EPA-450/3-85-021
Survey of Trichloroethylene
       Emission Sources
      Emission Standards and Engineering Division
        U.S. Fnvift'-.-rri*}: ::•• """<
        R'j,'10.ri V. -,,iv'" i: /
      U.S. ENVIRONMENTAL PROTECTION AGENCY
            Office of Air and Radiation
      Office of Air Quality Planning and Standards
          Research Triangle Park, NC 27711

                 July 1985

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This report has been reviewed by the Emission Standards and Engineering Division of the Office of Air
Quality Planning and Standards, EPA, and approved for publication. Mention of trade names or commercial
products is not intended to constitute endorsement or recommendation for use. Copies of this report are
available through the Library Services Office (MD-35), U.S. Environmental Protection Agency, Research
Triangle Park, IM. C. 27711, or from National Technical  Information Services,  5285 Port Royal Road,
Springfield, Virginia 22161.

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                              TABLE OF CONTENTS


Chapter                                                               Page

  1.0     INTRODUCTION AND SUMMARY	     1-1

          1.1  INTRODUCTION	     1-1

          1.2  SUMMARY	     1-2
               1.2.1  TCE Emission Source Categories 	     1-2
               1.2.2  Emission Estimates 	     1-2
               1.2.3  Additional  Control of TCE Emissions	     1-5
               1.2.4  Regulatory  Requirements	     1-6

          1.3  REFERENCES	     1-10

  2.0     TRICHLOROETHYLENE PRODUCTION / 	     2-1

          2.1  QUANTITIES PRODUCED AND MANUFACTURERS 	     2-1

          2.2  PROCESS DESCRIPTIONS,  EMISSIONS, AND CURRENT
                 CONTROLS	..	     2-1
               2.2.1  Chlorination of Ethylene Dichloride (EDC).  .     2-3
                      2.2.1.1  Process Description 	     2-3
                      2.2.1.2 Current Emissions and Controls.  .  .      2-3
               2.2.2  Oxychlorination of Ethylene Dichloride
                        (EDC)	     2-8
                      2.2.2.1  Process Description 	     2-8
                      2.2.2.2  Current Emissions and Controls.  .  .     2-8

          2.3  COST OF ADDITIONAL CONTROLS	     2-13
               2.3.1  Control of  Process Vent Emissions	     2-13
               2.3.2  Control of  Equipment  Leak Emissions	     2-13
               2.3.3  Control of  Storage Emissions 	     2-16
               2.3.4  Control of  Loading Emissions 	     2-16

          2.4  REFERENCES	     2-17

  3.0     OTHER CHEMICAL PRODUCTION	     3-1

          3.1  PROCESS DESCRIPTIONS,  EMISSIONS, AND CURRENT
                 CONTROLS	     3-1
               3.1.1  Ethylene Dichloride (EDC)/Vinyl  Chloride
                        Monomer (VCM) Manufacture	     3-1
                      3.1.1.1  Process Description 	     3-2
                      3.1.1.2  Current Emissions and Controls.  .  .     3-2
               3.1.2  Polyvinyl Chloride (PVC) Manufacture  ....     3-8
                      3.1.2.1  Process Description 	     3-8
                      3.1.2.2  Current Emissions and Controls.  .  .     3-8

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                        TABLE OF CONTENTS (Continued)


Chapter                                                               Page

               3.1.3  Vinylidene Chloride Manufacture	     3-9
                      3.1.3.1  Process Description 	     3-9
                      3.1.3.2  Current Emissions  and Controls.  .  .     3-10
               3.1.4  Storage of TCE for Resale	     3-10
                      3.1.4.1  Current Emissions  and Controls.  .  .     3-11

          3.2  COST OF ADDITIONAL CONTROLS	     3-12
               3.2.1  Control of Equipment Leaks  	     3-12
               3.2.2  Control of Storage Emissions 	     3-15

          3.3  REFERENCES	     3-16

  4.0     SOLVENT DECREASING OPERATIONS	     4-1

          4.1  INDUSTRY DESCRIPTION	     4-1

          4.2  DECREASING EQUIPMENT	     4-2

          4.3  EMISSIONS FROM DECREASING OPERATIONS	     4-3

          4.4  EMISSIONS CONTROL 	     4-5

          4.5  COST OF EMISSIONS CONTROL	     4-8

          4.6  REGULATORY REQUIREMENTS 	     4-14

          4.7  REFERENCES	     4-15

  5.0     DISTRIBUTION FACILITIES	     5-1

          5.1  EMISSIONS FROM DISTRIBUTION FACILITIES	     5-1

          5.2  REGULATORY REQUIREMENTS 	     5-3

          5.3  REFERENCES	     5-4

  6.0     MISCELLANEOUS SOURCES	     6-1

          6.1  REFERENCES	     6-3

  7.0     PUBLICLY OWNED TREATMENT WORKS (POTWS)  	     7-1

          7.1  EMISSION ESTIMATES	     7-1

          7.2  REFERENCES	     7-2
                                    IV

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                        TABLE OF CONTENTS (Continued)
Chapter                                                               Page

APPENDIX A:  MATERIAL BALANCE FOR TCE EMISSIONS FROM DECREASING
               OPERATIONS	      A-l

             A.I  MATERIAL BALANCE	      A-l

             A.2  NATIONAL EMISSION REDUCTION CALCULATIONS.  ...      A-2

             A.3  REFERENCES	      A-6

APPENDIX B:  METHODS USED FOR ESTIMATING STORAGE TANK AND
               EQUIPMENT LEAK EMISSIONS 	      B-l

             B.I  EMISSION FACTORS FOR FIXED-ROOF STORAGE
                    TANKS	• .  .  .      B-l
                  B.I.I  Emission Equations 	      B-l
                  B.I.2  Parameter Values and Assumptions ....      B-l
                  B.I.3  Sample Calculation 	      B-2

             B.2  EMISSION FACTORS FOR INTERNAL FLOATING ROOF
                    STORAGE TANKS 	      B-4
                  B.2.1  Emission Equations 	      B-4
                  B.2.2  Parameter Values and Assumptions ....      B-4
                  B.2.3  Sample Calculation 	      B-6

             B.3  EQUIPMENT LEAK EMISSIONS - SAMPLE
                    CALCULATIONS	      B-10

             B.4  REFERENCES	      B-12

APPENDIX C:  METHODS FOR ESTIMATING EMISSION CONTROL COSTS.  ...      C-l

             C.I  PROCESS VENT EMISSIONS CONTROL COST
                    ESTIMATION	      C-l

             C.2  COST CALCULATIONS FOR INSTALLING INTERNAL
                    FLOATING ROOFS IN FIXED ROOF TANKS	      C-7
                  C.2.1  Capital Cost	      C-7
                  C.2.2  Annual Cost	      C-15
                  C.2.3  C?HC1?/VOC Reduction	      C-15
                  C.2.4  Recovery Credits	      C-16
                  C.2.5  Net Annual Cost	      C-16
                  C.2.6  Cost Effectiveness	      C-16

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                        TABLE OF CONTENTS (Continued)
Chapter                                                               Page

             C.3  COST CALCULATIONS FOR INSTALLATION OF REFRIGERATED
                    CONDENSERS TO CONTROL LOADING EMISSIONS .  .  .      C-17

             C.4  SAMPLE CALCULATIONS FOR EQUIPMENT LEAK CONTROL
                    COSTS	      C-20

             C.5  REFERENCES	      C-23

APPENDIX D:  SUMMARY OF EXISTING STATE AND FEDERAL REGULATIONS
               AFFECTING TRICHLOROETHYLENE EMISSION SOURCES ...      D-l

             D.I  EXISTING STATE REGULATIONS	      D-l
                  D.I.I  Introduction	      D-l
                  D.I.2  General State VOC Regulations for Solvent
                           Use	      D-l
                  D.I.3  Prevention of Significant Deterioration
                           Regulations	      D-l
                  D.I.4  State Regulations Affecting Chemical
                           Production	      D-3

             0.2  EXISTING FEDERAL REGULATIONS	      D-3

APPENDIX E:  TRICHLOROETHYLENE EMISSIONS FROM DISTRIBUTION
               FACILITIES	      E-l

             E.I  TRICHLOROETHYLENE EMISSIONS FROM DISTRIBUTION
                    FACILITIES	      E-l

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                               LIST OF TABLES
Table                                                                 Page

 1-1      EMISSIONS IN 1983 FROM THE PRODUCTION AND USE OF
            TRICHLOROETHYLENE 	     1-3

 1-2      ACHIEVABLE TCE EMISSION REDUCTIONS FROM CHEMICAL
            PRODUCTION FACILITIES AND DEGREASERS AS A FUNCTION OF
            COST EFFECTIVENESS	     1-7

 2-1      TRICHLOROETHYLENE PRODUCTION PLANTS 	     2-2

 2-2      TOTAL EMISSIONS FROM TRICHLOROETHYLENE PRODUCTION
            FACILITIES	     2-5

 2-3      ESTIMATED EMISSIONS AND CURRENT CONTROLS AT THE
            FACILITY PRODUCING TRICHLOROETHYLENE BY THE
            CHLORINATION OF EDC	     2-6

 2-4      ESTIMATED EMISSIONS AND CURRENT CONTROLS AT THE
            FACILITY PRODUCING TRICHLOROETHYLENE BY THE
            OXYCHLORINATION OF EDC	     2-10

 2-5      COST OF ADDITIONAL CONTROLS AT TCE PRODUCTION
            FACILITIES (1984 DOLLARS) 	     2-14

 2-6      ESTIMATED TCE EMISSION REDUCTIONS AT TCE PRODUCTION
            FACILITIES	     2-15

 3-1      TOTAL EMISSIONS FROM OTHER CHEMICAL PRODUCTION
            FACILITIES	     3-3

 3-2      ESTIMATED EMISSIONS AND CURRENT CONTROLS AT FACILITIES
            USING TRICHLOROETHYLENE 	     3-4

 3-3      ESTIMATED COST OF ADDITIONAL CONTROL DEVICES AT
            OTHER CHEMICAL PRODUCTION FACILITIES 	    3-13

 3-4      ESTIMATED TCE EMISSION REDUCTIONS FOR OTHER CHEMICAL
            PRODUCTION FACILITIES AS A FUNCTION OF COST
            EFFECTIVENESS 	     3-14

 4-1      1983 TCE EMISSIONS FROM DECREASING OPERATIONS, BY
            INDUSTRY	     4-4

 4-2      1983 TRICHLOROETHYLENE EMISSIONS FROM DECREASING
            OPERATIONS, BY STATE	     4-6

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                         LIST OF TABLES (Continued)


Table                                                                 Page

 4-3      EXAMPLE CONTROL TECHNIQUES FOR DEGREASERS 	      4-7

 4-4      RETROFIT CONTROL COSTS FOR COLD CLEANERS	      4-9

 4-5      RETROFIT CONTROL COSTS FOR MEDIUM SIZE OPEN TOP VAPOR
            DEGREASER	      4-10

 4-6      RETROFIT CONTROL COSTS FOR CONVEYORIZED DEGREASERS.  . .      4-12

 5-1      SUMMARY OF MAJOR TRICHLOROETHYLENE DISTRIBUTORS ....      5-2

 6-1      1983 TRICHLOROETHYLENE CONSUMPTION AND EMISSIONS FROM
            OTHER CHEMICAL PRODUCTION SOURCE CATEGORIES 	      6-2

 B-l      PAINT FACTORS FOR FIXED ROOF TANKS	      B-3

 B-2      TYPICAL NUMBER OF COLUMNS AS A FUNCTION OF TANK
            DIAMETERS	      B-7

 B-3      SUMMARY OF DECK FITTING LOSS FACTORS (!O AND TYPICAL
            NUMBER OF FITTINGS (Nf)	r	      B-8

 C-l      TOTAL INSTALLED CAPITAL COST AS A FUNCTION OF VENT STREAM
            FLOW RATE	      C-2

 C-2      ADDITIONAL DUCT COST	      C-3

 C-3      PIPE RACK COST	      C-4

 C-4      OPERATING FACTORS FOR EACH DESIGN CATEGORY	      C-5

 C-5      ANNUALIZED COST FACTORS	      C-6

 C-6      SAMPLE CALCULATION FOR INCINERATOR COSTING	      C-7

 C-7      COST CONVERSION FACTORS	      C-13

 C-8      CONTROL TECHNIQUES AND COST FOR CONTROLLING EQUIPMENT
            LEAK EMISSION SOURCES 	      C-20

 D-l      GENERAL STATE VOC REGULATIONS FOR PHOTOCHEMICAL
            SOLVENTS	      D-2
                                  vm

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                         LIST OF TABLES (Continued)

Table                                                                 Page

 D-2      STATE REGULATIONS AFFECTING CHEMICAL PRODUCTION
            FACILITIES	      D-4

 D-3      SUMMARY OF FEDERAL REGULATIONS AFFECTING TRICHLOROETHYLENE
            EMITTING SOURCES	      D-7
                                   IX

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                               LIST OF FIGURES
Figure                                                                Page

 2-1      Process Flow Diagram for the Production of
            Trichloroethylene by Direct Chlorination 	    2-4

 2-2      Process Flow Diagram for the Production of
            Trichloroethylene by Oxychlorination 	    2-9

 C-l      Cascade Refrigeration System for Vapor Recovery	    c-18

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                        1.0  INTRODUCTION AND SUMMARY

1.1  INTRODUCTION

     This document identifies the sources and locations  of trichloroethylene
(TCE) emissions, estimates total  production and consumption volumes,
estimates emission levels, identifies applicable control  techniques  for each
source, and estimates the cost effectiveness of controlling emissions  for
several source types.  The information collected in this  source assessment
study will also be used by the U.S.  Environmental  Protection Agency  (EPA) to
estimate human exposure to TCE.
     Information for this document was acquired from various sources.
Background information, such as previous  EPA documents  and other published
literature, was reviewed in an attempt to identify the  producers of  TCE and
the major applications.  Two companies producing TCE at  two facilities were
identified.  Four companies using TCE or  emitting  TCE as  a byproduct were
also identified.  Further, ethylene  dichloride (EDC) production was  identi-
fied as a source of byproduct TCE formation.  A total of  twelve companies
producing EDC were identified, one of which also produces TCE.
     Under authority of Section 114  of the Clean Air Act, letters were sent
to the two companies producing TCE,  the four companies  using or emitting TCE
as a byproduct in various chemical production processes,  and to nine of the
twelve EDC producers.  Information was requested concerning TCE emissions,
emission levels, and control techniques for all  possible  emission sources
associated with the production, storage,  and use of TCE  in the  calendar year
1983.  General information such as production volumes and total sales/purchase
data were also requested in order to verify the completeness of the  submitted
information.  The production and  sales/purchase information was requested to
be treated as confidential and is not discussed in this  report.  For each
process unit making or consuming  TCE, detailed information was  requested on
the following emission types:  process vent emissions, equipment leaks,
equipment opening losses, raw material/product storage emissions, loading/
                                    1-1

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handling emissions, and secondary emissions.   The companies were asked only
to estimate these emissions.   No testing was  required specifically for this
information request.
     Information was obtained from the Halogenated Solvents Industry Alliance
(HSIA), a trade group representing the producers of TCE and other halogenated
solvents, regarding the total amounts of TCE  used in 1983 for various
applications.   Using this and other available information, emission levels
in 1983 were estimated for each application.   The major use of TCE was
identified to be solvent degreasing.

1.2  SUMMARY

1.2.1  TCE Emission Source Categories

     Trichloroethylene is produced by two chemical companies at two plants
in the United States.  The estimated total  1983 production volume of TCE was
65,700 Mg.   Two processes are used to produce TCE:  (1) chlorination of
                                                                    2
ethylene dichloride, and (2)  oxychlorination  of ethylene dichloride.   In
1983, 85 percent of the TCE produced was used as a solvent in degreasing
operations, and 15 percent was used in a variety of other applications.
These other applications include use as a solvent in adhesives manufacture,
paints and coatings manufacture, and as a reaction chain transfer agent  in
the production of polyvinyl chloride (PVC).
     Emission estimates have been made in this study for the following
categories:  TCE production, other chemical production (TCE as a by-product,
and use as a reaction chain transfer agent),  degreasing operations, distri-
bution facilities, publicly-owned treatment works (POTW), and miscellaneous
applications.

1.2.2  Emission Estimates
     The total emissions from TCE production  and use in 1983 were
57,600 Mg/yr.  The largest sources of emissions were degreasing operations
(52,600 Mg/yr) and POTW operations  (1,450 Mg/yr).  All identified emission
sources and  corresponding esimated emissions  are shown in Table 1-1.
                                     L-2

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        TABLE 1-1.  EMISSIONS IN 1983 FROM THE PRODUCTION AND USE OF
                              TRICHLOROETHYLENE

Emission Source
TCE Production
Other Chemical Production
Degreasing Operations
Distribution Facilities
POTW Operations
Adhesive Formulations
Paints and Coatings
PVC Production
Miscel laneous
TOTAL
Production/
Consumption
(Mg/Yr)
65,700
N/A
56,000
65,700b
-
420
520
6,500C
2,340
197,200
Emissions
(Mg/Yr)
100
28a
52,600
39
1,400
420
520
130C
2.340
57,600
N/A - Not available.

alncludes estimated 21 Mg TCE emissions as a by-product from other EDC/VCM
 facilities (see Section 3.1.1).
 Estimated amount sold through distributors.

cBased on a 1978 EPA/OPTS study.
                                    1-3

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     Trichloroethylene emissions from TCE production processes are estimated
to be 100 Mg/yr.  TCE emissions from other chemical production facilities
are estimated to be 28 Mg/yr.  About 7 Mg/yr of the 28 Mg/yr were emitted
from two EDC plants where TCE was reported to be formed as a by-product, two
chlorinated solvent plants where TCE is not produced but is stored to
maintain a full line of solvents, one polyvinyl chloride (PVC) plant where
TCE is used as a reaction chain transfer agent, and one vinylidene chloride
plant where TCE is formed as a by-product.  About 21 Mg/yr of the 28 Mg/yr
were estimated to be emitted from other EDC plants where TCE is suspected to
be emitted as a by-product.  No data were obtained directly from these other
EDC plants.  Emissions were estimated to be proportional to the emissions
from the two EDC facilities reporting TCE emissions.
     The chemical plant emission estimates were obtained from company
responses to Section 114 requests.  Included in these chemical plant
emission estimates are emission estimates from process vents (estimated at
full capacity), loading/handling operations, equipment opening losses,
pressure relief valve discharges, equipment leaks, storage tanks, and
secondary streams.  Volatile organic compound (VOC) emissions from equipment
leaks were calculated by applying the Synthetic Organic Chemical
Manufacturing Industry (SOCMI) VOC equipment leak emission factors to the
                                         3
equipment count provided by each company.   TCE emissions were estimated by
applying the volume percent of TCE passing through each piece of equipment
in TCE service to the calculated VOC emissions.  Emissions from storage
tanks were estimated by using AP-42 equations and storage tank data supplied
                A
by each company.    Detailed methods for estimating these emissions are
described in Appendix B.
     Trichloroethylene emissions from degreasing operations were estimated
to be 52,600 Mg in 1983.  Degreasing operations represented the largest
source category of TCE emissions in 1983, accounting for about 91 percent of
total TCE emissions.  Degreasing emission estimates were made using HSIA
information on  1983 TCE consumption in various applications and available
emission factors.  The HSIA indicated that TCE was used as a degreasing
solvent in five major industry groups in 1983.  These are:  furniture and
                                    1-4

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fixtures (Standard Industrial Classification (SIC) 25), fabricated metal
products (SIC 34), electric and electronic equipment (SIC 36), transportation
equipment (SIC 37), and miscellaneous industries (SIC 39).  Emission factors
for degreasing operations were obtained from previous EPA studies.  The
methodology for calculating the overall emission factor for degreasing is
presented in Appendix A.
     Almost all of the TCE produced is sold through various chemical distri-
butors.  The handling and storage operations at distribution facilities
located throughout the country were estimated to account for 39 Mg of TCE
emissions in 1983.
     Recent EPA studies have estimated that about 1,450 Mg of TCE emissions
occur annually at POTW operations.  These emissions are believed to occur
through volatilization from industrial discharges of waste streams containing
TCE.
     Additional applications of TCE include primarily use in adhesives
manufacture, paints and coatings manufacture, and as a reaction chain
transfer agent in the production of PVC.   These applications were estimated
to account for about 3,400 Mg of TCE emissions in 1983.  Adhesives, paints,
and coatings have largely consumer applications.  Thus, it is estimated that
all TCE used in these applications is emitted to the atmosphere.  For use of
TCE in PVC production, it is estimated that about two percent of consumption
is emitted to the atmosphere.  The identities of all PVC manufacturers
emitting TCE is presently not known.

1.2.3  Additional Control of TCE Emissions
     The cost associated with additional  control of TCE emissions was
estimated for TCE production facilities,  other chemical production facilities,
and degreasers.  Due to the large number  of degreasers, no attempt was made
to develop cost estimates for each degreaser actually in use.  Instead, cost
estimates were developed for model degreasers.   National costs and national
emission reductions associated with controlling degreasers were based on the
model degreaser data.  Specific information was provided for TCE production
and other chemical production facilities.  This information was used to
develop national cost and emission reduction estimates to be for these
production facilities.

                                     1-5

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     Emissions of TCE from chemical  plants producing or using TCE can be
reduced by various technically feasible controls.  Process vent emissions
can be controlled by incineration.   Equipment leak emissions can be reduced
through a combination of leak detection and repair programs and application
of equipment control devices.  Storage tank emissions can be reduced by
installation of floating roofs in fixed roof tanks.  Where floating roofs
are not technically feasible (i.e.  horizontal tanks or extremely small
diameter tanks), a refrigerated condenser can be used for control of storage
emissions.  Loading emissions can be controlled by venting displaced vapors
to a refrigerated condenser.  The methodology for estimating cost effective-
ness of control is presented in Appendix C.
     Emissions of TCE from degreasers can be reduced by using covers for
degreaser openings, increasing degreaser freeboard area, adding freeboard
chillers, providing drainage racks  for parts, and installing carbon
adsorbers.  The methodology for estimating cost effectiveness of control is
presented in Chapter 4.
     Costs were estimated for the above control techniques for all emission
sources which are not presently well controlled.  These costs estimates are
based on the information provided in the company Section 114 responses  on
the emission stream and process equipment parameters and also on the data
for model degreasers.  It is estimated that about 26,200 Mg/yr TCE emissions
can be controlled by the application of control techniques on process vent,
equipment leak storage tanks, and handling emissions at TCE production  and
other chemical plants and by application of control techniques on
uncontrolled degreasers.  This represents an overall emission reduction of
about 50 percent over current estimated emissions.  Table 1-2 shows the
emission reduction for each emission type for various ranges of cost
effectiveness.

1.2.4  Regulatory Requirements
     The 8 plants that produce TCE,  manufacture TCE as a byproduct, or  store
TCE are  located in four States:  Texas, Louisiana, Kansas, and Illinois.
The VOC  emissions from these existing chemical production facilities are not
                                    1-6

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             TABLE 1-2.   ACHIEVABLE TCE EMISSION REDUCTIONS FROM
             CHEMICAL PRODUCTION FACILITIES AND DEGREASERS AS A
                         FUNCTION OF COST EFFECTIVENESS
                                Emission Reduction,  Mg/Yr
Cost Effectiveness   Process  Equipment  Storage
 Range ($/Mg VOC)     Vents     Leak      Tanks   Loading  Degreasing  Total
     Credit

    0 -   500

  500 - 1,000

1,000 - 2,000

2,000 - 5,000

    >5,000
             TOTAL
0.3

0.3
         32.5
          0.4
32.9
 1.0

 0.1

 0.4

16.6

18.1
13.8

13.8
                              11,270  11,270

                                        33.5

                              14,900  14,900

                                         0.8

                                        30.7
26,170  26,230
                                    1-7

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controlled by Federal  regulations such as the new source performance
standards (NSPS) for volatile organic compounds in the synthetic organic
chemical manufacturing industry.   However, the EDC/VCM plants producing TCE
as a byproduct and the PVC plant  using TCE as a reaction chain transfer
agent may be controlled by the national  emission standards for hazardous air
pollutants (NESHAP) for vinyl chloride (VC).   Also, the emissions at most
plants are controlled to some extent in  each  of these States  by county,
district, or State regulations.
     Trichloroethylene emissions  from process vents are restricted by State
or district VOC regulations in Texas, Louisiana, and Illinois.  Texas
regulations require emissions to  be properly  incinerated at 1300°F.   Process
vent streams emitting less than  45 kg/day and 110 kg/hr in any 24 hour
period are exempt from this regulation.   Louisiana requires incineration at
1300°F with a 0.3 second residence time.   However, the control requirements
can be waived of the VOC emissions are less than 91 Mg/yr or  will not
support combustion, or if control will cause  economic hardship.  Illinois
regulations limit VOC emissions  to 100 ppm equivalent methane.
     Equipment leak emissions are not presently regulated in  any of the four
States.  However, both Texas and  Louisiana have recently enacted regulations
for equipment leaks with a final  compliance date of December  31, 1987.  In
Texas the requirements will include annual testing of all valves in liquid
service, capping of open-ended lines and valves, monitoring of pump seals,
and detailed recordkeeping of these practices.  In Louisiana  the requirements
will include annual monitoring of pump seals, pipeline valves in liquid
service, and process drains, and  quarterly monitoring of compressor seals,
pipeline valves in gas service,  and relief devices.
     Texas, Louisiana, and Illinois have regulations for VOC  emissions from
storage tanks.  In general, tanks greater than 40,000 gallons storing
liquids with a vapor pressure greater than 1.5 psia and less  than 11.0 psia
are required to be controlled by  an internal  floating roof with a primary
seal, an internal floating roof with both primary and secondary seals,
refrigerated condensers, or incineration.  Kansas regulates only emissions
from storage tanks containing petroleum.
                                    1-8

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     VOC emissions from loading/handling operations are regulated by Texas,
Louisiana, and Illinois.  Texas and Louisiana require vapor collection and
recovery or disposal for facilities loading greater than 20,000 gal/day
(40,000 gal/day for existing facilities in Louisiana).  Illinois requires
submerged fill.
     There are no Federal  regulations for TCE emissions from degreasing
operations.  A CTG for organic solvent cleaners has been issued by EPA
establishing RACT guidelines that have been used by State agencies to
develop SIPs.  Thirty two  states and the District of Columbia have adopted
RACT for use of TCE in degreasing operations.  Eighteen states have not
adopted any regulations.  Further details on state regulations are contained
in Appendix D.
                                     1-9

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1.3  REFERENCES

1.   Letter from D. L. Morgan, Cleary, Gottlieb, Steen, and Hamilton, to
     R. E. Rosensteel, EPA/ESED.   February 22, 1985.   Response for
     Halogenated Solvents Industrial  Alliance concerning industrial
     consumption volumes of trichloroethylene in 1983.

2.   Mannsville Chemical Products.  Chemical  Products Synopsis -
     Trichloroethylene.  Cortland, New York.   November 1984.

3.   U.S. Environmental Protection Agency.  Fugitive  Emission Sources of
     Organic Compounds - Additional Information on Emissions, Emission
     Reductions and Costs.   Research  Triangle Park, North Carolina.
     Publication No. EPA-450/3-82-010.

4.   Compilation of Air Pollutant Emission Factors, 3rd Edition.
     U. S. Environmental Protection Agency, Office of Air Quality Planning
     and Standards, Monitoring and Data Analysis Division.  Research
     Triangle Park, N.C.  January 1984.
                                    1-10

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                      2.0 TRICHLOROETHYLENE PRODUCTION

     This chapter presents the emissions and controls associated with the
production of trichloroethylene (TCE) at the two production facilities in
the United States.  Emissions from TCE production facilities come from
process vents, storage tanks, equipment openings, equipment leaks, handling
operations, relief device discharges, and secondary (disposal)  sources.
     TCE is currently produced by two processes.  These are the direct
chlorination of ethylene dichloride (EDC) and a single-step oxychlorination
of EDC.

2.1  QUANTITIES PRODUCED AND MANUFACTURERS

     TCE is currently produced by two companies at two facilities.  The
estimated total production capacity of these plants in 1983 was approxi-
mately 154,600 Mg/yr.1  In 1983 about 65,700 Mg of TCE were produced.2  The
total imports of TCE in 1983 were 14,900 Mg, and total exports  were 14,500 Mg
indicating a total domestic demand of about 66,000 Mg.  The producers, their
capacities, and production processes are listed in Table 2-1.
     Vulcan Chemicals is proceeding with engineering studies for a new TCE
facility despite a poor market outlook.   Demand for TCE is expected to
decrease in 1985, possibly due to the presence of improved solvent recovery
systems and the impact of regulatory constraints.

2.2  PROCESS DESCRIPTIONS, EMISSIONS, AND CURRENT CONTROLS

     This section presents the emission estimates and current  controls for
the two producers of TCE.  Dow Chemical in Freeport, TX, produces TCE by the
direct chlorination process.  PPG Industries in Lake Charles,  LA, uses the
oxychlorination process.
                                     2-1

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2.2.1  Chlorination of Ethylene Dichloride (EDC)
     The chlorination of EDC accounts for approximately 35 percent of the
current TCE production capacity.   At present, only one plant, Dow Chemical
in Freeport, TX, uses this process.  Perchloroethylene is the major
coproduct of this reaction.

     2.2.1.1  Process Description.   Trichloroethylene and perchloroethylene
(PCE) are co-produced from the chlorination of ethylene dichloride (EDC).
Changes in the EDC/chlorine ratio determine which compound will  be formed in
the greatest quantity.  The chlorination occurs according to the non-catalytic
reaction:

     C1CH2CH2C1  +      C12     400-45Q°C ^HCI,   +   HC1    +    [C2H3C1]
       (EDC)        (chlorine)              (TCE)    (hydrogen      (PCE)
                                                     chloride)

     The reaction is usually carried out at about 400° to 450°C  (750° to
850°F) and at a  pressure slightly above one atmosphere.  A generalized
process flow diagram is shown in Figure 2-1.

     2.2.1.2  Current Emissions and Controls.    The major sources  of
emissions from this process at the Dow/Freeport facility are from  storage
tanks, equipment leaks, and handling operations.   Emissions from process
vents, equipment openings, and secondary sources  were also reported.   The
emission types and quantity of emissions are  shown in Table 2-2.  The
emission types and their controls are discussed below and are listed in
Table 2-3.
     The production of TCE resulted in total  TCE  emissions of 46.7 Mg at
this facility in 1983.  Equipment leaks accounted for a majority of these
emissions, totalling 24.1 Mg (52 percent).   The largest sources  of equipment
leaks were valves (11.8 Mg, 49 percent of equipment leak emissions)  and  pump
seals (6.6 Mg, 27 percent of equipment leak emissions).  Dow indicated that
"containment and immediate pickup" procedures  are practiced to control
fugitive emissions.
                                    2-3

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     The Texas Air Control Board has recently promulgated regulations that
will require a formal equipment leak monitoring program.  The first round of
monitoring must be completed by the end of 1987.  The regulation will
require the annual testing of all  valves in VOC service with a portable
hydrocarbon analyzer, capping of open-ended lines and valves, monitoring of
pump seals, and detailed recordkeeping of these practices.
     Approximately 12.2 Mg of TCE (26 percent of total  plant TCE emissions)
were emitted from seven storage tanks at this facility  in 1983.   Storage
tanks in Freeport (Brazoria County) having capacities greater than
25,000 gallons and storing liquids with a true vapor pressure greater than
1.5 psia are required to have vapor recovery systems or fully equipped
internal or external  floating roofs.  The true vapor pressure of TCE is
1.5 psia at 80°F.  Dow claimed that further information regarding its
storage tanks is confidential.
     Two process vents emitted approximately 0.2 Mg of  TCE  in 1983 (less
than one percent of total plant emissions).  One of the vents is located on
a distillation column.  This vent is uncontrolled and accounted  for
70 percent of the process vent emissions from the plant. Dow claimed that
further information regarding the process vents is confidential.  Brazoria
County regulations require that TCE emissions from vent streams  must be
burned properly at a  temperature equal  to or greater than 1300°F (704°C) in
a smokeless flare or  direct flame incinerator.  Process vents are exempt
from this regulation  if they emit less  than 45 kg per day and less than
110 kg per hour averaged over any 24-hour period.
     TCE losses due to handling operations in 1983 were approximately 10 Mg,
or 21 percent of the  total emissions from the plant. Dow reported that
products are loaded into tank trucks, rail cars, drums, barges,  and ships.
The trucks are reported to be bottom loaded with open domes.  The rail  cars
are bottom or top dip-tube loaded with  open vents.  Barges  and ships are
loaded through top domes with open vents.  Texas law states that facilities
with an average daily throughput of 20,000 gallons (30-day  average) must
have controls on their loading and unloading operations. Dow did not report
any controls on their handling operations.
                                     2-7

-------
     Dow estimated that 0.01 Mg of TCE were emitted from secondary sources.
Three sources, two waste streams from a landfill  and one waste stream from a
steam stripper, are reported as emitting TCE.   No controls were reported for
these streams.  In addition, Dow reported that 0.2 Mg/yr of TCE was emitted
due to 83 equipment openings.  There are no laws  specifically regulating
secondary or equipment opening emissions in Brazoria County, TX.

2.2.2  Oxychlorination of Ethylene Dichloride  (EDC)
     The oxychlorination of EDC accounts for approximately 65 percent of the
current TCE production capacity.   At present, only one plant, PPG
Industries in Lake Charles, LA, uses this process.

     2.2.2.1  Process Description.   PPG Industries developed this process
and is currently the only company that uses the process to produce TCE.
     This process, like the chlorination process, produces both TCE and
perchloroethylene (PCE).  The product mix can  be  varied by adjusting the EDC
to chlorine ratio.  The reaction for TCE is shown below:
                                 /t-3n°r                       r     i
CH2C1CH2C1 + C12/or HC1 + 02     4JU L   ^ C2HC13 + H2°  +   [C2C14J
  (EDC)                                    (TCE)              (PCE)

     The build-up of a great amount of hydrogen chloride is avoided by
concomitantly-operating HC1 oxidation.  The reaction involves simultaneous
oxychlorination/dehydrochlorination with chlorine or anhydrous  hydrogen
chloride as the chlorine source.  A typical process flow diagram is shown in
Figure 2-2.

     2.2.2.2  Current Emissions and Controls.   The major sources of
emissions at this facility were equipment leaks and secondary sources.  TCE
emissions from process vents, storage tanks, equipment openings, handling
operations, and relief device discharges were also reported.  The emission
types and quantities of emissions are shown in Table 2-2.  The emission
types and their controls are discussed below and are listed in Table 2-4.
                                     2-8

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     The production of TCE at the PPG facility resulted in total  emissions
of 53.0 Mg of TCE in 1983.  Equipment leaks accounted for a majority of
these emissions totalling 32.1 Mg/yr (60 percent of total plant emissions).
The largest sources of equipment leaks were valves (16.4 Mg, 51 percent) and
flanges (9.9 Mg, 31 percent).  Eight pressure relief devices were controlled
by rupture disks.  PPG reported that there were no formal inspection programs
used in 1983.  Leaks were located by visual observations and repaired
"promptly" for economic reasons (loss of product, corrosion of equipment).
However, beginning in 1987 Louisiana regulations will require a VOC leak
patrol/repair program.  This includes annual monitoring of pump seals,
pipeline valves in liquid service, and process drains, and quarterly
monitoring of compressor seals, pipeline valves in gas service, and pressure
relief valves.
     TCE emissions from storage tanks at this facility in 1983 were 3.5 Mg
(7 percent of total plant emissions).  All ten storage tanks are  equipped
with fixed roofs.  The tanks range in volume from 13,500 to 430,000 gallon
and average 155,000 gallons.  Storage tanks of these sizes containing TCE
are required by Louisiana law to have a vapor recovery system.  All ten
tanks are controlled with condensers with reported efficiencies ranging from
75 to 77 percent.
     Three process vents emitted approximately 2.1 Mg of TCE in 1983
(4 percent of total plant emissions).  All three vents are controlled by
water scrubbers with an unspecified control efficiency.  One vent accounted
for 72 percent of the process emissions.  Louisiana requires process vent
emissions greater than 91 Mg/yr to be controlled by incineration  at 1,300°F
with a 0.3 second residence time.
     Losses occuring during handling operations in 1983 were approximately
5.4 Mg, or 10 percent of the total plant's TCE emission.  PPG reported that
TCE is transported by tank trucks, rail cars, barges, and ships.   All of
these operations are controlled by submerged fill pipe technology.  Drums
without controls are also used to handle a small amount of TCE.  Louisiana
law requires that all loading vehicles with a capacity of 200 gallons and a
throughput of 40,000 gallons per day must have controls similar to submerged
fill pipes.
                                    2-12

-------
     PPG estimated that 7.1 Mg of TCE (13 percent of total plant emissions)
were emitted from secondary sources.  No controls were reported for the two
secondary streams.  In addition, PPG reported that 2.8 Mg (5 percent) of TCE
were emitted due to 37 equipment openings.  There are no laws specifically
regulating secondary or equipment opening emissions in Louisiana.

2.3  COST OF ADDITIONAL CONTROLS

     Cost estimates were developed for controlling emissions at TCE
production facilities for sources that are not presently well controlled.
The cost effectiveness of control was calculated for process vents, equipment
leaks, storage tanks, and loading/handling operations.  The details of the
methods used for costing are presented in Appendix C.   Table 2-5 summarizes
the cost of additional control at TCE production facilities.  The achievable
TCE emission reduction for different VOC cost effectiveness ranges is
presented in Table 2-6.

2.3.1  Control of Process Vent Emissions
     The cost for additional control of process vent emissions was calculated
for those vent streams that are not currently controlled to at least
98 percent efficiency.  The cost for additional control  is based on thermal
incineration at 98 weight percent efficiency.  The cost  effectiveness values
are S3.1 million/Mg VOC for the uncontrolled vent at the Dow facility and
$2.4 million/Mg VOC for the three vents at the PPG facility.  The potential
TCE emission reductions for the Dow and PPG facilities are 0.13 and 0.19 Mg,
respectively.

2.3.2  Control of Equipment Leak Emissions
     Neither Dow nor PPG currently have formal programs  to control  equipment
leak emissions.  The costs for additional  control of equipment leak emissions
were estimated based on the requirements of the benzene  fugitive NESHAP and
the equipment count data supplied by Dow and PPG.  For the Dow facility, the
average control efficiency associated with controlling equipment leak was
                                     2-13

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-------
            TABLE 2-6.  ESTIMATED TCE EMISSION REDUCTIONS AT TCE
                        PRODUCTION FACILITIES
Cost Effectiveness
   Range (S/Mg)

      Credit
      0 -   500
    500 - 1,000
  1,000 - 2,000
  2,000 - 5,000
      >5,000
     Nationwide C?HC1., Emission Reduction (Mg/yr)
Process   Equipment Leak  Storage    Loading     Total
              30.0
                                   30.0
               TOTAL
 0.3
 0.3
30.0
13.4
13.4
13.8
13.8
27.5
57.5
                                    2-15

-------
66 percent.  The potential TCE emission reduction is estirated to be 15.9 Mg
with an associated cost effectiveness of $740/Mg VOC.  For the PPG facility,
the average control efficiency associated with controlling equipment leaks
was 44 percent.  The potential TCE emission reduction is estimated to be
14.1 Mg with an estimated cost effectiveness of $780/Mg VOC.

2.3.3  Control of Storage Emissions
     Costs for controlling all fixed-roof storage tanks containing TCE were
estimated using three techniques:  installation of internal  floating roofs
with primary seals only, the installation of internal floating roofs with
primary and secondary seals, and a refrigerated condenser system.  The
control technique presented in Table 2-5 is the most cost effective technique.
TCE emissions from all storage tanks can be reduced by 11.5 Mg at the Dow
facility and 1.9 Mg at the PPG facility.  The cost effectiveness of storage
emission control was estimated to range from $5,300/Mg VOC for a storage
tank at the Dow facility to $130,000/Mg VOC for a storage tank at the PPG
facility.

2.3.4  Control of Loading Emissions
     Loading emissions are not currently controlled at the Dow and PPG
production facilities.  Control costs for tank trucks, ships, barges,
railcars, and drum were estimated using a condenser (90 percent efficient)
as the control device.  The cost effectiveness of loading emissions was
estimated to be $18,200/Mg VOC at the Dow facility and $34,300/Mg VOC at the
PPG plant.  The potential TCE emission reduction is 9.0 Mg for the Dow
facility and 4.8 Mg for the PPG facility.
                                   2-16

-------
2.4  REFERENCES

1.   Mannsville Chemical Products.  Chemical Products Synopsis -
     Trichloroethylene.  Cortland, New York.  1984.

2.   Letter from Morgan, D.L., Cleary, Gottlieb, Steen and Hamilton, to
     Rosensteel, R.E., EPA.  February 22, 1985.   Response for Halogenated
     Solvents Industry Alliance concerning industrial consumption volumes of
     trichloroethylene in 1983.

3.   Misenheimer, D. C., and W. H. Battye (GCA Corporation).  Locating and
     Estimating Air Emissions from Sources of Ethylene Bichloride.  Prepared
     for U.S. Environmental Protection Agency, Research Triangle Park,
     North Carolina.  Publication No. GCA-TR-CH-82-4.  (Revised) February
     1983.  p.  5.

4.   Letter and attachments from Arnold, S.  W.,  Dow Chemical, U.S.A. to
     Farmer, J. R., EPA.-ESED.  February 28,  1985.   Response to C^HCU 114
     Questionnaire.

5.   SRI International.  Assessment of Human Exposures to Atmospheric
     Perchloroethylene.  Prepared for U.S. Environmental  Protection Agency.
     Project No. CRU-6780.   January 1979.

6.   Letter and attachments from Komoroski,  K. S.,  PPG Industries, Inc., to
     Farmer, J. R., EPA:ESED.  February 14,  1985.   Response to C
     Questionnaire.
                                    2-17

-------
                    3.0 OTHER CHEMICAL PRODUCTION PLANTS

     This chapter presents the emissions and controls for six additional
chemical plants reporting trichloroethylene (TCE) emissions.   TCE was
reported to be emitted at four plants where it is either produced as a
by-product or used as a raw material.  These processes include ethylene
dichloride/vinyl  chloride monomer manufacture (2 plants), polyvinyl  chloride
manufacture (1 plant), and vinylidene chloride manufacture (1 plant).  TCE
emissions from these four plants  are from process vents, storage tanks,
equipment openings, equipment leaks, handling operations, relief device
discharges, and secondary (disposal) sources.  TCE was also reported to be
emitted at two other facilities which produce chlorinated solvents other
than TCE.  In order to offer a complete line of chlorinated solvents to
their customers,  these plants store TCE at their facilities,  resulting in
emissions from storage tanks, equipment leaks, and handling operations.

3.1  PROCESS DESCRIPTIONS, EMISSIONS, AND CURRENT CONTROLS

     This section presents the emission estimates and current controls for
other chemical plants reporting TCE emissions.  TCE emissions come from the
following processes:  ethylene dichloride/vinyl  chloride manufacture,
polyvinyl chloride manufacture, vinylidene chloride manufacture, and storage
to maintain a complete line of solvents.

3.1.1  Ethylene Dichloride (EDC)/Vinyl  Chloride Monomer (VCM) Manufacture
     Two EDC/VCM  manufacturing plants reported TCE emissions  in 1983.  These
plants were Shell Oil Co. in Deer Park, TX, and Borden Chemical  in Geismar,
LA. It is suspected that 15 other EDC/VCM facilities using the same  process
as Shell and Borden may also emit TCE as a by-product.  However, seven of
these other facilities which were contacted had no record of  TCE emissions.
                                     3-1

-------
     3.1.1.1  Process Description.   TCE is formed as a byc/oduct in the
first step of a two-step reaction which is employed at the two facilities.
EDC is manufactured either by the direct chlorination of ethylene or by the
oxychlorination of ethylene.   In both cases, TCE is formed as a byproduct as
shown in the following reactions.

     Direct chlorination of ethylene
          C1  + CH   100°C    ClCHCHpCl   +
          (ethylene)  FeCl3      (EDC)         (TCE)
                                2
     Oxychlorination of ethylene
           C2H4 +  HC1  + 02  - *-   C1CH2CH2C1  +  H20   +
            (ethylene)                      (EDC)               (TCE)

     The second step in both processes is the cracking (pyrolysis) of EDC
into vinyl chloride monomer, which does not result in TCE formation.

     3.1.1.2  Current Emissions and Controls.  The primary types of emissions
from the two EDC/VCM facilities are from storage  tanks, process vents,
handling operations, and secondary sources.  The  types and quantities of
emissions from these facilities are listed in Table 3-1.  Emission estimates
are also included in Table 3-1 for the 15 other EDC plants where TCE is
suspected to be emitted as a by-product.  No data  were obtained directly
from these other EDC plants.  Emissions were estimated to be proportional to
the emissions from the Shell and Borden EDC facilities that reported TCE
emissions.  The total TCE emissions from these other EDC plants are
estimated to be 21 Mg/yr.

Shell Oil Co., Deer Park, TX3
     The major source of TCE emissions for the Shell plant facility in 1983
was a fixed-roof storage tank.  Shell also reported TCE emissions from
process vents, handling operations, and a secondary source.  The emission
types and their controls are listed in Table 3-2.
                                     3-2

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     The production of EDC by the direct chlorination of e-.nylene resulted
in total TCE emissions of slightly more than 0.1 Mg in 1933 at this facility.
Storage tanks accounted for a majority of these emissions, totalling about
0.1 Mg (79 percent of the plant emissions).  Of the seven storage tanks at
this facility, one 56,000 gallon tank contributed 99 percent of TCE storage
emissions.  This tank is not reported to have any control technique associated
with it.  The other six tanks were controlled by a compression and incinera-
tion system that has a reported control efficiency of greater than 98 percent.
The Texas State regulations require that storage tanks containing certain
VOC classes (including TCE) and with a volume greater than 40,000 gallons
must be controlled by an internal floating roof tank, an external floating
roof tank with a vapor mounted primary and secondary seal, or a vapor
recovery system.
     Secondary emissions from a waste stream accounted for 0.02 Mg of TCE
emissions (16 percent).  Texas regulations do' not require any control  for
streams of this kind.
     Two process vents, which are controlled by an incinerator with a
reported efficiency of greater than 98 percent, result in less than
one percent of the total plant emissions (3 x 10"  Mg/yr).  These process
vents are controlled through incineration because of the vinyl chloride
NESHAP which requires streams containing vinyl  chloride to be controlled to
less than 10 ppm VCM.  In addition, process vent emissions in Deer Park
(Harris County) are regulated by the State.  These regulations require
process vent gas streams containing certain VOC classes (including TCE) to
be incinerated properly at a temperature equal  to or greater than 1300°F
(704°C) in a smokeless flare or a direct flame  incinerator before they are
allowed to enter the atmosphere.
     Tank trucks, which receive the heavy ends  from the EDC distillation
step of the process, account for 5 x 10"  Mg (4 percent)  of TCE emissions.
Shell reported that a vapor recovery system is  not used in their handling
operations.  Texas law states that facilities with an average daily through-
put of 20,000 gallons (30-day average) must have controls on loading and
unloading operations.
                                      3-7

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                            4
Borden Chemical , Geismar, LA
     The only reported source of TCE emissions from this facility is storage
tanks.  The tanks are reported to be controlled by an incinerator with an
efficiency of greater than 98 percent.  This facility produces EDC by the
oxychlorination process and stores the EDC, contaminated by TCE at approxi-
mately 0.1 percent, in four 300,000 gallon tanks.  The emissions from these
tanks totalled 5 x 10"6 Mg in 1983.

3.1.2  Polyvinyl  chloride (PVC) Manufacture
     Borden Chemical  in Iliiopolis, IL, was the only PVC production facility
reporting TCE emissions in 1983.  It was not within the scope of this study
to contact all the PVC producers regarding their emissions of TCE.  Thus,
detailed emissions information for PVC production was not obtained.  However,
other EPA studies have indicated significant use of TCE as a reaction chain
terminator in the production of PVC.  Chapter 7 presents the consumption and
emission estimates for TCE in PVC production.

                                  4
     3.1.2.1  Process Description.   Borden reported that vinyl chloride,
vinyl acetate, and water are the primary raw materials used to manufacture
the PVC co-polymer.  They also reported that TCE is used as a secondary raw
material and is present in quantities of less than 91 kg per batch. A
reaction equation for the process follows:

     C2H3C1    +     C2HCHOCOC3H   +   H20   +  C2HC13 	*"
(vinyl chloride)   (vinyl acetate)              (TCE)

                    [-CH2CHC1 :  CH2CHC1 :  CH2CHCl-]n
                                 (PVC)
                                             4
     3.1.2.2  Current Emissions and Controls.   The major emissions from
this process at the Borden/Il1iopolis facility are from equipment leaks and
secondary sources.  TCE was also emitted from equipment openings, storage
tanks and relief device.  The emission types and quantities are presented in
Table 3-1.
                                    3-8

-------
     The production of PVC resulted in emissions of about 1.1 Mg of TCE in
1983 at this facility.  Equipment leaks accounted for 0.5 Mg (45 percent)  of
TCE emissions in 1983.  The major equipment leaks were valves (0.1 Mg,
20 percent of equipment leak emissions), open end lines (0.3 Mg, 60 percent),
and flanges (0.04 Mg, 8 percent).  Illinois does not regulate VOC emissions
from equipment leaks.
     The final effluent from a quench tank waste stream was  estimated to
result in 0.6 Mg (55 percent of plant total) of TCE.  Illinois does not
regulate VOC emissions from secondary sources.
     Two equipment openings released 6 x 10   Mg of TCE (less than one percent
of total plant emissions) in 1983.  Two pressure relief device discharges
resulted in TCE emissions of 7 x 10"  Mg (less  than one percent) in 1983.
Borden also reported that a process vent was controlled with an incinerator
and a quench tank system with a reported control efficiency  of greater than
98 percent.  However, emissions were not reported for this process vent.
Illinois regulations require process vent emissions of organic compounds to
be limited to 100 ppm equivalent methane.
     One fixed roof 5,800 gallon storage tank emitted 0.02 Mg (2 percent)  of
TCE in 1983.  For organic compound storage tanks with volumes over 40,000
gallons, Illinois regulations require that (1)  the tank must be a pressure
vessel, (2) the tank must be equipped with a floating roof,  or (3) an
85 percent efficient vapor recovery system must be in place.

3.1.3  Vinyl idene Chloride Manufacture
     Dow Chemical's Freeport, TX, plant was the only vinylidene chloride
manufacturing facility that reported TCE emissions in 1983.

     3.1.3.1  Process Description.   TCE is formed as a byproduct in  the
manufacture of vinylidene chloride.  Vinylidene chloride may be made  by the
action of caustic on 1,1,2-trichoroethane, as is shown in the following
equation:
     CH2C1CHC12    +    NaOH        ^r    CC12CH2   +  H20    +  NaCl  +   C
(1,1,2-trichloroethane)                (vinyldene  chloride)            (TCE)
                                     3-9

-------
The TCE is separated from the reaction mass in a distilled on column.  TCE
is also present in the final product stream and in an exnaust stream that is
vented to the atmosphere.

     3.1.3.2  Current Emissions and Controls.    The major source of TCE
emissions from the Dow facility is equipment leaks.  TCE emissions from a
process vent and a storage tank were also reported.  The emission types and
quantities are presented in Table 3-1.  The emissions types  and their
controls are listed in Table 3-2.  The production of vinylidene chloride at
this facility resulted in about 2.3 Mg of TCE  emissions in  1983.  Equipment
leaks accounted for nearly 100 percent of this total.  Valves were the major
source of equipment leaks (1.3 Mg, 57 percent  of all leaks)  while flanges
were also a significant contributor (0.6 Mg, 26 percent).  Dow reported that
the plant has a monitoring system that detects between 75 and 80 percent of
all leaks.  No information was provided on the frequency of  repair for
detected leaks.  Therefore, equipment leak emissions estimates are based on
uncontrolled emission factors.
     The Texas Air Control Board has recently  promulgated regulations that
will require a formal equipment leak monitoring program.  The first round of
monitoring must be completed by the end of 1987.   The regulation will
require the annual testing of all valves in VOC service with a portable
hydrocarbon analyzer, the capping of open-ended lines and valves, the
monitoring of pump seals, and the detailed recordkeeping of  these practices.
     TCE emissions from one process vent and one storage tank at this
facility are estimated to be 4 x 10"  Mg/yr.  Dow considers  further informa-
tion regarding the process vent and storage tank to be confidential.

3.1.4  Storage of TCE for Resale6
     Two Vulcan Chemicals plants in Geismar, LA and Wichita, KS, store TCE
on-site for the purpose of resale to their chlorinated solvent customers.
The company reported that TCE is not used as a feedstock or  created as a
byproduct at these facilities.
                                    3-10

-------
     3.1.4.1  Current Emissions and Controls
Vulcan Chemicals, Geismar, LA
     The Vulcan Chemicals facility in Geismar, LA, reported that two sources
of TCE emissions, storage tanks and handling operations, resulted in the
emission of 2.0 Mg of TCE in 1983.  The emission types and their controls
are listed in Table 3-2.
     One storage tank resulted in the emission of 1.1 Mg of TCE (55 percent
of total plant emissions).  Vulcan considers further information regarding
their storage tanks to be confidential.  Louisiana state regulations require
storage tanks with volumes greater than 40,000 gallons which contain
volatile organic compounds to meet certain specifications.  The storage
vessels must either be pressure tanks, be equipped with submerged fill
pipes, or have floating roofs.
     Handling operations accounted for the remaining 0.9 Mg (45 percent) of
plant TCE emissions.  The company claimed that the control  techniques for
reducing handling emissions are confidential.   Louisiana state regulations
require that any loading facility for VOC servicing tanks, trucks,  or
trailers having a capacity in excess  of 200 gallons and having 20,000 gallons
per day (gpd) throughput for new facilities or 40,000 gpd for existing
facilities, averaged over any 30-day  period,  must be equipped with  a vapor
recovery and disposal  system.
                              Q
Vulcan Chemicals, Witchita,  KS
     The Vulcan Chemicals facility in Witchita, KS,  was estimated to have
emitted 1.6 Mg of TCE  in 1983.   Equipment leaks accounted for 0.9 Mg of TCE
emissions in 1983 (56  percent of total plant  emissions).   Pump seals were
the major source of leaks (0.4  Mg, 45 percent  of total  equipment leaks).
Flanges accounted for  another 0.3  Mg  (34 percent)  of TCE  equipment  leaks
emissions.   Kansas state law does  not regulate VOC  emissions  from equipment
leaks.
     One storage tank  was estimated to have emitted  0.5 Mg  (31 percent  of
total  plant TCE emissions).   Handling operations  accounted  for 0.2 Mg of  TCE
emissions (12 percent).   Vulcan considers  further  information  regarding
                                    3-11

-------
storage tanks and handling operations to be confidential.   ansas does not
have any laws regulating TCE emissions from storage tanks or from handling
operations.

3.2  COST OF ADDITIONAL CONTROLS

     Cost estimates were developed for controlling TCE emissions at the
other chemical production plants for sources that are not presently well
controlled.  The cost effectiveness of control  was calculated for equipment
leaks, and storage emissions.  Methods used for calculating these costs are
presented in Appendix C.  Table 3-3 summarizes  the cost of additional
control at these chemical plants and Table 3-4  presents potential  emission
reductions at various cost-effectiveness levels.
     Table 3-4 indicates that further control  of TCE emissions at these
sources can result in reduction of 3.5 Mg/yr at cost-effectiveness values
ranging from $l,900/Mg of VOC to $139,000/Mg of VOC.   Process vents are
reported to be well controlled and, thus, further controls are not costed.
Of the total potential TCE emission reductions, emission reductions from
equipment leaks account for 57 percent while additional emission reductions
from storage tanks account for the remaining 43 percent.

3.2.1  Control of Equipment Leaks
     The cost for additional control of equipment leaks were estimated based
on the requirements of the benzene equipment leaks NESHAP and company
supplied equipment counts.
     TCE emissions can be reduced by 2.0 Mg by  applying these controls.
This would result in a 53 percent reduction in  equipment leak emissions.
     The cost effectiveness of controlling equipment leak emissions ranges
from $l,900/Mg VOC at the Dow/Freeport facility to $17,800/Mg VOC at the
Borden/Illiopolis facility.
                                     3-12

-------












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-------
TABLE 3-4.  ESTIMATED TCE EMISSION REDUCTIONS FOR G'VER CHEMICAL
    PRODUCTION FACILITIES AS A FUNCTION OF COST EFFECTIVENESS

Cost Effectiveness
Range ($/Mg VOC)
Credit
0 - 5,000
5,001 - 10,000
10,001 - 15,000
15,001 - 20,000
>20,001
Nationwide TCE Emission Reduction
Equipment
Process Leak Storage
- -
1.1
0.5 1.0
0.1
0.4
0.4
(Mg/yr)
Total
-
1.1
1.5
0.1
0.4
0.4
              TOTAL     0.0          2.0            1.5        3.5
                              3-14

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3.2.2  Control  of Storage Emissions
     Costs for controlling emissions from fixed-roof storage tanks containing
TCE were estimated using three control  techniques:  the installation of
internal floating roofs with primary seals only, the installation of internal
floating roofs  with primary and secondary seals, and the installation of a
refrigerated condenser.  The control technique which yielded the lowest cost
effectiveness ($/Mg VOC) for each facility is presented in Table 3-3.
     TCE emissions can be reduced by 89 percent (1.5 Mg) by applying these
controls.   The  cost effectiveness of controlling storage tank emissions
ranges from $8,800/Mg at the Vulcan/Geismar facility to $139,000/Mg VOC at
the Borden/Illiopolis facility.
                                     3-15

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3.3  REFERENCES

1.   "Source Assessment:   Chlorinated Hydrocarbons Manufacture",
     Kahn, Z. S., et al,   Prepared for U.S.  Environmental  Protection Agency,
     Office of Research  and Development, Washington, D.C.   August 1979.
     p. 17.  EPA-600/2-79-019g.

2.   "Chemistry of Organic Compounds", Noller,  Carl  R.   Saunders Publishing,
     Third Edition,  p.  794.

3.   Letter and attachments from Gillespie,  T.  E., Shell  Chemical Company,
     to Farmer, J. R., EPA:ESED.  January 4, 1985.  Response to C-HCl-
     114 Questionnaire.

4.   Letter and attachments from Springer, C.  R.,  Borden,  Incorporated,  to
     Farmer, J. R., EPA:ESED.   February 15,  1985.   Response to C2HC13
     114 Questionnaire.

5.   Letter and attachments from Arnold, S.  L., Dow Chemical, U.S.A., to
     Farmer, J. R.., EPA:ESED.   February 28,  1985.   Response to CpHCU
     114 Questionnaire.

6.   Letter and attachments from Boyd, J. M.,  Vulcan Chemicals, to
     Farmer, J. R., EPA-.ESED.   February 1, 1985.   Response to C2HC13
     114 Questionnaire.
                                    3-16

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                     4.0  SOLVENT DEGREASING OPERATIONS

     About eighty-five percent (or 56,000 Mg) of the total  trichloroethylene
(TCE) produced in 1983 was consumed as a solvent for degreasing operations.
It is estimated that of this amount about 52,600 Mg were emitted to  the
atmosphere.  Trichloroethylene was used as a solvent for degreasing  in  a
variety of industries, primarily within five distinct Standard Industrial
Classifications (SIC).  Emissions from degreasing operations  were estimated
in this study by obtaining the 1983 consumption of TCE for  each SIC  and
applying to it an emission factor derived for degreasing operations.   The
following sections present a brief discussion of the types  of degreasers,
emissions, emissions control, estimates of emissions from degreasing
operations in 1983, and estimates of the costs associated with emissions
control.  Due to the large number of degreasing facilities  in these
industries, no attempt was made in this study to identify locations  of
individual degreasers,

4.1  INDUSTRY DESCRIPTION

     Degreasing is an integral part of many industrial  processes such as the
manufacture of automobiles, electronics, furniture,  appliances, jewelry, and
plumbing fixtures.  It is also used to a minor extent in the  textiles,
paper, plastics, and glass manufacturing industries.   The degreasing process
makes use of nonaqueous or aqueous solvents to clean and remove debris  from
a surface prior to painting, plating, assembly, repair,  inspection,  or other
treatment.  Various solvents, including petroleum distillates, chlorinated
hydrocarbons, ketones, and alcohols are used either alone or  in blends for
degreasing purposes.   Five major industry groups used  TCE  in degreasing
operations.  These are furniture and fixtures (SIC 25),  fabricated metal
products (SIC 34), electric and electronic equipment (SIC 36), transportation
                                                                       2
equipment (SIC 37), and miscellaneous manufacturing  industries (SIC  39).

-------
4.2  DECREASING EQUIPMENT

     There are three basic types of degreasing equipment:   cold cleaners,
open top vapor degreasers, and conveyorized degreasers.   Cold cleaners  are
usually the simplest and least expensive type of degreaser.   Simple  cold
cleaners consist of a tank of solvent with a cover for nonuse periods.  More
sophisticated cold cleaners may have solvent sumps, spray nozzles, drains,
and automatic controls.   In the typical  cold cleaning process, soiled
objects are dipped into  the solvent bath until the soils are dissolved  from
the surface.  The cleaning process can be enhanced by agitating the  solvent
and brushing or spraying soiled parts.  Solvents are normally used at  room
temperature, but in some applications may be heated to a temperature below
the boiling point of the solvent.
     Open top vapor degreasers are similar in configuration  to cold  cleaners
but are operated in a different manner.   Open top vapor  degreasers are
operated at an elevated  temperature to boil  the solvent.  The vapors from
the boiling solvent condense on and clean soiled objects.   A typical open
top vapor degreaser consists of a  tank equipped with a heating and cooling
system.  The heating coils on the  inside bottom of the tank  boil  the
solvent, thereby generating the vapors needed for cleaning.   Cooling coils
located near the top and on the inside perimeter of the  tank condense
solvent vapors, preventing them from diffusing out of the  tank.   Thus,  a
controlled vapor zone is created within  the tank.  Soiled  objects are
lowered into the vapor zone where  solvent condenses on their surfaces  and
dissolves the soils.  When condensation  ceases, the cleaned  objects  are
withdrawn.  Only halogenated solvents are used for vapor degreasing  because,
in addition to their excellent cleaning  capabilities, they are nonflammable
and because their heavy  vapors can be easily contained within the machine.
     Conveyorized degreasers feature automated conveying systems  for
continuous cleaning of parts.  Conveyorized degreasers clean either  by  cold
cleaning or vapor degreasing, although most clean using  vaporized solvent.
While  these units tend to be the largest degreasers, they are enclosed
systems and actually produce less  emissions per part cleaned than other
types  of degreasers.
                                    4-2

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4.3  EMISSIONS FROM DEGREASING OPERATIONS

     National  emission estimates for degreasing operations were calculated
from 1983 TCE consumption data provided by the (Halogenated Solvents
                         2
Industry Alliance (HSIA).   The consumption data were used in conjunction
with emission factors generated from available literature to estimate
nationwide emissions.   A brief description of the estimation procedure
follows.
     Available data indicate that 5 percent of all TCE consumed in degreasing
operations is used in cold cleaning while about 95 percent is used in vapor
degreasing.   Previous EPA studies estimated that for every kg of a solvent
used in cold degreasing, 0.43 kg are emitted.   The corresponding emission
factor for open top vapor degreasing is 0.785  kg/kg solvent consumed and for
conveyorized degreasing is 0.85 kg/kg solvent  consumed.    Assuming that
vapor degreasing use of TCE is divided equally between open top and
conveyorized degreasing processes, a weighted  average emission factor of
0.79 kg/kg TCE consumed was calculated.  It was assumed  that the remaining
0.21 kg/kg TCE consumed would be recycled.
                                                 c
     Based on information from solvent recyclers," it was estimated that
about 75 percent of all waste solvent from degreasing (0.21 kg/kg TCE
consumed) is recovered and reused.  Therefore, total  TCE consumption by a
degreaser equals consumption of fresh solvent  plus consumption of recycled
solvent.  As before, 0.79 kg/kg of the recycled solvent  is emitted.   Taking
into account the emission of recycled solvent, it is  estimated that for
every kg of fresh TCE used in degreasing, 0.94 kg is  emitted.  The remaining
0.06 kg is assumed to be either incinerated or disposed  of in a landfill
according to appropriate regulations.  Appendix A presents the details  of
these material balance calculations.
     The total 1983 TCE emissions for each of  the five SICs were estimated
by applying the 0.94 kg factor to the 1983 TCE consumption figure
(56,000 Mg).  Table 4-1 shows the estimated TCE emissions from degreasing
operations in these industries.
                                   4-3

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   TABLE 4-1.  1983 TCE EMISSIONS FROM DECREASING OPERATIC'-S, BY INDUSTRY



                                                       Emissions
     Industry (SIC Code)                                (Mg/yr)


Furniture and Fixtures (25)                               4,370

Fabricated Products (34)                                 21,930

Electrical and Electronic Equipment (36)                  9,140

Transportation Equipment (37)                            10,730

Miscellaneous Manufacturing Industries (39)               6,430

          TOTAL                                          52,600
                                    4-4

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     Emissions were also estimated for each State in the 
-------
TABLE 4-2.  1983 TRICHLOROETHYLENE EMISSIONS -ROM
            DECREASING OPERATIONS, BY STATE

State
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawai i
Idaho
111 i no is
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri

Emissions
(Mg)
750
3
470
520
6,100
510
1,700
80
7
1,400
880
30
30
3,350
2,700
550
490
600
550
170
530
1,700
3,390
820
600
1,430

State
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsyl vania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
V i rg i n i a
Washington
West Virginia
Wisconsin
Wyoming
TOTAL
Emissions
(Mg)
15
200
60
200
1,700
70
3,430
1,700
20
3,600
580
250
2,840
250
700
450
30
1,160
2,250
250
150
1,000
850
150
1,330
4
52,600
                       4-6

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            TABLE 4-3.   EXAMPLE CONTROL TECHNIQUES FOR DE3xEASERS
Degreaser Type            Control  Devices            Operating Practices


Cold Cleaners            Cover for tank             Keep cover closed  when
                         Parts drainage rack         degreaser not  in  use
                         Raised freeboard           Fully drain cleaned
                                                     parts

Vapor Degreasers         Cover for tank   .          Keep cover closed  when
                         Freeboard chiller           degreaser not  in  use
                         Raised freeboard           Fully drain cleaned
                         Carbon adsorber             parts
                                                    Move parts slowly  into
                                                     and out of degreaser

Conveyorized             Port Covers                 Maintain conveyor  at
 Degreasers              Freeboard chillers           moderate speed
                         Carbon adsorbers           Keep exhaust ventilation
                                                     rates moderate


aFreeboard is the distance from the liquid solvent  surface or top of the
 solvent vapor to the lip of the tank.   "Raised  freeboard" is a physical
 extension of the freeboard to reduce drafts,  and  thereby solvent
 evaporation, within the degreaser.

 Additional cooling coils above the primary  coils  to further inhibit the
 diffusion of solvent vapors to the atmosphere.
                                    4-7

-------
     Work practices can be improved to limit solvent emis:; ons from
degreasing.  These improvements, characterized by practices that reduce
solvent exposure to the atmosphere, include: keeping degreaser covers
closed, fully draining parts prior to removal from degreaser, maintaining
moderate conveyor speeds, and keeping ventilation rates moderate.

4.5  COST OF EMISSIONS CONTROL

     The costs for controlling emissions from model  degreasing facilities
                                                      789
have been estimated in previous EPA-sponsored studies.  ' '   The purpose of
the cost evaluation effort for this document is to update the costs
presented in the earlier EPA studies.  Costs are presented for a representa-
tive size degreaser for each of three degreaser types:   (1) cold cleaners,
(2) open top vapor degreasers, and (3) conveyorized  vapor degreasers.  These
cost estimates are for retrofitting existing degreasing facilities.  Tables
4-4, 4-5, and 4-6 present the retrofit cost estimates for cold cleaners,
open top vapor degreasers, and conveyorized vapor degreasers, respectively.
The costs estimated in the previous EPA study are in fourth quarter 1980
dollars.  These costs were updated to fourth quarter 1984 dollars  using
plant cost indexes (323.6/269.7 = 1.20).10'11
     Several assumptions concerning degreaser operating parameters were made
in developing costs for controlling emissions from the  three types of
degreasers.  It was necessary to assume operating parameters for typical
uncontrolled and controlled degreasers so that average  emission reductions
for each type of degreaser could be determined.
     In developing cold cleaner control costs the degreaser size was assumed
           9
to be 0.4 m  and the annual period of operation was  assumed to be 500 hours
(2 hrs/day, 5 days/week, 50 weeks per year).  The uncontrolled emissions
were based on a cold cleaner with a 0.3 freeboard ratio and a manual cover.
Total emissions from this uncontrolled cold cleaner  were estimated to be
1,140 kg/yr.  The controlled emissions were based on a  cold cleaner with a
0.75 freeboard ratio, a manual cover, and a drainage rack.  Total  emissions
from this cold cleaner were estimated to be 740 kg/yr.   It is estimated that
a  35 percent emissions reduction can be achieved with a raised freeboard,
                                   91213
manual  cover,  and a drainage rack.  '  '

                                    4-8

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            TABLE 4-4.  RETROFIT CONTROL COSTS FOR COLD C_£ANERS
                        (Fourth Quarter 1984 Dollars)
                                             0.7 F8Ra, Manual
                                             Cover, and Drain


Capital  Costs, ($)

     -  Freeboard (installed)                     360
     -  Drain                                      25

Installation Costs, S

     -  Freeboard (in purchase cost)
     -  Drain                                      13

Total Installed Capital  Costs, S                  398

Annual Operating Costs,  ?/yr
- Capital Charges
- Administration, .Insurance, and Taxes
- Operating LaborJ
- Maintenance
- Utilities
Total Annual ized Cost, $/Yr
Emission Reduction, Mg/Yr
Recovered Solvent Credit , $/Yr
Net Annual ized Cost, $/Yr
Cost Effectiveness, $/Mg
53
16
238
12
0
370
0.4
176
180
450
aFreeboard ratio.

 Total Installed Capital  Cost annualized over 15 years  at a 10 percent
 interest rate.

GFour percent of total  installed capital cost.

 Labor due to drain time  requirement, based on  20 loads per day,
 15 second drain time per load.
Q
 Three percent of total  installed capital  cost.

 Based on solvent price  of 50.44 per kilogram.
                                     4-9

-------
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-------
       TABLE 4-6.   RETROFIT CONTROL COSTS FOR CONVEYORIZEI DEGREASERS




Capital Costs, 5
Refrig. Freeboard
Carbon Adsorber
Auxi 1 iary
Installation Costs, S
Refrig. Freeboard
Carbon Adsorber
Auxiliary Equipment
Additional Plant Space

3
RFC3

14,994
0
0

407
0
0
175

Carbon
Adsorber

0
58,310
0

0
11,900
0
4,998
Adsorber
Drying
Tunnel

0
58,310
11,900

0
11,900
2,380
5,998
Total Capital Costs, S
15,576
75,208
90,488
Capital Charges
Adm. , Ins. , & Taxes
Operating Labor
Maintenance
Util ities
Electricity
Steam
Cool ing Water
Total Annuaiized Cost, $/Yr
Emission Reduction, Mg/Yr
Recovered Solvent Credit, S/Yre
Net Annual ized Costs, $/Yr
Cost of Control , $/Mg
2,047
623
0
467

195
-
-
3,330
9.84
4,330
-1,000
-100
9,882
3,008
0
2,256

277
626
62
16,110
10.9
4,795
11,315
1,040
11,890
3,620
0
2,715

277
625
62
19,190
12.4
5,455
7,875
640
Refrigerated freeboard chiller.
bTotal installed capital cost annualized over 15 years at a 10 percent
 interest rate,
cFour percent of total  installed capital cost.
dThree percent of total installed capital cost.
eBased on solvent price of $0.44 per kilogram.
                                    4-12

-------
     For open top vapor degreaser (OTVD)  control  cost development the
                                      2
degreaser size was assumed to be 1.5 m  and the operating schedule was
assumed to be 1,500 hours (6 hr/day, 5 day/week,  50 week/yr).   The uncon-
trolled emissions were based on an OTVD with a freeboard ratio of 0.5 and
were estimated to be 8,770 kg/yr.  This estimate  assumes an 8-hour working
day during which the degreaser is uncovered for six of these hours; the
degreaser is idle for the remaining two hours.  Five control  options  for
OTVDs were investigated, including covers and raised freeboards,  automated
covers and raised freeboards, above-freezing refrigerated chillers, below
freezing refrigerated chillers, and carbon adsorption systems.  The
controlled emissions are presented in Table 4-5,  and are based on the
following:  (1) utilization of a cover with a control efficiency of 90 percent
during idle time; (2) reduction of 15 percent in  vaporization  losses  by
increasing the freeboard ratio from 0.5 to 0.75;  (3) reduction of 40  percent
in vaporization losses by use of either above- or below-freezing chillers;
(4) reduction of 40 percent in vaporization losses due to the  use of  an
automated cover; (5) reduction of 65 percent in vaporization  losses due to
the use of a carbon adsorber; and (6) a 10 percent reduction  in carry out
losses due to use of a refrigerated freeboard device.  Overall achievable
emission reductions with these techniques were estimated to range from
21 percent to 44 percent.9'12'13
     Conveyorized degreaser control cost  estimates were based  on  a degreaser
     2
3.0 m  in size with an operating schedule of 2,000 hours (8 hr/day, 5day/wk,
50 wk/yr).  Uncontrolled emissions for a  typical  conveyorized  degreaser were
estimated to be 21,840 kg/yr.  Three control  options were examined for
costing purposes, including refrigerated  freeboard chillers, carbon adsorbers,
and carbon adsorbers along with a drying  tunnel.   Controlled emissions are
presented in Table 4-6 and are based on the following:   (1) a  45  percent
reduction in solvent loss due to the use  of refrigerated freeboard chillers;
(2) a 50 percent reduction in solvent loss due to the use of a carbon
adsorber; and (3) a 15 percent reduction  in carry-out emissions only, due to
the use of a drying tunnel.  Achievable emission  reductions using these
                                                                9 12  13
techniques are estimated to range from 45 percent to 57 percent.  '  '
                                   4-13

-------
     Estimates of the national  emission reduction associate: with
controlling TCE emissions from  degreasers were made using:   (1)  emission
factors developed for uncontrolled cold cleaners, open  top  vapor degreasers,
and conveyorized vapor degreasers; and (2) the estimated total  number  of
uncontrolled degreasers in TCE  service in 1983.  It is  estimated that  about
26,170 Mg/yr TCE emissions can  be reduced by the application of control
techniques on uncontrolled cold cleaners, open top vapor degreasers,  and
conveyorized vapor degreasers.   This represents a 50 percent reduction in
TCE emissions from degreasers.   Potential TCE emission  reductions for  each
type of degreasers are 370 Mg/yr (cold cleaners), 10,900 Mg/yr  (open  top
vapor degreasers), and 14,900 Mg/yr (conveyorized vapor degreasers).   The
details of the calculations for estimating national  emission reduction are
presented in Appendix A.

4.6  REGULATORY REQUIREMENTS

     EPA has approved RACT guidelines for solvent degreasing operations  that
have been adopted by 32 States  and the District of Columbia. The 10  States
that have the highest estimated emissions of TCE from solvent degreasing,
California, Ohio, New York, Michigan, Illinois, Pennsylvania, Indiana,
Texas, Massachusetts, and New Jersey, have all adopted  EPA-approved  RACT.
These  10 States account for about 59 percent of total  degreasing emissions
of TCE.  In addition, EPA has proposed (but not promulgated) an NSPS  that
would  control emissions from new solvent degreasers.
                                     4-14

-------
4.7  REFERENCES

1.   Bellinger, J.  C., and J.  L.  Shumaker.   Control  of Volatile Organic
     Emissions from Solvent Metal  Cleaning.    U.S.  Environmental  Protection
     Agency.   Research Triangle Park, N.C.   Publication Mo.
     ERA-450/2-77-022.  November  1977.   203  p.

2.   Letter from Morgan, D. L., Cleary, Gottlieb,  Steen, and Hamilton,  to
     Rosensteel, R.E., EPA.  February 22, 1985.   HSIA data on
     trichloroethylene production  and consumption.

3.   Tankg, J. L.  Industrial  Survey of Halogenated  Solvent Producers and
     Degreaser Manufacturers.   GCA/Technology Division, Chapel  Hill,
     North Carolina.   July 1981.

4.   Hoogheem, T. J., 0. A. Horn,  T. W. Hughes,  and  P. J.  Marn  (Monsanto
     Research Corporation).  Source Assessment:   Solvent Evaporation  -
     Degreasing Operations.  Prepared for U.S.  Environmental Protection
     Agency.   Cincinnati, OH.   Publication  No.  EPA-600/2-79-019f.
     August 1979.  133 p.

5.   Telecon.  Pandullo, R. F., Radian  Corporation,  with Pokorny,  J.,
     Baron-Blakeslee, Inc.  March  19, 1985.   General  information  on solvent
     recycling.

6.   Bureau of the Census.  County Business  Patterns  1982.  U.S.  Department
     of Commerce.  Washington, D.C.  Publication No.  CBP-82.  October 1984.

7.   GCA Corporation.  Organic Solvent  Cleaners  -  Background Information for
     Proposed Standards.  Prepared for  U.S.  Environmental  Protection  Agency.
     Research Triangle Park, N.C.   Publication  No.  EPA-450/2-78-045a.
     October  1979.  282 p.

8.   Memo from O'Brian, T., GCA,  to D.  A. Beck,  EPA/CPB.  March 2, 1982.
     Estimation of Solvent-Specific Control  Costs.

9.   Memo from Smith, M., GCA, to  D. A. Beck, EPA/CPB.  August  20, 1981.
     Background Information on Cost Analysis for Emission  Guideline Document
     for Organic Solvent Cleaners,

10.  Chemical Engineering plant cost index.   Chemical Engineering,
     Volume 88, Number 8.

11.  Chemical Engineering plant cost index.   Chemical Engineering,
     Volume 92, Number 6.

12.  Westlin, P. R,, and J. W. Brown, Test  Report  -  Solvent Drainage  and
     Evaporation from Cold Cleaner Usage.  U.S.  Environmental Protection
     Agency,  Office of Air Quality Planning  and  Standards, Research Triangle
     Park, North Carolina.  January 1978.
                                    4-15

-------
13.   Suprenant,  K.  S.  and D.  W.  Richards.   Study to Supper, 'Jew Source
     Performance Standards for Solvent Metal  Cleaning Op=~ations.  Prepared
     by the Dow  Chemical  Company for the U.S. Environmental Protection
     Agency.   Contract No. 68-02-1329.  April 1976.
                                    4-16

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                        5.0  DISTRIBUTION FACILITIES

     Virtually all  trichloroethylene produced is sold through chemical
distributors.  There are an estimated 300 chemical  distributors handling
chlorinated solvents.  Table 5-1 presents the five  largest TCE distributors
handling about 93 percent of the total  TCE sold through distributors.   In
general, distributors maintain as few as three to as many as 65 regional
distribution facilities spread out across the nation.  One chemical  distri-
butor estimated the number of regional  distribution facilities at 500
nationwide.   Each  regional distributor receives chemicals directly  from the
producer by tank truck or railcar.  Transportation  is provided by the
distributor.  The received chemicals are stored by  regional  distributors in
8,000 to 20,000 gallon fixed-roof storage tanks. The storage tanks  used by
regional distributors include vertical, horizontal, and underground  tanks.
Turnover times for  storage tanks typically range from 2 weeks to a little
over a month.  Although the exact number of distributors and distribution
facilities that handle TCE is net known, it is estimated that there  are
96 TCE storage tanks owned by distributors, the majority of which are
fixed-roof tanks.  The procedure used to estimate the number of tanks  is
given in Appendix E.

5.1  EMISSIONS FROM DISTRIBUTION FACILITIES

     Emissions from distribution facilities can be  categorized as two  types,
storage and handling.  Storage emissions include breathing and working
losses from tanks.   Handling emissions  result from  vapor displacement  when
drums and tank trucks are filled.
     Storage and handling emissions of  TCE from distribution facilities were
estimated using AP-42 emission factors   and data supplied by the major
distributors.  The  details of those calculations are presented in Appendix 0.
It is estimated that approximately 39 Mg of TCE were emitted in 1983 from
distribution facilities.  Storage emissions accounted for 21 Mg, while
handling emissions  were about 18 Mg.
                                    5-1

-------
         FABLE 5-1.   SUMMARY OF MAJOR TRICHLOROETHYLENE T TRIBUTORS


Company

Number Of
Distribution
Facilities
Number
Of TCE
Storage
Tanks

Typical
Size
(Gal)

Typical
Size
Turnover
Ashland'
McKesson'
Chem-Centra"
Detrex"
Thompson-
  Hayward
61


63


31


25


26
52


 6


15


10


 6
 8,000      3 wks - 1 mo
10,000          N/A
10,000          1 mo
15,000      U wks - 1 mo
10,000      2-3 months
                                     5-2

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5.2  REGULATORY REQUIREMENTS

     There are State and Federal regulations that may affect trichloro-
ethylene distribution facilities.  Most States have regulations for storage
and handling of volatile organic liquids and a new source performance
standard (NSPS) for storage of volatile organic liquids was proposed in
October 1984.  However, TCE may be exempted from these regulations due to
its low vapor pressure.  Generally, these regulations exempt organic liquids
with a vapor pressure below 1.5 psia.  The vapor pressure for TCE is
1.2 psia at 70°F and 1.5 psia at 80°F.
                                     5-3

-------
5.3  REFERENCES

1.   Memo from Howie, R.  H., Radian Corporation.   March 4,  1985.
     Distribution of trichloroethylene, perchloroethylene,  methylene
     chloride, and carbon tetrachloride.

2.   Telecon.  Sterett, R.,  Ashland Chemical  Company,  with  Howie,  R. H.,
     Radian Corporation.   February 7,  1985.   Conversation on  storage of
     chlorinated solvents.

3.   Telecon.  Eisner, D.,  McKesson Chemical  Company,  with  Howie,  R. H.,
     Radian Corporation.   February 7,  1985.   Conversation on  storage of
     chlorinated solvents.

4.   Telecon.  Trice, L., Chem-Central, with  Howie,  R.  H.,  Radian
     Corporation.  February  8, 1985.  Conversation on  storage of chlorinated
     solvents.

5.   Telecon.  Blumquist, R., Detrex,  with R.  H.  Howie, Radian Corporation.
     February 9, 1985.  Conversation on storage of chlorinated solvents.

6.   Telecon.  Hart, W.,  Thompson-Hayward, with R. H.  Howie,  Radian
     Corporation.  February  18, 1985.   Conversation  on storage of
     chlorinated solvents.

7.   U.S. Environmental Protection Agency.  Compilation of  Air Pollutant
     Emission Factors.  Supplement 7.   Research Triangle Park, North
     Carolina.  Publication  No. AP-42.   August 1977.
                                     5-4

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                         6.0  MISCELLANEOUS SOURCES

     About 10,000 Mg of trichloroethylene (TCE) were consumed in
miscellaneous applications in 1983.  These miscellaneous applications
include use (1) as a solvent in adhesive formulations; (2) as a solvent in
paints and coatings; (3) as a reaction chain transfer agent in polyvinyl
chloride (PVC) production; and (4) in miscellaneous chemical synthesis and
                     1 2
solvent applications. '
     The estimated consumption and emissions of TCE emissions for each
miscellaneous source category are presented in Table 6-1.  It is estimated
that air emissions in 1983 were about 3,430 Mg.  The bulk of adhesives,
paints, and coatings are used in household applications, although they are
also used by industry.  Trichloroethylene emissions from adhesives, paints,
and coatings occur through evaporation upon application.  Consequently, it
is estimated that all the TCE consumed in these applications in 1983 was
emitted.  It is also estimated, for the purposes of this study, that all  TCE
consumed in the various chemical synthesis and solvent applications in 1983
was emitted.
     Trichloroethylene is used in PVC production as a reaction chain
transfer agent to create low molecular weight polymers.   The PVC suspension
process is the only process that uses TCE in this manner.  TCE is used by
about 15 percent of the companies using the suspension process.   Most of
the TCE is destroyed in the chain transfer reaction.  A recent EPA report
estimates that about 6500 Mg were used as a reaction inhibitor in PVC
                                                 4
production in 1978 and about 130 Mg were emitted.   It is assumed in
Table 6-1 that the consumption and emissions of TCE in PVC production were
the same in 1983 as they were in 1978.  It should be noted that it was not
within the scope of this study to identify all PVC producers using TCE.
However, one facility was identified as using TCE as a reaction inhibitor in
PVC production.  As discussed in Chapter 3.0, Borden Chemical  in Illiopolis,
Illinois emitted about 1 Mg of TCE in 1983 during PVC production.  The
estimated TCE emissions from PVC production listed in Table 6-1 include the
emissions from this Borden facility.
                                     6-1

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   TABLE 6-1.  1983 TRICHLOROETHYLENE CONSUMPTION AND EMISSIONS
               FROM MISCELLANEOUS SOURCE CATEGORIES
                                        Consumption      Emissions
     Category                             (Mg/Yr)         (Mg/Yr)
Adhesive Formulations                        420            420
Paints and Coatings                          520            520
PVC Production                             6,500            130
Miscellaneous                              2.340          2,340
(Chemical Synthesis and General Solvent)
     TOTAL                                 9,780          3,430
                                6-2

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6.1  REFERENCES
1.



2.


3.



4.
Letter from Morgan, D.L., Cleary, Gottlieb, Steen and Hamilton to
R. E. Rosensteel, EPA:ESED.  February 22, 1985.  Halogenated Solvents
Industry Alliance (HSIA) information on trichloroethylene consumption,
Chemical Products Synopsis - Trichloroethylene.
Mannsville Chemical Products.  March 1984.
Cortland, New York,
Telecon.  Barr, J., Air Products Co., with Murphy, P. B., Radian
Corporation, July 18, 1985.  Information on TCE useage in PVC
manufacturing.

Memo from Callahan, M.A., TSPC Solvents Work Group #2 to M.C. Bracken,
Toxic Substances Priorities Committee.  February 1, 1982.  Final report
of TSPC Solvents Work Group #2.
                                     6-3

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                 7.0  PUBLICLY OWNED TREATMENT WORKS (POTWs)

7.1  EMISSION ESTIMATES

     A recent EPA study described a methodology for estimating trichloro-
ethylene (TCE) emissions from publicly owned treatment works (POTWs).   TCE
emissions are believed to occur through volatilization during treatment of
industrial  discharges containing TCE.  According to the EPA study, emission
estimates were based on data from the 1,600 POTWs nationwide identifed as
treating industrial discharges.  Data obtained include percent of total
inflow to POTW attributable to industrial  discharges, types of industries
discharging to POTW, and type of treatment at the POTW.  A specific emission
factor for TCE was developed from the results of a prior EPA study providing
mass-balance information on several pollutants for 50 POTWs.  Emissions for
an individual POTW were estimated using the emission factor and the assumed
amount of TCE in the waste stream entering the POTW.  Using this methodology
and aggregating results for individual POTWs it is estimated that about
1,400 Mg of TCE are emitted annually in the U.S. from POTWs.1'2
     This national emission estimate is at best rough.   The TCE emission
factor used is based on a sample of 50 POTWs.  These 50 were not selected to
be a statistically valid representation of all POTWs in the country.  In
fact, they more accurately represent large POTWs with a relatively high
                                                   2
proportion of industrial discharge in the  influent.
                                     7-1

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7.2  REFERENCES

1.   Memorandum and attachments from Lahre, T.,  EPA:AMTB, to
     Southerland, J. H., EPA:AMTB.   December 5,  1983.   Initial  look at
     available emissions data on POTWs.

2.   U.S. Environmental  Protection  Agency.   Hazardous  Air Pollutants - Air
     Exposure and Preliminary Risk  Appraisal for 35 U.S.  Counties.   Office
     of Policy Analysis, Washington, D.C.   September 1984.
                                     7-2

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                               APPENDIX A
      MATERIAL BALANCE FOR TCE EMISSIONS FROM DEGREASING OPERATIONS

A.I  MATERIAL BALANCE
(1)
          Fraction  of degreasing use of TCE  in  cold cleaning     =  0.05
          Fraction  of degreasing use of TCE  in  vapor degreasing  =  0.95
          Emission  factors:
          - cold cleaning:             0.43  kg/kg  used
          - open top degreasing:      0.78  kg/kg  used
          - conveyorized degreasing:  0.85  kg/kg  used
          Assuming  TCE usage in  vapor degreasing  is divided equally between
          open  top  and conveyorized  vapor degreasing, a  weighted average
          emission  factor is calculated as  follows:
          (0.05)(0.43) + (0.475)(0.78) + (0.475)(0.85)  = 0.79 kg/kg used

(2)  -  For every kg of fresh TCE used, 0.79 kg is emitted.   Assume all  of
        the remaining 0.21 kg is sent to solvent recovery.
     -  Estimate that 75 percent of all solvent sent to recovery is
        recycled.
     -  Calculate emissions as follows:
                 0.79 kg
                       (emissions from
                   >V   fresh TCE)
                                                  0.79x
                                                      (Emissions  from  use  of
                                                      recycled TCE)
(Fresh TCE)
                 0.21
             (to solvent
              recovery)
                                                            —  x kg
                                                             (recycled TCE)
                                                   0.21x
                                                 (to  solvent
                                                  recovery)
                                     A-l

-------
         x = 0.75 (0.21 + 0.21x)
         x = 0.19 (Amount of recycled TCE used per kg of fresh TCE used)
     0.72x = 0.15 (Amount of recycled TCE emitted per kg of fresh TCE used)
     Total TCE emitted per kg of fresh TCE used = 0.79 + 0.15
                                                = 0.94 kg
A.2  NATIONAL EMISSION REDUCTION CALCULATIONS

     National emission reduction can be calculated by estimating the amount
of solvent emitted by the degreasers that are presently uncontrolled and
applying a control efficiency to these emissions.  The emission factors
presented in Section A.I for cold cleaners, open top vapor degreasers, and
conveyorized vapor degreasers are overall emission factors representing the
average emission factor from controlled and uncontrolled degreasers.  An
uncontrolled degreaser emission factor was developed for the three types  of
degreasers so that the national emissions from uncontrolled degreasers could
be calculated.  An uncontrolled degreaser is considered to be one that does
not have the most stringent control  technique for its degreaser type.  These
control techniques were described in Chapter 4.  For example, the most
stringent control technique for an open top vapor degreaser is a carbon
adsorber.  Therefore, an uncontrolled open top vapor degreaser is one that
does not control emissions with a carbon adsorber.  In reality, degreasers
have levels of controls ranging from no control techniques to the most
stringent control techniques available.  Therefore, defining an uncontrolled
degreaser as one that does not have the most stringent control techniques
for its degreaser type results in an overestimate of the achievable emission
reduction.

     Information on the number of uncontrolled versus controlled degreasers
                                    1 2
was obtained from industry contacts.  '   These are as follows:

     Ratio of uncontrolled/controlled cold cleaners = 0.65/0.35
                                     A-2

-------
     Ratio of uncontrolled/controlled open top vapor degreasers = 0.99/0.01
     Ratio of uncontrolled/controlled conveyorized vapor degreasers =
     0.95/0.05

     The uncontrolled degreaser emission factors were then calculated
according to the following equation:
(1)  y  =  (a)x + (b)(c) x
     where:
       y  =  overall degreaser emission factor, kg/kg solvent consumed
       a  =  fraction of uncontrolled degreasers
       x  =  uncontrolled degreaser emission factor, kg/kg solvent consumed
       b  =  fraction of controlled degreasers
      - c  =  1 - achievable emission reduction
     Since emission reduction is calculated only for presently uncontrolled
degreasers, the total solvent consumption must be adjusted to include only
the solvent used in uncontrolled degreasers.  The adjusted solvent consump-
tion levels were calculated according to the equation:

(2)  z  =  (s)(t)(u)
     where:
            z  =  total  solvent consumed by uncontrolled degreasers by
                  degreaser type, Mg/yr
            s  =  total  solvent consumption by all  degreasers (fresh solvent
                  plus recycled solvent = total emissions divided by
                  emission factor for fresh TCE), Mg/yr
            t  =  fraction of consumption by degreaser  type
            u  =  fraction of uncontrolled degreasers by degreaser type

     The uncontrolled emission factors were applied to  the total  amount
consumed by uncontrolled sources within each degreaser  type to yield the
national uncontrolled emissions for the degreaser type.  Applying the
control efficiency to the national uncontrolled emissions gives the emission
reduction for the degreaser type.  These calculations proceed according to
the equation:
                                   A-3

-------
(3)  r  =  (z)(x)(v)
     where:
            r  =  emission reduction for degreaser type, Mg/yr
            2  =  total solvent consumed by uncontrolled degreasers by
                  degreaser type, Mg/yr
            x  =  uncontrolled degreaser emission factor (kg/kg solvent
                  consumed)
            v  =  achievable emission reduction

Calculations:

I.   Cold Cleaners
     (1)     y  =  (a)x + (b)(c)x
          0.43  =  (0.65)x + (0.35)(l-0.35)x
             x  =  0.49

     (2)     2  .  (s)(t)(u)
             2  =  /52,600x(Q.05)(0.65)
                   ( 0.79 '
             2  =  2,160 Mg/yr

     (3)     r  =  (z)(x)(v)
             r  =  2,160(0.49)(0.35)
             r  =  370 Mg/yr

II.  Open Top Vapor Degreasers
     (1)     y  =  (a)x + (b)(c)x
          0.78  =  (0.99)x + (0.01)(l-0.44)x
             x  =  0.78

     (2)     2  -  (s)(t)(u)
             2  =  ,52.600^(0.475)(0.99)
                   { 0.79 ;
             2  =  31,600 Mg/yr
                                     A-4

-------
     (3)      r  =  (z)(x)(v)
             r  =  (31,600)(0.78)(0.44)
             r  =  10,900 Mg/yr

III.  Conveyorized Vapor Degreasers
     (1)      y  =  (a)x + (b)(c)x
          0.85  =  (0.95)x +  (0.05)(l-0.57)x
             x  =  0.87

     (2)      z  =  (s)(t)(u)
             z  =  ,52,600.(0.475)(0.95)
                   {  0.79 '
             z  =  30,000 Mg/yr

     (3)      r  =  (z)(x)(v)
             r  =  (30,000)(0.87)(0.57)
             r  =  14,900 Mg/yr
                                   A-5

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A.3  REFERENCES

1.   Telecon.  Murphy, P.  B., Radian Corporation, with Pokorny,  J., Baron-
     Blakeslee, Inc.  August 9, 1985.  Information on degreasing control
     technology.

2.   Telecon.  Murphy, P.  B., Radian Corporation, with Barr,  F., Graymills,
     Corporation.  August  9, 1985.  Information on degreasing control
     technology.
                                    A-6

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                                 APPENDIX B
   METHODS USED FOR ESTIMATING STORAGE TANKS AND EQUIPMENT LEAK EMISSIONS
B.I  EMISSION FACTORS FOR FIXED-ROOF STORAGE TANKS
B.I.I  Emission Equations
     The major types of emissions from fixed-roof storage tanks are breathing
and working losses.  Emission equations for breathing and working Tosses from
storage tanks were developed in EPA Publication No. AP-42.  The equations
used in estimating emissions rates for fixed-roof tanks storing VOL are:

          LT = LB + LW
          LR = 1.02 x 10"5 M  /	P   \°'68 D1-73H0.51T0.5F C|<
           o                v  	                      p  c
                              \14.7-P/
     -    Lw = 1.09 x 10"8 MvPVNKnKc
where,    Lj = total loss (Mg/yr)
          Ln = breathing loss (Mg/yr)
          LW = working loss (Mg/yr)

B.I.2  Parameter Values and Assumptions
     The following C^HCl- physical property values, plant-specific
information, and engineering assumptions were used to estimate the emission
losses:
          M  = molecular weight of product vapor (Ib/lb mole);
               for C2HC13, MV = 131.5
          P  = true vapor pressure of product, function of temperature.
          D  = tank diameter (ft); dependent upon plant-specific information.
          C  =  tank diameter factor (dimensionless):
               for diameter ^ 30 feet, C = 1
               for diameter < 30 feet, C = 0.0771 D - 0.0013(D)2 - 0.1334
          V  = tank capacity (gal); dependent upon plant-specific information
                                   B-l

-------
          N  = number of turnovers per year (dimensionless) ;  dependent upon
               plant-specific information
          T  = average diurnal  temperature change in °F;  plant specific
               information
          F  = paint factor (dimensionless);  the storage  tanks were assumed
               to be in good condition and painted white;  therefore, F  =  1
               (see Table B-l)
          H  = average vapor space height (ft):  used tank-specific values  or
               an assumed value of one-half the  tank height  (H/2)
          K  = product factor (dimensionless)  =  1.0 for VOL
          K  = turnover factor  (dimensionless);  dependent  upon plant-specific
               information
               for turnovers >  36, K  = 180 +  N
                                    n   ~~6H
               for turnovers 4  36, K  = 1

B.I. 3  Sample Calculation
     The following sample calculation is provided to demonstrate the
evaluation of emissions from a  typical fixed-roof storage  tank containing
CpHCl-.  For the general equations,

          Lp - 1*02 xV5 M  /L_\°-68 D  L73 H °'51  T  °'5 F  CKp
           8                V \14.7-Py                          P  C
          Lw » 1.09 x 10'8 Mv PVNKnKc
where,    My = 131.5
           P = 1.50 psia (@ 80°F)
           D = 37 ft
           C = 1
           V = 233,000 gallons
           N = 10
           T = 20°F
          Fp . 1.0
           H = 14 ft
          Kc = 1.0
                                    B-2

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               TABLE B-l.  PAINT FACTORS FOR FIXED-ROOF TANKS
                                                             1
                            Tank Color
                    Paint factors (F )
                     Paint condition
       Roof
     Shell
Good
Poor
White
Aluminum (specular)
White
Aluminum (specular)
White
Aluminum (diffuse)
White
Light gray
Medium gray
     White            1.00     1.15
     White            1.04     1.18
Aluminum (specular)   1.16     1.24
Aluminum (specular)   1.20     1.29
Aluminum (diffuse)    1.30     1.38
Aluminum (diffuse)    1.39     1.46
     Gray             1.30     1.38
   Light gray         1.33     1.44
  Medium gray         1.40     1.58
                                   B-3

-------
the emissions from this storage tank are:

     LB - 1.02 x 1(T5 (131.5)(_JL5_)0.68 (37}L73(14)0-51(20)0-5(1)(1)(1)
                              14.7-1.5
          2.71 Mg/yr
     Lw = 1.09 x 10"8 (131.5)(1.5)(233,000)(10)(1)(1)
        =5.01 Mg/yr
     LT = 2.71 Mg/yr + 5.01 Mg/yr = 7.72 Mg/yr

B.2  EMISSION FACTORS FOR INTERNAL FLOATING ROOF STORAGE TANKS

B.2.1  Emission Equations
     Emissions from internal floating roof tanks can be estimated from the
following equations:   (Note that these equations apply only to freely
vented internal floating roof tanks.)
     -    LT = Lw + Lr + Lf + Ld
where,    Lj = the total loss (Mg/yr)
          LW = the working loss (Mg/yr) = (0.943) Q C HL       JUc-Jlc
                                               D         1 +     D    /2205
where,    D  = tank diameter (ft)
          N  = number of columns (dimensionless); (see Table B-2)
          F  = effective column diameter (ft); 1.0 assumed
          Lr = the rim seal loss (Mg/yr)  = (KpD) P* My Kc/2205
          Lf = the fitting loss (Mg/yr)   = (Ff)  P* My «c/2205
          Ld = the deck seam loss (Mg/yr) = (Fd Krf D2) P* My Kc/2205

B.2.2  Parameter Values and Assumptions
     The assumptions and values used to calculate emissions from internal
floating roof tanks are:

           Q = product average throughput (bbl/yr); tank capacity
               (bbl/turnover) x turnovers/yr;  dependent upon plant-specific
               information
                                   B-4

-------
                                                          3   ?
      C = product withdrawal  shell  clingage factor (bbl/10  f t );  use
          0.0015 bbl/103ft2 for VOL in a welded steel  tank with light
          rust (0.0075 for dense rust)
     WL = density of product (Ib/gal); for C2HC13> 12.3 Ib/gal
      D = tank diameter (ft)
     N  = number of columns (dimensionless); (see Table 8-2)
      C
     F  = effective column diameter (ft); 1.0 assumed
      \f
      D = the tank diameter (ft); dependent upon plant-specific
          information
     M  = the average molecular weight of the product  vapor
          (Ib/lb mole).  For C2HC13, MV = 131.5
     Kp = the product factor (dimensionless) = 1.0 for VOL
   2205 = constant (Ib/Mg)
     P  = the vapor pressure function (dimensionless)
     P* = 0.068 P/((l + (1 - 0.068  P)0'5)2)
     P  = the true vapor pressure of the material  stored (1.5 psia
          for C2HC13)
        = the rim seal loss factor  (Ib mole/ft yr) that for an average
fitting seal  is as follows:

          Seal system description                 j(  (Ib mole/ft yr)
     Vapor-mounted primary seal  only.                     6.7
     Liquid-mounted primary seal only                     3.0
     Vapor-mounted primary seal  plus
      secondary seal                                       2.5
     Liquid-mounted primary seal plus
      secondary seal                                       1.6
     F. = the total deck fitting loss factor (Ib mole/yr)

         = S  (Nf  Kf ) = [(Nf  Kf )  + (Nf  Kf ) + ...+ (Nf  Kf  )]
         i=l    ii         11       22               n  n
                               B-5

-------
          where,    N^ = number of fittings of a  particular type
                      i       (dimensionless).   N-: is determined for the
                         specific  tank or estimated from Tables B-2 and B-3.
                         The values used for these emissions  estimates  are
                         designated by * in Table B-3.
                    K.p = deck fitting loss factor for a  particular type
                      i   fitting (Ib mole/yr).   K. is determined for each
                         fitting type from Table  B-3. The values  used  for
                         these emissions estimates are designated  by *.
                    n  = number of different types of fittings
                         (dimensionless)
                    Fd = the deck  seam length  factor (ft/ft2)
                       = 0.15, for a deck constructed from continuous metal
                         sheets with a 7 ft spacing between seams
                       = 0.33, for a deck constructed from rectangular  panels
                         5 ft by 7.5 ft
                       = 0.20, an  approximate  value for  use when no
                         construction details  are known
                    K. = the deck  seam loss factor (Ib mole/ft  yr)
                       = 0.34 for  nonwelded roofs
                       = 0 for welded decks
B.2.3  Sample Calculation
     The following sample calculation is provided to demonstrate the
evaluation of emissions from a typical storage tank with an internal floating
roof containing C^HCl    For the general equations,

          LT ' LW + Lr + Lf + Ld
             = (0.943)QCW
! + ^1/2205
                                     J
             = (KrD) P* Mv Kc/2205
                                    B-6

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TABLE B-2.   TYPICAL NUMBER OF COLUMNS AS A FUNCTION  OF TANK DIAMETERS

Tank
Greater
Than
0
85
100
120
135
150
170
190
220
235
270
275
290
330
360
Diameter Range
D (Ft)
Less Than
And Or Equal To
85
100
120
135
150
170
190
220
235
270
275
290
330
360
400
Typical Number
Columns, N
1
6
7
8
9
16
19
22
31
37
43
49
61
71
81
                                B-7

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           TABLE B-3.  SUMMARY OF DECK FITTING LOSS FACTORS (K-) AND
                       TYPICAL NUMBER OF FITTINGS (Nf)        T


1.



2.



3.










4.


5.


6.






7.

8.




Deck Fitting Type
Access Hatch
A. Bolted cover, gasketed
B. Unbolted cover, gasketed
C. Unbolted cover, ungasketed
Automatic Gauge Float Well
A. Bolted cover, gasketed
B. Unbolted cover, gasketed
C. Unbolted cover, ungasketed
Column Well
A. Built-up column-sliding cover,
gasketed
B. Built-up column-sliding cover,
ungasketed
C. Pipe column-flexible fabric
sleeve seal
D. Pipe column-sliding fabric
gasketed
E. Pipe column-sliding cover,
ungasketed
Ladder Well
A. Sliding cover, gasketed
B. Sliding cover, ungasketed
Roof Leg or Hanger Well
A. Adjustable
B. Fixed
Sample Pipe or Well
A. Slotted pipe-sliding cover,
gasketed
B. Slotted pipe-sliding cover,
ungasketed
C. Sample well-slit fabric seal,
10% open area
Stub Drain, 1-inch diameter

Vacuum Breaker
A. Weighted mechanical actuation,
gasketed
B. Weighted mechanical actuation,
ungasketed
Deck
Fitting Loss Typical Number
Factor, Kf Of Fittings
(Ib mole/yr) (Nf)

1.6 1
11 *
25

5.1 1
15 *
28
(see Table B-2)
33

47

10

19 *

32

1
56 *
76
2a
7.9 * (5 + D + D ^
0 ( 10 600'
1
44 *

57

12
?
1.2 * , DS b
(T25}
1
0.7 *

0.9

  Not used on welded, contact internal  floating  decks.
b D= tank diameter (ft).
                                      B-8

-------
          Lf = (Ff) P* My Kc/2205






          LD = (W2) P* Mv Kc/2205
where,    My = 131.5 Ib/lb mole
          P* = 0.0268





          Q  = 500,000 bbl/yr





          C  = 0.0015





          WL = 12.3 Ib/gal





          D  = 30 ft
          Nc-l
          FC = i.o
          Kr = 6.7 Ib mole/ft yr
          KC = i.o
          Ff = 242 Ib mole yr
          Fd = 0.20
          Kd-0
                                     B-9

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the emissions from this storage tank are:

          Lu = (0.943)(500.000)(0.0015) (12.3)          (
                            30                    (1 +   3Q  )  /2205
             = 0.136 Mg/yr

          Lp = ((6.7)(30))(0.0268)(131.5)(1.0)/2205

             = 0.321 Mg/yr

          Lf = (242)(0.0268)(131.5)(1.0)/2205

             = 0.387 Mg/yr

          LD = ((0.20)(0.34)(30)2)(0.0268)(131.5)(1.0)/2205

             = 0.0978 Mg/yr

          LT = 0.136 Mg/yr + 0.321 Mg/yr + 0.387 Mg/yr + 0.0978 Mg/yr

          Ly = 0.94 Mg/yr

B.3  EQUIPMENT LEAK EMISSIONS - SAMPLE CALCULATIONS

     Emissions were estimated from the number of equipment leak sources
(provided by the plant), the percentage of CpHCI- in the stream (provided by
the plant), and the emission factors for each type of equipment (from the
           p
SOCMI AID).   The following sample calculations illustrate the  procedure.
Emissions
Source
Pump seals



% C0HC1,
Number
3
6
2
12
Mg/yr source , Total Emissions
Service Emission Factor
X
X
X
X
7.5
50.5
87.5
100.0
X
X
X
X
0.043
0.043
0.043
0.043
Mg/yr
0.097
1.3
0.75
5.2
                                    B-10

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Emissions
  Source

Compressors

Flanges
Valves (gas)
Pressure Relief
 Devices (gas)
Sampling
 Connections
Number

   1

   4
 112
  30
 235
  66
 456
   4
   8
   3
   4
  11

   2
   4
   6

   5
   3
   1
   3
Service
 87.5
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
5.0
7.5
18.0
50.5
87.5
100.0
5.0
7.5
50.5
87.5
100.0
5.0
50.5
100.0
5.0
50.5
87.5
100.0
          X
          X
          X
          X
          X
          X


          X
          X
          X
          X
          X


          X
          X
          X


          X
          X
          X
          X
  Mg/yr source .
Emission Factor0

      2.0

      0.01
      0.01
      0.01
      0.01
      0.01
      0.01

      0.05
      0.05
                                                ,05
                                                ,05
Open Ended Lines    1    x  100.0
      0.05

      0.91
      0.91
      0.91

      0.13
      0.13
      0.13
      0.13

      0.015

    TOTAL
Total Emissions
     Mq/yr

      1.8

      0.002
      0.084
      0.054
      1.2
      0.58
      4.56
      0.01
      0.030
       .976
       ,18
                           0.
                           0.
      0.55

      0.091
      1.8
      5.5

      0.033
      0.20
      0.11
      0.39

      0.015

     24.6
Annual Emissions = 24.6 Mg/yr
 U. S. Environmental Protection Agency.   Fugitive Emission Sources of Organic
 Compounds - Additional Information on Emissions, Emission Reductions, and
 Costs.  Research Triangle Park, NC.  Publication No.  EPA-450/3-82-010.
 April 1982.
                                    B-ll

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B.4  REFERENCES

1.   U. S. Environmental  Protection Agency.  VOC Emissions from Volatile
     Organic Liquid Storage Tanks - Background Information for Proposed
     Standards.  Research Triangle Park, North Carolina.  Publication
     No. EPA-450/3-81-003a.  July 1984.  252 pp.

2.   U.S. Environmental Protection Agency.  Fugitive Emission Sources of
     Organic Compounds -  Additional Information on Emissions, Emission
     Reductions, and Costs.  Research Triangle Park, N.C.  Publication No.
     EPA-450/3-82-010.  April 1982.
                                    B-12

-------
                                 APPENDIX C
                METHODS FOR ESTIMATING EMISSION CONTROL COSTS

C.I  PROCESS VENT EMISSIONS CONTROL COST ESTIMATION

     The cost estimates for process vent emission control  are based on the
use of thermal incineration.  The procedure for estimating these costs uses
the methods presented in the Air Oxidation Processes Control  Techniques
Guidelines (CTG) document.    A detailed discussion of the  incinerator
costing methods may be found in Chapter 5 of this document.  It should be
noted that these incinerator costing procedures are designed  for vent
streams having high flowrates.  Since the vent streams containing TCE
generally have lower flowrates, the cost estimates for process vent emission
control may be somewhat overstated.  Further work will be  performed to
develop incinerator costing procedures for lower flowrate  vent streams if
regulatory development proceeds.
     The total installed capital cost of control  is determined using the
following equation:

Total Installed Capital Cost (10 $) = (# of incinerators)  x (escalation
factor) x (Cl - (Waste Heat Boiler Correction Factor)  + (C2 x (Flowrate per
incinerator * Design Vent Size Factor)  ) + (pipe rack cost)  + (additional
ductwork cost)
where:    Cl, C2, and C3 are coefficients from Table C-l that depend upon
          heating value and halogenation status of a given vent stream;
          waste heat boiler correction factor of 40 (10 $) is used for vent
          streams with flowrates below 700 scfm, where no  heat recovery in a
          waste heat boiler is assumed; escalation factor  of  0.90 escalates
          costs to 1978 dollars;
          design vent size  factor of 0.95 increases vent stream flowrate for
          costing purposes;
          pipe rack cost is calculated using the equation  presented in
          Table C-2;
          additional ductwork cost is calculated using the equation
          presented in Table C-3.
                                    C-l

-------
          TABLE C-l.   TOTAL INSTALLED CAPITAL COST AS A FUNCTION
                         OF VENT STREAM FLOW RATE

Category
Ala
A2a
B
C
D
Ea
Maximum
Flowrate
Ber Unit
(10 scm/min)
0
0
1
1
1
1
.74
.74
.42
.42
.25
.25
Minimum
Net
Heating
Value
(MJ/scm)
0.0
3.5
0.0
0.48
1.9
3.6
Maximum
Net
Heating
Value
(MJ/scm)
3.5
-
0.48
1.9
3.6
-
Fabricated
Equipment
Cost
Escalation
Factor
0.90
0.90
0.90
0.90
0.90
0.90
Cl
803.
786.
259.
297.
236.
236.

11
61
88
99
35
35
C2
12.
12.
4.
2.
3.
3.

83
44
91
84
23
23
C3
0.
0.
0.
0.
0.
0.

88
88
88
88
88
88
Halogenated vent stream.

Dilution flow rate is used in capital  cost equation.
Dilution flow rate = (design flow rate) x (original  heating value) r
(3.65 MJ/scm).

-------
                     TABLE C-2.  ADDITIONAL DUCT COST1'2
Additional duct cost (10  $) = (length) x (cost per unit length) x
(installation factor) x (duct escalation factor) * 1000
Cost per unit length = 1.37L - 1.76
     where L = duct diameter in inches
Dl-,mptpr = r    Flow rate (ft3/min)     4 , i
Diameter - L Linear velocity (ft/min) x 7 j
           r Flow rate (ft3/min)     4    -, 0.5
           L     2000 ft/min     x 3.1412 J
           if linear velocity is assumed to be 2000 ft/min
Additional duct length = 150 ft + (additional  vents x 100 ft/vent)
Installation factor = 1.087
Escalation factor (from 1977 to 1978) = 1.088
                                    C-3

-------
                        TABLE C-3.   PIPE RACK COST1'2
Pipe rack cost (10  $)  = (pipe rack length)  x  (cost per unit  length)  x
                         (installation factor)  x  (pipe  rack deescalation
                         factor)  * 1000
Pipe rack length = 250 ft + (# additional  vents  x 100 ft/vent)
Cost per unit length = $32.045/ft
Installation factor = 1.087
Escalation factor (1982 to 1978)  = 0.746
                                    C-4

-------
























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-------
     A sample calculation for incinerator costing is shown in Table C-6.
The calculation is based on vent stream parameters obtained from the Stauffer
Chemical Company (Le Moyne, Alabama) Section 114 letter response.  The cost
estimate was initially calculated in 1978 dollars and then was updated to
1984 dollars using the annualized cost escalation factor shown in Table C-7.

C.2  COST CALCULATIONS FOR INSTALLING INTERNAL FLOATING ROOFS IN
     FIXED ROOF TANKS

     The following equations were used to calculate the capital  and
annualized cost for the installation of a mild steel welded contact internal
floating roof to a fixed roof storge tank.  This internal  floating roof
                                            n
utilizes both primary (constructed of Teflon ) and secondary (constructed of
VitonR) seals.

C.2.1  Capital  Cost (4th Quarter 1982 Dollars)
                       4
     1.  Degassing Cost

     Cost = $130.8 v°-5132 or $1,000, whichever is greater where V = tank
     volume in cubic meters.
                                    4
     2.  Estimated Installation Cost

         a.  Basic cost of roof and primary seal:
             Cost = (1.91 + 2.54 x D) x $1,000 + ($204 x D)
             D = tank diameter in meters
                                                                    D
     (The $204 x D cost reflects the additional  cost of using Teflon  coated
     fiberglass to protect against TCE attack versus the standard
     polyurethane coating.)
                                    C-7

-------
        TABLE C-6.  SAMPLE CALCULATION FOR INCINERATOR COSTING
1. Capital Cost (10* $)
2. Additional  Duct Cost (10  $)
                                                                      ,0.88.
(# incinerators) x (incinerator capital
cost per unit) x (escalation factor)
(# incinerators) x (803.11 - 40.0 +
12.83 x (flow/0.95)0'88) x escalation
factor
1 x (803.11 - 40.0 + 12.83 (14.2)(
x 0.9
806.1

(length) x (cost per unit length) x
(escalation factor) x (installation
factor) = 350 ft. x (((500 ft3/min
x 4 T 2000 r 3.1412))0'5 x 12 x
1.37 - 1.76) x 1.088 x 1.087 * 1000
3.111
3. Pipe Rack Cost (10J $)
(length) x (cost per unit length) x
(installation factor) x (pipe rack
deescalation factor) x (retrofit
correction factor) * 1000 = 250 ft. +
(# additional vents x 100 ft./vent) x
$32.045/ft. x 1.087 x 0.746 x * 1000
11.693
4. Total Installed Total Capital    = Capital  cost (10  $) + extra duct
                                      cost (103 $) + pipe rack cost (103 S)
                                    = 806.1 + 3.111 + 11.693
                                    = 820.9
                              (continued)
                                    C-8

-------
                         TABLE C-6.   (Continued)
 5.  Natural  Gas Use (MJ/yr)
= (minutes per year) x (supplemental
  gas required per minute)
= 0.5256 106 min/yr x GQ + flow x
  (G1 + G2 x HT)
= 0.5256 106 min/yr x (3.96) x (4.53
  0.985 x 1.49) MJ/min)
=6.37 MJ/yr
 6.  Natural  Gas Cost (10  $)
= Natural gas price ($/10  J) x
  natural gas use (MJ/yr)
= S4.16/GJ x 6.37 MJ
= 26.2
 7.  Operating Labor Cost (10  $)      =  Wage  ($/hr)  x  labor  factor  (hr/yr)  r
                                       1000
                                     =  $8.50/hr  x  2400  hrs
                                     =  20.4

 8.  Supervisory Labor Cost (103  $)    =  Operating labor  cost (10  /yr)  x  0.15
                                     =  20.4  (103 $/yr)  x  0.15
                                     =  3.06
 9.  Maintenance Labor Cost (10  $)
= Installed capital  cost (10  $) x 0.03
= 820.9 (103) $ x 0.03
= 24.63
10.  Overhead Labor Cost (10J  $)
= Operating labor cost (10  $) +
  supervisory labor cost (10  $) +
  maintenance labor cost (10  $) x 0.80
= (20.40 + 3.06 + 24.63) x 0.80
= 38.47
                               (continued)
                                   C-9

-------
                         TABLE C-6.   (Continued)
11. Total  Labor Cost (ICr $)
= Operating labor cost (10  $) +
                            •5
  supervisory labor cost (10  $) +
  maintenance labor cost (10  $) +
  overhead labor cost (10  $)
= 20.4 + 3.06 + 24.63 + 38.47
= 86.56
12.  Electricity Cost (103 $)
13. Quench Water Cost (104 S)
= (electricity price) x (pressure drop)
  x (flow rate) x (flue gas:offgas
  ratio) x (fan equation conversion
  factor) x (# of hours per year) * fan
  efficiency * 1000
= 0.0279 ($/KWhr) x 22 in.  x 3.96 son/
  min x 2.9 x 0.004136 (KW/scmin.) *
  0.6 * 1000 (S/103 $)
= 0.426

= (quench water price) x (flow rate) x
  (flue gas:offgas ratio) x (water
  required per unit flow) x (minutes
  per year) * 1000
= 0.22 ($ 103 gal) x 3.96 (scm/min) x
  2.9 x 1.68 x 10"5 (103 gal/scm) x
                                       0.5256 (106  min/yr)
                                     = 0.0223
                        1000 ($/10J $)
                                 (continued)
                                   C-10

-------
                         TABLE C-6.   (Continued)
14.  Scrubbing Water Cost (1CT $)
= (scrub water price) x (flow rate) x
  (flue gasroffgas ratio)  x (chlorine
  content of flue gas) x (water
  required per unit chlorine) x (# of
  hours per year)
= 0.22 ($103 gal) x 3.96 (scm/min) x
  35.314 scf/scm x 2.9 x 0.0487
  (Ib/hr chlorine)/(scf/min flue gas) x
  0.0192 (103 gal/lb chlorine) x 8760
  (hr/yr) * 1000
= 0.73
15.  Neutralization Cost (10  $)
= (caustic cost) x (flow rate) x (flue
  gas:offgas ratio) x (chlorine
  content of flue gas) x (caustic
  requirement per unit chlorine) x
  (# of hours per year) * 1000
= 0.0436 ($/lb NaOH) x 3.96 (scm/min)  x
  35.314 scf/scm x 2.9 x 0.0487 (Ib/hr
  chlorine)/(scf/min flue gas) x 1.14
  (Ib NaOH/lb chlorine) x 8760 (hr/yr)
  1000 $/103 $
= 8.6
16. Heat Recovery Credit
= 0 (for all  streams <700 scfm)
                                 (continued)
                                   Oil

-------
                         TABLE C-6.   (Continued)
17. Taxes, Insurance, and
    Maintenance Cost (103 $)
  (installed capital cost) x (taxes,
  insurance, and administrative
  charges factor + maintenance labor
  factor)
  820.9 (103 $) x (0.04 + 0.03)
  57.46
18. Annual  Operating Cost (10  $)
  (TI&M cost) + (gas cost) + total
  labor cost) + (electricity cost) +
  (quench cost) + (scrubbing cost) +
  (scrubbing cost) + (caustic cost)
  57.46 + 26.20 + 86.56 + 0.426 +
  0.0223 + 0.73 + 8.6
  180.00
19. Annualized Cost (10  S)
  (operating cost) + (capital  recovery
  factor x total  installed capital
  cost)
  180.0 + (.163 x 820.9)
  313.8
20. Annual Emissions (Mg/yr)
  (hourly emissions) x 365 (days/yr) x
  24 (hrs/day)  x (Mg/103 kg)
  15.86 kg/hr x 365 (days/yr) x
  24 (hrs/day)  x 1 (Mg/103 kg)
  138.9
21. Annual Emission Reduction
    (Mg/yr)
= (annual  emissions) x 0.98
= 138.9 x  0.98 (C2HC13) = 136.1
= 349.6 (VOC)
                                 (continued)
                                     C-12

-------
                         TABLE C-6.  (Continued)
22. Cost Effectiveness ($/Mg)
23. Updated Cost-Effectiveness
    Values ($/Mg)
= (annual cost) * (annual emission
  reduction)
= 313.8 (103 $) T 136.1 Mg (C2HC13)
= 2305/Mg (C2HC13)
= 313.8 (103 $) v 349.6 Mg (VOC)
= 898/Mg

= 2305 ($/Mg) x 1.486 = $3420/Mg ( C..HC1.,)
                                    c   o
= 898 ($/Mg) x 1.486 = $1330/Mg (VOC)
                                     C-13

-------
TABLE C-7.  COST CONVERSION FACTORS FOR INCINERATOR COMPONENTS
Original
Cost Component
Incinerator
Pipe Rack
Duct Work
Annual ized Costs
Original
Year
1979
1982
1977
1978
Conversion
Year
1978
1978
1978
1984
Factor
0.900
0.745
1.088
1.486
                              C-14

-------
                                                      4
         b.  Additional cost of adding secondary seal:

             Cost = $580 x D
                                              D
     (The $580 x D cost reflects using a Viton  coating material  for the
     secondary seal)

     3.  Door Sheet Opening Cost

         Cost = $1,300

     Total capital cost (primary seal) = degassing cost + estimated
installed cost (2a) + door sheet opening cost.

     Total capital cost (primary + secondary seals) = degassing costs +
estimated installed cost (2a,b) + door sheet opening cost.

C.2.2  Annual Cost (4th Quarter 1982 Dollars)

     1.  Taxes, insurance, and administration — 4% of capital  cost (based
         on 10 percent interest rate and 10 year equipment  life)

     2.  Maintenance — 5% of capital  cost

     3.  Inspection — 1% of capital cost

     4.  Capital recovery factor — 16.275% of capital cost

     Total annual cost = [26.275% of capital cost]

C.2.3  C2HC13/VOC Reduction

     1.   Emissions calculated for fixed roof tanks using AP-42 formulas.
                                   C-15

-------
     2.   Emissions calculated for internal floating roof tanks using AP-42
          formulas.
          a.   Liquid mounted primary seal only
          b.   Liquid primary and secondary seal

     3.   Emissions from fixed roof tank - emissions from internal  floating
          roof tank = VOC emission reduction

                 emission reduction = VOC emission reduction x percentage of
                 in stored material

C.2.4  Recovery Credits (4th Quarter 1984 Dollars)

     Credits = (TCE emission reduction) x (4th Quarter 1984 TCE market value
               ($440/Mg) + [(TCE emission reduction - VOC emission  reduction)
                x (4th Quarter 1984 VOC market value ($330/Mg))]

C.2.5  Net Annual Cost

     Before annual cost can be calculated, all costing data is converted to
     1984 dollars using Chemical Engineering Economic Indicators)

     Cost = annual cost (4th quarter 1984 dollars) - VOC recovery credits
               (4th Quarter 1984 dollars)

C.2.6  Cost Effectiveness

     CpHCl- cost effectiveness = net annual cost/CpHCK emission reduction (Mg)

     VOC cost effectiveness = net annual cost/VOC emission reduction (Mg)
                                    C-16

-------
C.3  COST CALCULATIONS FOR INSTALLATION OF REFRIGERATED CONDENSERS TO
     CONTROL LOADING AND STORAGE EMISSIONS

     Cost estimates were developed for controlling handling and storage
emissions at trichloroethylene production facilities based on refrigeration
vapor recovery systems.  A diagram of such a system is presented in
Figure C-l.  Cost information was obtained from the EPA publication "Capital
                                                               2
and Operating Costs of Selected Air Pollution Control  Systems."
     The vapor recovery system cost is based on the flow rate of air through
the device.  Using the Dow/Freeport handling operations information as the
model, a sample calculation is presented below.
       -  Maximum flow rate = 110 cfm.  From Figure 5-26 of Reference C-l,
          the December 1977 capital cost for the refrigerated vapor recovery
          unit (which includes a complete skid mounted package containing
          the refrigeration unit, a brine storage tank, two condensing
          units, pumps, valves, and controls), was estimated to be $63,700.

       -  Stainless steel fixtures were included to prevent corrosion at an
          additional cost of 130 percent of the capital cost.  The cost of
          taxes, freight, and installation was estimated to be an additional
          75 percent of the cost.

       -  Capital cost of the unit updated to November 84 is $63,700 x 2.3 x
          1.74 x (335.4) = $380,200.
                  "2627?
       -  CE cost index for fabricated equipment:  November 1984 = 335.4,
          December 1977 = 226.2.

       -  Operating labor cost was calculated as $15/hr x 180 hr = $2700/yr.

       -  Maintenance costs were calculated as 5 percent of the updated
          capital cost.  0.05 x $380,200 = $19,000/yr.
                                    C-17

-------
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                                                                           CD
                                              C-18

-------
-  Electricity requirements were also based on Figure 5-26 of
   Reference B-l.   Power requirements include brine pumps,
   compressor, condenser fan, controls, and instrumentation.   With a
   utilization factor of 1.9 percent for Dow/Freeport's handling
   operations, November 1984 costs were estimated as 50 kW x  0.019 x
   8,760 hr_ x $0.0506/kw-hr = $420/yr.   An additional 20 percent was
         yr
   added to this to include electricity costs for the fan/blower and
   the produce recovery pump.  Total electrical  costs are estimated
   to be $420/yr x 1.2 = $500/yr.

-  Capital  charges were estimated as 22 percent  of the updated
   capital  cost of the system 0.22 x $390,200 =  $83,600.  These
   charges  include yearly taxes, insurance, administration, etc.

-  The annual cost of the system was calculated  as the sum of the
   following costs:  operating, labor,  maintenance, electricity, and
   capital  charges.  $2,700 + 19,000 +  500 + 83,600 = $105,800/yr.

-  A recovery credit of $440/Mg TCE recovered was applied to  the
   annual cost of the system.  A TCE emission reduction efficiency
   for the  unit was based on the vapor  pressure  of TCE at the inlet
   conditions (27°C, 1.54 psia) and at  the outlet conditions  (-79°C,
   0.0172 psia) and was estimated to be 90 percent for loading
   applications and 85 percent for storage tank  applications.
   Recovery credit = $440/Mg x (10 Mg TCE inlet  *90 percent removal)
   = $4,000/yr.

-  Total annualized cost = $105,800 - $4,000 = $101,800.

-  The total annualized cost for operating the system was calculated
   as (0.16275 x $380,200) + $101,800 = $165,600/yr.
                            C-19

-------
       -  The cost effectiveness of the system was calculated as
          ($163,700/yr)/(10 Mg x .90) = $18,200/Mg.

C.4  SAMPLE CALCULATIONS FOR EQUIPMENT LEAK CONTROL  COSTS

     To calculate the cost for the implementation of technologies to control
equipment leak emissions, the specific control techniques,  removal  efficien-
cies and capital/annualized costs per component are  given in Table C-8.   The
equipment leak emission sources costed are pump seals, compressors, flanges,
valves, pressure relief devices, sample connectors,  and open ended lines.

Capital cost per emission source:  (No. of components) x (capital cost per
component)

Total capital cost per plant:  £ [capital  cost per emission source] annual
cost per emission source:  (No. of components) x (annual cost per component)
CoHCl. emission reduction per emission source:   (current C^HCl- emission)  x
(percent reduction)

Total C2HC13 emission reduction per plant:   l [C,,HC13 emission reduction per
emission source]

VOC emission reduction per emission source:   (current VOC emission)  x
(percent reduction)

Total VOC emission reduction per plant:  z  [VOC emission reduction per
emission source]

Recovery credit per emission source:  (TCE  emission reduction for source i)
x  (4th Quarter 1984 TCE makret value ($440/Mg)  + [(TCE emission reduction
for source i - VOC emission reduction for source i) x (4th Quarter 1984 VOC
market value ($330/Mg)].
                                     C-20

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          TABLE C-8.   CONTROL TECHNIQUES  AND COST FOR  CONTROLLING
                      EQUIPMENT LEAK EMISSION SOURCES3
                        (4th Quarter 1984 Dollars)

Equipment Type
(Emission Source)
1.




2.

3.
4.


5.



6.




7.


Pump seals
- Packed
- Mechanical
- Double
Mechanical
Compressors

Flanges
Valves
- Gas
- Liquid
Pressure Relief
devices
- Gas
- Liquid
Percent 5
Control Techniques Reduction

Monthly LDAR
Monthly LDAR
N/A

Vent to combustion
device
None Available

Monthly LDAR
Monthly LDAR


0-Ring
N/A

61
61
N/A

100

N/A

73
59


100
N/A
Capital6
Cost
S/Component

0
0
N/A

10,200

N/A

0
0


310
N/A
Annual ized
Cost
$/Component

370
370
N/A

2,580

N/A

20
20


80
N/A
Sample Connections
- Gas

- Liquid

Open Ended Lines
- Gas
- Liquid
Closed-purge sampling
systems
Closed-purge sampling
systems

Caps on open ends
Caps on open ends
100

100


100
100
670

670


70
70
170

170


20
20
Updated to 4th quarter 1984 using  CE  index.
                                   C-21

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Recovery credit per plant:   E [Recovery credit per emission source]
Net annual cost (CpHCK) per emission source:   (annual  cost per emission
source) minus (recovery credits per emission source).

Net annual cost (C2HC13) per plant:  (total  annual  cost per plant)  minus
(total recovery credits per plant).

Net annual cost (VOC) per emission source:   (annual  cost per emission
source) minus (recovery credits per emission source).

Net annual cost (VOC) per plant:   (total  annual  cost per plant) minus  (total
recovery credits per plant).
Cost effectiveness for controlling C^HCl^ emissions  per emission source:
(net annual cost (C^HCl^) per emission source)  * (CpHCK emission reduction
per emission source).

Cost effectiveness for controlling CpHCl- emissions  per plant:   (net annual
cost (CpHCl,) per plant) * ^HCl- emission reduction per plant).

Cost effectiveness for controlling VOC emissions per emission source:   (net
annual cost (VOC) per emission source) * (emission reduction per emission
source).

Cost effectiveness for controlling VOC emissions per plant:   (net annual
cost (VOC) per plant) T (emission reduction per plant).
                                    C-22

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C.5  REFERENCES

1.   U.S. Environmental Protection Agency.  Control of Volatile Organic
     Compound Emissions from Air Oxidation Processes in Synthetic Organic
     Chemical Manufacturing Industry.  Research Triangle Park, N.C.
     Publication No. EPA-450/3-84-015.  December 1984.  p. 510.

2.   Memo from Pandullo, R. F. and I. A. McKenzie, Radian Corporation, to
     Air Oxidation Processes and Distillation Operations Project Filtes.
     May 3, 1985.  20p.  Revision to the Incinerator Costing Procedures Used
     for the Proposed Air Oxidation and Distillation NSPS.

3.   Neveril, R. B. (CARD, Inc.).  Capital and Operating Costs of Selected
     Air Pollution Control Systems.  (Prepared for the U.S. Environmental
     Protection Agency.)  Research Triangle Park, N.C.  Publication No.
     EPA-450/5-80-002.  December 1978.  pp. 5-65 through 5-71.

4.   Atkinson, R. D. (MRI) et al.  Source Assessment of Ethylene Dichloride
     Emissions.  (Prepared for the U.S. Environmental Protection Agency.)
     Research Triangle Park, N.C.  EPA Contract No. 68-02-3817.  September
     1984.

5.   U.S. Environmental Protection Agency.  Fugitive Emission Sources of
     Organic Compounds - Additional Information Document.  Research Triangle
     Park, N.C.  Publication No. EPA-450/3-82-010.  April 1982.  p. 1-4.

6.   U.S. Environmental Protection Agency.  Benzene Fugitive Emissions -
     Background Information for Promulgated Standards.  Research Triangle
     Park, N.C.  Publication No. EPA-450/3-80-032b.  June 1982.  Appendix A.
                                   C-23

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D.I  EXISTING STATE REGULATIONS

0.1.1  Introduction
     Trichloroethylene emissions originate from several industrial  sources.
These sources include producers of C2HC13> sources that use C^HCU  as a
chemical intermediate, and sources that store C^HCl.,.  These emissions can
be characterized as either process, fugitive, or product storage tank
emissions.
     There are a number of different regulations at the State level  that
limit £0^3 emissions.  CpHCl- emissions in nonattainment areas (areas that
have not achieved the ambient air quality standards for ozone) are  normally
controlled by the States'  RACT program.  C^HCl- emissions in areas  designated
as attainment or unclassified for ozone are controlled by Prevention of
Significant Deterioration  (PSD) regulations.  In addition to the RACT and
PSD programs, 12 States (including the District of Columbia) have general
VOC regulations that limit emissions of photochemically reactive compounds.

D.I.2  General State VOC Regulations for Solvent Use
     Table D-l presents a  list of the States that have adopted a general  VOC
solvent usage regulation and the emission limits established by each State.
These regulations affect volatile organic solvents found to be photochemically
reactive and usually require 85 percent reduction in VOC emissions.   Sources
emitting C2HC1- are currently covered by these regulations.

D.I.3  Prevention of Significant Deterioration Regulations
     PSD regulations control VOC emissions from major sources in areas
classified as attainment for ozone.  Under PSD regulations, a chemical
production plant must seek a PSD permit if it is:  (1) a new source  and
emissions or potential emissions are considered major (100 tons/yr); (2)  a
major increase in emissions or potential emissions (100 tons/yr) at  an
existing minor source; or  (3) a significant increase in emissions or
potential emissions (40 tons VOC/yr) at an existing major source.  Emission
control levels for PSD are established during the State's review of  the PSD
permit application prepared for the emission source.
                                         D-l

-------
    TABLE D-l.  GENERAL STATE VOC REGULATIONS FOR PHOTOCHEMICAL SOLVENTS
    State                                        Emission Reduction

California                                               85
Colorado                                                 85
Connecticut                                              85
District of Columbia                                     85
Illinois                                                 85
Indiana                                                  85
Louisiana                                                90
Maryland                           .                      851
North Carolina                                           85
North Dakota                                             85
Rhode Island                                             852
Virginia                                                 85

 Applies to sources in nonattainment  areas only.
p
 Applies to sources emitting less than 100 tons/year,  larger sources  must
 comply with RACT.
                                  D-2

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D.I. 4  State Regulations Affecting Chemical  Production
     In addition to the general discussion of State regulations concerning
 o- emission sources, a more indepth review was performed for States  in
which CpHCU production facilities are located.   These findings are
presented in Table D-2.  Other VOC emissions at  these facilities may also be
controlled.

D.2  EXISTING FEDERAL REGULATIONS

     Several VOC NSPS and a NESHAP have been developed that could affect new
and some existing sources of C^HCl- emissions.   A summary and the current
status of each of these standards are presented  in Table D-3.
                                  D-3

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   TABLE D-2.  STATE REGULATIONS AFFECTING CHEMICAL PRODUCTION FACILITIES
  State
          Source
         Regulation
Kansas
Louisiana
         1
No regulations for control of
VOC emissions from chemical
production facilities

Storage tanks >40,000 gal
Vapor pressure £ll.O psia
and >_1.5 psia.
                Storage tanks >250 gal
                <_40,000 gal

                VOC loading facilities
                servicing tanks, trucks or
                trailers having a capacity of
                >200 gal & throughput
                >_20,000 gal/day (40,000 gal/
                day for existing facilities)

                Pumps, compressors, valves,
                etc. (>^1.5 psia vapor
                pressure compounds)
- Pressure tank or
- An internal floating roof
  with a closure seal & sub-
  merged fill pipe
- An external floating roof
  with secondary seal and
  submerged fill pipe
- A vapor loss control system
  & submerged fill pipe

- Submerged fill pipe with
  vapor recovery system

- Vapor collection & disposal
  system
                              Equipped with mechanical
                              seals & maintained to
                              prevent leaks
                Waste gas disposal containing Halogenated hydrocarbons
                organic compounds from any    shall  be burned & the
                emission source including
                process unit upsets, start-
                ups and shutdowns.
                              products of combustion
                              subsequently controlled.
                              Other methods such as carbon
                              adsorption, refrigeration,
                              catalytic/thermal reaction
                              can be substituted.  Pro-
                              visions may be waived if gas
                              stream <100 T/yr, will not
                              support combustion without
                              auxiliary fuel, or control
                              will cause economic hardship
                                      D-A

-------
                           TABLE D-2.  (Continued)
  State
         Source
         Regulation
Louisiana
(cont.)
Illinois'
Texas'
Facility emitting >1.4 kg/hr
or 6.8 kg/day of VOC
Storage tanks >40,QOO
gallons
                VOC loading facilities
                servicing tanks, trucks
                or trailers having capacity
                of >250 gal and throughput
                >40,000 gal/day.
Storage tanks vapor
pressure >_1.5 psia,
                                        psia
                  _<1000 gal
                  >1000 gal  <25,000 gal
                  >25,000 gaT >42,000 gal
- Must reduce emissions
  either by incineration
  (90% removal  efficiency)
  or by carbon  adsorption
  system.  During process
  upsets, start-ups, or shut
  downs, VOC emissions must
  be vented and reduced
  either by an  afterburner,
  carbon adsorption system,
  refrigeration, catalytic
  and/or thermal reduction,
  secondary steam stripping,
  or vapor recovery system.

- Pressure tank or
- Floating roof
- Vapor recovery system with
  85 percent recovery
- Equipment or  means of equal
  efficiency

- Submerged loading or
- Equivalent control
                                None
                                Submerged fill pipe
                                Internal  or external
                                floating  roof with primary
                                & secondary seal,  or  vapor
                                recovery  system
                VOC loading and unloading     Vapor recovery system
                (facilities with >20,000 gal/
                day throughput of _>1.5 psia VOC)
                                     D-5

-------
                           TABLE D-2.   (Continued)
  State
          Source
          Regulation
Texas (cont.)
Vent gas control  (^0.4 psia
and emissions >100 Ibs/
24hr or >250 Ib/hr averaged
over 24 hours)

SOCMI Fugitive VOC
(Harris County)
                Storage tanks containing
                vinyl chloride
Flared or incinerated at
1300°F
No compound shall be allowed
to leak with a VOC concentra-
tion >10,000 ppm (time
limits given)

Concentration of exhaust
gases discharged to the
atmosphere from storage
tanks must not exceed 10 ppm
(NESHAP - Vinyl Chloride)
1
 Environment Reporter, State Air Laws.
 Affairs.
                        Washington,  D.C.   Bureau of National
                                     D-6

-------
            TABLE D-3.  SUMMARY OF FEDERAL REGULATIONS AFFECTING
                        TRICHLOROETHYLENE EMITTING SOURCES
         Source
Proposed
Promulgated
SOCMI Equipment Leaks
  (Fugitive) NSPS
01/05/81
  10/18/83
VOL Storage Vessels NSPS
SOCMI Air Oxidation NSPS
SOCMI Distillation Operations
  NSPS
SOCMI Reactor Processes NSPSa
10/84


10/21/83


12/30/83
 Currently draft standards.
                                    D-7

-------
E-l  TRICHLOROETHYLENE EMISSIONS FROM DISTRIBUTION FACILITIES
(1)  Estimate the quantity going through distribution (storage)
     1983 approximate production = 200 MM Ibs
     Assume that all TCE goes through distribution
(2)  Estimate the number of storage tanks nationwide
     -  Assume the average tanks size is 10,000 gallons
     -  Assume the average turnover time is 1 month
     Number of tanks = 356 MM Ibs    / ga1\  /    1 tank     \    QC ... .
                                                               =  96 tanks
                                              lO.OOO gal x 11
(3)  Estimate storage emissions (fixed roof tanks)
     Breathing Loss
     LR  =  1.02 x lO'5 M /   P \  0.6801.73 H0.51 T0.5 f  ^
      8                  ^TO^PJ                        p   x
     LR  = 1.02 x 10"5 (133)/   0.5  \ °'68 (10)1'73 (9)0'51 (1.15)(0.5)(1.0)
      B                     ^14. 7-0. 8J
     LB = 0.018 Mg/yr
Working Loss
Lw = 1.09 x 10"8 MvPVNKnKc
LW = 1.09 x 10"8 (133)(0.8)(10fOOO)(17)(l)(l)
Lw = 0.197 Mg/yr
Total Loss
LT  =  LB + LW  =  0.22 Mg/yr per tank
Total nationwide storage emissions  = (0.22) (96)   =  21 Mg/yr
                                   E-l

-------
     where:
          MV   =   molecular weight  of  product  vapor  (Ib/lb mole)
          P    =   true  vapor  pressure  of  product  (psia)
          D    =   tank  diameter  (ft)
          H    =   average  vapor  space  height (ft)
          T    =   average  diurnal temperature  change  (°F)
          F    =   paint factor  (dimensionless); 1.0  for clean white paint
          C    =   tank  diameter  factor (dimensionless):
                 for diameter >_ 30 feet,  C =  1              ?
                 for diameter < 30 feet,  C =  0.771D  - 0.013D^  -  0.1334
          K    =   product  factor (dimensionless)  = 1.0 for VOL
          V    =   tank  capacity  (gal)
          K    =   turnover factor (dimensionless):
                 for turnovers  > 36,  K   =  180  + N
                                      n        6N
                 for turnovers  1 36,  K   =  1
(4)  Estimate container filling emissions
     Loading  Loss
     LL  =  12.46 S P  M
     where:   S  =  saturation  factor  (0.50 for submerged fill  and
                   1.45 for  splash fill)
             P  =  True vapor  pressure,  psia
             M  =  Molecular weight
             T  =  Temperature, °R
                                   E-2

-------
Assume 50 percent splash filling (S = 1.0)
       12.46   1.0)0.8133)  ,  2>5 lb/1Q3

                               =  1.13 lb/103 gal
200 MM lb/  gal  V U13_M\    w Mg/yr
               n>A10J ga1/
                             E-3

-------
                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing/
1. REPORT NO.

 EPA-450/3-85-021
                              2.
                                                            3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
 Survey  of Trichloroethylene  Emission Sources
                                                            5. REPORT DATE
                                                              July 1985
              6. PERFORMING ORGANIZATION CODE
•j A I ITLJrtQ (C\
 [OTTapdullo.S.A. Sbareef.  l.E.Kincaid.  P.V.  Murphy
 Radian Corporation - Post  Office Box 1300(5
 Research Triangle Park,  North Carolina  27709	
                                                            8. PERFORMING ORGANIZATION REPORT NO.'
9. PERFORMING ORGANIZATION NAME AND ADDRESS

 Office  of Air Quality Planning and Standards
 Environmental Protection Agency
 Research  Triangle Park, North Carolina  27711
                                                            10. PROGRAM ELEMENT NO.
              11. CONTRACT/GRANT NO.
                EPA Contract 68-02-3816
12. SPONSORING AGENCY NAME AND ADDRESS
 DAA  for Air Quality Planning and Standards
 Office  of Air and Radiation
 U.S.  Environmental Protection Agency
 Research Triangle Park,  North Carolina  27711
              13. TYPE OF REPORT AND PERIOD COVERED
                Final
              14. SPONSORING AGENCY CODE


               EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
 The  potential  health impact of trichloroethylene emissions  is  being investigated.
 This  document contains  information on the  sources of trichloroethylene emissions,
 current  emission levels,  control  methods that  could be used  to reduce trichloro-
 ethylene emissions, and cost estimates for employing controls.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
b. IDENTIFIERS/OPEN ENDED TERMS  C.  COSATI Field/Group
 Air  Pollution
 Pollution  Control
 Synthetic  Organic Chemical  Manufacturing
    Industry
 Trichloroethylene
  Air Pollution  Control
   13B
18. DISTRIBUTION STATEMENT

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   120
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   22.  PRICE
       Insert the price set by the National Technical Information Service or the Government Printing Office, il known
EPA Form 2220-1 (Rev. 4-77) (Reverse)

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