Emission Master and Emissions Accountant are well suited to meet
many of the HAP emission calculation and record keeping requirements
contained in the new Chemical Manufacturing Area Source (CMAS)
regulations. The following is a list of several requirements
and a description of how environmental software from Mitchell
Scientific, Inc. can be used to meet these needs.
|
Standards and Compliance Requirements |
| |
|
§ 63.11495
What are the
management practices and other requirements? |
| [(a)(2)(i)] Use submerged loading or bottom loading. |
| Emission Master provides a
standard Subsurface Charge Model that incorporates special
subsurface modeling equations from US EPA Chapter 16.
|
| |
| [(a)(2)(ii)] Route
emissions to a fuel gas system or process in accordance with
§63.982(d) of subpart SS. |
| Emission Master provides a
General Control Device Model that enables the user to model
flares, thermal oxidizers, and other incineration devices.
This control device model can be configured with speciated
removal efficiencies for calculation purposes. For
example, a thermal oxidizer can be configured to have a
99.7% removal efficiency for methanol, a 95% removal
efficiency for Xylene, and a 0% removal efficiency for
Hydrogen Chloride vapors. |
| |
| [(a)(2)(iii)] Vapor
balance back to the storage tank or another storage tank
connected by a common header. |
| To be released soon in
Emission Master is a special Vapor Balancing control device
for Storage Tank modeling operations. This control
device model will apply a user configured removal efficiency
for working losses caused by tank car unloading operations.
|
| |
| [(a)(2)(iv)] Vent
through a closed-vent system to a control device. |
| Emission Master
provides a broad range of control device models to choose
from including condensers, scrubbers, direct contact
condensers, vacuum pumps, vapor balancing (storage tanks),
and general purpose devices (thermal oxiders, flares, ...).
|
| |
|
§
63.11496 What are the standards in compliance requirements
for process vents? |
|
[(a)] Organic HAP emissions from
batch process vents. ....If the total uncontrolled
organic HAP emissions from all batch process vents subject
to this regulation are equal to or greater than 10,000 lb/yr
then... |
| [(a)(1)] The sum of
actual organic HAP emissions from all batch process vents
within each CMPU must be determined either through process
knowledge, engineering assessment, or test data.
|
| Emission Master software
contains all of the basic batch process modeling and
calculation tools for combining process knowledge with
engineering assessment to determine the uncontrolled
organic HAP emissions from all process vessels in the CMPU.
Each emission model (filling, heating, depressurization,
transfers, ...) uses EPA Chapter 16 equations1.
Emissions Accountant enables the user to import Emission
Master calculations for each CMPU into factory folders where
an overall emissions analysis can be made. Standard
reporting and other tools contained in Emissions Accountant
enable the user to quickly determine the total uncontrolled
and controlled for all processes that share a common process
vent. |
| |
| [(a)(2)]
Alternatively, CMPU emission calculations which are
considered to be worst case operating scenarios can be used
to represent of other processes that operated in the same
CMPU at other times during the year when calculating the
annual emissions data.
|
| In Emissions Accountant,
users declare each process that is operated in the factory
for different CMPUs. Once declared, then Emission
Master calculations are imported into the process record and
combined with production records. Production data may
be entered as batches for a given month or by the batch
numbers that were produced on specific days in the month.
All production data can be imported into Emissions
Accountant directly from Microsoft Excel or files of other
format. Emission calculations for the worst case
process scenarios can be used to represent the emissions for
any of the process records in Emissions Accountant.
When this is done the calculated twelve month HAP emissions
account for the worst case twelve month emissions inventory.
Emissions Accountant also supports the US EPA PTE (Potential
To Emit) analysis that was published by the EPA in 1996.
In the PTE analysis, Emissions Accountant evaluates multiple
production operating plans as it searches for the maximum
Potential To Emit through worst case scheduling technology.
|
| |
| [(a)(3)] If emission
estimates for a CMPU are less than 10,000 lb/yr then
production records and calculated emission inventories must
be documented and maintained on an ongoing basis. If
process changes are to be considered then the impact of
these changes to the emissions inventory must be evaluated
with respect to the twelve month emissions inventory.
|
| When a process change must be
evaluated then Emission Master is used to open the earlier
process model and to make the necessary changes. The
emissions from the planned process change are calculated and
imported into Emissions Accountant for the primary process.
The next time the emissions inventory report is run it will
reflect the change in emissions due to the planned process
change. |
| |
| References: |
| 1
Subpart
VVVVVV - National Emission Standards for Hazardous Air
Pollutants for Chemical Manufacturing Area Sources. Oct 29,
2009. |
| 2
EIIP Guidance Document (Chapter 16),
Methods for Estimating Air Emissions from Chemical
Manufacturing Facilities. August
2007. |
| 3 CMPU = Chemical
Manufacturing Process Unit. |
