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memo.
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MEMORANDUM
TO:
Randy
McDonald,
U.
S.
Environmental
Protection
Agency,
OAQPS/
Sector
Policies
and
Programs
Division,
Coatings
and
Chemicals
Group
(
C504­
04)

FROM:
Danny
Greene,
Eastern
Research
Group,
Inc.

DATE:
June
7,
2006
SUBJECT:
Estimation
of
Control
Costs
and
Emission
Reductions
for
Group
2
Wastewater
Streams
1.0
INTRODUCTION
This
memorandum
describes
the
methodology
used
to
estimate
the
emission
reductions
and
capital
and
annual
costs
associated
with
controlling
Group
2
wastewater
streams
at
facilities
subject
to
the
National
Emission
Standards
for
Organic
Hazardous
Air
Pollutants
from
the
Synthetic
Organic
Chemical
Manufacturing
Industry
(
HON).

Section
2.0
summarizes
the
background
and
available
data
and
Section
3.0
discusses
the
methodology
used
to
estimate
emissions
and
emission
reductions
of
controlling
wastewater
streams.
The
methodology
used
to
estimate
control
costs
is
discussed
in
Section
4.0.
Attachment
A
contains
the
data
tables
cited
in
this
memorandum.

Table
A­
1
presents
the
emission
reduction
and
control
cost
estimates.
Based
on
this
analysis,
the
total
HAP
emission
reduction
associated
with
controlling
Group
2
wastewater
streams
is
approximately
449
megagrams
per
year
(
Mg/
yr).
The
cost
effectiveness
values
(
i.
e.,
total
annual
cost
divided
by
the
emission
reductions)
for
controlling
Group
2
wastewater
streams
ranged
from
a
low
of
approximately
$
3,600/
Mg
to
a
high
of
approximately
$
4,200,000/
Mg.
The
average
of
the
cost
effectiveness
values
calculated
for
each
facility
is
approximately
$
457,000/
Mg.
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2
2.0
BACKGROUND
For
storage
vessels,
process
vents,
process
wastewater
streams,
and
transfer
operations,
the
HON
establishes
applicability
criteria
to
distinguish
between
Group
1
emission
points
and
Group
2
emission
points.
Controls
are
required
only
for
emission
points
meeting
the
Group
1
criteria.
Group
2
emission
points
are
subject
to
recordkeeping
requirements
only.

The
HON
applicability
cutoffs
for
Group
1
streams
at
existing
facilities
are
based
on
the
total
annual
average
concentration
of
HAP
compounds
listed
in
Table
9
of
40
CFR
part
63,
subpart
G
and
the
wastewater
stream
flow
rate.
A
Group
1
stream
has
a:

 
total
annual
average
HAP
concentration
of
at
least
10,000
parts
per
million
by
weight
(
ppmw)
at
any
flow
rate;
or
 
total
annual
average
HAP
concentration
of
at
least
1,000
ppmw
and
an
annual
average
flow
rate
of
at
least
10
liters
per
minute
(
lpm).

Wastewater
streams
that
do
not
meet
either
of
these
criteria
are
considered
Group
2
streams.

Data
on
HAP
emissions
from
Group
1
and
Group
2
wastewater
streams
was
obtained
from
a
voluntary
survey
distributed
by
the
American
Chemistry
Council
(
ACC).

Table
A­
2
presents
the
ACC
survey
data
for
Group
2
streams.
As
shown
in
the
table,
the
survey
data
identified
the
wastewater
stream
source
and
provided
the
HAP­
specific
emissions
from
uncontrolled
and
undesignated
wastewater
streams
for
60
facilities
for
the
base
year
1999.
For
this
analysis,
uncontrolled
streams
(
UCWW)
and
streams
where
the
control
status
was
not
designated
(
WW)
were
considered
to
be
Group
2
streams.

To
develop
estimates
of
emission
reductions
and
control
costs
for
Group
2
wastewater
streams,
the
current
HON
MACT
level
of
control
(
i.
e.,
steam
stripper
with
control
of
overhead
gases)
was
applied
to
the
emissions
from
uncontrolled
wastewater
streams
reported
in
the
ACC
survey.
The
HAP
emissions
data
from
the
survey
were
used
directly
to
estimate
the
emission
reductions
achieved
by
controlling
Group
2
streams
(
see
Section
3.0).
However,
the
ACC
data
did
not
contain
flow
rate
data
for
individual
streams
which
is
necessary
to
estimate
control
costs.
Consequently,
we
developed
control
cost
estimates
using
model
wastewater
streams
(
see
Section
4.0).
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3
3.0
EMISSION
AND
EMISSION
REDUCTION
ESTIMATES
Emissions
and
emission
reduction
estimates
were
develop
for
each
individual
stream
identified
in
the
ACC
industry
survey
(
Table
A­
3).
For
this
analysis,
the
assumption
was
made
that
Group
2
streams
would
be
sent
to
a
steam
stripper
to
reduce
emissions.
Overhead
gases
from
the
steam
stripper
were
assumed
to
be
controlled
by
a
thermal
oxidizer
achieving
98­
percent
destruction.

The
total
controlled
emissions
were
calculated
as
the
sum
of
two
components:
the
emissions
from
the
stripper
thermal
oxidizer,
and
emissions
from
compounds
remaining
in
the
stripper
effluent
(
i.
e.,
residual
emissions).
The
emission
reductions
achieved
by
steam
stripping
were
calculated
by
subtracting
the
controlled
emissions
(
the
sum
of
emissions
from
the
stripper/
thermal
oxidizer
and
residual
stream
emissions)
from
the
emissions
reported
in
the
ACC
industry
survey.

The
emissions
from
the
stripper
thermal
oxidizer
were
calculated
using
the
following
equation:

Controlled
emissions
=
(
HAP/
Fe)*(
Fr)*(
1­
Eff)

where:

Controlled
emissions
=
stripper
thermal
oxidizer
emissions
(
kg/
yr)

HAP
=
HAP
emissions
reported
in
ACC
survey
(
kg/
yr)

Fe
=
compound­
specific
fraction
emitted
values
Fr
=
compound­
specific
fraction
removed
by
stripping
values
Eff
=
the
destruction
efficiency
of
the
thermal
oxidizer
(
98
percent)

The
compound­
specific
Fe
and
Fr
values
were
obtained
from
Table
2
of
Appendix
J
of
40
CFR
part
60,
subpart
YYY
(
the
proposed
New
Source
Performance
Standards
for
Wastewater
from
the
Synthetic
Organic
Chemical
Manufacturing
Industry
(
SOCMI
NSPS)).
In
cases
where
a
compound­
specific
value
was
not
available
for
a
particular
HAP,
the
average
of
the
assigned
Fe
(
or
Fr)
values
was
used.
Residual
emissions
were
estimated
using
the
following
equation:
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4
Residual
emissions
=
(
HAP/
Fe)*(
1­
Fr)

where:

Residual
emissions
=
emissions
from
compounds
in
the
stripper
effluent
(
kg/
yr)

HAP
=
HAP
emissions
reported
in
ACC
survey
(
kg/
yr)

HAP
=
HAP
emissions
reported
in
ACC
survey
(
kg/
yr)

Fe
=
compound­
specific
fraction
emitted
values
Fr
=
compound­
specific
fraction
removed
by
stripping
values
4.0
CONTROL
COST
ESTIMATES
To
estimate
the
capital
and
annual
costs
of
controlling
Group
2
streams,
the
assumption
was
made
that
a
new
steam
stripper
would
be
constructed
to
treat
the
additional
wastewater.
The
cost
estimates
do
not
include
the
cost
of
an
incinerator
for
combustion
of
stripper
off­
gases.
For
this
analysis,
the
assumption
was
made
that
the
organics
removed
by
the
steam
stripper
would
be
returned
to
a
production
process
or
combusted.

Section
4.1
describes
the
methodology
used
to
estimate
the
flow
rate
of
Group
2
wastewater
streams.
Section
4.2
explains
the
methodology
used
to
develop
the
control
cost
estimates.

4.1
Default
Wastewater
Stream
Flow
Rates
Since
data
for
wastewater
stream
flow
rates
were
not
provided
in
the
ACC
survey,

data
from
the
Miscellaneous
Organic
NESHAP
(
MON)
were
used
to
estimate
the
wastewater
stream
characteristics.
The
MON
data
were
used
since
the
production
processes
and
wastewater
streams
are
similar
to
those
found
in
the
facilities
regulated
by
the
HON.

To
develop
the
wastewater
stream
characteristics,
streams
in
the
MON
data
that
met
the
Group
2
applicability
characteristics
were
grouped
into
the
following
HAP
loading
ranges:

 
less
than
1
kg/
yr;

 
1
to
9
kg/
yr;

 
10
to
999
kg/
yr;
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5
 
1,000
to
9,999
kg/
yr;
and
 
10,000
kg/
yr
and
greater.

Within
each
of
these
HAP
loading
ranges,
the
streams
were
further
divided
into
those
that
were
considered
to
be
dilute
(
D),
intermediate
(
I),
or
concentrated
(
C)
based
on
an
evaluation
of
the
HAP
concentration
of
the
streams.

For
each
of
these
loading
ranges
(
i.
e.,
D,
I,
and
C),
a
default
flow
rate
(
liters
per
minute,
lpm)
was
estimated
by
multiplying
the
average
concentration
calculated
for
each
stream
grouping
by
the
median
of
the
HAP
loading
range.
The
median
was
used
instead
of
the
average
to
ensure
that
the
default
flow
rates
for
each
stream
grouping
were
comparable
to
the
actual
flow
rates
seen
in
MON
data.
Because
the
loading
values
cover
a
large
range,
using
the
average
of
the
loading
range
produced
flow
rates
that
did
not
appear
to
be
representative.
Table
A­
4
shows
the
MON
data
and
calculations
used
to
estimate
default
stream
flow
rates.
Table
A­
3
also
shows
the
weighting
factors
used
to
estimate
a
single
flow
rate
for
each
loading
range
(
rather
than
three
separate
flow
rates
for
dilute,
intermediate,
or
concentrated
streams).
The
weighting
factors
for
each
HAP
loading
range
were
calculated
by
dividing
the
number
of
streams
in
the
D,
I,
and
C
groups
by
the
total
number
of
streams
in
the
HAP
loading
range.

The
default
flow
rates
were
assigned
to
each
individual
stream
in
the
ACC
survey
data
based
on
each
stream's
HAP
loading.
Table
A­
5
shows
the
resulting
default
flow
rates
for
the
D,
I,
and
C
groups
and
the
weighted
flow
rates
for
each
Group
2
stream
reported
in
the
ACC
survey.

4.2
Steam
Stripper
Costs
The
capital
and
annual
costs
of
steam
stripping
were
estimated
using
values
($/
liter)
taken
from
Figure
5­
3
(
Unit
Operating
Costs
Versus
Wastewater
Feed
Rate
for
Steam
Stripping
Unit)
and
Figure
3­
1
(
Summary
of
Total
Capital
Investment
Versus
Wastewater
Feed
Rate
for
Steam
Stripping
Unit)
of
the
HON
proposal
BID.
The
steam
stripper
costs
from
the
HON
BID
were
in
1989
dollars.
To
estimate
the
equipment
costs
in
today's
dollars,
the
costs
indices
for
1989
(
361.1)
and
2004
(
444.2)
were
used.

Table
A­
6
summarizes
the
unit
cost
factors
used
in
this
analysis.
0154­
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Attachment
A
Data
Tables
