450R80108
oEPA
United States
Environmental Protection
Agency
Office of Air Quality May
Planning and Standards 1980
Research Triangle Park, NC 27711
National Errvssion Standards for Hazardous Air Pollutants
Benzene Emissions
from Maleic Anhydride Plants
Proposed Regulation
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Benzene Emissions
from Maleic Anhydride Plants
Proposed Regulation
Graphic Arts and Text Preparation:
Northrop Services, Inc.
Research Triangle Park, NC 27709
Photo Courtesy of:
Monsanto Company
St. Louis, Missouri
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National
Emission Standards
for Hazardous
Air Pollutants
The Clean Air Act as amended in 1977 re-
quires a comprehensive national program
for reducing air pollution and improving air
quality. Section 112 of the Act authorizes
EPA to establish National Emission Stan-
dards for Hazardous Air Pollutants
(NESHAPS). Hazardous air pollutants
being considered for NESHAPS regulation
are defined by the Act as substances (1) to
which no ambient air quality standard is
applicable and (2) that may reasonably be
anticipated to result in an increase in mor-
tality, in serious irreversible illnesses, or in
incapacitating, reversible disorders. Each
standard is to be set at a level that provides.
in the judgement of the Administration, an
ample margin of safety to protect the pub-
lic health. NESHAPS immediately apply to
new sources upon promulgation and to ex-
isting sources within 90 days, though under
special circumstances existing sources may
be given up to two years to comply. Each
state may develop and submit to EPA a
procedure for implementing and enforcing
NESHAPS for stationary sources located
within the state, which EPA will review for
efficacy. EPA is now proposing a NESHAPS
for benzene emissions from the process
vents of maleic anhydride plants.
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Benzene
Benzene was listed
as a hazardous air
pollutant by EPA
on June-8, 1977.
Studies of indus-
trially exposed
workers have shown
that benzene is caus-
ally related to the in-
duction of a number of blood disorders.
Among these diseases are leukemia (a can-
cer of the hematopoietic, or blood-forming,
system), various cytopenias (decreased lev-
els of formed elements in the circulating
blood, such as red cells, white cells and
platelets), aplastic anemia (a non-function-
ing bone marrow), and potentially inherit-
able chromosomal aberrations. The sever-
ity of hematopoietic diseases ranges from
mild and episodic to chronic and fatal.
The proposed NESHAPS would reduce the
risk of leukemia to individuals exposed to
benzene emissions from maleic anhydride
process vents. The estimated maximum
lifetime risk of leukemia to the most-ex-
posed individuals would be reduced from a
range of 1 chance in 1,600 to 11,000 to a
range of 1 chance in 29,000 to 200,000.
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Maleic
Anhydride
Plants
EPA established ini-
tial priorities for
stationary sources of
benzene emissions
according to max-
imum risk and can-
cer incidence, esti-
mated from ambient
exposures caused by
such sources. When these two factors are
weighed together, maleic anhydride process
vents rank as one of the higher priority
sources of benzene for regulation. Benzene
is used as a feedstock in the production of
maleic anhydride and/or lesser amounts of
maleic acid.
Stationary sources account for 20 percent
of the total benzene emissions released in
the United States, with the remaining 80
percent due to mobile sources. Maleic
anhydride plants are by far the largest
single source of benzene emissions in the
chemical industry, discharging 35 percent
of all benzene emitted by stationary sources.
The benzene emissions specifically affected
by the proposed regulation would be those
released from the vents of the maleic anhy-
dride production unit. This unit contains
several components: one or more reactors,
a product recovery absorber (whose vent
releases over 98 percent of the total benzene
emissions from a maleic anhydride plant),
and a refining system. The rulemaking
would be applicable to all production units
manufacturing over 500 megagrams (550
tons) of maleic anhydride and/or maleic
acid per year, a level of production that
distinguishes commercial-sized plants from
laboratory facilities.
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The Proposed
Standard for
Limiting
Emissions
The proposed regu-
lation would apply
to all existing and
new maleic anhy-
dride production
units. It would re-
quire 97 percent
control of benzene
emissions from ex-
isting sources (or units) and 100 percent
elimination of benzene emissions from new
sources. The permissible limit of benzene
discharges into the atmosphere from the
process vents of existing sources would be
0.30 kg benzene per 100 kg benzene fed to
the reactor(s). New sources would achieve
100 percent control of benzene emissions
through substitution of benzene with an-
other feedstock, such a n-butane.
The proposed standard would not allow
emissions in excess of the numerical emis-
sion limit except when a sudden and un-
avoidable failure of air pollution control
equipment occurs. During such a failure,
the emissions could not exceed the amount
that would be released in the process of
shutting down the plant. Emissions could
generally be kept below this level during
control equipment failures by modifying
plant operations, but in cases where emis-
sions would still exceed the level released
during shutdown (such as during lengthy
repairs), plant operations would have to
cease. The total quantity of uncontrolled
emissions calculated to occur during a
typical shutdown procedure is 250 kg
(550 Ib) for a typical plant with a capacity
of 25,000 tons per year and three reactors.
Owners and operators of all maleic anhy-
dride plants using benzene as a feedstock
would also be required to install contin-
uous monitoring systems and report any
emissions in excess of the numerical emis-
sion limit.
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Achieving and
Maintaining
the Standard
The proposed stan-
dard for existing
sources, which is
based on best avail-
able technology for
i < reducing benzene
V ) emissions (consider-
^—\ ,f~$\ ing environmental,
>/"^ economic and en-
ergy impacts), can be achieved through add-
on controls, such as thermal incineration or
carbon adsorption systems. Neither of these
methods is specifically required by the pro-
posed standard, but both have been proven
as viable means to curb emissions.
For new sources, the benzene feedstock
would be substituted entirely, resulting in
100 percent control of benzene emissions.
Although the proposed standard technically
applies to all maleic anhydride plants, those
plants not using benzene as a feedstock are
exempt from the requirements for initial
testing, continuous monitoring, or reporting
of excess emissions set forth by the pro-
posed standard.
Continuous monitoring systems, such as gas
chromatography with flame ionization de-
tection, would be used to indicate compli-
ance with the standard.
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Impacts
Environmental:
Nationwide annual
reductions of ben-
zene emissions from
maleic anhydride
plants, operating at
full capacity, would
be 4,900 megagrams
(from 5,800 to 900
Mg) or 5,400 tons (from 6,400 to 990 tons).
These reductions would be achieved with
minimal adverse impacts to other aspects of
the environment, although small increases
in NOX and SOX emissions to the atmo-
sphere would occur if control by thermal
incineration were used. Also, small increases
in solid waste and benzene could occur in
wastewater if carbon adsorption were used.
Energy: For the existing maleic anhydride
plants, nationwide energy requirements to
control emissions would be expected to
approximate 50,000 barrels of fuel oil per
year. To comply with the proposed stan-
dard, a typical, uncontrolled plant oper-
ating at full capacity would increase its
energy consumption by approximately
10,500 barrels per year.
Economic/Industrial: In the first two
years of compliance with the proposed
standard, the domestic maleic anhydride
industry would need a capital investment
of about $6.6 million. The annualized
costs for the industry would increase by
about $2.5 million per year by the fifth
year, and maleic anhydride prices would
increase up to 1.2 percent overall. In addi-
tion, during control system malfunctions,
production levels may be decreased in
order to meet the standard. Atypical plant,
with an annual capacity of 22,700 Mg
(25,000 tons), could lose between 15 to
42 hours of production time per year, at
an estimated cost per hour of $1,000 to
$1,500.
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Public
Participation
A public hearing on
the proposed regula-
tion is scheduled for
May 20, 1980, be-
ginning at 9:00 a.m.,
at the Olde Colony
Motor Lodge, 625
First St., Alexandria,
Virginia. Invited to
participate are individuals who wish to pre-
sent additional data, views, or other com-
ments concerning this NESHAPS regulation,
the listing of benzene as a hazardous pollut-
ant, or the health effects associated with
benzene emissions from maleic anhydride
plants. If you wish to speak at the hearing,
contact Ms. Deanna Tilley, Emission Stan-
dards and Engineering Division (MD-13),
U.S. Environmental Protection Agency,
Research Triangle Park, North Carolina
27711, telephone 919/541-5477 by May
13, 1980.
Written comments will be accepted on or
before June 17, 1980, and should be
submitted in duplicate and addressed to
Central Docket Section (A-130), Attention:
Docket Number OAQPS 79-3, U.S. Environ-
mental Protection Agency, 2903 B Water-
side Mall, 401 M Street, SW, Washington,
DC 20460. The docket contains all infor-
mation considered by EPA during the de-
velopment of this standard and is open for
inspection. The supporting background
documents for the proposed standard may
be obtained from the EPA Library (MD-35),
Research Triangle Park, North Carolina
27711, telephone 919/541-2777. Refer to:
Benzene Emissions from Maleic Anhydride
Plants—Background Information Document
for Proposed Standard, Assessment of
Health Effects of Benzene Germane to
Low-Level Exposures, Assessment of Hu-
man Exposures to Atmospheric Benzene,
and Carcinogen Assessment Group's Report
on Population Risk to Ambient Benzene
Exposures.
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Status of The proposed standard was published in and the final regulation is scheduled for
Regulation the Federal Register on April 18, 1980. A publication in February 1981.
public hearing is scheduled May 20, 1980,
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