Date:
June
30,
2003
Subject:
Revised
Environmental
and
Energy
Impacts
for
Chemical
Manufacturing
Facilities
Miscellaneous
Organic
NESHAP
From:
Melissa
Icenhour
To:
MON
Project
File
I.
Introduction
The
purpose
of
this
memorandum
is
to
present
the
environmental
and
energy
impacts
for
regulatory
alternatives
developed
for
the
national
emissions
standards
for
hazardous
air
pollutants
(
NESHAP)
for
the
miscellaneous
organic
chemical
manufacturing
source
category.
A
previous
analysis,
detailed
in
a
memo
dated
July
31,
2000,
explains
the
approach
used
to
estimate
these
impacts.
1
This
memo
presents
the
differences
between
the
two
analyses.
The
impacts
include:
(
1)
primary
air
impacts;
(
2)
secondary
impacts,
including
air,
water,
and
solid
waste;
and
(
3)
fuel
and
electricity
impacts.
The
impacts
are
presented
for
five
types
of
emission
points
in
the
source
category
(
process
vents,
equipment
leaks,
storage
tanks,
wastewater,
and
transfer
operations).

II.
Basis
for
Impacts
Analysis
The
impacts
are
based
on
the
use
of
control
devices
or
other
techniques
to
comply
with
the
MACT
floor
or
regulatory
alternatives
as
summarized
in
Table
1.
A
new
analysis
for
hydrogen
halide
and
halogen
emissions
from
process
vents
was
conducted
and
the
analysis
of
equipment
leaks
was
changed
slightly.
Previously,
a
Leak
Detection
and
Repair
Program
(
LDAR)
modeled
after
the
LDAR
program
from
Subpart
UU
was
required
for
all
sources
of
equipment
leaks.
This
analysis
assumes
that
the
LDAR
program
from
Subpart
UU
is
required
only
for
processes
with
at
least
one
continuous
process
vent,
while
the
LDAR
program
from
Subpart
TT
is
required
for
all
other
processes.
All
other
control
techniques
have
remained
the
same
since
the
previous
analysis.
2
Table
1.
Assumed
Control
Device
or
Approach
to
Comply
with
the
MACT
Floor
or
Regulatory
Alternative
Emission
source
type
Control
device
or
approach
Equipment
leaks
LDAR
program
from
Subpart
UU
for
all
processes
with
at
least
one
continuous
process
vent
and
subpart
TT
for
all
other
processes
Horizontal
storage
tanks
Condenser
Process
vents
Thermal
incinerator
or
flare,
whichever
has
the
lowest
cost
Process
vents
(
HF,
HCl,
and
Cl2
emissions)
Gas
absorber
Transfer
operations
Nonea
Vertical
storage
tanks
Internal
floating
roof
Wastewater
systems
Steam
stripper
a
Emissions
are
already
controlled
to
level
of
MACT
floor,
and
no
regulatory
alternative
was
developed.

III.
Primary
Impacts
Primary
air
impacts
consist
of
the
reduction
in
HAP
emissions
from
the
baseline
level
that
is
directly
attributable
to
the
selected
standard.
The
baseline
emissions
and
primary
impacts
for
the
miscellaneous
organic
chemical
manufacturing
source
category
are
presented
in
Table
2.
The
baseline
emissions
are
for
emission
streams
that
meet
the
thresholds
for
control
(
e.
g.,
for
the
MACT
floor,
baseline
includes
emissions
from
processes
with
collective
batch
process
vent
emissions
greater
than
10,000
pounds
per
year
and
storage
tanks
larger
than
10,000
gallons
containing
material
with
a
HAP
partial
pressure
greater
than
1.0
pound
per
square
inch).
The
overall
reductions
for
the
MACT
floor
decreased
from
28,000
Megagrams
per
year
(
Mg/
yr)
to
15,000
Mg/
yr.
2­
5
The
most
significant
changes
were
in
the
wastewater
and
equipment
leak
analyses.
For
wastewater,
both
the
baseline
emissions
and
the
emission
reductions
are
lower
because
changes
in
the
MACT
floor
analysis
reduced
the
number
of
affected
wastewater
streams.
The
revised
equipment
leak
analysis
includes
new
emission
rates
and
corrections
to
database
regarding
the
LDAR
programs
being
used
at
surveyed
facilities
that
resulted
in
a
new
MACT
floor.
These
changes
also
resulted
in
lower
baseline
emissions
and
lower
emission
reductions
at
the
MACT
floor.
A
regulatory
alternative
was
also
developed
for
equipment
leaks
because
the
new
MACT
floor
is
not
the
most
stringent
known
approach.
3
Table
2.
Summary
of
Primary
Impacts
for
Chemical
Manufacturing
Emission
point
MACT
Floor
Regulatory
Alternative
Emission
reduction
for
the
final
standard,
Mg/
yr
Baseline
emissions,
Mg/
yr
Emission
reductions
from
baseline,
Mg/
yr
Baseline
emissions,
Mg/
yr
Emission
reductions
from
baseline,
Mg/
yr
Continuous
process
vents
3,704
2,973
4,145
3,402
2,973
Batch
process
vents
6,773
6,291
6,923
6,436
6,291
Process
vents
with
HF,
HCl,
Cl2
emissions
106
94
107
95
94
Equipment
leaks
5,145
2,615
5,145
2,788
2,788
Storage
tanks
287
261
N/
A
290
261
Wastewater
5,907
2,837
6,334
2,996
2,837
Transfer
operations
N/
A
0
N/
A
0
0
TOTALS
21,922
15,000
22,654
16,007
15,244
IV.
Secondary
Environmental
Impacts
Secondary
environmental
impacts
consist
of
any
adverse
or
beneficial
environmental
impacts
other
than
the
primary
impacts
described
in
Section
III
of
this
memorandum.
The
secondary
impacts
are
indirect
or
induced
air,
water,
or
solid
waste
impacts
that
result
from
the
operation
of
the
control
system
that
controls
HAP
emissions.
Use
of
most
control
systems
described
in
Section
II
of
this
memorandum
will
cause
secondary
air
impacts;
secondary
water
and
solid
waste
impacts,
however,
are
expected
to
be
minimal.
The
secondary
air,
water,
and
solid
waste
impacts
are
discussed
in
the
sections
below.

Secondary
air
impacts
consist
of:
(
1)
generation
of
emissions
as
the
byproducts
of
fuel
combustion
needed
to
operate
the
control
devices
either
directly
or
to
generate
electricity
or
steam
and
(
2)
reductions
in
emissions
of
VOC
compounds.
These
impacts
were
calculated
according
to
the
previous
analysis.
1
A
summary
of
the
estimated
secondary
air
impacts
that
are
generated
for
each
of
the
five
types
of
emission
points
in
each
source
category
is
presented
in
Table
3.
Secondary
air
impacts
are
generated
from
operation
of
thermal
incinerators
and
flares
for
process
vents,
gas
absorbers
for
HCl,
HF,
and
Cl
2
emissions
from
process
vents,
condensers
for
horizontal
storage
tanks,
and
steam
strippers
for
wastewater
streams.
No
secondary
air
impacts
are
associated
with
the
use
of
floating
roofs
to
control
emissions
from
vertical
storage
tanks
or
with
the
implementation
of
an
LDAR
program.
4
Table
3.
Summary
of
Secondary
Air
Impacts
Emission
source
type
Secondary
air
impacts,
Mg/
yr
MACT
floor
Regulatory
Alternative
CO
a
NOX
b
SO2
c
PM10
d
CO
a
NOX
b
SO2
c
PM10
d
Equipment
leaks
0
0
0
0
0
0
0
0
Process
vents
(
organic
HAP)
1.
Continuous
vents
2.
Batch
vents
68.07
48.67
244.56
173.49
148.61
113.57
11.86
8.47
123.65
57.34
438.64
203.07
299.88
140.90
21.50
9.97
Process
vents
(
HCl,
HF,
Cl2)
0.11
0.31
0.77
0.02
0.14
0.38
0.94
0.02
Storage
tanks
0.08
0.23
0.55
0.01
0.09
0.26
0.64
0.02
Transfer
operations
0
0
0
0
0
0
0
0
Wastewater
6.80
25.84
7.42
1.20
7.02
26.67
7.66
1.23
TOTALS
123.73
444.43
270.92
21.56
188.24
669.02
450.02
32.74
a
The
CO
emissions
were
estimated
using
AP­
42
emission
factors
of
5
lb/
ton
of
coal
and
35
lb/
106ft3of
natural
gas.
b
The
NOX
emissions
were
estimated
using
AP­
42
emission
factors
of
13.7
lb
NOX/
ton
of
coal
and
140
lb
NOX/
106
ft3
of
natural
gas.
c
The
SO2
emissions
were
estimated
using
the
NSPS
for
coal­
fired
utility
boilers
of
1.2
lb
SO2/
106BTU
and
the
AP­
42
emission
factor
of
0.6
lb
SO2/
106
ft3
of
natural
gas.
d
The
PM10
emissions
were
estimated
using
the
NSPS
for
coal­
fired
utility
boilers
of
0.03
lb
PM10/
106
BTU
and
the
AP­
42
emission
factor
of
6.2
lb
PM10/
106
ft3
of
natural
gas.

Overall
secondary
impacts
for
the
MACT
floor
have
decreased
since
the
previous
analysis.
The
impacts
from
storage
tanks,
transfer
operations,
equipment
leaks,
and
organic
emissions
from
batch
process
vents
have
remained
basically
the
same.
The
impacts
of
controlling
certain
inorganic
emissions
from
process
vents
were
added,
but
the
amount
was
small
compared
to
the
decrease
in
impacts
from
continuous
process
vents
and
wastewater
streams.

The
decrease
in
secondary
impacts
is
due
to
MACT
floor
changes
made
to
the
analyses
of
continuous
process
vents
and
wastewater
streams.
For
continuous
process
vents,
the
TRE
cutoff
was
changed
from
2.6
to
1.9.
As
a
result,
eleven
vents
with
large
emission
rates
that
would
have
required
more
energy
to
operate
were
excluded.
In
the
case
of
the
wastewater
streams,
the
change
in
MACT
floor
criteria
excluded
59
streams
from
the
original
analysis
and
only
added
30
streams
that
were
not
included
in
the
original
analysis.

Overall
secondary
impacts
for
the
regulatory
alternative
have
also
decreased,
primarily
because
of
the
changes
to
the
wastewater
analysis
described
above.
Sulfur
dioxide
emissions
from
continuous
process
vents,
however,
increased.
This
increase
is
due
to
corrections
in
the
calculations
for
four
continuous
process
vents
at
two
facilities
that
increased
the
amount
of
electricity
required
while
decreasing
the
amount
of
natural
gas
required.
4
Most
of
the
SO
2
emissions
are
from
coal
combustion,
but
the
other
pollutants
are
more
evenly
split
between
coal
and
natural
gas
combustion.
Thus,
increasing
the
coal
combustion
has
a
greater
effect
on
the
SO
2
emissions
than
on
other
pollutants.
5
As
in
the
previous
analysis,
secondary
water
impacts
and
secondary
solid
waste
impacts
are
expected
to
be
minimal.
1
The
primary
adverse
secondary
water
impacts
would
be
from
the
gas
absorbers
used
to
control
HCl,
HF,
and
Cl
2
emissions
from
process
vents.
According
to
estimates,
2.4
million
gallons
of
wastewater
would
be
generated
by
the
gas
absorbers
for
the
MACT
floor
and
2.8
millions
gallons
of
wastewater
for
the
Regulatory
Alternative.

There
may
also
be
solid
waste
impacts
if
condensed
steam
and
pollutants
from
the
steam
stripper
used
to
treat
wastewater
cannot
be
reused.
Small
amounts
of
wastewater
in
the
form
of
blowdown
from
the
cooling
water
system
for
the
condenser
will
also
be
generated.

V.
Energy
Impacts
Energy
impacts
consist
of
the
fuel
(
natural
gas)
needed
to
operate
combustion­
based
control
devices
that
are
used
to
comply
with
the
regulatory
alternatives.
It
also
includes
the
amount
of
fuel
(
coal
or
natural
gas)
needed
to
generate
electricity
and
steam
to
operate
the
control
devices.
The
estimated
steam,
electricity,
and
fuel
impacts
for
each
of
the
five
types
of
emission
points
in
each
source
category
are
presented
in
Table
4.
In
each
case,
the
impacts
are
based
on
the
total
amount
of
steam,
electricity,
or
fuel
needed
to
operate
the
control
devices;
this
approach
overestimates
the
impacts
because
electricity
and
fuel
needed
for
any
existing,
less
efficient
control
devices
are
assumed
to
be
negligible.
The
assumptions
used
for
the
electricity
and
fuel
impacts
are
discussed
in
the
previous
analysis.
1
6
Table
4.
Summary
of
Energy
Impacts
Emission
source
type
MACT
floor
Regulatory
Alternative
Increase
in
electricity
use,

kWh/
yr
Increase
in
steam
use,

lb/
yr
Increase
in
fuel
energy,
BTU/
yr
Increase
in
electricity
use,

kWh/
yr
Increase
in
steam
use,

lb/
yr
Increase
in
fuel
energy,
BTU/
yr
To
generate
electricity
Auxiliary
fuel
for
incineratio
n
To
produce
steam
Total
To
generate
electricity
Auxiliary
fuel
for
incineratio
n
To
produce
steam
Total
Equipment
Leaks
0.00e+
00
0.00e+
00
0.00e+
00
0.00e+
00
0.00e+
00
0.00e+
00
0.00e+
00
0.00e+
00
0.00e+
00
0.00e+
00
0.00e+
00
0.00e+
00
Continuous
Process
Vents
(
organic)
2.78e+
07
2.57e+
08
2.72e+
11
2.52e+
12
3.79e+
11
3.17e+
12
5.62e+
07
3.40e+
08
5.48e+
11
4.49e+
12
5.01e+
11
5.54e+
12
Batch
Process
Vents
(
organic)
2.13e+
07
1.75e+
08
2.08e+
11
1.75e+
12
2.59e+
11
2.21e+
12
2.64e+
07
1.81e+
08
2.58e+
11
2.03e+
12
2.68e+
11
2.55e+
12
Process
Vents
(
HCl,

HF,
Cl2)
1.45e+
05
0
1.42e+
09
0
0
1.42e+
09
1.76e+
05
0
1.72e+
09
0
0
1.72e+
09
Storage
Tanks
1.04e+
05
0
1.02e+
09
0
0
1.02e+
09
1.20e+
05
0
1.17e+
09
0
0
1.17e+
09
Transfer
Operations
0
0
0
0
0
0
0
0
0
0
0
0
Wastewater
1.38e+
06
2.44e+
08
1.34e+
10
0
3.60e+
11
3.73e+
11
1.42e+
06
2.52e+
08
1.39e+
10
0
3.71e+
11
3.85e+
11
TOTAL
5.07e+
07
6.76e+
08
4.95e+
11
4.27e+
12
9.98e+
11
5.76e+
12
8.43e+
07
7.73e+
08
8.23e+
11
6.52e+
12
1.14e+
12
8.48e+
12
7
VI.
References
1.
Memorandum
from
J.
Fields,
B.
Shine,
and
D.
Randall,
MRI,
to
MON
Project
File.
July
31,
2000.
Environmental
and
Energy
Impacts
for
the
Miscellaneous
Organic
NESHAP.

2.
Memorandum
from
M.
Icenhour,
RTI
International,
to
MON
Project
File.
May
6,
2003.
Cost
Impacts
for
Wastewater
at
Chemical
Manufacturing
Facilities
for
Promulgation
Package
3.
Memorandum
from
B.
Shine,
North
State
Engineering,
and
M.
Icenhour
and
D.
Randall,
RTI
International,
to
MON
Project
File.
May
5,
2003.
Revised
MACT
Floor,
Regulatory
Alternatives,
and
Nationwide
Impacts
for
Equipment
Leaks
at
Chemical
Manufacturing
Facilities.

4.
Memorandum
from
D.
Randall,
RTI
International,
to
MON
Project
File.
May
6,
2003.
Revised
MACT
Floor
and
Cost
Impacts
for
Continuous
Process
Vents.

5.
Memorandum
from
M.
Icenhour,
RTI
International,
to
MON
Project
File.
May
19,
2003.
Determination
of
MACT
Floor,
Regulatory
Alternative,
and
Nationwide
Impacts
for
process
Vents
with
Hydrogen
Halide
and
Halogen
HAP
Emissions
at
Miscellaneous
Organic
Chemical
Manufacturing
Facilities.
