&EPA
          United States
          Environmental Protection
          Agency
          Office of Air Quality
          Planning and Standards
          Research Triangle Park NC 27711
EPA-450/3-84-004
March 1984
          Air
Benzene Emissions
From Benzene
Storage Tanks —
Background
Information for
Proposal to Withdraw
Proposed Standards

-------
                                  EPA-450/3-84-004
          Benzene Emissions from
         Benzene Storage Tanks —
        Background Information for
Proposal to Withdraw Proposed Standards
              Emission Standards and Engineering Division
             U.S. ENVIRONMENTAL PROTECTION AGENCY
                  Office of Air and Radiation
               Office of Air Quality Planning Standards
             Research Triangle Park, North Carolina 27711
                     March 1984

-------
This report has been reviewed by the Emission Standards and Engineering Division of the Office of Air
Quality Planning and Standards, EPA, and approved for publication. Mention of trade names or commercial
products is not intended to constitute endorsement or recommendation for  use. Copies of this report are
available through the Library Services  Office (MD-35), U.S. Environmental Protection Agency,  Research
Triangle Park, N.C. 27711, or, for a fee, from the National Technical Information Services, 5285 Port Royal
Road, Springfield, Virginia 221 61.

-------
                     ENVIRONMENTAL PROTECTION AGENCY

                         Background Information
                          Benzene Storage Tanks

                              Prepared by:
Ja£k R. Farmer       *                                    Date
Director, Emission Standards and Engineering Division
U.S. Environmental Protection Agency
Research Triangle Park, NC  27711

1.   The Federal Register notice proposes  withdrawal  of proposed national
     emission standards (45 FR 83952;  December 19,  1980)  for benzene
     emissions from all existing and new Benzene Storage Tanks.

2.   Copies of this document have been sent to the  following Federal
     Departments; Labor, Health and Human  Services,  Defense,  Transportation,
     Agriculture, Commerce, Interior,  and  Energy; the National  Science
     Foundation; the Council  on Environmental  Quality;  members  of the
     State and Territorial Air Pollution Program Administrators; the
     Association of Local  Air Pollution Control  Officials;  EPA  Regional
     Administrators; and other interested  parties.

3.   The comment period for review of  this document  is  30 days.
     Mr. Gilbert H.  Wood may be contacted  regarding  the date of the
     comment period.

4.   For additional  information contact:

     Gilbert H.  Wood
     Standards Development Branch (MD-13)
     U.S. Environmental Protection Agency
     Research Triangle Park,  NC  27711

5.   Copies of this  document may be obtained from:

     U.S. EPA Library (MD-35)
     Research Triangle Park,  NC  27711

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

-------
                           TABLE OF CONTENTS


Section                                                               page

          LIST OF FIGURES	v

          LIST OF TABLES	vi

  1       SUMMARY	i-i

          1.1  Summary of Changes Since Proposal  	 1-1
          1.2  Summary of Proposal to Withdraw the
               Proposed Standards 	 1-1

  2       SUMMARY OF PUBLIC COMMENTS	2-1

          2.1  Selection of Benzene Storage Tanks for Regulation  .  . 2-1

          2.2  Health and Environmental Impacts 	 2-14
APPENDICES

     A    EMISSIONS SOURCE TEST DATA AND ANALYSIS	A-l

     B    METHODOLOGY FOR ESTIMATING LEUKEMIA INCIDENCE
          AND MAXIMUM LIFETIME RISK FROM EXPOSURE TO
          BENZENE STORAGE TANKS 	                        B-l
                                  IV

-------
                             LIST OF  FIGURES

Figure                                                              page
 A-l      Process and instrumentation schematic  	  A-3
 A-2      Plan view of noncontact bolted  IFR	A-5
 A-3      Elevation view of noncontact bolted  IFR  in  test  tank   .  .  A-6
 A-4      Plan view of contact  welded IFR	A-7
 A-5      Elevation view of contact welded IFR in  test tank  . .  .  .  A-8
 A-6      Plan view of contact  bolted IFR	A-9
 A-7      Elevation view of contact bolted IFR in  test tank  ....  A-10
 A-8      Example of fitting emission bench test apparatus   ....  A-19

-------
                             LIST OF TABLES

Tab1e                                                                 Page
 1-1      Changes in Nationwide Impacts  	    1-2
 2-1      List of Commenters on the Proposed National
          Emissions Standards for Hazardous Air Pollutants
          for Benzene Storage Vessels  	  2-2
 2-2      Vessels Containing Mixtures That May be More Than
          10 Percent Benzene	2-13
 2-3      Comparison of Emissions as Calculated from the EPA
          Series and the 2519/2517 Series	2-20
 2-4      Internal  Floating Roof Tank Emissions by Source	2-22
 2-5      Emissions from a Typical Benzene Storage Vessel	2-23
 2-6      Comparison of Convective and Permeability Losses from
          Internal  Floating Roof Seal  Systems in the Model Tank.  .  .  2-28
 2-7      Model  Tank Emissions  (Mg/yr) from a Fixed Roof Tank
          and a  Typical  Internal  Floating Roof Tank	2-29
 2-8      Emissions from New and Existing Model  Plants	2-30
 2-9      Nationwide Emissions  from New and Existing
          Benzene Storage Tanks	  .  2-31
 A-l      Summary of Test Conditions for Phase 1 and 1R	A-ll
 A-2      Summary of Test Conditions for Phase 2 and 2R	A-13
 A-3      Summary of Test Conditions for Phase 3 and 3R	A-15
 A-4      Summary of Test Results  for  All
          Potentially Relevant Tests 	   A-16
 A-5      Summary of IFR Deck Fitting  Emission Tests	A-20
 A-6      Permeability of Polyurethane  Coated Nylon  Fabric 	   A-21
 A-7      Comparison of  Wiper Seals  to  Foam-Filled
          Vapor-Mounted  Seals  	   A-23
 A-8      Comparison of  Liquid-Mounted  Seal to
          Vapor-Mounted  Seal	A-24
 A-9      Bolted  Deck Seam  Emissions	A-26
 A-10      Comparison of  Emissions  as a  Function  of Liquid  Type  . .  .   A-27

                              (continued)
                                  vi

-------
                      LIST OF TABLES (Concluded)

                                                                     Page
         Plants and Locations for Benzene Storage Tanks 	  B-4
         Model Inputs for Each Type of Model Plant	B-10
         Estimated Maximum Concentration and Exposure
         for Benzene Storage Tanks  	  B-16
B-4      Estimated Nationwide Health Impacts
         for Benzene Storage Tanks  	  B-21
                                 VII

-------
                                1.  SUMMARY

      On December 19, 1980, the U.S. Environmental Protection Agency
 (EPA) proposed National Emissions Standards for Hazardous Air Pollutants
 (NESHAP) for benzene storage vessels under the authority of Section 112
 of the Clean Air Act.   The proposed standards were published in the
 Federa1 Register (45 FR 83952) with a request for public comment.   A
 public hearing was held on June 9, 1981.   Six individuals representing
 three organizations made presentations.   A total  of 22 comments from
 industry,  two trade associations, and an  environmental group were  submitted
 during the comment period.   Comments  submitted relevant to the  withdrawal
 decision and EPA's responses  are  summarized in this document.   The
 summary of comments and responses serves  as the basis  for the proposal
 to withdraw the proposed standards.
 1.1  SUMMARY OF CHANGES SINCE PROPOSAL
      Since the  standards for  benzene  emissions from benzene  storage
 vessels  were proposed  (December 19, 1980;  45  FR 83952),  estimated  benzene
 emissions  from  this  source  category have  declined  considerably.  This
 estimated  reduction  is  due  to revised emission factors  based on new test
 data  acquired since  proposal.   The basis  for the revised  emission  factors
 is  discussed  in more detail in  Section 2.2.2.1 of  this  document.   Table 1-1
 compares the estimated  nationwide baseline benzene emission and health
 impacts due  to benzene  storage  vessels at proposal with current estimated
 impacts.
 1.2  SUMMARY OF PROPOSAL TO WITHDRAW THE PROPOSED  STANDARDS
     The Administrator  is proposing to withdraw the proposal  of the
 benzene standards for benzene storage vessels.   This decision is based
on several  factors, including the  broad amount of  control currently

-------
                Table 1-1.  CHANGES IN NATIONWIDE IMPACTS
           Impact
 At proposal
                                                                Current
Benzene emissions (Mg/yr)

Leukemia incidence (cases/yr)

Maximum lifetime risk
    2,200

0.12 to 0.82

 1.5 x 10"4
     to
                                        1.0 x 10
                                                -3
    620

   0.043

3.6 x 10
-5
                                1-2

-------
within the source category, the relatively small amount of emissions,
the small estimated leukemia incidence and maximum lifetime risk at
current control levels, and the inability to reduce health risks
significantly with additional controls.   This decision is discussed in
greater detail in Section 2.1.2.
                               1-3

-------
                       2.  SUMMARY OF PUBLIC COMMENTS

       A list of commenters, their affiliations, and the EPA docket entry
  number assigned to each comment are shown in Table 2-1.  Twenty-two
  letters commenting on the proposed standards and the Background Information
  Document (BID) for the proposed standards were received.   Because the
  proposed standards are being proposed for withdrawal, only comments and
  responses relevant to that decision are addressed in this document.
  Significant comments have been combined into the following two categories:
       2.1  Selection of Benzene Storage Tanks for Regulation
       2.2  Health  and Environmental  Impacts
  2.1  SELECTION OF BENZENE STORAGE  TANKS FOR  REGULATION
  2-1.1  Selection  of Source  Category
       Several  commenters  contended  that the proposed  benzene storage
  emissions  standard  is  not needed and,  therefore,  should be  withdrawn.
  These comments  address the  following:   (1) significance and relative
  proportion  of  risk  associated with  benzene storage emissions;  (2) dupli-
  cation  of federal and State regulations and guidelines; (3)  information
  indicating  that risks are smaller than  estimated  in the preamble to the
  proposed standards;  (4) acceptable  residual risk; and (5) lack of data
  to demonstrate risk.
       Comment:  Tnree commenters stated that the EPA has not demonstrated
  that  benzene storage emissions, relative to other benzene source
 categories, pose a significant risk that merits the adoption of a benzene
 storage standard (IV-D-lOa,  IV-D-16, IV-F-1).  One of these commenters
•(IV-D-10a) stated that Section 112  requires that a NESHAP be established
 at the level that in the Administrator's judgement provides "an ample
 margin of safety to protect the public health from such  hazardous air
 pollutant."   According to the  commenter the Supreme Court has held that,
 absent a "clear mandate"  from  Congress  to  eliminate all  risk, the statutory

-------
             Table 2-1.   LIST OF COMMENTERS ON THE PROPOSED
        NATIONAL EMISSIONS STANDARDS FOR HAZARDOUS AIR POLLUTANTS
                       FOR BENZENE STORAGE VESSELS
Docket entry number3                       Commenter/affillation
IV-D-1                              Edward W.  Warren
                                    Kirkland and Ellis
                                    1776 K Street,  Northwest
                                    Washington,  D.C.  20006
                                    Counsel for the American Petroleum
                                      Institute

IV-D-2                              R.  W.  Bogan
                                    GATX Terminals  Corporation
                                    120 South Riverside Plaza
                                    Chicago, Illinois 60606

IV-D-3                              Edward W.  Warren
                                    Kirkland and Ellis
                                    1776 K Street,  Northwest
                                    Washington, D.C.  20006
                                    Counsel for the American Petroleum
                                      Institute

IV-D-4                              John T. Barr
                                    Air Products and Chemicals, Inc.
                                    Box 538
                                    Allentown, Pennsylvania 18105

IV-D-5                              John Heinz
                                    Unites States Senate
                                    Committee on Energy and Natural
                                      Resources
                                    Washington, D.C.  20510
                                    With attachment from Sun Petroleum
                                      Production Company

IV-D-6                              J.  C.  Pullen
                                    Celanese Fibers Company
                                    Box 32414
                                    Charlotte, North Carolina 28232

IV-D-7                              Herman A. Fritscher
                                    Cities Service Company
                                    Box 300
                                    Tulsa, Oklahoma 74102
                               (continued)


                                 2-2

-------
                           Table 2-1.  Continued
 Docket entry number3                          Commenter/affiliation


 IV'D-8                              E. M. Vancura
                                     Union Oil Company of California
                                     Box 7600
                                     Los Angeles, California 90051

 IV-D'9                              D. P. Martin
                                     Gulf Oil Company
                                     Post Office Box 2001
                                     Houston, Texas 77001

 IV"D'10                             Geraldine V.  Cox
                                     Chemical Manufacturers  Association
                                     2501 M Street,  Northwest
                                     Washington,  D.C.  20037

 IV-D-10a                             Lance S.  Granger
                                     Chemical  Manufacturers  Association
                                     2501 M Street,  Northwest
                                     Washington,  D.C.  20037
                                     Attachment to  docket entry  IV-D-10

 IV"D"n                              Paul  J.  Sienknecht
                                     The  Dow  Chemical  Company
                                     Midland,  Michigan 48640

 IV"D'12                              Alfred G. Hoerrner
                                     Merck Chemical Manufacturing Division
                                     Post Office Box 2000
                                     Rahway, New Jersey 07065

 IV"D"13                              Richard K. Meyers
                                    Texaco, Incorporated
                                    Post Office Box 509
                                    Beacon, New York 12308

IV-°-14                             F.  M. Parker
                                    Chevron U.S.A., Incorporated
                                    575 Market Street
                                    San Francisco,  California 94105

IV-D-15                             R.  J.  Samelson
                                    PPG Industries,  Incorporated
                                    One Gateway  Center
                                    Pittsburgh,  Pennsylvania 15222


                               (continued)


                                2-3

-------
                          Table 2-1.   Concluded
Docket entry number9                       Commenter/affiliation

IV-D-16                             Daniel B.  Rathbun
                                    American Petroleum Institute
                                    2101 L Street, Northwest
                                    Washington, D.C.  20037

IV-D-17                             John J.  Moon
                                    Phillips Petroleum Company
                                    Bartlesville, Oklahoma 74004

IV-D-18                             Dennis L.  Gehlhausen
                                    Eli  Lilly and Company
                                    307  East McCarty Street
                                    Indianapolis, Indiana 46285

IV-D-19                             David D.  Doniger
                                    Natural  Resources Defense Council,
                                      Incorporated
                                    1725 I Street, Northwest
                                    Suite 600
                                    Washington, D.C.  20006

IV-D-20                             Wells Eddleman
                                    General  Energy Consulting
                                    Route 1,  Box 183
                                    Durham,  North Carolina 27705

IV-D-21                             C.  D.  Mallach
                                    Monsanto Company
                                    800  North Lindbergh Boulevard
                                    St.  Louis,  Missouri 63166

IV-H-1                              T.  L.  Hurst
                                    Kerr-McGee Corporation
                                    Kerr-McGee Center
                                    Oklahoma City, Oklahoma 73125

IV-F-1                              National  Air Pollution Control
                                      Techniques Advisory Committee
                                    Transcript of Meeting for National
                                      Emission Standards for Hazardous
                                      Air Pollutants from Benzene
                                      Storage Vessels
                                    U.S.  Environmental Protection Agency
                                    Office of Administration
                                    Research Triangle Park, NC 27711

aThese designations represent docket entry numbers for Docket
 No.  A-80-14.   These documents are available for public inspection at:
 U.S.  Environmental Protection Agency,  Central  Docket Section, West
 Tower Lobby,  Gallery 1, Waterside Mall, 401 M Street, Washington,  D.C.
 20460.
                                 2-4

-------
 term "safe"  (regarding exposure levels),  rather than meaning "absolutely
 risk-free,"  means  a level  that protects  against a "significant risk of
 harm."   The  commenter noted that risk levels  that the EPA has calculated
 are  not "significant" as that  term has been used by  the  court.
      Two commenters (IV-D-16,  IV-D-21) felt that the risk from exposure
 to benzene emissions is insignificant compared  to other  commonly  accepted
 societal risks.  Two commenters (IV-D-13,  IV-D-16) noted that the risk
 from benzene storage emissions is  insignificant in comparison to  the
 background leukemia incidence  risk.
      Two commenters (IV-D-4, IV-D-13) further compared the risk from
 benzene storage  emissions  to other government determinations  of risk
 acceptability and  noted that,  under these  determinations,  the risk from
 exposure to  benzene storage emission  sources  would have  been  considered
 not  worthy of regulation.
      Response:   The commenters are judging the  significance of  benzene
 storage vessels  based on quantitative risk estimates.  In  general,
 quantitative risk  estimates at ambient concentrations involve an  analysis
 of the  effects of  a substance  in high-dose epidemiological or animal
 studies,  and extrapolation  of  these high-dose results to relevant  human
 exposure routes  at  low doses.   In  the case of benzene, the effects
 observed were the  result of high-dose epidemiological studies.  The
 mathematical   models  used for such  extrapolations are based on observed
 dose-response relationships for carcinogens and assumptions about  such
 relationships as the  dose approaches  very  low levels or zero.  Quantitative
 risks to  public  health  from emissions of an airborne carcinogen may be
 estimated by combining  the  dose-response relationship obtained from this
 carcinogenicity  strength determination with an analysis of the extent of
 population exposure to  a substance through ambient air.
     Most exposure analyses are based on air quality models, available
 estimates of emissions  from sources of a substance, and approximations
 of population distributions near these sources.   EPA considers this the
 best practicable approach.   Even though ambient monitoring data might be
 used to estimate quantitative risks to public  health, these data are
available only for a few locations near these  sources.   Thus, use  of
ambient monitoring data is  not  practicable.  However, EPA has data to
confirm that  the public is  exposed to  benzene.  For example, concentrations
                                 2-5

-------
 up  to  51  micrograms  per  cubic  meter  (on  a  24-hour  average) were  found
 around a  petrochemical plant in  Philadelphia,  Pennsylvania.
     The  air  quality models used in  exposure analyses  generally  estimate
 exposures out to  20  kilometers from  the  source.  During exposure analyses,
 population and growth statistics are examined  in conjunction with ambient
 concentrations.   Using these factors and existing  carcinogenicity strength
 determinations, estimates are  then made  of the degree  of risk to
 individuals and the  range of increased cancer  incidence expected from
 ambient air exposures associated with a  substance  at various possible
 emission  levels.
     The  assumptions and procedures  discussed above for extrapolation
 and  for exposure  estimates for benzene emissions are subject to
 considerable  uncertainty.  A small portion of that uncertainty has been
 considered by  calculating ranges  at  proposal.  The ranges presented at
 proposal  represent uncertainty in estimates of benzene concentrations to
 which  workers  were exposed in  occupational studies of  Infante, Aksoy,
 and Ott that  serves as the basis  for developing the benzene unit  risk
 factor (Part  I Docket Item II-A-31).   The  ranges presented represent
 95 percent confidence limits on  two  sources of uncertainty in the benzene
 risk estimates.   One source derives  from the variations in dose/response
 among  the  three occupational studies upon which the benzene unit  risk
 factor is  based.  A second source involves the uncertainties in the
 estimates  of ambient exposure.    In the former case, the confidence
 limits are based  on the assumption that the slopes of the dose/response
 relationships  are unbiased estimates of the true slope and that the
 estimates  are  log normally distributed.   In the latter case, the  limits
 are based  on the  assumption that actual  exposure levels may vary by a
 factor of  two  from the estimates obtained by dispersion modeling  (assuming
 that the source specific data are correct).
     Other uncertainties associated with estimating health impacts were
 not quantified at proposal.   EPA has extrapolated the leukemia risks
 identified for occupationally exposed populations (generally healthy,
white  males) to the general  population for whom susceptibility to a
 carcinogenic insult could differ.  The presence of more or less susceptible
 subgroups within the general  population  would result in an occupationally-
 derived risk factor that may underestimate or overestimate actual risks.
                                 2-6

-------
 To the extent that there are more susceptible subgroups within the
 general population, the maximum individual lifetime risks may be
 underestimated.
      On the other hand, general population exposures to benzene are much
 lower than those experienced by the exposed workers in the occupational
 studies, often by several orders of magnitude.  In relating the occupa-
 tional experience to the general population, EPA has applied a linear,
 non-threshold model that assumes that the leukemia response is linearly
 related to benzene dose, even at very low levels of exposure.   There are
 biological data  supporting this approach, particularly for carcinogens.
 However, there are also data which suggest that, for some toxic chemicals,
 dose/response curves are not linear,  with response decreasing  faster
 than dose at low levels of exposure.   At such levels,  the non-linear
 models tend to produce smaller risk factors than the linear model.   The
 data for benzene do not conclusively  support either hypothesis.   EPA has
 elected to use the linear model  for benzene because this  model  is  generally
 considered to be conservative compared to the non-linear  alternatives.
 This choice may  result in an overestimate of the actual leukemia  risks.
      EPA estimates ambient benzene  concentrations  in the  vicinity  of
 emitting sources through the use of atmospheric  dispersion  models.   EPA
 believes  that its  ambient dispersion  modeling provides a  reasonable
 estimate  of the  maximum ambient  levels  of benzene  to which  the public
 could  be  exposed.   The  models  accept  emissions estimates, plant parameters,
 and  meteorology  as  inputs  and  predict  ambient concentrations at specified
 locations,  conditional  upon  certain assumptions.   For example, emissions
 and  plant  parameters often must be estimated  rather  than measured,
 particularly  in  determining  the magnitude of  fugitive emissions and
 where  there are  large numbers of sources.  This can  lead to overestimates
 or underestimates of exposure.  Similarly, meteorological  data often are
 not available at the plant site but only  from distant weather stations
 that may not be representative of the meteorology of the plant vicinity.
     EPA's dispersion models normally assume that the terrain in the
 vicinity of the sources is flat.   For sources located in complex terrain,
 this assumption would tend to underestimate the maximum annual
concentration although estimates of aggregate population exposure would
be less affected.  On the other hand,  EPA's benzene exposure models
                                 2-7

-------
 assume that the exposed population is immobile and outdoors at their
 residence, continuously exposed for a lifetime to the predicted
 concentrations.  To the extent that benzene levels indoors are lower and
 that people do not reside in the same area for a lifetime, these
 assumptions will tend to overpredict exposure.
      Upon reconsideration, EPA has concluded that the presentation of
 the risk estimates as ranges does not offer significant advantages over
 the presentation as the associated point estimates of the risk.   Further,
 the proposal ranges for benzene make risk comparisons among source
 categories more difficult and tend to create a false impression that the
 bounds of the risks are known with certainty.   For these reasons, the
 benzene risks in this rulemaking are presented as point estimates of the
 leukemia risk.   EPA believes that these risk numbers represent plausible,
 if conservative, estimates of the magnitude of the actual  human cancer
 risk posed by benzene emitted from the source categories evaluated.   For
 comparison,  the proposal  ranges may be converted into rough point estimates
 by multiplying the lower end of the range by a factor of 2.6.
      The assumptions necessary to estimate benzene health  risks  and  the
 underlying uncertainties  have led some commenters on EPA's proposed
 rules to suggest that the risk estimates are inappropriate for use in
 regulatory decision making.   Although EPA acknowledges the potential  for
 error in such estimates,  the Agency has  concluded that both the  unit
 risk factor  for benzene and  the evaluation of  public exposure  represent
 plausible, if conservative,  estimates of actual  conditions.  Combining
 these quantities to produce  estimates of the leukemia risks to exposed
 populations  implies that  the risk estimates obtained are also  conservative
 in nature; that is the actual  leukemia risks from benzene  exposure are
 not likely to be higher than those  estimated.   In this context,  EPA
 believes that such estimates of the health hazard can and  should  play an
 important role  in the regulation of hazardous  pollutants.
      When the standard for benzene  storage vessels was proposed on
'December 19,  1980,  the Administrator  made the  judgment that "benzene
 emissions from  benzene storage  vessels create  a  significant risk  of
 cancer and require the establishment  of  a national emissions standard
 under Section 112"  (45 FR 83954).
                                  2-8

-------
      The  data  base  used  to  calculate  emissions  from  storage  vessels  has
 changed since  the standard  was  proposed.  This  change  is  based  on  new
 test  data acquired  since proposal.  This  data base and the reasons for
 using it  are described in Section 2.2.2.1.   Based on these new  data, the
 emission  estimates  for fixed  roof tanks (totally uncontrolled tanks)
 remains unchanged.  The  emission estimates  for  internal floating roof
 tanks and external  floating roof tanks are  lower than  at  proposal.
 Since a substantial proportion  of existing  tanks have  internal  or  external
 floating  roofs, this change resulted  in a substantial  reduction in the
 estimate  of nationwide emissions from these  tanks.   For this reason, the
 Administrator  reevaluated the need to establish Section 112  standards
 for benzene storage vessels.
      Using the new emission data and  a new exposure  modeling approach
 adopted since proposal,  the EPA estimated current leukemia cases and
 maximum lifetime risks that occur due to exposure from storage  vessels,
 and the potential reductions that could be achieved  to determine whether
 this  source category continues to pose significant risk and whether a
 standard  is warranted under Section 112.
      Benzene storage vessels are currently estimated to emit about
 620 Mg of benzene per year  from about 126 storage facilities.   This
 amount is about 1 percent of total benzene emissions from stationary
 sources.   Estimated lifetime risk due to these emissions  is about
 3.6 x 10   for the most exposed individuals, and over  the total  exposed
 population (within 20 km of each facility) about 0.043 cases per year
 are estimated to occur.
      For comparison, at proposal, the 126 facilities were estimated to
 emit  about 2,200 Mg benzene per year.   These benzene emissions were
 estimated to result in a range of 0.12 to 0.82 leukemia cases per year
 and a range of maximum lifetime risk of about 1.5 x 10   to 1.0 x 10"^.
 Thus,  since proposal,  estimated benzene emissions have been revised
 downward  by over 70 percent, estimated annual leukemia incidence by over
85 percent,  and estimated maximum lifetime risk by over 90 percent.
     Control  measures  that can be used to  reduce benzene emissions
 include the use of certain types of  equipment (much of which  is  already  .
 in place  on many tanks  in the  industry),  such as internal  floating
roofs, primary seals,  and secondary  seals, or enclosure of the storage
                                 2-9

-------
tanks and routing emissions to a combustion device (discussed at proposal).
These control techniques could reduce nationwide emissions over baseline
by about 18 to 98 percent, depending on the technique applied.
     The current estimated leukemia incidence and maximum lifetime risk
represent small risks to public health.   By both expressions of health
risk, the extent of the hazard posed by this source category is more
than an order of magnitude smaller than for benzene source categories
for which standards are being developed.  Using the control techniques
mentioned above, leukemia incidence could be reduced to roughly 0.036 to
0.0009 cases per year (about 16 to 98 percent reduction), and maximum
lifetime risk to roughly 2.9 x 10   to 7 x 10"7, (about 20 to 98 percent
reduction).   Although a large percentage reduction could be achieved in
the health risks by enclosing, routing,  and combustion, the absolute
amount is small.
     Because of the extent of control now exhibited by the industry, the
small amount of benzene emissions from these sources and the small
portion (about 1 percent) of the total benzene emissions from stationary
sources that these sources represent, the small leukemia incidence and
maximum lifetime risk estimated at current levels, and the small
incremental  reductions in these health risks achievable with available
control techniques, the Administrator has concluded that benzene emissions
from benzene storage vessels do not warrant Federal regulatory action
under Section 112.
     One commenter (IV-F-1) stated that the "risk levels that EPA has
calculated are not 'significant1  as that term has been used by the
Court."  EPA assumes that the commenter refers to the court interpretation
in Industrial Union Department, AFL-CIO v.  American Petroleum Institute,
65 L. Ed.  2d 1010,  100 S.  Ct.  2844 (1980).   This interpretation of the
significance of risk was made in the context of The Occupational Safety
and Health Act of 1970, not the Clean Air Act.   It is not necessarily
appropriate to transfer interpretations from one to the other.   In any
case, the Court in fact never indicated what actually constitutes a
"significant" risk except to give obvious examples of what constitutes
plainly acceptable and plainly unacceptable risks.  The Court stated:
"If, for example, the odds are one in a billion that a person will die
from cancer by taking a drink of chlorinated water, the risk clearly
                                 2-10

-------
 could not be considered significant.   On the other hand,  if the odds are
 one  in a thousand that regular inhalation of gasoline vapors that are
 two  percent benzene will  be  fatal,  a  reasonable person might well consider
 the  risk significant and  take appropriate steps to decrease or eliminate
 it"  (48 LW 5034).   The Court then  stated that it was  the  duty of the
 OSHA Administrator to determine, using rational judgment,  the relative
 significance of  the risks associated  with exposure to a particular
 carcinogen.
 2.1.2  Storage Vessels Attached to  Moving Vehicles
      Comment:  One commenter (IV-D-7)  stated that definition of storage
 vessels should exclude storage vessels attached to mobile  vehicles,  such
 as tankers,  barges and tank  trucks.
      Response:   The control  technologies  that would be necessary to
 control  benzene  emissions  from storage vessels  attached to  mobile vehicles,
 such as tankers,  barges,  or  tank trucks,  are completely different from
 those that  are appropriate for other  storage vessels.   Additionally,
 data collection  on tankers,  barges, and  tank trucks was not part of  the
 survey performed  by the EPA  to develop a  data base  to  support  the Benzene
 Storage Vessel NESHAP.  For  these reasons, it was  never the intent of
 the  EPA to  consider these types of benzene storage  vessels  as  designated
 sources  under this  NESHAP.
 2.1.3   Coke Oven  Byproduct Vessels
      Comment:  One  commenter  (IV-D-15) stated that the  regulations
 should  not exempt  tanks at coke oven by-product facilities.  He  felt
 that  if  benzene is  hazardous,  all  facilities  should be  required  to meet
 uniform  control requirements.
      Response:  A  separate NESHAP is currently being developed for coke
oven by-product facilities.  Vessels at coke oven by-product facilities
were not incorporated into the benzene storage vessels source category
because the applicable control techniques are different than the ones
considered for this source category.   This is a function of the nature
of the coking and byproduct processes.   For this reason, the Agency has
decided that a separate standard for vessels  at coke oven  by-product
facilities is appropriate  and that  such vessels should not be incorporated
into  these standards.
                                 2-11

-------
2.1.4  Benzene Mixtures
     Comment:  One commenter (IV-D-19) pointed out that the proposed
standards would apply only to vessels that store pure benzene.  He asked
if vessels that store mixtures of benzene and other substances existed;
and if so, why such vessels were not affected by these standards.
     Response:  It is true that vessels storing mixtures of benzene and
other chemicals exist, but such vessels were never intended to be part
of this source category.  In part, this is because many vessels storing
mixtures, such as those associated with coke oven byproduct processes,
have different control options than those identified for this source
category.  The controls and impacts of control strategies for vessels
storing mixtures would have to be examined as part of a separate source
category.  For this reason, the Agency decided not to extend the
applicability of this source category to vessels storing benzene mixtures.
     However, some information is currently available on vessels storing
benzene mixtures,  which for completeness will be presented here.   There
are three general  classes of stored liquids that are composed of benzene
that would not have been affected by the proposed standards.   These are:
     1.    Liquids  such as gasoline, which are stored in large quantities,
          but do not, on a fractional  basis,  contain more than 10 percent
          benzene;
     2.    Mixtures in which benzene may be more than 10 percent;  and
     3.    Benzene  that does not meet the specific gravity specification
          for industrial grade benzene (crude benzene).
     New vessels storing gasoline (^2  percent benzene) are affected
facilities under Standards of Performance for Petroleum Liquid Storage
Vessels  (40CFR60:   Subpart K(a)).   These standards discussed above
require  controls that are almost identical in effectiveness to those
that were selected as BAT for new benzene storage vessels in the  proposed
NESHAP rule requirements.   Many state  implementation plans (SIPs) require
that existing gasoline storage vessels be controlled to almost the same
extent as the proposed BAT for existing benzene storage vessels.
     Data were gathered on vessels storing liquids of the second  class
(Table 2-2).   This data was obtained from a data base of 4,054 vessels
associated with the Synthetic Organic  Chemical  Manufacturing
Industry (SOCMI).   Fifteen (15)  were thought  to possibly contain  more
                                 2-12

-------
              Table 2-2.  VESSELS CONTAINING MIXTURES THAT MAY BE
                         MORE THAN 10 PERCENT BENZENE3
        Vessel contents
    Volume (1000's of gallons)
Benzene Caprolactum

Benzene Lactum

Benzene/Toluene

EA, Benzene, Water

EA, Benzene

Light Aromatic Distillate
4.4

7

37.8, 237, 42, 8.8, 17.0, 1272.7l

2  2  2b
f. , f. , £.

4.75

515, 515, 63.5b
 Including crude benzene.
""Multiple vessels with same contents.
                                    2-13

-------
 than 10 percent of benzene.   The total  volume of these vessels  is about
 2.7 million gallons.   This  can be compared to the estimated 500 vessels
 with a total  volume of about 308 million gallons that stored industrial
 grade benzene in 1979.   The total  tank  volume (tankage)  devoted to the
 storage of this type of benzene mixtures is less than one  percent of the
 tankage devoted to benzene.   Because  vessels  storing  mixtures will  have
 reduced amounts of benzene  in them, the true  amount of benzene  stored
 may be significantly reduced from the above two  million  gallons.
      The last class of liquids  consists of unfinished (crude) benzene or
 off specification benzene.   Most such liquids are petroleum liquids  and
 many are affected facilities  under Subpart K(a)  or the SIPs and  as  such,
 would be controlled to  some  extent.   There was only one  such tank in the
 data base.
 2.2  HEALTH AND ENVIRONMENTAL IMPACTS
 2.2.1  Background
      The proposed standards,  which were  based on  Best  Available
 Technology  (BAT),  would  have  required the  use of  a fixed roof in
 combination with  an  internal  floating roof.   The  proposed standards  also
 would have  required  that the  internal floating roof be in contact with
 the  liquid surface  and be equipped with  a  liquid-mounted primary  seal
 and  a continuous  secondary seal.
      Many commenters suggested that the  EPA delay the development of  the
 final  standards until the effectiveness  of BAT equipment relative to
 other equipment types could be reevaluated using  data from  the American
 Petroleum Institute (API) 2519 Task Group testing program.   The results
 of this  testing program have been received and evaluated by the EPA.
 Comments were also received on other aspects  of BAT,  such as control
 equipment costs.
 2.2.2  Selection of the Level of the Standard
      2.2.2.1  Emission Data Base.  Seven commenters suggested that the
 emissions data base used in selection of the BAT at proposal was erroneous
 and that the Agency should await the completion of a  new API testing
program before selecting BAT prior to promulgation (IV-D-1, IV-D-2,
 IV-D-3,  IV-D-8, IV-D-10, IV-D-10a, IV-D-14).
      Response:  There are four potential emission data bases from which
emission calculations could be developed.  These are:

                                 2-14

-------
 1.    A test series  done by Chicago  Bridge  and Iron (CBI)  for an
      internal  floating  roof vendor.   This  series  measured emissions
      from  a bolted,  noncontact internal  floating  roof equipped with
      wiper-type,  vapor-mounted primary  seals;  and a welded contact
      internal  floating  roof.   The welded roof was equipped with a
      liquid-mounted  primary seal and  in  some  instances  a  secondary
      seal.   All the  tests  were performed in a propane/octane binary
      mixture.  This  data base  is hereafter referred to  as the
      Vendor report or series.
 2.    A large number  of  tests done on  various  external  floating
      roofs  with propane/octane as the stored  liquid.  These  tests
      were  also performed by CBI.  The primary  emphasis  of this work
      was to categorize  emissions from various  types  of  primary and
      secondary seals and was used to  update API bulletin  2517,
      which  is used in estimating emissions from external  floating
      roof  tanks.  It was also  used  in the  1981 revision of  EPA
      publication AP-42.   This  work  is referred to  as the  2517  series
      or report.
 3.    A test  series done  by  CBI  for the EPA using  benzene  as  the
      test  liquid.  This program  tested a  bolted noncontact  internal
      floating roof with  vapor-mounted, shingled, primary  and secondary
      seals;  a welded contact type internal  floating roof  equipped
      with a  liquid-mounted  primary seal   and in some instances, a
      secondary seal; and an external  floating roof equipped with a
      mechanical shoe primary seal and in some instances a secondary
      seal.   This data base will be referred to as the EPA report or
      series.
4.   A test program done by CBI for API  on  emissions from internal
      floating roofs.   This program tested three roof types (non-
     contact, bolted contact, welded contact), three primary seal
     types  (vapor-mounted wiper; vapor-mounted, foam-filled resilient
     seal;  liquid-mounted seal) with and without secondary seals,
     in three different  liquids (propane/octane,  hexane, and octane).
     Additional  work was done on emissions  from the components of
                            2-15

-------
           an internal  floating  roof.   This  consisted  of deck fitting
           emission  tests,  laboratory  evaporation  tests,  laboratory
           permeability tests, and  bench  permeability  tests.   This data
           base  will  be referred to as the 2519  report or series.
      Each  of the  above test  series was performed  in the  CBI  20  foot
 diameter pilot  test  tank.  The  first  three  were completed prior to the
 development  of  the proposed  standards, but  the  2519 series was  completed
 after the  date  of proposal.
      In evaluating the emissions data for internal and external floating
 roofs prior  to  proposal  it was  noted  that emissions from the  EPA series
 were  significantly higher than  those  measured in  either  the Vendor or
 the 2517 series when tests on similar equipment were  normalized to the
 same  vapor pressure and  molecular-weight.   The  Agency  believed  that the
 difference in emissions  resulted from a  difference in  liquids,  namely
 multicomponent  liquids such  as  propane/octane and single  component
 liquids such as benzene.  The reason  for this difference  was  believed to
 be due to  that  fact that in  a mixed product (e.g.  the  propane/octane
 mixture) the emission  rate depends upon  the ability of the component
 with  the highest  partial pressure  (e.g. propane) to migrate through the
 liquid to  the liquid surface and replenish the  component  that is lost
 through evaporation at the liquid  surface.   In  a single component product
 (e.g.  benzene), however, the liquid surface does not tend to become
 depleted of light ends at the liquid  surface during the evaporation
 process.    Thus, a mixed product of the same vapor pressure as a single
 component  product was expected to  have a lower  evaporation rate due to
 this  phenomenon.  Therefore,  in selecting BAT at proposal only the EPA
 test  series was used because it was believed that the previous
 propane/octane test work was not representative of single component
 emissions  such as a vessel  storing benzene.
      Industry representatives commented that the higher emissions were a
 result of  the test procedures and did not necessarily result from a
 difference in evaporative properties.   The 2519 test series shows that
when  normalized to a common vapor pressure and molecular weight, there
 is no significant emission difference between hexane,  octane, and the
 propane/octane binary mixture.   Based on these results the Agency now
 agrees that there is no evidence of evaporative difference between
                                 2-16

-------
  single and multicomponent liquids stored in floating roof tanks, and
  this is not a reason for the higher emissions measured in the EPA series.
       One cause of at least a portion of the higher emissions from the
  EPA series is that during certain internal  roof tests done for the EPA
  series, the roof fittings had openings that would not normally exist in
  the field and were sealed with polyurethane film, which,  as previously
  discussed, is permeable to benzene.   This would lead to artificially
  higher emissions being measured during the  EPA series than would normally
  be expected from a typical  field tank.   During tests done on the same
  roof for the 2519 series the roof fitting openings that would not normally
  exist in the field were sealed by welded metal  seals not  permeable to
  benzene.   This procedure would yield measured emissions more representative
  of emissions from a typical  field-located tank.
       Also during the EPA series,  the bolted noncontact  internal  floating
  roof was  tested with shingled  (i.e.,  noncontiguous)  primary and  secondary
  seals,  which are not as  effective in reducing emissions as  the more
  typical  continuous  wiper or  foam-filled  resilient seals.  This again
  would lead to  higher emissions  being measured during the  EPA series.
  Either  wiper or foam-filled  resilient  seals were  tested during the other
  test series.
       Other physical  mechanisms  that  could explain  the higher  emissions
  in the  EPA series were sought.  The  permeability  results  in  the 2519  series
  were  examined  to ascertain if permeation of the seal  system  could be
  responsible  for  the  higher benzene emission.  As detailed in Appendix A,
  the  permeation  rate  of benzene through a typical seal fabric  (polyurethane)
 was  significantly higher than the rates at which hexane or propane/octane
 permeate.  Because there are no direct measurements of benzene permeation
 rates through an entire seal system, theoretical models were developed.
 The most reasonable model of permeation through a liquid-mounted seal
 predicts emissions of 0.0102 pound moles per day in the test tank (see
 Appendix A).  While permeation and equipment differences may explain
•some of the emission differences between the benzene test work and the
 other test work, it is not sufficient to account for the total difference.
      Another explanation of the higher emissions from floating roof
 tanks shown by the EPA series,  has to do with the  test procedures used.
 The vendor series and the 2517  series used the same test procedure as
                                  2-17

-------
the EPA series, that is, a floating roof and seal system is installed in
the pilot tank, and air is blown over the floating roof.  The air is
collected and analyzed for hydrocarbon content.  In the vendor, 2517,
and EPA series test work, the temperature of the air being blown across
the roof was uncontrolled.  During periods when the air is cold (such as
during the winter), the benzene vapor being emitted will condense during
periods when actual tests are not being run.  When a test is then begun,
the benzene vapor that condensed will be measured during the test when
it was actually emitted before the test run began.   In the case of
benzene (EPA series) this could lead to artificially higher results.  In
the case of the propane/octane mixture, the uncontrolled air temperature
is not as important to the results since this mixture is less likely to
condense in the cold air.   In the 2519 series,  the air temperature was
controlled, and no emissions differences were observed between the three
tested liquids.
     As just explained, because the 2519 series test conditions were
more controlled than during the EPA series and because of the equipment
tested (continuous versus shingled seals), this test series resulted in
more representative emission measurements.   The 2519 series was also
structured to make it possible to ascertain more accurately the relative
contributions to emissions of the various emission points (e.g., seals,
roof seams and roof fittings).   Also,  the data  obtained from the 2519
series are similar to the vendor series that tested similar roofs and
seals and used a propane/octane binary mixture.
     The higher permeability of benzene,  the difference in  equipment
tested and the differences in test procedures explain most  of,  but not
all, the higher emissions from floating roof tanks  measured during the
EPA series.   Currently, however,  there is no explanation beyond what has
already been discussed as to why benzene emissions  would be any higher
than the hexane and octane emissions measured during the tests  done in
the 2519 series.
     Since there is no reason (other than possibly  permeability, which
is addressed later) for benzene emissions (normalized for vapor pressure
and molecular weight) to be higher than hexane  and  octane emissions
during the 2519 tests,  and since  the 2519 series was conducted  with more
refined procedures and more thoroughly evaluated the emission  sources
                                 2-18

-------
 and  control techniques  for  each  source,  the Agency  has  decided  to  use
 the  data  from  this  series to  evaluate the  emission  reduction  potential
 for  various control  technologies  applied to fixed roof  and  internal
 floating  roof  tanks.  For similar reasons, the Agency has selected the
 2517 series as  the  data base  for  evaluating controls for external  floating
 roof vessels.   The  2517 tests are more extensive in terms of  equipment
 tested and, for the  same reasons  as the  2519  series, have measured
 emissions more  representative of  emissions from a typical external
 floating  roof.
      Table 2-3  compares emissions from selected floating roof tank types
 as calculated  using  data from the EPA series  and as calculated  using
 data from the  2519  and  2517 series.  It  should be noted that because of
 differences in  tested equipment and test procedures, the emissions  are
 not  strictly comparable.  However, it can be  seen that the  sharp difference
 in emissions (particularly  in terms of mass rather than percentage)
 between the equipment configurations vanished in the 2519 and 2517  test
 series.  Making the  decision that the 2517 and 2519 test series are
 superior to the EPA  test series meant that it was then necessary to
 reexamine baseline impacts and effectiveness of control techniques  for
 benzene storage vessels.
     The Agency examined the emission points from possible baseline tank
 types and possible control  technologies.   As explained in the Volume I
 BID  there are four types of tanks  that could be used to store benzene.
 These are:
     1.   Fixed roof tanks;
     2.   Noncontact internal  floating roof tanks;
     3.   Contact internal  floating roof tanks;  and
     4.   External floating roof tanks.
 Based on the 2519 test series, there is  no inherent difference between
contact and noncontact deck types.  Analysis of the data concluded that
deck seams emit at the same  rate  if they are in contact with the liquid
or saturated vapor.   Contact decks may be welded (i.e.,  no deck seams)
or bolted (e.g., mechanically  connected  panels or sections that have
seams).   A bolted contact  deck would have deck seam emissions at the
same rate per foot of deck  seam as a noncontact  deck.   Because of this,
for the purpose of evaluating  control  efficiencies  the  two types of
                                 2-19

-------
        Table 2-3.   COMPARISON OF EMISSIONS AS CALCULATED FROM THE EPA
                        SERIES AND THE 2519/2517 SERIES
           Tank type/equipment
                                                             Test series
   EPA        2517/2519
emissions     emissions
 (Mg/yr)       (Mg/yr)
 I.   Internal Floating Roof

     A.   Bolted deck with vapor-mounted
         primary and secondary seals

     B.   Welded deck with liquid-mounted
         primary seal

     C.   Welded deck with liquid-mounted
         primary and secondary seals

II.   External Floating Roof with
     Mechanical Shoe Primary Seal
  3.56J
  1.15
  0.67
 Both primary and secondary seals were shingle design.

"All  seals were continuous.
0.42'
0.38
0.34
A. Primary seal only
B. With rim-mounted secondary
6.99
2.63
1.11
0.087
                                    2-20

-------
 internal  floating roofs were merged into the general  classification of
 internal  floating roof.   This procedure reduced the basic starting cases
 to  three  tank types:   fixed roof,  internal  floating roof (bolted deck
 assumed),  and external  floating roof.
      The  mechanisms  of  fixed roof  tank and  external  floating roof tank
 emissions  have been  fully discussed in the  Volume I  BID.   Although the
 external  floating roof  tank emission factors have changed based on the
 2517  series,  the  emission mechanisms are still  the same.   Fixed roof
 tank  emissions have  not changed since  proposal.
      The  2519 series  allows for a  more detailed breakdown of internal
 floating  roof tank emissions into:
      1.    Standing storage losses,  consisting of:
           a.   Rim seal  emissions;
           b.   Fitting losses;  and
           c.   Deck seam emissions
      2.    Working losses.
 Table 2-4  presents losses  from a model  benzene  storage vessel by  point
 of  loss, and  Table 2-5  compares emissions from  various selected tank
 configurations.   The  model  tank, used  in these  calculations  and all
 subsequent calculations  in  this section, has a  volume of  606 m3
 (160,000 gallons), a  diameter  of 9.1 m  (30  feet),  and undergoes
 50  turnovers  per  year.
      Internal  floating  roofs are typically  bolted  decks equipped with
 vapor-mounted  seals and  Case A fittings  (defined below).    In the model
 tank, emissions from  the vapor-mounted  seal  are about 35  percent of
 total emissions.  Emissions  from the vapor-mounted seal could be reduced
 through the use of a  liquid-mounted primary  seal,  a secondary seal,  or
 both.   A liquid-mounted  seal reduces emissions  from the vapor-mounted
 primary seal by about 55 percent.  The addition of a secondary  seal  to
 the vapor-mounted primary seal would reduce emissions by  about  63 percent.
The addition of a secondary seal to a liquid-mounted primary seal reduces
emissions by about 46 percent over the liquid-mounted primary seal
alone.  Converting a vapor-mounted primary seal  system to a liquid-mounted
primary seal with a secondary seal  reduces emissions from the seal area
by about 76 percent over the vapor-mounted primary seal  alone.
                                 2-21

-------
                             Table 2-4.   INTERNAL  FLOATING  ROOF  TANK  EMISSIONS  BY SOURCE"
ro
ro
ro
Seal
Type
Vapor-mounted
Liquid-mounted
Vapor-mounted
with secondary
Liquid-mounted
with secondary
losses
Emission
(Mg/yr)
0.19
0.085
0.071
0.046
Fitting losses
Emission
Case (Mg/yr)
A2 0.26
B3 0.16
C4 0.19

Deck losses
Emission
Roof type (Mg/yr)
Bolted 0.06
Welded 0.0


Working losses
Emission
(Mg/yr)
0.03



        Tank Parameters:
Volume = 160,000 gallons
Diameter = 30 feet
Turnovers = 50 turnovers per year
        "Case A assumes:   (1) access hatch, with ungasketed, unbolted cover; (2) automatic gauge float well,
        with ungasketed,  unbolted cover; (3) built-up column wells, with ungasketed sliding cover; (4) ladder
        well, with ungasketed sliding cover; (5) adjustable roof legs; (6) sample well with slit fabric (10%
        open area); (7) 1-inch diameter stub drains; and (8) vacuum breaker with, gasketed weighted mechanical
        actuation.
        Case B assumes:  (1) access hatch, with gasketed, bolted cover; (2) automatic gauge float well, with
        gasketed, bolted cover; (3) pipe column with flexible fabric sleeve seal; (4) ladder well, with
        gasketed sliding cover; (5) adjustable roof legs; (6) sample well with slit fabric (10% open area);
        (7) 1-inch diameter stub drains; and (8) vacuum breaker, with gasketed weighted mechanical actuation.

        Case C is identical to Case B except that built-up columns with gasketed sliding covers are assumed
        instead of pipe columns.

-------
       Table 2-5.  EMISSIONS FROM A TYPICAL BENZENE STORAGE VESSEL
        Tank type/equipment                             Emissions (Mg/yr)


 I.   Fixed Roof                                               9.2

II.   Internal Floating Roof

     A.   Bolted deck, vapor-mounted                           0.54
         seal,  Case A fittings

     B.   Bolted deck, liquid-mounted                          0.44
         Case A fittings

     C.   Bolted deck, liquid-mounted                          0.34
         seal,  Case B fittings

     D.   Bolted deck, liquid-mounted                          0.30
         primary with secondary, Case B
         fittings

     E.   Welded deck, liquid-mounted                          0.24
         primary with secondary, Case B
         fittings

III.  External Floating Roof

     A.   Mechanical Shoe Primary Seal                         1.11
         1.   Primary seal  only
         2.   With rim-mounted secondary                       0.087

     B.   Vapor-mounted Primary Seal                            6.9
         1.   Primary seal  only
         2.   With rim-mounted secondary                       2.31

     C.   Liquid-mounted Primary Seal                          0.36
         1.   Primary seal  only
         2.   With rim-mounted secondary                       0.080
                                 2-23

-------
      The  next major  source of  internal  floating  roof tank emissions  are
 losses  from  fittings.   Fittings  in general are ancillary equipment such
 as  hatches or column wells that  penetrate the deck.  Such penetrations
 will  emit benzene.   Typical fittings are:  (1) access hatch, with
 ungasketed,  unbolted cover; (2)  automatic gauge  float well, with
 ungasketed,  unbolted cover; (3)  built-up column  wells, with ungasketed
 sliding cover;  (4) ladder well,  with ungasketed  sliding cover;
 (5) adjustable  roof  legs; (6)  sample well with slit fabric (10% open
 area);  (7) 1-inch diameter stub  drains; and (8)  vacuum breaker with,
 gasketed  weighted mechanical actuation.  This equipment is referred to
 as  "Case  A".  In the model tank, emissions from  Case A fittings account
 for about 48 percent of total  emissions.  Emissions from Case A type
 fittings  could  be reduced through the use of gaskets, bolting covers,
 and constructing pipe columns with flexible fabric sleeve seals on the
 column well  in  place of built-up columns equipped with ungasketed sliding
 covers  in the column wells.   This configuration  of fittings is referred
 to as Case B and is the level of control that could be obtained in new
 benzene storage vessels equipped with internal floating roofs.
 Specifically, "Case B" is defined as:  (1) access hatch, with gasketed,
 bolted cover; (2) automatic gauge float well,  with gasketed,  bolted
 cover; (3) pipe column wells with flexible fabric sleeve seal;  (4) ladder
well,  with gasketed sliding cover; (5) adjustable roof legs;  (6) sample
well with slit  fabric (10% open area); (7) 1-inch diameter stub drains;
and (8) vacuum  breaker, with gasketed weighted mechanical  actuation.
Case B fittings would reduce emissions from the typical  fittings Case A
by about  38 percent.
     Existing internal floating roof benzene tanks typically use built-up
columns to support the fixed roof.   Such vessels could not be equipped
with pipe columns without replacing the columns.   In most instances,
this would be equivalent to requiring the construction of a new tank.
Therefore, an intermediate control  strategy was sought.   Emissions from
built-up  column wells could be controlled by gasketing the sliding
cover.  This strategy is referred to as "Case  C"  and represents the
level  of  fitting control available in existing internal  floating roof
tanks.
                                 2-24

-------
       Specifically,  Case C is identical  to Case B except that built-up
  columns with gasketed sliding covers are assumed instead of pipe columns.
  Case C fittings would provide about a 27 percent emission reduction over
  Case A fittings.  Because most existing fixed roof benzene tanks are
  equipped with built-up columns,  Case C  represents the level  of control
  of fitting emissions  generally available for existing tanks.
       The next source  of internal  floating roof tank emissions are deck
  seams.   Decks that  are constructed  of sections bolted together have
  emissions along the seam.   As discussed previously,  seams emit at the
  same rate if they are in contact  with the liquid surface (contact deck)
  or contain a saturated vapor on one side (noncontact deck).   Because of
  this fact,  the  distinction  between  contact  and noncontact decks  has been
  dropped,  and these  decks are now  referred to  as  "bolted"  for  emission
  purposes.   Emissions  from the deck  seams  in  the  model  tank are about
  11 percent of total emissions.
       Deck seam  emissions could be controlled  by  installing decks  that
  have no  seams.  Such  decks  are generally  made  out  of  steel sections
  welded together.  These  decks are generally  in contact with the  liquid
  surface,  and  are referred to  as "welded"  for  emission purposes.
       The  last emission type  in an internal floating roof  tank  is  the
  working  loss.  These  losses  are fully discussed  in the Volume  I BID  and
  account  for about 6 percent  of typical  losses.  No controls for working
  losses are available.
      As Table 2-5 shows, fixed roof tank emissions could be reduced by
  about 94 percent by the  installation of internal floating  roofs.  Emissions
  could be further reduced through the use of additional controls on
  seals, fittings, and deck seams.
      Emissions from  external floating roofs could be reduced by the
 addition of a secondary seal over the primary seal.  In the case of the
 mechanical shoe primary seal, this would reduce emissions by about
 92 percent.  Emissions from vapor-mounted primary seals could be reduced
"by replacing these seals with mechanical shoe seals or liquid-mounted
 primary seals alone  or further reduced with  secondary seals.
      In examining the  effectiveness  of the control  techniques  based on
 the 2519 and 2517 test series, it  was noted  that the emission  reductions
 for these techniques based on the  2519 and 2517 test series are quite
                                  2-25

-------
 different than those calculated at proposal.   For example,  the 2519 series
 showed that the control  effectiveness  of an internal  floating roof (of
 any type) in a fixed roof  tank is  much more effective in  reducing  emissions
 than was  believed at proposal,  based on the EPA  test  series.   On the
 other hand,  the 2519 test  series showed that a secondary  seal  in an
 internal  floating roof tank  is  much less  effective in reducing emissions
 than believed at proposal  based on the EPA  test  series.   This  is to be
 expected  because the internal  floating roof is more effective  than
 believed  previously  and  as a result, there  are less residual  emissions
 to  be controlled by  the  secondary  seal.   The  2519  test  series  showed
 that contact and noncontact  roofs  are  equally effective in  reducing
 emissions.   The 2519 test  series also  showed  that  liquid-mounted seals
 are  more  effective in reducing  emissions  than vapor-mounted seals.    This
 type of seal  can be  used with both  contact  and noncontact roofs and was
 considered as  a control technique.   Furthermore, the  2519 series showed
 that control  of roof fittings,  column  wells,  and roof deck  seams does
 reduce emissions.  Using the 2517  and  2519  data  in combination shows
 that external  floating roofs can, when  used with effective seals,  reduce
 emissions as  effectively as  internal floating  roofs.
      As briefly  mentioned previously,   there is an additional source  of
 emissions that  has not been  fully considered  up to this point.  This is
 the  permeability of  seal  systems and gaskets to benzene.  The 2519
 series and the  open  literature point to the fact that aromatics such as
 benzene have  higher permeability rates through polymers than some other
 types of compounds.  Because no direct measurements of seal  permeability
 are available, the Agency examined  this emission source by developing
 theoretical models.
     These models represented:
     1.   A foam-filled liquid-mounted seal;
     2.   A wiper type,  vapor-mounted  primary seal; and
     3.   Each of the above with a  wiper type secondary seal.
     Each seal consists  of two parts:
     1.   Two layers  (top and bottom)  of seal fabric;  and
     2.   Open cell foam  situated between the fabric layers.
     In selecting the fabric  layers for modeling, it was discovered that
there was little data on  what fabrics  are actually in  use, and little
                                 2-26

-------
 data on measured  fabric  permeability rates.   Because the Agency had
 permeability  measurements  on  0.037 inch  thick polyurethane-coated nylon
 fabric  from the 2519  tests, and because  this  material  is currently in
 use  in  field  tanks, the  Agency decided to  use this  material  as  the
 fabric  in  the models.
      In modeling  the  open  cell  foam it was assumed  that the  foam presented
 no permeability barrier.   Transport between the  fabric  layers was assumed
 to be diffusion (it was  assumed that the foam did not  allow  convective
 transport).   These models  done on  a 20 foot diameter tank are contained
 in Docket  Item IV-A-1.   For the purpose  of comparability to  the model
 tank (30 foot diameter)  emissions  the results have  been extrapolated  to
 the  model  tank.
      Table 2-6 compares  the convective losses presented in Table 2-4
 with the calculated permeability losses.   It  is  seen that permeation  may
 account for more  than 50 percent of seal losses  if:
      1.    The permeation rates  are  correct; and
      2.    The models  realistically  represent  actual  systems.
      Table 2-7 examines  how consideration  of  permeability affects  the
 overall  effectiveness of controls compared  to a  fixed roof tank.   The
 reduction  in  overall effectiveness  when  permeability is  considered  is
 less  than  3 percent.
      However,  the Agency examined how permeability  emissions may  be
 controlled.   These emissions could  be controlled by  a seal permeability
 specification.  Such a specification would  limit permeability emissions
 to a  specified limit per unit area  of seal.   However, the  variation in
 measured values in open literature  indicate that such measurements would
 be difficult  to make reliably.   Seal materials must withstand abrasion
 and  flexing as the floating roof moves.   At this point  in  time,  the
 Agency  is  aware of no materials  or  laminar composites that would have
 both  the necessary characteristics  of material strength  and permeation
 rates lower than the modeled fabric.  Such a  specification could be made
with  additional research on materials.
     Table 2-8 shows revised baseline emissions based on the revised
emission equations for each of the four model  plants developed during
proposal.  Table 2-9 shows  revised baseline nationwide emission  estimates
based on the revised emission  equations.
                                 2-27

-------
      Table 2-6.  COMPARISON OF CONVECTIVE AND PERMEABILITY LOSSES
       FROM INTERNAL FLOATING ROOF SEAL SYSTEMS IN THE MODEL TANK
  Seal type
                                       Emissions (Mg/yr)
Convective
  Modeled
permeation
Possible
  total
 losses
Vapor-mounted

Liquid-mounted

Vapor-mounted
with secondary

Liquid-mounted
with secondary
   0.19

   0.085


   0.071


   0.046
   0.21

   0.20


   0.11


   0.10
  0.40

  0.285


  0.181


  0.146
                                 2-28

-------
    Table 2-7.  MODEL TANK EMISSIONS (Mg/yr) FROM A FIXED ROOF TANK
                AND A TYPICAL INTERNAL FLOATING ROOF TANK
      Tank type
Emission
Percent control
Fixed roof
Internal floating roof with
9.2
0.54
94.1
bolted deck, Case A fittings,
vapor-mounted primary seal
only, no permeability

Internal floating roof with
bolted deck, Case A fittings,
vapor-mounted primary seal,
permeability
   0.75
     91.8
                                 2-29

-------
      Table 2-8.  EMISSIONS FROM NEW AND EXISTING
                     MODEL PLANTS
Tank dimensions
(meters x meters)
Large benzene producer
12 x 9
18 x 12
8x5
9x9
13 x 13
24 x 9
27 x 15
Total
Small benzene producer
3 x 11
13 x 13
8 x 11
32 x 7
Total
Benzene consumer
12 x 11
18 x 15
Total
Bulk storage terminal
12 x 11
18 x 15
Total
Emissions
Existing

0.72
2.19
0.48
0.59
0.68
1.36
1.82
7.84

1.27
0.68
0.50
2.17
4.61

0.64
0.97
1.61

0.64
0.97
1.61
(Mg/y)
New

0.72
0.13
0.48
0.59
0.68
1.36
1.82
5.78

1.27
0.68
0.50
2.17
4.61

0.64
0.97
1.61

0.64
0.97
1.61
aDiameter x height.
                        2-30

-------
     Table 2-9.  NATIONWIDE EMISSIONS FROM NEW AND
            EXISTING BENZENE STORAGE TANKS
                                   Emissions (Mg/y)
      Model plant               Existing          New3


Large benzene producer             269             55

Small benzene producer             192             53

Benzene consumer                   152             42

Bulk storage terminal                8              2

Total                              621            152

aFifth-year (1988).
                       2-31

-------
 2.2.3  Exposure Assessment
      A number of commenters (IV-D-1, IV-D-3, IV-D-4, IV-D-10, IV-D-lOa,
 IV-D-13, IV-D-21, IV-F-1) stated that the model plant methodology used
 by the EPA overestimates risk from benzene exposure.  The commenters
 suggested that a more realistic and accurate risk estimate would be
 obtained using actual plant emission data, actual population data, and
 available plant-specific emission data.
      One commenter (IV-D-lOa) maintained that the Agency's benzene
 emissions exposure analysis relied upon incomplete and inaccurate
 meteorologic data.   Rather than use site-specific climatological data as
 required by the Agency guidelines, the commenter remarked that the
 analysis relies entirely on conditions at the Gulf Coast to apply to
 storage vessels throughout the nation.
      According to the commenter, the EPA concedes that this assumption
 causes an overstatement of estimated exposure,  noting its data were
 "representative of poor dispersion conditions in the area in order to
 develop a potential  worst-case situation".   He  concluded that since
 climatological data for approximately 300 sites throughout the U.S.  are
 available in the Agency archives,  the EPA's total reliance on Gulf Coast
 meteorology was not justified.   The commenter also stated that the EPA
 arbitrarily oriented the benzene storage vessels of a hypothetical
 facility in order to maximize the  ambient concentrations at the plant
 boundary.   According to the commenter,  this was done despite the fact
 that the actual  storage vessels are not  usually arranged in a straight
 line configuration.
      The commenter  further asserted that the EPA failed to validate the
 results of its air  quality modeling as  a check  on its accuracy,  as
 required by Agency  guidelines.   According to the commenter,  in this
 exposure analysis,  the EPA repeatedly has relied upon unsupported
 assumptions about emissions,  meteorology, population distribution,  and
 other factors, even  though accurate data were readily available.   The
'approach taken results in an  unacceptably high  degrees  of uncertainty in
 the  Agency's exposure estimates;  in some instances,  the exposure estimate
 may  be off by a factor of 100 or more.
      Response:   The  commenter is correct in noting that the benzene
 storage risk assessment did not make use of plant-specific data  relating
                                  2-32

-------
 to emissions, meteorology, or plant configurations.  However, as explained
 below, the plant-specific approach probably would not improve the precision
 or accuracy of the results enough to justify the level of effort to use
 more specific data.  EPA has concluded that a plant-specific approach
 would be too costly and not necessary for benzene storage emission
 sources.  In response to this comment, the EPA has revised its original
 risk assessment for benzene storage vessels:   the unit risk factor has
 been recalculated; new emission estimates have been developed based on
 the new API data; the meteorology of the area where each plant is located
 has been used; and an improved population model (Human Exposure Model)
 has been used.
      The EPA considered the option of using plant-specific data for all
 parameters in order to run an exposure model  for each plant.   The EPA
 compared the uncertainty that would result using the plant-specific data
 approach with the uncertainty that would result using the model plant
 and extrapolation approach.   The EPA also compared the level  of effort
 that would be required to complete the two options.
      The plant-specific approach probably would not improve the precision
 or accuracy of the results enough to justify  the level of effort required
 to gather the input data.   A plant-specific approach would entail using
 "Section 114" letters to gather plant information on emissions, meteorology,
 and plant configuration from about 130 plants.   This would require
 substantial  effort from plant owners as well  as from the EPA.   The
 dispersion and exposure models would then have to be run about 130 times,
 at least once for each plant.   The resultant  increase in precision and
 accuracy would probably be small  compared to  the uncertainty  still
 remaining that is inherent in the dispersion  and exposure models and in
 the input data used.   Both the Industrial  Source Complex Long Term
 computer model (ISCLT) and the Human Exposure Model,  even with perfect
 input data,  are subject to substantial  uncertainty.   (The ISCLT model,
 even with state-of-the-art input data,  is  estimated to have a 95 percent
'confidence interval  of plus  or minus a factor of two.)  The plant-specific
 input data would also exhibit wide variability and thus  introduce
 uncertainty in the results of the study.
      The Agency has not exaggerated the precision of the results of the
 model  plant  extrapolation  method,  nor has  the EPA attempted to refine
                                  2-33

-------
 the results of the model plant extrapolation method any more than is
 warranted by the quality of the data and the modeling technique.
 Uncertainties are clearly delineated.  The results are presented in
 highly aggregate, nonspecific terms, in a fashion that exhibits much
 less uncertainty than if the EPA tried to obtain more detailed, refined
 results from the extrapolation.  Using the model plant extrapolation
 method, inaccurate deviations in the results for specific plants tend to
 average out when the total national incidence is computed.  Attempting
 to validate the results of the air quality modeling would require an
 extremely detailed, burdensome, and costly plant-specific approach.
 Because a plant-specific approach would be very costly and would not
 substantially improve upon the precision and accuracy already achieved
 by the model plant extrapolation approach, the EPA has elected to use
 the model plant extrapolation approach.
      Comment:   One commenter (IV-D-lOa)  added that deficiencies exist in
 the population concentration estimates contained in the exposure analysis.
 According to the commenter,  the EPA assumed that population is distributed
 uniformly in all  directions  at each site,  which introduces an uncertainty
 factor of 10 to 100 into the overall  exposure estimate.
      Response:   EPA's revised risk estimate (see Appendix B) was based
 upon a more sophisticated population exposure model,  which utilized  a
 population data base characterized as having a high level  of resolution.
 The Human Exposure Model (HEM) was used  to estimate the population that
 resides in the vicinity of each receptor coordinate surrounding each
 plant.   The HEM does not assume population is distributed evenly around
 each plant.   The  population  "at risk" to benzene exposure was considered
 to be persons  residing within 20 km of the plants.   The population
 around each plant was determined by specifying the geographical  coordinates
 of that plant.
      A slightly modified version of the  "Master Enumeration District
 List—Extended (MED-X)"  data base,  a Census Bureau data base, is contained
"in the HEM and used for population pattern estimation.   This data base
 is broken down into enumeration district/block group  (ED/BF) values.
 MED-X contains the population centroid coordinates (latitude and longitude)
 and the 1970 population of each ED/BG in the United States (50  states
 plus the District of Columbia).   For human exposure estimations,  MED-X
                                  2-34

-------
  has been  used to produce a randomly accessible computer  file of only  the
  data necessary for the exposure estimation.  A separate  file of county-
  level growth factors, based on the 1970 to 1980 growth factor at the
  county  level, has also been created for use  in estimating 1980 population
  figures for each ED/BG.
      The  plant's geographical coordinates and the concentration patterns
  computed  by the model plant extrapolation method were used as input to
  the HEM.  For each receptor coordinate, the  concentration of benzene  and
  the population estimated by the HEM to be exposed to that particular
  concentration are identified.  The HEM multiplies these  two numbers to
  produce population exposure estimates and sums these products for each
  plant.  A two-level scheme has been adopted  in order to  pair concentrations
  and populations prior to the computation of  exposure.  The two-level
  approach  is used because the concentrations  are defined  on a radius-azimuth
  (polar) grid pattern with nonuniform spacing.  At small  radii, the grid
  cells are much smaller than ED/BG's; at large radii, the grid cells are
  much larger than ED/BG's.   The area surrounding the source is divided
  into two regions, and each ED/BG is classified by the region in which
  its centroid lies.   Population exposures are calculated  differently for
  the ED/BG1s located within each region.
      For ED/BG centroids located between 0.1 km and 2.8  km from the
  emission source,  populations are divided between neighboring concentration
  grid points.   There are 96 (6 x 16) polar grid points within this  range.
  Each grid point has a polar sector defined by two concentric arcs  and
  two wind direction radials.   Each of these grid points is assigned to
  the nearest ED/BG centroid identified from MED-X.   The population
 associated with the ED/BG  centroid is then divided among  all  concentration
 grid points assigned to it.   The exact land area within each polar
 sector is considered in the apportionment.
      For the  population centroids  between  2.8 km and 20 km from  the
 source,  a concentration grid cell, the area approximating a rectangular
•shape  bounded by  four receptors,  is much larger than the  area  of a
 typical  ED/BG (usually 1 km in diameter).   Since  there is a linear
 relationship  between the logarithm of concentration  and the logarithm of
 distance for  receptors more  than  2 km from the  source,  the entire
 population of the ED/BG is  assumed to be exposed  to  the concentration
                                  2-35

-------
that is geometrically interpolated radially and azimuthally from the
four receptors bounding the grid cell.  Concentration estimates for 80
(5 x 16) grid cell receptors at 2.0, 5.0, 10.0, 15.0 and 20.0 km from
the source along each of 16 wind directions are used as reference points
for this interpolation.
     In summary, two approaches were used to arrive at coincident
concentration/population data points.  For the 96 concentration points
within 2.8 km of the source, the pairing occurs at the polar grid points
using an apportionment of ED/BG population by land area.   For the remaining
portions of the grid, pairing occurs at the ED/BG centroids themselves,
through the use of log-log linear interpolation.
     Comment:  A commenter (IV-D-lOa) stated the analysis failed to
account for population activity patterns and population mobility, thereby
overestimating exposure levels for persons residing in the affected area
surrounding these plants.   He further criticized the EPA's estimate of
"maximum individual lifetime risk" by noting that the Agency has no
evidence that any individual ever lives an entire lifetime 0.1 kilometers
from the plant at a point of maximum benzene concentration.
     Response:  The maximum individual lifetime risk, as  the commenter
understood, is the risk associated with exposure to the maximum
concentration.  Maximum concentrations are only modeled estimates and
may overestimate or underestimate the actual concentrations.   As discussed
in Docket Item IV-B-4, the maximum concentrations and,  consequently, the
maximum individual lifetime risks (which were estimated and used to
make,  to the limited extent they were used,  decisions)  appear to be
underestimates.   Provided the air at 0.1 kilometer from plant is located
in a neighborhood, the opportunity for exposure exists.   Using the HEM,
exposures to maximum concentrations are generally limited to distances
greater than 0.2 kilometer and to locations  where people  reside.   In the
absence of perfect information regarding the magnitude  and duration of
exposure, it is prudent to assume that, as a "maximum",  an individual
could face continuous exposure to a maximum  concentration.
     Comment:  One commenter (IV-D-19) felt  that the EPA  had understated
the risk of exposure to benzene storage emissions.   According to one
commenter,  the scientific knowledge necessary for reasonably reliable
and precise estimates of human cancer risks  simply is not available.
                                 2-36

-------
  The commenter felt that,  given interactions and synergisms,  it is much
  more likely that exposure to multiple chemicals will  have an additive or
  multiplicative effect than that such chemicals will  cancel  each other
  out.   This commenter cited many sources  of uncertainty in the risk
  assessment and concluded  that the EPA may have drastically  understated
  the real  leukemia risk associated with benzene.   According  to the commenter,
  the estimates given by the EPA may well  underestimate the health benefits
  of the increment between  the proposed requirements and use  of vapor
  recovery  or thermal  destruction of emissions.   He added that it is
  unacceptable that the noncarcinogenic effects  of benzene exposure have
  virtually dropped out of  the EPA's analysis due to the fact  that they
  cannot be readily quantified.   According  to the commenter, the  proposal
  makes  no  efforts  to  see that these effects  get appropriate weight in  the
  decision  to stop  short of more stringent  regulatory alternatives.
      Response:  While the commenter may be  correct that interactions  and
  synergisms  (resulting from exposures  to multiple  chemicals)  may  be
  additive  or multiplicative (or antagonistic) and  therefore result in
  truly  greater  (or smaller)  risks  to  persons  exposed to  benzene,  EPA is
  unable  to estimate these  effects  and,  therefore,  has  not  considered
  them.   It should  be  noted  that many  of the  factors used  in making  the
  exposure  assessment  have  uncertainties associated with  them  and  that
  these  uncertainties  can result  in  underestimation as well as overestimation.
  These uncertainties  are described  in a previous response  (2.1.2)  and
  have been considered  as much as is practicable by EPA in  the decision to
 withdraw the proposed  standards.
      Comment:  A commenter (IV-D-19) noted that the EPA assumed that
 many benzene-emitting  facilities have a life expectancy of 50 years or
 more.  Yet the quantifications of risk used to compare the proposed
 approach with a more protective one, assume a 20-year lifetime.   According
 to the commenter, this understates the number of benzene victims for
 such facilities by two and one-half times or more, and reconsideration
'of the decision not to adopt Alternatives IV or V (at proposal) with the
 appropriate health effects timeframe may  lead to a different decision
 (IV-D-31).
      Response:   Twenty years is an average figure for the lifetime of  a
 plant.   Some plants have a life expectancy of 50 years; some  have lifetimes
                                  2-37

-------
 shorter than 20 years.   Roughly,  a plant will  have a lifetime of 20 years.
 Since there are little  data available that estimate plant lifetimes,  the
 EPA considers 20 years  to be a reasonable estimate.   However,  the EPA
 agrees there is uncertainty associated with this  number.
 2.2.4  Risk Methodology Consistency
      Comment:   A number of commenters (IV-D-lOa,  IV-D-4,  IV-F-1)  stated
 that there  should be  some consistency in risk  assessment  methodologies
 between the four current benzene  proposals.  One  commenter  stated that
 if  benzene  is to be regulated by  a NESHAP standard,  the emission  concerns
 and risk/benefit analysis should  be completed  for all types of emissions
 (e.g.,  process  emissions,  storage tank emissions,  fugitive  emissions,
 etc.) simultaneously.   This  integrated analysis,  the  commenter maintained,
 would prevent duplication of  effort,  errors, or inconsistencies and
 result  in an  overall  analysis  of  the  risk/benefit  of  a product.   According
 to  another  commenter1s  (IV-D-21)  review of  the four current benzene
 proposals,  a  great deal  of duplication has  occurred with  little or no
 health  benefit  to the public.
      Response:   The risk  assessment methodologies  used in evaluating the
 four  source categories  for which  benzene  standards have been proposed
 have  been made  more consistent.   The  only area in which they are  different
 is  that the affected  industries voluntarily submitted detailed plant-
 specific information on the maleic anhydride and ethylbenzene process
 vents.  Obtaining this  kind of information  for the 126 or more plants
 that  have benzene fugitive and storage  sources would be too costly
 (considering the uncertainty of the final results either way) for the
 industry or the  EPA to obtain.  Because of the detailed information
 available on maleic anhydride and ethylbenzene/styrene process vents and
 the relatively  small  number of these plants, the more precise ISC
 dispersion model was  used for all  those plants and the SAI model  was
 used for the benzene  storage and benzene fugitive plants.   However, the
 ISC model was used for a few plants with benzene storage and fugitive
emissions to compare  the results of that model  with the SAI model.  For
plants containing multiple sources, the same meteorological  and population
data were used for each  plant each time the risks were calculated for
one of the sources in that plant.
                                 2-38

-------
              APPENDIX A
EMISSIONS SOURCE TEST DATA AND ANALYSIS

-------
           APPENDIX  A - EMISSIONS  SOURCE  TEST  DATA AND  ANALYSIS

      This  appendix  provides  a  summary  description of the  emission  tests
 conducted  on  internal  floating roof  (IFR) tanks and the major results.
 For  additional  and  complete  information, refer to the  referenced reports.
 A.I   TEST  PROCEDURES
      All emissions  test measurements were obtained by  Chicago Bridge and
 Iron  Company  (CBI)  under contract to the American Petroleum Institute.1
 The test program was  divided into two  broad components:   pilot tank test
 measurements  and internal floating roof tank  component measurements.
 The primary goal of the pilot  tank tests was  to determine emissions from
 IFR seal systems and  deck seams; while the purpose of the IFR component
 tests was to  determine emissions from  IFR fittings (hatches, ladder
 wells, etc.)  and to  investigate other  issues  such as the permeability of
 seal  systems  to the  stored hydrocarbon.
 A.1-1  Pilot  Test Tank Emission Measurements
     A. 1.1.2  Description of Test Facility.   The tests were performed in
 a test IFR tank at  CBI's research facility in Plainfield,  Illinois.  The
 test tank was 20 feet in diameter and had a 9-foot shell height (see
 Figure A-l).   The lower 5'3" of the tank shell was provided with a
 heating/cooling jacket through which a heated or cooled water/ethylene
glycol mixture was continuously circulated to control  the product
temperature.   The effect of air blowing through the shell  vents  was
simulated by means of a blower connected to  the tank by a  12-inch diameter
duct.   This air exited from the tank through a similar duct.
     Based on wind tunnel  tests, it has been possible  to determine the
pressure coefficient, C ,  variation over the exterior  surface  of the
tank.   The air flow rate through the vents  over the internal  floating
roof was then related to C   by means of a mathematical  model.1  Thus,
                                 A-2

-------
                      .Inlet
                      Concentration
             Outlet
             Concentration
 Air
Heater
                                  .Outlet
                              T)  Damper
                                                 Mixing
                                                 Section
                                   Shell
                                   Heating
                                   Panel
 Air Blower
    Propane
    P - Pressure
    T - Temperature
    F - Flow
    S - Sample
                                                                     Glycol
                                                                       Pump
Product
Circulation
Pump
Stripper
 Tower
                   Figure A-l.  Process and instrumentation schematic.
                                                    1

-------
 internal  air flow could  be  related  to  ambient wind  speed emissions.
 During  each  test,  emissions were  measured  at  several  equivalent  ambient
 wind  speeds.   The  recorded  data included the  inlet  and  outlet  total
 hydrocarbon  content,  system temperatures,  and the inlet air  flow rate.
      A.1.1.3  Pilot Test Tank  Internal  Floating  Roofs and Liquids.
 Tests were conducted  in  three  IFR types, and  three  seal  systems.  The
 first IFR tested  (Phase  1, 1R) was  a bolted noncontact  IFR,  equipped
 with  a  wiper type  primary seal, and on  some tests a secondary  seal
 (Figures  A-2 and A-3).   In some tests gaps were  intentionally  placed
 between the  seal and  the tank  shell.  Seal gaps  were either  of 1  or
 3  square  inches of gap per-foot-of-tank-diameter.   In some instances,
 0.020 inch thick polyurethane-coated nylon fabric,  which  was taped in
 place using  aluminum-backed duct  tape, was used  to  seal off  certain
 emission  sources.
      The  second IFR tested (Phase 2, 2R) was  a welded contact  IFR equipped
 with  a  liquid-mounted, foam filled  seal (Figures A-4 and  A-5).  As in
 Phase 1,  a secondary  seal was  in  place during some  tests; the  effects of
 seal  gaps on  emissions were investigated; and emission areas were sealed
 during  some  tests.
      The  final IFR (Phase 3, 3R) was a bolted contact type deck, equipped
with  a  vapor-mounted, foam-filled primary seal, and (during some tests)
 a  foam-filled secondary  seal (Figures A-6 and A-7).
      In each  phase, three different test liquids were employed.  The
 test  liquids were  a propane/octane mixture, hexane,  and octane.
      During  Phase  1, the primary seal  was replaced after Test No. 13.
The primary  seal was again replaced at the beginning of Phase 1R (Test
API 73).  Each of  the primary seals had the same construction.
      The  initial Phase 1 tests indicated that emissions might vary as a
function of the inlet air-product temperature difference.  To control
for this,  a heater was installed in the inlet air duct after Test API 19.
Table A-l displays the test conditions for all Phase 1,  1R tests.
     Table A-2 displays the test conditions for the  Phase 2,  2R tests.
There was  a problem with product seepage through a thermocouple during
Tests API  35 through API 44.   However,  it was possible to correct the
results to account for this problem.  Additionally Test API 51 was
performed  at the much higher air flow rates that simulate an  external
floating roof tank.
                                 A-4

-------
                       Deck Scam
                      Clamping Bar-*
                        Location
   Fittings
1 Access Hatch
2 Column Well
3 Vacuum  Breaker
    0
Air Outlet
           Figure A-2.  Plan view of noncontact bolted IFR.
                        A-5

-------
Figure A-3.   Elevation view of noncontact bolted IFR in test tank.
                              A-6

-------
Thermocouple
Locations
 D=Deck
 L = Liquid
 SV* Sec. Vapor
 Fittings
 1  s Guide  Pole
 2 * Bleeder Vent
 3sColumn Well
 4 = Bolted Access
    Hatch
  Seal
 N
O
Rim Brace
            Figure A-4.  Plan view of contact welded IFR.
                          A-7

-------
00
      (Q
      c
      -5
      (D
       I
       tn
      a>
      <
      0)
      O
      3
      o
      n
      o
      3
      r+
      0)
      n
      CL
      a>
      a.
      3

      r+
      n>
      01
      3
                        63"	

                 Shell Heating  Panel
    46
       II
Product Level
                          l"
                        Rim
                       Heat
                       Coil
     34"

Air Plenum
                                        Roof  Elcv.
                                      108'

-------
Thermocouple
Locations

 D = Deck
 L = Liquid
PV= Pri. Vapor
SV= Sec.Vapor
                        Air Inlet
Roof Support
   Lugs
          N
         O
Deck  Panels
                                                 Seal
                    Column
                    Well ~\
     Bolted Deck
        Seams
             Figure A-6.  Plan view of contact bolted IFR.
                           A-9

-------
(Q
C
I
M
o
m

(D
<
0)
C*
o
 n
 o
 0)
 n
 CT
 O
 (D
 Q.
 Z3


 tt>
 OJ
 a
                 63"

            Shell Heating Panel
                                              Air Plenum
Rim
Heat
Coil
               Product  Level
                                       	36
                                       Roof  EI<2V.

-------
Table A-l.   SUMMARY OF TEST CONDITIONS FOR PHASE 1 AND 1R
fcl_._l_A t
Test
number
Phase 1:
API 1
API 2
API 3
API 4
API 5
API 6
API 7
API 8
API 9
API 10
API 11
API 12
New Primary
API 13
API 14
API 15
API 16
API 17
API 18
API 19
API 19A
nuw HUM
Product vapor pressure
type (psla)

C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
Seal Installed
nC8
nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8

5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
0.5
0.5
0.5
0.5

0.5
0.5
5.0
5.0
5.0
5.0
5.0
5.0
Gap area
Ort2/ffr rfl«Matav>^
n /ii. cjiameierj
Primary Secondary

0 —
0 —
0 —
0 —
0 —
0 —
1 -•- —
3 —
* 	
i —
0 —
0 (1) -

0 —
1 —
0 —
0 —
0 0
3 0
3 1
3 1 (2)
Roof components
Column
well

Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Sealed
Sealed
Sealed
Sealed
Sealed
Sealed
Sealed

Sealed
Sealed
Unsealed
Unsealed
Sealed
Sealed
Sealed
Sealed
Deck
fittings

Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Sealed
Sealed
Sealed
Sealed
Sealed
Sealed
Sealed

Sealed
Sealed
Unsealed
Unsealed
Sealed
Sealed
Sealed
Sealed
Nominal
(mi r-nrnHurt^

Deck temperature difference
seams (°F) Notes

Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed

Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed

Variable
Variable
Variable
Variable
Variable
Variable
Variable
Variable
Variable
Variable
Variable
Variable

Variable
Variable
Variable
Variable
Variable
Variable
Variable
Variable




Air product
temperature
difference
was
uncontrolled







Air product
temperature
difference
was
uncontrolled

Air Duct Heater Installed
API 20
API 21A
API 218
API 21C
API 210
API 21E
API 22A
API 228
API 2?C
API 220
API 23
•API 24
API 25
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
Variable
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
0 —
0 —
0 —
0 —
0 —
0 —
1 	
I 	
1 —
•I , 	
Sealed —
Sealed —
Sealed —
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Sealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Sealed
Sealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
0
-15
0
+15
0
Variable
-15
0
+15
Variable
0
0
0
(3)



(4)








                      (continued)

-------
                                                 Table A-l.   Concluded
ro
Test
number
API
API
API
API
API
API
API
API
API
API
API
API
API
API
API
API
API
26A
26B
27A
27B
27C
28
29
29R
30
30R
31
31A
32
33
33A
34
34A
Nominal
Product vapor pressu
type
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
nC8
nCfl
nC8
nC8
nC8
nC8
nC6
nC6
nC6
nC6
nC6
(psla)
3.5
2.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
2.5
2.5
2.5
2.5
2.5
Gap area
(InVft diameter
||~g '
Primary
1
1
1
1
1
0
1
1
0
0
1
1
0
1
1
1
1

Roof components
.\
/ 	
— — Pnlimn
^^^ liUIUfflil
Secondary well
_
—
—
—
—
—
_
—
—
—
0
0
_«.
—
—
—
—
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Deck
fittings
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Deck
seams
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Nominal
(air-product)
temperature difference
(°F)
0
0
-15
0
+15
0
0
0
0
0
0
+15
0
0
+15
0
+15

Notes






(5)

(5)








Phase 1R:
API
API
API
API
API
API
API
73
73A
74
75
76
76R
77
Notes: (I)
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
Seal closure
5.0
5.0
5.0
5.0
5.0
5.0
5.0
devices
(?). Gaps fn the secondary





(3)
(4)
(5)
(6)
(7)
Emission test
. Emission test
. Emission test
A column well
Emission test
data Is
data Is
data Is
gasket
data Is
0
0
0
3
Sealed
Sealed
Sealed
were Installed to
seal were rotated
questionable due
questionable due
questionable due
_
—
—
—
—
—
—
Unsealed
Unsealed(6)
Unsealed(6)
Unsealed(6)
Sealed
Sealed
Sealed
eliminate all unintentional
45° to
Unsealed
Unsealed
Unsealed
Unsealed
Sealed
Sealed
Sealed
gaps.
position them directly above the
to variable product temperature causing
to nonequi 1 ibritim condition
to air
inlet heater control
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Sealed

0
0
0
0
0
0
0

(7)







primary seal gaps.
nonequilibrlum
in the rim vapor space due
problems.

conditions.
to prior air purge.




was used during this test.
questionable due
to nonequilibrlum condition
of product caused by Insufficient mixing.

-------
       Table  A-2.    SUMMARY  OF  TEST CONDITIONS  FOR PHASE 2  AND 2R (1)
 Test
 number
Product
  type
   Nominal
vapor pressure
   (psla)
                                             Gap area
                                          (inVft diami
                                          ter)
                                       Primary
                                       Secondary
                                                        Roof components
Column
 well
  Deck
fittings
                                                                                        Notes
 Phase 2
API 35
API 36
API 37
API 38
API 39
API 40
API 41
API 42
API 43
API 44
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
0
1
0
0.5
3
1
0
1
3
Sealed
0
0
1
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Sealed
Sealed
Sealed
Sealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Sealed
Sealed
Sealed
Sealed
(2)
(2)
(2)
(2)
(2)
(2)
(2)
(2)
(2)
(2)
Repaired Product Seepage Through Thermocouple Fitting
API 45
API 46
API 47
API 48
API 49
API 50
API 51
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
nC8
nC8
5.0
5.0
5.0
5.0
5.0
0.5
0.5
Sealed
Sealed
Sealed
0
0
1
1
Sealed
Unsealed
Unsealed
Unsealed
Sealed
Unsealed
Unsealed
Sealed
Sealed
Unsealed
Unsealed
Sealed
Unsealed
Unsealed
(3)
(3), (4)
Phase 28
API
API
API
AD?
nri
API
API
API
API
67A
67
68
CO
oy
70
71
71A
72
Notes:





(1).
(2).
(3).
(4).
(5).
nC8
nC8
nC6
nC6
C3/nC8
C3/nC8
C3/nC8
C3/nC8
During
Product
Product



0.5
0.5
2.5
2.5
5.0
5.0
5.0
2.5
1
1
1
1
1
1
1
1



;
-
0
0
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
both Phases 2 and 2R, nominal (air-product) temperature difference
seepage through a thermocouple fitting occurred during this test.
contained trace amount of orooane.
During this test
During this test
kept constant at
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
was kept at
the air flow rate was increased to simulate an external floating roof
the inlet air and product heaters were turned off, and the wind speed
about 10 ni/hr.
(3)

(5)
zero.
was
                                          A-13

-------
     Table A-3 displays the test conditions of Phase 3 and 3R.  During
some tests product penetrated the primary seal.  The problem was repaired,
and the tests were repeated.
     Table A-4 presents the results of all relevant tests.  In summary,
it was found that an air product temperature differential of up to 15F°
had no significant effect on emissions.  Small gaps (1 inchVfeet diameter)
did not appear to affect emissions significantly.  Also, the tests
demonstrate that ambient wind (particularly at speeds less than 20 miles
per hour) has little or no effect on emissions.
     A.1.1.4  IFR Component Tests.
     A.1.1.4.1  Deck fitting emission tests.   To quantify emissions from
various types of fittings, a series of bench scale tests were performed.
These fittings were placed through the top cover of a liquid-filled
drum, and the drum was then placed on a scale.  The weight change and
other data were recorded over a 30 day period.  Figure A-8 displays a
sample bench test, and Table A-5 summarizes the results.
     A.1.1.4.2  Permeability tests.   A series of bench permeability
tests were performed to determine the permeability of the 0.020 inch-
thick polyurethane-coated nylon fabric to various hydrocarbon liquids.
One laboratory test was also performed.  Also included was a test on the
same fabric of 0.037 inch thickness with benzene as a test liquid.   This
material had been used as the seal envelop material in Phase 2 and 2R,
                         2
and in earlier test work.    The results are shown in Table A-6.
A.2  MAJOR RESULTS
     This section discusses the major results of the analysis of test
work.   Although the relationship of emission factors to the test results
is discussed,  the actual development of emission factors is presented
elsewhere.
A.2.1  Seal Losses
     Total  measured emissions in a given tank test are the sum of all of
the emission sources in that test.   Therefore, to develop an emission
factor the results must be reduced.   For example, the permeation emissions
through any sealing material, fittings, and any other source that is not
of interest must be accounted for, and subtracted out before the emissions
from the component of interest are known.   Because of this reduction
process, component emissions factors cannot be read directly from Table A-4.

                                 A-14

-------
         Table A-3.    SUMMARY  OF  TEST  CONDITIONS  FOR  PHASE 3  AND  3R  (1)
   Test
  number
Product
  type
    Nominal
vapor pressure
    (psia)
      Gap area
  (in'/ft diameter)

Primary    Secondary
                                                                      Roof components
Column
 well
Deck
seams
 Rim
plate
                                                                                                 Notes
 Phase  3
API 52A
API 528
API 52C
API 520
API 52E
API 53A
API 53B
API 53C
API 54A
API 54B
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
0
0
0
0
0
1
1
1
3
3
0
0
0
0
0
0
0
0
1
1
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
(2)
(2)
(2)
(2)
(2), (3)
(2)
(2)
(2)
(2)
(2)
 Product Liquid Removed From Primary Seal
API 52
API 52R
API 53
,API 54
^PI 55A
API 55
API 56
UP I 57
«PI 58
WPI 59
API 60
API 61
API 62
API 63
API 64
API 65
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
C3/nC8
nC8
nC6
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
2.5
0.5
0.5
2.5
0
0
1
3
Sealed
Sealed
Sealed
Sealed
Sealed
0
j
3
1
1
1
1
0
0
0
1
Sealed
Sealed
Sealed
Sealed
Sealed
-
-
-
-
-
"
Unsealed
Unsealed
Unsealed
Unsealed
Sealed
Sealed
Sealed
Sealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Sealed
Sealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Sealed
Sealed
Sealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed





(4)
(4)
(4)
(4)






Phase 3R
API 65R
API 65A
API 66
API 66R
nC6
nC6
nC6
nC6
2.5
2.5
2.5
2.5
1
1
1
1
0
0
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
Unsealed
(5)
(2)
Notes:   (1).
        (2).

        (3).
        (4).
        (5).
  During both Phases 3 and  3R, Type 1 air flow distribution was  used, the nominal  (air-product)
  temperature difference was  kept at zero,  and the roof elevation was kept at 63  inches below
  the air inlet.
  Emission test data is of  questionable value since liquid product was present in  the primary

  Column well cover intentionally positioned off center with a gap.
  All  taped joints w«r« also  caulked during this test.
  During this test the primary seal  gap plates were intentionally extended down into the
  product.
                                             A-15

-------
Table A-4.   SUMMARY OF TEST RESULTS FOR
    ALL POTENTIALLY RELEVANT TESTS


CBI test number
API-1
API-2
API-3
API-4
API-5
API-7
API-8
API-12
API-13
API-14
API-13R
API-13, 13R
API-14R
API-14, 14R
API-16
API-17
API-18
API-19
API -19 A
API-21A
API-21B
API-21C
API-21AR
API-21A, AR
API-21BR
API-21B, BR
API-21CR
API-21C, CR
API-22A
API-22BI
API-22D
API-22B
API-22BI, B
API-22C
API-21E
API-23
API-24
API-25
API-26A
API-26B
API-27A


Nominal .
true vapor pressure
(psia)
5.00
5.00
5.00
5.00
5.00
5.00
5.00
0.50
0.50
0.50
0.50
0.50
0.50
0.50
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
0.50
(continued)
A- 16
Average
emissions
Ib-mole/day
0.283
0.423
0.309
0.449
1.33
0.224
0.439
0.0181
0.0605
0.0668
0.0567
0.059
0.196
0.159
0.926
0.0698
0.110
0.134
0.147
0.101
0.0891
0.0909
0.171
0.129
0.140
0.102
0.133
0.108
0.142
0.165
0.124
0.176
0.173
0.211
0.128
0.0714
0.120
0.108
0.117
0.128
0.030



-------
Table A-4.  Continued


CBI test number
API-27B
API-27C
API-28
API-30
API-29R
API-31
API-31A
API-32
API-33
API-33A
API-34
API-34A
API-35
API-36
API-37
API-38
API-39
API-39R
API-40
API-41
API-42
API-43
API-44
API-45
API-46
API-47
API-48
API-49
API-50
API-51
API-52
API-53P
API-54
API-53
API-53P, 53
API-55
API-56
API-57
API-58
API-52R
API-52, 52R
API-59
Nominal ,
true vapor pressure
(psia)
0.50
0.50
0.50
0.50
0.50
0.50
0.50
2.50
2.50
2.50
2.50
2.50
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
0.50
0.50
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
Average
emissions
Ib-mole/day
0.0196
0.0553
0.0167
0.0316
0.143
0.0357
0.0256
0.0232
0.0306
0.0251
0.0317
0.0347
0.0366
0.0359
0.0297
0.0334
0.0492
0.0387
0.0301
0.0154
0.0176
0.0269
0.0149
0.00693
0.00928
0.0170
0.0246
0.0188
0.00426
0.0390
0.0376
0.0407
0. 0400
0.0372
0.0399
0.0156
0.0338
0.0345
0.0433
0.0435
0.0400
0.0536
(continued)
      A-17

-------
                         Table  A-4.   Concluded
CBI test number
API-60
API-61
API-62
API-63R
API-64
API-65
API-66
API-66R
API-65R
API-65A
API-67A
API-67
API-68
API-69
API-70
API-71
API-72
API-73
API-73A
API-74
API-75
API-76
API-76R
API-76, 76R
API-77
Nominal ..
true vapor pressure
(psia)
5.00
5.00
5.00
0.50
0.50
2.50
2.50
2.50
2.50
2.50
0.50
0.50
2.50
2.50
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
Average
emissions
Ib-mole/day
0.0574
0.0690
0.0649
0.00930
0.00867
0.0242
0.0378
0.0322
0.0407
0.0417
0.00779
0.00500
0.0105
0.00715
0.0202
0.0247
0.040
0.0466
0.0628
0.0627
0.0730
0.0509
0.0433
0.0484
0.0417
Nominal average true vapor pressure (TVP) is the TVP at which the
emissions were calculated by using the vapor pressure function to
normalize the measured hydrocarbon concentration to the concentration
expected at the nominal TVP.
                                A-18

-------
                                      ft

                                          Y

                  \
                                                  22.5* I,D,
                                             X TEST DRUF1
GASKET
                                                1 1/2" mi  DIA, ALUfl,
                                                PIPE, SCH,  MO
                                                COVER  TENSIONING
                                                CABLE
                                                  WOODEN PALLET
                                                  PLACED ON SCALE
    Figure A-8.  Example of fitting emission bench test  apparatus.
                              A-19

-------
                                 Table A-5.  SUMMARY OF IFR DECK  FITTING  EMISSION  TESTS
ro
o

Test
number
1
2
3
4
5
6
7
8
9A
9B
10
11
12
13
14
15
Description
Access hatch cover, ungasketed
Access hatch cover, gasketed and clamped
lh inch diameter adjustable roof leg
8 inch diameter slotted pipe sample well
8 inch diameter pipe column well
1 inch diameter stub drain
Phase 1 column well, ungasketed
^ inch gap around built-up column
Phase 1 column well, gasketed
Phase 1 column well, ungasketed
Phase 2 column well
Phase 3 column well (1)
1/8 inch gap around built-up column
Access hatch cover with 1/8 inch gap
Sample well with 10% gap area
1/8 inch gap around built-up column (1)
Product
type
nC6
nC6
nC6
nC6
nC6
nC6
nC6
nC6
C3/nC8
C3/nC8
C3/nC8
C3/nC8
nC6
nC6
nC6
nC6
Correlation
coefficient
(-)
0.681
0.689
0.914
0.996
0.989
0.902
0.998
0.998
0.977
0.959
0.964
0.986
0.983
0.997
0.985
0.983
Average
emission
rate (2)
(Ib mole/yr)
0.204
0.158
0.977
4.69
2.11
0.279
4.32
5.42
3.38
5.07
1.22
2.25
2.44
5.61
1.45
2.81
      Notes:  (1).  Test drum was  30  in. diameter.

              (2).  Average emission  rate normalized to a nominal vapor pressure  of  5.00  psia.

-------
•£•
ro
                                      Table A-6.   PERMEABILITY OF POLYURETHANE COATED NYLON FABRIC
Test
number
16
17
18
19
20
21
22
23
Laboratory

Fabric
thickness
(in)
0.020
0.037
0.037
0.020
0.020
0.020
0.020
1/16" thk
aluminum
permeability
0.020
Fabric
area
(ft2)
2.75
2.75
2.75
2.75
2.75
2.75
2.75

Jest
0.467
Length
of taped
seams Product
(in) type
C3/nC8
C6H6
nC6
C3/nC8
C3/nC8
48 C3/nC8
C3/nC8
60 C3/nC8

nC6
Average
product
temperature
(°F)
59.2
60.5
60.1
53.8
48.1
50.9
43.2
44.2

74.8
Average
vapor
pressure
(psia)
7.13
1.22
1.98
3.86
3.56
4.68
3.59
3.38

1.85
Vapor
mole weight
(Ibm/lbmole)
45.8
78.1
86.2
46.6
46.3
45.9
46.0
46.3

86.2
Average
emission
rate
(Ibm/day)
0.0612
0.159
0.0158
0. 0652
0.0808
0. 0650
0.0344
0.00273

0.0244
Correlation
coefficient
(-)
0.838
0.996
0.663
0.783
0.806
0.863
0.805
0.096

--
Average
rate
(Ibm/ft2 day)
0.0222
0.0578
0.00578
0.0237
0.0294
0.0236
0.0125


0. 0522
Notes





(1)

(1)


         Notes:  (1).  Aluminum backed duct tape was used on all taped seams.

-------
      For seal  systems,  it was found that
                              Es  = Kp Mw D P*                       (C-l)
      Where:
           ES = Emissions  from the seal  area in Ibs/day
           Kr = Seal  factor
           Mw = Molecular  weight  of vapor
           D  = Tank  diameter
           P* = Vapor pressure function
 The  reduced emissions from seals  of similar construction  and  gap  condition
 are  averaged together.  A seal emission factor is  the  weighted  average
 of the  averaged reduced emissions.   Weights are  selected  according  to
 field survey data  that relate seal  gap  area to frequency  of occurrence.
 The  emission factor  which results  from  this procedure  of  repeated
 subtraction and averaging does not  represent any given tank,  but  is
 rather  an  expected value.
      The analysis  shows that  for  emission purposes seals  may  be divided
 into  two types:  liquid-mounted and  vapor-mounted.  An emission comparison
 of reduced results between  the foam-filled  vapor-mounted  seal tested
 during  Phase 3  and 3R and the vapor-mounted wipers tested in  Phase  1
 and  1R, shows  that emissions  from the foam-filled seal were lower than
 the  Phase 1 wiper but higher  than the Phase  1R wiper (Table A-7).   On
 this  basis, the  results from  Phases  1,  1R,  3 and 3R were merged into the
 general category of  vapor-mounted seal.
      The analysis shows that emissions  from  the liquid-mounted seal
 tested  in Phase 2 and 2R  are lower than both the average of the merged
 vapor-mounted seal tests  and the individual  vapor-mounted seal systems
 that were actually tested  (Table A-8).
     Another finding was  the presence of the secondary seal  reduced
 emissions whether or not  the primary seal was gapped.   Emissions reductions
obtained by a secondary seal average 47 percent for a liquid-mounted
primary seal  and 63 percent for a vapor-mounted primary seal.
A.2.2  Deck Seam Losses
     The welded IFR tested in Phase 2 and 2R was assumed to  have no deck
seam emissions.  The IFR's tested in Phases 1,  1R,  3 and 3R  have bolted  .
deck seams.  The seams in the contact deck (3 and 3R)  had a  different
construction  than those  in the noncontact deck (1 and 1R).  However, the
                                 A-22

-------
          Table A-7.   COMPARISON OF WIPER SEALS TO FOAM-FILLED
                           VAPOR-MOUNTED SEALS
   Seal  gaps
                                       Seal emissions
                                        (Ib mole/day)
(inVft diameter)  Phase 1 wiper        Foam-filled     Phase 1R wiper
                       0.0566
0.0248
0.0217
                       0.0978
0.0324
                                          0.0402
                 0.0319
 No  test available.
                                A-23

-------
   Table A-8.   COMPARISON OF LIQUID-MOUNTED SEAL TO VAPOR-MOUNTED SEAL
                                          Seal emissions
                                           (Ib mole/day)
    Seal gap
(inVft diameter)           Liquid-mounted             Vapor-mounted1



        0                        0.0052                   0.0217



        1                        0.0176                      —2



        3                        0.030                    0.0319



 Based on the best performing vapor-mounted seal  (Phase 1R wiper).

 No test available.
                                A-24

-------
 test data show that there is no significant difference in emissions from
 the seams in the two decks (on a per-foot-of-seam-basis) despite
 differences in construction and position relative to the stored liquid
 (Table A-9).   It should be noted that Test API 76 was not used in making
 the comparison.   API representatives have stated that due to slight
 problems in the test,  Test API 76 is not comparable with API 76R.4
      The per-foot-of-seam results that appear in Table A-9 were averaged
 together and divided by the value of the vapor pressure function to
 develop the deck seam emission factor Kd.   Further minor mathematical
 procedures are needed to develop Krf as it appears in Chapter 3.   These
 procedures relate seam length to deck diameter.
 A.2.3  Effect of Liquid Type on Emissions
      Comparisons between previous test programs  had indicated that
 emissions for single component (pure) liquids  (e.g.,  benzene),  could be
 significantly higher than emissions from multicomponent liquids
 (e.g.,  gasoline) when  normalized for both molecular weight and  vapor
 pressure.   Tests performed  in the API  program  show that  between  the
 tested  liquids  (hexane,  propane/octane,  and octane)  there were  no
 significant emissions  differences  after  normalizing for molecular  weight
 and  vapor pressure  (Table  A-10).
 A.2.4  The Effect of Vapor Pressure on  Emissions
      Several  emissions  tests  (from Phase  2 and 2R)  were conducted  to
 determine  the effect of  the product vapor pressure,  P,  on  the emissions
 rate.   This relationship was  evaluated during these tests  by  varying the
 product vapor pressure  in  the  pilot test tank which had been  fitted with
 a contact-type internal  floating  roof and a liquid-mounted primary seal.
 Based on these tests, the  emissions  are directly related to the vapor
 pressure function, P*:
                    P* =
                                      P
                                    14.7
A.2.5  Fitting Emissions
     The fitting emission factors are developed by a procedure similar
to that used for seal  factors.   A particular fitting design is analyzed
to determine emission  points and the results of the bench tests are
                                 A-25

-------
ro
en
                                                   Table A-9.   BOLTED DECK SEAM EMISSIONS1
Product
Test number type
Bolted, Contact IFR
API 55 C3/nC8
API 56 C3/nC8
Bolted, Noncontact IFR
API 76R C3/nC8
API 77 C3/nC8
Nominal
vapor pressure
(psia)

5.00
5.00

5.00
5.00
Vapor
•ole weight
(Ibm/lbmole)

48.1
48.2

46.8
47.1
Deck
seams

Sealed
Unsealed

Unsealed
Sealed
Total deck
seam length
(ft)

89
89

36
36
Emissions at
nominal vapor pressure
(Ibmole/day)

0.0156
0.0338

0.0433
0.0417
Emissions per foot
of deck seam
(Ibmole/day)


0.0002


0. 00004
              Other test conditions:
               Primary seal - sealed
               Secondary seal -  none
               Deck fittings - sealed

-------
     Table A-10.   COMPARISON OF EMISSIONS AS A FUNCTION OF LIQUID TYPE
Test number
Phase 2, 2R
API 50
API 67
API 67A
API 68
API 69
API 71
API 72
API 36
Phase 3, 3R
API 64
API 65
API 65R
API 65A
API 60
Product type

nC8
nC8
nC8
nC6
nC6
C3/nC8
C3/nC8
C3/nC8

nC8
nC6
nC6
nC6
C3/nC8
p
Emissions
(Ib mole/day)

0.0510
0.0599
0.0932
0.0233
0.0159
0.0247
0.040
0.0359

0.103
0.0537
0.0905
0.0927
0.0574
 All tests had identical conditions as follows:

     a.  1 inVft. diameter of gap on primary seal
     b.  No secondary seal.

     c.  All roof components unsealed.
2
 Emissions are normalized to 5.0 psia.
                                 A-27

-------
added and subtracted to account for each emission source in the design.
The individual emission sources are summed, and the resulting sum is
made independent of molecular weight and vapor pressure to form the
fitting factor.
     The test results show that the addition of gaskets and the bolting
of covers will reduce emissions from fittings.   Also demonstrated is the
fact that small  fitting design differences can lead to significant
differences in emissions.
                                A-28

-------
A.3  REFERENCES

 1.  Laverman, Royce J. et. al.  Testing Program to Measure Hydrocarbon
     Emissions from a Controlled Internal Floating Roof Tank;
     (Unpublished), Chicago Bridge and Iron Co. Chicago, Illinois
     March 1982.   304 pp.

 2.  U.S.  Environmental Protection Agency.   Measurements of Benzene
     Emissions from a Floating Roof Test TanEReport No.  EPA-450/3-
     79-020.   Research Triangle Park, N.C.   June 1979.

 3.  Letter and attachments, from O'Keefe, William,  F., American Petroleum
     Institute, to Wyatt,  Susan R.,  EPA.   January 25,  1983.

 4.  Moody, W.T.,  TRW, Meeting on September 2, 1982,  Durham,  N.C.
     between API,  EPA, and TRW.
                                A-29

-------
                   APPENDIX B

METHODOLOGY FOR ESTIMATING LEUKEMIA INCIDENCE AND
     MAXIMUM LIFETIME RISK FROM EXPOSURE TO
              BENZENE STORAGE TANKS

-------
                               APPENDIX B
        METHODOLOGY FOR ESTIMATING LEUKEMIA INCIDENCE AND MAXIMUM
          LIFETIME RISK FROM EXPOSURE TO BENZENE STORAGE TANKS

B.I  INTRODUCTION
     The purpose of this appendix is to describe the methodology and to
provide the information used to estimate leukemia incidence and maximum
lifetime risk from population exposure to benzene emissions from benzene
storage tanks.  The methodology consists of four major components:
estimation of annual average concentration patterns of benzene in the
region surrounding each plant, estimation of the population exposed to
each computed concentration, calculation of exposure by summing the
products of the concentrations and associated populations, and calcu-
lation of annual leukemia incidence and maximum lifetime risk from the
concentration and exposure estimates and a health effects estimate
represented by a unit risk factor.  Due to the assumptions made in each
of these four steps of the methodology, there is considerable uncertainty
associated with the lifetime individual risk and leukemia incidence
numbers calculated in this appendix.   These uncertainties are explained
in Section B.6 of this appendix.
B.2  ATMOSPHERIC DISPERSION MODELING AND PLANT EMISSION RATES
     The Human Exposure Model  (HEM) was used to estimate concentrations
of benzene around approximately 126 plants that contain benzene storage
tanks.    The HEM estimates the annual  average ground-level concentrations
resulting from emissions from point and area sources.   For point sources,
the dispersion model  within HEM is a Gaussian model  that uses the same
basic dispersion algorithm as  the climatological form of EPA's Climato-
                         2
logical Dispersion Model.    Gaussian concentration files are used in
conjunction with multi-year STAR data and annual emissions data to
estimate annual  average concentrations.   Details on this aspect of the
HEM can be found in Reference  1.
                                 B-2

-------
      Seasonal  or annual  stability array (STAR) summaries are principal
 meteorological  input to  the HEM dispersion model.   STAR data are standard
 climatological  frequence-of-occurrence summaries formulated for use in
 EPA models and  available for major U.S.  sites from the National Climatic
 Center,  Asheville,  N.C.   A STAR summary is a joint frequency of occurrence
 of wind  speed  stability  and wind direction categories, classified according
 to the Pasquill  stability categories.   For this  modeling analysis,
 annual STAR summaries were used.
      The model  receptor  grid consists  of 10 downwind  distances  located
 along 16 radials.   The radials  are separated by  22.5-degree intervals
 beginning with  0.0  degrees and  proceeding clockwise to 337.5 degrees.
 The 10 downwind  distances for each radial  are 0.2,  0.3,  0.5,  0.7,  1.0,
 2.0,  5.0, 10.0,  15.0,  and 20.0  kilometers.   The  center of the receptor
 grid for each plant was  assumed to be  plant center  as  determined by
 review of maps.
      Inputs  to the  dispersion model  include the  geographical  coordinates
 for each plant,  and the  emission  rates,  dimensions  and plume  character-
 istics for each  storage  tank in each plant.   The latitudes  and  longitude
 for each plant,  used in  selecting  the  STAR  site, are  listed in  Table B-l.
 Four  model  units representing the  different types of plants  that would
 have  benzene storage tanks were developed:   large producers  of  benzene,
 small  producers  of  benzene,  benzene consumers, and  bulk  storage  terminals.
 The model  units were assigned to each  plant  according  to  the  uses of
 benzene  within the  plant.  Where a plant had  two model units  assigned to
 it  (e.g.,  a plant may be  both a producer and  consumer  of  benzene),
 emissions  from both  model  units were used in  calculating  the  concentration
 pattern  around the  plant.  The  model units  assigned to each plant are
 listed in Table B-l.
      Each model unit consists of a set of benzene storage tanks with
 specified dimensions, roof types, turnovers,  and emission rates.  The
 tank parameters used in the dispersion model  are the same for benzene
 consumers and bulk  storage terminals; therefore,  no differentiation was
made between them for modeling purposes.  Table B-2 shows, for each
model unit, the height and vertical cross-sectional area (used in downwash
calculations) of each tank.  The table also shows the  emissions  from
                                 B-3

-------
                 Table B-l.   PLANTS AND LOCATIONS FOR BENZENE STORAGE TANKS
          Plant
  Region II
  1.  American Cyanamid
  2.  DuPont
  3.  Exxon
  4.  Standard Chlorine
  5.  Texaco
  6.  Ashland Oil
  7.  ICC Industries
  8.  Commonwealth  Oil
  9.  Phillips Puerto  Rico
10.  Puerto Rico Olefins
11.  Union Carbide
12.  Amerada Hess
Region  III
13.  Getty
14.  Standard Chlorine
15.  Sun-Olin
16.  Continental Oil
17.  Atlantic Richfield
18.  Gordon  Terminals
19.  Gulf  Oil
20.  Standard  Oil
      (Ohio)/BP Oil
21.  Sun Oil
22.  U.S.  Steel
23. Allied Chemical
24. American Cyanamid
25. Mobay Chemical
26. PPG
27. Union Carbide
                                                              Coordinates
  Location
                                                      Longitude
                                      Latitude
 Boundbrook,  NJ
 Gibbstown,  NJ
 Linden,  NJ
 Kearny,  NJ
 Westville,  NJ
 North  Tonawanda,  NY
 Niagara  Falls,  NY
 Penuelas, PR
 Guyama,  PR
 Penuelas, PR
 Penuelas, PR
 St. Croix, VI

 Delaware City,  DE
 Delaware City,  DE
 Claymont, DE
 Baltimore, MD
 Beaver Valley,  PA
 McKees, PA
 Philadelphia, PA

 Marcus Hook, PA
 Marcus Hook, PA
 Neville Island, PA
 Moundsville, WV
Willow Island, WV
 New Martinsvilie, WV
 Natrium,  WV
 Institute,  WV
 74°06'04"
 75°17'50"
 74°12'49"
 74°06'39"
 75°08'42"
 78°55'27"
 79000'55"
 66°42'00"
 66°07'00"
 66°42'00"
 66042'00"
 64°44'00"

 75°37'45"
 75038'47"
 76°25'40"
 77°34'02"
 80021'20"
 80°03'10"
 75°12'31"

 75°37'45"
 75024'51"
 80°05'00"
 80°48'04"
 81°19'08"
 80°49'50"
 80°52'14"
81047'05"
 40°33'25"
 39°50'25"
 40°38'10"
 40045'03"
 39°52'05"
 42°59'45"
 43°03'33"
 18004'00"
 17°59'00"
 18°04'00"
 18°04'00"
 17°45'00"

 39°35'15"
 39°33'54"
 39°48'20"
 39°14'19"
 40°39'21"
 40°28'22"
 39°54'18"

 39°35'15"
 39°48'45"
40°30'00"
 39°55'00"
39°21'45"
39°43'30"
39044'46"
38°22'40"
                             Model Plant
                                Type9
 C/T
 C/T
 SP.C/T
 C/T
 LP.C/T
 SP
 C/T
 LP.C/T
 LP.C/T
 C/T
 C/T
 LP

 SP
 C/T
 C/T
 C/T
 C/T
 C/T
 LP.C/T

 SP
 SP
 C/T
 C/T
 C/T
C/T
C/T
C/T
                                         (continued)
                                           B-4

-------
Table B-l.   Continued
Plant
Region IV
28. Jim Walter Resources
29. Reichhold Chemicals
30. Ashland Oil
31. B.F. Goodrich
32. GAP
33. 01 in Corporation
34. Chevron
35. First Chemical
Region V
36. Clark Oil
37. Core-Lube
38. Monsanto
39. National Distillers
(U.S.I.)
40. Northern
Petrochemicals
41. Shell Oil
42. Union Oil
(California)
43. Dow Chemical
44. Dow Chemical
45. Sun Oil
46. Vertac/Transvaal
47. Allied Chemical
48. American Hoechst
49. Cities- Service
50. Continental Oil
51. Cos-Mar, Inc.
52. Dow Chemical
Location
Birmingham, AL
Tuscaloosa, AL
Ashland, KY
Calvert City, KY
Calvert City, KY
Brandenburg, KY
Pascagoula, MS
Pascagoula, MS
Blue Island, IL
Danville, IL
Sauget, IL
Tuscola, IL
Morris, IL
Wood River, IL
Lemont, IL
Bay City, MI
Midland, MI
Toledo, OH
Jacksonville, AR
Geismar, LA
Baton Rouge, LA
Lake Charles, LA
Lake Charles, LA
Carrville, LA
Plaquemine, LA
Coordi
Longitude
86°47'30"
87°28I21"
82°36'32"
88°19'51"
88°24'48"
86°07'15"
88°28'37"
88°29'45"
87°42'07"
87°32'30"
90010'11"
88°21'00"
88°25'42"
90004'24"
88°00'10"
89°52I22"
84°12'18"
83°31'40"
92°04'56"
91°03'12"
91°12'40"
93°19'01"
93°16'35"
91°04'09"
91014'30"
nates
Latitude
33°35'30"
33°15'06"
38°22I30"
37°03'19"
37°02'51"
38°00'30"
30°19'04"
30°20'57"
41°39'19"
40°07'10"
38°36'06"
39°47'53"
41°21'28"
38°50'26"
41°40'20"
43°37'21"
43°35'42"
41°36'52"
34°55'36"
30°12'55"
30033'03"
30°10'58"
30°14'30"
30°14'16"
30°19'50"
Model Plant
Type3
C/T
C/T
LP
C/T
C/T
C/T
SP
C/T
C/T
C/T
C/T
C/T
C/T
LP
SP
LP.C/T
C/T
LP
C/T
C/T
C/T
SP
C/T
C/T
LP
    (continued)
       B-5

-------
Table B-l.   Continued
Coordinates
Plant
Region VI (continued)
53. Exxon
54. Gulf Coast Olefins
55. Gulf Oil
56. Gulf Oil
57. Pennzoil United
(Atlas Processing)
58. Rubicon
59. Shell Oil
60. Tenneco
61. Union Carbide
62. Sun Oil
63. Amerada Hess
64. American Hoechst
65. American Petrofina
of Texas
66. American Petrofina
(Cosden Oil)
67. American Petrofina/
Union Oil of
California
68. Atlantic Richfield
69. Atlantic Richfield
(ARCO/Polymers)
70. Atlantic Richfield
(ARCO/Polymers)
71. Celanese
72. Charter
International
73. Coastal States Gas
74. Corpus Christi
Petrochemicals
75. Cosden Oil


Location

Baton Rouge, LA
Taft, LA
Alliance, LA
Donaldsonville, LA

Shreveport, LA
Geismar, LA
Norco, LA
Chalmette, LA
Taft, LA
Tulsa, OK
Houston, TX
Bayport, TX

Port Arthur, TX

Big Spring, TX


Beaumont, TX
Channel view, TX

Houston, TX

Port Arthur, TX
Pampa, TX

Houston, TX
Corpus Christi , TX

Corpus Christi, TX
Groves, TX
(continued)
B-6
Longitude

91°10'17"
90°26'23"
89°58'26"
90°55'19"

93°46'13"
91°00'37"
90°27'35"
89°58'19"
90°27'15"
96°01'15"
95°14'15"
95°01'15"

93°53'20"

101024'55"


93°58'45"
95°07'30"

95°13'54"

93°58'15"
100°57'47"

95°15'09"
97°26'44M

97°31'2r'
93°52'58"


Latitude

30°29'14"
29°59'16"
29°41'00"
30°05'44"

32°28'12"
30°11'06"
29059.42"
29055'56"
29059'17"
36°08'25"
29°41'39"
29°36'10"

29°57'30"

32°16'11"


30°00'00"
29°50'00"

29°43'10"

29051-24"
35032'07"

29°40'17"
27°48'42"

27°50'02"
29°57'46"


Model Plant
Type3

LP
C/T
LP
C/T

LP
C/T
C/T
SP
LP
C/T,SP
C/T
C/T

SP

LP.C/T


SP,C/T
LP

LP

C/T
C/T

SP
LP.C/T

SP,C/T
C/T



-------
Table B-l.  Continued
Coordinates
Plant
Region VI (continued)
76. Crown Central
77. Dow Chemical (A)
78. Dow Chemical (B)
79. Dow Chemical
80. DuPont
81. DuPont
82. Eastman Kodak
83. El Paso Natural Gas
84. El Paso Products/
(Rexene Polyolefins)
85. Exxon
86. GATX Terminal Group
87. Georgia-Pacific Corp.
88. Goodyear Tire and
Rubber
89. Gulf Oil Chemicals
90. Gulf Oil Chemicals
91. Hercules
92. Howell
93. Independent Refining
Corp.
94. Kerr-McGee Corp.
(Southwestern)
95. Marathon Oil
96. Mobil Oil
97. Monsanto
98. Monsanto
99. Oxirane
Location
Pasadena, TX
Freeport, TX
Freeport, TX
Orange, TX
Beaumont, TX
Orange, TX
Longview, TX
Odessa, TX
Odessa, TX
Baytown, TX
Houston, TX
Houston, TX
Bayport, TX
Cedar Bayou, TX
Port Arthur, TX
McGregor, TX
San Antonio, TX
Winnie, TX
Corpus Christi, TX
Texas City, TX
Beaumont, TX
Alvin (Choco-
late Bayou)
Texas City, TX
Channel view, TX
Longitude
95°10'30"
95°19'55"
95°24'09"
93°45'14"
94°01'40"
93044 '44"
94°41 '24"
102°19'29"
102°20'00"
95°01'04"
95013'29M
95°03'00"
95°02'44"
94°55'10"
93°58'30"
97016'30"
98°27'36"
94°20'28"
97°25'24"
94054' 47"
94003'30"
95°12'44"
94°53'40"
95°06'29"
Latitude
29044'40"
28°57'23"
28059'17"
30°03'20"
SOW 51"
30°03'24"
32°26'17"
31°49'27"
31°49'22"
29044.50-
29°43'17"
29°37'20"
29039 .43,,
29°49'29"
29°51'30"
31030'15"
29°20'51"
29050'04"
27048'16"
29°22'2r'
30°04'00"
29°15'09"
29°22'44"
29°50'00"
Model Plant
Type3
SP
LP,C/T
LP.C/T
C/T
C/T
C/T
C/T
C/T
C/T
LP.C/T
C/T
C/T
C/T
C/T
LP,C/T
C/T
SP
SP
SP
SP.C/T
LP.C/T
LP,C/T
LP.C/T
C/T
    (continued)
       B-7

-------
Table B-l.   Continued
Plant
Region VI (concluded)
100. Petrounited Terminal
Services
101. Phillips Petroleum
102. Phillips Petroleum
103. Phillips Petroleum
104. Quintana-Howell
105. Shell Chemical
106. Shell Oil
107. Shell Oil
108. Standard Oil
(Indiana)
109. Standard Oil
(Indiana)/Amoco
110. Sun Oil
111. Texaco
112. Texaco/Jefferson
Chemical
113. Union Carbide
114. Union Carbide
115. USS Chemicals
Region VII
116. Chemplex
117. Getty Oil
118. Monsanto
Region IX
119. Atlantic Richfield
120. Chevron
121. Specialty Organics
Location


Houston, TX
Borger, TX
Pasadena, TX
Sweeny, TX
Corpus Christi, TX
Houston, TX
Deer Park, TX
Odessa, TX

Alvin, TX

Texas City, TX
Corpus Christi, TX
Port Arthur, TX

Port Neches, TX
Seadrift, TX
Texas City, TX
Houston, TX

Clinton, 10
El Dorado, KA
St. Louis, MO

Wilmington, CA
Richmond, CA
Irwindale, CA
Coordi
Longitude


95°01'23"
101°22'05"
95°10I53"
95°45'10"
97°27'30"
95°01'45M
95°07'33"
102°19'20"

95°11'55"

94055'45"
97031'38"
93°54'43"

93°56'00"
96°45'59"
94056'33"
95°15'06"

96°17'29"
96052'00"
90°12'00"

118°14'30
122°23'36"
117°55'56M
nates
Latitude


29°33'51"
35°42'05"
29°43'59"
29°04'24"
27°48'30"
29°38'15"
29°42'55"
31°49'05"

29°13'06"

29°21'58"
27049.57..
29°52'00"

29°57'50
28°30'38"
29°22'27"
29°42'18"

41°48'24"
37°47'10"
38°35'00"

33°48'49"
37°56'12"
34006'18"
Model Plant
Type3


C/T
SP
C/T
SP,C/T
SP
C/T
LP
SP

C/T

LP,C/T
LP.C/T
LP,C/T

C/T
C/T
C/T
C/T

C/T
SP.C/T
C/T

SP
SP.C/T
C/T
    (continued)
       B-8

-------
                                   Table B-l.  Concluded

Plant
Location
Coordi
Longitude
nates
Latitude
Model Plant
Type3
Region IX (continued)
122.
123.
124.
125.
126.
Standard Oil of
California (Chevron
Chemical)
Union Carbide
Witco Chemical
Montrose Chemical
Stauffer Chemical
El Segundo, CA
Torrance, CA
Carson, CA
Henderson, NV
Henderson, NV
118°24'41"
118°20'50"
118°14'13"
115°00'40"
115°00'40"
33°54'39"
33°51'11"
33°49'18"
36°02'28"
36°02'28"
SP.C/T
C/T
C/T
C/T
C/T
C/T represents a benzene consumer or bulk storage terminal;  LP represents  a large  producer of
benzene; SP represents a small  producer of benzene.
                                          B-9

-------
            Table  B-2.  MODEL  INPUTS  FOR EACH TYPE OF MODEL PLANT
Tank dimensions
Type of model
plant and tank number
Benzene Producer: Large
Facility (throughput of
224.6 x 106 liters/year)
1
2
3
4
5
6
7
Benzene Producer: Small
Facility (throughput of
46.3 x 106 liters/yr)
1
2
3
4
Benzene Consumer or
Bulk Storage Terminal
1
2
Vertical
cross-sectional
Height area
(m) (m2)

9
12
5
9
13
9
15


11
13
11
7


11
15

108
216
40
81
169
216
405


33
169
88
224


132
270
Baseline
Roof
type

ncIFR
EFRps
cIFRps
cIFRps
ncIFR
ncIFR
ncIFR


FR
ncIFR
ncIFR
cIFRps


ncIFR
cIFRps
Emissions
(kg/yr)

720
2,190
480
590
680
1,360
1,820


1,270
680
500
2,170


640
970
FR - Fixed-roof tank, IFR - internal  floating-roof tank,  ERF - external
floating-roof tank, c - contact roof,  nc - noncontact roof,  ps - primary seal,
ss - secondary seal, 1m - liquid-mounted seal.
                                    B-10

-------
 each tank for the baseline (current level) level of control.   Emissions
 from all the tanks were assumed to be at ambient temperature, which the
 model assigns as 293°Kelvin.   Because the gas exit velocity is negligible,
 it was assumed to be 0 m/s.   The model was run in the rural mode.   More
 information on the development of model plants and emission rates  can be
 found in Chapter 2 of this document.
 B.3  POPULATION AROUND PLANTS CONTAINING BENZENE STORAGE TANKS
      The HEM was used to estimate the population that resides in the
 vicinity of each receptor coordinate  surrounding each plant containing
 benzene storage tanks.   A slightly modified version of the "Master
 Enumeration District List—Extended"  (MED-X)  data base is contained in
 the HEM and used for population pattern estimation.   This data base is
 broken down into enumeration  district/block group (ED/BG) values.   MED-X
 contains the population centroid coordinates  (latitude and longitude)
 and the 1970 population of each ED/BG in the  United States (50 States
 plus the District of Columbia).   For  human  exposure estimations, MED-X
 has been reduced from its  complete form (including  descriptive and
 summary data)  to produce a randomly accessible computer  file  of the data
 necessary for  the estimation.   A separate file of county-level  growth
 factors,  based on 1978  estimates of the 1970  to  1980  growth factor  at
 the county  level,  has been used to  estimate 1980  population figures  for
 each ED/BG.  The  population "at risk"  to benzene  exposure  was  considered
 to  be  persons  residing  within 20 km of  plants containing  benzene storage
 tanks.   The  population  around each  plant was  identified by specifying
 the geographical  coordinates of  that plant.   The  geographical  coordinates
 are shown for  each plant in Table B-l.
 B.4 POPULATION EXPOSURE METHODOLOGY
 B.4.1   Exposure Methodology
     The HEM uses benzene atmospheric concentration patterns (see
 Section B.2) together with population information (see Section B.3) to
 calculate population exposure.   For each receptor coordinate,  the
 concentration of benzene and the population estimated by the HEM to be
 exposed to that particular concentration are identified.   The HEM
multiplies these two numbers  to produce population exposure estimates
and sums these products for each plant.  A two-level scheme has been
adopted in order to pair concentrations and populations prior to the

                                 B-ll

-------
 computation of exposure.   The two-level  approach is  used because the
 concentrations are defined on a radius-azimuth (polar)  grid pattern with
 nonuniform spacing.   At small radii,  the grid cells  are much smaller
 than ED/BG's;  at large radii, the grid cells  are generally much  larger
 than ED/BG's.   The area surrounding  the  source is divided into two
 regions,  and each ED/BG is classified by the  region  in  which its centroid
 lies.   Population exposure is calculated differently for the ED/BG's
 located within each  region.
      For  ED/BG centroids  located between 0.1  km and  2.8 km from  the
 emission  source,  populations  are divided between neighboring concentration
 grid points.   There  are 96 (6 x 16) polar grid points within this range.
 Each grid point has  a polar sector defined by two concentric arcs and
 two  wind  direction radials.   Each of  these grid points  is  assigned  to
 the  nearest ED/BG centroid identified from MED-X.  The  population
 associated with the  ED/BG  centroid is  then divided among  all  concentration
 grid points  assigned to it.   The exact land area within each polar
 sector  is  considered in the apportionment.
      For  population  centroids  between  2.8  km  and 20  km  from  the  source,
 a concentration grid cell,  the  area approximating a  rectangular  shape
 bounded by four receptors,  is much larger  than  the area of a  typical
 ED/BG (usually  1  km  in  diameter).  Since there  is a  linear relationship
 between the  logarithm  of concentration and  the  logarithm of  distance for
 receptors  more  than  2  km from the source,  the entire population of the
 ED/BG is  assumed  to  be  exposed to the  concentration that is  geometrically
 interpolated radially and arithmetically interpolated azimuthally from
 the  four receptors bounding the grid cell.  Concentration estimates for
 80 (5 x 16) grid  cell receptors at 2.0, 5.0, 10.0, 15.0, and 20.0 km
 from the source along each of 16 wind directions are used as reference
points for this interpolation.
     In summary,  two approaches are  used to arrive at coincident
concentration/population data points.   For the 96 concentration points
within 2.8 km of the source, the pairing occurs at the polar grid points
using an apportionment of ED/BG population by land area.  For the remaining
portions of the grid, pairing occurs  at the ED/BG centroids themselves,  .
through the use of log-log and linear interpolation.   (For a more detailed
discussion of the methodology used to estimate exposures, see Reference 1.)
                                 B-12

-------
B.4.2  Total Exposure
     Total exposure (persons-pg/m3) is the sum of the products of
concentration and population, computed as illustrated by the following
equation:
                                              N
                          Total exposure   =  I  (P-C-)                   (1)
                                             i=l   n n
   where
        P. = population associated with point i,
        C. = annual average benzene concentration at point i, and
        N  = total number of polar grid points between 0 and 2.8 km
             and ED/BG centroids between 2.8 and 20 km.

     The computed total exposure is then used with the unit risk factor
to estimate leukemia incidence.  This methodology and the derivation of
maximum lifetime risk are described in the following sections.
B.5  LEUKEMIA INCIDENCE AND MAXIMUM LIFETIME RISK
B.5.1  Unit Risk Factor
                                                       _Q
     The unit risk factor (URF) for benzene is 9.9 x 10   (cases per
year)/ (ug/m3-person years), as calculated by EPA's Carcinogen Assessment
Group (CAG).  This factor is slightly lower than the factor derived by
CAG at proposal.
     Arguments have been advanced that the assumptions made by EPA
(Carcinogen Assessment Group [CAG]) in the derivation of a unit leukemia
risk factor for benzene represented "serious misinterpretation" of the
underlying epidemiological evidence.   Among the specific criticisms are:
CAG (1) inappropriately included in its evaluation of the Infante et al.
study two cases of leukemia from outside the cohort, inappropriately
excluded a population of workers that had been exposed to benzene, and
improperly assumed that exposure levels were comparable with prevailing
occupational standards; (2) accepted, in the Aksoy et al. studies, an
unreasonable undercount of the background leukemia incidence in rural
Turkey, made a false adjustment of age, and underestimated the exposure
duration; and (3) included the Ott et al.  study in the analysis despite
a lack of statistical significance.
                                 B-13

-------
      EPA  has  reexamined  and  reevaluated  each of the three  studies.   In
 summary,  EPA  concluded that  one case of  leukemia was  inappropriately
 included  from the  Infante et al. study in computing the original  unit
 risk  factor.  Additionally,  EPA reaffirmed  its decision to exclude
 dry-side  workers from that study in developing the risk factor.   The
 Agency agrees that the Aksoy et al. study was adjusted improperly for
 age;  however, the exposures  and durations of exposures are still  considered
 reasonable estimates.  The Ott et al. study was not eliminated from the
 risk  assessment because  the  findings meet the test of statistical
 significance  and because it  provides the best documented exposure data
 available from the three epidemiological studies.
      Based on these findings, the unit risk factor (the probability of
 an individual contracting leukemia after a lifetime of exposure to a
 benzene concentration of one part benzene per million parts air) was
 recalculated.  The revised estimate resulted in a reduction of about
 7 percent from the original  estimate of the geometric mean, from  a
 probability of leukemia of 0.024/ppm to a probability of leukemia of
 0.022/ppm.
 B.5.2  Annual Leukemia Incidence
     Annual leukemia incidence (the number of leukemia cases per year)
 associated with a given plant is the product of the total  exposure
 around that plant (in persons - ug/m3) and the unit risk factor,
 9.9 x 10"8.   Thus,
     Cases per year = (total  exposure) x (unit risk factor),        (2)
where total  exposure is calculated according to Equation 1 and the unit
 risk factor equals  9.9 x 10"8.
B.5.3  Maximum Lifetime Risk
     The populations in areas surrounding plants  containing benzene
 storage tanks have  various  risk levels of contracting  leukemia from
exposure to benzene emissions.   Using the maximum  annual  average  concen-
tration of benzene  to which any person is exposed,  it  is  possible to
calculate the maximum lifetime  risk of leukemia (lifetime  probability of
 leukemia to any person exposed  to  the highest concentration of benzene)
attributable to benzene emissions  using the  following  equation:
                                 B-14

-------
             Maximum  lifetime  risk = C.     x  (URF) x 70 years       (3)
                                       I j Hid A
   where
        C. max = the  maximum concentration among all plants at any  receptor
                 location where exposed persons reside,
           URF = the  unit risk factor, 9.9 x 10"8, and
      70 years = the  average individual's life span.
B.5.4  Example Calculations
     The following calculations illustrate how annual leukemia incidence
and maximum lifetime  risk were calculated for specific plants listed in
Table B-l.  Table B-3 presents the maximum annual average concentration
and the total exposure for each plant under the baseline (current level)
control level.
     B.5.4.1  Annual  Leukemia  Incidence.  As an example for calculating
annual leukemia incidence the  Gulf Oil plant in Philadelphia, Pennsylvania,
is used.   As shown in Table B-3, the total exposure under the current
(baseline) level of emission control is 3.30 x 10  persons-ug/nv*.
Therefore, under the baseline, the cases per year are computed according
to Equation 2 as follows:
             Cases per year =  3.30 x 104 x 9.9 x 10"8
                  Cases per year = 0.003
     B.5.4.2  Maximum Lifetime Risk.  Plant numbers 73 (Coastal  States
and Gas)  and 117 (Sun Oil) had the highest maximum annual  average benzene
concentration of 5.22 ug/nr1.   Using this maximum concentration and
Equation 3, maximum lifetime risk under the current (baseline) level of
control is calculated as follows:
               Maximum lifetime risk = 5.22 x 9.9 x 10"8 x 70
                    Maximum lifetime risk = 3.62 x 10
B.5.5  Summary of Impacts
     Table B-4 summarizes the estimated nationwide impacts for the
baseline  (current level) level  of emission control.   The nationwide
annual  leukemia incidence was calculated by summing the total  exposure
over all  the plants  and multiplying by the unit risk factor.   The maximum
lifetime  risk was  calculated  as shonw in Section B.5.4.2.
                                 B-15

-------
Table B-3.   ESTIMATED MAXIMUM CONCENTRATION
  AND EXPOSURE FOR BENZENE STORAGE TANKS



Plant
number
Region II
1
2
3
4
5
6
7
8
9
10
11
12
Region III
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27


Baseline
Maximum annual
average benzene
concentration
(ug/m3)

4.45X10"1
2.50X10"1
2.60x10°
l.OOxlO"1
3.03x10°
3.19x10°
7.44X10'1
b
b
b
b
b

1.77x10°
2.50X10"1
8.67xlO"3
2. 50x10" l
2.50X10"1
4. 50x10" l
3.03x10°
1.77x10°
1.77x10°
4.50X10"1
l.SOxlO"2
2.50X10"1
9.62xlO"3
S.OOxlO"1
4.87X10"1
(continued)
B-16



Total exposure
(person pg/m3)

5.26xl03
2.27xl03
3.05xl04
1.44xl04
2.32xl04
3.95xl03
7.93xl02
b
b
b
b
b

1.21xl03
3.20xl02
S.SOxlO1
1.31xl02
5.20xl02
3.75xl03
3.30xl04
1. 21xl03
4.50xl03
2.32xl03
5.39xl02
1.21X102
7.24X101
1.03xl02
1.07xl03



-------
Table B-3.   Continued

Plant
number
Region IV
28
29
30
31
32
33
34
35
Region V
36
37
38
39
40
41
42
43
44
45
Region VI
46
47
48
49
50
51
52


Baseline
Maximum annual
average benzene
concentration
(ug/m3)

3.47X10"1
l.OOxlO"1
1.00x10°
1.04xlO"2
1.92xlO"2
1.53xlO"2
9. 78x10" 3
S.OlxlO"1

3.70X10"1
2.50X10"1
4.11X10"1
6.05xlO"3
3.70X10"1
2.51x10°
1.64x10°
1. 00x10°
3. 88x10" l
2.87x10°

l.OOxlO"1
2.50X10"1
2.50X10"1
5. 00x10" l
2.50X10"1
2.50X10"1
2.66x10°
(continued)
B-17


Total exposure
(person ug/m3)

1.70xl03
4.04xl02
2.57xl03
6.45X101
1.19xl02
1.41xl02
3.69xl02
3.77xl02

5.30xl03
1.96xl02
2.67xl03
4.75X101
4.91xl02
3.42xl03
3.43xl03
2.51xl02
4.81xl02
1.22xl04

1.63xl02
1.42xl02
6.57xl02
8.88xl02
3.65xl02
1.59.X102
1.49xl03



-------
Table B-3.  Continued



Plant
number
Region VI
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79


Baseline
Maximum annual
average benzene
concentration
(|jg/m3)
(continued)
1.00x10°
5.75X10"1
2.61xlO"2
2.50X10"1
3.72x10°
2.50X10"1
5.00X10"1
1.00x10°
2.50x10°
3.19x10°
4.39X10"1
8.13X10"1
1.00x10°
2.50x10°
1.00x10°
5.19x10°
1.00x10°
2. 50x10" l
3.25X10"1
2.01x10°
5.22x10°
3.78x10°
l.OOxlO"1
S.OOxlO"1
3.10x10°
1.00x10°
l.OOxlO"1
(continued)
B-18



Total exposure
(person ug/m3)

1.05xl04
3.51xl02
2.44xl02
2.01xl02
1.55xl04
1.35xl02
2.29xl02
1. OSxlO4
1.14xl03
5.29xl03
4.61xl03
7.39xl02
1.60xl03
7.50xl02
2.03xl03
4. 34xl03
1. 95xl04
3.43xl02
4. 55xl02
1.54xl04
4.89xl03
1.24xl03
3.59xl02
7.30xl03
l.OSxlO3
1.21xl03
3.42xl02



-------
Table B-3.   Continued



Plant
number
Region VI
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106


Baseline
Maximum annual
average benzene
concentration
(fjg/m3)
(continued)
2. 50x10" 1
l.OOxlO"1
l.OOxlO"1
l.OOxlO"1
4.12X10"1
1. 00x10°
4.39X10"1
8. 13x10" 1
2.50X10"1
"2.50X10"1
1.00x10°
2.50X10"1
4.72x10°
1.56xlO"2
3.07x10°
2.26x10°
2.50x10°
1.00x10°
3.10x10°
5.00X10"1
8. 13x10" l
1.00x10°
8.13X10"1
1.00x10°
3.07x10°
8.13X10"1
2.50x10°
(continued)
B-19



Total exposure
(person ug/m3)

3.57xl02
3.42X102
3.40xl02
5.94xl02
7.13xl02
4.70xl03
3.62xl03
7.71xl02
S.OOxlO2
2.07xl02
1.95xl03
1.32xl02
1. 36xl04
8.62X101
5.13X103
2.16xl03
3.24xl03
1.71xl02
3.81xl03
6.24xl02
7.33xl02
2.72xl02
2.60xl03
2.79xl02
1.73xl03
8.31xl02
7.55xl03



-------
                   Table B-3.  Concluded




Plant
number
Region VI
107
108
109
110
111
112

113
114
115
Region VII
116
117
118
Region IX
119
120
121
122
123
124
125
126
Baseline
Maximum annual
average benzene
concentration
(pg/m3)
(concluded)
1.85x10°
3. 36x10" 3
3.10x10°
5.22x10°
2.50x10°
l.OOxlO"1
-T
5.00x10 L
2. 50x10" l
4.39X10"1

6.11xlO"3
S.OOxlO"1
2.50X10"1

2.85x10°
4. 50x10°
5. 61x10" l
3.85x10°
7.33X10"1
5. 61x10" l
2. 50x10" l
2.50X10"1



Total exposure
(person pg/m3)

1.76xl03
9.02x10°
2.66xl03
2.13xl03
3.60xl03
6.22xl02
i
2.47X101
4.88xl02
4.55xl03

1.58X101
6.08xl02
2.82xl03

2.44xl04
1.07xl04
6.29xl03
2.40xl04
6.93xl03
8.47xl03
5.18xl02
5.18xl02
 This  table  lists  the  maximum  annual  average  benzene
 concentration to  which  at least one  person  is  exposed.
DPopulation  estimate is  not included  in the  HEM for this
 plant.
                            B-20

-------
   Table B-4.  ESTIMATED NATIONWIDE HEALTH IMPACTS
              FOR BENZENE STORAGE TANKS
                                           Baseline
Max. Annual Average                          5.22
Concentration (ug/m5)

Maximum Lifetime Risk                     3.6 x 10"5

Total Exposure.                            4.37 x 10^
 (persons-|jg/m3)

Incidence (cases/yr)                         0.043
                       B-21

-------
B.6  UNCERTAINTIES
     Estimates of both leukemia incidence and maximum lifetime risk are
primarily functions of estimated benzene concentrations, populations,
the unit risk factor, and the exposure model.  The calculations of these
variables are subject to a number of uncertainties of various degrees.
Some of the major uncertainties are identified below.
B.6.1  Benzene Concentrations
     Modeled ambient benzene concentrations depend upon:  (1) plant
configuration, which is difficult to determine for more than a few
plants; (2) emission point characteristics, which can be different from
plant to plant and are difficult to obtain for more than a few plants;
(3) emission rates, which may vary over time and from plant to plant;
and (4) meteorology, which is seldom available for a specific plant.
The particular dispersion modeling used can also influence the numbers.
The dispersion models also assume that the terrain in the vicinity of
the source is flat.  For sources located in complex terrain, the maximum
annual concentration could be underestimated by several  fold due to this
assumption.   The dispersion coefficients used in modeling are based on
empirical measurements made within 10 kilometers of sources.  These
coefficients become less applicable at long distances from the source,
and the modeling results become more uncertain.   Assuming the inputs  to
the dispersion model are accurate, the predicted benzene concentrations
are considered to be accurate to within a factor of 2.   This uncertainty
factor was not included in the calculations in this analysis.
     The Industrial Source Complex - Long Term (ISC-LT)  dispersion model
is considered to be a more complex and accurate dispersion model than
the dispersion model subprogram of the HEM.  However, it is too resource-
intensive for modeling a large number of sources, such as benzene storage
vessels.  To evaluate the effect of using the HEM dispersion model, the
ISC-LT was run on the model plants for several geographic sites and the
results were compared with those from the HEM dispersion model.   The
results of the analysis can be found in Docket A-80-14,  Item IV-B-4.
     For three sites (New Orleans, Houston, and Chicago) the maximum  and
mean ring concentrations predicted by each model were compared.   In all
cases, the ISC-LT resulted in higher estimates than the dispersion model
                                 B-22

-------
  of the HEM.   For the same three sites and two additional sites (Los Angeles
  and Philadelphia), the concentration at each receptor point times the
  corresponding area around the receptor point was summed over all  receptors
  at each plant.   (NOTE:   Docket Item IV-B-4 calls this sum "total  exposure."
  The usage in the docket item is different from that defined in Section B.4
  of this appendix.)  The ISC-LT results in a higher estimate of this sum
  (ranging from about 20 to 60 percent) than the HEM dispersion model for
  New Orleans, Houston,  and Philadelphia.   For Chicago and Los Angeles,
  the HEM and  ISC-LT give very similar results for this sum,  within
  10 percent of one another.
       This analysis shows that the  ISC-LT and the HEM dispersion model
  may give different results.   In many cases,  the  ISC-LT predicts higher
  concentrations  than the HEM.   However, because of the degree of uncertainty
  in the  basic data available  for the  model  and in dispersion  analysis,
  the degree of effort to model  all  the  plants  specifically using the more
  sophisticated dispersion model  (ISC-LT)  is  not warranted.
  B.6.2   Exposed  Populations
      Several  simplifying assumptions were made with  respect  to  the
  assumed  exposed population.  The location of  the  exposed population
  depends  on the accuracy  of the  census data in the HEM.  In addition, the
  exposed  population was  assumed  to  be immobile, remaining at  the same
  location 24  hours per day, 365  days per year, for a  lifetime (70 years).
  This assumption may be counterbalanced to some extent (at least in the
  calculation  of incidence) by the assumption that no one moves into the
 exposure area either permanently as a resident or temporarily as a
 transient.  The population "at risk" was assumed to reside within  20 km
 of each plant regardless of the estimated concentration at that point.
 The selection of 20 km is considered to be a practical modeling stop-point
 considering the uncertainty of dispersion estimates beyond 10 km.   The
 results of dispersion modeling are  felt to be reasonably accurate  within
 that distance (see above).  The uncertainty of these assumptions has not
'been quantified.
                                 B-23

-------
B.6.3  Unit Risk Factor
     The unit risk factor contains uncertainties associated with the
occupational studies of Infante, Aksoy, and Ott, and the variations in
the dose/response relationships among the studies.   Other uncertainties
regarding the occupational studies and the workers exposed that may
affect the unit risk factor were raised during the public comment period
and focus on assumptions and inconclusive data contained in the studies.
However, those uncertainties have not been quantified.
B.6.4  Other Uncertainties
     There are several uncertainties associated with estimating health
impacts.  Maximum lifetime risk and annual leukemia incidence were
calculated using the unit risk factor, which is based on a no-threshold
linear extrapolation of leukemia risk and applies to a presumably healthy
white male cohort of workers exposed to benzene concentrations in the
parts per million range.   It is uncertain whether the unit risk factor
can be accurately applied to the general  population, which includes men,
women, children, nonwhites, the aged, and the unhealthy, who are exposed
to concentrations in the parts per billion range.   It is uncertain
whether these widely diverse segments of the population may have
susceptabilities to leukemia that differ from those of workers in the
studies.  Furthermore, while leukemia is  the only benzene health effect
considered in these calculations, it is not the only possible health
effect.   Other health effects, such as aplastic anemia and chromosomal
aberrations, are not as easily quantifiable and are not reflected in the
risk estimates.   Although these other health effects have been observed
at occupational  levels, it is not clear if they can result from ambient
benzene exposure levels.   Additionally, benefits that would affect the
general  population as the result of indirect control of other organic
emissions in the process of controlling benzene emissions from benzene
storage tanks are not quantified.   Possible benzene exposures from other
sources also are not included in the estimate.   For example,  an individual
living near a benzene storage tank is also exposed  to benzene emissions
from automobiles.   Finally, these estimates do  not  include possible
cumulative or synergistic effects of concurrent exposure to benzene and  .
other substances.
                                 B-24

-------
B.8  REFERENCES

1.   Systems Applications, Inc.  Human Exposure to Atmospheric Concentra-
     tions of Selected Chemicals.  (Prepared for the U.S. Environmental
     Protection Agency, Research Triangle Park, North Carolina).
     Volume I, Publication Number EPA-2/250-1, and Volume II, Publication
     Number EPA-2/250-2.   May 1980.

2.   Busse, A.D.  and J.R.  Zimmerman.   User's Guide for the Climatological
     Dispersion Model.  (Prepared for the U.S. Environmental Protection
     Agency, Research Triangle Park,  North Carolina.)  Publication
     Number EPA-R4-73-024.  December 1973.

3.   Albert, R.  E.   Carcinogen Assessment Group's Final  Report on
     Population Risk to Ambient Benzene Exposures.   U.S.  Environmental
     Protection Agency.   Publication  No.   EPA-450/5-80-004   Docket
     Number A-79-27-II-A-28.   January 1979.
                                B-25

-------
TECHNICAL REPORT DATA
fflease read Instructions on the reverse before completing)
EPA-450/3-84-004

4. TITLE AND SUBTITLE
Benzene Storage Tanks - Background Information for
Proposal to Withdraw Proposed Standards
7. AUTHOR(S)
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Office of Air Quality Planning and Standards
Environmental Protection Agency
Research Triangle Park, North Carolina 27711
12. SPONSORING AGENCY NAME AND ADD
DAA for Air Quality Planning
Office of Air and Radiation
U.S. Environmental Protectior
Research Triangle Park, North
RESS
and Standards
i Agency
i Carolina 27711
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
March 1984
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-3063
13- JYPEpOF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMtN IAHY NOTES 	 — 	
It is proposed to withdraw the proposed National Emission Standards for
Hazardous Air Pollutants for the control of Benzene emissions from
Benzene Storage Tanks. Previously, standards had been proposed under
Section 112 of the Clean Air Act. This document contains background
information considered in the proposed withdrawal of those previously
proposed standards.
                                  KEY WORDS AND DOCUMENT ANALYSIS
                   DESCRIPTORS
                                                 b.lDENTIFIERS/OPEN ENDED TERMS
                                                                                 COSATI Field/Or
Air  pollution
 'ol lution control
 storage tanks
Floating roof and  seal  systems
Chemical  manufacturing  plants
Benzene
          Emissions  standards for Hazardous
  Air Pollution Control
13 B
                                                 19 SECURITY CLASS (This Report,
                                                                              ;21. NO. OF PAGES
    Unlimited
I 20 SECURITY CLASS /THispaget
i     Unclassified
                                                                              I22 PPICE
                                    ing
EPA Form 2220-1 (Rev. 4-77)    PREVIOUS EDITION is OBSOLETE

-------