EPA-450/3-83-016a
      Benzene Emissions from
Coke By-Product Recovery Plants -
      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

                   May 1984

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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, North Carolina 27711; or, for a fee, from
the National Technical Information Services, 5285 Port Royal Road, Springfield, Virginia 22161.
                                    Publication No. EPA-450/3-83-016a

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                 ENVIRONMENTAL PROTECTION AGENCY

                     Background Information
                            and Draft
                 Environmental Impact Statement
               for Coke By-Product Recovery Plants
                         Prepared by:
        Farmer                                       f
Director, Emission Standards and Engineering Division
U.S.  Environmental Protection Agency
Research Triangle Park, North Carolina  27711
                                                       '(Date)
The proposed national emission standards would limit emissions of
benzene from existing and new coke by-product recovery plants.  The
proposed standards implement Section 112 of the Clean Air Act and are
based on the Administrator's determination of June 8, 1977 (42 FR 29332)
that benzene is a hazardous air pollutant.  EPA Regions III, IV, and V
are particularly affected because most coke by-product recovery plants
are located in these regions.

Copies of this document have been sent to the following Federal Depart-
ments:  Labor, Health and Human Services, Defense, 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;
Office and Management and Budget; and other interested parties.

The comment period for review of this document is 75 days.  Mr. Gilbert H.
Wood, Standards Development Branch, telephone (919) 541-5578, may be
contacted regarding the date of the comment period

For additional information contact:

Dr. James U. Crowder
Industrial Studies Branch (MD-13)                                     |
U.S.  Environmental Protection Agency                                  :
Research Triangle Park, NC  27711
Telephone:  (919) 541-5601

Copies of this document may be obtained  from:

U.S.  EPA Library (MD-36)
Research Triangle Park, NC  27711

National Technical Information Service
5285  Port Royal Road
Springfield, VA  22161

                            iii

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                               TABLE OF CONTENTS
Tables	     xi

Figures.	     xv

1.   SUMMARY	    1-1
     1.1  CONTROL OPTIONS/REGULATORY ALTERNATIVES	    1-1
     1.2  ENVIRONMENTAL IMPACT 	    1-1
     1.3  ECONOMIC IMPACT	    1-3

2.   INTRODUCTION.	 	    2-1

3.   THE COKE OVEN GAS BY-PRODU;CT INDUSTRY	    3-1
     3.1  INDUSTRY BACKGROUND	    3-1
     3.2  PROCESS DESCRIPTIONS AND EMISSIONS .  	    3-4
          3.2.1  Process Overview	    3-4
          3.2.2  Tar Processing.	    3-10
               3,2.2.1  Tar Decanter	    3-10
               3.2.2.2  Ball Mill	    3-14
               3.2.2.3  Flushing-Liquor Circulation Tanks.  ....    3-14
               3.2.2.4  Tar Dewatering	    3-15
               3.2.2.5  Tar Refining	    3-16
               3.2.2.6  Pitch Prilling 	    3-16
               3.2.2.7  Tar and Tar Product Storage	    3-18
          3.2.3  Ammonia Wastewater Processing 	    3-19
               3.2.3.1  Ammonia Liquor Treatment 	    3-20
          3.2.4  Tar Acid (Phenol) Processing	    3-20
          3.2.5  Final Cooler and Naphthalene Recovery  	    3-22
               3.2.5.1  Direct-Water Final Cooler—Physical
                        Separation of Naphthalene	    3-2~5
               3.2.5.2  Tar-Bottom Final Cooler—Naphthalene
                        Recovery in Tar	    3-25
               3.2.5.3  Wash-Oil  Final Cooler—Naphthalene
                        Recovery in Wash Oil	    3-29
               3.2.5.4  Naphthalene Processing 	 ...    3-31
               3.2.5.5  Emissions from the Final Cooler and
                        Naphthalene Processing Units .   . .  . .  .   .    3-32
          3.2.6  Light-Oil Processing	    3-34
               3.2.6.1  Light-Oil Recovery 	    3-35
               3.2.6.2  Light-Oil Refining 	    3-38
          3.2.7  Wastewater Processing	    3-39
          3.2.8  Fugitive Emissions from Leaking Equipment
                 Components.	    3-41
          3.2.9  Summary of Emissions	    3-44

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                           TABLE OF CONTENTS (con.)
                                                                      Page
     3.3  BASELINE REGULATIONS 	     3-44
          3.3.1  Baseline Regulatory Requirements	     3-47
     3.4  REFERENCES	     3-48

4.   EMISSION CONTROL TECHNOLOGY 	     4-1
     4.1  GAS BLANKETING FROM THE COLLECTING MAIN	     4-4
          4.1.1  Applicable Sources.	     4-4
          4.1.2  Description of Technology 	     4-4
          4.1.3  Demonstration of Gas Blanketing from the
                 Collection Main	     4-iO
          4.1.4  Control Efficiency	     4-11
     4.2  GAS BLANKETING WITH CLEAN COKE OVEN GAS	     4-12
          4.2.1  Applicable Sources	     4-12
          4.2.2  Description of Technology	     4-12
          4.2.3  Demonstration of Gas Blanketing with Clean
                 Coke Oven Gas	     4-15
          4.2.4  Control Efficiency	     4-17
     4.3  NITROGEN OR NATURAL GAS BLANKETING	     4-18
          4.3.1  Applicable Sources	     4-18
          4.3.2  Description of Technology 	     4-18
     4.4  WASH-OIL SCRUBBERS 	     4-21
          4.4.1  Applicable Sources	     4-21
          4.4.2  Description of Technology 	     4-21
          4.4.3  Control Efficiency	     4-24
     4.5  ENCLOSURE	     4-29
     4.6  CONTROL OF COOLING TOWER AND NAPHTHALENE-HANDLING
          EMISSIONS	     4-29
          4.6.1  Tar-bottom Final Cooler 	     4-30
          4.6.2  Wash-Oil Final Cooler 	     4-31
     4.7  ALTERNATIVE CONTROL TECHNIQUES 	     4-33
          4.7.1  Venting to the Suction Main	     4-33
          4.7.2  Vapor Condensation	     4-37
          4.7.3  Adsorption	     4-39
          4.7.4  Absorption	     4-42
          4.7.5  Vapor Destruction 	     4-45
          4.7.6  Vapor Balance Systems 	     4-46
     4.8  CONTROLS FOR FUGITIVE EMISSIONS FROM EQUIPMENT
          COMPONENTS	     4-47
          4.8.1  Leak Detection and Repair Methods	     4-47
                 4.8.1.1  Leak Detection Techniques	     4-47
                          4.8.1.1.1  Individual  component survey  .     4-48
                          4.8.1.1.2  Unit area survey	     4-48
                          4.8.1.1.3  Fixed-point monitors	     4-49
                          4.8.1.1.4  Visual  inspections	     4-50
                 4.8.1.2  Repair Techniques	     4-50
                          4.8.1.2.1  Pumps 	     4-50
                          4.8.1.2.2  Valves	     4-50
                                    VI

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                      TABLE  OF  CONTENTS  (con.)
                                                    of
                     4.8.1.3.2
                     4.8.1.3.3
                     4.8.1.3.4
                     4.8.1.3.5
                4.8.1.2.3,  Flanges 	
                4.8.1.2.4  Relief valves .  .
                4.8.1.2.5  Exhausters.  .  .  .
       4.8.1.3  Emission Control  Effectiveness
                Leak Detection and Repair	
                4.8.1.3.1  Definition of a leak.  .  .
                           Inspection interval .  .  .
                           Allowable repair time  .  .
                           Estimation of reduction
                           of efficiency for valves
                           and pumps 	
                           Estimation of reduction
                           efficiency for safety
                           relief devices and
                           exhausters	
4.9
4.8.2  Preventive Programs
       4.8.2.1  Pumps.  .  .
                4.8.2.1.1
                4.8.2.1.2
       4.8.2.2  Exhausters
       4.8.2.3  Valves ........
       4.8.2.4  Safety/Relief Valves .
       4.8.2.5  Open-Ended Lines .  . .
       4.8.2.6  Closed-Purge Sampling.
REFERENCES	.  . .
                                Dual  mechanical  seals
                                Seal less pumps.  .  .  .
MODIFICATIONS
5.1
5.2
5.3
5.4
BACKGROUND 	
PROCESS MODIFICATIONS  .
5.2.1  Tar Dewatering
5.2.2  Tar Storage .  .  .
EQUIPMENT MODIFICATIONS
REFERENCES 	
MODEL PLANTS AND CONTROL OPTIONS.
6.1  MODEL PLANTS OVERVIEW.  .
     6.1.1  Selection of:Model
     6.1.2  Selection of Model
6.2  CONTROL OPTIONS OVERVIEW ....
     6.2.1  Final-Cooler Cooling Tower
     6.2.2  Gas Blanketing System .  .
     6.2.3  Wash-Oil Scrubber ....
     6.2.4  Light-Oil Sump.  	
     6.2.5  Pumps 	
     6.2.6  Valves.  .........
                          Plant Size .  .
                          Plant Emission
Sources
                   Page

                   4-52
                   4-52
                   4-54

                   4-55
                   4-55
                   4-56
                   4-56
                                                                 4-57
4-57
4-60
4-60
4-60
4-62
4-63
4-63
4-64
4-65
4-65
4-66

5-1
5-1
5-1
5-2
5-2
5-2
5-2

6-1
6-1
6-2
6-2
6-14
6-14
6-14
6-16
6-17
6-17
6-18
                               VI 1

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                      TABLE OF CONTENTS (con.)
     6.2.7  Exhausters	
     6.2.8  Pressure-Relief Devices 	
     6.2.9  Sampling Connection Systems and Open-Ended
            Lines 	
ENVIRONMENTAL IMPACT.
7.1  BENZENE AIR POLLUTION IMPACT 	
     7.1.1  Emission Source Characterization	
     7.1.2  Development of Benzene Emission Levels	
     7.1.3  Impact on Benzene Emissions from New Sources.  .
7.2  IMPACT OF THE CONTROL OPTIONS ON VOLATILE ORGANIC
     COMPOUND (VOC) EMISSIONS 	
7.3  WATER POLLUTION IMPACT 	  .
7.4  SOLID WASTE DISPOSAL IMPACT	
7.5  ENERGY IMPACT	
7.6  OTHER ENVIRONMENTAL IMPACTS	
7.7  IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES
7.8  IMPACT OF DELAYED STANDARDS	
7.9  REFERENCES 	
            8.1.1.2
8.   COSTS 	
     8.1  COST ANALYSIS OF REGULATORY ALTERNATIVES 	
          8.1.1  Existing Facilities 	
                 8.1.1.1  Rationale	
                          Tar Decanter, Tar-Intercepting Sump,
                          and Flushing-Liquor Circulation Tank
                          Excess Ammonia Liquor Tanks	
                          Light-Oil Plant	
                          Light-Oil and BTX Storage Tanks.  .  .
                          Tar-Collecting, Tar Storage,  and
                          Tar-Dewatering Tanks 	
                          Light-Oil Sump 	
                          Pure Benzene Storage Tanks 	
                          Final  Cooler	
                          Wash-Oil Final Cooler	
            8.
            8.
            8.
            8.
         1.1.3
         1.1.4
         1.1.5
         1.1.6
            8.
            8.
            8.
            8.
            8.
         1.1,
         1.1.
7
8
9
10
       1.2
       1.3
       1.4
                 New
                   1.1.11 Fugitive Emissions from Equipment
                          Components 	
8.2
8.3
           Facilities.
       Modified Sources	
       Summary of Estimated Control Costs.  ...
       Comparison of Actual and Estimated Capital
       Costs	  .
OTHER COST CONSIDERATIONS	
REFERENCES 	
     8.1.5
Page

6-18
6-18

6-19

7-1
7-1
7-1
7-1
7-3

7-3
7-7
7-7
7-7
7-10
7-10
7-10
7-10

8-1
8-1
8-2
8-2

8-4
8-11
8-11
8-14

8-16
8-23
8-23
8-27
8-30

8-30
8-33
8-36
8-36

8-43
8-44
8-45

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                           TABLE OF CONTENTS (con.)
9.    ECONOMIC IMPACT
     9.1
     9.2
INDUST
9.1.1
9.1.2
9.1.3
9.1.4
9.1.5
9.1.6
9.1.7
ECONOM
9.2.1
9.2.2
RY PROFILE 	
Introduction 	
9.1.1.1 Definition of the Coke Industry 	
9.1.1.2 Brief History of the Coke Industry in
the Overall Economy 	
9.1.1.3 Size of the Iron and Steel Industry. . .
Production 	
9.1.2.1 Product Description 	
9,1.2.2 Production Technology 	
9.1.2.3 Factors of Production 	
Demand and Supply Conditions 	
Market Structure 	
9.1.4.1 Concentration Characteristics and
Number of Firms 	
9.1.4.2 Integration Characteristics. . 	
9.1.4.3 Substitutes. . . 	
9.1.4.4 Pricing History 	 	 . .
9.1.4.5 Market Structure Summary 	 . . .
Financial Performance 	 	
Projections 	
Market Behavior: Conclusions 	
1C IMPACT OF REGULATORY ALTERNATIVES 	
Summary 	
Methodology 	
9.2.2.1 Supply Side 	 	
9.2.2.1.1 Data base 	
9.2.2.1.2 Output relationships . . . .
9.2.2.1.3 Operating costs 	
9.2.2.1.4 Capital costs 	
9.2.2.1.5 Environmental costs 	
9.2.2.1.6 Coke supply function —
                                      existing facilities.  .
                           9.2.2.1.7  Coke supply function--
                                      new facilities ....
                 9.2.2.2  Demand Side	
                 9.2.2.3  Synthesis	
                 9.2.2.4  Economic Impact Variables	
          9.2.3  Furnace Coke Impacts	
                 9.2.3.1  Price Effects	
                 9.2.3.2  Production and Consumption Effects
                 9.2.3.3  Coal Consumption and Employment
                          Effects	
                 9.2.3.4  Financial Effects	
                 9.2.3.5  Battery and Plant Closures ....
          9.2.4  Foundry Coke Impacts	
                 9.2.4.1  Price and Production Effects .  .  .
9-18
9-27
9-27
9-28
9-30
9-30
9-34
9-39
9-40
9-40
9-41
9-43
9-43
9-44
9-44
9-46
9-48

9-49

9-52
9-55
9-57
9-57
9-61
9-64
9-66

9-66
9-68
9-77
9-79
9-79

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                                       TABLE OF CONTENTS (con.)
                               9.2.4.2  Coal  Consumption and Employment
                                        Effects	     9-83
                               9.2.4.3  Financial  Effects	     9-83-
                               9.2.4.4  Battery and Plant Closures  	     9-87
                   9.3  POTENTIAL SOCIOECONOMIC AND INFLATIONARY IMPACTS ....     9-91
                        9.3.1  Compliance Costs	     9-91
                        9.3.2  Prices and Consumer Costs	     9-93
                        9.3.3  Balance of Trade	     9-93
                        9.3.4  Community Impacts 	     9-95
                        9.3.5  Small  Business Impacts	     9-95
                        9.3.6  Energy	     9-98
                   9.4  REFERENCES	     9-98

              APPENDIX A  EVOLUTION OF THE PROPOSED STANDARDS	     A-l
              APPENDIX B  INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS 	     B-l
              APPENDIX C  EMISSION MEASUREMENTS AND ESTIMATES	     C-l
              APPENDIX D  EMISSION MEASUREMENTS AND CONTINUOUS MONITORING.  ...     D-l
              APPENDIX E  METHODOLOGY FOR ESTIMATING LEUKEMIA INCIDENCE
                          AND MAXIMUM LIFETIME RISK FROM EXPOSURE TO
                          BENZENE EMISSIONS FROM COKE OVEN BY-PRODUCT
                          RECOVERY PLANTS	     E-l '
              APPENDIX F  SUPPLEMENTAL INFORMATION FOR THE COST ANALYSIS ....     F-l
_

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                                    TABLES
Number

1-1       Assessment of Environmental and Economic
          Impacts for Each Regulatory Alternative
          Considered	

3-1       Production and Consumption History of Coke
          Plants in the United States	
3-2       Coke and Coal Chemicals Produced by United
          States Coke Oven Plants in 1976	
3-3       Processes in the By-Product Recovery Plants .  .  .
3-4       Fate of Coke Oven By-Products 	
3-5       A Comparison of Emissions from Leaks from By-
          Product Plants to Those from Petroleum Refineries
3-6       Benzene Emission Factors Derived from VOC
          Emission Factors. •.	
3-7       Uncontrolled Benzene Emission Factors for
          Coke By-Product Plants. . .	
3-8       States Requiring Vapor Controls on Storage Tanks
          and Separators	
3-9       California Regulations for Coke Oven By-Product
          Plants	

4-1       Emission Sources and Control Techniques 	
4-2       Partition Factors for Benzene and Xylene in
          Wash Oil. 	
4-3       Percent Control of Benzene in a Wash-Oil Spray
          Chamber 	 	
4-4       Hierarchy of Equipment Types Based on Emissions
          Rate	
4-5       Percent Emission Reduction of Leak Detection
          and Repair Program for Valves and Pumps 	
4-6       Percent Emission Reduction of Leak Detection and
          Repair Program for Safety Relief Valves and
          Exhausters	

6-1       Coke By-Product Recovery Plant Processes	
6-2       Emission Sources for Coke By-Product Recovery
          Model Plants	
6-3       Number of Process Units at Coke By-Product
          Recovery Model Plants 	 	
6-4       Number of Equipment Components at Coke By-Product
          Recovery Model Plants 	
6-5       Coke By-Product Plant Benzene Emissions
          Sources and Control  Options . . .  ,	
1-2


3-3

3-5
3-6
3-9

3-43

3-43

3-45

3-46

3-46

4-5

4-26

4-26

4-49

4-58


4-58

6-5

6-9

6-10

6-13

6-15

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                                TABLES  (con.)

 Number                                                                Page

 7-1        Estimated  National  Baseline  Benzene  Emissions
           from Coke  Oven  By-Product  Recovery Plants.  .	    7-2
 7-2        The Effect of Control Options  on  Reducing
           Benzene  Emissions at  Coke  Oven By-Product  Plants  ....    7-4
 7-3        Relative Concentrations of Organics  Other  than
           Benzene-to-Benzene  Concentrations	    7-5
 7-4        The Effect of Benzene Control  Options on Reducing
           VOC Emissions Oven  By-Product  Plants 	    7-6
 7-5        Energy Use at a Model By-Product  Plant	  .    7-9
 7-6        Emissions  of Coke Oven Gas From Selected Coke
           Oven By-Product Plant Sources	    7-9
                                                '»
 8-1        Number of  Units at  the Model Plants	    8-3
 8-2        Capital  Cost Items	    8-5
 8-3        Annual ized Cost Items	    8-7
 8-4        Costs for  Gas Blanketing of Tar Decanter,
           Tar-Intercepting Sump, and Flushing-Liquor
           Circulating Tank	    8-10
 8-5        Costs for  Gas Blanketing Ammonia  Liquor Storage
           Tanks	    8-12
 8-6        Costs for  Wash-Oil  Vent Scrubber  for Ammonia
           Liquor Storage Tanks  	    8-13
 8-7        Costs for  Gas Blanketing of Light-Oil Condenser,
           Light-Oil  Decanter, Wash-Oil Decanter, and
           Circulation Tank	'. .  .  .    8-15
 8-8        Costs for  Gas Blanketing of Light-Oil and BTX
           Storage Tanks	    8-17
 8-9        Costs of Wash-Oil Vent Scrubber for  Light-Oil
           and BTX Storage Tanks	    8-18
 8-10       Costs for  Gas Blanketing of Tar Collecting,
           Storage, and Dewatering Tanks	    8-19
 8-11       Capital Cost Estimate for a Wash-Oil  Condenser
           and Scrubber for Tar Storage and Dewatering-Model
           Plant 2	    8-22
 8-12       Annualized Cost Estimates for  a Wash-Oil Condenser
           and Scrubber for Tar Storage and Dewatering	    8-24
8-13       Costs for  Covering  Light-Oil Sump.	    8-25
8-14       Costs for  Nitrogen  or Natural Gas Blanketing of
           Pure Benzene Storage Tanks 	    8-26
8-15       Costs of Wash-Oil Vent Scrubber for Benzene
          Storage Tanks	    8-28
8-16      Costs for  Installing a Tar-Bottom Final  Cooler 	    8-29
8-17      Costs of Installing a Wash-Oil  Final  Cooler	    8-31
8-18      Model  Plants for Fugitive Benzene Emissions
          from Equipment Components.	    8-32
                                   xn

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                               TABLES (con.)

Number                                                                Page

8-19      Capital Costs for Control of Equipment Leaks .......    8-34
8-20      Annualized Costs for Control of Fugitive Emissions
          from Equipment Components	    8-35
8-21      Estimated Distribution of Types of Coke Plant
          Emission Sources 	    8-37
8-22      Emission Reductions, Costs, and Cost Effectiveness
          for Model Plant 1	    8-38
8-23      Emission Reductions, Costs, and Cost Effectiveness
          for Model Plant 2.  .	    8-39
8-24      Emission Reductions, Costs, and Cost Effectiveness
          for Model Plant 3	    8-40
8-25      Nationwide Emission Reductions, Costs, and Cost
          Effectiveness	    8-42

9-1       Coke Industry Foreign Trade 	     9-4
9-2       Coke Production in the World	     9-5
9-3       Value of Shipments, SIC 3312.	     9-6
9-4       Value Added, SIC 3312	     9-8
9-5       Potential Maximum Annual Capacity of Oven Coke
          Plants in the United States on July 31, 1979	     9-11
9-6       Typical Cost Breakdowns:  Furnace Coke Production
          and Hot Metal (Blast Furnace) Production	     9-12
9-7       Employment in the By-Product Coke Industry	     9-13
9-8       Coke Rate	     9-17
9-9       Coke Plants in the United States, January 1980. ....     9-19
9-10      Interregional Coke Shipments in 1977.	     9-25
9-11      Percent of Coke Capacity Owned by Top Firms
          (January 1980)	 .     9-26
9-12      Comparison of Coal  Prices and Domestic and
          Imported Coke Prices	     9-29
9-13      Financial Information on Coke-Producing Firms, 1978 . ..     9-31
9-14      Financial Ratios for Coke-Producing Firms 	     9-33
9-15      Summary of the Projections from the Linear Model.  .  . .     9-36
9-16      Summary of Steel Industry Projections 	     9-37
9-17      Projections of Coke Capacity Requirements—1985,
          1990, and 1995	     9-38
9-18      Estimated Capital Costs of New Batteries	     9-47
9-19   •   Estimates of Elasticities of Steel and Coke
          Markets	     9-56
9-20      Economic Impact Variables and Affected Sectors	     9-59
9-21      1983 Baseline Values for Economic Impact
          Analysis—Furnace Coke	     9-62
9-22      Baseline Control Costs—Furnace Coke	     9-63
9-23      Price Effects of Regulatory Alternatives--
          Furnace Coke, 1983	     9-65
9-24      Production and Consumption Effects of Regulatory
          Alternatives—Furnace Coke, 1983.	  ...     9-67
                                   xn

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                               TABLES (con.)

Number

9-25      Coal Consumption and Employment Effects of
          Regulatory Alternatives—Furnace Coke, 1983 	     9-69
9-26      Industry Capital Requirements of Regulatory
          Alternatives—Furnace Coke, 1983	     9-70
9-27      The Ratio of Incremental Capital Costs to Net
          Income—Furnace Coke Producers, 1983	     9-72
9-28      The Ratio of Cumulative Capital Costs to Net
          Income—Furnace Coke Producers, 1983	     9-73
9-29      The Ratio of Incremental Capital Costs to
          Net Investment—Furnace Coke Producers, 1983	     9-75
9-30      The Ratio of Cumulative Capital Costs to Net
          Investment—Furnace Coke Producers, 1983	     9-76
9-31      1983 Baseline Values for Economic Impact
          Analysis—Foundry Coke	     9-80
9-32      Baseline Control Costs—Foundry Coke	'  9-81
9-33      Price and Quantity Effects of Regulatory
          Alternatives, 1983	     9-82
9-34      Coal Consumption and Employment Effects of
          Regulatory Alternatives—Foundry Coke, 1983 	     9-84
9-35      Industry Capital Requirements of Regulatory
          Alternatives—Foundry Coke, 1983	     9-85
9-36      The Ratio of Incremental Capital Costs to Net
          Income—Foundry Coke Producers, 1983	     9-86
9-37      The Ratio of Cumulative Capital Costs to Net
          Income—Foundry Coke Producers, 1983	     9-88
9-38      The Ratio of Incremental Capital Costs to Net
          Investment—Foundry Coke Producers, 1983	     9-89
9-39      The Ratio of Cumulative Capital Costs to
          Net Investment—Foundry Coke Producers, 1983	     9-90
9-40      Compliance Costs of Regulatory Alternatives
          Under Scenario A, 1983	     9-92
9-41      Coke, Steel, Ferrous Foundry,  and Consumer
          Products Price Effects of Regulatory Alternatives
          Under Scenario A, 1983	     9-94
9-42      Employment Data for U.S. Firms Operating
          Coke Ovens	     9-97
                                    xiv

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                                    FIGURES
Number
                                                                      Page
  3-1     Flow plan and material  balance of a representative coke
          by-product recovery plant	3-8
  3-2     Tar separation flow diagram	3-11
  3-3     Tar refining flow diagram	3-17
  3-4     Ammonia stills	3-21
  3-5     Solvent extraction and steam-stripping dephenolization
          processes	3-23
  3-6     Direct-water final cooler—physical separation of
          naphthalene	   3-26
  3-7     Tar-bottom final  cooler—naphthalene recovery in tar .  .  .   3-27
  3-8     Wash-oil  final cooler recovery system.  .  .    	   3-30
  3-9     Wash-oil  absorption of light oil  with light-oil
          rectification	   3-36

  4-1     Vapor flow for a gas blanketing control  system	4-2
  4-2     Gas blanketing of•tar decanters and flushing-liquor
          tank from the collecting main.  .  .	4-7
  4-3     Seal and vent arrangement for tar decanter	4-9
  4-4     Gas blanketing of a light-oil recovery system	4-14
  4-5     Schematic of a nitrogen or natural  gas blanketing
          system	4-19
  4-6     Wash-oil  scrubber for vents on tar storage,  ammonia
          liquor storage,  and sump	4-23
  4-7     Mixer settler	4-32
  4-8     Conversion of a final cooler from water to wash  oil
          cooling medium 	   4-34
  4-9     Negative-pressure system from tar-collecting tanks
          to suction main	4-36
  4-10    Surface condenser unit  used on a  tank handling warm
          volatile, organic materials	4-38
  4-11    Refrigeration vapor recovery unit	4-38
  4-12    Sketch of a vertical adsorber with two cones	4-41
  4-13    Cross-section of an adsorber with four beds  of
          adsorbed carbon	4-41
  4-14    Sketch of a two-unit, fixed-bed adsorber 	   4-41
  4-15    Packed tower	4-43
  4-16    Schematic diagram of a  bubble cap tray tower	4-43
  4-17    Venturi absorber with cyclone-type  liquid separator.  .  .  .   4-44

  6-1     Distribution of plant size as a function of  coke
          capacity .  .	6-3
  6-2     Coke oven by-product recovery,  Model  Plant 1	6-6
  6-3     Coke oven by-product recovery,  Model  Plant 2 .......   6-7
                                    xv

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                                FIGURES (con.)
Number
Page
  6-4     Coke oven by-product recovery, Model Plant 3	6-8

  8-1     Tar decanter	   8-9
  8-2     Conceptual design of a wash-oil scrubber for tar
          dewatering and tar storage at Model Plant 2	8-21

  9-1     Uses of oven coke as percents of total  coke
          consumption	9-9
  9-2     U.S. apparent consumption of coke	9-15
  9-3     Coke plants in the United States, 1980	9-23
  9-4     Economic impact model	9-42
  9-5     Coke plant cost centers	   9-45
  9-6     Estimated average cost of furnace coke  production
          as a function of plant production,  1980	9-50
  9-7     Estimated average cost of foundry coke  production
          as a function of plant production,  1980	9-51
  9-8     Marginal and average cost functions for furnace
          coke, 1980 .  .	9-53
  9-9     Marginal and average cost functions for foundry
          coke, 1980	   9-54
  9-10    Coke supply and demand	   9-58
  9-11    Coke demand and supply with and without regulatory
          alternatives 	   9-60
                                    xvi

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                              1.   SUMMARY

1.1  CONTROL OPTIONS/REGULATORY ALTERNATIVES
     Regulatory alternatives representing selected combinations of
control options were used to determine the economic impact of differing
control strategies.
     Regulatory Alternative I represents baseline control with no
national emission standard.  Regulatory Alternative II represents the
tar-bottom final-cooler control option; the gas blanketing control
option for tar decanters, tar-intercepting sump, flushing-liquor
circulation tank, tar storage tank, excess-ammonia liquor storage
tank,  light-oil decanter, light-oil condenser, wash-oil decanter, and
the wash-oil circulation tank; a wash-oil scrubber for light-oil or
benzene storage; a sealed cover for the light-oil sump; monthly monitor-
ing for pumps and valves; quarterly monitoring for exhausters; and
equipment controls for pressure relief devices, sampling connections,
and open-ended lines.  Regulatory Alternative III was chosen as a more
stringent combination of controls that would yield a greater emission
reduction.  The control options chosen for analysis as Regulatory
Alternative III would include the use of a wash-oil final cooler
system, and the gas  blanketing of light-oil and benzene  storage tanks,
in addition to the controls applied to other sources under Regulatory
Alternative II.
1.2   ENVIRONMENTAL IMPACT
      Table 1-1 summarizes  the environmental impacts of the regulatory
alternatives.  At  regulatory baseline  (Regulatory Alternative  I), the
nationwide benzene emissions are estimated at 29,000 Mg/yr.  The
                                   1-1

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           TABLE 1-1.  ASSESSMENT OF ENVIRONMENTAL AND ECONOMIC
            IMPACTS FOR EACH REGULATORY ALTERNATIVE CONSIDERED

Air
impact

Water
impact
Solid
waste
impact

Energy
impact

Noise
impact

Economic
impact
Regulatory
Alternative I

Regulatory
Alternative II

Regulatory
Alternative III
+3
+4
-1
                   +3
+4
                   +1
-4
 Long-term impact.

KEY:  + = Beneficial impact
      - = Adverse impact
      0 = No impact
      1 = Negligible impact
      2 = Small impact
      3 = Moderate impact
      4 = Large impact
                                  1-2

-------
combination of control options under Regulatory Alternative II would
reduce benzene emissions to about 3,500 Mg/yr.  The control options
for Regulatory Alternative III will reduce benzene emissions to about
700 Mg/yr.
     The only alternative that may affect water pollution is Regula-
tory Alternative III.  This alternative by requiring use of indirect
cooling (wash-oil final cooler) would tend to increase the cyanide
load in wastewater treated before discharge.  However, this impact is
expected to be negligible.
     Both Regulatory Alternatives II and III would have a beneficial
energy impact resulting from recovered coke oven gas emissions via the
gas blanketing control options.
1.3  ECONOMIC IMPACT
     The derivation of costs and economic impacts was based on a
pi ant-by-plant cost analysis at 1980 coke production capacities.
There is no annualized and capital cost for benzene emission controls
associated with reaching the regulatory baseline; i.e., Regulatory
Alternative I.
     A net credit in total annualized cost to the industry would
result with the implementation of Regulatory Alternative II due to
anticipated fuel savings and increased product.  Regulatory Alterna-
tive II may require a nationwide capital investment of about $31.5
million in 1982 dollars above the regulatory baseline, including the
cost of monitoring instrumentation.  Regulatory Alternative III may
require a nationwide capital investment of about $170 million in
addition to Regulatory Alternative II and a total annualized cost of
about $48 million/yr above the costs of Regulatory Alternative II.
 [NOTE:  Since this document was written, 13 plants have permanently
 closed and capacities  have changed  for  some of the other plants.
 Therefore, the estimated  impacts  summarized in this chapter would
 change accordingly.]
                                  1-3

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                           2.  INTRODUCTION

     EPA announced a decision to list benzene as a hazardous air
pollutant under Section 112 of the Clean Air Act on June 8, 1977
(42 FR 29332).   As a result, standards controlling benzene emissions
are under development.   The standard-setting process involves identi-
fying benzene emission sources and options for controlling them.  The
approach in determining the levels for recommended standards is to
select as the minimum control level best available technology (BAT),
considering costs, nonair quality health, environmental impacts, and
energy requirements of the control options.  Then the additional
reductions in health risks and the cost, economic, environmental, and
energy impacts that would result from requiring controls more stringent
than BAT are examined to determine whether more control would be
necessary to eliminate unreasonable residual risks.  This document
provides the background information necessary for this evaluation of
benzene emissions from coke by-product recovery plants.
                                 2-1

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                   3.   THE COKE OVEN GAS BY-PRODUCT INDUSTRY

3.1  INDUSTRY BACKGROUND
     Coke is the primary residue that remains when a blend of pulverized
coking coals is heated gradually to high temperatures in the absence of air
(900° to 1,000° C) for 10 to 40 hours.   This process, called destructive
thermal distillation,  produces a spectrum of chemicals, including hydrogen,
methane, benzene, cyanides, and polynuclear aromatic hydrocarbons (PAH's).
The coke oven by-product plant recovers these chemicals.  Coke is one of
the basic materials used in blast furnaces to convert iron ore into iron,
and about 90 percent of the coke produced in the United States is used for
this purpose.  Most of the iron is subsequently processed into steel, and
an adequate supply of coke is necessary to ensure a continuing steel supply.
Coke is also used by a number of other industries, principally iron foun-
dries, nonferrous smelters, and chemical plants.
     Blast furnace coke results when coal is coked for approximately 18
hours, and foundry coke, which is less common and of higher quality, results
when coal is coked for approximately 30 hours.  Coke is produced in the
United States by two methods:  the original method, termed the beehive
process, and the contemporary method, called the by-product recovery or
slot oven process.  Approximately 99 percent of the coke produced in the
United States is made by the slot oven process.  This conversion of coal to
coke is performed in long, narrow slot ovens that are designed and operated
to permit separation and recovery of the volatile materials (the by-produets)
evolved from the coal during the coking process.  In 1975, it was estimated
that the 62  slot oven plants operating consisted of 231 batteries containing
13,324 ovens.1  This number decreased to 60 by-product  recovery  (slot oven)
coke plants  operating in the United States during 19782 but increased to 64
in 1979.3
                                  3-1

-------
     The  coke  industry  has  two  sectors,  and plants  are  classified generally
as furnace or  merchant  plants.   In  1979, 45 furnace plants  supplied over 90
percent of the total  slot oven  production, and they were owned by or affil-
iated with iron- and  steel-producing  companies.  Consequently, firms in
this sector produce coke primarily  for consumption  in their own blast
furnaces, although they engage  in some intercompany sales among steel firms
with excesses  or deficits in coke capacity.
     Independent plants that produce  coke for sale  on the open market are
typically owned by chemical or  coal firms and are referred  to as merchant
coke producers.  However, the 19 merchant plants operating  in 1979 accounted
for less than  9.3 percent of the total coke produced.   The  19 merchant
plants in operation sell most of their products to  other firms engaged in
blast furnace, foundry, and nonferrous smelting operations.  Chemical
companies have entered  the coke industry to obtain  the  by-product hydrocar-
bon gases that are released when coal is converted  into coke, and coal
firms have entered the  coke industry  as a form of downstream vertical
integration.
     In 1979,  48.0 million metric tons (or teragrams, Tg) of coke were
produced in slot ovens'in the United  States.3  This  rate is less than the
1977 production of 48.5 Tg and  is 8 percent less than the 1976 production
of 52.3 Tg.4   Also in 1979, the most  recent year for which  complete data
are available, 90.7 percent of this total (43.5 Tg) was produced at furnace
plants.   In 1976, the production of coke from the beehive process accounted
for only 0.5 Tg or approximately 1 percent of total coke production during
that year,5 and the same oven continued production  in 1979,6  A production
and consumption history of coke in the United States since  1970 is presented
in Table 3-1.
     Although  coke was produced in 19 States in 1979, 58 percent of this
coke was produced in three eastern States:   Pennsylvania,  Ohio, and Indiana.7
Pennsylvania,  with 13.0 Tg of output, was the leading coke-producing State
and accounted  for 27 percent of U.S. coke oven production.   Ohio and Indiana
each produced 7.5 Tg of coke.   The relative amounts of coke produced in the
various  States have changed very little in the past decade.   The geographical
distribution  of coke oven facilities reflects  the locations of coal  deposits
and steelmaking facilities.
                                  3-2

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     The  separation  and  recovery  of the by-products evolved during the
 coking process are either  used within the facility or marketed.  Typical
 products  and by-products that resulted from the 1979 production of United
 States slot oven coke are  presented in Table 3-2.8
 3.2  PROCESS DESCRIPTIONS  AND EMISSIONS
     The  coke, by-product recovery industry uses different technologies to
 recover the volatiles emitted during the coking process.  The current
 domestic  application of these technologies is summarized in Table 3-3.
 3.2.1  Process Overview
     Coke by-product recovery consists of the separation and recovery of
 various components from the coke  oven gas.  These components include coal
 tar, pitch, ammonium sulfate, naphthalene, and light oil.
     A simplified flow plan and material balance of a representative by-
 product plant is given in  Figure  3-1.   This figure is not intended to
 indicate  the composition of each  stream in a by-product plant but to present
 an overview of the types of materials present in various sections of the
 by-product plant.  The material balance is based on a plant that produces
 5,000 Mg  of coke per day.  The diagram outlines the process steps; more
 detailed  process information is included in later subsections.   Table 3-4
 summarizes the fate of the major  coke oven by-products from this represen-
 tative plant.
     The  gases leave the coke ovens at approximately 700° C.   Coke ovens
 are maintained at a slightly positive pressure (1 mm water) to prevent air
 infiltration.   Immediately after  the gas leaves the oven, it is subjected
 to a cooling spray to reduce the  temperature of the gas and introduce a
 collecting medium for the condensed tar.   After a short duct run,  the gas,
which remains above atmospheric pressure,  passes through an askania valve
 and enters the suction main.   At  this  point,  the gas has been cooled to
 approximately 100° C and much of  the water,  tar, ammonia, and other com-
pounds has been condensed.
     Further condensation occurs  in the primary cooler.   The tar is separated
from the water in a tar decanter.   The water layer is  commonly known as the
ammonia liquor or flushing liquor.  If phenol  is recovered from the ammonia
liquor,  it is  often absorbed in an organic solvent before the ammonia

                                  3-4

-------
   TABLE 3-2.   COKE AND COAL CHEMICALS PRODUCED BY UNITED STATES
                     COKE OVEN PLANTS IN 1976
Product
Total production
   Yield  (Mg
of coal charged)
Coke
Breeze
Crude tar
Crude light oil
Ammonia (sulfate
equivalent)
Coke oven gas
48.0 Tg
3.35 Tg
2.239 million H
663.3 million &
0.426 Tg

23.62 billion m3
0.6843 net Mg
0.0477 net Mg
32.2 £
10.4 £
7.81 kg

339.6 m3
                             3-5

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                 TABLE 3-4.   FATE OF COKE OVEN BY-PRODUCTS
Component
           Route
H2, CH4, light hydrocarbons,
N2, 02, CO, and C02
Ammonia
Water

H2S, HCN

Benzene, toluene, xylene (BTX)

HC1


Tar bases (such as CsH5N)

Tar acids (such as phenol)

Naphthalenes

Heavy organics (boiling point >200° C)
Remain in gas; used as fuel gas.


Via gas to ammonia scrubber or
via liquor to ammonia still;
then back to gas and to the.
ammonia scrubber.   Most ammonia
converted to ammonium sulfate.
Via liquor to ammonia still; re-
mains as waste ammonia liquor.

Via gas or liquor to free ammonia
still and into gas to desulfurizer.
Via gas to light-oil scrubbers.

Via liquor to waste ammonia
liquor as CaCl2 (lime still).
Condensed into tar or via gas
to ammonia scrubber.

Via liquor to dephenolizer or
condensed as tar.
Condensed in tar or via gas
and condensed in final cooler.
Condensed as tar (small fraction
to light oil).
                                  3-9

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recovery step.  The liquor traditionally is steam-stripped with the addition
of a caustic to return the ammonia to the gas stream for recovery.   Ammonium
sulfate crystals that result from an acid contact procedure are separated
from the saturated liquor.
     The exhauster is a fan that provides motive power for the gas.  A
collection device removes the remaining tar from the gas, generally as a
particulate; both gas scrubbers and electrostatic precipitators are used as
collection devices in the industry.
     The final cooler is a pretreatment step for light-oil recovery.   In
the process, naphthalene is condensed from the gas and separated from the
cooling water by absorption in tar or by flotation.   Light oil is recovered
by absorption in a petroleum fraction wash oil.  The light oil is steam-
stripped from the wash oil, and the wash oil is recirculated.   Desulfuriza-
tion, which removes hydrogen sulfide from the coke oven gas, is not in
widespread use.
     The following subsections further describe the individual processes.
The reader should be aware that (1) today's by-product plants often have
evolved over 20 to 50 years of maintenance, design,  and operational changes;
(2) the technology is mature, providing many options for coal  chemical
recovery; and (3) the market for coal chemicals is uncertain,  and economic
pressure has led to operational changes at the plants.  This situation
results in a substantial plant-to-plant process variability.
3.2.2  Tar Processing
     3.2.2.1  Tar Decanter.  Figure 3-2 outlines the tar separation opera-
tions.  Tar condensation initially occurs by direct contact with flushing
liquor in the collecting and suction mains.  The gas mains are sprayed and
Vigorously flushed with recycled liquor to quench the gas and to avoid
buildup of tar deposits.  Approximately 80 percent of the tar is separated
from the gas in the mains and is flushed to a tar decanter.  Twenty percent
of the tar is condensed and collected in a primary cooler along with a
significant amount of water.  Tar continues to be removed in the exhauster,
which provides motive power for the gas, and a collector (often an electro-
static precipitator or gas scrubber) removes most of the residual, entrained
tar particulate.
     In a tar decanter, the tar is separated from the flushing liquor by
gravity.  Typical residence times are about 10 minutes for liquor and
                                   3-10

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40 hours for tar.  The degree of separation achieved is highly variable
because of coal type and operating differences between plants.  Liquor from
the decanters is recycled to the gas mains.
     Tar decanters are often elongated, multicompartment, rectangular tanks
that collect tar on the bottom of the tank and remove flushing liquor at
the top.  In addition to these two primary streams, sludge accumulates and
may be collected by a drag conveyor from the bottom of the decanter.  The
temperature of the flushing liquor in the decanters is approximately 80° C.
Decanter coal tar generally is stored in vented cylindrical tanks maintained
at 70° to 90° C.  Decanted flushing liquor also is stored in tanks that are
vented to the atmosphere.
     Multiple decanting stages may be used to reduce the tar's moisture
content.  These decanters, which may be covered, commonly are vented to. the
atmosphere.  If the tanks are covered, they have hatches to allow access to
the decanter interior.  Industry's common target for water in coal tar is
approximately 1 to 2 percent.10
     The "heavy" tar that condenses in the mains when the raw coke oven gas
is hit with flushing liquor tends to be richer in pitch and high-boiling
compounds and collects the coal and coke fines entrained out of the ovens
by the gas.  In contrast, the "light" or "primary cooler" tar that condenses
in the primary cooler tends to be cleaner, relatively lower boiling, less
viscous, and less dense.
     Depending on the plant scale and the design philosophy, these two
streams of tar may be merged or separated.  In the latter case, at least
two kinds of decanters are required.  One, often called the flushing-liquor
decanter, separates the heavy tar and sludge from the flushing liquor,
which is cooled and recirculated.  A second, called the primary-cooler
decanter or primary-cooler tar-intercepting sump, accepts the light tar and
condensate.  Some of the condensate is used as makeup to the flushing
liquor and some is forwarded (perhaps through a third kind of decanter) to
ammonia recovery or waste treatment.
     "Tar decanter" means the decanter type that accepts either all the tar
or only the heavy tar.  The tar decanter may be equipped with a mechanical
device to remove coal tar sludge, coal and coke fines, and adhering tar.
                                  3-12

-------
     The tar and liquor that come to either decanter will have been in
recent contact with raw coke oven gas at about the same temperature (60° to
80° C) and pressure (~1 atm) and will be saturated with the components of
that gas.  If separation from the gas were perfect, there would be no tar
fog to be removed from the gas and no froth from the liquid.  Separation is
never perfect; therefore, any coke oven gas mechanically entrained with the
descending tar and liquor will be delivered to the decanter at a slightly
higher pressure and will build up in the decanter if it is not vented.
     If the contents of the decanter are permitted to cool, some of the
mechanically entrained gas will dissolve.  However, no reasonable amount of
cooling will dissolve all the gas, and hydrogen is especially difficult to
dissolve.  Therefore, the minimum venting rate is related to the design of
the gas/liquid separator upstream; the venting rate will vary necessarily
from plant to plant even when expressed per unit of production.
     If the decanter is heated, perhaps in the belief that heating helps
separate the tar from the liquor, some of the dissolved species will'revert
to the gas phase.  Thus, heating augments the volume of emissions and
alters their composition.  For example, the total amount of benzene emitted
will increase even though the concentration of benzene per unit volume of
emissions may be reduced.
     Tar decanter emissions are sensitive to two variables that are not
narrowly limited:  residence time in a gas-liquid separator, and optional
heating.  The rates recorded by VanOsdell9 and those developed in this
document should be viewed in light of this sensitivity.
     Air emissions from a vented decanter depend on the composition and
temperature of the flushing liquor,  possible presence of a dispersed  light-
organic  phase floating on top of the flushing liquor, size and location of
the vents,  interior design of the decanter, and wind effects.  The emissions
contain  significant amounts of benzene and PAH's.9
     The estimated rate of benzene emissions from a tar decanter at U.S.
Steel,  Fairfield, Alabama, was 15.6  g/Mg of coke.9  The benzene emission
rate measured at a tar decanter at a Pennsylvania steel plant was 1.2  kg/h
(2.6  Ib/h).11  This decanter was one of  two for a coke battery.  Emissions
from the two  decanters are assumed to be twice the emissions from the
single  decanter, or 2.4  kg/h  (5.2 Ib/h).  The corresponding benzene emission
                                   3-13

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factor for this decanter would be 84.7  g/Mg coke.  One of three tar decan-
ters was tested at a  steel plant in  Indiana,12 where the average benzene
emission rate was 4.4 kg/h (9.7 Ib/h).  The corresponding emissions for
three decanters are 13.3 kg/h (29 Ib/h), which yields a benzene emission
factor of 69.6 g/Mg of coke at this  decanter.  The average benzene emission
factor from these two decanters is 77.2 g/Mg of coke.  The emission factor
is designated as 77 g of benzene per megagram of coke to estimate emissions
from tar decanters.
     3.2.2.2  Ball Mill.  The tar decanter collects sludge at a rate of
approximately 600 g/Mg of coke produced.13  Recent hazardous waste regula-
tions will tend to discourage disposal  of this tar decanter sludge.  One
method of recycling the sludge is to process it in a ball mill and recycle
it to the coke ovens.  A ball mill is a revolving mill that achieves size
reduction through mechanical impact.
     Emissions from the ball mill will  depend on temperature and air flow
from the ball mill.   A ball mill was observed at the Bethlehem Steel plant
at Bethlehem.  The operating temperature was low enough so that benzene and
benzo(a)pyrene (BaP)  emissions measured during a pretest screening estimate
were not considered significant.14
     Emissions from a ball mill processing tar-decanter sludge apparently
can be controlled if  the ball mill is operated at a relatively low tempera-
ture, but excessive temperatures drive  off benzene and tar components from
the sludge.  Emissions from the ball mill processing tar sludge are believed
to be relatively small at current operating conditions, and the ball mill
is therefore not considered to be a  major source.
     3.2.2.3  Flushing-Liquor Circulation Tanks.   The water that separates
from the tar in the tar decanters is transferred to the flushing-liquor
circulation tanks, as  illustrated in Figure 3-2.   The cooled flushing
liquor is used to reduce the temperature of the gas leaving the coke oven.
Because water is driven off the coal during the coking process and most of
this water is condensed into the flushing liquor,  water must be removed
from the circulating  flushing-liquor.   This excess flushing liquor is
stored in the excess-ammonia liquor  tank.
     The emission factor for the flushing-liquor circulation tank (9 g/Mg
of coke) and excess-ammonia liquor tank (9 g/Mg of coke) was obtained from
                                3-14

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a test where the fugitive emissions from a primary-cooler condensate tank
were measured.9  This tank was assumed to be similar to a flushing-liquor
circulation tank and contained liquids similar to those in the excess-
ammonia liquor tank.
     Ammonia liquor is produced at a rate of about 7 percent of the coal
rate, or 100,000 g/Mg of coke.  If the flushing liquor contained 600 ppm
benzene, the maximum benzene emission rate would be 60 g/Mg of coke.  The
benzene emission rate at a particular plant from the storage of flushing
liquor is thought to depend on the number of tanks, the number of vents,
the geometry of the tank, and other factors.
     3.2.2.4  Tar Dewatering.  The tar-dewatering process reduces the water
content of the tar more efficiently than does the decanting process.
Depending on the plant, the tar-dewatering process may consist of additional
storage time with or without chemical emulsion breakers, centrifugal separa-
tion, steam heating in tar dehydrators, or a combination of these methods.
Centrifugal dewatering should not produce air emissions directly, although
fugitive emissions are possible if any storage vessels are required for
centrifugal dewatering.
     In many existing plants, the coal tar  is not refined onsite but is
sold to tar refiners.  As mentioned previously, a common specification  is
that this sold tar  should contain no more than 2 percent water; however,
much more than this amount of water usually is mixed into the tar underflow
from the tar decanter.  Accordingly, plants dewater the crude coal  tar
usually by heating  it in tar  dehydrators to reduce its viscosity and
providing residence time for water droplets to coalesce and rise to the
surface of the denser tar.  Ordinarily, the temperature is maintained above
90°  C, and the combined vapor pressures of  hydrocarbons over the tar phase
and  water over the  aqueous phase can exceed 1 atm.  The result is a plume
of steam and hydrocarbons from  the vent if  the tank is vented to the
atmosphere.
     Some of the  by-product plants dewater  tar by  heating it with steam
coils to a temperature beyond the  boiling point of water.15  The benzene
emissions could depend on the quantity of water vapor  or  steam driven off
during the dewatering process.
                                   3-15

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     Emissions from tar dewatering were evaluated at three by-product
plants.12 16 17  The emissions data for tar dewatering at the Fairless
Hills Works (Appendix C) showed higher emissions from the West tank
(3.2 kg/h) than from the East tank (1.1 kg/h).  These tanks are operated
in series rather than in parallel, and the wet tar enters the West tar
dehydrator first.  Consequently, the emissions from the West tar dehydrator
are expected to be higher than emissions from the East tar dehydrator.  The
daily benzene emission rates from the two tar-dewatering tanks at this
first plant were 27 and 76 kg,-respectively.  Daily benzene emissions from
tar dewatering at the second plant were 43 kg.  The tar is dewatered in
storage at the third plant, where benzene emissions were 24 kg/day.   The
benzene emission factors from these three plants were 41, 9.5, and
12.9 g/Mg of coke, respectively.  These were averaged to obtain a benzene
emission factor for tar dewatering of 21 g/Mg of coke.
     The tar-dewatering tanks contained tar with 200 to 2,000 ppm benzene
in the liquid.  Tar, as collected from the flushing liquor and the primary
cooler, can contain greater than 0.2 percent benzene or 2,000 ppm at a rate
of 40 kg/Mg of coke produced.  The maximum potential for benzene loss from
tar dewatering and storage calculated from these values is greater than
80 g/Mg of coke.  The benzene emissions from tar dewatering and storage
probably will be less than 80 g/Mg of coke and will depend on the method of
operating these processes.
     S.2.2.-5  Tar Refining.  Emissions from tar refining are essentially
fugitive vapor emissions from vented tanks.  Tar-refining plants are rela-
tively unique because each plant has been built and operated to meet spe-
cific market conditions.  The basic operations are shown in Figure 3-3.
Emissions from a product storage tank were estimated as 0.008 g of benzene
per megagram of coke and 0.015 g of nonbenzene aromatic hydrocarbons per
megagram of coke, based on measured concentrations and estimated working
losses.9  Benzene emissions from these sources are therefore believed to be
relatively little, and tar-refining emissions are not considered a major
source when compared to others in the by-product plant.
     3.2.2.6  Pitch Prilling.  The tar recovered in a by-product plant can
be refined by distillation, which separates the tar components into various
fractions according to the relative vapor pressures.  The high-boiling
                                   3-16

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fraction, which includes some BaP,  is called pitch and can be formed into
prills or pellets by prilling.
     Approximately 2 million Mg of coal  tar pitch are produced annually in
the United States.  The pitch is used in the production of carbon elec-
trodes and synthetic graphite,  for roofing and paving, and as a binder for
composites such as foundry cones and refractory bricks.
                                   3-16a

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     The pitch may be shipped in molten form in tank cars,  as cast packages
of convenient size, as lumps after it solidifies, or as extruded pencils or
beads.   The latter are known as "prills" and, at one of the very few plants
performing this operation,18 they are glassy spheroids of perhaps 1 mm
(1/16 in.) diameter.
     At this plant, the pitch is preheated, filtered, and pumped to a head
tank where it is maintained at a controlled temperature and depth.  From
the head tank it drains by gravity through a steel plate perforated so the
individual streams break up into droplets.  These droplets, falling into a
stream of recirculated water, are rapidly quenched and rarely agglomerate.
The temperature in the head tank is crucial to proper priller operation.
     In times of reduced demand, the priller must be shut down.   Restarting
is a nuisance and may constitute an exceptional pollutant source if live
steam must be used to thaw pitch residues.
     At the plant discussed above, the hot pitch tank head space is vented
to avoid the buildup of explosive concentrations of hydrocarbons in air.
The venting may be passive (i.e., a fan or steam ejector is not used) and
still at some risk of explosion, or active.  If the venting is active, air
is pulled into the head space at various vents or at the edges of the lid,
and a stream of air and hydrocarbons is exhausted.  A steam or air ejector
is preferable to a fan because of tar condensation in the vent lines.
     The emissions from a pitch prilling operation were measured at a large
tar refinery.19  The flow rate of BaP was 0.00035 g/Mg of coke, considerably
less than BaP emissions from coke batteries at a large plant—approximately
0.11 g/Mg of coke.20
     3.2.2.7  Tar  and Tar Product Storage.  Tar and tar products are stored
in tanks  in coke oven by-product plants.  The primary cooler tar and the
flushing-liquor tar contain benzene, which can evaporate into the air over
the surface of the fluid inside the tank.  Some of the tar products contain
the light components of the tar, which also contains benzene.  Each of  the
tar and tar products storage tanks can contain BaP and other PAH's.  If the
tank is heated, the PAH vapor pressures may be significant.
     The  vapors from the surface of the liquid enter the head space of  the
tank, where they can be emitted into the  atmosphere by air displacement
                                 3-18

-------
when the tank is filled.  A lesser emission is contributed from tank
"breathing" (volume displacement caused by temperature changes).   Emissions
from storage tanks are influenced to some extent by the tank design, which
can influence the amount of benzene and PAH's in the tank head.  Storage
tank design for emission control is discussed in Subsection 4.1.11.
     Benzene emissions from tar storage were measured at a smaller plant21
as 5.4 kg/day.  Another plant17 had benzene emissions of 24 kg/day from tar
storage, but the second plant practiced tar dewatering in the heated tar
storage area.   The emissions factors from these two plants were 11 and
12.9 g of benzene per megagram of coke, respectively.  The benzene emission
factor for estimating emissions from tar storage, 12 g/Mg of coke, is
obtained when the two emission factors are averaged.  Uncontrolled emis-
sions of BaP (before control with a venturi scrubber) were measured as
6.8 g/day from pitch storage at a large plant.19
3.2.3  Ammonia Wastewater Processing
     This subsection describes the processes used to recover ammonia and
phenols from wastewater.  No significant benzene emission sources have been
identified in ammonia recovery from wastewater.
     The ammonia produced in a coke oven is approximately 0.2 percent of
the weight of the coal fed to the ovens.  Flushing liquor sprayed into the
collecting mains to cool the gas absorbs some of the ammonia, and more
ammonia is absorbed in the water condensed in the primary cooler (see
Figure 3-1).  Flushing liquor contains around 5 to 6 g of ammonia per
liter.   Along with ammonia, compounds such as hydrogen sulfide, phenolic
compounds (tar acids), and cyanides dissolve in the flushing liquor.  The
distribution of ammonia between the gas and liquid phases depends on operat-
ing conditions and coal composition.   Figure 3-1 assumes a phase split
where 75 percent of the ammonia remains in the gas phase.
     Several processing options have been developed to recover the ammonia.
The ammonia-handling route shown in Figure 3-1 is known as the semi direct
process and is the option commonly used in the United States.  All of the
ammonia eventually is recovered from the gas stream, but a portion enters
the flushing liquor first and is later stripped out.
                                  3-19

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     For the semi direct process, three alternatives are used for the liquor:
no treatment, free-still ammonia stripping, and free- and fixed-still
ammonia stripping.   Based on a recent Environmental Protection Agency (EPA)
survey of the by-product coking industry, all three alternatives are used.22
Out of 52 plants surveyed, 33 plants (53 percent) used or were planning to
use free and fixed stills; 4 plants (8 percent) used only free stills; and
the remainder did not attempt to recover ammonia from excess-ammonia liquor.
     3.2.3.1  Ammonia Liquor Treatment.  Aqueous ammonia solutions are
decanted from the tar in a variety of processing vessels.  Much of this
solution is recycled as flushing liquor, and a portion is constantly drawn
off to additional decanters as excess-ammonia liquor.  The ammonia in the
excess-ammonia liquor must be put into the gas phase for recovery via the
acid contactor.  The traditional removal technique is steam stripping as
shown in Figure 3-4.
     Ammonia removal from the coke oven gas traditionally has been by
contact with sulfuric acid and recovery of crystalline ammonium sulfate.
          ®
The Phosam  process involves the absorption of ammonia in circulating
aqueous ammonium hydrogen phosphate (monobasic) solution, the stripping of
ammonia from this medium, and the condensation of the concentrated ammonia.23
Distillation of the product, either cryogenically or under pressure, yields
a substantially pure ammonia that is more readily marketable than are the
salts.
3.2.4  Tar Acid  (Phenol)  Processing
     Phenol removal is  practiced as a  part of wastewater treatment and  is
not believed to be a significant benzene source. The term phenol is often
used to refer  to all the  tar acids in  the excess-ammonia liquor stream.
However, tar acids consist of approximately 60 to 80 percent phenol, and
the remainder  is mostly cresol with small amounts of some higher phenolic
homologs.24 2S   Phenol  is a minor constituent of coke oven gas, whose
concentration  varies according to coking practice and coal composition.
During 20 years  of operation, one operator has reported phenol concentra-
tions in the excess-ammonia liquor between 500 and 4,500 ppm and coking
times of 13 and  22 hours.26  Waste ammonia liquor phenol concentrations of
1,000 to 2,000 ppm are  cited commonly  as design values.
                                    3-20

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                                   AMMONIA TO
                                   GAS  STREAM
                       ii     COOLING  WATER

                    f    \ DEPHLEGMATOR  (PARTIAL CONDENSER)

                   */t
                   *     ~ 100° C  VAPOR
EXCESS-AMMONIA
LIQUOR
 WASTEWATER
                    FREE-
                  AMMONIA
                    STILL
                    FIXED-
                  AMMONIA
                    STILL
                                     LIME
                                     LEG
                                  (DISSOLVER)
IF NaOH USED
NO DISSOLVER NEEDED
                                      STEAM
                        Figure 3-4. Ammonia stills.9
                                3-21

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     Several phenol  removal/recovery techniques are practiced.   The tradi-
tional process techniques are solvent extraction and steam stripping.   In
both cases, the phenol-rich stream, once extracted, is treated with caustic
to make sodium phenol ate.
     The solvent extraction dephenolization process generally uses light
oil or benzene to extract phenol from the excess-ammonia liquor.  A flow
diagram of a solvent extraction dephenolization process is shown in Fig-
ure 3-5.  The excess-ammonia liquor flows through an absorber column,  which
may be a packed tower, a tray tower, a mechanically agitated column, or a
series of mixer-settlers.  The solvent rate is generally 1.2 volumes of
solvent per volume of excess-ammonia liquor, although wide variations
occur.
     Dephenolization generates wastewater after the tar acids are removed
from the sodium salts and springing gas.  The wastewater will be saturated
with light oil, and the  springing of the phenols with high-carbon dioxide
gas will tend to strip benzene from the water.  These emissions are not
considered to be significant nationally with respect to other by-product
benzene sources because  only a few plants are known to remove phenols with
light-oil extraction and the solubility of benzene in the water is expected
to be  low.
3.2.5   Final Cooler and  Naphthalene Recovery
     The basic function  of the final cooler is to reduce the temperature of
the coke oven gas from approximately 60° C to approximately 25° C to improve
light-oil absorption  in  the light-oil scrubber.  As the gas is cooled, some
water  and most of the naphthalene  in the coke oven gas are condensed into
the cooling medium.   Both must be  removed from the gas to prevent problems
downstream.
     Three  forms of  final  coolers  and naphthalene recovery technologies are
used  in the domestic  by-product industry.  These forms of recovery are:
direct cooling with water—naphthalene  recovery by physical separation;
direct cooling with watei—naphthalene  recovery in the tar bottom of the
final  cooler; and direct cooling with wash oil--naphthalene recovery in the
wash  oil.   Of the 55  plants listed in Table 3-3, 23 use direct-water final
coolers, 18 use tar-bottom final coolers, and 5 use a wash-oil  final cooler.
                                 3-22

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        SOLVENT EXTRACTION
                                              SPRINGING
 EXCESS-
AMMONIA
 LIQUOR
PHENOLIZED LIGHT OIL
    	»
DEPHENOLIZED-
  AMMONIA
   LIQUOR
                                            10% CAUSTIC
                    LEAN ABSORBENT
                                                            WASTE GAS
                                                              TAR ACID
                                                              PRODUCT
                                                              	*•
                                                                       WASTE (Na2, C03,
                                                                   WATER, PHENOL, ETC.)
                                                HIGH CQ2 GAS
             STEAM STRIPPING DEPHENOLIZATION  (VAPOR RECIRCULATION)
      EXCESS-
     AMMONIA
      LIQUOR
        1
    DEPHENOLIZED-
     AMMONIA
      LIQUOR

         STEAM -
        J   t
                            CAUSTIC, 10%
                                          SODIUM PHENOLATE (TO PROCESSING AS ABOVE)
         Figure 3-5.  Solvent extraction and steam-stripping dephenolization processes.9
                                       3-23

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     The circulating water absorbs hydrogen cyanide and benzene from the
coke oven gas and liberates them to the atmosphere if, as in many plants,
the same water is cooled against air in an open tower.  An indirect cooler;
i.e., a large shell-and-tube exchanger for the coke oven gas, prevents
cooling tower emissions.  The wash oil used to cool the coke oven gas in a
wash-oil final cooler is cooled indirectly in a heat exchanger.  This
cooling eliminates naphthalene fouling of the heat exchanger surface, which
would occur if hot water from a direct-water final cooler were cooled in
the heat exchanger.  Naphthalene is soluble in wash oil.
     In plants that use a direct-water final cooler, cooling the coke oven
gas causes condensation of naphthalene crystals and small amounts bf liquid
hydrocarbons.  This condensation occurs because at that point the system
pressure is higher9 and the temperature is often lower than in other parts
of the process.  Crude naphthalene that condenses in the final cooler must
be removed periodically or it will clog tubes, vents, and meters.  Removing
and processing the naphthalene for sale leads to benzene emissions, as
discussed in Subsection 3.2.5.5.
     An alternative method is to introduce tar into the final cooler.
Several plants have tar-bottom final coolers in which the water, after it
has cooled the coke oven gas and entrained the condensed hydrocarbons, is
forced through a pool of tar.  The tar removes most of the naphthalene from
the water and is recirculated to tar storage tanks.9  In another variation
of a tar-bottom final cooler, the water contacts tar in an external device
consisting of one or more mixing zones and as many settling zones, and
light tar can be sprayed into a lower section of the final cooler if a
decanter is provided to separate water and tar.18
     These methods for dissolving the naphthalene in a hydrocarbon liquid
eliminate naphthalene processing and the benzene emission from that step.
However, these methods do not eliminate benzene from the final-cooler
cooling tower.  If light tar from the primary cooler decanter is used
because the heavy tar is too viscous and has suspended solids, the light
tar already contains significant quantities of benzene.  Water brought near
equilibrium with coke oven gas at about 45° C cannot be expected to give up
much benzene to a tar that was in equilibrium with the same gas at about
35° C and a slightly lower pressure.  If the tar is supplied intermittently

                                3-24

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or only at a rate required to keep the naphthalene from clogging, the tar
will shortly come to equilibrium with the water and accept no more benzene.
     3.2.5.1  Direct-Water Final Cooler--Physical Separation of Naphthalene.
Figure 3-6 is a flow diagram of a final cooler and recirculating water
system with naphthalene collection by physical separation.  After contact-
ing the coke oven gas in the final cooler, the water is pumped through a
sealed outlet to a separation device.  Naphthalene, entrained tar, and
vapor-phase gums condense in the separation device by gravity in a sump
operation or flotation unit.  The emissions from naphthalene separation are
discussed in Subsections 3.2.5.4 and 3.2.5.5.
     After separation of the naphthalene, the water is cooled in an atmos-
pheric cooling tower and recirculated to the final cooler.  The water
contains soluble compounds such as chlorides and cyanides from the cooling
operation, as well as benzene and other hydrocarbons from the coke oven
gas.  The individual draft water cooling tower transfers heat from the
water to the air by atmospheric water-spray cooling.  Water cooling is
affected by the air circulation in the tower and ambient temperature.  A
blowdown stream may be bled from the recirculation water to prevent buildup
of  honevaporated water, chloride, and cyanide.
     The final cooler may be designed as a once-through water flow unit.
However, recirculation is preferred because of resource conservation and
water pollution constraints.
     3.2.5.2  Tar-Bottom Final Cooler—Naphthalene Recovery in Tar.  Another
common way of handling the final-cooler water is to pass the water through
tar in the bottom of the final cooler and allow the naphthalene to dissolve
in  the tar.  The naphthalene is then included with the tar in any additional
refining operations.
     Figure 3-7 is a flow diagram of a tar-bottom final cooler.  Sufficient
water must exist above the tar bottom to force the water through the distrib-
uter and into the tar.  The water then separates by gravity and  is recircu-
lated.  The tar can be recirculated continuously to the tar storage tanks
and may be sold as a final product or refined.  The final-cooler water  is
cooled in a cooling tower and recirculated to the final cooler.  A blowdown
operation may be used.
                                  3-25

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     In the tar-bottom final cooler, the water that descends from the zone
of contact with the coke oven gas carries the solid and liquid hydrocarbons
that were condensed out of the gas.   The condensed hydrocarbons are col-
lected by the tar and the water that disengages from the tar is essentially
free of entrained naphthalene, although some naphthalene is dissolved
(solubility 0.003 g/100 g of water at 25° C).  If the tar is furnished
batchwise to the tar-bottom cooler,  it eventually becomes saturated with
naphthalene as evidenced by a "silvery" irridescence or light scattering by
the crystals.  Tar in this condition cannot remove suspended naphthalene,
crystals from the cooling water and may become difficult to transfer.
Consequently, the operator usually changes the tar batch when it appears
(visually) to be saturated with naphthalene.  Estimates based on the vapor
pressures of solid and liquid naphthalene suggest that the tar becomes
saturated with naphthalene when the concentration is about 30 mole percent
or roughly 15 percent by weight, about twice the usual percentage.
     The tar-bottom cooler method not only eliminates naphthalene handling
and attendant benzene emissions but also has implications for benzene
emissions from the final cooler.  In this design, the water that picked up
benzene when it cooled the gas and went to the atmospheric cooling tower
may lose some of its benzene to the tar.  The amount of benzene the water
loses  depends on the source of the tar and the tar-to-water ratio.  The
primary or heavy tar that is condensed in the gas mains by quenching at
about  80° C contains very little benzene, perhaps 0.1 percent by weight.
If all of this tar (about 40 kg/Mg of coke) contacted all of the cooling
water  (about 4,200 kg/Mg), which contains benzene in equilibrium with coke
oven gas, some of the benzene would separate into the tar.
     However, there are operating debits.  The heavy tar is viscous and is
normally stored and handled while it is warm; therefore, cooling it to
35° C  in this contact may be inadvisable.  Using the smaller amount of
light  tar, which is richer  in benzene, might solve the naphthalene problem
but probably would not affect the benzene concentration.  Using the whole
tar is an intermediate case.  In any event, achieving close contact between
a viscous tar and an aqueous slurry of naphthalene crystals may invite
emulsification, clogging of nozzles, or both.  This process seems to work
                                   3-28

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as a naphthalene-handling method but probably should not be expected to
reduce benzene emissions from the final-cooler cooling tower significantly.
     3.2.5.3  Wash-Oil Final Cooler—Naphthalene Recovery in Wash Oil.
     Traditionally, water has been used to cool gases in the final cooler,
but wash oil also can be used.  The petroleum wash oil normally used for
the cooling medium has a boiling range of 270° to 350° C, a specific gravity
of 0.830, and a flash point of 150° C.27  Naphthalene and some light oil
will dissolve in the wash oil, and the water that condenses must be removed
in a decanter.  The wash oil normally is cooled by indirect heat exchange
and recirculated to the final cooler.  A slipstream of the wash oil contain-
ing naphthalene is routed to the light-oil recovery plant for removal of
both the naphthalene and light oil.   A lean wash-oil makeup stream is
provided to the final-cooler recirculation tank.  Figure 3-8 is a process
flow diagram of the wash-oil final cooler.
     In principle, benzene emissions from naphthalene handling and from the
direct final cooler can be eliminated by the wash-oil final cooler.  Because
the oil's heat capacity is about half that of water, the circulation rate must
be approximately doubled to maintain the same temperature pattern found in
direct-water fi.nal coolers.  If the column is the spray type, more pump
work per pound of coolant is required to break the oil into droplets of a
suitable size distribution.28  If a packed or baffled column is chosen, the
more viscous oil runs through the column more slowly, and allowance must be
made for the increased quantity of oil in the column.  Because the wash oil
removes heat from the gas, it must be cooled by cooling water (the normal
process) or possibly ambient air for much of the year.
     Cooling the gas to any temperature above its dew point would not be a
problem.  However, the purpose of this unit is to cool and dehumidify the
gas; the cooling required for moisture condensation is the greater part,
perhaps 80 percent, of the unit's capacity.   In a direct-water-cooled
column, the heavy hydrocarbons remaining in the gas, naphthalene espe-
cially, also tend to condense.  These hydrocarbons, partly solid because
naphthalene melts at 80° C and crystallizes from the condensate at lower
temperatures, form on or in the water and create a slight separation problem.
                                  3-29

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     Similarly, in a wash-oil final cooler, the condensing water will  form
small droplets on or in the oil.   The problem is analogous to that of the
hydrocarbon and naphthalene but is often more difficult to solve.  In both
cases, the dispersed phases are substantially less than is the continuous
phase.  In the wash-oil final cooler, separation is hindered by the vis-
cosity of the oil and possibly other factors.
     3.2.5.4  Naphthalene Processing.  Naphthalene collected by physical
separation is impure, has a dirty yellow-brown appearance, and contains a
high percentage of water (approximately 50 to 60 percent).  The naphthalene
slurry is commonly dewatered by gravity separation.  Crystallized naphtha-
lene may be refined through drying when the crystals are melted in a rectan-
gular tank equipped with coils for either cold water or steam circulation.
After 24 hours in the vessel, an upgraded naphthalene with a greater than
78° C crystallization point is generated.29  The crude naphthalene also may
be dissolved in coal tar after physical separation and sold as a commercial
feedstock.
     With a direct-water final cooler, crude naphthalene  is recovered from
the hot well of the direct final cooler.  The naphthalene crystals are wet
with a film of mixed hydrocarbons, often of a brownish color, which suggests
that some tar fog bleeds through the electrostatic precipitator and the
ammonia saturator.  This unpredictable amount of liquid hydrocarbon medium
is a solvent for benzene.  At these  conditions, a  liquid  hydrocarbon would
contain about 3 moles  of benzene per 100 moles  of  liquid, perhaps 6 percent
by weight.  The naphthalene  made at  this step might be 1  kg/Mg;  the liquid
hydrocarbon would not  be more than 2 kg/Mg to prevent the naphthalene from
dissolving and is probably less than 0.5 kg/Mg.  Thus, the dissolved ben-
zene might be  as much  as 30  g/Mg,  much of which would be  evaporated during
naphthalene handling and processing.   For  example, the naphthalene is
conveyed  some  distance in open troughs, heated  and dissolved  in  the accom-
panying hydrocarbon to disengage water, and  stored while  it  is  hot for
convenient handling.
      Crude naphthalene has little  market value; therefore, approximately
one-third of  all plants (see Table 3-3) eliminate  the nuisance  by  some
variant of the tar-bottom cooler.  However,  about  40 percent  of the plants
handle naphthalene  in  some manner.   Because  more  naphthalene  is  in the  tar

                                   3-31

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than is recovered at the final cooler and some of this naphthalene can be
recovered during tar refining, the tar-bottom final cooler does not elimi-
nate the production and sale of naphthalene.
     3.2.5.5  Emissions from the Final Cooler and Naphthalene Processing
Units.   Whether the tower is a direct-water once through, direct-water
recycle, direct water with a tar bottom, or wash-oil operation, the final-
cooler unit does not generate air emissions because it is a closed system.
However, air emissions may be emitted from the induced-draft cooling tower
used in conjunction with the direct-water and tar-bottom final coolers.   In
this unit, light components such as benzene and cyanide contained in the
recirculating water will be stripped out.
     Air emissions from a direct-water final  cooler cooling tower were
evaluated at three by-product plants.9 1J 16   The air stream directly above
the cooling tower at the first plant contained 51.6 g of benzene per megagram
of coke produced based upon a measured concentration and an assumed gas
flow rate.9  An analysis of the cooling tower blowdown showed it also
contained 22 to 43 g of cyanide and 10 to 16  g of phenol per megagram of
coke produced.9  Cyanide was emitted into the atmosphere from this cooling
tower at a rate of 280 g/Mg of coke.   Benzene emissions were measured from
the direct-water final-cooler cooling tower from a second large by-product
plant at a rate of 800 kg/day, or 292 Mg/ yr.11  This rate corresponds to a
benzene emission factor of 230 g/Mg of coke.   The third plant emitted
benzene at a rate of 764 kg/day, or 280 Mg/ yr.16  This benzene emission
factor is 300 g/Mg of coke, based upon capacity.   Another benzene emission
factor from a direct-water final-cooler cooling tower was estimated as 69 g
of benzene per megagram of coke produced, based on emission data provided
by a large steel company.30  This emission factor is not inconsistent with
the measured benzene emissions, although the  emissions are expected to vary
to some extent from plant to plant as well as with time at the same plant.
The benzene emission factor from cooling towers for direct-water final
coolers is 270 g/Mg of coke, the average of the two emission factors identi-
fied from actual measurements of benzene concentrations and volumetric gas
flow rates.
                                 3-32

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     The emissions from a cooling tower for a tar-bottom final cooler were
measured at another by-product plant.17  The rate of benzene emissions was
130 kg/day, or 47 Mg/yr.  The benzene emission factor, based on an assumed
capacity, was 70 g/Mg of coke.  Even considering the relative size of the
plants, emissions from the cooling tower were less than those from the
direct-water final-cooler cooling tower.
     The wash oil is cooled indirectly with heat exchangers; therefore,
benzene emissions are not anticipated from the cooling tower of a wash-oil
final cooler; however, a wash-oil decanter and circulation tank are associ-
ated with a wash-oil final cooler.  These are potential sources of benzene
emissions similar to a wash-oil decanter and circulation tank used with a
wash-oil scrubber; therefore, potentially significant benzene emissions are
likely if these sources are not controlled.  The benzene emissions from a
wash-oil decanter used for light-oil recovery were measured at a by-product
plant at a rate of 9.5 kg/ day, 3.8 g/Mg of coke, or 3 Mg/yr.16
     Emissions are generated  from the majority of the naphthalene separa-
tion, handling, and processing operations.  Naphthalene separation, when
conducted in open air dip tanks or vented storage tanks, is a potential
emission source of benzene, naphthalene, and other aromatic hydrocarbons.
These emissions increase when the crude naphthalene is refined by drying
with steam and/or melting.
     Air emissions from a flotation separation and naphthalene-refining
tank have been assessed.  The separator was approximately 8 m (25 ft) long,
3 m (10 ft) wide, and 3 m (10 ft) deep.  The refining tank was lined with
steam coils and had a 5-m vent stack.  Despite no measurable emission flow
rate from the separation tank, a vapor emitted from the vent was found to
consist primarily of benzene, benzene homologs, aromatic hydrocarbons,
fused polycyclic hydrocarbons, and fused nonalternant polycyclic hydrocarbons.
The naphthalene emission rate from the refining tank was estimated at 1.56
kg/Mg of coke produced.  The  benzene emission rate was not estimated.9
     Naphthalene is separated in a Denver flotation unit and processed in a
naphthalene drying tank and melt pit at a by-product plant in Pennsylvania.11
The benzene emission rate from the Denver flotation unit was 300 kg/day, or
110 Mg/yr.  Benzene emissions from the naphthalene melt pit were as great
as 216  kg/day, and the emission benzene rates from the two tests at the

                                  3-33

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drying tank were 17 kg/day and 0.44 kg/day.   The slurry recovered from the
Denver separation is transferred to the melt pit with an initial emission
rate of 1.5 to 3 kg/h (3 to 6 Ib/h)  As the liquid level in the pit rises,
the emission rate increases to approximately 5 kg/h (10 Ib/h).   As the
slurry in the pit melts, emissions increase to approximately 10 kg/h (25 Ib/h),
The average emission rate is assumed to be 3 kg/h (7 Ib/h), or an emission
factor of 20 g of benzene per megagram of coke.   The benzene emission
factors for the Denver flotation unit, the naphthalene melt pit, and the
naphthalene drying tank were 87, 20, and 0.12 g/Mg of coke, respectively.
The emifsions from the drying tank varied highly, depending upon the fraction
of benzene evolved in the previous step, the melt pit.   The order of magni-
tude of these combined naphthalene processing emissions was consistent with
emission estimates of Subsection 3.2.5.4.  The emission factor for both
naphthalene recovery and processing—107 g of benzene per megagram of
coke—was obtained when emission factors for the individual steps in the
process were summed.
     Other potential emission sources from the final-cooler system are:
(1) the heated tanks used to store the naphthalene-rich and lean tar of the
tar-bottom final cooler; (2) the wash-oil collecting tank, circulation
tank, decanter, and storage tank of the wash-oil final  cooler;  and (3) the
storage tanks, sumps, and/or lagoon where the decanted wastewater and
blowdown are piped for separation and storage.   Emissions from these poten-
tial sources were not measured, although emissions from a wash-oil decanter
that was a part of the wash-oil scrubber system were measured and are
discussed in Subsection 3.2.6.1.  Most of these sources are considered
small, compared with the major benzene emission sources at by-product
plants, such as the final-cooler cooling tower and tar decanters.
3.2.6  Light-Oil Processing
     Light oil is a clear yellow-brown oil composed primarily of benzene
(60 to 85 percent), toluene (6 to 17 percent),  xylene (1 to 7 percent),
solvent naphtha (0.5 to 3 percent), and over 100 minor constituents that
boil between 0° to 200° C.   The recovered quantity averages slightly less
than 1 percent of the coal  charge.   Light-oil processing at by-product
plants can consist of only light-oil recovery or light-oil recovery followed
                                 3-34

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by light-oil refining.  About two-thirds of the by-product plants sell
crude light oil, while the other third further refine the light oil.31
     3.2.6.1  Light-Oil Recovery.  Light oil is recovered from the coke
oven gas in a wash-oil scrubber.  The wash oil is petroleum straw oil with
a boiling point above 200° C to allow effective separation from the light
oil.  This wash oil resists degradation, has a high absorptive capacity for
light oil, has a low specific gravity (0.88 maximum) to aid in water separa-
tion, and does not react with the gas.24  The wash oil is pumped to the top
of a scrubbing tower and flows countercurrent to the coke oven gas entering
from the bottom.  These towers may be either tray, packed, or gravity spray
towers that are operated as a single unit or with two or more in series.
The wash oil is kept above the coke oven gas temperature to prevent water
condensation and emu!sification problems.  The wash oil is circulated at
1.5 to 2.5 £/m3 of gas and will remove approximately 95 percent of the
light oil.  A variation of this process is to substitute a coal tar fraction
for the petroleum wash oil.27       -._  . •
     The benzolized wash oil (wash-oil and light-oil mixture) is separated
by steam stripping.  Live steam is injected into the bottom of a plate
tower and the more volatile light oil is stripped-overhead.  The wash oil
is recycled to the scrubber.  This process, shown in Figure 3-9, includes a
rectifier that separates the recovered light oil into two fractions: inter-
mediate and secondary.  The flow scheme would not include the rectifier if
the crude light-oil fraction were the final product.
     Emission sources in the light-oil recovery plant include atmospheric
vents on light-oil storage tanks, process decanters, condenser vents,
intercepting sumps, and contaminated sumps.  These emission rates depend on
the operating temperature and process design parameters.
     Data for one  light-oil storage tank indicate the following emission
levels:9
          Benzene, 17.4 g/Mg coke;
          Toluene, 0.6 g/Mg coke; and
          Hydrogen sulfide, 0.5 g/Mg coke.
     The benzene emissions from a light-oil storage tank at another by-product
plant were measured as less than 12 kg/day, or about 25 g/Mg of coke.20
The head space concentration in this tank was 110,240 ppm, indicating a
                                  3-35

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-------
potential benzene emission from working losses.21  The emissions from the
tank vent are thought to be relatively low from breathing losses.
     If the head space of a storage tank containing 75 mole percent benzene
is permitted to attain equilibrium at 26° C, the vapor concentration of
benzene would be 100,000 ppm (derived from 13,330 Pa/101,308 Pa x 106 x
0.75).  This estimated value of vapor concentration can be used to estimate
that the benzene emissions from,working losses are 5.8 g/Mg of coke.  These
emissions are greater if the benzene-containing liquid is stored at a
higher temperature.
     In the light-oil system described by Wilson and Wells,24 the coke oven
gas rises through a wash-oil scrubber, and the effluent benzolized wash oil
is preheated and stripped.  The stripped vapors are partially condensed and
the uncondensed vapor passes to a light-oil rectifier where the overhead
consisting of benzene, toluene, and xylene (BTX), water vapor, and noncon-
densibles goes to a water-cooled condenser.  The noncondensibles, which are
saturated with BTX at temperatures up to 35° C in the summer, are vented to
the air.
     The noncondensibles cannot come from air leakage into the distillation
system because the system is under complete, positive pressure.  The feed
of benzolized wash oil is not commonly stored in contact with air--the
source of noncondensibles in many distillations.  The most probable source
seems to be coke oven gas dissolved in the wash oil at the scrubber.
     The amount of noncondensibles to be vented can be estimated from the
solubilities and the wash-oil rate.  In Subsection 3.2.5, the solubility of
coke  oven gas in coal tar has been estimated to determine the amount of
noncondensibles released  in tar dewatering.  Assuming the wash oil  is
chemically similar to tar in its ability to absorb benzene, the same estima-
tion  scheme applies  in this case.  The solubility at 25° C and 1 atm, a
conservative estimate, is about 1 mole of gas per 1,000 moles of oil.  The
mean  molecular weight of  the oil is assumed to be 200.
      According to Wilson  and Wells, a rule-of-thumb circulation rate is  1.6
to 2.5 £/stdm3 of gas; 1  Mg of  coal gives 160 kg (16,000 moles) of  dry
gas.24   The corresponding wash  oil is about 700 £, 600 kg, or 3,000 moles.
Approximately 3 moles of  gas dissolve if the gas is at atmospheric  pressure
and 4 moles dissolve at 34,000  Pa  (5 psig).  At worst, the vent gas  is
                                  3-37

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saturated with benzene at 35° C where its vapor pressure is about 19,000 Pa
(140 mm Hg).  Thus, the vent gas carries with it no more than 1 mole or
80 g of benzene per megagram of coal, or 110 g/Mg of coke.   This benzene
emission rate is clearly greater than that existing at the tar decanter
because the amount of liquid exposed to the gas is much greater and the gas
temperature is lower and its pressure is higher.
     The emissions from the light-oil condenser vent were evaluated at a
steel plant in Pennsylvania.11  The benzene emission rate was 314 kg/day,
or 115 Mg/yr.  The emission factor of other light-oil condenser vents is
assumed to be 89 g/Mg of coke produced, which is not inconsistent with the
theoretical estimate presented earlier in this subsection.
     The benzene that condenses in the light-oil condenser is collected in
the light-oil decanter.  If the light-oil decanter is open, significant
benzene emissions can result, since the benzene concentration is high in
the decanter.  The light-oil decanter can vent through the light-oil condenser
vent if it  is enclosed and sealed.
     Emissions from a wash-oil decanter used for light-oil recovery were
measured at a by-product plant at a rate of 9.5 kg/day, or 3 Mg/yr.16
This emission rate corresponds to an emission factor of 3.8 g of benzene
per megagram of coke.  Similar emissions are expected from the wash-oil
circulation tank, which contains wash oil separated in the wash-oil decanter.
The emission factor from the wash-oil circulation tank is assumed to be
3.8 g of benzene per megagram of coke.
     3.2.6.2  Light-Oil' Refining.  Light-oil refining involves the use of
fractional  distillation to separate the crude light oil into its various
components.  Initial processing produces an intermediate light oil composed
primarily of crude heavy solvent and naphtha.  The light-oil vapors are
condensed,  and the forerunnings (cyclopentadiene, carbon disulfide, hydrogen
sulfide, and other components boiling below benzene) are removed by distilla-
tion in another column.  The  light oil must be  desulfurized before sale;
this process is accomplished  by a sulfuric acid wash to remove impurities,
followed by neutralization and decanting of the aqueous waste.  The washed
BTX mixture is then distilled in a series of steam stills to separate the
components.27
                                  3-38

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     Light-oil refining onsite is often batch or semicontinuous because
this practice increases the unit's flexibility.   Products include the
forerunnings, benzene of various purities, toluene and xylene, washed
solvent naphtha, and crude solvent naphtha.
     Emission sources in the light-oil refining plant include the atmospheric
vents on the decanters and product storage.   These emissions are likely to
include benzene and its homologs and result from working and breathing
losses of the tanks.  Condenser vents are another source of emissions of
noncondensibles as well as the vapor from benzene and its homologs.
3.2.7  Wastewater Processing
     Depending on the coal type and coking practice, the flow of wastewater
originating from the coke ovens and by-product plant is 100 to 200 £/Mg of
coke produced.  Initially, the water is in the form of water vapor generated
from vaporizing surface moisture on the coked coal and bound water in the
coked coal.  Water is also formed from the ultimate coke oven gas combustion,
which is used to underfire the battery.
     Most of the water vapor is condensed into the flushing liquid.   This
blowdown is the primary wastewater stream.  Other sources of wastewater in
the by-product plant are:
       Barometric condenser water from steam jets used to draw vacuum
       on the ammonia crystal!izer,
       Steam stripping waste from wash-oil and light-oil decanters,
       and
       Blowdown from the final cooler.
     In one sense, ammonia recovery and phenol recovery from excess-ammonia
liquor are wastewater cleanup operations.  However, for this document they
are treated as by-product recovery processes.
     Barometric condenser water from vacuum ammonia crystal!izers is a
high-volume wastewater (1,000 £/Mg of coke).  The waste can be greatly
reduced in volume through use of surface condensers rather than barometric
condensers.  This step has led to an order of magnitude reduction in rate.32
No literature reference has been found to suggest that this waste can be
nearly eliminated through the use of vacuum pumps to draw the low pressure
                                 3-39

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on the crystal!izer.   Presumably, the service is thought to be too severe.
An attempt has been made to use recycled water in a cooling tower, but this
system had problems with corrosion and pH control.
     Final-cooler blowdown is necessary to control  the buildup of chlorides
in the cooling water.  A recycle system is recommended to minimize the
wastewater volume.  The final-cooler blowdown generally is combined with
the excess-ammonia liquor for treatment.
     Wash-oil and light-oil decanters generate approximately 300 £ of
wastewater per megagram of coke produced.  This waste results from steam
stripping the wash oil to recover light oil.   One firm has published plans
to put its light-oil  separator water into the final-cooler makeup.  This
wastewater also can be blended with the excess-ammonia liquor and treated
at the wastewater facility.
     Wastewater emissions are difficult to quantify.   Benzene may be emitted
from wastewater by aeration or evaporation from lagoons, sewers, and ditches.
The waste steam may be combined with benzene-saturated wastewater with the
release of benzene vapors into the atmosphere.  Information about these
wastewater sources is limited.
     Sumps are one source of benzene emissions for which information
is limited.  The wastewater contained in a sump may emit benzene that is
entrained or dissolved in the water.  Benzene-containing liquids also may
be present on the surface of wastewater in various sumps.  Tar is recovered
in common tar-intercepting sumps, and oil may be recovered from a light-oil
sump.
     Sump is defined here as a wastewater separation device containing one
or several streams that flow into a decanter, pit,  or tank.  There, some,of
the organic materials may float to the top for separation and recovery.
Many potential sources of benzene-containing water could be treated in a
sump.  Light oil  is recovered by distillation from the wash oil and the
condensate contains water.  The water may be separated from the light oil
in a process decanter and may then flow to another decanter or sump.
     Because of the many conceivable combinations of process water flows
and because of the absence of a detailed industry survey of sumps, benzene
emission estimates from sumps are possibly one of the least reliable of the
                                  3-40

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various sources considered in this chapter.   The sumps may be deep and
narrow, or shallow and wide and may differ according to contents, degree of
enclosure, and method of venting emissions.
     Often a sump is open to the atmosphere and has oil containing benzene
on the surface.  Benzene diffuses into the atmosphere from a surface at a
rate depending on the thickness of the boundary layer, the diffusion coef-
ficient, and the concentration.  An increased wind speed across the sump
will tend to decrease the boundary layer and increase emissions.  Also, the
rate of transport is increased by temperature and benzene concentration
activity at the surface.  The shape of a sump is important because its
area also can influence emissions.  Partial enclosure can reduce emissions
because it increases the boundary layer of air.
     Benzene that is not emitted from an open sump and that remains in the
water eventually can enter the atmosphere by evaporation during wastewater
treatment or after discharge to a receiving body of water.  The common
light-oil intercepting sumps at two by-product plants emitted 41 and 56 kg
of benzene per day.19 3S  These measurements correspond to benzene emission
factors of 3 and 27 g/Mg of coke, respectively.  The emission factor used
for estimating emissions from light-oil-intercepting sumps is 15 g of
benzene per megagram of coke, based upon the average emission factor obtained
from the two sumps that were sampled.  Measurements of the emissions from a
common tar-intercepting sump of another by-product plant indicated 45  kg of
benzene emissions per day.21  The benzene emission factor for a common
tar-intercepting sump for this plant is 95 g/Mg of coke.  Each of these
sumps emitted  approximately 16 Mg of benzene per year.  Emissions from the
common tar-intercepting sump are the most important from these three sumps
because of the potential for emitting tar components.
3.2.8  Fugitive Emissions from Leaking Equipment Components
     Leaking valves, flanges, pumps, exhausters, sampling connections,
pressure relief valves, and open-ended lines are potential sources of
fugitive benzene emissions from coke oven by-product plants.  Defective
seals on valves, pumps, and other equipment can permit benzene to leak out
of the process and evaporate into the air.  Personnel exposure to these
                                  3-41

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types of fugitive emissions has been reduced by the use of respirators,
benzene hazard signs, and building evacuation fans; but these cannot be
considered environmental controls.
     Benzene emissions from leaks can be significant when the benzene
content of the leaking liquid is high or when quantities of leaking coke
oven gas enriched with benzene are significant.   Most of the benzene liquids
are found in the light-oil recovery and refining parts of the by-product
plants.  The exhausters are potential sources of coke oven gas and benzene
emissions since the benzene has not been recovered from the gas at that
stage of the process.
     Emission factors of volatile organic compounds (VOC's) from potentially
leaking process units were obtained from an extensive investigation of
petroleum refineries.34  A source survey was also carried out at three
by-product plants to determine whether emissions from leaking process units
at coke oven by-product plants were similar to leaking process units at
petroleum refineries.35  The valves, pump seals, and exhausters were screened
at each of these by-product plants and emissions were measured when the
leaking sources were enclosed in a Mylar® bag and an equilibrium flow of
air through the enclosure was analyzed.   From the screening value distribu-
tions and the measured emission rates from most leaking sources, emissions
from the by-product plants were estimated.   These results are presented in
Table 3-5.   Emission factors from the petroleum refineries, also presented
in Table 3-5, are lower than are emissions at by-product plants except for
exhauster emissions, which were lower at by-product plants.  The emission
factors from the petroleum refinery surveys are believed to be more repre-
sentative of leaking units because they are consistent with the by-product
data and were developed from a larger data base than were by-product source
data.  Therefore, emission factors from the refinery data will be used to
estimate emissions from leaking by-product equipment.   It should be noted
that the expected emissions from various by-product plants have a considerably
greater range of variability than does the difference between the emission
factors that were determined at by-product plants and at petroleum refineries.
     Table 3-6 presents benzene emission factors for coke by-product plants
that were obtained from the VOC emission factors of petroleum refineries.
                                 3-42

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     TABLE 3-5.   A COMPARISON OF EMISSIONS FROM LEAKS FROM BY-PRODUCT
                 PLANTS TO THOSE FROM PETROLEUM REFINERIES
    Source
   Nonmethane
    organic
emission factor
 petroleum and
   refinery34
(kg/source day)
    Nonmethane
     organic
 emission factor
by-product plants35
 (kg/source day)
      Benzene
 emission factor
by-product plants35
 (kg/source day)
Valves
(Light liquid)

Pump seals
(Light liquid)

Exhausters
      0.26
      2.7
      1.236
       0.43
       5.2
       0.37
      0.25
      4.0
      0.087
             TABLE 3-6.  BENZENE EMISSION FACTORS DERIVED FROM
                           VOC EMISSION FACTORS
Percent of
sources
leaking
initially
Valves
Pumps
Exhausters
Pressure relief
devices
Sampling
connnections
Open-ended lines
11
24
35
d
d
d
VOC emission
factor
(kg/source
day)
0.26
2.7
1.2
3.9
0.36
0.055
Benzene emission factor
(kg benzene/source day)
Plant A,a
light
oil, BTX
0.18
1'9 c
0.28C
2.7
0.25
0.038
Plant B,b
refined
benzene
0.22
2.3
0.28C
3.4
0.31
0.047
 a70 percent benzene in light oil.

  86 percent benzene average in light oil  and refined benzene.

 C23.5 percent benzene in nonmethane hydrocarbon.   (From Table  3-5,  0.087
  0.37).
 f\
  This type of information would not be appropriate for relief  valve over
  pressure, sampling connections,  and open-ended lines.
                                   3-43

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Two different types of plants were assumed to estimate these emission
factors.  Plant A had light-oil and BTX recovery with an average of 70 per-
cent benzene in the benzene-containing light liquids.  Plant B produced
refined benzene in addition to the light oil with an average of 86 percent
benzene in the light liquids.  The estimated benzene emission factor at
by-product plants was obtained by multiplying the VOC emission factor by
the fraction of benzene in the liquid.  Emission factors for exhausters
were obtained by multiplying the VOC emission factor from compressors in
hydrogen service by 0.235, because this was the measured ratio of benzene
to nonmethane hydrocarbons present in the coke oven gas at the exhausters.35
     The benzene emission factors from potentially leaking units in Table 3-6
can be  used to estimate industry emissions.  The number of units of each
type at the different by-product plants was estimated and the emission
factors for each unit were multiplied by the number of appropriate units at
the plant.36  This model plant approach is discussed in Chapter 6.  The
benzene emissions from leaking process units estimated by this procedure
are a significant part of the overall emissions at coke oven by-product
recovery plants.
3.2.9   Summary of Emissions
     A  summary of the major benzene air emission sources is provided in
Table 3-7.  The estimated emission rate for benzene is given for each
source  with the annual emissions from all by-product plants.
3.3  BASELINE REGULATIONS
     The States listed in Table 3-8 have rules that govern the storage of
VOC's and may be applicable to the storage of benzene and light oil.  These
States  generally require vapor controls on storage tanks that hold more
than 150 m3 (40,000 gal) of organics with a vapor pressure greater than
10,000  Pa (1.5 psia).  The vapor control must be a pressure tank with no
vapor emissions, an edge-sealed floating roof, or a vapor recovery system.
These States regulate 21 by-product recovery plants, which produce about
42 percent of U.S. coke capacity.
     Six of these States also require vapor controls on organic compound
water separators.  This control is applicable to any separator that decants
a light-oil/water mixture or a benzene/water mixture.  Except for California's
                                3-44

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            TABLE 3-7.   UNCONTROLLED BENZENE EMISSION FACTORS
                       FOR COKE BY-PRODUCT PLANTS
         Source
 Emission factor
(g benzene/Mg coke)
Industry emissions
     (Mg/yr)36
Cooling tower
Direct-water
Tar-bottom
Light-oil condenser vent
Naphthalene separation
Naphthalene processing
Tar- intercept ing sump
Tar dewatering
Tar decanter
Tar storage
Light- oil sump
Light-oil storage
BTX storage
Benzene storage
Flushing-liquor circulation tank
Excess-ammonia liquor tank
Wash-oil decanter
Wash-oil circulation tank
Pump seals
Valves
Pressure-relief devices
Exhausters
Sample connections
Open-ended lines
Total (rounded)
270
70
89
87
20
95
21
77
12
15
5.8
5.8
5.8
9
9
3.8
3.8
a
a
a
a
a
a

6,340
1,090
4,080
2,040
470
5,360
1,090
4,350
680
780
300
80
80
510
510
180
180
600
400
270
30
50
20
29,000
Emissions were estimated on the basis of number of potentially leaking
units.   Emission factors are listed in Table 3-6.
                                3-45

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         TABLE  3-8.   STATES  REQUIRING VAPOR  CONTROLS ON  STORAGE TANKS
                                AND  SEPARATORS
Minimum tank
size
State
California
Colorado
Kentucky
Mary 1 and
Michigan

Missouri
Pennsylvania
Wisconsin
(m3)
150
150
150
240
150

150
150
150
(gal)
40,000
40,000
40,000
65,000
40,000

40,000
40,000
40,000
Minimum vapor
pressure separators
(Pa)
10,000
10,000
10,000
10,000
10,000

12,000
10,000
10,000
(psia)
1.5
1.5
1.5
1.5
1.5

1.8
1.5
1.5
included
Yes
Yes
Yes
Yes
Yes

No
Yes
No
Minimum
separator flow
(A/day )(gal /day)
760
760
760
760



760

201
200
200
200
No .
Minimum
—
200
~"
    TABLE 3-9.   CALIFORNIA REGULATIONS FOR COKE OVEN BY-PRODUCT PLANTS
Rule 462   -




Rule 463   -



Rule 464   -


Rule 466



Rule 466.1 -
Required to install, maintain, and operate a vapor contain-
ment or collection system on transfer of light oil (BTX)
from storage tanks (12- to 600,000-£ or 3- to 150,000-gal)
to railroad cars.

Required to install, maintain, and operate an approved vapor
containment collection system on (12- to 600,000-2 or
3- to 150,000-gal) light-oil storage tanks.

Required to cover all wastewater separators (eight tar
decanters)

Required to install and maintain approved mechanical seals or
equivalent on all pumps or compressors handling VOC's (11,000 Pa
or 1.55 psi Reid or greater).  Also inspect three times daily.

Required to inspect, record, and maintain all valves and
flanges handling VOC's (11,000 Pa or 1.55 psi Reid vapor
pressure or greater.)
                                  3-46

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regulations, no State regulations were found that would apply specifically
to tar-decanter, tar-dewatering, tar storage, or cooling tower emissions.
Table 3-9 lists relevant California regulations that can reduce benzene
emissions from by-product plants.
3.3.1  Baseline Regulatory Requirements
     The solid waste disposal guidelines are written with broad definitions
of "solid waste" and "disposal" so they may be interpreted to include coke
oven by-product plant emissions.  For example, disposal is defined as
including the placement of liquids or solids so any component may enter the
environment, including fugitive air emissions.37  The EPA Office of Solid
Waste Management has not promulgated specific standards for by-product
plant fugitive emissions, and there is no indication that they plan to
provide specific standards.
     In 1978, the Occupational Safety and Health Administration (OSHA)
promulgated an exposure limit on airborne concentrations of benzene of
1 part benzene per million parts of air, regulated dermal and eye contact
with benzene solutions, and imposed monitoring and medical testing.require-
ments on employers whose workplaces contain 0.5 ppm or more of benzene.38
The regulation originally applied to benzene emissions from any source in
the plant but was amended to exempt benzene emissions from mixtures contain-
ing less than 1 percent benzene (i.e., storage tanks).  However, the regula-
tion subsequently was remanded to OSHA in 1980 because of an incomplete
administrative record, coupled with the question of the cost/benefit associ-
ated with the standard.39
     By-product recovery operations currently are subject to a benzene
worker exposure limit of 10 ppm, based on an 8-hour time weighted average
for a 40-hour week.  A ceiling concentration of 25 ppm, with a maximum peak
of 50 ppm (with a maximum duration of 10 minutes) for each 8-hour shift
also is permitted.  Engineering or administrative (work practice) controls
could be required, if feasible, to meet the 10-ppm limit but usually are
not necessary.  If controls are not feasible to achieve full compliance,
OSHA may require protective equipment or other measures.40  For example,
OSHA may require the use of a respirator for an employee repairing a leaking
pump.  The current regulation applies to benzene emissions from any source
in the plant.  It is anticipated that this regulation will be enforced for

                                  3-47

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at least 1 to 2 years while the more stringent benzene standard undergoes
further Agency review.41  The current OSHA standard is expected to have no
influence on the baseline regulatory requirements because there are no

equipment requirements.

3.4  REFERENCES
 1.  Sheridan, E. T.  Supply and Demand for United States Coking Coals and
     Metal!urgial Coke.  Bureau of Mines, U.S. Department of the Interior.
     1976.  ,p. 18.

 2.  Telecon.  Murphy, M>, U.S. Department of Energy, with  Lough, C.,
     Midwest Research Institute.  February 27, 1979.

 3.  Energy Information Administration, U.S. Department  of  Energy.  Coke
     and Coal Chemicals in 1979.  Energy Data Report.  Washington, DC.
     October 31, 1980.  p. 1.

 4.  Telecon.  Sheridan, E. T., U.S. Department  of Energy,  with Lough, C.,
     Midwest Research Institute.  February 23, 1979.

 5.  Energy Information Administration, U.S. Department  of  Energy.  Coke
     and Coal Chemicals in 1976.  Coke and Coal  Chemicals,  Annual.  Energy
     Data Report.   Washington, DC.  May 11, 1978.  p. 5.

 6.  Reference 3, p. 2.

 7.  Reference 3, p. 6.

 8.  Reference 3, p. 4  and 5.

 9.  VanOsdell,  D.  W.,  et al.  Environmental Assessment  of  Coke By-Product
     Recovery Plants.   U.S.  Environmental  Protection  Agency.   Research
     Triangle Park, NC.  Publication No. EPA-600/2-79-016.  January  1979.

10.  Baldwin, V. H., and D.  W. Coy.  Study to Develop Retrofit Information
     and Other Data for Use  in Setting Standards for  Coke Oven Emissions.
     EPA Contract No.  68-02-2612, Task 39.  March 1978.

11.  U.S.  Environmental Protection  Agency.  Benzene Coke Oven  By-Product
     Plants—Emission Test Report,  Bethlehem Steel Corporation, Bethlehem,
     Pennsylvania.   Research Triangle Park, NC.   EMB  Report No. 80-BYC-l.
     March  1981.

12.  U.S.  Environmental Protection  Agency.  Benzene Coke Oven  By-Product
     Plants—Emission  Test Report,  Bethlehem Steel Corporation, Burns
     Harbor,  Indiana.   Research Triangle Park, NC.  EMB  Report No.  80-BYC-5.
     March  1981.                                         ;;
                                   3-48

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13.  Baldwin, V.  H.   Environmental  and Resource Conservation Considerations
     of Steel Industry  Solid Waste.   U.S.  Environmental  Protection Agency.
     Research Triangle  Park, NC.   Publication No.  EPA-600/2-79-074.   April
     1979.

14.  Roberson,  R., and  D.  Marsland.   Memorandum regarding emission testing
     at Bethlehem Steel  Corporation,  Bethlehem, Pennsylvania.   July 28,  1980.

15.  Allen, C.  C.  Trip Report  to  Republic Steel  Corporation,  Cleveland,  Ohio.
     January 21,  1982,  Research Triangle  Institute.   Research  Triangle Park,
     N.C.  January 27,  1982.

16.  U.S. Environmental  Protection  Agency.   Benzene  Coke Oven  By-Product
     Plants—Emission Test Report,  U.S. Steel  Corporation,  Fairless Hills,
     Pennsylvania.   Research Triangle Park,  NC.   EMB Report No.  80-BYC-8.
     March ,1981.

17.  U.S. Environmental  Protection  Agency.   Benzene  Coke Oven  By-Product
     Plants—Emission Test Report,  CF&I Steel  Corporation,  Pueblo,  Colorado.
     Research Triangle  Park,  NC.   EMB Report No.  80-BYC-6.   March  1981.

18.  Halberstadt, P.  Trip Report  to  U.S.  Steel  Corporation, Clair-
     ton, Pennsylvania,  April 30,  1979 and May 1,  1979.   Research  Triangle
     Institute.   Research  Triangle  Park,  N.C.   April  10,  1980.

19.  U.S. Environmental  Protection  Agency.   Benzene  Coke Oven  By-Product
     Plants—Emission Test Report,  United  States  Steel Corporation,  Clairton,
     Pennsylvania.   Research Triangle Park,  NC.   EMB Report No.  80-BYC-2.
     March 1981.

20.  Coke Oven  Emissions from By-Product  Coke  Oven Charging, Door  Leaks,
     and Topside  Leaks  on  Wet-Coal  Charged Batteries.  Background  Informa-
     tion Document (Draft).   Research Triangle Institute.   Research  Triangle
     Park, NC.  March 1981.

21.  U.S. Environmental  Protection  Agency.   Benzene  Coke  Oven  By-Product
     Recovery Plants—Emission  Test Report,  Wheeling-Pittsburgh  Steel
     Corporation, Monessen,  Pennsylvania.   Research  Triangle Park,  NC.  EMB
     Report No. 80-BYC-3.   March 1981.

22.  Carbone, W.  F.    Phenol  Recovery  from  Coke Wastes.   Sewage and  Indus-
     trial Waste.  22(2):200.   1950.

23.  United States Steel Engineers  and Consultants,  Inc.  (a subsidiary of
     U.S. Steel).  United  States Steel Phosam  Process.   Bulletin 2-01.

24.  Wilson, P.  J.,  Jr., and  J.  H. Wells.  Coal, Coke, and  Coal  Chemicals.
     New York, McGraw-Hill,  1950.

25.  T. Nicklin, et al.   U.S. patent  no. 3,035,889.  Assigned to Clayton
     Aniline Co., Ltd.  United  Kingdom.
                                 3-49

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26.   Wilks, F.  Phenol Recovery from By-Product Coke Waste.  Sewage and In-
     dustrial Waste.  22(2):196.  1950.

27.   McGannon, H. E. (ed.).  The Making, Shaping, and Treating of Steel.
     9th edition.  Section 4.  U.S. Steel Corporation.  Pittsburgh, PA.
     1971.

28.   Perry, R. H., and C. H. Chilton.  Chemical Engineer's Handbook.   5th
     edition.  New York, McGraw-Hill, 1973.

29.   McNeil, D.  The Separation and Purification of Naphthalene, Anthra-
     cene, and Other Polynuclear Hydrocarbons.  Coal Carbonization Products.
     Great Britain, Pergammon Press, 1966.

30.   Letter from Thorpe, J. S., Bethlehem Steel Corporation, to Goodwin, D.  R.,
     U.S. Environmental Protection Agency.  September 26, 1979.  Response
     to Section 114 questionnaire "Current and Planned  Emission Controls
     for Coke Oven By-Product Recovery Plants."

31.   Energy Information Administration., U.S. Department of Energy.   Coke
     and Coal Chemicals.  Energy Data Report.  Washington, DC.  DOE/EIA-0122/1.
     October 1978.

32.   Traubert, R. M.  Weirton Steel Division  Brown's Island Coke Plant.
     Iron and Steel Engineer.  55(1):61.  1978.

33.   U.S. Environmental Protection Agency.  Benzene Coke Oven By-Product
     Plants—Emission Test  Report, Republic Steel Corporation, Gadsden,
     Alabama.  Research Triangle Park, N.C.   EMB Report No. 80-BYC-4.
     March 1981.

34.   Mesich, F. G.  Results of Measurement and Characterization of Atmos-
     pheric Emissions from  Petroleum Refineries.  In:   Proceedings from
     Symposium on Atmospheric Emissions  from  Petroleum  Refineries.  U.S.
     Environmental  Protection Agency.  Publication No.  EPA-600/9-80-013.
     March 1980.  p. 139.

35.   U.S. Environmental Protection Agency.  Benzene Fugitive Leaks—Leak
     Frequency and  Emissions Factors for Fittings in Coke Oven By-Product
     Plants.  Research Triangle Park, N.C.  EMB Report  No. 81-BYC-12.
     January 1982.

36.   Allen, C. C.   Memorandum regarding  Method of Estimating Coke Oven By-
     Product  Plant  Industry Emissions.   Research Triangle  Institute.
     Research Triangle Park, NC.  May 28, 1981.

37.   U.S. Congress.  Resource Conservation and Recovery Act of 1976.   Public
     Law 94-580.  Washington, DC.  U.S.  Government Printing Office.
     October 21, 1976, as amended December 11, 1980.
                                  3-50

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38.  Permanent Standard for the Regulation of Benzene.  U.S. Occupational
     Safety and Health Administration.  43 Federal  Register 5918,  February 10,
     1978, as amended, 43 Federal Register 27962, June 27, 1978.

39.  U.S. Supreme Court.  Slip Op. No. 78-911.  Industrial Union Department,
     AFL-CIO vs. American Petroleum Institute, et al.  July 2, 1980.

40.  U.S. Occupational Safety and Health Administration Regulation for
     Benzene Exposure.  29 Code of Federal Regulations.  Part 1910.1000.
     Office of the Federal Register, General Services Administration.
     July 1, 1980.

41.  Telecon.  Scott, M.,  Research Triangle Institute, with Martonic, J.,
     Occupational Safety and Health Administration.  April 7, 1981.
                                 3-51

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                   4.0  EMISSION CONTROL TECHNOLOGY

     This chapter discusses the technology that has been or could be
used to control benzene emissions from the by-product plant sources
discussed in Chapter 3.  A few of these controls have been demon-
strated in by-product recovery plants; others, such as controls for
product storage tanks, are obvious candidates for technology transfer
from other industries with similarly controlled emission sources.
     The major emphasis in this chapter is on emission controls that
have been demonstrated for by-product recovery sources.  The emission
sources at most plants are uncontrolled, but a few plants have imple-
mented and demonstrated control techniques for selected sources.   Gas
blanketing is the most widely demonstrated control technique and one
of the simplest and most effective for by-product recovery plants.
Various options exist for gas blanketing and are discussed in detail
in the following subsections.  In general, the principles of gas
blanketing require sealing all of the source's openings to the atmos-
phere, supplying a constant-pressure gas blanket, and providing for
the recovery or destruction of displaced vapor emissions.
     To understand the operating principles of gas blanketing, consider
the three cases of vapor flow for the schematic in Figure 4-1.  The
first case is for vapor flow out of the source's vent line, from
pumping liquid into the tank, breathing losses, or from the continuous
evolution of gas dissolved in the liquid.   As the pressure in the
vapor space increases above the constant pressure setpoint of the
controller, the controller opens and relieves the excess pressure by
venting the vapors to a recovery or destruction system.  A second case
occurs when liquid is pumped out of the tank.  Then the blanketing gas
                                  4-1

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                                   PRESSURE CONTROLLER (OPEN)
CONSTANT-
rnL-ooUnt: \
GAS SUPPLY
VAPOR SPACE — ^>
LIQUID 	 *.
r
t
	 ^ ,—, 	 .., TO VAPOR
»• \/ ->• r
"^2
—L—
/_x, ; KbCUVhKY OK
VAPOR
	 • VENT LINE DESTRUCTION
•*"= — LIQUID LEVEL
                     EMISSION SOURCE
        Case I.  Emissions generated from pumping liquid, breathing losses,
                        or evolution of dissolved gases.
CONSTANT-
PRESSURE
GAS SUPPLY
VAPC
LIQUID
PRESSURE CONTROLLER (CLOSED)
c ^ ___ (NO FLOW)
J '" 	
IR SPACE -^_
C •« 	
\
1
•+?-
\

A
	 VENT LINE
^ 	 	 LIQUID
3
LEVEL
TO VAPOR
RECOVERY OR
VAPOR
DESTRUCTION
                     EMISSION SOURCE
         Case II.  Maintaining constant pressure when pumping liquid out.
CONSTANT-    (NO FLOW)
PRESSURE  <:
GAS SUPPLY
      NO
    LIQUID
    FLOW
PRESSURE CONTROLLER (CLOSED)   TO VAPOR
                  (NO FLOW)     /•  RECOVERY OR
                —:	j  VAPOR
                                 DESTRUCTION
                                         CONSTANT PRESSURE
                     EMISSION SOURCE
                    Case III. Static condition with no flow.
            Figure 4-1. Vapor flow for a gas blanketing control system.

                                  4-2

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flows through the vent line into the vapor space to maintain a constant
pressure, to relieve the partial vacuum, and to prevent the enclosed
vessel from collapsing inward.   The third case represents the static
condition when the liquid level remains constant and there is no net
evolution of gas or vapor from the liquid.  For this case, there is no
flow of blanketing gas or emissions, and the system remains pressurized
at the constant supply pressure.
     In by-product recovery plants, gas blanketing takes advantage of
several unique characteristics of the by-product processes because the
major elements of the system shown in Figure 4-1 are already in place.
A constant-pressure gas supply is provided by raw coke oven gas in the
collecting main or clean coke oven gas in the gas holder.  A pressure
controller is also in place because the As-kania regulator controls the
collecting main pressure, and gas holders have pressure controllers
that maintain a constant pressure for underfiring the battery.  For
gas blanketing from the collecting main, vapor recovery systems are in
place in the form of by-product recovery processes that remove organics
from the raw coke oven gas (e.g., light-oil scrubbers).  For gas
blanketing from the gas holder, a vapor destruction system is in place
because the clean coke oven gas is burned and the fuel value is recovered
when the gas is used to underfire the coke ovens.  Therefore, major
requirements for gas blanketing are already in place and would not be
purchased and retrofitted.  Major cost items for the gas blanketing
system in by-product recovery plants would be piping, valves, insula-
tion, and equipment modifications for leak-tight enclosure.
     This chapter also discusses other controls that have been demon-
strated  in by-product recovery plants or  similar industries.  For
example, a wash-oil scrubber is used in by-product plants to absorb
organics from gas streams  in the light-oil recovery operation.  Another
demonstrated control is a  processing equipment change to control
emissions from cooling towers and naphthalene handling by altering the
final-cooler process.  Candidates for technology transfer include
adsorption, vapor condensation, other forms of gas blanketing, other
forms of vapor destruction, alternative controls for storage tanks,
and  controls for  leaking equipment  components.
                                   4-3

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     Because a control technique may be applicable for several emission
sources, for each control the applicable sources are described.  For
easy reference, Table 4-1 lists each source, the applicable control
technique, and the subsection where the control is discussed.
4.1  GAS BLANKETING FROM THE COLLECTING MAIN
4.1.1  Applicable Sources
     A coke oven gas blanket from the collecting main can be used to
control emissions from the tar decanter, tar-intercepting sump, tar-
dewatering tanks, tar storage tanks, flushing-liquor circulation
tanks, and weak ammonia liquor storage tanks.  The emission sources
were chosen as a group because they are in close proximity to each
other.  In addition, all of these vessels are associated with the
recovery of tar and ammonia liquor in the initial step of the by-
product recovery process.
     The close proximity allows the use of a common large header to
supply coke oven gas to the area from the collecting main; smaller
branches of piping connect the individual vent lines to the header.
Because the liquid contents of these tanks come from water contact
with the raw coke oven gas and subsequent separation of tar and flushing
liquor, no contamination problems are expected from a raw coke oven
gas blanket.   An advantage in using coke oven gas from the collecting
main for these sources is that additional organics are recovered in
the tar and light oil instead of being vented to the atmosphere.
4.1.2  Description of Technology
     A gas blanket from the collecting main is provided by making a
pressure tap on the main, piping the gas to the by-product plant, and
connecting the enclosed sources to the blanketing line.   Vapor emissions
from the sources would flow back into the collecting main and would be
processed with the raw coke oven gas.   If liquid were removed from an
emission source, coke oven gas would fill the vapor space and maintain
a constant pressure.
     Gas blanketing from the collecting main has been implemented in
the by-product recovery plant of Armco,  Inc., in Houston, Texas.1  The
system at Armco was designed and installed by Koppers Company, Inc., a
                                  4-4

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         TABLE 4-1.  EMISSION SOURCES AND CONTROL TECHNIQUES
Emission source
Tar decanter
Flushing-liquor circulation
Tar- intercepting sump
Tar storage and dewatering
Ammonia liquor storage
Light-oil plant3
Light-oil sump
Light-oil storage
Pure benzene storage
Cooling tower and naphthalene
hand! i ng
Equipment leaks
Control
technique
COG- CM
COG- CM
COG- CM
COG- CM
WOS
COG-CM
WOS
COG-GH
Enclosure
COG-GH
WOS
GB-GH
WOS
TBFC
WOFC
Varies
Subsection
4.1
4.1
4.1
4.1
4.4
4.1
4.4
4.2
4.5
4.2
4.4
4.3
4.4
4.6.1
4.6.2
4.8
 COG-CM = coke oven gas blanket from the collecting main.'
 WOS    = wash-oil  vent scrubber.
 COG-GH = coke oven gas blanket from the gas holder or underfire
          system.
 GB-GH  = nitrogen  or natural  gas  blanket vented to the gas holder.
 TBFC   = tar-bottom final  cooler.
 WOFC   = wash-oil  final  cooler.

^Includes the light-oil condenser  and decanter,  wash-oil decanter, and
 circulation tank.
                                   4-5

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major builder of coke batteries and by-product recovery plants.   The
following discussion describes the control system's design and require-
ments in general and is based primarily on the design demonstrated at
the Houston plant.  A simplified schematic of the Armco system is
provided in Figure 4-2 for reference to the general discussion.
Specific details on the Armco system are provided following the general
discussion.
     An explanation of collecting main operation is needed to describe
how the control system works.  Coke oven gas is generated from the
coking of coal in the ovens and is removed through a series of stand-
pipes on each oven.  The standpipes are connected to a common, large
duct called the collecting main that routes the coke oven gas to the
by-product recovery plant.  The pressure in the collecting main is
very carefully controlled at 5 to 10 mm (0.2 to 0.4 in.) of water
pressure by the battery operator because of the direct impact of
collecting main pressure on the back pressure in the coke ovens.  Coke
plant operators have explained that pressure control in the collecting
main is inherently reliable and must be reliable for the safe operation
of the battery.1 2 3  Pressure control is provided by the Askania
regulator, and because of the importance of precise pressure-control,
a battery worker controls the pressure manually when any problems are
experienced.
     Excessive pressures and pressure excursions usually are controlled
by a bleeder control valve that vents the excess pressure through a
stack.  A high collecting main pressure causes the battery operator
many problems; e.g., unseating charging port lids, blowing standpipe
caps or damaging standpipes, and causing voluminous emissions from
coke oven doors.  Negative collecting main pressures also are avoided
because of more serious effects.  Oxygen infiltration from the oven
doors or topside can produce an explosive mixture  in the collecting
main, suction main, and every coke oven gas main (and associated
process equipment) in the by-product plant.  Negative collecting main
pressure also causes serious heat damage to doors, door seals, jambs,
and other parts of the battery structure.  Because of the existing
                                  4-6

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                                               15 cm
         Collecting
           Main
1
                                Offtake
                               Main  (61 cm)
              15 cm
Atmospheric
   Vent
   15 cm
  ~l—eg
          -#-
                    Flushing-Liquor Decanters
                        (Tar Decanters)
15 cm
                                                                 Flushing-Liquor
                                                                 Collecting Tank
              SYMBOLS
               t^[  Three-way valve

                )(  Steam-out connection

                ^  Gate valve

               M Butterfly valve
        Figure 4-2. Gas blanketing of tar decanters and flushing-liquor tank
                             from the collecting main.1
                                        4-7

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emphasis on precise pressure control, the collecting main is considered
a reliable source for a gas blanketing control system.
     Many design features and modifications to the emission sources
must be considered for the gas blanketing to work effectively and
safely.  Each emission source must be enclosed to accept a slightly
positive pressure without leaks to the atmosphere.  For most storage
tanks, enclosure would involve closing atmospheric vent lines and
connecting the tank's vent line to the gas blanketing line.   For
riveted vertical tanks in poor condition, more extensive modifications
may be required.  For example, the roof may need to be replaced,
welded, or sealed in some manner to avoid leakage of coke oven gas
from existing gaps where the roof contacts the perimeter of the tank
shell.
     Tar decanters and tar-intercepting sumps may require more exten-
sive modifications before a gas blanket can be applied.   Tar decanter
tops usually have a rectangular surface where the liquid is either
exposed to the atmosphere or partially covered with concrete slabs set
on steel support beams.   For many plants, the decanter top must be
removed, a water seal and metal cover installed, and gasket material
added to provide a tight seal for the metal cover.  A water seal for
the tar decanter is illustrated in Figure 4-3.4  The seal is a heavy
plate structure suspended from the roof of the decanter near the
sludge discharge chute that allows the major portion of the liquid
surface to be blanketed at a small positive pressure.   The remaining
13 percent5 of the liquid surface provides clearance for the sludge
conveyor and is open to the atmosphere.   In summary, the following
items are required to prepare the tar decanter for a positive-pressure
gas blanket:
          Remove the existing cover,
          Blank pipelines,
          Clean and inspect the tank, and repair leaks;
          Install the steel plate cover,  water seal, steel  support
          beams, and gaskets;
                                  4-8

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                    4-9

-------
          Weld; and
          Add access openings and vent pipe.
     The tar-intercepting sump requires the same modifications listed
for the tar decanter except for the water seal.  Because no sludge
conveyor is used, the entire surface of the sump can be covered with
metal plate and sealed with gasket material.
     Heat tracing and insulation are important design considerations
for this application.  The vented emissions and the raw coke oven gas
contain tar and naphthalene that can condense and plug lines and
valves.  Although heat tracing and insulation should prevent this
condensation and accumulation in the vent lines vent and drain connec-
tions are included in the design for steaming out lines should the
need arise.
     Each vessel would be equipped with three-way lubricated plug
valves to avoid sticking because of tar deposits.   Valve connections
are arranged so that in one position the tank is vented to the collecting
main and in the other position the tank is vented to the atmosphere.
This arrangement permits the blanketing line and the tank(s) to be
isolated for maintenance or visual inspections and ensures that the
tank is vented at all times.   In either position,  the plug valve
provides a clear opening for the passage of vapors and prevents pockets
where tar may accumulate and interfere with the opening and closing of
the valve.
4.1.3  Demonstration of Gas Blanketing from the Collecting Main
     Gas blanketing from the collecting main was installed at Armco's
Houston Works between 1976 and 1977 and was operated successfully
until the coke battery shut down in 1981.   The gas blanket was applied
to two tar decanters and a flushing-liquor circulation tank as shown
in Figure 4-2.   The tops of the tar decanters were enclosed up to the
sludge conveyor with a 6-mm (0.25-in.) steel plate and sealed with
gasket material.   Access hatches on the decanter and circulating tank
                                  4-10

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also were covered and sealed.   A vertical manifold of small valves was
installed to allow the operator to determine the level of tar and
flushing liquor in the tar decanter.1
     The gas blanketing line was a 15-cm (6-in.) pipe connected to the
61-cm (24-in.) offtake main upstream of the Askania regulator (butterfly
control valve).  Three-way valves, atmospheric vents, and steam-out
connections for line cleaning were installed; all of these lines were
steam traced and insulated.  The blanketing pressure was typically
controlled at 6 mm of water with a range of 4 to 8 mm of water.   No
significant operating problems were experienced with the control
system. -1
     The system at the Houston Works was not extended to control
emissions from ammonia liquor or tar storage.  (Armco installed a
wash-oil scrubber for these sources, as discussed in Subsection 4.4.)
However, the same gas blanket could be applied to these storage tanks
if the tanks were enclosed and connected to the gas blanket lines, as
described in the general discussion.  Armco personnel indicated that
three tar-collecting tanks, which were connected to a negative-pressure
vent system (see Subsection 4.7.1), also could have been controlled by
gas blanketing from the collecting main.1
4.1.4  Control Efficiency
     The benzene control efficiency of the gas blanketing system
depends upon three major factors:  leakage, the efficiency of benzene
removal in the light-oil scrubbers, and the efficiency of the underfire
combustion systems.   Approximately 90 to 95 percent of the benzene in
coke oven gas is removed in the light-oil recovery process,6 and 5 to
10 percent remains with the gas and is incinerated.  Incineration
efficiencies up to 99 percent have been reported for control of gasoline
vapors,7 8 and similar or higher efficiencies are expected in the
combustion of coke oven gas because of higher operating temperatures
and longer residence times.  Assuming a periodic inspection and main-
tenance program prevents leaks, a control efficiency in excess of
                                  4-11

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99 percent would be expected for the gas blanketing system.   However,
considering that a leak might develop and would require some time to
repair, a more conservative estimate of 98 percent control efficiency
is reasonable.
     These control efficiency estimates apply only to emissions collected
within the gas blanketing system.  Because the tar decanter would not
be covered completely (to allow sludge removal), control efficiency
for the tar decanter emissions is estimated to be 95 percent.
4.2  GAS BLANKETING WITH CLEAN COKE OVEN GAS
4.2.1  Applicable Sources
     A coke oven gas blanket from the gas holder or battery underfire
system has been used to control emissions from the light-oil condenser,
decanter, and storage tank; wash-oil decanter and circulation tank;
and benzene-toluene-xylene (BTX) storage.1 3 9  These emission sources
are generally in close proximity to each other in an area called the
light-oil pi antj and all are associated with the recovery of light oil
(70 percent benzene).  The close proximity allows the use of a common
large header to supply coke oven gas to the area from the gas holder;
smaller branches of piping connect the individual vent  lines to the
header.  No contamination problems are expected because this gas
blanketing control has been demonstrated for these sources with both
desulfurized and undesulfurized coke oven gas.  Collected emissions
from all of the sources would be added back to the coke oven gas to
recover their fuel value in the gas combustion system.
4.2.2  Description of Technology
     A positive-pressure blanket of clean coke oven gas is provided  by
making a pressure tap at the gas holder or underfire gas  supply,
piping the gas to the light-oil plant, and connecting the enclosed
sources to the blanketing line.  Vapor emissions from the sources
would flow back into the clean gas system and ultimate  control would
be provided by combustion of the coke oven gas.
     Available data  indicate that at least three by-product  recovery
plants have implemented gas blanketing of emission sources in the
light-oil plant.1 3  9  One plant installed such a system  as  early as
                                  4-12

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1954 and has since continued operation without difficulties.3  The
following discussion describes the control system and provides details
on the three demonstrated applications.  A simplified schematic con-
taining the major design details is given in Figure 4-4 for reference
to the general discussion.
     After by-product removal, the clean coke oven gas is used to
underfire the coke ovens and to provide a fuel source for other combus-
tion processes.  A few plants have desulfurization facilities and most
do not; however, both sulfur-containing and desulfurized coke oven
gases have been demonstrated in this application.  The clean coke oven
gas is maintained at a constant pressure, typically 36 to 46 cm (14 to
18 in.) of water by a gas holder.  The gas holder has an existing
pressure controller, and pressure excursions are prevented by a bleeder
control valve on the gas holder.  The bleeder control valve vents at
about 51 cm (20 in.) of water, and in addition, many gas holders have
a water seal that will blow at about the same or slightly higher
pressure.2  A continuous supply of blanketing gas is available because
the gas is required for underfiring the battery.  Most plants have a
source of natural gas that is used to supplement or replace the coke
oven gas in the gas holder or underfire system in the event that the
supply of coke oven gas is interrupted.1 2 3
     Several design features and modifications to the emission sources
must be considered for positive-pressure blanketing with clean coke
oven gas to work effectively and safely.  Each emission source must be
enclosed to accept the positive gas pressure without leaks to the
atmosphere.  For most vessels in the light-oil plant, enclosure includes
closing all vents to the atmosphere and connecting the vessel's vent
line to the gas blanketing line.  The  light-oil condenser and horizontal
tanks require few modifications to withstand a pressure of 36 to 46 cm
(14 to 18 in.) of water.1 3 9  However, old storage tanks, particularly
riveted vertical tanks in poor condition, may require extensive modifi-
cations to withstand the pressure without leakage to the atmosphere.
Because of gaps in the roofs of these  tanks, extensive repairs, sealing
gaps, or replacing the roof would be required.3
                                   4-13

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00
00
rgH&l	X
                 o
in
                                                           
-------
     Heat tracing and insulation are recommended for all  of the blanketing
lines to avoid condensation, accumulation, and plugging in the linfes.
As shown in Figure 4-4, steam-out connections are provided for line
cleaning if necessary.   Three-way lubricated plug valves  are installed
so the blanketing line or vessels can be isolated for maintenance,
line cleaning, or visual inspection.  The valve arrangement ensures
that the emission source is vented at all times, either to the atmosphere
or to the coke oven gas main.  Flame arrestors are installed in the
atmospheric vent lines to prevent flame propagation into  the tank
should emissions ignite while they are vented to the atmosphere.  Many
plants already use flame arrestors in this application.
     Gas blanketing of vessels containing light oil or benzene reduces
the fire and explosion hazard associated with these vessels when they
are vented to the atmosphere.  Currently, the vast majority of by-product
plants do not use gas blanketing and the vents on light-oil storage
tanks are open to the atmosphere.  When the atmospheric vent is open,
oxygen can enter the vapor  space when the tanks are emptied periodically
or when  significant cooling takes place.  This oxygen  infiltration can
cause the vapor in the tank to be within the explosive limits of
vapor.   Applying a positive-pressure blanket eliminates oxygen  infiltration
and maintains the vapor space in the tank above its upper explosive
limit.   Eliminating oxygen  also reduces sludge formation in the tanks
and process equipment  that  contain wash oil and light  oil.  The sludge
results  from  the oxidation  reaction between oxygen  in  the air and wash
oil or  light  oil.
4,2.3   Demonstration of Gas Blanketing with Clean Coke Oven Gas
     Gas blanketing of  the  light-oil plant has been demonstrated  at
Bethlehem Steel Corporation's Sparrows Point plant;3 Republic Steel
Corporation's Cleveland plant;9 and the Armco,  Inc., plant  in Houston.1
At Sparrows Point, undesulfurized coke oven gas from the gas holder is
used to  blanket wash-oil decanters, circulation tanks, collecting
tanks,  and wastewater  storage tanks in Plants A and B.  The system was
installed  in  Plant B in 1954, and a similar  system  was installed  in
Plant A  as part of the conversion to a wash-oil final  cooler.3
                                   4-15

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     The main supply for the gas blanket is a 20-cm (8-in.) line
connected to the coke oven gas line exiting the wash-oil scrubbers.
The various tanks are connected with a 15-cm (6-in.) line that runs
from the 20-cm (8-in.) supply to the top of each tank.  An isolation
valve is installed in each tank's vent, and steam-out connections are
provided for line cleaning.  Each tank is also equipped with 5-cm
(2-in.) atmospheric vent lines and flame arresters, but these lines
are closed during normal operation.  None of the gas blanketing lines
are heated or insulated.  Water U-seals are placed in the 20-cm (8-in.)
line to help remove condensate and to protect the system from excessive
pressures.  No safety relief valves, pressure controllers, pressure or
flow monitors, alarms, or explosive limit detectors are on the tanks.3
     The Bethlehem Steel personnel indicated no problems with the gas
blanketing system and minimal maintenance requirements.  The cost of
the installation was justified because it prevented oxidation, sludge
formation, and fouling of lines and equipment.   The gas blanket prevents
oxygen in the air from contacting the wash oil  and light oil, which
react with the oxygen to produce a sludge.   When sludge formation is
avoided, there is a large savings in labor ,to clean the final cooler,
heat exchangers, and piping.3  In addition, solid waste disposal  costs
are not incurred for the potentially hazardous  sludge.
     A gas blanketing system was installed in Republic Steel's Cleveland
plant in 1960.   In Plant 1, desulfurized gas from the battery underfire
system is used to blanket the wash-oil decanters, circulation tanks,
rectifier separators, primary light-oil separators, secondary light-oil
separators, light-oil condensers, and final-cooler circulation tanks.
In Plant 2, an undesulfurized gas blanket is applied to the primary
and secondary light-oil separators, rectifier separators,  and wash-oil
circulation tanks.9
     The main supply line for the coke oven gas is a 15-cm (6-in.)
line with 5-cm (2-in.) lines connecting separators and 10-cm (4-in.)
lines connecting the decanters to the supply line.   The gas blanketing
lines to each source are steam traced and insulated to minimize conden-
sation and fouling;  in addition,  four drip  points are installed so any
                                  4-16

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condensate could be drained from the lines.9  Other design features of
the system are similar to those described previously for the Sparrows
Point plant.
     Plant personnel stated that routine maintenance on the gas blanketing
system was minimal.  Routine inspections include a monthly check of
the seals in the flame arresters and quarterly inspections of piping
and other equipment.  When line cleaning is necessary, a steam supply
is connected and the lines are steamed out.  The purpose of the blanketing
system is to reduce sludge formation (as described for Sparrows Point),
and the system was reported to work well in performing this function.9
     The Houston plant of Armco, Inc., installed gas blanketing in the
light-oil plant between 1976 and 1977 and used the system until the
coke batteries shut down in 1981.  A schematic of the Armco system is
provided in Figure 4-4.  A blanket of undesulfurized coke oven gas
from the gas holder was used to control emissions from the wash-oil
decanter, circulation tank, storage tank, two light-oil storage tanks,
three light-oil condensers, and two light-oil separators.   Each of
these emission sources was equipped with three-way valves, flame
arresters, steam-out connections, steam tracing, and insulation as
discussed previously in the general description.   No major modifications
or repairs were required to pressurize the emission sources.1    I
     A 15-cm (6-in.) line from the gas holder supplied the gas blanket
to the light-oil plant.  Vent connections to the supply line were
10 cm (4 in.) in diameter for the wash-oil  tanks, 5 cm (2 in.) for the
light-oil storage tanks, and 8 cm (3 in.) for the light-oil condensers
and separators.  The gas blanket was maintained at a pressure of 38 cm
(15 in.) of water by the gas holder.  Plant personnel  reported no
significant operating difficulties with the system.1
4.2.4  Control  Efficiency
     The benzene control efficiency of the gas blanketing system
depends upon the amount of leakage and the efficiency of combustion in
the underfiring system.  The temperature and residence time of the
coke oven gas in the combustion system are expected to result in
efficiencies of 99 percent or greater.   (Incineration efficiencies of
                                   4-17

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99 percent have been reported for gasoline vapors.)  Assuming periodic
inspection and maintenance minimize leaks, an estimated 98-percent
control efficiency for the gas blanketing system is reasonable.
4.3  NITROGEN OR NATURAL GAS BLANKETING
4.3.1  Applicable Sources
     A gas blanket of nitrogen or natural gas can be used to control
emissions from pure benzene storage tanks.  By-product plant operators
have claimed that coke oven gas should not be recommended as the
blanketing medium because of product quality specifications for the
pure benzene and the possibility of contamination from components
(e.g., sulfur compounds) in the coke oven gas.2 9  For pure benzene
storage tanks, emissions from breathing or working losses would be
routed to the coke oven gas main and burned in the gas combustion
system.  Alternatively, emissions may be routed to the gas main before
light-oil removal and recovered in the wash-oil scrubbing operation.
4.3.2  Description of Technology
     The choice of blanketing gas depends upon existing gas supplies
in the plant, proximity of the supply to the tank, and reaction or
contamination considerations between the blanket gas and the liquid in
the tank.  Nitrogen or natural gas was considered for blanketing pure
benzene storage tanks'because most by-product plants have an existing
supply of one or both.   For example, coke plants that are part of an
integrated steelmaking complex may have access to nitrogen from their
oxygen plant associated with steelmaking.9  Most coke plants have a
source of natural gas used to supplement the coke oven gas; to replace
the coke oven gas in emergency situations; or to underfire the coke
ovens during startup, idle, or controlled shutdown of the coke
battery.* 2 3
     The major elements of a nitrogen or natural gas blanketing system
must be purchased and installed, whereas the coke oven gas blanketing
systems use many elements already in place.   The gas must be purchased
or routed to the by-product recovery plant,  a pressure controller
installed to control  supply pressure,  and another pressure controller
installed where emissions are vented to maintain the blanketing pressure.
A schematic of a gas  blanketing system is given in Figure 4-5.
                                   4-18

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          PRESSURE
         CONTROLLER
  GAS
SUPPLY
               FLAME
             ARRESTOR
                ATMOSPHERIC
                   VENT
         LIQUID   f
          LINE    r
                                •Z-
                                A
                                 i
    PRESSURE
  CONTROLLER
                      r  TO GAS HOLDER
                     "^  ORUNDERFIRE
                        SYSTEM
THREE-WAY VALVE
VENT LINE
                          BENZENE STORAGE
                                TANK
    VAPOR SPACE

    LIQUID LEVEL
           Note: Dashed arrows show emission's flow.
           Figure 4-5. Schematic of a nitrogen or natural gas blanketing system.
                                 4-19

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     The pressure controller or pressure reducer controls the supply
pressure of the gas at 38 to 46 cm (15 to 18 in.) of water.   Because
displaced vapors are vented to the gas holder, which is maintained at
46 cm (18 in.) of water, another pressure controller is installed to
prevent backflow of coke oven gas and to maintain the blanket pressure.
When the pressure in the tank's vapor space increases to above 46 cm
(18 in.) of water, the pressure controller opens and vents the vapors
to the gas holder.  When liquid is removed from the tank, more blanket-
ing gas is provided through the pressure controller on the gas supply
to maintain a constant pressure.  Under static conditions with no
liquid or vapor flow, the system remains pressurized with no net flow
of the blanketing gas or vapor emissions.
     The benzene storage tanks must be enclosed to accept a positive-
pressure gas blanket without leaking.  For some storage tanks, enclosure
is accomplished when the tank's atmospheric vent line is connected to
the gas blanketing line.  Modifications may be required for old riveted
storage tanks that are not currently leak tight.  The extent of the
modifications will depend upon the tank's condition and may include
sealing and repairing the roof, replacing the roof, or replacing the
tank.
     Heat tracing and insulation would be required for the gas blanket-
ing line from the benzene storage tank to the vapor destruction system.
Line heating would be most important for winter operations because
benzene freezes at 5.5° C (42° F).   Three-way valves would be installed
on each storage tank to allow the tank to be vented at all times,
either to the control system or to the atmosphere.   The ability to
vent to the atmosphere is necessary to isolate the tank from the gas
blanket, to perform maintenance or visual  inspections of the inside of
the tank, and to prevent loss of the blanketing gas if the tank is
emptied or taken out of service.  Flame arrestors would be installed
in the atmospheric vent lines to reduce the fire and explosion hazard
when the tank is vented to the atmosphere.
     Nitrogen blanketing of benzene storage tanks has been applied at
the Aliquippa Works of J&L Steel, but displaced emissions are not
                                  4-20

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controlled.10  Currently, nitrogen is used to blanket crude light-oil
storage tanks to prevent sludge formation.  However, emissions are
vented to the atmosphere and are not vented to a vapor recovery or
destruction device.
     The control efficiency of a nitrogen blanketing system that is
vented to a vapor recovery or destruction device depends upon the same
factors as that of a coke oven gas blanketing system:  extent of
leakage and combustion efficiency.  Assuming the gas blanketing lines
are well maintained with little leakage, an efficiency of 98 percent
or greater should be obtained with this control system.
4.4  WASH-OIL SCRUBBERS
4.4.1  Applicable Sources
     A wash-oil scrubber can be used to control emissions from the
various storage tanks in the by-product recovery plant.  The wash-oil
scrubber has been applied to weak ammonia liquor tanks, tar storage
tanks, and tar-dewatering vessels.1  Other potential applications
include light-oil storage tanks, BTX storage tanks, and pure benzene
storage tanks.
     The applicability of a wash-oil scrubber as an efficient control
device to sources with heated vapors (e.g., tar-dewatering and tar
storage tanks) depends upon the temperatures of the vapors in the
scrubber.  The vapors must be cooled for the scrubber to be effective,
either by a condenser or by a sufficiently high flow rate of cool
wash-oil spray.
     An advantage of the wash-oil scrubber over gas blanketing is the
applicability to old storage tanks in poor condition.  The pressure
drop through the wash-oil scrubber is negligible; therefore, modifi-
cations to old tanks are minimal because the tanks are not subjected
to pressures significantly higher than the normal operating conditions.
4.4.2  Description of Technology
     The wash-oil scrubber would be  installed on the side of the
storage tank or in a centralized  location to control emissions from
several storage tanks.  The emissions enter the bottom of the scrubbing
chamber and contact a spray of wash  oil that is introduced into the
                                  4-21

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top of the spray chamber.  The wash-oil spray absorbs benzene from the
vent vapors.  After passing through the scrubber, the benzolized wash
oil is routed to the light-oil recovery plant for removal of benzene
and other organics from the wash oil.  The debenzolized wash oil is
then recycled to the wash-oil scrubber.
     The process of absorbing benzene from a gas stream with a wash-oil
scrubber is not new to the by-product recovery industry.  The coke
oven gas leaving the final cooler contains about 2 percent benzene
that is removed in a wash-oil scrubbing operation.  Most by-product
recovery plants remove the light oil (primarily BTX) from the coke
oven gas by contacting the gas with liquid petroleum wash oil in a
scrubbing tower (absorber).  The inlet wash oil, containing about
0.2 percent light oil, is sprayed into the top of the wash-oil scrubber
and flows through spray nozzles to contact the g'as stream.  The outlet
wash oil contains 2 to 3 percent light oil and removes 90 to 95 percent
of the light oil from the coke oven gas.6
     Recent designs of wash-oil scrubbers are not fitted with hurdles
or packing to accomplish gas-liquid contact.   Contact is accomplished
by the use of single conical sprays placed at two or three elevations
in the tower.  Restrictions to gas flow by accumulated residues commonly
found in packed scrubbers are minimized or eliminated in scrubbers of
this design.6  Wash-oil scrubbers currently used for light-oil removal
are large towers designed to handle high volumes of coke oven gas.
Applying this scrubbing operation to the vented emissions from storage
tanks results in a much smaller scale design for the scrubbing chamber
and a lower wash-oil circulation rate.
     The Houston plant of Armco, Inc.,  used a wash-oil  scrubber to
control the vented emissions from two tar storage tanks, an ammonia
liquor storage tank, and an ammonia liquor sump.   A simplified schematic
of the control system for the Houston plant is given in Figure 4-6.
The system was installed between 1976 and 1977 and was  operated without
difficulty until the coke battery was shut down in 1981.l
     The two tar storage tanks shown in Figure 4-6 have capacities of
1.6 million £ (425,000 gal) and 280,000 & (75,000 gal).  Tar is dewatered
in the larger tank by steam heating for 6 days and settling for 1 day.

                                 4-22

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                              4-23

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The tar is then transferred to the  smaller tank and  sold  locally.  The
ammonia liquor storage tank has a capacity of  280,000 £ (75,000 gal),
and the ammonia liquor sump has dimensions of  3.7 m  by 6.7 m  (12 ft by
22 ft).  These sources were enclosed when the  access manways  were
covered and  sealed and the atmospheric vent  lines were connected to
the scrubber entrance.  The sump was enclosed  with a 1-cm (0.375-in.)
metal cover  and gasket, and access  openings  that were installed in the
sump cover were also  sealed with gasket material.1
     The scrubber is  a metal chamber with a  diameter of 0.3 m (1 ft)
and a length of 3.7 m (12 ft).  Debenzolized wash oil is supplied to
the top of the scrubber through a 2.5-cm (1-in.) supply line  at 0.1 £/s
(1.6 gal/min) through a spray nozzle.  (The  design and operating gas
flow rates were not available.)  The scrubbed  vent gases exit the
scrubber through a 20-cm (8-in.) vent line,  and the wash oil  is removed
from the scrubber by  gravity drain  through a 7.6-cm  (3-in.) drain
line.  The wash-oil drain runs to an enclosed  sump that routes the
wash oil to  the wash-oil decanter in the light-oil recovery system.
Organics are removed  in the light-oil recovery system, and a  slipstream
of debenzolized wash  oil is recirculated to  the top of the spray
scrubber.1   The debenzolized wash oil is removed from the hot side of
the wash-oil heat exchanger at about 110° C  (230° F) and enters the
scrubber as  hot wash  oil.  Plant personnel could not explain why hot
wash oil was used instead of cooled wash oil at 32° C (90° F).  Hot
wash oil has a much lower solubility for benzene (boiling point =
80° C) and other volatile compounds than cool wash oil has.
     The diameter of  the vent lines range from 7.6 cm (3 in.) to 15 cm
(6 in.).  The 7.6-cm  (3-in.) vents from the  ammonia liquor storage
tank and sump combine at a 10-cm (4-in.) line that enters the base of
the scrubber.  Each of the tar tanks has a 15-cm (6-in.) vent line
that enters the base  of the scrubber.i
4.4.3  Control  Efficiency
     No emission test results or estimates were available for the
control  efficiency of the wash-oil  scrubber at the Houston plant.   The
low solubility of benzene in the hot wash oil,  which is  above the
                                  4-24

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boiling point of benzene, indicates that this scrubber was not designed
for control of benzene emissions.  The solubility of benzene in hot
wash oil at 110 to 130° C is only 5 to 10 percent of the solubility of
benzene in cool wash oil at 25 to 30° C.  The hot wash oil that enters
this scrubber is near the temperature that is used to strip (remove)
benzene, toluene, and xylene from the benzol ized wash oil in the
wash-oil still.  These factors lead to the conclusion that the scrubber
with hoj: wash oil would not control benzene emissions.
     Many factors in the design and operation of a scrubber affect its
performance.  The rate and efficiency of absorption at constant pressure
depend on (1) the chemical and physical properties of the solvent
(wash oil) and the solute (benzene or light oil), (2) the operating
temperature, (3) the contacting efficiency of the column, and (4) the
gas and liquid flow rates.
     The type of scrubber and packing also affect control efficiency.
In unpacked scrubbers, the gas is in contact with droplets of wash oil
sprayed into the top of the chamber.  These spray scrubbers have the
advantage of a very low pressure drop, and they do not foul by sludge
accumulation on packing or bubble trays.  Demisters often are added at
the top of the spray chamber to remove liquid droplets entrained in
the countercurrent gas flow.  Packing could be used in the lower part
of a spray chamber to increase the surface area available for mass
transfer and reduce the backmixing due to turbulent air currents.
Packed-bed scrubbers are more suitable for storage vessels that do not
contain tar in the gas than for dirty gases that could foul the packing.
Packed-bed scrubbers can be designed with very low pressure drops,
depending on the type of packing, the gas and liquid flow rates, and
the required benzene removal efficiency.
     Two important factors influence the rate and efficiency of benzene
absorption in a spray chamber.   The first factor is the amount of
benzene vapor absorbed by the wash oil at equilibrium.  This quantity
can be represented by the partition factor, K, which has been expressed
in the literature as the concentration of benzene in the wash oil
divided by the concentration of benzene in the vapor at equilibrium,
where the units of concentration are the same for both phases.   Parti-
                                 4-25

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tion factors for benzene and xylene in wash oil are given in Table 4-2
as a function of temperature.11  The partition factor for benzene
decreases with increasing temperature; i.e., benzene is less soluble
in wash oil at higher temperatures than at lower temperatures.   The
fairly high values of K shown in Table 4-2 indicate that benzene is
quite soluble in wash oil.   Other light-oil components such as xylene
are more soluble than is benzene in wash oil at a given temperature;
i.e., they are more strongly partitioned (separated) from the gas into
the liquid.
     The second major factor affecting control of benzene emissions is
scrubber's contacting efficiency.  One measure of this efficiency is
the number of theoretical equilibrium stages provided by the scrubber.
A theoretical stage is an operation in which liquid and gas phases are
brought into contact with each other such that the two phases are in
equilibrium after the operation.  A number of theoretical stages may
be required to attain a specified separation or removal efficiency.
The number of theoretical stages is thus a measure of a particular
scrubber's effectiveness for benzene removal.  For example, the benzene
concentration in the vapor leaving the top of the scrubber would be in
equilibrium with the wash oil leaving the bottom of the scrubber if
the scrubber were equivalent to only one theoretical stage.  For a
scrubber with a performance greater than that obtained with one theore-
tical stage, the vapor phase benzene concentration leaving the scrubber
would be lower.   The number of theoretical stages in a particular
scrubber design is a function of the four factors previously listed.
     Table 4-3 illustrates the percent control of benzene in a wash-oil
spray chamber using the theoretical relationship developed by Lowry.11
The parameter KL/G is the product of the partition factor (K),  the
liquid rate (L), and the gas rate (G), in consistent units.  Table 4-3
indicates that benzene removal efficiency increases when KL/G increases,
even with a low number of theoretical stages.  Scrubber design can be
optimized through cooling the wash oil or gas (increases K), increasing
the wash oil flow rate (increases L), or modifying the design and
adding packing (increases the number of theoretical stages).
                                  4-26

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               TABLE 4-2.   PARTITION FACTORS FOR BENZENE
                       AND XYLENE IN WASH OIL11
Temperature
(°C)
25
80
130
Partition factor, K
(liquid concentration/gas concentration)3
Benzene
650
114
36.4
Xylene
7,570
716
170
aSame concentration units must be used (e.g., g benzene/L wash oil
 and g benzene/L gas)
              TABLE 4-3.   PERCENT CONTROL OF BENZENE IN A
                       WASH-OIL SPRAY CHAMBER11
KL
G
0.5
1.0
1.5
2.0
5.0
10.0
20.0

1
33.3
50.0
60.0
66.0
83.3
90.9
95.2
Number of theoretical
2
42.9
66.0
78.9
85.0
96.8
99.1
99.8
equil ibrium
5
49.2
83.0
95.2
98.0
100.0
100.0
100.0
stages
.10
50.0
91.0
99.4 '
99.9
100.0
100.0
100.0
K = partition factor, liquid concentration/gas concentration.
L = wash-oil flow rate, in units consistent with K and G.
G = vent gas flow rate, in units consistent with K and L.
                                 4-27

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     A small-scale study of variables affecting benzene absorption
from air by petroleum wash oil in a spray tower has been reported with
approximately 30 to 90 percent benzene recovery.i2  The benzene removal
was found to be a function of the gas flow rate, the liquid flow rate,
and the height of the spray chamber.  In practical wash-oil spray
systems for by-product plant applications, higher recovery rates can
be obtained when scrubber design is altered.  For example, the diameter
of the wash-oil droplet could be decreased from the 1.5 to 2.0 mm in
diameter in the study, the length of the scrubbing chamber can be
increased from the 1.4-m reported length, and the wash-oil flow rate
can be increased.
     Engineering design calculations were performed to examine the
potential application of wash-oil scrubbers to storage tanks holding
light oil, BTX, benzene, and ammonia liquor.13 14  The calculations
were based on the following worst case assumptions:   (1) maximum gas
feed rate to the scrubber of 19 £/s (40.1 ftVmin) resulting from a
maximum anticipated liquid displacement rate of 19 H/s (300 gal/min);
(2) a maximum gas phase benzene concentration of 17 percent by volume
(corresponding to storage of pure benzene liquid at 90° F); and
(3) maximum scrubber operating temperature of 90° F.   Two other design
parameters assumed, not falling in the category of "worst case," were
the following:  (1) the spray nozzle that distributes wash oil within
the column produces a mean droplet diameter of 1 mm;  and (2) the
smallest droplet produced by the same nozzle has a diameter of 0.2 mm.
These calculations indicated that a wash-oil scrubber with an 8-in.
inner diameter, an active height of 13 ft, and a wash-oil (solvent)
feed rate of 0.5 gal/min will achieve a continuous benzene control
efficiency of at least 90 percent from these sources.
     For sources with gas phase benzene concentrations of less than
17 percent and for smaller gas phase (vent system) flow rates, smaller
scrubbers with correspondingly lower wash-oil feed rates can be designed.
However, a scrubber of the design summarized above will ensure that
90 percent efficiency is achieved at design (worst-case) conditions
and that the benzene concentration in the absorber offgas stream can
be maintained at or below the design level.
                                  4-28

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     The previous discussion indicates that high control efficiencies
can be obtained and have been demonstrated for wash-oil scrubbers.
Based on data presented by Lowry, properly designed and operated
wash-oil scrubbers theoretically can provide benzene control effi-
ciencies of 95 percent or greater; however, the highest known control
efficiency demonstrated so far is 90 percent.  Supplemental cooling
may be required to obtain a 90-percent control efficiency for sources
with heated vapors.  The cooling may be supplied by indirect heat
exchange (e.g., shell in tube condenser) or by using a sufficiently
high flow rate of cool wash oil.
                                  4-28a

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4.5   ENCLOSURE
      Control  of  emissions  from  the  light-oil  sump can be accomplished
by covering the  sump  to  reduce  evaporative  losses.  Most sumps in
by-product plants are pits  that receive  liqyid streams from various
processing steps.  The liquid surface  for most sumps is uncovered and
completely open  to the atmosphere;  however, a few plants have covered
or partially  covered  sumps.  Enclosure is accomplished by installing a
steel cover,  sealing  the cover,  and adding  access manways and a vertical
vent.   In such an installation,  the edge of the sump cover would rest
in a  trough around the edge of  the  sump, and a gasket material in the
trough  would  prevent  emissions  from the edge of the sump cover.
      This enclosure procedure is the same as that described in Subsec-
tion  4.4.2 for the Armco,  Inc.,  plant's ammonia liquor sump.  At this
plant,  the sump was covered with a  1-cm (0.375-in.) steel cover and
gasket.  Access manways were installed in the steel cover to provide
ready access  for maintenance, cleaning, and visual inspection.1
      The purpose of the sump cover  is to protect against wind that
might blow benzene vapors out of the sump into the environment.  For
example, emissions from an  open  light-oil sump were measured as 56 kg
of benzene per day, suggesting  that the equivalent of approximately
146,000 £ per day of  saturated  benzene vapors are blown from the
sump.15  Enclosing the sump would limit emissions primarily to working
losses  (from  increasing the liquid  level in the sump) and breathing
losses  (from  increasing the temperature of the liquid in the sump).
The control efficiency of a sump cover is difficult to determine and
depends upon many factors,  such as wind speed, temperature,  benzene
concentration, and liquid throughput.   For sumps operated at or near a
constant liquid level, a 98-percent control  efficiency is estimated
for a tight cover compared to the uncontrolled situation with wind
blowing across the exposed  liquid surface.
4.6  CONTROL OF COOLING TOWER AND NAPHTHALENE-HANDLING EMISSIONS
     By-product plants that recover light oil  cool  the coke  oven gas
from 60° C to 25° C in an operation called final  cooling.   The purpose
of the final  cooler is to lower the gas temperature before the coke
                                 4-29

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oven gas enters the wash-oil scrubbers to improve absorption efficiency
and to optimize light-oil recovery.  Three forms of final cooling
generally are used by the industry and, depending on the type, the
nature and quantity of benzene emissions are quite different.
     Approximately 23 plants with about 43 percent of the total U.S.
coke capacity use a process called direct-water final cooling.  In
this process, the coke oven gas is cooled by direct contact with
water, naphthalene and other organics condense in the water, naphtha-
lene is removed by physical separation, and the water is recycled
through a cooling tower back to the final cooler.  Because some benzene
condenses and is removed with the direct-contact water, benzene emissions
result from the naphthalene/water separation and from the cooling
tower as air strips the residual benzene from the cooling water.  The
direct-water final cooler produces much greater benzene emissions than
do the other two processes; for this reason, the direct-water final
cooler will represent the uncontrolled case for benzene emissions from
the cooling tower and naphthalene handling.
     The demonstrated control technology for these emissions is based
on the other two major final cooling processes; i.e., the tar-bottom
final cooler and the wash-oil final cooler.  These two final cooling
processes will be discussed as control alternatives for the uncontrolled
case represented by the direct-water final coolers.
4.6.1  Tar-bottom Final Cooler
     The tar-bottom final cooler is used by approximately 18 by-product
recovery plants.  The coke oven gas is cooled by direct contact with
water, but the water is then sent through tar in the bottom of the
final cooler.  The tar removes naphthalene and some other organics
from the water, the tar and water are separated, and the water is then
cooled in a cooling tower.  The tar-bottom cooler does not eliminate
benzene emissions from the cooling tower, but it does eliminate benzene
emissions from the physical separation of naphthalene and water.  The
naphthalene remains with the tar and is sold, or it may be removed in
a tar-refining operation.
     A plant would not need to replace the direct-water final cooler
with a tar bottom to obtain the benefits of a tar-bottom final cooler.
                                  4-30

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A one-stage mixer-settler containing tar could be inserted into the
final cooling process to remove naphthalene from the direct-contact
water.  At a scale of 4,000 Mg of coke per day, with a 20° C increase
in water temperature through the final cooler, approximately 4,800 Mg
of cooling water per day is required for final cooling and should
contact a roughly comparable quantity of tar.  The daily production of
whole tar for this size plant is about 160 Mg, about 30 Mg of which is
light tar.  Because light tar is cleaner and less viscous than whole
tar is, light tar is more desirable for use in a tar mixer-settler.
If the light tar is recirculated from the settler at a rate 100 times
the production rate, the effective tar circulation rate is 3,000 Mg/day.
The combined stream of 4,800 Mg/day of water and 3,000 Mg/day of tar
could be forced through an orifice-plate mixer and into a tar settler
or decanter.  The settler should provide a residence time of 30 minutes,
with a vent back to the gas exiting the final cooler.  The water will
be circulated from the settler to the cooling tower in the usual way.
A sketch of this retrofit design for a tar-bottom final cooler is
presented in Figure 4-7.
     In Chapter 3, benzene emissions from the cooling tower were
estimated as 270 g/Mg coke for a direct-water final cooler and
70 g/Mg coke for a tar-bottom final cooler.   A control efficiency of
74 percent is thus estimated for cooling tower emissions through the
installation of a tar mixer-settler or tar-bottom process.   Naphthalene
handling and processing are eliminated; therefore, the control  efficiency
is estimated as 100 percent for these emission sources.
4.6.2  Wash-oil Final Cooler
     Available data indicate that five by-product recovery plants use a
wash-oil final cooler.   The coke oven gas is cooled by direct contact
with cool wash oil, which also removes the naphthalene.  The wash oil
is circulated through an indirect heat exchanger, cooled, and then
returned to the final cooler.   A slipstream of the wash oil  containing
naphthalene is routed to light-oil  recovery, and a makeup stream of
lean wash oil is added back to the final  cooler circulation loop.
                                  4-31

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     The wash-oil  final  cooler  eliminates  emissions  from  naphthalene
 handling because the  naphthalene  is  removed  in  the wash oil.  Benzene
 emissions  from the cooling tower  of  a  direct-water or tar-bottom  final
                                                          !
 cooler also are eliminated.  This final cooling process effectively
 eliminates the benzene emissions  associated  with  a direct-water final
 cooler by  cooling  the wash oil  with  indirect (noncontact) heat exchange
 and eliminating the need for a  cooling tower.
     A wash-oil final cooler has  been  retrofitted at the  Sparrows
 Point plant of Bethlehem Steel  Corporation.3  Figure 4-8  contrasts the
 process flow diagram  of  a direct-water and wash-oil  final cooler.
 Although some existing process  lines could be used,  conversion of a
 direct-water final cooler to a  wash-oil final cooler would require the
 installation of new process equipment.  In addition, the  final cooler
 probably would have to be retrofitted  with new  spray nozzles, pumps,
 and piping.
     The control efficiency of  a  wash-oil final cooler compared to the
 uncontrolled case  of  a direct-water  final cooler  is  estimated as
 100 percent for emissions from  both  the cooling tower and naphthalene
 handling.  This efficiency is obtained by eliminating the cooling
 tower and  the physical separation  of naphthalene  in  the final cooling
 process.
 4.7  ALTERNATIVE CONTROL  TECHNIQUES
     This  section will discuss  control techniques that have been
 demonstrated in a  few specific  applications  in by-product recovery
 plants and others  that are candidates  for technology transfer from
 other industries.   These  controls  are  discussed separately,  and the
 applicability of two controls operating in series is also discussed as
 a method for improving overall  control efficiency.
 4.7.1  Venting to the Suction Main
     The suction main is that part of the coke oven gas main between
 the Askania regulator and exhausters that is maintained at a negative
 pressure of -200 to -300 mm of water.  The exhausters provide the
motive force for the coke oven  gas by pulling the gas (negative pressure)
                                 4-33

-------
WATER
WASH OIL
1
	 .t 	 1 	 , COKE OVEN GAS TO
j | LIGHT-OIL SCRUBBER
j r^
: FINAL j
! COOLER j
1 •
COKE OVEN !
GAS FROM |
AMMONIA ! j
ABSORBER
NAPTHALENE
WATER
SLURRY
1 r
NAPTHA
J"~ HANOI
1
NAPHTH
i t
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WELL WELL
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COOLING
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WASH OIL
j ' | 1 t
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"[""-*{ EXCHANGER l"""! TANK T~ ^HT-O.L STILL
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i
WATER TO
WASTEWATER
TREATMENT
                                                 	WASH-OIL FINAL COOLER
                                                 	  DIRECT-WATER FINAL COOLER
                                                 	COMMON UNITS

  Figure 4-8. Conversion of a final cooler from water to wash oil cooling medium.
                                 4-34

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through the suction main and primary coolers ^nd by pushing the gas
(positive pressure) through the by-product recovery processes downstream
of the exhausters.  Emission control could be accomplished by enclosing
the source to accept a negative pressure without leakage inward and
then connecting the vent line to the suction line at the primary
coolers.  Emissions would enter the by-product recovery process, and
pollutants would be removed with the by-products or incinerated with
the coke oven gas.
     The Houston plant of Armco, Inc., used a negative-pressure system
to control emissions from three tar-collecting tanks.   The system was
installed between 1976 and 1977 and was operated without difficulty
until the coke battery shut down in 1981.   A simplified schematic of
the system is shown in Figure 4-9.   Vent lines on each of the horizontal
tanks were 10 cm (4 in.) in diameter and were connected to a common
vent line that was 15 cm (6-in.) in diameter.  The 15-cm common vent
was connected to the 91-cm (36-in.) suction main at the primary coolers
where the normal operating pressure was -200 to -300 mm of water.
Atmospheric vents, three-way valves, and steam-out connections were
installed at each tank, and all of the vent lines were steam traced
and insulated.1
     Armco personnel indicated no problems with the negative pressure
system but expressed reservations about the potential  for oxygen
infiltration and the resulting explosion hazard.1  For example, if a
significantly large leak developed in the tank or if the atmospheric
vent were inadvertently left open,  air could mix with the coke oven
gas in the main.  Normally the coke oven gas is maintained above its
upper explosive limit; however, if a significant quantity of air were
introduced, the coke oven gas might be between the upper and lower
explosive limits.  This would result in an explosive mixture exposed
to continuously arcing tar precipitators located downstream of the
exhausters.  The operator's preference would have been to blanket
these tar-collecting tanks with positive-pressure gas from the collecting
main.1
                                4-35

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                      -*•
               15 cm
       Atmospheric
          Vent
                                Suction Main
                            at Primary Coolers  (91 cm)
                                 10 cm
                                                           Steam-Out
                                                          Connection
                               Tar-Collecting Tanks
                  SYMBOLS
                    Cf[  Three-way valve

                        Steam-out connection

                        Gate valve

                        Atmospheric vent
Figure 4-9.  Negative-pressure system from tar-collecting tanks to suction main?
                                     4-36

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     Many industry commenters have expressed concern about the safety
hazard associated with negative-pressure systems.  However, the use of
negative pressure on tanks is not unusual.   For example, every coke
plant has a primary cooler, which is in effect a large tank, and each
primary cooler operates at a negative pressure.  The concern is not
the existence of negative pressure in the tank, but rather that the
tank be designed for safe operation under negative pressures.   The
choice of a positive- or negative-pressure system is probably best
made by the operator who must consider the condition and operation of
a specific vessel, the costs, and the safety aspects of each system.
The control efficiency of a negative-pressure control system is analogous
to that of positive-pressure systems, which is approximately 98 to
99 percent.
4.7.2  Vapor Condensation
     Although vapor condensation is not typically used for air pollution
sources at by-product plants, benzene vapors that escape from storage
tanks and process vents conceptually can be recovered with a condenser.
It is not anticipated that many of the by-product plant benzene sources
will be controlled through vapor condensation because condensation is
only moderately effective, and supplemental systems such as carbon
adsorption would be required for the 98+ percent control achievable
with other control techniques.
     Two types of condensers are shown in Figures 4-10 and 4-11.
Figure 4-10 shows a simple surface condenser, and Figure 4-11 illus-
trates a two-state condenser that can be operated at a lower temper-
ature and consequently a higher control efficiency.
     Condensation occurs when the condensible's partial pressure and
vapor pressure are equal.  Removal efficiencies depend on the inlet
concentrations of condensibles.  When the gas is saturated with hydro-
carbons; e.g., light-oil condenser vent gas, refrigeration up to
-73° C may yield removal efficiencies up to 96 percent.7  Complete
condensation is not possible because performance is limited by the
equilibrium partial pressure of the vapor stream.  Consequently,
condensers often are used in combination with other control equipment
such as incinerators, carbon adsorption units, or absorption units.
                                 4-37

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                           HARM ORGANIC
                           LIQUID STREAM
                                                          CONOENSATE
                                                          RETURN
                 Figure 4-10. Surface condenser unit used on a tank handling
                               warm volatile, organic materials.16
CONDENSER
   AIR
(PRECOOLER)
                                                             PRECOOLEH
                                                                          DISCHARGE FROM UNIT
 CONDENSER
    AIR
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PHECOOLER
REFRIGERATION
UNIT
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REFRIGERATION
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                                                                                        COOLING
                                                                                       -RECOVERY
                                                                                        SECTION
                                                                                        VAPOR
                                                                                        CONDENSED
                                                                                        SECTION
                                                   y^
                                                    HYDRO-
                                                    CARBON
                                                    —*• WATER

                        Figure 4-11. Refrigeration vapor recovery unit.17
                                             4-38

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     The presence of noncondensible gases in storage tanks, sumps, and
the tar decanter is a major factor affecting condenser performance
when the condenser is applied to these sources.  Air or nitrogen can
blanket the condenser surface so the added thermal resistance reduces
the condensation coefficients up to 50 percent.16  Factors that often
affect condenser performance include sizing (surface area, coolant
flow rate, and temperature), variation in vapor temperature and partial
pressure, and fouling from particulate matter such as tar or a frozen
component.  For example, tar and naphthalene are expected in the tar
decanter and dewatering emissions.  In addition, benzene freezes at
5.5° C; therefore, the condenser must include a means for removing
frozen benzene from the condenser if high separation efficiencies are
to be obtained by very low operating temperatures.
     Benzene vapor can be removed from a vapor stream at an estimated
60-percent efficiency by a surface condenser operating at 7° C, assuming
the vapor inlet and outlet are saturated with benzene.   This operating
temperature prevents freezing of the benzene vapor.  A two-stage
system that combines a preliminary condenser operating at 6° C, followed
by a final condenser operating at -73° C, can increase the overall
benzene control efficiency to 99 percent.18  Benzene and water vapor
are collected on the condenser fins and can be removed by reheating to
6° C.  An emission level of 10 ppm benzene vapor is possible if the
inlet vapor concentration is 1,000 ppm benzene.  These systems have
not been demonstrated in by-product recovery plants.   Because of the
presence of both noncondensibles and readily condensible components
(e.g., tar, naphthalene) in by-product plant emissions, the control
efficiency is expected to be less than that stated above for by-product
plant sources.
4.7.3  Adsorption
     Hydrocarbons in a gas or vapor may be adsorbed and retained on
the surface of a granular solid.  Organic vapor recovery by adsorption
is used widely by industry, and complete turn-key adsorption systems
are available from many manufacturers.   Activated carbon is useful for
                                4-39

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benzene recovery from moisture-laden by-product plant emissions because
it can adsorb organic gases and vapors when water vapor is in the gas
stream.14
     Adsorbers can have fixed, moving, or fluidized beds.7  The simplest
fixed-bed adsorber is a vertical, cylindrical vessel fitted with a
perforated supporting carbon screen (see Figure 4-12).  The cone-shaped
carbon bed allows more surface area for gas contact and accommodates
high gas flow rates at a lower pressure drop than does a flat-bed
adsorber.  If more than one carbon bed in a single unit is used, the
beds usually are arranged as shown in Figure 4-13.  For a continuous
process operation, a minimum of two fixed-bed units in parallel operation
is recommended so that one unit is adsorbing while the other is being
steam stripped of solvent and regenerated (see Figure 4-14).   Moving-bed
adsorbers move the adsorbent in and out of the adsorption zone, thus
increasing the adsorbent's efficiency.  However, disadvantages of this
system include wear on moving parts, attrition of the adsorbent, and
lower steam utilization efficiency that results from the shorter beds.
The fluidized bed adsorber contains a number of shallow fluidized beds
where the organic vapor fluidizes the activated adsorbent.   A high
loading of the solvent into the adsorbent can be maintained in this
unit, thus reducing the steam requirements for regeneration.   Desorbed
material can be vented to the gas main, collected by a condenser, or
eliminated by any of the other control techniques discussed in this
chapter.
     Vacuum regeneration can be used instead of steam regeneration to
eliminate the problem of disposal of a wastewater stream created by
steam regeneration.19  In this application,  the carbon bed is under a
vacuum caused by a liquid ring seal pump.   Desorbed organic vapor is
condensed by indirect cooling.
     When an air vapor mixture is passed over carbon,  adsorption is
100 percent at the beginning,  but when the retentive capacity (ratio
of the weight of the adsorbate retained to the weight of the  carbon)
is reached,  traces of benzene  appear in the  exit air.   In the control
of a benzene atmospheric discharge, the adsorption cycle should stop
                                  4-40

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                                                                                   VIPOB 10 COMHNSIH
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Figure 4-12. Sketch of a vertical adsorber with
                 two cones.16
Figure 4-13. Cross-section of an adsorber with
        four beds of adsorbed carbon.16
                         Figure 4-14. Sketch of a two-unit, fixed-bed adsorber.16
                                                  4-41

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at the first break point as determined by the detection of benzene
discharge.  In general, fixed-bed adsorbers are not installed to
remove organics when the vapor-laden stream contains less than 3.2 kg
of solvent per 1,000 stdm3 of gas (0.2 Ib per 1,000 dry stdft3) or
when the organic concentration is greater than 25 percent of the lower
explosive limit of the mixture.20
     Carbon adsorption is not known to be used at by-product recovery
plants for control of vapor emissions.  For vapor emissions from
light-oil or benzene stqrage tanks, the technology transfer should be
straightforward.  Other by-product emission streams containing tar and
naphthalene may not be suitable candidates for technology transfer
because of potential fouling and regeneration difficulties.
4.7.4  Absorption
     The application of a wash-oil scrubber to absorb benzene from
vented vapors was discussed in Subsection 4.4.  This subsection
discusses alternative absorption systems that have not been demon-
strated in by-product recovery plants.  These systems are candidates
for technology transfer and offer alternative techniques that may
achieve a result similar to the wash-oil scrubber.  In general, the
factors discussed in Subsection 4.4 that affect control efficiency of
absorption are applicable here and will not be repeated.
     The discussion of wash-oil scrubbers was based primarily on an
unpacked scrubber with a spray of wash oil.  The gas-liquid contact in
other scrubber designs has been accomplished by several types of
equipment, including packed towers (see Figure 4-15), spray towers,
bubble cap tray towers (see Figure 4-16), jet scrubbers, and venturi
absorbers (see Figure 4-17).  The majority of industrial applications
absorb gas with a packed or plate tower instead of an agitated vessel
(gas dispersed by a sparger system into a liquid-filled vessel), spray
chamber, or venturi scrubber.   Collecting efficiencies depend on the
absorber type and scrubbing liquor.16
     For emission streams that would not foul the packing, these
scrubber designs could provide a higher control efficiency than would
a simple, unpacked spray scrubber.  Potential applications in the
by-product recovery plant include light-oil and benzene storage tanks.
                                  4-42

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                                      CLEAN GAS
Figure 4-17. Venturi absorber with cyclone-type liquid separator
       (Chemical Construction Corp., New York, N.Y.).16
                            4-44

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     Another control option is to combine absorption with another
control technique.  The Vapor Control Company of Houston, Texas,
markets a unit that can use a combination of absorption and refriger-
ation for benzene removal.  The liquid absorber is chilled and contacts
the vapor steam in a countercurrent packed scrubber.  The system would
strip the benzene in a regenerator, using a heat exchanger to reduce
energy requirements.  Levels of hydrocarbon vapors as low as 1,000 ppmv21
can be obtained in the exit gas, which would provide 99 percent removal
of benzene if the inlet gas contained 100,000 ppmv benzene.  The only
by-product plant source where benzene concentrations of this magnitude
were measured is the light-oil condenser vent.  In addition, pure
benzene storage tanks would have an equilibrium vapor pressure of
130,000 ppmv at 26° C.
4.7.5  Vapor Destruction
     The discussion of gas blanketing in Subsection 4.2 included the
use of the coke oven gas combustion system for vapor destruction.  If
the coke plant operator chooses not to use the existing combustion
system, an incineration device may be retrofitted for vapor destruction.
     A thermal afterburner can be installed to incinerate benzene
vapors.  The process exhaust system or a blower delivers the organic
vapor stream to a refractory-lined burner area.  The gases are mixed
thoroughly with the burner flames and are passed through the remaining
part of the chamber where combustion is completed.7  This technology
has been demonstrated for gasoline vapors and has been tested for
benzene vapors.17  One significant advantage is that a wide range of
hydrocarbons can be destroyed; a disadvantage is that potentially
valuable compounds are not recovered.  However, the fuel value of the
hydrocarbons is recovered when heat recovery is practiced.
     The major factors affecting afterburner performance are residence
time to complete combustion, temperature, and vapor velocity.  A
minimum residence time of 0.3 to 0.5 s is recommended with vapor veloc-
ities of 7.6 to 16.2 m/s to ensure good mixing without quenching the
flame.  The required discharge temperature varies depending on the
organic compound, but it is usually between 538° to 816° C.16  If
                                  4-45

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combustion is inhibited by low temperature, low residence time, or poor
mixing, carbon monoxide, aldehydes, and other products of incomplete
combustion result.   Maximum efficiency occurs when all combustible
matter passes through the burner at the proper temperature.7
     Properly designed and operated thermal afterburners usually
achieve organic vapor removal efficiencies in excess of 95 percent,
and efficiencies of up to 99 percent have been reported for gasoline
vapors
       7 8
            In general, efficiency improves with increasing operating
temperature, flame contact, and residence time.  An afterburner rarely
attains 90 percent efficiency in removing combustibles below 700° C if
there is residual carbon monoxide.16  Thermal incineration of benzene
vapors at temperatures of 760°' to 816° C reportedly can limit benzene
emissions in the tail gas to as little as 10 ppmv.19
4.7.6  Vapor Balance Systems
     A vapor balance system uses a variable vapor space to contain the
vapors produced in storage tanks.   For example, the vents from product
storage tanks with similar products can be combined into a vapor
reservoir tank.  The vapor reservoir tank can be either a lifter-roof
type or an internal diaphragm type that accumulates displaced vapors.16
When liquid is pumped into a storage tank, the displaced vapors are
collected in the vapor reservoir by increasing the vapor space in the
reservoir (i.e., the roof is lifted or the diaphragm is raised).   If
the pressure limitations of the storage tank and vapor reservoir are
exceeded, the vapors are vented through a pressure relief device.
These vented emissions must be recovered or destroyed to obtain a
control efficiency analogous to gas blanketing.16
     The equipment modifications,  three-way valves, heat tracing and
insulation, and other requirements for gas blanketing would also be
required for a vapor balance system.   The emission sources must be
enclosed to accept the slight, positive pressure .of the system.   If
provision is made to handle excessive vapors that exceed the capacity
of the balance system, a control efficiency equal to that of gas
blanketing could be obtained.   In  a by-product plant, the excess
                                  4-46

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vapors could be returned to the by-product recovery process or to the
gas combustion system.  No details are available on the use of vapor
balance systems in by-product recovery plants.
4.8  CONTROLS FOR FUGITIVE EMISSIONS FROM EQUIPMENT COMPONENTS
     In Chapter 3, fugitive emissions from leaking process equipment
are discussed.  These equipment items include valves, pumps, exhausters,
open-ended lines, sampling systems, safety relief valves, and flanges.
Techniques for controlling emissions from these sources include leak
detection and repair programs and equipment specifications.  In some
cases, the techniques for controlling these emissions in by-product
recovery plants are based on transfer of control technology as applied
to related industries, such as petroleum refineries and chemical
plants.  This approach is possible because the related industries use
similar types of equipment.  There may be differences between by-product
recovery plants and related industries in average line temperatures,
product composition, and other parameters.  However, these differences
do not significantly influence the applicability of the techniques
used in controlling the fugitive emissions.
     The major reference for the following discussions is the preliminary
draft of the  background information document  (BID) for volatile organic
compounds (VOC's) in the petroleum refinery industry.22  When a reference
number appears in the title of a particular subsection, the entire
discussion in that subsection is attributed to that reference.
4.8.1  Leak Detection and  Repair Methods22
     Leak detection and repair methods can be applied in order to
reduce fugitive emissions  from by-product plant sources.   Leak detec-
tion methods  are  used to identify equipment components that are emit-
ting significant  amounts of benzene.  Emissions from leaking sources
may be reduced by three general methods:  repair, modification, or
replacement of the source.
     4.8.1.1   Leak Detection Techniques.  Various monitoring techniques
that can be used  in a leak detection program  include individual component
surveys, unit area (walk-through) surveys, and  fixed-point  monitoring
systems.  These emission detection methods would yield qualitative
indications of leaks.
                                4-47

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     4.8.1.1.1  Individual  component survey.22  Each fugitive emission
source (pump, valve, compressor, etc.) is checked for leakage in an
individual component survey.   The source may be checked for leakage by
visual, audible, olfactory, soap solution, or instrument techniques.
Visual methods are good for locating liquid leaks, especially pump
seal failures.  High-pressure leaks may be detected when the escaping
vapors are audible, and leaks of odorous materials may be detected by
smell.  Predominant industry practices are leak detection by visual,
audible, and olfactory methods.   However, in many instances, even very
large leaks are not detected by these methods.
     Applying a soap solution on equipment components is one individual
survey method.  If bubbles are seen in the soap solution, a leak from
the component is indicated.  The method requires that the observer
subjectively determine the rate of leakage based on formation of soap
bubbles over a specified time period.  The method is not appropriate
for very hot sources, although ethylene glycol can be added to the
soap solution to extend the temperature range.  This method is also
not suited for moving shafts on pumps or compressors, since the motion
of the shaft may cause entrainment of air in the soap solution and
indicate a leak when none  is present.  In addition, the method cannot
generally be applied to open sources such as relief valves or vents
without additional equipment.
     The use of portable hydrocarbon detection instruments is the best
known  individual survey method for identifying leaks of VOC's from
equipment components because it is applicable to all types of sources.
The instrument  is  used to  sample and analyze the air in close proximity
to the potential leak surface by traversing the sampling probe tip
over the entire area where leaks may occur.  This sampling traverse is
called "monitoring" in subsequent descriptions.  A measure of the
hydrocarbon  concentration  of the sampled air  is displayed in the
instrument meter.
     4.8.1.1.2  Unit area  survey.22  A unit area or walk-through
survey entails  measuring the ambient concentration within a given
distance; e.g., one meter, of all equipment located on ground levels
                                4-48

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and other accessible levels within a processing area.  These measure-
ments are performed with a portable VOC detection instrument utilizing
a strip chart recorder.
     The instrument operator walks a predetermined path to assure
total available coverage of a unit on both the upwind and downwind
sides of the equipment, noting on the chart record the location in a
unit where any elevated VOC concentrations are detected.  If an ele-
vated VOC concentration is recorded, the components in that area can
be screened individually to locate the specific leaking equipment.
     It is estimated that 50 percent of all significant leaks in a
unit are detected by the walk-through survey, provided that there are
only a few pieces of leaking equipment, thus reducing the VOC back-
ground concentration sufficiently to allow for reliable detection.
     The major advantages of the unit area survey are that leaks from
accessible leak sources near the ground can be located quickly and
that the leak detection manpower requirements can be lower than those
for the individual component survey.  Some of the shortcomings of this
method are that VOC emissions from adjacent units can cause false leak
indications; high or intermittent winds (local meteorological condi-
tions) can increase dispersion of VOC, causing leaks to be undetected;
elevated equipment leaks may not be detected; and additional  effort is
necessary to locate the specific leaking equipment,  i.e.,  individual
checks in areas where high concentrations are found.
     4.8.1.1.3  Fixed-point monitors.22  This method consists of
placing several automatic hydrocarbon sampling and analysis instru-
ments at various locations in the process unit.   The instruments may
sample the ambient air intermittently or continuously.   Elevated
hydrocarbon concentrations indicate a leaking component.   As  in the
walk-through method, an individual  component survey is required to
identify the specific leaking component in the area.   Leaks from
adjacent units and meteorological conditions may affect the results
obtained.   The efficiency of this method is not well  established,  but
it has been estimated that 33 percent of the number of leaks  identi-
fied by a complete individual  component survey could be located by
                                  4-49

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fixed-point monitors.   These leaks would be detected sooner by fixed-
point monitors than by use of portable monitors, because the fixed-
point monitors operate semi-continuously.   Fixed-point monitors are
more expensive, multiple units may be required, and the portable
instrument is also required to locate the specific leaking component.
Calibration and maintenance costs may be higher.  Fixed-point monitors
have been used to detect emissions of hazardous or toxic substances
(such as vinylchloride) as well as potentially explosive conditions.
Fixed-point monitors have an advantage in these cases, since a partic-
ular compound can be selected as the sampling criterion.
     4.8.1.1.4  Visual inspections.22  Visual inspections can be
performed for any of the leak detection techniques discussed above to
detect evidence of liquid leakage from plant equipment.  When such
evidence is observed, the operator can use a portable VOC detection
instrument to measure the VOC concentration of the source.  In a
specific application, visual inspections can be used to detect the
failure of the outer seal of a pump's dual mechanical seal system.
Observation of liquid leaking along the shaft indicates an outer seal
failure and signals the need for seal repair.
     4.8.1.2  Repair Techniques.22  When leaks are located by the leak
detection methods described in this subsection, the leaking component
can then be repaired or replaced.  Many components can be serviced
on-line.  This is generally regarded as routine maintenance to keep
operating equipment functioning properly.  Equipment failure, as
indicated by a leak not eliminated by servicing, requires isolation of
the faulty equipment for either repair or replacement.
     4.8.1.2.1  Pumps.  Most critical service process pumps a,re backed
up with a spare so that they can be isolated for repair.  Of those
pumps that are not backed up with spares, some can be corrected by
on-line repairs (e.g., tightening the packing).  However, most leaks
that need correction require that the pump be removed from service for
seal repair.
     4.8.1.2.2  Valves.  Most valve leaks can be reduced on-line by
tightening the packing gland for valves with packed seals or by lubrication
                                   4-50

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for plug valves, for example.  Various valve maintenance programs have
been performed by EPA and refinery personnel.  Union Oil Company and
Shell Oil Company each conducted studies at their California refineries
on maintenance of leaking valves.  Emission rates were estimated based
on screening value correlations.  EPA studied the effects of maintenance
on fugitive emissions from valves at four refineries.  Each valve was
sampled to determine emission rates before and after maintenance to
evaluate emission reductions.  In a separate study, EPA examined
maintenance effectiveness on block valves at an ethylene production
unit based on screening valves alone.  In a subsequent study, routine
on-line maintenance achieved a 70-percent reduction in mass emissions.
     In each of these studies, maintenance consisted of routine proce-
dures, such as adjusting the packing gland while the valve was in
service.  In general, the programs concluded that (1) a reduction in
emissions may be obtained by performing maintenance on valves with
screening values above 10,000 ppmv; (2) for valves with screening
valves (before maintenance) below 10,000 ppmv, a slight reduction in
emissions after maintenance may result; moreover, emissions from these
valves may increase; and (3) directed maintenance (emissions measured
during repair until VOC concentration drops to a specified level) is
preferable to undirected maintenance (no measurement of the effect of
repair).
     Valves that need to be repacked or replaced to reduce leakage
must be isolated from the process.   While control valves can usually
be isolated, block valves, which are used to isolate or bypass equipment,
normally cannot be isolated.   One refiner estimates that 10 percent of
the block valves can be isolated.
     When leaking valves can be corrected on-line, repair servicing
can be done immediately after detection of the leak.  When the leaks
can be corrected only by a total or partial shutdown, the temporary
emissions could be larger than the continuous emissions that would
result from not shutting down the unit until it was time for a shutdown
for other reasons.   Simple maintenance procedures, such as packing
gland tightening and grease injection, can be applied to reduce emissions
                                   4-51

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from leaking valves until a shutdown is scheduled.   Leaks that cannot
be repaired on-line can be repaired by drilling into the valve housing
and injecting a sealing compound.  This practice is growing in acceptance,
especially for safety concerns.
     4.8.1.2.3  Flanges.  One refinery field study noted that most
flange leaks could be sealed effectively on-line by simply tightening
the flange bolts.  For a flange leak that requires off-line gasket
seal replacement, a total or partial shutdown of the unit would probably
be required because most flanges cannot be isolated.
     For many of these cases, temporary flange repair methods can be
used.  Unless a leak is major and cannot be temporarily corrected, the
temporary emission from shutting down a unit would probably be larger
than the continuous emissions that would result from not shutting down
the unit until time for a shutdown for other reasons.
     4.8.1.2.4  Relief valves.  In general, relief valves that leak
must be removed in order to repair the leak.  In some cases of improper
reseating, manual release of the valve may improve the seat seal.  In
order to remove the relief valve without shutting down the process, it
is necessary to install a block valve on a three-way valve upstream of
the relief valve if the relief valve system is to be isolated and
repaired on-line without shutting down the unit.
     Flares can also be used as a means of handling emergency releases
from various processes within the plant.  According to the current
knowledge of flare design, the best available flare design or state-of-
the-art flare design is the smokeless flare.  Smoking flares are
environmentally  less desirable because they emit particulates.
     There are a number of techniques currently in  use which help
flares achieve smokeless operation.  One technique  involves the  use of
staged elevated  flare  systems, where a small diameter flare is operated
in tandem with a large  diameter  flare. ; The system  is designed such
that the small flare takes the continuous low flow  releases and  the
larger flare accepts emergency releases.  A second  technique involves
the  use of a small, separate conveyance line to the flare tip in  order
to maintain a high exit velocity for the continuous low  pressure  gas
                                  4-52

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 flow.   A  third technique,  sometimes  used  in  conjunction  with  either  of
 the  above techniques,  involves  the use  of continuous  flare  gas  recovery.
 In the  third  technique,  a  compressor is used to  recover  the continuously
 generated flare gas  "base  load."  The compressor is sized to  handle
 the  "base load,"  and any excess gas  is  flared.   These techniques can
 be used to help provide  smokeless operation  of a flare which  is used
 to reduce fugitive emissions  of VOC  (including benzene)  that  are
 captured  and  transported by closed vent systems.
      In recent tests,  smokeless steam-assisted flares, smokeless
 air-assisted  flares, and smokeless flares with no assist were found  to
 be as efficient as enclosed combustion  devices in destroying  VOC over
 a broad range of  operating conditions if  the heat content of  the
 flared  gas is maintained above  a certain  minimum, and the velocity of
 the  gas at the flare tip is maintained  below a certain maximum.  Based
 on the  test data  and a comparison of vent stream characteristics
 between the test  data  and  equipment  leaking  VOC,  EPA  believes that the
 destruction efficiency of  smokeless  flares would be at least  98 percent.
     Enclosed combustion devices can  be designed and  operated to
 achieve VOC (including benzene) emission  reductions of at least 98 percent.
 Vapor recovery systems can be readily designed and operated to achieve
 VOC  (including benzene)  emission reductions  of at least  95 percent.
 Existing  enclosed combustion devices  and  vapor recovery  systems may
 not  achieve the VOC  emission reduction  efficiencies that new  control
 devices achieve.  However, existing  control  devices achieve a VOC
 reduction  efficiency of  at least 95 percent.
     An emission  reduction efficiency of  95  percent is considered
 appropriate for control  devices used  to reduce equipment leaks of VOC,
 including  benzene.  The  use of  enclosed combustion devices and flares
 achieving  a 98 percent emission reduction  is too costly to add to a
 source  solely  to control VOC leaks in light  of the presence of existing
 control devices that can achieve 95 percent  control.   Because flares
with no assist, steam,  or air assist  can achieve at least 98 percent
VOC  (including benzene)  reduction efficiency if designed for smokeless
operation and existing control devices,  such as enclosed combustion
                                 4-53

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devices and vapor recovery systems, will achieve at least 95 percent
VOC (including benzene) reduction efficiency, a VOC reduction efficiency
of 95 percent is appropriate.
     Recommended design and operation requirements for flares include
smokeless operation and the presence of a flame.  The presence of a
flame can be ensured by monitoring the flare's pilot light with a
thermocouple or some other heat sensor connected to an alarm.  Smokeless
operation of the flare can be ensured through visible emission require-
ments.  Many plants currently comply with State limits similar to this
requirement.  In addition, only steam-assisted flares, air-assisted
flares, or flares with no assist could be used.  Steam-assisted flares
would have to be operated with exit velocities less than 18 m/sec
(60 ft/sec), under standard conditions, combusting gases with heating
values of 11.2 MJ/scm (300 Btu/scf) or greater.  Air-assisted flares
would have to be operated with heating values of 11.2 MJ/scm (300 Btu/scf)
or greater and with exit velocities equal to, or less than, the actual
velocity.  The actual velocity would be calculated by dividing the gas
flow (in standard units), by the unobstructed (free) cross section
area of the flare tip.  Flares operated without assist would have to
be operated with exit velocities less than 18 m/sec (60 ft/sec), under
standard conditions, combusting gases with heating values of 7.4 MJ/scm
(200 Btu/ scf) or greater.  For enclosed combustion devices that do
not use catalysts to aid in combustion of organic vapor streams,
provisions for a minimum vapor residence time of 0.75 seconds at a
minimum temperature of 816° C are considered equivalent to at least a
95 percent emission reduction efficiency.
     4.8.1.2.5  Exhausters.  Leaks from exhauster seals may be reduced
by the same repair procedure that was described for pumps (i.e.,
tightening the packing).  Other types of seals, such as a labyrinth
seal, may require that the exhauster be taken out of service for
repair.  Coke plants have spare exhauster capacity because of the
importance of continuous exhauster operation to the safe and efficient
operation of both the coke battery and the by-product recovery plant.
The spare exhauster capacity could be used while the leaking exhauster
is repaired without shutdown of the gas removal system.
                                  4-54

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     4.8.1.3   Emission Control Effectiveness of Leak Detection and
Repair.22  The control efficiency achieved by a leak detection and
repair program is dependent on several factors, including the leak
definition, inspection interval, and the allowable repair time.
     4.8.1.3.1  Definition of a leak.  The first step in developing a
monitoring plan for fugitive VOC emissions is to define an instrument
meter reading that is indicative of an equipment leak.   The choice of
the meter reading for defining a leak is influenced by several consid-
erations.  The percent of total mass emissions that can potentially be
controlled by the leak detection and repair program can be affected by
varying the leak definition.  Table 4-4 gives the percent of total
mass emissions affected at various leak definitions for a number of
component types.  From the table, it can be seen that,  in general, a
low leak definition results in larger potential emission reductions.
     Other considerations are more source specific.  For valves, the
selection of an active level for defining a leak is a tradeoff between
the desire to locate all significant leaks and to ensure that emission
reductions are possible through maintenance.   Although test data show
that some valves with meter readings less than 10,000 ppm have signif-
icant emissions rates, most of the major emitters have meter readings
greater than 10,000 ppm.  Maintenance programs on valves have shown
that emission reductions are possible through on-line repair for
essentially all valves with nonzero meter readings.  There are,  how-
ever, cases where on-line repair attempts result in an increased
emission rate.  The increased emissions from such a source could be
greater than the emission reduction if maintenance is attempted on low
leak valves.  These valves should, however, be able to achieve essen-
tially 100 percent emission reduction through off-line repair.  Gener-
ally, the emission rates from valves with meter readings greater than
or equal to 10,000 ppm are significant enough so that an overall
emission reduction is likely for a leak detection and repair program
with a 10,000-ppm leak definition.  Therefore, 10,000 ppm seems  to be
the most reasonable leak definition to direct maintenance effort at
the bulk of the valve emissions while still having confidence that an
overall emission reduction will result.

                                  4-55

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     For pump and exhauster seals, the rationale for selection of an
action level is different because the cause of leakage is different.
As opposed to valves, which generally have zero leakage, most seals
leak to a certain extent while operating normally.   These seals would
tend to have low instrument meter readings*  With time, however, as
the seal begins to wear, the concentration and emission rate are
likely to increase.  At any time, catastrophic seal failure can occur
with a large increase in the instrument meter reading and emission
rate.   As shown in Table 4-4, over 90 percent of the emissions from
compressor seals and pump seals are from sources with instrument meter
readings greater than or equal to 10,000 ppm.  Because properly designed,
installed, and operated seals should have low instrument meter readings
and because the bulk of the pump and exhauster seal emissions are from
seals that have worn out or failed such that they have a concentration
equal  to or greater than 10,000 ppm, this level was chosen as a reasonable
action level.
     4.8.1.3.2  Inspection interval.  The length of time between
inspections should depend on the expected occurrence and recurrence of
leaks after a piece of equipment has been checked and/or repaired.
This interval can be related to the type of equipment and service
conditions, and different intervals can be specified for different
pieces of equipment.  Monitoring may be scheduled on an annual, quar-
terly, monthly, or weekly basis.  The choice of the interval affects
the emission reduction achievable because more frequent inspection
intervals will result in earlier detection and repair of leaking
sources.
     4.8.1.3.3  Allowable repair time.  If a leak is detected, the
equipment should be repaired within a certain time period.  The allow-
able repair time should allow the plant operator sufficient time to
obtain necessary repair parts and maintain some degree of flexibility
in overall plant maintenance scheduling.  The determination of this
allowable repair time will affect emission reductions by influencing
the length of time that leaking sources are allowed to continue to
emit.
                                4-56

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     4.8.1.3.4  Estimation of reduction efficiency for valves and
pumps.22 2S  A mathematical model was developed to approximate the
behavior of fugitive emissions from equipment.  The leak detection and
repair (LDAR) model can be used to evaluate programs requiring leak
detection and repair of leaking sources at regular intervals (1 month,
3 months, 6 months, 9 months, or 1 year).   The model also includes an
option to evaluate a program requiring quarterly inspection of all
valves, attempted repair of leaking valves, reinspection of repaired
valves monthly until they are determined not to be leaking for two
successive months, and repair of leaking valves including those that
could not be repaired within 15 days during a process turnaround.   In
addition, the model allows a variable input for repair effectiveness,
process unit turnaround frequency, leak occurrence, and leak frequency.
The model can also incorporate the uncertainty of the inputs and
calculate approximate confidence intervals.  A description of the
methodology and data used to develop the LDAR model can be found in
Reference 23.
     For leaks in by-product recovery plants, the emission factors and
percent of initial leakers shown in Table 3-6 were used as inputs to
the LDAR model.  The overall emission reduction of the leak detection
and repair program for various monitoring; intervals was estimated with
the LDAR model and is shown in Table 4-5.
     4.8.1.3.5  Estimation of reduction efficiency for safety relief
devices and exhausters.22  The estimated reduction efficiencies for
safety relief devices and exhausters are given in Table 4-6 and are
based on a leak definition of 10,000 ppmv.   The first column in
Table 4-6 represents the percentage of total mass emissions that can
be expected from these sources with concentrations at the source
greater than 10,000 ppmv.   If a leak detection and repair program
resulted in repair of all  such sources to 0 ppmv, elimination of all
sources over 10,000 ppmv between inspections, and instantaneous "repair
of those sources found at each inspection,  then emissions could be
expected to be reduced by the amount represented by the first column
in Table 4-6 (see Item A).  However, because these conditions are not
                                  4-57

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met in practice, the fraction of emissions from sources with concen-
trations over 10,000 ppmv represents the theoretical maximum reduction
efficiency.  The approach to estimation of emission reduction presented

here is to reduce this theoretical maximum control efficiency by
accounting quantitatively for those factors outlined above.

     This approach can be expressed mathematically by the following
equation:24
                 Reduction efficiency =AxBxCxD,
where:
     A  =  Theoretical maximum control efficiency = fraction of total
           mass emissions from sources with concentrations greater
           than 10,000 ppmv.

     B  =  Leak occurrence and recurrence correction factor = correc~
           tion factor to account for sources that start to leak
           between inspections (occurrence); for sources that are
           found to be leaking, are repaired, and start to leak again
           before the next inspection (recurrence); and for known
           leaks that could not be repaired.

     C  =  Noninstantaneous repair correction factor = correction
           factor to account for emissions that occur between detec-
           tion of a leak and subsequent repair, since repair is not
           instantaneous.

     D  =  Imperfect repair correction factor = correction factor to
           account for the fact that some sources that are repaired
           are not reduced to zero.   For computational purposes, all
           sources that are repaired are assumed to be reduced to an
           emission level equivalent to a concentration of 1,000 ppmv.

An implicit assumption here is that the leak detection program detects
all of the sources with concentrations greater than 10,000 ppmv that
are present at the time of the inspection.  As an example of this
technique, Table 4-6 gives values for the "B," "C," and "D" correction
factors for various possible inspection intervals and allowable repair
times.

     Recent results of the LDAR model indicate that the ABCQ approach
slightly overestimates the emission reduction achieved by the inspection

program.   The emission reduction for valves in gas service was estimated
                                4-59

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using both approaches and revealed a ratio of the LDAR/ABCD emission
reduction of 0.69 for quarterly monitoring and 0.77 for monthly monitoring.
To put all of the emission reductions on approximately the same basis
(i.e., LDAR model), the percent reductions for safety relief valves
and exhausters in Table 4-6 were adjusted by the LDAR/ABCD ratio,
which is listed as Factor E in the table.  For safety relief valves,
the resulting emission reductions are 44 and 52 percent for quarterly
and monthly monitoring, respectively.  For exhausters, the corrected
emission reductions are 55 and 64 percent for quarterly and monthly
monitoring, respectively.
4.8.2  Preventive Programs22
     An alternative approach to controlling fugitive emissions from
by-product plant operations is to replace components with leakless
equipment.  This approach is referred to as a preventive program.
This subsection will discuss the kinds of equipment that could be
applied in such a program and the advantages and disadvantages of this
equipment.
     4.8.2.1  Pumps.  As discussed in Chapter 3, pumps can be potential
fugitive emission sources because of leakage through the drive-shaft
sealing mechanism.  This kind of leakage can be reduced to a negligible
level through the installation of improved shaft sealing mechanisms,
such as dual mechanical seals, or it can be eliminated entirely by
installing seal!ess pumps.  Another control option is to enclose the
seal area, collect the emissions, and transport the emissions to a
control device or return them to the process.
     4.8.2.1.1  Dual mechanical seals.  As discussed in Chapter 3,
dual mechanical seals consist of two mechanical sealing elements
usually arranged in either a back-to-back or a tandem configuration.
In both configurations a nonpolluting barrier fluid circulates between
the seals.  The barrier fluid system may be a circulating system, or
it may rely on convection to circulate fluid within the system.  While
the barrier fluid's main function is to  keep the pumped fluid away
from the environment, it can serve other functions as well.  A barrier
fluid can provide temperature control in the stuffing box.  It can
                                  4-60

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also protect the pump seals from the atmosphere, as in the case of
pumping easily oxidizable materials that form abrasive oxides or
polymers upon exposure to air.  A wide variety of fluids can be used
as barrier fluids.  Some of the more common ones that have been used
are water (or steam), glycols, methanol, oil, and heat transfer fluid.
In cases in which product contamination cannot be tolerated, it may
also be possible to use a clean product, a product additive, or a
product diluent.
     Emissions from barrier fluid degassing vents can be controlled by
a closed-vent system, which consists of piping, and, if necessary,
flow-inducing devices to transport the degassing emissions to a control
device, such as a process heater, or vapor recovery system.  Control
effectiveness of a dual mechanical seal and closed-vent system is
dependent on the effectiveness of the control device used and the
frequency of seal failure.  Failure of both the inner and outer seals
can result in relatively large emissions at the seal area of the pump.
Pressure monitoring of the barrier fluid may be used in order to
detect failure of the seals.  In addition, visual inspection of the
seal area also can be effective for detecting failure of the outer
seals.
     An alternative to venting the barrier fluid to a control device
is to operate the barrier fluid system such that the barrier fluid
pressure is greater than the stuffing box pressure.   For dual mechan-
ical seals in a back-to-back arrangement, the higher pressure of the
barrier fluid will result in some leakage of the barrier fluid across
the inboard face of the seal into the stuffing box and subsequently
into the pumped liquid.  The pressure of the barrier fluid prevents
outward leakage from the process stream and any leakage will be from
the barrier fluid into the process stream.  Barrier fluid going across
the outboard face of the seal will exit to the atmosphere.  Therefore,
the barrier fluid must be compatible with the process liquid as well
as with the environment.   This control option is not suitable for dual
mechanical seals in a tandem arrangement.  In the tandem arrangement,
the barrier fluid is at a pressure lower than that in the stuffing
                                    4-61

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box; therefore, any leakage from the stuffing box will be into the
barrier fluid.   Control of emissions from the barrier fluid's reservoir
for seals in the tandem arrangement must provide for the collection of
the emissions and transport to a control device.
     Another control option for pumps is to purge the barrier fluid to
an appropriate by-product recovery process.  The barrier fluid may be
circulated through the seal and transported to an appropriate point in
the process for removal or destruction of any benzene in the barrier
fluid.  Alternatively, the barrier fluid may be recirculated through a
closed system with removal of a slipstream of the barrier fluid to the
process to prevent accumulation of benzene in the fluid.  For either
case, clean barrier fluid must be added to the system on a continuous
basis to replace any barrier fluid that is removed.
     Dual mechanical seals are used in many by-product plant process
applications; however, there are some conditions that preclude the use
of dual mechanical seals.  Their maximum service temperature is usually
limited to less than 260° C, and mechanical seals cannot be used on
pumps with reciprocating shaft motion.
     4.8.2.1.2  Seal less pumps.  The seal!ess or canned-motor pump is
designed so that the pump casing and rotor housing are interconnected.
The impeller, motor rotor, and bearings are completely enclosed and
all seals are eliminated.  A small portion of process fluid is pumped
through the bearings and rotor to provide lubrication and cooling.
     Standard single-stage canned-motor pumps are available for flows
up to 160 m3 per second and heads up to 76 m.  Two-stage units are
also available for heads up to 183 m.  Canned-motor pumps are widely
used in applications where leakage is a problem.
     The main design limitation of these pumps is that only clean
process fluids may be pumped without excessive bearing wear.  Since
the process liquid is the bearing lubricant, abrasive solids cannot be
tolerated.  Also, there is no potential for retrofitting mechanical or
packed seal pumps for seal!ess operation.  Use of these pumps in
existing plants would require that existing pumps be replaced.
                                  4-62

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     4.8.2.2  Exhausters.  Exhausters can be potential fugitive emis-
sion sources because of leakage through the drive-shaft sealing mech-
anism.  This kind of leakage can be reduced to a negligible level
through the use of improved shaft-sealing mechanisms, which are analo-
gous to those described for pumps.
     Many exhausters have mechanical seals called a labyrinth seal,
which may also incorporate a barrier fluid.  Control options for this
type of system are similar to those described in the previous subsection.
For example, emissions from the barrier fluid's reservoir may be piped
to a control device or back to the process.  The barrier fluid system
may be operated at a higher pressure than the stuffing box pressure so
that any leakage would be the inward leakage of the barrier fluid.
Alternatively, emissions from the reservoir vent may be added back to
the process stream.  For example, a closed loop from the reservoir
vent to the exhauster inlet may be installed to add the emissions back
to the coke oven gas.
     4.8.2.3  Valves.  As in the case of pumps, valves can be sources
of fugitive emissions because of leakage through the packing used to
isolate process fluids from the atmosphere (see Chapter 3).  This
source of emissions, however, can be eliminated by isolating the valve
stem from the process fluid.   Sealed-bellows valves are designed to
perform in this manner.  The stem in a sealed-bellows valve is isolated
from the process fluid by metal bellows.  The bellows is generally
welded to the bonnet and dish of the valve, thereby isolating the
stem.
     There are two main disadvantages to these valves.   First, they
are only available in globe and gate valve configurations.   Second,
the crevices of the bellows may be subject to corrosion under severe
conditions if the bel-lows alloy is not carefully selected.
     The main advantage of these valves is that they can be designed
to withstand high temperatures and pressures so that leak-free service
can be provided at operating conditions beyond the limits of diaphragm
valves.
                                 4-63

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     4.8.2.4  Safety/Relief Valves.   A rupture disk can be used up-
stream of a safety/relief valve so that under normal conditions it
seals the system tightly but will break when its set pressure is
exceeded, at which time the safety/relief valve will relieve the
pressure.  The rupture disk installation is arranged to prevent disk
fragments from lodging in the valve and preventing the valve from
being reseated if the disk ruptures.   It is important that no pressure
be allowed to build in the pocket between the disk and the safety/relief
valve; otherwise, the disk will not function properly.  A pressure
gauge and bleed valve can be used to prevent pressure buildup.   With
the use of a pressure gauge, it can be determined whether the disk is
properly sealirig the system against leaks.   It is also necessary to
install a block valve or a three-way valve upstream of the rupture
disk if the disk/relief valve system is to be isolated and repaired
on-line without shutting down the unit.
     Use of a rupture disk upstream of a safety/relief valve would
eliminate leaks due to improper seating of the relief valve.   Also,
the disk can extend the life of a safety/relief valve by protecting it
against system materials that could be corrosive and thereby cause
seal degradation.
     Another control option would be to install o-rings in the pressure
relief device to improve the sealing mechanism.  'The o-rings could
provide a tighter seat for the metal disk and could alleviate poor
seating caused by corrosion or deposits on the metal-to-metal seal.
No data are available to estimate the control effectiveness of instal-
ling o-ring seals.
     A closed-vent system can also be used to collect and dispose of
emissions from the relieving or leaking of safety/relief valves.  The
vent on the relief valve could be connected to a control device or to
an appropriate point in the process to recover or to destroy the
vented emissions.  The efficiency of a closed-vent system would be
determined by the control efficiency of the control device that is
used to destroy or recover the emissions.
                                 4-64

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     4.8.2.5  Open-Ended Lines.22  Caps, plugs, and double block and
bleed valves are devices for closing off open-ended lines.  When
installed downstream of an open-ended line, they are effective in
preventing leaks through the seat of the valve from reaching atmosphere.
In the double block and bleed system, it is important that the upstream
valve be closed first.  Otherwise, product will remain in the line
between the valves, and expansion of this product can cause leakage
through the valve stem seals.
     The control efficiency will depend on such factors as frequency
of valve use, valve seat leakage, and material that may be trapped in
the pocket between the valve and cap or plug and lost on removal of
the cap or plug.  Annual emissions from a leaking open-ended valve are
approximately 100 kg.23  Assuming that open-ended lines are used an
average of 10 times per year, that 0.1 kg of trapped organic material
is released when the valve is used, and that all of the trapped organics
released are emitted to atmosphere, the annual emissions from closed
off open-ended lines would be 1 kg.  This would be a 99 percent reduc-
tion in emissions.  Due to the conservative nature of these assumptions,
a 100 percent control efficiency has been to estimate the emission
reductions of closing off open-ended lines.
     4.8.2.6  Closed-Purge Sampling.22  Emissions from purging sampling
lines can be controlled by a closed-purge sampling system, which is
designed so that the purged material is returned to the system or sent
to a closed disposal system and so that the handling losses are mini-
mized.  An example of a closed-purge sampling system is one where the
purged material is flushed from a point of higher pressure to one of
lower pressure in the system and where sample-line dead space is
minimized.  Other sampling systems are available that.utilize partially
evacuated sampling containers and require no line pressure drop, and
nonextractive sampling is possible.
     Reduction of emissions by applying closed-purge sampling is
dependent on many highly variable factors, such as frequency of sampling
and amount of purge required before the closed-purge system is applied.
For emission calculations, it has been assumed that closed-purge
                                  4-65

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sampling systems will provide  100  percent  control  efficiency for the
sample purge from uncontrolled sampling  systems.

4.9  REFERENCES

 1.  Branscome, M. R.  Trip  Report to  Armco,  Incorporated,  Houston,
     Texas.  Research Triangle Institute.   Research  Triangle Park,  NC.
     March 4, 1982.

 2.  Branscome, M. R.  Trip  Report to  U.S.  Steel  Corporation Fairless
     Hills, Pennsylvania.  Research Triangle  Institute.   Research
     Triangle Park, NC.  March 8,  1982.

 3-  Allen, C. C.  Trip Report to  Bethlehem Steel  Corporation,  Sparrows
     Point, Maryland.  Research Triangle Institute.   Research Triangle
     Park, NC.  January 20,  1982.

 4.  Jablin, R. A., et al.   Cost to Control Emission of  Benzene from
     Coke Oven By-Product Plants.   R.  Jablin  & Associates.   EPA Contract
     No. 68-02-3056.  February 13,  1979.
 5.
 6.
 7.
 8.
 9.
10.
11.
VanOsdell, D. W., et al.  Environmental Assessment  of  Coke  By-Product
Recovery  Plants.  U.S.  Environmental  Protection  Agency.  Washington,
DC.  Publication No. EPA-600/2-79-016.  January  1979.   387  p.

McGannon, H. E.  (ed.).  The Making, Shaping,  and Treating of
Steel.  U.S. Steel Corporation.  Pittsburgh,  PA.  1971.  p. 174-175.

Control Techniques for  Volatile Organic Emissions from Stationary
Sources.  Office of Air Quality Planning and  Standards,  U.S.
Environmental Protection Agency.  Research Triangle Park, NC.
Publication No.  EPA-450/2-78-022.  May 1978.

Organic Chemical Manufacturing:  Combustion Control  Devices.
Volume 4.  U.S.  Environmental Protection Agency.  Research  Triangle
Park, NC.  Publication  No. EPA-450/3-80-026.  December 1980.
p. II-3 to 11-10.

Allen, C. C.  Trip Report to Republic Steel Corporation, Cleveland,
Ohio.  Research Triangle Institute.   Research Triangle Park, NC.
January 21, 1982.

Letter from Lucas, A. W., J&L Steel Corporation, to D.  R. Goodwin,
U.S.  Environmental Protection Agency.  August 17, 1979.  Response
tq Section 114 questionnaire "Current and Planned Emission  Controls
for Coke Oven By-Product Recovery Plants."
Lowry, H. H. (ed.).  Chemistry of Coal Utilization.
Volume.  New York, John Wiley and Sons, Inc., 1963.
                                                          Supplementary
                                  4-66

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12.   Hixon, A. W., and C. E. Scott.  Absorption of Gases in Spray
     Towers.  Ind. and Eng. Chem.  27(3):307-314.  1935
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
Wood, J. P., and J. J. Spivey.  Methodology for Spray Absorber
Design and Performance Assessment:  Benzene Removal from  Light
Oil Storage Tank Surge Vent Gases.  Research Triangle Institute.
Research Triangle Park, NC.  April 27, 1983.

Memorandum from Wood, J. P., Research Triangle Institute, to D. W.
Coy, Research Triangle Institute.  November 14, 1983.  6  pp.
Wash-Oil Scrubbers—Guidelines for Equipment Specifications.

Benzene Coke Oven By-Product Plants—Emission Test  Report,  Republic
Steel Corporation, Gadsden, Alabama.  U.S. Environmental  Protection
Agency.  Research Triangle Park, NC.  EMB Report No. 80-BYC-4.
March 1981.

Air Pollution Engineering Manual.  Danielson, John  A. (ed.).
Office of Air Quality Planning and Standards, U.S.  Environmental
Protection Agency.1  Research Triangle Park, NC.  Publication
No. AP-40.  May 1973.

Standard Support and Environmental Impact Statement for Control
of Benzene from the Gasoline Marketing Industry (Draft).  Office
of Air Quality Planning and Standards, U.S. Environmental Protection
Agency.  Research Triangle Park, NC.  June 21, 1978.

Control of Refinery Vacuum Producing Systems, Wastewater  Separators,
and Process Unit Turnarounds.  U.S. Environmental Protection
Agency.  Research Triangle Park, NC.  Publication No. EPA-450/2-
77-025.  October 1977.

Duravent, S. W., D. Gee, and W. M. Talber.  Evaluation of Control
Technology for Benzene Transfer Operations.  Office of Air  Quality
Planning and Standards, U.S. Environmental Protection Agency.
Research Triangle Park, NC.  Publication No. EPA-450/3-78-018.
April 1978.

Control Techniques for Hydrocarbon and Organic Solvent Emissions
from Stationary Sources.  National Air Pollution Control  Adminis-
tration, U.S. Department of Health, Education, and  Welfare.
Washington, D.C.  Publication No. AP-68.  March 1970.

Letter from Schkade, Otto, Vapor Control Company, to C. Allen,
Research Triangle Institute.  April 7, 1982.  Enclosing product
information on vapor recovery systems.

VOC Fugitive Emissions in Petroleum Refining Industry-Background
Information for Proposed Standards.  U.S. Environmental Protection
Agency.  Research Triangle Park, NC.  Publication No. EPA-450/3-81-
015a.  November 1982.
                                 4-67

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23.   Fugitive Emission Sources of Organic Compounds—Additional Infor-
     mation on Emissions, Emission Reductions, and Costs.  U.S. Environ-
     mental Protection Agency.  Research Triangle Park, NC.  Publication
     No. EPA-450/3-82-010.  April 1982.

24.   Tichenor, B. A., K. C. Hustvedt, and R. C. Weber.  Controlling
     Petroleum Refinery Fugitive Emissions Via Leak Detection and
     Repair.  Symposium on Atmospheric Emissions from Petroleum Refineries.
     Austin, TX.   Publication No. EPA-600/9-80-013.  November 6, 1979.
                                  4-68

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                             5.   MODIFICATIONS

5.1  BACKGROUND
     This chapter identifies and discusses possible modifications to sources
in coke by-product plants.   The purpose of this chapter is to present what
changes are potential  modifications, not to define what changes would be
judged as a modification.   Determination of a modification is made by the
Administrator.
     "Modification"' is defined in 40 CRF Part 61,  Section 61.02, as:
          "any physical change in, or change in the method of operation of,
     a stationary source which increases the amount of any hazardous air
     pollutant emitted by such source or which results in the emission of
     any hazardous air pollutant not previously emitted, except that:
     (1)  Routine maintenance, repair, and replacement shall  not be con-
     sidered physical  changes, and
     (2)  The following shall not be considered a change in the method of
     operation:
     (i)  An increase in the production rate, if such increase does not
     exceed the operating design capacity of the stationary source;
     (ii) An increase in hours of operation.1
     The owner or operator of any source must notify EPA of changes that
could increase emissions of an air pollutant for which a NESHAP applies.2
Such changes are not considered modifications if the owner or operator
demonstrates that no increase in applicable emissions would result from the
alteration, in which case, the existing source would not have to meet the
emission standards for a new source.
5.2  PROCESS MODIFICATIONS
     The by-product coke industry is a mature industry with a mode of
operation that has been developed by over 50 years of experience.  A new
by-product recovery process probably will not be commercially available
within the next 10 years.   Some companies have experimented with using
inferior coking coals by either coal briquetting or formed coke processes,
                                  5-1

-------
but large-scale commercial use of these is not expected in the near future.3
Thus, any process modifications will be within the process description
explained in Chapter 3.
     One example of a process variation that would not be considered a
process modification is inconsistent variation in naphthalene processing.
There is substantial potential for temperature variability in naphthalene
melting operations, and thi ^variability leads to emission variability.
The temperature variability probably would not be considered a process
modification, but if the method of naphthalene melting consistently results
in greater emissions, such a change may constitute a process modification.
5.2.1  Tar Dewatering
     Thermal dewatering of tar is a variation of tar dewatering by decanting
in storage tanks.  Water is driven off as water vapor.  Higher temperatures
are used in thermal dewatering than are used in other dewatering processes;
therefore, the implementation of thermal dewatering could increase benzene
emissions and might be a process modification.
5.2.2  Tar Storage
     Increases in the storage temperature and changes in the method of
filling the tank are examples of process modifications that could increase
emissions.
5.3  EQUIPMENT MODIFICATIONS
     Combined with the definition of modification that excludes routine
maintenance, repair, and replacement of equipment, it is not expected that
equipment changes would be potential modifications.  Any discontinuance of
a control or control technique on a source that, does not offset the increased
emissions by implementing an alternate control technique on that source
would be considered a modification.
5.4  REFERENCES
1.

2.

3.
National Emission Standards for Hazardous Air Pollutants.
40 CFR 61.02.
National Emission Standards for Hazardous Air Pollutants.
40 CFR 61.05 (44 Federal Register 55174).
Subpart A.
Subpart A.
Hogan, W. T.,  and F. T. Koebkle.  Analysis of the U.S.  Metallurgical
Coke Industry.  Industrial Economics Research Institute, Fordham
University.   October 1979.  (Prepared for U.S.  Department of Commerce
under EDA Project 99-26-09886-10.)
                                  5-2

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                 6.   MODEL PLANTS AND CONTROL OPTIONS

     The impact of various options to control benzene emissions from
coke by-product recovery plants is determined, in part, through analysis
of model plants.   Subsection 6.1 defines three model coke by-product
recovery plants that typify processes that might be present at a small
by-product plant, a medium by-product plant, and a large by-product
plant.   Discussed in Subsection 6.2 of this chapter are the control
options considered for the benzene emission sources present in coke
by-product recovery plants.
6.1  MODEL PLANTS OVERVIEW
     Model plants for this industry are parametric descriptions of the
processes that may be practiced at an actual plant in a given size
range.   Model plants are used primarily to estimate costs for each
control option as a function of plant size.  Specific production
capacity, processes, and emission sources first were identified for
each actual plant to develop estimates of total nationwide impacts.  A
cost function for each process and emission source was then developed
from the model plant analysis in terms of production capacity and
applied to each actual plant.  Actual plant costs are summed for all
55 plants to estimate total nationwide costs.  This method of analysis
accounts for variations in the processes used at individual plants and
the differences in cost caused by these variations.  Nationwide emission
estimates are based on the type of process or emission source at a
particular plant, the associated emission factor for the emission
source in terms of grams of benzene per megagram of coke capacity, and
the plant's capacity.  The estimated nationwide environmental and
energy impacts of each control option are presented in Chapter 7.
                                  6-1

-------
Information regarding estimated control costs and costing methodology
is presented in Chapter 8, and an economic impact analysis of the
control options is presented in Chapter 9.
6.1.1  Selection of Model Plant Size
     Three model plants were developed to represent typical process
combinations for a small plant (Model Plant 1), a medium plant (Model
Plant 2), and a large plant (Model Plant 3).  The approximate distribu-
tion of actual plant sizes as a function.of coke capacity is shown in  '.
Figure 6-1.  Based on the distribution indicated in Figure 6-1, 25 (of
55 existing plants) plants produce between 300 Mg/day of coke (330
ton/day) and 2,000 Mg/day of coke (2,200 ton/day), accounting for
17 percent of total domestic coke capacity.  For the model plant
analyses, a small model plant is defined as a plant producing
1,000 Mg/day of coke (1,100 ton/day), slightly less than the midpoint
of the actual production range.  A total of 26 plants produce between
2,000 Mg/day of coke (2,200 ton/day) and 6,000 Mg/day of coke (6,600
ton/day).  These medium-sized .plants account for 59 percent of total
domestic capacity.   The production range midpoint of 4,000 Mg/day
(4,400 ton/day) was selected to define the size of a medium-sized
model plant (Model  Plant 2).   According to the distribution shown in
Figure 6-1, four plants produce between 6,000 Mg/day (6,600 ton/day)
and 13,000 Mg/day (14,300 ton/day) of coke.  These large plants account
for 24 percent of total domestic capacity.  For model plant analyses,
a large plant (Model Plant 3) is defined as a model plant producing
9,000 Mg/ day (9,900 ton/day), the midpoint of the actual production
range.
     No construction of new plants is expected during the next 5 years.
However, if a new plant were constructed, it most probably would fall
within the size ranges for Model Plant 1, 2, or 3.
6.1.2  Selection of Model Plant Emission Sources
     A total of 55  coke by-product recovery plants currently operate
throughout the United States.   These plants vary widely in size,  age,
design, equipment,  products,  and degree of control.   Other factors
such as space requirements;  availability of public water treatment
                                  6-2

-------
    40,000 r-
    35,000
    30,000
j:  25,000
e/j
z
o
u
u
uu
    20,000
    15,000
    10,000
     5,000
                                                                                          15
                                                                                               >
                                                                                               H;

                                                                                               U
                                                                                               a
                                                                                               I-
                                                                                               u.
                                                                                               O
                                                                                               u
                                                                                               tr
                                                                                          10
              300-  1001-  2001-  3001- 4001- 5001- 6001-  7001-  8001-  9001-10,001-

              1000  2000  3000  4000  5000 6000  7000  8000  9000  10,00012,000

                                      COKE CAPACITY (Mg/DAY)

           NOTE: Numbers above bars indicate number of plants in a givan size range.
                                                                                 12,001-

                                                                                 13,000
          Figure 6-1. Distribution of plant size as a function of coke capacity.

                                             6-3

-------
facilities for waste disposal; and the plant's physical location in
relationship to sensitive environmental areas, such as wetlands, also
contribute to the site-specific nature of by-product plant processes
and operational characteristics.
     Many different process combinations are used throughout the coke
by-product recovery industry because of the site-specific nature of
the plants.  For this reason, typical representations of actual pro-
cesses and process combinations were assigned to the appropriate model
plant size.  The process combinations used are similar to those widely
used at actual plants.  By-product recovery processes associated with
the emission sources considered for regulation for each model plant
are presented in Table 6-1.
     The presence of an emission source at a plant depends on the
processes practiced at that plant.  Benzene emission sources associated
with the model plant processes are shown in Table 6-2.  Coke by-product
recovery process flow diagrams for the three model plants are presented
in Figure 6-2, Figure 6-3, and Figure 6-4.  These flow diagrams are
intended to represent the typical products, processes, and emission
sources for each model plant  size.  Table 6-3 indicates the estimated
number of process units for each model plant size.  The number of
process units and storage tanks at the model plants was derived from
plant trips, emission test reports, and responses to Section 114
questionnaires.  The number of units and the processes practiced at
specific plants are variable  because various sizing options are avail-
able.  For example, a small plant could have one  large light-oil
storage tank or two smaller light-oil  storage tanks.  The numbers  in
Table 6-4  represent typical numbers of sources according to plant  size
and span the range of the available data for the  number of units at
specific plants.
     As indicated in Figures  6-2 through 6-4, crude tar production  is
practiced  at Model Plants I,  2, and 3.  Benzene emission sources
associated with crude tar production considered for regulation  include
tar decanters, tar-intercepting sumps, flushing-liquor circulation
tanks, tar-dewatering tanks,  excess-ammonia liquor storage tanks,  and
tar storage tanks (including  tar-collecting tanks).
                                  6-4

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          TABLE 6-1.  COKE BY-PRODUCT RECOVERY PLANT PROCESSES
Model plant

Size (Mg/day)
Range represented (Mg/day)
Number of plants within represented
range
Percent of total coke capacity
Crude tar production
Direct-water final cooler
Tar-bottom final cooler
Wash-oil final cooler
Naphthalene processing
Light-oil recovery
Light-oil rectification
Light-oil refining
1
1,000
300-
2,000
25
17
Yes
Yes
No
No
Yes
Yes
No
No
2
4,000
2,000-
6,000
26
59
Yes
No
Yes
No
No
Yes
Yes
No
3
9,000
6,000-
13,000
4
24
Yes
No
No
Yes
No
Yes
Yes
Yes
 Based on  the  distribution  presented in  Figure  6-1.
'includes  naphthalene  separation,  drying,  and handling.
                                     6-5

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                                                        IS
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                                                        §
                                                   5    8
                                                   8    o
                                                       (O
                                                   I   u.
6-6

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Wash-Oil
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Circulation

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6-8

-------
        TABLE 6-2.  EMISSION SOURCES FOR COKE BY-PRODUCT RECOVERY
                              MODEL PLANTS
Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
Source
Tar decanter
Tar- intercepting sump
Flushing- liquor circulation tarik
Tar- dewate ring tank
!
Tar storage tank
Excess-ammonia liquor storage tank
Direct-water final -cooler cooling tower
Naphthalene processing
Light-oil condenser and light-oil decanter vent
Light-oil storage tank
Light-oil sump
Tar-bottom final -cooler cooling tower
Benzene mixtures (BTX) storage tank
Wash-oil decanter
Wash-oil circulation tank
Benzene storage tank
f*
Equipment components
Model plant
1,2,3
1,2,3
1,2,3
1,2
1,2,3
1,2,3
1
1
1,2,3
1,2,3
1,2,3
2
2,3
1,2,3
1,2,3
3
1,2,3
 Corresponds  to  sources  indicated  in  Figures 6-2, 6-3, and 6-4.
 Includes  naphthalene  separation,  drying,  and  handling.
'Pumps,  valves,  exhausters,  pressure-relief devices,  sampling  connection
 systems,  and open-ended lines.
                                 6-9

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TABLE 6-3.  NUMBER OF 'PROCESS UNITS AT COKE BY-PRODUCT RECOVERY
                         MODEL PLANTS
Process equipment
Tar decanter
Flushing-liquor circulation tank
Tar-intercepting sump
Tar dewatering tank
Tar-storage tanka
Light-oil and BTX storage tank
Light-oil condenser
Light-oil sump
Light-oil decanter
Wash-oil decanter
Wash-oil circulation tank
Excess-ammonia liquor storage tank
Benzene storage tank

Model
Plant 1
2
1
1
1
4
2
3
1
1
1
1
1
0
Number of
Model
Plant 2
3
2
1
2
8
6
3
1
I
2
2
3
0
units
Model
. Plant 3
6
3
2
4
12
9
3
2
2
4
4
6
3
Includes tar-collecting tanks.
                             6-10

-------
     The final-cooler cooling tower, generally uncontrolled throughout
the industry, is usually the largest source of benzene emissions at a
plant equipped with a direct-water final cooler.  This process is
practiced by approximately 23 plants.  Benzene emissions are released
when the water from the final cooler is cooled against air in the
direct-water final-cooler cooling tower.
     Plants within the size range of Model Plant 1 (300 to 2,000 Mg/day)
account for about half of the direct-water final coolers and a similar
proportion of tar-bottom final coolers in the industry.  For the model
plant analyses, Model Plant 1 has been assumed to have a direct-water
final cooler and Model Plant 2 a tar-bottom final cooler.
     At Model Plant 1, naphthalene is separated from the process
stream by a direct-water final cooler.  Naphthalene is removed from
the well of the final cooler and may be transported to facilities for
steam drying.  Naphthalene processing (including separation, drying,
and handling) may result in significant quantities of benzene emissions.
     Model Plant 2 has a tar-bottom final cooler.  This process is
used by approximately 18 plants, or 33 percent of the industry.
Although benzene emissions are still released when water is cooled
against air in the final-cooler cooling tower, emissions are substan-
tially less than are emissions from the direct-water final-cooler
cooling tower.  When naphthalene is separated by a tar-bottom final
cooler, the naphthalene remains in the tar.  The tar in which the
naphthalene is entrained may be recirculated by pipeline to tar storage
tanks or sold as a final product.  Thus, benzene emissions from
naphthalene separation, drying, and handling are not attributed to
Model Plant 2.
     At Model Plant 3, a wash-oil final cooler is assumed to be present.
Five plants currently are equipped with this system.   Because the
wash oil is cooled in an indirect heat exchanger, there are no benzene
emissions from the cooling tower.  In this system, naphthalene dissolves
in the wash oil, which is then indirectly cooled and recirculated to
the final cooler.  Although emissions are not released from the cooling
tower, some emissions occur from the wash-oil decanter and wash-oil
circulation tank associated with the wash-oil final cooler.
                                 6-11

-------
     Light-oil recovery processes are attributed to Model Plants 1, 2,
and 3.  Benzene emission sources associated with light-oil recovery
include the common vent for light-oil condensers and light-oil decant-
ers, light-oil storage tanks, light-oil sumps, wash-oil decanters, and
wash-oil circulation tanks.  At Model Plant 3, wash-oil decanters and
wash-oil circulation tanks occur in conjunction with both the wash-oil
final-cooler system and light-oil recovery operations.   However,
light-oil rectification to obtain benzene-mixture products such as BTX
is attributed only to Model Plants 2 and 3.  Storage tanks used to
hold benzene mixtures are the emission sources associated with light-oil
rectification at these model plants.  Because light-oil refining is
usually practiced at large plants, benzene storage tanks are attributed
only to Model Plant 3.
     Fugitive emission sources at coke by-product recovery plants
include equipment components such as pumps, valves, exhausters,
pressure-relief devices, sampling connection systems, and open-ended
lines.  This equipment is prevalent among all plants and is attributed
to Model Plants 1, 2, and 3.  Benzene emissions and the associated
control costs for this equipment depend on the number of pieces of
equipment at the plant, and not on plant capacity.   Plants that practice
benzene refining would have more pieces of equipment than do plants
that recover light-oil and BTX.  Thus, Model Plant 3, which practices
benzene recovery, is credited with more pieces of equipment than are
Model Plants 1 and 2.
     Table 6-4 presents the estimated number of leaking equipment
components in benzene service for each model plant size.  The number
of equipment components was derived from emission test reports and
responses to Section 114 questionnaires.  The data on number of
exhausters ranged from 2 to 6 for 8 plants, and 1 plant had 25
exhausters.  Because exhausters can be sized to handle different
capacities, the number of exhausters was not a function of capacity;
therefore, the number chosen for the model plants (six) represents an
average of available data.  Sample connections were defined as a
                                  6-12

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TABLE 6-4.   NUMBER OF EQUIPMENT COMPONENTS AT COKE BY-PRODUCT
                    RECOVERY MODEL PLANTS
Equipment item
Exhausters
Pump seals
Valves
Relief valves
Sample connections
Open-ended lines

Model Plant 1
6
15
105
5
10
22
Number of units
Model Plant 2
6
15
105
5
10
22

Model Plant 3
6
30
210
9
21
45
                             6-13

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subset of open-ended lines; therefore, the 22 open-ended lines for
Model Plant 2 includes 10 sampling connections and 12 open-ended lines
that are not sampling connections.
6.2  CONTROL OPTIONS OVERVIEW
     In Subsection 6.1, the emission sources considered for regulation
are identified in association with typical processes that may be
practiced at each size model plant.  These emission sources are dis-
cussed further in Chapter 3.  Several options are available for the
control of benzene emissions from these sources.  The control options
considered for "best available technology" (BAT) for each emission
source and the associated benzene control efficiencies are presented
in Table 6-5.  Further information regarding each control technique is
contained in Chapter 4.  Detailed cost information is presented in
Chapter 8 for each emission source and associated control option.   The
environmental and energy impacts of the control options are discussed
in Chapter 7, while the economic impacts are presented in Chapter 8.
6.2.1  Final-Cooler Cooling Tower
     As shown in Table 6-5, three options are considered to control
emissions from final-cooler cooling towers.   At plants operating a
direct-water final cooler, naphthalene could be collected by a tar-
bottom final cooler or a wash-oil final cooler.  Both systems would
eliminate benzene emissions resulting from naphthalene separation,
handling, and drying and would reduce emissions from the cooling tower
substantially.   Use of the tar-bottom final  cooler would achieve an
overall benzene emission reduction of about 81 percent, while use of a
wash-oil system would achieve an emission reduction of 100 percent.
At a medium plant operating a tar-bottom final cooler, a benzene
100-percent control efficiency also would be achieved with a wash-oil
final cooler.
6.2.2  Gas Blanketing System
     Gas blanketing has been demonstrated as an effective control
technique for removing hydrocarbon vapors; e.g., benzene, from process
vessels and product storage tanks.   The basic principles of gas blanket-
ing require sealing all the openings on a vessel or tank, supplying a
                                  6-14

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                TABLE 6-5.   COKE  BY-PRODUCT PLANT BENZENE  EMISSIONS
               	SOURCES  AND CONTROL  OPTIONS	
                                                                                         Control
                                                                                        efficiency
          Emission  source
                                                 Control  option
 1.   Final-cooler  cooling towers
     a.   Direct-water  final-cooler
         cooling tower
     b.   Tar-bottom  final-cooler
         cooling tower
 2.   Tar decanters
 3.   Tar-intercepting  sump
 4.   Flushing-liquor circulation tanks
 5.   Tar-dewatering  tanks

 6.   Light-oil  condenser and  light-oil
     decanter vents
 7.   Wash-oil decanters
 8.   Wash-oil circulation tanks
 9.   Tar-storage tanks

10.   Excess-ammonia  liquor storage
     tanks
11.   Light-oil  storage tanks

12.   Benzene-mixture storage  tanks

13.   Benzene storage tanks
1.   Use tar-bottom  final cooler                     81
2.   Use wash-oil  final cooler                      100
1.   Use wash-oil  final cooler                      100

Coke oven gas  blanketing from collecting main       95
Coke oven gas  blanketing from collecting main       98
Coke oven gas  blanketing from collecting main       98
1.   Coke oven  gas blanketing from collecting main   98
2.   Wash-oil scrubber                               90
Coke oven gas  blanketing from gas holder            98

Coke oven gas  blanketing from gas holder            98
Coke oven gas  blanketing from gas holder            98
1.   Coke oven  gas blanketing from collecting main   98
2.   Wash-oil scrubber                               90
1.   Coke oven  gas blanketing from collecting main   98
2.   Wash-oil scrubber                               go
1.   Coke oven  gas blanketing from gas holder        98
2.   Wash-oil scrubber                               90-
1.   Coke oven  gas blanketing from gas holder        98
2.   Wash-oil scrubber                               90
1.   Nitrogen or natural gas blanketing              98
    system

14.
15.



16.



17.



18.



19.
20.

Light-oil sumps
Pumps



Valves



Exhausters



Pressure-relief devices



Sampling connection systems
Open-ended lines
2. Wash-oil scrubber
Source enclosure
1. Quarterly inspections
2. Monthly inspections
3. Equip with dual mechanical
seals
1. Quarterly inspections
2. Monthly inspections
3. Equip with sealed bellows
valves
1. Quarterly inspections
2. Monthly inspections
3. Equip with degassing
reservoir vents
1. Quarterly inspections
2. Monthly inspections
3. Equip with rupture disc
system
Closed-purge sampling
Plug or cap
90
98
71
83
100

63
72
100

55
64
100

44
52
100

100
100
 Includes  a  100-percent emission reduction for naphthalene processing and a 74-percent emission
 reduction for the direct-water final-cooler cooling  tower.
                                           6-15

-------
constant-pressure gas blanket with coke-oven gas, nitrogen or natural
gas, and providing for recovery or destruction of displaced vapor
emissions.  Depending on the source to be controlled, displaced vapors
from the enclosed source can be transported through a piping system to
the collecting main, to the battery gas holder, or to another point in
the by-product recovery process.
     With gas blanketing from the collecting main, a vapor recovery
system is in place in the form of the by-product recovery process that
removes organics from the raw coke oven gas.  Emission sources that
can be blanketed with raw coke oven gas from the collecting main
include tar decanters, tar-intercepting sumps, flushing-liquor circula-
tion tanks, tar storage tanks, tar-dewatering tanks, and excess-ammonia
liquor storage tanks.  With gas blanketing from the gas holder, a
vapor destruction system is in place because the clean oven gas is
burned to recover the fuel valve.  Emission sources that can be
blanketed with clean coke oven gas from the battery gas holder include
light-oil condensers and decanters, wash-oil decanters and circulation
tanks, light-oil storage tanks, and benzene-mixture storage tanks.  To
prevent product contamination, nitrogen or natural gas can be used to
blanket storage tanks containing refined benzene.  Emissions could be
routed to the collecting main and burned in the gas combustion system
or routed to the gas main before light-oil removal and recovered in
the wash-oil scrubbing operation.
     With source enclosure, the blanketing system's benzene control
efficiency is essentially 100 percent.   Because the deterioration of
piping occasionally can result in leaks, the benzene control efficiency
for gas blanketing is estimated at 98 percent for each source except
tar decanters.  A lower control efficiency (95 percent) is estimated
for tar decanters because a portion of this vessel's surface area must
be left open to the atmosphere to allow for sludge removal operations.
6.2.3  Wash-Oil Scrubber
     A wash-oil scrubber also can be used to absorb organics from tar
dewatering tanks and from storage tanks containing tar, excess ammonia
liquor, light-oil, BTX, or refined benzene.  In some cases, a wash-oil
scrubber could be less expensive than gas blanketing would be.   Wash-oil
                                 6-16

-------
scrubbers currently used for light-oil removal are large towers designed
to handle high volumes of coke oven gas.   This technology can be
applied to these storage tanks based on a smaller scale design for the
scrubbing chamber and a lower wash-oil circulation rate.  In an unpacked
wash-oil scrubber, emissions enter the bottom of the scrubbing chamber
and contact a spray of wash oil, which is introduced into the top of
the spray chamber.  The wash-oil spray absorbs benzene from the vented
vapors.  After passing through the scrubber, benzolized wash oil is
routed to the light-oil recovery plant for removal of benzene and
other organics; the debenzolized wash oil is then recycled to the
scrubber.  The benzene control efficiency of this technique is estimated
to be 90 percent.
6.2.4  Light-Oil Sump
     Source enclosure has been demonstrated as an effective method for
reducing benzene emissions from this source.  The enclosure (i.e., a
roof) need not be permanently affixed so the roof could be removed to
allow for maintenance or sludge removal.   A gasket seal could be
installed around the rim of the sump cover to form a closed system to
contain the emissions.  In addition, a vertical vent could be added to
the sump cover so that excess pressure does not build up in the sump.
Emissions from the vertical vent could be controlled by means of a
water leg seal, a pressure-relief device, or a vacuum relief device.
The' control efficiency of the sump cover, including the vertical vent,
is estimated at 98 percent.
6.2.5  Pumps
     Three options are considered to control fugitive emissions from
leaking pumps.  These options include implementing a leak detection
and repair program based on .quarterly or monthly inspection intervals.
As indicated in Table 6-5, quarterly inspections would achieve about a
72-percent benzene control efficiency, while monthly inspections would
achieve about an 83-percent benzene control efficiency.  A third
option would require that pumps be equipped with dual mechanical seal
systems.  This equipment requirement would achieve a benzene control
efficiency estimated at 100 percent.
                                  6-17

-------
 6.2.6  Valves
     Three  options  also  are  considered  to  control  fugitive benzene
 emissions from  leaking valves.  These options'include  implementing'a
 leak detection  and  repair program based on inspections made at quarterly
 or monthly  intervals.  A third option would require  installing sealed-
 bellows valves.  Quarterly monitoring valves  result  in about a
 63-percent  control  efficiency.  A leak  detection and repair program
 based on monthly monitoring  intervals would achieve  a  benzene control
 efficiency  estimated at  73 percent.  Equipping each  existing valve at
 a medium-sized  plant with sealed bellows valves would  result in about
 a 100-percent benzene control efficiency.
 6.2.7  Exhausters                       '
     Control options similar to those for  pumps and  valves are consid-
 ered for application to  exhausters.  Implementing  a  leak detection and
 repair program  with monitoring at quarterly intervals would achieve
 about 42 percent benzene control efficiency, while monitoring at
 monthly intervals would  result in a 52-percent benzene control effi-
 ciency.  An estimated benzene control efficiency of  100 percent would
 be achieved if  each exhauster were equipped with degassing reservoir
 vents.  Emissions from the degassing reservoir vents could be vented
 to a control device or back  to the process.  For example, a closed
 loop could be installed  to route emissions  from the  degassing reservoir
 vent to the exhauster inlet  and back into  the coke oven gas.
 6.2.8  Pressure-Relief Devices
     The control options considered for pressure-relief devices include
 quarterly inspections, monthly inspections, and equipment requirements.
 The equipment requirements considered include the use of a rupture
 disc system (block valve or  a three-way valve).  A leak detection and
 repair program with monitoring at quarterly inspections would achieve
 a benzene control efficiency of about 44 percent, while an estimated
 benzene control efficiency of 52 percent would result from a monthly
 inspection program.   Equipping each device with a rupture disc system
would achieve a benzene control  efficiency estimated at 100 percent.
                                 6-18

-------
6.2.9  Sampling Connection Systems and Open-Ended Lines
     Benzene emissions from open-ended lines can be eliminated by
capping or plugging the end of the line.   Closed-purge sampling tech-
niques can eliminate benzene emissions from a sampling connection
system.  As shown in Table 6-5, the benzene control efficiency for
both control options is estimated at 100 percent.
                                   6-19

-------

-------
                       7.0  ENVIRONMENTAL IMPACT
     This chapter discusses the environmental impacts from imple-
menting the control options presented in Chapter 6.   The primary
emphasis is a quantitative assessment of benzene emissions that would
result from each of the control options.  The emissions of organic
compounds other than benzene also are estimated.  Both beneficial and
adverse environmental impacts are assessed in terms of water quality,
solid waste, energy, and other environmental concerns.
7.1  BENZENE AIR POLLUTION IMPACT
7.1.1  Emission Source Characterization
     The emission sources at coke oven by-product plants are discussed
in Chapter 3.  The emission sources, emission factors, and
uncontrolled industry emissions are presented in Table 7-1.   These
uncontrolled emissions are characteristic of existing conditions and
are considered baseline.  They are estimated under the regulatory
alternative of no national by-product plant benzene emission standard.
Table 3-3 presents assumptions about the emission source distribution
among the various coke oven by-product plants.   Chapter 6 describes
the model plant approach used to characterize the various emission
sources for different sized plants.  The emission factors presented in
Chapter 3, the capacity of the plants identified in Table 3-3, and the
types of emission sources present at the different plants also
identified in Table 3-3 are used to estimate industry emissions.
7.1.2  Development of Benzene Emission Levels
     Emission factors for the model units were determined for each
control option to estimate the impacts of the control options on
benzene emission levels.  The control technology discussed in
Chapter 4 is applied to the model plants and to the industry model to

                                 7-1

-------
    TABLE 7-1.   ESTIMATED  NATIONAL BASELINE BENZENE  EMISSIONS  FROM  COKE
                      OVEN BY-PRODUCT RECOVERY PLANTS
Number
of plants
uncontrolled
Direct-water final -cooler
cooling tower
Tar-bottom final -cooler
cooling tower
Light-oil condenser vent
Naphthalene separation
Naphthalene processing
Tar- intercepting sump
Tar dewatering
Tar decanter
Tar storage
Light-oil sump
Light-oil storage
Benzene-tol uene-xyl ene
storage
Benzene storage
Flushing- liquor circulation
tank
Excess-ammonia liquor tank
Wash-oil decanter
Wash-oil circulation tank
Pump seals
Valves
Pressure relief devices
Exhausters
Sample connections
Open lines
23

18

44
23
23
55
54
55
55
46
46
20

7
55

55
44
44
46
46
46
46
46
46
Capacity
uncontrolled
(Mg/day)
64,376

42,790

125,724
64,376
64,376
154,680
142,000
154,680
154,680
143,203
143,203
39,479

35,720
154,680

154,680
131,340
131,340
143,203
143,203
143,203
143,203
143,203
143,203
Emission National
factor emissions
(g/Mg) (Mg/yr)
270

70

89
87
20
95
21
77
12
15
5.8
5.8

5.8
9

9
3.8
3.8
	 a
	 a
	 a
	 a
	 a
	 a
6,340

1,090

4,080
2,040
470
5,360
1,090
4,350
680
780
300
80

80
510

510
180
180
600
400
270
33
50
18
Emissions were estimated on the
leaking units.  Emission factors
basis of the number of potentially
in kg/day are listed in Table 3-6.
                                 7-2

-------
estimate the reduction in benzene emissions below baseline levels.
For example, the controlled emission factor for tar decanters was 5
percent of the uncontrolled emission factor because the control was
assumed to be 95 percent effective.
     Controlled benzene emission factors were also developed for
sources that would be controlled by implementation of a leak detection
and repair program.  These factors for pressure relief devices and
exhausters were calculated by multiplying the uncontrolled emission
factor for each type of equipment by a set of correction factors (see
Appendix F).  The factors for pump seals and valves were obtained from
the leak detection and repair (LDAR) model discussed in Subsection
4.8.1.3.  Plugs for open-ended lines and closed sampling lines were
assumed to be 100 percent effective.
     The resulting controlled benzene emissions are listed in Table 7-2
by source.  Where the control options require an equipment specifica-
tion to control leaks, it is assumed that there are no subsequent
emissions from the controlled source.
7.1.3  Impact oh Benzene Emissions from New Sources
     Over a 5-year period from 1982 to 1986, no new by-product plants
are expected to be operated.  Therefore, the control options are
estimated to affect only existing emissions.
7.2  IMPACT OF THE CONTROL OPTIONS ON VOLATILE ORGANIC COMPOUND (VOC)
     EMISSIONS
     VOC emissions were estimated by using emission factors derived
from coke oven by-product plant sampling.1  The bases for derivation
of the emission factors are detailed in a separate report.2  The
emission factors are used in Table 7-3 to estimate the .national
emissions of VOC's.  The atmospheric emissions are estimated as
approximately 194,000 Mg/yr of VOC's.  Table 7-4 presents the effect
of the control options on national VOC emissions from each of the
plant sources.
     The estimated 194,000 Mg of VOC's emitted each year from coke
oven by-product plants are a significant part of the estimated national
VOC emissions (1,400,000 Mg/yr from the processing of over 100 different
organic chemicals).3  The organic materials emitted from by-product
                                 7-3

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-------
     TABLE 7-3.   ESTIMATED  NATIONAL  BASELINE  VQC   EMISSIONS  FROM  COKE
                     OVEN BY-PRODUCT RECOVERY PLANTS
Number
of plants
uncontrol led
Direct-water final -cooler
cooling tower
Tar-bottom final -cooler
cooling tower
Light-oil condenser vent
Naphthalene separation
and processing
Tar- intercepting sump
Tar dewatering
Tar decanter
Tar storage
Light-oil sump
Light-oil storage
BTX storage
Benzene storage
Flushing- liquor circulation
tank
Excess-ammonia liquor tank
Wash-oil decanter
Wash-oil circulation tank
Pump seals
Valves
Pressure relief devices
Exhausters
Sample connections
Open 1 i nes
Total (rounded)
23
18
44
23
55
54
55
55
46
46
20
7
55
55
44
44
46
46
46
46
46
46

Capacity Emission National
uncontrolled factor emissions
(Mg/day) (g/Mg) (Mg/yr)
64,376
42,790
125,724
64,376
154,680
142,000
154,680
154,680
143,203
143,203
.39,47.9
35,720
154,680
154,680
131,340
131,340
143,203
143,203
143,203
143,203
143,203
143,203

4,239
1,100
127
168
202
492
164
281
21.4
8.3
8.3
5.8
12.9
12.9
5.4
5.4
— b
— b
— b
— b
— b
— b

99,600
17,200
5,830
3,950
11,400
25,500
9,260
15,900
1,120
430
120
76
730
730
260
260
850
570
390
140
,76
26
194,400
Benzene and other VOC.

Emissions were estimated on the basis
divided by 0.7; i.e., the fraction of
of benzene emissions in Table 7-1
benzene in light oil.
                               7-5

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                                                                                O O  Of—   0> *— XJ
                                                                                                      O)    F—
                                                                                                             >>••- TJ   "-  >, CO  ^-
                                                                                          .            -
                                                                                         OJCO.  C05O1  T3  r-
         f-l CM  U  O  U  r-i CM
                                                            rHCM  r-ICMiHCMro
                                                                                         rH CM CO  iH CM 0
                                   i-
                                                                         •r-      O*     r—

                                                     i—  ra    «—
                            r-     T-   TJ
                                                                         •r-      W>
                                                                §•
                                                                                         O  •—
                                                                                       I  4->   tO
                                                                     7-6

-------
plants can participate in a wide variety of reactions in the atmosphere,
including singlet oxygen formation4 and formation of ozone-hydrocarbon
reaction products.5 6
7.3  WATER POLLUTION IMPACT
     Most of the control options for the major emission sources do not
increase the water pollution of the plants.  The preferred technique
for most major emission sources is coke oven gas blanketing, which
results in essentially complete control of the emission source.  Any
emissions that are vented from the process are returned to the process
at a different location.  Thus, no water pollution problems are associ-
ated with recycling benzene vapors.
     A possible exception is the increased cyanide concentration in
wastewater due to indirect heat exchange.   Presently, cyanide is
emitted from the final-cooler cooling tower at some plants by air
stripping of the wastewater.  Measured HCN air emissions and calcula-
tions based on once-through cooling water indicate that about 200 g/Mg
of coke could be added to wastewater for treatment, if indirect cooling
were substituted for direct cooling.1  The actual amount of additional
cyanide in the wastewater would depend on cooling water temperature,
degree of recycle practiced, and numerous other factors.
7.4  SOLID WASTE DISPOSAL IMPACT
     None of the control options will adversely impact either solid
waste generation or disposal.   The blanketing control techniques not
only would result in more complete control of the source but would
eliminate some of the potential solid waste problems due to sludge
formation in light-oil plant process equipment.
     Potential solid waste sources include replaced mechanical seals,
seal packing, rupture discs, and valves.  Neither the volume of this
waste nor its degree of potential environmental hazard is expected to
be significant.
7.5  ENERGY IMPACT
     The blanketing and venting systems are essentially passive control
techniques; the only energy required for their operation is heat to
                                 7-7

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prevent vapor freezing in some of the blanketing and vent lines.  The
energy to heat these pipes could come from electrical heating tape or
steam tracing.  The pipes would be insulated to reduce the energy
requirements.
     Table 7-5 summarizes the energy requirements that were assumed
for the gas blanketing and wash-oil scrubber control options described
in Chapter 6 and costed in Chapter 8.  Steam estimates include amounts
needed for pipe heat tracing.  The modest amount of steam could be
available from low-pressure waste steam currently vented.
     A major energy impact for the control technology is the electrical
power for the wash-oil final cooler.   Alternatively, if tar-bottom
final cooling is used, the electrical consumption is much lower.  This
altered consumption results from differences between wash oil's and
water's heat capacities and heat transfer coefficients and because a
tar bottom (mixer-settler) is add-on instead of entire replacement
equipment.
     The major energy impact of the control options is the potential
for recovering large amounts of benzene and other organic compounds
that otherwise would be released to the atmosphere.   The light aromat-
ics are important because their uses include fossil  fuel replacement
and gasoline additives.
     Several of the coke oven by-product plant sources that emit
benzene also emit coke oven gas (methane and hydrogen).   The amount of
coke oven gas emitted could be substantially greater than the amount
of benzene emissions.   Table 7-6 summarizes process unit coke oven gas
emissions that could be recovered as a result of recycle of these
gases back to the coke oven gas.
     Table 7-6 does not include an estimate of the coke oven gas lost
from other potential sources at by-product plants.   If recovery of
21.3 H of gas/min/Mg of coke/day (see Table 7-6) is assumed, the
national energy savings from the recovered coke oven gas would be
approximately 36,100 TJ/yr (0.034 quad/yr).
                                  7-8

-------
          TABLE 7-5.   ENERGY USE AT A MODEL BY-PRODUCT PLANT
                          (4,000 Mg coke/day)
              User
   Steam
  (Mg/yr)
Electricity
 (MWh/yr)
Gas blanketing
Tar decanter, tar-intercepting sump,
  and flushing-liquor circulation tank
Tar dewatering, tar storage
Light-oil storage
Excess-ammonia liquor tank
Condenser, light-oil decanter, wash-oil
  decanter, and circulation tank
Wash-oil scrubber
Excess-ammonia liquor tank
Light-oil storage
Final cooler
Tar-bottom final cooler
Wash-oil final cooler
    350

    440
    107
    128
    176
     60
     60
      10
      10
                      85
                   2,020
               TABLE 7-6.  EMISSIONS OF COKE OVEN GAS FROM
              SELECTED COKE OVEN BY-PRODUCT PLANT SOURCES1
          Sources
      Emissions
(£ gas/min/Mg coke/day)
    Tar decanter
    Light-oil condenser
    Tar dehydrater
    Tar storage
        11.0
         0.2
         4.6
         5.5
                                7-9

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7.6  OTHER ENVIRONMENTAL IMPACTS
     The control options would have  improve the general  appearance of
by-product plant operations because  they would tend to eliminate
aesthetically displeasing phenomena  such as water vapor  plumes  from
process vents and naphthalene precipitation from air, and they  might
reduce some of the odors emitted from  some process steps.  Other
environmental considerations, such as  noise level, are not expected to
be influenced by the control options.
7.7  IRREVERSIBLE AND IRRETRIEVABLE  COMMITMENT OF RESOURCES
     The control options do not involve a tradeoff between short-term
environmental gains at the expense of  long-term environmental losses.
The control options, do not result in irreversible and irretrievable
commitment of resources.  As a result  of the control options, resources
such as light aromatic hydrocarbons  are recovered, and emissions from
affected sources are essentially eliminated.
7.8  IMPACT OF DELAYED STANDARDS
     Delay of the standard will not  significantly impact water  pollution,
solid waste disposal, or energy.  A  delay will result in continued air
pollution at or above the level of national baseline benzene emissions
(see Table 7-1).  The health impact  from control at this level  (described
in Appendix E) would continue throughout the delay.
7.9  REFERENCES
1.   VanOsdell, D.W.  Environmental  Assessment of Coke By-Product
     Recovery Plants.  U.S.  Environmental Protection Agency.  Research
     Triangle Park, NC.   Publication No. EPA-600/2-79-016.   January
     1979.
2.
3.
4.
Branscome, M. R., Summary of VOC and Total Organic Estimates for
Coke By-Product Recovery Plants.  Research Triangle Institute.
Research Triangle Park, NC.  July 11, 1983.
Hydrocarbon Pollutants from Stationary Sources.
Protection Agency.  Research Triangle Park, NC.
EPA-600/7-77-110.  September 1977.
U.S.  Environmental
Publication No.
Geacintov, N. E.  Reactivity of Polynuclear Aromatic Hydrocarbons
with 02 and NO in the Presence of Light.  U.S. Environmental
Protection Agency.  Research Triangle Park, NC.  Publication No.
EPA-650/1-74-010.  1973.
                                  7-10

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5.
6.
7.
Bufalini, J., and A. Altshuller.  Kinetics of Vapor-Phase
Hydrocarbon-Ozone Reactions.  Canadian Journal of Chemistry   43
1965.  pp. 2243-2250.                                         —'

Tebbens, B., J. Thomas, and M. Mukai.  Fate of Arenes Incorporated
with Airborne Soot.  American Industrial Hygiene Association Journal
September-October 1966.  pp. 415-422.
Coke By-product Emissions Evaluation Briefing.
tal Services.  November 1980.
                                                     Scott Environmen-
                                7-11

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                               8.  COSTS

8.1  COST ANALYSIS OF REGULATORY ALTERNATIVES
     This chapter contains cost estimates of implementing various
controls for benzene at existing and new by-product plants.  Costs of
process modifications and add-on controls are presented for each of
the hazardous pollutant sources considered for regulation.  The cost
analysis assumes that each source is uncontrolled and applies the
controls to the sources at each model plant.  Not all by-product
plants will incur all of the costs described in this section because
the types of pollution sources differ among the various plants.
Control costs are presented in terms of total capital cost and total
annualized cost and their components.
     Control costs for a particular plant are estimated according to
its coke capacity; a linear correlation between control cost and coke
capacity was obtained from the cost estimates for the three model
plants.  Nationwide control requirements are estimated on an individual
plant basis, according to available information oh process sources and
coke capacity.   Nationwide capital and annualized control costs are
presented in Subsection 8.1.4 for existing coke oven by-product plants.
     Controls were selected for major air emission sources for coke
oven by-product plants and are described in Chapter 4.   The special
process characteristics of the by-product plants were used to identify
cost-effective controls through implementation of various recycle
techniques.   By-product plants have sources of gas for blanketing and
existing pressure control  on the collecting main and gas holder for
the blanket gas.   These characteristics permit implementation of
relatively inexpensive and effective controls.
                                  8-1

-------
     Subsection 8.1.1 gives the cost analysis for control  of benzene
sources for existing by-product plants.   The control  method most
frequently advocated for the sources is blanketing with raw coke oven
gas from the collecting main or blanketing with clean coke oven gas
from the gas holder, both under a slight, positive pressure.   As
discussed in Chapter 4, gas blanketing generally achieves  essentially
complete control at less cost .than do condensers, absorbers, or
incinerators, which achieve only partial control.
8.1.1  Existing Facilities
     8.1.1.1  Rationale.  The number of process units, tanks, and
other emission points for the three model plants is given  in Table 8-1
and was estimated from industry surveys and plant trips.   A range of
cost estimates is provided for each model plant and is based on a
range of plant types and layouts.  Because piping incurs a major
portion of cost for gas blanketing systems, a range of piping distances
is used for each model plant.  These piping distances are  based on
plant layout data from four plants and include two relatively compact
plants (Armco, Inc., in Houston and Bethlehem Steel Corporation in
Sparrows Point) and two plants that are comparatively spread out (U.S.
                                             , /
Steel Corporation in Fairfield and Fair!ess Hills).
     Costs of gas blanketing and wash-oil scrubber systems are based
on designs that have been applied by the industry (see Chapter 4).
Much of the design data were obtained from systems installed at Armco,
Inc., Houston Works, by the Engineering and Construction Division of
Koppers Company, Inc., a major builder of coke ovens and by-product
recovery plants.
     To consider site-specific factors, EPA visited several by-product
plants that had installed some form of gas blanketing.  In addition,
personnel visited the U.S. Steel Fairless Works to examine potential
difficulties in retrofitting a gas blanketing system in a plant with
long pipe runs.  EPA consultants toured the plant and examined its
layout, existing piping and supports, operating parameters, and relevant
construction blueprints.  Extensive data on tank dimensions, pumping
rates, piping distances, and pipe supports were obtained to develop a
                                  8-2

-------
TABLE 8-1.   NUMBER OF UNITS AT THE MODEL PLANTS
Process equipment
Tar decanter
Flushing- liquor circulation tank
Tar- intercepting sump
Tar-dewatering tank
Tar-collecting, storage tank
Light-oil storage tank
Light-oil condenser
Light-oil sump
Light-oil decanter
Wash-oil circulation tank
Wash-oil decanter
Excess-ammonia liquor storage tank
Pure benzene storage tank

Model
Plant 1
2
1
1
1
4
2
3
1
1
1
1
1
0
Number of units
Model
Plant 2
3
2
1
2
8
6
3
1
1
2
2
3
0

Model
Plant 3
6
3
2
4
12
9
3
2
2
4
4
6
3
                      8-3

-------
detailed construction cost estimate.  The Fair!ess Works' estimate is
provided in Appendix F and was used to derive unit costs for many of
the items required for the model plants.
     Major capital cost  items, their unit cost, and the origin of the
estimate are summarized  in Table 8-2.  Annualized cost items are
listed in Table 8-3.  In the following subsections, these unit costs
are applied to model plants for each emission point, or group of
emission points, to generate a range of capital and annualized costs
for each model.  Annual  light-oil recovery credits are subtracted from
annualized costs to determine net or total annualized costs.  Recovery
credit is based on recovering additional light oil or, for cases of
venting to the gas holder, light oil's fuel value.  Recovery credits
are expected to be conservative because no credit is estimated for
recovery or additional fuel value for organics other than light oil.
Available data are too sparse to estimate accurately the quantity,
composition, and value of these organics; but the limited data show
that the quantity of other organics could be significant.  These other
organics vary in composition with the emission point and include such
compounds as hydrogen, methane, ethane, toluene, xylene, naphthalene,
and tars.  Best available estimates of the quantity and value of these
other organics based on available data are summarized in Appendix F.3.
     8.1.1.2  Tar Decanter, Tar-Intercepting Sump, and Flushing-Liquor
Circulation Tank.  The costs of controlling these sources were calcu-
lated by grouping the sources because they are generally located close
to each other.  The costs include covering and sealing the tar decanter
and sump and blanketing all of these vessels with coke oven gas from
the collecting main.  Pressure control would be provided by the Askania
regulator, which maintains collecting main pressure at 5 to 10 mm of
water.  Discussions with plant operators indicated that pressure
control in the collecting main is inherently reliable.   High-pressure
excursions sound an alarm and open emergency bleeder stacks to vent
the excess.   Low pressure is avoided because of potential damage to
the coke ovens and oxygen infiltration.   When necessary, an operator
will control the Askania manually to maintain the desired collecting
main pressure.
                                 8-4

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                     TABLE  8-2.   CAPITAL  COST  ITEMS
                              (1982  Dollars)
Item
Capital cost factors



Cover decanter and sumps



Fittings0











Flame arrestors ,

Instrumentation
Performance test
Pipe (straight)















Pipe columns
Pressure controller

Pressure reducer
Pressure tap

Pump
Scrubber shell



Description
Construction fee
Contingency
Engineering
Startup
Clean, cover, and seal 22 m2 (240 ft2)
for $7,800
Clean, cover, and seal 52 m2 (560 ft2)
for $16,000
20-cm (8-in. ) pipe

15-cm (6-in. ) pipe

15-cm (6-in.) pipe, light-oil plant

10-cm (4-in.) pipe, light-oil plant

7.6-cm (3-in.) pipe

7.6-cm (3-in.) pipe, light-oil plant

For 15-cm (6-in.) vent
For 7.6-cm (3-in.) vent
Flow rate, pressure, temperature
200 to 300 person-hours
20 cm (8 in.)

15 cm (6 in. )

15 cm (6 in.), light-oil plant .

10 cm (4 in.), light-oil plant

7.6 cm (3 in.)

7.6 cm (3 in.), light-oil plant

8.1 cm (2 in.)

2.5 cm (1 in: )

For piping support
For 7.6-cm (3-in.) line
For ,15-cm (6-in.) line, with backup
For 7.6-cm (3-in.) line
Equipment rental
Labor and materials
2.2 H/s (35 gal/min), 2 hp
7.2 m2 (77 ft2) at $1,530

22 m2 (240 ft2) at $5,000

• .Cost/unit
10% of capital
15% of capital
15% of capital
1% of capital
355/m2
(32.5/ft2)
308/m2
(28.6/ft2)
20/m
(6. I/ft)
16/m
(5.0/ft)
26/m
(7.8/ft)
15/m
(4.6/ft)
6.9/m
(2. I/ft)
13/m
(4. I/ft)
1,870
920
1,300
8,000
138/m
(42. I/ft)
109/m
(33.2/ft)
185/m
(56.4/ft)
126/m
(38.4/ft)
46.6/m
(14.2/ft)
102/m
(31.0/ft)
30.7/m'
(9.36/ft)
20.2/ra
(6.17/ft)
1,500
3,400
12,600
525
4,500/15 days
1,750/tap
2,570
214/m2
(20/ft2)
226/m2
(20.8/ft2)
Reference
1
1
1
1
2,3a

2,3b

d

d

d

d

d

d

e
6
f
g
2h

2h

2h

2h

2h

2h
U
2h

2h

i
j
k
1
m
m
n
0

'P

Footnotes on last page of table.
                                                                   (continued)
                               8-5

-------
                               TABLE  8-2.    (continued)
Item Description
Steam trace, insulation 20-cm (8-in.) line

15-cut (6-in. ) line

15-cm (6-in.) line, light-oil plant

10-cm (4- in.) line, light-oil plant

7.6-cm (3-in.) line

7.6-cm (3-in.) line, light-oil plant

Valves 20-cm (8-in.) plug
15-cm (6-in. ) plug
15-cm (6-in.) 3-way, light-oil plant
7.6-cm (3-in.) 3-way, light-oil plant
5.1-cm (2-in. ) gate
2.5-cm (1-in. ) vent
2.5-cm (1-in.) gate
1.3-cm (0.5-in.) gate
Cost/unit
122/m
(37. I/ft)
68/m
(20.7/ft)
86/m
(26. I/ft)
70/m
(21.3/ft)'
45.6/m
(13.9/ft)
62/m
(18.9/ft)
1,020
620
1,770
730
157
170
75
24
Reference '
2q

2q

2q

2q

2q

2q •

2r
2r
2r
2r
2r
2r
2r
2r
 Derived from Appendix F.   Includes  installing  seal plate, gaskets, welds, access openings, blanking
 lines, removing existing  cover,  and cleaning tank.
 Derived from Appendix F.   Based  on  replacing 52-m2 (560-ft2) primary cooler (tar) decanter top and
 includes blanking lines;  removing concrete  cover; cleaning; installing steel plate, supports, access
 openings, and vent pipe;  and welding.
cFittings include els, tees,  reducers,  and -flanges.
 Cost of fittings derived  from Appendix F, which  contains detailed construction estimate for one
 plant.  Based on costs of fittings  per meter of  pipe  for this design.
 From Grotn Equipment Company; see Appendix  F.
^Includes flowmeter with low flow alarm with 2.5-cm (1-in) flange connections ($787), stainless
 steel pressure indicator  ($90),  temperature gauge ($164) from distributor for Brooks Instruments
 Division, Charlotte, NC.   Installation cost of $130 per instrument is used.
^Includes presurvey, setup, laboratory preparation, analysis, report preparation, travel, and per
 diem expenses.
 Installed capital cost derived from Reference  2  with  details in Appendix F.  Includes installation
 premium for area where continuing operations may interfere with work progress.  For the light-oil
 plant, includes cost premium for flanged pipe  and installation premium for work in a hazardous area.
 Costs for 2.5-cm (1-in.)  and 5.1-cm (2-in.) pipe include fittings.  All pipe is Schedule 40.

 From Appendix F.
••Includes a pressure sensor,  control valve,  and alarm; from BGV Controls, Inc., distributor for
 Fisher Controls, Charlotte,  NC.
kFrom Appendix F.  Includes two Garlock "Gar-Seal" 100 butterfly valves, Teflon-coated surfaces
 including disc and valve  liner,  two General Torque valve actuators, chemical seal, and Robertshaw
 digital control modules with electronic differential  pressure transmitter and electropneumatic
 relays.
 Reduces gas supply pressure to 380  to 460  mm  (15'to.lS in.) of water; from BGV Controls,  Inc.,
 distributor for Fisher Controls, Charlotte, NC.
BFrom Appendix F.  Estimate provided by the Mueller Company.
"From Appendix F.  Pumps rated as 2.2 i/s at 23-m head (35 gal/min at 75 ft) with a 2-hp motor.
 includes pump ($1,350), foundation  ($390),  and electrical ($830).
°The design is for a flow of 0.15 mVs (310 ftVm) and wash-oil  rate of 0.3 je/s (4.3 gal/min).
 shell is a pipe with a 0.5-m (1.5-ft) diameter and a  4.9-m  (16-ft) length.  See Appendix  F.
pThe design is for a flow of 0.6 m3/s (1,200 ftVm) and a wash-oil rate of 2.24 £/s (35 gal/min).
 The shell is a pipe with a 0.9-m (3-ft) diameter and  a 7.3-m  (24-ft) length.  See Appendix  F.
^Derived from Reference 2 in Appendix F.  Includes  1.3-cm  (0.5-in.) Schedule 80 pipe, valves,  steam
 traps, insulation, and stainless steel jacket.  Hazardous area  installation premium included  for the
 light-oil plant.  Insulation is 5.1 cm (2  in.) thick  for  15-cm  (6-in.) pipe, 3.8 cm (1.5  in.) thick
 for 7.6- or 10-cm (3- or 4-in.) pipe, and  2.5  cm (1  in.)  thick  for the steam supply line.
rDerived from Reference 2 in Appendix F.  Includes  hazardous area  installation premium in  the  light-
 oil plant.
 Cost
The
                                             8-6

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                   TABLE 8-3.  ANNUALIZED COST ITEMS
                            (1982 Dollars)  ....
Item
Benzene credit, as fuel
Benzene credit, recovered
Capital recovery (10 years at 10%)
Electricity
Light-oil credit
Maintenance
Nitrogen (storage and supply)
Overhead
Steam
Taxes, insurance, and administration
Cost
$0.15/kg
$0.47/kg
16.3% of capital
$0.04/kWh
$0.33/kg
5% of capital
$0.27/m3
(0.76/100 ft3)
80% of labor
$17.6/Mg
4% of capital
Reference
4,5a
6
7
4b
c
8
d
d
8
4e
8
 Fuel value is based on underfire gas at $2.76 per million Btu's from
 Reference 4 in 1979 dollars ($4.00 per million Btu's in 1982 dollars);
 a fuel content of 17,500 Btu's/lb in Reference 5.

 Adjusted from value of $0.027/kWh (1979 dollars) in Reference 4.

 A light-oil credit equal to 70 percent of the benzene value is used.
 In Reference 4, the 1979 value of light oil was given as $0.77/gal
 and the value of benzene as $1.15/gal.

 Includes rental of 5.7-m3 (1,500-gal) liquid nitrogen storage tank,
 vaporizer, controls, and nitrogen.   Estimate provided by National
 Welders Supply Company, Inc., Raleigh,  NC.

Adjusted from value of $12/Mg ($5.44/1,000 Ib) in 1979 dollars in
 Reference 4.
                                  8-7

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     The major  cost  elements  for the blanketing system  include covering
 and  sealing  the decanter  and  sump,  installing a pressure tap upstream
 of the Askania,  and  adding the  steam-traced and insulated piping to
 route emissions  to the  collecting main.  Costs for covering and sealing
 include removing the existing concrete top; blanking the lines; clean-
 ing, inspecting, and repairing  the  tank; installing steel plate,
 supports, and gaskets;  welding; and adding access openings and a vent
 pipe.  The tar  decanter is sealed by a water seal plate near the
 sludge conveyor  discharge, as illustrated in Figure 8-1.  The majority
 of the liquid surface is  blanketed  with gas from the collecting main
 and  the remainder (approximately 13 percent) provides clearance for
 the  sludge conveyor  and is open to  the atmosphere.
     A 20-cm (8-in.)-diameter vent  line is used to carry the blanketing
 gas  and to route displaced emissions to the collecting main.  The
 large-diameter  line  is  used to  lower the pressure drop in the vent
 line and, consequently, to minimize pressure on the tar decanter.
 Included with the vent  line is a 1.3-cm (0.5-in.) line for steam
 tracing, 5.1 cm  (2 in.) of fiberglass insulation, and a stainless
 steel protective jacket.  The steam tracing should avoid condensation
 and accumulation in  the vent  lines.   However, vent and drain connections
 are provided for steaming out the line should the need arise.
     Each vessel is  equipped with three-way cast iron lubricated plug
 valves to prevent sticking because  of tar deposits.   Valve connections
 are arranged so that in one position the tank is vented to the collect-
 ing main and in the  other position the tank is vented to the atmosphere.
This arrangement permits the blanketing line and/or the tank(s) to be
 isolated for performing maintenance and ensures that the tank is vented
at all  times.  In either position,  the plug valve provides a clear
opening for the passage of vapors and does not have pockets where tar
may accumulate and interfere with the opening and closing of the valve.
     Capital  and annualized cost estimates are summarized in Table 8-4.
A range of piping distances is given for each model  plant to represent
variations in plant  layouts.   Some  plants will  be able to use  an
                                  8-8

-------
                                   CO
                                   u
                                   9)
                                   •a
                                   v.
                                   TO
                                   co

                                   £

                                   _0)
                                   u_
8-9

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TABLE  8-4.   COSTS  FOR GAS  BLANKETING  OF TAR  DECANTER,  TAR-INTERCEPTING
                    SUMP,  AND  FLUSHING-LIQUOR CIRCULATION  TANK
                              (All  Costs  in  1982 Dollars)
Model Plant 1
Cost element
Pressure taps
20-CB (8-in. ) pipe, m
(ft)
7.6-on (3-1n. } pipe, m
(ft)
Pipe supports
Three-way valves
20-cm (8-1n.) plug valve
Clean, cover, seal decanter, m2
(ft2)
Clean, cover, seal sump, m2
(ft2)
Capital cost
Total capital costf
Annual iz«d costs
Maintenance, overhead9 (9%)
Utilities'1
Taxes, insurance (4%)
Capital recovery1 (16.3%)
Total annual ized cost
Light-oil credit3
Annual ized cost
Benzene reduction (Hg/yr)
Cost effectiveness ($/Mg)
Minimum
1
61
(200)
46
(150)
0
4
1
0
(0)
3.0
(32)
34,200
48,300

4,300
1,900
1,900
7.900
16,000
30,100
(14,100)
63.9
(220)
Maximum
1
122
(400)
91
(300)
11
4
1
149
(1,600)
3.0
(32)
121,000
171,000

15,000
3,800
6,800
28.000
53,600
30.100
23,500
63.9
370
Model Plant 2
Minimum
1
91
(300)
46
(150)
0
6
1
0
(0)
23
(250)
52,700
74,300

6,700
2,600
3,000
12,000
24,300
121. QOO
(96,700)
256
(380)
Maximum
1
366
(1,200)
91
(300)
21
6
1
223
(2,400)
23
(250)
239,000
337,000

30,000
9,700
13,000
55,000
; 108, 000
121,000
(13,000)
256
(50)
Model Plant 3
Minimum
1
183
(600)
91
(300)
0
10
1
0
(0)
46
(500)
97,100
137,000

12,000
5,300
5,500
22,000
44,800
271.000
(226,000)
575
(390)
Maximum
1
457
(1,500)
183
(600)
32
10
1
446
(4,800)
46
(500)
377,000
532,000

48,000
12,800.
21,000
87,000
169,000
271.000
(102,000)
575
(180)
Cost per
• unit
. 4,000a
280b.
(85.3)°
99. lc^
(30.2) '
l,500d
1,660
1,020
327e
(30.5)e
328eo
(30.5)e












 From Table 8-2;  one-half of rental ($2,250) plus labor and materials ($1,750).
 From Table 8-2;  includes installed pipe  ($138/m or $42.I/ft),  fittings ($20/m or $6.10/ft), steam tracing,
 and insulation ($122/m or $37.I/ft).
cFro* Table 8-2;  includes installed pipe  ($46.6/m or $14.2/ft), fittings ($7.0/m or $2.13/ft),  steam
 tracing, and insulation ($45.6/m or $13.9/ft).
 Assumes some plants may add pipe supports for 25 percent of pipe; one column each 6.1 m (20 ft) for 20-cm
 (8-in.) pipe and each 3.7 m (12 ft) for  7.6-cm (3-in.) pipe.
eAssum«s some plants have existing covers and others do not.  The cost is averaged from Table 8-4 ($346/m2
 or $32.5/ft2 and $308/m2 or $28.6/ft2).
 Total capital cost includes construction fee (10 percent), contingency (15 percent), engineering (15 per-
 cent), and startup (1 percent).
^Maintenance and  overhead are 5 and 4 percent of capital, respectively.
hSteam at $17.6/Mg.
 Capital recovery factor for 10-year lifetime at 10 percent.
•'Light-oil credit at $0.33/kg ($0.15/lb).
                                        8-10

-------
existing cover on the decanter and  sump, while others must  install a
new cover and seal.  For  some plants, the piping may be  run on the
racks  supporting the flushing-liquor  line, and in other  cases new pipe
supports may be required.  Both of  these conditions are  included in
minimum and maximum estimates for the model plants.
     8.1.1.3  Excess Ammonia Liquor Tanks.  Two control  options were
considered for emissions  from the excess ammonia liquor  storage tanks:
gas blanketing and wash-oil scrubbers.  Depending upon the  location of
the storage tanks, a blanket of coke oven gas from either the collecting
main or gas holder can be used to control emissions.  The cost estimate
provided in Table 8-5 includes a range of piping distances to generate
a range of costs for each model plant.  The system's design features
are similar to those described in Subsection 8.1.1.2.
     The cost of a wash-oil vent scrubber is provided in Table 8-6.
The design is based on each tank venting at a rate of 0.013 m3/s
(200 gal/min) and the scrubber shell requirements discussed in Appen-
dix F.  For Model Plant 2, the wash-oil rate would be approximately
0.1 £/s (1.6 gal/min) and the scrubber shell would be 0.3 m (1 ft) in
diameter and 3.7 m (12 ft) in length.  Wash oil would be supplied
through an uninsulated 2.5-cm (1-in.) line and would be  removed through
a 5.1-cm (2-in.) drain line.   A range of piping distances is given for
each model plant.  In addition, pumps may be required at some plants
to move the wash oil, and other plants may use existing wash-oil  pumps
and gravity drain to recycle the wash oil.
     8.1.1.4  Light-Oil Plant.   The light-oil plant processes benzolized
wash oil from the wash-oil scrubbers, recovers the light oil, and
recycles the wash oil.   Some plants produce only the crude light oil,
others refine the light oil into primary and secondary light oil,  and
a few plants refine it further to produce pure benzene.   The major
equipment items emitting benzene in the light-oil  plant are the light-
oil  condenser,  wash-oil decanter,  and wash-oil circulation tank.
(Product storage tanks  are discussed separately in Subsection 8.1.1.5).
     The control  technology discussed in Chapter 4 for the light-oil
plant is gas blanketing with  clean coke oven gas  from the gas holder
                                  8-11

-------
    TABLE 8-5.    COSTS  FOR  GAS BLANKETING AMMONIA LIQUOR STORAGE TANKS
                               (All  Costs  in  1982  Dollars)
Model Plant 1
Cost element
15-cra (6-in. ) vent pipe, m
(ft)
Three-way valves
15-cm (6-in.) plug valve
Pip* supports
Capital cost
Total capital cost0
Annuali zed costs
Maintenance, overhead (9%)d
Utilities"
Taxes, insurance (4%)
Capital recovery (16.3%)f
Total annual i zed cost
Light-oil credit9
Annual ized cost
Benzene reduction (Mg/yr)
Cost effectiveness ($/Hg)
Minimum
46
(150)
1
1
0
11,100
15,700
1,400
840
630
2,600
5,470
1,500
3,970
3.22
1,200
Maximum
•152
(500)
1
1
7
42,200
59,500
5,400
2,800
2,400
9,700
20,300
1,500
18,800
3.22
5,800
Model Plant 2
Minimum
61
(200)
3
1
0
17,400
24,500
2,200
1,100
1,000
4,000
8,300
6,000
2,300
12.8
180
Maximum
183
(600)
3
1
9
54,400
76,800
6,900
3,400
3,100
12,500
25,900
6,000
19,900
12.8
1,600
Model Plant 3
Minimum
91
' (300)
6
1
0
28,300
39,800
3,600
1,600
1,600
6.500
13,300
13,700
(400)
29.0
(14)
Maximum unit
305 193*
(1,000) (58.9)a
6 1,660
1 620
15 l,500b
92,000
130,000
12,000
5,600
5,200
21,000
43,800
13,700
30,100
29.0
1,040
aFroa Table 8-2;  includes installed pipe ($109/m or $33.2/ft), fittings  ($16/m or $5.00/ft),  steam tracing,
 and insulation  ($68/m or $20.7/ft).
 Assumes some plants may add pipe columns for 25 percent of pipe; one column each 5.2 m (17 ft) for 15-cm
 (6-in.) pipe.
 Total capital cost includes construction fee (10 percent), contingency  (15 percent), engineering (15  per-
 cent), and startup (1 percent).
 Maintenance and  overhead are 5 and 4 percent of capital, respectively.
eSteam at $17.6/Mg.
 Capital recovery factor for a 10-year lifetime at 10 percent.
9Light-oil credit at S0.33/kg ($0.15/lb).
                                         8-12

-------
  TABLE 8-6.   COSTS FOR WASH-OIL VENT  SCRUBBER FOR AMMONIA LIQUOR  STORAGE  TANKS
                                  (All  Costs  in  1982  Dollars)
Model Plant 1
Cost element
Scrubber shell , ra2
(ft2)
7.6-cm (3-in.) vent pipe, m
(ft)
2.5-cm (1-ih.) wash-oil line, m
(ft)
5.1-crn (2-in.) wash-oil drain, m
(ft)
7.6-cm (3-in.) vent valves
Pumps
Instrumentation
Performance test
Capital cost
Total capital costd
Annual i zed costs
Maintenance, overhead (9%)e
f
Utilities
Taxes, insurance (4%)
Operating labor^
Capital recovery (16.3%)h
Total annual ized cost
Light-oil credit1
Annual ized cost
Benzene reduction (Mg/yr)
Cost effectiveness ($/Hg)
Minimum
2.6
(28)
9.1
(30)
30.5
(100)
30.5
(100)
1
0
1
1
12,600
17,800

1,600
-
710
4,200
2,900
9,400
1,400
8,000
2.96
2,700
Maximum
2.6
(28)
9.1
(30)
152
(500)
152
(500)
1
2
1
1
24,000
33,800

3,000
150
1,400
4,200
5,500
14,300
1,400
12,900
2.96
4,400
Model Plant 2
Minimum
3.4
(37)
46
(150)
61
(200)
61
(200)
3
0
1
1
17,500
24,700

2,200
-
990
4,200
4,000
11,400
5,600
5,800
11.8
490
Maximum
3.4
(37)
46
(150)
152
(500)
152
(500)
3
2
1
1
27,300
38,500

3,500
290
1,500
4,200
6,300
15,800
5,600
10,200
11.8
860
Model Plant 3
Minimum
4.6
(50)
91
(300)
122
(400)
122
(400)
6
0
1
1
25,200
35,500

3,200
-
1,400
4,200
5,800
14,600
12,500
2,100
26.6
79
Maximum
4.6
(50)
91
(300)
305
(1,000)
305
(1,000)
6
3
1
1
42,200
59,500

5,400
510
2,400
4,200
9,700
22,200
12,500
9,700
26,6
360
Cost per
unit
226
(21)
46.6
(14.2)
20 2a
£-W. t-
(6.17)a
30. 7a
(9.36)a
, 730
2,570b
1,300C
8,000













 Includes fittings.
 Assumes some plants use existing wash-oil supply and  gravity drain; other plants  require pumps.
''Includes flowmeter  with alarm ($920), pressure gauge  ($120), and temperature gauge  ($290).
 lent)  Candtstartut  (l^ercent)"51™0110" *** (1° percent)> Cont1'n9ency (15 percent), engineering  (15 per-
p
 Maintenance and overhead are 5 and 4 percent of capital, respectively.
Electricity at $0.04/kWh.
aFor 30 min/day at $23/hr.
_Capital recovery factor for 10-year lifetime at 10 percent.
1 Light-oil credit at $0.33/kg ($0.15/lb).
                                                8-13

-------
 or battery underfire system.   The gas blanketing technology has been
 demonstrated in'the light-oil  plant for at least three by-product
 recovery plants.   Pressure control  is provided at 380 to 460 mm (15 to
 18 in.) of water by the existing pressure controller on the gas holder.
 Excess pressure in the gas holder is prevented by a bleeder control
 valve and,  in addition, many  gas holders have a water seal  that will
 blow at about 500 mm (20 in.)  of water.
      The blanketing system consists of a 15-cm (6-in.) header from the
 gas holder to the light-oil plant with 10-cm (4-in.) vent lines connect-
 ing the equipment to the header.  All  lines  are heat traced,  insulated,
 and provided with steam-out connections  and  drains.   Three-way valves
 allow the tanks to be vented either to the blanket line or  to the
 atmosphere  for isolating and maintaining the equipment.   Flame arresters
 are included in the atmospheric  vent lines,  although some plants
 already have flame arresters in  place  and others  operate routinely
 without them.   A  pressure tap  will  be  made either at the gas  holder or
 on  the battery underfire gas line.
      A range of costs  for gas  blanketing the light-oil  plant  is given
 in  Table  8-7 for  a range of piping  distances at the  model plants.
 Light-oil credit  for this system  is  based on the  light oil's  fuel
 value because  the light oil is returned  to the  coke  oven gas,  which is
 burned.   Some  plants with gas  blanketing of  the light-oil plant have
 observed  decreased sludge formation, which occurs  from oxidation
 reactions with  oxygen  in the air.  No  estimates of the credits associ-
 ated  with reduced fouling, reduced maintenance, and  reduced hazardous
waste disposal  costs are available.
      8.1.1.5   Light-Oil  and BTX Storage  Tanks.  Two  control options
were  evaluated  for  emissions from light-oil  and BTX  product storage
tanks:  gas  blanketing  and wash-oil   scrubbers.  Light-oil storage
tanks can be blanketed with clean coke oven  gas from the  gas  holder or
battery underfire as described for the light-oil plant  (see Subsection
8.1.1.4).  For storage tanks that are sufficiently close  to the light-
oil plant, the same  header line from the gas holder may be used for
both the light-oil plant and the storage tanks.
                                  8-14

-------
TABLE  8-7.   COSTS  FOR  GAS  BLANKETING  OF LIGHT-OIL  CONDENSER,  LIGHT^IL DECANTER,
                    >•              lt WJBOBRi Af»D ftkCtftftftt               AN
                                  (All. Costs in  1982  Dollars)
Cost element
Pressure tap
10- to 15-cm (4- to 6-in.) pipe,
Plug valve
Three-way valves
Flame arrestors
Capital costs
Total capital costs0
Annual ized costs
Maintenance, overhead (9%)
Utilities8
Taxes, insurance (4%)
Capital recovery (16.3%)
Total annual ized cost
Light-oil credit*'
Annual ized cost
Benzene reduction (Mg/yr)
Cost effectiveness ($/Mg)
Model Plant 1
Minimum
1
m 61
(ft) (200)
1
6
6
30,800
43,500
3,900
1,000
1,700
7,100
'13', 700
7,400
6,300
34.6
180
Maximum
1-
183
(600)
1
6
6
64,400
90,700
8,200
3,100
3,600
14,800
29,700
7.400
22,300
34.6
640
Model Plant 2
Minimum
1
122
(400)
I
8
8
50,900
71,800
6,500
2,100
2,900
11,700
23,200
29,600
(6,400)
138
(46)
Maximum
1
244
(800)
1
8
8
84,400
119,000
10,700
4,100
4,800
19,400
39,000
. 29,600
' 9,400
138
68
Model Plant 3
Minimum
1
183
(600)
I
13
13
75,900
107,000
9,600
• 3,100
4,300
17,400
34,400
66,600
(32,200)
311
(100)
Maximum un.it
1 3,550a
305 275b,
(1,000) (83.8)D
1 620
13 730
13 920
109,000
154,000
13,900
5 , 100
6,200
25,100
50,300
66,600
(16,300)
311
(52)
 From Table 8-2; equipment rental for 6 days  ($1,800) plus  labor and materials ($1,750).
bAssumes 75 percent of pipe is 15-cm (6-in.)  header and 25  percent is 10-cm  (3-in.) vent  lines.  Cost
 includes installed pipe ($170/m or $51.9/ft), fittings ($23/m or $7.0/ft),  steam tracing,  and insulation
 ($81.7/m or $24.9/ft).
cTotal capital  cost includes construction fee (10 percent),  contingency (15  percent), engineering (15 per-
 cent), and startup (1 percent).
Maintenance and overhead are 5 and 4 percent of capital,  respectively.
eSteam at $17.6/Mg.
 Capital recovery  factor for 10-year lifetime at 10 percent.
9Light-oil credit  of $0.15/kg as fuel.
                                                 8-15

-------
     Gas blanketing costs for light-oil storage tanks are given in
Table 8-8 for a range of piping distances at the model plants.   The
design features are the same as those described for the light-oil
plant.  In addition, pipe columns are added for the maximum case
because a storage tank occasionally may be in a remote location without
existing overhead pipe racks.  Light-oil credit again is based on its
fuel value instead of on the value of recovering light oil.
     Costs of a wash-oil vent scrubber are provided in Table 8-9.
Design is based on a maximum vent rate of 0.013 ms/s (200 gal/min)
generated from pumping light oil into the tank and the scrubber shell
requirements discussed in Appendix F.  Wash-oil scrubbers may be an
appropriate control for old, vertical storage tanks with a riveted
construction.  Extensive modifications, such as replacing the roof on
the entire tank, may be required to rehabilitate the old, vertical
tanks to accept a positive-pressure gas blanket.  However, a wash-oil
scrubber has a negligible pressure drop and could be installed as a
vent control without major tank modifications.  The scrubber would be
installed beside the tank or mounted on the side of the storage tank.
     Wash oil is supplied through an uninsulated 2.5-cm (1-in.) line
and would be removed through a 5.1-cm  (2-in.) drain line.  A range of
piping distances is given for each model plant.  In addition, pumps
may be required at  some plants to move the wash oil, and other plants
may use existing wash-oil pumps and gravity drain to recycle the wash
oil.  Wash oil leaving the scrubber would be routed through the light-
oil plant for light-oil recovery.
     8.1.1.6  Tar-Collecting, Tar Storage, and Tar-Dewatering Tanks.
Costs for two control options—gas blanketing and a wash-oil scrubber—
were  evaluated for  tar collecting, storage, and dewatering tanks.  A
blanket of coke oven gas from the collecting main can be used to
control emissions from tar tanks, as described  in Subsection 8.1.1.2
for tar decanters.  Cost estimates for the model plants are  given  in
Table 8-10 for a range of piping distances.  The operational and
design  features (insulated and  heated  line, pipe supports, and  three-
way valves)  are the same as  those described for the tar decanter.  The
                                   8-16

-------
     TABLE  8-8.   COSTS  FOR  GAS  BLANKETING  OF  LIGHT-OIL AND BTX STORAGE TANKS
                                  (All Costs  in  1982 Dollars)
Model Plant 1
Cost element
10- to 15-cm (4- to 6-in.) pipe,
Three-way valves
Pipe supports
Flame arresters
Capital costs
Total capital costs
Annual i zed costs
Maintenance, overhead0 (9%)
Utilities'1
Taxes, insurance (4%)
Capital recovery8 (16.3%)
Total annual i zed cost
Light-oil credit
Annual ized cost
Benzene reduction (Mg/yr)
Cost effectiveness ($/Mg)
Minimum
m 18
(ft) (60)
2
0
2
8,300
11,700

1,100
290
500
1,900
3,790
500
3,290
2.08
1,600
Maximum
152
(500)
2
8
2
57,200
80,700

7,300
2,500
3,300
13,200
26,300
500
25,800
2.08
12,000
- Model Plant 2
Minimum
18
(60)
6
0
6
14,900
21,000

1,900
290
840
3,400
6,400
3,600
2,800
16.6
170
Maximum
213
(700)
6
11
6
85,100
120,000

10,800
3,500
4,800
19,600
38,700
3,600
35,100
16.6
2,100
Model Plant 3 .
Minimum
61
(200)
9
0
9
31,600
44,600

4,000
1,000
1,800
7,300
14,100
8,000
6,100
. 37.3
160
Maximum
244
(800)
9
12
9
99,900
141,000

12,700
4,100
5,600
23,000
45,400
8,000
37,400
37.3
1,000
Cost per
unit
275*
(83.8)a
730
l,500b
920












aAssumes 75 percent of  pipe is 15-cm (6-in.) header and 25 percent is 10-cm (3-in.) vent lines.  Cost
 includes installed pipe  ($170/m or $51.9/ft), fittings ($23/m or $7.0/ft), steam tracing,  and insulation
 ($81.7/m or $24.9/ft).
 Assumes some plants may  add pipe columns  for 25 percent of pipe.  One column each 5.1 m (17 ft) for 15-cm
 (6-in.) pipe and each  4.3 m (14 ft) for 10-cm (4-in.)  pipe.
Maintenance and overhead are 5 and 4 percent of total  capital cost, respectively.

dSteam at $17.6/Mg.
eCapital recovery factor  for 10-year lifetime and 10 percent.

fLight-oil credit of $0.15/kg as fuel.
                                                  8-17

-------
TABLE 8-9.   COSTS OF WASH-OIL  VENT SCRUBBER  FOR  LIGHT-OIL AND BTX STORAGE TANKS
                                   (All Costs  in  1982 Dollars)
Model Plant 1
Cost element
Scrubber shell, m2
(ft2)
ID-cm (4-in. ) vent pipe, m
(ft)
2.5-cra (1-i n.) wash-oil line, m
(ft)
5.1-cro (2-in.) wash-oil drain, m
(ft)
Pump
Vent valves
Instrumentation
Performance test
Capital cost
Total capital cost6
Annual i zed costs
Maintenance, overhead (9%)
Utilities9
Taxes, insurance (4%)
Operating labor
Capital recovery (16. 3*)1
Total annual i zed cost
Light-oil creditj
Annual i zed cost
Benzene reduction (Mg/yr)
Cost effectiveness ($/Hg)
Minimum
3.0
(32)
15
(50)
30.5
(100)
30.5
(100)
0
2
1
1
16,000
22,600

2,000
190
900
4,200
3,700
11,000
900
10,100
1.91
5,300
Maximum
3.0
(32)
15
(50)
183
(600)
183
(600)
2
2
1
1
28,900
40,700

3,700
380
1,600
4,200
6.600
16,500
900
15,600
1.91
8,200
Model Plant 2
Minimum
4.6
(50)
91
(300)
30.5
(100)
30.5
(100)
0
6
1
1
34,200
48,200

4,300
1,100
1,900
4,200
7,900
19., 400
7,200
12,200
• 15.2
800
Maximum
4.6
(50)
91
(300)
213
(700)
213
(700)
2
6
1
. 1
48,700
68,700

6,200
1,400
2,700
4,200
11,200
25,700
7.200
18,500
15.2
1,200
Model Plant 3
Minimum
5.9
(64)
137
(450)
61
(200)
61
(200)
0
9
1
1
47,200
66,600

6,000
1,600
2,700
4,200
10,900
25,400
16,200
9,200
34.3
270
Maximum
5.9
(64)
137
(450)
244
(800)
244
• (800)
2
9
1
1
61,600
86,900

' 7,800
2,200
3,500
4,200
14,200
31,900
16.200
15,700
34.3
460
Cost per
unit
226
(21)
196a
(59.7)a
K
20. 2b,
(6.17)b
h
30. 7D,
(9.36)b
2,570C
730
,t
1,300°
8,000

-











Includes  installed pipe ($126/m or $38.4/ft) and steam tracing with insulation  ($70/m or $21.3/ft)
blncludes  fittings.
cAssu«es that some plants use existing wash-oil supply and gravity drain and that  other plants require
 pumps.
dlnc1udes  flowmeter with alarm  ($920), pressure gauge ($120),  and temperature gauge  ($290).
eTotal capital cost includes construction fee (10 percent), contingency (15 percent), engineering  (15 per-
 cent),  and startup (1 percent).
^Maintenance and overhead are 5 and 4 percent of capital, respectively.
9Steam at  $17.6/Mg and electricity at $0.04/kWh.
hFor 30 min/day at $23/h.
i
 Capital recovery factor for 10-year lifetime at 10 percent.
•^Light-oil  credit at $0.33/kg.
                                                 8-18

-------
      TABLE 8-10,
COSTS  FOR  GAS  BLANKETING OF TAR COLLECTING, STORAGE, AND
                   DEWATERING TANKS
             ('All  Costs in 1982 Dollars)
Model Plant 1
Cost element
15-cm (6-in.) pipe, m
(ft)
Pipe supports
Three-way valves
Capital cost
Total capital cost
Annual ized costs
Maintenance, overhead (9%)
Utilities6
Taxes, insurance (4%)
Capital recovery (16.3%)
Total annual ized cost
Light-oil credit9
Annual ized cost
Benzene reduction (Mg/yr)
Cost effectiveness ($/Mg)
Minimum
61
(200)
0
5
20,100
28,300

2,500
1,100
1,100
4,600
9,300
5.600
3,700
11.8
310
Maximum
152
(500)
7
5
48,300
68,000

6,100
2,800
2,700
11,100
22,700
' 5.600
17,100
11.8
1,500
Model Plant 2
Minimum
91
(300)
0
10
34,300
48,300

4,300
1,600
1,900
7.900
15,700
22,200
( 6,500)
47.2
(140)
Maximum
762
(2,500)
37
10
219,000
309,000

27,800
13,900
12,400
50,400
104,500
22,200
82,300
47.2
1,700
Model Plant 3
Minimum
122
(400)
0
16
50,100
70,700

6,400
2,200
2,800
11,500
22,900
50,000
(27,100)
106
(260)
Maximum Unit
914 193aa
(3,000) (58.9)a
h
44 1,500°
16 1,660
269,000
380,000

34,200
16,700
15,200
61,900
128,000
50,000
78,000
106
740
Includes installed pipe ($109/m or $33.2/ft),  fittings ($16/m or $5.0/ft), steam tracing,  and  insulation
 ($68/m or $20.77ft).
bAssumes some plants may add pipe supports for 25 percent of pipe; one column each 5.2 m (17 ft) for 15-cm
 (6-in.) pipe.
cTotal capital cost includes construction fee (10 percent), contingency (15 percent), engineering  (15 per-
 cent), and startup (1 percent).      „
"^Maintenance and overhead are 5 and 4 percent of capital, respectively.
eSteam at $17.6/Mg.
fCapital recovery factor for 10-year  lifetime at 10  percent.
9Light-oil credit of $0.33/kg ($0.15/lb).
                                                8-19

-------
cost of a pressure tap is not included because the 15-cm (6-in.)
header for the tar tanks will tie into the gas blanketing line for the
tar decanter.
     The cost of a wash-oil scrubber for control of emissions from
tar-dewatering and tar storage tanks was also examined.  Because the
vapors from these sources are hot, the vapors must be cooled to obtain
a reasonable control efficiency from absorption in the wash oil.  A
high flow rate of once-through wash oil was considered for these
sources to effect both cooling and absorption, but this design could
require increasing the existing wash-oil still capacity at some plants.
The high wash-oil flow rate would be required because of the heat
content of the vapors, primarily from removal of the latent heat of
water that is present in the emissions.
     An alternate design is presented in Figure 8-2, which is a
conceptual design of a wash-oil condenser and scrubber that would
require a relatively low usage of wash oil.  The design includes a
two-zone scrubber in which initial cooling and absorption are accom-
plished in the bottom zone and additional absorption is accomplished
in the top zone.  On the scale of Model Plant 2, cooled wash oil would
be sprayed into  the bottom zone at 16 SL/s (250 gal/mi n), and the wash
oil and condensed water would enter the separator.  Water would be
separated and sent  to wastewater treatment.  The wash  oil from  the
separator would  be  circulated through an  indirect contact heat  exchanger
for cooling  and  then  recirculated to the  bottom  spray  zone.  A  slip-
stream o'f wash oil  at 0.3  iL/s  (5 gal/mi n) would  be  sent to the  light-oil
recovery process for  removal of organics.   Fresh wash  oil would be
sprayed  into the top  zone  of the  scrubber at 0.3 iL/s  (5 gal/min)  to
remove benzene vapors, which pass through the  cooling  section of  the
scrubber.
      The capital cost for  this  design  as  applied to Model  Plant 2 is
given in Table 8-11.  Annualized  costs  for  the  three  model plants are
given in Table 8-12.  The  capital  costs for Model  Plants  1 and  3  were
estimated  from Model  Plant 2 by scaling the capital cost  on  the basis
of capacity to the 0.6  power.
                                  8-20

-------
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-------
     8.1.1.7  Light-Oil  Sump.   Emissions from the light-oil  sump are
controlled by providing a steel  sump cover with a vertical  vent.  The
edge of the sump cover rests in a trough around the sump's  edge and is
sealed with gasket material.
     Costs for covering the sump are estimated in Table 8-13 for
different sizes of sumps at the model plants.  The unit cost for the
cover installation is derived in Appendix F and includes replacing the
existing cover; blanketing  lines; cleaning; adding gasket material;
installing the sump cover,  supports, and access hatches; and welding.
     8.1.1.8  Pure Benzene  Storage Tanks.  A coke oven gas blanketing
system was considered for pure benzene  storage tanks, but plant opera-
tors indicated that contamination may result from contact of the coke
oven gas with pure benzene.  This cost  analysis  is based on supplying
a  nitrogen  or natural gas blanket to pure benzene storage tanks and  on
returning vented  emissions  to the gas holder or  battery underfire
system.   Some coke plants that are  part of an  integrated steel  plant
may have  excess  nitrogen available  from the  oxygen plant associated
with steel making.  Most coke plants have a source  of clean  natural  gas
that is  used to  supplement  the  coke oven gas;  to replace the  coke  oven
 gas in emergency situations; or  to  underfire the coke ovens during
 startup,  idle,  or controlled shutdown  of the coke battery.  The cost
 analysis also recognizes that  a few plants may have  neither nitrogen
 nor natural gas available and  would incur an annual  expense for
 purchasing nitrogen.
      Costs of gas blanketing controls  for pure benzene storage tanks
 are summarized in Table 8-14 for Model  Plant 3.   The system design
 includes a pressure reducer to supply the gas blanket at a pressure of
 380 to 460 mm (15 to 18 in.) of water, a pressure controller that will
 open and vent to the gas holder at pressures over 460 mm (18 in.) of
 water, three-way valves for isolating  tanks, and flame arresters.
      When liquid was pumped out of the storage tank, nitrogen  or
 natural gas would fill  the vapor space  in the tank.   When liquid was
 pumped into the  tank,  excess pressure  in the vapor  space would be
 vented through the pressure controller to the gas holder.  The pressure
                                   8-23

-------
    TABLE 8-12.   ANNUALIZED COST ESTIMATES FOR A WASH-OIL CONDENSER
              AND SCRUBBER FOR TAR STORAGE AND DEWATERING
                            (1982 dollars)
Cost element
Capital cost
Annual ized costs
El ectri ci ty
Cooling water9
Maintenance, overhead (9%)
Taxes, insurance (4%)
Operating labor
Capital recovery (16.3%)c
Total annual ized cost
Light-oil credit
Annual ized cost
Benzene reduction (Mg/yr)
Cost effectiveness ($/Mg)
Model
Plant 1
118,000
500
5,500
10,600
4,700
4,200
19,200
44,700
5,100
39,600
10.8
3,700
Model
Plant 2
275,000
1,000
22,000
24,800
11,000
4,200
45,000
108,000
20,500
87,500
43.4
2,000
Model
Plant 3
448,000
2,300
50,000
40,300
17,900
4,200
73,000
188,000
46,000
142,000
97.6
1,500
 Based on 13 £/s (200 gal/min) for Model Plant 2 at $0.055/1,000 £
 ($0.21/1,000 gal) from Reference 4 in 1982 dollars.   Flow rates for
 Model Plants 1 and 3 were scaled from Model Plant 2 based on coke
 capacity.
bFor 30 min/day at $23/h.

cCapital recovery factor for 10-year lifetime at 10 percent.
dLight-oil credit at $0.33/kg ($0.15/lb).
                                  8-24

-------















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8-25

-------
  TABLE 8-14.   COSTS  FOR NITROGEN  OR NATURAL  GAS
      BLANKETING  OF  PURE  BENZENE STORAGE TANKS
            (All Costs  in  1982 Dollars)
Model Plant 3 rn*+ „„„
Cost element
2.5-cm (1-in. ) gas supply, m
(ft)
7.6-cffl (3-in.) vent pipe, m

Pressure controller
Pressure reducers

Three-way valves

Flame arresters
Pipe supports
Capital costs
Total capital costs6
Annuali zed costs
Maintenance, overhead (9%)
Utilities9
Taxes, insurance (4%)
Capital recovery (16.3%)
Total annual i zed cost
Benzene credit1
Annuali zed cost
Benzene reduction (Mg/yr)
Cost effectiveness ($/Mg)
Minimum
30.5
(100)
61
(200)

1
2

3


0
14,300
20,100

1,800
-
800
3,300_
5,900
2,900 '
3,000
18.7
170
Maximum unit
91.4 20.2
(300) (6.17)d
244 53.5bb
(800) (16.3)D
1 4 400C

2 525
3 730

3 920
O wt-w
H
10 1,500°
40,300
56,800

5,100
15,000
2,300
9,300
31,700
2.900
28,800
18.7
1,500
Includes fittings.
Includes installed pipe ($46.6/m or $14.2/ft) and fittings  ($7.0/m or
 $2.13/ft).
cFrom Table 8-2; includes pressure sensor,  control valve, and alarm.
Assumes some plants may add pipe columns and others may use existing
 pipe supports.
6Total capital  cost includes construction fee (10 percent),  contingency
 (15 percent),  engineering (15 percent), and startup (1 percent).
Maintenance  and overhead are 5 and 4 percent of capital, respectively.
9Nitrogen at  $0.27/m3 ($0.76/100 ft")    Includes rental of 5.7-m3
 (1 500-gal)  liquid nitrogen storage tank, vaporizer,  and gas usage.
 Some plants  are assumed to have a  nitrogen source  and others must
 purchase nitrogen.
 hCapital recovery  factor for 10-year  lifetime at 10 percent.

 Benzene credit of $0.15/kg as fuel.
                               8-26

-------
setpoint for the pressure controller would be slightly higher than
the pressure in the gas holder would be.   The benzene vapors would be
returned to the coke oven gas that is used as fuel.
     Costs of applying a wash-oil vent scrubber to benzene storage
tanks are summarized in Table 8-15.  The system is analogous to the
wash-oil scrubbers previously described.   Debenzolized wash oil is
sprayed into the top of the scrubber, and the wash oil is drained and
returned to the light-oil recovery system.
     8.1.1.9  Final Cooler.  In standard descriptions of by-product
plants, crude naphthalene is recovered from the hot well of the direct-
water final cooler.11  In a new plant, the tar-bottom final cooler
might be in one piece.  Retrofit costs for an existing plant are based
upon the design of a one-stage mixer-settler expending pump work
comparable to the extra lift work  of the one-piece design.  This
system  also would be suitable for  new applications.  The following
paragraph describes the parameters chosen for the cost estimation and
a  rationale for their  selection.
     At a scale of 4,000 Mg of coke per day, with a 20° C  increase
through the final cooler,  approximately 4,800 Mg of water  per  day
contacts a comparable  amount of  tar.  Daily production of  whole tar  is
about  160 Mg; for  light tar, which is cleaner and less viscous, daily
production  is approximately  30 Mg.   If the light tar  is recirculated
from the  settler at a  rate 100 times  the  throughput,  the effective tar
rate is 3,000 Mg/day.   If  the  combined stream is forced through an
orifice-plate mixer at a pressure  drop of 70  kPa  (10  psi), the
theoretical pump work is about 5.7 kW (7.6 hp).  The  electrical load
will be about  10  kW and a  15-hp  motor should  suffice.  The settler
 should provide  a  residence time  of 30 minutes,  requiring  300 m3
 (10,000 ft3),  with a  vent  back to  the gas exiting  the final  cooler.
The water will  be  circulated from  the settler to  the cooling tower  in
 the usual  way,  but a  pair  of small circulating  pumps and  extra piping
 are required for  the  tar circuit.   Cost  estimates,  scaled to the  three
 model  plants,  are  shown in Table 8-16.
                                  8-27

-------
  TABLE  8-15.    COSTS OF WASH-OIL VENT  SCRUBBER FOR
                    BENZENE STORAGE TANKS
               (All  Costs  in  1982  Dollars)
Model Plant 3
Cost element
Scrubber shell , m2
(ft2)
2.5-cm (1-in.) wash-oil line, m
(ft)
5.1-cm (2- in.) wash-oil drain, m
(ft)
10-cm (4-in.) vent pipe, m
(ft)
Vent valves
Flame arresters
Pump
Instrumentation
Performance test
Capital cost
Total capital cost
Annuali zed costs
Maintenance, overhead (9%)
Utilitiesf
Taxes, insurance (4%)
Operating labor^
Capital recovery (16.3%)h
Total annual ized cost
Benzene credit1
Annual ized cost
Benzene reduction (Mg/yr)
Cost effectiveness ($/Mg)
Minimum
3.4
(37)
61
(200)
61
(200)
45.7
(150)
3
3
0
1
1
23,900
33,700

3,000
-
1,300
4,200
5.500
14,000
5.700
8,300
17.2
480
Maximum
3.4
(37)
244
(800)
244
(800)
45.7
(150)
3
3
2
I
1
38,400
54,100

4,900
510
2,200
4,200
8.800
20,600
5,700
14,900
17.2
870
Cost per
unit
226
(21)
20. 2a
(6.17)a
30. 7a
(9.36)a
126
(38.4)
730
920
2,570b
1,300C
8,000













 Includes fittings.
bAssumes some plants use existing wash-oil supply and gravity drain
 while other plants  require pumps.
clncludes flowmeter  with alarm ($920),  pressure gauge ($120), and
 temperature gauge ($290).
dTota1 capital cost  includes construction  fee (10 percent), contingency
 (15 percent), engineering (15 percent), and startup (1 percent).
Maintenance and overhead are 5 and 4 percent of capital,  respectively.
Electricity at $0.04/kWh.
9For 30 min/day at $23/h.
hCapital recovery factor for 10-year lifetime at 10 percent.
Benzene credit at $0.33/kg ($0.15/lb).
                           8-28

-------
TABLE 8-16.  COSTS FOR INSTALLING A TAR-BOTTOM FINAL COOLER
                (All Costs in 1982 Dollars)
Cost element
Settler9
Mixer pumps, drivers3
Circulating pumps, drivers
Installed capital cost
Annual i zed costs
Maintenance, overhead (9%)
Utilities0
Taxes, insurance (4%)
Capital recovery (16.3%)d
Total annual ized cost
Light-oil credit6
Annual ized cost
Benzene reduction (Mg/yr)
Cost effectiveness ($/Mg)
Model
Plant 1
76,000
16,000
9,300
101,000

9,100
900
4,000
16,500
30,500
52,800
(22,300)
112
(200)
Model
Plant 2
173,000
32,000
11,000
216,000

19,400
3,400
8,600
35,200
66,600
211,000
(144,000)
448
(320)
Model
Plant 3
280,000
43,000
12,000
335,000

30,200
7,700
13,400
54,600
106,000
475,000
(369,000)
1,010
(370)
                                         of  capital,  respectively.
 Installed costs, derived from Reference 12.
 Maintenance and overhead are 5 and 4 percent
GElectricity at $0.04/kWh.
 Capital recovery factor for 10-year lifetime at 10 percent.
eLight-oil credit of $0.33/kg ($0.15/lb).
                              8-29

-------
     8.1.1.10  Wash-Oil Final Cooler.   In principle, benzene emissions
from naphthalene handling and the direct final cooler can be eliminated
by one device:   the wash-oil final cooler.  As described in Chapter 4,
the cooling fluid is a suitable wash oil directly contacting the coke
oven gas.  It is as assumed that the use of a suitable wash oil,
coupled with the use of appropriate additives and proper operating
conditions would permit easy separation of the condensed water from
the circulating oil in the system.
     The cost estimation for a new system of this kind was furnished
by Wilputte in 1977, as reported by VanOsdell.13  Those numbers,
scaled to the three sizes of model plants and escalated to 1982 dollars,
are the basis of Table 8-17.
     The least certain and, at the largest scale, the most significant
cost is for the wash-oil makeup.  Although 0.1 percent loss is arbitrary
and sounds trivial, at the larger scale it tends to overwhelm the
annualized cost.
     8.1.1.11  Fugitive Emissions from Equipment Components.  This
subsection summarizes costs associated with controlling benzene emissions
from equipment components that service or contain materials having a
benzene concentration of 10 percent or more by weight.  Exhausters
that handle coke oven gas with over 1 percent benzene also are included.
The light-oil recovery and refining processes at by-product recovery
plants use pumps, valves, pressure-relief devices, sampling connections,
and open-ended lines in benzene (or light-oil) service.  Costs are
determined by following the methodology established to control volatile
organic compounds (VOC's) from the petroleum  refinery industry.
Details are provided in Appendix  F.
     Two types of model plants were derived to estimate control costs
for equipment components in benzene service.  Model Plants 1 and 2
represent the majority of by-product plants that produce light oil
(about 70 percent benzene), and Model Plant 3 represents plants that
not only recover light oil but also refine it into benzene.  The
number of equipment items for each model  plant is given in Table 8-18
and was derived from plant surveys and  questionnaires.
                                   8-30

-------
       TABLE 8-17.   COSTS FOR INSTALLING A WASH-OIL FINAL COOLER
                      (All  Costs in 1982 Dollars)
  Cost element
Model
Plant 1
Model
Plant 2
                                                            Model
                                                            Plant 3
Total capital cost, millions'

Annualized costs
    2.1
    4.8
7.9
Additional operating labor
/•»
Maintenance, overhead (9%)
Makeup wash oil
Utilities6
Taxes, insurance (4%)
Capital recovery (16.3%)
Total
Light-oil credit^
Annual i zed costg
Benzene reduction (Mg/yr)g
Cost effectiveness ($/Mg)g
Light-oil credit11
Annual i zed cost
Benzene reduction (Mg/yr)
Cost effectiveness ($/Mg)h
40,000
144,000
84,000
20,200
84,000
340,000
712,000
65,000
647,000
138
4,700
12,000
700,000
26
27,000
40,000
430,000
335,000
80,700
190,000
780,000
1,860,000
260,000
1,600,000
550
2,900
48,000
1,810,000
102
18,000
40,000
710,000
755,000
181,700
320,000
1,290,000
3,300,000
580,000
2,720,000
1,240
2,200
108,000
3,190,000
230
14,000
 Updated and scaled from information  by Wilputte  Corporation  in  Refer-
  ence 13.
 bLabor in addition to that currently  used for direct-water or tar-
  bottom final  cooler.
 Maintenance and overhead are 5 and 4 percent of  capital,  respectively.
 dAt 0.1 percent of circulation ($0.11/kg).
 eElectricity at $0.04/kWh.
 fCapital recovery factor for 10-year  lifetime at  10 percent.
 9Replaces direct-water final cooler;  light-oil credit is $0.33/kg
  ($0.15/lb).
 hReplaces tar-bottom final cooler; light-oil credit is $0.33/kg
  ($0.15/lb).
                                   8-31

-------
    TABLE  8-18.   MODEL PLANTS  FOR FUGITIVE  BENZENE  EMISSIONS  FROM
                         EQUIPMENT COMPONENTS

                                 Number of items  at  each model  plant
  Equipment item
     Model
Plants 1 and 2C
Model Plant 3"
Exhausters
Pump seals
Valves
Pressure-relief devices
Sampling connections
Open-ended lines
6
15
105
'5
10
22
6
30
210
9
21
45
 Model  Plants 1 and 2 represent plants that produce light oil  only.

DModel  Plant 3 represents plants that produce light oil  and pure
 benzene.
                                  8-32

-------
     The cost analysis that was applied to the model  plants evaluates
inspections, leak detection, repair, and equipment modifications as
controls for the equipment in benzene service.  Capital cost items are
listed in Table 8-19 and were inflated to 1982 dollars at a 10-percent-
per-year rate.  Total capital costs for the model plants in Table 8-19
were generated by multiplying the cost per item by the number of items
for each model as listed in Table 8-18.
     Annualized costs for each equipment item and control option are
summarized in Table 8-20.  Development of these cost estimates is
described in detail in Appendix F in 1979 dollars, which were scaled
to 1982 dollars at 10 percent per year.  Annualized cost of control
(inspection, repair, and equipment) was estimated and an annual recovery
credit was subtracted to calculate total annualized cost per item
shown in Table 8-20 (see Appendix F for calculations).  Annualized
costs for the two model plants are also summarized in Table 8-20.
Total annualized cost was obtained by  multiplying the annualized cost
per  item by  the number of items at each plant (Table 8-18). • Control
techniques  expected to save  money are  denoted as credit by parentheses.
      In addition to costs shown in Table 8-20, each model plant would
be expected to  incur  an  expense for the monitoring instrument that
cannot be attributed  to  each equipment item.   Annualized cost of the
monitoring  instrument is estimated  as  $5,000  per year  (1979 dollars)
and  is based on a  capital cost of $8,500.  Annualized  cost  includes
capital  recovery  ($2,000 for a 6-year  lifetime at 10 percent),  mainte-
nance and  calibration ($2,700), and other  annual expenses  ($300  or
4 percent  of capital).
8.1.2  New Facilities
      The installed capital  and annualized  costs  associated  with the
control  options in terms of new facilities may be  less than the pro-
jected  cost for existing facilities.   The  controls may be  incorporated
 into the design of a new facility  to  take  advantage  of optimum  plant
 layout  to  minimize piping distances.   However, the annualized and
capital  costs for new facilities  are  expected to fall  within  the range
estimated for existing facilities  with the lower end of the range
                                    8-33

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being more appropriate for new plants.   The costs for controlling a
new facility would be a function of the plant layout, piping distances,
and the number and sizes of the various emission points.   Costs for
new,sources are not presented separately because those elements that
may be less expensive cannot be clearly identified and quantified, and
because any estimate would be a function of an assumed plant layout.
8.1.3  Modified Sources
     The analysis presented in Subsection 8.1.1 for existing sources
is applicable to sources that are modified.
8.1.4  Summary of Estimated Control Costs
     Cost estimates are provided in the previous sections for the
benzene sources at by-product plants, including groups of emission
sources and the leak detection and repair program.  Not all by-product
recovery plants have all of the emission sources for which cost esti-
mates have been provided.  All plants are assumed to have tar recovery
and handling sources, but a distribution of process types exists for
final coolers and light-oil recovery.  Table 8-21 shows this distribu-
tion with 23 plants (42 percent of total capacity) having a direct-water
final cooler and 32 plants (58 percent of total capacity) having another
type or no final cooler.  Nine plants (7 percent of total capacity) do
not recover light oil, and 7 plants (23 percent of capacity) refine the
light oil into pure benzene.
     The capital and annualized costs for each control option for each
model plant are summarized in Tables 8-22 through 8-24.  Also presented
in the tables for each source are uncontrolled benzene emissions,
benzene reductions achieved by the controls, and VOC reductions.
Average cost effectiveness is calculated by dividing the annualized
cost by the benzene emission reduction achieved.  For sources with
more than one control option, an incremental cost effectiveness is
also given. Incremental cost effectiveness for a particular control
option is calculated by subtracting the annualized cost for the next
less stringent option from that particular option, and dividing the
difference in cost by the difference in emission reduction between  the
two options.
                                   8-36

-------
TABLE 8-21.   ESTIMATED DISTRIBUTION OF TYPES OF COKE PLANT
                     EMISSION SOURCES
Source
Final cooler:
Direct- water
Tar-bottom
Wash- oil
Other
Light-oil storage
Benzene storage
Number of plants

23
18
6
8
46
7
Percent of
total capacity

42
28
14
8
* 93
23
                             8-37

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     Estimates of nationwide costs, emission reductions, and cost
effectiveness are presented in Table 8-25.  Nationwide costs (excluding
the leak detection and repair program, LDAR) were estimated from the
model battery analysis with the use of linear cost functions and data
on plant-specific capacities and processes.  For each control option,
a midrange capital and annualized cost was determined for each model  .
plant.   The midrange costs for the model plants were then used to
express the control cost as a linear function of coke capacity.   The
cost function for a source was then applied to each real plant that
has the given emission source by using the real plant's capacity in
the cost function.  Nationwide costs were determined by summing the
costs for all plants.   To estimate the nationwide costs of the LDAR
program, the costs for each type of model battery shown in Tables 8-19
and 8-20 were multiplied by the number of each type of battery currently
existing.  For exhausters, a total of 55 plants was used.   A total 'of
46 plants produce light oil, and 7 of»these refine it to benzene.
Therefore, a total of 39 plants fall into the Models 1 and 2 category,
and 7 plants are represented by Model Plant 3.
     Regulatory alternatives were developed from the control options
in Table 8-25 for the purpose of determining the economic impact
(Chapter 9) of differing control strategies.  Regulatory Alternative I
represents baseline control with no national emission standard.
     Based upon the average and incremental cost effectiveness in
Table 8-25, several options were chosen as Regulatory Alternative II
for the economic impact analysis.   The controls for Regulatory Alterna-
tive II include the tar-bottom final cooler; gas blanketing for Sources
No. 2 through No. 7 (tar decanter, tar-intercepting sump,  flushing-
liquor circulation tank, tar storage and dewatering, light-oil condenser,
light-oil decanter, wash-oil decanter, wash-oil circulation tank, the
excess-ammonia liquor tank, light-oil and benzene mixture storage tanks,
and benzene storage tanks); a sealed cover for the light-oil sump;
monthly monitoring for pumps and valves in benzene service (at least
10-percent benzene by weight); quarterly monitoring for exhausters in
benzene service (at least 1-percent benzene by weight); and equipment
                                  8-41

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controls for pressure-relief devices, sampling connections, and open-ended
lines in benzene service (at least 10-percent benzene by weight).
     Regulatory Alternative III was chosen as a more stringent combina-
tion of controls that would yield a greater emission reduction than
that achieved by Regulatory Alternative II.  The options chosen for
analysis as Regulatory Alternative III include a wash-oil final cooler;
equipment specifications for pumps, valves, and exhausters in benzene
service'(at least 1-percent benzene for exhausters and at least
10-percent benzene for pumps and valves, by weight); and for other
sources the same controls as listed for Regulatory Alternative II.
8.1.5  Comparison of Actual and Estimated  Capital Costs
     Because only a few gas blanketing systems have been installed,
any  comparison of actual and estimated costs  is limited.  Armco,  Inc.,
personnel estimated the cost of their gas  blanketing system as $130,000
(1975 dollars) but warned that the estimate was approximate.  The
system was part of a larger multimillion-dollar construction project,
which made  it difficult to extract only gas blanketing costs.14
Inflating this estimate to 1982 dollars at a  rate of 10  percent per
year yields  an estimate of $250,000  (1982  dollars).
     The Armco system  controlled  tar decanters; flushing-liquor circu-
 lation  tanks; ammonia-1iquor storage tanks; tar-collecting, tar-
 dewatering,  and tar  storage tanks; and  the light-oil plant, sump,  and
 storage tanks.  A  capacity  of  837 Mg coke/day puts  the  plant  into the
 Model  Plant 1  category.   Capital  cost estimates for Model  Plant 1 for
 sources controlled at  Armco  total $121,000 to $412,000  (1982  dollars)
 with a midrange estimate  of $267,000.   The Model  Plant  1 estimate
 appears reasonable compared to the actual  plant estimate.
      Bethlehem Steel  Corporation at  Sparrows  Point  estimated  the  cost
 of gas blanketing  the  light-oil  plant in  by-product Plant B as $44,000
 (1982 dollars).   Plant personnel  indicated that this blanketing system
 was also part of  a larger project, and all costs  could  not be identified
 clearly.15  The two by-product plants at  Sparrows Point are designed
 for a total coke  capacity of 7,100 Mg/day, which roughly equals two
 Model-2-type plants.   Costs for gas  blanketing the light-oil  plant for
 Model  Plant 2 were estimated as $72,000 to $120,000 with a midrange of
 $96,000 (1982 dollars).  Comparison with  Bethlehem's estimate of
                                   8-43

-------
$44,000 indicates this estimate may be high.  However, the estimate
encompasses a wide range of piping distances for the model plants, and
another specific plant with a different layout may incur greater
expenses than the relatively compact Sparrows Point plant would.
     Two other companies submitted cost estimates for their own design
of a gas blanketing system.  These designs were more sophisticated
than were gas blanketing systems that have been used in the industry
because of elaborate pressure controllers, alarms, blanketing tech-
niques, and redundant controls.  The two companies suggested they
might choose to use nitrogen or natural gas instead of coke oven gas
to blanket the emission sources.  These designs have not been applied
by the industry, and because the blanketing technology differs from
that recommended in Chapter 4 and analyzed  in this chapter, direct-cost
comparisons would not be valid.  However, in total capital costs,
estimates for the theoretical designs of the undemonstrated systems
were significantly higher  than was the simpler coke oven gas blanketing
"system, which has been applied in at least  three by-product recovery
plants.
8.2  OTHER COST CONSIDERATIONS
     By-product coke plants have incurred a number of regulations that
relate to atmospheric and  environmental emissions of solid waste and
water.  The Occupational Safety and Health  Administration (OSHA) has
developed occupational health  rules that restrict personal exposure of
workers to 10 ppm benzene.  (8-hour time-weighted average).  It  is
presently unclear which by-product emission sources are covered by
OSHA benzene standards and which mandated equipment and equipment
performance could be required.  The environmental control alternatives
could  effectively lower the emissions of the affected sources  and help
attain the personal exposure standard, but  the converse is not neces-
sarily true.  OSHA controls could reduce worker exposure  and have
little environmental benefit;  e.g., venting of emissions  into  the
atmosphere away from the workers.  For these reasons, the cost of OSHA
compliance is assumed to have  no influence  on potentially mandated
environmental controls.
                                  8-44

-------
     The coke oven by-product plants also have occupational health
requirements for exposure to benzene-soluble particulate materials

from the coke oven battery.  Atmospheric emission controls are required
for charging, doors, pushing, quenching, and oven leaks.  The costs
for OSHA regulations and other air and water regulations have been

included in the baseline costs, which will be analyzed  in Chapter 9,

Economic Impact.

8.3  REFERENCES
 1.  Neveril, R. B.  Capital and Operating Costs of  Selected Air
     Pollution Control Systems.  U.S. Environmental  Protection Agency.
     Research Triangle Park, NC.  Publication No. EPA-450/5-80-002.
     December 1978.  p. 3-2-3-8.

 2.  Mossman, M. J.  Mechanical and  Electrical Cost  Data:  1982,  5th
     ed.  Robert Snow Means  Company,  Inc.  1981.

 3.  National Construction Estimator:   1982, 30th ed.   Craftsman  Book
     Company, 1982.  p. 194-197.

 4.  PEDCo  Environmental,  Inc.  Technical Approach  for  a Coke  Production
     Cost Model.   (Prepared  for U.S.  Environmental  Protection  Agency.)
     EPA Contract  No. 68-02-3071, Task  1.  December, 1979.   p. 12.

 5.  Perry,  R.  H.  (ed).   Chemical Engineer's Handbook.   (Fifth Edition).
     McGraw-Hill,  Inc., 1973.  p. 9-16.

 6.  Current Prices of  Chemicals  and Related Materials.  Chemical
     Marketing  Reporter.   April 9,  1982.  p. 40-41.

 7.  Reference  1,  p.  A-9.

 8.  Reference  1,  p.  3-15-3-18.

 9.  Hall,  R.  S.,  J.  Matley, and  K.  J.   McNaughton.   Current Costs of
     Process Equipment.   Chemical  Engineering.   April 5, 1982.   89(11):
     80-116.

 10.  Happell,  J. ,  and D.  G.  Jordan.   Chemical  Process Economics.   2nd
     ed.   Marcel  Dekker.   NY.   1975.  pp.  213-255.

 11.  Wilson, P.  J., Jr.,  and J.  H.  Wells.   Coal, Coke,  and Coal  Chemi-
     cals.  New York, McGraw-Hill, 1950.  p.  44.

 12.  Guthrie,  K.  M.  Process Plant Estimating,  Evaluation, and Control.
      Sol ana Beach, Craftsman Book Company,  1974.
                                  8-45

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13.   VanOsdell, D. W., et.al.  Environmental Assessment  of  Coke
     By-Product Recovery  Plants.  U.S. Environmental  Protection  Agency.
     Research Triangle Park, NC.  Publication No. 600/2-79-016.
     January 1979.  387 p.

14.   Branscome, M. R.  Trip Report to Armco, Incorporated,  Houston,
     Texas.  March 4, 1982.  Research Triangle  Institute.

15.   Letter from McMullen, R. M., Bethlehem Steel Corporation, to
     Cuffe, S. T. , U.S. Environmental Protection Agency.  March  12,
     1982. 5 Section 114 response.
                                8-46

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                            9.   ECONOMIC IMPACT

     This chapter addresses the economic impacts of the regulatory alterna-
tives for coke oven by-product plants.   These alternatives are described in
Chapter 6 and apply to new and existing coke oven by-product plants.
Regulatory Alternatives II and III would have neglible impacts on the price
and production level of furnace and foundry coke but the regulatory alter-
natives are not expected to result in any closings of furnace or foundry
coke batteries, plants, or companies.
     Section 9.1 presents a profile of the coke industry.  Section 9.2
contains an analysis of the impacts of the regulatory alternatives, which
also addresses the potential impacts of compliance with a comprehensive
list of environmental and other controls.  These impacts are measured
against the existing state of control for all sources.  Section 9.3 presents
potential socioeconomic and inflationary impacts.
9.1  INDUSTRY PROFILE
9.1.1  Introduction
     Coke production is a part of Standard Industrial Code (SIC) 3312—
Blast  Furnaces and Steel Mills.  Coke is principally used in the production
of steel and ferrous foundry products, which are also part of the output of
SIC  3312.  Thus coke is both produced and principally consumed within
SIC  3312.  Furthermore, many producers of furnace coke are fully integrated
iron-  and steel-producing companies.  Any regulation on  coke production is
expected to have some  impact on the  entire blast furnaces and steel mills
industry with  special  emphasis on coke producers.
     This profile  has  two purposes:  (1) to provide the  reader with a broad
overview of the  industry  and (2) to  lend support to an economic analysis by
assessing the  appropriateness  of various economic models  to analyze the
industry.  Further,  the profile provides some  of the  data necessary to the
analysis itself.
                                  9-1

-------
     The industry profile comprises six major sections.   The remainder of
this introduction, which constitutes the first section,  provides a brief,
descriptive, and largely qualitative look at the industry.   The remaining
five sections of the profile conform with a particular model of industrial
organizational analysis.  This model maintains that an industry can be
characterized by its basic conditions, market structure, market conduct,
and market performance.
     The basic conditions in the industry, discussed in the second and
third sections of this profile, are believed to be major determinants of
the prevailing market structure.  Most important of these basic conditions
are supply conditions, which  are largely technological  in nature, and
demand conditions, which are determined by the attributes of the products
themselves.
     The market structure and market conduct of the blast furnaces and
steel mills industry are examined in the fourth section.  Issues addressed
include geographic concentration, firm concentration, integration, and
barriers to entry.  Market structure is believed to have a major influence
on the conduct of market participants.  Market conduct is the price and
nonprice behavior of sellers.  Of particular interest is the degree to
which the industry pricing behavior can be approximated by the competitive
pricing model, the monopoly pricing model, or some model of imperfect
competition.
     The fifth section of the industry profile addresses market perform-
ance.  The historical record of the industry's financial performance is
examined, with some emphasis on its comparison with other industries.  The
sixth section of the industry profile presents projections of key variables
such as coke production and steel production.  The seventh section discusses
market behavior.
     9.1.1.1  Definition of the Coke Industry.  Coke production is a part
of SIC 3312—Blast Furnaces and Steel Mills, which includes establishments
that produce coke and those that primarily manufacture hot metal, pig iron,
silvery pig iron, and ferroalloys from iron ore and iron and steel scrap.
Establishments that produce steel from pig iron, iron scrap, and steel
scrap and establishments that produce basic shapes such as plates, sheets,
and bars by hot rolling the iron and steel are also included in SIC 3312.1
The total value of shipments from SIC 3312 in 1980 was $50,303,900,0002 and
                                  9-2

-------
an approximate value for total coke production in 1980 was $4,648,413,000,3
or less than 10 percent of the total value of shipments.
     Coke is produced in two types of plants:  merchant and captive.
Merchant plants produce coke to be sold on the open market, and many are
owned by chemical or other companies. The majority of coke plants in the
United States are captive plants which are vertically integrated with iron
and steel companies and use coke in the production of pig iron.  At the end
of 1979, 17 plants were merchant and 43 were captive, and merchant plants
accounted for only 9 percent of total coke production.4
     9.1.1.2  Brief History of the Coke Industry in the Overall Economy.
Traditionally, the value of coke produced in the United States has con-
stituted less than 1 percent of the gross national product (GNP).5 6
During most of the 1950's, coke production was about 0.30 percent of GNP,
and during the 1960's and until the mid-19701s, coke production was only
about 0.20 percent or less of GNP.  However, in 1974, coke production as a
percent of GNP rose to above 0.30 percent.  This trend continued for the
next 2 years.  By 1979, coke production was about 0.2 percent of GNP.7 8
     Previously, U.S. .coke exports  have been greater than imports, but that
trend may be  changing.  The values  of all U.S. imports and exports and U.S.
coke imports  and exports are  shown  in Table 9-1.  From 1950 to 1972, coke
exports were  much greater than coke  imports, but after 1973, this trend was
reversed.  The same pattern applies  to the percentages of coke imports and
exports within total U.S. imports and exports.  From 1950 to 1972,  coke
exports were  a larger percentage of total U.S. exports than coke  imports
were of total U.S.  imports.   Again,  from  1973 to 1979, this trend reversed,
and coke imports were a  larger proportion of total U.S. imports than coke
exports were  of  total U.S. exports.
     U.S. coke production has always been a  substantial portion of  world
coke production.  This  share  has decreased during the past 30 years,  as
indicated in  Table  9-2.   From 1950  to 1977,  world coke production generally
increased while  U.S. coke production decreased.  This trend explains  the
decline  in  the U.S. percentage of world  coke production.
     9.1.1.3   Size  of the Iron and  Steel  Industry.   The value  of  shipments
of SIC  3312  has  increased since 1960.  There have been a  few  fluctuations
in this  growth;  for example,  as shown in  Table  9-3,  the 1965  value  of
                                  9-3

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               TABLE 9-2.   COKE PRODUCTION IN THE WORLD2 4 7
Year
 World production
(million megagrams)
  U.S.  production
(million megagrams)
U.S.  production
 as a share of
world production
    (percent)
1950
1951
1952
1953
1954
1955
1956
1957
1958
1959
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978
1979
182.3
204.1
208.9
225.6
211.5
242.3
256.8
266.1
255.0
260.4
279.7
272.0
272.9
281.7
298.5
310.3
310.4
303.9
315.8
335.8
350.5
342.7
340.5
365.8
367.4
363.3
367.2
373.5
364.7
341.0
65.9
71.9
62.0
71.5
54.4
68.3
67.6
69.0
48.6
50.7
51.9
46.9
47.1
49.3
56.4
60.7
61.2
58.6
57.8
58.8
60.3
52.1
54.9
58.4
55.9
51.9
52.9
48.5
44.5
48.0
36.1
35.2
29.7
31.7
25.7
28.2
26.3
25.9
19.1
19.5
18.6
17.2
17.3 _
17.5
18.9
19.6
19.7
19.3
18.3
17.5
17.2
15.2
16.1
16.0
15.2
14.3
14.4
13.0
12.2
14.1
  Oven  and  beehive  coke  combined.
                                  9-5

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TABLE 9-3.  VALUE OF SHIPMENTS, SIC 33128 9
Year
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
Current dollars
(millions)
15,783.8
14,873.3
15,571.6
16,418.0
18,840.1
20,841.7
21,193.9
19,620.6
21,161.1
22,299.0
21,501.6
21,971.3
23,946.7
30,365.5
41,671.7
35,659.8
39,684.1
41,897.8
1972 Dollars
(millions)
22,981.7
21,468.4
22,071.7
22,933.4
25,914.9
28,043.2
27,610.6
24,829.9
25,628.1
25,713.8
23,535.0
22,882.0
23,946.7
28,700.9
35,917.7
28,038.8
29,643.8
29,645.4
                 9-6

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shipments of SIC 3312 was the highest value between 1960 and 1972.   Since
1972, the value of shipments has remained around $30 million, with the
highest value being $35 million (1972 dollars) in 1974.
     For SIC 3312, Table 9-4 shows the value added by manufacture,  the
total number of employees, and the value added per employee.  Current and
constant (1972) dollar figures are included.  Both the total value added by
manufacture and the value added per employee peaked in 1974, the same year
in which the value of shipments for this industry was the highest.   The
increasing value added per employee might indicate that this industry is
changing to a more capital-intensive production process.
9.1.2  Production
     9.1.2.1  Product Description.  Two types of coke are produced:  fur-
nace coke and foundry coke.  Furnace coke is used as a fuel in blast
furnaces; foundry coke is used as a fuel in the cupolas of foundries.  Coke
is also used for other miscellaneous processes such as residential  and
commercial heating.  In 1978, only 2 percent of all coke used in the United
States was used for these miscellaneous purposes, 93 percent was used in
blast furnaces, and the remaining 5 percent was used in foundries.14
Time-series data for the percent of total U.S. consumption attributable to
each use are shown in Figure 9-1.
     9.1.2.2  Production Technology.  Coke  is typically produced from coal
in a regenerative type of oven called the by-product oven.  The type of
coal used in coke production and the length of time the coal is heated
(coking time) determine the end use of the  coke.  Both furnace and foundry
coke are usually obtained from the carbonization of a mixture of high- and
low-volatile coals.  Generally, furnace coke is obtained from a coal mix of
10 to 30 percent low-volatile coal and is coked an average of 18 hours, and
foundry coke is obtained from a mix of 50 percent or more low-volatile coal
and  is coked an average of 30 hours.
     The first by-product oven in the United States was built in 1892 to
produce coke and to obtain ammonia to be used in the production of soda
ash.  In such ovens, the by-products of carbonization (such as ammonia,
tar, and gas) are collected instead of being emitted into the atmosphere as
they were in the older, beehive ovens.
                                  9-7

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TABLE 9-4.  VALUE ADDED, SIC 33128 9
Year
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
Value added by
Current dollars
(millions)
6,844.4
6,546.3
6,620.9
7,506.4
8,479.6
9,379.8
9,643.6
8,910.1
9,275.8
9,853.2
9,350.5
9,563.1
10,304.7
12,769.4
17,425.8
13,356.2
14,755.5
15,021.4
manufacture
1972 Dollars
(millions)
9,965.6
9,449.0
9,384.7
10,485.3
11,663.8
12,620.8
12,563.3
11,275.8
11,233.9
11,362.1
10.234.8
9,959.5
10,304.7
12,069.4
15,019.7
10,501.8
11,022.3
10,628.6
Employees
(thousands)
550.0
503.4
502.2
500.5
532.9
565.4
559.4
533.1
533.1
537.7
526.5
482.2
469.1
502.1
518.0
451.3
451.9
441.4
Value added
per employee —
1972 dollars
(thousands)
18.1
,18.8
18.7
20.9
21.9
22.3
22.5
21.2
21.1
21.1
19.4
20.7
22.0
24.0
29.0
23.3
24.4
24.1
             9-8

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-------
     The total amount of coke that can be produced each year is restricted
by the number of ovens in operation for that year, and not all ovens are in
operation all of the time.  Oven operators try to avoid closing down a
group of ovens for any reason because of the time and energy lost while the
ovens cool and reheat and because of the oven deterioration that results
from cooling and reheating.  However, it is estimated that at any time,
approximately 5 to 10 percent of existing coke oven capacity is out of
service for rebuilding or repair.20  In a report written for the Department
of Commerce, Father William T. Hogan estimated the potential annual maximum
capacity of U.S. oven coke plants as of July 31, 1979.21  His estimates are
shown in Table 9-5.  Hogan assumes that almost 10 percent of his estimate
of total capacity will be out of service at any given time; therefore, he
subtracts the out-of-service capacity from total capacity to obtain maximum
annual capacity.
     Within the limits of the number of ovens available for coking, both
furnace and foundry coke production levels vary.  Some ovens that produce
furnace coke can be switched to produce foundry coke by changing the coal
mix and increasing the coking time.  Furthermore, some ovens that produce
foundry coke could be changed to produce furnace coke by changing the coal
mix and decreasing the coking time.  Also, some variation in the combina-
tion of flue temperature and coking time is possible for either type of
coke.  A shorter coking time results in greater potential annual produc-
tion.
     9.1.2.3  Factors of  Production.  Table 9-6 provides a typical  labor
and materials cost breakdown for furnace coke production.  Coal is  the
major material  input  in the production of coke.  In 1979, greater than 61
percent of the  coal received by coke plants was from mines that were
company owned or affiliated.23  In this same year, 14 States shipped some
coal to coke plants outside their borders.24  Of the coal received  by
domestic coke plants, over 81 percent came from West Virginia, Kentucky,
Pennsylvania, and Virginia.25  Any potential adverse  impact on the  coke
industry probably will have some impact in these States.  A total of 69.9
million megagrams  of  bituminous coal was carbonized in 1979.26
     Table 9-7  shows  employment in the by-product coke industry from 1950
to 1970 and  the percentage of total  SIC 3312 employees in the  by-product

                                  9-10

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        TABLE  9-5.   POTENTIAL MAXIMUM ANNUAL  CAPACITY OF OVEN COKE
               PLANTS  IN THE UNITED  STATES ON JULY  31, 197912

In existence
Furnace plants
Merchant plants
Total
Out of service3
Furnace plants
Merchant plants
Total
In operation
Furnace plants
Merchant plants
Total
Number of
batteries
169
30
199
(18)
(2)
(20)
151
28
179
Number of
ovens
10,076
1,337
11,413
(1,026)
(117)
(1,143)
9,050
1,220
10,270
Capacity
(Mg)
53,095,381
4,400,691
57,496,072
(5,255,001)
(460,599)
(5,715,600)
47,840,380
3,940,092
51,780,472
Batteries and ovens down for rebuilding and repair.
                                 9-11

-------
                        Percent of cost

                              77.1
                               9.4
                               6.6
                               6.9
     TABLE 9-6.   TYPICAL COST BREAKDOWNS:   FURNACE COKE PRODUCTION AND
                    HOT METAL (BLAST FURNACE) PRODUCTION13	

Furnace coke production

     Labor and materials

     Coking coal
     Coal transportation
     Labor (operation and maintenance)
     Maintenance materials

     Total labor and material costs

Hot metal production

     Charge metal!ics
          Iron ore
          Agglomerates
          Scrap
     Fuel inputs
          Coke
          Fuel oil
     Limestone fluxes
     Direct labor
     Maintenance
     General expenses

     Total labor and material costs
                             100.0
                         Percent of cost.
                              100.0
9-12

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           TABLE 9-7.  EMPLOYMENT IN THE BY-PRODUCT COKE  INDUSTRY15
Year
1950
1951
1952
1953
1954
1955
1956
1957
1958
1959
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971a
1972
1973
1974
1975
1976
1977
Number of employees
20,942
22,058
21,919
21,011
17,944
19,595
19,318
19,203
15,654
15,865
15,779
13,106
12,723
12,696
13,021
14,003
13,745
13,662
14,136
13,617
13,997
11,955
11,127
11,121
11,207
12,109
11,047
10,196
Percentage of all
employees in SIC 3312
NA
NA
NA
NA
NA
NA
NA
NA
3.06
3.13
2.87
2.60
2.53
2.54
2.44
2.48
2.46
2.56
2.65
2.53
2.66
2.48
2.37
2.21
2.16
2.68
2.44
2.31
NA = not applicable.
aFigures for 1971-1977 are estimates.  See text for more detail.
                                  9-13

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coke industry.  This table shows decreasing employment in the by-product
coke industry.  A similar decline in employment has occurred in SIC 3312.
Unfortunately, employment data for the by-product coke industry are not
available after 1970; however, these figures can be estimated by regressing
employment in the by-product coke industry on total iron and steel industry
employment and on the ratio of coke used in steel production.*  These
estimates are also shown in Table 9-7.
9.1.3  Demand and Supply Conditions
     Domestic consumption of coke from 1950 to 1980 is graphed in Figure
9-2.  In the early 1950's, the amount of coke consumption was fairly large;
an average of 65 million megagrams was consumed annually between 1950 and
1958.  The late 1950's and early 1960's showed a sharp decrease in coke
consumption, with an average of only 48 million megagrams consumed
annually.  Domestic consumption of coke increased during the mid-1960's to
mid-1970's to an annual figure of 57 million megagrams but it did not reach
the 1950 to 1957 level.  The late 1970's show another slump in coke
consumption.
     The variation in coke consumption shown in Figure 9-2 has both cyclic
and trend components.  The demand for coke is derived from demands for iron
and steel products, and these demands are sensitive to the performance of
the overall economy.  Cycles in coke demand are linked to cycles in aggre-
gate demand or cycles in demand for particular products such as automobiles.
     The trend component in coke consumption results from changes in blast
furnace production techniques.  Coke is used as a fuel in blast furnaces,
but it is not the only fuel that can be used.  Coke oven gas, fuel oil, tar
and pitch, natural gas, and blast furnace gas have all been used as supple-
ments to coke in heating the blast furnaces.  The increased use of these
supplemental fuels over the past 20 years has caused the amount of coke
used per ton of pig iron produced (the coke rate) to decrease.  Other
causes of the decline in coke rate are increased use of oxygen in the blast
     *Regressions performed by Research Triangle Institute, 1980.
                                  9-14

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furnaces and use of higher metallic content ores.   Table 9-8 shows U.S.  pig
iron production, coke consumed in the production of pig iron, and the coke
rate for 1950 to 1980.  (Data limitations make it difficult to calculate
the foundry coke rate in cupola production.)
     Recently, there has been some concern about the ability of the United
States' coke-making capacity to support domestic steel product!"on--the
major source of coke demand.  The study conducted by Hogan and Koelble of
the Industrial Economics Research Institute at Fordham University indicates
that in 1978, U.S. production of coke was 14.1 percent below domestic
consumption.31  Imports increased dramatically in that same year.  Hogan
and Koelble attribute this decline in coke production to the abandonment of
coke ovens for environmental reasons and predict a severe coke shortage by
1982.32  This prediction is disputed in a Merrill Lynch Institutional
Report by Charles Bradford.  The Bradford report attributes the lack of
adequate U.S. coke production in 1978 to two factors:  (1) a coal miner's
strike, which caused the drawing down of stocks of coke when they should
have been increasing, and  (2) the premature closing because of EPA regula-
tion of some coke ovens that normally would have been replaced before they
were closed.33  The Bradford report states that a survey of U.S. steel  .
producers revealed that all of the major steel producers are or soon will
be  self-sufficient with regard to coke-making capacity.34  The Bradford
explanation of 1978 coke imports seems more reasonable because 1979 coke
imports decreased about 1.6 million megagrams compared to the 1978 level.
Furthermore,  it seems unlikely that a severe shortage of coke capacity will
occur  in 1982 because currently there are no signs of a major shortfall in
capacity.
9.1.4   Market Structure
     Market power, the degree to which an individual  producer or groups of
producers can control market price,  is of particular  economic  importance.
Market structure  is an important determinant of market power.   Pricing
behavior  is relevant  to the choice of the methodology used  in  assessing the
potential impacts of  new  regulations.  It is important to determine  if the
competitive pricing model  (price equal to marginal cost) adequately
describes pricing behavior for coke  producers.
                                  9-16

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TABLE 9-8.  COKE RATE2 4 7
Year
1950
1951
1952
1953
1954
1955
1956
1957
1958
1959
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978
Pig iron production
(thousand megagrams)
58,514
63,756
55,618
67,906
52,570
69,717
68,067
71,128
51,851
54,622
60,329
58,834
59,546
65,173
77,527
80,021
82,815
78,744
80,529
86,186
82,820
73,829
80,628
91,915
86,616
72,322
79,788
73,931
79,552
Coke used in
blast furnaces
(thousand megagrams)
51,403
55,362
49,386
58,880
46,861
60,675
58,279
60,861
42,898
44,107
46,462
42,855
42,298
44,596
51,076
53,576
54,653
51,300
51,399
55,065
54,754
48,269
50,214
54,791
51,154
44,375
47,678
44,292
47,889
Coke rate
0.86
0.87
0.89
0.87
0.89
0.87
0.86
0.86
0.83
0.81
0.77
0.73
0.71
0.68
0.66
0.67
0.66
0.65
0.64
0.64
0.66
0.65
0.62
0.60
0.59
0.61
0.60
0.60
0.60
           9-17

-------
     Any analysis of market structure must consider the characteristics of
the industry.  This analysis addresses the number of firms producing coke;
the concentration of production in specific firms; the degree of inte-
gration in coke production; the availability of substitutes for coke; and
the availability of substitutes for the commodities for which coke is an
input to production.  Also, some information on past pricing in the coke
industry is presented.  These topics will be considered together with
financial performance (Section 9.1.5) and growth (Section 9.1.6) in asses-
sing market behavior (Section 9.1.7).
     9.1.4.1  Concentration Characteristics and Number of Firms.  This
section describes various concentration measures that can be computed for
the furnace and foundry coke industries.  Normally, concentration ratios
are used as an indication of the existence of market power.  While concen-
tration ratios are  a useful tool for describing industry structure, concen-
tration should not  be used as an exclusive measure of market power.  Many
other factors (e.g., availability of substitutes, product homogeneity, ease
of market entry) determine a firm's ability to control market price.
     As of December 1982, 30 companies operated by-product coke ovens.35
Fourteen companies  are integrated iron and steel producers; 16 companies  are
merchant firms.  These companies owned and operated a total of 55 coke
plants; 37 of these plants were captive  and 18 of them were merchant.  A
list of these companies,  their plant  locations, the major uses of coke at
each plant,  and plant coke capacities  is  given in Table 9-9.
     Reported capacities  in Table 9-9  are maximum,  nominal figures, which
do  not  include any allowance for outage  like  that estimated for the  overall
industry  in  Table  9-5.  All of the  largest plants are captive,  and most  of
the merchant plants have  very  small  capacities.   Furnace  coke production  is
concentrated in  captive plants.  Virtually all of the coke used in  foundries
and in  other industries was produced by  merchant  plants.   If coke  plant
sites were  ranked  according to  capacity,  the  top  five plant  sites  and top
ten plant sites  would have 30.9 percent  and 45.8  percent  of  total  coke
capacity,  respectively.   (A plant  site or location  may  include  more  than
one complete plant.)
      By-product  coke plants  are  concentrated  in  the States  bordering on  the
Ohio  River,  probably because  of  the coal in  that area.   Figure  9-3 shows
                                   9-18

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the number of coke plants in each State.   Pennsylvania and Ohio contain 10
coke plants each, and Indiana has 8 plants.
     Table 9-10 divides the United States into 11 coke-consuming and
coke-producing regions and shows the amount of coke produced in each region
arid the locations of coke consumption.  Most of the regions produce the  -v
bulk of the coke they consume; only three regions produce less than 80
percent of their own consumption arid only one produces more than it needs
for its own consumption.  Transportation of coke across long distances is
avoided whenever possible to reduce breakage of the product into smaller,
less valuable pieces and to minimize freight charges.
     The concentration of production or capacity in specific firms may have
economic importance.  Table 9-11 presents the percent of total capacity
owned by the largest four (of 30) firms.   The four-firm concentration ratio
for the coke industry has changed little over the years.  In 1959, the
four-firm concentration ratio was 53.5 (the top four firms own 53.5
percent of total capacity)40; in 1980 it was 54.4 percent.
     In the preceding discussion, furnace and foundry coke production are
considered jointly.  However, each existing coke battery may be considered
a furnace or foundry coke producer, based on the battery's primary use.
Separate capacity-based concentration ratios for the two types of coke are
calculated based on this allocation.  The 1980 four-firm concentration
ratio for furnace coke  is 60.0; the 1980 four-firm ratio for foundry coke
is 57.8.
     Concentration in the steel industry has economic relevance because a
large fraction of all furnace coke is produced by integrated iron and steel
companies.  Historically, the eight largest steel producers have been
responsible for approximately 75 percent of industry production.  However,
from 1950 to 1976, the  share of production attributable to the top four
firms declined from 62  percent to 53 percent.41
     In summary, concentration exists in the production of both types of
coke and in steel production.  However, the concentration is not sufficient
to guarantee market power, and many companies are involved in the pro-
duction of both coke and steel products.  Other factors must be considered
in any final assessment of market power.
                                  9-24

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TABLE 9-11.  PERCENT OF COKE CAPACITY OWNED BY TOP FIRMS
                   (JANUARY 1980)35
Firm
U.S. Steel, Inc.
Bethlehem Steel Corp.
J&L Steel Corp.
Republic Steel Corp.
Sum of largest four firms
Capacity
(103 Mg)
14,002
7,651
5,469
5,250
32,372
Percent of
total capacity
23.52
12.85
9.19
8.82
54.38
                        9-26

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     9.1.4.2   Integration Characteristics.   When one firm carries out
activities that are at separate stages of the same productive process,
especially activities that might otherwise be performed by separate firms,
that firm is said to be vertically integrated.  Through vertical integra-
tion, the firm substitutes intrafirm transfers for purchases from suppliers
and/or sales to distributors.  A firm may seek to supply its own materials
inputs to ensure a stable supply schedule or to protect itself from
monopolistic suppliers.  The firm may seek to fabricate further or
distribute its own products to maintain greater control over the consuming
markets or to lessen the chance of being shut out of the market by large
buyers or middlemen.  Therefore, the presence of vertical integration may
constitute a firm's attempt to control costs or ensure input supplies.
Vertical integration does not guarantee market power (control over market
price).
     Many coke-producing firms, especially furnace coke producers, are
vertically integrated enterprises.  As previously mentioned, 45 of the
existing coke plants are captive; i.e., they are connected with blast
furnaces and/or steel mills.  In addition, many coke firms own coal mines,
and  greater than 61.0 percent of the coal used in ovens was from captive
mines  in 1979.23  Assurance  of coal supply to coke production and coke
supply to pig iron  production appears to be the motivation behind such
integration.
     One implication of vertical integration  is that much of the furnace
coke used in the United States never enters the open market—it is consumed
by the producing company.  Accordingly, the impact analysis for furnace
coke (Section 9.2.2) uses an implied price for furnace coke based on  its
value  in producing  steel products, which are  transferred on the open  market.
     9.1.4.3  Substitutes.   Substitutes for a given  commodity reduce  the
potential for market power  in production of the commodity.  The substitu-
tion of  other inputs for coke  in blast furnaces  is somewhat  limited,  but
not  totally  unfeasible.   In  addition, electric arc furnaces, which do not
require  coke, are  becoming  increasingly  important  in steel production.  The
recent trend toward electric arc  furnaces and mini-milIs  has eased entry
into the  iron and  steel  industry, which  in turn  reduces  market  power.
                                  9-27

-------
     Imported coke can also be substituted for domestically produced coke.
In fact, although U.S. iron and steel producers prefer to rely on domestic
sources of coke, coke imports have increased recently.  If the cost of
domestic coke increased substantially compared to the cost of imported
coke, U.S. iron and steel producers might attempt to increase imports even
more.
     Furthermore, substitutes exist for the final products (iron and steel)
to which coke is an input.  Increases in the price of coke and the result-
ing increases in the price of iron and steel products can lead to some
substitution of other materials for iron and steel, which also reduces
market power in the production of coke.   Analagous substitutions for
foundry coke are possible, and cupola production of ferrous products, which
uses foundry coke, has competition from electric arc furnaces that do not
use coke.  Hence, there is a technological substitute for foundry coke in
the manufacture of ferrous products.  Furthermore, imported foundry coke
can be substituted for domestic foundry production.  In conclusion, some
substitution for coke is possible in the manufacture of both steel and
ferrous products.
     9.1.4.4  Pricing History.  As previously indicated, a significant
portion of all U.S. coke production is not traded on the market.  However,
the Bureau of Mines collects annual data on coke production and consumption
and gives the quantity and the total value of coke consumed by producing
industries, sold on the open market, and imported.  Dividing total value by
quantity yields an average price for each of these categories.  Time-series
data on these three average values are given in Table 9-12.  (Furnace and
foundry coke are combined in these figures.)
     Also shown in Table 9-12 are data on the average value of coal that is
carbonized in coke ovens.  An examination of coke and coal prices reveals
that increases in coal prices generally coincide with increases in coke
prices.   In fact, only 3 years show an increase in the price of coal that
was not accompanied by an increase in the price of the two categories of
coke.  Although it is impossible to conclude from this trend that
individual firms have market power, it indicates that the industry can pass
through some increases in costs.
                                  9-28

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    TABLE 9-12.  COMPARISON OF COAL PRICES AND DOMESTIC AND IMPORTED
                            COKE PRICES2 4 7
      Average value of
      coal
                  Average value of  Average value of
     carbonized.    oven coke used    oven coke sold   Average value of
in coke ovens '      by producers      commercially    imported coke '
           ($/Mg)
                        ($/Mg)
($/Mg)
($/Mg)
1950
1951
1952
1953
1954
1955
1956
1957
1958
1959
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978
9.56
9.85
10.17
10.19
9.92
9.74
10.31
10.92
10.90
10.89
10.90
10.79
10.86
10.46
10.23
10.48
10.78
11.05
11.03
11.49
13.46
15.43
17.34
20.19
40.22
48.73
48.68
50.99
57.37
14.26
14.50
15.11
15.36
17.33
17.90
19.39
19.98
19.82
19.16
19.92
19.12
19.53
18.88
19.17
17.89
18.40
18.58
19.57
21.54
30.30
32.86
35.76
41.34
82.32
92.84
93.83
90.57
105.79
14.54
15.72
17.63
17.96
18.95
18.52
20.27
21.51
21.90
23.03
22.32
23.30
23.36
23.24
22.85
23.90
24.49
24.99
24.25
27.01
33.04
41.29
44.87
47.31
72. 47
96.61
104.01
111.95
118.03
13.34
13.17
15.96
12.02
11.98
12.26
12.38
14.43
14.25
12.89
. 13.06
13.44
14.42
14.78
16.10
16.95
20.60
20.41
22.31
21.36
25.46
31.93
27.70
40.16
60.14
94.84
93.35
--
•• —
 Both furnace and foundry coke and the coals used to produce furnace and
 foundry coke are included in these figures.
 Market value at the oven (current dollars).
cGeneral customs value as reported by the Department of Commerce (current
 dollars).
                                  9-29

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     9.1.4.5  Market Structure Summary.  Although there is no perfect
method for measruing the extent of market power, the preceding sections
addressed four characteristics used to measure the potential for market
power—concentration, integration, substitution, and historical price
trends.  Concentration statistics indicated that some potential for market
power exists in the coke industry, yet, these statistics are not conclusive
proof.  Similarly, vertical integration in the steel industry is not     ^
conclusive in identifying the presence of market power because vertical
integration is a method of controlling the cost and ensuring the quality
and supply of inputs.  Finally, the possibility of substitution represents
a strong argument against the existence of extensive market power in the
coke-making industry.
9.1.5  Financial Performance
     Financial data on many of the coke-producing firms or their parent
firms, including captive and merchant  furnace and foundry producers, are
shown in Table 9-13.  (Data for other  firms were not available.)  From the
financial data in Table 9-13, three ratios have been calculated for each
company (Table 9-14).  The first, a liquidity ratio, is a measure of a
firm's ability to meet its current obligations as they are due.  A
liquidity ratio above 1.0 indicates that the firm is able to pay its
current debts with its current assets; the higher the ratio, the bigger the
difference between current obligations and the firm's ability to meet them.
All of the coke-producing firms have liquidity ratios between 1.0 and 3.0.
These figures are consistent with liquidity ratios for firms in a wide
variety of manufacturing industries.
     The second ratio, a coverage ratio, gives an indication of the firm's
ability to meet its  interest payments.  A high ratio indicates that the
firm is more likely  to be able to meet interest payments on its loans.
This ratio can also  be used to determine the ability of a firm to obtain
more loans.  The coverage ratio of the coke-producing firms ranged from 1.5
to 15.5.  Such ratios are equal to or  higher than the coverage evidenced  in
most manufacturing industries.
     The last of the ratios, a leverage ratio, indicates the relationship
between the capital  contributed by creditors and that contributed by the
owners.  Leverage magnifies returns to owners.  Aggressive  use of debt
                                  9-30

-------




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-------
           TABLE 9-14.   FINANCIAL RATIOS FOR COKE-PRODUCING FIRMS
Company name Liquidity ratio9 Coverage ratio
Armco, Inc
Bethlehem Steel Corp.
CF&I Steel Corp.
Crucible Steel, Inc.
Cyclops Corp.
Ford Motor Company
Inland Steel Co.
Inter! ake, Inc.
J&L Steel Corp.
Kaiser Steel Corp.
Northwest Industries, Inc.
National Steel Corp.
Republic Steel Corp.
U.S. Steel Corp.
Wheel ing- Pittsburgh
Alabama By- Products
Allied Chemical Corp.
Diamond Shamrock Corp.
McLouth Steel
Jim Walter
Koppers Co. , Inc.
Philadelphia Coke
1 •? m IT rM -t-w v*a"t* i r* — -^—
1.99
1.60
1.57
2.51
1.75
1.33
1.67
1.92
1. 27
1.43
2.30
1.71
2.03
1.67
1.63
2.21
1.43
1.96
1.54
1.98
2.24
1.54
Current assets
6.95
4.59
3.02
6.46
9.82
15.26
5.75
2.17
2.63
2.70
5.73
4.83
8.15
2.31
2.51
2.95
4.90
4.36
1.88
3.46
10.76
1.73

Leverage ratio0
1.97
2.09
1.92
2.24
2.22
2.28
2.07
2.15
2.48
2.17
2.38
2.33
1.83
2.00
2.22
2.30
2.54 ,.
2.34
2.51
3.02
1.99
2.48

                       Current  1iabi1ities
                             EBIT
Coverage  ratio  =  Annual  interest expense
'Leverage  ratio  =
Total liabilities
Tangible net worth
                                 9-33

-------
increases the chance of default and bankruptcy.   The chance of larger
returns must be balanced with the increased risk of such actions.   The
leverage ratio indicates the vulnerability of the firm to downward business
cycles.  Also, a high ratio reveals a low future debt capacity, i.e.  addi-
tions to debt in the future are less likely.   The firms with coke-making
capacity had leverage ratios that ranged from 1.8 to 3.0.  These figures
are relatively high among leverage ratios for firms in many manufacturing
industries.  Firms with coke-making capacity are engaged in substantial
amounts of debt financing.
     Another measure of financial performance is the rate of return on
equity.  Studies of the iron and steel industry show low rates of return on
equity.  In an analysis performed by Temple, Barker, and Sloane, Inc.
(TBS), the real (net of inflation) rate of return in the steel industry was
estimated to be 0.2 percent for the period 1970 to 1980.  The TBS analysis
projects a rate of return on equity of 1.0 percent for 1980 to 1990.44
These estimates of historical and projected return on equity compare very
poorly with estimates of the required return on investment in the steel
industry.  A difference between realized and required returns implies that
equity financing of capital expenditures may be difficult.
     As noted, low rates of return on equity affect common stock prices and
have implications for future investment financing, including environmental
control expenditures.  For the steel industry, issuing new stock to raise
investment capital is unlikely under current circumstances.  If environmen-
tal and other control investments cannot be financed through new equity,
another source of funds must be found.  Increased debt is one potential
source.  However, firms with coke-making capacity already have incurred
substantial amounts of debt.  The TBS analysis concludes that to avoid
deterioration in its financial condition, the steel industry is likely to
reduce expenditures to modernize productive facilities rather than increase
its external financing.45
9.1.6  Projections
     The demand for coke  is derived from the demand for  steel produced by
processes that utilize coke.  Hence, projection of the future production of
steel by process type is  a necessary precursor to the development of
projections of coke production and coke capacity requirements.
                                  9-34

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     In the initial study, steel industry projections developed by Data
Resources Incorporated (DRI) were used.  However, the DRI projections
developed during 1979 are for a short time period (up to 5 years), whereas
projections of the economic impact of the quench tower standard are re-
quired for years up to 1995.  A revised projection of steel production by
process type (basic oxygen furnace, open hearth, and electric arc) for
1985, 1990, and 1995 has been developed and is presented in Table 9-15.
This projection is based on two sources:
     1.   "Environmental Policy for the 1980's:  Impact on the American
          Steel Industry," Arthur D. Little, Inc. 1981.
     2.   Memorandum from Don Anderson, Economics Department, Research
          Triangle Institute, to Dave McLamb,  U.S. Environmental Protection
          Agency.  November 20, 1981.
In developing the projections for 1995, it is assumed that the growth of
the projected variables between 1990 and 1995 will be the same as the
growth pattern between 1980 and 1990.
     Table 9-16 presents the projection of furnace-coke consumption,
furnace-coke production, and furnace-coke imports for 1985, 1990, and 1995.
The projected furnace-coke consumption is based on a continuation of
historical trends of furnace-coke consumption in hot-steel production
(steel produced in basic oxygen and open-hearth furnace processes) and the
projected steel production presented in Table 9-15.  Furnace coke capacity
requirements are projected assuming a capacity utilization rate of 85
percent by the coke producers during the period.
     Coke capacity projection is sensitive to the level of coke imports.
Hogan and Koelble46 assert that coke suppliers in western Europe and Japan,
which are the major foreign coke suppliers to the U.S. steel industry, are
not likely to export substantial additional quantities to the United
States, in spite of the fact that U.S. coke imports have been growing
steadily.  If so, coke imports for 1985 and 1995 are more likely to remain
at about the 1985 level of imports of 3.5 million Mg during the 1985-95
period.  In Table 9-17, the coke capacity (furnace coke plus foundry coke)
is projected under two scenarios:  Scenario 1 is the long-run capacity
projection of Table 9-15, and Scenario 2 is the capacity projection,
assuming coke imports at the projected 1985 level through 1995.
                                  9-35

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       TABLE 9-15.  SUMMARY OF THE  PROJECTIONS  FROM THE  LINEAR MODEL*

1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
B!
Variable
World coke production
Furnace coke production
Foundry coke production
Furnace coke consumption
Foundry coke consumption
Coke imports
Coke exports0
Coke capacity
Capacity utilization6
Coal rate
Capital /output ratio
VHP of cokef (1979 $/Mg)

1985
427,015
39,893
2,959
43,440
2,536
3,547
423
49,115
84.37
1.40
14.00
208.27
Projections
1990
460,270
35,933
2,914
40,660
2,491
4,727
423
49,115d
80.52
1.36
18.59
262.55
Note:  Figures for variables 1-8 are in thousand megagrams.
       Figures for variable 9 are in percent.
       Figures for variable 10 are in megagrams of coal per megagrams of coke.
       Figures for variables 11-12 are in current dollars per.megagram.
aThe projection methodology includes no explicit assumption of additional
 controls like those assessed in this report.  Projections are based on nor-
 mal growth and intended to represent long-run trends in the industry.

 U.S coke production = coke demand + coke exports - coke imports.

cAssumed constant throughout the decade.
d!990 coke capacity is assumed to equal 1985 coke capacity.
eCapacity utilization = U.S. coke production/coke capacity.
fVMP stands for value of marginal product.  This is a measure of the implied
 price of furnace coke based on its value in the production of steel pro-
 ducts.  Historical estimates of VMP were based on econometric analysis of
 production functions for steel.
                                  9-36

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              TABLE 9-16.  SUMMARY OF  STEEL  INDUSTRY  PROJECTIONS
Projections

1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
Variable
U.S. steel production3
Proportion, basic oxygen furnace
Proportion, electric arc furnace3
Proportion, open hearth furnace3
U.S. steel consumption
Steel imports
Steel exports
Labor productivity
Producer price index of steel
mill products (1967 = 100)
Producer price index of ferrous
scrap (1967 = 100)
1985
132,723
64.25
27.83
7.92
154,442
23,913
2,194
347.04
287.5
324.7
1990
137,713
66.50
30.98
2.52
162,534
27,298
2,477
411.39
323.5
383.2
Note:    Figures for variables 1 and 5-7 are given in thousand megagrams.
        Figures for variables 2-4 are in percent.
        Figures for variable 8 are in thousand megagrams per employee.
3Based on estimates by Data Resources, Inc.28
 Steel consumption = steel production + steel imports - steel exports.
                                  9-37

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            TABLE 9-17.   PROJECTIONS OF COKE CAPACITY REQUIREMENTS'
                             1985,  1990, and 1995
Capacity requirements
scenario
1
2
Projections (10s Mq/yr)
1985
49,587
[46,106]
49,587
[46,106]
1990
48,578
[45,149]
49,966
[46,538]
1995
47,558
[44,182]
50,334
[46,959]
aCoke capacity includes furnace and foundry coke.  Figures in brackets
 represent furnace coke capacity.

Note:  Scenario 1 assumes imports to grow at the long-term trend;
       Scenario 2 assumes the imports for 1990 and 1995 at the 1985 trend
       1 eve!.
                                      9-38

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     Forecasts of U.S. coke demand are very sensitive to forecast steel
production and technology.  Other projections have been made of domestic
coke needs in 1985.  In a Merrill Lynch Institutional Report, Charles
Bradford forecast furnace coke consumption for 1985 at between 38.1 and
43.5 million megagrams.43  Blast furnace consumption assumed to be 92 to
93 percent of total coke consumption (figures for recent years) corre-
sponds to a forecast of total coke demand of 41 to 46 million megagrams. .,
The projection presented in this report is at the high end of that range.
However, Hogan and Koelble and Lawrence R. Smith (Koppers) forecast a much
higher coke demand for 1985.  They project the demand for furnace coke
alone at 51.7 to 53.5 million megagrams.28  These sources do not directly
address foundry coke demand; consequently, the projections for foundry coke
production cannot be compared.
9.1.7  Market Behavior:  Conclusions
     Market structure, financial performance, and potential growth
influence the choice of a methodology to describe supply responses in the
coke-making industry.  Although  some characteristics of this industry
indicate a potential for market  power, other characteristics belie it.
     Some concentration exists in coke-making capacity and steel produc-
tion; however, many firms produce coke and iron and  steel products.
Vertical integration  is substantial; however, integration appears to result
primarily from a desire for  increased certainty in the supply of critical
inputs.  Furthermore,  substitution through alternative technologies and
coke imports  is feasible, and some substitutes for the industry's final
products (iron and steel) are available.  In any industry, the potential
for substitution is a  major  factor leading to competitive pricing.
Certainly, the financial  profile of coke-making firms  is not indicative of
monopoly profits.  Prospects  for industry growth are limited.  An indi-
vidual  firm must actively compete with other firms in  the industry to
improve  its profit position.
     No  industry matches  the  textbook definition of  perfect  competition.
The important issue  is whether or not the competitive  model  satisfactorily
captures major behavioral responses of firms in the  industry.  Based on the
factors  outlined in  this  section, the competitive pricing model adequately
describes supply responses  for coke-making firms.
                                  9-39

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9.2  ECONOMIC IMPACT OF REGULATORY ALTERNATIVES
9.2.1  Summary
     Economic impacts have been projected for the baseline and for each
regulatory alternative.  Furnace and foundry coke impacts are examined
separately because their production costs and markets differ.  All cost and
price impacts are in third-quarter 1979 dollars.  To convert to 1982 dollars,
multiply by 1.25 which is the ratio of the 1982 producer price to the same
index for the third quarter of 1979, as updated in the Survey of Current
Business.46 47  When measured on a per-unit basis, the costs of meeting
baseline regulations for foundry coke plants tend to be greater than those
for furnace coke plants for two reasons.  First, some economies of scale
are present for some of the controls.  Foundry plants tend to be smaller
than furnace plants, thus, they have higher per-unit control costs.  Second,
for a given battery, foundry coke output will be less than furnace coke
output because foundry coke coking time is about two-thirds  longer than
furnace coke coking time.
     Recovery credits  cause Regulatory Alternative II to result in annualized
costs of $-1 million for furnace and foundry coke producers  combined.
Regulatory Alternative II requires capital expenditures of $23 million for
furnace and foundry coke producers combined.  Regulatory Alternative III
would result in annualized costs of $42 million and capital  costs  of $161
million for the combined furnace and foundry coke sectors.   Full  compliance
with baseline regulations measured against the  existing state of  control
results in annualized  costs of $436 million and capital costs of  $1,159
million.
     Price impacts are estimated under  the empirically supported  assumption
that furnace coke demand  is responsive  to higher  coke prices.   Foundry coke
demand  is also assumed to respond to price.  Regulatory Alternative  II
would have negligible  impacts  of $0.02/Mg and $0.19/Mg (less than 0.10 percent
change) on the prices  of  furnace and foundry coke,  respectively (1979  dollars).
Regulatory Alternative III would result in furnace  and foundry  coke  price
increases of $0.70/Mg  (0.05 percent) and $1.44/Mg (0.77 percent),  respectively.
Compliance with  baseline  regulations measured  against the  existing state of
control  increases the  furnace  coke  price by 6.4 percent and the foundry  coke
price by  15.4 percent.
                                    9-40

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     Regulatory Alternatives II and III would have little impact on the
production of either furnace or foundry coke.  Complete compliance with
baseline regulations measured against existing compliance would decrease
furnace production by 6.6 percent and foundry production by 12.2 percent.
Complete compliance with baseline regulations produces three potential
furnace battery closures and five potential foundry battery closures.  The
regulatory alternatives are not projected to result in any battery, plant,
or company closures.
9.2.2  Methodology
     The following approach focuses on the long-run adjustment process of
furnace and foundry coke producers to the higher costs of coke production
that the baseline and the regulatory alternatives will create.  These
long-run adjustments involve investment and shutdown decisions.  Short-run
adjustments, such as altering coking times, to meet the fluctuations in the
demand for coke are not the subject of this analysis.
     Because of differences in production costs and markets, furnace and
foundry coke producers are modeled separately.  Both are assumed to behave
as if they were competitive industries selling coke in a market.  This
assumption is somewhat more realistic for foundry than for furnace coke
producers because most furnace coke is produced in plants captive to the
steel industry.  However, interfirm and intrafirm shipments of coke are not
uncommon, as can be inferred from Table 9-10.  A pi ant-by-plant review of
the coke industry by Hogan and Koelble also confirms the existence of such
exchanges.48
     A set of programmed models has been developed to produce  intraindustry
and interindustry estimates of the economic  impacts of the alternative
regulations.  The models are applied to both furnace and foundry coke, and
the sectors included are coke, steel, and ferrous foundries.  The rest of
the economy is incorporated into the interindustry portion of the analysis.
     The analytical approach incorporates a production cost model of the
coke industry based on engineering data, an econometric model of the steel
industry, and an input-output model of the rest of the economy and final
demand.  The interrelationships of these models for furnace coke are shown
in Figure 9-4.  The upper portion of Figure  9-4 encompasses the supply side
impacts of the regulatory alternatives; the  lower portion contains the
                                  9-41

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demand side impacts.   In the synthesis step, the two sides are brought
together and the equilibrium price and quantity relationships are deter-
mined.  An analogous diagram for foundry coke would substitute ferrous
foundry products for steel.  The methodology is described further in the
following subsections.
     9.2.2.1  Supply Side.  A production cost model that incorporates
technical relationships and engineering cost estimates is used with
plant-specific information to compute separate industry supply functions,
with and without additional controls.49  Supply functions are estimated on
a year-by-year basis for furnace and foundry coke plants projected to be in
existence between 1980 and 1990.  Both coke production costs and the costs
that plants incur to meet existing environmental regulations are computed
to estimate the industry supply curve before any additional controls are
applied.  Estimates of the costs of control for further compliance with the
baseline regulations and the regulatory alternatives are used to compute
the projected upward shifts in that supply  function.  All costs are in 1979
dollars.
      This approach provides a method of estimating  the industry supply
curve for coke, which shows the alternative coke quantities that will be
placed on the market at alternative prices.  When the supply curve  is
considered  in conjunction  with the demand curve, an equilibrium price and
coke  output rate can be projected.  Supply  curve shifts caused by the
regulatory  alternatives can be developed from  the  compliance cost estimates
made  by the engineering contractor.  These  new supply functions, along with
the demand  curve,  can then be used to  compute  the  equilibrium price and
output rate under  each  regulatory alternative.
      9.2.2.1.1   Data base.  PI ant-by-plant  data on  over 60  variables  for
furnace and foundry coke  plants  in existence  in 1979 were compiled  from
government  publications,  industry contacts, and previous  studies of the
coke  industry.   The data  base was sent to  the  American  Iron and  Steel
 Institute,  which submitted it to  their members for verification, correc-
tions, and additions,50  and to  the American Coke and  Coal  Chemicals Insti-
 tute.
                                   9-43

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     9.2.2.1.2  Output relationships.   For a given battery,  the full  capac-
ity output of coke, measured in megagrams per year, is dependent on the
nominal coal charge (megagrams of coal per charge) per oven, the number of
ovens, and the effective gross coking time (net coking time  plus decarboni-
zation time).  The following values for effective gross coking time were
used except where pi ant-specific values were available.49 50
             Wet coal
             Preheated coal
Furnace
 coke
18 hours
13 hours
 Foundry
  coke
30 hours
24 hours
An age-specific outage rate that varies from 4 to 10 percent is assumed to
allow for normal maintenance and repair.  Thus, the model assumes some
increase in such costs as plants age.
     The quantities of by-products produced are estimated from engineering
relationships.  These quantities depend on the amount of coal carbonized,
percentage of coal volatile matter, coking time, and configuration of the
by-product facility at a plant.  The by-products included in the model are
coke breeze, coke oven gas, tar, crude  light oil, BTX, ammonium sulfate,
anhydrous ammonia, elemental sulfur, sodium phenol ate, benzene, toluene,
xylene, naphthalene, and solvent naphtha.  All plants are assumed to
produce breeze  and coke oven gas.
     9.2.2.1.3  Operating costs.  The major costs of operation for a coke
plant are expenditures for coal, labor, utilities, and chemicals.  The
activities within the coke plant were allocated to five production and ten
environmental control cost centers  (Figure 9-5) to facilitate the develop-
ment of the operating cost estimates.
     Coal is  the major operating cost item in  coke production.  Plant-
specific estimates of the delivered price of coal were developed by identi-
fying the mine  that  supplies each plant and estimating transportation costs
from the mine to the plant.  When it was not known which coal mine supplied
a particular  plant,  it was assumed  that the coal came from  the nearest
mines supplying coal of the  same volatile matter and ash content as that
used by the plant.   Transportation  cost estimates were based on the dis-
tances traveled and  the transport mode  (barge  or rail) employed.
                                  9-44

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                                                           3
9-45

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     Maintenance labor and supervision requirements were estimated for 69
jobs within the coke plant.  Primary variables that determine the number of
maintenance labor and supervision man-hours needed include type of plant
(merchant or captive), number of battery units, number of plants at a site,
size of by-product plant, type of coal charge (wet or preheated), and coke
production.  The labor rates used for captive plants were $17.04/h for
supervisory positions and $15.70/h for production labor.  For merchant
plants, rates of $15.80/h and $14.40/h were assumed.
     The major utilities at a coke plant are steam, electricity, water, and
other fuels.  Utility requirements were estimated from the data on the
plant configuration and output rates for coke and the by-products.  The
prices used for the utilities are $5.44/103 Ib steam; $0.027/kWh electric-
ity; $0.16/103 gal cooling water; and $2.76/106 Btu underfire gas.
     9.2.2.1.4  Capital costs.  Although no net additions to industry
coke-making capacity are anticipated during the 1980 to 1990 period, a
number of  producers have plans to rebuild  or replace existing batteries.
Such actions will alter the long-run industry  supply curve because the  new
batteries  will typically have lower operating  costs per unit of output  than
the batteries they replace and, most importantly, their capital costs will
be  reflected in the new supply curve.  Hogan and  Koelble43 have identified
pi ant-by-plant rebuild/replacement intentions.  These plans are included  in
the data base.  The cost of building a model new  coke battery and the  cost
of  major rehabilitation of an existing battery have been  estimated for  the
affected facilities.   It has been assumed  that new  furnace construction
will be 6-meter batteries  and new foundry  construction  will be  4-meter
batteries.   Pad-up  rebuilds are  assumed  to leave  the battery size  unchanged.
Pad-up  rebuild  costs  were  estimated  as a function of battery size.   A  zero
salvage value  is  assumed  for  existing batteries.
     The capital  cost breakdown  for  new  plants is shown in Table  9-18.   For
such plants,  the  major capital  cost  items  are  the battery, quench  tower,
quench  car,  pusher  machine,  larry  car, door machine and coke guide,  by-
product plant,  coal  handling  system,  and coke  handling  system.   A 60-oven
battery is assumed.   Pipeline charging can increase the coke-making
capacity of a given oven by  about  25 percent by  reducing gross  coking time.
                                   9-46

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          TABLE 9-18.   ESTIMATED CAPITAL COSTS OF NEW BATTERIES51
                                   Conventionally
                                  charged battery
Capital costs by element
  (106 1979 dollars)
   Pipeline
charged battery

Capacity (103 Mg/yr)
4-metera 6-metera
450 720
4-metera 6-metera
560 900
Coke battery
Quench tower with baffles
Quench car and pushing
emissions control
Pusher machine
Air-conditioned larry car
Door machine and coke guide
By-product plant
Coal -hand! ing system
Coke-handling system
Off sites
Total
34.20
2.45

6.58
2.50
1.72
1.80
32.50
18.20
6.85
1.60
$108.40
48.90
2.85

7.92 .
3.20
2.28
2.10
39.75
23.60
8.80
1.80
$141.20
64.60
2.45

6.58
2.40
0
1.80
35.76
20.62
7.74
1.69
$143.74
83.70
2.85

7.92
3.20
0
2.10
43.74
26.70
10.00
1.91
$182. 12
 In the production cost model, new foundry batteries were assumed to be
 4-meter batteries and new furnace batteries were assumed to be 6-meter
 batteries.
                                  9-47

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Consequently, the per-unit operating cost is reduced.   The capital  costs
show economies of scale, i.e., larger plants have smaller per-unit-of-
capacity capital costs.  The capital cost per unit of capacity is higher
for pipeline-charged batteries than for conventionally charged batteries.
     Periodically, batteries must undergo major rehabilitation or
rebuilding because of performance deterioration.  The costs of pad-up
rebuilds will vary from site to site depending on battery maintenance, past
operating practices, and other factors.  Average estimates of the cost of
rebuilding were developed for this  study and are shown in a report by
PEDCo.49  The economic  life of coke-making facilities is subject to
considerable variation  depending upon past maintenance and operating
practices, which  also  affect current operating  costs.  For this study, 25
years was used  as the  average preferred  life of a new coke-making facility;
however, many batteries are operated for 35 to  40 years.  If  35 to 40 years
is  a more reasonable battery  lifetime, use of a 25-year  lifetime will
result  in some  overestimation of the annual costs of new or rebuilt facili-
ties.   However,  firms  will probably not  plan or expect to wait 35 to
40  years to  recoup  an  investment in coke-making capacity.
     9.2.2.1.5   Environmental costs.   Plant-specific estimates of the
 installed capital and  operating costs  for  current and  proposed environ-
mental  regulations  and the  regulatory  alternatives  under consideration  in
 this  study were incorporated  in the model.  The current  and proposed
 regulations  include workplace standards  (Occupational  Safety  and Health
 Administration) [OSHA], water quality  regulations best practicable
 technology  [BPT] and best available technology [BAT],  State  implementation
 plan (SIP)  requirements,  and  proposed  air quality regulations for topside,
 charging,  and door leaks (National Emission Standard for Hazardous  Air
 Pollutants)  [NESHAP] and quench towers (New.Source  Performance Standards
 [NSPS].  Compliance expenses  already incurred for all  plants  in  the data
 base for each of the current and proposed regulations (existing  control
 costs) were estimated.  Therefore, it was possible to estimate the remain-
 ing environmental costs to plants  to meet current and proposed regulations
 (baseline control costs).  It has  been assumed that costs to comply with
                                   9-48

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OSHA and BPT water requirements under the Federal Water Pollution Control
Act will have to be incurred by 1981.  Costs for all other existing
environmental regulations are assumed to be incurred by 1983.
     The scatter diagrams in Figures 9-6 and 9-7 show estimates from the
coke supply model of average total cost of production in 1980, including
environmental costs, for all furnace and foundry coke plants.  A weak,
inverse relationship between the average cost of production and the size of
the plant is evident in Figures 9-6 and 9-7.  However, a number of other
factors create variability in the average cost of production across coke
plants.  The most important of these factors are the delivered price of
coal, the age of the plant, and the by-products recovered.
     9.2.2.1.6  Coke supply function—existing facilities.  The operating
and capital cost functions were used to estimate the cost of production,
including relevant environmental costs, for all plants in the data base.
This cost does not include a return on investment for existing facilities.
The capital costs for these facilities have already been incurred and do
not affect operating decisions.
     Capital costs that have not yet been incurred are annualized at 6.2
percent, which is estimated to be the real  (net of inflation) cost of
capital for the coke industry.  (This percentage is an after-tax estimate.)
This figure, which was estimated from data  on the capital structure for
publicly owned steel companies, has  been used in this study  as the minimum
acceptable rate of return on new facilities.52
     The capital costs of controls affixed  to coke oven batteries are
annualized under two different assumptions.  For scenario A, it is assumed
that when a battery reaches the end  of its  useful life, it is rebuilt or
replaced by a battery of the same height.   If this situation occurs, most
of the  control equipment is salvageable.53  Accordingly, under scenario A,
each annualization  is performed over the life of the control equipment.
     However, not every battery is rebuilt.or replaced at the end of  its
useful  life.  Similarly, some old batteries are  replaced by  new batteries
that are not comparable in  size (height).   In such cases, capital expendi-
tures  for affixed,controls  must be recouped by the time battery retirement
occurs.  Under scenario B,  this control equipment is assumed to be com-
pletely unsalvageable.  Annualizations are  performed over the remaining
                                  9-49

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                300        600        300       1,200      1,500      1,800


                       PRODUCTION CAPACITY  CTONNES*1'000/YR5



             Figure 9-6.  Estimated average cost of furnace coke production as a function

                                  of plant production, 1980.
                                                                       2, 100
                                        9-50

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   o
   I—
    o
    (O —
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                         100                200                SCO


                       PRODUCTION  CAPACITY  (TONNES*1000/YR)



             Figure 9-7. Estimated average cost of foundry coke production as a function of

                                    plant production, 1980.


                                          9-51
                                                             4CO

-------
life of the battery or over the control life, whichever is smaller.
Estimates of remaining life for existing batteries are based on a long
total life (40 years) because some batteries are being kept in operation
for 40 years.  While 40 years is longer than the preferred average life of
a battery, it is not necessarily longer than the battery's realized life.
     The regulatory alternatives for coke oven by-product plants involve
control equipment that is not affixed to batteries.  Accordingly, the
equipment is not affected by battery age or size (height) of the battery
replacement.  The capital costs of the regulatory alternatives are annual-
ized over the life of the control equipment (10 years).  This action is
tantamount to assuming either that all by-product plants have a remaining
life of at least 10 years or that the control equipment is salvageable.
     The supply function for each plant is estimated as follows:  the
average cost of production is computed for each battery in the plant; these
batteries are arranged in increasing order of their average costs of
production and the output for each battery is accumulated to produce a
stepped marginal cost function  for the plant; plant overhead costs are
averaged for all relevant plant output rates; and  average'total costs are
computed for each output rate by  summing the average costs for plant
overhead and the battery.  Each plant's supply  function is the portion of
the marginal cost function above  the average total cost function.  For  -
existing plants where the average total cost exceeds marginal cost over the
entire range of output, the  supply function  is  the point  on the plant's
average total cost function  represented by capacity output  (after allowing
for outages).  The aggregate long-run  supply function  for all currently
existing  coke plants and batteries is  obtained  by  horizontally  summing the
supply function for  each plant.  The  1980  industry marginal cost  (supply)
curves for existing  furnace  and foundry coke plants are presented  in
Figures 9-8 and 9-9, respectively.
      9.2.2.1.7  Coke supply  function—new  facilities.  The  cost of coke
production for  new furnace  and foundry batteries  was  estimated  from  the
engineering cost  model,  assuming the  new model  plants  described previously.
These costs include  the normal  return on  investment and  allowances  for
                                   9-52

-------
    O
    oo-
o
CO
o
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    o
    o-
       I
      J.
    o.
    00
                     AVERAGE COST
                     MARGINAL COST
0   -
                                                              40,000





                Figure 9-8.  Marginal and average cost functions for furnace coke, 1980.
10,000        20,000         30,000

         PRODUCTION CTONNES*1000/YR}
SO,COO
                                      9-53

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   depreciation and corporate Income taxes.  When expressed on a per-unit
       9.2.2.2  Pemand Side.   The  demand for coke Is derived fro. the  demand
   or products that use coke  as  an input to production-priori ly stee
  ferrous foundry products.   » demand function for furnace coke was d  i

    o™ ::Ty r:ling the  fmpacts ot changes <- f— •=•«» p~   -
  tion costs on the steel  industry.54
       The econometric  model  of the steel  industry has  two  sectors-  stee!
  an  coke.   The stee,  sector  includes domestic stee, supply, steei
  and exports,  and  stee, consumption (stee,  supp,y p,us  Imports minus
  exports).   Simi,ar,y, the mode, of the coke sector consists of domestic
  coke supp,y,  domestic coke demand, and coke imports and exports.  The two
 U.S. import demand.
     ,t                                             to  estimate the
      -sector mode!.   Two-stage ,east souares were used  to estimate the
 Afferent components  of the stee, sector.   Visua,  inspections of the corre-
  a ,on matnx and 3 p,ot of the dependent  variaMe  versus the residua
 indicated no mu,tico,,inearity or heteroscedasticity prob,en,s   The
 Durbin-Watson statistic showed no evidence of autocorrelation'
     The  econometric estimation of the  coke sector was comp,icated by  the
   a  ,  share  of tota,  domestic production that is traded in the  market.   he
 fact that very ,,tt,e coke is actua,,y  so,d creates concern  over the
 reported price of coke.   Therefore, estimates of the implied price  of  coke

                      °n  the
          in
•     An attempt was made to derive a demand function  for  foundry coke in an
  a    us manner.  However, the re,evant coefficient  estimates were not
statistical  significant at a reasonab,e ,„.,.  A direct estimation of'
                                9-55

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     TABLE 9-19.   ESTIMATES OF ELASTICITIES OF STEEL AND COKE MARKETS
                                                 Point
                                                estimate
              Interval
              estimate
1.   Percent change in furnace coke demand
     for 1 percent change in the price of
     furnace coke

2.   Percent change in foundry coke demand
     for 1 percent change in the price of
     foundry coke

3.   Percent change in import demand for 1
     percent change in the price of furnace
     coke

4.   Percent change in price of steel for
     1 percent change in the price of
     furnace coke

5.   Percent change steel demand for 1
     percent change in the price of steel

6.   Percent change in steel imports for
     1 percent change in the price of steel
-1.17b'c    (-1.06, -1.29)
-1.03'
 1.88
 0.14L
-1.86"
 1.51"
(-1.68,  5.44)
(0.139, 0.141)
(-0.54, -3.18)
(0.51, 2.51)
 Note:   Estimates  are  based  on  the empirical analysis  using annual data for
        the years  1950-1977  with  a structural econometric model of steel and
        coke  markets.

 alnterval estimates are  based  on 95  percent confidence  level.

  Derived  from the production function  for  steel.
 Significantly different from  zero at  1 percent  level of statistical
  significance.
 Calculation based on the theoretical  relationship  between  input demand
  elasticity  and input cost  share in  the production  of foundry  products.
  Accordingly, no interval is provided.
                                   9-56

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the demand function, based on the prices of foundry coke, foundry coke
substitutes, and complementary inputs, was also attempted.  Unfortunately,
the precise data necessary to properly estimate the demand function was not
readily available from published sources.  Accordingly, the elasticity of
demand for foundry coke was estimated based on the theoretical relationship
between the production function for foundry products and the derived demand
function for inputs to foundry production.  This elasticity calculation is
based on a 3-year average of the cost share of foundry coke in foundry
production.  This estimate is presented  in Table 9-19.
                                                                 i
     9.2.2.3  Synthesis.  Separate linear functions were fit to the furnace
and foundry coke marginal cost values depicted in Figures 9-8 and 9-9.  As
illustrated in Figure 9-10, each supply  function is used with the demand
function for the appropriate type of coke to compute the initial equilibrium
price-quantity values (P.^ and 0^ in Figure 9-10).  The supply function is
reestimated for each regulatory alternative (S1 in Figure 9-10), and the
new equilibrium price-quantity values are predicted.
     9.2.2.4  Economic  Impact Variables.  Table 9-20 shows the specific
economic variables  for which impacts are estimated.  The methodology
presented previously was designed to provide industry-level estimates of
these impacts.  The conventional demand  and supply partial equilibrium
model of a  competitive  market was chosen for this analysis because  it was
believed to represent the key characteristics  of the coke market and many
of the  impacts of  interest can be readily estimated from  this model.  In
Figure  9-11, DO' represents the derived  demand for coke.  The line  cd
represents  the supply of coke.  The equilibrium price  and quantity  are P^
and 0,, respectively.   The area OcdQ, is the total cost  of coke production,
OP,dQ,  is  the total revenue, and cP-^d represents before-tax profits.  The
total cost  of coke production  (OcdQ,) can be divided  into costs incurred  to
produce coke per se (OabQ,) and the costs being  incurred to meet existing
environmental and  other regulations (acdb).
     The  regulatory alternatives will increase the cost  of coke production
by shifting the  supply  function to ef.   Given  the  demand and  supply func-
tions as  drawn  in  Figure 9-11,  higher costs of production will  lead to
higher  prices.   If there were  no substitutes for coke  and no  decrease  in
                                  9-57

-------
S/Q
               Q
                             S'
                                            Q/time
       Figure 9-10.  Coke supply and demand.
                      9-58

-------
        TABLE  9-20.   ECONOMIC  IMPACT VARIABLES AND AFFECTED SECTORS
Variable
Price
Output
Profits
Costs
Plant closures/openings
Capital requirements
Factor employment
Labor
Metallurgical coal

Furnace
coke
X
X
X
X
X
X
X
X
Sector
Foundry
coke Steel
X X
X X
X
X

X
X
X

Final
demand
X






Imports
                                  9-59

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Figure 9-11.  Coke demand and supply with and without
                regulatory alternatives.
                             9-60

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the production of coke-using products, the rate of coke consumption would
remain at Q-,  annually and the price of coke would increase to P_.   The cost
of the regulatory alternative would be cefd.  However, a production decrease
is more likely.    As shown in Figure 9-11, the price would rise to P, and
the quantity demanded would fall to Q_.  The actual costs of the regulatory
alternative are ceik, and profits before income taxes are eP~i.
9.2.3  Furnace Coke Impacts
     As described in Section 9.2.2 of this analysis, the fgrnace coke
industry has been modeled as a competitive industry supplying coke to the
steel industry.   This definition implies the existence of interfirm and
irftrafirm shipments of coke.  However, no allowance has been made for coke
transportation costs, although coal transportation costs are included in
the cost of coke production estimates.  Coke plants and their associated
steel mills are typically clustered together.  As noted in Section 9.1.4.1,
most coke is consumed within the region where it is produced.  Hence,
transportation across great distances  is uncommon.  Therefore, the omission
of coke transport costs should not greatly influence the calculations.
     Trend projections for the 1980 to 1990 period in coke and steel produc-
tion and consumption were presented in Section 9.1.  The baseline values
for 1983, presented  in Table 9-21, are based on these projections.  The
projected values for 1983 were assumed to reflect full compliance with  ,M
applicable SIP, OSHA, water, and other air quality regulations, including
recommended standards (which may or may not be imposed) for topside, charg-
ing, and door leaks  (NESHAP) and quench towers (NSPS).  The coke supply
model was used to compute the price of furnace coke, costs, revenues, and
profits, given these trend projections.  Coal consumption and  employment
projections were made using current coal- and labor-output ratios.  The
supply function was  reestimated assuming only existing levels  of control
for all emission sources.  This estimation was used to determine the impacts
of moving from existing to baseline control  for all sources.   These impacts
are also presented  in Table 9-21.
     Table 9-22 presents the capital  and operating costs that  have yet  to
be incurred,  but that must be incurred in meeting  the baseline for all
                                  9-61

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sources.   Table 9-22 also provides an estimate of the costs that have
already been incurred to meet existing and proposed regulations (the base-
line) for all sources.
     9.2.3.1  Price Effects.   The price of furnace coke is assumed to be
established in a competitive market.  In the basic model of a competitive
market, the interaction of supply and demand determine the equilibrium
price.  This price is dependent on the costs of production of the marginal
producer and the value of the product to the marginal buyer.  The marginal
producer is the producer who is willing to supply the commodity at the
market price because he is just covering all his costs at that price.  The
marginal  buyer is just willing to pay the market price.  Other buyers who
value the product more still pay only the market price.
     Estimates of the demand and supply functions for furnace coke are
necessary to develop projections of the equilibrium price for furnace coke
with and without increased control.  The supply of furnace coke as shown
previously would be shifted by the regulatory alternatives.  The demand for
furnace coke has been econometrically estimated and found to be responsive
to price changes.  The estimated elasticity of demand for furnace coke is
-1.2.  This responsiveness reflects the substitution of other fuels for
coke in blast furnaces; the substitution of other inputs, primarily scrap,
for pig iron in steelmaking; and the substitution of other commodities for
steel throughout the economy.
     Higher prices for coke will increase the cost of steel production
unless there is a perfect substitution between coke and other inputs to
steelmaking.  In that case, the consumption of coke would decrease to zero.
If substitutions for coke in steelmaking were not possible  (i.e., input
proportions were fixed), the steel price increase would be the percentage
change in coke price times the share that coke represents in the cost of~
steelmaking  (14.3 percent) times the base price of steel.  This assumption
is used to develop maximum steel price effects.
     Table 9-23 presents the furnace coke and steel price impacts of the
regulatory alternatives.  This table also shows the impacts on prices
caused by the change from existing  to baseline levels of control for all
                                  9-64

-------
          TABLE 9-23.   PRICE EFFECTS OF REGULATORY ALTERNATIVES-
                            FURNACE COKE, 1983a
                              (1979 dollars)
                                             Coke
                                            ($/Mg)
                 Steel
                 ($/Mg)
Price assuming existing controls

Price increase caused by moving
  from existing to baseline
  controls

Price increase caused by moving
  from baseline to Regulatory
  Alternative
    II
    III
122.26

  7.84
  0.02
  0.70
405.83

  3.53
  0.01
  0.30
 Regulated sources included in the base.line are described in Table 9-21.
                                  9-65

-------
sources.   Complete compliance with the baseline measured against current
control increases the coke price by 6.4 percent.   The proposed regulatory
alternatives are not likely to affect coke prices.
     9.2.3.2  Production and Consumption Effects.   The estimated demand and
supply relationships for coke are used to project the production and con-
sumption effects of the regulatory alternatives.   As shown in Table 9-24,
the changes in coke production and consumption are fairly small for the two
regulatory alternatives.  Moving from existing to baseline levels of control
reduces coke production by 6.6 percent.
     Imported coke is a close substitute for domestically produced coke.
Imported coke is not a perfect substitute because coke quality deteriorates
during transit and contractual arrangements between buyers and sellers are
not costless.  However, increases in the costs of production for domestic
plants will increase the incentive to  import coke.
     The projected increases  in coke imports are  reported in Table 9-24.
As illustrated below, coke imports have increased significantly since 1972.
                         Year      Imports (1Q3  Mg)
                         1972           168
                         1973           978
                         1974         3,211
                         1975         1,650
                         1976         1,189
                         1977         1,659
                         1978         5,191
                         1979         3,605
     The  recent  increase  in  imports  is believed to  be  the result  of  a  coal
 strike in the United States  during  1978  combined  with  depressed conditions
 in the market for steel  in the  countries  exporting  coke to  the United
 States.   Accordingly,  continued importation  at a  high  level  may depend upon
 future market conditions  for steel  in other  countries.   In  any case, the
 change in coke imports  projected for all  the  regulatory alternatives is
 smal1.
      9.2.3.3  Coal  Consumption  and Employment Effects.   Any reductions in
 coke and steel production are expected to cause reductions  in the use of
 the  factors that produce them.   The major inputs  to coke production are
 coal  and labor.   Labor is also  an important  input in coal  mining.
                                   9-66

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     The coal consumption and employment implications of the projected
reductions in coal, coke, and steel production are shown in Table 9-25.
These values were developed assuming constant coal- and labor-output ratios.
The employment impacts shown do not include the estimated increases in
employment caused by the regulatory alternatives.  Therefore, the employ-
ment impacts represent maximum values.
     9.2.3.4  Financial Effects.
     The aggregate capital costs of the regulatory alternatives are summar-
ized in Table 9-26.  Capital costs have also been summed across member
plants to determine the cost to each coke-producing company of meeting
baseline and alternative regulations.  The total capital costs by company
may be used to produce ratios that express the relation between:  (1)  total
capital cost and the average net income of the company and (2) total capital
cost and the annual average net capital investment of the company.  This
analysis is presented to give some insight into the distribution of the
financial effects across coke-producing firms.
     The ratio of capital cost to  net  income may be used as a measure  of
the ability of each company to finance the capital cost.  The larger the
ratio, the more  likely a company will  be  to have capital shortage problems
and to have to rely upon external  debt financing.  The second ratio, the
ratio of total capital cost to annual  average  net  investment, is an indicator
of whether the usual  sources of  investment capital available to the firm
will be sufficient to  finance the  additional capital  costs caused by the
regulatory alternatives.  The larger  this ratio, the  greater the possibility
that  investment  needed to comply with the regulatory  alternatives would
significantly  reduce  investment  in other  areas.  Thus, both  ratios provide
some  insights  regarding  the degree to which  firms  will be  able  to  finance
the controls  required to meet the  regulatory  alternatives  without  a serious
impact  on  their  financial position.
      Financial  analysis  is  necessarily restricted  to  companies  for which
financial  data are publicly  accessible.   Therefore,  financial  analysis
cannot  be  conducted for  privately  owned  companies.   These  companies are
usually the  smallest in  a given industry, and they probably  experience
higher  per unit costs of regulation and  higher costs  for securing  financing
than  do larger companies.
                                   9-68

-------
          TABLE 9-25.   COAL CONSUMPTION AND EMPLOYMENT EFFECTS OF
               REGULATORY ALTERNATIVES—FURNACE COKE,  1983
Coal
consumption
for coke
(103 Mg/yr)
Employment (jobs)
Coalc
mining
Coke
plant
Steel -
making
Change caused by moving from
  existing to baseline controls
                      -3,365
-1,077   -478    -7,708
Change caused
  baseline to
  native
    II
    III
by moving from
Regulatory Alter-
                         -12
                        -284
    -4
   -91
 -2
-40
 -26
-651
 Regulated sources included in the baseline are described on Table 9-21.

 Employment impacts are based on input-output relationships and production
 impacts.  Impacts on coke plant employment do not include jobs created by
 the relevant controls.

 Annual labor productivity in coal mining is estimated as 3,125 Mg/yr/job.
                                  9-69

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         TABLE 9-26.   INDUSTRY CAPITAL REQUIREMENTS OF REGULATORY
                     ALTERNATIVES—FURNACE COKE, 1983

                                                Capital costs
                                                of regulations
                                                (106 1979 $)
Capital costs caused by moving from
  existing to baseline controls

Capital costs caused by moving from
  baseline to Regulatory Alternative
    II
    III
1,008
   22
  137
Calculated for all plants projected to be in existence in 1983.48 50

 The regulated sources included in the baseline are described in Table 9-22.
                                  9-70

-------
     A further complication of financial  analysis is that many coke-producing
companies are wholly owned subsidiaries of larger, highly diversified
corporations.  Financial data are available for the parent corporations
only.  Analysis of these data will probably lead to the conclusion that the
parent companies have ample resources to finance additional capital costs.
However, the extent to which these corporations will make such investments,
or will cease some coke operations in favor of other investment opportuni-
ties evidencing higher rates of return, cannot be determined without knowl-
edge of the required return on investment specific to the firm and the
other investment opportunities that exist for the firm.
     Table 9-27 provides estimates of the capital costs of meeting the
baseline regulations and of each  regulatory alternative as a percentage of
average annual net income  for each furnace-coke-producing company.  Whenever
possible, average annual net income was computed  for each company by averag-
ing  net income data  (in constant  1979 dollars) for 1977 to 1981.  In some
instances, less than 5 years of data were available.   In the case of
companies that are subsidiaries of other companies, the net income figures
used were those of the  parent companies.  Because of the approximate nature
of this analysis, the companies are  represented  by alphabetic  characters.
     Table 9-27 indicates  that the most capital-intensive  regulatory costs
are  associated with  meeting baseline regulations.   Regulatory  Alternatives II
and  III do not  impose capital costs  in excess  of 18 percent of net income
for  any  of the  companies.  The costs of the  regulatory alternatives  could
most likely  be  met with internal  financing.
      The  costs  of meeting the baseline regulations  simultaneously with each
of  the regulatory alternatives are given  in  Table 9-28 and are expressed, as
 ratios of compliance capital  costs to  average  annual  net income.   For  7 of
 the  15 analyzed firms,  each  regulatory alternative in  combination with the
 baseline  has associated .capital  costs  in  excess  of 50  percent of net income.
 For 2 of these firms,  G and  M, associated capital costs are  in excess  of
 100 percent  of net  income.  These companies  may  experience difficulties
 financing control expenditures.   However,  the  bulk of the expenditures
 required are pending baseline expenditures.   Slowness  in meeting baseline
 regulations  may signal  the intention to  retire facilities.   Nonetheless,
                                   9-71

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given that the average annual net income figures are those for the parent
companies, the cost of each regulatory alternative in combination with the
baseline may be prohibitive to several of the firms.
     Net income does not represent the sum of cash available annually to
the company.  Cash flow also includes the amount written off to depreciation,
depletion, and amortization.  Cash flow was not used as the denominator in
computing these ratios because depreciation accounting practices vary
widely among companies, and consistency of the data would have suffered.
However, the implication is that the ratios are somewhat overstated because,
in practice, additional cash is available to the company.
     Table 9-29 provides the ratio of capital costs to average annual net
investment by company for the baseline and each regulatory alternative.
The average annual net investment was calculated from financial records in
the same manner as average annual net income.  However, in many instances,
only 2 years of data were available.  This ratio compares the relative
amounts of the investment required for regulatory compliance and normal
investment by the firm.  The ratio provides some indication of the degree
to which investment required for regulatory compliance might crowd out
normal investment.
     Again, the bulk of compliance costs are associated with meeting baseline
regulations.  The regulatory alternatives impose capital costs as a percent-
age of average annual net investment between 0 and 6 percent.  Cumulative
capital cost to net investment ratios (baseline costs summed with costs of
each regulatory alternative) are given in Table 9-30.  Two of these firms
have cumulative ratios in excess of 50 percent; this might be prohibitively
large.
     The leverage ratios presented in Table 9-14 indicate that coke-producing
firms are engaged in a substantial amount of external financing.  These
firms may be reticent (or unable) to borrow more heavily.  Furthermore,
financing capital expenditures by issuing additional  common stock would
tend to dilute existing stockholder equity.  Considering the low historical
return on investment in the industry, this dilution would probably be
unacceptable.   An analysis of the iron and steel industry undertaken by
Temple, Barker, and Sloane, Inc. ,53 addresses the question of external
financing with regard to water pollution control expenditures.  This
                                  9-74

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analysis concludes that to avoid deterioration in its financial  condition,
the industry is likely to reduce expenditures to modernize production
facilities rather than increase its external financing.
     9.2.3.5  Battery and Plant Closures.   Battery closure candidates are
batteries that have marginal costs of operation greater than the projected
price of coke.  Some batteries are closure candidates under existing
regulatory controls while others become closure candidates when total
compliance with baseline regulations is posited.  No other batteries become
closure candidates when the regulatory alternatives are added.
     Under the existing state of control,  nine furnace batteries are closure
candidates.  When compliance with all baseline regulations is posited,
three additional batteries become closure candidates.  None of the regula-
tory alternatives adds to the closure list.  Hence, the total impacts under
the most stringent combination of regulatory alternatives include
12 batteries as closure candidates.
     The 12 batteries identified as closure candidates under baseline
control are owned by six companies and are located in seven plants.  Three
entire plants are closed under baseline conditions; no entire companies are
closed.
     The number of closure candidates under any regulatory scenario  is
extremely  sensitive to the projections of coke demand and coke imports for
1983.  A 10-percent increase in projected 1983 coke production would reduce
the list of closure candidates under the baseline to seven batteries in
five plants owned by four companies.
     The decision to close a battery is more complicated than the basic
closure rule would indicate; this  is particularly true for integrated iron
and steel  producers.  Continued access to profits from continued steel
production is a key factor  in the  closure decision for a captive battery.
Before closing or idling a  coke battery, managers would want to know where
they would get coke on a reliable  basis in  order to continue making  steel.
The obvious sources to be investigated include other plants within the same
company, other companies, and foreign suppliers.  As noted in Section 9.1,
some interregional and international movement of coke occurs.
                                  9-77

-------
     Obtaining coke from offsite sources introduces two potential complica-
tions:  the cost of transporting coke and the certainty of the coke supply.
Obtaining coke from a nearby source might be the most profitable alternative
to transporting coke.  If coke must be shipped over long distances, onsite
production at a cost above the projected market price might be more profit-
able.  Three of the battery closure candidates under the baseline are
located some distance from most other coke-producing facilities.
     If coke must be purchased, certainty of supply is a complication.
Steel producers prefer to have captive sources of coke to safeguard against
supply interruptions, and they may be willing to pay a premium for this
security.  Producing at a cost above market price would involve such a
premium.  Five of the twelve closure candidates under the baseline produce
at marginal costs that are less than 3 percent above the projected market
price.  Another two of the twelve closure candidates under baseline
compliance produce coke at marginal costs that are less than 5 percent
above the market price.  If 5 percent is not an excessive premium to pay
for certainty of supply, these batteries would not close.
     Several other factors could affect a particular plant's decision to
close a battery.  These factors relate to the relationship of coke quality
to the type of steel commodities produced, the existence of captive coal
mines, and required control and other expenditures.
     The developed demand model uses a single coke price, which represents
an average quality of coke used to produce a weighted average mix of steel
products.  If high production costs for a particular battery are associated
with a higher than average quality of coke, continued production might be
justified.  Production would also be justified if the firm produces only
the most highly valued steel products.
     Some coke-producing firms also own coal mines and may wish to secure
continued access to profits from coal mining.   Because profits in the coal
sector may be subject to less effective taxation because of depletion
allowances, these profits may be extremely attractive.
     Under the baseline, over half of the battery closure candidates have
incurred over 80 percent of projected baseline control  expenditures.  Three
of the battery closure candidates have incurred less than 30 percent of
                                  9-78

-------
projected baseline expenditures.   Furthermore, an integrated iron and steel
producer must consider the question of necessary expenditures for its
entire steel plant.   If the steel facility is old or if substantial addi-
tional expenditures will be necessary to comply with regulations on other
parts of the facility, then closure is more likely.
     As can be concluded from the preceding discussion, closure decisions
are so specific to individual situations and managers'  perceptions regard-
ing their future costs and revenues that exact projections of closures
should be viewed with caution.
9.2.4  Foundry Coke Impacts
     Oven coke other than furnace coke represents less than 10 percent of
U.S. coke production.   The majority of it is used as a fuel in the cupolas
of foundries.  The remainder is used for a variety of purposes, especially
for heating.
     Projections of various foundry coke variables in the absence of the
regulatory alternatives are presented in Table 9-31.  These projections are
based on historical trends in foundry coke production and consumption
extrapolated to 1983 and on the coke supply model.  Table 9-31 also provides
estimates of the impacts of meeting the baseline for all regulations meas-
ured against the existing state of control.  Table 9-32 presents the cost
already incurred and the costs yet to be incurred to meet current and
recommended regulations.  Some or all of the recommended regulations may
not be promulgated.
     9.2.4.1  Price and Production Effects.  In developing the estimates of
price and quantity impacts, a vertical shift caused by each regulatory
alternative has been projected in the linear estimate of the foundry coke
supply function generated under the regulatory baseline.  This shift is
used in conjunction with an estimated elasticity demand for foundry coke of
-1.03.  The projected price and quantity effects of these shifts are pre-
sented in Table 9-33.
     Complete compliance with the baseline, measured against the current
state of control, increases the foundry coke price by 15.4 percent.  This
price increase causes a 12.2-percent reduction in foundry production.  The
proposed regulatory alternatives do not cause any significant change in
coke price or coke output.
                                  9-79

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-------
    TABLE 9-33.  PRICE AND QUANTITY EFFECTS OF REGULATORY ALTERNATIVES
                            FOUNDRY COKE, 1983a
                              Coke price impact
                                (1979 $/Mg)
                    Coke quantity impact
                        (103 Mg/yr)
Value assuming exist-
  ing controls

Change in value caused
  by moving from exist-
  ing to baseline con-
  trols
163.62
 25.19
3,389
 -412
Change in value caused
  by moving from baseline
  to Regulatory Alterna-
  tive
    II
    III
  0.19
  1.44
   -3
  -24
 Regulated sources included in the baseline are described in Table 9-31.
                                  9-82

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     9.2.4.2  Coal Consumption and Employment Effects.   Any reductions in
foundry coke production are expected to cause reductions in the use of the
factors that produce the foundry coke.   The major inputs to foundry coke
production are coal and labor.  Labor is also an important input in coal
mining.
     The coal consumption and employment implications of the projected
reductions in coke production are shown in Table 9-34.   These values were
developed assuming constant coal- and labor-output ratios.  The employment
impacts shown do not include any employment increases caused by the regular
tory alternatives.  Consequently, the employment impacts represent maximum
values.                                                                   :
     9.2.4.3  Financial Effects.  The aggregate capital costs of the
regulatory alternatives are summarized in Table 9-35.  The capital require-
ments to meet Regulatory Alternatives II and III for the foundry coke
industry are $3 million and $19 million, respectively.   Capital costs have
also been summed across member plants to determine the cost to each company
of meeting baseline and alternative regulations.  These company capital
costs, along with firm-specific financial data, are used to produce the
same two financial ratios as described above for furnace coke:  (1) total
capital cost to net income and (2) total capital cost to net capital
investment.  Financial data are not available for the foundry coke producers
that are privately held companies.  Therefore, ratios for these companies.
are not included in the analysis.
     Table 9-36 provides ratios of capital costs to net income for each
foundry coke producer.  The costs of meeting the baseline regulations are
substantial.  This is  not unexpected since foundry coke production plants
operate at a significantly lower production rate for the same level of
investment as compared with furnace coke production rates.  This is due to
the longer coking time for foundry coke.  Furthermore, in looking at the
available data on the  age of the batteries used in the production processes
within each plant, there appears to be a correlation between the age of the
battery used and the level of compliance costs facing the firm.  The data
suggest that the foundry coke producing plants which are facing the highest
pending compliance costs are operating with batteries which were installed
                                  9-83

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    TABLE 9-34.   COAL CONSUMPTION AND  EMPLOYMENT  EFFECTS OF  REGULATORY
                     ALTERNATIVES—FOUNDRY  COKE,  1983d
Coal
consumption
for coke
(103 Mg/yr)
Employment (jobs)
Coal Coke
mining plant
Change caused by moving from           -570
  existing to baseline controls

Change caused by moving from base-
  line to Regulatory Alternative
    II                         "          -4
    III                                 -33
-182
  -1
 -10
                                                                   -71
-1
-4
aRegulated sources included in the baseline are described in Table 9-31.
Employment impacts are based on input-output relationships and production
 impacts.  Impacts on coke plant employment do not include jobs created
 by the relevant controls.
°Annual labor productivity in coal mining is estimated as 3,125 Mg
 per job.
                                   9-84

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         TABLE 9-35.   INDUSTRY CAPITAL REQUIREMENTS OF REGULATORY
                     ALTERNATIVES—FOUNDRY COKE, 1983

                                             Capital costs of regulations'
                                                    (106 1979 $)
Capital costs caused by moving from
  existing to baseline controls

Capital costs caused by moving from
  baseline to Regulatory Alternative
    II
    III
149
  3
 14
                                                                48 50
 Calculated for all plants projected to be in existence in 1983.

"'The regulated sources included in the baseline are described in Table 9-31.
                                  9-85

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          TABLE 9-36.   THE RATIO OF INCREMENTAL CAPITAL COSTS TO NET
                     INCOME—FOUNDRY COKE PRODUCERS,  1983	

                                          Ratio of compliance costs to
                                      average annual net income by firm (%)
                                   AA      BB     CC     DD     EE     FF.
Costs caused by moving
  from existing to b
  baseline controls

Costs caused by moving
  from baseline to Regu-
  latory Alternative
    II
    III
154
395
128
                                                         63
                              19
             24
  2
 19
  3
  3
  9
 57
1
8
0
0
0
0
NC = No cost to the company arises from this regulatory alternative.
aAverage annual net investment calculated from company profiles in Moody's
 Industrial Manual, Moody1s Investor Service, New York, 1982.  (Calculations
 were made on a constant 1979 dollar basis.)
bThe regulated sources included in the baseline are described in Table 9-32 of
 the BID.
                                   9-86

-------
between 1919 and 1946.   Conversely, the foundry coke producers which are
facing the lowest pending compliance costs are operating, for the most
part, with batteries installed between 1950 and 1979.
     Capital costs do not exceed 15 percent of the average annual net
income for either Regulatory Alternative II or III for four of the six
analyzed companies.  These costs could probably be met by internal financing.
Regulatory Alternative III imposes costs in excess of 15 percent of net
income for two of the six foundry coke producers.  The cumulative costs of
moving through the baseline to each alternative level of control are given
in Table 9-37.  These costs are substantial (in excess of 100 percent) for
several of the firms, and they may be prohibitive.
     Ratios of compliance costs to average annual net investment for the
foundry coke producers are provided in Table 9-38.  The costs of moving
from baseline to a regulatory alternative are never more than 17 percent of
the average annual net investment.  However, as shown in Table 9-39, the
costs of these alternatives and meeting the baseline regulations are in
excess of 100 percent of average annual net investment for one firm and in
excess of 50 percent for another.
     Tables 9-35 through 9-39 identified the existence of firms  that may
experience prohibitive cumulative  capital costs as a result of regulatory
actions.  Firms would use internal financing, additional equity  financing,
and/or debt financing to make these capital expenditures.  Since many  of_
the  foundry plants are owned by private corporations, data are  insufficient
to assess the eventual sources of  capital that these firms will  use.
Therefore,  only qualitative statements can be made concerning the  impacts
of financing  regulatory  investments.  Any  internal financing would reduce
return on equity  by  directly reducing dividends  or by reducing productive
capital  expenditures.  Debt financing may  reduce  the return on equity  by
increasing  the cost  of debt financing.  Finally,  financing regulatory
capital  requirements  using new common  stock  issues will  have  a  tendency to
dilute present owner's equity.  This  dilution could  be  substantial.
      9.2.4.4  Battery and Plant Closures.  The decision  rule  used  to  indi-
cate closure  candidates  among  furnace  batteries  is also  used  for foundry
batteries.  Any  foundry  battery for which  the marginal  cost of  operation  is
                                  9-87

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TABLE 9-37. THE RATIO OF CUMULATIVE CAPITAL COSTS TO NET
INCOME— FOUNDRY COKE PRODUCERS, 1983
Regulatory
Alternative
II
III
Ratio of compliance costs ^
to average annual net income by firm (%)
AA BB CC DD EE FF
156 398 137 64 20 24
173 398 185 71 20 24
NC = No cost to the company arises from this regulatory alternative.

aCapital costs include the costs of moving from existing to baseline controls
 plus the cost of the indicated regulatory alternative.  The regulated sources
 included in the baseline are described in Table 9-32 of the BID.

bAverage annual net investment calculated from company profiles in Moody's
 Industrial Manual. Moody1s Investor Service, New York, 1982.   (Calculations
 were made on a constant 1979 dollar basis.)
                                   9-88

-------
    TABLE 9-38.   THE RATIO OF INCREMENTAL CAPITAL COSTS TO NET INVESTMENT-
                         FOUNDRY COKE PRODUCERS,  1983

                                          Ratio of compliance costs
                               to average annual  net investment by firm (%)

                              AA       BB       CCb      DD       EE       FF
Cost caused by
 moving from
  existing to
  baseline
  controls

Costs caused by
  moving from
  baseline to
  Regulatory
  Alternative
      II
      III
134
54
32
                                                                           10
  2
 17
 0
 0
 0
 4
0
0
0
0
NC = No cost to the company arises from this regulatory alternative.

aAverage annual net investment calculated from company profiles in Moody's
 Industrial Manual. Moody's Investor Service, New York, 1982.  (Calculations
 were made on a constant 1979 dollar basis.)

 Data on annual investment are not available for this company.
cThe regulated sources included  in the baseline are described  in Table 9-32 of
 the BID.
                                   9-89

-------
    TABLE 9-39.   THE RATIO OF CUMULATIVE CAPITAL COST<
                         FOUNDRY COKE PRODUCERS, 1983C
TO NET INVESTMENT—
                                          Ratio of compliance costs
Regul atory
Alternative
•\
II
III
AA
136
151
BB
55
55
CCC DD
32
36
EE
10
10
FF
10
10
NC = No cost to the company arises from this regulatory alternative.
aCapital costs include the costs of moving from existing to baseline controls
 plus the cost of the indicated regulatory alternative.  The regulated sources
 included in the baseline are described in Table 9-32 of the BID.
bAverage annual net investment calculated from company profiles in Moody^s
 Industrial Manual, Moody1s Investor Service, New York, 1982.  (Calculations
 were made on a constant 1979 dollar basis.)
°Data on annual investment are not available for this company.
                                   9-90

-------
greater than the projected price of foundry coke is a candidate for closure.
According to this criterion and assuming baseline control, eight batteries
that are projected to be in existence in 1983 are closure candidates.
These batteries are located in five plants owned by five companies.  Three
entire plants are closed under baseline conditions.  All eight batteries
are smaller than the average foundry battery.
     Three of the eight batteries and one of the three plants are closure
candidates under the existing state of control.  Complete compliance with
current and proposed regulations is responsible for five potential battery
closures, which result in two potential plant closures.  Compliance with
even the most stringent of the regulatory alternatives should not add to
the list of closure candidates.
     The number of closure candidates under any regulatory scenario is
extremely sensitive to projected foundry coke production in 1983.  A
12-percent increase in projected production would  reduce the list of
closure candidates under the baseline to four batteries and one plant.
     If the battery closure candidates provide coke to nearby foundries and
if there are no other sources of coke in the immediate vicinity, these
batteries may continue to operate.  The cost of transporting coke from
distant sources may be sufficiently high to outweigh potential cost and
price differences between foundry coke producers.
9.3  POTENTIAL SOCIOECONOMIC AND INFLATIONARY  IMPACTS
9.3.1  Compliance Costs
     The estimated total annualized costs to coke  producers for compliance
with the regulatory alternatives are shown  in  Table 9-40.  Furnace and
foundry coke costs are shown separately and  in total.  Costs for furnace
and  foundry producers are differentiated because of differences  in coke
prices and control costs per unit of output.   The  costs are for  all plants
projected to be  in existence but not necessarily operating in  1983 are
calculated.
      In 1983,  Regulatory Alternative II would  result  in negative compliance
costs  for furnace coke producers and positive  compliance  costs  ($0.4
million per year) for foundry  producers.   For  furnace  and foundry  coke
producers combined,  Regulatory Alternative  III would  result  in  compliance
                                  9-91

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         TABLE 9"-40.   COMPLIANCE COSTS OF REGULATORY ALTERNATIVES
                          UNDER SCENARIO A,  1983a
                  Compliance cost*3 (1Q6 $/vr. 1979 $)

                  Furnace coke   Foundry coke   Total
                        Ratio of
                     average cost of
                     compliance to the
                     price of coke  (%)

                     Furnace   Foundry
                      coke      coke
Costs caused by      372.0
  moving from
  existing to
  baseline con-
  trols

Costs caused by
  moving from
  baseline to
  Regulatory
  Alternative
    II                -1.4
    III               36.9
64.0
436.0
                                                          7.23
                               11.39
 0.4
 4.6
 -1.0
 41.5
-0.03
 0.72
0.07
0.82
aRegulated sources included in the baseline are described in Table 9-31.

Calculated for all plants projected to be in existence  in 1983.48 50

GAssuming baseline price and production levels.
                                   9-92

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costs (in 1979 dollars) of $41.5 million per year.   It is expected that
1983 will be the year of maximum impact.  Thus, annual compliance costs do
not exceed the critical level, $100 million, indicated in Executive Order
12291.
     Estimates of the costs of the regulatory alternatives that exclude
closure candidate expenditures were also computed.   Without closure candi-
dates, Regulatory Alternatives II and III would still result in negative
compliance costs for both furnace and foundry producers.
     The ratios of the average costs of compliance per unit of coke produc-
tion to the prices of furnace coke and  foundry coke under the regulatory
baseline are shown in the right-hand portion of Table 9-40.  These ratios
are negative under both the regulatory  alternatives.
9.3.2  Prices and Consumer Costs
     The price changes projected in Section 9.2 are reproduced in
Table 9-41.  Coke price changes are based on the assumption that quantity
adjustments indicated by estimated demand and  supply  functions will occur.
Some part of the expected changes in the price of steel and ferrous foundry
products will be passed forward by producers who use  steel and ferrous
products and some will be absorbed by these producers.  The degree to which
those changes are passed forward as opposed to being  absorbed will depend
on  the demand and supply conditions of  the  affected markets.
      Projections of  the impacts on consumer prices of changes in the price
of  steel and ferrous foundry  products were made using input-output analysis.
These projections are  developed under the assumption  that  purchasers of
these products will  pass forward the entire projected price increases  to
final consumers.  Hence, this projection represents  a worst case outcome
for consumer prices.   As  shown  in Table 9-41,  the effects  on consumer
prices are  nominal  for both  regulatory  alternatives.
9.3.3 Balance  of Trade
      Projecting  recent trends in coke  imports  implies continued  increases
in  coke  imports.   Imposition  of  the  regulatory alternatives is expected .to
slightly reinforce  this trend.   Some  increase  in  steel  imports is  possible
also.  However,  since  steel  price  increases caused  by coke price  increases
                                   9-93

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     TABLE 9-41.   COKE,  STEEL,  FERROUS FOUNDRY,  AND CONSUMER PRODUCT?
     PRICE EFFECTS OF REGULATORY ALTERNATIVES UNDER SCENARIO A,  1983
                   Furnace
                     coke
                    ($/Mg,
                    1979 $)
Foundry
 coke     Steel
($/Mg,   ($/Mg,
1979 $)  1979 $)
         Foundry
         products
          Increase
         in consumer
         price level
Increase caused      7.84
  by moving from
  existing to base-
  line controls

Increase caused by
  moving from base-
  line to Regulatory
  Alternative
    II               0.02
    III              0.70
 25.19
3.53
0.40
                                                               .00075
  0.19
  1.44
0.01
0.30
0.01
0.02
0.00001
0.00020
 JRegulated sources included in the baseline are described in Table 9-31.^.
                                   9-94

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are projected to be quite small, any increase in imports caused by the
regulatory alternatives should be minor.   Moreover, trade regulations
covering steel imports may mitigate such increases.
     In the aggregate it appears unlikely that these regulatory alter-
natives would significantly affect the U.S. balance of trade position,
given the small share of international trade represented by coke imports.
However, compliance with the baseline for all control sources in the coke
plant is estimated to increase coke imports by at least 10 percent.
9.3.4  Community Impacts
     Furnace and foundry coke and steel production facilities are in
Pennsylvania, Indiana, Ohio, Maryland, New York, Colorado, California,
Michigan, Illinois, Alabama, Utah, Kentucky, Tennessee, Missouri,
Wisconsin, and West Virginia.  Closure of coke facilities could have
impacts on communities in these States.  The regulatory alternatives are
not projected to result in closures.  Potential production decreases should
not be sufficient to generate significant community  impacts.  However,
further compliance with existing and proposed regulations could result in
additional battery and plant closures and the resulting community impacts.
9-3.5  Small  Business Impacts
     The Regulatory Flexibility Act (RFA) requires consideration of the
potential impacts of proposed regulations on small "entities."  For the
NESHAP for coke oven by-product plants, small entities can be defined as
small furnace and foundry coke  firms.  The Environmental  Protection Agency
Office of Planning and Evaluation recently drafted a set  of guidelines for
RFA compliance.  This section addresses two  of the draft  guideline require-
ments that relate to the economic aspects  of the RFA.
          Identifying small  firms impacted by the  NESHAP, and
          Estimating the economic impact of  the NESHAP on these small
          firms.
     The guidelines for  conducting  a  regulatory flexibility analysis  define
a small business as "any business concern  which is  independently  owned and
operated and not dominant  in its  field as  defined  by the  Small Business
Administration  Regulations  under  Section 3 of the  Small Business  Act."
The Small Business Administration  (SBA) defines small  firms  in terms  of
                                  9-95

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employment.  Firms owning coke ovens are included in SIC 3312, which also
includes blast furnaces, steel works, and rolling mills.  The SBA has
determined that any firm that is in SIC 3312 and employs less than 1,000
workers will be considered small under the Small Business Act.
     Table 9-42 shows employment data for all U.S. firms that operate
by-product coke ovens.  Names of the companies are not given because closure
predictions will be made for plants owned by a few of the firms.  Four
firms in the list—23, 28, 29, and 30—can be designated as small based on
SBA definitions.  Employment information could not be found for firms 31
and 32.  Therefore, they will be treated as "small" firms for the remainder
of the analysis.  Because the standard being proposed is a NESHAP and all
existing and new plants will be expected by law to comply, all plants of
the small  firms not currently in compliance could be adversely impacted.
     After the affected small firms  are identified, the draft guidelines
for the RFA require an estimate of the degree of  economic impact.  The
first estimation method recommended  by the guidelines is to obtain the
percent increase in the average total cost of producing coke  as a result of
the proposed standard.  None  of the  small firms  identified was  found to
have an average cost  increase that was greater  than 5 percent.  Present  RFA
guidelines state that cost  increases greater than 5 percent are considered
to be significant.  None  of these cost  increases  exceed the 5-percent
criterion.
     The  second method  that the  RFA  draft guidelines  recommended  for esti-
mating  economic  impacts  requires  information  on average annual  capital
spending  of firms.  The goal  is  to  determine  if the capital  requirements of
regulations will  cause  capital  availability problems  for  small  firms.
 Ironically, small,  privately owned  firms  do not report  their annual  invest-
ment.   Therefore,  it  is usually impossible  to  assess  small  firm capital
 availability.   No financial data could be found for the small coke-producing
 firms  previously identified.
      The economic impact analysis in Section 9.2 included a closure
 analysis, which identified plant closure candidates that resulted from
 meeting existing regulations, i.e., OSHA coke oven emission standards,
 SIPs,  water standards,  and other air standards.  These plants are called
                                   9-96

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     TABLE 9-42.   EMPLOYMENT DATA FOR
      U.S. FIRMS OPERATING COKE OVENS
Company
Employment6
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
54,822
97,700
7,082
8,900
239,475
37,341
13,179
68,000
12,665
43,000
38,755
42,690
171,654
13,990
4,350
49,014
38,755
25,200
22,087
5,862
3,200
1,400
175
22,087
3,700
10,000
5,862
183
100
150
Not available
Not available
 ^Employment data were obtained from company
  profiles in Moody's Industrial  Manual42
  and telephone conversations with company
  representati ves.
                    9-97

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baseline closure candidates.  Furthermore, closure candidates were also
estimated as a result of implementing the proposed NESHAP.  The results of
the closure analysis revealed that the proposed NESHAP will have no impact
on the plants.
9.3.6  Energy
     The regulatory alternatives do not have any significant direct energy
impacts.  Although some indirect impacts are possible, they are likely to
be minor in nature.
     Indirect impacts could include the substitution of fossil fuels for
coke in blast furnaces, further reducing the coke rate.   Some reduction is
projected to occur in any case, but technological limits  govern the degree
to which the coke rate can be reduced.  Furthermore, projected coke price
increases are minor when compared to recent and projected fossil fuel price
increases.  Of course, if imports increase, fuel will  be  needed to transport
them.  Furthermore, if imports replace domestic coke production, excess
coke oven gas, some of which is currently used in other parts of the steel
plant, may be replaced by other fuels.  But if steel production decreases,
there will be some reduction in fuel consumption.
9.4
 1.
  2.
  3.
  4.
  5.
  6.
REFERENCES
Standard Industrial Classification Manual, 1972.  Executive Office of
the President, Office of Management and Budget.  Washington, DC.   U.S.
Government Printing Office.  1972.  p. 145.
1980 Annual Survey of Manufactures.  Statistics for Industry Groups
and Industries (Including Supplemental Labor Costs).  Bureau of the
Census, U.S. Department of Commerce.  Washington, DC.  February 1982.
Coke and Coal Chemicals in 1980.  Office of Coal, Nuclear, Electric
and Alternate Fuels.  Energy Information Administration, U.S. Depart-
ment of Energy.  Washington, DC.  November 1981.  p. 4.
Energy Data Reports:  Coke and Coal Chemicals  in 1979.  Office of Coal
and Electric Power Statistics, Energy Information Administration, U.S.
Department of Energy.  Washington, DC.  October 31, 1980.  p. 33-37.
Statistical Abstract of the United States:  1978.  99th Edition.
Bureau of the Census, U.S. Department of Commerce.  Washington, DC.
1978.  p. 441.
Minerals Yearbook.  Bureau of Mines, U.S.  Department of the  Interior,
U.S. Government Printing Office.  Washington,  DC.  1950-1978.  (Table
and page numbers vary because of  reclassifications).
                                   9-98

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 7.  Reference 3. p. 4.

'8.  Statistical Abstracts of the United States:  1980.  101st Edition.
     Bureau of the Census, U.S. Department of Commerce.  Washington, DC.
     1980.  p. 437.

 9.  Reference 5.  p. 874.

10.  Historical Statistics of the United States:  Colonial Times to 1970.
     Bureau of the Census, U.S. Government Printing Office, U.S. Department
     of Commerce.  Washington, DC.  1975.  p. 904-905.

11.  Reference 4, p. 8.

12.  1979 Annual Survey of Manufactures.  Value of Product Shipments.
     Bureau of the Census, U.S. Department of Commerce.  Washington, DC.
     October 1981.  p. 19.

13.  Reference 2, p. 16, 19.

14.  Energy Data Reports:  Coke and Coal Chemicals in  1978.  Office of
     Energy Data Operation, Energy Information Administration, U.S.
     Department of Energy.  Washington, DC.  1980.  p.  3-5.

15.  1972 Census of Manufactures.  Bureau of the  Census, U.S. Department  of
     Commerce, U.S. Government Printing Office.   Washington, DC.   1976.

16.  1977 Census of Manufactures.  Bureau of the  Census, U.S. Department  of
     Commerce, U.S. Government Printing Office.   Washington, DC.   1979.
     p. 2.

17.  1978 Annual Survey of Manufactures.  Statistics  for Industry  Groups
     and  Industries  (including supplemental  labor costs).  Bureau  of the
     Census, U.S. Department of Commerce.  Washington,  DC.  January 1981.
     p. 16.

18.  Minerals Yearbook, 1980.  Volume  I—Metals and Minerals.  Bureau  of
     Mines, U.S. Department of the Interior, U.S. Government Printing
     Office.  Washington, DC.  1981.   p. 437.

19.  Reference 3, p. 3.

20.  Analysis of the U.S. Metallurgical Coke Industry.   Industrial
     Economics Research Institute.  Fordham  University.  October 1979.
     p. 41.

21.  Reference 20.   p. 40.

22.  Kerrigan, Thomas  J.  Influences  upon the  Future  International Demand
     and  Supply  for  Coke.  Ph.D.  dissertation.  Fordham University.  New
     York.  1977.  p.  14, 114.
                                  9-99

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23.  Reference 4.  p. 1.

24.  Reference 4.  p. 13.

25.  Reference 4.  p. 3-5.

26.  Reference 4.  p. 3-5.

27.  Standard Support and  Environmental  Impact  Statement:   Standards  of
     Performance for Coke  Oven  Batteries.   Emissions  Standards  and
     Engineering Division,  Environmental  Protection Agency.   May 1976.
     p. 3-7.

28.  The  Politics  of Coke.   33  Metal  Producing.   March 1980.   p.  49-51.

29.  Reference 4.  p. 20.

30.  Reference 3,  p. 33-35.

31.  Reference 20.   p.  i.

32.  Reference 20.   p.  ii.

33.  The  Outlook for Metallurgical Coal and Coke.  Institutional Report.
     Merrill  Lynch,  Pierce, Fenner, and Smith,  Inc.  1980.  p.  1.

34.  Reference  33.  p.  5.

35.  Technical  Approach for a Coke Production Cost Model.  PEDCo Environ-
     mental,  Inc.   1979.  p. 39-50.

 36.   Energy Data Reports:   Coke Producers  in the United States  in 1978.
      Office of Energy Data and Interpretation, Energy  Information Adminis-
      tration, U.S. Department of  Energy.   Washington,  DC.  September 4,
      1979.

 37   Energy Data Reports:  Distribution  of Oven  and  Beehive  Coke  and
      Breeze.   Office of Energy Data  and  Interpretation, Energy  Information
      Administration, U.S. Department of  Energy.  Washington, DC.  April  10,
      1979.  p.  7-8.

 38.  Moody's Industrial Manual, Volumes  1  and  2.   Moody's Investors
      Service, Inc.  New York.  1981.

 39.  Annual Statistical Report American  Iron and Steel Institute.
      Washington,  DC.   1981.  p. 21.

 40   DeCarlo, J.  A., and  M.  M. Otero.   Coke  Plants in the United States on
      December 31, 1959.   Bureau of Mines,  U.S.  Department of the Interior.
      Washington,  DC.   1960.  p. 4-10.
                                    9-100

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41.  Staff Report on the United States Steel Industry and its International
     Rivals:  Trends and Factors Determining International Competitiveness.
     Bureau of Economics, Federal Trade Commission, U.S. Government Printing
     Office.  Washington, DC.  November 1977.  p. 53.

42.  Moody1s Industrial Manual.  Moody1s Investors Service, Inc.  New York.
     1979.

43.  Reference 33.  p. 3.

44.  An Economic Analysis of Proposed Effluent Limitations Guidelines, New
     Source Performance Standards, and Pretreatment Standards for the Iron
     and Steel Manufacturing Point Source Category.  Exhibit 6.  Temple,
     Barker, and Sloane, Inc., Lexington, Massachusetts.  December 1980.

45.  Reference 44.  p. VI-4.

46.  Survey of Current Business, Bureau of  Economic Analysis, U.S. Depart-
     ment of Commerce.  Washington, D.C.  August 1980.  p. 5-7.

47.  Survey of Current Business, Bureau of  Economic Analysis, U.S. Depart-
     ment of Commerce.  Washington, D.C.  April 1983, p. 5-6.

48.  Reference 20, p. 63-111.

49.  Reference 35, p. 1-69.

50.  Letter from Young, E.  F., American Iron and Steel  Institute, to
     Pratopos, J., U.S. Environmental Protection Agency.  May 16, 1980.

51.  Reference 35, p. 85.

52.  Economic Impact of NSPS Regulations on Coke Oven Battery Stacks.
     Research Triangle Institute.  Research Triangle Park, NC.   May 1980.
     p. 8-45, 8-47.

53.  Letter from Kemner, William F. , PEDCo  Environmental, Inc.,  to Bingham,
     Tayler, Research Triangle Institute.   March 31, 1980.

54.  An Econometric Model of the U.S. Steel Industry.   Research  Triangle
     Institute.  Research Triangle Park, NC.  March 1981.

55.  Ramachandran, V.  The  Economics of Farm Tractorization  in  India.   Ph.D.
     dissertation.  North Carolina State University.  Raleigh,  NC.  1979.

56.  Heckman, James J.  Shadow Price, Market Wages, and Labor Supply.
     Econometrica.  42.  p. 679-694.

57.  An Economic Analysis of Proposed Effluent Limitations Guidelines,  New
     Source Performance Standards, and Pretreatment Standards for the  Iron
     and  Steel Manufacturing Point Source Category.  Temple, Barker, and
     Sloane, Inc., Lexington, MA, December  1980.  p. VI-4.
                                  9-101

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            APPENDIX A



EVOLUTION OF THE PROPOSED STANDARDS

-------
            APPENDIX A - EVOLUTION OF THE PROPOSED STANDARDS

     The study to develop national emission standards for benzene
emissions from coke by-product recovery plants was initiated in October
1978 under U.S. Environmental Protection Agency Contract Number 68-02-
3056.  Research Triangle Institute was designated as the lead contractor
under the direction of Mr.  L. L.  Beck of the EPA Office of Air Quality
Planning and Standards, Industrial Studies Branch.
     During the course of this study, process and emissions data were
obtained through a source sampling survey followed by an emission
testing program and a Section 114 questionnaire entitled, "Current and
Planned Emission Controls for Coke By-Product Recovery Plants."  The
source sampling survey and the emission testing program were conducted
at approximately 7 plants.   Analysis of the liquid samples collected
during the source sampling survey was performed by TRW, Inc.  This
information was supplemented by other plant tours, meetings, and
telephone contacts, in addition to data obtained  from a literature
search and through the Agency.
     Chapters  3 through 6 of the  draft Background Information Document
(BID), which describe the industry, emission control techniques,
reconstruction and modification considerations, model plants, and
regulatory alternatives, were completed in February 1981 and mailed to
industry for review and comment.  The draft economic analysis was
completed in August 1981.  Industry comments on the draft BID were
analyzed and incorporated into a  revised version  that was submitted to
the  EPA Working Group  in October  1981 for  internal review of the
project.  Working Group comments  were considered  and incorporated into
the  draft BID, preamble, and regulation, to complete the package that
                                  A-2

-------
was distributed to the National Air Pollution Control Techniques
Advisory Committee in November 1981.  Similar packages were sent to
industry and environmental groups for additional comment.
     Prior to and during the data-gathering process, discussions were
held with individual steel companies and with representatives from the
American Iron and Steel Institute.  Other meetings were held to review
the project with the National Air Pollution Control Techniques Advisory
Committee (NAPCTAC) in December 1981.  The NAPCTAC is composed of 16
people from industry, State and local air pollution control agencies,
environmental groups, and others with expertise in air pollution
control.  This meeting was open to the public and was attended by
representatives of industry and environmental groups.
     During the NAPCTAC meeting, concern was expressed by industry
representatives that the gas blanketing emission control system recom-
mended by EPA as the basis of the proposed standard posed safety,
operation, and maintenance problems not fully addressed  in the draft
BID.  Industry representatives also commented that estimated costs for
the recommended system were understated.  However, industry officials
could supply no additional technical or cost information at that time.
     Following the NAPCTAC meeting, EPA personnel and their representa-
tives gathered additional technical and cost data relating to the gas
blanketing systems and other control techniques that could be applied
to emission sources at coke by-product recovery plants.  Visits were
made to  four additional by-product  plants to further evaluate the
design of demonstrated systems and  to discuss the operation, mainte-
nance, and safety questions raised  by industry  representatives at the
NAPCTAC  meeting.  These plants included Bethlehem Steel  Corporation,
Sparrows Point, Maryland; Republic  Steel Corporation, Cleveland, Ohio;
Armco Steel Corporation,  Houston, Texas; and U.S. Steel  Corporation,
Fair!ess Hills, Pennsylvania.
     Additional data concerning the design, operation,  and cost of gas
blanketing systems were also obtained through Section 114 questionnaires
sent to  these and other plants operating the proposed control system.
                                  A-3

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Information regarding fugitive emissions of benzene and VOC from
leaking equipment components was also collected through Section 114
questionnaires sent to seven other by-product plants and through data
collected for other benzene-related regulatory projects.  The revised
BID was transmitted for further internal review by the EPA Steering
Committee during July 1982.
     This draft of the BID reflects the additional information gathered
in response to the issues raised at the 1981 NAPCTAC meeting.  Technical
revisions to the proposed gas blanketing system design are included in
this draft of the BID, as are revised costs and energy, environmental,
and economic impacts.  This draft of the BID, preamble, and regulation
also reflects comments received from industry personnel, the EPA
Office of General Counsel, and the EPA Steering Committee.  Other
events that have occurred in the development of background information
for the proposed standard are presented in Table A-l.
                                   A-4

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              TABLE A-l.   EVOLUTION OF THE PROPOSED STANDARDS
        Date
                    Event
June 8, 1977


October 12, 1978

March 8, 1979


March 16, 1979


April 10-11, 1979



April 18-20, 1979



April 24, 1979



April 26, 1979



April 28, 1979



April 30 - May 1, 1979



May 3, 1979



June 6, 1979
July 10, 1979
Benzene listed as a hazardous air pollutant
  (42 Fed. Reg. 29332).

Work begun by Research Triangle Institute.

Finalization of quality assurance techniques and
  sample procedures for analysis of samples.

Approval of test plan for source sampling surveys
  of representative coke by-product recovery plants.

Plant visit to Republic Steel Corporation coke
  by-product recovery plant at Gadsden, Alabama,
  to obtain samples.

Plant visit to Bethlehem Steel Corporation coke
  by-product recovery plant at Burns Harbor,
  Indiana, to survey and obtain samples.

Plant visit to Republic Steel Corporation coke
  by-product recovery plant at Cleveland, Ohio,
  to survey and obtain samples.

Plant visit to National Steel Corporation coke
  by-product recovery plant at Weirton, West
  Virginia, to survey and obtain samples.
Plant visit to Wheeling-Pittsburgh Steel Corpora-
  tion coke by-product recovery plant at Monessen,
  Pennsylvania, to  survey and obtain samples.

Plant visit to U.S. Steel Corporation coke by-product
  recovery plant at Clairton, Pennsylvania, to survey
  and obtain samples.

Plant visit to U.S. Steel Corporation coke by-product
  recovery plant at Bethl.ehem, Pennsylvania, to
  survey and obtain samples.

Section 114 letter  requesting response to attached
  questionnaire, "Current and Planned Emission
  Controls for Coke By-Product Recovery Plants,"
  sent to U.S. Steel Corporation plants at Clairton,
  Pennsylvania, and Fairfield, Alabama.
Section 114 letter  requesting response to attached
  questionnaire, "Current and Planned Emission Con-
  trols for Coke By-Product Recovery Plants," sent
  to Jones & Laugh!in Steel Corporation plant at
  Aliquippa, Pennsylvania; Bethlehem Steel Corpora-
  tion plant at Sparrows Point, Maryland; Kaiser
                                                               (continued)
                                 A-5


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                          TABLE A-l.  (continued)
        Date
                    Event
October 15, 1979

April 28-19, 1980



May 12-15, 1980


May 20-21, 1980


May 22-23, 1980



May 28, 1980


June 3, 1980


June 18, 1980



June 20, 1980




July 7-25,  1980
July  28  -  August 8,
   1980


August 11-15,  1980
 August 28,  1980
  Steel Corporation plant at Fontana, California;
  Inland Steel Company plant at East Chicago,
  Indiana; Republic Steel Corporation plant at
  Youngstown, Ohio; and Chattanooga Coke and
  Chemical Company plant at Chattanooga, Tenneseee.

Analyses of samples completed by TRW, Inc.
Plant visit to Wheeling-Pittsburgh Steel Corpora-
  tion coke by-product recovery plant at Monessen,
  Pennsylvania, to survey and obtain samples.
Pretest survey at Bethlehem Steel Corporation coke
  by-product recovery plant at Bethlehem, Pennsylvania.

Pretest survey at U.S. Steel Corporation coke by-
  product recovery plant at Clairton, Pennsylvania.

Pretest survey at Wheeling-Pittsburgh Steel Corpora-
  tion coke by-product recovery plant at Monessen,
  Pennsylvania.
Pretest survey at Bethlehem Steel Corporation coke
  by-product recovery plant at Burns Harbor, Indiana.

Pretest survey at Republic Steel Corporation coke
  by-product recovery plant at Gadsden; Alabama.

Plant  visit to Republic  Steel Corporation coke
  by-product recovery plant at Youngstown, Ohio, to
  survey  and collect  samples.
Section 114  letter requesting information regarding
  emissions  from final-cooler cooling tower  sent to
  Bethlehem  Steel Corporation plant  at  Bethlehem,
  Pennsylvania.
Emission  testing at Bethlehem Steel  Corporation  coke
  by-product  recovery plant at Bethlehem, Pennsyl-
  vania.
Emission  testing at U.S. Steel Corporation coke
  by-product  recovery plant at Clairton,  Pennsyl-
  vania.
Emission  testing at Wheeling-Pittsburgh Steel
  Corporation  coke by-product recovery  plant at
  Monessen,  Pennsylvania.
Pretest survey at  CF&I  Steel Company coke by-
  product recovery plant at  Pueblo,  Colorado.
                                                               (continued)
                                  A-6

-------
                          TABLE A-l.   (continued)
        Date
                    Event
September 8-12, 1980
September 22-26, 1980
October 6-9, 1980
October 15-17, 1980
November 24 -
  December 3, 1980

December 8-15, 1980
January 12-23, 1981



February  6,  1981

February  27,  1981


March  1981

May  18, 1981

October 1981
October 28,  1981




December  1-2, 1981

January 18-
   February 11, 1982
Emission testing at U.S.  Steel Corporation coke
  by-product recovery plant at Fair!ess Hills,
  Pennsylvania.

Emission testing at Bethlehem Steel Corporation
  coke by-product recovery plant at Burns Harbor,
  Indiana
Emission testing at CF&I Steel Company coke by-
  product recovery plant at Pueblo, Colorado.

Emission testing at Republic Steel Corporation
  coke by-product recovery plant at Gadsden,
  Alabama.
Emission testing at Wheel ing-Pittsburgh coke by-
  product recovery plant at Monessen, Pennsylvania.

Emission testing at Republic Steel Corporation
  coke by-product recovery plant at Gadsden,
  Alabama.
Emission testing at Bethlehem Steel Corporation
  coke by-product recovery plant at Bethlehem,
  Pennsylvania.
Concurrence on regulatory alternatives.

Draft BID Chapters 3 through  6.3 distributed
  to industry for review and  comment.

Completion of Phase II.
Meeting with American  Iron and Steel  Institute.

Working Group review.
Draft preamble,  regulation, and BID distributed
  to NAPCTAC members,  industry representatives,
  environmental  groups,  EPA Regions,  and  others
  in preparation for NAPCTAC  meeting.

NAPCTAC meeting.
Section 114  requests for additional  information
  regarding  the  design,  operation,  and  costs  of
  emission control systems  sent to Bethlehem Steel
  Corporation,  Sparrows  Point, Maryland;  Republic
  Steel Corporation, Cleveland, Ohio, and Gadsden,
  Alabama; U.S.  Steel  Corporation,  Clairton,

                                        (continued)
                                   A-7

-------
                          TABLE A-l.  (continued)
        Date
                    Event
January 20, 1982
January 21, 1982
February 5-11, 1982
March 4, 1982

March 8, 1982

July 1982



March 1983



July 1983


February 1983
  Pennsylvania, Gary, Indiana, and Fairless Hills,
  Pennsylvania; and Armco Steel Corporation,
  Houston, Texas.
Plant visit to Bethlehem Steel Corporation,
  Sparrows Point,  Maryland

Plant visit to Republic Steel Corporation,
  Cleveland, Ohio.
Section 114 letter requesting information regard-
  ing benzene fugitive emissions from equipment
  components sent to CF&I Steel Corporation,
  Pueblo, Colorado; Shenago, Incorporated, Neville
  Island, Pennsylvania; Lone Star Steel Company,
  Lone Star, Texas; National Steel Corporation,
  Detroit, Michigan, and Browns Island, West
  Virginia; Keystone Coke Company, Swedeland,
  Pennsylvania; Koppers Company, Incorporated,
  Toledo, Ohio; and Jim Walters Resources, Inc.,
  Birmingham, Alabama.

Plant visit to Armco Steel Corporation, Houston,
  Texas.
Plant visit to U.S. Steel Corporation, Fairless
  Hills, Pennsylvania.

Draft preamble, regulation, and BID distributed
  to Agency representatives for Steering Committee
  review.

Draft preamble, regulation, and BID distributed to
  Agency representatives for Steering Committee
  review.

Draft preamble, regulation, and BID distributed
  to Agency representatives for internal review.

Draft preamble, regulation, and BID distributed
  for A.A. review.
                                   A-8

-------
                 APPENDIX B



INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS

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-------
            APPENDIX C



EMISSION MEASUREMENTS AND ESTIMATES

-------
                                APPENDIX C
                    EMISSION MEASUREMENTS AND ESTIMATES
C.I  OBJECTIVE
     The purpose of this appendix is to present and summarize data
gathered during the development of a standard for benzene emissions
from the coke oven by-product recovery plants.
C.2  DISCUSSION
     The source testing program was conducted in two phases:
          Testing of process unit emissions such as those from the
          tar dehydrator and cooling tower.
          Testing of fugitive emissions from leaking equipment
          components, such as pumps and valves.
     The testing of process units for benzene emissions was conducted
at seven by-product recovery plants.  Source and fugitive emissions
from process units were measured by Modified Method 110 (Section D.I.I)
and Tracer Gas Method (Section D.I.2), respectively.  Tables C-l
through C-23 contain the emission data for process units.  The major
sources of benzene from the process units are the tar-dewatering
tanks, naphthalene handling and drying operations, final-cooler cooling
tower, light-oil condensers, and light-oil storage.
     Fugitive emissions from leaking pumps, valves, flanges, and
exhausters were field tested at three by-product recovery plants.  The
measurement methods are described in Section D.4 and the data are
summarized in Tables C-26 through C-32.  Results of the testing program
and data analysis are discussed in Section C.4.
     As stated in the introduction to the Compilation of Air Pollutant
Emission Factors (AP-42),1 the techniques for determining emission
factors include detailed source testing, isolated source measurements

                                 C-2

-------
with incomplete background information, material/balance studies, and
engineering appraisals.  The quality of the emission factors generally
becomes worse in the order stated above.  Ratings A through E were
assigned for the published emission factors to alert the AP-42 user to
this decrease in quality.
C.3  TEST DATA FOR PROCESS UNITS
     Seven coke by-product plants were tested for process unit emissions.
These representative plants include U.S. Steel Corporation at Fairless
Hills2 and Clairton,3 Republic Steel Corporation at Gadsden,4 Wheeling-
Pittsburgh Steel Corporation at Monessen,5 Bethlehem Steel Corporation
at Burns Harbor6 and Bethlehem,7 and CF&I Steel Corporation at
Pueblo.8  The process unit emission data are presented by plant
(Tables C-l through C-7), gas phase sources (Tables C-8 through C-16),
and liquid phase sources (Tables C-17 through C-23).  Emission measure-
ment methods are discussed in detail in Section D.I.
C.4  TEST DATA FOR FUGITIVE EMISSIONS FROM LEAKS
     Field testing was conducted at three by-product recovery plants
to collect data on nonmethane hydrocarbon and benzene emissions from
leaking valves, pumps, flanges, threaded fittings, and exhausters. The
objectives of the field testing were:9
          To count and screen all valves and pump seals and one-
          third of all flanges on process lines containing at least
          4 weight percent benzene; also to screen all exhauster
          seals and to determine the percentage of benzene in each
          process line surveyed.
          To measure the mass emission rate of benzene and of
          nonmethane hydrocarbons at each leaking source identified
          during the screening.
The field testing was conducted at Wheeling-Pittsburgh Steel, Monessen,
Pennsylvania;10 Bethlehem Steel, Bethlehem, Pennsylvania;11 and Republic
Steel, Gadsden, Alabama.12  The objectives of the field testing were
met and the results are summarized in the following subsections.
     A statistical analysis was performed on the data from the three
plants and a summary report was issued.9  The objectives of the data
analysis were:
                                  C-3

-------
          To compile  leak frequency  distributions  for  different
          benzene service populations  (all  sources screened,  all
          sources on  lines with  at least 4  weight  percent  benzene,
          and all sources on lines with  at  least 10 weight percent
          benzene).
          To compare  the percentage  of benzene in  the  line to the
          estimated percentage of benzene in the leak  to determine
          if the benzene concentration in the line is  an adequate
          identifier  of potentially  significant sources.
          To prepare  benzene and nonmethane hydrocarbon emission
          factors for all sources and for sources  on lines with at
          least 10 percent benzene.
          To compare  the coke oven by-product recovery emission
          factors with emission factors for petroleum refineries.
These objectives were met and details are provided in the  following
subsections.  A brief summary of the conclusions is given  in the
following paragraphs.
     An examination of the population data indicates that the bulk of
benzene fugitive emissions can be attributed to sources on lines
containing  at least 10 percent benzene.  Usually,  only the light-oil
product lines contain 10  percent or more benzene.   These data indicate
that no sources were found in the 4- to 10-percent benzene service
range.
     The  study  concluded that the percentage of benzene in the process
stream is a good indicator of the percentage of benzene in a  leak from
that process stream.  The program was not  designed to produce an
extensive data  base  to  develop  firm emission  factors; however, it was
designed  to compare  emission  rates  from by-product plant  sources with
the extensive data base on  emission rates  from petroleum  refinery
sources.  The study  concluded that  the  mean  emission  factors  for
similar leaking equipment in  the two  industries are reasonably close
and that  the confidence intervals for the  two  show a  significant degree
of overlap.  Therefore, the use of  petroleum refinery data to charac-
terize equipment leak rates in  by-product  plants  is reasonable.13
                                   C-4

-------
C.4.1  Screening Value Distributions and Leak Rates From Sampled
       Sources"
     Fugitive emission screening was performed on fittings on process
lines containing at least 4 weight percent benzene.  Benzene is con-
centrated in the light-oil recovery section, so almost all of the
testing was performed in this area.  All three plants have light-oil
recovery units that operate by the absorption/stripping method of
light-oil recovery.  At two of three plants, the light oil is further
fractionated.
     The fugitive emission testing at each of the three plants included
both "screening" and "bagging" procedures.  Screening is a generic
term covering any quick portable method of detecting fugitive emissions.
The initial screening in this study was performed with a Century
Systems Organic Vapor Analyzer (OVA) Model 108.*  Bagging is a technique
                                                                 ®
for measuring fugitive emissions by enclosing the source in Mylar * and
analyzing an equilibrium flow of air through the enclosure.  The
screening and bagging procedures are described in more detail in
Appendix D, Subsection D.4.
     Screening value distributions are presented in Table C-26 for all
tested plants.  These distributions are reported by type of fitting
and by the concentration of benzene in the line.  Three subcategories
for the amount of benzene in the line were considered:
          All service (i.e., all1sources screened)
          Sources on lines with at least 4 weight percent benzene
          Sources on lines with at least 10 weight percent benzene.
However, no sources were found with benzene between 4 and 10 weight
percent.
     Sources with less than 4 weight percent benzene, other than
exhausters, were not screened intentionally.  But at the Wheeling-
Pittsburgh Steel and Bethlehem Steel plants, it was not immediately
*The mention of trade names or commercial products does not constitute
 endorsement or recommendation for use.
                                  C-5

-------
known that the wash oil from the light-oil  absorbers contained less
than 4 weight percent benzene.   Hence, these wash-oil  lines were
screened, even though subsequent analysis of samples from these lines
showed that the benzene concentration was less than 4 weight percent.
     Exhauster seals also were tested, even though these are in the
service of coke oven gas with less than 4 weight percent benzene,
because testing in petroleum refineries indicated that this type of
fitting can be a major source of emissions.  The exhausters are located
on the coke oven gas line upstream from the light-oil  recovery unit.
The distribution of screening values for exhausters is also presented
in Table C-26.
     Table C-27 summarizes the benzene and nonmethane hydrocarbon leak
rates in kilograms per day.  All valves, pump seals, and exhausters
that caused an OVA reading greater than the ambient reading or that
had a visible liquid leak were sampled.  Vapor phase leak rates were
measured using the bagging technique.  Liquid leak rates were measured
directly by timed collection in a graduated cylinder,  and a sample of
the collected liquid was analyzed for benzene.  Each sampled source
was screened immediately before sampling with an OVA and with a J. W.
Bacharach Instrument Company "TLV Sniffer."*  These screening values
are shown in Table C-27 along with the weight percent benzene in the
line.
C.4.2  Comparison of Benzene Concentration in the Leak and in the Line
     Table C-28 provides a comparison of the weight percent benzene in
the vapor, liquid, and total leak with the weight percent benzene in
the line.  The weight percent benzene in the vapor sample is not
directly comparable to benzene in the line, because the sample is
diluted with air.  These values for percent benzene are calculated as
the ratio of benzene to nonmethane hydrocarbon in the sample.  This
method is probably accurate unless the leak is small.   Those values of
benzene in the leak that are much less than the benzene in the line
The mention of trade names or commercial products does not constitute
 endorsement or recommendation for use.
                                  C-6

-------
represent samples that had only slightly more benzene and nonmethane
hydrocarbon than the ambient air samples had.   In these cases,  the
sampling and analytical precision is not sufficient to resolve  the
benzene concentration accurately and results in a lack of correlation
between sample and line benzene concentrations.
     The data show that the average percent difference between  the
weight percent benzene in the line and in the leak was -2 percent and
the absolute value of the percent difference was 26 percent.  The
largest percent differences were found for the sources with the lowest
leak rates.  These difference are within the accuracy of the determina-
tion of the percent benzene and the emission rate.   These data  indicate
that the percentage of benzene in the process stream is generally a
good indicator of the percentage of benzene in a leak from the  process
stream.  Therefore, the VOC emission factor is multiplied by the
weight percent benzene in the process stream to derive a benzene
emission factor for leaking equipment from the extensive VOC data
base.  For example, if a light-oil stream contains 70 percent benzene,
the VOC emission factor for a piece of leaking equipment in light-oil
service would be multiplied by 0.7 to estimate the benzene emission
factor.
C.4.3  Comparison of Emission Factors
     Emission factors were developed for the by-product plant sources
from the estimation methodology described in Reference 9.  The  results
for all sources screened are given in Table C-29, and the results for
sources with 10 percent or more benzene in the line are given in
Table C-30.  In Figures C-l to C-3, these emission factors are  compared
graphically with emission factors developed during the study of leaks
at refineries.  Tabular comparisons are presented in Tables C-31 and
C-32.
     In the light-oil plant, the process streams of interest contain a
mixture of benzene, toluene, and xylene (light oil, BTX) or refined
benzene only and are classed as a light liquid.  (A light liquid is
defined as a petroleum liquid with a vapor pressure greater than the
vapor pressure of kerosene, about 0.3 kPa at 20° C.)  Consequently,
                                  C-7

-------
the emission factors for equipment in light liquid service in petroleum
refineries are compared with emission factors developed from the
by-product plant data for equipment (pumps and valves) used in light
oil, BTX, or benzene service.  Exhausters are used in by-product
plants to provide the motive power for coke oven gas and are located
downstream of tar removal and upstream of the light-oil recovery
system.  The coke oven gas has a relatively low concentration of
volatile organic compounds (VOC's) and is composed chiefly of hydrogen
(~45 to 65 percent) and methane (~20 to 30 percent).  Compressors in
hydrogen service are the petroleum refinery equipment most comparable
to exhausters; consequently, data for by-product plant exhausters and
petroleum refinery compressors (H2 service) are compared in the tables.
     Table C-31 shows the leak frequency by equipment type as measured
in the petroleum refinery study and in the by-product plant study.
The valve leak frequency for coke by-product plants is about one-half
that of the refinery plants, while the pump leak frequency for by-product
plants is about twice that of the refinery plants.  However, the
95-percent confidence intervals for the by-product plant data and the
petroleum refinery data  show a significant degree of overlap.  A
comparison is not made in Table C-31 for the leak frequency of exhausters
and compressors because  two of the three by-product plants tested had
exhauster seals that effectively controlled emissions, whereas a very
high percentage of the compressors were not fitted with effective
seals.  Only 8.8 percent of the exhausters that were tested had leaks.
     The emission factors for nonmethane hydrocarbon leaks from valves,
pumps, and exhausters (compressors) are compared  in Table C-32 and
graphical comparisons are given in Figures C-l, C-2, and C-3.  For  all
sources, the 95-percent  confidence intervals for  the petroleum refinery
data fall within the 95-percent confidence intervals for the  by-product
plant  data.  The confidence  intervals  for the petroleum refinery
emission factors are smaller than those for coke  by-product plants
because  the refinery data are more extensive.
     The testing program at  by-product plants was not  designed to
produce  an extensive data base  from which firm  emission factors could
                                   C-8

-------
be developed.  However, a previous study of fugitive emissions from

petroleum refining was designed to develop emission factors for similar

equipment types from an extensive data base.  A comparison of emission

factors for comparable sources in coke by-product plants and refineries

indicates that the mean emission factors are reasonably close, especially

for valves, and that the confidence intervals for all categories show

a significant degree of overlap.  Therefore, the use of refinery data

to characterize the coke by-products fugitive emissions is reasonable.

C.5  REFERENCES
1.   Masser, C. C.  Compilation of Air Pollutant Emission Factors--
     Third Edition.  Publication Number AP-42.  U.S. Environmental
     Protection Agency.  Research Triangle Park, NC.  August 1977.

2.   U.S. Environmental Protection Agency.  Coke Oven By-Product
     Plants, Emission Test  Report, U.S. Steel Corporation, Fairless
     Hills,  Pennsylvania.   EMB No. 80-BYC-8.  March 1981.

3.   U.S. Environmental Protection Agency.  Coke Oven By-Product
     Plants, Emission Test  Report for U.S. Steel Corporation, Clairton,
     Pennsylvania.  EMB No. 80-BYC-2.  March 1981.

4.   U.S. Environmental Protection Agency.  Coke Oven By-Product
     Plants, Emission Test  Report for Republic  Steel Corporation,
     Gadsden, Alabama.  EMB No. 80-BYC-4.  March 1981.

5.   U.S. Environmental Protection Agency.  Coke Oven By-Product
     Plants, Emission Test  Report for Wheeling-Pittsburgh Steel Corpora-
     tion, Monessen, Pennsylvania.  EMB No. 80-BYC-3.   March 1981.

6.   U.S. Environmental Protection Agency.  Coke Oven By-Product
     Plants, Emission Test  Report for Bethlehem Steel Corporation,
     Burns Harbor,  Indiana.   EMB No. 80-BYC-5.  March 1981.

7.   U.S. Environmental Protection Agency.  Coke Oven By-Product
     Plants, Emission Test  Report for Bethlehem Steel Corporation,
     Bethlehem,  Pennsylvania.   EMB No. 80-BYC-l.   March 1981.

8.   U.S. Environmental Protection Agency.  Coke Oven By-Product
     Plants, Emission Test  Report for CF&I  Steel Corporation,  Pueblo,
     Colorado.   EMB No. 80-BYC-6.  March  1981.

9.   U.S.  Environmental Protection Agency.  Benzene Fugitive  Leaks:
     Leak Frequency and Emission Factors  for  Fittings  in Coke  Oven
     By-Product  Plants.   EMB  No. 81-BYC-12.   January  1982.
                                   C-9

-------
10.  U.S. Environmental Protection Agency.  Benzene Fugitive  Leaks:
     Emission Test Report for Wheeling-Pittsburgh Steel Corporation,
     Monessen, Pennsylvania.  EMB No. 80-BYC-ll.  August 1981.

11.  U.S. Environmental Protection Agency.  Benzene Fugitive  Leaks:
     Emission Test Report for Bethlehem Steel Corporation, Bethlehem,
     Pennsylvania.  EMB No. 80-BYC-9.  August 1981.

12.  U.S. Environmental Protection Agency.  Benzene Fugitive  Leaks:
     Emission Test Report for Republic Steel Corporation, Gadsden,
     Alabama.  EMB No. 80-BYC-10.  August 1981.
                                 C-10

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                TABLE C-24.  PAINT FACTORS FOR FIXED-ROOF TANKS
    Tank
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    White
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                                     C-30
    

    -------
                  TABLE C-25.  TANK TYPE, SEAL, AND PAINT FACTORS
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                                     C-31
    

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                       APPENDIX D
    
    
    
    EMISSION MEASUREMENTS AND CONTINUOUS MONITORING
    

    -------
                                    APPENDIX D
                  EMISSION MEASUREMENTS AND CONTINUOUS MONITORING
    
    D.I  INTRODUCTION
         Appendix D is divided into two sections, the first dealing with
    fugitive benzene process emissions and the second covering fugitive
    benzene leaks.
         For purposes of this study, the difference between fugitive
    process emissions and fugitive leaks is that process emissions originate
    from sources normally vented to or open to the atmosphere, whereas a
    fugitive leak is an accidental escape from normal confinement due to
    improper equipment or maintenance.  For example, the process emission
    study covered such sources as storage tanks, sumps, cooling towers,
    and material-handling processes; the fugitive leak survey included
    pumps, valves, and flanges located throughout the by-product plant.
         Subsections D.2 through D.4 cover the fugitive process emission
    study and Subsections D.5 through D.8 cover the fugitive leak survey.
    D.2  EMISSION MEASUREMENT METHODS FOR FUGITIVE PROCESS EMISSIONS
         During the standard support study for fugitive benzene process
    emissions from coke oven by-product plants, the U.S. Environmental
    Protection Agency (EPA) conducted emission tests at seven facilities.
    A total of 21 sources were tested:  14 for source benzene emissions, 5
    for fugitive benzene emissions, and 2 for benzo-a-pyrene (BaP).
         Source benzene emissions were measured through a modified EPA
    Method 110 procedure developed in the field for application to this
    test program.  Fugitive benzene emissions were measured using a tracer
    gas to model and estimate benzene emissions from unconfined sources.
    BaP was sampled through a draft EPA method.  The procedures used for
    these three test methods are described below.
                                       D-2
    

    -------
    D-2.1  Determination of Benzene from Stationary Sources:  EPA Method 110
           and Modifications
         EPA Method 110 consists of drawing a time-integrated stack gas
    sample through a probe into a Tedlar* sample bag, which is enclosed in
    a leak-free drum, by use of a pump hooked to the drum outlet that
    slowly evacuates the drum, causing the bag to fill.
         The method was modified because it did not account for moisture
    in the sample stream and is only designed to measure benzene concen-
    tration, not mass emission rate.  The following modifications were
    made to all tests done using Method 110:
         1.   Velocity and temperature readings were taken at the top of
    the stack at 5-minute intervals during the 30-minute sampling runs to
    obtain mass emission rates.  This information was used to calculate
    flow rate, which was used in conjunction with benzene concentration to
    yield mass emission rate.  Velocity readings were made by using a vane
    anemometer with direct electronic readout.
         2.   A personnel sampling pump was substituted for the pump,
    needle valve, and flow meter of the method.   The personnel pumps have
    built-in flow meters and rate adjustment screws and have the further
    advantage of being intrinsically safe, as required in many areas of
    the coke plant.
         3.   Swage!ok fittings were used in place of quick connects.
         4.   Instead of being discarded, Teflon sample lines after each
    set of samples were washed with propylene carbonate and/or acetone and
    flushed with nitrogen before reuse.
         5.   An orifice and megnehelic gauge were inserted in the sampling
    line before the Tedlar bag to indicate that air flow was reaching the
    bag.
         6.   A water knockout trap was inserted between the probe and
    magnehelic gauge to collect any condensate in the sample line.
         ^Mention of trade names or specific products does not constitute
    endorsement by the U.S.  Environmental Protection Agency.
                                      D-3
    

    -------
          7.    The  following  cleanup  procedures were  followed:
          If  any  condensate were  collected  in  the  trap  or  sample  line, it
    was measured and  saved for analysis.   The probe, line, and trap were
    then  washed  with  propylene carbonate,  which was  also  saved for analysis.
    Any benzene  found in these washed and  water catches was added to the
    total  found  in the sample bag to determine mass  emission rates.
          Bag volumes  were measured whenever water was  collected  in the
    trap  by  emptying  the bag through a dry gas meter after the sample was
    analyzed.  The volume of water collected  in the  trap was then converted
    to an equivalent  air volume  and  was added to  the volume in the bag to
    determine  the percent moisture in the  sample  stream.
          After the probe, line,  and  trap washes were completed,  the lines
    were  washed  with  acetone to  remove the propylene carbonate film and
    flushed  with nitrogen to dry.
          Figure  D-l shows the modified Method 110 setup.
          In  some cases the probe plugged with naphthalene, resulting in no
    sample collection.  This occurred on the  naphthalene-drying  tank and
    on two tar dehydrators.  The solution  to  this problem was to use a
    large diameter glass probe in place of the stainless steel tubing and
    to pass  the  sample stream through propylene carbonate to knock out the
    naphthalene.   As  shown in Figure D-2,  the knockout train consists of
    three impingers,  the first two each containing 100 m£ of propylene
    carbonate, and the third empty.   After the naphthalene was scrubbed
    out, the sample stream passed through  Teflon tubing and on into the
    sampling drum as  usual.  Cleanup consisted of saving the impinger
    catches and washes in addition to the  sample line and water trap
    washes for analysis of benzene.
    D.2.2  Fugitive Benzene  Sources;   Tracer Gas Method
         The tracer gas method is a practical procedure for quantifying
    mass emissions of volatile organics from  sources essentially open to
    the atmosphere without disturbing flow or dispersion patterns of the
    source operation.   This method uses the release of a tracer gas directly
    over the source of interest;  the tracer gas will  then follow the same
    dispersion patterns as will  emissions from the source.  The mass of
                                        D-4
    

    -------
                    Stainless Steel Probe
    
                         Swagelok Fittings
    Stack-
    Teflon Sampling Line
    
        7ater Knockout Trap
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                       Swagelok
                       Fittings
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                                                      .ctt
                                                          -Tygon Tubing
                             -Personnel Sampling
                                  Pump
                                                              -Leak-proof Barrel
                                     Tank
                                      FIGURE D-l
                            MODIFIED METHOD 110 SAMPLING TRAIN
                                          D-5
    

    -------
        Glass
        .Probe
    Stack
             A
           Stack
           Flow
                              Bucket
                           Empty
                   100 ml
                   Propylene
                   Carbonate
                                      ——Teflon Sampling Line
                Water Trap
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                                Tedlar Bag
                                                               	Tygon Tubing
                                         Personnel
                                          Sampling
                                          Pump
                                             •Leak-proof
                                              Barrel
                                        Tank
       FIGURE  D-2
    MODIFIED METHOD 110 SAMPLING TRAIN WITH PROPYLEIIE
    CARBONATE KNOCKOUT TRAP
                                         b-6
    

    -------
    tracer released over the sampling period is known and the mass-to-mass
    ratio of the benzene to the tracer gas in the collected samples is
    determined by gas chromatography.  The benzene emission rate can be
    calculated with this information.
         The method is based on the principle that the chosen tracer gas
    will model the dispersion of benzene from the source.  The tracer gas
    chosen for this project was isobutane because it was not present in
    the sources to be tested and could be separated readily from other
    source trace components by the same column used for benzene.  In
    addition, isobutane is a nontoxic gas that can be readily dispensed
    from a pressurized cylinder at a uniform measured rate.
         0.2.2.1  Sampling Strategy.   The program for a sampling run
    generally involved collection of triplicate downwind samples and a
    single-point upwind sample.  Prior to testing, grab samples were
    collected in glass flasks and analyzed to determine benzene concen-
    tration in the vicinity of the source to be tested,  This information
    was correlated with wind speed and direction to choose the exact
    sampler locations.  Ideally, downwind samplers would be equidistant
    from the source and along approximately a 30° arc.
         Two sets of samples were integrated over consecutive half-hour
    periods and together constituted a single test.  Samples were collected
    by Environmental Measurements Air Quality Assurance II sampling systems
    into clean 10-liter Tedlar bags.   The Air Quality Assurance II samplers
    are self-contained units capable of collecting one or more integrated
    samples at a preset rate.  For tracer tests the sampling rate used
    10 A/h.  Tedlar bags to be reused for sampling were flushed three
    times with nitrogen and allowed to sit overnight three-quarters full.
    Prior to their next use, each was analyzed for benzene content.
         The tracer gas dispersion apparatus was positioned over the
    source to be tested as near as possible to the actual emissions.
    Ideally, the dispersion tube or support member spanned the the emission
    source at its center.  After being collected, the tracer gas samples
    were transported immediately to the gas chromatograph and analyzed.
    The elapsed time between sample collection and analysis never exceeded
                                       D-7
    

    -------
    1 hour.  Some of the samples were retained for 24 hours and reanalyzed
    to verify that there was no sample degradation in samples of this
    type.  The loss of benzene and isobutane observed was typically  less
    than 5 percent.
         D.2.2.2  Dispersion Apparatus.  The apparatus for the dispersion
    of trace gas consists of a cylinder of the tracer gas connected  to  a
    dry gas meter, a rotameter, and a dispersion tube.  All necessary
    connecting lines are Teflon.  The dispersion tube was 8 feet long in
    two 4-foot sections connected via a T-joint to each other and to the
    tracer gas source.  The tube was constructed of  1/4-inch O.D. stainless
    steel tubing with 0.041-inch holes every 19 inches.  The ends of the
    tube were capped.
                          • Rotometer
                                           1/4" Teflon
                                            Tube
    Dispersion
      Tube
                            "-•Dry Gas Meter
            Isobutane
         D.2.2.3  Method Development.
         D.2.2.3.1  Tracer gas selection.  The  initial  consideration  with
    the tracer gas method is the selection of a suitable  gas  for which
    several criteria are used.  First, the tracer  gas must  not  be  present
    in the atmosphere at the sampling  location.  Second,  the  tracer gas
    must be separable from other components  in  the background at the
    sampling location and quantifiable on the same gas  chromatograph  (GC)
    column without interfering with  the  elution of the  compound(s) of
    primary interest.  The tracer gas  should also  be readily  available,
    transportable, economically feasible, and safe for  any  given usage.
         Isobutane is the recommended  tracer gas to determine benzene
    emissions at coke oven by-product  plants.   The second choice for  a
    tracer gas is a halogenated hydrocarbon.  At coke oven  by-product
    plants, the hydrocarbons in the  background  atmosphere are almost
                                       D-8
    

    -------
    exclusively emissions from the coking operation, and neither isobutane
    nor halogenated hydrocarbons are present to any significant degree.
    Isobutane was chosen over a halogenated hydrocarbon on the basis of
    chromatographic elution characteristics.  Isobutane elutes well before
    the benzene peak, thus eliminating any interference when a temperature
    program is used for the chromatographic analysis.
         Separation of isobutane from mixtures containing hydrocarbon
    concentrations typical of coke oven by-product plants was verified
    when samples collected at different sources in a coke oven by-product
    plant were spiked with various concentrations of isobutane and a
    temperature program of chromatographic analysis was conducted to
    achieve the desired separation.  In all cases, the desired separation
    was achieved.
         D.2.2.3.2  Dispersion tube configuration.  Two different dispersion
    tube configurations were tested, both constructed from 1/4-inch
    O.D. stainless steel tubing.  The first tube tested was 8 feet long
    with the tracer source connected to one end of the tube.  The tube
    contained holes every 19 inches that were progressively larger moving
    away from the gas source, ranging from 0.062 inch to 0.031 inch.  The
    second tube was 8 feet long in two 4-foot sections that were connected
    via.a T-joint to each other and to the tracer gas source.  This dispersion
    tube had 0.041-inch holes every 19 inches and the ends were capped.
         Of the two types of dispersion tubes tested, the latter described
    was more efficient for the dispersion of the tracer.  This judgment
    was made by visual inspection of the holes in each tube while  isobutane
    was flowing at 0.1 ft3/m.  At this rate, isobutane can be seen as it
    leaves the dispersion tube, and differences in the relative volume
    leaving each hole are visually discernible.  The first configuration
    had all gas coming out of the first two holes, whereas the second
    configuration had uniform emissions from each orifice.
         D.2.2.3.3  Method verification.  To check the validity of the
    tracer gas method, a  series of experiments was run in which known
    amounts of benzene and isobutane were released simultaneously, and the
    ratio of the two was  checked against the downwind sample concentration
    ratio.
                                       D-9
    

    -------
         Samples were  collected  along a 30°  arc,  25 feet downwind from the
    emission source.
                                                Downwind
                                                Collectors
                                       Eaiaaion Source
                                      Upwind Collector
         Initially, samples were grab  samples  collected  in  clean  1-liter
    glass gas flasks.  Later samples were  integrated  over a 1/2-hour
    period and collected in clean 10-liter Tedlar  bags via  Emissions
    Measurements Air Quality Sampler with  a  flow rate of 10 £/hr.
         Two methods were tried for releasing  benzene—direct  evaporation,
    and through a heated bubbler.  Both methods proved adequate for experi-
    mental determinations.  When evaporation was used to release  benzene,
    a stainless steel pan 16 inches x  24 inches x  1/2 inches was  employed
    to contain the benzene.  During an experimental determination, benzene
    was added to the pan in 50-cm3 aliquots  at intervals frequent enough
    to maintain a constant surface area of benzene in order to keep the
    benzene emissions constant.  However,  this evaporation  method proved
    unsatisfactory on days when the wind speed exceeded  15  to  20  mph  due
    to the changing evaporation rate resulting from gusting wind.  A  more
    steady benzene emission was achieved by  using  a heated  bubbler.   The
    bubbler system consisted of a 500-cm3  impinger of the Greenburg-Smith
    design wrapped with a heat tape.   The  impinger was kept at a  constant
    temperature below the boiling point of benzene.   A rubber  disphragm
    pump was used to push atmospheric  air  through  a bubbler and flow  was
    regulated with a rotameter.
                                      D-10
    

    -------
                                              Greenb«rg-Saith Impinger
                                                          Varlac
         It was necessary to add more benzene during an experimental run,
    because the emission rate drops substantially if the benzene level
    drops too low in the impinger.  The frequency of addition and the
    quantity of benzene per addition depend on the emission rate used.
    For these determinations, it was necessary to add 50 cm3 of benzene at
    approximately 10-minute intervals.
         In initial determinations, portions of actual presurvey samples
    containing 62 percent benzene were released to simulate the type of
    sample that would be encountered in the field. } Various amounts of the
    sample mixture from 0.20 to 10 cm3 were released, and samples were
    collected downwind in 1-liter gas flasks.  When these samples were
    analyzed, the amount of benzene detected was very small, approximately
    20 ppb.  It was apparent that it would be necessary to release signifi-
    cantly more benzene to produce the necessary concentration at the
    sampling location so that quantitative mass-to-mass ratios could be
    calculated.
         Because of the necessity of releasing more benzene and avoiding
    the foul odor the high-concentration benzene field samples possessed,
    it was decided that pure benzene would be used for all subsequent
    determinations.
         For the next series of experiments evaporation as previously
    described was used to release benzene.  This series of experiments
                                       D-ll
    

    -------
    produced results accurate to within 10 percent of the theoretical
    mass-to-mass ratios with a minimum benzene emission of 0.54 Ib/hr for
    the series.  These experiments were performed on days when wind speed
    was light (5 to 10 mph) and wind direction was steady (see Table D-l).
         The next experiment was designed to test variations that might be
    introduced when wind speed was 20 to 25 mph and direction was 180°
    variable due to a changing weather system.  The benzene evaporation
    rate was affected noticeably by conditions as were emission dispersion
    patterns.  Erratic results were produced by the meteorological stress
    on key experimental variables.  Calculated mass-to-mass ratios differed
    from the theoretical value by as much as 15 to 56 percent, demonstrating
    the effect of high and variable winds on the technique.  The benzene
    bubbler as described was used to provide a steady source of benzene
    emissions at a rate independent of meteorological conditions in order
    to reduce stress on the experiment.  On the day chosen to use the
    bubbler system, wind speed was 15 to 20 mph and direction was steady.
    Favorable results were obtained despite the relatively strong wind,
    demonstrating that the tracer technique is valid in winds up to 20 mph
    depending on the sampling location (see Table D-l).
         D.2.2.3.4  Conclusions.  When the tracer gas method is used, it
    is necessary to verify that the tracer gas is detectable at the chosen
    sampling location because the method depends somewhat upon meteorolog-
    ical conditions.  The method works best when wind speed is light to
    moderate, 5 to 15 mph, and wind direction is steady.  When wind speed
    exceeds approximately 20 mph or if there is no wind and/or the wind
    direction is too variable, dispersion patterns conducive to accurate
    sampling are disturbed and quantitative mass-to-mass relationships are
    difficult to establish.  The upper limit of stress with respect to
    meteorological conditions can be examined by the spread of mass-to-mass
    ratios for each individual sample for a given sampling run.  If the
    calculated ratios are inconsistent or the deviation between each
    calculated ratio and the mean is greater than 20 percent, it would be
    necessary to seek an explanation based on process variations or meteoro-
    logical conditions or to void the sampling run and possibly suspend
    sampling until conditions are more favorable.
    
                                       D-12
    

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    D.2.3  Determination of BaP from Stationary Sources
         An EPA draft method was used for sampling BaP.  The method basically
    consists of an EPA Method 5 sampling train modified to include an
    adsorbent sample tube packed with XAD resin located between the heated
    filter and the impinger train.   The adsorbent sample tube was maintained
    at a temperature of 53° C ± 2° C (127° F ± 4°).   Figure D-3 shows a
    schematic of the BaP sampling train.
         The solvent used for washing the impingers and sample train
    glassware was tetrahydrofuran (THF).  THF was also used in the labora-
    tory to extract BaP from the filter and resin.
         The purpose of the resin was to absorb any BaP that might pass
    through the filter, although the results were inconclusive about the
    effectiveness of the filter/resin system.  In the runs on the pitch
    prilling tank, less than 15 percent of the total BaP was collected on
    the filter and in the front-half washings, whereas in the pitch storage
    tank runs almost 69 percent of the total BaP was collected on the
    filter.
         Modifications to the draft method included the use of THF as the
    extraction and wash solvent in place of methylene chloride and substi-
    tution of gas chromatography for fluorescence spectrophotometry in the
    analytical method.
    D.3  PERFORMANCE TEST METHODS FOR FUGITIVE PROCESS EMISSIONS
         The control technology considered for regulating benzene emissions
    from coke by-product recovery plants includes equipment standards that
    would totally eliminate point source emissions.  Consequently, no
    performance test methods would be applicable.
         For confined sources vented to the atmosphere through a stack,
    EPA Method 110 is recommended for benzene.  Concurrently with
    Method 110, stack gas velocity and temperature should be monitored to
    calculate a mass emission rate from the process.   Due to the low
    velocity encountered in many process vents, it is  recommended that
    stack velocity be measured with a vane anemometer.  Additionally, many
    process vents are not equipped with sampling prots and sampling must
    be conducted from the top opening of the vent.  For high-moisture gas
                                       D-14
    

    -------
    FIGURE D-3
    BaP SA1-IPLING  TRAIN
                 D-15
    

    -------
    streams, a water knockout trap is recommended to prevent the moisture
    from condensing in the sample bag.  Any moisture collected in the trap
    must be analyzed subsequently for benzene to determine total emissions
    from the test run.
         The cost for three 1-hour Method 110 test runs would be approxi-
    mately $2,000.  If the plant has in-house sampling capabilities, the
    cost could be less.
         For fugitive process emissions from sumps or other open sources,
    a standardized method of known precision and accuracy that would apply
    to all similar sources is not practicable due to technological and
    economic limitations.  Therefore, no performance test methods would be
    applicable for such a process.
    D.4  CONTINUOUS MONITORING FOR FUGITIVE PROCESS EMISSIONS
         No emission monitoring instrumentation, data acquisition, and
    data processing equipment specifically installed to measure benzene
    emissions in atmospheric vents jat coke by-product recovery plants has
    been determined to date.  However, commercial systems are available
    that incorporate Automated GC with flame ionization detection (FID)
    and are equipped with automatic data processing systems.  With selec-
    tion of the proper separation column and operating cycle time, this
    type of system could feasibly be used to monitor benzene emissions,
    although EPA has not yet developed performance specifications for
    benzene emission monitors.
         It is estimated that the installed capital cost of an emission
    monitoring system would range from $30,000 to $50,000 depending on the
    system chosen and the installation difficulty encountered.  The annual
    operating cost is estimated to be between $8,000 to $10,000 per year.
    D.5  EMISSION MEASUREMENT METHODS FOR FUGITIVE LEAKS
         To provide data in support of standards for the control of fugitive
    benzene leaks and other nonmethane hydrocarbon emissions from coke
    oven by-product recovery units in steel mills, emission factors for
    valves, flanges, pump seals, and exhauster seals were developed from a
    determination of the frequency of leak occurrences from these sources
    and from measurements of their emission rates.  EPA conducted test
                                       D-16
    

    -------
    programs at three coke by-product plants1 to screen sources in every
    type of service, to measure the emission rate from sources found
    leaking, and to analyze emissions for total nonmethane hydrocarbons
    (NMHC's) and for benzene concentration.
         Proposed Reference Method 212 was used to determine whether or
    not a leak was present at each source and to estimate the leak rate.
    All potential fugitive sources were tested for leaks by this "screening"
    procedure, which also provided a count of the frequency of leaks from
    the different types of source (i.e., valves, flanges, pumps, and
    exhausters) and for each service (i.e., .liquid or vapor).
         For sources found to be leaking, the mass emission rate was
    determined by enclosing the source temporarily in plastic through a
    bagging technique.  A vacuum flow technique was used to establish a
    known flow rate of air through the bag, and the concentration of
    NMHC's and benzene in the air stream was analyzed by means of a total
    hydrocarbon analyzer (THC) or a GC equipped with an FID.
         From the screening data and measured emission rates, it was
    possible to develop correlations to predict, within confidence inter-
    vals, the mean vapor leak rate from a given source type based on its
    screening value.  These correlations permitted the calculation of
    emission factors for NMHC's and benzene vapor and for total (vapor and
    liquid) emissions from valves, flanges, and pump and exhauster seals
    at coke by-product plants.
    D.5.1  Leak Detection Method
         Proposed Reference Method 21,2 which describes procedures for
    using a portable instrument to determine VOC leaks, was developed
    during earlier test programs to develop data on fugitive emissions
    from petroleum refineries3 and synthetic organic chemical manufacturing
    industry (SOCMI) plants.4  Reference Method 21 was considered applicable
    for this program because of the similarity of the fugitive leak sources
    and the range of vapor pressures of the chemical gaseous and liquid
    streams present in coke oven by-product processing plants.  In the
    initial refinery programs, the instrument used to monitor for fugitive
    leaks was a J. W. Bacharach "TLV Sniffer," which uses a catalytic
    oxidation detector.  More recently, a Century Systems Organic Vapor
                                       D-17
    

    -------
    Analyzer (OVA) Model 108, which uses an FID, has been used.  The TLV
    Sniffer was necessary to relate the data base of the current program
    with the much larger data base from the refinery and SOCMI programs.
    The initial screening measurements of all potential fugitive emission
    sources were performed only with the OVA.  Then, just prior to and
    immediately after the emission rate was measured from leaking sources,
    screening values were obtained with both the OVA and the TLV Sniffer.
         Hexane gas at 2,000 ppmv was used to calibrate the TLV Sniffer in
    the refinery studies and was used again in this program for the TLV
    Sniffer calibration.  Methane standard gas mixtures are recommended
    for use with the OVA.
         It was recognized that coke by-product units have a number of
    potential vapor components and compositions to which all analyzer
    types do not respond equally.  The alternative of specifying a different
    calibration material for each stream type and normalization factors
    for each instrument type was not investigated.  Because at least four
    instrument types are available that might be used in this procedure,
    and a large number of potential stream compositions are possible, the
    amount of prior knowledge necessary to develop and subsequently use
    such factors would make the interpretation of results prohibitively
    complicated.  Based on EPA test results in the SOCMI program,4 the
    number of concentration measurements in the range where a variability
    of two or three would change the decision as to whether or not a leak
    exists was small compared to the total number of potential leak sources.
    D.5.2  Emission Rate
         D.5.2.1  Sampling.  Prior to the first test, available methods
    for measuring fugitive leaks were reviewed, with emphasis  on methods
    that would provide data on emission rates from each source.  Each
    individual piece of equipment must be enclosed in a temporary cover
    for emission containment to measure emission rates.  After contain-
    ment, the  leak rate can be determined by using concentration change
    and flow measurements.  This procedure has been used in several studies3 5
    and has been demonstrated feasible to develop screening value-emission
    rate correlations and emission factors.  However, direct measurement
    of emission rates from leaks is a time-consuming and expensive procedure
                                        D-18
    

    -------
    requiring about $40 for materials and equipment and 2 person-hours per
    source6 and is not feasible or practical for routine testing because
    of the large number of sources within each process unit.   There can be
    more than 100 valves in light liquid and gas service in a process
    unit.
         To measure the leak rate accurately for any given fitting, the
    fitting was isolated from the ambient air by an enclosure (or tent) of
    Mylar plastic (polyethylene terephthalate) that may range in thickness
    from 1.5 to 15 mils.  Mylar is well suited to this function because it
    does not absorb significant amounts of hydrocarbons, is very tough,
    and has a high melting point (250° C).  The enclosures were kept small
    to provide a more effective seal, to minimize the time required to
    reach steady-state conditions, and to minimize or prevent condensation
    of heavy hydrocarbons inside the enclosure by reducing residence time
    and surface area available for heat transfer.
         The tent was connected to a sampling train, dry gas meter, and
    vacuum pump as indicated in Figure D-4 to permit a measured flow of
    air to pass through the enclosure.  If the enclosure were so air tight
    that a significant vacuum existed, a hole was made in the tent on the
    opposite side from the outlet.  Sample bags of 2-mil Tedlar plastic
    were used to collect gas samples and transport them to a mobile labora-
    tory for analyses.  The cold trap was placed close to the tent to
    condense water and  heavy organics, thus preventing condensation in
    downstream  lines and equipment.  Any organic condensate that collected
    in the cold trap was measured for  later use  in calculating total  leak
    rates.  The use of  such a cold trap was critical; without it, order of
    magnitude errors were possible.
         The flow rate  through the system was throttled with a control
    valve  immediately upstream of the  vacuum pump when necessary to avoid
    operations  with an  explosive mixture of hydrocarbon  in the air.
         The sample procedure was accomplished  in the following steps:
              Obtain screening values  with  the OVA and TLV Sniffer.
              Enclose the  fitting in  a tight Mylar shroud.
                                       D-19
    

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              Connect the sampling train to the "tent."
    
              Immerse the cold trap in an ice bath.
    
              Note the initial reading of the dry gas meter.
    
              Start the vacuum pump and a stopwatch  simultaneously.
    
              Record the temperature and pressure at the dry gas
              meter.
    
              Observe the volatile organic compound  (VOC) concentration
              with the OVA at the vacuum pump exhaust.
    
              Record the temperature, pressure, dry  gas  meter reading,
              outlet VOC concentration, and elapsed  time every 2 to
              5 minutes.
    
              When the outlet VOC concentration stabilized, the
              system was at steady-state condition.   Fill a gas
              sample bag from the discharge of the Teflon-lined
              diaphragm pump.
    
              Fill another bag with ambient air near the tent area to
              measure the background VOC concentration.
    
              Take a,final set of readings and stop  the  vacuum pump.
    
              Remove the cold trap, seal it, and transport it to the
              laboratory along with the two bag samples  and the data
              sheet.
    
              Remove tent.
    
              Rescreen source with the OVA and TLV Sniffer.
    
         D.5.2.2  Chromatographic Analysis.  The concentration of total
    
    hydrocarbon and of benzene was determined through gas Chromatographic
    
    procedures to quantitate the VOC emissions from  the  bagged sources.
    
         Primary analysis of VOC's was performed on  a Byron 301C THC as
    
    was done in an earlier study.7  Because of an upper  limit of 20,000 ppmv
    
    to quantitate VOC samples on this instrument, when necessary, dilutions
    
    of the relevant samples were made with a 1.5-liter gas-tight syringe.
         Methane calibrations were carried out daily on  the THC with an
    
    8,000-ppmv methane/air tank standard.  NMHC calibrations were also
    carried out daily on the THC with a 713 ppmv NBS propane standard.
                                       D-21
    

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         Analyses for benzene were performed on a Hewlett Packard 573A
    dual FID Gas Chromatograph.  Dual gas samples were introduced simul-
    taneously onto separate columns with a Valco 10 port Hastalloy C
    multiport valve installed immediately forward of the GC syringe
    injection ports.  Peak integrations were compiled on two Hewlett
    Packard 3380A electronic integrators.
         Liquid samples were analyzed by normal syringe injection techniques
    using benzene as an external standard.
         The columns and conditions used for the analyses are listed
    below:
              1/8-in. OD, 2-mm ID, 15-ft, 5 percent SP-2100/1.75 per-
              cent Benton 34 on 100/120 mech Supelcoport.
              1/8-in. OD, 2-mm ID, 15-ft, 10 percent TCEP on 100/120
              mesh chromosorb P acid washed.
              N2 carrier at 20 m£/min.
              Isothermal at 110° C.
         The instrument was calibrated daily with a 5,571-ppmv benzene in
    air standard.  Single analyses were done simultaneously on the two
    different volumes after calibration.
    D.6  CONTINUOUS MONITORING SYSTEMS AND DEVICES FOR FUGITIVE LEAKS
         Because the leak determination procedure is not a typical emission
    measurement technique, continuous monitoring approaches are not directly
    applicable.  Continual surveillance is achieved by repeated monitoring
    or screening of all potential leak sources.  A continuous monitoring
    system or device could serve as an indicator that a leak has developed
    between inspection intervals.  In the study of fugitive emissions from
    synthetic organic chemical manufacturing,4 EPA performed a limited
    evaluation of fixed-point monitoring systems for their effectiveness
    in leak detection.   The systems consisted of both remote sensing
    devices with a central readout and a central analyzer system (gas
    chromatograph) with remotely collected samples.   Results of these
    tests indicated that fixed-point systems were not capable of sensing
    all leaks found by individual component testing.  This is to be expected
    since these systems are affected significantly by local dispersion
                                       D-22-
    

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    conditions and would require either many individual  point locations,
    or very low detection sensitivities to achieve results similar to
    those obtained through an individual component survey.
         It is recommended that fixed-point monitoring systems not be
    required since general specifications cannot be formulated to ensure
    equivalent results and each installation would have to be evaluated
    individually.
    D.7  PERFORMANCE TEST METHOD FOR FUGITIVE LEAKS
         The recommended fugitive emission detection procedure is Reference
    Method 21.  This method incorporates the use of a portable instrument
    to detect the presence of volatile organic vapors at the surface of
    the interface where direct leakage to the atmosphere could occur.
    This technique's approach assumes that if an organic leak exists,
    vapor concentration will increase in the vicinity of the leak and that
    the measured concentration is generally proportional to the organic
    compound's mass emission rate.
         An additional procedure provided in Reference Method 21 is to
    determine "no detectable emissions."  The portable VOC detector is
    used to determine local ambient VOC concentration in the vicinity of
    the source to be evaluated, and then a measurement is made at the
    surface of the potential leak interface.  If a concentration change of
    less than 2 percent of the leak definition is observed, a "no detect-
    able emissions" condition exists.  The definition of 2 percent
    of the leak definition was selected based on the readability of a
    meter scale graduated in 2 percent increments from 0 to 100 percent of
    scale and not necessarily on the performance of emission sources.  "No
    detectable emissions" would exist when the observed concentration
    change between local ambient and leak interface surface measurements
    is less than 200 ppmv if the leak definition is 10,000 ppmv.
         Reference Method 21 does not include a specification of the
    instrument calibration basis or a definition of a leak in terms of
    concentration.  Based on results of EPA field tests and laboratory
    studies, methane is recommended as the reference calibration basis for
    fugitive emission sources at coke oven by-product recovery units.
                                       D-23
    

    -------
         At least four types of detection principles currently are available
    in commercial portable instruments.   These are flame ionization,
    catalytic oxidation, infrared absorption (NDIR), and photoionization.
    Two types (flame ionization and catalytic oxidation) are known to be
    available in factory mutual certified versions for use in hazardous
    atmospheres.
         The recommended test procedure includes a set of design and
    operating specifications and evaluation procedures by which an analyzer's
    performance can be evaluated.  These parameters were selected based  on
    the allowable tolerances for data collection and not on EPA evaluations
    of the performance of individual instruments.   Based on manufacturer's
    literature specifications and reported test results, commercially
    available analyzers can meet these requirements.
         There is little correlation between screening value and emission
    rate for sources exhibiting liquid leaks.  When a source has a visible
    liquid leak, a leak rate may be estimated by collecting and measuring
    the volume of liquid in a given time.  The sum of the vapor and liquid
    leak is then a good estimate of the total leak.
         The estimated purchase cost for an analyzer ranges from about
    $1,500 to $5,000, depending on the type and optional equipment.   The
    cost of surveying a unit consisting of approximately 300 potential
    leaking sources will consist basically of the cost of 40 labor hours.
    A two-man team should be able to screen approximately 150 sources per
    day and record the location and nature of the sources leaking.
         An alternative approach to leak detection is an area survey, or
    walk-through, using a portable detector.  In this approach, the unit
    area is surveyed by walking through the unit, positioning the instrument
    probe within one meter of all valves and pumps, and continuously
    recording the concentration on a portable strip chart recorder.   After
    completion of the walk-through, local wind conditions are used with
    the chart data to locate the approximate source of any increased
    ambient concentrations.  This procedure was found to yield mixed
    results in an earlier EPA study.4  In some cases, the majority of
    leaks located by individual component testing could be located by
    walk-through surveys.  In other tests, prevailing dispersion conditions
                                       D-24
    

    -------
                   t
    
    and local, elevated ambient concentrations complicated or prevented
    
    the interpretation of the results.  Because of the potential variability
    in results from site to site, routine walk-through surveys were not
    
    selected as a reference or alternate test procedure.
    
    D.7  REFERENCES
    X.   Smith, C. D., and J. L. Steinmetz (Radian Corporation).  Emission
         Factors arfd Frequency of Leak Occurrence for Fittings in Coke
         By-Product Recovery Units.  Draft Final Report.  Prepared for
         U.S. Environmental Protection Agency.  Research Triangle Park,
         NC.  Contract No. 68-02-3542.  March 1981.
    
    2.   Method 21, "Determination of Volatile Organic Compound Leaks."
         Federal Register 40 CFR, Part 60, Appendix A.  48 FR 37598,
         August 18, 1983.
    
    3.   Wetherold., R. G. , L. P. Provost, D. D. Rosebrook, and C. D.
         Smith.  (Kadian Corporation).  Emission Factors and Frequency of
         Leak Occurrence for Fittings in Refinery Process. Units.  Prepared
         for U.S. Environmental Protection Agency.  Research Triangle
         Park, NC.  Publication No. EPA-600/2-79-004.  February 1979.
    
    4.   U.S. Environmental Protection Agency.  VOC Fugitive Emissions in
         Synthetic Organic Chemicals Manufacturing Industry—Background
         Information for Proposed Standards, Draft EIS.  Research Triangle
         Park, NC.  Publication No. EPA-45Q/3-80-033a.  November 1980.
    
    5.   Joint District, Federal, and State Project for the Evaluation of
         Refinery Emissions.  Los Angeles County Air Pollution Control
         District.  Report Numbers 2, 3, 5, 6, and 8.  1957-1958.
    
    6.   Memo from "Harris, G. E., Radian Corporation, to Wilkins, G. E.,
         Radian Corporation.  June 19, 1980.  1 p.  Information about
         bagging costs.
    
    7.   U.S. Environmental Protection Agency.  Control of Volatile Organic
         Compound  Leaks from Petroleum Refinery Equipment.  Research
         Triangle-fPark, NC.  Publication No. EPA-450/2-78-036.  June 1978.
                                       D-25
    

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                            APPENDIX E
    METHODOLOGY FOR ESTIMATING LEUKEMIA INCIDENCE AND MAXIMUM
      LIFETIME RISK FROM EXPOSURE TO BENZENE EMISSIONS FROM
               COKE OVEN BY-PRODUCT RECOVERY PLANTS
    

    -------
                                  APPENDIX E -
           METHODOLOGY FOR ESTIMATING  LEUKEMIA  INCIDENCE AND MAXIMUM
              LIFETIME RISK FROM EXPOSURE TO BENZENE EMISSIONS FROM
                     COKE QVEN BY-PRODUCT RECOVERY PLANTS
    
    E.1  INTRODUCTION
         The  purpose of this appendix  is to describe the methodology used
    to estimate leukemia incidence and maximum  lifetime risk from population
    exposure  to benzene emissions from coke oven by-product recovery
    plants, to present emissions data  for the regulatory baseline, and to
    describe  the calculation of input  data for  other regulatory alterna-
    tives.  The methodology consists of four major components:   estimation
    of the annual average concentration patterns of benzene in the region
    surrounding each plant, estimation of the population associated with
    each computed concentration, estimation of  exposures computed by
    summing the products of the concentrations  and associated populations,
    and finally, estimation of annual  leukemia  incidence and maximum
    lifetime  risk which are obtained from exposure and benzene potency
    data.1  Due to the assumptions made in each of these four steps of the
    methodology, there is considerable uncertainty associated with the
    lifetime  individual risk and leukemia incidence numbers calculated in
    this appendix.   They may represent overestimates or underestimates.
    These uncertainties are explained in Section E.7 of this appendix.
    The health effects of benzene will not be included in this appendix;
    however,  information on health effects is contained in EPA Docket
    No.  79-3 and "Response to Public Comments on EPA's Listing of Benzene
    Under Section 112 and Relevant Procedures for the Regulation of Hazard-
    ous Air Pollutants," EPA-450/5-82-003.   The appendix is presented in
    major subsections:
                         r
                                     E-2
    

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              Section E.2,  Atmospheric Dispersion Methodology, describes
              the methodology for calculating concentrations of benzene
              emissions to a radius of 20 km from the source.
    
              Section E.3,  Population Around Coke Oven By-Product
              Recovery Plants, describes the method used to estimate
              the population at risk; i.e., persons residing within
              20 km of existing coke oven by-product recovery plants.
    
              Section E.4,  Population Exposure Methodology, describes the
              methodology for calculating expected population exposures.
    
              Section E.5, Model Input Data, presents input data for
              the regulatory baseline and describes the calculation of
              input data for other regulatory alternatives.
    
              Section E.6, Leukemia Incidence Estimates, describes the
              annual leukemia incidence resulting from nonoccupational
              exposure and the maximum lifetime risk of leukemia
              attributable to benzene emissions from existing U.S. coke
              oven by-product recovery plants.
    
              Section E.7, Uncertainties in Estimates, discusses
              potential causes o| uncertainties in the derivation of
              the unit risk factor and the human exposure model.
    
    E.2  ATMOSPHERIC DISPERSION METHODOLOGY
    
         The human exposure model,1 which uses the same basic dispersion
    algorithm as the EPA's climatological display model (COM),2 was used
    to make concentration pattern estimates.
         Because wind velocity and atmospheric stability are the only
    
    meteorological variables involved in the Gaussian dispersion estimation,
    it is only necessary to evaluate 36 potential solutions (six wind
    speed categories times six stability classes) for a given source
    elevation and building cross-section combination.   In this manner, a
    file of normalized Gaussian solutions (concentrations/emissions), one
    for each combination of stability and wind speed classes, is created.
    This file is then stored for^further use (matrix multiplication) in
    conjunction with climatological (STAR*) data and emissions data.  This
         *STAR data are standard climatological frequence of occurrence
    summaries formulated for use in EPA models and available for major
    U.S. sites from the National Climatic Center, Asheville, N.C.   The
    data consist of frequencies which are tabulated as functions of wind
    speed stability and wind direction classes.
    
                                      E-3
    

    -------
    approach allows incorporation of the following key factors in the
    estimation of annual average ground level concentration patterns from
    a single emission site:
              Climatological data (STAR) from the nearest or otherwise
              most appropriate site,
              Individual emissions from each identified stack or vent
              within a plant, as well as fugitive emissions,
              Plume release height, speed, and buoyancy, and  ,
              Urban or rural character of the emission site.
         The output from the concentration pattern part of the computer
    program is a well-formatted concentration array for 160 receptors
    around each plant (10 receptors at distances of 0.2, 0.3, 0.5, 0.7, 1,
    2, 5, 10, 15, and 20 km along each of 16 wind directions).   Each
    receptor in the array has an associated value which is equal to the
    sum of all individual contributions from emissions sources within a
    plant.  The concentration patterns for each plant can be found in
    Docket No. A-79-16.
    E.3  POPULATION AROUND COKE OVEN BY-PRODUCT RECOVERY PLANTS
         The human exposure model (HEM) estimates the population that
    resides in the vicinity of each receptor coordinate surrounding each
    coke oven by-product recovery plant.   The population "at risk" to
    benzene exposure was considered to be persons residing within 20 km of
    coke oven by-product recovery plants.
         A slightly modified version of the "Master Enumeration District
    List— Extended (MED-X)" data base is used for population pattern
    estimation.1  This data base is broken down into enumeration district/
    block group (ED/BG)  values.   MED-X contains the population centroid
    coordinates (latitude and longitude)  and the 1970 population of each
    ED/BG in the United States (50 States plus the District of Columbia).
    For human exposure estimations,  MED-X has been reduced from its complete
    form (including descriptive and summary, data) to produce a randomly
    accessible computer file of the data  necessary for the estimation.
                                      E-4
    

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    A separate file of county-level growth factors, based on 1978 estimates
    of the 1970 to 1980 growth factor at the county level, has also been
    used to estimate 1980 population figures for each ED/BG.
    E.4  POPULATION EXPOSURE METHODOLOGY
    E.4.1  Exposure Methodology
         For each receptor coordinate, the estimated concentration of
    benzene and the population estimated to be exposed to that particular
    concentration are generated.   The HEM multiplies these two numbers to
    produce population exposure estimates and sums these products for each
    plant.  A two-level scheme has been adopted in order to pair concentra-
    tions and populations prior to the computation of exposure.  The
    two-level approach is used because the concentrations are defined on a
    radius-azimuth (polar) grid pattern with nonuniform spacing.  At small
    radii, the grid cells are generally much smaller than ED/BGs; at large
    radii, the grid cells are much larger than ED/BGs.  The area surround-
               *
    ing the source is divided into two regions, and each ED/BG is classi-
    fied by the region in which its centroid lies.  Population exposures
    are calculated differently for the ED/BGs located within each region.
         For ED/BG centroids located between 0.1 km and 2.8 km from the
    emission source, populations are divided between neighboring concentra-
    tion grid points.  There are 96 (6 x 16) polar grid points within this
    range.  Each grid point has a polar sector defined by two concentric
    arcs (rad.ii 0.1, 0.25, 0.4, 0.6, 0.8, 1.2, and 2.8 km) and two wind
    direction radials.  Each of these grid points is assigned to the
    nearest ED/BG centroid identified from MED-X.  The population associated
    with the ED/BG centroid is then divided among all concentration grid
    points assigned to it.  The exact land area within each polar sector
    is considered in the apportionment.
         For population centroids between 2.8 km and 20 km from the source,
    a concentration grid cell, the area approximating a rectangular shape
    bounded by four receptors, is much larger than the area of a typical
    ED/BG (usually 1 km in diameter).  Since there is a linear relationship
    between the logarithm of concentration and the logarithm of distance
    for receptors more than 2 km from the source, the entire population of
                                     E-5
    

    -------
     the EG/BD is assumed to be exposed to the concentration that is geomet-
     rically interpolated radially and arithmetically interpolated azimuth-
     ally from the four receptors bounding the grid cell.  Concentration
     estimates for 80 (5 x 16) grid cell receptors at 2.0, 5.0, 10.0, 15.0,
     and 20.0 km from the source along each of 16 wind directions are used
     as reference points for this interpolation.
          In summary, two approaches .are used to arrive at coincident
     concentration/population data points.   For the 96 concentration points
     within 2.8 km of the source, the pairing occurs at the polar grid
     points using an apportionment of ED/BG population by land area.   For
     the remaining portions of the grid, pairing occurs at the ED/BG cen-
     troids themselves,  through the use of  log-log linear interpolation.
     (For a more  detailed discussion of the methodology used to estimate
     populations,  refer  to Reference 1.)
     E.4.2  Total  Exposure
          Total exposure (persons-jjg/m3) is the sum of all  multiplied pairs
     of concentration-population computed by the  previously discussed
     methodology:
    where
         P  =
         f*  —
    
         N  =
                                           N
                          Total  exposure  = I  (P.C.)
                                          i=l  i  i
    population associated with point i,
    annual average benzene concentration at point i, and
    total number of polar grid points between 0 and 2.8 km
    and ED/BG centroids between 2.8 and 20 km.
                                                             (1)
         The computed total exposure is then used with the unit risk
    factor to estimate incidence and maximum lifetime individual risk.
    This methodology is described in the following sections.  (Note:
    "Exposure" as used here is the same as "dosage" in the computer print-
    out in Docket A-79-16.)
    E.4.3  Unit Risk Factor
         The unit risk factor (URF) is defined as the probability of
    contracting leukemia assuming an individual is exposed to 1 ug/m3 of
    
                                   E-6
    

    -------
                                                        _Q
    benzene for 1 year.   The URF for benzene is 9.9 x 10  .   The URF was
    calculated by EPA's Carcinogen Assessment Group (CAG).  The derivation
    of the URF can be found in the CAG report on population risk to ambient
    benzene exposure3 and is updated in the EPA report, "Response to
    Public Comments on EPA's Listing of Benzene Under Section 112 and
    Relevant Procedures for the Regulation of Hazardous Air Pollutants,"
    EPA-450/5-82-003.
    E.4.4  Calculation of Estimated Annual Leukemia Incidence
         The annual leukemia incidence associated with a given plant under
    a given regulatory alternative is the product of the total exposure in
                                                    _ Q
    ug/m3-persons and the unit risk factor, 9.9 x 10  .  Thus,
         Annual incidence = (total exposure) x (unit risk factor)
    where total exposure is calculated according to Equation (1).
    E.4.5  Calculation of Maximum Lifetime Risk
    (2)
         The populations in areas surrounding coke oven by-product recovery
    plants have various risk levels of leukemia incidence from exposure to
    benzene emissions.  Using the maximum concentration of benzene to
    which any person is exposed, it is possible to calculate the maximum .
    lifetime risk of leukemia (lifetime probability of leukemia to persons
    exposed to the highest concentration of benzene) attributable to
    benzene emissions using the following equation:
              Maximum lifetime risk = mavC. . x (URF) x 70 ,            (3)
                                      max i j
    where
              C.. = the maximum concentration at any receptor location
           m    ^   where exposed persons reside, and
              URF = the unit risk factor, 9.9 x 10  , and
         70 years = average individual's life span.
    E.5  MODEL INPUT DATA
         The inputs to the model include plant-specific locations, source
    types, and emissions from each source type.  Table E-l lists the 55
    plants with the latitudes and longitudes, which were derived from
    maps.  It also lists the emissions under the regulatory baseline for
                                     E-7
    

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    -------
    each of the source types present in the plant.  The baseline reflects
    the emissions with no benzene standard under Section 112 of the Clean
    Air Act.  For most sources at most plants, baseline represents uncon-
    trolled emissions.  However, where a source at a plant is controlled,
    the baseline emissions reflect that level of control.
         The rate of emissions for each source type at each plant is
    determined using the benzene emission factors per megagram of coke
    produced that are listed in Chapter 3 of the background information
    document and the total coke production.  As an example, the calculation
    of emissions from tar decanting at Plant 26 is presented in Equation (4).
    The emission factor for tar decanting has been determined to be 77 g
    of benzene per megagram of coke produced.  At Plant 26, the capacity
    is 4,038 Mg of coke produced per day.  The rate of benzene emissions
    from tar decanting in grams per second is obtained as follows:
    r
    77 g of benzene
       Mg of coke
    4.038 Mg of coke
         day
                                              day
                                           86,400 sec
    = 3.60 g/s .  (4)
    When the emissions are controlled, the uncontrolled emission rates are
    adjusted according to the efficiency of the control technique.   For
    example, a gas blanketing system on tar decanters provides 95-percent
    control of benzene emissions.  As shown in Equation (4), the uncontrolled
    rate of benzene emissions from the tar decanter at Plant 26 is  3.60 g/s.
    When controlled by gas blanking, this emission rate would be reduced
    by 95 percent, to 0.18 g/s (3.60 x 0.05).
         Table E-2 presents the parameters of the stack and stack gas that
    are input to the model for each source type.   The parameters include
    gas temperature and velocity, diameter of the vent, height of emission
    point from the ground, and vertical cross-sectional area of the building
    associated with the stack.  They were derived from plant visits,
    emission test reports, Section 114 responses, blueprints of plant
    designs supplied by the companies, and engineering estimates.
         This appendix only shows model inputs and results for the  baseline
    case.   When best available technology (BAT) and beyond BAT are  selected,
                                     E-10
    

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    -------
     the dispersion and exposure modeling are done using the same methodol-
     ogy as for the baseline case.   The emission rates are adjusted according
     to the percent reduction afforded by the control  technique.
     E.6  LEUKEMIA INCIDENCE ESTIMATES
          Table E-3 presents the estimates of maximum  annual  average concen-
     tration and of total  exposure  for each plant under baseline  conditions.
     The industry-wide estimates of total  exposure,  annual  incidence,  and
     maximum lifetime  risk under baseline are presented in the  following
     sections.   The computer printout indicating health risk impacts at the
     baseline,  BAT and beyond BAT levels  can be  found  in Docket A-79-16.
     E.6.1  Total  Exposure
          Total  exposure  (in megagrams per cubic meter multiplied by the
     number of  persons) was  found by multiplying each  appropriate concentra-
     tion  by the population  exposed to that concentration and summing  the
     products of these two numbers  as shown in Equation (1).  Total  industry-
     wide  exposure under baseline is 2.74  x 107  persons-pg/m3.
     E.6.2  Estimated  Annual  Leukemia Incidence
          The annual leukemia incidence is estimated as shown by  Equa-
     tion  (2).   The'industry-wide estimated annual leukemia  incidence  is
     2.6 cases/year.
     E.6.3  Maximum Lifetime  Risk Estimates
          The maximum  lifetime risk estimate within the coke oven by-product
     recovery industry is  8.3 x  io"3,  where the  maximum concentration  is
             O
     1.19  x  10   ug/m3.  The population at  this level of risk is a small
     subset  of the  total population  exposed to benzene  emissions  from  coke
     oven  by-product recovery plants.
     E.7   UNCERTAINTIES
          Estimates of both leukemia  incidence and maximum lifetime  risk
    are primarily  functions of estimated  benzene concentrations,  popula-
    tions, the  unit risk  factor, and  the  exposure model.  The calculations
    of these variables are subject to a number of uncertainties of various
    degrees.  Some of the major uncertainties are identified below.
                                    E-li
    

    -------
    TABLE E-3.   ESTIMATED MAXIMUM CONCENTRATION AND EXPOSURE FOR
            BENZENE EMISSIONS FROM COKE BY-PRODUCT PLANTS
                            BASELINE CASE
    Maximum annual
    average
    concentration
    Plant and address (ug/m3)
    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.
    Alabama By-Products, Terrant, AL
    Empire Coke, Holt, AL
    Koppers Company, Woodward, AL
    Republic Steel, Gadsden, AL
    Republic Steel Thomas Works, Birmingham, AL
    Jim Walter, Birmingham, AL
    U.S. Steel, Fairfield, AL
    Kaiser Steel, Fontana, CA
    CF&I, Pueblo, CO
    National Steel, Granite City, IL
    Interlake, S. Chicago, IL
    Republic Steel, S. Chicago, IL
    Bethlehem Steel, Burns Harbor, IN
    Citizens Gas & Coke Utility,
    Indianapolis, IN
    Indiana Gas and Chemical, Terre Haute, IN
    Inland Steel, East Chicago, IN
    J&L Steel, East Chicago, IN
    U.S. Steel, Gary, IN
    Allied Chemical, Ashland, KY
    Bethlehem Steel, Sparrows Point, MD
    Detroit Coke, Detroit, MI
    Ford Motor Company, Dearborn, MI
    National Steel, Detroit, MI
    Carondolet Corporation, St. Louis, MO
    Tonawanda Coke Co., Buffalo, NY
    Bethlehem Steel, Lackawanna, NY
    Donner-Hanna Coke, Buffalo, NY
    3.
    1.
    2.
    5.
    2.
    1.
    2.
    49
    10
    86
    13
    37
    15
    50
    '1.19
    1.00
    4.79
    1.00
    1.11
    1.00
    8,
    
    6
    6
    4
    5
    2
    2
    5
    1
    1
    7
    8
    2
    3
    .37
    
    .73,
    .06
    .43
    .00
    .92
    .50
    .00
    .00
    .00
    .58
    .28
    .50
    .49
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    102
    102
    102
    102
    102
    102
    102
    10s
    102
    102
    102
    102
    102
    10 !
    
    101
    102
    102
    102
    102
    102
    101
    102
    102
    10 !
    101
    102
    102
    Total
    exposure
    (persons-
    Mg/m3)
    3.
    4.
    1.
    2.
    3.
    2.
    9.
    4.
    1.
    5.
    8.
    4.
    5.
    2,
    
    7.
    1
    1
    1
    1
    6
    1
    7
    1
    1
    4
    7
    7
    17
    24
    90
    36
    37
    78
    75
    47
    51
    84
    64
    .34
    ,08
    .01
    
    .98
    .11
    .08
    .41
    .98
    .33
    .95
    .17
    .25
    .49
    .49
    .99
    .37
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    10s
    104
    105
    105
    10 5
    105
    10s
    105
    104
    105
    10s
    10s
    104
    105
    
    104
    106
    106
    106
    10s
    105
    10 5
    105
    106
    105
    104
    10 5
    10s
                                                             (continued)
                               E-13
    

    -------
    TABLE E-3  (continued)
    
    28.
    29.
    30.
    31.
    32.
    33.
    34.
    35.
    36.
    37.
    38.
    39.
    40.
    41.
    42.
    43.
    44.
    45.
    46.
    47.
    48.
    49.
    50.
    51.
    52.
    53.
    54.
    55.
    Plant and address
    Ironton Coke, Ironton, OH
    Armco Steel, Hamilton, OH
    Armco Steel, Middletown, HO
    New Boston Coke, Portsmouth, OH
    J&L Steel, Campbell, OH
    Koppers Co., Toledo, OH
    Republic Steel, Cleveland, OH
    Republic Steel, Massillion, OH
    Republic Steel, Warren, OH
    Republic Steel, Youngtown, OH
    U.S. Steel, Lorain, OH
    Bethlehem Steel, Bethlehem, PA
    Bethlehem Steel, Johnstown, PA
    J&L Steel, Aliquippa, PA
    Koppers Company, Erie, PA
    Philadelphia Coke, Philadelphia, PA
    Shenango Coke, Pittsburgh, PA
    U.S. Steel, Clairton, PA
    U.S. Steel, Fair! ess Hills, PA
    Wheeling-Pittsburgh, Monessen, PA
    Chattanooga Coke & Chemical,
    Chattanooga, TN
    Lone Star Steel, Lone Star, TX
    Lone Star Steel, Provo, UT
    National Steel, Browns Island, WV
    National Steel, Weirton, WV
    Wheeling-Pittsburgh, E. Steubenville, WV
    Milwaukee Solvay, Milwaukee, WI
    J&L Steel, Pittsburgh, PA
    Maximum annual
    average
    concentration
    (ng/m3)
    2
    1
    6
    1
    3
    3
    5
    .64
    .00
    .15
    .30
    .47
    .34
    .19
    2.50
    2.08
    3.12
    2.50
    6.77
    1.25
    3.36
    5.42
    4.27
    1.00
    9.
    4.
    1.
    1.
    1.
    1.
    2.
    2.
    5.
    3.
    6.
    25
    82
    34
    25
    00
    00
    76
    82
    00
    06
    35
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    102
    102
    102
    102
    102
    10 1
    102
    10 !
    102
    102
    102
    102
    102
    102
    101
    10 !
    102
    102
    102
    102
    102
    102
    102
    102
    102
    10 !
    10 1
    102
    Total
    exposure
    (persons-
    (jg/m3)
    2
    1
    9,
    4,
    5.
    3.
    1.
    6.
    .30
    .66
    .57
    .06
    .85
    .22
    .16
    ,50
    2.06
    5.76
    1.
    1.
    1.
    2.
    6.
    1.
    3.
    1.
    8.
    1.
    1.
    1.
    9.
    1.
    1.
    1.
    1.
    3.
    33
    41
    97
    63
    93
    86
    90
    05
    88
    13
    15
    60
    63
    26
    46
    86
    23
    25
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    10s
    10s
    10 5
    104
    10s
    104
    106
    104
    10s
    10s
    106
    106
    10s
    10s
    104
    10s
    10s
    106
    10 5
    10s
    10s
    104
    104
    105
    105
    10s
    105
    106
          E-14
    

    -------
    E.7.1  Benzene Concentrations
         Modeled ambient benzene concentrations depend upon:   (1) plant
    configuration, which is difficult to determine for more than a few
    plants; (2) emission point characteristics, which can be different
    from plant to plant and are difficult to obtain for more than a few
    plants; (3) emission rates, which may vary over time and from plant to
    plant; and (4) meteorology, which is seldom available for a specific
    plant.  The particular dispersion modeling used can also influence the
    numbers.  The dispersion models also assume that the terrain in the
    vicinity of the source is flat.  For sources located in complex terrain,
    the maximum annual concentration could be underestimated by several
    fold due to this assumption.  The best model to use (ISC) is usually
    too resource intensive for modeling a large number of sources.  The
    less complex model that was used for coke by-product recovery plants
    introduces further uncertainty through a greater number of generalizing
    assumptions.  The dispersion coefficients used in modeling are based
    on empirical measurements made within 10 kilometers of sources.  These
    coefficients become less applicable at long distances from the source,
    and the modeling results become more uncertain.  Assuming the inputs
    to the dispersion model are accurate, the predicted benzene concentra-
    tions are considered to be accurate to within a factor of 2.
    E.7.2  Exposed Populations
         Several simplifying assumptions were made with respect to the
    assumed exposed population.  The exposed population was assumed to be
    immobile, remaining at the same location 24 hours per day, 365 days
    per year, for a lifetime (70 years). .This assumption is counterbal-
    anced to some extent (at least in the calculation of incidence) by the
    assumption that no one moves into the exposure area either permanently
    as a resident or temporarily as a transient.  The population "at risk"
    was assumed to reside within 20 km of each plant regardless of the
    estimated concentration at that point.  The selection of 20 km is
    considered to be a practical modeling stop-point considering the
    uncertainty of dispersion estimates beyond 10 km.  The results of
    dispersion modeling are felt to be reasonably accurate within that
                                      E-15
    

    -------
     distance (see above).   The  uncertainty of these  assumptions  has  not
     been quantified.
     E.7.3  Unit Risk  Factor
          The unit risk factor contains  the uncertainties  associated  with
     the  occupational  studies of Infante,  Aksoy,  and  Ott,  and  the  variations
     in the  dose/response  relationships  among  the studies.  Other  uncertain-
     ties regarding the occupational  studies and  the  workers exposed  that
     may  affect  the unit risk factor  were  raised  during  the public comment
     period  on the listing of benzene and  focus on assumptions and inconclu-
     sive data contained in the  studies.   However,  those uncertainties have
     not  been quantified.
     E.7.4  Other Uncertainties
          There  are several  uncertainties  associated  with  estimated health
     impacts.  Maximum lifetime  risk  and annual leukemia incidence were
     calculated  using  the  unit risk factor, which  is  based on a no-threshold
     linear  extrapolation  of leukemia risk and applies to  a presumably
     healthy white male cohort of workers  exposed  to  benzene concentrations
     in the  parts  per  million range.   It is uncertain whether the  unit risk
     factor  can  be accurately applied to the general  population, which
     includes  men,  women,  children, nonwhites, the  aged, and the unhealthy,
     who  are exposed to concentrations in  the parts per  billion range.  It
     is uncertain  whether  these widely diverse segments  of the population
     may  have  susceptibilities to leukemia that differ from those  of workers
     in the  studies.   Furthermore, while leukemia  is  the only benzene
     health  effect considered in these calculations,  it  is not the only
     possible  health effect.  Other health effects, such as aplastic anemia
     and  chromosomal aberrations, are not as easily quantifiable and are
     not  reflected  in the  risk estimates.  Although these other health
     effects have  been  observed at occupational levels,  it is not  clear if
     they result from ambient benzene exposure levels.  Additionally,
     benefits that would affect the general population as the result of
     indirect control of other organic emissions in the process of control-
     ling benzene emissions from coke by-product recovery plants are not
    quantified.   Possible benzene exposures from other sources also are
                                    E-16
    

    -------
    not included in the estimate.  For example, an individual living near
    
    a coke by-product recovery plant is also exposed to benzene emissions
    from automobiles.  Finally, these estimates do not include cumulative
    
    or syner.gistic effects of concurrent exposure to benzene and other
    
    substances.
    
    E.8  REFERENCES
    
     1.  Environmental Protection Agency.  1980:  Human Exposure to Atmos-
         pheric Concentrations of Selected Chemicals, Attachment B.  U.S.
         Environmental Protection Agency.  Research Triangle Park, North
         Carolina.   EPA Contract No. 68-02-3066.
    
     2.  Busse, A. D., and J. R. Zimmerman.  User's Guide for the  Climate-
         logical Dispersion Model.  U.S. Environmental Protection  Agency.
         Research Triangle Park, North Carolina.  Publication No.  EPA-RA-
         73-024 (NTIS PB 227346/AS).  December 1973.
    
     3.  Albert , R.  E.  Carcinogen Assessment Group's Final Report on
         Population  Risk to Ambient Benzene Exposures.  U.S. Environmental
         Protection  Agency.  Publication No. EPA-450/5-80-004.  January
         1979.
                                      E-17
    

    -------
    

    -------
                      APPENDIX F
    
    
    
    SUPPLEMENTAL INFORMATION FOR THE COST ANALYSIS
    

    -------
                                  APPENDIX  F
                 SUPPLEMENTAL  INFORMATION  FOR THE COST ANALYSIS
    
     F.I  CONTROL COSTS  FOR  FUGITIVE BENZENE EMISSIONS FROM EQUIPMENT
         COMPONENTS
         The detailed cost  analysis for various control techniques applied
     to fugitive  emission sources  is presented in Tables F-l through F-6.
     Controls are analyzed for valves, pumps, exhausters, pressure relief
     devices, open-ended lines, and sampling connections in benzene service.
     The tables include  estimates  for both a leak detection and repair
     program at different intervals and costs of equipment specifications.
     The analysis for each source  is on a per item basis (e.g., cost per
     valve) and includes capital costs, annual!zed capital and operating
     costs, recovery credits,  emission reductions, and cost effectivenesses.
         For the purpose of this  analysis and for consistency with the
     model plants derived in Chapter 6, two  types of plants are defined.
     One type of  plant recovers light oil only, and the other plant recovers
     light oil and benzene.  Model Plants 1  and 2 from Chapter 6 are assigned
     to the first type,  and Model  Plant 3 represents the second type, which
     produces benzene.   Recovery credits for all of the model plants are
     based on the value  and quantity of benzene in the total emission
     reduction.   A value of $350/Mg benzene  (1979 dollars) is used.  For
     Model Plants 1 and 2 which do not refine light oil to benzene, this is
     equivalent to a recovery  credit of $245/Mg for additional light oil
    which is 70  percent benzene.  Emission  reductions and cost effective-
     nesses are different for  the two types  because some of the equipment
     at Model Plant 3 handles  pure benzene and therefore has a higher
    benzene emission rate.   For the purpose of estimating emission reduc-
    tions,  the process streams at Model  Plants 1 and 2 are assumed to
                                      F-2
    

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    TABLE F-5.  ANNUALIZED CONTROL COSTS FOR OPEN-ENDED LINES-
                          EXISTING UNITS3
                        (May 1979 Dollars)
    
                                                    Control
                                                   technique
    Costs
    Caps on
    open end
    Installed capital cost
    
    Annualized capital
      A.  Control equipment0
      B.  Initial leak repair
    
    Annualized operating costs
      A.  Maintenance
      B.  Miscellaneous
      C.  Labor
          1.  Monitoring
          2.  Leak repair
          3.  Administrative and support
    
    Total annualized cost before credit
    Recovery credit  ,
      Models 1 and 2
      Model 3
    
    Net annualized cost^
      Models 1 and 2
      Model 3
    
    Total emission reduction (Mg/yr)
    All VOC'sh
    
    Benzene1
      Models 1 and 2
      Model 3
    
    Cost effectiveness
    VOC's ($/Mg VOC)
      Models 1 and 2
      Model 3
    Benzene ($/Mg benzene)
      Models 1 and 2
      Model 3
    
    Weighted average ($/Mg benzene)
        50
    
    
         8
         0
    
    
         3
         2
    
         0
         0
         0
    
        13
    
    
         4.90
         5.95
    
    
         8.10
         7.05
         0.020
    
    
         0.014
         0.017
       405
       353
    
       579
       415
    
       550
     All costs and emission reduction estimates are for one
     piece of equipment in benzene service.
    
    "Emissions Control Options for the Synthetic Organic Chemicals
     Manufacturing Industry.  Fugitive Emissions Report.  Hydro-
     science.  February 1979.  (Cost updates from:  Chemical
     Engineering.  Economic Indicators.  April 23, 1979 and
     July 30, 1979).
    
    'Based on 10-year equipment life and 10 percent interest
     (CRF = 0.163).
    
     0.05 x capital cost.
                              F-12
    

    -------
            Footnotes from Table F-5.   (continued)
             0.04 x capital  cost.
    
             Recovery credit is based on the value of benzene ($350/Mg)
             and the benzene emission reduction.   For Models 1 and 2
             which do not refine light oil  to benzene, this is
             equivalent to using a value of $245/Mg for additional
             light oil recovery.
    
            ^Total annual cost (before credit)--recovery credit.
    
             VOC emission reduction is based on an uncontrolled emission
             factor of 0.055 kg/day and assumes 100 percent control
             efficiency for caps.
    
            Benzene emission reduction and cost-effectiveness estimates
             are presented for each model unit, based on the percentage
             of benzene in each process:  1 and 2 = 70 percent benzene;
             3 = 86 percent benzene.
    
            ^Obtained by dividing net annualized cost by total VOC or
             benzene emission reduction.
    
            H/eighted average cost effectiveness for existing model units =
    
    Net annual cost ($/yr) Models 1 and 2 x Fraction of Models 1 and 2 + Net annual
              	cost ($/yr) Model 3 x Fraction of Model 3
    VOC emission# of existing% benzene~# of existing
      reduction
       (Mg/yr)
    Models 1 and 2  in 1 and 2
             Model 3's
    % benzene
      in 3
           # of existing
           Models I and 2
                  # of existing
                 Model Unit 3's
                           (39/46) Net annual cost ($/yr) Models 1
                           and 2 + (7/46) Net annual cost ($/yr)
                                          Model 3
                             VOC emission
                              reduction
                               (Mg/yr)
                         x
    39(0.70) + 7(0.86)
         39 + 7
                            (0.85) Net annual cost
                           Models 1 and 2 + (0.15)
                           Net annual cost Model 3
                           VOC emission
                            reduction     x 0.72
                             (Mg/yr)
                                     F-13
    

    -------
    TABLE  F-6.    ANNUALIZED  CONTROL COSTS FOR SAMPLING
                 CONNECTIONS—EXISTING  PLANTS3
                          (May  1979 Dollars)
    
                                                     Control
                                                    technique
       Costs
      Closed-purge
    sampling systems
       Installed capital cost
       Annualized capital
         A.   Control  equipment
         B.   Initial  leak repair
    
       Annualized operating costs
         A.   Maintenance
         B.   Miscellaneous
         C.   Labor
             1.   Monitoring
             2.   Leak repair
             3.   Administrative and support
    
       Total annualized cost before credit
       Recovery credit -
         Models 1 and 2T
         Model  3
    
       Net annualized cost9
         Models 1 and 2
         Model  3
    
       Total emission reduction (Mg/yr)
       All VOC'sh
    
       Benzene1
         Models 1 and 2
         Model  3T
    
       Cost effectiveness ($/Mg)J'
       VOC's ($/Mg VOC)
         Models 1 and 2
         Model  3
    
       Benzene  ($/Mg  benzene)
         Models 1 and 2
         Model  3
    
       Weighted average ($/Mg benzene)
           480
    
    
            78
             0
    
    
            24
            19
    
             0
             0
             0
    
           121
    
    
            32
            39
    
    
            89
            82
             0.13
    
    
             0.092
             0.11
           685
           631
    
    
           967
           745
    
           940
        All costs and emission reduction estimates are for one
        piece of equipment  in benzene service.
    
        Hydroscience,  Inc.  Emissions Control  Options for the
        Synthetic Organic Chemicals Manufacturing Industry.
        Fugitive Emissions  Report.  For U.S.  EPA.  February 1979.
        Costs were updated  to reflect May 1979 dollars using:
        Economic Indicators, Chemical Engineering.  86(9):7,
        April 23, 1979 and  85(16):7, July 30,  1979.
    
       cBased on 10-year equipment life and 10 percent interest
        (CRF = 0.163).
    
        0.05 x capital cost.
                                    F-14
    

    -------
            Footnotes for Table F-6.   (continued)
            e0.04 x capital  cost.
            f Recovery  credit is  based  on  the  value  of  benzene  ($350/Mg)
            and the benzene emission  reduction.  For  Models 1 and  2
            which do  not  refine light oil  to benzene,  this  is
            equivalent  to using a  value  of $245/Mg for additional
            light oil recovery.
            ^Total annual  cost (before credit)--recovery credit.
    
            VOC emission  reduction is based  on an  uncontrolled emis-
            sion factor of 0.36 kg/day and assumes 100 percent control
            efficiency  for closed-sampling systems.
            Benzene emission reduction and cost-effectiveness estimates
            are presented for each model unit, based  on the percentage
            of benzene  in each process:   1 and 2 = 70 percent benzene;
            3 = 86 percent benzene.
            •^Obtained  by dividing net  annual i zed cost  by total VOC  or
            benzene emission reductions.
            Weighted  average cost effectiveness for existing  model
             units =
    Net annual cost ($/yr) Models 1 and 2 x Fraction of Models 1 and 2 + Net annual
              	cost ($/yr) Model 3 x Fraction of Model 3
    VOC emission# of existing% benzene~# of existing
      reduction
       (Mg/yr)
    x
    Models 1 and 2  in 1 and
           # of existing
                              Models 1 and 2
                  % benzene
    Model 3's "     in 3
         # of existing
                                              Model Unit 3's
                           (39/46) Net annual cost ($/yr) Models 1
                           and 2 + (7/46) Net annual cost ($/yr)
                                          Model 3
                             VOC emission
                              reduction
                               (Mg/yr)
                             x
                                 39(0.70) + 7(0.86)
                                          ~
                            (0.85) Net annual cost
                           Models 1 and 2 + (0.15)
                           Net annual cost Model 3
                           VOC emission
                            reduction     x 0.72
                             (Mg/yr)
                                      F-15
    

    -------
     have a benzene  concentration of 70 percent, and the process streams at
     Model Plant 3 are assumed to have an average concentration of 86 percent
     benzene.
         The origin of the emission estimates  is provided in Chapter 3, and
     control techniques and efficiencies are discussed in Chapter 4.  Total
     costs for the model plants and nationwide  costs are summarized in
     Chapter 8 and are based on the cost analysis presented in Table F-l
     through F-6.
     F.2  COST ESTIMATE FOR AN OPERATING BY-PRODUCT COKE PLANT1 2
         A survey and a field inspection were  conducted at an operating
     by-product coke plant to examine site-specific factors that may affect
     gas blanketing  costs.  The purpose was to  develop a detailed cost
     estimate for retrofitting a coke oven gas  blanketing system, which had
     been applied at other by-product plants, in a plant without a gas
     blanketing system.
         The coke plant that was inspected was constructed between 1952
     and 1953 and is widely spaced compared to  some older by-product plants.
     The effect of widely spaced process units  on costs is twofold, and the
     effects would tend to balance when compact plants are considered.   One
     effect is that  there is more than adequate room for installing the
     required equipment, and the other balancing effect is that piping runs
     tend to be longer and more costly than are those required in more
     compact plants.
         Because the designated sources of benzene emissions are at widely
     spaced locations, a single, unified control system covering all the
     sources would not be cost effective.   Geographically, the sources are
     grouped in five individual locations, and each location has its own
     site-specific problems and requirements.   Each location was studied
     individually, and drawings were prepared for control  systems at each
     site.3
         The most logical routes for new vent piping were within existing
    pipe aisles.   This location provided a cost advantage in installation
    because the new piping could be suspended from existing pipe supports
                                      F-16
    

    -------
    and gas mains.   Another advantage is that the mass of piping, especi-
    ally of larger diameter, protects against damage from moving vehicles
    such as cranes.
         Venting rates are based on test data obtained from similar sources
    at other by-product plants.  A conservative approach taken when pipe
    diameters were sized to produce a preliminary cost estimate ensured a
    substantially adequate system.  The following subsections discuss the
    cost assumptions and describe the proposed control options.
    F.2.1  Cost References and Cost Assumptions
         Piping costs were obtained from Reference 4 (Mechanical and Elec-
    trical Cost Data by M. S. Mossman) for welded piping; flanged piping;
    steam tracing, drains, and vents; insulation; and labor rates for
    various trades.  The new vent piping is assumed to be all welded
    construction except for welded flanges to accommodate valves and
    piping specialties, and flanged piping that is used in the  light-oil
    plant.  In general, the new piping is suspended from existing struc-
    tural supports by use of welded brackets, support rods, and split
    rings.
         Unit prices for  labor and material were  increased approximately
    14 percent to  convert to 1982 dollars.  An additional 15 percent was
    applied to labor costs  to  cover  installation  in an area where opera-
    tions may interfere with work progress.  The  low adder to  labor is
    appropriate where pipe  runs are  readily accessible by mobile crane  and
    adequate working room is available.  In a more crowded by-product
    plant,  labor  interference  may be  greater; however, the increased labor
    cost would be  offset  by shorter  piping runs.
         Flanged  pipe is  used  in  the  light-oil plant because of welding
    restrictions  in a hazardous area.   Sections of pipe are prefabricated
    and  carried  into the  plant for erection.  Installation labor costs
    were increased by 85  percent  to  cover the extra work and precautions
    required  in  a hazardous area.  Additional pipe  supports, bolted to  new
    concrete  foundations, are  included  for blanketing the  light-oil con-
    denser and  light-oil  storage  tank.
                                       F-17
    

    -------
         Steam tracing is 0.5-in.-diameter pipe with screw connections in
    the light-oil plant and welded construction in other areas.   Pipe
    insulation is fiberglass with a stainless steel jacket.
         Reference 5 (National Construction Estimator. 1981) provided unit
    prices of labor and materials for various types of steel construction
    as well as unit prices for bolts and welding.   These unit costs were
    applied to the construction of seals and covers for the tar and primary
    cooler decanters.  Cost data for pressure taps into gas lines were
    supplied by the Mueller Company and include material and labor for the
    stopper fitting, rental and transportation of the tapping machine,
    crane rental, and supervision.
    F.2.2  System Number 1—Flushing-Liquor Decanter
         The flushing-liquor decanters and circulation tank are located at
    the end of the coke battery several hundred feet from the main by-
    product recovery plant.  The emission sources for this location are
    listed below.
             Source
    Flushing-liquor decanter 1
    Flushing-liquor decanter 2
    Tar-collecting tank 1
    Tar-collecting tank 2
    Circulating tank
           Dimensions
    20 ft x 45 ft x 11.8 ft
    20 ft x 45 ft x H.8 ft
    11 ft diameter x 36 ft long
    11 ft diameter x 36 ft long
    11 ft diameter x 36 ft long
    Estimated
       vent
    rate (acfm)
        415
        415
        183
        183
        183
    The three tanks are horizontal and welded with dished heads, while the
    decanters are rectangular with sides and bottoms made of reinforced
    steel.  The decanter top is made of concrete slabs on steel support
    beams and is sealed by tar joints.  Excessive pressure may tend to
    lift the concrete slabs and break the tar joints; therefore, a new
    cover may be required to apply a gas blanket.
         Emission control is provided by a blanket of coke oven gas from a
    connection upstream of the Askania regulator for Battery Number 1.
    The normal gas pressure at this point is 5 mm of water and is limited
    to 15 mm of water by means of a low-pressure gas bleeder.  The existing
    atmospheric vents are 6-in. in diameter and are tied into the main
                                      F-18
    

    -------
    header, which is 8-in.  In diameter (see Table F-7).   For the 8-in.
    line size, the gas pressure in the decanter will not exceed 7 in. of
    water under maximum venting conditions from all tanks.
         The 8-in. main vent line follows and is supported from the exist-
    ing 18-in. flushing-liquor line.  Three-way plug valves are provided
    for isolating each source from the gas blanket, and 2 in. of fiberglass
    insulation is included.  Each decanter will be provided with a seal
    plate near the discharge end of the conveyor (see Table F-8).  The
    plate will be bolted to the supporting steel for the concrete top and
    to the  sidewalls and will extend below the liquid surface to provide a
    gas seal.
    F.2.3   System Number 2—Primary Cooler Decanters and Tar Dehydrators
         Two  decanters and tar dehydrators are located  side by  side  at  the
    primary cooler with the  dimensions given  below:
          Source
     Primary cooler decanter 1
     Primary cooler decanter 2
     Tar dehydrator, west
     Tar dehydrator, east
           Dimensions
    11 ft x 48 ft x 11.8 ft high
    11 ft x 48 ft x 11.8 ft high
    10 ft diameter x 25 ft long
    10 ft diameter x 25 ft long
        Estimated
    vent rate (acfm)
          248
          248
          525
          157
          The proposed control  technique is to blanket the vessel  with its
     own vapors slightly above atmospheric pressure.   The system requires
     6-in. vent piping, steam tracing, and insulation as described in
     Subsection F.2.2 and in Table F-9.   Vent connections are made from the
     tanks to the inlet of the primary cooler where the gas pressure is
     -30 in. of water (-45 in., maximum).  Two pressure control stations,
     one operating and one standby, are provided between the emission
     sources and the coke oven gas line.  The purpose of the control station
     is to maintain an essentially zero (atmospheric) pressure for the gas
     blanket within the tar dehydrators and primary cooler decanters.
     Condensation and fouling are minimized by steam tracing,  insulation,
     steamout and drain connections, Teflon®-lined butterfly control valves,
     and  chemical seals at the pressure tap.  Alarms are provided to indi-
                                       F-19
    

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    cate abnormal pressure conditions.   For additional safety, the concrete
    decanter top is removed and a new welded steel plate is sealed to the
    decanter top (see Table F-10).
    F.2.4  System Number 3—Tar Storage Tanks
         The system proposed fo> controlling emissions from the tar storage
    tanks (see Table F-ll), which are remotely located from the main
    plant, is a wash-oil scrubber.  The two tar storage tanks are 65 ft in
    diameter and 40 ft in height with an estimated vent rate of 310 acfm.
         The vent gases enter the scrubber's base through 6-in. lines and
    flow upward, countercurrent to the wash-oil spray.  Debenzolized wash
    oil is sprayed into the top of a scrubber with dimensions of 1.5 ft in
    diameter and 16 ft in length.  A 1-in. line supplies 4.4 gal/min of
    wash oil from the wash-oil supply line.  The spray chamber is partially
    elevated above one of the tar storage tanks to allow gravity flow
    through a 1.25-in. return line to the base of the light-oil scrubbing
    tower.  All  lines are heat traced and insulated to prevent condensation.
    F.2.5  System Number 4—Ammonia Liquor Tanks
         The plant has five storage tanks for ammonia liquor, three for
    phenolized ammonia liquor (each 30 ft in diameter and 32 ft in height),
    and two for  dephenolized ammonia liquor (38 ft and 34 ft in diameter;
    both 32 ft in height).  No data are available on measured vent rates,
    but the rates are expected to be low because the ammonia liquor con-
    tains mostly water at close to ambient temperatures.  The tanks are
    filled by pumps rated at 100  gal/min; therefore, the maximum emission
    rate is estimated as approximately 15 fts/min for each tank.
         The proposed gas blanketing system is comprised of three-way
    valves and 4-in. vent pipes at each tank with connections to a 6-in.
    pipe to the  gas line at the gas holder.  The gas pressure in the
    holder is normally 15 in. of water and will not exceed 18 in. of water
    without blowing the water seals.  Steam tracing and insulation are
    provided to  avoid condensation or freezing in the vent lines.  The tap
    into the gas line is 8  in. to provide a common connection for the
    light-oil plant's system, which is described  in the following subsec-
    tion.  This  tap is made under pressure, and a new valve-operating
    platform is  provided for access (see Table F-12).
                                      F-23
    

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    F.2.6  Light-oil plant
         Emission sources in the light-oil plant are listed below (see
    Table F-13).
        Sources
    Condenser vent
    Li ght-oi1 storage
    Light-oil receiver
    Wash-oil circulation
    Wash-oil decanter
    Wash-oi1 recovery
    Secondary light-oil 1
    Secondary light-oil 2
        Dimensions
    47 ft diameter x 32 ft high
    10 ft diameter x 30 ft long
    11 ft diameter x 36 ft long
    12 ft x 35 ft x 10 ft high
    10 ft diameter x 30 ft long
    10 ft diameter x 30 ft long
    10 ft diameter x 30 ft long
     Estimated
       vent
    rate (acfm)
           25
            4
            4
            4
          141
          101
            4
            4
         The gas blanketing is provided by clean coke oven gas from the
    gas holder.  Vent pipes, which are 3 in., 4 in., and 6 in. in diameter,
    all connect to a common 6-in. header that ties into the 8-in. pressure
    tap described previously.  In general, the vent piping follows the
    existing steam and wash-oil piping to and from the light-oil plant.
    The vent line from the light-oil condenser runs along the existing
    building structure and requires some new pipe supports.  New pipe
    supports also are required for the vent piping, which runs from the
    light-oil storage tank and receiver back to the 6-in. header.
         All of the vent piping within the confines of the light-oil plant
    will be prefabricated with flanged joints to avoid welding within this
    area.  The steam tracing in this area will have screwed fittings.  All
    of the piping exterior to this area will be provided with welded
    joints.  Insulation is provided in addition to the steam tracing to
    avoid vapor condensation.
         The connection to each source is provided with a flanged three-way
    valve to isolate the source when desired.  This valve is;arranged so
    the tank connects either to the vent system or to the atmosphere
    through a flame arrester.  There are three access openings into the
    wash-oil decanter that require new bolted and gasketed covers.
    F.2.7  Safety and Operational Aspects2
         The proposed systems for controlling benzene emissions are based
    on technology that has been applied successfully at various coke
                                      F-27
    

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    plants.   Two general types of technology are employed.  One is the use
    of coke oven gas as a blanket either from the gas holder o*r from the
    collecting main.  The first has been used at the Sparrows Point Plant
    for Bethlehem Steel, the Cleveland Plant of Republic Steel, and the
    Houston Plant of Armco.  The second has been used at the Houston Plant
    of Armco for tar decanters and flushing-liquor circulation tanks.
    Also at the Houston works is a second type of system that permits
    venting of various tanks, including ammonia liquor storage, tar dewater-
    ing, and tar storage, to the atmosphere through a wash-oil scrubber.
         At the Houston works, a negative-pressure system was used for
    tar-collecting tanks.  In this system, the tanks were connected directly
    to the inlet of the primary cooler without the use of control valves,
    thereby imposing a negative pressure of -25 inches of water on the
    tanks.  The use of negative coke oven gas pressure on tanks is not
    unusual.  In fact, each by-product plant has a primary cooler, which
    is in effect a  large tank, and every primary cooler operates at nega-
    tive pressure.  The concern is not the existence of negative pressure
    in the tank, but rather that the tank be designed for this operating
    condition.
         The proposed systems employ various features to maximize safety
    and to facilitate operations.  These are listed below:
         1.   Three-way Plug Valves.  In all systems that control emissions
              by a  coke oven gas blanket, each of the tanks  under this
              control is connected to a common vent pipe by  a three-way
              plug  valve.  The valve connections are arranged so that in
              one position the tank is connected to the vent main, and  in
              the other position the tank is connected to the atmosphere.
              This  arrangement permits the vent main and/or  the tank(s) to
              be isolated  to perform maintenance operations.  It also
              ensures that the tank is vented at all times.  The plug
              valve, in either position, provides a clear opening for the
              ready passage of vent vapors and avoids pockets where  tar
              and other deposits may accumulate over time and thereby
              interfere with opening and closing of the valve.
         2.   Steam Tracing.  All  vent piping in the various systems  is
              steam traced and insulated to  avoid condensation and accumu-
              lation of tar vapors as well as condensation of water  vapor.
              On the basis of experience with this method of keeping the
              lines warm,  there should be  little or no problem with  accum-
                                       F-29
    

    -------
    4.
          illations  that might  eventually  plug  the  lines.   Nevertheless,
          pressure  and drain connections  are provided  in  the  various
          pipelines for steaming  them  out should the need arise.
    
          Coke Oven Gas Blanketing.  Coke oven gas  blanketing is  used
          for various systems  as  described below.
         a.
          Coke  oven  gas  at  5  mm  of water  normal  (15 mm,  maximum)
          for gas  from the  collecting main.  An  8-in.  vent  pipe
          from  the collecting main to the tanks  ensures  that
          pressure at the emission source will remain  low and
          that  the water seal at the decanter will not be blown.
          If desired, additional  safety could be provided by
          means of a Protectoseal 6-in. pressure vent, piped to
          an elevated location,  complete  with alarm at the  up-
          stream end of  the 8-in. vent line.  This addition would
          cost $4,300.
    
    b.    Coke oven  gas  at  -30 in. normal  (-45 in. maximum) for
          gas from the inlet  of  the primary cooler.  This system
          has two  pressure  control stations, one operating  and
          one standby, between the emission sources and  the gas
          line connection.  The  purpose of the control station is
          to maintain an essentially zero atmospheric  pressure
          condition  within  the emission sources.  The  control
          system has valves that  are completely  Teflon -lined and
          pressure taps  that  have 3-in. diameter chemical seals,
          all to^minimize operational problems due to  fouling.
          In addition, alarms indicate abnormal  pressure conditions.
    
    c.    Coke oven  gas  at  15 in. of water normal (18  in. maximum)
          from the gas holder.  All emission sources in  these
          systems  are capable of  sustaining the  maximum  gas
          pressure.  In  addition, the quality of the coke oven
          gas at the holder is such that  the maintenance require-
          ments should be extremely limited.
    
    Wash-Oil Vent Scrubbers.  System Number 3 is vented to the
    atmosphere through  a scrubber that employs  debenolized wash
    oil as the scrubbing medium.  In System Number 3, oil  is
    used  once through at a flow rate of  4.4 gal/min, which is
    1 percent of  the wash-oil circulating rate  at the coke
    works.
    
         The benzenolized wash oil from  the vent scrubber is
    delivered to  the existing wash-oil stills for processing and
    reuse.  At other coke plants without  such a system,  several
    options would exist for handling the oil  from the wash-oil
    scrubbers.   These options include a  new small  distillation
    and cooling system  in which the benzene vapors would be
    returned to the coke oven gas main,  or the  use of Number 2
                                 F-30
    

    -------
    fuel oil as the absorbing medium, the benzenolized oil being
    used for combustion in the coke plant or in the steel mill.
    
         Wash-oil scrubbers impose essentially no pressure
    restrictions on the vent gases.  Therefore, they are especi-
    ally useful in coke plants that have benzene sources in the
    form of large, old, rivetted tanks.  In such plants, there
    may be concern that blanketing with coke oven gas may be
    hazardous due to leaks and to structural conditions within
    the sources.  Use of wash-oil scrubbers for these sources
    avoids the hazard.
    
    Alternative Control Methods.  As an alternative to the vent
    scrubber for the coke oven gas blanket, there are conditions
    under which it may be desirable to use natural gas or nitrogen
    for blanketing.  These latter systems have the disadvantage
    of requiring a substantially higher degree of control equip-
    ment with accompanying higher costs for installation and for
    maintenance.  The nitrogen system, in particular, imposes a
    further cost because of the gas consumption.  Nevertheless,
    if a plant has pure benzene product storage and handling, it
    may be necessary to use the systems for those sources to
    avoid contamination.
    
    Light-Oil Plant.  In providing the new vent system, flame
    arresters were added at five locations that had been operat-
    ing without them.  These are the wash-oil circulating tank,
    the wash-oil decanter tank, the wash-oil receiver, and the
    Number 1 and Number 2 secondary light-oil storage tanks.
    The flame arresters are used only when the three-way valve
    is positioned to vent the tanks to atmosphere.  Although
    these tanks have been operating safely without the flame
    arresters,  it was deemed desirable for the purpose of the
    study to add them at a cost of $9,500.
    
         An additional cost of $11,300 is imposed by the arrange-
    ment of the 6-in. vent header at its north end where it runs
    parallel to and duplicates the vent header from the ammonia
    liquor tanks.  Elimination of this duplication by means of a
    common header for both sources would save this expenditure.
    However, there is a remote possibility that vapors from the
    ammonia liquor tanks might back upstream into the light-oil
    plant, thereby contaminating the light-oil products.  The
    provision of parallel headers is a conservative design
    approach.
    
         In the light-oil plant, the use of gas blanketing will
    improve the operation safety.  At present, when the tanks
    breathe, air may enter them through the vent pipe and create
    an explosive mixture within.  This possibility is,recognized
    particularly at the light-oil condenser vent where a con-
                            F-31
    

    -------
              tinuous steam purge is in operation.   Under the new system,
              there is no possibility of creating this explosive mixture;
              in addition, the use and cost of the steam purge may be
              eliminated.
    F.3  ESTIMATE OF QUANTITY AND VALUE OF ORGANICS OTHER THAN LIGHT OIL
         IN BY-PRODUCT PLANT EMISSIONS
         The quantity of other organics in by-product plant emissions was
    estimated from data provided by an environmental assessment of a
    by-product recovery plant.6  These data are for a specific plant and
    limited number of sources and require numerous assumptions to extrap-
    olate to all by-product sources.  The available data are summarized in
    Table F-14.  Emissions of other organics are estimated by multiplying
    the benzene emissions (Chapter 7) by the ratio of other organics
    concentration to the benzene concentration.  Emissions of volatile
    organic compounds (VOC) are also estimated and include the quantity of
    total chromatographable organics (TCO, boiling point of 200 to 300° C)
    and the quantity of light oil (benzene, toluene, and xylene).  VOC
    emissions are estimated by adding light oil emissions (benzene emis-
    sions divided by 0.7) and TCO emissions (benzene emissions multiplied
    by the ratio of TCO concentration to benzene concentration).  Emissions
    of Ci-C7 hydrocarbons are not included as VOC because the average
    molecular weight (16 to 22) indicates that this fraction is mostly
    methane and ethane.
         Major assumptions for this analysis are listed below.
         1.   The environmental assessment data are .representative of
              concentrations in by-product plant emissions.
         2.   The Ci-C7 concentration in light oil storage tank emissions
              is also applicable to emissions from the light-oil plant and
              light oil sump.
         3.   The Ci-Cy concentration in emissions from the primary cooler
              condensate is also applicable to emissions from the flushing
              liquor circulation tank and excess ammonia liquor storage.
         4.   The concentration of organics in emissions from tar storage
              is also applicable to emissions from tar dewatering.
         5.   The concentration of organics in emissions from the tar
              decanter is also applicable to emissions from the tar sump.
                                      F-32
    

    -------
      TABLE F-14.   CONCENTRATION OF ORGANICS IN BY-PRODUCT PLANT EMISSIONS
    Concentration (mg/sm3)
    Source
    Light-oil storage tank
    Tar decanter
    Primary cooler condensate
    Naphthalene separation
    Coo ling 'tower
    Tar storage tank
    Benzene
    1,040
    7,283
    5,230
    4,700
    15.8
    66
    Ci-C7a
    225
    4,550
    1,183
    2,051
    2
    3.7
    Toluene,
    xylene and
    ethyl benzene
    37
    900
    900
    600
    —
    40
    TCOb
    —
    5,110
    —
    660
    226
    1,450
    Cj-Cy is mostly methane and ethane with an average molecular weight of 16
    to 22.
    
    TCO = total chromatographable organics and represents those organics with
    boiling points between 200° and 300° C.
                                   F-33
    

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              The recovery credit for organics other than light oil  is
              $150/Mg (1982).   This estimate should be conservative  based
              on the comparison given below.
                           Product
    
                Light oil  or benzene as fuel
                Crude tar
                Coal  tar pitch
                Naphthalene
                Light oil
                Benzene
       Value ($/Mg)
    150
    125
    250
    264
    330
    470
    (1982)
    (1979)
    (1982)
    (1979)
    (1982)
    (1982)
         7.    The control  efficiency of a gas blanket is 98 percent and
              the efficiency of a wash-oil scrubber is 90 percent.
    
         8.    The installation of a tar-bottom final cooler for a direct-
              water final  cooler will reduce other organics by the same
              proportion as the estimated benzene reduction.
    
         9.    The installation of a wash-oil final cooler will reduce
              other organics by the same proportion as the estimated
              benzene reduction.
    
         The results of this cost analysis are given in Tables F-15 through
    
    F-17 for the three model plants.  The total credit shown in the tables
    
    includes credits for light oil, C-^-Cf hydrocarbons, and TCO.   The net
    annualized cost was determined by subtracting the total credit from
    the midrange annualized cost (before credit) given in Chapter 8 for
    each control option.  Parentheses are used to denote savings or net
    credit for cases where the value of the recovered material is greater
    
    than the cost of the control option.
    
    F.4  REFERENCES
    
    1.   Trip Report.  Fairless Works of U.S. Steel Corporation, Fairless
         Hills, Pennsylvania.  Research Triangle Institute.  March 15,
         1982.
    
    2.   R.  Jablin and Associates, Engineering Consultants.  "Fairless
         Works Coke Plant:  Control of Benzene Emissions" and "Discussion
         of Cost Assumptions and System Safety."  April 2, 1982.   28 p.
    
    3.   Reference 2, Drawing Number RJA-BC001 "General Layout" and RJA-
         BC002 "Piping Isometrics."
    
    4.   Mossman, M.S.  Mechanical and Electrical Cost Data.  Robert Snow
         Means, Inc.  1981.
                                      F-37
    

    -------
    5.   National Construction Estimator.  Craftsman Book  Company.   1982.
    
    6.   VanOsdell, D. W., et al.  Environmental Assessment  of  Coke  By-
         product Recovery Plants.  U.S. Environmental  Protection  Agency.
         Washington, D.C.  Publication No.  EPA-600/2-79-016.   January
         1979.  p. 84 to 101.
                                      F-38
    

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                                         TECHNICAL REPORT £>ATA
                                 (Please read Instructions on the reverse before completing)
       EPA-450/3-83-016a
                                                                  3. RECIPIENT'S ACCESSION NO.
      Benzene  Emissions from Coke  By-Product Recovery
      Plants - Background Information for Proposed
      Standards
                                                                5. REPORT DATE
    
                                                                   May 1984
                                                                6. PERFORMING ORGANIZATION CODE
     7. AUTHOR(S)
                                                                 8. PERFORMING ORGANIZATION REPORT NO
                                  \ID 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.
                        AME AND ADDRESS
      DAA for  Air Quality Planning  and Standards
      Office of Air 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
      National  emission standards to  control  emissions of  benzene from new and  existing
      coke by-product recovery plants are being proposed under Section 112 of the  Clean
      Air Act.   This document contains information on the  background and authority,
      regulatory alternatives considered, and environmental  and economic impacts of  the
      regulatory alternatives.
     7.
                                     KEY WORDS AND DOCUMENT ANALYSIS
                      DESCRIPTORS
                                                   b.lDENTIFIERS/OPEN ENDED TERMS
                                                             lution Control
                                                                             c.  COSATI Field/Group
    Air pollution
    Pollution  control
    National emission  standards
    Industrial  processes
    Coke by-product recovery
    Hazardous  air pollutants
    Benzene
    Steel industry	
    Air Pol
    Benzene
    Stationary Sources
    T3B~
      Unlimited
                                                  19. SECURITY CLASS (ThisReport)
                                                     Unclassified
                              21. NO. OF PAGES
                                   466
                                                   2O. SECURITY CLASS (Tin'spage)
    
                                                       Unclassified
                                                                             22. PRICE
    EPA Form 2220-1 (R«v. 4-77)    PREVIOUS EDITION is OBSOLETE
    

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