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Control of Volatile Organic Compounds Emissions from Manufacturing

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esuIts are for a butadiene plant, and butadiene <strong>of</strong>fgas tends to be<br />

1 ean in VOC. Therefore, the test results support the achievability <strong>of</strong><br />

98 percent VOC destruction efficiency by a fie1 d incinerator designed<br />

to provide good mixing, even for streams with low VOC concentrations.<br />

. The EPA tests at Union Carbide and Rohm and Haas were for residence<br />

times greater than 0.75 second. However, theoretical calculations<br />

show that greater efficiency would be achieved at 870°C (1600°F) and<br />

0.75 second than at the longer residence times but lower temperatures<br />

represented in these two tests. The data on which the achieveability<br />

<strong>of</strong> the 98 percent VOC destruction efficiency is based is test data for<br />

similar control systems: thermal incineration at various residence<br />

times and temperatures. If 98 percent VOC reduction can be achieved<br />

at a lower temperature, then according to kinetic theory it can certainly<br />

be achieved at 870°C (1600°F), other conditions being equal.<br />

A control efficiency <strong>of</strong> 98 percent VOC reduction, or 20 pprn by<br />

compound, whichever is less stringent, has been considered to be the<br />

acheivable control level for a1 1 new inci nerators, considering available<br />

technology, cost and energy use.14 This is based on incinerator operation<br />

at 870°C (1600°F) and on adjustment <strong>of</strong> the incinerator after start-up.<br />

The 20 pprn (by compound) level was chosen after three different incinerator<br />

outlet VOC concentrations, 10 ppm, 20 ppm, and 30 ppm, were analyzed.<br />

In addition to the incinerator tests cited earlier in this Appendix,<br />

data <strong>from</strong> over 200 tests by Los Angeles County (L.A.) on various waste<br />

gas incinerators were considered in choosing the 20 pprn level. However,<br />

the usefulness <strong>of</strong> the L.A. data was limited by three factors: (1) the<br />

incinerators tested are small units designed over a decade ago; (2) the<br />

units were designed, primarily, for use on coating operations; and<br />

(3) the units were designed to meet a regulation requiring only 90 percent<br />

VOC reduct ion.<br />

The 10 ppmv level was judged to be too stringent. Two <strong>of</strong> the six<br />

non L.A. tests and 65 percent <strong>of</strong> the L.A. tests fail this criteria.<br />

consideration was given to the fact that many <strong>of</strong> the units tested were<br />

below 870°C (1600°F) and did not have good mixing. However, due to<br />

the large percent that failed, it is judged that even with higher<br />

temperatures and moderate adjustment, a large number <strong>of</strong> units would<br />

still not meet the 10 ppmv level.<br />

D-39

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