Date:
August
8,
2003
Subject:
Source
Reduction
Techniques
Reported
by
Miscellaneous
Organic
Chemical
Manufacturing
Sources
in
Responses
to
Section
114
Information
Collection
Requests
Miscellaneous
Organic
Chemical
Manufacturing
NESHAP
EPA
Project
No.
95/
08;
RTI
International
Project
No.
08550.001.011
From:
David
Randall
To:
MON
Project
file
I.
Introduction
This
memorandum
summarizes
the
source
reduction
activities
that
miscellaneous
organic
chemical
manufacturing
facilities
reported
in
Table
7
of
their
responses
to
the
January
1997
section
114
information
collection
request.
All
of
the
responses
are
contained
in
Docket
No.
A­
96­
04;
docket
item
numbers
II­
D­
33
through
II­
D­
373.
Since
responding
to
the
question
about
source
reduction
activities
was
voluntary,
many
of
the
facilities
did
not
provide
information.

Table
1
lists
the
types
of
source
reduction
activities
that
were
reported.
The
activities
have
been
organized
into
five
broad
categories:
(
1)
raw
material
substitutions,
including
changes
in
process
and
cleaning
solvents;
(
2)
techniques
to
reduce
the
amount
of
waste
generated;
(
3)
process
changes;
(
4)
emission
controls
and
suppression
techniques;
and
(
5)
miscellaneous
techniques
that
did
not
appear
to
fit
in
the
other
categories.
Strictly
speaking,
air
pollution
control
devices
are
not
a
source
reduction
technique,
but
the
reported
information
is
included
in
Table
1
for
completeness.
2
Table
1.
Source
Reduction
Techniques
Reported
in
Responses
to
Miscellaneous
Organic
Chemicals
ICR
Type
of
source
reduction
Number
of
facilities
Comments
Raw
material
substitution
Replaced
trichloroethylene
with
non­
HAP
1
low
VOC
substitutes
1
wash
solvent
50%
non
VOC
1
switch
from
formaldehyde
to
p­
formaldehyde
1
substituted
epoxidized
soybean
oil
for
propylene
oxide
1
eliminated
use
of
toluene
1
changed
reactants/
reformulation
1
unspecified
raw
material
substitution
1
non­
HAP
solvent
(
process
or
cleaning)
substitution
5
changed
raw
material
to
eliminate
methanol
by­
product
1
replace
tetrachloro____
with
non­
HAP
1
reduced
inhibitor
concentration
in
raw
materials
1
Reduce
waste
offspec
materials
reworked
1
QA/
QC
samples
and
filter
drainage
reblended
1
hot
melt
truck
sample
recovery
1
solvent
recovery
1
assumed
waste
solvent
recycled/
reused
water
condensed
from
reactors
1
modified
glycerine
recovery
to
semi­
continuous
with
methanol
recovery
1
eliminated
wash
so
no
WW
generated
1
installed
decanters
to
reduce
dimethylaniline
WW
loss
1
use
more
efficient
cleaning
methods
1
decreased
cleanout
(
less
frequent)
2
better
selection
of
bulk
containers
to
minimize
waste
1
Process
changes
Table
1.
(
continued)
3
Type
of
source
reduction
Number
of
facilities
Comments
reduced
excess
raw
material
feed
1
reduced
excess
HAP
reactant
in
process
1
changed
order
of
raw
material
addition
to
reduce
toluene
usage
1
increased
size
of
reactor
to
more
completely
react
raw
materials
1
reduced
operating
temp
&
heat
cycle
time
1
reduced
temperature
1
installed
feedstock
cooler
1
reduced
nitrogen
purge/
blow
2
reduced
discharge
air
1
improved
nitrogen
padding
2
reduced
cycle
time
and
air
flow
1
feed
material
from
tank
trailers
rather
than
too­
large
bulk
tank
1
switched
to
CS2
tote
bin
with
closed
handling
system
to
eliminate
ST
1
new
metering
system
1
increased
product
recovery,
thereby
reducing
solvent
used
in
waste
product
disposal
1
replaced
product
recovery
equipment
and
optimized
the
process
1
improved
yields
2
product
schedule
optimization
1
DCS
control
or
changed
control
system
2
installed
piping
to
eliminate
need
to
open
kettle
for
dumping
solid
resin
1
piping
changes
to
prevent
EL
and
losses
to
WW
1
welded
pipe
1
closed
sample
flush
collection
buckets
1
Table
1.
(
continued)
4
Type
of
source
reduction
Number
of
facilities
Comments
automatic
solvent
wash
2
pressurized
water
for
tank
cleaning
1
removed
HCl
loading
system
1
added
third
stage
on
dimer
still
1
changed
column
from
vacuum
to
atmospheric
1
phase
separation
for
solvent
recovery
1
changed
catalyst
to
reduce
WW
1
eliminate
unnecessary
sampling
and
process
steps
1
unspecified
process
change
2
removed
hopper
and
vent
1
closed
in
vent
system
and
eliminated
powered
vent
1
installed
closed­
loop
system
on
dryer,
filter,
and
vacuum
pump
1
re­
circulation/
circulation
loop
2
vapor
balance,
vent
equalization,
and
vapor
recovery
for
ST/
PV
6
Controls
APCDs
(
TO,
scrubber,
condenser,
carbon
adsorber,
flare)
27
Strip
HAP
from
wastewater
1
improved
drain/
sumps
1
modified
sewer
system
from
open
ditch
to
conduit
1
optimized
column
packing
1
Assuming
this
is
control
column
IFR
1
LDAR
8
install
better
lids
1
flame
arrestors
1
Miscellaneous
sealless
pump
or
mechanical
seals
on
pump
shafts
3
Table
1.
(
continued)
5
Type
of
source
reduction
Number
of
facilities
Comments
revised
method
of
returning
raw
material
containers
to
vendor
1
product
pigging
2
gravity
transfer
to
eliminate
pumped
displacement
emissions
1
switched
to
use
totes
instead
of
drums
1
product?
raw
material?

moved
styrene
from
drums
to
bulk
storage
1
low
VOC
powder
coatings
1
reduced
number
of
tanks
1
binder
vent
line
piping
1
conservation
vent
1
participated
in
early
reduction
program
1
discontinued
process
3
plant
shutdown
1
