Innovative Cost-Effective Control Device for Wastewater VOC Emissions (As Required by NESHAPs BWON, HON,MON, MACT and Other Regulations)

摘要

The USEPA National Emission Standards for Hazardous Air Pollutants (NESHAP) compliance regulations require 95 percent or greater removal of regulated Hazardous Air Pollutants (HAPs) in off-gas from storage vessels, process vents, and wastewater equipment. The BWON (Benzene Waste Operations NESHAP) regulations for refineries require 98 percent benzene removal or 95 percent total VOC removal. Previous to the effort discussed herein, the only Control Technologies, routinely acceptable to the USEPA, were Vapor Phase Adsorption and Thermal Incineration, including Flares. Both control devices are capital and operationally expensive and generate high carbon footprints. However, the rule allows implementation of an Alternative Control Device, subject to 98 percent benzene (95 percent VOC) removal and specified operating and monitoring conditions. This paper describes innovative protocols, developed by the authors and Marathon Petroleum Corporation (MPC) in Garyville, Louisiana, to certify an Alternative Control Device, that is cost-effective and has a minimal carbon footprint. The authors have developed bench-scale BOX Test and Core Column Simulation full-scale confirmation protocols and parameters, which delineate more realistic and reliable benzene biodegradation rates (f_(bio)) than the EPA default rates. The biorates, thus determined, are more representative of full-scale conditions than the typical USEPA approach. This effort has required modifying the recommended protocols and approach by the USEPA and obtaining their approval of data collection, testing methodology, and appropriate modeling techniques. Modification of typical, conventional protocols negated the required use of VOC biodegradation rate default values. This benzene-biodegradation system was approved in writing by the State of Louisiana and accepted by the USEPA - Research Triangle, North Carolina. The ADVENT Integral System (AIS) is now approved as an Enhanced Biodegradation Unit (EBU) and an Alternative Control Device for treatment of benzene under BWON criteria. It is premised that any properly designed and operated activated sludge system can be qualified as an Alternative Control Device when developed with the protocols herein.