The History of Trona Cloud Hazardous Air Pollutants “Left Click” to Next Slide.

The History of Trona Cloud Hazardous Air Pollutants

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Furnace

Calciner

An Industrial furnace and a rotating cylinder, called a “calciner”, are used to convert trona into soda ash.


Furnace

Calciner

Air

Coal / Nat Gas

Coal, or natural gas are used to generate the heat needed. This results in combustion products of CO, CO2, NOX and water vapor.

CO, CO2, NOX, H20

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Furnace

Calciner

Air

Coal / Nat Gas

Extra air is also fed through the furnace and calciner to help carry the heat from the furnace into the calciner.


Furnace

Calciner

Na2CO3NaHCO32H2O Na2CO3

Trona in Soda Ash out

HEAT

In order to make soda ash, the trona is heated to about 350 F.


Furnace

Calciner

Na2CO3NaHCO32H2O

2H2O +CO2

Na2CO3

Trona Soda Ash

HEAT

The trona also releases CO2, and H20 (water), with each molecule of trona that is converted to soda ash.


Furnace

Calciner


Trona Soda Ash

HEAT

Trona ore is not pure but may contain up to 50% of oil shale products. Typically ore grades are maintained at above 80% trona to conserve energy.

+Insoluble Material / Oil Shale Insoluble Material / Oil Shale

+


Furnace

Calciner


Trona Soda Ash

HEAT

When trona ore is heated, oil shale products are also heated, releasing hazardous air pollutants or “HAPS”.

+Insoluble Material / Oil Shale Insoluble Material / Oil Shale

+

HAPs2H2O +CO2


Furnace

Calciner

Air

Coal / Nat GasTrona + Oil Shale Soda Ash

The State of Wyoming has monitored these smoke stacks or point sources for combustion products (CO, CO2) and particulates, or dust (Opacity).


Furnace

Calciner

Air

Coal / Nat GasSoda Ash

The State of Wyoming, did not recognize the potential for HAPS until the 1990s, when suspected liquid oil shale products were found in stack monitoring equipment, during routine stack monitor certifications HAPs

Trona + Oil Shale


Calciner

Soda Ash

The Discovery of HAPs in the 1990’s Sounded Alarms at the State Capital and Corporate Boardrooms !!!

HAPs

HEAT

Trona + Oil Shale


Calciner

Soda Ash

Tests Were Conducted to Determine the Quantity and Nature of the HAPS

HAPs

HEAT

Trona + Oil Shale


HAPs testing resulted information about the Trona Cloud to become available on the Internet, at EPA’s

Website


Questions to the state of Wyoming about asbestos discharges and HAPs

Information, led to the discovery of alarming errors.


Dave Freudenthal. Governor

T h e S ta te of W yom ing

Departm ent of Environm ental Quality

AD M IN/OUTREA C

H (307)777-7758 FAX 777-3610

Herschler Building • 122 West 25th Street • Cheyenne, Wyoming 82002

ABAN DO NE D M INES A IR Q UA LITY INDU STRIA L S IT IN G LA ND QUA LIT Y SO LID & H AZ. W A STE

(307)777 -6145 (307)777 -7391 (307)777 -7369 (307)777 -77 56 (307)777 -77 52 FAX 777-6462 FAX 777-5616 FAX 777-6937 FAX 777-5864 FAX 777-5973

August 31, 2004 RE: HAPs

...your question about asbestos, we have not specifically entered any data into the EPA database. EPA used data from the National Toxics Institute database for 1996 and we do not know where NTI got it, however they did not get it from us or from the company. We downloaded that database several years ago and found it to be full of errors for a number of sources, so we basically threw it out. EPA has never fixed these problems which is why state agencies are so resistant to use these publicly accessible databases. …

Trona Cloud Information being provided to the public, via the EPA,

was not reliable.





AD M IN/OUTREA C

H (307)777-7758 FAX 777-3610


ABAN DO NE D M INES A IR Q UA LITY INDU STRIA L S IT IN G LA ND QUA LIT Y SO LID & H AZ. W A STE



You are correct that in the early 1990s there were no regulatory requirements associated with HAP emissions from trona calciners…. There still are no regulatory requirements.

…As a part of the investigation into this issue, tests were performed and it was determined that these plumes were composed of a number of compounds .. 5 of which are listed HAPs. The total emission of these HAPS was slightly over 5 TPY. …

Again, thanks for your interest…

…the State of Wyoming claimed 5 HAPS and slightly over 10,000

lbs/year…in sharp contrast to the EPA reports…





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ABAN DO NE D M INES A IR Q UA LITY INDU STRIA L S ITIN G LA ND QUA LIT Y SO LID & H AZ. W A STE



…The quantification of HAPs back then was related to the observation of a blue plume sometimes formed some distance from the stack exit. The question at that time was whether compliance with opacity standards should be evaluated at the stack exit or downwind, where we knew a mixture of water vapor and condensable organic matter resulted in the blue plume…

Again, thanks for your interest…

…but the quantification of HAPs was based on just looking at the sky...


Calciner

Trona Soda Ash

HEAT

Oil Shale Products

HAPs…looks like 5 HAPs and

only 5 Tons per Year…looks like 5 HAPs and

only 5 Tons per Year…looks like 5 HAPs and

only 5 Tons per Year


What goes into The Trona Cloud ???

Calciner

Trona Soda Ash

HEAT

Oil Shale Products

HAPs


Maybe we better run some tests…


Calciner

Trona Soda Ash

HEAT

Oil Shale Products

HAPs


…oops…using these emission (FUDGE)

factors, it looks more like 25 HAPs and 2 million

pounds per year…


1,3-ButadieneAcetaldehydeAcetophenone

AcroleinAcrylonitrile

Antimony CompoundsArsenic Compounds

AsbestosBenzene

Beryllium CompoundsBiphenyl

Bis(2-Ethylhexyl)PhthalateCadmium Compounds

Carbon DisulfideChlorobenzene

Chromium CompoundsCobalt Compounds

CumeneDibenzofuranEthylbenzene

Ethylene DichlorideFormaldehyde

HexaneHydrochloric AcidHydrogen Fluoride

IsophoroneLead Compounds

Manganese CompoundsMercury Compounds

Methyl ChlorideMethyl Chloroform

Methyl Ethyl KetoneMethylene ChlorideNickel CompoundsPerchloroethylene

PhenolPolycyclic Organic Matter

Polycyclic Organic Matter as 16-PAHPropionaldehyde

Selenium CompoundsStyreneToluene

TrichloroethyleneXylenes (Mixed Isomers)

Trona Cloud HAPS Were Identified and Quantified(2 Million Lbs Per Year)


Trona HAPs Reporting -The Fruits of a Poisonous Tree?




??? 1990’s Test Work ???


??? 1990’s Test Work ???

Assumptions



Assumptions

Emission

Factors


??? 1990’s Test Work ???


Emission

Factors

Emission

Factors

Clean Air Act Compliance

Assumptions


??? 1990’s Test Work ???


Emission

Factors

Emission

Factors

Clean Air Act Compliance

Assumptions

To be continued?


??? 1990’s Test Work ???

The History of Trona Cloud Hazardous Air Pollutants “Left Click” to Next Slide.

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