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OARBa 

Prepped by Keeia Richards 

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Document Nun 

5)11-

Docket Numbei 

Aber: 

B-2 

90-19 

Printed 12/2/2008 10:36: 6 AM Sheet 5 of 46 
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RADIAN 

<oi»giiario N 

P.2 

A-90-19 

ll-B-2 

MEMORANDU M 

Datfi: September 19, 1990 

To: Leslie Evans, EPA/CPB 

From: David Ocamb, Radian / 

Subject: Methodology for Incremental Gas cJstEflfo-AMftlPQ£fe)jTverlt 

and HON Transfer 

d e n w 

This memorandum presents the proposed methodology for estimating 

incremental gas costs to upgrade a thermal incinerator to operate at 

a destruction efficiency of 98 percent. The incinerator upgrade is 

necessary for completing the economic impacts for the HON Process Vents 

and HON Transfer NESHAPs. 

As part of the HON NESHAPs effort, control costs are generated to 

represent the monetary investment necessary to achieve the control level to 

be dictated by the NESHAPs. (The proposed control level is 98 percent Dy 

combustion for Process Vents and Transfer.) Existing (baseline) control 

levels are determined from State regulations and in some cases the baseline 

device is a thermal incinerator. For HON Process Vents, Illinois requires 

thermal incinerator control at a level of 85 percent destruction efficiency. 

For HON Transfer, Louisiana and Pennsylvania require 90 percent control by 

thernal incineration. As a result in order to reach the NESHAP control 

level, a cost must be estimated to increase the State control levels to 98 

percent destruction efficiency. 

The design of a thermal incinerator is dependent on three important 

variables: combustion temperature, residence time,and turbulence. The 

combination of these variables dictates the destruction efficiency of the 

inciierator. As part of the HON Process Vents and Transfer, the thermal 

incinerator is designed to operate at 1,600 F for combusting nonhalogenated 

materials or 2,000°F for halogenated materials. Both designs represent a 

residence time of 0.75 seconds with turbulent flow conditions. These design 

constraints correspond to the destruction efficiency of 98 percent. 
P.3 

As part of the HON Transfer and Process Vents analysis, the State 

incinerators are assumed to be designed to operate at 0.75 residence time 

and with turbulent flow conditions. The combustion temperature is the 

remaining parameter available to manipulate to achieve the 98 percent 

destrjction efficiency. 

The purpose of this memorandum is provide the methodology to determine 

the operation temperature for the State incinerators and to estimate the 

natural gas cost to increase the combustion temperature to reach the 

98 percent destruction level. Section 1.0 presents the methodology to 

generate the State incinerator operating temperatures. Section 2.0 presents 

the methodology to estimate the natural gas cost to achieve the combustion 

temperature at 98 percent destruction efficiency. 

1.0 METHODOLOGY FOR ESTIMATING STATE INCINERATOR OPERATING TEMPERATURES 

Since the states listed above require combustion control at less than 

98 percent, the State incinerator design must be improved to meet the design 

constraints of the HON incinerator. Therefore, a model design was 

developed. The assumption was made that the incinerators in these states 

would be operating at 0.75 seconds residence time with turbulent flow 

conditions. The remaining variable in the incinerator design available to 

improve was to increase the combustion temperature to 1,600°F or 2,000°F and 

achieve 98 percent destruction. Assuming the State incinerator design could 

operate safely at a higher combustion temperature, a control cost would then 

represent a higher natural gas requirement to reach the HON design 

temperature. 

Combustion temperatures required to achieve various destruction 

efficiencies vary based on the compound in question. Table 1-1 presents the 

combustion temperature requirements for various compounds at 90 percent, 95 

percent, and 99 percent destruction efficiencies and at three residence times 

(0.5, 1.0 and 2.0 seconds). Each compound is identified as a hazardous air 

pollutant (HAP) and the temperature data is available in the March 1990 

edition of Pollution Engineering. 
Table 11 . Incinerator Combustion Temperatures 

Cocnpound 

Halogen 

Status 

HAP 

(Y/N) 

Residence Time = O.S sec Residence Time = 1.0 sec 

DE=90X 0E=95X DE=99X DE=90X DE=95X 0E=99X 

Residence Time - 2.0 sec 

DE=90X DE=95X DE=99X 

u> 

Methanol N Y 

Ethylene H M 

N-Butyl Alcohol N N 

Styrene N Y 

Glycol Ethers N Y 

Methyl Isobutyl Ketone M Y 

Toluene H Y 

Phenol N Y 

Xylene N Y 

Acetone N N 

Benzene M Y 

Methyl Ethyl Ketone N Y 

Propylene N N 

1,1,1-Trichloroethane Y N 

Dichloroethane Y Y 

Trichloroethylene Y Y 

Chloroform Y Y 

Carbon Tetrachloride Y Y 

Tetrachloroethylene Y Y 

Freon 113 Y N 

Dichloromethane Y Y 

2,092 

1,424 

1,392 

1,424 

1,424 

1,772 

1.338 

2,489 

2,092 

2,489 

1,460 

1,772 

1,424 

1,193 

1.772 

1,545 

1,174 

1,424 

1,797 

1,457 

1,505 

2,116 

1.445 

1,407 

1,445 

1,445 

1,793 

1,351 

2.525 

2.116 

2.525 

1,489 

1,793 

1.445 

1,218 

1,793 

1.592 

1.190 

1,445 

1,842 

1,473 

1.522 

2,158 

1,480 

1,433 

1,480 

1,480 

1,828 

1,372 

2,587 

2,158 

2,587 

1,537 

1,828 

1,480 

1,261 

1,828 

1,675 

1,216 

1,480 

1,921 

1,499 

1,552 

2,029 

1,372 

1.353 

1.372 

1,372 

1,719 

1,304 

2,396 

2,029 

2,396 

1,389 

1,719 

1,372 

1,130 

1.719 

1.429 

1,133 

1,372 

1,684 

1,417 

1,459 

2,053 

1,391 

1,368 

1,391 

1,391 

1,738 

1,317 

2,431 

2,053 

2,431 

1,415 

1,738 

1,391 

1.153 

1.738 

1,472 

1.148 

1,391 

1.726 

1,432 

1.476 

2,092 

1,424 

1.392 

1,424 

1,424 

1,772 

1,338 

2,489 

2,092 

2,489 

1,460 

1,772 

1,424 

1,193 

1,772 

1.545 

1.174 

1.424 

1,797 

1,457 

1.505 

1,970 

1.322 

1,316 

1,322 

1,322 

1,668 

1,272 

2,310 

1,970 

2,310 

1,322 

1,668 

1,322 

1,072 

1,668 

1,326 

1,094 

1,322 

1,583 

1,379 

1,416 

1,992 

1,340 

1.330 

1,340 

1,340 

1,687 

1,284 

2.342 

1,992 

2,342 

1,347 

1.687 

1.340 

1,093 

1,687 

1,364 

1.109 

1.340 

1.620 

1,393 

1.443 

2,029 

1.372 

1,353 

1.372 

1,372 

1,719 

1,304 

2,396 

2,029 

2.396 

1,389 

1,719 

1,372 

1.130 

1.719 

1.429 

1.135 

1,372 

1.684 

1.417 

1,459 

Note: All temperatures are in Fahrenheit. 
P.5 

As shown on Table 1-1, the combustion temperature varies widely. In some 

cases, the combustion temperature at 99 percent exceeds the HON design 

temperature at 98 percent and in other cases the temperature at 99 percent 

destruction is much less than the HON design temperature. 

"he data on Table 1-1 was used to generate combustion temperatures at 

0.75 seconds residence time (HON residence time). The combustion 

temperature at 0.75 seconds was calculated by selecting the midpoint between 

the 0.5 second and 1.0 second residence times for each efficiency. The 

combustion temperatures at 0.75 second residence time is shown on Table 1-2 

for only HAP compounds. Overall, the temperatures vary widely at 0.75 

seconcs residence time. An average temperature was generated for each 

destruction efficiency and as shown on Table 1-2, the average temperatures 

for the nonhalogenated HAPs all exceed 1,600 F and the average temperatures 

for halogenated HAPs are much lower than 2,000°F. No clear correlation was • 

apparent for using the average temperature to determine the relationship of 

HON design temperature to destruction efficiency using the Pollution 

Engineering data. 

In order to develop a correlation of combustion temperature to 

destruction efficiency relative to the HON design temperatures, a 

temperature increment was calculated to use in estimating the State 

operating temperatures. The engineering assumption is that even through the 

average temperatures differ from the HON design temperatures, the 

incremental temperature is applicable. A temperature change from 90 percent 

to 95 percent was calculated as well as the temperature change for 95 

percent to 99 percent. The temperature change for each HAP stream is shown 

on Table 1-3. Next, an incremental temperature change was calculated 

representing the temperature increase per unit of efficiency. This was 

performed by taking the temperature change from 90 to 95 percent range and 

dividing by 5. This represents the temperature increase per 1 percent 

increase in efficiency. Similarly, a temperature change per 1 percent 

increase was generated for the 95 percent to 99 percent efficiency range. 

The temperature increments are also presented on Table 1-3. 
P.6 

Table 1-2. Incinerator Temperatures at 0.75 Seconds Residence Time 

Halogen HAP Residence Time = 0.75 sec 

Compound Status (Y/N) 

0E=90X DE=95X DE=99X 

Benzene 

Methyl Ethyl Ketone 

Methyl Isobutyl 

Xylene 

Glycol Ethers 

Methanol 

Toluene 

Styrene 

Phenol 

Ketone 

N 

N 

H 

H 

H 

N 

N 

H 

H 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

- Y 

Y 

1,425 

1,746 

1,746 

2,061 

1,398 

2,061 

1,321 

1,398 

2,443 

1,452 

1,766 

1,766 

2,085 

1,418 

2,085 

1,334 

1,418 

2,478 

1,499 

1,800 

1,800 

2,125 

1,452 

2,125 

1.355 

1,452 

2,538 

Avg. for Nonhalogen 1,733 1,756 1,794 

Dichloroethane 

Tetrachloroethylene 

Carbon Tetrachloride 

Chloroform 

Trichloroethylene 

Dichloromethane 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

1,746 

1,741 

1,398 

1,154 

1,487 

1,482 

1,766 

1,784 

1,418 

1,169 

1,532 

1,499 

1,800 

1,859 

1,452 

1,195 

1,610 

1,529 

Avg. for Halogen 1,534 1,560 1,605 

Note: All temperatures are in Fahrenheit. 
P.7 

Table 1-3. Temperature Increments 

Halogen HAP Temperature Change a RT = 0.75 sec Incremental Temp Change a RT *** 0.75 sec 

Compound Status (Y/N) 

90%->95X 0E=95X->99X 90X->95X DE=95%->99% 

Benzene 

Methyl Ethyl Ketone 

Methyl Isobutyl 

Xylene 

Glycol Ethers 

Methanol 

Toluene 

Styrene 

Phenol 

Ketone 

N 

N 

N 

N 

H 

N 

N 

N 

N 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

27.5 

20.0 

20.0 

24.0 

20.0 

24.0 

13.0 

20.0 

35.5 

46.5 

34.5 

34.5 

40.5 

34.0 

40.5 

21.0 

34.0 

60.0 

5.5 

4.0 

4.0 

4.8 

4.0 

4.8 

2.6 

4.0 

7.1 

11.6 

8.6 

8.6 

10.1 

8.5 

10.1 

5.3 

8.5 

15.0 

Avg. for Nonhalogen 22.7 38.4 4.5 9.6 

Dichloroethane 

Tetrachloroethylene 

Carbon Tetrachloride 

Chloroform 

Trichloroethylene* 

Dichloromethane 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

20.0 

43.5 

20.0 

15.5 

45.0 

17.0 

34.5 

75.0 

34.0 

26.0 

78.0 

29.5 

4.0 

8.7 

4.0 

3.1 

9.0 

3.4 

8.6 

18.8 

8.5 

6.5 

19.5 

7.4 

Avg. for Halogen 26.2 45.1 5.2 11.3 

Note: All temperature ranges are in Fahrenheit. 
P.8 

The temperature increments were averaged for the range 90 percent to 95 

percent and the range 95 to 99 percent for the nonhalogenated and 

halogenated HAPs. For nonhalogenated HAPs, the average temperature 

increment for the 90 to 95 percent range is 4.5 degrees and 9.6 degrees for 

95 to 99 percent. For halogenated HAPs, the average temperature increment 

for 90 to 95 percent is 5.2 and the incremental for 95 to 99 is 11.3. 

Clearly, the Pollution Engineering data is not provide a consistent 

temperature increase per unit increase in destruction efficiency. 

For the nonhalogenated HAPs, the increments for 90 to 95 percent and 95 

to 99 percent were used to calculate the average increment per unit 

destruction efficiency. This average for nonhalogenated HAPs is 7.0°F 

temperature increase per unit destruction efficiency. An average 

temperature increment was also calculated for the halogenated streams which 

was 8.25°F per unit destruction efficiency. 

Ii order to calculate the operating temperature for a State 

incinerator, the State control efficiency is subtracted from 98 percent. 

This difference is multiplied by the temperature increment per unit 

destruction efficiency to calculate the temperature difference for the State 

incinerators. This difference is subtracted from the HON design temperature 

to calculate the State operating temperature. The engineering assumption is 

that the temperature change per increase in destruction efficiency is 

constant and that the increments calculated from the Pollution Engineering 

data c;»n be extrapolated below 90 percent destruction efficiency. 

2.0 METHODOLOGY FOR INCREMENTAL GAS COST ESTIMATION 

Based upon the average temperature increments for the halogenated and 

nonhalogenated HAPs presented above, the State operating temperatures can 

now be estimated. The annual control cost for upgrading the State 

incinerators requires only the cost of the natural gas required to increase 

the combustion temperature from the State operating temperature to the HON 

operating temperature. 
P.9 

The current SOCMI CTG project provided HON with a costing algorithm for 

estimating incinerator and flare control costs. For sources not controlled 

at the baseline by combustion, this routine is used to calculate the cost 

for combustion control. For the States with incinerators at baseline, the 

same algorithm is used to calculate the natural gas cost to increase the 

operating temperature to the HON level. To calculate the incremental gas 

cost, the incinerator algorithm is used to calculate the natural gas cost at 

the Stite and HON operating temperatures based on the actual vent stream 

characteristics. The difference in these two costs is the annual gas cost 

to increase the control efficiency to 98 percent. 

Table 2-1 presents a number of HON Process Vent model streams used as 

examples in developing incremental natural gas costs. The model streams 

represent halogenated and nonhalogenated streams as well as vent streams 

with high and low flowrates and heat contents. The control scenario used in 

this example is an incinerator located at a plant in Illinois operating at 

85 percent destruction efficiency. To calculate the operating temperatures 

for halogenated and nonhalogenated streams, the following calculation is 

performed: 

Control Increment = 98% - 85% = 13% 

Halogen Combustion Temper* 

at 85 Percent Destruction 

Ncnhalogen Combustion Term; 

at 85 Percent Destruction 

Hclogen Combustion Temperature = 2,000 - (13 X 8.25) = 1,890°F 

Ncnhalogen Combustion Temperature = 1,6000 - (13 X 7.0) = 1,510°F 

The incremental control level is calculated and multiplied times the average 

temperature increment. This quantity is subtracted from the HON design 

temperature to determine the State operating temperature. 

Once the State operating temperature is determined, the natural gas 

cost for vent stream is estimated at the both the State and HON operating 

temperatures. The annual natural gas cost is the difference in the gas 

costs. Table 2-2 presents the gas costs for each destruction efficiency and 

the incremental gas cost for the example streams. 

8 
P.10 

Table 2-1. Example Vent Streams 

Stream 

10 

======== 

1 

2 

3 

4 

.5 

6 

7 

8 

9 

10 

Hazardous 

Air 

Pollutant 

======================== 

Adiponi tri le 

Isopthalic Acid 

Methanol 

Methyl Methacrylate 

N-Butyl Alcohol 

Styrene 

Dichlorobenzene 

Ethyl Chloride 

Ethyl Oichoride 

Ethylene Dichloride 

Halogen 

Status 

========= 

N 

N 

N 

N 

N 

N 

Y 

Y 

Y 

Y 

Flowrte 

(scfm) 

========= 

1,080 

123 

63.4 

2.6 

5.429 

574 

2.6 

20 

3,050 

40 

Heat 

Value 

(8tu/scf) 

•====*====== = 

70 

19 

449 

2870 

776 

300 

62 

1286 

804 

40 

ssssssssss: 

HAP 

Concentration 

(ppmv) 

=============== 

1,512 

7,600 

204,617 

1,000,000 

55.200 

17,620 

22,220 

850,850 

375,870 

5,940 

Note: Each stream is at 77 F, zero percent oxygen, and is released 

8,760 hours per year. 
P.11 

Table 2-2. Incremental Gas Cost for a Illinois Incinerator 

Stream 

ID 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

Hazardous 

Air 

PoUutant 

Adiponitrile 

Isopthalc Acid 

Methanol 

Methyl Methacrylate 

N-Butyl Alcohol 

Styrene 

Dichlorofcenzene 

Ethyl Chloride 

Ethyl Dichoride 

Ethylene Dichloride 

Halogen 

Status 

N 

N 

N 

N 

N 

N 

Y 

Y 

Y 

Y 

Flowrte 

(scfm) 

1,080 

123 

63.4 

2.6 

5,429 

574 

2.6 

20 

3,050 

40 

Heat 

Value 

(Btu/scf) 

70 

19 

449 

2870 

776 

300 

62 

1286 

804 

40 

HAP 

Concentration 

(ppmv) 

1,512 

7,600 

204,617 

1,000,000 

55,200 

17,620 

22,220 

850,850 

375,870 

5,940 

Gas Cost 

at 98 Percent 

(S/yr) 

3,677 

29,733 

1,022 

216 

121,966 

4,985 

3,715 

1,432 

18,190 

953 

Gas 

at 85 

Cost 

Percent 

($/yr) 

3,460 

26,502 

962 

203 

114,579 

4,691 

3,479 

1,350 

17,150 

711 

Incremental 

Gas Cost 

(S/yr) 

217 

3,231 

60 

13 

7,387 

294 

236 

82 

1,040 

242 

Note: Each stream is at 77 F, zero percent oxygen, and is released 

8,760 hours pe1 year. 

10