EPA-450/3-83-005a
Distillation Operations In
Synthetic Organic Chemical
Manufacturing-
Background Information For
Proposed Standards
Emission Standards and Engineering Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air, Noise, and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
December 1983
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This report has been reviewed by the Emission Standards and Engineering Division of the Office of Air
Quality Planning and Standards, EPA, and approved for publication. Mention of trade names or commercial
products is not intended to constitute endorsement or recommendation for use. Copies of this report are
available through the Library Services Office (MD-35), U.S. Environmental Protection Agency, Research
Triangle Park, N.C. 27711, or from the National Technical Information Services, 5285 Port Royal Road,
Springfield, Virginia 22161. ,
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ENVIRONMENTAL PROTECTION AGENCY
Background Information and Draft
Environmental Impact Statement
for Distillation Operations in Synthetic
Organic Chemical Manufacturing
Prepared by:
yoack R. Farmer
• XDirector, Emission Standards and Engineering Division
v U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
1. The proposed standards of performance would limit emissions of
volatile organic compounds from new, modified, and reconstructed
distillation operations. Section 111 of the Clean Air Act (42 U.S.C.
7411), as amended, directs the Administrator to establish standards of
performance for any category of new stationary source of air pollution
that ". . . causes or contributes significantly to air pollution which
may reasonably be anticipated to endanger public health or welfare."
Many such operations are located in the States of Texas and Louisiana.
2. Copies of this document have been sent to the following Federal
Departments: Labor, Health and Human Services, Defense, Office of
Management and Budget, Transportation, Agriculture, Commerce, Interior,
and Energy; the National Science Foundation; the Council on
Environmental Quality; members of the State and Territorial Air
Pollution Program Administrators; the Association of Local Air
Pollution Control Officials; EPA Regional Administrators; and other
interested parties.
3. The comment period for review of this document is 60 days from the date
of proposal of the Standards. Mr. Gilbert H. Wood may be contacted
at (919) 541-5578 regarding the date of the comment period.
4. For additional information contact:
Mr. Robert E. Rosensteel
Chemicals and Petroleum Branch (MD-13)
U. S. Environmental Protection Agency
Research Triangle Park, N. C. 27711
Telephone: (919), 541-5671.
5. Copies of this document may be obtained from:
U. S. EPA Library (MD-35)
Research Triangle Park
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
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On February 17, 1984 the Agency issued an erratta for this document replacing
Chapter 5. The eratta can be found under the publication number designation
EPA-450/3-83-005AES
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TABLE OF CONTENTS
Chapter . Page
LIST OF TABLES . viii
LIST OF FIGURES. xii
1.0 SUMMARY. 1-1
1.1 Regulatory Alternatives for Distillation
Operations 1-1
1.2 Environmental Impact 1-2
1.3 Economic Impact 1-4
2.0 INTRODUCTION • 2-1
2.1 Background and Authority for Standards 2-1
2.2 Selection of Categories of Stationary Sources . . . 2-5
2.3 Procedure for Development of Standards of
Performance 2-7
2.4 Consideration of Costs 2-9
2.5 Consideration of Environmental Impacts 2-10
2.6 Impact on Existing Sources. ............ 2-11
2.7 Revision of Standards of Performance 2-12
3.0 VOC EMISSIONS'FROM DISTILLATION OPERATIONS AT ORGANIC
CHEMICAL MANUFACTURING PLANTS. ...... 3-1
3.1 General Industry Information . 3-2
3.2 Distillation 3-8
3.2.1 Types of Distillation 3-8
3.2.2 Fundamental Distillation Concepts 3-11
3.3 VOC Emission Points From Distillation Units .... 3-17
3.3.1 National Emissions Profile (NEP) 3-18
3.3.2 Geographical Bias in the Screened NEP. . . . 3-23
3.4 Baseline Control Level for Distillation
Operations . 3-26
3.5 References for Chapter 3 3-30
4.0 EMISSION CONTROL TECHNIQUES 4-1
4.1 Noncombustion Control Devices 4-1
4.1.1 Adsorption 4-2
4.1.1.1 Adsorption Process Description. . . 4-2
4.1.1.2 Adsorption Control Efficiency . . . 4-3
4.1.1.3 Applicability of Adsorption .... 4-5
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TABLE OF CONTENTS (CONTINUED)
Chapter Page
4.1.2 Absorption 4-5
4.1.2.1 Absorption Process Description. . . 4-5
4.1.2.2 Absorption Control Efficiency ... 4-7
4.1.2.3 Applicability of Absorption .... 4-7
4.1.3 Condensation 4-9
4.1.3.1 Condensation Process Description. . 4-9
4.1.3.2 Condenser Control Efficiency. ... 4-9
4.1.3.3 Applicability of Condensers .... 4-11
4.2 Combustion Control Devices , 4-11
4.2.1 Flares . . . . . 4-12
4.2.1.1 Flare Process Description 4-12
4.2.1.2 Flare Combustion Efficiency . . . . 4-15
4.2.1.3 Applicability of Flares 4-19
4.2.2 Thermal Incineration 4-20
4.2.2.1 Thermal Incineration Process
Description 4-20
4.2.2.2 Thermal Incineration Removal
Efficiency 4-23
4.2.2.3 Applicability of Thermal
Incinerators 4-24
4.2.3 Industrial Boiler and Process Heater
Combustion Control Devices 4-24
4.2.3.1 Industrial Boiler Process
v Description 4-26
4.2.3.2 Process Heater Description 4-26
4.2.3.3 Control Efficiency. ... 4-27
4.2.3.4 Applicability of Industrial Boilers
and Process Heaters as Control
Devices 4-28
4.2.4 Catalytic Oxidation 4-29
4.2.4.1 Catalytic Oxidation Process
Description 4-29
4.2.4.2 Catalytic Oxidizer Control
Efficiency 4-31
4.2.4.3 Applicability of Catalytic
Oxidizers 4-31
4.2.5 Advantages and Disadvantages of Control by
Combustion 4-29
4.3 Summary 4-32
4.4 References for Chapter 4 4-34
5.0 MODIFICATION AND RECONSTRUCTION. 5-1
5.1 Modification 5-1
5.2 Reconstruction 5-3
5.4 References for Chapter 5 5-7
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TABLE OF CONTENTS (CONTINUED)
«
Chapter -' • . Page
6.0 REGULATORY ANALYSIS 6-1
6.1 Overview of the Regulatory Analysis 6-1
6.2 Selection of Control Options 6^-3
6.3 Summary of the Screened National Emission
Profile (NEP) 6-5 .
6.4 Results of Regulatory Analysis 6-7
7.0 ENVIRONMENTAL AND ENERGY IMPACTS . . 7-1
7.1 Air Pollution Impacts . 7-3
7.1.1 Effects of VOC Control . . 7-3
7.1.2 Other Effects on Air Quality . 7-6
7.2 Water Pollution Impacts 7-7
7.3 Solid Waste Disposal Impacts 7-8
7.4 Energy Impacts. 7-8
7.4.1 Energy Requirements for Combustion
Devices . . 7-8
7.4.2 Other Energy Requirements. 7-9
7.5 Other Environmental Impacts 7-9
7.5.1 Considerations for Installing Control
Equipment. 7-9
7.6 Other Environmental Concerns 7-9
7.6.1 Irreversible and Irretrievable Commitment
of Resources 7-9
• 7.6,2 Environmental Impact of Delayed Standards. . 7-9
7.7 . References for Chapter 7 7-11
8.0 COSTS 8-1
8.1 Development of Control System Costs 8-1
8.1.1 Control System Sizing. . 8-2
8.1.1.1 Thermal Incinerator 8-2
8.1.1.2 Industrial Boiler 8-3
8.1.1.3 Flare 8-5
8.1.1.4 Pipeline/Compressor System 8-8
8.1.2 Capital Cost Bases 8-8
8.1.2.1 Thermal Incinerator 8-10
8.1.2.2 Industrial Boiler . 8-11
8.1.2.3 Flare 8-11
8.1.2.4 Pipeline System 8-11
8.1.3 Annualized Cost Bases. 8-12
8.1.4 Comparison of Control System Costs 8-12
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TABLE OF CONTENTS (CONTINUED)
Chapter Page
8.2 National Cost Impacts 8-19
8.2.1 Determination of Cost Impacts. ....... 8-19
8.2.2 Results of Cost Analysis 8-20
8.2.3 Major Differences Between Cost Methodologies
Used in the Regulatory and Economic
Analyses 8-22
8.3 Other Cost Considerations 8-23
8.3.1 Control Cost Accumulation for 8-23
Synthetic Organic Chemical
Manufacturing Industries with
Distillation Operations
8.3.1.1 Introduction 8-23
8.3.1.2 Data and Assumptions for
Accumulating Costs 8-26
8.3.1.3 Rolled-Through Costs 8-39
8.4 References for Chapter 8 8-41
9.0 ECONOMIC IMPACT ANALYSIS 9-1
9.1 Industry Structure 9-2
9.1.1 The Organic Chemicals Industry 9-2
9.1.1.1 Industry Definition 9-2
9.1.1.2 Products.' 9-2
9.1.1.3 Producers . 9-3
9.1.1.4 Industry Employment 9-3
9.1.1.5 Industry Finances 9-5
9.1.1.6 Prices 9-9
9.1.1.7 Foreign Trade 9-15
9.1.1.8 Chemical Groups 9-20
9.1.1.9 Petroleum Refineries 9-43
9.1.2 Projections of New Plants 9-43
9.2 Chemical Screening Analysis 9-51
9.2.1 Screening Criterion 9-53
9.2.2 Control Costs for the Screening 9-53
9.2.2.1 Direct Costs 9-54
9.2.2.2 Rolled-Through Costs of Control . ." 9-55
9.2.3 Plant Parameters 9-57
9.2.4 Results of the Screening 9-59
9.3 General Economic Impacts 9-62
9.3.1 Price Impacts 9-63
9.3.2 Production Impacts 9-63
9.3.3 Employment Impacts 9-65
9.3.4 Trade Impacts 9-65
9.3.5 Other Impacts 9-66
vm
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TABLE OF CONTENTS (CONTINUED)
Chapter
9.4 Aggregate Impacts - Socioeconomic and
Inflationary. . 9-66
9.4.1 Fifth-Year Impacts 9-66
9.4.2 Regulatory Flexibility Act Considerations. . 9-67
9.4.3 Cumulative Price Impacts from Distillation
NSPS and Other Air Standards ....... 9-67
9.5 References for Chapter 9 9-71
APPENDIX A: EVOLUTION OF THE PROPOSED STANDARD . A-l
APPENDIX B: INDEX. TO ENVIRONMENTAL CONSIDERATIONS B-l
APPENDIX C: NATIONAL EMISSIONS PROFILE C-l
APPENDIX D: EMISSION MEASUREMENT . D-l
D.I Introduction D-l
D.I.I VOC Measurement D-2
D.I.2 Emission Measurement Tests D-2
D.2 Performance Test Methods D-2
APPENDIX E: LIST OF CHEMICALS COVERED BY THE STANDARD ...... E-l
APPENDIX F: COSTING ALGORITHMS • . F-l
F.I Flare Algorithms . F-l
F.2 Industrial Boiler Algorithms F-3
• F.3 Thermal Incinerator Algorithms . . F-9
F.4 Pipeline Algorithms F-ll
F.5 References for Appendix F F-17
APPENDIX G: TRE DEVELOPMENT 6-1
G.I Definition of TRE Index G-l
G.2 Development of TRE Equation Coefficients G-2
G.3 TRE Correlation Results . G-3
G.3.1 Flare Pipeline Correlation G-3
G.3.2 Incinerator Pipeline Correlation. ......... G-4
G.3.3 Flare Correlation . G-4
G.3.4 Incinerator Correlation G-5
6.3.5 Total Annualized Cost Equations ......... G-5
G.4 Development of TRE and TRE Index Equations . G-6
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TABLE OF CONTENTS (CONTINUED)
Chapter Page
APPENDIX H: UNITED STATES ORGANIC CHEMICAL PRODUCERS, PLANT
LOCATIONS, AND CHEMICALS PRODUCED, 1978 H-l
APPENDIX I: SCREENING DATA AND RESULTS 1-1
I.I Screening Data and Assumptions1 1-14
1.2 Screening Results 1-16
1.3 References for Appendix I 1-29
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LIST OF TABLES
Table Page
1-1 Matrix of Environmental and Economic Impacts for the
Extremes of Regulatory Alternatives Considered 1-3
3-1 Percentage of Feedstock Chemicals from Various Sources . . 3-3
3-2 Estimated Production and Chemical Coverage for Various
Production Levels 3-7
3-3 Overview of the National Emission Profile 3-24
3-4 Overview of the Screened National Emission Profile .... 3-25
4-1 Flare Emission Test Studies Complete 4-17
6-1 Overview of the Screened National Emission Profile .... 6-6
6-2 Relationship Between Number of Units Expected to be
Controlled and Percentage of Units Required to be
Controlled for some 'TRE Cutoffs' . 6-10
7-1 VOC Emission Reduction and Energy Requirements for
Flare Preference . . 7-4
7-2 VOC Emission Reduction and Energy Requirements for
Boiler Preference. 7-5
8-1 Incinerator General Design Specifications 8-4
8-2 Industrial Boiler General Design Specifications 8-6
8-3 Flare General Design Specifications 8-7
8-4 Capital Cost Equations for New Flares and Incinerators . . 8-9
8-5 Bases for Annual i zed Control System Costs 8-13
8-6 Cost Comparisons for Control of Individual Distillation
Vent Streams Listed in the NEP . . . 8-15
8-7 Annualized Control Costs of Eight Air Standards for
Twelve Chemical Groups Fifth Year After Proposal .... 8-27
8-8 Number of Benzene-Consuming Plants Projected to be
Affected by Distillation NSPS, 1982-1987, United States. 8-29
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LIST OF TABLES (Continued)
Table Page
8-9 Fifth Year Annualized Costs of the NSPS for Air Oxidation
Processes, by Specific Industry: 26 Chemical Industries,
United States, 1978 8-37
8-10 Fifth-Year Annualized Cost of Distillation NSPS
by Specific Chemical Groups, 14 Chemical Groups,
United States, 1978 . 8-38
8-11 Total Fifth Year Annualized Cost of Control Accumulated
for Eight Potential Air Regulations, 12 Chemical
Groups, United States, 1978 8-40
9-1 Chemical Sales as a Percentage of Total Sales at
the 50 Largest U. S. Chemical Producers 9-4
9-2 Combined Cash Flow at 15 Major U.S. Chemical Producers. . 9-10
9-3 Debt Ratios at Chemical Companies and All
Manufacturing Companies 9-11
9-4 U. S. Balance of Trade in Chemicals and All Products . . . 9-16
9-5 Selected Chemical Imports and Exports: Levels and
Percentages of U. S. Production 9-17
9-6 U. S. Plants, Producers, Capacity, Production,
Capacity Utilization, and Price (Feedstocks) 9-23
9-7 U. S. Plants, Producers, Capacity, Production,
Capacity Utilization, and Price (Intermediates:
General Aromatics) 9-26
9-8 U. S. Plants, Producers, Capacity, Production,
Capacity Utilization, and Price (Intermediates:
General Nonaromatics) 9-27
9-9 U. S. Plants, Producers, Capacity, Production,
Capacity Utilization, and Price (Intermediates:
Synthetic Elastomers). ..'...- 9-30
9-10 U. S. Plants, Producers, Capacity, Production,
Capacity Utilization, and Price (Intermediates:
Plastics and Fibers) 9-31
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LIST OF TABLES (Continued) ,
Table • Page
9-11 U. S. Plants, Producers* Capacity, Production,
Capacity Utilization, and Price (Intermediates:
Plast'icizers). . .... .......' . 9-35
9-12 U. S. Plants, Producers, Capacity, Production,
Capacity Utilization, and Price (Intermediates:
Pesticides). . . .... .'. ... . . . . . . . . ... .. .. 9-36
9-13 U. S. Plants, Producers, Capacity, Production, Capacity
Utilization, and Price (Intermediates: Dyes). ..... 9-37
9-14 U. S. Plants, Producers, Capacity, Production,
Capacity Utilization, and Price (Solvents) 9-38
9-15 U. S. Plants, Producers, Capacity, Production, Capacity
Utilization, and Price (Detergents and Surfactants). . . 9-40
9-16 U. S. Plants, Producers, Capacity, Production,
Capacity Utilization, and Price (Fuel Additives) . . . . 9-41
9-17 U. S. Plants, Producers, Capacity, Production,
Capacity Utilization, and Price (Aerosol Propellants
and Refrigerants) 9-42
9-18 U. S. Plants, Producers, Capacity, Production,
Capacity Utilization, and Price (Coatings) 9-44
9-19 U. S. Plants, Producers, Capacity, Production,
Capacity Utilization, and Price (Miscellaneous
End-Use Chemicals) 9-45
9-20 Total and Average Crude Distillation Capacity by Year. . . ,9-46
9-21 Product Yields of Refineries in the U. S.. . . . . . . . . 9-47
9-22 Equations for Projecting New Capacity and Plants
for the Organic Chemicals Industry 9-48
9-23 Projected Number of New and Replacement Distillation
Plants in the Organic Chemicals Industry Between
November 1982 and November 1987. ............ 9-52
xm
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LIST OF TABLES (Continued)
Table Page
9-24 Distribution of Chemicals According to Size of
Potential Price Increase 9-60
9-25 Average Throughput and Annual Plant Sales 9-64
9-26 Price Increases Due to Direct and Indirect Costs of
Control in the Synthetic Organic Chemicals Industry
for Eight Air Emission Standards 9-69
F-l Pipeline Components . F-15
G-l Coefficients for TRE ($/Mg) Equation G-7
G-2 Coefficients for TRE Index Equation G-8
1-1 Organic Chemicals Industry List of Chemical
Products Included in Computer Screening 1-2
1-2 Screening Data and Assumptions 1-18
1-3 Screening Results 1-24
xiv
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LIST OF FIGURES
Figure
3-1
3-2
3-3
3-4
3-5
3-6
3-7
3-8
3-9
4-1 ,
4-2
4-3
4-4
4-5
4-6
4-7
5-1
8-1
The Interwoven Nature of Feedstocks for the Organic
Chemicals Manufacturing Industry ............
Chain of Chemicals Made from Ethylene. . . .
Flash Distillation ......
A Conventional Fractionating Column
Potential VOC Emission Points for a Nonvacuum
Distillation Column
Potential VOC Emission Points for a Vacuum Distillation
Column Using Steam Jet Ejectors with a Barometric
Condenser
Potential VOC Emission Points for a Vacuum Distillation
Column Using Steam Jet Ejectors and Surface Condensers .
Potential VOC Emission Points for a Vacuum Distillation
Column Using a Vacuum Pump
Development of the Baseline Control Profile. .
Two Stage Regenerative Adsorption System ....
Packed Tower for Gas Adsorption
Condensation System. ...... ....
Steam Assisted Elevated Flare System .
Discrete Burner, Thermal Oxidizer
Distributed Burner, Thermal Oxidizer
Catalytic Oxidizer
Vapor Recompression
Summary of Annual i zed Control System Costs for the
Five Individual Vent Stream Cases Selected .......
Page
3-4
3-5
3-10
3-12
3-19
3-20
3-21
3-22
3-29
4-4
4-8
4-10
4-13
4-22
4-22
4-30
5-4
8-17
XV
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LIST OF FIGURES (Continued)
Figure Page
8-2 National Annualized Cost of Combustion Control Using
Flare and Incinerator Costs as a Function of the
Associated National Percent Reduction in Uncontrolled
VOC Emissions from Distillation Operations 8-21
9-1 U. S. Chemicals Industry Annual Profit Margin,
1970 - 1980 9-6
9-2 U. S. Chemicals Industry Annual Return on Stockholders'
Equity 9-7
9-3 Composite Index of Five Oil-Based Organic Chemicals
and Index of Crude Oil Prices . . 9-14
9-4 Processing Flow for 219 Organic Chemicals. . 9-21
F-l Distribution of Industrial Boiler Types. , F-5
F-2 Header Schematic F-12
xvi
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1. SUMMARY
New source performance standards (NSPS) are being developed for the
synthetic organic chemical manufacturing industry under authority of
Section 111 of the Clean Air Act, as amended in 1977. Emissions of volatile
organic compounds (VOC) from various sources in this source category are
being considered under several standards development programs. This back-
ground information document supports the development of NSPS for VOC
emissions from distillation operations involved in the manufacture of
synthetic organic chemicals. A list of affected chemicals considered in
this Document is presented in Appendix E.
1.1 REGULATORY ALTERNATIVES FOR DISTILLATION OPERATIONS
There are numerous control techniques applicable to the reduction of
VOC emissions from distillation operations. Some of these techniques are
used primarily for product recovery. These techniques include condensation,
carbon adsorption, and gas absorption. However, since these techniques can
only be used in very specific circumstances, they are not considered univer-
sally applicable to all distillation operations. One control technique,
combustion; was deemed to be applicable to emissions from distillation
operations in general. Combustion devices capable of achieving high
destruction efficiency were selected as best demonstrated technology (BDT)
for evaluating the regulatory impacts. The combustion devices considered in
the regulatory analysis included flares, boilers, and thermal incinerators.
These devices were determined to attain at least 98 percent destruction
efficiency (the control level assumed in the regulatory analysis).
The regulatory analysis was based on the control of varying numbers of
distillation units described in a statistical profile. The profile used in
the analysis was constructed from data on the distillation units tabulated
in Appendix C. The regulatory analysis examined the impacts of applying
combustion control to increasing numbers of distillation units in the
1-1
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statistical profile (corresponding to increasing levels of control across
the entire profile). This method of analysis simulates control alternatives
that range from control of no new units to control of all new units. In
order to choose which units would be controlled first, the units in the
profile were ranked. The ranking of distillation units for control was
based on the total resource effectiveness (TRE), a value relating the cost
of combustion control for the unit to the VOC destroyed by the combustion
control. Those units exhibiting the smaller TRE values were selected for
control first.
As is detailed in Appendix G, a particular TRE value can be selected to
serve as a limit for requiring combustion control. When used in a standard,
TRE values below the limit would dictate use of combustion control. And
values above the limit would indicate that a higher level of control was
already in place for purposes such as product recovery or that the
distillation column had inherently small VOC emissions that proved extremely
costly to control. The TRE ranking was a primary tool used in examining
regulatory alternatives.
1.2 ENVIRONMENTAL IMPACTS
When applied to a given distillation unit, the combustion devices
examined as BDT can achieve 98 percent destruction of VOC contained in the
vent stream. Thus, the control levels achieved in the regulatory analysis
ranged from the baseline control level of about 81 percent to the 98 percent
control level assuming control of all distillation units. In addition,
other impacts of the regulatory alternatives (water pollution, solid waste,
energy) were examined. A matrix describing the impacts of the extremes of
the regulatory analysis (no control, total control) is presented in
Table 1-1.
In the absence of NSPS (baseline control level), VOC emissions from
projected new, modified, or reconstructed facilities would be 51,000 Mg/yr
(56,000 tons/yr). The regulatory analysis considered alternatives that
would result in VOC emission reductions up to 46,000 Mg/yr (50,000 tons/yr).
The upper bound on the control alternatives examines represents control of
1-2
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TABLE 1-1. MATRIX OF ENVIRONMENTAL AND ECONOMIC IMPACTS FOR
THE EXTREMES OF REGULATORY ALTERNATIVES CONSIDERED
Administrative Action
Air
Impact
Water
Impact
Solid
Waste
Impact
Energy
Impact
Economic
Impact
No NSPS 00
Control All Units ' +4 -1 -1 -I to +1 -1 to -2
Key: 0 No Impact
1 Negligible Impact
2 Small Impact
3 Moderate Impact
4 Large Impact
+ Beneficial Impact
- Adverse Impact
1-3
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about 89 percent of the VOC emissions not currently controlled under the
baseline assumptions. Increases in other air pollutants as a result of the
VOC emissions controls examined are considered negligible. And no direct
solid wastes are expected to result from implementation of any of the
regulatory alternatives.
No increase in total plant wastewater was projected since there is no
organic wastewater effluent associated with the combustion devices
considered in the regulatory analysis. Potential water pollution could
result where additional product recovery is employed to reduce emissions.
Carbon adsorption and gas absorption are the only product recovery
techniques currently in use in the industry which have an associated organic
wastewater effluent. Based on past industry experience, very few new
distillation facilities are expected to employ carbon adsorption or gas
absorption. Therefore, the wastewater generated as a result of the
regulatory alternatives was expected to be minimal.
The impact on the projected national energy usage depends upon the
regulatory alternative considered (degree of overall control) and the BDT
assumed (flare, boiler, incinerator). , For the regulatory extreme of control
of all distillation units, the projected national energy usage in the fifth
year ranged from 1.2 billion MJ/yr (190 thousand barrels of fuel oil equiva-
lent) for a flare preference on nonhalogenated streams to a savings of
2.9 billion MJ/yr (460 thousand barrels of fuel oil equivalent) for a boiler
preference on nonhalogenated streams. For both estimates, incinerators were
assumed to be used only for distillation vent streams containing corrosive
compounds.
1.3 ECONOMIC IMPACT
The projected annualized costs of the regulatory alternatives depend
upon the degree of control considered and the BDT examined. As was done for
the energy impacts, a range of annualized costs resulted from considering a
flare preference and a boiler preference for control of non-corrosive
streams in the statistical profile. For control of all units, the projected
annualized costs in the fifth year ranged from about $20 million for the
1-4
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flare preference to about $0.2 million for the boiler preference. Almost
all annualized costs for boilers were credits due to the energy savings
resulting from combustion of VOC as a supplement to the fuel, required.
An economic screening analysis (see Chapter 9 and Appendix I) based on
worst case costing of combustion control (assuming incineration of all
streams in a plant, high vent stream flowrates, etc.) indicated that most of
the 219 chemicals considered under the scope of this program would comfort-
ably pass a 5 percent price increase criterion. Closer analysis of the few
chemicals failing the initial screening indicated that all chemicals that
would be affected by NSPS for distillations operations could pass the
5'percent increase criterion. And the vast majority could pass more
stringent price increase criteria.
1-5
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2. INTRODUCTION
2.1 BACKGROUND AND AUTHORITY FOR STANDARDS
Before standards of performance are proposed as a Federal regulation,
air pollution control methods available to the affected industry and the
associated costs of installing and maintaining the control equipment are
examined in detail. Various levels of control based on different
technologies and degrees of efficiency are examined. Each potential
level of control is studied by EPA as a prospective basis for a standard.
The alternatives are investigated in terms of their impacts on the
economics and well-being of the industry, the impacts on the national
economy, and the impacts on the environment. This document summarizes
the information obtained through these studies so that interested
persons will be able to see the information considered by EPA in the
development of the proposed standard.
Standards of performance for new stationary sources are established
under Section 111 of the Clean Air Act (42 U.S.C. 7411) as amended,
hereinafter referred to as the Act. Section 111 directs the Administrator
to establish standards of performance for any category of new stationary
source of air pollution which ". . . causes, or contributes significantly
to air pollution which may reasonably be anticipated to endanger public
health or welfare."
The Act requires that standards of performance for stationary
sources reflect ". . . the degree of emission reduction achievable which
(taking into consideration the cost of achieving such emission reduc-
tion, and any nonair quality health and environmental impact and energy
requirements) the Administrator determines has been adequately demon-
strated for that category of sources." The standards apply only to
stationary sources, the construction or modification of which commences
after regulations are proposed by publication in the Federal Register.
2-1
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The 1977 amendments to the Act altered or added numerous provisions
that apply to the process of establishing standards of performance.
1. EPA is required to list the categories of major stationary
sources that have not already been listed and regulated under standards
of performance. Regulations must be promulgated for these new categories
on the following schedule:
a. 25 percent of the listed categories by August 7, 1980.
b. 75 percent of the listed categories by August 7, 1981.
c. 100 percent of the listed categories by August 7, 1982.
A governor of a State may apply to the Administrator to add a category
not on the list or may apply to the Administrator to have a standard of
performance revised.
2. EPA is required to review the standards of performance every
four years and, if appropriate, revise them.
3. EPA is authorized to promulgate a standard based on design,
equipment, work practice, or operational procedures when a standard
based on emission levels is not feasible.
4. The term "standards of performance" is redefined, and a new
term "technological system of continuous emission reduction" is defined.
The new definitions clarify that the control system must be continuous
and may include a low- or non-polluting process or operation.
5. The time between the proposal and promulgation of a standard
under Section 111 of the Act may be extended to six months.
Standards of performance, by themselves, do not guarantee protection
of health or welfare because they are not designed to achieve any
specific air quality levels. Rather, they are designed to reflect the
degree of emission limitation achievable through application of the best
adequately demonstrated technological system of continuous emission
reduction, taking into consideration the cost of achieving such emission
reduction, any non-air-quality health and environmental impacts, and
energy requirements.
Congress had several reasons for including these requirements.
First, standards with a degree of uniformity are needed to avoid situations
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where some States may attract industries by relaxing standards relative
to other States. Second, stringent standards enhance the potential for
long-term growth. Third, stringent standards may help achieve long-term
cost savings by avoiding the need for more expensive retrofitting when
pollution ceilings may be reduced in the future. Fourth, certain types
of standards for coalburning sources can adversely affect the coal
market by driving up the price of low-sulfur coal or effectively excluding
certain coals from the reserve base because their untreated pollution
potentials are high. Congress does not intend that new source performance
standards contribute to these problems. Fifth, the standard-setting
process should create incentives for improved technology.
Promulgation of standards of performance does not prevent State or
local agencies from adopting more stringent emission limitations for the
same sources. States are free under Section 11C of the Act to establish
even more stringent emission limits than those established under Section 111
or those necessary to attain or maintain the National Ambient Air
Quality Standards (NAAQS) under Section 110. Thus, new sources may in
some cases be subject to limitations more stringent than standards of
performance under Section 111, and prospective owners and operators of
new sources should be aware of this possibility in planning for such
facilities.
A similar situation may arise when a major emitting facility is to
be constructed in a geographic area that falls under the prevention of
significant deterioration of air quality provisions of Part C of the
Act. These provisions require, among other things, that major emitting
facilities to be constructed in such areas are to be subject to best
available control technology. The term Best Available Control Technology
(BACT), as defined in the Act, means
... an emission limitation based on the maximum degree of reduction
of each pollutant subject to regulation under this Act emitted
from, or which results from, any major emitting facility, which the
permitting authority, on a case-by-case basis, taking into account
energy, environmental, and economic impacts and other costs,
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determines is achievable for such facility through application of
production processes and available methods, systems, and techniques,
including fuel cleaning or treatment or innovative fuel combustion
techniques for control of each such pollutant. In no event shall
application of "best available control technology" result in emissions
of any pollutants which will exceed the emissions allowed by any
applicable standard established pursuant to Section 111 or 11.2 of
this Act. (Section 169(3))
Although standards of performance are normally structured in terms
of numerical emission limits where feasible, alternative approaches are
sometimes necessary. In some cases physical measurement of emissions
from a new source may be impractical or exorbitantly expensive. Section lll(h)
provides that the Administrator may promulgate a design or equipment
standard in those cases where it is not feasible to prescribe or enforce
a standard of performance. For example, emissions of hydrocarbons from
storage vessels for petroleum liquids are greatest during tank filling.
The nature of the emissions, high concentrations for short periods
during filling and low concentrations for longer periods during storage,
and the configuration of storage tanks make direct emission measurement
impractical. Therefore, a more practical approach to standards of
performance for storage vessels has been equipment specification.
In addition, Section lll(i) authorizes the Administrator to grant
waivers of compliance to permit a source to use innovative continuous
emission control technology. In order to grant the waiver, the Administrator
must find: (1) a substantial likelihood that the technology will
produce greater emission reductions than the standards require or an
equivalent reduction at lower economic energy or environmental cost;
(2) the proposed system has not been adequately demonstrated; (3) the
technology will not cause or contribute to an unreasonable risk to the
public health, welfare, or safety; (4) the governor of the State where
the source is located consents; and (5) the waiver will not prevent the
attainment or maintenance of any ambient standard. A waiver may have
conditions attached to assure the source will not prevent attainment of
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any NAAQS. Any such condition will have the force of a performance
standard. Finally, waivers have definite end dates and may be terminated
earlier if the conditions are not met or if the system fails to perform
as expected. In such a case, the source may be given up to 3 years to
meet the standards with a mandatory progress schedule.
2.2 SELECTION OF CATEGORIES OF STATIONARY SOURCES
Section 111 of the Act directs the Adminstrator to list categories
of stationary sources. The Administrator "... shall include a cate-
gory of sources in such list if in his judgment it causes, or contri-
butes significantly to, air pollution which may reasonably be anticipated
to endanger public health or welfare." Proposal and promulgation of
standards of performance are to follow.
Since passage of the Clean Air Amendments of 1970, considerable
attention has been given to the development of a system for assigning
priorities to various source categories. The approach specifies areas
of interest by considering the broad strategy of the Agency for imple-
menting the Clean Air Act. Often, these "areas" .are actually pollutants
emitted by stationary sources. Source categories that emit these
pollutants are evaluated and ranked by a process involving such factors
as (1) the level of emission control (if any) already required by State
regulations, (2) estimated levels of control that might be required from
standards of performance for the source category, (3) projections of
growth and replacement of existing facilities for the source category,
and (4) the estimated incremental amount of air pollution that could be
prevented in a preselected future year by standards of performance for
the source category. Sources for which new,source performance standards
were promulgated or under development during 1977, or earlier, were
selected on these criteria.
The Act amendments of August 1977 establish specific criteria to be
used in determining priorities for all major source categories not yet
listed by EPA. These are (1) the quantity of air pollutant emissions
that each such category will emit, or will be designed to emit; (2) the
extent to which each such pollutant may reasonably be anticipated to
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endanger public health or welfare; and (3) the mobility and competitive
nature of each such category of sources and the consequent need for
nationally applicable new source standards of performance.
The Administrator is to promulgate standards for these categories
according to the schedule referred to earlier.
In some cases it may not be feasible immediately to develop a
standard for a source category with a high priority. This might happen
when a program of research is needed to develop control techniques or
because techniques for sampling and measuring emissions may require
refinement. In the developing of standards, differences in the time
required to complete the necessary investigation for different source
categories must also be considered. For example, substantially more
time may be necessary if numerous pollutants must be investigated from a
single source category. Further, even late in the development process
the schedule for completion of a standard may change. For example,
inablility to obtain emission data from we11-controlled sources in time
to pursue the development process in a systematic fashion may force a
change in scheduling. Nevertheless, priority ranking is, and will
continue to be, used to establish the order in which projects are
initiated and resources assigned.
After the source category has been chosen, the types of facilities
within the source category to which the standard will apply must be
determined. A source category may have several facilities that .cause
air pollution, and emissions from some of these facilities may vary from
insignificant to very expensive to control. Economic studies of the
source category and of applicable control technology may show that air
pollution control is better served by applying standards to the more
severe pollution sources. For this reason, and because there is no
adequately demonstrated system for controlling emissions from certain
facilities, standards often do not apply to all facilities at a source.
For the same reasons, the standards may not apply to all air pollutants
emitted. Thus, although a source category may be selected to be covered
by a standard of performance, not all pollutants or facilities within
that source category may be covered by the standards.
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2.3 PROCEDURE FOR DEVELOPMENT OF STANDARDS OF PERFORMANCE
Standards of performance must (1) realistically reflect best
demonstrated control practice; (2) adequately consider the cost, the
non-air-quality health and environmental impacts, and the energy require-
ments of such control; (3) be applicable to existing sources that are
modified or reconstructed as well as new installations; and (4) meet
these conditions for all variations of operating conditions being
considered anywhere in the country.
The objective of a program for developing standards is to identify
the best technological system of continuous emission reduction that has
been adequately demonstrated. The standard-setting process involves
three principal phases of activity: (1) information gathering, (2) analysis
of the information, and (3) development of the standard of .performance.
During the information-gathering phase, industries are queried
through a telephone survey, letters of inquiry, and plant visits by EPA
representatives. Information is also gathered from many .other sources,
and a literature search is conducted. From the knowledge acquired about
the industry, EPA selects certain plants at which emission tests are
conducted to provide reliable data that characterize the pollutant
emissions from well-controlled existing facilities.
In the second phase of a project, the information about the industry
and the pollutants emitted is used in analytical studies. Hypothetical
"model plants" are defined to provide a common basis for analysis. The
model plant definitions, national pollutant emission data, and existing
State regulations governing emissions from the source category are then
used in establishing "regulatory alternatives." (For the distillation
standard, there are a few deviations from this model plant and regula-
tory analysis approach, as described in Chapters 6 through 8.) These
regulatory alternatives are essentially different levels of emission
control.
EPA conducts studies to determine the impact of each regulatory
alternative on the economics of the industry and on the national economy,
on the environment, and on energy consumption. From several possibly
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applicable alternatives, EPA selects the single most plausible regula-
tory alternative as the basis for a standard of performance for the
source category under study.
In the third phase of a project, the selected regulatory alternative
is translated into a standard of performance, which, in turn, is written
in the form of a Federal regulation. The Federal regulation, when
applied to newly constructed plants, will limit emissions to the levels
indicated in the selected regulatory alternative.
As early as is practical in each standard-setting project, EPA
representatives discuss the possibilities of a standard and the form it
might take with members of the National Air Pollution Control Techniques
Advisory Committee. Industry representatives and other interested
parties also participate in these meetings.
The information acquired in the project is summarized in the
Background Information Document (BID). The BID, the standard, and a
preamble explaining the standard are widely circulated to the industry
being considered for control, environmental groups, other government
agencies, and offices within EPA. Through this extensive review pro-
cess, the points of view of expert reviewers are taken into consideration
as changes are made to the documentation.
A "proposal package" is assembled and sent through the offices of
EPA Assistant Administrators for concurrence before the proposed standard
is officially endorsed by the EPA Administrator. After being approved
by the EPA Administrator, the preamble and the proposed regulation are
published in the Federal Register.
As a part of the Federal Register announcement of the proposed
regulation, the public is invited to participate in the standard-setting
process. EPA invites written comments on the proposal and also holds a
public hearing to discuss the proposed standard with interested parties.
All public comments are summarized and incorporated into a second volume
of the BID. All information reviewed and generated in studies in
support of the standard of performance is available to the public in a
"docket" on file in Washington, D.C.
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Comments from the public are evaluated, and the standard of performance
may be altered in response to the comments.
The significant comments and EPA's position on the issues raised
are included in the "preamble" of a promulgation package," which also
contains the draft of the final regulation. The regulation is then
subjected to another round of review and refinement until it is approved
by the EPA Administrator. After the Administrator signs the regulation,
it is published as a "final rule" in the Federal Register.
2.4 CONSIDERATION OF COSTS
Section 317 of the Act requires an economic impact assessment with
respect to any standard of performance established under Section 111 of
the Act. The assessment is required to contain an analysis of: (1) the
costs of compliance with the regulation, including the extent to which
the cost of compliance varies depending on the effective date of the
regulation and the development of less expensive or more efficient
methods of compliance; (2) the potential inflationary or recessionary
effects of the regulation; (3) the effects the regulation might have on
small business with respect to competition; (4) the effects of the
regulation on consumer costs; and (5) the effects of the regulation on
energy use. Section 317 also requires that the economic impact assessment
be as extensive as practicable.
The economic impact of a proposed standard upon an industry is
usually addressed both in absolute terms and in terms of the control
costs that would be incurred as a result of compliance with typical,
existing State control regulations. An incremental approach is necessary
because both new at|d existing plants would be required to comply with
State regulations in the absence of a Federal standard of performance.
This approach requires a detailed analysis of the economic impact from
the cost differential that would exist between a proposed standard of
performance and the typical State standard.
Air pollutant emissions may cause water pollution problems, and
captured potential air pollutants may pose a solid waste disposal
problem. The total environmental impact of an emission source must,
therefore, be analyzed and the costs determined whenever possible.
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A thorough study of the profitability and price-setting mechanisms
of the industry is essential to the analysis so that an accurate estimate
of potential adverse economic impacts can be made for proposed standards.
It is also essential to know the capital requirements for pollution
control systems already placed on plants so that the additional capital
requirements necessitated by these Federal standards can be placed in
proper perspective. Finally, it is necessary to assess the availability
of capital to provide the additional control equipment needed to meet
the standards of performance.
2.5 CONSIDERATION OF ENVIRONMENTAL IMPACTS
Section 102(2)(C) of the National Environmental Policy Act (NEPA)
of 1969 requires Federal agencies to prepare detailed environmental
impact statements on proposals for legislation and other major Federal
actions significantly affecting the quality of the human environment.
The objective of NEPA is to build into the decisionmaking process of
Federal agencies a careful consideration of all environmental aspects of
proposed actions.
In a number of legal challenges to standards of performance for
various industries, the United States Court of Appeals for the District
of Columbia Circuit has held that environmental impact statements need
not be prepared by the Agency for proposed actions under Section 111 of
the Clean Air Act. Essentially, the Court of Appeals has determined
that the best system of emission reduction requires the Administrator to
take into account counter-productive environmental effects of a proposed
standard, as well as economic costs to the industry. On this basis,
therefore, the Court established a narrow exemption from NEPA for EPA
determination under Section 111.
In addition to these judicial determinations, the Energy Supply and
Environmental Coordination Act (ESECA) of 1974 (PL-93-319) specifically
exempted proposed actions under the Clean Air Act from NEPA requirements.
According to Section 7(c)(,l), "No action taken under the Clean Air Act
shall be deemed a major Federal action significantly affecting the
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quality of the human environment within the meaning of the National
Environmental Policy Act of 1969." (15 U.S.C. 793(c)(l)).
Nevertheless, the Agency has concluded that the preparation of
environmental impact statements could have beneficial effects on certain
regulatory actions. Consequently, although not legally required to do
so by Section 102(2)(C) of NEPA, EPA has adopted a policy requiring that
environmental impact statements be prepared for various regulatory
actions, including standards of performance developed under Section 111
of the Act. This voluntary preparation of environmental impact statements,
however, in no way legally subjects the Agency to NEPA requirements.
To implement this policy, a separate section in this document is
devoted solely to an analysis of the potential environmental impacts
associated with the proposed standards. Both adverse and beneficial
impacts in such areas as air and water pollution, increased solid waste
disposal, and increased energy consumption are discussed.
2.6 IMPACT ON EXISTING SOURCES
Section 111 of the Act defines a new source as ". . . any stationary
source, the construction or modification of which is commenced . . ."
after the proposed standards are published. An existing source is
redefined as a new source if "modified" or "reconstructed" as defined in
amendments to the general provisions of Subpart A of 40 CFR Part"60,
which were promulgated in the Federal Register on December 16, 1975
(40 FR 58416).
Promulgation of a standard of performance requires States to
establish standards of performance for existing sources in the same
industry under Section lll(d) of the Act if the standard for new sources
limits emissions of a designated pollutant (i.e., a pollutant for which
air quality criteria have not been issued under Section 108 or which has
not been listed as a hazardous pollutant under Section 112). If a State
does not act, EPA must establish such standards. General provisions
outlining procedures for control of existing sources under Section lll(d)
were promulgated on November 17, 1975, as Subpart B of 40 CFR Part 60
(40 FR 53340).
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2.7 REVISION OF STANDARDS OF PERFORMANCE
Congress was aware that the level of air pollution control achievable
by any industry may improve with technological advances. Accordingly,
Section 111 of the Act provides that the Administrator ". . . shall, at
least every four years, review and, if appropriate, revise ..." the
standards. Revisions are made to assure that the standards continue to
reflect the best systems that become available in the future. Such
revisions will not be retroactive, but will apply to stationary sources
constructed or modified after the proposal of the revised standards.
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3. VOC EMISSIONS FROM DISTILLATION OPERATIONS AT
ORGANIC CHEMICAL MANUFACTURING PLANTS
The major processing steps employed in organic chemical manufacturing
plants can be classified in two broad categories: conversion and separa-
tion. Conversion processes are chemical reactions that alter the molecular
structure of the compounds involved. Separation operations divide mixtures
into distinct fractions. A variety of unit operations such as filtration,
crystallization, distillation or extraction can be used for separation.
Selection of the separation technique depends upon the physical characteris-
tics of the compounds in the mixture (thermal scability, boiling point,
melting point, solubility) and the desired purity of the fractions. The
predominant separation technique at large scale organic chemical manufac-
turing plants is distillation.
i
Distillation is a unit operation used to separate one or more inlet
feed streams into two or more outlet product streams, each having
constituent concentrations different from the concentrations found in the
inlet feed stream. The emissions of volatile organic compounds (VOC) from
distillation units depend upon the operating conditions. The physical
properties of compounds being separated and economic considerations are the
primary factors used in establishing the operating conditions of distilla-
tion units.
This chapter describes the use of distillation operations in organic
chemical manufacturing plants. This chapter also includes a general
discussion of distillation operations and the associated VOC emissions from
distillation vent streams. In the final section of this chapter, the
baseline control profile is discussed and the baseline control level is
established.
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3.1 GENERAL INDUSTRY INFORMATION
Most organic chemicals are manufactured in a multi-level system of
chemical processes which is based on about 15 feedstock chemicals. These
feedstocks are processed through one or more process levels and result in
hundreds of intermediate or finished chemicals. These feedstocks originate
from three basic raw materials: crude oil, natural gas, and coal. Basic
raw materials for various feedstock chemicals are presented in Table 3-1.
Figure 3-1 shows the highly integrated supply system for these feedstock
chemicals from the three basic raw materials.
The chemical industry may be described in terms of an expanding system
of production stages. Refineries, natural gas plants and coal tar
distillation plants represent the first stage of the production system. As
illustrated in Figure 3-1, these industries supply the feedstock chemicals
from which most other organic chemicals are made. The organic chemical
industry represents the remaining stages of the system. Chemical manufac-
turers use the feedstocks produced in the first stage to produce
intermediate chemicals (secondary production stages can include parts of
refineries) and final products. Manufacturing plants producing chemicals at
the end of the production system are usually smaller operations since only a
narrow spectrum of finished chemicals are being produced. The end products
from these plants are heavier, less volatile compounds than the original
feedstock. Thus, more effort is generally spent to prevent the valuable
products from being wasted. The products from ethylene shown in Figure 3-2
are an example of a system of production stages from a feedstock chemical.
The production of feedstock chemicals is an extremely dynamic industry
which may quickly change its sources of basic raw materials depending upon
availability and costs. These facts are illustrated in the cases of benzene
and ethylene. In 1967, 9.3 percent of the total domestically produced
benzene came from coal tar; by 1979, economic and technological changes at
petroleum refineries had reduced this share from coal tar to only
3.6 percent. ' The same type of changes occurred for ethylene. Natural
gas was the source of 75 percent of domestically produced ethylene in 1970,
3-2
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TABLE 3-1. PERCENTAGE OF FEEDSTOCK CHEMICALS FROM VARIOUS SOURCES3
Feedstock Coal Tar
Chemical . Distillation
Benzene . .3.6
Butane .
1-Butene
2-Butene
Ethane
Ethyl ene
Isobutane
Isopentane
Methane
Naphthalene X
Pentane
Propane
Propylene
Toluene 0.9
Xylenes 1.4
Refineries
96.4
20
Xb
X
1.7
46
X
X
X
36.5
X
99.1
98.6
Natural Gas
Plants
,0
80
X
98.3
54
X
63.5
X
0
0
aBenzene, taluene, xylene estimates based on 1979 data; ethylene based on
1980 data; ethane, propane based on 1980 data; butane based on 1980
data.
X denotes a major source of this chemical, exact percentage figures are
not available. -
3-3
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GO
I
coal
Coal Tar
Distillers
Naphtalene
Benzene
Toluene
Xylene
Major Source
•Minor Source
crude oil
1
Refineries
1 - Butene
2 - Butene
natural gas
Natural Gas
Plants
n
Ethane
Methane
Butane
Propane
f i
bhylene
Propylene
Figure 3-1. The interwoven nature of feedstocks for the organic chemicals
manufacturing industry.
-------
co
i I
en •'
Ethyl ene di chloride
ftther chemi cals
Other chemicals
.Ethyl ene glycol acetate^
- Ethyl ene
Ethylene Oxide
1 .'.'
Ethylene GlycoT
Polyester fiber
Ethanol
Ethyl benzene
Ethatiol amines
•* Latex ,-p.ai nts
Figure 3-2. Chain of chemicals made from ethylene.
-------
but by 1980 competition from petroleum refineries had reduced this source to
7 8
only 54 percent. ' The use of shale oil and coal as sources of basic raw
materials is expected to change the future complexion of these feedstock
chemicals producing industries.
The estimated total domestic production for all synthetic organic
chemicals in 1979 was 103.5 x 106 Mg (228 x 109 Ibs). This production total
Q
includes hundreds of different chemicals. The scope of the Distillation
Operations NSPS was chosen to encompass the higher production volume
chemicals.
A relatively small number of chemicals dominate industry output, as
illustrated in Table 3-2. The table shows the number of chemicals with
production output above various production levels (i.e. chemicals with total
national production greater than the listed production level). A national
production level of 45,400 Mg/yr (100 million Ib/yr) was used to define the
segment of the organic chemical manufacturing industry covered by the scope
of the standards development program. The scope includes approximately 220
chemicals which account for close to 92 percent of total domestic chemical
production. This list does not include polymers, coal tar distillation
products, chemicals extracted from natural sources, or chemicals produced
totally by biological synthesis since these production processes are not
within the intended scope of this program. A detailed discussion of the
industry structure and end use patterns of the chemicals is provided in
Section 9.1. Appendix E presents the list of chemicals considered in this
study of VOC emissions from distillation operations.
Even limiting the scope of this study to about 220 chemical,
extraordinary amounts of time and resources would still be required to
study each chemical as a separate industry. Furthermore, organic chemical
manufacturing plants have exhibited the ability to develop quickly process
operations that take best advantage of raw material availability and costs
or recent technologies. New and more economical processes are continuously
being introduced to replace outdated processes. The nature of the organic
chemical industry would make it extremely difficult (perhaps even
impossible) to develop standards for all of the individual chemicals
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TABLE 3-2. ESTIMATED PRODUCTION AND CHEMICAL COVERAGE FOR
VARIOUS PRODUCTION LEVELSiU
Production Level Mg/yr
(million Ib/year)
453,600
(1,000)
226,800
(500)
113,400
(250)
45,400
(100)
27,200
(60)
13,600
(30)
9,100
(20)
4J500
(10)
Number of
Chemicals
63
102
155
219
283
410
506
705
Percentage of National
Production Covered
N/A
N/A
N/A
92
94
N/A
N/A
97
aThis number signifies the number of chemicals with national production
greater than the production level considered.
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produced. Thus, the approach taken in this study was to examine VOC
emissions from a single unit operation. Distillation as a unit operation
is common throughout the organic chemical industry and is a fundamental
processing procedure. And some of the control techniques described in
Chapter 4 are generally applicable to all distillation operations.
3.2 DISTILLATION
Distillation has been used as a separation and purification process for.
thousands of years. Fresh water was produced by distilling sea water in a
sponge condenser around 300 A.D. Earlier historical description of
production procedures of essential oils, perfumes, and medicines indicate
that some form of distillation was probably known 1000 to 2000 years prior
to sea water distillation.
Today, distillation is the most commonly used separation and purifi-
cation procedure in refineries and large organic chemical manufacturing
plants. The fundamental operating principles for a distillation column are
the same regardless of the application. This section briefly discusses some
of the fundamental principles involved in distillation to provide a better
understanding of operating characteristics of distillation units and causes
of VOC emissions from these units.
3.2.1 Types of Distillation
Distillation is an operation separating one or more feed stream(s)*
into two or more product streams, each product stream having component
concentrations different from those in the feed stream(s). The separation
is achieved by the redistribution of the components between the liquid- and
vapor-phase as they approach equilibrium within the distillation unit. The
more volatile component(s) concentrate in the vapor-phase while the less
volatile components(s) concentrate in the liquid-phase. Both the vapor- and
liquid-phase originate predominately by vaporization and condensation of the
feed stream.
*For batch distillation, the word "charge" should be used in place of
"stream", wherever applicable.
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Distillation systems can be divided into subcategories according to the
operating mode, the operating pressure, the number of distillation stages,
the introduction of inert gases, and the use of additional compounds to aid
separation. A distillation unit may operate in a continuous or a batch
mode. The operating pressures can be below atmospheric (vacuum), atmos-
pheric, or above atmospheric (pressure). Distillation can be a single stage
or a multistage process. Inert gas, especially steam, is often introduced
to improve separation. Finally, compounds are often introduced to aid in
distilling hard to separate mixture constituents (azeotropic and extractive
distillation).
Single stage batch distillation is not common in large scale chemical
production but is widely used in laboratories and pilot plants. Separation
is achieved by charging a still with material, applying heat and contin-
uously removing the evolved vapors. In some instances, steam is added or
pressure is reduced to enhance separation.
Single stage continuous distillation is referred to as flash distilla-
tion (Figure 3-3). It is generally a direct separation of a component
mixture based on a sudden change in pressure. Since it is a rapid process,
steam or other components are not added to improve separation. A flash
distillation unit is frequently the first separation step for a stream from
the reactor. The heated products from a reaction vessel are pumped to an
expansion chamber. The pressure drop across the valve, the upstream
temperature, and the expansion chamber pressure govern the separation
achieved. The light ends quickly vaporize and expand away from the heavier
bottom fractions which remain in the liquid-phase. The vapors rise to the
top of the unit and are removed. Bottoms are pumped to the next process
step. .. . • •
Fractionating distillation is a multistage distillation operation. It
is the most commonly used type of distillation unit in large organic
chemical plants, and it can be a batch or a continuous operation. At times,
inert carriers (such as steam) are added to the distillation column.
Fractionating distillation is accomplished by using trays, packing, or other
internals in a vertical column to provide multiple intimate contacts of
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Pressure Control
Valve
Feed
Overheads (Gas)
or Light Ends
Flash
Distillation Column
Bottoms (Liquid)
or Heavy Ends
Figure 3-3. Flash distillation.
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ascending vapor and descending liquid streams. A simplified block flow
diagram of a fractionation column is shown in Figure 3-4. The light end
vapors evolving from the column are condensed and collected in an
accumulator tank. Part of the distillate is returned to the top of the
column so it can fall countercurrent to the rising vapors. For difficult
separations, additional compounds may be added to achieve the desired
separation. This is commonly referred to as extractive distillation and is
typically used in lubricant oil refining. A desorption column is very
similar to a fractionating distillation column except that it does not use a
reflux condenser.
3.2.2 Fundamental Distillation Concepts
The emissions from distillation units are dependent on the size,
operating conditions and types of components present. Therefore, the design
parameters and selection of operating conditions are discussed in this
section to provide a better understanding of the emissions.
The separation of a mixture of materials into one or more individual
components by distillation is achieved by selecting a temperature and
pressure that allow the coexistence of vapor and liquid phases in the
distillation column. Distillation is described as a mass-transfer operation
involving the transfer of a component through one phase to another on a
molecular scale. The mass transfer is a result of a concentration
difference or gradient stimulating the diffusing substance to travel from a
high concentration zone to one of lower concentration until equilibrium is
reached. The maximum relative concentration difference between distillation
materials in the vapor- and liquid-phases occurs when a state of equilibrium
is reached. The equilibrium state is reached when the concentrations of
components in the vapor-phase and liquid-phase, at a given temperature and
pressure, do not change regardless of the length of time the phases stay in
contact.
For ah ideal system, the equilibrium relationship is determined using
the laws of Dal ton and Raoult. Dal ton's law states that the total pressure
of a mixture of gases is equal to the sum of the partial pressures of each
gas constituent:
3-H
-------
Feed i
r
Restdc--*-/ Reboiler
^
i/
^h\
vz t
4 "'
fa t
4 Lz
js< i
^5 1
4 *«
* ^5
^7 t
^ t
4 ^
+
C^
Heating medium
(Bottom Products)
io
(
/• NI.OO
*H Condenser J-»»
— 1 Accumulator I
t
Distillate
Overhead Produc
Figure 3-4. A conventional fractionating column.
3-12
-------
Pt = S P, • (3.1)
1
where:
P. = Total pressure.
p. = Partial pressure of each gas constituent.
n = Number of constituents.
Dal ton's law further states that the partial pressure of each ideal gas
constituent is proportional to the mole fraction (relative percentage) of
that gas in the mixture: . '
P, = Y, Pt (3.2)
where:
y. = Mole fraction.
Raoult's law states the relationship for ideal solutions between the partial
pressure of a mixture constituent in the vapor phase and its composition in
the liquid-phase in contact. When the vapor phase is at equilibrium with
the solution, the partial pressure of the evolved component is directly
proportional to its vapor pressure (at the same temperature) and its mole
fraction in the solution:
p. = x. p. (3.3)
where:
x. = Mole fraction in the solution.
p. = Vapor pressure of the pure substance at the same temperature.
These statements may be combined to give an equilibrium vaporization ratio
(K value). A simplified expression for this ratio is:
K. = -1 (3.4)
Xi
3-13
-------
This equilibrium constant is used to evaluate the properties that affect
gas-liquid equilibrium conditions for individual components and mixtures,
The K value represents the distribution ratio of a component between the
vapor and liquid-phases at equilibrium. The K value for various materials
may be calculated using thermodynamic equations of state or through
empirical methods (suitably fitting developed data curves to experimental
data). This constant is an extremely important tool for designing
distillation units (determining required temperatures, pressures, and column
size).
Another basic distillation concept is the separation factor or relative
volatility (a--) of system components. This is the equilibrium ratio of the
J
mole fractions of component i to some component j in the vapor and liquid
phase:
y • y •
a,, =-L/-l (3.5)
Xi Xj
It is expressed as the ratio of the vapor pressures for an ideal mixture:
cs.,= — (3.6)
i J p
J
This ratio is a measure of the separability of the two components to be
separated and is very important in designing distillation equipment. In the
case of a binary system, the two components to be separated are the two
components present in the feed. In a multicomponent system, the components
to be separated are referred to as "heavy key" (HK) and "light key" (LK).
The "heavy key" is the most volatile component desired to be present in
significant quantities in the bottom products or the residue. Similarly,
"light key" is the least volatile compound desired to be present in
significant quantities in the overhead products. Generally, separation by
distillation becomes uneconomical when the relative volatility of the light
key and heavy key is less than 1.05.
3-14,
-------
The operating temperature and pressure in a distillation unit are
interrelated. A decision made for the value of one of these parameters also
determines the value of the other parameter. Essentially, the pressure and
temperature are chosen so that the dewpoint* condition for the overhead
products and the bubble point** conditions for the bottom products can be
present inside the distillation unit. The actual decision on these two
conditions is predicated upon economic considerations and is made after
evaluating the following items: •
1. The relative volatility, a.-, of the components. A lower
' »J
pressure in the column increases the value of a... and improves separation.
J
This would result in a shorter fractionating column.
2. The effect of pressure on vapor volume in the distillation unit.
The vapor volume increases as the pressure decreases, requiring a larger
diameter vessel.
3. The effect of pressure on column wall thickness. Higher pressures
require increased wall thickness and raise costs.
*The dew-point temperature is the temperature at which the first droplet of
liquid is formed as the vapor mixture is cooled at constant pressure, and
the dew-point pressure is that at which the first droplet of liquid is
formed as the pressure is increased on the vapor at constant temperature.
Mathematically, the dew-point is defined by:
n _ _ n y
-E xi - 1.0 - z
1 1
_ _ i
E xi - 1.0 - z -f- (3_7)
**The bubble-point temperature is the temperature at which the first bubble
of vapor is formed on heating the liquid at constant pressure. The
bubble-point pressure is the pressure at which the first bubble of vapor
is formed on lowering the pressure on the liquid at constant temperature.
Mathematically, the bubble-point is defined by:
n n
£ y , .= 1.0 = £ K. x. (3.8)
^ 1 1
3-15
-------
4. Cost of achieving desired temperature and pressures. The cost of
changing the pressure and that of changing the temperature are considered
independently since these two costs are not proportional.
5. The thermal stability limit of the compounds being processed.
Many compounds decompose, polymerize, or react when the temperature reaches
some critical value. In such cases it is necessary to reduce the design
pressure so that this critical reaction temperature is not be reached at any
place in the distillation unit.
Data on the use of vacuum during distillation was compiled for a number
of major chemicals to predict the use of vacuum for distillation. The ..
physical properties of the compounds using vacuum during distillation were
compared with those of compounds not using vacuum, with .the following
conclusions:
1. Compounds with a melting point less than -10°C and with a boiling
point greater than 150°C are likely to be distilled under vacuum.
2. If the boiling point of a compound is less than 50°C then it is
likely to be distilled at or above atmospheric pressure.
3. For the separation of compounds with boiling points between 50°C
and 150°C, the use of vacuum depends on the thermal operable limit of the
compound (i.e., temperature range in which the compound does not decompose,
12
polymerize, or react).
In designing a distillation system, once the operating temperature and
pressure are established, the type of distillation is considered. Flash
distillation is preferred for separation of components with a high relative
volatility. Steam is the most frequently used heat source for column
distillation since using a direct fired heater (although used in some
instances) could create a dangerous situation. Steam is also used for
distilling compounds that are thermally unstable or have high boiling
points. Azeotropic and extractive distillation are used to separate
compounds that are difficult to separate. For example, benzene is sometimes
added in a distillation process to achieve separation of an alcohol-water
mixture.
3-16
-------
For a flash unit, the design of the flash vessel size is relatively
straightforward. In the case of a fractionating unit design, once the
column pressure and temperature are determined, the reflux ratio (fraction
of total overhead condensate returned to column) is selected to ensure an
adequate liquid phase in the distillation column for vapor enrichment. The
number of trays (or height of column packing), column diameter, and
auxiliary equipment (pumps, condenser, reboiler, and instruments) are then
determined. The final decisions on all these items are based on engineering
and economic trade offs. More detailed discussion on the design of distil-
lation units is readily available in various chemical engineering
texts.13'14'15'16
3.3 VOC EMISSION POINTS FROM DISTILLATION UNITS
The discussions on distillation column operating theory and design show
the basic factors of column operation. Vapors separated from the liquid
phase in a column rise out of the column to a condenser. The gases and
vapors entering the condenser can contain VOC, water vapor, and nonconden-
sibles such as oxygen (02), nitrogen (N2), carbon dioxide (C02). The vapors
and gases originate from vaporization of liquid feeds, dissolved gases in
liquid feeds, inert carrier gases added to assist in distillation (only for
inert carrier distillation), and air leaking into the column, especially in
vacuum distillation. Most of gases and vapors entering the condenser are
cooled enough to be collected as a liquid-phase. The noncondensibles (09,
N2, C02, and other organics with low boiling points), if present, are not
usually cooled to the condensation temperature and are present as a gas
stream at the end the of condenser. Portions of this gas stream are often
recovered in devices such as scrubbers, adsorbers, and secondary condensers.
Vacuum generating devices (pumps and ejectors), when used, might also affect
the amount of noncondensibles. Some organics can be absorbed by condensed
steam in condensers located after vacuum jets. In the case of oil-sealed
vacuum pumps, the oil losses increase the VOC content of the noncondensibles
exiting the vacuum pump. The noncondensibles from the last process equip-
ment (condensers, pumps, ejectors, scrubbers, adsorbers, etc.) constitute
3-17
-------
the emissions from the distillation unit unless they are controlled by
combustion devices such as incinerators, flares, and boilers.
The most frequently encountered emission points from fractionation
distillation operations are illustrated for several types of distillation
units in Figures 3-5 to 3-8. These emission points are indicated as follows
by the numbers in parentheses: condenser (1), accumulator (2), hot
wells (3), steam jet ejectors (4), vacuum .pump (5), and pressure relief
valve (6). Emissions of VOC are created by the venting of noncondensible
gases which concurrently carry out some hydrocarbons.
The total volume of gases emitted from a distillation operation depends
upon air leaks into the vacuum column (reduced pressure increases leaks and
increased size increases leaks), the volume of inert carrier gas used, gases
dissolved in the feed, efficiency and operating conditions of the condenser
and other process recovery equipment, and physical properties of the organic
constituents. Knowledge of the quantity of air leaks and dissolved gases in
the column in conjunction with information on organic vapor physical
properties and condenser operating parameters allows estimation of the VOC
emissions that may result from a given distillation unit operation.
The operating parameters for the industry vary to such a great extent
that it is difficult to develop precise emission factors for distillation
units. However, an extensive data base was gathered for organic chemical
industry distillation units. The data base contains information on
operating characteristics, emission controls, exit flows, and VOC emission
characteristics. This data base, presented in Appendix C, was used to
construct a National Emission Profile (NEP). This NEP provided the basis of
examining the baseline control level and the various regulatory alternatives
discussed in Chapter 6.
3.3.1 National Emission Profile (NEP)
The NEP was developed from an extensive data base for organic chemical
plants available from surveys performed for EPA by Houdry Division of Air
Products (1971-72)17 and by IT Enviroscience (1977-80).18 All data for
distillation units from these surveys were verified through contacts with
each chemical manufacturer. The NEP provides some insight into the types of
3-18
-------
Vent
Vapor Phase
Cooling
rWater }
Condenser/id)
r Pressure Relief
Valve :(6) >
Accumulator (2)
iLiquid Reflux
Overhead Product1
Distillation
Column
Figure 3^-5. Potential ;VOC emission points for a nonvax:uum
; , distillation: column. • ' ' [
3-19
-------
Steam
co
ro
o
Vapor Phase
Condenser
(1)
Liquid Reflux
Ptsttnation
Column
.Pressure
^Relief Valve
(6)
Accumulator
(2)
Overhead Product
Ejector(4)
Cooling
Water (CW)
Steam
Ejector(4)
Barometric
Condenser
Vent
(3) HotweV]
Figure 3-6. Potential VOC emission points for a'vacuum distillation column using steam jet
ejectors with barometric condenser.
-------
•Steam
co
i
IN3
Vapor Phase "
Cooling Water
Condenser(l)
x-^
-
^-v
.
I ] Accumu
. Overhead F
Distillation
Column
Ejector^
Cooling Water
Condens-er(l)
Vent
Accumulator^)
Waste Stream
Figure 3-7. Potential VOC emission points for a vacuum•distillation- column using a steam jet
ejector and surface condensers. ,. : 1 -
-------
Vapor Phase
Liquid Reflux
Distillation
Column
CW
Condenser
(1)
Vent
Vacuum Pump (5)
Accumulator(2)
Overhead Product
Figure 3-8. Potential VOC emission points for a vacuum distillation
column using a vacuum pump.
3-22
-------
distillation operations in use in organic chemical manufacturing and the
control systems currently being used. Table 3-3 gives the total number and
types of distillation units in the NEP and summarizes the combustion control
and product recovery measures reportedly used.
The NEP contains information on the type of distillation involved, the
product recovery and VOC control equipment, the vent stream characteristics,
and the other distillation units in the plant. The vent stream characteris-
tics listed for each column in the NEP (determined downstream of product
recovery devices, but upstream of combustion devices) are:
1. Volumetric flowrate.
2. Heat content,
3. VOC emission rate.
4. VOC concentration.
-\
5. Atomic concentrations as percents: carbon, nitrogen, hydrogen,
oxygen, and chloride.
6. Average number of atoms per molecule.
Complete information on vent stream characteristics was not available
for some of the reported distillation units. These columns were screened
out of the regulatory analysis, since their regulatory impacts due to VOC
control could not be calculated. Also screened out were units with zero
flowrate (because no noncondensible gases were vented to the atmosphere) and
units for which offgases were recycled to the manufacturing process. Only
those distillation columns for which complete vent stream characterization
was available for all columns in a plant were retained in the screened NEP.
The screened NEP provides the basis of the regulatory analysis. Table 3-4
gives an overview of the screened NEP. The data lines from the NEP
remaining in the screened NEP are marked in Appendix C.
3.3.2 Geographic Bias in the Screened NEP
Chemical plants in the screened NtP can be grouped into two broad
categories: plants in states with State implementation plans (SIP) for
emissions from distillation operations (Category 1), and plants in states
with no regulations covering emissions from distillation operations
(Category 2). The screened NEP contains 128 units (66 percent) in
3-23
-------
TABLE 3-3. OVERVIEW OF THE NATIONAL EMISSION PROFILE
Number of Units
1.
2.
3.
4.
5.
6.
7.
Operating Pressure
a. Vacuum
b. Nonvacuum
c. Information Not Available
Mode of Operation
a. Batch
b. Continuous
Type of Unit
a. Flash
b. Fractionating
Installed Product Recovery
Devices
a. Scrubbers
b. Absorbers
c. Carbon adsorption
Installed Combustion Controls
a. Flares
b. Incinerators
c. Boilers
Units with no Flowrate
Units with Emissions Recycled
1 318
582
137
1037
4
1033
1037
37
1000
1037
79
12
5
96
78
72
9
' 159
231
219
Percentage of Total
31
56
13
100
<1
>99
100
3
97
100
8
1
<1
10
8
7
1
16
22
21
aFor 13 percent of the 1037 total units, operating pressure information is
not given and is reported as confidential.
In addition to condensers.
3-24
-------
TABLE 3-4. OVERVIEW OF THE SCREENED NATIONAL EMISSION PROFILE
Units Screened Out of NEP
Total number of units in the NEP 1037
Units at plants with incomplete data9 392
Units with recycled emissions, or zero flowrate 450
Number of Units in Screened NEP 195
2. Operating Characteristics of the Screened NEP
o
Average offgas flowrate, m /min (scfm) 1.0 (36)
Flow range, m /min (scfm) 0.001-18 (0.005-637)
Average VOC emission rate, kg/hr (Ib/hr), 36 (78)
precontrolled
Average VOC emission rate, kg/hr (Ib/hr), 5.9 (13)
/->
controlled
VOC emission range, kg/hr (Ib/hr), 0-1670 (0-3668)
precontrolled
aThere are a number of plants in the NEP for Which there were distillation
units with insufficient data to permit calculation of VOC control costs.
Calculated downstream of adsorbers, absorbers,,and condensers, but upstream
of combustion devices.
GControlled VOC emission rates were estimated using a 98 percent destruction
efficiency for flares, boilers, and incinerators (where it was indicated
that control devices were being used).
3-25
-------
Category 1, and 67 units (34 percent) in Category 2. Moreover, the total
precontrolled emission rate of 6940 kg/hour (15,300 Ib/hr) is composed of
77 percent from Category 1 and 23 percent from Category 2. Since available
information shows that only 56 percent of all organic chemical plants are in
Category 1 States, while 44 percent are in Category 2, the screened NEP data
19
is weighted toward Category 1.
3.4 BASELINE CONTROL LEVEL FOR DISTILLATION OPERATIONS
The baseline level of emissions control is defined as the control level
that would exist in the affected industry in the absence of the NSPS. This
level is established to facilitate comparison of the economic, energy, and
environmental impacts of regulatory alternatives (Chapters 6-9).
A first consideration in establishing a baseline level is existing
state regulations. Only four of the states with organic chemical plants
have regulations applicable to distillation units in the organic chemical
industry. These states are Texas, Louisiana, New Jersey, a"d Illinois, and
account for about 55 percent of the existing plants producing the chemicals
within the scope of this program. Texas requires facilities emitting more
than either 100 Ibs/day or 250 Ibs/hr, depending on the true vapor pressure
of the VOC, to incinerate the waste gas steam "properly" at 1300°F. This is
20
equivalent to approximately 85 percent VOC reduction. Louisiana also
requires incineration of VOC at 1300°F, with a 0.3 second residence time, or
control by other acceptable methods; however, control requirements may be
Waived if the offgas is not significant or will not support combustion
21
without auxiliary fuel. New Jersey uses a sliding scale, based on the
degree of difficulty in controlling the VOC emission source, to establish
allowable emission rates for individual sources. Depending on the vapor
pressure, concentration, and amount of the waste stream VOC, the New Jersey
22
regulation requires from 0 to 99.7 percent VOC reduction. Illinois does
not differentiate between organic solvents and organic compounds in an
applicable regulation that limits VOC emissions to 8 Ibs/hr unless these
23
emission are reduced by 85 percent. The remaining states do not have
regulations for emissions from distillation units in chemical plants.
3-2G
-------
Often, the baseline control level selected is a weighted average of the
control level -required by State implementation plans (SIPs). Based on the
screened NEP, the average control level for distillation units in States
with applicable SIPs (Category 1) is significantly higher than the control
level for distillation units in states without applicable SIPs (Category 2).
And both categories exhibit control levels higher than the applicable SIPs
for each category. The screened NEP shows an average control level of
90 percent for Category 1 and an average control level of 63 percent for
Category 2 (assuming a control efficiency of 98 percent for flares, boilers,
and incinerators). Controls are used in Category 2 states because there are
high organic contents in the offgases from some distillation units and these
organics can be recovered or used as fuel. Considerations such as OSHA
regulations, odor problems, and other regulations may also play an important
rbl e.
Because of the geographic bias in the screened NEP, the level of
control that would exist if no NSPS were developed would be overestimated
by using the screened NEP directly. Investigation of the screened NEP shows
an average control level of 90 percent for Category 1, 63 percent for
Category 2, and 84 percent overall. While the 90 and 63 percent control
levels are representative of the control levels in their respective
categories, the 84 percent control level (a simple weighted average) may not
be representative of the level for the total nationwide population of
distillation columns. Therefore, it is preferable to examine the two
categories separately and then consider the geographic bias in combining the
categories for the national impact.
In order to investigate the two categories separately, the screened NEP
was divided into two parts, one representing Category 1 (128 distillation
units) and the other representing Category 2 (67 distillation units). The
level of control was determined to be 90 percent in Category 1, and
63 percent in Category 2. Then, data on the number of organic chemical
plants in each state was compiled to determine the number of chemical plants
in each category. This number was related to the population of columns
nationally. It was found that about 56 percent of all plants are in the
3-27 '
-------
four states in Category 1 and 44 percent in the remaining states. Weighting
factors to be applied to the individual units in the screened NEP were
developed for each category by ratio of the percent of units in the category
nationally to the percent of units in the category in the screened NEP.
Finally, the national baseline control level was evaluated by taking a
weighted average control level for the two categories, weighted according to
the proportion of plants in each category in the screened NEP and in the
nation. This procedure is illustrated in Figure 3-9 and the calculation is
presented in Equation 3.9.
Baseline Control Level =
(Controlled Emissions,,,. , x Weighting Factor- . , +
v>at. 1 LaL. 1
Controlled Emissions-. ,, x Weighting Factor.,,.
LaL. c. Lau.
* (Uncontrolled Emissions,,,. -, x Weighting Factor,,,. ., ,
L>az. i L.at. i T
Uncontrolled Emissions- . 0 x Weighting Factor..,. 0) (3-9)
This yields a baseline control level of 81 percent.
Together 5 the two data sets form a representative baseline control
profile to be used as a basis for calculating the environmental and cost
impacts of various regulatory alternatives. The estimation of impacts is
based on the assumption that the baseline control profile, which is
developed from information on existing distillation units, represents the
future distillation vent stream characteristics. Chemical identities are
not considered in the profile, nor is there claimed to be a one to one
correspondence between a vent stream in the profile and an existing or new
vent stream.
3-28
-------
NEP
Remove plants indicating no emissions, recycled vent streams,
or incomplete information
Screened NEP
(195 columns)
(128 columns)
(67 columns)
Category 1
(SIPs)
Category 2
(no SIPs)
Apply geographic''Weighting factors
Baseline Control
Profile
Figure 3-9. Development of the baseline control profile.
3-29
-------
3.5 REFERENCES
1. U.S. International Trade Commission. Synthetic Organic Chemicals,
United States Production and Sales, 1979.
2. Weaver, W.C. Meeting the Olefin Demand: 1980-2000. Chemical
Engineering Progress. 7^:31-33. December 1980.
3. Word, T,T. Where Will Light Hydrocarbon Feedstocks Fit In The '80s?
Chemical Engineering Progress. ^6_:36-38. December 1980.
4. Ponder, T.C. What's Ahead for NGLs? Hydrogencarbon Processing.
5_7_: 147-150. October 1978.
5. Lowenheim, F.A. and M.K. Moran, Faith, Keyes, and Clark's Industrial
Chemicals, fourth edition. New York, J. Wiley - Interscience
Publication.
6. Reference 1.
7. Reference 2. ,
8. Reference 5.
9. Reference 1.
10. Letter from Farmer, J.R., EPA:CPB, to Jonnard, A., U.S. International
Trade Commission. June 12, 1981. Request for additional list of
organic chemicals.
11. Van Winkle, M. Distillation. New York, McGraw-Hill, 1967.
12. Letter from Desai, T., EEA to Beck, D., EPA, August 11, 1980.
13. Reference 11.
14. King, C.J. Separation Processes. New York, McGraw-Hill, 1971.
15. Foust, A.S., et al. Principles of Unit Operations. New York,
John Wiley & Sons, 1960.
16. Treybal, R.E. Mass Transfer Operations, 2nd edition. New York,
McGraw-Hill, 1968.
17. Houdry Division, Air Products and Chemicals, Inc. Survey Reports on
Atmospheric Emissions from the Petrochemical Industry. (Prepared for
U.S. Environmental Protection Agency.) Research Triangle Park, N.C.
Data on file in Docket No. A-80-25 and at ESED Office. 1972.
3-30
-------
18. Trip Reports. Hydroscience, Inc. EPA Contract No. 68-02-2577. (Data
in file 2.2.2 at EPA, ESED, CMS, Research Triangle Park, N.C. and in
Docket No. A-80-25, Subcategory II-B. 1977 - 1980.
19. Memo and addendum from Desai, T., EEA, to SOCMI Distillation File.
January 22, 1982. Development of geographic weighting percentages.
20. Bureau of National Affairs, Inc. Environmental Reporter, State Air
Laws, Volume 3, Texas. Washington, D.C., 1982.
21. Bureau of National Affairs, Inc. Environmental Reporter, State Air
Laws, Volume 2, Louisiana. Washington, D.C., 1982.
22. Personal Communication, Ivey, L., New Jersey Air Pollution Control
Agency, with Flowers, M. Energy & Environmental Analysis.
September 11, 1975. 1 p.
23. Bureau of National Affairs, Inc. Environment Reporter, State Air Laws,
Volume 2,Illinois. Washington, D.C., 1982.
3-31
-------
-------
4. EMISSION CONTROL TECHNIQUES
This chapter presents a discussion of the volatile organic compound
(VOC) emission control techniques which are applicable to distillation vent
streams. The control techniques discussed are grouped into two broad
categories which include noncombustion control devices and combustion
control devices. Noncombustion control devices are generally product
recovery devices while combustion control devices are designed to destroy
the VOC in the vent stream prior to atmospheric discharge.
The design and operating efficiencies of the candidate emission control
equipment are discussed in this chapter. Basic design considerations for
condensers-, absorbers, adsorbers, flares, industrial boilers, process
heaters, thermal oxidizers and catalytic oxidizers are briefly explained.
The conditions affecting the VOC removal efficiency of each type of device
are examined in conjunction with evaluation of their applicability for use
at distillation units. Emphasis has been .given to combustion control
devices due to their wide applicability for the control of VOC in distilla-
tion vent streams.
4.1 NONCOMBUSTION CONTROL.-DEVICES
The noncombustion control devices discussed in this section include
adsorbers, absorbers, and condensers. The following three sections present
a process description and identify the VOC removal efficiency and applica-
bility of each device to distillation vent streams.
Noncombustion control devices are generally applied to recover VOC from
a vent stream for use as a product or to recycle a compound. The chemical
structure of the VOC removed is usually unaltered. Of the 62 plants
identified in the screened NEP, 14 apply absorbers to recover VOC, 49 apply
condensers, and none apply adsorbers. Although noncombustion control
devices are widely applied in industry, they are not universally applicable
to all distillation vent streams. The conditions under which these systems
are not applicable are identified in the following sections.
4-1
-------
4.1.1 Adsorption
4.1.1.1 Adsorption process description. Adsorption is a mass-transfer
operation involving interaction between gaseous and solid phase components.
The gas phase (adsorbate) is captured on the solid phase (adsorbent) surface
by physical or chemical adsorption mechanisms. Physical adsorption is a
mechanism that takes place when intermolecular (van der Waals) forces
attract and hold the gas molecules to the solid surface. Chemisorption
occurs when a chemical bond forms between the gas and solid phase molecules.
A physically adsorbed molecule can readily be removed from the adsorbent
(under suitable temperature and pressure conditions) while the removal of a
chemisorbed component is much more difficult. " ,
The most commonly encountered industrial adsorption systems use
activated carbon as the adsorbent. Activated carbon is effective in
capturing certain organic vapors by the physical adsorption mechanism. In
addition, the vapors may be released for recovery by regeneration of the
adsorption bed with steam. Oxygenated adsorbents such as silica gels,
diatomaceous earth, alumina, or synthetic zeolites exhibit a greater
selectivity than activated carbon for capturing some compounds. These
adsorbents have a strong preferential affinity for water vapor over organic
gases and would be of little use for the high moisture gas streams from some
2
distillation vents.
The design of a carbon adsorption system depends on the chemical
characteristics of the VOC being recovered, the physical properties of
the offgas stream (temperature, pressure, and volumetric flowrate) and the
physical properties of the adsorbent. The mass flow rate of VOC from the
gas phase to the surface of the adsorbent (the rate of capture) is directly
proportional to the difference in VOC concentration between the gas phase
and the solid surface. In addition, the mass flow rate of VOC is dependant
on the adsorbent bed volume, the surface area of adsorbent available to
capture VOC, and the rate of diffusion of VOC through the gas film at the
gas and solid phase interface. Physical adsorption is an exothermic
operation which is most efficient within a narrow range of temperature and
pressure. A schematic diagram of a typical fixed bed, regenerative carbon
4-2
-------
adsorption systems is given in Figure 4-1. The process offgases are
filtered and cooled (1) before entering the carbon bed. The inlet gases to
an adsorption unit are filtered to prevent bed contamination. The gas is
cooled to maintain the bed at optimum operating temperature and to prevent
fires or polymerization of the hydrocarbons. Vapors entering the adsorber
stage of the system (2) are passed through the porous activated carbon bed.
Adsorption-of inlet vapors occurs in the bed until the activated carbon
is saturated with hydrocarbons. The dynamics of the process may be
illustrated by viewing the carbon bed as a series of layers or mass-transfer
zones (3a, b, c). Gases entering the bed are highly adsorbed first in zone
(a). Because most of the VOC is adsorbed in zone (a), very little adsorp-
tion taking place in zones (b) and (c). Adsorption in zone (b) increases as
zone (a) becomes saturated with organics and proceeds through zone (c).
When the bed is completely saturated (breakthrough) the incoming VOC laden
offgases are routed to an alternate bed while the saturated carbon bed is
regenerated.
Regeneration of the carbon bed is accomplished by heating the bed or
applying vacuum to draw off the adsorbed gases. Low pressure steam (4) is
frequently used as a heat source to strip the adsorbent of organic vapor.
The steam laden vapors are then sent to a condenser (5) and on to some type
of solvent recovery system (6). The regenerated bed is put back into active
service while the saturated bed is purged of organics. The regeneration
process may be repeated numerous times but eventually the carbon must be
replaced.
4.1.1.2 Adsorption control efficiency. Many modern, well-designed
3
systems achieve 95 percent efficiency for some chemicals. The VOC
removal efficiency of an adsorption unit is dependent upon the physical
properties of the compounds present in the offgas, the gas stream
characteristics, and the physical properties of the adsorbent.
Gas temperature, pressure and velocity are important in determining
adsorption unit efficiency. The adsorption rate in the bed decreases
4 5
sharply when gas temperatures are above 38°C (100°F). ' High temperature
increases the kinetic energy of the gas molecules causing them to overcome
4-3
-------
VOC-Laden
Vent Stream
FAN
(4)
Ctosad
ADSORBER 1
(ADSORBING)
Open
Closed
ADSORBER 2
(REGENERATING)
VENT TO
ATMOSPHERE
J7)
(5)
[ CONDENSER J
OECANTOR
and/or
DISTILLING TOWER
Recovered / _\
Solvent ( D ^
Water
Figure 4-1. Two stage regenerative adsorption system.
4-4
-------
van der Waals forces. Under these conditions, the VOC are not retained on
the surface of the carbon. Increasing stream pressure generally will
improve VOC capture efficiency, however, care must be taken to prevent
solvent condensation and possible fire. The gas velocity entering the
carbon bed must be quite low to allow time for adsorption to take place.
The required depth of the bed for a given compound is directly proportional
to the carbon granule size and porosity and to the gas stream velocity (bed
depth must increase as the gas velocity increases for a given carbon type).
4.1.1.3 Applicability of adsorption. Although carbon adsorption is an
excellent method for recovering some valuable process chemicals, it can not
be used as a universal control method for distillation vents. The condi-
tions where carbon adsorption is not recommended are present in many distil-
lation vents. These include streams with high VOC concentrations, very high
or low molecular weight compounds and mixtures of high and low boiling point
VOC. The range of organic concentration to which carbon adsorption can be
applied is from only a few parts per million to concentrations of several
percent. Adsorbing distillation vent streams with high organic concen-
tration may result in excessive temperature rise in the carbon bed due to
the accumulated heat of adsorption of the VOC loading. However, high
organic concentrations can be diluted to make a workable adsorption system.
The molecular weight of the compounds to be adsorbed should be in the range
of 45 to 130 gm/gm-mole for effective adsorption. Carbon adsorption may not
be the most effective application for compounds with low molecular weights
(below 45 gm/gm-mole) owing to their smaller attractive forces or for high
molecular weight components ( 130 gm/gm-mole) which attach so strongly to
the carbon bed that they are not easily removed. Properly operated
adsorption systems can be very effective for homogeneous offgas streams but
can have problems with a multicomponent system containing a mixture of light
and heavy hydrocarbons. The lighter organics tend to be displaced by the
Q
heavier (higher boiling) components greatly reducing system efficiency.
4.1.2 Absorption
4.1.2.1 Absorption process description. The mechanism of absorption
consists of the selective transfer of one or more components of a gas
.4-5
-------
mixture into a solvent liquid. The transfer consists of solute diffusion
and dissolution into a solvent. For any given solvent, solute, and set of
operating conditions, there exists an equilibrium ratio of solute concen-
tration in the gas mixture to solute concentration in the solvent. The
driving force for mass transfer at a given point in an operating absorption
tower is related to the difference between the actual concentration ratio
Q
and the equilibrium ratio. Absorption may only entail the dissolution of
the gas component into the solvent or may also involve chemical reaction of
the solute with constituents of the solution. The absorbing liquids
(solvents) used are chosen for high solute (VOC) solubility and include
liquids such as water, mineral oils, nonvolatile hydrocarbon oils, and
aqueous solutions of oxidizing agents like sodium carbonate and sodium
hydroxide.
Devices based on absorption principles include spray towers, venturi
scrubbers, packed columns, and plate columns. Spray towers require high
atomization pressure to obtain droplets ranging in size from 500 to 1000 ym
12
in order to present a sufficiently large surface contact area. Although
they can remove particulate matter effectively, spray towers have the least
effective mass transfer capability and thus, are restricted to particulate
removal and control of high-solubility gases such as sulfur dioxide and
13
ammonia. Venturi scrubbers have a high degree of gas-liquid mixing and
high particulate removal efficiency but also require high pressure and have
relatively short contact times. Therefore, their use is also restricted to
14
high-solubility gases. As a result, VOC control by gas absorption is
generally accomplished in packed or plate columns. Packed columns are
mostly used for handling corrosive materials, liquids with foaming or
plugging tendencies, or where excessive pressure drops would result from use
of plate columns. They are less expensive than plate columns for small-
scale or pilot plant operations where the column diameter is less than 0.6 m
(2 ft). Plate columns are preferred for large-scale operations, where
internal cooling is desired or where low liquid flowrates would inadequately
15
wet the packing.
4-6
-------
A schematic of a packed tower is shown in Figure 4-2. The gas to be '.
absorbed is introduced at the bottom of the tower (1) and allowed to rise
through the packing material (2). Solvent flows from the .top of the column,
countercurrent to the vapors (3), absorbing the solute from the gas-phase
and carrying the dissolved solute out of the tower (4). Cleaned gas exits
at the top for release to the atmosphere or for further treatment as
necessary. The saturated liquid is generally sent to a stripping unit where
the absorbed VOC is recovered. Following the stripping operation the
absorbing solution is either recycled back to the absorber or sent to water
treatment facility for disposal.
The major tower design parameters to be determined for absorbing any
substance are column diameter and height, system pressure drop, and liquid
flowrate required. These parameters are derived from considering the total
surface area provided by the tower packing material, the solubility and
concentrations of the components, and the quantity of gases to be treated.\.
4.1.2.2 Absorption control efficiency. The VOC removal efficiency of
an absorption device is dependent on the solvent selected, and on proper
design and operation. For a given solvent and solute, an increase in
absorber size or a decrease in the operating temperature can affect the VOC
removal efficiency of the system. It may be possible in some cases to
increase VOC removal efficiency by a change in the absorbent.
Systems that utilize organic liquids as solvents usually include the
stripping and recycle of the solvent to the absorber. In this case the VOC
removal efficiency of the absorber is dependent on the solvent stripping
efficiency.
4.1.2.3 Applicability of absorption. Although absorption will be
attractive for some distillation vents> it cannot be used to control all
distillation vents. Since its use is dependent on the economics of
recovery, absorption can be better classified as a product recovery device
for distillation operations rather than a VOC control device. Absorption is
attractive if a significant amount of VOC can be recovered and if the
recovered VOC can be reused. It is usually not considered when the VOC
concentration is below 200-300 ppmv. Furthermore, the use of absorption
4-7
-------
CLEANED GAS OUT
To Final Control Oevics
ABSORBING
LIQUID IH
(3)
VOC LADEN
GAS IN
(4)
ABSORBING LIQUID
WITH VOC OUT
To Disposal or VOC/Solvent Recovery
Figure 4-2. Packed tower for gas absorption.
4-8
-------
is subject to the availability of an appropriate solvent for a particular
VOC.
4.1.3 Condensation
4.1.3.1 Condensation process description. Condensation is a process
of converting all or part of the condensable components of a vapor phase
into a liquid phase. This is achieved by the transfer of heat from the
vapor.phase to a cooling medium. If only a part of the vapor phase is
condensed, the newly formed liquid phase and the remaining vapor phase will
be in equilibrium. In this case, equilibrium relationships at the operating
temperatures must be considered. The heat removed from the vapor phase
should be sufficient to lower the vapor phase,temperature to at or below its
dewpoint temperature (temperature at which first drop of liquid is formed).
Condensation devices are of two types: surface condensers and contact
17
condensers. Surface condensers are shell-and-tube type heat exchangers.
The coolant and the vapor phases are separated by the tube wall and they
never come in direct contact with each other. Surface condensers require
more auxiliary equipment for operation but can recover valuable VOC without
contamination by the coolant,"minimizing waste disposal problems. Only
surface condensers are considered in the discussion of control efficiency
and applicability since they are used more frequently in industry.
The major equipment components used in a typical surface condenser
system for VOC removal are shown in Figure 4-3. This system includes
(1) shell and tube dehumidification equipment (2) shell-and-tube heat
exchanger (3) refrigeration unit (4) VOC storage tanks and operating pumps.
Most surface.condensers use a shell-and-tube type heat exchanger to remove
18
heat from the vapor. As the coolant passes through the tubes, the VOC
vapors condense outside the tubes and are recovered. The coolant used
depends upon the saturation temperature of the VOC stream. Chilled water
can be used down to 7°C (45°F), brines to -34°C (-30°F), and chlorofluoro-
carbons below -34°C (-30°F).19 Temperatures as low as -62°C (-80°F) may
20
be necessary to condense some VOC streams.
4.1.3.2 Condenser control efficiency. VOC removal efficiency of a
condenser is dependent upon the type of vapor stream entering the condenser,
4-9
-------
VQCLAOEHGAS-
CLEANED GAS OUT
To Primary Control Flare,
Afterburner, Etc.
OEHUMIOIRCATION
UNIT
To Remove Water
and
Prevent Freezing
tn Mam Condenser
(1)
-W ", ' ' '" MAM CONDENSER
4 4 < <
COOLANT
RETURN
•*— COOLANT
REFRIGERATION
PUNT
(3)
CONDENSED
VOC
I
STORAGE
(4)
TO PROCESS
Or Disposal
Figure 4-3. Condensation system.
4-10
-------
and on condenser operating parameters. Efficiencies of condensers usually
24
vary from 50 to 95 percent.
4.1.3.3 Applicability of condensers. A primary condenser system is ..
usually an integral part of most distillation operations. These condensers
are needed to provide reflux in fractionating columns and to recover
distilled products. At times additional (secondary) condensers are used to
recover more VOC from the vent stream exiting the primary condenser.
Condensers are sometimes present as accessories to vacuum generating devices
(e.g., barometric condensers).
The use of a secondary condenser to control VOC emissions may not be
applicable to some distillation vent streams. Secondary condensers used as
supplemental product recovery devices are not well suited for vent streams
containing VOC with low boiling points or for vent streams containing large
quantities of inerts such carbon dioxide, air, and nitrogen. Low boilers
and inerts cannot be condensed at normal operating temperatures and they
usually carry over some VOC.
4.2 COMBUSTION CONTROL DEVICES
Combustion control devices, unlike noncombustion control devices, alter
the chemical structure of the VOC. Combustion is complete if all VOC are
converted to carbon dioxide and water. Incomplete combustion results in
some of the VOC being totally unaltered or being converted to other organic
compounds such as aldehydes or acids.
The combustion control devices discussed in the following four sections
include flares, thermal incinerators, catalytic incinerators, and boilers
and process heaters. Each device is discussed separately with respect to
their operation, destruction efficiency, and applicability to distillation
vent streams. Many combustion devices are widely applied where VOC control
of distillation vent streams is mandated by current regulations. For
example, of the 62 plants identified in the screened NEP 7 use incinerators,
2 use boilers, and 11 use flares to control VOC prior to atmospheric
discharge of the vent stream. All of these plants are in states where VOC
emissions from distillation operations are regulated.
4-11
-------
4.2.1 Flares
4.2.1.1 Flare process description. Flaring is an open combustion
process in which the oxygen required for combustion is provided by the air
around the flame. Good combustion in a flare is governed by flame tempera-
ture, residence time of components in the combustion zone, turbulent mixing
of the components to complete the oxidation reaction, and oxygen for free
radical formation.
There are two types of flares: ground level flares and elevated
flares. Kalcevic presents a detailed discussion of different types of
flareSj flare design and operating considerations, and a method for
25
estimating capital and operating costs for flares. The basic elements
of an elevated flare system are shown in Figure 4-4. Process off-gases are
sent to the flare through the collection header (1). The off-gases entering
the header can vary widely in volumetric flowrate, moisture content, VOC
concentration, and heat value. The knock-out drum (2) removes water or
hydrocarbon droplets that could create problems in the flare combustion
zone. Off-gases are usually passed through a water seal (3) before going to
the flare. This prevents possible flame flashbacks, caused when the off-gas
flow to the flare is too low and the flame front pulls down into the stack.
Purge gas (N2, C02, or natural gas) (4) also helps to prevent
flashback in the flare stack (5) caused by low off-gas flow. The total
volumetric flow to the flame must be carefully controlled to prevent low
flow flashback problems and to avoid a detached flame (a space between the
stack and flame with incomplete combustion) caused by an excessively high
flowrate. A gas barrier (6) or a stack seal is sometimes used just below
the flare head to impede the flow of air into the flare gas network.
The VOC stream enters at the base of the flame where it is heated by
already burning fuel and pilot burners (7) at the flare tip (8). Fuel flows
into the combustion zone where the exterior of the microscopic gas pockets
is oxidized. The rate of reaction is limited by the mixing of the fuel and
oxygen from the air. If the gas pocket has sufficient oxygen and residence
time in the flame zone it can be completely burned. A diffusion flame
receives its combustion oxygen by diffusion of air into the flame from the
4-12
-------
Steam
Nozzles
Helps prevent flash back
Gas Col lection Header
and Transfer Line (1)
Knock-out »
Drum
(2)
Flare Tip (8)
Pilot
Burners (7)
Oiain
Ignition
Device
Air Line
Gas Line
Figure 4-4. Steam assisted elevated flare system.
4-13
-------
surrounding atmosphere. The high volume of fuel flow in a flare requires
more combustion air at a faster rate than simple gas diffusion can supply so
flare designers add steam injection nozzles (9) to increase gas turbulence
in the flame boundary zones, drawing in more combustion air and improving
combustion efficiency. This steam injection promotes smokeless flare
operation by minimizing the cracking reactions that form carbon. Signifi-
cant disadvantages of steam usage are the increased noise and cost. The
steam requirement depends on the composition of the gas flared, the steam
velocity from the injection nozzle, and the tip diameter. Although some
gases can be flared smokelessly without any steam, typically 0.15 to 0.5 kg
of steam per kg of flare gas is required.
Steam injection is usually controlled manually with the operator
observing the flare (either directly or on a television monitor) and adding
steam as required to maintain smokeless operation. Several flare manufac-
turers offer devices which sense flare flame characteristics and adjust the
steam flowrate automatically to maintain smokeless operation.
Some elevated flares use forced air instead of steam to provide the
combustion air and the mixing required for smokeless operation. These
flares consist of two coaxial flow channels. The combustible gases flow in
the center channel and the combustion air (provided by a fan in the bottom
of the flare stack) flows in the annulus. The principal advantage of air
assisted flares is that expensive steam is not required. Air assist is
rarely used on large flares because air flow is difficult to control when
the gas flow is intermittent. About 0.8 hp of blower capacity is required
oc
for each 100 Ib/hr of gas flared.
Ground flares are usually enclosed and have multiple burner heads that
are staged to operate based on the quantity of gas released to the flare.
The energy of the gas itself (because of the high nozzle pressure drop) is
usually adequate to provide the mixing necessary for smokeless operation and
air or steam assist is not required. A fence or other enclosure reduces
noise and light from the flare and provides some wind protection.
Ground flares are less numerous and have less capacity than elevated
flares. Typically they are used to burn gas "continuously" while steam
4-14
-------
assisted elevated flares are used to dispose of large amounts of gas
released in emergencies.
4.2.1.2 Flare combustion efficiency.
4.2.1.2.1 Factors affecting flare efficiency. The flammability
limits of the gases flared influence ignition stability and flame extinction
(gases must be within their flammability limits to burn). When flammability
limits are narrow, the interior of the flame may have insufficient air for
the mixture to burn. Outside the flame, so much air may be induced that the
flame is extinguished. Fuels with wide limits of flammability are therefore
usually easier to burn (for instance, H2 and acetylene). However, in
spite of wide flammability limits, CO is difficult to burn because it has a
low heating value and slow combustion kinetics.
The auto-ignition temperature of a fuel affects combustion because gas
mixtures must be at high enough temperature and at the proper mixture
strength to burn. A gas with low auto-ignition temperature will ignite and
burn more easily than a gas with a high auto-ignition temperature. Hydrogen
and acetylene have low auto-ignition temperatures while CO has a high one.
The heating value of the fuel also affects the flame stability,
emissions, and flame structure. A lower heating value fuel produces a
cooler flame which does not favor combustion kinetics and also is more
easily extinguished. The lower flame temperature will also reduce buoyant
forces, which reduces mixing (especially for large flares on the verge of
smoking). For these reasons, VOC emissions from flares burning gases with
low Btu content may be higher than those from flares which burn high Btu
gases.
Some fuels also have chemical differences (slow combustion kinetics)
sufficient to affect the VOC emissions from flares. For instance, flares
burning fuels with large amounts of CO may have greater VOC emissions that
flares burning pure VOC.
The density of the gas flared also affects the structure and stability
of the flame through the effect on buoyancy and mixing. The velocity in
many flares is very low, therefore, most of the flame structure is developed
through buoyant forces as a result of the burning gas. Lighter gases
4-15
-------
therefore tend to burn better. The density of the fuel also affects the
minimum purge gas required to prevent flashback and the design of the burner
tip.
Poor mixing at the flare tip or poor flare maintenance can cause
smoking (particulate). Fuels with high carbon to hydrogen ratios (greater
than 0.35) have a greater tendency to smoke and require better mixing if
they are to be burned smoke!essly.
4.2.1.2.2 Flare efficiency test data. This section presents a
review of the flares and operating conditions used in five studies of flare
combustion efficiency. Each study summarized in Table 4-1 can be found in .
complete form in the docket.
Palmer experimented with a 1/2-inch ID flare head, the tip of which was
located 4 feet from the ground. Ethylene was flared at 50 to 250 ft/sec at
the exit, (0.4 x 106 to 2.1 x 106 Btu/hr). Helium was added to the
ethylene as a tracer at 1 to 3 volume percent and the effect of steam
injection was investigated in some experiments. Destruction efficiency (the
28
percent ethylene converted to some other compound) was 97.8 percent.
Siege! made the first comprehensive study of a commercial flare system.
He studied burning of refinery gas on a commercial flare head manufactured
by Flaregas Company. The flare gases used consisted primarily of hydrogen
(45.4 to 69.3 percent by volume) and light paraffins (methane to butane).
Traces of H^S were also present in some runs. The flare was operated from
0.03 to 2.9 megagrams of fuel/hr (287 to 6,393 Ib/hr), and the maximum heat
release rate was approximately 235 x 10 Btu/hr. Combustion efficiencies
29
(the percent VOC converted to CO^) averaged over 99 percent.
Lee and Whipple studied a bench-scale propane flare. The flare head
was 2 inches in diameter with one 13/16-inch center hole surrounded by two
rings of 16 1/8-inch holes, and two rings of 16 3/16-inch holes. This
configuration had an open area of 57.1 percent. The velocity through the
head was approximately 3 ft/sec and the heating rate was 0.3 M Btu/hr. The
effects of steam and crosswind were not investigated in this study.
30
Destruction efficiencies were 99.9 percent or greater.
4-16
-------
TABLE 4-1. FLARE EMISSION STUDIES COMPLETED
OCTOBER 1982
Investigator Sponsor
Palmer (1972) E.I. du Pont
Lee & Whipple (1981) Union Carbide
Siege! (1980) Ph.D. Dissertation
University of Karlsruhe
Howes et al. (1981) EPA
HcDaniel et al. (1982) CMA-EPA
Flare Tip Design
0.5" dia.
Discrete Holes in 2"
dia. cap.
Commercial Design
(27.6" dia. steam)
Commercial Design
(6" dia. air assist)
Commercial Design H.P.
(3 tips @ 4" dia.)
Commercial Design
(4" dia. steam assist)
References
31
32
33
34
35
Flared Gas
Ethyl ene
Propane
35035 H,
, plus nght
hydrocarbons
Propane
Natural Gas .
Propylene
Throughput
10b Btu/hr
0.4 - 2.1
0.3
49 - 178
44
28 (per tip)
0.01 - 57
Flare
Efficiency
%
97.8 - >99
>99.9
>99
>99
>99
83 - 99.9
SOURCE: Reference 40
-------
Howes, et.al. studied two commercial flare heads at John link's flare
test facility. The primary purpose of this test (which was sponsored by the
EPA) was to develop a flare testing procedure. The commercial flare heads
were an LH air assisted head and an LRGO (Linear Relief Gas Oxidizer) head
manufactured by John Zink Company. The LH flare burned 2,300 Ib/hr of
commercial propane. The exit gas velocity based on the pipe diameter was
27 ft/sec and the firing rate was 44 x 10 Btu/hr. The LRGO flare,
consisted of 3 burner heads located 3 feet apart. The 3 burners combined
fired 4,200 Ibs/hr of natural gas. This corresponds to a firing rate of
83.7 x 10 Btu/hr. Steam was not used for either flare, but the LH flare
head was in some trials assisted by a forced draft fan. Combustion
efficiencies for both flares during normal operation were greater than
99 percent.36
An excellent detailed review of all four studies was done by Joseph,
et a!., in January 1982, and a summary of the studies is given in Table 1.
37
A fifth study determined the influence on flare performance of mixing,
Btu content and gas flow velocity. A steam-assisted flare was tested at the
John Zink facility using the procedures developed by Howes. The test was
sponsored by the Chemical Manufacturers Associated (CMA) with the coopera-
tion and support of the EPA. All of the tests were with an 80 percent
propylene, 20 percent propane mixture diluted as required with nitrogen to
give different Btu/scf values. This was the first work which determined
flare efficiencies at a variety of "nonideal" conditions where lower
efficiencies had been predicted. All previous tests were of flares which
burned gases which were very easily combustible and did not tend to soot.
This was also the first test which used the sampling and chemical .analysis
methods developed for the EPA by Howes.
The steam assisted flare was tested with exit flow velocities ranging
from 0.02 to 60 ft/sec, with Btu contents from 200 to 2,183 Btu/scf and with
steam to gas (weight) ratios varying from 0 (no steam) to 6.8611. Steam-
assisted flares were tested with fuel gas heat contents as low as 300 Btu/
scf. Flares without assist were tested down to 200 Btu/scf. All of these
tests, except for those with very high steam to gas ratios, showed
4-18
-------
combustion efficiencies of over 98 percent. Flares with high steam to gas
ratios (about 10 times more steam than that required for smokeless
operation) had lower efficiencies (69 to 82 percent) when combusting
2,183 Btu/scf of gas.
After consideration of the results of these five tests, the EPA has
concluded that 98 percent combustion efficiency can be achieved by steam-
assisted flares with exit flow velocities less .than 60 ft/sec and combustion
gases with heat contents over 300 Btu/scf and by flares operated without
assist with exit flow velocities less than 60 ft/sec and burning gases with
heat contents over 200 Btu/scf. Flares are not normally operated at the
very high steam to gas ratios that resulted in low efficiency in some tests
because steam is expensive and operators make every effort to keep steam
consumption low. Flares with high steam rates are also noisy and may be a
neighborhood nuisance.
The EPA has a program under way to determine more exactly the
efficiencies of flares used in the petroleum/SOCMI industry and a flare
test facility has been constructed. The combustion efficiency of four
flares (1 1/2 inches to 12 inches ID) will be determined and the effect on
efficiency of flare operating parameters, weather factors, and fuel
composition will be established. The efficiency of larger flares will be
estimated by scaling.
4.2.1.3 Applicability of flares. About 75 percent of the organic
•30
chemical plants are estimated to have a flare. Flares are usually
designed to control the normal operating vents or emergency upsets which
require release of large volumes of gases. Often, large diameter flares
designed to handle emergency releases are used to control low volume
continuous vent streams from distillation operations. In refineries usually
all process vents (including distillation vents) are combined in a common
gas line which supplies fuel to boilers and process heaters. However,
excess gases and fluctuations in flow in the gas line are sent to a flare.
The flare is a useful emission control device. It can be used for
almost any VOC stream, and can handle fluctuations in VOC concentration,
flowrate, and inerts content very easily. Some streams cannot be flared
4-19
-------
such as those containing high concentrations of halogen or sulfur compounds
due to corrosion of the flare tip or secondary pollution such as SCk.
4.2.2 Thermal Incineration
4.2.2.1 Thermal incineration process description. Any organic
chemical heated to a high enough temperature in the presence of enough
oxygen will be oxidized to carbon dioxide and water. This is the basic
principle of operation of a thermal incinerator. The theoretical tempera-
ture required for thermal oxidation to occur depends on the structure of the
chemical involved. Some chemicals are oxidized at temperatures much lower
than others. All practical thermal incineration processes are influenced by
time, mixing, and temperature. An efficient thermal incinerator system must
provide:
1. A chamber temperature high enough to enable the oxidation reaction
to proceed rapidly to completion,
2. Enough turbulence to obtain good mixing between the hot combustion
products from the burner, combustion air, and VOC, and
3. Sufficient residence time at the chosen temperature for the
oxidation reaction to reach completion.
A thermal incinerator is'us'ually a refractory-lined chamber containing
a burner at one end. As shown in Figure 4-5, discrete dual fuel burners
(1) and inlets for the offgas (2) and combustion air (3) are arranged in a
premixing chamber (4) to thoroughly mix the hot products from the burners
with the offgas air streams. The mixture of hot reacting gases then passes
into the main combustion chamber (5). This section is sized to allow the
mixture enough time at the elevated temperature for the oxidation reaction
to reach completion (residence times of 0.3 to one second are common).
Energy can then be recovered from the hot flue gases in a heat recovery
section (6). Preheating of combustion air or offgas is a common mode of
energy recovery; however, it is sometimes more economical to generate steam.
Insurance regulations require that if the waste stream is preheated, the VOC
concentration must be maintained below 25 percent of the lower explosive
limit (LEL) to prevent explosion hazards.
4-20
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Thermal incinerators designed specifically for VOC incineration with
natural gas as the auxiliary fuel may also use a grid-type .(distributed) gas
39
burner as shown in Figure 4-6. The tiny gas flame jets (1) on the grid
surface (2) ignite the vapors as they pass through the grid. The grid acts
as a baffle for mixing the gases entering the chamber (3). This arrangement
ensures burning of all vapors at lower chamber temperature and uses less
fuel. This system makes possible a shorter reaction chamber yet maintains
high efficiency.
Other parameters affecting incinerator performance are the offgas
heating value, the water content in the stream and the amount of excess
combustion air (the amount of air above the stoichiometric air needed for
reaction). The offgas heating value is a measure of the heat available from
the combustion of the VOC in the offgas. Combustion of offgas with a
o
heating value less than 1.86 MJ/Nm (50 Btu/scf) usually requires burning
auxiliary fuel to maintain the desired combustion temperature. Auxiliary
fuel requirements can be lessened or eliminated by the use of recuperative .
heat exchangers to preheat combustion air. Offgas with a heating value ._
3
above 1.86 MJ/Nm (50 Btu/scf) may support combustion but may need
auxiliary fuel for flame stability.
A thermal incinerator handling offgas streams with varying heating
values and moisture content requires careful adjustment to maintain the
proper chamber temperatures and operating efficiency. Water requires a
great deal of heat to vaporize, so entrained water droplets in an offgas
stream can substantially increase auxiliary fuel requirements owing to the
additional energy needed to vaporize the water and raise it to the combus-
tion chamber temperature. Combustion devices are always operated with some
quantity of excess air to ensure a sufficient supply of oxygen. The amount
of excess air used varies with the fuel and burner type but should be kept
as low as possible. Using too much excess air wastes fuel because the
additional air must be heated to the combustion chamber temperature. Large
amounts of excess air also increases flue gas volume and may increase the
size and cost of the system. Packaged, single unit thermal incinerators can
3
be built to control streams with flowrates in the range of 0.1 Mm /sec
(200 hundred scfm) to about 24 Nm3/sec (50,000'scfm).
4-21
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Waste Gas
Auxiliary
Fuel Burner-^
(discrete)
(1)
Air
Stack
Mixing
Section
(4)
Combustion
Section (5)
Optional
Heat
Recovery (6)
Figure 4-5. Discrete burner, thermal oxidizer.
(2)
Burner Plate-] Flame Jets7 (1)
Stack
Optional
Heat
Recovery
(4)
(natural gas)
Auxiliary Fuel
Figure 4-6. Distributed burner, thermal oxidizer.
4-22
-------
Thermal oxidizers for halogenated VOC control require additional
control equipment to remove the corrosive combustion products. The flue
gases are quenched to lower their.temperature and routed through absorption
equipment such as towers or liquid jet scrubbers to remove the corrosive
gases.
4.2.2.2 Thermal incinerator removal efficiency. The VOC destruction
efficiency of a thermal oxidizer can be affected by variations in chamber
temperature, residence time, inlet VOC concentration, compound type, and
flow regime (mixing). Test results show that thermal oxidizers can achieve
98 percent destruction efficiency for most VOC compounds at combustion
chamber temperatures ranging from 700 to 1300°C (1300 to 2370°F) and
40
residence times of 0.5 to 1.5 seconds. These data indicate that
significant variations in destruction efficiency occurred for C, to Cj-
alkanes and olefins, aromatics (benzene, toluene and xylene), oxygenated
compounds (methylethylketone and isopropanol), chlorinated organics (vinyl
chloride) and nitrogen containing species (acrylonitrile and ethylamines)
at chamber temperatures below 760°C (1400°F). This information used in
conjunction with kinetics calculations indicates the combustion chamber
parameters for at least a 98 percent VOC destruction efficiency are a
combustion temperature of 870°C (1600°F) and a residence time of
0.75 seconds (based upon residence in the chamber volume at combustion
temperature). A thermal oxidizer designed to produce these conditions in
the combustion chamber should be capable of high destruction efficiency for
almost any VOC even at low inlet concentrations.
At temperatures over 760°C (1400°F), the oxidation reaction rates are
much faster than the rate of gas diffusion mixing. The destruction
efficiency of the VOC then becomes dependent upon the fluid mechanics within
the oxidation chamber. The flow regime must assure rapid, thorough mixing
of the VOC stream, combustion air, and hot combustion products from the
burner. This enables the VOC to attain the combustion temperature in the
presence of enough oxygen for a sufficient time period for the oxidation
reaction to reach completion.
4-23.
-------
Based upon the studies of thermal oxidizer efficiency, auxiliary fuel
use, and costs it has been concluded that 98 percent VOC destruction or a
20 ppmv compound exit concentration (whichever is less stringent) is the
highest reasonable control level achievable by all new incinerators in all
41
distillation processes, considering current technology. Because of much
slower combustion reaction rates at lower inlet VOC concentrations, maximum
achievable VOC destruction efficiency decreases as inlet concentration
decreases. Therefore, a VOC weight percentage reduction based on the mass
rate of VOC exiting the control device versus the mass rate of VOC entering
the device, would be appropriate for vent streams with VOC concentrations
above approximately 2000 ppm (corresponding to 1000 ppm VOC in the incinera-
tor inlet stream since air dilution is typically 1:1). For vent streams
with VOC concentration below approximately 2000 ppm, it has been determined
that an incinerator outlet concentration of 20 ppm (volume, by compound), or
41
lower, is achievable by all new thermal'oxidizers. The 98 percent
efficiency estimate is predicated upon thermal incinerators operated at
870°C (1600°F) with 0.75 seconds residence time. Study results show that
this yields conservative estimates of costs and energy use for these type
units.
4.2.2.3 Applicability of thermal incinerators. In terms of technical
feasibility, thermal incinerators are applicable as a control device for
many distillation vents. They can be used for VOC streams with any
concentration and with any type of VOC. They can be designed to handle
minor fluctuations in flows. However, excessive fluctuations in flow
(upsets) might not allow the use of incinerators and would require the use
of a flare. Presence of compounds such as halogens or sulfur might require
some additional equipment such as scrubbers.
Thermal incinerators are usually capital intensive, but with efficient
recovery of energy from the flue gases they can be made economical.
4.2.3 Industrial Boiler and Process Heater Combustion Control Devices
Industrial boilers and process heaters can be designed to control VOC
by incorporating the distillation vent stream with the inlet fuel or by
feeding the stream into the boiler or heater through a separate burner. The
4-24
-------
following is a process description and discussion of the applicability and
efficiency of applying industrial boilers or process heaters to control VOC
from distillation vent streams. The process description for an industrial
boiler and a process heater are presented separately in the following two
sections. These process descriptions are focused on those aspects of each
process that relate to the use of these combustion devices as a VOC control
method.
4.2.3.1 Industrial boiler process description. Surveys of industrial
boilers show that the majority of industrial boilers used in the chemical
industry are of watertube design. Furthermore, over half of these boilers
42
use natural gas as a fuel. In a watertube boiler, hot combustion gases
contact the outside of heat transfer tubes which contain hot water and
steam. These tubes are interconnected by a set of drums which collect and
store the heated water and steam. The water tubes are of relatively small
diameter, 5 cm (2.0 inch), providing rap.id heat transfer, rapid response to
43
steam demands and relatively high thermal efficiency. Energy transfer
from the hot flue gases to water in the furnace water tube and drum system
can be above 85 percent efficient. Additional energy can be recovered from
the flue gas by preheating combustion air in an air preheater or by
preheating incoming boiler feedwater in an economizer unit.
When firing natural gas, forced or natural draft burners are used to
mix thoroughly the incoming fuel and combustion air. If a distillation ,y.ent
stream is combusted in a boiler, it can be mixed with the incoming fuel or
fed to the burnace through a separate burner. In general, burner design
depends on the characteristics of the fuel mix (when the vent stream and
fuel are combined) or of the vent stream alone (when a separate burner is
used). A particular burner design commonly known as a high intensity or
vortex burner can be effective for vent streams with low heating values
(i.e., streams where a conventional burner may not be applicable). Effec-
tive combustion of low heating valve streams is accomplished in a high
intensity burner by passing the combustion air through a series of spin
vanes to generate a strong vortex.
4-25
-------
Furnace residence time and temperature profiles vary for industrial
boilers depending on the furnace and burner configuration, fuel type, heat
44
input, and excess air level. A mathematical model has been developed
which estimates the furnace residence time and temperature profiles for a
45
variety of industrial boilers. This model predicts mean furnace
residence times of from 0.25 to 0.83 seconds for natural gas-fired water
tube boilers in the size range from 4.4 to 44 MW (15 to 150 x 10 Btu/hr).
Furnace exit temperatures for this range of boiler sizes are at or above
1475K (2200°F) with peak furnace temperatures occurring in excess of 1815K
(2810°F). Residence times for oil-fired boilers are similar to the natural
gas-fired boilers described here.
4.2.3.2 Process heater description. A process heater is similar to an
industrial boiler in that heat liberated by the combustion of fuels is
transferred by radiation and convection to fluids contained in tubular
coils. Process heaters are used in chemical manufacturing to drive
endothermic reactions such as natural gas reforming and thermal cracking.
They are also used as feed preheaters for other reactors and as reboilers
for some distillation operations. The fuels used in-process heaters include
natural gas, refinery offgases, and various grades of fuel oil. Gaseous
fuels account for about 90 percent of the energy consumed by process .
heaters.
There are many variations in the design of process heaters depending on
the application considered. In general, the radiant section consists of the
burner(s), the firebox, and a row of tubular coils containing the process
fluid. Most heaters also contain a convective section in which heat is
recovered from hot combustion gases by convective heat transfer to the
process fluid.
Process heater applications in the chemical industry can be broadly
classified with respect to firebox temperature: (1) low firebox temperature
applications such as feed preheaters and reboilers, (2) medium firebox
temperature applications such as steam superheaters, and (3) high firebox
temperature applications such as pyrolysis furnaces and steam-hydrocarbon
reformers. Firebox temperatures within the chemical industry can be
4-26
-------
expected to range from about 750°F for preheaters and reboilers to 2300°F
for pyrolysis furnaces.
4.2.3.3 Control efficiency. A boiler or process heater furnace can be
compared to an incinerator where the average furnace temperature and
residence time determines the combustion efficiency. However, when a vent
gas is injected as a fuel into the flame zone of a boiler or process heater,
the required residence time is reduced due to the relatively high flame zone
temperature. The following test data, which document the destruction
efficiencies for industrial boilers and process heaters, are based on
injecting the wastes identified into the flame zone of each combustion
control device.
An EPA sponsored test was conducted in an effort to determine the
destruction efficiency of an industrial boiler for polychlorinated biphenyls
(PCB's). The results of this test indicated that the PCB destruction
efficiency of an oil-fired industrial boiler firing PCB-spiked oil was
greater than 99.9 percent. This efficiency was determined based on the PCB
content measured by a gas chromatagraph in the fuel feed and flue gas.
As discussed in previous sections firebox temperatures for process
heaters show relatively wide variations depending on the application (see
Section 4.2.3.'2). Tests were conducted by EPA to determine the benzene
destruction efficiency of five process heaters firing a benzene offgas and
48 49 50
natural gas mixture. ' ' The units tested are representative of
process heaters with low temperature fireboxes (reboilers) and medium
temperature fireboxes (superheaters). Sampling problems occurred while
testing one of these heaters and as a result, the data for that test may not
51
be reliable and are not presented. The reboiler and superheater units
tested showed greater than a 98 percent overall destruction efficiency for
52
C, to Cg hydrocarbons. Additional tests conducted on a second superheater
and a hot oil heater showed that greater than 99 percent overall destruction
53
of C, to Cg hydrocarbons occurred for both units. These efficiencies were
determined based on the benzene content measured by a gas chromatagraph in
the fuel feed and flue gas.
-------
4.2.3.4 Applicability of industrial boilers and process heaters as
control devices. Industrial boilers and process heaters are currently used
by industry to combust off gases from distillation and refinery operations.
These devices are most applicable where high vent stream heat recovery
potential exists.
The primary purpose of a boiler is to generate steam. Process heaters
are applied within a plant for a variety of reasons including natural gas
reforming, thermal cracking, process feedstock preheating, and reboiling for
some distillation operations. Both devices are essential to the operation
of a plant and as a result, only streams which are certain not to reduce the
device's performance or reliability warrant use of a boiler or process
heater as a combustion control device. Variations in vent stream flowrate
and/or heating value could affect the heat output or flame stability of a
boiler or process heater and should be considered when using these
combustion devices. Performance or reliability may be affected by the
presence of corrosive products in the vent stream. Since these compounds
could corrode boiler or-process heater materials, vent streams with a
relatively high concentration of halogenated or sulfur containing compounds
are usually not combusted in boilers or process heaters. When corrosive VOC
compounds are combusted, the flue gas temperature must be maintained above
the acid dew point to prevent acid deposition and subsequent corrosion from
occurring.
The introduction of a distillation vent stream into the furnace of a
boiler or heater could alter the heat transfer characteristics of the
furnace. Heat transfer characteristics are dependent on the flowrate,
heating value, and elemental composition of the distillation vent stream,
and the size and type of heat generating unit being used. Often, there is
no significant alteration of the heat transfer, and the organic content of
the distillation steam can in some cases lead to a reduction in the amount
of fuel required to achieve the desired heat production. In other cases,
the change in heat transfer characteristics after introduction of the
distillation stream may adversely affect the performance of the heat
4-28
-------
generating unit, and increase fuel requirements. If for a given distilla-
tion vent stream, increased fuel is required to achieve design heat
production to the degree that equipment damage (for example, tube failure
due to local hot spots) might result, then heat generating units would not
be applicable as a VOC control device for that vent streams. In addition to
these reliability problems, there are also potential safety problems
associated with ducting distillation vents to a boiler or process heater.
Variation in the flowrate and organic content of the vent stream could, in
some cases, lead to explosive mixtures which could cause extensive damage. ,
Another related problem is flame fluttering which could result from these
variations.
When a boiler or process heater is applicable and available, they are
excellent control devices since they can provide at least 98 percent
destruction of VOC. In addition, near complete recovery of the vent stream
heat content is possible. However, both devices must operate continuously
and concurrently with the pollution source unless an alternate control
strategy is available in the event the heat generating capacity of either
unit is not required.
4.2.4 Catalytic Oxidation
4.2.4.1 Catalytic oxidation process description. Catalytic oxidation
is the fourth major combustion technique examined for VOC emission control.
A catalyst increases the rate of chemical reaction without becoming
permanently altered itself. Catalysts for catalytic oxidation cause the
oxidizing reaction to proceed at a lower temperature than required for
thermal oxidation. These units can also operate well at VOC concentrations
below the lower explosive limit which is a distinct advantage for some
offgas streams. Combustion catalysts include platinum and platinum alloys,
54
copper tixide, chromium and cobalt. These are deposited in thin layers on
inert substrates to provide for maximum surface area between the catalyst
and the VOC stream.
A schematic of a catalytic oxidation unit is shown in Figure 4-7. The
waste gas (1) is introduced into a mixing chamber (3) where it is heated to
about 316°C (600°F) by contact with the hot combustion products of a
4-29
-------
Auxiliary
Fuel Burners
(2)
Waste Gas
(1)
I— Catalyst Bed (4)
Mixing Chamber (3)
Figure 4-7. Catalytic oxidizer.
Optional
Heat Recovery
(5)
4-30
-------
burner (2). The heated mixture is then passed through the catalyst bed (4).
Oxygen and VOC migrate to the catalyst surface by gas diffusion and are
adsorbed in the pores of the catalyst. The oxidation reaction takes place
at these active sites. Reaction products are desorbed from the active sites
55
and transferred by diffusion back into the waste gas. The cleaned gas
may then be passed through a waste heat recovery device (5) before
exhausting into the atmosphere.
The operating temperature range of combustion catalysts is usually from
316°C (600°F) to 650°C (1200°F). Lower temperatures may result in slowing
down and possibly stopping the oxidation reaction. Higher temperatures may
result in shortened catalyst life and possibly evaporation of the catalyst
from the support substrate. Any accumulation of particulate matter,
condensed VOC, or polymerized hydrocarbons on the catalyst can block the
active sites and reduce effectiveness. Catalysts can also be deactivated by
compounds containing sulphur, bismuth, phosphorous, arsenic, antimony,
56
mercury, lead, zinc, or tin, or halogens. If these compounds exist in
the catalytic unit, VOC will pass through unreacted or be partially oxidized
to form aldehydes, ketones and organic acids. These compounds are highly
reactive atmospheric pollutants and can corrode plant equipment.
4.2.4.2 Catalytic oxidizer control efficiency. Catalytic oxidizer
destruction efficiency is dependent on the space velocity, (the catalyst
volume required per unit volume gas processed per hour), operating tempera-
ture, and waste gas VOC composition and concentration. A catalytic unit
operating at about 450°C (840°F) with a catalyst bed volume of 0.014 to
0.057 m3 (0.5 to 2 ft3) per 0.47 Nm3/s (1000 scfm) of offgas passing
57
through the device can achieve 95 percent VOC destruction efficiency.
Some catalytic units have been reported to achieve 97.9 to 98.5 percent
CO
destruction efficiencies. These higher efficiencies are usually
obtained by increasing the catalyst bed volume to offgas flow ratio. The
cost of this increased catalyst bed can be prohibitive.
4.2.4.3 Applicability of catalytic oxidizers. The sensitivity of
catalytic oxidizer to VOC inlet stream flow conditions, their inability to
handle high VOC concentration offgas streams, and their higher cost for
4-31
-------
destruction efficiencies comparable to thermal oxidizers limit the applica^
tion of catalytic units for control of VOC from distillation operations.
4.3 SUMMARY
The two general classifications of VOC control techniques discussed in
the preceding sections include noncombustion and combustion control devices.
This section summarizes the major points regarding control device applica-
bility and performance.
The noncombustion control devices discussed include adsorbers,
absorbers and condensers. Noncombustion control devices may be attractive
if a significant amount of usable VOC can be recovered, but they may not be
applicable to some distillation vent streams. For example, adsorbers may
not always be applicable to vent streams with high VOC concentrations or to
vent streams containing low molecular weight compounds. Absorbers are
generally not applied to streams with VOC concentrations below 200 to
300 ppmv, while condensers are not well suited for application to vent
streams containing low boiling point VOC or to vent streams with large inert
concentrations. Even though these restrictions exist, information in the
NEP shows that many condensers and absorbers are applied to distillation
vent streams in the synthetic organic chemical manufacturing industry.
Control efficiencies for the noncombustion devices considered vary from
50 to 95 percent for condensers and up to 95 percent for adsorbers.
The combustion control devices considered include flares, industrial
boilers, process heaters, thermal incinerators, and catalytic incinera-
59
tors. In general, these devices are applicable to a wide variety of
vent stream characteristics and all can achieve at least 98 percent
destruction efficiency. Combustion devices are capable of adapting to
moderate changes in effluent flowrate and concentration while control
efficiency is not affected by the type of VOC present. This is generally
not the case with noncombustion control devices. In general, combustion
control devices are both capital and energy intensive except where boilers
or process heaters are applied and the energy content of the vent stream is
recovered. However, because these devices are essential to the operation of
a chemical plant, only streams that are certain not to reduce boiler or
4-32
-------
process heater performance and reliability warrant use of these systems.
Application of a scrubber prior to atmospheric discharge may be required
when vent streams containing high concentrations of halogenated or
sulfonated compounds are combusted in an enclosed combustion device. In
addition, vent streams with high concentrations of corrosive halogenated or
sulfonated compounds may preclude the use of flares because of possible
flare tip corrosion and may preclude the use of boilers and process heaters
because of potential internal (boiler) corrosion.
There are some disadvantages associated with VOC control by combustion:
(1) high capital and operating costs result from thermal oxidation tech-
niques, which could require a plot of land as large as 300 ft by 300 ft for
installation; (2) since offgas must be collected and ducted to the combus-
tion device long duct runs may lead to condensation of combustibles and
possibly to duct fires; and (3) since thermal oxidizers utilize combustion
with a flame for achieving VOC destruction, the unit must be located at a
safe distance from process equipment in which flammable chemicals are used.
Alternatively, special designs may be employed to minimize the risk of
explosion or fire.
4-33
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4.4 REFERENCES
1. U.S. Environmental Protection Agency. Office of Air and Waste Manage-
ment. Control Techniques for Volatile Organic Emissions from
Stationary Sources. Research Triangle Park, N.C. Publication
No. EPA-450/2-78-022. May 1978. p. 53.
2. Stern, A.C. Air Pollution, Volume IV, 3rd Edition, New York, Academic
Press, 1977. p. 336.
3. Reference 2, p. 355.
4. Reference 2, p. 356.
5. Basdekis, H.S. (Hydroscience.) Emissions Control Options for the
Synthetic Organic Chemical Industry. Control Device Evaluation.
Carbon Adsorption. (Prepared for U.S. Environmental Protection
Agency.) Research Triangle Park, North Carolina. EPA Contract
No. 68-02-2577. February 1980. p. 11-15.
6. Reference 5, p. 11-15.
7. Reference 5, p. 1-4^
8. Staff of Research and Education Association. Modern Pollution Control
Technology. Volume I, New York, Research and Education Association,
1978. pp. 22-23.
9. Standifer, R.L. (Hydroscience.) Emissions Control Options for the
Synthetic Organic Chemical Industry. Control Device Evaluation. Gas
Absorption. (Prepared for U.S. Environmental Protection Agency.)
Research Triangle Park, North Carolina. EPA Contract No. 68-02-2577.
May 1980. p. III-5.
10. Perry, R.H., Chilton, C.H. Eds. Chemical Engineers Handbook.
5th Edition. New York. McGraw-Hill. 1973. p. 14-2.
11. Reference 1, p. 76.
12. Reference 2, p. 24.
13. Reference 1, p. 72.
14. Reference 9, p. II-l.
15. Reference 10, p. 14-1.
16. Reference 9, p.- III-5.
4-34
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17. Erikson, D.G. (Hydroscience.) Emissions Control Options for the
Synthetic Organic Chemical Industry. Control Device Evaluation.
Condensation. (Prepared for U.S. Environmental Protection Agency.)
Research Triangle Park, North Carolina. EPA Contract No. 68-02-2577,
July 1980, p. II-l.
18. Reference 1, p. 83.
19. Reference 17, p. IV-1.
20. Reference 17, pp. II-3, III-3.
21. Reference 1, p. 84.
22. Reference 17, p. II-l.
23. Reference 17, p. II-3.
24. Reference 17, p. III-5.
25. Kalcevic, V. (IT Enviroscience.) Control Device Evaluation - Flares
and the Use of Emissions as Fuels. In: U.S. Environmental Protection
Agency. Organic Chemical Manufacturing Volume 4: Combustion Control
Device. Publication No. EPA-450/3-80-026. December 1980. Report 4.
26. Klett, M.G. and J.B. Galeski. (Lockhead Missiles and Space Co., Inc.)
Flare Systems Study. (Prepared for U.S. Environmental Protection
Agency.) Huntsville, Alabama. Publication No. EPA-600/2-76-079.
March 1976.
27. Joseph, D., et al. Evaluation of the Efficiency of Industrial Flares
Used to Destroy Waste Gases, Phase I Interim Report - Experimental
Design, DRAFT. (Prepared for U.S. Environmental Protection Agency.)
Research Triangle Park, North Carolina. EPA Contract No. 68-02-3661.
January 1982.
28. Palmer, P.A. A Tracer Technique for Determining Efficiency of an
Elevanted Flare E. I. duPont de Nemours and Company, Wilmington, DE.
1972.
29. Siege!, K. D. Degree of Conversion of Flare Gas in Refinery High Flares
Ph.D. Dissertation, Fridericiana University, Karlsruhe, FRG, 1980.
30. Lee, K.C., and Whipple, G.M., Waste Gaseous Hydrocarbon Combustion in a
Flare. Union Carbide Corp., Presented at 74th APCA Annual Meeting,
South Charleston, West Virginia. June 1981.
31. Reference 28. '
4-35
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32. Reference 30.
33. Reference 29.
34. Howes, J.E., et al. (Battelle Columbus Laboratories.) Development of
Flare Emission Measurement Methodology. Draft Final Report. (Prepared
for U.S. Environmental Protection Agency.) Research Triangle Park,
North Carolina. August 1981.
35. McDaniel, et al. (Engineering-Science.) A Report on a Flare
Efficiency Study (Draft). (Prepared for U.S. Environmental Protection
Agency.) Research Triangle Park, North Carolina. September 1982.
36. Reference 34.
37. Reference 35
38. Letter from Matey, J.S., CMA, to Beck, D., EPA. November 25, 1981.
39. Reed, R.J. North American Combustion Handbook. Cleveland, North
American Manufacturing Company, 1979. p. 269.
40. Memo and attachments from Farmer, J.R., EPA, to distribution,
August 22, 1980. 29 pp. Thermal incinerator performance for NSPS.
41. Reference 40.
42. Oevitt, T., et al. The Population of Industrial and Commercial
Boilers. PEDCo Environmental, Inc., May 1979. p. xxi, 28.
43. U.S. Environmental Protection Agency. Background Information Document
for Industrial Boilers. Research Triangle Park, North Carolina.
Publication No. EPA-450/3-82-006a. March 25, 1982. p. 3-27.
44. U.S. Environmental Protection Agency. A Technical Overview of the
Concept of Disposing of Hazardous Wastes in Industrial Boilers (Draft).
Concinnati, Ohio. EPA Contract No. 68-03-2567. October 1982. p. 44.
45. Reference 44, p. 73.
46. Hunter, S.C. and S.C. Cherry. (KVB) NO Emissions from Petroleum
Industry Operations. Washington, D.C. API Publication No. 4311.
October 1979. p. 83.
47. U.S. Environmental Protection Agency. Evaluation of PCB Destruction
Efficiency in an Industrial Boiler. Research Triangle Park, North
Carolina. Publication No. EPA-6QO/2-81-055a. April 1981.
4-36
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48. U.S. Environmental Protection Agency. Emission Test Report on
Ethylbenzene/Styrene. Amoco Chemicals Company. Texas City, Texas.
Research Triangle Park, North Carolina. EMB Report No. 79-OCM-13.
August 1979.
49. U.S. Environmental Protection Agency. Emission Test Report. El Paso
Products Company. Odessa, Texas. Research Triangle Park, North
Carolina. EMB Report No. 79-OCM-15. April 1981.
50. U.S. Environmental Protection Agency. Emission Test Report. USS
Chemicals. Houston, Texas. Research Triangle Park, North Carolina.
EMB Report No. 80-OCM-19. August 1980.
51. Reference 48.
5.2. Reference 49.
53. Reference 50.
54. Staff of Research and Education Association. Modern Pollution Control
Technology. Volume I. New York Research and Education Association,
1978. p. 23-6.
55. Reference 1, p. 32.
56. Kenson, R.E. (Met-Pro Corporation.) A Guide to the Control of
Volatile Organic Emissions. Technical Page 10T-1. Harleysville,
Pennsylvania. (In-house Brochure). 1981
57. Key, J.A. (Hydroscience.) Emissions Control Options for the Synthetic
Organic Chemicals Manufacturing Industry. .Control Device Evaluation.
Catalytic Oxidation. (Prepared for U.S. Environmental Protection
Agency.) Research Triangle Park, North Carolina. EPA Contract
No. 68-02-2577. March 1980. p. 1-1.
58. Reference 57.
59. Blackburn, J.W. (Hydroscience.) Emissions Control Options for the
Synthetic Organic Chemicals Manufacturing Industry; Control Device
Evaluation: Thermal Oxidation. (Prepared for U.S. Environmental
Protection Agency.) Research Triangle Park, North Carolina. EPA
Contract No. 68-02-2577. July 1980. pp. IV-1, V-l.
4-37
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5. MODIFICATION AND RECONSTRUCTION
New Source Performance Standards (NSPS) affect new facilities and
existing facilities that have been modified or reconstructed in accordance
with the Code of Federal .Regulations Title 40, Sections 60.14 and- 60.15.l
An existing facility is defined in 40 CFR 60.2 as a facility of the type for
which standards of performance have been promulgated and the construction or
modification of which was begun prior to the proposal date of the applicable
NSPS.
For plants within the Synthetic Organic Chemical Manufacturing Industry
(SOCMI), a reactor facility is a synthetic organic chemical reactor/vent gas
processing equipment train. Such a train could consist of individual series or
parallel reactors and all equipment used to process or clean vent gases from
the reactors (e.g., product/by-product recovery devices). A typical
facility may consist of two or more parallel reactors, each feeding process
vent streams to one or more product recovery devices (e.g., condensers,
absorbers, adsorbers). These product recovery devices can be placed
in parallel; that is, more than one device may be used to recover VOC to
successively lower levels in the vent stream. Each reactor feeding offgas
into separate product recovery devices would constitute a separate facility.
A SOCMI reactor facility does not include distillation operations, air
oxidation reactors, or fugitive emission sources.
This chapter identifies some possible changes to reactor facilities at
SOCMI plants that might be deemed modifications or reconstructions.
5.1 MODIFICATION
"Modification" is defined in 40 CFR 60.14(a) as any physical or opera-
tional change of an existing facility that increases the emission rate of
any pollutant to which a standard applies. Exceptions to this definition
are presented in paragraph (e) of Section 60.14. These exceptions are:
1. Routine maintenance, repair, and replacement.
2. An increase in the production rate not requiring a capital expendi-
ture as defined in Section 60.2(bb).
5-1
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3. An increase in the hours of operation.
4. Use of an alternative fuel or raw material if the existing facility
was designed to accommodate that alternative fuel or raw material
prior to the effective date of the standards.
5. The addition or use of any system or device whose primary function
is the reduction of air pollutants, except when a system is removed
or replaced by a system considered to be less efficient.
6. Relocation or change in ownership.
If any other modification is made to the operation of an existing
facility that may result in an increased emission rate for each pollutant to
which the standard applies, the facility becomes an affected facility under
the provisions of Section 60.14.
The following discussion identifies some possible changes to reactor
operations used in the SOCMI which might be considered modifications. The
magnitude of the industry covered and the complexity of the manufacturing
process permit only a general discussion of these possible changes.
Furthermore, the list of potential modifications identified for reactor
facilities is not exclusive. The following general types of process modifi-
cations are identified for reactor facilities:
1. Feedstock or reactant substitution.
2. Process equipment changes.
3. Combinations of the above.
Feedstock or reactant substitution is dictated by economics and the
level of availability of the feedstock or reactant. Depending upon the
specific process, a change in feedstock may require substantial capital
investment to modify the process to accommodate the change. The magnitude
of the capital investment may prohibit feedstock substitution for many
chemicals.
Over 50 percent of the chemicals considered can be manufactured from
two or more different feedstocks. In most cases, feedstock substitution may
require equipment and/or process changes as well. For example,
cyclohexanone can be manufactured using either phenol or cyclohexanol as the
feedstock. Although use of cyclohexanol has predominated in the industry in
5-2
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the past, at least one plant has changed from cyclohexanol to phenol as the
feed material (see Appendix , plant Hyd-7). -This feedstock
substitution required the addition of a hydrogenation reactor to the
existing cyclohexanone unit.
For many chemicals, the potential exists to substitute air for pure
oxygen as a reactant or vice versa. These reactant substitutions may
increase VOC emissions to the atmosphere and as a result may constitute a
modification. Either of these may be substituted for chemical oxidation
processes as well. Changing to an air oxidation process may be an advantage
because (1) air is readily available and (2) expensive corrosion-resistant
materials are not required compared to the use of chemical oxidants.
However, there may be major disadvantages in changing from an oxygen or
chemical oxidation process to an air oxidation process, including a
substantial reduction in plant capacity, a large increase in the reactor-
related process vent stream flowrate, and an altered product mix.
Process equipment changes may also constitute modifications. Examples
of potential modifications are the replacement of a fixed-bed reactor with a
fluidized-bed reactor, increasing the plant capacity by increasing the size
of the reactor or adding additional reactors, and a change in the product
recovery system ( e.g., from an absorber to a condenser). Based on a survey
of chemical plant construction summaries for the last 5 years, plant
capacity expansions are expected to be the most wide-spread potential
modification. Such changes might be considered modifications since they can
result in increased VOC emissions to the atmosphere.
A combination of the changes described above would be chosen in any
given situation with the decision based on the most advantageous economics.
The combination of changes might be considered a potential modification if
they resulted in an increase in emissions. The most common combinations are
plant expansions or simultaneous changes in feedstock and catalyst as
described earlier. Other combinations are possible and currently are
encountered.
5.2 RECONSTRUCTION
Under the provisions of Section 60.15, an existing facility becomes an
affected facility upon reconstruction, regardless of changes in pollutant
5-3
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emission rates. Reconstruction is defined as the replacement of components
whose costs exceed 50 percent of the fixed capital cost of a comparable,
entirely new facility. Futhermore, the facility is considered an affected
facility if it is economically and technically feasible for the facility to
comply with the applicable standards of performance. The final judgement on
what replacement constitutes reconstruction and when it is technologically
and economically feasible to comply with the applicable standards of
performance is made on a case-by-case basis by the Administrator: The
Administrator's final determinations are made considering the following
bases:
1. Comparison of the fixed capital costs of the replacement components
and a comparable, entirely new facility,
2. Comparison of the estimated life of the facility after the
replacements and the life of a comparable, entirely new facility,
3. The.extent to which the components being replaced cause or contribute
to the emissions from the facility, and
4. Any economic or technical limitations on compliance with applicable
standards of performance which are inherent in the proposed
replacements.
The purpose of this provision is to prevent an owner or operator from
perpetuating an existing facility by replacing all but vestigial components,
support structures, frames, housing, etc., rather than totally replacing the
facility in order to avoid applicability to an NSPS. In accordance with
Section 60.5, EPA will, upon request, determine if the action taken
constitutes construction (including reconstruction).
5-4
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5.3 REFERENCES
1. The U.S. Environmental Protection Agency. Code of Federal Regulations.
Title 40, Chapter I, Subpart A, part 60. Washington, D.C., Office of
The Federal Register.
2. CE Construction Alerts. Chemical Engineering. 90: 80-51.
April, 1983. 89: 128-129. May, 1982. 88_: 152-155. April, 1981.
87: 134-136. April, 1980. 86: 96-98. March, 1979.
5-5
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6. REGULATORY ANALYSIS
This chapter describes the method of regulatory analysis used in the
development of new source performance standards (NSPS) for distillation
operations. The selection of the control options used in the regulatory
analysis is discussed. The methods of presenting the regulatory alterna-
tives are discussed and the range of results are presented.
The regulatory analysis is based on the screened National Emission
Profile (NEP) (see Chapter 3) that represents the national VOC emissions
from distillation operations. To project the national impacts in the fifth
year of NSPS implementation, the results of the regulatory analysis must be
scaled up from the number of distillation units in the profile (195) to the
number of new, modified, or reconstructed units expected nationally (1200).
The results presented in Section 6.4 have been scaled up to represent the
1200 new distillation units expected nationally.
6.1 OVERVIEW OF THE REGULATORY ANALYSIS
Typically, new source standards are developed for an industry that
utilizes one or two processes to manufacture a specific product. For such a
case, on'e or two model plants are generally designed to illustrate the
emissions and control device requirements of typical new sources within that
industry. These model plants, projected onto the number of new sources
coming on-line in a specified time period, are then used to analyze the
economic, energy, and environmental impacts of several regulatory alterna-
tives. The regulatory alternatives are generally based on the use of
several applicable control devices that may have different control efficien-
cies, costs, and energy requirements. The results of this regulatory
analysis permit selection of the regulatory alternative that reflects the
emission reduction achievable (considering costs) through application of the
best demonstrated technology for continuous emission reduction. The
selection process also includes consideration of any non-air quality health,
environmental, and energy impacts.
5-1
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Hundreds of organic chemicals are manufactured using a multitude of
different processes in the organic chemical manufacturing industry.
Development of standards for VOC emissions from the production of each
chemical or process would be time-consuming and extremely resource
intensive. Close examination of production processes in the organic
chemical manufacturing industry shows that, although the manufacture of
organic chemicals is complex and diverse, volatile organic compound (VOC)
emissions originate primarily from a few sources such as equipment leaks
(fugitive emission sources), storage tank vents, reaction system vents, and
distillation operation vents. The characteristics of equipment and
processing operation within a source type are similar enough to make
possible the development of widely applicable standards for each source
type, i.e. unit operations standards. For example, emissions from
distillation operations result from the release into the atmosphere of
noncondensibles which may contain organic compounds. This common emission
mechanism and the basic similarities .among distillation equipment used by
chemical manufacturers make the development of unit operations standards
applicable to all distillation operations feasible and practical given
limited time and resources.
This broad approach applied to distillation operations results in three
major differences in the standards development process from the typical
standards development. First, the screened NEP (introduced in Chapter 3)
representing future distillation vent streams under a baseline (no NSPS)
scenario is used as the basis from which to estimate the energy, cost, and
environmental impacts of regulatory alternatives instead of the model plant
approach. Typical or model distillation operations could not be developed
that would adequately represent the population of new distillation units.
Second, instead of examining only a few regulatory alternatives,
(usually representing application of different control devices of varying
effectiveness), a range of regulatory alternatives is analyzed, each
assuming universal application of one type of control (combustion) to
varying numbers of new distillation units. As shown in the control device
discussions in Chapter 4, combustion is the only control technique
6-2
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universally applicable to control of distillation vent emissions. The
extremes of regulatory alternatives vary from no required control of
distillation vent streams to control of all distillation vent streams.
Between these extremes, regulatory alternatives are based on control of
varying proportions of the population of new distillation units. A ranking
of the units controlled in the screened NEP is provided based on the cost
effectiveness or total resource effectiveness (TRE; see Appendix 6) of added
VOC control (i.e. cost per unit of emission reduction achieved). By
considering discrete TRE levels between no additional control and control of
all columns, a complete range of regulatory alternatives based on a single .
control technique can be examined.
Third, all noncombustion control devices are considered part of the
affected facility for the regulatory analysis. Thus, the uncontrolled
emissions for each distillation unit in the screened NEP (see Chapter 3) are
defined using the emission stream characteristics determined after all
noncombustion devices such as scrubbers, adsorbers, and condensers. These
devices are used more often for product recovery than air pollution control.
Excepting these three departures from the typical regulatory analysis
framework, the impacts of each regulatory alternative are determined in the
same manner as for other standards development programs. Control devices
are sized and costed for each distillation unit in the screened NEP and the
associated impacts are determined. As in a typical regulatory analysis
framework, the control devices examined in the regulatory analysis are
chosen based on applicability to the sources under investigation.
6.2 SELECTION OF CONTROL OPTIONS
Industrial experience indicates that many types of control devices,
including condensers, absorbers, adsorbers, incinerators, boilers, and
flares, can be used to reduce VOC emissions from distillation units.
Selection of the best VOC control device for a particular distillation unit
emission stream and determination of the degree of control achievable depend
upon the chemical composition of the emission stream and other process
characteristics. The stream flowrate, VOC concentration, the chemical and
physical properties of the stream components, and the stream temperature may
6-3
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greatly affect the effectiveness of devices such as condensers, adsorbers,
and absorbers. As a result, none of these product recovery devices is •
considered suitable for VOC reduction for every distillation unit emission
stream.
Thermal oxidation, however, using a boiler, a flare, or a thermal
incinerator is much less dependent upon process and emission stream charac-
teristics. Consequently, it is the only demonstrated VOC control technique
universally applicable to organic chemical distillation operations.
Furthermore, thermal oxidation can achieve the highest possible VOC control
level of all currently demonstrated technologies.
Boilers achieve a 98 percent reduction of VOC emissions and can be
applied at a reasonable cost to all nonhalogenated streams except those that
create safety or boiler reliability problems. They are the least expensive
of the three combustion devices since they are assumed to exist in the plant
already (only pipeline connections are needed) and VOC destruction can
provide energy credit by reducing fuel consumption. Incinerators can' also
achieve a 98 percent reduction of VOC emissions, can be applied to all
halogenated and nonhalogenated streams, but are generally the most costly of
the three devices. Flares are judged to achieve 98 percent efficiency in
destroying VOC over a wide range of stream characteristics and operating
conditions, can be applied to all nonhalogenated streams, and generally can
control VOC emissions in nonhalogenated streams for less cost than
incinerators.
Due to the limitations of applicability and relative differences in
cost between these three combustion devices, no single combustion device can
be determined to be BDT for the entire distillation source category.
Therefore, BDT for this source category has been determined to be as
follows: 1) for nonhalogenated streams, except for those instances where
safety or reliability problems would be created, BDT is a boiler; 2) for
nonhalogenated streams that create safety and reliability problems for
boilers, flares are BDT; and 3) for halogenated streams incinerators are
BDT.
6-4
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For the purpose of the regulatory analysis, the impacts of combustion
control of distillation emission streams are based on the use of flares for
nonhalogenated streams and incinerators for halogenated streams. Flares can
be applied to all nonhalogenated streams with few, if any, safety or relia-
bility problems, but they are assumed to be more expensive than boilers.
Thus, the use of flares for impact evaluation would result in more
conservative estimates of control costs than would the use of boilers.
Although the three combustion devices have been determined to be BDT
for organic chemical distillation operations as a whole, Section 111 of the
Clean Air Act permits the distinction among classes, types, and sizes within
categories of new sources for the purpose of establishing NSPS. Since vent
stream characteristics vary widely, both the cost per unit emission
reduction and the adverse environmental impacts of applying combustion
devices also are expected to vary widely. Therefore, it is possible that
for some vent streams the cost or environmental impacts of applying controls
would be so large that BDT for these streams would be no additional control.
6.3 SUMMARY OF THE SCREENED NATIONAL EMISSION PROFILE (NEP)
In order to evaluate the impacts of controlling distillation emission
streams by combustion, the screened NEP is used to represent existing
distillation vent streams. This profile is further assumed to represent the
distribution of new distillation vent streams expected in the future. A
summary of the screened NEP appears in Table 6-1. Since only a limited
amount of data is needed to evaluate the impacts of using combustion control
devices on distillation vent streams, the screened NEP provides a
statistical profile on which the regulatory analysis can be based.- Further
information on the NEP and screened NEP, illustrating available data in the
profile and the method of VOC emission factor development, is provided in
Chapter 3.
Before the regulatory analysis can be made, however, the existing
control level must be considered. As discussed in Chapter 3, this control
level depends to a large extent on existing local and State regulations.
The screened NEP is adjusted to represent existing (baseline) controls and
is called the baseline control profile. Considering the existing control
6-5
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TABLE 6-1. OVERVIEW OF THE SCREENED NATIONAL EMISSION PROFILE
1. Units Screened Out of NEP
Total number of units in the NEP
Units at plants with incomplete data3
Units with recycled emissions, or zero flowrate
Number of Units in Screened NEP
2. Operating Characteristics of the Screened NEP
o
Average offgas flowrate, m /min (scfm) 1.0 (36)
Flow range, m3/min (scfm) 0.001-18 (0.005-637)
Average VOC emission rate, kg/hr (Ib/hr), 36 (78)
precontrolled
Average VOC emission rate, kg/hr (Ib/hr), 5.9 (13)
controlled0
VOC emission range, kg/hr (Ib/hr), 0-1670 (0-3668)
precontrolled
aThere are a number of plants in the NEP for which there were distillation
units with insufficient data to permit calculation of VOC control costs.
Calculated downstream of adsorbers, absorbers, and condensers, but upstream
of combustion devices.
cControlled VOC emission rates were estimated using a 98 percent destruction
efficiency for flares, boilers, and incinerators (where it was indicated
that control devices were being used).
6-6
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levels in both categories (SIP states and non-SIP states) in the screened
NEP, the baseline control level is established at about 81 percent. The
baseline control profile is used to predict the impacts of various
regulatory alternatives.
6.4 RESULTS OF REGULATORY ANALYSIS
As described earlier in the chapter, the regulatory analysis involves
examination of the impacts of applying combustion control systems to the
individual vent streams given in the statistical profile, or screened NEP.
The analysis simulates the application of controls to varying numbers of the
population of new distillation units. The lower extreme of the regulatory
alternatives is represented by no additional control, or baseline control
(i.e. about 81 percent). And the upper bound on the regulatory alternatives
is represented by controlling all distillation units in the screened NEP
(i.e. 98 percent emission reduction). Regulatory alternatives between these
extremes are investigated by controlling varying proportions of the units in
the NEP. For each control system applied to each unit in the screened NEP,
the associated impacts (annualized cost, capital cost, energy requirement,
emission reduction, cost effectiveness of control) are calculated.
By costing individually controlled distillation columns in the
regulatory analysis, a large degree of conservatism is introduced into the
costs of control. But, in those plants having more than one distillation
column, ducting of multiple streams to a common control device would lower
the total control costs for that plant. Therefore, this approach to
combining streams in a given plant was used in developing the cumulative
costs for the regulatory analysis. Plants already having controls available
would probably employ these existing devices for control of other streams.
By not considering this possibility, additional cost conservatism is
introduced.
The easiest way to study the application of controls to individual
units in the screened NEP is to rank the units. Controls would be added to
units according to the ranking sequence. Ranking is best presented in terms
of the impacts associated with control: cost, energy, or environmental.
6-7
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Cost effectiveness is a cost of control per unit emission reduction
achieved. A cost effectiveness value is often useful since it describes not
only a cost impact, but also the primary environmental impact. Therefore, a
ranking based on some type of cost effectiveness value was selected as the
best means of presenting the regulatory alternatives.
Cost effectiveness can be described in terms of an individual value, an
average value (consider the cumulative values), or an incremental value
taken across the ranked profile. The individual value is the annualized
cost of control per unit emission reduction achieved by the control device
and thus describes the cost effectiveness of controlling a single column.
The average value is the cumulative cost of control in the ranking per
cumulative emission reduction achieved through application of controls.
This value is generally low and does not accurately reflect the cost
effectiveness actually incurred by the owner or operator of a distillation
unit. The incremental cost effectiveness across the ranked profile is the
increase in cumulative cost in the ranked profile per increase in associated
emission reduction. Such incremental values are often useful in evaluating.
different control techniques, but they can be misleadingly high when applied
to a statistical profile like the screened NEP. Since individual column
control costs are of greatest interest in this study, the individual cost
effectiveness value was chosen as the basis of the ranking for the
regulatory analysis. And to avoid confusion among the type of cost
effectiveness used for the analysis, it is defined as the total resource
effectiveness (TRE). Methods of determining TRE are developed further in
Appendix 6.
Under a TRE ranking, control systems are added to those distillation
columns in the screened NEP so that for any regulatory alternative the least
overall cost per unit emission reduction is attained. The resources (costs)
required for contrql were calculated based on use of flares on nonhaloge-
nated vent streams and use of incinerators for halogenated vent streams.
Flares were chosen instead of boilers for nonhalogenated vent streams
because flares present more conservative annualized cost estimates and
because they can be used in all instances, whereas boilers are not always
6-8
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applicable. Using results from the regulatory analysis, the number of units
controlled at several selected TRE levels are presented in Table 6-2. . These
levels span the entire range of regulatory alternatives. Because emission
stream VOC content and heating value generally are related inversely to
supplemental energy and capital requirements for VOC control, those streams
containing the highest levels of VOC are ranked before lower concentration •
streams. Therefore, TRE can be used to evaluate the achievability of a
given control level by using the least possible amount of total resources.
Other results from the regulatory analysis are presented in Chapter 7.
6-9
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TABLE 6-2. RELATIONSHIP BETWEEN NUMBER OF UNITS EXPECTED TO BE CONTROLLED
AND PERCENTAGE OF UNITS REQUIRING CONTROL AT VARIOUS TRE LEVELS
TRE, $/Mg
0 (Baseline)
100
300
600
1000
1400
1900
2500
2900
3500
9000
20000
75000
CO
Percentage of Units
Requiring
Control
0
9.7
17.4
22.6
30.3
37.4
42.6
44.6
45.1
52.3
58.5
66.7
79.5
100
Number of
Units Requiring
Control
0
117
209
271
363
449
511
535
542
628
702
800
954
1200
Number of
Units Expected to
be Controlled*
312
343
375
430
509
596
654
654
660
702
778
857
1001
1200
*Some units not required to use combustion control as a result of NSPS are expected to be controlled
for other reasons.
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7. ENVIRONMENTAL AND ENERGY IMPACTS
This chapter presents estimates of the nationwide environmental impacts
that would result from implementation of combustion control (flare, boiler,
incinerator) to distillation vent streams. The estimates are based oh an
analysis of the distillation vent streams listed in the screened National
Emission Profile (NEP). Impacts on air quality, water quality, solid waste,
and energy requirements are presented. The analysis considers both the
impacts attributed directly to a control device (e.g., reduced VOC
emissions) and the indirect or secondary impacts (e.g., aggravation of
another pollutant problem through the use of a control device). The
beneficial and adverse impacts of VOC control are examined, with,emphasis on
an assessment of1 the national incremental impacts of successively more
stringent regulatory alternatives.
As discussed in Chapter 6, the regulatory alternatives range from the
baseline level of control (no additional control of new units required) to
requiring combustion controls on all new distillation units. Within this
range, varying percentages of new units would be required to use combustion
devices for VOC control. For selected regulatory alternatives (control ,
levels), the associated environmental impacts are presented. The procedure
for determining these impacts is reviewed briefly here.
The determination of the various impacts is the focus of the regulatory
analysis. In this analysis, control devices are applied individually to
each of the 195 distillation columns listed in the screened NEP, simulating
application of controls to new distillation units. For each control device
applied (flare, boiler, incinerator), the associated cost, energy, and
environmental impacts are calculated for each column. These impact
calculations are based upon the heat and material balance computation,
equipment sizing, and costing criteria discussed in Chapter 8 and
Appendix F. '
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To determine the sequence in which distillation units in the screened
NEP should be controlled, they are ranked in order of increasing total
resource effectiveness or TRE of control (see Appendix G). This ranking of
units results in a continuously increasing resource cost per unit of
emission reduction across the entire screened NEP. By examining various TRE
levels, a wide spectrum of regulatory alternatives can be evaluated,
ranging from the,baseline control level (no additional VOC control) to the
98 percent control level associated with control of all distillation units.
As a result, the analysis provides a range of regulatory alternatives and
associated impacts.
In order to represent national impacts in the fifth year of NSPS imple-
mentation, the analysis results are scaled up using the ratio of the
expected new distillation units (1200)* to the number of distillation units
in the screened NEP (195). This chapter presents the national impacts for
new sources for selected TRE levels which span the range of regulatory
_^
alternatives considered.
The national impacts are dependent on the control device actually
selected by the plant. The VOC control efficiency assumed for the combus-
tion devices considered in the regulatory analysis is 98 percent for
incinerators, boilers, and flares. The energy requirements for each device
are substantially different, however. Furthermore, the use of incinerators
is almost always more expensive than the use of either flares or boilers.
It is assumed for the purpose of this analysis that incinerators will not be
the preferred control devices for nonhalogenated streams due to the cost
disadvantage. On the other hand, incinerators are assumed to be used for
*As described in Section 9.1.3, it is estimated that 605 new plants will
come on stream in the first 5 years of NSPS. (A plant, in this case, is a
chemical site, that is, one or more process units that are located at one
site and used to produce one particular chemical. In ordinary usage, a
plant consists of one or more process units that are located at one site
and used to produce one or more chemicals.) The NEP indicates that there
are approximately 3.4 distillation units per plant and that 58% of all
distillation units have VOC emissions. Therefore, the number of new units
expected to be affected by a distillation NSPS is 605 x 3.4 x .58 = 1193 or
1200.
7-2
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halogenated streams where flares and boilers are not always applicable.
Since the choice between using boilers or flares depends on various criteria
other than stream composition and flow (see Section 4.2.3.3), two impact
analyses are presented for all nonhalogenated streams, one assuming use of
flares (unless other devices are used under baseline) and one assuming use
of boilers.
7.1 AIR POLLUTION IMPACTS
7.1.1 Effects of VOC Control
The primary impacts of the regulatory alternatives considered consist
of VOC emission reductions from organic chemical distillation operations.
VOC emissions from affected distillation facilities in 1987 were estimated
using the projected number of new plants (see Chapter 9) and the emissions
data contained in the screened NEP.
The total precontrolled* 1987 emissions from new distillation.operation
vents would be 273,000 Mg/yr (300,000 tons/yr). At the estimated baseline
control level, 81 percent of these emissions are controlled. Thus, the
national VOC emissions from new distillation units at the baseline control
level are 51,000 Mg/yr (56,000 tons/yr).
Tables 7-1 and 7-2 present the 1987 VOC emissions reductions for
various representative control'levels spanning the range of regulatory
possibilities. The analysis presented in Table 7-1 assumes that all
distillation operations requiring c'ontrol will use a flare except for vent
streams containing halogenated VOC, which are controlled by incinerator/
scrubber systems. The analysis presented in Table 7-2 assumes that all
distillation operations requiring control will Use a boiler except for
streams containing halogenated VOC, which will use an incinerator/scrubber
system. The most stringent control level, representing control of all
distillation units, would provide 46,000 Mg/yr (50,000 tons/yr) of VOC
emissions reduction beyond the baseline level of control for new distilla-
tion sources.
K
"Precontrolled" refers to emissions downstream of product recovery devices
projected to be installed (based on the screened NEP), but upstream of any
combustion device.
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TABLE 7-1. VOC EMISSIONS AND ENERGY REQUIREMENTS FOR FLARE PREFERENCE*
Percent
Of Units
Requiring
Control
0
(Baseline)
9.7
17.4
22.6
30.3
37.4
42.6
44.6
45.1
52.3
58.5
66.7
79.5
100
TRE**
0
100
300
600
1,000
1,400
1,900
2,500
2,900
3,500
9,000
20,000
75,000
CO
National
Emissions
(10-3 Mg/yr)
51.0
24.4
20.3
17.2
10.8
8.8
7.1
7.1
7.0
6.6
6.1
5.8
5.5
5.5
National
Emission
Reduction
Baseline
(1(T Mg/yr)
0
26.6
30.7
33.8
40.2
42.2
43.9
43.9
•44.0
44.4
44.9
45.2
45.5
45.5
National
Energy Impacts
(10^ MM Btu/yr)
0
7.2
8.4
11.3
43.7
50.5
54.5
54.6
54.7
55.7
64.9
73.9
95.4
110
**
Calculated for 1982 through 1987.
k
TRE represents the cost per Mg of VOC removed for the last distillation
column to be controlled in the regulatory possibility. See Chapter 6
and Appendix G for a more detailed discussion of TRE.
7-4
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TABLE 7-2. VOC EMISSIONS AND ENERGY REQUIREMENTS FOR BOILER PREFERENCE*
Percent
Of Units
Requiring
Control
0
(Baseline)
9.7
17.4
22.6
30.3
37.4
42.6
44.6
45.1
52.3
58.5
66.7
79.5
100
TRE**
0
100
300
600
1,000
1,400
1,900
2,500
2,900
3,500
9,000
20,000
75,000
CO
National
Emissions
(HT Mg/yr)
51.0
24.4
20.3
17.2
10.8
8.8
7.1
7.1
7.0
6.6
6.1
5.8
5.5
5.5
National
Emission
Reduction
Baseline
(KT Mg/yr)
0
26.6
30.7
33.8
40.2
42.2
43.9
43.9
. 44.0
44.4
44.9
45.2
45.5
45.5
National
Energy Impacts
(1(T MM Btu/yr)
0
(242)***
, (267)
(277)
(282)
(284)
(283)
(283)
(285)
(288)
(286)
(282)
(268)
(272)
Calculated for 1982 through 1987.
**
TRE represents the cost per Mg of VOC removed for the last distillation
column to be controlled in the regulatory possibility. See Chapter 6 and
Appendix G for a more detailed discussion of TRE. .
***
Parentheses indicate energy credit due to conservation of normal fuel
requirements.
7-5
-------
7.1.2 Other Effects on Air Quality
Some adverse effects on air quality are associated with the use of
combustion devices to reduce VOC. Pollutants generated by the combustion
process, particularly nitrogen oxides (NO ), may have an unfavorable impact
A
on ambient air quality. The principal factors affecting the rate of NO
X
formation are the amount of excess air available, the peak flame tempera-
ture, the length of time the combustion gases are at peak temperature, and
the cooling rate of the combustion products. For thermal oxidizers, the
rate of NO formation is expected to be low due to relatively low combustion
X
temperatures and relatively short residence times.
Thermal oxidizer outlet concentrations of NO were measured in seven
A
sets of thermal oxidizer tests conducted at three air oxidation plants. The
test results indicate that NO outlet concentrations range from eight to
3
200 ppmv (0.015 to 0.37 g/m ). These values could increase by several
orders of magnitude in a poorly designed or operated unit. These tests are
described and documented in Appendix D. Although there are conflicting
data, some studies report that incineration of vent streams containing high
levels of nitrogeneous compounds may also result in increased NOV
2
emissions. The maximum outlet NO concentration measured from a combustion
A
device at an acrylonitrile plant was 200 ppmv. The vent stream of this
plant contains nitrogeneous compounds. The NO concentrations measured at
A
two other plants, where the vent streams do not contain nitrogeneous
o
compounds, range from 8 to 30 ppm (0.015 to 0.056 g/m ).
Control by thermal oxidation of halogenated VOC emissions may result in
the release of halogenated combustion products to the environment. However,
flue gas scrubbing can be used to remove these compounds from the
incinerator outlet stream. Incineration temperatures greater than 871°C
(1600°F) are required to ensure near total destruction of halogenated VOC.
For example when incinerating chlorinated VOC at temperatures of 980°C to
1100°C (1800°F to 2000°F), almost all chlorine present exists in the form of
hydrogen chloride (HC1). The HC1 emissions generated by thermal oxidation
3
at these temperatures can be removed efficiently be wet scrubbing.
7-6
-------
7.2 WATER POLLUTION IMPACTS
Control of VOC emissions using thermal oxidation does not result in
any significant increase in wastewater discharge by distillation unit opera-
tions. That is, no water effluents are generated by the thermal oxidizer.
The use of an incinerator/scrubber system for control of halogenated
VOC vent streams results in increased water consumption. In this type of
control system, water is used to remove the acid gas contained in the
thermal oxidizer outlet stream. The increase in total plant wastewater
would be relatively small and would not affect plant waste treatment or
sewer capacity. However, the absorbed acid gas may cause the water leaving
the scrubber to have a low pH. This acidic effluent could lower the pH of
the total plant effluent if it is released into the plant wastewater system.
The water effluent guidelines for individual states may require that
industrial sources maintain the pH of water effluent within specified
limits. To meet these guidelines, the water used as a scrubbing agent may
need to be neutralized prior to discharge to the plant effluent system. The
scrubber effluent can be neutralized by adding caustic (NaOH) to the
scrubbing water. The amount of caustic needed depends on the amount of acid
gas in the waste gas. For example, approximately 1.09 kilograms
(2.4 pounds) of caustic (as NaOH) are needed to neutralize one kilogram
(2.2 pounds) of HC1.
The salt formed in the neutralization step must be purged from the
system and properly eliminated. The methods of disposal include direct
waste water discharge or salt recovery. The increased water consumption and
caustic costs were included in the projected operating costs for units in
the screened National Emission Profile indicating halogenated VOC vent
streams. About 15 percent of the units in the screened NEP have halogenated
VOC in the vent gases. The national caustic (as NaOH) consumption is
estimated to be 3,750 Mg/yr (4,120 tons/yr) at an annual cost of about
$360 thousand. Approximately 86 percent of these requirements are for only
2 percent of the national population, however. The cost associated with the
disposal of the salt were not judged to be significant in comparison to the
control costs, and therefore, were not included in the projected impacts.
7-7
-------
7.3 SOLID WASTE DISPOSAL IMPACTS
There are no significant solid wastes generated as a result of control
by thermal oxidation. A small amount of solid waste for disposal could
result if catalytic oxidation, instead of thermal oxidation, were used by a
facility to achieve an equivalent degree of VOC control. The solid waste
would consist of spent catalyst. If a facility were to use an additional
absorption column for improved product recovery as an alternative to meeting
the NSPS with a combustion device, a small amount of solid waste could be
\
generated by cleaning the column.
7.4 ENERGY IMPACTS
7.4.1 Energy Requirements for Combustion Devices
The use of combustion devices to control VOC from distillation vents
can result in a net energy savings in some cases, while in other instances a
net fuel usage results. The use of an existing boiler for control of
energy-rich streams generally results in a net savings of the fuel normally
used in the boiler. An extremely low energy value of the distillation vent
stream may severely compromise the steam production rate, however. The use
of an incinerator results in a net energy usage if supplemental fuel is
needed to support combustion, or to promote flame stability. Flares can
also require supplemental fuel for flame stability if the heat content of
the vent stream is very low.
The determination of fuel usage requirements for all three types of
combustion equipment is discussed as part of the overall cost methodology in
Section 8.1 and is detailed in "Distillation Operations Regulatory Analysis
Program Guide" which describes the computer programs used in the regulatory
analysis.
Tables 7-1 and 7-2 present the energy requirements for various control
levels in the range of regulatory alternatives. Table 7-1 presents the
requirements for a flare preference and Table 7-2 presents the requirements
for a boiler preference (see Section 7.1.1).
7-8
-------
7.4.2 Other Energy Requirements
Electricity is required to operate the pumps, fans, blowers, and
instrumentation that may be necessary to control VOC using a boiler,
incinerator, or flare. Fans, and blowers are needed to transport vent
streams and combustion air; pumps are necessary to circulate absorbent
through a scrubber required to treat corrosive offgases from a incinerator
combusting halogenated VOC. '
7.5 OTHER ENVIRONMENTAL IMPACTS -
7.5.1 Considerations for Installing Control Equipment
Depending on the volume of offgas to be controlled, thermal oxidizers .
may require a site as large as 300 feet by 300 feet for installation.
Because thermal oxidizers use combustion with a flame to control VOC
emissions, these units must be located at a safe distance from process
equipment handling flammable chemicals; otherwise, special precautions must
be taken to minimize the risk of explosion or fire.
7.6 OTHER ENVIRONMENTAL CONCERNS
7.6.1 Irreversible and Irretrievable Commitment of Resources
The use of combustion devices to control VOC emissions from distilla-
tion operations usually requires the use of supplemental energy in the form
of natural gas. The adverse effects of using these nonrenewable resources
must be considered when evaluating the benefits of controlling the release
of potentially harmful air pollutants.
The use of product recovery techniques or process modifications is
another alternative to reduce VOC emissions. Control of VOC emissions using
product recovery techniques might be a viable alternative to combustion
control for some distillation facilities. Since the distillation vent
streams containing VOC also are derived ultimately from petroleum, these
techniques would result in conservation of both chemicals and fuels derived
from petroleum.
7.6.2 Environmental Impact of Delayed Standards
Delay of standards for distillation operations could result in signi-
ficant adverse impacts on ambient air quality. Based on industry growth
7-9
-------
projections, distillation facilities controlling VOC emissions at current
baseline levels (i.e., 81 percent national VOC reduction) would emit
78,000 Mg/yr (86,000 tons/yr) of VOC in 1987 compared to 6,000 Mg/yr
(6,600 tons/yr) under the most stringent, control level (100 percent of
distillation vent streams controlled by 98 percent efficient control
device).
The energy considerations of a delayed standard are difficult to
assess. If all owners or operators chose to control distillation emissions
by means of a boiler, an energy savings would result. However, because of
cost, safety, or other considerations, many owners or. operators would
probably use flares, resulting in some energy use. The most likely
situation, where a mix of boilers and flares are used, would.result in a
very small impact on national energy use. In this instance, the energy
impact of delaying the standard would be slight.
7-10
-------
7.7 REFERENCES
1. Blackburn, J.W. (Hydroscience). Emissions Control Options for the
Synthetic Organic Chemicals Manufacturing Industry. Control Device
Evaluation. Thermal Oxidation. (Prepared for U.S. Environmental
Protection Agency.) Research Triangle Park, N.C., EPA Contract
No. 68-02-2577. July 1980. p. V-43.
2. Basdekis, H.S. (Hydroscience). Emissions Control Options for the
Synthetic Organic Chemicals Manufacturing Industry. Control Device
Evaluation. Thermal Oxidation Supplement (VOC-Containing Halogens or
Sulfur). (Prepared for U.S. Environmental Protection Agency.)
Research Triangle Park, N.C., EPA Contract No. 68-02-2577.
November 1980. pp. II-4, II-6.
3. Reference 2, p. 111-15.
4. Memo from Senyk, D. and J. Stelling, Radian Corporation, to
Distillation File. August 30, 1982. 192 p. Distillation Operations
Regulatory Analysis Program Guide.
7-11
-------
-------
8. COSTS
This chapter presents the approach taken to estimate the cost of
controlling volatile organic compound (VOC) emissions from distillation
operations used in the manufacture of synthetic organic chemicals. Design
and cost equations are presented for the boiler, flare and incinerator
control systems considered in the regulatory analysis. In examining the
range of regulatory alternatives described in Chapter 6, the total resource
cost of controlling individual vent streams is determined by applying these
cost equations to vent streams characterized in the screened National
Emission Profile (MP). Each vent stream in the screened NEP is ranked
according to the total resource effectiveness (TRE) of VOC control,
expressed in $/Mg of VOC controlled. Control systems are then applied to
all streams incurring a resource cost at or below a specified cutoff value.
National cost impacts for a specified cutoff level are determined by summing
the control costs for all vent streams where controls are applied. National
costs for a wide range of cutoff values have been calculated. These costs
are projected to 1987 by estimating the number of new distillation units
expected.
The costing approach used for the regulatory analysis differs from the
worst case costing approach used in the economic analysis presented in
Chapter 9.' The differences between these two approaches are discussed in
Section 8.2.3. The costs associated with other environmental regulations
affecting plants using distillation operations are discussed in Section 8.3.
8.1 DEVELOPMENT OF CONTROL SYSTEM COSTS ,
This section presents the methodology used to develop VOC control
system costs for boilers, flares and incinerators. In addition, costs ,for
each control system are presented and discussed. A control system consists
of a combustion control device and all associated equipment needed to couple
-------
the device to the emission source. For example, an incinerator control
system consists of the incinerator combustion chamber, ducts, fans, stack,
recuperative heat exchanger (when applicable), quench/scrubber system,
transport pipelines, and compressor. A common pipeline model is applied to
all control systems. Therefore, the discussion of pipeline design and
capital costs are presented separately from the control device discussions.
Cost development consists of the following two tasks: sizing the
control system and costing the system. The general approach used consists
of determining the design parameters for a control system applied to a
particular VOC stream. Based on these design parameters, the system is
costed using cost equations developed from vendor and industry supplied
information.
8.1.1 Control System Sizing
In general, equations are used to calculate equipment size, operating
conditions, reagent consumption (caustic) and utility use (fuel, electri-
123
city, steam, water) for any set of vent stream characteristics. ' ' A
control system is selected and sized based on the vent stream flow rate, VOC
content, and chlorine content. This section highlights the important
features of the design analysis and summarizes the methodology used to
determine the basic design and operating parameters used to determine costs.
The equations used are outlined in more detail in Appendix F.
8.1.1.1 Thermal Incinerator. The thermal incinerator system consists
of the following equipment: combustion chamber, recuperative heat
exchanger, quench/scrubber system, ducts, fan and stack. The incinerator
sizing equations estimate the combustion chamber volume, heat exchanger
surface area (where applicable), and various system operating parameters.
These estimated equipment sizes and operating parameters are used to
determine the total installed capital cost of the incinerator system.
The combustion chamber volume is a function of the incinerator
residence time and calculated flue gas flowrate. For a specific vent
stream, the flue gas flowrate is determined through mass and energy balances
based on the incinerator temperature, the primary and supplementary natural
gas requirements and the excess air level assumed. These general design
8-2
-------
specifications, presented in Table 8-1, were developed in a report by IT
Enviroscience (formerly Hydroscience) and are based on vendor supplied
4 3
data. Vendor contacts indicate that a combustion chamber volume of 1.01 m
3 5
(35.7 ft ) is the smallest size commercially available. For vent streams
3 3
requiring a combustion chamber volume smaller than 1.01 m , the 1.01 m size
is applied. To compensate for the application of an oversized combustion
chamber in this case, natural gas and air are added to maintain the desired
temperature and residence time for this oversized incinerator.
A recuperative heat exchanger, which preheats, combustion air, is
provided when its use does not result in exceeding the design incinerator
temperature. For example, a heat exchanger is not applied to vent streams
with heating values high enough to maintain or exceed the desired
incinerator temperature, because further increasing the temperature could
result in damage to the combustion chamber and would not provide any fuel
savings. When a recuperative heat exchanger is applicable, the surface area
is calculated based on the combustion air flow rate, ambient air tempera-
ture, flue gas temperature and the overall heat transfer coefficient
presented in Table 8-1.
It is assumed the thermal incinerator uses a quench/scrubber system for
all streams containing corrosive chlorine compounds. Water is used to cool
the flue gases in a quench chamber before introduction to the scrubber for
acid gas removal. The acidic water resulting from waste gas scrubbing is
neutralized with caustic. The quench water and caustic requirements are
determined through mass and energy balances and the general scrubber design
specifications listed in Table 8-1. Calculation of the scrubber volume and
diameter is not required since the equipment cost is a function of gas
flowrate and not the volume and diameter as discussed in Section 8.1.2.
However, the quench/scrubber costs are based on the general design
specifications outlined in Table 8-1.
8.1.1.2 Industrial Boiler. When a boiler is applied to control VOC,
it is assumed the plant has an existing boiler which can be modified to
accommodate the vent stream. Surveys of industrial boilers show that
natural gas-fired watertube boilers are predominant in the chemical
8-3
-------
TABLE 8-1. INCINERATOR GENERAL DESIGN SPECIFICATIONS'
4,5
Item
Specification
00
Emission control efficiency
Minimum incinerator volume3
Incineration temperature
• low temperature incineration .
• high temperature incineration
Furnace residence times
• low temperature incineration
• high temperature incineration
Primary fuel requirement
Supplemental fuel requirement,(h = vent
stream heating value in MJ/nm (Btu/scf)
• 0 < h < 1.9 (0 < h < 50)
• 1.9 < h < 3.7 (50 < h < 100)
• h > 3.7 (h > 100)
Recuperative heat exchanger
• overall heat transfer coefficient
Scrubber system
• type
• packing height
• liquid/gas ratio
• gas velocity
• scrubber gas temperature
98 percent destruction
1.01m3 (35.7 ft3)
870°C (1600°F)
1100°C (2000°F)
0.75 sec
1.00 sec
Fuel required to maintain incinerator temperature
with 18 percent excess air
Required for flame stability
Add 0.38 MJ/nm3 (10 Btu/sef)
Add 10 percent of stream heating value
No supplemental fuel required
Not applicable when vent stream heating value is
sufficient to maintain design incinerator
temperature
K (4.0 Btu/hr^ft2.°F)
23 W/m2.0
Used when corrosive VOC is present
Packed tower
11.0 -n (36.0 ft)
1337 1/nT (10 gal/scf)
0.9 m/s (3.0 ft/s)
100°C (212°F)
_
If calculated incinerator combustion chamber volume is less than 1.01 m (35.7 ft ),^natural gas
and air are added to maintain the design temperature and residence time for a 1.01 m (35.7 ft )
incinerator volume.
""Used when corrosive VOC are present due to the difficulty of achieving complete combustion of
corrosive VOC at lower temperatures.
-------
industry. Therefore, this boiler type is assumed to be used for all vent
streams where a boiler is applicable. The boiler modifications considered
•3
are based on combusting a 0.472 nm /s (1000 scfm) vent stream in the
industrial boiler specified in Table 8-2. This is the highest vent stream
flowrate found in the screened NEP. Boiler modifications include increasing
the induced draft fan size and replacement of the existing burner with one
capable of burning a fuel and vent gas mixture. The modified equipment
specifications are shown in Table 8-2. The burner specifications are based
on the most expensive burner identified through vendor contacts and the fan
size is based on the pressure drop associated with combusting the combined
natural gas and vent stream gases. A boiler equation was developed to
predict the mass and energy transfer characteristics for the boiler
selected. This model, which is based on a series of heat and mass transfer
equations is used to predict the resultant steam production (energy credit)
associated with combusting a vent stream containing VOC.
8.1.1.3 Flare. The flare design consists of an elevated, guy
supported, steam assisted, smokeless flare. Published correlations relating
vent stream flow, heating value, and composition to the flare height and tip
8
diameter are used in the flare design. The general design specifications
used in developing these correlations are discussed below and presented in
Table 8-3.
Flare height and tip diameter are the basic design parameters usedjto
determine the installed capital cost of a flare. The tip diameter selected
is a function of the combined vent stream and supplemental fuel flowrates,
the combined gas temperature and molecular weight, and the maximum tip
pressure drop assumed. Supplemental fuel requirements and tip pressure drop
are shown in Table 8-3. Determination of flare height is based on worker .
safety requirements. The flare height is selected so the maximum ground
level heat intensity is 3787 W/m2 (1200 Btu/hr ft2). Vendor contacts
indicate that the smallest flare commercially available is thirty feet high
o
and two inches in diameter. For vent streams requiring smaller flare
systems, this is the minimum flare size used.
3-5
-------
TABLE 8-2. INDUSTRIAL BOILER GENERAL DESIGN SPECIFICATIONS
6,7
Item
Specification
CO
Emission control efficiency
Boiler type
Boiler heat output capacity
Modified equipment specifications
burner type
burner size
fan blades .
motor power
fan speed
Vent stream flowrate
Supplemental fuel requirement
98 percent destruction
Natural gas-fired, watertube boiler
10 MW (35 x 106 Btu/hr)
Low Btu gas vortex burner
10MW (35 x 105 Btu/hr)
91.4cm (36 inch) radial fan
48 kW (65 brake h.p.)
1200 rpm
0.472 nm3/s (1000 scfm)
From 0 to 10 percent of vent stream flow rate
required to maintain flame stability. Absolute
amount depends on vent stream heating value.
This burner would replace the existing natural gas burner.
""without introduction of the vent stream to this boiler a 37.3 kW (50 bhp), 1000 rpm motor is
required. The fan blade size is 88.9 cm (35 inch).
"Based on maximum vent stream flowrate found in the screened NEP.
-------
TABLE 8-3. FLARE GENERAL DESIGN SPECIFICATIONS^
Item
Specification
O3
Emission control efficiency
General flare design
minimum flare tip diameter
minimum flare height
maximum ground level heat intensity
flare tip pressure drop
emissivity
number of pilots
• pilot gas requirement
• steam requirement
• purge gas requirement
Supplemental fuel requirement
98 percent destruction
Elevated, guy supported, steam assisted,
smokeless flare
5.1 cm (2.0 inch)
9.0 m (3Q ft) ' • 9
3787 W/nT (1200 Btu/hr»fr)
69 cm (27 inch) w.c.
0.13
Tip diameter-cm (inch)
D < 20 • (_< 8)
20 < D < 61 (8 < D < 24)
61 < D < 107 (24 < D < 42)
- 107 < D < 178 (42 < D < 70)
D > 178
Number of pilots
1
2
3
4
o 5
(D > 70)
2.26 m /hr (80 scf/hr) of natural gas per pilot
0.4 kg/kg vent gas
0.01 m/s (0.04 ft/s) gas velocity at tip
Natural gas required to maintain vent stream
heating value of 5.6 MJ/nm (150 Btu/scf) for
flame stability
Natural gas used to purge system.
-------
The natural gas required for pilots and purge, and the mass flow of
steam required are calculated after the flare height and tip diameter are
determined. Pilot gas consumption is a function of the tip diameter as
shown in Table 8-3. Based on the tip diameter, the number of pilots is
selected and the pilot gas flowrate is calculated assuming a gas flow of
o
2.26 m /hr (80 scfh) per pilot. The purge gas requirement is also a
function of the tip diameter, and the design purge gas velocity at the tip
as shown in Table 8-3. Steam use is that flow which maintains a steam to
flare gas ratio of 0.4 kg steam/kg vent gas.
8.1.1.4 Pipeline/Compressor System. The pipeline/compressor system
described in this section is required for all combustion control systems
considered in the regulatory analysis. The pipeline design, which is based
on information supplied from chemical manufacturers, consists of two pipe
legs. It is assumed that 21m (70 feet) of pipe are required to join a
distillation unit with a compressor. The length of pipe from the compressor
to the control device is assumed to be 600m (2000 feet) for boilers and
flares, and 150m (500 feet) for incinerators. The number of valves,
fittings, and other piping components are identified in Appendix F.
The diameter of pipe selected for each vent stream is calculated using
Q
economic pipe diameter equations published in the literature. Once all
diameters are selected, the pipeline system pressure drop is estimated and
the compressor brake horsepower is determined. In the regulatory analysis,
a separate header and compressor are provided for each individual vent
stream at a specific plant. With respect to control costs, this is
considered to be a conservative approach since in many cases more than one
vent stream at a plant can be transported in a single pipeline/compressor
system at a lower cost.
8.1.2 Capital Cost Bases
The capital cost for each combustion control system includes the
purchase and installation of all equipment and piping systems necessary to
control a vent stream from an individual distillation unit. Table 8-4
presents a summary of the equations used to estimate installed capital costs
for new flares and incinerators. These equations were generated by using a
8-8
-------
TABLE 8-4. CAPITAL COST EQUATIONS FOR NEW FLARES AND INCINERATORS
Control Device
Item
Installed Capital Cost Equation
(1978 $)D
Flare
Flare and auxiliaries
0.895 (23,086 + 193.6 D2 + 5.7H2)3
00
to
Incinerator
Combustion chamber
(Incineration temperature of
1600°F)
Combustion chamber
(Incineration temperature of
2000°F)
Recuperative heat exchanger
Quench/scrubber
3.58 (51,964 + 67.99 Vrr - 0.0014 V '
\+\s \*\*
3.58 (50,490 + 55.33 V - 0.0001 V
cc
2.28 (18,574 + 33.61 A^0'9139)3
0.895 (180,139 + 54.99F - 0.00123F2)1
aD = flare diameter (in.); H = flare height (ft); V = combustion chamber volume (ft );
2
A^ = heat exchanger surface area (ft ); F = incinerator exit gas flow rate (scfm).
Costs are changed from 1979 to 1978 dollars by using a ratio of fabricated equipment indices
(References 11 and 12). Ratio = 1978 indice _ 244.0 n DQJ-
1979 indice " "ZTTT = u-byb
-------
linear regression analysis of cost curves presented by IT Enviroscience. -
Boilers are assumed to have a constant capital cost for modification when
they are applied to any vent stream. Pipeline system costs are a summation
of many individual component costs (i.e., pipes, fittings, valves,
compressors).
The capital cost bases for incinerators, boilers, flares, and pipeline/
compressor systems are discussed in the following sections. All capital
costs and cost equations are adjusted from December 1979 to December 1978
dollars using the Fabricated Equipment Indices published in The Chemical
11 12
Engineering Economic Indicators. '
8.1.2'.l Thermal Incinerator. Capital costs for the thermal incinera-
tor are based on cost curves developed by IT Enviroscience. Individual
cost equations for the incinerator combustion chamber, recuperative heat
exchanger and scrubber are based on a linear regression analysis of these
cost curves.
The incinerator cost equations provide a relationship between equipment
cost and combustion chamber volume for two incineration temperatures. The
high temperature equation (2000°F) is used when corrosive VOC are present in
the vent stream while the low temperature equation (1600°F) is used in the
absence of corrosive VOC. In addition to the cost of the chamber itself,
the equation also accounts for the cost of fans, ducts, and stack. A
modified Lang factor of 4.0 is applied to the combustion chamber capital
cost equation to account for such installation cost factors as foundation,
insulation, erection, instruments, painting, electrical, fire protection,
13
engineering, freight and taxes.
When a recuperative heat exchanger is included in the incinerator
system (see Section 8.1.1.1 for applicability), the equipment cost is
obtained as a function of the total heat exchanger surface area. Determina-
tion of the surface area is discussed in Section 8.1.1.1. A modified Lang
13
factor of 2.6 is used to estimate installation costs. The installation
components considered are the same as those identified for the combustion
chamber with the exception of fire protection.
8-10
-------
It is assumed that halogenated or corrosive streams require the use of
a quench/scrubber system after the incinerator to remove these corrosive
products of combustion. The capital cost of this system is determined as a
function of the total incinerator exit gas flowrate. The cost equation is
based on a linear regression analysis of the cost curves presented by
IT Enviroscience in a report on thermal oxidizers. The total installed
capital cost of the incinerator system is the summation of the combustion
chamber, heat exchanger, quench/scrubber, and pipeline/compressor costs.
8.1.2.2 Industrial Boiler. The installed capital cost associated with
using a boiler for VOC control consists of the costs for the burner and fan
modifications discussed in Section 8.1.1.2, and the pipeline/compressor
system. The costs for boiler modification were obtained from vendor
o
contacts for the size and design of the boiler selected. Since burner and
fan substitution is being considered, the modification costs are assumed to
be the incremental cost of the new equipment over a conventional burner and
fan. The estimated total installed capital cost associated with modifying
the boiler is $10,000 (1978 dollars).8 ;
8.1.2.3 Flare. The capital cost of a flare is based on IT Enviro-
science data and vendor supplied information. Enviroscience data provides
the total installed capital cost of a flare as a function of flare height
and tip diameter for systems designed to burn propylene. .' The vendor data
provides installed capital costs, flare height, and tip diameter for flares
combusting eight different VOC's. A cost equation was developed from a
linear regression analysis of the combined data set. This equation yields
the total installed capital cost of a flare as a function of height and tip
diameter. The installed capital cost of a new flare system is the sum of
the cost determined from this equation and the cost of the pipeline/.
compressor transport system. The installed capital cost of an existing
flare is simply that cost associated with the pipeline/compressor system.
8.1.2.4 Pipeline/Compressor System. The pipeline capital costs
include the equipment and installation cost of pipes, fittings, and
compressors necessary to transport the vent stream from its source to the
control device. The purchase cost for sizes of pipe and fittings
8-11
-------
commercially available are obtained from The Richardson Rapid System Process
Plant Construction Cost Estimating Standards. Compressor costs are
determined from vendor supplied capital cost data and are specified as a
function of compressor brake horsepower.
8.1.3 Annualized Cost Bases
The annualized costs' include direct operating and maintenance costs,
and annualized capital charges. The assumptions used to determine
annualized costs are presented in Table 8-5, and are given in 1978 dollars.
Direct operating and maintenance costs include operating and maintenance
I O
labor, replacement parts, utility use, fuel consumption, and caustic use.
Utility requirements include electricity for fans, pumps and compressors,
steam for flare operation, and make-up water for quench system operation.
Supplemental natural gas is required to increase the heating value of vent
streams, to maintain pilot flames, and to purge flare systems. Caustic is
required to neutralize acidic scrubber water. Direct operating and
maintenance costs are determined from the design specifications developed
for each distillation vent stream and the annual cost factors presented in
Table 8-5. Capital charges include annualized equipment costs, indirect
19
costs for overhead, taxes, insurance, administration and capital recovery.
A ten year life is assumed for all combustion systems while capital recovery
is based on a 10 percent capital charge taken over the 10 year life span of
the equipment. The assumptions used for capital charges are shown in
Table 8-5.
To account for reduced production levels and downtime an annual
capacity utilization factor of 77 percent is used. This translates into an
annual operating level of 6745 hrs/yr.
8.1.4 Comparison of Control System Costs
This section presents and discusses the capital costs, annualized
costs, and average cost effectiveness for boilers, new flares, existing
flares, and incinerators. These costs are determined by applying the
costing methodology developed in the previous sections, to individual
distillation vent streams characterized in the screened NEP.
8-12
-------
TABLE 8-5. BASES FOR ANNUALIZED CONTROL SYSTEM COSTS
Direct Operating Cost Factors
Hours of operation (hrs/yr)a 6745
Maintenance as a percent of total 6
installed capital cost (includes
labor and replacement parts)
Operating labor cost (1978 $/hr) (including 13.08
overhead)
Operating labor (manhours)
Incinerator . 1200
Incinerator with heat exchanger 1500
Incinerator with scrubber 2400
Industrial boiler 730
Flare 620
Pipeline/compressor ' 0
Utilities and Reagentsb (1978 $)
Electricity ($/10QO kWh) 49
Natural Gas ($/10° Btu) 5.03
Quench and scrubbing water ($/1000 gal) 0.22
Steam ($/1000 Ib) 5.90
Caustic ($/1000 Ib) 43.60
Capital Charges0
Equipment life (years) , 10
Interest rate (percent) 10
Capital recovery factpr (percent of 16.27
total installed cost)
Taxes, insurance, administration 5
(percent of total installed cost)
Reference 20.
Reference 18.
°Reference 19.
Before tax interest rate shown. After tax rate = 8.5 percent.
eCapital recovery factor = i (1 + i)n = 0.1627 (before taxes).
ri = equipment life (10)
i = interest rate (0.1)
(1 + i)n - 1
8-13
-------
For a specific control system, capital and annualized costs show a wide
variation with varying vent stream flowrate and heating value. Therefore,
five vent streams or cases are selected for analysis which allow the
comparison of control system costs over a wide range of vent stream heating
values and flowrates.
Case 1 - Low flowrate, high heating value
Case 2 - Low flowrate, low heating value
Case 3 - High flowrate, high heating value
Case 4 - High flowrate, low heating value
Case 5 - Average flowrate and heating value
Table 8-6 presents the capital costs, annualized costs, average cost
effectiveness, energy use, and vent stream characteristics for the five
cases selected. All vent stream characteristics used are from individual
distillation units in the screened NEP. The heating value and flowrate used
to represent the average case are typical of the average vent stream
characteristics defined in Chapter 3. It should be noted that vent streams
free of corrosive compounds are used so that incinerators, boilers, and
flares are applicable to each stream.
Table 8-6 shows that average cost effectiveness for each control system
varies depending on the vent stream characteristics applied. The most
favorable cost effectiveness values shown occur for vent streams with the
highest overall energy flow (i.e., Btu/hr) (Case 5, Case 3). For example,
the average cost effectiveness for Case 3 ranges from a cost savings of
116 dollars/ton of VOC destroyed for boilers to a cost of 15 dollars/ton for
incinerators. In general, the favorable cost effectiveness values shown for
high energy content vent streams are a result of the large mass of VOC
available for destruction and low supplemental fuel costs (high heat content
streams require little or no supplemental fuel). The cost savings for
boilers are a result of the fuel savings associated with the heat recovered
from the vent streams. Table 8-6 also shows the highest cost values occur
for vent streams with low energy flows (Case 1, Case 2). For Case 2,
average cost effectiveness ranges from 32,000 dollars/ton for existing
8-14
-------
TABLE 8-6. COST COMPARISONS FOR CONTROL OF INDIVIDUAL DISTILLATION
VENT STREAMS LISTED IN THE NEP
CD
cn
Item
Annual ized Cost (1978 $/yr)
Boiler
Flare
Incinerator
Existing Flare
Capital Cost (1978 $)
Boiler
Flare
Incinerator
Existing Flare
Average Cost Effectiveness ($/ton)
Boiler
Flare
Incinerator
Existing Flare
Supplemental Natural Gas
Required (scfh)
Boiler
Flare
Incinerator
Existing Flare
Vent Stream Characteristics
Flowrate (scfm)
Heating valve (Btu/scf)
VOC flbwrate (lb/hr)
Case 1
Low Flowrate
High Heat Value
16,800
21,400
128,100
10,300
21,300
37,300
250,800
6,300
339
431
2,584
208
0
80
1 ,340
0
1.2
3,643
15.0
Case 2
Low Flowrate
Low Heat Value
17 ,000
25,200
137,700
1,384
22,000
37,900
251,900
6,500
39,560
58,647
318,371
32 ,215
0
178
1,626
98
8.3
3.0
0.13
Case 3
High Flowrate
High Heat Value
'
(l,405,200)a
94,400
178,000
53,400
66,900
82,900
528,900
27,000 .
-(116)a
8
15
4
(44,018)b
80
368
0
560
1,258
3,668
Case 4
High Flowrate
Low Heat Value
.
33,200
306,000
156,800
285,800
68,800
85,200
348,900
28,000
82
753
386
703
0
6,756
1,189
6,676
637
19
123
Case 5
Average Flowrate
Average Heat Value
(18,200)a
24,900
112,100
12,400
23,100
39,000
253,900
6 ,900
(67)a
92
424
46
(l,100)b
80
821
0
26
494
82
Parenthesis indicate a net cost savings resulting from decreased requirements for natural gas to the boiler.
Parenthesis indicate natural gas savings.
-------
flares to 318,000 dollars/ton for incinerators. As discussed in the
following sections, application of controls to these low heat content
streams results in relatively high costs. In addition, a relatively small
amount of VOC are controlled because of the low VOC content and/or low
flowrates associated with these vent streams.
A comparison of capital costs is not discussed here because to do so
without including the cost impacts for energy consumption would be
misleading. For example, existing flares have the lowest capital costs for
all cases considered but have the lowest annualized costs for only two
cases. This is a direct result of the energy costs associated with the fuel
required for stable flare operation. Because of the effect of energy
consumption on annualized costs, comparison of control system costs are
presented on an annualized basis only.
Figure 8-1 illustrates the total annualized control costs for the five
cases selected. In general, the figure shows that existing flares have the
lowest annualiiied costs when applied to vent streams with low flowrates
(Cases 1 and 2) while boilers have the lowest annualized costs when applied
to vent streams with high flow rates (Cases 3 and 4). In addition,
incinerator systems have the.highest annualized control costs for all cases
except Case 4. This figure also shows that for vent streams with high
energy content (Case 3, Case 5), the use of boilers generates a cost savings
as a result of the energy recovery associated with combusting the vent
stream. In both cases, these cost savings are more than sufficient to
off-set the capital cost of the boiler modifications applied.
The following is a case-by-case comparison and discussion of the
annualized control system costs. Those cases that have similar cost trends
are grouped together.
Cases 1 and 2. Both cases are characterized by vent streams with low
flowrates. Figure 8-1 shows that for both cases existing flares have the
lowest annualized costs followed by boilers, new flares and incinerators.
The relatively low annualized cost for existing flares is attributed to the
low equipment costs associated with the use of an existing flare system. In
8-16
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00
r-.
to
-p
CO
o
o
N
to
3
300
S 200
100
KEY
Existing Flare - EXF
Hew Flare - NF
Boiler - BLR
Incinerator - INC
Energy Costs (Savings)
Average Case
(Case 5)
Sverage" Flowrate
Average Heating Value
IKC
BLR
EXF
Case 3
High Flowrate
High Heating Value
IHC
Case 1
.Low Flowrate
Case 2
High Heating Value
INC
Low Flowrate
Low Heating Value
INC
BLR
NF
EXF I
BLR
EXF
NF
Case 4
High Flowrate
Low Heating Value
NF
2 100
200
1405
Figure 8-1. Summary of annua11zed control system cost for the 5 individual vent
streams Cases selected.?
-------
addition, minimum flowrates of supplemental fuel are required as a result of
the low overall flowrates for these vent streams.
As shown in Figure 8-1, the incinerator system has the highest
annualized cost for Cases 1 and 2. These relatively high costs are
attributed to the high equipment costs and supplemental fuel consumption for
incinerators applied to low flowrate vent streams. For both of these low
flowrate cases, an oversized incinerator is applied (see Section 8.1.1.1 for
minimum incinerator size commercially available). Therefore, a large volume
of supplemental fuel and air are required to generate sufficient flue gas
for maintaining the design residence time of this oversized incinerator. As
shown in Table 8-6, the supplemental fuel required for incinerator operation
under Cases 1 and 2 ranges from 1340 to 1626 scfh. All other control
systems use under 200 scfh.
Case 3, Case 5. Both Case 3 and Case 5 represent vent streams with
high energy content. Therefore, little or no supplemental fuel is required
for combusting these vent streams using the control systems considered. The
use of boilers, which act to recover the vent stream heat content results in
significant energy cost savings. These cost savings, which act to off-set
the capital costs of boilers, are a result of the fuel savings associated
with the heat recovered from these vent streams. As shown in Figure 8-1,
the cost savings associated with using boilers range from 18,200 to
1,405,200 dollars.
For both cases, energy costs are low for existing flares, new flares
and incinerators. The incinerator systems have the highest capital cost and
they also have the highest annualized cost. Furthermore, existing flares
have the lowest capital cost and they also have the lowest annualized cost.
Annualized incinerator costs range from 112,000 to 178,000 dollars, while
annualized costs for existing flares range from 12,400 to 53,300 dollars.
The annualized costs for new flares lies between the costs for existing
flares and incinerators.
Case 4. The comparative costs for Case 4 differ from all others in
that new and existing flares have the highest annualized costs. For all
other cases considered, the use of an incinerator system results in the
8-18
-------
highest annualized cost. For Case 4, flares are more expensive than
incinerators because of the higher heating value assumed to be necessary for
flare operation as explained in the following discussion.
Figure 8-1 shows that the relatively high annualized cost of new and
existing flares is a direct result of the high energy cost component. A
high flowrate of supplemental fuel is required for flares because the vent
stream flowrate is high and its corresponding heating value is low.
Table 8-6 shows that over 6000 scfh of .supplemental natural gas is required
for flare systems while just over 1000 scfh is required for incinerator
operation. This difference in fuel requirements drives the annualized cost
of flares higher than incinerators, and is a result of the different
incinerator and flare heating values required. The flare cost equations add
•3
enough fuel to reach a minimum heating value of 5.7 MJ/nm (150 Btu/scf)
while the incinerator equations add enough fuel to maintain a heating value
of between 0.38 to 4.2 MJ/nm3 (10 to 110 Btu/scf).
Figure 8-1 shows that boilers have the lowest annualized cost as a
result of relatively low capital and energy costs. Although some supple-
mental fuel is required, there is no energy cost component shown in
Figure 8-1 because the cost credit associated with combusting this vent
stream acts to off-set the cost of the supplemental fuel required.
8.2 NATIONAL COST IMPACTS .
The screened national emission profile (NEP) was used to develop a
relationship between future national.percentage VOC emission reductions and
national VOC control costs due to a distillation NSPS. This relationship .
was developed as discussed below.
8.2.1 Determination of Cost Impacts
As described in greater detail in Chapter 6, an 81 percent VOC control
level from distillation units would exist if no NSPS were promulgated. The
available range of national VOC control for an NSPS is from requiring^no
additional units control to having all distillation units control their
emissions. Regulatory possibilities in this range are modeled by adding
controls to uncontrolled units in the screened NEP.
8-19
-------
In brief, the sequence is established by ranking individually all the
units in the NEP according to the total resources required for VOC control
(expressed in $/Mg of VOC controlled). Therefore, regulatory alternatives
consist of a set of $/Mg cutoff levels or TRE levels (as explained in
Chapter 6). For a given regulatory alternative there is an associated TRE
cutoff level; all units in the NEP ranked at or below the cutoff level must
be controlled (unless they are already controlled with combustion devices)
while those above the cutoff level are not controlled. To get the total
cost impact of a regulation alternative (i.e., TRE cutoff level), the costs
for all the affected units in the screened NEP are added. To get the
associated national VOC emission reductions, the reductions for each vent
21
stream are added assuming a 98 percent destruction efficiency.
An incinerator system is applied to all vent streams containing
corrosive VOC while new and existing flare systems are assumed to be applied
to all others. Existing flares are applied when the data in the screened
NEP indicates a flare exists at the plant while new flares are applied to
all cases where incinerators or existing flares are not applicable. Because
the cost associated with the use of boilers is relatively low, boilers are
assumed not to be applied to maintain a degree of conservatism in this
national cost impact analysis. Section 8.1 shows that boilers are the least
expensive control system for most applications and that use of boilers can
actually result in significant cost savings. For plants in the screened NEP
where more than one vent stream is controlled, it is assumed that each
stream is combined for treatment in a single control system.
The summing of costs for a regulatory alternatives results in total
costs for controlling the units in the screened NEP. To translate this
number to a projection of costs for all new distillation columns expected by
1987, a factor is applied which is simply the ratio of new units expected by
1987 to the number of units in the screened NEP. That factor is 6.15
(1200/195).
8.2.2 Results of the Cost Analysis
The results for the flare/incinerator cost analysis for the complete
range of regulatory possibilities are shown in Figure 8-2 for the fifth year
8-20
-------
20 ••
CO
r>
en
15 ••
•O
O)
fO
rci
C
O
10 ••
5 .-
0 --
80
Flare/Incinerator
85
90 95
National Percent VOC Reduction
Figure 8-2. National annualized cost of combustion control using
flare and incinerator costs as a function of the
associated national percent reduction in uncontrolled
VOC emissions from distillation operations - fifth year.
8-21
-------
of NSPS implementation. The national control costs due to an NSPS for
flares and incinerators range from zero dollars for an 81 percent emission
reduction (baseline level) to about $23.0 million dollars for a 98 percent
emission reduction. As shown in Figure 8-2, a steep slope is evident as the
curve approaches a 95 percent reduction level. This occurs because many
units with relatively high $/Mg values for controls are included in order to
achieve this level of national emissions reduction.
It should be emphasized that the cost curve shown in Figure 8-2 is
based on the application of flares and incinerators. If boilers and
incinerators were applied, Figure 8-2 would indicate significant national
cost credits as a result of the vent stream energy recovered through the use
21
of boilers.
8.2.3 Major Differences Between Cost Methodologies Used in The Regulatory
And Economic Analyses
Although the same equipment cost equations (presented in Section 8.1)
are used, the economic and regulatory analyses differ in control device
selection and vent stream specifications. The economic analysis assumes the
maximum number of distillation columns (13) in a process unit and the
application of an incinerator/scrubber complex which in most cases results
in the highest annualized control costs. The worst case vent stream
characteristics (those resulting in the highest cost) are assumed for
o
flowrate (52 m/min) and VOC concentration (no VOC content). Furthermore,
no heat value is attributed to the vent stream (so that supplemental fuel
requirements are maximized) and no recuperative heat recovery is assumed.
Application of the most expensive control device and selection of the worst
case vent stream characteristics adds a degree of conservatism to the cost
estimates. On the other hand in order to determine the cost impacts
associated with all applicable control devices, the regulatory analysis
considers the use of boilers, flares or incinerators depending on their
applicability to a particular vent stream. Furthermore, the vent stream
characteristics are taken directly from the data presented in the screened
NEP. This facilitates the analysis of a wide variety of cases and allows
the estimated national cost impacts to be based on vent stream characteris-
tics typically found in industry.
8-22
-------
The costs presented for both the regulatory analysis and the economic
screening analysis are in 1978 dollars. The costs for the economic
screening analysis, however, have been adjusted to 1987, i.e., they are
1987 costs given in 1978 dollars. This transformation to 1987 costs was
made using two factors. First, all costs, other than energy-related costs,
were escalated to 1987 using the historical inflation rate. Second, the
energy-related costs were escalated at a higher rate since these costs have
been rising facter than inflation in the recent past.
8.3 OTHER COST CONSIDERATIONS
8.3.1 Control Cost Accumulation for Synthetic Organic Chemical
Manufacturing Industries with Distillation Operations
8.3.1.1 Introduction. Since passage of the Clean Air Act Amendments
of 1977, EPA has initiated action on eight possible new source performance
and hazardous air pollutant standards that will affect the Synthetic Or-
ganic Chemical Manufacturing Industry (SOCMI). None has been promulgated.
The fifth-year annualized cost of these potential regulations, taken
together, and adjusted in the manner described below, sums to $31.1
million. Of this total, the potential NSPS for distillation comprises $9.6
million or 31 percent.
As the term is used here, the distillation industry consists of all
facilities and activities directly involved in the operation of distillation
columns used to produce any of 219 organic chemicals. The 219 chemicals
are defined by a minimum national production threshold of 45,400 Mg/yr (100
million Ib/yr) and account for approximately 92 percent by weight of total
domestic organic chemical production. The scope of distillation NSPS does
not include polymers, coal tar distillation products, chemicals extracted
from natural sources, or chemicals totally produced by biological synthesis.
The purpose of this control cost accumulation section is to examine
the incremental cost effect of NSPS for distillation for the SOCMI in the
context of seven other air emission regulations. In some cases, costs of
the potential standards for existing facilities are included in the accumu-
lation even though most existing facilities will not be affected by
8-23
-------
potential distillation NSPS in the first five years. Listed below are the
relevant potential regulations for cumulative costs with corresponding
Start Action Request (SAR) numbers:
- NESHAP: Benzene Emissions from Benzene Storage Tanks
SAR No. 1593.
- NESHAP: Benzene Fugitive Emissions
SAR No. 1126.
- NESHAP: Benzene Emissions from the Ethylbenzene/Styrene Industry
SAR No. 1128.
- NESHAP: Benzene Emissions from the Maleic Anhydride Industry
SAR No. 1127.
- NSPS: VOC Fugitive Emissions in Synthetic Organic Chemicals
Manufacturing Industry
SAR No. 1112.
- NSPS: VOC Emissions from Volatile Organic Liquid Storage Tanks
SAR No. 1612.
- NSPS: VOC Emissions from Air Oxidation Process Vents in the
Synthetic Organic Chemical Manufacturing Industry
SAR No. 1618.
- NSPS: VOC Emissions from Distillation Process Vents in the
Synthetic Organic Chemical Manufacturing Industry
SAR No. 1733.
the basic methodology employed to generate cumulative annualized
control costs is presented below:
1) All control costs are standardized to mid-1978 dollars.
2) All control costs are annualized using a real, before~tax
interest rate of 10 percent.
3) Only the EPA Administrator's recommended regulatory alternative
is considered when accumulating costs for existing (NESHAPs) and new,
modified, or reconstructed (NESHAPs and NSPSs) facilities. Where a regula-
tion is not in a late enough stage to have a regulatory alternative recom-
mended, then a best estimate of which regulatory alternative may be chosen
is made.
4) All control costs are incremental and do not include the cost of
pollution control equipment already in place.
8-24
-------
5) Costs are tabulated only for specific chemical groups that make
up the distillation industry and are thus directly affected by the poten-
tial NSPS for distillation. Twelve groups are defined that experience
control costs under the distillation standard: 1) General aromatics;
2) General non-aromatics; 3) Synthetic elastomers; 4) Plastics and fibers;
5) Plasticizers; 6) Pesticides; 7) Solvents; 8) Detergents and surfactants;
9) Fuel additives; 10) Aerosol propellents and refrigerants; 11) Coatings;
and 12) Miscellaneous end-use chemicals. Section 9.1.1.8 of the BID
categorizes the 219 organic chemicals by the above groups according to
whether the chemicals are intermediates used in the production of the
particular types of chemicals (groups 1-6), or are themselves members of
the types (groups 7-12). Two groups found in Section 9.1.1.8, Basic
chemicals and Dyes, have no control costs under NSPS for distillation and
thus are not included when accumulating incremental annualized costs.
Also, a few individual .chemicals within the 12 groups listed above experi-
ence no direct annualized control cost and are excluded when accumulating
costs.
6) For NESHAP regulations, control costs derived from model plants
are multiplied by the number of existing facilities affected for each
particular SOCMI standard.
7) Where future facilities are concerned (NESHAP and NSPS regula-
tions), the fifth year total annualized control costs for new, modified, or
reconstructed facilities are used for accumulation. The fifth year total
annualized control costs refer to the control costs expected to be incurred
by society in the fifth year following proposal of a standard in the
Federal Register.
The fifth year costs are calculated by multiplying annualized control
costs for one affected facility (in constant dollars) by the projected
number of- affected facilities to be built in the five years following
proposal of the specific standard. The fifth year will vary among poten-
tial regulations because the dates of proposal in the Federal Register vary
among potential regulations. The projected number of new facilities, af-
fected by NSPS for distillation to be built between November 1, 1982 and
8-25
-------
November 1, 1987 (see Table 9-23), is used to calculate fifth year control
costs for all eight of the potential NESHAP and NSPS regulations even
though the five year period used for distillation facility projections does
not correspond exactly to five year periods of other regulations.
8) When costs are accumulated, a few individual chemical industries
should be combined because of the existence of coproducts or by-products.
However, due to the intricate nature of coproduct and by-product relation-
ships within the SOCMI, the large number of chemicals affected, and the
time and effort required to define these relationships, coproducts and
by-products are treated as independent industries. Thus, some double
counting exists when projecting the number of new facilities and, as a
result, costs are somewhat overstated.
9) Table 8-7 lists costs for 12 chemical groups affected by the
potential NSPS for distillation. Two chemical groups identified in Chapter
9, basic chemicals and dyes, do not experience any NSPS costs. Chemicals
that are classified as basic chemicals are produced at refineries and have
no projected compliance costs, while no new, modified, or reconstructed
facilities are projected for dyes. Hence dyes do not experience any NSPS
costs.
10) The costs provided in Table 8-7 are only the direct costs of the
various SOCMI standards. At the end of this section rolled-through costs
are addressed. Rolled-through costs are costs that a producer may incur if
his supplier (of input chemicals) incurs costs due to standards and passes
these through. A more complete discussion of rolled-through costs can be
found in Section 9.2.
The data presented in Table 8-7 are not only based on the above gen-
eral methodology but more specific assumptions as well. These regulation-
specific assumptions are presented below.
8.3.1.2 Data and Assumptions for Accumulating Costs
8.3.1.2.1 Benzene storage NESHAP. Cost data are from the draft
Environmental Impact Statement (EIS) titled "Benzene Emissions from Benzene
Storage Tanks — Background Information for Proposed Standards," December
1980, (EPA-450/3-80-034a). Page numbers referencing costs are from this
EIS. Cost data in the EIS are in first quarter 1979 dollars.
8-26
-------
TABLE 8-7. ANNUALIZED CONTROL COSTS OF EIGHT AIR STANDARDS FOR TWELVE CHEMICAL GROUPS
FIFTH YEAR AFTER PROPOSAL*
12 Chemical Groups
United States 1978
(Mid-1978 Dollars)
00
i
ro
Chemical
group
(ft)
Benzene
storage
NESHAP
(B)
Benzene
fugitive
NESHAP
(C) (D)
Ethyl benzene/ Maleic
styrene anhydride
NESHAP NESHAP
(E)
VOC fugitive
emissions
NSPS
(D
Volatile organic
liquid storage
Tanks NSPS
(G)
Air oxidation
processes
NSPS
(H)
Distillation
columns
NSPS
Total
Intermediates for: .
GeneraT aromatics
241,500
General non-aromatics x
Synthetic elastomers
Plastics & fibers
Plasticizers
Pesticides
Solvents
Detergents and
surfactants
Fuel additives
Aerosol propellents &
refrigerants
Coatings
Miscellaneous end-use
chemicals
X
427,100
X
76,600
X
30,900
X
X
X
X
776,100
459,600
X
X
721,100
X
145,100
X
47,900
X
X
X
X
1,373,700
The fifth year varies among standards. See
Twelve of the 14 chemical groups presented
Note: 1
2
3
X
X
X
(321,400) 1,
X
X
X
X
X
X
X
X
(321,400) 1,
text.
in Chapter 9 are
Derivation of each regulation's annualized control
"X" denotes that these chemical industries are not
Totals differ slightly from the sum of figures due
X
»
X
X
885,000
X
X
X
X
X
X
X
X
885,000
listed.
331,000
1,497,000
245,400
956,800
356,000
98,100
650,200
773,200
86,200
110,500
171,700
392,800
5,668,300
Refer to text
68,700
310,600
50,900
198,500
73,900
20,300
134,900
160,400
17,900
22,900
35,600
81,500
1,176,000
165,000
737,000
407,000
6,941,000
2,750,000
X
X
X
X
X
X
X
11,000,000
326
2,246
489
1,219
422
316
1,363
1,872
124
.268
211
729
9,590
,400 1
,400 4
,600 1
,200 12
,400 3
,800
,200 2
,000 2
,800
,800
,200
,600 1
,400 31
,592,200
,791,000
,192,900
,027,300
,602,300
656,900
,148,300
,884,400
228,900
402,200
418,500
,203,900
,148,800
for further explanation.
cost is provided in the following pages.
covered by the particular standards.
to rounding.
-------
The benzene storage NESHAP would directly affect 11 specific chemicals
in 4 chemical groups that are benzene consumers and would be affected by
NSPS for distillation (see Table 8-8).
EPA recommends regulatory alternative IV for existing sources
(45 FR 83958) and regulatory alternative III for new sources (45 FR 83960).
Alternative IV for existing sources and alternative III for new sources
have the same requirements. Both alternatives require that each storage
tank have a contact internal floating roof tank with a liquid-mounted
primary seal and a continuous secondary seal.
The annualized cost to existing facilities affected by this standard
is $6,800 (p. 7-46) for alternative IV. There are 25 existing benzene
consumers in the general aromatics group, 52 in the plastics and fibers
group, 8 in the pesticides gr.oup, and 4 in the detergents and surfactants
group (see Table 8-8). Hence, the total annualized costs to existing
facilities in each of the four groups are $170,000, $353,600, $54,400, and
$27,700 respectively.
The annualized control cost for new benzene consuming facilities is
$5,700 per facility (p. 7-54) for alternative III. According to Table
8-8, 16'new facilities consuming benzene are projected for the general
aromatics group, 19 for the plastics and fibers group, 5 for the pesticides
group, and 1 for the detergents and surfactants group. Hence, annualized
benzene storage costs for future facilities are $91,200, $108,300, $28,500,
and $5,700, respectively.
An aggregation of annualized control costs for existing and new
sources computes to $261,200 for the general aromatics group, $461,900 for
the plastics and fibers group, $82,900 for the pesticides group, and
$33,400 for the detergents and surfactants group. The mid-1978 producer's
price index is 209.6 and the first quarter 1979 producer's price index is
226.7. In mid-1978 dollars, the total annualized costs of control are
therefore $241,500, $427,100, $76,600, and $30,900 for the general aroma-
tics, plastics and fibers, pesticides, and detergents and surfactants
groups, respectively.
8-28
-------
TABLE 8-8. NUMBER OF BENZENE-CONSUMING PLANTS PROJECTED TO BE
AFFECTED BY DISTILLATION NSPS, 1982-1987
United States
Projected
benzene-consuming
plants affected by
Chemical group9 Distillation NSPS11
General aromaticsc 16
Plastics and fibersd 19
Pesticides6 5
Detergents and surfactants 1
TOTAL 41
aThe list of 11 chemicals that use benzene as a raw material is taken
from pp. 9-17 through 9-24 of the Benzene Fugitive Emissions BID and
p. 7-10 of the Benzene Storage Tanks BID.
The methodology for projecting affected chemical plants to be built
between November 1982 and 1987 can be found in Section 9.1.2 of this
BID.
clncludes benzene suIfonic acid, monochlorobenzene, and (1-methylethyl)
benzene (commonly called cumene).
Includes benzenamine (commonly called aniline), cyclohexane, ethyl-
benzene/styrene, 2,5r-furandione (commonly called maleic anhydride),
and nitrobenzene.
elncludes l,l'-biphenyl.
Includes linear alky!benzene.
8-29
-------
8.3.1.2.2 Benzene fugitives NESHAP. Cost data are from the draft EIS
titled '"Benzene Fugitive Emissions-Background Information for Proposed
Standards," November 1980, (EPA-450/3-80-032a). Page numbers referencing
costs are from this EIS. Cost data in the EIS are in May 1979 dollars.
The benzene fugitive NESHAP would directly affect 11 specific chemi-
cals in 4 chemical groups that are benzene consumers and would be affected
by NSPS for distillation (see Table 8-8). These industries experience
fugitive benzene emissions.
EPA recommends regulatory alternative III for existing sources
(46 FR 1175). Regulatory alternative III requires the installation of
certain equipment and monthly monitoring for detection of leaks and is
expected to reduce benzene fugitive emissions by about 70 percent. Regula-
tory alternative IV includes more equipment in addition to that required by
regulatory alternative III and is expected to reduce benzene fugitive
emissions by about 80 percent. EPA recommends that Alternative IV be
imposed in the case of new sources (46 FR 1177). The annualized cost
to existing facilities affected by this standard is $8,700 per facility
when alternative III is imposed. This number is derived from the control
costs for three different model facilities. The annualized cost of control
for model facility A is $7,400, for model facility B, $9,700, and for model
facility C, $15,200, (p. 8-35). It is estimated that 62 percent of
existing refinery and SOCMI benzene-related production units would be
represented by model A, 31 percent by model B, and 7 percent by model C (p.
6-3). The $8,700 per facility annualized cost is an average control cost
for the three model facilities, weighted by the estimated current popula-
tion of each model facility. There are 25 existing benzene consumers in
the general aromatics group, 52 in the plastics and fibers group, 8 in the
pesticides group, and 4 in the detergents and surfactants group (see
Table 8-8 of this chapter). Hence, the total annualized costs to existing
facilities in each of the four groups are $217,500; $452,400; $69,600; and
$34,800, respectively.
The annualized control cost for new benzene consuming facilities is^
$18,200 per facility when alternative IV is imposed. This figure is based
on the same model facilities used for existing sources. The annualized
8-30
-------
cost of control for a new model facility A is $12,000, for new model
facility B is $25,700, and for new model facility C is $39,900 (p. 8-36).
Because it is expected that new facilities will follow the same distribu-
tion as the current population, the weighting procedure (i.e., model A-62
percent, model B-31 percent, model C-7 percent) is implemented to arrive at
the composite cost. According to Table 8-8, 16 new facilities consuming
benzene are projected for the general aromatics group, 19 for the plastics
and fibers group, 5 for the pesticides group, and 1 for the detergents and
surfactants group. Hence, annualized benzene fugitive costs for future
facilities are $291,200, $345,800, $91,000 and $18,200, respectively.
Aggregate annualized control costs for existing and new sources
compute to $508,700 for the general aromatics group, $798,200 for the
plastics and fibers group, $160,600 for the pesticides group, and $53,000
for the surfactants group. The mid-1978 producer's price index is 209.6
and the May 1979 producer's price index is 232.0. In mid-1978 dollars the
total annualized costs of control are $459,600, $721,100, $145,100, and
$47,900 for the general aromatics, plastics and fibers, pesticides, and
surfactants groups, respectively.
8.3.1.2.3 Ethyl benzene/sty rene NESHAP. Cost data are from the draft
EIS titled "Benzene Emissions from Ethylbenzene/Styrene Industry-Background
Information for Proposed Standards," August 1980, (EPA-450/3-79-035a).
Page numbers referencing costs are from this EIS. Cost data in the draft
EIS are in fourth quarter 1978 dollars.
The ethylbenzene/styrene NESHAP would affect two chemical industries
that fall under NSPS for distillation: ethyl benzene and styrene. The two
chemicals are usually produced in conjunction with each other and are part
of the plastics and fibers group.
EPA recommends regulatory alternative C for continuous emissions
(45 FR 83456) and regulatory alternative 1 (45 FR 83457) for excess emis-
sions. Alternative C requires that facilities achieve 99 percent benzene
emissions reduction in the main process vents by routing them to a boiler.
Alternative 1 requires the use of smokeless flares. Nine ethylbenzetieY
styrene facilities already have flares in place. With a present population
8-31
-------
of 13 ethylbenzene and styrene facilities, four facilities would be
required to install smokeless flares (45 FR 83456).
The annualized cost for the ethylbenzene/styrene industry to control
continuous emissions is a $460,000 credit (p. 7-41). The analysis assumed
that benzene is recovered in the condenser and scrubber system and is fed
back into the process via the benzene drying column. The value of the
benzene recovered is subtracted from the control cost. In this case the
value of the benzene recovered is greater than the control cost. The
annualized cost of controlling industry-wide excess emissions is $171,000
(45 FR 83456). Adding the $171,000 cost (excess emissions) to the $460,000
credit (continuous emissions) results in a $289,000 credit for all existing
ethylbenzene/styrene faci1ities.
The EIS did not project any new ethylbenzene/styrene facilities, so
that costs were not derived for new sources. It is assumed that new
sources producing ethylbenzene/styrene will experience a proportion of the
$289,000 annualized control credit. In Table 8-8, two ethylbenzene/styrene
facilities are projected to be constructed. The total annualized cost of
control for new ethylbenzene/styrene sources is a $44,500 credit (number of
new plants divided by the number of existing plants times $289,000).
Aggregate annualized control costs for existing and new sources
compute to a $333,500 credit for the ethylbenzene/styrene industry. The
mid-1978 producer's price index is 209.6 and the fourth quarter 1978
producer's price index is 217.5. In mid-1978 dollars the total annualized
cost of control for the plastics and fibers group is a $321,400 credit.
8.3.1.2.4 Maleic anhydride NESHAP. Cost data are from the draft EIS
titled "Benzene Emissions from the Maleic Anhydride Industry-Background
Information for Proposed Standards;" February 1980; (EPA-450/3-80-001a).
Page numbers referencing costs are from this EIS. Cost data in the EIS are
in second quarter 1979 dollars.
This regulation would affect only the maleic anhydride industry, which
is in the plastics and fibers group. EPA Recommends a 97 percent effi-
ciency control option for existing sources (42 FR 26660). This option is
based on the best demonstrated level of control that is now being achieved
8-32
-------
at an existing maleic anhydride plant and that is universally applicable to
any existing plant. For. the 97 percent regulatory option, the total annua-
lized control costs would be approximately $2,100,000 for the existing
maleic anhydride industry (p. 5-63). The mid-1978 producer's price index
is 209.6 and the second quarter 1979 producer's price index is 233.5. In
mid-1978 dollars the total annualized cost of control is $1,885,000 for the
plastics and fibers group. :
There are no control costs associated with new sources. Maleic
anhydride can be produced using either benzene or n-butane as a feedstock.
Because of the cost advantage associated with using the n-butane feedstock,
maleic anhydride manufacturers are likely to decide to use the.n-butane
process for new sources. Benzene emissions from new maleic anhydride
sources are thus likely to be zero.
8.3.1.2.5 VOC fugitive emissions NSPS. Cost data are from the draft
EIS titled "VOC Fugitive Emissions in Synthetic Organic Chemicals Manufac-
turing Industry - Background Information for Proposed Standards, November
1980, (EPA-450/3-80-033a). Page numbers referencing costs are from this
EIS. Cost data in the EIS are in fourth quarter 1978 dollars. The VOC
fugitive emissions NSPS would affect all SOCMI chemicals that are affected
by NSPS for distillation. .
EPA recommends regulatory alternative IV (46 FR 1136). Alternative IV
requires:
1) The monthly monitoring of all in-line valves and open-ended
valves in gas and light liquid service,
2) the installation of rupture disks upstream of gas service relief
valves that vent to the atmosphere,
3) the installation of closed vents and control devices for compres-
sor seal areas and/or degassing vents from compressor barrier fluid
reservoirs,
4) the installation of dual mechanical seals on pumps in light
liquid service and installation of closed vent control devices for degas-
sing vents from barrier fluid reservoirs of all pumps in light liquid
service,
8-33
-------
5) the installation of closed-loop sampling systems; and
6) the installation of caps, blinds, plugs, or second valves to seal
all open-ended lines.
The annualized cost of this standard is $13,500 per facility if alter-
native IV is used. This figure is derived from the control costs for three
different model facilities. The annualized cost of control for model
facility A is $7,900, for model facility B, $13,300, and for model facility
C, $33,000 (pp. 8-14 thru 8-16). The EIS estimates that 52 percent of
existing SOCMI plants are similar to model facility A, 33 percent are
similar to B, and 15 percent are similar to C (p. 6-2). It is assumed that
this distribution'will hold for the future SOCMI facility population. The
$13,400 per facility annualized cost is an average control for the three
model facilities, weighted by the estimated current SOCMI population of
each model facility.
To arrive at specific chemical group costs, the $13,400 per facility
annualized control cost is multiplied by the projected number of new
sources for each chemical group (refer to Table 9-23 for projections). All
costs are multiplied by 209.6/217.5, the ratio of the mid-1978 producer's
price index to the fourth quarter 1978 producer's price index, in order to
put all costs in mid-1978 dollars.
8.3.1.2.6 Volatile organic liquid storage tanks NSPS. Background
data are from the unpublished draft EIS titled "VOC Emissions from Volatile
Organic Liquid Storage Tanks-Background Information for Proposed Stan-
dards," June 1983, (EPA-450/3-81-003a). Control costs are in 1982 dollars.
Volatile organic liquid storage tanks NSPS would affect all SOCMI chemicals
that are produced using distillation.
It is assumed here that costs are incurred under regulatory alterna-
tive IV. This option would require that each storage vessel storing a VOL
with a true vapor pressure less than 76.6 kPa be equipped with a contact
internal floating roof with a liquid-mounted primary seal and a continuous
secondary seal. A vapor control system would be required for all storage
vessels storing a VOL with a true vapor pressure greater than or equal to
76.6 kPa. Small and low-pressure tanks are assumed to not need emissions
controls in this analysis.
8-34
-------
The total annualized cost of regulatory alternative IV for all of the
SOCMI in 1988 (the fifth year of the standards) is assumed to be $1,680,000.
In order to obtain specific chemical industry costs the $1,680,000 figure
is split equally among the 439 new and replacement plants projected for the
chemical groups listed in Table 8-7. (Refer to Table '9-23 for the
projections.) This yields a cost of $3,800 per source. To a small extent,
VOL storage costs are overstated in this cumulative cost analysis because
some of the $1,680,000 cost would be incurred by chemicals not covered by
Distillation NSPS.
To arrive at specific chemical group costs, the $3,800 cost is
multiplied by the projected number of new sources for each chemical group.
All costs are multiplied by 209.6/299.3, the ratio of the mid-1978
producer's price index to mid-1982 dollars, in order to put all costs in
mid-1978 dollars.
8.3.1.2.7 Air oxidation processes NSPS. Cost data are obtained from
the draft Environmental Impact Statement (EIS) titled Air Oxidation Proces-
ses in Synthetic Organic Chemical Manufacturing Industry-Background Infor-
mation for Proposed Standards," January 1982, (EPA-450/3-82-001a). Page
numbers referencing costs are from this EIS. Cost data in this document
are in mid-1978 dollars. Preliminary indications are that regulatory
alternative III will be the preferred course of action. This alternative
requires a 57 percent national VOC reduction from the baseline level based
on the use of a thermal oxidizer at those air oxidation facilities required
to meet a 98 percent VOC reduction requirement.
The national annualized cost is estimated to be $11,000,000 when
regulatory alternative III is. chosen (p..8-29). It is not possible to
determine which specific chemical types produced at future air oxidation
facilities would be required to control VOC emissions to achieve the
national emission reduction under regulatory alternative III. In order to
accumulate costs on an individual industry basis, it is assumed that the
$11,000,000 total annualized cost will be based on a specific chemical
industry's individual plant costs and projected number of new sources. The
EIS provides the projected number of new AO facilities (p. 9-47, Scenario I)
8-35
-------
and gives chemical process-specific costs (p. 8-44). For each industry the
projected number of new facilities is multiplied by each chemical industry's
specific cost. The products are summed to arrive at a total cost for all
industries. Next, the percentage of the total cost attributable to each
specific industry is calculated and the $11,000,000 national annualized cost
of control is distributed to each chemical specific industry based on these
percentages. Table 8-9 presents the calculations and results. To a small
extent, AO costs are overstated in this cumulative cost analysis because
some of the $11,000,000 cost would be incurred by chemicals not covered by
Distillation NSPS.
8.3.1.2.8 NSPS for distillation. Cost data are obtained from Chapter
8 of this document. These cost data are based on a mix of worst-case
assumptions and most-likely assumptions, and are in mid-1978 dollars. NSPS
for distillation would affect 219 SOCMI chemicals. The most-likely total
national annualized cost is $9.6 million, if a 98 percent VOC reduction is
sought.
The worst-case cost for each of the 219 chemicals affected by the
distillation NSPS is selected. The chemicals with worst-case costs (per
facility) are placed in their proper chemical group. Within each group the
worst-case costs per chemical facility are summed and then divided by the
number of chemicals in each group to determine the average worst-case cost
per facility for each chemical group (using a straight, unweighted average
among the chemicals in each group). In order to accumulate costs on a
chemical group basis, it is assumed that the $9.6 million estimated total
annualized cost will be shared based on the chemical group's average worst-
case cost per facility and the projected number of new sources. For each
chemical group the projected number of new facilities is multiplied by each
chemical group's average worst-case cost per facility. Next, the percent-
age of the total cost attributable to each specific chemical group is
calculated and the $9.6 million national annualized cost of control is
distributed to each chemical group based on these percentages. Table 8-10
presents the calculations and results.
8-36
-------
TABLE 8-9. FIFTH YEAR ANNUALIZED COSTS OF THE NSPS FOR AIR OXIDATION
PROCESSES, BY SPECIFIC INDUSTRY:
26 CHEMICAL INDUSTRIES
United States
1978
CO
CO
<*) (B)
Annual ized
chemical
Projected process-
number specific
. • of ftO costs
Chemical" facilities ($000)
Acetaldehyde
Acetic acid
Butyric acid
Formic acid
Methyl ethyl ketone
Propanoic acid
Acetone
Acetophenone
Cunene hydroperoxide
a -Methyl styrene
Phenol
Acrylic acid
Acroleln
Benzole acid
1,3-Butadiene
Ethylene dlchloride
Ethylene oxide
Formaldehyde
Hydrogen cyanide
1 soph thai 1c acid
Halelc anhydride
Phthaltc anhydride
Propylene oxide
Styrene
Terephthalic acid.
Dimethyl terephthalate
TOTAL
0
2
4
1
3
1
2
1
19
4
I
6
3
1
1
2.083
2,196C
240
-
1.661
122
895
-16
581
35"
20
. 1,658
590e
713f
4,816
2,213
(C)
Total
projected
cost per
Industry:
AxB
($000)
0
4.392
960
1.661
366
895
-32
581
665
80
1.6S8
3.540
2,139
4.816
2.213
23.934
(D)
Share of
all In-
dustry's
cost: .AxBi
sunaary of
column (C)
0.000
0.184
0.040
0.069
0.015
0.037
0.000
0.024
0.028
0.003
0.069
0.148
0.089
0.202
0.092
1.000
(E) (F)
Alternative III
costs per in-
dustry: Column D
multiplied by
$11,000,000 Chemical group
0
2.024.000
440,000
759,000
165.000
407,000
0
264.000
308,000
33.000
759,000
1,628.000
979,000
2.222,000
1.012.000
11,000,000
General non-aronatics
Plastics and fibers
General non-arcMHtics
Plastics and fibers
General aronatics
Synthetic elastomers
Solvents
General non-aromatic;
Plastics and fibers
General non-aronatics
Plasticizers
Plasticizers and
fibers
Plasticizers
Plasticizers and
fibers
Plasticlzers
(G)
Chemical's scientific name
Acetaldehyde
Acetic acid
2-Propanone
2-Propeno1c acid
Benzole acid
1,3-Butadiene
1,2-Dichloroethane
Oxirane
Formaldehyde
Hydrocyanic acid
1,3-Benzenedlcarboxyllc ac1
-------
TABLE 8-10. FIFTH YEAR ANNUALIZED COSTS OF THE DISTILLATION NSPS
BY SPECIFIC CHEMICAL GROUPS
14 Chemical Groups
United States
1978
(A)
Projected
number of
Chemical group facilities
Basic Chemicals
Intermediates for:
General aromatics
General non-
aromatics
Synthetic elastomers
Plastics and fibers
Plasticizers
Pesticides
Dyes
Solvents
Detergents and
surfactants
Fuel additives
Aerosol propel! ants
and refrigerants
Coatings
Miscellaneous end-
use chemicals
Total
166
21
113
17
73
24
8
0
50
72
5
11
14
31
(B)
Average
group
control
cost
a ($)
0
255,255
324,919
, 473,727
273,198
289,681
650,000
695,650
447,662
425,395
406,425
403,517
248,975
384,517
(C)
Total
projected
cost per group:
(AxB) ($1000)
0
5,360.4
36,715.8
8,053.4
19,943.5
6,952.3
5,200.0
0
22,383.1
30,628.4
• 2,032.1
4,438.7
3,485.6
11,920.0
1.57,113.4
(D)
Share of
total cost
AxB '
sum of
column C
.000
.034
.234
.051
.127
.044
.033
.000
.142
.195
.013
.028
.022
.076
1.000
(E)
Costs per
group:
column D
multiplied by
$9,600,000
0 '
326,400
2,456,000
489,600
1,219,200
422,400
316,800
• 0
1,363,200
1,872,000
96,000
268,800
211,200
729,600
9,590,400
aSee Section 9.1.3 and Table 9-23 of this
Using a straight average among chemicals
presented in Appendix I. .
8-38
BID.
in each group.
Data for each chemical are
-------
8.3.1.3 Rolled-through costs. A chemical producer not only experi-
ences the direct costs of control but also may incur costs indirectly as a
result of increases in the price of regulated chemicals used as inputs.
These costs are referred to as rolled-through costs because they may be
"rolled" through the production chain, affecting intermediate chemicals and
eventually end-products using the regulated chemical.
The analysis here assumes that all facilities — existing as well as
new -- are subject to the standards, and that producers of intermediates
will roll through the entire cost of control to other SOCMI producers.
Table 8-11 provides total annualized costs of control that producers in each
chemical group may experience when rolled-through costs are added to direct
costs. These figures allow for rolled-through costs of all eight air
standards by scaling up the total direct costs for all standards by the
ratio of rolled-through costs to direct costs determined in the screening
program for distillation NSPS. The implications of the figures in Table
8-11 are that some producers in each group may experience costs higher than
their own direct costs because of rolled-through costs from their suppliers,
(as if the average group cost had been greater). Total industry costs in
aggregate will not exceed the $31.1 million shown in Table 8-7, however.
8-39
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TABLE 8-11. TOTAL FIFTH YEAR ANNUALIZED COST OF
CONTROL ACCUMULATED FOR EIGHT POTENTIAL AIR REGULATIONS
12 Chemical Groups
United States
1978
(mid-1978 dollars)
Rolled-through
costs as a percent
Chemical group of direct costs
Intermediates for:
General aromatics
General non-aromatics
Synthetic elastomers
Plastics & fibers
Plasticizers
Pesticides
Solvents
Detergents and surfactants
Fuel additives
Aerosol propel 1 ants &
refrigerants
Coatings
Miscellaneous end-use
chemicals
36.1
100.7
385.0
81.0
139.3
62.2
123.6
6.9
58.9
72.4
317.5
4.1
Total rolled-through and
direct costs for eight
potential air regulations
$2,068,900
9,542,100
5,635,700
21,737,900
8,488,000
T, 07 5, 400
4,791,700
3,285,600
251,500
835,100
1,790,200
1,264,200
^Rolled-through and direct costs are shown in Appendix I. Both sets of
costs are generated for the distillation standards. The direct costs and
rolled-through costs for individual chemicals are aggregated within each
chemical group. The percentage cost increase when rolled-through costs
are added to direct costs is calculated and total costs for all standards
as given in Table 8-7 are increased by this percentage.
8-4C
-------
8.4 REFERENCES
1. Moore, D., Cost Comparison for Combustion Control Equipment.
Memorandum to Distillation NSPS file. December 16, 1982.
2. Dawecki, T., Distillation Pipeline Costing Model Documentation.
Memorandum to Distillation NSPS file. November 13, 1981.
3. Sarasua, A., Flare Cost Program (FLACOS) Documentation. Memorandum to
Polymers and Resins NSPS file. February 2, 1982.
4. Basdekis, H.S., Emissions Control Options for the Synthetic Organic
Chemicals Manufacturing Industry, Control .Device Evaluation. Thermal
Oxidation Supplement. November 1980, p. III-1 to 111-17.
5. Desai, T., Memorandum to Distillation file.
6. Devitt, T., et al. The Population of Industrial and Commercial
Boilers. PEDCo Environmental, Inc., May 1979, p. 33.
7. Senyk, D., Capital Cost Analysis for Using Industrial Boilers to
Control VOC. Memorandum to Distillation NSPS file. June 29, 1982.
8. Reference 3.
9. Perry, R.H., Chemical Engineers Handbook. 1973, p. 5-32.
10. Reference 4, pg. V5 to V14.
11. Chemical Engineering, Volume 87, No.l. January 14, 1980, p. 7.
12. Chemical Engineering, Volume 86, No.l. January 1, 1979, p. 7.
13. Galloway, J., Meeting at the Mutual Building, July 16, 1980 on Retrofit
Costs for Thermal Incineration. Memorandum to the Air Oxidation NSPS
file. August 8, 1980.
14. Reference 4, pg. V4. • .
15. Kalcevic, V., Emissions Control Options for the Synthetic Organic
Chemical Manufacturing Industry. Control Device Evaluation. Flares
and the Use of Emissions as Fuels. August 1980. p. IV-2.
16. Richardson Engineering Services, Inc. The Richardson Rapid System,
Process Plant Construction Cost Estimating Standards. Volume 4. 1981.
pg. 15-42.
17. Reference 2.
8-41
-------
18. Desai, T., Cost Parameters for Distillation NSPS Cost Impact
Determination. Memorandum to Distillation NSPS file. March 16, 1982.
19. Chemical Engineering, Volume 87, No. 22. November 3, 1980.
20. Memorandum from Galloway, J., Energy and Environmental Analysis Inc.,
to Hurley, E., Energy and Environmental Analysis Inc. Air Oxidation
NSPS. Discussion of the Average Capacity Utilization Factor Used in
the Chemical Affordability Screening and Regulatory Analyses
Computations. January 13, 1981.
21. Memorandum from Stelling, J., Radian Corporation, to Beck, D., EPA:CPB,
and Bell, D., EPA:SDB. Distillation Operations Regulatory Analysis
Using 98 Percent Flares. 20 p. August 26, 1982.
0-42
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9. ECONOMIC ANALYSIS
This chapter considers the potential impacts of the control costs of
NSPS for distillation on the chemical industry, chemical prices, produc-
tion, employments foreign trade, and small businesses. In particular, 219
chemicals that would be directly affected by the standards are examined.
The economic analysis consists of several sections. First, the chemi-
cal industry is described in terms of products, producers, employment,
finances, prices, and international trade (Section 9.1.1). Subsequently,
each chemical affected is described with respect to its plants, producers,
capacity, production, price, and chemical group (Section 9.1.2). The base
year for most statistics in this chapter is 1978, reflecting the base year
used in the BID for NSPS on SOCMI air oxidation processes. The description
of the industry includes a projection of the number of affected plants in
each chemical group over the first five years of the standards (Section
9.1.3); the projection also is used as the basis for the aggregate cost
estimates presented in Chapter 8.
A screening analysis is the central element in the economic impact
analysis. The screening analysis and its worst-case cost assumptions are
discussed in Section 9.2. A screening approach is used because over 200
chemicals would be affected and there is a need to distinguish chemicals
with negligible costs from any with potentially large costs. As explained
later in this chapter, even with worst-case cost assumptions, no chemical
would have a price increase of 5 percent or more in 1987.
Most-likely estimates of aggregate control costs are used in Section
9.3 to describe the general impacts of the standards. Impacts on average
prices, production, employment, and trade are discussed. Aggregate costs,
small business impacts, and cumulative costs of eight different air pollu-
tion standards affecting chemicals are summarized in Section 9.4.
9-1
-------
References are presented in Section 9.5. Two appendices present addi-
tional data for the economic analysis. Appendix H lists chemical producers
and their plants. Appendix I presents plant operating and cost assump-
tions used in the screening, as well as screening results for each of the
219 chemicals.
9.1 INDUSTRY STRUCTURE
Distillation is used extensively in the manufacture of organic chemi-
cals. NSPS for distillation would affect 219 chemicals directly, and
numerous other chemical derivatives and products. Characteristics of the
chemical industry are described below.
9.1.1 The Organic Chemical Industry
9.1.1.1 Industry Definition. Over 7,000 organic chemicals are pro-
duced each year. A small percentage of these chemicals account for the
majority of the industry's production. NSPS for distillation would affect
219 chemicals that were produced in quantities greater than 45.4 Gg in 1979
(refer to Chapter 3). These chemicals account for approximately 92 percent
of total organic chemical industry production by weight. Chemical names
used in Chapter 9 reflect the terminology used by the Chemical Abstracts
o
Service ,of the American Chemical Society.
Economic data used in this chapter generally refer to the United
States customs territory (including the 50 states, the District of Colum-
bia, and Puerto Rico). Production quantities and prices generally reflect
4
purities of 95 to 100 percent. Some exceptions exist, such as formalde-
hyde (for which production and prices are quoted in terms of the 37 percent
grade common in commercial applications). Such exceptions are noted in the
tables presenting chemical-specific production and price data.
9.1.1.2 Products. Chemicals are used extensively throughout the
economy. They act as substitutes for natural materials, facilitate
production through their versatile processing qualities, and allow
production of products with special qualities and performance features.
The magnitude of organic chemical production is extremely large. In
1979, an estimated 180,000 Gg of organic chemicals were produced in the
U.S. This included 60,000 Gg of basic chemicals, 50,000 Gg of intermediate
chemicals and solvents, and 70,000 Gg of finished chemicals. Approximately
55 percent of the raw materials for organic chemicals came from petroleum
9-2
-------
refining, 40 percent from natural gas and related gas liquids, and 5
5
percent from coal.
9.1.1.3 Producers. There are approximately 230 producers of the 219
chemicals covered by the standards. Many of these companies produce a
variety of chemicals and operate several plants. Appendix H lists the
organic chemical industry producers, their plant locations, and the rele-
vant chemicals they produce, for the base year 1978.
Production of chemicals is relatively concentrated, with a small
number of firms accounting for a large part of industry sales. It is
estimated that 23 percent of total industry sales are attributable to the
fi
top four companies and 40 percent to the top ten. However, concentra-
tion varies among specific groups within the organic chemical industry.
For example, aerosol propellent and refrigerant chemicals each have fewer
than six producers, with a single producer often accounting for a large
percentage of total production, while each basic chemical has more than ten
producers, with no single producer responsible for a high percentage of
production.
Vertical integration, i.e., expansion into other steps within the
chemical manufacturing process, is common among chemical firms. Thus, many
firms find it profitable to expand into the chemical industry both forward
from industries such as petroleum production and agriculture, and backward
from chemical-using industries such as Pharmaceuticals and paint goods.
Expansion of chemical companies into non-chemical areas is not uncommon
either. For instance, DuPont, Dow Chemical, American Cyanamid, and Rohm
and Haas all have entered the non-prescription drug industry. Table 9-1
details the 50 largest U.S. chemical producers and the percentage of their
8
sales attributable to chemical products. The average firm in this group
receives less than half of its total sales from chemicals.
9.1.1.4 Industry Employment. Employment at plants producing the 219
regulated chemicals can be estimated on the basis of statistics for major
classifications of organic chemical manufacturing. The U*S. Bureau of the
Census classifies most organic chemicals in SICs 2865 (Cyclic Crudes and
Intermediates) and 2869 (Industrial Organic Chemicals Not Elsewhere Clas-
sified). Since the 219 organic chemicals account for approximately 92
9
percent of total organic chemical production, it can be inferred that
9-3
-------
TABLE 9-1. CHEMICAL SALES AS A PERCENTAGE OF TOTAL
SALES AT THE 50 LARGEST U.S. CHEMICAL PRODUCERS
1980
Rank
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
Chemical ,-sales
Company ($10b)
DuPont
Dow Chemical
Exxon
Union Carbide
Monsanto
Celanese
Shell Oil
W,R. Grace
Gulf 011
Occidental Petroleum
Allied Corp.
Standard 011 (Indiana)
Hercules
Atlantic Richfield
American Cyanamid
Phillips Petroleum
Eastman Kodak
Stauffer Chemical
Rohm & Haas
Tenneco
Mobil
Borden
Ethyl
U.S. Steel
Ttxaco
Diamond Shamrock
Air Products
CF Industires
FHC
Williams
Standard Oil of California
C1ba-Ge1gy
Ashland Oil
Mobay Chemical
Union Oil of California
B.F. Goodrich b
International Minerals
PPG Industries
BASF Wyandotte
Lubrizol
American Hoechst
01 1n
Conoco
Reichhold Chemicals
National Distillers
Farmland Industries0
Dow Coming
Georgia-Pacific
Borg-Warner
Hal co Chemical
10,250
7,217
6,936
5,650
5,453
3,200
3,089
2,733a
2,569a
2,458a
2,450
2,235
2,095
1,945
l,861a
1,858
1,837
1,643
1,608
1,565
1,558
1.548*
l,517a
1,437
1,346
1,307
1,262
l,233a
1.215,
l,171a
1,155
1,115
1,100
1,069
1,048
1,022
974
964
917
902
896
883
875
807
744
734
681
661a
631
617
Total sales
($106)
13,652
10,626
103,143
9,994
6,574
3,348
19,830
6,101
26,483
12,476
5,519
26,133
2,485
23,744
3,454
13,377
9,734
1,695
1,725
13,226
59,510
4,596
1,741
12,492
51,196
3,143
1,421
1,233
3,482
2,073
40,479
1,690
8,118
1,069
9,984
3,080
1,790
3,158
917
902
1,290
1,853
18,301
885
2,055
4,745
681
5,016
2,673
617
Chemical sales
as a percentage Industry
of total sales classification
75
68
7
57
83
96
16
45 •
10
20
44
9
84
8
54
14
19
97
93
12
3
34
87
12
3
42
89
100
35
57
3
66
14
100
10
33
54
31
100
100
69
48
5
91
36
15
100
13
24
100
Basic chemicals
Basic chemicals
Petroleum
Basic chemicals
Basic chemicals
Basic chemicals
Petroleum
Specialty chemicals
Petroleum
Petrol eum
Basic chemicals
Petroleum
Basic chemicals
Petroleum
Basic chemicals
Petroleum
Photographic equipment
Basic chemicals
Basic chemicals
Petroleum
Petroleum
Dairy products
Basic chemicals
Steel
Petroleum
Basic chemicals
Basic chemicals
Agricultural chemicals
Farm and construction machinery
Agricultural chemicals
Petroleum
Specialty chemicals
Petroleum
Basic chemicals
Petroleum
Rubber products
Agricultural chemicals
Glass products
Basic chemicals
Specialty chemicals
Basic chemicals
Basic chemicals
Petroleum
Basic chemicals
•Alcoholic beverages
Agricultural supplies
Specialty chemicals
Lumber and wood products
Automobile equipment
Specialty chemicals
Chemical sales include significant amounts of final products, such as fabricated plastics, coatings, adheslves,
minerals, and the like.
For the year ended June 30, 1980.
cFor the year ended August 31, 1980.
SOURCE: Reference 8.
9-4
-------
they account for approximately the same share of total employment in
organic chemical manufacturing, as reported by the Census. In 1981,
employment among production and office workers in SICs 2865 and 2869 was
150,000. Accordingly, employment at plants producing the 219 chemicals
was approximately 140,000 in 1981.
Due to the large-scale operations present in the chemical industry,
most employees work in plants that employ 250 or more persons. For
example, in 1977 over 64 percent of the employees in SIC 2869 and 57
percent in SIC 2865 worked in plants with 250 or more employees.
9.1.1.5 Industry Finances. Profitability and capital structure are
the two major financial considerations for the chemical industry. Profita-
bility helps to measure financial returns for investors within the indus-
try. The industry's capital structure determines how it raises funds, to
finance its needs and growth. Also, the capital structure influences the
amount and stability of industry earnings.
Profitability in the chemical industry has fluctuated during the last
decade as illustrated by two measures: profit margin and return on stock-
holders' equity. Profit margin is after-tax earnings as a percentage of
sales and represents the ability of an industry to produce goods and
services at a profit. Sales are measured generally as "net sales," meaning
gross sales less discounts to customers, and are measured as revenues
before expenses or taxes. Return on stockholders' equity is after-tax
earnings as a percentage of stockholders' equity. Figure 9-1 shows the
12 13
annual profit margins " and Figure 9-2 the return on stockholders'
equity for the chemical industry from 1970 through 1980. »
Between 1971 and the end of 1974, both ratios increased steadily, and
then declined from the end of 1974 through 1976. In 1976, return on
stockholders' equity began to increase while the profit margin did not
start increasing until 1977. Both measures of profitability continued to
increase throughout 1978 and 1979, but did not approach the high rates they
achieved in 1974. In 1980, the profit margin and return on stockholders'
equity fell once again."
The chemical industry has high fixed costs because of the large
capital costs of plants. Fixed costs do not depend on the rate of
production in any given period. When plants are not operating at full
9-5
-------
RETURN OM SALES
Percent
8-
7 -L»-
6-
5-
1 m_
I I f I I I 1 I
1970 1971 1972 1973 1974 1975 1976 1977 1978
I
1979
1980
Figure 9-1. U.S. Chemical industry Annual Profit Margin, 1970-1980.
AFTER-TAX EARNINGS AS A PERCENTAGE OF NET SALES a
Net sales equal gross sales less discounts to customers. Sales are measured before expenses and taxes.
SOURCES: References 12 and 13.
-------
RETURN ON STOCKHOLDERS' EQUITY
Percent
20
16 H
14 J
12 -4
10 H
o-j—
i i 1 -i ~r i r i i
1970 1971 1972 1973 1974 1975 1976 1977 1978 1979 1980
Figure 9-2. U.S. Chemical Industry Annual Return on Stockholders' Equity
AFTER-TAX EARNINGS AS A PERCENTAGE OF STOCKHOLDERS' EQUITY
SOURCES: References 14 and 15.
-------
capacity, high fixed costs are spread over low production volumes resulting
in a low profit margin and Tow: returh on stockholders1 equity for"the" industry.
The industry experienced capacity utilization rates below 80 percent from
1975 through 1977 and since 1980, while its capacity utilization rates were
above 80 percent from 1971 through 1974 and 1978 through 1979.16 The
trend in capacity utilization correlates with the increasing profit margins
in the earlier years and decreasing profit margins in recent years.
Operating costs also influence profitability in the industry. The
chemical industry's major operating costs are for energy and raw material
feedstocks, both of which are related to the prices of oil and gas. Con-
suming approximately 3,518 trillion kJ in 1978, the chemical industry is
one of the largest energy consumers in the industrial sector. Most
organic chemicals are derived from oil or gas. Increasing oil and gas
prices have led to higher operating costs for the industry.
Within the industry, however, there are some industry segments that
are more profitable than others. Manufacturers of specialty chemicals
generally have had the highest profitability rates among large chemical
manufacturers. Chemical and Engineering News ranked the 40 largest (in
terms of sales) U.S. chemical companies on the basis of various profita-
bility ratios. The ranking showed that the top five companies in overall
profitability in 1980 were Freeport-McMoran, Lawter International,
18
Lubrizol, Texas Gulf, and Nalco Chemical. All of these companies,
except Texas Gulf, are specialty chemical firms. Producers of specialty
chemicals compete more on product qualities and consumer services than on
price. As a result, specialty chemical producers can pass increased costs
to the users of their products.
Most of the 219 chemicals covered by NSPS for distillation are high-
volume commodity chemicals, a characteristic that arises from the fact that
each is produced in quantities of 45 Gg or more nationally. Commodity
chemicals are sold in a more price-competitive environment because buyers
can shop more easily among different producers and receive similar
products. However, even though specialty chemicals earn higher margins,
high-volume chemicals represent the bulk of total chemical sales, and
chemical industry average profit measures are probably quite representative
of profitability for the 219 chemicals.
9-8
-------
Funds for investment are obtained from both internal sources (retained
earnings and depreciation) and external sources (debt and stock issues).
Table 9-2 provides specific information on sources of funds for a sample of
19
firms. Because the industry has large capital investments already in
place which generate depreciation allowances, 32 percent of the funds for
the sample group of chemical companies came from depreciation in 1980.
Funds generated internally do not always meet expanding capital require-
ments for replacement plants, though. (In part, the increased capital
requirements reflect the need for plants of a much larger scale in order to
utilize the latest, more efficient technologies.) Therefore, issues of
long-term debt also have been a major source of funds. In 1980, 17 percent
of cash flow was generated through issues of long-term debt. When net
income is low, investments must be funded to a greater extent through debt
financing.
The ability of the industry to raise capital for long-term investment
is sound, though marginally not as strong as it was in the past. The debt
ratio (long-term debt as a percentage of long-term debt plus equity) has
experienced only moderate changes during the past five years. ,In 1981, the
debt ratio for the chemical industry was 29.3 percent, compared to 27.6
percent for chemicals five years earlier (see Table 9-3) and a debt ratio
20
for all manufacturing firms of 26.0 percent in 1981.
The main use of funds in the chemical industry is for capital expen-
ditures in plant and equipment. Over 50 percent of its funds were used for
capital expenditures during the 1969-1975 period; however, this percentage
has been decreasing. Other funds are applied equally to dividends, reduc-
21
tion of long-term debt, and additions to working capital.
9.1.1.6 Prices.. A watershed year for prices in the organic chemical
industry was 1973. Before 1973, the industry was characterized by steady
price decreases for most of its products. Rapid growth in the industry
promoted extensive process research and plant investment, which resulted in
more efficient and economical production processes. Since 1973, though,
prices in the industry have soared, mainly due to increased oil and gas
prices and feedstock shortages. Chemical prices are influenced by the
relationship between production capacity and demand. When facilities are
highly utilized, producers generally are better able to implement price
9-9
-------
to
I
TABLE 9-2. COMBINED CASH FLOW AT 15 MAJOR U.S. CHEMICAL PRODUCERS
1977-1981
Item
SOURCE OF FUNDS
Net Income
Depreciation and depletion
Deferred taxes
Other internal sources
Long-term debt
Stock
TOTAL
APPLICATION OF FUNDS
Dividends
Capital expenditures
Additions to working capital
Reductions to long-term debt
Other applications
TOTAL
1981a
$ million15
4,360
4,270
1,010
1,830
7,490
4,930
23,890
1,850
8,340
3,760
1,490
8,450
23,890
% of
total
18.2
17.9
4.2
7.7 •
31.4
20.6
100.0
7.7
34.9
15.7
6.3
35.4
100.0
1980
$ million15
3,980
3,820
680
820
2,080 '
630
12,000
1,600
7,030
1,060
1,120
1,200
12,000
% of
total
33.2
31.8
5.7
6.8
17.3
5.2
100.0
13.4
58.5
8.8
9.3
10.0
100.0
1979
$ million15
3,800
3,600
430
1,090
1,210
320
10,450
1,470
5,630
1,080
1,040
1,230
10,450
% of
total
36.3
34.4
4.1
10.5
11.6
3.1
100.0
14.1
53.9
10.3
10.0
11.7
100.0
1978
$ million15
3,090
3,200
350
930
1,540
80
9,190
1,320
5,080
860
880
1,050
9,190
% of
total
33.6
34.8
3.8
10.1
16.8
0.9
100.0
14.3
55.3
9.4
9.5
11.5
100.0
1977
$ million15
2,750
2,830
360
1,210
1,610
230
9,000
1,180
5,490
520
750
1,060
9,000
% of
total
30.6
31.5
4.0
13.5
17.9
2.5
100.0
13.1
61.0
5.8
8.3
11.8
100.0
aFigures for 1981 reflect several large corporate acquisitions financed via stock and debt issues.
Nominal dollars.
SOURCE: Reference 19.
-------
TABLE 9-3. DEBT RATIO3 AT CHEMICAL COMPANIES AND ALL
MANUFACTURING COMPANIES
1971-1981
(Percent) .
Company group
Chemicals and
allied products
All manufacturing
1981
29.3
26.0
1980
26.3
25.2
1979
27.0
24.7
1978
27.9
24.5
1977
27.8
24.6
1976
27.6
24.4
1975
26.9
25.0
1974
23.8
24.2
1973
22.6
23.5
1972
24.2
25.1
1971
24.6
25.4
Debt ratio is defined as long-term debt as a percentage of long-term debt plus
stockholders' equity.
SOURCE: Reference 20.
-------
increases. VJhen a large share of plant capacity is idle, producers fre-.
quently must offer discounts or reduce prices to maintain their plant uti-
lization levels, with the consequence being that cost increases are more
difficult to recover through price increases.
Supply conditions affect chemical prices. If a feedstock for a chemi-
cal is in short supply or is used for other priorities, the selling price
of the chemical is apt to rise. This was the case throughout the organic
chemical industry during the Arab oil embargo that began in October 1973.
Alternatively, if a large amount of new capacity comes on line for a
product, the product's price is apt to decrease.
Demand for organic chemicals is determined mostly by the demand for
the end products that use the chemicals as materials in their production.
For example, 1,3-butadiene is used to produce styrene-butadiene-rubber-
(SBR), which is used to produce tires, primarily for automobiles. There-
fore, the demand for automobiles influences the demand for 1,3-butadiene.
Since chemicals consumption is spread throughout the economy, cyclical
macroeconomic trends affect chemical demand and prices.
Low capacity utilization rates for an industry indicate that fixed
costs are spread over fewer units of production. Effective costs per unit
of production therefore are higher. Capacity utilization is expressed as a
ratio of actual production over nameplate production capacity. A facility
is said to be operating at optimal capacity when capacity utilization, in
22
the long run, is 85 to 95 percent of nameplate production capacity.
Beyond this level a strain is put on plant equipment. Excess production
capacity, or low capacity utilization, often characterizes the chemical
industry. In 1978, capacity utilization averaged 83 percent, while in
23
1981, capacity utilization fell to 70 percent.
When the demand for chemicals is low for long periods, some producers '
"mothball" plants either temporarily or indefinitely. Official statistics
on nameplate production capacity generally exclude capacity at plants that
are felt to be closed permanently. However, capacity at plants that are
closed only temporarily is included in nameplate capacity statistics.
Therefore, a plant that is still operating during a recession is probably
operating at a rate equal to, or greater than, the average utilization rate
that is obtained by dividing production into nameplate capacity (since some
9-12
-------
of the nameplate capacity at other plants may actually be out of service at
24
the time). In the base year statistics used in this analysis, however,
there probably are few "mothballed" plants because capacity utilization in
1978 (the base year) was not indicative of a general recession that would
have led to many plants being idled. Accordingly, the base year statistics
can be viewed as representative statistics on the nameplate capacity for
operable plants in that year.
Chemical journals and periodicals usually use list prices when
reporting the cost of a chemical. The list price is used as a focal point
around which other chemical prices are formed. Chemical producers typical-
ly base their list prices on a full-cost or cost-plus method. The full -
cost pricing method involves adding a desired profit margin to estimated
unit costs. Cost-plus pricing uses a percentage return on equity instead
of a profit margin on sales when calculating product price. However, a
lower unit profit is set if demand is thought generally to be elastic.
Because of the use of full-cost or cost-plus pricing, list prices of
organic chemicals are related to the cost of feedstocks. Chemical prices
generally are tied to the cost of oil or natural gas. A rise in the cost
of natural gas, for example, could cause a corresponding rise in the price
of natural gas-based chemicals. Figure 9-3 shows this relationship by
comparing a composite price index of five oil-based chemicals (benz'ene,
oxirane, 4-methyi-2-pentanone, propylene glycol, and cyclohexanone) with an
25
index of crude oil prices from 1968 through 1978.
The market price is determined by supply and demand at a particular
time. Given the fact that supply and demand conditions change frequently,
producers offer discounts or add surcharges to list prices at times to keep
their prices at market levels. When prices in this analysis are quoted
from published sources, they represent list prices at major marketplaces
(such as New York). When prices are derived as averages of the annual
value of shipments divided by the annual volume of production, they repre-
sent actual unit.prices (albeit averaged across a 12-month period) for all
quantities sold in the U.S. Transportation costs to particular user loca-
tions are components in the price of chemicals to individual users, and can
be added onto prices used here in figuring costs to users. Ordering quan-
tities also affect prices; the price for a single drum of a given chemical
may be considerably higher, per kg, than for drums ordered in lots of 50 or
9-13
-------
PRICE INDEX
5.0
4.0
3.0
2.0
1.0
0.0
Composite index of prices of five oil-based chemicals
. (benzene, oxirane, 4-methyl-2-pentanone, propyiene
glycol, and cyclohexanone); 1973=1.0
i Index of crude oil prices; 1973=1.0
I I T
1968
1970
1972
1974
1976 1978
CALENDAR YEAR
Figure 9-3. Composite Index of Five Oil-Based Organic Chemicals and Index of Crude Oil Prices
1968 THROUGH 1978
9-14
-------
for tank car lots. Quantities reflected in chemical price quotations used
in Chapter 9 range from shipments of one drum to large orders under long-
term contracts. .
9.1.1.7 Foreign Trade. Chemicals have been a positive factor in U.S.
trade with other countries. While the U.S. has generally had an annual
deficit of $24 billion to $29 billion each year in its overall trade of
products since 1977, the U.S. has exported more chemicals than it has
imported. In 1981, the U.S. exported $21.2 billion of chemicals and
imported only $9.4 billion of chemicals (see Table 9-4). Organic chemicals
(and products such as plastics and resins) account for over half of the
nf n*j
surplus in U.S. chemicals trade. 5 Imports and exports for selected
28 29
chemicals are shown in Table 9-5. *
The substantial surplus of U.S. chemical exports over imports is the
result, in large part, of a cost advantage that U.S. producers have had,
over producers in Europe, Japan, and other countries. When the oil-
exporting countries raised prices for their oil exports, a large differen-
tial developed between the world oil price and the price of oil and gas in
the U.S. Oil and gas prices in the U.S. have increased at a slower rate
because of federal controls.
30
In 1981, however, prices for domestic oil were decontrolled.
Prices for natural gas are in the process of being decontrolled in phases.
31
By 1985, most natural gas will have been decontrolled. U.S. chemical
producers, particularly new plants, will use higher-priced oil and gas for
raw materials and, therefore, will have production cost structures that
will resemble those of European producers to a greater degree than in the
past. European producers generally use naphtha from oil as their primary
raw material for production of their basic chemicals.
As raw material costs increase for domestic producers, U.S. chemicals
will become less competitive in world markets. Moreover, several countries
are constructing large-scale chemical plants to use natural gas for manu-
facturing chemicals, much of which will be for sale on the world market.
Saudi Arabia, Canada, and Mexico, among others, are building plants with
32
the prospect that they will displace U.S. exports in many regions.
Several factors will allow U.S. chemical producers to retain at least
some of their trade advantages. First, decontrol of gas is a slow, phase-
in process and will not lead to total decontrol of all gas, even in the
9-15
-------
TABLE 9-4. U.S. BALANCE OF TRADE IN CHEMICALS AND
ALL PRODUCTS
1975-1981
Year
1975
1976
1977
1978
1979
1980
1981
Chemicals
($ billion9)
5.0
5.1
5.4
6.1
9.8
12.1
11.7
All products
($ billion3).
10.2
-5.9
-26.5
-28.5
-24.7
-24.2
-27.3
aNominal dollars.
SOURCES: References 26 and 27.
9-16
-------
TABLE 9-5. SELECTED CHEMICAL IMPORTS AND EXPORTS:
LEVELS AND PERCENTAGFS OF U.S. PRODUCTION
1978
Chemical
Acetaldehyde
Acetic acid
Acetic acid, anhydride
Acetic acid, ethenyl ester
Acetic acid, ethyl ester
2-Aminoethano1
Benzene
1,3-Benzenedicarboxylic acid
1,2-BenzenedicarboxyKc add, bis (2-ethylhexyl) ester
1,2-Benzenedicarboxylic acid, diisodecyl ester
1,4-Benzenedicarboxylic acid, dimethyl ester
2,2-Bis (hydroxymethyl)-l,3-propanediol
1,3-Butadiene
Butanal
1-Butanol ••'•-.
2-Butanone
Carbon disulfide
Chloroethane
Chloroethene
Chloromethane
Cyclohexane
1,2-Ethanediol
Ethanol .
Ethenyl benzene
2-Ethoxyethanol
Ethyl benzene
Formaldehyde
2,5-Furandione
D-Glucitol
1,6-Hexanediamine
Hexanedioic acid
2-Hydroxy-lj2,3-propanetricarboxy1ic acid
1,3-Isobenzofurandione
Methanol
2-Methoxyethanol
2-Methyl-l,3-butadiene
(1-Methyl ethyl) benzene
Methyloxirane
4-Methyl -2-pentahone
2 -Methyl -2-propeno1c acid, methyl ester
Naphthalene
Oxirane
Phenol
1,2-Propanediol
1,2,3-Propanetriol
Exports
(Gg)
NA
7.7
.1.9
164.7
28.7
36.9
151.2
2.0
0.7
0.3.
90.4
' 5.8
42.5
18.1
17.1
15.5
NA
12.8
407.7
3.8
161.8
56.8
16.1
357.3
6.6
85.9
10.4
1.3
13.9
2.9
3.3
9.1
NA
111.3
5.1
4.3
39.7
34.1
6.4
31.4
4.0
34.6
103.9
15.4
18.8
Exports as a
percentage
of U.S.
production
NA
0.6
0.3
21.5
21.1
61.5
3.2
4.4
.0.4
0.4
4.9
10.5
2.7
5.1
5.0
5.2
NA
5.2
13.0
1.8
15.3
3.2
2.8
11.0
3.6
2.3
0.4
0.8
14.9
1.0 .
0.4
7.9
NA
3.8
9.8
3.0
2.6
3.7
6.0
8.6
5.6
1.5
8.5
6.2
30.8
Imports
(Gg)
Neg
25.6
11.2
10.8
2.9
NA
102.1
Neg
NA
NA
Neg
NA
282.0
Neg
9.8
, 24.7
2.9
Neg
NA
27.7
4.5
50.1
65.8
14.0
15.7
NA
1.1
1.0
NA
1.7
2.1
2.5
18.3
218.8
0.2
1.0
256.8
15.9
2.5
1.6
Neg
0.4
0.1
• 2.1
3.6
Imports as a
percentage
of U.S.
production
Neg
2.0
1.9
1.4
2.1
NA
2.1
Neg
NA
NA
Neg
NA
-17.7
Neg
2.9
8.2
1.3
. Neg
NA
13.4
0.4
2 ."8
11.4
0.4
8.7
NA .
Neg
0.6
NA
0.6
0.3
2.2
4.1
7.5
0.4
0.7
16.8
1.7
2.4
0.4
Neg'
Neg
Neg
0.8
5.9
9-17
-------
TABLE 9-5 (Continued). SELECTED CHEMICAL IMPORTS AND
EXPORTS: LEVELS AND PERCENTAGES OF U.S. PRODUCTION
1978
Chemical
Exports
(Gg)
Exports as a
percentage
of U.S.
production
Imports
(Gg)
Imports as a
percentage
of U.S.
production
Propanoic acid
1-Propanol
2-Propanol
2-Propanone
1-Propene
2-propenenitr1le
2-Propeno1c acid, ethyl ester
Tetrachloroethene
Tetrachlororoethane
Tetracthylpi urabane
1,1,1-Trichloroethane
5.1
12.7
68.8
54.6
11.5
134.8
21.0
29.0
16.4
NA
18.0
5.6
17.4
8.8
4.8
0.2
17.0
15.4
8.8
3.7
NA
6.2
3.7
Neg
14.7
0.6
148.1
1.5
Neg
16.7
4.0
Neg
NA
4.1
Neg
1.9
0.1
2.5
0.2
Neg
5.1
0.9
Meg
NA
HA » information not available
Neg * negligible
SOURCES: References 28 and 29.
9-18
-------
33
mid-1980s. Second, gas-based plants in other countries are subject to
delays or changes in their countries' pricing policies for gas; Canada, for
example, has changed its gas pricing policy and this will affect some
34
Canadian chemical plants. Third, the U.S. chemical industry has effi-
cient inter-plant distribution networks, better technology in some cases,
and economies of scale. Fourth, many U.S. chemical plants are being con-
structed with raw material flexibility — the ability to select the raw
35
materials that have the lowest price at any particular time. In contrast,
European producers and many others must use naphtha regardless of naphtha's
price or availability. On the other hand, a number of European chemical
plants will use gas from the North Sea, a factor that will favor their
competitiveness against U.S. plants.
Overall, U.S. chemical producers will lose a large element of the
export strength that they have had in recent years because of the under-
lying reduction in their advantage in raw materials costs. This trend was
foreseeable at the time the growth projections (used in Section 9.1.2) were
made and are factored to a degree into the projections. However, it is
uncertain how strong the residual advantages of U.S. chemical producers
will be in the 1980s and 1990s, and at some point the lost advantages will
lead to a slower pace of plant construction in the U.S.
The U.S. is protected from organic chemicals imports due to high
tariffs. This is true especially with regard to the benzenoid imports
category, which contains many of the organic chemicals. The benzenoid
group includes any chemical whose molecular structure has one or more
six-membered carbocyclic or heterocyclic rings with conjugated double bonds
(e.g., benzene or pyridine rings). Until recently, tariff valuation for
some benzenoid chemicals was extremely protective under the American Sel-
ling Price (ASP) system. The ASP customs valuation system in some cases
led to a tariff representing approximately 20 percent or more of the sel-
ling price of imports, making it difficult for foreign producers to sell to
the U.S. at a profit.
Recent multilateral trade negotiations scrapped the ASP system and
replaced it with a new set of tariffs that became effective July 1, 1980.
However, many benzenoid chemicals do not have large reductions under the
37 ~
new tariff system. These benzenoid chemicals represented a $226 million
portion of the $688 million in dutiable benzenoid imports during 1976. A
9-19
-------
substantial tariff reduction was implemented for non-benzenoid chemicals
and diminished high tariffs by a greater percentage than low tariffs. The
average U.S. duty rate for such chemical imports will be approximately 7 to
38
7.5 percent when the new rates are fully phased in (1987). Tariff
rates for all chemicals have now been set on the basis of "transaction
39
value," which is the foreign invoice price plus shipping insurance.
Even though tariffs have been decreased in some instances by the
recent trade pact, organic chemicals still are highly protected. This is
true especially for benzenoid products. However, U.S. producers face
occasional problems in competing with government-subsidized non-U.S.
producers or exporting to regulated non-U.S. markets. These problems,
though, should not prevent the continuation of a balance of trade surplus
through the next five years, given the continued favorable treatment of
many benzenoid products in the new tariff system, the relatively small
decrease in most tariff rates, and the continued cost advantages many U.S.
chemical producers will have over European competitors.
9.1.1.8 Chemical Groups. The 219 chemicals can be categorized into
14 chemical groups based on their major functions or end uses. The chemi-
cal groups are listed below and are illustrated in Figure 9-4.
1. Basic chemicals
2. Intermediates used in the production of:
(I) General aromatics; general nonaromatics
(II) Synthetic elastomers
(III) Plastics and fibers
(IV) Plasticizers
(V) Pesticides
(VI) Dyes
3. Solvents
4. Detergents and surfactants
5. Fuel additives
6. Aerosol propel!ants and refrigerants
7. Coatings
8. Miscellaneous end-use chemicals.
Intermediates are classified "general" if one of the following state-
ments is true:
t Their main use represents less than 40 percent of total use.
t No data were found to indicate shares among the end uses for that
particular chemical.
9-20
-------
Basic Chemicals (13)
GENERAL AROMATICS ==> 11*
Inter-
mediate
Chemicals [
L
GENERAL NON-AROMATICS => 56
SYNTHETIC ELASTOMERS => 11
= PLASTICS and FIBERS =£> 45
===== PESTICIDES => 4
L
iPLASTICIZERS ==> 16
DYES ==> 2
SOLVENTS 22
DETERGENTS and SURFACTANTS ***!> 19
^^»™«~^ FUEL ADDITiVES =NI> 5
AEROSOL PROPELLANTS and REFRIGERANTS ==s|> 4
^Mi,,^ COATINGS ==£> 4
MISCELLANEOUS END-USE CHEMICALS «=$> 7
Figure 9-4. Processing fSow for 219 organic chemicals.
* Numbers indicate the number of chemicals in each group of the 219 chemicals directly affected by NSPS for distillation.
9-21
-------
In each group, specific information on products is presented including
capacity, production, capacity utilization, and price. Data presented in
this manner highlight factors and trends within the chemical groups that
may be important in the determination of economic impacts. It must be
noted, however, that production shown for chemicals within each group
represents total production of each chemical for all uses, not only the
main use of that group.
9.1.1.8.1 Basic chemicals. The economics of a large number of
intermediate and end-use chemicals are influenced by the building block
chemicals of the industry, the primary or basic chemicals. Table 9-6 shows
the basics and their level of production, annual nameplate capacity, and
40 41 42
market price in 1978. ' ' Basics are derived from crude oil or
natural gas.
Because the chemical industry involves a considerable number of con-
version steps between chemicals in the chain of production from raw
materials to finished chemical products, terminology is difficult to define
precisely for some chemical groups. As the term is used here, chemicals
produced directly from oil or gas for production of other chemicals are
termed "basic" chemicals. (In common language, many basic chemicals may be
referred to as "feedstocks." There is an overlap between the term "basic"
chemicals and common usage of the term "feedstocks," the latter term also
having very specific connotations in the refining industry.) The under-
lying denominator of "basic" chemicals is that they are important building
blocks for the production of many derivative chemicals and are produced
directly by refineries.
Crude oil is used as the raw material for approximately 55 percent of
basics. Aromatics, such as benzene, methyl benzene (toluene), and di-
methyl benzene (xylene), are the major basics derived from crude oil. About
25 percent of basic chemicals used by the organic chemical industry are
44
aromatics. Not only are these three chemicals used in great quantities,
but they are used in all segments of the organic chemical industry. The
competing demand for aromatics as gasoline components therefore has been a
serious concern for the industry.
A large portion of aromatics production is used in gasoline to provide
high octane ratings. The nation's demand pattern for gasoline determines
9-22
-------
TABLE 9-6. U.S. PLANTS, PRODUCERS, CAPACITY, PRODUCTION, CAPACITY UTILIZATION, AND PRICE
Basic Chemicals
1978
ro
00
Chemical
Benzene
Butane
1-Butene
.2-Butene
Dimethyl benzenes (mixed)
Ethene
Methyl benzene
2 -Methyl butane
2 -Methyl propane
Naphthalene
Pentane
Propane
1-Propene
Number
of
plants
54
21a
8
3a
37
37
47
2
20a
12
3
35a
67
Number
of
producers
34
14
6
2
30
26
32
2
13
6
3
23
37
Capacity
(Gg)
7,115
l,125b
517
l,406b
4,398
14,973
5,477
54b
657b
338
54b
4,622b
7,977
Production
(Gg)
4,765
934
429b
1,167
2,909
11,773
3,421
45C
545
71
45C
3,836
5,903
Capacity
utilization
(*)
67
83b
83b
83b
66
79
62
83b
83b
21
83b
83b
74
1978
price
($/Kg)
0.22
0.11
0.41
0.27
0.16
0.28
0.17
.0.14
0.14
0.34
0.14
0.12
0.21
Estimated on the basis of the group average plant-to-producer ratio of 1.5.
Estimated on the basis of the 1978 chemical industry average capacity utilization rate of 83.0 percent.
cEstimated on the assumption that the minimum chemical production level is 45.4 Gg.
SOURCES: References 40,. 41, and 42. ;
-------
the use of aromatics in this market. Due to downsizing of automobiles and
fuel conservation, U.S. gasoline consumption is expected to decline during
the 1980s. The effect of decreased gasoline consumption on the aromatics
market will be offset by unleaded gasoline's replacing most leaded gasoline
by 1990, and unleaded gasoline has a particularly high demand for aro-
matics. Therefore, the gasoline market will continue to determine the
availability and price of the aromatics used by the organic chemical
45
industry.
Natural gas, including natural gas liquids separated from natural gas,
supplies over 40 percent of the raw material for basic chemicals. Par-
affins, such as ethane, propane, and n-butane, are single bond compounds
found in natural gas liquids. Cracking or dehydrogenating the single bond
compounds yields other petrochemical building blocks including the olefins,
the most important of which is ethene (ethylene). Ethene's major deriva-
tives are polyethenes, oxirane, chloroethene, ethyl benzene, vinyl chloride,
ethylene glycol, and styrene, which are used for producing fabricated •
47
plastics, antifreeze, fibers, and solvents. The demand for ethene,
therefore, is related to the demand for these products. Another major
basic chemical that is related closely to ethene is 1-propene (propylene).
Essentially, 1-propene is produced as a co-product of ethene. When ethene
demand falls and it is produced in lesser quantities, the production of 1-
propene also decreases. Approximately 25 percent of 1-propene production
is used to make polypropene, 25 percent for 2-propenenitrile, 15 percent
for 2-propanol, and 10 percent for methyloxirane. Therefore, the major
48
downstream use of 1-propene is fabricated plastics manufacturing.
Ethene and 1-propene can be made from either natural gas or crude oil. Due
to the scheduled decontrol of most gas by 1985, industry analysts antici-
pate a shift from natural gas liquids to crude oil among sources of olefins.
Basic chemicals are produced both by oil companies (including their
chemical subsidiaries) and by the major chemical companies. Because aroma-
tics are products of petroleum refining, petroleum companies are the major
producers. Although the major chemical companies also produce aromatics,
their strength is in the production of olefins and other chemicals. Chemi-
cal companies use most of their basic chemical production captively for
9-24
-------
chemical production, but also provide feedstock supplies to smaller, less
diversified firms. There will be some changes in the future, however, as
chemical companies concentrate on downstream products and petroleum
companies increase their dominance in the feedstock industry.
As mentioned above, the chemical industry's stronghold among basic
chemicals is olefins. The industry, however, built its strength on the
cracking of natural gas liquids. The economic disadvantages of this method
49
after 1985 will cause a shift away from this production process. In
anticipation of this shift, olefins plants are being built with feedstock
flexibility for using alternative raw materials. As a result, industry
analysts speculate that in the future chemical companies will enter the
50
olefins business only in partnership with oil companies. Although the
future of basic chemicals is determined mainly by the availability and
price of crude oil and natural gas, coal should not be overlooked as a
raw material. Current use of coal as a raw material is limited, but
research is concentrating on increasing coal's use for a number of
chemicals. ' •'
9.1.1.8.2 Intermediates. Intermediates are used in the production of
other chemical products and are considered stepping stones between basic
chemicals and final chemicals or products. Two characteristics of inter-
mediate chemicals are important. First, many producers of intermediates
captively consume their intermediate products. Because of captive con-
sumption, production figures for some intermediates may understate actual
production. Furthermore, some high volume intermediates always are con-
sumed captively by their producers. For these products, it is difficult to
assess the reliability of production data, if available, and there are no
markets from which prices can be determined. Second, demand for inter-
mediates depends upon the demand for their derivatives. Intermediate
chemicals are grouped according to the characteristics of their principal
end products. Therefore, the groups help indicate the major factors that
influence demand for the intermediates. A discussion of several groups of
intermediates follows.
(I) General aromatics and general nonaromatics. Tables 9-7 and 9-8
show data on chemicals classified as general aromatics and general non-
9-25
-------
TABLE 9-7. U.S. PLANTS, PRODUCERS, CAPACITY, PRODUCTION, CAPACITY UTILIZATION, AND PRICE
Intermediates: General Aromatics
1978
ro
Chemical
Benzenesulfonic acid
Benzoic acid, technical
Chlorobenzene, mono-
(Chloromethyl) benzene
Dibutanized aromatic concentrate
Di ethyl benzene
(1-Methyl ethyl) benzene
l-Methyl-2-pyrrolidinone
Phenol
Propyl benzene
1 ,2 ,3 ,4-Tetrahydrobenzene
Number
of
plants
5
5
6
5
4d
2
14
3
18
3
2
Number
of
producers
5
4
6
4
4
2
13
2
16
3
2
Capacity
(Gg)
54a
116
279
84
54a
54a
1,991
54a
1,566
54a
l,257a
Production
(Gg)
45a
45b
134
50
45b
45b
1,533
45b
- 1,217
45b
1,043
Capacity
utilization
(X)
83a
39b
48
60
83a
83a
77
83a
78
83a
83a
1978
price
($/Kg)
0.72
0.53
0.49
0.73
0.14
1.10
0.24
1.59
0.35
NAC
.NAC
Estimated on the basis of the 1978 chemical industry average capacity utilization rate of 83 percent.
Estimated on the assumption that the minimum chemical production level is 45.4 Gg.
cPrice is not available. Chemical is analyzed under a threshold price approach based on the cost of input
chemicals.
Estimated on the basis of the group average plant-to-producer ratio of 1.1.
SOURCES: References 51, 52, and 53.
-------
TABLE 9-8. U.S. PLANTS, PRODUCERS, CAPACITY,
PRODUCTION, CAPACITY UTILIZATION, AND PRICE
Intermediates: General Nonaromatics
1978
Number
of
Chemical plants
Acet aldehyde
Acetic acid, magnesium salt
Alcohols, C-ll or lower, mixtures
Alcohols, C-12 or higher, mixtures
1,4-Butanediol
Butanes, mixed
Butanoic acid, anhydride
1-Butanol
2-Butanol
2-Butenal
2-Butyne-l,4-diol
Carbamic add, monoammonlum salt
Carbonic di chloride
Chloroethane
Chloromethane
(Chloromethyl) oxirane
2-Chl oro-1-propanol
3-Chloro-l-propene
Cyclohexane, oxidized
Cyclohexanol
Cyclohexanone
Cyclohexanone oxime
1,2-Di bromoethane
1-Dodecene
2,2'-[l,2-Ethanediy1 bis (oxy)]
bisetnanol
Ethenone
2-Ethyl hexana!
(2-Ethylhexyl) amine
Ethyl methyl benzene
D-Glucitol (70% by weight)
Heptenes (mixed)
Hexadecyl chloride
Hexane
Hydrocyanic acid
4-Hydroxy-4-methyl -2-pentanone
lodomethane
Methanamine
5
4a
7a
7a
4
ld
1
9
4
2
2
ld
17
7
11
3
2
5
8
9
8
4
4
10
14
ld
1
5 '
ld
5
3
1
7
12
4
4
5
Number
of
producers
4
3
5
5
3
ld
1
8
3
2
1
ld
15
6
9
2
2
,3
7
7
7
4
4
8
10
ld
1
4
ld
5
3
1
6
8
3
4
4
Capacity
(69)
668
54b
199b
199b
138
54b
54b
542
279
54b
54b
54b '
814
386
281
213
l,277b
157b
1,139
569
570
54b
125b
196b
68
54b
54b
54b
54b
130
54b
54b
240b
212b
148b
54b
148
Production
(Gg)
540
45C
' 165
165
127
45C
45C
343
189
45C
45C
45C
588
245
206
157
1,060
130
899
511
527
45C
104
163
54
45C
45C
45C
45°
93
45C
45C
199
176
123
45C
104
Capacity
utilization
81
83b
83b
83b
92
83b
83b
63
68
83b .
83b
83b
72
63
73
74
83b
83b
79
90
92
83b
83b
83b .
79
83b
83b
83b
83b
72
83b
83b
83b
83b
83b
83b
70
1978
price
(S/Kg)
0.42
2.89
. 0.73
0.64
0.97
0.15
NAe
0.37
0.51
NAe
2.05
NAe
0.55
0.33
0.31
1.06
NAe
0.63
0.78
0.82
0.73
NAe
0.77
0.27
0.68
0.96
NAe
2.10
NAe
0.70
0.22
2.46
0.21
0.73
0.64
NAe
0.74
9-27
-------
TABLE 9-8 (Continued). U.S. PLANTS, PRODUCERS, CAPACITY,
PRODUCTION, CAPACITY UTILIZATION, AND PRICE
Intermediates: General Nonaromatics
1978
Number
of
Chemical plants
Kethanol
2-Kethyl-2-butene
2-Methylbutenes, mixed
M«thylmethanam1ne
Methyloxlrane
2-Methylpentane
2-Hethylpropanal
2-Methyl-2-propeno1c acid, methyl
estar
1-Nonene
Oxlrane
Pentenes, mixed
Propanal
Propanolc add
2-Propanol
2-Propanone
Sodium cyanide
Tetrabromoffle thane
Tetrachl oromethane
2,6,6-Tr1methylb1cyclo[3.l.l]-
hept-2-ene
12
1
3a
5
7
1
7
7
5
16
ld
3
4
5
20
2
2
11
10
Number
of
producers
10
1
2
4
5
1
5
3
5
12
ld
2
4
4
IS
2
2
7
7
Capacity
(6g)
4,074
54b
54b
54b
1,374
54b
88
.499
236b
2,699
54b
54b
110
1,127
1,284
54b
547b
695
55b
Production
(Gg)
2,923
4SC
45C
45C
929
45C
73b
367
196
2,273
45C
45C
91b
785
1,143
45C
454
334
46
Capacity
utilization
(*)
72
83b
83b
83b
68
83b
83b
74
83b
84
83b
83b
83b
70
89
83b
83b
48
83b
1978
price
(S/Kg)
0.13
0.29
0.29,
O.SO
0.53
NAe
0.51
0.93
0.24
0.51
0.29
0.57
0.37
0.26
0.30
0.88
NAe
0.24
0.57
aEstimated on the basis of a group average plant-to-producer ratio of L.3.
Estimated on the basis of the 1978 chemical Industry average capacity utilization rate of 83.0 percent.
cEst1mated on the assumption that the minimum chemical production level 1s 45.4 Gg.
No data. Production 1s assumed to occur at 1 plant and 1 producer.
*PHce 1s not available. Chemical 1s analyzed under a threshold price approach based on the cost of input
chemicals.
SOURCES: References 51, 52, and 53.
9-28
-------
51 52 53
aromatics, respectively. ' ' Chemicals in these groups do not have
major single uses that account for most of their demand.
(II) Synthetic elastomers. The chemicals listed in Table 9-9 are
intermediates in the production of synthetic elastomers.' ' Demand
for end uses of synthetic elastomers will determine, therefore, the demand
for these products.
In 1979, synthetic elastomers were used for the following products:
tires and tubes, 64 percent; industrial and automotive molded goods, 15
percent; and other products, 21 percent. Smaller cars manufactured in
Detroit, technological advances in tire production that increase tire
durability, and the overall high cost of motor vehicle operation are
dampening demand for tires and, therefore, synthetic elastomers and their
intermediates.
Producers of synthetic elastomers and their intermediates include
tire, chemical, and petroleum companies. Some major producers that are
primarily chemical companies include DuPont and Copolymer Rubber and
Chemical Company.
(Ill) Plastics and fibers. The chemicals listed in Table 9-10 are
intermediates in the production of plastics and fibers. '' The fiber
industry is related to the plastics industry in that many plastics and
fibers share common resins.
The plastics industry has grown rapidly because plastics have proper-
ties that make them suitable for many different end uses. Plastics differ
from one another in their functional properties — flexibility, solubility,
resistance to heat and sun, behavior under stress, and clarity. Plastics
also differ in price. Polystyrene, for example, is inexpensive compared to
fluorocarbon plastics. Finally, plastics differ in terms of processability
because of factors such as moldability and extrudability. As a result,
each kind of plastic has defined end uses, although in many cases there are
uses in which other plastics and materials are competitive substitutes.
Synthetic organic fibers are derived from organic materials. One
major class of synthetics is the cellulosic class, which includes rayon and
acetates. Cellulosics are said to be semi-synthetics because their produc-
tion process uses regenerated cellulose obtained from high-purity wood pulp
9-29
-------
TABLE 9-9. U.S. PLANTS, PRODUCERS, CAPACITY, PRODUCTION, CAPACITY UTILIZATION, AND PRICE
Intermediates: Synthetic Elastomers
1978
vo
1
CO
0
Chemical
Butadiene and butene fractions
1,3-Butadiene
2-Chloro-l,3-biitadiene
1 ,4-Di chl oro-2-butene
3 ,4-Di chl oro-1-butene
1,6-Hexanediamine
1,6-Hexanediamine adipate
1 ,6-Hexanedi ni tri 1 e
2-Methyl -1 ,3-butadiene
Propanenitrile
2-Propenenitrile
Number
of
plants
10a
20
3a
2
1
5
3
6
8
ld
6
Number
of
producers
7
15
2
2
1
3
2
2
7
ld
4
Capacity
(eg)
264b
2,212
217b
619b
443b
506
499b
335
209
54b
973
Production
(Gg)
219
1,594
180
514
368
278
414
278
142
45e
795
Capacity
utilization
(X)
83b
72
83b
83b
83b
55
83b
83b
68
83b
82
1978
price
($/Kg)
0.43
0.43
1.55
NAC
NAC
0.59
1.16
NAC
0.34
NAC
0.51
Estimated on the basis of the group average plant-to-producer ratio of 1.4.
Estimated on the basis of the 1978 chemical industry average capacity utilization rate of 83.0 percent.
cPrice is not available. Chemical is analyzed under a threshold price approach based on the cost of input
chemicals.
No data. Production is assumed to occur at 1 plant and 1 producer.
Estimated on the assumption that the minimum chemical production level is 45.4 Gg.
SOURCES: References 54, 55, and 56.
-------
TABLE 9-10. U.S. PLANTS, PRODUCERS, CAPACITY,
PRODUCTION, CAPACITY UTILIZATION, AND PRICE
Intermediates: Plastics and Fibers
1978
Number
of
Chemical plants
Acetic add
Acetic add, anhydride
Benzenami ne
2,2-Bis(hydroxymethyl )-l,3-
propanediol
Butenes, mixed
2-Butenoic acid
Carbon dlsulflde
Chloroethene
Cyclohexane
1 ,3-Cycl opentadi ene
D1 chl orodlmethy 1 s1 1 ane
1,1-01 Chloroethene
l,3-D11socyanato-2- (and 4-)
methyl benzene (80/20 mixture)
1 ,2-D1methyl benzene
1 ,3-01rnethyl benzene
1 ,4-D1methy1 benzene
1,1-Dimethylethyl hydroperoxlde
2 ,6~D1methy1 phenol
Ethehyl benzene
Ethyl benzene
Ethyne
Formaldehyde (37% by weight)
2,5-Furandione
Hexahydro-2H-azepi n-2-one
Hexanediolc add
2-Hexened1n1trile
3-Hexened1n1tr11e
3-Hydroxybutyral dehyde
4-Methyl -1 ,3-benzened1am1ne
ar-Methy 1 benzenedl ami ne
1-Methyl -2 ,4-din1trobenzene (and
2-methy1-l,3-d1nitrobenzene)
1-Methyl -2 ,4-d1n1trobenzene
4,4'-(l-Hethylethyl1dene)b1sphenol
1-Methyl -1 -phenyl ethyl
hydroperoxlde
2 -Methyl -1-propene
2-Methyl -2-propeneni tril e
Nitrobenzene
10
6
7
4
3»
1
5
14
11
ld
2
3
10
12
lf
14
ld
3
14
15
10
S3
10
3
5
2
ld
1
'll
2
4
4
4
5
15
ld
7
: Number
of
producers
7
4
5
4
2
1
4
10
9
ld
2
2
8
12
1
12
ld
3
12
16
6 *
16
8
3
4
1
ld
1
6
2
3
4
4
5
9
ld
6
Capacity
(Gg)
1,389
936
399
78
636a
54a
386
3,490
1,394
54a
54a
54a
386
665
63a
2,073
54a
54a
4,223
5,142
270
4,041
234
510
866
369a
54a
54a
76a
54a
359a
359a
268
2,376a
551
54a
516
Production
(Gg)
1,259
590
275
55
528
45C
216
3,148
1,058
45C
45C
45C
284
459
52
1,595
45C
45C
3,260
3,804
112
2,894
155
417
735
306
45C
45C
63
45C
298
298
214
1,972
464
45C
261
Capacity
utilization
. W
91
63
69
71
83a
83a
56
90
76
83a
83a
83a
74 :
69 """
83a
77
83a
83a
77
74
41
72
66
82
85
83a
83a
834
83a
83a '-
83a
83a
80
83a
84
83a
51
1978
price
(S/Kg)
0.33
0.53
0.49
0.95
0.16
1.90
0.18
0.29
0.25
NAe
2.97
0.39
0.95
0.24
0.49
0.27 .
NAe
1.42
0.38
0.23
1.47
0.11
0.53
1.14
0.92
NAe
NAe
NAe
1.12
NAe
0.47
1.26
0.77
NAe
0.33
NAe
0.46
9-31
-------
TABLE 9-10 (Continued). U.S. PLANTS, PRODUCERS, CAPACITY,
PRODUCTION, CAPACITY UTILIZATION, AND PRICE
Intermediates: Plastics and Fibers
1978
Chemical
2,2'-Oxyb1sethanol
3-Pentenen1tr1le
l-Phenyl ethyl hydroperoxlde
l,2-Propaned1ol
2-Prop*no1c acid
1,3,5 ,7-Tetraazatr1 cycl o-
[3.3.1.13'7]decane
l,3,5-Tr1azine-2,4,6-triara1ne
1 ,1 ,l-Tr1brofflo-2-methyl -2-propanol
Number
of
plants
18
ld
ld
6
3
6
3
ld
Number
of
producers
13
ld
ld
5
3
6
3
ld
Capacity
(Gg)
214
54a
54a
388
179
68
77
54a
Production
(Gg)
169
45C
45C
248
147
56a
51
45C
Capacity
utilization
(*)
79
83a
83a
64
82
83a
66
83a
1978
price
(S/Kg)
0.37
NAe
NAe
0.53
0.71
0.66
0.79
MAe
aEst1mated on the basis of the 1978 chemical industry average capacity utilization rate of 83.0 percent.
Estimated on the basis of the group average plant-to-producer ratio of 1.4.
Estimated on the assumption that the minimum'chemical production level 1s 45.4 Gg.
No data. Production 1s assumed to occur at 1 plant and 1 producer.
ePr1ce 1s not available. Chemical 1s analyzed under a threshold price approach.
^Chemical has 1 producer. Producer is assumed to have 1 plant.
SOURCES: References 59, 60, and 61.
9-32
-------
or cotton. The second major class of synthetics is the pure synthetics
class, which includes polyester, nylon, and acrylics. These are manufac-
tured via chemical processes that involve substantial chemical conversion
to produce the final molecules. All synthetic organic fibers contain
carbon, which provides the basis for the linkages that allow long polymer
molecules to form.
The largest volume synthetic fiber, polyester, accounts for 45 percent
of all synthetic fiber production. Nylon accounts for 29 percent of total
fiber production, while acrylics, polyolefins, and rayon each are respon-
cp
sible for 8 percent of fiber production.
Growth in the synthetic fibers industry will continue, albeit at a
slower pace. Synthetic fibers are expected to penetrate the market for
CO
natural fibers at a decreasing rate and the big markets for fibers,
construction and transportation, currently are in a recession. The markets
for synthetic fibers are divided almost equally among industrial and other
64
consumer goods, home furnishings, and apparel.
(IV) Plasticizers. Plasticizers are used to facilitate processing of
polymers and resins and to increase the flexibility and toughness of plas-
tics. By reducing the viscosity of resins, plasticizers enhance their
moldability at elevated temperatures and pressures.
Over two thirds of aggregate plasticizer production is used in the
manufacture of an otherwise brittle synthetic polymer, polyvinyl chloride
cc
(PVC). Plasticizers transform PVC into a highly flexible and, thus,
workable resin. The demand for plasticizers is linked to the demand for
PVC.
The biggest market for PVC is the building and construction industry.
Pipe and tubing consumes about 40 percent of PVC production, while other
major uses include: flooring and textiles, 11 percent, and coatings and
paste processes, 11 percent. PVC1also is used in the manufacture of wire
and cables, phonograph records, furniture upholstery, and miscellaneous
moldings. Despite the slowdown in housing starts, demand for PVC is expec-
ted to grow at a rate of 7 percent per year through 1984.
The future demand for plasticizers in PVC production is uncertain.
Although more than two thirds of PVC production uses plasticizers, rigid
9-33
-------
vinyls, which use little or no plasticizers for their production, are
growing much faster than flexible vinyls.
Table 9-11 presents data on the plasticizers in the organic chemical
industry. '' It is not surprising that the prices for many plasticiz-
ers are similar because they are interchangeable in most applications.
(V) Pesticides. Pesticides are chemicals used to kill weeds, fungi,
insects, and other undesirable organisms, predominantly those that inter-
fere with the growth and storage of crops. Therefore, the major user of
pesticides is the agricultural sector. Table 9-12 shows the organic chemi-
71 72 73
cals that are intermediates in pesticide production. ' '
Pesticides have enjoyed the high growth rate of 11.5 percent per year
from 1968 through 1978. With the amount of cropland limited, farmers
depend on pesticides to increase crop yields per hectare. The future
75
annual growth rate for pesticides is expected to slow down considerably.
Factors hindering future growth include bans on products due to environ-
mental effects and resistance to some products by insects.
(VI) Dyes. Dyes are used to color fabrics and other materials. As a
result, the sales of dyes parallel the sales of the textile industry, its
largest consumer. Approximately two thirds of dye use is by the textile
industry, while other uses include coloring paper, dyeing leather and
plastics, and producing organic pigments.
Table 9-13 lists the organic chemicals that are intermediates in the
77 78 79
production of dyes. * ' The annual rate of growth of the dye industry
has decreased to about 1.9 percent, which suggests a similar growth rate
80
for these intermediate products.
9.1.1.8.3 Solvents. A solvent is a substance used to dissolve other
substances. The major uses of solvents are in paints, varnishes, lacquers,
printing inks, rubber processing, and Pharmaceuticals. Growth in solvent
81
use is projected at 4.7 percent per year. Table 9-14 lists the organic
solvent chemicals.82'83'84
9.1.1.8.4 Detergents and Surfactants. Surfactants are used to reduce
the surface tension of water and other solvents. Surfactants wet surfaces,
remove and suspend dirt, penetrate porous materials, and emulsify. These
products, therefore, are used most commonly as detergents for household and
9-34
-------
TABLE.9-11. U.S. PLANTS, PRODUCERS, CAPACITY,
PRODUCTION, CAPACITY UTILIZATION, AND PRICE
Intermediates: Plastlcizers
1978
Number
of
Chemical . plants
l,3-Benzenedicarboxy11c add
l,4-Benzened1carboxy1ic add
l,4-Benzenedicarboxy11c add
dimethyl ester
l,2-Benzenedicarboxyl1c add, bis
(2-ethylhexyl) ester
1,2-Benzenedlcarboxylic add,
butyl, phenyl methyl ester
l,2-Benzened1carboxyl1c add, d1-
n-heptyl -n-nonyl undecyl ester
1,2-Benzenedicarboxylic add,
diisodecyl ester
l,2-Benzened1cartaoxyl1c add,
diisononyl ester
l,2-(and l,3-)Butaned1ol
Butanal
2-Ethyl-l-hexanol
l,3-Isobenzofurand1one
Linear alcohols, ethoxylated,
mixed
6-Methyl heptanol
1-Nonanol
Octene
1
3
6
10
2
1
6
1
2
6
5
11
21
2
1
4
Number
of Capacity
producers (Gg)
1
2
4
9
1
1
6
1
2
5
5
9
15
2
1
4
109
930
1,887
213a-
54a
54a
84*
54a
54a
428a
293
603
54a
54a
54a
54a
Production
(Gg)
45
918
1,863
177
45b
45b .
70
45b
45b
355
191
444
45b
45b
45b
45b
Capacity
utilization
(*)
41 .
99
99
83a
,83a
83a
83a
83a
. 83a
83a
65
74
83a
83a
83a
83a
1978
price
($/Kg)
0.65
0.45
0.45
0.68
0.82
0.69
0.62
0.62
0.90
0.40
0.46
0.53
NAC
0.51
NAC
0.62
aEst1mated on the basis of the 1978 chemical Industry average capacity utilization rate of 83.0 percent.
Estimated on the assumption that the minimum chemical production level 1s 45.4 Gg.
cPrice is not available. Chemical 1s analyzed under the threshold price approach based on the cost of input
chemicals.
SOURCES: References 68, 69, and 70.
9-35
-------
TABLE 9-12. U.S. PLANTS, PRODUCERS, CAPACITY, PRODUCTION, CAPACITY UTILIZATION, AND PRICE
Intermediates: Pesticides
1978
to
I
oo
Number
of
Chemical plants
l.l'-Biphenyl 8 "
6-Chloro-N-ethyl-N'-(l-methylethyl ) 3
-l,3,5-triazine-2,4-diamine
2-Hydroxy-2-methyl propaneni tri 1 e 3
2,4,6-Trichloro-l,3,5-triazine 4
Number
of
producers
7
3
3
2
Capacity
(Gg)
54a
54a
505a
. 54a
Production
(Gg)
45b
45b
419
45b
Capacity
utilization
(*)
83a
83a
83a
83a
1978
price
($/Kg)
0.53
4.01
NAC
NAC
aEstimated on the basis of the 1978 chemical industry average capacity utilization rate of 83<0 percent.
Estimated on the assumption that the minimum chemical production level is 45.4 Gg.
°Price is not available. Chemical is analyzed under a threshold price approach based on the cost of input
chemicals.
SOURCES: References 71, 72, and 73.
-------
TABLE 9-13. U.S. PLANTS, PRODUCERS, CAPACITY, PRODUCTION, CAPACITY UTILIZATION, AND PRICE
Intermediates: Dyes
1978
VO
CO
Chemical
1-Chl oro-4-ni trobenzene
6-Ethyl -1 ,2 ,3 ,4-tetrahydro-9 ,10-
anthracenedione
Number
of
plants
1
lc
Number
of
producers
1
lc
Capacity
(Gg)
54a
54a
Production
(Gg)
45b
45b
Capacity
utilization
(%)
83a
83a
1978
price
($/Kg)
0.99
NAd
Estimated on the basis of the 1978 chemical industry average capacity utilization rate of 83.0 percent.
Estimated on the assumption that the minimum chemical production level is 45.4 Gg.
cNo data. Production is assumed to occur at 1 plant and 1 producer.
Price is not available. Chemical is analyzed under a threshold price approach based on the cost of input
chemicals.
SOURCES: References 77, 78, and 79.
-------
TABLE 9-14. U.S. PLANTS, PRODUCERS, CAPACITY,
PRODUCTION, CAPACITY UTILIZATION, AND PRICE
Solvents
1978
Chemical
Acetic add, ethyl ester (85%)
2-Butanone
2-Butoxyethanol
1 ,2-01 chl oroethane
Dlchlorowethane
1 ,3-01 chl oro-2-propanol
Ethanol
2-Ethoxyethanol
2-Ethoxyethyl acetate
2-Hethoxyethanol
4-Hethyl -2-pentanone
4-Hethyl -3-penten-2-one
2-Hethyl -1-propanol
2-Mtthyl -2-propanol
1,2,3-Propanetriol
1-Propanol
1,1,2 ,2-Tetrachl orcethane
Tetrachloroethene
Tetrahydrofuran
1,1,1-THchloroethane
I,l,2-Tr1 chl oroethane
Trlchloroethene
Number
of
plants
8
7
4
17
7
2
13
5
1
7
5
4
7
2
4
3
1
11
3
3
3
5
Number
of
producers
5
6
4
11
5
2
11
5
1
7
4
3
6 "
2
3
3
1
8
3
3
3
5
Capacity
(Gg)
127
386
112
6,502
372
264a
1,070
218a
54a
68
128b
54a
83
547
118
88a
54a
558
54a
313
54a
261
Production
(Gg)
83
300
86
4,990
259
219
575
181
45b
52
106
45b
66
454
61
73
45b
329
45
292
45b
136
Capacity
utilization
(%)
65
78
77
77
70
83a
54
83a
83a
76
83a
83a
80
83a
52
83a
83a
59
83a
93
83a
52
1978
price
($/Kg)
0.42
0.42
0.66
0.18
0.51
NAC
0.37
0.60
0.74
0.62
0.60
0.71
0.29
0.58
1.12
0.53
0.59
0.27
1.65
0.46
0.71
0.35
aEst1mated on the basis of the 1978 chemical industry average capacity
Estimated on the assumption that the minimum chemical production level
°Pr1ce 1s not available. Chemical is analyzed under a threshold price
chemicals.
SOURCES: References 82, 83, and 84.
utilization rate of 83.0 percent.
is 45.4 Gg.
approach based on the cost of input
9-38
-------
commercial use. Table 9-15 presents the organic chemicals classified as
surfactants.85'86'87
One source projects market growth for surfactants at an average annual
88
rate of 2 percent through 1990. This rate is not much lower than the
2.7 percent annual rate at which production increased in the years 1970
89
through 1980. Slow growth for surfactants can be attributed to a
mature industry that has penetrated all markets.
Many of the major chemical companies produce surfactants and are
involved in all stages of surfactant production. Some smaller producers,
however, purchase the raw material necessary for surfactant production and
focus their efforts on the final production process that requires low
90
capital investment.
9.1.1.8.5 Fuel additives. Tab.le 9-16 shows organic chemicals clas-
91 Q? 93
sified as fuel additives. ' ' These products increase the efficiency
of fossil fuel combustion, aid in fuel handling, decrease smoke and
particulate emissions in the combustion of fuels, or help to boost octane
levels. A particularly fast-growing fuel additive has been methyl t-butyl
ether (MTBE), which has increased in production from almost nothing in the
mid-1970s to approximately 800 Gg in 1982. MTBE is used as an octane-
boosting agent in gasoline.
9.1.1.8.6 Aerosol propel!ants and refrigerants. The chemicals listed
in Table 9-17 are largely fluorocarbons, which have two major applications:
aerosol propellents and refrigerants. ' '
Before 1974, aerosol propel!ants consumed approximately 50 percent of
98
fluorocarbon production. Concern over the environmental effects of
fluorocarbons caused production of aerosols to drop off after 1973. In
1978, production of'aerosols began increasing after decreasing 26 percent
99
from 1973 through 1977. Contributing to the increase in aerosols
production is the replacement of chlorofluorocarbons by other, less harmful
propel!ants. However, by 1985, aerosols are predicted to account for only
20 percent of total fluorocarbon consumption. Propel!ants such as
isobutane will become more important in the propellents industry.
The second largest use of fluorocarbons is as refrigerants; in 1978,
35 percent of fluorocarbon production went for this use. The demand
for fluorocarbon refrigerants is tied to the automobile and construction
9-39
-------
TABLE 9-15. U.S. PLANTS, PRODUCERS, CAPACITY,
PRODUCTION, CAPACITY UTILIZATION, AND PRICE
Detergents and Surfactants
1978
Number
of
Chemical plants
2-Ara1noethanol
Benzenesulfonlc add, mono-C,0 16-
alkyl derivatives, sodium salts
Coconut oil adds, sodium salt
Oodecyl benzene, linear
Oodecyl benzene, nonlinear
Dodecylbenzenesulfonlc add
Dodecylbenzenesulfonlc add,
sodium salt
Fatty adds, tall oil, sodium salt
2,2' -Im1nob1 sethanol
Isodecanol
Linear alcohols, ethoxylated and
sul fated, sodium salt, mixed
Linear alcohols, sul fated,
sodium salt, mixed
2,2' ,2"-M1trolotr1sethj.nol
Honyl phenol
Konyl phenol, ethoxylated
011 -soluble petroleum sulfonate,
calcium salt
011 -soluble petroleum sulfonate,
sodium salt
Tallow adds, potassium salt
Tallow adds, sodium salt
aNo data. Production 1s assumed to
5
la
11
4
3
29
39
4
5
2
12
4
5
13
20
7
6
1
16
occur
Number
of Capacity
producers (Gg)
4
la
6
4
3
16
24
4
4
2
8
4
4
10
15
5
4
1
10
at 1 plant and 1 pi
66
54b
89b
293
169b
lllb
170b
54b
66
81b
54b
54b
66
140
112b
151b
71b
54b
196b
reducer.
Production
(Gg)
60
45C
74
239
140
92
141
45C
53
67
45C
45C
52
57
93
125
59
45C
163
Capacity
utilization
(X)
91
83b
83b
82
83b
83b
83b
83b
80
83b
83b
83b
79
'41
83b
83b
83b
83b
83b
1978
price
(S/Kg)
0.71
NAd
0.51
0.65
0.65
0.68
0.60
0.64
0.77
0.52
0.73
1.74
0.82
0.51
0.73
1.15
0.66
0.63
0.63
on the basis of the 1978 chemical Industry average 83.0 percent capacity utilization rate.
cEst1mated on the assumption that the minimum chemical production level 1s 45.4 Gg.
Price 1s not available.
chemicals.
Chemical 1s analyzed under a threshold price approach based on the cost of input
SOURCES: References 85, 86, and 87.
9-40
-------
TABLE 9-16. U.S. PLANTS, PRODUCERS, CAPACITY, PRODUCTION, CAPACITY UTILIZATION, AND PRICE
Fuel Additives
1978
Chemical
Heptane
Methyl t-butyl . ether
Tetraethy 1 pi umbane
Tetra (methyl ethyl) pi umbane
Tetramethyl pi umbane
Number
of
plants
7
9
6
6
6
Number
of
producers
6
9
4
4
4
Capacity
(Gg)
54a
1,360
180a
201a
531a
Production
(Gg)
45b
770
149
167
441
Capacity
utilization
i°/\
\'°)
83a
57
83a
83a
83a
1978
price
($/Kg)
0.20
0.17
2.38
2.34
2.34
J-, ^Estimated on the basis of the 1978 chemical industry average capacity utilization rate of 83.0 percent.
1-1 b
Estimated on the assumption that the minimum chemical production level is 45.4 Gg.
SOURCES: References 91, 92, and 93.
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TABLE 9-17. U.S. PLANTS, PRODUCERS, CAPACITY, PRODUCTION, CAPACITY UTILIZATION, AND PRICE
Aerosol Propel1 ants and Refrigerants
1978
Chemi cal
Di chl orodi f 1 uoromethane
Di chl orof 1 uoromethane
Tri chl orofl uoromethane
l,l,2-Trichloro-l,2,2-
trifluoroethane
Number
of
plants
10
2
9
3
Number
of
producers
4
1
3
2
Capacity
(Gg)
1.78a
266a
106
54a
Production
(Gg)
148
221
88
45b
Capacity
utilization
(X)
83a
83a
83a
83a
1978
price
($/Kg)
0.95
1.01
0.75
1.34
Estimated on the basis of the 1978 chemical industry average capacity utilization rate of 83.0 percent.
VO k
JL Estimated on the assumption that the minimum chemical production level is 45.4 Gg.
PO
SOURCES: References 95, 96, and 97.
-------
industries. Fluorocarbons also are used as blowing agents and as plastics
materials.
9.1.1.8.7 Coatings and miscellaneous end-use chemicals. Table 9-18
shows chemicals that are used as coatings, and Table 9-19 lists chemicals
that have miscellaneous end uses.102'103'104
9.1.1.9 Petroleum Refineries. Since basic chemicals and some inter-
mediates are produced in petroleum refineries, characteristics of the
petroleum refining industry are discussed also. As shown in Table 9-20,
there were 273 refineries in the U.S. in 1982. The average
refinery had a capacity of 10,800 m per stream day.
Refineries produce primarily gasoline, distillate fuel oil, residual
fuel oil, and jet fuel. As shown in Table 9-21, these products accounted
for 83 percent of all refinery products in 1981. Petrochemical feed-
stocks (basic chemicals) accounted for approximately 5 percent of yields.
Refineries generally are owned by oil companies, many of which are
large and have integrated operations, spanning from crude oil exploration
and production through marketing of gasoline and oil products. The
refining industry at times has had high earnings. In 1981, for example,
the largest 8 oil companies had after-tax profits equal to 17.9 percent of
equity, while a large sample of manufacturing companies in all industries
11? 11*3
had profits of 14.0 percent.1 "»lld
In this BID, chemicals produced primarily by refineries (particularly
basic chemicals) are assumed to incur no control costs as a result of the
standards. Refineries are assumed to adopt controls for VOC emissions from
distillation of such chemicals even in the absence of NSPS on distillation
processes.
9.1.2 Projections of New Plants
In the five year period beginning November 1, 1982, approximately 600
chemical plants using distillation columns are projected to be built by the
organic chemical industry. This projection is derived using the equation
presented in Table 9-22. As used in this chapter, the term "plant" refers
to any operation engaged in the production of one of the 219 organic
chemicals. Thus, a producer that owns one installation producing five
chemicals is considered to be operating five "plants" (i.e., one for each
chemical).
9-43
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TABLE 9-18. U.S. PLANTS, PRODUCERS, CAPACITY, PRODUCTION, CAPACITY UTILIZATION, AND PRICE
Coatings
1978
Chemical
Acetic acid, butyl ester
Acetic acid, ethenyl ester
2-Propenoic acid, butyl ester
2-Propenoic acid, ethyl ester
Number
of
plants
5
7
5
5
Number
of
producers
4
6
4
4
Capacity
(eg)
66a
924a
219
234
Production
(Gg)
55
767
127
136
Capacity
utilization
(*)
83a
83a
58
58
1978
price
($/Kg)
0.57
0.40
0.79
0.66
Estimated on the basis of the 1978 chemical industry average capacity utilization rate of 83.0 percent.
SOURCES: References 102, 103, and 104.
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TABLE 9-19. U.S. PLANTS, PRODUCERS, CAPACITY, PRODUCTION, CAPACITY UTILIZATION, AND PRICE
Miscellaneous End-Use Chemicals
1978
10
en
Chemical
Cyclopropane
1,2-Ethanediol
2-Hydroxy-l,2,3-
propanetricarboxylic acid
Tribromomethane
Trichloromethane
Urea
Urea ammonium nitrate
Number
of
plants
1
17
5
1
7
47
ld
Number
of
producers
1
13
2
1
5
34
ld
Capacity
(Gg)
54a
3,084
147
54a
234
6,802
54a
Production
(Gg)
45b
1,771
115 ,
45b
158
5,690
45b
Capacity
utilization
(%)
83a
57
78
83a
68
84
83a
1978
price
($/Kg)
NAC
0.37
1.37
2.58
0.49
0.14
0.13
Estimated on the basis of the 1978 chemical industry average capacity utilization rate of 83.0 percent.
Estimated on the assumption that the minimum chemical production level is 45.4 Gg.
cPrice is not available. Chemical is.analyzed under a threshold price approach based on the cost of input
chemicals.
No data. Production is assumed to occur at one plant and 1 producer.
SOURCES: References 102, 103, and 104.
-------
TABLE 9-20. TOTAL AND AVERAGE CRUDE DISTILLATION CAPACITY BY YEAR3
United States Refineries
1978-1982
Year,
(January 1)
1978
1979
1980
1981
1982
Number of
refineries
285
289
. 297
303
273
Total capacity
(rnVsd)
2,801,000
2,870,000
2,975,000
3,080,000
2,957,000
Average refinery
capacity
(m3/sd)
9,800
9,900
10,000
10,200
10,800
Capacity in stream days.
SOURCES: References 105, 106, 107, 108, 109, and 110.
9-46
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TABLE 9-21. PRODUCT YIELDS OF REFINERIES IN THE U.S.
•1981
(Percent of input volume)
Product
Yield
Motor gasoline
Jet fuel
Ethane
Liquefied gases
Kerosene
Distillate fuel oil
Residual fuel oil
Petrochemical feedstocks
Special naphthas
Lubricants
Wax
Coke
Asphalt
Road oil
Stfll gas
Miscellaneous
Processing gaina
Total
44.5
7.9
0.1
2.4
0.9
20.5
10.4
4.5
0.6
1.3
0.1
3.1
2.7
0.1
4.5
0.7
-4.0
100.0
Represents the arithmetic difference between input and produc-
tion, reflecting the fact that refining products have a greater
volume than crude oil.
SOURCE: Reference 111.
9-47
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TABLE 9-22. EQUATIONS FOR PROJECTING NEW CAPACITY AND
PLANTS FOR THE ORGANIC CHEMICAL INDUSTRY
219 Distillation Chemicals
United States
November 1, 1982 - November 1, 1987
1)FPig87 = (1+r)9 x PP
2) FP1982 = (1+r)4 x PP
3) NP = FP198y - FPig82
4) TP = NP + RP
Where:
r = Growth rate for each group. These rates are based upon the
weighted averages among chemicals (in terms of relative
capacities of chemicals within each group). The growth rates are
based on rates in Chemical Marketing Reporter, which bases its
estimates on patterns found in surveys of chemical producers
(and, to a lesser extent, consultants and other sources).
Basic chemicals 4.5%
Intermediates for:
General aromatics 4.5%
General non-aromatics 4.1%
Synthetic elastomers 3.0%
Plastics and fibers 2.0%
Plasticizers 4.1%
Pesticides 5.0%
Dyes 1.9%
Solvents 4.7%
Detergents and surfactants 2.9%
Fuel additives 2.5%
Aerosol propel1 ants and refrigerants 3.0%
Coatings 6.7%
Miscellaneous end-use chemicals 3.9%
PP s "Present plants." The number of plants in existence as of
November 1978 (see Tables 9-6 through 9-19, and the note at the
end of this table).
"Future plants in 1987." The number of plants projected to be in
existence as of November 1987.
FP,g82 - "Future plants in 1982." The number of plants projected to be in
existence as of November 1982.
NP s "New plants." The number of plants expected to be added by
group producers in response to growth in demand from November
1982 through November 1987.
9-48
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TABLE 9-22 (Continued). EQUATIONS FOR PROJECTING NEW CAPACITY AND
PLANTS FOR THE ORGANIC CHEMICAL INDUSTRY
219 Distillation Chemicals
United States
November 1, 1982 - November 1, 1987
RP =: "Replacement plants." The number of plants projected to be built
to replace retired capacity in the five-year period from November
1982 to November 1987.
TP = "Total plants." The total number of plants projected to be built
during the five-year period from November 1982 to November 1987.
NOTE: Data on numbers of plants and aggregate capacities for producing
chemicals are listed in Tables 9-6 through 9-19. Most of the
figures represent published statistics from sources like SRI's
Directory of Chemical Producers in the United States. In some
cases, however, complete information was not available and several
techniques were used to estimate proxy numbers of the figures on
existing plants and capacity. ,
When there was information on the number of firms producing a
chemical but not on the number of plants, the number of plants was
multiplied by the average ratio of plants to producers found among
chemicals with data in the same chemical group. The average plant-
to-producer ratio ranges from 1.0 among dyes to 2.4 among aerosol
propel 1 ants and refrigerants, and is 1.3 for all chemicals in compo-
site.
When information was known on total capacity but not on the number
of plants or producers, capacity was divided by the average plant
size among chemicals in the same chemical group.
Existing plants, known and estimated, were counted in whole numbers.
New and replacement plant projections were made in decimal fractions
and summed to chemical group totals before rounding to whole numbers.
SOURCE: References 114 and 115.
9-49
-------
Several assumptions underlie the projection. First, capacity is as-
sumed to grow at the same rate as production during the five-year period.
Annual growth rates for production are identified by chemical group in
Table 9-22 and range from a low of 1.9 percent for dyes to a high of 6.7
114
percent for coatings, as projected by Chemical Marketing Reporter.
The projections published by Chemical Marketing Reporter are based upon
surveys of chemical producers (and, in some cases, consultants and other
sources); a general estimate is reached for each chemical based upon the
115
patterns shown by the survey results.
The assumption implies that the capacity utilization rate remains
constant throughout the period. The 1978 capacity utilization rate was 83
percent for the chemical industry as a whole. This 1978 rate is within 2
percentage points of the industry-wide 10-year average from 1969 through
1978, which was about 81 percent.
The median growth rate used in the projections is 4.1 percent.
Although the current recession has led to severe reductions in the rate of
capacity utilization among producers of many organic chemicals, implying
that new capacity additions will not be needed immediately, the rates used
in the growth projections are representative of long-term growth trends for
chemicals and, therefore, provide a representative basis for projecting
trends of plant construction that would be affected by NSPS in the future.
Second, plants are assumed to have an operating life of 20 years.
In the five-year period after November 1, 1982, capacity constructed in the
period from November 1, 1962, to November 1, 1967, is assumed to be
retired. Capacity added during this earlier period has been identified
from Chemical Engineering's "Construction Alert." The retired capacity
would be replaced and would not fall under the category of modifications
and reconstructions of existing plants (see Chapter 5). It is assumed that
no modifications or reconstructions will occur in the five-year period. No
plants are expected to reconstruct or change columns to the point of inves-
ting more than 50 percent of the replacement costs of the columns.
Third, the size of new plants is assumed to be the same as the average
size of present plants. This assumption tends to overstate the number of
plants because many new plants are larger than average existing plants
118-127
(reflected in the size of plants built in the past).
9-50
-------
The growth rates in Table 9-22 are used to project both the number of
plants expected to exist in November 1982 and the number of plants in
November 1987. The number of plants in 1982 then is subtracted from the
number of plants in 1987 to arrive at the number of new plants projected to
be built from November 1982 to November 1987 in the group. The number of
plants anticipated to replace retiring plants during the five-year period
is added to the number of new plants to calculate the total number of
plants expected to be added during the period.
Table 9-23 presents the projected number of new and replacement plants
for each group. New plants are projected to total 393 and replacement
plants 212.. This converts to 1,200 new and replacement distillation units
(see page 7-2). It is assumed that growth among plants in SIP states will
take place at the same pace as growth in non-SIP states. Hence, separate
projections for SIP and non-SIP plants are not needed.
These projections are based on the assumptions described above. While
the projections are as accurate as data permit, changes in the general
state of the economy, technological advances, development of competitive
substitutes, discovery of new product uses, and changes in the stability of
markets may affect actual industry growth. Such occurrences are difficult
to anticipate. These projections reflect the most probable scenario and
are the best possible given the data available.
Even if subsequent events prove the projections wrong, they remain
valid for their intended purpose: _a guide in exploring the future costs
and other impacts of NSPS. Indeed, reasonable variations in the projection
of affected facilities would have no effect on the need for, and selection
of, a standard.
9.2 CHEMICAL SCREENING ANALYSIS
The main tool in the economic analysis is a screening. A screening is
used because of the large number of chemicals (219) affected by the NSPS
and the fact that control costs for most of the chemicals are small in
relation to plant resources and sales. The screening uses a price impact
criterion, discussed in Section 9.2.1, to categorize chemicals in terms of
the severity of potential impacts for their producers or consumers.
In Section 9.2.2, characteristics of the control costs used in the
screening are summarized. Worst-case costs are based upon the technical
9-51
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TABLE 9-23. PROJECTED NUMBER OF NEW AND REPLACEMENT
DISTILLATION PLANTS IN THE ORGANIC CHEMICAL INDUSTRY
BETWEEN NOVEMBER 1982 AND NOVEMBER 1987
Groups
Basic chemicals
Intermediates for:
General aromatics
General non-aromatics
Synthetic elastomers
Plastics and fibers
Plasticizers
Pesticides
Dyes
Sol vents
Detergents and surfactants
Fuel additives
Aerosol propel 1 ants and
refrigerants
Coatings
Miscellaneous end-use chemicals
Total
New
plants
102
20
84
12
37
21
6
0
38
32
5
4
11
21
393
Replacement
plants
64
1
29
5
36
3
2
0
12
40
0
7
3 .
10
212
Total
plants
to be added
166
21
113
17
73
24
8
0
50
72
5
11
14
31
605
9-52
-------
plant characteristics described in Chapter 8, and also include costs that
are rolled through in cases where input chemicals are also covered by the
standards. Economic plant characteristics (production and sales) are
presented in Section 9.2.3.
The results of the screening are summarized in Section 9.2.4. Appen-
dix I presents the data used and the potential price impact results for
each of the 219 chemicals.
9.2.1 Screening Criterion
A screening is conducted to measure control costs in relation to
prices of chemicals. The following criterion is used to screen chemicals
that would not have significant costs of control from those that would:
If the worst-case annualized cost of control for a
chemical would be greater than 5 percent of the chemi-
cal's projected 1987 market price, that chemical would
need further examination for economic impacts.
The five percent level has been used because it is a generally accepr
ted criterion for determining if a price increase is significant. Chemi-
cals whose worst-case price increase would be less than 5 percent are not
examined in depth in the economic analysis, as it is assumed that a price
change (or the equivalent cost increase) of less than 5 percent would be
small, given the tendencies to overstate costs when the worst-case assump-
tions (explained below) are used.
An increase in chemical prices of less than 5 percent represents a
limited degree of change for chemical producers. In the five year period
from 1973 to 1978, the base year for this analysis, the index of prices for
Chemicals and Allied Products increased by an average of 4.9 percent per
128
year (in 1978 value dollars). Accordingly, the screening criterion
indicates a price increase no greater than a single year's average infla-
tion for the chemical industry in recent years. While no cost increase is
desirable, an increase of less than 5 percent falls within a range that the
industry and its customers have already experienced.
9.2.2 Control Costs for the Screening
The economic analysis is conducted in two parts using two sets of as-
sumptions on pollution control costs. In this section, a chemical-specific
screening examines each of the 219 chemicals for their potential price
increases if control costs equaled worst-case assumptions. Worst-case cost
9-53
-------
assumptions are used although, as explained below, a* number of refinements
are made in the worst-case assumptions for particular chemicals in the
screening. Subsequently, in Section 9.3, impacts are calculated for the
organic chemical industry in aggregate using the most-likely assumptions
for pollution control costs.
9.2.2.1 Direct Costs. Each chemical received one of four direct cost
codes. Appendix I lists the chemicals and corresponding codes.
•Code 0 is applied to 39 chemicals that will incur no control costs.
These are some of the basic chemicals, chemicals produced mostly in refi-
neries, and surfactants. In some cases the assumption is that adequate
control equipment would be included in a new plant for safety, operational,
or other reasons independent of an NSPS; this generally is the case in
refineries. For other chemicals, particularly surfactants, the assumption
is that new plants will use processes that do not require distillation.
Code 1 is applied to chemicals where sulfur or a halogen is involved
in the production process. A combined incinerator and scrubber complex are
assumed. The complex is designed to meet the specifications of Table 8-1
and is costed following procedures referenced in Chapter 8 and data from
Table 8-5. The annualized cost, using a 10 percent real interest rate and
10-year amortization period, is $1,160,900 per plant. This figure is
derived by assuming 13 columns to be controlled, a vent stream with a flow
o
rate of 52 m /min. and no VOC.or energy content, no credit for heat recov-
ery other than that associated with a recupertative heat exchanger, and no
sharing of control costs with coproducts or by-products that may be produced
at the same site. In figuring control costs, projected 1987 gas prices (in
1978 dollars) are used to estimate incinerat-ion operating costs; gas price
projections are explained in Section 9.2.3.
These assumptions represent the worst case one might encounter. The
average plant in the NEP has only three or four columns; only one plant has
13. On the average, in the NEP only two columns per plant would require
3
controls. The 52 m /min. flow rate is unusually high. The vent stream
is assumed to be nitrogen; nitrogen contributes no energy to incineration,
which means that substantial amounts of natural gas are required to bring
the gas up to incineration temperature and no heat recovery credits are
available from vent gases. Finally, savings that could arise from use of
9-54
-------
only a single incinerator for disposal of waste gas streams from many
sources, including from distillation columns for other chemicals, are not
counted. ' ,
Code 2 is identical to code 1, except that no scrubber is included
because corrosive chemicals are not present. The annualized control cost
is $356,000 per plant.
Code 3 chemicals are special cases. The screening was run initially
with cost codes 0, 1, and 2. Chemicals that did not show significant price
impacts were not subject to further study. However, the others were
examined to see if some code 1 or 2 assumptions clearly overstate likely
plant characteristics. In a few cases it was found that code 0 was more
appropriate. In most cases, code 3 was assigned. This means that EPA
prepared more reasonable worst-case cost estimates based on a closer look
at the number of distillation columns and actual emission rates. Costs for
code 3 chemicals typically range from $140,000 to $300,000 per plant. The
actual amounts are given in Appendix I.
The extent to which worst-case assumptions tend to overstate control
costs can be seen in the following comparisons. Under the flare prefer-
ence, control costs at plants with affected columns would be $70,800 per
plant. The flare preference represents the most-likely case for controls.
On the other hand, worst-case assumptions lead to the following control
costs at plants with affected columns: $1,160,900 under code 1, $356,000
under code 2, and generally $140,000 to $300,000 under code 3. Overstating
costs ensures a conservative basis for cost estimates in the individual
chemical screening process. At some plants, it is possible that control
costs may approach worst-case levels, although such instances are unlikely.
9.2.2.2 Rolled-Through Costs of Control. Plants can incur costs of
control not only from their own direct costs that they incur but also from
pass-through of control costs by suppliers of the input chemicals they use.
The organic chemical industry consists in large part of a series of proces-
ses, each of which modifies prior organic chemicals. Starting with basic
chemicals, such as ethene or benzene (which are generally produced by
refineries), chemicals are processed into derivatives and, in turn, into
other derivatives and, finally, into end products such as paints, tires,
and other items. Control costs at each stage affected by the standards may
9-55
-------
be passed on (or rolled through), such that costs add up for chemicals pro-
duced from other affected chemicals.
The screening takes into account potential rolled-through control
costs by charging control costs for input chemicals to derivatives in pro-
portion to the amounts used in the production of the derivatives. For
example, if 1 kg of chemical C is produced from 0.5 kg of chemical A and
0.75 kg of chemical B (with 0.25 kg becoming by-products), one half of the
control costs (per kg) for chemical A and three fourths of the control costs
(per kg) for chemical B are added to the direct control costs of chemical C
to determine the total cost impact for chemical C. (Since control costs
generally are calculated without allowing credits for the energy value of
VOC compounds combusted9 it may be noted that no credits are given to
chemicals from inputs even though all input costs are rolled through.)
In practice, not all suppliers for a given plant would be affected by
the standards and have control costs to pass through. Moreover, the rolled-
through effect could be much less if suppliers were unable to increase
prices for recovery of control costs at their plants. Nonetheless, this
rolled-through cost methodology helps to ensure that the total control costs
considered in the screening are worst-case magnitudes.
The second half of Appendix I presents a breakdown of direct costs and
total costs (including rolled-through costs) for each of the 219 chemicals.
The first half of Appendix I presents data on the sequence of chemical
derivatives used in the rolled-through cost calculations. T
In some cases, several manufactuf ing"processes'" are™ used 'by~pr"o'duce"r"S";~"
The screening program is"~de~s"i'grieH~~to'~s"eTec"t "the production""route' '
for producing each chenvfcal that would lead to the highest potential
control costs in the event all inputs were affected by the NSPS. ,""/.'"
In the program, each chemical and production process is assigned a hierarchy
code that instructs the computer to determine control costs for input chemi-
cals first and subsequently for successive generations of derivative chemi-
cals, which have higher codes. The computer calculates the combined direct
and rolled-through costs of control for every possible production route,
and then indicates the highest combined cost for each of the chemicals.
The hierarchy (or priority) codes are indicated for each chemical in Table
1-2 of Appendix I. Details on the screening program can be found in
Documentation of the SOCMI MAXCOST Model, as cited in Appendix I.
9-56
-------
9.2.3 Plant Parameters
Control costs are applied to plant parameters for each chemical to
relate control costs to chemical prices and determine the percentage price
increase that a plant producing a chemical may incur. Control costs are
translated from plant totals to cents-per-kg figures under the assumption
that they would be spread among production volumes found at average size
plants for each chemical.
Plant sizes are based upon each chemical's production and number of
plants in 1978, in general, and can be calculated from data presented in
Tables 9-6 through 9-19. Several methods were used to determine average
plant sizes, given the variations among chemicals in the amount of data
that are publicly available. The methods are:
t When both production and the number of plants are known, an
average plant production size is calculated by dividing the
number of plants into total production of the chemical.
• When only the number of plants is known, a production figure of
45.4 Gg (100 million pounds) per year is assumed. This is the
lowest level of production possible for chemicals included under
the standards. An average plant production size then is calcu-
lated using this assumption.
• When only the number of producers is known, the number of plants
is estimated with the assumption that the plant-to-producer ratio
is the same as the average for other chemicals in the same
chemical group. Production is assumed to be 45.4 Gg (100 million
pounds) per year (as in the second case above), and an average
plant size for each chemical is calculated.
• When data on production, the number of plants, and the number of
producers are not available (particularly in cases with disclo-
sure problems), an average production size of 45.4 Gg per year is
assumed.
It is assumed that new plants with columns affected by the standards will
be equal in size to existing plants used in the calculations.
Chemicals are valued at projected market prices for 1987, expressed in
1978 dollars. As shown earlier in Figure 9-3, chemical prices have tended
to increase in step with increases in the price of crude oil. Oil or gas
costs account for major portions of manufacturing costs for organic chemi-
cals because chemicals are derived from these sources, whose prices have
escalated rapidly. Chemical prices in 1987 (the fifth year after proposal)
9-57
-------
are projected to increase from 1978 levels at the same rate as the cost of
their raw materials — oil or gas.
Oil and natural gas prices are projected to increase in real terms
(i.e., 1978-value dollars) by 148 and 234 percent, respectively, from the
base year 1978 to 1987. These projections are taken from the U.S. Depart-
ment of Energy's Annual Report to Congress (1979) and "Technical Staff
Analysis in Response to Notice of Proposed Rulemaking on Phase II of Incre-
mental Price" (February 9, 1980). Even though the world energy markets are
soft in 1983, it should be noted that energy prices have increased substan-
tially since 1978. Even if future rates of increase were moderate, they
would suffice to approximate the 1987 energy price projections.
The 219 chemicals are partitioned into three groups. The first "group
consists of all the chemicals derived from oil (and natural gas liquids)
and encompasses most of the 219 chemicals. Included in this group are
ethylene, propylene, benzene, toluene, xylene, butadiene, and related
derivatives. The second group consists of chemicals derived only from-
natural gas, via such chemicals as methane (or synthesis gas), methanol, or
urea. Gas-based chemicals are: 43, 44, 51, 70, 71, 74, 75, 108, 122, 132,
133, 193, 195, 200, 201, 206, 207, 208, 211, 212, 216, 220, 221, and 236.
(Chemicals derived in part from oil-based chemicals and in part from gas-
based chemicals are assigned to the oil-based group to allow for the lower
escalation rate for oil.) A small number of chemicals belong to the third
group, natural-based chemicals, such as coconut oil, animal fat, or sugar-
based chemicals. Natural-based chemicals are: 57, 107, 110, 125, 191,
192,.and 210. Chemicals from natural raw materials are assigned no esca-
lation factor (i.e., are projected to increase in price no faster than the'
general inflation rate in the economy). The origins of any chemical can be
traced in the screening data shown in Appendix I.
Chemical prices are obtained from sources including the U.S. Inter-
national Trade Commission's Synthetic Organic Chemicals: United States
Production and Sales, 1978, Chemical Marketing Reporter, and communications
with chemical industry officials. In the case of quotations from Chemical
Marketing Reporter and industry officials, in particular, prices are
expressed generally as list prices. Discounts or surcharges on list prices
may exist, but would be difficult to quantify.
9-58
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In the case of some chemicals, prices are not available. A number of
chemicals are not sold widely. When prices are not available, a price
threshold is calculated. This threshold represents the lowest price the
chemical could have and still pass the 5 percent price increase criterion.
If producers do not sell at a price less than variable costs of production,
a chemical with raw material costs greater than the price threshold has a
price greater than the price threshold and, therefore, has control costs
that are less than 5 percent of its price. This situation prevails because
the 219 chemicals are high-volume chemicals generally produced for their
own sake, not as incidental by-products.
For example, cyclopropane incurred an effective cost increase of 0.7
cents per kg. Therefore, a price threshold of 14.1 cents per kg (or 0.7
cents divided by 5 percent) is identified. Using 1987 market prices (in
1978 dollars), the total cost, of purchasing raw materials used in produc-
tion of cyclopropane is 64.2 cents per kg of cyclopropane. Thus, one may
infer that the price of cyclopropane is likely to be higher than 64.2
cents per kg. Cyclopropane would not incur costs greater than 5 percent of
its price under this assumption, and would not fail the screen.
Some of the chemicals for which price information was unavailable were
screened out on this basis. This method is conservative in two ways.
First, because only raw material costs are considered, these "costs" sig-
nificantly understate the actual cost per unit of product, which would
include direct labor and capital costs as well as a share of the producer's
fixed costs. Second, in general, only raw materials with anticipated con-
trol costs are considered. Thus, the price of chemicals utilizing raw
materials not controlled by the NSPS has been underestimated by this pro-
cedure. This method allowed for the analysis of 33 chemicals (identified
in Appendix I).
9.2.4 Results of the Screening
None of the 219 chemicals directly affected by the NSPS for distilla-
tion fails the screening. Most chemicals would have price increases of
less than 1 percent. Table 9-24 summarizes price impacts under the worst-
case cost assumptions.
Close to two-fifths (38 percent) of the chemicals would have price
increases ranging between 0.0 and 1.0 percent. A further 19 percent of the
chemicals would have no price increase, because they are assumed to incur
9-59
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TABLE 9-24.
DISTRIBUTION OF CHEMICALS ACCORDING TO SIZE
OF POTENTIAL PRICE INCREASE
Screening Results
Percentage increase
in price of chemical
0.00
0.01 to 0.99
1.00 to 1.99
2.00 to 2.99
3.00 to 3.99
4.00 to 4.99
5.00 or greater
Number of
chemicals
35
70
55
16
8
2
0
Percentage of all
with price increase
18.8
37.6
29.6
8.6
4.3
1.1
0
chemicals
estimates
All chemicals with price
increase estimates
Chemicals studied for
threshold only
All chemicals
186
33
219
100.0
Potential price increases are based on the assumptions used in the screening
analysis. The analysis assumes full pass-through of worst-case direct and
rolled-through input control costs. Prices are projections for 1987 in 1978
dollars. Average size plants and processes with the highest control costs
are used.
A number of chemicals are determined to have control costs equal to less than
5 percent of their prices because known purchase costs (prices) for input
chemicals imply that prices charged by producers must be more than 20 times
control costs. However, specific price increases are not.known, so no
percentage price increase is listed.
9-60
-------
no control costs due to NSPS (most are basic chemicals produced at refin-
eries). An additional 30 percent would have price increases ranging
from 1.00 to 1.99 percent. Again, no chemical would have a price increase
of 5 percent or more in relation to its projected 1987 prices, even, with
the worst-case assumptions on direct and rolled-through control costs.
In sum, approximately 86 percent of the chemicals would have potential
maximum price increases below 2 percent if affected by NSPS for distilla-
tion. Approximately 95 percent would have potential price increases below
3 percent. While the 33 chemicals studied under the threshold price
approach might modify these percentages slightly, if precise price increases
were known, the general pattern is that NSPS for distillation would not be
a source of significant control costs for any chemicals. (Most-likely
control costs, under the flare preference, would show even smaller poten-
tial p'rice increases, given the much lower cost of flaring compared to the
costs of incineration, in most instances.)
The screening is based upon several cost codes and different degrees
of refinement and study of control costs for various chemicals, as dis-
cussed earlier in this section. It cannot be inferred that chemicals would
incur control costs of each magnitude indicated, since these are worst-case
control costs and each chemical's control experiences may vary from the
worst-case assumptions in different degrees. Hence, the distribution shown
in Table 9-24 illustrates the fact that most chemicals would incur maximum
control costs well below the 5 percent level. A small price increase with
worst-case control cost estimates indicates that there will be no signifi-
cant impacts on producer profits, capital availablility, or other finances.
Note, it would be misleading to name and rank each chemical, because
the chemicals have been treated differently in terms of the quality and
refinement of data collected and in the control cost assumptions. A chemi-
cal showing a 3 percent price increase, for example, may simply have
received less detailed study and research than one showing a 1.5 percent
price increase in the screening.
An implication of the screening results is that no chemical plant or
producer is likely to incur significant control costs under the standards,
even if control techniques entailed incineration at plants with adverse
conditions involving numbers of distillation columns, emissions flow rates,
9-61
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or energy credits from the emissions stream. Accordingly, no individual
chemicals are designated for more in-depth study in the economic analysis.
9.3 GENERAL ECONOMIC IMPACTS
This section examines issues such as potential impacts for chemical
prices, production, employment, and trade. Whereas the preceding chemical
screening analysis is based on worst-case control cost estimates, this
section uses estimates of control costs that reflect conditions that are
most likely to prevail at affected plants in the industry. Most-likely
control costs are based on flare preference and the 98 percent VOC
emissions reduction alternative.
Most-likely control conditions will require a capital investment of
$110,000 and will result in annualized control costs of $70,800 per
129
plant. For the chemical industry as a whole, investment requirements
are estimated to amount to $14.9 million during the first five years after
proposal of the distillation NSPS. Similarly, annualized control costs
will amount to $9.6 million in the fifth year after proposal. Industry cost
totals are based upon the number of plants projected to be affected by
distillation NSPS in the first five year period after proposal, net of
plants that might control emissions in the baseline or which might exceed
the TRE criterion.
The analysis of general economic impacts makes an additional
assumption that producers incurring control costs will pass their costs
through fully to consumers in the form of higher prices. In the event
producers absorbed all or some of their control costs, rather than passing
them through, impacts on prices, production, employment, and trade would be
less since there would be a smaller potential change in industry prices and
demand. As with the worst-case control costs used in the screening
analysis, control costs used in this section also reflect 1978 value
dollars.
9-62
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9.3.1 Price Impacts
Price impacts with the most-likely estimates of control costs would be
small. In 1977, sales by chemical producers in SICs 2865 and 2869 amounted
to $30.1 billion (in 1978 dollars), as shown in the 1977 Census of
130
Manufactures. Aggregate control costs of $9.6 million in the fifth year
of the NSPS would amount to less than one percent (0.03 percent) of the
aggregate sales of the organic chemical industry.. In terms of the overall
cost of chemicals for consumers, therefore, the distillation NSPS poses
little potential for change from what consumers would otherwise pay.
Price changes would be larger when measured against the sales of only
those plants affected by the NSPS, but such changes would also be small.
As shown in Table 9-25, plant sales by producers in each of the 12 chemical
groups incurring control costs range from an average of $6.1 million among
producers of detergents and surfactants to $56.4 million among producers of
fuel additives. The median sales level of plants is $25.4 million,
represented by the average for general non-aromatics plants. Annualized
control costs of $70,800 with most-likely controls amount to only 0.1 to
0.8 percent of plant sales, using the group average plants. Such costs
would represent an increase in prices of only 0.3 percent for the median
plant having $25.4 million in annual sales. Again, if pass-through were
less than 100 percent, cost increases would amount to an even lower
percentage of sales.
Using group average plant throughput figures, the $70,800 in control
costs would amount to 0.1 to 0.8 cents per kg of chemical production. At
the median size plant for the chemical industry, which has an annual
throughput of 54 Gg, the cost increase would amount to only 0.1 cents per
kg. Again, the costs of distillation NSPS do not pose the potential for a
large.increase in chemical prices.
9.3.2 Production Impacts
Because prices will not be affected by any large increases in the cost
of production due to distillation NSPS, demand for chemicals will remain
9-63
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TABLE 9-25.
AVERAGE THROUGHPUT AND ANNUAL PLANT SALES
12 Chemical Groups
United States
1978
Average
annual plant
•UU. .„!._..J.D
Average„
annual plant
-_i__D
Chemical group3
Intermediates for:
General aromatics
General non-aromatics
Synthetic elastomers
Plastics and fibers
Plasticizers
Pesticides
Solvents
Detergents and surfactants
Fuel additives
Aerosol propel! ants and
refrigerants
Coatings
Miscellaneous end-use chemicals
Will WI^JIIf^Mt*
(Gg)
63
54
74
80
54
31
70
9
46
21
49
106
(106~1978 $)
20.1
25.4
39.2
29.1
35.0
18.6
21.0 «•
6.1
56.4
20.4
24.0
23.2
aTwelve of the original 14 chemical groups are listed. The basic chemicals
group has no control costs associated with it while the dyes group has no
future facilities projected for the five years after date of proposal.
Figures are derived from Tables 9-6 through 9-19.
9-64
-------
essentially unchanged. The sensitivity of demand to changes in prices for
chemicals is described by economists as the elasticity of demand. It is
difficult to quantify the elasticity of demand for organic chemicals, so
the issue of potential production impacts can be illustrated by using
unit elasticity as an assumption. With unit elasticity (i.e., elasticity
equal to minus one), an increase in product prices would result in a
proportional decrease in demand for the product. As described in Section
9.3.1, the overall change in prices for the organic chemical industry would
be no more than 0.03 percent; hence, with unit elasticity the change in
production in the industry would amount to no more than 0.03 percent.
Similarly, if elasticity of demand were greater than one, potential
changes in production would still be small. An elasticity of (minus) two
would imply potential demand changes of no more than 0.06 percent, still
much less than one percent of industry production. Again, as with prices,
distillation NSPS offers little prospect of influencing the overall
chemical industry.
9.3.3 Employment Impacts
The same calculations apply for industry employment as apply for
industry production. As stated in Section 9.1.1.4, employment at plants
producing the 219 chemicals amounts to approximately 140,000. If prices
were increased to recover the full costs of controls and elasticity of
demand equalled (minus) one, the change in production described in Section
9.3.2 would cause a decrease in industry employment of only 40 workers.
Like the other changes for the industry as a whole, this is small.
9.3.4 Trade Impacts
Given the small potential change in domestic production ($9.6 million
in the example above), U.S. trade in chemicals will remain largely
unaffected. As shown earlier in Table 9-4, the U.S. exported $12.2 billion
more chemicals in 1980 than it imported. Small changes in domestic
production would not alter the overall positive trade balance for
chemicals.
9-65
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9.3.5 Other Impacts
Capital requirements for distillation NSPS would also be small. Using
the average ratio' of long-term capitalization (long-term debt and
131
stockholders' equity) to sales at chemical plants, the chemical
industry's median size plant (represented by the average for general
non-aromatics producers) has an estimated $1.98 million in long-term debt
and $5.11 million in stockholders' equity. This equals a 27.9 percent debt
ratio (long-term debt as a percentage of long-term debt plus stockholders'
equity) in the baseline. An increase in capital investment of $110,000 to
install distillation VOC emissions controls under most-likely control
conditions would increase the debt ratio to 29.0 percent if financed
entirely from debt sources. This change in the debt ratio is modest, and
could be limited to even less if part of the control investments were not
funded from debt.
9.4 AGGREGATE IMPACTS - SOCIOECONOMIC AND INFLATIONARY
Additional impacts are examined for fifth-year costs and small
businesses. These are discussed below.
9.4.1 Fifth-Year Impacts
As discussed in Section 9.3, in the fifth year after proposal of
distillation NSPS, aggregate control costs for the chemical industry will
be approximately $9.6 million. Aggregate capital investment requirements
will amount to $14.9 million through the fifth year of the NSPS. The
magnitude of these costs in relation to industry sales and financial
resources is described in Section 9.3 and shown to be small.
9.4.2 Regulatory Flexibility Act Considerations
The Regulatory Flexibility Act (Public Law 96-354, September 19, 1980)
requires that special consideration be given to the impacts of proposed
regulations on "small" entities. As one criterion for extending loans and
related assistance, the Small Business Administration defines a "small"
business in the organic chemical industry as one that employs fewer than
500 to 1,000 workers (13 CFR Part 121, Schedule A).132 Similarly, a small
business in the petroleum refining industry is one that employs fewer than
500 to 1,500 workers. .These employment numbers are for entire firms,
including affiliates, and not just for each individual process unit that
9-66
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involves distillation.
The actual employment-level against which each firm is judged depends
on what the primary product of the business is. Other characteristics,
such as dominance in a field of operation and refinery feedstock capacity,
are also used to classify businesses as large or small. For the purposes
of this section, a business is considered small if it: a) is primarily a
petroleum refiner and has fewer than 1,500 employees, or b) is primarily a
chemical producer and has fewer than 1,000 employees. The Act also applies
to small organizations and small governments. However, there is none that
would be affected by a distillation NSPS.
Of the 169 producers of the affected chemicals for which employment
information is available, 41 are small by the definition given
133 134
above. Thus, approximately 24 percent of the producers of the 219
chemicals are estimated to be small. Because 600 plants would be affected
in the first five years., it is possible that all 41 small producers might
potentially be affected by NSPS.
However, as revealed in the screening analysis in Section 9.2, control
costs would be small given the fact that no chemical would have cost
increases equal to 5 percent or more of chemical prices in 1987. As
indicated in Section 9.2.4, even with worst-case cost assumptions, 86
percent of the chemicals would have price increases below 2 percent and 95
percent would have price increases below 3 percent. Accordingly, no plants
would have significant economic impacts under NSPS.
Since the standards would apply primarily to new sources, it is
difficult to estimate their specific effects on projects that will be
undertaken by small businesses entering the industry. In general, if a
company has the capital to enter the industry, NSPS will require only a
small percentage increase in the capital required for the project.
9.4.3 Cumulative Price Impacts from Distillation NSPS and Other Air
Standards
This section describes potential organic chemical product price
increases due to production cost increases attributable to the fifth-year
cost of eight air pollution control regulations developed since August 1977
by EPA under Sections 111 and 112 of the Clean Air Act. Section 8.3.1
9-67
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gives a full account of the cost accumulation methodology and Table 8-11
provides the total direct and rolled-through costs of these potential air
regulations for 12 chemical groups.
The costs that are accumulated are based upon a mix of reasonable and
worst-case assumptions so that price increase impacts also are not worst
case. However, for the cumulative price impacts, it is assumed that
producers pass through all effective cost increases to the users of their
products.
The price increase analysis is conducted on a chemical group basis
because new plant projections are done only for chemical groups (see Table
9-23). Total annualized costs of control for each of the potential air
regulations are based partly on these new plant projections. Table 9-23
shows the projected numbers of affected plants through 1987 for
distillation NSPS. Table 9-25 presents the average annual plant throughput
and average annual plant sales for each chemical group. Dividing sales by
throughput, an average product price, per kg for the chemical group is
calculated. This price is shown in Column A of Table 9-26.
Table 9-26 presents estimates of potential price increases in three
stages of analysis: direct costs of seven air standards; direct costs of
seven air standards plus NSPS for distillation; and direct plus
rolled-through costs of all eight standards.
For each group, direct control costs first are aggregated for seven
air regulations initiated previous to the NSPS for distillation, then are
divided by the'number of affected plants (for distillation NSPS through
1987) and average plant sizes to determine the direct control costs per
kilogram produced. The extent to which the price would increase at
affected plants if all control costs were passed through to consumers then
is calculated. Price increases would range from less than 0.05 percent of
the base price for plants in several chemical groups to 0.5 percent for
plants in the plastics and fibers group.
The second stage adds the direct control costs due to NSPS for
distillation to the direct costs of the other seven air regulations. The
addition of the distillation control costs would cause little increase in
the product price over that when costs of control for the other seven air
9-68
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TABLE 9-26. PRICE INCREASES DUE TO DIRECT AND ROLLED-THROUGH INPUT COSTS OF CONTROL
IN THE SYNTHETIC ORGANIC CHEMICAL INDUSTRY FOR EIGHT AIR EMISSION STANDARDS
12 Chemical Groups
United States
1978
I
CD
(O
Chemical group3
Intermediates for:
General aromatics
General non-aromatics
Synthetic elastomers
Plastics & .fibers
Plasticizers
Pesticides
Solvents
Detergents and surfactants
Fuel additives
Aerosol propel! ants &
refrigerants
Coatings
Miscellaneous end-use
chemicals
(A)
Average
base price
U/kg)
32
47
53
36
65
60
30
68
123
97
49
22
(B)
Accumulated
costs of other
regulations
U/kg produced)
0.09
0.04
0.05
0.18
0.24
0.14
0.01
0.19
0.03
0.07
0.03
0.01
(C)
Percentage
price
increase
0.3
0.1
0.1
0.5
0.4
0.2
0.0
0.3
0.0
0.1
0.1
0.0
(D)
Accumulated
costs including.
distillation NSPS0
U/kg produced)
0.11
0.08
0.09
0.21
0.27
0.27
0.06
0.47
0.09
0.19
0.06
0.04
(E)
Percentage
price
increase
0.3
0.2
0.2
0.6
0.4
0.5
0.2
0.7
0.1
0.2
0.1
0.2
-------
regulations are totally passed through. The largest change would occur in
the detergents and surfactants .group, where the price increase would be 0.7
percent.
The final stage is the addition of rolled-through control costs to
the direct costs of all eight air regulations. Total direct and rolled-
through costs are taken from Table 8-11. Costs for inputs are rolled
through for all eight air standards by using the ratio of rolled-through to
direct costs from the NSPS for distillation and applying this ratio to the
total direct costs for all eight standards. This ratio is different for
each group of chemicals. The plasticizers and plastics and fibers groups
would show the largest potential price increases, equal to 1.0 percent when
cumulated costs were totally rolled through.
In sum, as measured here with group average plants, distillation NSPS
will not lead to large increases in chemical prices even when VOC control
costs for distillation NSPS are added to the costs of control incurred
under other air standards.
9-70
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9.5 REFERENCES FOR CHAPTER 9
1. Jonnard, A. Cited in a memo from Farmer, J.R., EPA, to R.E.
Rosensteel, EPA. June 8, 1981. Information from the U.S.
International Trade Commission.
2. U.S. International Trade Commission. Synthetic Organic Chemicals.
United States Production and Sales, 1978. USITC Publication 1001. p.
1.' , . t. .. . '
3. Ibid. p. 1.
4. Ibid. p. 1.
5. C.H. Kline & Company. The Kline Guide to the Chemical Industry.
1980. Fairfield, New Jersey, p. 96-98.
6. Ibid. p. 9.
7. Ibid. p. 14.
8. Facts and Figures for the U.S. Chemical Industry. Chemical and Engi-
neering News. June 8, 1981. p. 44. Vol. 59. No. 23.
9. Jonnard, A. Cited in a memo from Farmer, J.R., EPA, to R.E.
Rosensteel, EPA. June 8, 1981. Information from the U.S.
International Trade Commission.
10. U.S. Department of Commerce. 1981 U.S. Industrial Outlook. January
1979. p. 103.
11. U.S. Department of Commerce. Bureau of the Census. 1977 Census of
Manufactures: Industry Series - Industrial Organic Chemicals. July
1980. p. 28F-11.
12. Facts and Figures for the U.S. Chemical Industry. Chemical and Engi-
neering News. June 9, 1980. p. 43. Vol. 58. No. 23.
13. Chemical Profitability Sagged in 1980. Chemical and Engineering News.
June 1, 1981. p. 8. Vol. 59. No. 22.
14. Facts and Figures for the U.S. Chemical Industry. Chemical and Engi-
neering News. June 9, 1980. p. 43. Vol. 58. No. 23.
15. Chemical Profitability Sagged in 1980. Chemical and Engineering News.
June 1, 1981. p. 10. Vol. 59. No. 22.
16. Facts and Figures for the U.S. Chemical Industry. Chemical and
Engineering News. June 14, 1982. p. 62. Vo. 60. No. 24.
17. Facts -and Figures for the U.S. Chemical Industry. Chemical and Engi-
neering News. June 9, 1980. p. 67. Vol. 58. No. 23.
9-71
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18. Chemical Profitability Sagged in 1980. Chemical and Engineering News.
June 1, 1981. p. 8. Vol. 59. No. 22.
19. Facts and Figures for the U.S. Chemical Industry. Chemical and Engi-
neering News. June 14, 1982. p. 43. Data are based on company
annual reports for 15 major chemical companies: Allied Chemical,
American Cyanamid, Celanese, Diamond Shamrock, Dow Chemical, DuPont,
Ethyl, Hercules, Monsanto, 01 in, Pennwalt, Rohm & Haas, Stauffer
Chemical, Union Carbide, and Williams. Vol. 60. No. 24.
20. Facts and Figures for the U.S. Chemical Industry. Chemical and Engi-
neering News. June 14, 1982. p. 43. Based on Federal Trade
Commission data. Vol. 60. No. 24.
21. Facts and Figures for the U.S. Chemical Industry. Chemical and Engi-
neering News. June 14, 1982. p. 43. Vol. 60. No. 24.
22. Chemical Capacity Sinks to 60 Percent. Chemical and Engineering News.
May 24, 1982. p. 17. Vol. 60. No. 21.
23. Facts and Figures for the U.S. Chemical Industry. Chemical and Engi-
neering News. June*14, 1982. Vol. 60. No. 24.
24. Chemical Capacity Use Remains Depressed. Chemical and Engineering
News. October 11, 1982. p. 14. Vol. 60. No. 41.
25. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. April 27,
1983. Historical chemical and energy price data.
26. Facts and Figures for the U.S. Chemical Industry. Chemical and Engi-
neering News. June 12, 1978. p. 66. Vol. 56. No. 24.
27. Facts and Figures for the U.S. Chemical Industry. Chemical and
Engineering News. June 14, 1982. p. 67-68. Vol. 60. No. 24.
28. U.S. Department of Commerce. U.S. Exports Schedule E. Commodity by
Country. FT/410 December 1978.
29. U.S. Department of Commerce. U.S. General Imports. Schedule A.
Commodity by Country. FT/135 December 1978. U.S. Imports for
Consumption and General Imports: TSUSA Commodity by Country of
Origin. FT 246. Annual 1980.
30. Outlook Dims for Decontrol of Natural Gas. Chemical and Engineering
News. February 22, 1982. p. 11-16. Vol. 60. No. 8.
31. Ibid. p. 11.
32. Ibid. p. 16.
33. Ibid. p. 11-16.
9-72
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34. Chemical Companies Seek Relief from the Burden of Feedstock Costs.
Chemical and Engineering News. December 20, 1982. p. 61. Vol. 60.
No. 51.
35. World Chemical Outlook. Chemical and Engineering News. December 22,
1980. p. 33. Vol. 58. No. 51.
36. Kridl, A.G. and R.G. Muller. Relative Industrial Economics, U.S.A.
vs. EEC During the 1980s. Chemical Industries Division Newsletter.
SRI International. September-October 1981. p. 1.
37. Trade Fact Poll: The "Ayes" Have It. Chemical Week. June 13, 1979.
p. 16-17. Also Cappuccilli, E., U.S. International Trade Commission.
Personal communication with J. Viola, EEA, Inc. January 20, 1983.
Tariffs for organic chemicals.
38. Trade Fact Poll: The "Ayes" Have It. Chemical Week. June 13, 1979.
p. 16-17. Also Cappuccilli, E., U.S. International Trade Commission.
Personal communication with J. Viola, EEA, Inc. January 20, 1-983.
Tariffs for organic chemicals.
39. Cappuccilli, E. U.S. International Trade Commission. Personal
communication with J. Viola, EEA, Inc. January 20, 1983. Tariffs for
organic chemicals.
40. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. March 21,
1983. Sources and values of data used in the economic screening for
organic chemicals in the BID for Distillation NSPS.
41. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. April 27,
1983. Supplemental data for the screening analysis. Part 1.
42. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. April 27,
1983. Supplemental data for the screening analysis. Part 2.
43. C.H. Kline & Company. The Kline Guide to the Chemical Industry.
1980. Fairfield, New Jersey, p. 98.
44. U.S. International Trade Commission. Synthetic Organic Chemicals.
United States Production and Sales, 1978. USITC Publication 10001.
p. 14.
45. Gasoline to Trigger Aromatics Shortage. Chemical and Engineering
News. May 18, 1981. p. 16. Vol. 59. No. 20.
46. C.H. Kline & Company. The Kline Guide to the Chemical Industry.
1980. Fairfield, New Jersey, p. 98.
47. Slow Recovery Begins for Petrochemicals. Chemical and Engineering
News. November 17, 1980. p. 15. Vol. 58. No. 46.
48. Ibid. p. 16.
9-73
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49. How *ill They Feed Ethylene Plants of the 1990's. Chemical Business.
October 20, 1980. p. 20. Part Two of Chemical Marketing Reporter.
Vol. 218. No. 16.
50. Ethylene Feedstocks: An End to Light Ends. Chemical Business. June
29, 1981. p. 19-26. Part Two of Chemical Marketing Reporter. Vol.
219. No. 26.
51. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. March 21,
1983. Sources and values of data used in the economic screening for
organic chemicals in the BID for Distillation NSPS.
52. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. April 27,
1983. Supplemental data for the screening analysis. Part 1.
53. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. April 27,
1983. Supplemental data for the screening analysis. Part 2.
54. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. March 21,
1983. Sources and values of data used in the economic screening for
organic chemicals in the BID for Distillation NSPS.
55. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. April 27,
1983. Supplemental data for the screening analysis. Part 1. . ,
56. Viola, il. EEA Inc. Memo to the Distillation NSPS Docket. April 27,
1983. Supplemental data for the screening analysis. Part 2.
57. C.H. Kline & Company. The Kline Guide to the Chemical Industry.
1980. Fairfield, New Jersey. Table 3-17.
58. Chemical Profile. SB Rubber Chemical Marketing Reporter. January 14,
1980. p. 9.
59. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. March 21,
1983. Sources and values of data used in the economic screening for
organic chemicals in the BID for Distillation NSPS.
60. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. April 27,
1983. Supplemental data for the screening analysis. Part 1.
61. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. April 27,
1983. Supplemental data for the screening analysis. Part 2.
62. C.H. Kline & Company. The Kline Guide to the Chemical Industry.
1980. Fairfield, New Jersey, p. 168.
63. Ibid. p. 168.
64. Ibid. p. 174.
65. Ibid. p. 319.
9-74
-------
66. Chemical Profile. PVC. Chemical Marketing Reporter. March 10, 1980.
p. 9, 18.
67. C.H. Kline & Company. The Kline Guide to the Chemical Industry.
1980. Fairfield, New Jersey, p. 153.
68. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. March 21,
1983. Sources and values of data used in the economic screening for
organic chemicals in the BID for Distillation NSPS.
69. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. April 27,
1983. Supplemental data for the screening analysis. Part 1.
70. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. April 27,
1983. Supplemental data for the screening analysis. Part 2.
71., Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. March 21,
1983. Sources and values of data used in the economic screening for
organic chemicals in the BID for Distillation NSPS.
72. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. April 27,
1983. Supplemental data for the screening analysis. Part 1.
73. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. April 27,
1983. Supplemental data for the screening analysis. Part 2.
74. Pesticides Due for Slow Growth. Chemical and Engineering News.
February 27, 1978. p. 7. Vol. 56. No. 9.
75. Ibid. p. 7.
76. U.S. International Trade Commission. Synthetic Organic Chemicals.
United States Production and Sales, 1978. USITC Publication 1001.
77. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. March 21,
1983. Sources and values of data used in the economic screening for
organic chemicals in the BID for Distillation NSPS.
78. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. April 27,
1983. Supplemental data for the screening analysis. Part 1.
79. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. April 27,
1983. Supplemental data for the screening analysis. Part 2.
80. C.H. Kline & Company. The Kline Guide to the Chemical Industry.
1980. Fairfield, New Jersey, p. 285.
81. Hurley, E. EEA Inc. Memo to T. Desai, EEA Inc. January 22, 1982.
Methodology and results for projecting new and replacement facilities
in the SOCMI.
9-75
-------
82. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. March 21,
1983. Sources and values of data used in the economic screening for
organic chemicals in the BID for Distillation NSPS.
83. Viola, 0. EEA Inc. Memo to the Distillation NSPS Docket. April 27,
1983. Supplemental data for the screening analysis. Part 1.
84. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. April 27,
1983. Supplemental data for the screening analysis. Part 2.
85. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. March 21,
1983. Sources and values of data used in the economic screening for
organic chemicals in the BID for Distillation NSPS.
86. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. April 27,
1983. Supplemental data for the screening analysis. Part 1.
87. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. April 27,
1983. Supplemental data for the screening analysis. Part 2.
88. Surfactants Face Slow-Growing Market. Chemical and Engineering News.
May 22, 1978. p. 12. Vol. 56. No. 21.
89. C.H. Kline & Company. The Kline Guide to the Chemical Industry.
1980. Fairfield, New Jersey, p. 298.
90. Ibid. p. 305.
91. Viola, 0. EEA Inc. Memo to the Distillation NSPS Docket. March 21,
1983. Sources and values of data used in the economic screening for
organic chemicals in the BID for Distillation NSPS.
92. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. April 27,
1983. Supplemental data for the screening analysis. Part 1.
93. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. April 27,
1983. Supplemental data for the screening analysis. Part 2.
94. Mannsville Chemical Products. Methyl Tertiary-Butyl Ether. Chemical
Products Synopsis. 1982. Cortland, New York.
95. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. March 21,
1983. Sources and values of data used in the economic screening for
organic chemicals in the BID for Distillation NSPS.
96. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. April 27,
1983. Supplemental data for the screening analysis. Part 1.
97. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. April 27,
1983. Supplemental data for the screening analysis. Part 2.
98. C.H. Kline & Company. The Kline Guide to the Chemical Industry.
1980. Fairfield, New Jersey, p. 270.
9-76
-------
99. Production of Aerosols Begins to Rise Again. Chemical and Engineering
News. May 21, 1979. p. 5. Vol. 57. . No. 21.
100. C.H. Kline & Company. The Kline Guide to the Chemical Industry.
1980. Fair-field, New Jersey, p. 271.
101. Ibid.
102. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. March 21,
1983. Sources and values of data used in the economic screening for
organic chemicals in the BID for Distillation NSPS.
103. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. April 27,
1983. Supplemental data for the screening analysis. Part 1.
104. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. April 27,
1983. Supplemental data for the screening analysis. Part 2.
105. Annual Refining Survey. Oil and Gas Journal. March 20, 1978. p.
113. Vol. 76. No. 12.
106. Annual Refining Survey. Oil and Gas Journal,
127. Vol. 77. No. 13.
107. Annual Refining Survey. Oil and Gas Journal
135. Vol. 78. No. 12.
108. Annual Refining Survey. Oil and Gas Journal
112. Vol. 79. No. 13.
109. Annual Refining Survey. Oil and Gas Journal
130. Vol. 80. No. 12.
March 26, 1979. p.
March 24, 1980. p.
March 30, 1982. p.
March 22, 1982. p.
110. Erosion of U.S. Refining Capacity Shows Up. Oil and Gas Journal.
March 22, 1982. p. 79-81. Vol. 80. No. 12.
111. U.S. Department of Energy. Energy Information Administration.
Petroleum Supply Annual 1981. Volume I. July 1982. DOE/EIA-0340
112. Corporate Scoreboard. Business Week. March 15, 1982. Issue No.
2730.
113. The 500 Largest Industrial Corporations. Fortune. May 4, 1981. Vol.
103. No. 9.
114. Hurley, E. EEA Inc. Memo to T. Desai , EEA Inc. January 22, 1982.
Methodology and results for project! no new and replacement facilities
in the SOCMI.
115. Schell, A. Chemical Marketing Reporter. Personal communication with
J. Viola, Energv. and Environmental Analysis, Inc. September 30, 1982.
9-77
-------
116. Facts and Figures for the U.S. Chemical Industry. Chemical and Engi-
neering News. June 9, 1980. Vol. 58. No. 23.
117. U.S. Environmental Protection Agency. Office of Air Quality Planning
and Standards. Air Oxidation Processes in Synthetic Organic Chemical
Manufacturing Industry — Background Information for Proposed
Standards. January 1982. EPA-450/3-82-001a.
118.' Chemical Engineering. Semiannual Inventory of New Plants and
Facilities. April 15, 1963.
119. Chemical Engineering. Semiannual Inventory of New Plants and
Facilities. October 28, 1963.
120. Chemical Engineering. Semiannual Inventory of New Plants and
Facilities. April 27, 1964.
121. Chemical Engineering. New Plants and Facilities. October 26, 1964.
122. Chemical Engineering. New Plants and Facilities. April 26, 1965.
123. Chemical Engineering. New Plants and Facilities. October 11, 1965.
124. Chemical Engineering. New Plants and Facilities. April 25, 1966.
125. Chemical Engineering. New Plants and Facilities. October 24, 1966.
126. Chemical Engineering. New Plants and Facilities. April 10, 1967.
127. Chemical Engineering. New Plants and Facilities. October 9, 1967.
128. Facts and Figures for the Chemical Industry. Chemical and Engineering
News. June 14, 1982. p. 42. Vol. 60. No. 24.
129. Stelling, J. Radian Corp. Memo to Beck, D., EPArCPB, and Bell, D.,
EPArSDB. August 26, 1982. Distillation operations regulatory
analysis using 98 percent flares. 20 p.
130. U.S. Department of Commerce. Bureau of the Census. 1977 Census of
Manufactures: Industry Series - Industrial Organic Chemicals. July
1980. p. 28F-11.
131. Robert Morris Associates. Annual Statement Studies. 1980.
Philadelphia, Pennsylvania.
132. U.S. Small Business Administration. Small Business Size Standards.
Federal Register. July 15, 1980. 45 FR 47415.
133. Dun & Bradstreet. Million Dollar Directory. 1981.
134. Viola, J. EEA Inc. April 27, 1983. Memo to the Distillation NSPS
Docket. Business size data.
9-78
-------
APPENDIX A
EVOLUTION OF THE PROPOSED STANDARD
-------
-------
APPENDIX A
EVOLUTION OF THE PROPOSED STANDARD
This study was undertaken to develop new source performance standards
(NSPS) for distillation unit operations in the organic chemical manufacturing
industry. Work on the study was begun in September 1979 by Energy and
Environmental Analysis, Inc., under the direction of the Office of Air
Quality Planning and Standards (OAQPS), Emission Standards and Engineering
Division (ESED). The decision to develop this standard was made on the
recommendation of EPA in conformity with its policy to develop generic
standards for the organic chemical manufacturing industry.
The chronology which follows lists the important events which have
occurred in the development of background information for the new source
performance for distillation unit operations in the organic chemical
manufacturing industry.
A-l
-------
September 12, 1979
March 25, 1980
April 15, 1980
June 3, 1980
June 1980
June 1980
September 1980
September 18, 1980
September 1980
October 1980
November 1980
November 1980
November 1980
December 18, 1980
Letter from A. Miles, EEA, to L.Evans, EPA
assessing the Hydroscience draft vacuum
systems emission projections document and
the desirability of developing a generic
for control of emissions from vacuum systems.
Review report on Hydroscience vacuum systems
emission projections document delivered to
EPA.
Concurrence memorandum on NSPS Development for
the vacuum Unit operations in synthetic
organic chemical manufacturing industry
(SOCMI) finalized.
Concurrence memorandum on Change of Scope
of NSPS development for vacuum unit
Operations finalized.
Development of data profile initiated.
Work pi an approved by EPA.
Draft impact criteria and screening
work pi an for economic analysis delivered
to EPA.
Meeting with EEA, EPA, and CMA to discuss
the approach taken for the development
of a standard for distillation operations
for SOCMI.
Work initiated to designate chemicals
as product/byproduct.
Plant visit to Air Products and Chemicals
Inc., Pensacola, Florida.
Plant visit to Allemania Chemicals in
Plaquemine, Louisiana.
Plant visit to Dow Chemicals in
Freeport, Texas.
Preliminary costing done for the control
of worst case emissions.
Meeting held between EEA and EPA to discuss
modifying the Radian list of chemicals
representing SOCMI.
A-2
-------
January 12, 1981
January 1981
February 8, 1981
February 10, 1981
February 1981
April 7, 1981
April 21, 1981
May 28, 1981
June 1, 1981
June 10, 1981
June 1981
July 1981
August 6, 1981
September 2, 1981
Meeting held between EEA and EPA to discuss
EEA's recommendation for redefining
the scope of the distillation NSPS.
Results of first economic impact screening
analysis presented to EPA.
Meeting held between EEA and EPA to discuss '
production and plant capacity cutoffs.
Concurrence memorandum on redefining the
scope of NSPS distillation finalized.
Work completed on an evaluation of the
cost to control worst case emissions in
an incinerator.
Meeting with EEA, CMA, API, SOCMA, and
EPA to discuss the change in scope of the
project and the new approach to development
of the regulation.
Meeting held between EEA and EPA to discuss
what baseline emission control should be
used in the regulatory analysis.
Meeting with EEA and EPA to discuss methods
used in the regulatory analysis.
Meeting held between EEA and EPA to discuss
modifying the scope of the distillation
project.
Meeting with EEA and EPA to decide on a new
production capacity cutoff.
Work begun on the preparation of Chapters 3,
4, and 5 of the BID.
Memorandum for defining the regulatory
alternatives and the rationale for baseline
control delivered to EPA.
Meeting held between EEA and EPA to discuss
the regulatory analysis.
Meeting held between EEA and EPA to discuss
the regulatory analysis, national emission
profile, and economic affordability analysis.
A-3
-------
September 24, 1981
October 30, 1981
November 17, 1981
December 3, 1981
December 1981
December 1981
January 13, 1982
February 11, 1982
February 17, 1982
February 23, 1982
February 1982
February 1982
March 1982
April 1982
Meeting held between EEA and EPA to
discuss the economic affordability analysis.
Concurrence memorandum on the Chemicals
Subject to the Distillation NSPS finalized.
Plant visit to Allied Chemical in
Frankford, Pennsylvania.
Meeting held between EEA and EPA to discuss
combustion control devices and the regulatory
analysis methodology.
Memorandum comparing costs of various
control devices prepared.
BID Chapters 3,4,5, and 6 mailed out to
industry.
Meeting held between EEA and EPA to discuss
BID Appendix D and the flow cutoff point.
Meeting between EEA and EPA to discuss the
definition of an affected facility.
Meeting between EEA and EPA to discuss
boiler performance tests.
Meeting between EEA and EPA to discuss
the results of the regulatory analysis.
Revised worst case to control model is
developed and 'control costs estimated
for 15 chemicals provided by EAB.
Concurrence memorandum on the Basis for the
Standard to Regulate VOC Emissions from
Organic Chemical Plant Distillation
Operations finalized.
Economic analysis completed.
Working Group package submitted to ESED.
A-4
-------
June 7, 1982 NAPCTAC package submitted to ESED.
June 7, 1982 Docket opened in Washington, D.C.
July 21-22, 1982 NAPCTAC meeting.
July 29, 1982 Meeting to discuss issues raised at
NAPCTAC meeting.
A-5
-------
-------
APPENDIX B
INDEX TO ENVIRONMENTAL CONSIDERATIONS
-------
-------
APPENDIX B
INDEX TO ENVIRONMENTAL CONSIDERATIONS
This appendix consists of a reference system which is cross indexed
with the October 21, 1974 Federal Register (39 FR3.7419) containing EPA
guidelines for the preparation of Environmental Impact Statements. This
index can be used to identify sections of the document which contain
data and information germane to any portion of the Federal Register
guidelines.
B-l
-------
APPENDIX B
INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
Agency Guidelines for Preparing
Regulatory Action Environmental
Impact Statements (39 FR 37419)
Location Within the Background
Information Document (BID)
1. Background and Description
of proposed Action
Summary of Regulatory
Alternatives
Statutory basis for the
Standard
Facilities Affected
Process Affected
Availability of Control
Technology
Existing Regulations at
State or Local Level
2. Alternatives to the Proposed
Action
Description of range of
alternatives
A range of regulatory alternative
control levels is discussed in
Section 6.1.
The statutory basis for the
standard is given in Chapter 1,
Section 1.1.
A description of the facilities to
be affected is given in Chapter 6.
A description of the processes to
be affected is given in Chapter 3,
Section 3.3.
Information on the availability
of control technology is given in
Chapter 4.
A dscussion of existing regulations
on the industry to be affected by
the standards is included in
Chapter 3, Section 3.5.
The' definition of the available
control range is presented in
Chapter 6, Section 6.1.
B-2
-------
APPENDIX B
INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
(CONTINUED)
Agency Guidelines for Preparing
Regulatory Action Environmental
Impact Statements (39 FR 37419)
Location Within the Background
Information Document (BID)
Environmental Impacts
Air Pollution,
Water .Pollution
Solid Waste Disposal
Energy
Other Impacts
Costs
The air pollution impact of the
control alternatives are considered
in Chapter 7, Section 7.1.
The impact of the control alterna-
tives on water pollution are
considered in Chapter 7, Section 7.2,
The impact of the control alterna-
tives on solid waste disposal are
considered in Chapter 7, Section 7.3,
The impact of the control alterna-
tives on energy use are considered
in Chapter 7, Section 7.4.
Other impacts associated with the
control alternatives are evaluated
in Chapter 7, Sections 7.5 and 7.6,
The impact of the control alterna-
tives on costs are considered in
Chapter 8, Section 8.2.
B-3
-------
-------
APPENDIX C
NATIONAL EMISSIONS PROFILE
-------
-------
APPENDIX C
NATIONAL EMISSIONS PROFILE
The purpose of this appendix is to present the emissions data base
gathered for the distillation NSPS. All emissions data collected are
listed with appropriate reference to the source of the-data. Those
units used in the regulatory analysis are identified.
C-l
-------
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TYPE SCFH SCF LB/HR XVOC XC ZN ZH ZO XCL
FLH 000.000 0000 0000.000 000.00 000.00 000.00 000.00 000.00 000.00
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FRC 000.000 0000 0000 000 000 00 000 00 000 00 000 00 —000 OS — 000 00
FRC 999.999 9999 9999.999 999.99 999.79 999.99 999.99. 999.99 999.99
FRC 50.000 0004 0001.100 000.30 000.30 091.80 005.30 002.50 000.00
_FRC— 000.000— 0000— 0000.000—000,06— 000,00-000.00-000^0— 000,00-060,00
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FRC 999.999 9999 9999.999 999.99 999.97 999.W 999.97 999.W 977.99
-FRC— 358.000— 033 3— 0373.000— 011,40- 030.70~000,8»-028,60— 03»,30-000,00
FRC 575.000 0380 0600.000 011.60 030.90 000.80. 028.60 039.30 000.00
FRC 1.450 0903 0001.600 010.00 021.60 003.90 069.80 004.70 000.00
_FRC 0.180—0207—0000.080—006,20—008.20-040,70—034.40—014,50-000,00
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EQUP CHTL HO&E TYPE SCFH SCF Lt/HR ZVOC ZC ZH ZH ZO
CON
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ATM CHT FRC 41.700 0072 0024.300 002.50 004.10 044.10 011.70 018.10
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ATM CHT FRC 22.701 18 15.000 0.50 1.40 96.30 2.30 0.0
ATM.. CHT— £RC— SJ?»99SL— SSS9— ?999»?9?.~9y9,9?— ^99,99— 997,79 — 997,99 — 999.99
ATM CHT FRC 999.997 9999 9999.999 999.99 999.97 999.99 999.99 999.99
NOH CHT FRC 000.000 OOOO 0000.000 000.00 000.00 000.00 000.00 000.00
ATH. CHT FRC _7JOO, J)177_0002.000_003.40— 002.60— 075.30-001,40-020.20
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ATH CHT FLH 1.800 0451 0008.100 021.10 032.70 035.90 021.80 009.50
ATH_CNI_fRC 2^00—0042- 0001.300-002.00— 005.70-072.70-003.80—017.80
HON CNT FRC 000.000 OOOO 0000.000 000.00 000.00 000.00 000.00 000.00
NOH CHT FRC 000.000 OOOO 0000.000 000.00 000.00 000.00 000.00 000.00
ATM , CNT_,FRC. _. 4.500^-9999_0004.200—004.00— 999.99-999,99— 999.99— 999.99
ATH CNT FRC 8.400 ; 0234 0013.000 030.80 009.50 043.10 037.90 009.50
ATH CNT FRC 54.400 0047 0017.000 004.10 002.70 083.40 011.00 002.70
ATH , CNTUFRC 8^00— 0047— 0002,200— 004.40— 002.90— 082,40— 014.40—002.9^ -
ATH! CNT FRC 4.200 0180 0005.000 023.50 008.00 052.00 032.00 008.00
ATH CNT FRC 123.800 0768 0428.200 100.00 014.70 000.00 044.60 016.70
CON ATM I HUT FftP 15.DOQ_05ai_Jlttl2J)00_01SJO_006.00_JJA4J)a— 024.00— 004.00
CON
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ATH CNT FRC 176.000 0047 0057.000 004.40 002.80 083.00 011.30 002.90
ATH[ CHT FRC 15.000 0047 0005.000 006.40 002.90 082.40 011.40 002.90
IMP f TNT FRP 781 O'OO 07Afl 142A O'OO— 100 00 Olt^i70 -QOO-w^O QAfi.OQ 016^70 -*•
ATM CHT FRC 7.000 OOOO 0010.000 999.99 999.99 999.99 999.99 999.99
RCL CHT FRC 000.000 OOOO 0000.000 000.00 000.00 000.00 000.00 000.00
ATM_CHI_ FRC— lZw400__1282-.0120JOO~400^)0— 021 .90—000.00—044.80—013.30 -
ATH CNT FRC 79.300 1453 0401.000 100.00 023.10 000.00 044.30 012.40
NOH CNT FRC 000.000 OOOO 0000.000 000.00 000.00 000.00 .000.00 000.00
. CON. .ATH ,_CNT_FRC 0.300— 4978— 0004.900— 100.00— 044.40—000.00 -055.40—000.00
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ATM1: CNT FRC 19.500 OOOO 0000.000 000. OQi '000.00! iW.OO 000.00 " 021.00
ATHf-CHTr FRC — 27.200-49 5.400- 1.80^-4,00^71,20 12^80— 12^,00 '
ATH i: CHT FRC 219.800 45 454.000 1.60 3.00: 85.30 7.60 ' 4.10
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ATH; CNT FRC« 0.700 0680 0000.400 014.70 020.20: -014.30 054.40 008.90
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0000 0000.000 000.00 000.00 000.00 000.00 ''000.00
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9999 9999.999 999.99 999.99 997.97 999.99 997.99
000.00
000.00
000.00
000.00
000.00
_000.00
000.00
000.00
. 000.00
000.00
999.99
..016.30.
013.30
000.30
999*99
000.00
009.30
. 025.00
004,40
020.00
. 020.00
025.00
025.00
000.00
000.00
979.7?
.599.99.
999.99
000,00
000.00
000.00
999.9?
-999.99
999.99
000.00
000.00
999.99
000.00
000.00
000.00
000.00
999.7?
000.00
000.00
000.00
000.00
799.99
000.00
000.00
000.00
000.00
000.00
000.00
999.99
997.79
000.00
000.00
999.99
ATOM SCR REF
NUMB NEP NO
99.997
-00.000
00.000
00.000
00.000
00.000
00.000
00.000
00.000
00.000
00.000
00.000
99.99?
- 3.125
3.934
2.023
-99.79?
00.000
2.885
5.000
2.306
5.000
5.000
8.000
8.000
-00.000
00.000
99.999
99.779
99.979
00.000
00.000
2.000
99.799
99.999
99.997
00.000
00.000
99.999
00.000
00.000
00.000
00.000
9?.?99
00.000
00.000
00.000
2.000
79.779
00.000
00.000
00.000
00.000
00.000
00.000
??.99?
??.999
00.000
2.000
99.999
145,146,173
174
175
176,177,178
X 49,50,51
128,127,179
X 52
179,180,181
34,35,182
X 11,12,53
183
184,185,186
187
15,16,183
34,35
184,185,18?
170
54,1?1,1?2,1?3
54, 174,175, 196
54,197,178
X 54
54,84,85
17?
200,201,202
. 55,56,57
-------
CH
f HFR
51 DP
52 AC
52 PP
52 RH
53 SB
" 54 DB
55 USS
56 USS
57 AH
57 AH
58 AH
58 DE
58 DE
58 KQ
'58 HNS
58 USS
• 58 USS
" 58 RCHD
59 EX
i 60 AP
.: 60 CE
60 CE
60 HP
60 ALE
60 ALE
L 60 HNS
i £"}
i 61 LCP
00 .62 S
62 S
62 UC
63 HF
64 HF
65 DP
• 65 DP
65 DP
65 DP
65 RH
" " '65 " RH
M 65 RH
65 RH
• 65 RH
65 CYRO
• 65 CYRO
' 65 CYRO
65 CYRO
65 CYRQ
65 CYRO
66 USS
1 66 USS
66 CHEV
67 DB
68 RU
": 7 68 MDB
'69 BASF
69 BASF
i 70 DS
:i 1 70 DS
'1 70 DS
= 70 'DS
PLOT
LOCK
VTX
FOU
ITX
BPTX
FTX
"FTX
raw
HOH
JIL
JIL
JIL
HTX
HTX
BPA
SLHO
NPA
NIPA
'MIL
BNJ
PFL
BITX
BITX
PFL
PLA
PLA
fCTX
GLA
MUV
DPTX
DPTX
IUV
UNC
UNC
HTN
HTN
HTN
HTN
DPTX
DPTX
DPTX
DPTX
DPTX
ALA
ALA
ALA
ALA
ALA
ALA
HOH
HOH
RCA
FTX
GLA
PPA
GLA
GLA
DPTX
DPTX
DPTX
DPTX
HO
COL
1
1
*1
5
1
i
i
4
1
1
3
' i"
i
i
i
i
i
"" i
i
i
i
3
1
1
1
2
2
1
1
1
2
1
i
i
i
- 2
2
1
1
1
1
1
1
1
i
i
i
i
2
2
i
1
1
1
3
2
1
1
2
1
COL
cm
w
w
HV
HV
HV
HV
V
V
HV
HV
V
HV
V
V
V
NV
V
V
HV
NV
NV
HV
NV
NV
HV
HV
NV
NV
NV
NV
NV
V
" V
NV
NV
NV
V
• V
V
NV
V
NV
NV
NV
HV
HV
V
V
HV
HV
V
HV
NV
V
NV
V
NV
NV
V
NV
TK
EOUP
SCR
COH
CON
COH
COH
COH
COH
CON
COH
CON
COM
COH
COH
SCB
CON
COH
COH
SCB
CON
CON
CON
COH
CON
CON
CON
CON
CON
CON
CON
CON
CON
CON
CON
CON
CON
CON
ABS
CON
CON
CON
CON
CON
CON
CON
CON
CON
CON
CON
CON
CON
CON
CON
SCB
COH
CON
CON
CON
CON
SCB
CON
FIHt
CHTU
ATH
FUR
FLR
FUR
ROM
RCL
ATH
ATM
ATH
ATH
ATH
ATH
ATH
ATH
RCL
NON
ATH
ATH
NON
BLR
NON
RCL
NOH
BLR
NON
BLR
RCL
RCL
FLR
FLR
NOH
RCL
RCL
ATH
ATH
ATH
ATH
FLR
FLR
FLR
ATH
ATM
RCL
ATM
ATH
NON
ATH
ATM
ATH
ATM
INC
NON
ATH
ATH
FLR
ATH
ATH
ATH:
ATM
ATM:
v?(i
WD€
CHT
ChT
CHT
CHT
CHT
CHT
CHT
CHT
CHT
BTH
CNT
CHT
BTH
CNT
CHT
BTH
BTH
CHT
CHT
"CHT
CHT
BlSf FLQU BTU/ JQC
TYPE btTK SCF U/HR ZVOC ZC ZH ZH ZQ
HfcC 999.999 9997 9997.999 9?9.99 999.99 797.99 999.97 9f9.79
FRC 999.997 9999 9999.791. 999.99 999.99 999.99 999,99 999.99
FRC 799.999 9999 9999.999 999.79 799.77 799.99 797.99 999.97
FRC 999.999 9999 7999.997 999.99 799.79 799.79 977.99 799.99
FRC 000.000 OOOO OOOO.QOO 0,.90_JW.OO_ ,QO.Q.QO_JHK>.QO_000.00
FRC 000.000 OOOO 0000.000 000.00 000.00 000.00 000.00 000.00
FRC 999.999 9999 9999.979 799.97 799.9? 9T7.79 977.97 999.99
FRC 797.77? 9999 9997.99?_?99,t?_99?.9i ,9J?W?_9?9.?7._97?.?9-
FRC 637.000 0019 0123.000 002.00 001.90 092.40 003.80 001.70
FRC 997.7?? 9999 9999.99? 999.9? 997.77 ?9?.?9 999.99 999.99
FRC 0.200 OOOO 0000.000 OOO.OQ 09
-------
r
' CH
*
70
i 70-
70
70
MFR
DS
PLNT
LOCN
DPTX
VU— BLft-
VU HKS
ETH
70--ETH
70
70
•*»*
71
71
-.- — 71
71
71
71
71
• - 71
-71-
72
• 72
72
• 72
*— -72
72
72
72
O ?3
' 74
- 74
•74
74
74
i 74
I 75
.. — 75
75
75
~?— 75
75
75
I 75
• 75
75
i : ,'75
i 75
• 76
-' — 76
76
• 76
•---• -76
77
-:- • 77
-,.„.- 77
78
: 78
-— 7?
7?
1 79
IT— -80
: 80
ETH
PPG
uuc
- nNa
HNS
HNS
-USS
USS
USS
-USS
USS
CHEV
CHEV
KO
KO
KQ
KD
HNS
-STP
STP
USS
BASF
UC
NP
NP
PN
BFG
HBL
ARCO
AM
AM
AH
HNS
HNS
SUN
SUN
ELPP
ELPP
GULF
GULF
GULF
AM
DP
DP
SCE
SCE
RU
HOB
BASF
PPG
PPG
ETN
ETN
PPG
DP
ALL
BRLA
BRLA
BRLA
LCLA
ATV
ATX
ATX
ATX
HOH
HOH
HOH
HQH
HOH
RCA
RCA
CIL
CIL
Clk
BPA
TCTX
ELIL
ELIL
NIPA
KNJ
IHV
MIL
MIL
STX
CCKY
BTX
CVTX
TCTX
TCTX
TCTX
TCTX
TCTX
CCTX
CCTX
ODTX
ODTX
STLA
SJLA
SJLA-
DAL
CFNC
OHTN
CSC
CSC
GLA
NMWV
GLA
LCLA
LCLA
BRLA
BRLA
LCLA
CHNJ
OIL
NO
COL
1
— t
1
3
-2
1
4
1
2
1
4
1
1
2
2
3
1
1
1
1
2
1
1
i
2
1
1
1
2
2
2
2
1
-1
2
2
3
1
3
2
2
1
1
1
1
1
1
1
1
3
4
6
6
1
1
1
5
2
1
COL
CND
NV
PR FINL OPR BIST FLOW BTU/ VOC :
EQUP CNTL MODE TYPE SCFH SCF LB/HR ZVOC ZC ZN ZH ZQ
CON
— NV— OIK—
NV CON
NV
-tf
NV
NV
Ull
'Nv
NV
V
V
NV
NV
V
NV
NV
V
V
V
-- y
V
V
V
V
V
V
NV
NV
- NV-
NV
NV
NV
NV
V
V
V
V
V
NV
V
V
NV
V
V
V
NV
NV
NV.
NV
NV
V
V
V
NV
NV
NV
NV
NV
NV
NV
CON
ATH CNT FRC 0.200 777? 7779.799 999.99 997.77 999. 99 997.7? ???.??
ZCL
77?
-NON — CNT FRC 000.000 — 0000 0000:000 — 000.00 — OOO.OO 000.00 000.00 OOO.'OO wu
NON CNT FRC 000.000 0000 0000.000 000.00 000.00 000.00 000.00 000.00 000
NON CNT FRC 000.000 0000 0000.000 000.00 000.00 000.00 000.00 OOO.OO
eflH--NOH--CNT—F(W-OOOiOOO— 0000-0000:000— 000;00—OOOvOO-t)00-."00— 000700 "000;00
CON
CON
nniLi
WIN •
CON
CON
CON
CON
CON
CON
CON
CON
CON-
CON
RCL CNT FRC 000.000 0000 0000.000 000.00 000.00 000.00 000.00 000.00
NON CNT FRC 000.000 0000 0000.000 000.00 000.00 000.00 000.00 000.00
ATM -CNT -FRC — 979i7?9 9999 9779.797 777:77 777^7? "777.77 777C7? 777.7?
RCL CNT FRC 000.000 0000 0000.000 000.00 000.00 000.00 000.00 000.00
ATM CNT FRC 777.77? 7999 9777.977 ???.?? 779.99 999.99 777.99 977.99
ATM CNT— FR6— 97Vs9?9— 799?-7777;?79— 97?:99-979;??-7?7;77~7??;7? 777.7?
ATM CNT FRC ?99.?99 9999 9797.77? ???.?? 799.99 997.7? ???.?? 777.7?
ATH CNT FLH 797.799 977? 7777.777 ???.?? 977.7? ???.?? ???.?? 777.79
ATM-CNT—FRE- 79?;?9?~7?97— 7979^77— 977:77— ??7;?9~1»99777—7?7;?9-79?;97
ATH CNT FRC 999.797 9779 777? .777 77?.?? 977.7? 799.7? 777.9? 977.7?
NON CNT FRC 000.000 0000 0000.000 000.00 000.00 000.00 000.00 000.00
INC -CNT-- FRC— 979:979— 7777— 7797;777—779i;7?~7?77?9—7??r7? — 99?;7r "???."??
INC CNT FLN 0.500 3602 0011.500 100.00 053.30 000.00 026.70 020.00
CON INC CNT FRC 9.500 0490 0042.700 019.20 034.10:027.30 017.00 017.60
-CON- -ING CNT FRC" 13:200" "0777 — 00847100"" 027.20-: 039.30 025.70 019.60 015.W
CON NON CNT FRC 000.000 0000 0000.000 000.00 000.00 000.00 000.00 000.00
CON
CON
CON
CON
CON •
CON
CON
CON
CON
CON
CON
CON
CON
CON ~
CON
CON
•CON
CON
CON
CON
CON"
CON
CON
CON
ABS
CON
CON
SCB
CON
CON
CON
SCB,
CON
ABS
CON
CON
CON
CON
CON
INC CNT FRC 27.000 505 100.000 17.70 2?i.50 14.70 42.00 13.80
ATH -CNT FRC - "2:400 '-260' ' "4;000 26.70 17.70 50.00 7.80 20.50
ATH CNT FRC 17.700 69 8.000 1.90 6.80 69.00 3.40 20.80
INC BTN FRC 25.500 0494 0082.000 013.70 029.00 037.00 014.50 019.50
INC-CNT - FRC -??9:99?~7?97—7779;779— 7777??— 777:7?— ??9;79— 779;??— 777.77
NON CNT FRC 000.000 0000 0000.000 000.00 000.00 000.00 000.00 000.00
NON CNT FRC 000.000 0000 0000.000 000.00 000.00 000.00 000.00 000.00
RCL - CNT— FRC- OOOiOOO— 0000—0000;00»~ 000:00" 000;00"000:00— 000;00" -Q00;00
NON CNT FRC 000.000 0000 0000.000 000.00 000.00 000.00 000.00. 000.00
NON CNT » FRC 000.000 0000 0000.000 000.00: 000.00 000.00 000.00 000.00
NON -CNT*FRC;— 000;000 0000 0000:000- OOOvOO 000; 00 000.00 000700" XJOOiOO
NON CNTi FRC 000.000 0000 0000.000 000.00 000.00 000.00 000.00 000.00
RCL CNT FRC 000.000 0000. 0000.000 000.00 000.00 000.00 000.00 000.00
NON CNT^-FRC— OOOiOOO-:0000 -0000:000— 000^)0-000^00~OOa;dO— 000.00 '"000.00
ATH CNTiFRC 777.799 9999 999?.??? 999.99 997.7? ???.?? 79?.?? 777.99
RCL CNT>";FRC ooo.ooo oooo oooo.ooo ooo.oo ooo.oo ooo.oo ooo.oo ooo.oo
RCL CNTl'FRC-000:000-0000-0000.000--000;00"000.00" ~000;00" 000.00 "-000.00
NON CNT- FRC 000.000 0000 0000.000 000.00 000.00 000.00 000.00 000.00
ATM CNT FRC 999.999 9997 977?.??? ???.?? 997.99 999.99 977.9? 7T7.79
FLR CNT-fRC- 77?;?99 799?' 977?;?77-- 777:97* 777;?? -???;?7 -???.?? 777.??
NON CNT:' FRC 000.000 0000 0000.000 000.00 000.00 000.00 000.00 000.00
ATH CNT FRC 997.799 9799 9799.77? 999.9? 997.99 979.7? ??7.9? 797.7?
ATM CNT - FRC -T77.7??-???? -?79?;???-" T??;?? 797.77 "777;?? ~?77.7?" 777.77
ATH CNT FRC 7??.?9? 7777 7777.T7? 797.79 999.99 777.7? ???.?? 779.99
ATM CNT FRC 997.99? 799? ?99?.?9? 799.9? 997.7? 777.79 977.7? 779.99
NON CNT FRC 000:000 0000 '. 0000.000 O00."00 000.00 000.00 000.00 000.00
NON CNT FRC 000.000 0000 0000.000 , 000.00 000.00 000.00 000.00 000.00
ATH CNT FRC 2.500 0114 0001.900 006.60 000.00 000.00 000.00 000.00
ATM CNT- FRC 0.020 0169 0000.020 005.30 ' 000.00 ~000".00" 000. 00 000.00
ATM CNT FRC 999.77? 7777 7797.979 979.79 779.97 999.97 777.79 977.97
INC CNT FRC 777.77? ???? T799.779 799.9? 997. 77 999.99 999.99 999.99
ATM CNT FRC ???.?99 9777. 979?.??? 7T7.79 797.9? 777.77 777.77 977.7?
NON CNT FRC 000.000 0000 0000.000 000.00 000.00- 000.00 000.00 000.00
ATM CNT FRC ???.??? 7999 7997.9?? 999.79 997.99 ???.?? 779. 9? 799.9?
NON CNT FRC 000:000 0000 0000.000 000.00 000.00 000.00. 000.00 000.00
RCL CNT FRC 000.000 0000 0000.000 000.00 000.00 000.00 000.00 000.00
NON CNT FRC 000.000 0000 0000.000 000.00 000.00 000.00 000.00 000.00
NON CNT FRC' 000;000 0000 0000.000 000.00 000.00 000.00 000.00 000.00
RCL CNT FRC 000.000 0000 . 0000.000 000.00 000.00 000.00 000.00 000.00
000
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ATOM SCR REF
NUMB NEP NO
77.
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128,127
214,215,216
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34,35,217
M'OCC *M O *H n - • - • - - - - —
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103,104,217
... _._...
138,137,21?
X 77,80,81
77,80,81
X 77,84,85
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79,220,221 --
4,5,6
• " '"* -
145,146,173
174
175
176,177,178
84,85,167
132,133,168
167,170,171
46,47,48
222
40,41,42
X
28,29,30
223,224,225
34,35,217
214,215,216 •
34,35,217
-------
CH FtHT NO COL PR F1NL OPS WST Rfti BTU/ WC ATOH SCR REF
* HFR LOCH CO. C» EQUP COTU HO»E TYPE a. n SCF UJ/HR WOC 1C ZH XH 20 ML MB® HEP KO
51
CE
BCTX
JM— -Ce-BCTX-
st
81
— 81
81
' 81
81
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81
82
82
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82
82
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84
84
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CE
DP
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USI
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CO
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ETH
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PPG
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DP
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DP
DP
DP
DP
UCC
UCC
UCC
EXON
EXON
EXON
EXQN
EXON
TXEH
TXEH
TXEH
TXEH
TXEH
- A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A -
A
BCTX
HTX
HTX
HTX
HTX
HTX
HTX
DPTX
WTX
LCLA
LCLA
BRLA
BRLA
LCLA
LCLA
VTX
VTX
VTX
VTX
VTX
VTX
OTX
STX
STX
STX
BRLA
BRLA
BRLA
BRLA
BRLA
LTX
UX
LTX
LTX
LTX
NS
NS
NS
YS
YS
YS
NS
NS
NS
NS
YS
YS
NS
NS
NS
NS
NS
YS
NS
NS
. NS
NS
NS
2
-2-
i
2
1
1
1
1
1
3
2
2
1
5
1
3
1
6
2
7
4
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5
6
3
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10
23
17
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15
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9
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-------
Reference List For Appendix C
1. Letter from Farmer, J., EPA, to Tower, R., Celanese, August 13, 1980.
2. Letter from Tower, R., Celanese, to Farmer, J., EPA, October 3, 1980.
3. Letter from Edwards, J., Tennessee Eastman, to Patrick, D., EPA,
May 15, 1978.
4. Letter from Desai, T., EEA, to Bess, F. D., UCC, July 16, 1980.
5. Letter from Besss F. D., UCC, to Desai, T., EEA, August 6, 1980.
6. Emission Control Options for the Synthetic Organic Chemical Manufacturing
Industry. Trip Report - Union Carbide Technical Center. EPA Contract
No. 68-02-2577, December 1977.
7. EPA 1972 Houdry Questionnaires - Acetic Anhydride.
8. Letter from Desai, T., EEA, to Thomas, D., Tennessee Eastman, July 22, 1980.
9. Letter from Edwards, J., Tennessee Eastman, to Babcock, J., EEA, "'
March 27, 1981.
10. Letter from Farmer, J. R., EPA, to Mullins, J. A., Shell, August 21,;1980.
11. Letter from Mullins, J. A., Shell, to Farmer, J. R., EPA, October 15, 1980.
12. Letter from Mullins, J. A., Shell, to Goodwin, D. R., EPA, October 25, 1978.
13. Letter from Patrick, D. R., EPA, to Edwards, J., Tennessee Eastman,
October 20, 1978.
14. Letter from Bess, F., UCC, to Patrick, D., EPA, September 21, 1978.
15. Letter from Farmer, J. R., EPA, to Bess, F. D., UCC, August 30, 1980.
16. Letter from Bess, F. p., UCC, to Farmer, J. R., EPA, September 30, 1980.
17. Letter from Johnson, L. D., Rohm and Haas, to Miles, A. J., EEA,
March 21, 1980.
%
18. Letter from Farmer, J. R., EPA, to Venable, J. R., Rohm and Haas,
August 21, 1980.
19. Letter from Venable, J. R., Rohm and Haas, to Farmer, J. R., EPA
October 14, 1980.
20. Letter from Ray, R., Dow Badische, to 'Goodwin, D. R., EPA, May 12, 1978.
21. Letter from Desai, T., EEA, to Ray, R., Badische Corporation, July 16, 1980.
22. Letter from Ray, R., Badische Corporation, to Desai, T., EEA, August 7, 1980.
C-13 ,
-------
23. Emission Control Options for the Synthetic Organic Chemical Manufacturing
Industry. Trip Report - Union Carbide Acrylic Acid and Esters Plant.
EPA Contract No. 68-02-2577. June 1978.
24. EPA 1972 Houdry Questionnaires - Acrylonitrile.
25. Letter from Desai, T., EEA, to Volke, E. J., American Cyanamid,
September 18, 1980.
26. Letter from Volke, E. J., American Cyanamid, to Desai, T., EEA,
September 29, 1980.
27. Letter from Lorine, D. J., Conoco, to Goodwin, D. R., EPA, February 17, 1978.
28. Emission Control Options for the Synthetic Organic Chemical Manufacturing
Industry. Trip Report - Rubicon Nitrobenzene Plant. EPA Contract
No. 68-02-2577. July 19, 1977.
29. Letter from Desai, T., EEA, to Anthon, W.L., Rubicon, July 18, 1980.
30. Letter from Anthon, W. L., Rubicon, to Babcock, J. C., EEA, March 20, 1981.
31. Letter from Smith, A. G., Shell, to Goodwin, D. R., EPA, February 22, 1978.
32. Letter from Wurzer, H. J., Montrose, to Goodwin, D. R., EPA, March 7, 1978.
33. Letter from Dilmore, C. R., PPG, to Weber, R. C., EPA, September 30, 1977.
34. Letter from Farmer, J. R., EPA, to Dehn, Dr. F. C., PPG, October 20, 1980.
35. Letter from Samelson, R. J., PPG, to Farmer, J. R., EPA, November 14, 1980.
36, Letter from Meyer, A. J., Denka, to Goodwin, D. R., EPA, March 26, 1979.
37. Letter from Farmer, J. R., EPA, to Meyer, A. J., Denka, October 14, 1980.
38. Letter from Meyer, A. J., Denka, to Farmer, J. R., EPA, October 21, 1980.
39. EPA 1972 Houdry Questionnaires - Cyclohexanone/Cyclohexanol.
40. Letter from Smith, D. W., DuPont, to Goodwin, D. R., EPA, .October 20, 1978.
41. Letter from Farmer, J. R., EPA, to Steele, J. L., DuPont, August 13, 1980.
42. Letter from Steele, J. L., DuPont, to Farmer, J. R., EPA, December 12, 1980.
43. Letter from Edwards, J. C., Tennessee Eastman, to Goodwin, D. R., EPA,
August 31, 1978.
44. Letter from Anziano, L. B., Olin, to Goodwin, D. R., EPA, May 17, -1978."
45. Desai, T., Memo to SOCMI Distillation File, September 12, 1980,
46. Letter from Berry, F. E., Gulf, to Mascone, D., EPA, July 20, 1979.
C-14
-------
47. Letter from Desai, T., EEA, to Berry, F. E., Gulf, August, 19, 1980.
48. Letter from Berry, F. E., Gulf, to Desai, T., September 3, 1980.
49. Letter from Desai, T., EEA,'to De Bernardi, J. A., Conoco, October 20, 1980.
50. Letter from De Bernardi, J. A., Conoco, to Desai, T., EEA, November 4, 1980.
51. Letter from De Bernardi, J. A., Conoco, to Goodwin, D. R., EPA,
May 26, 1978.
52. EPA 1972 Houdry Questionnaires - Ethylene Dichloride.
53. Letter from Mullins, J. A., Shell, to Goodwin, D. R., EPA, January, 11, 1979,
54. EPA 1972 Houdry Questionnaires - Formaldehyde.
55. Letter from Smith, D. W., DuPont, to Goodwin, D. R., EPA, December 15, 1978.
56. Letter from Senyk, D., EEA, to Steele, J. L., DuPont, April 23, 1981.
57. Letter from Steele, J. L., DuPont, to Farmer, J. R., EPA, December 12, 1980.
58. Letter from Brennan, H. M., Amoco, to Mascone, D., EPA, July 28, 1978.
59. Emission Control Options for the Synthetic Organic Chemical Manufacturing
Industry. Trip Report - Amoco Maleic Anhydride Plant. EPA Contract
No. 68-02-2577. January 1978.
60. EPA 1972 Houdry Questionnaires - Maleic Andride.
61. Letter from Duggan, R. L., Air Products, to Goodwin, D. R., EPA, May 11, 1978.
62. Letter from Farmer, J. R., EPA, to Sroufe, R. H., Air Products,
August 13, 1980.
63. Letter from Sroufe, R. H., Air Products, to Farmers J. R., EPA,
September 30, 1980.
64. Letter from Brenner, D. M., Hercofina, to Goodwin, D.'R., EPA, April 12,
1978.
65. Letter from Farmer, J. R., EPA, to Hoffmann, G. R., Hercofina,
September 25, 1981.
66. Letter from Hoffmann, G. R., Hercofina, January 7, 1981, to Farmer, J. R.,
EPA, January 7, 1981.
67. Letter from Mullins, J. A., Shell, to Goodwin, D. R., EPA, June 22, 1978.
68. Letter from Mullins, J. A., Shell, to Farmer, J. R., EPA, December 2, 1980.
69. Letter from Farmer, J. R., EPA, to Mullins, J. A., Shell, November 6, 1980.
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70. Emission Control Options for the Synthetic Organic Chemical Manufacturing
Industry. Trip Report - DuPont Methyl Methacrylate Plant. EPA Contract
No. 68-02-2577. June 1978.
71. Letter from Gold, D. H., CYRO, to White, R., Hydroscience, May 4, 1978.
72. Letter from Desai, T., EEA, to Volke, E. J., CYRO, September 18, 1980.
73. Letter from Volke, E. J., CYRO, to Desai, T., EEA, September 29, 1980.
74. Letter from Johnson, L. D., Rohm and Haas, to Miles, A. J., EEA,
March 21, 1980.
75. Letter from Farmer, J. R., EPA, to Venable, J. R., Rohm and Haas,
August 21, 1980.
76. Letter from Venable, J. R., Rohm and Haas, to Farmer, J. R., EPA,
October 14, 1980.
77. Letter from Hughes, L. P., Mobay, to Goodwin, D. R., EPA, January 31, 1978.
78. Letter from Worthington, J. B., Diamond Shamrock, to Goodwin, D. R., EPA,
January 16, 1979.
79. EPA 1972 Houdry Questionnaires - Phthalic Anhydride,
80. Letter from Senyk, D., EEA, to Urbassik, M., Koppers, October 1, 1980.
81. Letter from Urbassik, M., Koppers, to Senyk, D., EEA, October 21, 1980.
82. Letter from Desai, T., EEA, to Moniot, J. D., U. S. Steel, October 2, 1980.
83. Letter from Moniot, J. D., U. S. Steel, to Desai, T., EEA, October 21, 1980.
84. Letter from Farmer, J. R., EPA, to Weishaar, M. F., Monsanto, November 6,
1980.
85.' Letter from Weishaar, M. F., Monsanto, to Farmer, J. R., EPA, May 21, 1981.
86. Letter from Bess, F. D., Union Carbide, to Evans, L. B., EPA, May 5, 1978.
87. Letter from Foster, R. L., UC, to Farmer J. R., EPA, December 18, 1980.
88. Letter from Farmer, J. R., EPA, to Foster, R. L. UC, November 6, 1980.
89, Letter from Smith, D. W., DuPont, to Goodwin, D. R., EPA, September 18, 1980.
90. Letter from Farmer, J. R., EPA, to Kafka, M. C., DuPont, November 4, 1980.
91. Letter from Kafka, M. C., DuPont, to Farmer, J. R., EPA, December 8, 1980.
92. Letter from Smith, H. A., DuPont, to Goodwin, D. R., EPA, November 28, 1978.
93. Letter from Farmer, J. R., EPA, to Steele, DuPont, December 12, 1980."
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94. Letter from Steele, J. L., DuPont, to Farmer, J. R., EPA, March 4, 1981.
95. Letter from Prendergast, G., Texas Eastman, to Goodwin, D. R., EPA,
January 26, 1979.
96. Letter from Farmer, J. R., EPA, to Prendergast, G., Texas Eastman,
August 21, 1980.
97. Letter from Prendergast, G., Texas Eastman, to Farmer, J. R., EPA,
January 27, 1981.
98. Emissions Control Options for the Synthetic Organic Chemical Manufacturing
Industry. Trip Report - Monsanto Acetic Acid Plant. EPA Contract
No. 68-02-2577. December 1977.
99. EPA 1972 Houdry Questionnaires - Acetic Acid.
100. EPA 1972 Houdry Questionnaires - Acetone.
101. Letter from Farmer, J. R., EPA, to Reiter, W., Allied, October 20, 1980.
'102. Letter from Alcorta, J. D., Allied, to Farmer, J. R., EPA, December 29, 1980.
103. Letter from Desai, T., EEA, to Demski, S. J., USS, October 6, 1980.
104. Letter from Demski, S. J., USS, to Desai, T., EEA, November 6, 1980.
105. Letter from Goodwin, D. R., EPA, to Rhodes, T. H., Exxon, August 16, 1978.
106. Letter from Rhodes, T. H., Exxon, to Goodwin, D. R., EPA, October 13, 1978.
107. Limpiti, A., Memo to SOCMI Distillation File, April 18, 1980.
108. Letter from Bess, F. D., UCC, to Evans, L. B., EPA, April 21, 1978.
109. .Emission Control Options for the Synthetic Organic Chemical Manufacturing
Industry - DuPont Acrylonitrile Plant. EPA Contract No. 68-02-2577.
September 1977.
110. Emission Control Options for the Synthetic Organic Chemical Manufacturing
Industry - Vistron Acrylonitrile Plant. EPA Contract No. 68-02-2577.
October 1977.
111. Letter from Smith, D. W., DuPont, to Goodwin, D. R., April 20, 1978.
112. EPA 1972 Houdry Questionnaires - Adi pic Acid.
113. Letter from Vistica, E. A., Witco, to Goodwin, D. R., EPA, February 6, 1978.
114. Letter from Derway, D., EEA, to Corinth, J., Witco, August 26, 1980.
115. Letter from Corinth, J., Witco, to Derway, D., EEA, September 15, 1980.
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116. Emission Control Options for the Synthetic Organic Chemical Manufacturing
Industry. Trip Report - Monsanto Alky! Benzene Plant. EPA Contract
No. 68-02-2577. November 1977,
117. Letter from Craddock, J. ft., UCC, to Patrick, D., EPA, May 31, 1979.
118. Emission Control Options for the Synthetic Organic Chemical Manufacturing
Industry. Trip Report - FMC Glycerine Plant. EPA Contract No. 68-02-2577.
119. Letter from Farmer, 0. R. s EPA, to Hopkins, C. B., FMC, September 16, 1980.
120. Letter from Hopkins, C. B., FMC, to Farmer, J. R., EPA, October 20, 1980.
121. EPA 1972 Houdry Questionnaires - Ally! Chloride.
122. Emission Control Options for the Synthetic Organic Chemical Manufacturing
Industry. Trip Report - Petro-Tex Butadiene Plant. EPA Contract
No. 68-02-2577. October 1977.
123. Letter from Desai, T., EEA, to Towe, R., Petro-Tex, August 19, 1980.
124. Letter from Stewart, L. A., Petro-Tex, to Desai, T., September 10, 1980,
125. EPA 1972 Houdry Questionnaires - Ethylene.
126. Letter from Mullins, P. B., Mobil, to Goodwin, D. R., EPA, January 26,
1978.
127. Letter from Robinson, T. A., Vulcan, to Patrick, D. R., EPA, July 9, 1979.
128. Letter from Desai, T., EEA,-to Renner, J., Vulcan, July 25, 1980.
129. Letter from Renner, J., Vulcan, to Desai, T., August 26, 1980.
130. Letter from Wurzer, H. J., Montrose, to Goodwin, D. R., EPA, March 7, 1978.
131. Letter from Kampfhenkel, J. R., Sun, to Goodwin, D. R...EPA, September 12,
1978.
132. Letter from Desai, T., EEA, to Myers, G., Sun, August 27, 1980.
133. Letter from Myers, G., Sun, to Desai, T., EEA, February 20, 1981.
134. Letter from Zanotti, M. P., Gulf, to Goodwin, D. R., EPA, September 19,
1978.
135. Letter from Desai, T., EEA, to Wilson, G., Gulf, August 22, 1980.
136. Letter from Wilson, G., Gulf, to Desai, T., EEA, September 4, 1980.
137. EPA 1972 Houdry Questionnaires - Cumene Hydroperoxide.
138. Letter from Babcock, J., EEA, to Davis, R. W., Chevron, March 11, 1981.
139. Letter from Davis, R. W., Chevron, to Babcock, J., EEA, April 13, 1981.
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140. Letter from Chaffin, R. L., Champlin, to Goodwin, D. R., EPA,
January 25, 1978.
141. Letter from Pardue, K., Cosden, to Goodwin, D. R., EPA, January 24, 1978.
142. Letter from Farmer, J. R., EPA, to Nairn, T. M., Cosden, August 11, 1980.
143. better from Nairn, T. M., Cosden, to Farmer, J. R., EPA, September 29,
1980.
144. Emission Control Options for the Synthetic Organic Chemical Manufacturing
Industry. Trip Report - Phillips Cyclohexane Plant. September 1977.
145. Letter from Desai, T., EEA, to Ballard, B. F., Phillips, October 16, 1980.
146. Letter from Ballard, B. F., Phillips, to Desai, T., EEA, October 29, 1980.
147. Letter from Dickinson, W. W., Sun, to Goodwin, D. R., EPA, January 26,
1978.
148. Emission Control Options for the Synthetic Organic Chemical Manufacturing
Industry. Trip Report. EPA Contract 68-02-2577. September 1977.
149. Letter from Farmer, J. R., EPA, to Cox, J. B., Exxon, September 11, 1980.
150. Letter from Cox, J. B.., Exxon, to Farmer, J. R., EPA, October 6, 1980.
151. Letter from Zanotti, M. P., Gulf, to Goodwin, D. R., EPA, January 26, 1978.
152. Letter from Desai, T., EEA, to Wilson, 6. J., Gulf, November 20, 1980.
153. Letter from Wilson, G. J., Gulf, to Desai, T., EEA, December 10, 1980.
154. Emission Control Options for the Synthetic Organic Chemical Manufacturing
Industry. Trip Report - Nipro Cyclohexanol Plant. April 1978.
155. EPA 1972 Houdry Questionnaires - Cyclohexanol.
156. Letter from Bess, F. D., UC, to Evans, L. B., EPA, May 5,'1978.
157. Emission Control Options for the Synthetic Organic Chemical Manufacturing
Industry. Trip Report - Monsanto Cycloheranol Plant. February 1978.
158. Letter from Smith, D. W., DuPont, to Goodwin, D. R., EPA, August 21, 1978.
159. Letter from Farmer, J. R., EPA, to Steele, J. L., DuPont, December 12, 1980.
160. Letter from Steele, J. L., DuPont, to Farmer, J. R., EPA, March 4, 1981. ,
161. Letter from Schrader, W. C., Allied, to Mascone, D. C., EPA, January 31, 197:8.
162. Letter from Desai, T., EEA, to Lanter, N. A., Allied, July 25, 1980.
163. Letter from Lanter, N. A., Allied, to Babcock, J. C., EEA, March 19, 1981.
164. EPA 1972 Houdry Questionnaires - Glycerine.
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165. Letter from Edwards, J. C., Tennessee Eastman, to Goodwin, D. R., EPA,
August 11, 1978.
166. Letter from Bufkin, L. T., American Hoechst, to Goodwin, D. R., EPA,
January 26, 1978.
167. Letter from Keating, H. M., Monsanto, to Evans, L., EPA, April 28, 1978.
168. Letter from Kampfhenkel, J. R., Sun, to Goodwin, D. R., EPA, November 7,
1978.
169. Letter from Kuykendall, C. R., El Paso, to Goodwin, D. R., EPA,
January 31, 1978.
170. Letter from Senyk, D., EEA, to Chapman, L., El Paso, October 7, 1980.
171. Letter from Smith, R. H., El Paso, to Senyk, D., EEA, December 3, 1980.
172. Letter from Smith, D. W.,,DuPont, to Goodwin, D. R., EPA, February 3, 1978.
173. Letter from McReynolds, L. A., Phillips, to Goodwin, D. R., EPA,
January 27, 1978.
174. Letter from Kaminski, K. J., B. F. Goodrich, to Goodwin, D. R., EPA,
November 15, 1978.
175. Letter from Mullin, P. B., Mobil, to Goodwin, D. R., EPA, January 26, 1978.
176. EPA 1972 Houdry Questionnaires - Ethylene.
177. Letter from Mullin, M. L., ARCO, to Desai, T., EEA, September 22, 1980.
178. Letter from Desai, T., EEA, to Mullin, M. L., ARCO, August 27, 1980.
179. Letter from Gordon, V., Vulcan, to Evans, L., EPA, October 24, 1978.
180. Letter from Farmer, J. R., EPA, to Cornell, P. B., ICI, November 6, 1980.
181. Letter from Cornell, P. B., ICI, to Farmer, J. R., EPA, November 26, 1980.
182. Letter from Samelson, R. J., PPG, to Goodwin, D. R., EPA, June 2, 1978.
183. Limpiti, 0., Memo to SOCMI Distillation Files, April 28, 1980.
184. Letter fom Kovacevich, T. R., BASF, to Goodwin, D. R., EPA, November 27.
1978.
185. Letter from Desai, T., EEA, to Caldwell, N. F., BASF, August 27, 1980.
186. Letter from Caldwell, N. F., BASF, to Desai, T., EEA, September 22, 1980.
187. Letter from Abelson, P. M., Calcasiev, to Goodwin, D. R., EPA,
December 20, 1978.
188. EPA 1972 Houdry Questionnaires - Ethylene Oxide.
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189. Emission Control Options for the Synthetic Organic Chemical Manufacturing
industry. Trip Report - BASF Ethylene Oxide Plant. July 1977.
190. EPA 1972 Houdry Questionnaires - 2 Ethyl hexanol.
191. Emission Control Options for the Synthetic Organic Chemical Manufacturing
Industry. Trip Report - Borden Formaldehyde Plant. August 1977.
192. Letter from Pandullo, R.,. EEA, to Moreau, J., Borden, August 7, 1980.
193. Letter from Moreau, J., Borden, to Pandullo, R., EEA, August 12, 1980.
194. Emission Control Options for the Synthetic Organic Chemical Manufacturing
Industry. Trip Report - Celanese Formaldehyde Plant.
195. Letter from Babcock, J., EEA, to Carpenter, B., Celanese, March 11, 1981.
196. Letter from Carpenter, B., Celanese, to Babcock, J., March 1981.
197. Letter from Senyk, D., EEA, to Wood, L. F., Hooker, September 24, 1980.
198. Letter from Wood, L. F., Hooker, to Senyk, D., EEA, October 14, 1980.
199. Limpiti, 0., Memo to SOCMI Distillation Files, April 17, 1980.
200. Letter from Hopkins, C. B., FMC, to Goodwin, D. R., EPA, February 6, 1979.
201. Letter from Farmer, J., EPA, to Hopkins, C., FMC, September 16, 1980.
202. Letter from Hopkins, C., FMC, to Farmer, J., EPA, October 20, 1980.
203. EPA 1972 Houdry Questionnaires - n-Butanol
204. Emission Control Techniques for the Synthetic Organic Chemical Manufacturing
Industry. Trip Report - Monsanto Maleic Anhydride Plant. EPA Contract
No. 68-02-2577. October 1977.
205. Letter from Ball, C., Exxon, to Goodwin, D. R., EPA, October 13, 1978.
206. Letter from Desai, T., EEA, to Schirripa, R., Exxon, August 19, 1980.
207. Letter from Schirripa, R., Exxon, to Desai, T., EEA, August 28, 1980.
208. Emission Control Techniques for the Synthetic Organic Chemical Manufacturing
Industry. Trip Report - Celanese Methanol Plant. EPA Contract
NO. 68-02-2577. October 1977.
209. Emission Control Techniques for the Synthetic Organic Chemical Manufacturing
Industry. Trip Report - Monsanto Methanol Plant. EPA Contract
No. 68-02-2577. December 1977.
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210. Letter from Robinson, T., Vulcan, to Patrick, D., EPA, July 9, 1979.
211. Letter from Senyk, D., EEA, to Robinson, T., Vulcan, September 22, 1980.
212. Letter from Robinson, T., Vulcan, to Senyk, D., EEA, October 1, 1980.
213. Letter from Muthig, J., Allied, to Goodwin, D., EPA, March 31, 1978.
214. Letter from Strader, W., Ethyl, to Goodwin, D., EPA, November 28, 1978.
215. Letter from Senyk, D., EEA, to Park, D., Ethyl, October 15, 1980.
216. Letter from Park, D., Ethyl, to Senyk, D., EEA, November 10, 1980.
217. Letter from Dehn, F., PPG, to Goodwin, D., EPA, March 14, 1979.
218. Emission Control Options for the Synthetic Organic Chemical Manufacturing
Industry. Trip Report - Monsanto Phenol Plant. EPA Contract
No. 68-02-2577. July 1977.
219. EPA 1972 Houdry Questionnaires - Phenol.
220. Letter from Babcock, J., EEA, to Neumann, G., BASF, October 23, 1980.
221. Letter from Neumann, G., BASF, to Babcock, J., EEA, March 30, 1981.
222. Emission Control Options for the Synthetic Organic Chemical Manufacturing
Industry. Trip Report - Amoco Terephthalic Acid Plant. EPA Contract
No. 68-02-2577. October 1977.
223. Letter from Kovacevich, T., BASF, to Goodwin, D., EPA, May 31, 1978.
224. Letter from Senyk, D., EEA, to Caldwell, N., BASF, September 1980.
225. Letter from Caldwell, N., BASF, to Senyk, D., EEA, October 13, 1980.
226. Emission Control Options for the Synthetic Organic Chemical Manufacturing
Industry. Trip Report. EPA Contract No. 68-02-2577. September 1977.
227. EPA 1972 Houdry Questionnaires - Vinyl Acetate.
228. Letter from Schaefer, C., Celanese, to Farmer, J., EPA, November 20, 1980.
229. Letter from Farmer, J., EPA, to Schaefer, C., Celanese, November 6, 1980.
230. Letter from Carpenter, K. G., USI, to Goodwin, D., EPA, August 17, 1978.
231. Letter from Farmer, J., EPA, to Carpenter, K., USI, November 6, 1980.
232. Letter from Carpenter, K., USI, to Farmer, J., EPA, November 20, 1980.
233. EPA 1972 Houdry Questionnaires - Vinyl Chloride.
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APPENDIX D
EMISSION MEASUREMENT
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APPENDIX D - EMISSION MEASUREMENT
D.I INTRODUCTION
The proposed distillation operations new source performance (NSPS)
divides distillation facilities into two groups. One group of facilities
is required under the proposed standard to reduce VOC emissions by
combusting them in one of the following control devices: an incinerator,
a boiler, or a flare. If emissions are combusted in an incinerator,
emissions must be reduced by 98 weight percent or to 20 ppm (total
volume concentration, by compound), whichever is less stringent.
Standard measurement methods should be used to determine the VOC reduction.
The second group of facilities is not required to reduce VOC emissions
under the proposed standard. As discussed in Chapter 8 and Appendix G,
the two groups of facilities are distinguished by a cutoff level of
total resource effectiveness (TRE). An index value of TRE can be associated
with each distillation vent stream for which the offgas characteristics
of flowrate and individual VOC emission concentrations are known. The
proposed standard would require that measurements be made to determine
whether a source has a TRE index value above or below the cutoff level.
In this case, measurements are needed to determine the flowrate and
individual VOC emission concentrations. The net heating value of the
distillation vent stream is then calculated.
The purpose of this appendix is to discuss and present measurement
methods acceptable for determination of VOC reduction efficiency and/or
individual VOC emission concentrations.
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D.1.1 VOC MEASUREMENT
Numerous'methods exist for the measurement of organic emissions.
Among these methods are continuous flame ionization analyzers (FIA) and
gas chromatograph (GC) (EPA Reference Methods 25 and 18). Each method
has advantages and disadvantages. Of the two procedures, GC has the
distinct advantage of identifying and quantifying the individual compounds.
However, GC systems are expensive; and determination of the column
required and analysis of samples can be time consuming.
The FIA technique is the simplest procedure. However, the FIA
responds differently to various organic compounds and can yield highly
biased results depending upon the compounds involved. Another disadvantage
of the FIA is that a separate methane measurement is required to determine
nonmethane organics. Qf course, the direct FIA procedure does not
identify or quantify individual compounds.
Method 25 sampling and analysis provides a single nonmethane
organic measurement on a carbon basis; this is convenient for establishing
control device efficiencies on a consistent basis. However, Method 25
does not provide any qualitative or quantitative information on individual
compounds present. For these determinations, Method 18 must be used.
D.I.2 EMISSION MEASUREMENT TESTS
No emission measurement tests were performed during data gathering
for this proposed standard. All emission data were collected .directly
from existing industry emission records.
D.2 PERFORMANCE TESTS METHODS
EPA Methods 18 and 25 are the recommended test procedures for
determining control device efficiencies for distillation operations.
D-2
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However, Method 25 is likely to yield slightly lower calculated
efficiencies than actually obtained. Method 25 can be expected to yield
higher results than the Method 18 at the emission outlet when the outlet
concentration is less than 100 ppm volume; therefore, at this time,
Method 25 is particularly not recommended for performance tests to
measure compliance with the 98 percent reduction provision of the proposed
standard when the outlet emissions are expected to be below 100 ppm.
EPA Methods 1, 1A, 2, 2A, and 2C are recommended for determination of
stack flowrates. Additions are being proposed to Method 2A to increase
flexibility in the measurement of low flows.
In order to determine the stream net heating value for distillation
sources, both identification and quantification of the substances being
emitted are necessary. Method 18 can be used to: (1) determine individual
VOC emissions from the control device outlet, (2) determine individual -
VOC reduction efficiency of the control device, and (3) provide data
required to determine whether a source has a TRE index value above or
below the cutoff level specified in the proposed standard.
The costs associated with performing a control device efficiency
test, a total outlet VOC concentration test, or a test to gather data to
compute a TRE value will vary widely, depending on the resources available;
but are estimated to be $10,000 to $15,000 per test.
D-3
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APPENDIX E
LIST OF CHEMICALS COVERED BY THE STANDARD
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APPENDIX E: LIST OF CHEMICALS COVERED BY THE STANDARD
The Agency initiated a standards development program for distillation
operations based on results from I.T. Enviroscience's four year engineering
study of a segment of the synthetic organic chemical manufacturing
industry. Enviroscience studied in-depth the production of high volume
chemical intermediates thought to contribute a large fraction to total
VOC emissions from organic chemical manufacturers. Thus, one of the first
tasks in the standards development program was to define exactly which
chemicals would be covered.
At first, it was decided to use a list of about 380 chemicals
comprising Radian Corporation's Organic Chemical Producers Data Base,
1976 (EPA Contract No. 68-02-1319, Task 51), which was composed for
EPA's Industrial Environmental Research Laboratory in Cincinnati. This
list was generated from "chemical trees" and from addition of certain
chemicals whose national production was estimated to be over 10 million
pounds per year. However, upon closer examination of the list and with
the assistance of the U.S. International Trade Commission, it was discovered
that there were numerous low volume chemicals on the list as well as a
few that apparently were no longer made in the U.S. It was desirable to
eliminate the lower volume (and of course those not made in the U.S.)
chemicals for two reasons. First the lower volume chemicals usually
have relatively high molecular weights and boiling points and, therefore,
are increasingly likely to be involved in separations by crystallization
and filtration rather than distillation. It was concluded that this would
make their distillation emission contribution relatively small.
Second, the emission data base represented high volume chemicals, consistent
with original objectives, and not low volume chemicals. Including the
low volume chemicals without adequate representation in the data base
would have compromised the credibility of the regulatory analysis.
In light of these considerations, a minimum national production of
45 Gg/yr ('blOO million pounds/yr) was established as the basis for
constructing a new list of chemicals to be covered by this program. The
E-l
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Agency has concluded that covering chemicals at or above this cutoff will
still address the bulk of VOC emissions from distillation operations while
comfortably working within the data base boundaries of representation.
Furthermore, non-photochemically reactive VOC that do not produce photo-
chemically reactive VOC as coproducts were eliminated from the list after
assuming the production volume cutoff. The resulting list of 218 chemicals
consists of high volume synthetic organic chemicals to which NSPS for
distillation operations may apply.
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LIST OF CHEMICALS AFFECTED BY DISTILLATION NSPS
Chemical
Acetaldehyde
Acetic acid
Acetic acid, anhydride
Common Names
(1) Acetic anhydride
Acetic acid, butyl ester
Acetic acid, ethenyl ester
Acetic acid, ethyl ester
Acetic acid, magnesium salt
Alcohols, C-ll or Tower, mixtures
Alcohols, C-12 or higher, mixtures
2-Aminoethanol
Berizenamine
Benzene
1,3-Benzenedicarboxylic acid
1,4-Benzenedicarboxylic acid
1,2-Benzenedicarboxylic acid,
bis (2-ethylhexyl) ester
1,2-Benzenedicarboxylic acid
butyl, phenylmethyl ester
1,2-Benzenedicarboxylic acid
di-n-heptyl-n-nonyl undecyl ester
1,2-Benzenedicarboxylic acid
diisodecyl ester
1,2-Benzenedicarboxylic acid
diisononyl ester
1,4-Benzenedicarboxylic acid,
dimethyl ester
Benzenesulfonic acid
Benzenesultonic acid, mono-
C-JQ ,g-alkyl derivatives,
socnunr salts
Benzoic acid, tech.
(2) Acetic oxide
n-Butyl acetate
Vinyl acetate
Ethyl acetate
Magnesium acetate
(1) Ethanolamine
(1) Aniline .
(2) Phenylamine
Benzol
Isophthalic acid
Terephthalic acid
(1) Bis (2-ethylhexyl) phthalate
(2) Dioctyl phthlate
(3) Di (2-ethyl hexyl) phthalate
Butyl benzyl phthalate
Di-n-heptyl-n-nonyl undecyl
phthalate
Di-isodecyl phthalate
Diisononyl phthalate
(1) Terephthalic acid, dimethyl ester
(2) Dimethylterephthalate
(3) DMT
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LIST OF CHEMICALS AFFECTED BY DISTILLATION NSPS (CONTINUED)
Chemical
Common Names
1,1-Biphenyl
2,2-Bis (hydroxymethyl)-
1,3-propanediol
1,3-Butadiene
Butadiene and butene fractions
Butanal
Butane
Butanes, mixed
1,2 (and 1,3) Butanediol
1,4-Butanediol
Butanoic acid, anhydride
1-Butanol
2-Butanol
2-Butanone
2-8utenal
1-Butene
2-8utene
Butenes, mixed
2-8utenoic acid
2-Butoxyethanol
2-Butyne-l,4-diol
Carfaamic acid, monoammonium salt
Carbon disulfide
Carbonic dichloride
Chlorobenzene
2-Chloro-l,3-butadiene
Chloroethane
Chloroethene
Diphenyl
Pentaerythritol
(1) Bivinyl
(2) Divinyl
Butyraldehyde
n-Butane
Butylene glycol
Butyric anhydride
n-Butyl alcohol
sec-Butyl alcohol
Methyl ethyl ketone
Crotonaldehyde
S-Methylacrolein
o-Butylene
(1) 8-Butyl ene
(2) pseudo-Butylene
Butylenes (mixed)
Crotonic acid
Butyl CellosolveR
Phosgene
Chloroprene
Ethyl chloride
Vinyl chloride
E-4
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LIST OF CHEMICALS AFFECTED BY DISTILLATION NSPS (CONTINUED)
Chemical
Common Names
6rChloro-N-ethyl-N'-(1 -
methyl ethyl)-!S3S5-
triazine-2,4-diamine
Chlorotnethane
(Chloromethyl) benzene
(Chioromethyl) oxirane
l-Chloro-4-nitrobenzene
2-Chloro-1-propanol
3-Chloro-1-propene
Coconut oil acids, sodium salt
Cyclohexane
Cyclohexane, oxidized
Cyclohexanol
Cyclohexanone
Cyclohexanone oxime
Cyclohexene
1,3-Cyclopentadiene
Cyclopropane
1,2-Dibromoethane
.Dibutanized aromatic concentrate
1,4-Dichloro-2-butene
3,4-Dichloro-1-butene
Dichlorodi f1uoromethane
Dichlorodimethylsi1ane
1,2-Dichloroethane
1,1-Dichloroethene
Dichlorofluoromethane
(1) 2-Chl oro-4-( ethyl ami no)-
6r(isopropylami no)-s-
triazine
(2) AtrazineR
Methyl chloride
1) Benzyl chloride
2) a-Chlorotoluene
Epichlorohydrin
(1) p-Chloronitrobenzene
(2) p-Nitrochlorobenzene
(1) 2-Chloropropyl alcohol
(2) Propylene chlorohydrin
(1) 3-Chloropropene
(2) Ally! chloride
Hexahydrobenzene
(1) Hexalin
(2) Hexahydrophenol
Pimelic ketone
1,2,3,4-Tetrahydrobenzene
Trimethylene
(1) Ethylene dibromide
(2) Ethylene bromide
1,4-Dichlorobutene
Freon 12
Dimethyldi chlorosi1ane
(11 EthyTene chloride
(2) Ethylene dichloride
Vinylidene chloride
Freon 21
E-5
-------
LIST OF CHEMICALS AFFECTED BY DISTILLATION NSPS (CONTINUED)
Chemical
Common Names
Dichloromethane
1,3-Dichloro-2-propanol
01ethyl benzene
1,3-Di1socyanato-2-(and 4-)
methyl benzene ($0/20 mixture)
Dimethyl benzenes (mixed)
1,2-Dimethylbenzene
1,3-Dimethylbenzene
1,4-Dimethylbenzene
1,1-Dimethyl ethyl hydroperoxi de
2,6TDimethylphenol
1-Dodecene
Dodecylbenzene, linear
Dodecylbenzene, non linear
Dodecylbenzenesulfonic acid
Dodecylbenzenesulfonic acid,
sodium salt
Methylene chloride
a-Dichlorohydrin
Toluene-2,4-(and 2,6)-
diisocyanate (80/20 mixture)
Xylenes (mixed)
o-Xylene
m-Xylene
p-Xylene_
tert-Butyl hydroperoxide
(1) m-Xylenol
(2) 2,6.Xylenol
(1) Dodecene
(2) Tetrapropylene
Alkylbenzene
1,2-Ethanediol
2,2'-(l,2-Ethanediylbis (oxy))
bisethanol
Ethanol
Ethene
Ethenone
Ethenylbenzene
2-Ethoxyethanol
2-Ethoxyethyl acetate
Ethylene glycol
Triethylene glycol
Ethyl alcohol
(1) Ethylene
(2) Elayl
(3) Olefiant gas
Ketene
Styrene
(1) Ethylene glycol monoethyl ether
(2) Cellosolve
(1) Ethylene glycol monoethyl ether
acetate
(2) Cellosolve acetateR
E-6
-------
LIST OF CHEMICALS AFFECTED BY DISTILLATION NSPS (CONTINUED)
Chemical
Common Names
Ethyl benzene
2-Ethylhexanal
2,-Ethyl-l-hexanol
(2-Ethylhexyl) amine
Ethylmethyl benzene
6TEthyl-l,2,3,4-tetrahydro-
9,10-anthracenedione
Ethyne
Fatty acids, tall oil, sodium salt
Formaldehyde
2,5-Furandione
D-Glucitol
Heptane
Heptenes (mixed)
Hexadecyl chloride
Hexahydro-2H-azepi n-2-one
Hexane
1,6-rHexanedi amine
1,6-rHexanediamine adipate
Hexanedinitrile
Hexanedioic acid
2-Hexenedinitrile
3-Hexenedinitrile
Hydrocyanic acid
3-Hydroxybutyraldehyde
4-Hydroxy-4-methyl-2-pentanone
2-Ethylhexyl alcohol
(1) Acetylene
(2) Ethine
(1) Formalin (solution)
(2) Methanal (gas)
Maleic anhydride
Sorbitol
n-Heptane
Caprolactarn
Hexamethylene diamine
(1) Hexamethylene diamine adipate
(2) Nylon salt
(1) Adiponitrile
(2) 1,4-Dicyanobutane
Adipic acid
1,4-Dicyano-l-butene
(1) 1,4-Dicyanobutene
(2) Dihydromucononitrile
(3) 1,4-Dicyano-2-butene
Hydrogen cyanide
Aldol
Acetaldol
Diacetone alcohol
E-7
-------
LIST OF CHEMICALS AFFECTED BY DISTILLATION NSPS (CONTINUED)
Chemical
Common Names
2-Hydroxy-2-methylpropanenitri1e
2-Hydroxy-l,2,3-
propanetricarboxy!ic acid
2,2'-Iminobisethanol
lodo/methane
1,3-Isobenzofurandione
Isodecanol
Linear alcohols, ethoxylated, mixed
Linear alcohols, ethoxylated and
sulfated, sodium salt, mixed
Linear alcohols, sulfated, sodium
salt, mixed
Methanami ne
Methanol
2-Methoxyethanol
Methyl benzene
4-Methyl-l,3-benzenediamine
ar-Methylbenzenediamine
2-Methyl-1,3-butadiene
2-Methylbutane
2-Methyl-2-butene
2-Methylbutenes, mixed
Methyl tert-butyl ether
1-Methyl-2,4-di ni trobenzene
(and 2-Methyl-1,3-dinitrobenzene)
1-Methyl-2,4-di ni trobenzene
(1-Methylethyl) benzene
(1) Acetone cyanohydrin
(2) 2-Methyllactonitrile
Citric acid
(1) Diethanolamine
(2) 2,2'-Aminodiethanol
Methyl Iodide
Phthalic anhydride
Isodecyl alcohol
Methyl amine
(1) Methyl alcohol
(2) Wood alcohol
(1) Ethylene glycol monomethyl
ether
(2) Methyl CellosolveR
Toluene
(1) Toluene-2,4-diamine
(2) 2,4-Diaminotoluene
(3) 2,4-Tolylenediamine
Isoprene
Isopentane
Amy!ene
Amylenes, mixed
MTRE
2,4(and 2,6)-dinitroto1uene
2,4-Di ni trotoluene
Cumene
E-8
-------
LIST O.F CHEMICALS AFFECTED BY DISTILLATION NSPS (CONTINUED)
Chemical
Common Names
4,4'-(1-Methyl ethylidene)
bisphenol
6-rMethyl-heptanol
N-Methylmethanami ne
Methyloxirane
2-Methylpentane
4-Methyl-2-pentanone
4-Methyl-3-penten-2-one
1-Methyl-1-phenylethyl hydroperoxide
2-Methylpropanal
2-Methyl propane
2-Methyl-1-propanol
2-Methyl-2-propanol
2-Methyl-1-propene
2-Methyl-2-propenenitrile
2-Methyl-2-propenoic acid,
methyl ester
1-Methyl-2-pyrrolidinone
Naphthalene
2,2' ,2"-Nitri1otrisethanol
Nitrobenzene
1-Nonanol
1-Nonene
Nonylphenol
Nonylphenol, ethoxylated
(1) 4,4'-Isopropylidenediphenol
(2) Bisphenol A
(1) Isooctyl alcohol
(2) Isooctanol
(1) Dimethyl amine
Propylene oxide
(1) Isopropyl acetone
(2) Methyl Isobutyl ketone
Cumene hydroperoxide
(1) Isobutyraldehyde
(2) Isobutylaldehyde
Isobutane
Isobutyl alcohol
(1) tert-Butyl alcohol
(2) t-Butanol
(1) Isobutylene
(2) 2-Methylpropene
Methacrylonitri1e
(1) Methacrylic acid methyl ester
(2) Methyl methacrylate
1-Methyl-2-pyrrolidone
(1) Naphthene
(2) Naphtha!in
(1) Triethanolamine
(2) Triethylolamine
Nitrobenzol
(1) n-Nonanol
(2) Nonyl alcohol
Tripropylene
E-9
-------
LIST OF CHEMICALS AFFECTED BY DISTILLATION NSPS (CONTINUED)
Chemical
Common Names
Octene
Oil-soluble petroleum sulfonate,
calcium salt
Oil-soluble petroleum sulfonate,
sodium salt
Oxirane
2,2'-Oxybisethanol
Pentane
3-Penetenenitrile
Pentenes, mixed
Phenol
1-Phenylethyl hydroperoxide
Propanal
Propane
1,2-Propanediol
Propanenitrile
1,2,3-Propanetriol
Propanoic acid
1-Propanol
2-Propanol
2-Propanone
1-Propene
2-Propenenitrile
2-Propenoic acid
2-Propenoic acid, butyl ester
2-Propenoic acid, ethyl ester
Propylbenzene
Sodium cyanide
Ethylene oxide
Diethylene glycol
n-Pentane
(1) Carbolic acid
(2) Hydroxybenzene
Propionaldehyde
Dimethyl methane
Propylene glycol
(1) Propionitrile
(2) Ethyl cya.nide
(1) Glycerol
(2) Glyceryl
(3) Glycerin
Propionic acid
Propyl alcohol
Isopropyl alcohol
(1) Acetone
(2) Dimethyl ketone
Propylene
Acrylonitrile
Acrylic acid
Butyl acrylate
Ethyl acrylate
Phenylpropane
Cyanogran
E-10
-------
LIST OF CHEMICALS AFFECTED BY DISTILLATION NSPS (CONTINUED)
Chemical
Common Names
Tallow acids, potassium salt
Tallow acids, sodium salt
1,3,5,7-Tetraazatricyclo
(3.3.1.13.7)-decane
Tetrabromomethajrie
1,1,2,2-Tetrachloroethane
Tetrachloroethene
Tetrachloromethane
Tetraethylplumbane
Tetrahydrofuran
Tetra (methyl-ethyl) plumbane
Tetramethylpiumbane
1,3,5-Triazine-2,4,6-rtriamine
Tribromomethane
1,1,l-Tribromo-2-methyl-2-propanol
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Trichloroethene
Trichlorofluoromethane
Triehioromethane
2,4,6-rTrichloro-l ,3,5-triazine
l,l,2-Trichloro-l,2,2-
trifluoroethane
2,6,6-rTrimethyl bicycl o
(3.1.1) hept-2-ene
Urea
Urea ammonium nitrate
(1) Hexamine
(2) Hexamethylene tetraamine
Carbontetrabromide
(1) Tetrachloroethylene
(2) Perch!oroethylene
Carbon tetrachloride
Tetraethyl lead
THF
Tetra (methyl-ethyl) 1ead
Tetramethyl lead
(1) Mel ami ne
(2) 2,4,6-:Triamino-s-triazine
Bromoform
(1) Tribromo-t-butyl alcohol
(2.) Acetone-bromoform
(3) Brometone
Methyl chloroform
Vinyl trichloride
Triehioroethylene
(1) Freon 11
(2) Fluorotrichloromethane
Chloroform
N
(1) Cyanuric chloride
(2) 2,4,6-Trichloro-s-triazine
(1) Trichlorotrifluoroethane
(2) Fluorocarbon 113
a-Pinene
(1) Carbamide
(2). Carbonyldiamide
E-ll
-------
-------
APPENDIX F
COSTING ALGORITHMS
-------
-------
APPENDIX F
DESIGN AND COSTING ALGORITHMS
The purpose of this appendix is to present the calculative steps
describing the control device design and costing algorithms used in the
regulatory analysis and to provide the basis for the assumptions used. The
algorithms presented in the appendix were used to estimate the costs
associated with controlling distillation vent streams in the National
Emission Profile using combustion devices (flares, boilers, and incinerar
tors). These costs were used to evaluate the impacts of various regulatory
possibilities. The cost algorithms for the three separate control systems.
evaluated in the regulatory analysis are presented in the following
sections.
The design procedures for boilers and incinerator/scrubber systems
involve the development of heat and material balances for the various
subsystems associated with each control device. For instance, the boiler
design involves determination of boiler applicability primarily through heat
transfer considerations. It is impractical to present the entire, detailed
calculative,procedures in this reference. The programs used in computing
designs and costs for these control systems are presented in the "Distilla-
tion Operations Regulatory Analysis Program Guide" which explains the
purpose and use of the computer analysis routines.
F.I FLARE ALGORITHMS
The algorithms used in designing flare systems were taken from vendor
design algorithms presented in the IT Enviroscience study of the Organic
2
Chemical Manufacturing Industry. The capital costs for new flares were
based on cost curves presented in that study and adjusted from 1979 dollars
to 1978 dollars. No capital costs were assumed for existing flare systems.
The same costing algorithms were used for annualized costs for both new and
existing flares.
Vendor contacts were also the source for the following assumptions:
pressure drop, commercially available flare sizes, flame emissivity, wind
F-l
-------
velocity, number of pilots, pilot gas requirements, and purge gas require-
3 4
ments. * The values for each assumption were selected to be representative
of flares designed for the chemical industry.
The total installed capital cost equation was derived from IT Enviro-
science and from vendor contacts. ' Review of the IT Enviroscience data
indicated that the costs presented were specific for flaring propylene.
Since the design was specific to propylene, a bias in the ratio of height to
diameter occurs. Additional cost data were obtained from vendors for flare
systems designed outside this ratio. Correlations relating the height and
diameter of the flare to the total installed capital costs were developed
and used in the costing of new flare systems. The selection of 150 Btu/scf
as a minimum heating value for stable flaring was based on vendor contacts.
The fuel requirement is chemical specific and typically ranges from 100 to
150 Btu/scf.
Calculation
(1) Calculate fuel requirement
for the emission stream.
(2) Calculate total mass flow.
(3) Calculate flare tip diameter.
D =
(4) Calculate flare height.
2.72
0 Jj + 460"
x 10 "Mf MW
VA^T
H =
-3.33D
VM LHV e
12.56 I
55
JL
COS 0
where 0 = tan
-1
1.47 V,
w
Assumption(s)
(a) A heating value of 150 Btu/scf
is required for stable flaring.
(a) Ap = 27" w.c.
(b) 2" minimum size available.
(a)
(b)
(c)
(d)
e
I
Vw
30
= 0.13 9
= 1200 Btu/hr ftr
= 60 mph
1 minimum height available.
F-2
-------
(5) Calculate number of pilots
required.
(a) No,
(6) Calculated pilot gas require
ment.
(7) Calculate installed capital
cost.
= °'895 (23086 +
193.6 D2 + 5.7 H2)
(8) Calculate purge gas require-
ment.
(9) Calculate steam requirement.
(a)
2
3
4
5
Tip Diameter
D < 8"
8" < D < 24"
24"< D < 42"
42"< D < 70"
D > 70^
Each pilot requires 80 scfh
natural gas.
(a) Minimum flare gas velocity at
tip of 0.04 ft/sec.
(a) 0.4 Ib steam per Ib vent gas
required.
(10) Calculate annualized operating
costs.
Nomenclature for Flare Algorithms
D = Flare tip diameter, in
H = Flare height, ft
LHV = Vent stream lower heating value, Btu/lb
M
MW
Ap
T
I
V
w
e
0
= Vent stream mass flowrate, Ib/hr
= Vent stream mean molecular weight
= Flare tip pressure drop, in. HpO
= Vent stream temperature, °F
f
- flame radiation intensity, Btu/hr/ft^
= Wind velocity, miles/hr
= flame emissivity
= Wind effect
F.2 INDUSTRIAL BOILER ALGORITHMS
The majority of the modeling provided for industrial boilers was
focussed on determining the applicability of a boiler to destroying VOC
F-3
-------
contained in distillation vent streams. In order to evaluate applicability,
the boiler design parameters had to be examined along with the changes
expected with the addition of a distillation vent stream to the boiler. The
annual fuel savings associated with combustion of a distillation vent stream
were also evaluated as part of the design procedure.
A boiler was assumed to be available for use in destroying the VOC in
the vent streams. Therefore, only modifications to the boiler would be
needed to permit its use as a control device. Since a single boiler size
was assumed in the modeling, a single capital cost of modifications was
used. Annualized costs were based primarily on the fuel savings resulting
from the VOC combusted.
The selection of a 34.1 million Btu/hr, natural gas fired, watertube
boiler as a "characteristic" boiler in the organic chemical industry was
based on a survey of industrial boilers. The survey indicated that
70.1 percent of the industrial boiler capacity is made up of watertube
boilers, while firetube and cast iron boilers make up 24.1 and 5.8 percent,
o
respectively. In addition, natural gas was the predominant fuel identified
in the chemical industry; it accounted for 60.0 percent of the units and
q
53.7 percent of the capacity. The average size natural gas boiler in the
chemical industry was given in the survey report as 95 x 10 Btu/hr.
Figure F-l shows the size distribution of industrial natural gas fired
watertube boilers.
The other assumptions presented in the following design procedure were
based on modeling the specific boiler type described. Worst case costs were
developed for the burner and fan modification. A 35 million Btu/hr burner
capable of burning low heating value gases is provided. The fan
modification includes a motor and fan capable of handling the vent gases and
fuel products of combustion for the largest vent in the national emissions
profile.
F-4
-------
4000 -
2000 .
Package Watertube Boilers
2000
CD
O
CD
o
cu
e
4000
2000
0-
Field-erected Watertube Boilers
Natural Gas Fired Boilers
0.1 0.4 2.9 7.3 14.7 29.3 73.3 146.5 439.5
Boiler Size Ranges, MW
Figure F-l. Distribution of Industrial Boiler Types.
F-5
-------
Calculation
(1) Select boiler size and type.
(2) Calculate fuel requirement,
flue gas volume and composi-
tion, and adiabatic flame
temperature for the emission
stream.
(3) Calculate furnace heat
transfer.
(a)
(b)
(a)
(b)
(c)
(a)
total
Watertube
Assumption(s)
=34.1 x 106
Btu/hr
Natural gas fired
85% overall thermal efficiency
18% excess air for combustion
Tfe = 2000°F
Mi Cpmi
-------
(8) Introduce vent stream into
boiler.
(9) Recalculate flue gas volume
and composition and adiabatic
flame temperature.
(10) Calculate furnace heat
transfer.
^furn vs ~ furn a
(11) Calculate furnace exit
temperature.
Tfe ~ TAFT
n
Em.. C
pmi
T
(a) 10 percent supplemental fuel
can be fired through burners.
T
(12) Assume stack temperature.
(13) Revise boiler heat transfer
variable.
fl'
vs
(14) Calculate stack temperature.
(15) Compare assumed and calculated
stack temperatures. Return to
(12) if necessary.
(16) Calculate boiler heat transfer.
n
Qboil vs =
(a) Musselt type heat transfer
coefficient.
'i Cpmi ^Tfe " Tstack'
(17) Calculate total heat transfer.
^total vs ~ ^furn vs ^boil vs
F-7
-------
(18) Compare total heat transfer
with and without vent stream.
If Qtotal vs bo11er
is considered not applicable as
a control device. Otherwise
return to (8) and reduce
supplemental fuel until
Qtotal vs = Qtotal
(19) Calculate fuel requirement/savings.
(20) Calculate annualized operating (a) Worst case costs for burner/
cost. fan modifications. (Capital
cost of modifications taken
to be $10,000.)
Nomenclature For Boiler Algorithms
A = Area, ft2
C = Mean heat capacity, Btu/lb mol/°F
h A = Convective heat transfer variable
k = Thermal conductivity
m = Molar flowrate, Ib mol/hr
M = Mass flowrate, Ib/hr
Q = Rate of heat transfer, Btu/min
T = Temperature, °R or °F
a = Absorptivity
e = Emissivity
p = Density
v = Viscosity
a = Stefan - Boltzman constant
Subscripts:
AFT = Adiabatic flame temperature
boil = Boiler
furn = Furnace
fe = Furnace exit
9 = Gas
1m = Log mean
s = Furnace surface
vs = Vent stream
F-8
-------
F.3 THERMAL INCINERATOR ALGORITHMS
The design and cost of the thermal incinerator were based on the
control device evaluation reports developed from a survey of the organic
chemical manufacturing industry. ' The design criteria for the thermal
incinerator system depend upon the constituents of the stream to be treated;
for example, where a halogenated stream must be treated, the following
considerations must be made:
(1) higher combustion temperature
(2) more costly materials of construction for corrosion
and temperature
(3) hydrogen addition to convert the halogen to acid
(4) absorber to remove halogen acid
(5) caustic to treat the acid absorbed from the offgas.
In general, the design procedure for the thermal incinerator system
involves the following steps:
(1) determination of oxygen requirements for complete combustion
(2) determination of natural gas requirements for flame stability
(3) determination of dilution air requirements to maintain a
combustion temperature
(4) determination of hydrogen requirements to form halogen acid
from halogenated VOC (if halogenated VOC is included in the
vent stream)
Based on these requirements, a heat and material balance is made to deter-
mine the key design parameters used in evaluating capital costs. These
parameters are volumetric gas flowrate through the incinerator and heat
transfer area needed to extract the optimum amount of heat by recuperative
heat exchange. The combustion chamber volume, which is used in determining
the incinerator cost, can be computed with the known gas flowrate, combus-
tion temperature, and residence time requirements. Capital cost algorithms
for these systems were based on the cost curves presented in the survey
reports of control devices in the organic chemical industry referenced
above.
F-9
-------
The results of the heat and material balance also allow the evaluation
of several annualized costs for incinerator/scrubber systems: quench water
requirements, make-up water requirements, and caustic requirements.
The stepwise calculation procedure is presented below. And the
computer program (FORTRAN code) can be found in "Distillation Operations
12
Regulatory Analysis Program Guide".
Calculation
(1) Calculate fuel requirement
for the emission stream.
(2) Calculate fuel for flame
stability.
(3) Calculate flue gas volume.
(4) Calculate combustion chamber
volume.
(5) Size recuperative heat
exchanger. (If there is no
heat exchanger provided.)
(6) If no corrosive compounds
present go to (10).
(7) Calculate quench water require-
ments.
(8) Revise flue gas volume.
(9) Calculate amount of caustic
required.
(a)
(b)
(a)
(a)
(b)
(a)
Assumption(s)
1600°F combustion chamber
temperature, 2000°F for
corrosive compounds.
18 percent excess air.
Auxiliary fuel supplied as
follows:
H < 50 Btu/scf
50 < H<100 Btu/scf
100 < H
10 Btu/scf
added
10% of stream
heat value
No fuel
0.75 second residence time,
1.0 second for corrosive
compounds.
3
34.7 ft minimum size.
Overall heat transfer coefficent
of 4 Btu/ft2/hr/°F assumed.
(a) Flue gases must be cooled to
212°F before entering scrubber.
F-10
-------
(10) Calculate installed combustion chamber cost.
1600° combustion temperature:
Chamber cost = 3.58 [51,969. + 67.99 V - 0.0014 V 2]
cc cc
2000°F combustion temperature:
Chamber cost = 3.58 [50,490. + 55.33 .Vcc - 0.0001 VC(,2]
(11) Calculate installed heat exchanger cost.
Exchanger cost = 2.28 [18,574. + 33.606 A^0'9139]
(12) Calculate quencher/scrubber cost, if necessary.
Scrubber cost = 0.895 [180,139. + 54.992 F - 0.00123 F2]
(13) Calculate total installed capital cost.
(14) Calculate annualized operating cost.
Nomenclature For Thermal Incinerator/Scrubber Algorithms
A = Area, ft2
F = Flue gas volumetric flowrate, scfm
V = Volume, ft3
Subscripts:
cc = Combustion chamber
he = heat exchanger
F.4 PIPELINE ALGORITHMS
The pipeline models presented here were used in combination with all
the combustion control options considered in the regulatory analysis (new
flares, existing flares, boilers, incinerators). Since each control option
required a pipeline connection, a separate model was developed. The model
is based on an optimal pipe diameter design. For each distillation column,
three pipe "legs" as shown in Figure F-2 were designed: a source leg, a
compressor leg, and a pipe leg.
As discussed in Chapter 6, the final regulatory analysis involved a
single column analysis of combustion control. That is, each individual
column in a plant was costed with a separate pipeline system. (This
individual column treatment is used only for selecting columns for control
F-ll
-------
en
-o
to
O)
CVI
I
O)
J-
F-12
-------
in the regulatory analysis.) Another approach to costing pipeline systems
considers combining several vent streams from one plant to minimize the cost
of piping. Multiple vents in process units are typically combined in a
common header without creating a serious safety hazard. This combined vent
approach was maintained in the costing done for the worst case model used in
the economic screening analysis (Chapter 9) and for reporting estimated
national control costs (Chapter 8). Since a chemical specific investigation
of explosive limits would be necessary to determine those vents Which could
be combined and those which would require separate venting, the pipeline
model assumed the first three vents to be individually vented. Each
additional vent stream in a plant would then be combined with one of these
three vents. Furthermore, as discussed in Chapter 6, analysis of plant
costs using either pipeline costing approach results in similar costs.
Equations and correlations for economic pipe diameter, pressure drop,
brake horsepower, and electricity were obtained from the
literature.13'14'15'16 The costs of installed piping, in $/100 ft of
piping, was based on tabulated data provided by a vendor contact.
Derivation of the equations presented for piping design are given in
Reference 17. Compressor cost correlations as a function of horsepower were
developed from vendor contacts.
Calculation Assumption(s)
(1) Identify number of distillation
vents.
(2) Divide into 3 vents such that (a) Vents can be combined into
combined flows are nearly 3 headers without safety
identical. problems.
(3) Calculate economic source leg
diameter.
DS = 0.042F - 0.472 (for F <40 scfm)
D = 0.009F + 2.85 (for 40 scfm ^F <700 scfm)
F-13
-------
(4) Select commercially available (a) Schedule 40 carbon steel pipe.
pipe diameter.
(5) Calculate source leg pressure drop.
AP = CM2 (1 x 10"9)/p
(6) Calculate economic compressor leg
diameter.
D = 0.015F + 0.56 (for <150 scfm)
c
D = 0.0042F + 2.58 (for 150 scfm
-------
TABLE F-1. PIPELINE COMPONENTS
Hardware
Schedule 40 pipe
Check Valves
Gate Valves
Control Valves
Strainers
.. Elbows
Tees
Flanges
Drip Valves
Expansion Fittings
Bolt $ Gasket Sets
Hangers
Field Welds
Source
Leg
70'
1
4
1
1
8
6
IS
1
2
15
9
18
Compressor
Leg
20'
1
2
0
1
6
2
10
1
. 1
12
4
12
Pipe
Leg
500'
1
3
1
1.
6
3
14
1
1
12
50
14
F-15
-------
Nomenclature For Pipeline Algorithms
BMP = Compressor brake horsepower, bhp
C = Coefficient based on diameter
D = Diameter, inches
F = Volumetric flowrate, scfm
kwh = Compressor electricity requirement
M = Mass flowrate, Ib/hr
AP = Pressure drop, in H00
3
p = Density, Ib/ft
Subscripts: •
c = Compressor leg
p = Pipe leg
s = Source leg
F-16
-------
F.5 REFERENCES
1. Memo from Senyk, D. and J. Stalling, Radian Corporation, to Distillation
File. August 30, 1982. 192 p. Distillation Operations Regulatory
Analysis Program Guide.
2. Kalcevic, V. (Hydroscience). Emission Control Options for the Synthetic
Organic Chemicals Manufacturing Industry, Control Device Evaluation:
Flares and the Use of Emissions as Fuels. (Prepared for U. S.
Environmental Protection Agency.) Research Triangle Park, NC. EPA
Contract No. 68-02-2577. August 1980.
3. Joseph, D., et al. (Energy & Environmental Research Corporation)
Evaluation of the Efficiency of Industrial Flares, Interim Report.
(Prepared for U. S. Environmental Protection Agency.) Research Triangle
Park, NC. EPA Contract No. 68-02-3661. January 1982.
4. Straitz, J. F. Nomogram for Sizing Process Flares. Parts 1 and 2.
Philadelphia, Pennsylvania. National Air Oil Burner Company, Inc.
(In-hours brochure). 1979.
5. Reference 2, p. B-3.
6. Memo from Sarasua, A. I., Energy and Environmental Analysis, to Polymers
and resins file. May 12, 1982. 15 p. Information on the flare Costing
program (FLACOS).
7. Reference 3.
8. Devitt, T., et al (PEDCo). The Population of Industrial and Commercial
Boilers. (Prepared for U. S. Environmental Protection Agency.) Research
Triangle Par, NC. EPA Contract No. 68-02-2603. May 1979.
9. Reference 8, p. xix.
10. Blackburn, J. W. (Hydroscience). Emission Control Options for the
Synthetic Organic Chemicals Manufacturing Industry, Control Device
Evaluation: Thermal Oxidation. (Prepared for U. S. Environmental
Protection Agency.) Research Triangle Park, NC. EPA Contract
No. 68-02-2577. July 1980.
11. Basdekis, H. S. (Hydroscience). Emissions Controls Options for the
Synthetic Organic Chemicals Manufacturing Industry, Control Device
Evaluation: Thermal Oxidation Supplement, VOC Containing Halogens or
Sulfur. (Prepared for U. S. Environmental Protection Agency.) Research
Triangle Park, NC. EPA Contract No. 68-02-2577. November 1980.
12. Reference 1.
F-17
-------
13. Perry, R. H., and C. H. Chilton, editors. Chemical Engineer's Handbook.
5th Edition. New York, McGraw-Hill, 1973. p. 5-31.
14. Crane Engineering Division. Flow of Fluids Through Valves, Fittings, and
Pipe. New York, Crane Company. Technical Paper No. 410, 1969. p. 3-22.
15. Memo from Desai, T., Energy & Environmental Analysis, to file. March 16,
1982. Procedure to estimate piping costs.
16. Reference 12, p. 24-3.
17. Memo from Kawecki, T., Energy & Environmental Analysis, to file.
November 13, 1981. Distillation pipeline costing model documentation.
F-18
-------
APPENDIX G
TRE DEVELOPMENT
-------
-------
APPENDIX G
TRE DEVELOPMENT
In order to determine the "reasonableness" of requiring combustion
controls (flare, boiler, or incinerator) on distillation vent streams, the
total resource effectiveness (or TRE) of control must be evaluated. The TRE
represents the total resources (cost, energy) required to remove volatile
organic compounds (VOC) for a distillation vent stream. To be of maximum
utility, the TRE is based on vent stream characteristics that are readily
available or determined.
This appendix presents the derivation of the equations for TRE and TRE
index. The TRE equations are generalized cost equations developed from the
calculated control costs for individual distillation vent streams listed in
the screened National Emission Profile (NEP). All of the coefficients for
each generalized cost equation were determined by linear regression using
the General Linear Model Procedure of the SAS* software library.
G.I DEFINITION OF TRE INDEX
TRE (expressed in $/Mg) is a measure of the total resources required
for control of a unit of VOC from a single distillation unit. For nonhalo-
genated vent streams, the TRE is calculated based on control by flares.
However, this does not preclude actual use of a boiler or incinerator. It
simply means that the TRE determination for nonhalogenated vent streams is
based on the cost of flaring. For halogenated vent streams (defined as
streams containing 20 ppm or greater halogenated species), the TRE is
calculated based on control by incinerator/scrubber systems. All resources
expected to be used in VOC control are considered in the TRE development.
The primary resources used are capital charges, supplemental natural gas,
and, for halogenated vent streams, caustic. Other resources used include
labor, electricity, and, for halogenated vent streams, make-up water for
scrubbing and quenching of the incinerator offgases.
Statistical Analysis System Institute, Inc., Post Office Box 10066,
Raleigh, North Carolina 27605.
G-l
-------
The TRE for any distillation unit is based on the offgas characteris-
tics (specifically flowrate, VOC emission rate, and net heating value of the
vent stream). Once the TRE has been calculated, the TRE index is determined
by simply dividing the TRE by $1900/Mg. Therefore, the TRE index is a
dimensionless measure of the resource burden associated with control of a
new or modified distillation unit. In order to make the TRE index indepen-
dent of the general inflation rate, certain assumptions have been made to
fix the relative costs of various resources, such as carbon steel
construction and natural gas fuel.
Within the framework of a new source performance standard, a particular
TRE index value can be chosen to serve as the upper limit for requiring
combustion control of a distillation vent stream. Distillation emission
streams with associated TRE indices above that upper limit would not have to
be controlled. Use of the TRE index in this manner would encourage the use
of product recovery techniques or process modifications to reduce VOC
emissions. The TRE index is calculated based on the vent stream character-
istics at the outlet of the final piece of product recovery equipment. Use
of product recovery equipment on a vent stream would decrease VOC emissions
and, thereby, increase the TRE index value.
6.2 DEVELOPMENT OF TRE EQUATION COEFFICIENTS
The total resources required to control VOC emissions from a distilla-
tion vent are primarily dependent on three vent stream characteristics:
flowrate, VOC emissions rate, and net heating value. These characteristics
are primary factors considered in the design and costing of flare and
incinerator control systems (see Appendix F). Flowrate is perhaps the most
important factor to be considered in sizing control equipment. It impacts
auxiliary equipment sizing (piping, fans, etc.) as well. The VOC emissions
rate and heat content of a vent stream impact annualized control costs by
determining the supplemental fuel requirements. Therefore, an equation for
calculating TRE was assumed to be a function of these three vent stream
characteristics.
6-2
-------
The heat content of the vent stream cannot be assumed to be a constant
function of flowrate and VOC emissions rate for any of the control
situations considered, since the heat of combustion (on a mass basis) ranges
from about 48.8 MJ/kg (21,000 Btu/lb) for paraffins and olefins to much
lower values for aromatic compounds, oxygenated compounds, and halogenated
compounds. Thus, a simplification of the TRE equation by using a constant
heat content is not feasible.
The coefficients for the three TRE equation parameters depend on the
control device used (i.e., either a flare or an incinerator). Therefore,,
three sets of coefficients were determined for each of the following
situations: combustion with a flare for vent streams with heating value
below 5.6 MJ/scm (150 Btu/scf), combustion with a flare for vent streams
with a heating value at or above 5.6 MJ/scm (150 Btu/scf), and combustion
with an incinerator/scrubber system.
In determining the coefficients, the resource requirements for control
were calculated first for all combinations of streams (within a plant)
represented in the screened National Emission Profile (NEP). The costing
algorithms used in the regulatory analysis and outlined in Appendix F were
used in calculating these resource requirements. The resource requirement
values obtained provided the data input to the linear regression models
which, in turn, computed correlation coefficients.
G.3 TRE CORRELATION RESULTS •
The total resource requirement for controlling a vent stream includes
the cost associated with the control device and the cost associated with
piping the vent stream to the control device. Therefore, correlation
coefficients were determined for the annualized cost of flares, incinera-
tors/scrubbers, flare piping, and incinerator piping. These individual
component costs were then combined to yield the total resource requirement
for each of the three situations described previously.
6.3.1 Flare Pipeline Correlation
A linear regression was performed on the pipeline cost data for flares
2
for a range of flows from 0.003 to 18.0 scm/min.* This regression had an r
This range includes all expected flows from new distillation vents.
G-3
-------
value of 0.992 and the resulting model is accurate to ± $495/yr at a
95 percent confidence level:
Cost = 1716 Q0-8 + 2959 (6-1)
where:
Cost = Annual Cost ($/yr)
Q = Vent Stream Flowrate (scm/min)
6.3.2 Incinerator Pipeline Correlation
The linear regression performed on the pipeline cost data for incinera-
tors yielded an equation of the same form as that for flare pipeline cost
2
for the same flow range. This regression had an r value of 0.993 and was
determined to be accurate to ± $363.0/yr at a 95 percent confidence level:
Cost = 1312 Q0-8 + 2292 (6-2)
G.3.3 Flare Correlation
A single model for annualized flare cost would not accurately cover all
streams in the NEP. The supplemental fuel required for streams with a
heating value below 5.6 MJ/scm (150 Btu/scf) required a different cost model
than that resulting for streams with a heating value equal to or above
5.6 MJ/scm. Therefore, two separate linear regressions were made, one for
streams with a heating value below 5.6 MJ/scm and one for streams with a
heating value equal to or above 5.6 MJ/scm. These regressions yielded the
2
following equations with r values of 0.9999 and 0.971, respectively:
Heating value below 5.6 MJ/scm
Cost = 16651 Q - 2465 QH - 1.43 V + 17923 . (6-3)
Heating value equal to or above 5.6 MJ/scm
Cost = 2338 Q + 128.9 QH - 44.8 V + 18009 (6-4)
where
H = Vent Stream Heating Value (MJ/scm)
V = VOC Emission Rate (kg/hr)
G-4
-------
The equation for low heating values, accurate to ± $648.3/yr at a
95 percent confidence level, was developed for flows ranging from 0.037 to
18.0 sctn/min and a range of heating values below 5.6 MJ/scm. The data base
included a range of VOC emission rates from 0 to 100 kg/hr. The equation for
high heating values, accurate to ± $3759/yr at a 95 percent confidence
level, was determined for flows ranging from 0.003 to 16.3 scm/min and a
range of heating values from 5.6 to 185 MJ/scm. The data base included a
range of VOC emission rates from 0.1 to 17.00 kg/hr.
G.3.4 Incinerator Correlation
A-multivariable regression was run for incinerator annual costs. This
regression included the same variables as for the flare annualized cost
equation, plus additional terms to characterize the incinerator more fully.
The additional terms were justified since an incinerator design is more
dependent upon operating temperature, flow rate and vent stream heat content
than is the design of a flare. The following model, accurate to ±$23209/yr,
was developed for a range of flows from 0.003 to 18.0 scm/min and heating
2
values ranging from 0 to 185 MJ/scm. The regression had an r value of
0.936.
Cost = 20603 Q + 2399 H + 377 QH (6-5)
- 33908 Q0-8 - 6772 H°'8 + 76.7 V + 211013
G.3.5 Total Annualized Cost Equations
Adding the equation for pipeline annual cost to the equation for the
annual ized cost of the applicable combustion device gives an equation for"
the total annual ized cost for flares and for incinerators. The resulting
equations for flares are as follows:
Heating value below 5.6 MJ/scm
Cost = 16651 Q + 1716 Q°'8 - 2465 QH - 1.43 V + 20881 (6-6)
Heating value equal to or above 5.6 MJ/scm
Cost = 2338 Q + 1716 Q°'8 + 128.9 QH - 44.8 V + 20967 (6-7)
G-5
-------
The equation for an incinerator is as follows:
Cost = 20603 Q - 32596 Q°'8 + 2399 H + 377 QH (6-8)
- 6772 H°'8 + 76.7 V + 213305
G.4 DEVELOPMENT OF TRE AND TRE INDEX EQUATIONS
Dividing the annualized cost equations by the VOC emission reduction
give equations for annualized control cost per megagram ($/Mg) or TRE. VOC
emission reduction is the annual VOC emission rate* multiplied by the
control efficiency of the combustion device (98 percent). The TRE equations
are of the form:
$/Mg = (aQ + bQ°*8 + cH + dQH + eH°*8 + fV + g)/V (6-9)
Where
$/Mg = Annualized Control Cost Per Megagram VOC Reduced
Q = Vent'Stream Flowrate (scm/min)
H = Vent Stream Heating Value (MJ/scm)
V = VOC Emission Rate (kg/hr)
and where coefficients a through g are as shown in Table 6-1.
Dividing these equations by $1900/Mg gives equations for the TRE index.
The format of the TRE index equations is the same as the format for the $/Mg
equations. The coefficients for the TRE index are shown in Table 6-2.
*Annual VOC emission rate,
Mg. = V /kcK x 8760 ,JUN x 0.001 ,M
-------
TABLE 6-1. COEFFICIENTS FOR TRE ($/Mg) EQUATION.
Flare
H < 5.6 MJ/scm
Flare
H ^5.6 MJ/scm
Incinerator
a
2520
354
3116
b
260
260
-4931 .
c
0
0
362
d
-373
19.5
56.9
e
0
0
-1022
f
-0.216
-6.78
11.6
g
3160
3170
32260
-------
CTi
I
00
TABLE G-2. COEFFICIENTS FOR TRE INDEX EQUATION
Flare
H < 5.6 MJ/scm
Flare
H ^ 5.6 MJ/scm
Incinerator
a
1.33
0.186
1.64
b
0.137
0.137
-2.60
c
0
0
0.190
d
-0.196
0.0103
0.0300
e
0
0
-0.538
f
-0.00011
-0.0036
0.0061
g
1.66
1.67
17.0
-------
APPENDIX H
UNITED STATES ORGANIC CHEMICAL PRODUCERS, PLANT
LOCATIONS, AND CHEMICALS PRODUCED, 1978
-------
-------
APPENDIX H
UNITED STATES ORGANIC CHEMICAL PRODUCERS, PLANT
LOCATIONS, AND CHEMICALS PRODUCED, 1978
Producer
Agway, Inc.
Airco, Inc.
Air Products &
Chemicals, Inc.
Akzona
Alcolac, Inc.
Allegheny Ludlum
Industries, Inc.
Allied Chemical Corp.
Plant Location
Olean, NY
Cleveland, OH
Louisville, KY
Pace, FL
Pensacola, FL
McCook, IL
Morris, IL
Baltimore, MD
LaPorte, TX
Baton Rouge; LA
Danville, IL
Detroit, MI
Elizabeth, NJ
El Segundo, CA
H-l
Chemicals Produced
Urea
Cyclopropane
Ethyne
N-Methylmethanamine
Methanol
Methyl amine
Urea
(2-Ethylhexyl) amine
(2-Ethylhexyl) amine
Dodecylbenzenesulfonic acid,
sodium salt
Linear alcohols, sulfated,
sodium salt, mixed
Carbonic dichloride
Chloroethane
Dichlorodif1uoromethane
1,2,-Dichloroethane
Trichlorofluoromethane
l,l,2-Trichloro-l,2,2-trifluoro-
ethane
Dichlorodifluoromethane
Trichlorofluromethane
Naphthalene
Di chlorodi f1uoromethane
Tri chlorofluoromethane
Di chlorodif1uoromethane
1,3-Isobenzofurandione
Trichlorofluoromethane
-------
Producer
Plant Location
Chemicals Produced
Amerada Hess
American Cyanamid Co.
Frankford, PA
Geismar, LA
Helena, AR
Hopewell, VA
Ironton, OH
Moundsville, WV
Omaha, NB
South Point, OH
St. Croix, VI
Bound Brook, NJ
New Orleans, LA
Willow Island, WV
H-2
1-Methyl-l-phenylethyl hydro-
peroxi de
Phenol
2-Propanone
Ethene
Urea
Urea
Cyclohexanol
Cyclohexanone
Cyclohexanone oxime
Hexahydro-2H-azepin-2-one
Hexanedioic acid
Naphthalene
Carbonic dichloride
Chloromethane
Dichloromethane
l,3-Diisocyanato-2-(and 4-) meth-
yl benzene
1-Methyl-2,4-dinitrobenzene (and
2-Methy1-1,3-di ni trobenzene)
1-Methyl-2 ,.4"di ni trobenzene
Tetrachloromethane
trichloromethane
Urea
Formaldehyde
1,3,5-Tri azi ne-2,4,6-tri ami ne
Urea
Benzene
Dimethyl benzenes, mixed
Methyl benzene
Benzenamine
4-Methy1-1,3-benzenedi ami ne
Hydrocyanic acid
2-Propenenitrile
1,3,5-Tri azi ne-2,4,6-tri ami-ne
Urea
Benzenamine
Nitrobenzene
2-Propanone
-------
Producer
Plant Location
Chemicals Produced
American Hoechst Corp. Baton Rouge, LA
Spartansburg, SC
American Petrofina
Beaumont, TX
Big Spring, TX
Groves, TX
Port Arthur, TX
Archer Daniels Midland Decatur, IL
Co.
Arizona Chemical Co. Panama City, FL
Armco Steel Corp.
Middletown, OH
Arol Chemical Products Newark, NO
Co.
Ashland Oil, Inc.
Ashland, KY
Janesville, WI
Louisville, KY
Neal, WV
Ethenylbenzene
Ethylbenzene
1,4-Benzenedicarboxylic acid/
1,4-Benzenedicarboxy1ic aci d,
dimethyl ester
Dimethyl benzenes, mixed
Methyl benzene
Benzene
Cyclohexane
1,2-Dimethylbenzene
Ethenylbenzene
Ethylbenzene
Methyl benzene
2-Methy1-1-propene
1-Propene
1-Propene
Benzene
Ethanol
2,6,6-Trimethy1 bieye 1 o [3.1.1]-
hept-2-ene
Benzene
Dimethyl benzenes, mixed
2-Methy1 butane
Dodecylbenzenesulfonic acid,
sodium salt
Benzene
Dimethyl benzenes, mixed
Methyl benzene
(1-Methylethyl) benzene
Naphthalene
1-Propene
Dodecylbenzenesulfonic acid,
sodium salt
Linear alcohols, ethoxylated,
mixed
1-Propene
2,5-Furandione
H-3
-------
Producer
Plant Location
Chemicals Produced
North Tonawanda,
NY
Atlantic Richfield Co. Beaver Valley, PA
Carson, CA
Channelview, TX
Houston, TX
Avtex Fibers, Inc.
Port Arthur, TX
Meadville, PA
Benzene
Dimethyl benzenes, mixed
Methyl benzene
Ethylbenzene
Diethyl benzene
Benzene
Dimethyl benzenes, mixed
1-Dodecene
Ethene
Methyl benzene
1-Nonene
1-Propene
Benzene
1,3-Butadiene
2-Butanol
2-Butanone
Ethene
Methylbenzene
2-Propanol
1-Propene
Benzene
Dimethyl benzenes, mixed
1,2-Dimethylbenzene
1,3-Dimethylbenzene
1,4-Dimethyl benzene
Ethene
Ethenylbenzene
Ethyl benzene
Methyl benzene
1-Propene
Ethyl benzene
Acetic acid, anhydride
BASF Wyandotte Corp.
Geismar, TX
1,4-Butanediol
Carbonic dichloride
l,3-Diisocyanato-2-(and 4-) meth-
ylbenzene
Oxirane
2,2'-Oxybisethano1
1-Propene
H-4
-------
Producer
Plant Location
Kearny, NJ
Wyandotte, MI
Palo Alto, CA
Bethlehem, PA
Sparrows Point,
MD
Bison Nitrogen Products Woodward, OK
Bofors Lakeway, Inc. Muskegon, MI
Beckman Inst., Inc.
Bethlehem Steel
Borden
Demopolis, AL
Diboll, TX
Fayetteville, NC
Freemont, LA
Geismar, LA
Louisville, KY
Kent, WA
LaGrande, OR
Missoula, MT
Chemicals Produced
1,2-Benzenedicarboxylic acid
bis (2-ethylhexyl) ester
1,3-Isobenzofurandione
Linear alcohols, ethoxylated,
mixed
Methyloxirane
Heptane
Benzene
Dimethyl benzenes, mixed
Methylbenzene
Benzene
l,l'-Biphenyl
Dimethyl benzenes, mixed
Methyl benzene
Urea
Dodecylbenzenesulfonic acid,
sodium salt
Linear alcohols, ethoxylated and
sulfated, sodium salt, mixed
Linear alcohols, sulfated, sodium
salt, mixed
Formaldehyde
Formaldehyde
Formaldehyde
1,3,5,7-Tetraazatricycl o-
[3.3.1.15'/]decane
Formaldehyde
Acetic acid
Acetic acid, ethenyl ester
Chloroethene
Formaldehyde • ~
Methanol
Urea
Formaldehyde
Formaldehyde
Formaldehyde
Formaldehyde
H-5
-------
Producer
Plant Location
Chemicals Produced
Borg-Warner Corp.
Sheboygan, WI
Springfield, OR
Morgantown, WV
Formaldehyde
Formaldehyde
Nonylphenol
CF&I Steel
C.F. Industries, Inc.
Calcasieu Chemical
Corp.
Caribe Isoprene Corp.
Celanese Corp.
Pueblo, CO
Dona!dsonvilie,
LA
Freemont, NB
Tunis, NC
Tyner, TN
Lake Charles, LA
Ponce, PR
Bay City, TX
Bishop, TX
Charlotte, NC
Benzene
Dimethylbenzenes, mixed
Methyl benzene
Urea
Urea
Urea
Urea
Oxi rane
2-Methyl-l,3-butadiene
Acetaldehyde
Acetic acid, ethenyl ester
Acetic acid
1-Butanol
Cyclohexanol
Cyclohexanone
1,6-Hexanedi ami ne
1,6-Hexanediamine adipate
Hexanedioic acid
Acetic acid, butyl ester
2,2-Bis (hydroxymethy1)-l,3"pro-
panediol
Butanal
l,2-(and l,3-)8utanediol
1-Butanol
Formaldehyde
4-Hydroxy-4-Methy1-2-pentanone
Methanol
2-Methylpropane1
2-Methyl-l-Propanol
1-Propanol
Dodecylbenzenesulfonic acid,
sodium salt
H-6
-------
Producer
Plant Location
Chemicals Produced
Clear Lake, TX
The Charter Co.
The Chemithon Corp.
Chemol, Inc.
Chemplex Co.
Ciba-Geigy Corp.
Narrows, VA
Newark, NJ
Pampa, TX
Pasadena, TX
Rock Hill, SC
Houston, TX
Chemical Exchange Co., Houston, TX
Seattle, WA
Greensboro, NC
Clinton, IA
Mclntosh, AL
Acetaldehyde
Acetic acid
2,2'-[l,2-Ethanediy1bis(oxy)]
bisethanol
Methanol
Oxirane
2,2'-Oxybisethano 1
2-Propenoic acid
2-Propenoic acid, butyl ester
2-Propenoic acid, ethyl ester
Acetic acid, anhydride
Formaldehyde
Acetic acid
Acetic acid, anhydride
Acetic acid, ethyl ester
2-Butanone
Propanoic acid
2-Propenoic acid, butyl ester
Acetic acid, ethenyl ester
Acetic acid, anhydride
Formaldehyde
Benzene
Dimethyl benzenes, mixed
1,4-Dimethylbenzene
Ethyl benzene
Heptane
Hexane
Methyl benzene
1-Propene
2,2'-[l,2-Ethanediy1bis(oxy)]
bisethanol
2,2'-Oxybisethanol
Dodecylbenzenesulfonic acid,
sodium salt
l,l'-Biphenyl
Ethene
1-Propene
2,4,6-Trichloro-l,3,5-triazine
H-7
-------
Producer
Plant Location
Chemicals Produced
Cities Service Co.
St. Gabriel, LA
Toms River, NJ
Copperhill, TN
Lake Charles, LA
Clark Oil & Refining Blue Island, IL
Corp.
Wood River, IL
Coastal States Gas Co. Cheyenne, WY
Corpus Christi,
TX
Columbia Nitrogen Corp.
Columbia Organic Chemi-
cals Co.
Commonwealth Oil
Refining Co.
Augusta, GA
Columbus, SC
Ponce, PR
Concord Chemical Co., Camden, NJ
Inc.
6-Chloro-N-etnyl-N'-(1-methyleth-
yl )-l,3,5-triazine-2,4-diamine
Hydrocyanic acid
2,4,6-Trichloro-l,3,5-triazine
(Chloromethyl) oxirane
Dodecylbenzenesulfonic acid
Dodecylbenzenesulfonic acid,
sodium salt
Benzene
Dimethyl benzenes, mixed
1,2-Oimethyl benzene
1,4-Oimethylbenzene
Ethene
2-Methyl-l-propene
1-Propene
(1-Methylethyl) benzene
Phenol
2-Propanone
1-Propene
1-Propene
Urea
Benzene
Dimethyl benzenes, mixed
Methy!benzene
(1-Methylethyl) benzene
1-Propene
Urea
lodomethane
Benzene
Cyclohexane
Dimethyl benzenes, mixed
1,2-Dimethylbenzene
Ethyl benzene
Methyl benzene
Tallow acids, sodium salt
H-8
-------
Producer
Plant Location
Chemicals Produced
Continental Chemical Clifton^ NJ
Co.
Continental Oil Co.
Cooperative Farm
Chemicals Assoc.
Copolymer Rubber &
Chemicals
Core-Lube, Inc.
CosMar, Inc.
Crest Chemical Co.
Croda, Inc.
Baltimore, MD
Hammond, IN
Newark, NJ
Westlake, LA
Lawrence, KS
Baton Rouge, LA
Danville, IL
Carville, LA
Newark, NJ
Mill Hall, PA
Newark, NJ
Crown Central Petroleum Pasadena, TX
Dodecylbenzenesulfonic acid
Dodecylbenzenesulfonic acid,,
sodium salt
Dodecylbenzene, linear
Dodecylbenzene, non-linear
Dodecylbenzenesulfonic acid,
sodium salt
Dodecylbenzenesulfonic acid
2,6-Dimethylphenol
1-Butanol
Chloroethane
Chloromethane
1,2-Dichloroethane
1-Dodecene
Ethene
Linear alcohols, ethoxylated,
mixed
1-Propene
Urea
1,3-Butadiene
Benzenesulfonic acid
Ethenylbenzene
Ethylbenzene
Dodecylbenzenesulfonic acid
Linear alcohols, ethoxylated and
sulfa'ted, sodium salt, mixed
Li near alcohols, ethoxy1ated,
mixed
Linear alcohols, ethoxylated,
mixed
Benzene
Dimethyl benzenes, mixed
1,2-Dimethyl benzene
Methyl benzene
H-9
-------
Producer
Plant Location
Chemicals Produced
Cyclo Chemicals Corp. Miami, FL
Linear alcohols, ethoxylated,
mixed
Dart Industries, Inc. Elyria, OH
Oenka Chemicals Co. Houston, TX
Diamond Shamrock Corp. Belle, WV
Cedartown, GA
Charlotte, NC
Deer Park, TX
Dixie Chemical Co.
Dow Badische Co.
Dow Chemical USA
Harrison, NJ
Bayport, TX
Freeport, TX
Bay City, MI
2-Butanone
2-Chloro-1,3-butadi ene
l,4-Dichloro-2-butene
3,4-Dichloro-l-butene
2,5-Furandione
Chloromethane
Dichlqromethane
Trichloromethane
Nonylphenol, ethoxylated
Tallow acids, sodium salt
Nonylphenol, ethoxylated
1,2-Di chloroethane
Tetrachloroethane
Trichloroethene
Tallow acids, sodium salt
2,2'-[l,2-Ethanediylbis(oxy)]
bisethanol
2,2'-Oxybisethanol
Butanol
1-Butanol
Cyclohexanol
Cyclohexanone
2-Ethyl-l-hexanol
Hexahydro-2H-azepin-2-one
2-Methylpropanol
2-Methyl-1-propanol
2-Propenem'trile
2-Propenoic acid, butyl ester
2-Propenoic acid, ethyl ester
Benzene
l,l'-Biphenyl
1,3-Butadiene
Ethane
1-Propene
H-10
-------
Producer
Plant Location
Chemicals Produced
Freeport, TX
Magnolia, AR
Midland, MI
2-Aminoethanol
Benzene
l,l'-Biphenyl
1,3-Butadiene
Carbonic dichloride
Chloroethane
Chloroethene
Chloromethane
(Chloromethyl) oxirane
3-Chloro-l-propene
1,2-Oichloroethane
Dichloromethane
Dichloropropanol
l,3-Diisocyanato-2-(and 4-)
methyl benzene
2,2'-[l,2-Ethanediylbis(oxy)3
bisethanol
Ethene
Ethyl benzene
Ethyne
Hydrocyanic acid
2,2'-Iminobisethanol
2-Methyl-l,3-butadiene
4,4'-(l-Methylethylidene) bis-
phenol
Methyloxirane
2,2*,2"-Nitrilotrisethanol
Oxirane
2,2'-Oxybisethanol
1,2-Propanediol
1,2,3-Propanetri ol
1-Propene
Tetrachloroethene
Tetrachloromethane
1,1,1-Trichloroethane
Trichloroethene
Trichloromethane
1,2-Dibromoethane
2-Aminoethanol
2-Butoxyethanol
Chlorobenzene, mono-
Diethylbenzene
Ethenylbenzene
2-Ethoxyethanol
Ethyl benzene
Ethylmethyl benzene
H-ll
-------
Producer
Plant Location
Chemicals Produced
Oyster Creek, TX
Pittsburg, CA
Plaquemine, LA
Dow Corning Corp.
Carrol ton, KY
Midland, MI
E.I. OuPont de Nemours Antioch, CA
& Co.
Beaumont, TX
Belle, WV
2,2'-Imi nobi sethano1
2-Methoxyethanol
Methyl benzene
2,2',2"-Nitri1otrisethanol
1,2-Oi chloroethane
Phenol
2-Propanone
Tetrachloroethene
Tetrachloromethane
Chloroethene
Chloromethane
2-Chloro-1-propanol
1,2-Dichloroethane
Dichloromethane
2,2'-[l,2-Ethanediylbis(oxy)]
bisethano1
Ethene
Methyl oxirane
Oxi rane
2,2'-Oxybisethanol
1,2-Propanediol
1-Propene
Tetrachloroethene
Tetrachloromethane
TriChloromethane
Chloromethane
Chloromethane
Di chlorodi methyls i1ane
Oichlorodi f1uoromethane
Tetraethylplumbane
Tetramethylpiumbane
Trichlorofluoromethane
Benzenamine
Hydrocyanic acid
Methanol
Nitrobenzene
2-Propenenitrile
Formaldehyde
N-Methylmethanamine
Methyl amine
2-Methyl-2-propenoic acid, methyl
ester
H-12
-------
Producer
Plant Location
Chemicals Produced
Cape Fear, NC
Corpus Christi, TX
Deepwater Point,
NO
Gibbstown, NJ
Healing Springs,
NC
Laplace, LA
La Porte, TX
Linden, NJ
Louisville, KY
Memphis, TN
l,4^Benzenedicarboxylic acid/
1,4-Benzenedicarboxylic acid,
dimethyl ester
Tetrachloroethene
Tetrachloromethane
Carbonic dichloride
Chloroethane
Dichlorodif1uoromethane
Dichlorof1uoromethane
l,3-Diisocyanato-2-(and 4-)
methyl benzene
Linear alcohols, sulfated,
sodium salt, mixed
1-Methyl-2,4-dinitrobenzene
Tetraethylpiumbane
Tetramethylpiumbane
Tri chlorof1uoromethane
1,1,2-Trichloro-1,2,2-trlf1uoro-
ethane
Benzenamine
Nitrobenzene
Formaldehyde
2-Chloro-l,3-butadiene
3-Chloro-1-propene
Hexanedinitrile
2-Hexenedi ni tri1e
3-Hexenedinitrile
Hydrocyanic acid
Acetic acid, ethenyl ester
1,4-Butanediol
Formaldehyde
Methyl amine
Tetrahydrofuran
Formaldehyde
Dichlorof1uoromethane
Hydrocyanic acid
2-Hydroxy-2-methylpropanenitrile
2-Methyl-2-propenoic acid,
methyl ester
2-Propenenitrile
Sodium cyanide
H-13
-------
Producer
Plant Location
Chemicals Produced
Montage, MI
Old Hickory, TN
Orange, TX
Toledo, OH
Victoria, TX
Di chlorodi f1uoromethane
Tri chlorof1uoromethane
l,l,2-Trichlro-l,2,2-trifluoro-
ethane
1,4-Benzenedicarboxylic acid/
1,4-Benzenedicarboxylic acid,
dimethyl ester
Cyclohexanol
Cyclohexanone
Ethene
1,6-Hexanedi ami n$
Hexanedinitrile
Hexanedioic acid
Methanol
3-Pentenenitrile
1-Propene
Formaldehyde
3-Chloro-1-propene
Cyclohexane, oxidized
Cyclohexanol
Cyclohexanone
l,4-Dichloro-2-butene
1,6-Hexanediamine
Hexanedinitrile
Hexanedioic acid
Hydrocyanic acid
Eastman Kodak
Columbia, SC
Kingsport, TN
1,4-Benzenedicarboxylic acid/
1,4-Benzenedicarboxylic acid,
dimethyl ester
Acetic acid
Acetic acid, anhydride
Acetic acid, butyl ester
Acetic acid, ethyl ester
1,2-Benzenedicarboxylic acid,
bis (2-ethylhexyl) ester
1,4-Benzenedicarboxylic acid/
1,4-Benzenedicarboxylic acid,
dimethyl ester
Butanoic acid, anhydride
2-Butanol
2-Ethoxyethyl acetate
4-Methy1-2-pentanone
Propanoic acid
2-Propanone
H-14
-------
Producer
Plant Location
Chemicals Produced
Longview, TX
El Paso Natural Gas
Co.
Odessa, TX
Emery Industries, Inc. Maul din, SC
Santa Fe Springs,
CA
Emkay Chemical Co.
Energy Cooperative,
Inc.
Enserch Corp.
Esmark, Inc.
Elizabeth, NJ
Acetaldehyde
Acetic acid, ethyl ester
Butanol
1-Butanol
2-Butoxyethanol
2,2l~[l,2-Ethanediylbis(oxy)3
bisethanol
Ethanol
Ethene
2-Ethoxyethanol
2-Ethylhexanal
2-Ethyl-l-hexanol
2-Methoxyethanol
2-Methylpropanol
2-Methy1-1-propanol
Oxi rane
2,2'-Oxybi sethanol
Propanal
1-Propene
1,3-Butadiene
Ethyl benzene
Ethene
Ethenylbenzene
Hexanedi ni tri1e
1-Propene
Linear alcohols, ethoxylated,
mixed
Nonylphenol, ethoxylated
Linear alcohols, ethoxylated,
mixed
Nonylphenol, ethoxylated .
Dodecylbenzenesulfonic acid
Dodecylbenzenesulfdnic acid,
sodium salt
East Chicago, IN
Kerens, TX
Pryor, OK
1-Nonene
1-Propene
Urea
Urea
Beaumont, TX
Urea
H-15
-------
Producer
Plant Location
Chemicals Produced
Ethyl Corp.
Baton Rouge, LA
Magnolia, AR
Pasadena, IX
Exxon Corp.
Rochester, NY
Baton Rouge, LA
Baytown, TX
Bayway, NJ
Chloroethane
Chloroethene
Chloromethane
1,2-Dichloroethane
Tetrachloroethene
Tetraethylpiumbane
Tetramethylpiumbane
Trichloroethene
1,2-Di bromoethane
1-Butanol
Chloroethane
1,2-Dichloroethane
Octene
Tetraethylpiumbane
Tetramethylpiumbane
lodotnethane
Benzene
1,2-Benzenedicarboxylic acid,
diisodecyl ester
1,2-Benzenedicarboxylic acid,
diisononyl ester
1,3-Butadiene
1-Butene
Ethene
1,3-Isobenzofurandione
Isodecanol
2-Methyl-l,3-butadiene •
6-Methyl-heptanol
4-Methyl-3-pentene-2-one
2-Methy1-1-propene
1-Nonene
2-Propanol
1-Propene
Benzene
Cyclohexane
1,2-Dimethylbenzene
1,4-Dimethyl benzene
Ethene
Methyl benzene
2-Methyl-1-propene
1-Propene
2-Butanol
2-Butanone
1-Butene
4-Methy1-2-pentanone
H-16
-------
Producer
Plant Location
Chemicals Produced
4-Methyl-3-pentene-2-one
2-Methyl-1-propene
Nonylphenol
Oil-soluble petroleum sulfonate,
calcium salt
2-Propanone
1-Propene
FMC Corp.
Bayport, TX
South Charleston,
WV
Fairmount Chemicals Co. Newark, NJ
Farmland Industries,
Inc.
Ferro Corp.
Fike Chemicals, Inc.
Finetex, Inc.
Dodge City, KS
St. Joseph, MO
Santa Fe Springs,
CA
Nitro, WV
Elmwood Park, NJ
Firestone Tire & Orange, TX
Rubber Co.
v
First Mississippi Corp. Pascagoula, TX
Acetic acid
1,2,3-Propanetriol
Carbon disulfide
Tetrachloromethane
todomethane
Urea
6-Chl oro-N-ethyl -N' - (1-methy T-
ethyl)-l,3,5-triazine-2,4- ,
diamine
Nonylphenol
Phenol
1,2-Ethanediol
Dodecylbenzenesulfonic acid
Dodecylbenzenesulfonic acid,
sodium salt
Nonylphenol, ethoxylated
1,3-Butadiene
Benzenamine
Nitrobenzene
GAP Corp.
Calvert City, KY
1,4-Butanediol
2-Butyne-l,4-diol
Formaldehyde
Linear alcohols, ethoxylated,
mixed
Methyl amine
1-Methy1-2-pyrrolidinone
H-17
-------
Producer
Plant Location
Chemicals Produced
General Electric Co.
Georgia Pacific Corp.
Getty Oil Co.
Linden, NJ
Rensselaer, NY
Texas City, TX
Mount Vernon, IN
Selkirk, NY
Waterford, NY
Albany, OR
Bellingham, WA
Columbus, OH
Coos Bay, OR
Crosset, AR
Lufkin, TX
Plaquemine, LA
Russelville, SC
Taylorsville, MS
Vienna, GA
Clinton, IA
Delaware City, DE
El Dorado, KS
Nonylphenol
Nonylphenol, ethoxylated
Linear alcohols, ethoxylated,
mixed
Linear alcohols, ethoxylated and
sulfated, sodium salt, mixed
Nonylphenol
Tetrahydrofuran
Methyl benzene
1,4-Butanediol
2-Butyne-l,4-diol
1-Methyl-2-pyrrolidinone
Carbonic dichloride
4,4'-(l-Methylethylidene) bis-
phenol
2,6-Dimethylphenol
Chloromethane
Formaldehyde
Ethanol
Formaldehyde
Formaldehyde
Formaldehyde
Formaldehyde
Methanol
Phenol
2-Propanone
Formaldehyde
Formaldehyde
Formaldehyde
Urea
Heptenes (mixed)
Naphthalene
1-Nonene
Octene
1-Propene
Benzene
Heptane
H-18
-------
Producer
Plant Location
Chemicals Produced
Givaudan Corp.
Goodpasture, Inc.
B.F, Goodrich Co.
Goodyear Tire & Rubber
Co.
W.R. Grace & Co.
Grain Processing Corp.
*
Great Lakes Chemical
Corp.
Grestco Dyes & Chemi-
cals, Inc.
The Greyhound Corp.
Gulf Coast Olefins Co.
North Haven, CT
Springfield, OR
Winnfield, LA
Clifton, NJ
Dimmitt, TX
Avon Lake, OH
Calvert City, KY
Bayport, TX
Beaumont, TX
Fords, NJ
Memphis, TN
Nashau, NH
Muscatine, IA
El Dorado, AR
Long Island City,
NY
Montgomery, IL
Taft, LA
Hexane
Methyl benzene
(1-Methylethyl) benzene
Phenol
2-Propanone
1-Propene
Heptane
Formaldehyde
Formaldehyde
1-Nonanol
Urea
1,2-Benzenedi carboxy1i c aci d,
bis (2-ethylhexyl) ester
Chloroethane
1,2-Dichloroethane
Ethene
1-Propene
2-Propanone
2-Methy1-1,3-butadiene
1,2-Benzenedicarboxy1ic acid,
bis (2-ethylhexyl) ester
1,2-Benzenedicarboxylic acid,
diisodecyl ester
Urea
Sodium Cyanide
1,3,5,7-Tetraazatricyclo-
[3.3.1.r'/]decane
Ethanol
1,2-Dibromoethane
Tetrabromomethane
Dodecylbenzenesulfonic acid,
sodium salt
Tallow acids, sodium salt
Ethene
1-Propene
H-19
-------
Producer
Plant Location
Chemicals Produced
Gulf Oil
Alliance, LA
Belle Chase, LA
Blue Island, IL
Cedar Bayou, TX
Jersey City, NJ
Lyndhurst, NJ
Philadelphia, PA
Port Arthur, TX
St. James, LA
Vicksburg, MS
Benzene ;
Dimethyl benzenes, mixed
Methylbenzene
1,3-Dimethylbenzene
Dodecylbenzenesulfonic acid
Dodecylbenzenesulfonic acid,
sodium salt
Ethene
Octene
1-Propene
Nonylphenol, ethoxylated
Linear alcohols, ethoxylated,
mixed
Benzene
Methy!benzene
(1-Methylethyl) benzene
1-Propene
Benzene
Cyclohexane
Ethene
Methyl benzene
(1-Methylethyl) benzene
1-Propene
Ethylbenzene
Ethenylbenzene
Formaldehyde
Hart Products Corp.
Henkel, Inc.
Jersey City, NJ
Charlotte, NC
Hawthorne, CA
Hoboken, NJ
Dodecylbenzenesulfonic acid,
sodium salt
Linear alcohols, ethoxylated and
sulfated, sodium salt, mixed
Dodecylbenzenesulfonic acid
Dodecylbenzenesulfonic acid,
sodium salt
Linear alcohols, ethoxylated and
sulfated, sodium salt, mixed
Linear alcohols, sulfated, sodium
salt, mixed
Linear alcohols, ethoxylated and
sulfated, sodium salt, mixed
H-20
-------
Producer
Plant Location
Chemicals Produced
Hereofina
Hercor Chemical Corp.
Hercules, Inc.
Hoffmann-La Roche Inc.
The Humphrey Chemical
Co.
Big Spring, TX
Plaquemine, LA
Port Arthur, TX
Wilmington, NC
Penuelas, PR
Brunswick, GA
Gibbstown, NJ
Glen Falls, NY
Hattiesburg, MS
Louisiana, MO
Wilmington, NC
Belvidere, NJ
North Haven, CT
Phillips, TX
Dimethyl benzenes, mixed
Methanol
Dimethylbenzenes, mixed
1,4-Benzenedicarboxylic acid/
1,4-Benzenedicarboxylic acid,
dimethyl ester
1,4-Di methyl benzene
2,6,6-Trimethylbicyclo [ 3.1.1]-
hept-2-ene
Hydrocyanic acid
2,6,6-Trimethylbicyclo I 3.1.1]
hept-2-ene
2,2'-Bis (hydroxymethyl)-l,3-
propanediol
Formaldehyde
Urea
Formaldehyde
D-Glucitol
Hexane
Octene
Heptane
ICC Industries Inc.
ICI Americas, Inc.
Independent Refining
Corp.
Inland Chemical Corp.
International Minerals
& Chemicals
Niagara Falls, NY
New Castle, OE
Winnie, TX
Manati, PR
Serpal, PA
Chlorobenzene, mono-
D-Glucitol
Nonylphenol, ethoxylated
Benzene
Tetrachloromethane
2,2'-Bis (hydroxymethyl)-l,3-
propanediol
Formaldehyde
H-21
-------
Producer
Plant Location
Chemicals Produced
Sterlington, LA
Terre Haute, IN
Formaldehyde
Propanoic acid
Ethanol
Methyl amine
The Andrew Jergens Co.
Jetco Chemicals, Inc.
Jones & Laugh!in
Industries
Cincinnati, OH
Corsicana, TX
Aliquippa, PA
Tallow acids, sodium salt
(2-Ethylhexyl) amine
Benzene
Dimethyl benzenes, mixed
Methyl benzene
Kaiser Aluminum &
Chemical Corp.
Kalama Chemicals
Kerr-McGee Corp.
Savannah, GA
Kalama, WA
Urea
Benzoic acid, technical
Nonylphenol
Phenol
Corpus Christi, TX Benzene
Dimethyl benzenes, mixed
Methyl benzene
Koppers Co., Inc.
Bridgeville, PA
Cicero, IL
Follansbee, WV
Fontana
Woodward, AL
2,5-Furandione
1,3-Isobenzofurandione
2,5-Furandione
1,3-Isobenzofurandi one
Naphthalene
2,6-Dimethyl phenol
Naphthalene
Phenol
Naphthalene
Naphthalene
Lachat Chemicals, Inc.
Laurel Products Corp.
Mequon, WI l-Methyl-2-pyrrolidinone
Philadelphia, PA Tallow acids, sodium salt
H-22
-------
Producer
Plant Location
Chemicals Produced
Lever Brothers Co.
Lonza, Inc.
Baltimore, MD
Edgewater, NJ
Hammond, IN
Los Angeles, CA
St. Louis, MO
Mapleton, IL
Dodecylbenzenesulfonic acid
Dodecylbenzenesulfonic acid,
sodium salt
Tallow acids, sodium salt
Dodecylbenzenesulfonic acid
Dodecylbenzenesulfonic acid,
sodium salt
Tallow acids, sodium salt
Dodecylbenzenesulfonic acid
Dodecylbenzenesulfonic acid,
sodium salt
Tallow acids, sodium salt
Dodecylbenzenesulfonic acid
Dodecylbenzenesulfonic acid,
sodium salt
Tallow acids, sodium salt
Dodecylbenzenesulfonic acid
Dodecylbenzensulfonic acid,
sodium salt
Tallow acids, sodium salt
D-Glucitol
Hexadecyl chloride
Mallinckrodt, Inc.
Marathon Oil Co.
Marathon Manufacturing
Co.
Mel amine Chemicals,
Inc.
Merck & Co., Inc.
Merichem Co.
Lodi, NJ
Detroit, MI
Texas City, TX
Dickinson, TX
Dona!dsonvilie,
LA
Danville, PA
Houston, TX
Acetic acid, magnesium salt
l,2-(and 1,3-) Butanediql
2,2'-Oxybisethanol "",'
1-Propene
Benzene
Dimethyl benzenes, mixed
Methyl benzene
(1-Methylethyl) benzene
1-Propene
Oil-soluble petroleum sulfonate,
sodium salt
1,3,5-Triazine-2,4,6-triamine
D-Glucitol
Phenol
H-23
-------
Producer
Plant Location
Chemicals Produced
Midwest Solvents Co. ,
Inc.
Milbrew, Inc.
Miles Laboratories,
Inc.
Mi Hi ken & Co.
Mineral Research &
Development Corp.
Minerec Corp.
Mississippi Chemical
Corp.
Mobay Chemical Corp.
Mobil Oil Corp.
Atchison, KA
Juneau, WI
Dayton, OH
Elkhart, IN
Inman, SC
Concord, NC
Baltimore, MD
Yazoo City, MS
Cedar Bayou, TX
New Martinsville,
WV
Beaumont, TX
Monochem, Inc.
Geismar, LA
Ethanol
Ethanol
2-Hydroxy-l,2,3-propanetri carb-
oxylic acid
2-Hydroxy-l,2,3-propanetri carb-
oxylic acid
Nonylphenol, ethoxylated
Acetic acid, magnesium salt
Carbonic dichloride
Urea
Carbonic dichloride
l,3-Diisocyanato-2-(and 4-)
methylbenzene
4-Methyl-l,3-benzenediamine
1-Methy1-2,4-di ni trobenzene(and
2-Methyl-l,3-dinitrobenzene)
Benzenamine
Carbonic dichloride
l,3-Diisocyanato-2-(and 4-)
methyl benzene
4-Methyl-l,3-benzenediamine
1-Methy1-2,4-di ni trobenzene(and
2-Methyl-1,3-di ni trobenzene)
Nitrobenzene
Benzene
1,3-Butadiene
Ethene
Methyl benzene
2-Methylbutane
1-Propene
Chloroethene
Ethyne
H-24
-------
Producer
Plant Location
Chemicals Produced
Monsanto Co.
Addyston, OH
Alvin, TX
Anniston, AL
Bridgeport, NJ
Chocolate Bayou,
TX
Oecatur, AL
Eugene, OR
Greenwood, SC
Kearny, NJ
Pensacola, FL
Sauget, IL
Formaldehyde
1,3-Oimethyl benzene
l,l'-Biphenyl
1,2-Benzenedicarboxylic acid,
butyl, phenylmethyl ester
1,3-Isobenzofurandione
Benzene
1,3-Butadiene
1-Butene
1,2-Oimethylbenzene
Dodecy1benzene, 1i near
Ethene
Ethylbenzene
Formaldehyde
Hydrocyanic acid
Methylbenzene
2-Methy\-1,3-butadi ene
(1-Methylethyl) benzene
Naphthalene
Phenol
2-Propanone
1-Propene
2-Propenenitrile
1,6-Hexanedi ami ne
Hexanedinitrile
Formaldehyde
1,6-Hexanediamine adipate
Nonylphenol
Nonylphenol,
ethoxylated
Cyclohexanol
Cyclohexanone
1,6-Hexanediamine
1,6-Hexanediamine adipate
Hexanedinitrile
1,2-Benzendicarboxylic acid,
butyl, phenylmethyl ester
Chlorobenzene, mono-
Chloromethyl benzene
1-Chloro-4-nitrobenzene
Nitrobenzene
Springfield, MA
Acetic acid, ethyl
Formaldehyde
ester
H-25
-------
Producer
Plant Location
Chemicals Produced
St. Louis, MO
Texas City, TX
Montrose Chemical
Corp.
Morton-Norwich Pro-
ducts, Inc.
Murro Chemical Co.
Henderson, NV
Greensville, SC
Portsmith, VA
2,5-Furandione
Acetic acid
1,2-Benzenedicarboxylic acid,
bis (2-ethylhexyl) ester
1,2-Benzenedicarboxylic acid, di-
n-heptyl-n-nonyl-undecyl ester
Ethene
Ethenylbenzene
Ethylbenzene
4-Hydroxy-4-methy1-2-pentanone
2-Hydroxy-2-methylpropaneni tri1e
1,3-Isobenzofurandione
Methanol
2-Methy1-1-propene
2-Propenenitrile
Chlorobenzene, mono-
Dodecylbenzenesulfonic acid,
sodium salt
Linear alcohols, ethoxylated and
sulfated, sodium salt, mixed
Tallow acids, potassium salt
Tallow acids, sodium salt
N-Ren Corp.
Nalco Chemical Co.
National Biochemical
Co.
National Distillers &
Chemical Corp.
National Mining &
Chemical Co.
National Starch &
Chemical Corp.
East Dubuque, IA
Pryor, OK
Freeport, TX
Chicago, IL
Urea
Urea
Tetraethy1 piumbane
Tetramethylpiumbane
Bromoform
Ethanol
Ethene
Tuscola, IL
Philadelphia, PA Tallow acids, sodium salt
Long Mott, TX
Meredosia, IL
Acetic acid, ethenyl ester
Heptenes (mixed)
H-26
-------
Producer
Plant Location
Chemicals Produced
Nease Chemical Co.
Neches Butane Products
Nipro, Inc.
North America Philips
Corp.
Northern Nat. Gas Co.
Northwest Industries
Salisbury, NC
State College, PA
Port Neches, TX
Augusta, GA
Kansas City, KS
Morris, IL
Beaumont, TX
Chattanooga, TN
Lone Star, TX
Dodecylbenzenesulfonic acid,
sodium salt
Benzenesulfonic acid
1,3-Butadiene
2-Methyl-l,3-butadiene
Cyclohexanol
Cyclohexanone
Cyclohexanone, oxime
Hexahydro-2H-azepin-2-orie.
Linear alcohols, ethoxylated,
mixed
Nonylphenol, ethoxylated
Oil-soluble petroleum sulfonate,
calcium salt
Ethene
Oxirane
2,2'-Oxybisethanol
1-Propene
Benzoic acid, technical
Benzoic acid, technical
Benzene
Dimethyl benzenes, mixed
Methyl benzene
Occidental Petroleum
Corp.
01efi ns/Aromati c
01 in Corp.
Arecibo, PR
North Tonawanda,
NY
Taft, LA
Beaumont, TX
Ashtabula, OH
1,3-Isobenzofurandione
Formaldehyde
1,3,5,7-Tetraazatricyclo-
[3.3.1.1J'7]decane
1,1,2,2-Tetrachloroethane
Tetrachloroethene
Trichloroethene
1,3-Oimethylbenzene
l,3-Diisocyanato-2-(and 4-)
methyl benzene
H-27
-------
Producer
Plant Location
Chemicals Produced
Brandenburg, KY
Original Bradford Soap
Works, Inc.
Oxirane Corp.
Oxochem Enterprise
Lake Charles, LA
Rochester, NY
1-Aminoethanol
2-Chloro-1-propanol
2,2'-[l,2-Ethanediylbis(oxy)]
bisethanol
Ethene
2,2'-Iminobisethanol
4-Methy1-1,3-benzenediami ne
Methyloxirane
2,2',2"-Nitrilotrisethanol
Oxirane
2,2'-Oxybisethanol
1,2-Propanediol
Carbonic dichloride
l,3-Diisocyanato-2-(and 4-)
methy!benzene
Methyl benzene
Urea
4-Methyl-1,3-benzenedi ami ne
Tetrabromomethane
West Warwick, RI Tallow acids, sodium salt
Bayport, TX
Channel view, TX
Pasadena, TX
Penuelas, PR
Methy!oxirane
2-Methyl-2-propanol
2-Methyl-2-propenoic acid, methyl
ester
1,2-Propanediol
2-Propanone
Ethenylbenzene
Ethyl benzene
1-Phenylethyl hydroperoxide
Ethanol
Butanal
1-Butanol
2-Ethyl-l-hexanol
2-Methy1propanal
2-Methyl-l-propanol
PPG Industries, Inc.
Barberton, OH
Beaumont, TX
Carbonic dichloride
1,2-Dibromoethane
2,2'-[l,2-Ethanediylbis(oxy)]
bisethanol
H-28
-------
Producer
Plant Location
Chemicals Produced
Guayanilla, R
Lake Charles, LA
Natrium, WV
Ponce, PR
PVO International, Inc. Boonton, NJ
Pennwalt Corp. Calvert City, KS
Crosby, TX
Genesee, NY
Greens Bayou, TX
Thorofare, NJ
Pennzoil Corp.
Perstorp
Pester Refining Co,
Pfizer, Inc.
Shreveport, LA
Toledo, OH
El Dorado, KS
Brooklyn, NY
2-Methoxyethanol
Oxirane
2,2'-Oxybisethanol
Tetraethylpumbane
Tetramethylpumbane
1,2-Dichloroethane
2,2'-[l,2-Ethanediylbis(oxy)]
bisethanol
Ozirane
2,2'Oxybisethanol
Chloroethane
1,2,-DIchloroethane
Tetrachloroethene
1,1,1-Tri chloroethane
Trichloroethene
Carbon disulfide
Chlorobenzene, mono-
Chloroethene
Nonylphenol, ethoxylated
Di chlorodif1uoromethane
Trichlorof1uoromethane
Ethanol
1-Methyl-l-phenylethyl hydro-
peroxide
Carbonic disulfide
Di chlorodif1uoromethane
Trichlorof1uoromethane
Benzene
Dimethyl benzenes, mixed
Hexane
Pentane
2,2-Bis (hydroxymethyl)-l,3-
propanediol
1-Propene
2-Hydroxy-l,2,3-propanetricarb-
oxylic acid
H-29
-------
Producer
Plant Location
Chemi cals Produced
Phillips Pacific
Chemical Co.
Phillips Petroleum Co.
Pilot Chemicals
Greensboro, NC
Groton, CT
Southport, NC
Terre Haute, IN
Finley, WA
Beatrice, NB
Borger, TX
Guayama, PR
Phillips, TX
Sweeny, TX
Avenel, NJ
Houston, TX
1,2-Benzenedicarboxylic acid,
bis (2 ethylhexyl) ester
1,2-Benzenedicarboxylic acid,
diisodecyl ester
D-Glucitol
2-Hydroxy-1,2,3-propanetricarboxy-
lie acid
2-Hydroxy-l,2,3-propanetricarboxy
lie acid
Benzoic acid, technical
Urea
Urea
1-Butene
Cyclohexane
Benzene
Cyclohexane
Dimethyl benzenes, mixed
1,2-Dimethy!benzene
1,4-Dimethyl benzene
Methyl benzene
1,3-Butadiene
Ethyl benzene
Hexane
2-Methy1-2-butene
2-Methylpentane
Pentane
1,2,3,4-Tetrahydrobenzene
Benzene
Cyclohexane
Ethene
Methyl benzene
1-Propene
Dodecylbenzenesulfonic acid
Dodecylbenzenesulfonic acid,
sodium salt
Linear alcohols, ethoxylated and
sulfated, sodium salt, mixed
l.l'-Biphenyl
H-30
-------
Producer
Plant Location
Chemicals Produced
Plastics Engineering
Co.
PI ex Chemical Co.
J.L. Prescott Co.
Proctor & Gamble
Lock!and, OH
Santa Fe Springs,
CO
Sheboygan, WI
Union City, CA
Passaic, NJ
Alexandria, LA
Augusta, GA
Baltimore, MD
Cincinnati, OH
Dallas, TX
Iowa City, IA
Ivorydale, OH
Kansas City, KS
Long Beach, CA
Quincy, MA
Staten Island, NY
St. Louis, MO
Dodecylbenzenesulfonic acid
Dodecylbenzenesulfonic acid,
sodium salt
Dodecylbenzenesulfonic acid
Dodecylbenzenesulfonic acid,
sodium salt
Linear alcohols, ethoxylated and
sulfated, sodium salt, mixed
1,3,5,7-Tetraazatricyclo-
[3.3.1.r»7]decane
Dodecylbenzenesulfonic acid
Benzeriesulfonie aeid, mono-C..0_ ^
alkyl derivatives, sodium saltl
Mitf
Benzenesulfonic acid, mono-C
alkyl derivatives, sodium
Benzenesulfonic acid, mono-C.,
alkyl derivatives, sodium s
Benzenesulfonic acid, mono~C10' g-
alkyl derivatives, sodium salts
Benzenesulfonic acid, mono-C^Q_1_•
alkyl derivatives, sodium faTts
Benzenesulfonic acid, mono-C-.0-fi-
alkyl derivatives, sodium sai.ts
Dodecylbenzenesulfonic acid,
sodium salt
Dodecylbenzenesulfonic acid,
sodium salt
Benzenesulfonic acid, mono-C-.Q ,g-
alkyl derivatives, sodium salts
Benzenesulfonic acid, mono-Cin_1fi-
alkyl derivatives, sodium salts
Benzenesulfonic acid, mono-C-,0 ,fi*
alkyl derivatives, sodium salts
Benzenesulfonic acid, mono-C-.-_-_-
alkyl derivatives, sodium salts
Benzenesulfonic acid, mono-C,0 ,-•
alkyl derivatives, sodium saTts
-------
Producer
Plant Location
Chemicals Produced
Publicker Industries
Puerto Rico Olefins
Co.
Purtx Corp.
Gretna, LA
Philadelphia, PA
Penuelas, PR
Bristol, PA
Omaha, MB
St. Louis, MO
South Gate, CA
Ethanol
Acetaldehyde
Acetic acid
Acetic acid, butyl ester
Acetic acid, ethyl ester
Ethanol
1,3-Butadiene
Ethene
1-Propene
Dodecylbenzenesulfonic acid
Dodecylbenzenesulfonic acid,
sodium salt
Tallow acids, sodium salt
Tallow acids, sodium salt
Dodecylbenzenesulfonic acid
Dodecylbenzenesulfonic acid,
sodium salt
Dodecylbenzenesulfonic acid
Dodecylbenzenesulfonic acid,
sodium salt
Quaker Oats Co.
Quintana-Howel1
Memphis, TN
Tetrahydrofuran
Corpus Christi, TX Benzene
Dimethyl benzenes, mixed
Methyl benzene
R.S.A. Corp.
Reichhold Chemicals,
Inc.
Ardsley, NY
Austin, TX
Bay Minette, AL
Carteret, NJ
Cyclohexanone, oxime
1,6-Hexanediamine
lodomethane
1,1,2-Tri chloroethane
1-Methyl-l-phenylethyl hydro-
peroxide
2,6,6-Trimethylbicyclo [ 3.1.1]-
hept-2-ene
1,2-Benzenedicarboxylic acid,
bis (2-ethylhexyl) ester
1,2-Benzenedicarboxylic acid,
diisodecyl ester
H-32
-------
Producer
Plant Location
Chemicals Produced
The Richardson Co.
Charlotte, NC
Elizabeth, NJ
Hampton, SC
Houston, TX
Kansas City, KS
Malvern, AR
Moncure, NC
Morris, IL
Oakdale, LA
Pensacola, FL
St. Helens, OR
Tacoma, WA
Tuscaloosa, AL
White City, OR
Chicago, IL
Acetic acid, ethenyl ester
2,5-Furandione
Formaldehyde
Formaldehyde
Formaldehyde
Formaldehyde
Formaldehyde
2,5-Furandione
2,6,6-Trimethylbicyclo 13.1.1]-
hept-2-ene
2,6,6-Trimethylbicyclo [3.1.1]-
hept-2-ene
Urea
Formaldehyde
Benzenesulfonic acid
Formaldehyde
Phenol
Formaldehyde
Richardson-Merrell,
Inc.
Rohm & Haas Co.
Lemont, IL
Paterson, NJ
Phillipsburg, NJ
Deer Park, TX
Dodecylbenzenesulfonic acid,
sodium salt
Linear alcohols, ethoxylated and
sulfated, sodium salt, mixed
Dodecylbenzenesulfonic acid
Dodecylbenzenesulfonic acid,
sodium salt
Acetic acid, magnesium salt
Ethyne
Hydrocyanic acid
2-Hydroxy-2-methylpropanenitrile
Methanol
2-Methyl-2-propenoic acid, methyl
ester .
Nonylphenol
Nonylphenol, ethoxylated
. H-33
-------
Producer
Plant Location
Chemicals Produced
Philadelphia, PA
Rubicon Chemicals Inc. Geismar, LA
2-Propenoic acid, butyl ester
2-Propenoic acid, ethyl ester
Linear alcohols, ethoxylated,
mixed
Nonylphenol
Benzenamine
Carbonic dichloride
4-Methy1-1,3-benzenediamine
1-Methy1-2,4-di ni trobenzene
Nitrobenzene
SCM Corp.
SPPC
Schenectady Chemicals,
Inc.
Shell Chemical Co.
Jacksonville, FL
2,6,6-Trimethylbicyclo [3.1.1]
hept-2-ene
Corpus Christi, TX Ethylmethyl benzene
Oyster Creek, TX Nonylphenol
Rotterdam Junc-
tion, NY
Deer Park, TX
Nonylphenol
Benzene
1,3-Butadiene
1-Butanol
2-Butanol
2-Butanone
1-Butene
Chloroethane
Chloroethene
Chioromethy1oxi rane
3-Chloro-l-propene
1,2-DiChloroethane
Dimethyl benzenes, mixed
1,2-Dimethy1 benzene
1,3-Dimethyl benzene
1,4-Dimethyl benzene
Ethanol
Ethene
2-Ethyl-l-hexanol
4-Hydroxy-4-methy1-2-pentanone
Methyl benzene
2-Methyl-l,3-butadiene
(1-Methylethyl) benzene
4,4'-(l-Methylethylidene) bis-
phenol
H-34
-------
Producer
Plant Location
Chemicals Produced
Dominiguez, CA
Geismar, LA
Martinez, CA
Norco, LA
Odessa, TX
Wilmington, CA
4-Methyl-2-pentanone ^
4-Methyl-3-penten-2-one
2-Methyl-1-propanol
2-Methyl~l-propene
Phenol
1,2,3-Propanetriol
2-Propanol
2-Propanone
1-Propene
4-Hydroxy-4-methyl-2-pentanone
4-Methy1-2-pentanone
4-Methyl-3-penten-2-one
2-Propanol
2-Propanone
2-Butoxyethanol
2,2'-[l,2-Ethanediylbis(oxy)]
bisethanol
2-Ethoxyethanol
Isodecanol
2-Methoxyethanol
Oxirane
2,2'-Oxybi sethanol
2-Methyl-2-propanol
2-Methyl-l-propene
Oil-soluble petroleum sulfonate,
calcium salt
Oil-soluble petroleum sulfonate,
sodium salt
Acetaldehyde
1,3-Butadiene
2-Butanol ''
2-Butanone
1-Butene
Chloroethene
(Chloromethyl) oxirane
3-Chloro-l-propene
1,2-Dichloroethane
Ethene
2-Methyl-1,3-butadiene
1,2,3-Propanetriol
2-Propanone
1-Propene
Benzene
Methyl benzene
1-Propene
H-35
-------
Producer
Plant Location
Chemicals Produced
The Shepherd Chemical
Co.
Simplot Co.
South Hampton Co.
Standard Chlorine
Chemical Co.
Standard Oil of
California
Standard Oil Co.
(Indiana)
Wood River, IL
Cincinnati, OH
Pocatello, ID
Silsbee, TX
Delaware City, DE
El Segundo, CA
Los Angeles, CA
Pascagoula, MS
Richmond, CA
Chocolate Bayou,
TX
Decatur, AL
Joliet, IL
Sugar Creek, MO
Benzene
Acetic acid, magnesium salt
Urea
Dimethyl benzenes, mixed
2-Methylbutane
Pentane
Chlorobenzene, mono-
Benzene
(1-Methy1 ethyl) benzene
1-Propene
Oil-soluble petroleum sulfonate,
calcium salt
1,4-Dimethylbenzene
1,2-Dimethylbenzene
1,4-Dimethylbenzene
Dodecylbenzene, non-linear
1,3-Isobenzofurandi one
2-Methyl-1-propene
Phenol
2-Propanone
1-Propene
Ethene
1-Propene
1,4-Benzenedicarboxylic acid/
1,4-Benzenedicarboxylic acid,
dimethyl ester
1,4-Dimethylbenzene
1,3-Benzenedicarboxylic acid
1,4-Benzenedicarboxylic acid/
1,4-Benzenedicarboxylic acid,
dimethyl ester
1,3-Butadiene
2,5-Furandione
2-Methyl-1-propene
1-Propene
H-36
-------
Producer
Plant Location
Chemicals Produced
Texas City, TX
Wood River, IL
Yorktown, VA
Standard Oil Co. (Ohio) Lima, OH
Stauffer Chemical Co. Carson, CA
St. Croix Petrochemi-
cal Corp.
The Stepan Chemical
Co.
Cold Creek, AL
Delaware City, OE
Edison, NJ
Henderson, NV
Le Moyne* AL
Louisville, KY
St. Gabriel, LA
St. Croix, VI
Anaheim, CA
Benzene
Dimethylbenzenes, mixed
1,4-Dimethylbenzene
Ethenylbenzene
Ethylbenzene
Methyl benzene
(1-Methylethyl) benzene
1-Propene
(1-Methylethyl) benzene
Heptenes (mixed)
(1-Methylethyl) benzene
1-Propene
Hydrocyanic acid
1-Propene
2-Propenenitrile
Urea
Chloroethane
Chloroethene
1,2-Dichloroethane
Carbonic dichloride
Carbon disulfide
(Chloromethyl) benzene
Benzenesulfonic acid
Tetrachloromethane
Chloromethane
Dichloromethane
Tetrachloroethene
Tetrachloromethane
TriChloromethane
Carbonic dichloride
1,4-Dimethylbenzene
Dodecylbenzenesulfonic acid
Dodecylbenzenesulfonic acid,
sodium salt
Linear alcohols, ethoxylated,
mixed
Nonylphenol, ethoxylated
H-37
-------
Producer
Plant Location
Chemicals Produced
Sterling Drug, Inc.
Stirason Lumber Co.
Sun Co., Inc.
Bordontown, NJ
Elwood, IL
Fieldsboro, NJ
Cincinnati, OH
Memphis, TN
Anacortes, WA
Corpus Christi, TX
Duncan, OK
Marcus Hook, PA
Toledo, OH
Benzenesulfonic acid, mono-C,« ,g-
alkyl derivatives, sodium salts
Dodecylbenzenesulfonic acid
Dodecylbenzenesulfonic acid,
sodium salt
1,3-Isobenzofurandiorie
Linear alcohols, ethoxylated,
mixed
Nonylphenol, ethoxylated
Oil-soluble petroleum sulfonate,
sodium salt
Dodecylbenzenesulfonic acid
Dodecylbenzenesulfonic acid,
sodium salt
Linear alcohols, ethoxylated,
mixed
Nonylphenol, ethoxylated
2,4,6-Trichloro-l,3,5-triazine
2,4,6-Tri chloro-1,3,5-tri azi ne
Phenol
2,6,6-Trimethylbicyclo[ 3.1.13-
hept-2-ene
Benzene
Dimethyl benzenes, mixed
1,2-Dimethylbenzene
Ethene
Ethenylbenzene
Ethyl benzene
Methyl benzene
(1-Methylethyl) benzene
1-Propene
1-Dodecene
1-Propene
Benzene
1-Dodecene
Methyl benzene
1-Propene
Benzene
1-Dodecene
Methyl benzene
1-Propene
H-3S
-------
Producer
Plant Location
Chemicals Producer
SunOlin Chemical Co.
Sybron Corp.
Tulsa, OK
Claymont, DE
Lyndhurst, NJ
Benzene
Cyclohexane
Methylbenzene
Ethene
Oxirane
l.l'-Biphenyl
Teknor Apex Co.
Tenneco, Inc.
Hebronville, MA
Tennessee Valley
Authority
Terra Chemicals
Internatonal, Inc.
Texaco
Chalmetta, LA
Elizabeth, NJ
Fords, NJ
Garfield, NJ
Houston, TX
Pasadena, TX
Muscle Shoals,
AL
Port Neal, IA
Austin, TX
1,2-Benzenedicarboxylic acid,
bis (2-ethylhexyl) ester
1,2-Benzenedicarboxylic acid,
diisodecyl ester
Benzene
Dimethyl benzenes, mixed
1,2-Dimethylbenzene
1,3-Oi methyl benzene
1,4-Dimethylbenzene
Ethylbenzene
Methyl benzene
Cyclohexanone, oxime
Chloromethyl benzene
Formaldehyde
2,5-Furandione
1,3,5,7-tetraazatricyclo-
.[3;3.1.13'7]decane
Benzoic acid, technical
Formaldehyde
1,3-Butadiene
1-Butene
2-Methy1-1-propene
Ethyne
Methanol
Urea
Urea
Linear alcohols, ethoxylated,
mixed
H-39
-------
Producer
Plant Location
Chemicals Produced
Port Arthur, TX
Texas City Refining
Tosco Corp.
Triad Chemicals
Tyler Corp.
Port Neches, TX
Westville, NJ
Texas City, TX
El Dorado, AR
Martinez, CA
Donaldsonville,
FL
Joplin, MO
Benzene
Cyclohexane
1-Dodecene
Methyl benzene
1-Propene
2-Aminoethanol
2-Butoxyethanol
2,2'- l,2-£thanediylbis(oxy)
bisetnanol
Ethene
2-Ethoxyethanol
2,2'-Imi nobi sethano1
Linear alcohols, ethoxylated,
mixed
2-Methoxyethanol
Methyloxirane
2,2',2"-Nitrilotrisethanol
Nonylphenol
Nonylphenol, ethoxylated
Oxi rane
2,2'-Oxybisethanol
1,2-Propanediol
1-Propene
Benzene
Methyl benzene
(1-Methylethyl) benzene
1-Propene
1-Propene
1-Propene
1-Propene
Urea
Urea
U.O.P., Inc.
Union Camp Corp.
East Rutherford,
NJ
Jacksonville, FL
(Chloromethyl) benzene
2,6,6-Trimethylbicyclo [3,1.1]
hept-2-ene
H-40
-------
Producer
Plant Location
Chemicals Produced
Union Carbide Co.
Ashtabula, OH
Bound Brook, NO
Brownsville, TX
Institute & South
Charleston, WV
Penuelas, PR
H-4'l
Ethyne
Phenol
2-Propanone
Acetic acid
Acetic acid, anhydride
Acetic acid, ethyl ester
2-Butanone
Ethanol
Acetaldol
Acetic acid, butyl ester
Acetic acid, ethyl ester
2-Butanol
Carbonic dichloride
Chloromethane
Di chlorodi f1uoromethane
l,3-Diisocyanato-2-(and 4-)
methyl benzene
Dodecylbenzene, linear
2-Ethoxyethanol
(2-Ethylhexyl) amine
4-Hydroxy-4-methyl-2-pentanone
Linear alcohols, ethoxylated and
sulfated, sodium salt, mixed
4-Methyl-1,3-benzenedi amine
l-Methyl-2,4-dinitrobenzene (and
2-Methyl-l,3-dinitrobenzene)
1-Methyl-2,4-dinitrobenzene
4-Methyl-2-pentanone
4-Methyl-3-penten-2-one
Nonylphenol, ethoxylated
1,2-Propanediol
1-Propanol
2-Propanone
1,3-Butadiene
Butanal
1-Butanol
Dimethyl benzenes, mixed
2,2'-[l,2-Ethanediylbis(oxy)]
bisethanol
Ethene
Ethyne
(1-Methylethyl) benzene
4,4'-(1-Methylethylidene) bis-
phenol
2-Methylpropanal
2-Methyl-1-propanol
-------
Producer
Plant Location
Chemicals Produced
Seadrift, TX
Sistersville, WV
Taft, LA
Texas City, TX
Oxi rane
2,2'-Oxybi sethanol
Phenol
2-Propanone
1-Propene
1-Aminoethanol
1,3-Butadiene
Butanal
2,2'-[l,2-Ethanediylbis(oxy)]
bisethanol
Ethene
Ethenylbenzene
Ethylbenzene
2-Ethyl-l-hexanol
Ethyne
2,2'-Iminobisethanol
2-Methylpropanal
2-Methyl-1-propanol
2,2',2"-Nitrilotrisethanol
Oxirane
2,2'-Oxybisethanol
Propanal
1-Propene
Dichlorodimethylsi lane
Acetic acid
Benzene
1,3-Butadiene
Cyclohexanol
Cyclohexanone
1,2-Dichloroethane
2,2'-[l,2-Ethanediylbis(oxy)]
bisethanol
Ethyne
Methanol
Methyl benzene
Oxirane •
2,2'-Oxybisethanol
2-Propenoic acid
2-Propenoic acid, butyl ester
2-Propenoic acid, ethyl ester
Acetic acid, butyl
Acetic acid, ethyl
1,3-Butadiene
1,2-Dichloroethane
Ethanol
Ethene
ester
ester
H-42
-------
Producer
Plant Location
Chemicals Produced
Union Oil Co. of
California
Union Pacific Corp.
Uniroyal, Inc.
Torrance, CA
Beaumont, TX
Brea, CA
Kenai, AK
Lemont, IL
Corpus Christi,
TX
Naugatuck, CT
U.S. Industrial Chemi- Deer Park, TX
cals Co.
U.S. Steel Corp.
Cherokee, AL
Ethyne
Linear alcohols, ethoxylated,
mixed
2-Methylpropanal
2-Methy1-1-propanol
2,2'-Oxybisethanol
Propanal
Propaneic acid
1-Propane1
2-Propanol
2-Propanone
1-Propene
1,1,2-Trichloroethane
Ethene
1-Propene
Benzene
Cyelohexane
Dimethylbenzenes, mixed
1-Dodecene
Heptane
Hexane
Methyl benzene
1-Nonene
1-Propene
Urea
Urea
Benzene
Dimethyl benzenes, mixed
Heptane
Hexane
Methyl benzene
Benzene
Cyclohexane
Dimethyl benzenes, mixed
Methyl benzene
Nonylphenol
1,2,3,4-Tetrahydrobenzene
Acetic acid, ethenyl ester
Urea
H-43
-------
Producer
Plant Location
Chemicals Produced
Clairton, PA
Univar Corp.
Upjohn Co.
Fairfield, AL
Gary, IN
Geneva, UT
Haverhill, OH
Ironton, OH
Neville Island,
PA
Eugene, OR
La Porte, TX
Benzene
Dimethyl benzenes, mixed
Methylbenzene
Naphtha!ene
Phenol
Naphthalene
Naphthalene
Benzene
Dimethyl benzenes, mixed
Methyl benzene
Isodecanol
6-Methyl-heptane!
1-Methyl-l-phenylethyl hydro-
peroxide
Phenol
2-Propanone
l,l,l-Tribromo-2-methyl-2-pro-
panol
1,2-Benzenedicarboxylic acid,
bis (2-ethylhexyl) ester
1,2-Benzenedicarboxylic acid,
diisodecyl ester
2,5-Furandione
1,3-Isobenzofurandione
Formaldehyde
Carbonic dichloride
Valley Nitrogen Pro-
ducers, Inc.
Vertac, Inc.
Virginia Chemicals,
Inc.
El Centre, CA
Helm, CA
Hercules, CA
Van De Mark Chemical Lockport, NY
Co.
Vicksburg, MS
Portsmouth, VA
Urea
Urea
Methanol
Urea
Carbonic dichloride
6-Chloro-N-ethy1-N'-(l-methyV
ethy1)-l,3,5-triazine-2,4-
diamine
(2-Ethylhexyl) amine
H-44
-------
Producer
Plant Location
Chemicals Produced
Vulcan Materials Co.
Geismar, LA
Wichita, KS
1,2-Dichloroethane
Dichloromethane
Tetrachloroethene
Tetrachloromethane
1,1,1-Tri chloroethane
Trichloromethane
Dichloromethane
Tetrachloroethene
Tetrachloromethane
Trichloromethane
Jim Walter Corp.
The Williams Companies
Witco Chemical Corp.
Birmingham, AL
Blytheville, AR Urea
Donaldsonville, LA Urea
Verdigris, OK Urea
Benzenesulfonic acid
Carson, CA
Clearing, IL
Gretna, LA
Houston, TX
Paterson, NJ
Petrolia, PA
Trainer, PA
Dodecylbenzene, linear
Dodecylbenzene, non-linear
Dodecylbenzenesulfonic acid
Dodecylbenzenesulfom'c acid,
sodium salt
Oil-soluble petroleum sulfonate,
calcium salt
Oil-soluble petroleum sulfonate,
sodium salt
Dodecylbenzenesulfonic acid
Dodecylbenzenesulfonic acid,
sodium salt
Linear alcohols, ethoxylated,
mixed
Nonylphenol, ethoxylated
Dodecylbenzenesulfonic acid
Dodecylbenzenesulfonic acid,
sodium salt
Oil-soluble petroleum sulfonate,
calcium salt
Oil-soluble petroleum sulfonate,
sodium salt
Oil-soluble petroleum sulfonate,
calcium salt
H-45
-------
Producer
Plant Location
Woonsocket Color & Woonsocket, RI
Chemicals
Wright Chemical Corp. Acme, NY
Chemicals Produced
Oil-soluble petroleum sulfonate,
sodium salt
l,l'-Biphenyl
Dodecylbenzenesulfonic acid
Formaldehyde
1,3,5,7-Tetraazatricyclo-
[3.3.1.1'3'']decane
H-46
-------
REFERENCES, APPENDIX H
1, SRI International. 1978 Directory of Chemical Producers, United
States of America. Menlo Park, California.,1979.
H-47
-------
-------
APPENDIX I
SCREENING DATA AND RESULTS
-------
-------
APPENDIX I
SCREENING DATA AND RESULTS
This appendix shows the plant, cost, and price data used for each of
the 219 chemicals analyzed in the screening. The appendix consists of
three elements: an index of the chemicals affected (Table 1-1); data and
assumptions used in the screening (Section I.I, including Table 1-2); and
the results of the screening (Section 1.2, including Table 1-3).
This appendix should be read in conjunction with Section 9.2 of the
BID. Section 9.2 provides a more in-depth discussion of the approach and
basis for assumptions used in the screening. This appendix, in contrast,
is intended to provide a record of the specific data used for each chemi-
cal , although some discussion is included for guidance.
The chemicals that will be directly affected by NSPS for distillation
are listed in Table 1-1. This list is the same as the list in Appendix E,
except that it: also contains chemical numbers assigned to each chemical
for purposes of the computer screening; includes 10 chemicals not regulated
by NSPS for distillation but which are factors in the' rolled-through cost
methodology; and lists chemicals in a slightly different order than that
used in Appendix E. Chemicals have been listed and numbered according to
their alphabetical order with respect to Chemical Abstracts Service names,
except that several chemicals are listed after urea ammonium nitrate (212)
even though alphabetically they precede this position.
Several other characteristics of the list warrant mention. First, no
chemicals are designated for numbers 47, 59, 100, 218, 219, 229, 231, and
233. Second, one chemical is given a number in Appendix I in relation to
its common name; this is cyclohexene, or 1,2,3,4-tetrahydrobenzene (197).
Third, as mentioned earlier, Appendix I lists 10 chemicals not regulated by
1-1
-------
TABLE I.I. ORGANIC CHEMICAL INDUSTRY
LIST OF CHEMICAL PRODUCTS INCLUDED IN COMPUTER SCREENING
Chemical
number
Chemical name
Common name
I Acetaldehyde
2 Acetic acid
3 Acetic acid, anhydride
4 Acetic acid, butyl ester
5 Acetic acid, ethenyl ester
6 Acetic acid, ethyl ester
7 Acetic acid, magnesium salt
8 Alcohols, C-ll or lower, mixtures
9 Alcohols, C-12 or higher, mixtures
10 2-Aminoethanol
11 Benzenamine
12 Benzene
13 1,3-Benzenedicarboxylic acid
14 1,4-Benzenedicarboxylic acid
15 1,2-Benzenedicarboxylic acid,
bis (2-ethylhexyl) ester
16 1,2-Benzenedicarboxylic acid,
butyl, phenylmethyl ester
17 1,2-Benzenedicarboxylic acid,
di-n-heptyl-n-nonyl undecyl ester
18 1,2-Benzenedicarboxylic acid,
diisodecyl ester
19 1,2-Benzenedicarboxylic acid,
diisononyl ester
(1) Acetic anhydride
(2) Acetic oxide
n-Butyl acetate
Vinyl acetate
Ethyl acetate
Magnesium acetate
Ethanolamine
(1) Aniline
(2) Phenylamine
Benzol
Isophthalic acid
Terephthalic acid
(1) Bis (2-ethylhexyl) phthalate
(2) Dioctyl phthalate
(3) Di (2-ethylhexyl) phthalate
Butyl benzyl phthalate
Di-n-heptyl-n-nonyl undecyl
phthalate
Diisodecyl phthalate
Diisononyl phthalate
1-2
-------
TABLE I.I (Continued). ORGANIC CHEMICAL INDUSTRY
LIST OF CHEMICAL PRODUCTS INCLUDED IN COMPUTER SCREENING
Chemical
number
Chemical name
Common name
20 1,4-Benzenedicarboxylic acid
dimethyl ester
21 Benzenesulfonic acid
22 Benzenesulfonic acid, mono-
C-JQ ig-alkyl derivatives,
soaTum salts
23 Benzoic acid, technical
24 l,T-Biphenyl
25 2,2-Bis(hydroxymethyl)-
1,3-propanediol
26 1,3-Butadiene
27 Butadiene and butene fractions
28 Butanal
29 Butane
30 Butanes, mixed
31 l,2-(and 1,3-) Butanediol
32 1,4-Butanediol
33 Butanoic acid, anhydride
34 1-Butanol
35 2-Butanol
36 2-Butanone
37 1-Butene
38 ' 2-Butene
(1) Terephthalic acid, dimethyl ester
(2) Dimethylterephthalate
(3) DMT
Diphenyl
Pentaerythritol
(1) Bivinyl
(2) Divinyl
Butyraldehyde
n-Butane
Butylene glycol
Butyric anhydride
n-Butyl alcohol
sec-Butyl alcohol
Methyl ethyl ketone
ct-Butylene
(1) 8-Butylene
(2) pseudo-Butylene.
1-3
-------
TABLE I.I (Continued). ORGANIC CHEMICAL INDUSTRY
LIST OF CHEMICAL PRODUCTS INCLUDED IN COMPUTER SCREENING
Chemical
number
39
40
41
42
43
44
45
46
48
49
50
Chemical name
Butenes, mixed
2-Butoxyethanol
2-Butyne-l,4-diol
Carbamic acid, monoammonium salt
Carbon disulfide
Carbonic di chloride
Chlorobenzene, mono-
2-Chl oro-1 ,3-butadiene
Chloroethane
Chloroethene
6-Chloro-N-ethyl -N ' - ( 1-methyl ethy
Common name
Butyl enes (mixed)
Butyl Cellosolve®
-
-
-
Phosgene
-
Chloroprene
Ethyl chloride
Vinyl chloride
1)- (1) 2-Chloro-4-(ethylamino)-6-
I,3s5-triazine-2s4-diamine
51 Chloromethane
52 (Chloromethyl) benzene
53 (Chloromethyl) oxirane
54 l-Chloro-4-nitrobenzene
55 2-Chloro-l-propanol
56 3-Chloro-l-propene
57 Coconut oil acids, sodium salt
58 Cyclohexane
60 Cyclohexane, oxidized
(isopropylamino)-s~triazine
(2) Atrazine®
Methyl chloride
(1) Benzyl chloride
(2) a-Chlorotoluene
Epichlorohydrin
(1) p-Chloronitrobenzene
(2) p-Nitrochlorobenzene
(1) 2-Chloroprppyl alcohol
(2) Propylene chlorohydrin
(1) 3-Chloropropene
(2) Ally! chloride
Hexahydrobenzene
1-4
-------
TABLE I.I (Continued). ORGANIC CHEMICAL INDUSTRY
LIST OF CHEMICAL PRODUCTS INCLUDED IN COMPUTER SCREENING
Chemical
number
Chemical name
Common name
61 Cyclohexanol
62 Cyclohexanone
63 Cyclohexanone oxime
64 1,3-Cyclopentadiene
65 Cyclopropane
66 1,2-Dibromoethane
67 Dibutanized aromatic concentrate
68 l,4-Dichloro-2-butene
69 3,4-Dichloro-l-butene
70 Dichlorodifluoromethane
71 Dichlorodimethylsilane
72 1,2-Dichloroethane
73 1,1-Dichloroethene
74 Dichlorofluoromethane
75 Dichloromethane
76 l,3-Dichloro-2-propanol
77 Diethyl benzene
78 l,3-Diisocyanato-2-(and 4-)
methyl benzene (80/20 mixture)
79 Dimethyl benzenes (mixed)
80 1,2-Dimethylbenzene
81 1,3-Dimethylbenzene
(1) Hexalin
(2) Hexahydrophenol
Pimelic ketone
Trimethylene
(1) Ethylene dibromide
(2) Ethylene bromide
1,4-Dichlorobutene
Freon 12
Dimethyldichlorosilane
(1) Ethylene chloride
(2) Ethylene dichlor'ide
Vinylidene chloride
Freon 21
Methylene chloride
Dichlorohydrin
Toluene-2,4-(and 2,6-)
diisocyanate (80/20 mixture)
Xylenes (mixed)
o-Xylene
m-Xylene
1-5
-------
TABLE I.I (Continued). ORGANIC CHEMICAL INDUSTRY
LIST OF CHEMICAL PRODUCTS INCLUDED IN COMPUTER SCREENING
Chemical
number
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
Chemical name
1 ,4-Dimethyl benzene
1 , 1-Dimethyl ethyl hydroperoxi de
2, 6-Dimethyl phenol
1-Dodecene
Dodecyl benzene, linear
Dodecyl benzene, nonlinear
Dodecyl benzenesulfonic acid
Dodecyl benzenesulfonic acid,
sodium salt
Ethane3
1,2-Ethanediol
2,2'-(ls2-Ethanediylbis (oxy))
bisethanol
Ethanol
Ethene
Ethenone
Ethenyl benzene
2-Ethoxyethanol
Common name
p-Xylene
-
(1) m-Xylenol
(2) 2,6-Xylenol
(1) Dodecene
(2) Tetrapropylene
Alkyl benzene
-
-
_
(1) Bimethyl
(2) Dimethyl
Ethylene glycol
Triethylene glycol
Ethyl alcohol
(1) Ethylene
(2) Elayl
(3) defiant gas
Ketene
Styrene
(1) Ethylene glycol monoethyl ether
98 2-Ethoxyethyl acetate
99 Ethyl benzene
(2) Cellosolve
(1) Ethylene glycol monoethyl ether
acetate
(2) Cellosolve acetate®
1-6
-------
TABLE I.I (Continued). ORGANIC CHEMICAL INDUSTRY
LIST OF CHEMICAL PRODUCTS INCLUDED IN COMPUTER SCREENING
Chemical
number
Chemical name
Common name
101 2-Ethylhexanal
102 2-Ethyl-l-hexanol
103 (2-Ethylhexyl) amine
104 Ethyl methyl benzene
105 6-Ethyl-1,2,3,4-tetrahydro-9,10-
anthracenedione
106 Ethyne
107 Fatty acids, tall oil, sodium salt
108 Formaldehyde
109 2,5-Furandione
110 D-Glucitol
111 Heptane
112 Heptenes (mixed)
113 Hexadecyl chloride
114 Hexahydro-2H-azepin-2-one
115 Hexane
11.6 1,6-Hexanedi amine
117 1,6-Hexanediamine adipate
118 1,6-Hexanedinitrile
119 Hexanedioic acid
120 2-Hexenedinitrile
2-Ethylhexyl alcohol
(1) Acetylene
(2) Ethine
(1) Formalin (solution)
(2) Methanal (gas)
Maleic anhydride
Sorbitol
n-Heptane
Caprolactam
Hexamethylene diamine
(1) Hexamethylene diamine adipate
(2) Nylon salt
(1) Adiponitrile
(2) 1,4-Dicyanobutane
Adipic acid
1,4-Dicyano-l-butene
1-7
-------
TABLE I.I (Continued). ORGANIC CHEMICAL INDUSTRY
LIST OF CHEMICAL PRODUCTS INCLUDED IN COMPUTER SCREENING
Chemical
number
Chemical name
Common name
121 3-Hexenedinitrile
122 Hydrocyanic acid
123 4-hydroxy-4-methyl-2-pentanone
124 2-Hydroxy-2-methylpropanenitrile
125 2-Hydroxy-l,2,3-
propanetricarboxylic acid
126 2,2'-Iminobisethanol
127 1,3-Isobenzofurandione
128 Isodecanol .
129 Linear alcohols, ethoxylated, mixed
130 Linear alcohols, ethoxylated and
sulfated, sodium salt, mixed
131 Linear alcohols, sulfated, sodium
salt, mixed
132 Methane9
133 Methanol
134 2-Methoxyethanol
135 Methyl benzene
136 4-Methyl-l,3-benzenediamine
137 ar-Methylbenzenediamine
138 2-Methyl-l,3-butadiene
(1) 1,4-Dicyanobutene
(2) Dihydromucononitrile
(3)'l,4-Dicyano-2-butene
Hydrogen cyanide
Diacetone alcohol
(1) Acetone cyanohydrin
(2) 2-Methyllactonitrile
Citric acid
(1) Diethanolamine
(2) 2,2'-Aminodiethanol
Phthalic anydride
Isodecyl alcohol
(1) Methyl alcohol
(2) Wood alcohol
(1) Ethylene glycol monomethyl ether
(2) Methyl Cellosolve®
Toluene
(1) Toluene-2,4-diamine
(2) 2,4-Diaminotoluene
(3) 2,4-Tolylenediamine
Isoprene
1-8
-------
TABLE I.I (Continued). ORGANIC CHEMICAL INDUSTRY
LIST OF CHEMICAL PRODUCTS INCLUDED IN COMPUTER SCREENING
Chemical
number
Chemical name
Common name
139 2-Methyl butane
140 2-Methyl-2-butene
141 2-Methylbutenes, mixed
142 1-Methyl-2,4-dinitrobenzene
(and 2-Methyl-l,3-dinitrobenzene)
143 1-Methyl-2,4-dinitrobenzene
144 (1-Methylethyl) benzene
145 4,4'-(1-Methylethylidene)
bisphenol
146 Methyloxirane
147 2-Methylpentane
148 4-Methyl-2-pentanone
149 1-Methyl-1-phenylethyl
hydroperoxide
150 2-Methylpropanal
151 2-Methylpropane
152 2-Methyl-1-propanol
153 2-Methyl-2-propanol
154 2-Methyl-1-propene
155 2-Methyl-2-propenenitrile
156 2-Methyl-2-propenoic acid,
methyl ester
157 1-Methyl-2-pyrrolidinone
Isopentane
Amy!ene
Amylenes, mixed
2,4- (and 2,6-) Dinitrotoluene
2,4-Dinitrotoluene
Cumene
(1) 4,4'-Isopropylidenejdiphenol
(2) Bisphenol A
Propylene oxide
(1) Isopropyl acetone
(2) Methyl Isobutyl ketone
Cumene hydroperoxide
(1) Isobutyraldehyde
(2) Isobutylaldehyde
Isobutane
Isobutyl alcohol
(1) tert-Butyl alcohol
(2) t-Butanol
(1) Isobutylene
(2) 2-Methylpropene
Methacrylonitrile
(1) Methacrylic acid methyl ester
(2) Methyl methacrylate
1-Methyl-2-pyrrolidone
1-9
-------
TABLE I.I (Continued). ORGANIC CHEMICAL INDUSTRY
LIST OF CHEMICAL PRODUCTS INCLUDED IN COMPUTER SCREENING
Chemical
number
Chemical name
Common name
158 Naphthalene
159 2,2' ,2"-Nitrilotrisethanol
160 Nitrobenzene
161 1-Nonanol
162 1-Nonene
163 Nonylphenol
164 Nonylphenol, ethoxylated
165 Octene
166 Oil-soluble petroleum sulfonate,
calcium salt
167 Oil-soluble petroleum sulfonate,
sodium salt
168 Oxirane
169 2,2'-Oxybisethanol
170 Pentane
171 3-Pentenenitrile
172 Pentenes, mixed
173 Phenol
174 1-Phenylethyl hydroperoxide
175 Propanal
176 Propane
177 1,2-Propanediol
(1) Naphthene
(2) Naphtha!in
(1) Triethanolamine
(2) Triethylolamine
Nitrobenzol
1) n-Nonanol
2) Nonyl alcohol
Tripropylene
Ethylene oxide
Diethylene glycol
n-Pentane
(1) Carbolic acid
(2) Hydroxybenzene
Propionaldehyde
Dimethyl methane
Propylene glycol
1-10
-------
TABLE I.I (Continued). ORGANIC CHEMICAL INDUSTRY
LIST OF CHEMICAL PRODUCTS INCLUDED IN COMPUTER SCREENING
Chemical
number
Chemical name
Common name
178 Propanenitrile
179 1,2,3-Propanetriol
180 Propanoic acid
181 1-Propanol
182 2-Propanol
183 2-Propanone
184 1-Propene
185 2-Propenenitrile
186 2-Propenoic acid
187 2-Propenoic acid, butyl ester
188 2-Propenoic acid, ethyl ester
189 Propylbenzene
190 Sodium cyanide
191 Tallow acids, potassium salt
192 Tallow acids, sodium salt
193 Tetrabromomethane
194 Tetrachloroethene
195 Tetrachloromethane
196 Tetraethylplumbane
197 1,2,3,4-Tetrahydrobenzene
198 Tetrahydrofuran
(1) Propionitrile
(2) Ethyl cyanide
(1) Glycerol
(2) Glyceryl
(3) Glycerin
Propionic acid
Propyl alcohol
Isopropyl alcohol
(1) Acetone
(2) Dimethyl ketone
Propylene
Acrylonitrile
Acrylic acid
Butyl acrylate
Ethyl acrylate
Phenylpropane
Cyanogran
Carbontetrabromide
(1) Tetrachloroethylene
(2) Perch!oroethylene
Carbon tetrachloride
Tetraethyl lead
Cyclohexene
THF
1-11
-------
TABLE I.I (Continued). ORGANIC CHEMICAL INDUSTRY
LIST OF CHEMICAL PRODUCTS INCLUDED IN COMPUTER SCREENING
Chemical
number
Chemical name
Common name
199 Tetra (methyl-ethyl) plumbane
200 Tetramethylplumbane
201 l,3,5-Triazine-2,4,6-triamine
202 1,1,1-Tribromo-2-methyl-2-propanol
203 1,1,1-Trichloroethane
204 1,1,2-Trichloroethane
205 Trichloroethene
206 Trichlorofluoromethane
207 Trichloromethane
208 2,4,6-Trichloro-l,3,5-triazine
209 l,l,2-Trichloro-l,2,2-
trifluoroethane
210 2,6,6-Trimethylbicyclo-
[3.1.1]hept-2-ene
211 Urea
212 Urea ammonium nitrate
213 3-Hydroxybutyraldehyde
214 2-Butenal
215
2-Butenoic acid
Tetra (methyl-ethyl) lead
Tetramethyl lead
(1) Mel amine
(2) 2,4,6-Triamino-s-triazine
(1) Tribromo-t-butyl alcohol
(2) Acetone-bromoform
(3) Brometone
Methyl chloroform
Vinyl trichloride
Trichloroethylene
(1) Freon 11
(2) Fluorotrichloromethane
Chloroform
1) Cyanuric chloride
2) 2,4,6-Trichloro-s-triazine
I
(1) Trichlorotrifluoroethane
(2) Fliu
Fluorocarbon 113
a-Pinene
(1) Carbamide
(2) Carbonyldiamide
(1) Aldol
(2) Acetaldol
(1) Crotonaldehyde
(2) g-Methylacrolein
Crotonic acid
1-12
-------
TABLE I.I (Continued). ORGANIC CHEMICAL INDUSTRY
LIST OF CHEMICAL PRODUCTS INCLUDED IN COMPUTER SCREENING
Chemical
number
216
217
220
221
222
223
224
225
226
227
228
230
232
234
235
236
237
Chemical name
1,3,5,7-TetKaazatricyclo-
[3.3.1.rj/]decane
6-Methyl heptanol
Methanamine
N-Methylmethanamine
4-Methyl -3-penten-2-one
Benzotri chloride3
1-Bromobutane3
2-Chloroethanola
Ethanamine3
Ethyl -A-nonylatea
Ethyl sul fate3
Isononanol3
Propiol acetone3
Tri bromomethane
1 ,1 ,2 ,2-Tetrachl oroethane
lodomethane
Methyl t-butyl ether
Common name
(1) Hexamine
(2) Hexamethylene tetraamine
(1) Isooctyl alcohol
(2) Isooctanol
Methyl ami ne
Dimethyl ami ne
Mesityl oxide
-
.
'
-
-
-
-
-
Bromoform
-
Methyl iodide
MTBE
Intermediate chemicals, not directly affected by the standards.
1-13
-------
NSPS for distillation. These 10 chemicals are: ethane (90); methane
(132); benzotrichloride (223); 1-bromobutane (224); 2-chloroethanol (225);
ethanamine (226); ethyl-A-nonylate (227); ethylsulfate (228); isononanol
(230); and propiolacetone (232). The last eight chemicals are intermedi-
ates along the chain of production processes between regulated chemicals
and, accordingly, are given numbers for the screening program even though
they are not regulated, since they serve as inputs and carriers of control
costs.
I.I SCREENING DATA AND ASSUMPTIONS
The data and assumptions used .in the screening are presented in Table
1-2 for each chemical and production process. Each line illustrates a
different chemical or production process. The basis for the figures on
each chemical is shown in Tables 9-6 through 9-19 in Section 9.2 of the
BID.1'2'3
The mechanics of the rolled-through cost methodology are summarized in
Section 9.2.2.2 and are explained further in Documentation of the NSPS
SOCMI MAXCOST Model.4 The program calculates the cost of direct controls
at a chemical plant plus control costs for input chemicals (rolled-through
costs) produced prior to each chemical; this is done for each process route,
or combination of process routes, and the screening program uses the
highest-cost production route to calculate the maximum potential price
increase for each chemical.
Several letter codes signify the contents of each column in Table 1-2.
These codes can be explained as follows:
A Chemical number. Each chemical has a number. The numbers are
identified in Table 1-1.
B Cost code. Each chemical is assigned a control cost on the basis
of its classification, as follows. Code 0 indicates a chemical
is produced primarily in refineries, which are assumed to control
VOC emissions even in the absence of NSPS for distillation.
Hence, Code 0 chemicals are assigned no control costs. In addi-
tion to refinery chemicals, five detergent and surfactant chemi-
cals are assigned Code 0 and are assumed to have no control costs
on the basis of the assumption that future plants will not use
distillation.
1-14
-------
Code 1 indicates that production of a chemical involves a halogen
or sulfur and that controlling emissions would require a scrubber
to avoid damage from corrosive airborne compounds. Chemicals
with Code 1 are assigned the highest control costs, $1,160,900
(annualized). Code 2 indicates that a chemical is assumed not to
need a scrubber and is assigned a standard control cost of
$356,000.
As explained in Section 9.2, after chemicals were analyzed int--
tially with Codes 0, 1, and 2, a further code was used for some
chemicals. Code 3 is assigned where chemicals warranted refined
assumptions concerning factors such as number of distillation
columns or flow rates, resulting in lower estimated control
costs. Control costs under Code 3 typically range from $140,000
to $300,000, with higher amounts in a few cases. The specific
control costs in each instance are shown in Column J for chemi-
cals with Code 3.
C Priority code. The computer program calculates the rolled-
through costs of chemicals through a series of calculations in
which control costs are calculated first for input chemicals and
subsequently for derivative chemicals on the list. Priority
codes are assigned to each chemical (and, in some cases, chemical
production process) to instruct the program to calculate costs in
an order that follows the chain of production among chemicals.
The first priority is Code 01, the second is 02, and so on.
Priority codes are simply instructions to the program for its
relative timing of calculations and do not inherently indicate
plant characteristics or importance.
D Number of processes using distillation.
E Number of chemicals used as inputs to produce a chemical.
F Input chemicals, identified by chemical number.
G Proportions of input chemicals used to produce a chemical (kg of
input chemical per kg of a given chemical product).
Columns F and 6 are repeated in the middle space on the printout
if more than one chemical input is used.
H Percentage of industry production using a given process.
I Chemical price (cents/kg) in 1987, expressed in 1978 dollars.
J Annualized control costs (1978 dollars) before taxes. Where a
blank occurs, refer to Column B for the annualized cost code.
Figures appear in Column J only when chemicals have been assigned
Code 3.
K Size of an average plant producing a chemical. Expressed in Gg
of annual production. Assumptions are explained in Section
1-15
-------
9.2.3. An asterisk indicates that the minimum national produc-
tion level of 45.4 Gg was used in calculating average plant size,
after being divided by the actual or estimated number of plants
producing the chemical. A # indicates that the plant size is
assumed to be 45.4 Gg. Tables 9-6 through 9-19 present chemical-
specific data on production in the base year (1978) and the
number of plants.
Price quotations are not available for a number of chemicals. The
threshold approach (described in Section 9.2) is used for the following 33
chemicals and indicates that none of them would have price increases of 5
percent or more: 22, 33, 42, 55, 63, 65, 68, 69, 76, 83, 101, 104, 105,
118, 120, 121, 124, 129, 137, 149, 155, 161, 171, 174, 178, 189, 193, 197,
202, 208, 213, 214, and 236.
One refinery chemical (147) does not have price data, but is assumed
not to have control costs on the assumption that refineries would control
VOC emissions even in the absence of NSPS for distillation. Six detergent
and surfactant chemicals are assumed not to have control costs because
future plants are not expected to use distillation; these are:
benzenesulfonic acid, mono-C,Q ,g-alkyl derivatives, sodium salts (22);
dodecylbenzenesulfom'c acid (88); dodecylbenzenesulfonic acid, sodium salt
(89); linear alcohols, ethoxylated, mixed (129); linear alcohols, ethoxy-
lated and sulfated, sodium salt, mixed (130); and nonylphenol, ethoxylated
(164).
Among refinery chemicals, in particular, there are a number of blanks
in Table 1-2. The blanks do not limit the analysis because refinery chemi-
cals are not assigned control costs on the assumption that refineries will
adopt VOC controls even in the absence of NSPS for distillation and, there-
fore, a price analysis is not necessary. There also are blanks for some
data involving the 10 chemicals listed in the program but not regulated by
NSPS; rolled-through control costs are counted on a per kg basis for these
chemicals, but aggregate plant data are not needed.
1.2 SCREENING RESULTS
The results of the screening analysis for each chemical are presented
in Table 1-3. The key below explains each column.
A Chemical number. Each number represents a particular chemical.
B Chemical price (<£/kg) in 1987, expressed in 1978-value dollars.
1-16
-------
C Annualized control costs (<£/kg) incurred directly in the produc-
tion of a given chemical, rounded to the nearest tenth of a cent.
D All annual ized control costs (<£/kg) incurred in the production of
a given chemical, including both direct control costs and rolled-
through control costs incurred in the production of input chemi-
cals (weighted in proportion to the extent inputs are used),
rounded to the nearest tenth of a cent.
E Increase (percent) in the 1987 chemical price if all annualized
control costs were passed through by producers, rounded to the
nearest hundredth of a percentage point.
F Flag. F signifies a chemical is a refinery chemical. (Chemicals
39 and 162 are also reinfery chemicals but are not flagged with
an F.) @ signifies that no price is available for a chemical
and, instead, a threshold price is calculated (equal to the
annualized control cost times the reciprocal of 5 percent).
G Index number of chemicals.
H Threshold price. Calculated as explained in F. Indicates a
point which, if exceeded by the prices of input chemicals weight-
ed by their proportion of use, signifies a chemical would not
fail the 5 percent price increase screening criterion.
1-17
-------
TABLE 1-2. SCREENING DATA AND ASSUMPTIONS
A B
ftfti t
001 3
001 3
002 3
002 3
002 3
0033
004 3
005 3
0053
0063
0072
008 3
0033
0083
0093
0102
Oil 3
0120
0132
0142
0153
016 3
0172
0182
0192
0202
0202
021 3
021 3
0220
023 3
0233
024 3
0253
0262
0262
0270
028 3
0290
030 0
031 3
032 3
f»33 3
0343
035 1
036 3
036 3
C
n-5
03
03
04
04
04
05
08
05
05
05
05
02
02
02
02
03
03
01
02
02
04
AS
03
03
03
03
03
02
02
03
02
03
02
04
02
02
01
06
01
01
05
05
0?
07
02
03
03
D E
ft1? m
03 01
03 rtl
0301
0301
03 01
01 01
01 02
0202
02 02
01 02
01-01
0301
0301
0301
01 01
01 01
01 01
01 01
01 01
01 02
ft1 M
01 02
01 02
01 02
0202
0202
0201
0201
01 01
02 01
0201
01 01
01 02
02 01
0201
0201
01 01
01 01
01 01
0201
01 01
02 01
02 01
F
n
-------
TABLE 1-2. SCREENING DATA AND ASSUMPTIONS (CONTINUED)
A B C D E F Q
037001 00 00 • ' '
038 0 01 00 00
03? 0 02 01 01
040 3 OS 01 02 168 .59 34 .90
041 2 04 01 02 106 00.43 108 1.00
042301
(!43 3 02 01 01 132 00.25
044 3 01 00 00
045 3 02 01 01 012 00.95
046 1 03 01 01 026 00.37
048 3 03 02 01 94 00.49
048 3 03 02 01 93 00.75
0493030201 7201,65
049 3 03 02 01 106 00.44
050 1 04 01 02 208 1.22 226 .30
051 30201 01 13200.30
052 .3 02 01 01 135 00.78
053 1 02 01 01 184 00.76
054 1 03 01 01 045 1.02
055 1 03 02 01 184 .64
055 1 03 02 01 056 1.16
056 1 02 01 01 184 .79
057 3 01 00
058 3 02 01 0! 012 .94
060 2 03 01 01 58 .94
061 3 04 02 01 58 1.20
061 3 05 02 01 173 1.34
062 3 08 02 01 58 1.01
062 3 03 02 01 173 1.01
0632090201 62 1.24
063 2 09 02 01 62 1.06
064 0 01
065 3 02 01 01 094 .93
066 1 02 01 01 094 .15
067 001
068 1 040201 026 1.88
068 1 04 02 01 069 1.43
069 3 03 01 01 026 0.94
070 3 04 01 01 195 1.60
071 1 03 01 01 51 1.12
072 1 02 02 01 94 .32
072 1 020201 94 .41
073 3 04 01 01 204 1.38
074 3 03 01 01 207 1.45
075 1 02 01 01 132 .18
076 3 03 01 01 56 .85
077 203 01 02 99 1.12 94 .30
H
100
loo
100
100
100
100
100
loo
100
100
75
25
50
50
100
100
100
100
100
51
49
100
100
35
85
85
15
50
50
95
05
100
100
100
50
50
100
100
100
51
49
75
100
100
ion
100
1
102.0
67.0
40.0
164.0
508.0
60.0
184.0
122.0
334.0
82.0
82.0
72.0
72.0
994.0
104.0
181.0
263.0
246.0
156.0
59.0
62.0
193.0
203.0
203.0
181.0
181.0
191.0
35.0
317.0
992.0
45.0
45.0
97.0
337.0
170.0
273.0
J K
53.6
389.0
176.0
27330$ 021.5
022.7 *
152200 45.4 *
215000 043.2
577800 34.6
304000 022.3
060.0
444000035.0
444000 035.0
312000 224.9
312000 224.9
015.1 *
267400 18.7
251200 10.0
52.3
45.4 *
530.0
530.0
26.0
152200 006.7
142600 096.2
112.4
149300 63.9
149300 63.9
149300 65.9
149300 65.9
011.4 *
011.4 *
f
282000 045.4 *
026.0
11.4 *
257.0
257.0
859300 368.0
220700 014.8
022.7 *
293.5
293.5
216100 15.1 *
235100 110.5
037.0
444000 202.7 *
22.7 *
1-19
-------
TABLE 1-2. SCREENING DATA AND ASSUMPTIONS (CONTINUED)
A BC D E F G
H
I
K
078 3 04 01 02 44 1.43 137 .38
079 0 01
030001
081 001
082001
083 1 03 02 01 133 1.22
083 1 03 02 01 153 .95
084 3 05 ol 02 173 3.08 133 1.05
085001
086 2 02 01 02 12 .35 85 .76
087 2 02 01 01 12 .35
088 0 03 01 01 86 .75
089 0 02 01 02 85 .40 12 .13
0900 01
091 2 03 01 01 168 .75
092 3 03 01 01 168 .90
0933020201 94 .65
0933020201 94 .61
094 0 01
095 3 05 02 01 183 1.94
095 3 05 02 01 002 2.04
096 2 02 01 02 12 00.87 94 00.32
097 3 03 01 02 168 .57 93 .60
098 3 05 01 02 97 .97 2 .65
099 2 02 01 02 12 .74 94 .27
101 3 07 01 01 28 2.29
102 3 07 01 01 28 1.30
103 3 08 01 01 102 1.44
104 2 02 01 02 135 1.08 94 .33
105 3 03 01 02 99 .64 127 .90
106 3 02 03 01 132 4.44
106 3 02 03 01 90 2.53
106 3 02 03 01 176 2.82
107 3 01 00 00
108 3 03 01 01 133 .47
109 2 02 02 01 12 1.87
109 2 02 02 01 139 .82
110 2 01 00 00
111 0 01
112 0 01
113 3 03 01 01 9 1.35
114 3 09 01 01 62 1.46
115 0 01
116 3 07 01 01 118 1.00
117 3 03 01 02 116 .63 120 .80
118 3 06 02 01 120 1.93
118 3 06>02 01 119 1.40
119 3 03 01 01 58 .80
120 2 05 01 01 068 01.68
100
236.0 193500 109.5
40.0 078.6
60.0 38.3
122.0 52.0
67.0 113.9
90
100
100
100
100
100
100
100
50
50
352.0
67.0
161.0
161.0
169.0
149.0
25.0
92.0
169.0
92.0
92.0
145800
155400
170000
170000
015.1 *
16.3
59.8
46.7
003.2
003.6
167.9
104.2
003.9
044.2
044.2
69.0 318.2
50 238.0 140900 #
50 238.0 140900 #
100 94.0 232.9
100 149.0 140400 36.2
100 184.0 135200 045.4 *
100 57.0 200.2
100 140900 045.4 *
100 114.0 253000 038.2
100 521.0 267200 009.1 *
100 #
100 230400 2
33 365.0 276600 11.2
33 365.0 276600 11.2
33 365.0 276600 11.2
64.0 152200 11.4 *
75 37.0 140900 54.6
50 131.0 15.5
50 131.0 - 15.5
100 70.0 018.6
100 50.0 6.5 *
100 55.0 15.1 *
100 610.0 317800 045.4 *
100 283.0 131300 139.0
52.0 28.4
100 146.0 149000 55.6
100 288.0 149000 138.0
50 163300 46.3
50 168300 46.3
95 223.0 168300 147.0
100 153.0
1-20
-------
TABLE 1-2. SCREENING DATA AND ASSUMPTIONS (CONTINUED)
A BC D E F G
H
K
12! 2 03 01 01 26 .73
122 2 02 01 01 132 .79
123 3 04 01 01 183 .71
i?4 3 04 01 01 <83 .60
125 2 01 00 00
126 2 03 0! 0! 168 .88
127 2 02 02 01 158 1.25
127 2 02 02 01 80 0.98
128 2 02 0! 0! 162 1.25
129 0 03 01 01 168 00.44
130 0 03 0! 01 168 ,44
13! 3 03 0! 01 09 .96
132 00!
133 3 01 00 00
134 3 03 01 02 168 .58 133 .60
135 0 0!
136 3 03 01 01 143 1.57
137 2 03 0! 01 143 3.57
138 3 02 01 0! 115 01.03
139 0 0!
140 0 0!
14! 00!
142 2 02 01 01 135 .5!
143 3020! 0! 13500.5!
144 2 02 01 02 012 00.80 184 00.43
145 3 05 01 02 183 00.27 173 .88
146 2 02 02 01 184 .94
146. 2 02 02 02 184 .78 15! 3.00
147 0 01
148 3 06 0! 0! 183 01.25
149 2 03 0! 0! 144 .80
150 3 02 0! 0! !84 03.00
15! 00!
!52 3 07 02 0! 028 OL03
153 2 02 0! 01 154 1.85
154 0 0!
•55 2 02 01 0! 154 01.00
156 2 04 0! 03 183 00.58 122 .27 133
157 2 04 0! 02 106 .37 108 .43
158 0 01
159 2 03 01 01 168 .93
160 3 02 01 01 12 .65
161 3 05 0! 01 227 3.27
!62 3 01
163 3 05 01 02 173 00.62 162 00.45
100
100
100
100
100
100
35
65
100
100
100
100
100
100
100
100
100
100
75
100
!00
100
100
70
30
100
100
100
100
70
100
100
.32
100
100
100
100
100
244.0
159.0
137.0
191.0
131.0
131.0
129.0
181.0
432.0
43.0
154.0
42.0
278.0
84.0
35.0
72,0
72.0
117.0
312.0
60.0
191.0
131.0
131.0
149.0
126.0
35.0
72.0
144.0
82.0
231.0
394.0
84.0
203.0
114.0
60.0
126.0
*
14.7
278300 30.8
134100 139.7
023.0
10.6
40.4
40.4
33.5
2.2*
003.8 *
968100 11.4.*
195000 243.6
140000 007.4
72.8
230700 5.7
22.7 *
495600 017.8
22.7 *
45.4 *
15.1 *.
74.5
269000 74.5
109.5
140900 53.5
132.7
132.7
045.4 *
253000 21.2
394.4
149000 10.4
27.3
149000 9.4
227.0
30.9
9
52.4 .
015.1 *
5.9
10.4
157000 037.3
280600 045.4 *
039.2
147400 005.8
1-21
-------
TABLE 1-2. SCREENING DATA AND ASSUMPTIONS (CONTINUED)
A B
164 0
C
05
D
01
E
02
F
136
G
1.27
93
.26
H
100
1
181.0
J
K
4.7
165 0 01 154.0 11.4 *
166 3 01 100 235.0 968100 017.9
167 2 01 100 164.0 009.3
168 3 02 01 01 94 1.10 100 126.0 133800 142.1
169 3 03 Qt 01 168 .84 100 92.0 155400 9.4
170001 " 35.0 15.1 *
171 2 03 01 01 26 .96 100 3
172 0 01 72.0 3
173 3 04 01 01 149 1.62 88 87.0 240000 67.6
174 2 03 01 01 96 1.09 100 #
175 2 03 03 01 146 .66 33 141.0 15.1 *
175 2 03 03 01 146 .80 33 141.0 15.1 *
175 2 03 03 01 094 .47 33 141.0 15.1 *
176 0 01 30.0 109.6
177 2 03 01 01 146 .76 100 131.0 041.3
178 2 04 03 01 180 1.92 33 #
178 2 04 03 01 185 1.38 33 2
178 2 04 03 01 228 3.27 33 f
179 3 03 02 01 184 .63 50 278.0 823700 015.3
179 3 03 02 02 184 .93 182 1.10 50 278.0 823700 015.3
180 3 03 02 01 94 .54 50 92.0 193500 22.3
180 3 03 02 01 93 .89 50 92.0 193500 22.8
181 3 04 01 01 175 1.40 50 131.0 249100 24.3
182 3 02 01 01 184 00.90 100 64.0 170000 157.0
183 3 03 02 01 182 01.23 40 74.0 218400 57.2
183 3 03 02 01 144 01.38 55 74.0 213400 57.2
184 0 01 52.0 088.1
185 2 02 01 01 184 1.12 100 126.0 132.5
186 3 02 01 01 184 0.83 176.0 149000 49.0
187 2 08 03 02 106 .28 34 .72 50 196.0 025.4
187 2 08 03 02 232 .57 34 .58 20 196.0 025.4
187 2 08 03 02 184 .47 34 .83 30 196.0 025.4
188 2 03 02 02 106 .26 93 00.46 50 164.0 027.2
188 2 03 02 02 184 .42 93 .46 50 164.0 027.2
189 3 02 01 02 12 .93 184 .50 100 149300 15.1 *
190 3 01 100 218.0 152200 022.7 *
l?i 3 oi 100 63.0 152200 045.4 *
192301 100 63.0 152200 10.2
'93 * 04 01 01 195 .66 100 227.0
194 3 04 03 01 235 1.20 33 67.0 330200 029.9
194 3 04 03 01 235 1.01 33 67.0 330200 029.9
194 3 04 03 01 94 .28 33 67.0 330200 029.9
195 3 03 02 01 043 .55 50 80.0 330200 30.4
195 3 03 02 01 132 .11 50 80.0 330200 30.4
1-22
-------
TABLE 1-2. SCREENING DATA AND ASSUMPTIONS (CONTINUED)
A SO D
196 1 04 01
1?? 2 06 01
198 3 % 01
199 3 04 01
200 30302
200
201
202
203
203
204
204
205
205
206
207
208
209
210
211
212
213
214
215
216
217
220
221
222
223
224
225
226
227
228
230
232
234
235
236
237
303
2
3
3
3
3
3
3
3
3
3
3
1
3
0
3
3
3
2
3
O
2
3
3
0
0
0
0
0
0
6
0
t
3
3
2
02
04
05
05
03
03
03
03
04
02
03
06
01
01
02
04
05
06
04
02
02
02
05
02
08
02
02
04
02
02
07
04
03
03
02
02
01
01
02
02
02
02
02
02
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
E
F
01 048
01 61
01 32
01 48
01 51
01
01
01
61
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
02
01
01
01
02
51
211
183
49
73
72
72
106
72
195
132
122
194
211
1
213
214
108
112
133
133
183
135
034
094
093
091
094
039
095
189
106
133
133
G
.80
1.74
1.79
.73
.22
.75
3.10
.27
.47
.73
.62
1.06
0.22
1.50
1.60
.13
0.44
1.26
.36
1.05
1.63
1.44
3.58
1.33
LOS
0.91
1.25
0.67
0.77
0.50
1.12
0.36
0.32
1.25
0.83 108 0.60
0.32
0.22
0.32
0.36 154 0.64
1-23
H
100
100
100
100
100
60
30
51
49
50
50
100
100
100
100
100
100
76
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
1
590.0
409.0
580.0
782.0
782.0
264.0
114.0
114.0
176.0
176.0
87.0
87.0
251.0
164.0
332.0
57.0
47.0
43.0
471.0
220.0
126.0
247.0
267.0
176.0
640.0
146.0
42.0
J
K
024.8
521.5
149300 015.0
232400 027.8
232400 73.5
232400
280600
236300
236300
236300
236300
330200
330200
220700
223200
444000
107500
152200
165000
163000
146500
267200
193500
330000
255500
73.5
017.0
097.3
097.3
15.1
15.1
027.2
027.2
009.8
031.6
011.4
015.1
004.6
121.1
022.7
9.3
022.7
020.8
9.1
11.4
045.4
045.4
011.4
85.6
#
$
*
*
«
9
*
*
*
*
*
*
*
*
*
-------
TABLE 1-3. SCREENING RESULTS
A
i
2
3
&
5
6
7
8
9
10
n
12
13
14
15
16
17
18
19
20
21
22
23
24
- 25
24
27
28
29
30
31
32
33
34
35
36
37
38
39
40
£1
42
43
44
45
46
48
49
B
104.0
82.0
131.0
141.0
99.0
104.0
717.0
181.0
159.0
176.0
122.0
55.0
161.0
112.0
169.0
203.0
171.0
154.0
154.0
112.0
179.?
0.0
131.0
131.0
236.0
107.0
107.0
99.0
27.0
37.0
223.0
241.0
0.0
92.0
126.0
104.0
102.0
67.0
40.0
164.0
508.0
0.0
60.0
184.0
122.0
384.0
82.0
72.0
C
0.6
0.2
0.1
1.2
0.1
1.3
3.1
1.1
1.2
3.0
0.4
0.0
0.8
0.1
1.0
2.2
0.8
3.0
0.8
0.1
3.3
0.0
2.9
2.5
2.0
0.4
0.0
0.3
0.0
0.0
0.7
0.5
0.4
0.4
2.5
0.3
0.0
0.0
0.0
1.3
1.6
0.3
0.5
1.7
1.4
1.9
L3
0.1
D
1.0
1.3
1.9
2.4
1.9
2.5
4.7
1.1
1.2
3.0
1.0
0.0
0.8
0.1
1.9
4.0
2.4
4.2
1.1
0.2
3.3
0.7
2.9
2.5
3.4
0.4
0.0
0.3
0.0
0.0
3.0
4.0
8.5
0.7
2.5
3.2
0.0
0.0
0.0
1.9
2.9
0.3
0.5
1.7
1.4
2.3
1.6
1.2
E F
1.00
1.59
1.45
1.72
1.90
2.37
0.65
0.59
0.75
1.73
0.81
0.00 F
0.49
0.10
1.10
1.95
1.43
2.73
0.73
0.22
1.83
0.00 §
2.23
1.93
1.43
0.42
0.00 F
0.25
0.00 F
0.00 F
1.35
1.65
0.00 8
0.72
1.95
3.09
0.00 F
0.00 F
0.00
1.19
0.58
0.00 i
0.83
0.91
1.12
0.61
1.90
1.70
G
2.0
4.0
7.0
8.0
10.0
11.0
12.0
13.0
14.0
15.0
16.0
17.0
18.0
19.0
20.0
21.0
22.0
23.0
24.0
25.0
27.0
31.0
32.0
33.0
34.0
35.0
37.0
38.0
40.0
41.0
42.0
43.0
44.0
45.0
47.0
48.0
49.0
50.0
51.0
54.0
54.0
55.0
56.0
57.0
58.0
59 0
62.0
64.0
H
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
14.8
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
170.6
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
6.7
0.0
0.0
0.0
0.0
0.0
0.0
1-24
-------
TABLE 1-3. SCREENING RESULTS (CONTINUED)
A
50
•51
52
53
«v4
55
56
57
58
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
7?
80
SI
32
83
84
85
86
87
Rfl
\J —
89
90
91
92
93
-------
TABLE 1-3. SCREENING RESULTS (CONTINUED)
A
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
125
126
127
128
129
130
13'
132
133
134
135
136
137
138
139
140
141
142
143
144
145
146
147
B
0.0
114.0
521.0
0.0
0.0
365.0
64.0
37.0
131.0
~70.0
50.0
55.0
610.0
283.0
52.0
146.0
288.0
0.0
228.0
0.0
0.0
244.0
159.0
0.0
137.0
191.0
131,0
129.0
0.0
181.0
432.0
0.0
43.0
154.0
42.0
278.0
0.0
84.0
35.0
72.0
72.0
117.0
312.0
60.0
191.0
131.0
0.0
C
0.3
0.7
2.9
0.8
0.5
2.5
1.3
0.3
2.3
1.9
0.0
0.0
0.7
0.1
0.0
0.3
0.1
0.4
0.1
0.2
0.8
2.4
0.9
0.1
1.5
3.4
0.9
1.1
0.0
0.0
8.5
0.0
0.1
1.9
0.0
4.0
1.6
2.8
0.0
0.0
0.0
0.5
0.4
0.3
0.3
0.3
0.0
D
0.9
1.0
4.4
0.8
1.4
2.5
1.3
0.3
2.3
1.9
0.0
0.0
2.3
1.8
0.0
5.6
5.7
5.3
0.2
2.6
1.1
2.4
1.5
0.6
1.5
3.4
0.9
1.1
0.0
0.0
9.6
0.0
0.1
2.0
0.0
4.6
2.9
2.8
0.0
0.0
0.0
0.5
0.4
0.3
1.3
0.3
0.0
E
0.00
0.87
0.84
0.00
0.00
0.68
2.09
0.80
1.75
2.73
0.00
0.00
0.38
0.63
0.00
3.82
1.97
0.00
0.10
0.00
0.00
0.99
0.94
0.00
1.13
1.80
0.67
0.32
0.00
0.02
2.23
0.00
0.19
1.30
0.00
1.66
0.00
3.31
0.00
0.00
0.00
0.41
0.12
0.54
0.68
0.20
0.00
F
i
a
i
F
F
F
§
§
§
S
i
p
F
§
F
p
F
p
G
125.0
126.0
127.0
128.0
129.0
130.0
133.0
134.0
iw ft
137.0
138.0
139.0
140.0
141.0
142.0
143.0
144.0
145.0
147.0
148.0
149.0
150.0
151.0
152.0
153.0
I'tt ft
155.0
157.0
158.0
159.0
160.0
161.0
162.0
163.0
164.0
165.0
166.0
167.0
168.0
169.0
170.0
171.0
172.0
173.0
174.0
175.0
177.0
H
17.7
0.0
0.0
15.7
28.3
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
106.1
0.0
51.2
22.2
0.0
0.0
11.9
0.0
0.0
0.0
0.0
0.8
0.0
0.0
0.0
0.0
0.0
0.0
0.0
57.1
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
1-26
-------
TABLE 1-3. SCREENING RESULTS (CONTINUED)
A
148
149
150
151
152
153
154
155
• 156
15?
158
15?
160
141
162
163
164
165
166
167
168
169
170
171
172
173
174
175
176
177
178
179
180
181
182
183
184
185
186
187
188
189
1?0
191
192
B
149.0
0.0
126.0
35.0
72.0
144.0
82.0
0.0
231.0
394.0
84.0
203.0
114.0
0.0
60.0
126.0
- 181.0
154.0
285.0
164.0
126.0
92.0
35.0
0.0
72.0
37.0
0.0
141.0
30.0
131.0
0.0
278.0
92.0
131.0
64.0
74.0
52.0
126.0
176.0
196.0
164.0
0.0
218.0
63.0
63.0
c
1.2
0.1
1.4
0.0
1.6
0.2
0.0
0.8
0.7
2.4
0.0
3.4
0.4
0.6
0.0
2.5
0.0
0.0
5.4
3.6
0.1
1.7
0.0
0.8
0.0
0.4
0.8
2.4
0.0
0.9
0.8
5,4
0.8
1.0
0.1
0.4
0.0
0.3
0.3
1.4
1.3
1.0
0.7
0.3
1.5
D
2.2
0.4
1.4
0.0
1.8
0.2
0.0
0.8
1.8
3.4
0.0
3.5
0.4
1.1
0.0
3.1
6.0
0.0
5.4
3.6
0.1
1.7
0.0
1.2
0.0
0.9
1.0
2.6
0.0
1.1
3.1
5.5
1.2
4.6
0.1
0.8
0.0
0.3
0.3
3.3
2.1
1.0
0.7
0.3
1.5
E
1.50
0.00
1.14
0.00
2.56
0.11
0.00
0.00
0.80
0.86
0.00
1.73
0.37
0.00
0.00
2.47
3.29
0.00
1.90
2.22
0.07
1.88
0.00
0.00
0.00
1.06
0.00
1.82
0.00
0.81
0.00
1.98
1.29
3.53
0.17
1.12
0.00
0.21
0.17
1.68
1.30
0.00
0.31
0.53
2.37
F
§ •
F
F
a
F
a
F
F
§
F
§
F
§
F
§
G
178.0
179.0
180.0
181.0
182.0
184.0
185.0
186.0
187.0
188.0
189.0
190.0
191.0
192.0
193.0
194.0
195.0
196.0
197.0
198.0
199.0
200.0
201.0
202.0
203.0
204.0
208.0
209.1
210.0
211.0
212.0
214,0
216.0
217.0
218.0
220.0
221.0
222.0
223.0
225.0
227.0
229.0
230.0
231.0
232.0
H
0.0
7.0
0.0
0.0
0.0
0.0
0.0
15.7
0.0
0.0
0.0
0.0
0.0
22.1
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
24.3
0.0
0.0
19.0
0.0
0.0 -
0.0
61.4
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
.0.0
19.8
0.0
0.0
0.0
1-27
-------
TABLE 1-3. SCREENING RESULTS (CONTINUED)
A
193
194
195
196
197
198
199
200
201
202
203
204
205
206
207
208
209
210
211
212
213
214
215
. 216
217
220
221
222
223
224
225
226
227
228
7-50
232
234
235
236
237
B
0.0
67.0
80.0
590.0
0.0
409.0
580.0
782.0
264.0
0.0
114.0
176.0 '
87.0
251.0
164.0
0.0
332.0
57.0
47.0
43.0
0.0
0.0
471.0
220.0
126.0
247.0
267.0
176.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
640.0
146.0
0.0
42.0
C
0.5
1.1
1.1
4.7
0.1
1.0
0.8
0.3
2.1
0.6
0.2
1.6
1.2
2.3
0.7
3.9
7.7
2.3
0.0
0.3
0.4
0.7
0.8
1.6
1.6
1.7
2.9
1.7
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
2.6
0.7
2.2
0.4
D
1.4
2.6
1.4
5.9
2.6
8.1
2.0
1.4
2.1
0.8
3.3
2.0
1.8
4.4
0.7
5.0
11.0
2.3
0.0
0.3
1.5
3.1
5.2
2.6
1.6
1.7
2.9
2.7
0.0
0.5
0.0
0.0
0.1
0.0
0.0
2.6
2.9
1.3
2.3
0.4
E
0.00
3.92
1.70
1.00
0.00
1.98
0.34
0.18
0.79
0.00
2.88
1.13
2.08
1.76
0.43
0.00
3.31
4.10
0.00
0.78
0.00
0.00
1.11
1.20
1.24
0.69
1.10
1.55
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.45
0.87
0.00
0.99
F
i
§
§
@
F
Q
i
§
§
8
§
i
8
s
8
a
G
233.0
234.0
235.0
237.0
238.0
240.0
241.0
243.0
244.0
245.0
247.0
249.0
251.0
252.0
253.0
254.0
255.0
256.0
256.1
256.2
259.0
260.0
261.0
262.0
263.0
266.0
267.0
268.0
269.0
270.0
271.0
272.0
273.0
274.0
277.0
278.0
280.0
281.0
282.0
283.0
H
28.2
0.0
0.0
0.0
52.5
0.0
0.0 '
0.0
0.0
16.8
0.0
0.0
0.0
0.0
0.0
99.2
0.0
0.0
0.0
0.0
29.2
61.9
0.0
0.0
0.0
0.0
0.0
• 0.0
0.0
10.3
0.0
0.0
3.0
0.0
0.0
52.9
0.0
0.0
45.3
0.0
1-28
-------
1.3 REFERENCES FOR APPENDIX I
1. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. March 21,
1383. Sources and Values of data used in the economic screening for
organic chemicals in the BID for Distillation NSPS.
2. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. April 27,
1983. Supplemental data for the screening analysis. Part 1.
3. Viola, J. EEA Inc. Memo to the Distillation NSPS Docket. April 27,
1983. Supplemental data for the screening analysis. Part 2.
4. EEA Inc. Documentation of the SOCMI MAXCOST Model. April 1982.
Prepared for U.S. Environmental Protection Agency. Office of Air
Quality Planning and Standards.
1-29
-------
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
REPOBT NO.
EPA-450/3-83-005a
3. RECIPIENT'S ACCESSION NO.
. TITLE AND SUBTITLE
Distillation Operations in Synthetic Organic Chemical
Manufacturing Industry - Background Information for
Proposed Standards
5. REPORT DATE
December 1983
6. PERFORMING ORGANIZATION CODE
AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
, PERFORMING ORGANIZATION NAME AND ADDRESS
Office of Air Quality Planning and Standards
Environmental Protection Agency
Research Triangle Park, North Carolina 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
DU-78-C132
12. SPONSORING AGENCY NAME AND ADDRESS
DAA for Air Quality Planning and Standards
Office of Air, Noise, and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
13. TYPE OF REPORT AND PERIOD COVERED
Interim Final
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Standards of Performance for the control of volatile organic compound emissions from
distillation operations in the synthetic organic chemical manufacturing industry are
beinci proposed'under the authority of Section 111 of the Clean Air Act. These standards
would apply to new, modified, and reconstructed distillation facilities. This
document contains background information and environmental and economic impact
assessments of the regulatory alternative's considered in developing proposed standards.
17.
KEY WORDS AND DOCUMENT ANALYSIS
a.
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Air pollution
Pollution control
Standards of performance
Distillation operations
Volatile organic compounds
Synthetic Organic Chemical Manufacturing
Industry
Air pollution control
13B
is. DISTRIBUTION STATEMENT
19. SECURITY CLASS f TMs Report/
Unclassified
21. NO. OF PAGES
395
Unlimited
20, SECURITY CLASS (TMs page I
Unclassified
22. PRICE
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