-------
Packed Tower for Gas Absorption
Absorbing
Liquid In
lililllfi
Packing Support
Cleaned Gas Out
to Final Control
Device
. Organic Laden
Gas In
Absorbing Liquid
with Organics Out
To Disposal or Organic Solvent Recovery
CONTROL DEVICES
Combustion Equipment
Flares
Thermal oxidizers (incinerators, boilers,
process heaters)
Catalytic incinerators
CONTROL DEVICES
Flares
Open combustion process
Steam injection improves combustion
Destruction efficiency at least 98%
2-33
-------
Steam-assisted Elevated Flare System
. Pilot
burners
Steam
nozzles
Gas
barriers
Helps prevent flashback
Flare _
stack'
Steam
line
Gas collection headerp
and
transfer line
X Purge
oas
Air line
Gas line
Knock-oul
drum
Water
seal
Drain
CONTROL DEVICES
Thermal Incineration
Requires high temperatures, good mixing,
sufficient oxygen, adequate residence time
Auxiliary fuel if vent gas less than
50 Btu/scf
Capacity of 200 to 500,000 scfm
Destruction efficiency at least 98%
Thermal Incinerator
Waste Gas
Auxiliary
Fuel Burner
(discrete)
Optional
Heat
Recovery
Combustion
2-34
-------
CONTROL DEVICES
Catalytic Incinerators
Oxidation at lower temperatures with catalyst
(320 - 650 ฐC)
Catalyst adversely affected by high temperatures,
high concentrations, fouling (particulate matter,
polymers),deactivation (halogens or some metals)
Can achieve 98% or higher destruction
Catalytic Oxidizer
Suck
Fซn
CONTROL DEVICES
Existing Boilers or Process Heaters
Control provided by existing equipment
Vent stream added as fuel, secondary combustion
air, or as diluent
Vapors with halogens or sulfur usually avoided
Recovers heating value of vent stream
Can achieve 98% or higher destruction
2-35
-------
Outline
Introduction
Sources and inherent controls
Air pollution control devices
Organic removal or destruction
Summary
Organic Removal
or Destruction
Steam stripping
Solvent extraction
Air stripping
Distillation
Thin-film evaporation
Waste incineration
ORGANIC REMOVAL
Features
Avoids need for controls on subsequent
processes (hence pretreatment)
Removal efficiency depends on waste
constituents and process design
Can remove essentially all of highly volatile
compounds
Applicable to many wastes and compounds
2-36
-------
ORGANIC REMOVAL
Control Efficiency
Percent removed from waste
Emissions from removal process
Emissions before removal process installed
Percent control of 98 to 99+ is possible
ORGANIC REMOVAL
Example:
Steam Stripping Benzene from Water
99.5% to 99.9% removed from water
0.7% to 1.4% emitted from stripping system
Control efficiency of 98% to 99% (if 70%
emitted in WWT)
ORGANIC DESTRUCTION
Waste Incineration
Used for wastes that were previously land-disposed
Destruction of 99.99% or higher demonstrated
in many units
Applicable to organic wastes and sludges
i
2-37
-------
Outline
Introduction
Sources and inherent controls
Air pollution control devices
Organic removal or destruction
Summary
SUMMARY
SOURCES
Impoundments
Tanks
Containers
Land disposal sources
SUMMARY
Characteristics
Affecting Emissions
Exposed surface areas
Residence time
ซ Constituent volatility
Turbulence
2-38
-------
SUMMARY
Emission Mechanisms
Area sources
Diffusion through waste to surface
Transfer from surface to air
SUMMARY
Emission Mechanisms (con.)
Enclosed sources
- Vapor space contains organics
- Displacement of vapor
Working losses
Breathing losses
Evaporation of leaks and spills
2-39
-------
SUMMARY
Competing Mechanisms
Biodegradation
Adsorption
Absorption
Removal with effluent
SUMMARY
Controls
Cover or enclose open area sources
Control devices for vapors captured by enclosure
Organic removal or waste incineration
(instead of covers/control devices)
Work practices for leaks (LDAR) and spills
2-40
-------
RCRA Organic Air Rules - Process Vents
40 CFR Parts 264 and 265
Subpart AA
(55 FR 25454, June 21, 1990)
-------
ABSTRACT: PROCESS VENT STANDARDS (SUBPART AA)
The objective of the presentation on the RCRA process vent rules is to
provide a basic understanding of the new RCRA air emission standards for
process vents in order that those persons required to comply, implement, or
enforce the rules can do so effectively and timely. The presentation clearly
explains the process vent rule applicability criteria which include facility
authorization under RCRA, hazardous waste management unit type, and waste
organic concentration. Technical requirements for emission controls and the
facility "bubble" concept for emission rate limits are explained. Recordkeeping
and reporting requirements are also discussed.
The process vent standards in 40 CFR Parts 264 and 265, Subpart AA, limit
organic air emissions at hazardous waste treatment, storage, and disposal
facilities (TSDF) requiring a permit under Subtitle C of the Resource
Conservation and Recovery Act (RCRA). The standards were promulgated on
June 21, 1990 (55 FR 25454) under the authority of Section 3004(n) of the
Hazardous and Solid Waste Amendments (HSWA) to the RCRA. The Subpart AA
standards are applicable to process vents associated with distillation,
fractionation, thin-film evaporation, solvent extraction, and air and steam
stripping operations that manage hazardous wastes with 10 parts per million by
weight (ppmw) or greater total organic concentration. The RCRA air rules for
process vents require that owners/operators of TSDFs subject to the provisions
of Subpart AA: (1) reduce total organic emissions from all affected process
vents at the facility to below 1.4 kg/h (3 lb/h) and 2.8 Mg/yr (3.1 ton/yr), or
(2) install and operate a control device(s) that reduces total organic emissions
from all affected process vents at the facility by 95 weight percent. The
process vent rules do not require use of any specific types of equipment or
add-on control devices. Condensers, carbon adsorbers, incinerators, and flares
are demonstrated emission control technologies for the regulated processes,
although the choice of control is not limited to these. To ensure that control
devices perform according to their design, the rules for process vents require
that specific control device operating parameters be monitored continuously
and the monitoring information be recorded in the facility operating record.
3-2
-------
BIBLIOGRAPHY
1. "Hazardous Waste Treatment, Storage, and Disposal Facilities -- Organic
Air Emission Standards for Process Vents and Equipment Leaks."
Federal Register, Vol. 55 pages 25454-25519. June 21, 1990.
2. U.S. EPA, OAQPS, "Hazardous Waste Treatment, Storage, and Disposal
Facilities (TSDF) -- Background Information for Promulgated Organic
Emission Standards for Process Vents and Equipment Leaks,"
EPA-450/3-89-009, July 1990.
3. U.S. EPA, OAQPS. "Hazardous Waste TSDF - Technical Guidance Document for
RCRA Air Emission Standards for Process Vents and Equipment Leaks."
EPA-450/3-89-21. July 1990.
4. U.S. EPA, OAQPS. "Alternative Control Technology Document - Organic
Waste Process Vents" to be published in December 1990.
5. U.S. EPA, OAQPS. "RCRA TSDF Air Emissions - Background Technical
Memoranda for Proposed Standards." EPA-450/3-86-009. October 1990.
6. "Hazardous Waste Treatment, Storage, and Disposal Facilities; Air
Emission Standards for Volatile Organics Control." Federal Register,
Vol. 52, pages 3748-3770. February 5, 1987.
7. U.S. EPA/ORD/IERL. "Process Design Manual for Stripping of Organics."
Cincinnati, OH. Publication No. EPA-600/2-84-139. August 1984.
8. U.S. EPA. Cincinnati, OH. Hazardous Waste Engineering Research
Laboratory, Office of Research and Development. "Air Strippers and
Their Emissions Control at Superfund Sites." Publication No. EPA-
600/D-88-153. August 1988.
9. U.S. EPA. "Air Stripping of Contaminated Water Sources - Air Emissions
and Controls." Control Technology Center. Research Triangle Park,
NC. Publication No. EPA-450/3-87-017. August 1987.
10. U.S. EPA/0RD/HWERL. "Preliminary Assessment of Hazardous Waste
Pretreatment as an Air Pollution Control Technique." Publication No.
EPA-600/2-86-028, NTIS PB46-17209/A6. March 1986.
11. U.S. EPA. "Distillation Operations 1n Synthetic Organic Chemical
Manufacturing-Background Information for Proposed Standards." EPA
Publication No. EPA-450/3-83-005a. December 1983.
12. U.S. EPA. Air Pollution Training Institute, RTP, NC 27711. "APTI
Course 415 Control of Gaseous Emissions." EPA-450/2-81-005.
December 1981.
13. U.S. EPA. "OAQPS Control Cost Manual, 4th Edition." EPA 450/3-90-006.
OAQPS, RTP, NC 27711. January, 1990.
3-3
-------
What the ?
Purpose of presentation
Process
Vents
~Answer common questions on the RCRA
air rules for organic emissions from
process vents
Basic questions ง Process
Who is affected ?
Why was Subpart AA developed ?
How many facilities are out there ?
3-4
-------
Questions on details
s*
Process
Vents
What units are regulated ?
How does the regulation work?
When do the regulations become effective ?
What are the requirements for control devices ?
What records have to be maintained ?
What reports have to be filed ?
Who is affected ?
Process
Vents
Facilities subject to Part 270
- Permitted
- Interim status
Previously exempt hazardous
waste recycling units at these
facilities
What units are affected?
Steam strippers
Distillation
Fractionation
Thin-film evaporation
Solvent extraction
Air strippers
Process
Vents
3-5
-------
What units are exempted ?
Process
: Vents
Production
Wastewater treatment tanks
Subtitle D
Domestic Sewage
Closed-loop reclamation
Additional detail provided in your
workshop manual on page 3-18 as
Attachment A of this session
What vents are covered ?
Process
Vents
On affected units that manage hazardous
waste with 10 ppmw or greater total
organics on a time-weighted, annual
average basis
On tanks associated with an affected unit if
emissions from these process units are
vented through the tank
Overhead
A Vapors
Process
Vents
Example 7
Feed
Vapors
Air
Stripper
Waste in
Air in
Effluent ou?
3-6
-------
Condenser
Example 2
Vapors
Vapors
Vapors
Distillate
Receiver
Steam
Stripper
Waste In
Steam
Feed Tank
Accumulator
Tank
Vapors
^4
Effluent
Storage
_JL
Why was Subpart AA developed? |prฃew
Vent#
* To protect human health and the
environment
To control emissions from land-disposal
restriction treatment technologies
How many units are out there?
200
Process
Vents
w 100
Fractionation TWn-fBm Sotven) Steam AlrStrtppen
evaporation Extraction Shippers
Source: 1967 T5DR Survey
3-7
-------
What are the annual emissions
from a typical facility ?
Process
Vents
25.0
20.0 -
>; 15.0
c
o
10.0
5.0
0.0
-L
Large Facility Medium Facility Small Facility
Model Plants - Annual Emissions Estimates
H Process
Vents
How do the regulations work?
O IDENTIFY affected process vents
ฉ DETERMINE emission rates
0 SUM individual rates
ฉ COMPARE to emission rate limits
0 REDUCE emissions below limits or 95%
5*
O IDENTIFY
Units covered by the standards
- Distillation - Air stripping
- Solvent extraction - Fractionation
- Steam stripping - Thin-film evaporation
which
- Average 10 ppmw or greater organics in waste
Process
Vents
3-8
-------
- Direct measurement
- Use of knowledge
ฆ*4
@ DETERMINE 0 Process
Vents
Hourly and annual emission rates
with either
0 SUM S Process
- Vents
1
The individual emission rates to get
a facility process rate
0 COMPARE
Process
Vents
The total facility process vent emissions to the
hourly and annual emission rate limits
3-9
-------
ฉ REDUCE
Process
Vents
~ Facilities exceeding the emission rate limits must
Install controls which
- Reduce facility emissions below 3 Ib/hr and 3.1
ton/yr, or
- Reduce facility emissions by 95 percent
Facility Bubble for Emission Rate (ER) =
Process
Vents
Facility
= E Rpv i * E kPv2+E Rpvj
Faculty
Example 3 - Control Options for a Facility
*4
Process
Vents
ER fQcijiiy - ERpw + ERPv2 ป ERpvj
ER = 10+1+55 = 66 ton/yr
3-10
-------
Example 3 (cont.) - Control Options for a Facility
66(1-.95) = 3.3
Process
Vents
.... Option 1 - 95% control on
ER Facility= 'on/yr an three vents
Option 2 - 88% control on pvl
3.3 ton/yr vs. 3.1 ton/yr and 9g0/o confro| on pv3
When do the regulations
become effective?
Process
Vents
Regulations became effective on 1 111 1 /90
Compliance date depends on classification of
facility
When do the regulations
become effective? (cont.)
s*
Process
Vents
Interim status facilities have until 6/21/92 to
Install control equipment
Permitted facilities are shielded from Phase I air
standards
3-11
-------
What are the requirements
for control devices ?
No specific device required
Individual performance requirements for
- Vapor recovery systems
- Enclosed combustion devices
- Flares
Equipment must be properly operated,
maintained, and continuously monitored
Process
Vents
Process
Vents
What are the requirements
for vapor recovery systems
(e.g. condensers or adsorbers) ?
Recovery efficiency of 95 weight percent or
better
Primary recovery devices do not count
toward the 95 weight percent
What are the requirements for
enclosed combustion devices
(e.g., vapor incinerators,
boilers, or process heaters) ?
Designed and operated with a destruction
efficiency of 95 weight percent or greater
Minimum residence time of 0.5 second at
a minimum temperature of 760 ฐC
Process
Vents
3-12
-------
What are the alternative = p~cesi
requirements for incinerators ? e
Reduce incinerator exhaust to a
concentration of 20 ppmv total
organics or less
What are the requirements H Process
for flares ? b
No visible emissions
Flame present at all times
Net heating value requirements
Exit velocity requirements
Note
'S*
Process
Vents
Design requirements for demonstrated
control technologies are presented on
page 3-20 in Attachment B of this
session in your workshop manual
3-13
-------
What are the owner/operator |Pvents$s
responsibilities for
control devices ?
Inspect readings from each
monitoring device daily
Immediately implement corrective
measures, if necessary
Process
Vents
What is a
closed-vent system ?
's*
Process
Vents
Closed-vent System
Ducts, pipes, connectors,
and blowers which transport
vapors or gases from
equipment to a control
device
Carbon Adsorption System
3-14
-------
What records have
to be maintained ?
Facility compliance documents
Control device records
G*
Process
Vents
Facility compliance H Process
documents e
Waste stream determinations
Emission rate determinations
Control device records
Process
Vents
Control device implementation schedule
Design and operating information
Control device exceedance records
Information on alternative controls
3-15
-------
ฅ
Note
Process
Vents
Details on recordkeeping requirements
provided on page 3-23 in Attachment C
of this session in your workbook
have to be filed ?
Facilities with RCRA permits must report
semiannually all exceedances > 24 hours
Interim-status facilities are not required to
report control device exceedances
c\
What reports
Process
Vents
3-16
-------
Summary
Applicability
Decision
Tree
'RCRAn
FACILITY
NO
YES
N0 ^AFFECTED
\ UNITS 7 .
YES
/HAZ. \
WASTES
S10 PPMW
ORGANICS,
RULE iNO
DOES NOT U<;
APPLY J
YES
RCRAN
EXEMPT
UNITS .
NO f RULE
1 *\ APPLIES
YES
EXEMPT
DOES
THE RULE
APPLY ?
Process
Vents
Summary what are the
R Process
emission rate limits ? Venh
Reduce total organic emissions from aN
affected process vents
- Below 3 Ib/hr and 3.1 ton/yr,
or
- By 95% after primary recovery
3-17
-------
Process
Vents
Attachment A - RCRA Exempt Units s*
Production Units
Applies to hazardous wastes generated in
production or process-related equipment
Exemption applies until waste is removed
from the unit, unless the waste remains in
unit for > 90 days after operation ceases
40 CFR 261.4(c)
Attachment A - RCRA Exempt Units
Generator Accumulation
Tanks
Generators who accumulate waste in tanks
or containers for < 90 days are excluded
from permitting requirements
40 CFR 270 and 40 CFR 262.34
's*
Process
Vents
Attachment A - RCRA Exempt Units
Totally Enclosed
Treatment Units
Exempt from RCRA Subtitle C under
-40CFR 264.1(g)(5)
-40CFR 265.1(c)(9)
-40CFR 270.1(c)(2)
Process
Vents
3-18
-------
Attachment A - RCRA Exempt Units
Closed-Loop
Reclamation Units
40 CFR261.4 amended to allow control of
reclamation of hazardous wastes
Amendments did not change
closed-loop reclamation exemption in
40 CFR 261.4(a)(8)
ms4
'ฆ Process
: vents
Attachment A - RCRA Exempt Units
Wastewater Treatment
Units
Units regulated under Section 402 or 307(b)
of the Clean Water Act are not subject to
RCRA Subtitle C standards
40 CFR 270.1(c)
*4
Process
Vents
Attachment A - RCRA Exempt Units
Domestic Sewage Units
Domestic sewage excluded from
definition of solid waste
Domestic sewage units are not subject
to hazardous waste regulations
40 CFR 261.4(a)(1)
ms*
Process
Vents
3-19
-------
Attachment A - RCRA Exempt Units
Subtitle D Units
Process
Vents
Subtitle D wastes not subject to
hazardous waste regulations
Subtitle D wastes include hazardous
wastes generated by conditionally
exempt small-quantity generators
Attachment B - Control Device Design ซr*
= Process
Thermal Incinerators 1 Vents
Minimum and average combustion zone
temperature
Combustion zone residence time
40 CFR 264.1035(b) (4) (i ii)(A)
Attachment B - Control Device Design
Catalytic Incinerators
Minimum and average temperature
across the catalyst bed inlet and outlet
40 CFR 264.1035(b)(4)(iii)(B)
Process
Vents
3-20
-------
Attachment B - Control Device Design
Boilers and Process Heaters
Minimum and average combustion
zone temperature
Combustion zone residence time
Location of vent introduction into
combustion zone
40 CFR 264.1035(b)(4)(iii)(C)
Process
Vents
Attachment B - Control Device Design
Flares
Process
Vents
No site-specific design analysis required
Flares must meet specified design and
operation requirements (40 CFR
264.1033(d))
40 CFR 264.1035(b) (4>(iii)(D)
Attachment B - Control Device Design
Condensers
Outlet gas organic concentration level
Outlet gas temperature
Coolant fluid inlet and outlet temperature
40 CFR 264.1035(b) -A) (iii) (E)
Process
Vents
3-21
-------
Attachment B - Control Device Design
Regenerable Carbon
Adsorption Systems
Outlet organic concentration level
Number, type, and capacity of carbon beds
Type and working capacity of activated
carbon
Total steam flow over regeneration cycle
Piocess
Vents
Attachment B - Control Device Design
Regenerable Carbon
Adsorption Systems
(continued)
Duration of the steaming and cooling/drying
cycles
Carbon bed temperature after regeneration
Carbon bed regeneration time
Design service life of activated carbon
40 CFR 264.1035(b)(4)(iii)(F)
s*
Process
Vents
Attachment B - Control Device Design r*
= Process
Nonregenerable Carbon 1Vents
Adsorption - Carbon Cannisters
Outlet organic concentration level
Carbon bed capacity
Type and working capacity of activated
carbon
Carbon replacement interval
40 CFR 264.1035(b)(4)(iii)(G)
3-22
-------
Attachment C - Recordkeeping
Compliance
Documentation
Information and data to support:
Waste determinations
Identification of affected process vents
Unit throughputs and operating hours
Emission rate for each affected vent
Emission rate for total facility
Basis for determining emission rates
Vr*
: Process
: Vents
Process
Vents
Attachment C - Recordkeeping r*
Control Device |
Implementation Schedule
Dates for design, construction, and operation
of control devices
Schedule may allow 18 months for installation
of control devices
Must be in operating record on effective date
40 CFR 264.1035(b)(1)
Attachment C - Recordkeeping
Control Device
Design Documentation
Design analysis
References and sources used
Statement by owner/operator certifying device
is designed for maximum emissions
Statement by owner/operator certifying device
is designed for 95% efficiency
Performance test results
40 CFR 264.1033
*4
Process
Vents
3-23
-------
Attachment C - Recordkeeping
5*
Control Device
Operating Records
Description and date of each modification to
closed-vent system or control device
Identification of operating parameter to be
monitored, description of monitoring device,
and diagram of monitoring sensor locations
40 CFR 264.1035(c)
Process
Vents
Attachment C - Recordkeeping
Control Device
Exceedance Reports
Must report periods when control device
operates outside design tolerances
Records include date, duration, cause, and
corrective measures taken
40 CFR 264.1035(c)(5)
V*
: Process
: Vents
Attachment C - Recordkeeping
*4
Control Device
Exceedance Reports
Thermal Incinerators
(Operating at 0.5 s and 760 ฐC)
Periods when the combustion temperature
!s below 760 ฐC
40 CFR 264.1035(c)(4)(i)
: Process
ฆ Vents
3-24
-------
Attachment C - Recordkeeping
Control Device
Exceedance Reports
Thermal Incinerators
(Operating at 95% or 20 ppmw)
Periods when the combustion
temperature is more than 28 ฐC below
the design average temperature
40 CFR 264.1035(c)(4)(ii)
V*
Process
Vents
Attachment C - Recordkeeping
Control Device
Exceedance Reports
Catalytic Incinerators
Periods when the vent stream temperature
at the catalyst bed inlet is more than 28 ฐC
below the design average temperature, or
Periods when the temperature difference
across the catalyst bed is less than 80% of
the design average temperature difference
40 CFR 264.1035(c)(4)(iii)
Process
Vents
Attachment C - Recordkeeping
Control Device
Exceedance Reports
Boilers and Process Heaters
Periods when the combustion temperature is
more than 28 ฐC below the design average
temperature
A change in the location where the vent
stream is introduced to the combustion zone
40 CFR 264.1035(c) (4) (iv)
*4
Process
Vents
3-25
-------
Attachment C - Recordkeeping
Control Device
Exceedance Reports
Flares
Periods when the flame is not ignited
40 CFR 264.1035(c)(4)(v)
's*
Process
Vents
Attachment C - Recordkeeping
s4
Control Device
Exceedance Reports
Condensers
with Temperature Monitors
Periods when the temperature of the condenser
exhaust is more than 6 ฐC above the design
average temperature, or
Periods when the temperature of the coolant
fluid exiting the condenser is more than 6 ฐC
above the design average temperature
40 CFR 264.1035(c) <4) (vii)
Process
Vents
Attachment C - Recordkeeping
Control Device
Exceedance Reports
Carbon Adsorbers
Regenerated On-site with
Concentration Monitors
Periods when the organic concentration in the
carbon bed exhaust is more than 20% greater
than the design concentration
40 CFR 264.1035(c)(4)(viii
Process
Vents
3-26
-------
Attachment C - Recordkeeping
ฅ
Process
Vents
Control Device
Exceedance Reports
Carbon Adsorbers
Regenerated On-site with
Fixed Regeneration Schedule
Periods when the process vent stream continues
to flow to the device beyond the predetermined
bed regeneration time
40 CFR 264.1035(c)(4)(ix)
Attachment C - Recordkeeping
Information on
Alternative Control Devices
Owner/operator must record information
indicating proper operation
Regional administrator will specify appropriate
recordkeeping requirements in permit
negotiation process
40 CFR 264.1035(e)
Process
Vents
3-27
-------
SEPA
EQUIPMENT LEAK
STANDARDS
4-1
-------
ABSTRACT: EQUIPMENT LEAK STANDARDS (SUBPART BB)
This session covers the organic air emission standards for equipment leaks at
hazardous waste TSDFs codified in Subpart BB of 40 CFR Parts 264 and 265. The lesson
is designed to provide a basic understanding of the equipment leak rules to aid RCRA
permit writers and enforcement personnel in determining compliance and to aid facility
owners and operators in achieving compliance.
The session begins with a review of the background of the equipment leak rules
followed by a detailed presentation of the applicability of the rules. The control
requirements are briefly summarized with references to the standards for details.
Waste stream determinations for the purposes of applicability are covered in detail and
the recordkeeping and reporting requirements are summarized. As is the case with the
control requirements, references to the standard are provided for details of the
recordkeeping requirements.
4-2
-------
BIBLIOGRAPHY
1. "Hazardous Waste Treatment, Storage, and Disposal Facilities -- Organic
Air Emission Standards for Process Vents and Equipment Leaks."
Federal Register, Vol. 55 pages 25454-25519. June 21, 1990.
2. U.S. EPA, OAQPS, "Hazardous Waste Treatment, Storage, and Disposal
Facilities (TSDF) ~ Background Information for Promulgated Organic
Emission Standards for Process Vents and Equipment Leaks,"
EPA-450/3-89-009, July 1990.
3. U.S. EPA, OAQPS. "Hazardous Waste TSDF - Technical Guidance Document for
RCRA Air Emission Standards for Process Vents and Equipment Leaks."
EPA-450/3-B9-21. July 1990.
4. U.S. EPA, OAQPS. "RCRA TSDF Air Emissions - Background Technical
Memoranda for Proposed Standards." EPA-450/3-86-009. October 1986.
5. "Hazardous Waste Treatment, Storage, and Disposal Facilities; Air
Emission Standards for Volatile Organics Control." Federal Register,
Vol. 52, pages 3748-3770. February 5, 1987.
6. U.S. Environmental Protection Agency. Fugitive Emission Sources of
Organic Compounds--Additional Information on Emissions, Emission
Reductions, arid Cost. Research Triangle Park, NC. Publication No.
EPA-450/3-82-010. April 1982.
7. U.S. Environmental Protection Agency, Air Pollution Training Institute,
Research Triangle Park, NC 27711. "APTI Course SI:417 Controlling
V0C Emissions from Leaking Process Equipment." EPA 450/2-82-015.
August 1982.
4-3
-------
Organic Air Emission Standards
for Equipment Leaks
at Hazardous Waste Treatment,
Storage, and Disposal Facilities
40 CFR Parts 264 and
265 Subpart BB
Purpose
Provide basic understanding of
Subpart BB equipment leak rules
promulgated under Section 3004(n) of
RCRA
Highlights
Standards generally affect equipment
contacting organic wastes
Facilities may have hundreds of these
potential sources
Standards include leak detection and
repair (LDAR) and specified equipment
Compliance is demonstrated through the
maintenance of records
4-4
-------
Topics
Background
Applicability
Waste stream determination
Control requirements
Recordkeeping requirements
Reporting requirements
Summary
Topics
Background
Applicability
Waste stream determination
Control requirements
Recordkeeping requirements
Reporting requirements
Summary
Background
Subpart BB Equipment
Leak Standards
Promulgated June 21,1990
(55 FR 25454)
Effective date December 21, 1990
4-5
-------
Background
Standards
Adopted from CAA standards for:
- Benzene equipment leaks
- SOCMI
- Petroleum refineries
- Coke oven by-product plants
Revised to RCRA format
Parts 264 and 265 rules identical except
reporting is not required by Part 265
Exempt I
from |
Subpart BB [
No
Yes
[Yes
No
Yes
Yes
4-6
Hazardous waste
10% organic^
Subpart BB
does no!
apply
Background
Applicability
Waste stream determination
Control requirements
Recordkeeping requirements
Reporting requirements
Summary
Topics
-------
Applicability
Equipment Covered by Subpart BB
Pumps
Valves
Compressors
Sampling connections systems
Open-ended valves or lines
Pressure-relief devices
Flanges and other connectors
Labyrinth Shaft Seal for Compressors
A
Potential
c ^
Leak Gas
vmm?
Internal
Atmosphere
Gas Pressure
Rising Stem Gate Valve
Packing Nut
Packing Gland
Potential
Leak Areas
Packing
4-7
-------
Spring-Loaded Relief Valve
Emissions
(simmering, improper
reseating, pressure relief)
Spring
Possible
Leak Area
Disk
Vent
Process Side
Flanged Joint
Potential
/ Leak Area
Leaks caused by
Improperly chosen gaskets
Damaged gaskets
Poor assembly
Vibrations
Applicability
Equipment
Affected equipment is found in destruction
or recycling/recovery processes; for
example:
- Incineration
- Distillation
- Solvent extraction
- Steam stripper
- Storage tanks for reclaimed organics
4-8
-------
Steam Stripper
Process Vent
Primary Condenser
Vapor Phase /
in
Storage Tank
Storage
and
Feed Tank
Bottoms Receiver
Topics
Background
Applicability
Waste stream determination
Control requirements
Recordkeeping requirements
Reporting requirements
Summary
Waste Stream Determination
Waste organic content at least 10%
by weight
Gas or liquid at operating conditions
Liquid stream light or heavy liquid
4-9
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Waste Stream Determination
Basis of Determinations
Knowledge
Analysis by direct measurement
Waste Stream Determination
Examples of Knowledge
No organics used
Identical to other process
Prior speciation analysis with no process
changes
Waste Stream Determination
Applicability of Organic Content
Analytical Methods
Method
Compounds
most applicable
ASTM E 260-85
(General GC analysis)
Multiple compounds
ASTM D 2267-88
(Aromatics by GC)
Benzene, toluene. C8. and
heavier aromatics
Method 9060 (SW-8^6)
(Tola! organic carbon
(TOCI)
Organic carbon greater
than 1 mg/L
Method 8240 (SW-846)
(Votatiles by gas
chroma lographfmass
spectrometer (GC/MS))
Generally used to measure
Appendix VIII compounds
in wastewaters, sludges,
and soils
ASTM E 168-88
(Infrared [IR| analysis)
Single- or double-component
systems
ASTM E 169-87
(Ultraviolet (UV) analysis)
Single- or double-component
systems
4-10
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Waste Stream Determination
Applicability of Organic
Analytical Detectors
Compounds
Method
most applicable
Flame ionization
All
Photoionization
Aromatics
Hall electrolytic
Halogenated
conductivity
device
Nondispersive
Any compound with
infrared
C-H bond
Mass spectrometer
All
Waste Stream Determination
Gaseous Waste Determination
Gas at operating conditions
Example: Overhead stream from distillation
prior to the condenser
Waste Stream Determination
Light/Heavy Liquid Determination
A light liquid:
- Is a liquid at operating temperatures
- Contains compound(s) with vapor
pressure >0.3 kPa (0.04 psia) at
20 ฐC (68 ฐF)
ฆ Total concentration of pure
components with vapor pressure >C.3
kPa at 20 ฐC is greater than 20%
All liquids not light liquids are heavy
liquids.
4-11
-------
Topics
Background
Applicability
Waste stream determination
Control requirements
Recordkeeping requirements
Reporting requirements
Summary
Control Requirements
Work Practice
Work practices are based on a leak
detection and repair program (LDAR)
* LDAR varies by source type, but
includes:
- Leak detection monitoring
- Inspections - visual and olfactory
- Repair within a given time frame
Control Requirements
Leak Detection Monitoring with
Method 21
Portable total organic analyzer is used to
locate leaks from valves, flanges, and
pumps
A leak is defined as 10,000 ppm, based
on a reference compound
The Subpart BB reference compound is
methane or n-hexane
A response factor must be determined for
each compound to be measured
4-12
-------
Control Requirements
Repairs
The first repair attempt must be made
within 5 calendar days of detecting leak
Repair must be completed within 15
calendar days of detecting leak
Control Requirements
Emission Limits
For equipment designed not to leak (e.g., no waste
contact with external activating mechanisms)
No detectable emissions (Method 21)
Compliance test initially and at least annually
Sealless Pumps Can Be Designated
for No Detectable Emissions
Outer
coupling
O-ring
Containment
Bearings
Motor
Volute
Motor
stator
Bearing
$v rj- inner
VWy coupling
Motor (oior/pump shaft
Impeller
b. Canned motor centrifugal pump
a. Magnetically coupled centrifugal pump
4-13
-------
Sealless Pumps Can Be Designated
for No Detectable Emissions
Inner
coupling
Ouier . O-ring
coupling v \ x /Oearing
Motor
ป Gear
Magnets
c. Magnetically coupled gear pump
Oullei , Ball and seal
Hydraulic Huid
7mhj
Hie
V * Die-
* Cam
' Piston
11 Diaphragms
Inlet
d. Hydraulically backed diaphragm
metering pump
Control Requirements
Equipment Standards
Specified equipment (dual seals, closed vents,
caps, closed loop sampling)
Checked by visual inspection and for detectable
emissions (Method 21)
Leaks must be repaired within 15 days
Control Requirements
Summary
Source Service
Pump
Valvo
Emission
Limit
Equipment
Specification
Work
Practice
Light
liquid
Heavy
liquid
Gas & light
liquid
No detectable (or) Dual seals, (or)
emissions closed vent
Monthly moniioring
(and)
weekly inspection
No detectable (or)
emissions
Monthly moniioring
Heavy
liquid
"Monitoring is required if evidence ol a leak is found.
iHJ Indicates the primary control method.
4-14
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Control Requirements
Summary (continued)
Source
Service
Emission
Limit
Equipment
Specification
Work
Practice
Pressure-
reliof
Gas
No detectable
emissions
Closed vent
device
Light &
heavy
liquids
l 1
Flange/
connector
Gas & light
& heavy
liquids
i i
'Monitoring is required if evidence of a leak is found.
1 1 Indicates the primary control method.
Control Requirements
Summary (concluded)
Source
Sampling
connection
Open-
ended
line
Service
Compressor Gas
Emission
Limit
No detectable (or)
emissions
Gas & lighi
& heavy
liquids
Gas & light
& heavy
liquids
Equipment
Specification
Seal system
with barrier fluid,
orcfosedvent
Closed-purge
system or dosed
vont
Cap. plug, flange,
or second valve
Work
Practice
(!~ Indicates Ihe primary control method.
Double Mechanical Seal with Barrier
Fluid Controls Emissions
Possible Leak into
Sealing Fluid
Seal FacI?
Outer Seal Assembly
Inner Seal Assembl;
Fluid
End
4-15
-------
Handwheel Operated Pinch Valve
Rupture Disk
To Almosphere
Process S-de
Closed-Loop Sampling System
(To Avoid Losses from Sampling)
Process Line
Sample Container
4-16
-------
Process Fluid
(perhaps under (
pressure)
Valve
Closed
T
T
\ X ^ Pipe
\
j' Leak
k X
Cap
Open-Ended Line
(leaks through valve)
Cap When Not
in Use
Control Requirements
Equipment Leak Model Units
Model Sampling Open-ended Pressure-reliel
Unit Pumps Valves Connections Lines Devices
A
15
364
26
105
9
B
5
121
9
35
3
C
3
72
5
21
2
Control Requirements
Equipment Leak Impacts
Emission
Model
Emissions
Reductions
Capital Costs*
Annual Costs'
Unit
(Mg/yr)
(Mg/yr)
<%)
($>
(S)
A
41.1
30.4
74
68,300
31,000
B
13.7
10.2
74
27,000
11.900
C
8.3
6.2
74
18,700
8,100
Nationwide
26,200
19.000
72.5
127 million
32.9 million
'Costs are in 1986 dollars.
4-17
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Topics
Background
Applicability
Waste stream determination
Control requirements
Recordkeeping requirements
Reporting requirements
Summary
Recordkeeping
Compliance with the control
requirements of Subpart BB
is demonstrated through the
maintenance of records
Recordkeeping Requirements
General Records Required
Equipment-specific identification
information (Section 264.1064[b])
Closed-vent system and control device
information (Section 264.1064[e])
Information on equipment not subject to
monthly LDAR (Section 264.1064[g])
4-18
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Recordkeeping Requirements
General Records Required
(continued)
Marking of leaking equipment
(Section 264.1064[c]).
Information on leaking equipment
(Section 264.1064[d])
Barrier fluid system sensor information
(Section 264.1064[j])
Information for determining exemptions
(Section 264.1064[k])
Recordkeeping Requirements
Records Retention
Three years for records of:
- Monthly leak monitoring and repair
- Detectable emission monitoring
- Closed-vent and control device
operations
Other records in the facility operating
record must be kept for the life of the
facility.
Topics
Background
Applicability
Waste stream determination
Control requirements
Recordkeeping requirements
Reporting requirements
Summary
4-19
-------
Reporting Requirements
Information Required in Semiannual
Reports (264.1065)
Control device exceedances uncorrected
for >24 hours - dates, duration, cause,
corrective measures
Pumps in LL service, valves in G/LL
service, compressors not repaired in 15
days
No report required if no exceedances
Facilities subject to interim status
provisions, Part 265, are not required to
report.
Topics
Background
Applicability
Waste stream determination
Control requirements
Recordkeeping requirements
Reporting requirements
Summary
4-20
-------
Summary
Equipment Leak Rules
Equipment at new or existing TSDF requiring
RCRA Subtitle C permit
Equipment containing or contacting wastes with at
least 10% organic
Control requirements vary by type of service-
gas, light liquid, heavy liquid
Recordkeeping requirements to demonstrate
compliance
Semiannual reporting of exceedances
Summary
Types of Equipment Leak Standards
Sources
Equipment
Work
Practice
Emission
Limit
Pumps
(or)
(or)
Valves
(or)
Compressors
(or)
Sampling
connection systems
Open-ended
valves or lines
Pressure-relief
devices
Flanges and
other connectors
4-21
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PHASE II
AIR RULES
-------
ABSTRACT: RCRA PHASE II RULEMAKING
Under the RCRA Phase II rulemaking, the U.S. EPA is developing new
standards and amendments that would control more TSDF waste management
units and add new requirements and implementation changes to the existing
RCRA air emission standards under Subpart AA (TSDF treatment unit process
vents) and Subpart BB (TSDF equipment leaks). A new Subpart CC would be
added to 40 CFR Parts 264 and 265 requiring organic emission controls be
applied to TSDF tanks, surface impoundments, containers, and certain
miscellaneous units based on the volatile organic concentration of the waste
managed in the unit. In addition, compliance with the air emission control
requirements relevant to tanks and containers under Subparts AA, BB, and CC
would be included as a condition to maintain a permit exemption for 90-day
accumulation tanks and containers. Also, the U.S. EPA would amend 40 CFR
270.4 to require the owner or operator of an existing permitted TSDF to comply
with the RCRA air emission standards for interim status facilities (40 CFR 265
Subparts AA, BB, and CC) until the facility's permit is modified or renewed.
Finally, to be consistent with Subpart CC, the U.S. EPA would add to Subparts
AA and BB requirements for managing spent carbon removed from carbon
adsorbers.
5-2
-------
Purpose
Summarize the proposed
Subpart CC control
requirements
Present other requirements proposed in
the Phase II rulemaking
Highlights of Phase II Rulemaking
Control more TSDF waste management
units
Based on volatile organic concentration of
waste
New requirements added and
implementation changes for
Subparts AA and BB
Outline
Background
Proposed Subpart CC Standards
Proposed Test Methods
Other Proposed Amendments
Summary
5-3
-------
Background
TSDF Organic Emissions
Contribute to ambient ozone formation
- 1.8 million megagrams per year of
organics
Impact public health
- 140 cancer incidences per year
nationwide
- Maximum individual risk of cancer
= 2x10-2
Contribute to stratospheric ozone
depletion
National VOC Emissions - Stationary Sources
Hazardous Waste TSDF
Industrial Processes
2%
Surface Coating
20%
Petroleum Marketinq
14%
Petroleum Refining
5%
Misc Solvent Uses
< ฆ , |i
23%
I
A--''
'
i
TSDF
1 P
VNป 12%
J
Phase 2
98%
Phase 1
2%
Chemical Manufacture
3%
Misc. Sources
20%
5-4
-------
Rulemaking Status
Proposal
Public hearing
Public comment period ends
EPA reviews and considers public
comments
Final rules promulgated
Outline
Background
Proposed Subpart CC standards
Proposed test methods
Other proposed amendments
Summary
Proposed Subpart CC Standards
Add air emission control requirements for
more TSDF waste management units
Same implementation as Subparts AA
and BB
- Subpart CC in Part 264 for permitted
TSDF
- Subpart CC in Part 265 for interim
status TSDF
Requirements identical except for
reporting in Part 264
5-5
-------
Subpart CC Standards
Applicability
RCRA Subtitle C facilities
Waste management units
- Tanks
- Surface impoundments
- Containers
- Miscellaneous units
Subpart CC Standards
Control Strategy
Identify waste streams with significant
emission potential
Control waste from point where it is
generated through treatment to remove or
destroy organics
Other rules establish treatment standards
Subpart CC Standards
Demonstration of Compliance
Either:
1. Install and operate organic emission
controls
or
2. Determine that waste managed in unit at
all times has a volatile organic
concentration <500 ppmw
or
3. Certify that waste managed in the unit
complies with Part 268 land disposal
restrictions treatment standards for
organics
5-6
-------
Subpart CC Standards
Tanks
Cover and vent to a control device
Alternative controls:
- External floating roof
- Fixed roof with internal floating roof
Control device not required for certain
tanks:
- Organic vapor pressure below
certain limits
- Waste managed in a "quiescent"
manner
Subpart CC Standards
Surface Impoundments
Cover and vent to a control device
Control device not required when waste is
managed in a "quiescent" manner
Subpart CC Standards
Containers
Cover
Submerge fill pumpable waste
Enclose and vent to a control device
during certain waste treatment processes
(e.g., waste fixation)
5-7
-------
Subpart CC Standards
Miscellaneous Units
Case-by-case determination based on
similarity
Comply with requirements in
40 CFR Subparts AA, BB, or CC
Example:
If miscellaneous unit resembles a
surface impoundment
Then -~ comply with surface
impoundment standards
Outline
Background
Proposed Subpart CC standards
Proposed test methods
Other proposed amendments
Summary
Test Methods Background
Used to determine which waste streams
require controls
Focus on organics potentially emitted
rather than total organics
Does not measure specific organic
compounds
Methods would be added to both:
- 40 CFR 60 Appendix A
- "Test Methods for Evaluating Solid
Waste, Physical/Chemical Methods"
(SW-846)
5-8
-------
Test Methods
Volatile Organic Concentration
Reference Method 25D/Test Method 5100
Procedure:
1. Collect representative samples;
minimizing loss of volatiles
2. Heat sample and purge with nitrogen
3. Analyze purged stream for carbon, as
methane, and halogens, as chloride
4. Sum methane mass and chloride
mass
Test Methods
Organic Vapor Pressure
Reference Method 25E/Test Method 5110
Procedure:
1. Collect representative samples
2. Analyze head space vapor for carbon
as propane
3. Calculate vapor organic pressure from
measured propane concentration
Outline
Background
Proposed Subpart CC standards
Proposed test methods
Other proposed amendments
Summary
5-9
-------
Proposed Amendments
Add new requirements and
implementation changes to
Subparts AA and BB
Affect:
- 90-day accumulation of hazardous
waste
- Implementation of RCRA air rules
- Management of spent carbon from
carbon adsorbers
90-Day Accumulation
Current Requirements
Generator tanks and containers
accumulating waste for 90 days or less
Exempt from the permitting requirements
if comply with certain conditions in
40 CFR 262.34(a)
Conditions include compliance with:
- 40 CFR 265 Subpart I for containers
- 40 CFR 265 Subpart J for tanks
90-Day Accumulation
Proposed Requirements
Add air emission control requirements to
maintain permit exemption
Amend 40 CFR 265 Subparts I and J
Conditions for exemption for a tank or
container would include compliance
with relevant requirements in
Subparts AA, BB, and CC
5-10
-------
RCRA Rule Implementation
Current Practice for New RCRA Rules
Interim status TSDF comply by rule's
effective date
Permitted TSDF comply when the facility's
permit is modified or renewed
RCRA Rule Implementation
Proposed Implementation of
RCRA Air Rules
Change implementation practice for
Subparts AA, BB, and CC by amending
40 CFR 270.4
Would require compliance by rule's
effective date regardless of permit status
RCRA Rule Implementation
Proposed Implementation of
RCRA Air Rules
(continued)
TSDF with a permit issued before
effective date would comply with the Part
265 standards until the facility's permit is
modified or renewed
TSDF with a permit issued or renewed
ฆ after effective date would comply with
the Part 264 standards
5-11
-------
Spent Carbon
Current Management
Activated carbon periodically replaced
Spent carbon saturated with organics
No environmental benefit if the organics
adsorbed on spent carbon are released to
the atmosphere
Spent Carbon
Proposed Management Requirements
Add requirements requiring offsite
regeneration, reactivation, or disposal be
controlled
Amend Subparts AA and BB to be
consistent with Subpart CC
Spent Carbon
Proposed Management Requirements
(continued)
Would require certification that spent
carbon is managed in either:
1. Regeneration/reactivation process
that minimizes air emissions
or
2. Incinerator complying with
40 CFR 264 Subpart 0
5-12
-------
Outline
Background
Proposed Subpart CC standards
Proposed test methods
Other proposed amendments
Summary
Summary
Establish air emission standards for TSDF
tanks, surface impoundments, containers,
and miscellaneous units
Require organic emission controls be
applied to waste streams with volatile
organic concentration >500 ppmw
Add new waste test methods to determine
volatile organic concentration and organic
vapor pressure
Summary
(continued)
Add compliance with relevant air emission
control requirements under Subparts AA,
BB, and CC to maintain permit exemption
for 90-day tanks and containers
Require permitted TSDF comply with
Subparts AA, BB, and CC under Part 265
until the facility's permit is modified or
renewed
Add spent carbon management
requirements to Subparts AA and BB
consistent with Subpart CC
5-13
-------
3 EPA
RCRA OVERVIEW
A-l
-------
RCRA Overview-Purpose
Summarize RCRA
Discuss structure of Subtitle C program
Review goals of Subtitle D program
Provide context for TSDF air emission rules
RCRA Overview - Highlights
RCRA-TheAct
Subtitle C -
Hazardous Waste
40 CFR Parts addressing TSDF air emissions:
264 Permitted TSDF standards
265 Interim status TSDF standards
270 Permit program
Subtitle D - Solid Waste (nonhazardous)
RCRA Overview-Outline
1.
RCRA Overview
- RCRA Orientation Video Segment 1
"Introduction to RCRA" (12 minutes)
2.
Subtitle C - Structure and Operation
3.
Relationship of 3004(n) Standards to Other
RCRA Rules
4.
Additional RCRA Air Standards
A-2
-------
Resource Conservation and
Recovery Act (RCRA)
Title II - Solid Waste Disposal
Subtitle C - Hazardous Waste Management
RCRA Subtitle C -
Hazardous Waste Management
A Federal "cradle-to-grave" system to manage hazardous waste
Statutes and regulations for hazardous waste:
Identification and listing of hazardous waste
Generators
Transporters
Treatment, storage, and disposal facilities
Permitting
Enforcement
State authorization
RCRA Hazardous Waste Program -
Title 40, Code of Federal Regulations
40 CFR Part Title
260
Hazardous waste management system: general
261
Identification and listing of hazardous waste
262
Standards applicable to generation of hazardous waste
263
Standards applicable to transporters of hazardous waste
264
Standards for owners and operators of hazardous waste
treatment, storage, and disposal facilities
265
Interim status standards for owners and operators of
hazardous waste treatment, storage, and disposal facilities
A-3
-------
RCRA Hazardous Waste Program -
Title 40, Code of Federal Regulations (continued)
40 CFR Part Title
266
Standards for the management of specific hazardous wastes
and specific types of hazardous waste management facilities
267
Interim status standards for owners and operators of new
hazardous waste land disposal facilities
268
Land disposal restrictions
270
EPA-administered permit programs: the hazardous waste
permit program
271
Requirements for authorization of State hazardous waste
programs
124
Procedures for decisionmaking
Waste Classifications
Definition of solid waste
Definition of hazardous waste
Exclusions to definitions
Hazardous Waste Definition
Characteristic wastes
Listed wastes
Mixture rule wastes
Derived from rule wastes
A-4
-------
Hazardous Waste Characteristics
Define characteristics in terms of
Physical,
Chemical, or
Other hazardous waste properties
Measure properties by standardized and available testing protocols
Hazardous Waste Characteristics (con.)
Characteristic Ignitable
RCRA Code D001
Corrosive
D002
Reactive
D003
Toxic*
D004 - D043
"Toxicity characteristic leaching procedure (effective 9/29/90).
Hazardous Waste Listings
Category
Nonspecific industry sources
Specific industry sources
RCRA Codes
F
K
Commercial chemical products, P and U
manufacturing chemical intermediates,
and contaminated soils and cleanup materials
A-5
-------
RCRA Waste Codes
F001 - F028 Wastes from Non-Specific Sources
Examples:
Spent halogenated degreasing solvents (F001)
Sludges from electroplating (F006)
RCRA Waste Codes
K001 - K136 Wastes from Specific Sources
Examples:
Oil emulsion solids from petroleum refining (K049)
Wastewater sludge from toxaphene production (K041)
RCRA Waste Codes
P001 - 122 and U001 - 359 Discarded/Off spec
Chemical Products/Species
Examples:
Container residue - dieldrin (P037)
Spill residue - pyridine (U196)
A-6
-------
Generators
Facility owner or operator or person who first creates a
hazardous waste
or
Person who first makes the waste subject to Subtitle C
regulations:
Combines hazardous wastes
Imports hazardous waste
Generators (con.)
Three categories:
- Large-quantity generators
- Small-quantity generators
- Conditionally exempt small-
quantity generators
greater than 1,000 kg/mo
ฆ- 100 to 1,000 kg/mo
ป- less than 100 kg/mo, or
less than 1 kg/mo if acutely
hazardous
Generators (con.)
EPA identification numbers
Pretransport requirements
Manifests for shipments
Recordkeeping and reporting
Hazardous waste accumulation time
- No permit required if accumulated less than
90 days - large-quantity generators
180 or 270 days - small-quantity generators
No time limit - conditionally exempt small-quantity
generators
A-7
-------
Hazardous Waste Generator Statistics
Waste Quantity by Generator Size
Small-Quantity Generators (1%)
(2 million Mg/yr)
Large-Quantity Generators (99%)
(273 million Mg/yr)
Source: EPAOSWER, The Hazardous Waste System, June 1967.
Hazardous Waste Generator Statistics
Number of Generators by Generator Size
Large-Quantity Generators (75%)
(71,000)
Small-Quantity Generators (25%)
(26,000)
Source: EPAOffice of Solid Wasle, April 1984 and June 1986.
A-8
-------
Transporters
EPA identification number
Marking, labeling, packaging, placarding, and spill reports
Manifest system
Handling hazardous waste discharges
Storage more than 10 days - RCRA storage permit
Basic Permitting Requirements
Any facility that treats, stores, or disposes of hazardous waste
must have a permit
Permit exemptions limited to:
- Generator accumulation time
- Emergency situations
- Imminent and substantial endangerment situations
Interim Status Standards
Applies to facilities not yet permitted
To qualify for interim status, a facility must:
- Exist when it becomes subject to permit requirements
- Notify EPA under RCRA Section 3010
- Submit Part A permit application which
Describes waste types and quantities
Identifies waste management processes
Interim Status is Temporary!
Available only until the final permit decision
A-9
-------
Interim Status Standards (con.)
Self-implementing
Administrative standards (apply to all facilities):
- Waste analysis plan - Manifest system
- Personnel training program - Closure and post-closure plans
- Contingency plan - Financial responsibility
Interim Status Standards (con.)
Technical standards address specific types of units:
- Containers - Landfills
- Tanks - Land treatment units
- Surface impoundments - Incinerators
- Wastepiles - Thermal treatment units
- Chemical, physical, and biological treatment
Components of a Permit
General facility standards
- Security
- Inspection
- Personnel training
- Location standards
- Preparedness and prevention
- Manifest system
- Recordkeeping and reporting
A-10
-------
Components of a Permit (con.)
Waste analysis plan
Contingency plan
Training plan
Closure plan
Post-closure plan
Corrective action schedule of compliance
Air emissions
Components of a Permit (con.)
Unit-specific standards
- Containers
- Landfills
- Tanks
- Land treatment units
- Surface impoundments
- Incinerators
- Wastepiles
- Miscellaneous units
(Subpart X)
RCRA Permit Process - Key Steps
Applicant submits Part B permit application
EPA reviews application
EPA prepares draft permit
EPA issues public notice to local newspapers and radio stations
- Notice of draft permit, or
- Notice of intent to deny permit
A-ll
-------
RCRA Permit Process - Key Steps (con.)
EPA allows 45-day comment period
EPA holds public hearing, if requested
EPA issues final decision and responds to comments
Public appeals decision (if desired)
Statutory Deadlines for Permitting
Waste Managemenl Process
Application
Due
Agency
Decision
Land disposal facilities
11/85
11/88
Incinerators
11/86
11/89
Storage/trealment and
11/88
11/92
miscellaneous units (Subpart X)
Land Disposal Restrictions
Requires treatment prior to land disposal
Exception - Case-by-case petition demonstrating no migration
from disposal unit
- Treatability
- National treatment capacity
- Surface impoundment exemption
2-Year variance where no treatment capacity exists
A-12
-------
Land Disposal Restrictions
Implementation of restrictions
Solvents and dioxins
November 8,1986
California list
July 8, 1987
First third scheduled wastes
August 8,1988
Second third scheduled wastes
June 8,1989
Third third scheduled wastes
May 8, 1990
Newly listed wastes (post-1984)
LDR determination
6 months after listing
40 CFR 271 - Requirements for Authorization
of State Hazardous Waste Programs
Procedures to grant States authority to administer RCRA in lieu of
Federal authority.
Standards Development
under Section 3004(n)
Phase I
Total organics
Process vents and equipment leaks
Promulgated 6/21/90 (55 FR 25454)
Phase II
Total organics
Tanks, surface impoundments, containers
and miscellaneous units
Phase III
Individual constituent standards, as needed,
to supplement Phase I and Phase II standards
A-13
-------
Relationship of 3004(n)
Standards to Other Rules
Hazardous waste toxicity characteristic
Land disposal restrictions (LDR) under Section 3004(m)
Corrective action under Section 3004(u)
CERCLA/SARA
Toxicity Characteristic
Background
RCRA interprets "hazardous" characteristic as:
- Ignitable - Reactive
- Corrosive - Toxic
40 Toxic organic and inorganic compounds and elements
Concentration-based limits for toxicity characteristic
leaching procedure
Effective date = September 25,1990
Toxicity Characteristic
Relation to Section 3004(n) Standards
Increases the volume of waste managed as hazardous
A-14
-------
Land Disposal Restrictions
Background
Treatment required before land disposal
Land disposal units include:
Landfills
Surface impoundments
Wastepiles
Land treatment units
Underground injection wells
Final effective date = May 8, 1990
Surface impoundments (treatment) exempt
if dredged annually
Land Disposal Restrictions
Air Emissions Reduced by Land Ban
Organic Emission
Sources
Yes
No
Tanks
V
Containers
V
Process vents
V
Equipment leaks
V
Miscellaneous units
V
Surface impoundments
V
Landfills
V
Land treatment units
V
Wastepiles
V
Underground injection wells
V
Land Disposal Restrictions
Impact on TSDF Air Emissions
Treatment can cause cross-media air emissions
Treatment reduces air emissions from land disposal units
A-15
-------
Land Disposal Restrictions
Relation to TSDF Air Standards
Phase I addresses LDR treatment process emissions
Phase II suppresses emissions to LDR treatment unit
for removal or destruction
Corrective Action
Background
Addresses constituent releases to air, water, and soil
Applies to hazardous and solid waste management
units at TSDF
Establishes site-specific compliance standards for
releases to each media
Corrective Action
Relation to Section 3004(n)
Air Standards
Corrective action units must comply with air rules
Corrective action relies on Section 3004(n) for control
of organic emissions
A-16
-------
CERCLA/SARA
Background
Authorizes EPA to "remove" and "remediate" hazardous
substance releases
"Removal"-short-term action to minimize exposure
Example: cleanup of a transportation spill
"Remediation"-long-term action to provide permanent remedy
CERCLA/SARA
Criteria
Site-specific
10"6 target risk
Meet ARARs
CERCLA/SARA
ARARs - "Applicable or Relevant
and Appropriate Requirements"
"Applicable" requirements - rules applicable to CERCLA
actions
"Relevant and appropriate" requirements - rules not
applicable but similar
A-17
-------
CERCLA/SARA
ARARs - Relation to TSDF
Air Standards
Phase I may be ARARs for certain processes
Phase II when promulgated may be ARARs for certain
processes
Hazardous waste generated at CERCLA sites would
be managed at TSDF (under air standards)
CERCLA/SARA
ARARS Potential Relation
to TSDF Air Standards
Applicable
Relevant and
appro priats
Hazardous wastes
>10 ppmw
volatile organics
'Substances" (e.g., non-
hazardous wastes)
>10 ppmw
volatile organics
CERCLA Management
Processes:
Distillation
Thin-film evaporation
Air stripping
Steam stripping
Fractionation
Solvent extraction
CERCLA/SARA
ARARs - Relation to TSDF
Air Standards
Phase I process vent standards are neither "applicable" nor
"relevant and appropriate" to:
Soil excavation In situ soil vapor extraction
In situ steam Soil washing
stripping of soil _ Bioremediation
In situ stabilization
Low-temperature thermal
desorption
A-18
-------
Additional RCRA Air Standards
Currently Regulated
Land disposal units (particulates)
Incinerators
Miscellaneous units (general)
Thermal treatment units
(interim status TSDF only)
Boilers and industrial furnaces
Land Disposal Units
40 CFR 264/265, Subparts L, M, & N
General design and operating practices to limit
particulates
Applicable to:
Wastepiles
Land treatment units
Landfills
Guidance document:
Hazardous Waste TSDFFugitive Particulate Matter Air
Emissions Guidance Document, May 1989
(EPA 450/3-089-019, NTIS No. PB 90103250)
Incinerators
40 CFR 264/265, Subpart O
Performance standard:
99.99% Destruction and removal efficiency for principal
organic hazardous constituents
Air emission limits on:
Hydrochloric acid
Particulates
Carbon monoxide
Revised risk-based regulations proposed in April 1990
A-19
-------
Miscellaneous Units
40 CFR 264, Subpart X
Musi prevent air releases that adversely affect human
health and the environment
Thermal Treatment Units
40 CFR 265, Subpart P
Interim status facilities only
Requires monitoring for:
Visible emissions
Operating conditions
Prohibits open burning (except for explosives)
Boilers and Industrial Furnaces
40 CFR, Part 266
Proposed 52 FR 16987 (May 6, 1987)
Performance standard:
99.99% Destruction and removal efficiency for principal
organic hazardous constituents
Air emission limits on:
- Carbon monoxide
- Metals
- Hydrochloric acid
A-20
-------
Case Study:
Measuring and
Estimating Emissions
B-l
-------
Measure or Estimate?
Sources to be constructed
Enclosed vented sources
Accuracy thai can be obtained
Is upper bound sufficient?
Variability (waste, operation, weather)
Cost and timing
Emission Measurements
Direct measurement
Indirect measurement
Engineering calculation
Direct Measurement
Vent sampling
Isolation flux chamber
B-2
-------
Vent Sampling
Vent
iftfl
v.T
Probe
ฃ
Calibration
Valve
Particulate
Filter or
Separation
Device
Sampling
Pump
Sample
Container
or
On-Line
Analyzer/
Recorder
Sampling
Applicable to TSDF
Approach
Emission Sources
Vent sampling
Vented treatment systems
Vented landfills
Vented storage buildings
Storage tanks
Solvent recovery
Isolation Flux Chamber and
Supporting Equipment
Carrier
Gas
Temperature
Sensor / Recorder
Impeller
Sampling
Plexiglas
Top
Outlet
Real-Time
Anal/zer
Stainless Steel
or Plexiglas
B-3
-------
Sampling
Applicable to TSDF
Approach
Emission Sources
Isolation flux
Active landfills
chamber
Inactive landfills
Surface impoundments
Land treatment
Cracks on landfill cap
Vents
Indirect Measurement
>
Concentrationprofile technology
Transect technology
Concentration-Profile Technology
Sampling
Mast
Direction *4
Indicator
Sampling
Probes
Y///////////S
Real-Time y.
'// uaia //
y. Collection V/
LfesuA
Thermocouple
Ground or Liquid Surface
B-4
-------
Sampling
Approach
Applicable to TSDF
Emission Sources
Concentration
profile technology
Surface impoundments
Land treatment
Concentration Profile Technology
Not suitable for quiescent or unstable
wind conditions
Not applicable to heterogeneous site with
many different emission sources
Transect Technology
Wind
Speed
Sensor
Sar
Wind
Direction
Indicator
Sampling
Probe at
an Upwind
Location
Virtual
Point
Source
* Plume Centefflne
Source
B-5
-------
Sampling
Applicable to TSDF
Approach
Emission Sources
Transect technology
Active landfills
Surface impoundments
Land treatment
Drum storage area
Transect Technology
Not suitable for quiescent or unstable
wind conditions
Applicable to disturbed and undisturbed
area sources
Applicable to heterogeneous site
Mass Balance Approach
Air emissions
Waste in
ฆ ~
Biodegradation,
adsorption, and
other mechanisms
Waste out
~
B-6
-------
Sampling
Applicable to TSDF
Approach
Emission Sources
Mass balance
Solvent recovery process
Surface impoundments
Land treatment
Wastewater treatment
Mass Balance Approach
Accuracy limited by precision of measurements
Difficult for non-steady-state and heterogeneous
waste streams
Other competing mechanisms should be quantified
Emission Measurements
PROS
CONS
Site-specific results
Affected by site and
ambient conditions
Standardized methods
Cost
Reasonable precision
Time requirements
Sensitivity varies
B-7
-------
Estimating Emissions
Overview
Models for open liquid surfaces
- Wastewater treatment tanks
- Surface impoundments
Models for porous solids
- Land treatment
- Landfills
- Waste piles
Overview
Why Use Models?
Evaluate estimates or measurements
Sources to be constructed
Measurements impractical or inaccurate
Understand factors affecting emissions
Sensitivity analysis: bounds on estimates
Environmental and health impact analyses
Overview
Modeling Limitations
Real system always more complex
Uncertainties and effect on accuracy
Availability of inputs
- Parameters describing system
- Variables (e.g., waste, process)
B-8
-------
Overview
Volatility
Concentration in vapor/concentration in waste
Henry's law constant for aqueous wastes
Measured data available for some compounds
Approximated by vapor pressure/solubility
For organic liquids, estimate volatility from
vapor pressure and mol fraction in liquid
Overview Examples of Volatility with Equal
Volume of Vapor and Waste
Benzene dissolved in water
- 20% in vapor
- 80% in water
Benzene dissolved in oil
- 0.2% in vapor
- 99.8% in oil
Phenol dissolved in water
- <0.002% in vapor
- 99.998+% in water
Overview
Emission Potential
Quantity of waste, Q
Concentration of organics entering source, C
Potential emissions = Q x C
Models estimate fraction emitted, f
Emissions = Q x C x f
B-9
-------
Open liquid surfaces
Modeling Approach
From Surtacซ lo Air
~ Two mechanisms in series
- Through liquid to surface
- From surface to air
i 1 1
Rate-controlling step
1 1 1
- Liquid phase
Diffusion Through Uquid
- Gas phase
Other removal mechanisms
- With effluent
- Biodegradation
- Sludge
Effect of Volatility on Emissions from a
Surface Impoundment
(Residence Time of 10 days)
TJ
-------
Fate of Organics: Emissions,
Effluent, Biodegradation, Sludge
Emissions
Wind
Flow In
Biodogradation
Sludge
ฆ Flow Out
- Sludge Out
Open liquid surfaces
Mass Transfer Correlations
(Calm Surfaces)
Liquid-phase mass transfer
- Diffusivity in liquid
- Wind speed
- Fetch/depth
Gas-phase mass transfer
- Volatility
- Diffusivity in air
- Wind speed
- Diameter
Open liquid surfaces
Mass Transfer Correlations
(Turbulent Surfaces)
Developed for mechanical aeration
Major parameters
- Power (hp) to aerators
- Diffusivities
- Impeller diameter and speed
Combine for calm and turbulert
- Fraction of area that is calm
- Fraction that is turbulent
- Weight coefficient based on fractions
B-ll
-------
Open liquid surfaces
Biodegradation Model
Monod kinetics
Effect of concentration
Biomass concentration
Data available for many compounds
Open liquid surfaces
Special Cases
Plug flow vs. well mixed
Oil-film surface
Diffused-air aeration
Disposal impoundment
Typical Model Inputs
(Liquid Surfaces)
Waste:
Constituents
Properties
Concentration
Quantities
Oil Content
Process:
Area
Depth
Agitation
Aeration
Flow Type
Site:
Wind Speed
Temperature
Emission Model
I
Emission Estimate
B-12
-------
Model Inputs for a Surface Impoundment
Wind
Berm
Surface Area
Waste
Dซฆ Waste
Out
Biomass Concentration
Depth
Model Inputs for an Aerated Lagoon
Wind I
Surface Area -
M:
J y Wasl0 Qul\
i Tfr^^
ฆ,. i ^ ^Aeration / I
Waste In gjomass Concentration / ^ P
Porous solids
Modeling Approach
Before mixing:
- Thin layer of waste on surface
- Use gas-phase mass transfer coefficient
After mixing:
- Air (in soil) and waste at equilibrium
- Diffusion through air voids to surface
B-13
-------
Air Porosity vs. Total Porosity
Vapors Move in Air
Water
^ Adsorption
onto soil particles
Biodegradation, / n
if any Absorption
V _ into oil and water
Land Treatment Emission Mechanisms
Wind
Volatilization
Diffusion
through pores
Porous solids
Biodegradation
Land treatment data available for
benzene and toluene
Aqueous data available for many compounds
Land treatment biorate extrapolated from
aqueous data
Rate is first-order for concentration
B-14
-------
Typical Model Inputs
(Porous Solids)
Emission Model
Site:
Wind Speed
Temperature
Process:
Area
Depth
Application Time
Waste:
Constituents
Properties
Concentration
Quantities
Porosity
Oil Content
Emission Estimate
Model Inputs for Land Treatment
Application Method
Waste Loading Area
Surface Area
Porosity
Model Inputs for a Covered Landfill
Depth
of
Waste
Cap i \
Venls Thickn0SS
C ^ Areaot 8
lง^5ap i
Cap Porosity
Waste Porosity
B-15
-------
Case Study:
Equipment Leaks Testing
EPA Method 21
c-i
-------
OVERVIEW
Method 21
Instruments and their operation
Field monitoring concerns
Comparison of available instruments
METHOD 21
For Subpart BB - identifies leaks, does not
quantify emissions
Promulgated in 40 CFR Part 60, Appendix A
Revised June 22,1990 (55 FR 25602)
METHOD 21 SPECIFICATIONS:
Instrument must respond to specific
compounds
Scale readable to 2.5% of leak concentration
Sample gas flow rate between 0.1 and
3.0 liters per minute
Instrument must be rated intrinsically safe
C-2
-------
METHOD 21
PERFORMANCE CRITERIA:
* Response factors less than 10
* Response time less than 30 seconds
* Calibration precision equal to or less than
10% of the calibration gas concentration
PERFORMANCE EVALUATION
REQUIREMENTS:
* Response factors needed for each
compound
* Response time checked initially and
after modifications affecting sample flow
* Calibration precision checked quarterly
INSTRUMENTS AND THEIR OPERATION
Types of Instruments
Daily pre-use checks (video)
Calibration gases
Response factors
C-3
-------
TYPES OF PORTABLE ORGANIC ANALYZERS:
Flame ionization
Catalytic combustion
Photoionization
Infrared
FLAME IONIZATION DETECTOR
OPERATING PRINCIPLES:
Sample gas is mixed with pure hydrogen
Organic vapors form positive ions
during combustion
Ions are collected and current flow
is amplified
C-4
-------
SINTERED
METAL
P FLAME
ARRESTOflS
EXHAUST
fuel
filler ano flow
RESTRJCTOW
refill
FITTING
SLOE PM> ASST.
SAMPLE HOSE
UUBaiCALCOAC
reaooutAssr
PCK-UP FIXTURE
C-5
-------
PHOTOIONIZATION ANALYZER
OPERATING PRINCIPLES:
Organic vapor Is exposed to high
energy UV light
* Ions are formed, collected, and
amplified
PHOTOIONIZATION LAMP CLEANING:
Frequency - when routine response
checks indicate a loss
in sensitivity
Procedure - cleaning compounds or
solvents (check with
the instrument supplier)
-------
CATALYTIC COMBUSTION ANALYZER
OPERATING PRINCIPLES:
Sample gas exposed to catalyst
coated wire
Heat of combustion of organic vapor
changes electrical resistance of wire
Change in resistance is detected by
Wheatstone bridge circuit
LB. (muiMfc-Mj .ปซ> B.uปnr
WM1ATURB
OOU-Mซ
Sulinl Model i
CซIU In
.VIBRATION
ISO LATINO
RECEPTACLE
OOX3H4SI
^-VasteSkVc
retainer OOOl-eOM
STUD 0001-S06ฉ
REACTION CHAMBER
CNABS9
SUBASSEMBLY
00JJ-4M3
C-7
-------
DAILY PRE-USE CHECKS:
(Video -11 minutes)
Battery status
Amplifier linearity
Probe leak checks
Probe/filter deposits
Sample gas flow rate
Hydrogen pressure
CALIBRATION GASES:
* Flame ionization detectors and catalytic
combustion analyzers
-10,000 ppm methane (n-hexane) in air
- Also suggest 500 ppm in air
CALIBRATION GASES:
Photoionization analyzers
- Poor response to methane and n-hexane
- Other compounds may be used (e.g., benzene)
- Conversion factors are needed when other
compounds used
C-8
-------
RESPONSE FACTOR DEFINITION:
Response factor = actual conc.
meter reading
EXAMPLE 1
Instrument
nnO
Catalytic combustion
Organic vapor
ซroC>
Methanol
Actual conc.
kdC>
10,000 ppm
Meter reading
[mQ>
5,000 ppm
Response factor
nrC>
2
EXAMPLE 2
Instrument
BOD<>
Flame ionization
Organic vapor
ncC>
o-Chlorotoluene
Actual conc.
irrQ>
3,028 ppm
Meter reading
mO
6,056 ppm
Response factor
hddC>
0.5
C-9
-------
EXAMPLE 3
Instrument
ซmC>
Catalytic combustion
Organic vapor
BOCซC>
1,1,2,2-Tetra
Chloroethane
Actual conc.
nrO
5,980 ppm
Meter reading
ซra>
427 ppm
Response factor
nooO
14
RESPONSE FACTORS VARY WITH
ORGANIC VAPOR CONCENTRATION
EXAMPLE 1: RESPONSE FACTORS AT
VARIOUS CONCENTRATIONS
Instrument umo Catalytic combustion
Organic vapor ซ>a=c> Methanol
Actual conc. (ppm) innr-tr^^. Response factors
c:.V5000iii
'.'100003
f."2QOQOifl
c-io
-------
EXAMPLE 2: RESPONSE FACTORS AT
VARIOUS CONCENTRATIONS
Instrument
inmrฃ> Flame ionization
Organic vapor =ฐc> O-Chlorotoluene
Actual conc. (ppm) Response factors
I
^ooฃ3
f:>1500jA3
wioom
EXAMPLE 3: RESPONSE FACTORS AT
VARIOUS CONCENTRATIONS
Instrument iocdc> Catalytic combustion
Organic vapor ฐc> 1,1,2,2-Tetrachloroethane
Actual conc. (ppm) idooC> Response factors
JSii
1453 IfiS
PUBLISHED RESPONSE FACTOR TABLES
PRESENT ESTIMATED VALUES AT A
CONCENTRATION OF 10,000 ppm
C-ll
-------
RESPONSE FACTOR USE:
Response factors used only for selecting
instruments
* Not used for adjusting meter readings
during leak tests
LIMITATIONS OF PUBLISHED
RESPONSE FACTORS:
* Less than 300 organic compounds
have been tested
There are instrument-to-instrument
variations in response
EXAMPLE 4:
INSTRUMENT VARIATIONS
Instrument
mocO
Flame ionization
Organic vapor
imnQ>
Cyclohexanol
Actual conc.
mooC>
Response factors
(ppm)
Unit #1 Unit #2
^200^
EssHg
ฆ :i2oMj
m ฆ
C-12
-------
EXAMPLE 5:
INSTRUMENT VARIATIONS
Instrument ซra>
Organic vapor
Actual conc.
(ppm)
;%29ฐ
ฃ150011
- 3000
. wja
: 45002
Catalytic combustion
Meta-xylene
Response factors
Unit #1 Unit #2
FIELD MONITORING CONCERNS:
(Video -17 minutes)
Poor capture
Gross contamination
Adverse weather
Potential health and safety hazards
CONTAMINATION RELATED
INSTRUMENT PROBLEMS:
Flame ionization detectors
- flame-out
- condensation in flame arrestors/sample lines
Catalytic combustion analyzers
volatilization of catalyst of detector wires
condensation in sample lines
Photoionization analyzers
- condensation on lamp window
C-13
-------
HEALTH AND SAFETY CONSIDERATIONS:
Inhalation hazards
- Keep portable organic analyzer on at all limes to indicate localized areas
where pollutants have accumulated
- Use relatively long probe so user does not have to be exposed to leak plume
Electrical and explosion hazards
- Use only instruments rated intrinsically safe for class 1, division 1 and
class 2, division 1 conditions
- Use only instrument recorders which satisfy the above requirements
- Do not touch rotating shafts with metallic probes or other parts
- Do not use cigarette lighters to check instrument response
Burn hazards
- Avoid hot surfaces adjacent to equipment being screened
Walking and climbing hazards
- Avoid exposed rotating equipment
- Avoid equipment more than 2 meters above secure platforms or surfaces
- Climb ladders properly
COMPARISON OF AVAILABLE
INSTRUMENTS: CRITERIA
Method 21 requirements
Ease of use
Instrument Costs
Other concerns
C-14
-------
MEET METHOD 21 REQUIREMENTS
Response factors
CRITERIA
EASE OF USE
Response time
Configuration
Calibration
Reliability
CRITERIA
INSTRUMENT COSTS
Capital
Operating
C-15
-------
COMPARISON OF AVAILABLE INSTRUMENTS*
Criteria
Analyzer type
Flame
ionization
Photo-
ionization
Catalytic
combustion
Infra-
red
Ease of use
Response time
Fast
Fast
Medium
Slow
Weight (portability)
Heavy
Light
Light
Heavy
Contamination
susceptability
Low
Moderate
Low
Moderate
Configuration
Excellent
Adequate
Adequate
Adequate
Maximum
concentration
capability
Excellent
Adequate
Excellent
Excellent
'A variety of models are available; the comparisons are subjective and
based on experience with a limited number of models.
COMPARISON OF AVAILABLE INSTRUMENTS (cont)*
Criteria
Analyzer type
Flame
ionization
Photo-
ionization
Catalytic
combustion
Infra-
red
Costs
Capital
Moderate
Moderate
Low
Moderate
Operating
Moderate
Moderate
Moderate
Moderate
Other Concerns
Ruggedness
Good
Good
Good
Good
Maximum hold
feature
No
Yes
No
No
Calibration
Good
Good
Good
Good
Capture Capability
Excellent
Adequate
Moderate
Moderate
'A variety of models are available; the comparisons are subjective and
based on experience with a limited number ot models.
C-16
-------
Case Study:
Computerized Emissions
Models
D-l
-------
COMPUTER MODELS
CHEMDAT7 (available)
CHEM7 (available)
LAND7 (available)
Combined model (soon)
Compiled program
Automatic assistance
CHEMDAT7
(Lotus 123 Spreadsheet)
Surface impoundments Land treatment
aerated Active landfills
nonaerated Capped landfills
disposal Waste piles
oil film
Open top tanks
aerated
nonaerated
CHEM7
Compiled program
Automatic assistance
Provides compound properties
for CHEMDAT7
D-2
-------
LAND7
Compiled program
Automatic assistance
Land treatment
Waste piles
COMBINED MODELS
Available soon
One compiled program
Include all major sources
Automatic assistance features
Structure like LAND7
REFERENCE MATERIALS
Emission Model Report
Documentation
Sample Calculations
Background Information
User's Guide
CHEMDAT7
LAND7
Write: USEPA-OAQPS
Petroleum Section - MD-13
Attn: Emission Model Report
RTP.NC 27711
D-3
-------
CASE STUDY: LAND7
LAND7 menu
Important inputs
Example calculations (land treatment)
m immn mmmmwt
Bring up help screens to explain procedures
MAIN MENU - make selection wtih cursor
FILE COMPOUND UNIT PRINT
QUIT
ACTIVE FR.E: aspen\DEFAULT
assistance r>o( enabled
number UggedO
.26:51 memory: 115*06 string spaoe: 15638 binary
| Bring up help screens to explain procedures
HELP MENU iruka wloctton wtth cmw
I GENERAL | FILE COMPOUND UNIT PRINT
UNIFAC DATA
| GENERAL HELP INSTRUCTIONS |b
Press any key (except cursor keys) to end help menu.
Select the desired procedure by using the main menu.
Use the cur*or keys to move the highlighted locator.
Preas [ENTER] (or [RETURN]) or any other key to implement procedure.
Press [Fl] to view HELP screens when usJng the program.
Press [ESC] to return to the procedure you wish to perform.
You can rapkfly scan all menu options by pressing [ENTER) or [down]
ts a menu option and moving across the main menu tMes wfth the
[right] or [teh] cursor control keys.
PRESS [0] TO KUL THE PROGRAM FROM HELP
726:55
memory 10360 string space 14690 Unary
=ฃ1
Figure 1. MAIN menu.
Figure Z HELP menu.
D-4
-------
uu-mLUUiit i-i^cgpcT
PRESS (ESC) TO RETURN TO MENU
-JT
MAIN MENU mako wtectton wtth cursor
if
HELP fFim COMPOUND UNIT PRINT QUIT
SELECT UST
Recover case study
Save current case study
Set the screen specifications
Add another compound to data set
Change the name oI the case stud)
USE 1EKITERI TO SELECT ITEM
PRESS [ESC) FOR NO SELECTION
728:03 mo mo ly - 103044 itrtng ipac* 14S&4 binary
Figure 3. FILE menu.
| Tag and edit selected compounds and properties
(I MAIN MENU -ฆ mako wtoctten wtthcurwr If-
HELP FILE ICOMPOUNCj UNIT PRINT QUIT
COMPOUND OPTION UST
ITAQ COMPOUNDS IN WASTE
eorr a tagged compound
EOfT UN IF AC PARAMETERS
CHECK DATA OF ALL TAGGED COMPOUNDS
CHECK DATA OF A TAGGED COMPOUND
COMPUTER FILLS IN DATA OF ALL TAGGED
COMPARE DATA CALCULATIONS OF ALL TAGGED
SAVE TAGGED DATA IN MASTER FILE
USE (ENTER) TO SELECT ITEM
PRESS (ESC) FOR NO SELECTION
729:07 memory - 103182 itrtng ipac* 15032 Unary
Figure 4. COMPOUND menu.
Specify conditions of land treatment facility
i Yซ
MAIN MENU - makป Mfedton wtth curtor ||
HELP FtLE COMPOUND |UNIT| PRINT QUIT
UNIT OPTIONS
1 SPECIFY LAND TREATMENT CONDITIONS |
Sp#dfy compound cooo*nualionซ
ESTIMATE LAND TREATMENT RATES
USE (ENTER] TO SELECT ITEM
PRESS (ESC] FOR NO SELECTION
729:42
memory - 103162 tiring tpac* - 15002 binary
s.&tM
Print the results ol the calculations
MAIN MENU rruk# Miction wflh curwr fP
J
HELP RLE COMPOUND UNIT fPRiNTl QUIT
PRINT LIST
Print report ol case study
Select printer type
USE |ENTER] TO SELECT ITEM
PRESS (ESCI FOR NO SELECTION
memory - 103192 string space ฆ 15032 binary Jf
Figure 5. UNfT menu.
Figure 6. PRINT menu.
D-5
-------
Quit the program and return to DOS
HELP
MAIN MENU - make selection wkh curtor 11
FILE COMPOUND UNIT PRINT lOUITl
CAUTION
IF YOU CONTINUE YOU WILL EXIT THE PROGRAM
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30:19 memory- 103212 stringspace - 15052 binary JC
Figure 7. QUIT menu.
INPUTS: POROUS MODEL
Time surface is exposed
Concentrations
Area and depth
Oil content
Temperature
Air and total porosity
D-6
-------
EXAMPLE OF LAND7 INPUTS
SPECIFIED PARAMETERS FOR LAND TREATMENT
wind (cm/s)
447
Temp (C)
25
011 content of waste (fraction!
.1
concentration of compound (ppm)
0
Time between applications (days)
30
Waste loading (g o1l/cc soil)
.034
Thickness of contaminated soil (cm)
20
Area of land treatment (m2)
24964
Aqueous waste, >1
0
Blomass density
.00179
Total porosity
.61
A1r porosity
.5
width of land treatment area (meters)
158
length of land treatment area (meters)
158
amount of waste applied (gallons)
450000
fraction liquid 1n waste
.1
BENZENE 5 ppmw
STATUS CHECK
Area of land treatment (m2) 1s relatively large.
D-7
-------
EXAMPLE OF LAND7 RESULTS
SOURCE: land treatment
COMPOUND: BENZENE
Equilibrium Keq
biological time const days-1
maximum fraction blodegraded
fraction blodegraded during time period
fraction emitted during time period
residual concentration In oil (ppmw)
diffusion coef cm2/s
emission rate during time period (g/s)
(Mg/year)
emission factor (g/cm2-s)
2.123418E-02
29.42251
.0930385
9.282061E-02
.9064917
3.43848E-03
2.351761E-02
2.968397E-04
9.361136E-03
1.189071E-12
Short term emissions, first day (g/s)
Peak emissions, fifteen minutes (g/s)
3.599377E-03
1.766045E-02
The reference emission factor 1s 1.252787E-12
g/cm2-sec.
COMPOUND PROPERTIES OF BENZENE
Type of compound A aromatic
density (g/cc)
molecular weight
diffusion coef. air (cm2/s)
vapor pressure (mm Hg)
Henry's law constant (atm m3/mol)
vapor pressure temp, coefficients
blorate constant Kmax (mg/g-l-hr)
UNIFAC code
.87
78.1
.088
95.2
.0055
6.905
1211.033
220.79
19
16:00000000000
STATUS CHECK
The estimated vapor diffusion coefficient 1s .1173281 cm2/s
The estimated vapor pressure 1s 95.02693 mm Hg.
D-8
-------
CASE STUDY: CHEMDAT7
CHEMDAT7 menu
Important inputs
Example calculations
- Activated sludge
- Impoundment (as time permits)
- Landfill (as time permits)
CHEMDAT7 MAIN MENU
DATA-FORMS VIEW SORT PRINT SELECT HELP QUIT
Go to data entry forms.
DATA-FORMS VIEW SORT PRINT SELECT HELP QUIT
Go to a portion ot worksheet (Results).
DATA-FORMS VIEW SORT PRINT SELECT HELP QUIT
Select compounds or rearrange order.
DATA-FORMS VIEW SORT PRINT SELECT HELP QUIT
Print a portion ol worksheet.
DATA-FORMS VIEW SORT PRINT SELECT HELP QUIT
Select which models to use.
DATA-FORMS VIEW SORT PRINT SELECT HELP QUIT
Look at instructional screen.
CHEMDAT7HELP MENU
GENERAL MODEL DATA LANDTREAT LANDFILL BIO-RATE IMPOUND QUIT
View general help screen information.
GENERAL MODEL DATA LANDTREAT LANDFILL BIO-RATE IMPOUND QUIT
Help in selecting (he data for your unit.
GENERAL MODEL DATA LANDTREAT LANDFILL BIO-RATE IMPOUND QUIT
Discussion ol data entry for new compounds or properties.
GENERAL MODEL DATA LANDTREAT LANDFILL BIO-RATE IMPOUND QUIT
Information for the use of the land treatment model.
GENERAL MODEL DATA LANDTREAT LANDFILL BIO-RATE IMPOUND QUIT
Information for the use of the landfill model.
GENERAL MODEL DATA LANDTREAT LANDFILL BIO-RATE IMPOUND QUIT
Information for the use of biological reaction rates.
GENERAL MODEL DATA LANDTREAT LANDFILL BIO RATE IMPOUND QUIT
Information for the use of the impoundment model.
D-9
-------
DATA FORMS
IMPOUND AERATED CLOSED-LF OPEN-LF/WP LAND-TREAT
CONC IMPORT DEFAULT
IMPOUND: Use for impoundments and open tanks that
are not mechanically agitated or aerated.
AERATED: Use for agitated tanks and impoundments.
CLOSED-LF: Closed or capped landfills.
OPEN-LF/WP: Open, active landfills and waste piles.
LAND-TREAT: Land treatment.
CONC: Use differing concentrations for compounds.
IMPORT: Import compound data.
DEFAULT: Put in default parameters.
INPUTS:
OPEN LIQUID SURFACES
Quantity or flow rate
Concentrations
Area and depth
Aeration rate
Agitation parameters
Windspeed
D-10
-------
CHEMDAT7 RESULTS FOR QUIESCENT IMPOUNDMENT
(all concentrations at 10 ppm)
NON-AERATED WASTEWATER TREATMENT
WINDSPEEO
4.47
n/s
depth
1.8
0
AREA
1500
02
FLOW
0.00156
m3/s
VO Inlet conc.
10
mg/1
TOTAL ORGAN ICS IN
250
mg/1
ACTIVE BIOMASS
0
0/1
BIOMASS SOLIDS IN
0
0/1
TEMPERATURE
25
deg. C
AL AIR EMISSIONS
2.61
Mg/yr
EFFLUENT
EMISS.
BIOL.
PHOTOL.ADSORB.
, air
COMPOUND NAME
& HYDRO.
eralss.
(Mg/yr)
bฃN2ฃllฃ
0.199
0.801
0.000
0.000
0.000
0.3943
CARBON TETRACHLORIDE
0.210
0.790
0.000
0.000
0.000
0.3887
HETHANOL
0.523
0.477
0.000
0.000
0.000
0.2345
METHYL ETHYL KETONE
0.251
0.749
0.000
0.000
0.000
0.3688
METHYLENE CHLORIDE
0.181
0.819
0.000
0.000
0.000
0.4031
PHENOL
0.895
0.105
0.000
0.000
0.000
0.0518
TETRACHLOROETHLYENE
0.218
0.782
0.000
0.000
0.000
0.3847
TOLUENE
0.213
0.787
0.000
0.000
0.000
0.3873
D-ll
-------
CHEMDAT7 RESULTS FOR AERATED IMPOUNDMENT
(all concentrations at 10 ppm)
AERATED WASTEWATER TREATMENT
WINDSPEED
4.47
m/s
DEPTH
1.8
D
AREA
1500
m2
FLOW
0.031
m3/s
ACTIVE BIOMASS
0.3
0/1
BIOMASS SOLIDS IN
0
0/1
VO INLET CONC.
10
mg/1
TOTAL ORGAN ICS IN
250
mg/1
TOTAL BIORATE
19
tng/g b1o-hr
FRACT. AGITATED
0.247
SUBMERGED AIR FLOW
0
m3/s
Number Impellers
1
Oxygen trans, rat.
3
1b02/h-hp
POWR (total)
75
HP
Power efficiency
0.85
Temperature
25
deg C
Impeller d1a
61
cm
Impeller speed
126
rad/s
RELATIVE AERATED WASTEWATER VOC PAT
EFFLUENT EMISS. BIOL. PHOTOL.ADSORB, air .
COMPOUND NAME
& HYDRO.
em1ss.
(Mg/yr)
BENZENE
0.016
A.621
0.163
0.000 0.0002
8.0283
CARBON TETRACHLORIDE
0.015
0.842
0.143
0.000 0.0003
8.2340
METHANOL
0.381
0.085
0.531
0.000 0.0026
0.B299
METHYL ETHYL KETONE
0.224
0.508
0.266
0.000 0.0016
4.9678
METHYLENE CHLORIDE
0.019
0.926
0.055
0.000 0.0002
9.0565
PHENOL
0.011
0.000
0.989
0.000 0.0001
0.0028
TETRACHLOROETHLYENE
0.017
0.902
0.081
0.000 0.0003
B.8196
TOLUENE
0.015
0.729
0.256
0.000 0.0003
7.1275
D-12
-------
CASE STUDY
PROCESS VENT RULE
APPLICABILITY
and
COMPLIANCE
Presented at
U.S. Environmental Protection Agency
Workshop on
Air Emissions from Waste Management Facilities
E-l
-------
PROCESS VENT CASE STUDY
Review of RCRA Air Emission Standard for Process Vents
Hazardous Waste TSDF Operations
Situation
The XYZ Manufacturing Company operates various manufacturing processes that
generate approximately 1,000 tons of hazardous waste per year. This qualifies the XYZ
Manufacturing Company as a large quantity generator under RCRA . The facility is a
RCRA TSDF operating under interim status. As the owner/operator of the facility, you are
required to:
1) determine the applicability of the RCRA air rules for process vents (i.e.,
40 CFR 265, Subpart AA) to the hazardous waste management unit emission
sources at the facility,
2) determine compliance status of current process vent emissions and emission
controls in relation to the control requirements in 40 CFR 265, Subpart AA,
3) determine what action can be taken to comply with the regulation, H the
emission reductions are required under the process vents standards.
E-2
-------
Determinations
Determine which process vents are subject to the
requirements of Subpart AA and why. For each
process vent identified In Figure 1 and 2, circle all
of the following statements that are correct (note:
some vents will have more than one applicable
statement; all relevant and appropriate choices
should be drcled)
a.
b.
c.
d.
Vent is a process vent associated with one of
the unit operations specified In the rule that
manages a hazardous waste with organic
concentration of greater than 10 ppmw and
therefore is subject to the requirements of
Subpart AA.
Vent is not a process vent as defined In the rule
and therefore is not subject to the requirements
of Subpart AA.
The operation/process associated with the vent
is nol one of the unit operations specified in
Subpart AA applicability (Section 265.1030(b)),
or
The passage of gases (i.e., vent emissions) into
the atmosphere is not process related. For
example, emissions are caused by tank loading
and unloading (wording losses) rather than the
process or unit operation.
Vent is not subject to the requirements of
Subpart AA because the waste managed In the
unit has an organic concentration concentration
of less than 10 ppmw.
Vent is not subject to the requirements of
Subpart AA because the operation/process unit
associated with the vent is not subject to RCRA
Subtitle C or is exempt from RCRA permitting.
Vent
Vent
No.
Answers
No.
Answers
1
a,b,c^>
10
a$,c,d
2
a,6,c -1
11
a.frc.d
3
a.ง.cj
12
a.Q.c.d
4'
e.b.c.d
13
a,$,c,d
5
a,$,c,d
14
6.c,d
Comments
a. The process vent rules apply only to (hose
waste management units or unit operations
that are specified in the rules. Affected unit
operations Include: distillation, fractionation,
thin-film evaporation, solvent extraction,
steam stripping and air stripping.
Vents on control devices (e.g., condensers
and carbon adsorbers) and on tanks serving
the affected unit operations (e.g., distillate
receivers, bottoms receivers, surge control
tanks, decant separator tanks, or hot wells)
are also subject to the standards if emission
from the process are vented through them
(e.g., uncondensed overhead vapors from a
distillation operation).
b. A process vent means any open-ended pipe
or stack that is vented to the atmosphere
either directly, through a vacuum-producing
system, or through a tank or air pollution
control device. Emissions (i.e., gases or
fumes) must be process-related such as
evaporation produced by heating or caused by
mechanical means such as a vacuum-
producing system.
c. The process vent rules apply to affected units
managing hazardous waste with a total
organic concentration of 10ppmw or greater
on an annual average basis. Units managing
wastes with an annual average of less than
10ppmw are not subject to the rules.
d. If the unit is exempt from RCRA Subtitle C, it
is not subject to the requirements of Subpart
AA. Examples of types of RCRA exempt
units are listed below:
Units such as product (not hazardous waste)
distillation columns generating organic
hazardous waste still bottoms are not subject
to the standards while the wastes are in the
product distillation column unit.
Elementary neutralization and wastewater
treatment tanks as defined by 40 CFR 260.10.
Units managing Subtitle D wastes or
nonhazardous wastes.
Generators that accumulate hazardous waste
in tanks and containers for 90 days or less.
E-3
-------
2. Calculate the total (acflity process vent emission Total Facility ER Is equal to the sum
rate (ER). emission rates for all Individual process
vents located at the facility that are subject
Case 1: to the requirements ot Subpart AA.
ER(Hour1y)~
^R(Annual)m ^^tftcBKy ~^pvt
Case 2:
ER(Homty)"
ER(AnnuiI)"
Process Vent Emission Rate (ER) and ODeratlna Hour(OH) Data:
Casซ 1:
Vซnt W.f
1
2
3
4
5
8
7
8
0
10
11
12
13
14
15
16
17
ERflfcrtw)
OJ
6.1
007
0.40
o.te
1.0
0.20
0.12
12
0.13
0.06
6.1
8.9
12
0.13
OA*
1J5
OHfhijyr)
4160
4160
8760
2000
8760
2000
8760
2000
2000
0760
2000
4160
2000
2000
2000
4160
2000
Efifloryyr}
10.3
12.7
0J1
0.49
0.7
1.0
0.08
0.12
12
0.57
0.06
12.7
e.s
1-2
0.13
1.7
1.3
Casfl 2:
Vซnt H J
1
2
3
4
8
8
7
8
0
10
11
12
13
14
15
16
17
0.1
5.2
an
1.0
0.18
OA
0.08
0.11
1.0
0.15
005
4.5
0.0
1.1
0.15
1.7
22
OH(hrfyr)
4180
4160
0760
4000
8760
4000
8760
2000
2000
8760
2000
4160
2000
2000
2000
4180
2000
16.8
10.8
048
2.0
0.78
1JS
0.35
0.11
1.0
0.66
0.09
0.3
0.0
1.1
0.15
3 3
22
E-4
-------
3. Based on ttie total ladllty process vent emission
After identifying all affected process
rate (ER) calculated above. Identify which course
vents, you must determine whether the total
of action Irom among those listed below, Is
facility affected process vent emission rate
required:
Is below the emission rate limits (see
operating data under #2 and compliance
a. ER below emission rate limits; therefore, no
criteria given below.)
emission reduction required.
If the total facility process vent emission
b. ER above emission rate limits; must reduce
rate for hourly or yearly emissions exceeds
omissions from each Individual process
the limits In the regulation, then some type
vent by 95%,
action must be taken to reduce emissions
below the limits, if the emission rats limits
c. ER above emtsslon rate limits; must reduce
cannot be attained, total facility process vent
total facility process vent emissions by 95%.
emissions must be reduced, by 95% or
more, through use of a control device.
d. ER above emtsslon rate limits; but can control
one or more vents to get below limits.
e. ER above emission rate limits; but can reduce
operating hours In order to get below the
limits.
Compliance Criteria
TotaJ facility process vent emission rate must be below the following emission rate limits:
Short Term - < 1.4 Kg/ft (3 Ib/ti) AND Long Term - < 2.8 Mgfyr (3.1 short tons/yr)
Recommended
Control Action
Case 1:
Case 2:
E-5
-------
Figure 1. Case Study Facility XYZ
mi
To Manufacturing
Operations
Manufacturing
Operations
Dtellllajton
Column
Generating
DJstlalate
Solve rt tn
Receiver
Sotvan
DBUQaton
Rafltnaie
Column
Sotvenl
DtetlltaJd
vacuum Pump
Receiver
a Hazardous
Was] a
Waste
r
Decanter
Storage
Tank
Carbon
Adsorber
Boiler
Clanfer
Plate and Frame
Finer Prese
Distillate
Reeehfer
Hazardous
Waste
Storage
Tank
Ptant
Waste
To Land Disposal
(Less Than 90
Day Accumulaiton)
Fitter CaVe
Decanter
(aqueous waste
< 8ppmw)
Steam
Stripper
To Land Disposal
Y V YV
To Wm
To WWT
(See Figure 2)
(See Figure 2)
vent Id No
Condenser
To Manufacturing
Operations
Note: Organic concentration of all streams (unless otherwise noted): 1.000 - 900.000 ppmw
Organic concentration of wastewater treatment (WWT) plant streams: <9 ppmw
-------
Primary
Clartfler
Hazardous Wastewater
(From Figure 1)
to WWT
Storage
Tank
Neutralization
M
Air
Strip pei
Air
Sludge
Holding
Tank
Plate and Frame
Filter Press yv
Secondary
i ClarBer ,
Aeration
To
NPDES
Discharge
To Land Disposal
Key
HI Vent Id No. Note: Organic concentration of wastewater treatment (WWT) plant streams: < 9 ppmw
ft Vent
Figure 2. Case Study Facility XYZ Wastewater Treatment Plant (WWT)
with NPDES Permit
-------
CASE STUDY
APPLICATION
Of
BENZENE WASTE OPERATIONS NESHAP
to
WASTEWATER TREATMENT SYSTEMS
Presentation Slides
F-l
-------
GENERAL STANDARDS
Facilities with 10 Mg/yr or more total annual benzene in waste
treat and control certain waste streams
Treat identified waste streams to remove or destroy benzene
Apply organic emission controls prior to and during treatment
to achieve treatment requirements
WHAT ARE THE TREATMENT REQUIREMENTS?
Reduce benzene concentration to less than 10 ppmw
Remove or destroy benzene by 99% or more
Dilution of wastes to meet requirements is prohibited
Mixing of wastes is allowed to facilitate treatment in
"wastewater treatment system " with special requirements
WHAT IS A "WASTEWATER TREATMENT SYSTEM"?
... a unit that ultimately discharges under NPDES permit
Manages certain wastes:,
-* Process wastewater
-> Product tank drawdown
-> Landfill leachate
-> Wastes mixed with any of these
Typically includes:
-ป Individual drain systems
-> Oil-water separators
-ป Dissolved air floatation (DAF) units
> Equalization tanks
-> Biological treatment units
F-2
-------
Got
Ptonl
DW.
Col.
004
FCCU
Product
lorik
. 005 .
(Coker!
to Dbchorge
Plant lay-out of ABC Ofl Refinery.
WHAT ARE THE SPECIAL REQUIREMENTS?
All units comprising the wastewater treatment system must use
organic emission controls except for those units where both the:
(1) Benzene concentration of wastewater entering unit is
less than 10 ppmw benzene
and
(2) Total annual benzene quantity in wastewaters first entering
all uncontrolled wastewater treatment system units facility-wide
is less than 1 Mg/yr
Benzene in wastewaters entering an "enhanced biodegration unit"
is excluded from the calculation of total annual benzene quantity
Product
Tankage
Drainage System
[Process 1ป
Units P+
Leachate
Ground-
water .
Oil/Water
Separator
24
DAF
20 ppa*
Unit
11 MiAr
Rainwater/Runoff L
Drainage System: |
0 004 Vj/jr. 0.02 ppmw |
Equalization
Basin
4J ppaซ
0 003 Uc/tt.
/jr.
2 ppm*
0.01 pea*
/ Storm \
Surface
Impoundment
A Basin )
o.e ui/jt
0.4 ppra
Polishing
Pond
Discharge
o.ou ux/r
Figure I. Wastewater treatment system showing benzene concentrations
and flow rales: Example \.
F-3
-------
WHAT IS AN "ENHANCED BIODEGRADA TION UNIT"?
Wastewater treatment system unit that:
-> Uses a suspended growth process
-ป Generates biomass
-> Uses recycled biomass
-ป Periodically removes biomass
Examples of processes not considered enhanced
-> Large, shallow biological impoundments
-> Attached growth processes such as trickling filters
or rotating biological contactors
Drainage System
Product
Tankage
Process
Units
8 ppm*
4.6 ppm*
20 ppm*
Leachate
Cround-
water ,
Storm
Basin
Rainwater/Runoff
Drainage System:
! 0.004 Ui/jr, 0.02 ppm*
Clarifier)
Mix
Box
DAF
Unit
Activated
Sludge
Tank
Oil/Water
Separator
Equalization
Basin
Discharge
0.014 Kf/yr
Figure 2. Wastewater treatment system showing benzene concentrations
and (low rates: Example 2.
Product
Tankage
Drainage System
Process
Units
Leachate'
Ground-
water ,
16 Ui/jrr.
10 ppm*
> Oil/Water
e Ui/jr,
5 ppm*
DAF
0 ซ UjfT-.
0.5 ppm*
Separator
Unit
Basin fl
0.6 Vi/jr:
0.6 ppmv
0.5 Mf/jr
0.9 ppm*
Equalization
Basin #2
0.5 Mj/jrr;
0.1 ppm*
Activated
Sludge
Tank
Discharge
Return audjt
0.07 Ht/jrr: /* 0.OM M(/jrr;
0,02 ppmป ( \ 0.003 ppm*
MClarilier)-
0.000 Vi/fr, 0.01 ppm*
Wastewater treatment system showing benzene concentrations and
mass flow rates. Example 3.
F-4
-------
CASE STUDY
APPLICATION
of
BENZENE WASTE OPERATIONS NESHAP
to
WASTEWATER TREATMENT SYSTEMS
Presented at
U.S. Environmental Protection Agency
Workshop on
Air Emissions from Waste Management Facilities
-------
CASE STUDY:
APPLICATION OF NATIONAL EMISSION STANDARD FOR BENZENE WASTE OPERATIONS
TO WASTEWATER TREATMENT SYSTEMS
OVERVIEW
This case study provides examples of the application of the National Emission Standard for
Benzene Waste Operations (40 CFR 61 Subpart FF) to wastewater treatment systems. The standards
for wastewater treatment systems that manage and treat aggregated or mixed waste streams are
reviewed using some simple examples. Then, a case study problem Is presented to Illustrate the
application of the standard to a 'real world' wastewater treatment system at a petroleum refinery.
STANDARDS FOR WASTEWATER TREATMENT SYSTEMS
The Benzene Waste Operations NESHAP requires owners and operators of affected facilities at
which the total annual benzene quantity from the facility waste Is equal to or greater than 10 Mg/yr to
remove or destroy benzene contained In certain waste streams using a treatment process or wastewater
treatment system. Section 61.348 of the rule establishes the treatment standards for treatment
processes or wastewater treatment systems. These standards require that If an owner or operator
chooses to aggregate or mix waste streams to facilitate treatment In a wastewater treatment system, then
the waste streams must be treated In a wastewater treatment system thai meets special requirements.
Each waste management unit that comprises the wastewater treatment systems at the facility must use
the appropriate emission controls as specified under Sections 61.343 through 61.347 urttf both of the
following conditions are met
1. The waste entering an uncontrolled unit Is less 10 ppmw benzene;
and
2. The total facility-wide wastewater treatment system annual benzene quantity first entering any
uncontrolled unit Is less than 1 Mg/yr.
Application of Basic Standards
Figure 1 Illustrates the application of the basic standards. The drainage system, the oil/water
separator and the dissolved air flotation (DAF) unit shown in Figure 1 require controls because they
receive waste with benzene concentrations of 10 ppmw or higher. The next three units require controls
because, even though the benzene concentration Is below 10 ppmw, the mass flow rate of benzene
(i.e., the annual benzene quantity) entering the units Is greater than 1 Mg/yr.
Enhanced Blodeoradation Units
There Is one major exclusion to the 1 Mg/yr benzene quantity limit. The rule excludes the benzene
quantity entering an "enhanced biodegradation' unit from the total annual benzene quantity Inventory for
1he wastewater treatment system If the enhanced biod ฉgradation unit is the first exempt unit.
Section 61.348(b)(2)(ll)(B) provides guidelines regarding operating conditions for what is defined as
"enhanced Wodegradatlon" unit. These guidelines basically describe the operation of a conventional
activated sludge wastewater treatment process. Activated sludge systems with benzene concentrations
of 10 ppmw or higher In any Influent stream will still require controls, but H the benzene concentration is
less than 10 ppmw, the annual benzene quantity entering an activated sludge system does not count
towards the 1 Mg/yr control limit. Therefore, If we replace the surface Impoundment In Figure 1 with an
activated sludge system (refer to Figure 2), no controls are then required after the equalization basin.
F-6
-------
Drainage System
Product
Tankage
Process
Units
40 ppow
Storm
Basin
j Rouiwaici / nuuun
[Drainage System:
| 0.004 Ht/yr; 0.02ppm*
0.001 Ui/yr!
legend:
IndkftUi unit aol requiring eonl/eU
undtr 40 CFR 61 Subpart 77
lodicatw unit requirini controls becausa
beniene conctnlralioa excieds 10 ppm
Polishing
Pond
Discharge
DAF
Unit
Leachate
Ground-
water ,
rrm _ lndkปlซ unit r*qulrin| coclrelt bซcauiซ 0.014
nut nซซ rtl* of bcaseiM ticซซdj 1 Ui/fr
Figure 1. Wastewater treatment system showing benzene concentrations
and flow rates: Example 1.
Drainage System
Product
Tankage
Process
Units
Leachate
Ground-
water
49 Ut/jr.
0 ppm*.
OiyWater
Separator
24 U|/yr;
DAF
.Unit
7.2 Wi/yr;
20 ppm*
0 ppmซ
Rainwater/Runoff
Drainage System:
. 0.004 k|/jrr; 0.02 ppm*
l^gfnri;
I I . IndicaUi unit Dot requlri&i conUqb
11 un
-------
Drainage System
Product
Tankage
Units
Leachate
Ground
water
15 Ut/fT.
10 ppm*
Oil/Water
Separator
0 Uc/yr
5 ppm*
I)AF
Unil
0 J Ui/rr.
0.5 ppm*
VO.e Ui/jt;
1.0,6 ppm*
Equalization
Basin 82
Equalization
Basin ง\
0 5 Vi/yr.
0.3 ppm*
0.5 Ui/yr:
0.5 ppm*
Activated
Sludge
Tank
0.0T Uj/yr;
0.02 ppm*
Return SIud|(
Clarilier
o.ooa Ui/rr.
0.003 ppm*
Discharge
0.006 Ug/yr; 0.01 ppm*
Figure 3. Wastewater treatment system showing benzene concentrations and
mass flow rates. Example 3.
Product
Tankage
*5ฉ
M
Process
Units
rtasrat; X'fS-
llll
8 U^/yr
5 ppm*
1
j 0.8 Ut/yr. i
1 0.6 ppm* fi
iii
1 1
Ground-
water
h jO.fl Uf/yr;
|0,fl ppm*
Equalization
Basin fZ
ฃ
0.5 Ut/yn
0.3 ppm*
0.5 Ui/yr:
0.5 ppm*
Activated
Sludge
Tank
1 0.07 Ut/yr; \ 0.000 Ht/yr:
0.02 ppm* / 0.003 ppra*
MClaruicr
Legend:
Return Sludft:
0.006 Uf/yr; 0.01 ppm*
Discharge
| | lndicttซi uttit Dol re^uiri&i eo&trelf ucdtr 40 CFR 61 Subpart fT
f**"! ฆ Indicilei unit nquirlo| eantrob became faeuene coacentralioa esceedi 10 ppm
PTil tadicilei unit requirim coot/ob bccauie bemene mau flo* rate exceed* IMt/fr
|' | ฆ Indicates unit requiiin| coot/ol* because facility-vide uDcaotrollcd betueoe quuUty eicccdi lU^/yr
Figure 3a. Wastewater treatment system showing benzene concentrations and
mass (low rates. Example 3; Solution A.
Drainage System
Product
Tankage
Process
Units
Leachate
Ground-
water
i-r'W
:iil9 ppป*j;U
-(X&izsjflfr
0U$rซl%
-.Separator
ซ W|/fT.
Ill
08 Ut/yr
0.5 ppm*
* -*: j
Equalization
Basin ง\
ป. uซ/r;
|J||i -iO.O ppm*
0-5 U|/jt;
0.3 ppm*
Equaur
([{Basin
tlllllllllHIli
ipii
ation
il
0.5 Ut/jr.
O S ppm*
Activated
Sludge
Taidc
0.006 U(/rr:
0.003 ppm
0.07 Ui/yr.
O.02
Clar uier
Discharge
Return Sludge;
0.008 U
-------
CASE STUDY
SITUATION
The ABC Oil Company operates a refinery that is determined to have a total annual benzene (TAB)
quantity greater than 10 Mg/yr and, therefore, the refinery owner/operator is required to manage the
benzene-containing waste streams in controlled units and treat the waste to comply with the National
Emission Standard tor Benzene Waste Operations (40 CFR 61 Subpart FF). As shown Figure 4, the
refinery already operates an advanced wastewater treatment system capable of treating the refinery
wastewater streams to meet the Section 61.348 treatment standards. As owner/operator of the ABC Oil
Company you must now decide which of the units comprising your wastewater treatment system must
use controls to comply with the standards.
PROBLEM
Identify which waste management units comprising the refinery wastewater treatment system require
controls. Possible answers (or each waste management unit are:
a. No controls required
b. Controls required: Benzene concentration entering the unit is 10 ppmw or more
c. Controls required: TAB quantity entering the unit is 1 Mg/yr or more
d. Controls required: Total TAB quantity managed in exempt wastewater treatment
units at refinery Is 1 Mg/yr or more
For each waste management unit shown in Figure 5, circle all correct answers (more than one
answer may be correct (or a particular unit).
1.
Individual Drain Systems
a
b
c
d
2.
Sour Water Stripper
a
b
c
d
3.
Oil/Water Separator
a
b
c
d
4.
DAF Unit
a
b
c
d
5.
Primary Clarifier
a
b
c
d
6.
Equalization Basin
a
b
c
d
7.
Activated Sludge Tank
a
b
c
d
8.
Secondary Clarifier
a
b
c
d
9.
Trickling Filter
a
b
c
d
10.
Clarifier
a
b
c
d
11.
Polishing Pond
a
b
c
d
F-9
-------
Crude Oil
Product
Tank
v 002 ,
Product
Tank
. 001 v
Hydro
.Treaty
Reformer)
Dist.
Col.
Product
Tank
v 003 ,
Product
Tank
v 004 /
f-tydro
Jreat^
/de-v
vSaft,
FCCU
*r* Lube
ฆ/V. Oil
;ooiii
Producl
Tank
v 006 .
Product
Tank
v 005 >
[Coker]
Fower
'Slop-Oil
V. Tank J
DAF Unit
Sour-
Water
Strippej
Trickling
Fitter
f-v (Clarifierr
Settling]
v Tank k'P' <
Oewatering
Unit
.t
* JT
Activated
Sludge Tank
Polishing
Pond
Equalization
Basin
Primary
Clarifier
Aerobic
Digest or
Wastewater
Process Fluids
Sludge
Figure 4. Plant lay-out of ABC Oil Refinery.
1. individual Drain Systems
* Ug/yr
8 ppm*
Product
Tankag
300 Ug/yr
100 ppm*
Process
Units
Leachate
6 Ug/yr
8 ppm
Water
Stripper
0.5 Ug/yr
1 ppm*
Recovered
0U
Equalization
Basin
7
5 Mj/yr
ActivaLed
1.6 ppmw
Sludge
Tank
6.2 Ug/yr
2 ppraw
i ug/y
0.3 ppm*
3
Oil/Water
Separator
22 Ug/yr
10 ppmw
4
DAF
Unit
6 Ug/yr
3 ppmw
Recycled
Sludge
8
econdar
Clarifier
Primary
Clarifier
Sludge
Trickling
Filter
I lo solids
0.3 Mg/yr
1 handling j
0.1 ppm
1.5 Ue/yr
0.75 Ug/yr
n
Polishing
Pond
2 ppmw
I ppm*
Clarifier
0 75 Ug/yr
0.2 ppm*
Discharge
Figure 5. Wastewater treatment- system showing benzene concentrations and
mass flow rates: Case Study.
F-10
-------
SEPA
BENZENE WASTE
OPERATIONS NESHAP
G-l
-------
Purpose
To summarize the major requirements of the
NESHAP for benzene waste operations
Outline
Overview
Applicability
Control requirements
Compliance
Summary
Outline
Overview
Applicability
Control requirements
Compliance
Summary
G-2
-------
Overview
Background
Benzene waste rule one of last under "old
Section 112"
Rules promulgated March 7, 1990
(45 FR 8292)
Impacts of standards
- Reduce benzene emissions from 6,000
to 450 Mg/yr
- Reduce maximum risk from 2 x 10"3 to
5 x 10"5
- Reduce annual cancer incidence from
0.6 to 0.05
Overview
Regulatory Approach
Identify facilities whose benzene
emissions pose public health problem
Identify waste streams that create
benzene emission problem
Treat identified waste streams to remove
or destroy benzene
Apply organic emission controls prior to
and during treatment
G-3
-------
Outline
Overview
Applicability
Control requirements
Compliance
Summary
Applicability
Which Facilities Require Control?
Specific industrial categories
- Chemical manufacturing plants
Petroleum refineries
- Coke by-product recovery plants
- Offsite TSDF that receive wastes
from the above facilities
Facilities with >10 Mg/yr total annual
benzene in waste (TAB)
Only wastes with >10% water included in
TAB determination
Applicability
What Is a Waste?
Waste defined very broadly
(CAA 40 CFR Part 60, Subpart Kb)
Excluded Wastes
- Wastes in the form of gases
and vapors
- Segregated stormwater streams
- Certain in-process recycle streams
G-4
-------
Applicability
How Is TAB Determined?
Determine waste flow and benzene
concentration at "point of generation"
- Knowledge of waste or process
- Direct measurement
Based on the following for each waste
ฃ10% water:
- Total annual quantity of waste
- Annual average benzene
concentration
Applicability
Total Annual Benzene in Waste (TAB)
TAB = ฃ (Q. C.)
i=1
Q = annual waste quantity
C = annual average benzene concentration
n = number of affected waste streams with
>10% water content
Applicability
What Is Point of Generation?
Where substance first becomes a waste
- Prior to losses due to emissions
- Prior to mixing
- Prior to any waste treatment
Can occur after a process unit or waste
management unit
Definition does not allow wastes to be
excluded from rule
Pollution prevention that eliminates waste
or reduces benzene allowed
G-5
-------
Applicability
Which Waste Streams Require
Control?
Generally, streams with >10 ppmw
benzene at point of generation
Exclusions for certain process
wastewater streams
Applicability
What Is Process Wastewater?
Water that contacts benzene within manufacturing
process unit
Certain waste streams are not process
wastewater
- Organic wastes
- .Cooling tower
blowdown
- Process fluids
- Steam trap
condensate
- Product tank drawdown
- Landfill leachate
Applicability
What are the Process Wastewater
Exclusions?
Waste streams less than 0.02 Lymin or
10 Mg/yr
Waste streams >10 ppmw benzene if
process wastewater TAB less than
1 Mg/yr for combination of:
- TAB in untreated streams at point of
generation
- TAB in treated streams at exit to
treatment unit
G-6
-------
Outline
Overview
Applicability
Control requirements
Compliance
Summary
Control Requirements
Overview
Affected wastes treated to remove or
destroy benzene
Control air emissions from management
units prior to and during treatment
Mixing of wastes to facilitate treatment
allowed
Dilution of waste to comply with treatment
standards prohibited
Treatment can occur onsite or offsite
Control Requirements
What Are the Treatment
Requirements?
Reduce benzene concentration to
<10 ppmw
Remove or destroy benzene by 99% or
more
Special requirements for certain wastewater
treatment systems (WWTS)
G-7
-------
Control Requirements
What Are the Treatment
Requirements?
(continued)
Compliance with treatment requirements of
other statutes:
- RCRA waste combustion rules
- RCRA land disposal restrictions
- Benzene-specific effluent guidelines
Control Requirements
What Are the Treatment Processes?
Steam stripper
Thin-film evaporator
Waste incinerator
Other processes that meet performance
standards
Wastewater treatment systems (WWTS)
Control Requirements
What Is a Wastewater Treatment
System?
... a unit that ultimately discharges under NPDES
permit
Manages certain wastes:
- Process wastewater
Landfill leachate
- Product tank
drawdown
Wastes mixed with
any of these
Typically includes:
- Individual drain
systems
Equalization tanks
Oil-water separators
Biological treatment
units
- Air flotation units
G-8
-------
Control Requirements
What are the Alternative
Standards for WWTS?
If wastes with 210 ppmw benzene mixed with
wastes <10 ppmw benzene in WWTS, special
provisions apply
All units in WWTS must be controlled until
both:
- The wastes entering an uncontrolled unit
are <10 ppmw
- The WWTS TAB first entering an
uncontrolled unit is <1 Mg/yr
TAB entering enhanced biodegradation is
excluded from the 1-Mg/yr determination
Treatment
How Is an Enhanced Biodegradation
Unit Defined?
A WWTS process unit that:
- Uses a suspended growth process
Generates biomass
- Uses recycled biomass
- Periodically removes biomass
Examples of processes not considered
enhanced
- Large, shallow biological impoundments
- Attached growth processes such as
trickling filters or rotating biological
contactors
Control Requirements
What Are the General
Control Requirements?
Apply controls prior to and during
treatment
Cover or enclose waste management unit
Generally, convey emissions through
closed-vent system to control device
Control devices remove or destroy >95%
of organics
G-9
-------
Control Requirements
What Are the Affected Waste
Management Units?
- Tanks
- Surface impoundments
- Oil-water separators
- Containers
- Individual drain systems
Control Requirements
Tanks
Requirements would apply to most
noncombustion treatment processes
Cover and vent to control device
Alternative controls: meeting
requirements of VOL storage NSPS
(40 CFR 60 Subpart Kb)
- Fixed-roof and internal floating
- External floating roof
Control Requirements
Surface Impoundments
Cover
Vent to control device
G-10
-------
Control Requirements
Containers
Cover
Submerge fill for pumpable waste
Enclose and vent to control device
during waste treatment
Control Requirements
Oil-Water Separators
Cover and vent to control device
Alternative controls
- Floating roof
- Meeting the requirements of
petroleum refinery wastewater
systems NSPS (40 CFR 60,
Subpart QQQ)
Control Requirements
Individual Drain Systems
Cover each opening and vent to control
device
Alternative controls
- Comply with NSPS control
requirements (40 CFR 60,
Subpart QQQ) and
- Control junction box emissions
Install water seals on junction box
Vent junction box to closed-vent
system and control device
G-ll
-------
Outline
Overview
Applicability
Control requirements
Compliance
Summary
Compliance
How Is Compliance Insured?
Initial determination of TAB
Certification of compliance
Monitoring and inspections
Records
Reports
Compliance
Initial Determination of TAB
Existing facilities report June 7,1990
Updates allowed as new information
obtained
New sources report at startup
Report to include:
TAB for wastes with ฃ10% water
- Identification of streams to be
controlled
- Details on basis for benzene waste
streams not controlled
G-12
-------
Compliance
<1 Mg/yr
>10 Mg/yr
TAB
Initial Certification;
Annual and Quarterly
Reporting ,
Annual
Reporting
No Further
Reporting
Applicable
Facilities
1 Mg/yr to 10 Mg/yr
Compliance
Certification of Compliance
Submitted by March 7, 1992, or by date of
new source startup
Certifies installation of required equipment
Certifies completion of initial testing and
inspections
Compliance
Monitoring and Inspections
For both treatment and control processes:
- Install continuous monitoring
equipment
- Record all important process
parameters
- Inspect monitoring data daily
Monthly effluent sampling for treatment
processes
Quarterly visual inspections of covers
Annual detectable emission surveys for
closed-vent systems
G-13
-------
Compliance
Recordkeeping Requirements
Record information documenting
compliance
- Waste determination results
- Treatment and control equipment
design
- Inspection and monitoring results
Maintain records onsite for 2 years
Compliance
Reporting Requirements
Quarterly reports documenting
inspections
Quarterly reports documenting incidences
of upsets
Annual reports summarizing:
- Incidences of detectable emissions
- Visual inspections of tears, gaps, etc.
- Repairs and corrective action
Outline
Overview
Applicability
Control requirements
Compliance
Summary
G-14
-------
Summary
The rule applies to owners and operators of:
- Chemical manufacturing plants
- Petroleum refineries
- Coke by-product recovery plants
- Offsite TSDF receiving waste from above
Treatment and control required for:
- Facilities with >10 Mg/yr TAB
- Waste streams within those facilities with
>10 ppmw benzene
Summary
(continued)
Treatment requirements
- <10 ppmw or
- >99 wt % benzene removal
Control prior to treatment and
noncombustion treatment units
- No detectable emissions
- > 95% total organic removal
G-15
6 U.S. GOVtRKMCNI PRINT INC OFFICE: 1991 548-187/20519
-------
Workshop - Organic Air Emissions from Waste
Management Facilities
Speaker Slide Copies and Supporting Information
Volume 1
-------