EPA-450/4-84-007i
                                    September 1985
Locating And Estimating Air Emissions
       From Sources Of Phosgene
           U.S. ENVIRONMENTAL PROTECTION AGENCY
                Office Of Air And Radiation
            Office Of Air Quality Planning And Standards '
            Research Triangle Park, North Carolina 27711 ;

                                   r
                   September 1985

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This report has been reviewed by the Office Of Air Quality Planning And Standards, U.S.. Environmental Protection
Agency, and has been approved for publication as received from the contractor. Approval does not signify that the
contents necessarily reflect the views and policies of the Agency, neither does mention of trade names or commercial
products constitute endorsement or recommendation for use.
                                          EPA-450/4-84-007!

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                                   CONTENTS
Figures                                                                  iv
Tables                                                                    v

1.   Purpose of Document                                                  1

2.   Overview of Document Contents                                        3

3.   Background  .                                       ;                  5

         • Properties of phosgene                                          5
          Overview of phosgene production and use                         7
          Miscellaneous phosgene sources                    .              7
          References For Section 3                                       11

4.   Phosgene Emission Sources                          >                 12
                                                        I
          Phosgene production            .                                12
          Isocyanate production                                          20
          Polycarbonate production                                       25
          Herbicides.and pesticides production                           29
        .  References For Section 4                                       35
                                                        :i
5.   Source Test Procedures                             .                 37
          References for Section 5                                       39

Appendix                                                i
     Phosgene Emissions Data    "   —            —     i                 A-l
          References For Appendix                       i                 A-14

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                                    FIGURES            ;

Number                                                 i                 Page
  1       Chemical Use Tree for Phosgene                                  9
  2       Basic Operations in a Phosgene Production Process              14
  3a      Flow Diagram of a Phosgene Emission Control System for
          Merchant Phosgene Operations                                   16
  3b      Flow Diagram of a Phosgene Emission Control System for
          Phosgene Production and Onsite Consumption                     17
  4       Basic Operations Used in the Production of Diiamino Toluenes    21
  5       Basic Operations Used in the Production of Toluene
          Diisocyanate                                 ;                  22
  6       Flow Diagram of a Phosgene Emission Control System             24
  7       Basic Operations Used in the Production of Polycarbonates      27
  8       Control  System for Polycarbonate Production                    28
  9       Basic Operations Used in the Production of Phenyl Ureas        31
 10       Emission Control System for Phenyl Urea Production             32
 11       Sampling Train for the Measurement of Phosgene                 38
                                     IV

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                                     TABLES
 Number                                                  ,
   1        Some  Physical  Properties  of Phosgene                             6
   2        Companies  That Produce  Phosgene                             .     8
   3        Estimated  Phosgene  Emissions  From  a Hypothetical  Phosgene
           Plant                                                          20
   4        Estimated  Phosgene  Emissions  From  a Hypothetical  Toluene
           Diisocyanate Plant  Using  Phosgene  Produced  on Site              25
   5        Estimated  Phosgene  Emissions  From  a Hypothetical  Polycar-
           bonate Plant Using  Phosgene  Produced on  Site                    29
   6        Estimated  Phosgene  Emissions  From  a Hypothetical  Herbicide
           and Pesticide  Plant Using  Phosgene Produced on Site             34
A-l  .      Summary of Estimated Phosgene Emissions  from  Hypothetical
           Phosgene and Phosgene Derivative Production Facilities        A-3
A-2        Estimated Fugitive  Phosgene Emissions From  a  Hypothetical
           Phosgene Plant  Producing 200 Million Pounds of Phosgene
           Per Year                                                      A_8
A-3        Estimated Fugitive  Phosgene Emissions From  a  Hypothetical
           Toluene Diisocyanate Production Facility                      A-9
A-4        Estimated Fugitive  Phosgene Emissions From  a  Hypothetical
           Polycarbonate Production Facility                             A-10
A-5        Estimated Fugitive  Phosgene Emissions From  a  Hypothetical
           Herbicide and Pesticide Production Facility                   A-ll
A-6        Process Fugitive Emission Factors for Plants                  A-12

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                                    SECTION  1
                               PURPOSE  OF  DOCUMENT      '.

     The  U.S.  Environmental  Protection Agency  (EPA),  States,  and  local  air
 pollution control agencies are becoming increasingly  aware  of the presence  of
 substances  in  the ambient air  that  may be toxic  at  certain  concentrations.
 This awareness,  in turn, has led to attempts to  identify  source/receptor
 relationships  for these substances  and to develop control programs  to regu-
 late emissions.  Unfortunately, very little information is  available on the
 ambient air concentrations of  these substances or on  the  sources  that may be
 discharging them to the atmosphere.
     To assist groups interested in inventorying air  emissions of various po-
 tentially toxic substances, EPA is  preparing a series of  documents  that com-
 piles available information on-the  sources and emissions  of these  substances.
 This document specifically deals with  phosgene.  Its  intended audience in-
 eludes Federal, State, and local air pollution personnel  and others who are
 interested in locating potential emitters of phosgene and making  gross esti-
mates of  air emissions therefrom.
     Because of the limited amounts of data available on  phosgene emissions,
 and because the configuration of many sources will  not be the same as those
 described herein, this document is  best used as a primer to inform air pol-
 lution personnel about 1)  the types of sources that may emit phosgene,
 2) process variations and release points that may be expected within these
 sources, and 3) available emissions information indicating the potential for
 phosgene to be released into the air from each operation.
     The reader is strongly cautioned against using the emissions  information
contained in this document in any attempt to develop an'exact assessment of
emissions from any particular facility.  Because of insufficient data, no
estimate can be made of the error that could result when these factors are
used to calculate emissions from any given facility.  It Is  possible,  in some

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extreme cases, that orders-of-magnitude differences could result between
actual and calculated emissions, depending on differences in source config-
urations, control equipment, and operating practices.  Thus, in situations
where an accurate assessment of phosgene emissions is necessary, source-
specific information should be obtained to confirm the existence of particu-
lar emitting operations, the types and effectiveness of control measures, and
the impact of operating practices.  A source test and/or material balance
should be considered as the best means to determine air emissions directly
from an operation.

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                                    SECTION 2
                          OVERVIEW OF DOCUMENT CONTENTS
                                                        ' |
      As  noted  in  Section  1,  the  purpose  of this  document  1s  to  assist  Federal,
 State, and  local  air  pollution agencies  and others who  are interested  in  loca-
 ting  potential air  emitters  of phosgene  and making gross  estimates  of  air
 emissions therefrom.   Because of the limited  background data  available, the
 information summarized in this document  does  not and  should  not be  assumed to
 represent the  source  configuration  or emissions  associated with any particular
 facility.
      This section provides an overview of  the  contents  of this  document.  It
 briefly  outlines  the  nature, extent,  and format  of the  material presented in
 the remaining  sections  of this report.
      Section 3 of this  document  provides.a  summary of the physical.and chemi-
 cal characteristics of  phosgene  and  an overview  of its  production and uses.  A
 chemical use tree summarizes the quantities of phosgene consumed in various
 end use  categories  in the United States.  This background section presents a
 general  perspective on  the nature of  the substance and where it is manufac-
 tured and consumed.
      Section 4 of this  document focuses on major industrial  source categories
 that may discharge phosgene air emissions.  The production of phosgene is
 discussed, along with the use of phosgene as an intermediate in the produc-
 tion of  isocyanates, polycarbonates, carbamates, chloroformates, and other
 esters of carbonic acid.  Example process descriptions and flow diagrams are
 provided and potential emission points are identified for each of the  major
 industrial source categories discussed.   Where the limited data allow,  emis-
 sion estimates are presented that show the potential  for phosgene emissions
before and after industry-applied controls.  Individual  companies  reported to
be involved  with either the production or use  of phosgene  are named.
     Section 5 summarizes  available procedures for source  sampling and  analy-
sis of phosgene.   Details  are not presented, and the  EPA neither gives  nor

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implies any endorsement of these sampling and analysis procedures.  Because
the EPA has not yet made a general evaluation of these methods, this document
merely provides an overview of applicable source sampling procedures and ref-
erences for the use of those interested in conducting source tests.
     Companies that produce or use phosgene, state air control agencies, and
other authorities were contacted in an effort to locate data representing
measured phosgene emissions.  Only one known direct measurement has been made
of phosgene emissions from industries that produce or use phosgene.  Aside
from this single measurement, the only emission data found were company
engineering estimates.  These estimated emission levels are included in this
report even though the companies provided no bases for them.
     Other information was used to obtain phosgene emission estimates.  For
example, health effects and air monitoring programs are discussed,  but only
to the extent  that they were used to estimate phosgene emissions.   References
are cited and  the methodology is discussed in sufficient detail to  allow the
reader to assess the  probable limitations of these estimates.  Additional
background information is. included in the appendix to assist  the  reader in
understanding  the basis for all -of the estimates presented  in the report."
    • Comments  on the  contents or usefulness of  this document  are  welcomed, as
is any information on process descriptions, operating practices,  control mea-
sures, and emission  information that would enable  EPA to  improve  its contents
All comments  should  be sent to:
                Chief, Source Analysis Section  (MD-14)
                Air Management Technology Branch
                U.S.  Environmental  Protection Agency
                Research Triangle  Park,  North Carolina   27711

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                                   SECTION 3
                                  BACKGROUND
3.1  PROPERTIES OF PHOSGENE
     Phosgene is a highly toxic, colorless gas that condenses at 0°C to a
fuming liquid.  Impurities can discolor liquid phosgene ;and cause -it to turn
a pale yellow to green color.   The human nose can detect its characteristic
odor only briefly at the time of initial exposure.  At ei concentration of
about 0.5 ppm in the air, this odor has been described as similar to that of
new-mown hay or cut green corn.  At higher concentrations, the odor may be
strong, stifling, and unpleasant.  A common decomposition product of chlo-
rinated compounds, phosgene is noncombustible.  Its molecular formula is
COC12, and it has the following planar structure.       i
                                   Cl     Cl
                                                        I

The physical properties of phosgene (also known as carbcmyl  chloride, carbon
oxychloride, carbonic acid dichloride, chloroformyl chloride, and combat
   O
gas ) are presented in Table 1.
     Phosgene is soluble in aromatic and aliphatic hydrocarbons, chlorinated
hydrocarbons, carbon tetrachloride, organic acids, and esters, and it is only
slightly soluble in water.   It is removed easily from solvents by heating or
air blowing.  Because the density of phosgene is more than three times that
of air, concentrated emission plumes tend to settle to the ground and collect
in low areas.                                           ,
     Phosgene decomposes to hydrogen chloride and carbon dioxide if contami-
nated with water.  Hence, wet phosgene is very corrosive and poses an addi-
tional hazard from pressure buildup in closed containers.

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                TABLE 1.   SOME PHYSICAL PROPERTIES OF PHOSGENE
                                                              1
              Properties and characteristics
 Value
     Molecular weight
     Melting point, °C
     Boiling point (at 101.3 kPa = 1 a tin),  °C
     Density at 20°C, g/cra3
     Vapor pressure at 20°C, kPa
     Vapor density (air - 1.0)
     Critical temperature, °C
     Density at critical point, g/cm3
     Critical pressure, MPa
     Latent heat of vaporization (at 7.5°C),
     Molar heat capacity of liquid (at 7.5°C), J/IC
     Molar heat of formation, kJ
      from elements
      from CO and Cl,
  98.92
•127.84
   7,
   1.
48
387
 161.68
   3.4
 182.0
   0.52
   5.68
 243
 100.8
 218
 108
     aTo convert kPa to psi,.multiply by 0.145.
     bTo convert MPa to psi, multiply by 145.
     cTo convert J to cal, divide by 4.184.
     •Phosgene reacts with many inorganic and organic reagents.   The reaction
of oxides and sulfides of metals with phosgene at elevated temperatures
yields very pure chlorides.  Phosphates and silicates of metals react with
phosgene at'elevated temperatures and yield.metal chloride, phosphorus oxy-
chloride, or silicon dioxide.  Anhydrous aluminum chloride forms a variety of
complexes with phosgene:  Al2Clg-5COCl2 at low temperatures, Al2Clg-3COCl2 at
30°C, and AUClg-COClg at above 55°C.  Ammonia reacts vigorously with phos-
gene in solution; the products are urea, biuret, ammelide (a polymer of
urea), cyanuric acid, and, sometimes, cyamelide (a polymer of cyanic acid).
     Phosgene also reacts with a multitude of nitrogen, oxygen, sulfur, and
carbon compounds.1  Reaction with primary alky! and aryl amines yields carba-
moyl chlorides, which can be dehydrohalogenated readily to isocyanate (an in-
termediate  in the manufacture of polyurethane resins).  Secondary amines also
form carbamyl chlorides when reacted with phosgene.  The reaction of phosgene
with amino  acids has been used to isolate and purify chloroformate deriva-
tives.  Hydrazine reacts with phosgene to yield carbohydrazine.  The

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reaction of phosgene with alcohols, which yields esters, is commercially
important because it serves as a basis of widely used polymer systems (poly-
carbonates).

3.2  OVERVIEW OF PHOSGENE PRODUCTION AND USE           {
                                                       'i
     Phosgene is used as a chemical intermediate (i.e.,;feedstock) in the
production of various commercial products.  Most commercially produced phos-
gene is used captive!y at the production sites in the manufacture of other
chemicals.  Less than 2 percent of the phosgene produced reaches the market-
place.   Phosgene is currently produced in the United States by 14 companies
at 17 manufacturing facilities (see Table 2).  As of January 1983 the annual
estimated production capacity was about one million tons.4
     The chemical use tree in Figure 1 shows the current uses of phosgene.
The manufacture of isocyanates consumes about 85 percent of the world's
                    35
phosgene production. »   The primary use of phosgene is in the production of
                           O
toluene diisocyanate (TDI),  a precursor of the polyurethane resins used to
make foams, elastomers, and coatings.  A rapidly growing use of phosgene is
in the manufacture of po'lymethylene polyphenylisocyanate (PMPPI), which is
used in. the production of rigid polyurethane foams.   The polycarbonate
resins used in appliance and electrical tool housings, electronic parts, and
break-resistant glazing are also phosgene-based.  About 6 percent of the
phosgene production is consumed in the polycarbonate industry.5  The remain-
ing 7 to 9 percent is used in the manufacture of herbicides, pesticides,
dyes, Pharmaceuticals, and other specialty chemicals.  The latter include
acyl  chlorides, chloroformate esters (intermediates in the production of
ore-flotation agents and perfumes), diethyl  carbonate, and dimethyl  carbamyl
chloride.                                              !

3.3  MISCELLANEOUS PHOSGENE SOURCES
3.3.1  Atmospheric Photoxidation of Chlorinated Hydrocarbons
     Under laboratory conditions, phosgene has been shown to form when chlo-
roform, methylene chloride, perch!oroethylene, and trichloroethylene are
irradiated with ultraviolet light.   Ambient phosgene measured in urban and
nonurban air samples in California  appears to confirm the possibility of
photochemical  phosgene formation in the troposphere.  7

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                  TABLE 2.  COMPANIES THAT PRODUCE PHOSGENE"
Company
                                        Location
                                                 End Product
BASF Wyandotte Corp.
Dow Chemical Co.
E. I. duPont de Nemours & Co.,
 Inc.
Essex Chemical Co.
General Electric Co.
ICI Americas
Laurel Industries

Mobay Chemical Co.

01 in Corp.

PPG  Industries  .
Stauffer Chemical Co.
       . * «
Upjohn Co.
Union Carbide Corp.
Van  De Mark Chemical  Co.,  Inc.
                    Geismar, La.
                    Freeport, Tex.

                    Deepwater Point, N.J.
                    Baltimore, Md.
                    Mount Vernon, Ind.
                    Geismar, La.
                    La Porte, Tex.

                    Cedar Bayou, Tex.
                    New Martinsville, W. Va,
                    Lake Charles, La.
                    Moundsville, W. Va.
                    Barberton,  Ohio
                    Cold Creek, Ala.
                    St. Gabriel, La.
                    La Porte, Tex.
                    Institute,  W. Va
                    Lockport, N.Yo
Isocyanates
Isocyanates
Isocyanates,
carbamates
Pesticides
Polycarbonate
Isocyanates
Merchant phosgene,
chloroformates
Isocyanates
Isocyanates
Isocyanates
Isocyanates
Pesticides
Pesticides
Pesticides
Isocyanates
Isocyanates
Merchant  phosgene
 Note:   This  listing is  subject to  change  as market  conditions  change,  facility
        ownership changes,  plants are  closed down, etc.  The  reader  should
        verify the existence of particular facilities  by consulting  current
        listings  and/or  the plants  themselves.   The  level  of  phosgene emissions
        from  any  given facility is  a function  of variables such as capacity,
        throughput, and  control measures.   It  should be determined through
        direct contacts  with plant  personnel.

      It is difficult, however, to  assess  the  amount of phosgene formed in  the
 atmosphere.   Although phosgene is  evidently one of  the photolysis products  of
 a number of high-volume chlorinated hydrocarbon solvents, the  role  and sig-
 nificance of.each solvent, the half-life  of phosgene  in  the  air, and  the
 atmospheric fate of phosgene are not well understood. The quantities  of
 phosgene produced by photolysis, however, may be much higher than those
 emitted by the chemical industry.

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3.3.2  Thermal and Ultraviolet Decomposition of Chlorinated Hydrocarbons
     Phosgene can be produced from the heating and resulting decomposition of
many chlorinated hydrocarbons, including methylene chloride, monochloro-
benzene, and dichlorobenzene (used as solvents in polymerization reactions
involving phosgene),.carbon tetrachloride, chloroform, ethyl chloride, poly-
vinyl chloride, and various fluorocarbons (Freons). '   When heated, chlori-
nated hydrocarbon vapors react with oxygen or water to form chlorine, hydro-
gen chloride, phosgene, and other toxic substances; therefore, incineration
used for the control of volatile organic compound emissions can become an
inadvertent source of phosgene emissions.  A properly operated caustic
scrubber can reduce  phosgene emissions  in exhaust gases from the incineration
of chlorocarbons.
     The potential for phosgene generation by chlorocarbon  decomposition
exists  at  chlorocarbon producing facilities, metallurgical  operations,  dry-
cleaning and  degreasing facilities,  certain  types of  industrial fires,  and
wherever solvents  contact  heat or ultraviolet  light.
                                        10

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                          REFERENCES FOR SECTION 3


1.  Kirk-Othmer.  Encyclopedia of Chemical  Technology.  3rd Ed., Volume 17.
    Wiley Interscience Publication, New York.  1979.  pp. 416-425.

2.  U.S. Department of Health, Education, and Welfare.  Occupational Diseas-
    es - A Guide To Their Recognitibn.  June 1977.      i

3.  U.S. Environmental Protection Agency.  Office of Pesticides and Toxic
    Substances.  Phosgene.  Chemical Hazard Information Profile.  June 1977,
    pp. 226-236.                                        :

4.  SRI International.  1983 Directory of Chemical Producers, USA.  1983.

5.  Faith, Keyes, and Clark's Industrial Chemicals.  Phosgene.  4th Ed.
    John Wiley & Sons.  November 1975.  pp. 624-627.  .

6.  Smith, A. J.  Measurements of Some Potentially Hazardous Organic Chemi-
    cals in Urban Environments.  Atmospheric Environment, 15:601-612, 1981.
    Pergamon Press, Ltd., Great Britian.

7.  Singh, H. B.  Phosgene in the Ambient Air.  Nature,  264:428-429,
    December 2, 1976.

8.  Bjerre, A.  Mathematical Modelling in the Hazard Assessment of Sub-
    stances Forming Toxic Decomposition Products.  The Example of Carbon
    Tetrachloride.  Annals of Occupational  Hygiene, 24(2):175-183, 1981.
    Pergamon Press, Ltd., Great Britain.
                                     11

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                                    SECTION  4
                            PHOSGENE EMISSION SOURCES
                                                        i
      This  section  describes  industrial processes that are sources of phosgene
 emissions,  including  direct  phosgene production and the; use of phosgene as an
 intermediate  in the production of  isocyanates, polycarbonates, carbamates,
 thiocarbamates, and phenyl ureas.   Included are process descriptions and
 emission estimates for hypothetical  facilities involved in the making or .use
 of phosgene.  Because the production of chloroformates and chlorocarbonates
 represents  a  minor end use of phosgene, this is not described.  The processes
 and the phosgene emissions and controls associated with the production of
 these'chemicals, however, are similar, to those described for polycarbonate
 production  (Section 4.3).
     Most phosgene is produced for onsite consumption, with merchant phosgene
 accounting  for less than 2 percent of total production.1  Hence, phosgene
 production  operations will generally be found at facilities engaged in the
 manufacture of isocyanates, polycarbonates, carbonates, etc.   The production
 of phosgene is discussed in Section 4.1, and the use of,phosgene as a chemi-
 cal intermedate, in the following sections.  For economy, .the discussion of
 phosgene production is not repeated in each of the sections in which its
 intermediate uses are discussed.   Instead, the reader should  refer back to
 Section 4.1.

4.1  PHOSGENE PRODUCTION                               <
4.1.1  Process Description
     Phosgene is produced by the  reaction  of carbon monoxide  and  chlorine
over a highly absorptive activated charcoal  catalyst at 200°C  and 14 to 28
kPa (2 to 4 psig):                                      '
                              CO  + C12 + COC12                         (1)
                                      12

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The reaction is rapid and exothermic.  Because phosgene decomposes at temper-
atures above 300°C, a water-cooled reactor is used to remove the excess heat.
Figure 2 presents a flow diagram of the production of phosgene from carbon
monoxide and chlorine.
     Phosgene production is continuous and highly automated and proceeds as
follows:
     0 •   Preparation and purification of carbon monoxide
     0    Preparation and purification of chlorine
     0    Metering and mixing of reactants
     0    Purification and condensation of phosgene
     0    Control of phosgene emissions to assure worker and environmen-
          tal safety
     Carbon monoxide may be manufactured either by the  reduction  of  carbon
dioxide  over  coal or carbon .or  by  the  controlled oxidation  of  hydrocarbon
fuels.   Chlorine  is usually purchased  from manufacturers who use  the electro-
lysis  of sodium-chloride brines (caustic chlorine process).  These reactants'
must be  pure*   Objectionable  impurities  include water  (which can  produce  hy-
drogen chloride,  hydrocarbons,  and hydrogen  that may trigger a reaction
between  chlorine  and  steel  and  destroy the equipment),  sulfides  (which can
produce  undesirable  sulfur chlorides), and other  impurities (which could  de-
activate the  catalyst).
      As  shown in  Figure  2, carbon  monoxide  (Stream  1)  and  chlorine  (Stream  2)
 are mixed either  in  equimolar proportions'or with a  small  excess  of  carbon
monoxide to ensure complete conversion of the chlorine. The  product gases
 (Stream 3)  are condensed,  the liquid phosgene (Stream  4)  is sent to  storage,
 and the remaining gases  (Stream 5) are scrubbed with a hydrocarbon  solvent  to
 remove residual phosgene.   Uncondensed phosgene and the solvent that is used
 in the scrubber may be used for subsequent processing  (e.g.,  in the  produc-
 tion of isocyanate).
      The liquid phosgene is stored in pressurized steel tanks.  A typical
 precautionary measure is to store the material in two tanks, neither of which
 is filled to more than half of its capacity.2  This allows the transfer of
 the phosgene to either tank in case a leak develops in one of the tanks or
 its piping system.
                                       13

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                                        14

-------
4.1.2  Emissions and Controls
     Phosgene emissions fall into three categories—process emissions (includ-
ing storage tank vents which are exhausted to the control system), fugitive
emissions, and emissions that occur during process upsets.  Each type is dis-
cussed, estimates are presented, and controls are explained.  The development
of emission estimates "is discussed further in the appendix.
Process Emissions--
     All process emissions from phosgene production and utilization are typ-
ically routed to a caustic scrubber.  The caustic scrubber is the control of
choice because phosgene is rapidly and completely destroyed fay aqueous sodium
hydroxide, as shown in the.following reaction:
                    COC12 + 4NaOH •»• 2NaCl + Na2C03 + 2H20             (2)
     The sodium hydroxide concentration should be maintained at between 3 and
8 weight percent, and the sodium chloride and sodium carbonate must not pre-
cipitate and clog the reactor.  It should be noted that the solubility of
                                                                        2
these components is appreciably lower in caustic solution than.in water.
These requirements are met by-continually replacing the solution in the
scrubber with fresh caustic solution.  Data generated by the U.S. Army indicate
that a two-stage scrubber can reduce phosgene emissions to below 0.5 ppm by
       •}
volume.   This study demonstrated that phosgene control is severely reduced
if 1) the phosgene flow to the scrubber exceeds the design capacity of the
scrubber, or 2) the caustic concentration in the scrubber is not  maintained
between 3 and 8 weight percent.  The design of the scrubber therefore must be
such that it can accommodate any phosgene surge.  It is estimated that a
phosgene plant producing 200 million pounds per year would emit 300 pounds
per year after scrubbing. ~
     Figures 3a and 3b present flow diagrams for phosgene emission control
systems.  Figure 3a shows a possible control system for a plant that produces
phosgene for sale without any subsequent onsite processing.  Control can be
achieved with a single caustic scrubber.  Figure 3b shows an emission control
system for a plant that produces phosgene and then processes it on site to
produce other products.  These subsequent operations generate additional
emissions that must be controlled.
                                       15

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                                       PLANT STACK
                                          EXHAUST
                  COC12 FROM
                  PURGE  VALVES
                 (See Figure 2)
CAUSTIC
SCRUBBER
                                        t
                                    CAUSTIC   SPENT
                                             CAUSTIC:
Figure 3a.  Flow diagram of a phosgene emission control system for
                   merchant" phosgene operations.
                                16

-------
      CD
   
-------
      In all commercial phosgene processes, the chlorine atoms react with
active hydrogen atoms to produce hydrogen chloride  (HC1).  Hydrogen chloride
is an acid gas, and like phosgene, it can be controlled with a caustic
scrubber; however, it is usually desirable for a water scrubber to precede the
caustic scrubber.  This not only permits HC1 to be  recovered as a byproduct,
but.also reduces the loadings to the caustic scrubber.  The production of
toluene diisocyanate includes a nitration step that generates acidic nitrogen
and sulfur oxide emissions, which would be routed to a caustic scrubber.
These reactions take place in an organic solvent medium, and the solvent is a
source of volatile organic compound (VOC) emissions.  Solvents include
chlorinated compounds such as methylene chloride, monochlorobenzene, and
ortho-dichlorobenzene, as well as pyridine, xylene, methanol, and aliphatic
hydrocarbons.  Whereas VOC can be controlled by incineration, the incineration
of chlorinated VOC can produce hydrogen chloride, chlorine, and phosgene emis-
sions.  Therefore, a second caustic scrubber is required in series with the
incinerator.
Fugitive Emissions—                                  \
     Pumps and valves are the major sources- of fugitive phosgene emissions  at
facilities where phosgene is produced or used.   No compressors are used on
phosgene process flows,  and emissions from flanges andidrains are considered
negligible.   Because phosgene is known to be very toxic,  industry typically
takes measures to minimize  fugitive emissions.   These measures include:4
     1.    Welding pipe joints and  monitoring of the quality of all  welds.
     2.    Enclosing the  reactor and condenser in  a negative-pressure build-
          ing, and venting  the exhaust to the caustic scrubber.
     3.    Employing special  construction materials and techniques  for all
          piping and  valves  handling  hazardous  or corrosive substances.
          Installing  plugs  or caps  on  all  open-ended lines  and  plug
          valves to minimize  stem  leakage.
     4.    Enclosing pump  couplings  and drivers  on  all  pumps handling phos-
          gene.   Using special mechanical  seals on other pumps  (dual seals
          with barrier fluids) and  closed  purge sampling systems.
     5.    Continuous area and  individual monitoring  and the installation
          of  phosgene-release  alarms.
     6.    Establishing procedures and  training for prompt response to
          phosgene  leaks  and  releases.
                                      18

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     7    Practicing intensive preventive maintenance during plant shut-
          downs and turnarounds.  (A turnaround is a planned shutdown to
          allow equipment to be used to make a different product.)
     All plants that produce and use phosgene have individual and/or area
monitors to detect excessive phosgene levels in plant air. "   Based on the
sensitivity of these alarm systems, the fugitive phosgene emissions from a
phosgene plant producing 200 million Ib/yr are estimated to be 120 Ib/yr or
0.6 Ib/million Ib of phosgene.
     Alternatively, this emission rate can be estimated by counting the
valves, pumps, and flanges at a typical plant and applying the fugitive leak
rates and control efficiencies developed by the Environmental Protection
Agency  for the synthetic organic chemicals manufacturing industry  (SOCMI).
This approach yields an estimated fugitive emission rate of 6600 Ib/yr, or 33
Ib/million Ib of phosgene produced.  Fugitive emission estimates by both the
monitoring approach and the equipment  count/emission factor approach are
presented hereafter as a range  for  each plant.  It  is observed, however, that
fugitive controls used in phosgene  production are actually much more strin-
gent than those reported in Reference  10.     .
      In phosgene plants where  the  reactor" and condenser are  enclosed in a
negative-pressure building  and the  exhaust is vented through  the  caustic
scrubber, 99  percent of  the fugitive phosgene emissions are  destroyed  in the
caustic scrubber,  and  phosgene emissions  are  further reduced  to an estimated
1 to  66 Ib/yr (0.005 to  0.3 Ib/million Ib phosgene  produced).  Fugitive emis-
sion  estimates are derived  in the  appendix.
Process Upsets—
      Some phosgene emissions  result from process  upsets,  e.g.,  pump failures
 and inadvertent opening of the wrong valve.  Based  on  15  process  upset re-
 ports during a recent  6-year  period,' three Texas  plants released  a total- of
 900 pounds of phosgene.   Phosgene releases in the 15 episodes ranged from 1
 to 220 pounds.  The stated amount released in each  case usually represented
 an estimate, and it often was not clear what part of the process  was in-
 volved.  For example,  one upset was reported as a ruptured line.   Based on
 the size of these three plants, the total phosgene releases and the number of
 releases of phosgene (and assuming all releases were reported), it is esti-
 mated  that a plant producing 200 millions pounds per year of phosgene will

                                        19

-------
 average  one  process  upset  per year  during  which  50  pounds  of phosgene  is
 released (0.0005  Ib/ton  phosgene  produced).
 Total  Phosgene  Emissions-
     Total phosgene  emissions for a plant  that produces  200  million  pounds  of
 phosgene a year is estimated to be  470  to  7000 pounds, comprising  300  pounds
 from the process  vents,  120 to 6600 pounds in the form of  fugitive emissions,
 and 50 pounds as  a result  of process upsets.  This  is equivalent to  2.35  to
 34.8 Ib  phosgene  emissions per million  pounds of phosgene  produced.  Table  3
 presents a summary of phosgene emissions from phosgene production.

  TABLE  3.   ESTIMATED PHOSGENE EMISSIONS FROM A  HYPOTHETICAL  PHOSGENE  PLANT3
                                     (lb/yr)
Process vent
emissions
300
Fugitive
emissions
120 to 6600
Emissions due
to upsets
50
Total
emissions
470 to 6950
Eimission factor,
Ib per million
Ib processed
2.35 to 34.8
 Based on facilities with a hypothetical rate of 200 million pounds of phos-
 gene production per year.                                  .
 Incinerator and scrubber exhausts.                           .
 Estimated fugitive emissions would be reduced by a factor of 100 if reactor
 and condenser are enclosed in a negative-pressure building and vented
 through a caustic scrubber.

4.2  ISOCYANATE PRODUCTION11'12
4.2.1  Process Description
     The commercial production of aromatic and aliphatic isocyanates is accom-
plished through the reaction of amines and phosgene.  Aromatic isocyanates are
more important commercially than aliphatic isocyanates.  In 1978, the esti-
mated world production of the two principal aromatic isocyanates was 635,000.
metric tons of toluene diisocyanate (TDI) and 454,000 metric tons of diphenyl-
methane-4,4'-diisocyanate (MDI).
                                                        i
Aromatic Diisocyanate Production-
     Figures 4 and 5 show the reaction sequences for the production of the
major aromatic diisocyanates.   Toluene (Stream 1) is the starting material for
                                       20

-------
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the production of TDI and 3,3'-dimethyldiphenylmethane 4,4'-diisocyanate.

Toluene is converted' to dinitrotoluene with a mixture of solvent (Stream 2)

and sulfuric and nitric acids (Stream 3).  (The sulfuric acid ties up water

formed in the reaction.)  The proportions of dinitrotoluene isomers prepared

can differ depending upon operating conditions.  Varying the mixture of

isomers allows flexibility in the properties of the diisocyanate polymers:

     0    When dinitrotoluene is made without separating the mononitrotoluene
          isomers (Stream 5), the resulting mixture is 80 percent 2,4-isomer
          and 20 percent 2,6-isomer.

     0    The nitration reaction can be interrupted after the formation of the
          mononitrotoluenes (Stream 4), and the ortho- and paramononitrotolu-
          enes (Streams 6 and 7) can be separated by distillation.  Nitration
          of paranitrotoluene yields 100 percent 2,4-dinitrotoluene.

     0    Nitration of orthonitrotoluene yields a mixture of 65 percent 2,4-
          dinitrotoluene and  35 percent 2,6-dinitrotoluene (Stream 8),  Alter-
          natively, orthonitrotoluene can be reduced to orthoaminotoluene  (not
          shown in Figures 4  and 5) and form benzidine through the benzidene
          rearrangement.  Benzidene can then be phosgenated to form 3,3'-toli-
          dene 4,4'-diisocyanate.

          .The nitrotoluenes (Stream 8).are reduced to the amines with hydrogen
          (Stream 9).  The aminotoluenes (Stream 10) react with phosgene
          (Streams 11 and 13) to form the isocyanates in a two-step phosgena-
          tion process shown  in Figure 5.  Phosgene is first added at a  tem-
          perature range of -20° to 60°C and again at 100° to 200°C.  Polymer-
          ization takes place immediately, but some monomers remain.  The  pro-
          duct  (Stream 14) is then distilled-to remove and recover solvent and
          unreacted monomer.

Aliphatic Diisocyanate Production—
     Diphenylmethane-4,4'-diisocyanate,.an aliphatic diisocyanate, is pro-

duced  by reacting two moles of  analine with one mole of formaldehyde, fol-

lowed  by phosgenation-of the  diamine and polymerization of the resulting

diisocyanate.  The reaction and process  conditions are similar to those  for

the formation of TDI.
     The phosgenation and polymerization reactions are carried out in a

solvent medium.  Although the role  of  the  solvent  is unknown, the choice of
                                                       12
solvent influences the  rate  and extent of  the  reaction.    The solvent must

dissolve the amines,  phosgene,  isocyanate  monomers9 and at least  the  lower
                                        23

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molecular weight polymers.  Typical  solvents are aromatic compounds such as
xylene, monochlorobenzene, and o-dichlorobenzene.   Aliphatic solvents such as
methanol or hydrocarbons may be added to precipitate the polymer from solu-
tion.                                                  ;
     Process economics require that  the solvents be recovered and recycled.
All phosgene used in the process reacts with active hydrogen atoms to form
hydrogen chloride, which is recovered and either sold or decomposed by elec-
trolysis to yield chlorine (used in  the production of phosgene)  and hydrogen
(used to reduce nitro compounds to amines).             ;
4.2.2  Emissions and Controls
     Potential process emissions from the production of isocyanate include
phosgene, hydrogen chloride, aromatic and aliphatic solvents, aromatic
amines, aromatic nitro compounds, isocyanates, nitrogen oxides,  and sulfur
oxides.  Because these emissions include a number of toxic and corrosive
chemicals, controls are necessary.  A typical  control  system (as shown in
Figure 6) would include:                               '
     1.   A water scrubber to remove and recover hydrogen chloride.
     2.   A caustic scrubber to provide removal  of VOC and COC12 from the
          water scrubber as well as  to remove  VOC from the nitration and
          distillation processes.                      !
     3.   An incinerator for volatile organic  compounds.
     4.   A second caustic scrubber  for treatment of the incinerator exhaust
          to remove residues from the combustion of chlorinated  hydrocarbons.
    HC1, VOC, COC12
    (See Figure 5)
         i
(A)®©©
  VOC,  NOV
         f\
 (See Figures
  •4 45)






t
WATER
SCRUBBER





CAUSTIC
SCRUBBER
A
1 I ,





INCINERATOR

I ;
WATER RECOVERED CAUSTIC SPENT FUEL

HC1 CAUSTIC AIR
->
CA
STACK
EXHAUST
t
CAUSTIC
SCRUBBER
B

t 1
LISTIC SPENT
CAUSTIC
         Figure 6.   Flow diagram of a  phosgene  emission control system.
                                       24

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     As shown in Table 4, total  annual  phosgene emissions,  after controls,
are estimated to be 705 to 9760 pounds  for a plant producing 200 million
pounds of phosgene and using it on site in the production of TDI.  This
estimate includes emissions from phosgene production, which were developed  in
the preceding section and are not reported here.  Almost always, phosgene is
produced at the same plant where phosgene derivatives, such as isocyanates,
are produced.

      TABLE 4.  ESTIMATED PHOSGENE EMISSIONS FROM A HYPOTHETICAL TOLUENE
             DIISOCYANATE PLANT USING PHOSGENE PRODUCED ON SITEa
                            (Ib/yr except as noted)




Phosgene
production
Toluene
diisocyanate
production
Total plant



Process vent
emissions
300

150


450



Fugitive
emissions
120 to 6600

60 to 2640

• • *
180 to 9240


Emissions
due to
upsets
50

25

.
75



Total
emissions
470 to 6950

235 to 2820


705 to 9760
Emission
factor, Ib
per million
Ib phosgene
produced
2.35 to 34.8

1.18 to 14.1


3.53 to 48.9
 aBased on facilities with a hypothetical rate of 200 million pounds of phos-
  gene production  per year.
  Incinerator  and  scrubber exhausts.
 Estimated  fugitive emissions would  be  reduced by a factor of  100 if reactor
  and condenser  are enclosed in  a  negative-pressure building and vented through
  a  caustic  scrubber.

 Derivation  of phosgene emissions  from TDI  production  is  documented  in the
 appendix.

 4.3  POLYCARBONATE  PRODUCTION14'15
 4.3.1  Process  Description
      In general,  polycarbonates are  formed by the  reaction of  a diol  (a mole-
 cule with two alcohol  groups)  and a  carbonic acid  derivative  (phosgene is  the
                                        25

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 chloride of carbonic acid).  Because most commercial polycarbonates are de-
 rived from the reaction of bisphenol A [2,2 bis(4-hydroxyphenyl) propane] and
 phosgene, this process is discussed here.  Polycarbonates can also be formed
 by the reaction of other aromatic or aliphatic diols (dihydroxy alcohols) and
 phosgene.
                                                        ;i
      The sequence of reactions for producing polycarbonate from bisphenol A
 and phosgene is presented in Figure 7.  The basic reaction is:

                                                       0
                                                       II
                    OH + COC12 * [0-(0)-C —(0)— 0-C-O]  +  2HC1   (3)
      Bisphenol A and 1 to 3 mole percent monofunctional  phenol  (to control  the
 molecular weight of the carbonate polymer)  are dissolved or slurried in aque-
 ous sodium hydroxide (Stream 1).  A solvent and a tertiary amine catalyst
 (such as pyridine) are added, phosgene gas  is bubbled in (Stream 2), and the
 resulting mixture.is vigorously stirred. Additional  caustic is added as
 needed to keep the mixture basic.  As the polymer is  formed, it is filtrated
 in the solvent layer.  When the reaction is completed, the aqueous phase
 (Stream 3) contains sodium chloride, sodium carbonate (formed by a side reac-
 tion of phosgene and caustic), and possibly traces of phenols.   The organic
 phase (Stream 4) is a polymer solution containing polycarbonate, residual
 catalyst, and solvent.  This polymer solution is washed  with water, extracted
 with acid to remove residual catalyst (Stream 5), and washed again (Stream  6)
 with water until neutral  (Stream 7).  The solvent-is  then stripped from the
 polymer, by evaporation (Streams 8 and 9).   These reactions take place at or
 about room temperature.   The reaction may also be carried out in a solvent
 medium in which a large quantity of pyridine is used  to  tie up  the hydrogen
 chloride formed by the reaction of phosgene and bisphenol  A.
      Possible solvents (Stream 1) include methylene chloride, aromatic liquids,
.chlorinated aromatic liquids, and aliphatic chlorohydrocarbons.   Process
 economics require the recovery and recycling of all organic solvents.
      Most of the processing conditions (including reaction conditions)  are
 closely guarded secrets,  particularly with  regard to  processes  for isolating
                                       26

-------
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                                           27

-------
the polymer from the solvents.  Possible procedures for'separating  polymers
and solvent include nonsolvent precipitation,  spray-drying, multistep  total
solvent evaporation, and partial or complete solvent removal in  boiling water
followed by oven-drying.  Total solvent evaporation is effected  by  the  use of
wiped-film evaporators and multiport vacuum-vented extruders.  The  total re-
moval of a low-boiling chlorinated hydrocarbon (such as methylene chloride)
from a very high-viscosity, high-melting polymer is complicated  fay  two  fac-
tors:  1) foam formation at low temperatures impedes heat and mass  transfer,
and 2) the solvent can react with water or thermally decompose and  cause prod-
uct contamination.
4.3.2  Emissions and Controls                          j
     Potential emissions from phosgene and polycarbonate production include
phosgene, hydrogen chloride, aromatic and aliphatic hydrocarbons (some  of
which are chlorinated and could produce phosgene on incineration),  and  phe-
nols.  Emission controls for the reactors and solvent recovery systems  include
incinerators and caustic scrubbers-.  These controls are similar  to  those used
for isocyanate production.  Figure 8 is a flow diagram of a control system.
         (A) and (B)
         VOC, COC12
       (See Figure 7)

INCINERATOR
t
FUEL, AIR

CAU
A STACK
EXHAUST
CAUSTIC
SCRUBBER
e
t |
STIC SPENT
CAUSTIC
            Figure 8.  Control system for polycarbonate production.

     The wastewater from the reactor, acid wash, and water wash (see Figure 7)
is acidic and may contain small amounts of organic compounds.  These compounds
would probably have high molecular weights, have low water solubility, be non-
volatile, and thus would not be a significant source of lair emissions.
                                     28

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     As shown in Table 5, total annual phosgene emissions are estimated to be
580 to 8190 pounds for a plant producing 200 million pounds of phosgene and
using it on site to produce polycarbonates.  Derivation of these emission
estimates is documented in the appendix.

                 TABLE 5.  ESTIMATED PHOSGENE EMISSIONS FROM A
       HYPOTHETICAL POLYCARBONATE PLANT USING PHOSGENE PRODUCED ON SITE
                                    (lb/yr)

Phosgene
production
Polycarbonate
production
Total plant
	 —
Process vent
emissions
300
70
370
=
Fugitive
emissions
120 to 6600
30 to 1160
150 to 7760
Emissions
due to
upsets
50
10
60
Total
emissions
470 to 6950
110 to 1240
580 to 8190
Emission
factor, Ib
per million
Ib phosgene
produced
2.35 to 34.8
0.55 to 6.2
2.90 to 41.0
 aBased>on  facilities  with  a  hypothetical rate  of  200 million  pounds  of  phos-
  gene  production  per  year.      .
 blncinerator and  scrubber  exhausts.
                                                   o
 Estimated fugitive emissions  would  be reduced by a factor of 100  if reactor
  and condenser are enclosed  in a  negative-pressure building and vented  through
  a caustic scrubber.

 4.4 HERBICIDES AND PESTICIDES PRODUCTION14
      Phosgene is used in the synthesis of some pesticides and herbicides.
 The active chlorine atoms  of phosgene react with  hydrogen to  produce hydrogen
 chloride,  and the carbonyl group (C=0) is added to the reacting molecule.
 The three general classes  of chemicals comprising herbicides  and pesticides
 are phenyl ureas, carbamates, and thiocarbamates.  Sections 4.4.1  through
 4.4.3 discuss the production of each of these classes  of herbicides and
 pesticides.  The phosgene emissions from the production of each of these are
 similar.  (Phosgene emission estimates for herbicide and pesticide production
 are presented in Section 4.4.4.)
                                      29

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4.4.1   Production of Substituted  Phenyl Ureas
     The herbicidal activity of substituted phenyl ureas, was discovered  in
the late 1940's.  There are currently 20 to 25 phenyl ureas on the commercial
market.  Although initially developed as industrial herbicides, they also
have been used in selective agricultural applications.
     A  general reaction for the substituted phenyl ureas (e.g., monuron) can
be written as follows:
                                   0 >  -NH-C-N-R
For monuron, x is hydrogen, y is -OC1, and R and R1 are CH3.  Other
substituted phenyl ureas have been prepared and are in use with different
substituents for x, y, R, and R'.
     Figure-9 presents the basic operations".used in substituted phenal  urea
production, and Figure 10 presents a flow diagram of a control system for
such a process.  The synthesis of monuron [3-(p-chloropheny])-l,l-dimethyl-
urea] is typical  of the general  commercial method used for the production of
substituted phenyl ureas.  For this synthesis, the p-chloroaniline in dioxane
or some other inert solvent (Streams 1 and 2) reacts with anhydrous hydrogen
chloride and phosgene at 70° to  75°C (Stream 3) to form.pi-chlorophenyl  iso-
cyanate (Stream 4).  This aromatic isocyanate further-reacts with dimethyl-
amine at 25°C to give monuron (Stream 5), which is then separated from the
solvent by precipitation and evaporation.  (See Reaction 4.)
          M2                      N = C = 0             ;      NHCON (CH3)
          to)       +
COC12
                            (CH3),NH
          Cl                        Cl
    p-chloroanaline       p-chlorophenyl  isocyanate
                                     30
                                                                        3/2

-------
                                      0) *J «
                                      tj  c
                                        J= 0)
                                      0> 4-> >
                                     J=
                                     •M "a *n
                                        c   •
                                        S s. in
                                         0)  u>  O
                                      
                                      3    01  C
                                      O) C  >  O
                                      •r-1-     U
                                      <*-    u>
                                        •O  in  10
                                      vi at  ai
                                      i- 
    o
a: o
o L
UJ
 S.
 (U
 a.
 o

 U
•I—
 tfl
 CO
03
                                                                   =3
                                                                   O)
                     31

-------
              O'
              O
              3
              •o

              2
              Q.
              (U
              o.
              o
              o
              o
              o

              CO
             O)


             3
             cn
32

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4.4.2  Carbamates Process
     Carbamates are used as herbicides, insecticides, and medicinals, and for
the control of nematodes, mites, and mollusks.  They are obtained either by
the reaction of a substituted analine with a chloroformate ester or the reac-
tion of an isocyanate with an alcohol.  The chloroformate ester is made by
reacting phosgene with an alcohol (ROM + COCL2 •»• C1COOR + HC1), and the iso-
cyanate is made by reacting phosgene with an amine (as described in Section
4.2).  The basic reactions are:

                                                                      (5)
                    O   -  N = C = 0 +
(6)
Different R groups and substitutions on the benzene ring yield  a variety of
useful products.
4.4.3  Thiocarbamates Process
     Thiocarbamates are used primarily as herbicides,  but  some  have  value  as
fungicides.  The phosgene  reaction  is the same  as  in the other  processes:  the
chlorine atoms react with  hydrogen  to form hydrogen chloride, and  the  car-
bony! group is added to the molecule.
     Thiocarbamates are formed  in a two-stage reaction.  The first stage is
the  reaction of phosgene and a  secondary amine  to  yield a  carbamyl chloride:
                         R2NH + COC12 -»• R2NCOC1  +  HC1                  (7)
followed by reaction with  a thiol to yield a carbamate:
                         R2NCOC1 +  NaSR1 -> R2NCOSR' +  NaCl             (8)
Alternatively, the secondary amine  can react with  an alkyl  chlorothiol  formate
in the presence of a proton acceptor to tie up  the HC1 formed in the reaction:
                         RSCOC1 + NHR'R" + RSCONR'R" + HC1 .          (9)
                                       33

-------
Varying the R, R', and R" groups will produce different thiocarbamates.
4.4.4  Emissions and Controls
     Generalized flow diagrams for herbicide and pesticide production and
emission controls are shown in Figures 9 and 10, respectively.  State-
of-the-art controls include incineration (to control VOC emissions) and
caustic scrubbers (to control phosgene and HC1 produced either by reactions
involving phosgene or by incineration of the VOCs).
     As shown in Table 6, total annual phosgene emissions are estimated to be
580 to 8220 pounds for a plant producing 200 million pounds of phosgene on
site and using it to produce herbicides and pesticides. ! Derivation of this
emission estimate is documented in the appendix.

          TABLE 6.  ESTIMATED PHOSGENE EMISSIONS FROM A HYPOTHETICAL
        HERBICIDE AND PESTICIDE PLANT USING PHOSGENE PRODUCED ON SITE9
                                    (lb/yr)

Phosgene
production
Herbicide and
pesticide
production
Total plant
Process vent
emissions
300
70
370
Fugitive
emissions
120 to 6600
30 to 1190
150 to 7790
Emissions
due
to upsets
50
10
60
i
Total
emissions
470 to 6950
110 to 1270
i
580 to 8220
Emission
factor, Ib
per million
Ib phosgene
produced
2.35 to 34.8
0.55 to 6.4
2.90 to 41.1
 Based on facilities with a hypothetical  rate of 200 mill ion pounds  of phos-
 gene production per year.
 Incinerator and scrubber exhausts.
Estimated fugitive emissions would  be reduced by a  factor of 100  if reactor
 and condenser are enclosed in a negative-pressure building and  vented through
 a caustic scrubber.
                                      34

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                           REFERENCES FOR SECTION 4

 1.  Kirk-Othmer.  Encyclopedia of Chemical Technology.  3rd Ed., Volume 17.
     Wiley Interscience Publication, New York.  1979.  pp. 416-425.
 2..  Personal communication with R. L. Matherne, Ethyl .Corporation, Baton
     Rouge, Louisiana, February 7, 1984.  Based on Mr. Matherne's experience
     at BASF Wyandott.
 3.  Kistner, S., et. al.  A Caustic Scrubber System For The Control Of
     Phosgene Emissions Design, Testing, and Performance.  Journal of the Air
     Pollution Control Association,.28(7):673-676,1978.
 4.  Enviro Control, Inc.  Assessment of Engineering Control Monitoring
     Equipment.  Volume I.  Prepared for the National Institute for Occupa-
     tional Safety and Health, Cincinnati, Ohio, PB83-15269.  Contract No.
     210-79-0011, June 1981.
 5.  Personal communication with Marshall Anderson, General Electric Corpora-
     tion, Mount Vernon, Indiana, February 8, 1984.
 6.  Personal communication with George Dinser, Mobay Chemical Company, Cedar
     Bayou, Texas, February 8, 1984.
 7.  Personal communication with Mark Kenne, ICI Americas, Rubicon Chemical
     Division, Geismar, Louisiana, February 14, 1984.  ;
 8.  Personal communication with Jerry Neal, PPG Industries, LaPorte, Texas,
     February 14, 1984.
 9.  Personal communication with George Flores, Dow Chemical Co., Freeport,
     Texas, February 15, 1984.
10.  U.S. Environmental Protection Agency.  Fugitive Emission Sources of
     Organic Compounds - Additional Information on Emissions, Emission Reduc-
     tions, and Costs.  EPA-450/3-83-010.  Research Triangle Park, North
     Carolina.  April 1982.                            '
11.  Personal communication with R. A. Campbell, Plant iManager, Olin Chemi-
     cals Group, Moundville, West Virginia, May 3, 1984.
12.  Kirk-Othmer.  Encyclopedia of Chemical Technology.   3rd Ed., Volume 13.
     Wiley Interscience Publication,  New York.  1979.  pp. 789-808.
                                      35

-------
13.  Encyclopedia of Polymer Science and Technology.  Volume 11.  Wiley Inter-
     science Publication, New York.  1979.  pp. 507-525. .
14.  Kirk-Othmer.  Encyclopedia of Chemical Technology.  3rd Ed., Volume 18.
     Wiley Interscience Publication, New York.  1979.  pp. 479-492.
15.  Encyclopedia of Polymer Science and Technology.  Volume 10.  Wiley Inter-
     science Publication, New York.  1979.  pp. 710-764.
16.  Kirk-Othmer.  Encyclopedia of Chemical Technology.  3rd Ed., Volume 12.
     Wiley Interscience Publication, New York.  1979.  pp. 319-326.
                                       36

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                                   SECTION 5
                            SOURCE TEST PROCEDURES      '.

     No EPA Reference Method has been established for measuring phosgene;
however, the .NIOSH Manual of Analytical Methods contains a proposed method
for the collection and analysis of phosgene in air.1  This method involves
the reaction of phosgene with a solution of 4,4'-nitrobenzyl pyridine in
diethyl phthalate to produce a red color.  The color reaction is measured in
a photometer.
     In the NIOSH method, exhaust or air containing phosgene is passed through
midget impingers (Figure 11) containing a color reagent made up of 2;5 g
4,4'-nitrobenzyl pyridine, 5 g N-phenylbenzyl amine, and 992.5" g diethyl  phtha-
late.  Fifty liters are drawn through the impingers if the phosgene level is
in the range of 0.04 to 1 ppm, whereas a volume of 25 liters is drawn for
phosgene levels above 1 ppm.  The phosgene reacts with the reagent to form a
red color.  The N-phenylbenzyl amine in the solution stabilizes the color and  .
increases the sensitivity.  The resulting red  color should be measured with a
photometer within 9 hours of sampling.  Sampling efficiency is 99 percent or
better.
     Interfering compounds are acid chlorides, alkyl and aryl derivatives
(which are substituted by active halogen atoms), and sulfate esters.   If
necessary, most of these interfering compounds can be removed in a prescrubber
containing an inert solvent, such as Freon-113, that has been cooled  by  an
ice bath.  This method has not been validated  by EPA.
                                     37

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                                                                               OJ

                                                                               
-------
                         REFERENCES FOR SECTION 5      I


1.  National Institute for Occupational Safety and Health.   NIOSH  Manual  of
    Analytical  Methods.  Part 1 - NIOSH Monitoring Methods,  Volume 1.   U.S.
    Department of Health, Education, and Welfare,  Cincinnati,  Ohio.  April
    1977.

2.  Knoll, J.  Intra-agency memorandum to T.  Lahre, U.S.  Environmental
    Protection Agency, Air Management Technology Branch,  Research  Triangle
    Park, North Carolina, December 4, 1984.
                                   39

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                                   APPENDIX            !;
                            PHOSGENE EMISSIONS DATA    '

     About 89 percent of the phosgene production capacity in the United
States is located in West Virginia, Louisiana, and Texas.1  In an effort to
obtain phosgene emissions data, several plants and their respective air con-
trol agencies in these States were contacted.  Plants iin two other states
were also contacted.  The Texas Air Control Board (TACB) files were also
reviewed for information on the Texas plants.  Only one direct measurement of
phosgene emissions was found, but the companies had made conservative calcu-
lations of phosgene emissions.  In one case, emission calculations were.based
on the sensitivity of in-place monitors; no phosgene was actually detected.
     Engineering estimates submitted to state air control agencies by eight
phosgene producers range from 0 to 7.0 tons of phosgene per year.  These
estimates contained no breakout of emissions due to phosgene production,
storage, use, etc., and the manufacturers did not indicate any basis for the
estimates.       .
     Compounds other than phosgene that must be controlled include process
solvents, reactants, intermediate products, chlorine, carbon monoxide, and
hydrogen.chloride (the latter is included unless phosgenation is carried out
in an alkaline medium).  Most of these compounds are subject to Occupational
Safety and Health Administration (OSHA) regulations.  A!typical plant's
emission control system will include the following:
     1.   A water scrubber to remove and recover hydrogen chloride for sale
          or reuse.                                    t
     2.   A caustic scrubber to control acidic gases, hydrogen chloride,  and
          phosgene.  A backup scrubber, installed as a spare, is used if the
          primary scrubber malfunctions.
     3.   An incinerator to control  volatile organic compounds (some may con-
          tain chlorine) and carbon monoxide.  If both caustic scrubbers
          malfunction, the phosgene will be routed directly to the incinerator
          for destruction.

                                     A-l

-------
     4.    An additional  caustic  scrubber  that  treats the  incinerator exhaust
          to remove  residues  from the  combustion  of chlorinated  hydrocarbons.
          In some plants where only one caustic scrubber  is used,  it is
          located downstream  of  the incinerator.

     5.    For fugitive emissions, plugs or caps on open-ended  lines, closed
          purge sample systems,  dual seals with barrier fluids on  pumps, and
          vent systems and rupture disks  on safety relief valves.   Phosgene
          plants are also typically enclosed in negative-pressure  buildings,
          which may  be vented to caustic  scrubbers.

     The following three types of emissions are found  within a phosgene plant:

     1.    Process vent emissions—These are emissions  from reactors, other
          processing equipment (including storage tanks), and  emission con-
          trol equipment, including incinerator and scrubber exhausts.

     2.    Process upsets emissions—These emissions represent  inadvertent
          releases due to equipment failures and  human error.

     3.    Fugitive emissions—These emissions  represent  releases due to leaks
          in pumps,  valves, and  other  phosgene handling  equipment.

Phosgene Emission Estimates

     Estimates of .total phosgene emissions from plants producing 200 million
pounds of phosgene per year (a capacity  chosen to represent production from a

large plant) are as  follows:

     1.    From a plant producing phosgene for sale, 470  to 6950  Ib/yr.

     2.    From a plant producing phosgene and converting it to toluene diiso-
          cyanates,  705 to 9760  Ib/yr.

     3.    From a plant producing phosgene and converting it to polycarbon-
          ates, 580  to 8190 Ib/yr.

     4.    From a plant producing phosgene and converting it to herbicides,
          580 to 8220 Ib/yr.

The emission factors on which these estimates are based  (in terms of pounds
of phosgene emitted per million pounds of phosgene processed)  are presented

in Table A-l.

     Phosgene emissions from processes that consume  phosgene  (TDI, polycar-
bonate, herbicide, and pesticide production) have been estimated by comparing

the processes used to produce these chemicals with the process for phosgene
                                     A-2

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         TABLE A-l.  SUMMARY OF ESTIMATED PHOSGENE EMISSIONS FROM
   HYPOTHETICAL PHOSGENE AND PHOSGENE DERIVATIVE PRODUCTION FACILITIES3

1. Phosgene production
at a merchant phos-
gene plant
2. Toluene diisocya-
nate production
3. Polycarbonate pro-
duction
4. Herbicide and pes-
ticide production
5. Total for TDI .
plant (1 + 2)d
6. Total for polycar- ,
bonate plant (1 + 3)
7. Total for herbi- .
cide plant (1 + 4)a
Process
vents'
Ib/yr
300
150
70
70
450
370
370
Upsets ,
Ib/yr
50
25
10
10
75
. 60
. 60
Fugitive
emissions,
lb/yrc
120 to 6600
60 to 2640
30 to 1160
30 to 1190
180 to 9240
i
150 to 7760
150 to 7790
Total
emissions,
Ib/yr
470 to 6950
235 to 2820
110 to 1240
110 to 1270
705 to 9760
580 to 8190
580 to 8220
Emissions,
ID/million
Ib phosgene
produced
2.35 to 34.8
1.18 to 14.1
0.55 to 6.2
0.55 to 6.4
3.53 to 48.8
2.90 to 41.0
2.90 to 41.1
Based on facilities with a production rate of 200 million pounds of phosgene
per year.

Incinerator and scrubber exhaust.

Fugitive emissions would be reduced by a factor of 100 if process reactor
and condenser are enclosed in negative-pressure buildings and vented through
the caustic scrubber.

Emissions from intermediate production are added to those from the phosgene
production operations  to estimate total  plant emissions.
                                   A-3

-------
production and then using engineering judgment to estimate the emissions
relative to those for phosgene production.  The processes were compared with
respect to operations where phosgene might still be present and potential
emission sources.  For example, emissions due to TDI production were estimated
to be one-half of those due to phosgene production, and those for polycarbonate
production and herbicide and pesticide production were estimated to be about
25 percent of those due to phosgene production.  The TDI estimates are higher
because two phosgenation stages are required (Section 4.2) as compared with
one phosgene reaction step for polycarbonate (Section 4.3) and herbicide and
pesticide production (Section 4.4).
     Phosgene emissions from phosgene consuming processes would be expected
to be significantly lower than those from the phosgene production process.
Phosgene is only used early in the process and  is almost completely consumed.
No provisions for phosgene recovery and storage after production are needed.
Therefore, it is reasonable to expect phosgene  production to  be the major
source of phosgene emissions.
Basis For Emission Estimates
     The emission estimates in Table A-l  are approximations based on. limited
information, derived as  shown below:
Process Emissions—
     Process emission estimates were based on  the  following:
     1.   An assumed phosgene  concentration of 0.5  ppm  in  the caustic  scrub-
          ber effluent,  based  on  a  U.S.  Army  study.2  This  study  indicates
          that  actual phosgene  concentrations  in  scrubber  exhausts  could be
          either significantly higher  or lower, depending  on  whether the
          scrubber  is properly designed  and operated.   The  range was 0.015  to
           10.3  ppm.  A  scrubber would  need to have the  capacity to  handle
           phosgene  surges.
     2.    Stack flow rates  calculated  from stack and  exhaust  velocity  data
           submitted to  the  Texas  Air Control  Board by the  four Texas phosgene
           producers.
      3.    Assumed  plant operations  of 24 hours a day, 330  days a  year  (90
           percent  availability).
                                      A-4

-------
 Based on this  information,  phosgene  emissions  of  19  to 500  pounds per year
 were calculated  for each  of these  plants.  Thus,  phosgene emissions from a
 plant producing  200 million pounds of  phosgene per year are estimated to be
 300  pounds  per year.
 Fugitive Emissions  (Based on Ambient Exposures)—
      Individual  and area,  monitors  of phosgene  exposures yield the best avail-
 able information about actual phosgene levels  in plants:  As standard equip-
 ment at  plants producing  and handling phosgene, these monitors allow upper
 limit estimations of ambient phosgene concentrations' and emissions.
      Phosgene  exposures are measured in ppm-minutes  (the product of the phos-
 gene concentration  in parts per million and the time of exposure in minutes).
 The  maximum phosgene concentration that OSHA allows  is 0.1  ppm for an 8-hour
 day,  or  48 ppm-minutes.   Area monitors can respond to phosgene levels as low
 as 0.05  ppm.   Film  badges are worn by all employees  in phosgene areas.   An
 exposure of 5 ppm-minutes can be detected by a visible color change, and as
 low  as 2 ppm-minutes can  be detected photoelectrically.   Based on reported
 data, photoelectrically detected color changes were infrequent—only five
 occurrences over an 18-month period in a single plant.3J  Other plants contacted
 indicated that positive monitor responses were also infrequent.   Because the
 badges would detect exposures of 2 ppm-minutes, a  steady-state phosgene
 concentration of 1.2 ppm-minutes for an 8-hour shift was  assumed.
     Other assumptions included an indoor work area measuring  200  feet by 100
 feet by 30 feet,  40 air changes per hour,4 and operated 24 hours a day,  330
 days a year.

 Process fugitive  emissions = l'2 Ppm"m1"  x 10"./ppm
                                 8 h  x  60 min/h
x 330 days/vr x 24 h/day  x 40 changes/h x 6xl05 ft3/change x 98.92  Ib/lb-mole

= 120 Ib/yr
                            380 fr/lb-mole
This calculation yields a controlled process  fugitive  phosgene  emission  of
120 pounds per year.  This is a conservative  estimate  because the  steady-
state phosgene exposure is assumed to be  constantly  high  throughout the
building for every working day during the year.         :
                                     A-5

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Fugitive Emissions (Based on Equipment Counts and Emission Factors)—
     An alternative method can be used to estimate fugitive emissions; one
which applies emission factors to each valve, pump, etc., based on the phos-
gene content of each process stream.  The following steps were followed in
this approach:
     1.   Develop a process flow diagram (see Figures 2, 5, 7, and.9 in   .
          text).
     2.   Identify all process streams containing phosgene.
     3.   Determine the phosgene content of each stream and whether phosgene
          is present as liquid or vapor.
     4.   Identify and estimate the total number of fugitive emission points
          (valves, pumps, and relief devices).
     5.   Estimate phosgene emission rates based on the probable  degree of
          control, assuming very stringent inspection and maintenance programs
          and typical phosgene plant control measures for valves,  open-ended
          pipes,'pump seals, and vents.5
     Fugitive emissions of phosgene and other volatile organics result from
 leaks  in  process  valve's,  pumps, compressors, and pressure-relief  devices.
 For  the four  processes discussed  (phosgene production, isocyanate production,
 polycarbonate production, and herbicides and pesticides  production)  the phos-
 gene emission rates are based on  process flow diagrams,  process operation
 data,  fugitive  source inventories  for  hypothetical  plants,  and emission fac-
 tors for  process  fugitive sources.
     The  first  step  in estimating  fugitive emissions  of  phosgene  entailed
 listing the process  streams  in  the hypothetical  plants and  then estimating
 their  compositions.   For  a  reactor product stream,  the estimated  composition
 was  based on reaction  completion  data  for  the reactor and on  the  plant  prod-
 uct mix.   For a stream from a distillation column  or other separator, the
 estimated composition  was based on the composition of the input stream  to  the
 unit,  the unit description,  and the general  description  of the stream of  in-
 terest (i.e., overheads,  bottoms, or sidedraw).
      After the process streams  were characterized, the number of  valves  per
 stream was estimated (based on the type of process).  Pumps were  assigned to
 each liquid process stream, and relief devices  were assumed on all reactors,
                                      A-6

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columns, and other separators.  No compressors are used on phosgene process
f1ows.
     Emissions were then calculated for pumps, valves in liquid and gas line
service, and relief devices.  Welded pipe joints are used in lieu of flanges,
and emissions from pipe joints are negligible.4  Fugitive emissions from a
particular source were assumed to have the same composition as the process
fluid to which the source is exposed.  For example, phosgene emissions from
valves in liquid service were determined by taking the product of 1) the
total number of liquid valves in phosgene service,'2) the average phosgene
content of the streams passing through these valves, and 3) the average fugi-
tive emission rate per valve per unit time.  Emissions from valves in gas
service and pumps were calculated in the same manner.  For relief devices,
the composition of fugitive emissions was assumed to be the same as that of
the overhead stream from the reactor or column served by the relief device.
Emissions from the various fugitive types of sources were summed to obtain
total process fugitive emissions of phosgene.
     Emissions from process fugitive sources depend on the number of sources
rather than their size; therefore, plant capacity does not affect total  pro-
cess fugitive emissions.  For this reason, overall  emissions are expressed in
terms of kilograms per hour of operation.              i
     The estimates of fugitive phosgene emissions are presented in Tables A-2
through A-5.   The emission factors used in these estimates are summarized in
Table A-6.   At a hypothetical phosgene plant producing 200 million pounds of '
phosgene per year, the process fugitive emission rate is;  0..38 kg/h or 3000
kg/yr (3.3  tons/yr), assuming the plant operates 24 hours per day, 330 days
per year.  For toluene diisocyanate production, estimated process fugitive
emissions are 0.15 kg/h or 1,200 kg/yr (1.3 tons/yr); for polycarbonate
production, 0.067 kg/h or 530 kg/yr (0.58 tons/ yr);  and  for herbicide and
pesticide production, 0.068 kg/h or 540 kg/yr (0.59 tons/yr), in addition to
the emission  rate (determined above)  associated with  captive phosgene
production, if carried out at these facilities.
     Reference 5, the basis for the emission factors  and  control  efficiencies
in this analysis, does not consider fugitive emission controls  as stringent
as those encountered in phosgene plants.   For example,  the most stringent
level  level of control for valves  cited in this report  only involves monthly

                                     A-7

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                   TABLE A-2.   ESTIMATED  FUGITIVE  PHOSGENE
                 EMISSIONS  FROM  A HYPOTHETICAL  PHOSGENE  PLANT
              PRODUCING  200 MILLION  POUNDS OF PHOSGENE PER YEAR'


•

Emission source
Valves
Liquid

Gas

Pumps

Relief valves on:
COC12 reactor.
Condenser
Adsorption column
Storage tanks



•
Number

150

100

2


2
2
2
4
Uncon-
trolled
emission.
factor,
kg/h

0.0071/
valve
0.0056/
valve
0.0494/
pump

0.104
0.104
0.104
.0.104


Control h
efficiency, >c
%

59

73

100


100
100
100
100



Avg. COC12
content, •%

68

50

68


65
100
. 35
100
All sources



Emissions,
kg/h

0.30

0.08

0


0
0
0
0
0.38
a Process streams and their composition at hypothetical plant:

                Process streams              Phase   % phosgene

      Reactor to condenser                   Gas         65
      Condenser to storage                   Liquid     100
      Condenser to absorber                  Gas         35
      Liquid phosgene to plant or shipment   Liquid     100
      Phosgene solution to plant             Liquid       5


  Reference 5.
c The control efficiencies are based on the use of plugs or caps on open-ended
  lines, double seals with barrier fluids on pumps, vent systems and rupture
  disks on safety relief valves, and a monitoring interval of at least monthly
  for valves.
                                     A-8

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             TABLE A-3.  ESTIMATED FUGITIVE PHOSGENE EMISSIONS
       FROM A HYPOTHETICAL TOLUENE DIISOCYANATE PRODUCTION FACILITY3



Emission source
Valves
Liquid

Gas

Pumps

Relief valves on:
Phosgene line to
first-stage
phosgenator
Phosgene line to
second-stage
phosgenator
Unreacted phos-
gene to recycle
line
First-stage -
phosgenation
Second-stage
phosgenation
Distillation
column



Number

100

200

2




2


2


2

2

2

2
Uncontrolled
emission.
factor,
kg/h

0.0071/
valve
0.0056/
valve
0.0494/
pump



0.104


0.104


0.104

0.104

0.104

0.104

Control .
efficiency,'0
%

59

73

100




100


100


100

100

100

100


Avg. COC12
content, %

5

45

\ 5




85


I 85 .


5

5

1

\ l
All sources ;


Emissions,
kg/h

0.01

0.14

0




0


• o


0

0

0

0
0.15
Process streams and their composition at the hypothetical plant:
               Process streams

    Phosgene to first-stage phosgenation
    Phosgene to second-stage phosgenation
    Unreacted phosgene to recycle
    Monoisocyanote to second-stage
     phosgenation
    Diisocyanate to distillation
    Waste phosgene to scrubber
Phase   % phosgene
Gas '
Gas
Gas
Liquid
Liquid
Gas
85
85
5
5
5
5
Reference 5.

The control efficiencies are based on the use of plugs or caps on open-ended
lines, double seals with barrier fluids on pumps, vent systems and rupture
disks on safety relief valves, and a monitoring interval of at least monthly
for valves.
                                   A-9

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               TABLE  A-4.   ESTIMATED  FUGITIVE  PHOSGENE  EMISSIONS
            FROM A HYPOTHETICAL  POLYCARBONATE  PRODUCTION  FACILITY0


Emission source
Valves
Gas

Pumps
Relief valves on:
Phosgene line to
reactor
Unreacted phos-
gene to inciner-
ator


Number

100

0

2


2
Uncontrolled
emission
factor,
u
. kg/hb

0.0056/
valve
0

0.104


0.104 -

Control b
efficiency, '
%

73

0

100


100

Avg. COC12
content, %

44

0

85.


85
All sources

Emissions,
kg/h

0.067

0

0


0
0.067
a Process streams and their composition at the hypothetical  plant:

                Process streams           Phase  % phosgene
      Phosgene to reactor                 Gas
      Unreacted phosgene to incinerator   Gas
85
 2
  Reference 5.
c The control efficiencies are based on the use of plugs or caps on open-ended
  lines, double seals with barrier fluids on pumps, vent systems and rupture
  disks on safety relief valves, and a monitoring interval  of at least"monthly
  for valves.
                                     A-10

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         TABLE A-5.  ESTIMATED  FUGITIVE  PHOSGENE  EMISSIONS  FROM A
         HYPOTHETICAL HERBICIDE AND PESTICIDE PRODUCTION  FACILITY*1

Emission source
Valves
Gas

Liquid

Pumps

Relief valves on:
Phosgene line to
reactor
Unreacted phos-
gene to scrubber

Number

100

50

1



2
.
2
Uncontrolled
emission
factor,
kg/hb

0.0056/
valve
0.0071/
valve
0.0494/
pump


.0.104

0.104

Control .
efficiency, 'c
%

73

59

100



100

" 100

i
Avg. COC12
content, %
]
44

.1

1
i


85

2
All sources ,i

Emissions,
kg/h

0.067

0.001

0



0

0
0.068
Process streams and their composition at the hypothetical plant:
             Process streams

    Phosgene to reactor
    Unreacted phosgene to incinerator
    Aromatic isocyanate to second-
     stage reactor


Reference 5.
Phase  % phosgene
Gas
Gas

Liquid
"85
  2
The control efficiencies are based on the use of plugs or caps on open-ended
lines, double seals with barrier fluids on pumps, vent systems and rupture
disks, on safety relief valves, and a monitoring interval of at least monthly
for valves.
                                   A-ll

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                         TABLE A-6.  PROCESS FUGITIVE
                          EMISSION FACTORS FOR PLANTS
           Facility
     Marketable phosgene
      producer

     Toluene diisocyanate
      producer
      Polycarbonate
       producer
      Herbicide and pesti-
       cide production
                               Emission source
                          Phosgene production
                          Phosgene production
                          TDI production
                          Phosgene production
                          Polycarbonate production
                          Phosgene production
                          Herbicide and pesticide
                          production
Emission factor,
    kg/h
 0.38
 0.15
 0.38
 0.067
 0.38
 0.0068
           0.38
                                                               0.53
                                                               0.45
                                                                0.39
 inspection and maintenance.   This program provides  73  percent leak  control
'for valves handling gases,  and 59 percent leak control  for valves handling
 light liquids.  A control  efficiency of 100 percent,  however, was estimated

 for plugs and caps on open-ended lines, dual  seals  with barrier fluids  on
 pumps, and vent systems and rupture disks on safety relief valves.   These
 efficiencies were used to  estimate fugitive phosgene  emissions from valves,

 pumps, and relief valves.
      The emission factors  from Reference 5 are based  on "leaking" and "non-

 leaking" sources.  Leaking is defined as ""screening at or above 10,000  ppm
 with a portable VOC monitor."  Nonleaking is defined  as "screening  below
 10,000 ppm."  These data do not allow extrapolation to the actual  level of
 control most likely in phosgene plants.  A 10,000 ppm phosgene concentration
 could not be tolerated because the average lethal exposure is 400 to 500
 ppm-minutes (concentration in ppm multiplied by exposure in minutes).  The

 current OSHA standard is 0.1 ppm.  Phosgene plant monitoring equipment typi-
                                                     6-8
                                                          Film badges typical-
cally responds to concentrations of 0.02 to 0.2 ppm.

ly respond to exposures of 2 ppm-min0
     The estimated fugitive phosgene emission rate of 120 Ib/yr based on the
monitoring approach from a facility with a capacity of 200 million pounds
                                      A-12

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corresponds to 99.3 percent control of valve emissions.  Considering that
phosgene concentrations of 0.02  to 0.2 ppm6"8 produce  immediate responses
from monitoring equipment, this  level of control seems achievable.  Both
estimates of fugitive phosgene emissions, however, are presented  in the
report to provide a range of fugitive phosgene emissions.
     In plants where the reactor, condenser, and associated valves, pumps,
etc. are enclosed in negative-pressure buildings and the exhausts are vented
through a caustic scrubber, phosgene fugitive emissions will be reduced by a
factor of 100 from the above estimates.
Process Upsets—                                           :
     As discussed earlier, a search of the Texas Air Control Board files
yielded process upset reports for three producers of phosgene.  Based on the
15 process upset reports during a recent 6-year period, the three plants had
a total phosgene release of 900 pounds.  Phosgene releases in the 15 episodes
ranged from 1 to 220 pounds.  The stated amount released in each case usually
represented an estimate.  All releases may not have been reported.  One
letter in the file responding to a Notice of Violation stated that the com-
pany was not obligated to report the release because none of the released
material (not phosgene) had left the company property.  One of the 15 re-
leases led to-a fatality, and two other releases were responsible for lost-
time accidents.  Based on the size of the plants, the total phosgene release,
and the number of releases of phosgene, it is estimated that a plant produc-
ing 200 'million pounds of phosgene per year will have one process upset per
year during which 50 pounds of phosgene is released.
                                     A-13

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                          REFERENCES FOR APPENDIX


1.  SRI International.  1983 Directory of Chemical Producers, USA.  1983.

2.  Kistner, S., et. al.   A Caustic Scrubber System for the Control of
    Phosgene Emissions Design, .Testing, and Performance.  Journal Air
    Pollution Control Association, 28 (7):  673-676, 1978.

3.  Personal Communication with R. L. Matherne, Ethyl Corporation, Baton
    Rouge, Louisiana, February 7, 1984, concerning Mr. Matherne's experiences
    at BASF-Wyandotte.

4.  Pollution Engineering Practice Handbook.  P. N. Cheremisinof and R. A.
    Young, eds.  Ann Arbor Science, Ann Arbor, Mighigan.  p. 212.

5.  U.S. Environmental Protection Agency.  Fugitive Emission Sources of Or-
    ganic Compounds—Additional Information on Emissions, Emission Reduc-
    tions, and Costs.  EPA-450/3-82-010, 1982.

6.  Personal communication with Marshall Anderson, General Electric Corpora-
    tion, Mount Vernon, Indiana, February 8, 1984.

7.  Personal communication with Jerry Neal, PPG Industries, LaPorte, Texas,
    February 14, 1984.                                   ,

8.  Personal communication with George Flores, Dow Chemical Company, February
  .  14, 1984.
                                    A-14

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 1. REPORT NO.
     EPA-450/4-84-0071
                                    TECHNICAL REPORT DATA
                             (Please read Instructions on the reverse before completing)
 4. TITLE AND SUBTITLE
2.
     Locating And Estimating  Air Emissions From Sources
     Of Phosgene
 7. AUTHOR(S)
 9. PERFORMING ORGANIZATION NAME AND ADDRESS
  2. SPONSORING AGENCY NAME AND ADDRESS
     Monitoring And Data Analysis  Division  (MD 14)
     Office  Of  Air Ouality Planning And Standards
     U. S. Environmental Protection Agency
     Research Triangle Park, NC  27711
 15. SUPPLEMENTARY NOTES
     EPA Project  Officer:  Thomas  F.  Lahre
                              3. RECIPIENT'S ACCESSION NO.
                                                             5. REPORT DATE
                                September 1985
                              G. PERFORMING ORGANIZATION CODE
                                                             8. PERFORMING ORGANIZATION REPORT NO.
                                                             10. PROGRAM ELEMENT NO.
                                                             11. CONTRACT/GRANT NO.
                              13. TYPE OF REPORT AND PERIOD COVERED
                              14. SPONSORING AGENCY CODE
        VCT
        To assist groups  interested in inventorying air emissions  of various
  potentially toxic substances, EPA is preparing a series of documents such as this
  to  compile available information on sources  and emissions of  these substances.
  This  document deals specifically with phosgene.  Its intended audience includes
  Federal,  State and local air pollution personnel and others interested in locating
  potential emitters of  phosgene in making gross estimates of air emissions therefrom.

        This document presents information on 1)  the types of sources that may emit
  phosgene, 2) process variations and release  points that may be  expected within
  these sources, and 3)  available emissions  information indicating the potential for
  phosgene  release into  the air from each operation.
 7.
                                KEY'WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
     Phosgene
     Emissions  Sources
     Locating Air  Emission Sources
     Toxic Substances
 8. DISTRIBUTION STATEMENT
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                                               !0. SECURITY CLASS (Thks page)
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                                              60
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