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
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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.
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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.
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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,
                                     2-3

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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
                                    2-4

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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
                                    2-5

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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
                                    2-7

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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
                                    2-10

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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).
                                    2-11

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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.
                                    2-12

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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.

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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.

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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
                                     3-6

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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.
                                     3-7

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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.
                                     3-8

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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
                                     3-9

-------
      Pressure Control
              Valve
Feed
                              Overheads (Gas)
                              or Light Ends
                                 Flash
                                 Distillation Column
                               Bottoms (Liquid)
                               or Heavy Ends
      Figure 3-3.  Flash distillation.
                      3-10

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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

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            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

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                            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

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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

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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

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                       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

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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

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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

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                                                                        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

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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

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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

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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

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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

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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

-------
     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

-------
  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

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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
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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
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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.
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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.
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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.
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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).
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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
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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
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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).
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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.
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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.
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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
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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
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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.
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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.              '
                                     7-1

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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.
                                     7-3

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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

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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

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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

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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

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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

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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

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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

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                                  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

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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

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                            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.

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                                   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

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                                   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

-------
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

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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

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     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

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   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

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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

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     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

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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

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     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

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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

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                 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.

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     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

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    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

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     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

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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

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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

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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

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     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

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     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

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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

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                                                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
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          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

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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

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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

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     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

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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

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                      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

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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

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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

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     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

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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.

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                          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

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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

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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

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                     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

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                 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.

-------
                 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.

-------
               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

-------
          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

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     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

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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

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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

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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

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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.
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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

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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
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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

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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,
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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.
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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
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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.
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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.
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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

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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

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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

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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

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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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15,16,108


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113,114,115

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144,145,146
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148,149,150
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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
Ra CHT FLH ooo.ooo oooo oooo.ooo ooo.oo ooo.oo ooo.oo ooo.oo ooo.oo
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
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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
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ATH CNT FRC 79.300 1453 0401.000 100.00 023.10 000.00 044.30 012.40
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. CON. .ATH ,_CNT_FRC 	 0.300— 4978— 0004.900— 100.00— 044.40—000.00 -055.40—000.00
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ATH CNT FRC 999.999 9999 9999.999 999.99 999.99 999.99 999.99 999.99
ATH i CHT; FRC 2.000 oooo 0000.003 ooo.oo ooo.oo 079.00 ooo.oo 021.00
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ATM1: CNT FRC 19.500 OOOO 0000.000 000. OQi '000.00! iW.OO 000.00 " 021.00
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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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158,157,140
141,142,143

40,41,42










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28,27,30


68,69,164


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132,133,168

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145,146,173
174
175
176,177,178
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128,127,179
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179,180,181
34,35,182
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183
184,185,186
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15,16,183
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54,197,178
X 54
54,84,85
17?
200,201,202
. 55,56,57

-------
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53 SB
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58 AH
58 DE
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NV
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NV
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CON
COH
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CON
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CON
COM
COH
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CON
COH
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SCB
CON
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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
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"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
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71
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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
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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
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128,127
214,215,216
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138,137,21?

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79,220,221 --
4,5,6

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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
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CO
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-000;00 -000.00- 000.00
FRC 000.000 0000 0000.000 000.00 000.00 000.00 000.00 000.00
FRC 000.000 0000 0000.000 000.00 000.00 000.00 000.00 000.00
FRC -000:000-0000 ~0000:000~-000;00— OOOTOO -000700-000.00 - 000:00
FRC 000.000 0000 0000.000 000.00 000.00 000.00 000.00 000.00
FRC 000.000 0000 0000.000 000.00 ,000.00 000.00 000.00 000.00
- FRC- 9??-.79?—»79?-7???:779 -777:97— 777:77 -777:77— 777.7?— 777.7?
FRC 65.000 6 17.000 13.00 1.30 70.00 2.70 5.60
RR 0.100 834 0.250 27.50 31.20 41.30 0.0 0.0
CHT- t-KUii jo.rui — f£s ~av*v\s — a:w B.OU HZ.W «.«« u.u
CHT FRC 16.700 1464 0.100 40.80 40.30 19.50 40.30 0.0
CNT
CNT
CNT
CNT
CNT
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RH 80.000 7 17.600, 5.10 33.50 2.20 1.60 " 62.70
RH-f 3;300 	 90— 28.800— 72:50 — 33:30—33:30 — 33^40*— 0.0
FRC' 999.799 ???? 7779.999 997.99 777.7? 777.9? 999.97,999.99
FLH; 000.000 0000 0000.000.000.00 000.00 000.00 000.00 000.00
-FRC-000.000-0000— 0000:0001000:00— 000:00-000.00— 000.00J-000.00
FRC 999.999 9979 9799.99? 999.9? 977.7? ???.??; 977.7? 997.79
CNT FRC 000.000 0000 0000.000: 000.00 000.00 '?, 000.00 000.00^000.00
CNT FRC— 999:997 — 9999 — 9979779? 799:9?— 777^7 797.77 997:77 777;7?
CNT
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CNT
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CNT-
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CNT-
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RH 000.000 0000 0000.000 000.00 000.00 000.00 000.00 000.00
FLH 999.99? 9999 779?. 799 799.99 999.7? • 777.77 ???. 77; 779.99
-FRC— 999; 99? 9979— 777?.???:— 7??r97 — ??9:??-'~997;??— 777:7? 777.7?
FLH 000.000 0000 0000.000 000.00 000.00 000.00 000.00 000.00
FRC 999.999 7999 9797.9T? 997.99 977.77 779.77 T77.9? 999.7?
-FRC*~000;000~0000 — 0000.000"^000:00— 000;00"~000:00— 000;00 000;00
FRC 000.000 -A 0000 0000.000 1 000.00 000.00 : 000.00 000.00 000.00
FRC' 000.000 • 0000 OOOO.OOOS 000.00 OOO.OOi OOO.OO; 000.00 000.00
FRC- 997.999 > 999? 	 3;700r97?;?7 -?77.7? ;-?77.7r-77?;??-?7?.?9
FRC 777.777 ! 7999 5.200? 999.99 779.9? "\ 999.99 997.7? T77.9?
FRC ooo.ooo-oooo ,0000.0001 ooo.oo ,ooo.oo;> ooo.oo, 000.00:000.00
FRC -ooo.ooo oooo -oooo.oool ooo;oo-ooo;oo,~ooo.oo- ooo.oo " ooo.oo
FRC 999.799 9999 9799.999! 999.99 997.79: 997.99; 999.99 999.99
FRC 799.99? , 9799 : 7977.7991 979.99 999.99! 997.7? 999 99 999.99
FRC 999.7??p-99?9 - - 5.200r 799:??- ??9.?9 777;??- 979.7? ???.??
FRC 997.999 9777 0.7001, ???.?? 779.99 799.99 999.9? 97?.??
FRC 799.999 9999 2.300J 999.99 777.7? 777.7? 97?.?? 797.79
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-- EOF:
  M

-------
                    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.
                                    C-is

-------
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."
                                    C-16

-------
 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.
                                      C-17

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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.

                                   C-18

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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.
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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
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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.
                                      E-2

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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
                                    E-3

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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

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        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

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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

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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

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                        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

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               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

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               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

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                  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

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                  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

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                  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

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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

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                                   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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