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

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. 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. This paper describes innovative protocols, developed by the authors and Marathon Petroleum Corporation (MPC) in Garyville, Louisiana, to certify a cost-effective Alternative Control Device that has a minimal carbon footprint. The authors have developed bench-scale and full-scale confirmation protocols, which delineate more realistic and reliable benzene biodegradation rates (fbio) than the EPA default rates. The biorates, thus determined, are more representative of full-scale conditions than the typical USEPA approach. 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 USEP A - Research Triangle, North Carolina. 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.