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RCRA Box 1883 

Prepped by Ollie Stewart 

Document Number: 

97) ll-B-259 

Docket Number: 

A-90-19 

Printed 12/3/200810:42:16 AM Sheet 97 of 171 
MEMORANDUM 

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A-90-19 

ll-B-259 

DATE: 

TO: 

FROM: 

SUBJECT: 

February 6, 1992 

HON Projec t File s 6.1 and 6.2 jfnl [f j .jji_Jl__W ill ' 

Thomas Olsen and Kristin e Scott, Radian ) 

y 

i!:j SEP 1 4 1992 '[•' 

Estimation of Secondary Impacts for HON jj |_ J 

^PAmoocKE: Transfer and Process Vents 

The purpose of this memorandum is to document the procedures 

used to estimate secondary environmental and energy impacts 

associated with combustion control of process vents and transfer 

loading operations. The secondary impacts of combustion control 

included air pollution, water pollution, and additional energy 

use. There are no significant solid wastes generated through use 

of thermal oxidation. A small amount of solid waste, 

consisting of spent catalyst, could result through use of 

catalytical oxidation. 

Section 1.0 discusses the secondary air impacts estimating 

methodology. Section 2.0 discusses the water pollution impacts 

and Section 3.0 presents the procedure to estimate energy 

impacts. 

1.0 SECONDARY AIR POLLUTION IMPACTS 

Secondary air emissions are generated as a result of 

combustion of organic HAP and VOC in the vent stream and 

auxiliary fuel in an incinerator or flare. The secondary air 

pollutants from combustion include nitrogen oxides (NOx) and 

carbon monoxide (CO). The estimation of these two criteria 

pollutants are discussed in the following sections. 

1.1 EMISSIONS ESTIMATION OF NITROGEN OXIDES 

Emissions of NOx are estimated based on the type of 

combustion device utilized. NOx emissions from incinerators are 

generally below 100 ppm except for cases where nitrogenous 

compounds are contained in the inert stream. Table 1 presents 

the N0X emission factors. For vent streams which do not contain 

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TABLE 1. N0X EMISSION FACTORS 

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Type of Combustion 

Control Device 

Nitrogeneous 

Compounds in 

Inert Stream 

Emission 

Factor 

Concentration 

of N0X in 

Outlet Stream 

Thermal Incinerator 

Thermal Incinerator 

Flare 

No 

Yes 

.05 lb 

mmBtu 

Total Heat 

Input 

4 0 ppmv 

2 00 ppmv 

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nitrogenous compounds and are controlled by incinerators, an 

outlet concentration of 40 ppmv NOx was assumed. For vent 

streams containing nitrogenous compounds that are controlled by 

incinerators, an outlet concentration of 200 ppmv NOx was 

assumed. ' NOx emissions from flares were calculated based on 

the total heat input of the VOC present in the vent stream. 

Table 1 presents the emission factor used to calculate NOx 

emission impacts for flares. 

1.2 EMISSIONS ESTIMATION OF CARBON MONOXIDE 

For process vent streams, emissions of CO are estimated 

based on the heat input of the vent stream. Table 2 presents CO 

emission factors used to calculate CO emission impacts for 

process vent streams. The emission factors were derived based on 

c 

the combustion of natural gas. 

For transfer vent streams, emissions of CO are estimated 

based on the size of the incinerator as determined by the 

auxiliary fuel flow rate. Table 3 presents CO emission factors 

used to calculate CO emission impacts for transfer vent streams. 

2.0 WATER POLLUTION IMPACTS 

Control of HAP and VOC emissions through use of a combustion 

device does not result in the generation of waste water 

effluents. However, vent streams containing halogenated 

compounds must be further controlled through the addition of a 

scrubber to remove the resulting acid gas. The use of a scrubber 

results in a relatively small increase in wastewater generation. 

This increase generally does not affect plant waste treatment or 

sewer capacity. 

The amount of wastewater generated is equal to the amount of 

water required by the scrubber design to absorb the acid gas 

leaving the incinerator. For the purpose of the HON analysis, a 

scrubbing liquid to vapor ratio of 17 gallons (of scrubber flow) 

per 1000 scfm of vapor measured at the scrubber inlet was used. 

This ratio represents an average liquid to vapor ratio based on a 

vender survey. 

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TABLE 2. CARBON MONOXIDE EMISSION FACTORS FOR PROCESS VENT 

STREAMS 

Total Heat Input (THI) 

(Btu/hr) 

Emission Factor3 

(lb CO/106ft3 Natural Gas) 

T H K IO7 

IO7 < THI < IO8 

THI > IO8 

20 

35 

40 

aAssumed (1000 Btu)/(scf natural gas) 

TABLE 3. CARBON MONOXIDE EMISSION FACTORS FOR TRANSFER VENT 

STREAMS 

Auxiliary Fuel Flow Rate 

(FR) (scfm) 

Emission Factor 

(lb CO/106 scf of fuel) 

FR< 167 

167<= FR < 1667 

FR > 1667 

20 

35 

40 

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3.0 ENERGY IMPACTS 

Energy impacts from combustion control include increased 

fuel usage to supplement the firing of the combustion device and 

increased electricity use for the collection and ducting of the 

vent stream to the control device. The estimation of these two 

impacts is discussed in the following sections. 

3.1 FUEL IMPACTS 

The use of a combustion device generally results in an 

increased net fuel usage for device startup, supporting 

combustion of the vent stream, or to promote flame stability if 

the heat content of the vent stream is low. The fuel impacts are 

equal to the design fuel requirement. The fuel requirements are 

dependent on the flowrate and the heat content of the VOC/HAP 

stream.

 rl' The volumetric flowrate of the auxiliary fuel 

(scfm) is calculated based on equation 3.18 in the OAQPS Control 

Cost Manual (OCCM). The flowrate of the fuel is then converted 

to energy input (Btu/min) by the following conversion from the 

OCCM10: 

Auxiliary fuel energy input = p - * Q - * (-Ahc) f 

where: 

Paf

 = Fuel density (lb/ft3) 

Qaf = Fuel flow rate (scfm) 

(-Ahc)af = Fuel heat of combustion (Btu/lb) 

The auxiliary fuel was assumed to be methane. The following 

conversion was used: 

Energy Input = fuel flowrate (scfm) * 0.0408 ib * 21,502 Btu 

ft3 lb 

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3.2 ELECTRICITY IMPACTS 

Electricity is required to operate the fans, blowers, and 

instrumentation necessary to transport vent streams and 

combustion air to a flare or incinerator. Electricity 

requirements and costs are based on the vent stream flow rate, 

pressure drop, and the design of the control device fans and are 

documented in a separate memorandum. However, it should be 

noted that the pressure drop equation became invalid at flowrates 

less than 93 scfm. Therefore, for streams with flows below 93 

scfm, electricity costs were not realistic and were adjusted to a 

minimum as discussed in a separate memorandum. 

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REFERENCES 

1. Control of Volatile Organic Compound Emissions From Reactor 

Processes and Distillation Operations Processes In The 

Synthetic Organic Chemical Manufacturing Industry; Draft 

CTG, EPA-450/4-91-031, November 1991. p. 4-6 

2. Reference 1, p. 4-3 

3. U.S. Environmental Protection Agency. Air Oxidation 

Processes in Synthetic Organic Chemical Manufacturing 

Industry-Background Information for Proposed Standards. 

Research Triangle Park, NC. Publication No. 

EPA-450/3-82-001a. January 1982. p. C-22. 

4. U. S. Environmental Protection Agency. Reactor Processes in 

Synthetic Organic Chemical Manufacturing Industry-Background 

Information for Proposed Standards. Research Triangle Park, 

NC. EPA-450/3-90-016a. 

5. Memorandum from Barbour, W. and R. Pandullo, Radian 

Corporation, to Evans, L., EPA/CPB. Reasonably Available 

Control Technology (RACT) Impacts for the SOCMI Reactor 

Processes and Distillation Operations CTG. March 29, 1991. 

6. Compilation of Air Pollutant Emission Factors, Volume 1: 

Stationary Point and Area Sources U. S. EPA, AP-42. 

September 1985. 

7. Reference 1, p. 4-4. 

8. Memorandum from Ferrero, B., Radian Corporation, to Project 

File 6.1. Estimating Liquid to Vapor Flowrate Ratios in 

Scrubber Columns. February 5, 1992. 

9. Reference 1, p. 5-7 to p. 5-8. 

10. OAQPS Control Cost Manual, EPA 450/3-90-006. January 1990. 

p. 3-31 to 3-35. 

11. Reference 1, p. 5-13. 

12. Memorandum from Probert, J. A., Radian Corporation, to 

Project File. Annual Electricity Costs for Motors That 

Power Fans in a Vapor Collection System for Transfer Loading 

Racks. August 28, 1991. 

13. Memorandum form Ferrero, B., Radian Corporation, to Project 

File 6.1. Electricity Requirement for Low Flow Streams for 

HON Process Vents. January 22, 1992. 

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