EPA-450/3-83-005aES
Distillation Operations In
Synthetic Organic Chemical
Manufacturing-
Background Information For
Proposed Standards
ERRATTA
Emission Standards and Engineering Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air, Noise, and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
FES 17 884
ERRATA FOR DISTILLATION OPERATIONS NSPS
BACKGROUND INFORMATION DOCUMENT
On December 30, 1983, the Administrator of the U.S. Environmental Protec-
tion Agency (EPA) proposed standards of performance for distillation operations
in synthetic organic chemical manufacturing under Section 111 of the Clean Air
Act, as amended. The standards would control air emissions of volatile organic
compounds from new, modified, and reconstructed distillation operations in the
United States. On January 10, 1984, the background information document and
Federal Register announcement for these proposed standards were made available.
The enclosed correct copy of Chapter 5 of the background information document
should replace the chapter that was included in the January 10, 1984 mailing.
Sincerely yours,
••N
/
C. Douglas Bell
Chief
Standards Preparation Section
1 Enclosure
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5. MODIFICATION AND RECONSTRUCTION
The distillation NSPS affects new distillation units and existing
distillation units that have been modified or reconstructed (in accordance
with the Code of Federal Regulations Title 40, Sections 60.14 and
60.15; 40 CFR 60.14 and 60.15). An existing facility is defined in
40 CFR 60.2 as a facility of the type for which standards of performance
have been promulgated and the construction or modification of which was
begun prior to the proposal date of the applicable NSPS standards. This
chapter identifies typical or possible changes to distillation operations
in synthetic organic chemical manufacturing plants that could be deemed
modifications or reconstructions.
5.1 MODIFICATION
"Modification" is defined in 40 CFR 60.14(a) as any physical or
operational change of an existing facility that increases the emission
rate of any pollutant to which a standard applies. Exceptions to this
definition are presented in paragraph (e) of Section 60.14. These
exceptions are:
1. Routine maintenance, repair, and replacement.
2. An increase in the production rate not requiring a capital
expenditure as defined in Section 60.2(bb).
3. An increase in the hours of operation.
4. Use of an alternative fuel or raw material if prior to the
standard the existing facility was designed to accommodate that alternate
fuel or raw material.
5. The addition or use of any system or device whose primary
function is the reduction of air pollutants, except when a system is
removed or replaced by a system considered to be less efficient.
6. Relocation or change in ownership.
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If any other modification is made to the operation of an existing
facility that results in an increased emission rate for each pollutant
to which a standard applies, the facility becomes an affected facility
under the provisions of Section 60.14. i
A common change made to distillation units is replacement of column
internals. Distillation columns are generally a low-maintenance type of
equipment , but replacement of trays or packing is not unusual, and
columns are normally constructed to facilitate their replacement.
Periodic replacement of trays and packing is common when corrosive
compounds are being distilled. Internal changes are sometimes made to
decrease operating costs — several manufacturers market column internals
designed to improve distillation. Replacement of trays or packing with
the same type of trays or packing is not considered a modification.
Replacement with different types of packing or trays that increase
emissions could in some cases be considered a modification.
Replacement of column accessories (e.g., reboiler, condenser,
vacuum systems)' is uncommon, but sometimes needed. Condensers can foul
or corrode, and other equipment can fail. Routine replacements are
exempted from the regulations, but installing accessories of a different
design, one that increases emissions, could be considered a modification.
Removal of vent stream control equipment would increase VOC emissions,
As mentioned in Section 3.4, there is approximately 52 percent average
control of VOC emissions from existing distillation columns in the
States which have no regulations for distillation vents, so in many
cases there are no regulations to prohibit removal of existing vent
stream product recovery devices (absorbers, adsorbers, condensers) or
combustion devices (boilers, incinerators, flares). It is, however,
unlikely that such equipment would be removed since their installation
is generally for economic, safety, or other reasons.
Energy conservation measures are becoming increasingly cost-effective
as energy prices escalate. Some available measures require only minor
changes, but others require major investments geared towards greatly
o
reducing energy requirements . For example, a change from a condensation
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system to a vapor recompression system, such as shown in Figure 5-1,
involves addition of a heat pump and elimination of the overhead condenser.
Although it is unlikely that a great number of distillation units will
be retrofitted with a vapor recompression system since it involves
installing new equipment and shelving existing equipment, such columns
could be considered to be modified if the emissions increase.
The inlet feedstream to a distillation unit can be changed to
different proportions of the same chemicals or to different chemicals
entirely. Changes in reactors or changes in catalysts are examples of
upstream operating conditions which could affect the proportion of
lighter compounds (by-products/products) in the feedstream. If the
proportion of lighter compounds produced increases, then emissions may
increase. However, if the distillation unit was originally capable of
handling the different feedstreams, the change would not be considered a
modification.
Changes can also be made in operating pressure and temperature,
which are interrelated. Operating pressure changes influence the
operating temperature, and it is sometimes desirable to operate at a
lower pressure or under vacuum, to prevent thermal decomposition of
product. (See Section 3.3 for a further discussion on selection of
operating pressure.) A small change in pressure is not expected to lead
to significant increases in emissions, but a change from nonvacuum to
vacuum could increase emissions.
5.2 RECONSTRUCTION
Under the provisions of Section 60.15, an existing facility becomes
an affected facility upon reconstruction, regardless of changes in
pollutant emission rates. Reconstruction is considered to occur upon
the replacement of components in the facility if the fixed capital cost
of the new components exceeds 50 percent of the fixed capital cost that
would be required to construct a comparable entirely new facility and if
it is economically and technically feasible for the facility to comply
with the applicable standards of performance. The final judgement on
what replacement constitutes reconstruction and when it is technologically
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Feed-
Column
Overhead
product
' Expansion
• valve
Compressor
Bottoms
product
Figure 5-1. Vapor recompression.
5-4
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and economically feasible to comply with the applicable standards of
performance is made by the Administrator. The Administrator's final
determinations are made on the following bases:
1. Comparison of the fixed capital costs of the replacement
components and a newly constructed comparable facility,
2. Comparison of the estimated life of the facility after the
replacements and the life of a comparable entirely new facility,
3. The extent to which the components being replaced cause or
contribute to the emissions from the facility, and
4. Any economic or technical limitations on compliance with
applicable standards of performance which are inherent in the proposed
replacements.
The purpose of this provision is to prevent an owner or operator
from perpetuating an existing facility by replacing all but vestigial
components, support structures, frames, housing, etc., rather than
totally replacing the facility in order to avoid applicability to an
NSPS. In accordance with Section 60.5, EPA will, upon request, determine
if the action taken constitutes construction (including reconstruction).
In most cases, equipment changes for distillation operations are
not a high cost item when compared to the cost of an entirely new
facility. Replacement of pumps, condensers, and other such equipment
amounts to a very low percentage of the capital cost of a new facility .
Replacement of internals (trays, packing) for the most part involves a
low percentage capital cost relative to a new facility, but it may
approach the 50 percent criteria for large capacity columns with a large
number of trays . Nonetheless, this is considered a routine maintenance
item and probably will not constitute a reconstruction. Major invest-
ments in energy conservation measures would be above the 50 percent
criteria. For example, vapor recompression systems such as described
above are two to three times as expensive as a conventional system, so
changes to a conventional system to incorporate vapor recompression
could be considered a reconstruction.
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5.3 PROBABILITY OF MODIFICATIONS AND RECONSTRUCTIONS
Although there are quite a few physical or operational changes that
conceivably could be made to existing distillation units, the number of
changes actually constituting modification or reconstruction is likely
to be very small. The reasons for this are that most physical or operational
changes will reduce emissions not increase them and most physical changes
will not be costly enough to constitute reconstruction. For the purposes
of regulatory analysis, it is assumed that the number of modifications
and reconstructions is negligible compared to the number of new distillation
units coming on stream.
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5.3 REFERENCES
1. Telecon. Smith, T., EPA with T. Cooper, APV, Inc., L. Montey, Artisan
Industries, and J. Hill, Koch Engineering, November 19, 1981,.
Conversation about modification/reconstruction of distillation units.
2. Energy Conservation in Distillation. U.S. Department of Energy.
DOE/CS/4431-T2. May 1980.
3. Reference 1.
4. Reference 1.
5. Reference 1.
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United States
of America
PROCEEDINGS AND DEBATES OF THE 9S CONGRESS, SECOND SESSION
Vol. 130 WASHINGTON, THURSDAY, FEBRUARY 23. 1984 No. 18
LEGISLATIVE LIBRARY382-5425832 wtbf iuWtK
CONGRESS HAS ADJOURNED UNTIL MONDAY, FEBRUARY 27, 1984
SENATE
The Judiciary Committee reported S.J. Resolution 202, The Year of Mater (S1615)
S.2340 was introduced by Deconcini (D-AZ), Copper Environmental Equalization
Act, referred to the Committee on Finance; made statement and inserted text
(1622), regarding increased duty on environmental requirements (S1616)
Stafford (R-VT), detailed the Committee on Public Works jurisdiction, and commended
new members D. Evans (R-WA), and Lautenberg (D-NJ), inserted revised membership
roster, and excerpts from Committee rules. (S1653)
P. Wilson (R-CA), critized the Supreme Court ruling that federal consistency
with state CZM is not required at leasing stage of PCS oil and gas development
under CZMA.~~fTl648)
Proxmire (D-WS), endorsed Carl Sagan thesis that nuclear war would produce a
"nuclear winter," destroying the worlds environment; called for stricter
nonproliferation controls; inserted a New York Times letter. (S1551)
HOUSE
The Committee on the Interior, Subcommittee on Energy and the Environment held a
hearing on bills to grant consent of Congress to the following interstate compacts
on low-level radioactive waste: HR.1012, NW; HR.3002, Central; HR.3777, SE;
HR.4388 Rocky Mountains; to continue.
HR.4813 was introduced by Lent (R-NY) and 17 others, Superfund amendments to
expedite inactive waste sites cleanup, improve enforcement authorities, provide
financial aid for affected communities, and regulate underground storage tanks;
referred to the Committee on Energy and Commerce, and the Committee on Public
Works and Transportation. (H903)
HR.4939 was introduced by Waxman (D-CA), and Echart (D-OH), Federal Food, Drug
and Cosmetic Act amendments authorizing action regarding pesticides presenting
imminent public health hazard; referred to the Committee on Energy and Commerce.
(H904)
HR.4922 was introduced by J. Edwards (R-AL), to exclude Fort Morgan Road from
Baldwin County AL coastal barrier resources system; referred to the Committee on
Merchant Marine and Fisheries. (H903)
Wyden (D-OR), supports a bill to authorize the EPA to revoke exemption and set
tolerance for pesticides posing imminint hazard to public health, and direct EPA
to take such action regarding EDB. (E587)
-OVER-
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Florio (D-NJ), supports HR.4813, to establish fund for cleanup of hazardous waste
sites which threaten human health and environment, standards for cleanup, federal-
state partnership, rules regarding liability for damages, and emergency assistance
and health studies for affected residents; inserted articles on links of cancer
and deaths to contaminated water. (E594) THIS BILL ALSO ADDED 5 COSPONSORS. (H904)
THE FOLLOWING BILLS ADDED COSPONSORS (H904).
HR.3282, Water Pollution Control Amendments A. Hawkins (D-CA).
HR.4393, Federal Water Pollution Control Act amendments regarding permits for
dredge or fill material. Harrison (D-PA), and Towns (D-NY).
HR.4037, to require states to identify polluted water areas and provide assistance
for pollution control. Ferraro (D-NJ).
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United States
of America
PROCEEDINGS AND DEBATES OF THE
CONGRESS, SECOND SESSION
Vol. 130 WASHINGTON, WEDNESDAY, FEBRUARY 22, 1984 No. 17
LEGISLATIVE LIBRARY
SENATE
382-5425
832 WEST TOWER
S.2324 was introduced by Packwood (R-OR), and 13 others, CZMA
(Costal Zone Management Act). Made statement supporting
reaffirming "consistency provision" that federal CZM activities
follow state plans; referred to the Supreme Court limiting
state input in OCS oil and gas development. Additional
statements by Hollings (D-SC), Cranston (D-CA), (S1507);
P. Hawkins (R-FL), Lautenberg (D-NJ), (S1508); and Chiles
(D-FL), (S1509); (S1527)
Johnston (D-LA), marked progress on Nuclear Waste Policy Act
programs; expressed concern over lack of permanent director
for civilian waste management office; and inserted articles,
and correspondence on repository site location decisions
regarding LA. (S1527)
HOUSE
The Committee on Energy and Commerce, Subcommittee on Energy
Conservation and Power held a hearing on DOE budget request
on high-level nuclear waste disposal.
HR.4906
control
acid deposition;
was introduced by Rinaldo (R-NJ) and 6 others, to
sulfur dioxide and nitrogen oxides sources to reduce
E n e r gy
referred to the Committee on Energy and
Commerce; and made statement regarding implementing Coalition
of Northeastern Governors recommendation regarding flexible
state control to achieve required reduction and accelerated
research program. (H809) and (E566)
Coats (R-IN),
share of aci d
on Energy
asserted disadvantaged will bear the greatest
rain control costs; and inserted Subcommittee
Sandra
and Commerce testimony by
Indianapolis Urban League. (E530)
Emmanual of
Markey (D-MA), ednorsed Dingell (D-MI), criticisms of
Administration "dismantling of regulatory controls" and consumer
protecti on ; referred
Federation. (E544)
to Dingell speech to Consumer
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Wyden (D-OR), congradu1ated CH2M Hill, recipients of EPA
award for commitment to small and minority businesses in EPA
funded subcontracting. (E565)
Seiberling (D-OH), inserted a Washington Post letter asserting
other civilizations are "keeping their distance" from Earth
due to war and environmental destruction. (H750)
HR.3282, Water Pollution Control Act Amendments added one
cosponsor Ferraro (D-NY), (H810)
HR.3777, consent of Congress to SE interstate Low-Level
radioactive waste management compact added 8 cosponsors.
(H810)
E.G.2674, EPA transmitted a 5 year plan for envi ronmental
RD&D, and comments from Science Advisory Board. (H808)
E.G.2696, Department of Commerce transmitted FY82 report on
ocean pollution monitoring and research. ALSO E.G.2695, FY81-2
report on marine sanctuary program. (H808)
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