EPA-450/3-89-008
CONTROL TECHNOLOGY ASSESSMENT REPORT

         FOR AIR EMISSIONS FROM

   WASTEWATER TREATMENT OPERATIONS
       CONTROL TECHNOLOGY CENTER

              SPONSORED BY:

          Emission Standards Division
    Office of Air Quality Planning and Standards
      U.S. Environmental Protection Agency
       Research Triangle Park, NC 27711

  Air and Energy Engineering Research Laboratory
       Office of Research and Development
      U.S. Environmental Protection Agency
       Research Triangle Park, NC 27711

   Center for Environmental Research Information
       Office of Research and Development
      U.S. Environmental Protection Agency
       Research Triangle Park, NC 27711
                  April 1989

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                                         EPA-450/3-89-008
                                         April 1989
CONTROL TECHNOLOGY ASSESSMENT REPORT

          FOR AIR EMISSIONS FROM

   WASTEWATER TREATMENT OPERATIONS


                     by

       Scott Harkins and Ashok S. Damle
           Research Triangle Institute
               P.O. Box 12194
  Research Triangle Park, North Carolina 27709


         EPA Contracts No. 68-02-4397



                Project Officer:

               Robert B. Lucas
          Emission Standards Division
   Office of Air Quality Planning and Standards
      U.S. Environmental Protection Agency
       Research Triangle Park, NC  27711


                Prepared for:

           Control  Technology Center
      U.S. Environmental Protection Agency
       Research Triangle Park, NC  27711

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                            ACKNOWLEDGMENT

      This report was prepared for the Control Technology Center by Scott Harkins
and Ashok Damle of Research Triangle Institute. The EPA Project Officer was Robert
B. Lucas of the Office of Air Quality Planning and Standards (OAQPS). Also
participating on the project team were Jim Durham of OAQPS, and Alfred Azevedo
and Carl Beard of the West Virginia Air Pollution Control Commission.

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                                  PREFACE

      This investigation of air emissions from wastewater treatment operations was
funded as a project of EPA's Control Technology Center (CTC).

      The CTC was established by EPA's Office of Research and Development (ORD)
and Office of Air Quality Planning and Standards (OAQPS) to provide technical
assistance to State and local air pollution control agencies.  Three levels of assistance
can be accessed through the CTC. First, a CTC HOTLINE has been established to
provide telephone assistance on matters relating to air pollution control technology.
Second, more in-depth engineering assistance can be provided when appropriate.
Third, the CTC can provide technical guidance through publication of technical
guidance documents, development of personal computer software, and presentation
of workshops on control technology matters.

      This investigation was  performed at the request of the West Virginia Air
Pollution  Control Commission. The report examines air  emissions from wastewater
treatment operations at a chemical manufacturing plant.  The report presents
information on existing emission controls and options for additional controls, with
associated costs.

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                              TABLE OF CONTENTS



1.0  INTRODUCTION 	 1

2.0  PROCESS DESCRIPTION  	 1

3.0  ESTIMATE OF UNCONTROLLED VOC AIR EMISSIONS 	 3

4.0  EMISSION REDUCTION MEASURES  	 6

5.0  EVALUATION OF CONTROL OPTIONS 	 7

     5.1  Refrigeration System Using Glycol  	 8

          5.1.1  Exit Gas Temperature = -5°C 	 8
          5.1.2  Exit Gas Temperature = 2°C	 8
          5.1.3  Energy Ba lance 	10
          5.1.4  Cost Estimate for Refrigerated Cooling  	13

       5.1.4.1  Recovery Credits  	14

    5.2  Carbon Adsorption System 	14

    5.2.1  Cost Estimate  	15

       5.2.1.1  Estimated Capital Costs 	15
       5.2.1.2  Estimated Operating Costs  	16

    5.3  Combined Refrigeration and Carbon Adsorption System 	16

    5.3.1  Cost Estimate  	'	17

       5.3.1.1  Capital Costs 	17
       5.3.1.2  Estimated Operating Costs  	17

    5 .4  Summary 	18

6.0  CONCLUSIONS 	18

7.0  REFERENCES 	20

APPENDIX 	21

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                         LIST OF FIGURES AND TABLES


Figure 1.  Simplified Schematic of Sampling Points	 2

Table 1.   Comparison of Vent Streams Measured by RTI during 9/86
          Samp 1 i ng Study	 4

Table 2.   Determination of Exit Gas Composition and Amount of
          Vaoors Condensed (-5°C)	 9

Table 3.   Determination of Exit Gas Composition and Amount of
          Vapors Condensed (2°C)	11

Table 4.   Physical Properties	12

Table 5.   Comparison of 3 Control Options	19

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1.0  INTRODUCTION

     The Occidental Chemical Plant at Belle, West Virginia produces Cj-
chlorinated solvents (e.g., methylene chloride, carbon tetrachloride, and
chloroform).  The wastewater generated at this plant is treated in organics/
solids decanters and a steam stripper to recover volatile organics before
discharge.  These operations result in substantial air emissions with high
concentration of volatile organics.  This report identifies and evaluates
various options available to control the air emissions of volatile organics
(VOCs).  The information gathered in field visits by Research Triangle
Institute personnel in September 19861 and July 19882 is usea to estimate the
total annual emissions of the VOCs as well as the maximum rate of emissions
due to working losses from the wastewater treatment operations.  Conden-
sation of organics in a refrigeration system, carbon adsorption and a
combination of both techniques are evaluated in this report as possible
control options.

2.0  PROCESS DESCRIPTION

     The wastewater at the Occidental Chemical plant consists of equipment
wash water and rainfall collected from diked areas around the plant;-
consequently, the flow rate and composition of the wastewater is cyclical and
dependent upon the amount of rain.  Plant personnel indicated in September
19861 that the steam stripper operated roughly 75 percent of the time.
Wastewater accumulates in a storage tank when the stripper is not operating1.
Once the stripper is started, it operates continuously until the wastewater  in
storage has been steam stripped.

     A flow schematic of the treatment system* is given in Figure 1.  (Figure
1  is a simplified block diagram because the more detailed process schematic
was considered to be confidential business information.)  The wastewater
enters one of two decanters (each approximately 20,000 gal capacity) where it
is processed as a batch.  Sodium hydroxide solution (caustic) is added to the
decanter to adjust the pH and flocculants are added to aid in solids removal.
The mixture is recirculated and mixed in the decanter and allowed to settle.
The wastewater (upper layer) is sent to the stripper feed (or storage) tank
(approximately 125,000 gal capacity).  The organic layer (at the bottom) is
removed from the decanter and sent to a surge or collection tank, and solids
are periodically removed and dried in a vacuum dryer.  The vapors from the
dryer are collected in a carbon bed adsorber unit.

     The steam stripper is started after a sufficient quantity of water has
accumulated in the storage tank.  The stripper feed passes through a heat
exchanger for preheating by the effluent from the stripper.  The stripper
column is packed with 1-inch saddles and processes about 12 gal/min.  The
stripper effluent, after cooling by the heat exchanger, enters one of two
open-topped holding tanks  (about 5,000 gal) where it is analyzed for
comparison with the discharge limits.  If the analysis is satisfactory, the
water  is pumped to a surge tank where the pH is adjusted for final discharge

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                  i
      S9
                Vant
              Condenser
      S1
Water
In
                  -S12
                   Vent
Decanter
          S3
                     S2
               Sludge
                            Water
                            S4
                            Organics
                                              S10
                                               I
Storage
             SB
              I
                                                          •
                                                       Carbon
                                                                       SB
                                                                               Vent
                                                                            Condenser
                                                                             Decanter
Stripper
                                                              Vapors


                                                                  S6
                                                                    Water
                                                                                     Water
                                                                   Holding
                                                                                Surge Tank
                                                       Condensate


                                                             -S7



                                                             S11
                                                                                  Collection
                                                                                     Tank
                                                                            Discharge to River
                                    Figure 1. Simplified schematic of sampling points.

                                           (SI, S2,  ...  S12 indicate sampling  locations
                                            during 9/86  sampling  study by RTI)
                                                                             1

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to the river under the NPOES permit.  Additional pH adjustments can be made at
the surge tank and final analyses of the water can be performed before
discharge to the river.

     The overhead vapors from the stripper pass through a condenser cooled
with cooling tower water.  The condensate enters a decanter that separates the
heavier organic layer from water.  The entire water layer is returned to the
steam stripper and the organic layer is drained periodically by the operator
to a small collection tank for recycle back to the process.  The collection
tank is open-topped and has a layer of water and sludge floating on too of the
organic layer.

     The condenser is vented through the decanter to a vent condenser as shown
in Figure 1.  The vent condenser is now equipped with a refrigeration system
with glycol coolant available at -10°C.  Although equipped, the condenser is
not yet run continuously at the  lower operating temperature.2  The vent
condenser receives vapors from the initial water/organics/solids decanters and
the steam stripper condenser/decanter.   The initial decanters and storage tank
are fixed roof tanks and have conservation vents that open as necessary to
prevent pressure buildup.
3.0  ESTIMATE OF UNCONTROLLED VOC AIR EMISSIONS

     The primary VOC air emission points at the above wastewater treatment
facility are the secondary (vent) condenser outlet and the conservation vents
on decanter and feedwater storage tanks which open whenever liquid is pumped
into these tanks (streams S9, S10, and S12 in Figure 1).  The concentration of
the volatile Ci-chlorinated solvents in the various vent emission streams were
measured in the detailed sampling study conducted by RTI in September 1986,*
and are given in Table 1.

     The measured concentrations of organics at the outlet from primary and
secondary condensers are very similar in Table 1 because at the time of this
sampling study,  the secondary condenser operated at a temperature similar to
that of the primary condenser, resulting in very little additional
condensation.  The secondary condenser is now equipped to use refrigerated
glycol as coolant instead of plant cooling water.2  This modification will
allow the condenser to cool the vent gases down to -5°C when fully
operational.   For the purpose of estimating uncontrolled emissions, the
measured concentrations (at the secondary condenser outlet as well as at other
vent streams) will be used and the effect of refrigerated glycol cooling will
be considered as one VOC control option.

     The vent streams are also nearly saturated with water vapor at the
respective stream temperatures due to the extended contact with the aqueous
phase.  Because of the immiscibility of water with the organics phase,  the
partial pressure exerted by water vapor will be close to the saturated vapor
pressure.   The balance of the vent stream flows is composed of air.

     During the September 1986 RTI sampling study,1 typical operating
conditions for the steam stripper and primary condenser were established.   The
feed rate to the stripper was about 10.8 gal/min (40.9 1/min)  and the

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TABLE 1.   COMPOSITION OF VENT STREAMS AS MEASURED BY RTI DURING 9/86 SAMPLING STUDY.
Stream
S8
S9
' S10
Sll
S12
Description
Primary Condenser
Vent
Secondary
Condenser Vent
Storage Tank Vent
Organics
Collection Tank
Vent
Solids Decanter
Vent

CH3C1
0.57
0.53
0.19
0.0051
0.77
Concentration, Mole %
CH2C12
39.18
38.59
11.04
1.81
28.57
CHC13
4.16
4.28
2.86
0.35
7.06
CC14
0.21
0.29
0.76
0.032
2.62

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corresponding average primary condenser vent flow was measured to be about
15.06 gal/min (57 1/min) at standard conditions.  The secondary condenser
outlet flow, however, was measured to be about 3.17 gal/min (12 standard
1/min) average.   The primary condenser outlet flow rate was measured by
venting the outlet directly to atmosphere.  In actual operation, the vapors
leaving the primary condenser travel through long piping to secondary
condenser, causing a significant back pressure (~ 1.5 psig) at the primary
condenser.  Also the primary condenser outlet vapors are in direct contact
with the  liquid in the collection tank.  Thus during flow measurement at the
primary condenser some of the liquid in the collection tank may also have been
flash vaporized causing additional flow.  Due to the uncertainties involved in
the primary condenser flow measurement and almost identical comoosition of
primary and secondary condenser outlet streams (indicating almost no
additional condensation in the secondary condenser) the flow rate leaving the
primary condenser is assumed to be the same as measured flow at the secondary
condenser; i.e., 3.17 gal/min (12 1/min) for a steam stripper feed rate of
10.8 gpm  (40.9  1/min).

     Attempts to measure the vent flows from the decanter tank and storage
tank with the liquid pumping into the tanks failed during the previous
sampling study because of opening of conservation vents.  The conservation
vents are designed to keep the headspace pressure in the tanks within 0.188 -
0.25 psi of atmospheric pressure.  Thus the rapid filling of liquid,  as
currently practiced, forces the conservation vents to open releasing tne
vapors to atmosphere.  The vent flows from these tanks may simply be assumed
to be equal to  liquid feed rate because of volumetric displacement of the gas
with incoming liquid.  The total amount and rate of tank vent gases displaced
is thus equal to the total volume and rate of the liquid feed in the decanter
and storage tanks.

     The relatively low vapor phase concentration at Sll and low working
losses from the low rate of condensate generation suggest that the air
emissions from the organics collection tank would be much lower than the other
sources; e.g., for the 10.8 gpm stripper feed rate the rate of primary
condensate is about 0.08 gal/min (0.3 1/min),  as compared to 3.17 gal/min (12
1/min) primary condenser vent flow rate.  Furthermore, the concentration of
organics  in the collection tank headspace is 2.2% as compared to 44.1% in the
condenser outlet vapors.  Thus, VOC emissions from Sll may be expected to be
only about 0.1% of the primary condenser outlet emissions.   Therefore, these
emissions will be ignored in the present study.

     Recent inquiries with Occidental Chemical Plant personnel^ indicated that
the total amount of the wastewater processed average to about 6.5 gpm for
24 hrs/day, 365 days/yr operation.  Thus the total amount of wastewater
processed in one year = 3.4164 x 106 gallons (-12.93 x 106 liters).   Since the
total amount of wastewater is fed into decanter tanks and subsequently to
feedwater storage tank  and then to steam stripper, the total amount of vent
flows from each of the major sources may be estimated for the above given
total annual wastewater flow.  The individual  organic compound annual
emissions may be determined using their measured concentration given in
Table 1:

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     1)  Decanter Tank Vent, S12:      12.93 x 105 liters/year & 25°C
           Methyl Chloride
           Methylene Chloride
           Chloroform
           Carbon Tetrachloride

                Total
  2.056 x 105 gm/yr
  1.284 x 107 gm/yr
  4.462 x 106 gm/yr
   -     x
                    452.9 Ib/yr
                    2.829 x 104 Ib/yr
                    9.827 x 103 Ib/yr
                   -l-J-QO x 103_Ib/yr
  1.964 x 107 g»/yr ~ 4.326 x 104 Ib/yr
     2)  Storage Tank Vent, S10:

           Methyl Chloride
           Methylene Chloride
           Chloroform
           Carbon Tetrachloride

                Total
12.93 x 106 liters/year & 25°C

~ 5.074 x 104 gm/yr ~ 111.77 Ib/yr
~ 4.963 x 106 gm/yr ~ 1.093 x 104 Ib/yr
~ 1.807 x 106 gm/yr ~ 3.981 x 103 Ib/yr
- 6.189 x 105 gm/vr -1.363^_LQ?_1 b/yr

  7.440 x 106 gB/yr - 1.639 x 104 Ib/yr
     3)  Primary Condenser
         Outlet Stream, S8:

           Methyl- Chloride
           Methylene Chloride
           Chloroform
           Carbon Tetrachloride

                Total
3.796 x 106 liters/year @ 0°C
4.878 x 104 gm/yr
5.644 x 106 gm/yr
8.424 x 105 gm/yr
5.480 x 104 qm/vr
                      107.45  Ib/yr
                      1.243 x 104 Ib/yr
                      1.856 x 103 Ib/yr
                      120.7 Jb/yr
  6.590 x 106 g»/yr - 1.452 x 104 Ib/yr
     The total uncontrolled VOC emissions from all 3 sources is thus
calculated to be about 33.67 Mg/yr, 74,163 Ibs/yr.
     Another important aspect from control standpoint is the rate of
emissions.  The rate of primary condenser outlet vapors is 12 standard 1/min
when the stripper is in operation, which would roughly be 60% of the time
given the normal stripper feed rate and average wastewater generation rate.
In the September 1986 study, the stripper operation time was estimated to be
about 75$ of the time1.  The reduction from 75% to 60% may be perhaps because
of reduced wastewater generation rate due to recent plant modifications.
Since the stream concentration used in estimation were the same as those used
in the September 1986 study, the reduced wastewater generation rate resulted
in a lower estimate of 33.7 Mg/yr VOC emissions as compared to 44 Mg/yr
estimate1 in the previous sampling study report.  The normal pumoing rates as
provided by plant personnel during RTI's recent visit^ are:  48 gpm for
wastewater feed into decanters and 120-140 gpm for liquid feed from decanters
to feedwater tank.   Thus liquid feed operation into decanters is carried out
over only 13.5% of total time and the liquid pumping into feedwater tank
occurs only 5% of the time.

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4.0  EMISSION REDUCTION MEASURES

     The emissions from the  feedwater storage  tank  result when  liquid  is
pumped  from  the decanter  tank  to  the  feedwater tank.   Due to  the  high  rate  of
liquid  pumping the conservation vent  opens  letting  out  the  emissions.   At
present the  feedwater  tank headspace  is  not  connected  to the  decanter  tank
headspace.   The vapor  emissions from  feedwater tank may be  prevented by simply
connecting the feedwater  tank  headspace  to  the decanter tank  head space by  a
duct.   This  will allow the displaced  vapors  to enter the decanter tank  during
liquid  pumping operation.  The duct should  be  of  large  enough size to  handle
130 gpm or 17.4 ft3/min (492.1 1/min) flow  rate with minimal  pressure  drop  «5
inches  of water ~ 0.2  psi) to  prevent opening  of  the conservation vent.  This
simple  ducting arrangement will eliminate 7.44 Mg/yr (16,402  Ibs/yr) VOC
emissions from the feedwater storage  tank,  and the  total VOC  load on a  control
system-  will  be reduced to 26.23 Mg/yr or 57,753 Ibs/yr.  Recent discussion
with plant personnel2  indicated that  this duct installation will  cost  UD to
$3,000  including materials and labor.

     In order for any  control  system  to  be effective all the  vent emission
must pass through the  control  system.  Thus  a  forced drive  system downstream
of a control system is essential  to prevent  opening of  conservation vents on
the decanter and feedwater tanks.  The fan or  blower must automatically be
turned  on whenever any liquid  pumping operation starts  or the steam striooer
is running.  The vent  flow rate from  primary condenser  is typically 12  stan-
dard 1/min, which will be present 60% of the time.  The maximum flow rate that
the drive system would need  to be able to handle  is 12  standard 1/min  + 182
lit/min (48 gal/min) from the  decanter tank  or  about 194 1/min  (7 ACFM) total.
Thus the fan must be able to deliver  7 ACFM  of  maximum  flow in order to
prevent pressure buildup  in the decanter and feedwater  tanks  during liauid
filling operations and consequently to prevent  opening  of conservation  vents.
The fan should also be able to reduce the flow  to 12 1/min when only the steam
stripper is  in operation  to prevent excessive  vacuum in the decanter and
feedwater tanks.   Due  to  the variability of  the total vent emission'flow rate.
the fan should be of flexible  capacity from  10  to 200  1/min (0.3  to 7.5 ACFM)
and its operating caoacity should be controlled by  the  wastewater  treatment
operation.

     Also it is very important to prevent any  unwarranted emissions such as
those occuring through overflow vents for liquid  level.  During RTI's earlier
sampling trip,1 it was found that vapors from  the decanter tanks  were
discharging at ground  level through pipes installed as  overflow lines
connected near the top of the  tanks.   These  lines were  plugged for RTI's
sampling and were reported to  plant personnel  for modification such as
installation of traps  on decanter tank overflow plumbing.   No vent control
system will operate properly when vent gases discharge  through uncontrolled
exits.   This problem was reidentified to current plant  personnel  during RTI's
most recent sampling trip2,  for proper modifications.

5.0  EVALUATION OF CONTROL OPTIONS

     The emission of volatile organics from  the steam stripper plant may De
reduced by condensing  the organics at a  lower  temperature or by using a carbon
adsorption system.   A combination of  both approaches is also possible.   The
secondary vent condenser at Occidental's wastewater treatment plant is now

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equipped to use refrigerated glycol at -5 to -10°C as coolant.  This lower
operating temperature as compared to primary condenser would allow additional
organics to condense thereby reducing their emissions.  Carbon adsorption
systems have been shown to be very effective for removing chlorinated
organics.3  The Occidental plant uses such a carbon adsorption system to treat
sludge dryer emissions.  The dryer vapor emissions are thus reported to be
reduced by more than 99%.2

5.1  Refrigeratjon_System Using Jjlycqj

5.1.1  Exit Gas Temperature = -5°C

     The refrigerated glycol is available at -5 to -10°C.  Thus it may be
assumed that the vent gases can be cooled only down to -5°C.  Because of the
intermittent nature of the two primary emission sources and difference in the
stream compositions, the condenser performance can change with time.  Looking
at the estimate of total emissions, almost 75% of the total VOC emissions come
from decanter tank vent.  The maximum load that the condenser will experience
may be determined by assuming that the liquid is pumped into the decanters
while the steam stripper operates.  The total maximum vent flow rate at such
conditions would be ~ 194 1/min with a comoosite composition of S8 and S12
stream as follows:

                      CH3C1             0.76 mol%
                      CH2C12           29.23 mol%
                      CHC13             6.88 mol%  •
                      CC14              2.47 mol%
                      Inerts + Water   60.66 mol%

     The stream may also be assumed to be saturated with water vaoor at the
primary condenser exit temperature of 21°C.  Since water is immiscible with
organics phase, its concentration in the vent gases would be 2.45 mol%.
corresponding to the saturated vapor pressure.

     For the above feed composition and for condenser exit vapor temperature
of -5°C. the amount of vapor that would be condensed may be calculated from
equilibrium considerations as shown in Table 2.  The calculations take into
account the immiscibi1ity of the water and organic phases and uses Raoult's
law to calculate equilibrium vapor pressure of each organic component.  The
computation for vapor exit temperature of -5°C indicate that almost 11.1% of
the organic vapors may be condensed in the secondary condenser.

     Applying individual condensation efficiencies for each component total
organic vapor emissions after condensation may be estimated:

       Methyl Chloride                 ~ 2.099 x 105 gm/yr ~ 462.3  Ib/yr
       Methylene Chloride              ~ 4.542 x 106 gm/yr ~ 10,000 Ib/yr
       Chloroform                      ~ 6.217 x 105 gm/yr ~ 1,369  Ib/yr
       Carbon Tetrachloride            ~ 1.499 x 105 qm/yr ~ 330.2  Ib/yr

        Total VOC Emissions              5.524 Mg/yr ~ 12,166  Ib/yr

      In terms of VOC mass emission, the secondary condenser operated at gas
exit temperature of -5°C would reduce mass emission by 78.9% to 5.52 Mg/yr.

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TABLE 2.  DETERMINATION OF EXIT GAS COMPOSITION AND AMOUNT OF VAPORS CONDENSED.
                         Basis:   1  gmole of Feed Vapor
                          Exit Gas  Temperature = -5°C
Feed Gas
Component
CH3C1
CH2C12
CHC13
CC14
— — - •
H20
Inert
•• • 	
Moles in
Feed Gas
0.0076
0.2923
0.0688
0.0247
	 	 • • ...
0.0245
0.5821
% of Feed
Condensed
17.49
75.43
88.28
93.15



Moles
Condensed
0.001329
0.2205
0.06074
0.0230


0.30556
ni
Moles
in Gas
0.00627
0.07182
0.00806
0.00169
0.0028
0.5821
0.67274
XT
Organic Phase
Mole Function
0.004350
0.721576
0.198774
0.075299


Ki
Relative
Volatility
2.1434
0.14792
0.06030
0.03339


Mi
Equilibrium Gas
Phase Mole Fraction
0.009324
0.106735
0.011986
0.002514



YI = Hi/En,
Gas Phase Mol
Fraction
0.009321
0.106753
0.011985
0.002514
0.004162
0.865265
1.0

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5.1.2  Exit Gas Temperature = 2°C
     Because of the intermittent nature of emissions one potential problem  in
keeping condenser exit gas temperature below 0°C is  icing.  Whenever vapor
flow to condenser stops, ambient humidity can easily enter the condenser and
cause icing blockage problems.  One way to prevent icing is to keep the exit
gas temperature above 0°C.  Therefore, condensation eauilibrium calculation
were also carried out for exit gas temperature of 2°C, as shown in Table 3.
Because of the higher exit gas temperature, the condensation of orqanics would
be decreased to about 67.4%.  By applying individual condensation efficiencies
for each component, the total organic vapor emissions after condensation at
2°C may be estimated:
       Methyl Chloride
       Methylene Chloride
       Chloroform
       Carbon Tetrachloride

         Total VOC Emissions
          - 2.241 x 105 gm/yr ~ 493.7   Ib/yr
          ~ 6.669 x 106 gm/yr ~ 14.696  Ib/yr
          ~ 1.012 x 106 gm/yr ~ 2,229   Ib/yr
          - 2.559 x 105 qm/yr ~_56.3..6L JJp/yr

            8.161 Mg/yr ~ 17,976 Ib/yr
     The reduction in VOC mass emission in this case would be 68.9%, with
emissions of 8.16 Mg/yr.

5.1.3  Energy Balance

     The existing secondary vent condenser consists of eight (8) 3/4" ID and
10' long tubes.  In order to determine the ability of this condenser to handle
all of the vent vapor emissions load, an energy balance was carried out.
Since the gas cooling to -5°C involves maximum condenser duty with minimum
temperature driving force, the exit gas temperature was assumed to be -5°C in
energy balance calculations.

     Basis (mass balance):  1 gmole of feed gas to condenser @ 25°C

     Basis (energy balance):  Enthalpy of liquid phase = 0 @ -5°C

Assume that gases are cooled down to -5°C at exit.  The physical properties of
each component in the gas phase are given in Table 4.  The mole fraction of
each component in the feed and exit gases as well as moles of liquid condensed
are given in Table 2.

     Enthalpy of condensate liquid out = 0

     Enthalpy of exit gases (as given by latent heat):
         CH3C1
         CH2C12
         CHC13
         CC14
         H20
         Air
0.00627 x 4934.36
0.071818 x 7232.12
0.008063 x 7791.77
0.001691 x 8070.58
0.0028 x 10991.48
Latent heat ignored
          Total Enthalpy of Exit Gases
   30.94 cal
  519.40 cal
   62.83 cal
   13.65 cal
   30.78 cal
  _Q	

= 657.60 cal
                                     10

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TABLE 3.   DETERMINATION OF EXIT GAS COMPOSITION AND AMOUNT OF VAPORS CONDENSED.

                         Basis:   1  gmole of Feed Vapor
                          Exit  Gas  Temperature = 2°C
Feed Gas
Component
CH3C1
CH2C12
CHC13
CC14
H20
Inert
Moles in
Feed Gas
0.0076
0.2923
0.0688
0.0247
0.0245
0.5821
% of Feed
Condensed
11.89
63.92
80.92
88.31



Moles
Condensed
0.000903
0.186838
0.055672
0.021812


0.265227
ni
Moles
in Gas
0.00669
0.10546
0.01313
0.00289
0.0050
0.5821
0.71527
*1
Organic Phase
Mole Function
0.003407
0.704445
0.209906
0.082241


Ki
Relative
Volatility
2.7486
0.2093
0.08742
0.04912


KiXi
Equilibrium Gas
Phase Mole Fraction
0.009364
0.14744
0.01835
0.004039



Yi = ni/Eni
Gas Phase Mol
Fraction
0.009361
0.147442
0.018352
0.004036
0.00699
0.81382


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                                         TABLE 4.  PHYSICAL  PROPERTIES
r\>
Component
CH3C1
CH2C12
CHC13
CC14
H20
Air
Heat of
Vaporization
(? -5»C
cal/gmole
4934.36
7232.12
7791.77
8070.58
10,991.48
—
Gas Phase
Specific Heat
(-5° to 25°C)
cal/gmole °K
9.44
11.81
15.37
19.71
8.014
6.902

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Enthalpy of gases entering condenser (as given by latent and sensible
     :
     heat)
         CH3C1
         CH2C12
         CHC13
         CC1
         H20
         Air
       4
0.0076 x (4934.36 + 9.44 x 30)   =   39.65 cal
0.2923 x (7232.12 + 11.81 x 30)  = 2217.51 cal
0.0688 x (7791.77 + 15.37 x 30)  =  567.80 cal
0.0247 x (8070.58 + 19.71 x 30)  =  213.95 cal
0.0245 x (10991.48 + 8.014 x 30) =  275.18 cal
0.5821 x (6.902 x 30)            = _12CL_53_ca1
                  Total Enthalpy of Feed Gas                  = 3434.62 cal

     Therefore, energy removed in the condenser = 2777 cal/gmole feed gas.

     Maximum flow rate of feed gas = 194 1/min @ 25°C =7.93 gmoles/min.

     Thus maximum condenser heat duty = 7.93 x 2777.02
                                      = 2.202 x 104 cal/min
                                      = 87.39 Btu/min
                                      =0.44 ton of refrigeration

     Existina secondary condenser inside surface area = rr x (0.75/12) x 8 x 10
                                                      = 15.71 ft2
     Assuming glycol temperature of -6°C on cooling liquid side, the log mean
temperature gradient = 8.74°C.  Therefore, to achieve, the maximum required
condenser duty the overall heat transfer coefficient required

                             = 87.39 x 60 / (15.71 x 8.74 x 1.8)
                             = 21.2 Btu/hr-ft2-°F

     Since the typical value for overall heat transfer coefficient for
condensers is usually between 40 - 100 Btu/hr-ft2-°F.  the existing condenser
may be expected to satisfactorily handle the maximum condensation load.

5.1.4  Cost Estimate for Refrigerated Cooling

     Since the secondary condenser is already in place and equipped for glycol
cooling,  no additional capital cost is reauired.  The maximum heat duty
required is only 0.44 tons of refrigeration.  According to the plant
personnel2 10-15 tons of refrigeration capacity is currently available at the
plant site with an operating cost of $1000/ton/year.

     Thus the operating costs associated with glycol  cooling would be less
than $500/year.  In addition, operator/maintenance labor cost may be
considered as ~ $1.825/yr, @ 0.5 hr/day and $10/hr.  The total operating costs
may thus be calculated to be about $2,325/yr.
                                     13

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     5.1.4.1  Recovery Criggjts

     With a condenser operating temperature of -5°C almost 45,580 Ibs of
organics will be recovered per year.  The corresponding recovery credit will
be $5,700/yr @ $0.125/lb of organics recovered.

     For higher condenser operating temperature of 2°C about 39.780  1b of
organics will be recovered resulting in $4,970 recovery credit @ $0.125/lb of
organics recovered.

5-2  Carbon Adsorption System

     Since the maximum expected vent flow rate is only 194 1/min (~ 7 ft3/min)
the design of carbon adsorption system will simply be based on the desired
capacity.  The activated carbon may generally be expected to be very efficient
for higher chlorinated hydrocarbons.3  The adsorption capacity of activated
carbon for methyl chloride under dry conditions is about 0.03 lb/ Ib carbon.
whereas for methylene chloride, chloroform and carbon tetrachloride the
capacity under dry conditions  is about 0.5 Ib/lb carbon according to one
vendor.3  The low capacity for methyl chloride will not be a significant
problem in the present case due to its low gas phase concentration compared to
methylene chloride.  For humid saturated conditions the dry capacities may be
reduced3 by 60 - 70%, i.e.. the reduced capacity would be 0.02 Ib/lb carbon
for methyl chloride and 0.35 Ib/lb carbon for the other organics.  The removal
efficiency for all organics is expected to be greater than 99% for inlet vapor
concentrations in the percentage ranges.  Methyl chloride is likely to be the
first compound to break through due to its low capacity for adsorption.

     For a system employing parallel beds with alternate adsorption and steam
regeneration, the working caoacity may be expected to be reduced as compared
to fresh carbon capacity.  Due to the low boiling compounds,  the working
capacity is likely to be reduced by only 5% according to one vendor.3  For a
conservative estimate, a 50% reduction in the capacity will be assumed in the
present case.  Thus the capacity of carbon under water saturated conditions
may be considered to be 0.01 Ib/lb carbon for methyl chloride and 0.17 Ib/lb
carbon for other organics.

     The total emission of uncontrolled organics as estimated in sections 3.0
and 4.0 is about 57,800 Ib/year or about 158.4 Ib/day.  For a one-day
adsorption/regeneration cycle,  the amount of carbon required in the adsorption
bed using capacity for higher hydrocarbons is 932 Ibs.  Due to low concen-
tration of methyl chloride, this amount of carbon will have an adequate
capacity to adsorb all of methyl chloride as well.

     For design consideration,  two parallel beds holding 1000 Ib of activated
carbon each may be assumed.  With a typical carbon bulk density3-4 of about 30
lb/ft3, the volume of the carbon bed is calculated to be 33.33 ft3.   A 3.5'
dia, 6.5' tall vessel with an  internal volume of 62.8 ft3 will be adequate to
house 1000 Ibs of carbon.  Steam stripping of an exhausted bed followed by
condensation may be expected to recover almost 90% of the organics.   The vent
stream flow from the adsorber/condenser may be added into the total vent
stream of the wastewater treatment plant to be processed again.   Condensate
liquid may be decanted into organic and aqueous fractions.  The organic
                                     14

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fraction may be recycled to the process along with the organic condensate from
primary and secondary condensers.  The aqueous stream can be sent back to the
wastewater treatment system, making all streams integrated to the existing
wastewater treatment plant.

     With a 99+% removal efficiency in the adsorber the organic emissions will
be reduced to 580 Ib/year or less.  Since the wastewater treatment system is
of intermittent nature, the carbon adsorption beds must be equipped with a VOC
detector at the outlet to signal breakthrough and need for regeneration.

5.2.1  Cost Estimate

     5.2.1.1  Estimated ._CajDitaljCp.sts

     The capital and operating costs associated with the carbon adsorption
system may be estimated using the guidelines provided in the EA8 Control Cost
Manual.5

         Initial Carbon, 2000 Ibs                      $ 4,000
           @ $2/lb of fresh carbon

         2 Adsorber Vessels                             15,000
         (3.5' diameter, 6.5' tall)

         Fan, pumps, decanter,
          condenser, internal piping                   	LAQO
            [0.39 (4,000 +  15,000)]

         Adsorber equipment total cost                 $26,400

         Instrumentation, taxes,
          freight, (0.18 x  26,400)                     ._j*..750

         Total purchased equipment                     $31,150

         Installation Cost  (-30%)
          (foundation, supports,
          erection, electrical,
          piping, insulation, etc.)                      9,350

         Indirect cost (-31%)
          (engineering, supervision,
          construction and  field expenses,
          construction fee, startup, etc.)               9,650

         Cost of ductwork^  to bring vent
         gases from secondary vent condenser
         outlet to adsorber system (including
         installation)                                 	5jpOO

                 Total Capital Investment              $55,150
                                     15

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     5.2.1.2
                 jOBerat_irrg .Costs
i)  Steam Cost:   steam consumption @ 3.5 Ib/lb adsorbed VOC
                                   ~ 2.023 x 105 Ib/yr
           Steam cost @ $5/1000 Ib

      ii)  Cooling water cost:
           (same as steam cost)

     iii)  Electricity
           (very little pressure drop
            across bed due to low flow)
                                                $l,000/yr

                                                 1.000/yr


                                                   200/yr



                                                 1,200/yr



                                                 7,420


                                                 3,650/yr


                                               $14,470

                                               $ 6.500/yr
      iv)  Carbon replacement
           (for 5-year carbon life)
           0.2638 (1.08 x 4000) + 250

       v)  Indirect annual cost
           [50,150 - (1.08 x 4000 +250)] x 0.1628

      vi)  Operating and maintenance labor
           (1 hr/day @ $10/hr)

            Total Annual Operating Costs

           Possible Recovery credit
           (with a 90% recovery, rate about 52,020 Ib
           of organics will be recovered every year
           resulting in $6500 recovery credit
           @ $0.125/lb) of recovered organics)

5.3  Cpmbined JRefrj^ej.atJon_and_Caf^ojn__Adsprp_tjort.System

     In this option, a carbon adsorption system will be installed downstream
of the secondary vent condenser to take advantage of the existing secondary
condenser facility and to reduce load on the carbon adsorption system.
Because of the icing problems associated with lower operating temperature of
-5°C, the condenser is assumed to operate at a temperature of 2°C.  From
section 5.1.2, the resultant organic loading on the carbon adsorption system
would be about 18,000 Ib/year, or about 49.3 Ib/day.

     The secondary condenser also will reduce the amount of water vaoor in the
gas stream considerably increasing the adsorption capacity of the activated
carbon.   Assuming a conservative 50% reduction in the carbon capacity due to
regeneration, the capacity of the activated carbon may be assumed to be 0.25
Ib/lb carbon.  The amount of carbon required for one day cycle is therefore
about 200 Ib/day.  The corresponding volume of carbon would be 6.67 ft3.  A
vessel of 2' diameter and 4' depth with an internal volume of 12.6 ft3 will be
able to house 200 Ibs of activated carbon.

     Due to low concentration of methyl chloride, this amount of carbon will
have an adequate capacity for adsorbing all of the methyl chloride as well.
                              16

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With 99+% removal efficiency for organics, their emission may be expected to
be reduced to 180 Ib/year or less.  Again, due to the intermittent nature of
the wastewater treatment system, the carbon adsorption beds must be equipped
with a VOC sensor at the outlet to signal VOC breakthrough and need for
regeneration.

     Because of the intermittent nature of the wastewater treatment system,  it
may also be possible to use a single larger bed of carbon and regenerate it
every 4 to 5 days whenever steam stripper and liauid filling operation are not
in progress.  For example, a single bed of 1000 Ib carbon as discussed in
section 5.2 will be able to provide enough carbon for 5 days.  However, an
adsorption system with two smaller beds may be preferable as it will not out
any constraints on the main wastewater treatment plant.

5.3.1  Cost Estimate

     A two-bed system with each holding 200 Ib of carbon is considered for
cost estimation.  The capital and operating costs are based on the EAB Control
Cost Manual guidelines.5
     5.3.1.1
ital  Costs
     Capital costs may be determined using rule of scale and the cost of the
larger system discussed in 5.2.  Using a scaling factor6 of 0.6, the capital
cost for the adsorption system may be estimated to be:

                             - $50,150 (l/5)0-6     ~ $19,100

         Cost of ductwork2 to bring vent                5,000
         gases from secondary vent condenser
         outlet to adsorber system (including
         installation)

         Total Capital Investment                     $24.100

     5.3.1.2  Estimated Operating Costs

        i)   Steam cost: (? 3.5 Ib/lb of adsorbed VOC    $  340/yr
                        and $5/1000 Ib steam

       ii)   Cooling water cost                            340/yr

      iii)   Electricity                                   200/yr

       iv)   Carbon replacement for 5-year                 300/yr
            carbon life:   0.268 (1.08 x 800 + 250)

        v)   Indirect annual cost for carbon             2,930/yr
            adsorption system
            [19,100 - (1.08 x 800 + 250)] x 0.1628

       vi)   Glycol refrigeration cost (section 5.1.4)      500/yr
                                     17

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      vii)  Operating and maintenance labor             5,474/yr
            (1.0 hr/day @ $10/hr) - Adsorption sys.
            (0.5 hr/day @ $10/hr) - Refrigeration sys.

             Total Operating Costs                    $10,085/yr

            Possible Recovery Credit:

            Secondary Condenser System (sec. 5.1.4.1)   4,970/yr

            Adsorption System                           2,030/yr
            (With a 90% recovery rate, about 16,200 Ibs
             of organics will be recovered every year
             by the adsorption system resulting in
             $2,025 credit 9 $0.125/lb

            Total Recovery Credit                      $7,000/yr

5.4  Summary

     The estimates for cost, emission of organics and recovery of organics for
each option are summarized in Table 5.  Due to the limited time available for
this study, no optimization of the control systems is made, e.g. adsorption
cycle time.  The costs presented are therefore rough estimates for preliminary
assessment.  As seen from this table, use of secondary vent condenser with
refrigerated glycol cooling followed by carbon adsorption offers the lowest
cost for high organics removal efficiency.  The refrigerated cooling alone
provides the best ratio of organics removed per total cost, however, it will
still result in significant organic emissions of 12,000 to 18,000 Ibs/year.


6.0  CONCLUSIONS

     Based upon this study, the following conclusions may be drawn for
efficient organics removal from wastewater treatment system vent VOC emissions
at the Occidental Chemical Plant at Belle, West Virginia.

     1.  Connecting the headspaces of storage feedwater tank and decanter
         tanks will eliminate the source of VOC vent emissions (working
         losses) at the feedwater tank.   This will result  in 7.44 Mg/yr
         reduction in VOC emissions.

     2.  For any control system to be effective, a forced drive system such as
         a fan or blower at the downstream of the control system is essential
         to carry the vent gases through the system and to prevent opening of
         the conservation vents.  Moreover, the fan should be of flexible
         capacity controlled by wastewater treatment operations.  For example,
         whenever liquid is being filled in the decanter tank, the fan must
         pull vent streams at the same rate as liquid pumping rate; and when
         only the steam stripper is running the fan must reduce the vent flow
         rate accordingly so as not to cause any vacuum in the storage or
         decanter tanks.
                                     18

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                              TABLE 5.  COMPARISON OF  THREE  CONTROL  OPTIONS.
Option f
1
1A
2
3
Description
Refrigerated
cooling at -5°C*
Refrigerated
cooling at 2°C
Carbon adsorption
alone
Refrigerated
cooling at 2°C
followed by
carbon adsorption
Amount of
Organ ics Removed
(Ibs/yr)
45.590
39,750
57,170
57,570
VOC Emissions
( Ibs/yr)
12,160
17,980
580
180
Total
Capital
Cost, $
—
—
55,150
24,100
Annual
Operating
Costs, $/yr
2.325
2,325
14.470
10.090
Possible
Recovery
Credit, $/yr
5.700
4,970
6.500
7,000
Possibility of icing blockage problems

-------
     3.  It is necessary to prevent any unwarranted vapor emissions such as
         those occurring through overflow vents for liquid level (e.g.,
         decanter tank overflow plumbing) by installing liquid traps.

     4.  The secondary vent condenser is capable of condensing up to 68% by
         mass of vapors in the feed stream using refrigerated glycol cooling
         operated at the gas exit temperature of 2°C.   This will result in
         recovery of 18.07 Mg/yr of organics with annual VOC emissions of 8.16
         Mg/yr.

     5.  A combination of the refrigerated glycol cooled secondary condenser
         and a subsequent carbon adsorption system will be able to remove
         almost all of the organics in the vent emissions at a lower cost than
         that for a carbon adsorption system alone.  The value of recovered
         organics will be able to pay for almost 70% of the total operating
         costs.   The VOC emissions may be expected to be reduced to 180
         Ibs/yr.

7.0  REFERENCES

1.   Branscome,  M., S. Harkins,  and K. Leese, "Field Test and Evaluation of
     the Steam-Stripping Process at Occidental  Chemical, Belle,  WV", Research
     Triangle Institute Project  Report prepared for Hazardous Waste
     Engineering Research Laboratory,  U.S. EPA  Contract No.  68-03-3253, Work
     Assignment 1-6, March 1987.

2.-   Harkins,  S.   Report to EPA/OAQPS of trip to Occidental  Chemical Plant,
     Belle, WV,  September 1988.   (Attached as an Appendix to this report).

3.   Roy, Al,  Calgon Corporation,  Technical Representative,  personal
     communication. August 1988.

4.   Spivey, J.J.,  "Recovery of  Volatile Organics from Small Industrial
     Sources",  Environmental  Progress, Vol. 7,  No.  1,  pp.  31-40,  February
     1988.

5.   Vatavuk,  W.M., W.L.  Klotz and R.L.  Stallings,  "Carbon Adsorbers" Section
     4 in EAB Control Cost Manual, 3rd ed., EPA 450/5-87-001A,  February 1987.

6.   Peters, M.S.  and K.D.  Timmerhaus, "Plant Design and Economics for
     Chemical  Engineers",  pp.  166-167, McGraw-Hill  Bank Company,  New York,
     1980.
                                     20

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                    APPENDIX



Report for RTI Trip to Occidental Chemical Plant,



              Belle, WV. July 1988
                       21

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  RESEARCH  TRIANGLE  INSTITUTE

  Center for Process Research                                                James J. Spivey, Ph.D
                                                                         Director

       		September 12. 1988	


       MEMORANDUM


       TO:    Robert B. Lucas,  EPA/OAQPS

       FROM:  Scott Harkins.  RTI

       RE:    Report for the  Trip  to  Occidental  Chemical  Plant. Belle. WV
       Purpose
            The purpose of this trip was to discuss organic  vapor  emissions from
       Occidental's steam stripper and wastewater treatment  operations,  source of the
       emissions, and possible control options; and to obtain  additional information.

       Place

            Occidental Chemical Corporation
            Electrochemicals Division
            Belle Plant
            P.  0. Box 615
            Belle,   WV 25015

      Attendees

            Scott Harkins.  RTI

            Robert  Lucas, EPA-OAQPS

            Al  Azevedo. West  Virginia APCC

            Larry Hearn,  Occidental

            Steve Meadows,  Occidental
Post Office Box 12194        Research Triangle Park, North Carolina 27709        Telephone:  919 541 -6000

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 S. Harkins Trip Report to Lucas                    '


     On July 1. 1988 Scott Harkins (RTI)  and Bob Lucas (EPA/OAQPS)  conducted a
 site visit to the West Virginia Air Pollution Control Commission and the
 Occidental Chemical Corporation's Plant  in Belle W.Va.   This visit was to
 discuss organic vapor emissions from Occidental's steam stripper and
 wastewater treatment operations,  the generation of the emissions,  and possible
 control options.   Additional  process information was requested to assist in
 evaluating vapor  emissions control options.

     Bob Lucas and Scott Harkins initially met with Al Azevedo (West Virginia
 Air Pollution Control Commission  (APCC).  1158 Washington St.  East,  Charleston,
 W.Va.. 25311. (304) 348-4022) for an hour before proceeding to the Occidental
 plant.  At the Occidental plant Lucas, Harkins,  and Azevedo met with Larry
 Hum and Steve Meadows (Occidental Chemical  Corporation, Electrochemicals
 Division.  Belle Plant,  POB 615, Belle, W.Va..  25015,  (304)  949-4515).   Larry
 Hum was the principal  contact at the plant.   The steam stripper equipment was
 examined after a  discussion (approx.  1 hr)  with  the plant personnel.   Lucas,
 Harkins, and Azevedo ate lunch after leaving the plant.   This was  followed by
 a  short meeting at the  W.Va APCC  offices  prior to departure.

     Al Azevedo related  the APCC's recent  involvement  with the plant.   The
 W.Va.  APCC conducted a  risk assessment of air  pollutants in the Kanawa valley
 from the chemical  plants in the region.   Although the Belle Occidental plant
 is a relatively small chemical  plant the  risk  assessment indicated  its
 emissions  were the most significant  risk  in  the  area.   The  largest  source of
 emissions  from the plant was  fugitive emissions  while the second highest was
 from the wastewater processing  operations.   The  plant has hired a  contractor
 to check for  leaks on a quarterly basis.   The  discovered leaks are  then
 repaired to reduce fugitive emissions.  W.Va.  APCC would like the  Control
 Technology Center  (CTC)  of EPA/OAQPS to assess possible  control  technology
 options to minimize emissions of  volatile organic chemicals (VOC)   from the
 wastewater treatment  facility at  Occidental  Chemical.

     RTI  sampled the steam  stripper process and vents  in  September  1986 as  part
 of  an  EAA-ORD  project.   The vent  emission measurements and  estimates of total
 emissions  were used by  WVAPCC in  the risk assessment  for the  plant.  The vapor
 emissions  reported  by RTI  were much  higher than  earlier  estimates of vapor
 emissions  from the  wastewater treatment system (estimated as  79  Ibs of organic
 vapor/year  in  the  1984  inventory  of  the plant  site).  The organic vapor
 concentrations in gas above water  in  the  decanter  tanks  and feedwater  tank
 were much  higher than previously  believed.  The  ineffectiveness  of  the
 condenser  for  the decanter  tanks  (secondary steam  stripper  condenser)  was  not
 identified prior to RTI's  sampling of the wastewater  treatment process.

    Several changes to  the wastewater treatment  system have occurred since
RTI's 9/86 sampling of this process:

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S. Harkins Trip Report to Lucas
Page 2


    1)  A sludge drier is currently  being  installed  for  the  dehydration  of
    decanter tank sludge.   This drier  is adjacent  to the decanter  tanks  and
    feed sludge is pumped directly into the drier.   The  drier  operates under
    a vacuum and two  sets of condensers/decanters  are placed before and  after
    the vacuum  pumps.  Gases from the second condenser/decanter  (glycol
    cooled)  are passed through  two carbon beds  (in series) prior to
    discharge.   Used carbon beds will be collected by the activated carbon
    vendor/supplier and regenerated offsite.  The sludge dewatering system
    (when  operated properly) would not significantly  increase  the vapor
    emissions from the treatment operations due to the carbon  bed VOC control
    system installed.

    2)  Another significant change to the system was  the conversion of the
    decanter tank condenser from plant cooling water  to refrigerated glycol
    The operating temperature of the condenser will be -6 to -8 °C when
   operational.  This will condense much more of the vent gas from the
   primary steam stripper condenser.  It is connected to but will  not
   efficiently condense the vent flows from the decanter tanks during tank
   filling,  as these flows are too high for the condenser and the decanter
   tank conservation vents will open and vent to the atmosphere.

   3)  One modification  which  should have  occurred was  the installation  of
   traps on  decanter tank overflow plumbing.   During RTI's earlier sampling
   trip we found that vapors from  the decanter  tanks were discharging at
   ground level through  pipes  installed as  overflow lines connected near the
   top of the tanks.   These lines were plugged  for RTI's sampling  and were
   reported  to  plant  personnel  for modification.   No vent control  system
   will operate properly  when vent gases discharge through uncontrolled
   exits.  This problem was reindentified to current plant personnel  for
   proper  modification.

   4)   Several  modifications to the plant operating  conditions have reduced
   the volume of  wastewater for  treatment.  Heat exchangers  at several
   locations were changed  from  steel to titanium.  The new heat  exchangers
   require cleaning less  frequently and produce  less  wastewater  from  the
   cleaning operations.  New gutters were installed  on a plant building
   routing rainwater to rainwater discharge rather than  the  wastewater
   treatment plant.  Feed  filtering systems for the distillation columns
  were improved, increasing intervals between cleanings.  These changes
  result  in less operation of the wastewater treatment  system.  Although
  the above mentioned changes may reduce the total amount and rate of
  wastewater generation,  it may not necessarily reduce  the organic vapor
  concentration  in various vent streams as measured  in RTI's  September  1986
  sampling study.  Also, since the maximum vent flow rates are determined
  by  liquid pumping rate  into  the decanter and feedwater tanks and by
  operating  rate of the steam  stripper,  these flow rates will not be
  affected by these plant modifications.

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S. Harkins Trip Report to Lucas                    »
Page 3

    There are no current standards for the vent emissions and the control
design should remove a large percentage of the methyl chloride (Ch^Cl),
methylene chloride (Q^C^) chloroform (CHCla), and carbon tetrachloride
(CC14).  The vent emissions predominantly contain methylene chloride and
chloroform and thus the control strategy should focus on these to compounds.
    The measurements of vent concentrations and flowrates collected by RTI in
1986 will be used for the control design and calculations of vent emission
rates.  There are no additional data collected since the last study on the
process vent streams to be included in the design.  These data were collected
in the month of September but will be assumed to be representative of the
plant vapor emissions during the entire year.

    Additional information provided by Larry Hum of Occidental Chemical Plant
regarding wastewater treatment system operation is given below":
    1.    Refrigerated glycol temperature cooling

    2.    Refrigerated glycol availability at
         the plant

    3.    Glycol  operating costs at the plant

    4.    Steam cost  at the plant

    5.    Carbon  used in the adsorption system
         on  sludge dryer emissions

    6.    Carbon  cost (fresh)

    7.    Offsite carbon regeneration  cost


    8.    Recent  changes to steam stripper  operation
   9.   Size of the secondary vent condenser
   10.  Current average rate of wastewater
        treatment

   11.  Flow rate into decanter tanks
 -5*C  minimum

 10-15 tons  of
 refrigeration

 $1000/ton/yr

 $3.75/1000  IDS

 GAC 8-mesh  x 30 mesh
 from  PBS carbon

 $2/lb carbon

 $0.80/lb carbon +
 freight expenses

 Upgraded transfer pumps
 between decanter and
 feedwater tank

 Shell  and tube condenser
 consists of  8 tubes,
 3/4"  10. and 10' long

 6 to  7 gpm  for 24 hr/day
 365 day/yr operation

 48 gpm typical (37 gpm
wastewater,   11 gpm
caustic soda solution).
Transfer pumps rated
 from  25 to  100 gpm,  but
 long pipe length reduces
maximum flow rate.

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  S. Harkins Trip Report to Lucas
  Page 4


      12.   Flow rate  from decanter  to  feedwater  tank     120-140  gpm.   Pump  is
                                                        rated  at 140  gpm.

      13.   Distance between  decanter tank and            ~  25'  horizontal,
 -         storage tank-headspaces	n)*~vert1c"a"1	
      14.  Approximate cost estimate to connect         ~ $2000 - $3000
          the top of the decanter to the top of
          the storage tank

      15.  Height of decanter tank secondary vent       - 40'
          condenser

      16.  Length of duct required to bring the         - 150'
          gases from secondary vent condenser to the
          probable location of adsorption system
          on ground level

     17.  Cost to install the duct work to connect     ~ $4000 - $5000
          condenser outlet stream to adsorber unit

     18.  Approximate value of recovered and           ~ $250 - $300/ton
          organic condensate in condenser              - $0.125/lb of organics


     RTI will  prepare a  technical  and economic  evaluation of control options
 for the vent  stream.  Estimated costs  and emission reductions will be
 reported.   The  designs  will  be based on  the maximum expected vent flow with
 concentrations  based on RTI's previous vent sampling.   For all  designs the
 feedwater tank  will  be  vented to  a common  header  with  the decanter tanks.
 When liquid is  pumped from  the decanter  tanks  to  the feedwater  tank the gas
 displaced from  the feedwater  tank will flow into  the top of the  decanter
 tanks.   This vent  line  will eliminate  emissions associated with  water transfer
 from the decanters to the feedwater tank.   When water  is pumped  into the
 decanters gas from the  top of  the decanter tanks  will  be vented  through the
 control  system.  The control  system will also  handle the 12 1pm  vent stream
 from the primary steam  stripper condenser.

     A problem associated with  any control  system  for the  tank vents is  the
 tank operating pressure.  The  decanter tanks and  feedwater tank  were designed
 for  atmospheric operation.  The conservation vents  at  the  top of  the tanks
 open at very small pressure differences from atmospheric pressure.   If  an
 installed control system places more than  an extremely small  back  pressure on
 the vent lines the conservation vents will open and  vent displaced gas  to  the
atmosphere.   Since these vents are on top  of the  tanks, operators  would
probably not notice the discharge.  An alarm system  to indicate open
conservation vents could be installed to show a failure of  an installed vent
control system.

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