Control of Volatile Organic Compounds Emissions from Manufacturing

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The 20 pprn level was judged to be attainable. All of the non L.A. I I and the majority of the LA. units met this criteria. There was concern over the. large number of L.A. tests that failid, i .e. 43 percent. However, two factors outweighed this concern. First, all of the non L.A. units met the criteria. This is significant since, though the L.A. units represent many tests, they represent the same basic design. They all are small units designed over a decade ago to meet a ruie for 90 percent reduction. They are * I # ? I did so due to common factors and do not represent a widespread inability I Second, the difference between 65 percent failing 10 ppmv and , 43 percent failing 20 ppm is larger than a direct comparison of the ' percentages would reveal. At 20 ppm, not only did fewer units fail, but those that did miss the criteria did so by a smaller margin and would require less adjustment. Dropping the criteria from 10 pprn to ' 20 pprn drops the failure rate by 20 percent, but is judged to drop the overall time and cost for adjustment by over 50 percent. I adjustment effort for the worst case is considered. The crucial point is how close a 10 pprn level pushes actual field unit efficiencies to those of the lab unit. Lab unit results for complete backmixing indicate that a 10 pprn level would force field units to almost match lab unit mixing. A less stringent 20 pprn level i~ncreasesthe margin allowed for nonideal incinerator operation, especially for the worst improve mixing enough for field units to approach lab unit efficiencies, a drop from 10 pprn to 20 pprn hay decrease costs .to improve mixing in the worst case by an order of magnitude. I The 30 pprn level was judged too lenient. The only data indicating such a low efficiencv was from L.A. All other data shbwed 20 Dpm. showed that moderate adjustment can increase efficiency. In addition, I the L.A. units were judged to have poor mixing. The mixing deficienkies I I
weve large enough to mask the effect of increasing temperature. Thus, it is judged that 20 ppm could be reached with moderate adjustment and that a 30 ppm level would represent a criteria not based on the best available control techno1 ogy cost, energy, and environmental impact.
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dine Series Emission Standards and
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TABLE OF CONTENTS ................
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D.2 THERMAL INCINERATOR VOC EMISSIO
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LIST OF TABLES End Uses of Polyprop
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Typical Inci nerator Parameters for
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LIST OF FIGURES Simplified Process
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2.1 INTRODUCTION 2.0 PROCESS AND PO
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Polypropylene resins are supplied i
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Table 2-2. POLYPROPYLENE (PP) PLANT
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Fxlrus loll l'el lciiz ltlq Methano
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Tab1e 2-3. CHARACTER1 STICS OF VENT
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in addition to C3 and process dilue
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used in maki fig shopping bags. For
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I 2 CTC E%% PCS A wrcc 2 C W P U iZ
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Table '2-6. CHARACTERISTICS OF VENT
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A1 though polymers with molecular w
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A - . STYREL +VACUUH SYSTEM (8) (9)
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Tab1e 2-8. CHARACTERISTICS OF VENT
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3.0 EMISSION CONTROL TECHNIQUES Vol
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that they require for complete comb
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PILOT AND CENTER mAlri JET ELNATION
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Ground flares are usually enclosed
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flare was operated with from 130 t
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w Table 3-1 . FLARE EMISSIONS STUDI
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has become less common during the p
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Waste Gas- Stack Section Figure 3-3
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chamber temperatures ranging from 7
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= alti-
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control can be used. Any breakdown
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and, in some cases, reused in the p
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are immiscible with the coolant. Th
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3.2 .I .1 Condenser Control Efficie
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VOC -*, VENT TO VcntS~ AmOSPnERE Fi
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ABSORBlHG UQUlD WITH VOC OUT To Dis
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REFERENCES FOR CHAPTER 3 Lee, K.C.,
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Reference 24, p. 34. Key, J . A. Or
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4.1 INTRODUCTION 4.0 ENVIRONME NTAL
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Table 4-1. UNCONTROLLED EMISSION RA
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C Table 4-3. UNCONTROLLED EMISSION
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the results and an analysis of cost
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Tab1e 4-4. MODEL PLANT ENVIRONMENTA
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Tab1e 4-5. ADDITIONAL ENERGY REQUIR
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-- Table 4-7. ADDITIONAL ENERGY REQ
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5.0 CONTROL COST ANALYSIS OF RACT T
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m I W 1. Simple. continuous uanuall
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Tab1e 5-2, INSTALLATION COST FACTOR
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FOOTNOTES FOR Tab1 e 5-3 a Incl ude
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In order to prevent an explosion ha
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analysis of the Distil 1 ation NSPS
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Install ed piping and ducting costs
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estimated by the same procedure as
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.ble 5-4. POLYPROPYLENE MODEL PLANT
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Table 5-6. POLYSTYRENE MODEL PLANT
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emitters, while other dryers, e.g.,
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Table 5-8. COST ANALYSIS FOR POLYPR
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other dryers may have higher or low
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Table 5-11. COST ANALYSIS FOR HIGH
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Table 5-12. COST ANALYSIS FOR POLYS
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Polymer Table 5-15. COST EFFECTIVEN
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effectiveness of polystyrene contro
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EEA. Distil lation NSPS Pi peline C
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APPENDIX A LIST OF COMFIENJERS
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APPENDIX B COMMENTS OW MAY 1982 DRA
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Mr. J. R. Famet Page 2 EPA June 16,
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October 19, 1981 Attachment to June
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Be The mocial plant does nst incEud
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1000 BRAZOS, SUITE 200, AUSTIN, TEX
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our previous comments the TCC quest
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. . . . " . . 5. Emission Reduction
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REFERENCES Texas Chemical Council t
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' Y !. Jack R. Faner o The A~ency h
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NATION& AIR POLLUTION CONTROL Y COM
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" DEFINITION OF INCINERATION AS MCT
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-5- IN SUWRYj THE AGENCY, BY RELYIN
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STRUMS WITH RELATIVELY STABLE FLOW
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1 I CoHPlTIONS OF 10 TIMES NORMAL S
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I 1 I - gU - I I n G PROPO.SED INCI
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The use of data from the CTG for ai
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Mr. Jack R. Farmer, Chief July 19,
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APPENDIX C MAJOR ISSUES AND RESPONS
Page 171 and 172: generally for large volume, variabl
Page 173 and 174: control devices, such as thermal an
Page 175 and 176: modification or rep1 acement, based
Page 177 and 178: epresent excellent agreement for su
Page 179 and 180: Response: The following responses a
Page 181: processes (e.g ., polypropylene and
Page 184 and 185: I I I I The purpose of this appendi
Page 187 and 188: Data collection continued for each
Page 189 and 190: Test . Number ~104Velocity (scfm) (
Page 191 and 192: found for tests of incinerators at
Page 194 and 195: 7' Tab1e 0-4. TYPICAL INCINERATOR P
Page 196 and 197: I I I I I l l I averages for the mo
Page 198 and 199: Table D-5. ARC0 POLYMERS INCINERATO
Page 200 and 201: Thempies Spaced Evenly Across the T
Page 202 and 203: probe for the temperature while a w
Page 204 and 205: The total installed capital cost of
Page 206 and 207: 3. Test Results - VOC destruction e
Page 208 and 209: Figure D-4. Petro-Tex 0x0 unit inci
Page 210 and 211: air to reduce the air flow through
Page 213 and 214: HEAT EXCHANGE1 NOTE: From Exchanger
Page 215 and 216: ' organic carbon. chromatography. T
Page 217 and 218: D.3 VAPOR RECOVERY SYSTEM VOC EMISS
Page 219: However, the calculations assume pe
Page 224 and 225: REFERENCES FOR APPENDIX D McDaniel,
Page 227 and 228: APPENDIX E: DETAILED DESIGN AND COS
Page 229 and 230: characteristics: volumetric flow ra
Page 231 and 232: Footnotes for Table E-1 astandad co
Page 233 and 234: sources to the flare header were as
Page 235: Flare Tip Diameter (in.) Figure E-1
Page 238 and 239: Table E-3. CAPITAL AND ANNUAL OPERA
Page 240 and 241: Footnotes for Table E-3 aFluidic se
Page 242 and 243: Tab1e E-4. WtORKSHEET FOR CALCULATI
Page 244 and 245: excess air for oxygen in the waste
Page 246 and 247: Table E-6. PROCEDURE TO DESIGN THER
Page 248: I I a plant had a use for it, heat
Page 252 and 253: Footnotes for Table E-7 Wpdated usi
Page 255 and 256: Table E-8. OPERATING PARAMETERS AND
Page 257: TABLE E-9. GAS PARAMETERS USED FOR
Page 260 and 261: ~ 1 1 I I l 1 I I represent June 19
Page 262 and 263: Tabl e -11 CAPITAL AND . IERATIONG
Page 264 and 265: $0.335/scfm for units with no heat
Page 266 and 267: Table E-12. PROCEDURE TO CALCULATE
Page 268 and 269: Footnotes for Table E-12 (Concluded
Page 270 and 271: i m- Table E-13. PROCEDURE TO CALCU
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I - I - 1 A nnnrrn~~nrc rn rnl PIII
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Table E-15. CAPITAL AND ANNUAL OPER
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aUpdated using Chemical ~ I nneiri
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Condenser ~y2 ! ;tern Area (ftL) Fi
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ased on an equation in the Chemical
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m Equi p ent Type Check Valves Gate
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- 1/8 - - Table E-20. INSTALLED DUC
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Reference 12, p. 6-3 and 6-4. Refer
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APPENDIX F CALCULATION OF UNCONTROL
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Table F-1 . INITIAL EMISSION CHARAC
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Table F12. SUMMARY OF ANNUAL COSTS,
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= the difference between the operat
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I 8 - a F.Z. 1 Sty rene-i n-Steam m
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(9 CE = AC - (0.9 ~ CDnA ~ x eRC) d
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Substituting the values from Table
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Table 7. EXPONENTS USED FOR CONDENS
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Within Line Table F-8. STYRENE'-IN-
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Control of Volatile Organic Compounds Emissions from Manufacturing

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