Miscellaneous organic NESHAP compliance for a new countermeasure flare production facility at the Milan Army Ammunition Plant

Abstract

AbstractFR Countermeasures, Inc. (FRC), a division of Flight Refuelling Ltd. of the United Kingdom, has sited a countermeasure flare production facility at the Milan Army Ammunition Plant (MLAAP) in Milan, Tennessee. Franklin Engineering Group, Inc. (Franklin Engineering) worked in cooperation with FRC to develop an air permitting strategy that would allow expedited regulatory review and approval to meet an aggressive construction schedule. This strategy addressed eventual compliance with the 40 CFR, Subpart FFFF (Miscellaneous Organic NESHAP (MON) standard) by permitting the facility as a conditional major source to allow for construction, start‐up, and initial operation with eventual operation as a major source (i.e., Title V) at full processing rates.The facility was modeled after Flight Refuelling Ltd.'s North Stockbridge, U.K., manufacturing facility, with several important distinctions. First, the regulatory standards for air emissions from this type of facility in the United States, in combination with a higher production capacity, necessitated a higher level of control for hazardous air pollutants (HAPs). Additionally, FRC had to address increased volume of effluent water from the solvent recovery process and carbon regeneration process. Finally, this effluent water had to meet the Sewer Use Agreement, which required additional acetone removal prior to discharge to the sewer. The selection of an integrated air pollution control system to achieve these environmental objectives required special consideration of safety issues inherent to energetics manufacturing.After consideration of several air pollution control technologies, FRC and Franklin Engineering selected an activated carbon adsorption system for treatment of combined gases from two main batch sources: mixing and drying processes. This system will achieve greater than 95 percent recovery of HAPs from these processes, as required for regulatory purposes. Carbon beds are regenerated via steam stripping to yield two streams: recovered hydrocarbons and a recondensed aqueous stream. Recovered solvents are reused or sold. The aqueous stream is combined with water from the batch wash process and steam stripped for solvent recovery. Crucial to assuring safe operation of the air pollution control system was the utilization of a flame isolation valve with gas cartridge actuators to eliminate potential flame/deflagration passage between each process unit. © 2004 Wiley Periodicals, Inc.