United States
             "Environmental Protection
             Agency
            Office of Air Quality
            Planning and Standards
            Research Triangle Park NC 27711
EPA-450/3-84-018
December 1984
             Air
&EPA
Survey of
Ethylene
Dichioride
Emission Sources

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                               EPA-450/3-84-018
Survey of  Ethylene Dichloride
         Emission Sources
        Emission Standards and Engineering Division
       U.S. ENVIRONMENTAL PROTECTION AGENCY
             Office of Air and Radiation
        Office of Air Quality Planning and Standards
       Research Triangle Park, North Carolina 27711

                December 1 984

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

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                            TABLE OF CONTENTS

                                                                    Page

Preface	     ii

Table of Contents	   in

List of Tables	   vi

List of Figures	viii

1.    INTRODUCTION AND SUMMARY	1-1

     1.1  INTRODUCTION	1-1

     1.2  SUMMARY	1-1

          1.2.1  Industry Description  	   1-1
          1.2.2  Emission and Cost-Effectiveness Data	1-2
          1.2.3  Regulatory Requirements 	   1-4

2.    CHEMICAL PLANTS	2-1

     2.1  ETHYLENE DICHLORIDE PRODUCTION AND USE 	   2-1

          2.1.1  Ethylene Dichloride Production  	   2-1
          2.1.2  Vinyl Chloride Monomer Production 	   2-2
          2.1.3  Ethyl Chloride Production 	   2-3
          2.1.4  Methyl Chloroform Production  	   2-3
          2.1.5  Ethyleneamines Production 	   2-4
          2.1.6  Perchloroethylene and Trichloroethylene
                 Production	2-5

     2.2  PROCESS VENTS	   2-6

          2.2.1  Current Controls and Emissions  	   2-6
          2.2.2  Additional Controls 	   2-7

     2.3  FUGITIVE SOURCES 	   2-8

          2.3.1  Current Controls and Emissions  	   2-8
          2.3.2  Additional Controls 	   2-9

     2.4  SECONDARY EMISSIONS  	   2-9

          2.4.1  Emission Sources  	   2-9
          2.4.2  Current Controls and Emissions  	   2-10
          2.4.3  Additional Controls 	   2-10
                                  m

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                      TABLE OF CONTENTS (continued)

                                                                    Page

     2.5  STORAGE TANKS	2-11

          2.5.1  Current EDC Storage Patterns  	  2-11
          2.5.2  Current Controls and Emissions  	  2-16
          2.5.3  Additional Emission Control Techniques  	  2-17

     2.6  TANK TRUCK/RAIL CAR/BARGE LOADING  	  2-20

          2.6.1  Emission Sources  	  2-20
          2.6.2  Current Controls and Emissions  	  2-21
          2.6.3  Additional Controls 	  2-22

     2.7  REFERENCES	  2-68

3.   PUBLICLY OWNED TREATMENT WORKS  	  3-1

     3.1  ETHYLENE DICHLORIDE SOURCES AND EMISSIONS  	  3-1

     3.2  REFERENCES	  3-7

4.   PHARMACEUTICAL MANUFACTURING PLANTS 	  4-1

     4.1  ETHYLENE DICHLORIDE SOURCES AND EMISSIONS  	  4-1

     4.2  REFERENCES	4-4

5.   LEAD SCAVENGER BLENDING FACILITIES  	  5-1

     5.1  ETHYLENE DICHLORIDE USE AND EMISSIONS  	  5-1

     5.2  REFERENCES	"	5-14

6.  MISCELLANEOUS USES AND EMISSION SOURCES  	  6-1

     6.1  ETHYLENE DICHLORIDE SOURCES AND EMISSIONS  	  6-1

          6.1.1  Paints,  Coatings, and Adhesives  	  6-1
          6.1.2  Extraction Solvent	  !	6-2
          6.1.3  Cleaning Solvent  	  6-2
          6.1.4  Polysulfide Rubber Production 	  6-3
          6.1.5  Grain Fumigant	  6-3
          6.1.6  Liquid Pesticide Formulations ...  	  6-4
          6.1.7  Miscellaneous  EDC Uses	'.'	6-5
          6.1.8  Volatilization From Waste Treatment,  Storage,
                 and,  Disposal  Facilities  	  6-5

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                      TABLE OF CONTENTS-(continued)
     6.2  REFERENCES	6-6

APPENDIX A:   SAMPLE CALCULATIONS FOR CONTROL COSTS AND
             COST EFFECTIVENESS	A-l

     A-l:   SAMPLE CALCULATIONS FOR FUGITIVE COSTS  	  A-l

     A-2:   SAMPLE COST CALCULATIONS FOR INSTALLING INTERNAL
           FLOATING ROOFS IN FIXED ROOF TANKS  	  A-3

     A-3:   SAMPLE COST CALCULATIONS FOR CONDENSER SYSTEMS
           (Storage Tanks and Process Vents) 	  A-7

     A-4:   SAMPLE CALCULATIONS FOR SHIPPING COSTS  	  A-11

     A-5:   SAMPLE COST CALCULATIONS FOR CONTROL OF PROCESS
           EMISSIONS	A-14

REFERENCES   	A-24

APPENDIX B:   EXISTING STATE REGULATIONS  	  B-l

REFERENCES   	:	B-2

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                             LIST OF TABLES

Table                                                               paqe
""•™"^™t—-—                                                               «MI«J*^^

1-1   Ethylene Dichloride Emissions and Potential
      Emission Reductions  	  1-5

1-2   Volatile Organic Compound Emissions and Potential
      Emission Reductions  	  1-6

1-3   Estimated Ethylene Dichloride Emission Reductions From
      Chemical Plants as a Function of Cost Effectiveness  ....  1-7

1-4   Estimated Volatile Organic Compound Emission Reductions
      From Chemical Plants as a Function of Cost Effectiveness .   .  1-8

1-5   Ethylene Dichloride Emission Reduction From Lead Scavenger
      Blending Facilities as a Function of Cost Effectiveness  .   .  1-9

1-6   Volatile Organic Compound Emission Reduction From Lead
      Scavenger Blending Facilities as a Function of Cost
      Effectiveness  	  1-10

2-1   Physical Properties of Ethylene Dichloride 	  2-23

2-2   Chemical Plants Producing and/or Using Ethylene Dichloride  .  2-24

2-3   Sources of Ethylene Dichloride Consumption in 1983 	  2-26

2-4   Costs for Retrofitting an Incineration System for the
      Reduction of EDC and VOC Process Emissions	2-27

2-5   VOC Emission Factors From Equipment Leaks  .	2-31

2-6   Costs for Implementation of Controls for EDC Fugitive
      Emission Sources 	  2-32

2-7   Costs for Implementation of Controls for VOC Fugitive
      Emission Sources 	  2-34

2-8   Control Techniques and Cost for VOC/EDC Fugitive
      Emission Sources	2-36

2-9   EDC and VOC Emission Reduction From Fugitive Emission
      Sources as a Function of Cost Effectiveness	2-37

2-10  Secondary EDC Emission Sources	  .  .   .  2-38

2-11  Nationwide EDC Storage Patterns	2-43
                                   VI

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                       LIST OF TABLES (continued)

Table                                                               Page

2-12  Controls Used on Existing Fixed Roof Tanks	2-44

2-13  Retrofit Costs for Welded Steel Internal Floatng Roofs .  .   .  2-45

2-14  EDC Emissions and Cost Data for Retrofitting Fixed Roof
      Storage Tanks with Internal Floating Roofs (Primary Seals)  .  2-46

2-15  EDC Emission Reduction From Fixed Roof Tanks as a Function
      of Cost Effectiveness	2-50

2-16  Fixed Roof Tank Summary	  2-51

2-17  VOC Emissions and Cost Data for Retrofitting Fixed Roof
      Storage Tanks With Internal Floating Roofs (Primary Seals)  .  2-52

2-18  EDC Emissions and Cost Data for Retrofitting Fixed Roof
      Storage Tanks With Internal Floating Roofs (Primary and
      Secondary Seals) 	  2-56

2-19  VOC Emissions and Cost Data for Retrofitting Fixed Roof
      Storage Tanks with Internal Floating Roofs (Primary and
      Secondary Seals) 	  2-60

2-20  EDC Emissions From Pressure Vessels	2-64

2-21  Pressure Vessel Summary Table  	  2-65

2-22  Costing Data for Control of Shipping Emissions 	  2-66

3-1   Estimated EDC Emissions From Publicly Owned Treatment Works.  3-4

4-1   Summary of Estimated EDC Use and Emissions in the
      Pharmaceutical Manufacturing Industry  	  4-3

5-1   Producers of Lead Scavenger Additive 	  5-4

5-2   Emission and Control Cost Data for Process Emissions ....  5-5

5-3   EDC Emissions and Cost Data for Retrofitting Fixed Roof
      Storage Tanks With Internal Floating Roofs (Primary Seals)  .  5-6

5-4   VOC Emissions and Cost Data for Retrofitting Fixed Roof
      Storage Tanks With Internal Floating Roofs (Primary Seals)  .  5-7
                                  vn

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                       LIST OF TABLES (continued)

Table                      .                                         Page

5-5   EDC Emissions and Cost Data for Retrofitting Fixed Roof
      Storage Tanks With Internal Floating Roofs (Primary and
      Secondary Seals) 	  5-8

5-6   VOC Emissions and Cost Data for Retrofitting Fixed Roof
      Storage Tanks With Internal Floating Roofs (Primary and
      Secondary Seals)	5-9

5-7   Costs for Implementation of Control Techniques for EDC
      Fugitive Emission Sources  	  5-10

5-8   Costs for Implementation of Control Techniques for VOC
      Fugitive Emission Sources  	  5-11

5-9   Secondary EDC Emission Sources 	  5-12

5-10  EDC Emission Summary	5-13

A-l   Control Techniques and Cost for VOC/EDC Fugitive
      Emission Sources 	  A-17

A-2   Fugitive Emissions Control Cost Calculations 	  A-18

A-3   Total Installed Capital Cost for Incinerators as a Function
      of Off gas Flowrate	A-20

A-4   Annualized Cost Factors for Incinerators 	  A-21

A-5   Operating Factors for Incinerators 	  A-22

A-6   Annualized Cost Equations for Incinerators 	  A-23
                             LIST OF FIGURES

Figure

                                                                    Page

2-1    Internal Floating Roof Tanks  	  2-13

A-3.1  Installed Capital Cost vs Flow Rate for Complete Condenser
       System With a VOC Removal Efficiency of 95 Percent  ....  A-9

A-3.2  Annual Cost vs Flow Rate for Complete Condenser System
       With VOC Removal Efficiency of 95 Percent   	A-10
                                  vi n

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                      1.  INTRODUCTION AND SUMMARY

1.1  INTRODUCTION
     This document describes the various sources of emissions of ethylene
dichloride (EDC) and provides information on the location, emission rate,
and control technologies which are being used for specific sources.  Also
provided in this document is information relating to opportunities to
reduce EDC emissions and the cost of reducing emissions below current
levels.  This information will be used by the EPA along wfth other
information, such as health effects data, to decide whether specific
sources of EDC should be regulated under the Clean Air Act.
1.2  SUMMARY
1.2.1  Industry Description
     Ethylene dichloride ranks No.  16 in nationwide chemical production;
approximately 9.5 xlO6 Megagrams (Mg) (10.5 xlO6 tons) were produced in
1982.   It is used primarily as a feedstock in the manufacture of other
products.   In 1983, 84.7 percent of domestic EDC consumption was used for
the manufacture of vinyl chloride monomer (VCM), 6.1 percent for ethyl
chloride,  3.4 percent for methyl chloroform amines, 2.0 percent for
ethyleneamines, 1.9 percent for perchloroethylene (PCE), 1.5 percent for
trichloroethylene (TCE), 0.3 percent for lead scavenger additives to
leaded gasoline, and 0.1 percent for miscellaneous uses such as the
processing of Pharmaceuticals, grain fumigants, and pesticides.
     For the purposes of this report, the following categories of EDC
emissions  have been defined:  chemical  plants, publicly owned treatment
works  (POTW's), pharmaceutical manufacturing plants, lead scavenger
additive blending facilities and gasoline marketing facilities (bulk
                                   1-1

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terminals, bulk plants, and service stations), and miscellaneous EDC-
consuming industries.
1.2.2  Emission and Cost-Effectiveness Data
     Emission estimates were gathered from several sources.   Estimates
for chemical plants and lead scavenger additive blending facilities came
from industry responses to information requests.   The POTW estimates are
based on emission models developed in another EPA study.  Pharmaceutical
plant emissions were approximated using data provided by the Pharmaceutical
Manufacturers Association.  Finally, the estimates in the miscellaneous
category were extracted from various literature sources.
     The total estimated EDC emissions from each of the source categories
are presented in Table 1-1.  The emission rates are presented for
several emission sources within each category.  These emission sources
are fugitive (e.g., equipment leaks), storage tanks, secondary (e.g.,
evaporative emissions  from wastewater treatment), process vents, and
shipping (e.g., loading of tank trucks, rail cars, or barges).  For some
categories, the emission source could not be defined with-in the scope of
this study.  These emission sources are categorized as "unassigned" in
Table 1-1.  Approximately 0.2 percent of the total EDC produced is
emitted to the atmosphere.  Ethylene dichloride is a volatile organic
compound (VOC), and Table 1-2 presents total estimated VOC emissions
(including EDC) from each category.  Tables 1-1 and 1-2 also present the
emission .reductions possible (in parentheses) for EDC and VOC, respectively.
     Emissions of EDC  from all chemical plants with current controls
total approximately 4,100 Mg/yr (4,500 tons/yr).   Significant emission
reductions can be realized at the chemical plants through the application
of efficient control techniques on most of the sources.  Fugitive emissions
can be decreased through a combination of leak detection and repair
programs involving periodic inspections and the application of equipment
control devices.  Storage tank emissions can be mitigated through the
installation of internal floating roofs on fixed roof tanks.  Secondary
emissions can be reduced through the use of recovery equipment on the
waste streams.  Process emissions provide the least opportunity for
further control because nearly all are currently well controlled, mainly
due to the effects of the national emission standards for vinyl chloride.
                                   1-2

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Shipping emissions can be reduced by the application of recovery systems
such as refrigerated condensers.  Table 1-3 presents the EDC emission
reductions possible from chemical plants as a function of the cost
effectiveness of control.  Table 1-4 presents the same information for
VOC emission reductions.
     In recent work sponsored by the EPA, some POTW's were identified as
sources of EDC emissions.  This identification was made by examining
mass-balance data from 50 POTW's.  The mass-balance data were used along
with information on the type of treatment used at POTW's and the standard
Industrial Classification Codes of the dischargers to extrapolate EDC
emissions from the estimated 355 POTW's nationwide that emit EDC.  These
355 POTW's were estimated to emit approximately 7,300 Mg/yr (8,050 tons/yr)
of EDC.  However, recent testing in Philadelphia, Pennsylvania, indicates
that for the Philadelphia POTW, the emission estimate may overstate EDC
emissions by a factor of 8 to 10.  Further testing is planned in Baltimore,
Maryland, to determine if the emission estimates can be lowered universally.
Effluent limitations guidelines for the organic chemical, plastic, and
synthetic fiber industries are to be promulgated in approximately 6 months.
Compliance with these guidelines will reduce the amount of EDC in the
wastewater streams discharged to POTW's, and therefore, EDC emissions
from POTW's will also be reduced.  The net reduction in EDC emissions may
be offset by an increase in air emissions at some dischargers subject to
the guidelines.
     Pharmaceutical manufacturing plants may emit as much as 800 Mg/yr
(880 tons/yr) of EDC to the atmosphere and another 500 Mg/yr (550 tons/yr)
may be discharged to POTW's.   A separate study of the pharmaceutical
industry would be needed to determine the specific opportunities for EDC
emission reductions.
     Approximately 75 Mg/yr (85 tons/yr) of EDC are emitted by facilities
that manufacture lead scavenger additive for use in leaded gasoline.  The
emission sources and control  technologies for this category are similar
to those for the chemical plant category.  Tables 1-5 and 1-6 present EDC
and VOC emission reductions,  respectively, possible from lead scavenger
blending facilities as a function of the cost effectiveness of control.
Approximately 245 Mg/yr (270 tons/yr) of EDC are emitted from leaded
                                   1-3

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gasoline marketing sources (i.e., bulk terminals, bulk plants, and
service stations).  It should be noted that EDC emissions from these
leaded-gasoline-related sources will decline because of the phase-down of
leaded gasoline.
     An EPA study (made available as this document was being prepared)
indicates that approximately 5,300 Mg/yr (5,900 tons/yr) of EDC may be
emitted from the miscellaneous industry category.  Industries in this
category include the manufacture of paints, coatings, and adhesives;
extraction and cleaning solvents; grain fumigants; color film; pesticides
and herbicides; and copper ore leaching solvents.  Emission estimates
range from 100 percent of the EDC used in grain fumigants to 0 percent of
that used to leach copper ore.  Further study of the miscellaneous
industries would be required to determine the specific opportunities for
emission reductions.
1.2.3  Regulatory Requirements
     The 23 chemical and lead scavenger additive plants that produce/use
EDC are located in six States:  Louisiana, Texas, Kentucky, California,
Kansas, and New Jersey.  Of these, Louisiana and Texas contain 19 of the
23 plants.  All have general VOC emission regulations that are applicable
to the regulation of EDC emissions.  New Jersey also regulates emissions
of EDC as part of its air toxics program.   Ethylene dichloride emissions
are also reduced as a result of the national emission standard at the
11 chemical plants that produce both VCM and EDC.  Specific aspects of
each State's regulations for these sources are discussed in Appendix B.
     Other sources of EDC emissions (i.e., POTW's pharmaceutical manu-
facturing plants, gasoline marketing facilities, and miscellaneous
consumers) are located throughout the United States.  State regulations
for reducing EDC emissions from these categories were not investigated in
preparation of this report.
                                   1-4

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                     TABLE 1-1.   ETHYLENE  DICHLORIDE EMISSIONS AND POTENTIAL EMISSION REDUCTIONS
I
en

Category/source Fugitive
Chemical plants 1,900
(1,350)
POTW's
Pharmaceutical
Lead scavenger addi- 11
tive blending and (9)
gasoline marketing
Miscellaneous

TOTAL
Current
Storage
tanks
730
(575)
--
--
21
(20)
--


emissions (emi
Secondary
650
(165)
7,300f
500g
2
(0)
--


ssion reduction potential).
Process
vents
420
(5)
--
--
41
(41)
--


, Mg/yra
d Un~ e
Shipping assigned
230
(185)
--
0
(0)
0
(0)
--


—
--
800
g
245
5,300
g


Total
3,930
(2,280)
7,300
1,300
320 .
(70)h
5,300

-18,150
(-2,350)
      .Numbers in parentheses represent emission reduction potential  regardless of cost.
       Treatment of EDC-laden wastewater.
       .Process sources include vents from reactors,  distillation columns,  process tanks,  etc.
       Tank truck, rail car, and barge loading.
      ^Specific source of emissions not known.
       Emission estimate based on mass-balance model.
      ^Further analysis of these sources would no doubt reveal  some emission reduction potential
      .the potential could not be calculated with the information available for this report.
       Total reduction of EDC emissions may result from phase-out of leaded gasoline.
However,

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            TABLE 1-2.  VOLATILE ORGANIC COMPOUND EMISSIONS AND POTENTIAL EMISSION REDUCTIONS

Category/source Fugitive
Chemical plants 3,290
(2,390)
POTW's
Pharmaceutical
Lead scavenger addi- 48
tive blending (43)
Miscellaneous
TOTAL
Current emissions (emi
Storage .
tanks Secondary
840 170f
(715) (165)
__
_-
80
(74)
__

ssion reduction potential), Mg/yra
Process
vents
2,270
(1,290)
--
--
63
(60)
--

d Un" e
Shipping assigned Total
190f — 6,760
(185) (4,745)
—
—
190
(180)
--
-6,950
(-4,925)
^Numbers in parentheses represent emission reduction potential regardless of cost.
 Treatment of EDC-laden wastewater.
d$ources include vents from reactors, distillation columns, process tanks, etc.
gTank truck, rail car, and barge loading.
fSpecific source of emissions not known.
 No non-EDC VOC data reported.

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 TABLE 1-3.   ESTIMATED ETHYLENE DICHLORIDE EMISSION-REDUCTIONS FROM CHEMICAL
                 PLANTS AS A FUNCTION OF COST EFFECTIVENESS
Cost effec-
tiveness
range, $/Mg
      Nationwide emission reduction, Mg EDC/yr
Fugitive
Storage
  tanks
Second-
   da ry
Process
  vents
Loading
Credit

0-500

500-1,000

1,000-2,000

>2,000

     TOTAL
     305

     930

     115



   1,350
    345

     70

     95

     25

     40

    575
                          185
    165

    165
     _5

      5
    185
                                    1-7

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    TABLE 1-4.  ESTIMATED VOLATILE ORGANIC COMPOUND EMISSION REDUCTIONS
         FROM CHEMICAL PLANTS AS A FUNCTION OF COST EFFECTIVENESS
Cost effec-
tiveness
range, $/Mg
Credit
0-500
500-1,000
1,000-2,000
>2,000
TOTAL
Nationwide emissi
Fugitive
—
2,280
110
—
	
2,390
Storage
tanks
480
75
90
30
40
715
on reducti
Second-
da ry
—
--
—
—
165
165
on, Mg VOC/yr
Process
vents Loading
—
185
—
1,285
J
1,290 185
No non-EDC VOC data reported by plants.
                                   1-8

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     TABLE 1-5.   ESTIMATED ETHYLENE DICHLORIDE EMISSION REDUCTION FROM
  LEAD SCAVENGER BLENDING FACILITIES AS A FUNCTION OF COST EFFECTIVENESS
Cost effec-
tiveness
range, $/Mg
Credit
0-500
500-1,000
1,000-2,000
>2,000
TOTAL
Nationwide emissi
Fugitive
—
—
8
—
J.
9
Storage
tanks
—
—
—
—
20
20
on reduction,, Mg EDC/yr
Second- Process
dary vents Loading
—
—
—
__
41
41 0
No loading reported by plants.  .
                                   1-9

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     TABLE 1-6.  ESTIMATED VOLATILE ORGANIC COMPOUND  EMISSION  REDUCTION
                FROM LEAD SCAVENGER BLENDING FACILITIES AS  A
                       FUNCTION OF COST EFFECTIVENESS
Cost effec-
tiveness
range, $/Mg
Credit
0-500
Nationwide emission reduction, Mg VOC/yr
Fugitive
37
6
Storage
tanks
—
Second-
dary
—
Process
vents
—
Loading
—
500-1,000

1,000-2,000               —          21

>2,000                    II          53          II         60

     TOTAL                43          74          --         60

jjNo VOC data reported by plants.
 No loading reported by plants.
                                    1-10

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                           2.   CHEMICAL PLANTS

2.1  ETHYLENE DICHLORIDE PRODUCTION AND USE
     Ethylene dichloride (1,2-dichloroethane) is a clear, colorless, oily
liquid with a chloroform-like,  sweet odor and taste.1  Ethylene dichloride
is used as a raw material in the production of vinyl  chloride monomer
(VCM), various ethyleneamines,  methyl chloroform (1,1,1-trichloroethane),
ethyl chloride, trichloroethylene (TCE), and perch!oroethylene (PCE).
Its physical properties are presented in Table 2-1.  The major domestic
producers and users of EDC are listed in Table 2-2.  The consumption of
EDC is summarized in Table 2-3.  Production of EDC and its use in other
chemical production processes are discussed in Section 2.1.1 through
2.1.6.  Emissions of EDC at chemical plants come from five primary
sources:  process vents; equipment leaks; secondary sources; storage
tanks; and truck, rail car or barge loading.  These emission sources and
applicable control technologies are discussed in Sections 2.2.1 through
2.2.5, respectively.
2.1.1  Ethylene Dichloride Production
     Ethylene dichloride is produced in the United States by direct
chlorination of ethylene, oxychlorination of ethylene, or a combination
of these methods.  Also, one corporation reported production of about
2 million pounds per year of EDC as a byproduct of the manufacture of a
fire retardant  for urethane foam.
     Direct chlorination of ethylene is accomplished in  either the liquid
or vapor phase  according to the catalytic reaction:2
     CH2=CH2     +     C12      *     C1CH2CH2C1
     ethylene        chlorine            EDC
                                  2-1

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Actual yields are as high as 96 to 98 percent of theoretical yields.2
Catalysts mentioned most often in the patent literature include ferric,
aluminum, cupric, and antimony chlorides.3  The majority of industries
use ferric chloride catalysts and liquid-phase reaction conditions.2  One
vapor-phase procedure reacts ethylene and chlorine at 40° to 50°C (105°
to 120°F) in the presence of an ethylene dibromide (EDB) catalyst.3,4.
     The oxychlorination of ethylene proceeds via the catalytic reaction:5
   •
     2 CH2=CH2 + 02    +      4 HC1        *   2 C1CH2CH2 + 2 H20
     ethylene   oxygen   hydrogen chloride          EDC      water
Actual yields are usually about 90 percent of theoretical yields.6  This
reaction is normally carried out  in the vapor phase in either a fixed-bed
or fluid-bed reactor.2  Cupric chloride is the most common  catalyst for
this reaction.  Typically, the reaction pressure and temperature are
maintained at 138 to 483 kilopascals (kPa) (20 to 70 pounds per square
inch, gauge [psig]) and 200° to 315°C (390° to 600°F), respectively.  The
oxygen for this reaction may be provided in the pure form or obtained by
adding air to the reaction vessel.3
     When the EDC produced is used on site to manufacture VCM, the
oxychlorination and direct chlorination processes are often used in
combination in what is known as the balanced process.  Most facilities
use the  balanced  process.  Vinyl  chloride monomer is produced by the
dehydrochlorination of EDC which  also produces HC1 as a  byproduct.  The
HC1 can  be used  in the oxychlorination of ethylene to produce more  EDC.3
2.1.2  Vinyl  Chloride Monomer Production
      Approximately 96 percent of  the VCM produced domestically in 1979
was made from EDC.7. The VCM product is purified by distillation and  is   .
usually  sold  for  the production of polyvinyl chloride  (PVC).8
      In  the production of VCM,  EDC vapor  is cracked  in  a pyrolysis
furnace  via the  dehydrochlorination  reaction as  follows:
      C1CH2CH2C1    £     CH2=CHC1     +     HC1
          EDC              VCM      hydrogen chloride
                                   2-2

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About 50 percent conversion of EDC to VCM is achieved in the reaction.
Temperatures and pressures of 450° to 620°C (840° to 1150°F) and 450 to
930 kPa (65 to 135 psig) are usually used.   The process gas stream from
the furnace is separated into EDC, VCM, and HC1 by condensation.  The
unreacted liquid EDC is recycled back to the furnace, and the HC1 is
usually used on site in the production of EDC by the oxychlorination
process.
2.1.3  Ethyl Chloride Production
     Ethyl chloride is used as a refrigerant, solvent, and alkylating
agent and as a starting point in the manufacture of tetraethyl  lead.9
     About 90 to 95 percent of the ethyl chloride produced in the United
States comes from the hydrochlorination of ethylene.  In this process,
equimolar amounts of ethylene and anhydrous hydrogen chloride are mixed
and introduced into a reactor containing EDC or a mixture of EDC and
ethyl chloride.10  The exothermic hydrochlorination of ethylene takes
place in the presence of a catalyst such as aluminum chloride.10,11  The
vaporized products are fed into a column or flash drum to remove .heavier
products, and the crude ethyl chloride is purified by fractional distil-
lation.10
     Ethyl chloride is also produced by the thermal chlorination of
ethane or by a combination of ethane chlorination and ethylene  hydro-
chlorination.  Ethylene dichloride is a byproduct of both processes.10
2.1.4  Methyl Chloroform Production
     Methyl chloroform (1,1,1-trichloroethane) is used predominantly as a
metal-cleaning solvent and is produced domestically by three processes.12
In 1975, about 60 percent was produced by the hydrochlorination of VCM,
and about 30 percent was produced by the hydrochlorination of vinylidene
chloride.  The remaining 10 percent was produced by the chlorination of
ethane.12  Ethylene dichloride is involved only in the first technique of
methyl chloroform production.  Although EDC is not used directly as a
feedstock for methyl chloroform production, emissions of EDC may occur if
it is an impurity in VCM or from inadvertent EDC production in  the
hydrochlorination and chlorination reactors.12
                                  2-3

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     Methyl chloroform is produced from VCM by the catalytic hydrochlor-
ination of VCM to 1,1-dichloroethane followed by thermal chlori.nation to
methyl chloroform.12
                                      Fed 3
     CH2=CHC1 +         HC1           	>          CH3CHC12
   »
       VCM       hydrogen chloride                1,1-dichloroethane

         CH3CHC12       +   C12    •*      CH3CC13      +       HC1
     1,1-dichloroethane   chlorine   methyl chloroform   hydrogen chloride
The HC1 generated in the thermal chlorination step is generally recycled
to react with VCM in the catalytic hydrochlorination step.13  The catalytic
hydrochlorination reaction is exothermic and usually takes place at 35°
to 40°C (95° to 105°F) in the presence of ferric chloride or ferric
copper catalyst.12,13  The thermal chlorination reaction is also exothermic
but noncatalytic and occurs at about 400°C (750°F).12  The overall yields
from VCM are reported to be over 95 percent.13
2.1.5  Ethyleneamines Production
     Ethyleneamines are used in the production of carbaniate fungicides,
chelating agents, dimethylethylene urea resins, and diaminoethylethanol.14
     In 1979, all ethyleneamines were produced by reacting EDC and
ammonia.5  More recently, some ethyleneamines have also been produced
from ammonia and ethylene oxide.15  The major product of both reactions
is ethylenediamine; however, the ethylene oxide process is reportedly
more selective for ethylenediamine with only small quantities of byproducts
such as diethylenetriamine, triethylenetetramine, tetraethylenepentamine,
pentaethylenehexamine, and higher polymers.14,15
     The reaction between EDC and ammonia can be performed in either the
liquid or vapor phase.  In the vapor phase reaction, EDC and an excess of
anyhydrous ammonia are reacted at 150°C (300°F) and 9.0 MPa (1,305 psi)
in a pressure reactor.  The product of this reaction is anhydrous ethlene-
diamine hydrochloride, which is treated with sodium hydroxide at 100°C
(212°F) to yield free ethylenediamine.   The product amine, or mixture of
amines, is separated and purified by fractional distillation, and the
                                  2-4

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excess ammonia is recovered and recycled.   The mixture of product ethylene-
amines is controlled by the reaction conditions and the mix of reactants.14
With a 15:1 ratio of ammonia to EDC, the yield of ethylenediamine is
about 50 percent.1S
2.1.6  Perchloroethylene and Trichloroethylene Production
     Perch!oroethylene is used primarily as a dry-cleaning, textile-
processing, and metal-cleaning solvent.16  Trichloroethylene is used
primarily as a metal-cleaning solvent.16  Perchloroethylene and trichloro-
ethylene can be produced separately or as co-products.  Initially, both
PCE and TCE were produced from acetylene.   As EDC production capacity
increased to produce VCM, and as ethylene became more available and less
expensive, it became economical to also use EDC to manufacture PCE and
TCE.  The last acetylene-based PCE and TCE plant was closed in 1977.16,17
     Both PCE and TCE are now manufactured by the chlorination or oxy-
chlorination of EDC or other chlorinated ethanes.16,17,18  In 1979,
49 percent of PCE and 91 percent of the TCE produced in the United States
were made from EDC.5  The chlorination process proceeds via the noncatalytic
reactions:6

     C1CH2CH2C1 +  3 C12    A C12=CC12 +       4 HC1
       •  EDC     chlorine      PCE       hydrogen chloride

     C1CH2CH2C1 +  2 C12    A  CHC1=CC12 +      3 HC1
         EDC     chlorine         TCE       hydrogen chloride
The reaction is  usually carried out at about 400° to 455°C (750°  to
850°F) and at a  pressure of slightly above one atmosphere.  The HC1
byproduct can be utilized by other processes.  The  PCE  or TCE product  is
scrubbed with sodium hydroxide and purified.16
     The oxychlorination of EDC to PCE or TCE proceeds  via the catalytic
reactions:5
     C1CH2CH2C1  +    C12     +  02     -»• C12C=CC12 + 2  H2 0
         EDC       chlorine    oxygen      PCE          water
                                   2-5

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     C1CH2CH2C1 +  1/2 C12  + 3/4 02  -* CHC1=CC12 + 3/2 H2 0
        EDC       chlorine    oxygen      TCE         water
Copper chloride is used as a catalyst.  The reaction is usually carried
out at about 425°C (795°F) and at a pressure of slightly above one
atmosphere.16  Hydrogen chloride can also be used as a reactant in the
oxychlorination process.  When HC1 is used, additional 02 is also required.6
The amount of PCE and TCE produced by both the chlorination process and
the oxychlorination process is controlled by the reactant concentra-
tions.16,17,18
2.2  PROCESS VENTS
     Ethylene dichloride can be emitted from process vents during its
production and when it is used as a feedstock for manufacturing other
chemicals.  In both the direct chlorination and oxychlorination of
ethylene to produce EDC, process emissions can originate from the purging
of inert gases from reactor vessels and from drying, heads, and finishing
columns.   In the dehydration of EDC to produce VCM, unreacted EDC can be
present in distillation column streams.   Process emissions of EDC from
the production of ethyl chloride can come from reactor vessels and
distillation columns.   Emissions of EDC in methyl chloroform production
result from the presence of EDC as an impurity in the VCM feedstock or
the production of EDC in the hydrochlorination and chlorination reactions.
The hydrochlorination vents and steam stripper gas effluent vents (used
to purify methyl chloroform) are the major process sources of EDC emissions.
Vents from reactor vessels and dehydration and distillation columns are
potential sources of EDC emissions in ethyleneamines production.   During
production of PCE and TCE, process emissions of EDC can result from the
purging of inert gases in the neutralization and drying processes and
from distillation columns.  Table 2-4 identifies process vents in EDC
service on a plant-specific basis.
2.2.1  Current Controls and Emissions
     Thermal oxidation in incinerators or boilers is the control  used on
all but one process vent in EDC service at chemical plants.  Emissions
from several vents are typically ducted to a common incinerator or
boiler.   The destruction efficiency in these devices is typically
                                  2-5

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98 percent or greater, with some companies reporting values as high as
99.99 percent when the incinerator or boiler is also used to destroy
hazardous wastes, as defined by the Resource Conservation and Recovery
Act.   (In this study, a 98 percent removal efficiency was assumed unless
the company claimed test data to substantiate a higher efficiency.)  The
one process vent not controlled by thermal oxidation is controlled by an
absorber with a reported EDC removal efficiency of 90 percent.
     Current EDC and VOC emissions from process vents at chemical plants
total approximately 420 and 2,250 megagrams/year (Mg/yr) (460 and
2,470 tons/yr), respectively.  Emission rates of EDC and VOC from each
process vent in EDC service are given in Table 2-4.
2.2.2  Additional Controls
     Where the existing control efficiency for process vents was found to
be less than 98 percent, the emission reductions and costs of installing
a 98 percent efficiency incinerator were calculated.  The cost estimate
for the incinerator includes a refractory-lined carbon steel mixing and
combustion chamber, 46 meter (m) (150 feet [ft]) of ductwork, fans for
offgas and combustion air, a waste heat boiler for heat recovery, a flue
gas caustic scrubber to remove and neutralize hydrogen chloride, and a
24-m (80-ft) high stack.  The  incinerator combustion temperature is
1100°C (2000°F), and  its residence time is 1 second.  These  incinerator
design parameters were based on those determined by the EPA  to be appro-
priate for streams containing  halogenated compounds, such as  EDC.19
     The capital and  annualized costs of applying  an incinerator to the
one process vent not  currently controlled with 98  percent efficiency was
calculated to be approximately $4,500,000 and $1,500,000, respectively
(see Table 2-4).  Emissions of EDC and VOC would be reduced  from 4 and
1,315 Mg/yr (4.4 and  1,445 tons/yr) to 0.1 and 26  Mg/yr (0.1 and 29 tons/yr),
respectively from this vent.   The  resulting cost-effectiveness values of
EDC and VOC control of this source are approximately $3,800,000/Mg
($3,400,000/ton) and  $l,170/Mg ($l,060/ton), respectively.   The  noticeable
difference in cost effectiveness of EDC and VOC control is  because the
company reports  a 90  percent EDC removal  efficiency of  their existing
control system and a  0 percent control for non-EDC VOC.   Calculations
showing derivation of capital  and  annualized costs are  given in  Appendix  A.
                                   2-7

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2.3  FUGITIVE SOURCES
     Process components in EDC service that are potential sources of
fugitive emissions are pump seals, compressors, flanges, valves, pressure
relief devices, sample connections, and open-ended lines (lines closed
during normal operation that would be used during maintenance operations).
Emission factors used in estimating fugitive VOC emissions from these
equipment types are shown in Table 2-5.
2.3.1  Current Controls and Emissions
     Currently, the majority of the facilities examined in this document
utilize some type of control technique on all or part of their fugitive
sources.  Those using in-plant monitoring systems were analyzed by EPA
and assigned an efficiency ranging from 0 to 100 percent based on a
judgment of the effectiveness of the system against one of known effec-
tiveness.  The control techniques judged to be effective (>0 percent
efficient) currently in use by industry are as follows:
     1.  Pressure relief devices vented to either a flare or an incinerator
(98 percent efficiency);
     2.  Closed loop sampling systems (100 percent efficiency);
     3.  Blind flange or secondary valve on all open ended lines
(100 percent efficiency);
     4.  Pressure relief devices equipped with rupture disks (100 percent
efficiency); and
     5.  Leak detection and repair program using ethylene dichloride
fixed point monitors for detecting pump, valve, flange and compressor
seal leaks (33 percent efficiency).
     Current fugitive emissions of EDC from chemical plants producing or
using EDC total 1,930 Mg/yr (2,120 tons/yr), and range from 2 to 360 Mg/yr
(2 to 395 tons/yr) per plant.  Fugitive emissions of VOC at these plants
total 3,370 Mg/yr (3,710 tons/yr) and range from 5 to 580 Mg/yr (6 to
640 tons/yr) of VOC per plant.  (See Tables 2-6 and 2-7 for plant-specific
information.)
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     For most plants, fugitive emissions were calculated by multiplying
the component fugitive emission factors (see Table 2-5) by the corresponding
number of components in a plant and summing the emissions for each
component type.   For four plants, data were insufficient to follow this
procedure.   Fugitive emissions were estimated at these plants by using an
average of the fugitive emissions calculated for similar plants.
2.3.2  Additional Controls
     This section presents the cost and removal efficiency of applying
the same fugitive emission controls that were adopted for control of
benzene fugitive emissions.20  The specific control techniques, control
efficiencies and capital and annualized costs per component are given in
Table 2-8.
     Tables 2-6 and 2-7  present the costs, EDC and VOC emission reduction
potential,  and cost effectiveness of controlling fugitive emissions on a
plant-specific basis.  By adopting the fugitive control program, EDC and
VOC emissions would be reduced by 1,350 and 2,390 Mg/yr (1,490 and
2,630 tons/yr),  respecively.  This would lower EDC and VOC emissions from
fugitive sources to 580 and 990 Mg/yr (640 and 1,090 tons/yr), respectively.
Table 2-9 summarizes the emission reduction potential and cost-effectiveness
data for EDC and VOC control.
     The cost effectiveness (based on EDC.) ranged from a low of $150/Mg
($135/ton)  to a high of about $l,600/Mg ($l,450/ton).  However, if VOC
emissions are considered the cost effectiveness of controls is under
$l,000/Mg ($910/ton) for all plants.  Sample calculations of the control
costs are given in Appendix A.
2.4  SECONDARY EMISSIONS
2.4.1  Emission Sources
     Secondary emissions are those air emissions resulting from the
treatment or disposal of wastewater, liquid waste, or solid wastes.  The
chemical plants surveyed identified several types of EDC-laden waste
streams, including process wastewater, contaminated floor drains, water
used to clean equipment, and residual heavy-ends and tars.  Table 2-10
identifies  the EDC-laden waste streams, treatment techniques used, and
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EDC emissions on a plant-specific basis.  Insufficient data were reported
to estimate total VOC emissions.
     Waste treatment or disposal techniques include collection in a
closed system followed by steam stripping to collect and recycle the EDC,
biotreatment, incineration, and deep well injection.  Of these, b*i otreatment
is responsible for most of the secondary EDC emissions to the atmosphere.
This is because EDC is not readily biodegradable.21  (Biotreatment is
used to remove other pollutants.)  Ethylene dichloride thus evaporates
from treatment ponds, especially during aeration.  Estimates provided by
industry of the amount of EDC that evaporates range from approximately 0
to 96 percent; 50 percent is the most common value reported.  The evaporation
rate depends on such parameters as pond surface area and depth, atmospheric
temperature, and aeration practices.
2.4.2  Current Controls and Emissions
     Currently, there are no add-on controls present on biotreatment
emission sources in the EDC production/use chemical industry.  Secondary
emissions of EDC total approximately 650 Mg/yr (720 tons/yr).
2.4.3  Additional Controls
     The feasibility of applying covers to biotreatment ponds was investi-
gated.   Under this concept, a rigid equipment cover fabricated from such
materials as aluminum or plastic would allow-evaporative emissions to be
collected and routed to a control device.22  This approach, however,
could hinder biodegradation by reducing the amount of oxygen entering the
waste stream by surface aerators.
     Secondary emissions from the treatment of liquid wastes can be
reduced by lowering the EDC content of the waste stream prior to bio-
treatment.  Process wastewater, contaminated floor drains, and flush
water can be collected and passed through a steam stripper to remove EDC.
Information received from the pla/its through the information requests was
insufficient to perform a detailed evaluation of the possible emission
reductions or the costs of pretreating individual secondary waste streams.
     Information was obtained from a vendor of steam strippers for a
0.5 mVmin (130 gal/min) waste stream saturated with EDC at 21°C (70°F).23
(Waste flows reported by the industry ranged from 0.06 to 5.8 mVmin [15
to 1,500 gal/min]).  This system would have a design emission rate of
                                  2-10

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100 ppm EDC in the waste stream (98.8 percent removal), would operate
continuously,  and would have a rectifying section for EDC recovery.   The
installed capital cost of the unit would be $400,000.  For a saturated
stream at these flow rates, EDC recovery would be favorable, resulting in
an annualized cost of approximately $235,000 and a cost effectiveness of
approximately $85/Mg ($75/ton).24  However, scaling this unit to the
flows reported and using the reported EDC emission levels (0 to 200 Mg/yr
[0 to 220 tons/yr]), cost-effectiveness values exceed $2,500/Mg ($2,260/ton).
(These high values result from the high flow rates and less-than-saturated
flow streams.)  Because of the lack of detail on current plant-specific
treatment systems, the emission reductions obtainable and associated
costs should be treated as general indications of the impacts of these
controls.  Actual impacts for both emission reductions and costs may be
higher or lower than the stated values.
2.5  STORAGE TANKS
2.5.1  Current EDC Storage Patterns
     Four types of storage vessels are currently used to store  EDC:
     1.   Fixed roof tanks;
     2.   Internal floating roof tanks;
     3.   Open top tanks; and
     4.   Pressure vessels.
     2.5.1.1  Fixed Roof Tanks.25  As  shown  in Table 2-11,  fixed roof
tanks account for about 73 percent of  all  vessels used to store EDC.   A
typical  fixed roof tank consists  of  a  cylindrical steel  shell with  a
cone- or dome-shaped  roof  that is permanently affixed  to the  tank  shell.
A  breather valve  (pressure-vacuum valve),  which  is commonly  installed  on
many fixed roof  tanks,  allows the tank to  operate at a  slight internal
pressure or vacuum.   Because  this valve  prevents the release  of vapors
only during very  small  changes in temperature,  barometric presssure,  or
liquid level, the emissions  from  a fixed roof tank can  be appreciable.
     The major types  of emissions from fixed-roof tanks  are breathing  and
working  losses.   Breathing loss  is the expulsion of  vapor from  a  tank
vapor space that has  expanded or  contracted because  of daily changes  in
                                   2-11

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ambient temperature and barometric pressure.  The emissions occur in the
absence of any liquid level change in the tank.
     Working losses are those that occur when the tank is filled or
emptied.  Filling losses are associated with an increase of the liquid
level in the tank.  The vapors are expelled from the tank when the
pressure inside the tank exceeds the relief pressure as a result of
filling.  Emptying losses occur when the air that is drawn into the tank
during liquid removal expands as a result of reaching temperature and
saturation equilibrium, thus exceeding the fixed capacity of the vapor
space and overflowing through the pressure vacuum valve.
     Fixed roof tanks account for about 95 percent of the 610 Mg/yr
(670 tons/yr) of EDC emissions from storage vessels.  Many storage vessels
contain mixtures of EDC and other organic liquids.   If emissions of VOC's
are considered, fixed roof tanks still account for about 804 Mg/yr
(886 tons/yr),  or 95 percent, of emissions from storage vessels.
     2.5.1.2  Internal Floating Roof Tanks.26  As shown in Figure 2-1, an
internal floating roof tank has both a permanently affixed roof and a
roof that floats inside the tank on the liquid surface (contact roof) or
is supported on pontoons several inches above the liquid surface (noncontact
roof).   The internal floating roof rises and falls with the liquid level.
     Contact-type roofs include (1) aluminum sandwich panel roofs with a
honeycombed aluminum core floating in contact with the liquid; (2) resin
coated, glass fiber reinforced polyester (RFP) buoyant panels, floating
in contact with the liquid; and (3) pan-type steel  roofs, floating in
contact with the liquid with or without the aid of pontoons.
     Several variations of the pan-type contact steel roof exist.   The
design may include bulkheads, or open compartments, around the perimeter
of the roof to minimize and/or localize the effects of liquid that may
leak or spill onto the deck.  Alternately, the bulkheads may be covered
to form sealed compartments (i.e., pontoons), or the entire pan may be
covered to form a sealed, double-deck, steel floating roof.  Construction
is generally welded steel.
     Noncontact roofs typically consist of an aluminum deck on an aluminum
grid framework supported above the liquid surface by tubular aluminum
pontoons.   The deck skin for the noncontact-type floating roofs typically
                                  2-12

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     PERIPHERAL
      ROOF VENT  '
                                         CENTER VENT
  PRIMARY SEAL
    MANHOLE
    PERIPHERAL
    ROOF VENT
PRIMARY SEAL
     MANHOLE
                                                  •TANK SUPPORT COLUMN WITH COLUMN WELL

                     A.  CONTACT  INTERNAL  FLOATING ROOF.

                                         CENTER VENT
        RIM PLATE
                RIM PONTOONS
             RIM PONTOONS
                                                              PONTOONS
TANK SUPPORT COLUMN WITH COLUMN WELL
                                                VAPOR  SPACE
                    B.  NONCONTACT INTERNAL FLOATING ROOF.
                  Figure 2-1.  Internal  floating roof tanks.26

                                         2-13

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is constructed of rolled aluminum sheets (about 1.5 m wide and 0.58 mm
thick).   The overlapping aluminum sheets are joined by bolted aluminum
clamping bars that run perpendicular to the pontoons to improve the
rigidity of the frame.  The deck skin seams can be metal on metal or
gasketed with a polymeric material.   The pontoons and clamping bars form
the structural frame of the floating roof.
     All types of internal floating roofs incorporate flexible perimeter
seals or wipers that slide against the tank wall as the roof moves up and
down.  Circulation vents and an open vent at the top of the fixed roof
are generally provided to minimize the possibility of vapors accumulating
between the roofs in concentrations approaching the flammable range.
     As ambient wind flows over the exterior of an internal floating roof
tank, air flows into the enclosed space between the fixed and floating
roofs through some of the shell vents and out of the enclosed space
through others.  Any VOC or EDC vapors that have evaporated from exposed
liquid surface and that have not been contained by the  floating roof will
be swept out of the enclosed space.
     Losses of VQC vapors from under the floating roof  occur in one of
four ways:
     1.  Through the annular rim space around the perimeter of the
floating roof (rim or seal losses);
     2.  Through the openings  in the deck required for  various types of
fittings (fitting losses);
     3.  Through the  nonwelded seams formed when joining  sections of the
deck material (deck seam  losses); and
     4.  Through evaporation of liquid left on  the tank wall following
withdrawal  of liquid  from the  tank  (withdrawal  loss).
Seal Idsses,  fitting  losses, and deck seam  losses occur not only during
the working operations  of the  tank  but also, during free standing periods.
The  mechanisms and  loss rates  of internal floating roof tanks were
studied  in  detail by  the  Chicago Bridge  and Iron Company  for the American
Petroleum  Institute.  The results of this work  form  the basis for  internal
floating roof emissions discussion.
     Several  potential  mechanisms  for vapor loss  from  the rim seal  area
of an  internal floating roof tank can be postulated:
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     1.   Circumferential  vapor movement underneath vapor-mounted rim
seals;
     2.   Vertical mixing, due to diffusion or air turbulence, of the
vapor in gaps that may exist between any type of rim seal and the tank
shell;
     3.   Expansion of vapor spaces in the rim area due to temperature or
pressure changes;
     4.   Varying solubility of gases, such as air, in the rim space
liquid due to temperature and pressure changes;
     5.   Wicking of the rim-space liquid up the tank shell; and
     6.   Vapor permeation through the sealing material.
     Vapor permeability is the only potential rim seal area loss mechanism
that is readily amenable to independent investigation.  Seal fabrics are
generally reporte'd to have very low permeability to typical hydrocarbon
vapors,  such that this source of loss is not considered to be significant.
However, if seal material is used that is highly permeable to the vapor
from the stored liquid, the rim seal loss could be significantly higher
than that estimated from the rim seal loss equation used to calculate EDC
emissions from internal floating roof tanks.  Particularly when dealing
with a chemical product, such as EDC, rather than petroleum liquids,
attention must be paid to the properties of the individual compound being
stored.   For instance, benzene is suspected of having permeability losses
that equal or exceed convective and diffusion losses from the seal.
Additional permeability data for liquid/seal material combinations must
be developed to characterize fully the significance of permeability
losses.   Such data do not exist.
     The extent to which any or all of these mechanisms  are responsible
for the total fitting loss is not known.  The relative importance of the
various mechanisms probably depends on the type of fitting, and the
design of the fitting seal.
     Internal floating roofs are typically made by joining  several
sections of deck material together, resulting in  seams in the deck.  To
the extent that these seams are not completely vapor tight,  they become  a
source of loss.  Generally the same loss mechanisms discussed for deck
fittings may apply to deck seams.
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     Withdrawal loss is another source of emissions from floating roof
tanks.   When liquid is withdrawn from a tank, the floating roof is
lowered, and a wet portion of the tank wall is exposed.  Withdrawal loss
is the evaporation of liquid from the wet tank wall.
     Currently, nine internal floating roof tanks are used to store EDC.
Total EDC emissions from these vessels are estimated to be about 9 Mg/yr
(10 tons/yr).
     2.5.1.3  Open Top Tanks.  EDC is also stored in three open top
tanks.   Open top tanks are cylindrical shells with no roof.  A lighter
liquid is floated on the surface of the primary liquid EDC, forming an
evaporative barrier.  Total EDC emissions were etimated to be less than
1 Mg from these three tanks.
     2.5.1.4  Pressure Vessels.  Pressure vessels are designed to withstand
relatively high internal pressures.  They are generally used for storing
highly volatile and/or toxic materials and are constructed in various
sizes and shapes, depending on the operating pressure range.  Noded
spheroid and hemispheroid shapes are generally used for low-pressure
vessels (117 to 207 kPa); horizontal cylinder and spheroid designs are
generally used for high-pressure tanks (up to 1,827 kPa).  Because high
pressure vessels are generally operated in a closed system at the presure
of the stored material, losses are not generally incurred.  However,  low
pressure vessels (2-15 psig) can emit EDC during filling operations.
     Emissions from the 11 pressure vessels used to store EDC totaled
about 16 Mg/yr (18 tons/yr).  Four low pressure vessels are responsible
for over 15 Mg/yr (17 tons/yr).
2.5.2  Current Controls and Emissions
     In general, because of the low emission rates of internal floating
roof tanks and pressure vessels, these tank types are not currently
equipped with additional controls.  Also, the three open top tanks are
not currently controlled.  Therefore, the focus of this discussion is on
fixed roof tanks.
     Emissions from 65 fixed roof tanks currently are ducted to an
emission control device (Table 2-12).  These devices include thermal
oxidation units (incinerators) and various types of refrigeration systems.
The efficiency of incinerators was reported to be between 98 and
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99.99 percent, while the efficiency reported for refrigeration systems
ranged from 37 to 99.5 percent.   The average efficiency of a refrigeration
system was estimated at about 90 percent.
     The remaining 39 fixed roof tanks are either uncontrolled, or have
low efficiency controls.  Low efficiency controls include devices such as
conservation vents.
2.5.3  Additional Emission Control Techniques
     2.5.3.1  Fixed Roof Tanks.   Emissions from uncontrolled fixed roof
tanks could be reduced through the use of add-on controls (such as vent
condensers) or by equipping the tank with an internal floating roof.
Condensers were evaluated, but were more costly than internal floating
roofs.  Ducting emissions to existing process incinerators was not
examined because there were no data on existing incinerator capacities or
the proximity of the tanks to the incinerator.  Therefore, only internal
floating roofs were considered.
     Depending on the type of roof and seal system selected and on tank
parameters, an internal floating roof will reduce the fixed roof tank
emissions by about 93 to 99 percent.  An internal floating roof, regardless
of design, reduces the area of exposed liquid surface in the tank.
Reducing the area of exposed liquid surface, in turn, decreases the
evaporative losses.   The relative effectiveness of one internal floating
roof design over another is a function of how well the floating roof can
be sealed.
     Two types of internal floating roofs were examined in this study.
     These were:
     1.  A welded steel, contact, internal floating  roof with a Teflon  ,
liquid-mounted, primary seal only; and
                                                                      io\
     2.  A welded steel, contact, internal floating  roof with a Teflon  ,•
liquid-mounted primary seal, and a Viton  secondary  seal.  These controls
were attributed emission reductions of 94 percent and 97 percent,
respectively.27,28
     These controls are s'ignificnatly more expensive than typical,
bolted, aluminum noncontact internal floating roofs.  However, compability
problems with EDC prevent the use of typical deck materials such as
aluminum, and typical seal fabrics, such as polyurethane-coated nylon.
                                  2-17

-------
Table 2-13 presents a summary of the costing methodology.  The details  of
the costing are presented in Appendix A.  it should be recognized that
the internal floating roof physically occupies a finite volume of space
that takes away from the maximum liquid storage capacity of the tank.
When completely full, the floating roof touches or nearly touches the
fixed roof.  Consequently, the effective height of the tank decreases,
thus limiting the storage capacity.  The reduction in the effective
height varies from about 0.5 to 2 feet depending on the type and design
of the floating roof employed.  This reduction in capacity was not
considered as a cost.
     The emission reduction and costs of retrofitting 40 fixed roof tanks
with internal floating roofs equipped with liquid-mounted primary seals
only was evaluated.  These tanks were selected because, with one exception,
they are not currently controlled with incinerators or refrigeration
systems.  The one exception was a tank controlled with a 37 percent
effective vent condenser.  The results of this analysis are presented in
Table 2-14.
     It should be noted that no plant-specific data were available for
the Borden Chemical or Diamond Shamrock plants.  The values for these
plants were generated by using industry averages for similar plants.
However, tanks that are highly controlled have virtually no emissions,
while larger uncontrolled fixed roof tanks may have very large emissions.
EDC storage tanks vary between-these two extremes.   In this type of
situation, averages are very misleading, and are presented here only for
completeness.  The following discussion and tables do not include these
plants.
     The results of the analyses are summarized in Tables 2-15 and 2-16.
As shown in the tables, a small number of fixed roof tanks account for
the majority of emissions."  About 89 percent of the available EDC emission
reduction can be obtained for less than $l,000/Mg ($910/ton), and 93 percent
of the available EDC emission reduction can be obtained for less than
$2,000/Mg ($l,820/ton).
     As shown in the Table 2-16, 70 tanks emit less than 1 Mg/yr (1.1 tons
year) per tank.   These low emissions result from existing high efficiency
controls (such as incinerators), small volumes, a low percentage of EDC
                                  2-18

-------
stored, or a combination of all  these factors.   Because of the low EDC
emissions, the cost effectiveness of additional controls (where applicable)
always exceeds $4,300/Mg ($3,900/ton).
     Forty-two fixed roof tanks  have EDC emissions between 1 and
10 Mg/yr (1.1 and 11 tons/yr).   These account for about 175 Mg/yr
(193 tons/yr) of EDC emissions.   Some of the tanks are already controlled.
The cost effectiveness of equipping these vessels with internal floating
roofs ranged from a credit to $10,000/Mg ($9,070/ton) of EDC controlled.
     The cost effectiveness of controls for vessels that emit more than
10 Mg/yr (11 tons/yr) is generally a credit, but does range up to $l,500/Mg
(1,350/ton) in one case.  These 12 tanks are responsible for about
73 percent of the fixed roof tank emissions and about 76 percent of all
EDC storage emissions.
     Because some EDC storage vessels also emit other VOC's, the VOC
emission reduction that would be obtained by controls was also examined.
The results of this analyses are presented in Table 2-17.  The only sub-
stantial changes in cost effectiveness occur in six tanks.  The cost
effectiveness of controls for four tanks decreases from values in excess
of $10,000/Mg (9,070/ton) to net credits.  This is because these vessels
store  liquids that have a low EDC content.  The cost effectiveness of
controlling the other two tanks drops from about $2,500/Mg to  about
$l,300/Mg  ($2,300/ton to $l,200/ton).  These six tanks have EDC emissions
that total about 9 Mg/yr (10 tons).  The major conclusion from the
analysis of VOC emissions is that if tanks were to be regulated based  on
cost effectiveness, the additional consideration of VOC emissions would
make little difference  in the overall end result; both in terms of the
total  EDC  emission reduction that would be obtained and the number of
sources that would be controlled.
     The  impacts of adding secondary seals to  the internal floating roof
were calculated and the results of this analysis are presented in Tables  2-18
and 2-19 for EDC and VOC, respectively.  The calculated  incremental cost
effectiveness of a secondary seal over a liquid-mounted primary seal
always exceeds $28,000/Mg ($25,400/ton).
                                   2-19

-------
     2.5.3.2  Pressure Vessels.  As shown in Table 2-20, four pressure
vessels account for the majority of emissions from this tank type.  The
noncylindrical shape of this tank precludes the installation of internal
floating roofs as a control system.  Therefore, a refrigerated vent
condenser was evaluated.
     The results of the analysis are contained within Tables 2-14- and
2-17, but is also presented in Table 2-21.  Of particular note is the
radical drop in cost effectiveness of controlling the largest single tank
if VOC is considered.   This tank with EDC emissions of 5.7 Mg/yr (6.3 tons),
is responsible for about 35 percent of EDC emission from all pressure
vessels.
     2.5.3.3  Internal Floating Roof and Open Top Tanks.  Additional
controls were not extensively considered for existing internal floating
roof tanks.   It would be possible to degass the tank and gasket existing
fittings.  This would provide an emission reduction of about 0.1 Mg/yr
per tank, or about 0.9 Mg (1 ton) nationwide.  Previous studies have
shown that gasketing fittings is not cost effective if the cost of
degassing is included.  These controls may be cost effective (=$300/Mg)
if the gaskets are installed when the tank has been cleaned and degassed
for other reasons.29
     €missions from open top tanks could be reduced by doming the tank
and adding an internal floating roof.   The cost effectiveness of adding
only the internal floating roof would be in excess of 59,500/Mg ($8,600/ton)
in all cases.
2.5  TANK TRUCK/RAIL CAR/BARGE LOADING
2.6.1  Emission Sources
     Ethylene dichloride is transported from producer to user by either
tank truck,  railroad tank car, or barge.  One manufacturer reports
shipping EDC in portable container drums.   Emissions of EDC to the  •
atmosphere primarily occur during loading of the vehicle as a result of
vapors residing in empty cargo spaces being displaced by the liquid being
loaded.  These vapors result from evaporation of residual product from a
previous load and those generated in the space as new EDC is being
loaded.  The total evaporative loss from loading operations is a function
                                  2-20

-------
•of  the  physical  and  chemical properties  of  the  previous  and  new  cargos,
 the method  used  for  loading  or  unloading the  cargos,  and the service
 history of  the cargo carrier.30   Because other  VOC  components are  typically
 present only  in  minute  quantities as  impurities in  EDC,  non-EDC  VOC
 emissions would  be negligible and are consequently  not addressed in this
 report.
 2.6.2   Current Controls and  Emissions
     Table  2-22  presents  current  shipping mode, control  systems  employed,
 and emission  data on a  plant-specific basis.  Current EDC emissions
 reported by the  industry  are approximately  225  Mg/yr  (250 tons/yr).
      Loading  emissions  can be reduced by submerged  loading,  vapor  recovery
 systems, incineration,  and vapor  balance systems.   These control options
 are described below.
      2.6.2.1  Submerged Loading.   Submerged loading is the introduction
 of  liquid  EDC into the  tank  being filled with the transfer line  outlet
 being  below the  liquid  surface.   Submerged  loading  minimizes droplet
 entrainment,  evaporation, and turbulence.   (This is compared to  splash
 loading where the transfer line outlet is at the top  of  the  tank and
 liquid free-falls into  the tank.)  Emission reductions can range from 0
 to  65  percent.31 Six companies report utilizing, or  have the facilities
 to  utilize, submerged loading.
      2.6.2.2  Vapor  Recovery Systems.  Vapor recovery equipment  recovers
 the EDC and VOC  vapors  displaced  during loading operations by use  of
 refrigeration (e.g., vent condensers).   Control efficiencies range from
 90  to  98 percent, depending  on  the nature of the emissions and the type
 of  recovery equipment used.32   In the case  of barges, the vapor  recovery
 system may  be located on  the barge, rather  than on  shore.  Three companies
 currently  use vapor  recovery systems.
      2.6.2.3  Incineration.  Venting  emissions  to an  incinerator can  give
 97  to  99 percent emissions control.  Three  companies  utilize incineration.
      2.6.2.4  Vapor  Balance  System.  The vapor  balance  system consists of
 a pipeline  between the  vapor spaces of the  receiving  vehicle and the
 unloading  storage tanks,  which  essentially  creates  a  closed system
 allowing the  vapor spaces of the  storage tank and the vehicle to balance
 with each  other.  The net effect  of the system  is to  transfer vapor
                                   2-21

-------
^displaced  by  liquid  entering  the  vehicle  to  the  storage  tank  during
 loading  operations.   If  a  system  is  leak  tight,  very  little or  no  air is
 drawn  into the  system, and venting,  due to compression,  is also substan-
 tially reduced.   However,  vapor balance systems  cannot be utilized with
 floating roof storage tanks.  Three  companies  have  the ability  to  utilize
 a vapor  balance  system with fixed roof tanks.
 2.6.3  Additional Controls
     Each  of  the above control options are in  use by  the EDC  industry
 although some shippers do  not control their  loading emissions.   Many  of
 the plants report no  shipping of  EDC; they use it all captively.   Only
 one plant,  responsible for approximately  84  percent of reported EDC
 emissions  from  tank  trucks, rail  cars, and barges,  provided enough
 information to  calculate emission reduction  and  cost  values for a  barge
 loading  operation.   For  this  system, a refrigerated vent condenser system
 would  reduce  EDC barge loading emissions  by  184  Mg/yr (203 tons/yr) at a
 net annualized  cost  of $24,900 and a cost effectiveness  of $135/Mg
 ($123/ton)  of EDC reduction.  These  costs are  also  presented  in Table 2-22,
 and sample calculations  are provided in Appendix A.   The system that  was
 evaluated  employs two-stage cooling  for water  vapor removal.  This design
 cools  the  stream down to -70°C (-95°F) and has a removal efficiency of
 98 percent.   The system  includes  a skid mounted  refrigerated  vent  condenser,
 concrete pad, electric feeder, and vapor  piping.
     The emission reductions  achievable by controlling barge  loading
 operations  depend on  the volume shipped per  year, information not  provided
 by most  of the  companies.  The cost  of control for  tank  truck and  rail
 car loading is  highly dependent on the type  of vehicle being  used  and its
 compatibility with the various control systems.  Many of the  companies
 reported being  able  to use control systems on  appropriately equipped  tank
 trucks,  rail  cars, and barges.  Because of the relationship between
 control  system  and vehicle adaptability,  no  costs for tank truck or rail
 car loading operations are presented.
                                  2-22

-------
        TABLE 2-1.  PHYSICAL PROPERTIES OF ETHYLENE DICHLORIDE*
                           C°F)
Molecular weight
Density, g/ml at 20°C
Melting point, °C (°F)
Boiling point °C (°F)
Index of refraction, 20°C

Vapor pressure, torr, at °C
  -44.5 (-48.1)
  -13.6 (7.5)
  10.0 (50.0
  29.4 (84.9)
  64.0 (147.2)
  982.4 (180.3)
Solubility in water, ppm w/w/ at °C (°F)
  20 (68)
  30 (86)
Biochemical oxygen demand (5 days, %
Theoretical oxygen demand, mg/mg
Measured chemical oxygen demand, mg/mg

Vapor density (air = 1)
Flash point, open cup, °C (°F)
Ignition temperature, °C (°F)
Explosive limit, % volume in air
  Lower
  Upper
Specific resistivity
Viscosity, cP, at 20°C
Dielectric constant
Surface tension, dyne/cm
Coefficient of cubical expansion,
  10° to 30°C
Latent heat of fusion, cal/g
Latent heat of vaporization, cal/g,
  at boiling point
Specific heat, cal/g °C
  Liquid at 20°C
  Vapor, 1 atm at 97.1°C
Critical temperature, °C (°F)
Critical pressure, atm
Critical density, g/cm3
Thermal conductivity, Btu/h-ft2 at 20°C
Heat of combustion, cP, kcal/g-mole
Dipole moment, ESU
Conversion factors, 25°C 760 torr
98.96
1.2351
-35.36 (-31.65)
83.47 (182.25)
1.4448


1
10
40
100
400
760


8,690
9,200
0
0.97
1.025

3.35
13.0 (55.4)
413.0 (775.4)

6.2
15.9
9.0 xlO6

0.840
10.45
33.23
0.0016

21.12

77.3
                                            0.308
                                            0.255
                                            288 (550)
                                            53
                                            0.44

                                            0.825
                                            296.36
                                            1.57 x 10-18   *
                                            1 mg/L = 1 g/m3 = 247 ppm
                                            1 ppm = 4.05 gm/m3 = 4.05 g/L
Reference 33.
                                  2-23

-------
            TABLE 2-2.  CHEMICAL PLANTS PRODUCING AND/OR USING
                            ETHYLENE DICHLORIDE3
Product
Producer
Location
Ethylene dichloride
Vinyl chloride monomer
Ethyl Chloride
Methyl chloroform
Ethyleneamines
Perch!oroethylene
Arco Chemicals
B. F. Goodrich
                              Diamond Shamrock
                              Dow Chemical
E. I. duPont
Ethyl Corporation
Formosa Plastics

Georgia Pacific
01 in Corporation
PPG Industries
Shell Chemical Co.
Vulcan Chemicals

B. F. Goodrich

Borden Chemical0
Dow Chemical

E. I. duPont
Formosa Plastics

Georgia Pacific
PPG Industries
Shell Chemical Co.

B. F. Goodrich
Dow Chemical
            f
Dow Chemical
PPG Industries

Dow Chemical^
Union Carbide

Diamond Shamrock
Dow Chemical
PPG Industries
Vulcan Chemical
Port Arthur, Tex.
Calvert City, Ky.
Convent, La.
LaPorte, Tex.
Deer Park, Tex.
Freeport, Tex.
Oyster Creek, Tex.
Plaquemine, La.
Westlake, La.
Baton Rouge, La.
Baton Rouge, La.
Point Comfort, Tex.
Plaquemine, La.  *
Lake Charles, La.
Lake Charles, La.
Deer Park, Tex.
Geismar, La.

LaPorte, Tex.
Calvert City, Ky.
Geismar, La.
Plaquemine, La.
Oyster Creek, Tex.
Westlake, La.
Baton Rouge, La.
Point Comfort, Tex.
Plaquemine, La.
Lake Charles, La.
Deer Park, Tex.

Convent, La.
Freeport, Tex.

Freeport, Tex.
Lake Charles, La.

Freeport, Tex.
Taft, La.

Deer Park, Tex.
Freeport, Tex.
Lake Charles, La.
Geismar, La.
Wichita, Kans.
                                                             (continued)
                                    2-24

-------
                          TABLE 2-2.  (continued)
Product                       Producer                  Location

Trichloroethy1ene             Dow Chemical1             Freeport,  Tex.
                              PPG Industries            Lake  Charles,  La.


^Data from information requests unless otherwise  noted.
 Reference 34.
^Reference 35.
 Reference 36.
^Reference 37.
 Reference 38.
^Reference 11.
.Reference 17.
 References 17 and 39.
                                     2-25

-------
TABLE 2-3.  SOURCES OF ETHYLENE DICHLORIDE CONSUMPTION IN 1983'
Use
Vinyl chloride monomer
Ethyl chloride
Methyl chloroform
Ethyl eneamines
Perchloroethylene
Trichloroethylene
Lead scavenger
Pharmaceuticals
Miscellaneous
TOTAL

(gigagrams)
5,270
405
250
150
140
115
20
]_
5
-7,400
EDC consumotion
(106 pounds)
13,825
895
550
325
315
250
45
2
15
-16,300

Percent
of total
84.7
6.1
3.4
2.0
1.9
1.5
0.3
--
0.1
100.0
 Reference 40.
                                2-26

-------
TABLE 2-4.   COSTS FOR RETROFITTING AN INCINERATION SYSTEM FOR THE REDUCTION OF
                         EDC AND VOC PROCESS EMISSIONS
                                1984 Dollars3
Plant/location.
Process source
Arco Chemicals, Por\ Arthur. Tex.
EOC Manufacture
(a) Incinerator slack EDC-9g
B. F. Goodrich. Calvert City. Ky.
(b) Primary incinerator
U. F. Goodrich. Convent, la.
r\j
i
ro
^ B. F. Goodrich. laPorle. Tex.
EOC/VCH manufacture
(a) Incinerators A & B
Borden Chemicals^
VCH Manufacture
Geiswar, la.
Diamond Shamrock-*
EOC/PCE Manufacture
Deer Park. lex.
Dow Chenical
EDC plant
freeport, Tex.
DC -EDC
(a) Process vent
Dow Chemical
1,1,2 Trichloroetbane plant
Freeport, Tex.
(a) 1,1,2 Trichloroethane
Current Applic- f
EDC/VOC Current able EOC/VOC _Cost effectiveness 	
Current conlrol EDC/VOC addi- eMlsslon Cap'^Jj e Net agnyaj EOC VOL
control, effi- . emissions, tional reduction. cost. • • cost. • • emissions. ««'"«°''s.
technology" ciency. %b Mg/yr" controls Hg/yr£ $ » »/»9 »/Mg
Incinerator/ 9B/98h 30/30 N/A1 N/A M/A N/A N/A N/A
scrubber
4 0/1.314 Incln- 3.9/1.288 4.540.000 1.500.000 3.800.000 1.170
240/287 M/A N/A N/A M/A N/A M/A
0/0 N/A M/A M/A M/A M/A N/A
1.3/8 5 N/A N/A M/A N/A N/A N/A
Incinerator/ 98/98 41/230 N/A N/A N/A M/A N/A N/A
scrubber
Incinerator/ 98/98 1.3/3.0 N/A N/A N/A N/A N/A N/A
scrubber
Flare -k/98h 0/1.3 M/A M/A N/A N/A N/A .N/A
0/0 M/A H/A N/A N/A N/A N/A
— 	 	 	 	 	 	 	 ~~ (continued)

-------
TABLE 2-4.   (continued)













INJ
i
ro
00

















Plaiit/locatlon.
Process source
Dow Chemical"
Irlchlor plant
Ereeporl. lex.
(a) ICE
Oow Chemical, Oyster Creek, lex.
EOC/VCM Manufacture
(a) Unit A

(b) Unit U
(c) Unit C
Oow Chemical (Vinyl 1)
Plaquemlne. La.
IOC Manufacture
(a) Gaseous vent (EDC finishing)

(b) Gaseous vent (EOC reaction)


Oow Chemical (Vinyl 11)
EDC Manufacture
(a) Gasous vent (Oxy vent)

(b) Gaseous vent (EOC finishing)

Oow Chemical"
E thy leneaml nes plant
lexas Division
E. 1. duPont (Conoco)
Westlafce. La.
EOC manufacture
(a) Direct chlorlnation reactor
accumulator (f-101)
(b) EOC acid wash tank (I-103A)
(c) EDC caustic wash tank (1-102)
(d) Steam stripper aqueous
holding tank (1-110)
Current
EOC/VOC
Current control
control effi- ^
technology clency, X
--

Material, 99.99/99 99
recovery
Scrubber 99.99/99 99
Scrubber 99 99/99 99



Combustion 99.9/99.9
device •
Combustion 99.9/99.9
device



Material, 99.9/99.9
recovery
Material, 99.9/99.9
recovery
..











Current
EOC/VOC
emissions,
Mg/yr"
--

(l.OOb/0 025

0.04/0. 54
0.06/0.49



0 09/0. 59

1.67/2.04




1.1/31.1

l.O/l./

--





0 01/0.03

0 01/0.06
0/0 002
0.001/0.001

Applic-
able
addi-
tional
controls
--

H/A

H/A
H/A



H/A

H/A




H/A

H/A

--





N/A

N/A
N/A
H/A

1 UC/VOC
emission
reduct Ion,
Mg/yr
--

N/A

H/A
N/A
•


H/A

H/A




H/A

H/A

--





H/A

H/A
H/A
N/A

Cost effectiveness
cos ,
--

H/A

N/A
N/A



H/A

H/A




H/A

H/A

--





N/A

N/A
H/A
H/A

Het annual
cost. ' '
--

II/A
*
N/A
N/A



H/A

N/A




N/A

N/A

--





N/A

N/A
N/A
N/A

EDC VOC
emissions, emissions,
$/Mg t/Hg
--

H/A

H/A
N/A



N/A

N/A




N/A

N/A

--





N/A

N/A
N/A
N/A
— 	 ' 	 ' 	 ' — 1 	
--

H/A

N/A
H/A



H/A

H/A




H/A

H/A

--





H/A

H/A
H/A
H/A
— n 	 fr

-------
                                                TABLE 2-4.   (continued)
r\>
i
ro
10
Current
Maul/location, control.
Process source technology
(e) Light ends column overhead
accumulator (S-102)
(f) Heavy ends column overhead
accumulator (S-103)
(g) EOC tar still column (C-104)
VCH manufacture
(a) VCM tar stills column (C-204)
Ethyl Corporation, Baton Rouge, La.
EOC manufacture
(a) Incinerator vent Incinerator/
scrubber
Formosa, Baton Houge, la.
IOC/VCM Manufacture
(a) Incinerator Incinerator
Formosa, Point Comfort, Tex."
(a) Incinerator A Incinerator
(b) Incinerator B Incinerator
Georgia Pacific, Plaquemine, La.
Vinyl chloride manufacLure
(a) IN- 662 liquid incineration
and IN-661 gas incineration
(burning vents)
(b) IN-662 liquid Incinerator
01 in Corporation"
Lake Charles, La.
Fire retardent
PPG Industries, Lake Charles, La.
(a) No. 1 and No. 2 incinerator Incinerator
secondary scrubber stack
(b) No. 3 incinerator secondary Incinerator
scrubber
(c) No. 4 incinerator secondary Incinerator
scrubber stack
Current
EOC/VOC Current
control EOC/VOC
effi- . emissions,
ciency, % Hg/yr
0.002/0.222

0.003/0.003

0/0

0/0

t
98/98" 2.2/10.2



98/98" 38/204

99.99/99.99 5.2/12.82
99.99/99.99 5.2/12.82


0.08/1.58

0.03/0.17
-.



99.99/99.99 0.06/0.06

99.99/99.99 0.06/0.06

99.99/99.99 0.01/0.01

Applic-
able
addi-
tional
controls
N/A

N/A

N/A

N/A


N/A



N/A

N/A
N/A


N/A

N/A
--



N/A

N/A

N/A

EOC/VOC
emission
reduction, i
Mg/yr
N/A

N/A

N/A

N/A


N/A



N/A

N/A
N/A


N/A

N/A
--



N/A

N/A

N/A

Cost effectiveness
;osl, ' >e
t
N/A

N/A

N/A

N/A


N/A



N/A

N/A
N/A


N/A

N/A
--



N/A

N/A

N/A

Net annual
co.1."'"'1
t
N/A

N/A

H/A

N/A


N/A



N/A

N/A
N/A


N/A

N/A
--



N/A

N/A

N/A

EOC
emissions,
$/Hg
N/A

N/A

N/A

N/A


N/A



N/A

N/A
N/A


N/A

N/A
--



N/A

N/A

N/A

VOC
emissions,
t/Mu
N/A

N/A

N/A

N/A


N/A



N/A

N/A
N/A


N/A

N/A
--



N/A

N/A

N/A


-------
                                                                       TABLE  2-4.    (continued)
ro
I
CJ
o



Plant/location
Process source
Shell Chemical Co. ,
Deer Park, lex.
VCH manufacture
(a) A- 1750 IICIN-2 Incinerator
(b) A-1770 IICIN-3 Incinerator


Current
. control.
technology



Incinerator
Incinerator
Current
EOC/VOC
control
effi-
cieiuy, X


i,
90/90
98/90"

Current
EOC/VOC
emissions,
Hg/yr"



22/55
22/55
Applic-
able
addi-
tional
controls



N/A
N/A

EOC/VOC
emission
reduction, <
Mg/yr



N/A
H/A


r
Cost effectiveness'
Capital Net aynlial
cost • >e cost, ' '



H/A N/A
H/A H/A
— foe 	
emissions,
t/Hg



N/A
N/A
vOE
emissions,
»/Mg



N/A
N/A
          Union Carbide, llahnville. ta.
          Elhyleneamines 1
          (a) Chlorides Incinerator

          Vulcan Chemicals. Gelsmar, ta.
          PCE manufacture
          (a) fOC oxyclilorinatlon vent

          Vulcan Chemicals. Wichita, Kans.
          Grain fiwigant blending
          (a) 111 cod tank vent
                                      Incinerator     99.9/99.9
                                      Incinerator
                                                         9U/9U
                                                              h
 0/0.02        N/A
1.2/2.7        H/A
                                                                  0 004/0.10       N/A
H/A
N/A
                             N/A
N/A
N/A
             H/A
N/A
N/A
              N/A
N/A
N/A
                 N/A
H/A
N/A
             N/A
.Calculated using CE Plant Cost Index (Chemical Enyineerimj. June 11. 1984).
 Cited from information request.
 Deference No.  41 (96 percent efficiency)
"Heference No.  42.
Reference No.  43.
 Annual iied cost  per unit of emission reduced
^Incinerator stack EUC-9 (all process vent emissions are  conveyed to the Incinerator emission control system via closed system).
.Actual efficiency rale reported as >98 percent; however,  insufficient data were available to verify the higher rale.
jM/A = Hot applicable.  Ho additional controls coiled If  existing removal efficiency 298 percent.
[•Emissions estimated as average of similar plants
      vent contains no EOC.
           No  further details provided.
          "MO  process emissions.
          "itala from Reference 44.

-------
      TABLE 2-5.   VOC EMISSION FACTORS FROM EQUIPMENT LEAKS3
                                           VOC emission factor
Equipment type                           kg/d              Mg/yr


1.   Pump seals
    •  Packed                            1.19              0.43
    •  Mechanical                        1.19              0.43
    •  Double mechanical                 0.0               0.0

2.   Compressors                          5.47              2.0

3.   Flanges                              0.02              0.01

4.   Valves
    •  Gas                               0.13              0.05
    •  Liquid                            0.17              0.06

5.   Pressure relief devices
    •  Gas                               2.50              0.91
    •  Liquid                            0.0               0.0

6.   Sample connections
    •  Gas            '                  0.36              0.13
    •  Liquid                            0.36              0.13

7.   Open ended lines
    •  Gas                               0.04              0.15
    •  Liquid                            0.04              0.15

Reference 45.
                               2-31

-------
TABLE 2-6.  COSTS FOR IMPLEMENTAI10N OF CONTROLS FOR FOC FUGITIVE EMISSION SOURCES
                           First Quarter  1904  Dollars
Plant/Location
Arco Chemical, Port Arthur, Tex.
U. F. Goodrich, LaPorte. Tex.
0. F. Goodrich. Calvert City, Ky.
D. F. Goodrich, Convent, La.
Borden, Geismer, La.
Diamond Shamrock, Deer Park. Tex.
Dow Chemical (Vinyl I Plant),
Plaquemine, La.
Dow Chemical (Vinyl II Plant)
Plaqueutine, La.
ro Dow Chemical, Oyster Creek, Tex.
• Dow Chemical. Texas Division
CO
ro
Dow Chemical. EOC Plant,
Freeuort, Tex.
Oow Chemical, 1-1,2, Trlchloroethane
Plant, Freeport, lex.
Dow Chemical, Trichloro Plant
Freeport, Tex.
E. 1. duPont (Conoco). West lake. La.
Ethyl Corporation, flat on Rouge. La.
Formosa, Point Comfort, Tex.
Formosa. Baton Rouge, La.
Georgia Pacific, Plaquemine La.
01 in Corporation, Lake Charles, La.
PPG Industries, lake Charles. La.
Shell Chemical Co.. Deer Park. Tex.
Union Cat hide, llahnville, La.
Vulcan Chemicals, Geismar, La.
Vulcan Chemicals, Wichita. Kans.
Current
control
niques '
N/A
M/A

N/A
N/A
N/A
1

N/A

m
N/A
N/A

N/A

N/A


P
q
H/A
N/A
N/A
N/A
M/A
M/A
N/A
N/A
Current
control
cffl-
cie«By
N/A
H/A

N/A
H/A
N/A
0.00

M/A

5.2
H/A
N/A

N/A

H/A

3.0
7.5
20
H/A
H/A
N/A
N/A
H/A
M/A
N/A
H/A
Current
EOC
emis-
sions.
Mg/yr
20h
200
144h
2,
601'
50h
360

100

110
5
21

a

9

100
46
67
100
200
41
64
140
3
44
3
Addi-
tional
EDC
emission
reduc-
tion. .
Mg/yr
14
142
102
1.3
43
36
260

75

66
4
16

6

0

70
27
40
70
130
30
46
100
2
29
2
Total
capital .
cost, $U
29.500
217,900
217.900
3.000
65.400
04,500
064.700

141.000

80.300
4,000
13,000

6.300

3.800

136.900
10.700
60,700
133.200
61.600
33.200
102.500
95.500
3.100
50.000
2,600
Annual! zed
cost, $°
12,400
130,500
130,500
420
39,200
50.700
340,000

97,300

60.700
1,900
14,000

4,900

5.700

97,300
14,900
44.100
71.400
90,000
24.000
71.200
76.000
2.600
35.100
2.200
EOC
recovery
credit.
$a,e
4,600
46,300
33.250
2.000
14 .000
11.700
64.800

24,500

21,500
1,300
5,200

2.000

2.600

22.800
6.800
13.000
25,400
42.400
9.000
15,000
32.600
650
9,400
650
Net
annua 1 -
liedf
cost1
7.000
84,200
97,250
1,540
25.200
47.000
255.200

72,800

39.200
600
0.800

2.900

3,100

74.500
6,100
31.100
46.000
40.400
14.200
56.200
43.400
1,950
25,700
1.550
Cost
effective-
ness,
$/Mg EOC"
560
590
950
1,100
590
1.300
900

970

590
150
550

400 '

390

1.100
230
700
590
370
470
1,200
430
900
690
700
                                                                                         (continued)

-------
ro
i
co
CO
                                                              TABLE 2-6.    (continued)
         Calculated using CE Plant Cost Index  and MiS Equipnent Cost Index (Chen leal Engineering June 11.  1981).
         Information sited from Section 114  information request responses.
         Current control techniques were not  listed if the technique or technology was judged to have 0 percent control  efficiency.
         Based upon proposed emission control  techniques and control efficiencies listed in Table 2-8.
             valve ~$326/Mg First Quarter 1984 dollars, Reference No. 46.
        'Annualized cost minus recovery credit.
        :JNet annual ized cost per unit of emissions reduced.
        .Emissions and costs estimated as average of similar plants.

        j
        k

         Pressure relief devices protected by rupture disc (100 percent efficiency).
        "Rupture discs installed under 21 percent of relief devices  in VOC or EOC liquid or vapor service (100 percent efficiency).

        o'

        ^Sample connections equipped with flow back loops (100 percent efficiency).
        ^Relief valves protected by rupture discs (100 percent efficiency).

-------
                 TABLE  2-7.   COSTS FOR
r\>
i
IMPLEMENTATION Of CONTROLS FOR VOC

     First Quarter 1984 Dollars
FUGITIVE EMISSION  SOURCES


Plant/location
Arco Chemical. Port Arthur, lex.
0. F. Goodrich, LaPorte. lex.
0 F. Goodrich. Calvert City. Ky.
I). F. Goodrich. Convent, La.
Hoi ilen. Gelsmer. La.
Diamond Shamrock. Deer Park, lex.
Dow Chemical (Vinyl I Plant)
P 1 a(|uew I ne . La.
Dow Chemical (Vinyl II Plant)
Plai)uemine, La.
Dow Chemical. Oyster Creek, Tex.
Dow Chemical, lexas Division
Dow Chemical, EUC Plant.
Frecport, lex.
Dow Chemical, 1-1,2, IricMoroelhane
Plant. Freeporl. lex.
Dow Chemical. Irichloro Plant,
Freeport, lex.
E. 1. duPonl (Conoco), Uesllake, La.
Ethyl Corporation, Baton Rouge, la.
Formosa, Point Comfort, lex.
Formosa, ttaton Kouge, la.
Georgia Pacific. Plaqtiemlne, La.
01 In Corporation, lake Charles, La.
PPG Industries, lake Charles, la.
Shell Chemical Co., Deer Park, lex.
Union Carbide, llanville. La.
Vulcan Chemicals. Geismar. La.
Vulcan Chemicals. Wichita. Kans.
Current
control

N/A
N/A
N/A
N/A
N/A
m
N/A
n
N/A
N/A
N/A
N/A
M
m
N/A
N/A
H/A
N/A
N/A
N/A
N/A
N/A
Current
control
effi
: clc^6y
N/A
N/A
N/A
N/A
N/A
O.UO
N/A
52
N/A
N/A
H/A
H/A
30
75
20
N/A
H/A
N/A
N/A
N/A
N/A
N/A
N/A
Current
VOC
emis-
sions.
Hg/yr
29.
345
2491
104 '
126*
500
210
100
5
38
14
20
170
50
120
160
320
61
150
270
3
75
5
A.I.I 1
I tonal
VOC
emission
redtic-
Ml/"rd
21
245
100
3
75
90
420
150
no
4
30
11
17
110
30
70
120
230
43
no
200
2
52
4

lotal
capital,
cost. }
29.500
217.900
217.900
3.000
65.400
84.500
064 . 700
141.000
00.300
4.000
13.000
6.300
3.000
136.900
10.700
60.700
133.200
61.600
33.200
102.500
95.500
3.100
50.000
2.600


Annual lied
cost. t8
12.400
130.500
130.500
2.400
39.200
50.700
340,000
9' . 300
60,700
1,900
14,000
4.900
5.700
97.300
14.900
44.100
71.400
90,000
24,000
71.200
76.000
2.600
35.100
2,200
tot
recovery
;s?U!i'
6,000
79.900
58.700
900
24.450
29.300
136.900
40.900
35,900
1.300
9.800.
3.600
5.500
35.900
9.000
22.000
39.100
75.000
14.000
35.900
65.200
650
16.800
1.300
Net
annua 1 -
lied,.
cost9
5.600
50,600
71.800
1.400
14.750
29.400
203.100
40.400
24.000
600
4.200
1.300
200
61.400
5,100
21.300
32.300
15.000
10.000
35.300
10.000
1.950
18.300
900
Cost
effective-
ness,
$/Hg VOC1
270
210
400
470
200
330
400
320
230
150
140
120
10
560
170
300
270
70
230
320
55
900
350
230
                                                                                                           (continued)

-------
                                                              TABLE  2-7.    (continued)
        ^Calculated using CE Plant Cost Index  and M&S Equipment Cost Index (Chemical Engineering June 11, 1984).
         Information sited from Section 111  information request responses.
        c.Current control teclmlqiies were not  listed  If the technique or technology was Judged to have 0 percent control  efficiency.
         Based upon proposed emission control  techniques and control efficiencies listed in Table 2-fl.
        *EOC valve ~$326/Mg First Quarter 1984 dollars, Reference Ho. 46.
         Assumed VOC value = EOC value.
        pAnnuatiied cost minus recovery credit.
         Net annual I zed cost per unit of emissions reduced.
        '.Emissions and costs estimated as average of similar plants.

        k
        I
        ""Pressure relief devices protected by rupture disc (100 percent efficiency).
        "Rupture discs  installed under 27 percent of relief devices  In VOC or EOC liquid or vapor service (100 percent efficiency).

        P
        ^Sample connections equipped with flow back  loops  (100 percent efficiency).
to
in

-------
       TABLE 2-8.   CONTROL TECHNIQUES AND COST FOR VOC/EDC FUGITIVE
                            EMISSION SOURCES3
                               1984 Dollars
Equipment type
1.



2.

3.

4.


Pump seals
• Packed
• Mechanical
• Double
mechanical
Compressors

Flanges

Valves
• Gas
Liquid
Control techniques

Monthly inspection
Monthly inspection
N/Aa

Degassing
Reservoir vents
None
Available

Monthly inspection
Monthly inspection
Capital
cost,
Percent $/comr
reduction ponent

83.3
83.3
N/A

100

N/A


70.3
72.5

0
0
N/A

10,200

N/A


0
0
Annual-
ized
cost,
$/com£
ponent

370
370
N/A

2,580

N/A


20
20
5.   Pressure relief
      devices
    •   Gas
       Liquid

6.   Sample connections
    •   Gas

       Liquid
7.   Open ended lines
    •  Gas
    •  Liquid
0-Ring                  -100
N/A                      N/A
Closed-purge sampling    100
  systems
Closed-purge sampling    100
  systems
Caps on open ends        100
Caps on open ends        100
310
N/A
670

670
 70
 70
 80
N/A
170

170
 20
 20
^Reference No. 47.
 Dollars updated using CE Plant Cost Index and M&S Equipment Cost  Index
 (Chemical Engineering, June 11, 1984).
 .Assume 0 emissions per year.
 Not applicable.
                                     2-36

-------
TABLE 2-9.  EDC AND VOC EMISSION REDUCTION FROM FUGITIVE EMISSION
           SOURCES AS A FUNCTION OF COST EFFECTIVENESS
Cost-
effectiveness
range, $/Mg
0-500
500-1,000
1,000-2,000
TOTAL
Nationwide emission
No.
EDC
7
14
_3
24
of plants
VOC
22
2
_0
24
reduction,
EDC
300
930
120
1,350
Mq/yr
VOC
2,280
110
	 g
2,390
                                2-37

-------
                                    TABLE 2-10.  SECONDARY EDC EMISSION SOURCES
     Plant/
     Plant location/
     Emission source
                              Current     Existing
                             emissions,    control
                               Mg/yr     technology
     Applicable
     additional
       control
     technology
 Capital
and annual
 cost for
additional
control, $
    Cost
effectiveness
 additional
   control
     Arco Chemicals
     Port Arthur, Tex.
     • Wastewater from  steam
       stripper
     • Disposal of spent
       drying media
                                  0£

                                  0
       None

       None
00
B.  F.  Goodrich
Calvert City. Ky.
• Wastewater from steam
  stripper

B.  F.  Goodrich
Convent, La.
• Wastewater from steam
  stripper

B.  F.  Goodrich
LaPorte, Tex.
• Wastewater from steam
  stripper

Borden
Geismar, La.

Diamond Shamrock
Deer Park, Tex.
                                       0
                                     121'
                                    0.40'
                                                                     None
                                                                     None
       None
-NO  ADDITIONAL  DATA AVAILABLE-
-NO  ADDITIONAL  DATA AVAILABLE-
                                                                                                 (continued)

-------
                                             TABLE  2-10.   (continued)
     Plant/
     Plant location/
     Emission source
     Current
    emissions,
      Mg/yr
 Existing
 control
technology
Applicable
additional
  control
technology
 Capital
and annual
 cost for
additional
control, $
    Cost
effectiveness
 additional
   control
INJ

CO
     Dow Chemical
     Freeport, Tex.
     • Wastewater discharge

     Oow Chemical
     Oyster Creek, Tex.
     • Treatment and
       disposal of waste-
       water, liquid wastes,
       or solid wastes
         g
Negligible
     Dow Chemical
     Plaquemine, La.
     • Liquid waste stream
       combustion (Vinyl I)
     • Combustion device on
       materials recovery unit
       (Vinyl II)

     E. I. duPont
     Westlake,  La.
     • Wastewater from  steam
       stripper

     Ethyl Corp.
     Baton Rouge, La.
     • Wastewater aeration
         0

      0.05
                                       None
                       None
Incinerator

Incinerator/vent
scrubber
  None

  None
                Steam stripper
                                       None
                        None
                                                                                                  (continued)

-------
                                              TABLE 2-10.   (continued)
      Plant/
      Plant location/
      Emission source
                              Current     Existing
                             emissions,    control
                               Mg/yr     technology
Applicable
additional
  control
technology
                                              Capital
                                             and annual
                                              cost for
                                             additional
                                             control, $
    Cost
effectiveness
 additional
   control
ro
i
Formosa Corp.
Baton Rouge, La.
• Wastewater discharge
• Wastewater discharge

Formosa Corp.
Point Comfort, Tex.
• Wastewater discharge


Georgia Pacific
Plaquemine, La.
• Wastewater from steam
  stripper
• Liquid incineration

01 in Corp.
Lake Charles, La.
• Biological treatment
  pump wastewater

PPG Industries
Lake Charles, La.
• Emergency scrubber
  on steam stripper
 • Incinerator on EDC
  recovery from steam
  stripper
 • Wastewater discharge
                                      190      Steam stripper.
                                      127      Steam stripper
122




  O1

  0


**n
                                         m
                                     14.9

                                        0


                                        0
                                               Biosludge
  None
  None
  Steam
  stripper
                                                                      None

                                                                      None
                                                                      Steam
                                                                      stripper
  None

  None


  None
                                                                                                  (continued)

-------
                                            TABLE 2-10.   (continued)
IV)
Plant/
Plant location/
Emission source
Shell Chemical
Deer Park, Tex.
• Biological treatment of
wastewater
• Incineration of light
and heavy ends, tars
Union Carbide
llahnville, La.
• Incineration of waste
liquids
• Flush buggy vent
• Wastewater treatment
•
Vulcan Chemicals
Geismar, La.
• Wastewater from steam
stripper
• Effluent from scrubber
on tank vents
Capital
Applicable and annual Cost
Current Existing additional cost for effectiveness
emissions, control control additional additional
Mg/yr technology technology control, $ control

l.Tp None Steam 1 1
stripper
0 Incinerator None

0 Incinerator/scrubber None
0 Incinerator None
2.0 None Stream 1 1
stripper

0 Steam stripper None
0^ Oeepwell injection None

                                                                                                  (continued)

-------
                                        TABLE 2-10.   (continued)
Emissions from steam stripper are reported as zero.   Any EDC dissolved in the wastewater after steam
.stripping may be emitted to the atmosphere after the water is discharged.


C.-- = No control beyond steam stripping,  scrubbing,  or incineration costed.
 Wastewater to ponds is reported to contain less  than 10 ppm EDC.
^Approximately 0.8 kg/d of EDC are contained in the  water discharge.
 Emissions estimated as industry average  based on similar sized plants.
^Wastewater discharge contains about 0.15 Mg/yr of EDC.
 4
!NO control reported.
rPlant reports that 96 percent of EDC contained in waste discharge is emitted to the air.
Ifflant estimates that 50 percent of EDC contained in wastewater discharge is emitted to the air.
 Cost effectiveness exceeds $2,500/Mg ($2,260/ton) because of low EDC concentration.
'"Emissions are reported to be zero (closed system).
nWastewater discharge to biological treatment contains 87 Mg/yr of EOC.   The fraction that is emitted
 was not reported and was assumed to be 50 percent.
°EDC content of waste discharge not reported.
'Vlant reports that 90 percent of EDC contained in discharged wastewater is emitted to the air after
 discharge.
^Scrubber discharge contains about 0.2 Mg/yr.

-------
             TABLE 2-11.   NATIONWIDE EDC STORAGE PATTERNS3'b
Tank type
Fixed- roof
Internal floating roof
Pressure vessel
Open top
TOTAL
No. of tanks
103
9
11
3
141
emi
EDC
583.2
9.4
15.8
0.9
609.3
Nationwide
ssions, Mg/yr
VOC
803.9
9.5
24.2
3.6
841.2
.Chemical  industry only.
 Does not  include Borden  Chemical  at Geismar,  Louisiana,  or Diamond
 Shamrock  at Deer Park, Texas.
                                    2-43

-------
     TABLE 2-12.  CONTROLS USED ON EXISTING FIXED ROOF TANKS


                                No. of                Efficiency
Type                            tanks                 range, %


Thermal oxidation                 25                  98-99.99

Refrigeration                     40                  37-99.5

     TOTAL                        65
                                2-44

-------
   TABLE 2-13.   RETROFIT COSTS FOR WELDED STEEL INTERNAL FLOATING ROOFS
                         4th Quarter 1982 dollars
       Item
             Cost, $
1.   Degassing'
2.   Door sheet opening'

3.   Cost of the deckb
4.  Cost of Teflon  primary seal

5.  Cost of Viton  secondary seal'
Cost = 130.8 V0-5132; or $1,000:
whichever is greater

where V = tank volume in cubic
meters

$1,300

Cost ($l,000's) = 2.0 + 2.672D
                        «
where D = tank diameter in meters

$204 per meter of tank diameter

$580 per meter of tank diameter
 Reference No. 48.
 iReference No. 49.
 'Reference No. 27.
 Reference No. 28.
                                     2-45

-------
               TABLE 2-14.  HOC EMISSIONS AND COS1 DATA FOR RETROFITTING FIXEO-ROOF STORAGE TANKS WITH
                                       INTERNAL FLOATING-ROOFS (Primary Seals)
                                                March 1984 Dollars3
ro
i
en


Plant/Location
Arcu
Porl Arthur, Hex.
U F. Goodrich
Caivert City. Ky.











I), f. tioodrlch
Convent, la.
U F. Goodrich
IdPorle. lex.
Uordeii Clie*lcal<<
Geismar. La.
Diamond Shamrock
Deer Park. Tex.
Dow Chenlcal
CDC Plant
Freeporl. lex.

Dow Chemical
1.1.2 Irlcliloroelhane
Plant, Ireepori, Tex.
Oow f dun leal
Irkhlor Plant.
Freuport. lex.
Current Current Curient
Percent No. of control control EDC
Tank IOC storage le£l' [, ef"~b emissions.
type 'C stored tanks ni<|uei ciency H(j/yr

0 21
0.23
2
56
4
2
0.18
O.S4
0.10
0.30
0.90
63
46
I
0

0

F 100 10 p 90 2.4

F 100 10 p 98 50

F 56 2 r 8/ 3.4
F 100 1 r 37 0.63
F 5 1 s 67 0 04
F 100 2 r 9) 46
0.20
•

b
0 OH


Tola!
(.apitdl .
cost. $"•'

N/A
10.900
77.500
53.700
15.600
N/A
14.600
H/A
H/A
H/A
H/A
10,200
67.100
H/A
H/A

H/A

H/A

H/A

34.000
33.600
33,000
125,100
H/A


140,000
140,800


Animal
J/LM!
cosl.
-------
                                              TAOLE 2-14.   (continued)
r\>
i


Plant/Local ion
Dow Chemical
Oyster Creek, Tex.
Dow Chemical (Vinyl 1)
Plaquemine, la.




Dow Chemical (Vinyl 11)
Plaquewine, La.
Dow Chenical
Texas Division
OuPonl (Conoco)
West lake. La.






tlliy 1 Corp.
Baton Rouge, La.

Formosa Plastics
Balon Rouge, La.

Fornosa
Co i nl Comfort, lex.




lype >C
F
F
F
F
F
F
F
F
F
F
'F
F
F








PV
PV
PV
PV
F
F
F
F
F
F
F
F
F

Pei cent
EDC
stored
99
76-99
76-99
99
99
99
99
99
99
99
100
100
99








99
99
50
99
100
100
99
30
95-99
99
99
100
30-50

No of
storage
tanks
2
1
1
1
1
1
1
1
1
1
1
2
1








2
1
1
1
2
1
1
1
1
1
1
1
2
Current
control
lech
niques
w
w
w
X
X
X
X
X
X
X
X
X
r








1
P
y
P
t
aa
p
1
y
y
y
y
y
Currenl
control
effi-b
tiency
99
99
99
95
95
95
95
95
95
95
95
95
99








0
99.9
0
99.9
85
BO
99 9
0
99
99
99
99
99
Currenl
EDC
emissions
Mg/yr
0.43
0.23
0.15
0.22
0.00
0.30
0.77
3.0
2.1
1.2
4.9
3.5
0.40

21
0
O.OOB
0
0
0.01
0
0
3.5
0 04
3.0
0.01
29
20
0 25
0.60
0.10
0 26
0.81
1.0
0.02

loldl
capital
cosl. »*•'
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A

114.400
N/A
N/A
N/A
N/A
N/A
N/A
N/A
11.500
H/A
10.600
N/A
110.500
42.600
N/A
22.600
N/A
N/A
N/A
N/A
N/A

Anniid 1 -
ized
cosl.9 $
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A

27.000
N/A
N/A
N/A
N/A
N/A
N/A
N/A
3.000
N/A
2. BOO
N/A
29,000
11.200
N/A
5.900
N/A
N/A
N/A
N/A
N/A
EDC
emission
Mg/yr ,
reduclion
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A

20
N/A
N/A
N/A
N/A
N/A
N/A
N/A
3
N/A
2.7
N/A
28
IB
N/A
0.60
N/A
N/A
N/A
N/A
N/A
EDC
recovery
credits
$3.l
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A

6.500
N/A
N/A
N/A
N/A
N/A
N/A
N/A
1.000
N/A
900
H/A
9.100
5.900
N/A
200
N/A
N/A
N/A
N/A
N/A
Nel
annual
ized.
cosls,J $
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A

20,500
N/A
N/A
N/A
N/A
N/A
N/A
N/A
2.000
N/A
1.900
N/A
19,900
5.300
N/A
5.700
N/A
N/A
N/A
N/A
N/A
	 j
Cosl
effect
iveness,
$/M./
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A

i.OOO
N/A
N/A
N/A
N/A
N/A
N/A
N/A
700
N/A
700
N/A
/OO
300
N/A
9.500
N/A
N/A
N/A
N/A
N/A
/-nut I iiiiufl

-------
                                                   TABLE 2-14.   (conlimied)
INJ

4*
00


Plant/Location
Georgia Pacific
Plaquemine, la.







01 in Corporation
Lake Charles. La.
I'l'G hulustries
take Charles. La.
Shell Chemical Company
Oc-er Park. lex.




Union Carbide
laft, la
Vulcan
fioismar, La.





Vulcan Chemicals
Uirhtta Kins

Percent
lank tDC
type • stored










f N/A
f N/A
f 9'J
F 100
F 100
F 100
F 0-50
F S 10
f 100

F 100
F 100
F 100
f ion
F 100
F 100
F 100


Ho of
storaye
tanks










a
3
1
1
2
1
1
1
1

1
1
3
1
1
2
1

Cm f (Mil Current
control control
niqiie!> ciency










p 100
Mi 100
cc 99 99
cc 99.99
cc 99.99
cc 99.99
cc 99.99
I 0

-------
                                                          TABLE  2-14.    (continued)
^Calculated using CE Plant Cost Index and MIS Equipment Cost Index (Chemical  Engineering June 11,  1984).
 Cited from Section 114 information request  responses
c!ank types.                 '
   F = fixed roof.
 Clf = Contact internal floating roof.
   S = Spherical lank.
   II = Horizontal lank.
  IIP = Horizontal pressure lank.
 . HV = Pressure vessel.
 Current storage tank emissions (per tank basis) based upon Section 114 information request responses.
"Refer lo Table 2-13.
 Additional cost for I lie use of a Teflon coaled primary seal ~$230/m (m = meler of diameter). Reference No.  27.
^Reference No. SO.
,Internal floating roof (primary seal only). 94 percent emission reduction efficiency.
HOC value -$320/Mg (First Quarter 1984 dollars). Reference No  46
^Annual tied cost minus EOC recovery credits.
.Net annual(zed cost per unit of emissions  reduced

m
ii
o

"incinerator.
^Estimated as industry average.
      condensei
      scrubber
I*
 Venl condenser.
wHechanical refrigeration units and condensers.
  Refrigeration vapor recovery.
  Nitrogen blankets and incineration.
  Vapor recovery.
*. Conservation vents and inerts.
  H
..C
 He t r i gerat i on/recyc 1 e .
 .Compression and incineration.
 lank is nitrogen blanketed,  submerged  filled. Insulated and refrigerated.

-------
TABLE 2-15.  EDC EMISSION REDUCTION FROM FIXED ROOF TANKS AS A  FUNCTION
                         OF COST EFFECTIVENESS
Cost
effectiveness
range, $/Mg
Credit
0-100
100-500
500-1,000
1,000-2,000
>2,000
TOTAL
No. of tanks
7
1
2
8
4
18
40
Nationwide
emission
reduction.
Mg EDC/yra
345
43
26
95
22
41
572
        aBased on welded, contact internal floating  roof with
         primary seals only.
                                 2-50

-------
                  TABLE 2-16.   FIXED ROOF TANK SUMMARY
EDC
emission
range,
Mg/yr
0-1
1-10
10-20
>20
Total
No. of
tanks
70
42
2
10
124
Percent
of
tanks
56
34
2
8
100
EDC
emissions,
Mg/yr
8
175
34
461
678
Percent
of
emissions
1
26
5
68
100
Emission
reduction,
Mg/yra
2
84
31
455
572
Based on welded contact internal floating roof with primary seals only.
                                  2-51

-------
TAULE 2-17,
VOC EMISSIONS AND COS] DATA f()R RETRO, I II ING FIXED-ROOF STORAGE TANKS WITH
           INTERNAL FLOATING-ROOHS (Primary Seals)
                    March 1904 Dollars*

Ho ol
lyuo ' tanks
Port Arthur, lux.
U. 1 (lUOlli till
fdlverl City. Ky








J\»
en
r\J
U. 1. tiooUi iili
Convent, la.
U. f. (uiouYicli
laPoitu. lex. •
Uonlvn ClieMicalr f 10
(ieismar. la.
Diamond Shamrock* f 10
Ouer Park. lex.
Oow Chemical ' 1 2
IOC Plant f )
freeiiorl. lex. t 1
f 2
Uow Chemical
1.1.2 Irlcliloroethantt
Plant, fiuuuorl, Tex.
UOM Chemical
Irichlur Plant
fr«e|iort. lex.
Curi enl Curi eiit Current
contiul control VOC
nlqnesb cieitcy1* Mu/yr
0 21
12
100
57
4
2
0 72
2.0
0.40
12
0 95
64
46
1 0

0

0

 ,,
leiluil Ion
H/A
II
94
54
40
H/A
0 70
H/A
H/A
H/A
H/A
60
44
H/A

H/A

H/A

N/A

H/A

5
0 60
0 75
4
H/A


10
0 16

VOC
recovery
credits.
,1.1.
N/A
1.600
10.600
17.600
1.100
H/A
210
H/A
II/A
H/A
H/A
19.600
14.200
N/A

H/A

N/A

N/A

H/A

1.000
200
250
1.400
H/A


1.100
50

Mel
annual'
lied
costs, t
H/A
-700
-10.200
-3.500
2.000
N/A
1.600
H/A
H/A
H/A
M/A
-16.900
3.400
H/A

H/A

H/A

H/A

H/A

7.100
6.600
11.100
11.500
N/A


27.400
10.600

Coil
effect-
iveness
H/A
-65
-no
-65
/OO
H/A
5.100
H/A
II/A
N/A
N/A
-200
00
N/A

N/A

H/A

II/A

H/A

1 . 100
14.100
10.500
7.100
N/A


2.700
191.100


-------
TABLE  2-17.   (continued)


Dow Chemical
Oyster Creek, lex.
Uuw Chemical (Vinyl 1)
PlaqueMine. La.




Oow Chemical (Vinyl 11)
Naquenine, la.
Uow Chemical
Texas Division
^° UiiPonl (Conoco)
en West lake. La.
Co





Flhyl Coip.
Uaton Kouye, la

Formosa Plastics
baton Houye. la

Formosa
Co i nl Comlorl. lex.


Current
Ho of control
lank. storage tech- ^
type ' tanks niques
{ 2 x
F x
F y
F y
f V
1 7
f V
f t
f . • v
F v
• *
F y
F 2 J
F 1 s







PV 2 •
HV q
PU 1
f ¥ *
PV <|
: aa
t>b
(I
1
A
2
2
j
/
2 2
Current
control
•I"-*,
ciency
99
99
99
95
95
95
95
95
95
95
95
95
99







0
9.9.9
0
99 9
05
BO
99 9
0
99
99
99
99
99
Current
VOC
emissions.
Ha/yr
0 43
0 23
0 15
0 22
0 Bl
0 30
0/8
2 0
2 1
i a
4 9
35
0 40

21
0
0 OOB
0
0
0 01
0
0
3.5
0 04
6
0.01
29
20
0 3
2.0
0.10
0 26
O.B2
1 0
0.04
Total
capital .
cost. $*•'
H/A
H/A
H/A
N/A
H/A
N/A
H/A
N/A
N/A
H/A
H/A
H/A
H/A

114.400
N/A
N/A
H/A
N/A
H/A
N/A
N/A
11.500
H/A
10.600
H/A
110.500
42.800
N/A
22.600
H/A
H/A
N/A
H/A
N/A
Annual-
lied
cos I. $
N/A
N/A
N/A
H/A
H/A
N/A
H/A
N/A
H/A
H/A
H/A
H/A
H/A

2/.000
H/A
H/A
N/A
N/A
H/A
H/A
N/A
3.000
N/A
2.000
N/A
29.000
11.200
N/A
5,900
N/A
H/A
H/A
H/A
H/A
VOC
emiss ion
Ha/yr ,
reiltu Lion
N/A
N/A
N/A
N/A
N/A
N/A
H/A
N/A
N/A
N/A
H/A
H/A
N/A

20
N/A
H/A
H/A
H/A
H/A
N/A
H/A
3
H/A
5 5
H/A
20
IB
H/A
1.9
N/A
H/A
N/A
H/A
N/A
VUC
recovery
credits.
N/A
N/A
H/A
H/A
N/A
H/A
H/A
N/A
N/A
H/A
N/A
N/A
N/A

6,500
N/A
N/A
H/A
N/A
N/A
N/A
N/A
1.100
N/A
1 .000
H/A
9.000
6.000
H/A
620
N/A
H/A
N/A
H/A
H/A
He I
annua 1 -
lied
costs. »
H/A
H/A
N/A
H/A
N/A
H/A
H/A
N/A
N/A
N/A
N/A
N/A
N/A

20,500
N/A
H/A
N/A
H/A
N/A
H/A
N/A
1.900
N/A
1.000
N/A
20,000
5.200
H/A
5.300
H/A
H/A
N/A
H/A
N/A
Cost
effect-
iveness
I/Mo,1
H/A
N/A
N/A
N/A
H/A
N/A
H/A
H/A
H/A
H/A
H/A
N/A
H/A

1.000
H/A
H/A
H/A
H/A
N/A
H/A
H/A
500
H/A
1UO
N/A
/(HI
100
N/A
2.UOO
N/A
N/A
N/A
N/A
H/A
                                                                 (toni inuetl)

-------
                                                   TAULE  2-17.   (continued)
f\>
0
in



tieoruia Pacific
Plai|iiewine, la.








01 in Corporation
lake Charles, la.
fl'li Industries
lake Charles, la.
Shell Chemical Cowpany
Deer Park, lex.




Union Carbide
lafl. la.
Vulcan
Gefswar, la.





Vulcan Cltcn teals
Wichita, Kans.

No. of
lank. storage
lype • tanks












F 0
F 3
1
1
2
1
1
1
f 1

F 1
F 1
F 3
F 1
F 1
F 2
F 1


Current
control
lech
ni<|iies













-------
                                                                    TABLE  2-17.    (continued)
          'Calculated usiny LI Plant Cost liulex anil MiS Equipment Cost Index (Chemical Engineering, June II. 1904).
           Cited I mat Section 114 information request  responses
           'lank types.
             I  - f ixed roof.
           Cll  - Contact internal floating roof.
             S - Spherical tank.
             II = lloriiontal tank.
            IIP = Horizontal pressure lank.
            I'V = Pressure vessel.
           Cunenl storage lank emissions (per tank basis) based upon Section 111 information request responses
                 to (able 2-13.
           Additional cosl for Ibe use of a lei Ion coaled primary seal  J2JO/» (« - meter of diameter). Deference Ho.  27
          !JKeference No  60.
           '         floating roof (prinary seal  only),  94 percent emission itiluttlo/i efficiency
           llHC value ~$126/My (first Quarter 1964 dollars). Reference Ho. 46
           ^Assumed VUC value equal to [DC value.
           .Annuali/ed cosl minus fUC recovery credits
           Mel annualiied cosl per unit of emissions reduced
          m                    r
           n
           o
           P,
           ''incinerator
           Estimated as industry averaye.
           fvenl condenser.
,xj
 I          Vent scrubber.
en        "
cri        v
           Hechanical refrigeration units and condensers
          yHefrigeration vapor recovery.
           Nitrogen blankets and  Incineration.
           Vapor recovery.
          .'Conservation vents and inerts.
         Yjttefriyeration/recycle.
           Com|>ression and  incineration.
                 is nitrogen blanketed,  submerged filled,  insulated and  refrigerated

-------
              TABLE 2-10.
i
<_n
ot
EDC EMISSIONS AND COS1  DATA FOR RE1ROF1ITING FIXED-ROOF  STORAGE  TANKS  WITH
    IN1ERNAL FLOAT ING-ROOFS (Primary and Secondary Seals)
                    March T984 Dollars


PUnl /local Ion
At CO
I'uil Arthur, lex.
U. (. UuudrUh
Calveit City. Ky.










U 1 Cooiti Uli
Convent , la.
U 1 . tooil« Icli
laCorle. lex.
H.rJ.n Cla-.cal'
Ulomuml Shamrock'
fleer 1'ark. lex.
Ouw Cliuinicdl
(OC Plant
fieunurl. lex
U,,w Chemical
1,1,2 Iriihluroethane
Plant. 1 rttj)U( 1 , (ex.
v
Triihlor Plant
( > iitjiui I . lex.
Curient Current Current
Percent Ho at control control IDC
lank (OC slorage lecli- e«"'|, emissions.
ty|ie ' sluieU tanks niques ciency Hy/yi
0 21
0 23
2
56
4
2
• 0. 10
0 54
0 10
0.30
0 90
63
46

0

0
•
( 100 10 q 90 24
f 100 10 i| 90 50

f 56 2 i 07 3.4
| 100 1 » 37 0 63
t SI t 67 0 04
( 100 2 s 93 46
0 20


6
0 00


loldt
co"'."ig!«-
H/A
12.100
91.900
56.500
17.700
H/A
16.900
H/A
H/A
H/A
H/A
11.500
70.100
H/A
H/A

H/A

H/A
H/A

40.000
39.100
39.000
149.100
H/A


H/A
H/A


Anmut 1 -
iJeil
u cost."*
H/A
3.200
25.600
16.500
4.700
H/A
4 . 700
H/A
H/A
H/A
H/A
3 000
20,500
H/A
H/A

H/A

H/A
H/A

10.500
10.300
10.250
39.200
H/A


H/A
H/A

(DC
tMiUUou
reduction
H/A
0.22
1.9
54
4
H/A
O.I?
H/A
H/A
H/A
H/A
61
4&
. H/A
H/A

H/A

H/A
N/A

3.3
0.61
0.04
4 S
H/A


H/A
H/A

IOC
iccuvery
credits
r-1
H/A
70
600
17.600
1.300
H/A
60
H/A
H/A
H/A
H/A
19.900
14.700
H/A
H/A

H/A

H/A
H/A

1 . 100
200
IS
1.500
H/A


H/A
H/A

Hut
aniiiia 1 - i
costs/ }
H/A
3.100
24.900
- 1 . 100
3.400
H/A
4.600
H/A
H/A
H/A
H/A
-16.900
IS. 000
H/A
H/A

• H/A

H/A
It/A

9.400
10.100
10.250
37.700
It/ A


H/A
H/A

{.Oil
L-lllMl
T/HU*
H/A
14.100
13.100
-20
or>o
H/A
27.100
H/A
H/A
H/A
H/A
-200
110
H/A
H/A

H/A

H/A
H/A

2.900
16.600
256.300
0.400
H/A


H/A
H/A

                                                                                                         (con

-------
                                              TAQLt 2-18.   (continued)
ro
i
en
Current Curienl
Percent No of control control
Plant/location
Uiiw Chemical
Oyster Creek, (ex.
Uuu Chemical (Vinyl 1)
Pla<|uemine, la.




bow Chemical (Vinyl II)
Plb
•


'
99
99
99
95
95
95
95
95
95
95
95
95
99







0
99 9
0
99 9
05
00
99 9
0
99
99
99
99
99
Current
EUC
emissions
Mtf/yr
0 41
0 23
0 15
0.22
0 80
0 30
0.77
3.0
21
12
4 9
3 5
0.40

21
0
0 008
0
0
0.01
0
0
35
0.04
3.0
0.01
29
20
0 25
0 60
0. 10
0 26
O.B1
1 0
0 02
folal
IOC
Annual- emission
tapiljl, lied Mg/yr }
cosl. I8'1-" cost." $ reduction
H/A
N/A
H/A
N/A
H/A
H/A
H/A
H/A
H/A
H/A
H/A
H/A
H/A

121.100
H/A
H/A
H/A
H/A
H/A
H/A
• H/A
13.000
H/A
11.900
H/A
129.900
49.900
H/A
26.500
H/A
H/A
H/A
H/A
H/A
H/A
H/A
H/A
H/A
H/A
H/A
H/A
H/A
H/A
H/A
H/A
H/A
H/A

35.400
H/A
H/A
H/A
H/A
H/A
H/A
H/A
3.400
H/A
3.100
H/A
34.100
13.100
H/A
7.000
H/A
H/A
H/A
H/A
H/A
H/A
H/A
H/A
H/A
H/A
N/A
H/A
H/A
H/A
H/A
H/A
H/A
H/A

20 4
H/A
N/A
H/A
H/A
H/A
H/A
N/A
34
H/A
2.0
H/A
2B 5
19
H/A
0.6
H/A
H/A
H/A
H/A
H/A
I DC
recovery
ciedils
$».J
H/A
H/A
H/A
H/A
N/A
H/A
H/A
M/A
H/A
H/A
H/A
H/A
H/A

6. 700
H/A
14/A
H/A
H/A
H/A
H/A
N/A
1 . 100
N/A
900
H/A
9. JOO
6.200
H/A
200
H/A
H/A
H/A
H/A
H/A
He I Cost
anmia 1 - e 1 f et I -
lied . Ivenesj
costs." » t/Mtj
N/A
H/A
N/A
H/A
H/A
N/A
H/A
N/A
H/A
H/A
H/A
H/A
H/A

20. 700
N/A
N/A
H/A
H/A
N/A
H/A
H/A
2.100
N/A
2.200
H/A
24,000
6.900
H/A
6,000
H/A
H/A
H/A
H/A
H/A
/rn
N/A
H/A
H/A
H/A
H/A
N/A
H/A
H/A
H/A
N/A
H/A
H/A
N/A

1.400
H/A
H/A
N/A
H/A
N/A
H/A
H/A
(.110
N/A
/'JO
H/A
U/0
IbO
H/A
1 1 . JOO
H/A
H/A
H/A
H/A
H/A

-------
                                                   TABLE 2-18.   (continued)
ro

en
CD


Plant/location
Georgia Pacific
iMaiMiemine. la.








01 in Corporation
Lake Charles, la
PI'U Industries
lake Charles, la.
Shell Chemical Company
Deer Park, lex.




Union Carbide
lafl. la.
VlllCdll
(ieiswar, la.





Vulcan Cheuicals
Ulchita. Kans.


type •*•





»






F
F
f
F
F
F
F
F
F

F
F
F
f
F
F
F



Pvi cent
(DC-
stored












H/A
H/A
99
100
100
100
0-50
5-10
too

100
100
100
100
100
100
100


Current
No of control
sloidye leclr.
tanks »l<|i»tb












a q
3 cc
1 (III
1 dd
2 dffl
H/A
H/A
H/A
N/A
N/A
N/A
H/A
H/A
H/A
H/A
H/A

H/A
H/A
N/A
N/A
H/A
N/A
H/A
H/A
113.300

15.100
11.900
25.700
33.700
121. '100
124.400
135,000
H/A
H/A

Annudl-
tietl.
cost." »
H/A
H/A
N/A
N/A
H/A
H/A
H/A
N/A
N/A
N/A
H/A

N/A
N/A
N/A
H/A
H/A
H/A
H/A
N/A
29.000

4.000
3.100
6.000
0.900
31.000
32 . 700
35.600
N/A
N/A
EOC
emission
M.j/yr .
reduction
N/A
N/A
H/A
H/A
N/A
N/A
H/A
H/A
H/A
H/A
H/A

N/A
N/A
H/A
H/A
N/A
N/A
N/A
H/A
13.6

77
9.2
3.2
6.6
34
3.5
7.3
N/A
N/A
EDC
recovery
credits
$».J
H/A
H/A
H/A
H/A
H/A
N/A
N/A
N/A
N/A
N/A
N/A

H/A
H/A
H/A
H/A
H/A
N/A
H/A
H/A
4.400

2.500
3.000
1.000
2.200
1.100
1.100
2.400
N/A
N/A
Net
anniia 1 -
Ued .
costs.
H/A
N/A
H/A
H/A
H/A
H/A
H/A
H/A
H/A
H/A
H/A

H/A
H/A
H/A
H/A
H/A
H/A
H/A
N/A
25.400

1.500
100
5. 800
6.700
30.700
31,600
33,100
N/A
N/A
Cost
sllecl-
Iveness
$ »/Ms|
H/A
N/A
N/A
H/A
H/A
H/A
N/A
N/A
N/A
N/A
N/A

N/A
N/A
N/A
H/A
H/A
H/A
H/A
N/A
1.900

200
10
1.000
1,000
9,000
9.000
4.500
H/A
H/A
                                                                                                                    (continued]

-------
                                                                     TABLE  2-18.    (continued)
          "
          "calculated usiny Ct Plant tost  Index  and HIS f<,uipmcnl tost Index (U.ernical tnylneeriny June U.
          Ceiled frum Seclion 114 inlormation lequest  responses
           lank types.
             f = fixed roof
           til - Contact internal floatiny roof.
             S = Splierical tank.
             II - llorjiontal tank
            III' - Horizontal pressure tank.
•            I'V ~ Piessure vessel
          Current sloraye tank emissions (per tank basis)  based upon Section  114  information request responses.

          CdUional'cos't'for tbe use of a leflon coaled primary  seal ~|2JO/« (•  = ««««« of dU.eler)  Reference Mo  21
          "fosl lor a Viton* coaled secondary seal ~656/. (. = melers of  diameter) 1st Quarter  1904 dollars. Reference No  20
           .Reference Mo  50.
           llnlernal lloaliny loot (primary and secondary  seal). 9? percent  emission reduction efficiency.
          htiC value ~»126/M        'Vent condenser
 I         Vent scrubber.
en        u
           "
  Mechanical  relriyeration units  and condensers.
 yl(e(rimeiaed filled,  insulated and refrigerated
          eL'

-------
TABLE 2-19.
VOC EMISSIONS AND COS1  UATA FOR RETHOFI1TING FIXED-ROOF STORAGE TANKS WITH
    IN1ERNAI. FLOA1 ING-HOOFS (Primary and Secondary Seals)
                    March 1984 Dollars

furl Arllkur. lex.

Calvurl City, Ky.








ro
i
crt
Cl
U. 1 . GuoilritU
Convent, la.
U. f. tioutirith
tdPorle. lex
OorUen Clienical
Guismar. la.
S
U«ur Park, lex
Ouw Client it a 1
IDC Pldiit
1 iu4!|>ort. lex.
HUM Diem it a 1
1,1,2 Iritliloruelliane
Plant. Ireeuoil, lex.
Don Chew leal
h fUiior Plant
f t «!or I , lex.
Current Current Current
No ol control tonlrol VOC
lank. storage teen- elfl- e«lsslyns
type >C tdnki nlguti ciemy M>j/yr
0.21
12
100
4
2
0 72
2.0
0.40
1.2
0.95
64
46
1 0

0

0

f 10 r 90 2.4

f 10 r 90 5.0

[ 210/6
f 1 t 17 0.61
f I u 67 0 00
f 21 91 46
0.20


II
0 16

lulal
cost. I •
H/A
12.100
91.900
56. 600
17.700
H/A
16. 'JOO
H/A
H/A
H/A
H/A
II !iOO
70. 100
H/A

H/A

H/A

H/A

H/A

40.000
19.100
19.000
149.100
H/A


H/A
H/A

Annud 1 -
H/A
1.200
25.500
16.500
4.700
H/A
4 . 700
N/A
H/A
H/A
H/A
1.000
20.500
H/A

H/A

H/A

H/A

H/A

10.500
10.100
10.2'jO
19.200
H/A


H/A
N/A

VOC
uml&slun
lUj/yr ,
N/A
11.6
97
1.9
H/A
0.70
H/A
N/A
N/A
H/A
62
45
H/A

H/A

H/A

H/A

H/A

5.0
0.61
0.70
45
N/A


H/A
N/A

VOC
recovery
Lrfitlllt.
H/A
1.000
11.600
18.000
1.100
H/A
210
N/A
H/A
H/A
H/A
20.200
14.700
H/A

H/A

H/A

H/A

H/A

1.900
200
250
1,500
H/A


H/A
H/A

Net
lief
coils, t
N/A
-600
-6.100
-1 500
1.400
H/A
4.500
H/A
H/A
H/A
H/A
-I/. 200
5.000
H/A

H/A

H/A

H/A

H/A

0.600
10.100
10.000
17.700
H/A


H/A
H/A

Cost
ellecl-
ivvness
I/Ha
H/A
Ml
60
-10
070
H/A
6.40U
H/A
H/A
N/A
H/A
-2UII
110
H/A

H/A

H/A

N/A

H/A

1.500
16.600
12.000
0.400
N/A


H/A
H/A


-------
                                              TABLE  2-19.   (continued)
ro
i
cr>




Oysler Creek, lux.
Dow Chemical (Vinyl 1)
l'|j<|ue«iiie. la.




Dow Chemical (Vinyl II)
Plaqneiuine. La.
Dow Chemical
lexas Division
Diit'tml (Conoco)
West lake. Id.





1 Iliyl Coru
(la luii ttuuye. la

1 uiuusa Plaslics
Da I on Huiiye. La

1 oiMosa
I'oinl Coulort. lux.




lyuel)>C
t






f
f
f







PV
PV
PV
PV
f
1
f
r
t
i
f
t

Current
No. ol control
slorane teclr
lanks ni(|ties
2 y
y
y
I
J
1
I
I
\ I
2 l
1 1







2 n
1 r
1 aa
1 r
2 bb
1 cc
1 r
1 ii
1 aa
I aa
1 aa
I aa
2 aa
Cm rent
control
effl
ciency
99
99
99
95
95
95
95
95
95
95
95
95
99







0
99 9
0
99 9
85
60
99 9
0
99
99
99
99
99
Current
VOC
emissions.
Mu/yr"
0 41
0.21
0 15
0.22
0 81
0.10
0 78
1 0
21
1.6
4 9
1 5
0 40

21
0
0 006
0
0
0 01
0
0
1.5
0 04
6
0 01
29
20
0 1
2 0
0 10
0.26
0.62
1 0
0 04

lolal
capilal , „
cosl. $'•'•"
N/A
H/A
N/A
N/A
H/A
N/A
H/A
N/A
N/A
N/A
N/A
N/A
N/A

121.100
H/A
N/A
N/A
H/A
H/A
N/A
N/A
11.000
H/A
11.900
H/A
129.900
49.900
H/A
26.500
H/A
N/A
N/A
N/A
N/A

Annual-
co!Crt »
H/A
N/A
N/A
N/A
H/A
N/A
N/A
N/A
H/A
N/A
N/A
H/A
H/A

15.400
H/A
N/A
H/A
N/A
H/A
H/A
N/A
1.400
N/A
1.100
N/A
14.100
11.100
N/A
7.000
N/A
H/A
N/A
H/A
N/A
VOC
emlSblon
M.j/yr ,
reiltii I ion
H/A
N/A
N/A
N/A
H/A
H/A
N/A
H/A
N/A
H/A
H/A
H/A
N/A

20 4
N/A
N/A
N/A
H/A
N/A
N/A
N/A
1 4
N/A
5 8
H/A
20 5
19
H/A
1 9
H/A
H/A
N/A
N/A
N/A
VOC
recovery
credit £ ,
N/A
H/A
N/A
H/A
N/A
H/A
H/A
N/A
N/A
N/A
N/A
H/A
H/A

6.700
H/A
N/A
H/A
N/A
H/A
N/A
H/A
1.100
H/A
1.900
N/A
9.100
6.200
N/A
bOO
H/A
H/A
N/A
N/A
H/A
Met
annual
iicd
cosls, J
N/A
H/A
N/A
N/A
H/A
N/A
N/A
H/A
N/A
N/A
H/A
H/A
H/A

28 . /OO
N/A
H/A
N/A
N/A
N/A
N/A
N/A
2,100
H/A
1.200
N/A
24,800
6.900
N/A
6.400
N/A
N/A
N/A
N/A
N/A
Cusl
eMecl-
jveness
I/MU
N/A
N/A
H/A
H/A
H/A
H/A
N/A
N/A
N/A
H/A
H/A
H/A
H/A

1,400
H/A
H/A
H/A
N/A
N/A
H/A
H/A
600
H/A
200
H/A
0/0
K.O
H/A
1,400
N/A
N/A
H/A
N/A
N/A

-------
                                                  TABLE  2-19.   (continued)
f\>
I
—— — 	 	 — — ^^ 	 ~ 	 i


Ceoryid Pacific
Pla<|iie«ine. La.







01 in Corporation
lake Charles, La.
I'I'U hutustries
lake Charles, la.
Shell Cltunical Cowpany
Oeer Park, lex.




Union Carbide
laft. la
Vulcan
Geiswar, la.





Vulcan Chew lea U
Uirhlta Kans.


type °c










f
f
f
f
f
f
f
f
f

f
f
f
f
f
F
0


No. of
iloi line
tanks"










a
i
i
i
2
1
1
1
1

,
1
1
I
1
2
1

Current
control
lech-
nii|iies










r
u.l
ee
ee
ee
ee
ee
n
ff

n
n
n
t
i
i
t

Current
control
effi-
ciency










100
100
99.99
99.99
99.99
99 99
99 99
0
60

0
0
0
90
90
90
90

Current
VOC
ewissiuns.
Mtf/yra
0.001
0.001
0
0
0.001
0.001
0.001
0
0.001
0
0

0
0
0.000
0.001
0.005
0.01
0
0.90
14

a
9.5
11

1.5
1.6
7.5
0
0

total
capital .
cost, j*-1'*
N/A
N/A
N/A
N/A
H/A
H/A
H/A
H/A
H/A
H/A
H/A

H/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
m.JOO

15.100
11.900
25.700
13.200
121.100
124.400
115.000
N/A
N/A

Anniia 1 *
• '"H
1 cosl. t
H/A
N/A
N/A
H/A
H/A
N/A
N/A
H/A
H/A
H/A
N/A

H/A
N/A
N/A
N/A
N/A
N/A
H/A
N/A
29.000

4 .000
1.100
6.600
a. 900
11,000
32,700
35.500
N/A
H/A
VOC
emission
Mfl/yr ,
reiluclion
N/A
N/A
H/A
N/A
N/A
N/A
N/A
N/A
H/A
H/A
H/A

H/A
H/A
N/A
N/A
H/A
N/A
N/A
N/A
11 6

78
92
1.2
60
1.4
1.5
7.1
N/A
H/A
VOC
recovery
cred|l|.
H/A
N/A
H/A
N/A
H/A
H/A
H/A
N/A
H/A
H/A
H/A

N/A
N/A
H/A
H/A
H/A
H/A
H/A
H/A
4,400

2.500
1.000
1.000
2.200
1.100
1,100
2.400
H/A
H/A
He I
diinual-
ized
costs. $
N/A
H/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
H/A
H/A

H/A
H/A
N/A
N/A
H/A
N/A
H/A
H/A
25.400

1.400
110
5.000
6,700
10.700
11.600
11.100
H/A
H/A
tost
effect-
Ja8"
H/A
N/A
N/A
N/A
N/A
N/A
H/A
N/A
H/A
N/A
H/A

N/A
N/A
N/A
H/A
H/A
H/A
H/A
H/A
I.'JOII

100
15
1.000
1.000
9.000
9.000
4.500
N/A
N/A
                                                                                                                   (continued)

-------
                                                           TABLE  2-19.    (continued)
Calculated using CE Plant Cost Index and H&S  Equipment Cosl  Index (Chemical Engineering June II.
UCiled from Section 114 Information request  responses.
I1ank lypes.
   I - Fixed ioof.
 Cll = Contact internal floating rouf.
   S = Spherical tank.
   II - llorliontal tank.
  Ill' = lluriiontal pressure lank.
  PV = Pressure vessel.
^Current storage lank emissions (per lank basis) based upon Secllon  IM  Inlormallon request  responses.

lAUdUlo«*|i'cosl'iir'u»e use of a leflon coaled primary seal  ~»2)0/m (m  =  meler of  diameter) Reference  No.  27.
"tost  lor a Viton*  coaled secondary seal ~656/m (. = melers of  diameter) 1st Quarter 1984  dollars.  Reference Ho.  2U

{intei'uaTfUallnu  •«">( (primary and secondary seal). 9?  percent  emission  reduction efficiency.
^Assumed VOC  value  equal to EDC value.
,I(IC value ~$326/Mg (first Quarter 190* dollars). Reference Ho.  «6
 Annualiled cost minus (DC recovery credits.
"ik'l annual iied cost  per unit of emissions reduced.
ii
 I'
 M
 1 Incinerator
   nner.
 *tsliwaled as  industry  average.
  Vent  condenser.
 "vent  scrubber.
 yHecbanital relriyerallon units and condensers
 *Helrl|jeralion vapor recovery
."I'll i t rogun blankels and inc literal Ion.
 ' 'Vapor i ecovery
^Conservation vents and inerls.
 _ ;He I riyeral ion/recycle.
''             and inc literal ion
   uiiinoii                 .
"lank is nitrogen blanketed, submei unit filled,  insulated  and  refrigerated

-------
   TABLE 2-20.  EDC EMISSIONS FROM PRESSURE VESSELS
Emission
range,
Mg/yr
No.  of tanks
   Total
emissions,
   Mg/yr
0-1

1-5

>5

TOTAL
     7

     3

    _1

    22
    0.13

   10

    5.7

   15.83
                           2-64

-------
                TABLE 2-21.   PRESSURE VESSEL SUMMARY TABLE
No. of
tanks
1
2
1
Emissions,
Mq/yra
EDC
5.7
3.5
3.0
VOC
11
3.5
6
Emission
reduction,
Mg/yra
EDC
5.4
3.3
2.7
VOC
10
3.3
5.5
Cost
effectiveness,
$/Mq
EDC
5,350
600
690
VOC
720
600
180
aPer tank basis.
                                    2-65

-------
TABLE 2-22.   COSTING DATA FOR CONTROL OF  SHIPPING EMISSIONS
               First Quarter 1904 Dollars
Plant/location
Arco Chemicals, I'ort Arthur, lex.
U. f. Goodrich, Calvert City. Ky.
U. f. (ioodrich. Convent, La.
0 t. iioodrich. LaCorte. lex.
Dordun, (ieismar, La.
Diamond Shamrock, Deer Park, lex.
Dow Chemical, NCA/tUC plant,
Freeport. lex.
Uow Chemical,
ro 1,1.2 Irlcliloroelhanc plant
' frceport. Tex.
cn
Dow Chemical, Irichlora plant
Freeporl. lex.
Uow Chemical, Oyster Creek, lex.
Dow Chemical (Vinyl 1), flaquemine, La.
Uow Chemical (Vinyl II). flaquewine. La.
Dow Chemical, lexas Division
f. 1. diil'ont (Conoco), West lake, la.
Llliy 1 Corporation, Uaton Rouye, La.
Formosa , lialon Houye, la.
Formosa, Point Comfort , lex.
Ueor||ia Pacific, flaquemine, la.
tin i tnl Current
control control
Shifipiny vehicle noluijy ciency
Bdnje h 98
	 HO HI ('Oil 1(1) SMII'I'lHli 01 tUC 	
N/Rk
N/R


	 -HO AVAIIAHIt UAIA •
	 NO Htl'OHItU SIIII'I'INCi Of fOC 	
	 NO Hfl'OHHO SHIPPING Of fUC 	

	 NO KtrOHIlU illlrrlHIi Or tilt 	
	 NO Rfl'OltllU SMII'flNIJ Of tOC 	
	 NO Ktl'OKIEU SMII'I'lHI! Of IOC 	
Rail car o 0
(large o 0
H/K N/H N/R
Current LUC
IUC emission
em is reduc- lolal
sions Lion, capitdl
Ma/y« M(j/yr cost. »
5.6 N/A1 N/A
N/R








0 N/A N/A
0 N/A N/A
24
109 104 390.000
N/R
N/H
N/H
N/R
He I Cost
Annual- EOC annual- ellecllve-
tted. recovery I"-'1*! "OSSA -
cost, t credit. , f cost.1 $ »/Mg9
N/A N/A H/A N/A
--








N/A N/A N/A H/A
N/A N/A N/A N/A
B4.900 60.000 24,900 140

-------
                                                           TABLE  2-22.    (continued)
Plant/location
01 in Corporation, take Charles, La.
PPG Industries, lake Charles, la."
Shell Chemical Co.. Deer Park, lex.
Union Carbide, llahnville, La.
Vulcan Chemicals, Geismar, la.
Vulcan Chemicals, Wichita, Kans.w
Shipping vehicle
Rail car
Tank truck
Barge
	 NO REPORIEO
	 NO KEPORIEO
lank truck
Rail car
Barge
	 NO REPORIED
Current Current
control control
leclrb eff'"h
nology clency
H/R H/R
SHIPPING Of EOC 	
v H/R
v H/R
v H/R
SHIPPING Or tUL
Current EOC
EDC emission Net Cost
emls- reduc- lolal Annual- EOC annual- effectlve-
sions lion. capital iied. recovery i*ed, "CSSA
Mg/yr Mg/yrc cost. » cost. $ credit. $ cost.1 » »/Hy9
H/H
5
0 50
1.6
5.2
^Calculated using CE Plant Cost Index and H&S Equipment Cost Index (Chemical Engineering, June 11,
1X1 Cited front Section 114 information request.
O^ Efficiency of refrigeration system (98 percent) calculated by the differences in partial pressure
H/A N/A N/A H/A H/A N/A
1984).
per atmospheric pressure at: I, = standard temperature of
 storage vessel  and  T2 =  condensation.
 Reference No.  51.
jEDC value ~$326/Hg  first quarter 1984 dollars,  Reference Ho. 46.
 Annualized cost minus EOC  recovery credits.
?Mel annual ized cost per  unit of emissions reduced
.Refrigerated vapor  recovery system and incineration  system.
:N/A - Nol  Aiuilicalile.  Already achieves 98 percent or  greater control efficiency.

|N/K - Not reported.
 -- = Insufficient data upon which to base calculation
 Submerged fill  lines.   Refrigerated vent condenser  costed.
''A11  enclosed operation.
 insufficient data provided  for costing.  Emissions  cited are  total  for all three transportation nodes.
u
vVapor recovery  (emissions noted are for drying and system maintenance)
wlhe 1983 emissions  from  loading grain fumigants are estimated at 67 kg/yr.

-------
2.7  REFERENCES FOR CHAPTER 2

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

 2.  Key, J. A., and F. D. Hobbs.  (IT Enviroscience).   Ethylene  Dichloride:
     In:  Organic Chemical Manufacturing,  Vol. 8.   Selected Processes.
     Prepared for U. S. Environmental Protection Agency.  Research
     Triangle Park, North Carolina.  Publication No. EPA-450/3-80-028c.
     October 1980.   p. III-1-2.

 3.  Reference 1, pp.  8-9.

 4.  Mansville Chemical Products.  Chemical Product Synoposis-Ethylene
     Dichloride.  Cortland, New York.  September 1982.

 5.  Chemical Profile—-Ethylene Dichloride.  June  13,  1983.
                            »
 6.  Standard Research Institute.  Chemical Economics  Handbook,   p.  300.
     5203M and 651.5031c.

 7.  Reference 2, p. II-l.

 8.  Reference 1, p. 21.

 9.  Merch and Company.  The Merch Index of Chemicals  and Drugs.  Seventh
     Edition.  Rahway, New Jersey.  1960.  pp. 425-426.

10.  Reference 1, pp.  50-52.

11.  Reference 1, p. 34.

12.  Reference 1, pp.  25-30.

13.  Mannsville Chemical Products.  Chemical Products  Synopsis--
     1,1,1-Trichloroethane.  Cortland, New York.   November  1982.

14.  Reference 1, pp.  31-34.

15.  Mannsville Chemical Products.  Chemical Product Synopsis—Ethylene-
     diamine.  Cortland, New York.  December 1982.

16.  Reference 1, pp.  35-46.

17.  Mannsville Chemical Products.  Chemical Products  Synopsis--
     Trichloroethylene.  Cortland, New York.  October  1981.
                                  2-68

-------
18.


19.
20.
21.
22.
23.


24.


25.
26.

27.



28.



29.

30.
Mannsville Chemical Products.  Chemical Product Synopsis--Perchloro-
ethylene.   Cortland, New York.  October 1981.

U. S. Environmental Protection Agency.  Air Oxidation Processes  in
Synthetic Organic Chemical Manufacturing Industry-Background
Information for Proposed Standards.  Draft EIS.  Research Triangle
Park, North Carolina.  Publication No. EPA-450/3-82-001a.  October  1983.
pp. 8-1 - 8-22.

U. S. Environmental Protection Agency.  Benzene Fugitive Emissions--
Background Information for Promulgated Standards.  Research Triangle
Park, North Carolina.  Pubication No. EPA-450/3-80-032b.  June 1982.

Suta, B. E.  (SRI International).  Assessment  of Human  Exposures to
Atmospheric Ethylene Dichloride.  Prepared for U.  S. Environmental
Protection Agency.  Research  Triangle Park,  North  Carolina.  Center
for Resources  and Environmental Systems Studies Report  No. 82.
May 1979.  pp. 11-13.

Organic Chemical Manufacturing Volume 3:  Storage, Fugitive, and
Secondary Sources.  Prepared  for U.  S. Environmental Protection
Agency.  Research Triangle Park, North Carolina.   Publication
No. EPA-450/3-80-025.  December 1980.  p. V-15.
Telecon.  Glanville, J., MRI, with  Sontag,  D.
1984.   Information about steam  strippers.
                         Amcec.  September 11,
Memorandum from Maxwell, W., MRI,  to  Project  File  7710-L.
1984.  Costs of steam  strippers.
                                     September 11,
Control of Volatile  Organic  Compound  Emissions  from Volatile Organic
Liquid  Storage  in  Floating and  Fixed  Roof  Tanks.   U.  S.  Environmental
Protection Agency.   Research Triangle Park,  North  Carolina.   Publication
No.  EPA 450/3-84-005.   June  1984.   p.  3-3.

Reference 25, pp.  2-5  through 3-6.
Telecon.   Powers,  S.,
Iron.  July  26,  1984.
primary  seal  versus  a
MRI, with Bergstrom, B. , Chicago Brp'dge and
 Additional cost in using a Teflon  coated
polyurethane coated seal.
Telecon.   Powers,  S.,  MRI,  with  Mason,  M.,  Chicago Bridge and Iron.
July  27,  1384.   Cost for  the  installation  of a secondary seal coated
with  Viton .

Reference 25,  p.  5-5.

Erickson,  D.  G.   Storage  and  Handling.   In:   Organic Chemical
Manufacturing.   Volume 3:   Storage,  Fugitive, and Secondary Sources.
U.  S.  Environmental  Protection Agency.   Research Triangle Park,
North Carolina.   Publication  No.  EPA-450/3-80-025.  December 1980.
p.  III-2.
                                   2-69

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 31.  U.  S.  Environmental  Protection  Agency.   Evaluation of Air Pollution
     Regulatory  Strategies  for  Gasoline  Marketing Industry.   Research
     Triangle  Park,  North Carolina.   Publication  No.  EPA-450/3-84-012a.
     July  1984.  p.  2-8.

 32.  Mosser, C.  C.   "Transportation  and  Marketing of  Petroleum Liquids."
     In:   Air  Pollutant Emission  Factors,  AP-42,  2nd  Edition,  Part A.
     U.  S.  Environmental  Protection  Agency.   Research Triangle Park,
     North  Carolina.  August 1977.   pp.  4.3-13  to 4.3-14.

 33.  Reference 21, p. 10.

 34.  Reference 1, p. 20.

 35.  Mannsville  Chemical  Products.   Chemical  Product  Synopsis-Vinyl
     Chloride Monomer.  Cortland, New York.   January  1983.

 36.  Reference 1, p. 24.

 37.  Mannsville  Chemical  Products, Chemical  Product Synopsis--Ethyl
     Chloride.   Cortland, New York.   August  1981.

 38.  Reference 1, p. 30.

 39.  Reference 1, p. 41.

 40.  Memorandum  from Powers, S. ,  MRI, to Project  File 7710-L.   August 1983.
     Calculations concerning EDC  consumption  for  different products.

 41.  Reference 19, p. 8-28.

 42.  Reference 19, pp. 8-2 and  8-3.

 43.  Reference 19, p. 8-16.

 44.  Letter from Su, J.,  Formosa  Plastics  Corporation Texas, to Seek,  D.,
     EPAiESED.  September 11, 1984.   Transmittal  of process  emission
     data.

 45.  U.  S.  Environmental  Protection  Agency.   Fugitive Emission Sources of
     Organic Compounds—Additional Information  on  Emissions, Emission
     Reductions, and Costs.   Research Triangle  Park,  North  Carolina.
     Publication No. EPA-450/3-82-010.  April 1982.   p.  1-4.

 46.  Telecon.   Powers, S.  , MRI, with  Robson,  J.,  EPA:EA8.   July 24, 1984.
     Market price EDC, mid-1982 dollars.

 47.  Reference 20, pp.- A-4 - A-24.

48.  Reference 25, p. 5-4.

49.  Reference 25, p. 5-3.
                                  2-70

-------
50.   Reference 25, p.  5-6.

51.   Gros, S. , (MSA Research Corporation).  Demonstration of Vapor
     Control Technology for Gasoline Loading of Barges.  Prepared for
     U.  S. Environmental Protection Agency.  Research Triangle  Park,
     North Carolina.   Contract No. 68-02-3657.  p. 30.
                                  2-71

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                   3.   PUBLICLY OWNED TREATMENT WORKS

3.1  ETHYLENE DICHLORIDE SOURCES AND EMISSIONS
     In recent work sponsored by the EPA,  POTW's were identified as
sources of EDC emissions.1  The premise of this work was that volatili-
zation of EDC-bearing industrial discharges at the POTW, rather than
secondary formation during wastewater treatment, is the most likely
source of EDC emissions.2  This work utilized existing data files to
identify 1,600 POTW's (out of approximately 20,000 total nationwide) that
treat industrial  discharges.3,4  Data available from these files (e.g.,
percent of inflow to POTW attributable to industrial dischargers, types
of industries discharging to POTW, and type of treatment at POTW), along
with a set of pollutant-specific emission factors for POTW's (available
from mass-balance information for 50 POTW's), were used to estimate
emissions of each of nine pollutants including EDC, from the 1,600 POTW's.
The presence of these nine pollutants in the waste streams was presumed
based on the Standard Industrial Classification Codes of the dischargers
rather than on available sampling data from actual discharge streams.
Three hundred fifty-five POTW's were projected to emit EDC.1
     Table 3-1 presents a list of 95 counties containing POTW's having an
estimated EDC emission level of at least 10 Mg/yr (11 tons/yr).1  (Two
hundred sixty additional counties were presented in Reference 1, each
having EDC emissions less than 10 Mg/yr [11 tons/yr].)  Total EDC
emissions for all 355 POTW's are estimated to be approximately 7,300 Mg/yr
(8,050 tons/yr).
     Within a POTW, EDC in wastewater is volatilized to the atmosphere
from the aeration basins or from the clarifiers.  Any operation that
generates aerosols (e.g., spray irrigation, trickling filters) or provides
                                  3-1

-------
 agitation  of the  wastev/ater  (e.g.,  screens,  grit  chambers)  could  also
 enhance  the  release  of EDC to  the atmosphere.1  No  control  measures
 specifically for  VOC's or air  toxics  have  been  implemented.1
      Recently,  ambient air monitoring was  performed in  Philadelphia,
 Pennsylvania,  to  determine the validity  of the  emission estimates.5   Ten
 monitoring stations  were sited around Philadelphia,  including  the POTW,
 and  samples  were  collected every third day for  3  months.  The  data from
 this sampling  effort are being used to validate the ambient dispersion
 models used  to  relate pollutant emissions  with  influent wastewater
 concentrations.   The air monitoring included analyses for EDC.  The
 preliminary  results  of this  testing approach indicate that  the data
 developed  using the  approach cited  in References  3  and  4 may overstate
.EDC  emissions  by  a factor of eight  to ten.   A critical  assessment of  both
 sets of  data (mass-balance and ambient monitoring)  to determine which
 approach to  estimating EDC emissions  from  POTW1s  is  most accurate or
 whether  the  difference in the  two approaches is likely  to occur at other
 POTW1s has not  been  made yet.   Additional  ambient monitoring may  be
 performed  in Baltimore, Maryland, to  increase the amount of data  available
 for  validating  the models.5
      Since the  primary emission point for  EDC is  the aeration  basin,  the
 most likely  control  strategy is pretreatment of the  EDC-laden  wastewater.
 Towards  that end, effluent limitations guidelines for best  practicable
 technology (BPT), best conventional technology  (BCT), and best available
 technology (BAT), new source performance standards  (NSPS),  and pretreat-
             •
 ment standards  for the Organic Chemicals and Plastics and Synthetic
 Fibers Source  Category will  be promulgated in approximately 6  months.2
 These regulations will  limit the discharge of effluents into receiving
 waters and into POTW's from  facilities that produce  organic chemicals,
 plastics,  and  synthetic fibers.  Ethylene  dichloride is one of the
 pollutants covered and will  be regulated by the BAT, NSPS,  pretreatment
 standards  for  existing sources of indirect discharges (PSES),  and pre-
 treatment  standards  for new  sources of indirect discharges  (PSNS).5
 (Indirect  discharges are those to a POTW rather than directly  to  a
 receiving  stream.)   The selected technology for BAT, PSES,  and PSNS  is a
 combination  of  process controls, in-plant  physical/chemical treatment,
                                   3-2

-------
and end-of-pipe treatment (those processes that treat a combined plant
stream prior to discharge).   No individual or specific BAT is specified;
because of the diversity of pollutants in the source category, BAT will
be plant specific.6  Existing technologies include biological treatment
(preceeded by the necessary controls necessary to protect the biota),
polishing ponds and filters, water reduction and reuse techniques,
process changes, and product or solvent recovery (including distillation
and steam stripping).
     The effluent limitations for EDC are a 150 micrograms per liter
(ug/£) maximum for any one day and a 100 ug/£ average of daily values for
four consecutive monitoring days.5  These limitation values are the same
for BAT, NSPS, PSES, and PSNS sources.  No estimate can be made of the
impact of these effluent limitations on EDC air emissions from POTW's (or
from the regulated sources).  It is believed that the limitations will
effectively remove EDC from the waste streams, and, thus, air emissions
of EDC from POTW1s should drop significantly.2  The fate of the EDC
removed from the waste stream at the plant is not addressed in the
effluent limitations.
                                  3-3

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TABLE 3-1.  ESTIMATED EDC EMISSIONS FROM PUBLICLY OWNED TREATMENT WORKS
                             (By County)1
County
Ramsey, Minn.
Philadelphia, Pa.
Cook, 111.
Middlesex, N.J.
Montgomery, Ohio
Dade, Fla.
Douglas, Nebr.
Union, N.J.
Harris, Tex.
St. Louis City, Mo.
Dane, Wis.
Sedgwick, Kans.
Tarrant, Tex.
Fulton, Ga.
Niagra, N.J.
San Francisco, Calif.
Orleans, La.
Broward, Fla.
Aiken, S.C.
Fairfield, Conn.
Lucas, Ohio
Baltimore City, Md.
Dallas, Tex.
Fort Bend, Tex.
Kittitas, Wash.
Lorain, Ohio
McLennan, Tex.
Tromboll , Ohio
Floyd, Ind.
Caddo, La.
Erie, N.Y.
Richmond, Ga.
Alameda, Calif.
Guilford, N.C.
Lenoir, N.C.
EDC
Mg/yr
782
760
729
498
230
224
194
148
148
138
133
126
123
121
92
85
80
76
76
72
69
68
60
60
57
54
53
52
47
46
43
41
38
38
38
emissions3
Tons/yr
862
837
804
549
254
247
213
163
163
153
147
139
135
134
101
93
88
84
84
80
77
75
66
66
63
60
59
57
52
50
47
45
42
41
41
                                                        (continued)
                                 3-4

-------
TABLE 3-1.   (continued)
County
Hamilton, Tenn.
Montgomery, N. Y.
Hampden, Mass.
Kalamazoo, Mich.
Essex, N.J.
Tulare, Calif.
Smith, Tex.
St. Clair, 111.
Whitfield, Ga.
Madison, Tenn.
Johnson, Kans.
Miami , Ohio
Morgan, Ala.
Brown, Minn.
Twin Falls, Idaho
Story, Iowa
Alamance, N.C.
Worcester, Mass.
Hillsborough, N.H.
Cattaraucus, N.Y.
Santa Cruz, Calif.
Hamilton, Ohio
Monmouth, N.J.
Call away, Mo.
Forsyth, N.C.
Durham, N.C.
Hudson, N.J.
Buncombe, N.C.
New Haven, Conn.
Burke, N.C.
Stanislaus, Calif.
Knox, Ind.
Cleveland, N.C.
Winnebago, Wis.
Kennebec, Maine
EDC
Mg/yr
36
32
32
29
29
27
27
27
26
26
26
25
23
23
23
23
23
22
20
20
20
20
20
19
19
18
17
17
16
15
15
15
15
15
14
emissions
Tons/yr
39
36
35
32
32
30
30
29
29
29
28
27
25
25
25
25
25
24
23
22
22
22
22
21
21
20
19
18
18
17
17
16
16
16
16
                                 (continued)
         3-5

-------
                    TABLE 3-1.  (continued)
County
Washington, Miss.
Angelina, Tex.
Jefferson, Tex.
Venango, Pa.
Ottawa, Mich.
Dodge, Wis.
Talladega, Ala.
Canyon, Idaho
Iredell, N.C.
Madison, Ala.
Hampshire, Mass.
Jackson, Ala.
Houston, Ala.
Washtenaw, Mich.
Morris, N.J.
Wayne, W. Va.
Lynchburg, Va.
Spartanburg, S.C.
Portsmouth, Va.
Oconee, S.C.
Cumberland, Pa.
York, S.C.
Columbiana, Ohio
Washington, Ark.
Boulder, Colo.
Total EDC emissions, top 95 counties
remaining 260 counties
EDC
Mg/yr
14
14
14
13
13
13
13
12
12
12
12
12
11
11
11
11
11
11
11
10
10
10
10
10
10
-6,660
-630
emissions3
Tons/yr
15
15
15
15
15
15
14
14
13
13
13
13
13
12
12
12
12
12
12
11
11
11
11
11
11
-7,350
-690
Estimated air emissions may be overstated by a factor of eight.
See References 2 and 5.
                              3-6

-------
3.2  REFERENCES

1.   Memo and attachments from Lahre, T., EPA:AMTB, to Southerland, J. H.,
    EPA:AMTB.  December 5, 1983.  Initial look at available emissions
    data on POTW's.

2.   Telecon.  Atkinson, D., MRI, with Haemisegger, E., EPA:OPA.
    August 28, 1984.   Update on Versar POTW work.

3.   Memo and attachment from Haemisegger, E., EPA:OPA, to Atkinson,  R. D.,
    MRI.  August 31,  1984.  Description of POTW emission estimation
    algorithm.

4.   Memo and attachments from Alexander, D., AMS, Inc., D. Sullivan  and
    J.  Alchowiak, Versar, Inc., to Haemisegger, E., and T. Gorman,
    EPArOPA.  February 7, 1984.  Algorithm for estimating volatilization
    of air toxics from POTW's.

5.   Telecon.  Maxwell, W., MRI with Haemisegger, E., EPArOPA.  September  14,
    1984.   Additional information on EPA tests at Philadelphia.

6.   U.  S.  Environmental Protection Agency.  Proposed Effluent Guidelines
    Pretreatment Standards for Organic Chemicals, Plastics, and Synthetic
    Fibers Industry.   40 CFR Parts 414 and 416.  Washington, D.C.  Office
    of the Federal Register.   March 21, 1983.   Volume 48.  pp. 11828+.
                                  3-7

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                 4.   PHARMACEUTICAL MANUFACTURING PLANTS

4.1  ETHYLENE DICHLORIDE SOURCES AND EMISSIONS
     Ethylene dichloride is one of many solvents used in the manufacture
of synthetic Pharmaceuticals.   Pharmaceuticals are typically made in a
series of batch operations, many of which involve the use of solvents.
These operations include reactors, distillation systems, filters,
extractors, centrifuges, crystal!izers, dryers, and various holding
tanks.  Solvent emissions can occur in any of these process steps, and
can also occur from solvent storage, transfer, and recovery systems.
Solvents may be used as a reaction medium, to dissolve an intermediate
product prior to a process step, to wash an intermediate or final product,
or as a drier after a water-based production step.1  No information was
obtained on specific locations, applications, or emission points for EDC
use in the pharmaceutical industry.  The magnitude of gathering such
information was beyond the scope of this study.
     In May 1984, the Pharmaceutical Manufacturer's Association (PMA)
solicited information from member companies on their use of four solvents,
including EDC.2  The EDC purchase, emission, and disposal statistics
provided by the member companies are presented in Table 4-1.  Responding
companies account for about half of the 1982 domestic sales of
prescription Pharmaceuticals.   However, the PMA indicated that some
manufacturers may not have responded to the survey because they do not
use any of the four solvents.   Thus, the numbers may not accurately
represent the actual ratio of EDC use to pharmaceutical sales and the
doubling of the estimates in the responses (as is done in Table 4-1) may
result in overestimation of true EDC purchase and losses for the entire
industry.
                                  4-1

-------
     From the table, it appears that as much as 800 Mg/yr (880 tons/yr)
of EDC may be emitted directly from process operations or vessels with
some possible indirect atmospheric losses from EDC disposal in sewers
discharging to POTW's.   (Some of these losses are no doubt included in
the emission estimates for POTW's in Chapter 3.)
     The summary of member company information that was provided to EPA
did not include company- or plant-specific details on EDC emissions, only
aggregate data.   Similarly, no information was available as to the
control practices (other than incineration) being used in the
pharmaceutical manufacturing industry.   Control techniques that could be
investigated to control  these emission sources include condensation,
carbon adsorption, liquid scrubbing,  incineration, vapor balance systems,
pressurized tanks, internal floating roof tanks, and inspection and
maintenance programs.   The control  techniques are similar to those in
chemical  plants discussed in Chapter 2, although the batch nature of
pharmaceutical manufacturing often produces intermittent and variable
emissions that can be expensive to control per unit of EDC removed.   To
estimate the costs of controls and emission reductions achievable, a
specific study on this  industry-will  be necessary.
                                  4-2

-------
 TABLE  4-1.   SUMMARY OF  ESTIMATED  EDC  USE AND  EMISSIONS  IN  THE
             PHARMACEUTICAL  MANUFACTURING INDUSTRY2

Annual EDC purchased
Direct EDC air emissions
EDC discharged to sewer
EDC incinerated
Actual data
from member
companies,
Mg/yr
1,400
400
250
775
Industry-
wide
totals,
Mg/yr
2,800
800
500
1,550

 representing  approximately  one-half  of  the  1982  domestic  sales
 of prescription  Pharmaceuticals.   Values  shown may be  over-
 stated  because those  companies  not responding to the  survey  may
 not use EDC.
^ote that  amount purchased  does not  represent amount  used but
 amount  purchased to replace losses.   Amount used not  reported
 by Reference  2.
                               4-3

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4.2  REFERENCES

1.  U.  S. Environmental Protection Agency.  Control of Volatile Organic
    Emissions from Manufacture of Synthesized Pharmaceutical Products.
    Research Triangle Park, North Carolina.  Publication No. EPA-450/
    2-78-029.  December 1978.

2.  Letter and enclosure from White, T. X., Pharmaceutical Manufacturers
    Association, to Beck, D.  A., EPA:ESED.  June 8, 1984.  Information on
    solvent use by pharmaceutical plants.
                                  4-4

-------
                 5.   LEAD SCAVENGER BLENDING FACILITIES

5.1  ETHYLENE DICHLORIDE USE AND EMISSIONS
     Ethylene dichlon'de is blended with chemicals, such as ethylene
dibromide (1,2-dibromoethane, EDB), to form lead scavenger additives for
use in leaded gasoline.1,2  Typical concentrations for EDC in leaded
gasoline are 150 to 300 ppm.3  The addition of these compounds prevents
the fouling of the engfne combustion chamber with lead oxides.  Ethylene
dichloride and EDB react with lead during combustion to form lead chloride
(PbCl2) and lead bromide (PbBr2) which remain in the gas phase and are
expelled with the exhaust gases.
     About 0.3 percent (20,000 Mg [22,500 tons]) of the EDC produced in
1983 was used as a lead scavenger.  Table 5-1 lists the four plants that
produce lead scavenger additives.
     Because the use of leaded gasoline has been decreasing since the
introduction of catalytic control devices on automobiles in the early
1970's, and is expected to continue to decline as noncatalyst vehicles
are retired from the fleet, emissions of EDC from the production and use
of lead scavenger additives are also expected to decline.   Also, a recent
EPA proposal to reduce the lead content in gasoline by 91 percent by 1986
would hasten the decline of EDC emissions from this source.4  The EPA is
also considering a total ban of leaded gasoline by 1995.4
     Potential sources of emissions during manufacture of the additive
are similar to those at a chemical plant, i.e., process, fugitive,
secondary, and storage.  Process sources differ the most because the
lead scavenger production process involves blending-of several compounds
rather than a chemical synthesis.  Thus, in lead scavenger production,
EDC does not undergo a chemical change to other compounds.   The blending
                                  5-1

-------
 process is therefore typically conducted under atmospheric conditions,
 compared to the elevated pressures  and temperatures  often used in
 chemical  synthesis.
      Tables 5-2 through  5-9  list  these EDC  and VOC emission sources  for
 specific plants,  and give their respective  control practices,  emission
 rates,  and estimates of  the  costs of  additional  controls.   The same
 additional  controls  and  the  criteria  for determining their applicability
 for  each  source type were used here as were discussed in  Chapter  2.
 These additional  controls were incinerators on process  vent emissions;  a
 combination of  equipment control  devices  and inspection and maintenance
 programs  for fugitive emissions;  and  floating roof tanks  for storage
 emissions.   The emission reduction potential  and costs  of  applying a
 refrigerated vent condenser  on one process  vent were  calculated.
 Incineration was  not applicable in this  instance because  some  emissions
 occur during nonoperating hours,  when  personnel would not  be available  to
 operate  the incinerator.   Vent condensers,  by contrast, could  operate
 safely without  continuous  monitoring.
      Approximately 76  Mg/yr  (84 tons/yr)  of EDC are  emitted  from  three  of
 the  four  plants  listed in  Table 5-1.   Emissions from  the fourth plant,
 Ethyl Corporation in  Baton Rouge, Louisiana,  were discussed  in Chapter  2
 because this  facility  produces  EDC on  site.    No other lead  additive
 manufacturers reported manufacturing their  own EDC.    Approximately
 195  Mg/yr  (215  tons/yr)  of VOC are emitted  from these three plants.
      Table  5-10  summarizes the potential  EDC  emission reduction data from
 each  plant  by source.  Process vents are  the  largest  source of EDC
 emissions,  responsible for approximately  55 percent of  current emissions;
 followed by  storage, 28  percent;  fugitive,  14 percent;  and secondary,
 3 percent.  These companies reported no shipping of EDC; consequently,
 there are no shipping emissions.
     By applying the above control techniques, EDC emissions from lead
additive production could be reduced by approximately 69 Mg/yr
 (76 tons/yr), a 91 percent reduction.   However, most of this emission
 reduction potential  would be achieved at a cost effectiveness that is
relatively high compared to that achievable by chemical plants (discussed
in Chapter 2).  The cost effectiveness of further controlling process
vent emissions ranges from $9,600  to $427,600/Mg ($8,700 to $387,800/ton),
                                  5-2

-------
with an overall cost effectiveness of $17,300/Mg ($15,700/ton).   The cost
effectiveness of fugitive emission controls ranges from $660 to $44,100/Mg
($600 to $40,000/ton), and averages approximately $900/Mg ($820/ton).
Storage emissions can be controlled by floating roof tanks with primary
seals only for $5,800 to $10,800/Mg ($5,300 to $9,800/ton), and an
average of $9,20Q/Mg ($8,300/ton).  Sample cost calculations are given in
Appendix A.
     Sources of EDC emissions from transportation and use of leaded
gasoline include blending operations at refineries, bulk gasoline marketing
and transportation, service stations, gasoline combustion, and evaporation
from the vehicles.  In a separate study, EPA estimated EDC emissions from
gasoline marketing sources (i.e., bulk terminals, bulk plants, and service
stations) to be about 245 Mg/yr (270 tons/yr) in 1982.5  Th,is emission
•level will decline over the years as a result of lead phase-down.  An
analysis of the effects of various control scenarios on EDC emissions
from gasoline marketing is presented in the EPA document referenced
above.  Emissions were not estimated within the scope of this study  for
gasoline combustion and evaporation from vehicles, although emission
levels are expected to be very low.
                                  5-3

-------
        TABLE 5-1.  PRODUCERS OF LEAD SCAVENGER ADDITIVE
Company
Location
E. I. duPont


Ethyl Corporation

Nalco Chemicals
Antioch, California
Deepwater, New Jersey

Baton Rouge, Louisiana

Freeport, Tex.
                              5-4

-------
                                    TABLE  5-2.    EMISSION  AND  CONTROL  COST  DATA FOR PROCESS  EMISSIONS
                                                                         1984 Dollars
cn
cn
Cost effectiveness1"


Plant/location.
Process source
E. I. duPont
Antioch, Calif.
(a) Blender during operation
(b) Blender when not operating




E. I. duPont
Deep Water, N.J.
(a) MFAC blending

Nalco Chemical
Freeport, Tex.
(a) Common flare stack
Current
control
techno-
logy8


d
g






i



k

Current control
efficiency, %
EDC VOC


98e 98e
0 0






19 32



98 98

Current EDC/
VOC emissions.
Mg/yr


0.10/0.2
0.80/2.12






41/60



0.02/1.02

Addi-
tional
controls


N/Af
Refrig-
erated
vent
condenr
h
ser


Incin- .
erator^


N/A
EDC/VOC
emission
reduction,
Mg/yr


N/A.
0.76/1.25"





i
40/58. 6J



N/A

Capital Net annual
cost, cost,
» *


N/A. N/A.
858,000" 201,400"





i i
1,211,000J 382,000J



N/A N/A
EDC
emission
reduc-
tion, »/Hg


N/A
265,000"





i
9,600J



N/A
VOC
emission
reduc-
tion, $/Hg


N/A
161,000





i
6,400J



N/A
        ^Calculated  using CE Plant Cost  Index (Chemical  Engineering, June 11,  1984).
         Cited from  information request.
         .Annual ized  cost per unit of emission reduced.
         Incinerator.
        ^Actual emission efficiency reported as >98 percent; however, insufficient  data were available to verify  this efficiency.
         N/A = Not applicable.   No additional controls costed  if efficiency already 298 percent.
        ?No control  device used when blender is not operating.  See text for additional explanation.
         The emission  reduction potential  and costs of  installing a 95 percent efficient refrigerated vent condenser when the blender is  not operating were calculated.
         The condenser system costed was a shell-and-tube  type with a storage tank,  a pump and the necessary piping and instruments.   The refrigeration unit included the
         compressor, condenser expansion valve, evaporator, controls, foundations and all auxiliary components.   Sample cost calculations appear in Appendix A.
        .Methodology from Reference 6.
        .Vapor return  within vessels for motor fuel antiknock  compound (MFAC) blending.
        •'The emission  reduction potential  and costs of  installing a 98 percent efficient incinerator were calculated.  Sample costs calculations appears in Appendix A.
        .Methodology from Reference 7
         Knock-out pot, flare gas absorber.

-------
Ol
I
CT>
                   TABLE 5-3.    EDC  EMISSIONS AND  COST  DATA  FOR  RETROFITTING FIXED  ROOF  STORAGE TANKS  WITH
                                                     INTERNAL FLOATING  ROOFS  (Primary Seals)
                                                                 March 1984  Dollars3
Plant/Location
E. I. duPont
Antloch, Calif.
£. I. duPont
Deep Water, N.J.



Halco Chemical
Freeport. lex.





Tank
typeB'c
F

F
HP
F
F
F
F (PV)
F (PV)
F (PV)
r (PV)
f (PV)
F (PV)
F (PV)
Percent
EOC
stored
100

11-25
99
11-25
11-25
11-25
19
19
19
19
100
10
19
No. of
storage
tanks
1

8
1
5
2
3
3
1
2
1
1
1
5
Current
control
tech-.
t b
niques
1

ID
n
m
m
m
P
P
P
P
P
P
P
Current
control
effi-b
ciency
0

50-80
100
50-80
50-80
50-80
96
96
96
96
96
96
96
Current
EDC
emissions
Mg/yra
1. 1

0.95
0
0.95
0.85
1.9
0.03
0.03
0.03
0.01
0.06
0.01
0.01
lota)
capital ,
cost. $e>t
23,000

3/.900
M/A°
33,300
33,100
52,500
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Annua 1 -
ized
cosl.a $
6,100

10,000
N/A
8.8UO
8,700
13,800
H/A
N/A
N/A
N/A
N/A
N/A
N/A
EOC EDC
emission recovery
Mg/yr . credits
reduction" $a>1
1.0

0.90
N/A
0.90
0.80
1.80
N/A
N/A
N/A
N/A
N/A
N/A
N/A
340

290
N/A
280
260
570
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Net
annual -
ized.
costs,J $
5.800

9,700
N/A
6,400
8,400
13,200
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Cost
effect-
iveness
»/Mg*
5. BOO

10,800
N/A
9,300
10.500
7,300
N/A
N/A
N/A
N/A
N/A
N/A
N/A
      .Calculated using CE  Plant Cost Index and M&S Equipment Cost Index  (Chemical  Engineering June  11, 1984).
      cCited from information request responses.
       Tank types.
          F = Fixed roof.
        CIF = Contact internal floating  roof.
          S = Spherical tank.
          II = Horizontal tank.
         IIP = Horizontal pressure tank.
       .  PV = Pressure vessel.
      £Current storage tank emissions (per tank basis) based upon Information request  responses.
      _Refer to Table 2-13.
      'Additional cost for  the use of a  Teflon" coated primary seal ~$230/m (m = meter of diameter), Reference No  8
      ^Reference No. 9.
      .Internal floating roof (primary seal only), 94 percent emission reduction efficiency.
      .EDC value ~$326/Mg (First Quarter 1984 dollars), Reference No.  10.
      jjAnnualized cost minus EOC recovery credits.
      •Net annualized cost  per unit of emissions reduced.

      mNone-
      floating liquid barrier.
      QVapor transfer when  unloading tank cars and conservation vent
       N/A = Not applicable.  No additional controls cos led If efficiency alieady 494 percent.
      ^Nitrogen pad system  maintained at 1.5 psig.   Ihe system is put  through a flare gas absorber lower,  followed by a flare knock-out drum before being routed  to a
       flare.

-------
in
i
                    TABLE 5-4.   VOC  EMISSIONS AND  COST  DATA  FOR  RETROFITTING  FIXED  ROOF  STORAGE  TANKS WITH
                                                     INTERNAL FLOATING  ROOFS  (Primary  Seals)
                                                                 March 1984  Dollars3
Current
No. of control
Tank. storage tech- ^
type ' tanks niques
E. I. duPont
Antioch, Calif.
E. 1. duPont
Deep Water, N.J.



Nalco Chemical
Freeport, Tex.





F

F
HP
F
F
F
F (PV)
F (PV)
F (PV)
F (PV)
F (PV)
F (PV)
F (PV)
^Calculated using CE Plant Cost Index and
Cited from information
cTank types.
F = Fixed roof.
CIF = Contact internal
S = Spherical tank.
H = Horizontal tank.
request responses.


floating roof.


1

8
1
5
2
3
3
1
2
1
1
1
5
M&S






m

n
o
n
n
n
p
P
p
p
P
p
P
Equipment Cost






Current
control
effir
b
ciency
0

50-80
100
50-80
50-80
50-80
96
96
96
96
96
96
96
Index (Chemical






Current
VOC
emissions,
Mg/yr8
1.1

3.8
0
3.7
3.4
7.6
0.16
0.16
0.16
0.05
0.06
0.10
0.05
Engineering






VOC
Total Annual- emission
capital . ized
cost, $e'r cost,9 $
23,000

37,900
N/A
33,300
33,100
52,500
N/Aq
N/A
N/A
N/A
N/A
N/A
N/A
June 11, 1984)






6,100

10,000
N/A
8,800
8,700
13,800
N/A
N/A
N/A
N/A
N/A
N/A
N/A







Mg/yr .
reduction
1

3.5
N/A
3.5
3.1
7
N/A
N/A
N/A
N/A
N/A
N/A
N/A







VOC
recovery
credits,
$T,J.
330

1.150
N/A
1.150
1,000
2,300
N/A
N/A
N/A
N/A
N/A
N/A
N/A







Net
annual-
ized
costs, $
5,800

8,850
N/A
7,700
7,700
11,500
N/A
N/A
N/A
N/A
N/A
N/A
N/A







Cost
effect-
iveness
$/Mg'
5,800

2,500
N/A
2,200
2,500
1,650
N/A
N/A
N/A
N/A
N/A
N/A
N/A







HP = Horizontal pressure tank.
. PV = Pressure vessel.











         Current storage  tank emissions (per tank basis) based upon information request responses.
        *Refer to Table 2-13.
         Additional cost  for the use of a Teflon  coated-primary seal  ~$230/m (m = meter of diameter),  Reference No. 8.
        ?Reference No. 9.
        .Internal floating roof (primary seal only),  94 percent emission  reduction efficiency.
        '.EDC  value ~$326/Mg (First Quarter 1984 dollars). Reference No. 10.
        j| Assumed VOC value equal to EDC value.
        .Annualized cost  minus EDC recovery credits.
         Net  annualized cost per unit of emissions reduced.
         None.
        "Floating liquid  barrier.
         Vapor transfer when unloading tank cars and  conservation vents.
        pNitrogen pad system maintained at 1.5 psig.  Hie system is put through a flare gas absorber tower, followed by a flare knock-out drum before being routed to a
         flare.
        qN/A  = Not applicable.  No additional controls costed if existing efficiency £94 percent.

-------
en
 i
do
                     TABLE 5-5.    EDC  EMISSIONS  AND  COST  DATA FOR  RETROFITTING FIXED  ROOF  STORAGE TANKS  WITH
                                             INTERNAL  FLOATING  ROOFS  (Primary arid  Secondary Seals)
                                                                   March  1984  Dollars'1
Plant/Location
E. 1. duPont
Antioch, Calif.
E. I. duPont
Deep Water. N.J.



Nalco Chemical
Freeport, Tex.





Tank
F

F
HP
F
F
F
F (PV)
F (PV)
F (PV)
F (PV)
F (PV)
F (PV)
F (PV)
Percent
EOC
stored
100

11-25
99
11-25
11-25
11-25
19
19
19
19
100
10
19
No. of
storage
tanks
1

8
1
5
2
3
3
1
2
1
1
1
5
Current
control
niques
m

n
o
n
n
n
q

q
q
q
q
q
Current
control
effi-.
, b
ciency
0

50-80
100
50-80
50-80
50-00
96
96
96
96
96
96
96
Current
EOC
emissions
Mo/yr
11

0.95
0
0.95
0.85
1.9
0.03
0.03
0.03
0.01
0.06
0.01
0.01
Total
capital.
cost, $g'f-9
27,000

44,900
N/AP
39.300
39.100
62,500
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Annual-
ized.
cost.h $
7,100

11,800
N/A
10,300
10,300
16,400
N/A
N/A
H/A
N/A
N/A
N/A
N/A
EOC
emission
Mg/yr .
reduction
1.1

0.92
N/A
0.9?
0.82
1.8
N/A
N/A
N/A
N/A
N/A
N/A
N/A
EDC
recovery
credjts
360

300
N/A
300
270
600
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Net
annual -
ized .
costs,"
6,700

11.500
N/A
10,000
10.000
15.800
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Cost
effect-
iveness
$ $/Hg'
6.100

12.500
N/A
10,100
12.200
8.800
N/A
N/A
N/A
N/A
N/A
N/A
N/A
         .Calculated using CE  Plant Cost Index and MAS Equipment Cost Index  (Chemical Engineering June  II, 1984).
          Cited from information request responses.
          Tank types.
             F = Fixed roof.
           CIF = Contact internal floating  roof.
             S = Spherical tank.
             II = Horizontal tank.
            IIP = Horizontal pressure tank.   '
          .  PV = Pressure vessel.
          Current storage tank emissions (per tank basis) based upon information request  responses.
         *Refer to Table 2-13.
          Additional cost Tor  the use of a  Teflon  coated primary seal ~$?30/m (« = meter of diameter), Reference  No. B.
         IJCost for a Viton  coated secondary seal ~656/m (m = meters of diameter) 1st Quarter 1984 dollars. Reference No.  11.
         "Reference No. 9.
          •Internal floating roof (primary and secondary seal), 97 percent emission reduction efficiency.
         jJfOC value ~$326/Mg (First Quarter 1984 dollars), Reference No.  10.
         IAnnual)zed cost minus EDC recovery credits.
          Net annualized cost  per unit of emissions reduced.
         nNone'
         floating liquid barrier.
          Vapor transfer when  unloading tank cars and conservation vent.
         PN/A = Not applicable.
          Nitrogen pad system  maintained at 1.5 psig.  Hie system is put through a flare  gas absorber lower,
          flare.
followed by a Mare knock-out drum before being routed to a

-------
en
i
10
                   TABLE  5-6.   VOC  EMISSIONS  AND COST DATA FOR  RETROFITTING FIXED  ROOF  STORAGE TANKS  WITH
                                           INTERNAL  FLOATING ROOFS  (Primary and  Secondary Seals)
                                                                 March  1984  Dollars

E. I. dufont
Antioch, Calif.
E. I. duPont
Deep Water, N.J.



Nalco Chemical
Freeport, Tex.





Tank.
typeb'c
F

F
HP
F
F
F
F (PV)
F (PV)
F (PV)
F (PV)
F (PV)
F (PV)
F (PV)
No. of
storage
tanks"
1

8
1
5
2
3
3
1
2
1
1
1
5
Current
control
tech-
niques
n

0
p
0
0
0
r
r
r
r
r
r
r
Current
control
effi-
ciency
0

50-80
100
50-80
50-80
50-80
96
96
96
96
96
96
96
Current
VOC
emissions
Mg/yra
1.1

3.8
0
3.7
3.4
7.6
0.16
0.16
0.16
0.05
0.06
0.10
0.05
Total
' eSS!1*1-'*
27,000

44,900
N/Aq
39,300
39,100
62,500
N/Ar
N/A
N/A
N/A
N/A
N/A
N/A
VOC
Annual- emission
ized Mg/yr .
cost, $ reduction
7,100

11,800
N/A
10,300
10,300
16,400
N/A
N/A
N/A
N/A
N/A
N/A
N/A
1.1

3.7
N/A
3.6
3.3
7.4
N/A
N/A
N/A
N/A
N/A
N/A
N/A
VOC
recovery
credits,
$J.K
360

1,200
N/A
1,200
1,100
2,400
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Net
annual-
ized
costs,' $
6,700

10,600
N/A
9,100
9,200
14,000
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Cost
effect-
iveness
$/Mg"
6,100

2,900
N/A
2,500
2,800
1,900
N/A
N/A
N/A
N/A
N/A
N/A
N/A
        fCalculated using CE Plant Cost Index  and M&S Equipment Cost  Index (Chemical Engineering June 11,  1984).
         Cited from information request responses.
        GTank types.
            F = Fixed roof.
          C1F = Contact internal floating roof.
            S = Spherical tank.
            H = Horizontal tank.
           HP = Horizontal pressure tank.
           PV = Pressure vessel.
         Current storage tank emissions (per tank basis)  based upon information request responses.
        !Refer to Table 2-13.                 fi
         Additional cost for the use of a Teflon  coated  primary seal ~$230/m (m = meter of diameter), Reference No.  8.
        ?Cost for a Viton  coated secondary seal ~656/m (m = meters of diameter) 1st Quarter 1984 dollars, Reference No.  11.
        "Reference No.  9.
        .Internal floating roof (primary and secondary seal), 97 percent emission reduction efficiency.
        ^Assumed VOC value equal to EDC value.
        *EOC value ~$326/Mg (First Quarter 1984 dollars), Reference No. 10.
         Annual)zed cost minus EDC recovery credits.
         Net annualized cost per unit of emissions  reduced.
        Vne.
        "Floating liquid barrier.
        ^Vapor transfer when unloading tank cars and conservation vent.
        qN/A = Not applicable.
         Nitrogen pad system maintained at 1.5 psig  The system is put through a flare gas absorber tower, followed by a flare knock-out drum before being routed to a
         flare.

-------
en
i
               TABLE 5-7.   COSTS FOR IMPLEMENTATION  OF  CONTROL  TECHNIQUES  FOR  EDC  FUGITIVE EMISSION SOURCES
                                                       First Quarter 1984 Dollars3

Plant/Location
E. I. duPont
Deep Water, N.J.
E. I. duPont
Antioch, Calif.
Nalco Chemical
Freeport, Tex.

Current
control
tech- b
niquesD'c
h
N/A
N/A
Current
control
effi-
ciency
%D
60
N/A
N/A

Current
IDC
emissions,
Mg/yr
1.5
0.024
9
Additional
EOC
emission
reduction,
Kg/yr
0.9
0.016
8

Total
capital .
cost, $a
3,400
1,300
18,200

Annual ized
cost. $°
2,300
710
7,900

EOC
recovery
credit.
$a,e
300
5
2,600

Net
annual -
izedf
cost'
2,000
705
5,300

Cost
effective-
ness,
$/Mg EDC9
2,200
44.100
660
^Calculated using CE  Plant Cost Index and M&S Equipment Cost  Index (Chemical engineering June 11, 1984).
clnformation sited from  information request responses.
^Current control techniques were not listed if the technique  or technology was judged to have 0 percent control efficiency.
 Based  upon proposed  emission control techniques and control  efficiencies listed in Table 2-8.
f£DC valve ~$326/Mg First Quarter 1984 dollars, Reference  No. 10.
 Annualized cost minus recovery credit.
jjNet annual ized cost  per unit of emissions reduced.
 Pressure relief devices protected by rupture disc (100 percent efficiency)

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      TABLE 5-8.    COSTS FOR IMPLEMENTATION  OF  CONTROL  TECHNIQUES  FOR  VOC  FUGITIVE EMISSION  SOURCES
                                               First Quarter 1984  Dollars3



Plant/Location
E. I. duPont
Deep Water, N.J.
E. I. duPont
Antioch, Calif.
Nalco Chemical
Freeport, Tex.

Current
control
tech- fa
niques '
i

N/A

N/A

Current
control
effi-
ciengy
60

N/A

N/A


Current
VOC
emissions,
Mg/yrd
6

2

40

Additional
VOC
emission
reduction,
Mg/yrfl
4

2

37



Total
capital .
cost, $d
3,400

1,300

18,200


VOC
recovery
Annual! zed cEeiiH>
cost, $° $a>e>1
2,300 1,300

710 650

7,900 12,100


Net
annual -
ized
cost9
1,000

60

-4,200


Cost
effective-
ness, .
$/Mg VOCn
250

30

-110

^Calculated using CE Plant Cost Index and M&S Equipment Cos,t Index (Chemical Engineering June 11, 1984).
 Information sited from  information  request responses.
.Current control techniques were not listed if the technique or  technology was judged to have 0  percent control  efficiency.
 Based  upon proposed emission control techniques and control efficiencies listed  in Table 2-8.
?EOC valve ~$326/Mg First Quarter 1984 dollars, Reference No.  10.
 Assumed VOC value = EDC value.
rJAnnualized cost minus recovery credit.
.Net annualized cost per unit of emissions reduced.
 Pressure relief valves protected by rupture discs (100 percent  efficiency).

-------
                                     TABLE 5-9.   SECONDARY EDC EMISSION SOURCES
en
i
fv>
Plant/
Plant location/
Emission source
E. I. duPont
Antioch, Calif.
E. I. duPont
Deep Water N.J.
Nalco Chemical
Freeport, Tex.
Current
emissions,
Mg/yr
0.007
2.4
0.05
Existing
control
technology
a
c
c
Applicable
additional
control
technology
None
None
None
Capital
and annual
cost for
additional
control , $
__b
--
__
Cost
effectiveness
additional
control
--
—
—
      bAirstripping,  settling,  neutralization.

      c~-  =  No  additional  controls costed.

       Wastewater to  discharge  or to primary  and secondary treatment is pretreated by steam stripping to
       remove EDC.  EDC is removed and recycled.

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                                    TABLE 5-10.   EDC EMISSION SUMMARY
Plant/location
E. I. duPont, Antioch, Calif.
Current emissions, Mg/yr
Reduction potential, Mg/yr
E. I. duPont, Deep Water, N.J.
Current emissions, Mg/yr
Reduction potential, Mg/yr
Nalco Chemical, Freeport, Tex.
Current emissions, Mg/yr
Reduction potential, Mg/yr
Totals
Current emissions, Mg/yr
Reduction potential, Mg/yr
Process

0.9
0.76

41
40

0-02r
N/AC

42.0
40.8
Storage

1.1
1.0

19.75
18.7

0.27.
N/Ad

21.1
19.7
Fugitive

1.5
0.9

0.024
0.016

9
8

10.5
8.9
Secondary

0.007.
N/Ab

2.4.
N/Ab

0.05.
N/Ab

2.5.
N/Ab
Shipping

N/Aa
N/Aa

N/Aa
N/Aa

N/Aa
N/Aa

N/Aa
N/A3
Total

3.5
2.7

63.2
58.7

9.3
8

76.0
69.4
^Company reported no shipping of EDC.
 Insufficient data reported to determine feasibility of applying steam stripping, as discussed in
 Chapter 2.
dNo additional process controls costed if existing controls £98 percent.
 No additional storage controls costed if existing controls ^94 percent.

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5.2  REFERENCES FOR CHAPTER 5

 1.  Stanford Research Institute.  Chemical Economics Handbook.
     pp.  300.5203M and 651.5031C.

 2.  U.  S.  Environmental Protection Agency.  Locating and Estimating Air
     Emissions from Sources of Ethylene Dichloride.  Research Triangle
     Park,  North Carolina.   Publication No. EPA-450/4-84-OQ7d.  March 1984.
     p.  72.

 3.  McDermott, H. J., and S. E.  Killiany, "Quest for a Gasoline TLV,"
     American Industrial Hygiene Association Journal (AIHA).  February 1978.

 4.  Environment Reporter,  Bureau of National Affairs.   Lead in Gasoline.
     Vol.  15, No.  14,  August 3, 1984.   p.  532.

 5.  U.  S.  Environmental Protection Agency.  Evaluation of Air Pollution
     Regulatory Strategies  for Gasoline Marketing Industry.   Washington,
     D.C.   Publication No.  EPA-45Q/3-84-Q12a.  July 1984.

 6.  U.  S.  Environmental Protection Agency.  Organic Chemical Manufacturing
     Volume 5:  Adsorption, Condensation,  and Absorption Devices.
     Research Triangle Park, North Carolina.  Publication No. EPA-450/
     3-80-027.  December 1980.  pp. V-l -  V-23.

 7.  U.  S.  Environmental Protection Agency.  Air Oxidation Processes in
     Synthetic Organic Chemical Manufacturing Industry—Background
     Information for Proposed Standards.   Draft EIS.  Research Triangle
     Park,  North Carolina.   Publication No. EPA-450/3-82-001a.  October 1983.
     pp.  8-2, 8-3, 8-16, and 8-28.

 8.  Telecon.  Powers, S.,  MRI, with B. Bergstrom, Chicago Bridge and
     Iron.   July 26, 1984.   Additional cost in using a Teflon  coated
     primary seal  versus a polyurethane coated seal.

 9.  Control of Volatile Organic Compound  Emissions from Volatile Organic
     Liquid Storage in Floating and Fixed-Roof Tanks.  U.  S. Environmental
     Protection Agency.   Research Triangle Park, North Carolina.  Publication
     No.  EPA 450/3-84-005.   June 1984.  pp. 5 and 6.
                                                                            \
10.  Telecon.  Powers, S. ,  MRI, with J. Robson,  EPA-.EAB.  July 24, 1984.
     Market price EDC, mid-1982 dollars.

11.  Telecon.  Powers, S.,  MRI, with M. -Mason,  Chicago Bridge and Iron.
     July 27, 1284.  Cost for the installation of a secondary seal coated
     with Viton .
                                  5-14

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               6.  MISCELLANEOUS USES AND EMISSION SOURCES

6.1  ETHYLENE DICHLORIDE SOURCES AND EMISSIONS
     Minor uses of EDC are in textile cleaning and processing, in
coatings, in formulations of acrylic-type adhesives, as a product inter-
mediate for polysulfide elastomers, as a constituent of polysulfide
rubber cements, in the manufacture of grain fumigants, and as a cleaning
and extraction solvent.1  These minor uses accounted for only 0.1 percent
of the EDC produced in 1983.   Of the estimated consumption of EDC by
minor uses, about 28 percent is used in the manufacture of paints,
coatings, and adhesives.   Extracting oil from seeds, treating animal
fats, and processing pharmaceutical products (discussed in Chapter 4)
account for 23 percent.  An additional 19 percent is consumed in cleaning
textile products and PVC manufacturing equipment.  Nearly 11 percent is
used in the preparation of polysiJlfide compounds.  Grain fumigation
requires about 10 percent.   The remaining 9 percent is used as a carrier
for amines in leaching copper ores, in the manufacture of color film, as
a diluent for pesticides and herbicides, and for other miscellaneous
purposes.2  Some of these uses are discussed below.
     Estimates of EDC emissions from the miscellaneous uses are provided
where possible.   No information was obtained on specific emission points
for EDC.   The magnitude of gathering such information was beyond the
scope of this study.   To estimate the cost of controls and emission
reductions achievable, specific study of these industries will be
necessary.
6.1.1  Paints,  Coatings,  and Adhesives
     A study performed by the EPA's Office of Air Quality Planning and
Standards estimated that about 1,400 Mg of EDC per year (1,540 tons/yr)
                                  6-1

-------
are used in the manufacture of paints, coatings, and adhesives.3  Although
specific uses of EDC in paints and coatings are not known, EDC is thought
to be used as a solvent in paints and coatings which use vinyl polymers,
particularly PVC.   Ethylene dichloride use in adhesives is restricted to
adhesives using acrylics.4
     Because EDC.is used as a solvent in paints, coatings, and adhesives,
it is estimated that all of the EDC used in these products is eventually
emitted to the atmosphere.4  Data are not available on the relative
amounts of EDC emitted during formulation and use of these products.
6.1.2  Extraction Solvent
     Ethylene dichloride is used in a number of solvent extraction
applications.  Major applications include the extraction of oil from
seeds,- the processing of animal fats, and the processing of pharmaceutical
products.  Another EPA study estimated that EDC use as an extraction
solvent accounts for about 1,100 Mg/yr (1,200 tons/yr).5
     The solvent used in extraction processes is generally recovered by
low pressure distillation.   Some solvent is lost to the atmosphere from
valves, pumps, and compressors; in spills; and during transfer operations.
It is estimated in published literature that about 95 percent of the EDC
consumed in solvent extraction processes is emitted to the atmosphere,
while about 5 percent is discharged with solid wastes.  These solid
wastes are generally incinerated.5  Therefore, about 1,050 Mg/yr
(1,150 tons/yr) of EDC are emitted to the air from extraction processes.
6.1.3  Cleaning Solvent
     Solvents containing EDC are used in cleaning equipment in the PVC
and textile manufacturing industries.  It is estimated that this use
accounts for about 910 Mg/yr (1,000 tons/yr).6  Data are not available on
the equipment cleaned, the specific nature of the cleaning operations, or
the compositions of the solvents used.
     Although no 'emissions data are available for solvent cleaning uses
of EDC, it is estimated in the literature that about 95 percent (or
860 Mg/yr [950 tons/yr]) of the EDC consumed is ultimately emitted to the
atmosphere, while the remaining 5 percent is discharged with solid
wastes.6  These solid wastes are generally incinerated.
                                  6-2

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6.1.4  Polysulfide Rubber Production
     Polysulfide rubber is a synthetic rubber polymer which is used in
the manufacture of caulking putties, cements, sealants,  and rocket-fuel.
It is produced by the reaction between aliphatic ha!ides,  such as EDC,
and alkali polysulfides such as Na2S4.  The main products  of the reaction
are the polysulfide rubber chain, (CH2CH2-S4)n, and sodium chloride.7
     Based on yields for similar industrial chemical  reactions, the
second EPA study estimated that 94 percent of the EDC used during the
manufacturing of polysulfide rubber becomes incorporated in the end
product.7  It is estimated that 5 percent of the EDC used  in the process
is released to the atmosphere via leaks, spills, and fugitive emissions
associated with the overall polysulfide manufacturing process.  The
remaining I percent of EDC remains dissolved in the mother liquor from
which the polymer is produced.  The mother liquor may be discharged as
solid waste and stored in landfills.7
     From the stoichiometry of the polysulfide production  reaction and
the percentages of EDC consumed and emitted, the average controlled EDC
emission factor for polysulfide rubber manufacture is 33.8 kg of EDC per
Mg of polysulfide rubber produced (67.6 lb/ton).7  Only one company was
reported to be manufacturing polysulfide rubber in 1983, and no production
figures were reported by the EPA study, so no EDC emission estimate can
be made.7
6.1.5  Grain Fumigant
     Ethylene dichloride is used as a component of fumigant mixtures that
are applied to control insect infestations in grains during storage,
transfer, milling, distribution, and processing.  Ethylene dichloride
comprises 7.1 percent of the total weight of fumigant active ingredients
applied to stored grain.  Annual usage of EDC in grain fumigants ranged
from 870 to 1,570 Mg/yr (960 to 1,730 tons/yr) during the period from
1976 to 1979.8
     Due to its flammability, EDC is used in fumigant mixtures with
carbon tetrachloride, which decreases the fire and/or explosion hazard of
the mixture.  A product containing three parts EDC to one part carbon
tetrachloride (3:1) has been used widely.  Other grain fumigant formula-
tions have EDC:carbon tetrachloride ratios ranging from 2.4:1 to 1:7.
                                  6-3

-------
Other constituents may be present in these formulations, including EDB
and carbon disulfide.8
     Liquid grain fumigants are used on approximately 12 percent of the
grain grown in the United States.9  Fumigants are used during binning
(placement in storage) and turning (shifting from one storage facility to
another) operations or at any time during storage when infestation
occurs.   Fumigants have a period of effectiveness of only a few days.
Thus, they kill existing insect populations but do not prevent later
reinfestation.  Newly harvested grain typically is fumigated 6 weeks
after binning.  Corn grown in the southern regions of the U.S. usually is
fumigated immediately following binning because of field infestation of
weevils.10
     Emissions of EDC from fumigant mixtures occur during fumigant
application and when fumigated grain is exposed to the atmosphere, for
instance, during turning or loading.   The rate of emissions of EDC from
fumigant use depends on a number of factors including the type of grain,
the type and concentration of fumigant applied, the type of storage
(whether loose or tight-fitting), the manner in which the grain is
handled, and the rate of release of fumigant residues in and on the
grain.11  Although high sorption efficiencies (84 percent) have been
reported for certain cereals, it is generally concluded that by the time
the grain is processed, essentially all of the retained EDC will have
been dissipated to the atmosphere.12  Thus, up to 1,500 Mg/yr
(1,650 tons/yr) of EDC may be emitted to the atmosphere from grain
fumigation.
6.1.6  Liquid Pesticide Formulations
     Ethylene dichloride is used in a number of liquid pesticide
formulations.   These formulations generally are mixtures of EDC and other
active ingredients such as carbon tetrachloride and carbon disulfide.8
     Pesticide formulation systems are typically batch mixing operations.
Technical grade pesticide is usually stored in its original shipping
container in the warehouse section of the plant until it is needed.  If
the material is received in bulk, it is transferred to holding tanks for
storage.  Solvents are normally stored in bulk tanks.
                                  6-4

-------
       Batch mixing tanks are typically closed vessels.   The components of
  the formulation are fed into the tank, measured by weight, and mixed by
  circulation with a tank pump."  The formulated material is then pumped
  to a holding tank before being put into containers for shipment.
       The blend tank is vented to the atmosphere through a vent dryer,
  which prevents moisture from entering the tank.13  Storage and holding
  tanks and container-filling lines may be provided with an exhaust
  connection or hood to  remove any vapors.   The  exhaust  from the system may
  be vented to a control  device or directly to the atmosphere.14
       Sources of EDO emissions from pesticide formulation include  storage
  vessels,  mixing vessel  vents,  and leaks  from pumps,  valves, and flanges.
  Insufficient information  is  available  for the  development of  EDC  emission
  factors  for  liquid  pesticide  formulation  facilities.   No  national emission
  estimates  for  EDC  from  liquid  pesticide  formulation  are  available.
  6-1.7  Miscellaneous EDC Uses
      Ethylene dichloride is used  in the manufacture  of color  film, as a
  diluent in pesticides and herbicides, and as an amine carrier  in the
  leaching of copper ores.  The total amount of EDC used in these applica-
 tions is 460 Mg/yr (500 tons/yr).1*  Very little information is available
 in published sources regarding the details of these processes.
      It is estimated in published literature that all of the EDC used in
 the manufacture of pesticides, herbicides, and  color film is emitted to
 the atmosphere,  while nearly all  of the EDC used in copper leaching  is
 either consumed in the  leaching process or emitted with wastewater. "
 5-1-8  Volatilization From Waste  Treatment,  Storage,  and Disposal
        Facilities
      Considerable potential  exists for  volatile substances,  including
 EDC,  to be  emitted  from  hazardous  waste treatment,  storage,  and handling
 facilities.   A  study  in  California shows  that significant  quantities  of
 EDC may be  contained  in  hazardous  wastes,  which may be  expected to
 volatilize within hours, days,  or  months after disposal by landspreading,
 surface impoundment, or  covered landfill,  respectively.^  Volatilization
 of EDC and other substances was confirmed  in this study by significant
ambient air concentrations of EDC over one site.  Reference 17  provides
general theoretical models for estimating volatile substance emissions
                                  6-5

-------
from a number of generic kinds of waste handling operations,  including

surface impoundments, landfills, landfarming  (land treatment)  operations,

wastewater treatment systems, and drum storage/handling processes.   If

such a facility is known to handle EDC, the potential should  be  considered
for some air emissions to occur.

6.2  REFERENCES

 1.  U. S. Environmental Protection Agency.   Locating and Estimating Air
     Emissions from Sources of Ethylene Dichloride.  Research  Triangle
     Park, North Carolina.   Publication No. EPA-450/4-84-007d.   March 1984.
     p. 9.

 2.  Drury, J.  S.  and A. S. Mammons.   Investigation of Selected  Environ-
     mental Pollutants:   1,2-Oicnloroethane.  U. S. Environmental
     Protection Agency.   Washington, D.C.  Publication No.  EPA-560/2-78-006.
     April 1979.

 3.  Reference 1,  p.  76.

 4.  Bryson, H.,  K. Durrell, E. Harrison, V.  Hodge, L. Phuoc,  S.  Paige,
     and K. Slimak.  Materials Balance:  1,2-Dichloroethane.   U-.  S.
     Environmental Protection Agency.  Washington, D.C.  Publication
     No.  EPA-560/13-80-002.  February 1980.   pp. 3-43 to 3-44.

 5.  Reference 4,  pp. 3-44 to 3^45.

 6.  Reference 4,  p.  3-46.

 7.  Reference 4,  pp. 3-47 to 3-48.

 8.  Holtorf, R.  C. ,  and G. F.  Ludvik.  Grain Fumigants:  An Overview of
     Their Significance to U.S. Agriculture and Commerce and Their
     Pesticide Regulatory Implications.  U. S. Environmental  Protection
     Agency.  Washington, D.C.   September 1981.

 9.  Reference 1,  p.  61.

10.  Ludvik, G.  F.  Fumigants for Bulk Grain  Protection:  Biological
     Aspects and Relevant Data.  U.  S. Environmental Protection  Agency.
     Washington,  D.C.  August 1981.

11.  Reference 1,  p.  67.

12.  Reference 4,  p.  3-49.
                                          •
13.  Letter from Cox, G. V., Chemical Manufacturing Association,  to
     Lahre, T.,  EPA:OAQPS.   August 18, 1983.
                                  6-6

-------
14.   U.  S.  Environmental Protection Agency.  Development Document for
     Effluent Limitations Guidelines for the Pesticide Chemicals Manu-
     facturing Point Source Category.  Washington, D.C.  Publication
     No.  EPA-440/l-78/060e.  April 1978.

15.   Reference 4, p. 3-51.

16.   Scheible, M. ,  et al.  An Assessment of the Volatile and Toxic
     Organic Emissions from Hazardous Waste Disposal in California.
     Sacramento, California.  February 1982.

17.   GCA Corporation.  Evaluation and Selection of Models for Estimating
     Air Emissions  from Hazardous Waste Treatment, Storage and Disposal
     Facilities.  Revised Draft Final Report.  Prepared for the U. S.
     Environmental  Protection Agency under Contract No. 68-02-3168, Work
     Assignment No.  77.  Bedford, Massachusetts.  May 1983.
                                  6-7

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               APPENDIX A
SAMPLE CALCULATIONS FOR CONTROL COSTS AND
           COST EFFECTIVENESS

-------
 SECTION  A-l:   SAMPLE  CALCULATIONS  FOR  FUGITIVE  COSTS


     To  calculate the cost  for the  implementation of  technologies  to

 control  fugitive emissions, the  specific control techniques,  removal

 efficiencies and capital/annualized costs per component  are given  in

 Table A-l.  By  incorporating the data  in Table  A-l, a table similar to

 Table A-2 can  then be constructed  for  each  individual facility by  using

 the following  equations.  (All tables  appear at the end  of the text.)

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

 Total capital  cost per plant:  I [capital cost  per emission-source]

 Annual cost per emission source:   (No. of components) x  (annual cost per
  component)

 Total annual cost per plant:  I  [annual cost per emission source]

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

 Total EDC emission reduction per plant:  I  [EDC emission  reduction per
  emission source]

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

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

 EDC recovery credits  per emission source:    (EDC emission  reduction per
  emission source) x  (1st Quarter 1984 EDC market value  ($326/Mg))

 Total EDC recovery credit per plant:   (Total EDC emission reduction per
  plant) x (1st Quarter 1984 EDC market value ($326/Mg))

VOC recovery credit per emission source:   (VOC emission  reduction per
  plant) x (1st Quarter 1984 EDC market value ($326/Mg)).

VOC recovery credit per plant:   (VOC emission reduction per plant) x
  (1st Quarter 1984 EDC market value ($326/Mg)).

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

Net annual  cost (EDC) per plant:   (total  annual  cost per plant) minus (total
  EDC recovery credits per plant).
                                   A-l

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

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

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

Cost effectiveness for controlling EDC emissions per plant:  (net annual
  cost (EDC) per plant) per (EDC emission reduction per plant).

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

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


                      COST CONVERSION CALCULATIONS

CE Plant Cost Index (Chemical Engineering June 11, 1984)

Updating May 1979 dollars to March 1984 dollars.

CE Plant Cost Index.

     Fabricated equipment = March 1984 = $332.9
                            Mid 1979   = $238.7

          132^9
          238.7

     Conversion of EDC cost from mid-1982 dollars to 1st Quarter 1984
dollars:

     M&S Equipment Cost Index (Chemical Engineering June 11, 1984)

     Chemical products 1st Quarter 1984 = 783.6
     Annual index mid-1982 = 745.6

     Conversion factor for converting mid-1982 dollars to 1st Quarter
1984 dollars:

     783.6 _
     74
     EDC value/Mg = ($310)(1.05) = 326/Mg
     1st Quarter 1984
                                   A-2

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SECTION A-2:  SAMPLE COST CALCULATIONS FOR INSTALLING INTERNAL FLOATING
                ROOFS IN FIXED ROOF TANKS


     The following equations are used to calculate the capital and annualized

cost for the installation of a mild steel welded contact internal floating

roof to a fixed roof storage tank.1  This internal floating roof utilizes
                                   ®
both primary (constructed of Teflon ) and secondary (constructed of

Viton ) seals.   An example calculation is also attached demonstrating

these equations.

A.   Capital Cost (4th Quarter 1982 Dollars)

     1.  Degassing Cost2

     Cost = $130.8 V0'5132 or $1,000, whichever is greater where V = tank
volume in cubic meters.

     2.  Estimated Installation Cost3

          a.  Basic cost of roof and primary seal:

               Cost = (1.91 + 2.54 x D) x $1,000 + ($204 x D)

               D = tank diameter in meters

                                                                    ®
     (The $204 x D cost reflects the additional cost of using Teflon
coated fiberglass versus the standard polyurethane coating.)4

          b.  Additional cost of adding secondary seal:5

               Cost = $580 x D

     (The $580 x D cost reflects using a Viton  coated material for the
secondary seal.)

     3.  Door Sheet Opening Cost6

          Cost = $1,300

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

     Total capital cost (primary + secondary seals) = degassing costs
+ estimated installed cost (2a,b) + door sheet opening cost.
                                   A-3

-------
B.  Annual Cost7  (4th Quarter 1982 Dollars)
     1.   Tax, insurance, and administration—4% of capital cost  (based
          on 10 percent interest rate and 10 year equipment life)
     2.   Maintenance—5% of capital cost
     3.   Inspection—1% of capital cost
     4.   Capital recovery factor—16.275% of capital cost
     Total annual cost = [26.275% of capital cost]
C.  EDC Emission Reduction
     1.  Internal floating roof primary seal8
     (0.94)(current EDC emissions (Mg))
     2.  Internal floating roof primary + secondary seals9
     (0.97)(current EDC emissions (Mg))
D.  EDC Recovery Credits (1st Quarter 1984 Dollars)
     Credits = ($326)(EDC emissions reduced)
E.  Net Annual  Cost
     (Before annual  cost can be calculated,  all  costing data is converted
to 1984 dollars using Chemical  Engineering Economic Indicators.)
     Cost = annual  cost (1st quarter 1984 dollars) - EDC recovery credits
               (1st Quarter 1984 dollars)
F.  Cost Effectiveness
     = net annual  cost/EDC emission reduction (Mg)
G.  Cost Conversion Calculations
     Convert equipment cost from 4th Quarter 1982 dollars to 1st Quarter
1984 dollars
     CE Plant Cost  Index10
     Fabricated equipment 1st Quarter 1984 = 332.9
     Annual  index 1983 (mid) =  316.9
                 1982 (mid) =  314.0
                                 2.9
                                   A-4

-------
     Average increase per quarter = 2.9/4 = 0.725

     4th Quarter 1982 = 314 + (2)(0.725) = 315.45

     Conversion factor for converting 4th Quarter 1982 dollars to 1st
Quarter 1984 dollars =
          315.45

     Conversion of EDC cost from mid- 1982 dollars to 1st Quarter 1984
dollars:

          M&S Equipment Cost Index10

          Chemical products 1st Quarter 1984 = 783.6
          Annual index mid- 1982 = 745.6

     Conversion factor for converting mid- 1982 dollars to 1st Quarter
1984 dollars:

          783.6  _   Q5
          745.6    1-U;3

     EDC value/Mg11 = ($310)(1.05) = $326/Mg
     1st Quarter 1984

H.  Example Storage Tank Calculations

     Data12

     D = 31.7 m
     V = 9,620 m3
     Current emissions = 29.42 Mg/yr

     Capital Cost (4th Quarter 1982 Dollars)

     1.  Degassing cost

          Cost = $130.8 (9,6200-5132) = $14,480

     2.  Estimated installation cost

          a.  Primary seal only

               Cost = (1.91 + 2.54 x 31.7) x $1,000 + ($204 x 31.7) = $88,895

          b.  Primary + Secondary seal additional cost

               Cost = $580 x 31.7 = $18,386
                                   A-5

-------
     3.  Door sheet opening cost
          Cost = $1,300
     Total capital cost (primary seal)
          Cost = $14,480 + 88,895 + 1,300 = $104,675
     Total capital cost (primary + secondary seal)
          Cost = $14,480 + 88,895 + 18,386 + 1,300 = $123,061
     Annual cost (primary seal only)
          Cost = 0.26275($104,675) = $27,503
     Annual cost (primary + secondary seals)
          Cost = 0.26275($123,061) = $32,334
     Conversion of capital and annual cost data to 1st Quarter 1984 dollars
Capital cost (primary seal only) = ($104,675)(1.0553) = $110,464
Capital cost (primary + secondary sea'ls) = ($123,061)(1.0553) = $129,866
Annual  cost (primary seal only) = ($27,503)(1.0553) = $29,024
Annual  cost (primary + secondary seals) = ($32,334)(1.0553) = $34,122
     EDC Emissions Reduced
     1.  (Primary seal only) = (0.94)(29.42 Mg/yr) = 27.65 Mg/yr
     2.  (Primary + secondary seals ) = (0.97)(29.42 Mg/yr) = 28.54 Mg/yr
     EDC Recovery Credits (1st Quarter 1984 Dollars)
     I.  (Primary seal only) credits = ($350)(27.65) = $9,678
     2.  (Primary + secondary seals) credits = ($350)(28.53) = $9,986
     Net Annual  Cost (1st Quarter 1984 Dollars)
     1.  (Primary seal only) = $29,024 - 9,678 = $19,346
     2.  (Primary + secondary seals) = $34,122 - 9,986 = $24,136
     Cost Effectiveness
     I,  (Primary seal only) = $19,346 ••• 27.65 = $700/Mg
     2.  (Primary + secondary seal) = $24,136 -r 28.54 = $846/Mg
                                   A-6

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SECTION A-3:   SAMPLE COST CALCULATIONS FOR CONDENSER SYSTEMS (Storage
              tanks and process vents)
     This section presents assumptions and sample calculations for
determining the filling rate, capital and annualized costs, recovery
credits, and emissions reduction for condenser control systems controlling
emissions from EDC storage tanks.   The condenser system has an efficiency
of 95 percent.
     Estimates of EDC emissions and the size specifications for storage
tanks were reported by each company in its response to EPA's information
request.  The following correlations were determined from the information
request concerning tank size versus filling rate and gas flow rate to
condenser.
           Tank                  Filling              Gas flow rate
        volume (m3)            rate (gpm)          to condenser (acfm)
          1-5                      100                    13.37
          6-100                    200                    26.74
          >100                   2,000                   267.40
     The gas flow rates presented above are used to determine the capital
and annualized costs for each condenser system.  Capital cost estimates
represent the total installed capital costs for the condenser system and
its refrigeration unit.  The methodology for determining capital and
annualized costs is presented in Organic Chemical Manufacturing Volume 5:
Adsorption, Condensation, and Absorption Devices.13  These costs are
presented in graph form in Figures A-3.1 and A-3.2.
     To determine the percentage VOC in the emission stream the following
methodology was used.
     Average storage tank temperature = 77°F
     At 77°F (EDC) partial pressure   = 1.63 psia
     Atmospheric pressure             = 1 atm = 14.69 psia
                                        1 63
     % VOC in-emission stream         = ppfg = 11%
Therefore, to determine capital and annual cost each gas stream is
assumed to contain 10 percent VOC.
                                   A-7

-------
     The following equations are used to approximate the capital and
annual cost for annual filling rates of less than 100 acfm.
     Capital cost = 277.5 [filling rate (acfm)] + 3.15 xlO4
     Annual cost  = 70 [filling rate (acfm)] + 2.30 xlO4
The equations for capital and annualized costs for EDC storage tanks with
filling rates of less than 100 acfm were obtained by calculating equations
of the 10 percent VOC lines on Figures A-3.1 and A-3.2.  The annual
average filling rate is calculated by the following.
     Annual average filling rate = (filling rate per tank)(A/B)

     A = (fin-ing rate per tan^tank volume)(N) = minutes of tank filling
     N = number of times the tank is filled per year
       _ .-annual throughput..
             tank volume   '
     B = minutes per year of tank operation
       = 525,600 minutes/yr (based on 24 h/d and 365 d/yr of operation)
     For a tank volume of 128.44 m3 (4,536.5 ft3) and a throughput of
11,250 m3 (397,350 ft3), the annual average filling rate is calculated
below.
Average   (                 1              ^.397,350 ft3
annual     uo/.t acTmn267i4 acfnrK^,w/ Tt A 4)537 fta )
filling = 	=0.76 acfm/yr
rate                        525,600 min/yr
                                   A-8

-------
  700

-------
  300
  250
o
in
O
   150
o
O
1 100
c
   50
                                                                                              20%VOC
                                                                                              10%VOC

                                                                                              5% VOC
                                              2%VOC
                                              1 % VOC
                                              0.5%VOC
                                        J_
J_
_L
J_
J_
1
             200      400      600     80O     \OOO     A200     140O
                                          Gas Flow to Condenser (scfm)
                         160O
                              1800
                             2000
                                  22OO
                         2400
                  Figure A-3.2.  Annual cost vs flow rate for complete condenser system
                   with VOC removal efficiency of 95 percent and no VOC recovery credit.15

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SECTION A-4:   SAMPLE CALCULATIONS FOR SHIPPING COSTS

Data

Barges/yr                = 8116

Filling time             = 2.5-3 h16

Emissions                = 188 Mg/yr17

Control efficiency       = 98% (See Cost Efficiency Calculations)

EDC value/Mg             = 310 $/Mg18 mid-1982 dollars

EDC value/Mg             = 326 $/Mg, 1st Quarter 1984, dollars
                           (See Cost Conversion Calculations)

Control Efficiency Calculation

Standard temperature of tank  = 77°F

Partial pressure              = 84.30 mm Hg

Refrigerated temperature      = -99.4°F
     Partial  press ~1 mm Hg

     Atmospheric pressure 760 mm Hg
          1 - [(1/760)7(84.3/760)] = 1 - 0.02 = 98%

Control efficiency            = 98%

Cost Conversion Calculations

Convert equipment cost (1979 dollars to 1984 dollars):

CE plant cost index19
  Fabricated equipment 1st Quarter 1984      = 332.9
  Annual index:   1980 (mid)                  = 261.2
                 1979 (mid)                  = 238.7
                                                22.5

Average increase per quarter = 22.5/4 = 5.625

4th Quarter 1979 ='238.7 + (2)(5.625) = 249.95

Conversion factor for converting 4th Quarter 1979 dollars to
  1st Quarter 1984 dollars =
      332 9
      OJC-J = i
     249.95   •
                                  A-11

-------
For the conversion of EDC cost from mid-1982 to 1st Quarter 1984 dollars,
  use the following procedure:

M&S Equipment Cost Index19

  Chemical products 1st Quarter 1984  = 783.6
  Annual index mid-1982'               = 745.6

  Conversion factor for converting mid-1982 dollars to 1st Quarter
1984 dollars =

     (783.6, _ T ft,
      74576J ~ *•'"*

EDC Value/Mg = ($310)(1.05) = $326 1st Quarter 1984 dollars.

     The following data is an example of the calculations necessary to
analyze the installation cost of a refrigeration unit to control
shipping emissions.  The fixed capital cost is for an average
refrigeration unit of a size that could handle consecutive barge loading
indefinitely with 1 to 2 hours lapse time between each loading.20  This
fixed capital cost is used for all shipping emissions costing.

            REFERIGERATION UNIT (1979 4th Quarter Dollars)21

Fixed capital

   Skid mounted unit           -                          $264,600
   Concrete pad                                             2,700
   Electric feeder                                          5,000
   Freight                                                  3,000
   Rigging, crane, and men at $175 for 8 h                  1,400
   Vapor piping to unit                                    10,000
   Parts inventory                                 .        6,QQO
                                                         $292,700

Capital recovery cost (CRC)

                                   in + i^n
     CRC = (fixed capital costs) x -^	J-
                                   (1 + i)n -1

     where i = annual interest rate
           n = capital recovery period

CRC for 10 percent annual interest rate and 15 years equipment  life = 0.131

     CRC = (0.131)x(292,700) = 38,340
                                  A-12

-------
Electricity

     140 kWh x 3.0 h (load)                                 =      420
     442 kWh x $0.06/kWh x 81 barges/yr                     =   $2,148

Maintenance and operating labor

     Based on $15/h and 1,000 h                             =  $15,000

General and administrative

     15 percent of other yearly operating costs
     (0.15)(55,900)                                         =   $8,400
     Annual cost = $55,900 + $8,400                         =  $64,300/yr


              REFRIGERATION UNIT (1984 1st Quarter Dollars)
                 (Refer to Cost Conversion Calculations)

Fixed capital  = $292,700 (1.332)                           = $389,900
Annual cost    = ($64,300X1.332)                           =  $85,650
Mg EDC reduced = (EDC emissions)(control efficiency)
               = (188) (0.98)                                = 184 Mg .

EDC recovery credits = (Mg EDC reduced)(EDC value/Mg)
                     = (184)($326)                          =  $60,000

Net annual cost = [annual cost]- [EDC recovery credit]
                = $85,650 - $60,000                         =  $25,650

Cost effectiveness = N
                      Mg EDC reduced
                   _ $25,650 _
                       184
                                  A-13

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SECTION A-5:  SAMPLE COST CALCULATIONS FOR CONTROL OF  PROCESS  EMISSIONS
              COSTS
     This  section presents data and calculations necessary for determining
the capital costs, annual costs, and cost effectiveness.of thermal
incineration systems used to control EDC process emissions.  The total
installed  capital cost is a function of the process offgas flowrate  and
is calculated from the following equation.22
     Total Installed Capital Cost ($1,000) = (No. of units)
                                                        o
           x (Escalation Factor) x (Cj + C2 [Flowrate (NM /min)
           T Design Vent Size Factor]Cs
The gas flowrate is 10,667 acfm (302.1 mVmin) and is  reported by the
company to contain no moisture at 28°C (82°F).  Therefore, the gas
flowrate equals 10,583 dscfm (294.1 Nm3/min) when corrected to standard
conditions.  The selection of the incinerator design category  was based
on.offgas  net heating value, the design flowrate, and  the presence or
absence of halogenated compounds.   Categories Al and A2 were selected
because EDC is a halogenated compound and all factors  used in  the above
equation are based on process vent streams containing  halogenated compounds.
For these  sample calculations, the total  installed capital costs are
based on a gas flowrate of 10,383 dscfm (294.1 mVmin) and equal $2,985,000.
     Tables A-3, A-4, A-5, and A-6 show cost factors,  operating factors,
and cost equations for calculating annualized costs for the thermal
incineration system.   The process is assumed to operate 24 h/day and
350 days/yr (8,400 h/yr), and the control  device operating labor is
2,400 h/yr.  The calculations and rates for operating  labor, electricity,
natural gas, heat recovery credit,  quench water, scrubbing water, and
caustic are presented below.   The maintenance labor plus materials factor
is 0.06 of total installed capital  cost and the overall taxes and main-
tenance factor is 0.11 of total installed capital cost.22
Annualized Costs (based on 2,400 h/yr of operation)
     Direct
     •  Operating Labor ($13.08/h):
       ($13.08/h)(2,400 h/yr) = $31,000/yr
                                  A-14

-------
       Electricity  ($0.02616/kwh):
       (0.0604)($0.02616/kwh)(22  in.  w.c.)(294.1  NmVmin)(2.9)
       =  $30,000/yr

       Natural  Gas  ($4.78/thousand  MJ):
       Natural  gas  used:
       0.504 million  min/yr  x  G$  +  flowrate  x  (Gl +  G2  x  heating  value
       +  G3  x heating value2)

       (0.504)(0) + (294.1)  [4.86  +  (-0.985)(3.5) + (0)(3.5)2]
       =  415.42 TJ/yr

       Natural  gas  cost ($4.78/GJ):
       ($4.78/GJ)(415.42 TJ/yr) $1,986,000

       Heat  Recovery  Credit  ($4.78/GJ):
       ($4.78/GJ)(3.63 MJ/Nm3)(294.1  NmVmin)(0.504  million min/yr)
       =  $2,572,000/yr

       Quench Water ($0.22/thousand gallons)
       ($0.22/thousand gallons)(294.1 Nm3/min) (0.00886)(2.9) = $2,000/yr

       Scrubbing Water ($0.22/thousand gallons-)
       ($0.22/thousand gallons)(294.1 Nm3/min)(0.289)(2.9)  = $54,000/yr

       Caustic ($0.0436/lb):
       ($0.0436/lb)(294.1 Nm3/min)(17.17)(2. 9) =  $638,000/yr

       Maintenance  Labor plus  Materials Factor (0.06 of total  installed
       capital  cost):
       (0.06)($2,995,000) =  $179,000/yr

       Overall  Taxes  and Maintenance  Factor  (0.11 of total  installed
       capital  cost):
       (0.11)($2,985,000) =  $328,000/yr
Indirect
     Interest rate (i)        =8.5% (after taxes)
                              = 10% (before taxes)
     Incinerator Lifetime (N) = 10 years

     Capital  Recovery Factor  =  i(1 + i)    = 0.152 (after taxes)

                                 (1 + i)N-l = 0.163 (before taxes)

     Taxes,  Insurance, and Administrative  Charges Factor = 0.05 of total
     installed capital cost.

     Overall  Capital  Charges Factor = 0.213 of total  installed capital
     cost.
                                  A-15

-------
Operating cost = Taxes and Maintenance Cost per unit + (No. of units)
                 (gas cost +• labor cost + electricity cost + quench water
                 cost + scrubber water cost + caustic cost - heat recovery
                 credit)

          OC   = $328,000 + (1)(1,986,000 + 31,000 + 30,000 + 2,000
                 + 54,000 + 638,000 - 2,572,000) = $497,000

Annualized costs = OC + (Capital Recovery Factor)(Capital Costs)
                 = $497,000 + (0.163)($2,985,000)
                 = $984,000 (before taxes)

The annualized costs of $984,000 are calculated in December 1979 dollars

and are updated to March 1984 dollars using the Chemical Engineering

Plant Cost Index for Fabricated Equipment.  The fabricated equipment cost

factor is used to simplify the updating of the capital and annualized
costs.

Annualized costs (March 1984) = $984,000 (Dec. 1979)  r332.9-
                                                      L2lOJ

                              = $1,497,000

Annual emissions w/existing emission control

                              =-3,977 kg/yr

Annual emissions reduction w/incinerator

                              = (3,977 kg/yr)(0.98)
                              = 3,897 kg/yr (3.9 Mg/yr)

Cost effectiveness = $1,497,000 -r 3.0 Mg/yr
                   = $383,846/Mg (before taxes)
                                  A-16

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       TABLE A-l.  CONTROL TECHNIQUES AND COST FOR VOC/EDC FUGITIVE
                            EMISSION SOURCES3
                               1984 Dollars


Equipment type
(emission source)
1.
2.
3.
4.

Pump seals
• Packed
• Mechanical
• Double .
mechanical
Compressors
Flanges
Valves
• Gas
Liquid

Control techniques
Monthly inspection
Monthly inspection
N/Ae
Degassing
Reservoir vents
None
Available

Monthly inspection
Monthly inspection

Capital
cost,
Percent $/comr
reduction ponent
83.3
83.3
N/A
100
N/A

70.3
72.5
0
0
N/A
10,200
N/A

0
0
Annual -
ized
cost,
$/comr
ponent
370
370
N/A
2,580
N/A

20
20
5.  Pressure relief
      devices
    '  Gas   d
       Liquid

6.  Sample connections
    •  Gas

       Liquid
7.   Open ended lines
    •  Gas
    •  Liquid
0-Ring                   100
N/A                      N/A
Closed-purge sampling    100
  systems
Closed-purge sampling    100
  systems


Caps on open ends        100
Caps on open ends    '    100
310
N/A
670

670
 70
 70
 80
N/A
170

170
 20
 20
j*Reference No.  23.
 Dollars updated using CE Plant Cost Index and M&S Equipment Cost Index
 (Chemical Engineering, June 11, 1984).
dBased on 10-year equipment life and 10 percent interest (CRF = 0.163).
 Assume 0 emissions per year.
 N/A = Not applicable.
                                     A-l 7

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                             TABLE A-2.   FUGITIVE  EMISSIONS  CONTROL  COST  CALCULATIONS
                                           (First  Quater  1984  Dollar)
CO
Emission source
Pumps
Compressor
Valves, (gas)
Valves, (liquid)
Pressure relief
Sample connect
Open ends
Flanges
Totals
No. of
components
1 .
1
85
142
6
26
0
N/A
Capital
cost/
compo-
nent, $c
0
10,200
0
0
310
670
70
N/A
Annual
cost/
compo-
nent, $c
370
2,580
20
20
80
170
20
N/A
Capital
cost per
emission
source
0
10,200
0
0
1,900
17,400
0
--
29,500
Annual
cost per
emission
source
370
2,600
1,700
2,800
500
4,400
0
--
12,400
Current
EOC
emissions,
Mg/yrT
0.22
2.0
2.8
6.2
3.0
2.1
0
3.5
20
Current
VOC
emissions,
Hg/yr
0.5
2.0
4.0
9.0
5.5
3.3
0
5.1
29
Percent
emission
reduction
83.3
100
70.3
12.5
100
100
100
N/A
N/A

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                                                     TABLE  A-2.   (continued)
Emission source
Pumps
Compressor
Valves, (gas)
Valves, (liquid)
Pressure relief
Sample connect
Open ends
Flanges
Totals
.Calculated using
EDC
emission
reduc-
tion, Mg
0.18
2.0
2.0
4.50
3.0
2.1
--
14
CE Plant Cost Index
VOC
emission
reduc-
tion, Mg
0.42
2.00
2.8
6.5
5.5
3.3
--
21
and M&S Equipment
Net
annual -
EDC VOC ized
recovery. recovery k cost .
credit, $J credit, $K EDC. $'
60
650
650
1,500
1,000
700
--
4,600
Cost Index
150
650
910
2.150
1.800
1,100
--
--
6,800
(Chemical Engineering
300
1,950
1,100
1.300
-500
3,700
--
--
7,800
, June 11,
Net
annual -
ized
cost
VOC, $m
220
1,950
800
650
-1,300
3,300
—
—
5,600
1984).
Cost
effec-
tiveness
EDC, $/kg
1.700
980
600
290
-170
1,800
--
--
560

Cost
effec-
tiveness
VOC. $/kg
520
980
290
100
-240
1,000
--
--
270

cCost for each component taken from Publication No. EPA 450/3-80-0326, Benzene Fugitive Emissions—Background  Information for Promulgated
 .Standards, Tables A-l through A-9.
 Capital cost/component x No.  of components.
^Annual cost/component x No.  of components.
 Emission data based upon information request responses.
Deduction efficiency from Publication No. EPA 450/3-80-0326 Benzene Fugitive Emissions—Background Information  for Promulgated Standards,
.Tables A-l through A-9.
.Current EOC emissions x emission  reduction efficiency.
.Current VOC emissions x emission  reduction efficiency.
j*$350 x EDC emission reduction.
,$350 x VOC emission reduction.
 Total annual ized cost _- EDC  recovery credit.
 Total annualized cost - VOC  recovery credit.

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         TABLE A-3.  TOTAL INSTALLED CAPITAL COST FOR INCINERATORS
                    AS A FUNCTION OF OFFGAS FLOWRATE*
Maximum
f 1 owrate
per unit
(thousand
NmVmin)
0.74
Fabricated
equipment
cost
escalation
factor
0.900

Design
vent
size
factor
0.95




Cl C2 C3
802.70 16.16b 0.88
Total installed capital cost ($1,000) = (No. of units) x (escalation factor)
                                        x (Ct + C2 [flowrate (NmVmin) *
                                                                C3
                                        design vent size factor]  )c

^Reference No. 22.
 Flowrate correction factor of 1.12 = (1.14)-88 incorporated into
Coefficient C2.
 Flowrate per equipment unit.
                                     A-20

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                                        TABLE  A-4.    ANNUALIZED COST  FACTORS  FOR  INCINERATORS1
ro
Direct

  Operating labor:   $13.08/h  (includes overhead)


  Operating labor factor:   2,400  labor-h/yr (categories A1-A2)

                           2,133  labor-h/yr (categories B-C)

                           1,200  labor/h/yr (categories D - E)

  Electricity:   $0.02616/kWhb

  Natural gas:   $4.78/thousand MJe

  Heat recovery credit:   $4.78/thousand HJ


  Quench water price:   $0.22/thousand gallons

  Scrubbing water price:   $0.22/thousand gallons

  Caustic price:   $0.0436/lbb

  Maintenance labor plus  materials  factor = 0.06 of
  total installed capital
                                                                              December  1978 dollars

                                                                              Indirect  ("capital charges")

                                                                                Interest  rate =  i =8.5% (after taxes)0
                                                                                             =  10% (before taxes)

                                                                                Incinerator lifetime = 10 years = N

                                                                                                                  N                      c
                                                                                Capital recovery factor = i (1 + i)  = 0.152 (after taxes)
                                                                                                         (1 *
                                                                                                                    = 0.163 (before taxes)"
                                                                              Taxes,  insurance, and administrative charges factor = 0.05 of  total
                                                                              installed capital

                                                                              Overall  capital charges  factor = 0.213 of total installed capital
                                   Overall  taxes and maintenance factor = 0.11 of total  installed  capital
        .Reference No. 22.
         Corrected from Enviroscience values  (in December 1979 dollars) to December 1978 dollars  by  a deflation  factor of 0.872.
        cAfter tax interest rate and capital  recovery factor used in process-specific economic  analysis and calculating typical costs for facilities
         .in each design category.
         Before tax interest rate and capital  recovery factor used in calculating national  cost impact for each  regulatory alternative.
        eGalloway, J. ,  EEA telecon with Robson, J., EPA:EAB, July 13, 1981.   Discussion on  natural gas prices.

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                                            TABLE  A-5.   OPERATING  FACTORS  FOR  INCINERATORS
                     Hinimuffl       Maximum
                       net           net                           Minimum       Pressure
                     heating       heating     Ratio of flue          heat          drop
                     value         value       gas flow to         recovered      (inches    Labor cost         Natural gas use coefficients
                    (MJ/N»3)      (MJ/Nm3)     offgas flow3        (MJ/Nm3)        II20)      ($l,000/yr)        GO	Gl	G2	G3

                      0             3.5           2.9               3.63         22C          31.39           0        1.86   -0.985    0


        bBoth at standard conditions.
          Includes 6 inches across the combustion chamber. 4 inches across the waste heat boiler, and 12 inches across the scrubber.
ro

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                                        TABLE A-6.   ANNUALIZED  COST  EQUATIONS  FOR INCINERATORS
        Operating  flowrate (NmVmin) = design flowrate  (NmVmin) x capacity utilization factor
                                                                                                                      •
        In the following operating cost and emissions equations, "flowrate" means the operating flowrate per  equipment unit (dilution flowrate for
          Category E)

        Natural  gas used (TJ/yr) = 0.5256 million min/yr  x G4> +  flowrate x (Gl + 62 x heating value + G3 x heating value2)

        Natural  gas cost ($l,000/yr) = natural gas price  ($/GJ)  x natural gas used (TJ/yr)

        Labor cost ($l,000/yr) = labor wage ($/man-h) x operating labor factor (man-h/yr) * 1,000

        Electricity cost ($l,000/yr) = 0.0604 x electricity  price ($/kWh) x pressure drop (inches H20) x flowrate (NmVmin) x  flue-gas/off gas ratio

        Quench water cost  ($l,000/yr) = quench water price (I/thousand gal) x flowrate (NmVmin) x 0.00886 x  flue-gas/offgas ratio

        Scrubbing  water cost  ($l,000/yr) = scrubbing water price ($/thousand gal) x flowrate (NmVmin) x 0.289 x flue-gas/offgas  ratio

        Caustic cost ($l,000/yr) = caustic price ($/lb) x flowrate (NmVmin) x 17.17 x flue-gas/offgas ratio

        Heat recovery  credit  ($l,000/yr) = natural gas  price ($/GJ)  x heat recovery factor (MJ/Nm3) x flowrate (NmVmin) x  0.5256 (million min/yr)

^      Taxes and  maintenance cost ($l,000/yr) = installed capital ($1,000) x taxes and maintenance factor
ro
w      Operating  cost ($l,000/yr) = taxes and maintenance cost  ($l,000/yr) + number of equipment units x (gas cost + labor cost  + electricity cost
                                                                                                      + quench cost +  scrub  cost + caustic cost
                                                                                                      - heat recovery  credit)

        Annualized cost ($l,000/yr) = operating cost +  capital  recovery  factor x capital cost ($1,000)

        Hourly emissions (kg/h) = 0.0268 (moles/Nm3)(min/hour)(kg/g)(l/100%) x flow (NmVmin) x (% VOC) x (molecular weight)

        Annual emissions (Gg/yr) = hourly emissions (kg/h)  x 365 days/year x 24 hours/day x 1 Gg/106kg

        Annual emission reduction (Gg/yr) = annual emission  (Gg/yr)  x 0.98

        Cost effectiveness ($/Mg) = annualized cost ($l,000/yr)  T  annual  emission  reduction (Gg/yr)

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I.  REFERENCES

 1.  U. S. Environmental Protection Agency.  Control  of  Volatile  Organic
     Compound Emissions from Volatile Organic  Liquid  Storage  Vessels in
     Fixed and Floating Roof Tanks.  Research  Triangle Park,  North
     Carolina.  Publication No. EPA 450/3-84-005.  June  1984.
                                             •
 2.  Reference 1, p. 2-23.

 3.  Reference 1, p. 2-21.

 4.  Telecon.  Powers, S., MRI, with Bergstrom, B., Chicago Bridge and
     Iron.  July 26, 1984.  Additional cost  in using  a Teflon  coated
     primary seal versus a polyurethane coated seal.

 5.  Telecon.  Powers, S., MRI, with Mason,  M., Chicago  Bridge  and Iron.
     July 27, 1|84.  Cost for the  installation of  a secondary seal  coated
     with Viton .

 6.  Reference 1, p. 2-23.

 7.  Reference 1, p. 2-25.

 8.  Reference 1, p. 2-37.

 9.  Reference 1, p. 2-13.

10.  Economic Indicators.  Chicago Engineering.  91:(12):7.   June 11,
     1984.                                       ~

11.  Telecon.  Powers, S.. , MRI, with Robson, J. , EPA.  July 24, 1984.
     Market price EDC mid-1982 dollars.

12.  Letter and attachments from McAulliffe, C. H., Formosa Plastics
     Corporation, U.S.A., to Farmer, J. R. ,  EPA:ESED.  March  28,  1984.
     Transmittal  of Section 114 information  questionnaire.

13.  U. S. Environmental Protection Agency.  Organic  Chemical Manu-
     facturing Volume 5:  Adsorption, Condensation, and  Absorption
     Devices.  Research Triangle Park, North Carolina.   Publication
     No. EPA-450/3-80-027.  December 1980.   pp. V-l - V-12.

14.  Reference 13, p. V-5.

15.  Reference 13, p. V-12.

16.  Telecon.  Cooper, R., MRI, with Heath,  S., Formosa  Plastics.
     June 13, 1984.  Additional data on EDC  shipping  emissions.

17.  Ethylene Dichloride Emission Summary.   Midwest Research  Institute.
     Raleigh, North Carolina.   June 18, 1984.
                                  A-24

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18.   Telecon.  Powers, S. ,  MRI, witfi Robson, J., EPA.  July 24, 1984.
     Market price EDC mid-1982 dollars.

19.   Economic Indicators.  Chemical Engineering 91:(12):7.  June 11,
     1984.

20.   Gross, S. , (MSA Research Corporation).  Demonstration of Vapor  Control
     Technology for Gasoline Loading of Barges.  Prepared for U. S.
     Environmental Protection Agency.  Research Triangle Park,  North
     Carolina.  Contract No. 68-02-3657.  p. 28.

21.   Reference 20, p. 30.

22.   U. S. Environmental Protection Agency.  Air Oxidation Processes  in
     Synthetic Organic Chemical Manufacturing  Industry—Background
     Information for Proposed Standards.  Draft EIS.  Publication
     No. EPA-450/3-82-001a.  October 1983.  pp. 8-16 and 8-17.

23.   U. S. Environmental Protection Agency.  Benzene Fugitive Emissions--
     Background Information for Promulgated Standard.  Research Triangle
     Park, North Carolina.   Publication No. EPA-450/3-80-0326.  June  1982.
     pp. A-2 - A-24.
                                  A-25

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        APPENDIX B






EXISTING STATE REGULATIONS

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     The regulations to control  EDC emissions vary between the six States
(Texas, Kansas, New Jersey, California, Louisiana, Kentucky) where EDC
and EDC products are produced.1   Of these six States, only California has
no regulations that would control EDC emissions.   New Jersey regulates
EDC emissions under its toxic air volatile organic substances (TVOS)
regulations.   Other States either do not control  certain sources or
regulate them under their general volatile organic compound (VOC)
regulations.
     In New Jersey, emissions of EDC from production processes, storage
tanks, or transfer operations are prohibited unless the equipment and
operation are registered with the New Jersey Department of Environmental
Protection.   The control of EDC  emissions from the equipment or operating
processes is to represent advances in the art of control as determined by
the New Jersey Department of Environmental Protection.  The discharge of
any TVOS into the atmosphere must be:
     1.  No less than 12.2 meters (m) (40 feet [ft]) above grade;
     2.  No less than 6.1 m (20  ft) higher than any area of human use of
occupancy within 15.2 m (50 ft); and
     3.  Directed vertically upward at a velocity of 1,097 meters per
minute (m/min) (3,600 feet per minute [fpm]).
Also, any discharge of TVOS into the atmosphere from a system, equipment,
or control device must be effective in preventing aerodynamic downwash.
     Ethylene dichloride emissions from a production process of EDC are
not controlled under any Texas,  Kansas, or Kentucky regulations.
Louisiana regulates EDC emissions under its volatile organic compound
(VOC) regulations.  If a facility emits greater than 1.4 kilograms per
hour (kg/h) (3.0 pounds per hour [lb/h]) or 6.8 kg/d (15 Ib/d) of VOC, it
must reduce the emissions either by incineration (90 percent removal
efficiency required) or by using.a carbon adsorption system.  With any
process upsets, start-ups, or shutdowns, VOC emissions must be vented and
reduced either by an afterburner, carbon adsorption system, refrigeration,
catalytic and/or thermal reaction, secondary steam stripping, recycling,
or vapor recovery system.
                                   B-l

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     Regulations pertaining to storage tanks laden with materials
emitting VOC emissions are quite similar between Texas, Kansas,
Louisiana, and Kentucky with only minor variations in allowed pressure
levels and tank storage size associated with different control techniques.
In general, a storage tank with a capacity greater than 151,400 liters
(£) (40,000 gallons [gal]) but having less than 76 kilopascals (kPa)
(11 pounds per square inch absolute [psia]) of pressure, would require a
floating roof with seals between the tank wall and roof edge, or a vapor
recovery system which returns vapor to a disposal system.   For tanks
smaller than 151,400 £ (40,000 gallons), a submerged fill  pipe is
considered sufficient control, and for tanks larger than 151,400 2
(40,000 gallons) with pressure greater than 76 kPa (11 psia), a submerged
fill pipe and vapor recovery system is required.
     Kentucky and Kansas do not have any regulations concerning loading
and unloading of materials emitting VOC emissions.  In Louisiana,
facilities with at least 75,700 £ (20,000 gallons) of throughput per day
must have vapor collection and disposal systems.   All pumps and
compressors handling VOC's should also be equipped with mechanical seals.
     In Texas attainment and nonattainment areas, facilities with at
least 75,700 2 (20,000 gallons) of throughput per day are required to
have vapor tight seals and vapor collecting or recovery system to pick up
residual emissions at loading and unloading operations.  In nonattainment
areas, the vapor recovery system should ensure that VOC emissions are
reduced to a level not to exceed 0.08 kg (0.17 pounds) of VOC per 3,785 £
(1,000 gallons) of liquid transferred.  In Harris County,  with facilities
of 1.9 xlO6 £ (500,000 gallons) of throughput a day, reduction of VOC
emissions must be down to a level of 0.15 kg (0.33 pounds) per 3,785 £
(1,000 gallons) transferred.
REFERENCES FOR APPENDIX B
1.  Bureau of National Affairs.  Environment Reporter.  State Air Laws.
    Vol. 1, 2, and 3.  Washington, D.C.  pp. 321:0101-321:1001 (last
    revision, November 11, 1983), 381:0101-381:0501 (last revision,
    January 27, 1984), 386:0101-386-0501 (last revision, January 27,
    1984), 391:0101-391:1001 (last revision, June 10, 1983), 451:0081-
    451:0921 (last revision, January 6, 1984), 521:0101-521:0681 (last
    revision, November 11, 1983).
                                   B-2

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                                    TECHNICAL REPORT DATA
                             (Please read Instructions on the reverse before completing)
 1. REPORT NO.
  EPA-450/3-84-018
              3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
                                                             5. REPORT DATE
                                                              December 1984
  Survey  of Ethylene Bichloride Emission  Sources
                                                             6. PERFORMING ORGANIZATION CODE
 '. AUTHOR(S)
                                                             8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
  Office  of  Air Quality Planning and Standards
  Environmental Protection Agency
  Research Triangle Park,  North Carolina   27711
                                                             10. PROGRAM ELEMENT NO.
              11. CONTRACT/GRANT NO.
                                                              EPA Contract 68-02-3817
 12. SPONSORING AGENCY NAME AND ADDRESS
  DAA for Air Quality Planning and Standards
  Office of Air and Radiation
  U.S. Environmental Protection Agency
  Research  Triangle Park, North Carolina   27711
              13. TYPE OF REPORT AND PERIOD COVERED
                Final
              14. SPONSORING AGENCY CODE
                EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
  The potential health impact   of nationwide  ethylene dichloride emissions  is  being
  investigated.  This document  contains information on the  sources of ethylene
  dichloride  emissions, current emission levels,  control methods that could  be used
  to reduce ethylene dichloride emissions, and  cost estimates  for employing  controls.
 7.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
c.  COSATI Field/Group
  Air Pollution
  Pollution  Control
  Synthetic  Organic Chemical Manufacturing
    Industry
  Ethylene Dichloride
  Air Pollution  Control
     13B
 8. DISTRIBUTION STATEMENT
                                               19. SECURITY CLASS (ThisReport)
                                                 Unclassified	
  Unlimited
                            21. NO. OF PAGES
                            	151
20. SECURITY CLASS (Thispage)
  Unclassified
                                                                          22. PRICE
EPA Form 2220-1 (Rev. 4-77)   PREVIOUS EDITION is OBSOLETE

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