United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
November 1992
EPA-453/D-92-016a
Air
Hazardous Air Pollutant Draft
Emissions from Process Units EIS
in the
Synthetic Organic Chemical
Manufacturing industry-
Background Information
for Proposed Standards
Volume 1A: NationaHmpacts Assessment
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EPA-453/D-92-016a
Hazardous Air Pollutant Emissions
from Process Units in the
Synthetic Organic Chemical
Manufacturing Industry-
Background Information
for Proposed Standards
Volume 1A: National Impacts Assessment
Emission standards Division
U.S. Environmental Protection Agency
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
November 1992
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(DISCLAIMER)
This Report has been reviewed by the Emission Standards Division of
the Office of Air Quality Planning and Standards, EPA, and approved
for publication. Mention of trade names or commercial products is
not intended to constitute endorsement or recommendation for use.
Copies of this report are available through the Library Services
Office (MD-35), U.S. Environmental Protection Agency, Research
Triangle Park, N.C. 27711, or from the National Technical
Information Service, 5285 Port Royal Road, Springfield, VA 22161.
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ENVIRONMENTAL PROTECTION AGENCY
Background Information for Proposed Standards
Hazardous Air Pollutant Emissions from Process Units
in the Synthetic Organic Chemical Manufacturing Industry
Volume 1A: National Impacts Assessment
Prepared by:
_ _
Bruce JordaX ~ - (Date)
Director, /Emission Standards Division
U.S. Environmental Protection Agency
Research Triangle' Park, N.€. 27711
1. The proposed standards would regulate emissions of organic
hazardous air pollutants (HAP's) emitted from chemical
manufacturing processes of the Synthetic Organic Chemical
Manufacturing Industry (SOCMI) . Only those chemical
manufacturing processes that are part of major sources under
Section 112 (d) of the CAA would be regulated. The recommended
standards would reduce emissions of 149 of the organic
chemicals identified in the CAA list of 189 hazardous air
pollutants.
2. Copies of this document have been sent to the following
Federal Departments: Labor, Health and Human Services,
Defense, Office of Management and Budget, Transportation,
Agriculture, Commerce, Interior, and Energy; the National
Science Foundation; and the Council on Environmental Quality.
Copies have also been sent to members of the State and
Territorial Air Pollution Program Administrators; the
Association of Local Air Pollution Control Officials; EPA
Regional Administrators; and other interested parties.
3. The comment period for this document is 90 days from the date
of publication of the proposed standard in the Federal
Register. Ms. Julia Stevens may be contacted at 919-541-5578
regarding the date of the comment period. •
4. For additional information contact:
Dr. Janet Meyer
Standards Development Branch (MD-13)
U.S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
Telephone: 919-541-5299
5. Copies of this document may be obtained from:
U.S. EPA Library (MD-35)
Research Triangle Park, N.C. 27711
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National Technical Information Service (NTIS)
5285 Port Royal Road
Springfield, VA 22161
Telephone: 703-487-4650
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OVERVIEW
Emission standards under Section 112(d) of the Clean Air Act
apply to new and existing sources in each listed category of
hazardous air pollutant emission sources. This background
information document (BID) provides technical information used in
the development of the Hazardous Organic National Emission
Standard for Hazardous Air Pollutants (NESHAP), which will affect
the Synthetic Organic- Chemical Manufacturing Industry (SOCMI).
The BID consists of three volumes: Volume 1A, National Impacts
Assessment (EPA-453/D-92-016a); Volume IB, Control Technologies
CEPA-453/D-92-016b); and Volume 1C, Model Emission Sources
(EPA-453/D-92-016C).
Volume 1A presents a description of the affected industry
and the five kind's of emission points included in the impacts
analysis: process vents, transfer loading operations, equipment
leaks, storage tanks, and wastewater collection and treatment
operations. Volume 1A also describes the methodology for
estimating nationwide emissions, emission reductions, control
costs, other environmental impacts, and increases in energy
usage resulting from a potential NESHAP; and presents three
illustrative sets of potential national impacts and a summary of
the economic analysis. While Volume. 1A provides the overview of
how information on model emission sources and control technology
cost were used to estimate national impacts, Volumes IB and 1C
contain detailed information on the estimation of control
technology performance and costs and model emission source
development.
Volume IB discusses the applicability, performance, and
costs of combustion devices; collection systems and recovery
devices; storage tank improvements; and control techniques for
equipment leak emissions. These control technologies were the
basis of the Hazardous Organic NESHAP impacts analysis. These
control technologies are applicable to emission' points in the
SOCMI and' in other source categories. Methods for estimating
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capital costs and annual costs (including operation and
maintenance costs) of each control technology are presented.
Volume 1C presents descriptions of each kind of emission
point included in the impacts analysis and the development of
model emission sources to represent each kind of emission point
for use in the impacts analysis.. The emission reductions, other
environmental impacts, and energy impacts associated with
application of the control technologies described in Volume IB to
the model emission sources is discussed. For illustrative
purposes, the environmental, energy, and cost impacts that would
results from control of several example model emission sources
are presented.
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TABLE OF CONTENTS
Section paqe
LIST OF TABLES .............. ....... . . x
LIST OF FIGURES ....... ..... ............ xii
ACRONYM AND ABBREVIATION LIST - .......... . . . . . xiii
GLOSSARY. .............. ...... ....." xv '
1.0 INTRODUCTION .... .......... ....... L_!
1 . 1 References ... ..... ... ...... ... 1-4
2.0 BACKGROUND AND AUTHORITY FOR STANDARDS ........ 2-1
2.1 Selection of Pollutants and Source Categories . . 2-5
2.2 Procedures for Development of NESHAP ....... 2-6
2.3 Consideration of Costs. ... .......... 2-9
2.4 Consideration of Environmental Impacts ...... 2-10
2.5 Residual Risk Standards .... ..... .... 2-11
3.0 SOURCE CATEGORY DESCRIPTION AND SOCMI
CHARACTERIZATION, ...... ., ., ... .. .. . ... . . .. ... .. -
3.1 Definition of The Synthetic Organic Chemical
Manufacturing Industry. .... ...... ... 3-2
3.2 Description and Characterization of the Synthetic
Organic Chemical Manufacturing Industry ..... 3-8
3.2.1 Description of the Industry ....... .3-8
3.2.2 Characterization of the Industry ..... 3-11
3.3 Sources of Hazardous Air Pollutant Emissions. . . 3-16
3.3.1 Storage Tanks. ....... ..... .... 3-20
3.3.2 Process Vents. . . . . ........ ...... 3-20
•
3.3.3 Equipment Leaks. ......... ....... 3-21
3.3.4 Wastewater Collection and Treatment
Operations „ ..... .... ...... 3-21
3.3,5, Transfer Loading Operations. . ., .„ ., .. . .. 3-21
3.4 References. . . . „ . .............. 3-22
Vll
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TABLE OF CONTENTS
(CONTINUED)
Section Page
4.0 ESTIMATION METHODOLOGY 4-1
4.1 Industry Characterization Information 4-4
4.1.1 Process Unit and CPP Information . . ... . 4-4
4.1.2 Baseline Control Requirements. ...... 4-5
4.2 Model Emission Source Approach 4-9
4.2.1 Process Vents 4-15
4.2.2 Transfer Loading Operations 4-19
4.2.3 Storage Tanks. 4-23
4.2.4 Wastewater Collection and Treatment
Operations 4-29
4.2.5 Equipment Leaks 4-31
4.3 Estima-tion Methodology for Unmodeied CPP's. . . . 4-34
4.3.1 Estimating Emissions and Control Impacts
for Unmodeied SOCMI CPP's 4-34
4.3.2 Estimating Emissions and Control Impacts
for Non-SOCMI CPP's 4-35
4.4 References 4-36
5.0 NATIONAL IMPACTS 5-1
5.1 Description of National Impacts Analysis. 5-1
5.2 Presentation of National Impacts 5-2
5.2.1 Primary Air Pollutant Impacts 5-3
5.2.2 Cost Impacts 5-6
5.2.3 Other Impacts 5-10
6.0 ECONOMIC ANALYSIS 6-1
6.1 Introduction 6-1
6.2 Representativeness of Sample 6-2
6.2.1 Annual Production and Control Costs. . . . 6-2
6.2.2 Basic Feedstock Chemicals 6-5
6.2.3 Summary 6-5
6.3 Overview of Economic Impacts 6-5
Vlll
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TABLE OF CONTENTS
(CONTINUED J,
Section . Page
6.3.1 Nature of Impacts. 6-5
6.3.2 Price Adjustments and Reduction in
Output . 6_7
6.3.3 Closure 6-8
6.3.4 Process Changes. 6-10
6.3.5 Economic Impacts 6-11
6.3.6 Low Range Impacts. ............ 6-15
6.3.7 Intermediate Range Impacts 6-15
6.3.8 High Range Impacts. ....... 6-16
6.4 Small Business Impacts. 6-16
6.5 Conclusions . ....'.... 6-20
6.6 References. "... 6-22
Appendix A: SOCMI Chemicals. . A-l
Appendix B: Non-SOCMI Equipment Leaks. B-l
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LIST OF TABLES
Table
3-1 Hazardous Air Pollutants Listed in the Clean
Air Act Amendments 3-3
3-2 Geographic Distribution of SOCMI Process Units . . 3-14
3-3 Distribution of Chemical Reaction Types Used in
SOCMI Processes Evaluated for the HON 3-17
4-1 Emission Source Types with Baseline Control
Requirements by State 4-7
4-2 Selected Control Technologies and Their Assumed
Control Efficiencies 4-14
4-3 General Model Process Vents Streams, 4-16
4-4 Model Transfer Loading Racks for Tank Trucks . . . 4-21
4-5 Model Transfer Loading Racks for Tank Cars .... 4-22
4-6 Model Storage Tank Farms 4-25
4-7 Model Unit Parameters 4-32
5-1 National Primary Air Pollution Impacts in the
Fifth Year • 5-4
5-2 National Control Cost Impacts in the Fifth Year. . 5-9
5-3 National Energy Impacts in the Fifth Year 5-12
5-4 National CO and NOX Emission Impacts in the
Fifth Year 5-15
6-1 Distribution of Chemicals by Percentage Cost
Increase and Annual Production (10 MMkg):
TIC Option 6-3
6-2 Selected Chemicals Grouped by the Eight Basic
Feedstock Chemicals from Which They Are Derived. . 6-6
6-3 Number of SOCMI Chemicals Produced on the Same
Site as Facilities Producing Selected Chemicals. . 6-9
6-4 Summary of Market Adjustments 6-12
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LIST OF TABLES
(CONTINUED)
Table Page
6-5 Summary of Percentage Price Increases for the
Selected Chemicals 6-13
6-6 Likelihood of Closure and Process Change Under
Total Industry Controls Option 6-14
6-7 1990 Sales and Employment of Selected SOCMI
Members. ..... 6-17
XI
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LIST OF FIGURES
Figure
3-1
3-2
3-3
3-4
3-5
4-1
4-2
4-3
4-4
5-1
5-2
5-3
5-4
5-5
Page
Origin of 11 Basic Chemicals ........... 3-9
A Sample of Chemicals Originating from Propylene
Oxide 3_10
Industries Consuming SOCMI Products Listed by
SIC Code 3-12
Frequency Distribution of SOCMI Process Unit
Production Capacity 3-18
Common Sources of Emissions from SOCMI
Processes 3-19
Overview of Impacts Analysis 4-2
Process Units in Evaluated States, Default States,
and States Without SOCMI Regulations 4-8
Model Emission Source Approach ... 4-11
Logic Flow Diagram for Storage Tank Farm Model
Assignment ' 4-26
National Baseline Emissions in the Fifth Year. . . 5-5
National Emissions Reductions in the Fifth Year. . 5-7
National Capital and Total Annual Costs in the
Fifth Year 5-11
National Energy Impacts in the Fifth Year 5-14
National CO and NOX Emission Increases Compared
to VOC Emission Reductions in the Fifth Year . . .
5-17
xii
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ACRONYM AND ABBREVIATION LIST
BID
BOB
Btu
CAA
CO
CPP
EO
EPA
GACT
gal
Gg
HAP
HON
Kw-hr
i
Ib
MACT
MMBtu
MMgal
icrniHg
MMkg
MW
NEPA
NESHAP
Pollutants
NOX
NSPS
psia
RFA
RIA
SBA
TIC
SIC
Background Information Document
barrels of oil equivalent
British thermal unit(s)
Clean Air Act
.carbon monoxide
chemical production process
executive order
U.S. Environmental Protection Agency
generally available control technology
gallon(s)
gigagram(s)
hazardous air pollutant
hazardous organic NESHAP
kilowatt hour(s)
liter (s-)
pound(s)
maximum achievable control technology
million British thermal unit(s)
million gallons
millimeter(s) of mercury
million kilograms
megawatt(s)
National Environmental Policy Act
National Emission Standards for Hazardous Air
nitrogen oxides
New Source Performance Standards
pound(s) per square inch
Regulatory Flexibility Act
Regulatory Impact Analysis
Small Business Act
total industry control
standard industrial classification
Xlll,
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ACRONYM AND ABBREVIATION LIST
(CONTINUED)
SOCMI synthetic organic chemical manufacturing industry
tpy ton(s) per year
VOC volatile organic compound
VOHAP volatile organic hazardous air pollutant
yr - year(s)
xav
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GLOSSARY
Chemical production process (GPP)—The specific route,
reaction type, reactants, and process technology used to
produce specific chemicals. A single chemical or chemicals
may be produced by different CPP's,"but this usually occurs at
different facilities.
Control impacts—The emission reductions, control costs, and
secondary impacts associated with applying additional emission
control to an emission source.
Co-product—For the purpose of the HON analysis, a desired
chemical output other than the product.
Emission source type—A type of manufacturing Operation or •
•equipment that can be a source of emissions. For the purposes
of the HON analysis, the five emission source types are
storage tanks, process vents, transfer loading racks,
equipment leaks, and wastewater collection and treatment
operations.
Facility—A collection of all process units and other
operations (e.g., wastewater collection and treatment
operations and transfer loading operations) within a
continuous fenceline, and under common ownership or control at
a specific geographic location.
Finished chemical—SOCMI products that have uses outside the
SOCMI, such,, as- chemicals that are direct consumer products or
are consumed, by other industries.
xv
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Intermediate chemical—Within a CPP, an intermediate chemical
is a chemical that is produced and consumed as part of the
process. Regarding the chemical products of the SOCMI, an
intermediate chemical is one that is primarily used within the
SOCMI to produce more SOCMI chemicals. These are referred to
as SOCMI intermediates within the text. This latter
definition is, in contrast to a finished chemical.
Process unit—The set of process equipment at a specific
geographic location using a specific CPP to produce specific
chemicals.
Product—For the purpose of the HON analysis, the desired
chemical making up the majority of the useful output from a
CPP.
Reactant and raw material—For the purpose of the HON
analysis, these two terms are synonymous and include anything
that is consumed, completely or partially, or is present
during the chemical reaction and is not a solvent.
xvi
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1.0 INTRODUCTION
This volume presents a description of the affected
industry and emission points and description of the
methodology for estimating nationwide emissions, emission
reductions, control costs, impacts to other environmental
media, and increases in energy usage. This volume also
presents three illustrative sets of potential national impacts
and a summary of the economic analysis.
Chapter 2 explains the U. S. Environmental Protection
Agency's (EPA's) statutory authority for development of this
National Emission Standard for Hazardpus Air Pollutants
(NESHAP) and the general process for standards development.
As described in Chapter 2, part of the standards development
process is the estimation of model plant and national impacts
associated with potential regulations.
Chapter 3 describes the types of synthetic organic
chemical manufacturing industry (SOCMI) chemical production
processes (CPP's), and emission points that could be subject
to the Hazardous Organic NESHAP (HON). It also provides
specific information on which hazardous air pollutants (HAP's)
were considered in the impacts analysis. A brief description
of the SOCMI as defined for this rulemaking is provided to
distinguish it from related industries that were not
considered for the HON. The five emission source types
considered in the impacts analysis are briefly described.
These are: storage tanks, process vents, equipment leaks,
wastewater collection ajid treatment operations, and transfer
loading operations.
Chapter 4 presents the methodology used to estimate
emissions and national impacts resulting from the control of
' 1-1
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emissions from SOCMI sources. This involves estimation of
"baseline" emissions, which represent the current levels of
emissions (taking into account applicable State and Federal
regulations) in the absence of the HON. The procedures used
to determine the baseline emissions are described. Costs and
emission reductions associated with the application of
additional control are calculated relative to the baseline.
Because of the large number of SOCMI process units and
the lack of site-specific emissions information on each
process unit, a model emission source approach was used to
estimate impacts. Chapter 4 describes this approach. The
collection of information (such as location, chemical
reactants and products, and production capacity) on each SOCMI
process unit was' attempted, and this information was assembled
into a data base. Model emission sources were developed for
each of the five emission source types. These models were
matched with the process units in the data base to estimate
baseline emissions. Applicable control technologies for each
of the five emission source types were identified and used as
the basis for estimating the potential emission reductions,
control costs, impacts to other environmental media, and
increases in energy usage for each process unit in the data
base. The results were aggregated to a national level.
Further technical details on model emission source
development, control technologies, and detailed example
emission and cost calculations for each emission source type
are included in Volumes IB and 1C of the HON Background
Information Document (BID).1'2
Chapter 5 presents illustrative examples of national
impacts that could result from the application of control to
emission points considered for regulation under the HON. The
maximum impact would result if controls were applied to every
emission point potentially subject to the HON. Impacts for
this total industry control scenario are presented. Impacts
are also presented for two other scenarios where controls are
only applied to certain subsets of emission points. This is
intended to show the range of impacts that might be associated
1-2
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with a regulation. Numerous regulatory alternatives could be
considered and would have impacts within the ranges presented
in Chapter 5'. Impacts that are quantified included HAP and
volatile organic compound (VOC) emission reductions, capital
and annual costs of control, energy usage, and emissions of
nitrogen oxides (NOX) and carbon monoxide (CO). Other
impacts, such as water and solid waste generation impacts, are
discussed qualitatively.
A summary of the economic analysis is presented in
Chapter 6. The economic analysis discusses the cost increase
for production of each chemical under the total industry
control scenario. The percentage price increase and
percentage decrease in output quantity were predicted for a
sample subset of 20 chemicals. Impacts stemming from these
adjustments, including the potential for facility closures and
substitution of one GPP for another are discussed. Finally,
the potential for the HON to impact small businesses is
analyzed. The complete economic analysis is described in the
EPA report "Economic Impact Analysis of the Hazardous Organic
NESHAP."3
1-3
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1.1 REFERENCES
1. .U.S. Environmental Protection Agency. Hazardous Air
Pollutant Emissions from Process Units in the Synthetic
Organic Chemical Manufacturing Industry — Background
Information for Proposed Standards, Volume IB: Control
Technologies. EPA-453/D-92-016b. Research Triangle
Park, NC. November 1992.
2. U.S. Environmental Protection Agency. Hazardous Air
Pollutant Emissions from Process Units in the Synthetic
Organic Chemical Manufacturing Industry — Background
Information for Proposed Standards, Volume 1C: Model
Emission Sources. EPA-453/D-92-016c. Research Triangle
Park, NC. November 1992.
3. U. S. Environmental Protection Agency. Economic Impact
Analysis of the Hazardous Organic NESHAP. Draft.
Research Triangle Park, NC.' November 1992.
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2.0 .BACKGROUND AND AUTHORITY FOR STANDARDS
According to industry estimates, more than
2.4 billion Ibs of toxic pollutants were emitted to the
atmosphere in 1988 ("Implementation Strategy for the Clean Air
Act Amendments of 1990," EPA Office of Air and Radiation,
January 15, 1991). These emissions may result in a variety of
adverse health effects, including cancer, reproductive
effects, birth defects, and respiratory illnesses. Title III
of the Clean Air Act- (CAA) Amendments of 1990 provides the
tools for controlling emissions of these pollutants.
Emissions from both large and small facilities that contribute
to air toxics problems in urban and other areas will be
regulated. The primary consideration in establishing national
industry standards must be demonstrated technology. Before
NESHAP are proposed as Federal regulations, air pollution
prevention and control methods are examined in detail with
respect to their feasibility, environmental impacts, and
costs. Various control options based on different
*
technologies and degrees of efficiency are examined, and a
determination is made regarding whether the various control
options apply to each emission source or if dissimilarities
exist between the sources. In most cases, regulatory
alternatives are subsequently developed that are then studied
by EPA as a prospective basis for a standard. The
alternatives are investigated in terms of their impacts on the
environment, the economics and well-being of the industry, the
national economy, and energy and other impacts. This document
summarizes the information obtained through these studies so
that interested persons will be able to evaluate the
2-1
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information considered by EPA in developing the proposed
standards.
National emission standards for hazardous air pollutants
for new and existing sources are established under Section 112
of the CAA as amended in 1990 [42 U.S.C. 7401 et seq., as
amended by PL 101-549, November 15, 1990]. Section 112
directs the EPA Administrator to promulgate standards that
"require the maximum degree of reduction in emissions of the
hazardous air pollutants subject to this section (including a
prohibition of such emissions, where achievable) that the
Administrator, taking into consideration the cost of achieving
such emission reductions, and any non-air quality health and
environmental .impacts and energy requirements, determines is
achievable ...." The CAA allows the Administrator to set
standards that "distinguish among classes, types, and sizes of
sources within a category or subcategory."
The CAA differentiates between major sources and area
sources. A major source is defined as "any stationary source
or group of stationary sources located within a contiguous
area and under common control that emits or has the potential
to emit considering controls, in the aggregate, 10 tons per
year or more of any hazardous air pollutant or 25 tons per
year or more of any combination of hazardous air pollutants."
The Administrator, however, may establish a lesser quantity
cutoff to distinguish between major and area sources. The
level of the cutoff is based on the potency, persistence, or
other characteristics or factors of the air pollutant. An
area source is defined as "any stationary source of hazardous
air pollutants that is not a major source." For new sources,
the amendments state that the "maximum degree of reduction in
emissions that is deemed achievable for new sources in a
category or subcategory shall not be less stringent than the
emission control that is achieved in practice -by the best
controlled similar source, as determined by the
Administrator." Emission standards for existing sources "may
be less stringent than the standards for new sources in the
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same category or subcategory but shall not be less stringent,
and may be more stringent than—
(A) the average emission limitation achieved by the best
performing 12 percent of the existing sources (for which the
Administrator has emissions information), excluding those
sources that have, within 18 months before the emission
standard is proposed or within 30 months before such standard
is promulgated, whichever is later, first achieved a level of
emission rate or emission reduction which complies, or would
comply if the source is not subject to such standard, with the
lowest achievable emission rate (as defined by Section 171)
applicable to the source category and prevailing at the time,
in the category or subcategory for categories and
subcategories with 30 or more sources, or
(B) the average emission limitation achieved by the best
performing five sources (for which the Administrator has or
could reasonably obtain emissions information) in the category
or subcategory for categories or subcategories with fewer than
30 sources."
The Federal standards are also known as "MACT" standards
and are based on the maximum achievable control technology
previously discussed. The MACT standards may apply to both
major and area sources, although the existing source standards
may be less stringent than the new source standards, within
the constraints presented above. The MACT is considered to be
the basis for the standard, but the Administrator may
promulgate more stringent standards, which have several
advantages. First, they may help achieve long-term cost
savings by avoiding the need for more expensive retrofitting
to meet possible future residual risk standards, which may be
more stringent (discussed in Section 2.7). Second, Congress
was clearly interested in providing incentives for improving
technology. Finally, in the CAA Amendments of 1990, Congress
gave EPA a clear mandate to reduce the health and
environmental risk of air toxics emissions as quickly as
possible.
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For area sources, the Administrator may "elect to
promulgate standards or requirements applicable to sources in
such categories or subcategories which provide for the use of
generally available control technologies or management
practices by such sources to reduce emissions of hazardous air
pollutants." These area source standards are also known as
"GACT" (generally available control technology) standards,
although MACT may be applied at the Administrator's
discretion, as discussed previously.
The standards for HAP's, like the new source performance
standards (NSPS) for criteria pollutants required by Section
111 of the CAA (42 U.S.C. 7411), differ from other regulatory
programs required by the CAA (such as the new source review
program and the prevention of significant deterioration
program) in that NESHAP and NSPS are national in scope (versus
site-specific). Congress intended for the NESHAP and NSPS
programs to provide a degree of uniformity to State
regulations to avoid situations where some States may attract
industries by relaxing standards relative to other States.
States are free under Section 116 of the CAA to establish
standards more stringent than Section 111 or 112 standards.
Although NESHAP are normally structured in terms of
numerical emission limits, alternative approaches are
sometimes necessary. In some cases, physically measuring
emissions from a source may be impossible or at least
impracticable due to technological and economic limitations.
Section 112(h) of the CAA allows the Administrator to
promulgate a design, equipment, work practice, or operational
standard, or combination thereof, in those cases where it is
not feasible to prescribe or enforce an emissions standard.
For example, emissions of VOC's (many of which may be HAP's,
such as benzene) from storage vessels for volatile organic
liquids are greatest during tank filling. The nature of the
emissions (i.e, high concentrations for short periods during
filling and low concentrations for longer periods during
storage) and the configuration of storage tanks make direct
2-4
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emission measurement impractical. Therefore, the MACT or GACT
standards may be based on equipment specifications.
Under Section 112(h)(3), the CAA also allows the use of
alternative equivalent technological systems: "If, after
notice and opportunity for comment, the owner or operator of
any source establishes to the satisfaction of the
Administrator that an alternative means of emission
limitation" will reduce emissions of any air pollutant at
least as much as would be achieved under the design,
equipment, work practice, or operational standard, the
Administrator shall permit the use of the alternative means.
Efforts to achieve early environmental benefits are
encouraged in Title III. For example, source owners and
operators are encouraged to use the Section 112(i)(5)
provisions, which allow a 6-year compliance extension of the
MACT standard in exchange for the implementation of an early
emission reduction program. The owner or operator of an
existing source must demonstrate a 90 percent emission
reduction of HAP's (or 95 percent if the HAP's are
particulates) and meet an alternative emission limitation,
established by permit, in lieu of the otherwise applicable
MACT standard. This alternative limitation must reflect the
90 (95) percent reduction and is in effect for a period of
6 years from the compliance date for the otherwise applicable
standard. The 90 (95) percent early emission reduction must
be achieved before the otherwise applicable standard is first
proposed, although the reduction may be achieved after the
standard's proposal (but before January 1, 1994) if the source
owner or operator makes an enforceable commitment before the
proposal of the standard to achieve the reduction. The source
must meet several criteria to qualify for the early reduction
standard, and Section 112(i)(5)(A) of the CAA provides that
the State may require additional reductions.
2.1 SELECTION OF POLLUTANTS AND SOURCE CATEGORIES
As amended in 1990, the CAA includes a list of 189 HAP's.
Petitions to add or delete pollutants -from this list may be
submitted to EPA. Using this list of pollutants, EPA will
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publish a list of source categories (major and area sources)
for which emission standards will be developed. Within
2 years of enactment (November 1992), EPA will publish a
schedule -establishing dates for promulgating these standards.
Petitions may also be submitted to EPA to remove source
categories from the list. The schedule for standards for
source categories will be determined according to the
following criteria:
11 (A) the known or anticipated adverse effects of such
pollutants on public health and the environment;
(B) the quantity and location of emissions or reasonably
anticipated emissions of hazardous air pollutants that each
category or subcategory will emit; and
(C) the efficiency of grouping categories or
subcategories according to the^pollutants emitted, or the
processes or technologies used."
After the source category has been chosen, the types of
facilities within the source category to which the standard
will apply must be determined. A source category may have
several facilities that cause air pollution, and emissions
from these facilities may vary in magnitude and control cost.
Economic studies of the source category and applicable control
technology may show that air pollution control is better
served by applying standards to the more severe pollution
sources. For this reason, and because there is no adequately
demonstrated system for controlling emissions from certain
facilities, standards often do not apply to all facilities at
a source. For the same reasons, the standards may not apply
to all air pollutants emitted. Thus, although a source
category may be selected to be covered by standards, the
standards may not cover all pollutants or facilities within
that source category.
2.2 PROCEDURE FOR DEVELOPMENT OF NESHAP
Standards for major and area sources must
(1) realistically reflect MACT or GACT; (2) adequately
consider the cost, the non-air quality health and
environmental impacts, and the energy requirements of such
2-6
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control; (3) apply to new and existing sources; and (4) meet
these conditions for all variations of industry operating
conditions anywhere in the country.
The objective of the NESHAP program is to develop
standards to protect the public health by requiring facilities
to control emissions to the level achievable according to the
MACT or GACT guidelines. The standard-setting process
involves three principal phases of activity: (1) gathering
information, (2) analyzing the information, and (3) developing
the standards. During the information-gathering phase,
industries are questioned through telephone surveys, letters
of inquiry, and plant visits by EPA representatives.
Information is also gathered from other sources, such as a
literature search. Based on the information acquired about
the industry, EPA selects certain plants at which emissions
tests are conducted to provide reliable data that characterize
the HAP emissions from well-controlled existing facilities.
In the second phase of a project, the information about
the industry, the pollutants emitted, and the control options
are used in analytical studies. Hypothetical "model plants"
are defined to provide a common basis for analysis. The model
plant definitions, national pollutant emissions data, and
existing. State regulations governing emissions from the source
category are then used to establish "regulatory alternatives."
These regulatory alternatives may be different levels of
emissions control or different degrees of applicability or
both.
The EPA conducts studies to determine the cost, economic,
environmental, and energy impacts of each regulatory
alternative. From several alternatives, EPA selects the
single most plausible regulatory alternative" as the basis for
the NESHAP for the source category under study.
In the third phase of a project, the selected regulatory
alternative is translated into standards, which, in turn, are
written in the form of a Federal regulation. The Federal
regulation limits emissions to the levels indicated in the
selected regulatory alternative.
2-7
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As early as is practical in each standard-setting
project, EPA representatives discuss the possibilities of a
standard and the form it might take with members of the
National Air Pollution Control Techniques Advisory Committee,
which is composed of representatives from industry,
environmental groups, and State and local air pollution
control agencies. Other interested parties also participate
in these meetings.
The information acquired in the project is summarized in
the BID. The BID, the proposed standards, and a preamble
explaining the standards are widely circulated to the industry
being considered for control, environmental groups, other
government agencies, and offices within EPA. Through this
extensive review process, the -points of view of expert
reviewers are taken into consideration as changes are made to
the documentation.
A "proposal package" is assembled and sent through the.
offices of EPA Assistant Administrators for concurrence before
the proposed standards are officially endorsed by the EPA
Administrator. After being approved by the EPA Administrator,
the preamble and the proposed regulation are published in the
Federal Register.
The public is invited to participate in the standard-
setting process as part of the Federal Register announcement
of the proposed regulation. The EPA invites written comments
on the proposal and also holds a public hearing to discuss the
proposed standards with interested parties. All public
comments are summarized and incorporated into a second volume
of the BID. All information reviewed and generated in studies
in support of the•standards is available to the public in a
"docket" on file in Washington, DC. " Comments from the public
are evaluated, and the standards may be altered in response to
the comments.
The significant comments and EPA's position on the issues
raised are included in the preamble of a promulgation package,
which also contains the draft of the final regulation. The
regulation is then subjected to another round of internal EPA
2-8 •
-------
review and refinement until it is approved by the EPA
Administrator. After the Administrator signs the regulation,
it is published as a "final rule" in the Federal Register.
2.3 CONSIDERATION OF COSTS
The requirements and guidelines for the economic
analysis of proposed NESHAP are prescribed by Presidential
Executive Order 12291 (EO 12291) and the Regulatory
Flexibility Act (RFA). The EO 12291 requires preparation of a
Regulatory Impact Analysis (RIA) for all "major" economic
impacts. An economic impact is considered to be major if it
satisfies any of the foil-owing criteria:
1. An annual effect on the economy of $100 million or
more;
2. A major increase in costs or prices for consumers;
individual industries; Federal, State, or local government
agencies; or geographic regions; or
3. Significant adverse effects on competition,
employment, investment, productivity, innovation, or on the
ability of United States-based enterprises to compete with
foreign-based enterprises in domestic or export markets.
An RIA describes the potential benefits and costs of the
proposed regulation and explores alternative regulatory and
nonregulatory approaches to achieving the desired objectives.
If the analysis identifies less costly alternatives, the RIA
includes an explanation of the legal reasons why the less
costly alternatives could not be adopted. In addition to
requiring an analysis of the potential costs and benefits,
EO 12291 specifies that EPA, to the extent allowed by the CAA
and court orders, demonstrate that the benefits of the
.A
proposed standards outweigh the costs and that the net
benefits are maximized.
The RFA requires Federal agencies to give special
consideration to the impact of regulations on small
businesses, small organizations, and small governmental units.
If the proposed regulation is expected to have a significant
impact on a substantial number of small entities, a regulatory
flexibility analysis must be prepared. In preparing this
2-9
-------
•analysis, EPA takes into consideration such factors as the
availability of capital for small entities, possible closures
among small entities, the increase in production costs due to
compliance, and a comparison of the relative compliance costs
as a percent of sales for small versus large entities.
The prime objective of the cost analysis is to identify
the incremental economic impacts associated with compliance
with the standards based on each regulatory alternative
compared to baseline. Other environmental regulatory costs
may be factored into the analysis wherever appropriate. Air
pollutant emissions may cause water pollution problems, and
captured potential air pollutants may pose a solid waste
disposal problem. The total environmental impact of an
emission source must, therefore, be analyzed and the costs
determined whenever possible.
A thorough study of the profitability and price-setting
mechanisms of the industry is essential to the analysis so
that an accurate estimate of potential adverse economic
impacts can be made for proposed standards. It is also
essential to know the capital requirements for pollution
control systems already placed on plants so that the
additional capital requirements necessitated by these Federal
standards can be placed in proper perspective. Finally, it is
necessary to assess the availability of capital to provide the
additional control equipment needed to meet the'standards.
2.4 CONSIDERATION OF ENVIRONMENTAL IMPACTS
Section 102(2)(C) of the National Environmental Policy
Act (NEPA) of 1969 requires Federal agencies to prepare
detailed environmental impact statements on proposals for
legislation and other major Federal actions significantly
affecting the quality of the human environment. The objective
of NEPA is to build into the decision-making process of
Federal agencies a careful consideration of all environmental
aspects of proposed actions.
In a number of legal challenges to standards for various
industries, the United States Court of Appeals for the
District of Columbia Circuit has held that environmental
2-10
-------
impact statements need not be prepared by EPA for proposed
actions under the CAA. Essentially, the Court of Appeals has
determined that the best system of emissions reduction
requires the Administrator to take into account
counterproductive environmental effects of proposed standards
as well as economic costs to the industry. On this basis,
therefore, the Courts established a narrow exemption from NEPA
for EPA determinations.
In addition to these judicial determinations, the Energy
Supply and Environmental Coordination Act of 1974 (PL-93-319)
specifically exempted proposed actions under the CAA from NEPA
requirements. According to Section 7(c)(1), "No action taken
under the Clean Air Act shall be deemed a major Federal action
significantly affecting the quality of the human environment
within the meaning of the National Environmental Policy Act of
1969" (15 U.S.C. 793(c)(l)).
Nevertheless, EPA has concluded that preparing
environmental impact statements could have beneficial effects
on certain regulatory actions. Consequently, although not
legally required to do so by Section 102(2)(C) of NEPA, EPA
has adopted a policy requiring that environmental impact
statements be prepared for various regulatory actions,
including NESHAP developed under Section 112 of the CAA. This
voluntary preparation of environmental impact statements,
however, in no way legally subjects the EPA to NEPA
requirements.
To implement this policy, a separate section is included
in this document that is devoted solely to an analysis of the
potential environmental impacts associated with the proposed
standards. Both adverse and beneficial impacts in such areas
as air and water pollution, increased solid waste disposal,
and increased energy consumption are discussed.
2.5 RESIDUAL RISK STANDARDS
Section 112 of the CAA provides that 8 years after MACT
standards are established (except for those standards
established 2 years after enactment, which have 9 years),
standards to protect against the residual health and
2-11
-------
environmental risks remaining must be promulgated, if
necessary. The standards would be triggered if more than one
source in a category or subcategory exceeds a maximum
individual risk of cancer of 1 in 1 million. These residual
risk regulations would be based on the concept of providing an
"ample margin of safety to protect public health." The
Administrator may also,consider whether a more stringent
standard is necessary to prevent—considering costs, energy,
safety, and other relevant factors—an adverse environmental
effect. In the case of area sources controlled under GACT
standards, the Administrator is not required to conduct a
residual risk review.
2-12
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3.0 SOURCE CATEGORY DESCRIPTION AND SOCMI CHARACTERIZATION
The purpose of this chapter is to describe the SOCMI and
present the results of the characterization performed as part
of the impacts analysis. Section 3.1 lists the HAP's
considered for the impacts analysis for.the HON and explains
how the list was developed. Section 3.2 characterizes the
industry in terms of geographic distribution, reaction types
used, and process unit production capacity. Section 3.3
•
briefly discusses the five sources of HAP emissions from SOCMI
CPP's.
As described in Chapter 1, the impacts analysis
(1) characterized the common emission sources within SOCMI in
terms of baseline emissions and baseline control requirements
and (2) estimated the range of organic HAP emission
reductions, costs, impacts to other environmental media, and
energy usage resulting from the implementation of additional
control. The impacts analysis evaluated those CPP's that
produced as a product or co-product or used as a reactant or
raw material one or more organic HAP's for which information
was available. The control technologies used for the basis of
estimating the impacts of control were judged to achieve the
highest emission reduction and to be universally applicable.
The impacts analysis focused on the CPP;S most likely to emit
HAP's. The impacts of controlling these CPP's are considered
representative of the range of impacts resulting from
controlling other SOCMI CPP's.
3-1
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3.1 DEFINITION OF THE SYNTHETIC ORGANIC CHEMICAL
MANUFACTURING INDUSTRY
For the purposes of the impacts analysis, the SOCMI is
defined as the process units that manufacture or process a
specific set of organic chemicals1. The set of chemicals used
to define SOCMI CPP's was compiled from lists in the NSPS for
reactor processes,2 distillation operations,3 air oxidation
processes, and equipment leaks,5 and was augmented with
chemicals listed in the Industrial Organic Chemical Use
Trees.6 The SOCMI CPP's are those that manufacture or process
these SOCMI chemicals.
Of the 189 HAP's or classes of HAP's included in the CAA
Amendments of 1990, only those organic HAP's that were
determined, based on the analysis, to be emitted by SOCMI
CPP's were included in thf HON impacts analysis. Pesticides,
inorganic compounds, and metal-containing organic compounds
were specifically omitted. Pesticides will be the subject of
a separate regulatory effort. The scope of the HON targets
hazardous organic compounds, and the control technologies
selected as the basis for the HON are best suited to the
control of pure organic compounds. Therefore, inorganic and
metal-containing organic compounds were omitted from the list.
Table 3-1 lists the 189 HAP.'s addressed by the CAA
Amendments. The third column distinguishes the 111 organic
HAP's analyzed for the HON. The impacts analysis identified
the majority of SOCMI chemicals produced by a CPP that (l)
produced as a product or co-product, (2) or used as a reactant
or raw material one or more of the 111 organic HAP's or
classes of HAP's. Production of these chemicals is likely to
emit HAP's. Once identified, these CPP's became the focus of
the HON analysis and information on these CPP's was gathered
to support the estimation of emissions and control impacts.
For the purpose of this discussion, control impacts include
emission reductions, costs, impacts to other environmental
media, and energy usage.
3-2
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TABLE 3-1.
HAZARDOUS AIR POLLUTANTS LISTED IN THE CLEAN AIR
ACT AMENDMENTSa
Chemical or Class Listed ,
In Clean Air Act Amendments Inoroanic
Acetal dehyde
Acetami de
Acetonitrile
Acetophenone
2--Acetyl ami nof 1 uori ne
Acrolein
Acryl ami de
Arylic acid
Acryl onitrile
Ally! chloride
4-Ami nobi phenyl
Aniline
o-Anisidine
Asbestos
Benzene
Benzidine
Benzotri chloride
Benzyl chloride
Bi phenyl
Bis (chloromethyl ) ether
Bis (2-ethyl hexyl) phthalate
(DEHP)
Bromoform
1,3-butadiene
Calcium cyanamide
Caprolactam
Captan
Carbaryl
Carbon disulfide
Carbon tetrachloride
Carbonyl sulfide
Catechol
Chloroacetic acid
2-Chl oroacetophenone
Chi oramfaen
Chlorobenzene
Chi orobenzi late
Chlordane
Chlorine X
Chloroform
Chloromethyl methyl ether
Chloroprene
Cresols/Cresylic acid
(isomers and mixture)
o-Cresol
m-Cresol
p-Cresol
Cumene
2.4-D, salts and esters
ODE
Oiazomethane
Oi benzof urans
l,2-Oibromo-3-chloropropane
Di butyl phthalate
1 , 4-Oi chl orobenzene ( p )
3 , 3-Oi chl orobenzi dene
Dichloroethyl ether
[bis(2-chloroethyl )ether]
1 , 3-Oi chl oropropene
Oraanic
X
X
X
X
X
x.
X
X
X .
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
.X
Analyzed for
HON
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
* X
X
x
X
•X
x
x
x
x
x
x
x
x
x
x
x
x
x
X
3-3
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TABLE 3-1. HAZARDOUS AIR POLLUTANTS LISTED IN THE CLEAN AIR
ACT AMENDMENTS3 (CONTINUED)
Chemical or Class Listed
In Clean A1r Act Amendments Inorganic
Organic
Analyzed for
HON
Dlchlorovos
Diethanolamine
N,N-Oiethyl aniline
(N,N-Dimethylaniline)
Di ethyl sulfate
3.3-Dimethoxybenzidine
Dimethyl aminoazobenzene
3.3'-Dimethyl benzidine
Dimethyl carbamoyl chloride
Dimethyl formamide
1,1-Dimethyl hydrazine
Dimethyl phthalate
Dimethyl sulfate
4,6-D1n1tro-o-cresol, and salts
2.4-Dinitrophenol
2,4-Dinitrotoluene
1,4-Dioxane
(1,4-Diethyleneoxide)
1,2-Di phenylhydrazi ne
1,2-Epoxybutane
Epichlorohydrin
(1-Chloro-2,3-epoxypropane)
Ethyl acrylate
Ethyl benzene
Ethyl carbamate
(Urethane)
Ethyl chloride
(Chloroethane)
Ethylene dibromide
(Dibromoethane)
Ethyl ene di chloride
(,2-01chloroethane)
Ethylene glycol
Ethyl ene inline
(Aziridine)
Ethylene oxide
Ethylene thiourea
Ethyl i dene di chloride
(1,2-Dichloroethane)
Formaldehyde
Glycol ethers0
Heptachlor
Hexachlorobenzene
Hexachlorobutadi ene
Hexachlorocyclopentadi ene
Hexachloroethane
Hexamethylene-1.6-di isocyanate
Hexamethylphosphorami de
Hexane
Hydrazine
Hydrogen chloride
(Hydrochloric acid)
Hydrogen fluoride
(Hydrofluoric acid)
Hydroquinone
Isophorone
Lindane (all isomers)
Haleic anhydride
Hethanol
Hethoxychlor
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
3-4
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TABLE 3-1.
HAZARDOUS AIR POLLUTANTS LISTED IN THE CLEAN AIR
ACT AMENDMENTS3 (CONTINUED)
Chemical or Class Listed
in Clean Air Act Amendments Inorganic
Organic
Analyzed for
HON
Methyl bromide
(bromomethane)
Methyl chloride
(Chloromethane)
Methyl'chloroform
(l',l,l-Trichloroethane)
Methyl ethyl ketone
(2-Butanone)
Methyl hydrazine
Methyl iodide
(lodomethane)
Methyl isobutyl ketone
(Hexone)
Methyl i socyanate
Methyl methacrylate
Methyl tert butyl ether
4,4-Methylene
bi s(2-chloroani 1 i ne)
Methylene chloride
(Dichloromethane)
Methylene diphenyl diisocyanate
(MDI)
4,4-Methylenedi ani 1 i ne
Naphthalene
Nitrobenzene
4-Nitrobiphenyl
4-Nitrophenol
4-Nitropropane
N-Ni troso-N-methylurea
N-Nitrosodimethyl amine
N-Ni trosomorpholi ne
Parathion
Pentachloron i trobenzene
(Quintobenzene)
Pentachlorophenol
Phenol
p-Phenylenedi ami ne
Phosgene
Phosphine
Phosphorus
Phthalic anhydride
Polychlorinated biphenyls
(Aroclors)
Polycylic organic matter1-'
beta-Propiolactone
1,3-Propane sultone
Propionaldehyde
Propoxur
(Baygon)
Propylene dichloride
(1,2-Di chloropropane)
Propylene oxide
1,2-Propylenimine
(2-Methyl aziridine)
Quinoline
Quinone
Styrene
Styrene oxide
2,3,7,8-Tetrachlorodi benzo-p-di oxi n
1,1,2,2-Tetrachloroethane-
X
X
X
X
X.
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
3-5
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TABLE 3-1. HAZARDOUS AIR POLLUTANTS LISTED IN THE CLEAN AIR
ACT AMENDMENTS3 (CONTINUED)
Chemical or Class Listed . Analyzed for
1n Clean Air Act Amendments Inorganic Organic HON
Tetrachloroethylene
(Perch!oroethylene) X X
Titanium tetrachloride X
Toluene X X
2,4-Toluene diamine . XX
2,4-Toluene dilsocyanate ' X X
o-Toluidine X X
Toxaphene
(chlorinated camphene) X
1,2,4-Trichlorobenzene • x X
1,1,2-Trichloroethane ' X X
Trichloroethylene X X
2,4,5-Trichlorophenol X X
2,4,6-Trichlorophenol X
Triethyl amine X X
Trlfluralin X
2.2,4-Trimethylpentane X X
Vinyl acetate X X
Vinyl bromide X
Vinyl chloride X X
Vinylidene chloride
(1,1-Dichloroethylene) 'X X
Xylenes (isomers and mixtures) X X
o-Xylenes X X
m-Xylenes X X
p-Xylenes X X
Antimony Compounds6 '
Arsenic Compounds6
(inorganic including arsine)
Beryllium Compounds8
Cadmium Compounds X
Chromium Compounds X
Cobalt Compounds6
Coke Oven Emissions8
Cyanide Compounds8-' X
Lead Compounds8
Manganese Compounds X
Mercury Compounds8
Fine mineral fibersS x
Nickel Compounds • X
Radionuclides
(including radon)" X
Selenium Compounds8
ffrom Reference 7.
bFor all listings containing the word "Compounds" and for glycol ethers, the following applies: Unless
otherwise specified, these listings are defined as including any unique chemical substance that contains
the named chemical (i.e., antimony, arsenic) as part of that chemical's infrastructure.
clncludes mono- and di- ethers of ethylene glycol, diethylene glycol, and triethylene glycol
R-(OCH2CH2)n - or where:
n » 1, 2, or 3
R * alkyl or aryl groups
R' « R, H, or groups which, when removed, yield glycol ethers
with the structure: R-(OCH2CH)n -OH.
Polymers are excluded from the glycol category.
"Includes organic compounds with more than one benzene ring, and which have a boiling point greater than
or equal to 100 "C.
^Compound group whose members can be either inorganic or organic.
fy'CN where X = H'or any other group where a formal dissociation may occur. For example RCN or Ca(CN)2.
3-6
-------
TABLE 3-1. HAZARDOUS AIR POLLUTANTS LISTED IN THE CLEAN AIR
ACT AMENDMENTS3 (CONCLUDED)
Chemical or Class Listed Analyzed for
in Clean Air Act Amendments Inorganic Organic HON
Slncludes mineral fiber emissions from facilities manufacturing or processing glass, rock, or slag
fibers (or other mineral derived fibers) of average diameter 1 fen or less.
"A type of atom that spontaneously undergoes radioactive decay.
3-7
-------
Appendix A lists all of the SOCMI chemicals and indicates
which NSPS regulated each chemical. This serves to illustrate
the historical record of EPA's regulatory actions on the
SOCMI. Appendix A also indicates which chemicals were part of
the HON impacts analysis. Those CPP's in which an organic HAP
was used only as a solvent to manufacture a SOCMI chemical
were not included in the impacts analysis. The use of organic
HAP's as solvents will be evaluated for possible regulation
under a separate regulatory effort.
3.2 DESCRIPTION AND CHARACTERIZATION OF THE SYNTHETIC ORGANIC
CHEMICAL MANUFACTURING.INDUSTRY
3.2.1 Description of the Industry
The SOCMI can be represented as an expanding system of
production stages producing a multitude of organic chemicals
from 11 basic chemicals. As illustrated in Figure 3-1,
refineries, natural gas plants, and coal tar distillation
plants represent the first stage of a chemical industry which
supplies the 11 basic chemicals utilized by the SOCMI. The
SOCMI consists of the remaining stages of this expanding
production system. Within the SOCMI, the 11 basic chemicals
are processed through one or more CPP's to produce
intermediate and finished chemicals.
Figure 3-2 presents a portion of one expanding production
system of the SOCMI—a set of chemicals originating from
propylene oxide. In addition to illustrating the variety of
chemicals produced from a single chemical, the figure shows
that there are multiple means of manufacturing some chemicals."
For example, the production of allyl alcohol is 'possible using
three different raw materials. The figure also illustrates
how a family of chemicals can be produced sequentially from
one chemical (propylene oxide). Generally, there is a shift
from high-volume production of SOCMI intermediates at the
front end of the chemical family to low-volume production of
finished chemicals (e.g., ethyl acrylate) at the farthest end
of the chemical family.
Organic chemicals are produced at a wide range of
facilities, from large facilities manufacturing a few
3-8
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3-9
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chemicals in large volumes, to smaller facilities
manufacturing many different finished chemicals in smaller
volumes. Facilities producing chemicals at the end of a
chemical family are usually smaller operations that produce a
variety of closely-related finished chemicals.
The products of the SOCMI are used in many different
industrial markets. The industries that consume the majority
of SOCMI products are shown in Figure 3-3, with their
associated Standard Industrial Classification (SIC) codes.
Many SOCMI chemicals serve as the raw materials for deriving
non-SOCMI products such as plastics, synthetic rubbers,
fibers, protective coatings, and detergents. Few SOCMI
chemicals have direct consumer uses. The HON impacts analysis
considered only the production of SOCMI chemicals and did not
cover the production of the non-SOCMI products.*
3.2.2' Characterization of the Industry
In previous standards-setting programs, the EPA has
characterized the SOCMI as a group of process units
manufacturing or processing one or more chemicals included' in
a specific list. This approach has also been used for the HON
analysis. There were 419 chemicals included in the impacts
-analysis. Each one of these is manufactured by a CPP that
produces an organic HAP (e.g., the listed chemical itself or a
co-product) or uses an organic HAP as a reactant or raw
material.
Of these 419 chemicals included in the impacts analysis,
complete information useful in estimating emissions and
control impacts was available for 219 chemicals. These data
provide sufficient representation of the SOCMI. The 219
chemicals account for more than 50 percent of the listed SOCMI
chemicals. Furthermore, the 219 chemicals for which complete
information was gathered represent 97 percent of the estimated
86,113 Gg/yr total production capacity for the SOCMI (as
defined for this analysis). Because emissions from most
sources can be related to production rate, accounting for most
3-11
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3-12
-------
of the total SOCMI production capacity will thereby account
for most of the emissions. Extrapolation to those chemicals
for which infprmation was incomplete was judged adequate for
the impacts analysis for the following reasons: First, the
CPP's for the uncharacterized chemicals are likely to have the
same emission source types as those that were analyzed.
Second, the control impacts (costs, emission reductions, and
secondary impacts) associated with control of these
uncharacterized sources were judged to be within the range of
control impacts for those that were analyzed.
The SOCMI can also be characterized by geographic
distribution. Information on the geographic distribution was
important in estimating emissions and control impacts because
the location of the process units indicated which States
should be analyzed to determine current levels of control and
to establish baseline control requirements. In the absence of
Federal regulations or guidelines, State regulations specify
the control requirements or emission levels allowed for
various industries.
Table 3-2 presents the geographic distribution of those
SOCMI process units that were characterized as part of the HON
impacts analysis. For the purpose of the impacts analysis,
each combination of CPP and geographic location was counted as
a process unit. For example, where industry characterization
information identified the production of chemical 'X1 at
location 'Y1, that was identified as a single process unit. A
large percentage of the total number of process units in the
SOCMI was found in only a few states, with Texas and.Louisiana
having the greatest number. Specifically, more than
70 percent of the SOCMI process units are located in only nine
States. Table 3-2 shows that only 40 of the 50 States have
SOCMI process units, and 18 of the 40 States have less than
1 percent of the national total number of process units.
Thus, it was not necessary to analyze all States for baseline
control requirements to support the estimation of emissions
and control impacts..
3-13
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TABLE 3-2. GEOGRAPHIC DISTRIBUTION OF SOCMI PROCESS UNITS3
State
Texas
Louisiana
New Jersey
West Virginia
Illinois
North Carolina
Tennessee
Kentucky
Michigan
Pennsylvania
Alabama
California
Kansas
Ohio
New York
Indiana
South Carolina
Mississippi
Virginia
Delaware
Washington
Wisconsin
Arizona
Florida
Oregon
Maryland
Missouri
Oklahoma
Connecticut
Number of Process
Units*5
251
115
56
33
26
20
18
17
17
16
15
15
14
14
13
9
8
7
7
6
6
6
5
5
5
4
4
4
3
Percentage of
National Total
34
16
8
5
4
3
2
2
2
2
2
2
2
2
2
1
1
*c
*
*
*
*
*
*
*
*
*
*
*
3-14
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TABLE 3-2.
GEOGRAPHIC DISTRIBUTION OF SOCMI PROCESS UNITSa
(CONCLUDED)
State
Georgia
Massachusetts
Minnesota
Montana
New Hampshire
New Mexico
Number of Process
Units*3
3
2
2
1
1
1
Percentage of
National Total
*
*
*
*
*
*
aFrom Reference 9.
^ number of process units = 729. Locations were not
available for six process units.
c* = Less than 1 percent of total process units.
3-15
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The SOCMI can also be characterized by the types of
chemical reactions within a process. There were three groups
of chemical reaction types considered for the HON analysis:
(1) those from the SOCMI Reactor Processes NSPS, (2) those
from the Air Oxidation Processes NSPS, and (3) an unspecified
reaction to catch any reaction types not in the other two
groups (Table 3-3). The frequency of chemical reaction type
is also shown in Table 3-3. The most common of the specified
reaction types was halogenation.
Finally, the SOCMI has been characterized in terms of
production capacity and production rate. The difference
between production capacity and production rate is capacity
utilization. Without complete information for capacity
utilization, capacity can be used as an indicator of rate. As
previously stated, this information was important because
emissions generally are closely tied to production rate.
Figure 3-4 shows that the production capacities for SOCMI
process units used in the analysis range from less than
20 Gg/yr (22 million tpy) to greater than 600 Gg/yr
(660 million tpy). The largest process unit had a production
capacity of 1227 Gg/yr (1.35 million tpy). There are many
small process units manufacturing small volumes of finished
chemicals and fewer large process units manufacturing high
volume SOCMI intermediates. It was judged that the complete
range of production volumes for SOCMI process units have been
included in this evaluation.
3.3 SOURCES OF HAZARDOUS AIR POLLUTANT EMISSIONS
Figure 3-5 illustrates the five types of HAP emission
sources that are commonly found at SOCMI facilities: storage
tanks, process vents, equipment leaks, wastewater collection
and treatment operations, and transfer loading operations.
The HON impacts analysis evaluated the impacts of controlling
emissions from these sources using conventional emission
reduction technologies. Each emission source type is briefly
described below. Volume 1C of the HON BID contains more
detailed descriptions of each emission source type.
3-16
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TABLE 3-3. DISTRIBUTION OF CHEMICAL REACTION TYPES USED
IN SOCMI PROCESSES EVALUATED FOR THE HONa
Reaction Type
Frequency of Use in CPP's
(percentage)
Unspecified
Halogenation
Air Oxidation
Hydrolysis
Hydrogenation
Esterification
Alkylation
Condensation
Dehydrohalogenation
Dehydrogenation
Nitration
Sulfonation
Carbonylation
Hydrohalogenation
Catalytic Reformation
Hydrodimerization
Oxidation
Hydroformylation
Oxyacetylation
32.8
13.6
9.0
7.9
6.2
5.1
3.4
3.4
3.4
2.8
2.3
2.3
1.7
1.7
1.1
1.1
1.1
0.6
0.6
aFrom Reference 9.
3-17
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3-19
-------
3.3.1 Storage Tanks
Storage tanks can contain chemical raw materials,
products, and co-products. Different types of tanks are used
to store various types of chemicals. Those with vapor
pressures greater than 14.7 psia (gases) are stored in
pressurized vessels that are not vented to the atmosphere
during normal operations. Liquids (chemicals with vapor
pressures of 14.7 psia or less) are stored in horizontal,
fixed roof, or floating roof tanks, depending on chemical
properties and volumes to be stored. Liquids with vapor
pressures greater than 11 psia are typically stored in fixed
roof tanks that are vented to a control device. Volatile
chemicals with vapor pressure up to 11 psia are usually stored
in floating roof tanks because such vessels have lower
emission rates than fixed roof -.tanks within this vapor
pressure range.
Emissions from storage tanks typically occur as working
losses. As a storage tank is filled with chemicals, VOC-laden
vapors inside the tank become displaced and can be emitted to
the atmosphere. Also, diurnal temperature changes result in
breathing losses of VOC-laden vapors from storage tanks.
3.3.2 Process Vents
Process vent emissions occur from reactor and air
oxidation process units, and from the associated product
recovery and product purification devices. Product recovery
devices include condensers, absorbers, and adsorbers used to
recover products or co-products for use in a subsequent
process, for use as recycle feed, or for sale. Product
purification devices include distillation operations.10
The process vent emissions characterized by the HON
impacts analysis are from reactor and air oxidation process
units and the associated distillation operations. Reactor
processes are unit operations where one or more chemicals are
combined to form new organic compounds. Air oxidation
processes are unit operations that combine air with one or
more compounds to form new organic compounds. Distillation
operations separate products, co-products, and reactants and
3-20
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are used in concert with reactor or air oxidation process
units.
""-••s,
3.3.3 Equipment Leaks
Equipment leaks are releases of process fluid or vapor
from process equipment. These releases occur primarily at the
interface between connected components of equipment. The
equipment analyzed in the RON analysis includes pumps,
compressors, process valves, pressure relief devices, open-
ended lines, sampling connections, flanges and other
connectors, agitators, product accumulator vessels, and
instrumentation systems.
3.3.4 Wastewater Collection and Treatment Operations
In the manufacture of some chemicals, wastewater streams
containing organic compounds are generated. Sources of
wastewater include: water formed during the chemical reaction
or used as a reactant in a process; water used to wash
impurities from organic products 'or reactants; water- used to
cool organic vapor streams; and condensed steam from vacuum
vessels containing qrganics.11 Organic compounds in the
wastewater can volatilize and be emitted to the atmosphere
from wastewater collection and treatment units if these units
are open or vented to the atmosphere. Potential sources of
HAP emissions associated with wastewater collection and
treatment -systems include drains, manholes, trenches, surface
impoundments, oil/water separators, storage and treatment
tanks, junction boxes, sumps, and basins.
3.3.5 Transfer Loading Operations
Chemical products can be transported by barges, tank
cars, or tank trucks. Chemicals are transferred to these
vehicles through a loading rack, which can have multiple
loading arms for connection to several transport vehicles.
Emissions can occur during loading operations when residual
vapors in transport vehicles and transfer piping are displaced
or when the chemicals being loaded vaporize and are displaced.
The HON impacts analysis addresses only emissions from
the loading, of, tank trucks and tank cars.. Marine vessels are
being studied, under a separate regulatory effort.
3-21
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3.4 REFERENCES
1. Memorandum from King, B. S., Radian Corporation, to
Meyer, J. S., EPA/SDB. RON SOCMI list analysis.
February 14, 1992.
2. Proposed Standards of Performance for SOCMI Reactor
Processes. Federal Register, Vol. 55, No. 126,
pp. 26953-70. Washington, DC. Office of the Federal
Register." June 29, 1990.
3. Code of Federal Regulations, Title 40, Part 60,
Subpart NNN. Standards of Performance for SOCMI
Distillation Operations. Washington, DC. U. S.
Government Printing Office. June 29, 1990.
4. Code of Federal Regulations, Title 40, Part 60,
Subpart III. Standards of Performance for SOCMI Air
Oxidation Processes. Washington, DC. U. S. Government
Printing Office. June 29,- 1990.
5. Code of Federal Regulations, Title 40, Part 60,
Subpart W, as amended May 30, 1984. Standards of
Performance for Equipment Leaks of VOC in SOCMI.
Washington, DC. U. S. Government Printing Office.
October 18, 1983.
6. Meserole, N. P., P. W. Spaite, and T. A. Hall.
Industrial Organic Chemical. Use Trees. Prepared for
U. S. Environmental Protection Agency, Office of Research
and Development. Cincinnati, OH. Publication No.
DCN 83-211-030-09-08. October 1983.
7. Memorandum from King, B. S., Radian Corporation, to HON
project file. February 14, 1992. Classification of
organic HAP's.
8. U. S. Environmental Protection Agency. Distillation
Operations in Synthetic Organic Chemical Manufacturing
Industry—Background Information for Proposed Standards.
EPA-450/3-83-005a. Research Triangle Park, NC.
December 1983. p. 3-3.
9. Memorandum from King, B. S., Radian Corporation, to
Meyer, J. S., EPA/SDB. HON SOCM-I characterization.
February 14, 1992.
10. U. S. Environmental Protection Agency. Reactor Processes
in Synthetic Organic Chemical Manufacturing Industry—
Background Information for Proposed Standards. EPA
450/3-90-016 Research Triangle Park, NC. June 1990.
p. 3-7.
3-22
-------
11. U. S. Environmental Protection Agency. Industrial
Wastewater Volatile Organic Compound Emissions—
Background Information for BACT/LAER Determination.
EPA-450/3-90-004. Research Triangle Park, NC.
January 1990. pp. 3-1 through 3-2.
3-23
-------
-------
4.0 ESTIMATION METHODOLOGY
As part of the rulemaking process, EPA estimates the
quantity of emissions from the affected industry in the
absence of national standards (referred to as the baseline
case) and also potential emission reductions under alternative
control scenarios.• Studies are conducted to estimate and
evaluate the impacts of these different control scenarios on
the economics of the industry and on the national economy, on
the environment, and on energy consumption. These estimates
are developed for representative process units and for the
total nationwide industry. Collectively these estimates are
referred to as the "impacts" of the standard. From the
alternative control scenarios evaluated, EPA selects the most
plausible alternative that meets the criteria enumerated in
Section 112 (d) of the Clean Air Act, as amended in 1990. For
example, the cost of achieving emission reductions, non-air
environmental impacts, and energy requirements are to be
considered in selecting the alternative. This chapter
describes the methodology used to estimate both the process
unit and national impacts for the HON analysis.
Figure 4-1 illustrates the steps of the impacts analysis
and points the reader to the particular section of this BID '
volume that discusses each step. While this chapter focuses
on the estimation of emissions and control impacts, Figure 4-1
includes steps discussed in Chapters 3 (Source Category
Description and SOCMI Characterization) and 5 (National
Impacts) of this BID volume to better illustrate how the
estimation methodology fits into the entire impacts analysis.
For the purpose of this discussion, control impacts include
4-1
-------
Chapter 3
Create SOCMI Characterization
Data Base with Data on each
Chemical Production Process and
the Associated Process Units
there -Section 4.1
sufficient information
on GPP & the associated
process units to assign
model emission
sources?
Assign Model Emission Sources for
Process Vents, Storage Tanks, Transfer .
Loading Operations, Wastewater Operations,
and Equipment Leaks to CPP's and
Associated Process Units
Section 4.2
Section 4.3
Estimate Baseline Emissions
and Control Impacts for
each Model Emission Source
at a Process Unit
Develop Default Value
for Scaling Unmodelled
Process Units to
National Impacts
Chapter 5
National Impacts
Figure 4-1. Overview of Impacts Analysis
4-2
-------
emission reductions, costs, impacts to other environmental
media, and energy usage.
Briefly, the impacts analysis attempted to collect
information on and estimate emissions and control impacts for
every process unit in the country using a SOCMI chemical
production process (CPP). Where possible, a model emission
source approach was used to estimate emissions and control
impacts for each of the five emission source types (process
vents, storage tanks, transfer loading operations, wastewater
collection and treatment operations, and equipment leaks)
present at a given process unit. To quantify emissions and
control impacts without using an approximation such as a model
emission source approach, emissions and control impacts would
have to be examined for each SOCMI process unit in the country
or at least a significant' number of process units. Because
this detailed information was not available, model emission
sources were developed for the five emission source types to
represent the range of emissions and operating conditions
likely to be found within the SOCMI. These model emission
sources served as the basis for estimating emissions and
impacts. Estimates of emissions and control impacts developed
using the model emission source approach were based on
average, representative or typical operations. Thus, the
estimates do not reflect the emissions or control impacts that
wpuld be observed at any particular process unit. Instead,
estimates developed for process units- collectively provide a
reasonable estimate of national impacts that could be used for
making regulatory decisions. The model emission source
approach is described in this chapter.
Where it was not possible to use a model emission source
approach due to information limitations, estimates of
emissions and impacts were not made for individual process
units. Instead, a scaling factor, based on the process unit
estimates that could be made, was used to account for the
remaining process units.
This chapter is organized in the following manner.
Section 4.1 describes the industry characterization required
4-3
-------
for implementing the model emission source approach. In
particular, Section 4.1.1 discusses the specific information
about process units and CPP's that were used during model
assignment and emission estimation. Section 4.1.2 describes
the approach for determining the baseline control requirements
for SOCMI process units.1 Because the same procedure was used
to determine baseline control requirements for all five
emission source types, the description is not repeated for
each emission source type. Section 4.2 describes the model
emission source approach and has subsections focusing on each
emission source type. Section 4.3 describes how the unmodeled
CPP's and their process units were accounted for in scaling
national impacts. Section 4,3 also identifies the non-SOCMI
processes included as part of the equipment leaks negotiated
regulation. For the seven non-SOCMI processes that are
included in the negotiated regulation for equipment leaks,
emissions and control impacts were estimated as described in
Appendix B of this volume.
4.1 INDUSTRY CHARACTERIZATION INFORMATION
The SOCMI characterization includes information about
each process unit in the country using a SOCMI CPP.2 In
addition, the baseline control requirements to which these
process units would be subject were determined and included in
the SOCMI characterization data base.1 Baseline control
requirements are defined in terms of specific applicability
(i.e., physical description of emission points required to
apply additional control) and the control requirements for
applicable State and Federal regulations. Control
requirements can be defined in terms of a required emission
reduction efficiency, a specific control technology, or both.
All of this information was compiled and placed in the
Framework. The Framework refers to the system of data bases
and computer programs developed to support the estimation of
emissions and control impacts for the HON.
4.1.1 Process Unit and CPP Information
Two types of information related to process units were
required -for evaluation using the model emission source
4-4
-------
approach: (l) production information, including production
capacity and "the production rate pf the process unit, and
(2) the geographic location of a process unit. Production
information was important for' sizing control equipment, and
influenced capital costs and annual costs of control as well
as emissions. The prpduction information was used to scale up
(or down) those model emission source characteristics provided
on a production basis (e.g., megagram of HAP emissions per
megagram of production). Those characteristics that were
provided as part of the model emission source on a production
basis were (1) HAP and VOC emissions and flow rate for model
process vent streams and (2) flow .rate for model wastewater
streams. Production capacity and production rate were also
used to determine the potential and actual amount of a given
chemical that was stored or transferred. Geographic location
was needed to determine baseline control requirements from
State regulations.
Three types of information concerning CPP's were required
before model emission sources could be assigned to a process
unit: chemical reaction type, chemical reaction equation, and
process description. The chemical reaction type was used in
assigning those model process vent streams representing
reactor emissions. The chemical reaction equation was needed
to identify the reaction constituents associated with a given
GPP and to provide their stoichiometric relationship to the
product (e.g., kilogram of raw material per kilogram of
product). This information, in conjunction with chemical
reaction yield information, was used to identify the chemicals
and amount of each that was stored or transferred and to
identify the chemicals likely to be present in any wastewater
streams. Finally, the process description was used to
identify process equipment pieces likely to generate
wastewater and also the type of distillation columns used
(vacuum or nonvacuum).
4.1.2 Baseline Control Requirements
The baseline represents the current level of control in
the absence of the HON regulation. Baseline control
4-5
-------
requirements were considered for two reasons. First, they
were considered to avoid overestimating the existing
emissions. Second, they were considered to ensure that
control impacts were 'calculated only for those emission points
where additional control was required. When baseline control
requirements were equivalent in stringency to the control
level selected for the HON, control impacts were calculated to
be zero.
Because specific control information for process units
was not available, State and Federal regulations were used as
the basis for determining baseline control requirements. It
was assumed that all emission points would be in compliance
with applicable State and Federal regulations. However, not
all baseline control requirements applicable to SOCMI process
units were included in this analysis because site-specific
information concerning controls that have been applied for
reasons other than State or Federal regulations was not
available.
Regulations from nine States (listed in Table 4-1) were
evaluated in detail to determine baseline control requirements
for those States' regulations. Figure 4-2 illustrates that
more than 70 percent of the SOCMI process units that were
evaluated using the model emission source approach are located
in these nine States. The remaining States were assigned
either Federal baseline control requirements (applicable
NESHAP) only or both default State baseline control
requirements and Federal baseline control requirements. The
17 States having regulations for the SOCMI that were not
evaluated in detail were assigned default baseline control
requirements based on the regulations for Kentucky,
Pennsylvania, and Michigan. These 17 States contain
approximately 12 percent of the SOCMI process units in the
Framework. The 23 States with no regulations for the SOCMI
(representing approximately 15 percent of the SOCMI process
units in the Framework) were assigned baseline control
requirements based on Federal regulations only. Two NESHAP
were reviewed for baseline control requirements; they were the
4-6
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600
500 -
400 -
1
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"5
200 -
100 -
Ohio
California
Pennsylvania
.Michigan
Kentucky
Illinois
New Jersey
Louisiana
Texas
Analyzed Default
Baseline Control Requirements
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SOCMI Regulations
Figure 4-2. Process Units in Evaluated States, Default
States, and States Without SOCMI Regulations
(Only includes process units that used model emission source
approach)
4-8
-------
vinyl chloride and benzene NESHAP. The vinyl chloride NESHAP
affected process vents and wastewater operations. The benzene
NESHAP affected transfer loading operations, wastewater
operations, and storage tanks. The control requirements of
these two NESHAP were applied to all applicable process units
as required, regardless of location. Based on these data,
baseline control requirements are considered to be adequately
represented in the HON analysis.
Table 4-1 indicates those emission source types that are
regulated in the analyzed States and the emission source types
that are assumed to be regulated under the default assignment.
Generally, States with higher numbers of process units had
some level of control required at baseline for SOCMI emission
sources, although air emissions from wastewater operations
were not regulated in any States.
The State regulations were evaluated to determine
(1) specific applicability, (2) required emission reductions
(e.g., 95 percent), and (3) required control devices (where
specified). Two assumptions were made to facilitate
interpretation. First, it was assumed that all SOCMI sources
were in compliance with applicable State and Federal
regulations. Second, because no information was available to
indicate differently, the minimum acceptable level of control
required by the regulation was selected as the baseline
control requirement. For example, a given State may require
one of the following controls on all storage tanks with a
capacity of 20,000 gal (75,800 £) or greater storing a
. chemical with a vapor pressure of 1.5 psia (77.5 mm Hg) or
greater: (1) use of an internal floating roof, (2) use of a
90-percent efficient vapor control system, or (3) use of a
submerged fill pipe. A submerged fill pipe is the least
stringent .control technique and, therefore, was selected as
the baseline control requirement for the HON. analysis.
4.2 MODEL EMISSION SOURCE APPROACH
The model emission source approach was used for those
CPP's and the associated process units that were well-defined
by the industry characterization (described in Section 4.1)
^
-------
Both "process unit" and "CPP" are defined in the glossary for
this BID volume. Process units and CPP's are related in that
a process unit uses a specific CPP to produce a given chemical
or set of chemicals. Therefore, to estimate emissions and
control impacts for a given process unit, the CPP being used
at that process unit must be known.
The model emission source approach has five steps:
(1) Development of model emission sources (which is
described in detail in Volume 1C of the BID);
(2) Assignment of model emission sources to the process
units represented in the Framework;
(3) Estimation of baseline emissions, accounting for
baseline control requirements from applicable State
and Federal regulations;
(4) Assignment of selected control technologies to model
emission sources not already controlled to the level
that could be achieved by control technologies
considered for the HON; and
(5) Estimation of control impacts (e.g., emission
reduction, cost, and energy usage).
These five steps are shown in Figure 4-3. Chemical production
processes for which this approach could be used are referred
to here as "modeled CPP's."
The first step of the five-step approach was the
development of model emission sources. Each of the five
emission source types were modeled differently because of the
inherent differences in the emission mechanisms and the
selected control technologies. Volume 1C of this BID
describes the model emission sources and their development.
The five emission source types analyzed for the HON were
modeled as follows:
• Process vents were represented by model process vent
streams (i.e., vent stream characteristics at the
exit of the product recovery device);
4-10
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Identify Emission Source
Types Present at
Individual Process Units
Develop Model
Emission Sources
Industry
Characterization
Assign Model Emission
Sources to Each
Identified Emission Point
Stepl
Step 2
Estimate Baseline
Emissions
Could
Additional Control
be Required by
the RON?
Assign Control
Technology
Step 4
StepS
Estimate Impacts
StepS
Figure 4-3. Model Emission Source Approach
4-11
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• Transfer loading operations were represented by
model loading racks;
• Storage tanks were represented by model storage tank
farms;
• Wastewater collection and treatment operations were
represented by model wastewater streams (i.e.,
stream characteristics at. the point of wastewater
generation); and
• Equipment leaks were represented by model process
units.
The differences among the model emission sources were most
apparent in the model characteristics that were provided to
support the estimation"of emissions and control impacts.
The second and third steps were assignment of model
emission sources to process units in the Framework and
estimation of baseline emissions. Within this chapter, the
sections addressing the five emission source types (i.e.,
Sections 4.2.1 through 4.2.5) describe the specific industry
characterization information required, the model emission
source characteristics provided, and application of the
baseline control requirements as they relate to model
assignment and estimation of baseline emissions. The specific
methods used to estimate emissions for each emission source
type (e.g., the use of equations from the EPA report AP-42 to
estimate storage tank emissions ) are described in appendices
to Volume 1C of the BID.
The fourth and fifth steps are the assignment of control
technologies and calculation of control impacts. Costs,-
emission reductions, energy usage, and NOX and CO emissions
were quantified as part of the impacts analysis, while solid
waste generation and water pollution were considered on a
qualitative basis. The specific approach used to estimate
costs is presented in appendices to Volume IB of the BID. The
appendices to Volume 1C of the BID detail the methods used to
estimate emission reductions and secondary impacts. Control
impacts were determined for each model emission source at a
process unit that did not meet the selected control level
4-12
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at baseline and therefore might be required by the HON to
implement additional control.
Specific control technologies were analyzed to estimate
control impacts of the HON. Table 4-2 presents the selected
control technology or set of control technologies for each
emission source type and their control efficiencies. Each
control technology or set of control technologies selected for
the HON analysis was the most stringent that was universally
applicable to the specific emission source type for SOCMI
CPP's. The selected control technologies and others were
evaluated for emission reduction efficiencies and
applicability. However, no other control technologies were
found to be more stringent and universally applicable than
those chosen. For example, there were other technologies
(e.g., carbon adsorption) for controlling process vents that
on a site-specific basis may have achieved the same control
level as combustion (98 percent emission reduction). However,
this level of performance could not be achieved in all
applications. Further, each control technology chosen has
been used in past rulemakings for all or part of the SOCMI.
Because in some cases more than one control technology
was applicable to an emission source type, emission stream
characteristics and costs were considered to select the
appropriate control technology for a particular model emission
source. This is discussed for each emission source type in
the following subsections.
A separate control device was applied to each model
emission source requiring additional control (e.g., a separate
combustion device for each model process vent or a separate
refrigerated condenser for each storage tank). This
assumption tended to result in an overestimation of the costs
of control. However, it was a reasonably conservative
assumption, because without detailed plant-specific
information it was not possible to determine those emission
points that could be controlled by a common device. The
application of control to wastewater-collection and treatment
operations was an exception. Because the control of emissions
4-13
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TABLE 4-2.
SELECTED CONTROL TECHNOLOGIES AND
THEIR ASSUMED CONTROL EFFICIENCIES
Emission Source Type
Control
Technologies
Control
Efficiency
(percent
reduction)
Process vents
Storage tanks
Wastewater collection
and. treatment operations
Transfer loading
operations
Equipment leaks
Combustion:
thermal
incinerator3 or
flare.
Tank improvements or
use of refrigerated
condensers.
Steam stripper with
air emissions
control
device.
*
Combustion:
thermal incineratora
or flare.
Leak detection and
repair program
specified by the
negotiated
regulation.
98
95
98
c
aUse of an acid gas scrubber following the incinerator was
assumed for streams containing halogenated VOC's.
control efficiency for this source type is variable and
is dependent on the volatility of the HAP's present in the
wastewater .
GThe actual overall effectiveness of controlling the various
individual equipment types within this source type is highly
variable.
4-14
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from wastewater is commonly practiced on multiple wastewater
streams within a facility, control costs for steam stripping
were-based on the combination of all model wastewater streams
at a facility.
4.2.1 Process Vents
Model process vent streams (i.e., described by vent
stream characteristics at the exit of the product recovery
device) were developed using process vent stream data gathered
during earlier regulatory efforts. Model process vent streams
were characterized by flow rate, heat content, and content of
HAP's and VOC's.
Where actual process vent stream data for. a given GPP
were available, CPP-specific model process vent stream
characteristics were developed and assigned to all the process
units using that CPP. For purposes of modeling those CPP's
for which CPP-specific models were not available, 19 general
model process vent streams representing different chemical
reaction types and 2 general model process vent streams
representing vacuum and non-vacuum distillation columns were
developed. These general reaction types and distillation
operations are listed in Table 4-3.
4.2.1.1 Assignment of Model Process Vent Streams. For
process vents, the same model emission source was assigned to
each process unit using a given CPP. If a CPP-specific model
process vent stream was available, it was assigned. If no
CPP-specific model process vent stream was available, general
model process vent stream characteristics (Table 4-3) were
assigned based on the chemical reaction type and information
available from the Framework on the presence and type of
distillation columns.
Unless information from the industry characterization
indicated otherwise, each CPP was assumed to have emissions
from reactor vents and distillation columns. Reactor
emissions from multiple vents within the same process unit
were grouped together and represented by a single model
process vent stream. Distillation column emissions were
handled in the same manner. Individual process units were
« ,
4-15
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TABLE 4-3. GENERAL MODEL PROCESS VENT STREAMS3
Air Oxidation
. Alkylation
Carbonylation
Catalytic reformation
Condensation
Dehydrogenation
Dehydrohalogenation
Esterification
Halogenation
Hydrodimerization
Hydroformylation
Hydrogenat ion
Hydrohalogenation
Hydrolysis
Nitration
Oxyacetylation
Oxidation
Sulfonation
Unspecified
Distillation (vacuum)
Distillation (nonvacuum)
aFrom Reference 4.
4-16
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therefore assigned two separate model process vent streams
(i.e., one for the reactor(s) and one for the distillation
operation(s)) with one exception. Because the flow rate from
an air oxidation process vent is so much larger than the flow
rate from a distillation column, process units utilizing air
oxidation reactions were assigned a single model process vent
stream to represent emissions from both the air oxidation
reactor vents and the distillation column vents.
To accommodate the difference in size (production) among
process units, vent stream flow rate and VOC and HAP
emissions were developed on a production capacity basis (e.g.,
megagram of HAP emissions per megagram of production). To
determine the emission source characteristics for a particular
process unit, the model characteristics were multiplied by the
ratio of process unit production capacity to model production
capacity.
4-2.1.2 Estimating Emissions. Uncontrolled emissions
for model process vent streams were calculated by multiplying
the values for emissions contained in the assigned model
process vent streams by the ratio of process unit production
capacity to model production capacity. Because the selected
control technology for process vents is an end-of-pipe control
device, baseline control requirements were accounted for after
the calculation of uncontrolled emissions. if baseline
controls were required based on applicable State or Federal
regulations, baseline emissions were estimated by adjusting
uncontrolled emissions using the emission reduction efficiency
specified by the applicable regulations. To obtain the total
emissions for a process unit, emissions from individual
streams were summed.
4.2.1.3 Assigning Control Technologies. The control
technology evaluated for process vents was combustion
achieving emission reductions of at least 98 percent. For
streams containing halogenated VOC's, control impacts were
estimated assuming the use of a thermal incinerator with an
acid gas scrubber. For streams containing only nonhalogenated
VOC's, control impacts were estimated assuming the use of
4-17
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either a thermal incinerator or a flare, whichever was less
expensive on a case-by-case basis. The same control devices
and approach were used for the control of transfer loading
operations.
As stated previously, baseline control requirements were
considered to ensure that additional control was assigned only
to those process vents not already meeting the selected
control level at baseline. Further, two assumptions
concerning existing control devices were made. First, it was
assumed that an existing combustion device'could be improved
to achieve 98-percent emission reduction. Second, if the
existing control device was not a combustion device and was
not achieving emission reductions as stringent as the selected
control level (98 percent), a combustion device was placed in
series with the existing control device.
4.2.1.4 Estimating Control Impacts. Procedures for
calculating control impacts were developed for each of the
selected control devices (flare, incinerator, or incinerator
with acid gas scrubber). Each calculation procedure used the
model stream characteristics (e.g., vent stream flow rate and
heat content), existing baseline control requirements, and
industry characterization information from the Framework to
calculate control impacts.
Emission reductions that would result from combustion
control were estimated differently depending on the baseline
control of the process vent. If a stream was uncontrolled at
baseline or controlled to less than 98-percent emission
reduction with a combustion device, it was assumed that
uncontrolled emissions would be reduced by 98 percent. This
would be accomplished by installing a new combustion device or
improving the existing combustion device. If a stream was
controlled at baseline to less than 98-percent emission
reduction with something other than a combustion device, the
emissions remaining after the noncombustion control device -
were reduced by 98 percent to reflect the addition of a
combustor downstream of the existing device.
4-18
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Control impacts were estimated for a combustion control
device that was designed and operated based on production
capacity. Further information on the equations and procedures
used to estimate control costs for incinerators and flares is
provided in BID Volume IB.
4.2.2 Transfer Loading Operations
Model loading racks were characterized by volumetric
throughput range and the number of loading arms per loading
rack. Different model loading racks were developed to
represent facility-wide transfer loading operations for tank
cars and tank trucks. Information collected specifically for
the HON analysis from industry questionnaires was used in
developing model loading racks. When assigning model loading
racks to a facility, emission stream characteristics
(e.g., flow rate and vapor pressure) representing the
chemicals transferred at that facility were developed for each
model loading rack. These vent stream characteristics
represent the overall conditions for all the chemicals loaded
at a particular model loading rack.
4.2.2.1 Assignment of Model Transfer Loading Racks.
Because transfer loading operations are most commonly a
facility-wide activity, model loading racks were assigned to
facilities rather than to individual process units. Model
transfer loading racks varied by, and were assigned based on,
the number of chemicals loaded and the annual throughput
transferred for facility-wide SOCMI operations. For the
purpose of assigning model loading racks, throughput values
for each vehicle type (tank trucks and tank cars) were
estimated based on the production capacity for all SOCMI
process units at the facility and the use of allocation
factors. The allocation factors were developed based on the
information collected for this analysis and represent the
average fraction of annual throughput transferred by each
vehicle type. The collected data showed that on average less
than 15 percent of total annual throughput was transferred by
tank cars and tank trucks combined. This reflects the high
percentage of co-located SOCMI process units, which minimizes
4-19
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the need for off-site transport of products. Volume 1C of the
BID contains details of the development of the allocation
factors.
Once the number of chemicals transferred and the annual
throughput for each vehicle type were determined for a given
facility, Tables 4-4 and 4-5 were used to assign model loading
racks for each type of transfer vehicle. Dedicated model
loading racks were not assigned for large production volume
chemicals. However, additional model loading racks were
assigned when the annual throughput for a given model loading
rack exceeded the maximum values shown in-Tables 4-4 and 4-5.
In such instances, the largest production volume chemical, or
set of chemicals, was assigned to the additional model loading
rack(s) to bring the first model loading rack below its
maximum annual throughput.
4.2.2.2 Estimating Emissions. Uncontrolled emissions
from model loading racks were estimated using an emissions
calculation'procedure from EPA report AP-42. Emissions for
a given chemical were estimated separately for each vehicle
type and were a function of chemical vapor pressure and annual
vehicle throughput based on production. Total emissions for a
model loading rack were determined by adding together the
emissions for each chemical loaded. Because the selected
control technology for transfer loading operations is an end-
of-pipe control device, baseline control requirements were
applied after the initial calculation of uncontrolled
emissions. If baseline controls were required based on
applicable Federal or State regulations, baseline emissions
were estimated by adjusting the uncontrolled emissions by the
emission reduction efficiency specified.
4.2.2.3 Assigning Control Technologies. The control
technology evaluated for transfer loading operations was
combustion achieving emission reduction of at least
98 percent. For streams containing halogenated VOC's, control
impacts were estimated assuming the use of a thermal
incinerator with an acid gas scrubber. For streams containing
only nonhalogenated VOC's, control impacts were estimated
4-20
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TABLE 4-4. MODEL TRANSFER LOADING RACKS FOR TANK TRUCKS**
Number of
Chemicals
Loaded
1 to 4
5 to 12
13 to 20
> 21
Throughput (TP) Range Number
(MMgal/yr) of Arms
0 < TP < 3
3 < TP < 12
12 < TP < 70b
0 < TP < 3.5
3.5 < TP < 7.5
7.5 < TP < 21
21 < TP < 54C,
0 < TP < 30d
0 < TP < 12
12 < TP < 24e
aFrom Reference 6.6
bFor throughputs above the
1-arm rack per 3 MMgal.
cFor throughputs above the
1-arm rack per 3.5 MMgal.
dFor throughputs above the
1-arm rack per 15 MMgal.
eFor throughputs above the
3-arm rack per 12 MMgal.
1
2
4
1
2
4
6
2
3
4
maximum value, assign an additional
maximum value, assign an additional
maximum value, assign an additional
maximum value, assign an additional
4-21
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TABLE 4-5. MODEL TRANSFER LOADING RACKS FOR TANK CARSa
Number of
Chemicals Throughput (TP) Range Number
Loaded _ (MMgal/yr) _ _ of Arms _
1 to 3 0 < TP < 10 3
10 < TP < 40 8
40 < TP < 80b 16
4 to 9 0 < TP < 10 3
10 < TP < 20 • 6
20 < TP < 30 10
30 < TP ^ 60C 16
10 to 22 0 < TP < 3' ' 3
3 < TP < 80d 10
> 23 0 < TP < 10 4
10 < TP < 20e 9
aFrom Reference 6.
throughputs above the maximum value, assign an additional
3-arm rack per 10 MMgal.
GFor throughputs above the maximum value, assign an additional
3-arm rack per 10 MMgal.
throughputs above the maximum value, assign an additional
3-arm rack per 3 MMgal.
eFor throughputs above the maximum value, assign an additional
4-arm rack per 10 MMgal.
4-22
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assuming the use of either a thermal incinerator or a flare,
whichever was less expensive on a case-by-case basis. The
same control devices and approach were used for the control of
process vents. Baseline control requirements were considered
to ensure that additional control was assigned only to those
transfer loading operations not already meeting the selected
control level at baseline.
4.2.2.4 Estimating Control Impacts. The same
calculation procedures used for estimating control impacts for
process vents were used for transfer loading operations. Each
calculation procedure used the model stream characteristics
(e.g., vent stream flow rate and heat content), existing
baseline control requirements, and industry characterization
information from the Framework to calculate control impacts.
Emission reductions that would result from, combustion *
control were estimated differently depending on the baseline
control of the loading rack. If a stream was uncontrolled at
baseline or controlled to less than 98-percent emission
reduction with a combustion device, it was assumed that
combustion would reduce uncontrolled emissions by 98 percent.
If a stream was controlled at baseline to less than 98-percent
emission reduction with something other than a combustion
device, the emissions remaining after the noncombustion
control device were reduced by 98 percent to reflect the
addition of a combustor downstream of the existing device.
Control costs and secondary impacts were estimated for a
combustion control device that was designed and operated based
on production capacity. Further information on the equations
and procedures used to estimate costs for incinerators and
flares is provided in BID Volume IB.
4.2.3 storage Tanks
Model storage tank farms were characterized by tank size,
number of tanks, and tank type. The data used in developing
these models were obtained from past regulatory efforts.
Model storage tank farms were developed in an iterative
process in order to generate a national storage tank
distribution reflective of the best information available to
4-23
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the EPA. This was accomplished by varying the number of tanks
per model storage tank farm, assigning model storage tank
farms to the process units represented in the Framework, and
comparing the aggregate results to the national storage tank
distribution.7
4.2.3.1 Assignment of Model Storage Tank Farms. The
assignment of model storage tank farms involved two steps.
First, the size and number of tanks in a tank farm were
determined, and second, the tank type was determined. Using
the annual throughput based on production capacity for the
storage of a given chemical at a process unit, the number and
size of tanks in the model tank farm were determined using
Table 4-6.
Selection of model tank type was based on the size of the
tank, the baseline control requirementsc imposed by »applicable
State and'Federal regulations, and the chemical properties of
the stored chemical (i.e., vapor pressure and compatibility
with aluminum). Baseline control requirements were considered
in assigning model tank type because certain tank types can be
emission points in one instance and additional control in
another. For example, an internal floating roof tank may be a
part of baseline control where this is required by State or
Federal regulations; the installation of an internal floating
roof can also be considered an additional level of control for
a fixed roof tank.
The determination of tank type followed the logic flow
diagram presented in Figure 4-4. First, all chemicals having
a vapor pressure of 14.7 psia (760 mm Hg) or greater were
assigned to pressurized vessels. All model tanks with
capacities of 10,000 gal (38 m3) were assigned horizontal
tanks. Vertical tanks were assigned for tanks haying
capacities of 20,000 gal (75 m3) or greater.
In the next step, baseline control requirements were
evaluated. For those 10,000 gal (38 m3) model tanks subject
to State or Federal regulations requiring controls, a
refrigerated condenser with the emission reduction efficiency
4-24
-------
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required by the applicable regulation was assigned. This was
necessary because floating roofs cannot be used on horizontal
tanks. For model tanks with capacities of 20,000 gal (75 m3)
or greater, if no control was required by a State or Federal
regulation, a fixed roof tank was assigned. If additional
control was required, the specific baseline control
requirements were evaluated to determine the tank type. Where
a vapor recovery system was required, a fixed roof tank and a
refrigerated condenser were assigned. The emission reduction
efficiency of the refrigerated condenser was determined by the
applicable regulation. Where an internal floating roof was
required, chemical properties were evaluated to ensure the
technical feasibility of using this control technology.
Chemicals compatible with aluminum were stored in internal
floating roof tanks. The number and types of seals and the
type of fittings (controlled or uncontrolled) for internal
floating roof tanks were determined by the applicable
regulation. Halogenated chemicals and other chemicals that
are incompatible with aluminum were not assigned an internal
floating roof tank. Because most floating roofs are
constructed of aluminum, their use with incompatible chemicals
can result in corrosion of the roof and contamination of the
product. Chemicals with these characteristics were assigned
fixed roof tanks with additional control provided by a
refrigerated condenser achieving 95-percent emission reduction
efficiency. Ninety-five percent emission reduction was
selected because that was judged to be equivalent to the
reduction possible with an internal floating roof. Where the
baseline control requirements allowed a choice between vapor
recovery systems and use of an internal floating roof, and the
chemical was compatible with aluminum, the internal floating
roof was chosen because it has a lower cost.
4.2.3.2 Estimating Emissions. To calculate baseline
emissions from model storage tank farms, simplified empirical
emission equations from AP-42 were used.3 The information
required for the emission equations was provided as model
4-27
-------
emission source characteristics (e.g., tank type and tank
size) or was available from the Framework (e.g., chemical
vapor pressure and annual storage throughput). For the
purpose of estimating emissions, annual storage throughput was
based on production rate. Three calculation procedures
covered the possible combination of baseline control
requirements and tank types. First, if the model storage tank
was a fixed roof tank, the AP-42 equations for fixed roof
tanks were used to estimate emissions. Second, if baseline
control requirements specified vapor recovery, the emissions
calculated from the AP-42 equations for fixed roof tanks were
reduced by the emission reduction efficiency specified in the
applicable regulation as shown:
Bas.eline Emissions = [Fixed Roof Tank Emissions] *
[1-Required Emissions Reduction Efficiency]
Third, if the model tank was an internal floating roof tank,
emissions were calculated using the AP-42 equations for
internal floating roof tanks and the factors for the seals and
fittings specified in the applicable regulation.
4.2.3.3 Assigning Control Technologies. Two control
technologies were evaluated for storage tanks: tank
improvements and refrigerated condensers. These technologies
were judged to be equivalent in stringency, each achieving
emission reductions of approximately 95 percent.
For tanks storing chemicals compatible with the use of an
internal floating roof (compatible with aluminum), control
impacts were calculated based on the use of tank improvements
(i.e., installation of an internal floating roof with specific
seals and fittings). The calculation procedure for tank
improvements distinguished between improving an existing
internal floating roof tank and modifying a fixed roof tank by
adding an internal floating roof.
For tanks storing halogenated chemicals or other
chemicals that are incompatible with aluminum, control impacts
were estimated based on the use of refrigerated condensers.
When a refrigerated condenser was assigned as the control
technology for a storage tank, the control impacts were
4-28
-------
estimated based on the assumption that any existing control
device was removed and a new refrigerated condenser achieving
the required 95 percent emission reduction efficiency was
installed.
Once again, baseline control requirements were considered
to ensure that additional control was assigned only to those
storage tanks not already meeting the selected control level
at baseline.
4-2.3.4 Estimating Control Impacts. When tank
improvements were assigned as the control technology, emission
reductions were estimated by determining the controlled
emissions for the new tank (i.e., an internal floating roof
tank with specific seals and fittings) and subtracting this
value from the baseline emissions, which were .estimated based
on: (1) a fixed roof tank; (2) a fixed roof tank equipped
with a refrigerated condenser having a removal efficiency less
than 95 percent; or (3) an internal floating .roof tank without
the specific seals and fittings. Control costs were estimated
based on procedures developed for a previous rulemaking effort
and are described in BID Volume IB. There are no secondary
impacts resulting from the use of this control technology.
When refrigerated condensers were assigned as the control
technology, emission reductions were estimated by subtracting
the controlled emissions (representing use of a condenser
achieving 95 percent removal efficiency) from the baseline
emissions, which represent either a fixed roof tank or a fixed
roof tank equipped with a condenser having a lower removal
efficiency.
4-2.4 Wastewater Collection and Treatment Operations
Model wastewater streams (i.e., described by stream
characteristics at the point of wastewater generation) were
developed using industry questionnaire data collected as part
of the HON analysis and other available data. Unique model
wastewater streams were developed for each CPP and were
characterized by flow rate (provided on a production basis),
HAP concentration, and HAP volatility. For some CPP's, actual
wastewater stream data as reported in Section 114 responses
4-29
-------
were used as model wastewater streams. For the remaining
CPP's, unique model wastewater streams were developed for each
GPP in the following manner. From the Section 114 data,
average flow rates and ratios of HAP concentration to HAP
solubility were developed for typical process equipment pieces
that generate wastewater streams. From the HON industry
characterization, wastewater-generating process equipment
pieces and the chemicals expected to be present in the
wastewater streams were identified for each CPP. Using these
two sets of information, flow rate and HAP concentration were
predicted for each wastewater stream. Volatility is dependent
upon the chemicals present and was predicted for each model
• wastewater stream.
4.2.4.1 Assignment of Model Wastewater Streams. Unique
model wastewater streams were developed for each CPP that was
modeled. Flow rate was provided on a production basis so that
a model wastewater stream representative of a particular CPP
could be assigned to different process units. The specific
flow rate for any given process unit was determined by
multiplying the value for flow rate of the model stream by the
ratio of process unit production rate to the model production
value.
4.2.4.2 Estimating Emissions.. Emissions for model
wastewater streams were a function of flow rate, HAP
concentration, and the volatility of those HAP's. Based on
the analysis, no States had regulations for the control of air
emissions from SOCMI wastewater operations, but both NESHAP
applicable to the SOCMI (vinyl chloride and benzene) do
regulate air emissions from wastewater operations. For
wastewater streams associated with CPP's regulated by these
NESHAP, baseline emissions were estimated by adjusting
uncontrolled emissions by the emission reduction efficiency
specified. Baseline control requirements were considered to
ensure that additional control was assigned only to those
wastewater collection and treatment operations not already
meeting the selected control level at baseline. Total
4-30
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process unit emissions were determined by summing emissions
for all the assigned model wastewater streams.
4.2.4.3 Assigning Control Technologies. The control
technology evaluated for wastewater collection and treatment
operations was a steam stripper followed by an air emissions
control device. Steam stripping achieves variable emission
reductions depending on the volatility and strippability of
the HAP's in the wastewater. For 'the purposes of estimating
the control impacts, it was assumed that the air emissions
control device was an existing combustion device.
4.2.4.4 Estimating Control Impacts. Control impacts for
wastewater collection and treatment operations were estimated'
on a facility basis. Control costs were evaluated based on
the total facility-wide wastewater flow based on production
rate. Emission reductions are a function of strippability and
were estimated for each wastewater stream.
Designing and costing a control device for multiple
wastewater streams at a facility provides an economy of scale
compared to the control of individual wastewater streams. As
a result, the costs of controlling the same stream at two
different facilities may not be the same. Control costs and
secondary impacts were apportioned to individual model
wastewater streams based on the ratio of individual flow to
total facility flow.
4.2.5 Equipment Leaks
Data available to EPA from past studies and regulatory
efforts were used to develop model process units. Model
process units for equipment leaks were characterized by
complexity (equipment counts) and baseline control level.
From these two characteristics, HAP and VOC emissions and
control impacts were calculated and included as
characteristics of the model process unit. Six model process
units were developed to represent three different levels of
complexity and two levels of baseline control. Table 4-7
shows the equipment types and counts associated with the six
model process units.
4-31
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4.2.5.1 Assignment of Model Process Units for Equipment
Leaks. Model process units for equipment leaks were assigned
to process units represented in the Framework exclusively for
the purpose of determining baseline control requirements as
dictated by process unit location and State regulations.
Specific information for CPP's was not needed to estimate
emissions or control impacts because of the nature of the
model emission sources. Each of the six model units had
specific emissions and control impact values included as a
model characteristic.
As part of the SOCMI Equipment Leaks NSPS, it was
estimated that nationally 15 percent of process units have
high complexity, 52 percent have medium complexity, and
33 percent have low complexity.9 (Note: The more equipment a
process unit has, the more complex it is.) This distribution
was used to assign complexity to the process units represented
in the Framework. After complexity was determined for
individual process units, the control status dictated by
process unit location was determined and the model process
unit was assigned.
4-2.5.2 Estimating Emissions. Model process units for
equipment leaks included as a model characteristic the actual
value for emissions for the process units to which they were
assigned. No adjustments were required to account for the
size (production capacity) of the process unit or for baseline
control requirements.
4.2.5.3 Assigning Control Technologies. The control
technology evaluated for equipment leaks was determined by the
negotiated regulation. Impacts were calculated based on the
assumption of a more effective leak detection and repair
program than the programs required by the SOCMI equipment"
leaks NSPS and the benzene NESHAP.
Baseline control requirements were considered to ensure
that control impacts were calculated only for those process
units not already meeting the selected control level at
baseline.
4-33
-------
4.2.5.4 Estimating Control Impacts. For equipment
leaks, values for control impacts were included as a
characteristic of the assigned model process units. The
control impacts associated with the uncontrolled models
reflect a process unit without an equipment leak control
program at baseline implementing a control program that meets
the requirements of the negotiated regulation. The control
impacts associated with the controlled models reflect a
process unit with a baseline control program meeting the
requirements of the Equipment Leaks Control Techniques
Q
Guideline implementing a control program meeting the
requirements of the negotiated regulation.
4.3 ESTIMATION METHODOLOGY FOR UNMODELED GPP's
For those SOCMI CPP's where little or no information was
available from the industry characterization, estimation of
individual process unit impacts were not attempted and a
default factor was used to account for them in the estimate of
national impacts. It was estimated that these "unmodeled
CPP's" represent only 3 percent of the total SOCMI production
capacity, and therefore the use of a default value was judged
to provide an adequate representation of impacts.
In order to develop a complete estimate of national
impacts, control impacts for two groups of unmodeled CPP's
were estimated.. The two groups are: (1) SOCMI CPP's that
were not well-defined by the industry characterization, and
(2) seven non-SOCMI processes that would be subject to the
equipment leaks negotiated regulation and were therefore
included in the HON control impacts analysis.
4.3.1 Estimating Emissions and Control Impacts for Unmodeled
SOCMI CPP's
The industry characterization was successful- in providing
information for the CPP's for the chemicals with larger
production capacities (i.e., the modeled CPP's). It was
estimated that the production capacity of these CPP's
•
represents approximately 97 percent of the total SOCMI
production capacity. Based on this, each unmodeled CPP was
assumed to have a small national production capacity. It was
4-34
-------
further assumed that one process unit manufactured the entire
national production capacity of a given CPP.
*S -'8
Using these assumptions, scaling factors for emissions-
and control impacts were developed to represent the unmodeled
SOCMI CPP's in the estimation of national impacts. These
factors were the average emissions and control impacts for the
bottom 5 percent by size (small production capacity) of the
modeled CPP's. It was judged that those CPP's making up the
bottom 5 percent of total production capacity for modeled
CPP's would span the range of production capacities likely to
be within the unmodeled CPP's. Further, while production
capacity was not the sole determinant of emissions and control
impacts, it was judged that a correlation could be drawn
between the two for developing these scaling factors.
4•3•2 Estimating Emissions and Control Impacts for Non-SOCMI
CPP's ~
The equipment leaks standard was developed through the
regulatory negotiation process. This standard is included as
part of the HON.
The scope of the equipment leaks standard included seven
processes not included in the scope of the HON for the other
emission source types. The processes included by the
negotiated regulation that would otherwise not have been
included in the HON analysis are referred to as the non-SOCMI
processes. Appendix B of this volume contains the emissions
and control impacts and specific information on the estimation
methodology used in developing emissions and control impacts
for the non-SOCMI process.
4-35
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4.4 REFERENCES
1. Memorandum from King, B. S., Radian Corporation, to
Meyer, J. S., EPA/SDB. HON baseline control
requirements. February 14', 1992.
2. Memorandum from King, B. S., Radian Corporation, to
Meyer, J. S., EPA/SDB. HON SOCMI characterization.
February 14, 1992.
3. U. S. Environmental Protection Agency, Office of Air
Quality Planning and Standards. Compilation of Air
Pollutant Emission Factors, Volume 1: Stationary Point
and Area Sources. Publication No. EPA/AP-42. Research
Triangle Park, NC. September 1985. pp. 4.3-1 through
4.3-35.
4. Memorandum from Olsen, T., Radian Corporation, to Evans,
L., EPA/CPB. September 17, 1991. Development of model
emission source characteristics for SOCMI process vents.
5. Ref. 3, pp. 4.4-1 through 4.4-17.
6. Memorandum from Ocamb, D. and Olsen, T. R., Radian'
Corporation, to Markwordt, D., EPA/CPB. Revised HON
transfer model loading racks development. October 6,
1991.
7. Memorandum from Probert, J.A., Radian Corporation, to
Kissell, M.T., EPA/SDB. September 14, 1992. Development
of model tank farms for the HON analysis.
8. U. S. Environmental Protection Agency. Control of
Volatile Organic Compounds Leaks from Synthetic Organic
Chemical and Polymer Manufacturing Equipment. Guideline
Series. Publication No. EPA 450/3-90-006. Research
Triangle Park, NC. January 1990.
9. Erikson, D. G. and V. Kalcevic. (IT Enviroscience,
Inc.). Fugitive Emissions. In: Organic Chemical
Manufacturing, Volume 3: Storage, Fugitive, and
Secondary Sources. Report 2. U. S. Environmental
Protection Agency. Research Triangle Park, NC.
EPA-450/3-80-025. December 1980. p. II-2.
10. National Emission Standards for Hazardous Air Pollutants;
Announcement of Negotiated Regulation for Equipment
Leaks. Federal Register. Vol. 56. No. 44,
pp. 9315-9339. Washington, DC. Office of the Federal
Register. March 6, 1991.
11. Memorandum from King, B. S., Radian Corporation, to
Meyer, J. S., EPA/SDB. National impacts scaling
procedure for Level C CPP's in the HON impacts analysis.
February 14, 1992.
4-36
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5.0 NATIONAL IMPACTS
This chapter describes the analysis and presents the
resulting estimates of national emission, cost, and other
impacts that could occur as a result of controlling HAP
emissions from the SOCMI. National impacts are presented for
the selected option.
5.1 DESCRIPTION OF NATIONAL IMPACTS ANALYSIS,
National impacts represent the total impacts of control
for all emission points (e.g., individual process vent or
storage tank) nationwide that are required to apply additional
control as part of complying with the HON standard. Control
impacts are presented in terms of primary air pollutant
impacts, cost impacts, and other impacts.
Primary air pollutant impacts are the hazardous air
pollutant (HAP) and volatile organic compound (VOC) emission
reductions that result from the application of additional
controls to SOCMI emission points. Since emissions of
individual HAP constituents are not known, HAP emissions and
emission reductions are presented on a total HAP basis. For
some emission source types (i.e., process vents, wastewater
operations, and equipment leaks), the control of HAP emissions
also results in the control of non-HAP VOC emissions. As a
result, VOC emission reduction estimates include HAP VOC's and
non-HAP VOC's. For example, if an emission point generates 80
Mg/yr (88 tpy) of HAP's and 20 Mg/yr (22 tpy) of non-HAP
VOC's, the HON analysis would indicate 100 Mg/yr (110 tpy) of
VOC emissions and 80 Mg/yr (88 tpy) of HAP emissions for this
emission point. With a national ratio of HAP to VOC emissions
of approximately 1 to 2.3, the potential to control a
significant amount of non-HAP VOC emissions exists.
5-1
-------
Baseline emissions are presented in conjunction with
emission reductions to better illustrate the level of control
achieved. The estimation of baseline emissions takes into
account the current estimated level of emissions control based
on State and Federal regulations. As a result, baseline
emissions reflect the level of control that would be achieved
in the absence of the HON standard.
Cost impacts include the estimated capital and annual
costs of applying additional control to SOCMI emission points.
The components of cost include the capital costs of new
control equipment, the cost of energy (supplemental fuel,
steam, 'and electricity) required to operate control equipment,
and the cost of operation and maintenance of control
equipment. Cost impacts also include cost savings generated
by reducing the loss of valuable product in the form of
emissions. Average cost effectiveness (cost per megagram of
pollutant removed) is also presented as part of cost impacts.
Other impacts include increased energy requirements, the
emissions of NOX and CO, and the genera-ion of solid waste and
water pollution. Energy requirements, also accounted for in
the cost impacts, are expressed as increased use of steam,
natural gas, and electricity. These increases represent the
energy required to operate control equipment. Emissions of
NOX and CO result from the combustion of HAP and VOC emissions
and the on-site combustion of fossil fuels required to operate
control equipment (combustion devices) or to generate steam
for use in a control device (steam strippers). Emissions of
NOX and CO resulting from increased electricity demand are not
included in this analysis. Amounts of solid waste and water
pollution generated are not quantified-in this analysis but
instead are discussed qualitatively.
5.2 PRESENTATION OF NATIONAL IMPACTS
National impacts are presented in three sections:
primary air pollutant impacts, cost impacts, and other
impacts. National impacts are expressed as the incremental
impact relative to baseline and represent control impacts in
the fifth year of the standard. Fifth-year control impacts
5-2
-------
V" *f.
include control impacts for existing emission points and for
additional emission points built in the first five years
following the base year of the analysis. National impacts for
the additional emission points were estimated to represent
16 percent of the total fifth-year impacts. This estimation
was made assuming a SOCMI-wide growth rate of 3.5 percent
compounded each year over a five-year period. The same
control technology was applied to existing sources and
.additional equipment.
5.2.1 Primary Air Pollutant Impacts
Primary air pollutant impacts are total HAP and VOC
emission reductions resulting from control of emission points
in the SOCMI. Table 5-1 presents baseline emissions and
emission reductions for the selected option. Total HAP
baseline emissions are estimated to be 597,000 Mg/yr
(656,700 tpy) and total HAP emission reductions are estimated
to be 475,000 Mg/yr (522,500 tpy). This is an overall
reduction of 80 percent. The VOC emissions and emission
reductions are approximately 2.3 times the HAP values. Total
baseline VOC emissions are estimated to be 1,380,000 Mg/yr
(1,518,000 tpy) and total VOC emission reductions are
estimated to be 986,000 Mg/yr (1,084,600 tpy).
Figure 5-1 shows the relative contribution of each
emission source type to total baseline emissions. Emissions
from storage tanks and transfer loading operations are small
relative to emissions from the other emission source types for
two reasons. First, chemicals with vapor pressures of
760 mmHg (14.7 psia) or greater are stored or transferred
under pressure which results in no measurable emissions. This
greatly reduces the opportunity for emissions from these two
emission source types in comparison to the others. Second,
there are several State and Federal regulations that apply to
the storage of organic liquids. Because many tanks are
controlled at baseline due to these existing regulations, the
emissions are greatly reduced. It should be noted that the
analysis of storage tanks and transfer loading operations was
limited to pure substances and only HAP's. As a result,
5-3
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within each of these emission source types, the emissions of
HAP's and VOC's are'equivalent.
Emissions from process vents and wastewater operations
are large because there are a greater number of chemicals
(i.e., those with vapor pressures greater than 760 mmHg
[14.7 psia]) potentially emitted from these two emission
source types Further, there are very few existing standards
that regulate emissions from wastewater operations. No State
regulations covering air emissions from wastewater were
identified, and only two Federal regulations (vinyl chloride
and benzene NESHAP) requiring control of emissions from
wastewater operations were considered in the estimation of
baseline emissions. Principally resulting from the lack of
existing regulations for air emissions from wastewater
operations, the contribution to total VOC emissions from
f
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type. Equipment leak emissions are regulated by both State
and Federal regulations and the control of emissions from this
emission source type can save valuable product and bring
economic benefit. As a result, it is reasonable that the .
emissions from equipment leaks would be smaller than emissions
from process vents or wastewater operations.
Figure 5-2 shows the relative contribution of each
emission source type to total emission reductions. Since the
control efficiencies of the evaluated control technologies are
roughly equivalent, the relative contribution of each emission
source type to total emission reductions is similar to the
relative contribution to total baseline emissions. Therefore,
the. control of emissions from process vents and wastewater
operations account for the majority of both HAP and VOC air
impacts, while air impacts from the control of emissions from
storage tanks and transfer loading racks are much smaller.
5.2.2 Cost Impacts
Cost impacts include total capital costs, total annual
costs, and average HAP and VOC cost effectiveness (cost per
megagram of pollutant removed). Average cost effectiveness is
5-6
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computed by dividing the national annual cost by the national
emission reductions (relative to baseline).
Table 5-2 shows estimated national control cost impacts
in the fifth year of the standard. Cost estimates for the HON
impact analysis are conservatively high and therefore
represent worst-case costs. Estimates were made assuming a
separate control device would be constructed for each process
vent, storage tank, and transfer rack. Ducting the emissions
from several of these emission points to a common control
device would reduce the estimated costs while achieving the
same emission reductions. A common control device may be an
existing device with excess capacity or a new device; in
either case, the estimated costs would be reduced if multiple
emission points shared a common control device. Because-it is
not possible to predict how often ducting to a common device
might be possible, the worst-case assumption (that sharing of
control devices would never occur) was used. Accordingly,
actual costs of achieving emission reductions for process
vents, storage tanks, and transfer racks will be less than the
estimates in Table 5-2.
Cost estimates for controlling emissions from wastewater
operations are based on facility-wide control because this is
general industry practice. Cost estimates for controlling
emissions from equipment leaks are almost exclusively based on
equipment counts. Therefore, cost estimates for the control
of emissions from both wastewater operations and equipment
leaks are not considered either conservatively high or low. •
As shown in Table 5-2, total capital costs are
$347 million and total annual costs are $134 million. Costs
for controlling emissions from process vents' and wastewater
operations account for more than 80 percent of total annual
cost. Table 5-2 also shows that, although controlling
emissions from equipment leaks represents over 30 percent of
the total capital costs, on an annual basis there is actually
a cost savings due to the prevention of product loss.
Average HAP cost effectiveness values for individual
emission source types range from $10,000/Mg of HAP for
5-8
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5-9
-------
transfer loading- operations to a net savings of $20/Mg of HAP
for equipment leaks (driven by the net savings for annual
costs). Controlling emissions from transfer loading
operations yields a relatively high cost per megagram of
pollutant removed because of the small amount of emission
reductions achieved by controlling this emission source type.
The total average HAP and VOC cost effectiveness values are
$280/Mg of HAP and $140/Mg of VOC, respectively. Overall, the
cost per megagram of pollutant removed for VOC control is
approximately half that of HAP control. This is due to
control of the non-HAP VOC emissions. More- emission
reductions are being achieved for the same annual cost.
Figure 5-3 illustrates the relative contribution of each
emission source type to the total capital and annual costs.
5.2.3 Other Impacts
Some adverse effects on air quality and other
environmental media and increased energy requirements are
associated with the use of emission control devices,
specifically the use of combustion devices to control
emissions from process vents and transfer loading operations,
the use of steam strippers to control emissions from
wastewater operations, and the use of refrigerated condensers
to control emissions from storage vessels. Impacts associated
with air quality and other media include emissions of NOX and
•CO and the generation of solid waste and water pollution. The
cause of and estimation methodology for these impacts are
discussed in Volume 1C of the BID for each emission source
typSl
5.2.3.1 Energy Use. Table 5-3 shows the estimated
increases for steam, natural gas, and electricity. As
described in Volume 1C of the BID, increased energy
requirements were estimated separately. The use of steam is
associated exclusively with steam strippers and natural gas,
"consumed as supplemental fuel, is associated exclusively with
combustion devices. For purposes of comparison, these energy
requirements were converted to a barrels of oil equivalent
(BOB) basis.
5-10
-------
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5-12
-------
Total estimated energy use increases are 2.4 million BOB.
This equates to 260 million kw-hr/yr of electricity;
6,650 billion Btu/yr of natural gas; and 5,300 billion Btu/yr
of industrial steam on a heat input basis. The total
electricity requirement is equivalent to the electricity
produced by one small power plant rated at approximately 37 MW
operating 8760 hr/yr at 80 percent capacity. The total
natural gas requirement is equivalent to the energy consumed
by approximately 3 large coal-fired industrial boilers, each
boiler rated at 400 million Btu/hr heat input and operating
8760 hr/yr at 60 percent capacity. The total steam
requirement on a heat input basis is equivalent to the energy
consumed by 2 industrial boilers each rated at approximately
400 million Btu/hr heat input and operating 8760 hr/yr at
60 percent capacity. Figure 5-4 illustrates energy use »
increases by emission source type.
Energy use increases attributable to the control of
emissions from equipment leaks were not quantified but are
judged to be insignificant. A small amount of electricity is
required to charge batteries found in some of the leak
detection equipment. If some equipment components are
controlled by capturing the emissions and combusting them in
an existing control device, a small amount of supplemental
fuel (e.g., natural gas) for the combustion device may be
required.
5.2.3.2 Nitrogen Oxides and Carbon Monoxide Emissions.
Table 5-4 shows national emissions of CO and NOX resulting
from the combustion of emission streams and the on-site
combustion of supplemental fuel required to operate control
devices. Off-site emissions of CO and NOX resulting from
increased electricity demand were not estimated.
Total CO and NOX emissions are 1,570 Mg/yr (1,727 tpy)
and 15,700 Mg/yr (17,270 tpy), respectively. The control of
HAP and VOC'emissions from process vents accounts for the
majority of the total CO and NOX emissions. The CO emissions
are equivalent to the emissions generated by approximately
7 large coal-fired industrial boilers, and the -NOX emissions
5-13
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5-15
-------
are equivalent to the emissions generated by approximately
23 large coal-fired industrial boilers, each boiler rated at
400 million Btu/hr heat input and operating 8760 hr/yr at
60 percent capacity.
Emissions of CO and NOX should also be considered in
context with total VOC emission reductions to understand the
overall significance, of these emission increases. Total VOC
emission reductions"are 986,000 Mg/yr (1,084,600 tpy). The
emission reductions achieved are 57 times the combined
emission increases of NOX and CO that result from controlling
HAP and VOC emissions from SOCMI emission points. Figure 5-5
illustrates this comparison.
Because the control technologies for controlling
emissions from equipment leaks and storage tanks do not
involve the on-site combustion of significant amounts of
supplemental fuel (none for the control of storage tanks),
there are no measurable CO or NOX emissions as a result of
controlling these emission points. Further, the emissions of
CO and NOX from the control of transfer loading operations are
so small as to be insignificant.
5.2.3.3 Solid Waste. There are no direct or measurable
solid waste impacts resulting from the application of the
evaluated control technologies to control emissions from
process vents, transfer loading operations, storage tanks, or
equipment leaks.
There are two potential sources of solid waste as a
result of controlling emissions from wastewater operations.
Solid wastes may be generated as part of the steam stripper
overheads and as part of feed pretreatment. However, these
wastes are expected to be reused in the process or burned as
fuel, and therefore were judged by EPA to not create
significant additional solid waste impacts.
5.2.3.4 Water Pollution. There are no direct or
measurable water pollution impacts resulting from controlling
emissions from equipment leaks. Steam strippers, the
evaluated control technology for the control of wastewater air
emissions, improve the quality of water by decreasing HAP and
5-16
-------
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5-17
-------
VOC concentrations and therefore have a beneficial impact on
water quality.
No significant increase in total plant wastewater is
projected for the control of emissions from process vents and
transfer loading operations. There is no wastewater
associated with combustion devices themselves. The only
wastewater generated originates from the-use of scrubbers, to
control acid gas resulting from the combustion of halogenated
vent streams in incinerators. However, the magnitude of HAP's
and VOC's transferred to water as a result of applying the
evaluated control technology (thermal incinerator) would be
insignificant compared to the overall amount of HAP and VOC
emissions reduced from the air. Therefore, these wastewater
discharges were judged by the EPA to pose an insignificant
adverse environmental impact.
There are two potential sources of water pollution
associated with controlling emissions from storage
tanks—contamination of water used during tank cleaning and
water used as cooling fluid in the condenser. It was judged
by the EPA that neither of these sources would significantly
affect water quality. Further, it is anticipated that the
majority of storage tank cleaning and degassing in order to
apply tank improvements would have occurred in absence of the
HON standard.
5-18
-------
6.0 SUMMARY OF ECONOMIC IMPACTS
6.1 INTRODUCTION
• The intention of this chapter is to summarize the
economic impacts of the HON. The HON will regulate HAP
emissions from the SOCMI, a complex and diverse industry that
produces thousands of chemical compounds/ with ultimate uses
in nearly every consumer and industrial market. For purposes
of analyzing the SOCMI, chemical trees were constructed for
490 synthetic organic chemicals, that identify the various
routes by which a particular chemical is produced. Many
different production processes can be used to produce the same
chemical. The 490 chemicals include about 400 whose
production involves the use of a HAP as a raw material or the
production of a HAP as a product, co-product, or intermediate.
Production of the other roughly 90 chemicals is not known to
involve HAP's and would not be directly regulated by the HON.
However, these chemicals must be included in the cumulative
cost analysis because they form links in the SOCMI production
chain. Since in-depth analysis of all 490 chemicals was
untenable, 20 chemicals were chosen for detailed analysis.
Emissions from production of these 20 compounds are subject to
the HON. While a random sample would have been desirable,
availability of information and the ongoing nature of the
impacts analysis (which provided cost information) precluded
this possibility.
This chapter proceeds in three broad sections.
Section 6.2 scrutinizes the extent to which the 20 selected
chemicals are representative of the population of all 490
chemicals. Subsequently, Section 6.3 reviews the economic
impact analysis and examines the implications of the study for
6-1
-------
the SOCMI as a whole. Finally, Section 6.4 analyzes the small
business impacts.
6.2 REPRESENTATIVENESS OF SAMPLE
6.2.1 Annual Production and Control Costs
Annual production data was compiled, and cumulative cost
impacts were calculated for each of the chemicals for which
chemical trees have been constructed. The cost option
examined is the total industry control (TIC) option, which
represents the maximum control cost that the SOCMI would incur
if all HAP emission points were required to apply the selected
control technologies. Because the selected regulatory ©ption
does not require control of some of the smaller emission
points, analysis of the TIC option overstates the economic
impacts. The total annual cost of the TIC option is
$292 million/yr compared to $134 million/yr for the selected
option.
Table 6-1 compares the distribution of the 490 chemicals
with those 20 selected for analyses, in terms of both annual
production arid control costs. The percentage cost increases
presented were calculated at the 50th percentile of industry
output. These increases were not the ones employed for
estimating economic impacts. They were used merely for
comparison's sake, so that the representativeness of the
selection could be appraised.
The percentage cost increase was calculated by dividing
the cumulative compliance cost per kilogram by the per-unit
revenue, or price, for each chemical, as:
* 100
where
CCj = cumulative compliance cost for chemical i; and
P,- = price of chemical i.
The comparison by annual production demonstrates the
primary shortfall of the selected chemicals. Specifically,
only one chemical with annual production less than 10 MMkg was
6-2
-------
TABLE 6-1. DISTRIBUTION OF CHEMICALS BY PERCENTAGE COST
INCREASE AND ANNUAL PRODUCTION (10_MMkg): TIC OPTION
All Chemicals
Distribution
By Annual Production
(MMkcn
% Change in Cost3
Less than 1.00
1.00 - 2.00
2.00-3.00
3.00 - 4.00
4.00 - 5.00
5.00 - 7,00
7.00 - 10.00
Greater than 10.00
Total
% of Total
Number
237
96
48
16
7
11
19
56
490
100%
% of
Total
48.4
19.6
9.8
3.3
1.4
2.2
3.9
11.5
100.0
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41
64
1-5 5-10
9 10
1 20
0 13
3 6
3 2
3 4
8 4 * ,
6 4
33 63
13.1 6.7 12.9
Selected
% Change in Costa
Less than 1.00
1.00 - 2.00
2.00 - 3.00
3.00 - 4.00
4.00 - 5.00
5.00 - 7.00
7.00 - 10.00
Greater than 10.00
Total
% of Total
of industry output.
Number
11
6
2
0
0
0
1
0
20
100%
on control
% Of
Number
55
30
10
0
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0
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costs
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198
75
35
7
2
4
4
' 5
330
67.3
Distribution
Annual Production
(MMkg)
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0 1
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0 0
0 0
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0 0
0 0
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11
5
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19
95
at the 50th percent ile
6-3
-------
selected for detailed analysis and no chemicals less than
5 MMkg. In the population, 32.7 percent of the chemicals have
annual production of less than 10 MMkg and 19.8 percent less
than 5 MMkg. Clearly, the selection was biased towards large
production volume chemicals. This was a consequence of the
selection process. To perform detailed analysis on particular
chemicals, an adequate amount of information was needed.
Little or no information was available for chemicals with
annual production levels of less than 10 MMkg. Therefore,
little can be said about these chemicals, which account for
32.6 percent of all chemicals.
Because the small production volume chemicals were under-
represented, comparisons based on control costs were valid
only for those with annual production greater than 10 MMkg.
This includes all but one of the selected compounds and 330
chemicals from the entire population. . .
As with annual production, the selected population of
chemicals was under-represented in several areas in terms of
control costs. Chemicals were absent in four ranges of
control costs. Compounds in these cost ranges — 3 to
4 percent, 4 to 5 percent, 5 to 7 percent, and greater than
10 percent — account for 18.4 percent of the 490 compounds.
On the other hand, the selection did encompass the other
five cost ranges, which account for 81.6 percent of the 490
chemicals. For the range of cost increases less than
2 percent, the correlation was fairly strong. Sixty-eight
percent of the population was included in this range, as
compared with 85 percent of the selection. The cost range of
2 to 3 percent, 'which includes 9.8 percent of the population
.and 10 percent of the selection, was also well represented.
Costs ranging from 5 to 7 percent include 2.2 percent of the
population and 5 percent of the selection. Thus, extending
the results of the detailed analyses to the SOCMI as a whole
was judged to be a useful representation of economic affects
on the SOCMI as a whole.
6-4
-------
6-2.2. Basic Feedstock Chemicals
Chemicals produced by the SOCMI were ultimately derived
from eight basic feedstock chemicals, which served as the
building blocks for the SOCMI. These eight feedstock
chemicals were derived from petroleum refineries, natural gas
plants, and coal tar distillers. Table 6-2 presents, the
selected chemicals, grouped by the basic feedstocks from which
they were derived. 'As illustrated, each basic feedstock
chemical is represented. Thus, the selected chemicals were a
satisfactory representation of the scope of the SOCMI as
measured by basic feedstock chemicals.
6 ..2 . 3 Summary
In general, the selection under-represented chemicals
with costs greater than 3 percent, as well as chemicals with
annual production less than 10 MMkg. However, the large
production volume chemicals, which'compose 67.3 percent of the
population, were represented in terms of annual production,
control costs in the lower ranges, and basic feedstock
chemicals. Because these chemicals represent the vast
majority of SOCMI production, extending the results of the
cumulative cost impact analysis of HON control costs on the
selected chemicals to the industry as a whole was not
unreasonable.
6.3 OVERVIEW OF ECONOMIC IMPACTS
6.3.1 Nature of Impacts
The economic impacts of the HON on the SOCMI were
derived from several possible outcomes. Primary attention was
paid to price and output adjustments, because these estimates
were likely to be the most accurate. Impacts stemming from
these adjustments were the closure of a process unit and the
substitution of one production process for another.
6-5
-------
TABLE 6-2. SELECTED CHEMICALS GROUPED BY THE EIGHT
BASIC FEEDSTOCK CHEMICALS FROM WHICH THEY ARE DERIVED
Benzene
Styrene-Butadiene Rubber
Cyclohexylamine
Hydroquinone
Styrene
Acetone
Bisphenol-A
Propylene Glycol
Toluene
Terephthalic Acid
Phthalic Anhydride
Naphtha1ene
Acetone
Phthalic Anhydride
Methane
Formaldehyde
Chloroform
Methyl Tertiary Butyl Ether
Ethylene
Butadiene
Polybutadi ene
Styrene-Butadiene Rubber -
Ethylene Dichloride
Ethylene Glycol
Styrene
Triethylene Glycol
Propylene Glycol
Propylene
Cyclohexylamine
Acetone
•
Bisphenol-A
Propylene Glycol
Methyl Tertiary Butyl Ether
Acrylonitrile
Butvlenes
Butadiene
Methyl Tertiary Butyl Ether
6-6
-------
6.3.2 Price Adjustments and Reductions in Output
Installation of control equipment leads to increases in
production costs which, in-turn, spurs price increases in the
industry. Price increases were estimated' by calculating a
production-weighted cost increase for each chemical and
dividing it by industry revenue. For a detailed discussion of
methodology, see "Economic Impact Analysis of the Hazardous
Organic NESHAP."1 Thus, these cost increases will differ from
those shown in Table 6-1.
Market structure will have important implications on the
size of the price increase that will occur as a result of the
HON. In general, it can be said that if a market structure is
not perfectly competitive, firms in the industry will raise
prices less than they would in the perfectly competitive case.
The market structure in the SOCMI is characterized by the
following attributes:
a limited number of firms producing each
chemical,
a large degree of market concentration,
a large degree of vertical integration,
a large degree of horizontal integration,
barriers to entry and exit in the form of high
capital and raw materials costs.
Given these characteristics, the SOCMI can be characterized as
oligopolistic (dominated by a small number of companies) and
not perfectly competitive, and firms will absorb a portion of
HON control costs. Thus, the price increases are likely to be
lower than estimated. Moreover, price increases are apt to be
felt in end-use markets, due to the considerable amount of
captive consumption in the industry.
Because the industry demand curve is downward sloping,
each price increase will be accompanied by a reduction in
output. While these quantity adjustments were derived
directly from the control costs and the price elasticity of
demand for each chemical, it was not readily apparent how
these changes would be experienced at the process unit level.
6-7 "
-------
As data on average cost of production and process unit age
were not available, identifying the marginal process unit was
difficult. If there are notable differences in production
cost and process unit age, the quantity adjustment could be
absorbed by those firms that are marginal. If the process
units have similar control costs per unit of production, the
output reduction could be distributed across the industry.
Given the way in which the SOCMI is organized, it seems likely
that quantity adjustments would be distributed across the
industry, rather than falling on any one process unit. Most
facilities are owned by large parent corporations, that could
subsidize process units that might be less efficient. In
addition, the industry is dynamic, and cost increases will
stimulate alternative production processes to offset
competitive disadvantages. Also, chemical production will be
driven by the economics of co-products and by-products. Firms
will often have the flexibility to step up production of more
profitable chemicals to offset the burden of compliance.
6.3.3 Closure
In general, closure of a process unit might be predicted
if a significant percentage of output were to be wrested from
the marginal plant (i.e., the plant with the highest average
cost of production). In the SOCMI, however, there is reason
to believe that, even with significant price increases,
closure is highly unlikely.
The primary explanation for this is the flexibility of
chemical producers. In most cases, several chemicals other
than the selected chemicals are produced at facilities
producing the 20 selected chemicals analyzed. Table 6-3
presents this information, and indicates the lowest number of
chemicals, the highest number of chemicals, and the average
number of chemicals produced at a given facility. In only one
case is the average number of chemicals produced at a facility
equal to one. In two cases, as many as 20 chemicals are
produced at the same facility. Therefore, revenue at a given
6-8
-------
TABLE 6-3. NUMBER OF SOCMI CHEMICALS PRODUCED ON THE
SAME SITE AS FACILITIES PRODUCING SELECTED CHEMICALS*
Number of Chemicls
Produced on Same
Site
Sample Chemical
Butadiene
Styrene-Butadiene Rubber
Polybutadiene
Ethylene Dichloride
Ethylene Oxide
Cyclohexylamine
Hydroquinone
Ethylene Glycol
Styrene
Formaldehyde
Acetone
Chloroform
Triethylene Glycol
Bisphenol-A
Terephthalic Acid0
Propylene Glycol
Methyl -Tertiary Butyl
Ether
Phthalic Anhydride
Benzoic Acid
Acrylonitrile
Number of
Facilities
9
5
4
15
13
2
2
•
11
9
46
13
6
11
4
7
5
18
6
3
6
Low
1
NAb
NA
2
1
1
2
1
1
1
2
2
1
2
1
3
1
1
2
1
High
10
NA
NA
17
15
1
9
15
17
5
9
20
15
18
2
20
7
7
3
6
Average
5
NA
NA
5
6
1
6
6
4
1
5
9
6
8
2
10
2
2
3
aMay not include co-products and by-products.
bNA = Not available.
clncludes dimethyl terephthalate.
6-9
-------
facility is shared among a number of chemicals, and the
reduction in output of one of them is unlikely to lead to
closure. It is also possible that a decline in output of one
chemical could be cross-subsidized by another chemical. There
is flexibility in other areas as well. Some facilities have
the ability to use different production processes for the same
chemical if economic conditions dictate. Constructing new
process units with the ability to use different feedstocks is
becoming more common in the industry. Also, firms can vary
capacity utilization and idle parts of the facility, and can
run inventories up and down to cope with changes in demand.
In some cases, it is difficult to close facilities, as
different production processes are dependent on the same
' feedstock. In addition, the SOCMI is a dynamic industry in
which new processes and chemical formulations are constantly
being explored. The prospect of control costs could stimulate
changes of these types rather than closure of a process unit.
If the impacts are large, it is important to note that
ceasing production of one chemical does not always necessitate
closing the entire facility. Employment might be kept at the
same level, or production might be stepped up for another
chemical at the same facility.
Finally, the SOCMI is an oligopolistic industry dominated
by large parent corporations. While this ensures that a
portion of compliance costs will be absorbed by producers, it
also ensures the ability to finance purchase of control
equipment. Also, high capital and raw materials costs provide
barriers to exit. As long as firms are covering
these large fixed costs, closure will not ensue, even if the
facility is unprofitable in the short run.
For all of these reasons, closure due to the HON is, in
general, unlikely.
6.3.4 Process Chancres
It is quite possible that the HON will stimulate a shift
to an already existing production process, usher in a
production process that was previously uncompetitive, or
stimulate research and development into new production
6-10
-------
processes. Given the dynamic and flexible nature of the
SOCMI, it is likely that each of these will take place in
response to the HON. r *
6.3.5 Economic Impacts
Table 6-4 illustrates the summary of market adjustments
for the selected chemicals. The output changes were based on
the upper bound of the estimated price elasticity of demand,
which forecasts the maximum reduction in output. It should be
' noted that the change in price is an increase, and the change
in output is a decrease. These market adjustments were
derived from a production-weighted average price increase.
Each chemical is accompanied by one price adjustment and
quantity adjustment, except for benzoic acid. Because the
process units producing benzoic acid in this industry cater to
three separate markets (e.g., phenol [market 1], benzoate
plasticizers [market 2], and sodium and potassium benzoate
[market 3]), it was necessary to calculate three impacts.
Thus, 23 price and quantity adjustments are presented.
Table 6-5 categorizes the selected chemicals in three
ranges of percentage price increases: low, less than two
percent; intermediate, two to five percent; and high, greater
than five percent. Because these percentages were derived
from the production-weighted average price increase, they
differ from those presented in Table 6-1, which were based on
costs at the 50th percentile of industry output. Production-
weighted averages were not calculated for all 490 chemicals,
so direct comparison is not possible. However, general
conclusions can be drawn from those chemicals analyzed.
Table 6-6 extends these market adjustments to the possibility
for closure and process substitution. The possibility for
closure was based solely on the percentage output reduction as
compared with the smallest size facility in the industry. It
was stated in Section 6.3.3 that closure in any case is
unlikely. Thus, Table 6-6 shows the maximum case.
6-11
-------
TABLE 6-4. SUMMARY OF MARKET ADJUSTMENTS
Total Industry Control
Chemical Name
Butadiene
Styrene-Butadiene
Rubber
Polybutadiene
Ethylene Dichloride
Ethyl ene oxide
Cyclohexalyamine
Hydroquinone
Ethylene glycol
Styrene
Formaldehyde
Acetone
Chloroform
Triethylene glycol
Bisphenol-A
Terephthalic acid
Propylene glycol
Methyl -tert i ary
butyl ether
0
Phthalic anhydride
Benzoic acid
Market 1
Market 2
Market 3
Acrylonitrile
CAS
Number
106990
00043
00045
107062
75218
108918
123319
107211
100425
50000
67641
67663
112276
80057
100210
57556
1634044
85449
65850
107131
% A
% A Quantity
Pricea'b Production13 /c
0.97
0.28
0.30
1.24
0.65
2.01
0.97
0.94
0.49
2.81
1.07
2.97
"0.55
0.91
1.85
0.75
0.31
,
4.84
0,91
1.45
4.13
0.92
(0.96)
(0.28)
(0.30)
(0.82)
(0.22)
(1.33)
(0.96)
(t>.63)
(0.48)
(1.84)
'(0.71)
(0.96)
(0.37)
(0.61)
(1.22)
(0.74)
(0.10)
(3.12)
'
(0.90)
(1.42)
(3.96)
(0.61)
aThe percentage price increase is based on the production-
weighted average compliance cost. From Reference 1.
"A » Change in
cThe percentage change in quantity is based on the most
elastic estimate of demand elasticity, which forecasts the
higher percentage change in quantity.
6-12
-------
TABLE 6-5.
SUMMARY OF PERCENTAGE PRICE INCREASES FOR THE
SELECTED CHEMICALS3
Price Range/Chemical Name
Percentage Price
Increase
Total Industry
Control
High Increase; Over 5
None
Intermediate Increase; 2 to 5 Percent
Phthalic Anhydride
Benzoic Acid (for market 3)
Chloroform
Formaldehyde
Cyclohexylamine
Low Increase; Below 2 Percent
Terephthalic Acid
Benzoic Acid (for market 2)
Ethylene Dichloride
Acetone
Butadiene
Hydroquinone-
Ethylene Glycol
Acrylonitrile
Bisphenol-A
Benzoic Acid (for market 1)
Propylene Glycol
Ethylene Oxide
Triethylene Glycol
Styrene
Polybutadiene
Methyl-Tertiary Butyl Ether
Styrene-butadiene rubber
aThe percentage cost increases were based
control costs.
4.84
4.13
2.87
2.81
2.01
1.85
1.45
1.24
1.07
0.97
0.96
0.94
0.92
0.91
0.91
0.75
0.65
0.55
0.49
0.30
0.31
0.28
on total industry
6-13
-------
TABLE 6-6.
LIKELIHOOD OF CLOSURE AND PROCESS CHANGE UNDER
TOTAL INDUSTRY.CONTROLS OPTIONa
Chemical Name
Likelihood of
Closure
Likelihood of
Process Change
Butadiene
Styrene-butadiene rubber
Polybutadiene.
Ethylene Dichloride
Ethylene Oxide
Cyclohexylamine .
Hydroquinone
Ethylene Glycol
Styrene
Formaldehyde
Acetone
Chloroform
Triethylene Glycol
Bisphenol-A
Terephthalic Acid
Propylene Glycol
Methyl-Tertiary Butyl Ether
Phthalic anhydride
Benzoic Acid
Acrylonitrile
Possible
Unlikely
Unlikely
Possible
Unlikely
Unlikely
Unlikely
Possible
Possible
Possible
Possible
Unlikely
Unlikely
Possible
Unlikely
Possible
Possible
Possible
Unlikely
Unlikely
Unlikely
NAb
NAb
NAb
NAb
Possible
Unlikely
NAb
Possible
Probable
Possible
Unlikely
Unlikely
NAb
Unlikely
NAb
Unlikely
Possible
NAb
NAb
aClosure is in general unlikely.
most extreme case.
This table presents only the
s-c extreme case.
bNA = Not applicable, because only one process is used.
6-14
-------
6.3.6 Low Range Impacts
The low cost range includes 78 percent, or 18 of the 23
price increases shown.' Because the low cost range represents
the majority of the SOCMI, it is useful to consider the
implication of the results applicable to the remaining low
cost range chemicals. For the group of low cost chemicals,
maximum quantity adjustments range from 0.10 percent to
1.42 percent of industry output. For eight of these
chemicals, closure is unlikely even under the maximum case.
Closure is possible for seven other chemicals under the most
maximum case.
Seven chemicals in this range are produced by more than
one production process. For two of these, the cost
differential is large enough to predict possible process
changes. However, it is quite possible that the HON will
»
. stimulate research and development into new production
processes.
One qualification is necessary: Of those chemicals in
the low cost range, little can be inferred about chemicals
with annual production volumes of less than 10"MMkg.
6.3.7 Intermediate Range Impacts
The intermediate range includes 22 percent, or 5 of the
23 price increases displayed. Maximum quantity adjustments
range from 0.96 percent to 3.96 percent of industry output.
Closure is possible for chloroform, phthalic anhydride, and
formaldehyde, and unlikely for the other two chemicals.
Again, closure is possible only in the most extreme case and
is in general unlikely.
Three out of five chemicals in the intermediate cost
range are produced by more than one process. In each case,
the cost differential is large enough to predict process
changes.
One qualification is necessary: Of those chemicals in
the intermediate cost range, little can be inferred about
chemicals with annual production volumes of less than 10 MMkg.
6-15
-------
6.3.8 High Range Impacts
No chemicals in the selection were in the high cost
range and so no conclusions can be drawn for this range.
6.4 SMALL BUSINESS IMPACTS
The Regulatory Flexibility Act (Public Law 96-354,
September 19, 1980), requires Federal agencies to give special
consideration to the impact of regulation on small businesses.
The Act specifies that a regulatory flexibility analysis
must be prepared if a proposed regulation will have (1) a
significant economic impact on (2) a substantial number of
small entities. Economic impacts are considered significant
if:
Annual compliance costs increase total costs of
production by more than 5 percent,
Annual compliance costs exceed 10 percent of profits
for small entities,
Capital cost of compliance represent a significant
portion of capital available to small entities, and
The requirements of the regulation are likely to
result in closures of small entities.
A "substantial number" of small entities is generally
considered to be more than 20 percent of the small entities in
the affected industry.
A first step in determining small business impacts is
assigning an appropriate definition for what constitutes a
small entity in the SOCMI. The SBA defines small businesses
in the SIC major group 28 (chemicals and allied products) as
having employment from under 500 to under 1,000, depending on
the SIC. For this analysis, the upper bound of 1,000
employees will be used as the cutoff for assessing small
business impacts.
Table 6-7 lists 1990 sales and employment figures for
those companies in the SOCMI that produce the 20 chemicals
selected for the economic analysis. This is a comprehensive
6-16
-------
TABLE 6-7
1990 SALES AND EMPLOYMENT OF
SELECTED SOCMI MEMBERS
Company
Air Products
Allied Signal
American Cyanamid
American Petrofina
American Synthetic
Rubber Corp.
American Synpol
AMOCO
ARCO
Ashland Oil, Inc.
Atlantic Richfield
BASF
B.F. Goodrich
Borden
British Petroleum
BTL Specialty Resins
Corp.
Champlin Refining
Chevron
Citgo
, Conoco
Copolymer Rubber and
Chemical
Deltech
Diamond-Shamrock
Dow
DuPont
Eastman-Kodak
Exxon.
Firestone
Sales ($MM)
2,895
12,343
4,574
3,978
93
NAa
31,581
18,808
8,994
1,590
4,023
2,470 '
7,633
33,039
(£ mil.)
64
974
41,540
4,940
12,330
250
20
1,118
19,773
40,028
18,908
115,794
3,867
Number of Employees
14,000
105,800
32,012
3,997
, 311
2,600
54,524
27,300
33,400
26,600
133,759
11,892
46,300
118,050
200
800
54,208
3,300
19,000
710
200
84
62,100
NA
134,450
104,000
53,500
6-17
-------
TABLE 6-7.
1990 SALES AND EMPLOYMENT OF SELECTED
SOCMI MEMBERS (CONTINUED)
Company
Formosa Plastics
GE
General Tire
Georgia Gulf
Georgia Pacific
Goodyear
Hani in Group
Hercules
Hill Petroleum
Hoechst Celanese
Kalama
Koppers
Marathon (USX)
Mobil
Monsanto
Mt. Vernon Phenol
Occidental Petroleum
Olin
Oxy Petrochemicals
P.D. Glycol
Pfizer
Phillips Petroleum
Polysar
PPG
Quantum
Questra (PJaone-
Poulenc Data)
Rexene
Shell Oil
Spurlock
Sales ($MM)
625
55,300
1,300
1,110
12,665
11,273
1,110
3,200
4
1,500
NA
426
. 20,659
64,472
8,995
56,279
1,500
25,300
322
26
6,406
12,500
643
5,820
2,656
2,278
553
24,460
11
Number of Employees
1,700
292,000
9,600
1,350
63,000
107,671
1,350
19,867
1,070
2,400
NA
1,900
51,523
67,300
41,081
292,043
12,500
15,400
1,320
185
42,500
21,800
1,200
35,500
NAa
91,571
1,300
NA
41
6-18
-------
TABLE 6-7. 1990 SALES AND EMPLOYMENT OF SELECTED
Company
Stepan Co.
Sterling Chemical
Sun Co.
Texaco
Texas Olefins
Union Carbide
Velsicol
Vista Chemicals
Vulcan Materials
Sales ($MM)
346
581
13,270
41,822
300
8,740
100
. 779
1,080
t^j^t^r i
=================================
1,150
926
20,926
39,000
300
45,000
500
1,750
6,250
aNA = Not available.
6-19
-------
list of producers of the 20 selected chemicals, totaling
66 companies. Data were compiled from a collection of
1991 annual reports, the 1991 Million Dollar Directory3, and
Standard and Poor's Register of Corporations, Directors, and
Executives.4
As shown, 10 of the 66 companies fall below the 1000
employee cut-off. Thus, given this sample, only 15 percent of
the SOCMI can be classified as small entities.
The 1988 Handbook of Small Business Data5, which provides
information on the nature of businesses that typify different
SIC categories, supports this assertion. Each of the SIC
categories affected .by the HON are listed as "Large-Business-
Dominated ."
For control cost information, refer to Table 6-1.
Looking at the top half of the table, the data show that
82.5 percent of the entire population of 490 chemicals incur
cost increases lower than the 5 percent required to be
considered a significant impact. Thus, less than 20 percent
of the regulated entities incur cost increases in excess of
5 percent, and a regulatory flexibility analysis was therefore
unnecessary.
6.5 CONCLUSIONS
Price and quantity adjustments were calculated for 20
select chemicals whose production will be subject to the HON.
The majority o.f price increases — 78 percent — were below
2 percent. Ninety-one percent of reductions in output were
below 2 percent. -In general, impacts on the selected
chemicals were small. Because the selection did not
adequately represent the entire population of chemicals, it
cannot be said that the impacts were small for all chemicals.
Nevertheless, given the cost increases from Table 6.1, it is
safe to say that impacts for the SOCMI were, in general,
small. This is particularly true since the economic analysis
assumes application of control to all HAP emission points (the
TIC option). In reality, the regulatory options likely to be
considered for the HON require control of fewer emission
6-20
-------
points than the TIC option so costs and economic impacts would
be lower than estimated in this economic analysis.
Given the dynamic and flexible nature of the SOCMI, as
well as the oligopolistic market structure, closure in the
majority of cases is unlikely.
The notable impact of the HON will be the stimulation of
a shift to already existing production processes, the ushering
in of processes that were previously uncompetitive, or
stimulation .of research and development into new production
processes. It is likely that each of these will take place in
response to the HON.
In conclusion, the SOCMI is a dynamic industry that
responds quickly.to changes in the economic environment.
Increasing costs, driven by the HON, will serve to reinforce
moves to lower-cost production processes, facilities .and
process units engineered for flexibility in feedstock choice,
and facilities capable of producing a variety of chemical
substitutes depending on costs and market demand.
6-21
-------
6.6 REFERENCES
1. U. S. Environmental Protection Agency. Economic Impact
Analysis of the Hazardous Organic NESHAP. Draft.
Research Triangle Park, NC. November 1992. Chapter 2.
2. Small Business Administration ? Small Business Size
Standards; Final and Interim Final Rules. Federal
Register. -Vol. 13, Part 121. Washington, DC. Office of
the Federal Register. December 21, 1989.
3. Dun's Marketing Services. Million Dollar Directory.
Parsippany, New Jersey. 1991.
4. Register of Corporations, Directors, and Executives. New
York, Standard and Poor's Corporation Publishers. 1991.
5. Handbook of Small Business Data. Washington, DC. U. S.
Government Printing. Office. November 1988,
6-22
-------
APPENDIX A
SOCMI CHEMICALS
For the HON analysis, the SOCMI was defined as production of
a specific set of chemicals. The list of SOCMI chemicals for the
HON was a composite of chemicals from the following sources:
1. "Industrial Organic Chemical Use Trees" prepared by
Paul W. Spaite Company and Radian Corporation,1
2. Standards of Performance for Equipment Leaks of VOG in
SOCMI,2
3. Proposed Standards of Performance for SOCMI Reactor
Processes,3
4. Standards of Performance for SOCMI Distillation
Operations,4
»
5. Standards of Performance for SOCMI Air Oxidation
Processes.5
In addition to listing the chemicals considered part of the
overall definition of SOCMI, the chemicals listed in each of the
above sources is indicated by an "x" in the appropriate column.
Our analysis used the chemical lists from the four NSPS and the
Chemical Trees to make the set of SOCMI chemicals used in the HON
analysis all inclusive.
The Appendix also serves to illustrate the EPA's past
rulemaking efforts in relation to the HON SOCMI chemicals. The
four sources used to define the HON SOCMI chemicals are recent
NSPS. The Air Oxidation Processes NSPS and the distillation
operations NSPS were both developed in the mid-1980s and
promulgated in 1990 and 1991, respectively. The reactor
processes NSPS was proposed in 1990. These rulemakings served as
a starting point in defining the chemicals the HON would cover.
A-l
-------
TABLE Al. SOCMI CHEMICALS
Chemi cal Name
Acenaphthene
Acetal
Acetal dehyde
Acetal dol
Acetami de
Acetanilide
Acetic add
Acetlc'anhydride
Acetoacetanilide
Acetoamides
t Acetone
Acetone cyanohydrln
Acetonitrlle
Acetophenone
Acetyl chloride
Acetyl ene
Acetylene tetrabromide
Acrolein
Acryl amide
Acrylic a'cid
Acrylonltrile
Adlpic acid
Adiponitrile
Alcohols, C-ll or lower, mixtures
Alcohols, C-12 or higher, mixtures
Alizarin
Alkyl anthraqui nones
Alkyl naphthalene sulfonates
Alkyl naphthalenes
Ally! alcohol
Allyl bromide
Allyl chloride
Allyl cyanide
Aluminum acetate
Included
in HON
Impacts
Analysis
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Chemical
Trees3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Air
Oxidation
Processes'3
NSPS
X
X
X
X
X
X
•
X
X
Distillation
Operations0
NSPS
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Reactor
Processes'-'
NSPS
X
X
• X
X
X
X
X
X
X
X
X
X
X
Equipment
Leaks6
NSPS
X
X
X
X
X
X
X
X
X •
X
X
X
X
X
X
X
X
X
X
X
X
X
X
A-2
-------
TABLE Al. SOCMI CHEMICALS (CONTINUED)
Chemical Name
Aluminum formates
Aminobenzoic acid (p-)
Ami noethyl ethanol ami ne
Aminophenol sulfonic acid
Aminophenol (p-)
Amino 3,4,6-trichlorophenol (2-)
Ammonium acetate
Ammonium thiocyanate
Amylene
Amylenes, mixed
Amy! acetates ,
Amy! alcohol (n-)
Amyl alcohol (tert-)
Amyl alcohols (mixed)
Amyl chloride (n-)
Amyl chlorides (mixed)
Amyl ether
Amyl ami nes
Aniline
Aniline hydrochloride
Anisidine (o-)
Anisole
Anthracene
Anthranil ic acid
Anthraquinone
Azobenzene
Barium acetate
Benzaldehyde
Benzamide
Benzene
Benzenedi sulfonic acid
Benzenesulfonic acid
Benzenesulfonic acid Ci0.16-alkyl
derivatives, sodium salts
Included
in HON
Impacts
Analysis
X
X
X
X
X
X
X
X
X
X
X
X
Chemical
Trees3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Air
Oxidation
Processes'3
NSPS
X
X
Distillation
Operations0
NSPS
X
X
X
X
X
Reactor
Processes1^
NSPS
X
X
X
X
X
X
^=^
Equipment
Leaks6
NSPS
• x
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
A-3
-------
TABLE Al. SOCMI CHEMICALS (CONTINUED)
Chemi cal Name
Benzldine
Benzll
Benzilic acid
Benzoguanamine
Benzole add
Benzoin
Benzonitrile
Benzophenone
Benzotri chloride
Benzoyl chloride
Benzoyl peroxide »
Benzyl acetate
Benzyl alcohol
Benzyl benzoate
Benzyl chloride
Benzyl di chloride
Benzyl ami ne
Benzyl ideneacetone
Biphenyl
Bisphenol A
Bis (Chi oromethyl ) Ether
Brometone
Bromobenzene
Bromoform
Bromonaphthal ene
Butadiene (1,3-)
Butadiene and Butene fractions
Butane
Butanes, mixed
Butanediol (1.4-)
Butenes, mixed
Butyl acetate (n-)
Butyl acetate (sec-)
Butyl acetate (tert-)
Included
in HON
Impacts
Analysis
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Chemi cal
Trees3
X
X
X
. X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Air
Oxidation
Processes'3
NSPS
X
X
Distillation
Operations0
NSPS
X
X
X
X
X
X
X
X
X
X
X
X
Reactor
Processes'-'
NSPS
X
X
X
X
X
X
X
X
X
X
Equi pment
Leaks6
NSPS
X
X
X
X
X
X
X
X
X '
X
X
X
X
X
X
X
X
X
X
A-4
-------
TABLE Al. SOCMI CHEMICALS (CONTINUED)
•p.
Chemi cal Name
Butyl acryTate (n-)
* Butyl alcohol (n-)
Butyl alcohol (sec-)
Butyl alcohol (tert-)
Butyl benzoate
Butyl chloride (tert-)
Butyl hyroperoxide (tert-)
Butyl mercaptan (n-)
Butyl mercaptan (tert-)
Butyl methacrylate (n-)
Butyl methacrylate (tert-)
Butyl phenol (tert-)
Butyl ami ne (n-)
Butyl ami ne (s-)
Butylamine (t-)
Butyl benzene (tert-)
Butylbenzoic acid (p-tert-)
Butyl benzyl phthalate
Butyl ene glycol (1,3-)
Butyl enes (n-)
2-Butyne-l,4-diol
Butyraldehyde (n-)
Butyric acid (n-)
Butyric anhydride (n-)
Butyrolactone
Butyronitrile
Calcium acetate
Calcium propionate
Caproic acid
Caprolactam
" Carbaryl
Carbazole
Carbon disulfide
Carbon tetrabromide
1 "
Included
in HON
Impacts
Analysis
X
X
X
X
X
X
_X
X
X
X
=j=^==:^
Chemi cal
Trees2
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
=5=^=^=
Air
Oxidation
Processes'3
NSPS
X
1
Distillation
Operations0
NSPS
X
X
X
X
X
X
X
X
X
X
x
=j==^=
Reactor
Processes^
NSPS
X
X
X
X
.
X
X
X
X
X
X
X
=:=====
Equipment
Leaks6
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
A-5
-------
TABLE Al. SOCMI CHEMICALS (CONTINUED)
Chemi cal Name
Carbon tetrachloride
Carbon tetra fluoride
Cellulose acetate
Chloral
Chlofanil
Chloracetlc acid
Chloroacetophenone (2-)
Chi oroani line (m-)
Chloroaniline (o-)
Chi oroani line (p-)
Chi orobenzal dehyde
Chi orobenzene
Chlorobenzoic acid
Chi orobenzotri chloride (o-)
Chi orobenzotri chloride (p-)
Chlorobenzoyl chloride (o-)
Chlorobenzoyl chloride (p-)
Chi orodi f 1 uoroethane
Cl orodi f 1 uoromethane
2-Chloro-4-(ethylamino)-6-
( 1 sopropyl ami no ) -S-tr i azi ne
Chi orof 1 uorocarbons
Chloroform
Chlorohydrin
Chi oronaphthal ene
Chloronitrobenzene (1,3-)
Chloronitrobenzene (o-)
Chloronitrofaenzene (p-)
Chlorophenol (m-)
Chlorophenol (o-)
Chlorophenol (p-)
Chloroprene
Chlorosulfonic acid
Chlorotoluene (m-)
Included
in HON
Impacts
Analysis
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Chemi cal
Trees3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Air
Oxidation
Processes'3
NSPS
Distillation
Operations0
NSPS
X
X
X
X
X
X
Reactor
Processes"
NSPS
X
X
•
X '
X
X
X
Equipment
Leaks6
NSPS
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
x •
X
X
X
A-6
-------
TABLE Al. SOCMI CHEMICALS (CONTINUED)
Chemical Name
Chlorotoluene (o-)
Chi orotol uene (p-)
Chi orotri f 1 uoroethyl ene
Chi orotri f 1 uoromethane
Choline chloride
Chrysene
Cinnamic acid
Citric acid
Cobalt acetate
Copper acetate
Cresol (m-)
Cresol s/cresylic' acid (mixed)
Cresol s (o-)
Cresol s (p-)
Crotonaldehyde
Crotonic acid
Cumene
Cumene hydroperoxide
Cyanami de
Cyanoacetic acid
Cyanoformamide
Cyanogen chloride
Cyanuric acid
Cyanuric chloride
Cyclohexane
Cyclohexane, oxidized
Cyclohexanol
Cyclohexanone
Cyclohexanone oxime
Cyclohexene
Cyclohexylamine
Cyclooctadiene
Cyclooctadiene (1,5-)
Cyclopentadiene (1,3)
Includec
in HON
Impacts
Analysis
X
X
X
X
X
X
X
X
.
X
X
X
X
X
X
Chemi cal
Treesa
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
==^=^
Air
Oxidation
Processes'3
NSPS
X
X
.
X
X
Distillation
Operations0
NSPS
X
X
X
X
X
X
X
X
X
X
X
X
Reactor
Processes'^
NSPS
X
X
X
X
X
X
X
X
X
X
Equipment
Leaks6
NSPS
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
A-7
-------
TABLE Al. SOCMI CHEMICALS (CONTINUED)
Chemical Name
Cyclopropane
Decahydronaphthal ene
Decanol
01 acetone alcohol
Diacetoxy-2-butene (1,4-)
Diallyl isophthalate
•
Diallyl phthalate
Olamlnobenzoic acids
Diaminophenol hydrochl ori de
Oibromomethane
Dibutanized aromatic concentrate
Difeutoxyethyl phthalate
Oichloroaniline (all isomers)
Oichlorobenzene (1,4-) (p-)
Oichlorobenzene (m-)
Oichlorobenzene (o-)
Oichlorobenzidine (3,3-)
1 , 4-Di chl orobutene
Di chl orodi f 1 uoromethane
Dichlorodimethylsi lane
Dichloroethane (1,2-)
Dichloroethyl ether
Oichloroethylene (1.2-)
Oi chl orof 1 uoromethane
Dichlorohydrin (a-)
Di chl oron i trobenzenes
Dichloropentanes
Dichlorophenol (2,4-)
Oichloropropane (1,1-)
Dichloropropene (1,3-)
Oi chl oropropene/di chl oropropane (mi xed )
Oi chl orotetraf 1 uoroethane
Oichloro-1-butene (3,4-)
Oichloro-2-butene (1,4-)
Included
in HON
Impacts
Analysis
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Chemical
Trees3
X
X
X
X
X
X
X
X
X
X
X
X
X
X,
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Air
Oxidation
Processes"
NSPS
Distillation
Operations0
NSPS
X
X
X
X
X
X
X
Reactor
Processes^
NSPS
X
X
X
X
X
X
Equipment
Leaks6
NSPS
X
X
X
X
X
X
X
X
X
X
X
A-8
-------
TABLE Al. SOCMI CHEMICALS (CONTINUED)
Chemical Name
Dicyanidi amide
D i eye 1 ohexy 1 ami ne
Dicyclopentadiene
Diethanolamine
Oi ethyl phthalate
01 ethyl sulfate
D1 ethyl ami ne
Oi ethyl aniline (2,6-)
Oi ethyl aniline (N,N-)
Di ethyl benzene
D-i ethyl ene glycol
Di ethyl ene glycol di butyl ether
Di ethyl ene glycol di ethyl ether
Oi ethyl ene glycol dimethyl ether
Di ethyl ene glycol monobutyl ether
acetate
Di ethyl ene glycol monobutyl ether
Di ethyl ene glycol monoethyl ether
acetate
Di ethyl ene glycol monoethyl ether
Di ethyl ene glycol monohexyl ether '
Di ethyl ene glycol monomethyl ether
acetate
Di ethyl ene glycol monomethyl ether
Difluoroethane (1,1-)
Di isobutylene
Diisodecyl phthalate
Diisononyl phthalate
Diisooctyl phthalate
Diisopropyl amine
Di ketene
Dimethyl acetamide
Dimethyl benzidine (3,3-)
Dimethyl ether - N,N
Dimethyl formamide (NN-)
Included
in HON
Impacts
Analysis
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X '
X
X
Chemical
Trees3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
a=
Air
Oxidation
Processes"
NSPS
=====
Distillation
Operations0
NSPS
X
X
X
Reactor
Processes1^
NSPS
X
X
X
X
X
Equipment
Leaks8
NSPS
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
A-9
-------
TABLE Al. SOCMI CHEMICALS (CONTINUED)
Chemical Name
Dimethyl hydrazine (1,1-)
Dimethyl phthalate
Dimethyl sulfate
Dimethyl sulfide
Dimethyl sulf oxide
Dimethyl terephthal ate
CM methyl ami ne
Dimethyl ami noethanol (2-)
Oimethylaniline - N,N
Dinitrobenzenes
Oinltrobenzoic acid (3.5-)
Oinitrophenol (2,4-)
Oinitrotoluene (2,3-)
Oinitrotoluene (2,4-)
Oinitrotoluene (2,6-)
Dinitrotoluene (3,4-)
Oioctyl phthalate
Dioxane
Oioxolane
Diphenyl methane
Oiphenyl oxide
Diphenyl thiourea
Diphenyl ami ne
Dipropylene glycol
Di(2-methoxyethyl) phthalate
Oi -o-tol yguani di ne
Dodecene (branched)
Dodecene (n-)
Dodecyl benzene (branched)
Dodecyl benzene, nonlinear
D"odecylbenzenesulfonic acid
Dodecyl mercaptan (branched)
Dodecyl phenol (branched)
Oodecyl aniline
Included
in HON
Impacts
Analysis
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Chemi cal
Trees3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Air
Oxidation
Processes'5
NSPS
X
Distillation
Operations0
NSPS
X
X
X
X
X
X
X
X
Reactor
Processes1^
NSPS
X
•
X
X
X
X
X
X
X
Equipment
Leaks8
NSPS
X
X
X
X
X
X
X.
X
X
X
X
X
X
X
X
A-10
-------
TABLE Al. SOCMI CHEMICALS (CONTINUED)
Chemical Name
Oodecyl benzene (n-)
Oodecyl phenol
Epichlorohydrin
Ethane
Ethanol
Ethanol amines (all isomers)
Ethyl acetate
Ethyl acetoacetate
Ethyl acrylate •
Ethyl benzene
Ethyl bromide *
Ethyl caproate
Ethyl chloride
Ethyl chloroacetate
Ethyl ether
Ethyl hexanol (2-) .
Ethyl mercaptan
Ethyl orthoformate
Ethyl oxalate
Ethyl sodium oxal acetate
Ethyl ami ne
Ethyl aniline (n-)
Ethylaniline (o-)
Ethyl cellulose
Ethyl cyanoacetate
Ethyl ene
Ethyl ene carbonate •
Ethyl ene chlorohydrin
Ethyl ene di bromide
Ethyl ene glycol
Ethyl ene glycol di acetate
Ethyl ene glycol di butyl ether
Ethyl ene glycol di ethyl ether
Ethyl ene glycol dimethyl ether
^=^=
Includec
in HON
Impacts
Analysis
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Chemical
Trees3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Air
Oxidation
Processes'3
NSPS
' -
Distillation
Operations'3
NSPS
X
X
X
X
X
X
X
X
X
X
Reactor
Processes0
NSPS
X
X
X
X
X
X
X
X
X
X
Equipment
Leaks6
NSPS
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
x
A-ll
-------
TABLE Al. SOCMI CHEMICALS (CONTINUED)
Chemical Name
Ethyl ene glycol monoacetate
Ethyl ene glycol monobutyl ether
acetate
Ethyl ene glycol monobutyl ether
Ethyl ene glycol monoethyl ether
acetate
Ethyl ene glycol monoethyl ether
Ethyl ene glycol monohexyl ether
Ethyl ene glycol monomethyl ether
acetate
Ethyl ene glycol monomethyl ether
Ethyl ene glycol monooctyl ether
Ethyl ene glycol monophenyl ether
Ethyl ene glycol monopropyl ether
Ethyl ene oxide
Ethyl enedi ami ne
Ethyl enedi ami ne tetracetic acid
Ethyl eneimine
2-Ethylhexanal
Ethylhexanoic acid
Ethyl hexyl acrylate (2-)
( 2 - Ethyl hexyl ) ami ne
Ethyl hexyl succinate (2-)
Ethyl methyl benzene
6-Ethyl -1.2.3. 4-tetrahydro
9, 10-antracenedione
Fluoranthene
Formaldehyde
Formamide
Formic acid
Fumaric acid
Furfural
Glutaraldehyde
Glyceraldehyde
Glycerol
Included
in HON
Impacts
Analysis
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Chemical
Trees3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
•
X
X
X
X
- x
X
X
X
X
X
X
X
Air
Oxidation
Processes'3
NSPS
X
X
X
Distillation
Operations0
NSPS
X
X
X
X
X
X
•
X
X
X
X
X
Reactor
Processes0'
NSPS
X
X
X
X
X
X
X
X
Equipment
Leaks6
NSPS
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
A-12
-------
TABLE Al. SOCMI CHEMICALS (CONTINUED)
1 II 1.1— ^ •— ^ ^^_^^^^^_
Chemical Name
Glycerol dichlorohydrin
Glycerol tri ether
Glyci'dol
Glycine
Glycol ethers
Glyoxal
Guanidine
Guanidine nitrate
n-Heptane
Heptenes
Hexachl orobenzene
Hexachl orobutadi ene
Hexachl orocycl opentadi ene
Hexachl oroe'thane
Hexadecyl alcohol
Hexadecyl chloride
Hexadiene (1,4-)
Hexamethyl enedi ami ne
Hexamethyl ene diamine adipate
Hexamethyl ene glycol
Hexamethyl enetetrami ne
Hexane
Hexanetroil (1,2,6-)
2-Hexenedi ni tri 1 e
3-Hexenedinitrile
Hexyl alcohol
Hexylene glycol
Higher glycol s
Hydrogen cyanide
Hydroquinone
Hydroxyadi pal dehyde
Hydroxybenzoic acid (p-)
Imi nodi ethanol (2,2-)
Isoamyl alcohol
:
Includec
in HON
Impacts
Analysis
X
X
X
X
X
X
X
X
X
X
X
X
Chemical
Trees3
X
X
X
X
X
X
X .
X
X
X
X
X
X
X
X
X
X
X
X
X
X'
X
X
X
X
'X
Air
Oxidation
Processes'3
NSPS
X
X
=^=^==
Distillation
Operations0
NSPS
X
X
X
X
X
X
X
X
X
X
-
Reactor
Processes^
NSPS
X
X
X
X
X
X
Equipment
Leaks6
NSPS
X
X
-
X
X
X
X
X
X
X
X
x .
X
X
A-1.3
-------
TABLE Al. SOCMI CHEMICALS (CONTINUED)
Chemical Name
Isoamyl chloride (mixed)
Isoamylene
Isobutane
Isobutanol
Isobutyl acetate
Isobutyl aery late
Isobutyl methacrylate
Isobutyl vinyl ether
Isobutyl ene
I sobutyral dehyde
Isobutyric acid
Isodecanol
Isohexyldecyl alcohol
Isononyl alcohol
Isooctyl alcohol
Isopentane
Isophorone
Isophorone nitrile
Isophthalic acid
Isoprene
Isopropanol
Isopropyl acetate
Isopropyl chloride
Isopropyl ether
Isopropyl ami ne
Isopropyl phenol
Ketene
Lactic acid
Lauryl dimethylamine oxide
Lead acetate
Lead phthalate
Lead subacetate
Linear alcohols, ethoxylated, mixed
Included
in HON
Impacts
Analysis
X
X
«
X
X
X
X
X
Chemi cal
Trees3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Air
Oxidation
Processes"
NSPS
X
X
Distillation
Operations'3
NSPS
X
X
X
X
X
X
X
X
X
X
X
Reactor
Processes"
NSPS
-
X
X
X
X
X
X
X
X
X
Equipment
Leaks6
NSPS
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
A-14
-------
TABLE Al. SOCMI CHEMICALS (CONTINUED)
Chemical Name
Linear alcohols, ethoxylated, and
sul fated, sodium salt, mixed
Linear alcohols, sulfated,- sodium
salt, mixed
Linear alkyl benzene
Magnesium acetate
Maleic acid
Maleic anhydride
Maleic hydrazide
Mai ic acid
Manganese acetate
Mel ami ne
Mercuric acetate
Mesityl oxide
Metanil ic acid
Methacrylic acid
Methacrylonitrile
Methallyl alcohol
Methallyl chloride
Methane
Methanol
Methionine
Methyl acetate
Methyl acetoacetate
Methyl acrylate
Methyl anthranilate
Methyl bromide
Methyl butenols
Methyl butynol
Methyl chloride
Methyl ethyl ketone
Methyl formate
Methyl hydrazine
Methyl vodide
Included
in HON
Impacts
Analysis
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Chemical
Trees3
X
X
X
X
X
X
X
X
X
X
X
X
X.
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Air
Oxidation
Processes'3
NSPS
X
X
_
Distillation
Operations0
NSPS
X
. X
X
X
X
X
X
X
X
X
X
Reactor
Processes0"
NSPS
X
X
X
X
X
X
X
Equipment
Leaks5
NSPS
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
A-15
-------
TABLE Al. SOCMI CHEMICALS (CONTINUED)
Chemical Name
Methyl isobutyl carbinol
Methyl Isobutyl ketone
Methyl i socyanate
Methyl mercaptan
Methyl methacryl ate
Methyl phenyl carbinol
Methyl salicylate
Methyl tert butyl ether
Methyl ami ne
Methylaniline (n-)
ar-Methyl benzenedl ami ne
Methyl butanol (2-)
Methyl cycl ohexane
Methyl cycl ohexanol
Methyl cycl ohexanone
Methyl ene chloride
Methylene dianiline (4,4'-)
Methyl one di phenyl dii socyanate
Methyl ionones (a-)
Methyl napthtal ene (1-)
Methyl naphthalene (2-)
Methyl pentane (2-)
Methyl pentynol
1-Methyl -2-pyrrol i done
Methyl styrene (a-)
Methyl -1-pentene (2-)
Morpholine
Naphthalene
Naphthalene sulfonic acid (a-)
Naphthalene sulfonic acid (b-)
Haphthenic acids
Naphthol (a-)
Naphthol (b-)
Naphthol sulfonic acid (1-)
Included
in HON
Impacts
Analysis
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Chemi cal
Trees3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
x .
X
X
X
X
X
X
X
X
X
Air
Oxidation
Processes'3
NSPS
X
Distillation
Operations0
NSPS
X
X
X
X
X
X
Reactor
Processes0'
NSPS
X
X
X
X
X
X
X
Equipment
Leaks8
NSPS
X
X
X
X
X
X
X
X
X
X
•
X
X
X
X
X
X
A-16
-------
TABLE Al. SOCMI CHEMICALS (CONTINUED)
Chemical Name
Naphthylamine sulfonic acid (1,4-)
Naphthyl ami ne sulfonic acid (2,1-)
Naphthylamine (1-)
Naphthyl ami ne (2-)
Neohexane
Neopentanoic acid
Neopentyl glycol
Nickel formate
Nitriloacetic acid
Nitroanil itie (m-)
Nitroaniline (o-)
Nitroaniline (p-)
Nitroani?ole (o-)
Nitroanisole (p-)
Nitrobenzene
Nitrobenzoic acid (m-)
Nitrobenzoic acid (o-)
Nitrobenzoic acid (p-)
Nitrobenzoyl chloride (p-)
Nitroethane
Ni troguanidine
Ni tromethane
Nitronaphthalene (1-)
Nitrophenol (4-) (p-)
Nitrophenol (o-)
Nitropropane (1-)
Nitropropane (2-)
Ni trotoluene
Nitrotoluene (2-) (o-)
Ni trotoluene (3-) (m-)
Nitrotoluene (4-) (p-)
Nitroxylene
Nonene
Nonyl alcohol
Included
in HON
Impacts
Analysis
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Chemi cal
Trees3
X
X
X
X
X
' X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Air
Oxidation
Processes"
NSPS
Distillation
Operations0
NSPS
•
X
X
Reactor
Processes1^
NSPS
X
X
x
Equipment
Leaks6 .
NSPS
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
A-17
-------
TABLE Al. SOCMI CHEMICALS (CONTINUED)
Chemical Name
Nonyl benzene (branched)
Nonyl phenol
Nonyl phenol (branched)
Nonyl phenol , ethoxyl ated
N-Vfnyl-2-pyrrolidine
Octane
Ocetene-1
Octylamine (tert-)
Octyl phenol
011 -soluble petroleum sulfonate
calcium salt
01-1 -soluble petroleum sulfate,
sodium salt
Oxalic acid
Oxami de
Oxo chemicals
Para formaldehyde
Paraldehyde
Pentachlorophenol -
Pentaerythri tol
Pentaerythritol tetranitrate
Pentane
Pentanethiol
Pentanol (2-)
Pentanol (3-)
Pentene (1-)
Pentene (2-)
3-Pentenenitrile
Peracetic acid
Perchloroethylene
Perchloromethyl mercaptan
Phenacetin
Phenanthrene
Phenetidine (o-)
Included
in HON
Impacts
Analysis
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Chemi cal
Trees3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Air
Oxidation
Processes"
NSPS
Distillation
Operations0
NSPS
X
X
X
X
X
X
X
X
Reactor
Processes1-'
NSPS'
X
X
X
X
X
X
X
Equipment
Leaks6
NSPS
X
X
,
• '
X
X
X
X
X
X
X
A-18
-------
TABLE Al. SOCMI CHEMICALS (CONTINUED)
Chemical Name
Phenetidine (p-)
Phenol
Phenol phthalein
Phenol sulfonic acids
Phenylanthranilic acid
Phenylenediamine (m-)
Phenylenediamine (o-)
Phenylenediamine (p-)
1-Phenyl ethyl hydroperoxide
Rhenylmethyl pyrazol one
Phenyl propane
Phloroglucinol
Phosgene
Phthalic acid
Phthalic anhydride
Phthal imide
Phthalonitrile
Picoline (a-)
Picoline (b-)
Picramic acid
Picric acid
Piperazine
Pi peri dine
Piperylene
Polybutenes
Polyethylene glycol
Polypropylene glycol
Potassium acetate
Propane
Prppiolactone (b-)
Propionaldehyde
Propionic acid
Propyl acetate (n-)
Propyl alcohol (n-)
Included
in HON
Impacts
Analysis
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Chemical
Trees3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
• X
X
X
X
X
X
X
X
X
X
X
X
Air
Oxidation
Processes"
NSPS
X
X
X
Distillation
Operations0
NSPS
X
•
X
X
X
••
X
X
x
Reactor
Processes^
NSPS
X
. X
X
X
X
X
X
x
Equipment
Leaks6
NSPS
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
x
A-19
-------
TABLE Al. SOCMI CHEMICALS (CONTINUED)
Chemical Name
Propyl chloride
Propylamine
Propyl ene
Propyl ene carbonate
Propyl ene chl orohydri n
Propyl ene d1 chloride
Propyl ene glycol
Propyl ene glycol monomethyl ether
Propyl ene oxide
Pseudocumene
Pseudocumi di ne
Pyrene
Pyridine
Pyrrolidone (2-)
p-tert-Butyl toluene
Quinone
Resorcinol
Resorcylic acid
Salicylic acid
Sebacic acid
Sodium acetate
Sodium benzoate
Sodium carboxymethyl cellulose
Sodium chloroacetate
Sodium cyanide
Sodium dodecyl benzene sulfonate
Sodium Formate
Sodium methoxide
Sodium oxalate
Sodium phenate
Sodium propionate
Sorbic acid
Sorbitol
Stilbene
Included
in HON
Impacts
Analysis
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Chemical
Treesa
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
_x
X
X
Air
Oxidation
Processes'3
NSPS
X
Distillation
Operations0
NSPS
X
X
X
• X
X
Reactor
Processes"
NSPS
X
X
X
X
Equipment
Leaks6
NSPS
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
A-20
-------
TABLE Al. SOCMI CHEMICALS (CONTINUED)
Chemi cal Name
Styrene
Succinic acid
Succinonitrile
Sulfanilic acid
Sulfolane
Synthesis gas
Tannic acid
Tartaric acid
Terephthal ic acid
Terephthaloyl chloride
Tetrabromophthalic anhydride
Tetrachlorobenzene (1,2,3,5-)
Tetrachlofobezene (1,2,4,5-)
Tetrachloroethane (1,1,2,2-)
Tetrachlorophthalic anhydride
Tetraethyl lead
Tetraethylene glycol
Tetraethyl enepentami ne
Tetrafi uoroethyl ene
Tetrahydrofuran
Tetrahydronapthal ene
Tetrahydrophthal ic anhydride
Teteramethyl enedi ami ne
Tetramethyl lead
Tetra (methyl -ethyl ) lead
Tetramethyl ethyl enedi ami ne
Thiocarbanil ide
Thiourea
Toluene
Toluene 2,4 diamine
Toluene 2,4 diisocyanate
•
Toluene di isocyanates (mixture)
Toluene sulfonamides (o- and p-)
Toluene sulfonic acids
Included
in HON
Impacts
Analysis
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Chemi cal
Trees3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Air
Oxidation
Processes'3
NSPS
X
X
•
Distillation
Operations0
NSPS
X
X
X
X
X
X
X
X
Reactor
Processes1^
NSPS
X
X
X
X
X
X
X
X
X
Equipment
Leaks8
NSPS
X
X
X
X
X
X
X
X
X
-
X
X
X
X
X
X
X
X
X
X
x
A-21
-------
TABLE Al. SOCMI CHEMICALS (CONTINUED)
Chemi cal Name
Toluene sulfonyl chloride
ToluicHne (o-)
Trichloroacetic add
Tri chl oroani line (2,4,6-)
Trichlorobenzene (1,2,3-)
Triohlorobenzene (1,2,4-)
Trichlorobenzene (1,3,5-)
Trichloroethane (1,1,1-)
Tr1 chl oroethane (1,1,2-)
Tri chl oroethyl ene
Tri chl orof 1 uoromethane
Trichlorophenol (2,4,5-)
Trlchloropropane (1,2,3-)
Trfchlorotrifluoroethane (1,2,2-1,1,2)
Tricresyl phosphate
Tridecyl alcohol
Triethanolamine
Tri ethyl aralne
Tri ethyl ene glycol
Tri ethyl ene glycol dimethyl ether
Tri ethyl ene glycol roonoethyl ether
Tri ethyl ene glycol monomethyl ether
Triisobutylene
Trimellitic anhydride
Trimethyl pentanol
Trimethylamine
Trinvethyl cycl chexanol
Trimethyl cycl ohexanone
Tr imathyl cycl ohexyl ami ne
Tri methyl ol propane
Tri methyl pentane (2,2,4-)
Trimethyl -1 ,3-pentanedi ol (2,2,4-)
Tripropylene glycol
Urea
Included
in HON
Impacts
Analysis
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Chemical
Trees3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Air
Oxidation
Processes'5
NSPS
Distillation
Operations0
NSPS
X
X
X
X
X
X
X
'
Reactor
Processes"
NSPS
X
X
X
X
X
X
X
Equi pment
Leaks6
NSPS
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
A-22
-------
TABLE Al. SOCMI CHEMICALS (CONCLUDED)
Chemi cal Name
Vinyl acetate
Vinyl chloride
Vinyl toluene
Vinyl cyclohexene (4-)
Vinylidene chloride
Vinyl (N)-pyrrolidone(z)
Vinylpyridine
Xanthates
Xylene Sulfonic Acid
Xylene (m-)
Xylenes (mixtures)
Xylenes (o-)
Xylenes (p-)
Xylenol
Xylenol (2,3-)
Xylenol (2,4-)
Xylenol (2,5-)
Xylenol (2,6-)
Xylenol (3,4-)
Xylenol (3,5-')
Xylidine (2,3-)
Xylidine (2,4-)
Xylidine (2,5-)
Xylidine (2,6-)
Xylidine (3,4-)
Xylidine (3,5-)
Zinc acetate
Included
in HON
Impacts
Analysis
X
X
X
X
X
X
. X
X
X
X
Chemical
Trees3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Air
Oxidation
Processes'3
NSPS
•
Distillation
Operations0
NSPS
X
X
X
. X
X
X
X
Reactor
Processes0*
NSPS
X
X
X
X
X
X
X
Equipment
Leaks6
NSPS
X
X
X
X
X
X
X
X
X
X
X
X
X
a Reference 1.
*> Reference 5.
c Reference 4.
d Reference 3.
e Reference 2.
A-23
-------
REFERENCES
1. Meserole, N. P., Spaite, P. W. , Hall, T. A. Industrial
Organic Chemical Use Trees. Prepared for U. S. Environmental
Protection Agency, Office of Research and Development.
Cincinnati, OH. EPA Contract No. 68-03-3038-SBR09.
October 1983.
2. Code of Federal Regulations, Title 40, Part 60, Subpart W,
as amended May 30, 1984. Standards of Performance for
Equipment Leaks of VOC in SOCMI. Washington, DC. U. S.
Government Printing Office. October 8, 1983.
3. Proposed Standards of Performance for SOCMI Reactor
Processes. .Federal Register, Vol. 55, No. 126, pp. 26953-70.
Washington, DC. Office of the Federal Register.
June 29, 1990.
4. Code of Federal Regulations, Title 40, Part 60, Subpart NNN.
Standards of Performance for SOCMI Distillation Operations.
Washington, DC. U. S. Government Printing Office.
June 29, 1990.
5. Code of Federal Regulations, Title 40, Part 60, Subpart III.
SOCMI Air Oxidation Processes. Washington, DC. U. S.
Government Printing Office. June 29, 1990.
A-24
-------
APPENDIX B
NON-SOCMI EQUIPMENT LEAKS
The negotiated regulation for equipment leaks specified
several non-SOCMI processes that are subject to the standard.
Specific chemicals used as reactants or process solvents are
regulated for the non-SOCMI processes. These processes and the
regulated chemicals (shown in parenthesis) are presented below.
Styrene-butadiene rubber production (butadiene and
styrene) - A process that produces styrene-butadiene
copolymers, whether in solid (elastomer) or emulsion
(latex) form.
Polybutadiene production (1,3-butadiene) - A process
that produces polybutadiene through the polymerization
of 1,3-butadiene.
Chlorine production (carbon tetrachloride) - A process
that, uses carbon tetrachloride as a diluent for
nitrogen trichloride or as a scrubbing liquid to
recover chlorine from the liquefaction of tail gas.
Pesticide production (carbon tetrachloride, methylene
chloride, and ethylene dichloride) - A process that
uses one or more of these chemicals as a reactant or a
processing aid in the synthesis of a pesticide
intermediate or product.
Chlorinated hydrocarbon use (carbon tetrachloride,
methylene chloride, tetrachloroethylene, chloroform,
and ethylene dichloride) - A process that uses one of
these chemicals to produce chlorinated paraffins,
Hypalon®, OBPA/l,3-diisocyanate, polycarbonate,
polysulfide rubber, and symmetrical
tetrachloropyridiene.
Pharmaceutical production (carbon tetrachloride and
methylene chloride) - A process that synthesizes
pharmaceutical intermediates or -final products using
carbon tetrachloride or methylene chloride as a
reactant or process solvent.
Miscellaneous butadiene uses (1,3-butadiene) - A
process that produces one or more of the following
butadiene products: tetrahydrophthalic anhydride
(THPA), methylmethacrylate-butadiene-styrene (MBS)
resins, Captan®, Captafol®, 1,4-hexadiene,
B-l
-------
adiponitrile, dodecanedionic acid, butadiene-furfural
cotrimer, methylmethacrylate-acrylonitrile-butadiene-
styrene (MABS) resins, and ethylidene norbornene.
The impacts from each of the above non-SOCMI processes were
estimated in a manner similar to that used for the SOCMI CPP's.
In contrast to the estimation method used for the SOCMI CPP's,
actual equipment count data for that equipment handling the
regulated chemical(s) in the non-SOCMI processes were available.
Only equipment containing the regulated chemical(s) was included
because in some of the non-SOCMI processes the regulated
chemical(s) were used only as a solvent or processing aid in a
well-defined- area of the process unit. Therefore, the affected
equipment count represents a small subset of the total equipment
count for the entire process unit.
The method of determining the impacts in the non-SOCMI
processes is briefly summarized below. This method parallels
that used for the SOCMI CPP's, which is described in detail in
HON BID Volume 1C.
Section 114 letters from process units using the non-SOCMI
processes were reviewed to obtain the geographical location and
equipment count for each process unit. Baseline control
requirements for each process unit were assigned based on
existing Federal or State regulations. Using the process unit-
specific equipment counts and the emission factors appropriate
for the existing baseline control level, baseline emissions were
calculated. Emission reductions were then calculated using the
MACT emission factors, and costs of implementing the negotiated
regulation were calculated using the same algorithms that were
used for the SOCMI CPP's. These algorithms are described in-
detail in HON BID Volume IB.
Based on a brief review State and Federal regulations,
chlorine, pesticide, and pharmaceutical processes were judged to
have no baseline control requirements, and all of the process
units in these processes were assigned uncontrolled equipment
leak emission factors. The remainder of the non-SOCMI processes
were all polymer production processes. In all pf the regulations
reviewed, polymer production processes had the same regulatory
requirements as SOCMI CPP's. Where appropriate (based on
geographic location), polymer production processes were assigned
equipment leak emission factors consistent with the level of
control presented in the Control Techniques Guidelines document
B-2
-------
CO
EH
D
W
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H
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•.^ ^T CD r*>» CO ' ^t-
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gggggggggg
CMCOO, 'S ^ ^
'"x -5. 1 £ 1 ~
f- i f "i j J
o .us's-i.li8
W W O fl) f— -r— _C
13 o~3'~ E -C ST3 0
O-M C-O'TJ'-O''"" s -c
-Q o a a) a) a)
o ^ ~D *5 ^ *"" *"" "^ "^ "^
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-------
to represent the baseline control requirements found in specific
State regulations.
The average impacts for each non-SOCMI process are presented
in Table B-l. The impacts for the SOCMI model units are included
in the table for comparison. In general, the average total
annual cost for each non-SOCMI process is less than the SOCMI
model unit's total annual cost. For chlorine production,
pesticide production and miscellaneous butadiene use, the total
annual costs are below the lowest value for the SOCMI model
units. Lower total annual costs for these non-SOCMI processes
occurs since they have low equipment counts (only equipment
handling the regulated chemical(s) is counted). For the
remainder of the non-SOCMI processes, the range of average costs
are comparable to the SOCMI model unit costs. None of the
average to.tal annual cost for non-SOCMI processes exceed the
highest; SOCMI model unit total annual cost. The average net
annual cost and cost effectiveness of the non-SOCMI processes are
also comparable to the net annual cost and cost effectiveness for
the SOCMI model units.
B-3
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TECHNICAL REPORT DATA
(Please react Instructions on the reverse before completing)
EPA-453/D-92-016a
3. RECIPIENT'S ACCESSION NO.
t. TITLE AND SUBTITLE Hazardous Air Pollutant-Emissions from
Process Units in the Synthetic Organic Chemical
Manufacturing Industry—Background Information for
Proposed Standards
Volume 1A; National Impacts Assessment
5. REPORT DATE
November 1992
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
ION NAME AND ADDRESS
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
10. PROGRAM ELEMENT NO.
1. CONTRACT/GRANT NO.
68D10117
12. SPONSORING AGENCY NAME AND ADDRESS
Director, Office of Air Quality Planning and Standards
Office of Air and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
EPA/200/04
IY NOTES
A draft rule for the regulation of emissions of organic hazardous air pollutants
(HAP s) from chemical processes of the synthetic organic chemical manufacturing
industry (SOCMI) is being proposed under the authority of Sections 112, 114, 116,
and 301 of the Clean Air Act, as amended in 1990. This volume of the Background'
Information Document presents the results of the national impacts assessment for
the proposed rule.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Air pollution
Pollution control
SOCMI
Hazardous air pollutant
National impacts
Air pollution control
STATEMENT
19. SECURITY CLASS (This Report!
21. NO. OF PAGES
160
20. SECURITY CLASS fTin's page)
UNCLASSIFIED
22. PRICE
EPA Form 2220—1 (Rev. 4—77) PREVIOUS EDITION is OBSOLETE
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