Four Stage Process:

Feasibility Study

The feasibility study looks at two important considerations, emissions and equipment use to determine if there is flexibility in current permit or other regulatory requirements to allow a lower operating temperature of the oxidizer(s) or allow use of heat exchangers in the configuration of the control equipment.

The first step in this process is a review of existing conditions including actual and/or demonstrated emissions in reference to allowable permit or regulatory limits.  In this step, we review existing emission statements, source testing reports, permits and applicable regulations.  In certain cases, best available control technology (BACT) or lowest achievable emission rate (LAER) requirements may preclude further considerations for savings.  The objective in this step is to identify whether there is opportunity to lower oxidizer operating temperatures, while still meeting destruction efficiency (DE) requirements.

The second step in this process is a review of operating conditions and equipment configuration to determine what savings in fuel consumption are potentially achievable.  If operating temperatures can be lowered, then an estimate of fuel usage reduction and cost saving achievable can indicate whether to move forward with field evaluations.  Alternatively, configuration changes such as addition of heat exchangers can be considered to ensure operating temperatures can be achieved and compliance is maintained.

The result of the feasibility study is a preliminary determination that operational or configuration changes should be evaluated further in order to reduce overall energy consumption and cost for control.

Field Evaluation

The field evaluation is an empirical confirmation that the calculated fuel savings can be attained, while still demonstrating compliance with all applicable regulations.  The evaluation is coordinated to be conducted at or near the maximum operating capacity and typically involves having an oxidizer technical service engineer on-site to inspect and monitor the oxidizer system, during the evaluation. 

The field evaluation typically involves EPA method 25A/18 to simultaneously measure inlet and outlet VOC loading, to yield the VOC destruction removal efficiency.  An Avogadro mobile air testing laboratory is used to conduct the evaluation for greatest efficiency.  

The VOC loading will be measured on a mass bases at multiple oxidizer operating temperatures to yield the optimal or most fuel efficient set point for your oxidizer.

The client will have the option of requesting a report to document the feasibility of the lower operating temperature and the demonstration of compliance at the new operating condition.

Regulatory Approval

 Based on the results of the feasibility study and field verification through pilot studies of emissions or equipment, a better understanding of operational or configuration changes required can be communicated to regulatory agencies to determine if additional approvals are needed.  If operational conditions are included in existing permit language, then permit modifications will be required.  If not, it is still advisable to review operational and/or configuration changes with regulators and have a written account of changes which would become part of the agency record for your site, sources, and equipment.  Permit modification review cycle time needs to be considered, when evaluating and/or implementing changes.

Demonstration

This is the final phase which includes official agency authorized field verification of permanent physical changes to operations or configuration of control equipment.  Modifications to permits or other regulatory requirements will have been previously attained and the State agencies will likely request an option to observe the evaluation.

Assuming a compliance demonstration was previously conducted on the oxidizer, a test protocol was submitted and approved by the state regulating agency.  A detailed technical review of the protocol is conducted to verify the test methodology is germane and the old test protocol should be followed.

The test program is coordinated with all of the applicable parties, including the state agency, oxidizer service engineer, plant engineers and the Avogadro test group.

The evaluation will focus on conducting three official compliance tests on the new oxidizer set-point.  Regardless of the test method required by the regulating agency, the real-time methodology is conducting concurrently to provide on-site confirmation of the actual oxidizer performance and the highest level of certainty that compliance is attained.

A final report will be prepared and submitted to all parties documenting and demonstrating the new operating conditions and or configuration meets all of the compliance requirements.

Oxidizer Case Histories

Avogadro Environmental was retained by Dolco Packaging (Lawrenceville, Georgia) to perform a compliance emissions test program for VOC destruction efficiency on its Durr Industries regenerative thermal oxidizer.  After discussions with Dolco and the State of Georgia Department of Natural Resources (DNR), it was agreed to conduct triplicate test runs for destruction efficiency at three separate set point temperatures.  It was demonstrated that the oxidizer met required the destruction efficiency at each temperature value.  Accordingly, Dolco will be allowed to operate the oxidizer at a reduced temperature of 200^◦F below the permit set point.

Avogadro Environmental was retained by La Brea Bakery (Swedesboro, NJ) on various occasions to perform compliance emissions testing for VOC destruction efficiency on its Anguil catalytic oxidizer using USEPA Method 25.  Avogadro also performed VOC periodic monitoring for destruction efficiency using USEPA Methods 25A/18.  After one sampling event, Avogadro demonstrated that the required 95% VOC destruction efficiency was met at a temperature of approximately 650^oF instead of 750^oF, which was the set point temperature maintained after the last compliance test.  After permit changes, La Brea will be allowed to operate the oxidizer at a greatly reduced operating temperature, resulting in substantial fuel savings per month.

Avogadro Environmental was retained by Interstate Brands Corporation (IBC) to perform a compliance emissions test program for VOC destruction efficiency at its Philadelphia, PA. plant on bread lines associated with oxidizers 1 and 3.  After discussions with IBC and the City of Philadelphia (AMS), it was agreed to conduct one of the three test runs for destruction efficiency at a lower set point temperature.  Since it was demonstrated that the oxidizer met required the destruction efficiency at the lower temperature value, IBC has the option to run the oxidizer at a reduced temperature which resulted in significant cost savings every month, for the life of the permit.

Avogadro Environmental was retained by a “Confidential Client” to perform diagnostic emissions testing for VOC destruction efficiency on a thermal oxidizer at its NJ facility.  Sampling using USEPA Methods 25A/18 revealed oxidizer leakage.  Avogadro worked with the facility to select a vendor to replace the old, inefficient oxidizer with a new regenerative thermal oxidizer (RTO).  Avogadro also conducted the compliance emissions testing on the new RTO.  The replacement of the oxidizer has resulted in 75% fuel savings per month and yielded an 18 month payback period.