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


-------