EPA Course Number AIR 206 Miscellaneous Organic Chemical Manu MACT Training ------- [This page intentionally left blank.] ------- Miscellaneous Organic Chemical Manufacturing MA CT Training EPA Contract No. 3W-2360-NALX Prepared for: Marcia Mia Office of Enforcement and Compliance Assurance U.S. Environmental Protection Agency Washington, DC 20460 Prepared by: RTI International 3040 Cornwall is Road Research Triangle Park, North Carolina 27709 April 2004 ------- [This page intentionally left blank.] 11 ------- Miscellaneous Organic Chemical Manufacturing MACT Training Table of Contents Title Presentation # Overview of Industry 1 Overview of NESHAP 2 Applicability 3 Emission Standards 4 Case Study 5 Initial Compliance Requirements 6 Ongoing Compliance Requirements 7 Recordkeeping and Reporting 8 Alternative Standard 9 Pollution Prevention 10 Comparison of Rule Requirements for PAI, PHARMA, and MON 11 Review of Available Implementation Tools 12 Other Questions and Answers 13 in ------- Miscellaneous Organic Chemical Manufacturing MACT Training List of Appendices AppendixA Appendix B Appendix C Appendix D Appendix E Appendix F Appendix G Appendix H Compliance Timeline Tabular Summaries of Requirements in Subpart FFFF and Comparisons of Requirements in Subparts GGG, MMM, and FFFF Applicability and Compliance Flowcharts Case Study Data Equations and Exercises to Calculate Uncontrolled Process Vent Emissions Exercise to Determine Ongoing Compliance Status Acronyms, Definitions, and Applicability Materials Presenter's Biographical Sketches IV ------- EPA Course Number AIR 206 Miscellaneous Organic Chemical Manufacturing MACT Training Miscellaneous Organic Chemical Manufacturing MACT Training ¦ Overview of Industry ¦ Overview of NESHAP ¦ Applicability ¦ Emission Standards ¦ Case Study ¦ Initial Compliance Requirements ¦ Ongoing Compliance Requirements ¦ Recordkeeping and Reporting ¦ Alternative Standard ¦ Pollution Prevention ¦ Practical Aspects of Inspection ¦ Comparison of Rule Requirements for PAI, PHARMA, and MON ¦ Review of Available Implementation Tools ¦ Other Questions and Answers 1 ------- [This page intentionally left blank.] 2 ------- National Emission Standards for Miscellaneous Organic Chemical Manufacturing 1.0 Overview of the Industry Overview of the Industry ¦ Background ¦ Section 112 of the Clean Air Act ¦ Discussion of Source Category List and Subsumed Categories ¦ Data Collection and Rule Development 1.0 Overview of the Industry 3 ------- Section 112 5 ¦ Section 112 of the Clean Air Act Amendments of 1990 . 112 (b) List of HAP ¦ 112 (c) Source Category List . 112 (d) MACT . MACT Floor Best 12% of sources (existing) Best of best (new) 1.0 Overview of the Industry Source Categories ¦ Source Categories ¦ www.epa.gov/ttn/atw/socatlst/socatpg.html ¦ Latest list for major sources: Feb 12, 2002 (67 FR 6521) - Specialty organic chemicals - Explosives - Certain polymers and resins - Pesticide intermediates ¦ Implications for 112 (j) 1.0 Overview of the Industry 4 ------- 7 Types of Processes Chemical Manufacturing 1.0 Overview of the Industry Types of Processes Polymer Manufacturing I Add Extruder/ Pelletizer 1.0 Overview of the Industry 5 ------- 9 Processing Scale Small scale, batch manufacturers to SOCMI facilities 1.0 Overview of the Industry 10 Non-Dedicated Equipment Equipment Production Areas Reactors Process Tanks Filters Evaporators Crystal izers Reactors Process Tanks Filters Evaporators Crystal izers Reactors Process Tanks Filters Evaporators Crystal izers Reactors Process Tanks Filters Evaporators Crystal izers Reactors Process Tanks Filters Evaporators Crystal izers Reactors Process Tanks Filters Evaporators Crystal izers 1 2 3 4 5 6 Production Activities at Factory A Bay Process 1 A 2 A 3 A B C 4 A C 5 C 6 B C D 1.0 Overview of the Industry 6 ------- 1 National Emission Standards for Miscellaneous Organic Chemical Manufacturing 2.0 Overview of NESHAP (40 CFR part 63, subpart FFFF) Overview of Subpart FFFF ¦ Development history ¦ Summary of requirements ¦ Key changes since proposal ¦ Impacts ¦ Compliance timeline 2.0 Overview of NESHAP 7 ------- 3 Development History ¦ Project started in 1995 ¦ Data collection in 1997 ¦ Proposal: April 4, 2002 ¦ Promulgation: November 10, 2003 ¦ Litigation...? 2.0 Overview of NESHAP Organization of Subpart FFFF ¦ What's covered (applicability) ¦ Compliance dates ¦ Standards and compliance requirements ¦ Alternative means of compliance ¦ Notifications, Reports, and Records ¦ Other Requirements 2.0 Overview of NESHAP 8 ------- Overview of Applicability ¦ Facility must be a major source of HAP emissions ¦ Process units that: ¦ Produce organic chemicals that are not subject to other MACT standards ¦ Process, use, or produce organic HAP or hydrogen halide and halogen HAP ¦ Batch process vents from HON process units ¦ Several cited exclusions 2.0 Overview of NESHAP Overview of Standards ¦ Standards for: ¦ Process vents ¦ Storage tanks ¦ Transfer operations ¦ Wastewater ¦ Equipment leaks ¦ Heat exchange systems 2.0 Overview of NESHAP 9 ------- Overview of Compliance Requirements ¦ Most compliance requirements are specified by cross-referencing other rules Emission Point/Equipment Referenced Subparts Continuous process vents G and SS Batch process vents SS and GGG Storage tanks WW and SS and GGG Equipment leaks TT and UU Process wastewater G Maintenance wastewater and heat exchange systems F Transfer operations ss 2.0 Overview of NESHAP Initial Compliance Overview ¦ Determine Group status, or designate as Group 1 ¦ Group 1 emissions vented to APCD ¦ Performance test, design evaluation, or calculate controlled emissions ¦ Establish operating limits for parameter monitoring ¦ Wastewater treatment units ¦ Performance test or design evaluation ¦ Initial inspections ¦ Floating roofs, closed-vent systems, waste management units 2.0 Overview of NESHAP 10 ------- Ongoing Compliance Overview ¦ Vent streams to APCD or recovery device ¦ Monitor parameters (generally continuously) ¦ Average parameter readings (generally daily) ¦ Wastewater treatment unit parameter monitoring ¦ M21 monitoring and visual inspections for equipment leaks (LDAR program) ¦ Periodic inspections ¦ Floating roofs, closed-vent systems, waste management units 2.0 Overview of NESHAP 10 Recordkeeping Overview ¦ Operating scenarios for each process ¦ Various written plans ¦ Startup, shutdown, and malfunction plan ¦ Maintenance wastewater plan ¦ Plans for inspecting unsafe- or difficuIt-to-inspect equipment ¦ Ongoing records. For example, ¦ Monitoring data and documentation of periods when operating limits are exceeded ¦ Inspection results and documentation of repairs ¦ Operating log or schedule ¦ Documentation of SSM events 2.0 Overview of NESHAP 11 ------- 11 Reporting Overview ¦ Initial notification ¦ Precompliance report ¦ Notification of compliance status ¦ Compliance reports ¦ Miscellaneous reports required by the General Provisions ¦ Notification of performance test (and test plan) ¦ Notification of CEMS performance evaluation ¦ Request for extension of compliance ¦ Application for approval of construction or reconstruction 2.0 Overview of NESHAP 12 Exceptions to General Provisions ¦ Startup, shutdown, and malfunction ¦ Records (occurrence, duration, and actions) and reports required only if excess emissions occur ¦ No immediate SSM report (continued) 2.0 Overview of NESHAP 12 ------- 13 Exceptions to General Provisions ¦ Performance tests ¦ Must conduct no later than 150 days after compliance date ¦ Site-specific test plan must be submitted with notification of performance test for batch process vents ¦ Performance tests for batch process vents must be conducted under worst-case conditions rather than representative conditions (continued) 2.0 Overview of NESHAP 14 Exceptions to General Provisions ¦ Compliance reports ¦ Changes to information already submitted in NOCS are to be reported in compliance reports rather than within 15 days of the change ¦ Required semiannually; the provisions that specify more frequent reporting do not apply ¦ Only one type of report (i.e., not summary reports and excess emissions reports) ¦ Information to report doesn't depend on percentage of time during which excess emissions occur ¦ Certain CPMS records are excluded 2.0 Overview of NESHAP 13 ------- 15 Differences From Subpart SS ¦ Initial compliance ¦ Must conduct performance tests for batch process vents under worst-case conditions, not maximum representative conditions ¦ Design evaluation instead of performance test is allowed for small control devices ¦ Correct concentrations to 3% oxygen for supplemental gases rather than supplemental combustion air ¦ May elect to conduct design evaluation for halogen scrubbers regardless of scrubber size ¦ Determine controlled emissions for condensers using procedure in subpart GGG rather than conducting performance test or design evaluation (continued) 2.0 Overview of NESHAP 16 Differences From Subpart SS ¦ Ongoing compliance ¦ Measure caustic strength as alternative to pH ¦ Alternative monitoring for catalytic incinerators ¦ Operating limits for batch operations may be averaged over the batch operations rather than daily ¦ For batch process vent control devices, alternative to continuous monitoring is allowed if inlet HAP is <1 tpy ¦ Monitoring data collected during periods of SSM are to be used in calculating daily averages ¦ Excused excursions are not allowed (continued) 2.0 Overview of NESHAP 14 ------- 17 Differences From Subpart SS ¦ Other ¦ Install a flow indicator at inlet or outlet of control device if flow could cease periodically; Monitoring data collected during periods of no flow may not be used in averages ¦ For storage tank emissions vented to control devices, follow the same provisions as for process vents, not the monitoring plan approach in §63.985(c) 2.0 Overview of NESHAP 18 Key Changes Since Proposal ¦ Significant changes to format ¦ Developed separate thresholds for control of partially soluble and soluble HAP in wastewater ¦ Added emission limits for hydrogen halide and halogen emissions from process vents ¦ Added less-stringent LDAR requirements for processes with batch process vents ¦ Deleted calibration and other QA/QC specifications in favor of the requirements in subpart SS ¦ Eliminated the immediate SSM reporting requirement ¦ Added "process unit group" compliance option for non- dedicated equipment 2.0 Overview of NESHAP 15 ------- Process Unit Group Process Vessels Process A Process B Process C Process D R400 decanter batch still R410 reactor extraction hold tank R420 decant/wash reactor R270 reactor reactor R250 hold tank extraction R160 hold tank chlorinator R150 batch still batch still R130 receiver receiver R390 reactor extractor R280 extraction hold tank pH adjust R2400 separator hold tank T2300 hold tank hold tank T1300 hold tank receiver 2.0 Overview of NESHAP Process Unit Group ¦ Create PUG ¦ Process units with overlapping equipment ¦ Projection of processes to be run in 5-year period ¦ May add process units in the future if there is overlap (continued) 2.0 Overview of NESHAP 16 ------- Process Unit Group ¦ Determine primary product ¦ Type of material projected to be made for the greatest operating time in the 5-year period ¦ Redetermine at least every 5 years (continued) 2.0 Overview of NESHAP Process Unit Group ¦ Generally, comply with the rule that applies to the primary product for all process units in the PUG 2.0 Overview of NESHAP 17 ------- Impacts ¦ Approximately 260 facilities with emission points that meet some of the thresholds for control ¦ Estimated HAP reductions: 16,800 tpy ¦ Estimated cost: $75 million/yr 2.0 Overview of NESHAP 24 Compliance Timeline Existing sources - initial startup before April 4, 2002 (Rule proposal date) March 9, 2004 May 6, 2006 November 10, 2006 60 days before performance test April 7, 2007 August 31, 2007 and every 6 months thereafter New sources- initial startup after April 4, 2002 (Rule proposal date) With the application for approval of construction March 9, 2004 or 120 days after initial startup, or whichever reconstruction is later November 10, 2003 or upon initial startup, whichever is later 60 days 150 days First Aug 31or Feb 28 before after following the end performance the of the compliance test Compliance period that occurs date more than 6 months after the compliance date, and every 6 months thereafter 2.0 Overview of NESHAP 18 ------- 1 National Emission Standards for Miscellaneous Organic Chemical Manufacturing 3.0 Applicability Applicability Topics ¦ Affected Source ¦ Definitions ¦ Types and Functions of Affected Units ¦ Questions and Answers 3.0 Applicability 19 ------- MON Applicability §63.2435 (a) Specifies applicability to owners or operators of MCPU located at major sources of HAP (b) Defines MCPU (c) Provides Exemptions 3.0 Applicability Miscellaneous Organic Chemical Manufacturing Process Unit §63.2435 (b): MCPU includes equipment necessary to operate a miscellaneous organic chemical manufacturing process that meets (b)(1) through (3): ¦ (1) manufacture materials or families of materials described by: . (i and ii) SIC codes 282,283,284,285,286,287,289,386 or NAICS code 325, with some noted exceptions ¦ (iii) Quaternary ammonium compounds and ammonium sulfate produced from caprolactam (continued) 3.0 Applicability 20 ------- Miscellaneous Organic Chemical Manufacturing Process Unit ¦ (iv) Hydrazine ¦ (v) Organic solvents recovered using nondedicated solvent recovery devices ¦ (2) The MCPU processes, uses or produces any of the organic HAP listed in the CM section 112(b) or hydrogen halide and halogen HAP ¦ (3) The MCPU is not an affected source or not part of an affected under Part 63 (except for HON batch vents) 3.0 Applicability 6 Potential Reach of the MON 3.0 Applicability 21 ------- Implications of Broad Applicability ¦ Chemical and polymer manufacturers that are major sources of HAP that have units that have not been affected by other MACT will likely be affected sources under the MON. ¦ HON CMPU may also have to be revisited because the MON will regulate batch vents. 3.0 Applicability Miscellaneous Organic Chemical Manufacturing Process 3.0 Applicability 22 ------- Isolated Intermediate ¦ Isolated intermediate means a product of a process that is stored before subsequent processing. An isolated intermediate is usually a product of a chemical synthesis, fermentation, or biological extraction process. Storage of an isolated intermediate marks the end of a process. Storage occurs at any time the intermediate is placed in equipment used solely for storage. (continued) 3.0 Applicability 10 Isolated Intermediate Process A Process B 3.0 Applicability 23 ------- Family of Materials ¦ A family is considered part of the same process ¦ A family is defined in Appendix J ¦ Based on the same emission profiles (see Appendix J for an example) 3.0 Applicability 12 Example: MON Process Boundaries 3.0 Applicability 24 ------- Example: MON Process Boundaries versus PAI 13 MCPU Products B,C,D 2nd Product: Raw Materials Product A PAI Process Unit (continued) 3.0 Applicability Scrubber Distillation PAI Process Units Products A and B Recycle Reactor Materials HAP Raw Materials (RM) for Product A: 2-Butoxy Ethanol Product Storage & Formulation For Product B: Triethylamine Aromatic-200 contains HAP and is used for formulation of Product A Aromatic 200 MCPU Example: MON Process Boundaries 14 versus PAI 3.0 Applicability 25 ------- Process Verits ¦ Batch: » >50 ppmv HAP or >200 Ib/yr ¦ Continuous: ¦ >.005 wt% total organic HAP 15 (continued) 3.0 Applicability 16 Process Vents Continuous Vents are defined as in the HON-- from continuous distillation, air oxidation reaction or reaction. Batch vents are essentially anything not explicitly defined as a continuous vent, a storage tank, wastewater tank, bottoms receiver or surge control vessel. 3.0 Applicability 26 ------- Example: Process Vents 17 Reaction Batch Note: although the dryer is operated continuously, it is considered a batch vent in the MON (continued) 3.0 Applicability Example: Process Vents Reaction Batch The distillation unit vent is a continuous vent for MON purposes. 3.0 Applicability 27 ------- 19 Storage lariks i J Ffxod Roof Tank [External Floating Roof Tank 3.0 Applicability 20 Process Vents versus Storage Tanks Reaction Batch 3.0 Applicability 28 ------- Process Vents versus Storage tanks versus Surge Control Vessels and Bottoms Receivers 21 a Reaction Batch a Distillation Continuous Reaction Continuous -d] 3.0 Applicability 22 Exercise 3.0 Applicability 29 ------- 23 Storage I ank Assignment Under the HON: ¦ Tanks A and F are intervening tanks and assigned to the CMPU; ¦ B and E will be subject to OLD MACT; ¦ C and D are not: assigned to the CMPU because they supply another process; if the process is a MCP, then the tanks will be MON associated tanks 3.0 Applicability 24 Wastewater Wastewater thresholds ¦ >. 5 ppmw and > 0.02 Ppm, or ¦ >. 10,000 ppmw Process wastewater Tank Drawdown (continued) 3.0 Applicability 30 ------- 25 Wastewater ¦ Maintenance wastewater 3.0 Applicability Wastewater versus Open Liquid In-Process Streams 26 To Wastewater «4- Destination ? Drying Column Finished Product ?/ r / Vacuum System discharges from other equipment POG Condensate Drum POD i> V Drains V Destination? 3.0 Applicability 31 ------- 27 Equipment Leaks 3.0 Applicability ¦ Piping components in 5% wt organic HAP service. 28 Transfer Operations 3.0 Applicability 32 ------- 29 Questions and Answers 3.0 Applicability How many MACT standards would apply to this facility? What are they? 30 Light Distillate from Refinery •J 'A xJ 2,3 -Dimethylbutane 4 - methylpentane XJ xJ xJ T_l TJ Poly ouiaaiene Isobutylene Heavy gasoline Benzene XJ 3.0 Applicability 33 ------- How many MACT standards would apply to this facility? What are they? 31 Light Distillate from Refinery I I tCq, ^Polyj^opylene 2,3 -Dimethylbutane 4 - methylpentane 0 xJ 3.0 Applicability What MACT standard(s) apply for this system? 32 The diagram below presents a typical production scheme for polycarbonates, thiocarbamates, and chloroformates from phosgene. What MACT standard(s) apply for this system? Bis-A, Phenols, for etc. Feedstock and , Solvent COCI2 (Phosgene) CO, CI2 1 ~ Acid/Base Wash Water Wash Product to Drying < 3.0 Applicability 34 ------- What is the MACT applicability? ¦ A chemical manufacturer produces benzenesulfonic acid (a chemical listed in Table 1 of the HON) using a batch process, stores the material, and then produces fonofos (a non- SOCMI chemical) using the benezenesulfonic acid as a feedstock. What is the MACT applicability? 3.0 Applicability 35 ------- [This page intentionally left blank.] 36 ------- 1 National Emission Standards for Miscellaneous Organic Chemical Manufacturing 4.0 Emission Standards Emission Standards ¦ Standards are specified for ¦ Group 1 CPV, BPV, ST, WW streams, and transfer racks ¦ Process vents with uncontrolled hydrogen halide and halogen HAP emissions > 1,000 Ib/yr/process ¦ Process vents at new sources only with uncontrolled PM HAP emissions > 400 Ib/yr/process 4.0 Emission Standards 37 ------- Emission Standards ¦ Standards specified for (cont.) - Equipment in organic HAP service > 300 hr/yr ¦ Heat exchange systems ¦ Generally, no requirements for Group 2 streams or emission points below thresholds listed above 4.0 Emission Standards Continuous Process Vents ¦ Group 1: TRE < 1.9 (existing) or < 5.0 (new) ¦ Standards for Group 1 CPV ¦ > 98% reduction in organic HAP ¦ < 20 ppmv as TOC or total organic HAP ¦ Flare ¦ Recovery device to maintain TRE >1.9 ¦ Halogen reduction options if halogenated vent stream is combusted ¦ Requirements for Group 2 CPV ¦ If TRE < 5.0, monitor recovery device parameters ¦ If TRE > 5.0, no requirements 4.0 Emission Standards 38 ------- Batch Process Vents ¦ Group 1: collective uncontrolled organic HAP emissions > 10,000 Ib/yr/process (> 3,000 Ib/yr/process at new sources) ¦ Standards for Group 1 BPV ¦ Collective reduction > 98% using control devices ¦ Collective reduction > 95% using recovery devices ¦ Other options for subset of vents: Flare < 20 ppmv as TOC or total organic HAP (continued) 4.0 Emission Standards Batch Process Vents ¦ Standards for Group 1 BPV (cont.) - Halogen reduction options same as for CPV ¦ Only recordkeeping (estimated emissions per batch and tracking the number of batches) for Group 2 batch process vents 4.0 Emission Standards 39 ------- Other Process Vent Standards ¦ For processes with uncontrolled hydrogen halide and halogen emissions > 1,000 Ib/yr ¦ > 99 percent reduction ¦ < 20 ppmv ¦ Process at a new source with uncontrolled PM HAP emissions from process vents > 400 Ib/yr ¦ > 97 percent reduction 4.0 Emission Standards 8 Storage Tank Standards • Group 1: > 10,000 gal; MTVP > 6.9 kPa (existing) or > 0.69 kPa (new) ¦ For Group 1 storage tank: ¦ > 95 percent reduction in organic HAP ¦ < 20 ppmv as TOC or total organic HAP ¦ Flare ¦ Floating roof as specified in subpart WW (but maximum true vapor pressure must be < 76.6 kPa) ¦ Vent to a process or fuel gas system ¦ Vapor balance ¦ Halogen reduction options same as for CPV 4.0 Emission Standards 40 ------- Transfer Rack Standards ¦ Group 1: rack loads >0.65 million l/yr of material with average partial pressure >1.5 psia ¦ Standards for Group 1 transfer racks ¦ > 98 % reduction in organic HAP ¦ < 20 ppmv as TOC or organic HAP ¦ Flare ¦ Vent to a fuel gas system or process ¦ Vapor balance to a storage tank ¦ Halogen reduction options same as for CPV ¦ Group 2 transfer racks: none 4.0 Emission Standards Group 1 Wastewater HAP concentration, ppmw Total HAP load, tpy Wastewater flow, P/min PSHAP SHAP Total > 50 > 10,000 Any > 50 > 1,000 > 1 < 50 > 30,000 > 1 4.0 Emission Standards 41 ------- 11 Wastewater Standards ¦ Emission suppression (or management) required for waste management units: ¦ Wastewater tanks ¦ Surface impoundments ¦ Containers ¦ Individual drain systems ¦ Oil-water separators 4.0 Emission Standards 12 Individual Drain Systems 4.0 Emission Standards 42 ------- 13 Wastewater Treatment Options ¦ < 50 ppmw (not allowed for biotreatment or designated Group 1 streams) ¦ Design steam stripper ¦ Percent reduction (not for biotreatment) ¦ > 99% removal ¦ > Fr value ¦ Mass removal ¦ Based on Fr ¦ > 95% for all Group 1 and Group 2 streams sent to biotreatment 4.0 Emission Standards 14 Biotreatment Illustration 1 2 3 4 5 6 Group 1 Streams Group 2 Streams discharge RMR=^Q%{c,*Fr) AMR = M. - M , in out - M. * Fh. in bio M UJ 4.0 Emission Standards 43 ------- 15 Design Steam Stripper - Steam > 0.04 kgM WW feed 4.0 Emission Standards 16 4.0 Emission Standards 44 ------- Wastewater Standards ¦ For wastewater transferred offsite to biotreatment, less burdensome management requirements are an option (offsite only) if the wastewater contains < 50 ppmw of partially soluble HAP ¦ Must have a maintenance wastewater plan as part of the S/S/M plan 4.0 Emission Standards Equipment Leak Standards ¦ Comply with LDAR requirements in: ¦ Generic MACT subpart TT Not allowed for process units with continuous process vents Not allowed for new sources ¦ Generic MACT subpart UU, or ¦ Consolidated Federal Air Rule (CAR; 40 CFR part 65, subpart F) 4.0 Emission Standards 45 ------- 19 Miscellaneous Standards Heat exchange systems: monitor inlet and outlet of heat exchange system Exit - Cooling Tower IS- y y HX (continued) 4.0 Emission Standards Miscellaneous Standards ¦ Alternative means of compliance ¦ Emissions averaging: same as in §63.150 of the HON ¦ Pollution prevention ¦ The "alternative standard" 4.0 Emission Standards 46 ------- 21 Hierarchy for Combined Streams ¦ Hierarchy used to select a single set of requirements for combined streams ¦ Group 1 batch process vents ¦ Continuous process vents to control device ¦ Transfer operations ¦ Group 1 wastewater streams ¦ Storage tanks ¦ Continuous process vents to recovery device (continued) 4.0 Emission Standards 22 Hierarchy for Combined Streams 4.0 Emission Standards 47 ------- [This page intentionally left blank.] 48 ------- 1 National Emission Standards for Miscellaneous Organic Chemical Manufacturing 5.0 Case Studies Case Study ¦ Using the case study, we will: ¦ Describe the process and equipment ¦ Identify raw materials, products, wastes ¦ Calculate HAP emissions from various emission generating steps ¦ Review the requirements of FFFF in the context of the example ¦ Develop a strategy for compliance with FFFF ¦ Develop an emission profile for demonstrating compliance with FFFF 5.0 Case Studies 49 ------- 3 Case Study No. 1 5.0 Case Studies 4 Case Study No. 2 5.0 Case Studies 50 ------- 1 National Emission Standards for Miscellaneous Organic Chemical Manufacturing 6.0 Initial Compliance Determination Initial Compliance Demonstration ¦ Summary of Requirements ¦ Emission Calculations ¦ Initial Compliance Demonstration Conditions ¦ Control Device Operation and Design ¦ Test Methods 6.0 Initial Compliance Determination 51 ------- 3 6.0 Initial Compliance Determination Other Requirements for Process Vents ¦ Determine halogenated vent streams if using a combustion control device ¦ Conduct initial inspection of CVS (§63.983) ¦ Requirement for flares is called a "compliance assessment test" (§63.987) ¦ No performance test or design evaluation for certain boilers/process heaters (§63.988) ¦ No inspections or performance tests for final recovery devices used for CPV 6.0 Initial Compliance Determination 52 ------- 5 Requirements for Storage Tanks Standard Initial Compliance Requirements 1. CVS to control with percent reduction or outlet concentration ¦ CVS initial inspection and repair as specified in §63.983 ¦ Conduct performance test or design evaluation at the reasonably expected maximum filling rate ¦ A test for process vents may be used to demonstrate compliance ¦ A previously conducted performance test may be used 2. CVS to flare ¦ CVS inspection ¦ Conduct flare compliance assessment as specified in §63.987 of subpart SS 3. Vapor balancing to tank trucks or railcars ¦ Comply with 63.1253 (f) ¦ Pressure relief setting >.2.5 psig on the storage tank ¦ Certification from offsite cleaning/reloading facility of compliance with the 95% standard ¦ Records of DOT certification of tank trucks and railcars 4. Fuel gas system ¦ No design evaluation or performance test required (§63.984(b)(1)) 5. Return to process ¦ Conduct design evaluation to demonstrate that the HAP in the stream meet any of four conditions specified in §63.984(b)(2) 6. Floating roof ¦ Comply with subpart WW design and inspection requirements 6.0 Initial Compliance Determination 6 Wastewater Initial Compliance ¦ Determine or designate Group 1 wastewater streams ¦ Requirements for treatment units (§63.138, 63.145) ¦ Design Steam Stripper or RCRA-permitted unit: No design evaluation or performance test ¦ Closed Biological Treatment or non-Biological Treatment: Performance Test or Design Evaluation ¦ Open Biological Treatment: Performance test ¦ Enhanced Biological Treatment ¦ No performance test if 99% of compounds are on "List 1" of Table 36 ¦ If not, use Appendix C and default biodegradation rates to determine Fbio ¦ Initial inspections for WMUs (§63.143) ¦ Offsite: certification of compliance with the MON (§63.132) 6.0 Initial Compliance Determination 53 ------- Wastewater Management Unit Vent Stream Initial Compliance Standard Initial Compliance Requirements (§§63.139, 63.143, and 63.145 of the HON) 1. CVS to 95% control with percent reduction or to 20 ppmv ¦ CVS inspection ¦ Conduct performance test or design evaluation ¦ A test for process vents may be used to demonstrate compliance 2. CVS to boiler or process heater: . w/ > 44MW . 40 CFR 266 Subpart H or 264 Subpart 0 ¦ Where vent stream is introduced as primary fuel ¦ CVS inspection ¦ No design evaluation or performance test 3. CVS to flare ¦ CVS inspection ¦ Comply with 63.11(b) 4. CVS to combustion device designed with residence time >0.5 second and temperature >760°C ¦ CVS inspection ¦ Conduct design evaluation (document that conditions exist) 6.0 Initial Compliance Determination 8 Initial Compliance for Transfer Racks Group Standard Initial Compliance Requirements 1 CVS to control device Same as for process vents, except no need to calculate uncontrolled emissions Vent to fuel gas system No requirements Vent to process Same as for storage tanks Vapor balance Design and operate system to collect and route HAP vapors to the originating storage tank 2 None No requirements 6.0 Initial Compliance Determination 54 ------- Exceptions to Subpart SS in Initial Compliance Demonstration ¦ Correct concentrations to 3% oxygen for supplemental gases rather than supplemental combustion air (also have to correct concentrations for supplemental gases when using noncombustion devices) (§§63.2450(i) and 63.2460(c)(6)) ¦ Must conduct performance tests for batch process vents under worst-case conditions, not maximum representative conditions (§63.2460(c)(2)(ii)) ¦ Design evaluations using procedures is §63.1257(a)(1) of subpart GGG are allowed for "small" control devices (§63.2450(h)) ¦ Instead of performance test or design evaluation, may calculate controlled emissions for condensers used to control emissions from batch process vents (§63.2460(c)(2)(iii)) 6.0 Initial Compliance Determination Emission Estimation Equations for 10 Batch Process Vents ¦ Refer to §63.1257(d)(2)(i), with some clarifications in §63.2460(b) ¦ Used to calculate uncontrolled HAP and condenser controlled HAP from batch operations when process vent compliance is required ¦ Based on ideal gas law 6.0 Initial Compliance Determination 55 ------- 11 Other Equations ¦ Draft EIIP Document: Chapter 16 of Volume II, "Methods for Estimating Air Emissions from Chemical Manufacturing" ¦ Subsurface and above-surface charging of liquid that is miscible in liquid already in the vessel ¦ Vessel-specific saturation factor for purge of partially filled vessel ¦ Illustrations for all of the equations that are specified in the rule ¦ http://www.epa.gov/ttn/chief/eiip/index.html 6.0 Initial Compliance Determination Engineering Assessments for Batch 12 Process Vents ¦ Refer to §63.1257(d)(2)(ii) ¦ Non-standard procedures and methods used to calculate uncontrolled HAP emissions, or to define process vents ¦ Engineering assessments require preapproval via the precompliance report ¦ Examples ¦ Use of previous test results, bench-scale or pilot scale test data ¦ Use of flow rates or HAP emission rates implied within a permit limit ¦ Design information such as material balances, design flow rates, or concentration estimates 6.0 Initial Compliance Determination 56 ------- 13 Example Description ¦ In the first step of case study No. 2, feed tank T-l is charged with 200 gallons of methanol. The temperature of the vessel vapor space is assumed to be 25°C based on ambient conditions 6.0 Initial Compliance Determination 14 Procedure ¦ Using Equation 11, emissions are calculated as follows: E = (R)W S (P'XMW') (Eq.ll, 1. In this case, there is only one component, methanol; therefore n = 1 2. Partial pressure of methanol, P„ is calculated using Raoult's Law, or t> t> XjPj* = Pj where: x, = mole fraction, 1 for single components P,* = vapor pressure of methanol, 125 mmHg at 25°C (Continued) 6.0 Initial Compliance Determination 57 ------- Procedure 15 3. Plugging values into the equation (200gallo„s)(748gJ E=f mmHgft'1, Z125 mmHg)l lbmoleJ V999 lbmole K j + E = 0.36 lb methanol/event 6.0 Initial Compliance Determination Exercise 16 ¦ Calculate uncontrolled emissions for a displacement ¦ See Appendix E of the workbook 6.0 Initial Compliance Determination 58 ------- Initial Compliance Demonstration Conditions ¦ Batch process vents: worst case conditions ¦ Continuous process vents, transfer racks, and storage tanks: maximum representative conditions ¦ Wastewater vents: representative operating conditions 6.0 Initial Compliance Determination 18 Emission Profile for Batch Vents ¦ By process ¦ Most difficult; must consider all emission episodes that can vent to the control device in any given hour (see example - 53 Ibs/hr) ¦ By equipment ¦ Based on the limitations of the equipment; finding the highest emitting equipment, like a dryer, and test using the most volatile HAP even though operation in this manner does not represent any actual processes ¦ By limitations of the capture and conveyance system ¦ Example: testing at the set point limits for bypasses or at the maximum flow based on the fan 6.0 Initial Compliance Determination 59 ------- 19 Emission Profile by Process 60 4AP Load b/hr 30 15 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Hours Total HAP load vented to the device over a 24-hour period: 600 lbs 8 -hour period with at least 50% of the total load: 320 lbs Test over the one-hour period with the highest mass loading rate 53 lbs .i|pp 21 22 23 24 6.0 Initial Compliance Determination Control Devices Operation and Design ¦ Flares ¦ Incinerators ¦ Boilers and process heaters ¦ Carbon adsorption ¦ Gas absorbers ¦ Condensers 6.0 Initial Compliance Determination 60 ------- 21 Flares ¦ General procedure outlined in 63.987(b) ¦ Compliance assessment tests are used to determine composition, tip velocity, and visible emissions 6.0 Initial Compliance Determination 22 Incinerators Vapor Fuel gas ~ Sample ports ~ Thermocouple Design Evaluation to establish: Thermal Incinerators I Minimum and average temperature of combustion zone l Combustion zone residence time Catalytic Incinerators l Minimum and average temperature across the catalysts bed Damper ~ 6.0 Initial Compliance Determination 61 ------- 23 Boilers and Process Heaters Design heat input capacity >44 MW (150 mm BTU/hr) Haz waste combustor Mixed with primary fuel Boiler Feed water Fuel Mix Drum ! \/ ^ Combustion L J Air 6.0 Initial Compliance Determination 24 Carbon Adsorption Design evaluation to establish Exhaust stream organic HAP composition Cycle time Regeneration mass flow Design carbon bed temperature Regeneration time Service time of carbon 6.0 Initial Compliance Determination Exhaust to atmosphere Low- pressure steam 0-0 Pretreatment filtration, cooling dehumidification Vapor- laden air -o-1 Decai 62 ------- 25 Gas Absorbers I Design evaluation to establish Exhaust stream organic HAP composition Type and total number of theoretical and actual trays Type and surface area of packing column and for individual sections 6.0 Initial Compliance Determination Condensers 26 Tin 100° F "U" coolant, t 0 70 F 50° F coolant, t. ru exhaust gas out 80° F Design equations for condensers: Q = heat load, BTU/hr Q = U0 A A Tlm «— heat exchanger design Q = m Cp A T + m A Hvap <— heat load in gas stream ATlm — (Tin ~ tout )~ Oin ~ Tout ) En (Tin ~ ton, (tin "Ton, ) 6.0 Initial Compliance Determination 63 ------- Design Evaluation Example for Regenerative Carbon Adsorption 27 ¦ System description The total flowrate of gas entering a carbon adsorption system is 2000 ft3/imin. The maximum HAP load is 100 Ib/hr of CH3CI (chloroform). The carbon system will operate in continuous mode. While operating, two carbon beds will be adsorbing, while a third will be desorbing/on standby. = 2615 ppmv 100 Ib/hr Ibmole 379 ft3 (2000 ft3/min) (60min/hr) 119.4 lb 1 mole 6.0 Initial Compliance Determination 28 Example Design Evaluation ¦ Adsorptive capacity The adsorption capacity of the carbon used in this design evaluation is presented below for chloroform: 25- 20 - -Q *5 ±2 15- O 10 CHCI, CHCI, I 25° C \ Temperature for cooling ) 100°C 3,000 5,000 10,000 PPMV (continued) 6.0 Initial Compliance Determination 64 ------- 29 Example Design Evaluation ¦ Work capacity of carbon ¦ For this concentration (~2500 ppmv), the working capacity is estimated from adsorption isotherm to be approximately 0.2 lb/lb carbon. Applying a 50 percent safety factor for dynamic working capacity, we will use a working capacity of 0.1 lb/lb. (continued) 6.0 Initial Compliance Determination 30 Example Design Evaluation Carbon requirement Mc = r N A 1- ° uc n nj Mc - 100 lb / hr .1 lbCHCh lb carbon [12 hours][l+.5] Mc = 18,000 lbs carbon on adsorption cycle at all times (continued) 6.0 Initial Compliance Determination 65 ------- 31 Example Design Evaluation Desorption time ¦ Desorption time must be less than the following: (N ^ D ~1~ = 12 hours Ina; _2_ - 6 hours Because the stated desorption time (5 hours) is less than 5 hours, the proposed bed configuration is feasible. (continued) 6.0 Initial Compliance Determination 32 Example Design Evaluation Desorption Time, hr. Optimum steam flowrate = 15 lb/lb VOC = (15 lb/lb VOC) (100 lb VOC/hr) = 1,500 Ib/hr (continued) 6.0 Initial Compliance Determination 66 ------- 33 Example Design Evaluation ¦ Example carbon system design parameters Regeneration duration: 5 hours Regeneration frequency: 12 hours Minimum bed temperature: 100°C Maximum temperature for bed cooling: 25°C Minimum steam flow: 1500 Ibs/hr 6.0 Initial Compliance Determination Humidity Concerns ¦ The manufacturer data indicate that adsorption will not be affected if the influent gas concentration is less than 50 percent relative humidity 6.0 Initial Compliance Determination 67 ------- 35 Test Methods ¦ Identified in §§63.1257(b) and 63.997 ¦ Concentration ¦ Method 18 for control efficiency determination ¦ Method 25 for control efficiency for combustion devices . Method 25A for TOC ¦ As calibrated on methane or ¦ Predominant HAP ¦ Other . EPA Methods 2, 2A, 2C, 2D ¦ Methods 3, 4 stack gas moisture 6.0 Initial Compliance Determination 36 Wastewater Test Methods ¦ HAP concentration using the following methods, per §§63.144(b)(5)(i) and 63.2485(h): ¦ M305 of 40 CFR Part 63, Appendix A ¦ M25D of 40 CFR Part 60, Appendix A . M624, M625 of 40 CFR Part 136, Appendix A . M1624, M1625 of 40 CFR Part 136, Appendix A . M1666, M1667 of 40 CFR Part 136, Appendix A . M8260, M8270 in EPA Pub. No. SW-846 ¦ Other EPA methods, with validation 6.0 Initial Compliance Determination 68 ------- Questions and Answers ¦ Question #1: ¦ If someone does not reflux back to the reactor, but sends recovered solvent offsite, is that a control device or process condenser? ¦ Answer #1: ¦ Any condenser that supports a vapor-to- liquid phase change for operations above the boiling point is a process condenser. 6.0 Initial Compliance Determination 69 ------- [This page intentionally left blank.] 70 ------- 1 National Emission Standards for Miscellaneous Organic Chemical Manufacturing 7.0 Ongoing Compliance Requirements 2 Monitoring for Vent Streams §63.994(c): Halogen scrubbers and Habgen Control Devices §63.996: General Monitoring Requirements §63.998(b) and (c) and §63.999(c)(6): Data Averaging, Data Availability Requirements, QA/QC, and Rec»rds §63.999(b)(3): Procedures for Establishing Operating Parameter Limits 7.0 Ongoing Compliance Requirements 71 ------- Monitoring for Vent Streams ¦ Generally, must continuously monitor operating parameters (as specified in subpart SS and subpart G) ¦ Additional parameters specified in the MON for halogen scrubbers and catalytic incinerators (§63.2450(k)(3) and (4)) ¦ Slight differences in lists of devices for which subparts G and SS specify parameters 7.0 Ongoing Compliance Requirements Requirements for Parameter Monitoring ¦ Procedures for setting operating limits ¦ If initial compliance is based on performance tests (§§63.152(b)(2)(ii) and 63.999(b)(3)(H)): Operating limit based on values measured during the three test runs May supplement test data with engineering assessment and manufacturer's recommendations May set separate levels for different operating conditions if the APCD is used for batch process vents ¦ Base on design evaluation for small control devices (§63.2450(h)) (continued) 7.0 Ongoing Compliance Requirements 72 ------- Requirements for Parameter Monitoring ¦ Calibrate monitoring equipment according to manufacturer's specifications or other written procedures that assure accurate operation (§§63.143(g) and 63.996(c)(1)) ¦ Accuracy requirements specified for: ¦ Temperature monitoring devices (§§63.111 and 63.981) ¦ Specific gravity monitoring devices (§§63.111 and 63.981) ¦ Monitoring devices for carbon adsorber regeneration stream flow rate (§63.990 and Table 13 to subpart G) (continued) 7.0 Ongoing Compliance Requirements Requirements for Parameter Monitoring ¦ Data averaging periods ¦ Daily for any emission stream (§§63.998(b)(3) and 63.147(d)) ¦ Operating block only for batch process vents (§63.2460(c)(4)) ¦ Include data from periods of startup, shutdown, and malfunction (§63.2450(1)) (continued) 7.0 Ongoing Compliance Requirements 73 ------- Requirements for Parameter Monitoring ¦ Data availability requirements (§§63.999(c)(6) and 63.152(c)(2)(ii)) ¦ Must have sufficient data to constitute valid data for at least 75% of the operating hours in an operating day when operation is > 4 hr/d ¦ No more than one hour of data may not be valid due to insufficient data if operation is < 4 hr/d ¦ Must have measured values for each of the 15-minute periods to have a valid hour of data 7.0 Ongoing Compliance Requirements Other Monitoring Requirements for Vent Streams ¦ Inspections for closed vent systems and vapor collection systems (§§63.983 and 63.148(b)(1) and (2)) ¦ Annual visual inspections if system is constructed of hard-piping ¦ Annual Method 21 inspection if system is constructed of ductwork (continued) 7.0 Ongoing Compliance Requirements 74 ------- Other Monitoring Requirements for Vent Streams ¦ Inspections for closed vent systems and vapor collection systems (§§63.983 and 63.148(b)(1) and (2)) (cont.) - Differences between subparts G and SS: Subpart SS specifies an additional calibration gas for instruments that have multiple calibration scales Subpart SS does not require visual indications of a leak to be considered a leak if a Method 21 inspection is also conducted and the reading is < 500 ppm (continued) 7.0 Ongoing Compliance Requirements Other Monitoring Requirements for Vent Streams ¦ Monitoring for bypass lines around APCDs (§§63.983(a)(3) and 63.148(f)) ¦ Continuously monitor using a flow indicator in the bypass line, or ¦ Monthly visual inspection of car-seal on the bypass line valve (continued) 7.0 Ongoing Compliance Requirements 75 ------- Other Monitoring Requirements for Vent Streams ¦ Exceptions to requirement for continuous parameter monitoring ¦ Complying with alternative standard? Use CEMS (§§63.1258(b)(5)(i) and 63.2450Q)) m BPV routed through CVS to APCD that receives uncontrolled HAP <1 tpy? Conduct approved periodic verification (§63.2460(c)(5)) 7.0 Ongoing Compliance Requirements Ongoing Compliance Requirements 12 for Floating Roofs ¦ Inspection requirements (§63.1063(c) and (d)) ¦ Annual inspections of IFRs for design and operational failures ¦ Inspect for design and operational failures of IFRs and EFRs each time the tank is emptied and degassed (not to exceed every 10 years) ¦ Seal gap measurements for EFRs Annually for secondary seal Every 5 years for primary seal (continued) 7.0 Ongoing Compliance Requirements 76 ------- Ongoing Compliance Requirements 13 for Wastewater Treatment ¦ Parameter monitoring (§63.143(b), (c), and (d)) ¦ Steam strippers, continuously monitor: Steam flow rate Wastewater mass flow rate Wastewater feed temperature ¦ Other treatment units: request approval to monitor appropriate parameters that demonstrate proper operation (continued) 7.0 Ongoing Compliance Requirements Ongoing Compliance Requirements 14 for Waste Management Units ¦ Inspections (§63.143(a), §63.148(b)(3), and Table 11 to subpart G) ¦ Semiannual visual inspections for leaks, control equipment failures, and improper work practices ¦ Periodic seal gap measurements for floating roofs used on wastewater tanks and oil-water separators (continued) 7.0 Ongoing Compliance Requirements 77 ------- Ongoing Compliance Requirements 15 for Equipment Leaks ¦ Periodic monitoring using Method 21 and/or visual inspections to detect leaks (subparts TT and UU) 7.0 Ongoing Compliance Requirements Monitoring Example ¦ As part of the compliance strategy chosen for case study No. 2, the source chose to control all process vents with a thermal incinerator. After the performance test, the minimum combustion temperature required to demonstrate 98% was determined to be 1760 F, based on the average of the minimum combustion temperatures measured during the three test runs. ¦ A 24-hour data sampling for this incinerator is provided in Appendix F. From the example, determine the following: ¦ Is the incinerator in compliance with the standard for the 24-hour sampling period? ¦ Does the data constitute a valid 24-hour period of data? ¦ How would the source record and report the period of data presented? 7.0 Ongoing Compliance Requirements 78 ------- National Emission Standards for Miscellaneous Organic Chemical Manufacturing 8.0 Records and Reports 2 Recordkeeping Requirements ¦ Each applicable record required by Subpart A, and referenced subparts F, G, SS, UU, WW, and GGG (§63.2525(a)) ¦ S/S/M plan ¦ Monitoring parameter measurements, periods of excess emissions or monitor breakdowns, and other requirements in General Provisions ¦ Inspection records ¦ LDAR records ¦ Operating scenarios (§63.2525(b)) ¦ Schedule or log of operating scenarios updated each time a different scenario is put into operation (§63.2525(c)) ¦ Other records specified in §63.2525(d) through (k) 8.0 Records and Reports 79 ------- 3 Operating Scenarios ¦ Description of process and type of process equipment used ¦ Identification of related process vents, emission episodes (if not complying with alternative standard), wastewater PODs, storage tanks, and transfer racks ¦ Applicable control requirements ¦ Control or treatment devices used, and operating and testing conditions ¦ Vents routed to control ¦ Applicable monitoring requirements and parametric levels that assure compliance ¦ Calculations and engineering analyses required to demonstrate compliance 8.0 Records and Reports Precompliance Report ¦ Submit 6 months prior to compliance date of the standard ¦ Should contain: ¦ Alternative monitoring requests ¦ Setting monitoring parameters outside those established during performance test ¦ Periodic verification for control devices with less than 1.0 tpy HAP ¦ Engineering assessment for calculation of uncontrolled process vent emissions and for defining process vents ¦ P2 demonstration summary ¦ Parameters to monitor for wastewater treatment units other than steam strippers rcontmu 8.0 Records and Reports 80 ------- Precompliance Report ¦ Precompliance Report is a preapproval mechanism; the Administrator has 90 days to approve or disapprove ¦ For alternative monitoring and testing approval: ¦ Who can approve? ¦ What guidance is available? 8.0 Records and Reports Setting Monitoring Parameters Outside of Those Established During Performance Tests ¦ Request to set monitoring parameters outside of those established during performance tests, per §§63.999(b)(3)(ii)(A) and 63.2460(c)(3)(i) Example: Incinerator tested at worst-case load. Results indicate 99.9% control efficiency achieved at a temperature of 2200°F. Owner or operator would like to set operating temperature at 1500°F. Cites EPA documentation that this temperature will ensure 98% destruction Control Test operating temperature 2200°F 99.9% Request to set at 1500°F 98% 8.0 Records and Reports 81 ------- Data and Rationale Used to Support Engineering Assessments ¦ Per §63.1257(d)(2)(ii), sources can use modified versions of emissions estimation equations provided: ¦ The facility can demonstrate it has been used to meet other regulatory obligations ¦ The modified equations do not affect applicability or compliance determinations (continued) 8.0 Records and Reports Data and Rationale Used to Support Engineering Assessments i For example, a manufacturer requested approval to use a different heating equation to use up to 1°K below the boiling point, rather than as described in 63.1257(d)(2)(i)(C)(3) i((P,*)(xi)(MW1)) E = — x Ari m / \/ \ 7«0-5>j*X*i) i=l (continued) 8.0 Records and Reports 82 ------- Data and Rationale Used to Support Engineering Assessments ¦ May be a conservative approach for applicability (higher uncontrolled emissions will more likely trigger control requirements), but could bias control efficiency high, which could affect a compliance determination. ¦ EPA's position—not allowed unless the facility can demonstrate that it will not affect the compliance determination. 8.0 Records and Reports One-Time Process Condenser Demonstration 10 A request to skip the process condenser demonstration when the control device is an incinerator that will comply using the 98 percent reduction standard. 98% CE To incineration /V^Vw EPA has not allowed this request because \y improper operation [/\ will ultimately result in higher actual emissions under the percent reduction requirement. 20 ppmv outlet 8.0 Records and Reports 83 ------- Miscellaneous Requests in the Precompliance Report ¦ Request use of compliance extension at §63.6(i)(4) to install control equipment to become a synthetic minor. ¦ EPA response is that they must become synthetic minor by the compliance date. The extension at §63.6(i)(4) is to install equipment to comply with the rule. 8.0 Records and Reports Notification of Compliance Status Report ¦ Results of applicability determinations, emission calculations, or analyses used to identify and quantify HAP emissions from the affected source ¦ Results of emission profiles, performance tests, engineering analyses, design evaluations, flare compliance assessment, inspections and repairs, and calculations used to demonstrate compliance ¦ Descriptions of monitoring devices, monitoring frequencies, and the operating limits established during the initial compliance determinations, including data and calculations to support levels established (continued) 8.0 Records and Reports 84 ------- Notification of Compliance Status Report ¦ All operating scenarios ¦ Descriptions of worst-case operating and/or testing conditions for control devices ¦ Identification of emission points subject to overlapping requirements ¦ Identification of storage tanks for which vapor balancing is used ¦ Records of process units used to create a process unit group 8.0 Records and Reports 14 Content of Compliance Report ¦ Information regarding deviations ¦ Statement that none occurred, if applicable ¦ For deviations that occur where CMS is not used to demonstrate compliance, report ¦ Total operating time of affected source ¦ Number, duration, and cause of deviations ¦ Operating logs for day(s) when deviation occurred (except not required for deviations of standards for equipment leaks) (continued) 8.0 Records and Reports 85 ------- 15 Content of Compliance Report ¦ Information regarding deviations (cont.) - For deviations that occur where CMS is used to demonstrate compliance, report ¦ Date and time each CMS was inoperative ¦ Date, time, and duration when any CEMS was out of control ¦ Date and time each deviation started and stopped, and whether or not it occurred during a period of SSM ¦ Total duration of deviations during the reporting period and as a percent of the total operating time (continued) 8.0 Records and Reports 16 Content of Compliance Report ¦ Information regarding deviations (cont) m For deviations that occur where CMS is used to demonstrate compliance, report (cont.) m The total duration of deviations caused by various types of known causes and those caused by unknown causes ¦ Total deviation of CMS downtime during the reporting period and as a percent of the total operating time ¦ The HAP in the emission stream(s) associated with the deviations ¦ Descriptions of the process units and CMS associated with the deviations (continued) 8.0 Records and Reports 86 ------- 17 Content of Compliance Report ¦ Information regarding deviations (cont.) - For deviations that occur where CMS is used to demonstrate compliance, report (cont) ¦ Operating logs for the days during which deviations occurred ¦ Daily or block averages for the days that deviations occurred ¦ For each CEMS, include a statement that there were no periods it was out-of-control, if applicable (continued) 8.0 Records and Reports Content of Compliance Report ¦ Records of S/S/M during which excess emissions occur ¦ New operating scenarios ¦ Records of process units added to a PUG ¦ Notification of changes to information provided in the NOCS (note that plans for certain changes must be reported at least 60 days before the change) (continued) 8.0 Records and Reports 87 ------- 19 Content of Compliance Report ¦ Information required in periodic reports by referenced subparts. For example, ¦ Reports of LDAR program ¦ Results of tank and waste management unit inspections ¦ CVS bypass and/or car seal breaks ¦ Information about periods of planned routine maintenance of APCD for storage tanks ¦ Delay of repair provisions for heat exchange systems 8.0 Records and Reports 88 ------- 1 National Emission Standards for Miscellaneous Organic Chemical Manufacturing 9.0 Alternative Standard 2 Alternative Standard 9.0 Alternative Standard 89 ------- Alternative Standard ¦ Option for process vents and storage tanks ¦ Emission limits ¦ 20 ppmv for combustion device ¦ 50 ppmv for noncombustion device ¦ 95% reduction alternative for scrubbers after combustion devices 9.0 Alternative Standard Alternative Standard ¦ Compliance demonstration ¦ Use CEMS (QA/QC as specified in 63.2450Q)) ¦ Correct concentrations for supplemental gases ¦ Performance test and CPMS for scrubber if complying with 95% requirement ¦ Average data over operating day ¦ Closed-vent system operation and inspections per section 63.983 9.0 Alternative Standard 90 ------- Alternative Standard ¦ Recordkeeping and reporting ¦ Records of data, deviations, maintenance, calibrations, etc. as specified in 63.10(b) and (c) and 63.2525(h) ¦ Descriptions of monitoring devices, monitoring frequencies, and emission limits (and supporting data) in notification of compliance status report (63.2520(d)(2)(iii)) ¦ Provide information about deviations in compliance report, as specified in 63.2520(e)(5)(iii) 9.0 Alternative Standard 91 ------- [This page intentionally left blank.] 92 ------- National Emission Standards for Miscellaneous Organic Chemical Manufacturing 10.0 Pollution Prevention Alternative 2 Illustration Emissions Waste or Wastewater 93 ------- 3 Pollution Prevention Alternative ¦ Allows compliance with the standards by demonstrating reductions in HAP usage, per unit of product ¦ Uses annual consumption factor ¦ kg HAP / kg product ¦ Reduce the HAP consumption factor by at least 65% from the baseline ¦ Baseline: first 3 years of operation (beginning no earlier than 1994-1996) 10.0 Pollution Prevention Alternative Consumption Factors HAPs (solvent) f Emissions MCPU A ->• Product A Waste or wastewater Determine baseline: 10,000 kg/yr HAP input for 20,000,000 kg/yr product Baseline consumption factor 10,000 kg/yr =0 0005kg/kg 20,000,000 kq/yr Target consumption factor (0.35)(0.0005 kg/kg) = 0.000175 kg/kg Annual consumption factor Must be less than target consumption factor 10.0 Pollution Prevention Alternative 94 ------- Compliance Requirements ¦ P2 Demonstration Summary ¦ Submit with precompliance report ¦ Describes method of tracking consumption and production and provides supporting documentation ¦ Calculate baseline and target HAP and VOC consumption factors ¦ Calculate and record rolling annual factors monthly or every 10 batches ¦ Submit in compliance reports all days when annual factors exceed the target factors 10.0 Pollution Prevention Alternative Exclusions From P2 Alternative ¦ May not apply to HAP generated in process or to HCI generated in combustion control devices ¦ May not merge nondedicated solvent recovery with any other processes ¦ May not merge solvent recovery currently performed offsite with an existing process ¦ May not eliminate steps by transferring them offsite ¦ P2 option not available for processes for which initial startup occurred after April 4, 2002 10.0 Pollution Prevention Alternative 95 ------- Case Study 1. Manufacturer develops baseline using yearly consumption and production rates and averages the HAP consumption over 3 years HAP: methylene chloride Year 1994 1995 1996 MeCI2 usage, kg 24,800 25,960 28,320 Production kg 10,000 11,000 12,000 HAP baseline consumption factor, kg/kg 2.48 2.36 2.36 Average of 3 years 2.40 kg/kg < HAP baseline consumption factor VOC usage, kg 45,600 47,520 48,290 VOC baseline factor, kg/kg 4.56 4.32 4.02 Average of 3 years 4.3 kg/kg < VOC baseline consumption factor (continued) 10.0 Pollution Prevention Alternative Case Study Calculate target consumption factors HAP 2.40 x 0.35 = 0.84 VOC MeCI2 is not a VOC. Therefore, target VOC factor is same as baseline VOC factor. Manufacturer implements pollution prevention techniques to lower the amount of methylene chloride in the process. Calculate annual HAP and VOC consumption factors for the MCPU on a rolling 12-month average. Production during this 12-month period was 20,000 kg. HAP VOC Usage, kg 10,000 84,000 Annual consumption factor, kg/kg 0.5 4.2 10.0 Pollution Prevention Alternative 96 ------- Questions and Answers ¦ Question #1: ¦ If an owner or operator switches from offsite solvent recovery to onsite solvent recovery, can the pollution prevention alternative be used? ¦ Answer #1: ¦ No. This scenario is specifically excluded in the rule because the material originally sent offsite was not really waste. Simply moving the location of the recovery operation does not achieve pollution prevention. 10.0 Pollution Prevention Alternative 97 ------- [This page intentionally left blank.] 98 ------- 1 National Emission Standards for Miscellaneous Organic Chemical Manufacturing 11.0 Comparison of Requirements in Subparts GGG, MMM, and FFFF History MON is third MACT rule to focus on processes that consist primarily of batch operations (following pharmaceuticals production and pesticide active ingredient production) Big picture similarities among the rules Differences are in the details See tables 4 through 13 in appendix B of the workbook 11.0 Comparison of Rules 99 ------- Differences in Applicability ¦ Handling of intermediates ¦ Definitions of "dedicated" process units ¦ HAP that are subject to control 11.0 Comparison of Rules Differences in Standards ¦ Process vents ¦ CPV/BPV in MON versus all process vents ¦ Ways HCI/CI2/HF are handled ¦ Percent reduction requirements ¦ MTVP thresholds for storage tanks ¦ Only MON allows sensory monitoring for equipment leaks from batch processes (continued) 11.0 Comparison of Rules 100 ------- Differences in Standards ¦ Wastewater ¦ Scrubber effluent ¦ Maintenance wastewater ¦ Wastewater from cleaning operations ¦ Treatment options in subpart GGG versus options in the other rules 11.0 Comparison of Rules Differences in Initial Compliance Requirements ¦ Most differences are due to differences in the standards. For example, ¦ Calculate TRE for CPV under MON ¦ Test conditions under MON for CPV ¦ Requirements for fuel gas systems under subparts GGG and MMM ¦ Performance test or design evaluation for all steam strippers under subpart GGG 11.0 Comparison of Rules 101 ------- Differences in Ongoing Compliance 7 i®®# i®®# i Requirements ¦ Numerous relatively minor differences such as: ¦ Accuracy and calibration requirements for CPMS ¦ Monitoring options for catalytic incinerators, regenerative carbon adsorbers, and caustic scrubbers ¦ Options for the alternative standard 11.0 Comparison of Rules Differences in Recordkeeping ¦ All monitoring data versus daily averages ¦ No maintenance wastewater plan for subpart MMM ¦ Certification by offsite treatment facility not required under the MON if the wastewater is to be treated as a hazardous waste ¦ MON requires SSM records of actions taken only if excess emissions occur 11.0 Comparison of Rules 102 ------- Differences in Reporting ¦ SSM reporting for the MON ¦ Submit records of actions taken and a description of malfunctions only if excess emissions occur ¦ No immediate SSM report requirement ¦ Include the applicable records in the compliance report (continued) 11.0 Comparison of Rules Differences in Reporting ¦ Compliance reports ¦ Start date first reporting period ¦ Submittal schedule ¦ Language/structure of requirements ¦ Notification of process change ¦ MON specifies that changes from Group 2 to Group 1 must be documented at least 60 days before the planned change 11.0 Comparison of Rules 103 ------- [This page intentionally left blank.] 104 ------- 1 National Emission Standards for Miscellaneous Organic Chemical Manufacturing 12.0 Review of Available Implementation Tools 2 Available Implementation Tools ¦ http://www.epa.gov/ttn/atw/mon/monpg.html ¦ Rule information (all FR notices) ¦ http://www.gpoaccess.gov/cfr/index.html ¦ Code of Federal Regulations (CFR) ¦ http://www.netionline.com (at the site you must logon, select the classrooms, select AIR206, enter the classroom, and select reference materials under "course activities") ¦ EPA 305-B-04-001 (Report with case studies illustrating compliance options for nondedicated equipment subject to the MON, PAI, and Pharmaceuticals MACT rules) ¦ MON response to comments document ¦ HON wastewater inspector training course ¦ Draft EIIP chapter on emission estimation procedures for batch chemical manufacturing operations 12.0 Review of Available Implementation Tools 105 ------- 3 Available Implementation Tools ¦ http://www.epa.gov/reg3artd/airregulations/delegate/appdet.pdf ¦ How to Review and Issue Clean Air Act Applicability Determinations and Alternative Monitoring (Attachment 1 is July 10, 1998 memorandum from John Seitz delegating Part 63 General Provisions authority to State and local agencies) 12.0 Review of Available Implementation Tools 106 ------- 1 National Emission Standards for Miscellaneous Organic Chemical Manufacturing 13.0 Wrap-Up Questions and Answers 107 ------- |