Hazardous Air Pollutant Emissions
From the Pesticide Active Ingredient
Production Industry
Supplementary Information Document
for Proposed Standards
Emission Standards Division
U. S. Environmental Protection Agency
Office of Air And Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
July 1997
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453R97O14
DISCLAIMER
This report has been reviewed by the Emission Standards Division of the Office of Air Quality Planning
and Standards, EPA, and approved for publication. Mention of trade names or commercial products is not
intended to constitute endorsement or recommendation for use.
PROPERTY OF
EPA LIBRARY, RTF, NC
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TABLE OF CONTENTS
Subject Date
Documentation of Data Base Containing Information from Responses to November 11,1996
Section 114 Information Collection Requests for the Production of Pesticide
Active Ingredient NESHAP
Estimation of the Number of Affected Sources in the Production of Pesticide November 27, 1996
Active Ingredients Source Category
Recommended Control Levels for the Process Vent, Storage Tank, and Wastewater December 16, 1997
Planks of the New Source MACT Floor
Growth Projections for the Pesticide Active Ingredient Production Industry January 6, 1997
Summary of Data from Responses to Information Collection Requests and April 15,1997
Site Visits
Storage Tank Data and Results of Storage Tank Emission Calculations Using April 30, 1997
TANKS 3 Software
MACT Floor and Regulatory Alternatives for the Pesticide Active Ingredient April 30, 1997
Production Industry
Model Plants for the Pesticide Active Ingredient Manufacturing Industry April 30, 1997
Baseline Emissions for the Pesticide Active Ingredient Production Industry April 30, 1997
Environmental Impacts for the Pesticide Active Ingredient NESHAP April 30. 1997
Cost Impacts of Regulatory Alternatives for the Production of Pesticide Active April 30, 1997
Ingredients NESHAP
Procedures to Estimate Characteristics and Population of Dilute and April 30, 1997
Concentrated Streams for Model Processes
Basis for Pollution Prevention Factors for the Production of Pesticide Active June 30,1997
Ingredients NESHAP
Basis for Applicability Cutoff Equation for Process Vents Under Regulatory June 30,1997
Alternative No. 1
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MIDWEST RESEARCH INSTITUTE
Suite 350
401 Hamson Oaks Boulevard
Gary. North Carolina 27513-2412
Telephone (919) 677-0249
FAX (919) 677-0065
Date: November 11, 1996
Subject: Documentation of Data Base Containing Information from
Section 114 Responses and Site Visits for the
Production of Pesticide Active Ingredients NESHAP
EPA Contract No. 68-D1-0115; Work Assignment No. VI-144
BSD Project No. 93/59; MRI Project No. 6506-44
From: Karen Schmidtke
To: Laiit Banker
ESD/OCG (MD-13)
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
I. Introduction
This memorandum compiles information provided by the
pesticide active ingredient (PAI) production industry. This
information will be used in developing maximum achievable control
technology (MACT) for national emissions standards.for hazardous
air pollutants (NESHAP) for the production of PAI. Information
for this industry was provided: (1) in response to the
Section 114 information collection request for this industry that
was sent to nine companies, (2) in response to requests for
information during several EPA site visits, and (3) during
followup telephone conversations to clarify information in the
responses. The Section 114 requests were sent on October 5, 17,
or 23, 1995. Data were obtained from 23 plants at ten companies.
In some instances, additional calculations were performed based
on information submitted. The data base for the PAI production
source category is contained in the attachment.
II. References
1. Memorandum from Pagett, G., PES (Schmidtke, K., MRI), to
Banker, L., BPA/ESD/OCG. May 12, 1995. Summary report for
September 28, 1993, site visit to Ciba-Geigy's St. Gabriel,
Louisiana plant.
2. Memorandum from Pagett, G., PES (Schmidtke, K., MRI), to
Banker, L., EPA:BSD. May 12, 1995. Summary report for
September 29, 1993, site visit to Zeneca Ag Company, Bucks,
Alabama.
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3. Letter from Cheek-Deajon, K., DuPont Specialty Chemicals, to
Banker, L., BPA:ESD. August 30, 1995. Transmittal of
general plant process and emissions data for the La Porte,
Texas plant.
4. Letter from Cheek-Deajon, K., DuPont Specialty Chemicals, to
Banker, L., EPA:BSD. October 6, 1995. Transmittal of
descriptions of wastewater treatment systems, emission
estimates, and equipment leak components for the La Porte,
Texas plant.
5. Letter from Altamirano, C., Sandoz Agro, Inc., to Jordan, a.,
EPA/BSD. December 5, 1995. Response to Section 114
information collection request for the Beaumont, Texas plant.
6. Letter from Herrold, K., Zeneca Ag Products, to Jordan, B.,
BPA/ESD. December 6, 1995. Response to Section 114
information collection request for the Bayport, Texas and
Richmond, California plants.
7. Letter from Herrold, K., Zeneca Ag Products, to Jordan, B.,
EPA:BSD. December 6, 1995. Transmittal of response to
Section 114 information request for Perry, Ohio plant.
8. Memorandum from Hale, C., MRI, to Banker, L., EPA:BSD.
December 8, 1995. Summary report of July 26, 1995, site
visit to Monsanto Plant, Muscatine, Iowa.
9. Letter from Lockemer, R., Rhone-Poulenc, to Jordan, B.,
EPA/BSD. December 8, 1995. Response to Section 114
information collection request for the Institute, West
Virginia plant.
10. Letter from Ray, T., Elf Atochem North America, Inc., to
Jordan, B., EPA/BSD. December 11, 1995. Response to
Section 114 information collection request for the Riverview,
Michigan plant.
11. Letter from Alderman, J., Dow Chemical Company, to Jordan,
B., BPA/ESD. December 14, 1995. Response to Section 114
information collection request for the Midland, Michigan;
Pittsburg, California; and Freeport, Texas plants.
12. Letter from Lockemer, R., Rhone-Poulenc, to Jordan, B.,
EPA:BSD. December 14, 1995. Transmittal of response to
Section 114 information collection request for the
Mt. Pleasant, Tennessee plant.
13. Letter from Fletcher, L., DuPont Agriculture Products, to
Banker, L., EPA/ESD. December 15, 1995. Response to
Section 114 information collection request for the Belle,
West Virginia; Manati, Puerto Rico; and Mobile, Alabama
plants.
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14. Letter from Chowdary, R., Elf Atoehem North America, Inc., to
Jordan, B., EPA/ESD. December 21, 1995. Response to
Section 114 information collection request for the
Carrollton, Kentucky plant.
15. Letter from Willett, J., American Cyanamid Company, to
Jordan, B., EPA/ESD. December 29, 1995. Response to
Section 114 information collection request for the Hannibal,
Missouri plant.
16. Letter from Crews, R., Ciba-Geigy Corporation, to Jordan, B.,
EPA/ESD. January 12, 1996. Response to Section 114
information collection request for the Mclntosh, Alabama
plant.
17. Letter from PeshJcin, J., Monsanto, to Banker, L., EPA/ESD.
January 29, 1996. Submittal of additional information
regarding the site visit at the Muscatine, Iowa plant.
18. Letter from Herrold, K., Zeneca Ag Products, to Banker, L.,
EPA/ESD. February 8, 1996. Response to Section 114
information collection request for the Cold Creek Plant in
Bucks, Alabama.
19. Letter from Mureebe, 0., Uniroyal Chemical Corporation, Inc.,
to Banker, L., EPA/ESD. February 13, 1996. Response to
Section 114 information collection request for the Naugatuck,
Connecticut; Gastonia, North Carolina; and Geismar, Louisiana
plants. (2 letters sent on the same date)
20. Letter from Mureebe, 0., Uniroyal Chemical Corporation, Inc.,
to Banker, L., EPA/ESD. February 13, 1996. Response to
Section 114 information collection request for the Naugatuck,
Connecticut; Gastonia, North Carolina; and Geismar, Louisiana
plants. (2 letters sent on the same date)
21. Letter from Raff, B., Ciba-Geigy Corporation, to Banker, L.,
EPA/ESD. February 14, 1996. Submittal of additional
information regarding the site visit at the St. Gabriel,
Louisiana plant.
22. Letter from Bradley, G., Rhone-Poulenc, to Banker, L.,
BPA/ESD. February 19, 1996. Submittal of additional
information for the Institute, West Virginia plant.
23. Notes on allocating fraction of process vent, equipment
leaks, and wastewater emissions to individual processes based
on production levels for Ciba-Geigy's St. Gabriel, Louisiana
plant. Prepared by K. Schmidtke, MRI. February 23, 1996.
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24. Letter from Cheek-Deajon, K., DuPont Specialty Chemicals, to
Banker, L., EPA:BSD. March 4, 1996. Corrections to original
information packet submitted August 30, 1995 for the
La Porte, Texas plant.
25. Letter from Herrold, K., Zeneca Ag Products, to Schmidtke,
K., MRI. March 14, 1996. Submittal of completed Table 5,
Wastewater Survey Information, for Cold Creek plant in Bucks,
Alabama.
26. Telecon. Schmidtke, K., MRI, with Alford, R., Zeneca Ag
Products. March 14, 1996. Discussion of response to the
Section 114 information collection request for the Cold Creek
plant in Bucks, Alabama.
27. Letter from Alford, R., Zeneca Ag Products, to Banker, L.,
BPA/ESD/OCG. March 19, 1996. Completed Table 4, Information
Requested for Equipment Leaks, for the Cold Creek Plant in
Bucks, Alabama.
28. Letter from Herrold, K., Zeneca Ag Products, to Banker, L.,
EPA/BSD. March 21, 1996. Submittal of additional
information for the Cold Creek Plant in Bucks, Alabama.
29. Letter from Cheek-Deajon, K., DuPont Specialty Chemicals, to
Banker, L., EPA:BSD. March 25, 1996. Transmittal of
additional, information for the La Porte, Texas plant.
30. Telecon. Schmidtke, K., MRI, with Willett, B., American
Cyanamid. March 26, 1996. Discussion of the response to the
Section 114 information collection request for Hannibal,
Missouri plant.
31. Telecon. Schmidtke, K., MRI, with Montague, R., Uniroyal
Chemical. March 28, April 17 and 19, May 15, and July 3,
1996. Discussion of response to Section 114 information
collection request for Geismar, Louisiana plant.
32. Telecon. Schmidtke, K., MRI, with Dumelow, J., DuPont
Agriculture Products. April 4, May 14, and September 16,
1996. Discussion of response to the Section 114 information
collection request for the Mobile, Alabama plant.
33. Telecon. Schmidtke, K., MRI, with Germinario, T., American
Cyanamid. April 22 and 23, 1996. Discussion of the response
to the Section 114 information collection request for
Hannibal, Missouri plant.
34. Telecon. Schmidtke, K., MRI, with Bradley, G.( Rhone-
Poulenc. April 23, 1996. Discussion of response to the
Section 114 information collection request for the Institute,
West Virginia plant.
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35. Notes on allocating fraction of total process vent and
wastewater emissions to individual processes based on
production levels, for American Cyanamid, Hannibal, Missouri,
prepared by K. Schmidtke, MRI. April 25, 1996.
36. Memorandum from Randall, D. and C. Hale, MRI, to Banker, L.,
EPA:BSD. April 26, 1996. Summary report for July 27, 1995,
site visit to E.I. DuPont DeNemours and Company, Inc., La
Porte, Texas.
37. Telecon. Schmidtke, K., MRI, with Alford, R., Zeneca Ag
Products. April 26, June 4, September 20, and October 3,
1996. Discussion of response to the Section 114 information
collection request for the Cold Creek plant in Bucks,
Alabama.
38. Telecon. Schmidtke, K., MRI, with Bradley, 6. and R. Tenney,
Rhone-Poulenc. April 30, 1996. Discussion of response to
the Section 114 information collection request for the
Institute, West Virginia plant.
39. Telecon. Randall, D., with Chowdary, R., Elf Atochem North
America, Inc. May 3 and 21, 1996. Discussion of response to
the Section 114 information collection request for the
Carrollton, Kentucky plant.
40. Letter from Herrold, K., Zeneca Ag Products, to Schmidtke,
K., MRI. May 7, 1996. Process flow diagram; completed
Table 5, Wastewater Survey Information; and completed
Table 6, Design of Wastewater Collection and Treatment
Controls, for the Richmond, California plant.
41. Telecon. Schmidtke, K., MRI, with Fanjung, E., Zeneca Ag
Products. May 9, 1996. Discussion of response to the
Section 114 information collection request for the Richmond,
California plant.
42. Telecon. Schmidtke, K., MRI with Dickey, H., Zeneca Ag
Products. May 14, 1996. Discussion of response to the
Section 114 information collection request for the Perry,
Ohio plant.
43. Letter from Dumelow, J., DuPont Agriculture Products, to
Schmidtke, K., MRI. May 15, 1996. Submittal of additional
information for the Mobile, Alabama plant.
44. Tabulated results of process vent emissions for two pesticide
active ingredient processes and data used in estimating
storage tanks emissions, for Monsanto's Muscatine, Iowa
plant, prepared by D. Randall, MRI. May 17, 1996.
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45. Letter from Willett, B., American Cyanamid, to Schmidtke, K.,
MRI. May 21, 1996. Submittal of additional information for
the Hannibal, Missouri plant.
46. Letter from Alderman, J., Dow Chemical Company, to Banker,
L., EPA/BSD. May 30, 1996. Submittal of additional
information for the Pittsburg, California, and Freeport,
Texas plants.
47. Letter from Cheek-Deajon, K., DuPont Specialty Chemicals, to
Banker, L., EPA:BSD. May 30, 1996. Storage Tank Summary
Tables for the Lannate/API process for La Porte, Texas plant.
48. Notes on estimating emissions from an intermediate process at
Zeneca Cold Creek plant, Bucks, Alabama, prepared by
K. Schmidtke, MRI. June 3, 1996.
49. Letter from Smith, D., Zeneca Ag Products, to Banker, L,. ,
EPA:BSD. June 11, 1996. Transmittal of additional
information for the Cold Creek plant in Bucks, Alabama.
50. Letter from Cheek-Deajon, K., DuPont Specialty Chemicals, to
Banker, L., EPA:BSD. June 20, 1996. Transmittal of
additional information for the La Porte, Texas plant.
51. Telecon. Schmidtke, K., MRI, with Gulak, J., Uniroyal
Chemical. July 2 and 12, 1996. Discussion of response to
the Section 114 information collection request for the
Naugatuck, Connecticut plant.
52. Letter from Gulak, J., Uniroyal Chemical, to Schmidtke, K.,
MRI. July 1996. Transmittal of additional information for
the Naugatuck, Connecticut plant.
53. Telecon. Schmidtke, K., MRI with Keyes, K., Rhone-Poulenc.
August 1 and 21, 1996. Discussion of response to the
Section 114 information collection request for the Institute,
West Virginia plant.
54. Letter from Alderman, J., Dow Chemical Company, to Schmidtke,
K., MRI. August 16, 1996. Submittal of additional
information for the Pittsburg, California plant.
55. Letter from Dumelow, J., DuPont Agriculture Products, to
Schmidtke, K., MRI. September 16, 1996. Submittal of
additional information for the Mobile, Alabama plant.
56. Letter from Dumelow, J., DuPont Agriculture Products, to
Schmidtke, K., MRI. September 19, 1996. Submittal of
additional information for the Mobile, Alabama plant.
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57. Letter from Alderman, J., Dow Chemical Company, to Schmidtke,
K., MRI. September 20, 1996. Submittal of additional
information for the Pittsburg, California plant.
58. Letter from Alford, R., Zeneca Ag Products, to Schmidtke, K.,
MRI. October 3, 1996. Submittal of additional information
for the Cold Creek plant in Bucks, Alabama.
59. Letter from Dumelow, J.f DuPont Agriculture Products, to
Schmidtke, K., MRI. December 3, 1996. Submittal of
additional information for the Mobile, Alabama plant.
Attachment
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Docket No. A-95-20
Category II-B
The following information is located in the confidential
files of the Director, Emission Standards Division, Office of Air
Quality Planning and Standards, U. S. Environmental Protection
.Agency, Research Triangle Park, North Carolina 27711. This
information is confidential pending final determination by the
Administrator and is not available for public inspection.
Attachment to Documentation of Data Base Containing
Information from Section 114 Responses and Site Visits Memorandum
(part of docket item II-B-21).
This attachment consists of a confidential printout of the
data base for the pesticide active ingredient production source
category.
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MIDWEST RESEARCH INSTITUTE
Suite 350
401 Hamson Oaks Boulevard
Gary. North Carolina 27513-2412
Telephone <919) 677-0249
FAX (919)677-0065
From:
To:
Date: November 27, 1996
Subject: Estimation of the Number of Affected Sources in the
Production of Pesticide Active Ingredients Source
Category--Production of Pesticide Active Ingredient
NESHAP
EPA Contract No. 68-D1-0115; Work Assignment No. VI-144
BSD Project No. 93y59; MRI Project No. 6506-44
Karen Schmidtke
Laiit Banker
ESD/OCG (MD-13)
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
I. Introduction
This memorandum summarizes the methodology used to estimate
the number of affected sources in the production of pesticide
active ingredients (PAI) source category. The EPA is developing
maximum achievable control technology (MACT) for national
emissions standards for hazardous air pollutants (NESHAP) for the
production of PAI source category. The number of affected
sources will be used in estimating the nationwide impacts and in
determining the number of sources required for the MACT floor
calculation for existing sources. Affected sources for the PAI
source category are those sources that (1) manufacture pesticide
active ingredients, and {2) are major with respect to hazardous
air pollutants (HAP) (i.e., 10 tons per year or more of a single
HAP or 25 tons per year or more of any combination of HAP).
II. Estimation of the Number of Affected Sources
A. Initial Lists of Facilities
Two lists of facilities were used to identify possible
affected sources: (1) the Section Seven Tracking System (SSTS),
and (2) a list of PAI manufacturers that the Office of Water
identified while developing effluent guidelines and standards for
PAI manufacturing facilities. The SSTS tracks information about
which facilities produce pesticide products and what pesticide
products are being made. The EPA requires all producers of
pesticide products, both technical grade (i.e., active
ingredient) and formulated product (i.e., active ingredient plus
inerts), to report annually the amount of pesticides produced.
The SSTS data base identifies the name and address of the
producer, the pesticide products that producer made in a
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particular year, where the product is marketed (within U.S or
exported), and the pesticide product's use and class. Facilities
indicate the type of product they make on EPA Form 3540-16. The
SSTS data base search was limited to only those facilities that
indicated they manufacture PAI; this search identified 316
facilities in 1991. •L
In 1986, the Office of Water collected information on the
PAI manufacturing industry in an effluent guidelines study. The
Office of Water study surveyed all facilities that were
-.manufacturing specific PAI's in 1984 and 1985. This study
identified 90 facilities that manufacture PAI.2 By promulgation
of the effluent guidelines in 1993, 15 facilities were no longer
manufacturing PAI. The Office of Water study identified a total
of 75 facilities that manufacture PAI (September 28, 1993;
58 PR 50642).
A total of 329 facilities were identified as possible
producers of PAI, and these facilities are listed alphabetically
by State in Table 1. The list from the Office of Water study
contains an additional 11 facilities not on the SSTS list. The
other 64 facilities on the Office of Water list are also
contained on the SSTS list. In addition to the 327 facilities
identified on the SSTS and Office of Water list, two other
facilities were also identified; one was identified by one of the
State agencies contacted and another was identified by an EPA
site visit to the facility.
B. Confirmation of Affected Sources
There was some question as to whether all 316 facilities
identified in the 1991 SSTS were PAI manufacturers. This
question was based on (1) the large difference in the number of
facilities from the SSTS list relative to the Office of Water
list, and (2) some of the facility names (i.e., the name
indicated that it was a formulator or packager). The SSTS data
base likely included formulators, packagers, and research
facilities in addition to active ingredient manufacturers. The
75 facilities identified in the Office of Water study included
active ingredient manufacturers but only included those that
produced specific active ingredients.
Several State and local agencies and, in some instances,
the facilities themselves were contacted to confirm whether the
facilities on these two lists are: (1) PAI manufacturers, and
(2) major sources for HAP with respect to potential to emit. The
facilities that meet both criteria were confirmed in twelve
States. These States are listed in Table 2, along with the
number of facilities identified on the two lists and the number
of confirmed affected sources (i.e., the number of sources that
meet both criteria) for each State. Ten of the States were
contacted individually by telephone. In addition to telephone
contact, the list of facilities was sent to STAPPA/ALAPCO, which
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they sent to the States. Two of the States, Michigan and New
York, responded to this request for information. The ten States
that were contacted individually were contacted because the State
had a large number of possible sources listed in SSTS, the State
was a member of the MACT Partnership group, or because there was
a State contact from previous information gathering for the PAX
source category.
In these twelve States, a total of 140 facilities were
identified on the lists. Of these 140, 33 were confirmed
affected sources for the PAI source category (24 percent),3'40
The 33 confirmed affected sources are listed in Table 3.
C. Estimate of the Number of Affected Sources
The nationwide number of affected sources was estimated
assuming 24 percent of 329 facilities are major source PAI
manufacturers. Therefore, there are an estimated 78 affected
sources in the PAI source category.
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TABLE 1. LIST OF FACILITIES THAT PRODUCE PAI
COMPANY NAME
Akzo Nobel Chemicals
Ciba Geigy Corp.
Ou Pont Mobile Plant
Elf Atochem N.A. Inc.
Monsanto Co.
Olin Corp.
Tull Chemical Company
Zeneca, Inc.
Arkansas Eastman Division
Cedar Chemical Corp.
Ethyl Corporation
Great Lakes Chemical Corp.
Helena Chemical Company
Amvac Chemical Corp.
California Spray Dry Company
Chevron Chemical Co.
Continental Candle Company
Custom Chemicides
Dow Chemical
FMC Corporation
Fillmore Piru Citrus
Golden Bear Division Wrtco Corp.
Imperial West Chemical Company
Kerr-McGee Chemical
Lonza Inc.
Monterey Co. Dept. of Ag.
Niklor Chemical Co. Inc.
North American Chemical
Reaction Products Company
Rio Linda Chem
Sandoz Agro Inc.
Sandoz Agro Inc.
Sungro Chemicals
United States Borax & Chemical
Unocal Petroleum Products
Washburn & Sons
Western Farm Service
Western Farm Service
Zeneca, Inc.
CITY
Axis
Mclntosh
Axis
Axis
Anniston
Mclntosh
Oxford
Bucks
Magness
West Helena
Magnolia
El Dorado
West Helena
Los Angeles
Stockton
Richmond
Compton
Fresno
Pittsburg
Fresno
Piru
Oildale
Antioch
Trona
Carson
Salinas
Carson
Trona
Richmond
Sacremento
East Palo Alto
Wasco
Los Angeles
Boron
Rodeo
Riverside
Hanford
Firebaugh
Richmond
STATE
AL
AL
AL
AL
AL
AL
AL
AL
AR
AR
AR
AR
AR
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
LIST
(OW/SSTS)
SSTS
OW/SSTS
OW/SSTS
OW/SSTS
SSTS
SSTS
SSTS
OW/SSTS
SSTS
OW/SSTS
OW
OW/SSTS
SSTS
OW/SSTS
SSTS
OW
SSTS
SSTS
OW/SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
OW/SSTS
SSTS
SSTS
SSTS
OW/SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
OW/SSTS
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TABLE 1. LIST OF FACILITIES THAT PRODUCE PAI (CONTINUED)
COMPANY NAME
CITY
STATE
LIST
(OW/SSTS)
Alpha Labs
Cargill Inc.
Cargill Inc.
Platte Chemical Company
Bedoukian Research, Inc.
Macdermid, Inc.
Nefes Forest Insect and Disease
Thor Chemicals, Inc.
Uniroyal Chemical
Chloramone Division/Kuehne Chemical
Standard Chlorine Chemical
Texaco Chemical Company
Arizona Chemical Company
Bestech, Inc.
Bulk Storage
Chevron Chemical Co.
Chevron Chemical Co.
Conrads Pool Supply
FLA Potting Soils
FMC Corporation
Fleetwing Corporation
Gator Pool & Spa Service
Insecta Sales Inc.
Knox Pools Inc.
SCM Glidco Organics
Southern Mill Creek Products
Sun Refining
Union Camp Corporation
Universal Water Industries
Bold Corporation
hemical Specialties
Georgia Gulf Sulfur Corporation
Hickson Corporation
LCP Chemicals
Micro-Flo Company
Olin Corp.
Prentiss Inc.
Rockland React-Rite
Southern Chemical Products
Denver
Cope
Limon
Greeley
Danbury
Waterbury
Hamden
Meriden
Naugatuck
Delaware City
Delaware City
Delaware City
Panama City
Pompano Beach
Tampa
San Francisco
Tampa
Titusville
Orlando
Jacksonville
Lakeland
Fort Myers Beach
Oakland Park
Pompano Beach
Jacksonville
Tampa
Lake Alfred
Jacksonville
Miami
Trfton
Valdosta
Bainbridge
Conley
Brunswick
Rockmart
Augusta
Sandersville
Rockmart
Macon
CO
CO
CO
CO
CT
CT
CT
CT
CT
DE
DE
DE
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
OW/SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
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TABLE 1 . LIST OF FACILITIES THAT PRODUCE PAI (CONTINUED)
COMPANY NAME
Stepan Company
Vinings Industries Inc.
A to Z Drying
Albaugh Chemical Corporation
Bio Products Inc.
Denbo Corporation
Farmers Coop Company
Monsanto Co.
Abbott Labs
CP Inorganics
Cabery Fertilizer Company
Cabery Fertilizer Company
Chase Products Company
ChemTech
Du Pont
IEcolab
Elkhart Fertilizer Service
Farmers Ag Service
Gateway FS
K A Steel Chemicals
Lakefork Fertilizer Service
Lonza Inc.
Mason Chemical Corporation
Monsanto Co.
Morton International
Morton International
Olin Corp.
Riverdale Chemical Co
Stepan Company
West Agro
3M Company
Eli Lilly Tippecanoe Labs
H&S Chemicals
Pfizer Vigo Plant
Reilly Industries
Agco Inc.
Bubeck Water Services
PBI Gordon Corporation
Simmons Turf Grass Farm
CITY
Winder
Marietta
Osage
Ankeny
Manson
Alkeny
Manson
Muscatine
North Chicago
Joliet
Cabery
Union Hill
Broadview
Cabery
El Paso
Joliet
Elkhart
Gifford
Waterloo
Lemont
Lakefork
Mapleton
Joliet
Sauget
Lansing
Ringwood
Joliet
Chicago Heights
Elwood
Des Plaines
Hartford Ctty
Lafayette
Huntington
Terre Haute
Indianapolis
Dorrance
Lenexa
Crestline
Wichita
STATE
GA
GA
IA
IA
IA
IA
IA
IA
IL
IL
IL
IL
IL
IL
IL
IL
IL
IL
IL
IL
IL
IL
IL
IL
IL
IL
IL
IL
IL
IL
IN
IN
IN
IN
IN
KS
KS
KS
KS
LIST
(OW/SSTS)
SSTS
OW/SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
OW/SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
OW/SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
OW/SSTS
SSTS
SSTS
SSTS
OW/SSTS
OW/SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
-------
TABLE 1. LIST OF FACILITIES THAT PRODUCE PAI (CONTINUED)
COMPANY NAME
Mean Chemicals
N. F. Leonard Company
Elf Atochem N.A. Inc.
fenderbilt Chemical Corp.
Vngus Chemical Company
;hem-Lig International
;iba Geigy Corp.
•rco Industries
.aRoche
Magnolia Chemicals
Micro Chemical Company
Monsanto Co.
)lin Corp.
>PG Industries
'ioneer Chlor Alkali
Jniroyal Chemical
I/Vitco Corp. Argus Chem. Div.
feneca, Inc.
:hemdesign Corporation
Ecoscience Corporation
teneca Inc.
Central Chemical Corporation
Espro Inc.
:MC Corp. Ag. Chem. Group
sliro Inc.
/V.R. Grace & Company
.CP Chemicals
Vloosehead Products
\nderson Development Company
3VA D/B/A B-V Associates
Berger & Company
Cropmate Fertilizer
)ow Chemical
Elf Atochem N.A. Inc.
B Kremer Company
Mai Company
§4or-Am Chemical Company
rennisula Copper Industries
CITY
Wichita
Meridan
Carrollton
Murray
Sterlington
Port Allen
St. Gabriel
Monroe
Gramercy
Jefferson
Winnsboro
Luling
Lake Charles
Lake Charles
St. Gabriel
Geismar
Taft
St. Gabriel
Fitchburg
Worcester
Dighton
Elkton
Columbia
Baltimore
Columbia
Baltimore
Orrington
Corinna
Adrian
Wixom
Croswell
Mulliken
Midland
Riverview
Livonia
Novi
Muskegon
Hubbell
STATE
KS
KS
KY
KY
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
MA
MA
MA
MD
MD
MD
MD
MD
ME
ME
Ml
Ml
Ml
Ml
Ml
Ml
Ml
Ml
Ml
Ml
LIST
(OW/SSTS)
OW
SSTS
OW/SSTS
OW
SSTS
SSTS
OW/SSTS
SSTS
SSTS
SSTS
SSTS
OW/SSTS
SSTS
SSTS
SSTS
SSTS
OW/SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
OW/SSTS
SSTS
SSTS
OW/SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
OW/SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
-------
TABLE 1. LIST OF FACILITIES THAT PRODUCE PAI (CONTINUED)
COMPANY NAME
3M Company
3M Company
Diversified Mfg
H B Fuller Company
Hawkins Chemical
Mclaughlin Gormley King Co.
Mclaughlin Gormley King Co.
Munson Feed Company
Timed Release Corporation
Water Technologies Corporation
Agrolinz Inc. (Albaugh Inc.)
American Cyanamid Co.
Bayer Corporation
Buckman Laboratories Inc.
Calgon Vestal Labs (Convatech)
Chevron Chemical Co.
Dial Corporation
Farmland Industries
Findett Corporation
Lange-Stegman Fertilizer
Monsanto Co.
Rhone Poulenc Ag. Co.
Rhone-Poulenc Ag Co.
West Agro
Eka Nobel
Kerr-McGee Chemical
Morton International
Odom Industries
Red Panther Chemical
American Chemet Corporation
Transbas Inc.
FMC Corporation
Fair Products
Forrest Farm Supply
Holtrachem
Mac-Page Blending
Mineral R & D Corp.
Monsanto Co.
Morflex Inc
CITY
St. Paul
StPaul
StPaul
Minneapolis
Minneapolis
Chaska
Minneapolis
Howardlake
Maple Plain
Plymouth
St. Joseph
Hannibal
Kansas City
Cadet
St. Louis
Maryland Heights
St. Louis
St. Joseph
St. Charles
St. Louis
St. Louis
St. Louis
St. Joseph
Kansas City
Columbus
Hamilton
Moss Point
Waynesboro
Clarksdale
East Helena
Billings
Bessemer City
Gary
Bayboro
Riegelwood
Dunn
Harrisburg
Fayetteville
Greensboro
STATE
MN
MN
MN
MN
MN
MN
MN
MN
MN
MN
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MO
MS
MS
MS
MS
MS
MT
MT
NC
NC
NC
NC
NC
NC
NC
NC
LIST
(OW/SSTS)
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
OW/SSTS
SSTS
SSTS
SSTS
OW/SSTS
OW/SSTS
OW/SSTS
SSTS
SSTS
SSTS
SSTS
OW/SSTS
SSTS
SSTS
OW/SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
OW/SSTS
OW/SSTS
-------
TABLE 1. LIST OF FACILITIES THAT PRODUCE PAI (CONTINUED)
:OMPANY NAME
Occidental Chemcial
'isgah Labs
'rochem Chemicals
Rhone Poulenc Ag. Co.
3CM Metal Products
Bandoz Chemicals Corp.
Bouthchem
•Trinity Mfg
Farmers Union Oil Company
IfVkzo Chemicals Inc.
|\kzo Nobel Chemicals
•American Cyanamid Co.
Rrsynco Inc.
•Atomergic Chemetals
GDI Dispersions
Cell and Cell Products Fermentation
Dosan Chemical Corporation
Sivauden-Roure Corp.
Hercules Chemical
Hoechest Celanese
lame Fine Chemical
Martz Mountain Corporation
Mason Chemical Corporation
Merck & Co. Inc.
Old Bridge Chemical
Pfister Chemical
Princeton Pool and Patio
'urefine Washing Fluid
toscom Inc.
•Troy Chemical Corp.
•Kerr-McGee Chemical
Pioneer Chlor Alkali
•Diaz Chemical
FMC Corporation
FMC Corporation
pin Corp.
l/Vttco Corp.
lArchem Corporation
lAshta Chemicals Inc.
CITY
Castle Hayne
Pisgah Forest
High Point
RTP
RTP
Charlotte
New Bern
Hamlet
Kulm
New Brunswick
Edison
Princeton
Carlstadt
Patterson
Newark
Piscataway
Carlstadt
Clifton
Passaic
Newark
Bound Brook
Bloomfield
Paterson
Rahway
Old Bridge
Ridgefield
Princeton
Elizabeth
Trenton
Newark
Henderson
Henderson
Holley
Middleport
Tonawanda
Rochester
Brooklyn
Portsmouth
Ashtabula
STATE
NC
NC
NC
NC
NC
NC
NC
NC
ND
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NV
NV
NY
NY
NY
NY
NY
OH
OH
LIST
(OW/SSTS)
SSTS
SSTS
SSTS
OW/SSTS
SSTS
OW/SSTS
SSTS
SSTS
SSTS
OW/SSTS
SSTS
SSTS
SSTS
OW
SSTS
SSTS
SSTS
OW/SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
OW/SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
OW/SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
OW/SSTS
OW/SSTS
SSTS
OW
-------
10
TABLE 1. LIST OF FACILITIES THAT PRODUCE PAI (CONTINUED)
COMPANY NAME
G Frederick Smith Chemical
Hess & Clark
Jones Hamilton Company
MTM Chemicals
Monsanto Co.
Ohio Grain Company
PMC Specialties
Purex Corporation
Ricerca Inc.
Vigoro Industries
Zeneca Inc.
Avitrol Corporation
Phillips Petroleum Company
Chevron Chemical Co.
Elf Atochem N.A. Inc.
Gatx Tank Storage Terminals
Rhone Poulenc Ag. Co.
ACT
Advanced Chemicals
Bayside Marine Paint
Huntingdon Labs.
Ionics Incorporated
Merck & Co. Inc.
Mooney Chemicals Inc.
PPG Industries
Pagoda Industries
Rohm & Haas Inc.
Ruetgers-Nease Chemical Company
Sun Company
Ultra-Hyd
Pacific Anchor Chemcial
CP Chemcials
Hickson Corporation
MTM-Hardwicke Inc.
Mobay Corporation
Pulverizing Services
Alco Chemical
Bit Manufacturing Inc.
Buckman Laboratories Inc.
CITY
Columbus
Ashland
Walbridge
Columbus
Dayton
Urbana
Cincinnati
Marion
Concord
Shandon
Perry
Tulsa
Bartlesville
Portland
Portland
Portland
Portland
Allentown
Lansdowne
Conshohocken
Lansdale
Bridgeville
Riverside
Franklin
Folcroft
Sinking Springs
Philadelphia
State College
Marcus Hook
Horsham
Cumberland
Sumter
Hickory Grove
Elgin
Goose Creek
North Charleston
Chattanooga
Copperhill
Memphis
STATE
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OK
OK
OR
OR
OR
OR
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
Rl
SC
SC
SC
SC
SC
TN
TN
TN
LIST
(OW/SSTS)
SSTS
SSTS
SSTS
OW/SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
OW
SSTS
SSTS
SSTS
SSTS
SSTS
OW
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
OW/SSTS
SSTS
SSTS
OW/SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
OW/SSTS
SSTS
SSTS
OW/SSTS
OW/SSTS
OW/SSTS
-------
11
TABLE 1. LIST OF FACILITIES THAT PRODUCE PAI (CONTINUED)
•COMPANY NAME
•Chapman Chemical Co
•Drexel Chemical Co
•Eastman Kodak-Tennessee Eastman
•Great Lakes Chemical Corp.
JlBC Mfg
•Music City Supplement Company
iNutra Basics
•Olin Corp.
•Pro-Serve Inc.
iRhone-Poulenc Ag Co.
•Rohm & Haas Inc.
•Tennessee Valley Performance
•Velsicol Chemical Corp
•Zeneca Inc.
lAgrevo Environmental Health
JAgtrol Chemical Products
•Alliance Packaging
•American Chrome & Chemicals
iBetz Labs
•Biomedical & Pharm. Mfg.
•chemical Specialties
•Cumberland
•Dow Chemical
•DU Pont LaPorte Plant
JEnnis Agri-Tech
•Exxon Chemical
•Griffin Corporation
llSK Biotech Corp.
•Rohm & Haas Inc.
Isandoz Agro Inc.
•Schenectady International
•Southwestern Livestock Mineral Co.
•Sun Company
•synergy Fluids
•zeneca, Inc.
Izoecon Corporation
•Amphos Ltd.
ICSS Employment
•Olympic Mountain & Marine Prod. Inc.
CITY
Memphis
Memphis
Kingsport
Newport
Memphis
Nashville
Chattanooga
Charleston
Memphis
Mt. Pleasant
Knoxville
Dayton
Memphis
Mt. Pleasant
Pasadena
Houston
Irving
Corpus Christ*
West Orange
Houston
Gilmer
Houston
Freeport
LaPorte
Ennis
Houston
Houston
Houston
LaPorte
Beaumont
Freeport
San Angelo
Nederiand
Hull
Pasadena
Dallas
Weyers Cave
Tacoma
Kent
STATE
TN
TN
TN
TN
TN
TN
TN
TN
TN
TN
TN
TN
TN
TN
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
VA
WA
WA
UST
(OW/SSTS)
OW
OW/SSTS
OW/SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
OW/SSTS
OW/SSTS
SSTS
OW/SSTS
OW/SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
OW
OW/SSTS
OW/SSTS
SSTS
SSTS
SSTS
OW/SSTS
OW/SSTS
OW/SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
-------
12
TABLE 1. LIST OF FACILITIES THAT PRODUCE PAI (CONTINUED)
COMPANY NAME
Weyerhauser Co. Chemcial Plant
Aldrich Chemical Company
Atfiea Labs
Coating Place
Hacco Inc.
Northland Foods Cooperative
Specialtychem Products
Witco Co. Sherex Chemical Company
Clearon Corporation
Cytec Industries
Du Pont Belle Plant
FMC Corp. Institute Plant
Hanlin Chemicals
Kincaid Enterprises Inc.
Newell Specialty Chemicals
PPG Industries
Rhone-Poulenc Ag Co.
Union Carbide
CITY
Tacoma
Milwaukee
Milwaukee
Verona
Randolph
Owen
Marinette
Janesville
So. Charleston
Willow Island
Belle
Institute
Moundsville
Nitro
Newell
New Martinsville
Institute
South Carleston
STATE
WA
Wl
Wl
Wl
Wl
Wl
Wl
Wl
WV
WV
WV
WV
WV
WV
WV
WV
WV
WV
LIST
(OW/SSTS)
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
SSTS
OW/SSTS
SSTS
OW/SSTS
OW
OW/SSTS
SSTS
OW/SSTS
SSTS
SSTS
OW/SSTS
SSTS
-------
TABLE 2. PERCENTAGE OF SOURCES THAT ARE MAJOR ACTIVE INGREDIENT MANUFACTURERS
STATE
ARKANSAS
GEORGIA
ILLINOIS
KANSAS
MARYLAND
MICHIGAN
MISSOURI
NEW YORK
NORTH CAROLINA
TENNESSEE
TEXAS
WEST VIRGINIA
ORIGINAL
NUMBER OF
FACILITIES
(OW + SSTS)
5
12
21
6
5
10
13
5
15
17
21
10
CONFIRMED
MAJOR SOURCE
ACTIVE
INGREDIENT
MANUFACTURERS
3
0
5
1
1
3
3
0
2
4
6
5
PERCENTAGE
OF CONFIRMED
MAJOR SOURCE
ACTIVE INGREDIENT
MANUFACTURERS
60.00%
0.00%
23.81%
16.67%
20.00%
30.00%
23.08%
0.00%
13.33%
23.53%
28.57%
50.00%
CUMULATIVE
PERCENTAGE
60.00%
17.65%
21.05%
20.45%
20.41%
22.03%
22.22%
20.78%
19.57%
20.18%
21.54%
23.57%
CUMULATIVE
MAJOR ATS
3
3
a
9
10
13
16
16
18
22
28
33
CUMULATIVE
SOURCES
5
17
38
44
49
59
72
77
92
109
130
140
-------
14
TABLE 3. MAJOR SOURCES IDENTIFIED AS AFFECTED SOURCES IN THE
PRODUCTION OF PESTICIDE ACTIVE INGREDIENT SOURCE CATEGORY3
Company name
Arkansas Eastman Division
Ethyl Corporation
Great Lakes Chemical Corp.
Abbott Labs
Lonza Inc.
Monsanto Co.
Morton International
Riverdale Chemical Co.
Vulcan Chemicals
FMC Corp. Ag. Chem. Group
Anderson Development Company
Dow Chemical
Elf AtochemN.A., Inc.
American Cyanamid Co.
fiuclcman Laboratories Inc.
Farmland Industries
FMC Corporation
Occidental Chemical
Eastman Kodak-Tennessee Eastman
Great Lakes Chemical Corp.
Olin Corp.
Zeneca Inc.
Dow Chemical
DuPont
ISK Biotech Corp.
Sandoz Agro Inc.
Schenectady International
Zeneca Inc.
Cytec Industries
DuPont
PPG Industries
Rhone-Poulenc Ag. Co.
Union Carbide
City
Magness
Magnolia
El Dorado
North Chicago
Mapleton
Sauget
Ringwood
Chicago Heights
Wichita
Baltimore
Adrian
Midland
Riverview
Hannibal
Cadet
St. Joseph
Bessemer City
Castle Hayne
Kingsport
Newport
Charleston
Mt. Pleasant
Freeport
LaPorte
Houston
Beaumont
Freeport
Pasadena
Willow Island
Belle
New Martinsville
Institute
South Charleston
State
AR
AR
AR
IL
IL
IL
IL
IL
KS
MD
MI
MI
MI
MO
MO
MO
NC
NC
TN
TN
TN
TN
TX
TX
TX
TX
TX
TX
wv
wv
wv
wv
wv
have facilities that are major source active ingredient
manufacturers.
-------
15
III. References
x. U.S. Environmental Protection Agency. Section Seven Tracking
System, Pesticide Report-1991. Information collected on EPA
Form 3540-16 for reporting year 1991.
2. U.S. Environmental Protection Agency. Development Document
for Best Available Technology: Pretreatment Technology, and
New Source Performance Technology for the Pesticide Chemical
Industry. Washington, DC, Office of Science and Technology.
EPA Publication No. EPA-821/R-92-005. March 1992.
j. Telecon. Schmidtke, K., MRI, with Harrell, C., Arkansas
Department of Pollution Control and Ecology. September 13,
1995. Discussion to determine whether plants listed in
Section 7 Tracking System are HAP major sources and pesticide
active ingredient manufacturers.
4. Letter from Johnston, J., Georgia Department of Natural
Resources, to Schmidtke, K., MRI. December 26, 1995.
Information on pesticide active ingredient facilities that
are HAP major sources.
5. Telecon. Schmidtke, K., MRI, with Naour, H., Illinois
Environmental Protection Agency. October 18, 1995.
Discussion to determine whether plants listed in Section 7
Tracking System are HAP major sources and pesticide active
ingredient manufacturers.
t>. Telecon. Schmidtke, K., MRI, with Gross, T., Kansas
Department of Air and Radiation. October 10, 1995.
Discussion to determine whether plants listed in Section 7
Tracking System are HAP major sources and pesticide active
ingredient manufacturers.
7. Telecon. Randall, D., MRI, with Irons, K., Maryland
Department of the Environment. August 25, 1995. Discussion
to determine whether plants listed in Section 7 Tracking
System are HAP major sources and pesticide active ingredient
manufacturers.
8. Telecon. Banker, L., EPA/OAQPS/ESD, with Avery, J., Michigan
Department of Environmental Quality. , 1996. Discussion
to determine whether plants listed in Section 7 Tracking
System are HAP major sources and pesticide active ingredient
manufacturers.
9. Telecon. Schmidtke, K., MRI, with Giroir, E., Missouri
Department of Natural Resources. September 14 and 27, 1995.
Discussion to determine whether plants listed in Section 7
Tracking System are HAP major sources and pesticide active
ingredient manufacturers.
10. Telecon. Schmidtke, K., MRI, with Horgan, T., City of
St. Louis Air Pollution Control, Missouri Department of
Natural Resources. September 29 and October 4, 1995.
Discussion to determine whether plants listed in Section 7
Tracking System are HAP major sources and pesticide active
-------
16
ingredient manufacturers.
11. Telecon. Schmidtke, K., MRI, with Wildt, C., County of
St. Louis Air Pollution Control Program, Missouri Department
of Natural Resources. October 2, 1995. Discussion to
determine whether plants listed in Section 7 Tracking System
are HAP major sources and pesticide active ingredient
manufacturers.
12. Telecon. Schmidtlce, K., MRI, with Carney, D., and S. Honig,
Missouri Department of Natural Resources. October 3, 1995.
Discussion to determine whether plants listed in Section 7
Tracking System are HAP major sources and pesticide active
ingredient manufacturers.
13. Telecon. Banker, L., BPA/OAQPS/ESD, with , New York
Department of Environmental Conservation. . 1996.
Discussion to determine whether plants listed in section 7
Tracking System are HAP major sources and pesticide active
ingredient manufacturers.
14. Telecon. Schmidtke, K.f MRI, with Menon, P., Raleigh
Regional Office, North Carolina Department of Environment,
Health, and Natural Resources. October 2 and 19, 1995.
Discussion to determine whether plants listed in Section 7
Tracking System are HAP major sources and pesticide active
ingredient manufacturers.
15. Telecon. Schmidtke, K., MRI, with Edwards, R., Wilmington
Regional Office, North Carolina Department of Environment,
Health, and Natural Resources. October 5, 1995. Discussion
to determine whether plants listed in Section 7 Tracking
System are HAP major sources and pesticide active ingredient
manufacturers.
16. Telecon. Schmidtke, K., MRI, with Bulow, B., Washington
Regional Office, North Carolina Department of Environment,
Health, and Natural Resources. October 6, 1995. Discussion
to determine whether plants listed in Section 7 Tracking
System are HAP major sources and pesticide active ingredient
manufacturers.
17. Telecon. Schmidtke, K., MRI, with Davey, B., Mooresville
Regional Office, North Carolina Department of Environment,
Health, and Natural Resources. October 6, 1995. Discussion
to determine whether plants listed in Section 7 Tracking
System are HAP major sources and pesticide active ingredient
manufacturers.
18. Telecon. Schmidtke, K., MRI, with Revels, M., Fayetteville
Regional Office, North Carolina Department of Environment,
Health, and Natural Resources. October 6, 1995. Discussion
to determine whether plants listed in Section 7 Tracking
System are HAP major sources and pesticide active ingredient
manufacturers.
-------
17
19. Telecon. Schmidtke, K., MRI, with Edwards, L., and
H. Varner, Winston-Salem Regional Office, North Carolina
Department of Environment, Health, and Natural Resources.
October 6 and 9, 1995. Discussion to determine whether
plants listed in Section 7 Tracking System are HAP major
sources and pesticide active ingredient manufacturers.
20. Telecon. Schmidtke, K., MRI, with Muller, P., Asheville
Regional Office, North Carolina Department of Environment,
Health, and Natural Resources. October 9, 1995. Discussion
to determine whether plants listed in Section 7 Tracking
System are HAP major sources and pesticide active ingredient
manufacturers.
21. Telecon. Schmidtke, K., MRI, with Liu, J., and
J. Schoenfuss, Mecklenburg County Department of Environmental
Protection, North Carolina Department of Environment, Health,
and Natural Resources. October 9, 1995. Discussion to
determine whether plants listed in Section 7 Tracking System
are HAP major sources and pesticide active ingredient
manufacturers.
22. Telecon. Schmidtke, K., MRI, with Huggins, P., Davidson
County Air Pollution Control, Tennessee Department of Air
Pollution Control. October 24, 1995. Discussion to
determine whether plants listed in Section 7 Tracking System
are HAP major sources and pesticide active ingredient
manufacturers.
23. Telecon. Schmidtke, K., MRI, with Reksten, E., and
A. Frazier, Hamilton County Air Pollution Control Bureau,
Tennessee Division of Air Pollution Control. October 24,
1995. Discussion to determine whether plants listed in
Section 7 Tracking System are HAP major sources and pesticide
active ingredient manufacturers.
24. Telecon. Schmidtke, K., MRI, with Sherrill, L., Shelby
County Air Pollution Control, Tennessee Department of Air
Pollution Control. October 24, 1995. Discussion to
determine whether plants listed in Section 7 Tracking System
are HAP major sources and pesticide active ingredient
manufacturers.
25. Telecon. Schmidtke, K., MRI, with Ahmed, M., Tennessee
Department of Air Pollution Control. October 26 and
December 4, 1995. Discussion to determine whether plants
listed in Section 7 Tracking System are HAP major sources and
pesticide active ingredient manufacturers.
26. Letter from Nixon, S., Knox County Government, Tennessee
Department of Air Pollution Control, to Schmidtke, K., MRI.
November 14, 1995. Information on pesticide active
ingredient facilities that are HAP major sources.
27. Telecon. Schmidtke, K., MRI, with Brochi, P., Texas Air
Control Board. October 16, 1995. Discussion to determine
whether plants listed in Section 7 Tracking System are HAP
major sources and pesticide active ingredient manufacturers.
-------
18
28. Telecon. SchmidtJce, K., MRI, with Enke, S., Betz
Laboratories, Inc. December 5, 1995. Discussion to
determine whether the West; Orange, Texas plant is a HAP major
source and pesticide active ingredient manufacturer.
29. Telecon. Schmidtke, K., MRI, with Hodges, G., Ennis Agri-
Tech. December 6, 1995. Discussion to determine whether the
Ennis, Texas plant is a HAP major source and pesticide active
ingredient manufacturer.
30. Telecon. Schmidtke, K., MRI, with Neman, D., Rohm and Haas
Bayport. December 6, 1995. Discussion to determine whether
the La Porte, Texas plant is a HAP major source and pesticide
active ingredient manufacturer.
31. Telecon. Schmidtke, K., MRI, with Robinson, P., Schenectady
International, Inc. December 8 and 15, 1995. Discussion to
determine whether the Freeport, Texas plant is a HAP major
source and pesticide active ingredient manufacturer.
32. Telecon. Schmidtke, K., MRI, with Buchmann, R., Griffin
Corporation. December 12, 1995. Discussion to determine
whether the Houston, Texas plant is a HAP major source and
pesticide active ingredient manufacturer.
33. Telecon. Schmidtke, K., MRI, with Hoicomb, M., Zoecon
Corporation/Sandoz Agro, Inc. December 12, 1995. Discussion
to determine whether the Dallas, Texas plant is a HAP major
source and pesticide active ingredient manufacturer.
34. Telecon. Schmidtke, K., MRI, with Bartos, S., Chemical
Specialties. December 14, 1995. Discussion to determine
whether the Gilmer, Texas plant is a HAP major source and
pesticide active ingredient manufacturer.
35. Telecon. Schmidtke, K., MRI, with Legg, J., West Virginia
Air Pollution Control. October 20, 1995. Discussion to
determine whether plants listed in Section 7 Tracking System
are HAP major sources and pesticide active ingredient
manufacturers.
36. Telecon. Schmidtke, K., MRI, with Gibson, T., Union Carbide
Corporation. December 14, 1995. Discussion to determine
whether the South Charleston, West Virginia plant is a HAP
major source and pesticide active ingredient manufacturer.
37. Telecon. Schmidtke, K., MRI, with Hackney, H.f PMC
Corporation. December 14, 1995. Discussion to determine
whether the Institute, West Virginia plant is a HAP major
source and pesticide active ingredient manufacturer.
38. Telecon. Schmidtke, K., MRI, with* Miller, D., Clearon
Corporation. December 14, 1995. Discussion to determine
whether the South Charleston, West Virginia plant is a HAP
major source and pesticide active ingredient manufacturer.
39. Telecon. Schmidtke, K., MRI, with Sabatino, B., Cytec
Industries. December 14, 1995. Discussion to determine
whether the Willow Island, West Virginia plant is a HAP major
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19
source and pesticide active ingredient manufacturer.
40. Telecon. Schxnidtke, K., MRI, with Waiborn, K., PPG
Industries, Inc. December- 14, 1995. Discussion to determine
whether the New Martinsville, West Virginia plant is a HAP
major source and pesticide active ingredient manufacturer.
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MIDWEST RESEARCH INSTITUTE
SUM 350
401 Harrison Oaks Bouttvard
Gary. North CeroDna 27513-2412
Telephone (919) 677-0240
FAX (919) 677-0065
Date: December 16, 1996
Subject: Recommended Control Levels for the Process Vent,
Storage Tank, and Wastewater Planks of the New Source
MACT Floor--Pesticide Active Ingredient Manufacturing
NESHAP
EPA Contract 68-D-0115; Work Assignment No. 7-155
BSD Project No. 93/59; MRI Project No. 6507-55
From: David D. Randall
Karen L. SchmidtJce
To: Laiit Banker
BSD/OCG (MD-13)
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
A. Introduction
This memorandum presents recommended control levels for the
process vent, storage tank, and wastewater planks of the new
source MACT floor for the Pesticide Active Ingredient Production
source category. The available information and approach used to
develop the recommended levels are also described.
The 1990 Clean Air Act Amendments specify that standards
for new sources "shall not be less stringent than the emissions
control that is achieved in practice by the best controlled
similar source, as determined by the Administrator." This
control level is termed the "MACT floor."
Information in responses to a Section 114 information
request was used as the starting point in the process to develop
the MACT floor. Several of the responses for the best-performing
plants reported control efficiencies that were higher than those
reported for similar industries in other EPA projects.
Therefore, these facilities were contacted for additional
information in an effort to verify the reported control levels.
Information from the followup contacts was then used along with
knowledge about the performance of similar control devices in
other industries to develop the recommended control levels for
the MACT floor.
The remainder of this memorandum is divided into four
sections. Background information from the Section 114
information requests and additional information that was obtained
during followup calls with the plants is presented in Section II.
A summary of this information, a discussion of factors that
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affect control device performance, and conclusions about the
validity of the reported control efficiencies are presented in
Section III. Recommended control levels for the process vent,
storage tank, and wastewater planks of the new source MACT floor
are presented in Section IV. References are listed in Section V.
II. Information Obtained From Responses to Section 114
Information Requests and Foljowup Contacts
In responses to the Section 114 information request,
several facilities reported organic HAP and HC1 control levels
that are higher than those reported for similar industries in
other EPA projects. These reported control levels, the types of
control devices, and the facility identification numbers are
shown in Table 1. As shown in Table 1, the best performing
facilities in the industry reported organic HAP control levels
above 98 percent for process vents and storage tanks, two
facilities reported HC1 control levels of 99.97 percent or more
for process vents, and one facility reported a control level of
99.99 percent for organic HAP's in wastewater. The facilities
reported the organic HAP control levels for many different types
of control devices: thermal oxidizers, incinerators that are
subject to hazardous waste incinerator regulations under the
Resource Conservation and Recovery Act (RCRA), boilers and
industrial furnaces that are subject to the Boilers and
Industrial Furnaces regulations under RCRA, and scrubbers
followed by condensers. (Note: two facilities indicated that
all of their wastewater was disposed of by deepwell injection.)
The HC1 control devices were water and caustic scrubbers.
For process vents, two control levels are shown for each
process in Table 1. The first control level is the estimated
overall control level for the process; it was calculated from the
reported data for all of the individual process vent streams
related to that process. The second control level is the
reported control level for the primary control device. For
several of the processes, these two control levels do not match
because some process vents are not controlled or are controlled
by a separate, less efficient control device. The highest
verified overall process control level is the value that would be
tteed as the basis for the new source MACT floor control level.
For wastewater, the standard will be applied on an
individual stream basis rather than an overall process basis.
Therefore, only the control level for the most efficient control
flevice needs to be identified in Table 1. In this case, both are
shown simply because the most efficient control device also
happens to be used to control all wastewater streams at the
facility, and the same control level was reported for each
stream.
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TABLE 1. CONTROL DEVICES AND ESTIMATED OVERALL CONTROL EFFICIENCIES FOR
PROCESS VENTS, STORAGE TANKS, AND WASTEWATER SYSTEMS.
Plant
Estimated flvsnll control
efficiency for each
Process
«
nimuy control device
Reported efficiency of
primary control device,
percent
Organic HAP emMOos from prooeu vents
9
22
20
17
12
99.99
99.99
99.99
99.99
99.99
99.99
99.99
99.9
99.9
99.99
99.99
99.99
99.99
99.99
99.0
99.S
99.2
99.99
99.9
99.0
HC1 emianoiis front process vents
11
9
12
100.0
99.97
99.75
25
74
75
76
77
78
79
80
81
82
83
84
85
86
66
61
63
37
38
39
31
32
33
24
25
40
Boiler*
Thermal oxidizer
Thermal oxidizer
Thermal oxidizer
Thermal oxidizer
Thermal oxidizer
Thermal oxidizer
Thermal oxidizer
Thermal oxidizer
Thermal oxidizer
Thermal oxidizer
Thermal oxidizer
Thermal oxidizer
Thermal oxidizer
Absorber/condenser
Industrial furnace
Industrial furnace
Boder
Boiler
RCRA incinerator
Water scrubber
Water scrubber
Water scrubber
Acid scrubber
Acid absorber/caustic scrubber in
series (two backup caustic scrubbers,
99.99% and 95%)
2 caustic scrubbers in series
99.99
99.99
99.99
99.99
99.99
99.99
99.99
99.99
99.99
99.99
99.99
99.99
99.99
99.99
99.6
99.5
99.5
99.99
99.99
99.99
100.0
100.0
100.0
99.95
99.9997
99.75
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Plant
Estimated overall control
effiokocy far each
PTOCCM
Primary control device
. ^__
mMSWmUf
n
99.99
RCRA incinerator
Reported efficiency of
primary control device,
percent
99.99
"In ttae reaponae to the Section 114 information request, Oui control device was identified u • dunnil onduer. In (he
followup tdenhooe eoavccmkm, it wu ideatified u • boiler.
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Bach of the facilities in Table 1 was contacted for
additional information to determine the validity of the reported
control efficiencies. Specifically, they were asked to describe
the methodology used to develop the reported efficiencies,
including whether they had conducted emissions tests, whether the
emission streams are routed to the control device continuously,
and whether the control device is achieving the reported
efficiency continuously.
The information obtained in the responses to the
Section 114 information request and in followup calls for each of
the plants in Table 1 is described in the subsections below.
Organic HAP and HC1 control levels for process vents are
described in Sections B and C, respectively. Storage tank
control levels are described in Section D, and wastewater control
levels are described in Section B. Because many of the
facilities were using incinerators or boilers that are subject to
hazardous waste incineration regulations under RCRA, a review of
some of the hazardous waste incineration requirements is
presented in Section A.
A. Hazardous Waste Incineration Regulations
All incinerators, boilers, and industrial furnaces that
burn hazardous waste must demonstrate a specified 99.99 percent
or greater destruction and removal efficiency (DRE) on the
organic compounds in the hazardous waste feed. This is
accomplished by conducting a trial burn, during which a
synthesized waste or waste spiked with principal organic
hazardous constituents (POHC's) (typically liquid, but it can
also include gas) of known composition and flow is fed to the
unit. The material must contain one or more POHC's. The POHC's
are selected on a case-by-case basis from a list in an EPA
guidance document for permit writers; typically, the selected
POHC's are either major components in the hazardous waste that
the facility wants to burn or they are compounds that are more
difficult to destroy than the major compounds in the hazardous
waste. In most cases, the trial burn must show a DRE of
99.99 percent. Then, as long as the facility operates within
permit conditions (which are established based on operating
conditions during the trial burn), the unit is assumed to be
achieving the 99.99 percent DRE on all hazardous waste.
A second component of the hazardous waste incinerator
regulations is that either carbon monoxide (CO) or hydrocarbon
(HC) concentrations in the outlet stream be monitored
continuously to ensure that the unit operates at high combustion
efficiency and. thus, minimizes the production and emissions of
products of incomplete combustion (PIC'a). The PIC's consist of
thermal decomposition products, compounds that are synthesized
during or immediately after combustion, and any unburned organic
compounds from the waste feed. The PIC emissions are minimized
when the units operate under good operating conditions. To
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ensure that boilers and industrial furnaces operate at high
combustion efficiencies, the regulations require either a CO
limit of 100 ppmv or a HC limit of 20 ppmv, both corrected to
7 percent oxygen. These same requirements are also included in
permits for incinerators.
B. Organic HAP Control Levels for Process Vents
Plant 9.1'2'3 in its response to the Section 114
information request, this facility indicated that all process
vents from process 25 are routed to a thermal oxidizer, and the
reported control efficiency of the thermal oxidizer was 99.99
percent. Thus, the overall process vent control efficiency for
this process was also reported to be 99.99 percent.
In followup conversations, the thermal oxidizer was
identified as a boiler. The facility indicated that process vent
emissions are not routed to the boiler continuously; the
incinerator is down for maintenance for a certain period of time
each year. Organic process vent emissions are routed to a
process recovery device while the incinerator is down. The
recovery rate of this recovery device has not been provided,
however, even if the organics in this stream were not recovered
or controlled, the control efficiency for this process would
still be greater than 99 percent. A trial burn with a mixed
(liquid and gas) POHC was performed to demonstrate the DRE. This
test demonstrated that the boiler achieves a ORE of
99.99 percent. The average feed rate of POHC to the incinerator
during the trial burn was approximately 618 pounds per hour with
approximately 376 standard cubic feet per minute stack flow rate.
The average inlet concentration during the trial burn was
228,000 ppmv corrected to 7 percent 02 by volume. The average
feed rate to the incinerator from this process during regular
operation is approximately 11.9 pounds per hour at 2 standard
cubic feet per-minute flowrate. The average concentration in the
exit stream from this process during normal/regular process
operation is 233,500 ppmv organic HAP; process 25 is a small
percentage of the load to the oxidizer during regular process
operation (less than 5 percent). The concentration to the
thermal oxidizer during normal operation is unknown. In addition
to the trial burn, a source test was performed on process vent
emissions; however, only the exit stream from the thermal
oxidizer was measured. The facility has not performed an
emissions test on the inlet and outlet streams to demonstrate the
control efficiency for process vent emissions. This facility
monitors the CO concentration to comply with the 100 ppmv limit.
Plant- 22.4 The Section 114 response indicated that nearly
all process vent emissions are routed to a thermal oxidizer that
has a reported control efficiency of 99.99 percent. The
remaining process vents are routed to a carbon adsorber with a
reported control efficiency of 99 percent. As shown in Table l.
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the overall control efficiency for processes 74 through 86 is
99.9 percent or greater.
In followup, the plant representative indicated that no
liquid waste is burned at the facility; the thermal oxidizer
controls vapor emissions only. The facility has performed a
stack test on the exit stream from the thermal oxidizer. The
facility has not performed an emissions test on the inlet and
outlet streams to demonstrate the control efficiency of the
device. Based on the design of the oxidizer and on the exit
stream stack test. Plant 22 assumed in its response that the
device achieves 99.99 percent efficiency. Processes are vented
-to the thermal oxidizer continuously, i.e., 100% of the time.
The facility monitors temperature to demonstrate good operation
of the thermal oxidizer. A copy of the exit stream emission test
report may be requested from the corporate representative.
Plant 17.5 The Section 114 response indicated that nearly
all process vent emissions are routed to an industrial furnace
that has a reported control efficiency of 99.5 percent. The
remaining process vents are either uncontrolled or routed to a
^scrubber with a reported control efficiency of 90 percent.
Therefore, the overall process vent control efficiency for each
of two processes was calculated to be 99.5 and 99.2 percent.
In followup, the plant representative indicated that the
control device burns both liquid and vapor streams. The facility
has performed a RCRA Part B pre-Trial Burn on the industrial
furnace to demonstrate liquid waste destruction. The plant has
not performed emissions testing on the process vent emission
streams. (No test data was available for this facility.)
Plant 20.6 Based on the response to the Section 114
information request, this plant vents most process vents to an
absorber and condenser in series. This control equipment
reportedly reduces acetonitrile emissions by 99.6 percent. Other
process vents are uncontrolled. Therefore, the overall process
vent control efficiency for process 66 was estimated to be 99.0
percent.
The plant representative indicated in followup that an
emissions test to demonstrate the control efficiency of the
device has not been performed. The control efficiency reported
in the response was based on the design of the control devices.
Plant 12.7'8'9'10 Based on data from the Section 114
response, some process vent streams are routed to boilers, some
are routed to a RCRA incinerator, and others are uncontrolled.
Control efficiencies were reported to be 99.99 percent for both
the boilers and the RCRA incinerator. Estimates for the overall
process vent control efficiency for three processes at the plant
ranged from 99.0 to 99.99 percent.
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8
In followup, the plant representative indicated that there
are two boilers at the facility. These were originally vapor
stream incinerators and were later modified to be boilers; while
the boilers were once used for liquid waste stream destruction,
they are no longer used for liquid waste streams because
regulatory requirements are too expensive. The facility has not
performed a formal Trial Burn. The plant representative
indicated that the facility has performed a "stack test" on the
boiler to demonstrate 99.99 percent reduction for liquid streams.
An emissions test for vapor streams has not been done. However,
in the Section 114 response, the plant representative assumed
that the boiler was achieving 99.99 percent for process vent
emission streams. All emissions streams from processes 37 and 38
are vented continuously to a boiler; one of the two boilers is
always on-line, and the processes are not operated unless it is
venting to a boiler.
The RCRA incinerator burns both liquid hazardous waste and
vapor streams. The plant has performed a Trial Burn to
demonstrate 99.99 percent DRB for liquid wastes. The plant has
not performed an emissions test to demonstrate the efficiency
achieved by the incinerator on vapor streams. The plant
representative assumed that the control efficiency for process
vent emissions is equal to the DRE for liquid wastes. The plant
is required to keep data on the operating temperature and
residence time of the incinerator. Process vent emissions are
routed to the incinerator continuously; if the incinerator is
shutdown, then the process is shutdown as well. During the trial
burn, approximately 380 pounds per hour of POHC was fed to the
incinerator at an average flow rate of 8,200 standard cubic feet
per minute (concentration averaged 1,590 ppmv organic HAP, no
data on percent CM . For regular process operation,
approximately 37.5 pounds per hour of organic HAP is routed to
the incinerator from process 39 at 246 standard cubic feet per
minute inlet flow rate (concentration is approximately
16,100 ppmv). At least one other PAI process at the plant also
vents to this device.
C. HC1 Control Levels for Process Vents
II-11 In its response to the Section 114 information
request, this plant indicated that HC1 was emitted from two
processes. These HC1 emissions were controlled using water
scrubbers (in series with RCRA incinerators that are used to
control organic HAP emissions) with reported control efficiencies
of 100 percent. In a followup conversation, the corporate
representative indicated that the reported control efficiency was
incorrect. The scrubbers were designed to achieve a 99 percent
reduction. Tests have not been conducted to determine the actual
control efficiency.
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Plant g.1*2*3 In its response to the Section 114
information request, this plant indicated that HC1 was emitted
from two processes.
The plant indicated that all HC1 emissions from process 24
are controlled by a two-stage acid absorber reportedly achieving
99.95 percent. The facility has not performed an emissions test
on the device to demonstrate the control efficiency for HC1. The
control efficiency reported in the response is based on design of
the devices.
For process 25, the overall control efficiency was
estimated to be 99.9996 percent. For this process, the HC1
emission stream is controlled by an acid absorber and caustic
scrubber in series (these devices are associated with the thermal
oxidizer). When the thermal oxidizer is down, the HC1 in this
stream is controlled by one of two backup scrubbers. The
absorber and scrubber associated with the thermal oxidizer
reportedly achieve an overall 99.9997 percent reduction in HC1
emissions. One of the backup scrubbers reportedly achieves
95 percent control efficiency for HC1 and the other backup
^scrubber was reported to achieve 99.99 percent control efficiency
for HC1. The facility has not performed emission tests on these
control devices to determine the HC1 control efficiency. The
control efficiencies reported in the response are based on design
of the device.
Plant 12.7,8,9,10 prom the response to the Section 114
information request, it is estimated that the HC1 control
efficiency for process 40 is 99.75 percent. The HC1 emissions
.were controlled using two caustic scrubbers in series with
reported control efficiencies of 95 percent each. In a followup
conversation, the plant representative indicated that the first
scrubber is an HC1 control device with a design efficiency of
95 percent. The outlet stream from the first scrubber is routed
to a second scrubber that is a general building air wash system
(high inlet gas flowrate). This device is used to controls
vapors collected from miscellaneous sources such as sample hoods
and is intended to be an industrial hygiene device rather than an
air pollution control device. The control efficiencies provided
by the facility for each of these devices is based on design.
Tests have not been conducted to determine the actual HC1 control
efficiency.
u. Storage tanks
Several facilities vent storage tank emissions to control
devices with efficiencies that were reported to be greater than
98 percent. Five facilities reported 22 storage tanks that are
controlled above 98 percent; 21 out of 22 of the tanks are
controlled with combustion technology.12 These facilities use
the same control device units to control storage tank emissions
that are used to control process vent emissions (i.e., the
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10
control devices are not dedicated to storage tank
emissions) .1'2'3»4»7'8'9'10'13 AS is the case for process vent
emissions, the facilities have not performed emission tests to
demonstrate the reduction efficiency achieved by the devices for
storage tank emission streams.
B. Hastewater
~ Plant fri.lljl3 In its response to the Section 114
-information request, this facility indicated that all wastewater
streams are incinerated in any of several RCRA incinerators. For
organic compounds in all wastewater streams, the control
efficiencies of all incinerators were reported to be
99.99 percent. The RCRA incinerators are used to control
emissions from some process vents and storage tanks as well as to
incinerate wastewater and hazardous waste.
In followup conversations, plant and corporate contacts
indicated that the facility conducted a Trial Burn, which
demonstrated a 99.99 percent ORE. The POHC incinerated during
the Trial Burn was chosen based on compounds in liquid waste
streams and in wastewater streams. The DRB would apply to
wastewater streams that are burned in the RCRA incinerators just
like it would to any other liquid waste stream at the facility
(however, more auxiliary fuel would be needed to evaporate all
the water and maintain the required operating temperature). The
facility has not conducted a test to determine the control
efficiency on organics in wastewater alone. (Monitoring
procedures were not discussed during the conversations.)
III. Discussion
A. Organic HAP control efficiency
To reduce organic HAP emissions from process vents, four of
the five plants listed in Table 1 for process vents used
combustion control devices and one used a scrubber followed by a
condenser. The combustion devices were used to control a variety
of organic HAP's; the other devices were used to control only a
single organic HAP.
According to the follow-up contacts, none of the five
plants have conducted emissions tests to determine the emissions
reductions for process vent emissions alone. The four plants
that used combustion devices reported control efficiencies that
were based on (1) DRE's from trial burns, (2) destruction
efficiencies for liquid wastes from non-trial burn tests, and
(3) design specifications. The plant that used an absorber and
condenser in series reported a design control efficiency.
None of the reported cdhtrol efficiencies should be used as
the control efficiency for the new source MACT floor. The DRB's
from trial burns indicate the percentage reduction in organic
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11
compounds in liquid (or mixed) wastes, but no data are available
to show that they represent the control efficiency that would be
achieved on a gas stream alone. In addition to no data on the
control efficiency for gas streams alone, there also are no data
to verify the control efficiencies that were calculated based on
design specifications. The validity of the reported assumed
control efficiency for process vents alone is suspect. According
to the available test data (source test at Plant 9 and Trial Burn
at Plant 12) and the Section 114 responses, the operating
conditions during the performance test may not necessarily be
similar to the conditions during normal process operation. Two
important differences include: (1) the amount of organic HAP
emission from processes during normal operation may be a fraction
of the POHC feed to the combustion device during the performance
test, and (2) during normal continuous and batch process
operation, the amount of organic HAP emissions in the process
vent streams may vary significantly throughout the batch or
process cycle. Such differences in concentration may lead to
differences in ORE (or control efficiency), as described in a
report summarizing the results of Trial Burns.14 Given these
potential differences, the reported control efficiencies based on
pRE's should not be the basis of the process vent new source MACT
floor for organic HAP.
To reduce organic HAP emissions from storage tanks, all but
one of the best controlled storage tanks used combustion-based
control devices. The same devices that are used to control
emissions from process vents are used to control emissions from
storage tanks. As described above, the reported control
efficiencies for these devices can not be supported with test
data. In addition, there is no data to demonstrate the
efficiencies for dedicated control devices for storage tanks.
The MACT standard for storage tanks will address the control
efficiency achieved on storage tanks alone. Thus, the reported
control efficiencies should not be used as the basis for the new
source MACT floor.
Variations in chamber temperature, residence time, inlet
concentration of organics, compound type, and mixing affect the
organics destruction efficiency of a thermal incinerator.
Performance tests demonstrate that all new thermal incinerators
can achieve at least 98 percent VOC destruction (or HAP
destruction, since most HAP's are VOC's) for vent streams with
VOC concentrations above 2,000 ppmv at combustion chamber
temperatures ranging from 1,300 to 2,370°F and residence times of
0.5 to 1.5 sec. For VOC streams with concentrations below
2,000 ppmv (corresponding to 1,000 ppmv VOC in the incinerator
inlet stream because air dilution is typically 1:1), all new
thermal incinerators can achieve either a reduction of 98 percent
or greater or an outlet VOC concentrations of 20 ppmv or lower
(i.e., for a low inlet concentration, 98 percent may not be
possible, but the outlet concentration would not exceed
20 ppmv).15 A flare that is designed and operated in accordance
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12
with the requirements in 40 CFR 63.11 also achieves at least
98 percent reductions.
The control efficiencies achieved with condensers and
scrubbers vary depending on stream characteristics. Condensers
are most efficient on streams with high concentrations and low
volatility. Scrubber efficiency depends on finding a solvent in
which the HAP is highly soluble; the absorptive capacity and
strippability of the solvent are other important factors.
Although each of these control devices may be able to achieve an
efficiency equal to or greater than a combustion device for
certain streams, none can do it as consistently across the board
as a combustion device.
B. RC1 control efficiency
Design of HC1 control devices for three processes at two
facilities indicate control efficiencies that are greater than
99 percent. As indicated in the follow-up contacts, neither of
these facilities have conducted emissions tests to determine the
HC1 control efficiencies for these devices. The control
efficiencies reported were based on design parameters of the
^devices.
The HC1 emissions in the PAI industry may occur from two
types of operations: (1) HC1 generated during process operation
and vented from the process, or (2) HC1 generated from control of
chlorinated organics by combustion. Variability in the inlet gas
HC1 concentration, the inlet gas flow rate and the water flow
rate (liquid to gas ratio), the concentration of HC1 in the
scrubber water, and the water temperature affect absorption of
HC1 into water in a packed bed scrubber.
The best reported HC1 controls are scrubbers for two
processes at Plant 9, i.e., 99.9996 and 99.95-percent. Although
no test data are available to show the HC1 control efficiencies
for scrubbers at these PAI plants, tests of similar scrubbers
used to control HC1 emissions from hazardous waste incinerators
are available. These tests indicate that HC1 removal
efficiencies for packed bed scrubbers following incineration
devices of 99.90 and 99.94 percent can be achieved.14 These
plants in the hazardous incineration study with control
efficiencies of 99.9 percent or higher are controlling HC1 with
two or three scrubbers in series. The HC1 control devices used
for one process at Plant 9 follow an incinerator and have a
similar application to those devices tested in the hazardous
waste incineration study. At least one State, Texas requires
99.9 percent reduction of HC1 emissions generated from the
combustion of chlorinated organics in hazardous waste
incinerators.
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13
C. Wastewater control efficiency
Plant 11 reported its incinerators have control
efficiencies of 99.99 percent on hazardous waste, but no
wastewater-specific control efficiency data are available.
However, it is reasonable to assume that, because the devices are
RCRA incinerators, the control efficiency is at least 99 percent,
the same level achievable by steam stripping for many compounds.
Data are not available to the EPA to conclude that the
incinerator is achieving greater efficiency.
IV. Recommended MACT Floor Control Levels
Based on the information obtained through the follow-up
contacts, the new source MACT floor for organic HAP emissions
from process vents and storage tanks should be based on
combustion technology. The control efficiency, however, should
be 98 percent, a level that has been demonstrated in numerous
tests. The floor should not be based on the higher efficiencies
reported by the facilities in the Section 114 responses because
none of the facilities had data to support a control efficiency
•greater than 98 percent. Other types of control devices may be
able to achieve control efficiencies equal to or greater than
98 percent on certain streams, but because there is significant
variability in stream characteristics throughout the industry,
not all streams can be controlled to the same high levels as
could be achieved for a specific individual stream.
Based on the follow-up contacts, the new source MACT floor
for HC1 emissions should be based on a 99.9 percent control
efficiency. The floor should not be based on a higher efficiency
reported in the responses to the Section 114 information
collection request because none of the facilities had test data
to support their reported design control efficiency. While no
test data was provided for the PAI industry, test data from
similar scrubbers in another industry show that the HC1 control
efficiency of 99.9 percent is achievable. Without specific test
data for this industry, the HC1 control efficiency that has been
demonstrated in other industries will be used.
Based on information from Plant 11, the control level for
the wastewater systems plank of the new source MACT floor should
be 99 percent. This plant has not conducted a test showing the
control efficiency for the incinerator when burning only
wastewater.
V. References
1. Confidential business information.
2. Confidential business information.
3. Confidential business information.
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14
4. Confidential business information.
5. Confidential business information.
6. Confidential business information.
7. Confidential business information.
8. Confidential business information.
9. Confidential business information.
10. Confidential business information.
11. Confidential business information.
12. Confidential business information.
13. Confidential business information.
14. Performance Evaluation of Pull-Scale Hazardous Waste
Incinerators. Volume 2 Incinerator Performance Results and
Volume IV Appendices C through J. Midwest Research
Institute. November 1984.
15. Memorandum and attachments from Farmer, J., EPA/BSD, to
Ajax, B. et al. August 22, 1980. Thermal incinerators and
flares.
-------
Docket No. A-95-20
Category H-B
The following information is located in the confidential files of the Director, Emission
Standards Division, Office of Air Quality Planning and Standards, U. S. Environmental Protection
Agency, Research Triangle Park, North Carolina 27711. This information is confidential pending
final determination by the Administrator and is not available for public inspection.
Attachment to Recommended Control Levels for the Process Vent, Storage Tank, and
Wastewater Planks of the New Source MACT Floor Memorandum (part of docket item EI-B-21).
This attachment consists of the full citations for the confidential references in this
memorandum.
-------
MIDWEST RESEARCH INSTITUTE
Suite 350
401 Harrison Oiks Boulevard
Gary. North Carolina 27513-2412
Taltphon* (919) 677-0249
FAX (919) 6774065
Date: January 6, 1997
Subject: Growth Projections for the Pesticide Active Ingredient
Production Industry--Pesticide Active Ingredient
Manufacturing NESHAP
EPA Contract 68D60012; Task Order No. 0004
ESD Project No. 93/59; MRI Project No. 4800-04
From: Karen L. Schmidtke
To: Laiit Banker
ESD/OCG (MD-13)
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
I. Introduction
This memorandum presents the available information and the
approach used to estimate the growth of the Pesticide Active
Ingredient (PAI) Production industry in the five years after
promulgation of the standards. The EPA is required to estimate
the impacts of the MACT standards. The number of new sources
expected for this industry in the five years following
promulgation will be used in the determination of impacts of the
new source MACT.
II. Estimation of the Number of New Affected Sources
The number of new affected sources was estimated using the
number of existing affected sources and the industry growth rate
in the five years following promulgation of the standards. The
total number of existing affected sources is estimated to be
78 sources.1 From 1983 to 1993, the amount of PAI production
increased from 975 million pounds to 1,150 million pounds at an
approximate average of 2 percent per year. The projected growth
rate has been based on 10 years of production data for the
industry. Looking at shorter time periods of 2 to 3 years within
the 1983 to 1993 decade indicates alternating periods of
increasing and declining production. Because there is
fluctuation in PAI production from year to year, basing the
growth projection on a longer period of time is likely to provide
a more representative indication of industry trends.
Because there was no available information on the increase
in the number of sources over time, the annual average 2 percent
increase in PAI production was assumed to be equivalent to the
increase in the number of new sources. It was assumed that the
industry will grow at the same rate in the five years following
-------
promulgation. Applying this growth rate to the 78 existing
affected sources results in an estimated 8 new sources over the
five years following promulgation of the NESHAP
[78 x ((l + 0.02)5 - 1) = 8] .
III. References
-L. Memorandum from K. Schmidtke, MRI, to L. Banker, EPA:BSD.
November 27, 1996. Estimation of the Number of Affected
Sources in the Production of Pesticide Active Ingredient
Source Category.
2. Chemical and Engineering News. July 26, 1995.
-------
MIDWEST RESEARCH INSTITUTE
Suite 350
401 Human Oaks Boulevard
Caiy. North CireGna 27513-2412
Telephone (919) 677-0249
FAX (919) 677-0065
Date: April 15, 1997
Subject: Summary of Data from Responses to Information
Collection Requests and Site Visits for the Production
of Pesticide Active Ingredients NESHAP
EPA Contract No. 68-D1-0115; Work Assignment No. 1-04
BSD Project No. 93/59; MRI Project No. 4800-04
From: David Randall
Karen Schmidtke
To: Laiit Banker
ESD/OCG (MD-13)
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
I. introduction
This memorandum summarizes the data that were provided by
the pesticide active ingredient (PAI) production industry in
response to Section 114 information requests that were sent to
nine companies. The data were collected for use in developing
maximum achievable control technology (MACT) for national
emissions standards for hazardous air pollutants (NESHAP) for the
production of PAI industry. The companies that received
information requests were selected because they have at least one
plant that: (1) is a major source, (2) produces a variety of
products, (3) uses a variety of production processes, and
(4) implements air pollution control technology. Companies with
more than one plant meeting these criteria were favored over
companies with only one plant. Information was also obtained
from a site visit at one plant belonging to another company.
Data were obtained from 23 plants.1 Two of the plants were
area sources, and information from one plant is incomplete.
Therefore, data from 20 plants are summarized in this memorandum.
This memorandum also describes procedures used to estimate total
annual uncontrolled and controlled emissions from PAI processes
at the 20 plants. The remainder of this memorandum is divided
into five sections that each address one of the five types of
emission points in the PAI production industry: process vents,
equipment leaks, storage tanks, wastewater systems, and bag dumps
and product dryers.
-------
II. Process Vents
The 20 plants reported a total.of 93 processes that,
collectively, emit 39 hazardous air pollutants (HAP) . A list of
the HAP is presented in Table 1. Hydrochloric acid (HC1) is used
by the most plants, is emitted from the most processes, and is
the HAP that is emitted in the greatest quantity. Methanol and
toluene, which are used by 10 and 7 plants, respectively, are the
most widely emitted organic HAP. Of all of the organic HAP,
toluene is emitted in the greatest quantity (controlled basis).
The next highest emissions are for methanol. Chlorine, HC1,
•hydrogen cyanide, and hydrazine are inorganic HAP; the other HAP
are all volatile organic compounds (VOC).
•*
Table 2 presents operating and emissions data for each of
the 93 processes. Active ingredients and intermediates are
manufactured in 77 and 15 of the processes, respectively; 1
process was not identified. Sixty-six of the processes are batch
processes, 19 are continuous, and 8 are a combination of batch
and continuous operations.
Operating hours for the 93 processes ranged from 96 to
#,760 hr/yr for batch processes and from 336 to 8,136 hr/yr for
continuous processes. Data on process operating hours were
provided in as many as three formats by each facility: (1) the
hours per batch and batches per year for batch processes, (2) the
hours per day and days per year for continuous processes and some
batch processes, and (3) the operating hours per year for the
individual process vents. When data were provided in multiple
formats, the resulting hours per year often varied. Therefore,
the following criteria were used to select the process operating
hours that are presented in Table 2:
1. If the facility provided only one value, it was
automatically selected;
2. Hours per year for individual process vents were not
selected unless it was the only value available; individual
process vent hours per year may differ from the process operating
hours if the unit operation is only used during part of the
process or if the vent has pressure relief settings;
3. The value obtained by multiplying the hours per batch
times the batches per year was selected if it gave a lower value
than the hours per day times the days per year. The selected
value is the minimum number of hours that the process could be
operating; the higher value may indicate that there are gaps
between batches;
4. The value obtained by multiplying the hours per day
times the days per year was selected if it gave a lower value
than the hours per batch times the batches per year. The
difference suggests that the batches overlap. Therefore, the
selected value corresponds with the number of hours that a
control device would need to operate;
-------
5. If the hours per batch and batches per year were the
only data provided, and the product of these values exceeded
8,760 hours per year, the selected value was 8,760 hours per
year.
Table 2 also presents uncontrolled (or precontrol) and
controlled annual emissions for each of the 93 processes. The
emissions data that were provided by the plants were classified
in Table 2 as: (1) chlorinated organics, (2) unchlorinated
organics, (3) HC1, (4) other, and (5) total. The processes in
Table 2 are ranked according to their uncontrolled total annual
emissions. Emissions data were not provided for six processes,
although emissions were reported to be small for all six. Of the
remaining 87 processes, 84 have organic HAP emissions and 34 have
HC1 emissions. Thirty-one of these processes have both organic
HAP and HC1 emissions. There are 53 processes that emit organic
HAP but have no HC1 emissions; three processes have HC1 emissions
but do not emit organic HAP.
There are a total of 72 processes with organic HAP
emissions greater than or equal to 0.15 Mg/yr. The majority of
processes with low uncontrolled organic HAP emissions are not
controlled. Of the 23 processes with the lowest uncontrolled
organic HAP emissions, 11 are controlled and 12 are uncontrolled.
Of the lowest 12 processes (based on uncontrolled organic HAP
emissions), 3 processes are controlled and 9 are uncontrolled.
There are 16 processes with HC1 emissions greater than or
equal to 6.8 Mg/yr. Of these 16, 11 are controlled to 94 percent
or greater and 5 are controlled to less than 94 percent.
Many of the reported control efficiencies for gaseous
organic HAP emissions were above 98 percent. The facilities
using combustion-based control devices were contacted to discuss
the basis for the reported control efficiencies. These
facilities indicated that they did not conduct emissions tests
when only process vent emissions were routed to the control
devices. The reported control efficiencies were based on trial
burns for demonstrating compliance with the hazardous waste
incineration regulations, tests when burning multiple types of
waste or emission streams, or on manufacturer guarantees. The
control efficiencies were revised based on analysis of the
original data from the Section 114 response, follow-up contact
with the plants, and other information. The controlled emissions
shown in Table 2 are based on the revised control efficiencies.
III. Equipment Leaks
Nine of the plants provided equipment counts for 30 of the
93 processes. A summary of the equipment counts is presented in
Table 3. Nineteen of the processes are batch processes and
11 are continuous processes. Information on valves in gas and
-------
liquid service was provided for 17 of the processes; only the
total number of valves was provided for the other 13 processes.
According to 40 CFR part 63 subpart H [part of the
hazardous organic NESHAP (HON) for the synthetic organic
chemicals manufacturing industry], liquid valves and pumps may be
, in either light liquid service or heavy liquid service. Light
liquid service for equipment components means a piece of
equipment in organic HAP service meets the following conditions:
(l) the vapor pressure of one or more of the organic compounds is
greater than 0.3 kilopascals (kPa) at 20°C, (2) the total
-concentration of the pure organic compound(s) having a vapor
pressure greater than 0.3 JcPa at 20°C is equal to or greater than
j20 percent by weight of the total process stream, and (3) the
fluid is a liquid at operating conditions.3
Seventy-eight of the 84 processes with organic HAP
emissions use at least one HAP that would satisfy the vapor
pressure condition for light liquid service. Because seven of
the nine plants that provided equipment count-data were
implementing leak detection and repair (LDAR) programs, it is
likely that they reported only those components that are in
Contact with a liquid process fluid at the operating conditions.
The concentration of HAP in the process fluid in contact with the
components was not provided. However, based on the prevalence of
compounds that satisfy the vapor pressure criterion, it was
assumed that all of the liquid valves and pumps are in light
liquid service.
Modelling of equipment counts and operating hours is needed
to estimate annual fugitive emissions for 60 of the 93 processes.
Therefore, uncontrolled and controlled equipment leak emissions
estimates for these processes are presented in the baseline
emissions memorandum rather than in this memorandum.4
*
IV. Storage Tanks
Sixteen of the plants provided information on 102 storage
tanks that contain 30 HAP compounds. All storage tanks reported
are fixed roof tanks. These storage tanks consist of 80 organic
HAP tanks, 2 hydrazine hydrate tanks, 18 HC1 tanks, and
2 phosphorus tanks (molten phosphorus). Table 4 lists the HAP
compounds that are stored in the PAI production industry and the
uncontrolled and controlled emission level for each HAP.
Sixteen of the 20 plants (80 percent) have organic HAP storage
tanks. Hydrochloric acid storage tanks are located at 7
facilities (35 percent). Table 5 describes the number and
percentage of organic HAP tanks based on tank capacity and vapor
pressure parameters; Table 6 describes the number and percentage
of organic HAP tanks based on tank capacity and uncontrolled
emissions. Average values for various tank parameters are
provided in Table 7.
-------
Vapor pressures for pure component storage tanks were
calculated using Antoine's equation and constants, virial
equations of state, or other generally available sources of
information. Raoult's Law and Henry's Law were used to calculate
partial pressures for mixtures of components. The uncontrolled
. emissions from each organic HAP storage tank were calculated
using EPA's TANKS3 program (User's Guide to TANKS, Storage Tank
Emissions Calculation Software, February 20, 1996,
EIB/OAQPS/EPA).5
A number of control devices are used to reduce HAP
emissions from storage tanks. Table 8 contains a list of control
devices used for storage tanks in the PAI manufacturing industry;
this table identifies the type of HAP controlled and provides a
range of control level achieved by the device. The uncontrolled
and controlled emissions and the percent reduction for each
facility are shown in Table 9. From the tank information
provided, the total uncontrolled emissions from organic storage
tanks at these 16 plants are 56.9 Mg/yr and the total controlled
emissions are 9.02 Mg/yr.
Other regulations, such as the HON and Pharmaceuticals
'NESHAP, have established capacity and vapor pressure
applicability cutoffs in their requirements. All 82 tanks at the
surveyed PAI plants are listed in Table 10 along with each
control device, control efficiency, and the uncontrolled and
controlled emissions. There are 68 storage tanks in the PAI
manufacturing data base with capacity greater than or equal to
38 cubic meters (m3) (10,000 gallons). These 68 tanks are
located at 16 plants. Storage tanks greater than or equal to
38 m3 (10,000 gallons) account for 98 percent of the uncontrolled
storage tank emissions and 93 percent of the controlled storage
tank emissions at the facilities in the data base.
V. Wastewater Systems
Sixteen of the 20 plants provided data on wastewater
streams for 45 of the 93 processes. Table 11 lists the 28 HAP
that were reported to be in the wastewater streams. Toluene,
methanol, xylenes, and HC1 were contained in the most streams.
Annual loadings for methanol, ethylene dichloride, and HC1 were
significantly higher than loadings for other compounds; ethylene
'dichloride annual loading from two processes at one plant ranked
second behind methanol.
Not all of the HAP loading has the potential to volatilize
from wastewater. For the HON, extensive modeling analyses were
conducted to estimate the fraction of each HAP loading that might
volatilize from typical collection and biotreatment systems.
These fractions, or Fe values, were used to determine which HAP
would be subject to the standards. A total of 76 HAP in the HON
had Fe values that indicated a significant fraction of the
loading would be emitted; these HAP were listed in Table 9 of the
-------
HON, and streams that: contained them were subject to the
standards. Wastewater streams with HAP that were not Table 9
compounds in the HON were not. subject-to the rule because their
low Fe values indicated that they would not be emitted in
significant quantities from collection and biotreatment systems.
In addition, the organic HAP with low Fe values also readily
degrade in biological treatment units. Of the 28 HAP in
Table 11, 19 are Table 9 compounds in the HON. Compounds that
are not Table 9 compounds in the HON include chloroacetic acid,
cyanides, ethylene glycol, ethylene glycol mono butyl ether,
formaldehyde, HC1, hydrogen cyanide, and phenol. One HAP was
'identified by the generic term "glycol ether." This compound is
a Table 9 compound in the HON if it is ethylene glycol dimethyl
;ether; all other glycol ethers are not Table 9 compounds in the
HON.
In many cases, it was not clear if the respondents were
providing information for an aggregated stream or if only one
wastewater stream was generated from each process. For ten of
the processes (processes 13, 14, '15, 16, 17,^18, 22, 35, 37, and
38) , the plant reported information for several individual
wastewater streams for each process. Data for individual streams
•from these eight processes are provided in Table 12. To put all
of the data on the same basis, these individual wastewater
streams for a given process were aggregated. Table 13 shows data
on the 45 aggregated streams with compounds in Table 9 of the HON
at the 16 PAI.production facilities.
Wastewater streams from 29 of the 45 processes receive
onsite biological treatment and are discharged directly to nearby
waterways. Four plants also treat streams from 13 of these
29 processes with activated carbon before biological treatment.
The stream from 1 of the 29 processes is treated with steam
stripping; the overheads are incinerated and the bottoms are sent
for biological treatment. Streams from 4 of the 45 processes
receive no onsite treatment or only neutralization before
indirect discharge to publicly owned treatment works (POTW's).
The streams from 2 processes are disposed of by deepwell
injection. Streams from 9 processes are treated by incineration.
The stream from 1 process is sent to an air stripper, and the
resulting vapors are incinerated.
In previous regulations (and regulations under
development), biodegradation technology was assigned a level of
zero percent control in MACT floor analyses, although it is
allowed as a technology for complying with the control
requirements for wastewater. A control level above zero was
assigned only when other treatment methods (e.g., steam stripping
or incineration) were used. The same approach was used in this
analysis.
As noted above, not all of the HAP in the wastewater has a
potential to volatilize. Therefore, uncontrolled emissions were
-------
estimated to be equal to the HAP loading times the respective Fe
value. The Fe values that were developed for the HON are shown
in Table 13 for each HAP in wastewater streams from PAI
manufacturing facilities. The resulting uncontrolled emission
estimates are also shown in Table 13.
Controls are assumed to be installed upstream of, or in
place of, the biotreatment system. Therefore, controlled
emissions were estimated by a two step process. First, an
assumed efficiency of the control technology was multiplied by
the HAP loading. Second, the remaining HAP in the wastewater
after control was multiplied by the Fe. This two step procedure
is equivalent to multiplying the uncontrolled emissions by the
assumed efficiency of the control technology. For the
incinerator used at plant 11, the control efficiency on multiple
organics was assumed to be 99 percent (a scrubber is used to
control HC1 that is formed from combustion of chlorinated
organics). Based on the fraction removed (Fr) analysis for the
HON, the steam stripper at plant 13 was assumed to have a control
efficiency of 31 percent on methanol. At plant 10, air stripping
was assumed to have a control efficiency of 95 percent on carbon
tetrachloride and tetrachloroethylene. The resulting controlled
emissions estimates are shown in Table 13.
VI. Baa Dumps and Product Dryers
Two of the 20 plants reported particulate matter (PM) HAP
emissions. One plant emitted maleic anhydride from a bag dump
used to introduce the raw material into the process. The second
plant emitted captan from a product dryer. Table 14 presents the
HAP compounds and emissions from bag dumps and product dryers.
-------
8
TABLE 1. LIST OF HAP COMPOUNDS FROM PROCESS VENTS*
HAI*
1.3-Butadiene
Acetonitrile
Aniline
Bourne
Benzyl chloride
Cuban disulfide
Cuban tetncUoride
Chlorine
Chlofofoiin
Cyanides '
Unspecified
Hydrogen cyanide
Ethyl benzene
Ethyl chloride
Ethylene dichloride
Fonnaldehyde
Glycol ethers
Unspecified
Ethylene glycol
butyl ether
HC1
Hexachlorobenzene
Hexachlorocyclopentadiene
Hexachloroethane
Hexane
Hydnzine
Hydroquinone
Maleic anhydride
Methanol
Methyl chloride
Methyl ethyl ketone
Methyl uobutyl ketone
h4_lk«jl :«tmm»ate
Metnyi isocyanaie
Methyfeoe chloride
N.N-DimethyUniline
Phosgene
Tetnchloroethylene
Toluene
*§*•—§-• - «- -
HH41IUHHIf IIJI JH
No of
plants
1
2
1
2
1
2
5
5
1
1
1
1
2
2
3
1
1
11
1
1
1
2
1
1
1
10
3
1
2
3
1
2
2
7
2
No of
1
3
1
3
4
2
7
8
1
4
1
5
3
8
9
1
1
36
1
1
1
2
1
1
2
23
4
1
5
1
3
1
7
2
32
2
Uncontrolled
«ni«ons
Mf/yr
33.0
86.3
0.009
92.7
1.39
29.1
66.0
95.9
0.142
30.3
7.71
1.13
27.1
167
2.63
0.916
0.068
4.050
0.005
0.045
2.85
24.7
0.091
c
0.149
405
115
18.9
59.4
1 10
41.1
34.3
2J50
59.7
496
0.444
Controlled
Mf/yr
0.660
2.69
0.009
3.41
1.39
14.3
16.5
2.38
0.142
0.003
0.001
0.023
3.60
4.54
0.386
0.027
0.068
301
c
0.005
0.057
3.14
0.091
c
0.149
80.4
51.1
0.668
21.9
Our?
18.2
0.171
48.8
9.80
151
0.314
Pnccnt
*
98
97
0
96
0
51
75
98
0
99.99
99.89
98
87
97
85
97
0
93
99.91
90
98
87
0
0
0
80
56
96
63
56
99.5
97
84
70
29
-------
TABLE x. (continued)
HAP0
Trichlofoethyleae
Triethylamine
Xykae
TOTAL
No. of
plants
2
1
4
No. of
prOCeBeCS
2
2
IS
Uncontrolled
cmunons.
Mg/yr
18.2
56.2
135
8,510
Controlled
^fin wi^fiif
Mg/yr
0.609
17.3
21.7
777
Percent
reduction.
%
97
69
84
91
?HAP emitted from 93 proceiiea at 20 plmti.
"HCI, chlorine, hydrogen cyanide, and hydrazine are inorganic; the other HAP are VOC's.
are leu than 0.0001 Mg/yr
-------
TABLE 2. SUMMARY OF PROCESS VENT EMISSIONS
Plant
no. (a)
3
15
3
8
13
3
15
15
15
10
23
15
15
3
15
3
15
11
23
20
15
17
11
11
21
Process
no.
10
53
8
21
41
5
52
55
49
26
87
48
50
9
51
13
56
35
88
65
57
60
34
36
70
Ml
IN B/C
Al B
Al B
IN B
Al B
Al B
Al B
Al B
Al B
Al B
Al B
IN B
Al B
Al B
Al B
Al B
Al B
Al B
Al B/C
Al B
Al B
Al B
Al B
Al B/C
IN B
Al B
Process
operating
hr/yr
904
192
3,312
2,208
(d)
7,809
120
8,160
840
7,296
567
960
96
1,425
192
5,040
360
3,588
340
2,200
3.960
1,548
1,600
7,776
127
Chlorinated
organics
-------
TABLE 2. SUMMARY OF PROCESS VENT EMISSIONS (continued)
Plant Process
no. (a) no.
23 90
15 58
3 7
3 12
21 71
21 72
5 14
21 73
14 46
23 89
22 81
8 22
14 43
15 54
14 44
22 80
23 92
14 47
14 45
22 76
22 77
1 2
21 69
17 61
1 4
Al/
IN B/C
Al B
Al B
IN B
Al B
Al B
Al B
IN C
Al B
Al B
Al B
Al B
Al B
Al B
Al B
Al B
IN C
Al B
Al B
Al B
IN B
IN B
Al C
Al B
Al C
Al C
Process
operating
hr/yr
1,340
5,220
8,160
4,178
148
169
7,464
189
288
2,320
300
2,208
792
5,784
696
456
360
576
840
1,776
1,184
336
570
1,920
720
Chlorinated
organics
0.00771
0
0.693
0
0
0
0
0
0
0.0132
0
0
0
0
0
0
0486
0
0
0
0
0.0459
0
0
0.0751
Uncontrolled
Unchlor-
inated
0.198
0.679
0
0.782
0.820
0.857
0.916
0.969
1.00
0.342
1.38
1.41
1.74
1.59
1.76
1.81
1.39
2.28
3.19
4.54
4.54
5.59
5.81
8.19
914
emissions.
HCI (b)
0.410
0
0
0
0
0
0
0
0
0710
0
(d)
0
0.157
0
0
0.000950
0
0
0
0
0.0262
0
0
0.0428
Mg/yr
Other (c)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0 .
0
0
0
0
Total
0.616
0.679
0.693
0.782
0.820
0.857
0.916
0.969
1.00
1.07
1.38
1.41
1.74
1.74
1.76
1.81
1.88
2.28
3.19
4.54
4.54
5.66
5.81
8.19
9.26
Controlled emissions. Ma/vr
Chlorinated
organics
0.00227
0
0.693
0
0
0
0
0
0
0.00408
0
0
0
0
0
0
0.00971
0
0
0
0
0.0459
0
0
0.0751
Unchlor-
inated
0.0594
0.679
0
0.0780
0.119
0.125
0.0272
0.141
0.0199
0.103
0.0276
0.141
0.0345
1.59
0.0351
0.0363
0.0279
0.0458
0.0642
0.0907
0.0907
3.25
0.938
0.164
5.32
HCI Other
0.0122
0
0
0
0
0
0
0
0
0.0209
0
(d)
0
0.157
0
0
9.43E-06
0
0
0
0
0.0131
0
0
0.0214
(a) Total
0 0.0739
0 0.679
0 0.693
0 0.0780
0 0.119
0 0.125
0 0.0272
0 0.141
0 0.0199
0 0.127
0 0.0276
0 0.141
0 0.0345
0 1.74
0 0.0351
0 0.0363
0 0.0376
0 0.0458
0 0.0642
0 0.0907
0 0.0907
0 3.31
0 0.938
0 0.164
0 5.42
-------
TABLE 2. SUMMARY OF PROCESS VENT EMISSIONS (continued)
Plant Process
no. (a) no.
3 11
7 18
8 23
17 82
12 37
11 28
6 16
13 42
1 3
8 20
22 78
21 68
22 83
12 38
10 27
7 17
19 64
11 30
3 6
5 15
22 82
23 93
11 29
22 79
11 33
At/
IN B/C
IN B
Al C
Al C
Al C
Al B
Al B/C
Al B
Al B/C
Al C
Al B
Al B
Al B
Al B
(b) B
IN C
IN B
Al B
Al B/C
Al C
Al B
Al B
Al B
Al B/C
IN B
IN C
Process
operating
hr/vr
8,160
5,300
7,896
2,424
1,368
1,272
4,404
8,760
720
2,088
1,036
4,056
1,946
1,170
7,680
6,072
6,318
3,072
8,136
6,039
8,760
4,150
3,792
432
7,176
Chlorinated
organics
0
0.181
0
0
0
0
0
0
0.158
0.0454
0
0
22.7
0
31.3
0
0
0
50.9
42.8
45.4
40.1
0
8.30
60.3
Uncontrolled
Unchlor-
inated
0.403
12.6
0
15.3
4.59
16.1
16.5
18.9
19.3
15.2
23.8
28.5
6.27
24.3
0
33.0
34.3
48.3
0
9.05
12.2
18.6
59.5
0
4.41
emissions,
HCI (b)
9.00
0
14.5
0
11.0
0
0
0
0.0904
6.80
0
0
0
0.000136
0
0
0
0
0
0
0
0.557
0
54.4
0.761
Mg/yr
Other (c)
0
0
0
0
0
0
0
0
0
0
0
0
0
7.71
1.39
0
0
0
0
0
0
0
0
0
0
Total
9.41
12.8
14.5
15.3
15.6
16.1
16.5
18.9
19.5
22.1
23.8
28.5
28.9
32.0
32.7
33.0
34.3
48.3
50.9
51.9
57.5
59.2
59.5
62.8
65.5
Controlled emissions. Mg/yr
Chlorinated
organics
0
0.181
'0
0
0
0
0
0
0.158
0.00454
0
0
0.454
0
23.0
0
0
0
2.03
42.8
0.907
7.65
0
0.166
1.21
Unchlor-
inated
0.00806
12.6
0
2.91
0.0918
5.33
1.65
0.668
11.2
1.52
0.475
4.14
0.125
0.504
0
0.660
0.171
16.0
0
9.05
0.242
5.90
19.7
0
4.04
HCI Other la) Total
0.0900
0
1.21
0
0.110
0
0
0
0.0452
0.680
0
0
0
1.36E-06 0
0.000907
0
0
0
0
0
0
0.0146
0
0.567
0.00761
0 0.0981
0 12.8
0 1.21
0 2.91
0 0.202
0 5.33
0 1.65
0 0.668
0 11.4
0 2.21
0 0.475
0 4.14
0 0.579
.00857 0.512
0.274 23.3
0 0.660
0 0.171
0 16.0
0 2.03
0 51.9
0 1.15
0 13.8
0 19.7
0 0.733
0 5.25
-------
TABLE 2. SUMMARY OF PROCESS VENT EMISSIONS (continued)
Plant Process
no. (a) no.
22 85
12 40
20 66
11 31
22 84
23 94
11 32
23 91
1 1
21 67
9 25
17 63
8 19
12 39
9 24
22 75
22 86
22 74
Al/
IN B/C
Al B
Al B
Al B
Al B/C
Al B
Al B
Al B/C
IN C
Al C
Al B
i
Al C
Al C
Al C
Al C
Al B
Al B
IN B
Al C
Process
operating
hr/yr
1,542
1,568
840
7,104
2,496
4,370
7,176
7,488
5,040
8,400
3,384
8.064
7,896
7,000
5.568
4,500
(d)
5,184
Chlorinated
organics
0
32.8
0
40.7
0
26.5
103
4.02
1.11
0
18.2
0
0.0431
199
0
53.1
1,730
347
Uncontrolled
Unchlor-
inated
66.7
15.4
81.8
51.5
96.3
38.5
7.52
0
135
129
0
200
202
0
0
0
0
0
emissions.
HCI (b)
0
26.7
0
0
0.101
33.1
1.30
117
0.633
12.0
174
0
13.2
67.2
356
349
535
2,360
Mg/yr
Other (c)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
*
Total
66.7
74.9
81.8
92.2
96.4
98.1
112
121
137
141
192
200
215
266
356
402
2,260
2,710
Controlled emissions. Mo/vr
Chlorinated
organics
0
0.919
0
18.2
0
3.35
2.05
1.38
1.11
0
0.364
0
0.0431
5.93
0
1.06
34.5
6.94
Unchlor-
inated
1.33
2.19
0.810
21.8
1.93
11.8
6.87
0
78.7
63.5
0
5.22
12.9
0
0
0
0
0
HCI Other (a)
0
0.0667
0
0
0.101
0.357
0.0130
1.17
0.317
2.36
0.174
0
1.32
1.03
0.356
3.66
267
23.7
Total
0 1.33
0 3.18
0 0.810
0 40.0
0 2.03
0 15.5
0 8.94
0 2.55
0 80.1
0 65.9
0 0.538
0 5.22
0 14.3
0 6.96
0 0.356
0 4.72
0 302
0 30.6
(a) This table shows processes 1 through 58 and processes 60 through 94; process 59 was omitted after the initial analysis.
(b) This column includes both HCI and chlorine.
(c) Others include hydrazine. hydrogen cyanide, and maleic anhydnde.
(d) No data provided.
-------
14
TABLES. SUMMARY OF EQUIPMENT COMPONENT COUNTS
Process
number (a)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
Batch or
continuous
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
C
c
C
c
c
c
c
c
c
c
c
Flanges
0
44
44
100
192
252
372
506
593
810
812
914
1,098
1.140
1.453
2.839
2.979
3.528
3.528
0
0
980
1.284
1.500
1.500
1,500
1.500
2.591
2,604
2,740
Pumps
0
0
0
1
0
3
6
7
11
2
4
14
5
1
20
44
33
53
53
13
128
7
4
33
33
33
33
28
22
27
Number
Valves
8
8
161
206
362
443
952
956
1.300
1.300
538
4.735
1.108
of components
Gas
valves
0
6
50
61
4
11
76
43
126
19
35
278
278
278
278
260
251
Liquid
valves
32
20
323
75
218
231
154
278
294
392
508
954
954
954
954
1.330
1.004
Sampling
connections
11
4
0
3
16
2
6
9
12
22
53
0
0
0
12
Others
16
22
2
5
10
4
3
17
264
6
0
0
0
81
(a) These process numbers are for convenience; they do not correspond with the process numbers
in Table 2.
-------
15
TABLE 4. LIST OP HAP COMPOUNDS IN STORAGE TANKS
HAP
Ace tool trile
Aniline
Carbon tetnchloride
ChloRMCetic icid
Cyanides
Cyanohydrin
Cyanuric chloride
Dimethyl hydnzine
Ethyl benzene
Ethylene dichloride
Ethylene glycol
Formaldehyde
Glycol ethers
Unspecified
Butyl Cellosolve
Hexachlorobenzene
Hexachloroethane
Hexane
HC1
Hydrazine
Maleic anhydride
Methanol
Methyl ethyl ketone
Methylene chloride
Methyl isobutyl ketone
Phosphorus
Tetrachloroethylene
Toluene
Trichlorobenzene
Trichloroethylene
Triethylamine
Xylene
No. of
tanks*
1
2
4
1
1
2
2
1
2
4
3
3
2
2
2
2
18
2
2
14
1
2
1
2
5
23
4
1
1
10
TOTAL
Uncontrolled
emissions, kg/yr
62.2
0.653
2.720
0.000
0.721
0.000
356
1.23
4,590
0.163
228
2.000
1.72
0.000
0.082
381
—
42.8
67.9
4,370
269
582
45.6
—
418
37.600
169
752
0.531
2,210
56,900
Controlled
emissions,
kg/yr
62.2
0.653
54.1
0.000
0.014
0.000
356
0.025
91.7
0.163
223
40.1
1.72
0.000
0.002
348
—
42.8
12.7
3.020
269
533
5.02
_
8.37
2.060
169
752
0.531
969
9,020
PCI cent
reduction,
*
0
0
98
—
98
0
98
98
0
2
98
0
—
98
8
„-
0
81
31
0
9
89
__
98
95
0.1
0
0
56
84
"The number of tanks shown
compound.
in this column will not sum to 102; some tanks contain more than one HAP
-------
16
TABLE 5. DISTRIBUTION OF STORAGE TANKS BY
AND HAP VAPOR PRESSURE
CAPACITY
Tank capacity, gallons
< 7,000
£7,000, < 10,000
2:10,000, <20,000
£20,000, 00,000
£30,000, < 40,000
£40,000
Sum of tanks
Percentage of total
HAP vapor pressure, psia
<0.1
1
3
3
3
3
4
18
22%
£0.1 to
<0.5
3
2
4
2
5
6
22
27%
£0.5 to
<0.75
1
2
9
0
2
3
17
21%
£0.75 to
>1.9
0
0
4
2
2
4
12
15%
£1.9
1
1
7
1
1
3
14
17%
Sum of
tanks
6
8
27
8
13
20
82
100%
Percentage
of total
7.3%
9.8%
33%
9.8%
16%
24%
100%
TABLE b. DISTRIBUTION OF STORAGE TANKS BY CAPACITY
AND UNCONTROLLED HAP EMISSIONS
Tank capacity, gallons
< 7,000
£7,000, < 10,000
£10,000, < 20,000
£20,000. < 30,000
£30,000, < 40,000
£40,000
Sum of tanks
Percentage of total
Uncontrolled HAP emissions, Ib
<1
1
3
1
2
0
0
7
8.5%
>=1 to
<250
3
4
11
3
7
4
32
39%
£250 to
< 1,000
1
1
10
1
4
4
21
26%
£1,000 to
< 7,000
1
0
5
2
2
7
17
21%
£7,000
0
0
0
0
0
5
• 5
6.1%
Sum of
tanks
6
8
27
8
13
20
82
100%
Percentage
of total
7.3%
9.8%
33%
9.8%
16%
24%
100%
-------
17
TABLE 7. AVERAGE PARAMETERS FOR ORGANIC STORAGE TANKS
Parameter
Tank size, gallons
Throughput , gal 1 ons
Vapor pressure, psia
Minimum
Maximum
Average
Minimum
Maximum
Average
Minimum
Maximum
Average
2,500
1,567,000
76,360
600
64,000,000
3,796,000
0.00
7.92
0.92
TABLE 8. CONTROL DEVICES USED FOR STORAGE TANKS
Control device
Carbon adsorber
Scrubber
Water
Caustic
Combustion (Incinerator,
BIF Boiler, RCRA
Incinerator, Thermal
Oxidizer)
Flare
Condenser
Closed vent system
Compound controlled
Organic
Organic
HC1
HC1
Organic
Chlorinated organic
Organic
Organic
Chlorinated organic
HC1
Range of
control , %
95-98
90-99.5
90-99
96
98
98
98
13-89
4
None
provided
-------
TABLE 9. UNCONTROLLED AND CONTROLLED ORGANIC HAP EMISSIONS FROM STORAGE TANKS PER PLANT
PLANT
1
3
5
7
8
10
11
12
13
14
15
17
20
21
22
23
TOTAL
NO. ORGANIC
TANKS
5
5
3
1
9
5
10
13
1
5
3
1
6
8
2
5
82
UNCONTROLLED
ORGANIC
EMISSIONS, KG/YR
33,100
87.0
2,000
55.5
973
3,140
6,930
1,830
269
1,160
83.2
0.0091
473
4,360
636
1,740
56.900
CONTROLLED '
ORGANIC
EMISSIONS. KG/YR
1,660
10.7
40.1
0.277
943
62.7
1,870
1,120
269
23.3
83.2
0.0091
473
731
12.7
1,740
9.020
•
PERCENT
REDUCTION
95%
88%
98%
99.5%
3%
98%
73%
39%
0%
98%
0%
0%
0%
83%
98%
0%
84%
-------
19
TABLE 10 UNCONTROLLED AND CONTROLLED EMISSIONS FROM STORAGE TANKS
ffiPlan
|,
1
1
1
1
3
3
3
3
3
5
5
5
7
8
8
8
8
8
8
8
8
8
10
10
10
10
10
11
11
11
11
11
11
11
11
11
11
12
12
12
12
12
12
12
12
12
12
12
12
TanK
Size,
gal
6,000
500,000
500.000
500,000
500,000
2,500
14.000
7,500
10,000
22,000
66,000
66,000
66,000
14,500
220.000
35,000
100.000
500,000
27,000
7.000
7,000
7,000
10,000
5.200
15,750
15.750
8.400
33.000
12.690
30.000
7.900
6.540
13.500
13.500
1,567,000
144.000
27.000
30,600
40,000
32.000
84.000
40,000
10.500
7,000
10.300
10,300
10,300
30.000
20,000
7,500
Throughput.
gal
60.000
56.000.000
56,000,000
64,000.000
64,000,000
9,600
119,000
38,000
81,000
262.940
176,440
176.440
176,440
350,000
4,840,000
175.000
500.000
1,000,000
40.300
77.000
77.000
224,000
3.670
348.700
324.900
324.900
537.700
179.200
2.120.260
455.000
175.000
52.980
322.530
755.800
5,342,000
2,890,000
3,140.000
815.000
31.000
79.000
68.000
56,000
33,000
11.000
75.000
213.000
111,000
31.200
33.800
7,800
vapor uncontrolled control controlled
pressure, emissions, efficiency emissions.
psia kg/yr Control device (a) % kg/yr
0.5494
0.5494
0.5494
0.3469
0.3469
0.0002
0.0052
2.4155
2.4155
0.0139
1.5235
1.5235
1.5235
0.1812
0.0082
0.4855
2.4155
0.0082
0.2267
0.0006
0.0006
0.0006
0.4329
0.3499
1.8742
1.8742
0.5381
1.4285
0.5254
0.1284
0.373
7.9181
0.5302
2.2488
0.2233
1.4824
1.4824
0.0715
0.5494
0.5494
0.2686
0.0565
2.4155
0.058
0.5494
0.5494
0.456
0.0082
2.9292
0.7432
45.1
11.500
11.500
5.020
5,020
0.000
0.535
31.8
52.9
1.72
669
669
669
55.5
98.2
32.2
692
67.3
49.7
0.0363
0.0363
0.0816
34.4
121
1,050
1.050
283
631
231
43.8
45.6
554
118
260
1.090
3.220
1.360
7.05
127
116
108
16.6
76.8
0.376
63.9
124
65.6
3.40
348
32.8
CA
CA
CA
CA
CA
NONE
NONE
SC
SC
NONE
SC
SC
SC
SC
SEAL POTS
SEAL POTS
SEAL POTS
SEAL POTS
SEAL POTS
SEAL POTS
SEAL POTS
SEAL POTS
SC
INC
INC
INC
INC
INC
CONDENSER
SC-ACID/SC-CAUSTIC/INC
CONDENSER
CONDENSER
CONDENSER
CONDENSER
CONDENSER
INC
INC
THERMAL OXIDIZER
BIF BOILER
BIF BOILER
BIF BOILER
BIF BOILER
BIF BOILER
BIF BOILER
BIF BOILER
BIF BOILER
BIF BOILER
NONE
NONE
RCRA INC
95.00
95.00
95.00
95.00
95.00
0.00
0.00
90.00
90.00
0.00
9800
98.00
98.00
99.50
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
90.00
98.00
98.00
98.00
9800
98.00
13.20
98.00
89.00
4.00
41.00
42.00
2500
98.00
98.00
98.00
98.00
98.00
98.00
98.00
98.00
98.00
98.00
98.00
98.00
0.00
0.00
98.00
2.25
576
576
251
251
0.000
0.535
3.18
5.29
1.72
13.4
13.4
13.4
0.278
98.2
322
692
67.3
49.7
00363
0.0363
0.0816
3.44
243
21.0
210
5.67
12.6
201
0.877
502
532
69.5
151
816
64.5
27.3
0.141
2.55
2.32
2.15
0.331
1.54
0.0075
1.28
2.48
1.31
3.40
348
0.656
-------
20
TABLE 10. UNCONTROLLED AND CONTROLLED EMISSIONS FROM STORAGE TANKS
Plan
12
13
14
14
14
14
14
15
15
15
17
20
20
20
20
20
20
21
21
21
21
21
21
21
21
22
22
23
23
23
23
23
TOTAL
rank
Size,
gal
20,000
17,500
47,000
32.000
47,000
30,000
32,000
5,313
6,423
12,847
17.780
25,800
30.000
16,000
12,000
14.000
12,387
15.000
15,000
30,000
15,000
15,000
15,000
15,000
15,000
31,600
102,000
20,000
20.000
75,000
30,000
50,000
Vapor
Throughput, pressure,
aal
369,000
160,000
620,800
747.310
1,226.040
91,823
308,147
146.160
146,160
146,160
600
119,742
464.997
177,681
13,330
12.540
7,120
213.950
19.914
2.250.000
490.000
10,800.000
3,640,000
1,810,000
14.700.000
68.478
288.954
20,540
20.540
816,334
1,375.248
3,069.544
psia
1.3353
1.7443
0.2267
0.2267
0.2267
2.4155
0.2267
0.2267
0.2267
0.2267
0.0002
0.1562
0.1562
0.0186
3.033
3.033
1.7824
2.4155
0.5494
1.195
2.4155
0.5494
0.5494
0.5494
0.5494
0.5494
2.4155
0.013
0.013
2.4155
0.0042
0.0433
uncontrolled
emissions,
ko/yr
752
269
223
242
394
186
118
25.0
25.6
32.5
9.07E-03
12.7
30.0
12.4
164
192
62.2
212
50.0
575
394
1,000
483
350
1,290
112
524
0.327
0.327
1,360
4.08
372
56,900
Control device (a)
NONE
NONE
FLARE
FLARE
FLARE
FLARE
FLARE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
FLARE
NONE
CA
CA
CA
CA
THERMAL OXIDIZER
THERMAL OXIDIZER
NONE
NONE
NONE
NONE
NONE
control
Controlled
efficiency emissions,
%
0.00
0.00
98.00
98.00
98.00
98.00
98.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
9800
0.00
98.00
98.00
98.00
98.00
98.00
98.00
0.00
0.00
0.00
0.00
0.00
Ka/yr
752
269
4.46
4.85
7.89
3.72
2.36
25.0
25.6
32.5
9.07E-03
12.7
30.0
12.4
164
192
62.2
212
50.0
11.5
394
20.1
9.67
7.00
25.8
2.24
10.5
0.327
0.327
1.360
4.08
372
9,020
(a)SC = Scrubber
CA = Carbon adsorber
INC = Incinerator
-------
21
TABLE 11.
LIST OF HAP COMPOUNDS IN WASTEWATER STREAMS AT
SURVEYED PLANTS
HAP
Acetonitrile
Benzene
Carbon disulfide
Carbon tetrachloride
Chloroacetic acidb
Chloroform
Cyanides
Unspecified12
Hydrogen cyanide"
Bthylene di chloride
EChylene glycolb
Formal dehydeb
Glycol ethers
Unspecified
Bthylene glvcol mono
butyl ether6
HClb
Hexachlorobenzene
Hexane
Methanol
Methyl chloroform
Methyl ethyl ketone
Methyl ieobutyl ketone
Methylene chloride
N,N-Diraethylaniline
Naphthalene
Phenolb
Tetrachloroethylene
Toluene
Trichlorobenzene
Xylene
No. of plants
2
2
1
1
1
2
1
1
1
2
2
1
1
7
1
1
8
1
1
2
2
1
1
1
1
6
2
5
NO. Of
processes
2
2
1
1
1
3
1
1
2
5
4
1
1
9
1
1
16
1
1
4
2
1
1
1
1
21
2
9
TOTAL
HAP
load,
ug/yr
73.7
15.3
0.907
0.113
108
2.24
19.5
a
760
4.77
59.2
6.78
1.53
622
0.0050
0.0356
1,950
0.0009
51.3
152
205
34.1
0.0043
0.0004
0.0680
88.7
7.39
20.0
3.370
Uncontrolled
HAP
emissions,
Mg/yr
26.5
12.3
0.835
0.107
1.7S
486
2.17
0.0032
0.0356
331
0.0008
24.6
80.6
158
11.6
0.0022
0.0626
71.0
4.73
16.0
1,230
Tne surveyed plant indicated that the load was "trace."
"These compounds are not Table 9 compounds in the HON and are not
likely to volatilize from the wastewater streams.
-------
22
TABLE 12. INDIVIDUAL WASTEWATER STREAMS FROM PROCESSES
Plant
11
11
' 11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
12
12
12
12
19
19
19
19
21
21
21
21
21
21
21
Process
13
13
13
13
14
14
14
14
15
15
15
15
16
16
16
16
16
16
17
17
18
18
22
22
22
22
35
35
35
35
37
37
37
37
37
37
37
Wastewater
stream
number
WW001
WW001
WW002
WW002
WW001
WW001
WW002
WW002
WW001
WW001
WW002
WW002
WW001
WW001
WW001
WW002
WW002
WW002
WW001
WW002
WW001
WW002
WW001
WW002
WW003
WW004
WW001
WW002
WW003
WW004
WW003
WW004
WW005
WW006
WW008
WW009
WW009
HAP
load,
Mg/yr
18.0
2.54
1.38
0.195
66.4
9.36
5.09
0.718
54.0
7.61
4.14
0.584
728
161
11.6
195
43.3
3.12
479
1.56
281
0.916
0.00694
0.327
00635
0.399
1.02
2.54
15.3
15.3
0.774
5.15
0.000295
0
145
81.6
0.00229
Flow rate,
gal/yr Fe
908,700 0.53
908,700 0.80
70,200 0.53
70,200 0.80
3,355,200 0.53
3,355,200 0.80
259,200 0.53
259.200 0.80
2,726,100 0.53
2,726,100 0.80
210,600 0.53
210,600 0.80
4,400,000 0.17
4,400,000 0.77
4,400,000 0.80
1,200,000 0.17
1,200,000 0.77
1,200,000 0.80
5.040,000 0.64
1.260.000 0.79
2.960.000 0.64
740,000 0.79
3,600 0.80
159,000 0.80
33,000 0.80
208.000 0.80
675.500 0.34
1.680,000 0.34
10,060,000 0.34
10,080,000 0.34
1,512,000 0.17
4,536,000 0.17
85,909 0.17
1,008.000 0.17
2,520,000 0.17
1,260,000 0.17
1,260,000 0.80
HAP emissions. Mo/vr
Uncontrolled
9.53
2.03
0.731
0.156
35.2
7.49
2.70
0.575
28.6
6.09
2.19
0.467
124
124
9.30
33.2
33.4
2.50
306
1.25
180
0.733
0.00555
0.261
0.0508
0.319
0.348
0.864
5.19
5.19
0.132
0.875
0.000050
0
24.6
13.9
0.00183
Controlled
0.0953
0.0203
0.00731
0.00156
0.352
0.0749
0.0270
0.00575
0.286
0.0609
0.0219
0.00467
1.24
1.24
0.0930
0.332
0.334
0.0250
3.06
0.0125
1.80
0.00733
0.00555
0.261
0.0508
0.319
0.348
0.864
5.19
5.19
0.132
0.875
0.000050
0
24.60
13.88
0.00183
-------
23
TABLE 12. INDIVIDUAL WASTEWATER STREAMS FROM PROCESSES (continued)
Plant
21
21
' 21
21
21
21
21
21
21
21
21
21
21
21
21
21
21
21
Wastewater
stream
Process number
37
37
37
37
37
37
37
37
37
37
37
36
38
38
38
38
38
38
WW011
WW011
WW012
WW013
WW013
WW014
WW014
WW015
WW015
WW018
WW019
VWV001
WW001
WW002
WW002
WW003
WW003
WW004
HAP
load,
Mg/yr
97.3
11.3
0.0264
0.237
0.00513
0.0854
0.0582
143
6.28
0.405
0.215
87.5
3.32
0.125
0.0544
0.0431
0.136
0.00590
Flow rate,
gal/yr Fe
14,408.000 0.17
14,408.000 0.80
800 0.17
10,500 0.17
10,500 0.80
3,500 0.17
3,500 0.80
22.166,000 0.17
22,166
140
,000 0.80
,000 0 17
157,500 0.17
5,250,000 0.17
5,250,000 0.80
30,100 0.17
30
.100 0.80
145,950 0.17
145.950 0.80
504,000 0.80
HAP emissions. Mg/yr
Uncontrolled
16.5
9.00
0.00448
0.0403
0.00410
0.0145
0.0465
24.3
5.02
0.0688
0.0366
14.9
2.66
0.0212
0.0435
0.00733
0.109
0.00472
Controlled
16.5
9.00
0.00448
0.0403
0.00410
0.0145
0.0465
24.3
5.02
0.0688
0.0366
14.9
2.66
0.0212
0.0435
0.00733
0.109
0.00472
-------
24
TABLE 13. SUMMARY OF WASTEWATER STREAMS
Plant
1
" 1
1
1
3
3
3
5
7
8 (a)
8 (a)
8 (a)
10
10
10
11
11
11
11
11
11
11
11
11
11
11
11
11
Process
1
2
3
4
5
6
7
8
9
10
10
10
11
11
12
13
13
14
14
15
15
16
16
16
17
17
18
18
Number of
streams
per process
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
HAP
load,
Mg/yr
6.17
0.925
0.386
0.231
2.06
0.173
1.23
6.78
0.907
6.89
2.22
213
0.113
0.0680
0.00499
19.4
2.73
10.1
71.5
8.19
58.1
14.7
924
205
1.56
479
0.916
281
Flow rate,
gal/yr Fe
200,000,000 0.80
30,000,000 0.80
12,500.000 0.80
7,500,000 0.80
27,600,000 0.78
411,000 0.17
11,600 0.17
73,417,000 0.32
13,500,000 0.92
130,000,000 0.64
130,000,000 0.80
130,000,000 0.17
2,630,000 0.94
2,630.000 0.92
36,981.000 0.64
978.900 0.53
978,900 0.80
3.614.400 0.80
3.614.400 0.53
2,936,700 0.80
2,936,700 0.53
5,600,000 0.80
5.600.000 0.17
5,600,000 0.77
6.300,000 0.80
6,300,000 0.79
3.700.000 0.80
3,700,000 0.79
HAP emissions,
Mg/yr
Uncontrolled Controlled
4.94
0.740
0.308
0.185
1.61
0.0294
0.209
2.17
0.835
0.00
0.00
0.00
0.107
0.0626
0.00319
10.3
2.18
8.06
37.9
6.55
30.8
11.8
157
158
1.25
306
0.733
180
4.94
0.740
0.308
0.185
1.61
0.0294
0.209
2.17
0.835
0.00
0.00
0.00
0.00533
0.00313
0.00319
0.103
0.0218
0.0806
0.379
0.0655
0.308
0.118
1.57
1.58
0.0125
3.06
0.00733
1.80
-------
25
TABLE 13. SUMMARY OF WASTEWATER STREAMS (CONTINUED)
Plant
11
11
11
11
11
11
12
12
12
13
13
14
15
15
15
15
15
17
17
17
17
17
17
17
17
17
17
19
20 (a)
Process
19
19
20
20
21
21
22
23
24
25
26
27
28
29
30
31
32
33
33
34
34
34
34
34
34
34
34
35
36
Number of
streams
per process
1
1
1
1
1
1
4
1
1
1
1
1
1
1
1
1
1
1
1
4
1
HAP
load,
Mg/yr
7.08
13.4
3.08
5.86
7.98
15.2
0.796
1.81
0.499
3.18
51.3
136
0.0508
0.349
0.192
0.385
10.7
0.247
0.179
0.0356
3.47
0.000122
0.000862
0.00430
0.000980
4.31
73.6
34.1
0.0408
Flow rate,
gal/yr Fe
4,173,000 0.80
4,173,000 0.17
1,819,000 0.80
1,819,000 0.17
4,708,000 0.80
4,708.000 0.17
403,600 0.80
47,000 0.17
132,000 0.64
7.000,000 0.17
4.000,000 0.48
120,000 0.80
1.824 0.80
5,625 0.80
1,028 080
2,056 0.80
1,857.100 0.80
4,026.000 0.77
4.026.000 0.78
24,918.000 1.00
24,918,000 0.53
24,918,000 0.78
24,918,000 0.91
24,918,000 0.51
24,918,000 0.80
24,918,000 0.17
24,918,000 0.36
22,516,000 0.34
220 0.36
HAP emissions, Mg/yr
Uncontrolled
5.66
2.29
2.47
0.996
6.39
2.58
0.637
0.308
0.319
0.540
24.6
10.9
0.0406
0.279
0.154
0308
857
0.190
0.140
0.0356
1.84
0.000096
0.000784
0.00219
0.000784
0.732
26.5
11.6
0.00
Controlled
0.0566
0.0229
0.0247
0.0100
0.0639
0.0258
0.637
0.308
0.319
0.393
24.6
10.9
0.0406
0.279
0.154
0.308
8.57
0.190
0.140
0.0356
1.84
0.000096
0.000784
0.00219
0.000784
0.732
26.5
11.6
0.00
-------
26
TABLE 13. SUMMARY OF WASTEWATER STREAMS (CONTINUED)
Plant
21
21
21
21
22
22
22
22
22
22
22
22
22
22
22
Process
37
37
38
38
39
40
41
42
42
43
43
43
44
44
45
Number of
streams
per process
13
5
3
4
1
1
1
1
1
1
1
1
1
1
1
HAP
load,
Mg/yr
474
17.6
87.7
3.52
0.0318
0.658
0.627
140
2.81
•D.691
0.691
34.5
29.4
4.61
0.395
HAP emissions, Mg/yr
Flow rate,
gal/yr
47,808.000
47,808,000
5,930.100
5,930.100
222.070
777.600
705,600
3,513.600
3,513.600
'• 885.600
885.600
885.600
695.670
695.670
933.120
Fe
0.17
0.80
0.17
0.80
0.80
0.80
0.80
0.17
0.80
0.80
0.80
0.17
0.17
0.80
0.80
Uncontrolled
80.5
14.1
14.9
2.81
0.0254
0.527
0.502
23.8
2.24
0.553
0.553
5.87
5.00
3.69
0.316
Controlled
80.5
14.1
14.9
2.81
0.0254
0.527
0.502
23.8
2.24
0.553
0.553
5.87
5.00
3.69
0.316
(a) Wastewater streams are disposed of by deepwell injection; there are no HAP emissions
from these streams.
-------
TABLE 14.
27
LIST OF PARTICULATE MATTER HAP COMPOUNDS FROM
BAG DUMPS AND PRODUCT DRYERS3
HAP
Cap tan
Maleic anhydride
TOTAL
No. of plants
1
1
Emission point
product dryer
bag dump*
Uncontrolled
CO11 801 Oltff
Mg/yr
844
1.66
846
Controlled
emissions.
Mg/yr
8.44
0.00181
8.4S
Percent
reduction.
%
99
99.9
99
•HAP emitted from 2 of the 20 plants.
VI. References
j.. Memorandum from K. Schmidtke, MRI, to L. Banker, EPA/ESD.
November 11, 1996. Documentation of Data Base Containing
Information from Section 114 Responses and Site Visits for
the Production of Pesticide Active Ingredients NESHAP.
z.. Memorandum from D. Randall and K. Schmidtke, MRI, to
L. Banker, EPA/ESD. December 16, 1996. Recommended Control
Levels for the Process Vent, Storage Tank, and Wastewater
Planks of the New Source MACT Floor--Production of Pesticide
Active Ingredient NESHAP.
3. 40 CFR Part 63, subpart H, section 63.161.
4. Memorandum from D. Randall, K. Schmidtke, and C. Hale, MRI,
to L. Banker, EPA/ESD. April 30, 1997. Baseline Emissions
for the Pesticide Active Ingredient Production Industry.
5. Memorandum from K. Schmidtke, MRI, to L. Banker, EPA:BSD.
April 30, 1997. Storage Tank Data and Results of Storage
Tank Emission Calculations Using TANKS3 Software--Pesticide
Active Ingredient Production Industry.
-------
MIDWEST RESEARCH INSTTTUT,
Suite 35C
401 Harrison Oaks Boulevard
Gary. North Carolina 27513-2412
Telephone (919) 677-0249
FAX (919) 677-0065
Date: April 30, 1997
Subject: MACT Floor and Regulatory Alternatives for the
Pesticide Active Ingredient Production Industry
EPA Contract 68D60012; Task Order No. 0004
BSD Project No. 93/59; MRI Project No. 4800-04
From: David D. Randall
Karen L. Schmidtke
To: Lalit Banker
ESD/OCG (MD-13)
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
I. Introduction
The purpose of this memorandum is to present the maximum
achievable control technology (MACT) floor and regulatory
alternatives for existing and new sources in the pesticide active
ingredient (PAD production industry. The Clean Air Act
Amendments of 1990 (CAA) require that standards for sources of
hazardous air pollutant (HAP) emissions reflect the maximum
degree of reduction in HAP emissions that is achievable. This
control level is referred to as MACT. The CAA also provides
requirements for determining the least stringent level allowed
for a MACT standard; this level is termed the "MACT floor." In
addition, the CAA requires examination of alternatives more
stringent than the floor. However, the CAA specifies that
evaluation of regulatory alternatives that are more stringent
than the floor consider the cost of achieving the emission
reduction, any nonair quality health and environmental impacts,
and energy requirements.
The MACT floors and regulatory alternatives for the PAI
source category have been developed to reduce HAP from five types
of emission points including: process vents, equipment leaks,
storage vessels, wastewater systems, and bag dumps and product
dryers. Each type of emission point constitutes a "plank" in the
MACT floor for the source category.
The remainder of this memorandum is divided into three
sections. Section II describes the approach used to determine
the MACT floor and regulatory alternatives for existing sources.
Section III describes the MACT floor and regulatory alternatives
for new sources. Section IV lists the references.
-------
II. Existing Source MACT Floor and Regulatory Alternatives
A. Overview for Existing Sources
1. Clean Air Act Requirements for Existing Sources.
Section 112(d)(3) of the CAA specifies that standards for
existing sources shall be no less stringent than "the average
emission limitation achieved by the best performing 12 percent of
the existing sources" for source categories and subcategories
.with 30 or more sources, or "the average emission limitation
:achieved by the best performing 5 sources" for source categories
-or subcategories with fewer than 30 sources.
The EPA has evaluated two interpretations of the MACT floor
for existing sources. Under the first interpretation, EPA would
look at the average emission limits achieved by each of the best
performing 12 percent of existing sources, and the lowest would
be used to represent the MACT floor. The second interpretation
is that the MACT floor is represented by the "average emission
limitation achieved" by the best performing sources, where the
"average" is based on a measure of the central tendency, such as
.the arithmetic mean, median, or mode. This latter interpretation
is referred to as the "higher floor interpretation." In a
June 6, 1994, Federal Register notice (59 PR 29196), the EPA
presented its interpretation of the statutory language concerning
the MACT floor for existing sources. Based on a review of the
statute, legislative history, and public comments, the EPA
believes that the "higher floor interpretation" is a better
reading of the statutory language. In this memorandum, the
determination of the MACT floor for existing sources follows the
"higher floor interpretation."
2. Determination of the Best Performing Facilities for
Existing Source MACT. Because there are an estimated 78 affected
facilities nationwide in the PAI source category, the MACT floor
is based on the best performing 12 percent of facilities. With
an estimated 78 affected facilities, the best performing
12 percent consists of nine facilities.
Identification of the best performing 12 percent was
accomplished by conducting a screening telephone survey followed
by sending a detailed written information request to selected
companies.2 The screening telephone survey was conducted to
identify several facilities that achieve high emissions
reductions. The survey was also designed to identify plants that
each produce a variety of PAI's, use a variety of production
processes, and are major sources. Companies with multiple plants
that met the criteria were favored over those with only one
plant. A detailed information request was then sent to nine
companies, and these companies provided data for a total of
20 plants. Because plants with good emission controls were
targeted to receive the information request, EPA believes that
-------
the surveyed plants include the nine plants that are the best
performing 12 percent.
The best-performing nine plants were determined based on
the total percentage reduction in HAP emissions from the affected
source for each of the 20 surveyed facilities. For the PAI
production source category, the affected source is the collection
of all process equipment and waste management units involved in
the production of PAI's at the plant. Emission points from this
process equipment and waste management units include process
vents, equipment leaks, storage tanks, wastewater, and bag dumps
and product dryers. The HAP emitted from these five planks
include unchlorinated and chlorinated organic HAP, hydrochloric
acid (HC1) and chlorine, and particulate matter (PM) HAP. The
20 plants are ranked in Table 1 according to their total
percentage reduction in these HAP emissions.
Table 1 shows plant 16 has an overall control efficiency of
99.9 percent. The only HAP emissions from this plant consist of
PM HAP generated from a raw material bag dump. This is not
considered to be typical of sources in this source category. As
a result, this plant was not included among the best performing
12 percent of sources. The best-performing nine facilities
include Plants 9, 22, 7, 17, 6, 12, 11, 20, and 8 (listed in
descending order of plantwide emission reduction achieved).
3. Approach for the MACT Floors and Regulatory
Alternatives for Existing Sources. After the nine best-
performing sources in the source category were identified, the
"average emission limitation achieved" was determined for each of
the five planks at these plants. The average emission limitation
was determined using the second interpretation, or the higher
floor determination, discussed in section II.A.I above. The
arithmetic mean was evaluated first. When the arithmetic mean
was at a level that corresponded with the control achieved by a
known technology, it was selected as the MACT floor. When the
arithmetic mean did not correspond with the control achieved by a
known technology, the median was selected as the MACT floor.
The next step was to determine regulatory alternatives more
stringent than the MACT floor. Potential regulatory alternatives
were developed based on the Hazardous Organic NESHAP (HON) and
the Alternative Control Techniques Document for Control of
Volatile Organic Compound Emissions from Batch Processes (Batch
Processes ACT).4'5 The HON was selected because (1) the
characteristics of the emissions from storage tanks, equipment
leaks, and wastewater systems in the PAI production industry are
similar or identical to those addressed by the HON and (2) the
levels of control required under the HON were already determined
through extensive analyses to be reasonable from a cost and
impact perspective.
-------
TABLE 1. OVERALL CONTROL EFFICIENCY OF HAP EMISSIONS FROM PAI PLANTS2
Plant
16b
9
7
22
6
17
12
11
20
8
15
10
23
19
1
21
3
13
14
5
Uncontrolled HAP emissions, Mg/yr
Process
vents*
1.66
549
,_ 890
5,720
16.5
224
388
394
82.1
253
2.87
32.7
282
34.3
171
178
61.9
18.9
9.96
52.8
Equipment
leaks
0
14.2
57.7
136
0.56
128
80.4
242
22.7
69.0
107
90.6
126
11.3
56.8
79.4
137
22.7
56.7
48.1
Storage
tanks
0
0
0.06
0.64
0
0
1.83
6.93
0.47
0.97
0.08
3.14
1.74
0
33.1
4.36
0.09*
0.27
1.16
2.0
Wastewater
0
0.03 .
0.835
43.1
0
29.4
1.26
931
0.0147
42.5
9.35
0.173
d
11.6
6.17
112
1.84
25.1
10.9
2.17
Controlled HAP emissions, Mg/yr
Process
vents*
0.002
0.540
21.9
343
1.65
8.30
10.8
95.1
1.04
17.8
2.84
23.3
31.8
0.17
100
71.4
2.96
0.67
0.20
51.9
Equipment
leaks
0
10.7
57.7
136
0.56
12.6
80.4
242
22.7
69.0
25.1
21.6
126
11.3
39.5
79.4
13*
22.7
56.7
47.8
Storage tanks
0
0
0
0.01
0
0
1.12
1.87
0.47
0.94
0.08
0.006
1.74
0
1.66
0.73
0.01
0.27
0.02
0.04
Wastewater
0
0.03
0.835
43.1
0
29.4
1.26
9.31
OF
0°
9.35
0.0117
d
11.6
6.17
112
1.84
24.7
10.9
2.17
Overall
control
efficiency,
%
99.9
98.0
91.5
91.2
87.0
86.8
80.2
77.9
77.0
76.0
68.7
64.6
61.1
59.7
44.8
29.5
29.4
27.8
13.9
3.0
fParticulate matter HAP emissions from bag dumps and product dryers are included in this category.
''This plant is not considered to be typical of the industry and, thus, is not included in (he best performing 12 percent.
cThis plant disposes of wastewater using deepwell injection.
"No data provided.
-------
The Batch Processes ACT document was selected to identify
regulatory alternatives for batch process vents; batch processes
are not addressed by the HON. The Batch Processes ACT document
covers VOC emissions, and most of the HAP emitted from PAI
production facilities are also VOC. Unlike the HON, the Batch
Processes ACT document is not a regulation and, therefore, does
not specify a level of control that must be met. Instead, the
Batch Processes ACT document provides information on potential
levels of control and their costs. Using procedures in the Batch
Processes ACT document, the EPA developed a regulatory
alternative that requires 98 percent reduction of gaseous organic
HAP emissions from "large" process vents. This level of control
was selected because it was determined to be achievable,
considering costs and other impacts, for process vents that meet
certain flow and HAP load characteristics.
Under the CAA, EPA can distinguish among classes, types,
and sizes of sources within a source category in establishing
standards; one way to make distinctions is to establish
applicability cutoffs. The PAI source category is comprised of
many different production processes. Variability in the
characteristics of these processes may affect the emission rates.
To address this variability, a MACT floor and regulatory
alternatives were developed that consist of applicability cutoffs
as well as control efficiencies for the emission points that
exceed the cutoffs. In this analysis, the cutoffs were based on
uncontrolled emission rates.
B. MACT Floor and Regulatory Alternatives for Existing
Sources
1. Process Vents. The MACT floor for process vents could
be determined on a plant basis or on a process basis. In this
analysis, the MACT floor was determined on a process basis to
maintain consistency with the Batch Processes ACT document. In
addition, because many processes have a dedicated control (or
controls), application on a process basis would be easier to
implement, monitor, and demonstrate compliance. A process-based
MACT flgor would also be consistent with the pollution prevention
option.6
The MACT floor for process vents was developed from data on
•all 41 processes at the nine MACT floor plants. Uncontrolled and
controlled emissions and the corresponding control efficiencies
for each process are shown in Table 2. The HAP emissions were
grouped into two categories for analysis: (1) organic HAP and
(2) HC1 and chlorine. The HC1 emissions include both HC1 from
the process and HC1 that was generated by burning chlorinated
organic HAP in combustion-based control devices; HC1 from the
process was reported by the plants in responses to the
information requests, and HC1 generated by combustion in control
devices was estimated assuming all of the chlorine in the
chlorinated organics that are burned is converted to HC1.7
-------
TABLE 2. SUMMARY OF PROCESS VENT EMISSIONS
a,2
Plant Proceu
No. No.
6 16
7 17
7 11
I 19
1 20
t 22
I 23
9 24
9 25
11 28
11 29
11 30
11 31
II 32
11 33
11 34 n
11 35
11 36
12 37
12 38
12 39
12 40
17 60
17 61
17 62
17 63
20 65
20 66
22 74
22 75
22 76
22 77
22 78
22 79
22 80
22 81
22 82
22 83
22 84
22 85
22 86
UDeontrolM tmurioiu, Mg/yr
Oiganici HCIb
16.5 0
33.0 0
12.8 0
202 13.2
15.3 6.80
1.41 e
0 14.5
0 356
18.2 191
16.1 0
59.5 0
48J 0
92.2 19.8
110 77.0
64.7 45.3
OJ54, . .«. .0.
0.154 0
0.399 0
4.59 11.0
24.3 0.000
199 212
48.2 50.4
0.337 0.29
8.19 0
15.3 0
200 0
0146 0
81.8 0
347 2.393
53.1 355
434 0
4.54 0
23.8 0
8.30 55.3
1.81 0
1.38 0
57.5 1.67
28.9 0.84
96.3 0.101
66.7 0
1.730 598
Controlled rauinont. Mg/yr
OifuiiM HClb
1.65 0
0.660 0
12.8 0
13.0 1.32
1.53 0.680
0.141 c
0 121
0 OJ56
0.364 0.191
5.33 0
19.7 0
16.0 0
40.0 0.198
8.92 0.770
5.24 0.453
0.0071
-------
Thirty-nine of the processes had organic HAP emissions and 20 had
HC1 and chlorine emissions. Additional details about the data
are presented in the Data Summary memorandum.
In responses to the information request, several facilities
reported control efficiencies for thermal oxidation control
devices of 99 percent or more. These reported control
efficiencies were based on the results of trial burns for
compliance with RCRA regulations or were based on the results of
emissions tests when burning either liquid waste alone or both
liquid waste and process vent emissions. No data are available
on the control level when burning only process vent emissions.
However, based on numerous incinerator emission tests, it is
reasonable to assume that the control level is at least
98 percent.9 Therefore, reported control levels above 98 percent
were changed to 98 percent for use in the MACT floor analysis.
As noted above, the MACT floor consists of both an
applicability cutoff and a control efficiency requirement for
processes that exceed the cutoff. Separate cutoffs were
determined for each of the three categories of HAP emissions from
/process vents. These cutoffs were determined by first ranking
the processes by uncontrolled emission rates in each category and
then examining the list for an appropriate cutoff. The 39
processes at the nine MACT floor plants with organic HAP
emissions are listed in Table 3. For the organic HAP emissions,
process 65 had the lowest uncontrolled emissions, and this
process was uncontrolled. Process 35 had the second lowest
uncontrolled emissions (0.154 Mg/yr), and it was controlled. A
cutoff of 0.15 Mg/yr (330 Ib/yr) was selected because this is the
highest point below which the arithmetic mean control efficiency
.is no control; for higher cutoffs, the arithmetic mean control
efficiency for processes below the cutoff would be at least
49 percent. For the 38 processes with uncontrolled emissions
above the 0.15 Mg/yr (330 Ib/yr) cutoff, the arithmetic mean
control efficiency was 90 percent. Because this efficiency can
be achieved by various control devices, it was selected as the
MACT floor control level. Therefore, the MACT floor for organic
HAP emissions from process vents consists of a control efficiency
of 90 percent for processes with uncontrolled emissions greater
than or equal to 0.15 Mg/yr (330 Ib/yr).
All 20 processes at the MACT floor plants with HC1 and
chlorine emissions are ranked in Table 4 according to
uncontrolled emissions. Processes 38, 60, 82, 83, and 84 have
the lowest uncontrolled HC1 and chlorine emissions, and each is
uncontrolled. All of the other 15 processes with HC1 and
chlorine emissions are controlled. A cutoff was established at
uncontrolled emissions of 6.80 Mg/yr (7.5 tons/yr), which is
equal to the lowest uncontrolled emissions from a controlled
process (process 20). This value was selected because it is the
highest value below which the arithmetic mean control efficiency
is no control; for higher cutoffs, the arithmetic mean control
-------
8
TABLE 3. SUMMARY OF ORGANIC EMISSIONS FROM PROCESS VENTS*
Rut Process
No. No.
22 86
22 74
8 19
17 63
12 39
11 32
22 84
11 31
20 66
22 85
11 33
11 29
22 82
22 75
11 30
12 40
7 17
22 83
12 38
22 78
9 25
6 16
11 28
8 20
17 62
7 18
22 79
17 61
12 37
22 76
22 77
22 80
8 22
22 81
11 36
11 34
17 60
11 35
20 65
UoOOttvOUDu COBMODftfl
Mi/yr
1,730
347
202
200
199
110
96.3
9Z2
81.8
66.7
64.7
593
57.5
53.1
48.3
48.2
33.0
28.9
24.3
23.8
18.2
163
16.1
15.3
15.3
12.8
8.30
8.19
439
434
434
1.81
1.41
1.38
0399
0-354
0.337
0.154
0.146
Controlled emisBions,
Mg/yr
343
6.94
13.0
5.22
5.93
8.92
1.93
40.0
0.807
133
5.24
19.7
1.15
1.06
16.0
3.11
0.660
' 0379
0304
0.475
0364
1.65
533
133
2.91
12.8
0.166
0.164
0.0918
0.0907
0.0907
0.0363
0.141
0.0276
0.0080
0.0071
0.0067
0.0031
0.146
Control cfficiBocicSt %
98.0
98.0
93.6
97.4
97.0
91.9
98.0
56.6
99.0
98.0
91.9
66.9
98.0
98.0
66.9
933
98.0
98.0
97.9
98.0
98.0
90.0
66.9
90.0
81.0
0.0
98.0
98.0
98.0
98.0
98.0
98.8
90.0
98.0
98.0
98.0
98.0
98.0
0.0
Avenge8 90.2
•include* all
controlled e
at the nine MACT floor plants with organic HAP emissions. Some of the
ssions and control efficiencies woe dunged for reasons thai «e described in the
Recommended Control Levels for New Souree MACT Floor memorandu
:nc i
38
with IB
HAP
HAP
is based on the efficiencies for the
man0.15Mg/yr.
-------
TABLE 4. SUMMARY OF HC1 AND CHLORINE EMISSIONS
• FROM PROCESS VBNTSa'b
FUm Process
No. No.
22 74
22 86
9 24
22 75
12 39
9 25
11 32
22 79
\.i 40
11 33
11 31
8 23
8 19
12 37
8 20
22 82
22 83
17 60
22 84
12 38
Mg/yr
2J90
598
356
355
212
191
77.0
55J
50.4
45.3
19.8
14.5
13.2
11.0
6.80
1.67
0.84
0.29
0.101
0.000
Mg/yr
57.8
331
0.356
8.75
2.48
0.191
0.770
1.38
0.304
0.453
0.198
1.21
1.32
0.110
0.680
1.67
0.84
0.29
0.101
0.000
Control efficiencies, %
97.6
44.7
99.9
97J
99.8
99.9
99.0
97.5
99.4
99.0
99.0
91.7
90.0
99.0
90.0
0.0
0.0
0.0
0.0
00
Avenge6 93.5
"Includes all processes atjbe nine MACT floor plants with HCI emissions. Some of the controlled
changed for n
emissions and control efficiencies were
.Control Levels for New Source MACT Floor
randum.
are described in the Recommended
HCI emissions include HC1 and chlorine from the process and HC1 created by burning chlorinated
organics in a combustion-based control device, M*"ffir*t all of the chlorine in the chlorinated organic is
converted to HCI.'
°The avenge HCI control efficiency is based on the efficiencies for the 15 processes with uncontrolled
HCI gqni««?«w greater man 6.80 Mg/yr.
-------
10
efficiency for processes below the cutoff would be at least
18 percent. Above the 6.80 Mg/yr (7.5 tons/yr) cutoff, the
arithmetic mean control efficiency is.94 percent. Because this
level can be achieved by control technologies, it was selected as
the MACT floor control level. Therefore, the MACT floor for HC1
and chlorine emissions from process vents consists of a control
efficiency of 94 percent for processes with uncontrolled
emissions greater than or equal to 6.80 Mg/yr (7.5 tons/yr).
Two regulatory alternatives beyond (i.e., more stringent
4than) the floor were developed. Regulatory Alternative 1 would
•require 98 percent control of organic HAP emissions from vents
•that meet certain flow and uncontrolled HAP mass loading criteria
•and that currently are not controlled to the MACT floor level of
90 percent. For all other process vents, Regulatory Alternative
1 would be equivalent to the MACT floor. Specifically, a 90
.percent reduction in organic HAP emissions would be required from
the combination of all vents within a process, excluding vents
that meet the requirements for 98 percent control. In additon, a
94 percent reduction in-, combined HC1 and chlorine emissions would
be required from the combination of all vents within a process.
tRegulatory Alternative 2 would require 98 percent control of
jorganic HAP and 99 percent control of combined HC1 and chlorine
.emissions on a process basis. The applicability cutoffs for the
MACT floor would apply under both regulatory alternatives (i.e.,
process-based uncontrolled emissions sO.15 Mg/yr (330 Ib/yr) for
organic HAP emissions and 26.8 Mg/yr (7.5 tons/yr) for combined
HC1 and chlorine emissions).
A process vent would meet the criteria for 98 percent
control of organic HAP emissions under Regulatory Alternative l
if (1) the current annual organic HAP control is less than 90
percent and (2) the actual total flow rate from the vent is less
than the flow rate calculated using the following equation:
*
FR = 0.02 * HL 1,000
where:
FR = calculated flowrate, scfm
HL * actual HAP emission load from the vent, Ib/yr
This equation was developed using a method nearly identical
to the approach described in the Batch Processes ACT.4 Using
this method, a series of curves was developed that approximates
boundaries of cost effective control for a range of emission
stream characteristics (i.e., flow rate and operating hours) and
types of control devices (i.e., thermal incinerators and
condensers) for a given annual HAP load. Similar series of
curves were generated for several additional annual HAP loads.
From each series of graphs, the average flow rate corresponding
to an optimum cost effectiveness of $3,500/Mg was determined.
These flow rates were then plotted versus the corresponding
annual HAP load, and a simple linear regression analysis was used
-------
11
to define a line through the points; this line represents the
limits of cost effective control to 98 percent. The cost
•effectiveness target of $3,500/Mg was selected based on decisions
in previously promulgated part 63 rules where this value was
judged to be reasonable.
The difference between the method used in this analysis and
that in the Batch Processes ACT involved the number of pollutants
that were evaluated. In the analysis for Regulatory Alternative
1, the annual HAP load was represented only with methanol,
whereas the Batch Processes ACT used several pollutants, each
with different volatilities. Methanol was used in this analysis
because it is one of the most common HAP in process vent
emissions at PAI manufacturing plants; it also has a moderate
volatility, which means the resulting cost effectiveness should
represent the average cost effectiveness for the range of actual
HAP emissions. Additional details about the methodology and the
resulting curves for this analysis are provided in a separate
memorandum.10
2. Storage Tanks. Storage tank emissions are a function
of many factors, including the size of the tank, the vapor
pressure, throughputs, and molecular weight of the stored
material. Therefore, the methodology used to develop the storage
tank plank of the MACT floor focused on the characteristics of
individual tanks at the MACT floor plants rather than the plant
wide control efficiency for storage tanks at these plants. The
characteristics for tanks at the MACT floor facilities are shown
in Table 5.
The MACT floor for storage tanks is based on 42 tanks at
.the nine MACT floor plants. The MACT floor for storage tanks
consists of two applicability cutoffs and a control efficiency
requirement for tanks that exceed the cutoffs. To determine the
cutoff, the tanks were first ranked according to their
uncontrolled emissions, as shown in Table 5. The list in Table b
shows a majority of the tanks with low uncontrolled emissions
were not controlled. Working up from the bottom of the list, the
median control efficiency is 0 percent for all tanks with
uncontrolled emissions below any cutoff up to 0.11 Mg/yr
(240 Ib/yr). Above a cutoff of 0.11 Mg/yr (240 Ib/yr) the median
control efficiency is 41 percent. Thus the first cutoff was
determined to be uncontrolled emissions *0.ll Mg/yr (240 Ib/yr).
A second cutoff was established based on the capacity of
the tank. In the group of tanks with uncontrolled emissions
%0.ll Mg/yr (240 Ib/yr), the smallest tank had a capacity of
6,540 gal. The two next smallest tanks have capacities of about
10,000 gal, and both are controlled to 98 percent. A capacity
cutoff of 38 m3 (10,000 gal) was selected because this is the
smallest tank in the group of tanks with uncontrolled emissions
fcO.ll Mg/yr (240 Ib/yr) that is controlled to the median control
efficiency of 41 percent. Therefore, the MACT floor for storage
-------
12
TABLE 5. STORAGE TANK CHARACTERISTICS AT MACT FLOOR PLANTS2
Tank
number
1
2
3
4
5
6
7
1
9
10
11
12
13
14
15
16
17
11
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
FUnt
mimbtr
11
11
11
12
I
11
22
12
11
11
20
20
12
12
11
12
22
12
1
12
8
12
12
20
7
8
11
11
12
8
8
20
12
20
20
11
12
12
8
8
8
17
HAP
ETHYLENE DICHLORIDE
ETHYLENE DICHLORIDE
XYLENE
TRICHLOROETHYLENE
METHANOL
METHYLENE CHLORIDE
METHANOL
HEXANE
METHANOL
TOLUENE
DIMETHYL HYDRAZINE
DIMETHYL HYDRAZINE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
MDC-TOLUENE/CYANOHYDRIN
TRICHLOROBENZENE
METHANOL
TRICHLOROBENZENE
MDC-TOLUENE/METHYLENE
CHLORIDE
TOLUENE
ACETONmULE
MALEIC ANHYDRIDE
XYLENE
METHYL ISOBUTYL KETONE
TOLUENE
MDC-HEXANE/TRICHLOROBENZENE
TOLUENE
METHANOL
HYDRAZINE HYDRATE
MDC-ETHYL BENZENE/XYLENE
HYDRAZINE HYDRATE
MALEIC ANHYDRIDE
MDt-FORMALDEHYDE/METHANOL
TRICHLOROBENZENE
FORMALDEHYDE
ETHYLENE OLYCOL
ETHYLENE OLYCOL
ETHYLENE OLYCOL
ETHYLENE OLYCOL
Taaknz*.
1*1
144,000
27.000
1.567,000
20,000
100.000
6.540
102.000
20,000
13,500
12.690
14.000
12,000
40.000
10,300
13.500
32.000
31.600
84.000
220.000
10.500
500,000
10.300
10.300
12.378
14.500
27.000
7.900
30.000
7,500
10.000
35.000
30.000
40.000
25.600
16,000
30.600
30.000
7.000
7.000
7.000
7,000
17,760
UncomrolW
•minions,
If/yr
3.220
1.360
1,090
752
692
554
525
348
260
231
192
164
127
124
118
116
*•• 112
108
98.2
76.8
67.3
65.6
63.9
62.2
55.5
49.7
45.6
43.8
32.8
34.4
32.2
300
16.0
' 12.7
12.4
7.05
340
0.38
0.08
0.04
0.04
0.01
Control
tml,
»•
98
98
25
0
0
4
98
0
42
133
0
0
98
98
41
98
98
98
0
98
0
98
98
0
99.5
0
89
98
98
90
0
0
98
0
0
98
0
98
0
0
0
0
CoonoUwi
•__•
VXIIHBIOO*!
fe/yr
64.5
27.3
816
752
692
532
10.5
348
151
201
192
164
2.52
2.48
69.5
2.32
2.24
2.15
98.2
1.54
67.3
1.31
1.28
62.2
0.28
49.7
5.02
0.88
0.66
3.44
322
300
0.33
12.7
12.4
0.14
3.40
0.01
0.08
0.04
0.04
0.01
'Plants reported control efficiencies of 99.99 percent for several tanks that are controlled with thermal
oxidizen and other combustion-based control devices. These values were changed to 98 percent for
reasons that are described in a memorandum in the Recommended Control Level for New Source MACT
Floor memorandum.
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13
tanks was determined to be 41 percent control for storage tanks
with uncontrolled emissions *0.11 Mg/yr (240 Ib/yr) and
capacities *38 m3 (10,000 gal).
One regulatory alternative more stringent than the MACT
floor was also developed for storage tanks. This alternative
would require 95 percent control of storage tanks with capacities
greater than or equal to 76 m3 (20,000 gal) that have
uncontrolled emissions that are greater than or equal to
0.11 Mg/yr (240 Ib/yr); tanks with smaller capacities that meet
the uncontrolled emissions cutoff for the MACT floor would be
required to control to the level of the MACT floor. Floating
roof technology has been demonstrated to achieve 95 percent
control and is considerably less expensive than other
technologies, even technologies that achieve control levels of
less than 95 percent; therefore, it is the preferred method of
control for tanks with capacities of greater than 76 m3
(20,000 gal). Regulatory alternative 1 takes advantage of this
fact for tanks that can be equipped with floating roof technology
and merely requires the level of control that has been
demonstrated to be cost effective and technically feasible to
achieve. Regulatory alternative 1 also requires no additional
control of any tank that is currently equipped with a control
device achieving at least 41 percent control. This provision was
included in the regulatory alternative because the cost
associated with the incremental reduction achieved by increasing
control from 41 percent to 95 percent is not reasonable. 1
3. Equipment leaks. The MACT floor for equipment leaks
was determined to be no control. This determination was based on
all equipment leak data provided by the nine MACT floor plants
and on the modelled equipment counts for those plants that did
not provide data.2'12 The arithmetic mean of control
efficiencies in Table 6 is 13 percent, and the median is
0 percent. The arithmetic mean does not represent the
performance of any known regulatory program for equipment leaks.
Therefore, the median (i.e., no control) was determined to be the
MACT floor.
One regulatory alternative more stringent than the floor
was developed. This alternative is the implementation of all of
the requirements in subpart H of 40 CFR part 63, except that it
does not cover receivers and surge control vessels. Receivers
and surge control vessels are process vessels that typically
operate in batch mode. They also have vents like other types of
process vessels. Therefore, it is more appropriate to regulate
•emissions from these vessels as process vent emissions rather
than equipment leak emissions.
4. Wastewater. The MACT floor for wastewater systems was
determined to be no control of HAP evaporative losses from
wastewater collection and treatment systems. The MACT floor
determination for wastewater is based on all wastewater data
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14
TABLE 6. CONTROL EFFICIENCIES FOR
EQUIPMENT LEAKS. AT MACT FLOOR PLANTS2
Plant
6
7
8
9
11
12
17
20
22
Control efficiency,
percent
0.0
0.0
0.0
24.6
0.0
0.0
90.0
0.0
0.0
TABLE 7. CONTROL EFFICIENCIES FOR .
WASTEWATER SYSTEMS AT MACT FLOOR PLANTS'
Plant
6
7
8
9
11
12
17
20
22
Control efficiency,
percent
0.0
0.0
a
0.0
99. Ob
0.0
0.0
a
0.0
aThis plant disposes of wastewater
using deepwell injection.
"Control based on incineration of
all wastewater.
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15
provided by the nine MACT floor plants.2 The plantwide emissions
reduction for wastewater was determined at each plant. Table 7
presents the plantwide wastewater control efficiencies being
achieved at the MACT floor plants. Only one of these plants
treats wastewater with a technology that controls emissions.
Based on the data in Table 7, the arithmetic mean and median of
the wastewater system control efficiencies for the MACT floor
plants are 14 and 0 percent, respectively. The arithmetic mean
excludes plants 8 and 20, which use deep-well injection to
dispose of wastewater. Because this disposal method is not
available to all sources, it was not included in the MACT floor
analysis. It is, however, a technology that can be used to meet
the proposed control requirements. Because the arithmetic mean
efficiency does not correspond with the control efficiency of any
control technology, the median (i.e., no control) was determined
to be the MACT floor.
One regulatory alternative more stringent than the floor
was developed for wastewater. This alternative would be to
implement the requirements in the HON (i.e., §§ 63.131 through
63.149 of subpart G of part 63). This alternative specifies
.certain design and emission control requirements for waste
management units and a variety of control options for wastewater
treatment units.
For this alternative, Group 1 wastewater streams containing
Table 9 HAP compounds would be controlled. Table 9 is in 40 CPR
part 63, subpart G. A Group 1 stream is defined as those streams
with the total annual average concentration of Table 9 compounds:
(1) that is greater than or equal to 10,000 ppmw at any flow
rate, or (2) that is greater than or equal to 1,000 ppmw and the
.annual average flow rate is greater than or equal to 10 L/min
(2.6 gal/min). The regulatory alternative would require Group 1
wastewater streams for Table 9 compounds to do one of the
following: (1) reduce the concentration of Table 9 compounds to
less than 50 ppmw; (2) use a steam stripper with specific design
and operating requirements; (3) reduce the mass flow rate of
Table 9 compounds by at least 99 percent; (4) reduce the mass
flow rate of Table 9 compounds by an amount equal to or greater
than the Fr value in Table 9; (5) for a source using biotreatment
for at least one wastewater stream that is Group 1 for Table 9
compounds, to achieve a required mass removal greater than or
equal to 95 percent for Table 9 compounds; or (6) treat
wastewater streams with permitted RCRA units or by discharging to
a permitted underground injection well.
Unlike the HON, this regulatory alternative applies to
maintenance wastewater as well as process wastewater.
Maintenance wastewater was excluded under the HON because it is
generated in batches, whereas the process wastewater is generated
continuously. However, in the PAI production industry, batch
processes with batch discharges are common. Thus, the same
procedures used to determine process streams that are subject to
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16
control would be used to determine maintenance streams that are
subject to control.
5. Bao dumps and product dryera. Only one of the MACT
floor plants emits PM HAP from bag dumps or product dryers. The
PM HAP emissions at this plant are from a product dryer that is
controlled with a fabric filter. This fabric filter controls PM
HAP emissions to a concentration below 22.9 milligrams per dry
•standard cubic meter (mg/dscm) (0.01 grains per dry standard
cubic foot [gr/dscf]). This level is typical for fabric filter
:. controls and, thus, was selected as the MACT floor for PM HAP
^emissions from bag dumps and product dryers. No alternative more
•stringent than the MACT floor was developed because the MACT
floor was based on the best control at an existing plant, and the
level represents good control.
•XXI. New Source MACT Floor and Regulatory Alternatives
A. Overview
; 1. Clean Air Act Requirements for New Sources.
•Section 112 (d) (3) of the CAA specifies that standards for new
•sources in a source category or subcategory "shall not be less
stringent than the emission control that is achieved in practice
'by the best controlled similar source, as determined by the
Administrator."
2. Approach for the MACT Floors and Regulatory
Alternatives for New Sources. The MACT floor for new sources in
the PAX production industry represents a high level of control
that is at the limit of technical feasibility for four of the
five planks. Therefore, no options above the floor were
developed for process vents, storage tanks, equipment leaks, or
bag dumps and product dryers. Alternatives more stringent than
the MACT floor were developed only for wastewater systems. The
remainder of this section describes the five planks of the new
source MACT floor and the regulatory alternatives for wastewater.
B. MACT Floor and Regulatory Alternatives for New Sources
1. Process vents. The MACT floor for process vents at new
sources was determined on a process basis using data for the best
-.controlled processes at the best performing plants. Data for the
-best performing plants are shown in Table 2. The MACT floor for
new sources also consists of applicability cutoffs and control
efficiency requirements for the same two categories of HAP
emissions described above for existing sources: (1) organic HAP
and (2) HC1 and chlorine.
To determine the MACT floor for organic HAP emissions, the
processes in Table 2 were first ranked by their uncontrolled
organic HAP emissions. Process 35 is the controlled process with
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17
the lowest uncontrolled emissions (0.154 Mg/yr). This process is
controlled to 98 percent, and this level represents the best
control that is being .achieved. Therefore, the MACT floor
consists of 98 percent control for any process with uncontrolled
organic emissions greater than or equal to 0.15 Mg/yr
(330 Ib/yr).
In responses to the information collection request, a
facility reported scrubber control efficiencies of 99.99 percent
or higher for HC1. These reported control efficiencies were
based on design parameters of the scrubbers and were not based on
the results of an emissions test.8 Without specific test data to
demonstrate the control efficiency actually achieved by the
facility in the PAI production industry, control efficiencies
demonstrated for similar control devices in another industry were
evaluated. Test data for an application in another industry
demonstrated scrubber control efficiencies for HC1 of at least
99.9 percent.13 Therefore, higher reported control efficiencies
were changed to 99.9 percent, as shown in Table 2.
To determine the MACT floor for HC1 and chlorine emissions,
the processes in Table 2 were first ranked by their total
uncontrolled HC1 and chlorine emissions. Processes 24 and 25 are
both controlled to 99.9 percent. This level represents the best
control that is being achieved; therefore, the control efficiency
component of the MACT floor was determined to be 99.9 percent.
The other component of the floor is the applicability cutoff. To
determine the cutoff, EPA examined the uncontrolled HC1 and
chlorine emissions from processes 24 and 25. The lowest value is
the 191 Mg/yr (211 tons/yr) emissions from process 24.
Therefore, 191 Mg/yr (211 tons/yr) is the cutoff associated with
the 99.9 percent control level. The floor for new sources cannot
be less stringent than for existing sources. Therefore, the
floor consists of a 94 percent control level for processes with
uncontrolled HC1 and chlorine emissions greater than or equal to
6.80 Mg/yr (7.5 tons/yr) and less than 191 Mg/yr (211 tons/yr)
(i.e., the MACT floor level of control for existing sources).
2. Storage Tanks. The MACT floor for storage tank
emissions at new sources was based on the best performing tanks
at the nine MACT floor plants. To determine the MACT floor, all
of the storage tanks at the best performing plants were first
ranked according to their uncontrolled emissions; the tanks are
ranked in Table 5. The best level of control being achieved is
98 percent. Because the data show many tanks are controlled to
98 percent, the best performing individual tank from this group
was determined based on the applicability cutoffs of uncontrolled
emissions and tank capacity. In Table 5, tank 38 is the tank
with the lowest uncontrolled emissions that are controlled to
98 percent; these emissions are 0.45 kg/yr (1 Ib/yr). Tank 38
also has a capacity of 26 m3 (7,000 gal), which is the smallest
tank that is controlled to 98 percent. Thus, the new source MACT
floor was determined to be 98 percent control for any storage
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16
tank with uncontrolled emissions greater than or equal to
0.45Jcg/yr (1 Ib/yr) and a capacity greater than or equal to
26 mj (7,000 gal). (Tank number 25-is controlled.to
99.5 percent, but it is controlled with a scrubber. A scrubber
efficiency is related to the characteristics of the HAP being
controlled; although it may achieve a high control level for a
soluble compound, it would not achieve the same control level on
other compounds.)
3. Equipment leaks. The MACT floor for equipment leaks at
.new sources is based on the facility with the best controlled
.•equipment leak emissions. The MACT floor for equipment leak
.•emissions at new sources was determined to be the LDAR
requirements in subpart H of 40 CFR part 63. This floor is based
on the finding that two PAI production facilities are
implementing LDAR programs that are consistent with the subpart H
.requirements. No facility is controlling equipment leaks to a
level above that achieved with the subpart H requirements. '
4. Baa-dumps and product drvers. The best performing PAI
production source uses a fabric filter to control PM HAP
^missions from process vents on a product dryer. Based on
emissions test data, PM HAP emissions at this source do not
exceed 22.9 mg/dscm (0.01 gr/dscf). Thus, the MACT floor for PM
HAP emissions from dryer vents was determined to be 22.9 mg/dscm
(0.01 gr/dscf).
5. Wastewater systems. The new source MACT floor for
wastewater was determined to be 99 percent control of all
wastewater streams at plants that have a total HAP mass flow rate
(of Table 9 compounds in subpart G of part 63) of 2,100 Mg/yr
(2,300 tons/yr) or more in wastewater from all POD's. For all
other plants the floor was determined to be no control.
As shown In Table 7, one of the best performing facilities
incinerates all of its wastewater, two dispose of wastewater
using deepwell injection, and the others do not use treatment
technology that controls emissions. A facility using deepwell
injection cannot be considered a similar source because the
technology is not available to all sources. Therefore, the new
source MACT floor for wastewater is based on the practices of a
single facility that is burning all of its wastewater in RCRA
incinerators that burn a mixture of wastes. This facility is the
best performer due to the degree and extent to which it is
controlling wastewater streams containing HAP compounds that are
listed in Table 9. Wastewater streams from nine processes are
incinerated at this plant. Data for these streams are presented
in the Data Summary memorandum.2
The control level for the best performing source was
determined as follows. Based on trial burns, the plant reported
in its response to the information collection request that the
incinerators have control efficiencies of 99.99 percent on
-------
19
hazardous waste, but no wastewater-specific control efficiency
data are available. However, it is reasonable to assume, because
these are RCRA incinerators, that the control efficiency is at
least 99 percent, the same level achievable by steam stripping
for many compounds. Data are not available to conclude that the
incinerator is achieving a greater efficiency. Therefore, the
MACT floor control efficiency was determined to be 99 percent.
To determine the cutoff for the floor, the mass flow rate
of Table 9 compounds that are being incinerated at the best
performing facility was examined. Collectively, the wastewater
streams at the facility contain more than 2,100 Mg/yr
(2,300 tons/yr) of Table 9 compounds. Thus, 2,100 Mg/yr
(2,300 tons/yr) is the applicability cutoff associated with the
99 percent control level of the MACT floor.
Two regulatory alternatives more stringent than the floor
were developed. Both alternatives include the floor control
requirements for sources that have a total mass flow rate of
Table 9 compounds of 2,100 Mg/yr (2,300 tons/yr) or more, but
requirements for other sources differ. Regulatory alternative 1
would require new sources with mass flow rate below this cutoff
to implement the HON requirements for existing sources (i.e., the
requirements in §§ 63.131 through 63.149 of subpart G of part
63). This alternative would require owners and operators to
control Group 1 streams for Table 9 compounds. Regulatory
alternative 2 would require new sources below the mass flow rate
cutoff to implement the HON requirements for new sources (i.e.,
the same requirements as for existing sources except that Group 1
streams for Table 8 compounds also must be controlled).
Regulatory alternative 2 is more stringent than regulatory
alternative 1 because the applicability cutoffs for Group 1
streams are lower for Table 8 compounds than for Table 9
compounds. Both regulatory alternatives apply to maintenance
wastewater streams and process wastewater streams.
The requirements for sources with mass flow rates that
exceed the mass flow rate cutoff are more stringent than the HON
requirements for two reasons. First, these facilities would be
required to control all wastewater streams at the source, whereas
the HON only requires control of Group 1 streams. Second, these
facilities would be required to achieve 99 percent control for
each stream, whereas the HON requires control levels at least
equal to the Fr values, which, for many compounds, are less than
0.99. Additionally, as for sources that do not exceed the mass
flow rate cutoff, these requirements apply to maintenance
wastewater streams as well as process wastewater streams.
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20
IV. REFERENCES
1. Memorandum from K. Schxnidtke, MRI, to L. Banker, EPA: BSD.
November 27, 1996. Estimation of the Number of Affected
Sources in the Production of Pesticide Active Ingredient
Source Category.
2. Memorandum from D. Randall and K. Schmidtke, MRI, to
L. Banker, EPA:BSD. April 15, 1997. Summary of Data from
Responses to Information Collection Requests and Site Visits
for the Pesticide Active Ingredient Production Industry.
3. Memorandum from K. Schmidtke, MRI, to L. Banker, EPA:BSD.
November 11, 1996. Documentation of Data Base Containing
Information From Section 114 Information Responses and Site
Visits for the Production of Pesticide Active Ingredient
NESHAP.
4. U.S. Environmental Protection Agency. Control of Volatile
Organic Compound-Emissions from Batch Processes--Alternative
Control Techniques Information Document. EPA-453/R-94-020.
February 1994.
a. 40 CFR Part 63, subparts F, G, and H.
6. Memorandum from D. Randall, MRI, to L. Banker, EPA:ESD.
June 30, 1997. Basis for Pollution Prevention Factors for
the Pesticide Active Ingredient Production Industry.
7. Notes on estimating generated HC1 emissions from process
vents, prepared by K. Schmidtke, MRI. October 22, 1996.
8. Memorandum from D. Randall and K. Schmidtke, MRI, to,
L. Banker, EPA:BSD. December 16, 1996. Recommended Control
Levels for the Process Vent, Storage Tank, and Wastewater
Planks of the New Source MACT Floor.
9. Memorandum and attachments from Fanner, J., EPA:ESD, to
Ajax, B. et al. August 22, 1980. Thermal incinerators and
flares.
10. Memorandum from D. Randall, MRI, to L. Banker, EPA:BSD.
June 30, 1997. Basis for Applicability Cutoff Equation for
Process Vents under Regulatory Alternative No. 1 for the
Pesticide Active Ingredient Production Industry.
11. Memorandum from K. Schmidtke and D. Randall, MRI, to,
L. Banker, EPA:BSD. April 30, 1997. Cost Impacts of
Regulatory Alternatives for Production of Pesticide Active
Ingredients NESHAP.
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21
12. Memorandum from D. Randall and K. Schmidtke, MRI, to,
L. Banker, EPA:BSD. April 30, 1997. Model Plants for the
Pesticide Active Ingredients Production NESHAP.
13. Performance Evaluation of Full-Scale Hazardous Waste
Incinerators. Volume 2 Incinerator Performance Results and
Volume IV Appendices C through J. Midwest Research
Institute. November 1984.
-------
MIDWEST RESEARCH INSTITUT
Suit* 35,
401 Hamson Oaks Boulevarc
Gary. North Carolina 27513-2412
Telephone (919) 677-024S
FAX (919) 677-0065
Date: April 30, 1997
Subject: Storage Tank Data and Results of Storage Tank Emission
Calculations Using TANKS3 Software--Pesticide Active
Ingredient Production Industry
EPA Contract 68D60012; Task Order No. 0004
BSD Project No. 93/59; MRI Project No. 4800-04
From: Karen L. Schmidtke
To: Laiit Banker
ESD/OCG (MD-13)
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
The purpose of this memorandum is to describe the method
used to estimate hazardous air pollutant (HAP) emissions from
storage tanks for the pesticide active ingredient (PAD
production industry. Uncontrolled emissions from each HAP
storage tank were calculated using EPA's TANKS 3 program. This
program requires several parameters for calculating emissions,
including type of tank, tank dimensions, liquid height, location
of the tank, and composition of the tank components. Facilities
provided tank capacity, throughput, and tank composition in their
responses to information requests. A location contained within
the city/state data base in the TANKS3 program closest to the
facility was used. The following assumptions were made: (1) the
tank roof is shaped like a cone, (2) throughput is divided
equally among 12 months of the year, and (3) default values in
the TANKS3 program were used for roof and shell color, roof and
shell condition, roof slope, and pressure/vacuum vent settings.
Other assumptions relating to the dimensions of each storage tank
were also made. This information is contained in the
confidential addendum to this
Storage tank dimensions and annual throughputs for each
tank are presented in Attachment l. The emissions estimated by
the TANKS 3 program are provided in Attachment 2. The plant
identification number and the tank number are listed for each
tank. Facilities provided emission estimates for some storage
tanks in their responses and these tanks are identified in
Attachment l.
Some of the storage tanks identified by facilities in the
PAI industry are not shown in Attachment 1. These tanks were not
included because: (1) the composition of tanks components was
not provided, (2) the tanks were determined to be process tanks
-------
not storage tanks, (3) throughput was zero for 1994, or (4) the
tank contained hydrochloric acid.
REFERENCES
1. User's Guide to TANKS, Storage Tank Emissions Calculation
Software, Version 3.0. Emissions Inventory Branch, U.S.
Environmental Protection Agency. February 1996.
2. K. Schmidtke, MRI, to L. Banker, EPA:BSD. November 11, 1996
Documentation of Data Base Containing Information from
Section 114 Responses and Site Visits for the Pesticide
Active Ingredient Source Category.
Attachments
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Attachment 1
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STORAGE TANK PARAMETERS
SIZE-GAL THROUGHPUT. GAl
S1ZE.FT3 H SHELL FT DIAMETER. FT H LIQUID. FT
ST001
ST006
ST007
ST009
ST010
3 ST003
3 ST004
3 STOOS
3 ST006
3 ST007
5 ST001
5 ST002
5 ST003
7 ST001 PUM cmotc
8 ST001
8 ST002 BnaaungfrBliier
8 ST003
8 ST004
8 STOOS
8 ST006
8 ST007
8 ST008
8 ST017
10 ST001
10 ST002
10 ST003
10 ST004
10 STOOS
11 ST001
11 ST002
11 ST003
11 STOW
11 STOOS
11 ST006
11 ST007
11 STOOS
11 ST010
11 ST011
12 ST001
12 ST002
12 ST003
12 STOW
12 STOOS
12 ST006
12 ST007
12 ST008
12 ST009
12 ST010
12 ST011
12 ST012
12 ST013
13 ST001
14 ST001
14 ST002
14 STOOS
14 STOW
14 STOOS
15 ST002
16 ST003
15 STOW
17 STOOS
20 ST001
20 ST002
6.000
500.000
500.000
500.000
500.000
2.500
14.000
7.500
10.000
22,000
66.000
66,000
66,000
14.500
220,000
«, 35.000
100.000
500.000
27.000
7.000
7.000
7.000
10.000
5.200
15.750
15,750
8.400
33,000
12.690
30.000
7.900
6.540
13.500
13.500
1.567.000
144.000
27.000
30.600
40.000
32.000
84.000
40.000
10.500
7.000
10.300
10.300
10.300
30.000
20.000
7.500
20.000
17.500
47.000
32.000
47,000
30.000
32,000
5,313
6.423
12.847
17,760
25.600
30.000
60,000
56.000.000
56.000.000
64,000.000
64.000,000
9.800
119.000
38.000
81,000
262,940
176.440
176,440
176.440
27.000
4.840.000
Constant level
500,000
1.000.000
40.300
77.000
77.000
224,000
3.670
348.700
324.900
324.900
537.700
179.200
2,120.260
455.000
175.000
52.980
322.530
755.800
5.342.000
2.890.000
3.140.000
815.000
31.000
79.000
68.000
56.000
33.000
11.000
75.000
213.000
111.000
31.200
33.800
7.800
369.000
160.000
620,800
747.310
1.226.040
91.823
308.147
146.160
146.160
146.160
600
119.742
464.997
802.1380
66.8449198
66.8449198
66.8449198
66.844.9198
334.2246
1.871.6578
1.0026738
1.336.8964
2,941.1765
8.8235294
6.8235294
8.823.5294
1.938.5027
29.411.7647
4.6791444
13,3689840
66.844.9198
3.609.6257
935.8289
9358289
935.8289
1.3368984
6951872
2.105 6150
2.1056150
1.122.9947
4.411.7647
1.6965241
4.0106952
1.0561497
8743316
1.8W8128
1.8W8126
209.491 9786
19.251.3369
3.6096257
4.0909091
5.347 5936
4.278 0749
11.2299465
5.347 5936
1.403.7433
9358289
1.377.0053
1,3770053
1,3770053
4.0106952
2.6737968
1.0026738
2.673.7968
2.339 5722
6.2834225
4.2760749
6,2834225
4.0106952
4,278 0749
7102941
858 6898
1.7175134
2.3743316
3.422.4599
4,0106952
Z
M
H
s
§
g
Z
M
CO
CO
Cd
Z
M
CO
03
J
<
M
E-
Cd
Q
M
t-
o
u
-------
b 1 UKAGe TANK PARAMETERS
PLANT NUMBER SIZE-GAL THROUGHPUT. GAL
20 ST003 Pl»»it«mcaiculn>on
20 ST005
20 ST006
20 ST007
21 ST001
21 ST002
- 21 ST003
21 ST007
21 ST008
21 ST009
21 ST010
21 ST011
22 ST006
22 ST007
23 ST001 PlwttwncalcubtOM
23 ST002 Flint tin cafcutaBOM
23 ST003 Plant cm catoubMra
23 ST004 Ptanl cm oleuliMns
23 ST005 Ptant >m ateutotwn*
16.000
12.000
14.000
12.387
15.000
15.000
30.000
15.000
15.000
15.000
15.000
15.000
31.600
102.000
20.000
20,000
75.000
30.000
50.000
177.881
13.330
12,540
7,120
213.950
19.914
2.250.000
490.000
10.800.000
3.640.000
1.810,000
14.700.000
68.478
288.954
20.540
20.540
816.334
1.375.248
3.069.544
SIZE FT3 H SHELL. FT DIAMETER. FT H LIQUID. FT
2.139.0374
1.604.2781
1.871.6578
1.656.0160
2.005.3476
2,005.3476
4.010.6952
2,005.3476
2.005.3476
2.0053476
2.0053476
2.005.3476
4.2245989
13.636.3636
2.673.7968
2.673.7966
10.026.7380
4.010.6952
6.6844920
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Attachment 2
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TANKS PROGRAM 3.0
EMISSIONS REPORT
BRIEF FORMAT
07/18/97
PAGE 1
wvw»l Emissions Report
01.001 Vertical Fixed Roof
Total:
01.006
Total:
01.007
Total:
01.009
Total:
01.010
Components
Toluene
Vertical Fixed Roof
Components
Toluene
Vertical Fixed Roof
Components
Toluene
Vertical Fixed Roof
Components
TOLUENE/CYANURIC CHLORIDE
Toluene
CYAMUR1C CHLORIDE
Vertical Fixed Roof
Components
TOLUENE/CTANURIC CHLORIDE
Toluene
Emissions (Ibs.)
99.39
99.39
Emissions (Ibs.)
25396.12
25396.12
Emissions (Ibs.)
2S396.12
25396.12
Emissions (Ibs.)
277338.49
11058.72
266279.77
277338.49
Emissions (Ibs.)
277338.49
11058.72
-------
TANKS PROGRAM 3.0
EMISSIONS REPORT
BRIEF FORMAT
07/18/97
PAGE 2
CYANURIC CHLORIDE
Total:
03.003
Total:
03.004
Total:
03.005
Total:
03.006
Total:
03.007
Total:
OS.001
Vertical Fixed Roof
CcHponentt
CHLOROACET1C ACID/WATER/ETHYL
CHLOROACETIC ACID
WATER
ETHYL CHLOROACETATE
Ethyl alcohol
Vertical Fixed Roof
Components
BUTYL CELLOSOLVE/ETHVL ALC/UAT
BUTYL CELLOSOLVE
Ethyl alcohol
WATER
TRIETHVLAN1NE
Vertical Fixed Roof
Components
Methyl alcohol
Vertical Fixed Roof
Components
Methyl alcohol
Vertical Fixed Roof
Components
BUTYL CELLOSOLVE
266279.77
277338.49
Emissions (Ibs.)
2.24
0.00
1.75
O.OS
0.43
2.24
Emissions (Ibs.)
78.50
0.01
73.35
3.97
1.17
78.50
Emissions (Ibs.)
70.17
70.17
Emissions (Ibs.)
116.71
116.71
Emissions (Ibs.)
3.79
3.79
Vertical Fixed Roof
-------
Component*
Emissions (Ibs.)
CLYCOL ETHERS
Total:
05.002 Vertical Fixed Roof
CONJJOf MintS
Total:
08.005
Total:
08.006
GLYCOl ETHERS
Total:
05.003 Vertical Fixed Roof
Components
GLYCOL ETHERS
Total:
08.001 Vertical Fixed Roof
Components
Total:
08.003 Vertical Fixed Roof
Total:
08.004
TRICHLOROBENZENE (1,2,4-)
Methyl alcohol
Vertical Fixed Roof
Cofflpofitfnts
TRICHLOROBENZENE (1,2,4-)
Vertical Fixed Roof
Components
Xylene (-m)
Vertical Fixed Roof
Components
ETHVLENE GIVCOL/WATER
1474.33
1474.33
Emissions (Ibs.)
1474.33
1474.33
Emissions (Ibs.)
1474.33
1474.33
Emissions (Ibs.)
216.46
216.46
Emissions (Ibs.)
1524.82
1524.82
Emissions (Ibs.)
148.30
148.30
Emissions (Ibs.)
109.47
109.47
Emissions (Ibs.)
14.04
-------
ETHYLENE OLVCOL 0 ofl
-------
TANKS PROGRAM 3.0
EMISSIONS REPORT - SUMMARY FORMAT
INDIVIDUAL TANK EMISSION TOTALS
PAGE 3
Annual Emissions Report / t3f
Liquid Contents
METHANOL/WATER
Methyl alcohol
WATER
Losses (Ibs.):
Standing
100.22
r'70.94 ,
' 29.28''
Working
76.11
53.87
22.24
Total
176.33
124.81
51.52
Total:
100.22
76.11
176.33
-------
TANKS PROGRAM 3.0 . 07/18/97
EMISSIONS REPORT PAGE 3
BRIEF FORMAT
WATER 13.97
Total: 14.04
08.007 Vertical Fixed Roof
Components Emissions (Ibs.)
ETHVLENE CLYCOL/WATER 14.04
ETHVLENE GLYCOL O.OB
WATER 13.97
Total: 14.04
08.008 Vertical Fixed Roof
Components Emissions (Ibs.)
ETHYLENE GLYCOL/WATER 28.72
ETHVLENE CLVCOL 0.18
WATER 28.54
Total: 28.72
08.017 Vertical Fixed Roof
Components Emissions (Ibs.)
Toluene 75.88
Total: 75.88
10.001 Vertical Fixed Roof
Coponents Emissions (Ibs.)
Tetrachloroethytene 267.46
Total: 267.46
10.002 Vertical Fixed Roof
Components Emissions (Ibs.)
CARBON TET/TETRACHLOROETNYLENE 2316.54
Carbon tetrachloride 2230.97
-------
TANKS PROGRAM 3.0 , 07/18/97
EMISSIONS REPORT PAGE 4
BRIEF FORMAT
. Tetrachloroethylene 85. 56
Total: 2316.54
10.003 Vertfeal Flxtd Roof
Emissions (Ibs.)
CARBON TET/TETRACHLOROETHVLENE 2316.54
Carbon tetrachloride 2230.97
Tetrachloroethylene 85.56
Total: 2316.54
10.004 Vertical Fixed Roof
Component* Emissions (lb».)
CARBON TET/TETRACHLOROETHV/HEX 658.40
Tetrachloroethylene 344.29
HEXACHLOROETHANE (PERCHLOROETH 0.10
JjEXACHLOROBENZENE_^^ 0.00
Carbon tetrachloride 280.54
Total: 658.40
10.005 Vertical Fixed Roof
Components Emissions (Ibs.)
CARBON TET/TETRACHLOROETHV/HEX 1404.23
Carbon tetrachloride 1251.00
Tetrachloroethylene 139.57
HEXACHLOROETHANE (PERCHLOROETH 0.08
HEXACHLOROBENZENE 0.00
Total: ^^^^^^^^^ 1404!23
11.001 Vertical Fixed Roof
Components Emissions (Ibs.)
TOLUENE/OTHER 518.16
Toluene 509.48
-------
TANKS PROGRAM 3.0
EMISSIONS REPORT
BRIEF FORMAT
07/18/97
PAGE 5
Total:
11.002
Ethylbenzene
Total:
11.003
Total:
11.004
Total:
11.DOS
Total:
11.006
Vertical Ftxad Roof
Components
TOIUENE/ANINONITIIII.E
Toluana
Vartlcal Fixed Roof
Components
Methyl Isobutyl ketone
Vertical Fixed Roof
Components
OICHLOROMETHANE/OTHER
Nethylene chloride
Toluene
Vertical Fixed Roof
Components
TOLUENE/OTHER
Toluene
Ethylberaene
Vertical Fixed Roof
Components
METMANOL/UATER
Methyl alcohol
8.68
518.16
Emissions (lb«.)
229.88
96.64
133.24
229.88
Emissions (Ibs.)
100.52
100.52
Emissions (Ibs.)
1225.90
1222.25
3.65
1225.90
Emissions (Ibs.)
263.09
259.59
3.50
263.09
Emissions (Ibs.)
578.40
574.22
-------
TANKS PROGRAM 3.0
EMISSIONS REPORT
BRIEF FORMAT
, 07/18/97
PAGE 6
, Total:
11.007
WATER
Verticil Fixed Roof
Component!
Total:
11.008
XVIENE/OTHER
Ethylbeniene
Xylene (-o)
Vertical Fixed Roof
Components
Total:
11.010
EWLENE DtCHLORIDE/OTHER
Dichloroathane (1,2)
Ethylbentene
Vertical Fixed Roof
Components
ETNUENE OICHLORIDE/OTHER
Dichloroethane (1,2)
Ethylbenxene
Total:
11.011
Vertical Fixed Roof
Components
FORMALDEHYDE/METHANOL/UATER
Methyl •Icohol
4.18
578.40
Emissions (Ibs.)
2455.44
56.06
2399.39
2455.44
Emissions (Ibs.)
7122.15
7105.93
16.22
7122.15
Emissions (Ibs.)
3011.92
3005.06
6.86
3011.92
Emissions (Ibs.)
15.54
6.52
-------
.TANKS PROGRAM 3.0
EMISSIONS REPORT
BRIEF FORMAT
07/18/97
PAGE 7
•Total:
12.001
FORMALDEHYDE (37X)
Vertical Fixed Roof
Components
Total:
12.002
Total:
12.003
Toluene
Vertical Fixed Roof
Components
Toluene
Vertical Fixed Roof
Conponents
CYAHOHYORIN/TOLUENE
CYMIOHVDRIN
Toluene
Total:
12.004
Vertical Fixed Roof
Conponcfits
9.02
15.54
Emissions (Ibs.)
280.80
280.80
Emissions (Ibs.)
255.38
255.38
Emissions (Ibs.)
237.32
1.59
235.72
237.32
Emissions (Ibs.)
PSEUDOCUNENE/TRIHETHYLBENZ/XYl
PSEUDOCUMENE (1,2,4-TRIMETHYLB
TRINETHYLBENZENE (1,3,5-)
Xylene (-m)
PROPVL BENZENE (N-)
Ethylbenzene
62.09
7.58
15.31
33.81
2.68
2.71
-------
•TANKS PROGRAM 3.0
EMISSIONS REPORT
BRIEF FORMAT
, 07/18/97
PAGE 8
lota I:
12.005
Total:
12.009
Vertical Fixed Roof
Conponccits
Methyl alcohol
Total:
12.006 Vertical Fixed Roof
Total:
12.007
Total:
12.008
FORMALDEHYDE (37X)
Vertical Fixed Roof
Components
Toluene
Vertical Fixed Roof
Components
Toluene
Vertical Fixed Roof
Components
TOLUENE/METHVLENE CHLORIC
Heptane (-n)
62.09
Emissions (Ibs.)
169.31
169.31
Emissions (Ibs.)
0.83
0.83
Emissions (Ibs.)
140.90
140.90
Emissions (Ibs.)
273.71
273.71
Emissions (Ibs.)
284.30
138.IS
-------
TANKS PROGRAM 3.0
EMISSIONS REPORT
BRIEF FORMAT
07/18/97
PAGE 9
Toluene
MethyIene chloride
Total:
12.010
Total:
12.011
Total:
12.012
Total:
12.013
Total:
13.001
Total:
UATER
Vertical Fixed Roof
TRICHLOROBENZENE (1,2,4-)
Vertical Fixed Roof
Components
Hexane (-n)
Vertical Fixed Roof
Components
HEXANE/TRICHLOROBENZ/RABON/PCA
Hexane (-n)
TRI
Vertical Fixed Roof
Components
Trichloroethylene
Vertical Fixed Roof
Components
Methyl ethyl ketone
83.00
61.52
0.07
0.00
1.56
284.30
Emissions (Ibs.)
7.50
7.50
Emissions (Ibs.)
766.83
766.83
Emissions (Ibs.)
93.55
72.06
0.25
0.00
0.00
21.24
0.00
93.55
Emissions (Ibs.)
1656.80
1656.80
Emissions (Ibs.)
592.36
592.36
-------
14.001
Total:
14.002
Total:
14.004
Total:
14.005
Total:
15.002
Total:
15.003
Total:
15.004
Vertical Fixed Roof
Components
Xylene (-•»
Vertical Fixed Roof
Components
Xylene (-•>
Total:
14.003 Vertical Fixed Roof
Xylene (-•)
Vertical Fixed Roof
Component*
Methyl alcohol
Vertical Fixed Roof
Components
Xylene (*m)
Vertical Fixed Roof
Components
Xylene (-m)
Vertical Fixed Roof
Components
Xylene (-m)
Vertical Fixed Roof
Components
Emissions (Ibs.)
491.21
491.21
Emissions (Ibs.)
534.29
534.29
Emissions (Ibs.)
869.26
869.26
Emissions (Ibs.)
410.03
410.03
Emissions (Ibs.)
259.65
259.65
Emissions (Ibs.)
55.16
55.16
Emissions (Ibs.)
56.50
56.50
Emissions (Ibs.)
-------
Xyltne C-m) 71.66
Totil: 71.66
17.005 Vertical Flxad Roof
Conpontntt Emissions (Ibs.)
ETHVLENE OLYCOL/WATER 10.76
ETNVLENE OLVCOL 0.02
-------
TANKS PROGRAM 3.0
EMISSIONS REPORT
BRIEF FORMAT
i 07/18/97
PAGE 10
Total:
20.001
Total:
20.002
Total:
20.005
Total:
20.006
Total:
20.007
Total:
21.001
WATER
Vertical Fixed Roof
Components'
HYDRAZINE/UATER
WATER
HVDRAZINE
Vartlcal Fixed Roof
Components
HTORAZI HE/WATER
HTDRAZINE
WATER
Vartlcal Fixed Roof
Component•
Dimethyl hydraitne (1,1)
Verticil Fixed Roof
Components
Dimethyl hydrailne (1,1)
Vertical Fixed Roof
Components
Acatonitrile
Vertical Fixed Roof
Components
10.75
10.76
Emissions (Ibs.)
53.35
25.29
28.06
53.35
Emissions (Ibs.)
125.87
66.21
59.67
125.87
Emissions (Ibs.)
362.54
362.54
Emissions (Ibs.)
423.04
423.04
Emission! (Ibs.)
137.15
137.15
Emissions (Ibs.)
Methyl alcohol
467.71
-------
Total: 467.73
21.002 Vertical Fixed Roof
Components Emissions (tbs.)
Toluene 110.15
Total: 110.15
21.003 Vertical Fixed Roof
Conponents Emissions (Ibs.)
METHMIOL/TOLUENE/OTHER 1326.98
Methyl alcohol 875.H
-------
TANKS PROGRAM 3.0
EMISSIONS REPORT
BRIEF FORMAT
07/18/97
PAGE 11
Total:
21.007
Total:
21.008
Total:
21.009
Total:
21.010
Total:
21.011
Total:
22.006
Toluene
WATER
Vertical Fixed Roof
Components
Methyl alcohol
Vertical Fixed Roof
Components
Toluene
Vertical Fixed Roof
Components
Toluene
Vertical Fixed Roof
Components
Toluene
Vertical Fixed Roof
Components
Toluene
Vertical Fixed Roof
Components
Toluene
Total:
22.007 Vertical Fixed Roof
392.63
59.21
1326.98
Emissions (Ibs.)
869.50
869.50
Emissions (Ibs.)
2215.21
2215.21
Emissions (Ibs.)
1065.62
1065.62
Emissions (Ibs.)
771.72
771.72
Emissions (Ibs.)
2841.41
2841.41
Emissions (Ibs.)
247.06
247.06
-------
Components Emissions tlbs.)
Methyl alcohol 1155.60
Total: 1155.60
-------
Attachment 3
-------
Docket No. A-95-20
Category II-B
The following information is located in the confidential
files of the Director, Emission Standards Division, Office of Air
Quality Planning and Standards, U. S. Environmental Protection
Agency, Research Triangle Park, North Carolina 27711. This
information is confidential pending final determination by the
Administrator and is not available for public inspection.
Attachment 3 to Storage Tanks Data and Results of Storage
Tank Emission Calculations Using TANKS3 Software Memorandum (part
of docket item II-B-21).
This attachment consists of the full citations for the
confidential references in this memorandum, tank dimension data
provided by one plant, and the calculated dimensions for each
tank in Attachment 1.
-------
MIDWEST RESEARCH INSTTTUTl
Suite 35C
401 Harrison Oaks Boulevart
Gary. North Carolina 27513-2412
Telephone (919) 677-0249
FAX (919) 677-0065
Date: April 30, 1997
Subject: Model Plants for the Pesticide Active Ingredient
Manufacturing Industry
EPA Contract No. 68D60012; Task Order No. 0004
BSD Project No. 93/59; MRI Project No. 4800-04
From: David Randall
Karen Schmidtke
To: Laiit Banker
ESD/OCG (MD-13)
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
I. Introduction
The purpose of this memorandum is to describe model
emission points and model plants that were developed to
characterize affected sources under the MACT standard for the
pesticide active ingredient (PAD manufacturing source category.
Model emission points (i.e., process vents, equipment leak
components, storage tanks, wastewater systems, and bag dumps and
^product dryers) were developed for estimating the environmental
and cost impacts of regulatory alternatives. Model plants (i.e.,
various combinations of the model emission points) were developed
for estimating economic impacts.
There are an estimated 78 plants nationwide that would be
affected sources under the MACT standard for the PAI
manufacturing source category.1 Information is available for 20
of these plants, leaving 58 to be modelled. The 20 facilities
for which information is available are referred to in this
memorandum as "surveyed" plants, and the other 58 plants are
referred to as "modelled" plants.
To simplify the impacts analyses, models were developed to
characterize each of the 20 surveyed plants. The same models
»»
were then used to characterize the 58 additional plants. The
procedures used to develop the models and the characteristics of
-------
the models are described in the remainder of this memorandum.
Model process vents, equipment leaks, storage tanks, wastewater
systems, and bag dumps and product dryers are described in
sections II through VI, respectively. Sections VII and VIII
cover the model plants for existing and new sources,
respectively. Section IX lists the references.
II. Model Process Vents
Most of the available process vent emissions data are for
manifolded streams, not individual vent streams. Therefore,
model process vents were developed on a process basis. In the
remainder of this discussion, the terms "emissions" or "process
emissions" refer to aggregated emissions from all of the vents
associated with a process.
Each of the 58 modelled plants are estimated to have 2 PAI
processes, for a nationwide total of 116 "projected" processes.
As noted in the data summary memorandum, the 20 surveyed plants
have a total of 93 processes, for an average of 4.7 per plant.2
This is believed to be higher than the industry average because
an effort was made to obtain information from some of the known
large plants.2 In addition, a 1986 survey by EPA's Office of
Water found that more than half of the plants in the industry
produced only one active ingredient. The 1986 survey also found
an average of about 2 processes per plant (although it did not
account for production of intermediates in separate processes,
and it may not have covered all active ingredients that were
produced at the plant).3 The estimate of two processes per plant
for this modelling analysis was selected to be consistent with
those findings.
Table 1 shows the distribution of processes at the surveyed
plants and the assumed distribution of projected processes.
Batch and continuous processes with organic HAP emissions account
for more than 85 percent of the surveyed processes. Many of
these processes also emit HC1. Models were developed based on
these processes because it is expected that they are also the
most prevalent in the rest of the industry.
-------
TABLE 1. DISTRIBUTION OF SURVEYED AND MODEL PROCESSES*
Type of process
Batch with organic HAP
Continuous with organic HAP
Batch with only inorganic
HAPb
Continuous with only
inorganic HAP^
Batch/continuous
Total
Surveyed processes
Uncontrolled
emissions
i cutoff
46
18
1
1
8
74
Uncontrolled
emissions
< cutoff
17
0
2
0
0
19
Projected processes
Uncontrolled
emissions
2 cutoff
67
26
0
0
0
93
Uncontrolled
emissions
< cutoff
23
0
0
0
0
23
The cutoff is 0.15 Mg/yr for organic HAP and 6.8 Mg/yr for HCI (72 surveyed processes exceed the
organic HAP cutoff, and 2 additional surveyed processes exceed only the HCI cutoff).
''Inorganic HAP includes HCI, chlorine, hydrogen cyanide, and hydrazinc.
To simplify the analysis, unique models to represent other
types of processes and other types of HAP emissions were not
developed. Also, such processes can be adequately represented by
the existing models. For example, unique models for processes
that are a combination of batch and continuous operations were
not developed because these processes also have organic HAP
emissions, and it is believed that the impact of regulations on
such processes can be adequately estimated by representing some
as batch processes and others as continuous processes. Unique
models for processes that emit only inorganic HAP (typically HCI)
were not developed because some of the models for processes that
emit organic HAP also emit HCI. Thus, using model processes that
emit both HCI and gaseous organic HAP to represent processes that
emit only HCI is expected to provide a worst case estimate of
emissions and cost impacts.
According to the data in Table j., the surveyed plants have
74 processes with uncontrolled HAP emissions equal to or greater
than cutoffs established in the MACT floor memorandum (i.e.,
0.15 Mg/yr for organic HAP and 6.8 Mg/yr for HCI emissions) and
-------
19 processes have lower emissions (i.e., 80 percent and 20
percent, respectively) .4 Based on the assumption that this
distribution is applicable in the industry as a whole, 93 of the
116 projected processes were characterized with uncontrolled HAP
emissions above the cutoffs, and 23 were characterized with lower
uncontrolled HAP emissions. The number of processes with
uncontrolled emissions above and below the cutoffs was determined
because the MACT floor control level differed for the two
groups.4
The distribution of batch and continuous projected
processes was based on the distribution of surveyed processes.
As shown in Table JL, the surveyed plants have 46 batch and- 18
continuous processes with organic HAP emissions equal to or
greater than the cutoffs (i.e., 72 percent batch and 28 percent
continuous). Applying this same ratio to the 93 projected
processes with uncontrolled emissions equal to or greater than
the cutoffs resulted in 67 batch processes and 26 continuous
processes. The same methodology was used to estimate the
distribution of the 23 projected processes with uncontrolled
emissions below the cutoffs.
Four model processes were developed to characterize the 93
projected processes with uncontrolled HAP emissions equal to or
greater than the cutoffs. Table 2 shows the operating parameters
and uncontrolled emissions for the four groups of processes at
the surveyed plants that were used to develop these models. The
resulting parameters for the model processes are shown in
Table 3. No model processes were developed to characterize the
23 projected processes with uncontrolled emissions below the
cutoffs because no regulatory alternatives were developed for
these processes.
The primary parameters used to differentiate among the
models were the type of HAP (chlorinated or unchlorinated) and
the type of process (batch or continuous). The type of HAP was
used because emissions streams with chlorine often require
additional control equipment to remove, or prevent the formation
of, HC1. The type of process was selected as a critical
-------
TABLE 2. SUMMARY OF PROCESS VENT CHARACTERISTICS AT SURVEYED PLANTS
Plant
no.
15
11
21
15
3
21
21
21
14
22
8
15
14
14
14
14
22
22
21
6
22
12
21
7
19
22
20
22
23
23
17
23
3
22
23
5
22
8
3
12
21
12
23
22
22
9
Proems
no.
57
36
70
58
12
71
72
73
46
81
22
54
43
44
47
45
77
76
69
16
78
38
68
17
64
85
66
84
90
89
60
92
7
83
93
15
82
20
11
37
67
40
94
79
75
24
B/C
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
PTOMM
operating
hr/yr
3,960
7.776
127
5.220
4,176
148
169
189
288
300
2.208
5,784
792
696
576
840
1.184
1.776
570
4,404
1.036
1,170
4,056
6.072
6,318
1,542
840
2,496
1,340
2,320
1.548
360
8.160
1.946
4.150
6,039
8,760
2,208
8.160
1,368
8.400
1.568
4.370
432
4,500
5,568
Un
l^lilmhi^ta ft
umanmiN
OTQWUC6
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
000771
0.0132
0.337
0486
0693
22.7
40.1
42.8
45.4
0.0454
0
0
0
32.8
26.5
830
53.1
0
Unchlor-
Irated
0276
0.309
0.447
0.679
0.782
0.820
0.857
0.969
1.00
1.38
1.41
1.59
1.74
176
2.28
3.19
4.S4
454
581
16.5
23.8
24.3
285
330
343
667
818
963
0198
0342
0
1.39
0
6.27
18.6
9.05
122
15.2
0.403
4.59
129
15.4
385
0
0
0
*.Mg/yr
HCI
0
0
0
0
0
0
0
0
0
0
(a)
0.157
0
0
0
0
0
0
0
0
0
0.00014
0
0
0
0
0
0101
0410
0710
0
000064
0
0
0557
0
0
6.80
900
110
120
267
331
544
349
356
Other
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
771
0
0
0
0
0
0
0
0
0
000045
0
0
0
0
0
0
0
0
0
0
0
0
0
0
ToUl
0.276
0.399
0.447
0679
0782
0.820
0.857
0969
100
138
1 41
1.74
1.74
176
228
319
454
454
5.81
165
238
320
285
330
343
667
816
964
0616
1 07
0337
1 88
0.693
289
592
519
575
221
941
156
141
749
981
628
402
356
-------
6
TABLE 2. SUMMARY OF PROCESS VENT CHARACTERISTICS AT SURVEYED PLANTS (CONTINUED)
Plant
no.
5
22
17
17
17
1
1
1
7
1
10
3
11
8
8
23
12
9
22
Process
no.
14
80
61
62
63
2
4
3
18
1
27
6
33
23
19
91
39
25
74
B/C
C
C
C
C
C
C
C
C
C
C
C
C
C
C
C
C
C
C
C
Process
operating
hr/yr
7.464
456
1,920
2,424
8,064
336
720
720
5.300
5,040
7,680
8,136
7,176
7,896
7,896
7,488
7,000
3,384
5.184
Chlorinated
organics
0
0
0
0
0
0.0459
0.0751
0.158
0.181
1.11
31.3
50.9
60.3
0
0.0431
4.02
199
18.2
347
Uncontrolled
Unchlor-
inated
0.916
1.81
8.19
15.3
200
5.59
9.14
19.3
12.6
135
0
0
4.4
0
202
0
0
0
0
emissions, Mg/yr
HCI
0
0
0
0
0
0.0262
0.0428
0.0904
• 0
0.633
0
0
0.761
14.5
13.2
117
67.2
174
2,360
Other
0
0
0
0
0
0
0
0
0
0
1.39
0
0
'o
0
0
0
0
0
Total
0.916
1.81
8.19
15.3
200
5.66
9.26
19.5
12.8
137
32.7
50.9
65.5
14.5
215
121
266
192
2.707
(a) No data provided.
-------
TABLE 3. MODEL PROCESS PARAMETERS
Parameters
Type of process
Type of organic
HAP
Typical organic
HAP
Operating hours,
hr/yr
Gas flow rate,
scftn
-dilute
-concentrated
Number of vents
per process
Uncontrolled
emissions,
Mg/yr/process
HC1
chlorinated
unchlorinated
Number of model
processes
Models
1
Batch
Unchlorinated
Toluene
2,800
2,950
683
6
0
0
13.7
48
2
Batch
Chlorinated
Methylene chloride
and toluene
2,800
2,080
21
6
66.1
20.9
19.1
19
3
Continuous
Unchlorinated
Toluene
5,000
41,100
140
6
0
0
41.0
14
4
Continuous
Chlorinated
Methylene chloride
and toluene
5,000
32,900
131
6
295
78.9
22.9
12
parameter because batch processes often operate fewer hours,
produce less product, and are more difficult to control than
continuous processes.
The average emissions data for 46 of the 47 batch processes
and all 19 of the continuous processes at the surveyed plants
were used to develop the emissions levels for the four model
processes; the data for these processes are shown in Table 2.
Data for the 8 surveyed batch/continuous processes were not
included in Table 2 because this type of process was not
modelled. Thirty-three of the 47 batch processes emitted
unchlorinated organic HAP, HC1 <6.8 Mg/yr, and chlorinated
-------
8
organic HAP <7.9 Mg/yr (i.e., the amount of methylene chloride
that would be needed to generate 6.8 Mg/yr of HC1 if all of the
chlorine were converted to HC1 in « combustion-based control
device). The average uncontrolled organic HAP emissions for
these 33 processes was 13.7 Mg/yr. This level was used for model
process 1. Thirteen of the 47 batch processes emitted
chlorinated organic HAP >7.9 Mg/yr, HC1 >6.8 Mg/yr, or both; 10
of these processes also emitted unchlorinated organic HAP. The
average chlorinated organic, unchlorinated organic, and HC1
emissions for these 13 processes were 20.9, 19.x, and 66.x Mg/yr,
respectively. These levels were used for model process 2. One
of the 47 batch processes was not used to establish model
parameters because of its characteristics; emissions from this
processes consisted primarily of very high amounts of HC1 and
phosgene.
The average emissions data for the 19 continuous processes
at the surveyed plants were used to develop the emissions levels
for model processes 3 and 4. Ten of the 19 continuous processes
emitted unchlorinated organic HAP, HC1 <6.8 Mg/yr, and
chlorinated organic HAP <7.9 Mg/yr. The average organic HAP
emissions for these 10 processes was 41.0 Mg/yr. This level was
used for model process 3. Nine of the 19 continuous processes
emitted chlorinated organic HAP >7.9 Mg/yr, HC1 >6.8 Mg/yr, or
both; 2 of these processes also emitted unchlorinated organic
HAP. The average chlorinated organic, unchlorinated organic, and
HC1 emissions for these 9 processes were 78.9, 22.9, and 295
Mg/yr, respectively. These levels were used for model process 4.
The distribution of the processes in Table 2 was also used
to determine the distribution of the four model processes among
the 93 projected processes with uncontrolled HAP emissions equal
to or greater than the cutoffs. Of the 46 batch processes in
Table 2, 33 were used to develop the emissions level for model
process 1, and 13 were used to develop the emissions level for
model process 2. This same ratio was applied to the 67 projected
batch processes from Table 1, resulting in 48 processes
represented by model process 1 and 19 processes represented by
-------
model process 2. Of the 19 continuous processes in Table 2, 10
were used to develop the emissions level for model process j, and
9 were used to develop the emissions level for model process 4.
This same ratio was applied to the 26 projected continuous
processes in Table 1, resulting in 14 processes represented by
model process 3 and 12 processes represented by model process 4.
Operating hours were available for all 46 batch processes
and 19 continuous processes in Table 2. Operating hours were
also available for another 13 batch processes with emissions
<0.15 Mg/yr (330 Ib/yr).2 The 59 batch processes operated for an
average of about ^,800 hr/yr, and the 19 continuous processes
operated for an average of about 5,000 hr/yr. These values were
used for the model processes.
The typical unchlorinated HAP for the model processes was
assumed to be toluene because it was emitted from the most
surveyed processes and in greater quantities than any other
organic HAP.2 A wide variety of chlorinated organics were
emitted from the surveyed processes. Overall, the chlorinated
HAP's had an average of about two chlorine atoms per molecule.
Ethylene dichloride, methylene chloride, and phosgene were the
only organic HAP's with two chlorine atoms per molecule emitted
from processes in the PAC industry.2 Methylene chloride was
emitted in the smallest quantity. However, it was selected for
the model processes for several reasons. First, it was used at
the most plants (one more than the others). Relative to ethylene
dichloride, methylene chloride has a higher vapor pressure, lower
heat of combustion, and nearly the same heat of condensation.
These characteristics would make methylene chloride more
difficult to control and more costly to control. Thus, using
methylene chloride in the model would result in a worst-case
impacts analysis. Phosgene was not selected because it is not
combustible and decomposes in water; thus, it is not
representative of most chlorinated organic compounds.
Two gas flow rates, one for dilute streams and one for
concentrated streams, were estimated for each of the four model
processes. These flow rates are equivalent to the weighted
-------
10
average of the flow from a single vent stream created by
manifolding all of the individual vent streams from a process.
The data and procedure used to estimate the model flow rates are
presented in a separate memorandum.5
III. Equipment Leak Models
Two equipment leak models were developed from data for 30
of the 93 processes at the surveyed plants. The equipment
components used in the models are flanges, pumps, valves in gas
service (gas valves), and valves in liquid service (liquid
valves). Other types of components were not included in the
modeling because they were not present in significant quantities.
The component counts for all 30 surveyed processes are
shown in Table 4. The counts for flanges and pumps are as
reported by the plants. Counts for gas and liquid valves were
also available for 17 of the processes, but only the total number
of valves was available for the other 13 processes. Liquid
valves accounted for an average of about 60 percent of the valves
in the 17 processes. This distribution was used to estimate the
number of gas and liquid valves in the other 13 processes.
Parameters for both of the equipment leak models are shown
in Table 5. One of the models characterizes batch processes, and
one characterizes continuous processes. The equipment counts for
models 1 and 2 were developed by averaging the equipment counts
for the batch and continuous processes, respectively, in Table 4.
As noted in Section II, model batch processes were estimated to
operate 2,800 hr/yr, and continuous processes were estimated to
operate 5,000 hr/yr.
Uncontrolled emissions for the models were calculated using
SOCMI average emission factors for connectors, valves in gas
service and light liquid service, and pumps in light liquid
service.6 It was assumed that components were in service 100
percent of the process operating hours and that they were in
contact with process fluid that is 100 percent HAP.
According to section 163.161 of 40 CFR part 63 subpart ri,
light liquid service for equipment components means a piece of
equipment in organic HAP service meets the following conditions:
-------
11
TABLE 4. EQUIPMENT COMPONENT COUNTS FOR PROCESSES AT SURVEYED PLANTS
Process
Number*
1
2
3
4
5
6
7
I
9
10
11
12
13
14
IS
16
17
18
19
20
21
22
23
24
25
26
27
21
29
in
Batch or
continuous
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
C
C
C
C
C
C
C
C
C
C
r
Number of components
Flanges
0
44
44
100
192
252
372
506
593
S10
112
914
1.098
1.140
1.453
2.839
2.979
3.528
3.528
0
0
980
1,284
1.500
1,500
I.SOO
1,500
2,591
2.604
21JA
Pumps
0
0
0
i
0
3
6
7
11
2
4
14
5
1
20
44
33
S3
53
13
128
7
4
33
33
33
33
28
22
57
Gas
valves
0
i
l
6
50
61
32
41
4
11
76
72
43
126
89
190
191
260
260
108
947
19
35
278
278
278
278
260
251
?T7
Liquid
valves
32
7
7
20
323
75
129
165
218
231
154
290
278
294
354
762
765
1.040
1.040
430
3.788
392
508
954
954
954
954
1.330
1,004
RftA
-------
12
TABLES. PARAMETERS FOR EQUIPMENT LEAK MODELS
Parameters
Type of model process
Operating hours, hr/yr
Equipment counts
Flanges
Pumps*
Gas valves
Liquid valves*
Uncontrolled emissions, Mg/yr/process
Number of models
At modelled plants
At surveyed plants
Total
Models
1
Batch
2,800
1,100
14
65
340
11.3
90
48
138
2
Continuous
5,000
1,500
33
240
1,100
46.3
26
11
37
(1) the vapor pressure of one or more of the organic compounds is
greater than 0.3 kilopascals (kPa) at 20°C, (2) the total
concentration of the pure organic compounds having a vapor
pressure greater than 0.3 kPa at 20°C is equal to or greater than
20 percent by weight of the total process stream, and (3) the
fluid is a liquid at operating conditions.
Seventy-eight of the 84 processes with organic HAP
emissions use at least one HAP that would satisfy the vapor
pressure condition for light liquid service.2 The concentration
of HAP in the process fluid is unknown; however, as noted above,
emissions for the equipment leak models were calculated assuming
100 percent HAP. Because equipment count data were provided by
plants that were implementing leak detection and repair (LDAR)
programs, it is likely that they reported only those components
that are in contact with a liquid process fluid at operating
conditions. Thus, all of the modelled liquid valves and pumps
were assumed to be in light liquid service.
-------
13
The equipment count models were used to characterize
components in both the 116 model processes and 63 processes from
the surveyed plants for which equipment counts were not available
(i.e., 93-30-63). Eight of the 63 processes were identified as
combinations of batch and continuous operations; five of these
processes were characterized with the batch model, and three were
characterized with the continuous model. Four of the 63
processes use only inorganic or granular HAP and, thus, would not
have any organic HAP emissions. As a result, Table 5 shows 175
processes represented by the models (i.e., 116+59=175).
IV. Model Storage Tanks
Model tanks were developed by sorting the data from organic
(plus 2 inorganic) HAP storage tanks at major sources. The
characteristics of 82 storage tanks from 16 major sources were
used in the development of model tanks.2 It was assumed that the
number of storage tanks and their characteristics at the
16 surveyed plants are representative of tanks at other plants in
the PAI production industry. Table 6 contains data for the
82 storage tanks that were used to define the model tank
parameters. The primary parameters used to develop the model
tanks include tank capacity, the uncontrolled emissions, and the
control efficiency. The models are based on three capacity
ranges as follows:
l. Models l <20,000 gal;
2. Models 2 ^20,000 and <40,000 gal; and
3. Models 3 ^40,000 gal.
The uncontrolled emission level and the control efficiency were
used to further define the models. Based on uncontrolled
emissions and the control efficiency, three models for each tank
capacity range were developed:
j.. A all tanks with uncontrolled emissions 2110 kg/yr
(z240 lb/yr) and control efficiency 295 percent;
2. B all tanks with uncontrolled emissions 2110 kg/yr
(2240 lb/yr) and control efficiency <95 percent; and
3. C all tanks with uncontrolled emissions <110 kg/yr
(<240 lb/yr).
-------
TABLE 6. STORAGE VESSELS AT SURVEYED FACILITIES
Tank
No.
TANKS
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
Tank size,
HAP gal
<20,000 gal (41 TANKS)
TOLUENE
MIX-CARBON TETRACHLORIDE/TETRACHLOROETHYLENE
MIX-CARBON TETRACHLOR1DE/TETRACHLOROETHYLENE
TOLUENE
TOLUENE
TOLUENE
MIX-CARBON TETRACHLORIDE/TETR ACH LOROETH YLEN E/
HBXACHLOROETHANE/HEXACHLOROBBNZENE
TOLUENE
TETRACHLOROETHYLENE
METHYLENE CHLORIDE
METHANOL
METHYL ETHYL KETONE
METHANOL
TOLUENE
METHANOL
DIMETHYL HYDRAZINE
DIMETHYL HYDRAZINB
TOLUENE
METHANOL
MIX-TOLUENE/METHYLENE CHLORIDE
TOLUENE
ACETONITRILE
MALEIC ANHYDRIDE
METHANOL
TOLUENE
METHYL ISOBUTYL KETONE
TOLUENE
15,000
15,750
15,750
15,000
15,000
15,000
8,400
10,300
5,200
6,540
15,000
17,500
13,500
12,690
15,000
14,000
12,000
13.500
10,500
10,300
10,300
12,387
14,500
10,000
15,000
7,900
6,000
Annual Vapor Uncontrolled
Throughput, Pressure, emiMom, '
gal paa *Mc V«
14,700,000
324,900
324.900
10,800,000
3,640,000
1,810,000
537,700
213,000
348,700
52,980
490,000
160,000
755,800
2,120,260
213,950
12,540
13,330
322,530
33,000
111,000
75,000
7,120
350,000
81,000
19,914
175,000*
60,000
0.5494
1.8742
1.8742
0.5494
0.5494
0.5494
0.5381
0.5494
0.3499
7.9181
2.4155
1.7443
2.2488
0.5254
2.4155
3.033
3.033
0.5302
2.4155
0.456
0.5494
1.7824
0.1812
2.4155
0.5494
0.373
0.5494
1,290
1,050
1.050
1,000
483
350
283
124
121
554
394
269
260
231
212
190
164
118
76.8
65.6
63.9
62.2
55.5
52.9
50.0
45.6
45.1
Control
efficiency,
*
98
98
98
98
98
98
98
98
98
4
0
0
42
13.2
0
0
0
41
98
98
98
0
99.5
90
0
89
95
-------
TABLE 6. STORAGE VESSELS AT SURVEYED FACILITIES (continued)
Tank
No.
28
29
30
31
32
33
34
35
36
37
38
39
40
41
Tanks
42
43
44
45
46
47
48
49
50
51
52
53
HAP
MDC-HEXANE/TRICHLOROBENZENE
TOLUENE
XYLENE
METHANOL
XYLENE
XYLENE
MALEIC ANHYDRIDE
FORMALDEHYDE
MIX-BUTYL CBLLOSOLVE/TRIETHYLAMINE
ETHYLENE GLYCOL
ETHYLENE GLYCOL
ETHYLENE GLYCOL
ETHYLENE GLYCOL
CHLOROACETIC ACID
> -20,000 and < 40,000 gal (21 TANKS)
ETHYLENE DICHLORIDE
MIX-CARBON TETRACHLORIDE/TETRACHLOROETHYLENE/
HEXACHLOROETHANE/HEXACHLOROBENZENE
MIX-METHANOL/TOLUENE
XYLENE
METHANOL
XYLENE
TOLUENE
TOLUENE
TRICHLOROETHYLENE
HEXANE
XYLENE
TOLUENE
Annual Vapor Uncontrolled
Tank lize. Throughput, Preuure, emiinoni, '
gal gal pna *MgWl
7.500
10.000
12,847
7,500
6,423
5,313
16.000
7,000
14,000
7,000
7,000
7.000
17,760
2,500
27,000
33,000
30,000
32,000
30,000
32,000
32,000
31,600
20,000
20,000
27,000
30.000
7,800
3,670
146,160
38,000
146,160
146,160
177,681
11,000
119,000
224.000
77,000
77.000
600
9,800
3.140,000
179,200
2,250,000
747,310
91,823
308,147
79,000
68,478
369,000
33,800
40,300
455,000
0.7432
0.4329
0.2267
2.4155
0.2267
0.2267
0.0186
0.058
0.0052
0.0006
0.0006
0.0006
0.0002
0.0002
1.4824
1.4285
1.195
0.2267
2.4155
0.2267
0.5494
0.5494
1.3353
2.9292
0.2267
0.1284
32.8
34.4
32.5
31.8
25.6
25.0
12.4
0.38
0.54
0.08
0.04
0.04
0.01
0
1,360
631
575
242
186
118
116
112
752
752
348
49.7
43.8
Control
efficiency,
*
98
90
0
90
0
0
0
98
0
0
0
0
0
0
98
98
98
98
98
98
98
98
0
0
0
98
-------
TABLE 6. STORAGE VESSELS AT SURVEYED FACILITIES (continued)
Tank
4o.
54
55
56
57
58
59
60
61
62
ranki>
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
HAP
METHANOL
HYDRAZINE
HYDRAZ1NE
MIX-FORMALDEHYDE/METHANOL
TOLUENE
TRICHLOROBENZENE
BUTYL CELLOSOLVE
ANILINE
ANILINE
-40.000 gal (20 TANKS)
TOLUENE
TOLUENE
MIX-TOLUENE/CYANUR1C CHLORIDE
MIX-TOLUENE/CYANURIC CHLORIDE
ETHYLENE DICHLORIDE
GLYCOL ETHER
GLYCOL ETHER
GLYCOL ETHER
METHANOL
XYLENE
XYLENE
TOLUENE
METHANOL
XYLENE
METHANOL
MIX-FORM ALDEHYDE/METHANOL
MIX-TOLUENE/CYANOHYDRIN
TRICHLOROBENZENE
TRICHLOROBENZENE
MIX-ETHYL BENZENE/XYLENE
Tank nze,
6«1
35,000
30,000
25,600
30,600
30,000
30,000
22,000
20.000
20,000
500,000
500,000
500,000
500,000
144.000
66,000
66,000
66,000
102,000
47,000
47,000
40,000
75,000
1,567,000
100,000
50,000
84,000
220,000
500,000
40,000
Annual Vapor Uncontrolled
Throughput, Prewure, emiuioiu, '
gal piia Xfcta
175.000
464,997
119,742
815,000
1,375,248
31,200
262,940
20,540
20,540
56,000,000
56,000,000
64,000,000
64,000,000
2.890,000
176,440
176,440
176,440
288,954
1,226,040
620.800
31.000
816,334
5,342,000
500,000
3,069,544
68,000
4.840,000
1,000,000
56,000
0.4855
0.1562
0.1562
0.0715
0.0042
0.0082
0.0139
0.013
0.013
0.5494
0.5494
OJ469
0.3469
1.4824
1.5235
1.5235
1.5235
2.4155
0.2267
0.2267
0.5494
2.4155
0.2233
2.4155
0.0433
0.2686
0.0082
0.0082
0.0565
32.2
30.0
12.7
7.05
4.08
3.40
1.72
0.33
0.33
11,500
11,500
5,020
5.020
3.220
669
669
669
524
394
223
127
1.360
1.090
692
372
108
98.2
67.3
16.6
Control
efficiency,
%
0
0
0
98
0
0
0
0
0
95
95
95
95
98
98
98
98
98
98
98
98
0
25
0
0
98
0
0
98
-------
17
A total of nine model tanks were developed to represent
storage tanks in the PAI manufacturing industry; Table 7 presents
the parameters for each of the models. Data in Table 6 were used
to determine the number of tanks at surveyed plants to be
characterized by each model. For example, 15 of the tanks in
Table 6 have uncontrolled emissions *110 kg/yr U240 Ib/yr) and
control efficiencies less than 95 percent. Nine of these 15
tanks have capacities <20,000 gal, 2 have capacities 220,000 to
<40/000, and 4 have capacities *40,000 gal. Therefore, these
tanks are characterized by models IB, 2B, and 3B, respectively.
Table 7 shows the number of tanks at the surveyed plants
represented by each of the 9 model tanks.
The number of storage tanks at the 58 modelled plants was
estimated by extrapolating data from the 20 surveyed plants. The
20 surveyed plants have 82 tanks that store organic liquids.
Assuming the average number of tanks per plant industry-wide is
the same as at the surveyed plants results in an estimated total
of 238 tanks at the 58 modelled plants (i.e., 82 x 58/20 = 238).
This same ratio was used to estimate the number of tanks at the
modelled plants represented by each of the model tanks. For
example, 26 of the 238 tanks are represented by model IB (i.e., 9
tanks at the surveyed plants multiplied by 58/20 equals 26).
Table 7 shows the number of tanks at the modelled plants
represented by each of the 9 model tanks.
V. Wastewater Systems
As noted in the data summary memorandum, the 20 surveyed
plants reported a total of 72 POD wastewater streams that were
generated from 45 of the 93 processes (48 percent).2
Characteristics of aggregated wastewater streams from each of the
45 processes are presented in Table e. These characteristics
include: (1) the organic HAP loads and concentrations, (2) the
wastewater flow rates, and (3) the total uncontrolled and
controlled HAP emissions.
If 48 percent of all processes in the industry have
wastewater streams, then an estimated 56 of the 116 model
processes generate wastewater (45/94 x 116 «= 56). Two approaches
-------
TABLE 7. CHARACTERISTICS OF MODEL STORAGE TANKS
Parameter*
Tank camcttVi.
g«l
Avg throughput,
gaJ/yr
Baseline control,
percent
Uncootrolled
emissions per
tank, kg/yr
No. of tanks per
capacity range
nationwide:
at surveyed
plants
at modelled
plants
Models
1-A
12.820
3,633,000
95%
640
9
26
I-B
13.300
460,200
11%
226
9
26
1-C
9,771
91.130
45%
31.0
23
67
2-A
30,950
858,000
95%
418
8
23
2-B
20,000
201,400
0%
550
2
6
2-C
27,290
343,700
18%
16.8
li
32
3-A
214,800
20,470,000
95%
3.300
i2
34
3-B
448,000
2,432,000
6%
876
4
12
3-C
211,000
1,491,000
50%
72J
4
12
-------
TABLE 8. CHARACTERISTICS OF MODEL WASTEWATER STREAMS
Wastewater
stream
model No.
12
39
36 (a)
28
6
11
30
4
29
31
3
45
33
24
41
40
22
9
2
7
23
5
25
1
8
HAP
load,
Mg/yr
0.0050
0.0318
0.041
0.051
0.173
0.181
0.192
0.231
0.349
0.385
0.386
0.395
0.427
0.499
0.627
0.658
0.796
0.907
0.925
1.23
1.81
2.06
3.18
6.17
6.78
Wastewater
flowrate,
gal/yr
36,981,000
222,100
220
1,824
411,000
2,630,000
1,028
7,500,000
5,625
2,056
12,500,000
933,100
4,026,000
132,000
705,600
777,600
403,600
13,500,000
30,000.000
11,600
47,000
27,600.000
7,000,000
200,000,000
73.420.000
HAP
cone.,
ppmw
0.0357
38
49,111
7,371
111
18
49,514
8
16,433
49,514
8
112
28
1,000
235
224
522
18
8
28,046
10.217
20
120
8
24
Process
operation,
hr/yr
7,296
1,036
2,200
960
7,809
7,680
96
720
840
192
720
1.542
1.548
1,568
300
456
1.368
5,300
336
904
1.170
7.809
5,040
6,039
Uncontrolled
emissions,
Mg/yr
0.00319
0.0254
0.0147
0.0406
0.0294
0.169
0.154
0.185
0.279
0.308
0.308
0.316
0.330
0.319
0.502
0.527
0.637
0.835
0.740
0.209
0.308
1.61
0.540
4.94
2.17
Controlled
emissions,
Mg/yr
0.00319
0.0254
0.0147
0.0406
0.0294
0.00846
0.154
0.185
0.279
0.308
0.308
0.316
0.330
0.319
0.502
0.527
0.637
0.835
0.740
0.209
0.308
1.61
0.0540
4.94
2.17
Nationwide wastewater streams
Surveyed
plants
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Model
plants
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
2
2
2
2
2
2
2
2
Total
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
H
VO
-------
TABLES. CHARACTERISTICS OF MODEL WASTEWATER STREAMS (CONTINUED)
Wastewater
stream
model No.
20
32
27
19
13
21
44
35
43
26
15
34
14
38
42
10 (a)
18
17
37
16
HAP
load,
Mg/yr
8.94
10.7
13.6
20.5
22.1
23.2
34.1
34.1
35.9
51.3
66.3
81.4
81.6
91.2
143
223
282
480
491
1,143
Wastewater
flowrate,
gal/yr
1,819,000
1,860,000
120,000
4,173,000
978,900
4,708,000
695,700
22,520,000
885,600
4,000,000
2,937,000
24,920,000
3,614,000
5,930,000
3,514,000
130,000,000
3,700,000
6,300,000
47,810,000
5,600,000
HAP
cone.,
ppmw
1,301
1,524
30,012
1,301
5,974
1.301
12,955
400
10,737
3,391
5,973
865
5,974
4,072
10,774
453
20,172
20,172
2,719
54,039
Process
operation,
hr/yr
3,588
5,784
792
1,600
1,272
7,776
2,496
6,318
1,946
8,760
3,072
8,064
3,792
4,056
8,760
7,896
7,176
7,176
8,400
7,104
Uncontrolled
emissions,
Mg/yr
3.46
8.57
10.9
7.95
12.4
8.97
8.70
11.6
6.98
24.6
37.3
29.1
46.0
17.7
26.1
42.5
181
308
94.7
327
Controlled
emissions.
Mg/yr
0.0003
8.57
10.9
0.0008
0.0012
0.0009
8.70
11.6
6.98
24.6
0.0037
29.1
0.0046
17.7
26.1
42.5
0.0181
0.0308
94.6
0.0327
Natlonwid
Surveyed
plants
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
e wastewate
Model
plants
2
2
2
1
1
1
1
1
1
1
1
1
1
1
r streams
Total
3
3
3
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
K)
O
(a) At the surveyed plants, the treatment process for this stream is deepwell injection;
therefore, controlled emissions are 0 Mg/yr. Emissions shown in this table are for the process at a projected plant.
-------
21
were used to develop models to characterize the aggregated
wastewater streams from each of the 56 processes. The first
approach used all of the 72 streams at the surveyed plants as
models; these model streams will be used to estimate baseline
emissions, environmental impacts, and cost impacts. The second
approach developed three model streams based on average
characteristics of streams at the surveyed plants that meet the
applicability criteria for control under the HON (i.e., assuming
the same provisions are part of this regulation); these model
streams will be used as part of the model plants that will be
used for estimating economic impacts. Both approaches are
discussed below.
A. Approach 1
Under approach j., all of the 72 streams from the 45
processes at the surveyed plants were used as model streams.
Because there were 56 processes to be characterized, the survey
data needed to be extrapolated by a factor of 1.24 (56/45«1.24) .
This extrapolation was accomplished in two steps. First, each of
the 45 processes was assumed to represent one of the model
processes. Second, the HAP loads for the 45 processes were
ranked, and each of the 11 processes in the middle of the
rankings (0.24x45=11) was used to represent a second model
process. This distribution allows for the use of whole streams
rather than fractions, and it focuses the analysis on median
streams rather than extremes. The rankings are presented in
Table 8, and the characteristics of the individual streams for
each process are presented in Table 9. In Table 9, wastewater
flow rates in L/min were calculated assuming the wastewater is
discharged continuously during the entire process operating time.
The average fraction emitted (Fe) and fraction removed (Fr)
values are weighted averages based on the fractional contribution
of each HAP to the total load in the stream.
Approach 1 was developed for two reasons. First, the
greater variety in streams may help in the process of deciding
what applicability criteria should be established for the
regulatory alternative above the MACT floor. For example, the
-------
22
TABLES. CHARACTERISTICS OF INDIVIDUAL WASTEWATER STREAMS
Plant
1
1
1
- 1
3
3
3
5
7
8
10
10
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
12
12
12
12
12
12
13
13
14
15
15
15
15
ww Process
stream operation,
(a) hr/vr
1
2
3
4
5
6
7
8
9
10
11
12
13a
13b
14a
14b
15a
15b
16a
16b
17a
17b
18a
18b
19
20
21
22a
22b
22c
22d
23
24
25
26
27
28
29
30
31
5,040
336
720
720
7,809
1,425
904
6,039
5,304
7,896
7,296
7.296
1,272
1,272
3.792
3,792
3,072
3.072
7,104
7,104
7,176
7,176
7.176
7.176
1,600
3,588
7,776
1,368
1,368
1,368
1,368
1,170
720
8,760
792
960
840
96
192
WWflow WWflow
rate, rate,
gal/yr l/min
200,000,000
30,000,000
12.500,000
7.500,000
27,600,000
411,000
11,600
73.417,207
13,500,000
130.000,000
2,630,000
36,981,000
908,700
70,200
3,355.200
259.200
2,726,100
210,600
4,400.000
1,200,000
1,260,000
5.040,000
740.000
2,960,000
4,173,000
1,819,000
4,708,000
3,600
159,000
33,000
208.000
47,000
132,000
7,000,000
4,000.000
120,000
1.824
5,625
1,028
2.056
2,503
5,632
1,095
657
223
18
1
767
161
1,039
23
320
45
3
56
4
56
4
39
11
11
44
7
26
165
32
38
0
7
2
10
3
12
29
10
0
0
1
1
HAP
load,
Mg/yr
6.17
0.925
0.386
0.231
2.06
0.173
1.23
6.78
0.907
223
0.181
0.0050
20.5
1.57
75.8
5.81
61.6
4.72
902
242
1.56
479
0.916
281
20.5
8.94
23.2
0.0069
0.327
0.064
0.399
1.81
0.499
3.18
51.3
13.6
0.051
0.349
0.192
0.385
HAP Uncontrolled
cone., emissions, Average Average
ppmw Mg/yr Fe Fr
8
8
8
8
20
111
28,046
24
18
453
18
0
5,977
5,936
5,977
5,936
5,977
5,936
54.227
53,352
328
25,133
328
25,133
1,301
1.301
1,301
510
544
509
508
10,217
1.000
120
3,391
30.012
7,371
16,433
49,514
49.514
4.94
0.740
0.308
0.185
1.61
0.029
0.209
2.17
0.835
42.47
0.170
0.003
11.6
0.887
42.7
3.28
34.7
2.66
257
69.1
1.25
306
0.733
180
7.95
3.46
8.97
0.0056
0.261
0.051
0.319
0.308
0.319
0.540
24.6
10.9
0.041
0.279
0.154
0.308
0.8
0.8
0.8
0.8
0.78
0.17
0.17
0.32
0.92
0.191
0.932
0.64
0.563
0.563
0.563
0.563
0.563
0.563
0.286
0.286
0.8
0.64
0.8
0.64
0.387
0.387
0.387
0.8
0.8
0.8
0.8
0.17
0.64
0.17
0.48
0.8
0.8
0.8
0.8
0.8
0.99
0.99
0.99
0.99
0.99
0.31
0.31
0.9
0.99
0.338
0.990
0.99
0.990
0.990
0.990
0.990
0.990
0.990
0.441
0.441
0.99
0.99
0.99
0.99
0.544
0.544
0.544
0.99
0.99
0.99
0.99
0.31
0.99
0.31
0.95
0.99
0.99
0.99
0.99
0.99
-------
23
TABLE 9.
Plant
15
17
' 17
19
19
19
19
20
21
21
21
21
21
21
21
21
21
21
21
21
21
21
21
21
21
22
22
22
22
22
22
22
WW
stream
(a)
32
33
34
35a
35b
35c
35d
36
37a
37b
37c
37d
37e
37f
37g
37h
37i
37j
37k
37!
37m
38a
38b
38c
38d
39
40
41
42
43
44
45
Process
operation,
hr/yr
5,784
7,896
8,064
6,318
6,318
6,318
6,318
840
8,400
8,400
8,400
8,400
8,400
8,400
8.400
8,400
8,400
8,400
8,400
8,400
8,400
4,079
4,079
4,079
4,079
1,036
456
300
8,760
1,946
2,496
1.542
CHARACTERISTICS OF INDIVIDUAL WASTEWATER
STREAMS (CONTINUED)
WWflOW WWflOW
rate, rate,
oal/vr l/min
1,857,146
4,026,000
24,917,933
675.500
1,660,000
10,080,000
10,080,000
220
1,512,000
4,536,000
85,909
1,008,000
2,520,000
1,260,000
14,407,848
800
10,500
3,500
22,165,920
140.000
157,500
5,250,000
30,100
145,950
504.000
222,071
777,600
705,600
3,513,600
885,600
695.665
933.120
20
32
195
7
17
101
101
0
11
34
1
8
19
9
108
0
0
0
166
1
1
81
0
2
8
14
108
148
25
29
18
38
HAP
load,
Mo/vr
10.7
0.427
81.4
1.02
2.54
15.3
15.3
0.041
0.774
5.15
0.00029
0
145
81.6
109
0.0264
0.242
0.144
149
0.405
0.215
90.9
0.222
0.136
0.0059
0.032
0.658
0.627
143
35.9
34.1
0.395
HAP Uncontrolled
cone., emissions, Average Average
pprnw Mg/yr Fe Fr
1,527
28
865
401
401
400
400
49,111
136
300
1
0
15,197
17,145
1.993
8,726
6,111
10,860
1,783
765
362
4.581
1,954
247
3
38
224
235
10,776
10,737
12,956
112
8.57
0.330
29.1
0.348
0.864
5.19
5.19
0.015
0.132
0.875
0.00005
0
24.6
13.9
25.5
0.0045
0.044
0.061
29.3
0.069
0.037
17.5
0.072
0.109
0.0047
0.025
0.527
0.502
26.1
6.98
8.70
0.316
0.8
0.774
0.358
0.34
0.34
0.34
0.34
0.36
0.17
0.17
0.17
0.17
0.17
0.170
0.235
0.17
0.183
0.425
0.197
0.17
0.17
0.193
0.324
0.8
0.8
0.8
0.8
0.8
0.182
0.194
0.255
0.8
0.99
0.990
0.620
0.99
0.99
0.99
0.99
0.62
0.31
0.31
0.31
031
031
0310
0.381
0.31
0.324
0.585
0.339
0.31
031
0335
0477
0.99
0.99
0.99
0.99
0.99
0.323
0.336
0.402
0.99
(a) The letter designations after the wastewater stream number indicate multiple streams are
discharged from a given process.
-------
24
impact of differences in load, Fe, and flow on the cost
effectiveness may be easier to understand when using numerous
individual models rather than only a few average models. Second,
by using all of the streams as models, the baseline emissions
will not change with changes in the regulatory alternative
applicability criteria. Conversely, changes in the applicability
criteria would change the group of streams used as the basis for
each model, and this could result in changes to the baseline
emissions.
B. Approach 2
Under approach 2, three model streams were developed to
characterize streams that meet the applicability criteria for
control under the HON. The applicability criteria are a HAP
concentration greater than or equal to 10,000 ppmv at any flow
rate or * HAP concentration greater than or equal to 1,000 ppmv
at a flow rate greater than or equal to 10 liters per minute.
Characteristics for these three model streams are shown in
Table 10.
Examination of the flow rates and HAP loads for the
wastewater streams in Table 9 shows that a total of 27 of the 72
wastewater streams exceed the applicability cutoffs for the HON.
Based on the estimated population of these 22 processes at the
surveyed and modelled plants (Table 8), wastewater streams from
40 processes would need to be controlled (note that streams from
processes 13 through 21 at the surveyed plants are already
controlled). In situations where a facility generates multiple
wastewater streams, an aggregated stream was developed for use in
costing analyses. For example, streams 29, 30, 31, and 32 were
aggregated for surveyed plant 15; streams 37 and 38 were
aggregated for surveyed plant 21; and streams 42, 43, and'44 were
aggregated for surveyed plant 22. These streams were not
aggregated for a model plant because no information is available
to suggest that multiple processes similar to those at any of the
surveyed plants would be located at any other individual plant.
However, streams 13a, 14a, and 15a were combined for a single
model plant because these streams are generated by flexible
-------
25
TABLE 10. CHARACTERISTICS OF MODEL WASTEWATER STREAMS
Parameters
Flow rate, gal/yr
HAP loading, Mg/yr
HAP concentration, ppmw
Process operating time, hr/yr
Uncootrolled emissions, Mg/yr
Number of POD's
Models
LFr
9,000,000
278
8,200
6,100
66
10
HFr
2,500,000
91.4
9,700
4,000
57
11
HW
20,500
1.1
14,400
820
0.255
9
processing equipment that is used to produce three similar
products at a surveyed plant; it was assumed that similar
flexible operating equipment would exist a a model plant.
Similarly, streams from processes 19, 20, and 21 were aggregated.
Aggregating the streams from multiple processes at a plant
resulted in 30 wastewater streams to control. The
characteristics of these 30 streams are shown in Table 11. These
30 streams were classified into three groups. The first group
consists of streams with HAP's that only have high Fr values.
The second group contains streams with at least one HAP that has
a. low Fr value. The third group contains small-volume streams
for which disposal as <* hazardous waste was determined to be less
costly than on-site treatment in a steam stripper.7 These three
groups are represented by models LFr, HFr, and HW, respectively.
As shown in Table 10, 10 streams were represented by model LFr,
11 streams were represented by model HFr, and 9 streams were
represented by model HW.
The characteristics of the models in Table 10 were based on
the characteristics of the streams in the three groups in Table
11. The HAP loads, process operating hours, and uncontrolled
emissions for all three models, and the wastewater flow rate for
-------
TABLE 11. CHARACTERISTICS OF AGGREGATED WASTEWATER STREAMS
Model stream
I3a, I4u, and
I5a
I7b
1Kb
26
27
32
29, 30. 31,
and 32
Process operating
time, hr/yr
8.136
7.176
7.176
8.760
792
5,784
S.784
Plow, gal/yr
6.990.000
5.040,000
2.960.000
4.000,000
120.000
1. 857,000
1.866.000
Load. Mg/yr
158
479
281
51.3
13.6
10.7
11.6
Average Fe
056
0.64
0.64
0.48
0.8
0.8
0.8
Uncontrolled
emissions. Mg/yr
89.0
306
180
24.6
10.9
8.57
9.31
Average Fr
0.99
0.99
0.99
0.95
0.99
0.99
0.99
Nationwide
number of
streams
1
1
1
3
2
1
2
16&, b
20
19. 20. and 21
37e,f,g.j. k
38a
37e, f. g, j, k,
and38a
42
43
44
42. 43, and 44
7.104
3.S88
7.776
8.400
4,056
8.400
8,760
1,946
2,496
8.760
5,600,000
1.819.000
10.700.000
40,357,000
5,250.000
45.607,000
3,513.600
885.600
695.700
5.095.000
1,144
8.94
52.6
485
90.9
576
143
35.9
34.1
213
0.286
0.387
0.387
0.193
0.193
0.193
0.182
0.194
0.255
0.196
326
3.46
20.4
93.4
17.5
III
26.1
6.98
870
41.8
0.441
0.544
0.544
0.335
0.335
0.335
= 0.323
0.336
0.402
0.338
1
1
1
1
1
1
1
1
1
1
7
23
29
30
31
904
1.170
840
96
192
11.600
47.000
5.62S
1.028
2.0S6
1.23
1.81
0.349
0.192
0.385
0.17
0.17
0.8
0.8
0.8
0.209
0.308
0.279
0.154
0.308
0.31
0.31
0.99
0.99
0.99
3
3
1
1
1
10
-------
27
model HW, were based on the average values of these parameters
from the streams that they represent.
The wastewater flow rates for models LFr and HFr were
estimated using values that resulted in approximately the same
nationwide control cost as the sum of the costs to control
wastewater streams from the individual processes. Algorithms
used to estimate costs are described in the cost impacts
memorandum.7 As shown in Table 8, wastewater flow rates varied
over a wide range. Because the relationship between flow rate
and total annual cost is not linear, using arithmetic mean
flowrates in the models resulted in overstated nationwide costs,
and median flowrates resulted in understated costs. Therefore,
values between the arithmetic mean and median values were
selected. The HAP concentrations were calculated based on the
load and flowrate for the model.
VI. Bag Dumps and Product Dryers
Only two surveyed facilities had particulate (PM) HAP
emissions from bag dumps and product dryers; both were controlled
to the level of the MACT floor.4 Any other facilities in the
industry that have PM HAP emissions from bag dumps and product
dryers were assumed to be controlled to the same level.
Therefore, no model bag dumps or product dryers were developed.
VII. Model Plants for S?"?tinq Sources
This section describes the procedure that was used to
develop four model plants. The model plants consist of various
combinations of the model process vents, equipment components,
storage tanks, and wastewater systems that were developed in
sections II through V. The components of each model plant are
shown in Table 12.
The procedure used to develop the model plants consisted of
three basic steps. First, each of the actual emission points at
the 20 surveyed plants was represented with a model emission
point, and the plants were categorized into groups with similar
characteristics. Second, the distribution of model processes at
the 58 modelled plants was estimated. Third, model emission
points were assigned to each of the model plants to achieve two
-------
28
TABLE 12. MODEL PLANT CHARACTERISTICS
Model emission points
No. of model plants
nationwide
No. of model emission points
per model plant
A
26
B
12
c
15
D
5
Totala
58
Process vents
Model No. 1
Model No. 2
Model No. 3
Model No. 4
1
0
0
0
0
1
0
0
1
0
1
0
1
2
0
2
46
22
15
10
Equipment leaks
Model batch process
Model continuous process
1
0
2
0
2
1
3
2
95
25
Storage tanks
Model IB
Model 2B
Model 3B
1
0
0
0
0
0
0
0
1
0
1
0
26
5
15
Wastewater streams
Model LFr
Model HFr
Model HW
0
0
0
0
1
0
0
0
1
1
0
0
5
12
15
aTotals for the model emission points are calculated using
the total number of model plants multiplied by the number of
model emission points.
-------
29
objectives: (1) that the characteristics of the model plants be
as consistent as possible with the average characteristics of the
groups of surveyed plants and (2) that the nationwide population
and distribution of emission points using the model plants be
similar to the nationwide population and distribution of the
individual model emission points developed in sections II through
V of this memorandum. These steps are described in more detail
below.
The first step in developing the model plants was to assign
model processes, equipment component counts, storage tanks, and
wastewater systems to each of the actual corresponding types of
emission points at the 20 surveyed plants. Each of the model
emission points characterize emission points that would be needed
to implement controls to meet the proposed standards.4 Model
processes were assigned to each surveyed process with
uncontrolled organic HAP emissions *0.15 Mg/yr (s330 Ib/yr)
and/or HC1 emissions *6.8 Mg/yr (7.5 tons/yr); all surveyed
processes were included because all processes at the modelled
plants were assumed to have organic HAP controls below the level
of the standard. Model equipment component counts were assigned
to each of the 88 surveyed processes that had organic HAP
emissions, regardless of the level. Model storage tanks were
assigned to represent storage tanks that would need to add
controls to meet the MACT floor; thus, only three of the nine
model tanks were needed. Model wastewater streams were assigned
to represent each wastewater stream that meets the concentration
and load criteria described in section V.B. The plants were then
categorized into four groups with similar characteristics. These
four groups are shown in Table 13.
The second step was to determine the number of processes at
each of the 58 modelled plants. As noted in Section II, the 58
modelled plants were assumed to have an average of two processes
per plant, for a total of 116 processes. To approximate two
processes per plant, 52 percent of the 58 plants were assumed to
have one process (30 plants), 31 percent have two processes (18
plants), and 17 percent have 5 processes (10 plants). This
-------
TABLE 13. BASIS FOR MODEL PLANTS
Group
I
II
III
IV
Surveyed
plants
6
16
19
10
13
20
5
7
9
IS
1
3
8
II
12
14
17
21
22
23
No. of actual processes with uncontrolled organic
HAP emissions >0.15 Mg/yr and/or HCI emissions
>6.8 Mg/yr represented by each model process
1
>
1
0
X
I
0
1
0
3
0
2
I
1
1
S
0
6
6
3
2
0
X
0
0
0
0
1
0
1
0
0
I
1
X
2
0
1
1
5
2
3
0
X
0
0
X
0
1
1
0
0
4
0
0
X
0
0
3
0
1
0
4
0
X
0
1
0
0
0
0
1
0
0
1
2
1
1
0
0
0
1
1
Total
2
2
2
3
4
4
4
9
4
S
4
7
13
6
Total No. of
processes
for
equipment
leaks"
1
0
1
2
2
2
2
2
1
10
4
9
3
9
4
5
4
7
12
8
No of storage tanks subject to
control represented by each
model tank"
IB
0
0
0
0
1
2
0
0
0
0
0
0
0
2
0
'•o
0
2
0
0
2B
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2
0
0
0
0
0
3B
0
0
0
0
0
0
0
0
0
0
0
0
1
1
0
0
0
0
0
2
Total
0
0
0
0
1
2
0
0
0
0
0
0
1
3
2
0
0
2
0
2
No. of processes with
wastewater streams
subject to control and
represented by each
model wastewaler
stream6
1
0
0
0
0
1
0
0
0
0
0
0
1
0
4
1
0
0
2
3
0
2
0
0
0
0
0
0
0
0
0
4
0
0
0
5
0
1
0
0
0
0
Total
0
0
0
0
1
0
0
0
0
4
0
1
0
9
1
1
0
2
3
0
u>
o
8At some plants, the number of processes for equipment leak emissions is less than the number of processes for process vent emissions because one or more
processes has only HCI emissions.
"Storage tanks subject to control have uncontrolled emissions S250 Ib/yr and existing control levels <9S percent. Of the nine model tanks, only models IB.
2B. and 3B represent tanks at the surveyed plants that meet die criteria for control.
^Wastewaler streams subject to control meet the concentration and load criteria specified in Section V.
"An "x" denote uncertainty about which model characterizes the given process.
-------
31
distribution is similar to the distribution in the 1986 OW
survey.3 Data from the surveyed plants were extrapolated to
estimate that only 93 of the 116 processes have uncontrolled
organic HAP emissions aO.15 Mg/yr (z330 Ib/yr) and/or
uncontrolled HC1 emissions *6.8 Mg/yr (7.5 tons/yr). The
estimated distribution of these 93 processes at the 58 plants is
shown in Table 14. The 38 plants with 1 process were split
between model plants A and B in Table 11 in such <* way as to
achieve approximately the same number of model processes no. 1
and no. 2 as in Table 3.
Although there are similarities among plants in each of the
groups in Table 13, there are also many differences. Model
•plants based simply on the most prevalent characteristics in each
group would have a distribution of emission points that is
inconsistent with the distribution developed in sections II
through V of this memorandum. Therefore, the third step was to
assign model emission points in such a way that the two
approaches result in approximately the same total number and
distribution of emission points. The number of model processes
assigned to model plants A, B, and C was based on the average
number of processes at the surveyed plants in groups I, II, and
"III; model plant D was assigned five processes instead of the
average of six at the surveyed plants in group IV because (1) the
analysis above estimated five processes for the largest model
plant and (2) five is the median number of processes at the
surveyed plants in group IV. Distributing model processes among
the model plants in the same ratio as at the surveyed plants did
not result in the correct nationwide distribution of model
processes; therefore, assignments were adjusted as necessary to
achieve the correct nationwide distribution. Model processes for
equipment leak emissions correlated with the model processes at a
model plant, except that an extra batch process was added to
model plants B and C to account for processes with process vent
emissions below the 0.15 Mg/yr threshold.
At the surveyed plants, storage tanks were concentrated at
plants in group IV. If the same distibution were used at model
-------
32
TABLE 14. DISTRIBUTION OF PROCESSES AT MODEL PLANTS
No. of
processes
per plant
1
2
5
Total
No. of model
plants
nationwide
30
18
10
58
Total No. of
processes
nationwide
30
36
SO
116
Nationwide No. of plants with
processes that emit organic HAP
£0.15 Mg/yr
1 process
per plant
30
8
0
38
2 processes
per plant
0
10
5
IS
5 processes
per plant
0
0
5
5
Nationwide No. of
processes that emit
organic HAP
2s 0.1 5 Mg/yr
30
28
35
93
-------
33
plants, the nationwide number of tanks would be under
represented. Therefore, one model tank was also assigned to
model plants A and C.
At the surveyed plants, most of the wastewater streams (17
out of 22) were at plants in group IV; the others were at plants
in groups and III. Assigning most of the model streams to model
plant D would under represent the number of wastewater streams.
Therefore, model plant B was assigned a model wastewater stream.
These model wastewater stream assignments result in approximately
the correct total number of wastewater streams, but the
distribution is biased towards model stream 3.
Table 15 compares the nationwide number of model emission
points developed by the two approaches. Because there are
differences, the nationwide cost and environmental impacts also
would be different for the model plants than for the sum of the
individual model emission points. However, the model plants
should characterize the range of plants in the industry,
especially those with few processes.
VIII. Model Plants for New Sources
The four model plants used to characterize existing sources
were also used to characterize new sources, but the nationwide
allocation of each model is lower for new sources. Average
annual growth rates in PAI sales in the five years after the
standards are promulgated were estimated to be about 2 percent.
This rate translates into a total of 8 new facilities that would
be subject to the standards (78*(l.025-l)»8).8 It was assumed
that the plant size distribution for new sources would be the
same as for existing sources. Thus, the model plants were
allocated as follows: three of model plant A, two of model plant
B, two of model plant C, and one of model plant u.
-------
34
TABLE 15.
COMPARISON OF TOTAL MODEL EMISSION
POINTS BY TWO APPROACHES
Model emission point
No. of model emission points
Individual
emission
point basis
Model plant
basis
Process vents
Model No. 1
Model No. 2
Model No. 3
Model No. 4
48
19
14
12
46
22
15
10
Equipment leaks
Model batch process
Model continuous process
90
26
95
25
Storage tanks
Model IB
Model 2B
Model 3B
26
6
12
26
5
15
Wastewater systems
Model LFr
Model HFr
Model HW
10
11
9
5
12
15
-------
35
IX. References
1. Memorandum from K. Schmidtke, MRI, to L. Banker, EPA:BSD.
November 27, 1996. Estimation of the Number of Affected
Sources in the Production of Pesticide Active Ingredient
Source Category.
2. Memorandum from D. Randall and K. Schmidtke, MRI, to
L. Banker, EPA:BSD. April 15, 1997. Summary of Data from
Responses to Information Requests and Site Visits for the
Pesticid Active Ingredient Production Industry.
j. U. S. Environmental Protection Agency. Development Document
for Best Available Technology: Pretreatment Technology, and
New Source Performance Technology for the Pesticide Chemical
Industry. Washington, DC, Office of Science and Technology.
EPA Publication No. EPA-821/R-92-005. April 1992. p. 3-60.
4. Memorandum from D. Randall and K. Schmidtke, MRI, to
L. Banker, EPA:BSD. April 30, 1997. MACT Floor and
Regulatory Alternatives for the Pesticide Active Ingredient
NESHAP.
3. Memorandum from D. Randall, MRI, to L. Banker, EPA:BSD.
April 30, 1997. Procedure to Estimate Characteristics and
Population of Dilute and Concentrated Streams for Model
Processes.
6. Protocol for Equipment Leak Emission Estimates. U. S.
Environmental Protection Agency. EPA-453/R-95-017.
November 1995. p. 2-12.
7. Memorandum from D. Randall and K. Schmidtke, MRI, to
L. Banker, EPA:BSD. April 30, 1997. Cost Impacts of
Regulatory Alternatives for the Pesticide Active Ingredient
NESHAP.
B. Memorandum from K. Schmidtke, MRI, to L. Banker, EPA:BSD.
January 6, 1997. Growth Projections for the Pesticide Active
Ingredient Manufacturing Industry.
-------
MIDWEST RESEARCH INSTTTUT.
Suite 3SC
401 Harrison Oaks Boutevarc
Gary. North Carolina 27513-241«
Telephone (919) 677-0245
FAX(919)677-006£
Date: April 30, 1997
Subject: Baseline Emissions for the Pesticide Active Ingredient
Production Industry--Pesticide Active Ingredient
Production NESHAP
EPA Contract No. 68D60012; Task Order No. 0004
BSD Project No. 93/59; MRI Project No. 4800-04
From: David Randall
Karen Schmidtke
Charlie Hale
To: Laiit Banker
ESD/OCG (MD-13)
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
±. Introduction
The purpose of this memorandum is to present the estimated
baseline HAP emissions for the pesticide active ingredient (PAX)
production industry. The emissions were calculated for five
types of emission points: process vents, equipment leaks,
storage tanks, wastewater systems, and bag dumps and product
dryers. The emissions are for an estimated 78 sources
nationwide.
For each type of emission point, site-specific emissions
are presented for 20 plants that responded to EPA information
requests (i.e., "surveyed" plants). Also presented are
nationwide emissions for models that represent the emission
sources at the other 58 plants.
Table 1 shows the estimated total baseline emissions are
about 6,750 Megagrams per year (Mg/yr) (7,450 tons per year
[tons/yr]). Baseline emissions from equipment leaks account for
approximately half of the total. Combined, emissions from
process vents and wastewater systems account for the other half.
Emissions from storage tanks and bag dumps and product dryers
account for less than 1 percent of the total baseline emissions
from PAI production plants.
-------
TABLE 1. BASELINE HAP EMISSIONS IN THE PAI
MANUFACTURING INDUSTRY
Emission source
Process vents
Equipment leaks
Storage vessels
Wastewater systems
Bag dumps and
product dryers
Total
Baseline HAP emissions
Mq/yr
1,770
3,410
37.3
1,530
8.5
6,750
Percent of total
26
50
0.6
23
0.1
100
The remainder of this memorandum is divided into six
sections. Sections II through VI provide additional details
about the emissions from each of the five types of emission
points. The procedures used to estimate the emissions are also
presented in Sections II through VI. Section VII lists the
references.
II. Process Vents
Table 2 shows the uncontrolled and baseline emissions from
process vents at PAI production plants. For the surveyed plants,
the emissions are based on the actual emissions that were
reported for all of the processes at each plant.1
For the modelled plants, the uncontrolled emissions per
model process and the estimated population of each of the four
model processes are presented in the model plants memorandum.2
The product of these values yields the nationwide uncontrolled
emissions per model process that are shown in Table 2. The
control efficiency for organic HAP for the model processes was
estimated to be 80 percent; this control efficiency is equal to
the arithmetic mean control efficiency for 72 processes with
organic HAP emissions of 0.15 Mg/yr (0.17 ton/yr) or greater at
the surveyed plants (i.e.. processes that were used as the basis
for the model processes).
A similar method was used to estimate the combined HC1 and
chlorine (HC1) control efficiencies for the model processes.
Sixteen of the surveyed processes had HC1 emissions equal to or
greater than the MACT floor applicability cutoff of 6.8 Mg/yr
(7.5 ton/yr).1'3 The average control efficiency for these
processes was over 93 percent; this value is close to the MACT
floor control level of 94 percent.3 Therefore, the 16 processes
were divided into two groups. Eleven processes with HC1 control
-------
TABLE 2. BASELINE HAP EMISSIONS FOR PROCESS VENTS
Plant
1
3
5
6
7
8
9
10
11
12
13
14
15
16
17
19
20
21
22
23
Model proceM 1
Model procen 2
Model proceii 3
Model proce*i 4
Uncontrolled emissions, Mg/yr
Organic
171
52.9
52.8
16.5
45.8
219
18.2
31.3
392
276
18.9
9.96
2.71
0
224
34.3
82.0
166
2,420
130
658
760
574
1,220
HCI
0.790
9.00
0
0
0
34.5
530
0
2.06
105
0
0
0.160
0
0
0
0
12.0
3,300
152
0
1,260
0
3,540
Other
0
0
0
0
0
0
0
1.39
0
7.71
0
0
- 0
0
0
0
0.090
0
0
0
0
0
0
0
Control efficiency, percent
Organic
41.5
94.7
1.68
90.0
70.6
93.3
98.0
26.4
75.7
96.6
96.5
98.0
1.0
N/A
96.3
99.5
99.0
58.4
98.0
76.8
80
80
80
80
HCI
50.0
99.0
N/A
N/A
N/A
91.1
99.9
N/A
99.0
98.8
N/A
N/A
0
N/A
N/A
N/A
N/A
80.4
91.1
98.9
N/A
a
N/A
b
Baseline emissiona, Mg/yr
Organic
99.9
2.87
51.9
1.65
13.5
14.6
0.360
23.0
95.1
9.63
0.670
0.20
2.68
0
8.30
0.17
0.950
69.0
48.6
30.2
131
152
115
244
HCI
0.400
0.090
0
0
0
3.21
0.53
0
0.020
1.21
0
0
0.160
0
0
0
0
2.36
294
1.58
0
88
0
260
Other
0
0
0
0
0
0
0
0.274
0
0.0086
0
0
0
0
0
0
0.090
0
0.300
0
0
0
0
0
Total 7,580 8,940 9.19 1.120 650 0.37
Ul
*Of the 19 model 2 processes, 13 (69 percent) model processes are controlled to 99 percent and 6 pi percent) are controlled to 80 percent.
^Of the 12 model 4 processes, 8 (69 percent) are controlled to 99 percent and 4 (31 percent) are controlled to 80 percent.
-------
efficiencies over 94 percent were in one group, and five
processes with HC1 control efficiencies below 94 percent were in
the second group. The average HC1 control efficiencies for the
two groups were 99 and 80 percent, respectively. Therefore, for
the models with HC1 emissions (models 2 and 4), approximately
69 percent are controlled to 99 percent, and 31 percent are
controlled to 80 percent.
III. Equipment Leaks
Table 3 shows the uncontrolled and baseline emissions from
equipment leaks at PAI production plants. For the surveyed
plants, uncontrolled emissions for equipment leaks were
calculated by two procedures. The first procedure was used for
the 30 processes for which equipment count data were available.
Emissions from most of these processes were calculated using
actual equipment counts and actual operating hours. When actual
operating hours were not available for a process, the emissions
were estimated using average operating hours (i.e., the hours
from the equipment leak models) . In all but one case, the
uncontrolled emissions were based on average SOCMI emission
factors. Light liquid factors were used for liquid valves and
pumps because each process with organic HAP in the process fluid
had at least one compound that would satisfy the vapor pressure
condition for light liquid service. Two processes with only
inorganic HAP in the process fluid were assumed to have no
equipment leak emissions. The exception to the use of SOCMI
average emission factors was for one plant that provided initial
leak rates for some components, which could be used in the
average leak rate equations. Detailed calculations for each
process are provided in the attachment to this memorandum. The
second procedure was based on the use of model equipment counts
and operating hours and average SOCMI emission factors. The
model plant memorandum presents the component counts for the
batch and continuous models; it also gives the number of
processes that were represented with each model.
Baseline emissions for six of the surveyed plants were
estimated based on information about leak detection and repair
(LDAR) programs that were implemented for some or all of their
processes. The methodology used to estimate the baseline
emissions varied depending on the specifics of the LDAR program
in use. When the plant implemented an LDAR program with
requirements at least as stringent as those under phase III in
40 CFR part 63 subpart H, the control effectiveness was estimated
to be 92 percent for gas valves, 88 percent for light liquid
valves, 75 percent for pumps, and 93 percent for connectors.5'7
When the leak definition and monitoring frequency of the LDAR
program corresponded with guidance in the CTG on equipment leaks
for SOCMI and polymer production equipment, the control
effectiveness was estimated to be 64 percent for gas valves,
44 percent for light liquid valves, 33 percent for light liquid
pumps, and no control for connectors.8 Baseline emissions for
-------
TABLE 3. BASELINE HAP EMISSIONS FOR EQUIPMENT LEAKS
Plant
Uncontrolled
emissions ,
Mg/yr
Control
efficiency, %
Baseline
emissions,
Mg/yr
Surveyed plants
1
3
5
6
7
8
9
10
11
12
13
14
15
16
17
19
20
21
22
23
Models
Model 1
Model 2
56.8
137
48.1
0.56
57.7
69.0
14.2
90.6
242
80.4
22.7
56.7
107
Oa
128
11.3
22.7
79.4
136
126
30.5
0
0.7
0
0
0
24.6
76.1
0
0
0
0
76.5
N/A
90.2
0
0
0
0
0
1,020
1,200
0
0
39.5
137
47.8
0.56
57.7
69.0
10.7
21.6
242
80.4
22.7
56.7
25.1
Oa
12.6
11.3
22.7
79.4
136
126
1,020
1,200
Total 3,700 3,410
aThe only HAP used at this plant is a granular organic raw
material.
-------
the other 14 surveyed plants were assumed to be the same as the
uncontrolled emissions. Detailed calculations for each process
at these six plants are provided in the attachment to this
memorandum.
The uncontrolled equipment leak emissions from the
116 processes at the 58 model facilities were estimated using the
equipment leak models and the estimated population of these
models that are presented in the model plant memorandum. The
product of these values gives the nationwide uncontrolled
emissions per model, as shown in Table 3. The control efficiency
for the models was assumed to be 0 percent for two reasons.
First, the average control efficiency of the five surveyed plants
that were not used in the MACT floor determination was only
7 percent. This efficiency is much lower than would be expected
with any existing control programs such as those in the 1984 CTG,
Subpart W, or the HON.7'9 Second, many of the surveyed plants
were selected on the basis that they were likely to be better
controlled than the rest of the industry; thus, even 7 percent
may be high. Therefore, baseline emissions were estimated to be
equal to the uncontrolled emissions.
TV. storage Tanks
Three approaches were evaluated for determining the
baseline HAP emissions from storage tanks in the PAI production
industry. Each approach uses the actual emissions for the
storage tanks at the surveyed plants and estimated emissions for
model storage tanks at the modelled plants. The estimates differ
under the three approaches because different methodologies were
used to estimate current control efficiencies for the model
storage tanks. The methodologies for the three approaches are as
follows:
l. Assume the control efficiency for modelled tanks is
0 percent;
2. Assume the average control efficiency for tanks at
surveyed plants is representative of the efficiency for modelled
storage tanks; or
3. Assume the average control efficiency for surveyed
storage tanks not at the top 12 percent facilities, i.e., the
average efficiency at non-MACT floor plants, is the control
efficiency at each of the modelled tanks.
The number of storage tanks and their uncontrolled
emissions and other characteristics were developed in separate
analyses. The surveyed plants reported a total of 82 storage
tanks that contain organic HAP. Nine model storage tanks were
developed to represent an estimated total of 238 storage tanks at
the modelled plants.
Approach 1 would overestimate the baseline emissions
because it is unlikely that the 11 surveyed plants with storage
-------
tank controls are the only plants in the industry that control
storage tank emissions. If all of the modelled storage tanks
were assumed to be uncontrolled, the baseline emissions would be
172 Mg/yr (190 ton/yr).
The second approach would provide an average control
efficiency for each of the nine model storage tanks and a lower
estimate of baseline emissions than Approach 1. Under this
approach, control efficiencies for B and C models range from
0 percent to 50 percent. The average control efficiency for A
models was estimated to be 95 percent. The baseline emissions
would be 37.3 Mg/yr (41.1 ton/yr) with this approach.
Approach 3 was developed because it was expected that the
control efficiencies might be lower at the non-MACT floor plants.
However, the average control efficiencies for the 40 tanks at the
non-MACT floor plants and the 42 tanks at the MACT floor plants
are actually similar. The control efficiencies are similar
because storage tank emissions make up such a small portion of a
plant's overall emissions that they do not affect a plant's
overall HAP control efficiency or its overall ranking in the MACT
floor analysis. As a result, the baseline emissions for
Approaches 2 and 3 are similar. The baseline emissions for
Approach 3 would be 36.5 Mg/yr (40.2 ton/yr).
Approach 2 is believed to be the simplest, most reasonable
approach and was used to estimate the baseline emissions from the
modelled storage tanks. Table 4 provides the baseline emissions
from the 82 surveyed storage tanks and the 238 modelled storage
tanks. The baseline emissions level for tanks is 37.3 Mg/yr
(41.1 ton/yr). These emissions are approximately two orders of
.magnitude lower than the emissions from process vents, equipment
'leaks, and wastewater systems.
V. Wastewater Systems
Table 5 shows the uncontrolled and baseline emissions from
wastewater systems at surveyed and modelled PAI production
plants. Uncontrolled emissions for the surveyed plants were
based on the fraction of the reported loading with a potential to
volatilize from the water. The reported loadings and calculated
uncontrolled emissions were presented in the data summary
memorandum.1 Baseline emissions for 15 of the surveyed plants
were assumed to be the same as the uncontrolled emissions because
only biotreatment or no treatment was received before discharge
(one of the 15 plants did not provide loading data). Three of
the surveyed plants used incineration or either steam or air
stripping followed by incineration to treat some or all of the
wastewater. The methodology used to calculate the controlled
emissions for wastewater streams at these three plants was also
described in the data summary memorandum.1 Wastewater streams at
two of the surveyed plants contained no HAP.
-------
8
TABLE 4. BASELINE HAP EMISSIONS FOR STORAGE VESSELS
Model
Number
of tanki
Toul
uncontrolled
•minion*,
Mg/yr
Control
efficiency,
p0TMflt
BMeline
eminioiu,
Mg/yr
Surveyed plant*
Bub of
Model 1-A
(9tanka)
Batii of
Model 1-B
punka)
Baii* of
Model 1-C
(23unk»)
Basil of
Model 2-A
(Sunki)
Baiii of
Model 2-B
(2 lank*)
Bamof
Model 2-C
(1 1 Unit*)
Baiiiof
Model 3-A
(12 unk»)
Buiiof
Model 3-B
(4unkf)
Bail* of
Model 3-C
(4 lute)
9
5
1
I
1
1
12
1
3
1
S
1
8
2
9
2
4
1
3
1
2
2
5.76
1.24
0.553
0.231
0.118
0.260
0.204
0.0456
0.121
0.0451
0.241
0.0555
3.34
1.10
0.134
0.0512
33.1
6.49
2.43
1.08
0.165
0.125
98
0.0
4.0
13.2
41
42
0.0
89
90
95
98
99.5
98
0.0
0.0
98
95
98
00
25
0.0
98
0.115
1.24
0.531
0.201
0.0694
0.151
0.204
0.0050
0.0121
0.0023
0.0048
0.0003
0.0669
1.10
0.134
0.0010
1.65
0.130
2.43
0.809
0.165
0.0025
Toul 56.9 9.02
Modal
Total
uncontrolled
emiaiioii*,
Mg/yr
Control
efficiency,
peccant
Baseline
amiarioni,
Mg/yr
Modeled planti
Modal 1-A
(26 unit*)
Model 1-B
(26 tank*) '
Model 1-C
(67 tank*)
Model 2-A
(23unki)
Model 2-B
(6 lank*)
Model 2-C
(32 tank*)
Model 3-A
(34 tank*)
Model 3-B
(Utanki)
Model 3-C
(12 tank*)
16.6
6.93
2.08
962
3.30
0.540
112
105
0.869
95
11
45
95
0.0
18
95
6.0
SO
0.832
6.17
1.14
0.481
3.30
0.442
5.60
9.88
0.435
163 28.3
-------
TABLE 5. BASELINE HAP EMISSIONS FOR WASTEWATER SYSTEMS
Plant
1
3
5
6
7
8
9
10
11
12
13
14
15
16
17
19
20
21
22
23
Model
wastewater
streams
Uncontrolled
emissions,
Mg/yr
6.17
1.84
2.17
0
0.835
42.5
b
0.173
931
1.26
25.1
10.9
9.35
0
29.4
11.6
0.0147
112
43.1
c
1,260
Control
efficiency, %
0
0
0
N/A
0
a
c
93.2
99
0
1.9
0
0
N/A
0
0
a
0
0
0
0
Baseline
emissions,
Mg/yr
6.17
1.84
2.17
0
0.835
0
b
0.0117
9.31
1.26
24.7
10.9
9.35
0
29.4
11.6
0
112
43.1
C
1,260
Total 2,490 1,530
^Deep-well injection, 100 percent control efficiency.
"Less than 5 ppmw.
GNo data provided.
-------
10
The uncontrolled emissions per model wastewater stream and
the estimated population of each model stream are presented in
the model plant memorandum.2 These data were used to estimate
nationwide uncontrolled emissions of 1,260 Mg/yr (1,390 ton/yr)
for the modelled portion of the industry, as shown in Table 5.
The control efficiency of treatment systems for the model streams
was assumed to be zero percent. This value was selected because
the control efficiency was zero for most of the surveyed
facilities, including 8 of the 11 plants that were not used in
the MACT floor analysis (of the other three, one had a control
efficiency of 93 percent, one had a control efficiency of
2 percent, and one had no HAP in its wastewater) . Thus, baseline
emissions for wastewater streams at the model plants were
estimated to be equal to the uncontrolled emissions.
Table 6 presents the nationwide emissions for all
45 processes with wastewater streams at both the surveyed and
model plants. The model plant memorandum describes the basis for
uncontrolled emissions and the population of each model stream.
Streams for which the baseline emissions are lower than the
uncontrolled emissions represent the controlled streams at
surveyed plants 10, 11, and 13.
VI. Bag Dumps and Product Dryers
Two of the surveyed plants emitted particulate matter HAP;
one facility emitted from a product dryer, and the other emitted
from a raw material bag dump.1 The total emissions from these
two plants was 8.5 Mg/yr (9.3 tons/yr). Because they were
uncommon at the surveyed plants, no bag dumps or product dryers
were included in the model plants analysis. Therefore, the
nationwide baseline emissions from bag dumps and products dryers
was estimated to be equivalent to the emissions from the surveyed
plants.
-------
TABLE 6. BASELINE EMISSIONS FOR MODEL WASTEWATER STREAMS
Wastewater
stream
model
number
12
39
36
28
6
11
30
4
29
31
3
45
33
24
41
40
22
9
2
7
23
5
25
1
8
20
32
27
Number of wastewater streams
Surveyed
plants
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Modelled
plants
1
1
1
1
1
1
2
2
2
2
2
2
2
2
2
2
2
Total
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
3
Uncontrolled emissions, Mg/yr
Surveyed
plants
0.00319
0.0254
0.0147
0.0406
0.0294
0.169
0.154
0.185
0.279
0.308
0.308
0.316
0.330
0.319
0.502
0.527
0.637
0.835
0.740
0.209
0.308
1.61
0.540
4.94
2.17
3.46
8.57
10.9
Modelled
plants
0.00319
0.0254
0.0147
0.0406
0.0294
0.169
0.154
0.185
0.279
0.308
0.308
0.316
0.330
0.319
0.502
0.527
0.637
1.67
1.48
0.418
0.617
3.21
1.08
9.87
4.34
6.93
17.1
21.8
Total
0.00639
0.0509
0.0294
0.0813
0.0588
0.338
0.308
0.370
0.559
0.615
0.617
0.631
0.661
0.639
1.00
1.05
1.27
2.50
2.22
0.627
0.925
4.82
1.62
14.8
6.51
10.4
25.7
32.7
Baseline emissions, Mg/yr
Surveyed
plants
L 0.00319
0.0254
0
0.0406
0.0294
0.00846
0.154
0.185
0.279
0.308
0.308
0.316
0.330
0.319
0.502
0.527
0.637
0.835
0.740
0.209
0.308
1.61
0.0540
4.94
2.17
0.0346
8.57
10.9
Modelled
plants
0.00319
0.0254
0.0147
0.0406
0.0294
0.169
0.154
0.185
0.279
0.308
0.308
0.316
0.330
0.319
0.502
0.527
0.637
1.67
1.48
0.418
0.617
3.21
1.08
9.87
4.34
6.93
17.1
21.8
Total
0.00639
0.0509
0.0147
0.0813
0.0588
0.178
0.308
0.370
0.559
0.615
0.617
0.631
0.661
0.639
1.00
1.05
1.27
2.50
2.22
0.627
0.925
4.82
1.13
14.8
6.51
6.96
25.7
32.)
-------
TABLE 6. BASELINE EMISSIONS FOR MODEL WASTEWATER STREAMS (CONTINUED)
Wastewater
stream
model
number
10
13
21
44
35
43
26
15
34
14
38
42
10
18
17
37
16
Total
Number of wastewater streams
Surveyed
plants
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Modelled
plants
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Total
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
Uncontrolled emissions, Mg/yr
Surveyed
plants
7.95
12.4
8.97
8.70
11.6
6.98
24.6
37.3
29.1
46.0
17.7
26.1
42.5
181
308
94.7
327
Modelled
plants
7.95
12.4
8.97
8.70
11.6
6.98
24.6
37.3
29.1
46.0
17.7
26.1
42.5
181
308
94.7
327
Total
15.9
24.9
17.9
17.4
23.2
14.0
49.2
74.7
58.2
91.9
35.4
52.2
84.9
361
615
189
653
2,490
Baseline emissions, Mg/yr
Surveyed
plants
0.0795
0.124
0.0897
8.70
11.6
6.98
24.6
0.373
29.1
0.460
17.7
28,1
0
1.81
3.08
94.6
3.27
Modelled
plants
7.95
12.4
8.97
8.70
11.6
6.98
24.6
37.3
29.1
46.0
17.7
26.1
42.5
181
308
94.7
327
Total
8.03
12.6
9.05
17.4
23.2
14.0
49.2
37.7
58.2
46.4
35.4
52.2
42.5
182
311
189
330
1,530
-------
13
VII. References
1. Memorandum from D. Randall and K. Schmidtke, MRI, to
L. Banker, EPA:BSD. April 15, 1996. Summary of Data From
Responses to Information Requests and Site Visits for the
Production of PAI NESHAP.
2. Memorandum from D. Randall and R. Schmidtke, MRI, to
L. Banker, EPA:BSD. April 30, 1997. Model Plants for the
PAI Production Industry.
3. Memorandum from D. Randall and K. Schmidtke, MRI, to
L. Banker, EPA:BSD. April 30, 1997. MACT Floor and
Regulatory Alternatives for the Pesticide Active Ingredient
Production Industry.
4. Protocol for Equipment Leak Emission Estimates. Office of
Air Quality Planning and Standards. U. S. Environmental
Protection Agency. EPA-453/R-95-017. November 1995.
p. 2-12.
5. 40 CFR Part 63, Subpart H, section 163.161.
6. Reference 4. p. 5-46.
7. Reference 4. p. 5-9.
8. Control of VOC Fugitive Emissions from Synthetic Organic
Chemical, Polymer, and Resin Manufacturing Equipment.
EPA-450/3-83-006. Office of Air Quality Planning and
Standards. U. S. Environmental Protection Agency. Research
Triangle Park, NC. March 1984.
9. 40 CFR Part 60. Subpart W.
Attachment
-------
Docket No. A-95-20
Category H-B
The following information is located in the confidential files of the Director, Emission
Standards Division, Office of Air Quality Planning and Standards, U. S. Environmental Protection
Agency, Research Triangle Park, North Carolina 27711. This information is confidential pending
final determination by the Administrator and is not available for public inspection.
Attachment to Baseline Emissions Memorandum (part of docket item II-B-21).
This attachment consists of calculated uncontrolled and controlled equipment leak
emissions for 30 processes at 8 plants. The confidential material consists of 17 pages of data.
-------
MIDWEST RESEARCH INSTITUTE
Suit* 350
401 Harrison Oaks Boulevard
Gary. North Carolina 27513-2412
Telephone (919) 677-0249
FAX (919) 677-0065
Date: April 30, 1997
Subject: Environmental Impacts for the Pesticide Active
Ingredient Production NESHAP
EPA Contract No. 68D60012; Task Order No. 0004
BSD Project No. 93/59; MRI Project No. 4800-04
From: David Randall
Karen Schmidtke
To: Laiit Banker
ESD/OCG (MD-13)
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
I. Introduction
The purpose of this memorandum is to present the
environmental impacts and the approach used to estimate the
impacts for regulatory alternatives that were developed for the
national emissions standards for hazardous air pollutants
(NESHAP) for pesticide active ingredient (PAI) production. The
environmental impacts that were estimated include (1) primary air
impacts; (2) secondary impacts, including air, water, and solid
waste; and (3) fuel and electricity impacts. The impacts are
presented for each of the five emission source types or "planks"
(i.e., process vents, equipment leaks, storage tanks, wastewater
systems, and bag dumps and product dryers).
II. Basis for Impacts Analysis
Regulatory alternatives (including the maximum achievable
control technology [MACT] floor) for existing sources are
described in detail in the MACT floor and regulatory alternatives
memorandum.1 In summary, the MACT floor was developed for all
five emission source types; one additional regulatory alternative
was developed for storage tanks, wastewater systems, and
equipment leaks; and two additional regulatory alternatives were
developed for process vents. Impacts were estimated for the MACT
floor and all regulatory alternatives. The emissions and the
model plants for each plank are described in the Data Summary,
Model Plant, and Baseline Emissions memoranda. •3•*
To comply with the regulatory alternatives for gaseous
organic HAP emissions from process vents, this analysis assumes
that PAI facilities would use thermal incinerators to control
organic HAP emissions from dilute streams; control of
concentrated streams was assumed to be achieved with refrigerated
-------
condensers. Water scrubbers (gas absorbers) were assumed to be
used to control hydrochloric acid (HC1) emissions from process
vents. Compliance with the regulatory alternatives for storage
tanks was assumed to be achieved with the installation of
internal floating roofs (IFR) for tanks with capacities greater
than or equal to 76 nr (20,000 gallons) and condensers for tanks
with smaller capacities. Compliance with regulatory alternatives
for wastewater systems was assumed to be achieved with steam
strippers. Compliance with the regulatory alternatives for
equipment leaks was assumed to be achieved by implementing a leak
detection and repair (LDAR) program. Fabric filters were assumed
to be used to control particulate matter from bag dumps and
product dryers. Emissions from bag dumps and product dryers are
already controlled to the level required by the MACT floor; there
are no environmental impacts associated with implementation of
the requirement for bag dumps and product dryers.
III. Primary Air Impacts
Primary air impacts consist of the reduction in HAP
emissions from the baseline level that is directly attributable
to the regulatory alternative. The primary air impacts for each
emission source type under each regulatory alternative are shown
in Table 1.
TABLE 1. SUMMARY OF PRIMARY AIR IMPACTS FOR MACT FLOOR AND
REGULATORY ALTERNATIVES
Emission source type
Process vents
- Organic HAP's
-HCI
Equipment leaks
Storage tanks
Wastewater systems
Bag dumps and product
dryers
Emission reduction from baseline
MACT floor,
Mg/yr
616
4S8
0
10.S
0
0
Regulatory
alternative 1, Mg/yr
714
458
3,020
20.0
934
N/A
Regulatory
alternative 2, Mg/yr
966
567
N/A
N/A
N/A
N/A
A. Process Vents
Primary air impacts for process vents at the MACT floor are
616 Mg/yr organic HAP emissions and 458 Mg/yr for HCI emissions.
Primary impacts for organic HAP and HCI emissions under
regulatory alternative 1 are 714 Mg/yr and 458 Mg/yr,
respectively. Under regulatory alternative 2, the primary
impacts are 966 Mg/yr for organic HAP emissions and 567 Mg/yr for
-------
HC1 emissions. Impacts for each process were estimated based on
the difference between the baseline control level for the process
and the control level required by the MACT floor or the
regulatory alternative. The impacts for each process under each
regulatory alternative are shown in Attachment 1.
B. Equipment Leaks
Primary air impacts for equipment leaks at the MACT floor
are 0 Mg/yr because the MACT floor is no control. Primary
impacts under regulatory alternative 1 are 3,020 Mg/yr. The EPA
protocol document for estimating equipment leak emissions
presents control effectiveness values for components that are
controlled using the LDAR program in the HON.5 These values were
applied to the baseline emissions for 14 individual processes
where the component counts were known and to the batch and
continuous model component counts for other processes. Details
of this analysis are presented in Attachment 2.
C. Storage Tanks
The primary air impacts for storage tanks under the MACT
floor are 10.5 Mg/yr for HAP emissions. Under regulatory
alternative 1, HAP emissions would be reduced by 20.0 Mg/yr. The
control levels and associated applicability cutoffs for the floor
and regulatory alternative were applied to the 82 surveyed tanks
and the 238 modelled tanks to estimate the HAP emission reduction
achieved. The emissions for each of the tanks are provided in
Attachment 3.
D. Wastewater Systems
The primary air impacts for wastewater at the MACT floor
are 0 Mg/yr (the floor is no control). Primary impacts under
regulatory alternative 1 are 934 Mg/yr. These impacts were
calculated for the 30 wastewater streams nationwide with process
wastewater streams that meet the applicability cutoffs for the
regulatory alternative.1'3 Details of this analysis are shown in
Attachment 4.
E. Bao Dumps and Product Dryers
Primary air impacts for the bag dumps and product dryers at
the MACT floor are 0 Mg/yr; emissions from this source type are
already controlled to the MACT floor level.
IV. Secondary Environmental Impacts
Secondary environmental impacts consist of any adverse or
beneficial environmental impacts other than the primary impacts
described in Section III. The secondary impacts are indirect or
induced air, water, or solid waste impacts that result from the
operation of the control system that controls HAP emissions. Use
-------
of most of the control systems described in Section II of this
memorandum will cause secondary air impacts; secondary water and
solid waste impacts, however, are expected to be minimal. The
secondary environmental impacts for both the surveyed plants and
the modelled plants were based on the use of models to represent
actual emission source types (i.e., site-specific impacts were
not estimated for the surveyed plants). The secondary air,
water, and solid waste impacts are discussed in the sections
below.
A. Secondary Air jEmpacts
Secondary air impacts consist of: (1) generation of
emissions as the byproducts of fuel combustion needed to operate
control devices, and (2) reductions in emissions of VOC
compounds. These secondary air impacts are discussed below.
Fuel combustion is necessary to maintain operating
temperatures in incinerators, to produce steam for steam
strippers, and to generate electricity for operating fans, pumps,
and refrigeration units. Byproducts of fuel combustion include
emissions of carbon monoxide (CO), nitrogen oxides (NOX), sulfur
dioxide (S02), and PM less than 10 microns in diameter (PM1Q).
Steam was assumed to be generated in small, natural
gas-fired industrial boilers. Incinerator control devices also
use natural gas as the auxiliary fuel. The estimated natural gas
consumption rates are described in Section V. Emissions from
combustion in both the boilers and incinerators were estimated
using AP-42 emission factors for small industrial boilers.6
Electricity was assumed to be generated at coal-fired
utility plants built since 1978. The estimated electricity
requirements, and the fuel energy needed to generate this
electricity, are described in Section V. Utility plants built
since 1978 are subject to the new source performance standards
(NSPS) in subpart Da of 40 CFR part 60. These NSPS were used to
estimate the PM10 and S02 emissions from coal combustion. The
NOX emissions were estimated using the AP-42 emission factor
because the emission factor is lower than the level required by
the NSPS. The CO emissions were estimated using the AP-42
emission factor because CO emissions are not covered by the
NSPS.8 The sulfur content of the coal was assumed to be
1.8 percent.
A summary of the estimated secondary air impacts that are
generated for each of the five emission source types is presented
in Table 2. Secondary air impacts are generated from operation
of thermal incinerators, condensers, and scrubbers for process
vents, condensers for storage tanks, and steam strippers for
wastewater streams. There is no generation of secondary air
impacts associated with the use of floating roofs to control
emissions from storage tanks or with the implementation of an
-------
LDAR program to control equipment leaks. In addition, no
secondary air impacts result from control of bag dumps and
product dryers because the MACT floor control level is equivalent
to baseline control. The secondary air impact calculations for
each type of emission source is provided in Attachment 5.
In addition to the generation of emissions from fuel
combustion for the operation of control devices, secondary air
impacts also include the reduction of VOC emissions. This
reduction in VOC emissions includes reduction of: (1) non-HAP
VOC emissions and (2) HAP compounds that are also VOC compounds.
The VOC compounds are precursors to ozone. The reduction of VOC
achieved by the MACT floor and regulatory alternatives can not be
quantified.
B. Secondary Water Impacts
Secondary water impacts consist of wastewater blowdown from
water scrubbers used to control HC1 emissions from process vents.
Wastewater from HC1 scrubbers is estimated to increase by
10.8 million liters per year (2.86 million gallons per year).
The amount of wastewater generated from each model scrubber is
estimated in the design and cost algorithms for scrubbers used
with each model process; these algorithms are included in the
cost impacts memorandum. A summary of the wastewater impacts is
provided in Table 3.
TABLE 3. WASTEWATER IMPACTS FROM HCL SCRUBBERS
Model
2d
2c
4d
4C
Increase in
wastewater
flowrate,
gal /yr/ scrubber
222,789
133,632
307,158
249,895
Number
of
models
5
2
4
1
Nationwide increase in
wastewater
flowrate,
gal/yr
1,113,947
267,263
1,228,631
249,895
Total 2,860,000
To simplify the analysis, one approach was used to estimate
the amount of increased scrubber blowdown for the MACT floor and
both regulatory alternatives. This approach assumes that all of
the HC1 in the gas stream is neutralized and the maximum
acceptable dissolved solids concentration in the circulatory
water is 10 weight percent.10 As a result, the estimated
-------
TABLE 2. SUMMARY OF SECONDARY AIR IMPACTS
Emisson source
type
Process vents
Equipment leaks
Storage tanks
Wastewater
systems
Bag dumps and
product dryers
Units
Mg/yr
Mg/yr
kg/yr
Mg/yr
Mg/yr
M ACT floor
CO* N0xb S02C PM,0d
100 359 228 17.S
0000
0.16 0.43 1.89 0.03
0000
0000
Regulatory alternative 1
CO* NOxb SO2C PM10d
107 378 274 18.6
0000
0.16 0.43 1.89 0.03
2.8S 11.3 0.85 0.012
N/A N/A N/A N/A
Regulatory alternative 2
CO* N0xb S02C PM10d
111 388 298 19.3
N/A N/A N/A N/A
N/A N/A N/A N/A
N/A N/A N/A N/A
N/A N/A N/A N/A
o\
*The CO emissions were estimated using AP-42 emission factors of S Ib CO/ton of coal and 35 Ib CO/10^ ft3 of natural gas.
bThe NOX emissions were estimated using AP-42 emission factors of 13.7 Ib NOx/ton of coal and 140 Ib NOX/10* ft3 of natural gas.
°The SOj emissions were estimated using the NSPS for coal-fired utility boilers of 1.2 Ib SOj/106 Btu and the AP-42 emission factor of 0.6 Ib
SCtylO6 ft3 of natural gas.
*The PMjn emissions were estimated using the NSPS for coal-fired utility boilers of 0.0? lb/10* Btu and the AP-42 emission factor of 6.2 Ib
PM10/Hr ft3 of natural gas.
-------
increase in scrubber blowdown is the same under the MACT floor
and both regulatory alternatives. This approach may overestimate
the increase in wastewater under the MACT floor and Regulatory
Alternative 1 by up to 30 percent because the baseline control
level is 80 percent, and the HC1 control level under the MACT
floor and Regulatory Alternative 1 is 94 percent, not
100 percent. However, the difference is likely to be less than
30 percent because it is expected that most controls used to
achieve the required 94 percent reduction for the floor and
Regulatory Alternative 1 will actually have much higher control
efficiencies. Similarly, the increase in scrubber blowdown under
Regulatory Alternative 2 may be overestimated by as much as 5
percent because the HC1 control efficiency under regulatory
alternative 2 is 99 percent.
The volume of wastewater generated would also increase at
plants that choose to use a water scrubber to control certain
water soluble organic HAP's; this volume was not estimated
because the use of water scrubbers is expected to be uncommon.
C. Secondary Solid Waste Impacts
Solid waste impacts are expected to be minimal. Captured
PM HAP emissions from bag dumps and product dryers are expected
to be either raw material or product that would be returned to
the process. At some plants, the overheads from a steam stripper
(i.e., the mixture of steam and volatilized organic compounds)
may be a waste that needs to be disposed of. Other plants,
however, may be able to condense the overheads and return the
condensed material to the process as either raw material or fuel.
Thus analysis assumes the waste costs at some plants are balanced
by the savings at other plants.
V. Energy Impacts
Energy impacts consist of the fuel usage and electricity
needed to operate control devices that are used to comply with
the regulatory alternatives. The estimated electricity and fuel
impacts for each of the five emission source types are presented
in Table 4. In each case, the impacts are based on the total
amount of electricity or fuel needed to operate the control
devices; electricity and fuel needs for existing controls are
assumed to be negligible. The energy impacts, like the secondary
impacts, were based on the use of models to represent both the
surveyed plants and the modelled plants. The electricity and
fuel impacts are estimated in the cost algorithms for control
devices developed for each of the models: these algorithms are
included in the Cost Impacts memorandum.9 The tables in
Attachment 5 provide the estimated electricity and fuel impacts
for each of the models and the nationwide impacts. The
electricity and fuel impacts are discussed in the sections below.
-------
TABLE 4. SUMMARY OF ENERGY IMPACTS
Emiicion source type
PVOCCM vein
MACTRoor
Regulatory Alternative 1
Regulatory Alternative 2
Equipment leaks
MACT Roor
Regulatory Alternative 1
Increase in
electricity
consumption,
kwh/yr
42.7 x 106
51. 4 x 106
56.0 x 106
Increase in steam
consumption, Ib/yr
0
0
0
0
0
0
0
Increase in fuel energy, Blu/yr
To generate
electricity
4,l60xl08
5,010 x I08
5,460 x 108
Auxiliary fuel for
incinerators
42,000 x 108
42,000 x 108
42,000 x 108
••
0
0
Storage tanks
MACT Roor
Regulatory Alternative 1
19ft
198
0
0
0.0193 x 10*
0.0193 x 108
Wastewater systems
MACTRoor
Regulatory Alternative 1
0
0.089 x 106
0
119x I06
0
8.63 x 108
0
0
0
0
To produce steam
0
0
0
': *.-^|| <'*<
0
0
f.
0
0
•' " : T.;"'v
0
0
Bag dumps and process dryen
MACTRoor
0
0
0
0
0
1,750 x 10*
Total
V.:,^:$l
46,100 x 10s
47,000 x 108
47,400 x 10* |
';*. -i#*&-jrim
•«?f: - ^':^':j
0
0
• 'Jc '•
0.0193 x 108
0.0193 x 108
"'• §x& 'V
0
1,760 x 108
• ' •/ x "
0
0
00
-------
A. Electricity
Electricity would be needed to operate control devices used
to control emissions from process vents, small storage tanks, and
wastewater systems. As noted above, electricity was assumed to
be generated in coal-fired boilers at utility plants. The amount
of fuel energy required to generate the electricity was estimated
using a heating value of 14,000 Btu/lb of coal and a power plant
efficiency of 35 percent.
Specifically, electricity would be needed to operate the
fans for incinerators, scrubbers, and condensers; the
refrigeration unit for condensers; and pumps for scrubbers,
condensers, and steam strippers. The power requirements for
these devices were estimated using procedures in the OAQPS
Control Cost Manual.11 No additional electricity would be needed
to operate floating roofs for storage tanks or to implement an
LDAR program for equipment leaks. In addition, no additional
electricity is needed to control emissions from bag dumps and
product dryers because the MACT floor is equivalent to baseline.
u. Fuel
Fuel would be needed to operate incinerators and to
generate steam for steam strippers. In both cases, natural gas
was assumed to be the fuel of choice. No additional fuel would
be needed to operate condensers for process vents, to operate
condensers or floating roofs for storage tanks, or to implement
an LDAR program for equipment leaks. In addition, no fuel would
be needed to control emissions from bag dumps and product dryers
because the MACT floor is equivalent to baseline. The fuel
requirements for each control device are included in the control
device cost algorithms, which are attachments to the Cost Impacts
memorandum.9
The amount of natural gas needed in incinerators was
estimated using mass and energy balances around the incinerators.
The operating temperature was assumed to be 1600°F. Energy
losses were assumed to be equal to 10 percent of the total energy
input. Additional details on the procedure are described in the
OAQPS Control Cost Manual.12
Steam strippers for wastewater streams were designed with
an assumed wastewater-to-steam ratio of 10.4:1. The steam was
assumed to be at 350°F and 100 psia. The enthalpy change was
estimated to be 1,180 Btu per pound of steam, assuming the feed
water to the boiler is at 50°F. The energy required to generate
the steam was estimated assuming a boiler efficiency of
80 percent. The quantity of natural gas needed to supply the
energy was estimated assuming the heating value of natural gas is
1,000 Btu per standard cubic foot.
-------
10
VI, References
1. Memorandum from D. Randall and K. Schmidtke, MRI, to
L. Banker, EPA:BSD. April 30, 1997. MACT Floor and
Regulatory Alternatives for the Pesticide Active Ingredient
Production Industry.
2. Memorandum from D. Randall and K. Schmidtke, MRI, to
L. Banker, EPA:BSD. April 15, 1997. Summary of Data from
Responses to Information Collection Requests and Site Visits
for the Production of Pesticide Active Ingredients NESHAP.
j. Memorandum from D. Randall and K. Schmidtke, MRI, to
L. Banker, EPA:BSD. April 30, 1997. Model Plants for the
Pesticide Active Ingredient Production Industry.
4. Memorandum from D. Randall and K. Schmidtke, MRI, to
L. Banker, EPA:BSD. April 30, 1997. Baseline Emissions for
the Pesticide Active Ingredient Production Industry.
5. Protocol for Equipment Leak Emission Estimates. Office of
Air Quality Planning and Standards. U. S. Environmental
Protection Agency. EPA Document No. EPA-453/R-95-017.
November 1995.
6. AP-42. 1995 Edition, pp. x.4-3 and 1.4-4.
7. 40 CFR Part 60. Subpart Da.
8. AP-42. 1995 Edition, p. J..1-3.
9. Memorandum from D. Randall and K. Schmidtke, MRI, to
L. Banker, EPA:ESD. April 30, 1997. Cost Impacts of
Regulatory Alternatives for the Pesticide Active Ingredient
Production NESHAP.
10. OAQPS Control Cost Manual. Fourth Edition.
EPA 450/3-90-006. January 1990. p. 9-53.
11. OAQPS Control Cost Manual. Fourth Edition.
EPA 450/3-90-006. January 1990. pp. 3-55, 8-30, and 9-39.
12. OAQPS Control Cost Manual. Fourth Edition.
EPA 450/3-90-006. January 1990. pp. 3-31 and 3-32.
-------
Attachment 1
-------
PROCESS VENT EMISSIONS
PAI NESHAP
F.\PROIECr\AGCHEMS\WENTS\PV-EMRED.XLS
•
N>.
••. M we M
1 1 C
1 2 C
1 3 C
1 4 C
i a c
3 7 B
J • •
3 11 •
3 12 B
3 13 B
B 14 C
• IS B
8 IB B
7 17 B
7 IB C
B IB C
B 20 B
B 21 B
B » C
B 24 B
B 2B C
10 28 B
10 27 C
11 2B B/C
11 21 B/C
11 30 BA:
11 31 B/C
11 32 B/C
11 31 C
11 34 B/C
11 16 B/C
11 3B B
12 37 B
12 36 B
12 3* C
17 4O B
13 42 B/C
14 4] B
14 44 B
CM»lnM*4 Unrtibi
miiH*m hut** MO O*w T«ul
1.11 13B OB33 0 137
O.O468 86B 002B2 0 6.86
0.1BB 18.3 00*04 0 188
0.0781 B.I 4 OO47B O 8.28
BO.B 0 O 0 BOB
0.883 000 0.883
0 O.O248 O 0 O.0246
0 0.4O3 tJOO O 8.41
0 0.782 0 0 0782
0 00878 O 0 0.0878
0 O.B1B O O 0818
42.8 8.08 0 0 61 8
O 18.6 0 0 186
0 33* 0 0 330
O1B1 128 0 O 867
O.O431 202 13.2 O 216
0.0464 IB J B BO 0 72 1
0 141 0 141
O 0 148 0 146
0 0 J68 0 368
182 O 174 0 187
OOO488 0 O 0 OOO468
31 3 O O 1 30 33 7
0 16 1 0 0 10 1
0 88.8 0 0 666
0 48.3 0 0 483
407 616 0 0 822
103 782 130 0 112
003 441 O.781 0 866
0 O.364 O 0 0.364
0 O.1B4 0 0 0.164
O 0 36* O O 0 1t»
O 466 11 O O 168
0 24.3 00001J8 771 3} O
!•• 0 81 2 0 2«fl
328 164 267 0 746
O 166 O O 18*
0 1 74 0 0 1 74
0 1 78 0 0 1 78
6i»lNl« •9MU94
Olg«n« HCI
•II.. « *H . %
416 BOO
416 6O 1
41.6 BOO
416 466
680
00
0.0
68 O 68 O
600
OO
670
00
600
680
00
638 MO
(OO BOO
800
• 1 7
68 «
86 0 66 1
668
78 a
68*
666
66*
666
61 * 660
616 660
680
68 O
680
68 O I* O
674 (CO
970 »Ub
(It ((•
*a»
• BO
tao
••••bia BMnMBjBTinBi Maht
O>l»wu* UMhbi-
•IOMM MU4 HO OIlMI T*Ul
1 11 787 0.317 O 80.1
0.046* 326 00131 O 3.31
O168 11 2 OO4B2 0 11.4
O.O761 832 0.0214 O 6.42
203 O 0 0 2.03
0863 O O 0 O.B63
0 00246 0 0 OO14B
0 OOOBO8 00*00 0 OO8B1
0 O.0760 0 0 OO78O
0 0.0878 0 0 0.0878
0 0.0272 0 0 0.0272
428 *O6 O 0 618
0 1 66 0 0 1.86
o 0880 o o o.eeo
0181 128 0 0 21.3
00431 12* 1.32 0 14.3
000464 162 0880 0 221
O 0141 O O141
0 O 1 21 0121
0 O O.366 O O.368
0 304 0 O 174 00 638
4 6K-08 O 0 4 68E-06
JI O O OOOO*07 O274 232
0 6 33 0 0 6 33
0 16 7 0 O 16 7
0 180 0 0 160
18.2 218 0 O 400
2 O6 887 O013O O 884
1 21 404 O.O0781 0 6 26
0 OO070B 0 0 000706
O OO0310 0 0 OOO110
0 OO0768 0 0 0007(8
0 00*18 0110 0 0202
0 O812 138EO8 OOOB9O 0841
6 61 O 1 03 0 6 68
0*1* 7 1* OO867 O 1 IB
0 08«B 0 0 08*8
0 O 034ft O 0 O0346
0 00361 0 0 00361
MACTFbM
n. 8m*Jil
toMr«Mnul f«4uotiM. MflV
O>|»nk» MO
882
2.73
844
4.47
0.824
48.7
11.6
0627
0.272
OS
1* 8
3 72
13.6
11.2
308
togulMMy •kicMb* 1
M.8*M*M
iMramMUl i«4uMfen. tftffl
0>M>*» HO
882
2.71
6.44
4.47
0424
60.8
11.6
0627
0.271
OJ
733
372
118
11.1
308
Bf IMVMWltfl ff)dlMtBM* MB/VV
OrgwlM . HO
77.1
3 18
11jO
8.11
1.O11
0.87*
0.082
0.008
606
1.11
128
8.81 1.16
1.11 0.811
0.111
1 1
22.3
6 O1
IBB
16.0
182
671
388
0148
1 0 0.3B8
1.16
028*
-------
PROCESS VENT EMISSIONS
PAI NESHAP
F:\PROJECT\AGCHEMS\PVENTS\PV-EMRED.XLS
L
No.
Plant Proceee modele
no. no. B/C lal
14 46 B
14 48 B
14 47 B
16 48 B
16 49 B
16 60 B
16 61 B
16 62 B
16 64 B
16 66 B
16 66 B
16 67 B
16 68 B
18 69 B
17 60 B
17 81 C
17 82 C
17 83 C
19 84 a
20 66 B
2O 88 B
21 87 B
21 68 B
21 89 B
21 70 B
21 71 B
21 72 B
21 73 B
22 74 C
22 76 B
22 76 B
22 77 B
22 78 B
22 79 B
22 80 C
22 81 B
22 82 B
22 83 B
22 B4 B
Uncontrolled emieeione. Mg/yr
Chlorirteted Unchtor-
orgenice inated HCI Other Total
0 3.19 0 O 3.19
0 1.OO 0 0 1.OO
0 2.28 0 0 2.28
0 0.0133 6.90E-06 0 0.0134
0 O.OO127 0 0 O.O0127
O O.O237 0 0 0.0237
0 0.0474 0 0 0.0474
0 0 9.80E-06 0 9.BOE-08
0 1.69 0.167 0 1.74
0 0.000246 0.000982 0 O.O0121
0 0.0866 0 0 0.0866
0 0.278 0 0 0.276
0 0.879 0 0 0.679
00000
0.337 000 0.337
0 8.19 0 0 8.19
0 16.3 0 0 16.3
0 2OO 0 0 200
0 34.3 0 0 34.3
0 0.146 O 0.0907 0.237
0 81.8 0 O.O0260 81.8
0 129 12.0 0 141
0 28.6 0 0 28.6
0 6.81 0 0 6.81
0 0.447 0 0 0.447
0 0.820 0 0 0.820
0 0.867 0 0 0.867
0 0.989 0 0 0.989
347 0 2,360 0 2.7O7
63.1 0 349 0 4O2
0 4.64 0 O 4.64
0 4.64 0 0 4.64
0 23.8 0 0 23.8
8.30 0 64.4 0 62.8
0 1.81 0 0 1.81
O 1.38 0 0 1.38
46.4 12.2 0 0 67.6
22.7 8.27 O 0 28.9
o eo.a 0.101 o se.a
Baeeline control
Orgenice HCI
ell.. % ell.. %
98.O
98.0
98.0
0.0 0.0
0.0
O.O
70.0
O.O
0.0 0.0
0.0 0.0
0.0
0.0
0.0
98.0
98.0
81.0
97.4
99.6
0.0
99.0
60.6 80.4
86.6
83.9
86.6
86. 6
86.6
86.6
98.0 99.0
98.0 99.0
98.0
98.0
98.0
98.0 99.0
98.0
98.0
98. 0
98.O
ea.o o.o
Baeeline emieeione, Mg/yr
Chlorinated Unchlor-
Organice inated HCI Other Total
0 0.0842 0 0 O.O642
0 0.0199 0 O 0.0199
0 O.O468 0 0 O.O46B
0 0.0133 6.90E-06 O O.O134
0 O.O0127 0 0 O.OO127
0 O.O237 0 0 O.O237
0 0.0142 O 0 O.O142
0 0 9.80E-06 0 9.80E-O8
0 1.69 0.167 0 1.74
0 0.000246 0.000962 O.OO121
0 0.0866 O.O866
0 0.276 0 0 0.276
0 0.879 0 0 0.879
0 0000
O.O0874 000 O.OO874
0 0.164 0 0 0.164
0 2.91 0 0 2.91
0 6.22 0 O 6.22
0 0.171 O 0 0.171
0 0.146 0 0.0907 0.237
0 0.807 O O.O0260 0.807
0 63.6 2.38 0 66.9
0 4.14 0 0 4.14
0 0.938 O 0 0.938
0 0.0860 0 0 O.O660
0 0.119 0 0 0.119
0 0.126 0 0 0.126
0 0.141 O 0 0.141
6.94 0 23.7 0 30.6
1.O6 O 3.86 0 4.72
0 O.O907 0 0 O.O807
0 0.0907 0 0 0.0907
0 0.476 0 0 0.476
0.168 0 0.667 0 0.733
0 0.0363 0 0 0.0363
0 0.0276 0 0 0.0278
0.907 0.242 0 0 1.16
O.464 O.126 O O O.679
O 1.&3 O.1O1 O 7.O3
MACT Floor
va. Baeeline
incremental reduction, Mg/yr
Organice HCI
1.43
0.248
0.811
1.380
60.7 1.84
1.29
0.367
0.02O
O.O37
0.039
O.O44
teguletory alternative 1
ve. Baeeline
incremental reduction, Mg/yr
Organic* HCI
1.43
0.248
0.811
1.3 BO
80.9 1.84
1.29
0.367
0.020
0.037
0.039
0.044
'
Regulatory alternative 2
e. Baaelin*
incremental reduction. Mg/yr
Organic* < HCI
1.66
O.270
O.668
2.80
1.22
80.9 2.24
3.67
O.B22
0.066
O.103
O.107
O.121
0.1
0.171
O.O
0.0
J-
PROCESS VENT EMISSIONS
-------
PROCESS VENT EMISSIONS
PA1 NESHAP
F:\PROJECT\AGCHEMS\PVEMTS\PV-EMREO.XLS
Me.
f^Ml M*MMit HMtiilta
HO. M. WC M
22 88 B
M 80 B
23 87 B
U 88 8
23 66 8
M tO B
23 61 C
M B2 8
33 63 •
13 M •
Model 1 (M 42
Model 1 to) •
Model 2 IM 4
Model 2 IM •
Model 2 lot 2
•to** 2 lei 6
Model 3 IM 13
Model 3 lot 1
Model 4 IM •
Model 4 IM •
Model 4 |cl 3
Model 4 (el 3
B3
Cloeihoieil UnehoH
Hgimmt neled MCI Oik.. !•»«!
o ee.7 o o M 7
1.728 0 636 0 2.100
0 OXMM3 0 0 O.OOBB3
O.OO181 OO4BB O1O4 0 O 166
O.0132 0 342 O 710 0 1 07
0.00771 0.1M 0.410 O O.818
4.02 0 117 0 121
O.4B6 1 39 OOOO66O 0 1 68
40.1 16 fl O667 0 69 J
26.6 38.6 33.1 0 *B 1
O B76 0 676
O B2 2 0 82
81.0 764 2B4 424
167 163 62* B49
41.8 30.2 132 212
106 66.6 331 631
O 633 0 633
0 4IX> 0 41
71 22.6 2(6 397
366 114.6 1.476 1.984
237 66.7 666 1.1 CO
237 68.7 106 1.1 BO
4.168 3.377 6.640 9 19 16.624
BaMbM CMNfvl
O>OMI« tici
•n . % •»( . %
980
oa.o 60.t
00
70.0 67 0
70.0 87 1
7O O 67 O
667 990
680 1000
76.9 97 4
76 7 98 9
800
800
800 600
800 990
BOO BOO
80 O 660
BOO
800
BOO BOO
BOO 990
600 600
BOO 99 O
warn** mud HC1 Otker Teul
0 1 33 0 0 1.33
34.6 0 267 0 302
0 OOOB63 0 0 OOOHO
OOOO643 OO160 000310 00186
0 OO40B 0 103 0 0209 O 0.127
000227 00664 O.0122 O O.O736
1 3B 0 1.17 O 2 66
000671 00778 O O O 0378
766 6 BO 00146 O 13.6
3 36 116 0 367 0 16.6
0 116 0 116
0 164 0 16.4
167 163 629 846
31 4 30.6 6.29 69 3
6 36 7 64 26 4 42 4
709 191 331 41.1
O 107 O 1O7
0 82O O 62O
16 8 4.68 69 79
789 228 148 116.6
47 3 13.74 177 218
47 3 13.7 8 9 69.9
474 892 662 0376 1,769
MACTFbot
•0.6eeetM
Miomonul fedHOMOA, Maft*
OiawriM HD
236
OO71
O.O41
0676
766
8.66
67.6
8.22
16.0 37.O
32.0
8.OO 166
20.0
63.3
4 1O
1O 2 413
60.6
30 6 123.6
30.6
616 468
ftrpjnbl HQ
236
0.071
O.O41
O.676
7.66
666
67.6
14.8
16 O 37 .0
17.0
14.4 16.8
380
•13
7.16
1O.2 41 3
609
•6.0 123.8
660
714 468
M.BM6M
0*Mb« HQ
262
OO66
0068
1.3O
124
13.6 0.0
104
14 8
288 6O.2
•7.6
14 4 26 1
36.0
66.8
738
18.3 66
81.6
66.0 188
66.0
666 887
M The panMHtn vt Mcli ol tfw lew m«del eraceeeee • p«»»ie»Ked to Hie 6*
The mmket el model piecieeee ihel eeuety the epolnebiMir cme>u ler BB percent cenml und« Reguleiair Ali.m.ii.. 1 w deec>*ed in ih* Coel knpecie nwiwtendwn.
M Immfr-f etteem chencuneMe de net Mlielr a«nv AHernoiioe 1
-------
Attachment 2
-------
UNCONTROLLED EMISSION FACTORS AND REGULATORY ALTERNATIVE I EMISSION FACTORS FOR EQUIPMENT LEAKS
PAI NESHAP FILE: F:\PROJECT\AGCHEMS\ELEAKS\ELFACTOR.XLS
BATCH MODEL
Processes
FLANGES
PUMPS
GAS VALVES
LIQUID VALVES
CONTINUOUS MODEL
Processes
FLANGES
PUMPS
GAS VALVES
LIQUID VALVES
Number of
component!
1,100
14
65
340
Number of
component!
1,500
33
240
1.100
Avenge SOCMI
emission
factor,
kg/hr/component
0.00183
00199
0.00597
0.00403
Average SOCMI
emiuion
factor,
kg/hr/component
000183
0.0199
0.00597
0.00403
Mourn of
operation,
hr/yr
2,800
2,800
2,800
2,800
Houri of
(ipenlicin,
lir/yr
5.000
5.000
5,000
5.000
Uncontrolled Control
(or Baseline) Efficiency
emissions, for LDAR,
kg/yr %
5,636 0 93
780.1 0.75
1,087 0.92
3.837 0.88
11, 340 kg/yr
1 1 .34 Mg/yr
Uncontrolled Control
(or Baseline) Efficiency
emissions, for LDAR,
kg/yr %
13,725 093
3,284 0.75
7,164 0.92
22,165 0.88
Regulatory
alternative 1
emiuioni.
kg/yr
394.5
1950
86.9
460.4
1,137 kg/yr
I.I 37 Mg/yr
Regulatory
alternative 1
emissions,
kg/yr
960.7
820.9
573.1
2,659 8
46,338 kg/yr
46.34 Mg/yr
5,015 kg/yr
5.0IS Mg/yr
-------
EQUIPMENT LEAK EMISSION REDUCTION FOR MACT FLOOR AND REGULATORY ALTERNATIVE
PAI NESHAP FILE: F:\PROJECT\ACCHEMS\ELEAKS\EL-EMRED.XLS
Baseline
Regulatory Emissions
Alternative (Mg/yr)
MACT floor 3,407
Subpart H 3,407
ER From
Baseline
(Mg/yr)
0
3,022
ER From
Baseline
<*)
0
88.7%
Number of Emission* per process
Processes processes Mg/yr/process
Uncontrolled (a)
Batch EL model 138 11.34
Continuous EL model 37 46.34
Process 1
Process 4
Process 20
Process 23
Process 24
Process 25
Process 26
Process 10
Process 22
Process 14
Process 11
Process 13
Process 6
Process 9
1.78
0.56
14.2
42.1
2.80
6.01
6.01
2.64
2.02
1.27
24.1
7.06
3.09
3.79
Implementing subput H 14 21.7
203
Baseline (a)
11.34
46.34
1.43
O.S6
10.7
29.2
1.95
4.17
4.17
2.64
2.02
1.27
24.1
7.06
3.08
3.79
2.26
MACT Floor
11.34
46.34
1.43
0.56
10.7
29.2
1.95
4.17
4.17
2.64
2.02
1.27
24.1
7.06
3.08
3.79
2.26
After
subpart H (a)
1.137
5.015
0.093
0.044
1.10
4.79
0.319
0.684
0.684
0.239
0.164
0.106
2.07
0.625
0.282
0.368
2.26
Nationwide emissions,
Mg/yr
Uncontrolled
1,565
1,715
1.78
0.56
14.2
42.1
2.80
6.01
6.01
2.64
2.02
1.27
24.1
7.06
3.09
3.79
304 -
3,701
Baseline
1,565
1,715
1.43
0.56
10.7
29.2
1.95
4.17
4.17
2.64
2.02
1.27
24.1
7.06
3.08
3.79
31.6
3,407
MACT Floor
1,565
1,715
1.43
056
10.7
29.2
1.95
4.17
4.17
2.64
2.02
1.27
24.1
7.06
3.08
3.79
31.6
3,407
After
subpart H
157
186
0.093
0.044
1.10
4.79
0.319
0.684
0.684
0.239
0.164
0.106
2.07
0.625
0.282
0.368
31.6
386
(a) Uncontrolled, Baseline, and Regulatory Alternative emissions Tor all except the model procesneii are cKtimtted in »n attachment to the Baseline emissions
memorandum (the attachment in CBI). The emiiwionii for the model proce*»eM are diNcuKsed in the Model PUnt memorandum.
-------
Attachment 3
-------
STORAGE TANK EMISSIONS AT BASELINE. MACT FLOOR. AND REGULATORY ALTERNATIVE
PAI NESHAP FILE; F:\PROJECT\AOCHEMSVTANKS\ST-GMRED XLS
MMVEVED TANKS
tabefMMMI-A
!• TANKS)
•Mb ml Motfol 1-a
KTAMCW
•MbcfMMMI-C
in TANKS!
•Mb ol Modil 2-A
!• TANKS)
•Mb* MM* 2-1
12 TANKS!
(Mb ol M«M 2-C
111 TANKS)
•Mb •» MWM 2-A
(12 TANKS)
•MB of M»M t-t
14 TANKS!
•MM ol Motfol 2-C
14 TANKS!
UNCONTROLLED MATKJNWKK
EMISSIONS/ UNCONTROLLEO
NO. TANK. EMISSIONS.
TANKS IB/VR IB/Yd
* 12.702
• 2.7*8
I 1.21*
1 SO*
1 2»»
1 674
12 461
1 1O1
1 767
1 •»
6 637
122
• 7,174
2 2422
• 2*6
2 111
4 72*17
• 14.391
1 6.147
7. in
2 364
2 77t
NATIONWIDE
BASELINE BASELINE
CONTROL EMISSIONS.
tff. ItSVR
9800% 2M
0 00% 2.77«
4.OO% 1.1 TO
11 20% 442
41 00% 161
42 00% 111
0.00% 4S1
M.00% 11
*OOO% 27
•600% 6
*too% 11
1*60% 1
M00% 147
000% 7.472
000% 7M
M00% 7
M 00% 1.646
9800% 7M
000% 6,147
2600% 1.786
O 00% 114
M00% S
NATIONWRX
MACT FLOOR MACT FLOOR MACT FLOOR
CONTROL CONTROL EMISSIONS.
DEVICE fff. LIAR
t
WfC 2M
CONDENSER 41% 1.610
CONDENSER 41% 6*0
CONDENSER 41% 261
WNE ,83
WNE 3,3
WNE 4*1
IONE „
WNE n
WNE l
WNE 11
WNE 1
WNE 147
FR 41% 1.47*
WNE 796
WNE ,
MNE 1.646
WNE 7M
FR 41% 1.166
*« 41% 1.061
WNE 364
WNf »
MEOULATMIV REGULATORY NATnMTOC
ALTERNATIVE ALTERNATIVE REO ALT
CONTROL CONTROL EMNuioNB,
oivtce trr. LOTH
WNE H4
CONDENSER 41% 1.6,0
CONDENBER 41% „„
CONDENSER 41% Ml
WNE ui
WNE m
WNE 46,
WNE
WNE 27
WNE a
WNE
WNE
WNE ,47
FR M% 121
*»* 2M
WNE ,
WNE 1.646
WNE 786
« ••% 267
FR w% n
•ONE 364
WME ,
-------
STORAGE TANK EMISSIONS AT BASELINE, MACT FLOOR. AND REGULATORY ALTERNATIVE
PAI NESHAP FILE:. F:\PROJECT\AGCHEMS\TANKS\ST-EMRED.XLS
UNCONTHOilfO NATIONWIDE NATIONWIDE
EMnSMMS/ UNCONIROUCO 9ASEUNE SASCLME
NO. TANK. EMISSIONS, CONTROL EMISSIONS.
TANKS LB/VR IB/VR Iff, LB/VR
MOMUEO TANKS
ModHI-A 2« 1.411.33 M.696 9600* I.MS
IM TANKS!
M«*M-B M Oe7.ll 16.163 1100% 13.602
IN TANKS]
Mooai-e «? SIM 4.879 4soo* 2.919
NT TANK»
MteM^A 13 92179 21.201 WOO* 1.OW
HlTAMCn
MMd>« • 1.210.SB l.Mt 0.00% 7.2*6
IS TANKS]
MMriK 12 17.17 1.1M 1900% 97B
112 TANKS!
MMrt»« 34 7.267.74 247.101 9600* 12,3(6
IM TANKS!
ModMM 2 1.931 64 23.190 6OO* 21.799
IIS TANKS!
M«M»-C 2 189 71 1.917 WOO* 9S9
112 TANKS!
TOTAL 120 493.79999 IS 92.244.77
NATIONWIDE
MACT R.OOM MACT HOOB MACT H.QO*
COMTRCK. CONTROl EMISSIONS.
DEVICE IFF. am
tOUf 1.918
CONDENSER 41% 9.029
WNE 2.S1S
-------
Attachment 4
-------
WASTEWATER EMISSIONS FOR MACT FLOOR AND REGULATORY ALTERNATIVE
PAINESHAP FILE: F:\PROJECTVAOCHEMS\WW-1MPAX\WW-EMRED.WQ2
Stream
(b)
1 13a, 14a. ISa
2 I7b
3 I8b
4 27
5 32
6 plant IS
7 26
8 20
9 I6a.b
10 37e.f,gJ,k
II 31*
12 42
13 43
14 44
15 plant 21
16 plant 22
17 19*20+21
18 29
19 30
20 31
21 7
22 23
Flownta
par ilream,
gal/yr
6,990,000
5,040.000
2,960.000
120,000
1,857,146
1,865,855
4,000.000
1.819,000
5,600.000
40,357.268
5,250.000
3,513,600
885,600
695,665
45.607.268
5.094,865
10,700,000
5,625
1.028
2,056
11.600
47,000
Load par
dream,
Mg/yr
158
479
281
13.6
10.7
11.6
51.3
894
1,144
485
90.9
143
35.9
34.1
576
213
52.6
0.349
0.192
0.385
1.23
1.81
ppmw
5,971
25,123
25,095
29,958
1,523
1,647
3,390
1,299
54,001
3,175
4.577
10.759
10.716
12.957
3,336
11,051
1,300
16.392
49.338
49.513
28.033
10.179
Baseline and
MACT Flour
amiuioni,
Mg/yr
88.4
306
180
10.9
8.57
9.30
24.6
3.46
326
93.4
17.5
26.1
6.98
8.70
III
41 7
204
0.279
0154
0308
0209
0308
Fr
099
099
099
099
0.99
0.99
0.95
0544
0.44
0335
0335
0.323
0.336
0402
0335
0.338
0544
0.99
0.99
099
031
031
Fe
0.56
064
0.64
0.8
0.8
0.8
0.48
0.387
0.286
0.193
0.193
0.182
0.194
0.255
0 193
0196
0.387
0.8
08
08
0 17
0.17
REGULATORY ALTERNATIVE (•)
Removed
from load
per ilream,
M|(/yr
156
474
278
13.5
10.6
11.5
487
486
504
162
305
462
12 1
137
193
720
28.6
0.345
0.190
0381
0381
0.561
Left in Emiaiioni
water per Mream
per ilream, after SS,
Mg/yr Mg/yr
1.58 0.884
4.79 3.07
281 1.80
0.136 0.109
0.107 00856
0.116 0.0930
2.57 1.23
4.08 1.58
641 183
322 62.2
605 11.7
968 17.6
23 8 4.63
20.4 5 20
383 73.9
141 27.6
24 0 9.29
0 0035 0.0028
00019 00015
00039 00031
0.849 0 144
1 25 0.212
Reduction
from biwline
per ilream,
Mg/yr
87.5
303
178
10.8
8.48
9.21
23.4
1.88
143
31.2
5.83
8.48
2.35
3.50
37.2
14.1
It 1
0276
0 152
0305
00647
0.0956
Number of
flreanulo
control
nationwide
1
1
1
3
2
1
2
1
1
1
1
1
1
1
1
1
1
1
1
1
3
3
NfttionwKw
baseline and
MACT floor,
Mg/yr
88.4
306
180
32.7
17.1
9.30
49.2
3.46
326
93.4
17.5
261
698
8.70
III
41.7
20.4
0.279
0.154
0.308
0.627
0.924
Nationwide
reduction from
baseline,
Mg/yr
87.5
303
178
32.4
17.0
9.21
46.7
1.88
143
31.2
5.83
8.48
2.35
3.50
37.2
14.1
II. 1
0.276
0.152
0.305
0.194
0.287
934
Nationwide
flowrate to SS,
gal/yr
6,990,000
5,040.000
2.960,000
360,000
3,714,292
1,865.855
8,000,000
1,819,000
5.600,000
40,357,268
5,250,000
3,513,600
885,600
695,665
45,607,268
5,094.865
10.700,000
5,625
1,028
2,056
34,800
141.000
148.637,922
(a) Regulatory alternative emissions are baaed on the auumplion that a steam stripper n uied in control emittioni.
(b) Slraami at surveyed planla IS, 21, and 22 combined for control with one ilream Dripper il each facility, ilill separate stream strippers for each ilream at modelled plants
Combined streams 19, 20, and 21 at a modelled plant because of their relationship in each other si the surveyed plant.
Combined streams 13s, Ms, and 15s al a modelled plant because of their relslioiuhip »l the surveyed plsnl
-------
Attachment 5
-------
PAC NESHAP FILE: PROJECnAGCHEMS\PVENTSVATT5EQN.XLS
Process Vents • Secondary Air Environmental Imptcu
2l-Apr-97
The electricity and natural fat requirements for each of the models ar» baaed on th« control device design algorithm* that art
diicuaMd in th« Cod Impacu Memorandum. See section* V.A and B for diacuation* of electricity and fuel calcuUtiom
and fection IV.A for diacuiaion of cmiirion factors tiled to eibnute secondary air impact* from fuel combustion.
EXAMPLE MODEL ID:
Calculate amount of coal burned to generate electricity required, assuming 35 percent heal to energy conversion-
2.666,070 Kw-hr/yr x 3,412 Btu/Kw-hr / 14,000 Btu/lb coal / 2, 000 Ib coal/ton coal / 0.35 = 928 ton* coal/yr
Calculate amount of coal Btu'i burned to generate electricity required, aiauming 35 percent beat to energy convention:
2.666.070 Kw-hr/yr x 3.412 Btu/Kw-hr / 0.35 - 25.990.373.829 Btu/yr
Emiuion* of CO:
92S ton coal/yr x 5 Ib CO/ton coal / 2204 Ib/Mg + 372.673.514 tcf nat. gu x 35 Ib CO/10'6 »cf tut. ga* / 2204 Ib/Mg - 1.03 Mg CO/yr
E million* of NOx:
928 ton coal/yr x 13.7 IbNOx/ion coal/2204 Ib/Mg + 372.673.584 »cf nat gt* x 140 Ib NOx/10'6 «cf nat gti / 2204 Ib/Mg - 29.5 Mg NOx
Emiuioni of 3O2-
Firtt. convert the emission factor: 1.2 Ib SO2/10*6 Btu x 14,000 Btu/lb coal x 2,000 Ib coal/ton coal = 33.6 Ib SO2/ton coal
928 ton coal/yr x 33.6 Ib SO2/ton coal / 2204 Ib/Mg + 372,673,584 tcf nil. ga* x 0.6 Ib SO2W6 *cf nil gai / 2204 Ib/Mg - 14.3 Mg SO2/y
Emiuioni of PM:
Pint, convert the emiuion factor 0 03 Ib SO2/IO*6 Btu x 14.000 Btu/lb coal x 2,000 Ib coal/ton coil = 0 84 Ib SO2/ton coal
928 ton coal/yr x 0 84 Ib PM/ton coal / 2204 Ib/Mg + 372.673.584 scf nat ga* x 6.2 Ib PM/10'6 tcf nat. gat / 2204 Ib/Mg = 1 40 Mg PM/yr
Conversion Data-
UtUiry Plant NSPS
Subpan Da. 40 CFR pan 60
1.2 Ib SO2/10*6 Btu (controlled)
0 03 Ib PM/1CT6 Btu (controlled)
AP-42 Emission factors
5 Ib CO/ton coal
13.7 Ib NOx/ton coal
35 Ib CO/10'6 A3 nat. ga* (unc.)
140 Ib NOx/10'6 ft3 nat g**(unc.):
62 Ib PM/10'6 10 nat. gas (unc.):
06 Ib 502/10*6 ft3 nat. ga* (unc.):
3.412 Btu/Kw-hr
14.000 Btu/lb coal
1000 Bru/icf nat gas
1.80 % sulfur in coal
35* pp eff
-------
PAC NESHAP FILE: PROIECnAOCHEMS\PVENTS\ATTSWWEQ.XLS
Wastewater - Energy Impacts
IS-Iul-97
The electricity tad tutunl gas requirements an baaed on the control device design algorithms that an
ditcusted in the COM Impact* Memonndum. See sections V. A and B for discussions of electricity and fuel calculations
and section IV. A for discussion of emission factors used to estimate secondary air impacts from fuel combustion.
The secondary air impacts are calculated by the same method as for process vents.
EXAMPLE:
Calculate the actual «eam used for stripping HAP from westewater:
141.000.000 gal H20/yr x 8 33 Ib/gal H2O / 10.4 Ib water/lb steam • 118,542.301 Ib steam
Calculate the energy needed to generate the steem required, assuming 10 percent boiler efficiency:
141.000.000 gal H2O/yr x 8.33 Ib/gal H2O / 10.4 Ib water/lb steem x 1.180 Bru/lb steam / 0.80 = 174,849.903.846 Btu/yr
Calculate the amount of natural gas required to generate steem required:
174.849.903.846 Btu/yr / 1.000 Btu/scf nat gas - 174.849.903 8 scf net. gas
Calculate amount of electricity required to run the strippers, assuming 64 percent pump efficiency:
148.000.000 gel H2O/yr x 122 ft H2O x 8.33 Ib/gsl H2O / 0 00182 hp-s/ft-ft) / 3600 *ec/hr x 0.74S7 kW/hp / 0.64 = 88.503 kW-hr/yr
Calculate amount of coal required to generate electricity required, assuming 35 percent heat to energy conversion
88.503 Kw-hr/yr x 3.413 Biu/Kw-hr / 14,000 Btu/lb coal / 2.000 Ib/ton / 0.35 - 30.82 tons coal/yr
Conversion Data-
Utility Plant NSPS
Subpatt Ds. 40 CFR pan 60
1.2 Ib SO2/10*6 Bni (controlled)
003 Ib PM/10'6 Btu (controlled)
AP-42 Emission factors
5 Ib CO/ion coel
13.7 IbNOxAoncoal
35 Ib CO/10'6 ft3 nat. gas (fate.)
140 Ib NOx/10'6 fO nat gas(unc.)
6.2 Ib PM/10'6 ft3 nst. gas (unc.)
0.6 Ib $O2/10"6 ft3 nat gas (unc.)
3.412 Btu/Kw-hr
14.000 Btu/lb cosl
1000 Bni/scf nat gas
1.80 % sulfur in coal
35% pp eft
-------
PA! NE3HAP RLE: PROJECT\AOCHEMS\PVENTS\E[2_MF WQI
Procett Vmu EnvironrnenUl Impacts • MACT floor
30-Apr-97
Data:
Model (•)
li
Ic
1A (MCI IO*l
fa \n%*9 ^uwg
2d (HCI 94*)
2c (HO 10*)
2c (HO 94*)
3d
3c
4d (HO 10*)
4d(H094*)
4e (Ha Mft)
4e (Ha 94*)
4td (Ha »*)
Control Device
incinerator
condeiuer
• • -J0 _«(( M/M^natitiMr
incinerator
•cnibbar/condenMr
coademer
incinerator
comlcnwr
inclnenior/ecnibber
incinerator
•cnibber/condemar
condetuer
•enibber
Nitural
*«•,
•cf/yr/roodtl
20,704,088
0
13,892,987
13.892,987
0
0
166,068,810
0
131,310.794
131,310,794
0
0
0
Number
Electricity.
kwh/yr/model
148,1 IS
26S.IS7
108,536
104,434
19,516
19,449
1,177,836
44,898
979,978
942,842
144,902
144,546
37,136
of
modeli
18
43
s
11
2
6
13
8
3
8
1
3
1
Nationwide
electricity,
kwh/yr
2,666,070
II.40I.7SI
542,680
1,148.774
39.032
116,694
15.311,868
359.184
2.939,934
7,542,736
144,902
433,638
37,136
Nationwide
luxiliiry
natural g*i,
tcf/yr
372.673.584
69,464,935
152.822,857
2,158.894.530
393.932.382
1.050,486.352
CoeJ burned
to generate
electricity,
ton/yr
928
3.970
189
400
14
41
5.331
125
1.024
2,626
50
151
13
Coil burned
to generate
electricity,
Btu/yr
25,990,373,829
111,150,784,034
5.290,354,743
11,198,905,394
380,506,240
1,137,599.794
149.268.838.903
3,501,530,880
28,660,156,594
73,530,900,663
1,412,587,497
4,227,351,017
362,022.949
M|CO/yr
8.03
9.01
1 S3
• t«*J
3.34
0.031
0.092
46.4
0.284
8.58
22.7
0.115
0.343
0.029
MfNOx/yr
29.5
24.7
5 M
•V>W
12.2
0.085
0.253
170
0.778
31.4
83.1
0.314
0.939
0.080
MfSO27yr
14.3
60.6
2 90
••^j
6.14
0.207
0.620
81.9
1.91
15.7
40.3
0.770
2.30
0.197
MfPM/yr
1.40
1.51
ni&g
V«*V9
0.583
0.005
0.015
8.11
0.048
1.50
3.96
0.019
0.058
0.005
TOTAL:
640.200,000 62.970.000,000
1507
5389
3418
262.3
(•) The HCI efficiency in pireniheiei it the biieline level of control for each model.
-------
PACNESHAP FILE! PROIECTVAOCHEMSVPVENTSVEa.RAI.WQI
i lutuw vmiu cnvira
30-Apr>97
Data:
Model (•)
111
le
2d (HO 80*)
U (HCI 94%)
2c (HCI 80%)
2c (HCI 94%)
3d
3c
4d (HCI 80%)
4d(HCI94%)
4e (HO 10%)
4c(HCI94%)
4«5(HaonJy)
Icilt
2d elt (Ha 80%)
2d 111010 94%)
2e alt (HCI 80%)
2c alt (HCI 94%)
Seall
4d alt (HCI 80%)
4d a* (HCI 94%)
4e ah (HCI 80%)
4c alt (HCI 94%)
nmenu unpecw - Mg an i
Natural Electricity, Number Nationwide
gat, kwh/yr/model of electricity,
Control Device
iKiMnto,
condenser
incinerator/scrubber
incinerator
scrubber/condenser
condenser
incinerator
condenser
incineralor/acnibber
incinerator
scrubber/condenser
condenser
scrubber
condenser
incinerator/scrubber
incinerator
ic rubber/condenser
condenser
condenser
incinerator/scrubber
incinerator
scrubber/condenser
condenser
ecf/yr/model
30.704,081
0
13,892,987
13,892,987
0
0
166,068.810
0
131.310,794
131,310.794
0
0
0
0
13,892,987
13,892,987
0
0
0
131.310,794
131.310.794
0
0
141.115
265.157
108,536
104,434
19.517
19.449
1,777,836
44.898
979,978
942.842
144,902
144,546
37,136
378,417
108,536
104.434
31,345
31,277
80.969
979,978
942,842
205,895
205.539
Model*
18
37
3
10
1
1
13
7
1
5
0
2
1
6
2
1
1
5
1
2
3
1
1
Kw-hr/yr
2,666,070
9,810.809
325,608
1,044,340
19,517
19,449
23,111,868
314,286
979,978
4.714,210
0
289.092
37,136
2,270,502
217.072
104,434
31.345
156.385
80,969
1,959,956
2.828,526
205.895
205,539
Nationwide
auxiliary
natural gas,
sef/yr
372.673,584
41,678,961
138,929,870
2,158.894,530
131.310.794
656.553,970
27.785,974
13,892,987
262,621,588
393.932,382
Coal burned Coal burned
to generate to generate
electricity, electricity,
ton/yr
928
3,416
113
364
6.80
6.77
8,047
109
341
1.641
0.00
101
12.9
791
75.6
36.4
10.9
54.4
28.2
682
985
71.7
71.6
Btu/yr
25.990,373,829
95,641,372.309
3,174,212,846
10,180,823,086
190,262,869
189.599,966
225.307,696,046
3,063,839.520
9.553,385431
45,956,812,914
0
2,818,234.011
362,022,949
22,134,150,926
2,116,141,897
1,018,082,309
305,568,971
1,524,530,343
789,332,080
19,106.771,063
27,574.087,749
2.007.182.114
2,003,711.623
MgCO/yr
8.03
7.75
0.920
3.03
0.015
0.015
52.6
0248
2.86
14.2
0.000
0.228
0.029
1.79
0.613
0.303
0.025
0.124
0.064
5.72
8.50
0.163
0.162
Mg NOx/yr Mg SCH/yr
29.5
21.2
3.35
11.1
0.042
0.042
187
0.681
10.5
51.9
0.000
0.626
0.080
4.92
2.24
1.11
0.068
0.339
0.175
20.9
311
0.446
0.445
I4J
52.1
1.74
5.58
0.104
0.103
123
1.67
504
25 Jt
0.000
1.54
0.197
12.1
1.16
0.558
0.166
0.831
0.430
10.5
15.1
1.09
1.09
MgPM/yr
1.40
IJO
0.161
0.530
0.003
0.003
9.15
0.042
0.500
2.47
0.000
0.038
0.005
0.301
0.107
0.053
0.004
0.021
0.011
1.00
1.48
0.027
0.027
TOTAL:
51,390.000 4,198,000,000
107
378
274
18.6
(a) The Ha efficiency in parentheses ia the baseline level of control for each model.
-------
PACNESHAP FILE! F:\PROJECT\AGCHEMS\PVENTS\EI2_RA2WQ1
W-Apr-97
Data:
Model (a)
Id ill
Icall
2d ah (Ha 10ft)
24 alt (HCI 94%)
2c ah (HO 80ft)
2c all (HCI 94%)
3d lit
3call
4d ah (HO 80ft)
4d all (Ha 94%)
4c all (Ha (Oft)
4e ah (Ha 94ft)
4ad ah (Ha only)
lead
2d all (Ha 80ft)
2d ah (Ha 94ft)
2c alt (Ha 80ft)
2c alt (Ha 94ft)
3c.lt
4d ah (Ha 80ft)
4d alt (Ha 94ft)
4d all (Ha 80ft)
4dah(Ha94»)
mmwui ui^ww - nrg i
Control Device
incinenMor
condenMr
incineralor/«c rubber
incinentor
__ . .
•cruDDeT/conoenaer
condenMr
incinatalor
condenMr
ineinerator/acrubber
incinerator
•crubbcr/condenflcr
eoodeoaer
*-•
•6IUUVVI
condenaer
inciDBnlor/tcfUblMr
incifWMtor
•crubber/condeiuer
condenaer
condenaer
incinerator/fcrubber
incineraior
•crubbcr/condenter
condenaer
m i
Natural
>".
acf/yr/model
20,704,088
0
13,892,987
13,892,987
0
0
166,068,810
0
131,310,794
131,310,794
0
0
0
0
13,892,987
13,892,987
0
0
0
131,310,794
13 M 10,794
0
0
Electricity,
kwh/yr/roodel
148. IIS
378.417
108.536
104.434
31,345
31,277
1,777.836
80,969
979.978
942.842
205,895
205,539
37.136
378,417
108.536
104.434
31,345
31.277
80,969
979,978
942.842
205.895
205.539
Number
of
Modeli
18
37
3
10
1
1
13
7
1
5
0
2
1
6
2
1
1
5
1
2
3
1
Nationwide
electricity,
Kw-hr/yr
2,666,070
14,001.429
325.608
1.044.340
31.345
31.277
23.111.868
566.783
979.978
4.714.210
0
411,078
37,136
2.270.502
217,072
104.434
31,345
156,385
80,969
1 .959,956
2.828.526
205.895
205.539
Nationwide Coal burne
auxiliary lo generate
natural gai,
icf/yr
372,673,584
41.678,961
138,929.870
2,158,894.530
131.310.794
656,553,970
27.785.974
13.892.987
262.621.588
393.932,382
electricity,
ton/yr
928
4,875
113
364
10.9
10.9
8,047
197
341
1.641
0.000
143
12.9
791
75.6
36.4
10.9
54.4
28.2
682
985
71.7
716
Coal burned
lo generate
electricity,
Blu/yr
25,990,373,829
136.493.930,709
3.174.212.846
10,180,823.086
305,568,971
304,906.069
225,307,696,046
5.525,324,560
9,553,385,531
45.956,812,914
0
4,007,423.246
362,022,949
22,134,150,926
2.116,141,897
1,018.082.309
305,568,971
1.524.530,343
789,332,080
19,106,771,063
27.574,087,749
2,007,182,114
2,003.711.623
MgCO/yr
8.03
II. 1
0.920
3.03
0.025
0.025
52.6
0.448
2.86
14.2
0.000
0.325
0.029
1.79
0.613
0.303
0.025
0.124
0.064
5.72
8.50
0.163
0.162
Mg NOi/yr
29.5
30.3
3J5
II. 1
0068
0.068
187
1.23
10.5
51.9
0.000
0.890
0.080
4.92
2.24
1.11
0.068
0.339
0.175
20.9
31.2
0.446
0.445
MgSO2/yr
I4J
74.4
1.74
5.58
0.166
0.166
123
3.01
5.24
25.2
0.000
2.18
0.197
12.1
1.16
0.558
0.166
0.831
0.430
10.5
15.1
1.09
1 09
MgPM/yr
1.40
1.86
0.161
0530
0.004
0.004
9.15
0.075
0.500
2.47
0.000
O.OSS
0.005
0.301
0.107
0.053
0.004
0.021
0.011
1.00
1.48
0.027
0027
TOTAL
55.980.000 4.198.000.000
III
388
298
19.3
(a) The HCI efficiency in parenlheaea it the binlinc level of control tut each
-------
PAINESHAP RLE: FVROJECT\AOCHEMS\ENV_WP^NV_»W.XLS
Storage Tanka Environmental Impada
01-Mey-07
Date:
MACT floor
MoM IB (41 PERCENT)
Model 2B (41 PERCENT)
Model 3B (41 PERCENT)
W/AP-42EF
W/AP-42EF
Control
Q0VVM
condenser
IFR
IFR
Electricity
Kw-nr/yf
par model
5.66
0
0
TOTAL (Kw):
TOTAL (Mw):
Numbar
of
--.— -|— |—
mOCMPV
35
8
16
NiUonwkte
oloctrtclly,
Kw-hr/yr
198
0
0
198
0.20
Coal burned
lo gwMrate
•toetttcNy.
ton/yr
0.0689
0.0000
0.0000
Coal burned
to generate
electricity.
BUi/yr
1.929.500
0
0
TOTAL (kg):
TOTAL OA»):
kgCCVyr
0.16
0.00
0.00
0.16
0.000156
k0NOx*r
0.43
0.00
0.00
0.43
0.000429
ControlM
kB8O2V
149
0.00
0.00
1J9
0.001892
Contrafad
hoPM/yr
003
0.00
0.00
003
0.000026
•guWofyal
Model IB (41 PERCENT)
Model 2B (95 PERCENT)
Model 38 (95 PERCENT)
eonderaar
IFR
IFR
566
0
0
TOTAL (Kw):
TOTAL (Mw).
35
a
16
198
0
0
198
0.20
00689
00000
00000
1.929,500
0
0
TOTAL (KG):
TOTAL(MG):
0.16
0.00
0.00
0.16
0.00016
0.43
0.00
0.00
043
0.00043
1J9
0.00
0.00
1,89
0.00189
0.03
0.00
0.00
003
0.00003
-------
PAJVSSHAP FILE: PKOrECTSACCMEMSVWW.IMPXNENV.IMPIXLS
VMHMHr Bnvuvonioul lapcu
I4IJOOOJOOO
10
93500
Turf M{ HAP eoOBoIUd.
DmiyH2O(iypl>:
133
1.760
1A .
TMlMfHAPanolM
0
0
1JP.34
I
141X100.000
Emwiy raquirad to nia f Bqppan. kw-hrryr
! coMtderad)-
ufbwnMDail coaiidfndi:
bader cfricmcy
wfa«. (M
935 (OifrtwiB«dtoprocciii
935 (OifrcauMdtoproaH)
Ibmol. CH4
I ISO
1000*
1.000 Bm
J9:
OOOa IbnokCO
0001
COOlldcredl
' I tanuumt D-
Ib NOObmet. NO*
PM-10 oc. «BMioa hcior (Ibftoe coal):
PM CML ••••m fMUr (Moo oulk
$02 «nc «u
$02 COOL 01
»S«irur
IM boor (Ib • «S/M coal):
•oofacvir
13.7
140
46
132
0*4
136
1*0
-------
MIDWEST RESEARCH INSTTTUTL
Suite 35C
401 Harrison Oaks Boulevard
Gary. North Carolina 27513-2412
Telephone (919) 677-0249
FAX (919) 677-0065
Date: April 30, 1997
Subject: Cost Impacts of Regulatory Alternatives for the PAI
Production NESHAP
EPA Contract 68D60012; Work Assignment No. 004
BSD Project No. 93/59; MRI Project No. 4800-04
From: Karen L. Schmidtke
David D. Randall
To: Lalit Banker
ESD/OCG (MD-13)
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
I. Introduction
This memorandum presents the estimated cost and cost
effectiveness of techniques to control missions from the five
emission source types in the pesticide active ingredient (PAI)
industry. The five emission source types are process vents,
storage tanks, equipment leaks, wastewater, and bag dumps and
product dryers. Costs were estimated for techniques likely to be
used to control emissions to the maximum achievable control
technology (MACT) floor control level and, for some emission
source types, to the control level for one or two regulatory
'•alternatives.
The MACT floor and regulatory alternatives for existing and
new source process vents, equipment leaks, storage tanks,
wastewater, and bag dumps and product dryers are provided in the
MACT Floor and Regulatory Alternatives memorandum.1 In addition,
the baseline emissions and the hazardous air pollutant (HAP)
emission reductions achieved by the standards are provided in the
Baseline Emissions memorandum and the Environmental Impacts
memorandum, respectively.2'3
Costs were developed for a variety of control techniques.
For process vents, costs were developed for three types of add-on
control devices (incinerators, condensers, and gas absorbers).
For storage tanks, costs were developed for condensers and
internal floating roofs (IFR). For wastewater, costs were
developed for steam strippers an offsite disposal as a hazardous
waste. For equipment leaks, costs were developed for
implementation of a leak detection and repair (LDAR) program. No
costs were developed for bag dump and product dryer controls
because no model plants were developed.
-------
This memorandum contains four sections. Section II
presents a discussion of the cost analysis for each of the
emission source types for existing sources. Section III presents
the cost analysis for each emission source type for new sources.
Section IV provides references.
' II. Description of Cost Analysis for Existing Sources
A. Standard/Common Costs
Each of the cost analysis discussions in paragraphs B
through F below includes specific information that details the
assumptions and methodology used in costing control devices for
each emission source type. Some of the assumptions are common to
each cost analysis and are summarized in this paragraph.
In estimating the total capital investment (TCI) for
control device equipment, the equipment costs were based on data
from various years and must be scaled to represent cost in the
current year. All equipment costs were scaled to June 1995
dollars. Purchased equipment costs (PEC) generally include the
control device and auxiliary equipment costs, instrumentation
costs, sales tax, and freight costs. Costs for instrumentation
(10 percent), sales tax (3 percent), and freight (5 percent) were
estimated to be 18 percent of control device and auxiliary
equipment costs.
Several components of the annual costs are common for the
control devices. These common costs include direct annual costs
such as labor wages and maintenance costs, utilities, raw
materials, and waste treatment. Common costs for indirect annual
costs include overhead, administrative charges, property taxes,
insurance, and capital recovery factors. These are listed in
Table 1. Control equipment was assumed to operate 8,760 hours
per year (hr/yr) for storage tanks and batch processes and
5,000 hr/yr for continuous processes.
B. Process Vents at Existing Sources
Emission control costs were developed for the MACT floor
and two regulatory alternatives more stringent than the MACT
floor. For this analysis, the estimated 167 processes in the
industry with uncontrolled emissions equal to or greater than the
regulatory applicability cutoffs were each characterized with one
of eight model processes. Eight model processes were developed
to represent the industry: four with diluted emission streams
and four with concentrated emission streams. Control device
costs for process vents were developed for three control devices:
incinerators, condensers, and water scrubbers.
The MACT floor cost and cost effectiveness for each model
process are shown in Attachment A. For the MACT floor, control
device costs for diluted emission streams containing organic HAP
-------
TABLE 1. COMMON ASSUMPTIONS FOR ANNUAL COST CALCULATIONS
Parameter/Factor
Direct Annual Costs
Operator labor wage rate (except steam stripper)
Operator labor wage rate (steam stripper)
Maintenance labor wage rate
Supervisor labor cost
Maintenance materials cost
Operator labor time requirements
Maintenance labor time requirements
Utilities
Electricity
Water
Natural gas
Caustic
Wastewater treatment
S 15.64 per hour
S22.SO per hour
SI 7.21 per hour
15 percent of Operator labor cost
100 percent of Maintenance labor cost
0.5 hours per 8 hours operation
0.5 hours per 8 hours
operation
S0.059 per kW-hr
S0.20 per 1,000 gallons
S3.30 per 1,000 scf
S300 per ton
S3.80 per 1,000 gallons
Indirect Annual Costs
Overhead
Administrative, Property taxes, and Insurance
Capital recovery factor for IFR, Incinerators.
Manifolds, Condensers, Equipment leak
components, and Initial LDAR labor
Capital recovery factor for Scrubbers and Steam
strippers
Capital recovery factor for Equipment leaks
monitoring instrument
Capital recovery factor for Equipment leaks
rupture seals and pump seals
60 percent of all labor and maintenance material
costs
4 percent of TCI
10-year equipment life at 7 percent interest rate
(CRF = 0.1424)
15-year equipment life at 7 percent interest rate
(CRF = 0.1098)
6-year equipment life at 7 percent interest rate
(CRF = 0.21)
2-year equipment life at 7 percent interest rate
(CRF - 0.55)
-------
were based on incinerators, and costs for concentrated emission
streams with organic HAP were based on condensers. Condenser
costs were based on condensers that achieve a 90 percent control
level for organic HAP; the organic HAP emission reduction
achieved by the condenser control device is also based on the
floor control level of 90 percent. While the floor requires
organic HAP control of 90 percent, the incinerator costs were
developed based on incinerators that achieve 98 percent control
efficiency and the organic HAP emission reduction achieved by the
control device was based on the 98 percent reduction.
The MACT floor requires 94 percent reduction of hydrogen
chloride (HCl) emissions. Costs for a water scrubber to control
HC1 emissions were developed for process vent models 2D, 2C, 4D,
and 4C. While the floor requires 94 percent reduction of HCl
emissions, the scrubber costs were developed for a device that
achieves 99 percent control efficiency, and the emission
reduction achieved by the device was based on 99 percent control.
The cost and cost effectiveness for the regulatory
alternatives are shown in Attachment A. Twenty-three of the
streams represented by models 1C, 2D, 2C, 3C, 4C, and 4D are
subject to more stringent control levels for organic HAP under
Regulatory Alternative 1, and the costs to control these streams
are provided in the Attachment. For Regulatory Alternative 1,
the cost to control models with incinerators is equivalent to the
cost estimated for the floor. The cost to control models with
condensers is equivalent to the floor costs for all models except
those subject to more stringent control requirements for organic
HAP; the incremental increase in cost for these models is due to
the increase in control efficiency required by the device.
Regulatory Alternative 1 costs for scrubbers to control HCl
emissions are identical to floor costs.
Regulatory Alternative 2 requires more stringent control
than the floor for both organic HAP and HCl emissions. The cost
and cost effectiveness data for Regulatory Alternative 2 are
provided in Attachment A for each model. The cost to control
models with incinerators is equivalent to the cost for both the
floor and Regulatory Alternative 1. There is an incremental
increase in cost for 49 streams represented by models controlled
with condensers and that are subject to a more stringent control
requirement for Regulatory Alternative 2 than Regulatory
Alternative 1 (models 1C, 2C, 3C, and 4C). The cost for
99 percent emission reduction of HCl required by Regulatory
Alternative 2 is equivalent to the cost estimated for the floor
and Regulatory Alternative 1.
The nationwide costs and actual cost effectiveness of the
MACT floor and regulatory alternatives are shown in Table 2. The
incremental cost effectiveness for requiring control levels above
the stringency of the MACT floor and the incremental cost
effectiveness between the regulatory alternatives are also
-------
TABLE 2. PROCESS VENT MACT FLOOR AND REGULATORY ALTERNATIVES NATIONWIDE
COSTS FOR EXISTING SOURCES*
Option
MACT floor
Regulatoiy
Alternative
No. 1
Regulatory
Alternative
No. 2
Uncontrolled
emissions,
Mg/yr
16,520
16,520
16,520
Baseline
emissions,
Mg/yr
1,996
1,996
1,996
Nationwide
TCI,
$
55,710,000
56,220,000
59,390,000
Hie emissions and costs in this analysis are based on the use o
the surveyed facilities.
Nationwide
TAG,
$/yr
33,780,000
33,910,000
35,220,000
Emission
reduction from
baseline,
Mg/yr
1,236
1,281
1,375
Emission
reduction from
baseline,
%
62
64
69
Cost
effectiveness
relative to
baseline,
$/Mg
27,320
26,460
25,600
Incremental
cost
effectiveness,
$/Mg
2.900
14,000
f model processes to represent all processes in the industry, including processes at
-------
provided. The cost effectiveness {from baseline) for Regulatory
Alternatives 1 and 2 are $26,500 per megagram (/Mg) and
$25,600/Mg, respectively. The incremental cost effectiveness
from the floor to Regulatory Alternative 1 is $2,900/Mg, and the
incremental cost effectiveness from Regulatory Alternative 1 to 2
is $14,000/Mg.
Example design and cost algorithms for the three control
devices are presented in Attachment A. The assumptions and data
used in each algorithm are described below.
1. Condenser. The refrigeration unit size (tons of
cooling) is based on an energy balance around the unit when the
process is venting and the inlet stream contains its maximum HAP
load. Costs were developed for packaged, multiple-stage
refrigeration units using the approach in the Office of Air
Quality Planning and Standards (OAQPS) Control Cost Manual.
This approach estimates that the refrigeration unit cost is
80 percent of the refrigeration system equipment cost. The
remaining 20 percent of the system cost includes the HAP
condenser, recovery tank, connections, piping, and
instrumentation.
The PEC for the refrigeration system is equal to the total
equipment cost plus 8 percent for sales tax and freight. The
installation cost for the refrigeration system is equal to the
PEC for the system plus 15 percent.
The manifolding equipment cost was estimated for venting
one process with a total of 6 vents to the condenser. The number
of vents per process was based on the average from the surveyed
plants.4 The manifold equipment cost includes the cost of one
automatic damper, 300 feet of duct designed to convey exhaust gas
at 2,000 feet per minute, twelve elbows, and six detonation
arresters. The PEC for the manifold is equal to the manifold
equipment cost plus 16 percent for instrumentation, taxes and
freight. The installation cost for the manifold is assumed to be
equal to the PEC for the manifold.
The cost to conduct an initial compliance test to
demonstrate the efficiency of the condenser is estimated to be
$24,420. The cost for a thermocouple and datalogger to monitor
the exit stream temperature from the condenser is estimated to be
$3,000.6
The TCI is equal to the sum of the PEC for the
refrigeration system, PEC for the manifold, installation cost of
the refrigeration system, installation cost of the manifold, cost
for the performance test, and cost for a thermocouple and
datalogger.
The total annual cost (TAC) for the condenser consists of
direct annual costs and indirect annual costs. Direct annual
-------
costs are costs for labor, maintenance materials, and utilities
(electricity). Indirect annual costs are costs for overhead,
administrative charges, property taxes, insurance, and capital
recovery. Except for electricity requirements, the unit costs
and other factors used to estimate these costs are given in
Table l.
Electricity requirements for the refrigeration unit were
estimated using the tabulated data in the OAQPS Control Cost
Manual.5 Linear regression was used to develop an equation for
electricity requirements per ton of cooling as a function of the
condenser temperature. The mechanical efficiency of the
compressor was estimated to be 85 percent. Electricity
requirements for pumps and blowers were considered to be
negligible relative to the requirements for the refrigeration
unit.5
2. Incinerator. Costs for thermal incineration units were
calculated for packaged, recuperative incinerators based on the
approach in the OAQPS Control Cost Manual. The cost of the
incineration unit is based on the volumetric flowrate of flue gas
exiting the unit. The incinerator unit costs are based on the
assumption that 70 percent of the energy from the incinerator
flue gas is recovered. The incinerator unit cost includes
auxiliary equipment, which includes the stack and collection fan.
The PEC for the incinerator is equal to the total equipment
cost for the incinerator unit and auxiliary equipment plus sales
tax and freight.
Direct installation cost for the incinerator unit and
vauxiliary equipment is equal to 30 percent of the incinerator
PEC. These costs are for foundations and supports, handling and
erection, electrical installation, piping installation,
insulation for ductwork, and painting. Indirect installation
costs include engineering, construction and field expenses,
contractor fees, startup, performance test, and contingencies.
The indirect installation cost is equal to 31 percent of the
incinerator PEC.
The cost to conduct an initial compliance test to
demonstrate the efficiency of the incinerator is estimated to be
$24,420.6 The cost for a thermocouple and datalogger to monitor
the exit chamber temperature from the incinerator is estimated to
be $3,000.6
The manifold equipment cost was estimated using the same
method that was used for condensers for process vents.
The TCI is equal to the sum of the PEC for the incinerator
plus the direct and indirect installation costs and the sum of
the PEC and the installation cost for the manifolding. The
-------
8
compliance test and monitoring equipment costs are initial costs
that were also considered to be part of the TCI.
The TAG consists of direct annual costs and indirect annual
costs. Direct annual costs are costs for labor, maintenance
materials, and utilities (natural gas and electricity). Indirect
•annual costs are costs for overhead, administrative charges,
property taxes, insurance, and capital recovery. Except for
natural gas and electricity requirements, the unit costs and
other factors used to estimate these costs are given in Table 1.
Natural gas requirements are based on the amount of
auxiliary fuel necessary to stabilize the incinerator flame and
to maintain the incinerator temperature. Auxiliary fuel
requirements are at a maximum when the process is not venting to
the incinerator; depending on the organic concentration in the
exhaust stream, the auxiliary fuel requirements may be
significantly less when the process is venting. The equations to
calculate the amount of auxiliary fuel are described in the OAQPS
Control Cost Manual.7
Electricity requirements were also estimated using
equations in the OAQPS Control Cost Manual.7 Electricity
requirements were estimated for the fan and motor; the estimate
is based on the volumetric flowrate, pressure drop, and the
combined mechanical efficiency of the fan and motor. The
mechanical efficiency is estimated to be 60 percent.
3. Scrubber. The total equipment cost for the scrubber
system is equal to the sum of the tower cost plus auxiliary
equipment such as packing material and a pump. The scrubber
tower cost is based on the surface area of the unit. Costs were
developed using the approach in the OAQPS Control Cost Manual for
packed tower absorbers made of fiberglass reinforced plastic.
The equipment cost for the scrubber tower includes the tower
shell and numerous equipment components associated with the
tower. The equipment cost of the packing material is based on
use of ceramic Raschig rings at $20 per cubic foot. The
equipment cost of the pump used for circulating water is based on
a cost of $16 per gallon per minute of scrubber water.
The PEC for the scrubber system is equal to the total
equipment cost plus 10 percent for instrumentation and controls
and 8 percent for sales tax and freight.
The TCI is equal to the PEC for the scrubber system plus
the direct and indirect installation costs. The direct
installation costs are equal to 85 percent of the PEC and include
foundations and supports, handling and erection, electrical,
piping, insulation, and painting. Indirect installation costs
include engineering, construction and field expenses, contractor
fees, startup, performance test, and contingencies and are equal
to 35 percent of the PEC.
-------
The TAG for the scrubber system consists of direct annual
costs and indirect annual costs. Direct annual costs are costs
for labor, maintenance materials, utilities (electricity and
water), purchase of caustic, and wastewater treatment. Indirect
annual costs are costs for overhead, administrative charges,
property taxes, insurance, and capital recovery. Except for
electricity and water requirements, the unit costs and other
factors used to estimate these costs are given in Table 1.
Electricity requirements for the scrubber unit were
estimated using equations in the OAQPS Control Cost Manual.
Electricity requirements were estimated for the pump. The
mechanical efficiency of the pump is estimated to be 70 percent.
The annual amount of water usage was based on the liquid flowrate
necessary for operation of the scrubber plus makeup water. The
annual caustic usage was estimated based on the stoichiometric
amount necessary to neutralize the HC1.
C. Storage Tanks at Existing Sources
For the cost analysis, the 238 storage tanks in the
industry were each characterized by a model tank. A total of
nine model storage tanks were developed to represent the
industry. Emission control device costs were calculated for the
MACT floor and one regulatory alternative more stringent than the
floor.
The MACT floor control costs were developed for two control
devices: IFR and condensers. Condensers were costed for control
of storage tanks with capacity less than 76 cubic meters (m3)
(20,000 gallons); IFR were costed for storage tanks greater than
76 m3 (20,000 gallons). Costs for IFR were used for tanks
greater than 76 m3 (20,000 gallons) because the IFR costs are
less than condenser costs; it was assumed that facilities would
install the least costly control device that -meets the control
requirements. Costs were developed for only three of the model
storage tanks. Models IB, 2B, and 3B are the only models that
meet the MACT floor applicability criteria and are not already
controlled to greater than or equal to 41 percent. The floor
requires HAP emission control of 41 percent, but the IFR achieves
emission reductions of 95 percent and the emission reduction was
based on the 95 percent control efficiency. Condenser costs and
emission reductions were based on condensers that achieve the
floor control level. The costs and cost effectiveness for
control devices for each model tank are shown in Attachment B.
The regulatory alternative control costs were also
developed for IFR and condensers. The resulting costs and cost
effectiveness are shown in Attachment B for each model. The
regulatory alternative requires more stringent control of storage
tank emissions for tanks greater than or equal to 76 m3
(20,000 gallons) (models 2B and 3B). There is no increase in
cost or emission reduction from the floor to the regulatory
-------
10
alternative with use of IFR control. There is no change in the
requirements for storage tanks less than 76 m3 (20,000 gallons)
for the regulatory alternative and therefore, no change in the
cost or emission reduction (model IB).
As shown in the regulatory alternative table in
•Attachment B, there is no incremental cost effectiveness for
models 2B and 3B. As noted above, the emission reduction
achieved by the IFR for these models is the same under Regulatory
Alterative 1 and the MACT floor. Therefore, the cost for the
regulatory alternative is equivalent to the cost to meet the MACT
floor.
The nationwide costs and cost effectiveness of the MACT
floor and regulatory alternative are shown in Table 3, along with
the nationwide incremental cost effectiveness for the regulatory
alternative above the floor.
A cost algorithm table for the IFR control devices is
presented in Attachment B; the condenser cost algorithm is
similar to the one shown in Attachment A for process vents. The
assumptions and data used in each algorithm is described below.
1. IFR. The cost of an IFR was based on an aluminum
noncontact IFR with vapor-mounted primary seal and secondary
seal.9 The installed capital costs were based on an equation
relating cost of the floating roof to the diameter of the storage
tank. Initial costs for degassing and cleaning ($150 per foot of
diameter) and sludge disposal (assume 1 percent sludge volume at
$5 per gallon disposal cost) were also estimated. Annual costs
were developed for capital recovery, taxes, insurance,
administration, and operating costs (6 percent of installed
capital and other initial costs).
2. Condenser. The estimated condenser costs for storage
tanks were developed following the same methodology used to
estimate the cost of condensers for process vents. The
refrigeration unit size (tons of cooling) is based on an energy
balance around the unit when the inlet stream contains its
maximum HAP load. Maximum HAP load occurs while filling the tank
(i.e., working losses). Just as for the process vent condensers,
costs were developed for packaged, multiple-stage refrigeration
units using the approach in the OAQPS Control Cost Manual.5 The
remainder of the approach is also similar, with only a few
differences detailed below.
No manifolding equipment costs were estimated for control
of storage tanks with condensers. Unlike process vents where
multiple vents are manifolded to the control device, the storage
tank has only one vent. In addition, each storage tank was
assumed to be controlled with a condenser in close proximity to
the tank.
-------
TABLE 3. STORAGE TANK MACT FLOOR AND REGULATORY ALTERNATIVES NATIONWIDE
COSTS FOR EXISTING SOURCES
Option
MACT Floor
Regulatory
Alternative
No. 1
No. of
tanks
controlled
nationwide
57
57
Uncontrolled
emissions.
Mg/yr
219.4
219.4
Baseline
emissions,
Mg/yr
37.31
37.31
Nationwide
TCI,
$
866,900
866,900
Nationwide
TAC,
$/yr
607,400
607,400
Emission
reduction
from
baseline,
Mg/yr
19.98
19.98
Emission
reduction
from
baseline,
%
54
54
Cost
effectiveness
from baseline,
$/Mg
30.410
30,410
Incremental
cost
effectiveness.
S/Mg
0.0
H
H
-------
12
The direct annual cost, which is part of the total annual
costs, were estimated for full-time operation because this
analysis assumes storage tank condensers will be in service for
8.760 hr/yr.
In estimating the annual cooling load, and thus the
electricity requirements, separate loads were estimated for the
time periods when working losses are vented to the condenser and
when breathing losses are vented to the condenser. The load
during breathing losses is significantly lower than during
working losses. The inputs to the condenser cost algorithm are
shown in Attachment B.
D. Wastewater at*- gxistinq Sources
Emission control costs for wastewater were developed for
the MACT floor and one regulatory alternative. The MACT floor is
no control, and the regulatory alternative consists of a variety
of control requirements that can be met using one of several
control techniques.1 Cost impacts for the regulatory alternative
were estimated assuming that all facilities use either a steam
stripper to remove HAP from wastewater, or they dispose of
wastewater as a hazardous waste (which is treated by
incineration). Costs were developed for 22 model wastewater
streams representing a total of 30 wastewater streams nationwide;
the selection of these streams is described in the Model Plants
memorandum.*
The total nationwide capital and annual costs, the emission
reduction achieved, and the cost effectiveness of the MACT floor
and the regulatory alternative are presented in Table 4. There
are no cost impacts associated with the MACT floor because the
floor is no control. For the regulatory alternative, it was
assumed that facilities would use the least costly control
technique. Steam stripping was the least costly technique for 21
of the 30 wastewater streams, and hazardous waste disposal was
the least costly for the other 9 wastewater streams. The cost-
effectiveness values for individual streams range from $430/Mg to
$122,000/Mg, and the nationwide average incremental cost
effectiveness of the regulatory alternative is $3,070/Mg.
The estimated capital and annual costs of the control
techniques under the regulatory alternative for each of the
22 model wastewater streams, the emission reduction achieved per
model, the characteristics of each model, and the nationwide
population of each model are provided in Attachment C. An
example cost algorithm for steam strippers and example hazardous
waste cost calculations are also included in Attachment C. The
assumptions and data used to calculate the steam stripper and
hazardous waste disposal costs are described below.
1. Steam stripper system. Costs for steam stripper
systems are based on the approach used for the Hazardous Organic
-------
TABLE 4. WASTEWATER MACT FLOOR AND REGULATORY ALTERNATIVES NATIONWIDE
COSTS FOR EXISTING SOURCES
Option
MACT
floor
Regulatory
Alternative
Uncontrolled
emissions,
Mg/yi*
2,490
2,490
Baseline
emissions,
Mg/yrb
1,530
1,530
Nationwide
TCI,
$
0
9,777,000
Nationwide
TAC,
$/yr
0
2,869,000
Emission
reduction from
baseline,
Mg/yr
0.0
934
Emission
reduction from
baseline,
%
0.0
61
Cost
effectiveness
from baseline,
$/Mg
0
3,070
Incremental
cost
effectiveness,
$/Mg
3,070
The uncontro led emissions consist of 1,340 Mg/yr from streams subject 10 the regulatory app icability criteria and 1,150 Mg/yr rom other
streams.
''The baseline emissions consist of 1,340 Mg/yr from streams subject to the regulatory applicability criteria and 190 Mg/yr from other streams.
-------
14
NESHAP (HON) wastewater control cost analysis.10 The steam
strippers were designed to achieve the fraction removed (Fr)
value for the HAP in the wastewater stream. In estimating the
size of the steam stripper, it was assumed that the wastewater
flow rate would be equal to the annual flow rate divided by the
annual steam stripper operating hours. The operating hours of
•the steam stripper were estimated to be 85 percent of the process
operating hours. The minimum treatment rate was assumed to be
5 gallons per minute (for instances where annual flow rate
divided by operating hours was less than 5 gallons per minute) .
The liquid to vapor ratio was 10.4 pounds of wastewater per
pounds of steam, and the number of theoretical trays was assumed
to be 5. The steam was at 100 pounds per square inch, gauge
(psig) and 350°F. The column flooding rate was assumed to be
80 percent. The wastewater stream enters the feed preheater at
68°F and enters the stripper column at 170°F.
The total equipment cost for the steam stripper system is
equal to the sum of the steam stripper column cost plus the cost
for auxiliary equipment, which includes the wastewater feed tank,
the wastewater preheater, overheads condenser, overheads
decanter, pumps, and a flame arrestor. As in the HON wastewater
cost analysis, the steam stripper column equipment cost was
estimated using the average from two costing approaches. One
costing scenario estimated the cost for the column shell, skirt,
nozzles, manholes, platform, ladder, and trays, and the other
costing scenario estimated the cost for the column shell,
manholes, nozzles, trays, platform, ladder, handrail, and
insulation costs.10
The equipment cost for the feed tank and the overheads
decanter were both estimated based on equations relating tank
capacity to cost. The equipment cost of the overheads condenser
was based on an equation relating the condenser surface area to
cost. Equipment cost for four pumps was estimated from cost
equations relating horsepower and cost. The feed preheater
equipment cost was estimated from an equation relating flow rate
and cost. The flame arrestor equipment cost was estimated to be
$100.10
The PEC for the steam stripper system is equal to the total
equipment cost plus the cost for piping, instrumentation, sales
tax, and freight. Piping cost and instrumentation cost was
estimated to be equal to 30 percent and 10 percent, respectively,
of the equipment cost. Sales tax and freight are equal to
8 percent of the cost for the total equipment, piping, and
instrumentation.
The TCI for all stripper system equipment is equal to the
sum of the PEC for the system and the direct and indirect
installation costs. The direct installation costs are equal to
55 percent of the PEC and include foundation and support,
electrical, erection and handling, painting, and insulation
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15
costs.10 Indirect installation costs include engineering and
supervision, construction and field expenses, startup and
testing, and contingency costs and are equal to 35 percent of the
PEC.10
The TAG consists of direct and indirect annual costs.
•Direct annual costs are costs for labor, maintenance, and
utilities (steam, electricity, and water). Indirect annual costs
are costs for overhead, administrative charges, property taxes,
insurance, and capital recovery.
2. Hazardous waste disposal costs. The cost for hazardous
waste disposal was based on a unit cost per gallon of wastewater
sent for disposal. Cost for disposal were $0.704 per gallon of
wastewater (or $169.02 per ton of wastewater). There are no
capital costs associated with hazardous waste disposal of
wastewater.
E. Equipment Leaks at Existing Sources
Control costs for equipment leaks were estimated for the
MACT floor and one regulatory alternative. For determining the
cost of the regulatory alternative, the costs to control
equipment leak emissions were estimated for 28 of the surveyed
processes based on actual equipment component counts, operating
hours, and estimated control efficiencies for reported LDAR
programs. The control cost estimates for the 175 modelled
processes are based on a batch equipment leak model and a
continuous equipment leak model; there is no baseline LDAR
program for the models.
The regulatory alternative control costs for equipment leak
emissions are based on the LDAR program of 40 CFR part 63,
subpart H. A cost algorithm similar to the one used to estimate
control costs for subpart H of the HON was used to estimate costs
for the PAI industry.12 An example cost algorithm for the batch
equipment leak model is presented in Attachment D. The
assumptions and data used in the cost algorithm are described
below.
The control costs for a LDAR program include capital costs
(equipment costs), indirect annual costs (annualized equipment
costs and annualized initial monitoring and repair charges), and
direct annual costs (maintenance, miscellaneous, and labor
charges).
Equipment costs for each surveyed process and model process
were developed for the monitoring instrument and various parts
used to control emissions. These parts were estimated to cost
$434 for sample connections and $4,176 for pressure relief
devices. The monitoring instrument costs $6,907. The total
equipment cost per model or process is equal to the sum of the
equipment cost for all components.
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16
The TCC is equal to the sum of the equipment cost for each
component type.
The cost for the initial monitoring of liquid valves, gas
valves, pumps, and connectors is based on the component count, a
monitoring cost of $2.50 per component, plus 40 percent for
•administrative charges. The cost for the initial repair is based
on the component count, the initial leak frequency (percentage),
the fraction of components that require repair, the hours
required for each repair, a repair labor cost of $22.50 per hour,
plus 40 percent for administrative and support charges. An
additional repair cost for pumps was included for replacement
seals; this replacement cost is based on the number of pumps, the
initial leak frequency (percentage), the fraction of pumps
requiring repair, and a $191.30 replacement cost for the seal.
The initial leak frequency, the fraction requiring repair, and
the hours for repair are provided in Table 5.
TABLE 5. PARAMETERS USED TO CALCULATE INITIAL AND ANNUAL
MONITORING AND REPAIR LABOR COSTS
Parameter
Initial leak
frequency, %
Subsequent
leak
frequency, %
Fraction
requiring
repair
Hours for
repair per
component
Monitoring
frequency
Gas
valves
11.4
2.0
0.25
4
Quarterly
Light
liquid
valves
6.5
2.0
0.25
4
Quarterly
Pumps
20.0
10.0
0.75
16
Monthly3
Sampling
connections
2.1
0.5
0.25
2
Annually
Pressure
relief
devices
N/A
N/A
N/A
N/A
Annually
aWeekly visual monitoring is also conducted for pumps.
The indirect annual costs consist of miscellaneous charges
and capital recovery. Miscellaneous charges for monitoring
instruments, pressure relief devices, and sampling connections
are equal to 4 percent of the equipment cost. The annual
miscellaneous charges include taxes, insurance, administration,
and other fees. Miscellaneous charges for replacing pump seals
is equal to 80 percent of the maintenance charge for the pump
seals. The total equipment cost and the cost for the initial
monitoring and repair were annualized using capital recovery
factors. The capital recovery cost for the equipment is based on
the capital equipment cost and the appropriate capital recovery
factors for the individual components (see Table 1). The
annualized cost for the initial monitoring of liquid valves, gas
valves, pumps, and connectors is based on the cost for initial
monitoring of each component and the appropriate capital recovery
-------
17
factor for that component. The annual!zed cost for the initial
repair is based on the initial cost to repair each component and
the appropriate capital recovery factor for each component type.
An additional capital recovery cost for repair of pumps is
included for replacement seals.
The direct annual costs associated with the LDAR program
include annual maintenance charges, annual miscellaneous charges,
and annual labor charges. The maintenance cost for the
monitoring device is $4,548. The maintenance cost for pressure
relief devices, and sampling connections is equal to 5 percent of
the equipment cost. The maintenance charge for replacing pump
seals is equal to $191 per pump repaired.
Annual labor charges for conducting the LDAR program are
for monitoring and repairs. The annual labor cost associated
with monitoring of gas valves, liquid valves, pumps, connectors,
and pressure relief devices is based on the component count, the
number of monitorings performed per year, a monitoring fee of $2
per component, plus 40 percent for administrative and support
costs. Labor costs for monitoring of pumps also includes the
cost for visual monitoring of the pump each week; this cost is
based on the number of pumps, weekly monitorings, 30 seconds of
monitoring time per pump, the monitoring labor cost of $22.50 per
hour, plus 40 percent for administrative and support costs. The
annual labor cost for repairing equipment components is based on
the component count, the leak frequency, the number of
monitorings per year, the fraction of components requiring repair
(percentage), the hours required per repair, the repair labor
cost of $22.50 per hour, plus 40 percent for administrative and
support. The leak frequency, fraction requiring repair, hours
for repair, and the monitoring frequency are provided in Table a.
The TAG is equal to the annualized equipment and annualized
initial monitoring and repair costs, the annual maintenance
charges, the annual miscellaneous charges, and the annual labor
charges. A credit of $l,250/Mg of product recovered is included
for materials that are no longer lost to equipment leaks.
The nationwide costs and cost effectiveness of the MACT
floor and regulatory alternative are shown in Table 6. There are
no cost impacts associated with the equipment leak MACT floor
because the floor is no control. The average cost effectiveness
for the regulatory alternative for the equipment leak emission
source is $546/Mg, and the cost effectiveness for the individual
models and processes range from a cost of $30,lOO/Mg to a savings
of $722/Mg. The cost and cost effectiveness for each of the
surveyed processes and each model process for the regulatory
alternative are shown in Attachment D. The emissions reductions
used in these cost-effectiveness calculations were developed in
the Baseline Emissions and Environmental Impacts memoranda. '^
-------
TABLE 6. EQUIPMENT LEAK MACT FLOOR AND REGULATORY ALTERNATIVE NATIONWIDE
COSTS FOR EXISTING SOURCES
Option
MACT
floor
Regulatory
Alternative
Uncontrolled
emissions,
Mg/yr
3,700
3.700
Baseline
emissions,
Mg/yr
3,410
3,410
Nationwide
TCI,
$
0
3,397,000
Nationwide
TAG,
$/yr
0
1,650,000
Emission
reduction from
baseline,
Mg/yr
0.0
3,022
Emission
reduction from
baseline,
%
0.0
89
Cost
effectiveness
from baseline,
$/Mg
0
546
Incremental cost
effectiveness,
$/Mg
546
00
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19
F. Bag Dumps and Product Dryers at Existing Sources
No emission control device costs for controlling
particulate HAP were developed for the existing source MACT
floor. It is assumed that processes with particulate HAP
emissions are already controlled to the floor level for existing
sources, therefore, no additional control equipment is
necessary.1
III. Description of Cost Analysis for New Sources
A. Number of Sources
Average annual growth rates in PAI sales in the 5 years
after the standards are promulgated were estimated to be
approximately 2 percent. The number of new sources manufacturing
PAI is assumed to correlate to the increase in production and
sales, thus an estimated eight new facilities will be subject to
the standards.13 It is assumed that the new facilities will have
emissions points and control devices similar to the emission
points and control devices at existing sources.
B. Process Vents at New Sources
Emission control costs were developed for the new source
MACT floor. A total of 14 new processes are estimated for the 8
new facilities.4 These new processes were modelled using the
same model processes as for existing sources. Control costs for
incinerators, condensers, and water scrubbers were developed
using the same algorithms as for existing; emission reductions
achieved by the devices were also estimated using the same
assumptions as for existing sources (see sections II.A and B).
The MACT floor cost and cost effectiveness for each model
process are shown in Attachment E. The nationwide cost and cost
effectiveness for the process vent MACT floor for new sources are
shown in Table 7. (See the design and cost algorithms presented
in Attachment A. See section II.B for discussion of the
assumptions and data used in each algorithm.)
C. Storage tanks at new sources
Emission control device costs were calculated for the new
source MACT floor. A total of 6 storage tanks subject to the new
source floor are estimated. The new storage tanks were modelled
using the existing source models. The MACT floor control costs
and emission reductions were developed for IFR and condensers
using the same cost algorithms and assumptions as for existing
sources.
The costs and cost effectiveness for the MACT floor are
shown in Attachment F for each new storage tank. The nationwide
cost and cost effectiveness for storage tanks at new sources
-------
TABLE 7. PROCESS VENT MACT FLOOR NATIONWIDE COSTS FOR NEW SOURCES
Option
MACT floor
Uncontrolled
emissions.
Mg/yr
1,572
Baseline
emissions,
Mg/yr
286
Nationwide
TCI,
$
7.771.000
Nationwide
TAC,
$/yr
4.619.000
Emission
reduction from
baseline,
Mg/yr
265
Emission
reduction from
baseline,
%
93
Cost
effectiveness,
$/Mg
17.580
(J
o
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21
subject to the MACT floor are provided in Table 8. (See the cost
algorithm table in Attachment B for IFR and the condenser
algorithm in Attachment A; see sections II.B and C for the
condenser cost discussion and section II.C for IFR cost
discussion.)
D. Wastewater at New Sources
Emission control costs were developed for the new source
MACT floor and two regulatory alternatives. Based on the model
plants analysis, five of the eight estimated new plants were
assumed to have wastewater streams (two represented by model LFr,
two represented by model HFr, and one represented by model HW) .
None of these models exceeds the 2,100 megagrams per year (Mg/yr)
applicability criteria for the MACT floor for new sources (Note:
this result is believed to be reasonable because only one
existing source is known to exceed the cutoff). Therefore, no
control is needed to meet the MACT floor, and there are no cost
impacts associated with the floor.
The control requirements under Regulatory Alternative l for
new sources are the same as under the regulatory alternative for
existing sources.1 In addition, the distribution of wastewater
streams at new sources is assumed to be the same as at existing
sources, and the MACT floor in both cases is no control.
Therefore, the average uncontrolled emissions, the average
control costs, and the average cost effectiveness per stream
under Regulatory Alternative 1 for new sources should be the same
as under the regulatory alternative for existing sources. This
result, however, cannot be obtained using the model wastewater
streams because there are so few streams at new sources that the
models cannot be distributed in the same ratio as at existing
sources. Therefore, emission control costs for regulatory
alternative 1 for new sources were estimated using data from the
analysis for existing sources. As shown in Table 4, the TAC
under the regulatory alternative for existing sources was
$2.87 million. This value was divided by 30 (the number of
streams at existing sources) to obtain the average cost per
stream. This average value was then multiplied by 5 to estimate
the nationwide TAC for streams at new sources. Similar
calculations were used to estimate the emissions and emissions
reductions for new sources. Thus, the cost effectiveness of
Regulatory Alternative 1 for new sources is $3,070/Mg, the same
as for existing sources. The nationwide cost and cost
effectiveness for wastewater streams at new sources under
Regulatory Alternative 1 are presented in Table 9.
Relative to Regulatory Alternative l, the applicability
requirements under Regulatory Alternative 2 consist of smaller
flow rate cutoffs and lower HAP concentration cutoffs.1 The
models used in the analyses for existing sources were not based
on streams with these characteristics. Therefore, the emission
control cost analysis for Regulatory Alernative 2 was based on
-------
TABLE 8. STORAGE TANK MACT FLOOR NATIONWIDE COSTS FOR NEW SOURCES
Option
MACT Floor
No. of
tanks
controlled
nationwide
6
Uncontrolled
emissions,
Mg/yr
3.10
Baseline
emissions.
Mg/yr
2.91
Nationwide
TCI,
$
654,000
Nationwide
TAC,
$/yr
494.100
Emission
reduction Tram
baseline.
Mg/yr
1.08
Emission
reduction
from
baseline,
%
37
Cost
effectiveness,
$/Mg
458.100
TABLE 9. WASTEWATER MACT FLOOR NATIONWIDE COSTS FOR NEW SOURCES
Option1
MACT floor*
Regulatory
Alternative r
Uncontrolled
emissions.
Mg/yr
0
223.5
Baseline
emissions,
Mg/yr
0
223.5
Nationwide
TCI,
$
0
1,629,000
Nationwide
TAC.
$/yr
0
478.000
Emission
reduction from
baseline,
Mg/yr
0
136.3
Emission
reduction from
baseline,
0
61
Cost
effectiveness,
$/Mg
0
3.070
Incremental
cost
effectiveness,
$/Mg
3.070
M
•Regulatory Alternative 2 is not shown. See the discussion of the new source Regulatory Alternative 2 in the text.
Ml is estimated that there are no wastewater streams that will be subject to the new source MACT floor. Therefore, there are no costs or emission
reductions.
The costs and emission reductions for Regulatory Alternative I are based on the average emissions and cost per stream for existing source
wastewater streams. The emission reduction and percent reduction from baseline is equal to the percent reduction achieved for existing sources
(61 percent). The cost effectiveness is also equal to the cost effectiveness for the existing source regulatory alternative.
-------
23
information about the individual streams at the surveyed plants
that would meet the more stringent applicability criteria. A
total of 10 additional streams at the surveyed plants would meet
the applicability criteria under Regulatory Alternative 2. Two
of the streams are from processes that have other wastewater
streams covered under Regulatory Alternative 1, and eight streams
are from processes that have no streams covered under Regulatory
Alternative 1. Characteristics of the 10 streams are presented
in Attachment G. In the Model Plants analysis, nine of these
streams were models that each represented two streams nationwide,
and one represented three sreams. Just as in the analysis for
Regulatory Alternative 1, the distribution of streams at existing
and new sources is assumed to be the same. Therefore, the
incremental cost-effectiveness of Regulatory Alternative 2 would
be approximately equal to the overall incremental cost
effectiveness for the 10 streams; the actual number of streams
that would be subject to Regulatory Alternative 2 does not need
to be estimated. The control costs were developed for steam
strippers and disposal as a hazardous waste (with treatment by
incineration). The results of the analyses are shown in
Attachment G; the cost effectiveness values range from $3,290/Mg
to $2.2 million/Mg for the individual streams, and the overall
cost effectiveness is $226,000/Mg. Thus, even if the
distribution of streams at new and existing sources differ, the
incremental cost effectiveness of Regulatory Alternative 2 would
be high. (See the cost algorithm for steam strippers in
Attachment C. See section II.D for discussion of the steam
stripper costs.)
E. Equipment Leaks at New Sources
Control costs for equipment leaks were estimated for the
new source MACT floor. A total of 18 new processes subject to
the new source MACT floor for equipment leaks have been
estimated, and the equipment leak control cost is based on
component count models of these 18 processes. Just as for
existing sources, control costs are based on the LDAR program of
40 CFR part 63, subpart H.
The costs and cost effectiveness for each model process are
shown in Attachment H. The nationwide cost and cost
effectiveness for equipment leaks at new sources are shown in
Table 10. (See the equipment leak cost algorithm in
Attachment D. See section II.E for the discussion of equipment
leak costs.)
F. Baa Dumps and Product Drvers at New Sources
No control device costs for controlling particulate HAP
were developed. It is assumed that processes with particulate
HAP emissions are already controlled to the new source floor
level and there are no costs for additional control equipment.1
-------
TABLE 10. EQUIPMENT LEAK MACT FLOOR NATIONWIDE COSTS FOR NEW SOURCES
Option
MACT
floor
Uncontrolled
emissions.
Mg/yr
379
Baseline
emissions.
Mg/yr
379
Nationwide
TCI,
$
317,000
Nationwide
TAG,
$/yr
143,400
Emission
reduction from
baseline,
Mg/yr
339
Emission
reduction from
baseline.
%
89
Cost
effectiveness,
$/Mg
423
to
-------
25
IV. REFERENCES
1. Memorandum from D. Randall and K. Schmidtke, MRI, to
L. Banker, EPA:BSD. April 30, 1997. MACT Floor and
Regulatory Alternatives for the Pesticide Active Ingredient
Production Industry.
2. Memorandum from D. Randall, K. Schmidtke, and C. Hale, MRI,
to L. Banker, EPA:BSD. April 30, 1997. Baseline Emissions
for the Production of Pesticide Active Ingredient Industry.
j. Memorandum from D. Randall and K. Schmidtke, MRI, to
L. Banker, EPA:ESD. April 30, 1997. Environmental Impacts
for the Pesticide Active Ingredient Production NESHAP.
4. Memorandum from D. Randall and K. Schmidtke, MRI, to
L. Banker, EPA:ESD. April 30, 1997. Model Plants for the
Pesticide Active Ingredient Production Industry.
5. OAQPS Control Cost Manual. Fourth Edition.
EPA 450/3-90-006. January 1990. Chapter 8. Refrigerated
Condensers.
6. Memorandum from B. Shine, MRI, to R. McDonald, EPA:BSD.
July 14, 1993. Enhanced Monitoring Costs for Polymers and
Resins II NESHAP.
/. OAQPS Control Cost Manual. Fourth Edition.
EPA 450/3-90-006. January 1990. Chapter 3. Thermal and
Catalytic Incinerators.
8. OAQPS Control Cost Manual. Fourth Edition.
EPA 450/3-90-006. January 1990. Chapter 9. Gas Absorbers.
9. Alternative Control Techniques Document: Volatile Organic
Liquid Storage in Floating and Fixed Roof Tanks. EPA
Publication No. EPA-453/R-94-001. January 1994. p. 6-29.
10. Memorandum from D. Whitt, Radian, to D. Markwordt, EPA:CPD.
June 5, 1991. Impacts from the Control of Volatile Hazardous
Air Pollutant Emissions from Equipment in Non-SOCMI Process
Units for HON.
11. Engineering Cost Model Documentation Report for the
Pharmaceutical Manufacturing Industry. Prepared by Radian
Corporation for U. S. Environmental Protection Agency, Office
of Water. February 28, 1995. pp. 2-8 and 4-29.
-------
26
12.- Memorandum from K. Scott, Radian, to M. Kissell, EPA.
June 30, 1993. Steam Stripper Total Capital Investment and
Total Annual Costs.
13. Memorandum from K. Schmidtke, MRI, to L. Banker, EPA:BSD.
January 6, 1997. Growth Projections for the Pesticide Active
Ingredient Production Industry.
-------
ATTACHMENT A
Costs and Cost Effectiveness Tables for the Process
Vent MACT Floor and Regulatory Alternatives for
Existing Sources
Example Condenser, Incinerator, and Scrubber Cost
Algorithms for Process Vent Models 2d and 2c
-------
4/2M7
MACT FLOOR COSTS. EMISSION REDUCTIONS. AND COST EFFECTIVENESS FOR PROCESS VENTS (OVERALL)
PAINESHAP FILE F \PROJECT\AGCHEMS\OATADOR\PVCOSTEF XLS
TAG
HAP
HAP
CcnM
JSL
JSL
J£L
Tott
JL
TAC.SV
ermnlei
Mgiyr pwprocts*. pvpranw. ptrprottu. pwpracM. redjcton. •MclMnui,
CM
tvm
*M8_
d
c
d.«H
4H
C.MH
C.H
d
c
d.noH
4H
C.HBH
ftH
i.o.H
1}
as
8
4
»
2
T
7
9
3
3
1
n
I
29
431X100 8.189.000
302X100 12.966,000
401.000 4.010.000
479.000 2.379.000
143X100 898.000
145,000 290.000
972.000 12.636,000
160.000 1.280.000
918.000 7344X100
3 MWMtfMruttMr 1.446.000 4338000
3 candMitr 216.000 648.000
1 KntttrfcondrnMr 226.000 278.000
1 •autbtr 928000 928.000
218.000
123.000
186.000
289.000
85.000
137.000
831.000
62.600
692000
942000
76.900
210.000
249000
4.142XX»
9.289.000
1.880.000
1.329X100
910X100
274XWO
10.803X100
9.936XMO
2.826000
230.700
210.000
249000
13.7
137
40
40
40
40
41
41
102
102
102
102
102
0
0
881
681
681
66.1
0
0
299
295
299
299
299
0
0
179
179
0
0
0
0
878
678
0
0
0
137
• 137
1240
1240
108.1
108.1
41.0
41.0
484.8
4846
3*70
3970
3*70
11
27
13.0
24.8
120
21.2
62
82
42.2
93.0
38.1
794
04
1.4
1*
1,6
4.7
47
0.6
4t
9.7
9.7
132
29
14
114
23.2
7.3
16.6
74
4.1
36.9
673
29.0
663
961
46.9
98.9
114.0
119.8
43J
331
99.9
32.8
292.0
2619
74.9
66.3
961
88.400
60.800
122
(b)
argirtcHAP.tUnoIHa
99.708.000 33.779.900
c HAP eaneamion. -H- mnm •dMdral HO eonrol It ntcdid. TOT
1236
tMMACTftxirlor
11.400
11.000
8.300
111600
19.300
19000
10.800
3.100
3200
4.400
27.321
«m Ma bmd on tw drttulen ri nivnyM (HmH
on. procwthrt Ha eo(*d t«to« 1^ HACT floor lM(o(»4p«e«rt.l)UOf9irtc HAP
94,97.70.89.wiiJSO'Mr«ri|ir*MnMroc•slM27.3l.tnd9l«•r•r•pr•Mrt•d*l^mlxl•l44|ne•H 1»wt»«fco
*Mi mod* 4d. M ««hBU t» nMd f or MmonM canfrok tor orgwfc HAP
irtd rtiinanlillnvKUrMmxindLmlMc«uMli«i^^ AlM.tMtnMramMnMiiipteliaralyilKMnal
IndUd* HO CTMtod In canlurtorvtaud cflnrd
-------
4OM7
REGULATORY ALTERNATIVE 1 CO6T8, EMISSION REDUCTIONS, AND COST EFFECTIVENESS FOR PROCESS VENTS (OVERALL)
PAINESHAP FILE F \PROJECTWJCHEM8\DATAOOR\PVCOSTEF XL8
I AC
Contol
Iff
MrprocMi. pvprooiti. pvpracMi, Mr proem,
TAC.IM TAC.tMlll
c
AnoH
*M
«.r*H
•.N
II
»
AH
«,MH
e.M
41H.M
t.MKM
I.HM
«.«•
4MH.M
4 KM
C.MHW
•.KM
II
I?
)
n
in
oa.ni.ooo
U.M7.1W
•0,000
11.900
1.000
1.WO
•XMO
9.000
111.100
II?
117
40
40
40
40
41
41
102
101
107
101
102
117
40
40
10
40
41
102
102
102
102
0
0
Ml
Ml
Ml
Ml
0
0
2M
2M
2M
2M
2M
0
Ml
Ml
Ml
M.I
0
2M
0
0
171
17 •
0
0
0
0
171
171
0
0
0
0
179
17J
0
0
0
•7J
•71
0
0
117
117
1240
1240
1M1
101.1
410
41X1
4841
4MJ
M7X>
uro
W7X)
11.7
1240
1240
IM.1
IMI
41.0
4M1
4141
M7«
mo
01
1.4
1.1
\»
47
4.1
01
4.1
17
17
111
l»
112
1.4
II
1*
47
4.7
4.1
47
8,7
IU
1U
01
14
1.6
1*
47
47
OJ
41
67
17
112
IU
111
M
1J
14
16
16
01
67
67
10
6.0
00
06
00
0.0
00
00
OX>
OX)
OA
0X1
00
OX!
ox>
1.1
OA
OX)
12
12
11
OX)
OX)
1.2
U
00
0X1
0.0
OX)
oo
OX)
00
00
0X1
00
00
00
oo
6.6
00
00
160
1.1
u
OX)
OX)
•00
1400
1.100
1,100
»mMMi2>.10,61 M.M. 7l
2c(«ri
44 (raMM 27 Ma MMli •• CMM Ml M% canM el VfMc HAT >. mem I* «M Me
In Mdlon.m proem hMHCIeonMb«oi»MUMTtoerta^«(MpMMrt.tMorgMe HAP
l>««cf«wi7.M,»7.70.M.indBOMrara«r«MnM«»Mo«MM
27. 11. •*•
Mniriiati*i(f«lwliiiieoiiy)erdM*lttMii,tntcandBMri««ralMi(«iiiy»t»««rt»«>»^
> MO cmtjl m tailmaai titniJ iun>«l
-------
REGULATORY ALTERNATE* 3 CO8T8, EMISSION REDUCTIONS. AND COST EFFECTIVENESS FOR PROCESS VENTS (OVERALL)
PAINE8HAP FILE F \PROJECT\AOCHEMS\OATAOORVPVCOSTEF XLS
TCI
TAG
HAP
JIL
JBL
JSL
Coftol
**•"«
NMomM*
J_
u»y
Jtt tAC.Vlf TAG. W 1.1 orartt. MO
CmM
HO
Mtiton
Mrtr MGftrM HrtftM
I**""
11
CM
C.MM
C.H
4
C
AM
c.noH
C.H
».*H
C.W
4XMHM
4H.M
C.MKM
C.H.M
C.M
AN.M
C.KOH.M
C.H.M
n
IT
i
411000
H6.000
401,000
470.000
IN 000
111.000
177000
111.000
•11000
1.441.000
191000
712,000
todnmtarftcruUNr 1,440.000
w ooo
401.000
479.000
1MOOO
111.000
111.000
0*1.000
1.440.000
2U.OM
MnMxrfcandMMf MI.OOO
l»
I.1M.OOO
ii.in.ooo
ioo> ooo
I.4M.OOO
150.000
101.000
120M.OOO
I.N?.000
4 SOO 000
1 440.000
604.000
0
1.440.000
2.110,000
401,000
990,000
7W.OOO
111 ooo
101.000
3.794000
2.0*2,000
293.000
2*3000
oo.iu.ooo
210.000
1M.OOO
1MOOO
MS 000
MIOO
140000
•11.000
17.000
on ooo
•42.000
S9.900
210.000
•41.000
110,000
1U.OOO
2*9000
H.100
140.000
17900
107000
•43000
09.KO
211.000
4.147000
9.100400
1.0*3,000
7*9.000
MIOO
10J01MO
479100
1.400.000
•43.000
171.400
0
•41,000
•21.000
tu,ooo
910.000
440.000
140.000
•MOO
2.071.000
1.0M.OOO
10(00
210.000
0
990.000
0
0
1.100
1.000
0
17.100
0
0
19.000
0
902,000
0
0
0
0
0
0
0
0
117
117
40
40
40
40
41
41
102
107
107
103
102
1)7
40
40
40
40
41
102
103
102
102
0
0
0(1
Ml
Ml
Ml
0
0
2M
2W
299
299
2W
0
Ml
Ml
Ml
Ml
0
3n
3M
2M
0
0
171
IT*
0
0
0
0
174
171
0
0
0
0
171
17 •
0
0
«
171
0
0
117
117
1340
1340
1011
1M1
410
410
4140
4949
1870
»70
1070
11.7
1240
1340
m i
1011
410
4M1
4MI
M70
W70
01
11
1C
K
47
IT
01
41
97
97
113
113
113
0.1
10
10
19
19
0*
97
9.7
90
00
01
04
1*
10
01
00
97
97
90
AA
90
01
1«
tl
10
10
01
07
• T
00
90
00
II
00
00
13
13
00
31
00
00
•3
0.3
03
0,0
00
00
00
00
00
00
00
00
00
00
400
00
00
13
13
00
no
oo
oo
101
•A
13
00
00
0.0
00
00
00
00
00
00
00
0
11.700
1.000
no
1.00
1.10
04.10
19219900 1.101.300
1M90
(1»V
M MMT toor tor vfvM HAP M ml HO; IT
ccmirtaMc**irMHAPecTBirMtoriWnii«miMI»n*i^
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TfMamtu0artttit»Mficlu« mtemmtMtinnuuuitv not* I m<3
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•nc4MM30 30.00 00 M.71.77.M*7lMr*r«(raMflMiMiiHoM 1c tnctn*91.M.irtMw**t^n**a**mo&MUnt»utl•&!•&&ttt»mwlHaai+**im»tt»»aB\.fnc»*tllw»*
«7c(li«NinMlir<»crlMrtilo>M%cinM«l«gir»cNAP| PracMtM 1.7.1.4 II >^»m rm Hiu miff k«lrartlviMr«ti*lMMco*lylo>dMiitMni.in4ccn4t«Mrt«MralHMco«tyl«
(•I
lai MHcor*dinlvllAlbiciiMKA3ilMraajJr«»MHMnMI
Thttn«mtflM»ii«im> niKHr 1 11 I'-mrtntrtrrmT-t-- rritj1"* --- TI -- " T •••-*-rr- •••yi'i *X> •»
!•><§ in iiiiartlii i mli«l»i mil <•• m Hi TII
-------
07-Jan-97;
CONDENSER COST ALGORITHM (MACT floor)
Model number:
Reqpired condenser control efficiency:
Variables and «qutiiom
Wane Gas Parameters
MaasfluxofHAP.Ib/yr
Ftowrat*. adm
Flowrate. adm
Temperature. degrees C
-degreaaC
- degrees F
HAP molecular weight
VOC mote fraction
VOC uitumuauoa. ppmv
Noo condenaable mole fraction
Operating houn
Vent
Control device
Ratio of HAP venting time to
eonlrol device operating tone
Coodeoacr design calculation
HAPpoUuiaot
Antoine equation constants
A
B
C
HAP partial pratwre at outlet, am Hg
• assume* idea] fas
HAP mole fraction at outlet
Condensation temperature
C
F
Condenser exit flowrate. ftJAntn
HAP erhical temperature
Molar heat ofoondematioa, BOi/lbmole
-»t23dcgreesC
• atTCON
Molar beat capacity of RAP. Btu/lbmolc/deg F
Molar beat capacity of air. Btuflbmole/dej F
Average characieriftiei during vcnttn( events
HAP in inlet sown
-Ibmote/hr
2
0.9 eff
taUOO
21 Qin
21
25
77 Tin
7CO Plot
S3 MWhap
0.11324 yb
113^33
O.SMI
2.WO Vh
f.760 COh
OJ196 Ratio-WCOh
MeCU
7.409 A
1325.9 B
232.6 C
0.01261 voufPP/Ptot
-46J2 Tdcgc-((B^(A-loglOPP)>C)
-5U7 TCON-CTdtgcXl l>*-32
14J5
13.005 Hoon
32JO Cphap
6.93 Cpair
OJ640 Min-(QinXyinXA>inBVbryp92sft3/lbmole)
30^4
HAP in outlet stream
-Ibmolelv
-IMu-
Heat load. Bu/hr
Enthalpy change of condensed HAP
Enthalpy change of noncondenaed HAP
Enthalpy change of noncondensible 'air
Tout enthalpy change
-Btu/hr
• tons
Heat load during ran venting periods
• Beu/hr (aasumed to be 10H of max toad)
• tons
Total annual condenser heal load. BoVyr
Log mean temperature difference, deg F:
Coolant flow rate. Ib/hr
0.036397 Mout-(MiDXl-cfl)
3.094 LBout-fMoutXMWhap)
5.6IS OELHcon-(Mb>MoiitXHcoiKCphapXTin-TCON))
151 DELHimeon-(MoutXCphap)(rttvTCON)
UI2 LOADims-DELHcon+DELHuncorH-DELHair
0.693 Rmax-(LOADmaxyi2.000
S31 LOADmin-(LOAI>roaxXO.l)
0.069 RnwKLOADnuiiyi2.000
21221.007
49.90
511 Qcool
-------
07-Jan-97; PVMODCST.WB2
(design parameters
Diameter of collection miin (ft):
. calculated Mwming a velocity of 2.000 ft/rain
Length of dud ft
Tool number of vents
Number of elbows per vent
[ficton:
Operator labor wage rate. S/hr
Maintenance tabor wage rate. SVhr
Operating labor. hi/Mr operation
Supervisory labor. W of operating labor
Maintenance labor. hf/t-fa- operation
Monitoring maintenance labor. hr/8-hr operation
0.116 rx(4XQiny2,000/PirO.S
300 L
6 Vents
2 N
$15.64 WRo
$17 JO WRm
0.5
15
05
0.5
|Uilityr«quirenient»
Electricity, kwfafyr
IChaaical Engineering Map
June 1995 plant index
Feb 1989 plant index
August 1990 plant index
tot cons (June 1995 dollars)
Detonation armor. Stem
Stainless round duct, S/ft
Elbows. S/a
Automatic damper. S/ea
Refiigeralion uah east, $
•multistage packaged unh
19.449
+3.446nCDh/0.85)
382
352.4
354.8
5.000 OAooe
4.22 Oucf-(0.t5XQinrOJ(3t2O52 4)
6.97 Eone-<0.t5X1.65XQinr0.5(3K/352.4)
791.16 ADooc«(215*QinA0.5+723X3S2O524)
25.469 RU-<«p(9.73-0.012TCON*0 3«4»
Cipital Coos (June
Packaged refrigeration system
- includes instnunentatioo
Auxiliary equipment (manifolding) costs
Automatic damper (sastimr 1 per manifold)
Total rouod duct cost
Total elbow coat (2/Veot)
Detonation arresters (I/vent)
Total
Purchased equipment cost
Packaged refrigeration system
Auxutary equipment
Installation cost
Packaged retngeration system
Auxiliary equipment (assume equal to PEC)
Monitoring costs
Initial Performance test for condenser
Thermocouple and datalogger
TOTAL CAPrT AL INVESTMEiTT
Annual Costa." JVyr
Direct annual costs
Operating labor
Monitoring labor
Supervisor labor
31.836
791 AD-ADooe
U67 RD-(DuciXL)
84
30.000 DA-
-------
Maiaunanee labor
: material* (supplra):
Qeetnaty.
Indina annual
OvabMd
Capital Rmvay
. CRF. 0.109S. bawd oa 13 yn and 7%
TOTAL ANNUAL COST. Vyt
07-Jan-97; PVMOt)d
9.419 ML-(O.J hr^hr shiftXWRmXCOh)
9.419 MM-ML
500 MONNI
1.14t ELEO(KutXS0.059/toift)
23.420
3.713 PTU-(0.04XTCO
CR-(CRFXTCO
•KHPTIA+CR
induction. Ma/yr
COST EFFECTIVENESS. Sftfg
34.04
S2JJI
-------
07-Jan-97; PVMODCST.WB
CONDENSER COST ALGORITHM (Reg alt)
Model number
Required condenser control efficiency:
Wisu Gas Parameteri
Mass flux of HAP. Ib/yr
Flovmle. sefin
Flownte, acfin
Temperature, degrees C
• degrees C
• degrees F
Premre. mm Hg
HAP molecular weight
VOCmofcfiaclion
VOC concentration, ppmv
Variables and equations
Noo condensable mole fraction
Operating hours
Vent
Control device
Ratio of HAP venting time to
control device operating time
Cuudfliicr design
HAP pollutant
Anloine equation eonsunts
A
B
C
HAP partial preswre at outlet, mm Hg
- assumes ideal gas
HAP mole fraction at outlet
Condcnsalioo lemprnntre
- degrees C
- degrees F
Condenser exit flowrate. ft3/min
HAP critical temperature
Molar heal of condensation. Btu/lbmole
-at 25 degrees C
• aiTCON
Molar bemt capacity of HAP. Btu/lbmole/deg F
Molar beat capacity of air. Btu/lbmole/deg F
Average characteristic* during vetting events
HAP in mkt stream
-Ibmole/hr
-Ib/hr
HAP in outlet stream
2
0.98 eff
88^00
21 Qin
21
23
77 Tm
760 Plot
85 MWhap
0.11324 yin
113.235
0.8868
2.800 Vh
8.760 CDh
OJ196 Ratio-WCDh
MeCQ
7.409 A
1325.9 B
252.6 C
1.936
0.00255 yout-PP/PlM
Tdegc-((B/(A.|oglOPP)>C)
TCON-(TdegcX1.8>*32
12.95
-Ib/hr
Heat load, Btu/nr
Enthalpy change of condensed HAP
Enthalpy change of noocondensed HAP
Enthalpy change of nonoondensrble "air*
Total enthalpy change
• Bni/hr
-tons
Heat load during non venting periods
- Btu/to (aoumed to be 10S of max load)
-tons
Total annual condenser heat load. Blu/yr
Log mean temperature difference, deg Fr
Coolant flow rate. Ib/hr
13.005 Hcon
32JO Cphap
Cpair
OJ640
30.94
0.007279 Mout-(MmXl-efi)
0619
6.535
39
DELHce«-(Miii-Mo«XHcairKCphapXTm-TCON))
DELHunconHMoutKCphapXTm-TCON)
9.834 LO.^Dmax-DELHcon-DELHuncon-DELHair
O.S19 Rma.T-(LOADmaxyi2.000
983 LOADmb-(LOADin«XO 1)
0.082 Rmm^LOADmmyi2.000
33J95.783
49.90
605 Qcool
-------
07-Jan-97: PVMODCS
Manifolding design parameters
Diameter of collection main (ft):
• calculated •—• mine * wlocfty of 2.000 ft/nun
Length of duet, ft
Total number of vena
Number of elbows per vent
Casting frcton:
Operator labor wage rate, &nr
Maintenance labor wage rate. S/hr
Operating labor, hr/t-br operation
Supervisory labor. % of operating labor
Maintenance labor. hr/8-ar operation
0.1 i«
300 L
6 Vents
2 N
$15.64 WRo
S17.20 WRm
0.3
13
OJ
0.3
Utility requir
Eketrieity.kwIV'yT
Chemical Eogineertiig Maga
: Co« lade
June 1995 plant index
Feb 1989 plant index
August 1990 plant index
Unit
(June 1993 dollar*)
Detonation arrester. SVea
StaiaUcs round duo. S/ft
Elbows, yea
Automatic damper. S/ea
Refrigeration unit eon. S
-muttisuge packaged unit
Capital Costs (June 1995 dollars).S
Eojutpmeot cocts. S
Packaged refrigeration system
- includes iasownenution
Auxiliary equtpmenl (manifolding) costs
Automalic damper (assume 1 per manifold}
Total round duct cost
Total elbow cost (2/vent)
Detonation arrcstors (1/veot)
Total
3U77
3R
352.4
334.1
5.000 DAone
432 Dua-(O.S3XQmr0.3(3*2/352.4)
6.97 Eone-(0.«X1.65XQinr0.5(3«1352.4)
791.16 ADooe-(215'Qin-0.5*722X3«i052.4)
35.761 RU-(exp(9.7M.012TCON-H)JI4-ta(RroM))X38XOJ4.8)
44.710 ECR-(1.25XRU)
791 AD-ADooe
U67 RD-(DuaXL)
84 Eall-
-------
07-Jan-97; PVMODCST.WE
Overhead 23.420 O^.«XOL+SL+ML+MONX-.\IM-MONM)
m.intuniMe,aAniniiniivectivgn: 6JJ2 PTIA-(0.04)(TCI)
Ctpiul Recovery 17.437
- CRF. 0.109«. bwed on 15 yn and 7S toetett
TOTAL ANNUAL COST. S^r tl.0>7 TAC-OL+SL»ML*MM*MOSL+NUDNM-ELEC
EoiMioo reduction. Mo/yr 39.24
COST EFFECTIVENESS. S/M( $2^45
-------
08-Jan-97; PVMODCST.WB
IOTAL ANNUAL COST SPREADSHEET PROGRAM-GAS ABSORBERS [1]
COST BASE DATE: Third Quarter 1991 [2]
VAPCCI (Second Quarter 1995): [3] •- 100.1
INPUT PARAMETERS:
srr
Wei inputs
-Model number
-Gas conditions out of process or incinerator
- Gas flow rate, scfin
- Gas temperature, deg. F
-Gas conditions into absorber (saturated)
- Gas flow rate, scfm
•- Gas temperature, deg. F
- Inlet HC1 concentration, mole fraction
-Vent operating hours, hr/yr
-Control device operating hours, hr/yr
Sueam parameters:
- Inlet waste gas flowrate (acfrn): 16
-Inlet waste gas temperature (oF): 65
-Inlet waste gas pressure (atm.): 1
-Pollutant in waste gas: Hydrogen chloride (HC1)
-Inlet gas poll, cone., yi (mole fraction): 0.444
-Pollutant removal efficiency (fraction): 0.99
-Solvent; Aqueous caustic soda
-Inlet pollutant cone, in solvent: 0
-Waste gas molecular weight (Ib/lb-mole): 29.00
- Solvent molecular weight (IbAb-mole): 18
-Inlet waste gas density (Ib/ft3): 0.0757
-Solvent density (Ib/ft3): 62.4
-Solvent specific gravity: .1
- Waste gas viscosity @ inlet temp. Ob/ft-hr): , 0.044
-Solvent viscosity @ inlet temp. (Ib/ft-hr): 2.16
- Minimum wetting rate (ft2/hr): 1.3
- Pollutant diffusivity in air (ft2/hr): 0.725
-Pollutant diffusivity in solvent (ft2/hr):
Packing parameters:
-Packing type:
- Packing factor, Fp:
-Packing constant, alpha:
-Packing constant, beta:
-Packing constant, gamma:
-Packing constant, phi:'
••Packing constant, b:
-Packing constant, c:
-Packing constant,]:
-Surface area-to-volume ratio, a (ft2/ft3):
-Packing cost (S/ft3):
0.000102
1-in ceramic Raschig rings
160
6.41
0.32
0.51
0.00357
0.35
0.97
0.25
58
35
1-in ceramic Raschig rings
160
6.41
0.32
0.51
0.00357
0.35
0.97
0.25
58
35
-------
08-Jan-97; PVMODG
DESIGN PARAMETERS:
- Material of construction (see list below):[4]
- Inlet pollutant concentration (free basis) (Yi):
-- Outlet pollutant concentration (free basis) (Yo):
- Out. eq. poll. cone, in solv., Xo* (op. line):
- Theoretical operating line slope (Ls/Gs,min.):
-- Ls/Gs adjustment factor:
— Actual operating line slope (Ls/Gs, act.):
~ Gas fiowrate, Gs (free basis, Ib-moles/hr):
— Solvent flowrate, Ls (free basis, Ib-mol/hr):
— Gas flowrate, Gmol.i Qb-moles/hr):
— Solvent flowrate, Lmol.i (Ib-moles/hr):
— Outlet actual pollutant cone, in solv., Xo:
— Gas poll. cone, in eq. with Xo (Yo*):
- Outlet solv. poll. cone, (mol frac basis.xo):
— Gas poll, cone., yo* (mole fract. basis):
— Outlet gas poll, cone., yo (mole fract.):
-- Slope of equilibrium line (m):
- Absorption factor (AF)—first calculation:
- ABSCISSA (column diameter calculation):
- ORDINATE (column diameter calculation):
- Superficial gas flowrate, Gsfr.i (Ib/sec-ft2)
- Hooding factor, f:
- Column cross-sectional area, A (ft2):
- Superficial liq flowrate (Ib/hr-ft2) (Lsfr.i):
— Minimum liquid flowrate (Ib/hr-ft2):
- If Superficial liquid flowrate is < minimum
needed, the minimum must be used to calculate
tower area and diameter (iteratively):
— guess A iteratively until the two
ORDINATE values below agree, ft!
— recalculate Lmol.i
- calculate ABSCISSA for Fig. 9.5
- calculate Gsfr.i from Eq. 9-21
- calculate ORDINATE for Fig. 9.5 using
eq. 9.54
- calculate ORDINATE from eq. 9-19
- Absorption factor—based on min liq flowrate
~Xo
- xo
- AF
~ Values to use in subsequent calculations
- Lsfr,i
--A
- Gsfr,i
--AF
- Column diameter, D (ft2):
-- Number of transfer units, Ntu:
- Gas film transfer coefficient, Hg (ft):
-- Liquid film transfer coefficient, HI (ft):
-- Height of a transfer unit (ft):
-- Packing depth (ft):
-- Column total height (ft):
-- Column surface area (ft2):
— Column gas pressure drop (in. w.c./ft packing):
1
7.985612E-01
0.0079856
27
0.23532
0.2763
0.0785
0.0788
1.21E-02
1.23E-02
7,144.47
4,705
0.102
0.2763
7,144.47
4.027
0.625
0.969
0.625
2.516
6.70
7.8
1.017
check for each model
4.9411
1.5
7.4116
1
10.09
2
10.09
v
i check for each model
*
0.0964
0.0001
0.00792
0.00104
7144.47
0.16020
0.0971
0.3071
0.7
0.05
3559.64
4,705
-------
08-Jan-97; PVMOOCST.WB
, Column liquid pressure drop (ft of H2O): 60
- Packing volume (A3): 0.3
CAPITAL COSTS:
Equipment costs (S):
.Gas absorber 896
- Pump (assumes S 16/gprn) 15
-Packing 9
-Total (base) 920
' (escalated) 1.026
Purchased Equipment Cost (S): 1.210
Total Capital Investment (S): 2,662
ANNUAL COST INPUTS:
Control device operating factor (hr/yr): 8.760
Vent operating factor, hr/yr 2.800
Operating labor rate (S/hr): 15.64
Maintenance labor rate (S/hr): 17.20
Operating labor factor (hr/sh): 0.0
Maintenance labor factor (hr/sh): 0.5
Electricity price (S/kWhr): 0.059
Caustic price (S/ton): 300
Solvent (water) price (S/1000 gal): 0.2
Wastewater trtmt cost (S/1000 gal): 3.80
Overhead rate (fraction): 0.6
Annual interest rate (fraction): 0.07
Control system life (years): 15
Capital recovery factor (system): 0.1098
Taxes, insurance, admin, factor: 0 04
ANNUAL COSTS:
Item Cost($/yr) WL Factor W.F.(cond.)
Operating labor 0 0000 —
Supervisory labor 0 0.000 —
Maintenance labor 9.419 0.182 —
Maintenance materials 9.419 0.182 —
Electricity (5) 4 0.000 —
Caustic 18.627 0.359 —
Quench water 0 0.000 —
Solvent (water) 134 0.003 —
Wastewater treatment 2.539 0.049 —
Overhead 11.303 0.218 0.581
Taxes, insurance, administrative 106 0.002 —
Capita] recovery 292 0.006 0.008
Total Annual Cost 51.844 1.000 1.000
NOTES: .
[1] This program has been based oft data and procedures in Chapter 9
of the OAQPS CONTROL COST MANUAL (4th edition).
-------
08-Jan-97;
PVMODCsl
[2] Base equipment costs reflect this date.
[3] VAPCCI - Vatavuk Air Pollution Control Cost Index (for gas
absorbers) corresponding to year and quarter shown. Base equipment cost,
purchased equipment cost, and total capital investment have been
escalated to this date via the VAPCCI and control equipment vendor data.
[4] Enter one of the following: fiberglass-reinforced plastic (FRP)-T
; 304 stainless steel-'1.4'; porypropylene-'0.95'; polyvinyl chloride
(PVQ-'0.70'.
[5] Does not include electricity for fan because fan electricity is
included in the incinerator or condenser algorithm.
-------
07-Jan-97; PVMODCST.V.
THERMAL INCINERATOR COST ALGORITHM
Proem vent* mod*):
Waste gas parameters
I. MM flux of HAP. lbr>T
I. Vohimtric flow ml*, tcftn
3.HAPeaaentralioa.pemv
3. Assumed heating value of HAP*. Boj/scf HAP
4. TcBpcHiure, deg, F
5. Molecular weight of HAP
& Molecular weight of fat
MJOO
1.080.0
1.143
2,000
n
«J MeCU
29.0«
HAPS CONTROLLED (91% of input). Mg/yr
39.24
COST EFFECTIVENESS (S/Mg>
4.7SO
Operating noun.hr/yr
Vena
Control deviee
Ratio of HAP voting time to control
device opening time
2JKO Vh
1.760 CDh
0.3196 Ratio-Vh/CDh
Equipment design parameters
Manifoldinc
Number 01 vnti
Dumeter of collection main, ft
• nli-iilitTi) tfp-mint vttocity of 2.000 ft/min
Length of duct, ft
Number of tlbows m duel per went
Number of dampen
inciDetvtor
Eueiyy noowe^f. percent
Operating unpenmre, deg. F
Vemblca/Eauaiions
f Vents
1.15
300 L
2 N
1
70
1600
Calculate oaninl gas requirements
STEP 1: Calculate total wmste gas flow
Calculate 02 content, vol percent
i|^|^i|^y dilution air
Calculate dilution air for **f«y, acfbi
Total gas flow into incinerator, sefin
20.98
0.00
0.00
2010.00 scfini
Step 2: Calculate beat content of waste gas into
incinerator. Btu/tcf
Step 3: Calculate wactt gas temperature out of
prehaater.deg.F
• ffilffiltfffil aMuming amount of auxiliary fuel
and dilution air are small to that mass flow
rate* on both sides of the prchcater are about
the same.
Z29
1.143
Step 4: Calculate auxiliary fuel required while
vant(s) operate, scfin
STEP 3: Calculate total gat flow out of
incinerator while veat(s) operate, tcfin
22.76 FFmin
2102.76
Step 6- Calculate maximum auxiliary fuel flow
21.16 FFmax
-------
07-Jan-97; PVMOO|
(whcanoi
i «rt vented), xfin
Step 7: Calculate
of
total pi flow out
•.•cfin
210*16 Kfin
Witty
Natural**
-«*yr
-Bta/yr
ftn^Doior co&ocQcy oT60 pvom
June 1993 phdi
Fcfa 19*9 plant i
•line 1995 •qwpnat index
April 19*S phot index
Unit costs
Elbows. 5/em.
SS rouod duct dam. ofnaia. Sit
Openlor tabor vnge me, S/hr
M^menme hbor «mge me. Mr
104.434 K«b-(p.000117Xfe6aX29 in. H20XCDhyO.<
OASn3-((FFa>»xXl-iUtioWFFnnnXR*lio)X60XCDh)
GASboi-(GASft3X 1.000 BbiM)
3S2
33X4
4216
340.1
34X3
C9J4
4X02
SS&77
3JMO DAooe
1564 WRo
17J1 WRai
in] Can for fan
(Jun.199JctoU.nXS
fttrcfauM »ADane
30XWO DAF(DAoocXVcaB)
5X304 PECd-(EaIHIU>»Al>»DA)*l.IS
3X304 Im-(PECd}
104.60S TCtai-PEOHIm
24.420 TEST
3.000 TD
400.(40 TCI
-------
07-Jan-97: PVMODCST.V
then TCI-1 J3xPECi*TCIm*TE$T+TD
- If mefin from step 7 >- 20.000:
then TCI-TCIt+TCIm+TEST+TD
Annual cotfi, Sfyr
Direct usual costs
Operating labor
Control device
labor 9.422
toatcriab 9.422 MM-ML
Maaflarincsupplies 500 MS
Utilities
Natural ps 45.«47 NO-(CASft3XO.J/1.000sef)
Ehctrierty 6.162 Ebe>^KwhXS0.059/kwti)
tednd annual cods
Overhead 23.424 O-(0.6XOU+OLii»*SL+ML+MM+MS)
Property ux 4.00t PT-(OJ)1)(TCO
Capital recovery 57.010 CR-(CRFXTCI)
-CRF. 0.1424. based on 10-yn and 7* nuerctt
Tbttl ADnuAl oocL SrVr
+INS+CR
-------
08-Jan-97; PVMODCST.Wt
TOTAL ANNUAL COST SPREADSHEET PROGRAM-GAS ABSORBERS [1]
COST BASE DATE: Third Quarter 1991 [2]
VAPCCI (Second Quarter 1995): [3] ' 106.1
INPUT PARAMETERS:
Model inputs
-Model number
- Gas conditions out of process or incinerator
- Gas flow rate, scfin
- Gas temperature, deg. F
- Gas conditions into absorber (saturated)
- Gas flow rate, scfin
- Gas temperature, deg. F
- Inlet HC1 concentration, mole fraction
-Vent operating hours, hr/yr
~ Control device operating hours, hr/yr
Stream parameters:
- Inlet waste gas flowrate (acfin): 2,654
- Inlet waste gas temperature (oF): 130
-Inlet waste gas pressure (atm.): 1
-Pollutant in waste gas: Hydrogen chloride (HC1)
i-Inlet gas poll, cone., yi (mole fraction): 0.004902
-Pollutant removal efficiency (fraction):
} - Solvent:
,-Inlet pollutant cone, in solvent:
-Waste gas molecular weight (Ib/lb-mole):
-Solvent molecular weight (Ib/lb-mole):
-Inlet waste gas density (Ib/ft3):
-Solvent density (Ib/ft3):
- Solvent specific gravity:
-Waste gas viscosity @ inlet temp. (Ib/ft-hr):
-Solvent viscosity @ inlet temp. (Ib/ft-hr):
i -Minimum wetting rate (ft2/hr):
-Pollutant diffusivity in air (ft2/hr):
-Pollutant diffusivity in solvent (ft2/hr):
0.99
Aqueous caustic soda
0
29.00
18
0.0673
62.4
1
0.044
2.16
1.3
0.725
0.000102
Packing parameters:
i-Packing type:
• -Packing factor, Fp:
; -Packing constant, alpha:
-Packing constant, beta:
-Packing constant, gamma:
-Packing constant, phi:
-Packing constant, b:
-Packing constant, c:
••Packing constant, j:
••Surface area-to-volume ratio, a (ft2/ft3):
-Packing cost ($/ft3):
2-in. ceramic Raschig rings
65
3.82
0.41
0.45
0.0125
0.22
0.24
0.17
28
20
1-in ceramic Raschig rings
160
6.41
0.32
0.51
0.00357
0.35
0.97
0.25
58
35
-------
08-Jan-97; PVMODC|
DESIGN PARAMETERS:
~ Material of construction (see list below): [4]
- Inlet pollutant concentration (free basis) (Yi):
- Outlet pollutant concentration (free basis) (Yo):
- Out. eq. poll. cone, in solv., Xo* (op. line):
- Theoretical operating line slope (Ls/Gs,min.):
- Ls/Gs adjustment factor:
- Actual operating line slope (Ls/Gs, act.):
- Gas flowrate, Gs (free basis, Ib-moles/hr):
- Solvent flowrate, Ls (free basis, Ib-mol/hr):
- Gas flowrate, Gmol.i (Ib-moles/hr):
- Solvent flowrate, Lmol,i (Ib-moles/hr):
- Outlet actual pollutant cone, in solv., Xo:
- Gas poll. cone, in eq. with Xo (Y°*):
- Outlet solv. poll. cone, (mol frac basis,xo):
- Gas poll, cone., yo* (mole fract. basis):
- Outlet gas poll, cone., yo (mole fract.):
- Slope of equilibrium line (m):
- Absorption factor (AF)-first calculation:
- ABSCISSA (column diameter calculation):
- ORDINATE (column diameter calculation):
- Superficial gas flowrate, Gsfr.i (Ib/sec-ft2)
- Flooding factor, f:
- Column cross-sectional area, A (ft2):
- Superficial liq flowrate (U>/hr-ft2) (Lsfr.i):
- Minimum liquid flowrate (Ib/hr-ft2):
- If Superficial liquid flowrate is < minimum
needed, the minimum must be used to calculate
tower area and diameter (iteratively):
- guess A iteratively until the two
ORDINATE values below agree, ft2
— recalculate Lmol,i
- calculate ABSCISSA for Fig. 9.5
- calculate Gsfr.i from Eq. 9-21
- calculate ORDINATE for Fig. 9.5 using
eq. 9.54
- calculate ORDINATE from eq. 9-19
• Absorption factor-based on min liq flowrate
-Xo
- xo
-AF
- Values to use in subsequent calculations
-Lsfr.i
— A
-Gsfr.i
-AF
• Column diameter, D (ft2):
• Number of transfer units, Ntu:
• Gas film transfer coefficient, Hg (ft):
• Liquid film transfer coefficient, HI (ft):
• Height of a transfer unit (ft):
• Packing depth (ft):
• Column total height (ft):
• Column surface area (ft2):
• Column gas pressure drop (in. w.c./ft packing):
1
4.926148E-03
0.0000493
for each model
0.0305
1.5
0.0457
368
16.82
370
16.82
; check for each model
0.0964
0.0001
0.00005
0.00104
44.07
0.00093
0.2061
0.6621
0.7
6.40
47.35
2,271
877
0.04835
0.6123
0.1761
0.1759
1.50E-08
1.50E-08
infinity
2,271
6.95
0.6123
infinit
4.600
2.272
1.064
2.272
10.452
20.48
205.3
0.838
-------
08-Jan-97; PVMODCST.WE
- Column liquid pressure drop (ft of H20): 60
- Packing volume (ft3): 72.6
CAPITAL COSTS:
Equipment costs ($):
- Gas absorber 23.605
- Pump (assumes S 16/gpm) SOS
.Packing ' 1,453
-Total (base) 25.563
' (escalated) 28.495
Purchased Equipment Cost ($): 33,624
Total Capital Investment (S): 73.972
ANNUAL COST INPUTS:
Control device operating factor (hr/yr): 8,760
Vent operating factor, bi/yr 2.800
Operating labor rate (S/hr): 15.64
Maintenance labor rate (S/hr): 17.20
Operating labor factor (hr/sh): 0.0
Maintenance labor factor (hr/sh): 0.5
Electricity price ($/kWhr): 0.059
Caustic price (S/ton): 300
Solvent (water) price ($71000 gal): 0.2
Wastewater trtmt cost (S/1000 gal): 3.80
Overhead rate (fraction): 0.6
Annual interest rate (faction): 0.07
Control system life (years): 15
Capital recovery factor (system): 0.1098
Taxes, insurance, admin, factor: 0.04
ANNUAL COSTS:
Item Cost($/yr) WL Factor W.F.(cond.)
Operating labor 0 0.000 —
Supervisory labor 0 0.000 —
Maintenance labor 9.419 0.122 —
Maintenance materials 9.419 0.122 —
Electricity [5J 242 0.003 —
Caustic 31.054 0.402 —
Quench water 188 0.002 —
Solvent (water) 223 0.003 —
Wastewater treatment 4.233 0.055 —
Overhead 11.303 0.146 0.391
Taxes, insurance, administrative 2.959 0.038 —
Capital recovery 8,122 0.105 0.144
Total Annual Cost 77.162 1.000 1.000
NOTES:.
[1] This program has been based on data and procedures in Chapter 9
of the OAQPS CONTROL COST MANUAL (4th edition).
-------
08-Jan-97; PVMODCST.vl
[2] Base equipment costs reflect this date.
[3] VAPCCI * Vatavuk Air Pollution Control Cost Index (for gas
absorbers) corresponding to year and quarter shown. Base equipment cost,
purchased equipment cost, and total capital investment have been
escalated to this date via the VAPCCI and control equipment vendor data.
[4] Enter one of the following: fiberglass-reinforced plastic (FRP)-T
; 304 stainless steel—'1.4'; polypropylene—"0.95'; polyvinyl chloride
(PVCK0.701.
[5] Does not include electricity for fan because fan electricity is
included in the incinerator or condenser algorithm.
-------
ATTACHMENT B
Inputs to the Condenser Cost Algorithm for Storage
Tanks
Costs and Cost Effectiveness Tables for the Storage
Tank MACT Floor and Regulatory Alternative for Existing
Sources
Example IPR Cost Calculation Table (see Attachment A
for Condenser Algorithm)
-------
INPUTS TO THE CONDENSER COST ALGORITHM FOR STORAGE TANKS
Model
IB
2B
3B
Total emissions, Mg
588
1,210
1,930
Working loss
emissions, Mg
34S
706
1,050
Breathing loss
emissions, Mg
242
505
877
Tank capacity, gallons
13,300
20,000
448,000
Turnovers*
34.6
10.1
5.43
*A fill rate of 750 gallons per minute was assumed, providing a flowrate of 100 acfm.
tt
i
H
-------
STORAGE TANK CAPITAL COSTS AND ANNUAL COSTS PER MODEL FOR EXISTING SOURCE MACT FLOOR
Model lank1
Model 1
Model!
Model 3
A
B
C
A
B
C
A
B
C
No. of itorage
tankt
nationwide6
35
35
90
30
8
43
46
16
16
Control device0
None
Condenser
None
None
(PR
None
None
IFR
None
ToUl capital
investment,
$
0
4,133
0
0
11,560
0
0
39,880
0
Total annual cost,
$/yr
0
14,450
0
0
2,514
0
0
6,901
0
Emission reduction
from baseline,
Mg/yr0"
0.00
0.0973
0.00
0.00
0.5218
0.00
0.00
0.7824
0.00
Cost effectiveness,
$/Mg
0
148,500
0
0
4,813
0
0
8,812
0
0
I
to
*For each size category, Model A is based on storage tanki that are controlled to 295 percent and that have uncontrolled HAP emissions 2110 kg/yr
(240 Ib/yr).
Model B is based on storage tanks that are controlled to <95 percent and that have uncontrolled HAP emissions 2110 kg/yr (240 Ib/yr).
Model C is based on all storage tanks with uncontrolled HAP emissions < 110 kg/yr (240 Ib/yr).
"Total nationwide number of tanks is 320.
C1FR • internal floating roof.
^While the MACT floor control level requires 41 percent control efficiency, an IFR control device achieves 95 percent emission reduction. The
95 percent emission reduction of the control device is used to calculate emission reduction for the cost analysis.
-------
STORAGE TANK CAPITAL COSTS AND ANNUAL COSTS PER MODEL FOR
EXISTING SOURCE REGULATORY ALTERNATIVE
Model unk"
Model 1
Model 2
Model 3
A
B
C
A
B
C
A
B
C
No. of
storage tanks
nationwide1*
35
35
90
31
8
43
46
16
16
Control device
None
Condenser
None
None
IFR
None
None
IFR
None
Total capital
investment,
$
0
4,133
0
0
11,560
0
0
39,880
0
Total annual
cost,
$/yr
0
14,450
0
0
2,514
0
0
6,901
0
Incremental
annual cost from
MACT floor,
$/yr
0
0
0
0
0
0
0
0
0
Incremental
emission
reduction from
MACT floor,
Mg/yr*
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
Incremental cost
effectiveness from
MACT floor,
< $/Mg
0
0
0
0
0
0
0
0
0
tt
i
u*
•For each size category, Model A ii baaed on storage tanks that are controlled to 295 percent and that have uncontrolled HAP emissions 2110 kg/yr
(240 Ib/yr).
Model B is based on storage tanks that are controlled to <9S percent and that have uncontrolled HAP emissions 2110 kg/yr (240 Ib/yr).
Model C is based on all storage tanks with uncontrolled HAP emissions < 110 kg/yr (240 Ib/yr).
'Total nationwide number of tanks is 320.
CIPR » internal floating roof.
"Because a 95 percent emission reduction was used in the M ACT floor emission reduction (for cost analysis), there is no increase in the emission
reduction from the floor to the regulatory alternative for the cost analysis.
-------
MTERNAL FLOATING ROOF CO0T8 FOR STORAGE TANK MODELS
ALUMINUM NONCONTACTIFR WITH VAPOR MOUNTED PRIMARY SEAL AND SECONDARY SEAL
FAPROJECT\AOCHEM«T>NKS\IFR.COST XLS
l-310(O.fl)*2*7.734 1891 DOLLARS
301 3 1991 ANNUAL PLANT INDEX
3620 JUN1889 PLANT INDEX
MOB JAN 10MPLANT INDEX
MODEL2B
MODEL 34
CAPACITY, GALLONS
CAPACITY, FT3
DIAMETER. FT (ASSUME N181 M»
INPUT FROM MODEL TANK
GALLONS/7 46 A3
(FT3A 49014)*033
20.000
2.673 M
12.4
446.000
S0,693.0S
34.6
INSTALLED CAPITAL COST
I • 3161 D.Upa* T.734
OCQ
1881
JUN 1885
6.224.40
6.6SS70
11,507 2J
12,261.68
DEGASSING AND CLEANING
(S1SO/FTOMMETER)
1.64000
5.22000
SLUDGE DISPOSAL
pMAL. ASSUME 1% SLUDGE VOLUME)
1.00000
22,400.00
TOTAL CAPITAL MVESTMENT
TO • ICC • DEOAWCLEAN » SLUDGE DI8P
JUN1885
11.5S5.70
30,661.66
ANNUALIZEOCOST
(7%. 10YRS CRF« 1423)
JUN 1885
1.644 38
5.675.16
TAXES. INS. AOMIN
(4% OF ICQ
JUN 1085
347U
400.47
OPERATING COST
(6% OF ICQ
JUN 1885
52174
735.70
NET ANNUAL COST
JUN 1885
2,51385
6.60133
-------
ATTACHMENT C
Costs and Cost Effectiveness Table for the Wastewater
Regulatory Alternative for Existing Sources
Example Steam Stripper Cost Algorithm for Wastewater
Stream 44
Example Hazardous Haste Disposal Cost Calculation Table
-------
WASTEWATER COSTS AND COST EFFECTIVENESS FOR EXISTING SOURCE REGULATORY ALTERNATIVE
PAINESHAP FILE. F \PROJECT\AOCHEMS\WW-1MPAX\WW-COST WQ2
*M
M
1 13*. I4«. I5»
t lib
3 l(k
4 27
5 n
6 f*Ml5
1 26
1 20
9 I6^k
10 37M.(J.k
II 3*.
11 42
13 4)
14 44
15 ptMll
14 thus
17 19+20+21
II 19
I* 30
20 31
11 7
22 23
FWM.
fWMMW
p**
•.99*409
5440409
2.900409
120400
1457.146
1465415
4400409
1419400
5.400400
40457401
5.150400
)4I).*»
H5.600
695.665
45407.KI
5494465
10.700400
5.625
14V
24*6
11400
47400
l~6,.r
tumm.
Mifrr MM.
151 5,971
479 25,12)
201 25495
1)4 29.951
M.7 1423
11.4 1447
513 3490
194 1,299
1.144 54401
405 3.173
W.9 4.577
143 10,759
15.9 10.716
34.1 11957
576 3.3)6
213 II 451
516 1.309
0.349 16.392
0 192 49.310
0315 49.511
1 21 9jm
IJI 10.179
MACTFto
PMrtMin.
Miftn Fr F*
(14 099 0.56
306 0.99 0.64
1(0 0 99 0.64
10.9 0.99 OJ
147 0.99 OJ
940 0 99 0 (
144 0 95 0 41
3.46 0.544 0.3(7
326 0 44 0.1*4
91.4 0.331 0 193
175 O115 01*1
16 1 0 32) 0.1(2
691 0)36 0.194
1.70 0 401 0 1)3
III 03)5 0191
41.7 03)1 0196
20.4 0 544 0 367
0179 OW 01
0154 099 00
0)01 099 0*
0 209 0 31 0 17
0 301 O.)l 0.17
REOULATOH V ALTEKNATIVE. p» Mom to)
Rcovwd Uflln
frail Imd, MUr,
M^ M^
156 151
474 479
7711 111
13 5 0.136
106 0107
11.5 0.116
4*7 257
4.H 40*
504 641
1*2 322
305 «U3
46.2 961
121 2)1
1)7 294
1*1 3*3
720 141
216 240
0343 00915
0190 00019
03*1 OOO39
0)11 0*49
0561 1 25
Bnium It
•ItofSS. rim
M|*r
OM4
347
in
0109
040)6
0.0930
1 23
1 51
1(3
622
II 7
176
40)
520
73.9
77.6
9.29
0 002*
00013
00011
0144
0212
•tuuUoa
ihwllm.
M.*
174
303
17*
104
041
911
23.4
i.n
143
31 2
3.11
0.40
2.35
3)0
171
14.1
II. 1
017*
0.151
0)05
00647
0.0*56
53 SB
TCI. TAC.
* $*r(4
490432 141.1)1
450,1*5 1)0,360
374,002 110,166
i
119.470 53.971
341,465 93.911
341.919 94411
393,226 126,406
407.2)5 f9.)IO
476,340 I34.0H
1414.3)1 349437
541.614 I2M2I
771414 111.30)
392.790 73.124
333,101 67.013
I.OM.5C1 300499
417,017 135.461
511460 173.141
N/A 42,729
N/A 41,715
N/A 42,177
N/A 46.17)
N/A 5),472
...I
MM,
$*r(<*
4.920.7)1
3.541400
10*1.746
64.476
1407471
1.313.303
2,111.17)
1.21041*
3.942,222
2i.4IO.in
).*95434
2.471.46)
623,4)4
4(9,716
M.104,071
3.506.413
7.137,441
3.9(9
714
1.447
(.1*6
334*7
NATWNWIDB
Niatwif
•mala TCI, TAC,
«* $ $
1 $4994)2 $141.110
1 $4H.IU $1)0409
1 $374401 1110.166
3 MS«,4IO $161.915
1 $606430 $1174X1
1 $341.919 (94411
1 $716,451 $252411
1 $407.215 $19410
1 $476441 $134,401
1 $1414451 $349417
1 $5*1,414 Il2l.ni
1 $171414 $111.30)
1 $391,790 $7)414
1 $335.101 $67413
1 $I4*M01 $300,099
1 $4274*7 $135.461
1 $501.669 $173,141
1 N/A $3.900
1 N/A $714
1 N/A $1,447
) N/A $14,491
1 N/A $994*3
» $9.776.30) I2.M9.4I9
BMCb.^
M ACT floor.
-0*
1*4
306
IH
S2.7
17.1
940
49.2
1.46
326
93.4
174
16.1
6.9$
170
III
41.7
20.4
0.279
0.154
040
04B
0914
hm Oo«
• — "-. EHMhawt
Mo^iM $M(
t?4 $«.*«
39) $4)0
171 $611
32.4 $5401
174 $1140*
9.21 $10410
467 $5.409
I.H $47.417
143 1949
314 $11494
54) $2X4*6
1.41 $14.313
1.35 $3141*
3.50 $19413
17.1 $10411
141 $9406
M.I $15.62*
0171 $14,557
0.150 $4419
OJOO $44V
0.55) $44.21)
0415 $111,7)0
9)45 1)471
r 1 1 lit rrr * -- * — " ----- r *
•to 1 5. 21. M6 12
1 9. 20, «rf 21 • •
*~ **~* " "~~ — Tl ---- "'*" ""T - ' " ' ' ---- L --- *" "~ *** *" L-J—— '— ' *- •— J *- — •-• * — «~^—
x gwl I* wl* *• •!•«—• itriffmi M •«* **«iiy; Mill mftfOm Mmn Hnfftn tut OH*I Mmm
hMMM «f tell ntabniWp to •**> altar M *k >ufw)n4 phM .
M kbi
* «•• • jtrlthy »UI «M (!• IK* MjcwKc wMHil oat. MiMMfaia VMM 4kpMri ODM ($0 704/^1 « 1169 01/bn) MR tfrwkv^ b> (he 9 orallMl Mnm
(•ducOon tar *t>«anw 1 ovougti 1 7 •«• b«««d «n •«• rt*irtai< acNtwrt b» »<• *••«"•«''«» th« •«»•««» »»d«e«>on to »liMm« 16 BwowghZ?
•i* tWMd on 00 pwcwtf rcduc
-------
STEAM STRIPPER COST ALGORITHM
PAI NESHAP FILE\PROJECT\AGCHEMS\WW-IMP\HON_SSR2.XLS
5/2/97
Design Inputs:
Feed Rate (gpm):
Gallons/yr Stripp
On-Stream Time (hr/yr)
HAP concentration
HAP mass (Ib/hr)
HAP Mass (Ib/yr)
HAP Identity
L/V (feed-to-steam ratio)
Steam Pressure (psig)
Steam Temperature (K)
Steam Hv (BTU/lb):
Safd steam Temp (F):
Theoretical stages
Hap Removal
Required Feed Temp (F):
Bottoms Temp (F):
Wastewater Temp (F):
5.5 Feed=(Gal)(60)/Hours
695.665 Gal
2.121.6 Hours
12,973 Conc=(Massyr)/(GaO'(8.33)(10«6)
35.4 Masshr=(Conc)/(10A6)(Feed)(8.3){60)
75.177 Massyr
10.4 Ratio
100 Pst
450 Tst
900 HVs
328 Tsat
depends on Fr
5 Stage
170 Tfeed
210 Tbot
68 Tww
Cost Indices:
Chemical Eng. Magazine 2/95
42S.5 • Fabricated Equip.
389.5 - Tanks
369.5 -Condensers
595.5 • Pumps
356.0 CE plant index July 1989
382.0 CE plant index June 1995
Overheads Temp (F):
Overhead Hvap (BTU/lb):
Overheads Flow (Ib/hr):
Decant Temp (F):
Cool Outlet (F):
Design Calculations
Bottom Approach Temp(F):
Wastewater Flow (Ib/hr)
Duration of Stnpp (hrs)
170 Tov
1800 Hvov
32 Massov
77 Tdec
150 Tout
73 Tbotapp=Tv»w»5
2.731 Massww=(Feed)(8.33)(60)
2,121.6 Hours
252.5 HON Tower #1 CEM 1st quarter 1979
- Fabricated equip, cost index
252.5 HON Tower «2 Peters & Timmerhaus CEM 1st quarter 197
- Fabricated equip, cost index
252.5 HON Tanks CEM 1st quarter 1979
252.5 HON Decanter CEM 1st quarter 1979
356 HON Preheater CEM 7/89
457.7 HON Pumps CEM 9/88
365.4 HON Condensers CEM 9/88
Sizing Calculations:
Column
Steam Density (lb«3)
0.24 Denst=[(Pst)/(14.7)(760)+ 760]»(18)/(999xTst)
Flooding Abcissa
Flooding Ord (for 18 in. tray spacin
Velocity at Flood. Ws
Percent of Flood. %
Tower Diameter (@80%flood) (ft)
0.64 Floodab=(Ratio)x(Denst/62.4)A0.5
0.12 Floodord=10"[1.04635-0.64549(log(Floodab))-0.19925(Iog(Floodab))A21
1.90 Vel=(Floodord)[(62.4-Denst)/Denst]"0.5
80 %Flood
0.80 D=(Massww/3600/Vel/(%Flood/100)(4)/3.1459]"0.5
Tower Height
Weight of Column (Ib):
21.39 H=3'Stage*3-0*4
1,440 W=82.11xDx(H*0.8116xD)
Cost*
Column Cost HON «1 (S):
S39.315 Cost1=1A*1B*1C(0.85)(1.189+0.0577-D)(382.0/230.9)
-shell.ski its,nozzles
-platforms
-trays
S29.457 1 A=[exp((6.823+0.14178'ln(W)+0.02468'(ln(W))«2)]-3.1
S1.S30 1B=151.8V(D"0.63316)<(H'>0.80161)
$4.795 1C=(Stage)(3)(278.38)-exp(0.1739-D)
-------
Column Co*t HON«($)
5/2/97
$56.440 Co«OaA»28»2O»2O»2E*2F.2CH3e20/22S9)
-muiholo
$15.477 2A»(1M30)(W«08*I7)
S1S107 29*(3.1«0)(D)(H)(10)
Column Co«t Aung* of Two
TinJa
TRAY
Food Vofomo fO
Food Tink (I)
Ooc*nttr($)
13.378 Foo*ol>(48)(GoJ)(Houil/DaS)
J29.083
FMtfMX <21 000 04 then OOST*=«pa331«1 M7nn(F^<»«0-0 0830Wln(HVp)*04207-(S7407)(2)(3S2.0rM7e)
LMTD
Ar»i(tO)
Co«KJ)
Condtnscr
LMTD
Ce«(S)
FUrnt Arrester (J)
EqwpmmtCett
S*lM Tu (3%)* FrxgM (S«)
10 83 LMTDp«(«((Tboi-T«*«iO-rrbatipp.Twi^)r1ln((Tba(-T*ndy(TboCiB>TMi<»)))
9737 AREApr««(MiMww)(TrMd.T«wV(170*LMTD)
S7 478 IT F«w)«0 48 (Mfl CO5Tpr^(4213 3S7*(0 48)*0 5 • 2882 31)(382 CV3SO 0)
»F«*d»0 48 men COSTpn«(4213 357<(FMd)*0 S • 2882 311(3820/354 01
1378 LMTOcond3[(To»-ToiKKT(tK-66)11ln((TevTau))(3SO(V34301
If AREAoond>240 »«n COSToond=(S328(EC*Pip
-------
ObM Annul
5/2/97
SSeptaun,hftiMk
OpvraOng Labor
Supw^nfton MM A0RW.
(9.26/MQ)
12,342
$79 E)K-(HPM*»
tne w^»«{i«ii,i.l
40.6 Houra*>HounO2
S3 wWyr And SS
VHeuiM<6 «nd »4 AM OL-(1)/(a)(Hou*)(22.SO)
VHoun>«4 and »-1 Own OL-(4V(«)(Moom}(22.SO)
tfHounxl VnnOL>(Haum)(a.SO)
S446 SL=(Og(Q.15)
SZOM ML=OL
$2.9*4 MM=ML
ToWD*
•I Co
Indraet Anmal
kounnra
Admmonow Ctaigw
CRF (7% ISyrm)
ToW indHwS Annual COM
$11.073
IS 838 (X(QL«SL«ML*MM)(OaO)
$3351 PT^POKOOI)
$3.351 1NS«(TCI)(001)
$6 702 A=(TCQ(D 02)
$38.795 CR=(TT3)(CRF)
$SS83S
$67.813 TAC=OtRTAC*IMOTAC
-------
HAZARDOUS WASTE DISPOSAL COSTS FOR WASTEWATER FOR EXISTING SOURCE REGULATORY ALTER
PAI NESHAP FILE: F:\PROJECRAGCHEMS\WW-IMPAX\HAZWASTE.WQ2
Stream
1 29
2 30
3 31
4 7
5 23
Flow rate
per stream,
gal/yr
5,625
1,028
2.056
11,600
47,000
Load per
stream,
Mg/yr
0.349
0.192
0.385
1.23
1.81
ppmw
16,392
49,338
49.513
28.033
10.179
Disposal
as hazardous
waste,
$/yr
$3.960
$724
$1.447
$8.166
$33.087
EXAMPLE: Stream 29
Hazardous waste disposal cost is $0.704/gal or $169.02/ton. Stream 29 has a flow rate of 5,625 gallons per year.
5,625 gal/yr x $0.704/gal = $3,960/yr
-------
ATTACHMENT D
Costs and Cost Effectiveness Table for the Equipment
Leak Regulatory Alternative for Existing Sources
Example Cost Calculations for Batch Equipment Leak
Model
-------
COm, RMIMIONI, AND COST EFFECTIVENESS OP REGULATORY ALTERNATIVES FOR EQUIPMENT LEAKS
PAI NBIHAP PILE: F:\PROJBCT\AOCHBMS\BLBAKS\EL IMP.XLS
Regulatory
Anamettv*
MACT floor
Subpart H
Data:
Proeeaaei
Batch BL model
ContlniMua BL model
Proceii 1
Pruc*ii4
Proceu20
Proceaa23
Proem 24
Proceii 25
Proceu26
Proceii 10
Proceea 22
ProceuH
Proeeu 1 1
Proc*Ml3
Proeeu 6
Pruteu9
Implementing eubperl \\
Baaellne
Bmliiloru
(Mg/yr)
3,407
3,407
Number of
pnxeaaea
138
37
1
1
1
1
1
1
1
1
1
I
1
1
1
1
14
Capital
Coin
($)
0
$3,397,000
TCI,
$/proctu
$15,401
$25,341
$11,910
$9,371
$13,112
$24,317
$24,517
$24,517
$24,517
$12,800
$37,333
$19,387
$14,606
$17.783
$10,376
$11,894
to
Annual
Com
($)
ER Prom
BaMllne
$/Mg
978
22
1,183
6,155
2.585
844
30.096
13,412
13,412
2,784
10.523
10,246
(722)
1,077
1.336
3,898
0
203
$3.396,599 $1.650.196
3,407
386
546
-------
EXAMPLE COST CALCULATIONS FOR THE BATCH MODEL
I. CAPITAL COSTS
i. Equipment costs
compressor
open-ended lines
sample connections
pressure relief devices
monitoring instrument
0 x $6,633
0 x $108
Ox $434
0 x $4.176
Ix $6,907
$0
$0
$0
$0
$6,907
$6,907
2. Initial monitoring cost (Not part of the Capital Cost, but is «inmii»«H under section n. Annual Costs.)
Component
Gas valves
Liquid valves
Pump
pump
replacement seals
r
Flanges
No. components
65
340
14
1,100
Monitoring Cost
(* cotnp. x $2.50)
162.50
850.00
35.00
N/A
2,750
Initial monitoring cost
(Cost x 1.4)
227.50
1.190.00
49.00
N/A
3,850
3. Initial repair cost (Not part of the Capital Cost, but is annualized under section n. Annual Costs.)
Component
Gas valves
Liquid valves
Pump
pump
replacement seals**
Flanges
No.
components
65
340
14
1,100
Initial leak
frequency
0.11
4
0.06
5
0.20
0.20
0.02
1
Fraction
require
repair
0.25
0.25
0.75
0.75
0.25
Hour
I*'
repair
4
4
16
N/A
2
Repair cost
(x $22.50)*
166.72
497.25
756.00
N/A
259.87
Initial repair
cost
(Costx 1.4)
233.41
696.15
1.058.4
401.73
363.82
*Not applicable to pump replacement seals.
blnitial repair cost for replacement seals is equal to the number of components, times the leak frequency, times
the fraction requiring repair times a cost of $191.30 per replacement seal. No administrative charges are
included for this repair cost.
D-l
-------
D. ANNUAL COSTS
i. Indirect annual costs
.. Animal I md equipment costs
compressor
open-coded lines
sample connections
pressure relief devices
monitoring i
Ox $6.633x0.14
Ox $108x0.14 =
Ox $434x0.14 =
Ox $4,176x0.14
1 x $6.907 x 0.21
$1.450
b. Annualized initial monitoring
Component
Gas valves
Liquid valves
Pump
pump
replacement seals
Flanges
TOTAL
Initial monitoring cost
227.50
1.190
49.00
N/A
3.850
CRF
0.14
0.14
0.14
0.55
0.14
Annwtliziffd initial
monitoring cost
(Cost x CFR)
31.85
166.66
6.86
N/A
539.00
744.37
c. Annualized initial repair costs
Component
Gas valves
Liquid valves
Pump
pump
replacement seals
Flanges
TOTAL
Initial repair cost
233.41
696.15
1.058.40
401.73
363.82
CRF
0.14
0.14
0.14
0.55
0.14
Annualized initial repair
cost (Cost x CFR)
18.63
170.93
148.12
220.95
50.93
609.62
D-2
-------
2. Direct annual costs
•. Annual nr*'rit*Ti*t"** charges
monitoring instrument 1 x $4,548 =
compressor 0.05 x $0 =
pressure relief devices 0.05 x $0 =
open-coded lines 0.05 x $0 =
sampling connections 0.05 x $0 =
pump replacement seals 12.6 x $191
b. Annual ini*°^Han
-------
Annual repair labor
Component
Gas valves
liquid*
valves
Pump
pump
Flanges
TOTAL
No.
components
65
340
14
1.100
No. of
leak
frequency
0.02
0.02
0.10
O.OS
No. of
monitorings
per year
4
4
12
1
Fraction
require
repair
0.25
0.25
0.75
0.25
Hour
per
repair
4
4
16
2
Cost
(x $22.50)
117.00
612.00
4,536.00
6189.75
Annual
repair
cost (Cost
xl.4)
81.90
428.40
6.350.40
173.25
7.033.95
Annual labor charges = monitoring labor + repair labor
= $8,277.50 + 7,033.95
- $15,311.45
3. Product recovery credit
emission reduction = 10.20 Mg (Estimated in the Environmental Impacts memo)
recovery credit = $l,250/Mg
10.20 Mg x $l,250/Mg = $12.750 credit
4. Calculation of total annual cost
equipment
initial monitoring
initial repair
maintenance
annual miscellaneous charges
annual labor charges
product recovery credit
TOTAL ANNUAL COST
1,450.47
744.37
609.62
2,406.60
2,201.28
15,311.45
12,750.00
9,973.79
D-4
-------
ATTACHMENT E
Costs and Cost Effectiveness Table for the Process Vent
MACT Floor for New Sources
-------
van
sam
NEW SOURCE UACTFIOOR COSTS FOR PROCESS VENTS
PM NESHAP FEE F-VROJECTMOCHEMSUMTAOOmPV-NEWCEMS
PtoM
A1
A2
A3
Bl
82
C1
C2
03
HAP
content To
Id
IcM
Ie98
2d
2c98
Id
3d
1c88
3e98
Id
2dH
4dH
Control
W device
IndnenMor
condenser
condenser
Indneralor
condenser
Incinerator
Inckieretor
condenser
condenser
tnclntntor
! Incfaufjlofftcmbbnf
{ MMrttor/Scrubber
TCI
P»r
model.
S
431.000
356.000
356.000
401.000
159.000
431.000
972,000
366,000
181.000
431.000
475.000
1.446.000
fc*— jfai«^i litm
wuDnwKM
Ta.s/»t
431.000
356.000
356.000
401.000
159.000
431.000
972,000
356.000
181.000
431.000
950.000
2.692.000
TAC
PW
fflOOW,
**r
210.000
138.000
138.000
166.000
66.100
218.000
631.000
136.000
67,900
216.000
265.000
942.000
TAC.t/yr
218.000
138.000
138.000
186.000
69100
218.000
631.000
136.000
67.900
218.000
530.000
1.684.000
Uncontrol
•mlunf
Mgryr
oraimcs
137
137
137
40
40
137
41
137
41
137
40
102
M
*. c
HCI
0
0
0
661
661
0
0
0
0
0
661
295
Un
ruled •
HCI. pc
Mo/yr
0
0
0
179
0
0
0
0
0
0
179
676
cofltroitod 1
HAP
missions •
r process. DM
Mg/yr
137
137
137
1240
1081
137
410
137
410
137
1240
4646
••Mine
HAP M
riutons i
process, per
Mp/yr
17
27
27
86
87
27
82
27
6.2
27
248
930
HAP IM
nfsslam •
it floor n
process, pei
MoAr
03
03
0.3
16
15
03
08
as
0.8
03
16
5.7
mmMW N
mlulen im
iductioft
r process, *
Uat*
25
25
25
7.2
72
IS
74
15
74
15
232
873
•tkVMtde N
l*WMlfc«^sW«l
mnwOTu
HAP
minions, •
ttato
137
137
117
1240
106.1
13.7
41.0
117
410
13.7
248.0
9296
— M IJ^ Al
iDomniN n
beM»ne Im
HAP i
imsdan*. n
Mrtr
2.7
27
17
6.8
87
27
82
27
82
17
49.6
105.9
•ttomride
n*^«BhAf»tal
mmvniBi
imhston
iduedoA *t
Mafrr
15
IS
15
72
72
25
74
IS
74
25
46.3
174.6
Cveni
coet
•tUmneii.
SAta
68.400
56.000
56.000
26.100
11200
66.400
112.600
56.000
9.200
68.400
11.400
10.800
7.916.000
4.657.000
1.S72
266
26S
17.583
-------
ATTACHMENT F
Costs and Cost Effectiveness Table for the Storage Tank
MACT Floor for New Sources
-------
5/7/97
StnawcatJta
NEW SOURCE UACT FLOOR COSTS FOR STORAGE TANKS
PAINESHAP FILE F \PROJECT\AOCHEMS\TANKaSTNEWCST XL3
Plant
A1
A2
A3
B1
B2
C1
C2
O2
Modal
tank
IB
1B
1B
Nona
Nona
3B
3B
2B
TCI
modal. Nationwide
No. models
1
1
1
•.•———
nono
Nona
1
1
1
$
52,060
52.060
52.060
219.546
219.548
58.684
TC1,$/vr
52.060
52.060
52.060
219.548
219.548
58.684
TAG
par
modal. Nationwide
Vvr
71.938
71.938
71.938
102.551
102.551
73.147
TAC.Wr
71.938
71.938
71.938
102.551
102.551
73.147
Nationwide Nationwide N
Uncontrolled BaaeUne HAP Incremental uncondoned bateNna In
HAP HAP emtaalona amlaalon HAP HAP i
emtaalona amlulona at floor raductlon amlaalona, amlaakma. r
MoM
0.267
0267
0267
0876
0.876
0549
Mfl/yr
0237
0.237
0237
0.824
0824
0549
MoM
0.157
0.157
0.157
0.517
0.517
0.324
MorVr
0.080
0080
0060
0.307
0.307
0.225
Mfl/y»
0267
0267
0267
0.876
0.876
0549
MflrVr
0237
0.237
0237
0.824
0.824
0.549
tUonwMe
imhalon
BducUon. 4
MoAr
0.080
0.060
0080
0.307
0.307
0225
OmaR
coat
RadlMnaM.
IMa
899.400
899.400
699.400
334.400
334.400
324.800
653.960
494.063
3.10
291
1.08
458.105
-------
ATTACHMENT G
Costs and Cost Effectiveness Table for the Wastewater
Regulatory Alternative 2 for New Sources
-------
RNUUI.ATORV AtTBRHATTVB 2 COST*. OMUOKW
RHUULATORV ALTBRMATTVB 2 COST*. OMIOOKW
Ml NUBIAF RLE.
1
•uam
\ 9
2 II
1 ZfcAM
4 *
S 171
• MM
7 »
1 40
* 41
10 45
F:\PRUinrr\AOCHIMJ\WW_l
Fh.
t
t t
S • t
RAI
Bn Ro4
Milkman
0
0
0
0
11.2
i.n
0
0
0
0
tM.
*•"***
V*
9.»M»
IJ»4»
2RIJ4
I.2M
2^4I1.90»
Ml*.t»
H6.MO
547.4K
496.742
656.916
RA2 RAI
RA2 nimniii Mlh
Ualto* fm U*f^» U^O^v B«
PlfrJT ~ • iHJFjm tUJfff rl
MM 0,99 MH OJOO* 0.92
0.169 0.99 0179 MOB 0.91
0AM 090 0717 OjOOO OJ
M4I 0.90 OMD OJODI OJ
034 0131 162 m O.IOM
17.7 0,14 10.7 OM 0.1943
OJ02S 0*0 OJBI MM OJ
OJ26 0.99 0452 OjOD7 OJ
OJ02 0.10 OJBI OJ06 OJ
0.116 0.99 0.191 0AM OJ
WTte
TAG i
2 b huid at Mann urtfftn b> iM Mn
-------
5/7/97
IA2
Uninlhd RA2
coMom BmRcdiiD
•ton, f ram U»
Mnyt M»/yifr"»»
(U» 0.126 I
nan o.i67 t
0.006 0.630 $
0.0004 0.040 $
6C.2 31.2 t
IIJ 1M $
OJOOD e.0252 t
0.005 0.571 t
0403 0.497 $
OyOn OJI3 1
RAJ
TOO)
746^72 f
354.7*7 t
3404« t
261.175 t
1.014,491 t
S75.CH t
3M.701 t
•32.224 i
721.254 1
43*313 1
IA2
TACCS)
1*3.044 t
I0».l» t
60.726 1
39.120 t
349.197 1
130.525 1
54.711 t
103.044 f
114.236 S
71.071 t
RAIMHA2
TCKS)
74*372 t
354,717 t
340.393 1
261.175 t
147 t
7.0X5 t
124.702 I
632.224 t
721.254 S
436.313 t
RAItoRA2
TACO)
193.044
IM.I2*
60.726
39.120
60
l,70«
54.711
103,044
114.236
71.077
RAIURA2
Incrcmnttl
FmtM
Mg/xr/pmacu
0.126
0.167
063
0.041
0.011
0121
0.025
0521
04ITI
0.313
KAIk>RA2
Uwiwnuttl
CE
(IMi)
1233.613
M53.443
J96.4M
19W.764
S3.2H
113,313
S2.I72.223
tl9T,730
1230.044
1249.577
Ninfexuf
ilnn to
eonral
•tlnwkk
3
2
2
2
2
2
2
2
1
2
t
t
t
t
t
t
S
1
t
Ifclknwide
RAIURA2
tonmtuJ
TCI<$)
2.239.116 S
709.574 f
6n.7M S
WA $
294 f
14,170 S
649,404 1
1.264.441 t
1.442.501 t
172.626 S
thlfcmiiHi
RAItoRAI
hMMKOMl
TAC«)W
579.132
211,251
121,451
U*
IX
3.401
109.422
vtjm
221.472
156.154
RAItotAl
M(^rW
1M
0.334
IJf
Oj09M
OjOW
02M
OAS04
IJM
0.993
OA6
RAIURA2
C/B
OVM|)
t233«6n
W53.443
W6.4M
125.794
t3.2H
113.313
S2.I72.223
SI9T.730
S230JM4
1249.577
ftMtaowkb
Ikwiu*
i»uy>
40,300,000
5.2>M>»
107.200
3.6«
60.735^36
10,152.100
444,142
I>SS^DD
ijuijm
1^6.240
7.I72.926 S
1.025^74
7.17 S
226.497
I43.435.2W
-------
ATTACHMENT H
Costs and Cost Effectiveness Table for the Equipment
Leak MACT Floor for New Sources
-------
COSTS OF-NEW SOURCE MACT FLOOR FOR EQUIPMENT LEAKS
PA1NESHAP FILE: F:\PROJECT\AOCHEMS\ELEAKSVELNEWCST.XLS
Plant
Al
A2
A3
Bl
B2
Cl
C2
D2
PrOCeilee
Batch EL model
Batch EL model
Batch EL model
Batch EL model
Belch EL model
Belch EL model
Continuous EL model
Belch EL model
Conlinuooi EL model
Belch EL model
Conlinuoui EL model
Number of
proceiMi
1
1
1
2
2
2
1
2
1
3
2
TCI,
S/proceu
$15.401
$15.401
$15,401
$15.401
$15.401
$15.401
$25.341
$15.401
$25.341
$15.401
$25,341
CR.
$/yr/procei«
2104
4419
2151
1807
12849
4304
4304
4304
4304
2299
5793
•\
TAC,
$/yr/proce*i
$9.977
$9.977
$9.977
$9.977
$9.977
$9.977
$928
$9.977
$928
$9.977
$928
EmiuKHU.
Biieline
11.34
11.34
11.34
11.34
II 34
11.34
4634
11.34
4634
II 34
46.34
Mf/yr/proceM
After
•ubpirtH
1.14
1.14
1.14
1.14
1.14
1 14
502
1.14
5.02
1.14
502
Nationwide
TCI.
$
$15.401
$15,401
$15,401
$30,802
$30,802
$30,802
$25.341
$30.802
$25,341
$46,203
$50.682
Nationwide
TAC,
$/yr
$9.977
$9,977
$9,977
$19,954
$19,954
$19,954
$928
$19.954
$928
$29.931
$1,856
Nationwide
emiaaioM. Mg/yr
Baaeline
11.3
46J
11.3
22.7
22.7
22.7
46.3
22.7
46J
34.0
92.7
After
MbpertH
1.14
5.02
1.14
2.27
2.27
2.27
5.02
2.27
5.02
3.41
10.0
Coal
•fncttvoncM,
$/MK
978
241
978
978
971
978
22
978
22
978
22
$316,978 $143.390
379
39.9
423
-------
MIDWEST RESEARCH INSTTTUT
Suite 35"-
401 Hamson Oaks Boulevarc
Gary. North Carolina 27513-241:
Telephone (919) 677-024'
FAX (919) 677-006:
Date: April 30, 1997
Subject: Procedures to Estimate Characteristics and Population of Dilute and Concentrated
Streams for Model Processes-Pesticide Active Ingredient Production NESHAP
EPA Contract No. 68D60012; Task Order No 0004
ESD Project No. 93/59; MRI Project No. 4800-04
From: David Randall
To: Lalit Banker
ESD/OCG(MD-13)
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
I Introduction
The model plants memorandum describes parameters for four model processes that are
used to characterize process vent emissions at modelled plants; each model process characterizes
both a dilute stream and a concentrated stream ' The objectives of this memorandum are to.
(1) describe the methodology used to estimate the flow rates (and corresponding organic HAP
concentrations) for these eight streams and (2) estimate the number of processes at the 58
modelled plants that are represented by dilute and concentrated streams. The methodology is
described in Sections II and III, and the distribution of dilute and concentrated models is
described in Section IV
II Cutoffs for Model Streams
The first step in the methodology was to determine the flow rates and associated
concentrations that define the cutoff, or cross-over point, between dilute and concentrated
streams for each model process. This was accomplished by estimating the costs to control the
organic HAP emissions from the model processes with an incinerator and a condenser over a
range of flow rates. The cutoff is the flow rate for which the control costs are equal Dilute
streams are streams with flow rates above the cutoff, and for which control with an incinerator is
the least costly alternative. Flow rates below the cutoff characterize concentrated streams, and
the least costly control alternative for these streams is to use a condenser. Graphs of the costs for
each model, and examples of the algorithms used to calculate the costs, are shown in
attachment 1.
-------
The algorithms used to estimate the costs are the same as those used to estimate cost
impacts for regulatory alternatives. In the algorithms, the annual HAP emissons and operating
hours are fixed based on the model characteristics. Thus, as flow rate increases, the HAP
concentration decreases. The average organic HAP concentration at the flow rate cutoff was
calculated using the annual mass emissions for the model process, the ideal gas law at standard
conditions, and the process operating hours (i.e., 2,800 n/yr for batch model processes and
5,000 h/yr for continuous model processes).I Model processes 2 and 4 are designed with both
toluene and methylene chloride emissions, but, for simplicity, this analysis assumes that the entire
organic HAP emissions from these models are methylene chloride. An example calculation is
presented in attachment 2, and the results are presented in Table 1.
TABLE 1. FLOW RATE CUTOFFS FOR MODEL PROCESSES
Model process
1
2
3
4
Annual emissions,
Ib/yr
30,200
88,200
90,400
224,400
Flow rate cutoff,
scfm
1,390
285
760
230
Organic HAP
concentration at flow
rate cutoff, ppmv
540
8,340
1,660
14,730
II. Model Flow Rates and Organic HAP Concentrations
The second step in the methodology was to determine the flow rates and concentrations
above and below the cutoffs that represent the dilute and concentrated model streams,
respectively. This was accomplished by using averages from the data for processes at the
surveyed plants.
A. Data From Surveyed Plants
The surveyed plants reported flows for 23 batch processes and 15 continuous processes.
For each vent in these 38 streams, the reported organic HAP emissions, duration of venting
episodes, and the flow rate are shown in attachment 3. When a reported venting duration was
greater than the process operating hours, it was changed to be equal to the process operating
hours; the changed values are shaded in attachment 3. For most processes, the maximum venting
duration for a vent within the process is equal to the process operating hours. In a few cases,
however, the maximum venting duration is less than the process operating hours; for these
processes this analysis assumes that venting episodes from all vents overlap so that operating time
for a control device would be equal to the venting duration for the vent with the longest duration.
-------
Average flow rates were calculated for an aggregated (manifolded) stream from each of
the 38 processes. The average flow rate is equal to the sum of the reported flow rates for each
vent in the process if the duration of venting episodes is the same for all vents in the process. If
the duration of venting episodes varied for the vents in a process, a weighted average flow rate
was calculated for the process. Weighted flow rates for each vent were calculated by multiplying
the reported flow rate for the vent by the reported duration of venting episodes for the vent and
dividing by the maximum duration for any vent in the process. The weighted flow rates were then
summed to give the average flow rate for the process. A sample calculation is presented in
attachment 2.
Average concentrations were calculated for each of the 38 processes as follows
Average mass emission rates were calculated by dividing the annual mass emissions by the number
of minutes for the largest venting duration for each process These values were then convened to
concentrations using the calculated average flow rates and the ideal gas law at standard
conditions. An example calculation is presented in attachment 2. The resulting concentrations for
each of the 38 processes are presented in Table 2, along with other reported and calculated
characteristics.
B Model Characteristics
The flow rates and concentrations for the model streams were estimated by averaging
various groups of data in Table 2. For example, the averages for model 1 were calculated as
follows. From Table 1, the concentration cutoff is 540 ppmv. In Table 2, six batch processes
have aggregated emission streams with concentrations below this cutoff (i.e , dilute). The average
flow rate and concentration for these streams are 2,950 scfm and 277 ppmv, respectively
Because the six surveyed processes have a wide range of annual mass emissions, not all of them
have flows above the model 1 cutoff of 1,390 scfm, but the average is above the cutoff Similarly,
17 batch processes in Table 2 are above the 540 ppmv cutoff (i.e, concentrated) The average
flow rate and concentration for these strreams are 683 scfm and 219,000 ppmv, respectively.The
same approach was used to estimate the characteristics for models 2, 3, and 4. The results are
shown in Table 3.
IV. Population of Dilute and Concentrated Streams
As stated in the model plants memorandum, model processes 1, 2, 3, and 4 represent 48,
19, 14, and 12 processes at modelled plants, respectively. The number of dilute and concentrated
streams was estimated assuming the ratio of dilute to concentrated streams at the surveyed plants
is representative of the industry as a whole. Thus, of the 48 processes represented by model 1,13
are estimated to have dilute streams (48 x 6/23 = 13), and 35 have concentrated streams (48 x
17/23 - 35). Similar procedures were used to estimate the number of dilute and concentrated
streams for models 2, 3, and 4; and the results are shown in Table 4.
-------
TABLE 2. CHARACTERISTICS OF MANIFOLDED PROCESS VENT STREAM FOR
PROCESSES AT SURVEYED PLANTS
Plant
number
Process
number
Type
of
HAP*
Venting
time, h/yr
Emissions,
Mg/yr
Max. flow
rate, scfin
Avg. cone.
at max.
flow, ppmv
Avg. flow
rate, scfm
Avg. cone
atavg.
flow.
ppmv
Batch processes
23
23
3
23
21
23
21
21
21
21
21
21
23
12
12
17
5
6
12
20
7
3
3
90
89
7
94
70
93
71
72
73
68
67
69
92
38
37
60
IS
16
40
66
17
11
12
C
C
C
C
U
C
U
U
U
U
C
U
C
C
C
C
C
U
C
U
U
C
U
1340
2320
8.160
4370
127
4.150
148
169
189
4.0S6
8.400
570
360
1.170
1368
1,548
6.039
4.404
1468
840
6.072
8.160
4.176
0.206
0.3SS
0.693
65
0.447
58.7
0.82
0.857
0.969
28.5
129
5.81
1.88
243
459
0.337
519
16.5
48.2
81.8
33
0.403
0.782
1,400
1.400
80
6.884
1.083
6.884
1,080
1.080
1.080
1.080
3.818
1,080
270
2.650
76
0.962
23.7
9.5
48
508
20
0.025
0.145
SO
50
240
375
954
489
1.030
1,010
1.010
1.070
uoo
1,450
3.190
4300
10300
37,667
111.000
236.000
615,000
515.000
569,000
977,000
992.000
1.400
1.400
80
6.884
1.050
6.884
1.067
1.063
1.063
1.078
3.818
1,080
270
1.993
76
0962
237
95
63
508
20
0.025
0145
50
SO
240
375
455
489
821
861
973
1.001
1300
1.450
3.190
5370
10300
37,667
111.000
236.000
264,000
515.000
569,000
977.000
992,000
-------
Plant
number
Proccai
number
Type
of
HAP*
Venting
time, h/yr
Errascions.
Mg/yr
Max. flow
rate, scfm
Avg. cone
at max
flow.ppmv
Avg flow
rate, scfm
Avg. cone.
at avg
flow.
ppmv
Continuous proccues
23
1
7
1
1
1
S
8
10
3
17
12
17
17
9
91
4
18
2
1
3
14
19
27
6
63
39
62
61
25
C
C
C
C
C
C
U
C
C
C
U
C
U
U
C
7.488
720
5300
336
S.040
720
7,464
7.896
7.680
8.136
8.064
7.000
2.424
1.920
3384
4.02
932
12.8
S.64
136
195
0916
202
65.6
50.9
200
199
15.3
819
182
4.900
74400
29,250
74.500
74400
74400
125
10.800
141
350
666
246
129
6.7
2
16
26
16
35
56
56
153
606
2.606
2.986
51300
33.500
12.500
101.000
237,000
4,900
74400
15,250
74400
74.500
74400
125
10.800
141
179
486
122
36
6.7
1.8
16
26
29
35
56
56
153
606
2.606
2.984
22.600
32.500
37300
101.000
254.000
*C means the emissions include chlonnated organic HAP; U means the emissions consist only of unchlonnated organic HAP.
-------
TABLE 3. FLOW RATES AND ORGANIC HAP CONCENTRATIONS FOR MODEL
PROCESSES
Model process
Number
1
1
2
2
3
3
4
4
Type of stream
Dilute
Concentrated
Dilute
Concentrated
Dilute
Concentrated
Dilute
Concentrated
Number of surveyed
processes used in
average
6
17
14
9
8
7
10
5
Model characteristics
Average
flow rate,
scfin
2,950
683
2,080
21
41,130
139
32,940
131
Organic HAP
concentration at
average flow rate,
ppmv
277
219,000
1,170
412,000
122
65,100
947
89,500
In addition to representing processes at modelled plants, the model processes are also
used to represent processes at the surveyed plants in cost impacts analyses. The surveyed
processes that are represented are those that would have to add control to meet the proposed
standard. Based on the data in attachment 1 of the environmental impacts report, a total of 28
processes at the surveyed plants would have to increase control levels to meet the requirements of
the MACT floor and the regulatory alternatives 3»4 The 28 surveyed processes are identified in
Table 5 Eighteen of these processes are batch processes, and 10 are continuous processes.
Based on the rankings in Table 2 and the flow rate cutoffs for the models, the models that
represent 21 of the 28 processes can be readily determined For example, for model process 1 the
concentration associated with the flow rate cutoff is 540 ppmv. Batch processes 7, 70, 89, and 90
at the surveyed plants have lower concentrations; thus, these four processes are represented with
the dilute model.
The surveyed plants did not report flow data for 7 of the 28 processes. However, a
model was assigned based on knowledge about the type of HAP and the process operating hours
Processes 28, 29, 30, and 31 were reported to be batch/continuous processes, and processes 54,
57, and 58 were reported to be batch processes. To be included in the analysis, the
batch/continuous processes were assumed to be either batch or continuous processes in
-------
TABLE 4. POPULATION OF DILUTE AND CONCENTRATED MODEL PROCESS VENT
STREAMS
Model process
Number
1
1
2
2
3
3
4
4
Total
Type of stream
Dilute
Concentrated
Dilute
Concentrated
Dilute
Concentrated
Dilute
Concentrated
Dilute
Nationwide population at
modelled plants
13
35
12
7
7
7
8
4
93
TABLE 5. MODEL PROCESSES USED TO REPRESENT SURVEYED PROCESSES
Model process
Number
1
1
2
2
3
3
4
4
Total
Type of stream
Dilute
Concentrated
Dilute
Concentrated
Dilute
Concentrated
Dilute
Concentrated
Surveyed processes represented by model
process
Based on Table 2
7, 70, 89, 90
68, 69, 71, 72, 73
67, 93, 94
15
1,2,3,4,18
62
27,91
Assigned
54,57
28, 30, 58
29
31
Total
number of
processes
6
8
3
1
6
1
3
0
28
-------
8
approximately the same ratio as the known batch and continuous processes. Processes 28,29,
and 30 have only unchlorinated HAP emissions, and process 29 operates for more hours per year
than the other two processes. Because batch processes are more prevalent than continuous
processes in the PAI industry, two of these three processes were assumed to be represented with
batch model 1 (processes 28 and 30), and one was assumed to be represented with continuous
model 3 (process 29). Process 31 has both chlorinated and unchlorinated organic HAP emissions
and operates for nearly 7,800 hours per year; thus, this process was assumed to be represented
with continuous model 4. Processes 54, 57, and 58 have only unchlorinated emissions; thus, they
were all assumed to be represented with batch model 1. The next step was to determine if these
seven processes should have a dilute or concentrated stream. Processes 29 and 31 were assumed
to have dilute streams because Table 2 shows dilute streams are more prevalent than concentrated
streams for models 3 and 4. Table 2 also shows concentrated streams are more prevalent than
dilute streams for model 1. Thus, three of the five surveyed processes represented by model 1
were assumed to be concentrated, processes 28, 30, and 58 were randomly selected.
V References
1. Memorandum from D. Randall and K. Schmidtke, MR], to L. Banker, EPA:ESD. April 30,
1997. Model Plants for the Pesticide Active Ingredient Production Industry.
2. Memorandum from K. Schmidtke and D. Randall, MRI, to L. Banker, EPA:ESD. April 30,
1997. Cost Impacts for the Pesticide Active Ingredient Production NESHAP.
3. Memorandum from D. Randall and K. Schmidtke, MRI, to L. Banker, EPA:ESD. April 30,
1997. Environmental Impacts for the Pesticide Active Ingredient Production NESHAP.
4. Memorandum from D. Randall and K. Schmidtke, MRI, to L. Banker, EPA:ESD April 30,
1997. MACT Floor and Regulatory Alternatives for the Pesticide Active Ingredient
Production Industry.
-------
Attachment 1
1. Graphs of annual cost versus flow rate for each of the four model processes
2. Example incinerator algorithm for model process 1
3. Example condenser algorithm for model process 1
-------
190
MODEL 1 COSTS
Toluene (30,200 Ib/yr)
1000
1100
1200 1300 1400
Flowrate, scfm
1500
1600
—i Condenser (90%)
Th. Ox.
-------
180
170 •
160 •
140
130
110 -
90
100
MODEL 2 COSTS
Methylene Chloride (88,200 Ib/yr)
200
300 400 500
Flowrate, scfm
600
700
Condenser (90%) -Q- Th. Ox.
-------
MODEL 3 COSTS
Toluene (90,400 Ib/yr)
200
400
600 800
Flowrate, scfm
1000
1200
1400
i Condenser (90%) I I Th. Ox.
-------
120
70
100
MODEL 4 COSTS
Methylene Chloride (224,400 Ib/yr)
150
200 250 300
Flowrate, scfm
350
400
— Condenser (90%)
Th. Ox.
-------
'HERMAL INCINERATOR COST ALGORITHM
Process vents model:
07-Jan-97; PVCSTHR4.Wi
Vaste gas parameters
1. Mass flux of HAP, Ib/yr
1. Volumetric flow rate, scfrn
2. HAP concentration, ppmv
3. Assumed heating value of HAPs, Btu/scf HAP
4. Temperature, deg. F
5. Molecular weight of HAP
6. Molecular weight of gas
30,200
1,000.0
752
2,000
77
92 Toluene
29.05
HAPS CONTROLLED (98% of input), Mg/yr
13.44
COST EFFECTIVENESS ($/Mg)
11,244
)perating hours, hr/yr
Vents
Control device
Ratio of HAP venting time to control
device operating time
2,800 Vh
8,760 CDh
0.3196 Ratio=Vh/CDh
equipment design parameters
Manifolding
Number of vents
Diameter of collection main, ft
- calculated assuming velocity of 2,000 ft/min
Length of duct, ft
Number of elbows in duct per vent
Number of dampers
Incinerator
Energy recovery, percent <
Operating temperature, deg. F
Variables/Equations
6 Vents
0.80
300 L
1 N
1
70
1600
Calculate natural gas requirements
STEP 1: Calculate total waste gas flow
into incinerator
Calculate O2 content, vol percent
Calculate dilution air for combustion, scfrn
Calculate dilution air for safety, scfm
Total gas flow into incinerator, scfm
20.98
0.00
0.00
1000.00 scfini
Step 2: Calculate heat content of waste gas into
incinerator, Btu/scf
Step 3: Calculate waste gas temperature out of
preheater, deg. F
- calculated assuming amount of auxiliary fuel
and dilution air are small so that mass flow
rates on both sides of the preheater are about
the same.
1.50
1,143
Step 4: Calculate auxiliary fuel required while
vent(s) operate, scfm
STEP 5: Calculate total gas flow out of
incinerator while vent(s) operate, scfm
11.83 FFmin
1011.83
Step 6: Calculate maximum auxiliary fuel flow
13.54 FFmax
-------
07-Jan-97; PVCSTHR4.V|
(when not
lartvtntedXscfin
Step 7: Calculate maximum total fa* flow out
of incuMratof. >cfin
1013.54 Kfin
Utitity requirements
Electricity, kwb/yr
- eombmed fen/motor efficie
Natural gat
f of 60 percent
-Btu/irr
50.208 KwMOOOOl 17XscfinX29 m. H20XCDh)D.6
6.828.452 OASft3-((FFiMxXl-Rmik)HFFminXRatio)X«)XCI»)
6.828.451.598 GASbm-(OASft3X1.000 Bfutaf)
June 1995 phot index
Feb 1989 plant index
June 199S equipment index
April 1988 plant index
Unit carts
Elbows, S/ca.
SS round duct diam. of main. S/ft
Autonntic damper. S/ea.
OeumiiMamtlor.yea.
Operator labor wage rate. S/hr
Maintenance labor wage rate, S/hr
3S2
35X4
4216
340.1
34X5
41.08 Eone-(0.«5Xl
29.14 Duct-(0.g5Xscfinr0.5(3«2^524)
854.11 ADone-(215»icfin*0.5+722X382/352 4)
5.000 DAone
15.64 WRo
17.21 WRrn
Capital Cons for Incinerator (June 1995 dollan). S
Recuperative incinerator
- use 500 scfin when max scfin from
step 7 is less than 500
Instrumentation
Sale* tax
Freight
Total purchased equipment cod
Direct installation coctt
Indirect cocts (tnttallali on)
Total capital nvectment
Capital Cocts for ManifbUing(June 1995 doUanX S
Purchaaed equipment ooct
Ductwork
Elbowi
RoMndduct
Automatic *"ny*^
Total (w/ inttr, tales tax. * freight)
•ime equal to PEC)
Total capital mvcttment
Capital Costs fat Monitoring (June 1995 dollanX $
Initial performance test
151.754 Rl-(21.342Xscfinr0.25(428.6/3401)
15.175 I-(RIXO I)
4.553 S-+DA)«l.l«
47.403 uHPECd)
94.806 TCIm-PECd+lm
24.420 TEST
3.000 TD
346.064 TO
-------
07-Jan-97; PVCSTHR4.VI
then TC1-1 J3xPECi+TClm*TEST+TD
- If icfin from itep 7 >- 20,000;
then TCHTClMtlm+TEST+TD
Annual corta.&'vr
Dinct annual oorti
Operating labor
Ooolral device
- Monitoring
Supervisory labor
Muntenano* labor
Moohorin««ippli
Utilitief
Natural pa
Electricity
Indirect umiul oo*U
Overhead
8,563
8.563 OLro-(0.5bT/8-hr*iftXWRoXCDh)
2469 SL-(0.15XOU+OLm)
9.422
9,422 MM-ML
500 MS
Property ux
Imumce
Capital recovery
- CRF. 0. 1424. baaed on 10-yn and 7% uitereit
Total annual cod. S/yr
22^34
2^62 Ehc-(K«hXSO 059/Vwh)
23.424 O-(0.6XOLc+OLm+SL+ML+MM+MS)
6^21 A-(0.02XTCI)
3,461 PT-<0.01XTCI)
3,461 (NS-(001XTCr)
49^79 CR-(CRFXTCO
151.012 TAC-OLc*OLm*SL*ML*MM+MS*NG*Elec*OA+rT
+INS+CR
-------
07-Jan-97; PVCSTHR41
CONDENSER COST ALOORTTHM (MACT floor)
Model number
Required condenser oootral efficiency;
Variablei and equations
1
03
Wa
Mas*fluxofHAP.Ib/yr
Ftawrate.tcfin
Ftownte,«cfin
Temperature, degrees C
- degrees C
. degrees F
HAP nolacular weight
VOCmoJefr«etion
VOC concentration, ppmv
Non condensable mote fraction
Operating hour*
Vent
Control device
Ratio of HAP venting lime to
control device operating time
HAP pollutant
Anloine equation constants
A
B
C
HAP partial procure at outlet, mm Hg
• assume* ideal gas
HAP mole fraction at outlet
Condensation temperature
- dcgieu C
- degrees F
Condenser exit Qovmt/e, fU/min
HAP critical temperature
.Molar he*t of condensation. Btu/lbmole
-at 25 degrees C
• atTCON
Molar heat capacity of HAP. Bbi/Ibmole/deg F
Molar heal capacity of air. Btu/lbnofe/deg F
Average characteristics during venting events
HAP in inlet stream
-Ibmole/hr
• Ib/hr
HAP in outlet stream
-Ibmole/hr
-Ib/hr
Heal load. BnVhr
Enthalpy change of condensed HAP
Enthalpy change ofnoncoadened HAP
Enthalpy change of aoncondencibk 'an*
Total enthalpy change
-BnVhr
30^00
1.000 Qm
1.000
Tl Tm
760 Plot
92 MWhap
0.00073 yin
752
0.9992
2.COO Vh
8,760 CDh
OJ196 Ratio-VhrCDh
Toluene
6.955 A
1344.1 B
219.4« C
0.057
KM! loftd during non venting pcfioo
- BnVhr (aammed to be 10H ofnmx load)
Total annual condenser heal load. Btu/yr
Log mean temperature diflerencc, deg F:
Coolant flow rate. Ib/hr
0 00008 yout-PP/Ptot
•55.43 Tdegc-((B/(A.loglOPP)K:)
^7.77 TCON-(TdegcX1.8>*32
729.91
16^28 Hcon
24.84 Cphap
6.95 Cpair
0.1151 Min-(QinXy&>X60 min/hrypW sft3/lbmole)
10.59 LBin-(MinXMWhip)
0011514 Mout-(MinXl-efl)
1.059 LBout<-(MoutXMWhap)
2.127 DELHcon^Mn>MoutXHcon-KCphapXTin.TCON))
41 DELHuncon-(MoutXCDhapXTtn-TCON)
153.192 DELHaiH((QinXMnibVhryp92)HMin)XCpairXTui.TCOX)
156,060 LOAOntax-OELHcon+OELHuncon+DELHair
13.005 Rmax-(LOADinaxyi2.000
15^06 LOADniip-(LOADDiaxXO I)
1J01 Rrnin-(U>ADminyi2.000
529.9M.709
54.41
9.596 Qcool
-------
07-Jan-97; PVCSTHR4.W
Manifolding deaign parameters
Diameter of collection mm (ft):
- calculated aawming a velocity of 2,000 ft/min
Length of duet, ft
Total number of vents
Number of elbow* per vent
Costing factore:
Operator labor wage rate, S/hr
Maintenance labor vjige rale. S/hr
Operating labor. hf/8-br operation
Supervisory labor. H of operating labor
Manttnaneelabor.br/V4iroperaiion
Mooftoring maintenance labor. hr/8-hr operation
O.SOO
300 L
6 Vent*
2 N
S15.64 WRo
S17.20 WRm
0.5
13
05
05
Utility requirements
Electricity, kwh/yr
Chemical Engineering Magazine Cost Indexes
June 1995 plant index
Feb 1989 plant index
August 1990 plant index
424.605
382
352.4
3548
-Ralio))*((-0 06973XTCON)
*3.446)'(CDh/0 85)
Unit costs (June 1995 dollars)
Detonation arrester. S/ea
Stainless round duct. S/ft
Elbow*, Ve«
Automatic damper. S/ea
Refrigeration unit cost, S
-multistage packaged unit
5.000 DAone
2914 Duct-{0 85XQui)"0.5(382/352 4)
48.08 Eone-(0.85Xl 65XQm)"0 5(382O52 4)
854 18 ADone-(2l5*Qin*0 5+722X382352 4)
157.501 RU-(exp(9.73-0 012'TCON*0 584«ln(Rmax))X382^54 8)
Capital Costs (June 1995 dollan).S
Equipment costs, S
Packaged refrigeration system
- includes instrumentation
Auxiliary equipment (manifolding) costs
Automatic damper (assume 1 per manifold)
Total round duct cost
Total elbow cost (2/vcnt)
Detonation arresters (I/vent)
Total
Purchased equipment coat
Packaged refrigeration system
Auxiliary equipment
Installation cost
Packaged refrigeration system
Auxiliary equipment (assume equal to PEC)
Monitoring costs
Initial PtifiHm^TKT test for condenser
Tneiiuucouple and datalogger
TOTAL CAPITAL INVESTMENT
Annual Costs, Vyr
Direct annual costs
Operating labor
Monitoring labor
Supervisor labor.
196.876 ECR-<1.25XRU)
854 AD-ADone
(.741 RD-(DuctXL)
577 Eall-(EoneXVentsXN)
30.000 DA-(DAoneXVents)
40.172 ECA-Eall+RIHAD+DA
212.626 PECrKECRXl 08)
47.403 PECa-(ECAXl 18)
31.194 MPECrXO.IS)
47.403 la-PECa
24.420 TEST
3.000 TO
366.747 TCI-PECr+PECa+Ir*Ia+TEST+TD
8.563 OL-(05reV8-hTShiftXWRoXCDh)
8.563 MOhfL-<0.5hr/8-hrshiftXWRoXCDh)
2.569 SL-(0.15XOL+MONL)
-------
07-Jan-97; PVCSTHR4v|
Maintenance labor 9.419 ML-{0.5 hr/Wir ifaiftXWRmXCDh)
Maintenance materials: 9.419 MM-ML
Monitariiig maintenance materials (supplies): 300 MONM
Electricity: 23.052 ELEO(KwhX$0 059/kwh)
Indirect nmual costs
Overhead 23,420 O-(0.6XOL+SL+ML+MONL+MM+MONM)
Property Uxe*. imurmnce. «dtaniijtimtive chirget: 14,670 PT1A-(0.04XTCO
Cental Recovoy 40^69 CR-(CRF)(TCO
- CRF, 0.109*. bMed on 15 ynud THmterest
TOTAL ANNUAL COST. S/yr 142,443 TAOOL+SL+ML*MM+MONL+MONM+ELEC
-KHPTIA+CR
EmiMioQ reduction. Mgfy 12J4
COST EFFECTIVENESS. S/Mg SI 1.543
6
-------
Attachment 2
Example calculations
1. Equation used to calculate concentration associated with flow rate cutoff:
C = (E x 385 x 1,000,000) / (MW x Q x 60 x H)
where,
C = HAP concentration, ppmv
E = HAP emissions, Ib/yr
MW = HAP molecular weight, Ib/lbmole
Q = Manifolded flow rate from all vents, scfrn
H = Process operating hours, h/yr
385 = cubic feet per Ibmole at standard conditions
60 = min/h
1,000,000 = conversion factor to ppmv
For model process 2, the equation yields the following result.
C = (88,200 lb/yr)(385 scf7lbmole)( 1,000,000)
(85 lb/lbmole)(285 scfrn)(60 min/h)(2,800 h/yr)
= 8,340 ppmv
2. Calculation of average flow rate for process 2 at surveyed plant 3 (page 11 of attachment 3):
weighted flow for PV001= (175 scfm)(168 h/8,136 h)= 3.61 scfm
weighted flow for PV002= (175 scfrn)(8,136 h/8,136 h)= 175 scfm
average flow rate for process= 179 scfm
3 Calculation of average concentration for process 2 at surveyed plant 3 (using the same
equation for sample calculation number 1):
C = (112,271 lb/yr)(385 scf71bmole)( 1,000,000)
(166 lb/lbmole)(179 scfm)(60 min/h)(8,136 h/yr)
= 2,980 ppmv
-------
Attachment 3
Data used to estimate maximum and average flow rates and HAP concentrations for manifolded
vents for processes at surveyed plants
-------
30-Apr-97;flm».wb2
PROCESS
NO. VENT*
Pbnl 17 (61-63)
. EM<0 45 PV002
MW
2 PV001
2 PV001
2 PV003
2 PV004
3 PV001
3 PV001
3 PV002
3 PV002
3 PV003
3 PV003
3 PV003
3 PV004
3 PV004
3 PV005
3 PVOOS
3 PV006
3 PV007
3 PV007
3 PV006
3 PVOOS
3 PV006
3 PV009
3 PV009
3 PV010
3 PV010
HAP
METHYLENE CHLORIDE
ACETONITRILE
METHYL ISOBUTYL KETONE
METHYL ISOBUTYL KETONE
METHYL ISOBUTYL KETONE
max flow w/b tost ore.
typical:
ACETONITRILE
METHYL ISOCYANATE
ACETONITRILE
METHYL ISOBUTYL KETONE
ACETONITRILE
HEXANE
METHYL ISOBUTYL KETONE
HEXANE
METHYL ISOBUTYL KETONE
HEXANE
METHYL ISOBUTYL KETONE
HEXANE
ACETONITRILE
HEXANE
ACETONITRILE
HEXANE
METHYL ISOBUTYL KETONE
ACETONITRILE
HEXANE
ACETONITRILE
HEXANE
average
PV001
PV002
PVOOS
PV004
PVOOS
PV006
PV007
PV008
METHANOL
METHANOL
METHANOL
METHANOL
METHANOL
METHANOL
METHANOL
METHANOL
85
41
100
100
100
41
57
41
100
41
86
100
86
100
86
100
86
41
86
41
86
100
41
86
41
86
32
32
32
32
32
32
32
32
SCFM
0962
452
4.52
2.19
218906
6.71
same
1292
12.92
4.13
4.13
4.13
413
413
9301
9301
214
214
214
4.67
467
1.63
1.63
1.63
225
225
214
214
1292
36
013
44457
043
919
91.9
406
1151
1 1
iTION UNCON LBMOLE/
IR/YR
1548
1920
1920
1920
1920
2424
2424
2424
2424
2424
2424
2424
50.5
SOS
SOS
505
2424
2424
2424
2424
2424
2424
;<&$i
242*
2424
2424
8064
8064
8064
168
168
8064
8064
8064
LB/YR
743.04
1536
16512
0.008
8E-05
18.048
484
2424
242
242
1188
11150
146
22
SOS
22
50.5
8726
582
20362
1454.4
3878.4
1939.2
4032
16773
2424
970
337055
274
187080
145.2
9912
9912
48384
53222
111283
YR
874
37.46
16512
0.00
0.00
202.58
1180
42.53
5.90
2.42
28.98
129.65
146
0.26
0.51
026
051
10.15
14.20
2368
3547
4510
1939
9834
19.50
5.91
1128
5073
0.86
584625
454
30975
309.75
151.20
16632
34.78
AVG/
MW
85.00
7.58
81.51
000
0.00
891
0.95
4.78
0.48
0.48
2.34
21.98
0.29
0.04
0.10
0.04
0.10
1.72
1.15
4.01
2.87
7.65
382
795
3.31
048
1.91
664
000
1356
001
0.72
072
035
039
008
CONTL.
LB/YR
297
7.68
826
4E-06
4E-07
2.42
12.12
1.21
1.21
594
55.8
0.73
22
505
22
50.5
4.36
2.91
10.18
7.27
19.39
9.7
4032
167.3
1.21
4.85
014
9354
0.73
9912
9912
2419
2661
1112.83
TYPE
C
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
LB/MIN
0.00800
0.01333
0.14333
0.00000
0.00000
0.1567
0.00333
0.01667
000166
0.00166
0.00817
0.07666
0.00100
0.00726
0.01667
0.00726
0.01667
0.00600
0.00400
0.01400
001000
0.02667
0.01333
0.02772
0.01153
0.00167
0.00667
02786
0.00006
0.38666
000030
098333
0.98333
O.O1000
0.01100
000230
PPMV
37.667
27.700
122.087
0
0
100.900
2.419
8.713
3.783
1.551
18.572
83.100
936
349
690
15.189
29.984
12.551
8.046
13.421
57.609
73,239
31.493
115.699
22,946
7.313
13.952
12.495
37.301
S.241
10.464
8.397
128.735
128.735
29,634
11.498
25.156
-------
30-Apr-97;flovw.wb2
PROCESS
NO. VENT*
4 PV009
4 PV010
4 PV011
4 PV012
page2
MW
HAP
METHANOL
METHANOL
METHANOL
METHANOL
average:
32
32
32
32
SCFM
1.1
4.51
10.46
406
666
486
DURATION UNCON. LBMOLE/ AVQ/ CONTL
HR/YR LB/YR YR
6064 693.5 21.67
8064 159667 4969.59
8064 58060.8 1814 40
8064 4838.4 151.20
441.610 13.800
LB/MIN
PPMV
MW
0.05
11.57
4.21
0.35
32
LB/YR TYPE
3.47 U
798.34 U
290.3 U
24.19 U
3414.44
0.00143
0.33000
0.12000
0.01000
2.84
15.677
880.334
138.026
29.634
51.297
22.595
-------
30-Apr-97;flov».wt>2
PROCESS
NO. VENT*
pag»3
Plant 1 (1-4)
PV001
PV002
PV003
PV003
PV004
2 PV001
2 PV002
2 PV003
2 PV003
2 PV004
3 PV001
3 PV002
3 PV003
3 PV003
3 PV004
PV001
PV002
PV003
PV003
PV004
HAP
TOLUENE
TOLUENE
BENZYL CHLORIDE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
BENZYL CHLORIDE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
BENZYL CHLORIDE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
BENZYL CHLORIDE
TOLUENE
TOLUENE
average
average
average
MW
92
92
1265
92
92
92
92
1265
92
92
92
92
1265
92
92
92
92
126.5
92
92
average
SCFM
3062
18481
925
925
51966
74454
same
3082
18481
925
925
51966
74454
same
3082
18481
925
925
51966
74454
same
3082
18481
925
925
51966
74454
same
TION UNCON. LBMOLE/
R/YR
5040
5040
5040
5040
5040
336
336
336
336
336
720
720
720
720
720
720
720
720
720
720
LB/YR
131227.8
322796
24481
128862.7
5798.3
300.617
54199
13332
101.1
5322.2
239.5
12.416
18723 4
4605.6
3493
183859
8273
42.892
8869
21816
165.5
87091
391.9
YR
1426.39
350.87
19.35
140068
63.03
3.260
5891
1449
0.80
57.85
260
135
203.52
5006
2.76
199.85
899
465
9640
2371
131
9466
426
AVQ/
MW
40.25
990
0.75
39.52
1.78
92
40.25
9.90
0.75
3952
1.78
92
4025
990
075
3952
1.78
92
4025
990
0.75
3952
178
CONTL
LB/YR T\
6561.4 U
32279.6 U
2448.1 C
128862.7 U
5798.3 U
175.950
271 U
1333.2 U
101.1 C
5322.2 U
239.5 U
7.267
936.3 U
4605.6 U
349.3 C
18385.9 U
827.3 U
25.104
443.4 U
2181.6 U
165.5 C
87091 U
391.9 U
20.317
220
92
11.892
LB/MIN
043395
0.10674
0.00810
0.42613
0.01917
0.99
0.26684
0.06613
0.00501
0.26400
0.01188
0.62
0.43341
0.10661
000809
0.42560
0.01915
099
0.20530
005050
0.00383
0.20160
000907
0.47
PPMV
589
24
27
1.928
2
56
365
15
17
1.104
1
35
588
24
27
1.925
2
56
279
11
13
912
1
26
-------
30-Apr-97;flows.wb2
PROCESS
NO. VENT#
Plant 21 (67-73))
page 4
MW
HAP
1 PV002
1 PV003
1 PV004
1 PV005
1 PV006
1 PV007
1 PV008
1 PV009
1 PV010
1 PV011
1 PV012
1 PV013
1 PV013
1 PV014
1 PV015
1 PV016
1 PV017
1 PV018
METHANOL
METHANOL
METHANOL
METHANOL
METHANOL
METHANOL
METHANOL
METHANOL
METHANOL
METHANOL
METHANOL
METHANOL
TOLUENE
TOLUENE
METHANOL
TOLUENE
METHANOL
TOLUENE
PV001
PV002
PV003
PV004
PV005
2 PV006
3 PV001
3 PV002
3 PV003
3 PV004
3 PV005
3 PV006
4 PV001
4 PVOO2
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
average:
average:
average:
32
32
32
32
32
32
32
32
32
32
32
32
92
92
32
92
32
92
92
92
92
92
92
92
92
92
92
92
92
92
92
92
SCFM
8
0.604
125.5
4.5
450
135
3.34
0.19
0.67
3.4
4.7
129
129
2.07
388
2543
14.71
5.2
3,818
same
1015
8.1
13.2
9.8
0.6
36.5
1,083
1,078
1015 /
8.1 J
13.2
9.8
0.6
36.5
1,083
same
1O15 ;
8.1 f
;ATION UNCON. LBMOLE/
HR/YR
8400
8400
8400
8400
8400
8400
8400
8400
8400
8400
8400
9400
84<}0
8400
8400
8400
S40&:
8400
40ft
405$
3682.5
3682.5
3682.5
3682.5
"'B»
S?0
5?0
6*>
S?o,
*70
' m-
iS?,'
LBA'R
10080
22.74
2988
224.64
99426
27448
239.04
432
463.68
207.36
15.84
52.992
8481.6
15.84
705.6
132480
15.84
43.2
283.342
2101
13026
4454
2983
218.5
39991
62,774
420.75
2608.65
891.99
597.46
286.15
8008.76
12,814
33
204.6
YR
315.00
0.71
93.38
7.02
3107.06
857.75
7.47
13.50
14.49
6.48
0.50
1.66
92.19
0.17
22.05
1440.00
0.50
0.47
5,980
22.84
141.59
48.41
32.42
2.38
434.68
682
4.57
28.35
9.70
6.49
3.11
87.05
139
0.36
2.22
AVG/
MW
1.69
0.00
0.50
0.04
16.63
4.59
0.04
0.07
0.08
0.03
0.00
0.01
1.42
0.00
0.12
22.15
0.00
0.01
47
3.08
19.09
6.53
4.37
0.32
58.61
92
3.02
18.73
6.40
4.29
2.05
57,50
92
3.08
19. 09
CONTL.
LBA'R TY
100.8 U
21.6 U
119.52 U
224.64 U
99426 U
27448 U
239.04 U
4.32 U
463.68 U
10.368 U
15.84 U
13.248 U
8481.6 U
15.84 U
705.6 U
2649.6 U
15.84 U
43.2 U
139,999
42 U
260.5 U
4454 U
2983 U
218.5 U
1159.7 U
9,118
8.41 U
52.2 U
891.99 U
597.46 U
286.15 U
232.25 U
2.068
0.66 U
4.O9 U
LB/MIN
0.02000
0.00005
0.00593
0.00045
0.19727
0.05446
0.00047
0.00086
0.00092
0.00041
0.00003
0.00011
0.01683
0.00003
0.00140
0.26286
0.00003
0.00009
0.56
0.00863
0.05353
0.02016
0.01350
0.00099
0.18100
0.278
0.01230
0.07628
0.02608
0.01747
0.00837
0.23417
0.375
0.00433
O.O2685
PPMV
30,078
899
568
1,192
5.274
4.854
1.708
54.276
16,521
1,456
80
10
546
64
43
433
26
69
1,197
36
27.653
6.391
5,765
6,897
20,751
1,073
1,001
51
39.407
8,269
7.460
58.357
26,848
1.447
18
13,872
-------
30-Apr-97;flows.wb2
PROCESS
pages
MW
NO.
VENT*
PV003
PV004
PV005
PV006
5 PV001
5 PV002
5 PV003
5 PV004
5 PV005
5 PV006
PV001
PV002
PV003
PV004
PV005
PV006
PV001
PV002
PV003
PV004
PV005
PV006
HAP
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
average:
average:
average:
average:
/ DURATION
92
92
92
92
92
92
92
92
92
92
92
92
92
92
92
92
92
92
92
92
92
92
SCFM
13.2
9.8
0.6
36.5
1.083
1,050
1015
8.1
13.2
9.8
0.6
36.5
1,083
1.067
1015
8.1
13.2
9.8
0.6
365
1,083
1,063
1015
8.1
13.2
9.8
0.6
36.5
1,083
1,063
HR/YR
57.8
57.8
57.8
57.8
144
$44
106
106
106
106
188
J8B
110.9
110.9
110.9
110.9
' m
189
125.3
125.3
125.3
125.3
UNCON. LBMOLE/
LB/YR
69.96
46.86
3.43
628.1
986
60.5
375.1
128.26
85.91
6.29
1151.6
1.808
63.25
392.15
134.09
89.81
6.58
1203.93
1.890
71.5
443.3
151.58
101.53
7.44
1360.97
2,136
YR
0.76
0.51
0.04
6.83
11
0.66
4.08
1.39
0.93
0.07
12.52
20
0.69
4.26
1.46
0.98
0.07
13.09
21
0.78
4.82
1.65
1.10
0.08
14.79
23
AVG/ CONTL.
MW
6.53
4.37
0.32
58.61
92
3.08
19.09
6.53
4.37
0.32
58.61
92
3.08
19.09
6.53
4.37
0.32
58.61
92
3.08
19.09
6.53
4.37
0.32
58.61
92
LB/YR TYPE
69.96 U
46.86 U
3.43 U
18.2 U
143
1.21 U
7.5 U
128.26 U
85.91 U
6.29 U
33.4 U
263
1.26 U
7.84 U
134.09 U
89.81 U
6.58 U
34.91 U
274
1.43 U
8.87 U
151.58 U
101.53 U
7.44 U
39.47 U
310
LB/MIN
0.02017
0.01351
0.00099
0.18111
0.247
0.00700
0.04341
0.02017
0.01351
0.00099
0.18107
0.266
0.00627
0.03890
0.02015
0.01350
0.00099
0.18093
0.261
0.00631
0.03909
0.02016
0.01350
0.00099
0.18103
0.261
PPMV
6.395
5.770
6,898
20,765
954
455
29
22,430
6,393
5,768
6,898
20,760
1,028
821
26
20,099
6,389
5,764
6,897
20,744
1,007
861
26
20,196
6,392
5,767
6,902
20,755
1,009
973
-------
30-Apr-97;flows.wb2
PROCESS
NO. VENT #
Plant 7 (17,18)
MW
HAP
SCFM
DURATION UNCON. LBMOLE/
HR/YR LB/YR YR
AVG/ CONTL.
MW LB/YR TYPE
LB/MIN
PPMV
1 PV001
2 PV001
2 PV002
2 PV006
2 PV006
2 PV007
2 PV007
2 PV008
2 PV009
2 PV009
1,3-BUTADIENE
CARBON
CARBON
CARBON
CARBON
CARBON
CARBON
CARBON
CARBON
CARBON
average:
DISULFIDE
DISULFIDE
DISULFIDE
TETRACHLORIDE
DISULFIDE
TETRACHLORIDE
DISULFIDE
DISULFIDE
TETRACHLORIDE
average:
54
76
76
76
154
76
154
76
76
154
20
same
10000
10000
900
900
4000
4X#
350
4000
4000
29,250
15,250
760
850
4450
5300
5300
850
850
5300
4450
4450
72800
85
450
10800
220
240
30
15000
1260
150
28,235
1348.15
1.12
5.92
142.11
1.43
3.16
0.19
197.37
16.58
0.97
369
54
0.23
1.22
29.28
0.60
0.65
0.08
40.67
3.42
0.41
76.5
1456 U
85 U
450 U
10800 U
220 C
240 U
30 C
15000 U
1260 U
150 C
1.59649
0.00167
0.00169
0.03396
0.00069
0.00471
0.00059
0.04717
0.00472
0.00056
0.096
569,120
1
1
191
2
6
0.4
683
6
0
16
29
page6
-------
30-Apr-97;flows.wb2
PROCESS
NO. VENT#
Plant 12(37-40)
MW
HAP
1 PV002
1 PV003
1 PV003
1 PV004
1 PV004
1 PV005
1 PV005
1 PV006
1 PV007
1 PV008
1 PV009
1 PV010
1 PV011
1 PV011
1 PV012
1 PV012
1 PV013
1 PV014
1 PV015
1 PV016
1 PV017
1 PV017
1 PV018
1 PV019
1 PV020
METHANOL
METHANOL
TOLUENE
METHANOL
TOLUENE
METHANOL
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
METHANOL
METHANOL
TOLUENE
METHANOL
TOLUENE
TOLUENE
TOLUENE
TOLUENE
TOLUENE
METHANOL
TOLUENE
TOLUENE
TOLUENE
TOLUENE
average:
2 PV001 HYDROGEN CYANIDE
2 PV002 METHANOL
2 PV003 METHANOL
2 PV004 HYDROGEN CYANIDE
2 PV004 TOLUENE
2 PV005 TOLUENE
2 PV006 TOLUENE
2 PV007 METHANOL
2 PV008 METHANOL
2 PV009 METHANOL
2 PV010 TOLUENE
2 PV011 TOLUENE
32
32
92
32
92
32
92
92
92
92
92
32
32
92
32
92
92
92
92
92
32
92
92
92
92
27
32
32
27
92
92
92
32
32
32
92
92
average:
SCFM
1.4
7.9
7.9
11.7
11.7
0.07
0.07
2.5
3.6
1.4
4.7'
3.9
4
4
6.9
6.9
5.1
6.6
0.7
0.2
6.2
6.2
2.7
2.6
3.8
75.97
same
2608
4.2
4.9
1
1
6.8
5.4
4.8
5.1
2.6
7
1
2650.8
1.993
HR/YR
3* "fl368
"IIP
V^'v %1368
1368
m
1*38
1068
876
876
219
CON. LBMOLE/
3/YR
14
1380
340
420
3680
60
360
300
614
140
18
118
130
94
100
80
88
98
52
36
510
848
334
14
290
10118
16900
160
40
100
360
18280
120
68
34140
140
220
40
YR
0.44
43.13
3.70
13.13
40.00
1.88
3.91
3.26
6.67
1.52
0.20
3.69
4.06
1.02
3.13
0.87
0.96
1.07
0.57
0.39
15.94
9.22
3.63
0.15
3.15
165.7
625.93
5.00
1.25
3.70
3.91
198.70
1.30
2.13
1066.88
4.38
2.39
0.43
AVG/
MW
0.08
8.33
2.05
2.54
22.21
0.36
2.17
1.81
3.71
0.85
0.11
0.71
0.78
0.57
0.60
0.48
0.53
0.59
0.31
0.22
3.08
5.12
2.02
0.08
1.75
61.1
8.82
0.08
0.02
0.05
0.19
9.54
0.06
0.04
17.82
0.07
0.11
0,02
CONTL.
LB/YR TYPE
0.0014 U
0.138 U
0.034 U
0.042 U
0.368 U
0.006 U
0.036 U
0.03 U
0.0614 U
0.014 U
0.0018 U
0.0118 U
0.013 U
0.0094 U
0.01 U
0.008 U
0.0088 U
0.0098 U
0.0052 U
0.0036 U
0.051 U
0.0848 U
0.0334 U
0.0014 U
0.029 U
0.0845 U
0.016 U
0.004 U
0.01 U
0.036 U
1.828 U
0.012 U
0.0068 U
3.414 U
0.014 U
0,022 U
40 U
70,568
1,916
36.8
LB/MIN
0.00017
0.01681
0.00414
0.00512
0.04483
0.00073
0.00439
0.00365
0.00748
0.00171
0.00022
0.00144
0.00158
0.00115
0.00122
0.00097
0.00107
0.00119
0.00063
0.00044
0.00621
0.01033
0.00407
0.00017
0.00453
0.124
0.32154
0.00228
0.00057
0.00142
0.00513
0.26040
0.00171
0.00097
0.48632
0.00199
0.00419
0.00304
1.09
PPMV
1,466
25.605
2.194
5.262
16,036
125,640
262.204
6.118
8.696
5.098
195
4,435
4.764
1,198
2.124
591
880
757
3,787
9.177
12.057
6.973
6,307
275
4,984
10,310
1,758
6,529
1,399
20,312
21,460
160,252
1,325
2,428
1,147,274
9,228
2,502
12,739
4,297
5.273
-------
30-Apr47;tam.wb2
PROCESS
NO. VENT i
3 PV001
3 PV001
3 PV002
3 PV002
3 PV003
3 PV003
3 PV004
3 PV005
PV001
PV002
PV009
PV004
PV006
PV008
PV007
PV008
PVOOQ
PV000
PV010
PV012
PV013
pages
MW
HAP
PHOSGENE 99
TRICHLOROETHYLENE 131.5
PHOSGENE 99
TRICHLOROETHYLENE 131.5
PHOSGENE 99
TRICHLOROETHYLENE 131.5
TRICHLOROETHYLENE 131.5
TRICHLOROETHYLENE 131.5
TRICHLOROBENZENE 181
TRICHLOROBENZENE 181
TRICHLOROBENZENE 181
HEXANE 86
HEXANE 86
HEXANE 86
HEXANE 86
HEXANE 86
HEXANE 86
METHYL CHLORIDE 505
HEXANE 86
TRICHLOROBENZENE 181
TRICHLOROBENZENE 181
SCFM
DURATION UNCON. LBMOLE/
HR/YR LB/YR YR
AVG/ CONTL.
MW LB/YR TYPE
LB/MIN
PPMV
120
120
2
2
120
120
25
1
2455
122
12
12
0.13
0.27
1
4
03
6
2
2
1
8.5
05
47.7
63
6900
6900
7000
7000
70
70
50
1
17
17
720
720
720
57
720
33
456
456
720
57
720
393600
35200
180
4380
3980
358
60
4
437.762
20
12
260
3720
2800
960
2880
1026
18300
71440
4240
72
520
106.250
3975.76
267.68
1.82
33.31
40.20
2.72
0.46
0.03
4.322
0.11
0.07
1.44
43.26
32.56
11.16
33.49
11.93
21 £79
1414.65
49.30
0.40
2.87
1.814
91.07
8.14
0.04
1.01
0.92
0.08,
0.01'
0.00
101.3
0.01
0.01
0.14
2.05
1.64
0.53
1.59
0.57
1009
3938
2.34
0.04
0.29
586
39.36 C
3.52 C
0.018 C
0.438 C
3980 C
358 C
60 C
4 C
0.002 C
0.0012 C
0.026 C
0.372 U
0.28 U
0096 U
0.288 U
0.1026 U
1.83 U
7.144 C
4240 U
72 C
520 C
0.95072
0.08502
0.00043
0.01043
0.04762
0.06524
0.02000
0.06667
2.17
0.01961
0.01176
0.00602
O.OS611
0.06481
0.28070
0.06667
0.51818
0.66886
241111
0.09815
0.0210S
0.01204
4.47
30,811
2,074
833
15.266
30,710
2.080
23,422
195.184
33,538
32.474
3.476
2.065
98.476
1.427.768
290.159
314.157
994,832
386,628
1,497.167
9.953.245
439.384
5.268
51.207
615.298
263.946
-------
pages
30-Apr-97;flows.wb2
PROCESS
NO.
VENT#
Plant 9 (25)
2 PV001
2 PV001
2 PV002
2 PV003
HAP
CARBON TETRACHLORIDE
HEXACHLOROETHANE
CARBON TETRACHLORIDE
CARBON TETRACHLORIDE
MW
SCFM
DURATION UNCON. LBMOLE/ AVG/
HR/YR LB/YR YR MW
CONTL.
LB/YR TYPE
LB/MIN
PPMV
154
237
154
154
1-8ltl
1 .8
0.17
NA
1.97
1.84
701
0
33849
6286
0.003
0
40,135
220
27
1 .95E-05
0
246
137
26
0
0
163
3.4 C
0.6 C
0.003 C
0 C
0.16671
0.03096
0.00000
ERR
0.19767
231.543
27,940
1
ERR
237.092
253,843
-------
30-Apr 97;fflows.wb2
page 10
PROCESS
NO. VENT*
MW
Plant 10 (27)
PV001
PV001
PV002
PV002
PV003
PV003
HAP
CARBON TETRACHLORIDE
TETRACHLOROETHYLENE
CARBON TETRACHLORIDE
TETRACHLOROETHYLENE
CARBON TETRACHLORIDE
TETRACHLOROETHYLENE
average:
SCFM
DURATION UNCON. LBMOLE/
HR/YR LB/YR YR
LB/MIN
PPMV
154
166
154
166
154
166
1.6
1.6
7.2
7.2
131.8
131.8
140.6
same
7680
7680
7680
7680
WQ
?6St>
18161
2551
24583
16006
6833
788
68.922
117.9
15.4
159.6
96.4
44.4
4.7
438
41.4
5.8
56.1
36.5
15.6
1.8
157
9080 C
1275 C
24337 C
15847 C
75.9 C
7.4 C
0.03941
0.00554
0.05335
0.03474
0.01483
0.00171
0.14957
61.581
8.025
18,524
11,189
281
30
2,606
-------
30-Apr-97 ;flows .wb2
PROCESS
NO. VENT#
Plant 3 (6, 7. 11.12)
2 PV001
2 PV002
3 PV001
3 PV001
3 PV001
3 PV001
7 PV002
7 PV003
7 PV006
8 PV001
8 PV002
8 PV003
8 PV004
8 PV005
8 PV006
MW
HAP
TETRACHLOROETHYLENE
TETRACHLOROETHYLENE
average:
CARBON TETRACHLORIDE
CHLOROFORM
ETHYL CHLORIDE
TRICHLOROETHYLENE
average:
METHANOL
METHANOL
METHANOL
METHANOL
METHANOL
METHANOL
METHANOL
METHANOL
METHANOL
average:
166
166
154
119
64.5
131.5
32
32
32
32
32
32
32
32
32
average:
SCFM
175
175
350
179
80
80
80
80
80
same
0.015
0.0088
0.0015
0.0253
same
0.024
0.046
0.024
0.0012
0027
0.023
0.1452
same
TION UNCON. LBMOLE/
R/YR
168
8136
Sfcoa
$m
m$
mt
7200
7200
7200
2400
2400
2400
2400
2400
2400
LB/YR
2271
110000
112,271
542
313
543
130
1,528
520
315
53
888
280
550
280
14
320
280
YR
13.7
662.7
676
3.5
2.6
8.4
1.0
16
16.3
9.8
1.7
27.75
8.8
17.2
8.8
0.4
10.0
8.8
AVG/
MW
3.4
162.6
166
34.8
20.1
34.9
8.4
98
18.7
11.4
1.9
32
5.2
10.2
5.2
0.3
5.9
5.2
CONTL.
LB/YR Ti
2271 C
11 C
542 C
313 C
543 C
130 C
0.5 U
0.3 U
0.05 U
28 U
55 U
28 U
1 U
32 U
28 U
1724
53.875
32
LB/MIN
0.22530
0.22534
0.45063
0.00173
0.00100
0.00174
0.00042
0.00489
0.00120
0.00073
0.00012
0.002056
0.00194
0.00382
0.00194
0.00010
0.00222
0.00194
0.011972
PPMV
2.986
2.986
2,986
2,980
54
41
130
15
240
965,471
996,908
984,037
977.506
974,754
998,972
974,754
974.754
990.226
1,017.135
992.017
-------
30-Apr-97.1ows.wb2
PROCESS MW DURATION UNCON. LBMOLE/ AVG/ CONTL. LB/MIN PPMV
NO. VENT* HAP SCFM HR/YR LB/YR YR MW LB/YR TYPE
pago12
Plant 6 (16)
1 PV001 CARBON OISULFIDE 76 9.5 1370 36410 479.1 76 3640 U 044294 236.196
average same
-------
page 13
PROCESS
NO. VENT *
Plant 20 (66)
2 PV001
2 PV002
2 PV003
2 PV004
MW
HAP
MALEIC ANHYDRIDE
ACETONITRILE
ACETONITRILE
ACETONITRILE
98
41
41
41
average:
SCFM
1.51
12.44
3689
5084
same
ION UNCON. LBMOLE/
I/YR
840
840
840
LB/YR
5.76
413.58
140000
40000
YR
0.1
10.1
3414.6
AVG/
MW
0.002
0.121
40879
CONTL.
LB/YR TYPE
5.76 O
413.58 U
560 U
BOO U
140.419
3.425
LB/MIN
0.00011
0.00821
277778
2.79
PPMV
297
6.194
707.075
514.585
-------
30-Apr-97;flows.wb2
PROCESS
NO. VENT*
Plant 23 (89-94)
3 PV001
3 PV001
4 PV001
4 PV001
5 PV001
5 PV002
6 PV001
6 PV001
6 PV001
MW
PV001
PV001
PV001
PV002
PV002
PV002
PV003
PV004
PV005
PV006
PV006
PV006
PV007
PV007
PV007
PV008
PV008
PV009
HAP
ETHYLENE DICHLORIDE
FORMALDEHYDE
average:
ETHYLENE DICHLORIDE
FORMALDEHYDE
average:
ETHYLENE DICHLORIDE
ETHYLENE DICHLORIDE
average:
ETHYL CHLORIDE
METHYL CHLORIDE
TOLUENE
average:
7 PVO1O
FORMALDEHYDE
METHANOL
TRIETHYLAMINE
FORMALDEHYDE
METHANOL
TRIETHYLAMINE
FORMALDEHYDE
FORMALDEHYDE
METHANOL
FORMALDEHYDE
METHANOL
TRIETHYLAMINE
ETHYLENE DICHLORIDE
FORMALDEHYDE
TOLUENE
FORMALDEHYDE
TRIETHYLAMINE
TOLUENE
ETHYLENE DICHLORIDE
99
30
99
30
99
99
64.5
50.5
92
30
32
101
30
32
101
30
30
32
30
32
101
99
30
92
30
101
92
99
SCFM
1400
1400
1400
same
1400
1400
1400
same
2000
2900
4900
same
270
270
270
270
same
1.7
1.7
1.7
4.6
4.6
4.6
2.9
2.9
0.87
4.6
4.6
4.6
190
190
190
76
76
1 7E-05
5OO
TION UNCON. LBMOLE/
R/YR
2320
2320
1340
1340
7488
7488
380
360
360
4150
4150
4150
4150
4150
4150
4150
4150
4150
4150
4150
4150
4150
4150
4150
4150
4150
4150
41 SO
LB/YR
29
754
783
17
436
453
6300
2570
8870
780
290
3075
3365
4.1
85
390
14
33
43
0.023
0.023
3.9
14
33
43
26
70
7
33
295
5.6
0.9
YR
0.29
25.13
25.4
0.17
14.53
14.7
63.64
25.96
89.6
12.09
5.74
33.42
39.2
0.14
2.66
3.86
0.47
1.03
0.43
0.00
0.00
0.12
0.47
1.03
0.43
0.26
2.33
0.08
1.10
2.92
0.06
O.O1
AVG/
MW
1.14
29.65
30.8
1.16
29.65
30.8
70.3
28.7
99.0
19.9
7.4
78.5
85.9
0.0
0.0
0.2
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.1
0.0
o.o
CONTL.
LB/YR TYPE
9 C
226 U
5 C
131 U
228 C
2570 C
0.78 C
0.29 C
3.2 U
4.1 U
85 U
390 U
14 U
33 U
43 U
0.046 U
0.023 U
3.9 U
14 U
33 U
43 U
8 C
21 U
2.1 U
33 U
295 U
5.6 U
0.26 C
LB/MIN
0.00021
0.00542
0.00563
0.00021
0.00542
0.00563
0.01402
0.00572
0.01974
0.03611
0.01343
0.14236
0.19190
0.00002
0.00034
0.00157
0.00006
0.00013
0.00017
0.00000
0.00000
0.00002
0.00006
0.00013
0.00017
0.00010
0.00028
0.00003
0.00013
0.00118
O.OOOO2
o.ooooo
PPMV
1
50
50
1
50
50
27
8
16
798
379
2.206
3.185
124
2,416
3.512
157
347
143
0
0
217
157
347
143
2
19
1
22
59
5.536.211
O
-------
PROCESS
NO.
VENT*
PV010
PV010
PV010
PV011
PV011
PV011
PV012
PV012
PV012
PV012
8 PV001
8 PV001
8 PV001
8 PVD02
8 PV002
8 PV002
8 PV003
8 PV003
8 PV003
8 PV004
8 PV005
8 PV006
8 PV007
8 PV007
8 PV007
8 PV008
8 PV008
8 PV009
8 PV010
8 PV010
8 PV010
8 PV011
8 PV011
8 PV011
8 PV012
8 PV012
8 PV012
HAP
METHANOL
METHYL CHLORIDE
METHYLENE CHLORIDE
FORMALDEHYDE
METHANOL
TRIETHYLAMINE
ETHYLENE DICHLORIDE
METHANOL
METHYL CHLORIDE
METHYLENE CHLORIDE
average
FORMALDEHYDE
METHANOL
TRIETHYLAMINE
FORMALDEHYDE
METHANOL
TRIETHYLAMINE
FORMALDEHYDE
METHANOL
TRIETHYLAMINE
FORMALDEHYDE
FORMALDEHYDE
METHANOL
ETHYLENE DICHLORIDE
FORMALDEHYDE
TOLUENE
FORMALDEHYDE
TRIETHYLAMINE
TOLUENE
FORMALDEHYDE
METHANOL
TRIETHYLAMINE
ETHYL CHLORIDE
ETHYLENE DICHLORIDE
TOLUENE
ETHYL CHLORIDE
ETHYLENE DICHLORIDE
TOLUENE
average
IW ' DURATION
32
50.5
85
30
32
101
99
32
505
85
30
32
101
30
32
101
30
32
101
30
30
32
99
30
92
30
101
92
30
32
101
645
99
92
645
99
92
SCFM
500
500
500
100
100
100
6000
6000
6000
6000
6884
same
1.7
17
17
46
46
4.6
46
46
46
29
29
087
190
190
190
76
76
1 7E 05
100
100
100
500
500
500
6000
6000
6000
6884
same
HR/YR
4150
4150
4150
4150
4150
4150
4150
4150
4150
4150
4370
4370
4370
4370
4370
4370
4370
4370
4370
4370
4370
4370
4370
4370
4370
4370
4370
4370
4370
4370
4370
4370
4370
4370
4370
4370
4370
UNCON LBMOLE/
LB/YR
2
2319
26
590
23
39300
55
4.6
85900
22
129.342
4.2
85
390
15
34
43
15
34
43
0.023
0023
4
27
70
8
34
295
56
127
56
83000
2725
25
130
55700
46
406
143.258
YR
0.06
45.92
0.31
19.67
0.72
389.11
056
0.14
1700.99
026
2.175
014
266
386
050
1.06
0.43
050
106
043
0.00
0.00
0.13
027
2.33
0.09
1.13
292
006
4.23
1.75
82178
4225
0.03
141
86357
005
441
1.757
AVG/ CONTL.
MW
00
1.1
00
0.3
0.0
18.1
0.0
00
395
00
59
0.00
005
0.22
001
002
002
001
002
002
000
0.00
000
0.02
0.04
0.00
002
017
0.00
007
003
4724
1.55
000
007
3170
000
023
82
LB/YR TYPE
0.6 U
2319 C
26 C
177 U
7 U
11800 U
3 C
0.2 U
14500 C
3.72 C
4.2 U
85 U
390 U
15 U
34 U
43 U
15 U
34 U
43 U
0.023 U
0.023 U
4 U
8 C
21 U
2.4 U
34 U
295 U
56 U
38 U
7 U
24900 U
2725 C
074 C
39 U
4660 C
0.1 C
10 U
LB/MIN
000001
000931
0.00010
0.00237
0.00009
0.15783
0.00022
0.00002
0.34498
0.00009
052
0.00002
0.00032
0.00149
0.00006
000013
000016
0.00006
0.00013
000016
000000
0.00000
0.00002
0.00010
0.00027
0.00003
0.00013
000113
000002
000048
0.00021
0.31655
0.01039
000001
000050
021243
000002
0.00155
054637
PPMV
0
142
1
304
11
6,016
0
0
438
0
489
121
2,294
3.335
160
339
136
160
339
136
0
0
211
2
18
1
22
56
5.257.500
62
26
12.067
124
0
4
211
0
1
375
-------
30-Apr-87;flcvw.wb2
PROCESS
NO. VENT *
page 16
MW
HAP
SCFM
DURATION UNCON. LBMOLE/ AVQ/ CONTL
HfVYR LB/YH YR MW LB/YR
LB/MIN
PPMV
TYPE
-------
3O-Apr-97 ;flows .wb2
PROCESS
NO. VENT*
Plant 5 (.14,15)
1 PV001
1 PV002
1 PV003
MW
PV001
PV002
PV003
PV003
PV004
PV004
PV005
HAP
GLYCOL ETHER
GLYCOLETHER
GLYCOL ETHER
METHYL CHLORIDE
METHYL CHLORIDE
METHANOL
METHYL CHLORIDE
METHANOL
METHYL CHLORIDE
METHYL CHLORIDE
average:
90
90
90
50.5
50.5
32
50.5
32
50.5
50.5
average:
SCFM
58.7
66.5
0.07
125.27
same
9.9
9.9
6.9
6.9
6.9
6.9
N/A
23.7
same
TION UNCON. LBMOLE/
R/YR
7464
7464
W&
§030
6039
6039
6039
6039
9039
LB/YR
1000
1000
20
2020
0
9980
47000
9980
47000
400
YR
11
11
0
22.4
0.00
312
931
312
931
AVG/
MW
44.6
44.6
0.9
90.0
0
4.02
18.91
4.02
18.91
CONTL.
LB/YR Pi
20 U
20 U
20 U
0 C
0 C
9980 U
47000 C
9980 U
47000 C
400 C
113,960
2,485
46
LB/MIN
0.00223
0.00223
0.00447
0.00000
0.02754
0.12971
0.02754
0.12971
0.31451
PPMV
163
144
153
0
48,026
143,318
48.026
143.318
111,416
-------
30-Apr-»7;flow».wb2
PROCESS
NO. VENT*
Plant 8 (19)
1 PV001
1 PV002
1 PV003
1 PV005
1 PV005
1 PV005
18
MW
HAP
METHANOL
XYLENES
METHANOL
METHANOL
TRICHLOROBENZENE
XYLENES
SCFM
DURATION UNCON LBMOLE/ AVG/ CONTL
HR/YR LB/YR YR MW LB/YR TYPE
LB/MIN
PPMV
32
106
32
7730
1187
1922
7896
7896
7896
8760
8760
8760
113999
238361
72545
3695
95
16268
3.562
2.249
2.267
14.1
29.5
90
1
2280 U
4767 U
1451 U
3695 U
95 C
16268 U
0.24063
0.50313
0.15313
375
1.540
959
average
10839
same
424905
8.078
52.6
0.89688
606
Shaded hours were changed to equal procan operating hours
-------
MIDWEST RESEARCH INSTITUT
Suit* 35
401 Harrison Oaks Boulevaf
Gary. North Carolina 27513-2*1:
Telephone (919) 677-024
FAX (919) 677-006'
Date: June 30, 1997
Subject: Basis for Pollution Prevention Factors for the Production of Pesticide Active
Ingredients NESHAP
EPA Contract No. 68D60012, Task Order 0004
ESD Project No. 93/59; MRI Project No. 4800-04
From: David Randall
To: Lalit Banker
ESD/OCG (MD-13)
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
I. Introduction
The purpose of this memorandum is to describe the basis for pollution prevention (P2)
alternative standards to the MACT standards for process vents, storage tanks, equipment leaks.
and wastewater systems for pesticide active ingredient manufacturing facilities.
II Background
Hazardous air pollutants that are emitted from a PAI process may be solvents, react ants
above the stoichiometric amount needed in a reaction, byproducts generated in a reaction, or the
product of a reaction Solvent and reactant emissions are losses from the process that, together
with losses of the same compounds in wastewater discharge or solid (or hazardous) waste
disposal, can be related to consumption of purchased materials. Reducing solvent and reactant
losses, as tracked by consumption records, forms the basis of pollution prevention alternative
standards.
Losses to wastewater or waste disposal may not be equivalent to HAP emissions from
the PAI process. However, reducing these losses would reduce other emissions For example,
HAP emissions from treatment technologies (e.g., incineration), and emissions from the
generation of energy to operate the treatment technology, would be reduced. The plant
producing the HAP compound would have reduced emissions due to reduced production
Emissions from transportation of the waste for disposal would also be reduced.
-------
ID. Pollution Prevention Standard
Two P2 options were developed, and both options would be applied on a process basis.
A. Option 1
Under option 1, a facility would track HAP material usage and product production rates.
The format of the standard would be the mass of HAP consumed per unh mass of product
produced. This ratio is termed the "HAP factor." Compliance with the process vent, storage
tank, equipment leak, and wastewater MACT standards for a given process would be
demonstrated by showing the annual HAP factor is reduced by 85 percent from a baseline HAP
factor. The 85 percent reduction was developed using the data in Table 1. The second column
shows the nationwide uncontrolled HAP emissions from process vents, equipment leaks, and
storage tanks in the P AI manuftcturing industry; also shown is the nationwide HAP load in
wastewater discharges from PAI processes. The third column shows the emissions and load after
implementation of the MACT standards. The fourth column shows the overall reduction is 88
percent; for the P2 option, this value was rounded to down 85 percent (mis may provide a small
incentive to implement pollution prevention techniques). Note that this is a national average
reduction; for individual facilities (or individual processes) h may resuh in either higher or lower
reductions than would be achieved by the MACT standards, depending on the type of changes the
plant implements and the level of reduction that would have been required under the MACT
standards (le.. some process vent emissions must be reduced 90 percent, and others must be
reduced by 98 percent).
TABLE 1. HAP DISCHARGES FROM THE PAI MANUFACTURING INDUSTRY
1 JT|JC iM UiaUWIg^
r v cHUd^M^jvid
Fjt^ emissions
ST emissions
WWIoad
Totals
U_«..._«_*»n_.i
ncontr oued
discharges. Mg/yr
16,500
3.700
220
6,800
27,200
Discharges after
MACT, Mg/yr
600
390
17
2,310
3.320
Reduction,
l1"***"111
%
89
92
66
88
The IN
SARA/TTUrep
dme year was
would be the first
rtmgraqc
to be 1987 because this was the first year fbr-the
If the process was not operating in 1987, the basehw
ducb
year of operation after 1987. Similarly, if etther consumption or
1987.
which data are available.
To
the
ual HAP factor at r
standard, the faculty would have to
vals. The frequency of the calculation is an
-------
important issue. Continuous compliance would require essentially instantaneous calculations
during process operation, which would be impossible. Daily measurements of consumption and
production would be feasible (most likely using tank level measurements), but die resulting annual
HAP factors for batch processes dial last more dun a day could fluctuate depending on die stage
of die process at die end of die day and die number of days of operation in die past 12 months.
Calculations over a longer term would damp out die fluctuation, but if die term is too long, die
calculation would not serve die purpose of demonstrating compliance on a continuous basis.
Calculations every 10 batches for batch processes and moodily for continuous processes seem Eke
a reasonable compromise. Presumably, each excccdance would be considered a violation of die
standard for however many days had elapsed since die last calculation (Le., 30 violations for a
continuous process, and up to 10 for a batch process—less dian 10 if multiple batches are
conducted per day).
One potential way to reduce die HAP factor would be to replace die HAP with a non-
HAP VOC. However, dns substitution would not be a true P2 measure Therefore, die facility
should also be required to demonstrate that VOC consumption per unit of product remains die
same or is reduced. Therefore, a baseline VOC factor would need to be developed, and an annual
VOC factor would be calculated every time die annual HAP factor is calculated.
The P2 standard could not be used for a HAP that is generated in die process because
there is no usage quantity to track for such a HAP. In addition, compliance with die P2 standard
would not be available for HAP emissions from product dryers because die HAP emissions are die
product, not a material that is consumed. Emissions of diese HAP's would have to be reduced in
accordance widi die MACT standards.
A storage tank or wastewater system dial serves multiple processes would still have to
meet die MACT standards for any processes) not subject to the P2 alternative
B. Option 2
A second option was developed duu would allow a facility to take advantage of both
poDution prevention techniques and add-on controls. Under dus option, die facility would be
required to achieve (1) at least a 50 percent reduction in die annual HAP factor relative to die
basefine HAP factor, (2) emissions reductions diat, when divided by the mass annual production,
yields a value equivalent to at least a 35 percent reduction in die annual HAP factor, and (3) no
increase in die VOC annual factor. Thus, die overall reduction would be equivalent to die 85
percent reduction under opton 1. Note diat no additional credit would be given for exceeding
ehher die 50 or 35 percent requirements.
The calculation frequency of die HAP and VOC annual factors, and die exclusion of
generated HAP, would be die same as under option 1 Demonstrating compliance wid» die 35
percent requirement for add on controb would be achieved using die same strategies as in die
MACT standards The reduction in emissiojts must be accomplished in such a way diat die RAP
is dutiuyed or odierwise pieveitted from being returned to die process, odiemise die emission
reduction would abo be counted as a reduction in consumption in die annual HAP factor
-------
MIDWEST RESEARCH INSTITUTE
Suite 350
401 Hamson Oaks Boulevard
Gary. North Carolina 27513-2412
Telephone (919) 677-0249
FAX (919) 677-0065
Date: June 30, 1997
Subject: Basis for Applicability Cutoff Equation for Process Vents Under Regulatory
Alternative No. 1-Pesticide Active Ingredient Production NESHAP
EPA Contract No. 68D60012; Task Order No. 0004
ESD Project No. 93/59; MRI Project No. 4800-04
From David Randall
To: Lalit Banker
ESD/OCG(MD-13)
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
I Introduction
A regulatory alternative more stringent than the MACT floor was developed that would
require 98 percent control of organic HAP emissions from certain large process vent emission
streams This memorandum describes the procedure used to develop an equation to determine
which process vent emission streams would be subject to the 98 percent control requirement The
resulting equation is also presented, and an estimate of the number of processes at the surveyed
and modelled plants that would meet the requirement for 98 percent control is developed
II. Development of the Applicability Cutoff Equation
The methodology used to develop the equation is the same as that described in the
Alternative Control Techniques Document for Batch Processes. This methodology also was
used to develop an equation for the Pharmaceuticals NESHAP. Because the equation for a
given pollutant should be the same regardless of the type of process causing the emission, the
equation developed for the Pharmaceuticals NESHAP is also applicable to the PAI NESHAP.
The remainder of this section summarizes the methodology used to develop the equation.
Variables that affect control costs are the type of control device, the type of pollutant,
the pollutant concentration, the vent stream flow rate, and the operating hours The
concentration, flow rate, and operating hours define the annual mass emissions rate; this analysis
uses the mass emissions rate as a variable instead of the the operating hours. The first step in the
methodology was to select a representative pollutant for analysis. Methanol was selected as
representative because it is a common pollutant from pharmaceutical processes (it is also emitted
from many PAI processes), and it has a moderate volatility. The second step was to develop a
-------
series of four graphs showing the relationship between cost effectiveness and flow rate for
different mass emission rates, concentrations, and control devices. Each graph (shown in
reference 1) was developed at a different annual mass emission rate (75,000,100,000, 125,000,
and 150,000 Ib/yr). On each graph, separate curves were developed, each representing 98 percent
control with either a condenser or an incinerator. Condensers tend to be less costly for
concentrated streams, and incinerators tend to be the least costly for dilute streams. Therefore, a
curve at saturated conditions (164,000 ppm) was developed for a condenser, a curve at a dilute
concentration (1,000 ppm) was developed for an incinerator, and curves were developed for both
an incinerator and a condenser at an intermediate concentration (10,000 ppm), because either
device might be least costly. Taken together, the four curves represent the least costly means of
control over a range of operating conditions. The third step was to define a target cost
effectiveness cutoff; $3,500/Mg was judged to be acceptable based on decisions for previously
promulgated Pan 63 rules for sources with organic HAP emissions. Therefore, the midpoint of
the range of flowrates at S3,500/Mg on each of the four graphs was identified and used in a plot
of flow rate versus annual emission rate The final step was to develop the equation of a line
through these four points using linear regression. The resulting equation is as follows:
Flow, scfrn = (0.02 * Mass emissions, Ib/yr) -1,000
To use this equation, the annual emissions from a process vent are inserted and a flow
rate is calculated. If the calculated flow rate is higher than the actual flow rate, the vent stream
would be subject to the 98 percent control requirement because control would cost less than
S3,500/Mg. Conversely, if the calculated flow rate is lower than the actual flow rate, the cost to
control the vent stream would exceed $3,500/Mg, and the vent stream would not be subject to the
98 percent control requirement. Further examination of the equation shows the calculated flow
will be lower than the actual flow for any vent stream with a mass emission load less than
50,000 Ib/yr.
II. Estimated Number of Streams Subject to 98 Percent Control
The number of processes at the surveyed plants that meet the criteria for 98 percent
control was estimated based on process and control data presented in Table 1; these data were
extracted from two previous project memoranda. ' The first step was to eliminate all processes
with total organic HAP emissions less than 22.7 Mg/yr (50,000 Ib/yr). The second step was to
eliminate all of the remaining processes that are controlled to 90 percent or better (because the
control of these streams would not need to be increased). This left five batch processes (15, 67,
68, 93, and 94) and two continuous processes (1 and 27) to check using the applicability cutoff
equation. Flow rate data were available for all seven processes. Because some of these data were
for manifolded streams (rather than for individual vents from unit operations), a simplifying
assumption was to use the average aggregated process flow rates that were developed for a
previous modelling analysis.4 Three of the seven processes (15,27, and 67) meet the criteria for
98 percent control. (Note that if the reported data for manifolded and individual vents were used,
only one additional process would meet the criteria for 98 percent control).
-------
TABLE 1. PROCESS VENTS FOR SURVEYED PROCESSES THAT MEET APPLICABILITY CUTOFF FOR 96 PERCENT
CONTROL UNDER REGULATORY ALTERNATIVE NO 1
PfDMM
Piant ProcM* op*ntmg
no. no hr\r
S&tch prooBMM
IS 57 3.060
11 38 7.776
21 70 127
IS . SB 5220
3 12 4.178
21 71 148
21 72 IN
21 73 189
14 46 266
22 81 300
8 22 2.208
IS 54 5.784
14 43 792
14 44 age
14 47 S76
14 4S 840
22 77 1.184
22 76 1.778
21 69 570
6 16 4.404
22 78 1.036
12 38 1 170
21 66 4.0S6
7 17 6.072
10 64 8318
22 65 1.S42
20 66 840
22 84 2496
23 90 1 340
23 69 2320
17 60 1 548
23 92 360
3 7 8160
22 83 1 946
23 93 4150
S IS 6039
22 62 8 780
8 20 2208
3 11 6^60
12 37 1386
21 67 8 400
12 40 1568
23 94 4370
22 79 432
22 7S 4500
9 24 5568
Uncontrolled em*eione Mg/yr
Chlorinated Unehtor-
organic* mated Total
0 0.276 0.278
0 0399 0399
0 0447 0.447
0 0679 0679
0 0782 0782
0 0820 0620
0 0657 06S7
0 0869 0969
0 00 0996
0 .38 38
0 41 41
0 59 59
0 74 74
0 76 78
0 228 228
0 319 319
0 4S4 4S4
0 4S4 454
0 581 561
0 165 16 S
0 236 236
0 24 3 24 3
0 285 285
0 330 330
0 34 3 34 3
0 667 667
0 61 8 61 8
0 963 963
000771 0198 0205
00132 0342 035S
0 337 0 0 337
0 488 1 39 1 66
0693 0 0693
22 7 6 27 29 0
401 186 SB7
426 90S 519
454 122 576
00454 152 153
0 0403 0403
0 4 59 4 59
0 129 129
328 IS 4 432
26 S 38 5 65 0
830 0 830
531 0 531
0 0 0000
Control wd
•ffiMcront.
Mg/yr
0276
0006
006S
0679
0078
0119
0125
0141
0020
0028
0141
1 587
0034
0035
0046
0064
0091
0091
0936
165
0475
0504
4 14
0660
0171
1 33
0607
193
0062
0107
0007
0036
0693
0579
135
51 9
1 15
1 S3
0000
0092
635
3 11
152
0166
106
0000
Control
eff %
00
980
855
00
900
855
855
855
960
960
900
00
980
960
980
960
980
980
839
900
960
979
855
980
995
980
990
960
700
700
960
960
00
960
769
00
960
900
999
960
506
935
767
960
960
Avg
Flew.
adm
1.050
0145
1.030
1.010
1.010
1080
95
1 993
1.080
20
506
1 400
1.400
0962
270
80
6684
237
00253
76
3816
63
6664
toad>
cutoH(y/n)
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
yM
yM
yM
yM
yM
yM
yM
yM
n
n
n
n
n
yw
yM
yM
»•»
n
n
n
yM
yM
yM
n
y*s
n
Control < 90
percent (y/n)
VM
n
yM
fM
n
»••
y~
»••
n
n
n
yM
n
n
n
n
n
n
yM
n
n
n
yee
n
n
n
n
n
yM
yM
n
n
»•*
n
yM
yM
n
n
n
n
yM
n
yM
n
n
»•»
flow>actuaJ
flow(y n N/A)(b)
NiA
N.'A
N A
MA
NA
N A
NA
NA
N'A
N.'A
N A
NA
N'A
NA
NA
N A
NA
N A
N A
NA
N.A
N.A
no
NA
NA
NA
NA
N A
NA
N A
N A
N A
N A
N A
ne
yM
N A
N A
N A
K A
y«
K A
no
S A
S A
Ki A
(a) i ne appncaMny equation « amamm in tection II ol tlw memorandum
(b) *N/A* meant the (low was not calculated became the load wei below the ippUcatntffy thrMhold of 22 68 Mgiyr (SO 000 ib/yr) or the control
effoency • greater than 90 percent 'No' mean* the calculated (lew rale * lower tnan the actual flow rete
and *yer meani the actual flow rale u lower than the calculated (low rale
-------
TABLE 1. PROCESS VENTS FOR SURVEYED PROCESSES TtttT MEET APPUCABUTY CUTOFF FOR 98 PERCENT
.UNDER REGULATORY ALTERNATIVE Ma
fr.il MM) IW
17
17
17
1
1
1
7
14
2
4
s
10
1J
24
0
0
0
0
o
osi6
15.3
S50
SJOO
SJMO
1 11
12JO
tas
0010
101
153
ao
so
105
1U
ia
00X72
OJBB3
0104
07 JO
ou
900
01O
974
aa
114
110
TOO
414
414
00
41S
1XSO
e.7
ao
74JOD
74JDD
74JOD
1S2SD
74500
MM
MM
MM
MM
10
a
11
«
o
33
12
9
22
27
•
a
a
19
91
7.170
7 JOBS
7000
5104
313
ao
903
0
OOOl
402
199
347
0
0
44
0
0
0
0
0
31J
ao
•47
00
9«7
ao
20
525
00
139
50
0364
• 94
as
•60
919
ao
057
970
ao
ao
141
179
MM
MM
MM
MM
MM
MA
-------
The approach to estimate how many of the 93 projected processes at the 58 modelled
plants that would meet the criteria for 98 percent control was estimated by extrapolating from the
data, for surveyed processes; the data and results are shown in Table 2. The surveyed processes
are organized into four groups in Table 2, each group containing processes that were used to
establish the characterisics of one of the four model processes Of the 33 surveyed processes used
to characterize model 1, 8 have annual mass emissions above 50,000 Ib/yr. Flow rates are
available for four of these eight processes, and two of the four would meet the criteria for 98
percent control. Therefore, it was assumed that 12 percent of the 48 projected processes (i e. 6
processes) represented by model 1 would meet the criteria for 98 percent control (8/33 * 2/4 * 48
=6). Similar procedures were used to estimate the number of projected processes represented by
models 2,3. and 4 that would meet the criteria for 98 percent control. The data and results are
shown in Table 3.
The final step in the analysis for the projected processes was to estimate whether the
vent stream is concentrated or dilute These estimates were based on the ratio of concentrated to
dilute surveyed processes that meet the criteria for 98 percent control For example, surveyed
processes 15,40. and 67 are the only processes used to characterize model number 2 that also
meet the criteria for 98 percent control Two of these processes have concentrated vent streams.
and one has a dilute vent stream. Therefore, approximately two-thirds, or five, of the seven
projected processes represented by model number 2 were assumed to have concentrated vent
streams, and one-third, or two, of the seven were assumed to have dilute vent streams Similar
procedures were used to estimate the dilute and concentrated vent streams for the other projected
processes, and the results are shown in Table 4.
-------
TABLE 2. PROCESS VENTS FOR MODELLED PROCESSES THAT MEET APPLICABILITY CUTOFF FOR 98 PERCENT
CONTROL UNDER REGULATORY ALTERNATIVE NO. 1
Process
Plant Process operating
no. no. hrtyr
Batch processes
15 57 3.960
11 36 7.778
21- 70 127
15 58 5.220
3 12 4.176
21 71 148
21 72 169
21 73 189
14 46 288
22 81 300
8 22 2.208
15 54 5.784
14 43 792
14 44 696
14 47 576
14 45 840
22 77 1.184
22 76 1.776
21 69 570
6 16 4.404
22 78 1.036
12 38 1.170
21 68 4.056
7 17 6.072
19 64 6.318
22 85 1.542
20 66 840
22 84 2.496
23 90 1.340
23 89 2.320
17 60 1.548
23 92 360
3 7 8.160
22 83 1.946
23 93 4 150
5 15 6.039
22 82 8.760
8 20 2.208
3 11 8.160
12 37 1.368
21 67 8.400
12 40 1.568
23 94 4.370
22 79 432
22 75 4.500
9 24 5.568
UnoontoVed emastans. Mo/Vr
Chlorinated UncNor-
organfcs inated HCI/CI2 Total
0 0276 0 0.276
0 0399 0 0399
0 0.447 0 0.447
0 0.679 0 0679
0 0.782 0 0.782
0 0.820 0 0.820
0 0.857 0 0.857
0 0.969 0 0.969
0 1.00 0 1.00
0 1.38 0 1.38
0 1.41 (a) 1.41
0 1.59 0.157 1.74
0 174 0 1.74
0 1 76 0 1 76
0 228 0 2.28
0 319 0 3.19
0 454 0 454
0 4.54 0 454
0 581 0 581
0 16.5 0 16.5
0 23.8 0 238
0 243 0.00014 32.0
0 285 0 285
0 330 0 33.0
0 343 0 343
0 66.7 0 667
0 81.8 0 818
0 96.3 0.101 96.4
000771 0.198 0.410 0616
00132 0342 0.710 1.07
0.337 0 0 0337
0486 139 000064 188
0.693 0 0 0.693
227 627 0 289
40.1 186 0557 592
428 905 0 519
45.4 122 0 575
0.0454 15.2 680 221
0 0.403 900 941
0 459 110 156
0 129 12.0 141
32.8 15.4 267 749
265 385 33.1 981
8.30 0 54.4 628
531 0 349 402
0 0 356 356
Avg.
Flow.
scftn
1.050
0145
1.030
1.010
1.010
1.080
9.5
1.993
1.080
20
508
1.400
1.400
0962
270
80
6884
237
00253
76
3.818
6.3
6.884
°* 1 Ant
k>ad>
cutoff (y/n)
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
yes
yes
yes
yes
yes
yes
yes
yes
n
n
n
n
n
yes
yes
yes
yes
n
n
n
yes
y«
yes
n
yes
n
ic cutoff en. (bl
flow > actual
ftow(y.n.N/A)(c)
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
unknown
no
no
yes
unknown
unknown
yes
unknown
N/A
N/A
N/A
N/A
N/A
unknown
no
yes
unknown
N/A
N/A
N/A
yes
yes
no
N/A
unknown
N/A
(a) No data provided.
(b) The applicability equaion • discussed in section II of VMS memorandum
(c) -N/A- means the flow was not cafcutatod because the load was below the applicability threshold of 22.68 Mg/yr (50.000 Ib/yr).
•Unknown* means the actual flow rate was not reported
•No* means the calculated flow rate is tower than the actual flow rate, and *yW means to actual flow rate is lower ftan the calculated
low rale
-------
TABLE 2 PROCESS VENTS FOR MODELLED PROCESSES THAT MEET APPLICABILITY CUTOFF FOR 98 PERCENT
CONTROL UNDER REGULATORY ALTERNATIVE NO. 1 (continued)
Process
Plant Process operating
no no. hrfyr
Continuous processes
5 14 7.464
22 80 456
17 61 1.920
17 62 2.424
17 63 8.064
1 2 336
1 4 720
1 3 720
7 18 5.300
1 1 5.040
10 27 7,680
3 6 8.136
11 33 7.176
8 23 7.896
8 19 7.896
23 91 7.488
12 39 7.000
9 25 3,384
22 74 5.184
Uncontrolled emissions. Mgtyr
ChJorfnatsd Unchtor-
organlcs Inated HCVCI2 Total
0 0.916 0 0.916
0 1.81 0 1.81
0 8.19 0 8.19
0 153 0 15.3
0 200 0 200
0.0459 5.59 0.0262 566
0.0751 9.14 0.0428 926
0.158 193 0.0904 195
0.181 12.6 0 12.8
1.11 135 0.633 137
313 0 0 327
509 0 0 509
603 44 0761 65.5
0 0 145 14.5
00431 202 132 215
4.02 0 117 121
199 0 672 266
18.2 0 174 192
347 0 2,360 2.707
Avg
Flow.
scfm
1250
67
360
486
74.500
74.500
74.500
15.250
74.500
141
179
10.800
4.900
122
1.8
RAIAmhe cutoff oofbl
load>
cutoff (y/n)
n
n
n
n
yes
n
n
n
n
yes
yes
yes
yes
n
yes
n
yes
n
yes
flow>acttjal
now (y. n. N/A) (c)
N/A
N/A
N/A
N/A
y"
N/A
N/A
N/A
N/A
no
yes
yes
unknown
N/A
no
N/A
yes
N/A
unknown
(a) No data provided
(b) The applicability equation is discussed In section II of Bus memorandum.
(c) 'N/A* means the now was not calculated because the toad was below (he applicability threshold of 22 68 Mgtyr (50.000 Ib/yr)
*Unhnown* means the actual How rate was not reported
'No' means the calculated flow rate is lower than the actual flow rate, and "yes" means the actual flow rate is lower than the calculated
flow rate
-------
8
TABLE 3. PROJECTED PROCESSES THAT WOULD MEET CRITERIA FOR 98
PERCENT CONTROL
Model
process
1
2
3
4
Population
of model
processes
nationwide5
48
19
14
12
Surveyed processes used to characterize
the model processes
Total
number5
33
13
10
9
Organic HAP
emissions
>50,000 Ib/yr5
8
8
2
6
Number
with flow
data6
4
5
2
4
Number
that meet
criteria for
98 percent
control
2a
3"
lc
3"
Estimated
number of
projected
processes
that meet
criteria for
98 percent
control
6
.7
1
6
processes 17 and 66
"processes 15, 40, and 67
Srocess 63
Processes 6, 27, and 39
TABLE 4. DILUTE AND CONCENTRATED STREAMS FOR PROCESSES THAT MEET
CRITERIA FOR 98 PERCENT CONTROL
Model
process
1
2
3
4
Surveyed processes that meet criteria
for 98 percent control8
Total
number
2
3
1
3
Concentrated
processes
17 and 66
IS and 40
63
39
Dilute
processes
none
67
none
6 and 27
Estimated number of projected processes
that meet criteria for 98 percent control
Concentrated
processes
6
5
1
2
Dilute
processes
0
2
0
4
Total
number
6
7
1
6
aSeeTable2.
-------
ffl. References
1. Control of VOC Emissions From Batch Processes-Alternative Control Techniques
Document. EPA 453/R-94-020. February 1994
2. C. Hale, MRJ, to Pharmaceuticals NESHAP Project File. March 26, 1996. 98 Percent
TRE for Single Process Vents.
3. D. Randall and K. Schmidtke, MRI, to L. Banker, EPA:ESD. April 15, 1997. Summary
of Data from Responses to Information Collection Requests and Site Visits for the
Production of Pesticide Active Ingredients NESHAP.
4. D. Randall, MRI, to L. Banker, EPA:ESD. April 30, 1997 Procedures to Estimate
Characteristics and Population of Dilute and Concentrated Streams for Model Processes
5. D. Randall, MRI, to L. Banker, EPA:ESD. April 30, 1997. Model Plants for the
Pesticide Active Ingredient Manufacturing Industry.
6. D Randall, MRI, to L. Banker, EPA.ESD. June 30, 1997 Procedures to Estimate
Characteristics and Population of Dilute and Concentrated Streams for Model Processes.
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