A Wastewater Solution for an Air Pollution Problem • A Cost-Effective Alternative for VOC Control as Required by NESHAP [BWON, HON, MON, MACT] Dr. Carl E. Adams, Jr., PE, BCEE Senior Author1 * Dr. Lial F. Tischler2 Andrew W. Edwards, PE3 1 ENVIRON International Corporation, Nashville, TN 2 Tischler/Kocurek, Austin, Texas 3 ENVIRON International Corporation, Houston, TX
BWON (Benzene Waste Operations NESHAP) • Aqueous Wastewater Considerations • Influent wastewater benzene concentration must be <10 mg/L to avoid required regulatory inventory accounting procedures • Wastewater treatment bioplant must qualify as an Enhanced Biodegradation Treatment Unit (EBU) • Current approved control is by excellent benzene separation in production processes and use of a NESHAPS Benzene Steam Striper on benzene-laden wastewaters • Wastewater Gaseous Emissions Considerations • Applies to gaseous emissions from wastewater treatment processes • Includes API separators, dissolved air and induced air flotation processes, uncovered tanks and includes sumps and wet wells emissions • Must incorporate an approved Control Device to reduce benzene emissions form these sources by 98% • Current approved controls are thermal oxidizers and vapor-phase activated carbon
BWON (Benzene Waste Operations NESHAP)Wastewater Gaseous Emissions Considerations • Title 40: Protection of Environment: 40 CFR § 61.340 presents three basic Control Devices that are acceptable, pursuant to specific design constraints: • An enclosed combustion device (e.g., vapor incinerator, boiler, or process heater) • A vapor recovery system (e.g., a carbon adsorption system or a condenser) • A flare • Title 40: Protection of Environment: 40 CFR § 61.340 also states “other” Control Devices can be used provided that certain conditions are met. (iv) A control device other than those described in paragraphs (a)(2) (i) through (iii) of this section may be used provided that the following conditions are met:
BWON (Benzene Waste Operations NESHAP) Wastewater Gaseous Emissions Considerations (A) The device shall recover or control the organic emissions vented to it with an efficiency of 95 weight percent or greater, or shall recover or control the benzene emissions vented to it with an efficiency of 98 weight percent or greater. (B) The owner or operator shall develop test data and design information that documents the control will achieve an emission control efficiency of either 95 percent or greater for organic compounds or 98 percent or greater for benzene. (C) The owner or operator shall identify: • The critical operating parameters that affect the emission control performance of the device; • The range of values of these operating parameters that ensure the emission control efficiency specified in paragraph (a)(2)(iv)(A) of this is maintained during operation of the device; and • How these operating parameter will be monitored to ensure the proper operation and maintenance of the device.
Overview • From Nashville, TN: The idea • To Garyville, LA: The testing site and first case study • To Research Triangle, NC(USEPA): The endorsement • To Baton Rouge, LA (LDEQ): The final approval • To Austin, TX: ENVIRON workshop • To weekly conference calls: VOC BioTreat™ Core Group • To creating marketing solutions: Brand, media relations, collateral • To prestigious recognition: AAEE E3 Grand Prize for Research • To today: Learn what you can; communicate to your contacts; bring in Carl, Greg or Andy
Prestigious Accolade:National Grand Prize – Research Category 2011 VOC BioTreat has garnered the coveted National Grand Prize in the Research category of the prestigious American Academy of Environmental Engineers (AAEE) 2011 Excellence in Environmental Engineering®(E3) Competition. The concept was conceived, developed and implemented by Dr. Carl E. Adams, Jr., Global Practice Area Leader: Industrial Wastewater Management.
Kirkpatrick Award: Semifinalist Kirkpatrick Chemical Engineering Achievement Award recognizes the most innovative chemical engineering technology achieved through group effort and successfully commercialized worldwide during the two years prior to an award year. Chemical Engineering Magazine has awarded this biennial prize continuously since 1933.VOC BioTreat was the 2011 Semi-Finalist
Louisiana Section of the Air & Waste Management Association: 2011 Industry Award: Grand Prize
What is VOC BioTreat? • VOC BioTreat is the process of qualifying an Alternative Control Device, other than Activated Carbon or Thermal Oxidation, for the biodestruction of regulated biodegradable VOC emissions. • The Alternative Control Device is cost-effectively an existing activated sludge process with emission sources in proximity to a WWTP.
Typical Acceptable Control Devices Thermal Oxidizers: Flare or Gaseous Incinerator Vapor-Phase Adsorption: Granular Activated Carbon Granular Activated Carbon Canisters Thermal Oxidizers
A Cost-Effective Solution for the Biodestruction of VOC Emissions • Incorporates ENVIRON-developed protocols to demonstrate an Alternative Control Device • Confirms the use of existing biological wastewater treatment facilities • Follows exact EPA requirements and protocols for approval
A Cost-Effective Solution for the Biodestruction of VOC Emissions • Conclusively demonstrates co-treatment of gaseous emissions or VOCs and aqueous soluble organicsin existing wastewater treatment facilities • Using these protocols, most activated sludge biotreatment systems can be qualified as an Alternative Control Deviceto treat biodegradable VOCs • It is transferable to other VOC/HAP and other regulations • Provides excellent configuration flexibility with existing facilities
Regulatory Interface & Approval Specific projects State of Louisiana State of Wyoming: in process of approval State of Mississippi: in process of approval Regular invitation to ENVIRON USEPA Research Triangle Park: Presented as a Technical Seminars(2) USEPA region 5: Presented as a Technical Seminar USEPA region 6: Presented as a Technical Seminar USEPA region 7: Presented as a Technical Seminar USEPA region 8: Presented as a Technical Seminar
Why VOC BioTreat? • Economics, Economics, Economics!!! • Typical systems (carbon or TOs) have much higher operating costs • O&M costs are typically <$10K per year • Capital investment quickly recovered(ROI <1 year typically, <2 yrs worst case) • Discarding previously installed system carbon/TO ok • OK, it’s not all economics! • N2 blankets: expensive, maintenance issue, leakage (pressurized) • Sustainableat reduced costs
VOC BioTreat Application Industrial Sectors • Refineries: BWON • Organic Chemicals: MACT (e.g., HON, MON, etc) • Pharmaceuticals: Pharma MACT • Coke plants (steel industry): BWON • Soil-Vapor-Extraction remediation systems Regulatory Drivers • Alternative NESHAP Wastewater Emission Control • WWTP Compliance Assurance Monitoring Optimization (CAM) for biological destruction efficiency (Fbio) • Process Vent Control
VOC BioTreat Typical Applications Soil-Vapor-Extraction
How is it Applicable? ConclusionsVOC BioTreatTM – the Process
High-Level Assessment: Comprehensive Questionnaire • Existing WWTP amenable to the technology? • Diffused aeration system • Deep tanks • Existing blowers have adequate air flow treatment capacity (modification may be necessary) • VOC emission sources appropriate for technology? • Compounds relatively biodegradable • Compounds have sufficient solubility(relatively low Henry’s Law constants) • VOC air volume compatible with WWTP diffused air treatment capacity • Favorable economics? • Reasonable proximity of VOC sources to WWTP • Current system O&M costs • Minimal modifications required to adapt WWTP to technology
VOC BioTreat – The Process STEP 1 High-Level Feasibility Evaluation Develop preliminary facility-specific model with assumedbiodegradation rate to gauge benzene removal performance requirements and obtain initial Agency concurrence for approach STEP 2 Conduct BOX testing to determine site-specific VOC biodegradation rate and maximize VOC BioTreateffectiveness STEP 3 STEP 4 Conduct Core Column Simulation Full-scale confirmation testing STEP 5 Obtain final Agency approval of Alternative Control Device Prepare detailed engineering plan and implement Alternative Control Device solution STEP 6 Steps 1 & 2 must be concluded favorably before proceeding with the remaining steps.
Case History Marathon Petroleum CompanyGaryville Refinery (MPC)Garyville, Louisiana Petroleum Refinery: BWON Alternative Control Device
Why was MPC-Garyville an Excellent Choice? • Economics, Economics, Economics! • Current MPC system had very high operating cost (energy and carbon) • Discarding initial capital investment wasn’t a deal breaker • BioTreat alternative costs almost nothing to operate • OK, it wasn’t all economics! • N2 blanket system leakage degrading overall performance of currentsystem (not an issue for BioTreat alternative) • Reduction in carbon footprint, better sustainability aspects • Substantial reduction in energy requirements • Simplicity of installation and operation of BioTreat alternative (maintenance cost likely much lower)
Current/Proposed Benzene Control Devices MPC asked ENVIRON to develop protocols to qualify the existing activated sludge system (AIS) as an Alternative Control Device.
MPC Case History – Economic Economic Impacts for VOC Control DevicesMPC –Garyville Refinery WWTP
MPC Case History – Sustainability Economic Impacts for VOC Control DevicesMPC – Garyville Refinery WWTP
Proposed Alternative Control Device BioReactor Construction UNICELL Induced Air Flotation (IGF) Closed-Circuit Cooling Tower Marathon Petroleum Company Garyville, Louisiana Refinery
Other Significant Variables Air Distribution in Zones Depth of BioReactor Aeration Tank Surface Area Temperature Hydraulic Flow Rate & COD Loading Inputs to Site-Specific Model Major Variables • Benzene Biodegradation Rate • Table 2 represents various experimentally-determined biorates from API and ENVIRON databases • Air Flow • Biomass Concentrations • Potential Benzene Injection Locations into AIS • Benzene Loadings & Mass Balance
Models for Calculating VOC BioTreat™ Emissions • Applicable models • EPA WATER9 • TOXCHEM+ • BASTE • TOXCHEM+ is preferred – can simulate vapor to liquid phase transfer • All are identified in 40 CFR 63 Appendix C as “acceptable” for HAP emissions calculations for biological treatment Units • All three models calculate the following: • VOC emission rates (g/sec, tons/yr) • Fractions of influent VOC mass loading emitted, biodegraded, and discharged-overall and for each process unit individually • Model inputs: • Site-specific physical and operating characteristics • Site-specific compound biorates (each has default rates)
BWON Modeling Benzene Biodegradation Rates Data referred to as API is from Table 5 of the API/NPRA comments to EPA datedDecember 28, 2007.
Benzene Removal with Preliminarily Assumed Rates vs. Actual Site-Specific Rate (Corrected to 20°C)
Develop Site-Specific Biodegradation Rate;Select Appropriate EPA-Recommended Approach Source: EPA 40 CFR part 63, Appendix C, Figure 1
Develop Site-Specific Biodegradation RateBOX Test Apparatus that is typically used Typical BOX Test ApparatusOption 1 Typical BOX Test ApparatusOption 2
Develop Site-Specific Biodegradation Rate BOX Test Apparatus Developed by ENVIRON
Develop Site-Specific Biodegradation Rate BOX Test Column (without aeration) Air Supply Tank (Supplies BOX Test Column & GC) Fine-Bubble Air Diffuser (Off)
Develop Site-Specific Biodegradation Rate Voyager Photovac Online Photo-ionization GC Sample Syringes
Development of Preliminary Site-Specific Benzene Control Model Rerun Calibrated Model with Site-Specific Biodegradation Rate • The site-specific biodegradation rate, corrected to 20°C, is • 22.6 L/g VSS-hr @ 20°C at Marathon-Garyville • The Toxchem+ model will adjust the rate to the selected temperature for full-scale operating conditions
Benzene Removal with Preliminarily Assumed Rates vs. Actual Site-Specific Rate (corrected to 20°C)
Full-Scale Confirmation Performance Validation of Full-Scale SystemUsing VOC BioTreatColumn Protocols