EPA Course Number AIR 206
Miscellaneous Organic
Chemical Manu
MACT Training
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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
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11
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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
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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
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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
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2
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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27
Equipment Leaks
3.0 Applicability
¦ Piping components
in 5% wt organic
HAP service.
28
Transfer Operations
3.0 Applicability
32
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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
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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
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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
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36
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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
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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
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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
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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
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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
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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
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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
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15
Design Steam Stripper
- Steam
> 0.04 kgM WW feed
4.0 Emission Standards
16
4.0 Emission Standards
44
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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
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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
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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
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48
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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
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3
Case Study No. 1
5.0 Case Studies
4
Case Study No. 2
5.0 Case Studies
50
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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
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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
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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
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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
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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
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[This page intentionally left blank.]
70
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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
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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
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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
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1
National Emission Standards for Miscellaneous
Organic Chemical Manufacturing
9.0 Alternative Standard
2
Alternative Standard
9.0 Alternative Standard
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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
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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
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National Emission Standards for Miscellaneous
Organic Chemical Manufacturing
10.0 Pollution Prevention
Alternative
2
Illustration
Emissions
Waste or Wastewater
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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National Emission Standards for Miscellaneous
Organic Chemical Manufacturing
13.0 Wrap-Up Questions
and Answers
107
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