Date:
March
20,
2003
Subject:
MACT
Floor
for
Soluble
HAP
in
Wastewater
Streams
From:
David
Randall
To:
MON
Project
file
I.
Introduction
The
MACT
floor
for
wastewater
was
originally
based
on
an
evaluation
of
all
wastewater
streams
in
a
single
group.
1
Public
comments
on
the
proposed
rule
suggested
that
wastewater
streams
that
contain
only
soluble
HAP
should
be
considered
separately
from
all
other
streams
(
i.
e.,
those
that
contain
partially
soluble
HAP
or
a
mix
of
partially
soluble
and
soluble
HAP).
This
memorandum
presents
the
results
of
an
analysis
of
wastewater
streams
that
contain
only
soluble
HAP
compounds.
The
results
of
an
analysis
of
streams
that
contain
only
partially
soluble
HAP
or
a
mix
of
HAP
is
presented
in
a
separate
memorandum.
2
II.
Discussion
Of
the
364
wastewater
streams
in
our
database,
172
streams
at
33
facilities
contain
only
soluble
HAP
compounds.
Methanol
is
the
soluble
HAP
in
161
of
the
streams;
the
remaining
11
streams
contain
acetonitrile,
triethylamine,
and/
or
ethyl
sulfate.
The
MACT
floor
level
of
performance
for
these
streams
is
management
and
treatment
(
i.
e.,
"
control")
that
is
consistent
with
the
HON
requirements
because
these
procedures
are
implemented
by
5
of
the
33
facilities
for
all
of
their
wastewater
streams
that
contain
soluble
HAP.
In
the
response
to
the
ICR,
a
sixth
facility
(#
92)
also
reported
using
HON­
equivalent
treatment,
but
the
facility
does
not
implement
HON­
equivalent
management
procedures
because
the
sewers
at
this
facility
are
not
completely
closed.
3
The
soluble
HAP
concentration
(
i.
e.,
methanol
at
each
of
the
five,
top
performing
facilities)
was
selected
as
the
parameter
on
which
to
rank
the
facilities.
Control
of
a
stream
with
a
low
methanol
concentration
is
considered
more
stringent
than
control
of
a
stream
with
a
higher
concentration.
The
lowest
methanol
concentration
in
a
stream
at
each
facility
was
selected
as
a
threshold
for
that
facility,
and
facilities
were
then
ranked
based
on
this
threshold
methanol
concentration.
Table
1
summarizes
the
results.
2
Table
1.
Wastewater
Streams
that
Contain
Soluble
HAP
Facility
Stream
ID
Methanol
concentration,
ppmw
Flow
rate
HAP
load,
tpy
gal/
yr
lpma
106
1
4,500
44,366
0.32
1,663
2
9,800
241,700
1.74
19,730
3
102,000
23,868
0.17
20,279
4
102,000
17,824
0.13
15,144
5
132,000
1,554
0.011
1,709
65
1
<
30,000
N/
A
N/
A
N/
A
74
1
30,000
175,000
1.26
43,731
2
30,000
7,500
0.05
1,874
138
1
150,000
7,167
0.05
8,955
2
150,000
1,766
0.013
2,207
3
150,000
30,498
0.22
38,106
4
200,000
153,164
1.1
255,171
1
1
200,000
17,000b
44.7
7,300,000
a
The
flow
in
lpm
is
normalized
over
8,760
hr/
yr.
b
The
flow
rate
for
this
facility
is
in
gal/
d.
N/
A
means
not
available.

The
mean
and
median
methanol
threshold
values
for
the
top
performing
five
facilities
are
80,000
ppmw
and
30,000
ppmw,
respectively.
We
believe
the
median
better
represents
the
central
tendency
of
the
data
because
the
median
better
represents
characteristics
of
both
the
top
performing
facilities
and
the
industry
as
a
whole
(
i.
e.,
only
20
of
the
172
streams
have
concentrations
greater
than
or
equal
to
80,000
ppmw).
All
of
the
13
streams
at
the
top
performing
facilities
have
soluble
HAP
loads
of
at
least
1,700
pounds
per
year,
or
about
1
ton
per
year
(
tpy).
Therefore,
we
would
set
the
existing­
source
floor
for
wastewater
streams
that
contain
soluble
HAP
as
HON­
equivalent
management
and
treatment
for
streams
that
contain

30,000
ppmw
and
a
soluble
HAP
load

1
ton/
yr.
The
best­
performing
source
is
controlling
a
stream
containing
soluble
HAP
at
a
concentration
of
4,500
ppmw
and
a
load
of
approximately
1
tpy.
Therefore,
we
would
set
the
floor
for
new
sources
as
HON­
equivalent
management
and
treatment
for
streams
that
contain
soluble
HAP
at
a
concentration

4,500
ppmw
and
at
a
load

1
tpy.
3
III.
References
1.
Memorandum
from
D.
Randall
and
J.
Fields,
MRI,
to
Miscellaneous
Organic
NESHAP
Project
File.
MACT
Floor,
Regulatory
Alternative,
and
Impacts
for
Wastewater
at
Chemical
Manufacturing
Facilities.
May
17,
2000.

2.
Memorandum
from
B.
Shine,
North
State
Engineering,
Inc.,
to
MON
Project
File.
MACT
Floor
for
Partially
Soluble
and
Mixed
HAP
in
Wastewater
Streams.
April
30,
2003.

3.
Telecon.
B.
Shine,
North
State
Engineering,
Inc.,
with
J.
Jones,
Reilly
Industries.
June
20,
2002.
Management
and
treatment
of
wastewater
containing
methanol.
