HAZARDOUS ORGANIC NATIONAL EMISSION STANDARD
FOR HAZARDOUS AIR POLLUTANTS
SUPPLEMENTAL GUIDANCE DOCUMENT
Emission Standards Division
U.S. Environmental Protection Agency
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
January 1993
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TABLE OF CONTENTS
Page
1.0 INTRODUCTION 1-1
2.0 SUMMARY OF THE HON 2-1
2.1 Overall HON Structure 2-2
2.2 Summary of Applicability 2-7
2.3 Summary of Provisions for Process Vents 2-17
2.4 Summary of Provisions for Storage Vessels . . . 2-25
2.5 Summary of Provisions for Transfer Operations . . 2-35
2.6 Summary of Provisions for Wastewater Operations . 2-43
2.7 Summary of Emissions Averaging 2-61
2.8 Summary of Recordkeeping and Reporting 2-67
2.9 Summary of Continuous Parameter Monitoring . . . 2-77
2.10 Summary of Equipment Leaks Provisions 2-79
3.0 CASE STUDIES 3-1
3.1 The Facility 3-1
3.2 Reference Control Case Study 3-4
3.3 Emissions Averaging Case Study 3-22
4.0 ADDITIONAL WASTEWATER CASE STUDY 4-1
4.1 Biological Treatment Unit Option 4-1
4.2 Process Unit Alternative Treatment Option .... 4-10
5.0 LIST OF FACILITIES USED IN THE HON IMPACTS ANALYSIS . . 5-1
6.0 OAQPS CONTACTS 6-1
APPENDIX A: OAQPS BULLETIN BOARD SYSTEM: WATER7 A-l
APPENDIX B: TRE INDEX B-l
APPENDIX C: TERMS IN THE CREDIT EQUATION C-l
APPENDIX D: ALLOWED EMISSIONS FROM PROCESS VENTS D-l
APPENDIX E: TERMS IN THE DEBIT EQUATION E-l
APPENDIX F: ACTUAL EMISSIONS FROM STORAGE VESSELS AND
TRANSFER RACKS F-l
11
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LIST OF TABLES
Page
2-1 Reference Control Technologies 2-4
^
2-2 Phased Approach for Pump and Valve Standards 2-82
3-1 General Chemical Processes and Primary Products . . . .3-3
3-2 General Chemical Process Vent Information 3-6
3-3 Emissions from Process Vents 3-9
3-4 General Chemical Storage Vessel Information 3-10
3-5 Emissions from Storage Vessels 3-14
3-6 General Chemical Transfer Rack Information 3-15
3-7 Emissions from Transfer Racks 3-17
3-8 General Chemical Wastewater Stream Parameters .... 3-18
3-9 Emissions from Wastewater Streams 3-21
3-10 Baseline Emissions and Emissions After Control for
General Chemical 3-24
3-11 Credit Calculation 3-30
3-12 Debit Calculation 3-34
3-13 Baseline Emissions and Emissions After Control Under the
Emissions Averaging Scenario for General Chemical . . 3-35
4-1 Wastewater Stream Characteristics for Process
Units A and C 4-5
4-2 Wastewater Stream Characteristics for Process
Units A and C for Calculating Actual Mass Removal (MR) . 4-7
4-3 Process Unit B Stream Characteristics 4-11
111
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LIST OF FIGURES
Page
2-1 Applicability of the HON 2-8
2-2 Applicability of the HON (continued) 2-9
2-3 Applicability for Process Vents 2-20
2-4 Group I/Group 2 Determination for Process Vents . . . 2-21
2-5 Compliance Options for Process Vents 2-23
2-6 Applicability for Storage Vessels 2-28
2-7 Group 1 and Group 2 Determination for Storage Vessels
at New Sources 2-29
2-8 Group 1 and Group 2 Determination for Storage Vessels
at Existing Sources 2-30
2-9 Compliance Options for Group 1 Storage Vessels .... 2-31
2-10 Applicability for Transfer Racks 2-37
2-11 Group 1 and Group 2 Determination for Transfer Racks . 2-38
2-12 Compliance Options for Transfer Racks 2-40
2-13 Overview of HON Wastewater Provisions 2-49
2-14 HON Wastewater Determination 2-50
2-15 Group 1 and Group 2 Determination for Wastewater Streams -
Table 8 HAP ' s 2-51
2-16 Group 1 and Group 2 Determination for Wastewater Streams -
Table 9 HAP ' s 2-52
2-17 Compliance Options for Control of Table 8 HAP's . . . 2-55
2-18 Compliance Options for Control of Table 9 HAP's . . . 2-56
2-19 Process Unit Alternative Compliance Option 2-57
2-20 Compliance Options for Control of Residuals 2-58
2-21 Emissions Averaging Applicability 2-62
IV
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LIST OF FIGURES (Continued)
Page
2-22 Reporting and Recordkeeping Schedule for Subpart G
Requirements for New Sources 2-68
2-23 Reporting and Recordkeeping Schedule for Subpart G
Requirements for Existing Sources 2-69
4-1 XYZ Chemical Company Schematic 4-2
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ACRONYM LIST
BID - Background Information Document
Btu - British thermal units
CAA - Clean Air Act as amended in 1990
CEM - Continuous Emission Monitor
CFR - Code of Federal Regulations
dscm - dry standard cubic meter
EPA - Environmental Protection Agency
g - gram
gal - gallon
gpm - gallons per minute
HAP - Hazardous Air Pollutant
HON - Hazardous Organic National Emission Standard for
Hazardous Air Pollutants
hr - hour
kg - kilogram
kPa - kilopascal
£ - liter
Ib - pound
LDAR - leak detection and repair
£pm - liter per minute
m - meter
Mg - megagram
mg - milligrams
min - minute
MMscf - Million standard cubic feet
MR - Actual Mass Removal
NESHAP - National Emission Standard for Hazardous Air Pollutants
vi
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OAQPS - Office of Air Quality Planning and Standards
ppmv - parts per million by volume
ppmw - parts per million by weight
psia - pounds per square inch absolute
QIP - Quality Improvement Program
RCT - Reference Control Technology
RMR - Required Mass Removal
scfm - standard cubic feet per minute
scmm - standard cubic meters per minute
SOCMI - Synthetic Organic Chemical Manufacturing Industry
TOC - Total Organic Compound
tpy - tons per year
TRE - Total Resource Effectiveness
VHAP - Volatile Hazardous Air Pollutant
VOC - Volatile Organic Compound
VOHAP - Volatile Organic Hazardous Air Pollutant
yr - year
VII
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Metric-to-English Conversions
for Group I/Group 2 Status Determination
Storage
38 m3 = 10,040 gal
75 m3 = 20,000 gal
151 m3 = 40,000 gal
0.7 kPa =0.1 psia
5.2 kPa = 0.75 psia
13.1 kPa = 1.9 psia
Transfer
6.5 x 105 £/yr = 172,000 gal/yr
10.3 kPa = 1.5 psia
204.9 kPa = 29.7 psia
Process Vents
0.005 scmm =0.18 scfm
0.5 mg/dscm = 0.031 Ib/MMscf
Wastewater
0.02 £pm = 0.005 gpm
10 £pm = 2.6 gpm
Vlll
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1;0 INTRODUCTION
In December 1992, the EPA proposed the National Emission
Standard for Hazardous Air Pollutants for Source Categories:
Organic Hazardous Air Pollutants from the Synthetic Organic
Chemical Manufacturing Industry and Equipment Leaks from Seven
Other Processes, commonly referred to as the HON. The HON covers
new and existing sources in the SOCMI and seven non-SOCMI
processes. The proposed regulation is contained in three
subparts of 40 CFR Part 63: Subpart F (general applicability);
Subpart G (provisions for process vents, transfer, storage,
wastewater, emissions averaging and general recordkeeping and
reporting); and Subpart H (equipment leaks negotiated rule).
Subpart G regulates 112 HAP's, and Subpart H regulates 149 HAP's.
The HON is the first major standard being proposed to meet
the statutory requirements of Section 112 of the CAA. The
proposed rule is expected to result in more emissions reduction
than any other single standard that will be issued under
Section 112 of the CAA. It is anticipated that the proposed
standard will reduce HAP emissions from approximately 370 plant
sites by an overall 80 percent, which is equivalent to
approximately 475,000 Mg/yr (522,500 tpy). An added benefit is
that emissions of VOC's would be reduced by 71 percent, which is
equivalent to approximately 986,000 Mg/yr (1,085,000 tpy).
The purpose of this document is to provide the reader with a
better understanding of the provisions in Subparts F and G for
applicability, process vents, storage vessels, transfer
operations, wastewater operations, emissions averaging, and
general reporting and recordkeeping. Key points of these
subparts are summarized, and flow diagrams and example case
studies are used to clarify the provisions and provide
supplementary information. A brief summary of Subpart H is also
included.
This document describes the HON proposal. Some aspects of
the HON may change between proposal and promulgation because of
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public comment. Thus, this document should be used in early
planning for compliance and in understanding the proposed rule &s
a basis for informed public comment. However, because there may
be changes to the HON between proposal and promulgation, the
reader is advised to review the final standard and accompanying
enabling materials when they become available.
This document is organized into six chapters. Chapter 2
provides a summary, including flow diagrams of the different
'provisions of the regulation: applicability, process vents,
storage vessels, transfer operations, wastewater operations,
emissions averaging, general reporting and recordkeeping, and
equipment leaks. Chapter 3 presents two case studies. The first
case study illustrates a source using a reference control
technology on each kind of emission point to comply with the HON.
The second case study presents the same source using emissions
averaging for a subset of emission points. Chapter 4 presents an
additional wastewater case study to illustrate additional options
for compliance. The first portion of the wastewater case study
presents the option of using a biological treatment unit, and the
second illustrates the process unit alternative allowed under the
HON wastewater provisions. Chapter 5 lists the facilities in the
HON data base which was used in the analysis of national impacts,
and Chapter 6 lists the technical and regulatory contacts at the
EPA's OAQPS and their telephone numbers.
As previously stated, this document is intended as an aid to
understanding the proposed rule. The actual applicability and
control requirements will be specified in the final rule.
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2.0 SUMMARY OF THE HON
This chapter presents an introduction to the structure and
content of the HON. Section 2.1 presents an overview of the
structure of the rule. Section 2.2 presents a summary of the
Subpart F provisions. Sections 2.3 through 2.9 summarize the
provisions of Subpart G. Section 2.10 presents a summary of
Subpart H.
More specifically, Sections 2.3 through 2.6 present detailed
discussions of the applicability, compliance options, and
specific monitoring, recordkeeping and reporting requirements for
process vents, storage vessels, transfer operations, and
wastewater operations, respectively. Section 2.7 summarizes the
emissions averaging provisions and Section 2.8 summarizes the
general recordkeeping and reporting provisions. Section 2.9
summarizes the requirements for continuous monitoring of
parameters associated with control and recovery devices.
Section 2.10 summarizes Subpart H, the negotiated rule for
equipment leaks.
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2.1 OVERALL HON STRUCTURE
The HON comprises three subparts of 40 CFR Part. 63: F, G,
and H. Subpart F specifies general applicability of the HON.
Subpart G specifies for process vents, storage vessels, transfer
operations, and wastewater operations: specific applicability
criteria; compliance options; and monitoring, recordJceeping and
reporting requirements. Subpart G also specifies the HON's
emissions averaging provisions. Subpart H specifies the standard
for equipment leaks. These three subparts to the HON are
outlined in this section.
2.1.1. Subpart P - General Applicability
Subpart F specifies the general criteria for determining
applicability of the HON. These criteria include the following:
(1) the source must be a major source, based on a maximum
potential to emit HAP's of 10 tpy of a single HAP or 25 tpy of
total HAP's; (2) the source must produce at least one of the
chemicals on a list of 396 chemicals considered "SOCMI
chemicals;" and (3) the source must use as a reactant or produce
as a product, by-product, or co-product at least one of the
organic HAP's regulated by Subpart G (Table 1 of Subpart F) or by
Subpart H (§63.184). Subpart F also specifies seven non-SOCMI
processes subject to the equipment leaks standard in Subpart H,
and defines what it means to produce a chemical.
2.1.2 Subpart G - Provisions for Process Vents. Storage
Vessels. Transfer Operations, and Process Wastevater
Operations
For those SOCMI sources that meet the applicability criteria
in Subpart F, Subpart G specifies a method for determining how
much emission reduction must be achieved for process vents,
storage vessels, transfer operations, and process wastewater
operations. The method is expressed in terms of an equation.
The required reduction is determined by the reductions that would
be achieved by applying the reference controls to each emission
point that meets the HON's criteria for control. The HON
includes two general approaches for compliance. The first
approach, "point-by-point compliance" involves applying controls
to all emission points that meet the applicability criteria for
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control. The second approach is emissions averaging, which
allows a source to "under-control" or not control some points
that meet the applicability criteria, but requires the source to
offset the resulting extra emissions by "over-controlling"
another point or points.
For each kind of emission point, Subpart G establishes
criteria for determining which points are subject to control.
Those points that meet the applicability criteria are called
Group 1 points, and those points that do not meet the criteria
are called Group 2 points. For each kind of emission point, the
HON specifies at least one control device or practice as the RCT.
Table 2-1 gives the RCT for each kind of emission point. If a
source opts for the first compliance approach, the RCT must be
applied to each Group 1 point to achieve requirements specified
in the standard, and no control would be required for the Group 2
points. However, because the format of the standard for each
kind of emission point is a percent reduction or emission limit,
non-RCT control techniques can also be used if they provide
equivalent control.
With the second general approach for compliance with the
HON, the source would meet the HON's allowable emission level
through emissions averaging. Emissions averaging may be used
across any or all emission points in the source that are subject
to the HON. This alternative approach allows compliance to be
achieved by applying controls on some.Group 2 emission points or
by "over-controlling" a Group l emission point instead of
applying controls to all Group 1 emission points. Emissions
averaging allows the source to use the most cost-effective, site-
specific controls while achieving approximately equivalent
emissions reductions to point-by-point compliance.
Subpart G includes monitoring requirements for each kind of
emission point. The primary monitoring requirements are related
to the demonstration of on-going compliance with the operating
conditions for control devices. Parameter monitoring is used to
demonstrate proper operation of control devices. Subpart G
specifies monitoring parameters for each RCT but allows sources
to use alternative parameters upon approval from the permitting
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TABLE 2-1. REFERENCE CONTROL TECHNOLOGIES
Kind of Emission
Point
Reference Control Technology
Reference Control
Efficiency
Process vents
Transfer
Storage
Combustion device
Combustion device, recovery device, or
vapor balancing system
Internal floating roof, external
floating roof, or closed vent system
with control device
98% reduction or outlet <20
ppmv
98% reduction or outlet <20
ppmv
95% reduction
Process Wastewater 3 Components:
(1) covers or closed vent systems on
tanks, separators, impoundments,
drains, treatment systems, etc;
(2) design steam stripper or
equivalent.; and
(3) control device for all vapor
streams from closed vent systems
and strippers.
Level of reduction achieved
by design steam stripper
(varies by chemical) and
95% reduction for vapor
streams
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authority. Sources are required to establish a site-specific
range for each monitored parameter. These parameter ranges are
used to certify compliance with operating conditions. Daily
average values are calculated from the continuous records (i.e.,
every 15 minutes). The proposal allows each control device three
to six "excused" days per semi-annual reporting period. (A
single number of excused days will be selected for promulgation.)
If an emission point has more than the excused number of daily
average values outside the specified range, that control device
is considered in violation of its operating conditions.
Subpart G establishes recordkeeping and reporting
requirements for the four kinds of emission points. The
following types of reports are required: (1) an Initial
Notification, which notifies the permitting authority that the
source is subject to the HON; (2) an Implementation Plan, which
describes how a source plans to comply in the case that an
operating permit application has not yet been submitted; (3) a
Notification of Compliance Status, which demonstrates that
compliance with all control and monitoring requirements has been
achieved; (4) Periodic Reports, generally on a semiannual basis,
which demonstrate ongoing compliance with control and monitoring
requirements; and (5) other reports, generally on a sporadic
basis, most of which describe specific events that may result in
unanticipated emissions. The records needed to prepare each of
these reports must be maintained and kept readily accessible for
five years.
Subpart G also establishes a mechanism by which sources can
request a 1-year compliance extension, as provided by
Section 112(i) of the CAA. This request for an extension may be
submitted with the Initial Notification or at anytime prior to
the submittal of the Implementation Plan.
2.1.3 Subpart H - Provisions for Equipment Leaks
Subpart H specifies the standard for equipment leaks, which
applies to SOCMI and the seven non-SOCMI processes specified in
Subpart F. Subpart H was developed through regulatory
negotiation among representatives from petroleum, chemical, and
pharmaceutical industries; State and local agencies;
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environmental groups; and the EPA. The negotiation was completed
in November 1990. The negotiating committee agreed on a
combination of equipment and work practice requirements which are
based on a pre-existing equipment leak standard (i.e., Subpart V,
40 CFR 61, National Emission Standard for Equipment Leaks).
Subpart H categorizes chemical production processes into five
groups and allows staggered implementation according to groups.
The first group must be in compliance by six months after the
final standard is issued, and the last group must be in
compliance by eighteen months after the final standard is issued.
Subpart H also includes incentives for good performance.
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2.2 SUMMARY OF APPLICABILITY
This fact sheet summarizes the provisions for establishing
the applicability of the proposed HON. Figures 2-1 and 2-2
illustrate the applicability provisions of the HON.
2.2.1 General
In order for the HON to apply to processes at a plant
site three conditions must be met:
The plant site must be a major source;
The plant site must have SOCMI processes, or one
of the 7 non-SOCMI processes subject only to the
equipment leak provisions; and
The SOCMI processes must emit organic HAP's (the
7 non-SOCMI processes must emit at least one of
the designated HAP's).
2.2.2 Ma-jor Source
The HON is applicable to emission points which are part
of major sources as defined in Section 112(b) of the
CAA. Major sources emit, or have the potential to emit
considering controls, at least:
10 tons per year of any individual HAP; or
25 tons per year of a combination of HAP's.
All emission points located at the same plant site are
considered in determining whether a plant site is a
major source. A plant site means all contiguous or
adjoining property that is under common ownership or
control.
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Sum emissions from all operations
at the plant site
Do total
emissions exceed
10 tons/year of any
individual HAP or 25 tons/year
of any combination of
HAP's
Not a major
source -
plant site is
not subject
to this rule
List the intended products for each
CMP (design capacity mass basis)
For the
products identified,
is one cleariy the
primary intended product
or purpose
of the CMP?
Is only
one intended
product Identified
as predominant?
(e.g., >50% if
2 products)
Proceed
to
Rgure 1b
CMP is identified by this primary
product
Is
the product
listed in
§63.105?
Does
the CMP use
as a reactarrt or
manufacture as a product,
by-product or co-product one
or more of the organic HAP's
listed in §63.104
9
CMP
is subject
to this rule.
CMP = Chemical Manufacturing Process
Figure 2-1. Applicability of the HON
2-8
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From Figure 1a
CMP = Chemical Manufacturing Process
Is only
one intended
product identified
as predominant?
e.g., >50% if
2 products)
Are
all of the
products listed
in §63.105?
CMP is not
subject to
this rule.
any one of the
products listed in
§63.105?
CMP is identified by one
of the products listed in §63.105
CMP may be identified
by any of the products.
Does
the CMP use
as a reactant or
manufacture as a product,
by-product, or co-product one
or more of the organic HAP's
listed in §63.104
CMP Is
subject to
this rule.
Figure 2-2. Applicability of the HON (continued)
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2.2.3 EON Source
For Subpart G, the HON source includes the following
emission points that are associated with processes
subject to the HON:
Process vents;
Storage vessels;
Transfer racks; and
Wastewater and treatment residuals.
For Subpart H, the HON source includes only:
Equipment leaks.
2.2.4 HON Processes
Determination of whether a process is subject to the
HON is based upon:
The "primary product" of the process; and
Whether or not the process uses organic HAP's as a
reactant or produces them as a product, by-
product, or co-product.
If the primary product is listed in S63.105 of
Subpart F and the process uses or produces as a
product, by-product, or co-product one of the HAP's
listed in §63.104 of Subpart F, the process is subject
to Subparts F and G. If the primary product is listed
in §63.184 of Subpart H and the process uses or
produces as a product, by-product, or co-product one of
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the HAP's listed in §63.183 of Subpart H, the process
is subject to Subparts F and H.
If a process produces more than one intended
product, the one with the greatest annual design
capacity on a mass basis is considered the primary
product.
If a process produces two or more products that
have the same maximum annual design capacity and
if one of the products is listed in either §63.105
of Subpart F or §63.184 of Subpart H, the listed
chemical is considered the primary product. If
more than one of the products is listed in §63.105
or §63.184, the owner or operator may designate
any of the listed chemicals as the primary
product.
Subparts F and H also apply to the following 7
processes for the designated HAP's:
Styrene-butadiene rubber production (butadiene and
styrene emissions only);
Polybutadiene production (butadiene emissions
only);
Chlorine production (carbon tetrachloride
emissions only);
Pesticide production (carbon tetrachloride,
methylene chloride, and ethylene dichloride
emissions only);
Chlorinated hydrocarbon use (carbon tetrachloride,
methylene chloride, tetrachloroethylene,
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chloroform, and ethylene dichloride emissions
only);
Pharmaceutical production (carbon tetrachloride
and methylene chloride emissions only); and
Miscellaneous butadiene use (butadiene emissions
only).
See Subpart H for further explanation of these
processes.
2.2.5 Situations When HON Does Not Apply
If a unit operation that produces one of the HAP's
listed in either §63.104 (Table 1 of Subpart F) or
S63.183 is an integral part of a process that does not
produce one of the chemicals listed in either §63.105
(Table 2 of Subpart F) or §63.184, then the HON does
not apply.
A unit operation is equipment used to make a
single change to the physical or chemical
characteristics of process streams. Examples of
unit operations include the following:
Reactors;
Distillation columns;
Extraction columns;
Decanters;
Compressors;
Condensers;
Boilers; and
Filtration equipment.
For a unit operation to be an integral part of a
process, at least 90% of the product stream from
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the unit operation must be used by the process.
For example, if a distillation column is used to
produce purified methyl methacrylate by removing
an inhibitor, but the distillation column is part
of the process to manufacture methyl methacrylate
acrylonitrile-butadiene-styrene (MASS) resins,
then the distillation column is considered part of
the resins process and is not subject to the HON.
For batch operations or flexible operation units,
Subparts G and H apply only during periods when the
process is actually manufacturing a chemical listed in
§63.105 or §63.184.
Research and development (R&D) facilities are not
subject to the HON even if the R&D facilities are
located at the same plant site as a process that is
subject to the HON.
Petroleum refining and ethylene processes produce
multiple-chemical mixtures for use as fuels or
feedstocks for subsequent chemical manufacturing
processes. Petroleum refining and ethylene processes
are not subject to the HON even if the multiple-
chemical mixture they produce includes chemicals listed
in §63.105 or §63.184. However, any subsequent
chemical manufacturing processes that produce one of
the chemicals listed in §63.105 or §63.184 as a single
chemical product (rather than a mixture) would be
subject to the HON.
The HON does not apply to equipment that does not
contain organic HAP's even if the equipment is located
within a process that manufactures one of the chemicals
listed in §63.105 or §63.184.
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The HON does not apply to processes that are ^.ocated in
coke by-product recovery plants.
The HON does not apply to equipment or operations that
are not associated with the manufacture of chemicals
listed in §63.105 or §63.184 even if such equipment or
operations are located at a plant site that has other
equipment and operations subject to the HON.
2.2.6 Process Assignment for Storage Vessels and Transfer
Racks
A storage vessel or transfer rack is part of a process
if it is used exclusively by a specific process.
If a storage vessel or transfer rack is shared among
several processes, then the applicability of Subparts F
and G is determined as follows:
A storage vessel is part of the process that has
the predominant use of the vessel:
If the greatest input into the vessel is from
a process located on the same plant site,
then the storage vessel is part of that
process; or
If the greatest input comes from a process
that is not located on the same plant site,
then the storage vessel is part of the
process that receives the greatest amount of
material from the vessel.
The applicability of Subparts F and G to a shared
transfer rack is determined at each loading arm or
hose:
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Each loading arm or hose that is dedicated to
the transfer of liquid organic HAP's from a
process which is subject to the HON is part
of that process; or
If a loading arm or hose is shared among
processes, the loading arm or hose is part of
the process that provides the greatest amount
of material loaded by the arm or hose.
If there is no single predominant use of a storage
vessel, loading arm, or hose among the shared
processes, the emission points will be considered
to be part of the process which is subject to the
HON.
If the HON applies to more than one of the shared
processes, the owner or operator may assign the
storage vessel, loading arm, hose, or transfer
rack to any of the processes to which the HON
applies.
If predominant use of a storage vessel or a
loading arm or hose varies from year to year, then
applicability will be determined based on the
equipment's utilization during the year preceding
publication of the final rule. This determination
must be included in the Implementation Plan
required in Subpart G or as part of an operating
permit application.
2.2.7 Applicability of Controls to Individual Emission Points
(Group l/Group 2)
The concept of new and existing sources is important
for determining specific applicability for the
individual emission point provisions, and is defined in
Section 112 (a) of the CAA. A new source is any major
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source for which construction or reconstruction
commenced after the date of proposal. An existing
source is a major source for which construction or
reconstruction commenced before the date of proposal.
If any change is made to a process within a source
(such as alteration, upgrade, rebuild, or replacement
of equipment), or if any additional emission point or
process is added, the owner or operator must determine
whether the source is a new, existing, or modified
source according to provisions being established under
Section 112 (g) of the CAA. If a new chemical
manufacturing process emits or has the potential to
emit, at least 10 tpy of any individual HAP, or 25 tpy
of a combination of HAP's, then the chemical
manufacturing process is considered a new source.
To establish the applicability of the control
requirements of Subpart G, the Group I/Group 2 status
is determined for each emission point in a process
subject to the HON.
The Group I/Group 2 status determination is based on
the characteristics of each kind of emission point.
The criteria are dependent on the emission point. For
example, the process for determining storage vessel
Group 1/Group 2 status is based on vapor pressure and
tank size. The criteria are stated in sections of
Subpart G that state the control requirements for
individual emission points. The various emission point
provisions are summarized in Sections 2.3 through 2.6
of this document.
Unless an emission point is involved in an emissions
average, Group 1 emission points must be controlled and
Group 2 emission points do not require control.
2-16
-------
2.3 SUMMARY OP PROVISIONS FOR PROCESS VENTS
This fact sheet summarizes the proposed HON provisions for
process vents which are in §§63.113 through 63.118 of Subpart G.
Additional process vent requirements can be found in §63.110(b)
of Subpart G and in the definition sections of Subparts F and G.
It has been assumed in the writing of this fact sheet that the
source has determined it is subject to the HON.
2.3.1 Applicability;
"Process vent" means a gas stream that is continuously
discharged during the operation of an air oxidation
process unit, reactor process unit, or distillation
operation within a SOCMI chemical manufacturing
process. It includes gas streams discharged to the
atmosphere after diversion through a product recovery
device.
The following are not considered process vent streams
and, therefore, are not subject to the HON:
Relief valve discharges;
Batch operation process vents; and
Vents with a HAP concentration < 0.005 weight
percent.
2-17
-------
The following are vent streams covered by other
portions of the HON and, therefore, are net subject to
the HON process vent provisions:
Vents from a recovery device installed to comply
with wastewater operations provisions in
Subpart G; and
Vents covered by equipment leak provisions in
Subpart H.
Group I/Group 2 status determinations are required for
each process vent stream, except where the vent is
already in compliance with the Group 1 requirements.
Unless a process vent is involved in an emissions
average, Group 1 process vents require control; Group 2
process vents do not require control.
Characteristics of Group 1 process vents:
Flow rate >. 0.005 scmm;
HAP concentration > 50 ppmv; and
TRE index value < i.o.
Characteristic of Group 2 process vents:
Not a Group 1 process vent.
2-18
-------
TRE format is a cost-effectiveness index associated
with an individual process vent stream and determined
at the outlet of the final recovery device based on the
following characteristics of the stream:
Flow rate;
Net heating value;
TOG emission rate; and
HAP emission rate.
TRE value = 1.0 is based on cost-effectiveness values
of:
$ll,000/Mg HAP removed for new sources; and
$2,000/Mg HAP removed for existing sources
Figures 2-3 and 2-4 illustrate the applicability
determination for the process vent provisions and Group I/Group 2
status determination.
2.3.2 Compliance
Compliance options for Group 1 process vent streams:
Use a flare;
Achieve 98% emission reduction or 20 ppmv exit
concentration (product recovery devices are
considered part of the process and cannot be
included in determining compliance with this
option);
2-19
-------
Vent at a
HON Source
Is Vent
a Relief Valve
Discharge
Not Subject to
the HON
Is Vent
Discharged
from Batch
Process
Is Vent
Discharged from
ecovery Device Install
to Control Emissions from
Wastewater Treatment
Operations Subj
x.to Subpart G
?
Yes /Subject to Krocess
Vent Provisions
of the HON
Does
Vent Satisfy
Definition of 'Equipment
Leak" in Subpart F
Subject to Process
Vent Provisions
of the HON
Is there
<0.005wt.
HAP in Vent
Stream
Not Subject
to the HON
Vent is a 'Process
Venf Subject to the HON
A process vent means a gas stream that is continuosry discharged
during operation of the process unit.
Figure 2-3. Applicability for Process Vents
2-20
-------
No (Optional)
No (Optional)
In Taking this Option,
THE Determination Not
Required and Combustion
Is the Only Option
Process Vents at New
and Existing Sources
Direct Compliance
by Combustion
Preferred
9
Is
Flowrate
< 0.005 scmm
9
Process vent is
Group 2. Control
Not Required.
Is
HAP
Concentration
<50 ppmv
Process vent is
Group 2. Control
Not Required.
Is
TRE Index
Value < 1.0
9
Process Vent is
Group 2. Control
Not Required.
Process Vent is Group 1.
There are 3 Compliance Op^tjons:
Emissions Reduction,
Emission Averaging, or
Increasing THE
At this Point the Source could
Elect to Control the Vent with
Combustion and Avoid the
Calculation of TRE
Emissions Reduction of Organic
Hap using a Flare or by 98
Weight Percent or to
Less than 20 ppmv
Exit Concentation
Figure 2-4. Group 1 and Group 2 Determination
for Process Vents
2-21
-------
Achieve and maintain a TRE index > i.o (e.g., by
process modification or product recover, v
device); or
Include in an emissions average.
If halogenated process vent streams with > 200 ppmv
halogen atoms are combusted, a scrubber that achieves
99% emission reduction or 0.5 mg/dscm exit
concentration of halogens and hydrogen halides must be
installed following the combustion device. Flares
cannot be used with halogenated vent streams.
Figure 2-5 illustrates the process vent compliance options.
2.3.3 Testing. Monitoring, Recordkeeping, and Reporting
Testing:
Required to determine TRE if TRE < 4.0 (estimation
allowed if TRE > 4.0);
Initial Method 18 test to determine compliance
with 98% emission reduction or 20 ppmv;
Initial Method 26 or 26A test to determine
compliance for scrubbers on halogenated streams;
and
A performance test is not required for flares;
however, a compliance determination is required,
which includes, among other requirements, using
Method 22 of Part 60, Appendix A to determine
visible emissions.
2-22
-------
Group 1
Process Vents
/* Achieve an ^^"N.
( Emissions Reduction }
\{SB3.113(a)(1)or(2ti/
Does
the Vent Stream"
Contain >200 ppmv
Halogen
Atoms
Yes
Include
in an Emission Average
(§63.112 (c)(2))
Use a Non-Recovery
Control Device Other Than a
Flare to Achieve 98% Emission
Reduction or 20 ppmv Exit
Concentration; and If Combustion
is Used, Use Scrubber Achieving 99%
overall or 0.5 mg/dscm Exit
Concentration of Each Individual
Halogen or Hydrogen Halide
(§63.113(c))
Achieve and Maintain
a TRE Index
Value >1.0 (e.g. Using a
Process Modification or
Product Recovery Device)
63.113 (a)(3))
Reduce Emissions
by 98% or to 20 ppmv Exit
Concentration Using a Non-
Recovery Control Device
(§63.113 (a)(2))
Figure 2-5. Compliance Options for Process Vents
2-23
-------
Specific monitoring, recordkeeping, and reporting
requirements are specified for each alternative type of
control.
Monitoring of acid gas scrubbers required.
No performance test or monitoring for boilers or
process heaters that:
Introduce the vent stream with primary fuel; or
Have a design capacity > 150 million Btu/hour.
Initial and periodic reporting:
Report of TRE determinations and performance tests
with Notification of Compliance Status to
demonstrate compliance with HON; and
Periodic reporting of operating parameter
monitoring results.
RecordJceeping of monitoring and test results.
A detailed summary of recordkeeping and reporting
requirements is in Section 2.8.
2-24
-------
2.4 SUMMARY OF PROVISIONS FOR STORAGE VESSELS
This fact sheet summarizes the proposed HON provisions for
storage vessels which are in §§63.119 through 63.123 of
Subpart G. Additional storage vessel applicability requirements
can be found in §63.100(b)(4) of Subpart F, in §63.110(c) of
Subpart G, and in the definition sections of Subparts F and G.
It has been assumed in the writing of this fact sheet that the
source has determined that it is subject to the HON.
2.4.1 Applicability
"Storage Vessel" means a tank or other vessel used to
store organic liquids.
The following vessels are assumed to have negligible
HAP emissions and are, therefore, not subject to the
storage vessel provisions of the HON:
Vessels containing organic HAP's as impurities
only;
Pressure vessels designed to operate in excess of
204.9 kPa and without emissions to the atmosphere;
and
The following vessels are not considered to be part of
the SOCMI source category and are, therefore, not
subject to the storage vessel provisions of the HON:
Vessels with a capacity < 38 m3;
Vessels permanently attached to motor vehicles;
Vessels not assigned to a chemical manufacturing
process subject to the HON; and
2-25
-------
The following vessels are covered by the other sections
of the HON and, therefore, are not subject to the HON
storage vessel provisions:
Product accumulator vessels; and
Wastewater storage tanks.
Unless a storage vessel is involved in an emissions
average, Group 1 vessels require control and Group 2
vessels do not require control.
Characteristics of Group 1 storage vessels at new
sources:
The storage vessel capacity is > 38 m3 and
< 151 m3, and the total organic HAP vapor pressure
is > 13.1 kPa; or
The storage vessel capacity is £ 151 m3, and the
total organic HAP vapor pressure is > 0.7 kPa.
Characteristics of Group 1 storage vessels at existing
sources:
The storage vessel capacity is > 75 m3 and
< 151 m3, and the total organic HAP vapor pressure
is > 13.1 kPa; or
The storage vessel capacity is > 151 m3, and the
total organic HAP vapor pressure is > 5.2 kPa.
Characteristic of a Group 2 storage vessel:
Not a Group 1 storage vessel.
2-26
-------
Figures 2-6 through 2-8 illustrate the applicability
determination and Group I/Group 2 status determination for the
storage vessel provisions.
2.4.2 Compliance
Compliance options for Group 1 storage vessels:
Operate and maintain an internal floating roof
having double seals, a single liquid-mounted seal,
or a single metallic shoe-seal;
Operate and maintain an external floating roof
having double seals;
Operate and maintain an internal floating roof
converted from an external floating roof;
Operate and maintain a closed vent system and a
control device that achieves at least 95% emission
reduction; or
Include in a emissions average.
Figure 2-9 illustrates the compliance options for the
storage vessel provisions.
2.4.3 Testing. Monitoring, RecordXeepina, and Reporting
Testing
For a closed vent system, a leak test using
Method 21 and visual inspection while filling the
vessel, and at least once per year;
2-27
-------
Vessel that Stores HAP'i
at a HON Source
Is
the Vessel
Permanently Attached
to a Motor Vehicle
Subject to
e Provisions
Does
the Vessel
Contain Organic HAP's
Only as Impurit)
Vessel is
Not Subject to
the HON
Is
the Vessel a
Product Accumulator
Vessel
Vessel is
Not Subject to
Storage Provisions
of the HON
Is
the Vessel a
Wastewater Storage
Tank
Subject t
Provisions
Is the
Vessel a Pressure
Vessel Designed to Operate
in Excess of 204.9 kPa and
Without Emissions to the
Atmosphere
7
the Capacity
of the Vessel
<38m3
V
Vessel is a 'Storage
Vessel' Subject to the HON
Figure 2-6. Applicability for Storage Vessels
2-28
-------
f Storage Vessels \
V at New Sources )
Storage
Vessel is
Group 2.
Control Not
Required
Is
the Organic
HAPVP*
Is
Capacity
;>151m3
Storage
Vessel is
Group 2.
Control Not
Required
Is
the Organic
HAPVP*
Storage
Vessel is
Group 1.
Control
Required
VP refers to the maximum true vapor pressure of total organic HAP at
storage temperature.
Figure 2-7. Group 1 and Group 2 Determination for
Storage Vessels at New Sources
2-29
-------
( Storage Vessels \
\. at Existing Sources )
Storage
Vessel is
Group 2.
Control Not
Required
Is
Capacity
a 75m3
9
Storage
Vessel is
Group 2.
Control Not
Required
Is
the Organic
HAPVP*
Is
Capacity
;>151rrv>
9
Storage
Vessel is
Group 2.
Control Not
Required
Storage
Vessel Is
Group 1.
Control
Required
Is
the Organic
HAPVP*
;»5.2kPa
9
* VP refers to the maximum true vapor pressure of total organic HAP al
storage temperature.
Figure 2-8. Group 1 and Group 2 Determination for
Storage Vessels at Existing Sources
2-30
-------
( Group 1
V Storage Vessels
Control Required
Equip a Fixed Roof
Vessel with an Internal
Floating Roof having
Single or Double Seals
(§63.119(b))
Convert an External
Floating Roof Vessel
to an Internal
Floating Roof Vessel
(§63.119(d))
Equip with an External
Floating Roof having
Double Seals
(§63.119(0))
Include in an
Emission Average
(§63.112(c) (2))
Equip with a Closed
Vent System and 95%
Efficient or Greater
Control Device
(§63.119(e))
Figure 2-9. Compliance Options for Group 1 Storage Vessels
2-31
-------
No performance test is required for control
devices; however, a design evaluation which sets
monitoring parameters and their ranges is required
and submitted with the Notification of Compliance
Status.
A compliance determination is required for flares,
which includes, among other requirements, using
Method 22 of Part 60, Appendix A, to
determine visible emissions; and
No testing is required for internal or external
floating roofs; however, inspections are required
as summarized below.
Monitoring requirements for a closed vent system and
control device:
For a control device other than a flare, monitor
the parameters established in the Implementation
Plan for the control device used.
For a flare, monitor the flare according to the
general control device requirements specified in
§63.11(b) of Subpart A of Part 63. (These
provisions are identical to 40 CFR 60.18.)
Monitoring requirements for an internal floating roof:
Initial visual inspection before filling; and
If a single seal is used, visual inspection
through manholes and roof hatches annually and
internal inspection each time the vessel is
emptied and degassed, and at least once every 10
years;
2-32
-------
If a double seal is used, one of the following
inspection schedules:
Visual inspection through the manholes and
roof hatches annually and internal inspection
each time the vessel is emptied and degassed,
and at least once every 10 years; or
Internal inspection each time the vessel is
emptied and degassed, and at least once every
5 years.
Monitoring requirements for an external floating roof:
Perform seal gap measurements according to the
following schedule:
For the primary seal, a seal gap measurement
initially and at least once every 5 years;
and
For the secondary seal, a seal gap
measurement initially and at least annually-
Internal inspection each time the vessel is
emptied and degassed.
Monitoring requirements for an external floating roof
converted to an internal floating roof:
Internal floating roof requirements apply.
Initial, periodic, and other reporting required:
An Implementation Plan includes, for a closed vent
system and control device, a 95% efficiency
demonstration (design analysis) and the
parameter(s) to be monitored.
2-33
-------
A Notification of Compliance Status includes:
For a control device other than a flare, the
operating range(s) for the parameter(s) to be
monitored; or
For a flare, the results of the compliance
determination.
Periodic Reports include:
For an internal floating roof, the results of
inspections;
For an external floating roof, the results of
seal gap measurements;
For an external floating roof converted to an
internal floating roof, the results of
inspections;
For a closed vent system and control device
other than a flare, operating parameter
monitoring results; and
For a flare, occurrences when the flare does
not meet the general control device
requirements in §63.11(b) of Subpart A of
Part 63. (These provisions are identical to
40 CFR 60.18.)
Other reports, as applicable.
Recordkeeping of monitoring and testing results.
A detailed summary of recordkeeping and reporting
requirements is in Section 2.8.
2-34
-------
2.5 SUMMARY OP PROVISIONS FOR TRANSFER OPERATIONS
This fact sheet summarizes the proposed HON provisions for
transfer operations which are in §§63.126 through 63.130 of
Subpart G. Additional transfer applicability requirements can be
found in §63.100(b)(5) of Subpart F, in §63.110(d) of Subpart G,
and in the definition sections of Subparts F and G. It has been
assumed in the writing of this fact sheet that the source has
determined that it is subject to the HON.
2.5.1 Applicability
"Transfer Operation" means the loading of liquid
organic HAP's at an operating pressure < 204.9 kPa into
a tank truck or railcar.
The following loading operations are not considered
"Transfer Operations" and are, therefore, not subject
to the HON:
Loading operations at a pressure > 204.9 kPa;
Loading operations during which liquid organic
HAP's are loaded into marine vessels; and
Loading operations during which vapor balancing is
used.
An owner or operator may designate loading operations
during which vapor balancing is used as a transfer
operation and comply with the transfer operations
provisions. The primary purpose for such a designation
would be to include the rack in an emissions average.
2-35
-------
"Transfer Rack" means the piping and valves necessary
to fill tank trucks or railcars, including loading
arms, pumps, meters, shutoff valves, and relief valves
The following are not considered transfer racks and,
therefore, are not subject to the HON:
Racks operating only at pressures > 204.9 kPa;
Racks transferring only to marine vessels;
Racks transferring only liquids containing HAP's
only as impurities; and
Racks that use vapor balancing during all HAP
loading.
Unless a rack is involved in an emissions average,
Group 1 racks require control; Group 2 racks do not
require control.
Characteristics of Group 1 racks:
Total throughput > 650,000 £/yr of liquids
containing organic HAP's; and
Rack weighted average HAP vapor pressure
> 10.3 kPa.
Characteristic of a Group 2 rack:
Not a Group l rack.
Figures 2-10 and 2-11 illustrate the applicability
determination for the transfer operation provisions and
Group I/Group 2 status determination.
2-36
-------
Rack that Transfers
HAP's at a HON Source
Does
Rack Load
only Marine
Vessels
Not Subject
to the HON
Does the Rack
use a Vapor Balancing
system and the point Is
not Included In Emissions
Averaging?
Not Subject
to the HON
Does Rack
Always Operate
at a Pressure
>204.9 kPa
Not Subject
to the HON
Does
Rack only
Transfer Liquids
Containing HAP's only
as Impurities
Not Subject
to the HON
Rack is a Transfer
Rack* Subject to the HON
* Transfer rack* applies to
tank truck and railcar
loading only.
Figure 2-10. Applicability for Transfer Racks
2-37
-------
Transfer Racks at
New and Existing Sources
Does
Rack Load
>6.5x105|/yr of Liquid
Products Containing
Organic HAPs *
Rack is Group 2
Control not Required
Is Rack
Weighted Average
VP*;s10.3kPa
Rack is Group 2
Control not Required
Rack is Group 1.
Control Required During
Operations when Operating
Pressures £204.9 kPa
* Chemicals loaded at a pressure 2204.9 kPa are not
used in the determination of the throughput at the rack
or the rack weighted average vapor pressure.
Figure 2-11. Group 1 and Group 2 Determination
for Transfer Racks
2-38
-------
2.5.2 Compliance
Compliance options for Group 1 racks:
Use a flare;
Use a control device to achieve 98% emission
reduction or 20 ppmv exit HAP concentration;
Use a vapor balancing system; or
Include in an emissions average.
If halogenated vent streams with > 200 ppmv halogen
atoms are combusted, a scrubber that achieves 99%
emission reduction or 0.5 mg/dscm exit concentration of
halogens and hydrogen halides must be installed
following the combustion device. Flares cannot be used
with halogenated vent streams.
Figure 2-12 illustrates the compliance options for the
transfer racks.
2.5.3 Testing, Monitoring. RecordXeepina. and Reporting
Testing
Initial Method 18 or Method 25A test to determine
compliance with 98% emission reduction or 20 ppmv;
Initial Method 26 or 26A test to determine
compliance for scrubbers on halogenated streams;
and
2-39
-------
/Use a Combustion\
f Device \
V (§ 63.126 (b)) J
Group 1
Transfer Racks
Use a Recovery
Device to Achieve 98%
Emission Reduction or
20ppmv Exit Concentration
(§ 63.126 (b)(1))
Include in an
Emission Average
(§63.112(c)(2j)
Use a vapor
Balancing System
(§ 63.126 (b)(3))
Use a Combustion
Device, Other Than a Rare,
to Achieve 98% Emission
Reduction or 20 ppmv Exit
Concentration and Use Scrubber
Achieving 99% or 0.5 mg/dscm
Exit Concentration Hydrogen
Halides and Halogens
(S 63.126 (d))
Does the
Stream Contain
>200ppmv Halogen
Atoms
Use a Combustion
Device to Achieve 98%
Emission Reduction or 20 ppm
Exit Concentration
(§63.126(b)(1))
f Use a Flare that >v
( Complies with § 63.11 (b) )
\" (§ 63.113 (a)(1)) "/
* If this option is chosen, the transfer rack
can be considered not subject to the HON.
Figure 2-12. Compliance Options for Transfer Racks
2-40
-------
A performance test is not required for flares;
however, a compliance determination is required,
which includes, among other requirements, using
Method 22 of Part 60, Appendix A, to determine
visible emissions.
Specific monitoring, recordkeeping, and reporting
requirements are specified for each alternative type of
control.
Monitoring of acid gas scrubbers required.
No monitoring required for boilers or process heaters
that:
Introduce the vent stream with primary fuel; or
Have a design capacity > 150 million Btu/hour.
Monitoring frequency can be based on the length of the
transfer operation or the length of time the control
device is operating. The owner or operator can
determine which method upon which to base the
monitoring frequency; however, the use of certain
control devices dictates that the monitoring frequency
be based on the length of the transfer operation.
Initial and periodic reporting required
Report of performance tests with Notification of
Compliance Status to demonstrate compliance with
the HON; and
Periodic reporting of operating parameter
monitoring results.
2-41
-------
RecordJceeping of monitoring and test results.
A detailed summary of recordkeeping and reporting
requirements is in Section 2.8.
2-42
-------
2.6 SUMMARY OP PROVISIONS FOR WASTEWATER OPERATIONS
This fact sheet summarizes the proposed RON provisions for
wastewater operations which are in §§63.131 through 63.147 of
Subpart G. Additional requirements and information are in
§63.100(b) of Subpart F, and the definition sections of
Subparts F and G . It has been assumed in the writing of this
fact sheet that the source has determined that it is subject to
the HON.
2.6.1 Applicability
"Wastewater" means water or process fluid that contains
organic HAP's and that is discharged into an individual
drain system.
The HON proposes to regulate organic HAP emissions from
the following three types of wastewater streams:
Process wastewater;
Maintenance wastewater; and
Maintenance-turnaround wastewater.
Process Wastewater (SS63.131-147 of Subpart 6)
"Process wastewater" means any water or wastewater
that directly contacts or results from the
production or use of any organic HAP-containing
process fluid.
"Process fluid" means any raw material,
intermediate product, finished product, by-
product, or waste product.
2-43
-------
Examples of process wastewater:
Product or feed tank drawdown;
Water formed during chemical reactions or
used as a reactant;
Water used to wash impurities from organic
products or reactants;
Water used to cool or quench organic vapor
streams through direct contact; and
Condensed steam from jet ejector systems
pulling vacuum on vessels containing
organics.
Maintenance Wastewater (§63.102(b) of Subpart F)
"Maintenance wastewater" means wastewaters which
are generated by draining process fluid from
process unit components into an individual drain
system for maintenance activities.
Maintenance-Turnaround Wastewater (§63.102(b) of
Subpart F)
"Maintenance-turnaround wastewater" means
wastewater generated by a process unit shutdown or
by maintenance activities during the period of the
process unit shutdown.
Examples of process unit activities that may
generate maintenance-turnaround wastewater
include:
Descaling heat exchange bundles;
Cleaning distillation column traps;
Draining low legs or high point bleeds; and
Draining pumps into an individual collection
system.
2-44
-------
The difference between maintenance wastewater
and maintenance-turnaround wastewater is that
maintenance wastewater is not generated
during process unit shutdowns, while
maintenance-turnaround wastewater is only
generated during process unit shutdowns.
Wastewater streams subject to the HON requirements:
> 5 ppmw total organic HAP's and
a flow rate > 0.02 £pm; or
> 10,000 ppmw total organic HAP's at any flow
rate.
Wastewater streams not subject to the HON requirements
include organic HAP-containing water or process fluid
with:
< 5 ppmw total organic HAP's at any flow rate; or
< 10,000 ppmw total organic HAP's at a flow rate
< 0.02 £pm
Although the HON does not include cooling water in the
definition of wastewater streams, the rule does
establish specific requirements for cooling waters,
which have been contaminated with organic HAP's from
leaking heat exchange systems.
2-45
-------
The following are not subject to the HON:
Storm water from segregated storm watex ~ewers;
Water from safety showers; and
Spills.
Group I/Group 2 status determinations are required for
each process wastewater stream except where the owner
or operator chooses to comply with the process unit
alternative compliance option.
The Group I/Group 2 status determinations are made
either at the point of generation or determined through
engineering calculations for the point of generation.
The point of generation is the location where the
wastewater stream exits the process unit component,
product tank, or feed storage tank prior to mixing with
other wastewater streams or prior to handling or
treatment in a piece of equipment which is not an
integral part of the process unit.
For Group I/Group 2 status determination, existing
sources must consider Table 9 of Subpart G.
For Group I/Group 2 status determination, new sources
must consider both Table 8 of Subpart G and Table 9 of
Subpart G.
Table 8 of Subpart G lists HAP's that are considered
very volatile and are a subset of the Table 9 volatile
HAP's.
2-46
-------
Characteristics of Group 1 process wastewater streams
at an existing source:
A total VOHAP average concentration (i.e., average
of all organic HAP's in the stream) of
> 10,000 ppmw of compounds listed in Table 9 of
Subpart G; or
An average flow rate > 10 £pm and a total VOHAP
average concentration > 1,000 ppmw of compounds
listed in Table 9 of Subpart G.
Characteristics of Group 1 process wastewater streams
at a new source:
An average flow rate > 0.02 £pm and an average
concentration of > 10 ppmw of any single HAP
listed in Table 8 of Subpart G;
A total VOHAP average concentration of
> 10,000 ppmw of compounds listed in Table 9 of
Subpart G; or
An average flow rate > 10 £pm and a total VOHAP
average concentration > 1,000 ppmw of compounds
listed in Table 9 of Subpart G.
Characteristic of a Group 2 process wastewater stream:
Not a Group 1 process wastewater stream.
Unless a process wastewater stream is involved in an
emissions average, Group 1 process wastewater streams
require control; Group 2 process wastewater streams do
not require control.
2-47
-------
Figures 2-13 to 2-16 illustrate the applicability
determination for the process wastewater operations provisions
and the Group I/Group 2 status determination.
2.6.2 Compliance
Emissions of organic HAP's from Group 1 process
wastewater streams must be suppressed from the point of
generation through final treatment and/or recycling.
To suppress emissions, a cover is required on certain
waste management units (e.g., trenches, sumps, or
tanks) followed by the routing of vapors to a control
device.
Compliance options for Group 1 process wastewater
streams:
Recycling the stream to a process;
Treating the stream with a design steam stripper;
Reducing total HAP mass or concentration in the
stream; and
Reducing HAP content in the stream to specific
target values.
Possible approaches for reducing total HAP mass or
concentration in the stream:
The process unit alternative control option, which
can be selected only for existing sources,
requires that every individual or combined stream,
from one individual process unit, exits at less
than 10 ppmw total volatile HAP concentration
before being exposed to the atmosphere or being
mixed with streams from other processes. For
2-48
-------
Not
Subject to
Wastewater
Provisions
HON Wastewater?
(Figure 2)
New Source?
(§63.100(1))
Group 1
for Table 6
HAP's?
(Figure 3)
Group 1
for Table 9
HAP's?
(Rgure 4)
Group 2
Wastewater
Stream
Control
(Figures 5 & 8)
Control
(Figures 6 or 7, and 8)
Figure 2-13. Overview of HON Wastewater Provisions
2-49
-------
Not
Subject to
the HON
SOCMI Unit?
(§63.100(b))
Stormwater
in Segregated Sewer?
or Spilt? or Safety
Shower Water?
(§§63.110(e)&63.111)
Not
Subject to
Wastewater
Provisions
Not
Subject to
Wastewater
Provision*
Concentration
<10,000 ppmw&
Flowrate <0.02f pm?
' (§63.110(6))
Not
Subject to
Wastewater
Provisions
Concentration
HON Wastewater
(§63.101
Figure 2-14. HON Wastewater Determination
2-50
-------
Do for each waslewater stream
generated from a process unit at a new source
Determine Concentration
and Flow Rate
Flowrate & 0.02.1pm
and Concentration of any
Table 8 HAP
a 10 ppmw?
Goto
Rgure 4
V
Group 1 Wastewater Stream:
Requires Treatment for Table 8 HAP's
Go to Figure 5
Figure 2-15. Group 1 and Group 2 Determination for Wastewater Streams
Table 8 HAP's [Refer to §63.132(c)]
2-51
-------
Do for each wastewater stream
Determine Concentration
and Flow Rate
(§63.132(1))
VOHAP Concentration
Group 1
Wastewater
Stream
Goto
Figure 6
Beet
1 Mg/yr Source
Wide Exemption?
(§63.138(c))
Total
VOHAP Concentration
£1000 ppmw and Flow Rate
(§63.132(f)(1)(0)
Group 2
Wastewater
Stream
Group 2
Wastewater
Stream
Figure 2-16. Group 1 and Group 2 Determination for Wastewater Streams
Table 9 HAP's [Refer to §§63.132(f) and 63.138(c)]
2-52
-------
example, an owner or operator could use the
process unit alternative control option for
process unit X provided that all four wastewater
streams (A, B, C, and D), whether individual or
combined, exit the process unit with a total VOHAP
concentration < 10 ppmw. Additional requirements
for this option are discussed in §63.138(d) of
Subpart G .
The required mass removal (RMR1 option establishes
a required level of removal for total VOHAP mass
in Group l wastewater streams. The RMR is
determined by an engineering calculation in
Subpart G §63.145(h). To achieve compliance with
this option, the owner or operator must
demonstrate that the actual mass removal, which
may include emission reductions for both Group 1
and Group 2 process wastewater streams, equals or
exceeds the RMR.
The HON requires the owner or operator who generates
maintenance wastewater to submit a description of
implementation procedures for collection of the
wastewater followed by recycling, destruction, or
management in a controlled individual drain system.
The owner or operator must submit this description as
part of the startup, shutdown, and malfunction plan.
The HON requires the owner or operator, who generates
maintenance-turnaround wastewater, to provide an
outline as part of the startup, shutdown, and
malfunction plan, describing procedures for proper
management and control of air emissions. The owner or
operator must implement these procedures during
maintenance activities.
2-53
-------
Compliance options for contaminated cooling water:
Monitor the concentration of HAP's in cc :ing
water, implement a leak detection and repair
program to monitor for leaking heat exchangers,
and repair a leaking heat exchanger as soon as
practicable; or
Maintain pressure in the cooling water side of the
heat exchange system at least 35 kPa greater than
the maximum pressure on the process side.
Figures 2-17 through 2-20 illustrate the wastewater stream
compliance options.
2.6.3 Testing, Monitoring, Recordkeepincr. and Reporting for
Process Wastewater
Testing
Proposed Method 305 may be used to determine the
VOHAP concentration for Group I/Group 2 status
determination. Process knowledge can be used
instead of Method 305. A different EPA-approved
test method (e.g., EPA Method 601 or 602) that
measures organic HAP concentrations in wastewater
also may be used if it is corrected by multiplying
each organic HAP concentration by the compound-
specific Fm in Table 13 of Subpart G. Test
methods that have not received EPA-approval must
be validated by Method 301 of Part 63, Appendix A.
Proposed Method 304 is required for the
determination of site-specific biodegradation
kinetic constants which characterize the operation
of properly operated biotreatment units. These
constants are used as inputs to WATER? to
2-54
-------
Control Air Emissions Before
and During Treatment/Recycle
One or
More Group 1 and/or
Group 2 Wastewater Streams
Combined?
Yes
For One Group 1
Wastewater Stream Only:
1. Recycle to Process
or
2. Use Design Steam Stripper
or
3. Reduce VOHAP Mass by 99%
or
4. Reduce Concentration of Each
HAP to < 10 ppmw
For One or More Group 1/
Group 2 Wastewater Streams:
1.
Recycle to Process
or
2. Us* Design Steam Stripper
3. Reduce VOHAP Mass by 99%
or
4. Treat to Achieve Required
Mass Removal
Treat Residuals
(Figure 8)
Determine if Group 1
forTable9HAP's
(Figure 4)
Figure 2-17. Compliance Options for Control of Table 8 HAP's
[Refer to §63.138(b)]
2-55
-------
Control Air Emissions Before
and During Treatment/Recycle
Combined
Group 1 and
Group 2 Wastewater
Streams?
For One or More Individual
Group 1 Wastewater Streams:
1. Recycle to Process
or
2. Use Design Steam Stripper
or
3. Reduce VOHAP Mass by
Percentages Specified for
Strippabilrty Groups in Table 9
or
4. Reduce Total VOHAP Concentration
to <50 ppmw
or
5. Reduce VOHAP Mass by 99%
Treat
Residuals
(Rgure 8)
Yes
For One or More Group 1/
Group 2 Wastewater Streams:
1. Recycle to Process
or
2. Use Design Steam Stripper
3. Reduce VOHAP Mass by
Percentages Specified for
Strippabilrty Groups in Table 9
or
4. Treat to Achieve Required
Mass Removal
or
5. Reduce VOHAP Mass by 99%
Figure 2-18. Compliance Options for Control of Table 9 HAP's
[Refer to §63.138(c)]
2-56
-------
For control of Table 9 HAP's only
Non-process wastewater streams and
wastewater streams from other process
units cannot be combined when using this option
Control Air Emissions Before
and During Treatment/Recycle
All Process Wastewater Streams
from a Process Unit Must Comply
with these Provisions if this
Option is Selected
For All Wastewater Streams:
1. Recycle to the Process
or
2. Reduce Total VOHAP Concentration
to < 10 ppmw before Being
Discharged or Combined with
Wastewater Streams from Other
Process Units
Treat
Residuals
(Figure 8)
Figure 2-19. Process Unit Alternative Compliance Option
[Refer to §63.138(d)]
2-57
-------
Control Air Emissions Before
and During Trealment/Recycle
For All Residuals:
1. Recycle to Process
(includes sale as feedstock)
or
2. Return to Treament Process
or
3. Destory Total HAP Mass by 99%
(includes sale for energy recovery)
Figure 2-20. Compliance Options for Control of Residuals
[Refer to §63.138(g)]
2-58
-------
determine Fbi0, a variable in the mass removal
calculation, which is required for compliance
demonstration of a biological treatment unit, in
§63.145(1)(2). Access to WATER? is described in
Appendix A of this guide.
Specific sections within the process wastewater
operations provisions (§§63.144 and 63.145 of
Subpart G) should be referred to for details
regarding the use of test methods.
The type of waste management unit and control device
determines the specific monitoring, recordkeeping, and
reporting requirements.
The following monitoring guidelines and inspection
standards are generally required:
Continuous parameter monitoring for vapor control
devices;
Monthly parameter monitoring for treatment units
and other waste management units;
Continuous parameter monitoring for design steam
strippers;
Annual leak inspections of covers and openings for
waste management units;
Seal gap inspections of waste management units
every five years for primary seals;
Annual seal gap inspections of waste management
units for secondary seals; and
2-59
-------
Semi-annual visual inspections of waste nanagement
units for proper operation, maintenance, and sound
work practices.
2-60
-------
2.7 SUMMARY OP EMISSIONS AVERAGING
This fact sheet summarizes the proposed HON provisions for
emissions averaging found in §63.150 of Subpart G. Figure 2-21
illustrates the determination of whether emissions averaging can
be used at a source.
HON Subpart G standard is stated as an emissions
allowance (see §63.112 for an explanation of the terms
of this equation) :
= 0.02 ZEPVx + EEPV2 +0.05 EESi + EES2
+ 0.02 EETRi + EETR2 + EEWWlc + EEWW2
Stating the standard in this way allows for
emissions averaging as an alternative means of
compliance for points subject to Subpart G of the
HON.
Emissions Averaging allows a source flexibility in
their method of control while achieving approximately
equivalent emission reductions.
May average across all elements in a single HON
source:
Different kinds of emission points (e.g.,
process vents, storage vessels, transfer
operations and wastewater);
Different chemical manufacturing processes;
and
Different pollutants (organic HAP's).
2-61
-------
to
I
en
to
Is the
Group 2
Point Controlled by
a Pollution Prevention
Measure Implemented
after f987 X
7
Are
Group 1
Emissions Points
that the Facility
Does Not Want
to Control?
Are there
Group 1 or
Group 2 Emission
Points Available for
Over-control
7
lathe
Over-controlled
Point a Group 1
Point?
Source Interested
In Emissions
Averaging
Emissions
Averaging
nof
Beneficial
bit
Controlled
by a Control
Device Installed
After
11/15/90
7
Emission
Point
Cannot be
Used to
Generate
Credit
bit
Controlled
by a Pollution
Prevention Measure
Implemented After 1987
and Achieving a Level
of Control more
Stringent than
the Reference
Technology
Was
the
Control Device
Installed as Part
of 33/50 or an Early
Reduction
Commitment
7
by a Control
to Which EPA\ No
has Assigned a Nominal
Efficiency Higher than
. the Reference x
Technology
Was
the Control
Device Installed
after
11/15/90
7
Is
the Device
of a 33/50 or an
Earty Reduction
Commitment
7
Group 1 Emission
Emission
Point
Cannot be
Used to
Generate
Credit
Point can be Used
to Generate Credit
Are
there
Additional
Points Available
for
Over-control
7
Calculate Credits for
each Over-controlled
for Under-controlled
Averaging
Possible
Point add Together,
Grouo 1 Points and
Written
Statement for
Implementation
Program and Install
Controls
* Proposal Includes a discount factor ranging between 0.8 to 1.
Figure 2-21. Emissions Averaging Applicability
-------
May not average across sources, including:
New and existing sources;
Sources in different source categories; and
Sources at different facilities.
Credit/Debit System
Credits are generated when there is an "over-
control," or when allowed emissions are greater
than actual emissions.
Debits are generated when there is an "under-
control" of a Group 1 point, or when allowed
emissions are less than actual emissions.
For Group 1 points: Allowed emissions are the
residual emissions after the RCT or an equivalent
is applied.
For Group 2 points: Allowed emissions are the
emissions at baseline control levels.
Emission Credits and Debits must balance:
On a mass basis (in Mg) and on an annual
basis.
Debits may not exceed credits by more than
25 - 35% in any one quarter.
1) Seeking comment on what value in the
25 - 35% range should be required.
2) Seeking comment on an alternative
quarterly check.
Credits and debits must be calculated monthly.
Equations are provided in §63.150(f) and (g) .
2-63
-------
Credits may be "discounted"that is, reduced in
value by 0-20% before being compared to debits.
Creditable Controls are:
Control devices installed since 11/15/90;
Pollution prevention measures taken after 1987;
and
Controls put in place prior to 11/15/90, if:
They are part of a 33/50 commitment; or
They are part of an early reductions
commitment, other than a shutdown.
Ways to Generate Credit:
Group 2 points: Apply a creditable control.
Group 1 points: Apply a creditable control that
is different from the RCT in use or design and is
more efficient than the relevant RCT (see RCT
summary table in Section 2.1). RCT cannot
generally be used to generate credits from Group 1
points.
Two exceptions for generating credit with an RCT
on a Group l point:
RCT applied to a process vent, if:
(1) It can be demonstrated that 99.9%
efficiency has been achieved;
(2) An EPA-approved GEM plan has been
instituted; and
(3) EPA has approved the efficiency prior to
use.
2-64
-------
Closed vent systems with a control device on
storage vessels, if:
(1) It can be demonstrated that 98%
efficiency has been achieved;
(2) The credit would be for 3% control over
the RCT's 95%; and
(3) The efficiency must be approved by the
permit authority prior to use.
Approval process required for having a "nominal"
emissions reduction efficiency assigned to a "new,"
non-RCT, device that has a higher efficiency than the
RCT.
Approval processes required for devices that are
different from the RCT in use or design.
If the device has broad applicability: EPA
approval required and Federal Register notice used
to assign a nominal efficiency.
If the device will be used in fewer than 3
applications: Permit authority assigns
efficiency, documents use of the device in
source's permit.
If permitting authority considers new
technology to have broad applicability, must
notify EPA.
Banking
"Extra" credits, established after the annual
comparison of credits and debits, can be banked
for future use.
2-65
-------
Credits can be banked for 2-5 years.
Seeking comment on how long banked credits
should be available for usea single value
will be selected for the final rule.
Must keep all relevant records about the
credit and debits for an average, including
the pre-existing records for the banked
credit, for 5 years after use of a banked
credit.
Banked credits can only be used to meet the annual
credit/debit balance.
Cannot be used for quarterly emissions
"check."
Recordkeeping and Reporting
Emissions averaging must be approved as part of
Implementation Plan or operating permit
application.
Emissions averaging plan must project sufficient
credits to balance debits under representative
operations.
Control commitments in an emissions averaging plan
are separately enforceable from the credit/debit
balance.
Quarterly reporting of operating parameter
monitoring results, credits, and debits for points
in emissions averages.
2-66
-------
2.8 SUMMARY OF RECORDKEEPING AND REPORTING
This fact sheet summarizes the proposed HON recordkeeping
and reporting requirements which are §§63.151 and 63.152 of
Subpart G.
2.8.1 Records
Keep readily accessible for 5 years [§63.103(c)].
Keep for life of equipment if pertaining to equipment
design [e.g., (§63.123(a)) dimensions and capacity for
storage vessels].
For continuously (every 15 minutes) monitored control
devices, generally keep records of monitored values for
every 15 minutes of operation (or the 15-minute average
if values are measured more frequently than once every
15 minutes) [§63.111].
Record that required periodic inspections or
measurements were performed [e.g., (§63.123(c) and (e)
inspections of floating roofs for storage vessels].
2.8.2 Reports
Submit to "Administrator" (defined as Administrator of
EPA, an EPA regional office, State agency, or other
delegated authority). Reports are usually sent to
State agencies [§63.2 and 63.103(d)(i)].
Submit according to dates on timelines (Figures 2-22
and 2-23) .
If requesting a compliance extension of up to 1 year,
submit request for extension to operating permit
authority as part of the operating permit application,
2-67
-------
Figure 2-22. Reporting and Recordkeeping Schedule for Subpart G Requirements
for New Sources'
to
I
o>
03
Initial Notification0
and Implementation Plan
Due i
Time Varies
Notification of
Compliance Status
L/U6
1st
Semiannual Semiannual
and Quarterly and Quarterly
Reports Reports
Due Due
1 4
' -6 -4
Month
A AAAA/
^r T » » v
' 1
Commencement
of
Construction
A
w
x x + 2
Start-up
_i
'
x + 4
L A
^
x + 6
1st
Quarterly
Report*
1 i
xia x +
Quarterly
Report
Due
> A
10
^r
x + 12 x
Quarterly
Report
Due
4 . * ^
-^ ^
+ 14 x + 16
^ ^
x+ 18 x + 20
Quarterly
Report
Due
P \
'
X + 22
/
x + 24
Quarterly
Report
Due
a) Assumes commencement of construction is after promulgation.
b) Initial Notification and Implementation Plan are due 45 days after promulgation
or 180 days before commencement of construction or reconstruction,
whichever is later.
c) Implementation Plans are only required for sources that have not already
submitted an operating permit application.
d) Notification of Compliance Status is due 150 days after compliance date.
Compliance date is start-up date or promulgation date, whichever
is later.
e) Quarterly Reports for points in an emissions average are due 60 days after the
end of each quarter. The first Quarterly Report is due no later than 5 months
after compliance date. Periodic Reports may be required quarterly instead ol
semiannualfy in some non-emissions averaging situations.
f) Semiannual Reports are due 60 days after the end of each 6 month period
The first report is due no later than 8 months after compliance date.
-------
Figure 2-23. Reporting and Recordkeeping Schedule for Subpart G
Requirements for Existing Sources
to
I
Notification 1 st
Initial
Notification"
Due
Implementation Plan
for Points in an
Emissions Average b
Due
Promulgation I ^^v.
I 0 2
Month
Year 0
468
10 12 14
Year!
16 18
Implementation Plan
for Points Not In an
Emissions Average6
Due
. . i .. .
20 22 24 26 28 30
Year 2
Semiannual
of Semiannual and Quarterly
Compliance Report* Reports
Status c Due Due
Compliance
32 34 36 38
Year 3
Due
_
^
40
I.
rW % w-
42 44 46
1 st Quarterly
Quarterly Report
Report o Due
Due
A A M m t
Semiannual
and Quarterly
Reports
Due
.1.
TTW w V V « w w~i
48 50 52 54 56 58
| Year 4 |
60
Year 5
Quarterly Quarterly Quarterly
Report Report Report
Due Due
Due
a) Initial Notification is due 120 days after promulgation date. Requests for
site-specific compliance extensions should be submitted with the Initial
Notification or the operating permit application when available, or no later
than the date the Implementation Plan is required to be submitted.
b) Implementation Plans are only required for sources that have not already
submitted an operating permit application. Trie Implementation Plan is due
18 months before compliance date for points in an emissions average or
12 months before compliance date for points not in an emissions average.
c) Notification of Compliance Status is due 150 days after compliance date.
d) Quarterly Reports for points in an emissions average are due 60 days after the
end of each quarter. The first Quarterly Report is due no later than 5 months
after compliance date.
e) Semiannual Reports are due 60 days after the end of each 6 month period. The
first report Is due no later than 8 months after compliance date.
-------
with the Initial Notification, or as a separate
submittal, but no later than the date the
Implementation Plan is required to be submitted
[§63.151(a)(6)].
There are five types of reports: Initial Notification,
Implementation Plan, Notification of Compliance Status,
Periodic Reports, and Other Reports.
Initial Notification: Used to tell if a source is
subject to the HON [§63.151(b)]. Includes:
Source identification;
Identification of chemical manufacturing processes
at the source that are subject and which Subpart G
provisions may apply;
Whether source can achieve compliance by
compliance date; and
If requesting exemption, an analysis demonstrating
the source is an area source.
Initial Notification (and Implementation Plan) for
new sources are due 45 days after promulgation, or
180 days before commencement of construction or
reconstruction, whichever is later. Initial
notification for existing sources is due 120 days
after the promulgation date [§63.151(b)(2)].
Implementation Plan: Tells how a source plans to
comply and is submitted only if an operating permit
application has not yet been submitted
[§63.151(c)-(h)]. Also used to seek approval for
alternative monitoring requirements.
2-70
-------
Regardless of whether the source takes part in
emissions averaging or not, plan must include
[§63.151(d) and (e)]:
Identification of emission points and whether
each emission point is Group 1 or 2;
Control technology or method of compliance to
be used for each point; and
Description of parameters to be monitored.
For points in an emissions average, plan must also
include [§63.151(d)]:
Projected emission debits and credits for
each emission point and sum of emission
points involved in average;
Information specific to process vents,
storage vessels, transfer racks, and
wastewater operations in the emissions
average including:
(1) Values of parameters needed for input to
emission debit and credit calculations;
(2) Estimated percent reduction if a control
technology less efficient than the RCT
is applied;
(3) Anticipated nominal efficiency if a
control technology more efficient than
the RCT is applied; and
(4) Written statement that all testing,
monitoring, recordkeeping, and reporting
procedures for Group 1 points will be
implemented for all points in the
average.
2-71
-------
If setting unique operating parameters for
monitoring [§63.151(f)]:
Description of parameters to be monitored;
Description of methods and procedures used to
demonstrate that parameter indicates proper
operation of control device and schedule for
demonstration; and
Planned frequency and content of monitoring,
recordkeeping, and reporting.
Submit supplement to the Implementation Plan if
using alternative controls or operating scenarios
[563.151(g)].
Submit written updates of the Implementation Plan
within 90 days of the process change or the change
in the planned method of compliance when
[S63.151(h)]:
Process change alters Group I/Group 2 status
determination of emission point;
Value of a parameter in the emission credit
or debit equation changes so it is outside
range specified in Implementation Plan and
causes a projected decrease in credits or
increase in debits;
Use alternative control technique or plan to
monitor alternative parameter; or
A new emission point is added.
Implementation Plan (and Initial Notification) for
new sources are due 45 days after promulgation or
180 days before commencement of construction or
reconstruction, whichever is later.
Implementation Plan for existing sources is due
18 months before compliance date for points in an
2-72
-------
emissions average or 12 months before compliance
date for points not in an emissions average
[§63.l5l(c) ].
Notification of Compliance Status: Demonstrates that
compliance has been achieved [§63.152(b)]. Contains
3
information such as the results of:
*.
Emission point Group I/Group 2 status
determinations;
x
Performance testssubmit one complete test report
for each test method used for a particular kind of
emission point. Submit summary of results of
additional tests using that method, including
values of monitored parameters during the tests;
Inspections [e.g., §63.129(a)(8) for transfer
racks, visual inspections and method 21 leak
readings made prior to the performance test];
TRE determinations for process vents;
Design analyses [§63.146(b)(7)(ii)(B) for
wastewater operations, design analysis of closed
vent systems and control devices as an alternative
to performance tests; §63.117(a)(5)(i) flare
design for process vents; §63.129(a)(5)(i) flare
design for transfer racks];
Specific range determinations for each monitored
parameter for each emission point and rationale
for why this range indicates proper operation of
the control device;
2-73
-------
For points in an emissions average, the measured
or calculated values of all parameters needed to
calculate emission credits and debits, and result
of calculation for the first quarter; and
Continuous monitoring system performance
evaluations.
Notification of Compliance Status is due 150 days
after the compliance date.
Periodic Reports: Ensure compliance and that control
devices are operated and maintained properly
[§63.152(c)].
Semiannual report includes:
Identification of periods when values of
monitored parameters are outside established
ranges;
Results of periodic inspections that indicate
problems; [e.g., for storage vessels
§63.121(d)(1), annual visual inspections of
internal floating roofs; §63.121(d)(2)
internal inspections of internal floating
roofs, and §63.121(e) inspections of seal gap
measurements for external floating roofs];
and
Results of performance testssubmit one
complete test report for each test method
used for a particular kind of emission point,
and summary of results of additional tests
using that method.
Semiannual reports are due 60 days after the end
of each 6 month period; first report is due no
later than 8 months after the compliance date.
2-74
-------
Quarterly reports for all emission points included
in an emissions average; every fourth quarterly
report contains annual credit and debit balance
[§63.152(c)(4)].
Quarterly reports for points in an emissions
average are due 60 days after the end of each
quarter; first report is due no later than
5 months after the compliance date.
Quarterly reports may be required for 1 year for
emission points not included in an emissions
average if [§63.152(c)(5)J:
Monitored parameters are outside of
established range for greater than 1 percent
of operating time or continuous monitoring
system downtime is greater than 5 percent of
total operating time for reporting period;
and
Administrator requests quarterly reports.
Other Reports: Allow source to provide information
before or after specific events [§63.152(d)]. These
reports are:
Reports of startup, shutdown, and malfunction;
Reports of some process changes for process vents;
Request for extensions of repair and notifications
of inspections for storage vessels;
Requests for extensions for emptying a wastewater
tank; and
2-75
-------
Requests for approval of a nominal ccntrol
efficiency for use in calculating credits for an
emissions average; and
Other reports are due according to dates specified
in the NESHAP General Provisions in Subpart A of
Part 63 or in §63.113 through §63.151.
2-76
-------
2.9 SUMMARY OP CONTINUOUS PARAMETER MONITORING
Continuous monitoring of control device operating
parameters is required for most control devices.
Periods when parameter values are outside site-specific
ranges must be reported. Results are used to determine
compliance with the operating conditions for each
control.
Operating parameters to be monitored and reported for
each control device are specified in §§63.114 and
63.118 for process vents, §§63.127 and 63.130 for
transfer racks, and §§63.143 and 63.146 for wastewater
operations.
Sources can apply to monitor other site-specific
parameters under §§63.151(f) and 63.152(e).
The Notification of Compliance Status or operating
permit application will establish a site-specific range
for each monitored parameter, §63.152(b)(2). Include
in the Notification of Compliance Status the following:
Specific range of monitored parameter(s) for each
emission point;
Rationale for the specific range for each
parameter, including data and calculations used in
developing the range and a description of why the
range indicates proper operation of the control
device; and
Definition of source's operating day, including
times, for determining daily average values of
monitored parameters.
2-77
-------
Keep records and submit reports as follows:
Keep records of values generated every 15-minutes
(or 15-minute averages).
Keep records of daily average values (average of
all 15-minute values during the operating day).
Report in the periodic Report all daily average
values that fall outside the established range.
The values outside the established range are
considered "excursions."
3-6 excused excursions (3 to 6 operating days) are
allowed per semiannual reporting period, or 1-3 days
per quarterly reporting period, for each control device
§63.152(c)(5)(v). (A single number of excused days
will be selected for the final rule.)
If an emission point has more than the excused number
of excursions in a reporting period (a quarterly or
semiannual period), then that emission point is in
violation of the permitted operating conditions.
2-78
-------
2.10 SUMMARY OP PROVISIONS FOR EQUIPMENT LEAKS
This fact sheet summarizes the proposed HON provisions for
equipment leaks which are in Subpart H. It has been assumed in
the writing of this fact sheet that the source has determined it
is subject to HON. Additional information may be found in the
article "Understanding the Regulations Governing Equipment
Leaks", which was published in the August 1991 issue of Chemical
Engineering Progress.
2.10.1 Applicability
The standards for equipment leaks apply to SOCMI
sources and specific HAP emissions from seven non-SOCMI
processes. The seven non-SOCMI processes and their
designated HAP's are:
Styrene-Butadiene rubber production (butadiene and
styrene emissions);
Polybutadiene production (butadiene);
Chlorine production (carbon tetrachloride);
Pesticide production (carbon tetrachloride,
methylene chloride, and ethylene dichloride);
Chlorinated hydrocarbon use (carbon tetrachloride,
methylene chloride, tetrachloroethylene,
chloroform, and ethylene dichloride);
Pharmaceutical production (carbon tetrachloride
and methylene chloride); and
Miscellaneous butadiene use (butadiene).
The following types of equipment that contain or
contact a fluid that is at least 5 percent total VHAP
are subject to Subpart H:
Pumps Sampling connection systems
Valves Accumulator vessels
Connectors Pressure relief devices
2-79
-------
Compressors Open-ended lines
Agitators Instrumentation systems
Control devices Closed vent systems
Subpart H categorizes the SOCMI processes into five
groups. The applicability date for Subpart H
provisions differs for each of the five groups. Each
group must comply with the following implementation
schedule for equipment leak provisions:
Group I must comply six months after the final
rule is issued.
Group II must comply nine months after the final
rule is issued.
Group III must comply twelve months after the
final rule is issued.
Group IV must comply fifteen months after the
final rule is issued.
Group V must comply eighteen months after the
final rule is issued.
The seven non-SOCMI processes must comply with
Subpart H six months after the final rule is issued.
2.10.2 Compliance
The negotiated rule (i.e., Subpart H) is similar to
existing NSPS and NESHAP requirements for volatile
organic equipment leaks (40 CFR 60, Subpart V, and
40 CFR 61, Subpart J). Subpart H is based on LDAR
programs for pumps and valves and provisions identical
to or very similar to those in the NSPS and NESHAP for
2-80
-------
compressors, open-ended lines, pressure relief devices,
sampling connection systems, and closed vent systems
and control devices.
The negotiated rule also requires LDAR for connectors
and agitators. The standard for connectors bases
monitoring frequency on performance (i.e., percent
leakers).
The standards for pumps and valves differ from LDAR
programs in the previous NSPS and NESHAP in the
following ways:
These standards are implemented in three phases,
with new process units entering at the second
phase (see Table 2-2).
Pumps and valves at existing process units in
Phase I are subject to a leak definition of
10,000 ppm for the first year after the
applicability date.
Phase II commences one year after the
applicability date for existing pumps and valves
and after initial startup for new pumps and valves
and continues for the next 1 1/2 years.
Phase II provides a lower leak definition for
pumps of 5,000 ppm. Phase II also provides a
lower leak definition for valves of 500 ppm.
Phase III for pumps lowers the leak definition
from 5,000 ppm to levels ranging from 1,000 to
5,000 ppm. For general duty pumps, the leak
definition is 1,000 ppm with repair required at
2,000 ppm. For pumps in food/medical service, the
leak definition is 2,000 ppm. For pumps in
2-81
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TABLE 2-2. PHASED APPROACH FOR PUMP AND VALVE STANDARDS
Duration
Leak Definition and
Monitoring for
Valves
Leak Definition
and Monitoring
for Pumps
Phase
M
-P
M
D
W
w
0)
u
o
M
Pu
Phase
"
0-1 year
after
promulgation
1-2.5 years
after
promulgation
10,000 ppm;
quarterly
monitoring
500 ppm; quarterly
monitoring
10,000 ppm;
monthly
monitoring
5,000 ppm;
monthly
monitoring
-P
U
tH
X
u
Phase
HI
2.5 years
after
promulgation
and
thereafter
500 ppm;
monitoring
frequency based on
performance (i.e.,
percent leaking
components)
Phase
I
1,000 or 5,000
ppm;a
monthly
monitoring based
on performance
(i.e., percent
leaking
components); QIP
may be required
for general duty
pumps
w
P
-H
c
D
Cfl
Cfl
0)
o
o
l-l
Phase
II
Phase
III
0-1.5 years
after initial
start-up
1.5 years
after initial
startup and
thereafter
500 ppm;
quarterly
monitoring
500 ppm;
monitoring
frequency based on
performance (i.e.,
percent leaking
components)
5,000 ppm;
monthly
monitoring
1,000 or 5,000
ppm;a
monthly
monitoring based
on performance
(i.e., percent
leaking
components); QIP
may be required
Depends on type of service.
Pumps and valves at new process units must comply with the
provisions of Phase II immediately after initial startup.
2-82
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polymerizing monomer service, the leak definition
remains 5,000 ppm.
For general service pumps in Phase III, if either
10% or more of the pumps or 3 pumps leak, the
owner/operator must institute a QIP-
Phase III for valves maintains the Phase II leak
definition of 500 ppm. If 2% or more of the
valves leak, the owner/operator must either
conduct monthly monitoring or institute a QIP.
The basic QIP consists of information gathering,
determining superior performing technologies, and
replacing poorer performers with the superior
technologies until the target performance level is
met.
The QIP's were developed in recognition that the
low leak definitions provided in Phases II and III
may not be achievable at all SOCMI process units
(because for pumps the lowest definition does not
occur until Phase III). These provisions allow
those plants that implement the program but do not
achieve the base performance levels the
flexibility to develop process-specific and cost-
effective methods for improving emissions
performance.
Owners and operators can take partial credit in the
calculation of percent leaking valves and connectors
for valves and connectors permanently removed from the
process unit.
Special provisions are included for pumps in
food/medical and polymerizing monomer service; leakless
2-83
-------
pumps; nonrepairable, unsafe- or difficult-to-monitor
valves and connectors; and small plants.
Alternative standards have been written for batch
processes. Also, procedures are provided for pressure-
testing batch process equipment with both gas and
liquid.
2.10.3 Testing, Monitoring. Recordkeepina. and Reporting
Initial and Periodic Reporting:
Initial report describing the source and its
subject equipment; and
Semiannual reports summarizing the percent leaking
components (by component type); number of
nonrepairable components; results of all
performance tests to determine compliance with
SS63.164(i), 63.165(a), and 63.173(f); changes in
monitoring frequency or other alternatives allowed
under each standard; and initiation of a QIP-
Reports may be submitted on electronic media.
2-84
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3.0 CASE STUDIES
This chapter presents two possible scenarios a facility can
choose to meet the requirements of the HON. The scenarios are
presented in the form of case studies. Under the RCT case study,
controls are applied to each Group 1 emission point at the
facility. The emissions averaging case study presents an
approach where the facility controls some Group 2 emission points
and some Group 1 emission points instead of all Group 1 emission
points. The purpose of these case studies is to illustrate the
following: the emission points subject to control; the control
options; the monitoring provisions as they apply to the controls
chosen; and an example of how a facility can use the flexibility
of the emissions averaging provisions. Throughout the chapter,
the terms "SOCMI" and "SOCMI process" are used to apply to
chemicals listed in §63.105 of Subpart G.
The chapter is divided into three sections. In Section 3.1,
the fictitious company used for the case studies, General
Chemical, is introduced and the applicability of the HON is
determined. Section 3.2 steps through the Group I/Group 2 status
determination for each emission point in the HON source at the
General Chemical facility, the decision of which RCT to apply to
Group 1 emission points, and the resulting monitoring
requirements. The emissions averaging case study is described in
Section 3.3.
3.1 THE FACILITY
In order for a facility to have processes that are subject
to the HON, the facility must be a major source and have one or
more SOCMI processes that use a HAP as a reactant or produce a
HAP as a product, by-product, or co-product.
General Chemical is an existing source which has five
chemical production processes at its plant. General Chemical is
already aware that it is a "major source" as defined in
Section 112(b) of the CAA. It emits greater than 10 tpy of an
individual HAP and greater than 25 tpy of a combination of HAP's;
however, only one of these conditions (the 10 tpy or 25 tpy) must
be met to consider the facility a "major source". All emission
3-1
-------
points within contiguous or adjoining property that are under
common ownership or control are considered part of the source for
the determination of whether the source is major. Thus, both
SOCMI and non-SOCMI processes are considered in the determination
of whether General Chemical is a major source. The EPA is
currently developing guidance for source owners and operators to
use in determining whether a facility is a major or an area
source.
To determine if a process is a SOCMI process, General
Chemical first looked at its primary products. Table 3-1 lists
General Chemical's manufacturing processes and primary products
produced. For a process to be a SOCMI process, the primary
product must be a chemical listed on Table 2 in §63.105 of
Subpart F. Four of General Chemical's production processes are
SOCMI processes, since methanol, dimethyl formamide, methylamine,
and diethylamine are all listed in §63.105 of Subpart F.
Isopropylamine is not listed in §63.105 of Subpart F; therefore,
its production is not a SOCMI process, and the process is not
subject to the HON.
In order to determine if the SOCMI processes are subject to
the HON, General Chemical then looked at whether organic HAP's in
the processes are being produced (as products, co-products, or
by-products) by the processes or used as reactants. Table 1 in
§63.104 of Subpart F lists the organic HAP's subject to the HON.
As a first review, General Chemical compared their primary
products with the list in §63.104 of Subpart F. Both methanol
and dimethyl formamide are organic HAP's (listed on Table 1), but
methylamines and diethylamine are not. Therefore, General
Chemical had to look further at co-products, by-products, and
reactants for the methylamines and diethylamine processes to
determine if any were organic HAP's subject to the HON. In the
case of Process D, which produces diethylamine by the ethylation
of ammonia, triethylamine is produced as a co-product.
Triethylamine is on Table 1 of Subpart F. In the case of
Process C, which produces methylamines by the methylation of
ammonia, methanol is used as a reactant. Methanol is on Table 1
3-2
-------
TABLE 3-1. GENERAL CHEMICAL PROCESSES & PRIMARY PRODUCTS
-Process Products
A Hydrogenat;ion of Carbon Methanol
Monoxide3 ;
B Aminolysis of Methyl Formate3 Dimethyl Formamide
C Methylatian of Ammonia3 Methylamines
D Ethylatio* of Ammonia3 Diethylamine
E AminolysiJ of Isopropyl Alcohol Isopropylamine
3 SOCMI Processes
3-3
-------
of Subpart F. Therefore, all four SOCMI processes are subject to
the HON.
The emission points of the four production processes subject
to the HON are process vents, storage vessels, transfer racks,
wastewater streams, and equipment leaks. The "source" subject to
the HON is the combination of these emission points within the
four SOCMI processes. Equipment leaks must be controlled
according to the provisions of Subpart H and cannot be included
in emissions averages; therefore, equipment leaks will not be
discussed in these case studies.
3.2 REFERENCE CONTROL CASE STUDY
The owner or operator complying with the HON through
application of RCT would first determine whether each emission
point is a Group 1 or Group 2 emission point. The flow diagrams
and regulatory summaries in Chapter 2 of this document discuss
the technical parameters used to make the Group I/Group 2 status
determination for each kind of emission point. Since this plant
is an existing source, the criteria for existing source
Group I/Group 2 status determinations are used. After completing
the Group I/Group 2 status determination, the owner or operator
would apply the specified level of control to each Group 1
emission point. Control of Group 2 emission points is not
required. This case study illustrates how the technical
parameters for Group I/Group 2 status determination are evaluated
for a source's emission points (process vents, storage vessels,
transfer racks and wastewater streams), what controls could be
applied to the Group 1 emission points, and the resulting
monitoring requirements.
3.2.1 Process Vents
A HON process vent is defined as a gas stream that is
continuously discharged during the operation of an air oxidation
process, reactor process, or distillation operation within a
SOCMI chemical manufacturing process. The definition of process
vent does not include process vents from batch operations, relief
valve discharges, vents covered by the equipment leak or
wastewater provisions, and vent streams with a HAP concentration
less than 0.005 weight percent. Two process vents are associated
3-4
-------
with each of the four SOCMI processes at General Chemical: a
reactor vent and a distillation column vent. Thus, a total of
eight process vents are associated with the source. Table 3-2
gives specific data for each process vent.
Once the process vents subject to the HON are identified,
the group status of each vent must be determined, unless the
owner or operator chooses to treat all vents as Group 1 and to
comply with the Group 1 requirements which are outlined in
Section 3.2.1.1. A Group 1 process vent has a vent stream with
all three of the following characteristics: a flow rate greater
than 0.005 scmm, an organic HAP concentration greater than 50
ppmv, and a TRE index value less than or equal to 1.0. If the
vent stream of a process vent does not have any one of these
three characteristics, the vent is a Group 2 vent and not subject
to control, regardless of whether it has one or both of the other
two characteristics. As a result, an owner or operator will
typically choose to evaluate the process vent flow rate first,
since flow rate is the most straightforward group determination
criterion, followed by the organic HAP concentration. For vent 7
the flow rate is less than 0.005 scmm; therefore, the vent is a
Group 2 vent and not subject to control. The remaining streams
all have flow rates greater than 0.005 scmm and organic HAP
concentrations greater than 50 ppmv so the TRE index value must
be calculated to complete the Group I/Group 2 status
determination. The TRE index equation inputs and results are
shown in Appendix B for each vent and control option. Process
vents 4. and 8 have TRE index values above 1.0 and are, therefore,
Group 2 process vents which require no further control. Process
vents 1, 2, 3, 5, and 6 have TRE index values less than 1.0 and
are Group 1 vents.
Flow rate is measured by Method 2, 2A, 2C, or 2D of
40 CFR Part 60, Appendix A, as appropriate. The organic HAP
concentration is measured by Method 18. An alternative means of
measuring HAP concentration to determine whether concentration is
less than 50 ppmv is to use Method 25A to measure TOG; however,
if this method is used, the TOG must be less than 25 ppmv to be
considered a Group 2 vent.
3-5
-------
TABLE 3-2. GENERAL CHEMICAL PROCESS VENT INFORMATION
I
a\
Chemical
Production
Process
A
A
B
B
C
C
D
D
Vent #
1
2
3
4
5
6
7
8
Flow Rate
scmm
(scfro)
12.82
(452.7)
47.68
(1684)
0.03
(1.06)
1.66
(58.6)
0.49
(17.3)
12.22
(432)
0.004
(0.14)
2.29
(80.9)
HAP
Concentration
ppmv
302,000
91,700
279,000
1,220
458,000
17,640
N/A
5,580
TRE
Index
0.003
0.053
-0.0263a
1.256
-0.005a
0.410
N/A
1.012
Group 1 or 2
l-^'1
1
1
2
1
1
2
2
In some situations the TRE Index can be negative. For example, a vent stream with a
flow rate less than 0.5 scmm and a heat content greater than approximately 250 MJ/scm
will result in a negative value in the flare TRE equation. A negative TRE index does
not reflect a money making option, but reflects a more cost effective value than a
positive TRE index value.
-------
The TRE index is calculated based on the appropriate TRE
equations. The TRE index equations and coefficients estimate the
TRE index based on four control configurations: flare,
incineration with zero percent heat recovery, incineration with
70 percent heat recovery, or incineration (zero percent heat
recovery) with scrubbing. The RCT for a halogenated vent stream
is incineration followed by scrubbing, so only the TRE index
equation and coefficients associated with incineration with
scrubbing are used for halogenated vent streams to determine the
TRE index. For non-halogenated vent streams the owner or
operator must calculate a TRE index for each of the other three
control configurations and select the lowest of the three TRE
index values. Since none of the General Chemical vent streams
are halogenated, the incineration-with-scrubbing option was not
considered. The TRE index was calculated separately for both
flares and incinerators using their respective TRE index
equations and coefficients. The lowest TRE index value
calculated becomes the TRE index for the process vent (see
Appendix B). The inputs to the TRE index equations are flow
rate, heat content, TOC emission rate, and HAP emission rate.
These inputs can be measured and calculated using Methods 2
and 18. If the TRE index is determined to be greater than 4.0
through engineering assessment and calculations, measurement is
not required.
3.2.1.1 Control Options. There are three options available
for controlling a Group 1 process vent: (1) achieve 98 percent
emission reduction or a 20 ppmv exit concentration (product
recovery devices are considered part of the process and cannot be
included in determining compliance with this option; (2) use a
flare; or (3) achieve and maintain a TRE index greater than 1.0
(e.g., by process modification or product recovery device).
General Chemical elects to control process vents 1, 2, 3, and 5
with the 98 percent HAP emission reduction by combustion.
Combustion controls could include flares, incinerators (with or
without heat recovery), boilers, and process heaters. In this
case, the plant elects to control process vents 1 and 2 by flare,
process vent 3 by combustion in a boiler, and process vent 5 by
3-7
-------
incineration. General Chemical elects to control process vent 6
by installing a condenser to increase the TRE index to above 1.0
and, thusr make the vent a Group 2 vent requiring no further
control.
3.2.1.2 Testing and Monitoring. To ensure compliance, a
t
performance; test is required for the incinerator (Method 18). A
performance test is not required for the flare or for the boiler
because of Its size (greater than 44 MW). A compliance
determination is required for flares and includes a test to
determine visible emissions using Method 22 of 40 CFR Part 60,
Appendix A/ and the flare must meet certain specifications
contained in the General Provisions of 40 CFR Part 63 (not yet
proposed). To ensure continued compliance, the pilot flame of
the flare must be monitored. The average firebox temperature of
the incinerator must be monitored, and the average exit
temperature of the condenser must be monitored. If the TRE were
greater than 4.0, monitoring of the condenser would not be
required. All combustion devices, including boilers, must be
equipped with flow indicators, or the valves that are in any
bypass lines that could divert the emission stream from the
control device must be sealed.
3.2.1.3 Emission Reduction. The combustion devices
(i.e., the incinerator, the boiler, and the flare) achieve
98 percent destruction of HAP and VOC. The condenser removes
enough HAP to increase the TRE to greater than 1.0. In this
case, a 90 percent reduction was achieved. Table 3-3 shows both
baseline emissions (i.e., emissions prior to compliance with the
process vent provisions of the HON) and the actual emissions
after control. The baseline emissions were calculated using
equations provided in Appendix A of Volume 1C of the BID. The
emissions are provided for informational purposes and are not
necessary for determining applicability or compliance.
3.2.2 Storage
Three HAP's are stored in 20 fixed roof vessels associated
with the four SOCMI processes at General Chemical. Table 3-4
gives specific data on these 20 vessels.
3-8
-------
TABLE 3-3. EMISSIONS FROM PROCESS VENTS
U)
I
Vent Group
# 1 or 2
1 1
2 1
3 1
4 2
5 1
6 2a
7 2
8 2
Control
Method
Flare
Flare
60 MW boiler
N/A
Incinerator
with heat
recovery
Condenser
N/A
N/A
Control
Efficiency
(%)
98
98
98
N/A
98
90
N/A
N/A
Baseline
HAP
Mg/yr
(Tons/yr)
10070
(11077)
3062
(3368)
11
(12.1)
20
(22)
158
(174)
151
(166)
1.30
(1-43)
28
(31)
Actual Emissions
Emissions (After Control)
VOC
Mg/yr
(Tons/yr)
11740
(12,914)
3925
(4,317)
13
(14.3)
26
(28.6)
190
(209)
192
(211)
1.56
(1.72)
36
HAP
Mg/yr
(Tons/yr)
201.4
(221.5)
61.2
(67.3)
0.2
(0.2)
20
(22)
3.2
(3.5)
15.1
(16.6)
1.30
(1.43)
28
(40) (31)
VOC
Mg/yr
(Tons/yr)
234.9
(258.4)
78.5
(86.3)
0.3
(0.3)
26
(28.6)
3.8
(4.2)
19.2
(21.1)
1.56
(1.72)
36
(40|
a The owner or operator elected to increase the TRE index to above 1.0, thereby changing the process vent
from Group 1 to Group 2 status.
-------
TABLE 3-4. GENERAL CHEMICAL STORAGE VESSEL INFORMATION
CO
I
Tank Chemical
Farm Production
Number Process Compound
1 A Methanola
2 A Methanola
3 A Methanola
4 B Dimethyl
Formamide
5 D Triethylamine
Total
Throughput I
jB/year
(gal/year)
20,592,000
(5,440,000)
25,741,000
(6,800,000) *
2,554,000
(675,000)
4,839,000
(1,278,000)
10,216,000
(2,699,000)
63,942,000
^16,892,000)
\
lumber of Vessel Size Pr
Vessels m3
(gal) (
9 3,785
(1,000,000)
7 757
(200,000)- '"
1 38
(10,038)
1 38
(10,038)
2 38
(10,038)
/apor
assure Group
kPa 1 or 2
psia)
M ' ' ' r1 *
13.3 'VVlL'f'
(1.9)
13.3 1
" (1.9)
13.3 2
(1.9)
0.5 2
(0.1)
53.3 2
12 !>
Anhydrous methanol containing less than 4 percent water.
-------
For vessels -with capacity greater than or equal to 75 m3
(19,813 gallons), the determination of Group 1 status is based on
the vapor pressure of the stored liquid. To be a Group 1 vessel
at an existing source, a vessel must have a capacity greater than
or equal to 75 m^ (19,813 gallons) and store liquid with a vapor
pressure greater than or equal to 13.1 kPa (1.9 psia) [or greater
than or equal to35.2 kPa (0.75 psia) if the tank is greater than
151 m3 (39,890 gallons)]. For General Chemical, the four storage
vessels in tank farms 3, 4, and 5 are Group 2 storage vessels
because they all'have storage capacities of 38 m3(10,038
gallons). The remaining 16 vessels in tank farms 1 and 2 have
1
capacities greater than 151 m3 (39,890 gallons) and store
anhydrous methanbl (i.e., less than 4% water). Because methanol
»
has a vapor pressure of 13.3 kPa (1.9 psia), which exceeds the
applicability criteria of 5.2 kPa (0.75 psia) for vessels at
existing sources; each of the 16 vessels is a Group 1 vessel.
The vapor ptessure determination is based on the partial
pressure of the organic HAP's in the stored liquid at storage
temperature. If'the stored liquid is a "pure" material, then the
partial pressure"can be determined by any one of the following
methods: (1) American Petroleum Institute (API) Bulletin 2517;
(2) American Society for Testing and Materials (ASTM)
Method D2879-83;" (3) standard reference texts; or (4) any other
method approved by the EPA Administrator. If the stored liquid
is a mixture, then the vapor pressure of the mixture is
determined by summing the partial pressures of the individual HAP
components in the liquid according to the following equation:
n
VPmixture = E (*i) (VPj.)
i=l
where:
vpmixture = tne vapor pressure of the mixture;
i = a HAP component of the mixture;
Xi = mole fraction of i in the liquid; and
= vapor pressure of pure i at storage
temperature.
3-11
-------
The partial pressure of a HAP component is the product of its
pure vapor pressure and its liquid mole fraction. The vapor
pressure of pure components (VPjJ may be determined by the ASTM
or API methods or other references indicated above for vapor
pressure determination of "pure" liquids.
3.2.2.1 Control Options. There are several options
available for controlling the Group 1 storage vessels in order to
comply with the requirements of the HON: (1) equip the storage
vessel with an internal floating roof having double seals or a
single liquid-mounted seal; (2) convert an external floating roof
to an internal floating roof having double seals or a single
liquid-mounted seal; (3) equip the storage vessel with an
external floating roof having double seals; ~r (4) equip the
storage vessel with a closed vent system and control device which
reduces organic HAP emissions by 95 percent.
For this case study, General Chemical will equip the nine
Group 1 vessels in tank farm 1 with internal floating roofs with
double seals and the remaining seven Group 1 vessels in tank
farm 2 with a closed vent system and a condenser.
3.2.2.2 Testing and Monitoring. For Group 2 storage
vessels, monitoring and testing are not required. A record of
Group 2 storage vessel dimensions and any analysis of capacity
must be kept. For Group 1 storage vessels, monitoring and
inspections are required depending on the control option used.
Performance tests are not required for use of any of the control
options for Group l storage vessels. A design analysis is
required for any control device. Monitoring requirements for an
internal floating roof with double seals include one of the
following two options: (1) an internal inspection every five
years; or (2) an internal inspection every ten years and an
external inspection annually. The monitoring and testing
required for a closed vent system include a leak test using
Method 21 and a visual inspection while filling a storage vessel.
For a condenser, the parameters established in the Implementation
Plan or operating permit must be monitored.
3-12
-------
3.2.2.3 Emission Reduction* The emission reduction
achieved byr application of an internal floating roof to a storage
vessel varies according to the number of turnovers and the vapor
pressure and molecular weight of the stored material. Table 3-5
shows both the baseline emissions (i.e., emissions prior to
compliance with the storage provisions of the HON) and the actual
emissions after control. The baseline emissions were calculated
based on equations given in Appendix C of Volume 1C of the BID.
Because each stored liquid is both a HAP and a VOC, HAP and VOC
emissions are the same. The emissions are given for
informational purposes only and are not necessary for determining
applicability or compliance.
3.2.3 Transfer
Three HAP's are transferred in two racks at General
Chemical. Rack 1 has an average rack vapor pressure of 15.0 kPa
(2.2 psia) and transfers 18,800,000 £/yr (4,967,000 gal/yr) into
railcars. Rack 2 has an average rack vapor pressure of 15.8 kPa
(2.3 psia) and transfers 8,480,000 £/yr (2,240,000 gal/yr) into
tank trucks. Methanol, dimethyl formamide, and triethylamine are
transferred at both racks. Table 3-6 gives specific data for
racks 1 and 2 on a chemical basis.
The determination of Group I/Group 2 status is based on
total HAP throughput and average rack HAP vapor pressure. Group 1
transfer racks have a total HAP throughput greater than or equal
to 650,000 t/yr (172,000 gal/yr) and an average rack weighted HAP
vapor pressure greater than 10.3 kPa (1.5 psia). Therefore, the
racks at General Chemical are both Group 1 racks.
3.2.3.1 Control Options. There are several options
available for controlling Group 1 racks. The HON transfer
provisions require that a control system be used consisting of a
vapor collection system and a control device. The control device
can be a vapor balancing system, a flare, or a control device
which reduces organic HAP's by 98 percent or to an exit
concentration of 20 ppmv, whichever is less stringent. A
combustion device (e.g., incinerator, boiler, or process heater)
or a recovery device (e.g., absorber, condenser, or carbon
adsorber) can be used to meet the 98 percent or 20 ppmv
3-13
-------
TABLE 3-5. EMISSIONS FROM STORAGE VESSELS
u>
I
Actual Emissions
Baseline Emissions (after control)
Mg/yr Mg/yr
(ton/yr) (ton/yr)
Tank
Farm
Number
1
2
3
4
5
Total
Control
Group Control Efficiency
1 or 2 Method (%)
1 IFR 95
1 Condenser 95
2 None N/A
2 None N/A
2 None N/A
HAP
61.5
(67.6)
37.7
(41.5)
0.32
(0.35)
0.04
(0.04)
13.9
[15.31
113.5
(J.24.8)
VOC
61.5
(67.6)
37.7
(41.5)
0.32
(0.35)
0.04
(0.04)
13.9
tiS^lL-j
113.5
(124.8)
HAP
3.1
(3.4)
1.9
(2.1)
0.32
(0.35)
0.04
(0.04)
13.9
H- L1JL-3-L-
19,3
(21.2)
VOC
3.1
(3.4)
1.9
(2.1)
0.32
(0.35)
0.04
(0.04)
13.9
...QAliL...
19.3
(21.2)
IFR - Internal Floating Roof
-------
TABLE 3-6. GENERAL CHEMICAL TRANSFER RACK INFORMATION
u>
I
]
Vapor
Chemical Pressure
Production kPa
Process Compound (psia)
A Methanol 13.3
(1.9)
B Dimethyl Formamide 0.5
(0.1)
D Triethylamine 53.1
______ 17 -7J
Rack Total/Average 15. Oa
(2.2)
Rack 1 (Railcar)
Throughput
-/yr Group 1
(gal/yr) or 2
17,735,000
(4,685,000)
204,000
(54,000)
863,000
^228_COOOJL j
18,800,000 1
(4,967,000)
Rac
Vapor
Pressure
kPa
(psia)
13.3
(1.9)
0.5
(0.1)
53.1
u (1-11.
15. 8a
(2.3)
k 2 (Tank truck)
Throughput
£/yr Group 1
(gal/yr) or 2
7,780,000
(2,054,000)
136,000
(36,000)
568,000
(ISOfiOOO)
8,480,000 1
(2,240,000)
a Rack weighted average vapor pressure is weighted by throughput. For example the average vapor pressure
for Rack 1 was calculated as follows:
{(13.3 kPa) (17,735,000 */yr) + (0.5 kPa) (204,000 -Yyr) + (53.1 kPa) (863,000 £/yc)}/(18,800,000 £/yr).
-------
requirement. For this example, General Chemical will use a flare
to comply with the HON transfer provisions for both Group 1
racks.
3.2.3.2 Testing and Monitoring. For Group 2 transfer
racks, monitoring and testing are not required; however, records
of total HAP throughput and average rack weighted HAP vapor
pressure are required. For Group 1 transfer racks monitoring and
testing are required, depending on the control option used. A
performance test is not required for use of a flare; however, a
compliance determination including a Method 22 test is required
for determining if there are visible emissions. A flare must
also meet the requirements in 40 CFR 63.1l(b) which include
monitoring of the pilot flame. (The provisions of
40 CFR 63.ll(b) are identical to the provisions of 40 CFR 60.18.)
3.2.3.3 Emission Reduction. The flare applied to
racks 1 and 2 reduces HAP and VOC emissions by 98 percent.
Table 3-7 shows both the baseline emissions (i.e., emissions
prior to compliance with the transfer provisions of the HON) and
the actual emissions after control. The baseline emissions were
calculated based on equations given in Appendix B of Volume 1C of
the BID. Because each transferred liquid is both a HAP and a
VOC, the HAP and VOC emissions are the same. The emissions are
given for informational purposes and are not necessary for
determining applicability or compliance.
3.2.4 Wastevater
At General Chemical, the four chemical production processes
generate eight organic HAP-containing wastewater streams. If
General Chemical produced a process wastewater stream that did
not contain any organic HAP's, the stream would not be subject to
the HON wastewater provisions. For this case study, however, all
eight wastewater streams contain organic HAP's and therefore,
must be evaluated. Wastewater stream parameters are presented in
Table 3-8.
At this existing source, the owner or operator must first
determine whether the source's total mass flow rate of HAP's
exceeds 1 Mg/yr (1.1 tpy). If the source's total mass flow rate
did not exceed 1 Mg/yr, no control would be required. Since
3-16
-------
TABLE 3-7. EMISSIONS FROM TRANSFER RACKS
u>
I
Actual Emissions
Baseline Emissions (after control)
Mg/yr Mg/yr
(Tons/yr) (Tons/yr)
Control
Group Efficiency
Rack 1 or 2 Control (%) HAP
1 1 Flare 98 2.40
(2.64)
2 1 Flare 98 1.21
(1.33)
Total 3.61
(3.97)
VOC
2.40
(2.64)
1.21
(1.21)
3.61
(3.97)
HAP
0.05
(0.05)
0.02
(0.03)
0.07
(0.08)
VOC
0.05
(0.05)
0.02
(0.03)
0.07
^0.08)
-------
TABLE 3-8. GENERAL CHEMICAL WASTEWATER STREAM PARAMETERS
I
H
00
Chemical
Production
Process
A
A
B
B
B
C
D
D
Stream
ID
Number
1
2
3
4
5
6
7
8
VOHAP
Concentration
ppmw
30
1,280
1,070
80
780
1300
80
1,200
Flow Rate
£pm
(gal/min)
90
(24)
120
(32)
0.1
(0.03)
10
(3)
0.1
(0.03)
90
(24)
30
(8)
20
(5)
Group
1 or 2
2
1
2
2
2
1
2
1
-------
General Chemical's total mass flow rate does exceed 1 Mg/yr, the
company must determine the Group I/Group 2 status of the eight
process wastewater streams. For a process wastewater stream to
be a Group 1 stream it must meet one of the following criteria:
(1) the stream's VOHAP concentration is greater than or equal to
10,000 ppmw or (2) the stream's VOHAP concentration is greater
than or equal to 1,000 ppmw, and its flow rate is greater than or
equal to 10 £pm (2.6 gal/min). Based on these criteria,
streams 2, 6 and 8 are Group 1 streams.
Each stream was assessed to determine the VOHAP
concentration, as measured by the proposed Method 305, and the
average flow rate for each respective point of generation. The
point of generation is the location where the wastewater stream
exits the process unit component, product tank, or feed storage
tank prior to mixing with other wastewater streams or handling or
treatment in a piece of equipment, which is not an integral part
of the process unit. The average flow rate may be determined by
any one of the three following procedures: (1) selecting the
highest average flow rate from the past five years of historical
records; (2) using maximum production capacity to estimate the
flow rate; or (3) measuring the flow rate of the wastewater at
the point of generation during conditions that represent the
average flow rate. General Chemical estimated the average flow
rate for each wastewater stream using the third method.
3.2.4.1 Control Options. There are several options
available for controlling the Group 1 wastewater streams at
General Chemical. The provisions for wastewater operations
require control by one of the following methods: (1) recycle to
the process; (2) treat with a design steam stripper; (3) treat to
achieve 99 percent reduction in total VOHAP mass flow rate;
(4) treat to achieve target percent reductions in mass flow rates
for each strippability group of HAP's; (5) treat to achieve a RMR
or (6) treat to achieve a total VOHAP concentration less than
50 ppmw. In addition, the provisions for wastewater operations
require control of the vapors from all treatment and management
units. For stream 2, General Chemical will install and operate a
steam stripper that meets the design requirements of the
3-19
-------
wastewater provisions. Stream 6 will be recycled to the original
process. Emissions from stream 8 will be controlled in a
biodegradation unit to achieve a RMR.
3.2.4.2 Testing and Monitoring. A performance test is not
required for a steam stripper if it is designed according to
§63.138(f) of the provisions for wastewater operations. However,
continuous parameter monitoring is required, for the following:
steam flow rate, wastewater feed mass flow rate, wastewater feed
temperature, and condenser vapor outlet temperature.
Biodegradation units require a performance test using proposed
Method 304 and WATER? (this computer program can be accessed via
the OAQPS bulletin board system; see Appendix A for details) to
determine biodegradation rate constants which characterize the
operation of properly operated biotreatment units. Actual mass
removal measured by this method is compared with required mass
removal calculated according to the wastewater provisions.
Monthly monitoring of biodegradation units is also required. The
monitoring parameters for biodegradation are established on a
source-by-source basis. For the stream being recycled back to
the process, a performance test is not required. Annual leak
inspections using Method 21 and visual inspections are also
required for all covers and openings for waste management units.
Group 2 streams are not subject to monitoring requirements, but
General Chemical must maintain records documenting that the
streams are not Group 1.
3.2.4.3 Emissions Reductions. The design steam stripper
applied to wastewater stream 2 achieves an 83-percent reduction
in mass flow rate. By recycling stream 6 back to the original
process, complete (i.e., 100 percent) emission reduction is
achieved. Through the application of biodegradation, emissions
from stream 8 are reduced by 90 percent. Table .3-9 shows the
baseline emissions (i.e., emissions prior to compliance with the
HON provisions for wastewater operations) and the actual
emissions from wastewater streams after control. The baseline
emissions were calculated based on equations provided in
Appendix D of Volume 1C of the BID. Again, the emissions are
given for informational purposes and are not necessary for
3-20
-------
TABLE 3-9.
EMISSIONS FROM WASTEWATER STREAMS
I
N)
Baseline Emissions Emissions after Control
Mg/yr Mg/yr
(Tons/yr) (Tons/yr)
Stream
ID Number
1
2
3
4
5
6
7
8
Group
1 or 2
2
1
2
2
2
1
2
1
Control
Method
None
Design Steam
Stripper
None
None
None
Recycled to
Process
None
Biodegradation
Control
Efficiency
(*)
N/A
83
N/A
N/A
N/A
100
N/A
90
HAP
1.0
(1.1)
57
(63)
0.1
(0.1)
0.3
(0.3)
0.1
(0.1)
2.4
(2.6)
0.8
(0.9)
8.6
(9.5)
VOC
4
(4)
210
(231)
0.1
(0.1)
1.1
(1-2)
0.1
(0.1)
8.8
(9.7)
3.1
(3.4)
32
(35)
HAP
1.0
(1.1)
10
(11)
0.1
(0.1)
0.3
(0.3)
0.1
(0.1)
0
(0)
0.8
(0.9)
0.86
(0.95)
'' '*-;-
VOC
4
(4)
36
(40)
0.1
(0.1)
1.1
(1.2)
0.1
(0.1)
0
(0)
3.1
(3.4)
3.2
(3.5)
-------
determining applicability or compliance.
3.2.5 Reference Control Technology Case Study 8\
Table 3-10 summarizes the control technique chosen by
General Chemical for each Group 1 emission point along with the
control efficiency, baseline emissions, and the emissions after
control. If General Chemical decides to control all of its
Group 1 emission points by using the specified controls, total
HAP emissions after control would be 363 Mg/yr (399 tpy).
3.3 EMISSIONS AVERAGING CASE STUDY
Emissions averaging allows owners and operators to achieve
the emission reductions required by the HON in a way that
reflects their site-specific control costs. As a result,
emissions averaging allows for more cost-effective compliance
with the HON.
In putting together an emissions averaging scenario, the
owner or operator has to calculate and balance their debits and
credits. Credits must equal or outweigh debits. Debits are
associated with the Group 1 emission points that the source would
prefer not to control to the level of the RCT. Credits are
associated with other emission reductions (i.e., control of a
Group 2 emission point, or "over-control" of a Group 1 emission
point) that the source uses to make up for the excess emissions
at the uncontrolled or "under-controlled" Group 1 points.
Section 2.7 of this document summarizes the emissions averaging
provisions and the debit and credit concepts.
The fictitious company, General Chemical, is again the basis
of the case study, which illustrates one example of how a source
could use emissions averaging to comply with the HON. See
Section 3.1 and 3.2 for details on the chemical production
processes and the specific emission points at the source. In
this case study, eleven emission points within the source are
involved in an emissions average. The other points are
controlled with the control devices described in Section 3.2.
Emissions averaging calculations are done only for the eleven
points involved in the averaging.
3-22
-------
TABLE 3-10. BASELINE EMISSIONS AND EMISSIONS AFTER CONTROL FOR GENERAL CHEMICAL
u>
I
NJ
U)
Baseline Emissions
Mg/yr
(Tons/yr)
Emission ID
Point Number
Storage Tank 1
Farms
2
3
4
5
Transfer 1
2
Vents 1
2
3
4
5
6
Group
1
1
2
2
2
1
1
1
1
1
2
1
2
Control
Method
IFR
Condenser
Flare
Flare
Flare
Flare
60 MW Boiler
Incinerator
with Heat
Recovery
Condenser
Control
Efficiency
(*)
95
95
98
98
98
98
98
"""
98
90
HAP
61.5
(67.6)
37.7
(41.5)
0.32
(0.35)
0.04
(0.04)
13.9
(15.3)
2.40
(2.64)
1.21
(1.33)
10,070
(11,077) (
3,062
(3,368)
11
(12)
20
(22)
158
(174)
151
(166)
voc
61.5
(67.6)
37.7
(41.5)
0.32
(0.35)
0.04
(0.04)
13.9
(15.3)
2.40
(2.64)
1.21
(1.33)
11,740
12,914)
3,925
(4,317)
13
(14)
26
(29)
190
(209)
.192
(211)
Emissions
After Control
Mg/yr
(Tons/yr)
HAP
3.1
(3.4)
1.9
(2.1)
0.32
(0.35)
0.04
(0.04)
13.9
(15.3)
0.05
(0.05)
0.02
(0.03)
201.4
(221.5)
61.2
(67.3)
0.2
(0.2)
20
(22)
3.2
(3.5)
15.1
(16.6)
VOC
3.1
(3.4)
1.9
(2.1)
0.32
(0.35)
0.04
(0.04)
13.9
(15.3)
0.05
(0.05)
0.02
(0.03)
234.9
(258.4)
78.5
(86.3)
0.3
(0.3)
26
(29)
3.8
(4.2)
19.2
(21.1)
-------
TABLE 3-10.
BASELINE EMISSIONS AND EMISSIONS AFTER CONTROL FOR GENERAL CHEMICAL
(CONCLUDED)
Baseline Emissions
Mg/yr
(Tons/yr)
Emission ID
Point Number
7
8
Wastewater 1
2
3
4
5
6
7
8
Total
Group
2
2
2
1
2
2
2
1
2
1
Control
Control Efficiency
Method (%) HAP
1.30
(1.43)
28
(31)
1.0
(1.1)
Design Steam 83 57
Stripper (63)
0.1
(0.1)
0.3
(0.3)
0.1
(0.1)
Recycled to 100 2.4
Process (2.6)
0.8
(0.9)
Biodegradation 90 8.6
(9.5)
13,689 16
(15,058) (18
VOC
1.56
(1.72)
36
(40)
4
(4)
210
(231)
0.1
(0.1)
1.1
(1.2)
0.1
(0.1)
8.8
(9-7)
3.1
(3.4)
32
(35)
,500
,149)
Emissions
After Control
Mg/yr
(Tona/yr)
HAP
1.30
(1.43)
28
(31)
1.0
(1.1)
10
(11)
0.1
(0.1)
0.3
(0.3)
0.1
(0.1)
0
(0)
0.8
(0.9)
0.86
(0.95)
363
(399)
VOC
1.56
(1.72)
36
(40)
4
(4)
36
(40)
0.1
(0.1)
1.1
(1.2)
0.1
(0.1)
0
(0)
3.1
(3.4)
3.2
(3.5)
467
(515)
IFR - Internal Floating Roof
-------
3.3.1 General chemical Emissions Averaging paciaion
In deciding upon an emissions averaging plan, a facility's
motivation to consider emissions averaging might be that they
have an emission point that would be easily "over-controlled" or
particular Group 1 emission points that would be difficult or
costly to control. Whatever the trigger to consider emissions
averaging, it will be a unique decision based on the site
specific situation including factors such as: location of
emission points, equipment on site, corporate philosophy, future
expansion plans., and many other criteria which are impossible to
predict for the full set of sources. In the case of General
Chemical, the facility would like to avoid controlling the two
Group 1 transfer racks and as many of the Group 1 storage vessels
as possible. These emission points are relatively costly to
control; not controlling these points would also eliminate the
need to monitor and inspect the equipment associated with the
Group 1 storage vessels (nine vessels in tank farm 1 and seven
vessels in tank farm 2) and the two transfer racks.
In determining what is available as a credit to balance the
debits, the source would look at the other Group 1 and Group 2
points to determine how credits could be generated. Further
information on how to determine which emission points would
generate credits is contained in Section 2.7 of this document.
In this case, the source asks the following questions:
Are there Group 1 or Group 2 points already controlled
by a pollution prevention measure implemented after
1987?
Are there Group 1 or Group 2 points already controlled
by a device installed as part of an early reduction or
33/50 commitment, and installed before
November 15, 1990?
Since General Chemical did not participate in the early
reduction program or a 33/50 commitment and did not install a
pollution prevention measure after 1987, there are no credits
available from these programs. The source then asks the
3-25
-------
SOCMI Process
Unit A
SOCMI Process
UnltB
I
NJ
Stream A-1 21pm, 2400 ppmw
Stream A-2 20 ipm, 200 ppmw
Stream A-3 17 1pm, 350 ppmw
Stream B-1 72 Ipm, 230 ppmw
Recycle to Process
Manhole
Stream B-2 *13 ipm, 1600 ppmw
Stream B-3 101 pm, 5 ppmw
Steam Stripper
(98%
Reduction)
To
"POTW
SOCMI Process J
UnHC S
Stream C-1 *
Stream C-2
Stream C-3
Stream C-4 *
151pm, 1000 ppmw
25 Ipm, 700 ppmw f
2 Ipm, 700 ppmw V
10 Ipm, 3500 ppmw ^
QW
-N Manhole ^
^ Manhole
Junction
Box
* Indicates Group 1 Piocasa WwUnmtar Stream
Figure 4-1. XYZ Chemical Company Schematic
-------
3.3.2 The Credit and Dabit Calculations
The credit and debit calculations are based on
determinations of the allowed and actual emissions for each
emission point in the emissions average. Allowed emissions are
defined from the perspective of a facility not using emissions
averagingthe emissions that would be allowed under the rule for
each emission point. The actual emissions are the emissions that
will occur once the emissions averaging control scenario is in
place. Credits and debits are generated depending on the
difference between the allowed and actual emissions.
3.3.2.1 Credits. A credit is generated when the actual
emissions are less than the allowed emissions for a Group 1 or
Group 2 emission point. The amount of the credit depends on the
difference between allowed emission and actual emissions.
Credits can be generated by "over-controlling" Group 1 points, or
by controlling Group 2 points. To get the final credit used in
emissions averaging, the difference between allowed emissions and
actual emissions is discounted. The proposed emissions averaging
provisions propose a discount factor between 0.8 and 1.0. A
single factor will be selected at promulgation. The following
credit equation shows the relation between the allowed and actual
emissions (A list of each term of the equation with its meaning
and units is in Appendix C.):
n
Credits = D £ ((0.02) EPVliu - EPVliACTUAL) +
f=l
m n
D £ (EPV2iBASE - EPV2iACTUAL) + D £ ( (0.05) ESliu -
m n
ES1iACTUAL> + D E (ES2iBASE ~ ES2iACTUAL) + D E ( (0'02)
1^1 1^1
m n
ETRliu - ETRliACTUAL) + D V (ETR2iBASE -ETR2iACTUAL) + D £
1=1 1=1
m
(EWWlic - EWWliACTUAL) + D V; (EWW2iBASE - EWW2iACTUAL)
1 = 1
3-27
-------
option. The characteristics of streams from Process Units A and
C are given in Table 4-1. Streams A-l, A-2, A-3, C-2 and C-3 are
Group 2 streams because they are below the concentration and flow
levels presented in Section 63.132(f). Streams C-l and C-4 are
Group l streams, so the RMR is calculated based on only these two
streams. Group 1 determination is not necessary for Process
Unit B streams because all streams from Process Unit B are in
compliance through the use of the Process Unit alternative
treatment option, which is discussed in Section 4.2 of this fact
sheet.
Stream C-l
RMR (C-l) - (1 Mg/m3) (7,875 m3/yr) (1 * 1CT6)
* [(350 * 95/100) -I- (650 * 70/100)]
RMR (C-l) = 6.20 Mg/yr
Stream C-4
RMR (C-4) = (1 Mg/m3) (5250 m^/yr) (1 * 10'6)
* [(750 * 99/100) + (750 * 95/100)
+ (1500 * 70/100) + (500 * 99/100) ]
RMR (C-4) = 15.75 Mg/yr
Total
RMR (Total) » RMR (C-l) + RMR (C-4)
RMR (Total) - 6.20 + 15.75
RMR (Total) = 21.95 Mg/yr
4-4
-------
uncontrolled emissions, and the emissions from points with the
baseline level of control applied (EPV2iBASE) are a1^ tne same.
(For Group 2 points used to generate credits, the allowed
emissions and emissions at the baseline level of control are
always the same.) The company determined these allowed emissions
by performing the calculations required in the emissions
averaging credit calculation provisions in S63.l50(g)(2).
Appendix D shows the calculation of the allowed emissions for
process vent 8.
The flare that is being applied to the two process vents is
a RCT and reduces uncontrolled emissions by 98 percent, meaning
that only 2 percent of the uncontrolled emissions will be emitted
after control. Therefore, actual emissions will be 0.02 times
the uncontrolled emissions or 0.4 Mg/yr (20*0.02) for process
vent 4, and 0.6 Mg/yr (28*0.02) for process vent 8. Assuming a
discount factor of 0.9 for this example, the credit from
controlling process vents 4 and 8 is:
(0.9*((20-0.4)+(28-0.6))) = 42.3 Mg/yr
Table 3-11 summarizes the credit calculation. See the emissions
averaging provisions in §63.150(g) for a detailed description of
how to calculate credits for each emission point.
3.3.2.2 Debits. A debit occurs when the actual emissions
are greater than the allowed emissions. Actual emissions can
never be greater than allowed emissions for Group 2 points,
because HON does not require control of Group 2 points.
Therefore, Group 2 points can not generate a debit. A debit can
only be generated by not controlling or "under-controlling" a
Group 1 emission point. A Group 1 point is "under-controlled" if
it is controlled by a device less efficient than the RCT
3-29
-------
To determine the MR achieved by the biological treatment
unit, the mass flow rate of HAP's entering (Eb) and exiting (Ea)
the treatment process must be determined and then multiplied by
the fraction of each chemical that would be biodegraded (Fbio).
The theoretical fraction of HAP's entering the biological
treatment unit which is biodegraded, Fbio/ must be calculated
using WATER?, with the site-specific biorate factors developed
using proposed Method 304 of Appendix A in 40 CFR Part 63.
Table 4-2 contains the stream characteristics for Process Units A
and C that are necessary for calculating total MR. (Note that
the Fbi0 values and the Ea values used in this example are for
illustrative purposes only and have not been rigorously
developed.) Actual mass removal of HAP's from streams A-l, A-2,
A-3, C-l, C-2, C-3, and C-4 is calculated below:
MR = (Eb - Ea) * Fbio
Where:
MR = Actual mass removal by the treatment process or
series of treatment processes of total VOHAP for
Table 9 HAP compounds or VOHAP from Table 8 HAP
compounds, kg/hr.
Eb = Mass flow rate of total VOHAP for Table 9 HAP
compounds or VOHAP from Table 8 HAP compounds
entering the treatment process or series of
treatment processes, kg/hr.
Ea = Mass flow rate of total VOHAP for Table 9 HAP
compounds or VOHAP from Table 8 HAP compounds
exiting the treatment process or series of
treatment processes, kg/hr.
Fbio = Tne fraction of VOHAP from Table 8 HAP compounds,
or total VOHAP for Table 9 HAP compounds,
biodegraded in a properly operated biological
treatment unit. This fraction shall be determined
using WATER?. The site specific biorate constants
used as inputs to WATER? shall be determined by
using Method 304 of Appendix A of Part 63.
4-6
-------
efficiency. The following debit equation shows the relation
between the actual and allowed emissions (A list of each term of
the equation with its meaning and units is in Appendix E) :
n n
Debits = £ (EPViACTUAL - (0.02) EPViJ + £ (ESiACTUAL
n
(0.05)ESiu) * £ (ETRiACTUAL - (0.02) ETRiu)
i-1
n
E (^iACTDAL ~ EWWic)
The allowed emissions for Group l points are the residual
emissions after a device achieving an emission reduction equal to
the RCT efficiency is applied (98 percent for process vents and
transfer, 95 percent for storage vessels, and a calculated
reduction for wastewater) . For instance in the equation above,
for a Group 1 storage vessel, the allowed emissions are equal to
0.05 (the residual after a 95 percent efficient device has been
applied) times the uncontrolled emissions ( (0.05) ESliu) .
The actual emissions are the emissions that the point will
actually emit once the emissions averaging control scenario is in
place. Actual emissions refers to the emissions once the control
technology (if any) is applied to the debit generating point. In
most cases the control technology applied will be no control. In
the other cases it will be a control technology that "under-
controls" the Group 1 point generating the debit.
In this case study, General Chemical will not control the
two Group 1 transfer racks or the Group 1 storage vessels in
tank farm 2 (seven vessels) which will generate debits. There
are no wastewater streams or process vents generating debits;
therefore, only a small part of the debit equation is needed to
3-31
-------
Stream A-l
MR(A-l) = [(0.07kg/hr - O.Olkg/hr) * 0.06]
+ [(0.22kg/hr - 0.002kg/hr) * 0.25]
MR(A-l) = 0.06
Stream A-2
MR(A-2) - (0.24kg/hr - 0.15kg/hr) * 0.5
MR(A-2) = 0.05
Stream A-3
MR(A-3) = (0.36kg/hr - O.Olkg/hr) * 0.87
MR(A-3) = 0.31
Stream C-l
MR(C-l) = [(0.32kg/hr - 0.09kg/hr) * 0.81]
+ [(0.59kg/hr - 0.12kg/hr) * 0.9)]
MR(C-l) = 0.61
Stream C-2
MR(C-2) = [(0.81kg/hr - 0.22kg/hr) * 0.81]
+ [(0.24kg/hr - 0.18kg/hr) * 0.86]
MR(C-2) = 0.53
4-8
-------
debits for the two transfer racks and the seven storage vessels
in tank farm 2 are:
(2.40-0.05)+(1.21-0.02)^(37.7-1.9) = 39.3 Mg/yr.
Table 3-12 summarizes the debit calculation. See the
emissions averaging provisions in S63.150(f) for a detailed
description of how to calculate debits for process vents and
other kinds of emission points.
3.3.3 Emi?lfi?n Averaging Case sty^y ffMMIIflrT
Since the credits (42.3 Mg/yr) are greater than the debits
(39.3 Mg/yr), General Chemical can emissions average by
controlling the Group 2 process vents 4 and 8 instead of the two
Group l transfer racks and the seven Group 1 storage vessels at
tank farm 2. With the 3.0 Mg/yr (42.3-39.3) additional credits,
General Chemical could choose to balance debits from not
controlling a storage vessel in tank farm 1. However, General
Chemical decides to control tank farm 1 and keep the excess
credits so that these credits can be banked and be available to
fall back on if a problem occurs with their emissions average
(for example, if the operating hours of the credit generating
Group 2 process vents are lower than expected, or the storage
tank or transfer rack emissions are greater than expected).
Table 3-13 shows the control method, the control efficiency,
actual emissions, and emissions after control for each emission
point at General Chemical including those points used in the
emissions average. Table 3-10 showed this information assuming
all points are controlled with an RCT. Comparing
Tables 3-10 and 3-13, the total HAP emissions after control are
363 and 355 Mg/yr, respectively, showing that emissions averaging
will result in at least as much emission reduction as using the
RCT on each Group 1 emission point.
3.3.4 Compliance. Banking. Monitoring. Recordkeepina. and
Recording
Debits and credits must balance on an annual basis; however,
sources must maintain records of their emissions averaging
credits and debits on a monthly basis. Also, a quarterly check
3-33
-------
4.2 PROCESS UNIT ALTERNATIVE TREATMENT OPTION
This example illustrates compliance through the use of the
process unit alternative treatment option, which is discussed in
§63.138(d). If this option is chosen as the method of
compliance, the owner/operator must ensure that all individual or
combined wastewater streams in a process unit achieve a total
VOHAP concentration of less than 10 ppmw prior to contact with
ambient air or combination with streams from other process units.
The option must be used for all process wastewater streams from
the process unit, and no Group I/Group 2 determination for
stareams within that unit is required. At the XYZ Chemical
Company, the process unit alternative compliance option is
applied to one process unit (i.e., Process Unit B) containing
three wastewater streams. The point of generation
characteristics of these three streams are summarized in
Table 4-3.
Stream B-3 meets the requirements because its VOHAP
concentration (5 ppmw) at the point of generation was already
below the process unit alternative threshold; therefore, no
further treatment is required. To comply with the process unit
alternative treatment provisions, streams B-l and B-2, after
being combined in a junction box, are hard-piped to a steam
stripper for a product recovery of 98 percent. A strippability
efficiency of 98 percent was assumed for the purpose of this
example. A steam stripper with a different strippability
efficiency (e.g., 85%) also could be used for this compliance
option as long as the total VOHAP concentration in the discharged
streams is < 10 ppmw. since they are hard-piped, there is no
contact with ambient air, and they are not combined with
wastewater streams from other process units. Furthermore, the
equipment components up to and including the steam stripper have
been properly enclosed to suppress emissions. The VOHAP
concentration of the steam stripper effluent is 9 ppmw.
Therefore, the effluent meets the requirements.
4-10
-------
TABLE 3-13.
BASELINE EMISSIONS AND EMISSIONS AFTER CONTROL UNDER THE EMISSIONS AVERAGING
SCENARIO FOR GENERAL CHEMICAL
U)
I
CJ
01
Emission ID
Point Number
Storage Tank 1
Farms
2
3
4
5
Transfer 1
2
Vents 1
2
3
4
5
6
Group
1
1
2
2
2
1
1
1
1
1
2
1
2
Control
Method
IFR
*
Flare
Flare
6O MW Boiler
Flare
Incinerator
with Heat
Recovery
Condenser
Baseline Eminions
Mg/yr
Control (Tona/yr)
Efficiency
(%) HAP
95 61.5
(67.6)
37.7
(41.5)
0.32
(0.35)
0.04
(0.04)
13.9
(15.3)
2.40
(2.64)
1.21
(1.33)
98 10,070
(11,077)
98 3,062
(3,368)
98 11
(12)
98 20
(22)
98 158
(174)
90 151
(166)
voc
61.5
(67.6)
37.7
(41.5)
0.32
(0.35)
0.04
(0.04)
13.9
(15.3)
2.40
(2.64)
1.21
(1.33)
11,740
(12,914)
3,925
(4,317)
13
(14)
26
(29)
190
(209)
192
(211)
Kmi.mmi.onm
After Control
Mg/yr
(Tons/yr)
HAP
3.1
(3.4)
37.7
(41.5)
0.32
(0.35)
0.04
(0.04)
13.9
(15.3)
2.40
(2.64)
1.21
(1.33)
201.4
(221.5)
61.2
(67.3)
0.2
(0.2)
0.4
(0.4)
3.2
(3.5)
15.1
(16.6)
VOC
3.1
(3.4)
37.7
(41.5)
0.32
(0.35)
0.04
(0.04)
13.9
(15.3)
2.40
(2.64)
1.21
(1.33)
234.9
(258.4)
78.5
(86.3)
0.3
(0.3)
0.5
(0.6)
3.8
(4.2)
19.2
(21.1)
-------
on the balance between debits and credits is required and debits
cannot exceed credits by more than 25-35 percent in any one
quarter (a single value for the quarterly variability factor will
be selected for the final rule) . Quarterly reports are required
to show the most recent credit and debit calculations.
One way a source can meet the annual compliance requirements
for the proposed rule involves the use of "banked" emission
credits. The proposed rule allows sources to bank their extra
credits for 2-5 years if they generate more credits than are
necessary to offset the debits from a given annual compliance
period (a single value for the bankable period will be selected
for the final rule). These banked credits are available for use
in future compliance periods when the source has generated more
debits than credits. Section 63.150(e) of Subpart G details how
banked credits can be generated and used. Banked credits can
only be used to meet the annual compliance requirement; they
cannot be used for the quarterly compliance requirement.
As described in Section 2.8, the HON requires five types of
reports: Initial Notification, Implementation Plan, Notification
of Compliance Status, Periodic Reports; and Other Reports. The
first report submitted to the "Administrator" containing
information about emissions averaging is the Implementation Plan
for the points in the average. For existing sources, this plan
is due 18 months prior to the compliance date unless an operating
permit application containing the information has been submitted
by that date. For all existing sources, except those who have
received case-by-case extensions from the EPA Administrator,
18 months before the compliance date is the same as 18 months
after the promulgation of the HON. The Implementation Plan for
the emissions averaging points must include the projected debits
and credits for each emission point involved in the average, the
specific control technology or pollution prevention measure that
will be applied to each emission point, and some additional
information on the specific emission points in the average. In
this case study, General Chemical must submit information on the
eleven emission points involved in the average.
3-37
-------
Chemical Manufacturing Facilities Including the HON Impacts Analysts
State City
Facility Name
Production Process
AK
AL
At
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AR
AR
AR
AR
AR
CA
CA
KENAI
ANDALUSIA
ANNISTON
BIRMINGHAM
BUCKS
BURKEVILLE
CHEROKEE
COLO CREEK
OECATUR
DECATUR
OEHOPOLIS
LE MOYNE
THEODORE
THEODORE
THEODORE
BLYTHEVILLE
CROSSETT
EL DORADO
MAGNOLIA
HALVERN
ANAHEIM
ANTIOCH
UNOCAL CORPORATION
CHEHBOND CORP
MONSANTO CORPORATION
WALTER INDUSTRIES
HOECHST CELANESE CORPORATION
GENERAL ELECTRIC
LA ROCHE INDUSTRIES
1C I /RUBICON
AMOCO CHEMICAL
MONSANTO CORPORATION
BORDEN CHEMICAL
AKZO CHEMICALS
DEGUSSA CORP
OEGUSSA CORPORATION
PEGUSSA
FREEPORT - HCHORAN
GEORGIA-PACIFIC
GREAT LAKES
ETHYL CORPORATION
BTL SPECIALTY RESINS
STEPON CO.
DU PONT
* UREA VIA CONDENSATION OF AMMONIA AND CARBON DIOXIDE
FORMALDEHYDE VIA AIR OXIDATION OF HETHANOL
BIPHENYL VIA DEHYDROGENATION OF BENZENE
BENZENE SULFONIC ACID VIA SULFONATION 1 CONTINUOUS EXTRACTION
BENZENE SULFONIC ACID VIA SULFONATION I REMOVAL OF ISO
' BUTYLAMINE (T-) VIA ADDITION OF HCN TO ISOBUTYLENE
* CYCLOHEXYLAMINE VIA AMMINATION OF CYCLOHEXANOL
CYCLOHEXYLAMINE VIA HYDROGENATION OF ANILINE
* ISOPROPYLAMINE VIA AHINOLYSIS OF ISOPROPYL ALCOHOL
* PROPYLAMINE VIA HYDROGENATION OF PROPIONITRILE
PHOSGENE VIA HALOGEN AT I ON OF CARBON MONOXIDE
* UREA VIA CONDENSATION OF AMMONIA AND CARBON DIOXIDE
PHOSGENE VIA HALOGEN AT I ON OF CARBON MONOXIDE
TEREPHTHALIC ACID VIA OXIDATION OF P-XYLENE
TEREPHTHALIC ACID VIA OXIDATION OF P-XYLENE
XYLENE (P-) VIA PURIFICATION OF MIXED XVLENE
AOIPONITRILE VIA ELECTROHYDRODIMERIZATION OF ACRYLONITRILE
* HEXAMETHYLENED1AMINE VIA HYDROGENATION OF AOIPONITRILE
FORMALDEHYDE FROM DEHYDROGENATION OF METHANOL
CARBON DISULFIOE VIA SULFONATION OF METHANE
CARBON TETRACHLORIOE VIA CHLORINATION OF CARBON DISULFIOE
* CYANURIC CHLORIDE VIA HALOGEN AT ION OF HCN
* HYDROGEN CYANIDE VIA AIR OXIDATION OF METHANE
FORMALDEHYDE FROM DEHYDROGENATION OF HETHANOL
* UREA VIA CONDENSATION OF AMMONIA AND CARBON DIOXIDE
FORMALOEHYDE FROM DEHYOR06ENATION OF METHANOL
FORMALDEHYDE VIA AIR OXIDATION OF METHANOL
METHYL BROMIDE VIA HAL06ENATION OF METHANOL
METHYL BROMIDE VIA HALOGENATION OF METHANOL
FORMALDEHYDE VIA AIR OXIDATION OF METHANOL
* SODIUM DODECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
CFC VIA LIQUID PHASE CATALYTIC REACTION
CFC-U2 VIA HALOGENATION OF CHLORO COMPOUNDS
CFC-22 VIA HALOGENATION OF CHLOROFORM
Included for analysts of economic Impacts, but unit would not be subject to the HON
5-2
-------
result in the same value. The only difference in the
credit/debit analysis when an early reduction commitment, 33/50
commitment, or pollution prevention measure is involved in an
emissions average is the baseline date. For early reduction
commitments, 33/50 commitments and pollution prevention measures
the baseline date is prior to the application of the control or
pollution prevention measure. In this case the baseline date
would be October 11, 1990. On October 11, 1990, there was no
control on process vent 4. Therefore, the emissions from process
vent 4 with the baseline level of control applied (EPV2iBASE) is
equal to the uncontrolled emissions (EPV2iu) which is equal to
the allowed emissions, just as in the case where there was no
early reduction commitment. As shown in Section 3.3.2.1,
EPV2iBASE = 20 Mg/year. The actual emissions (EPV2jj^cTUAL) after
the flare are calculated using the same equations that would be
used if the flare had been installed after November 15, 1990
(0.4 Mg/year or 20*0.02). The credit for process vent 4 would be
the difference between EPV2 iACTUAL an(* EpV2iBASE times the
discount factor: (20-0.4)*0.9=17.6 Mg/year. See Table 3-11 for
comparison with the case study when there was not an early
reduction commitment involved.
There is a difference in the compliance schedule for
facilities involved in early reduction commitments. As described
in Section 112(i)(5) of the CAA those emission points in an early
reduction commitment, which have a demonstrated reduction in HAP
emissions (usually 90 percent reduction) prior to proposal of a
NESHAP covering that source, would not be required to comply with
the NESHAP until 6 years after the compliance date specified in
the NESHAP. In this case, the HON compliance date is 3 years
after promulgation. Thus, process vents 3 and 4, the emission
points in the early reduction commitment would not be required to
be in compliance with the HON until 9 years after promulgation.
At the time General Chemical has to comply with the HON, the
Group 2 process vent 4 could be used to generate credits for the
emissions average. Process vent 4 could not be used to generate
credit before the 9th year after promulgation, because as part of
3-39
-------
Chemical Manufacturing Facilities Including the HOH Impacts Analysts
State
FL
KL
GA
GA
GA
GA
GA
GA
GA
IA
IA
IA
IL
1L
IL
IL
IL
IL
IL
IL
IL
City
PENSACOLA
PENSACOLA
ATLANTA
AUGUSTA
AUGUSTA
AUGUSTA
BRUNSWICK
VIENNA
WINDER
CLINTON
MUSCAT I NE
PORT NEAL
BLUE ISLAND
BLUE ISLAND
CHICAGO
CHICAGO
CHICAGO
CHICAGO
CHICAGO
CICERO
DANVILLE
Facility Name
AIR PRODUCTS
MONSANTO CORPORATION
THROCHEN LAB. INC.
COLUMBIA NITROGEN
DSM CHEMICALS AUGUSTA, INC.
PROCTER 1 GAMBLE CO.
SCM CORP.
GEORGIA-PACIFIC
STEPON CO,
HAWKEYE CHEMICAL
MONSANTO CORPORATION
TERRA INTERNATIONAL
BTL SPECIALTY RESINS
WITCO CORPORATION
DU PONT
GREYHOUND CORP.
PHC. INC.
UNOCAL CORPORATION
WITCO CORPORATION
(COPPERS
ALLIED CHEMICAL
Production Process
* 6UTYLAMINE (T-) VIA ADDITION OF HCN TO ISOBUTYLENE
DIETHYLAMINE VIA ETHYL AT I ON OF AMMONIA
DIMETHYL FORHAMIDE VIA AMINOLVSIS OF METHYL FORMATE
* ISOPROPYLAHINE VIA AMINOLYSIS OF ISOPROPYL ALCOHOL
NETHANOL VIA HYOROGENATION OF CARBON MONOXIDE
HETHYLAMINES VIA NETHYLATION OF AMMONIA
* ADIPIC ACID VIA AIR OXIDATION OF CYCLOHEXANE
* ADIPONITRILE VIA DEHYDRATION OF ADIPIC ACID
* HEXAMETHYLENEOIAHINE VIA HYDROGENATION OF AOIPONITRILE
MALEIC ANHYDRIDE VIA AIR OXIDATION OF BUTENES
* SODIUM DODECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL
* UREA VIA CONDENSATION OF AMMONIA AND CARBON DIOXIDE
CAPROLACTAM PRODUCTION VIA REARRANGEMENT OF CYCLOHEXANONE
* CYCLOHEXANONE VIA AIR OXIDATION OF CYCLOHEXANE
* SODIUM DODECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL
DIPHENYL OXIDE VIA HYDROLYSIS OF CHLOR08ENZENE
FORMALDEHYDE FROM DEHYDROGENATION OF METHANOL
* SODIUM DOOECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL
* UREA VIA CONDENSATION OF AMMONIA AND CARBON DIOXIDE
* KETENE VIA DEHYDRATION OF ACETIC ACID
* UREA VIA CONDENSATION OF AMMONIA AND CARBON DIOXIDE
CUMENE HVDROPEROXIDE VIA OXIDATION OF CUMENE
CUMENE VIA ALKYLATION OF BENZENE WITH PROPYLENE
PHENOL VIA ACID CLEAVAGE OF CUMENE HVDROPEROXIDE
* SODIUM DOOECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL
* CHLOROSULFONIC ACID VIA HYDROHALOGEMATION OF SULFUR TRIOX1DE
* SODIUM DOOECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL
BENZENE
BENZENE
BENZENE
BENZENE
BENZEHL
CRESOLS/CRESVLIC ACIDS (MIX) VIA RECOVERY FROM SPENT REFINERY CAUSTICS
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
POLYETHYLENE 6LYCOL VIA POLYMERIZAT.'n* Of ETHYLCNC 6LYCOI * rTHY
POLYPROPYLENE 6LYCOL VIA POLYMER OF PRuPYLENE OXirL AND PRC, J,
PHTHALIC ANHYDRIDE VIA AIR OXIDATION OF NAPHTHALENE
CFC VIA LIQUID PHASE CATALYTIC REACTION
CFC-142 VIA HALOGEN AT I ON OF CHLORO COMPOUNDS
LENc .
t 61.
I m. \ uilt-il for analysts ut ecoounit c Impact a. but unl t woul d not be subject to the HON
5-4
-------
4.0 ADDITIONAL WASTEWATER CASE STUDY
The following case study provides two additional examples to
help illustrate the flexibility of the process wastewater
provisions. In general, a source can comply with the
requirements of the process wastewater provisions by: suppressing
emissions until the stream reaches the treatment unit; treating
the wastewater stream to remove organic HAP's; and controlling
air emissions from waste management units and treatment
processes. A variety of treatment technologies could possibly be
used to reduce either the mass or the concentration of HAP's in
the process wastewater stream. The first example, in
Section 4.1, demonstrates the reduction in the mass of HAP's by
biological treatment and explains the use of the associated mass
removal equation. The second example, in Section 4.2, explains
how reduction in HAP concentration (e.g, by steam stripping) can ".
also be used to comply with these provisions.
The source examined in this case study (XYZ Chemical
Company) is different from other case studies in other sections
of this document. The XYZ Chemical Company is an existing source
and has three process units (i.e., Process Units A, B, and C)
generating a total of ten process wastewater streams. Of these,
three are Group 1 wastewater streams. A schematic diagram of the
plant is given in Figure 4.1.
4.1 BIOLOGICAL TREATMENT UNIT OPTION
This example illustrates a compliance method for biological
treatment units, which requires the use of the total VOHAP RMR
calculation [§63.138(c)(1)(iii)(D)]. To achieve compliance, the
facility must suppress emissions from wastewater starting at the
point of generation with continued emission suppression until the
wastewater enters the biological treatment unit. This means that
process unit drains, manholes, junction boxes, surface
impoundments, tanks, oil/water separators, sewers, etc., must be
covered, trapped, or otherwise controlled as specified in
§§63.133-63.137. In this example, only streams from process
4-1
-------
Chemical Manufacturing Facilities Including the HON Impacts Analysis
State Ctty
Facility Name
Production Process
KS
KS
KS
KS
KS
KS
KS
KS
KY
KY
KY
KY
EL DORADO
KANSAS CITY
KANSAS CITY
LAWRENCE
LENEXA
WICHITA
WICHITA
WICHITA
KY ARDSLEY
KY BRANDENBURG
KY CALVERT CITY
KY CALVERT CITY
KY CALVERT CITY
CARROLLTON
CATLETTSBURG
LOUISVILLE
LOUISVILLE
TEXACO
COLGATE-PALMOLIVE CO.
PROCTER & GAMBLE CO.
FARMLAND INDUSTRIES
EAGLE-PICHER INDUSTRIES
AIR PRODUCTS
ESSEX
VULCAN CHEMICALS
R.S.A. CORPORATION
OLIN CORPORATION
B. F. GOODRICH
GAF CORPORATION
PENNWALT CORP.
DOW CORNING
ASHLAND CHEMICALS
BORDEN CHEMICAL
DU PONT
CUMENE HYDROPEROXIDE VIA OXIDATION OF CUMENE
CUHENE VIA ALKYLATION OF BENZENE WITH PROPYLENE
PHENOL VIA ACID CLEAVAGE OF CUMENE HYDROPEROXIDE
SODIUM DODECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
SODIUM DODECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
UREA VIA CONDENSATION OF AMMONIA AND CARBON DIOXIDE
SUCCINIC ACID VIA HYDROLYSIS OF ETHYLENE DICYANIDE
TETRACHLOROETHANE (1.1.2,2-) VIA HALOGENATIDN OF ACETYLENE
TETRACHLOROETHANE (1.1.2.2-) VIA HALOGENATION OF ETHYLENE
CYCLOHEXYLAMINE VIA HYDROGENATION OF ANILINE
DICYCLOHEXYLAMINE VIA HYDROGENATION OF CYCLOHEXYLAMINE-C.H
CFC-22 VIA HALOGENATION OF CHLOROFORM
CARBON TETRACHLORIDE VIA CHLORINATION OF HYDROCARBONS
CHLOROFORM VIA HALOGENATION OF METHYL CHLORIDE
CHLOROFORM VIA HALOGENATION OF METHANE
PENTACHLOROPHENOL VIA HALOGENATION OF PHENOL
PERCHLOROETHYLENE VIA CHLORINATION OF ETHYLENE DICHLORIDE
BROMONAPHTHALENE VIA HALOGENATION OF NAPHTHALENE
ETHYLENE OXIDE VIA AIR OXIDATION OF ETHYLENE
POLYETHYLENE GLVCOL VIA POLYMERIZATION OF ETHYLENE GLYCOL I ETHYLENE OXIDE
PROPYLENE GLVCOL VIA HYDROLYSIS OF PROPVLENE OXIDE
ETHVLENE DICHLORIDE VIA CHLOR1NATION/OXYCHLORINATION OF ETHYLENE
VINYL CHLORIDE VIA DEHYDROHAL06ENATION OF ETHYLENE DICHLORIOE BY THERMAL CRACKING
FORMALDEHYDE VIA AIR OXIDATION OF METHANOL
METHYLAMINES VIA METHYLATION OF AMMONIA
CFC VIA LIQUID PHASE CATALYTIC REACTION
CFC-142 VIA HALOGENATION OF CHLORO COMPOUNDS
CFC-22 VIA HALOGENATION OF CHLOROFORM
METHYL CHLORIDE VIA HVDROHAL06ENATION OF METHANOL
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
CUMENE VIA ALKYLATION OF BENZENE WITH PROPVLENE
FORMALDEHYDE FROM DEHYDROGENATION OF METHANOL
CFC-142 VIA HALOGENATION OF CHLORO COMPOUNDS
CFC-22 VIA HALOGENATION OF CHLOROFORM
* Included for analysis of economic Impacts, but unit would not be subject to the HON
-------
units A and C are identified for use in the biological treatment
unit option. The plant must demonstrate that the actual mass
removal achieved by the biotreatment unit is greater than or
equal to the calculated RMR. The RMR for each Group 1 wastewater
stream is calculated from the following equation:
RMR
K
106
n
E
100
(from Section
63.145(h) of
Subpart G)
Where:
K
NOTE:
Density of each Group 1 wastewater stream (assumed
to be 1.0 Mg wastewater/m3 wastewater for this
example).
Annual wastewater quantity of each Group 1
wastewater stream, cubic meters per year.
Average VOHAP concentration of each organic HAP
compound "j" (from Table 9 of Subpart G) in each
Group l wastewater stream at the point of
generation, ppmw (g VOHAP/Mg water).
Required percent removal of each compound "j"
(i.e., target removal efficiency from Table 9 of
Subpart G).
Two important parameters must be quantified
initially and whenever process changes are made to
determine whether a process wastewater stream is a
Group 1 or Group 2 stream. Those parameters are
the annual wastewater quantity for a stream and
the VOHAP concentration of HAP's in the stream.
The VOHAP concentration can be quantified as a
flow-weighted annual average for either total
VOHAP or for individually-speciated HAP's. In
this example, Cj; quantifies the flow-weighted
annual average for individually-speciated HAP's.
The total RMR for all Group 1 wastewater streams treated in the
biological treatment unit is calculated by adding the RMR for
each Group l wastewater stream considered under this compliance
4-3
-------
State City
Facility Nome
Chemical Manufacturing Facilities Including the HON Impacts Analysts
Production Process
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
FORT1ER
GARYVILLE
GEISHAR
GEISHAR
GEISHAR
OEISHAR
GEISHAR
GEISHAR
GRAHERCY
LA PLACE
LAKE CHARLES
AMERICAN CYANAMID
NALCO
ARCADIAN CORP.
BASF
BORDEN CHEMICAL
1C I/RUBICON
SHELL OIL COMPANY
VULCAN CHEMICALS
KAISER
OU PONT
CITGO PETROLEUM CORP.
CALCIUM CYANAMIDE VIA REACTING CALCIUM CARBIDE WITH NITROGEN GAS
UREA VIA CONDENSATION OF AMMONIA AND CARBON DIOXIDE
ACRYLAMIOE VIA HYDROLYSIS OF ACRYLONITRILE
UREA VIA CONDENSATION OF AMMONIA AND CARBON DIOXIDE
4.4-METHYLENEDIANILINE VIA CONDENSATION OF ANILINE WITH FORMALDEHYDE
ETHYLENE 6LVCOL VIA HYDROLYSIS OF ETHYLENE OXIDE
ETHYLENE OXIDE VIA AIR OXIDATION OF ETHYLENE
MDI VIA REACTING 4.4 METHVLENEDIANILINE WITH PHOSGENE
PHOSGENE VIA HALOGENATION OF CARBON MONOXIDE
TOLUENE DIISOCYANATES VIA DINITRATION OF TOLUENE UITH PHOSEGENAT10N
ACETIC ACID VIA CARBONYLATION OF METHANOL
ETHYLENE OICHLOR1DE VIA CHLORINATION/OXYCHLORINATION OF ETHYLENE
FORMALDEHYDE FROM DEHYDROGENATION OF METHANOL
METHANOL VIA HYDROGENATION OF CARBON MONOXIDE
UREA VIA CONDENSATION OF AMMONIA AND CARBON DIOXIDE
VINYL CHLORIDE VIA HYOROHALOGENATION OF ACETYLENE
4.4-METHYLENEOIANILINE VIA CONDENSATION OF ANILINE UITH FORMALDEHYDE
ANILINE VIA HYDROGENATION OF NITROBENZENE
MDI VIA REACTING 4.4 HETHYLENEDIANILINE WITH PHOSGENE
NITROBENZENE VIA NITRATION OF BENZENE
PHOSGENE VIA HALOGENATION OF CARBON MONOXIDE
TOLUENE DIISOCYANATES VIA DINITRATION OF TOLUENE WITH PHOSEGENATION
ETHYLENE GLYCOL HONOB. ETHER VIA ALCOHOLYSIS OF ETHYLENE OXIDE BY BUTANOL
ETHVLENE GLYCOL VIA HYDROLYSIS OF ETHYLENE OXIDE
ETHVLENE OXIDE VIA AIR OXIDATION OF ETHVLENE
CARBON TETRACHLORIOE VIA CHLORINATION OF HYDROCARBONS
CHLOROFORM VIA HALOGENATION OF METHYL CHLORIDE
ETHVLENE DICHLORIDE VIA CHLORINATION/OXYCHLORINATION OF ETHYLENE
PERCHLOROETHVLENE VIA CHLORINATION OF ETHYLENE DICHLORIDE
TRICHLOROETHANE (1.1.1-) VIA HALOGENATION OF ETHANE
CFC-22 VIA HALOGENATION OF CHLOROFORM
ADIPONITRILE VIA ADDITION OF HYDROGEN CYAN10 TO BUTADIENE
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
METHYL TERT BUTYL ETHER VIA ETHERIFICATION OF ISOBUTYLENE AND METHANOL
Included for analysis of economic Impacts, but unit would not be subject to the HON
5-8
-------
TABLE 4-1.
WASTEWATER STREAM CHARACTERISTICS
FOR PROCESS UNITS A AND C
.*>
ui
Volumetric
Plow Rate
Process VOHAP
Wastewater Concentration
Stream HAP Chemical (ppmw) (*pn») (m3/yr)
A-l
A-2
A-3
C-l
C-2
C-3
C-4
Carbon tetrachloride
Chloroform
Ch lorobenzene
2,4, 5-Tr ichlorophenol
2 , 4-Dinitrophenol
Methanol
Nitrobenzene
Aniline
Carbon Tetrachloride
Chlorobenzene
Benzene
Benzene
Nitrobenzene
Aniline
Toluene
600
1.800
2,400 2 1,050
200 20 10,500
350 17 8,925
350
650
1,000 15 7,875
540
160
700 25 13,125
100
400
200
700 2 1,050
750
750
1,500
500
3,500 10 5,250
VOHAP
Mass Target
Plow Removal
Rate Efficiency* Fbio
(Mg/yr) (%) (%)
0.63
1.89
2.52
2.10
3.12
2.76
5.12
7.88
7.09
2.10
9.19
0.11
0.42
0.21
0.74
3.94
3.94
7.88
2.63
18.38
6%
25%
50%
87%
95% 81%
70% 90%
81%
86%
6%
50%
69%
99% 69%
95% 81%
70% 86%
99% 42%
From Table 9 in $63.131 of Subpart G.
-------
Chemical Manufacturing Facilities Including the HON Impacts Analysis
State City
Facility Name
Production Process
LA PLAQUEH1NE
LA
LA
LA
LA
LA
LA
LA
LA
LA
HA
HA
PLAQUEHINE
SHREVEPORT
ST. GABRIEL
ST. GABRIEL
ST. GABRIEL
ST. JAMES
TAFT
TAFT
WINNFIELD
QUINCY
SPRINGFIELD
DOW
GEORGIA GULF
UOP INC.
AIR PRODUCTS
CIBA-GEIGY CORPORATION
ICI/RUBICON
CHEVRON CORPORATION
UNION CARBIDE
WITCO CORP.
CHEMBONO CORP
PROCTER t GAMBLE CO.
MONSANTO CORPORATION
PROPYLENE CHLOROHYORIN VIA HALOGENATION OF PROPVLENE
PROPYLENE GLYCOL MONOMETHYL ETHER VIA ALCOHOLV. PROPYLENE OXIDE BY METHANOL
PROPYLENE GLYCOL VIA HYDROLYSIS OF PROPYLENE OXIDE
PROPYLENE OXIDE VIA DEHYDROHALOGENATION OF PROPYLENE CHLOROHYDRIN '''
VINYL CHLORIDE VIA DEHYOROHALOGENATION OF ETHYLENE DICHLORIDE BY THERMAL CRACKING
VINYLIDENE CHLORIDE VIA DEHYDROCHLORINATION OF 1.1.2-TRICHLOROETHANE
CUMENE HYDROPEROXIDE VIA OXIDATION OF CUMENE
ETHYLENE DICHLORIDE VIA CHLORINATION/OXYCHLORINATION OF ETHYLENE
METHANOL VIA HYDR06ENATION OF CARBON MONOXIDE
PHENOL VIA ACID CLEAVAGE OF CUHENE HYDROPEROXIDE
VINYL CHLORIDE VIA DEHYDROHALOGENATION OF ETHYLENE DICHLORIDE BY THERMAL CRACKING
NITROANILINE (P-) VIA AMMONOLYSIS OF P-CHLORONITROB.
BUTYLAMINE (T-) VIA ADDITION OF HCN TO ISOBUTYLENE
DIETHYLAMINE VIA ETHVLATION OF AMMONIA
ISOPROPYLAMINE VIA AHINOLYSIS OF ISOPROPYL ALCOHOL
HYDROGEN CYANIDE VIA AIR OXIDATION OF METHANE
PHOSGENE VIA HALOGENATION OF CARBON MONOXIDE
ETHYLBENZENE VIA ALKYLATION OF BENZENE WITH ETHYLENE
STYRENE PRODUCTION VIA DEHYDROGENATION OF ETHYLBENZENE
ACROLEIN VIA OXIDATION OF PROPVLENE
ACRYLIC ACID VIA OXIDATION OF ACROLEIN. ACROLEIN FROM OXIDATION OF PROPYLEN
BUTYL ACRYLATE (N-ISOMER) VIA ESTERIFICAT10N OF ACETYLENE
ETHYL ACRYLATE VIA ESTERIFICATION OF ACRYLIC ACID BY ETHYL ALCOHOL
ETHYLCNE GLYCOL MONOB. ETHER VIA ALCOHOLYSIS OF ETHYLENE OXIDE BY BUTANOL
ETHYLENE GLYCOL MONOETH. ETHER VIA ALCOHOLYSIS Of ETHYLENE OXIDE BY ETHANOL
ETHYLENE GLYCOL MONOMETH. ETHER VIA ALCOHOLYSIS OF ETHYLENE OXIDE BY HET".A
ETHYLENE GLYCOL VIA HYDROLYSIS OF ETHYLENE OXIDE
ETHYLENE OXIDE VIA AIR OXIDATION OF ETHYLENE
PROPYLENE GLYCOL MONOMETHYL ETHER VIA ALCOHOLY. PROPYLENE OXIDE BY M
AMMON1UN THIOCYANATE VIA PVROVSIS OF AMMONIUM DITHIOCARBONATE
FORMALDEHYDE VIA AIR OXIDATION OF METHANOL
SODIUM DOOECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
ETHYL ACETATE VIA HYDROLYSIS OF POLYVINYL ACETATE BY ETHANOL
FORMALDEHYDE FROM DEHYDROGENATION OF METHANOL
IncA uded for analysts of economt c impacts, but unlt would not be subject to the HON
5-10
-------
TABLE 4-2.
WASTEWATER STREAM CHARACTERISTICS FOR PROCESS UNITS A AND C
FOR CALCULATING ACTUAL MASS REMOVAL (MR)
Process
Wastewater
Stream HAP Chemical
A-l
A-2
A-3
C-l
C-2
C-3
C-4
Carbon tetrachloride
Chloroform
Chlorobenzene
2,4, 5-Trichlorophenol
2, 4-Dlnitrophenol
Methanol
Nitrobenzene
Aniline
Carbon Tetrachloride
Chlorobenzene
Benzene
Benzene
Nitrobenzene
Aniline
Toluene
VOHAP Mass Flow Rate
Entering Treatment
Processes
(Mg/yr) (kg/hr)
0.63
1.89
2.10
3.12
2.76
5.12
7.09
2.10
0.11
0.42
0.21
3.94
3.94
7.88
2.63
0.07
0.22
0.24
0.36
0.32
0.59
0.81
0.24
0.01
0.05
0.02
0.45
0.45
0.90
0.30
VOHAP Mass Flow Rate
Exiting Treatment
Processes
(Mg/yr) (kg/hr)
0.09
0.02
1.31
0.09
0.79
1.05
1.93
1.58
0.03
0.18
0.04
0.26
0.70
1.23
0.44
0.01
0.002
0.15
0.01
0.09
0.12
0.22
0.18
0.003
0.02
0.005
0.03
0.08
0.14
0.05
Fbio
(%)
6%
25%
50%
87%
81%
90%
81%
86%
6%
50%
69%
69%
81%
86%
42%
-------
Chemical Manufacturing Facilities Including the HON Impacts Analyst*
State City
Facility Name
Production Process
HO ST. LOUIS
HO ST. LOUIS
HO ST. LOUIS
HO ST. LOUIS
HS ABERDEEN
HS PASCAGOULA
HS PASCAGOULA
HS 1ATIORSVILLE
HS VICKSBURG
HS YAZOO CITY
HT HISSOULA
NC ACME
NC CAPE FEAR
NC CHARLOTTE
NC CHARLOTTE
NC CONUAY
NC FAYETTEVILLE
NC GREENSBORO
NC GREENSBORO
NC GREENSBORO
NC HEALING SPRINGS
NC HONCURE
NC NEW BRUNSWICK
NC RALEIGH
NC WILMINGTON
NC WILMINGTON
NE LA PLATTE
MONSANTO CORPORATION
PROCTER I GAMBLE CO.
RHONE-POULENC INC.
UNILEVER US, INC.
VISTA CHEMICAL CO.
CHEVRON CORPORATION
FIRST CHEMICAL CORP.
GEORGIA-PACIFIC
BOROEN CHEMICAL
MISSISSIPPI CHEMICAL
BORDEN CHEMICAL
WRIGHT CHEMICAL CORPORATION
DU PONT
AMERICAN CYANAHID
SANOOZ. INC.
GEORGIA-PACIFIC
BORDEN CHEMICAL
CHEHOL INC.
MORFLEX CHEMICAL CO.
HORFLEX CHEMICAL CO.. INC.
DU PONT
CHEMBONO CORP
RHONE-POULENC
INTERNATIONAL MINERALS t, CHEMICALS
CAPE INDUSTRIES
DU PONT
ARCADIAN CORP.
KETENE VIA DEHYDRATION OF ACETIC ACID
SODIUM DOOECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
SALICYLIC ACID VIA HYDROFORMYLATION OF SODIUM PHENATE
SODIUM DOOECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
DIISODECYL PHTHALATE VIA ESTERIFICATION W/PHTHALIC ANHYDRIDE AND DECANOL
DIISOOCTYL PHTHALATE VIA ESTERIFICATION W/ PHTHALIC ANHYDRIDE I OCTYL ALCOH
XYLENE (P-) VIA PURIFICATION OF MIXED XYLENE
ANILINE VIA HYDROGENATION OF NITROBENZENE
NITROBENZENE VIA NITRATION OF BENZENE
FORMALDEHYDE VIA AIR OXIDATION OF METHANOL
FORMALDEHYDE VIA AIR OXIDATION OF METHANOL
UREA VIA CONDENSATION OF AMMONIA AND CARBON DIOXIDE
FORMALDEHYDE FROM DEHYDROGENATION OF METHANOL
FORMALDEHYDE FROM OEHYOROGENATION OF METHANOL
HEXAMETHYLENETETRAM1NE VIA ADDITION OF AMMONIA TO FORMALDEHYDE
DIMETHYL TEREPHTHALATE VIA ESTERIFICATION OF TPA
GLYOXAL VIA AIR OXIDATION OF ETHYLENE GLYCOL
DINITROPHENOL (2.4-) VIA HYDROLYSIS OF 2.4-DINITROCHLOROBENZENE
FORMALDEHYDE VIA AIR OXIDATION OF METHANOL
FORMALDEHYDE FROM OEHYDR06ENATION OF METHANOL
HEXAMETHYLENETETRAMINE VIA ADDITION OF AMMONIA TO FORMALDEHYDE
BIPHENVL VIA DEHYDROGENATION OF BENZENE
DIISOOECYL PHTHALATE VIA ESTERIFICATION U/PHTHAL1C ANHYDRIDE AND DECANOL
DIISOOCTYL PHTHALATE VIA ESTERIFICATION W/ PHTHALIC ANHYDRIDE & OCTYL ALCOH
BENZYL BENZOATE VIA ESTERIFICATION OF BENZYL ALCOH
FORMALDEHYDE FROM DEHYDROGENATION OF METHANOL
FORMALDEHYDE VIA AIR OXIDATION OF HETHANOL
DIPHENYL OXIDE VIA HYDROLYSIS OF CHLOROBENZENE
AMINOPHENOL (P-) VIA HYDROGENATION OF NITROPHENOL
DIMETHYL TEREPHTHALATE VIA ESTERIFICATION OF TPA
TEREPHTHALIC ACID VIA HYDROLYSIS OF DHf
TEREPHTHALIC ACID VIA OXIDATION OF P-XYLENE
TEREPHTHALIC ACID VIA OXIDATION OF P-XYLENE
UREA VIA CONDENSATION OF AMMONIA AND CARBON DIOXIDE
Included for analysis of economic Impacts, but unit would not be subject to the HON
R-1 2
-------
Stream C-3
MR(C-3) = [(O.Olkg/hr
+ [(0.05kg/hr
+ [(0.02kg/hr
MR(C-3) - 0.03
0.003kg/hr) * 0.06]
0.02kg/hr) * 0.5) ]
0.005kg/hr) * 0.69]
Stream C-4
Total
MR(C-4) - [(0.45kg/hr - 0.03kg/hr) * 0.69]
+ [(0.45kg/hr - 0.08kg/hr) * 0.81]
+ [(0.9kg/hr - 0.14kg/hr) * 0.86]
+ [(0.3kg/hr - 0.05kg/hr) * 0.42]
MR(C-4) = 1.35
MR (Total) = MR(A-l) +MR(A-2) +MR(A-3)
+ MR(C-l) + MR(C-2) +MR(C-3) + MR(C-4)
MR (Total) = 0.06 + 0.05 + 0.31 + 0.61 + 0.53 + 0.03 + 1.35
MR (Total) =2.94 kg/hr = 25.75 Mg/yr
It is important to note that the wastewater streams in
Process Units A and C are required to suppress emissions from the
point of generation through treatment. Since the total MR
(25.75 Mg/yr) exceeds the total RMR (21.95 Mg/yr), Group 1
streams from Process Unit C at this source are in compliance with
the provisions.
4-9
-------
Chemical Manufacturing Facilities Including the HOH Impacts Analysis
State Ctty
Facility Name
Production Process
NJ FAIRFIELD
NJ FAIRLAWN
NJ FIELOSHORE
NJ FORDS
NJ GARFIELO
NJ GRASSELLI
NJ GRASSELLI-LINDEN
NJ JERSEY CITY
NJ KEARNY
NJ KEARNY
NJ LINDEN
NJ LINDEN
NJ LODI
NJ LYNDHURST
NJ NEWARK
NJ NEWARK
NJ NEWARK
NJ NEWARK
NJ NUTLY
NJ OLD BRIDGE
NJ PATTERSON
NJ PHILLIPSBURG
NJ RIDGEFIELD
NJ SOUTH KEARNY
NJ SOUTH PLAINFIELD
NJ TOTOUA
NJ UNION BEACH
PENTA MANUFACTURING CORP
CROMPTON AND KNOWLES
STEPON CO.
HATCO
KALAMA CHEMICAL. INC.
DU PONT
DU PONT
INTERNATIONAL MINERALS & CHEMICALS
BASF
MONSANTO CORPORATION
EXXON CORPORATION
GAF CORPORATION
NAPP CHEMICALS. INC.
PENCO OF LYNDHURST
HOECHST CELANESE CORPORATION
HONI6 CHEMICAL
JARCHEM INDUSTRIES
WHITE CHEMICAL CORP.
HOFFMAN-LAROCHE
CPS CHEMICAL CO.
WITCO CORPORATION
PROCTER AND GAMBLE
NICKSTAOT-MODELLER. INC.
BADISCHE CORP
CHEMICAL DYNAMICS CORP
UNGERER AND COMPANY
INTERNATIONAL FLAVORS & FRAGRANCES
ACETAL VIA CONDENSATION OF ETHANOL AND E.V.ETHER
DIPHENYL OXIDE VIA HYDROLYSIS OF CHLOROBENZENE
SODIUM DOOECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
DIISODECYL PHTHALATE VIA ESTERIFICATION W/PHTHALIC ANHYDRIDE AND DCCANOL
DIISOOCTYL PHTHALATE VIA ESTERIFICATION W/ PHTHALIC ANHYDRIDE I OCTYL ALCOH
SALICYLIC ACID VIA HYDROFORMYLATION OF SODIUM PHENATE
DIMETHYL SULFATE VIA ESTERIFICATION OF METHYLC.S. t DI-M.S.
CHLOROSULFON1C ACID VIA HYDROHALOGENATION OF SULFUR TRIOXIDE
SODIUM BENZOATE VIA ADDITION OF BENZOIC ACID TO S. HYDROXIDE
DIISODECYL PHTHALATE VIA ESTERIFICATION W/PHTHALIC ANHYDRIDE AND DECANOL
DIISOOCTYL PHTHALATE VIA ESTERIFICATION W/ PHTHALIC ANHYDRIDE I OCTYL ALCOH
NONYLPHENOL VIA ALKVLATION OF PHENOL
NONYLPHENOL VIA ALKYLATION OF PHENOL
NONYLPHENOL VIA ALKYLATION OF PHENOL
6ENZIL VIA CARBONYLATION OF CHLOROBENZENE
BENZOIN VIA ESTERIFICATION OF BENZALDEHYOE
FORMALDEHYDE VIA AIR OXIDATION OF METHANOL
SODIUM ACETATE VIA ADDITION OF ACETIC ACID TO SODIUM HYDROXIDE
SODIUM BENZOATE VIA ADDITION OF BENZOIC ACID TO S. HYDROXIDE
ACETYL CHLORIDE VIA HAL06ENATION OF SODIUM ACETATE
DIPHENYL OXIDE VIA HYDROLYSIS OF CHLOROBENZENE
DIOXANE (1.4-) VIA CYCLIC DEHYDRATION OF OI6LYCOL
SODIUM DOOECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
AMMONIUM THIOCYANATE VIA PYROYSIS OF AMMONIUM DITHIOCARBONATE
SUCCINIC ACID VIA HYDROLYSIS OF ETHYLENE D1CYANIOE
BENZOIN VIA ESTERIFICATION OF BENZALDEHYOE
PHTHALIC ANHYDRIDE VIA AIR OXIDATION OF 0-XYLENE
BENZIL VIA CARBONYLATION OF CHLOROBENZENE
BENZOIN VIA ESTERIFICATION OF BENZALDEHYDE
BENZYL BENZOATE VIA ESTERIFICATION OF BENZYL ALCOH
SUCCINIC ACID VIA FERMENTATION OF AMMONIUM TARTRATE
DIPHENYL OXIDE VIA HYDROLYSIS OF CHLOROBENZENE
BENZYL BENZOATE VIA ESTERIFICATION OF BENZYL ALCOH
DIPHENYL OXIDE VIA HYDROLYSIS OF CHLOROBENZENE
for analysis of economic Impacts, but unit would not be subject to the HON
5-14
-------
TABLE 4-3. PROCESS UNIT B STREAM CHARACTERISTICS
Flow Rate VOHAP Concentration
Stream (£pm) (ppmw)
B-l 72 230
B-2 13 1600
B-3 10 5
4-11
-------
btate City
Facility Name
Chemical Manufacturing Facilities Including the HON Impacts Analysts
Production Process
OH
OH
OH
OH
OH
OK
OK
OK
OK
OK
OR
OR
OR
OR
OR
OR
OR
PA
PA
PA
PA
PA
HA
PA
PA
PERRY
ST. BERNARD
TOLEDO
TOLEDO
TOLEDO
ENIO
PONCA CITY
PRYOR
TULSA
VERDIGRIS
ALBANY
LA GRANDE
SPRINGFIELD
SPRINGFIELD
ST HELENS
ST. HELENS
WHITE CITY
BEAVER VALLEY
BRISTOL
DELAWARE WATER GAP
MARCUS HOOK
NEVILLE ISLAND
PETROLIA
PHILADELPHIA
PHILADELPHIA
ICI AMERICAN HOLDINGS
PROCTER t GAMBLE CO.
DU PONT
PERSTORP POLYOLS. INC.
SUN COMPANY. INC.
FARMLAND INDUSTRIES
CONOCO
N-REN CORP.
SUN COMPANY. INC.
FREEPORT - MCMORAN
GEORGIA-PACIFIC
BORDEN CHEMICAL
BORDEN CHEMICAL
CHEMBOND CORP
CHEVRON CORPORATION
CEPEX
RVP CORP
ARCO CHEMICAL
GREYHOUND CORP.
WHITTAKER CORP
SUN COMPANY. INC.
ARISTECH
INDSPEC CHEMICAL CORP.
ALLIED CHEMICAL
CHEVRON CORPORATION
PERCHLOROMETHYL MERCAPTAN VIA HAL06ENATION OF CARBON DISULFIDE
* SODIUM DODECYL BENZENE SULFONATE VIA SULFONAT10N OF LINEAR ALKYL BENZENE
FORMALDEHYDE FROM DEHYOROGENATION OF METHANOL
PENTAERYTHRITOL VIA ADDITION OF FORMALDEHYDE TO ACETALDEHYDE
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
* UREA VIA CONDENSATION OF AMMONIA AND CARBON DIOXIDE
METHYL TERT BUTYL ETHER VIA ETHERIFICATION OF ISOBUTYLENE AND METHANOL
*. UREA VIA CONDENSATION OF AMMONIA AND CARBON DIOXIDE
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
BENZENE VIA HYORODEALKYLATION/TRANSALKYLATION OF TOLUENE
CYCLOHEXANE VIA HYDROGENATION OF BENZENE
* UREA VIA CONDENSATION OF AMMONIA AND CARBON DIOXIDE
FORMALDEHYDE VIA AIR OXIDATION OF METHANOL
FORMALDEHYDE FROM DEHYDROGENATION OF HETHANOL
FORMALDEHYDE FROM DEHYDROGENATION OF METHANOL
FORMALDEHYDE VIA AIR OXIDATION OF METHANOL
* UREA VIA CONDENSATION OF AMMONIA AND CARBON DIOXIDE
* UREA VIA CONDENSATION OF AMMONIA AND CARBON DIOXIDE
FORMALDEHYDE VIA AIR OXIDATION OF METHANOL
STYRENE PRODUCTION VIA DEHYDROGENATION OF ETHYLBENZENE
* SODIUM DODECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
ACETAH1DE VIA DISTILLATION OF AMMONIUM ACETATE
* AMMONIUM ACETATE VIA REACTION WITH ACETIC ACID AND AMMONIUM CARBONATE
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
BENZENE VIA HYOROOEALKYLATION/TRANSALKYLAT10N OF TOLUENE
METHYL TERT BUTYL ETHER VIA ETHERIFICATION OF ISOBUTYLENE AND METHANOL
DIISOOECYL PHTHALATE VIA CSTER1FICATION W/PHTHALIC ANHYDRIDE AND DECANOL
DIISOOCTVL PHTHALATE VIA ESTERIFICATION W/ PHTHAL1C ANHYDRIDE 1 OCTYL ALCOH
MALEIC ANHYDRIDE VIA AIR OXIDATION OF BUTENES
RESORCINOL VIA SULFONATE FUSION PROCESS
CUMENE HYDROPEROXIDE VIA OXIDATION OF CUMENE
PHENOL VIA ACID CLEAVAGE OF CUMENE HYDROPEROXIDE
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
BENZENE VIA HYOROOEALKYLATION/TRANSALKYLATION OF TOLUENE
Included for analysts of economic Impacts, but unit would not be subject to the HON
5-16
-------
5.0 LIST OP FACILITIES USED IN THE HON IMPACTS ANALYSIS
This section lists facilities that were used in the HON
impacts analysis and which may be affected by the promulgated
regulation. These soureces were identified through data
gathering and engineering analysis. This list may contain
outdated or inaccurate information as it was compiled in 1990
ago, and some sources may have ceased production of SOCMI
chemicals, changed ownership, or changed operations since then.
At the same time, there may be other sources that are not on the
list but may be subject to the rule. For these reasons, this
list should not be used to determine whether a facility is
subject to the HON rule. Only the applicability criteria stated
in the regulation and the latest information available on
facility operations should be used to determine whether a source
is subject to the rule.
The processes in the attached list that are designated by an
asterisk (*) were not considered subject to the HON in the
economics impacts analysis. However, these processes must be
included in the cumulative cost analysis (see BID Volume 1A,
Chapter 6) because they form links in the SOCMI production chain.
5-1
-------
State Ctty
Factllty Name
Chemical Manufacturing Facilities Including the HON Impacts Analysts
Production Process
TN
TN
IN
TN
TN
TX
TX
IX
TX
.TX
TX
TX
TX
TX
TX
TX
KINGSPORT
KINGSPORT
KINGSPORT
MEMPHIS
OLD HICKORY
BAr C1TT
BAY CITY
BAYPORT
BAYPORT
BAYPORT
BAYPORT
BAYPORT
BAYPORT
BAYPORT
BAYPORT
BAYTOUN
EASTMAN CHEMICAL
EASTMAN KODAK
TENNESSEE EASTMAN
DU PONT
OU PONT
HOECHST CELANESE CHEMICAL
HOECHST CELANESE CORPORATION
AMERICAN HOECHST
ARCO CHEMICAL
CONZA, INC.
GOODYEAR
HOECHST CELANESE CORPORATION
LONZO. INC.
OCCIDENTAL CORPORATION
OXY PETROCHEMICALS
ADVANCED AROMATICS
PROPIONIC ACID VIA AIR OXIDATION OF PROPIONALOEHYDE
ETHYLENE 6LYCOL MONOBUTYL ETHER ACETATE VIA ESTERIFICATION OF E.G.MB ETHER
METHANOL VIA HYDROGENATION OF CARBON MONOXIDE
HYDROGEN CYANIDE VIA AIR OXIDATION OF METHANE ',
METHYL HETHACRYLATE VIA HYDROLYSIS AND ALKYLATION OF ACETONE CYANOHYDRIN
SODIUM CYANIDE VIA NEUTRALIZATION OF HYDROGEN CYANIDE BY SODIUM HYDROXIDE
DIMETHYL TEREPHTHALATE VIA ESTERIFICATION OF TPA
TEREPHTHALIC ACID VIA OXIDATION OF P-XYLENE
ACETALOEHYOE VIA AIR OXIDATION OF ETHYLENE
ACETIC ACID VIA OXIDATION OF ACETALOEHYDE WITH CATALYST
BUTYL ALCOHOL (N-ISOMER) VIA HYDROFORMVLATION OF PROPYLENE THEN HYDROGENATION OF N-BUTYHAIDIH
BUTYRALOEHYDE (N-ISOMER) VIA HYDROFORMYLATION OF PROPVLENE
HYDROFORMYLATION OF ETHYLENE THEN HYDROGENATION OF PROPIONALDEHYDE/OXO PROC
VINYL ACETATE VIA OXVACETYLATION OF ETHYLENE
STYRENE PRODUCTION VIA DEHYOROGENATION OF ETHYLBENZENE
ALLYL ALCOHOL VIA HYDROLYSIS OF ALLYL CHLORIDE
ALLYL ALCOHOL VIA ISOMERIZATION OF PROPENE OXIDE
ISOBUTYLENE VIA DEHYDRATION OF TERT-BUTYL ALCOHOL
PROPYLENE 6LYCOL MONOMETHYL ETHER VIA ALCOHOLV. PROPVLENE OXIDE BY METHANOL
PROPYLENE 6LYCOL VIA HYDROLYSIS OF PROPYLENE OXIDE
PROPYLENE OXIDE VIA EPOXIDATION OF T-BUTYL HYDROPEROXIOE
T-BUTYLHYDROPEROXIDE VIA OXIDATION OF ISOBUTANE
KETENE VIA DEHYDRATION OF ACETIC ACID
HYDROQUINONE VIA OIISOPROPYL-BENZENE HTDROPEROXIDE CLEAVAGE
BENZENE VIA HYDROOEALKYLATION/TRANSALKYLAT10N OF TOLUENE
ETHYLBENZENE VIA ALKYLATION OF BENZENE HUH ETHYLENE
DIKETENE VIA SPONTANEOUS DIMERIZATION OF KETENE
ETHANOLAMINE VIA ANNONOLYSIS OF ETHVLENE OXIDE
ETHYLENE 6LVCOL MONOB. ETHER VIA ALCOHOLYSIS OF ETHYLENE OXIDE BY BUTAKd
ETHYLENE 6LVCOL MONOETH. ETHER VIA ALCOHOL YS IS OF ETHYLENE OXIDE BY UHASJL
ETHYLENE GLVCOL MONOMETH. ETHER VIA ALCOHOLYSIS OF ETHYLENE OXIDE BY Ml 1HA.
ETHYLENE OXIDE VIA AIR OXIDATION OF ETHVLENE
ETHYLENE GLYCOL VIA HYDROLYSIS OF ETHYLENE OXIDE
NAPTHALENE FROM PETROLEUM DEALKYLATION
Included for analysts of economic Impacts, but unit would not be subject to the HON
5-18
-------
State City
Facility Name
Chemical Manufacturing Facilities Including the HON Impacts Analysts
Production Process
CA BREA
CA CARSON
CA EL SEGUNDO
CA FREMONT
CA IRWINDALE
CA LOS ANGELES
CA MARTINEZ
CA PASADENA
CA PITTSBURG
CA SACRAMENTO
CA SANTA FE SPRINGS
CA SANTA FE SPRINGS
CA SANTA FE SPRINGS
CA SOUTH GATE
CA SUN VALLEY
CT BETHANY
CT GROTON
CT NAUGATUCK
CT NORTH HAVEN
OE CLAYMONT
OE CLAYMONT
DE CLAYMONT
OE DELAWARE CITY
DE DELAWARE CITY
DE DELAWARE CUT
FL JACKSONVILLE
FL PACE
UNOCAL CORPORATION
MONSANTO CORPORATION
ALLIED CHEMICAL
BORDEN CHEMICAL
SPECIALTY ORGANICS, INC
UNILEVER US. INC.
SHELL OIL COMPANY
TENNECO
DOW
PROCTER I GAMBLE CO.
PILOT CHEMICAL CO.
PMC. INC.
WITCO CORPORATION
GREYHOUND CORP.
REDELL INDUSTRIES
CARBOLABS. INC.
PFIZER. INC
UNIROYAL CHEMICAL
UPJOHN CO.
HENLEY MANUFACTURING
HENLEY MANUFACTURING CO.
SUN COMPANY. INC.
AKZO CHEMICALS
STANDARD CHLORINE CHEMICAL
TEXACO
ASTOR PRODUCTS
AIR PRODUCTS
UREA VIA CONDENSATION OF AMMONIA AND CARBON DIOXIDE
LINEAR ALKYLBENZENE VIA ALKYLATION OF N-CHLOROPARAFFINS
N-CHLOROPARAFFINS VIA HALOGENATION OF M-PARAFFINS
CFC VIA LIQUID PHASE CATALYTIC REACTION
CFC-142 VIA HALOGENATION OF CHLORO COMPOUNDS
CFC-22 VIA HALOGENATION OF CHLOROFORM
FORMALDEHYDE FROM DEHYDROGENATION OF METHANOL
CHLOROPHENOLS VIA HYDROLYSIS OF CHLOROBENZENE
SODIUM DODECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
BUTYL ALCOHOL (T-) VIA HYDRATION OF ISOBUTVLENE
METHANOL VIA HYDROGENATION OF CARBON MONOXIDE
CARBON TETRACHLORIOE VIA CHLORINATION OF HYDROCARBONS
PERCHLOROETHYLENE VIA CHLORINATION OF ETHYLENE DICHLORIDE
SODIUM DODECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
SODIUM DODECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
CRESOLS/CRESYLIC ACIDS (P-ISOMER) VIA ALKALI FUSION OF TOLUENE SULFONATES
POLYETHYLENE GLYCOL VIA POLYMERIZATION OF ETHYLENE GLYCOL I ETHVLENE OXIDE
SODIUM DODECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
SODIUM DODECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
DIMETHYL FORMAMIDE VIA CARBONYLATION OF OIMETHYLAMINE
PERCHLOROMETHYL MERCAPTAN VIA HALOGENATION OF CARBON DISULF10E
SORBIC ACID VIA CONDENSATION OF KETENE I CROTONALDEHYDE
NONYLPHENOL VIA ALKYLATION OF PHENOL
BENZOPHENONE VIA ACYLATION OF BENZENE t BENZOYL CHLORIO
SUCCINIC ACID VIA FERMENTATION OF AMMONIUM TARTRATE
ACETAMIDE VIA DISTILLATION OF AMMONIUM ACETATE
AMMONIUM ACETATE VIA REACTION WITH ACETIC ACID AND AMMONIUM CARBONATE
ETHYLENE OXIDE VIA AIR OXIDATION OF ETHYLENE
CARBON DISULFIDE VIA SULFONATION OF METHANE
CHLOROBENZENE VIA HALOGENATION OF BENZENE
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
NAPTHALENE FROM PETROLEUM DEALKVLATION
SODIUM DODECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
MORPHOLINE VIA HYDROGENATION OF DIETHYLENE GLYCOL
Included for analysis of economic impacts, but unit would not be subject to the HON
5-3
-------
Chemical Manufacturing Facilities Including the HOH Impacts Analysts
State City
Factllty Name
Production Process
IL
1L
IL
IL
IL
IL
IL
IL
IL
II
IL
IL
IL
IN
IN
IN
IN
IN
IN
IN
IN
IN
IN
IN
KS
DANVILLE
GEORGETOWN
GURNEE
JOLIET
LYONS
MILLSOALE
MILLSDALE
MORRIS
SAUGET
SAUGET
SEUARD
SKOKIE
WOOD RIVER
HAHHONO
HAMMOND
INDIANAPOLIS
JEFFERSONVILLE
MOUNT VERNON
NT. VERNON
MUNCIE
TERRA HAUTE
TERRE HAUTE
TERRE HAUTE
WHITING
EL DORADO
ALLIED CHEMICAL
CL INDUSTRIES
PPG INDUSTRIES
AMOCO CHEMICAL
PELRON
STEPAN CHEMICAL
STEPON CO.
QUANTUM CHEMICALS
MONSANTO
MONSANTO CORPORATION
OLIN CORPORATION
HODAG CHEMICAL
SHELL OIL COMPANY
UNILEVER US. INC.
VISTA CHEMICAL CO.
RE ILLY INDUSTRIES
COLGATE-PALMOLIVE CO.
GENERAL ELECTRIC
GENERAL ELECTRIC
HAK CHEMICAL CORP
PFIZER INC.
PFIZER. INC.
PITMAN-MOORE (IMC)
AMOCO CHEMICAL
TEXACO
CFC-22 VIA HALOGENATION OF CHLOROFORM
BENZENE SULFONIC ACID VIA CONTINUOUS SULFONATION W/ OLEUM
POLYPROPYLENE 6LYCOL VIA POLYMER OF PROPVLENE OXIDE AND PROPYLENE GLYCOL
ISOPHTHAL1C ACID VIA AIR OXIDATION OF M-XYLENE
MALEIC ANHYDRIDE VIA AIR OXIDATION OF BUTENES
POLYETHYLENE 6LYCOL VIA POLYMERIZATION OF ETHYLENE GLYCOL t ETHYLENE OXIDE
POLYPROPYLENE 6LYCOL VIA POLYMER OF PROPYLENE OXIDE AND PROPYLENE GLYCOL
PHTHALIC ANHYDRIDE VIA AIR OXIDATION OF 0-XYLENE
* SODIUM DODECYL IENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
ETHYLENE GLYCOL VIA HYDROLYSIS OF ETHVLENE OXIDE
ETHYLENE OXIDE VIA AIR OXIDATION OF ETHYLENE
* NITROANILINE (P-) VIA AMMONOLYSIS OF P-CHLORONITROB.
CHLOROBENZENE VIA HALOGENATION OF BENZENE
CHLORONITROBENZENE (P-ISOMER) VIA NITRATION OF CHLOROBENZENE
TRICHLOROETHANE (1.1. 2-) VIA HALOGENATION OF ETHYLENE
POLYETHYLENE GLYCOL VIA POLYMERIZATION OF ETHYLENE GLYCOL 1 ETHYLENE OXIDE
POLYPROPYLENE GLYCOL VIA POLYMER OF PROPYLENE OXIDE AND PROPYLENE GLYCOL
* ACETONE PRODUCTION VIA DEHYDROGENATION OF ISOPROPANOL
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
* SODIUM DODECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
* SODIUM DOOECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
PYRIDINE VIA CONDENSATION OF ACETALDEHYDE AND FORMALDEHYDE
' SODIUM DOOECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
CUMENE HYDROPEROXIDE VIA OXIDATION OF CUMENE
PHENOL VIA ACID CLEAVAGE OF CUMENE HYDROPEROXIDE
BISPHENOL A VIA CONDENSATION OF PHENOL AND ACETONE
PHOSGENE VIA HALOGENATION OF CARBON MONOXIDE
* SODIUM CARBOXYMETHYL CELLULOSE VIA CELLULOSE AND SODIUM CHLOROACETATE
* SODIUM BENZOATE VIA ADDITION OF BENZOIC ACID TO S. HYDROXIDE
BENZOIC ACID VIA OXIDATION OF TOLUENE
FUMARIC AC10 VIA HYDRATION OF MALEIC ANHYDRIDE
METHYLAMINES VIA METHYLATION OF AMMONIA
METHYL TERT BUTYL ETHER VIA ETHERIFICATION OF ISOBUTYLENE AND METHANOL
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
Included for analysts of economic Impacts, but unit would not be subject to the HON
5-5
-------
Chemical Manufacturing Facilities Including the HON Impacts Analysis
State City
Facility Name
Production Process
IX
IX
TX
IX
TX
IX
TX
TX
TX
TX
TX
BORGER
BORGER
BROWNSVILLE
BROWNSVILLE
CHANNELVIEU
CHANNELVIEU
CHANNELVIEW
CHOCOLATE BAYOU
CHOCOLATE BAYOU
CHOCOLATE BAYOU
CHOCOLATE BAYOU
TX CHOCOLATE BAYOU
TX CHOCOLATE BAYOU
TX CLEAR LAKE
PHILLIPS PETROLEUM CO.
PHILLIPS PETROLEUM COMPANY
TEKNOR APEX CO.
UNION CARBIDE
ARCO CHEMICAL
ATLANTIC RICHFIELD COMPANY
LYONDELL PETROCHEMICAL
AMOCO CHEMICAL
CAIN CHEMICAL
CONOCO
MONSANTO CORPORATION
HONSATO
OCCIDENTAL CORPORATION
HOECHST CELANESE CORPORATION
TRIMETHVLPENTANE (2.2.4-) (M-) VIA ALKYLATION OF ISOBUTYLENE AND ISO-BUTANE
CYCLOHEXANE VIA HYDROGENATION OF BENZENE
SULFOLANC VIA ADDITION OF SULFUR DIOXIDE TO BUTADIENE
DI1SODECYL PHTHALATE VIA ESTERIFICATION W/PHTHALIC ANHYDRIDE AND DECANOL
DIISOOCTYL PHTHALATE VIA ESTERIFICATION U/ PHTHALIC ANHYDRIDE I OCTYL ALCOH
ACETIC ANHYDRIDE VIA DEHYDRATION OF ACETIC ACID
BUTYL ALCOHOL (S-ISOHER) VIA HYDROLYSIS OF _ - BUTYLENE
ETHYLBENZENE VIA ALKYLATION OF BENZENE WITH ETHYLENE
ISOBUTYLENE VIA DEHYDRATION OF TERT-BUTYL ALCOHOL
METHYL TERT BUTYL ETHER VIA ETHERIFICATION OF ISOBUTYLENE AND METHANOL
STYRENE VIA DEHYDRATION OF METHYL BENZYL ALCOHOL
BENZENE VIA HYDROGENATION OF PYROLYSIS GAS
BUTADIENE VIA CATALYTIC REFORMATION OF C4 STREAMS
METHANOL VIA HYOROGENATION OF CARBON MONOXIDE
METHYL ETHYL KETONE VIA DEHYDROGENAT10N OF S-BUTYL ALCOHOL
METHYL TERT BUTYL ETHER VIA ETHERIFICATION OF ISOBUTYLENE AND METHANOL
BUTADIENE VIA CATALYTIC REFORMATION OF C4 STREAMS
BUTADIENE VIA CATALYTIC REFORMATION OF C4 STREAMS
XYLENE (0-) VIA FRACTIONAL DISTILLATION OF MIXED XYLENE
XYLENE (P-) VIA PURIFICATION OF MIXED XYLENE
ACRYLONITRILE VIA AIR OXIDATION OF PROPYLENE
FORMALDEHYDE FROM OEHYDROGENATION OF METHANOL
KETENE VIA DEHYDRATION OF ACETIC ACID
LINEAR ALKYLBENZENE VIA ALKVLATION OF N-CHLOROPARAFFINS
N-CHLOROPARAFFINS VIA HALOGENATION OF K-PARAFFINS
DIPHENYL OXIDE VIA HYDROLYSIS OF CHLOHOBENZENE
SORBIC ACID VIA CONDENSATION OF KETENE I CROTONALOEHYDE
BENZENE VIA HVDftODEALKVLATION/TRANSALKYLATION OF TOLUENE
BENZENE VIA HYOROGENATION OF PYROLYSIS GAS
ACETIC ACID VIA CARBONYLAflOK OF HETHAMOL
ACRYLIC ACID VIA OXIDATION OF ACROLE1N. ACROL.IN MOrt OXIOAIlUn OF IV.
BUTYL ACRYLATE (N-ISOMER) VIA ESTERIFICATION OF ACRYLIC ACID
ETHYL ACRYLATE VIA ESTERIFICATION OF ACRYLIC ACID BY ETHYL ALCOHOL
ETHYLENE GLYCOL VIA HYDROLYSIS OF ETHYLENE OXIDE
Included for analysts of economic Impacts, but unit would not be subject to th« HON
-------
State City
Facility Name
Chemical Manufacturing Facilities Including the HON Impacts Analysts
Product ton Procesi
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
ALEXANDRIA
ALLIANCE
BATON ROUGE
BATON ROUGE
BATON ROUGE
BATON ROUGE
CARVILLE
CHALMETTE
CMALMETTE
CHARLES
CONVENT
DONALDSONVILLE
DONALDSONVILLE
DONALOSONVILLE
FORTIER
PROCTER t GAMBLE CO.
SOHIO OIL COMPANY
ALLIED CHEMICAL
EXXON CORPORATION
FERRO CORP.
FORMOSA PLASTICS
COS-MAR
MOBIL CORPORATION
TENNECO
VISTA CHEMICAL CO.
OCCIDENTAL
CF INDUSTRIES
FREEPORT - MCMORAN
TRIAD
AMERICAN CYANAH10
SODIUM DOOECYL BENZENE SULFONATE VIA SULFQNATION OF LINEAR ALKYL BENZENE
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
BENZENE VIA HYDRODEALKYLATION/TRANSALKYLATION OF TOLUENE
CFC-142 VIA HALOGENATION OF CHLORO COMPOUNDS
CFC-22 VIA HALOGENATION OF CHLOROFORM
TRICHLOROTRIFLUOROETHANE VIA HALOGENATION OF PERCHLOROETHYLENE
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
BENZENE VIA HYOROGENATION OF PYROLVSIS GAS
BUTADIENE VIA CATALYTIC REFORMATION OF C4 STREAMS
DIISOOECYL PHTHALATE VIA ESTERIFICATION W/PHTHALIC ANHYDRIDE AND DECANOL
D1ISOOCTYL PHTHALATE VIA ESTERIFICATION W/ PHTHALIC ANHYDRIDE & OCTYL ALCOH
ISOBUTYLENE VIA CRACKING OF MTBE
METHYL ETHYL KETONE VIA DEHYDR06ENATION OF S-BUTYL ALCOHOL
NEOPENTANOIC ACID VIA CARBONYLATION OF ISOBUTYLENE
PHTHALIC ANHYDRIDE VIA AIR OXIDATION OF 0-XYLENE
DIETHVLENE GLYCOL DIMETHYL ETHER VIA HYDROGENATION OF OEGMH ETHER
DIOXANE (1.4-) VIA DEHYDROHAL06ENATION OF CHLOROHYDRIN
DIOXOLANE VIA CONDENSATION OF GLYCOL AND FORMALDEHYDE
ETHYLENE DICHLORIDE VIA CHLORINATION/OXYCHLORINATION OF ETHYLENE
VINYL CHLORIDE VIA DEHVDROHALOGENATION OF ETHYLENE DICHLORIDE BY THERMAL CRACKING
ETHYLBENZENE VIA ALKYLATION OF BENZENE WITH ETHYLENE
STYRENE PRODUCTION VIA DEHYDROGENATION OF ETHYLBENZENE
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
XYLENE (0-) VIA FRACTIONAL DISTILLATION OF MIXED XYLENE
XYLENE (P-) VIA PURIFICATION OF MIXED XYLENE
ETHYLENE DICHLORIDE VIA CHLORINATION/OXYCHLORINATION OF ETHYLENE
METHYL CHLORIDE VIA HVDROHALOGENATION OF METHANOL
ETHYLBENZENE VIA ALKYLATION OF BENZENE WITH ETHYLENE
ETHYLENE DICHLORIDE VIA CHLORINATION/OXYCHLORINATION OF ETHYLENE
UREA VIA CONDENSATION OF AMMONIA AND CARBON DIOXIDE
UREA VIA CONDENSATION OF AMMONIA AND CARBON DIOXIDE
UREA VIA CONDENSATION OF AMMONIA AND CARBON DIOXIDE
ACRYLAMIDE VIA HYDROLYSIS OF ACRYLONITRILE
ACRYLONITRILE VIA AIR OXIDATION OF PROPYLENE
Included for analysts of economic Impacts, but unit would not be subject to the HON
5-7
-------
Chemical Manufacturing Facilities Including the HON Impact? Analysis
State City
Facility Name
Productton Process
TX
IX
IX
IX
IX
IX
TX
IX
IX
DEER PARK
DEER PARK
DEER PARK
DEtR PARK
DEER PARK
DEER PARK
DEER PARK
DIBOLL
FREEPORT
OCCIDENTAL CORPORATION
QUANTUM CHEMICALS
ROHM AND HAAS COMPANY
SHELL OIL CO.
SHELL OIL COMPANY
US1 DIVISION
U.R. GRACE AND CO.
BORDEN CHEMICAL
BASF
TX
FREEPORT
DOW
VINYL CHLORIDE VIA DEHYDROHAL06ENATION OF ETHYLENE DICHLORIDE BY THERMAL CRACKING
METHANOL VIA HYOROGENATION OF CARBON MONOXIDE
ACRYLIC ACID VIA OXIDATION OF ACROLE1N. ACROLEIN FROM OXIDATION OF PROPYLEH
BUTYL ACRYLATE (N-ISOMER) VIA ESTERIFICATION OF ACETYLENE
ETHYL ACRYLATE VIA ESTERIFICATION OF ACRYLIC ACID BY ETHYL ALCOHOL
HYDROGEN CYANIDE VIA AIR OXIDATION OF METHANE
METHYL METHACRVLATE VIA HYDROLYSIS AND ALKYLATION OF ACETONE CYANOHYDRIN
NONYLPHENOL VIA ALKYLATION OF PHENOL
DIACETONE ALCOHOL VIA CONDENSATION OF ACETONE
ACETONE PRODUCTION VIA DEHYDROGENATION OF 1SOPROPANOL
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
BENZENE VIA HYDROGENATION OF PYROLVSIS GAS
8ISPHENOL A VIA CONDENSATION OF PHENOL AND ACETONE
BUTADIENE VIA CATALYTIC REFORMATION OF C4 STREAMS
BUTYL ALCOHOL (N-ISOMER) VIA HYDROFORMVLATION OF PROPYLENE THEN HYDROGENATION OF N-BUTYRAIDEH
CUMENE HYDROPEROXIDE VIA OXIDATION OF CUMENE
CUMENE VIA ALKYLATION OF BENZENE WITH PROPYLENE
EPICHLOROHYDRIN VIA CHLOROHYDRATION OF ALLVL CHLORIDE
MESITYL OXIDE VIA DEHYDRATION OF DIACETONE AND HYDROGENATION OF DOUBLE BOND
PHENOL VIA ACID CLEAVAGE OF CUMENE HYDROPEROXIOE
XYLENE (0-) VIA FRACTIONAL DISTILLATION OF MIXED XYLENE
ACETIC ACID VIA CARBONYLATION OF METHANOL
GLYCINE VIA AMHONOLVSIS OF CHLOROACETIC ACID
FORMALDEHYDE FROM DEHYDROGENATION OF METHANOL
ACRYLIC ACID VIA OXIDATION OF ACROLEIN. ACROLEIN FROM OXIDATION OF PROPYLEN
BUTYL ACETATE VIA ESTERIFICATION OF BUTYL ALCOHOL
BUTYL ACRYLATE (N-ISOMER) VIA ESTERIFICATION OF ACRYLIC ACID
BUTYL ALCOHOL (N-ISOMER) VIA HYDROFORMYLATION OF PROPYLENE THEN HYDROGENATION OF N u.llVRAU
BUTYRALOEHYDE (N-ISOMER) VIA HYDROFORMYLATION OF PROPYLENE
CAPROLACTAM PRODUCTION VIA REARRANGEMENT OF CYCLOHEXANONE
CYCLOHEXANONE VIA AIR OXIDATION OF CYCLOHEXANE
ETHYL ACRYLATE VIA ESTERIFICATION OF ACRYLIC ACID BY ETHYL ALCOHOL
ETHVLHEXANOL (Z-ISOMER) VIA 0X0 PROCESS OF PROPYLENE
ALLYL CHLORIDE VIA HALOGENATION OF PROPENE
Incl uded for analysis of economl c Impacts, but uni t would not be subject to the HON
-------
Chemical Manufacturing Facilities Including the HOH Inpacta Analysis
State City
Facility Name
Production Process
LA
LA
LAKE CHARLES
LAKE CHARLES
OLIN CORPORATION
PPG INDUSTRIES
LA
LA
LA
LA
LAKE CHARLES
LAPLACE
NEW ORLEANS
NORCO
VISTA CHEMICAL CO.
DU PONT
CYRO IND.
SHELL OIL COMPANY
LA
LA
PLAQUEMINE
PLAQUEMINE
ASHLAND CHEMICALS
DOW
PHOSGENE VIA HALOGENATION OF CARBON MONOXIDE
TOLUENE DIISOCVANATES VIA DINITRATION OF TOLUENE WITH PHOSEGENAT10N
UREA VIA CONDENSATION OF AMMONIA AND CARBON DIOXIDE
ETHYL CHLORIDE VIA HVOROCHLORINATION OF EHTYLENE
ETHYLENE DICHLORIDE VIA CHLORINATION/OXYCHLORINATION OF ETHYLENE
PERCHLOROETHYLENE VIA OXYCHLORINATION OF ETHYLENE OICHLORIDE
TRICHLOROETHANE (1.1.1-) VIA HYDROHALOGENATION OF VINYL CHLORIDE
TRICHLOROETHYLENE VIA CHLORINATION OF ETHYLENE DICHLORIDE
VINYL CHLORIDE VIA DEHYDROHALOGENATION OF ETHYLENE DICHLORIDE BY THERMAL CRACKING
VINYLIOENE CHLORIDE VIA DEHYDROCHLORINATION OF 1.1.2-TRICHLOROETHANE
LINEAR ALKYLBENZENE VIA ALKVLATION OF N-CHLOROPARAFFINS
N-CHLOROPARAFFINS VIA HALOGENATION OF N-PARAFFINS
VINYL CHLORIDE VIA OEHYDROHALOGENATION OF ETHYLENE DICHLORIDE BY THERMAL CRACKING
CHLOROPRENE VIA OEHYDROHALOGENATION OF 3.4-OICHLORO-l-BUTENE
METHYL HETHACRVLATE VIA HYDROLYSIS AND ALKYLATION OF ACETONE CYANOHYORIN
ALLYL CHLORIDE VIA HALOGENATION OF PROPENE
BUTADIENE VIA CATALYTIC REFORMATION OF C4 STREAMS
BUTYL ALCOHOL (S-ISOMER) VIA HYDROLYSIS OF _ - BUTYLENE
METHYL ETHYL KETONE VIA DEHYDROGENATION OF S-BUTYL ALCOHOL
SULFOLANE VIA ADDITION OF SULFUR DIOXIDE TO BUTADIENE
METHANOL VIA HYDR06ENATION OF CARBON MONOXIDE
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
BENZENE VIA HYDROOEALKVLATION/TRANSALICVLATION OF TOLUENE
CARBON TETRACHLORIDE VIA CHLORINATION OF HYDROCARBONS
CHLOROFORM VIA HALOGENATION OF METHYL CHLORIDE
ETHANOLAMINE VIA AMHONOLVSIS OF ETHYLENE OXIDE
ETHYLENE DICHLORIDE VIA CHLORINATION/OXYCHLORINATION OF ETHYLENE
ETHYLENE GLYCOL MONOB. ETHER VIA ALCOHOLYSIS OF ETHYLENE OXIDE BY BUTANOL
ETHYLENE 6LVCOL HONOETH. ETHER VIA ALCOHOLYSIS OF ETHYLENE OXIDE BY ETHANOL
ETHYLENE GLYCOL MONOMETH. ETHER VIA ALCOHOLYSIS OF ETHYLENE OXIDE BY HETHA.
ETHYLENE GLYCOL VIA HYDROLYSIS OF ETHVLENE OXIDE
ETHYLENE OXIDE VIA AIR OXIDATION OF ETHYLENE
METHYL CHLORIDE VIA HYOROHALOGENATION OF METHANOL
PERCHLOROETHYLENE VIA CHLORINATION OF ETHYLENE DICHLORIDE
Included for analysis of economic Impacts, but unit would not be subject to the HON
5-9
-------
Chemical Manufacturing Facilities Including the HON Impacts Analysis
State City
Facility Name
Product ton Process
IX
TX
rx
TX
TX
TX
TX
TX
IX
IX
TX
TX
TX
TX
TX
TX
TX
HOUSTON
HOUSTON
HOUSTON
HOUSTON
HOUSTON
HOUSTON
HOUSTON
HOUSTON
HOUSTON
LA PORTE
LA PORTE
LA PORTE
LA PORTE
LA PORTE
LONGVIEW
LUFKIN
ODESSA
HILL PETROLEUM
HERICHEN CO.
HOBAY SYNTHETICS CORP.
PENNUALT CORP.
SALOMON INC
TEXAS OLEFINS
TEXAS OLEFINS CORP
TEXAS PETROCHEMICALS
UITCO CORPORATION
B. F. GOODRICH
DOW
DU PONT
PPG INDUSTRIES
QUANTUM CHEMICALS
EASTMAN CHEMICAL
GEORGIA-PACIFIC
EL PASO NATURAL GAS CO.
METHYL TERT BUTYL ETHER VIA ETHERIFICATION OF ISOBUTYLENE AND METHANOL
CRESOLS/CRESVLIC ACIDS (MIX) VIA RECOVERY FROM SPENT REFINERY CAUSTICS
MALEIC ANHYDRIDE VIA AIR OXIDATION OF BUTENES
CARBON OISULFIDE VIA SULFONATION OF METHANE
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
ISOBUTYLENE VIA CRACKING OF MTBE
* 01 ISOBUTYLENE VIA HYDRODIMERIZATION OF ISOBUTENE
BUTADIENE VIA DEHYDROGENATION OF C4 COMPOUNDS
METHYL TERT BUTYL ETHER VIA ISOMERIZATION OF BUTANE
POLYETHYLENE GLYCOL VIA POLYMERIZATION OF ETHYLENE GLYCOL ft ETHYLENE OXIDE
* SODIUM DODECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALICYL BENZENE
ETHYLENE D1CHLORIOE VIA CHLORINATION/OXYCHLORINATION OF ETHYLENE
VINYL CHLORIDE VIA DEHYDROHALOGENATION OF ETHYLENE DICHLORIDE BY THERMAL CRACKING
4.4-METHYLENEDIANILINE VIA CONDENSATION OF ANILINE WITH FORMALDEHYDE
MO I VIA REACTING 4.4 METHYLENEDIANILINE VITH PHOSGENE
PHOSGENE VIA HALOGEN AT I ON OF CARBON MONOXIDE
FORMALDEHYDE FROM DEHYDROGENATION OF METHANOL
METHYL ISOCYANATE VIA PHOS6ENATION OF METHYLAMINE
VINYL ACETATE VIA OXYACETYLATION OF ETHYLENE
PHOSGENE VIA HALOGENATION OF CARBON MONOXIDE
VINYL ACETATE VIA OXYACETYLATION OF ETHYLENE
ACETALDEHVDE VIA AIR OXIDATION OF ETHYLENE
* BUTYL ALCOHOL (N-ISOMER) VIA HYDROFORMYLATION OF PROPVLENE THEN HYDROGENATION OF N-BUTYRALOEli
* BUTYRALOEHVDE (N-ISOMER) VIA HYDROFORMYLATION OF PROPVLENE
ETHYLENE GLYCOL HONOB. ETHER VIA ALCOHOLYSIS OF ETHYLENE OXIDE BY BUTANOL
ETHYLENE 6LVCOL MONOETH. ETHER VIA ALCOHOLYSIS OF ETHYLENE OXIDE BY ETHANOL
ETHYLENE GLYCOL MONOMETH. ETHER VIA ALCOHOLYSIS OF ETHYLENE OXIDE BY METHA.
ETHYLENE GLYCOL VIA HYDROLYSIS OF ETHYLENE OXIDE
ETHYLENE OXIDE VIA AIR OXIDATION OF ETHYLENE
* ETHVLHEXANOL (2-ISOMER) VIA 0X0 PROCESS OF PROPYLENE
HYDROFORMYLATION OF ETHYLENE THEN HYDROGENATION OF PROPIONALOEHYDE/OXO PROC
FORMALDEHYDE VIA AIR OXIDATION OF METHANOL
* ADIPONITRILE VIA DEHYDRATION OF ADIPIC ACID
STYRENE PRODUCTION VIA DEHYDROGENATION OF ETHYLBENZENE
Included for analysis ut economic impacts, but unit would not be subject to the HON
-------
Chemical Manufacturing Facilities Including the HON Impacts Analysts
State City
Facility Name
Production Process
HA
HO
HD
HO
HD
HD
HI
HI
HI
HI
HI
HN
HN
HO
HO
HO
SPRINGFIELD
BALTIHORE
BALTIMORE
BALTIMORE
BALTIMORE
CHESTERTOUN
MIDI AND
MIDLAND
MONTAGUE
TRENTON
WYANOOTTE
DULUTH
VIRGINIA
LOUISIANA
ST. LOUIS
ST. LOUIS
MONSANTO CORPORATION
ESSEX
PROCTER t GAMBLE CO.
UNILEVER US. INC.
VISTA CHEMICAL CO.
NUODEX INC.
DOU
DOW CORNING
DU PONT
MONSANTO CORPORATION
PENNWALT CORP.
MOBAY SYNTHETICS CORP
D.B. WESTERN
HERCULES INC.
CHEM-FLEUR
GREYHOUND CORP.
METHYL ACETATE VIA HYDROLYSIS OF POLYVINYL ACETATE BY METHANOL
PHOSGENE VIA HALQGENATION OF CARBON MONOXIDE
SODIUM DODECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
SODIUM DODECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
LINEAR ALKYLBENZENE VIA ALKYLATION OF N-CHLOROPARAFFINS
N-CHLOROPARAFFINS VIA HAL06ENATION OF N-PARAFFINS
OIISODECYL PHTHALATE VIA ESTERIFICATION V/PHTHALIC ANHYDRIDE AND DECANOL
OIISOOCTYL PHTHALATE VIA ESTERIFICATION W/ PHTHALIC ANHYDRIDE t OCTYL ALCOH
ACRYLAMIOE VIA HYDROLYSIS OF ACRYLONITRILE
CHLOROACETIC ACID VIA HYDROLYSIS OF CHLOROACETYL CHLORIDE
DIPHENYL OXIDE VIA HYDROLYSIS OF CHLOROBENZENE
ETHANOLAMINE VIA AMMONOLYSIS OF ETHYLENE OXIDE
ETHYL CELLULOSE VIA ETHYLATION OF CELLULOSE
ETHYLENE GLYCOL MONOB. ETHER VIA ALCOHOLYSIS OF ETHYLENE OXIDE BY BUTANOL
ETHYLENE GLYCOL MONOETH. ETHER VIA ALCOHOLYSIS OF ETHYLENE OXIDE BY ETHANOL
ETHYLENE GLVCOL HONOMETH. ETHER VIA ALCOHOLVSIS OF ETHYLENE OXIDE BY HETHA.
POLYPROPYLENE GLYCOL VIA POLYMER OF PROPYLENE OXIDE AND PROPYLENE GLYCOL
PROPYLENE GLVCOL HONOMETHYL ETHER VIA ALCOHOLY. PROPYLENE OXIDE BY METHANOL
SALICYLIC ACID VIA HYDROFORMYLATION OF SODIUM PHENATE
METHYL CHLORIDE VIA HYDROHALOGENATION OF METHANOL
CFC VIA LIQUID PHASE CATALYTIC REACTION
CFC-UZ VIA HAL06ENATION OF CHLORO COMPOUNDS
CFC-22 VIA HALOGENATION OF CHLOROFORM
TRICHLOROTRIFLUOROETHANE VIA HALOGENATION OF PERCHLOROETHYLENE
ETHYL ACETATE VIA HYDROLYSIS OF POLYVINYL ACETATE BY ETHANOL
BUTYLAMINE (T-) VIA ADDITION OF HCN TO ISOBUTYLENE
DIETHYLAMINE VIA ETHYLATION OF AMMONIA
ISOPROPYLANINE VIA AMINOLYSIS OF ISOPROPYL ALCOHOL
FUMARIC ACID VIA HYDRATION OF MALEIC ANHYDRIDE
FORMALDEHYDE FROM DEHYDROGENATION OF METHANOL
FORMALDEHYDE FROM DEHYDROGENATION OF METHANOL
PENTAERYTHRITOL VIA ADDITION OF FORMALDEHYDE TO ACETALDEHYDE
DIPHENYL OXIDE VIA HYDROLYSIS OF CHLOROBENZENE
SODIUM DODECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
Included for analysis of economic. Impacts, but unit would not be subject to the HON
5-11
-------
Chemical Manufacturing Facilities Including the HON Impacts Analysts
State City
Facility Name
Production Process
TX PORT NECHES
TX
TX
TX
TX
TX
TX
TX
TEXACO
SEADRIFT
UNION CARBIDE
SUNRAY
SWEENY
TEXAS CITY
DIAMOND SHAMROCK
PHILLIPS PETROLEUM COMPANY
AMOCO CHEMICAL
TEXAS CITY
TEXAS CITY
TEXAS CITY
GAF CORPORATION
MONSANTO CORPORATION
STERLING CHEMICALS INC.
ETHANOLAMINE VIA AHMONOLVSIS OF ETHYLENE OXIDE
ETHYLENE 6LYCOL VIA HYDROLYSIS OF ETHVLENE OXIDE
ETHYLENE OXIDE VIA AIR OXIDATION OF ETHYLENE
METHYL TERT BUTYL ETHER VIA ETHERIFICATION OF ISOBUTYLENE AND HETHANOL :
MORPHOLINE VIA HYDROGENATION OF DIETHYLENE 6LYCOL
NONYLPHENOL VIA ALKYLATION OF PHENOL
POLYETHYLENE 6LYCOL VIA POLYMERIZATION OF ETHYLENE GLYCOL & ETHYLENE OXIDE
ETHANOLAMINE VIA AMHONOLYSIS OF ETHYLENE OXIDE
ETHYLENE 6LVCOL HONOB. ETHER VIA ALCOHOLYSIS OF ETHVLENE OXIDE BY BUTANOL
ETHYLENE GLYCOL MONOETH. ETHER VIA ALCOHOLYSIS OF ETHYLENE OXIDE BY ETHANOL
ETHYLENE GLYCOL MONOMETH. ETHER VIA ALCOHOLYSIS OF ETHYLENE OXIDE BY ME1HA.
ETHYLENE GLYCOL VIA HYDROLYSIS OF ETHYLENE OXIDE
ETHYLENE OXIDE VIA AIR OXIDATION OF ETHYLENE
POLYETHYLENE GLVCOL VIA POLYMERIZATION OF ETHYLENE GLYCOL I ETHYLENE OXIDL
PROPYLENE GLYCOL MONOMETHYL ETHER VIA ALCOHOLY. PROPYLENE OXIDE BY HETHANOL
METHYL TERT BUTYL ETHER VIA ETHERIFICATION OF ISOBUTYLENE AND HETHANOL
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
BENZENE VIA HYDROGENATION OF PYROLYSIS GAS
CYCLOHEXANE VIA HYDROGENATION OF PETROLEUM FRACTIONS
METHYL TERT BUTYL ETHER VIA ETHERIFICATION OF ISOBUTYLENE AND HETHANOL
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
BENZENE VIA HYDROGENATION OF PYROLVSIS GAS
CUMENE VIA ALKVLATION OF BENZENE WITH PROPYLENE
ETHYLBENZENE VIA ALKVLATION OF BENZENE WITH ETHYLENE
STYRENE PRODUCTION VIA DEHVDR06ENATION OF ETHYLBENZENE
XVLENE (P-) VIA PURIFICATION OF NIXED XVLENE
FORMALDEHYDE VIA AIR OXIDATION OF HETHANOL
PHTHALIC ANHYDRIDE VIA AIR OXIDATION OF 0-XYLENE
ACETIC ACID VIA CARBONVLATION OF METHANOL
ACRYLONITRILE VIA AIR OXIDATION OF PROPYLENE
BUTYLAMINE (T-) VIA ADDITION OF HCN TO ISOBUTYLENE
DIISOOECYL PHTHALATE VIA ESTERIFICATION W/PHTHALIC ANHYDRIDE AND DECANOL
01ISOOCTYL PHTHALATE VIA ESTERIFICATION W/ PHTHALIC ANHYDRIDE ft OCTYL ALCOH
ETHYLBENZENE VIA ALKYLATION OF BENZENE WITH ETHYLENE
Included for analysis of economic impacts, but unit would not be subject to the HON
-------
State City
Facility Name
Chemical Manufacturing Facilities Including the HON Impacts Analysis
Production Process
NH
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NASHUA
AVEREL
BAYUAY
BIRMINGHAM
BOUND BROOK
BRIDGEPORT
BRIDGEPORT
BUONTON
CARTEVEI
CLIFTON
CLIFTON
DEEPUATER
DEEPUATER
DEER PARK
EAST HANOVER
EOISON
EDISON
EOISON
ELIZABETH
FAIRFItLD
U.R. GRACE AND CO.
PILOT LAB. INC.
EXXON CORPORATION
SYBRON CHEMICALS. INC.
GEORGIA GULF
MONSANTO COMPANY
MONSANTO CORPORATION
PPF
STARFLEX SPECIALTY ESTERS
CONTINENTAL CHEMICAL CO.
GIVAUDAN CORP.
DU PONT
OUPONT
ROHN AND HAAS CO.
BASF
AK20 AMERICA
AKZO CHEMICALS
STAUFFER
ALLIED CHEMICAL
PENTA MANUFACTURING CO.
GLYCINE VIA AMMONOLYSIS OF CHLOROACETIC ACID
SODIUM OOOECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
BUTYL ALCOHOL (S-ISOMER) VIA HYDROLYSIS OF _ - BUTYLENE
BIPHENYL VIA DEHYOROGENATION OF BENZENE
CUMENE HYDROPEROXIDE VIA OXIDATION OF CUMENE
PHENOL VIA ACID CLEAVAGE OF CUMENE HYOROPEROXIDE
TETRACHLOROPHTHAL1C ANHYDRIDE VIA HALOGENAT ION OF PHTHALIC ANHYDRIDE
BENZYL CHLORIDE VIA CHLORINATION OF TOLUENE
DIPHENYL OXIDE VIA HYDROLYSIS OF CHLOROBENZENE
DIISODECYL PHTHALATE VIA ESTERIF1CATION W/PHTHALIC ANHYDRIDE AND DECANOL
DIISOOCTYL PHTHALATE VIA ESTERIFICATION W/ PHTHALIC ANHYDRIDE & OCTYL ALCOH
SODIUM DOOECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
BENZYL BENZOATE VIA ESTERIFICATION OF BENZYL ALCOH
DIPHENYL OXIDE VIA HYDROLYSIS OF CHLOROBENZENE
CFC VIA LIQUID PHASE CATALYTIC REACTION
CFC-142 VIA HALOGENAT ION OF CHLORO COMPOUNDS
CFC-22 VIA HALOGENATION OF CHLOROFORM
CHLORONITROBENZENE (P-ISOMER) VIA NITRATION OF CHLOROBENZENE
CHLOROTRIFLUOROMETHANE VIA FLUORINATION OF CHLORO COMPOUNDS
DINITROTOLUENE (2.4-) VIA NITRATION OF NITROTOLUENE(P-)
ETHYL CHLORIDE VIA HYDROCHLORINATION OF EHTYLENE
PHOSGENE VIA HALOGENATION OF CARBON MONOXIDE
TETRAETHVL LEAD VIA ADDITION OF ETHYL CHLORIDE TO LEAD-SODIUM ALLOY
DIMETHYLANILINE VIA ALKYLATION OF ANILINE
NITROANILINE (P-) VIA AMMONOLYSIS OF P-CHLORONITROB.
METHACRVLIC ACID VIA OXIDATION OF ISOBUTYRALDEHYDE
ACETAL VIA CONDENSATION OF ETHANOL AND ACETALDEHYD
BENZOIN VIA ESTERIFICATION OF BENZALDEHYDE
BENZVLAMINE VIA AMMONOLYSIS OF BENZALDEHYOE
BENZYL ALCOHOL VIA HYDROLYSIS OF BENZYL CHLORIDE
BENZYL CHLORIDE VIA CHLORINATION OF TOLUENE
CFC-142 VIA HALOGENATION OF CHLORO COMPOUNDS
CFC-22 VIA HALOGENATION OF CHLOROFORM
BENZYL BENZOATE VIA ESTERIFICATION OF BENZYL ALCOH
Included (or analysis of economic Impacts, but unit would not be subject to the HON
5-13
-------
Chemical Manufacturing Facilities Including the HON Impacts Analysis
State City
Facility Name
Production Process
NJ WASHINGTON
NJ UESTVILLE
NH LAS VEGAS
NY BROCKPORT
NY BRONX
NY BUFFALO
NY HARRIHAN
NY HAUPPAUGE
NY LOCKPORT
NY NEW YORK
NY NEW YORK
NY NEWARK
NY NIAGARA FALLS
NY NIAGARA FALLS
NY NIAGARA FALLS
NY NORTH TONAWANDA
NY ROTTERDAM JUNCTION
NY WATERFORD
OH BARBERTON
OH CAMBRIDGE
OH CINCINNATI
OH COLUMBUS
OH HAVERHILL
OH IVORYDALE
OH LIMA
OH LOCKLAND
OH MIDDLETOUN
BASF
COASTAL CORPORATION
O.B. WESTERN
KLEEN BRITE LAB. INC.
HEXAGON LABORATORIES, INC
BUFFALO COLOR CORP.
CAMBROX CORPORATION
UNITED GUARDIAN. INC.
VAN DEHARK
BASF
FLORASYNTH
CHEM-FLEUR
NIACET CORP.
OCCIDENTAL CORPORATION
OCCIDENTAL PETROLEUM CO.
OCCIDENTAL CORPORATION
SCHENECTAOY CHEMICALS
GENERAL ELECTRIC
PPG INDUSTRIES
COLGATE-PALMOLIVE CO.
HILTON-DARIS
GEORGIA-PACIFIC
ARISTECH
PROCTER I GAMBLE CO.
BP AMERICA
PILOT CHEMICAL CO.
PILOT CHEMICAL CO.
POLYETHYLENE GLYCOL VIA POLYMERIZATION OF ETHYLENE GLYCOL & ETHYLENE OXIDE
POLYPROPYLENE GLYCOL VIA POLYMER OF PROPYLENE OXIDE AND PROPYLENE GLYCOL
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
CUHENE VIA ALKYLATION OF BENZENE WITH PROPYLENE
FORMALDEHYDE FROM DEHYDROGENATION OF METHANOL
SODIUM DODECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
CHLOROPHENOLS VIA HYDROLYSIS OF CHLOROBENZENE
DIMETHYLANILINE VIA ALKYLATION OF ANILINE
PYRIDINE VIA CONDENSATION OF ACETALDEHYDE AND FORMALDEHYDE
BROMONAPHTHALENE VIA HALOGENAT ION OF NAPHTHALENE
PHOSGENE VIA HALOGENATION OF CARBON MONOXIDE
DIPHENYL OXIDE VIA HYDROLYSIS OF CHLOROBENZENE
DIPHENYL OXIDE VIA HYDROLYSIS OF CHLOROBENZENE
DIPHENYL OXIDE VIA HYDROLYSIS OF CHLOROBENZENE
SODIUM ACETATE VIA ADDITION OF ACETIC ACID TO SODIUM HYDROXIDE
BENZOYL CHLORIDE VIA REACTION OF BENZOIC ACID AND BENZOTRICHLORIDE
CHLOROTOLUENE (0-) VIA HALOGENATION OF TOLUENE
HEXAHETHYLENETETRAMINE VIA ADDITION OF AMMONIA TO FORMALDEHYDE
NONYLPHENOL VIA ALKYLATION OF PHENOL
METHYL CHLORIDE VIA HYDROHALOGENATION OF METHANOL
PHOSGENE VIA HALOGENATION OF CARBON MONOXIDE
SODIUM DOOECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
SALICYLIC ACID VIA HYDROFORMYLATION OF SODIUM PHENATE
FORMALDEHYDE VIA AIR OXIDATION OF METHANOL
ANILINE VIA AMINOLYSIS OF PHENOL
BISPHENOL A VIA CONDENSATION OF PHENOL AND ACETONE
CUMENE HYDROPEROXIDE VIA OXIDATION OF CUHENE
PHENOL VIA ACID CLEAVAGE OF CUMENE HYDROPEROXIDE
SODIUM OOOECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
ACRVLONITRILE VIA AIR OXIDATION OF PROPYLENE
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
BENZENE VIA HYDRODEALKYLATION/TRANSALKYLATION OF TOLUENE
SODIUM DODECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
SODIUM DOOECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
Included for analysis of economic Impacts, but unit would not be subject to the HON
5-15
-------
Chemical Manufacturing Facilities Including the HON Impacts Analyst?
State Ctty
Facility Name
Production Process
UA KENT
UA SEATTLE
UI JAHESVILLE
Wl MARINEITE
WI MILWAUKEE
UI SHEBOYGAN
Wl SHEBOYGAN
uv
WV BELLE
UV BELLE
WV BELLE
WV FOLLANSBEE
WV INSTITUTE
WV INSTITUTE
WV MORGANTOWN
WV HOUNDSVILLE
WV NATRIUM
WV NEAL
WV NEW MARTINSVILLE
BORDEN CHEMICAL
HONSATO
AK20 AMERICA. INC
CHENOESIGN CORP.
ALORICH CHEMICAL CO.
BOROEN CHEMICAL
PLASTICS ENG. CO.
AMERICAN CYANAMID
OU PONT
DUPONT
OCCIDENTAL CORPORATION
KOPPERS
RHONE-POULENC INC.
UNION CARBIDE
GENERAL ELECTRIC
LCP CHEMICALS
PPG INDUSTRIES
ASHLAND CHEMICALS
MOBAY SYNTHETICS CORP.
FORMALDEHYDE FROM DEHYDR06ENATION OF METHANOL
OIPHENYL OXIDE VIA HYDROLYSIS OF CHLOROBENZENE
AMMONIUN THIOCYANATE VIA PYROYSIS OF AMMONIUM D1THIOCARBONATE
DIETHYLENE 6LYCOL DIMETHYL ETHER VIA HYDR06ENATION OF DEGMH ETHER
BENZYL BENZOATE VIA ESTERIFICATION OF BENZYL ALCOH
ETHYL ACRYLATE VIA ESTERIFICATION OF ACRYLIC ACID BY ETHYL ALCOHOL
FORMALDEHYDE FROM DEHYDROGENATION OF METHANOL
HEXAMETHYLENETETRAMINE VIA ADDITION OF AMMONIA TO FORMALDEHYDE
NAPHTHOL (B-ISOMER) VIA OXIDATION CLEAVAGE OF ISOPROPYL NAPHTHALENE
DIMETHYL FORMAMIDE VIA AMINOLYSIS OF METHYL FORMATE
FORMALDEHYDE FROM DEHYDROGENATION OF METHANOL
METHACRYL1C ACID VIA HYDROLYSIS OF ACETONE CYANOHYDRIN WITH SULFURIC AGIO SOLUTION
METHYLAMINES VIA METHYLATION OF AMMONIA
DIMETHYL ETHER (N.N-) VIA CATALYTIC DEHYDRATION OF METHANOL
DIMETHYL SULFATE VIA ESTERIFICATION OF METHVLC.S. I DI-H.S.
METHACRYLIC ACID VIA OXIDATION OF ISOBUTANE
CHLOROFORM VIA HALOGENATION OF METHYL CHLORIDE
METHYL CHLORIDE VIA HYDROHALOGENATION OF METHANOL
NAPHTHALENE FROM COAL TAR DISTILLATION
METHYL ISOCYANATE VIA PHOS6ENATION OF METHYLAMINE
PHOSGENE VIA HALOGENATION OF CARBON MONOXIDE
ACETONE PRODUCTION VIA DEHYDROGENATION OF ISOPROPANOL
MESITYL OXIDE VIA DEHYDRATION OF DIACETONE AND HYDR06ENATION OF DOUBLE BOND
POLYETHYLENE 61YCOL VIA POLYMERIZATION OF ETHYLENE GlYCOL t ETHYLENE OXIDE
NONYLPHENOL VIA ALKYLATION OF PHENOL
CHLOROFORM VIA HALOGENATION OF METHYL CHLORIDE
METHYL CHLORIDE VIA HYDROHAL06ENATION OF METHANOL
CHLOROBENZENE VIA HAL06ENATIM OF BENZENE
MALEIC ANHYDRIDE VIA AIR OXIDATION OF BUTENES
4.4-METHYLENEDIANILINE VIA CONDENSATION OF ANILINE WITH FORMALDEHYDE
DINITROTOLUENE (2.4-) VIA NITRATION OK NlTTOTOlUfHf MIXTURE
MDI VIA REACTING 4.4 HETHYLENEOIANILINt WITH PHOSGENE
NITROBENZENE VIA NITRATION OF BENZENE
PHOSGENE VIA HALOGENATION OF CARBON MONOXIDE
Included for analysis of economic Impacts, but unit would not be subject to the HON
-------
Chemical Manufacturing Facilities Including the HON Impacts Analysis
State City
Facility Name
Production Process
PA
I'A
PA
PA
SC
SC
SC
SC
SC
SC
SC
SC
IN
TN
IN
TN
PHILADELPHIA
PHILADELPHIA
SEIPLE
SOMERSET
BUSHY PARK
COLUMBIA
HAMPTON
MAULDIN
ROCK HILL
ROCK HILL
RUSSELLVILLE
SPARTANBURG
CHATTANOOGA
CHATTANOOGA
CHATTANOOGA
KINGSPORT
CHEVRON CORPORATION
ROHM AND HAAS COMPANY
INTERNATIONAL MINERALS ft CHEMICAL CORP.
CARBOSE CORP.
HAARMAN AND REIMER
EASTMAN CHEMICAL
BTL SPECIALTY RESINS
QUANTUM CHEMICALS
CELANESE CORPORATION
HOECHST CELANESE CORPORATION
GEORGIA-PACIFIC
BASF
CHATTEN. INC.
VELSICOL CHEM. CORP.
VELSICOL CHEMICAL CORP.
EASTMAN CHEMICAL
CUMENE VIA ALKYLATION OF BENZENE WITH PROPYLENE
NONYLPHENOL VIA ALKYLATION OF PHENOL
FORMALDEHYDE FROM DEHYDROGENATION OF METHANOL
SODIUM CARBOXVMETHYL CELLULOSE VIA CELLULOSE AND SODIUM CHLOROACETATE
DIPHENYL OXIDE VIA HYDROLYSIS OF CHLOROBENZENE
TEREPHTHALIC ACID VIA OXIDATION OF P-XYLENE
FORMALDEHYDE FROM DEHYDROGENATION OF METHANOL
POLYETHYLENE GLYCOL VIA POLYMERIZATION OF ETHYLENE GLYCOL ft ETHYLENE OXIDE
KETENE VIA DEHYDRATION OF ACETIC ACID
ACETIC ANHYDRIDE VIA DEHYDRATION OF ACETIC ACID
FORMALDEHYDE VIA AIR OXIDATION OF METHANOL
FORMALDEHYDE VIA AIR OXIDATION OF METHANOL
POLYETHYLENE GLYCOL VIA POLYMERIZATION OF ETHYLENE GLYCOL I ETHYLENE OXIDE
POLYPROPYLENE GLYCOL VIA POLYMER OF PROPYLENE OXIDE AND PROPYLENE GLYCOL
GLYCINE VIA AMHONOLVSIS OF CHLOROACETIC ACID
SODIUM BENZOATE VIA ADDITION OF BENZOIC ACID TO S. HYDROXIDE
BENZOIC ACID VIA OXIDATION OF TOLUENE
BENZOYL CHLORIDE VIA REACTION OF BENZOIC ACID AND BENZOTRICHLORIDE
BENZYL CHLORIDE VIA CHLORINATION OF TOLUENE
ACETIC ACID VIA OXIDATION OF ACETALDEHYDE WITH CATALYST
ACETIC ANHYDRIDE VIA AIR OXIDATION OF ACETALDEHYDE
ACETIC ANHYDRIDE VIA CARBONYLATION OF METHYL ACETATE
BUTYL ACETATE VIA ESTERIFICATION OF BUTYL ALCOHOL
CROTONIC ACID VIA OXIDATION OF CROTONALDEHVDE
DIISODECVL PHTHALATE VIA ESTERIFICATION W/PHTHAL1C ANHYDRIDE AND OECANOL
OIISOOCTYL PHTHALATE VIA ESTERIFICATION W/ PHTHALIC ANHYDRIDE ft OCTYL ALCOH
DIKETENE VIA SPONTANEOUS DIMERIZATION OF KETENE
ETHYL ACETATE VIA ESTERIFICATION OF ACETIC ACID AND ETHYL ALCOHOL
HYDROQUINONE VIA OIISOPROPYL-BENZENE HVDROPEROXIDE CLEAVAGE
HYOROQUINONE VIA QUINONE REDUCTION
ISOPROPYL ACETATE VIA ESTERIFICATION OF ISOPROPYL ALCOHOL
KETENE VIA DEHYDRATION OF ACETIC ACID
MESITYL OXIDE VIA DEHYDRATION OF OIACETONE AND HYDROGENATION OF DOUBLE BONO
METHYL ACETATE VIA HYDROLYSIS OF POLYVINYL ACETATE BY METHANOL
Included for analysis of economic Impacts, but untt would not be subject to the HON
5-17
-------
State City
Facility Name
Chemical Manufacturing Facilities Including the HON Impacts Analysis
Production Process
IX
IX
TX
TX
TX
IX
TX
TX
TX
IX
BAYTOWN
BAT TOWN
BEAUMONT
BEAUMONT
BEAUMONT
BEAUMONT
BIG SPRING
BISHOP
BISHOP
BORGER
EXXON CORPORATION
MOBAY SYNTHETICS CORP.
OU PONT
HOBIL CORPORATION
PO GLYCOL
UNOCAL CORPORATION
FINA OIL 1 CHEMICAL
HOECHST CELANESE
HOECHST CELANESE CORPORATION
COMINCO AMERICAN
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
BENZENE VIA HVDROOEALKVLATION/TRANSALKYLATION OF TOLUENE
BENZENE VIA HYDROGENATION OF PYROLYSIS GAS
BUTADIENE VIA CATALYTIC REFORMATION OF C4 STREAMS
ISOBUTYLENE VIA DEHYDRATION OF TERT-8UTYL ALCOHOL
METHYL TERT BUTYL ETHER VIA ETHERIFICATION OF ISOBUTYLENE ANO METHANOL
XYLENE (0-) VIA FRACTIONAL DISTILLATION OF MIXED XYLENE
XYLENE (P-) VIA PURIFICATION OF MIXED XVLENE
4,4-HETHYLENEOIANILINE VIA CONDENSATION OF ANILINE WITH FORMALDEHYDE
OINITROTOLUENE (2.4-) VIA NITRATION OF NITROTOLUENE MIXTURE
HOI VIA REACTING 4.4 METHYLENEDIANILINE WITH PHOSGENE
PHOSGENE VIA HALOGENATION OF CARBON MONOXIDE
TOLUENE DIISOCYANATES VIA DINITRATION OF TOLUENE WITH PHOSEGENATION
ACRYLONITRILE VIA AIR OXIDATION OF PROPYLENE
ANILINE VIA HYDROGENATION OF NITROBENZENE
METHANOL VIA HYDROGENATION OF CARBON MONOXIDE
NITROBENZENE VIA NITRATION OF BENZENE
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
BENZENE VIA HYDROGENATION OF PYROLYSIS GAS
BUTADIENE VIA CATALYTIC REFORMATION OF C4 STREAMS
METHYL TERT BUTYL ETHER VIA ETHERIFICATION OF ISOBUTYLENE ANO METHANOL
ETHYLENE GLVCOL VIA HYDROLYSIS OF ETHYLENE OXIDE
ETHYLENE OXIDE VIA AIR OXIDATION OF ETHYLENE
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
CYCLOHEXANE VIA HYDROGENATION OF BENZENE
METHYL TERT BUTYL ETHER VIA ETHERIFICATION OF ISOBUTYLENE ANO METHANOL
BUTYLENE GLYCOL (I.3-) VIA HVOROGENATION OF ACETALDOL
DIACETONE ALCOHOL VIA CONDENSATION OF ACETONE
BUTYL ACETATE VIA ESTERIFICATION OF BUTYL ALCOHOL
FORMALDEHYDE FROM DEHVOROGENATION OF METHANOL
ISOPROPYL ACETATE VIA ESTERIFICATION OF 1SOPROPYL ALCOHOL
METHANOL VIA HYDROGENATION OF CARBON MONOXIDE
PENTAERYTHRITOL VIA ADDITION OF FORMALDEHYDE TO ACETALDEHYDE
UREA VIA CONDENSATION OF AMMONIA AND CARBON DIOXIDE
Included for analysis of economic Impacts, but unit would not be subject to the HON
5-19
-------
Chemical Manufacturing Facilities Including the HON Impacts Analysis
State Ctty
Factllty Name
Production Process
TX CLEAR LAKE
TX CONROE
IX CORPUS CHRIST1
TX CORPUS CHRIST1
IX CORPUS CHRIS1I
IX CORPUS CHRIST I
IX CORPUS CHRIST I
TX
IX
TX
TX
TX
TX
IX
CORPUS CHRISTI
CORPUS CHRISTI
CORPUS CHRISTI
CORPUS CHRISTI
DALLAS
DALLAS
DEER PARK
HOECHST CELANESE CORPORATION
TEXACO
ARCO CHEH1CAL
CAIN CHEMICAL
CHAHPLIN REFINING
COASTAL CORPORATION
DU PONT
KERR-MCGEE CORPORATION
KOCH INDUSTRIES
OCCIDENTAL CORPORATION
VALERO REFINING
KALAMA CHEMICAL
PROCTER ft GAMBLE CO.
OCCIDENTAL CORPORATION
ETHYLENE OXIDE VIA AIR OXIDATION OF CTHYLENE
VINYL ACETATE VIA OXYACETYLATION OF ETHYLENE
MORPHOLINE VIA HYDROGENATION OF DIETHYLENE 6LYCOL
PIPERAZINE VIA REACTION OF AMMONIA AND NONOETHANOLANINE
POLYETHYLENE GLYCOL VIA POLYMERIZATION OF ETHYLENE 6LYCOL i ETHYLENE OXIDE
POLYPROPYLENE GLYCOL VIA POLYMER OF PROPYLENE OXIDE AND PROPYLENE GLYCOL
METHYL TERT BUTYL ETHER VIA ETHERIFICATION OF ISOBUTYLENE AND METHANOL
BUTADIENE VIA CATALYTIC REFORMATION OF C4 STREAMS
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
CUMENE VIA ALKYLATION OF BENZENE WITH PROPYLENE
CYCLOHEXANE VIA HYDROGENATION OF BENZENE
METHYL TERT BUTYL ETHER VIA ETHERIFICATION OF ISOBUTYLENE AND METHANOL
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
BENZENE VIA HVDROOEALKYLATION/TRANSALKVLATION OF TOLUENE
CFC-I42 VIA HALOGENATION OF CHLORO COMPOUNDS
CFC-Z2 VIA HALOGENATION OF CHLOROFORM
TRICHLOROTRIFLUOROETHANE VIA HALOGENATION OF PERCHLOROETHYLENE
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
BENZENE VIA HYDRODEALKYLATION/TRANSALKYLATION OF TOLUENE
CUMENE VIA ALKYLATION OF BENZENE WITH PROPVLENE
ETHYLBENZENE VIA ALKYLATION OF BENZENE WITH ETHYLENE
XYLENE (0-) VIA FRACTIONAL DISTILLATION OF MIXED XYLENE
XYLENE (P-) VIA PURIFICATION OF MIXED XVLENE
BENZENE VIA HYDROOEALKYLATION/TRANSALKYLATION OF TOLUENE
BENZENE VIA HYDROGENATION OF PYROLYSIS GAS
ETHYLENE 01CHLORIDE VIA CHLORINATION/OXYCHLORINATION OF ETHYLENE
METHYL TERT BUTYL ETHER VIA ETHERIFICATION OF ISOBUTYLENE AND HETHANOL
SODIUM BENZOATE VIA ADDITION OF BENZOIC ACID TO S. HYDROXIDE
SODIUM DODECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
ETHYLENE DlCHLORIDE VIA CHLORINATION/OXYCHLORINATION OF ETHYLENE
ETHYLENE OICHLORIOE VIA CHLORINATION/OXYCHLORINATION OF ETHYLENE
GLYCEROL VIA HYDROLYSIS OF GLYCIDOL
PERCHLOROETHYLENE VIA CHLORINATION OF ETHYLENE DICHLORIDE
Included for analysis of economic Impacts, but unit would not be subject to the HON
5-21
-------
Chemical Manufacturing Facilities Including the HON Impacts Analysts
State City
Facility Name
Production Process
IX
FREEPORT
DOW
TX
TX
TX
IX
IX
TX
IX
FREEPORT
FREEPORT
FREEPORT
GREEN LAKE
HOUSTON
HOUSTON
HOUSTON
DOW CHEMICAL
HOFFMAN-LAROCHE
SCHENECTADY CHEMICALS
BP AMERICA
ARCO CHEMICAL
ATLANTIC RICHFIELD COMPANY
BTL SPECIALTY RESINS
BENZENE VIA HYDROOEALKYLATION/TRANSALKYLATION OF TOLUENE
BENZENE VIA HYDROGENATION OF PYROLYSIS GAS
BISPHENOL A VIA CONDENSATION OF PHENOL AND ACETONE
CHLOROFORM VIA HALOGENAT ION OF METHYL CHLORIDE
EPICHLOROHYDRIN VIA CHLOROHYDRATION OF ALLVL CHLORIDE
ETHYL CHLORIDE VIA HYDROCHLORINATION OF EHTVLENE
ETHYLBENZENE VIA ALKYLATION OF BENZENE WITH ETHYLENE
ETHYLENE 01CHLORIDE VIA CHLORINATION/OXYCHLORINATION OF ETHYLENE
ETHYLENEDIAHINE VIA DEHYDROHALOGENATION OF ETHYLENE 01CHLORIDE
GLYCEROL VIA HYDROLYSIS OF EPICHLOROHYDRIN
HYDROGEN CYANIDE VIA AIR OXIDATION OF METHANE
METHYL CHLORIDE VIA HYOROHALOGENATION OF METHANOL
PHOSGENE VIA HALOGENATION OF CARBON MONOXIDE
POLYETHYLENE 6LYCOL VIA POLYMERIZATION OF ETHYLENE GLYCOL i ETHYLENE OXIDE
POLYPROPYLENE GLYCOL VIA POLYMER OF PROPYLENE OXIDE AND PROPYLENE GLYCOL
PROPYLENE CHLOROHYDRIN VIA HALOGENATION OF PROPYLENE
PROPYLENE GLVCOL VIA HYDROLYSIS OF PROPYLENE OXIDE
PROPYLENE OXIDE VIA OEHYDROHALOGENATION OF PROPYLENE CHLOROHYDRIN
SODIUM CYANIDE VIA NEUTRALIZATION OF HYDROGEN CYANIDE BY SODIUM HYDROXIDE
STYRENE PRODUCTION VIA DEHYDROGENATION OF ETHYLBENZENE
TOLUENE DIISOCYANATES VIA OINITRATION OF TOLUENE WITH PHOSEGENATION
TRICHLOROETHANE (1.1.1-) VIA HYDROHALOGENATION OF VINYL CHLORIDE
TRICHLOROETHYLENE VIA CHLORINATION OF ETHYLENE OICHLORIDE
VINYL CHLORIDE VIA HYDROHALOGENATION OF ACETYLENE
D10XANE (1.4-) VIA ETHYLENE OXIDE HYDROOIMERIZATION
TRICHLOROETHANE (1.1.2-) VIA HALOGENATION OF VINYL CHLORIDE
OIPHENVL OXIDE VIA HYDROLYSIS OF CHLOROBENZENE
NONYLPHENOL VIA ALKYLATION OF PHENOL
ACRYLONITRILE VIA AIR OXIDATION OF PROPVLENE
XYLENE (0-) VIA FRACTIONAL DISTILLATION OF MIXED XYLENE
XYLENE (P-) VIA PURIFICATION OF MIXED XYLENE
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
BENZENE VIA HYDRODEAUttLATlON/TRANSALKYLATION OF TOLUENE
FORMALDEHYDE VIA AIR OXIDATION OF METHANOL
li.Lluikil tur analybii of ei-orumlc Impacts, but unit would not be subject to the HON
5-23
-------
State City
Factltty Name
Chemical Manufacturing Facilities Including the HON Impacts Analyst*
Production Process
TX
TX
TX
IX
TX
TX
TX
IX
TX
TX
TX
ODESSA
ORANGE
OYSTER CREEK
PAMPA
PAHPA
PASADENA
PASADENA
PASADENA
PASADENA
PASADENA
TX POINT COHFORT
TX PORT ARTHUR
TX PORT ARTHUR
TX
PORT ARTHUR
PORT NECHES
SHELL OIL COMPANY
DU PONT
DOW
CELANESE CORPORATION
HOECHST CELANESE CORPORATION
AIR PRODUCTS
CROWN CENTRAL PETROLEUM CORPORATION
ETHYL CORPORATION
GEORGIA GULF
TENN-USS CHEMICALS
FORMOSA PLASTICS
AMERICAN PETROFINA
CHEVRON CORPORATION
TEXACO
TEXACO
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
ADIPIC ACID VIA AIR OXIDATION OF CYCLOHEXANE
ADIPONITRILE VIA ADDITION OF HYDROGEN CYANID TO BUTADIENE
HEXAMETHYLENEOIAMINE VIA HYDROGENATION OF ADIPONITRILE
HYDROGEN CYANIDE VIA AIR OXIDATION OF METHANE
CUMENE HYDROPEROXIOE VIA OXIDATION OF CUMENE
ETHYLENE DICHLORIDE VIA CHLORINATION/OXYCHLORINATION OF ETHYLENE
PHENOL VIA ACID CLEAVAGE OF CUMENE HYDROPEROXIOE
VINYL CHLORIDE VIA DEHYDROHALOGENATION OF ETHYLENE DICHLORIDE BY THERMAL CRACKING
KETENE VIA DEHYDRATION OF ACETIC ACID
ACETIC ACID VIA AIR OXIDATION OF BUTANE
ACETIC ANHYDRIDE VIA DEHYDRATION OF ACETIC ACID
ETHYL ACETATE VIA ESTERIFICATION OF ACETIC ACID AND ETHYL ALCOHOL
DINITROTOLUENE (Z.«-) VIA NITRATION OF NITROTOLUENE MIXTURE
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
BENZENE VIA HYDRODEALKVLATION/TRANSALKYLAT10N OF TOLUENE
ETHYL CHLORIDE VIA HYDROCHLORINATION OF EHTYLENE
CUMENE VIA ALKYLATION OF BENZENE WITH PROPYLENE
BUTYRALDEHYDE (N-ISOMER) VIA HYDROFORMYLATION OF PROPYLENE
ETHYLHEXANOL (2-ISOMER) VIA 0X0 PROCESS OF PROPYLENE
PHTHALIC ANHYDRIDE VIA AIR OXIDATION OF 0-XYLENE
ETHYLENE DICHLORIDE VIA CHLORINATION/OXYCHLORINATION OF ETHYLENE
VINYL CHLORIDE VIA DEHYDROHALOGENATION OF ETHYLENE DICHLORIDE BY THERMAL CRACKING
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
BENZENE VIA HYDRODEALKYLAT10N/TRANSALKYLATION OF TOLUENE
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
BENZENE VIA HYDRODEALKYLATION/TRANSALKYLATION OF TOLUENE
BENZENE VIA HYDROGENATION OF PVROLYSIS GAS
CUHENE VIA ALKYLATION OF BENZENE WITH PROPYLENE
CYCLOHEXANE VIA HYDROGENATION OF BENZENE
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
BENZENE VIA HYOR06ENATION OF PYROLYSIS GAS
CYCLOHEXANE VIA HYDROGENATION OF BENZENE
BUTADIENE VIA CATALYTIC REFORMATION OF C4 STREAMS
Included for analysts of economic Impacts, but unit would not be subject to the HON
5-25
-------
State City
Facility Name
Chemical Manufacturing Facilities Including the HON Impacts Analysis
Production Process
IX TEXAS CITY
IX TEXAS CITY
IX
IX
UT
VA
VA
VA
VA
VA
VA
VA
VA
WA
UA
UA
ItXAS CIIY
VICTORIA
SALT LAKE CITY
GREENWOOD
HOPEWELL
HOPEWELL
HOPEWELL
NARROWS
NARROWS
PORTSMOUTH
YORKTOWN
ANACORTES
ICALAMA
KALAMA
STERLING CHEMICALS INC.
UNION CARBIDE
USX CORPORATION
DU PONT
HURSH CHEMICAL CO.
GREENWOOD CHEMICAL CORP
ALLIED CHEMICAL
AQUALON
HERCULES INC.
CELANESE CORPORATION
HOECHST CELANESE CORPORATION
HOECHST CELANESE CORP.
AMOCO CHEMICAL
STIMSON LUMBER CO.
ICALAMA CHEMICAL. INC.
ICALAMA. INC.
SODIUM CYANIDE VIA NEUTRALIZATION OF HYDROGEN CYANIDE BY SODIUM HYDROXIDE
STYRENE PRODUCTION VIA DEHVDROGENATION OF ETHYLBENZENE
BUTYL ACETATE VIA ESTERIFICATION OF BUTYL ALCOHOL
BUTYL ALCOHOL (N-ISOMER) VIA HYDROFORMYLATION OF PROPVLENE THEN HYOROGENATION OF N BUIfRA
BUTYRALDEHYDE (N-ISOMER) VIA HYDROFORMYLATION OF PROPYLENE
ETHYLHEXANOL (2-ISOMER) VIA 0X0 PROCESS OF PROPYLENE
HYDROFORMYLATION OF ETHYLENE THEN HYDROGENATION OF PROPIONALDEHYOE/OXO PROC
PROPION1C ACID VIA AIR OXIDATION OF PROPIONALDEHYDE
VINYL ACETATE VIA OXYACETYLATION OF ETHYLENE
BENZENE VIA CATALYTIC REFORMING OF NAPHTHA
ADIPIC ACID VIA AIR OXIDATION OF CYCLOHEXANE
ADIPONITRILE VIA ADDITION OF HYDROGEN CYAN ID TO BUTADIENE
HEXAHETHYLENEOIAMINE VIA HYDROGENATION OF ADIPONITRILE
HYDROGEN CYANIDE VIA AIR OXIDATION OF METHANE
SODIUM DODECYL BENZENE SULFONATE VIA SULFONATION OF LINEAR ALKYL BENZENE
BENZIL VIA CARBONYLATION OF CHLOROBENZENE
BENZOIN VIA ESTERIFICATION OF BENZALDEHYDE
CAPROLACTAM PRODUCTION VIA REARRANGEMENT OF CYCLOHEXANONE
CYCLOHEXANONE VIA HYDROGENATION OF PHENOL
CHLOROACETIC ACID VIA HALOGENATION OF ACETIC ACID
SODIUM CARBOXYMETHYL CELLULOSE VIA CELLULOSE AND SODIUM CHLOROACETATE
ETHYL CHLORIDE VIA HYDROCHLORINATION OF ETHANOL
KETENE VIA DEHYDRATION OF ACETIC ACID
ACETIC ANHYDRIDE VIA DEHYDRATION OF ACETIC ACID
BUTYLAMINE (T-) VIA ADDITION OF HCN TO ISOBUTYLENE
DICYCLOHEXYLAMINE VIA HYDROGENATION OF CYCLOHEXYLAMINE-C.H
METHYL TERT BUTYL ETHER VIA ETHERIFICATION OF ISOBUTYLENE AND METHANOL
CRESOLS/CRESYL1C ACIDS (MIX) VIA RECOVERY FROM SPENT REFINERY CAUSTICS
BENZOIC ACIO VIA OXIDATION OF TOLUENE
BENZYL ALCOHOL VIA HYDROGENATION OF BENZALDEHYDE
NONYLPHENOL VIA ALKYLATION OF PHENOL
BENZYL BENZOATE VIA ESTERIFICATION OF BENZYL ALCOH
BENZYLAMINE VIA AMMONOLYSIS OF BENZALDEHYOE
SODIUM BENZOATE VIA ADDITION OF BENZOIC ACIO TO S. HYDROXIDE
Included tor analysis of economic Impacts, but unit would not be subject to the HON
5-27
-------
Chemical Manufacturing Facilities Including the HON Impacts Analysis
State City
Facility Name
Production Process
UV
uv
wv
uv
uv
NEU MART1NSVILLE
NEU HART1NSVILLE
PARKERSBURG
S. CHARLESTON
SOUTH CHARLESTON
HOBAY SYNTHETICS CORP.
PPG INDUSTRIES
OU PONT
UNION CARBIDE CO.
UNION CARBIDE
ur
CHEYENNE
UYCON CHEMICAL
TOLUENE OIISOCYANATES VIA DINITRATION OF TOLUENE WITH PHOSEGENATION
CARBON DISULFIDE VIA SULFONATION OF METHANE
FORMALDEHYDE FROM DEHYDROGENATION OF METHANOL
DIACETONE ALCOHOL VIA CONDENSATION OF ACETONE
ETHYLENE GLYCOL MONOB. ETHER VIA ALCOHOLYSIS OF ETHYLENE OXIDE BY BUTANOL
ETHYLENE GLYCOL MONOETH. ETHER VIA ALCOHOLYSIS OF ETHYLENE OXIDE BY ETHANOL
ETHYLENE GLYCOL MONOMETH. ETHER VIA ALCOHOLYSIS OF ETHYLENE OXIDE BY METHA.
POLYETHYLENE GLYCOL VIA POLYMERIZATION OF ETHYLENE GLYCOL & ETHYLENE OXIDE
POLYPROPYLENE GLYCOL VIA POLYMER OF PROPYLENE OXIDE AND PROPYLENE GLYCOL
PROPYLENE GLYCOL MONOMETHYL ETHER VIA ALCOHOLY. PROPYLENE OXIDE BY METHANOL
PROPYLENE GLYCOL VIA HYDROLYSIS OF PROPYLENE OXIDE
UREA VIA CONDENSATION OF AMMONIA AND CARBON DIOXIDE
Included for analysis of economic Impacts, but unit would not be subject to the HON
5-29
-------
TABLE B-2. TRE INDEX COEFFICIENTS FOR EXISTING SOURCES
TRE Coefficients
Control
Device
Flare
2.902 5.490X10'1 -1.153xlO~2 -l.lOOxlO'3
Incinerator 2.238 9.400x10-2 4.765xlO~2 -1.739xlO~3
0% Heat Recovery
Incinerator 3.778 1.775xlO~2 1.950xlO~2 7.185X1Q-2
70* Heat
Recovery
TRE Index Equation:
(1/HAP Emission Rate) [a
+ d (TOC Emission Rate)]
+ b (Flow Rate) + c (Heat Content)
B-2
-------
6.0 OAQF8 CONTACTS
The following table lists the individuals involved in
preparing the proposed HON. Specific questions should be
addressed to the appropriate individual.
RESPONSIBILITY
NAME
TELEPHONE
Project Manager
Overall Policy
Implementation
PROCESS VENTS
Regulatory Lead
Technical Lead
TRANSFER OPERATIONS
Regulatory Lead
Technical Lead
WASTEWATER OPERATIONS
Regulatory Lead
Technical Lead
STORAGE VESSELS
Regulatory Lead
Technical Lead
EQUIPMENT LEAKS
Regulatory Lead
Technical Lead
EMISSIONS AVERAGING
REGULATORY i
ECONOMICS ANALYSIS
TEST METHODS &
PROCEDURES
Jan Meyer
Daphne McMurrer
Sheila Milliken
Warren Johnson
Les Evans
Warren Johnson
Dave Markwordt
Mary Tom Kissell
Penny Lassiter
Mary Tom Kissell
Randy McDonald
Jan Meyer
Dave Markwordt
Daphne McMurrer
Tom Walton
Rima Dishakjian
Tony Wayne
(919) 541-5254
(919) 541-0248
(919) 541-2625
(919) 541-5124
(919) 541-5410
(919) 541-5124
(919) 541-0837
(919) 541-4516
(919) 541-5396
(919) 541-4516
(919) 541-5402
(919) 541-5254
(919) 541-0837
(919) 541-0248
(919) 541-5311
(919) 541-0443
(919) 541-3576
6-1
-------
APPENDIX A:
OAQPS BULLITEN BOARD SYSTEM: WATER?
-------
OAQPS BULLITEN BOARD SYSTEM: WATER?
The EPA has developed software called WATER? which can be
used to predict the air emission rates of organic compounds
treated in wastewater management units. The emission models
within the software require the user to input site-specific
parameters on the physical dimensions of the wastewater
management units. The software package also includes
physical/chemical properties data for approximately 800
compounds. This piece of the software also allows the user to
input any site-specific physical/chemical property data or to
approximate physical/chemical properties for compounds not
already in the list of 800. Within this physical/chemical
property data base, default values are provided for biorate
kinetic constants, which are necessary when modeling air
emissions from a biological wastewater management unit; however,
due to the site-specific nature of biorate kinetics, the EPA has
proposed draft Method 304 that can be used to calculate site-
specific kinetic constants that can be used in running the WATER?
models.
The WATER? software, which includes a user's guide, is
available on the EPA CHIEF Bulletin Board. WATER? is a menu
driven software package that does not require any external
software support. The software must be completely down loaded
before it can be executed. It can be accessed via modem with the
following telephone numbers:
if running at 300, 1200, or 2400 baud, 919-541-5742, or
if running at 9600 baud, 919-541-1447.
The system operator is Michael Hamlin, telephone 919-541-5332.
A-2
-------
APPENDIX B:
THE INDEX
-------
TABLE B-l. INPUTS FOR TRE INDEX CALCULATION
Process Flow Rate
Vent scmm
(scfm)
1 12.82
(452.70)
2 47.68
(1,683.58)
3 0.03
(1.06)
4 1.66
(58.62)
5 0.49
(17.30)
6 12.22
(431.49)
7 0.004
(0.14)
8 2.29
(80.86)
Heat Content
MJ/scm
(BTU/ft3)
438.54
(11,770)
266.41
(7,150)
280.78
(7,540)
77.82
(2,090)
280.78
(7,540)
77.82
(2,090)
N/Aa
77.82
(2,090)
HAP
Emission
Rate
kg/hr
(Ib/hr)
1147.95
(2,530.79)
349.05
(769.52)
1.22
(2.69)
2.32
(5.12)
18.07
(39.84)
17.19
(37.90)
N/Aa
3.22
(7.10)
TOC
Emission
Rate
kg/hr
(Ib/hr)
1339.00
(2,951.99)
447.41
(986.37)
1.46
(3.22)
2.96
(6.52)
21.62
(47.66)
21.88
(48.24) ''.
N/Aa
4.10
(9.04)
a TRE was not calculated for this stream since it was a Group 2
stream based on the flow rate.
B-l
-------
ES1iACTUAL
(0.05)
ES2iACTUAL
ES2iBASE
(0.02) ETRliu
ETR2iACTUAL
Emissions from each Group 1 storage
vessel (i) that is controlled to a level
more stringent than the RCT, calculated
according to §63.150(g)(3) of Subpart G.
Emissions from each Group 1 storage
vessel (i) if the RCT had been applied to
the uncontrolled emissions. ESliu is
calculated according to $63.150(g)(3) of
Subpart G. These are the allowed emissions
for Group 1 storage vessels.
Emissions from each Group 2 storage
vessel (i) that is controlled, calculated
according to §63.150(g)(3) of Subpart G.
Emissions from each Group 2 storage
vessel (i) at the baseline date, as
calculated in §63.150(g)(3) of Subpart G.
These are the allowed emissions for Group 2
storage vessels.
Emissions from each Group 1 transfer
rack (i) that is controlled to a level more
stringent than the RCT, calculated according
to §63.150(g)(4) of Subpart G.
Emissions from each Group 1 transfer
rack (i) if the RCT had been applied to the
uncontrolled emissions. ETR1
1U
is
calculated according to §63.150(g)(4) of
Subpart G. These are the allowed emissions
for Group l transfer racks.
Emissions from each Group 2 transfer
rack (i) that are controlled, calculated
according to §63.150(g)(4) of Subpart G.
C-2
-------
TABLE B-3. RESULTS OF TRE INDEX CALCULATIONS BY PROCESS VENT
Process
Vent
1
2
3
4
5
6
7
8
Flare
TRE
Index
0.003
0.073
-0.263
1.256
-0.005
0.506
N/A
1.012
Incinerator
0% Heat
Recovery
TRE Index
0.019
0.053
12.798
2.628
0.865
0.410
N/A
1.911
Incinerator
70% Heat
Recovery
TRE Index
0.095
0.120
7.669
2.387
0.598
0.412
N/A
1.748
TREa
Index
0.003
0.053
-0.263
1.256
-0.005
0.410
N/A
1.012
a According to the process vent provisions, the TRE index is the
lowest of the 3 values for flares and incinerators calculated
for each stream.
B-3
-------
APPENDIX C
TERMS IN THE CREDIT EQUATION
-------
EPVliACTUAL
TERMS IN THE CREDIT EQUATION
This Appendix gives the terms for the credit equation.
Credits and all terms of the equation are in units of Mg/month
and the baseline date is November 15, 1990, except for pollution
prevention measures initiated after 1987 or controls applied as
part of the early reduction program or the 33/50 program. For
these three exceptions, the baseline date is immediately prior to
initiation of the pollution prevention measure or application of
the early reduction or 33/50 program control strategy.
Discount factor = A range of 0.8 to 1.0 is
proposed. (A single number will be selected
at promulgation.)
Emissions for each Group 1 process vent (i) -^
that is controlled to a level more stringent-
than the RCT, calculated according to
§63.i50(g)(2) of Subpart G.
Emissions from each Group 1 process vent (i)
if the RCT had been applied to the
uncontrolled emissions. EPVliu is
calculated according to S63.150(g)(2) of
Subpart G. These are the allowed emissions
for Group 1 process vents.
Emissions from each Group 2 process vent (i)
that is controlled, calculated according to
§63.150(g)(2) of Subpart G.
Emissions from each Group 2 process vent (i)
at the baseline date, as calculated in
§63.150(g)(2) of Subpart G. These are the
allowed emissions for Group 2 process vents.
(0.02)
EPV2iACTUAL
EPV2iBASE
C-l
-------
ETR2
iBASE
EWWlic
EWW21ACTUAL
iBASE
n
m
Emissions from each Group 2 transfer
rack (i) at the baseline date, as calculated
in §63.150(g)(4) of Subpart G. These are
the allowed emissions for Group 2
transfer racks.
Emissions from each Group 1 wastewater
stream (i) that is controlled to a level
more stringent than the RCT, calculated
according to §63.150(g)(5) of Subpart G.
Emissions from each Group 1 wastevater
stream (i) if the RCT had been applied to
the uncontrolled emissions, calculated
according to §63.150(g)(5) of Subpart G.
These are the allowed emissions for Group l
wastewater streams.
Emissions from each Group 2 wastewater
stream (i) that is controlled, calculated
according to §63.150(g)(5) of Subpart G.
Emissions from each Group 2 wastewater
stream (i) at the baseline date, calculated
according to §63.150(g)(5) of Subpart G.
These are the allowed emissions for Group 1
wastewater streams.
Number of Group 1 emission points included
in the emissions average. The value of n is
not necessarily the same for process vents,
storage vessels, transfer racks, and
wastewater.
Number of Group 2 emission points included
in the emissions average. The value of m is
not necessarily the same for process vents,
storage vessels, transfer racks, and
wastewater.
C-3
-------
APPENDIX D
ALLOWED EMISSIONS FROM PROCESS VENTS
-------
where:
Q =» Vent stream flow rate (dscnun) meas- d using
Method 2, 2A, 2C, or 2D of Part 60,
Appendix A, as appropriate.
h = Monthly hours of operation during which
positive flow is present in the vent.
Cj - Concentration (ppntv, dry basis) of organic
HAP compound j as measured by Method 18.
Mj - Molecular weight of organic HAP compound j
(g/g-mole).
T = Vent stream discharge temperature, in °C.
n = Number of organic HAP compounds.
The values for each parameter in this equation are as follows:
Q: The flow rate is 2.29 scmm.
h: The actual hours of operation for the month are
730 hours.
Cj: The concentration of triethylamine in this process
vent is 5,580 ppmv. Triethylamine is the only HAP
emitted.
Mj: Process Vent 8 contains triethylamine, whose
molecular weight is 101.19 g/g-mole.
T: The discharge temperature is 25°C.
n: There is only 1 organic HAP compound, so no
summation is required.
D-2
-------
CALCULATION OF ALLOWED EMISSIONS FOR PROCESS VENT 8
The eight process vents associated with the source are
described in Table 3-2. Allowed emissions for process vents are
calculated according to the provisions in S63.150(g)(2) of
Subpart G. In the credit equation, the term for allowed
emissions (or baseline emissions) from Group 2 process vents is
EPV2iBASE. Since this Group 2 process vent is not controlled,
§63.150(g)(2)(iv)(A) of Subpart G indicates that the allowed
emissions are equal to the uncontrolled emissions:
EPV2
iBASE
EPV2
iu
where:
EPV2iBASE
EPV2
iu
Emissions from each Group 2 process vent'
(i) at the baseline date, in Mg/month.
Uncontrolled emissions from each Group 2
process vent (i) in Mg/month.
The "i" in the above terms implies that these calculations must
be done for each emission point included in the emissions
average. This sample calculation is for Process Vent 8; the same
calculation would also be required for Process Vent 4. The value
of EPV2j_u is calculated according to the equation in
§63.150(f)(2)(ii):
EPV
iu
(7.31 x 10~7) Qh
T + 273
E CJM
D-l
-------
Each value is input to the equation to calculate EPVj_u:
(7.31 X 10"7)*(2.29)*(730)*(5580)*(101.19)
=
25 + 273
= 2.3 Mg/month or 28 Mg/yr
D-3
-------
APPENDIX E
TERMS IN THE DEBIT EQUATION
-------
(0.02) ETRiu = Emissions from each Group 1 transfer
rack (i) if the RCT had been applied to the
uncontrolled emissions, calculated according
to S63.150(f)(4) of Subpart G. These are
the allowed emissions for Group 1 transfer
racks.
EVWiACTUAL = Emissions from each Group 1 wastewater
stream (i) that is not controlled to the
level of the RCT. This is calculated
according to §63.150(f)(5) of Subpart G.
EWWic =» Emissions from each Group 1 wastewater
stream (i) if the RCT had been applied to
the uncontrolled emissions. This is
calculated according to S63.150(f)(5) of
Subpart G. These are the allowed emissions
for Group l wastewater streams.
n = The number of emission points being included
in the emissions average. The value of n is
not necessarily the same for process vents,
storage vessels, transfer racks, and
wastewater.
E-2
-------
TERMS IN THE DEBIT EQUATION
This Appendix gives the definitions to all terms in the
debit equation. All terms of the equation are in units of
Mg/month.
EpviACTUAL
(0.02) EPViu
EsiACTUAL
(0.05) ESiu
ETRiACTUAL
Emissions from each Group 1 process vent (i)
that is not controlled to the level of the
RCT. This is calculated according to
S63.l50(f)(2) of Subpart G.
Emissions from each Group 1 process vent (i)
if the RCT had been applied to the
uncontrolled emissions, calculated according
to §63.150(f)(2) of Subpart G. These are
the allowed emissions for Group 1 process
vents.
Emissions from each Group 1 storage
vessel (i) that is not controlled to the
level of the RCT. This is calculated
according to §63.150(f)(3) of Subpart G.
Emissions from each Group 1 storage
vessel (i) if the RCT had been applied to
the uncontrolled emissions, calculated
according to §63.150(f)(3) of Subpart G.
These are the allowed emissions for Group 1
storage vessels.
Emissions from each Group 1 transfer
rack (i) that is not controlled to the level
of the RCT. This is calculated according to
§63.150(f)(4) of Subpart G.
E-l
-------
APPENDIX F
ACTUAL EMISSIONS FROM STORAGE VESSELS AND TRANSFER RACKS
-------
CALCULATION OF ACTUAL EMISSIONS FOR ONE STORAGE VESSEL
IN TANK FARM 2 AND FOR TRANSFER RACK 1
In this Appendix, sample calculations will be shown for the
actual emissions from a storage vessel in Tank Farm 2 and from a
transfer rack (Rack l).
Storage Vessel
The seven storage vessels in Tank Farm 2 are characterized
in Table 3-4. Actual emissions from fixed roof storage vessels
are calculated using the equations provided in S63.150(f)(3) of
Subpart G. According to §63.150(f)(3)(ii)(A), actual emissions
are equivalent to uncontrolled emissions, since the company has
not applied control equipment to the storage vessel. The
following equation shows the relation between actual and
uncontrolled emissions:
ESiACTUAL = ESiu
Where:
EsiACTUAL = Emissions from the Group 1 storage vessel
that will not be controlled once the
emissions averaging control scenario is in
place, in Mg/month.
ESiu = Uncontrolled emissions from the Group 1
storage vessel in Mg/month.
The "i" in the above term implies these calculations must be
performed for each individual emission point used in the
emissions average, in this case, the individual storage vessels.
Since all seven of the storage vessels in Tank Farm 2 are the
same size, hold the same chemical, have the same number of
turnovers, and are the same type of tank subject to the same
F-l
-------
environmental conditions, the emissions are the same from each
storage vessel:
ESlu = ES2u = ES3u = ES4u = ES5u = ES6u = ES7u
This Appendix will show the calculations for storage vessel 1.
According to §63.150(f ) (3) (i) , ESj_u is calculated according
to the following equation:
ESiu
where:
LB = Breathing loss emissions in Mg/year.
LW = Working loss emissions in Mg/year.
Breathing loss emissions are calculated using the following
equation:
LB = 1.02 x ID'5 MV (p P_ p)
Where:
MV = Molecular weight of vapor in the storage vessel
(Ib/lb mole).
PA = Average atmospheric pressure (psia).
P = True vapor pressure of the HAP at liquid storage
temperature (psia). See Table 20 of the proposed
Subpart G to determine storage temperature as a
function of ambient temperature and tank color.
D = Tank diameter (ft).
F-2
-------
H - Average vapor space height (ft). Use a vessel-
:_;.. specific value or an assumed value of one-half the
:-«'i- height.
AT - ?"" Average ambient diurnal temperature change (°F) .
A typical value of 20° F may be used.
Fp » Paint factor (dimensionless) from Table 21 of the
proposed Subpart G.
C - Adjustment factor for small diameter tanks
(dimensionless): use C = l for diameter >30 ft;
use C - 0.0771D - 0.0013D2 - 0.1334 for diameter
<30 ft.
KC - Product factor (dimensionless). Use 1.0 for
volatile organic HAP's.
The information for each parameter in the equation was determined^
as follows: '.
My : Molecular weight of methanol is 32.042 Ib/lb-mole.
PA ' Average atmospheric pressure is 14.7 psia.
P : According to Table 20 of Subpart G, storage
temperature is a function of tank color and
average annual ambient temperature (°F) . For this
storage vessel, the tank color is aluminum and the
average annual ambient temperature (T^) is
74.5 °F. According to Table 20, if the tank color
is aluminum the average storage temperature is
TA + 2.5, which equals 77 °F for this storage
vessel. As determined from a standard reference
book, at 77 °F (25 °C), the true vapor pressure of
methanol is 1.9 psia. Methods from API
Bulletin 2517 and ASTM D2879-83 could also be used
to determine the vapor pressure.
D : Tank diameter is 32 ft.
F-3
-------
H : Average vapor space height is one-half of the
storage vessel height of 33 ft, vhich equals
16.5 ft.
AT : For the average ambient diurnal temperature
change, we will use the typical value of 20 °F.
Fp : The paint factor, as specified in Table 21 of
Subpart G, is a function of the color of the roof
the color of the shell, and the paint condition
(i.e., good or poor). This vessel has a white-
colored roof, a diffuse aluminum-colored shell,
and is in good condition. Based on these
characteristics, the paint factor is equal
to 1.30.
C : Because the vessel diameter is >30 ft, C = 1.
KC : The product factor is equal to 1.0 for all
volatile organic HAP's.
The value for each parameter is entered into the equation to
calculate LB:
LB = (1.02 X 10~5) * (32.042) * ( \0.68 «, (32)1'73
0 \14.7 - 1.9/
* (16.5)0-51 * (20)°-50 * (1.30) * (1) * (1.0)
- 0 . 87 Mg/year
Working loss emissions are calculated using the following
equation:
Lw = (1.089 X 10'8) (Mv) (P) (V) (N) (%) (1^)
Where:
MV = Molecular weight of vapor in the storage vessel
(Ib/lb mol).
F-4
-------
P » True vapor pressure of the HAP at liquid storage
temperature (psia), using Table 20 as described
above for the breathing loss emissions
calculation.
V = Tank capacity (gallons).
N = Number of turnovers per year.
KN - Turnover factor (dimensionless):
K m 180+N
6N
for turnovers (N) >36; KN - 1 for turnovers <36.
Kc - Product factor (dimensionless). Use 1.0 for
volatile organic HAP's.
The information for each parameter in the equation was determined
as follows:
My : Molecular weight of methanol is 32.042 Ib/lb-mole.
P : As described above, the true vapor pressure of
methanol is 1.9 psia at 25 °C (77 °F), based on a
tank color of aluminum and an average annual
ambient temperature of 74.5 °F (see Table 20 of
Subpart G).
V : Tank capacity is equal to 200,000 gallons.
N : Number of turnovers is 34 per year.
KN : Because the number of turnovers is < 36, the
turnover factor is equal to 1.
Kc : Product factor is 1.0 for all volatile organic
HAP's.
F-5
-------
The value for each parameter is entered into the equation to
calculate Ly:
Lw - (1.089 x 10~8) * (32.042) * (1.9)
* (200,000) * (34) * (1) * (1.0)
- 4.51 Mg/year
The calculated values for LQ and Lyj are entered into the equation
to calculate ESiu:
ESiu = °-87 + 4.51 = 0<45 Mg/month
Because ESiACTUAL is equal to ESiu for the storage vessel, actual,
emissions are 0.45 Mg/month or 5.38 Mg/year for each of the seven-
storage vessels.
Transfer Rack 1
The compounds-transferred through Transfer Rack 1 are
characterized in Table 3-6. Actual emissions from transfer racks
are calculated using the equations provided in §63.150(f)(4) of
Subpart G. Since this transfer rack is not controlled,
§63.150(f)(4)(iv)(A) indicates that actual emissions are
equivalent to uncontrolled emissions:
ETRiACTUAL = ETRiu
Where:
ETRiACTUAL = Emissions from the Group 1 transfer rack
that will not be controlled once the
emissions averaging control scenario is
in place, in Mg/month.
ETRj_u = Uncontrolled emissions from the Group 1
transfer rack, in Mg/month.
F-6
-------
The "i" in the above term implies these calculations must be
performed for each individual emission point used in the
emissions average. This sample calculation is for Rack 1; the
same calculation would also be required for Rack 2.
The value of ETRiu from this rack is calculated using the
emissions equation presented in §63.150(f)(4)(i):
ETRiu = 1.20 x 10~7
Where:
ETRiu = Uncontrolled transfer emission rate,
(Mg/month.)
S = Saturation factor [see Table 32 of
Subpart G, S63.1SO(f) (4)].
P - Weighted average rack vapor pressure of
organic HAP's transferred at the rack
during the month, (kPa.)
M = Weighted average molecular weight of
organic HAP's transferred at the rack
during the month, (g/g mole.)
G = Monthly volume of organic HAP
transferred, (t/month.)
T = Temperature of bulk liquid loaded,
°Kelvin (°C -i- 273) .
F-7
-------
The weighted average vapor pressure of materials transferred at a
rack is calculated using the equation presented in
§63.150(f) (4) (ii):
P =
j=n
£ (pj)(Gj>
Where:
P = Weighted average rack vapor pressure of
organic HAP's transferred at the rack during
the month, (kPa.)
Pj = Vapor pressure of individual organic HAP
transferred at the rack, (kPa.)
G = Monthly volume of organic HAP transferred,
(£/month.)
Gj = Monthly volume of individual organic HAP
transferred at the rack, (4.)
n = Number of organic HAP's transferred at the
rack.
The weighted average rack molecular weight is calculated using
the equation presented in §63.150(f)(4)(iii):
MjGj
M = i
Where:
M = Weighted average molecular weight of organic
HAP transferred at the rack during a month,
(g/g mole).
Mj = Molecular weight of individual organic HAP
transferred at the rack, (g/g mole).
F-8
-------
Gj = Monthly volume of individual organic HAP
transferred at the rack, (I/month).
n - Number of organic HAP's transferred at the
rack.
As Table 3-6 shows, Rack 1 is used to transfer 3 HAP's into
railcars. As a simplifying assumption for this example
calculation, the throughput of each HAP on a'monthly basis was
calculated by dividing the yearly throughput by 12. However, the
rule requires owners or operators to record actual monthly
throughputs each month, and use these in the credit and debit
calculations. An average monthly value based on annual
throughput would not be acceptable for demonstrating compliance
with the emissions averaging provisions. The vapor pressures of
each HAP were determined using a standard reference book.
Compound
Vapor Pressure
(Pj)(kPa)
Throughput
(Gj)
(t/month)
Molecular3
Weight(Mj)
(g/gmol)
Methanol
Dimethyl formamide
Triethylamine
13.3
0.5
53.1
1,477,920
17,000
71,920
32.04
73.09
101.19
aMerck Index, 10th edition.
F-9
-------
The weighted average rack vapor pressure is calculated as
follows:
j-n
E PJGJ
1
p m (13.3) (1,477,920) + (0.5) (17,000) + (53.1) (71,920)
1,477,920 + 17,000 + 71,920
P - 15.0 kPa
The weighted average rack molecular weight is calculated as
follows:
M
j-n
E MJGJ
M m (32.04) (1,477,920) + (73.09) (17,000) + (101.19) (71,920)
1,477,920 + 17,000 + 71,920
M - 35.7 g/g-mole
All three chemicals were submerge-loaded at ambient temperatures
Table 32 in §63.150 of Subpart G indicates that the saturation
factor (S) for materials submerge loaded with dedicated normal
service is 0.60.
Uncontrolled emissions are calculated as follows:
ETRiu = (1.20 x ID'7) -§M»
T
Where:
S = 0.6.
P =15 kPa.
M = 35.7 g/g-mole.
G = 1,566,840 £/month.
F-10
-------
298°K, based on the loaded liquid being at an
average temperature of 25°C.
ETRiu - (1.20 x 10-7) (0.6) (15) (35.7) (1,566,840)
298
ETRiu - 0.20 Mg/month or 2.43 Mg/yr
Because ETRiu is equal to
ETRiACTUAL "0-20 Mg/month or 2.43 Mg/yr
F-ll
------- |