The Miscellaneous Organic Chemical Manufacturing National Emission Standards for Hazardous Air Pollutants (NESHAP), or MON, establishes emission limits and work standards for miscellaneous organic chemical manufacturing process units, wastewater treatment and conveyance systems, and
associated equipment. CH2M HILL was retained to assess the applicability and requirements of the MON rule for a polymer production facility. The facility treats process and sanitary wastewater at an existing activated sludge wastewater treatment plant (WWTP). Compliance with MON may require
a new water scrubber at the facility to control process vent streams, which would result in a new flow and organic load to the WWTP, and potentially using the existing biological treatment system to destroy the hazardous air pollutants (HAPs) contained in any Group 1 wastewater streams (Group
1 streams will be in addition to the new flow and load from the water scrubber). A Group 1 wastewater stream exceeds HAP concentrations and flow rates defined by the MON rule. Group 1 wastewater streams must be managed to control air emissions between the source and the selected treatment
or recovery process. The capacity of the existing WWTP and alternatives for routing a Group 1 wastewater stream to the existing WWTP for HAP removal in the activated sludge process was evaluated. The compliance demonstration method used for a Group 1 wastewater stream in a biological treatment
process depends on whether the system meets the definition of an enhanced biological treatment system. A preliminary design evaluation indicates that the existing aeration basins will meet the U.S. Environmental Protection Agency's (EPA's) definition of a thoroughly mixed basin in an enhanced
biological treatment system after modifications to the inlet pipes. Compliance alternatives were reviewed based on technical feasibility, ease of implementation, permitting and compliance risks, and estimated capital costs. Based on the alternatives reviewed, routing the Group 1 wastewater
stream to the existing equalization/diversion tank was recommended. The evaluation concluded that the existing treatment system could be modified to manage wastewater sources regulated by the MON.
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