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Developing Strategies for Compliance with OCPSF Regulations

IP.com Disclosure Number: IPCOM000217200D
Publication Date: 2012-May-04
Document File: 35 page(s) / 1M

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This is the abbreviated version, containing approximately 9% of the total text.

Page 01 of 35

Developing Strategiesfor Compliance with OCPSF Regulations

Ralph L. Stephenson, Principal Engineer1 Annette J. KiMa, Senior Staff Engineer1

Gary L. Clark, Senior Engineer1


Hassan M. Gomaa, ProductTechnology Manager', Environmental

Prepared for presentation at the AIChE Spring National Meeting Session on Compliance with OCPSF Regulatory Requirements

MNCh-qorill993

Copyright 0R.L. Stephenson, A. J. KiMa, G. L. Clark, H. M. Gomaa January 1993

AlChE shall not be responsiblefor statements or opinions contained in papers or printed in its publications.

(he M. W. Kellogg Company, Houston,Texas

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Page 02 of 35

Abstract

This paper presents a brief summary of the OrganicChemical, Plastics,and Synthetic Fibers (OCPSF) regulations and a 10 point plan for compliance with the regulations. Several practicalexamples are discussed concerning the applicationof this plan to actual facilities with emphasis placed on waste minimization methods.


Page 03 of 35

Introduction

This paper presents a brief summary of the Organic Chemical, Plastics, and Synthetic Fibers (OCPSF) regulations and a 10 point planfor compliance with the regulations. Several practical examples are discussed concerning the application of this planto actual facilities with emphasis placed on waste minimizationmethods. The following section contains the OCPSF regulation summary.


1. REVIEW OF THE OCPSF REGULATIONS

On 5 November 1987the final rulingfor 40CFR 414, Effluent Guidelines and Standards for (OCPSF) was publishedinthe federal register. These regulations define the effluent limitations and pretreatment standards for all applicable process wastewaters. The standards are divided into categories by products manufactured; Subpart B - Rayon

Fibers; Subpart C - Other Fibers; Subpart D - Thermoplastic Resins; Subpart E -

Thermosetting Resins; Subpart F - Commodity Organic Chemicals; Subpart G - Bulk Organic Chemicals; and Subpart H - Specialty Organic Chemicals. Within each category, standards for meeting best practicable controltechnology currently available (BPT), best available technology economically achieveable (BAT), new source performance standards (NSPS), pretreatment standards for existing sources (PSES), and pretreatment standards for new sources (PSNS) are identified.

Determination of the relevant standards is dependant on the source type and the treatment method. Figure 1is a flow chart identtfying the steps required to determine the applicable standards. The flow chart is applicable for every category of wastes regulated under 40CFR 414.

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Page 04 of 35

Yes

Y8s

Meet BPT effluent limitations

Table 1

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Yes

Meet point source with EOP treatment and BPT/NSPS standards

Table 1 and 3

Meet point source w/o EOP treatment and BPT/NSPS standards

Table 1 and 4


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For all categories, BAT is defined as the same level of treatment as BPT when the production is less than or equal to 5 MM Ibs/yr. BPT effluent limitations for each of the subcategories are listed inTable 1....