&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 ------- |