STANDARD SUPPORT
       ENVIRONMENTAL IMPACT STATEMENT
               FOR CONTROL OF
  BENZENE FROM THE MALEIC ANHYDRIDE INDUSTRY
                 Draft Report


                  July, 1978
   U. S. Environmental  Protection Agency
    Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina  27711

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                            INTRODUCTION

     This document describes the domestic maleic anhydride production
industry with emphasis on the benzene emissions to the atmosphere.  The
first sections of the report discuss the characteristics of the industry,
the processes used to produce maleic anhydride, and the associated
emissions.  Only ducted process vents are covered in this document.
Emissions of benzene from other sources, i.e., fugitive emissions, emissions
from storage and handling of benzene, and miscellaneous secondary sources
of benzene will be covered in other documents in preparation.  Applicable
control techniques and alternative levels of control are also described.
Finally, the environmental, energy, cost, and economic impacts of the
alternative levels of control are discussed.

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                         TABLE OF CONTENTS
                                                                page
1.0  The Maleic Anhydride Industry
     1.1  General	1-1
     1.2  Process Descriptions and Emissions 	 1-6
          1.2.1  Benzene Oxidation Process 	 1-6
          1.2.2  n-Butane Oxidation Process  	 1-14
          1.2.3  Byproduct of Phthalic Anhydride 	 1-17
                  Production
          1.2.4  Foreign Processes 	 1-17
          1.2.5  Summary	1-18
     1.3  References	1-19
2.0  Emission Control Techniques
     2.1  Alternative Emission Control Techniques  	 2-1
          2.1.1  Carbon Adsorption 	 2-1
          2.1.2  Thermal Incineration  	 2-3
          2.1.3  Catalytic Incineration  	 2-4
          2.1.4  n-Butane Process Conversion 	 2-4
     2.2  Performance of Emission Control  Techniques  	 2-4
          2.2.1  Carbon Adsorption 	 2-4
          2.2.2  Thermal Incineration  	 2-10
          2.2.3  Catalytic Incineration  	 2-13
          2.2.4  n-Butane Process Conversion	'.  .  .  . 2-13
     2.3  References	2-14
                                   n

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                                                                    paqe
3.0  Alternative Regulatory Options or Control Levels 	  3-1
4.0  Environmental  and Energy Impact
     4.1  Air Pollution Impact	4-1
          4.1.1   Carbon Adsorption (99.5 percent control  	  4-10
                 of benzene)
          4.1.2   Carbon Adsorption (97 percent control  	  4-12
                 of benzene)
          4.1.3   Thermal Incineration (99.5 percent 	  4-12
                 control  of benzene)
          4.1.4   Thermal Incineration (97 percent 	  4-13
                 control  of benzene)
          4.1.5   n-Butane  Process Conversion (100 percent 	  4-13
                 control  of benzene)
     4.2  Water  Pollution  Impact   	  4-14
     4.3  Solid  Waste Disposal  Impact 	  4-15
     4.4  Energy Impact	4-15
          4.4.1   Carbon Adsorption (99.5 percent control   	  4-15
                 of benzene}
          4.4.2   Carbon Adsorption (97 percent control   .  	  4-16
                 of benzene)
          4.4.3   Thermal Incineration (99.5 percent 	  4-16
                 control  of benzene)
          4.4.4   Thermal Incineration (97 percent 	  4-16
                 control  of benzene)
          4.4.5   n-Butane  Process  Conversion  	  4-16
          4.4.6   Summary	4-17
     4.5   Other  Environmental  Impacts 	  4-18
     4.6   Other  Environmental  Concerns
          4.6.1   Irreversible and  Irretrievable  Commitment   ....  4-18
                 of Resources
     4.7   References		  4-19
     5.0   Economic  Impact  .....  	   5-1
          5.0.1   Introduction	5-1

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                                                                          page
               5.0.2  Executive Summary 	  5-1
     5.1  Industrial Economic Profile 	  5-2
     References	5~19
     5.2  Cost Analysis of Alternative Emission Control  Systems 	  5-21
     References	5-47
     5.3  Economic Impact of Alternative Emission Control  Systems ....  5-49
     References	5-84
Appendix A - Evolution of the Proposed Standard 	  A-l
Appendix B - Matrix of Environmental Impacts of Alternative 	  B-l
             Control Systems
Appendix D - Emission Monitoring and Compliance Testing Technique .  .  .  .  D-l
                                       IV

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                             LIST OF TABLES
                                                                     page
Chapter  1.0
         1-1  Maleic Anhydride Usage and Growth  	  1-2
         1-2  Maleic Anhydride Capacity 	  1-3
         1-3  Benzene and Total VOC Emissions	  1-12
         1-4  Waste Gas Composition - Product Recovery Absorber . . .  1-13
Chapter  2.0
         2-1  Technical Data - Carbon Adsorption System   	  2-9
              (99.5 percent control)
         2-2  Technical Data - Carbon Adsorption System 	  2-9
              (85 percent control)
        2-3  Technical Data - Carbon Adsorption System 	  2-10
              (98 percent control at design)
        2-4  Technical Data - Thermal  Incineration 	  2-12
              (99.5 percent control)
        2-5  Technical Data - Thermal  Incineration 	  2-13
Chapter 4.0
        4-1  Maximum Annual Average Benzene Concentrations  	  4-2
        4-2  Maximum 1-hour, 3-hour, 8-hour, 24-hour, and  	  4-4
              Annual Average Benzene Concentrations Produced
              by the Combined Emissions from a  Maleic
              Anhydride Plant at Any Distance Downwind
              and at 0.1, 1.0,  10.0, and  20.0 kilometers
        4-3  Identification of Model Source Numbers by Source  .  .  .   4-7
              Name and Emission  Control Option
        4-4  Total National Energy Requirement  	   4-18
Chapter 5.0
        5-1  Maleic Anhydride Capacity  	   5-5
        5-2  Maleic Anhydride Usage and Growth  	   5-10
        5-3  Technical  Parameters Used  in  Developing  	   5-23
              Control  System Costs

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              LIST OF TABLES (continued)

                                                            page

5-4  Annualized Cost Parameters	5-26

5-5a Existing Plant Costs for Achieving 97 Percent  .... 5-28
      Benzene Emission Reduction Control Method:
      Carbon Adsorption

5-5b Existing Plant Costs for Achieving 97 Percent  .... 5-29
      Benzene Emission Reduction Control Method:
      Thermal Incineration with Primary Heat
      Recovery

5-6a Existing Plant Costs for Achieving 99.5 Percent  .  .  . 5-32
      Benzene Emission Reduction Control Method: .
      Carbon Adsorption

5-6b Existing Plant Costs for Achieving 99.5 Percent  .  .  . 5-33
      Benzene Emission Reduction Control Method:
      Thermal Incineration with Primary Heat
      Recovery

5-7  Costs for Continuous Monitoring of Benzene 	 5-36
      Stack Emissions

5-8  Cost Summary tor Existing Maleic Anhydride 	 5-37
      Plants

5-9  Estimated Total Investment Cost for Achieving  .... 5-51
      Benzene Emission Reduction

5-10 Ratio of MA Sales to Parent Company Sales	5-53

5-11 Comparison of Control Costs to Total 	 5-55
      Company Capital Expenditures

5-12 Possible Cost Pass-Through Under Case	5-57
      Assumption of 56% Production Capacity

5-13 Possible Cost Pass-Through Under Case	5-58
      Assumption of 100% Production Capacity

5-14 Depiction of Possible Competitive Advantages 	 5-61
      Due to Cost Pass-Through Under the 56 Percent
      Production Capacity Assumption - 97% Control

5-15 Depiction of Possible Competitive Advantages 	 5-62
      Due to Cost Pass-Through Under the 56 Percent
      Production Capacity Assumption - 99.5% Control

5-16 Effect of Transportation Under a 97 Percent  	 5-68
      Control Standard
                           VI

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               LIST OF TABLES (continued)
                                                            page
5-17  Effect of Transportation Under a 99.5 Percent  .... 5-69
       Control  Standard
5-18  Summary of Impact of 97% Benzene Control  .  	 5-73
       Level on MA Companies
5-19  Summary of Impact of 99.5% Benzene 	 5-75
       Control  Level on MA Companies
5-20  Price Increases of Polyester Resins  Due  	 5-78
       to Increased MA Prices
5-21  Price Increases of Fumaric Acid Due	5-79
       to Increased MA Prices
5-22  Price Increases of Malathion Due to   	 5-80
       Increased MA Prices
                          vn

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                           LIST OF FIGURES
                                                                   page
Chapter 1.0
        1-1  Manufacturing Locations of Maleic Anhydride 	  1-4
        1-2  Process Flow Diagram  	  1-7
Chapter 4.0
        4-1  Layout of the Maleic Anhydride Plant Showing  ....  4-6
              Source Locations
Chapter 5.0
        5-2  Captive and Merchant Sales of MA Companies	5-6
        5-3  Price Fluctuations  	  5-12
        5-4  Maleic Anhydride:  A Comparison of Imports to ....  5-15
              U.S. Production and Demand
        5-5  U.S. Consumption of MA by Source	5-16
        5-6  Cost-Effectiveness of Alternative Control 	  5-39
              Systems Operating Factor:  4500 hours/year
        5-7  Cost-Effectiveness of Alternative Control 	  5-40
              Systems Operating Factor:  8000 hours/year
        5-8  Installed Costs of Carbon Adsorbers	  5-44
        5-9  Installed Costs of Thermal Incinerators 	  5-45
              with Primary Heat Recovery
                                 viii

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                      1.0 THE MALEIC ANHYDRIDE INDUSTRY

 1.1  GENERAL
     This chapter will discuss the production of maleic anhydride, focusing
primarily on three basic processes used in the United States and the benzene
emissions related to these processes.  The processes are:  oxidation of
benzene, oxidation of n-butane, and recovery as a byproduct of phthalic
anhydride manufacture.  Most of the current domestic capacity is based on
the oxidation of benzene.  Foreign processes will also be briefly described.
     Table 1-1 shows the end uses of maleic anhydride and its expected
growth rate.   The predominant end use is the production of unsaturated
polyester resins, which go into reinforced plastic applications such as
marine craft, building panels, automobiles, tanks, and pipes.  The U. S.
maleic anhydride production capacity for 1977 was reported to be 229,000
                                                                              1 2
megagrams (Mg) with only 56 percent of this capacity currently being utilized. *
At an estimated 11 percent annual growth in maleic anhydride consumption,
production would reach 95 percent of present capacity by 1982.  No shortage
                                                                   3
of benzene, the major raw material, is expected during this period.
     As of 1977, there were eight producers of maleic anhydride in the U. S.
with ten plants.  Table 1-2 lists the producers and the processes being used;
Figure 1-1 shows the plant locations.  Approximately 83 percent of the
229,000 Mg/year domestic capacity is based on the oxidation of benzene.
Oxidation of n-butane accounts for another 15 percent of capacity, and the
remaining 2 percent is from phthalic anhydride production which yields maleic
                         4
anhydride as  a byproduct.    The projected growth rate for the n-butane
                                     1-1

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                                         TABLE 1-1
                           MALEIC ANHYDRIDE USAGE AND GROWTH9
                                                              Average Annual
           End Use                    % Production         % Growth (1974-1980)
Unsaturated Polyester Resins               51.1                      9.5
Fumaric Acid                                6.4                      2.0
Agricultural Chemicals                     10.0                      6.5
Alkyd Resins                                1.3                      0.0
Lubricating Additives                       7.8                      8.0
Copolymers                                  5.3                      6.0
Reactive Plasticizers                       3.6                      5.0
Maleic Acid                                 3.8                      7.0
Chlorendic Anhydride and Acid               1.1                     10.0
Surface-Active Agents                       2.9                      5.0
Other                                       6.7                      2.0
                                          100.0

(A)  These numbers include a decline in MA consumption of 27% in 1975.  The annual MA
     growth rate from 1976-1982 is now projected to average 11%.  Polyester resins
     are expected to continue as a growth leader.
                                            1-2

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                                        TABLE  1-2
                               MALEIC ANHYDRIDE CAPACITY10'11

                                             ^Capacity  -  1977
                                           10  Megagrams  (Mg)              Process
 1.   Amoco,  Joliet,  IL                            27                          2
 2.   Ashland,  Neal,  WV                            27                          1
 3.   Koppers,  Bridgeville,  PA                    15                          1
 4.   Koppers,  Chicago,  IL                          5                          3
 5.   Monsanto, St.  Louis, MO                     48                  (80%) 1  -  (20%)  2
 6.   Denka (Petrotex),  Houston, TX                23                          1
 7.   Reichhold, Elizabeth,  NJ                    14                          1
 8.   Reichhold, Morris, IL                        20                          1
 9.   Tenneco,  Fords, NJ                          12                          1
10.   U.  S. Steel,  Neville Island, PA             38                          1
        TOTAL                                     229
     Processes:
     (1)  Oxidation of benzene
     (2)  Oxidation of n-butane
     (3)  By-product of phthalic anhydride manufacture
                                             1-3

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                                   FIGURE 1-1
Key
1.
2.
3.
4.
5.
                         MANUFACTURING LOCATIONS
                                   OP
                            MALEIC ANHYDRIDE
Amoco, Joliet, IL
Ashland, Neal, W. VA
Koppers, Bridgeville, PA
Koppers, Chicago, IL
Monsanto, St. Louis, MO
                                     1-4
 6.
 7.
 8.
 9.
10.
Denka  (Petro-Tex),  Houston, TX
Reichhold, Elizabeth, NJ
Reichhold, Morris, IL
Tenneco, Fords, NJ
U.S. Steel, Neville Island, PA

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 oxidation  process  through  1982  is 24.3  percent,  primarily  through  conversion
 of existing  benzene capacity, as compared  to  only a 9.1 percent growth, rate
 for the  benzene oxidation  process.  This assumes the butane process becomes
 fully  commercialized.  Substantive data regarding the economic incentives for
 switching  to n-butane oxidation are not available.  Finally, no growth in
 the quantity of maleic anhydride recovered during phthalic anhydride
 production is expected.
     As  mentioned  earlier, there are two predominant processes for producing
 maleic anhydride.  Oxidation of benzene was the  first and still is used for
 most of  the  domestic production.  However, work  began in 1960 to develop a
 catalyst suitable  for producing maleic  anhydride from butane/butene (C4)
 streams  available  from naphtha cracking because  of anticipated increases in
 the price  of benzene.  This effort was  curtailed during the 1961-1967  period
 when the maleic anhydride  market was depressed and low-cost benzene was
 available.   In 1967, demand for maleic  anhydride increased and work
 was  renewed  in Japan by Kasei Mizuishima.  In 1974, announcements
concerning the production of maleic anhydride from C4's were made by Petro-

                                                                            7
Tex, Chem Systems, BASF, Bayer, Alusuisse/lO, and Mitsubishi.   Presently,
Amoco and Monsanto are producing maleic anhydride from a n-butane feedstock.
It is still uncertain whether or not the n-butane process is competitive with
                    Q
the benzene process.
                                      1-5

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1-.2  PROCESS DESCRIPTIONS AND EMISSIONS
     As previously discussed, the two major processes used to manufacture
maleic anhydride in the United States are benzene oxidation and n-butane
oxidation.  A small amount of maleic anhydride is recovered as a byproduct
of phthalic anhydride production.  The only significant foreign process
for maleic anhydride production not used in the U. S. starts with a butene
                                                            12           13
mixture feedstock.  This process is currently used in France   and Japan.
There are no known plans to introduce this process domestically.
     This chapter only addresses ducted process emissions, i.e., normal
vents from the process equipment, and does not include emissions from the
storage and handling of benzene, leaks from equipment, or secondary sources
of benzene e.g., benzene evaporation from a wastewater stream.  It is important
to recognize that  there are no benzene emissions  from any of the processes using
n-butane  or butenes, or from  the recovery process from phthalic anhydride production,

1.2.1  Benzene Oxidation Process
     Maleic anhydride is produced by the following vapor-phase chemical reaction:
                                       H-C - C"°
                            _^         II     ^°  + 2H2°  + 2C02
                          2            H-C - C^Q

          BENZENE     OXYGEN            MALEIC         WATER     CARBON
                                       ANHYDRIDE                DIOXIDE

The process flow diagram shown in Figure 1-2 represents a typical process.
The typical process is continuous, although some plants operate dehydration
and distillation batchwise.  The emissions in either case are judged to be
           14
equivalent.
                                     1-6

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                                      Figure 1-2
AIR
                                                                                         U AXE.-UP
                                                                              sP
                                                                          PROCE.VJ
                                                                          MOCCI. PLWJT - uuCQuT PQUL&D	
Key:  A  -  product recovery absorber vent
      B  -  vacuum system  vent
      C  -  storage and  handling emissions
      K  -  secondary emission potential

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     A mixture of benzene and air enters a tubular reactor where the
catalytic oxidation of benzene is carried out at a temperature of
350-400°C.  The catalyst contains approximately 70 percent vanadium
pentoxide supported on an inert carrier; most of these catalysts also
contain 25-30 percent molybdenum oxide.  The reaction is highly exothermic,
releasing 24.4 MJ/kg of benzene reacted, with the excess heat being used
to generate steam.  Maleic anhydride yields range from 60-67 percent of
theoretical.15
     The reactor feed mixture is provided with excess air to keep the benzene
concentration below its explosive limit of 1.5 volume percent.  The resultant
large volume of reactor exhaust (Stream 3) directly influences the size of
the subsequent product recovery equipment.  After reaction, the stream passes
through a cooler, partial condenser, and separator in which 40 percent of
the maleic anhydride is condensed and separated as crude product (Stream 4).
The remaining product and other organics (Stream 5) enter the product recovery
absorber where they are contacted with water or aqueous maleic acid.  The
liquid effluent from the absorber (Stream 6) is a 40 weight percent aqueous
solution of maleic acid.  The absorber vent (Vent A) exhausts to the atmosphere
or is directed to an emission control device.
     The 40 percent maleic acid (Stream 6) is dehydrated by azeotropic
distillation with xylene.  Any xylene retained in the crude maleic anhydride
(Stream 9) is removed in a xylene stripping column, and the crude maleic
anhydride (Stream 10) from this column is then combined with the crude maleic
                                          18
anhydride from the separator (Stream 4).
                                      1-8

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      Color-forming  impurities  in the crude maleic anhydride are removed by aging,
 which causes  impurities to polymerize.  After aging, the crude maleic anhydride
(Stream 11) is fed to a fractionation column which yields  purified molten  maleic
anhydride as the overhead  product (Stream 12).   The fractionation  column bottoms
containing the color-forming  impurities are removed as  liquid  residue waste
(Stream 13).  This stream  is  either combined with other effluent or is fed to  a
liquid incinerator.    A small  percentage of the finished  product  is made
into briquets.
     The vacuum lines from the dehydration column, xylene  stripper, and
fractionation column are joined to the vacuum system (Stream 14).   The
refining vacuum system vent (Vent B) can exhaust to the atmosphere, recycle
to the product recovery absorber (Stream 5), or be directed to an emission
control device.  Water from the vacuum system can be recycled as make-up
                                                              20
water (Stream 7) or join the liquid residue waste (Stream 13).
     Essentially all process emissions will exit through the product recovery
absorber (Vent A).  These emissions will include any unreacted benzene, which
                                                     21
constitutes 3 to 7 percent of the total benzene feed.    The only other process
emission source is the refining vacuum system vent (Vent B), which can contain
small amounts of maleic anhydride, xylene, and a slight amount of benzene,
since benzene could be absorbed in the liquid stream from the product recovery
absorber (Stream 6) or in the crude maleic anhydride from the separator (Stream 4),
     Although the process just described and illustrated in Figure  1-2 is
typical for the benzene oxidation process, there are variations.  In place of
the partial condensation system (cooler, partial condenser, and separator) shown
in Figure  1-2, a so called switch condenser system can be incorporated.
                                      1-9

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This utilizes a series of condensers which are alternately cooled to
freeze maleic anhydride on the surface and then heated to melt the maleic
anhydride for pumping to crude maleic anhydride storage.  Switch Condensing
can remove up to 60 percent of the maleic anhydride from the process compared
                                                  22
to 40 percent for the partial condensation system.    The removal  of this
additional maleic anhydride would allow the size of the product recovery
absorber to be reduced and would slightly reduce the maleic acid loss
through the product recovery absorber (Vent A).
     Xylene is the only known azeotropic agent currently being used for
dehydration.  Several other agents can be used, including isoamyl  butyrate,
                                        23
di-isobutyl ketone, anisole, and cumene.    Further, a .vacuum evaporation
system, which replaces the dehydration column and xylene stripper, is used
by at least one plant to remove water and dehydrate the maleic acid to form
maleic anhydride.    Since an azeotropic agent is not required in that case,
xylene is eliminated as a process emission.
     The emission rates for the benzene oxidation process are based on a
model plant with a capacity of 22,700 Mg/yr (50 x 106 Ib/yr), based on 8000
annual hours of operation.  Though not an actual operating plant, it is
typical of most plants.  The model benzene oxidation process, shown in Figure 1-2,
best fits today's maleic anhydride manufacturing and engineering technology.
Single-process trains as shown are typical for the large plants except in the
reaction area where multiple reactors are common.  The model process uses
partial condensation and azeotropic distillation with xylene.
                                      1-10

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     The emission rates and sources for the benzene oxidation process are
summarized in Table T-3.
     a.  Main Process Vent
         The largest vent is the main process vent from the product recovery
absorber (Vent A, Figure 1-2).   All plants have this vent.  The emissions
are influenced by the excess air fed to the reactor to maintain the benzene
concentration below the explosive limit.  The composition of this stream for
the model plant is shown in Table 1-4.  The majority of the unreacted benzene
is contained in this stream.  A small amount of benzene can be contained in
the vent stream from the refining vacuum system, although this had not been
quantified.
                                      1-11

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                                                      Table 1-3

                                           BENZENE AND TOTAL YBC EMISSIONS
                                            MALE1C ANHYDRIDE FROM BENZENE
                                             MODEL PLANT 22,70Q,Mg/Yr
                                                  UNCONTROLLED31


                                 Stream             Benzene   3    Total VOC  3
                               Designation         (kg/kg)xlO      (kg/kg)xlO          Benzene           Total VOC
   	Source	Figure 3-2	MA Produced     MA Produced	kg/hr	kg/hr

   Product Recovery
     Absorber                      A                  67.0             86.0              190                 244


   Refining Vacuum
     System                        B                  —               0.1              —                   0.28
ro
         Emission rates are annual averages at 8000 hours per year,

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                                   TABLE 1-4
      WASTE GAS COMPOSITION - PRODUCT RECOVERY ABSORBER
                             (Weighted Average)
                                                        25, 26, 27, 28
Component

Oxygen
Nitrogen
Carbon Dioxide
Carbon Monoxide
Water
Benzene
Maleic Acid
Formaldehyde
Formic Acid
Weight %

16.67
73.37
 3.33
 2.33
 4.00
 0.23
 0.01
 0.05
 0.01
Kg/Hr
13,800
60,740
 2,757
 1,929
 3,312
   190
     8
    41
	8
82,785
                                        1-13

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     Some  types of  process  upsets will result in more benzene being released, since
the product recovery  absorber can only remove benzene up to its solubility level
in water or aqueous maleic  acid.  These upsets can result in short duration
benzene and VOC emissions of three to five times normal.  Process startup
also results in temporary benzene emissions three to five times normal be-
cause the benzene does not  react completely until proper catalyst temperature is
reached, and again absorption is only effective up to the limits of
solubility.  Shutdown will  not  increase emissions because benzene is shut off
as the first step in the shutdown procedure.  This immediately reduces the
                                                    29
level  of unreacted benzene  emitted from the reactor.
     b.   Refining Vacuum Vents
         The refining vacuum system vent (Vent B, Figure 2) exhausts the
noncondensibles from the three vacuum columns used to dehydrate and
fractionate maleic anhydride.  The VOC emissions will be maleic acid, xylene,
and possibly benzene, and are estimated to be relatively small as
indicated in Table 1-3.  Process upsets, startups, and shutdowns do not affect
the VOC emissions from this vent.
     c.   Other Emission Sources
         Descriptions of fugitive emissions, storage and handling emissions,
and secondary emissions of  benzene are covered in another document.
1.2.2  n-Butane Oxidation Process
     There is very little information in open literature on maleic anhydride
production by the oxidation of n-butane as currently practiced in the United
States.   Thus, it is particularly difficult to assess the economics and efficiency
of this process relative to the conventional benzene oxidation process.  At this
                                      1-14

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7 09
2 Z

oxygen

0
li
H-C-C
* M ** Q
H-C-C " u
8
maleic
anhydride


+ 4H00
2

water

time, the viability of this process may not yet be established.  Very general
information on n-butane oxidation is summarized below, although it may not
accurately represent the process as practiced today by Monsanto and Amoco.
     The chemical reaction of interest is:
      CH3-
          n-butane

The reaction involves both dehydrogenation and oxidation.  The actual
catalysts used today have not been reported, although several possibilities are
listed in Hydrocarbon Processing.  One is a mixture of iron and vanadium
pentoxide - phosphorous pentoxide on a silica-alumina support.  Proportions are
not specified.  The reaction proceeds at 500°C and atmospheric pressure and
results in a yield of 14.2 mole percent.  Another scheme uses a cerium chloride,
cobalt-molybdenum oxides catalyst supported on silica.  The cerium chloride
dehydrogenates the butane to butene; the cobalt-molybdenum oxide catalyst then
oxidizes the butene to maleic anhydride.  The reaction is carried out at 490°C and a
yield of 63 weight percent was reported.  A third catalyst system has been reported
which uses phosphorous and vanadium.  Yields are reported to be 55 percent to
           32
60 percent.    The actual catalyst used by the two domestic producers of maleic
anhydride from n-butane, Monsanto and Amoco, has not been reported.  The catalyst
is certainly different from that used in the benzene oxidation process.  Further,
catalyst development research is actively continuing and the catalyst technology
is a closely held secret.
                                      1-15

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     The process flow diagram for maleic anhydride production from n-butane
is believed to be quite similar to the benzene oxidation process, which was
shown previously in Figure 1-2.  One obvious major difference is in the raw
material storage facilities, since the n-butane is a gas at atmospheric conditions
and will normally be stored as a liquid in pressure vessels at ambient temperature.
A simplified flow diagram from one producer indicates that the butane oxidation
process is very similar to the benzene oxidation process.  Like the benzene
process, product recovery is by partial condensation, product absorption,
dehydration, and fractionation.    There is further indirect evidence to support
the assumption that it is analogous to the benzene process.  First, Ashland
Chemical, which started up a new benzene based plant in 1976, claims to be able
to convert to n-butane feed simply with a change in catalyst.    Second, it has
been reported that the switch to n-butane feed can be accomplished at a relatively
small fraction of the cost of a new plant.    This implies that for the most
part the same unit operations are used after the reaction module and in equip-
ment of similar design and capacity.
     On the other hand, there is evidence that there are some process differences
between the benzene and the n-butane process.  The n-butane process is said
to require a longer reaction residence time and therefore bigger reactors.
This means that a higher capital investment is required for the n-butane process,
although there are no data upon which to estimate the increase in capital cost.
For an existing benzene-based plant, unless the reactors were replaced with
larger equipment the production capacity would be decreased.  Further, the
composition of the stream from the reactors is likely to be different in
                                                                             37
the n-butane process, even though many of the same compounds will be present.
For this reason, one would expect some variations in the design and operation
                                                                             38
of the product recovery and refining steps for a new plant based on n-butane.
The impact of this on the efficiency of a converted facility is not well known,
but could be a significant problem.   Quoting from  Chemical Week:
                                  1-16

-------
     One producer notes that the advisability of building new butane-
     based capacity vs. converting old benzene-based capacity to butane
     is "one of these questions not yet answered." 9
It has been reported that the benzene oxidation process can be converted to n-butane
oxidation by changing the catalyst system and that this conversion can be done
for much less than the cost of a new plant.    However, according to one source,
a switch in feeds for an existing facility would require a major investment for
new catalyst.    Further, the overall yield in converted plants will probably
not be as high as in new plants designed specifically for n-butane; this lowered
efficiency might be serious enough to warrant other major design changes.     » 3
     There are no benzene emissions from the n-butane oxidation process.  One
reference reports that other VOC emissions should not differ to a great extent
                                   44
from the benzene oxidation process.    Preliminary data from another source
indicate that VOC emissions from this process may be twice those from the
                45
benzene process.

1.2.3  Byproduct of Phthalic Anhydride Production
     Phthalic anhydride is manufactured from naphthalene and ortho-xylene.
                                                                      4fi
Maleic anhydride is recovered as a by-product from the plant effluent.^*  The
emissions associated with maleic anhydride recovery are believed to be
insignificant and are not being investigated at this time.  There are no benzene
emissions from this recovery process.  In addition, no growth in the production
of maleic anhydride by this process is expected.
1.2.4  Foreign Processes
     The only significant foreign deviation from benzene oxidation for maleic
anhydride production is a process using feedstocks of 65-80 percent n-butenes
with the remainder mostly butanes or isobutene (mixed C^ oxidation).  The
general process description is very similar to that shown in Figure 1-2 for
                                  1-17

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                                                  4 7 4fi
benzene oxidation  and,  therefore,  is not repeated.  />no  The exhaust from the
main process vent  contains  unreacted butane, butene, carbon monoxide, and various
secondary products.  Except for the absence of benzene, the VOC emissions should
                                                       40
be about the same  as for the benzene oxidation process.
     The most significant process variation is the use of a fluidized
catalyst bed rather than a  fixed bed and was developed for the mixed-C. process.
This provides good temperature control  within the bed and, thus, allows optimum
ratios of feed to air.  In  contrast, optimum feed to air ratios cannot be used
with fixed bed systems because temperature cannot be precisely controlled, and
therefore excess air becomes necessary to stay below the explosive range.  The
reduction of excess air in  the fluidized bed feed will reduce emissions from
the product recovery absorber.  However, this advantage is offset by the lower
product yields with the fluidized bed than with the fixed bed..
1.2.5  Summary
     This chapter has described the processes and associated emissions for
four routes to the production of maleic anhydride.  The benzene oxidation
process was emphasized, since it is the only one from which benzene can be
emitted.  Two process emission points were discussed:   (1) the product recovery
absorber vent, and (2) the  refining vacuum system vent.  Only the process
emissions were discussed; emissions of benzene from fugitive sources, storage
and handling, and secondary sources will be addressed  in another document.
     The n-butane oxidation process was discussed to the extent that
available data permitted.   It may replace benzene oxidation in the future,
although its viability  is  in question.
                                      1-18

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  1.3  REFERENCES
  1.  Blackford, J. C., CEH Marketing Research Report on Maleic Acid.  July,  1976.
     Chemical Economics Handbook, Stanford Research Institute, Menlo Park,
     California.
  2.  Unpublished EPA Survey and Ranking Information, Emission Standards and
     Engineering Division, Research Triangle Park, North Carolina , 1977.
  3.  Ibid.
  4.  Blackford, Op. Cit.
  5.  Unpublished EPA Survey and Ranking Information, Op. Cit.
  6.  Technical Week, European Chemical News, April 5, 1974.
  7.  Blackford, Op. Cit.
  8.  "Maleic Builds New Bridges to Feedstocks," Chemical Week, October 13,  1976,
     pg. 79.
  9.  Blackford, Op. Cit.
10.  Ibid.
11.  Hewett, P. S., Reichhold Chemicals, Personal communications with D. R. Patrick,
     U.  S. EPA, March 27,  1978.
12.  Lenz, D. and M. Oe Boville, "The Bayer Process for the Production of Maleic
     Anhydride from Butenes," Rev. Assoc.  Fr. Tech. Pet., Volume 236, No. 20-3,
     p.  17 (1976).
13.  Shinji, Vemura and Kamimura Shiego,  "Production of Anhydrous Maleic Acid
     from C^ Distillate, "Petroleum Academic Association Journal, Volume 16,
     No. 8 (1973).
14.  Blackford,  Op.  Cit.
15.  Ibid.
16.  Lawson, J.  F.,  Maleic Anhydride - Product Report (draft), Hydroscience,  Inc.
     unpublished report under EPA contract no. 68-02-2577, March, 1978.
                                     1-19

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17.  Blackford, Op. Cit.
18.  Ibid.
19.  Ibid.
20.  Ibid.
21.  Lewis, W. A., Jr., G. M. Rinaldi,  and T.  W.  Hughes,  "Source  Assessment:
     Maleic Anhydride Manufacture,"  (draft report),  Monsanto  Research  Corporation,
     EPA Contract No. 68-02-1874.
22.  Lawson, J. F., Trip Report for  visit to Reichhold  Chemicals, Inc.,
     Morris, Illinois, July 28, 1977,  Hydroscience,  Inc.,  under EPA
     Contract No. 68-02-2577.
23.  Blackford, Op. Cit.
24.  Lawson, Op. Cit. (reference 22).
25.  Morse, P. L., "Maleic Anhydride"  November,  1973.   Process  Economic  Program.
     Stanford Research Institute, Menlo Park,  California.
26.  Lawson, Op. Cit. (reference 22).
27.  Pervier, J. W., et. al, Survey  Reports on Atmospheric Emissions from the
     Petrochemical Industry. Volume  III. Houdry Division  of Air Products, Inc.,
     EPA-450/3-73-005-C, U.S. EPA, Office of Air Quality  Planning and  Standards,
     Research Triangle Park, North Carolina, April,  1974.
28.  Reference  16, Op. Cit.
29.  Lawson, J. F., Hydroscience, Inc., Personal communications with
     G. R. Wood, Monsanto Chemical Company, October 20, 1977.
30.  Pervier, Op. Cit.
31.  Reference  29, Op. Cit.
32.  Hydrocarbon Processing, November, 1977, page 335.
                                   I -20

-------
33.  Lawson, J.F., Trip Report for visit to Amoco Chemicals Corp.,
     Chicago, Illinois, January 24, 1978, Hydroscience, Inc., under
     EPA Contract No. 68-02-2577.
34.  "Maleic Makers Build on Hopes for Polyester," Chemical Meek. February 2, 1977.
     pg. 37-38.
35.  Ibid.
36.  Reference 8, Op.Cit.
37.  Ibid.
38.  Pierle, M.A., Monsanto Chemical Intermediates Co., Personal
     communication with D.R. Patrick, U.S. EPA, March 22, 1978.
39.  Reference 34, Op.Cit.
40.  Ibid.
41.  Reference 8, Op. Cit.
42.  Ibid.
43.  Reference 34, Op. Cit.
44.  Reference 21, Op. Cit.
45.  Reference 33, Op. Cit.
46.  Blackford, Op. Cit.
47.  Reference 12, Op. Cit.
48.  Reference 13, Op. Cit.
49.  Reference 21, Op. Cit.
50.  Reference 6, Op. Cit.
                                      1-21

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                     2.0  EMISSION CONTROL TECHNIQUES
2.1  ALTERNATIVE EMISSION CONTROL TECHNIQUES
     This chapter addresses the control techniques that can be applied and the
emission reductions that can be achieved for each of the sources of benzene
identified in Chapter 1.
     The control techniques that can be applied to reduce benzene emissions
from maleic anhydride manufacturing facilities fall into two classes:
     1.  Add-on control  devices such as adsorbers or incinerators.
     2.  Change in the feedstock to eliminate benzene from the process, to
the extent that it is technically feasible.
     For add-on control  devices, it is assumed that the product recovery
absorber vent and the refining vacuum system vent can be controlled by the
same device.  Only piping additions are required for controlling the refining
vacuum system along with the product recovery absorber, and no added utilities,
manpower, or other operating costs are involved.  Emissions from the refining
vacuum system vent are included in all control system calculations.  The
control devices described here are applicable to the waste gas streams defined
in Chapter  ].  Further,  it is expected that add-on control devices will be
able to control the process vents during upset conditions (as discussed in
Chapter  1) with no increase in emissions.
 2.1.1   Carbon  Adsorption
      Carbon adsorption  systems  have often  been  applied  in other industries to
 control  waste  gas streams  carrying VOC for similar applications,  e.g., with
 inlet organic  concentrations  ranging from 1  ppm to 40 volume percent and  at
                                 2-1

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 air  flow  rates  of  10  cfm  to  over  200,000 cfm.   General  discussions of  the
 theory  and  application  of carbon  adsorption can be found elsewhere.2»3»4
        Adsorption onto activated carbon can be used to  recover benzene from
 the  product recovery  absorber and refining vacuum system vent gas.  Two plants
 currently use a carbon  adsorber system to control the product recovery
 absorber.   To  use carbon adsorption in this service, the exhaust gas stream
 should be scrubbed with a caustic solution to remove organic acids and
 water-soluble organics.   Benzene  is likely the only VOC  remaining in
 appreciable quantity  after scrubbing.  The stream should then be conditioned to
 reduce the relative humidity.  This is necessary to improve adsorption
 efficiency, particularly  loading  capacity.
     Various levels of control can be achieved with carbon adsorption, depending
on the design and operation of the adsorber system.  Nearly 100 percent
reduction of hydrocarbon  emissions can be accomplished.   Factors influencing
the efficiency of carbon  adsorption systems for benzene control in maleic
anhydride plants include:   (1) the relative humidity of the incoming waste
gas stream, (2) the presence of other organic compounds which may interfere
with benzene adsorption or which may form polymeric materials on the carbon
beds thereby decreasing capacity, (3) the temperature of the beds during
adsorption, (4) the efficiency of the steam regeneration, and (5) the dryness of
the bed when put back on  line.7'8  A preheater is required to lower the
relative humidity, since  the stream normally is saturated with water.  A
caustic scrubber will remove most of the other organics  in the stream, therefore
preventing the second problem.  Thus, both a heater and a caustic scrubber
should be included in a carbon adsorption system for this application.  In general,
a system of two or more carbon beds are used.  The gas stream containing benzene
passes through one or more beds in parallel and the benzene is removed from the
gas stream.  At the same  time, the other bed is being regenerated with low
                                   2-2

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pressure steam.  The steam and benzene are condensed and then decanted.  The
benzene returns to the process and the aqueous layer can be combined with the
other liquid waste from the plant or recycled to the process.  After regeneration,
the  carbon bed is hot and saturated with water.  The bed is usually cooled and
dried, often by blowing organic-free air through the bed.  The bed size, number
of beds, and cycle times can be varied to achieve the desired removal efficiency.
Finally, since the system may be exposed to corrosive compounds, stainless steel
vessels are required.  Specific systems which can achieve various removal effi-
ciencies are discussed in section 2.2.1.  A carbon adsorption system, however,
will not remove carbon monoxide, which is also present in the waste gas from
the  product recovery absorber.
2.1.2  Thermal  Incineration
     Thermal  incineration, also called direct-fire incineration, can be used
to control  the emissions from maleic anhydride manufacture.  Three plants in
the United States use a thermal incinerator on the product recovery absorber vent;
                                                                            9 10
one uses n-butane while the other two of these use benzene as the feedstock. '
                                                                   11 12
General information on thermal incineration can be found elsewhere.  »    Because
of the cost of the fuel required to operate  a thermal incinerator, heat recovery
is generally used.  The recovered heat can be used to either preheat the feed to
the  incinerator or to generate steam,,  In general, some of the factors which
influence the efficiency of incineration are:  (1) temperature, (2) degree of
mixing, and (3) residence time in the combustion chamber.
     For maleic anhydride plants, a knockout demister tank is required to
prevent liquid droplets from reaching the burner area.    Supplemental fuel
is required to maintain the necessary combustion temperatures.  Supplemental
combustion air may also be required, if the incoming gas stream is not preheated.
Because the gas stream to the incinerator contains corrosive materials, the
                                    2-3

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equipment ahead of the  combustion chamber must be made of stainless steel.
Specific incineration systems and their removal efficiencies are described in
section  2.2.2.
 2.1.3  Catalytic  Incineration
     Catalytic incineration can be used as an alternative to thermal incineration
of a waste gas stream.  The catalyst allows oxidation to occur more rapidly at
a lower temperature, thereby decreasing supplemental fuel consumption.  One
maleic anhydride  producer is using a catalytic incinerator to control emissions
from the product  recovery absorber.    Reduced catalyst life because of fouling or
poisoning can be  a problem with catalytic incinerators.  This is a problem
with maleic anhydride plants, since some of the components of the gas stream
may polymerize.    The maximum practical VOC removal efficiency for catalytic
incinerators is reported to be less than 95 percent.    The large catalyst volume
or high temperatures necessary to achieve removal efficiencies higher than 95 percent
tend to make this system uneconomical for this service.
2.1.4  n-Butane Process Conversion
     Since the n-butane oxidation process has no potential benzene emissions,
conversion of benzene based plants to n-butane as the feedstock can be considered
a control technique for the reduction of benzene emissions from maleic anhydride
manufacture.  The process and emissions were discussed in Chapter 1.  Factors
influencing the conversion of benzene capacity to n-butane capacity were also
discussed in Chapter 1.
2.2  PERFORMANCE  OF EMISSION CONTROL TECHNIQUES
2.2.1  Carbon Adsorption
     Based on engineering experience with similar applications for the control
of VOC, a carbon  adsorption system can be designed and operated at a sustained
removal efficiency of 99.5 percent.18  This efficiency reflects optimum control
                                   2-4

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 of temperature,  pressure,  humidity,  and the level of other organics.  Carbon
 adsorption systems operating at different levels of control will be described
 in this section.  The first system,  at 99.5 percent control of benzene, is
 based on engineering design calculations and previous engineering experience.
 The  other systems  described  here are based on  the experience of  existing
 maleic anhydride facilities. One  1 s_.repprtedjby the company to  achieve an average
of only 85 percent control  of benzene while the actual efficiency of the other is
                   in
not yet determined.
      As discussed  in section 2.1.1,  several  key factors influence the efficiency
 of the adsorption  system,  and optimum  control  of these factors is responsible
 for  99.5 percent reduction of benzene  emissions.  To control the level of other
 organics in the  stream and to decrease the relative humidity,  the carbon
 adsorption system  uses a caustic scrubber and  a heater before  the carbon beds.
      The size  of the activated  carbon  adsorbers is determined  by two factors -
 the  superficial  velocity through the bed and the carbon requirements as determined
 by the flow of adsorbable  species  and  the carbon loading for each species.  The
 superficial velocity is important  because it affects the pressure drop
 through the bed.  The usual  acceptable range for superficial velocity is 25-51  cm/sec
 which gives a  pressure drop of  25-66 cm H20/m bed.  The air
                                                             •a
 flow rate to the carbon adsorber system is approximately 21 nT/sec.  Assuming a
 superficial velocity of 38 cm/sec, the required cross-sectional  area is about
 55m2.  Since adsorbers this large  are  usually horizontal tanks,  two tanks 3 m
 diameter x 9 m long  operated in parallel would give the required cross-sectional
 area.
      To allow  enough time  for regeneration,  additional adsorbers would be
 necessary.  For  this system, two additional  adsorbers were chosen instead of one
 for added assurance  that >99 percent removal could be achieved.   Also, some
 experience from  one  adsorber system  in this application suggests there is not
                                   2-5

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sufficient  time to  complete  the regeneration cycle (including the cooling
and drying  cycle) and  thereby prevent breakthrough when only three beds are
used.20
     The amount of  carbon put in the adsorber is determined by the desired
cycle time, flowrate of adsorbable species, and the carbon loading.
Although shorter cycle times have been used, a two-hour loading cycle was
chosen initially to allow a one-hour steaming cycle plus another hour to cool
and dry the carbon  in preparation for adsorption service.  The amount of carbon
per adsorber can be calculated by:
     kg carbon _ 190 kg Bz   2 hr    1 kg carbon     1
     bed cycle      hr     x cycle   O.Ob kg Bz  x 2 beds
        carbon        ,
                      kg
     bed cycle
     Volume of carbon = 3200 kg x    m3    = 7.1 m3
                                   448 kg
The depth of the carbon required to give a two-hour loading cycle is 25 cm in the
adsorbers selected.  Thus, in this case, the size of the adsorber is dictated
more by the total flowrate than by the carbon requirements.  Since the
incremental cost of putting more carbon in the adsorbers is small, a carbon
depth of 61 cm was used.  Each adsorber would now hold 17 m  or 7620 kg of
carbon.  Using the same carbon loading and benzene flow as before now gives
an adsorption cycle of 4.8 hours.  This should allow enough adsorption capacity
to prevent premature breakthrough while the companion bed is being regenerated.
     A loading of 0.06 kg Bz/kg carbon has been selected based on capacity

                                                                          22
                                                               21
data reported by Hoyt Manufacturing (a carbon adsorber vendor).    This is also
similar to Reichhold's experience with a benzene adsorber in this service.
The loading selected is conservative because other data in the literature
show benzene loadings as high as 0.25 Ib Bz/lb carbon on successive cycles for
                                                   23
full-scale systems adsorbing benzene from town gas.    If higher loadings are
                                    2-6

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achieved, the loading cycle would be extended, giving still more time for
regeneration and cooling and drying.
     There is some indication that the relative humidity of the vent stream can
affect the loading capacity.  Hydroscience has observed a 75-80 percent  drop in
loading for some materials at a relative humidity of 80 percent as compared to
                             24 25
20 percent relative humidity.  '    Similar data for activated carbon is
reported by Rohm and Haas in their technical bulletin on Ambersorb Carbonaceous
       2fi
Resins.    It is important to note, however, that changes were noted only in
the loading capacity and not the ability to achieve a baseline outlet concentration
                27
of <5 ppm (v/v).
     For regeneration of the carbon beds, the amount of steam required has been
chosen as 20 kg steam/kg Bz.  This should be adequate to complete the desorption
since steam requirements of as low as 3 kg steam/kg toluene have been quoted in
               28
the literature.    Some flexibility is available in selecting the duration of
the steaming cycle.  The steaming easily can be completed in one hour or less
if the condensing capacity exists.  For a new installation it is best to size the
condenser to handle the steam flow equivalent for at least a one-hour steam cycle
as an additional safety factor.  The average steam flow of 1.1 kg/sec (for
calculating annualized costs) is determined from the average benzene flow and
the steam-to-benzene ratio.
     An important part of the total operation is the cooling and drying sequence.
If the bed is not properly cooled and dried, both poor efficiency and lower
adsorption capacities will  result.  Note that this is in contrast to the previously
discussed effect that the relative humidity of the inlet gas has on loading
capacity and efficiency.  The full-scale experience with benzene adsorbers at
one facility where cooling  and drying are not practiced shows that there was
an initial spike of benzene in the outlet immediately after the hot bed
                    29
was put back online.      In addition to this initial spike, the
                                   2-7

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instantaneous removal was rarely better than 97 percent.  These data
are consistent with the observations that poor efficiency and reduced loading
capacity occur when the adsorber is not properly cooled and dried following a
steam regeneration.  In order to achieve greater than 99 percent removal, the
bed must be cooled and dried.  In addition, the exhaust from the cooling and drying
cycle must be recycled to a carbon bed which is in the adsorption mode,  This means
that the adsorbers must be sized so there is enough capacity to handle the
additional benzene and air flow as well as time to complete the cooling and
drying cycle.  The data from one facility show that the cooling and drying
period lasted about 15 minutes and that about 1 to 3 percent of the benzene in
the feed left the system during this period.30  If the worst case of 3 percent
is used, the calculated adsorber duty would be 197 kg/hr instead of 190 kg/hr.
The calculated time to breakthrough (at a loading of 0.06 kg Bz/kg carbon) would
only be reduced from 4.8 hours to 4.65 hours.
     The effect of total flowrate on efficiency and pressure drop through the
online adsorber is more critical than the recycle of some adsorbed benzene, since
outside air must be used for drying.  The vent itself is not suitable for
drying  (even though the relative humidity of the vent downstream of the
scrubber is reduced from 100 percent relative humidity  to ^50 percent relative
humidity by the preheater).    For design purposes, a cooling and drying
cycle of one hour  at a flowrate equivalent to one-fourth to one-half of
the flowrate during the adsorbing  cycle was  chosen.   This would  raise  the super-
ficial  velocity for the adsorbing  carbon bed  from  38 cm/sec  up  to  49-57 cm/sec
during the cooling and drying cycle, but would not create an excessive pressure
drop.  Since two beds could be cooling at once, the blower has been sized to
deliver 21 m3/sec.  A capital savings could be achieved if a blower was sized at
11 m3/sec.  However, it is believed that the additional capital cost of the
larger blower is justified to give added flexibility to the operation of
the adsorption system.  Pertinent details of the system designed to achieve
                                   d-ti

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99.5 percent control of benzene are in Table 2-1.  The costs for  systems of this
type are presented for each plant in Chapter 5.

                                 Table 2-1
         Technical Data - Carbon Adsorption System (99.5% control)

         No. of beds                                      4
         Wt. of carbon per bed                         7620 kg
         Loading cycle time                               5 hours
         No. of stacks                                    2
         Benzene emission rate per stack                 0.13 g/sec
         Air flow rate from system (per stack)          18.0 m3/sec

     Two plants currently use a carbon adsorption system to control benzene from
the product recovery absorber vent.  The system at one plant for which data are
available is reported by the plant to have achieved a sustained benzene removal
                              32
efficiency of only 85 percent,.    Preliminary results of tests conducted by the
EPA showed a mean benzene removal efficiency of about 95 percent (90 percent
confidential interval of 92 to 98 percent ).33  However, the plant was operating
at only about 40 percent of full capacity when tested. Pertinent technical  data
on that system are summarized in Table 2-2.
                                  Table 2-2
          Technical Data  - Carbon Adsorption System  (85%  control)
          No.  of  Beds                                       3
          Loading cycle time                                2 hours
          Regeneration cycle  time                           1 hour
          No.  of  stacks                                     1
          Air  flow rate from  system3                       20.3 m  /sec
          a at capacity
                                   2-9

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This system does not use an organic-free gas stream to cool and dry the beds
after regeneration with steam.  Immediately after regeneration the waste gas
stream containing benzene is directed to the hot bed.  Consequently, until the
bed cools and dries, benzene removal efficiency is very low.  This partially
accounts for the low overall benzene removal efficiency.
      The third system was designed for a benzene removal efficiency of 98 percent,
although there are currently no reliable data upon which to estimate its performance.
The system can be expected to show better performance than the one discussed
                                                                                  34
previously, because the beds are cooled and dried with air after steam desorption.
Pertinent technical data on this system are in Table 2-3.

                                 Table 2-3
         Technical Data - Carbon Adsorption System (98% control at design)
         No. of beds                                2
         Loading cycle time                         6 hours
         Regeneration cycle time                    1.5 hours
         Cooling and drying cycle time              0.75 hours
         No. of stacks                              2
         Waste gas flow rate a                      11.3 m /sec
                                                          3
         Cooling air flow rate                      11.3 m /sec
         Wt. of carbon per bed                      15,900 kg.
         a at capacity
 2.2.2  Thermal Incineration
      Based on engineering experience with similar applications for the control
 of VOC, a thermal incinerator can be designed and operated at a sustained removal
 efficiency of 99.5 percent.3   There is limited information on direct-flame
 afterburners used on maleic anhydride production facilities, but there are
 several cases in which streams similar to the product recovery absorber and refining
 vacuum system vent gas have been controlled at very high efficiencies.  In one
 case, data reported for toluene indicate a destruction efficiency of 99.9 percent

                                      2-10

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  at  766°C  and  a  residence  time  of 0.21  sec.     Another facility is  incinerating
  a toluene-xylene  fume  at  760°C (1400°F)  and  is reported  to  achieve a destruction
  efficiency  of 99.1  percent.37   A third installation  reports a destruction efficiency
  of  greater  than 99.8 percent at 760°C  for an organic stream considered as toluene.38
  Finally,  a  review of several case  studies indicates  that low combustion efficiencies
  of  less than  95 percent were achieved, except in  one case,  at temperatures of
  730°C  or  lower.  Conversely, high  efficiencies of 99 percent plus  were achieved
  at  temperatures of  760°C  or greater.39
      Research data on a fume incinerator also  indicate high  removal  efficiencies
 for similar streams.  With a toluene-contaminated  gas, it was  found  that  approximately
 99 percent destruction efficiency was  achieved  at  760°C  and  a  residence time
of 0.33 sec.    As the temperature was  increased to 816 C, the efficiency
increased to 99.5 percent.
      Recent laboratory studies on the thermal incineration of benzene also
show very high destruction efficiencies.     With a detection limit of 2 ppmv, no
benzene was found at temperatures above 790°C with residence times as low as
0.08 seconds.  Based on that research, a thermal oxidizer with a residence
time of 0.5 seconds would require a temperature of 750°C for 99.9 percent
destruction of benzene.  In addition, those researchers found the destruction
of benzene to be highly temperature dependent.
      One plant controls the emissions from the product recovery absorber
routing the waste gas steam to a waste heat boiler.    That system is reported
to achieve a benzene removal efficiency of greater than 99 percent, with the
benzene concentration in the stack of less than 10 ppmv.  The temperature is
about 1090°C, and the residence time at design rate is 0.6 seconds.  A waste
heat  boiler,  however, is only a viable option when the facility has a need for
the additional  steam.
                                     2-11

-------
     Based on both the data from this maleic anhydride facility, and the data
discussed above on similar incinerator systems, it is expected that a removal
efficiency of 99.5 percent for benzene can be achieved at 870°C (1600°F) in
a well-designed and operated incinerator.  Pertinent technical data are
summarized in Table  2-4
                                Table  2-4
           Technical Data - Thermal Incineration (99.5% control)
           Residence time                    0.5 sec.
           Temperature                       870°C
           Natural Gas (supplemental         0.435 nr/sec
                        fuel)
           Supplemental Combustion           1.24 kg/sec
            air
     A temperature of 870°C (1600°F) is specified to ensure complete combustion
of the waste gas.  While it is possible that greater than 99 percent VOC
removal can be obtained at lower temperatures, it cannot be dependably predicted.
The conditions of Table 2-4 are consistent with various air pollution engineering
manuals.  *    While the manuals do not provide data on combustion temperatures
above 800°C, extrapolation of the data presented combined with the similar
incineration experience described above supports the projection of greater than
99 percent removal at 870°C.  The costs for systems of this type are presented
in Chapter 5 for each maleic anhydride plant.
     A second plant uses a thermal incinerator on this stream operating at
760°C with a residence time of 0.7 second.4   Total hydrocarbon destruction
efficiency has been reported to be at least 93 percent, although the company
has no data on benzene removal efficiency.  Tests  conducted by the  EPA  showed
a mean benzene removal  efficiency of 98.6 percent  (90 percent  confidence
interval of 98.5 to 98.7 percent).46'47  Although  the plant  was operating
at about 70 percent of capacity when the sampling  was conducted,  the plant
personnel did not think the lower production rate  would seriously affect the
validity of the results when applied at full capacity.   Pertinent technical
data are summarized in Table 2-5
                                  2-12

-------
                           Table 2-5
             Technical Data - Thermal Incineration
        Residence time                      0.7 second
        Temperature                         760°C
        Natural gas  (supplemental fuel)a    30 m /sec
        Supplemental combustion aira        6.5 kg/sec
         a when tested by EPA48
This incinerator is also used to generate steam, with a steam production rate of
                                  AQ
about 7 kg/sec during the testing.
2.2.3  Catalytic Incineration
     There are no VOC removal data available on the catalytic incinerator
used by one maleic anhydride producer.  However, as discussed in section  2.1.3,
the maximum practical VOC removal efficiency reportedly is less than 95 percent
for catalytic incinerators.
2.2.4  n-Butane Process Conversion
     Since there are no benzene emissions from this process, the conversion
of a benzene-based plant to a butane-based plant achieves 100 percent control of
benzene from maleic anhydride production.  However, there are very little data
available on the technical difficulties associated with this conversion.  The
butane process, if uncontrolled, is a significant source of VOC and CO, as
discussed previously in Chapter 1.  The estimated costs of this control technique
   ^in Chapter 5.
                                 2-13

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 2.3  REFERENCES
 1.   Wayner,  N.  J.,  "Introduction  to  Vapor  Phase Adsorption Using Granular
     Activated Carbon,"  Calgon Activated  Carbon Division, Calgon Corporation.
 2.   Hughes,  T.  W.,  et.  al.,  Source Assessment!:  Prioritization of Air
     Pollution from  Industrial  Surface Coating Operations, EPA-650/2-75-Ol9a,
     U.  S.  Environmental  Protection Agency, Research Traingle Park,
     North  Carolina   27711,  1975.
 3.   Hydrocarbon Pollutants  Systems Study.  Vol. L., Stationary Sources. Effects,
     and Control.  MSA Research Corporation, Report No. APTID-1499, U. S. Environmental
     Protection  Agency,  Research Triangle Park, North Carolina 27711, October, 1972.
 4.   Danielson,  J. A.,-(ed.),  Air  Pollution Engineering Manual, Second Edition,
     Publication No.  AP-40,  U.  S.  Environmental Protection Agency, Research
     Triangle Park,  North Carolina, May,  1973.
 5.   Lawson,  J.  F. Maleic Anhydride - Product Report (draft), Hydroscience, Inc.,
     unpublished report  under  EPA  contract  no. 68-02-2577, March, 1978.
 6.   Lewis, W. A., Jr.,  et.  al., Source Assessment:  Maleic Anhydride Manufacture,
     (draft report), Monsanto Research Corporation, EPA Contract No. 68-02-1874.
 7.   Ibid.
 8.   Parmale, C. S., Hydroscience, Inc.,  Personal  communications with L. B. Evans,
     U.  S.  EPA,  May  4, 1978.
 9.   Reference 2, Op. Cit.
10.   Twaddle, Warren W., Olson, Charles,  and Kramer, Karen L., "Heat Recovery
     Incineration of Organic Emissions Saves Amoco $970,000/yr in Fuel Costs"
     Chemical Processing, January, 1978.
11.   Reference 5, Op. Cit.
12.   Reference 6, Op. Cit.
13.   Reference 2, Op. Cit.
                                    2-14

-------
14.  Ibid.
15..  Reference 6, Op. Cit.
16.  Ibid.
17.  Ibid.
18.  Reference 2, Op. Cit.
19.  Lawson, J. F.t  Trip Report for visit to Reichhold Chemicals,  Inc.,
     Morris, Illinois, July 28, 1977,  Hydroscience,  Inc.,  under EPA Contract
     No. 68-02-2577.
20.  Ibid.
21.  Reference 8, Op. Cit.
22.  Parmale, C. S., Hydroscience,  Inc.,  Personal  communications with
     A. L. Henry, Reichhold Chemicals, Inc., Morris,  Illinois, May 3, 1978.
23.  Smisck, M., and Cerny, S., Active Carbon.  Elsevier Publishing Company,
     1970, pg. 202.
24.  Reference 8, Op. Cit.
25.  White, R. E., Hydroscience, Inc., Personal communications with D. R.  Patrick,
     U. S. EPA, April 13, 1978.
26.  Rohm and Haas,  "Ambersorb Carbonaceous Resins,"  Technical Bulletin, August,  1977.
27.  Reference 8, Op. Cit.
28.  Ray Solv, Inc., Linden, N. J., Brochure dated October, 1976.
29.  Reference 19, Op. Cit.
30.  Ibid.
31.  Reference 8, Op. Cit.
32.  Reference 19, Op. Cit.
33«  Emission Testing at a Maleic Anhydride Manufacturing  Plant -  Reichhold
     Chemical, Inc.  Morris, Illinois (draft report),  Clayton Environmental
     Consultants, Inc., under EPA Contract No.  68-02-2817,  Work Assignment 2,
     April, 1978.
                                      2-15

-------
 34.  Weber, R.C..U.S. EPA,Trip Report for visit to Reichhold Chemicals,  Inc.,
      Elizabeth, New Jersey, July 5, 1978.
 35.  Reference 2, Op. Cit.
 36.  Rolke, R.W. et. al., Afterburner Systems  Study,  Shell  Development Company,
      EPA-R2-72-062, U.S. Environmental Protection  Agency, Office  of  Air  Programs,
      August, 1972.
 37. Reference 25, Op. Cit.
 38. Industrial Gas Cleaning Institute, Study of Heat Recovery Systems for
     Afterburners. Contract No. 68-02-1473, Task No. 23, U.  S. Environmental
     Portection Agency, Office of Air Quality Planning and Standards, August, 1977.
 39. Novak, R., Hydroscience, Inc., Personal communications with R. E, White,
     Hydroscience,  Inc., May 4, 1978.
 40,  Ibid.
 41. Lee, K., Jahnes, H.J., Macauley, D.C., "Thermal Oxidation Kinetics of
     Selected Organic Compounds", Union Carbide Corporation, paper presented at
     the 71st Annual Meeting of the Air Pollution Control  Association, Houston, TX,
     June 25-30, 1978.
 42. Lawrence, A. W., Koppers Company, Inc., Personal communications with D, R.  Goodwin,
     U. S. EPA, February 28, 1978.
 43. Reference 5, Op. Cit.
 44. Air Pollution Engineering Manual, U. S. Department of Health, Education and
     Welfare, 1967.
 
-------
48.  Weber, R.C..U.S. EPA,  Trip Report for visit to Denka Chemical  Corporation,
     Houston, Texas, April  20,  1978.
49.  Ibid.
                               2-17

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               3.0  ALTERNATIVE REGULATORY OPTIONS OR CONTROL LEVELS

     This chapter describes three alternative regulatory options or levels for two
emission points in maleic anhydride production facilities:  (1) the product recovery
absorber vent, and (2) the refining vacuum system vent.  The same control device can
be used to reduce emissions from both sources.
     For existing maleic anhydride production facilities, two control levels are
considered viable alternatives.  These options, and examples of applicable control
techniques, are:  (1) Benzene control efficiency of 99.5 percent, which can be
achieved by either thermal incineration or adsorption on activated carbon.
(2) Benzene control efficiency of 97 percent, which can also be achieved by carbon
adsorption or thermal incineration.
     The control devices, i.e., -incineration and carbon adsorption, can be designed
and operated at various levels of control efficiency.  The benzene control efficiency
of 97 percent was chosen to represent readily available control already demonstrated
on maleic anhydride facilities.  This level of control was chosen for study because
of uncertainty regarding the energy requirements of control devices operating at
99.5 percent removal  efficiency, which represents the state-of-the-art and is
and is based on technology transfer.
     As discussed in Chapter 1, there is still some uncertainty regarding the
viability of converting existing benzene based plants to facilities using n-butane
as the feedstock.  However, the technology for maleic anhydride production from
n-butane is likely near to full commercialization, as indicated by the new n-butane
based facility currently in operation.  Since projected growth rates for maleic
anhydride production indicate that no new capacity is needed before 1982, the use
of n-butane as a feedstock is considered viable for new facilities.  Therefore, a
viable regulatory approach for new maleic anhydride is to eliminate benzene by the
substitution of n-butane as the feedstock.
                                    3-1

-------
      The environmental, energy, and economic impacts of these alternatives
are presented in Chapter 4 and Chapter 5.
                                    3-2

-------
                  4.0  ENVIRONMENTAL AND ENERGY IMPACT
     The environmental  and energy impacts of each regulatory option or
control level presented in Chapter 3 will be discussed in this chapter.
Both beneficial  and adverse environmental impacts will be assessed,  The
two emission control options for existing plants are:
     1.  A removal efficiency for benzene of 99.5 percent by carbon
adsorption or thermal incineration.
     2.  A removal efficiency for benzene of 97 percent by carbon adsorption
or thermal incineration.
The emission control option.for new plants is the elimination of benzene by
substitution of n-butane as the feedstock.  Both primary and secondary impacts
of these alternative control systems will be discussed in the next sections.
4.1  AIR POLLUTION IMPACT
     This section addresses both the positive and negative effects on air
pollution from the application of the alternative emission control systems,
The emission rates from a model plant as defined in Chapter 1  are presented
in Table 4-1 for the following cases;
     1.  uncontrolled model plant
     2.  99.5 percent control by thermal incineration
     3.  99.5 percent control by carbon adsorption
     4.  97 percent control by carbon adsorption.
                                   4-1

-------
                                           Table 4-1
                           MAXIMUM ANNUAL AVERAGE BENZENE CONCENTRATIONS

1
Emission
Rate
Option (g/sec)

Combined
Maximum
Concentration
in ug/m3
Contribution of the
Process Vents to the
Combined Maximum
Concentration in
ug/m3
A.  Uncontrolled model
     plant
    53.1
35.5
                                                                                      31.2
^      B.  99.5% control by
            incineration
                                  0.26
                          20.7
                         0.00405
C.  99.5% control by  .
     carbon adsorption
0.13 (Stack A)
0.13 {Stack B)
20.7
                                                                                       0.0395
D.  97% control by carbon
     adsorption
     1.6
20.7
                                                                                       0.0317
  Storage, handling, and fugitive emissions are assumed to be uncontrolled in all cases.

  Only refers to emission rate from the product recovery absorber and vacuum system vent, or to
  the control device for these emission points.

  All sources.

-------
Also in Table 4-1 are the estimated ambient concentrations of benzene In the
vicinity of the model facilities, determined by atmospheric dispersion
modeling.
      The Industrial Source Complex (ISC) Dispersion Model was used to
evaluate the air quality impact of benzene emissions from the model
maleic anhydride plant.  The program was used to calculate the maximum
annual average benzene concentration resulting from each control option,
for both the combined emissions from all sources of benzene in the plant
as well as the concentration from the product recovery absorber and the
refining vacuum system vent (both uncontrolled and controlled).  These
are presented in Table 4-1.  The program also calculated the maximum
benzene concentrations from the combined emissions, for averaging times
of 1 hour, 3 hours (uncontrolled case only), 8 hours, and 24 hours.  These
data are in Table 4-2.
     The short term program (ISCST) was for the averaging times of 1,3,8,
and 24 hours.  The long term program (ISCLT) was used to calculate the
annual averages.  For the model features used in this study, the ISCST
program corresponds to the Single-Source (CRSTER) Model, modified to
include the effects of the separation of individual sources and the effects
of volume and area source emissions.  The ISCLT program, which is a sector-
averaged model similar to the Air Quality Display Model (AQDM) or the
Climatological Dispersion Model (COM), makes the same basic model assumptions
as the ISCST program.  The ISCLT program uses STAR summaries (statistical
tabulation of the joint frequency of occurrence of wind-speed and wind-direction
categories, classified according to the Pasquill stability categories) to
calculate annual average concentrations.  For the same source data and
                                  4-3

-------
                              Table 4-2

    MAXIMUM 1-HOUR,  3-HOUR,  8-HOUR, 24-HOUR AND ANNUAL AVERAGE
     BENZENE CONCENTRATIONS  PROIHJCED BY THE COMBINHU EMISSIONS
      FROM A MALEIC ANHYDRIDE PLANT AT ANY DISTANCE  DOWNWIND
             AND AT  0.1,  1.0,  10.0 AND 20.0 KlLOMr.TKRS
Distance
(km)

0.3
0.1
1.0
10.0
20.0

0.7

0.1

1.0
10.0
20.0

0.3

0.1
1.0
10.0
20.0

0.3
O.I
1.0
10.0
20.0

0.3
0.1
1.0
10.0
20.0
Concentration (lij;/m )
Option (a)
Option (b)
Option (c) Option (d)
(a) 1-Hour Concentrations
7.30xl02
6.26xl02
5.55xl02
8.10x10}
4.23x10
_
3.73xl02
4.20x101
1.96
1.03

3.73xl02
4.45\IOl
1.95
1.03

4.45x10?
5.34x10'
3.97
2.06
(b) 3-Hour Concentrations
5.44x10?,
2
2.80x10:;

4.54x107^
4.04x107
1.61x10
_

_

_
_
-


_

_
_
-


_

_
_
-
(c) 8-Hour Concentrations
3.67x10^

2.13x10,
2.48x107
2.18x10
8.20
_

1.55x10,
1.23x10
5.57x10 |
2.06x10
_

1.56x10,
1.36x10
5.67x10 [
2.07x10
—


1.91X101
1.09 T
4.02x10"'
(d) 24-hour Concentrations
3.30x10?,
1.46x10,
1.71x10
8.44
3.21
_
8.83X101
5.63
2.15x10 I
7.93x10

8.83x10
5.94
2.19x10 j
7.92x10

1 .00x10^
a. 77 T
4.22x10 i
1.56x10"'
(e) Annual Concentrations
3.55xlo}
2.12x107
2.18x10
1.21
4.39x10

2.07x10
1.03 -
3.05x10
1.07x10

2.07x10
1.09
3.06x10 ,
1 .07x10
~ i
2.07x10'
1.54 9
5.94x10",
2.11x10"^
cone, in ppmv = (0.000314) x cone,  in ug/nr  (at  25°C  and  1  atm)
                                 4-4

-------
meteorological data base, ISCLT calculates annual  average concentrations
that are equivalent to those obtained from ISCST using a year of sequential
hourly meteorological data.
     The dispersion estimates used a model plant with a capacity of 22,700 Mg/yr.
The layout of the emission points was assumed to be as in Figure 4-1.
The emission points are identified by name and number in Table 4-3.
Fugitive emissions and emissions from benzene storage were assumed to be
uncontrolled, and estimated emission rates were taken from reference 2; these
were 0.45 gm/sec, 0.05 gm/sec, and 0.22 gm/sec.for tank A, tank B, and
fugitive emissions.  These types of emissions will be covered in separate
documents, but were included here to illustrate the relative influence
of the product recovery absorber and refining vacuum system vents on the
ambient benzene concentration.
     A significant fraction of the maleic anhydride plants in the United
States are located in the Pittsburgh, Pennsylvania area.  Also, meteorological
conditions that maximize ground-level concentrations produced by emissions
from stacks of the type studied here (neutral stability in combination with
moderate-to-strong winds that persist within a narrow angular sector for
a number of hours) are common in the Pittsburgh area.  Surface and upper-air
meteorological data from the Greater Pittsburgh Airport were used in the
dispersion-model calculations for these reasons and because the data were
readily available.  It was assumed that the maleic anhydride plant was
located in the Pittsburgh urban area and ISC Urban Mode 2 was used in the
dispersion-model calculations to account for the effects of urban roughness
elements and heat sources.  Because of the high frequency of occurrence
of west winds in the Pittsburgh area, an east-west orientation was assumed
for the maleic anhydride plant (see Figure 4-1).
                                4-5

-------
-p.
I
en
                                        MALE1C ANHYDRIDE PLANT
INCINERATOR OR ADSORBER VENTS-^
I STORAGE PRODUCT
"X ® TAN KB RECOVERY
\ J2 SCRUBBER
1 80
J XI \ X4 *5
^ \
STORAGE
TANK A |
1
1 i ^^
9,10+12
XG \ X7
\
                                    N
                                            o = STACK SOURCES

                                            • = VOLUME SOURCES

                                            X = AREA SOURCES
r~
0
• i
10
20m
    Figure 4-l.L«iyout of  the malcic anhydride*  plant showinj; sourco lorntions.

-------
                      Table  4-3
IDENTIFICATION OF MODEL SOL1 KGE NUMBERS BY SOURCE
        NAME AND EMISSION CONTROL OPTION
Model
Source No.
1
2
3
4
5
6
7
8
9
10
11
12
Source Name
Benzene Storage Tank A
Benzene Storage Tank B
Fugitive Emissions (subarea source)
Fugitive Emissions (subarea source)
Fugitive Emissions (subarea source)
Fugitive Emissions (subarea source)
Fugitive Emissions (subarea source)
Product Recovery Scrubber
Incinerator Vent (with heat recovery)
Adsorber System Vent A
Adsorber System Vent B
Adsorber System Vent
(-.mission Control
Option(s)
All
All
All
All
All
All
All
Option (a) - Uncontrolled
Option (b) - 99.5% Control
Option (c) - 99.5% Control
Option (c) - 99.5% Control
Option (d) - 97% Control
                         4-7

-------
     The  ISC Model  contains  numerous model options and  features that are
required  to simulate the  air quality impact of emissions from the wide
variety of sources  found  in  industrial source complexes.  Because of the
requisite complexity of the  ISC Model, it is usually economically unfeasible
to use the ISCST program  to  calculate hourly concentrations for a year of
sequential hourly meteorological data, the procedure generally followed
with the Single-Source (CRSTER) Model.  However, from a knowledge of the
critical meteorological conditions for emissions from maleic anhydride
plants, it was possible to select ten 24-hour periods representative of
"worst-case" dispersion conditions and to execute ISCST for these days
only to obtain maximum 1-hour, 3-hour (Option (a) only), 8-hour and
24-hour average benzene concentrations.  First, the ratio of the vector
mean wind speed to the scalar mean wind speed was computed for each day
of 1964 from the Greater  Pittsburgh Airport hourly surface observations.
This ratio has a value near  unity for days of persistent wind directions
which are usually associated with maximum 8-hour and 24-hour average
concentrations.  The days with ratio values near unity were examined to
select ten days with neutral and/or stable conditions and either persistent
light-to-moderate winds ("worst-case" meteorological conditions for the
storage tanks and fugitive emissions) or persistent moderate-to-strong
winds ("worst-case" meteorological conditions for the stack emissions).
The selected days were days  5, 10, 26,  112, 118,  122, 265,  316, 343, and 358.
The principal  meteorological input to the ISCLT program for the annual
concentration calculations was the 1964 annual  STAR summary for the Greater
Pittsburgh Airport.
     The objective of the dispersion study was  to estimate maximum benzene
concentrations at or beyond  the property boundaries and at  downwind distances
                                  4-8

-------
of 0..1, 1.0, 10.ft and 20.0 kilometers.  Maximum concentrations produced by
fugitive and storage tank emissions can be expected to occur in the
immediate vicinity of the plant production area.  However, the dispersion
coefficients used by the ISC Model, the Pasquill-Gifford curves, begin
at a downwind distance of 100 meters.  Consequently, the property boundaries
were assumed to be 100 meters from the edge of the plant production area
and receptors were spaced at 30-meter intervals around the edge of the property
boundaries.  Preliminary calculations for the buoyant stack emissions
indicated that the maximum concentrations should occur within 2 kilometers
of the stacks.  Therefore, additional receptors were placed at distances
from the boundaries of 0.1, 0.2, 0.4, 0.6, 0.9, 1.4, 1.9, 9.9, and 19.9
kilometers along radials originating at the center of Source 5 and passing
through each of the receptors at the property boundary.
     The results of the dispersion analysis are summarized in Table 4-1 and
4-2.  The ISC Model calculations for the uncontrolled case, Option (a),
indicate that emissions from the product recovery absorber and refining
vacuum system vent are principally responsible for the maximum benzene
concentrations produced by the combined emissions from the plant.  At the
distances of maximum concentrations, the product recovery absorber emissions,
account for more than 85 percent of the calculated maximum concentrations.
Additionally, for some distances and averaging times, the product recovery
absorber accounts for more than 98 percent of the maximum concentrations.
However, the product recovery absorber of Option (a) does not necessarily
dominate the maximum concentrations at the assumed boundaries of the plant
property.  For a given averaging time, meteorological conditions such as
stability and wind direction determine whether the fugitive and storage tank
emissions or the product recovery absorber emissions are primarily responsible
for the magnitude and location of the maximum concentration at the property
boundaries.
                                  4-9

-------
     For emission control Options  (b) through (d), the benzene emissions
from the product recovery absorber are reduced by 97 to 99.5 percent.
With these reductions  in emissions, the ISC Model calculations show that
the fugitive and storage tank emissions (which are not controlled) have
a much greater influence on the maximum ground-level benzene concentrations
than in Option (a).  The maximum concentrations calculated for all averaging
periods are located at the assumed boundaries of the plant property, and
the fugitive and storage tank emissions are principally responsible for
the maximum concentrations.  Because the fugitive and storage tank emissions
dominate the air quality near the plant for Options (b) through (d), the
effects on ambient air quality near the plant of different emission
reductions are minimal without control of fugitive and storage emissions.
Disregarding the contribution from fugitive and storage emissions, however,
Table 4-1 shows that the maximum concentration of benzene from the process
vents after 99.5 percent control is less than 0.1 percent of the ambient
concentration resulting from these sources when uncontrolled.  When
Option (d) is used (97 percent control by carbon adsorption), the resulting
benzene concentration is about 0.1 percent of the concentration before control.
     Table 4-1  and Table 4-2 emphasize the positive impact on air quality from the
application of the alternative control systems.  However, there are usually
some adverse effects on air quality associated with each of the control
techniques that are incorporated in the selected alternative control systems.
These adverse impacts are compared to the benefits for each technique in the
next sections.
4.1.1  Carbon Adsorption (99.5 percent control of benzene)
     The carbon adsorption system described for this level of control in
Chapter 2 will reduce benzene emissions by 1510 Mg/yr for the model plant,
Of this emission reduction, about 1470 Mg of benzene per year is recovered for
                                4-10

-------
                         2
recycling to the process,   The remainder of the benzene and the other VOC
(M60 Mg/yr) are picked up in the scrubber or decanter water and are removed
as effluent wastewater,   The amount of benzene sent to wastewater treatment
is 40 Mg/yr, or about 1.4 g/sec,
     Depending upon the method of wastewater treatment practiced by the facility,
some volatilization of benzene to the atmosphere can occur,  A worst-case
assumption is that all of this benzene is emitted to the atmosphere at a constant
rate of 1.4 g/sec,  This is roughly 3 percent of the benzene emission rate
from the uncontrolled product recovery absorber of a model pi ant, which was
shown in Table 4-1.  The actual quantity of benzene emitted has not been
determined, because it is highly dependent upon the wastewater treatment technique
since benzene is biodegradable.4  Further, at least two facilities employ
an aqueous waste incinerator for the maleic anhydride production facilities.5'6
The aqueous stream from the carbon adsorber system could conceivably be combined
with the other liquid wastes sent to the incinerator.  Assuming a conservative
benzene destruction efficiency of 90 percent in this type of incinerator, the
benzene emissions from this source would be about 0.14 g/sec, or less than
1  percent of the emissions from an uncontrolled product recovery absorber.
    A second technique has been suggested to avoid this problem, in
which the aqueous layer from the decanter is recycled to the product
recovery absorber.   This eliminates the need for treatment of the water
stream and the potential for subsequent emissions of benzene.  This type
of source, i.e., benzene evaporation from a wastewater stream is considered
a secondary emission and will be more fully discussed in later documentation
specific to secondary sources.
                                    4-11

-------
4.1.2  Carbon Adsorption  (97 percent control of benzene)
    The carbon adsorption  system described for this level of control will
reduce benzene emissions by 1470 Mg/yr, based on the model plant.  Like
the system discussed  in section 4.1.1, some fraction of this controlled
benzene is picked up  in the decanter water and removed as effluent wastewater.
In a manner analogous to the previous system, about 1430 Mg of benzene
per year is recovered and  recycled to the process.  Therefore, about 40 Mg/yr
(^1.4 g/sec) of benzene would be carried in the aqueous waste from the
adsorber system.
    Consistent with the assumptions in section 4.1.1  a worst-case
benzene emission rate from this source is 1.4 g/sec, or less than 3 percent
of the emissions from an uncontrolled product recovery absorber.  Similarly,
control in a liquid incinerator would result in a benzene emission of less
than 0.14 g/sec.  Recycle of the aqueous stream could also be practiced.
Again, the benzene emissions from this type of source will be more
thoroughly discussed  in another document along with other secondary
sources of benzene.
4.1.3  Thermal Incineration (99.5 percent control of benzene)
    The incinerator system described in Chapter 2 reduces benzene emissions
by 1510 Mg/yr for the model plant.  No organics are recovered for recycle.
Pollutants generated by the combustion process can have a negative impact
on the environment, particularly nitrogen oxides (NOX).  The emission
rate of NO  from the  incinerator designed to achieve 99.5 percent control
          A
of benzene has not yet been estimated.  By comparison with industrial furnaces
and boilers, fume incinerators tend to have low NO  emission factors.  One
                                                  J\
reference reports NO  effluent concentrations from thermal incinerators of
                    J\
20-30 ppmv.   Even at temperatures as high as 870°C, estimated NO  concentrations
                                                                 /\
would be on the order of 50-200 ppmv.  Preliminary results from recent tests

                                    4-12

-------
on an incinerator operating at 7fiO°C showed an average NO  emission rate
                                                         J\
                     g
of about 0.27 gm/sec.
    Normally, carbon monoxide (CO) emissions from incinerators can be of
concern.  In this case the waste gas stream going to the incinerator
contains roughly 2 percent CO by volume, for the model plant.  The
incinerator achieves a net reduction in CO emissions from maleic anhydride
production.  At the incinerator conditions described in Chapter 2, it
is estimated that greater than 99 percent control of CO would be achieved.
    It is possible that in some locations natural gas will be unavailable
for the incinerator.  In those areas fuel oil will be used as the supplemental
fuel.  Depending upon the type of fuel used, there may be SO- and
particulate emissions from this control technique.
4.1.4  Thermal  Incineration  (97 percent  control  of benzene)
     An  incinerator with this efficiency will reduce benzene emissions by
1470 Mg/yr for  the model plant.  As with the  incinerator discussed in the
previous section, there can be negative  impacts  on the environment as a
result of NO ,  SO , and particulate matter emissions, but these impacts
            n    A
would tend to be less than the incinerator operated at a higher temperature.
The efficiency of CO destruction would also be lower at the lower temoerature
of 760°C.
4.1.5  n-Butane Process Conversion (100 percent control  of benzene)
    The organic emissions from the n-butane process represent an adverse
impact on air quality resulting from this technique to control  benzene emissions
from maleic anhydride production.   Although very little data are available
yet on the quantity and composition of the organic emissions, preliminary
information indicates that total  uncontrolled VOC emissions are higher
than the model  benzene process.    At present, there is no nationwide
                                4-13

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requirement to control the emissions from the n-butane oxidation process
for maleic anhydride production.  The effect of the VOC emissions on the
attainment of the oxidant standard is recognized.
4.2  WATER POLLUTION IMPACT
    There are no water effluents discharged as result  of the application of
incinerator systems.  As mentioned in the previous sections, there is a
wastewater stream containing benzene associated with the carbon adsorption
systems.  However, the organic  load of the wastewater from carbon
adsorption is much  less  than  10 percent of the total  liquid waste from a typical
                                     12 13
maleic anhydride production facility.  * J  Also as discussed, the wastewater
stream from the carbon adsorption systems could be treated along with the
other plant effluent or  recycled to the process.  The organic  liquid
effluent from the carbon adsorber systems will include maleic  acid,
other organic acids, formaldehyde, other aldehydes, and benzene.  These
materials are also contained  in other waste liquid streams from the process.
As mentioned previously, the  organic liquid effluent from the  carbon
adsorption systems is a  very  small percentage of the total liquid effluent
from maleic anhydride production facilities, and is therefore  estimated
to have an insignificant incremental impact on water pollution.
    There are insufficient data available to assess the wastewater load
from the n-butane process relative to the load from the benzene process.
The difference in wastewater  load will depend upon the specific operation
of the recovery, dehydration, and refining steps.  As discussed in
Chapter 1, differences between  the processes are not well known.  Assuming
that there are no major  differences between the two processes, the replacement
of benzene based facilities with n-butane based facilities as  a
control system will not  have  a  significant impact on water pollution.
                              4-14

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 4.3   SOLID WASTE DISPOSAL  IMPACT
     The  only potential  Impact on solid waste disposal  associated with  the
 alternative emission  control systems discussed previously  is  the handling
 of spent carbon from  the adsorption systems.  Typically, rather than disposal
 in a landfill, the spent carbon will be transported  to a facility for
 reclamation and regeneration.  If it were disposed of  in a  landfill, the
 amount of solid waste from this source would be approximately 7620 kg/yr
 from the model plant using the system achieving 99.5 percent control of
 benzene.    Assuming the same bed life for the system  at 97 percent
 control  of benzene, the amount of solid waste would  be on the order of
 7430  kg/yr for the model plant.   However, in both cases it is likely that
 the  carbon can be reclaimed, such that there would be  no impact on solid
 waste disposal from any of the alternative control systems.
4.4   ENERGY IMPACT
    A model uncontrolled maleic anhydride plant, using the benzene process,
will produce a small energy surplus of 15 kJ per kg of maleic anhydride
produced.  * 6  For a model plant with a production capacity of 22,700 Mg/yr,
the energy surplus is 340 GJ/yr (55 bbl/yr).  The energy impact of each
control technique is discussed in the following sections.  For comparison,
energy equivalents, in barrels of fuel  oil,  are included in parentheses
 (assuming 140,000 Btu/gal or 6.2  GJ/bbl).
4.4.1  Carbon Adsorption (99.5 percent control  of benzene)
    Energy (steam)  is required to desorb the benzene from the carbon.  For
the model plant,  this energy (as  steam)  is 57,000 MJ/Mg of benzene emission
reduced,  or 86,000 GJ/yr.    The  electrical  energy required for recycle
pumps and other equipment is 2500 MJ/Mg  of benzene emission reduced, or
                               In
3800 GJ/yr for the model plant.  °  The total energy requirement is
thus about 90,000 GJ/yr (14,500  bbl/yr).
                              4-15

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 4.4.2   Carbon  Adsorption (97  percent  control of  benzene)
    The energy requirements for  this  system are  less  than  the  system
 operating  at a higher  removal  efficiency.  For the model plant,  the
 required energy (as  steam) is  estimated to be 82,000  GJ/yr, or
                                          19
 56,000 MJ/Mg of benzene emission reduced.    The required  electrical enerqy
 is  assumed to  be the same as  the system operating at  99.5  percent  control of
 benzene.  Therefore, the total requirement is about 86,000 GJ/yr (14,000 bbl/yr).
 4.4.3   Thermal Incineration (99.5 percent control of  benzene)
     Supplemental  fuel  is required in the form of natural  gas or fuel oil to
 maintain suitable  operating conditions.  The net amount of energy  required
 for the model  plant  ranqes from  278,000 MJ/Mg of benzene removed for an
 incinerator without  any form of  heat  recovery to 62,000 MJ/Mg for  an incinerator
                                                                    20
 in which 50 percent  of  the heat  in the exit gas  stream is  recovered.    On
 an annual  basis, this  corresponds  to 420,000 GJ/yr (68,000 bbl/yr) for an
 incinerator without  heat  recovery,  and 94,000 GJ/yr (15,200 bbl/yr) for an
                               21
 incinerator with heat  recovery.
 4.4.4   Thermal  Incineration (97 percent control  of benzene)
     Since it  is expected that 97  percent control of benzene can be achieved
 at a lower temperature  than 99.5 percent control, the amount of  supplemental
 fuel required  will be decreased.   The expected net energy  requirement is about
 43,000  GJ/yr (7,000  bbl/yr) for an  incinerator with heat recovery, or 29,000
                                   22
MJ/Mg of benzene emission reduced.
4.4.5   n-Butane Process Conversion
     There  are no data  available to estimate the difference in energy requirements,
or net  energy  production, between the n-butane and the benzene oxidation processes.
The difference in energy usage will depend upon the difference in the amount of
heat generated by the reaction system, as well  as the energy requirements of
the recovery,  dehydration, and refining sections of  the process.   At this time,
there is no evidence that there is a significant difference in energy usage
between the two processes.
                                  4-16

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 4.4.6   Summary
    All of the  add-on  control devices require more energy than  is produced
 by the  typical  benzene process.  The thermal incinerator requires the most
 energy  at 99.5  percent control although with heat recovery it is just slightly
 more than the carbon adsorption system operating at the same level of control.
 At 97 percent control, the carbon adsorption system requires about twice  as
much energy as  the incinerator at 97 percent control.  The two  control
 devices operating at 99.5 percent removal efficiency for benzene use less than
 10 percent more energy than the carbon adsorption system operating at 97 percent
 control of benzene.  However, the thermal incinerator operating at 97 percent
control uses significantly less energy.  Further, consideration of the energy
usage by the add-on control devices at a 99.5 percent level of  control does not
significantly favor either carbon adsorption or incineration provided heat
recovery is employed with the latter.  Thermal  incineration is favored at 97
percent control.  As expected, the energy requirement .decreases as the control
efficiency decreases.
    The total  national  energy requirement will  depend upon the particular control
technique chosen for any alternative level of control.  However, the likely
upper limit on energy usage is the case in which all  plants achieve 99.5 percent
control  of benzene by thermal incineration with 50 percent heat recovery.  The
lower limit is the case in which all benzene based facilities convert to
n-butane as the feedstock.  Table 4-4 summarizes the  total  national  energy
requirement,  at current capacity, assuming all  plants are controlled by the
same  alternative emission control  system.
                                  4-17

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                           Table 4-4
                 Total  National Energy Requirement
Annual Energy Requirement (TJ/yr)
   910 (150,000 bbl/yr)

   870 (140,000 bbl/yr)

   950 (160,000 bbl/yr)

   430 (69,000 bbl/yr)
            Control System
 1.  Carbon adsorption  (99.5 percent
             control)
 2.  Carbon adsorption  (97 percent
             control)
 3.  Thermal incineration (99.5
     percent control)(with 50
     percent heat recovery)
 4.  Thermal incineration (97
     percent control)(with 50
     percent heat recovery)
 5.  n-butane process (new facilities
     only)(100 percent control)
4.5  OTHER ENVIRONMENTAL IMPACT
    There are no other known significant environmental impacts associated
with any of the alternative emission control systems discussed in Chapter 3.
4.6  OTHER ENVIRONMENTAL CONCERNS
4.6.1  Irreversible and Irretrievable Commitment of Resources
    Emission control systems using carbon adsorption recover a valuable
raw material, or resource, for reuse, whereas an incineration system
destroys the resource.  Over the long term, the amount of recovered benzene
is substantial.  Further, there is an energy savings when benzene is recovered
rather than burned, equivalent to the energy required to produce benzene.
                                 4-18

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 4.7  REFERENCES
 1.  Dispersion Model Analysis of the Air Quality Impact of Benzene
    Emissions from a Maleic Anhydride Plant for Four Emission Control
    Options (draft report), H. E. Cramer Company, Inc., EPA Contract
    No. 68-02-2507, U. S. Environmental Protection Agency, Research
    Triangle Park, North Carolina  27711, July, 1978.
 2.  Lawson, J. F., Maleic Anhydride - Product Report (draft), Hydroscience,
    Inc., unpublished report under EPA Contract No. 68-02-2577, March, 1978.
 3.  Ibid.
 4.  Dorigan, J., Fuller B., and Duffy, R., Preliminary Scoring of
    Selected Organic Air Pollutants Appendix I - Chemistry, Production.
    and Toxicity of Chemicals A Through C. (The Mitre Corporation),
    EPA-450/3-77-008b, U. S. Environmental Protection Agency, Office of
    Air Quality Planning and Standards, Research Triangle Park, North Carolina,
    27711, October, 1976.
 5.  Lawson, J. F., Trip Report for visit to Reichhold Chemicals, In,c.,
    Morris, Illinois, July 28, 1977, Hydroscience,  Inc., under EPA
    Contract No. 68-02-2577.
 6.  Lawson, J. F., Trip Report for visit to Amoco Chemicals Corp., Chicago,
    Illinois, January 24, 1978, Hydroscience, Inc., under contract No. 68-02-2577,
 7.  Patrick, D. R., U. S. EPA, Personal communications with M. A. Pierle,
    Monsanto Company, April 11, 1978.
8.  Rolke, R. W., et. al., Afterburner Systems Study. Shell Development
    Company, EPA-R2-72-062, U. S. Environmental Protection Agency, Office
    Of Air Programs,  August, 1972.
9.  Stationary Source Testing of a Maleic Anhydride Plant  at  the Denka Chemical
    Corporation. Houston. Texas, (draft report),  Midwest Research Institute,
    under EPA Contract No. 68-02-2814,  Work Assignment  No. 5,  May 1,  1978.
                                 4-19

-------
10.  Reference 2,  Op.  Cit.
11.  Reference 6,  Op.  Cit.
12.  Hewett,  P. S.,  Reichhold  Chemicals, Inc., Personal communications with
     D. F.  Patrick,  U. S.  EPA, March 27, 1978.
13.  Reference 2,  Op.  Cit.
14.  Ibid.
15.  Morse, P. L., "Maleic  Anhydride," November, 1973, Process Economic
     Program, Stanford Research  Institute, Menlo Park, California.
16.  Reference 2,  Op.  Cit.
17.  Ibid.
18.  Ibid.
19.  Weber, R. C., U.  S.  EPA,  Personal communications with W. M. Vatavuk,
     U. S.  EPA, July 7, 1978.
20.  Reference 2,  Op.  Cit.
21.  Ibid.
22.  Reference 19, Op. Cit.
                              4-20

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5.0  ECONOMIC IMPACT
5.0.1  Introduction
     This chapter is divided into three sections.   Section 5.1  presents  a
general profile of the maleic anhydride (MA) industry.   Section 5.2  is a
detailed cost analysis of the two benzene control  levels being  considered--
97 and 99.5 percent reduction.   Finally, Section  5.3 discusses  the economic
impact of these two control  levels.   The analysis  evaluates specific impacts
on the individual MA plants  as  well  as overall  market impacts,  such  as
the effect on product inflation.
5.0.2  Executive Summary
     The major results of the economic analyses may be summarized.  At
both the 97 and 99.5 percent control  levels, eight companies must finance
installation and operation of benzene control  and/or backup systems. Of
these eight companies, only two indicated that the costs may cause them
to discontinue production.  Tenneco  indicated that it would close down to
seek more profitable ventures.   Denka cited capital budget requirements
for the control equipment as being too burdensome, especially in the
aftermath of recent funded control equipment designed to meet Texas  Air
Pollution Control Board standards.  MA comprises  one-third of Denka's
total product sales.
     Other results show that the  average production cost increase from add-
on controls would be approximately one to four percent of the current MA
list price at full capacity, although individual  plants could experience
more than two times that increase at various price levels and operating
rates.
                                   5-1

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5.1  INDUSTRIAL ECONOMIC PROFILE
5.1.1  Fc'iiic Anhydride Supply and Capacity
5.1.1.1  General
     Maleic anhydride (MA) is produced by eight companies at ten  different
plants in the United States (Figure 5-1).  The ten maleic anhydride  plants  are
located in six states:  New Jersey, Pennsylvania,  West Virginia,  Illinois,
Missouri, and Texas.  Total employment at these companies is estimated  at 330
workers.
     Considerable excess MA capacity currently exists in the United  States.
Market conditions have forced MA producers to operate plants at under 60
percent design capacity.  Although present demand  has increased 11 percent
since 1976, overall nameplate capacity of 229 gigagrams (Gg)* is  more than  70
percent above the predicted demand for 1978.    Investor confidence is strong
however, and producers believe that demand will equal capacity by the end of
1982 (assuming a continued 11 percent growth  rate).  Consequently, producers
are willing to let current MA prices of 61.7  cents/kilogram remain until the
                                 2
projected balance can be reached.
     The confidence felt by chemical producers is  best demonstrated  by  the
rapid growth in MA capacity in the past few years.  Three years ago, in 1975,
annual  capacity was rated at 156 Gg.  It is now 229 Gg, an increase  of  47
percent, and includes two new 28 Gg plants (Ashland and Amoco), a large
18.2 Gg expansion (U.S. Steel), and a small expansion of 3.6 Gg (Koppers).
 A gigagram (Gg) is equivalent to one million kilograms.
                                     5-2

-------
                                            FIGURE 5-1

                      MANUFACTURING LOCATIONS OF MALEIC ANHYDRIDE
          /HOBTH DAKOTA
          i

         j SOUTH D«O"TA
         i
wficT^N^.
          "«K«;ri
        L
                   1.  Amoco. Joliet. IL.
           K       2.  Ashland. Neal. W. VA.
           E       3.  Koppers. Bridgeville, PA
           y       4.  Koppers. Chicago,  IL.
                   5.  Monsanto. St Louis. MO.
                           6.  Denka (Petro-Tex). Houston. TX.
                           7.  Reichhold. Elizabeth. N.J.
                           8.  Reichhcld. '.'orris. IL.
                           9.  Tenneco. Fords. N.J.
                           10.  U.S. Steel. Neville IMand. PA.
SOURCE : "Emission Control Options (or the Synthetic Orgonic Che-nieoll Mooufociuring Industry: Mo!cie Anhydride Product Report",
         Hydroscience, Morch 1978.
                                                  D™" J

-------
Although no new plants or expansions are planned, Amoco and Ashland eech could
expand 14 Gg should demand outstrip present capacity, which seems unlikely
until 1982 or 1983.
     In the United States, MA is produced from one of two feedstocks, benzene
or butane.  Presently, no supply constraints exist for either feedstock.
However, benzene was in short supply late in 1973 for a number of reasons,
including the Arab oil embargo.   At that time, benzene accounted for 96
percent of all feedstock used.  After subsequent increases in MA butane-
feedstock capacity, including the addition of Amoco1 s 27 P.g butane plant,
benzene consumption has been reduced to 83 percent of all feedstock
used.  This number could further be reduced should Monsanto rely more heavily
on butane (it currently uses butane for 20 percent of its production) or
should Ashland switch its new plant at Neal, West Virginia to butane.
     Another source of MA, though minor, is by-product recovery from phthalic
anhydride.  Presently, only Koppers in Chicago, with a total capacity of 5 ^g,
produces MA from the effluent of its phthalic anhydride plant.  This source of
MA is dependent on production of phthalic anhydride as the primary product.
No growth in this source of MA is expected.
5.1.1.2  The Individual MA-Producing Companies
     Table 5-1 compares the capacities of the individual MA plants with their
actual 1978 production.  Figure  5-2 summarizes the relationship between each
company's captive and merchant sales.  The eight MA-producing companies and
their capacities are listed on the following page of text.
                                    5-4

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                  Table 5-1   MALEIC ANHYDRIDE CAPACITY

Estimated
Manufacturing Locations Production
(Gg) 1978
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.

Amoco, Joliet, IL
Ashland, Neal , WV
Koppers, Bridgeville, PA
Koppers, Chicago, IL
Monsanto, St. Louis, MO
Denka (Petrotex) ,
Houston, TX
Reichhold, Elizabeth, NJ
Reichhold, Norris, IL
Tenneco, Fords, NJ
U.S. Steel, Neville
Island, PA
TOTAL
15
15
8
3
27
13
8
11
7
21
128
Capacity
1978 (Gg)
27
27
15
5
48
23
14
20
12
38
229
Process
2
1
1
3
(30%)1 (20%}2
1
1
1
1
1

Processes

 (1) Oxidation of benzene

 (2) Oxidation of n-butane
 (3) By-product of phthalic anhydride manufacture

SOURCES:  Capacity and process  figures were taken from:   Blackford,  J.C.,
          CEH Marketing Research Report on Maleic Acid.   July,  1975
          Chemical Economics Handbook, Stanford Pesearch Institute,
          Menlo Park, California.

          Personal Communications with D.R. Patrick,  U.S.  EPA,  March 27,  1978.

          Production figures were estimated by assuming  56 percent
          capacity for each plant.
                                     5-5

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                                                               FIGURE 5-2
                                           CAPTIVE AND MERCHANT SALES OF MA COMPANIES
MC. x 1000

      18


      16


      14


      12
 tn
 i
      10
                      I
                                                          I
                                                                                MERCHANT SALES
                                                                                CAPTIVE SALES
                                                                                                                     I
                  ASHLAND
MONSANTO
DENKA
REICHHOLD      TENNECO
U.S. STEEL
AMOCO
KOPPERS
       SOURCE  Personal Conversations wllh Representatives from each of the MA Producing Companies

-------
(1)   Amoco Chemical  Corporation
     Amoco has the  only U.S.  plant totally  dedicated  to  the  n-
     butane process.    The  facility has  an  annual  capacity of
     27 Gg and is  expandable  to 41 Gg.
(2)   Ashland Chemical  Company
     The Ashland  facility is  a new benzene-based  plant with
                                                            n
     an annual capacity of 27 Gg and is  expandable to 41 Gg.
     Fifty percent  of the annual capacity is  used captively
     to produce unsaturated polyester resins.   This plant can
                                                     g
     be switched  from benzene to n-butane feedstocks.
(3)   Koppers Company,  Inc.
     About 25 percent of the  MA from their  15 Gg/yr benzene
     oxidation plant in Bridgeville, Pennsylvania is  used
     captively to  produce unsaturated polyester resins and
     alkyd resins.   Their Chicago facility  can recover 5 Gg
     of MA per year from the  effluent of their phthalic
     anhydride plant which started in 1975.
(4)   Monsanto Company
     Monsanto at  48 Gg/yr is  the largest producer of MA.
     The company  uses butane  feedstocks  for about 20 percent
     of its capacity.   Approximately 25  percent of the MA
     is consumed  captively to produce fumaric acid, maleate/
     fumerate esters, styrene copolymers, and ethylene-maleic
     anhydride copolymers.
                                 5-7

-------
     (5)  Denka USA
          Their 23 Gg/yr Houston facility was designed by Scien-
          tific Design Company, Inc., and was purchased from
          Petrotex Chemical Corporation, a Japanese firm, July 1,
               12
          1577.    The feedstock now used is benzene.
     (6)  Reichhold Chemicals, Inc.
          Reichhold's combined production from both plants, at
          Elizabeth, New Jersey and Morris, Illinois,  is 34 Gg/yr,
          20 percent of which is used captively to produce un-
          saturated polyester resins, alkyd resins, and plas-
          ticizers."
     (7)  Tenneco Chemicals, Inc.
          Less than 20 percent of their 12 Gg/yr MA production
          is used captively to produce fumaric acid, dibutyl
                                                   14
          maleate, and dodecanylsuccinic anhydride.
     (8)  United States Steel Corporation
          Their MA capacity was recently expanded to 38 Gg/yr.
          Approximately 20 percent of their MA production is
          used captively to produce fumaric acid, dibutyl
          maleate, and dioctyl maleate.
     The expansion capabilities of 14 Gg each, for Amoco and Ashland represent
a potential  nationwide capacity of 257 Gg.
                                      5-8

-------
5.1.1  MA Usage and Demand
     Maleic anhydride (MA) is an important raw material in the production of
polyester resins, agricultural chemicals, lubricants, fumaric acids, copoly-
mers and other intermediate raw materials.  Table 5-2 breaks out these
categories by percentage and growth rates.  Deinand for MA has increased his-
torically at a rate of nine percent a year and is expected to grow at a rate
of six to 11 percent over the next five years.17  A major reason for the large
amount of excess capacity is investor confidence that MA demand will be
strong.
     The predominant end use of MA is the production of unsaturated polyester
resins, which go into reinforced plastic applications such as marine craft,
building panels, automobiles, tanks and pipes.  Of the 126 gigagrams (Gg) of
maleic anhydride produced in 1977, polyester resins consumed 55 percent  (69
Gg).   Industry forecasters expect polyester production to grow at an annual
rate of ten to fifteen percent.  The growth rate would double this  industry's
use of maleic by 1981 to about  144 Gg.  This growth could be greater if  po-
tential polyester markets in housing, marine craft, and autos materialize.
Automobile manufacturers, striving to lighten  products in order to  meet  Con-
gressionally-mandated fuel economy standards,  are turning more and  more  to
                                                                       1 Q
polyester with above average maleic content to replace heavier metals.
Presently, no chemical can substitute for MA as  in the production of polyester
resins.
     Agricultural chemicals, which are  the second  largest  users of  maleic
(ten percent of  demand),  are  expected to  grow  at  a rate almost as  rapid  as
polyester  resins.   This  growth  could be further  accelerated  by I'-A's use  as  an
                                      5-9

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               Table  5-2    MALEIC ANHYDRIDE USAGE AND GROWTH

End Use
Unsaturated Polyester Resins
Agricultural Chemicals
Lubricating Additives
Fumaric Acid
Co polymers
Maleic Acid
Reactive Plasticizers
Surface-Active Agents
Alkyd Resins
Chlorendic Anhydride and Acid
Other
All MA Products
1978 Demand
Gg/yr
77.7
13.4
8.7
5.7
5.9
4.2
4.0
3.2
1.5
1.2
7.5
134.0
1978 Demand as
% of Production
53
10
7
5
4
3
3
2
1
1
6
100
Average Annual
3 Growth 1978-83
13
1C
12
5
9
10
o
u
8
4
13
5
11
SOURCES:  Total MA demand was taken from the Chemical  Profile on Maleic An-
          hydride Chemical Marketing Reporter. February 13, 1978.  Demand for
          each product was obtained by multiplying the expected percentage
          production of each category by the expected  demand of MA, 134 Gg/yr.
          for 1978.

          Percentages of polyester resins, agricultural chemicals,  and  fumaric
          acid was taken from the Chemical Profile on  maleic anhydride,
          Chemical Marketing Reporter, February 18, 1978.

          Percentages of the remaining end uses were based upon the production
          figures in JC Blackfords Marketing Research  Report on Maleic  Anhy-
          dride, July 1976.  Chemical  Economics Handbook,  Standard  Research
          Institute.  Menlo Park, California.   Growth  rates were also derived
          from this source, but were adjusted  to reflect 100 percent capacity
          utilization by 1933.
                                      5-10

-------
agricultural pesticide.  Other chemicals can be substituted for MA as an
agricultural chemical.  Presently, however, MA is highly competitive in this
       19
market.
     Other markets, such as lubricants, maleic anhydride copolymers, fumaric
acids, and reactive plasticizers are expected to grow at either modest or
rapid rates in .the next five years.
     MA is not a regional product.  Companies try to concentrate their markets
in one area, but due to overcapacity, producers are willing to sell MA through-
out the country.  Several market areas of the country are more concentrated
than others.  More than 15 percent of U.S. markets lie in each of the follow-
ing regions:  Middle Eastern, South Eastern, Western South Central, and Eas-
                   20
tern North Central.    The polyester resins are primarily produced in the
central regions; agricultural chemicals and fumaric acid are mostly produced
in the East.  Although these geographic tendencies exist, MA is a homogeneous
product, irrespective of producer characteristics, and can be sold in any of
the aforementioned markets.
5.1.3  Prices
5.1.3.1  Price o'f MA
     Historically, prices of maleic anhydride have fluctuated widely (Figure
5.3.)  Maleic sold at 37.4 cents per kilogram in 1971, and at 28 cents per
kilogram in 1972.  In these years, there was a small difference between the
price posted by the producer (list price) and the price received (actual
price).  The MA price began to rise at the end of 1973, in large part due to
increased benzene prices.  List prices climbed steadily until they leveled off
                                                                  21
at 81.4 cents per molten kilogram; 90.2 cents per bagged kilogram.    Since
                                      5-11

-------
                                 FIGURE  5-3

                  PRICE FLUCTUATIONS OF MALEIC ANHYDRIDE
CENTS PER
   MOLTEN
 KILOGRAM
        90
         1955
            1960
1965
                                     YEAR
1970
1975
1980
SOURCE:
"CEH Marketing  Research Report on Kaleic  Anhydride", Judith Blackford,
July 1976.   Chemical Economics Handbook,  Stanford Research Institute.
                                     5-12

-------
then, actual prices have fallen steadily.   In January 1977, the actual  price


for molten maleic was 72.6 cents per kilogram; it is now 51.7 cents per kilo-


gram.22 The 1978 list price of MA is 19.7  cents more per kilogram than the


actual price.


     Current actual and list prices for MA are the same for the eight !!A-


producing companies.  Due to excess capacity, no company feels they can raise


prices without losing business.


5.1.3.2  Feedstock Costs


     Traditionally, costs for benzene feedstock accounted for 40 to 50 percent


of the final price, but the quadrupling of world oil prices altered this


relationship.  Feedstock costs presently make up a 43-57 percent share of the

                                                          23
production  price and this share will rise with oil prices.    At present, the


use of butane as a feedstock can lead to as much as 7.3 cent reduction per


kilogram over benzene feedstock costs.24  Cost for benzene feedstock presently


is 31.9 cents/kilogram of MA, where the cost of the n-butane feedstock is 24.6


                     25
cents/kilogram of MA.


5.1.3.3  Transportation Costs


     MA is  usually transported by  truck or by train.  The  price  for trans-


porting MA  to its  various markets  around the country has varied  historically


to within a  few cents.  It  is several tenths of a cent  per kilogram cheaper to


transport maleic by train than by  truck.  However,  a client  must purchase at


least 45 thousand  kilograms of maleic, the amount needed to  fill a tank  car to make


transportation by  train practical.  Presently, costs for transporting  MA by


train average 0.005 cents/kilogram/mile, whereas  the costs for  truck  transport

                                 26
average 0.01 cents/kilogram/mile.



                                     5-13

-------
     It is a common practice among producers to charge their customers equal



transportation costs regardless of their location.  Thus, the price paid by



the customer frequently will not cover the actual cost of transportation,


                                             27
ranging from 0.003-0.013 cents/kilogram/mile.    Suppliers are willing to pay



freight costs in excess of above 3.9 cents/kilogram, themselves, because the



MA market is vastly over-supplied.



5.1.4  Briquettes vs. Molten MA



     The MA market can be segmented into two parts — briquette users and molten



MA users.  A typical briquette user is much smaller than a molten user and can



neither buy in bulk (i.e., 45,000 kg. per tank car), nor afford liquid storage



facilities, even though briquettes normally cost 5.5 to 9 cents per kilogram



more than the molten form and require up to 4.5 cents per kilogram to melt


                28
down before use.    In addition, briquettes cannot be stored for periods


                                                           29
longer than about 60 days because they begin to emit gases.



     Briquettes would be purchased by large users only in abnormal  circum-



stances where foreign sources of briquettes temporarily undercut molten MA



prices by more than the cost of melting the MA down.    This actually occurred



last year and will be discussed in the following subsection on imports.



5.1.4.1  Imports of Maleic Anhydride



     Figure 5-4 shows the relationship between domestic production and demand



and imports.  All imported MA is in the form of briquettes; molten MA cannot



be transported overseas.  Currently imports account for only about five per-



cent of the U.S. MA market, but about one-third of the U.S. briquette market



(see Figure 5-5).
                                     5-14

-------
                                    FIGURE  5-4

       MALEIC ANHYDRIDE:  A Comparison of Imports to U.S. Production and Demand
NANOGRAMS
      (Ng)
                1974           1975

        SOURCE  EEAjnc. . April, 1978
1976
                                           5-15
1977
                                                                    1978
YEAR

-------
                                     FIGURE  5-5
                          U.S. CONSUMPTION OF MA BY SOURCE
                   VA.
                BRIpAJETTES
                    9%
              IMPORTS
           (BRIQUETTES)
                 5%
    U.S.
 MERCHANT
PRODUCTION
    66%
                      U.S.
                    CAPTIVE
                   PRODUCTION
SOURCES:   Import information  was  obtained  in  a  personal  communication with
          Mr.  Fred Magnusson,  Dept.  of Commerce.

          Figures for merchant, captive, and  briquette  domestic production
          were obtained  in  personal  communications with  representatives from
          each of the MA-producing  companies.
                                        5-16

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     Only recently have MA  imports posed  problems  for  U.S.  producers.   Prior



to  1977, MA imports were not even recorded by  the  Bureau of Census.   In 1977,



however, 6.8 Gg of MA v/as imported at 73  cents  per kilogram,  primarily  from



Korea and Mexico.    By September 1977, the price  of domestic  briquettes


                                          32
dropped from 90 to 75 cents per kilogram.    At that line,  imports also con-



tributed to the reduction of molten MA prices  from 81.4 cents  to  61.7 cents/



kilogram.    Although domestic overcapacity was undoubtedly the main factor



for this price drop, briquettes were, temporarily,  almost four cents per



kilogram cheaper to buy and melt down than the  molten  form.



     The low price of imported MA can be  attributed to two  factors:  1)  for-



eign MA companies have excess capacity; thus,  they purposely  undercut U.S.



prices in order to attract business; and  2) many foreign companies may  be



partially subsidized by their governments and  can  afford to sell  at minimal or



no profit.



     Adding to the cost of imports, however, are the added  transportation



costs and import duties.  These duties depend  on the feedstock used to  produce



the MA and the country of origin.



     Currently, equal quantities of butene (C.)-based !-iA from  Korea and Japan



and benzene-based MA from Mexico and Italy are  being imported.  Of these, the



C.-based MA has the most favorable duty—six percent ad valorem.    Some



domestic producers fear that this is not  high enough to keep  large amounts of



C.-based MA from being imported in the future at considerably  lower than



current prices.  However,  this viewpoint  is not supported by  the  currently



rising price of imports.
                                     5-17

-------
     The import rate of duty on benzene-derived products is  presently 1.2
cents per pound plus 12.5 percent ad valorem.  Prior to I960,  the rate was  3.5
cents per pound plus 25 percent ad valorem; although the duty  has declined,  it
is still significant.35
     Imports of benzenoid products from less developed countries  (LDC's) are
duty free, however, under the general system of preferences.  This means that
imports from Mexico and Korea are not subject to duty as long  as  at least  35
                                                              37
percent of the value of their product comes from that country.    This raises
the possibility that exporters might try to conceal  the actual origin of some
                                                            38
MA imports to obtain a low duty rate or avoid it altogether.    The more
important observation is that the two largest exporters of MA  to  the U.S.  have
no duty.
                                       5-18

-------
                                References

 1.   "Maleic Anhydride Capacity Booming," Chemical and Engineering News.
     October 4,  1976.
 2.   Stanford  Research Institute, Chemical Economics Newsletter, July/
     August, 1976.
 3.   Chemical  and  Engineering News, October 4,  1976.
 4.   Chemical  Economics  Newsletter, July/August,  1976.
 5.   "Maleic Markets  Build  on Hopes for  Polyester" Chemical Week,
     February  2, 1977, p. 37.
 6.   Blackford,  J.C., CEH Marketing Research  Report on Maleic Anhydride,
     July,  1976.  Chemical  Economics  Handbook,  Stanford Research Institute,
     Menlo  Park, California.
 7.   Chemical  Week.  February 2, 1977.
 8.   Blackford,  J.S., Chemical  Economics Handbook, July,  1976.
 9.   Chemical  Week,  February 2, 1977.
10.   Blackford,  J.S., Chemical  Economics Handbook, July 1976.
11.   Ibid.
12.   Hydroscience, Emission Control Options  for the Synthetic Organic
     Chemicals Manufacturing  Industry,  Maleic Anhydride Product Report,
     March, 1978.
13.   Blackford,  J.D., Chemical  Economics Handbook. July 1976.
14.   Ibid.
15.   Ibid.
16.   Chemical  Week,  February  2, 1977.
17.   Ibid.
18.   Ibid.
19.   Ibid.
                                    5-19

-------
20.  Confidential Communication with a representative from Ashland Oil,
     Neal, West Virginia.
21.  Chemical Week, February 2, 1977.
22.  Ibid.
23.  Confidential communication with a representative from Teneco.
24.  Personal communication with Mr. Vadzbuk, RTP, EPA.
25.  Ibid.
26.  Personal communication with Mr. Hardy of U.S. Steel, Pittsburgh, PA,
     April 7, 1978.
27.  Ibid.
28.  Personal communication with a representative from Denka, Houston, Texas.
29.  Ibid.
30.  Ibid.
31.  Personal communication with Mr. Magnusson, Dept. of Commerce.
32.  Personal communication with a representative from Denka, Houston, Texas,
33.  Personal communications with representatives from several MA producing
     companies.
34.  Personal communication? with Denka representative.
35.  Blackford, J.C. Chemical Economics Handbook, July,  1976.
36.  Ibid.
37.  Personal communication with Mr. Becker, Department of Commerce.
38.  Personal communication with a representative from Denka.
                                    5-20

-------
 5.2   COST ANALYSIS OF ALTERNATIVE  EMISSION CONTROL SYSTEMS
 5.2.1   Introduction
      In  this  section, costs are presented for controlling and monitoring
 benzene  emissions  (where  necessary) at each of the eight existing
maleic anhydride plants  utilizing  benzene as  a  feedstock.   For each plant,
two kinds of add-on control  systems have  been  examined:  thermal  incineration
with primary heat recovery,  and carbon adsorption.   For  each system, two
benzene emission reduction levels  have been  costed:   97  and  99.5 percent.
It is important to note  that under each standard  being considered,  the
installation and maintenance of a  backup  system is  assumed.   For the three
plants which already meet the 97 percent  reduction  level--Denka, Reichhold
(NJ) and Koppers (PA)--and for the Koppers (PA) plant, which already meets
the 99.5 percent reduction,  backup thermal incineration  systems have been
costed.  Monitoring costs, however, which have  also been developed, have not
been incorporated into the investment costs  associated with  each control
system, and will be discussed later in this  section.
5.2.2  Summary  of Technical  Parameters Used as the Basis in Cost Analysis
     This section summarizes the assumptions used in developing control
costs at the  97 and 99.5 percent control  level  for eight maleic anhydride
plants.  It should be recognized,  however, that these costs  are only pre-
liminary estimates(- 30%).  In developing these costs, plant capacity was the  only
plant-specific  parameter taken into consideration.   To develop definitive
costs for an  actual installation,  a detailed engineering evaluation is
required.  Such an evaluation is beyond  the resources and scope of this
document.
                                    5-21

-------
     The efficiencies and other parameters used in costing the  control
methods in this analysis are listed in Table 5-3.   Some of the  parameters
listed are expressed in terms of plant capacity, "P".   Since  these  para-
meters vary from plant to plant, these expressions have been  derived  for
the sake of brevity.  It has been assumed that the gas  volumetric flow-
rate and the benzene emission rate vary proportionately with  plant  capa-
city.  This assumption has been made in the absence of  current  technical
information for the individual  maleic anhydride plants.  Given,  however,
that benzene-fed maleic anhydride plants are of a  similar process design,
such assumptions are not unfounded.
     Other assumptions used in  costing the add-on  systems for each  plant
are as follows:
     (1)  Intensive stream parameters, such as gas pressure and  tempera-
ture, are the same for all plants;
     (2)  No credit is given for control equipment in use in  an  existing
plant, unless the controls already achieve the alternative in question--
i.e., 97 or 99.5 percent;
     (3)  Unless costs are listed separately for a backup system, the
costs for each control system include costs for a  "backup" unit  consist-
ing of an incinerator which would come on-line in  the event of equip-
             p
ment failure;
     (4)  All  control  system installations are retrofits, whose  costs re-
flect retrofit penalties of 40  and 30 percent of the new plant  installation
cost, for incinerator and carbon adsorption systems, respectively.
(These moderate penalties, in turn, reflect the fact that retrofit  costs
                                   5-22

-------
          TABLE 5-3.   TECHNICAL PARAMETERS USED IN  DEVELOPING
                         CONTROL SYSTEM COSTS3
     Parameter
                Value
1.   Gas temperature

2.   Gas pressure

3.   Gas volumetric flowrate

4.   Inlet benzene emission rate

5.   Benzene control efficiency

6.   Plant capacities

7.   Incinerator combustion0
    temperature & residence time

8.   Design carbon loading
38°C (100°F)

120 KPa (18 psia)

0.0536 P m3/min (1.89 P ACFM)b

0.0084 P kg/hr (0.0185 P Ib/hr)

97%, 99.5*c

(See Tables 5-5 to 5-6 )

870°C (16000F); 0.5 sec.
760°C; 0.5 sec.

6 kg VOC/100 kg carbon (6 Ib VOC/
100 Ib carbon)
 References 1, 2, and EPA estimates.

 P = plant capacity in megagrams per year of maleic anhydride.

cTemperature varies with percent control  - 870°C at 99.5 percent control
 and 760°C at 97 percent control .
                                    5-23

-------
are not appreciably greater than those for new plant installations.   The
primary retrofit difficulty may be finding adequate space to fit  the
                                              4
control system into the existing plant layout. )
     In addition to developing control costs for  the various maleic anhy-
dride plants, costs were also developed for continuous monitoring of  ben-
zene stack emissions.  This is required under Section 112 of the  Clean
Air Act.  The device costed is a gas chromatograph, with appropriate
auxiliary equipment:  air sampler, data processor, and piping.
     The add-on control costs have been primarily based on data available
from an EPA contractor (Hydrosciences, Inc.),  and a compendium of costs
for selected air pollution control systems.  Monitoring costs were ob-
tained from a vendor.
     Two cost parameters have been evaluated in this analysis:  installed
capital and total  annualized.  The installed capital cost for each emis-
sion control system includes the purchased costs  of the major and auxil-
iary equipment, costs for site preparation and equipment installation,
and design engineering costs.  No attempt has been made to include costs
for research and development, possible lost production during equipment
installation, or losses during start-up.   All capital  costs in this
section reflect fourth quarter 1977 prices for equipment, installation
materials, and installation labor.
     The total annualized cost consists of direct operating costs,
annualized capital  charges, and recovery credits.  Direct operating costs
include fixed and variable annual  costs such as:
     •  Labor and materials needed to operate control  equipment;
     •  Maintenance labor and materials;
                                     5-24

-------
     •  Utilities, such as natural  gas and electric power;
     •  Liquid waste disposal.
     The annualized capital  charges account for depreciation,  interest,
administrative overhead, property taxes, and insurance.   The depreciation
and interest have been computed by use of a capital recovery factor,  the
value of which depends on the depreciable life of the control  system  and
the annual  interest rate (ten percent  is used  for the  latter). Admin-
istrative overhead, taxes, and insurance have  been fixed at  an additional
four percent of the installed capital  cost.
     The recovery credits apply to the value of material  or  energy  re-
covered by the control system.   With carbon adsorption systems,  benzene
is recovered from the regenerated carbon beds, while a credit  for natural
gas is applied to thermal incineration systems with primary  heat re-
covery.  The annual cost factors used in this  section are listed in
Table 5-4.
     Finally, the total annualized cost is obtained simply by  adding  the
direct operating costs to the annualized capital charges, and  subtracting
the recovery credits from this sum.
5.2.3  Control Costs for Maleic Anhydride Facilities
     Costs  for controlling benzene emissions have been developed for  each
of the eight benzene-fed maleic anhydride plants at two control  levels:
97 and 99.5 percent efficiency.  Only existing plant costs  are included,
because no  new plants are anticipated before 1983.  The maleic anhydride
industry presently is operating at 56 percent  capacity.   Projected  in-
creases in  demand could therefore be accomodated by increases  in operating
rates over  the next few years.
                                   5-25

-------
                TABLE 5- 4 .   ANNUAL I ZED COST  PARAMETERS0
         Parameter
              Value
1.   Operating factors
2.   Operating labor
3.   Maintenance labor and
    materials:
    Control  systems
    Gas chromatographs
4.   Utilities:
    Electric power
    Natural  gas
    Steam
    Cooling water
5.   Operating materials:
    Sodium hydroxide (50%)
    Carbon
    Benzene
    Carrier gas
    Chart paper
6.   Liquid waste disposal
7.   Recovery credits
    Benzene
    Natural  gas
8.   Depreciation and interest
9.   Taxes, insurance, and admin-
    istrative charges
4500 and 8000 hours/year
$10/man-hour


5.0 percent of total  installed  cost
3.4 percent of total  installed  cost

$0.03/kilowatt-hour
$2.10/GJ ($2.00/million Btu)
$5.50/Mg {$2.50/thousand Ibs)
$0.026/kilo1iter ($0.10/thousand  gal.)

$0.20/kg ($0.09/lb)
$1.90/kg ($0.85/lb)
$0.21/liter ($0.80/gallon)
$17/tank
$5.60/pack
$0.003/liter ($0.01/gallon)

$0.17/liter ($0.63/gallon)
$2.10/30 ($2.Do/million Btu)
16.28 percent of total  installed  cost
4.0 percent of total  installed  cost
 References 1, 7, 12, and EPA estimates.
3Based on a 10-year life and 10 percent annual  interest.
                                  5-26

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5.2.3.1   Costs to Achieve the  97% Benzene Emissions  Control Level
     The costs for reducing benzene emissions  by 97  percent are  shown  in
Tables 5-5a  and 5-5b,  for the carbon adsorption and thermal incineration
control  systems, respectively.   Of the eight plants  for which  costs  are
shown, the best information available indicates that three  (Denka;
Reichhold (Elizabeth, NJ); and Koppers (Bridgevelle, PA)) already reduce
their benzene emissions by at  least 97 percent.  However, because the
anticipated benzene NESHAP would permit no violation of the emission
limit, backup thermal incinerator systems have been  costed for these three
plants.   As Table 5-5ashows, the installed cost of these backup  systems
ranges from $538,000 to $783,000 for the Reichhold and  Denka  plants,
respectively.  Because these are backup systems, no  variable  operating
costs (e.g., fuel) or energy credits have been computed. The  only direct
cost included is maintenance labor and materials, which is  five  percent
of the installed cost per year.   The annualized capital charges  are  based
on a 10-year depreciable life  and 10 percent annual  interest  rate.   The
total annualized cost—the sum of maintenance  and capital charges—ranges
from $136,000 to $198,000 per year for the backup systems.
     As  expected, the control  costs for the five other  plants  are signifi-
cantly higher.  Of the two control systems costed at this control level,
the carbon adsorption systems  are the more costly throughout.   This  is
primarily due to the fact that the installed costs,  operating costs, and
benzene  recovery credits are very close to those for the adsorbers  design-
ed for 99.5 percent efficiency.   In fact, the  main  difference between  the
capital  costs at 97 and 99.5 percent is the slightly smaller  amount  of
carbon required at the lower efficiency, which, in  turn, results in  lower
                                    5-27

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                                       Table 5-5a.EXISTING PLANT COSTS FOR ACHIEVING 97. PERCENT BENZENE EMISSION REDUCTION3
                                                                      CONTROL METHOD:  CARBON ADSORPTION
Plant Name and Location
1. Ashland-Neal, W. Va.
2. Monsanto-St. Louis, Mo.
3. Denka-Houston, Tex9
4. Reichhold-Ellzabeth, N.J.9
5. Re ichho Id -Morris, 111.
6. Tenneco-Fords , N.J.
7. U.S. Steel-Neville
Island, Pa.
8. Koppers-Bridgeville, Pa.9
Capacity
(Mg/yr)
27,200
38,100e
22,700
13,600
20,000
11,800
38.500
15,400
Installed ,.
Cost (M$)°'c
2,370
3.180
783
538
1,820
1.180
3.200
590
Direct Operating
Cost (M$/yr)
4500 .
hrs/yrd
411
560
39
27
314
200
566
30
8000
hrs/yr
620
853
39
27
468
290
862
30
ACC
(M$/yr)
480
645
159
109
369
240
649
120
Benzene Recovery
Credit (M$/yr)
4500
hrs/yr
(186)
(261)
None
None
(137)
(81)
(264)
None
8000
hrs/yr
(331)
(464)
None
None
(244)
(144)
(469)
None
Total Annua
(M$/vrl
4500
hrs/yr
705
944
198
136
546
359
951
150
8000
hrs/yr
769
1.034
198
136
593
386
1.042
150
lized Cost r
($/Mq Product)1
4500
hrs/yr
46.7
44.6
16.1
18.8
49.4
55.4
44.4
18.2
8000
hrs/yr
28.5
27.3
9.0
10.5
30.6
33.3
27.2
10.2
in
 i
CO
        'References 1 to 3. 8 to 13
        6The  letter "M" denotes thousands; "MM", millions, etc.
        Installed costs  are rounded to the nearest ten thousand dollars; other costs are rounded to the nearest thousand.
         Operating factor represents production at 56 percent of capacity.
        eThis  represents  80 percent of the total plant capacity.  The rest of the M.A. is produced from n-butane.
         Includes the cost of benzene continuous monitoring (approximately $7,000 per year per plant).
        9Costs  shown are  for a back-up thermal incinerator unit.

-------
                               Table5-5b.EXISTING PLANT COSTS FOR ACHIEVING 97. PERCENT BENZENE EMISSION REDUCTION3
                                            CONTROL METHOD:  Thermal Incineration with Primary Heat Recovery
Plant Name and Location
1. Ashland-Neal, W. Va.
2. Monsanto-St. Louis, Mo.
3. Denka-Houslon, Tex.9
A, Reichhcld-Elizabeth, H.J.9

5. Reichhold-Morris, 111.
6. Tenneco-Fords, N.J.
7. U.S. Steel-Neville
Island, Pa.
B. Koppers-Bridgeville, Pa."
Capacity
(Mq/yrl
27,200
38,100
22,700
13,600

20,000
11,800
38,500

IS. 400
Installed
Cost (H$)»>.c
2.080
2,720
783
538

1,650
1,140
2,760

590
Direct Op
Cost (Ml
4500
hrs/yrd
528
724
39
27

399
250
733

30
crating
/yr)
8000
hrs/yr
846
1,169
159
109

633
388
1,183

30
ACC
(Ml/JfT)
421
55 1
159
109

335
231
559

120
Energy Recovery
Credit (M$/yr)
4500
hrs/yr
(351)
(491)
Hone
None

(258)
(152)
(497 )

None
8000
hrs/yr
(626)
(876)
None
None

(460)
(271)
(886)

None
Total Annua'
(HJ/vr3. .
4500
hrs/yr
598
784
198
136

476
329
795

150
8000
hrs/yr
641
344
198
136

504
348
856

150
ized Cost t
($/Mg Product)1
4500
hrs/yr
39.7
37.1
16.1
18.8

43.1
50.8
37.2

18.2
8000
hrs/vr
23.8
22.3
9.0
10.5
1 '
25.6
30.0
22.4

10.2
tn
i
10
VO
         References  1  to 3, 8  to  10, 13.

       b'c>d>eSee Table 5-5a  footnotes.

         Includes the  cost of  benzene continuous monitoring  (approximately $7,000  per year per plant).

       9Costs shown are for a backup thermal  incinerator unit

-------
costs for the adsorber vessels.  However, the capital costs for auxiliaries,.
such as ductwork, are the same for both efficiencies.  In addition, there
are lower operating costs for steam, cooling water, and liquid waste dis-
posal as well as a smaller benzene recovery credit.  Yet, all  in all, the
total annualized costs are no more than five percent less than the corres-
ponding costs at 99.5 percent level.  (See Tables 5-6a and 5-6b).
     On the other hand, the costs for the thermal incinerator-with-heat
recovery system are much lower at the 97 percent level than at 99.5 per-
cent.  This is because the combustion temperature required at  the lower
level (760°C)  is less than the 870° temperature required to achieve
99.5 percent reduction.  Consequently, the net fuel cost is significantly
less (about 30 percent) at the lower combustion temperature.  Furthermore,
because the fuel cost comprises most of the total annualized cost, the  annual
ized costs are significantly lower.   At full capacity (8000 hours per
year operating factor), the annualized cost (including the backup systems)
ranges from $348,000 per year for the Tenneco plant to $856,000 for the
U.S. Steel plant.  When the benzene monitoring costs are added in (about
$7,000 per year), these costs convert to $30 to $22 per Mg of  product.
The corresponding costs for operation at 56 percent capacity (4500 hours
per year) are $329,000 and $795,000 per year, or $51 and $36 per Mg of
product including monitoring costs.   As these figures show, there is not
a great deal of cost difference between operating at full or partial
capacity.  This indicates that the control  costs are more heavily weighted
toward the fixed costs (e.g., maintenance, capital  charges) than tov/ard
such variable costs as fuel.
                                  5-30

-------
5.2.3.2  Costs  to Achieve the 99.5% Benzene Emissions  Control  Level
     Tables 5-6a and 5-6b display respective control  costs  to  achieve 99.5
percent benzene emission reduction via  carbon adsorption  and thermal  incinera-
tion with heat  recovery.  Except for the  Koppers  (PA)  plant, all  benzene-fed
plants require  additional control  to achieve this  level.  Table  5-6&  lists
costs for a thermal  incinerator with primary heat  recovery.  As  the capacity
increases from  11,800 to 38,500 Mg/yr., the system installed cost goes  from
$1.21 million to $2.99 million.  These  are only slightly more  than the
incineration capital costs in Table 5-5b which were for 97  percent
control.  However, because of high fuel costs, the direct operating
costs for incineration are significantly higher than the costs for
97 percent carbon adsorption.  These costs range from $309,000 to
$928,000/year at 4500 hours/year of operation, and $491,000 to $1.52  million/
year at 8000 hours/year.
     In addition, a heat exchanger is built into the incinerator unit to
preheat the incoming air, while cooling the exhaust gas.   In  this way,
about 50 percent of the total heat duty of the incinerator  is  recovered.
The credits shown in Table 5-6b account for this recovered  energy.  Depend-
ing on plant size and operating mode, these credits amount  from 60 to 70
percent of the  direct operating costs.   These credits offset the direct
operating costs and annualized capital  charges to such an extent that the
total annualized costs compare favorably with those for adsorption (Table
5-5a).  The annualized costs range from $374,000 to $945,000/year and
$416,000 to $1.08 million/year, for the 4500 and 8000 hours/year operating
factor, respectively.
     The carbon adsorption system costs shown in Table 5-6a also represent
achievement of a 99.5 percent control efficiency.   Any differences between
                                       5-31

-------
                                        Table5-6a.EXISTING  PLANT  COSTS FOR ACHIEVING 99.5 PERCENT BENZENE EMISSION REDUCTION9

                                                                        CONTROL METHOD:  Carbon Adsorption
Plant Name and Location
1. Ashland-Neal, W. Va.
2. Honsanto-St. Louis, Mo.
3. Denka-Houston, Tex.
4. Reichhold-Elizabeth, N.J.
5. Relchhold-Morris, 111.
6. Tenneco-Fords , N.J.
7. U.S. Steel-Neville
Island. Pa.
8. Koppers-Bridgeville, Pa.9
Capacity
(Mg/yr)
27,200
38,100e
22,700
13,600
20,000
11,800
38,500

15.400
Installed
Cost (M$)b.c
2,470
3.320
2,120
1,380
1,900
1.240
3,350

632
Direct Operating
Cost (M$/yr)
4500 .
hrs/yrd
426
581
363
232
324
207
587

32
8000
hrs/yr
643
885
544
341
483
301
894

32
ACC
(M$/yr)
501
674
429
279
385
251
680

128
Benzene Recovery
Credit (M$/yr)
4500
hrs/yr
(191)
(268)
(160)
(96)
(141)
(83)
(271)

None
8000
hrs/yr
(340)
(476)
(284)
(170)
(250)
(147)
(481)

None
Total Annua
(M$/vr5_ .
hrs/yr
736
987
632
415
568
375
996

160
8000
hrs/yr
804
1,083
689
450
618
405
1,093

160
ized Cost f
l$/Mg Product)1
hrs/yr
48.8
46.6
50.3
55.4
51.3
57.8
46.5

19.4
8000
hrs/yr
29.9
28.6
30.7
33.7
31.3
35.0
28.6

10.8
•Jl
I
ro
        'References I  to 3. 8 to 13.

        b.c.d,eSee footnotes in Table 5-Sa


         Includes the cost of benzene continuous monitoring  (approximately $7,000 per year per plant).

        9Costs shown are for a backup thermal incinerator unit.

-------
                                       Table 5-6b.EXISTING PLANT COSTS FOR ACHIEVING 99.5 PERCENT BENZENE EMISSION  REDUCTION3
                                                         CONTROL METHOD:  Thermal Incineration with Primary Heat Recovery
Plant Name and Location
1. Ashland-Heal, W. Va.
Z. Monsanto-St. Louis, Mo.
3. Oenka-Houston, Tex.
4. Reichhold-Elizabeth, N.J.
5. fieichhold-Morris, 111.
6. Tenneco-Fords, N.J.
7. U.S. Steel-Neville
Island, Pa.
8. Koppers-Brldgeville, Pa.9
Capacity
(Mq/yr)
27,200
38.1006
22,700
13,600
20,000
11,800
38,500
15,400
Installed
Cost (M$)B'C
2,220
2,960
1,930
1,330
1,770
1,210
2,990
632
Direct Operating
Cost fMJ/vrl
4500 .
hrs/yrd
665
919
562
352
500
309
926
32
8000
hrs/yr
1,083
1,505
911
561
807
491
1,520
32
AQC
(M$/yr)
450
601
391
270
359
246
607
128
Energy Recovery
Credit (MJ/vrl
4500
hrs/yr
(417)
(584)
(348)
(208)
(306)
(101)
(590)
None
8000
hrs/yr
(741)
(1,038)
(618)
(370)
(545)
(321)
(1,049)
None
-_.
-------
the costs for the 99.5 percent and 97 percent efficiency  adsorbers  are  direct-
ly or indirectly due to the additional  carbon required with the  more
efficient system.  Because the gas flowrates are the same,  costs for  duct-
work and other auxiliaries are equal, as are such operating costs  as  power
and caustic.  However, the capital costs for the adsorber vessels  and
carbon are different, along with such items as the steam  cost and  the ben-
zene recovery credit.
     Ranging from $1.24 to $3.35 million, the installed costs for the
99.5 percent adsorbers are moderately higher than those for the  incinera-
tion systems.  However, both the direct operating costs and the  recovery
credits are significantly lower than the corresponding values for the
incinerator.  The e*nd result is that their total annual ized costs are
virtually equal.  At 4500 hours/year, the total annualized cost  ranges
from $375,000 to 5996,000/year, versus a range of $374,000 to $945,OOO/
year for the incineration systems.  Similarly, at full capacity  operation,
the 99.5 percent adsorber total annualized cost ranges from $405,000  to
$1.09 million/year, compared to $416,000 to $1.08 million/year for the
incinerator.
     Clearly, for achievement of the 99.5 percent level,  the incinerator
is the least costly control option for some plants, while the adsorber is
the choice  for other installations.  However, in most cases, the difference
between costs for a given plant is less than six percent.  Moreover,
because this difference falls within the t 30 percent precision  afforded
these estimates, the choice of control options is not a clear one.
                                      5-34

-------
     The costs shown (in Tables  5-6a and 5-6b)  for the  Koppers  plant are
merely those for a backup incinerator system.   The investment  for  this
system is $590,000, while the total  annualized cost is $150,000  per year,
or $10 per Mg of product at full  capacity.   As discussed  above,  this
annualized cost includes fixed charges for  maintenance and  capitali-
zation of the control  system along with monitoring costs.
     The last cost table (Table  5-7 ) contains costs for  continuous moni-
toring of benzene stack emissions from both the 97 and 99.5 percent emis-
sion controls using a gas chromatograph with a dual flame detector.   The
installed cost of the chromatograph and its auxiliaries is  $30,000.
Depending on the operating factor, the direct operating cost varies from
about $1,200 to $1,400/year.  When the annualized capital  charges  are
added to this, the total annualized cost amounts to $7,300 and $7,500/year
for the 4500 and 8000 hours/year cases, respectively.   Needless  to say,
these costs are insignificant when compared to the costs  in Tables 5-5a,
5-5b, 5-6a, and 5-6b.
5.2.4  Cost-Effectiveness of the Alternative Emissions Limits
     For each of the control methods costed to achieve one or more of the
alternative emission limits considered herein, it is informative to com-
pare the total annualized cost with the amount of benzene removed. A
convenient yardstick for expressing this comparison is the cost-effective-
ness ratio.  This  ratio is the quotient of the annualized cost and the
quantity of benzene removed annually, usually expressed in units of
dollars per megagram.
     These ratios  and other important cost data appear in the cost sum-
mary table, Table  5-8 .  Three kinds of data are  shown:  total annualized

                                    5-35

-------
            TABLE 5-7.   COSTS FOR CONTINUOUS  MONITORING OF
                      BENZENE STACK EMISSIONS3»b
         Cost                              Operating  Factor  (hours/year)

                                            4500               8000


Installed                                  30000              30000


Direct Operating ($/year)                   1230               1370


Annualized Capital  ($/year)                 6080               6080


Total Annualized ($/year) (rounded)0        7300               7500
aReference 14.

bThese costs apply to all existing plants utilizing benzene  feed.


clncludes:  gas chromatograph with dual  flame detector,  automatic  gas
 sampling valve, air sampler, post-run calculator, and gas  regulators.
                                    5-36

-------
TABLE  5-B.   COST SUMMARY FOR EXISTING  KALEIC ANHYDRIDE PLANTS


            97  Percent  Benzene Emission Redjcticn

t ' .' u Idle I iSh
- ..J , ,.al. ,. '.= )
!'. • Jrtu ,Sl l'.ui£ . ".0 )
ui-i. (i — ton. Ilia;)6
- ' '.I...-.!!,. % J)«
• ' "J.,1 . Ill )
". > .. , uidi, '• J }
j -.n t:.L.ille 'sUnd, Pa )
• • - }*
Tiiiiel Incineration nth Primary Hut Recovery
-.500 tours/Year
Uc
fro'-3.,
i :tr
39 7
„,
16 1
18 S
43 1
SO 8
37 2
IE 2
riizcnc
Ri luted
998
13;6
-
-
734
433
1413
-
Ccst-efttc-
ixeness
'.!/Kg)d
607
566
-
-
659
777
568
-
8000 Hours/Year
TAC
23 B
22 3
9.0
10.5
25 6
30 0
22 4
10.2
Ctnzene
Removed
1773
2484
-
-
1304
769
2510
-
Cost-effec-
tiveness
366
343
-
-
393
463
344
-
brU,n 1
-
TAC
46 7
44 6
16.1
18 E
49.4
55 4
44 4
18.2
.5SO Hov,rs/Yea-
Ee-r.zer.e
958
1398
-
-
734
433
1413
-
Ctst-efftc-
twer.ess
714
£81
-
-
754
846
679
-
.dic'tllo..
E::: C.jrs/Ytar
TAC
'tt £
27 :
9.0
10 S
30.0
33 3
27 2
10.2
Ecn.-crt
1773
«,
-
-
1304
7£9
2510
-
Ccii-effec-
43B
4?0
-
-
461
512
418
•
             59.S Percent ttnzene Emsiion Reduction

r.,t :,.«,,! Locate
n.- ,ai2 ...1. ..' Va )
'.'.jntu '5: L.^IS. !'.C )
• - (' ., -lull. TL'O^)

. • . "-in . IT /
. , .u.. '. J )

-• :. K !
i
T-tr.ial Incineration »ith Prmary Heat Recovery
4500 Hours/Year
Fro'-'
46 3
44 2
-(. i
55 3
50 0
57.7

"
-
Benzene
Renoved
(«0/yr)
1020
1430
,54
512
752
444

:,=..
-
Cost-effec-
tiveness
(S/Hg)
691
659
717
£22
745
858

C57
-
8000 Hours/Year
TAC
29 4
28.2
30 5
34 5
31.5
35 9

:-.- 2

Benzene
Removed
1820
2550
1520
909
1340
789

:-570
-
Cost-effec-
tiveness
440
422
455
516
469
537

423
-
Carbon Adsorption
4500 Hours /Year
TAC
48 8
46 6
50 3
55 4
51.3
57 S

46 V
"
Renoved
1020
1430
«
112
752
444


'
Cast-effec-
tiveness
728
695
»
824
765
P.CO



8050 HOurs/Ytai
TAC
29 9
28 6
30 7
33 7
31 3
35 0

2i c.
•
Benzene
Removed
U20
2550
1S20
909
1340
785

?i70
-
Cost-effec-
t iv tress
446
«,
459
504
467
SI!

«..
-
                                         it  •  '. • I  11 : e '
                                         i  '  .  ii  " '.' ,
      i  i  1  i il Kin i >
                           5-37

-------
cost, the amount of benzene removed annually by the control method, and the
cost-effectiveness ratio.  Because the total annualized cost is expressed in
dollars per megagram of maleic anhydride produced annually, two costs are
given: one computed at 4500 hours/year operating factor, the other at full
capacity, or 8000 hours/year.  Unlike the numbers in Tables 5-5a to 5-6b,
these total annualized costs include the monitoring ccsts from Teble 5-7.
     Each "benzene removed" number is the product of the inlet emission
loading to the control method (see Table 5-3), and the control  efficiency.
Furthermore, as discussed above, the cost-effectiveness is the quotient of
the annualized cost and the benzene removed.
     Figures 5-6 and 5-7 depict the cost-effectiveness ratios for the 4500
and 8000 hours/year operating factors, respectively.  To better display the
data, the vertical  axes on these figures have been expanded.
     In Figures 5-6 and 5-7, note that the 99.5 percent curves  often lie
above the 97 percent curves, indicating that it may be more cost-effective
to control 97 percent than to 99.5 percent.   The reason for these results
must be explained relative to the two control techniques employed—thermal
incineration and carbon adsorption.
     Regarding incineration, the reason for  the difference is fairly simple:
the lower combustion temperature employed at the 97 percent control level
(as opposed to the 99.5 percent level ) more than offsets the relatively high
capital  costs for the system which are  similar to those encountered at the
higher control  level.   Consequently,  cost-effectiveness improves somewhat
at the 97 percent control  level,  although it does degenerate as lower control
levels are sought.
                                      5-38

-------
         Figure 5-6.  Cost-effectiveness of Alternative  Control  Systems
                              Operating Factor:   4500  hours/year
•o
0)

-------
       Figure 5-7.
                Cost-effectiveness of Alternative Control  Systems
                        Operating Factor:  8000 hours/year
    560
    540
    520
    500
480
    460
    440
 O)
 >  420
                                          I: Carbon adsorption  - 99.55*  control
                                         II: Thermal  incineration  - 99.5%  coniro
                                        III: Carbon adsorption  - 97%  control

                                         IV: Thermal  incineration  - 97% control
•a
01
OJ
03
c
Ol
IM
c
01
 o>
                    I


                  III
                        IV
 u
 O)
 O)
 I
 o
o
    400
    380
    360
    340
    320



      0
    1
        0
                    10              20             30

                             Plant  Capacity (Gg/year)
                                                                    40
                                       5-10

-------
     For the carbon adsorption case, the anomoly between the 97 and 99.5
percent control level costs apparently is due to the disproportionate  rela-
tionship between fixed and variable charges for systems operating at these
two control levels.  As the desired control level  decreases  from 99.5  to  97
percent, fixed system charges remain approximately similar,  lessening  only
slightly.   However, steam requirements for adsorber regeneration fall  off
rapidly as the control level  drops  from 99.5 to 97 percent.   In this respect,
the relative difference between the quantity of benzene removed at these  two
control levels is not sufficient to offset the disproportionate cost rela-
tionship and, thus, the cost-effectiveness at the  97 percent control level
appears improved.  However, as noted with thermal  incineration, cost-
effectiveness  ceases  to further improve for lower control levels and  eventu-
ally compares unfavorably with that of the 99.5 percent level.
     Finally, in both Figures 5-6 and 5-7, note that the curves slope  grad-
ually downward, with  increasing plant capacity.  This indicates a positive
economy of scale.  At 4500 hrs/year, for example, the 97 percent curve
decreases from $846/Mg to $679/Mg and from $777/Mg to $568/Mg, as the  plant
size goes from 11,800 to 38,100 Mg/year.  The corresponding ratios for
the 99.5 percent curves are $858/Mg to $657/Mg, and $860/Mg to $692/Mg.
For plant sizes above 40,000 Mg/year, the cost-effectiveness ratios
approach asymptotic values.  This behavior is reasonable when one con-
siders that, as the plant capacity increases, the influence of the fixed
costs on the total annualized cost becomes less and less pronounced,
while  the variable costs—those proportional  to production  capacity--become
more influential.  In other words, the  total  annualized cost becomes nearly
proportional to  the  production capacity.  Moreover, since the  amount of
benzene removed  is exactly proportional to production capacity,  the ratio of
these  quantities approaches a  constant  value.
                                      5-41

-------
5.2.5  Control Cost Comparison
     Before the accuracy and representativeness of control costs can be
ascertained, they must be compared with costs obtained from other data
sources.  In doing this, one can either compare the installed capital
costs, the annualized costs, or both.  However, since the capital costs
influence the annualized costs (via the annualized capital charges) and
because there is much more variability among the several terms in the
annualized cost (utilities, for instance), it is preferable to limit the
comparison to the installed costs.
     Even for a control system sized for a particular emission point,
the installed cost may vary considerably from site to site.  Such things
as the cost of installation labor (electricians, pipefitters, etc.), the
requirement for special installation materials (e.g., extra insulation
for systems installed in colder climates), and the presence or absence of
excess utility capacity considerably influence the total installed cost.
     Keeping this in mind, however, capital cost comparisons can be made
among a range of control system sizes.  This comparison is best made
graphically; that is, installed costs adjusted to the same reference date
(fourth quarter 1977, in this case) are plotted against some technical
parameter relevant to the control system.  In this section, installed
costs are compared among various sizes of carbon adsorbers and thermal
incinerators with primary heat recovery.  The technical parameters used
•in the comparisons are the gas volumetric flowrates at the control system
inlet and outlet, respectively.
                                     5-C2

-------
     For the carbon adsorbers, the capital costs developed for the
existing plants (Tables 5-5 and 5-6B) are compared with costs developed
by an EPA contractor and with an actual cost for a system installed at a
maleic anhydride plant.  These costs have been plotted against the inlet
volumetric flowrate on full logarithmic paper (Figure 5-8).  Note that
two EPA curves appear in the figure.  The top EPA curve applies to a
99.5 percent efficient adsorber, while the one beneath it is a unit
designed for 97 percent efficiency.
     Consider first the 99.5 percent adsorbers.  Figure 5-8 shows that
the contractor's costs (reference 1) exceed the EPA figures over the entire
range of 730 to 2,000 m/min.  However, the differences among the costs
range only from 5 to 21 percent, which falls within the ±30 percent
accuracy range assigned to the costs.
     Good agreement is also observed between the-EPA cost for 97 percent
control and the cost for a system at an actual installation (reference  15),
                                                    3
which operates at 95 percent efficiency.  At 1,220 m/min, the flowrate in
question, the installed costs are $1.25 million (EPA) and $1.06 million
(reference 10), or a difference of 18 percent.
     Figure 5-9 displays the installed costs for thermal incineration
systems with primary heat recovery.  The lone point on the figure represents
an incinerator operating at another maleic anhydride plant. 6  Its benzene
control efficiency is 98 percent, compared to 99.5 percent for the EPA
systems.
     The EPA cost at this flowrate (5,920 m3/min) is $1.24 million which is
$770,000 (62 percent) less than the industry figure.  Most of this discrepancy
is due to a design difference between the two units.  The plant system con-
tains a boiler for heat recovery, while the EPA system just utilizes a simple
                                        b-43

-------

                                                             i   . L.I  ..i..
                                 : .   .  :
Figure 5-8.   Installed Costs of Carbon Adsorbers

Referencet:l
   efficienoy)
                                           "Reference
              Inlet Gas Flowrate  (actual m /r,iin)
                               5-44

-------
   10
     7
                   Figure 5-9.   Installed  Costs  of Thermal  Incinerators with
                                Primary  Heat  Recovery
    ,4-




                                            \-\
                                                  r_.___T__           ^   _v:,.._r

                                                       Reference  16  (98%  efficiency)
• i
> I
1
 u
l/l
c
                  .!.  .LI   ..
                   I   -:•.•••)    :•
--'EPA (99.55^  efficiency)
                                                i    Reference  1  (99.5%  efficiency)
      i
                              diet  Gas  Flowiv'f  (actual nr/  n)
                                             5-45

-------
gas-to-gas heat exchanger.  As expected, the former system is the more
costly.
     On the other hand, the EPA costs are significantly higher than those
from reference 1, both of which represent 99.5 percent control efficiency.
The cost difference varies from 74 to 76 percent over the flowrate range
of 2,200 to 8,000 m3/min.  After examining the itemized costs from these
two data sources, it appears that most of the discrepancy is due to the
costs of the respective incinerator chambers.  In addition, the EPA figures
include costs for ductwork and stacks, while the contractor costs do not.
Still, given the potential variation in costs from site to site, such
differences are not unusual.
                                      5-46

-------
                       REFERENCES FOR SECTION 5.2
1.  Lawson, J.F.  Emissions Control  Options for the Synthetic Organic
    Chemicals Manufacturing Industry Maleic Anhydride - Product Report.
    Prepared by:Hydroscience, Inc.(Knoxville, Tennessee).Prepared
    for:  U.S. Environmental Protection Agency, Office of Air Quality
    Planning and Standards, Emission Standards and Engineering Division
    (Research Triangle Park, N.C.).   Contract No. 68-02-2577.  March 1978.

2.  Written communication between William M. Vatavuk (Economic Analysis
    Branch, Strategies and Air Standards Division) and Robert Weber
    (Chemical and Petroleum Branch,  Emission Standards and Engineering
    Division).  March 28, 1978.

3.  Kinkley, M.T. and R.B. Neveril.   Capital and Operating Costs of
    Selected Air Pollution Control  Systems.  Prepared by:  GARD, Inc.
    (Miles, Illinois).Prepared for:U.S. Environmental Protection
    Agency, Office of Air Quality Planning and Standards, Strategies
    and Air Standards Division (Research Triangle Park, N.C.). Contract
    No. 68-02-2072.  May 1976.

4.  Lav/son, J.F.  Emissions Control  Options for the Synthetic Organic
    Chemicals Manufacturing Industry Maleic Anhydride - Product Report.
    Prepared by:Hydroscience, Inc. (Knoxville, Tennessee).Prepared
    for:  U.S. Environmental Protection Agency, Office of Air Quality
    Planning and Standards, Emission Standards and Engineering Division
    (Research Triangle Park, N.C.).   Contract No. 68-02-2577.  March
    1978.

5.  Ibid.
6.  Written communication between William M. Vatavuk (Economic Analysis
    Branch, Strategies and Air Standards Division) and Robert Weber
    (Chemical and Petroleum Branch, Emission Standards and Engineering
    Division).  March 28, 1978.

7.  Written communication between William M. Vatavuk (U.S. Environmental
    Protection Agency, Office of Air Quality Planning and Standards,
    Strategies and Air Standards Division, Research Triangle Park, N.C.)
    and Joe Lorber (Hewlett-Packard, High Point, N.C.).  March 22, 1978.

8.   Written communication between P.S.  Hewett (Reichhold Chemicals, Inc.
     White Plains, New York) and D.R.  Patrick (U.S.  Environmental  Pro-
     tection Agency,  Office of Air Quality Planning  and Standards, Emission
     Standards and Engineering Division, Research Triangle Park,  N.C.)
     March 27, 1978.

9.   Guthrie, Kenneth M.   Process Plant  Estimating Evaluation and  Control.
     Craftsman Book Company of America (Los  Angeles, California).1974.
                                   5-47

-------
10.   Written communication between William M.  Vatavuk  (Economic Analysis
      Branch, Strategies and Air Standards Division)  and  Robert Weber
      (Chemical  and Petroleum Branch, Emission  Standards  and  Engineering
      Division).  June 27, 1978.

11.   Blacker, Herbert G. and Thomas M.  Nichols.   Capital  and  Operating
      Costs of Pollution Control Equipment Modules -  Vol.  II  - Data Manual.
      Prepared by:ICARUS Corporation (Silver  Spring,  Maryland).Prepared
      for:  U.S. Environmental  Protection Agency,  Office  of Research and
      Monitoring (Washington, D.C.)  Report No.  EPA-R5-73-023b.  July  1973.

12.   Chemical Marketing Reporter.   March 6, 1978.

13.   Chemical Engineering.  Economic Indicators,  February 13, 1978.

14.   Written communication between William M.  Vatavuk  (U.S.  Environmental
      Protection Agency, Office of Air Quality  Planning and Standards,
      Strategies and Air Standards Division, Research Triangle Park, N.C.)
      and Joe Lorber (Hewlett-Packard, High Point, N.C.).  March 22, 1978.

15.   Written communication between John F. Lawson (Hydroscience,  Inc.,
      Knoxville, Tennessee) and Robert C. Weber (U.S. Environmental
      Protection Agency, Office of Air Quality  Planning and Standards,
      Emission Standards and Engineering Division, Research Triangle Park,
      N.C. ).  November 1 , 1977.

16.   Chemical Engineering Progress.  August 1977.  pp. 69-73.
                                     5-48

-------
5.3.  ECONOMIC IMPACT OF ALTERNATIVE EMISSION CONTROL  SYSTEMS
5.3.1  Introduction
     This section discusses the economic impact of two possible benzene
control  standards for MA plants--97 percent and 99.5 percent emission
reductions.  Subsection 5.3.2 describes the impacts on individual  MA
manufacturers due to increased capital  budget requirements,  shifts in
competitive position due to unequal control costs, and other possible
costs borne by MA producers to meet other environmental  standards.  Sub-
section 5.3.3 describes the impact on the price of products  which  use
MA.  Subsection 5.3.4 describes effects on employment  and balance  of
trade.  Finally, the annualized costs incurred five years from now are
summarized in subsection 5.3.5.
5.3.2  Impact on Manufacturers
     The direct economic effect of a benzene control standard  would fall
on MA manufacturers that use benzene as a feedstock.  This impact, which
depends upon the level of benzene control required, principally involves
two areas—capital budget requirements and competition from domestic and
foreign producers.  Since the substitutes for MA are few and relatively
unimportant in its primary markets, little interindustry impact is
expected.
5.3.2.1  Capital Budget Requirements
     Two control levels for reducing benzene emissions are being consid-
ered:  97 percent and 99.5 percent reduction.  At each of these levels,
 three  plants  will  require  partial  or no  investment  in controls  because they
 already  meet  the standards.   These plants  are  Koppers  (PA)--which uses the in-
 cineration  technique  to  presently control  benzene—and  Koppers  (IL) and Amoco,

                                    5-49

-------
which do not use benzene as a feedstock,  Of these plants,  only Koppers
(PA) will need to invest in a backup system.  Table 5-9 shews  the  capital
budget requirements for (1) those plants requiring either carbon adsorp-
tion or incineration to achieve the standard being considered  and  (2)  for
those plants only requiring installation of a backup system to insure  un-
interrupted operation with controls.   It is important to note that  usider
the standards being determined, installation and maintenance of a  back-
up system is assumed.  Furthermore, the investment costs given in  the  table
do not credit partial controls already in place on MA plants presently not
meeting a possible standard.  Thus, for plants presently meeting some  lev-
el of benzene control, capital outlay assumptions for the 97 or 99.5 percent
emission reduction standard may represent a "worst case".
     In discussion of capital budget requirements, the main question is
whether MA producers will  have the financial resources from which  to fund
the initial capital investment.  Funding can occur either externally,  by
increasing debt, or internally, by using current capital budgets or
allocating funds from the capital budgets of other divisions in the  par-
ent company.  In addition to these financing techniques, costs can be
passed through to consumers by raising the price of MA or other products
produced by the firm to recover the capital expenses over a time period.
Finally, although the method or combination of methods firms may employ
to finance the additional  capital expenditures cannot be predicted,  it
is likely that the expenditures will be treated as part of the parent
company's overall capital  budget.
                                    5-50

-------
                   TABLE  5-9    ESTIMATED TOTAL INVESTMENT COST FOR ACHIEVING  BENZENE  EMISSION REDUCTION

P)&ni \ene & Location
1.


2.


3.

4.

5.


6.


7.


8
9
10.
Ashland
Neal . VA


Konsanto
St. LOJIS. MO


Denka
Houston, TX

Reichhold
Elizabeth. HJ

Reichhold.
Morris, IL


Tenneco
Fords, NJ


U S Steel
Neville Island. PA


Koppers
Bridgeville, PA
Koppers
Chicago, IL
A.-.QCO
Joliet. IL
Tjpe & Level of Control
CA
CA
!•
1
CA
CA
I
I
B
CA
I
B
CA
I
CA
CA
I
I
CA
CA
]
I
CA
CA
I
1
B
CA/I
CA/I
CA/1
97!
99 51
97*
99. SI
971
99 S".
971
99 Si
971
99.51
99. SI
971
99.51
99 SI
971
99.51
971
99 51
971
99.51
971
99 SI
97 S
99. SI
97*
99. SI
99. SI
97-99 SI
97-99.51
97-99.51
Control Equipment
Investment Cost
(103 dollars)
2370
2470
20RO
2220
3180
3320
2720
2960
763
2120
1930
S38
13BO
1330
1820
1900
1650
1770
1180
1240
1140
1210
3200
3350
2760
2990
590
0
0
0
Monitoring Equipment
Investment Cost
(103 dollars)
30
30
30
30
30
30
30
30
UNK
30
30
UHK
30
30
30
30
30
30
30
30
30
30
30
30
30
30
UHK
I'.'.K
UNK
UNK
Total Intestntrt
.Cost
(103 dollars)
2400
2JOO
2110
2<£0
3210
33SO
2750
2990
763
21SO
1960
538
U10
1360
1850
1930
1C80
2000
1210
1270
1170
1240
3230
3380
2790
3020
S90
0
0
0
CA = Carbon Adsorption with a  backup  sysleii.  I  •  Incineration with a backjp system, B * Backup System (Backup thermal  Incinerator
     for carbon adsorber and Incinerator.)
0'iK = Indicates that the cost  of  monitoring equipment  for  those  firms now meeting certain standard levels Is unknown
                                                              5-51

-------
     Besides the question of how the control  costs  might  be  financed is


the question of whether such an investment  is worthwhile.  This decision


depends on the importance of MA to total  company sales, capital availa-


bility, and the rate of return and risks  relative to  competing invest-


ment opportunities.  Since producers claim  that  MA  manufacturing  div-


isions are just "breaking even", this judgment also must  consider the antic-


ipated (not the current) high demand MA market of 1983, especially if firms


have enough flexibility to support the temporarily  ailing MA sector of


their business with other, more profitable  product  lines.


     Personal communication with company representatives  reveals  that of  the


eight companies which could be affected by  the proposed  benzene  standards,


six appear to have the ability to meet capital budget requirements.  The  other


two companies either would not or could not finance such  an  investment.


One of those, Tenneco, probably would not make such an investment, re-

                                     2
gardless of its financial capability.   Instead, the  company would invest


in projects that could yield higher profits,  and thus cease  manufacturing


MA.  Moreover, Tenneco1s maleic anhydride sales  as  a  percentage of total


company sales is the lowest of all affected companies, 0.06  percent (see


Table 5-10), which indicates that MA is not a critical part  of their


product mix.


     Only Denka expressed a concern that it could not finance benzene


pollution controls or the backup system required at the  97 percent ben-


zene reduction level.   The company already has made  a major capital out-


lay for benzene controls within the past two years; Denka still  is re-


covering from this investment.  It is a two-product company, with MA


sales representing thirty-three percent of its total  coi^pony sales.



                                    5-52

-------
        TABLE 5-10.   RATIO OF MA SALES TO PARENT COMPANY SALES3

1.
2.
3.
4.
5.
6.
7.
8.

Ashland
Monsanto
Denka
Reichhold
Tenneco
U.S. Steel
Koppers
Amoco
Sales of MA
(1976 $ Mil)
9.39
13.16
NAC
11.60
4.07
13.30
6.91
9.32
Parent Company Sales
(1976 $ Mil)
4087
4270
NA
585
6423
8604
1189
11532
MA Sales as !
Total Parent
pany Salesb
0.23%
0.31%
33.0%d
1.9%
0.06%
0.15%
0.58%
0.081!
8 of
Com'








3 56 percent capacity figure was assumed in calculating MA sales  for
  each company


  These figures were obtained from Business Week. June, 1977.


c NA = not available


  Personal communication with Mr.  Kendrik, Denka.
                               5-53

-------
To invest another 1.9 to 2.1 million dollars in new pollution control
equipment (or 0.76 million dollars in a backup system) could cause Denka
to go out of business, according to a Denka spokesman.
     Table 5-11  compares the cost of the least expensive control  option to
total capital expenditures of the MA companies.  Among the firms, Reichhold-
which had the highest control costs when expressed as a pc-rcentage of  its
capital budget—indicated that it intends to continue MA production.   The
capital budget requirement may affect Reichhold to a greater degree than
the other companies (outside of Denka); nevertheless, Reichhold likely
would fund needed control equipment and eventually pass costs to  the con-
sumer.
5.3.2.2  Intraindustry Competition
     Intraindustry competition prompted by a 97 or 99.5 percent benzene
emissions standard chiefly would involve the price differentials  in MA
merchant sales created by control costs being passed through to the con-
sumer.  Other potentially contributing factors are the interplay  of trans-
portation costs  and the prospect of import competition.  This section
summarizes possible effects of the above factors on competition within the
MA industry due  to imposition of a benzene control standard.
5.3.2.3  Effect  of Cost Pass-Through on Market Competition Due to Benzene
Emissions Control
     After funding initial capital to install controls, companies may  be
able to raise the price of their product (MA) to recover expenses incur-
red.   The price  increment each manufacturer would like to pass-through to
sales depends on the total investment costs and the quantity of product
                                    5-54

-------
                TABLE  5-11.   COMPARISON OF CONTROL COSTS TO

                     TOTAL  COMPANY CAPITAL EXPENDITURES

Ashland
Monsanto
Denka
Reichhold
Tenneco
U.S. Steel
Koppers
Amoco
T977
Capital
Expenditures
(106 dollars)
425
607
N/A
26
750
865
104
1862
Control Costs as % of Total
Company Capital Expenditures
97% Control a'b/
0.25%
0.23%
N/A
4.3%
0.08%
0.16%
0.28%
0%
99.5% Control9 'b/
0.27%
0.25%
N/A
6.3%
0.08%
0.17%
0.28%
0%
aAverage annual  capital  cost assuming two years installation time and
 financing.

 Assumed the least expensive control  between carbon adsorption and incinera-
 tion.

SOURCE:   Capital  expenditures are taken from Annual Reports and Form 10-K
         filed with the Securities and Exchange Commission Control Costs.
                                      5-55

-------
 produced  (i.e.,  the  number of units through which price increments can
 be  passed).
      The  MA  industry is  expanding production from approximately 56 percent
 toward  the 100 percent production figure predicted for the post-1983 per-
 iod.    Price  increments  due to cost pass-through thus should be viewed
 according to  two production scenarios — SB percent and 100 percent capa-
 city  utilization.  Tables 5-12 and 5-13 depict possible price increments
 of MA based on 100 percent cost pass-through and production capacities of
 56 percent and 100 percent, respectively.  In each case, the least expen-
 sive  control  option  is employed, and costs are passed through according
 to both the production figures of each company, and annualized captial
 control costs extended over a 10-year period.  For the case of 56 percent
 capacity  utilization, cost increments are based on the current actual
 price of  MA (61.7 cents/kilogram); for the case of 100 percent capacity
 utilization cost increments are based on the current list  price of MA
 (81.4 cents/kilogram), a price likely reflecting MA prices in a high-de-
mand market.*
      It should be noted, in reference to Tables 5-12 and 5-13, that cost
 pass-through is being examined to show the effect of price differentials
in the present MA market.  Recognition of the effect of cost pass-through
                          i
 in the present market contributes to understanding the potential  for its
occurrence.   This analysis is  not meant to suggest that cost pass-through
*
 MA currently is listed at 81.4 cents/kilogram (1978);  however, MA  current-
 ly sells for only 61.7 cents/kilogram.
                                       5-56

-------
             TABLE 5-12. POSSIBLE COST PASS-THROUGH UNDER CASE ASSUMPTION OF 56% PRODUCTION CAPACITY'
Company
1. Ashland
2. Monsanto
3. Denka
4. Reichhold (NJ)
5. Reichhold (IL)
6. Tenneco
7. U.S. Steel
8. Koppers (PA)
9. Koppers (II)
0. Amoco
97% Benzene Emissions Control Level
Increment
U/kg)
3.9
3.7
1.6
1.8
4.3
5.0
3.7
1.9
0
0
Total Cost
U/kg)
65.6
65.4
63.3
63.5
66.0
66.7
65.4
63.6
61.7
61.7
% Cost
Increase
6.3
6.0
2.6
2.9
7.0
8.1
6.0
3.1
0
0
99.5% Benzene Emissions Control Level
Increase
U/kg)
4.6
4.4
4.8
5.4
5.0
5.7
4.4
1.9
0
0
Total Cost
U/kg)
66.3
66.1
66.5
67.1
66.7
67.4
66.1
63.6
61.7
61.7
% Cost
Increase
7.5
7.1
7.2
8.8
8.1
9.2
7.1
3.1
0
0
aCosts are based on the current actual  price of MA,  61.7
-------
              TABLE  5-13.  POSSIBLE COST PASS-THROUGH UNDER CASE ASSUMPTION OF 100% PRODUCTION CAPACITY3
r  5'
01
Company
1. Ashland
2. Monsanto
3. Denka
4. Reichhold (NJ)
5. Reichhold (IL)
6. Tenneco
7. U.S. Steel
y Koppers (PA)
9. Koppers (IL)
0. Amoco
97% Benzene Emissions Control Level
Increment
U/kg)
2.4
2.2
0.9
1.0
2.5
2.9
2.2
1.0
-
-
Total Cost
U/kg)
83.8
83.6
82.3
82.4
83.9
84.3
83.6
82.4
81.4
81.4
% Cost
Increase
2.9
2.7
1.1
1.2
3.1
3.6
2.7
1.2
0
0
99.5% Benzene Emissions Control Level
Increment
U/kg)
2.9
2.8
3.0
3.3
3.1
3.5
2.8
1.0
-
-
Total Cost
U/kg)
84.3
84.2
84.4
84.7
84.5
84.9
84.2
82.4
81.4
81.4
% Cost
Increase
3.6
3.4
3.7
4.1
3.8
4.3
3.4
1.2
0
0
    Costs are based on the current list price of MA, 81.4
-------
will happen; indeed, later analysis will show that passing costs through--
unilaterally, in particular—is somewhat discouraged under the present
market conditions.
     Passing costs through to the product can create price differentials
between products of the different companies.  Under each benzene control
level--97 percent or 99.5 percent — some MA-producing companies are not re-
quired to install new benzene emissions controls; these companies incur no
new  expense and their products may remain at or near the same price, de-
pending on whether installation of a backup system is required.  Significant
price differentials thus may result between  the  products  of companies
funding control  costs and passing them through,  and  those of companies
not installing  controls  and/or choosing not  to pass  expense through  to
the consumer.
     Intraindustry competition caused by MA  price differentials  (resulting
from cost pass-through of benzene controls)  is sensitive  to the  operating
rate of the MA  industry, whether at the present  rate  of approximately  56
percent capacity, or at  the  anticipated rate of  100  percent capacity
following 1983.   Table 5-12  shows that, in  the present  market, passing
benzene control  costs through 100 percent can  raise  product prices  by  up
to 8.1  percent  in the 97 percent control  case, and by up  to 9.2  percent in
the 99.5  percent control case for an  individual  plant.   In the high  demand,
full  capacity utilization market (Table 5-13), potential  cost increments
would be  lower,  varying  from 3.6 to 4.3 percent  for  the 97 and 99.5  per-
cent control  cases,  respectively.   Under both  control  and capacity  utiliz-
ation assumptions,  Tenneco may be forced to  raise prices  the most,
assuming  they choose to  pass costs through.
                                    5-59

-------
     It must be emphasized that, when intraindustry competition  is  viewed

relative to possible MA price increases from cost  pass-through,  the major

arena of competition involves merchant, rather than captive,  markets.

While costs may be passed through both markets, the greatest  direct effect

is seen in merchant sales which compete with MA of all  producers.   Con-

versely, price increments in the captive MA market emerge  only in  the  final

product, having been diluted by costs of other constituents also necessary

to production of the final product.  The effect of this "dilution"  is  quite

substantial (see section 5.2.4).  The following subsections,  therefore,

focus on the effects of cost differentials on MA merchant  sales  in  both  the

present and post-1983 scenarios of MA production rate.

5.3.2.3.1  Price Differentials and the Present MA Market

     Raising prices in a low-demand market is not  an auspicious  prospect.

Price elasticities governing the present MA market simply  are not  known.

However, the MA industry has indicated that it would be quite reluctant

to raise prices under present market  conditions; conversely, because most

MA manufacturers are part of larger parent  firms having other products, an

alternative choice  to total MA  cost pass-through is to partially or totally

pass costs through  to other products.    Some members of the MA  industry

have noted employing this option,  assuming  the  choice  is made to install
                                            Q
benzene  emissions  control under a  standard.

     Tables 5-14 and 5-15 further  examine  the  effect of cost pass-through

for two benzene control  levels, based on the 56 percent production  rate

which approximates present MA operating conditions.  Numbers  in  the table

indicate the price differential (in cents per kilogram) between  company
                                   5-60

-------
           TABLE  5-14.  DEPICTION OF POSSIBLE COMPETITIVE  ADVANTAGES DUE TO COST PASS-THROUGH
                           UNDER THE 56 PERCENT  PRODUCTION  'CAPACITY  ASSUMPTION3

                         (97% Benzene Emissions  Control  Level  With  Backup Systems)
^^^^^Company
Competitor****^,^
27* ASHLAND
48 MONSANTO
23 DENKA
.. REICHHOLD
" (NJ.)
,n REICHHOLO
20 (ILL)
\2 TENNECO
38 U.S. STEEL
., KOPPERS
1S (PA.)
, KOPPERS
5 (ILL/
27 AMOCO
ASHLAND

+0.2
+2.3
+2.1
-0.4
(-0.6)
-1.1
(-1.6)
+0.2
+2.0
+3.9
+3.9
MONSANTO
-0.2
(-0.3)

+2.1
+1.9
-0.6
(-0.9)
-1.3
(-1.9)
0
+1.8
+3.7
+3.7
DENKA
-2.3
(-3.5)
-2.1
(-3.2)

-0.2
(-0.3)
-2.7
(-4.1)
-3.4
(-5.1)
-2.1
(-3.2)
-0.3
(-0.5)
+1.6
+1.6
REICHHOLD

-------
        TABLE
5-15.
DEPICTION OF POSSIBLE COMPETITIVE ADVANTAGES  DUE  TO COST PASS-THROUGH UNDER
                 56?', PRODUCTION CAPACITY ASSUMPTION3

             (99.5% Benzene Emissions  Control  Level)
THE
^^^^Company
Compcli lor**>«KX>^
27* ASHLAND
48 MONSANTO
23 OENKA
.. REICHHOLD
" (NJ.)
„ REICHHOLO
20 (ILL.)
12 TENNECO
38 U.S. STEEL
., KOPPERS
n (PA.)
KOPPERS
5 (ILL.)'
27 AMOCO
ASHLAND

+0.2
-0.2
(-0.3)
-0.8
(-1.2)
-0.4
(-0.5)
-1.1
(-1.6)
+0.2
+2.6
+4.6
+4.6
MONSANTO
-0.2
(-0.3)

-0.4
(-0.6)
-1.0
(-1.5)
-0.6
(-0.8)
-1.3
(-2.0)
same
+2.4
+4.4
+4.4
OENKA
+0.2
+0.4

-0.6
(-0.9)
-0.2
(-0.?)
-0.9
(-1.3)
+0.4
+2.8
+4.8
+4.8
REICHHOLD
(NJ.)
+0.8
+1.0
+0.6

+0.4
-0.3
(-0.4)
+1.0
+3.4
+5.4
+5.4
REICHHOLD
(ILL.)
+0.4
+0.6
+0.2
-0.4
(-0.7)

-0.7
(-1.2)
+0.6
+3.0
+5.0
+5.0
TENNECO
+1.1
+ 1.3
+0.9
+0.3
+0.7

+1.3
+3.7
+5.7
+5.7
U.S. STEEL
-0.2
(-0.3)
same
-0.4
(-0.6)
-1.0
(-1.5)
-0.6
(-0.8)
-1.3
(-1.9)

+2.4
+4.4
+4.4
KOPPERS
(PA.)
-2.6
(-3.9)
-2.4
(-3.6)
-2.8
(-4.2)
-3.4
(-5.0)
-3.0
(-4.5)
-3.7
(-5.5)
-2.4
(-3.6)

+2.0
+2.2
KOPPERS
(ILL)
-4.6
(-6.9)
-4.4
(-6.7)
-4.8
(-7.2)
-5.4
(-8.0)
-5.0
(-7.4)
-5.7
(-8.5)
-4.4
(-6.7)
-2.0
(-3.1)

same
AMOCO
-4.6
(-6.9)
-4.4
(-6.7)
-4.8
(-7.2)
-5.4
(-8.0)
-5.0
(-7.4)
-5.7
(-8.5)
-4.4
(-6.7)
-2.0
(-3.1)
same

 • Numbers refer to Nameplale Capacity (Gg)

aTop number in grid represents price differential  between  companies; negative sign indicates company  has
 lower price than competitor.  Number  in  parenthesis  depicts  potential  advantage in terms of cost-differential
 expressed in percent (current list price  of  MA  is  basis:   81.4if/kg).

-------
and competitor assuming 100 percent cost pass-through;  negative  numbers
indicate a price advantage over a competitor and the accompanying  per-
centage expresses that advantage in terms of a price differential  divided
by the assumed base price of MA prior to cost pass-through.   Positive
table numbers indicate that a company is marketing its  MA at a higher
price than its competitor.  For example, Table 5-14 shows that Ashland1s
product sells for 0.2 cents more per kilogram than Monsanto1s; conse-
quently, Monsanto may sell its product for less at a 0.3 percent differen-
tial over Ashland.
     Under a 97 percent benzene control  assumption, five companies would  be
required to install total control systems:  Ashland, Monsanto, Reichhold
(IL), U.S. Steel, and Tenneco.  If these companies decided to pass costs
through 100 percent, they would be competing with other companies that  had
not installed new controls or that had only required backup systems, and
whose MA prices consequently could be lower.
     Table 5-14 shows that Tenneco (potentially the producer with the largest
price increment (5.0 cents/kilogram), could be at a competitive disadvantage
with other MA producers under a 97 percent benzene control standard. Of
the competitors, all except Koppers (IL) have production capacities exceed-
ing Tenneco's.  Indeed, all have residual production capacity which would
be used to capture part or all of Tenneco's market should price differen-
tials encourage it.  Similar situations, to a lesser extent, could exist
for the other three companies required to install controls if they decide
to pass costs through.
     A 99.5 percent benzene emissions control would impose a similar situ-
ation, since the same number of companies would be financially un-
                                   5-63

-------
affected by the standard (Table 5-15).*  Under the 99.5 percent  control
case, only Amoco and Koppers (IL) plant would not have to fund new  control
hardware.  Again, Tenneco could establish the greatest price increase
(5.7 cents/kilogram) putting itself at a possible disadvantage with its
competitors.  More companies would face similar situations,  however, with
the regaining, non-affected companies — toppers (II.) and A;?oco--not  having
enough residual capacity to capture all of the affected companies'  mar-
kets.  This situation would favor, to a degree, some cost pass-through,
assuming the absence of import competition (see section 5.3.3.3).
     The effect of financing benzene emissions controls in today's  MA  mar-
ket may be summarized.  In general, passing the costs of benzene controls
through to MA may be Difficult since MA demand is low, the market is quite
competitive, and at least two companies, Koppers (IL) and Amoco, need  not
incur any new expense to meet a possible benzene emission standard.  Due
to these circulstances, MA companies financially affected by the standard
may choose partial or total pass-through of benzene control  costs to other
company products as a means of offsetting the costs associated with re-
quired controls, while not placing themselves at a competitive  disadvan-
tage.  Nevertheless, companies may not choose this option for a  number of
reasons.
     In spite of the depressed MA market situation, companies may choose in-
stead to raise MA prices.  Eight out of 10 MA companies are required to  install
hardware (either total systems or backup) under the standard at  both 97  and
99.5 percent benzene emission levels and each of these companies will  want  to
pass control costs through to the consumer.   If all or several  companies with
 The term'financially unaffected" pertains to co;,ipcnies r,ow meeting possible
 standard levels which will not be required to nv-tdll a total control system
3rd, a;, i/orst, will only be required to install uackujj systems.

-------
large capacities independently decide to  pass  costs  through  to  MA, the
market system may be able to sustain the  higher MA prices.   In  this rase,
Amoco and Koppers would impose a limited  threat of competition  since  neither
company could produce MA in quantities sufficient to fulfill  the  entire
domestic MA demand.   Furthermore, Amoco,  one of the  largest  MA  producers,
has invested large sums of money into the research and development of
its n-butane process.  According to an Amoco spokesman, the  company would
                                                                           g
readily raise prices to offset high R&D costs  if a favorable market existed.
Thus, in the absense of import competition, higher MA prices may  be a pos-
sible option for MA manufacturers even in today's market.
5.3.2.3.2  Price Differentials and  the Future  MA Market (at  100 percent
capacity utilization)
     Within the next five years, the MA market is expected to increase in
demand, corresponding to a 100 percent production rate of present MA
capacity.10  As this high demand market is approached, increasing the
price of MA will become more auspicious,  and cost pass-through, thus, more
possible.  Furthermore, as the base price of MA increases to meet market
demand (regardless of a benzene standard), price increments  due to control
cost pass-through become less significant.  Table 5-13 (previously cited)
shows that the highest MA price increments under both the  97 and  99.5 per-
cent control level are 3.6 and 4.3 percent, respectively.
     MA price differentials created from passing benzene control  costs
through to the consumer may not occur in  an industry running at 100 per-
cent production capacity.  The largest producers are likely  to  be the
price leaders when demand picks up; thus, Monsanto and U.S.  Steel may set
                                  5-65

-------
prices in the high-demand market of 1983.   Monsanto  and  U.S.  Steel, the



largest MA producers, are both affected by the  two possible  benzene control



level requirements.  However, it is likely that if market  demand  increases



and no new MA capacity is built, prices will  rise to accomodate passing



benzene control costs through with no concomitant loss in  sales.   (This



assumes, of course, no import competition; see  following sections.)



5.3.2.3.3  Effect of Transportation on Intraindustry Impact!



     Transportation charges can affect the delivered cost  of MA.   Present-



ly, costs for transporting MA by train average  0.005 cents/kilogram-mile,



and by truck, 0.01 cents/kilogram-mile.    Thus, for every 100 miles of



transport, the final cost of MA can increase  from 0.5 to 1.0 cent.  How-



ever, MA is not presently a regional  product  because the market is over-



supplied; suppliers send MA wherever the demand exists.  Transportation



costs therefore can be several  cents  higher.  The current  average trans-



portation cost quoted is 3.86 cents/kilogram, or between 300 and  400


                   12
miles of transport.    Thus, the final  delivered price of  MA may  average



65.3 cents/kilogram in today's market.



     If MA prices do increase, some companies could  have an  advantage



over others in terms of transport credit.   That is,  considering MA prices



of two competitors, a differential  between the  prices of their products



could allow the lower priced product further  transport distance before a



"break-even" price with its more expensive competitor is reached.  In an



excess capacity, low demand market—as the MA market is  today—such price



differentials could allow one company to penetrate the regional market of



another.
                                     5-66

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     This possibility is illustrated in  Tables  5-16  and  5-17, under
different benzene emissions control  levels.   The  tables  assume  regional
markets exist for each company.   Companies  possibly  breaking into a
competitor's market area are shown  horizontally,  in  the  top row of the
table.   If a company from that  row  has a  lower  priced  product than its
competitor (shown in the vertical column),  then the  company is  given
appropriate transport credit {in  miles)  equivalent to  the  price differ-
ential  between the two companies' products.   The  distance  between com-
peting companies also is shown  in the table,  in the  bottom number of each
applicable grid.  If a competitor has transport credit exceeding that
distance, then market penetration of a competitor is possible.  However,
it must be pointed out that many  MA companies have an  average market
radius  of between 300 and 400 miles.   Consequently,  if between  600 and
800 miles is subtracted from the  distance shown between  two companies,
it is evident that many companies already compete in common market re-
gions.   Another unknown factor  is where, within each plant's  radius, is
its major market concentrated.
      Tables 5-16 and 5-17 were calculated using the differential  between
companies at 56 percent capacity, assuming both a 97 percent  and a 99.5  per-
cent control level for benzene  emissions, respectively.   The  transportation
effects at 100 percent capacity utilization were not included  because, at
that utilization rate, companies  would be selling to a high-demand market
in which lack of buyer should not be an  issue remedied by transport  to
other markets.  At the 56 percent production capacity  of today's market,
however, lack of buyer is an issue.
                                     5-67

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                     TABLE  5-16.   EFFECT  OF  TRANSPORTATION UNDER A 97 PERCENT CONTROL STANDARD
                                 (Industry at 56% Production Capacity Utilization)3

                                   COMPANIES  POSSIBLY ENTERING COMPETITORS'  MARKET
^^**^^Company
Compel) lor^*****^^
27* ASHLAND

48 MONSANTO

23 DENKA

,. REICHHOLD
(NJ.)
„ REICHHOLD
20 (ILL)
U TEN N ECO

IB ii « STFR

., KOPPERS
15 (PA.)
KOPPERS
b (ILL)'
27 AMOCO
ASHLAND


MTC

NTC

NTC

40
576
110
527
NTC

NTC

NTC
NTC
MONSANTO
20
509


NTC

NTC

60
222
130
930
NTC

NTC

NTC
NTC
DENKA
230
1278"
210
779


20
1555
270
967
340
1558
210
1313
30
1288
NTC
NTC
REICHHOLD
(NJ.)
210
524
190
927
NTC



250
913
320
50
190
339
10
364
NTC
NTC
REICHHOLD
(ILL.)
NTC

NTC

NTC

NTC



70
915
NTC

NTC

NTC
NTC
TENNECO
NTC

NTC

NTC

NTC

NTC



NTC

NTC

NTC
NTC
U.S. STEEL
20
213
NTC

NTC

NTC

60
574
130
341


NTC

NTC
NTC
KOPPERS
(PA.)
200
163
180
563
NTC

NTC

240
314
310
366
180
100


NTC
NTC
KOPPERS
(ILL.)
390
457
370
289
160
1067"
180
755
430
100
500
752
370
452
200
452

NTC
AMOCO
390
442
370
274
160
1052
180
770
430
15
500
767
370
465
200
4T5
NTC

en

CO
     ' Numbers refer to Nameplate Capacity (Gg)

     3A/B  = numbers  in table; where A  is  the  number of miles designated companies can possibly penetrate their
     competitor's market.   These  figures are based on price differentials between plants operating at 56 percent
     capacity with  the 85  percent carbon absorption control.   A 0.01 it/kilogram-mile transportation cost was
     assumed in the calculations; B is the number  of miles  between designated companies.
    NTC  = No Transportation Credit

-------
                  TABLE    5-17.  EFFECT OF TRANSPORTATION UNDER  A  99.5  PERCENT CONTROL STANDARD
                                 (Industry at 56''  Production  Capacity Utilization)3

                                  COMPANIES POSSIBLY  ENTERING  COMPETITOR'S  MARKET
^"***>^Coinpany
Compel) tor"""*'*^^

27* ASHLAND

48 MONSANTO

23 DENKA
REICHHOLO
14 (NJ.)
REICHHOLO
20 (ILL)

12 TENNECO

38 U.S. STEEL
V HDD TDC
,, KUrrcKS
15 (PA.)
. KOPPERS
5 (ILL]f
27 AMOCO
ASHLAND


NTC

20
T278
80
524"
40
576
110
527
NTC

NTC

NTC
NTC
MONSANTO
20
509


40
779
100
927
60
222
130
930
NTC

NTC

NTC
NTC
DENKA
NTC

NTC



60
1555
20
967
90
1558
NTC

NTC

NTC
NTC
REICHHOLD
(NJ.)
NTC

NTC

NTC



NTC

30
50
NTC

NTC

NTC
NTC
REICHHOLD
(ILL.)
NTC

NTC

NTC

40
913


70
9T5"
NTC

NTC

NTC
NTC
TENNECO
NTC

NTC

NTC

NTC

NTC



NTC

NTC

NTC
NTC
U.S. STEEL
20
213
1
588
40
1313
100
339
60
574
130
341


NTC

NTC
NTC
KOPPERS
(PA.)
260
163
24C
563
280
1288
340
364
300
314
370
366
240
100


NTC
NTC
KOPPERS
(ILL.)
460
457
440
289
480
1067
540
755
500
100
570
752
440
452
200
452

NTC
AMOCO
460
442
440
274
480
1052
540
770
500
15
570
767
440
465
200
475
NTC

I
a>
kO
     ' Numbcis refer to Nameplate Capacity (Gg)

      aA/B =  numbers in table;  where A is the number of miles designated companies can possibly penetrate their
       competitors'  market.   These figures are based on price differentials between plants operating at  56  percent
       capacity with the  99.5 percent thermal incineration control.  A O.OU/kilogram-mile transportation cost
       was assumed in the calculations; B is the number of miles between designated companies.
      NTC = No Transportation Credit

-------
     Table 5-T6 shows that, under a 97 percent benzene control  level,
the companies having the greatest potential  for regional  market pene-
tration (due to MA price differentials) are  Denka, Reichhold (IJJ),  U.S.
Steel, Koppers, and Amoco.  Of these, Amoco  presents the  greatest  po-
tential problem because of its large, residual  production capacity,
which can be used to capture part of competitor's markets.
      Table  5-17  shows  that, under a  99.5 percent  benzene emissions control,
 financially  affected companies face  potential regional market penetration
 by  a  greater number of competitors.   In this scenario, however, Amoco again
presents the greatest threat due to both its potentially  large  transport
credit and its large residual  production capacity.
     Although both tables show that the competitive position of MA  com-
panies due to price differentials can be enhanced by transportation,  the
prospect of this situation occurring is unknown.   In the  present market,
transportation costs limit the regional market of a producer to a  radius
of about 300 to 400 miles.  Under a benzene  emissions standard, assuming
industries decide to pass control costs through,  transportation may be
used to sell MA beyond the traditional 300 to 400 mile market radius  and
 still  meet  competitive  prices in certain cases as  illustrated in the tables.
 Whether companies will  pass costs through and employ this method to achieve
 market penetration of  a competitor cannot be determined.   If MA producers
 elect  to absorb  pollution control cost and not raise prices, transportation
 costs  then  could serve  to restrict market radii to  below 300 or 400 miles.
 In  this case,  regional  market penetration of a competitor would not be pro-
 fitable and  would have  low probability of occurring.
                                     5-70

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5.3.2.4  Effect of Imports
     The effect imports  have  on  the present  MA market  is  small.   In 1977,
imports accounted for only  5.4  percent of the U.S. MA  demand  and  for only
about 5.6 percent of the total  merchant sales MA.    The  effect imports
have on the future MA market  is  uncertain, however.
     Maleic anhydride is produced in two forms:   molten and  briquettes.
Molten MA is the preferred  form for large consumers, accounting for 90
percent of the domestic  MA  output.14  The other  ten  percent  of MA is con-
verted into briquettes,  the form of all imported MA.     Because briquettes
can be converted to the  molten form only at a  cost,  and  because briquettes
have a limited shelf-life,  imported MA competes  primarily with domestic
MA briquettes, and not with the "molten market".
     Imports could be a  problem for U.S. MA briquette  producers.   Although
small quantities of imported MA have not interfered with domestic pro-
duction, recent MA imports may pose problems.   At times, imports  have  sold
for nine cents less per kilogram than domestic briquettes (which  represent
10 percent of U.S. MA production), although imports now sell for  only  two
cents  less per kilogram than U.S.  briquettes. 6  Prices could drop again,
however.   Foreign manufacturers are producing MA at below capacity and
could  readily  expand  if the demand existed.  Moreover, imports may con-
tinue  to compete with U.S. briquettes,  particularly in the West Coast
market,  because  imports arriving there  incur little additional overland
 freight  charges.
      Countering  the  potential of foreign  competition  is  the  fact  that MA
 production costs  are  rising  abroad and  the  possibility that  foreign gov-
 ernment subsidizing  MA  production  may cease this  subsidy.    Furthermore,
                                      5-71

-------
it should be reiterated that the degree of forcing  competition  is  some-
i/hat limited, since the major arena of competition  is  briquette f'A
which comprises only 10 percent of the domestic market.
     Overall, the cost of benzene controls on domestic MA production may
be somewhat exacerbated by foreign imports within  the  next five years.
However, the U.S. has always met imported MA prices;  if  they continue  10
do so without incurring a loss until  the post-1983  high-demand  market  is
reached, then imports should not present a problem.
5.3.2.5.  Summary of Impact on Manufacturers
     Table 5-18 and 5-19 summarize the major impacts  on  the manufacturer
arising from capital budget requirements and intraindustry competition
under two benzene control levels, 97 and 99.5 percent, respectively.
Impacts of capital budget requirements show Tenneco and  Denka to be pos-
sibly the most affected.  Impacts of intraindustry  competition  show
possible competition arising from benzene control  cost pass-through in
the present market, and the greater potential for  cost pass-through
in the future, high demand market.  Overall, the prospect of offsetting
add-on benzene control costs and augmenting profits is enhanced in the
future, high demand market of 1983.
5.3.3  Effect on Product Prices
5.3.3.1  Cost Pass-Through to the Final Consumer
     MA is purchased by manufacturers for use as an intermediate in the
production of various end-products.  Should MA producers raise their
product prices due to pollution installation costs, purchasers of MA
will feel the greatest economic impact of these increments.  It there-
fore is likely taht MA users, like MA producers, will  choose to raise

                                     5-72

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                           TABLE 5-18.  SUMMARY OF IMPACT OF 97% BENZENE CONTROL LEVEL ON MA COMPANIES
                      Capital Budget  Requirements
                                                                                     Intraindustry Impact.
                                   At 56% Production  Capacity  (Present)
                                       At 100% Production  Capacity (1903)
 MOMS ditto
 Dcnka
en
i
CO
  Reichhold, NJ
  Ruicliliolcl,  IL
  Teimeco
                    • Could fund costs and continue
                      production
• Could fund costs and continue
  production
• Would not need to install  a
  total control  system, but
  would need a backup system
• May not be able to meet capi-
  tal budget requirements from
  internal resources
• May choose to discontinue
  production

• Would not need to install  a
  total control  system, but
  would need a backup system
• Could fund costs and continue
  production

• Could fund costs and continue
  production
• Could fund costs but may choose
  to discontinue MA production
• Would have to pass costs through MA
  or other product line
• Could face competition with Monsanto,
  U.S. Steel, Koppers, and Amoco

• Would have to pass costs through MA
  or other product line
• Could face competition from U.S.
  Steel, Koppers, and Amoco

• Would have to pass costs through MA
  or other product line
• Should have no new regional com-
  petitors
• Would have to pass costs through MA
  or other product lino
• Could face competition from Koppers
  and Amoco
• Would have to pass costs through MA
  or other product line
• Could face competition from Ashland,
  U.S. Steel, Reichhold, Koppers,
  Monsanto, and Amoco

• Would have highest production costs
  due to benzene control investment
• Could face competition from Reich-
  hold, Koppers, U.S. Steel, and
  Ashland
                                                                          • Could pass costs through
                                                                            without sales loss
• Could pass costs through
  without sales loss
• Could pass costs through
  without sales loss
• Could pass costs through
  without sales loss
• Could pass costs through
  without sales loss
• Could pass costs through
  without sales loss

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                   1ABLL 5-18. SUMMARY Of IMPACT OF 97% BENZENE CONTROL LEVEL ON MA COMPANIES (Continued)
                     Cnpilnl Budget Requirements
                                                                                    Intra Indus try  Impact
                                   At 56%  Production  Capacity (Present)
                                       At 100%  Production  Ciip.icily
U.S. Steel
Koppers, PA
Koppcrs, IL
Amoco
t Could fund costs and continue
  production
• Would not need to install  a
  total control  system, but
  would need a backup system
t Could fund costs and continue
  production

t Would not need to install
  controls
• Would not need to install
  controls
• Would have to pass costs through MA
  or other product line
e Could face competition from Koppers
  (IL) and Amoco.

t Would have to pass costs through MA
  or other product line
• Could face competition from Ashland
  or U.S.  Steel
• Would not have to pass costs or
  raise prices


• Would not have to pass costs or
  raise prices
                                                                                             • Could pass costs  through
                                                                                               without sales loss
                                                                                             • Possible price leader
• Could pass costs through
  without sales loss
• Same as in present market
• Would likely raise prices in
  response to demand

• Same as in present market
• Would likely raise prices in
  response to demand

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                       TABLE 5-19.  SUMMARY  OF  IMPACT OF  99.5% BENZENE  CONTROL  LEVEL  ON MA  COMPANIES
                       Capital  Budget Requirements
                                                                                     Inlraindustry  Impact
                                   At 56% Production  Capacity  (Present)
                                       At 100X Production  Capacity  (19H.1)
  Ashland
  Monsanto
  Denka
  Reichhold, NJ
Ul
-J
en
  Rnichhold, IL
  Tonneco
  U.S. Steel
• Could fund costs and continue
  production
t Could fund costs and continue
  production
• May not be able to meet capi-
  tal budget requirements from
  internal resources
t May choose to discontinue
  production

• Could fund costs and continue
  production
• Could fund costs and continue
  production
t Could fund costs, but may
  choose to discontinue produc-
  tion
0 Could fund costs and continue
  production
• Mould have to pass costs through MA
  or other product line
• Could face competition from Koppers
  (IL) and Amoco

• Would have to pass costs through MA
  or other product line
• Could face competition from Koppers
  (IL) and Amoco

• Mould have to pass costs through MA
  or other product line
• Should have no new regional com-
  petitors
• Would have to pass costs through MA
  or other product line
• Could face competition from Koppers
  (IL) and Amoco

• Would have to pass costs through MA
  or other product line
• Could face competition from Koppers
  (IL) and Amoco

• Would have highest production costs
  due to benzene control investment
• Could face competition from U.S.
  Steel, Koppers (IL) and Amoco

• Would have to pass costs through MA
  or other product line
• Could face competition from Koppers
  (IL) and Amoco
• Could pass costs through
  without sales loss
a Could pass costs through
  without sales loss
• Possible price leader
• Could pass costs through
  withoug sales loss
« Could pass costs through
  without sales loss
• Could pass costs through
  without sales loss
• Could pass costs through
  wi thout sales loss
• Could pass costs through
  without sales loss
« Possible price leader

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                       TAIU.E 5-19.  SUMMARY  OF  IMPACT  OF  99.52 BENZENE CONTROL  LEVEL OH MA COMPANIES (Continued)
                       Cnpil.nl Budget Requirements
                                                                                      Inlrainduslry Impacl
                                    At  56X Production Capacity (Present)
                                        At  100* I'rodur.l.ion CapncHy (1
  toppers,  PA
  Koppers,  IL
  Amoco
• Would not need to install  a
  total control system, but  would
  need a backup system
t Could fund costs and continue
  production

• Would not need to install
  controls
• Would not need to install
  controls
• Would have to pass costs through MA
  or other product line
• Would not have to pass costs or
  raise prices


• Would not have to pass costs or
  raise prices
• Could pass costs through
  without sales loss.
• Same as in present market
• Would likely raise prices
  in response to demand

• Same as in present market
• Would likely raise prices
  in response to demand
cr«

-------
prices of their products to offset higher production costs.   Price  incre-
ments of these products should not be as high as  potential  MA price incre-
ments, since MA accounts for only a percentage of the wholesale  price of
each product; thus,  the impact of increased MA prices should  be  diluted
in the final product.
     KA is used as an  intermediate in the production of several  products,
mainly polyester resins, agricultural chemicals and fumaric acids.
Tables 5-20, 5-21, and 5-22 show how increased MA prices could affect
the prices of these products.  Product price increments depend on  the
percent of MA in the product, and the percent of its wholesale price
attributed to MA.  These factors contribute to the varying increments
associated with each product.
      The  predominant end use of MA is the production of unsaturated poly-
ester resins  (58  percent of MA demand) which go into reinforced plastic
applications  such as marine craft, building panels, automobiles, tanks
and pipes.  Currently, these resins  sell for 55$ to $3.30/kilogram.
Should MA prices  increase, polyester resins could  rise from 0.3 to 0.8
cents/kilogram for each resin currently priced at  55 cents/kilogram and
from  1.8  to 4.6 cents/kilogram for resins priced at $3.30/kilogram.*
These increments  are relatively small, since MA accounts for only 15
percent of  the total sales price of  these resins;  they represent only
a  0.5 to  1.5  percent increase over the wholesale price of  resins.
*
  Increments reflect the maximum  range of increments that could  occur using
  the  worse  price  increases associated with  the least  expensive  add-on con-
  trol options at  97 and 99.5  percent benzene  control.
                                     5-77

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                     TABLE  5-20.   PRICE INCREASES OF POLYESTER RESINS DUE TO INCREASED MA PRICES
00

"i Control
of Benzene
Emissions
97

99.5

Production
Capacity of
MA Plant («)
56
100
56
100
Present Whole-
sale Price of
Polyester Resins
(it/kilogram)
55-330

55-330

% of Wholesale Price Increase
Price of Polyester of Polyester
Resins Atti routed Resins
to MA ((t/kilogram)
15 0.7-4.0
0.3-1.8
15 0.8-4.6
0.4-2.1
% Increase
of Polyester
Resin Prices
1.2
0.5
1.4
0.7
New Wholesale
Price of
Resins
(it/kilogram)
56-334
55-332
56-335
55-332
   aPricc increments of polyester resins were calculated from the worse price increases associated with the
    "best-case" control options for MA.

   SOUP.CT:  Personal communication with representative of Tonneco's MA division.

-------
                   TABLE  5-21.  PRICE INCREASES OF FUMARIC ACID DUE TO INCREASED MA PRICES'
Ul
I
-J

% Control
of Benzene
Emissions
97

99.5

Production
Capacity of
MA Plant(%)
56
100
56
100
Present Whole-
sale Price of
Fumaric Acid
(^/kilogram)
94

94

% of Wholesale
Price of
Fumaric Acid
attributed to MA
73

73

Price Increase
of Fumaric Acid
(
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                 TABLE   5-22.   PRICE  INCREASES OF MALATHIOM DUE TO  INCREASED MA PRICES

- Control
of Benzene
Emissions
97

99.5
Ul
1
co
o
Production
Capacity of
MA PI ant (X)
56
100
56
100
Present Whole-
sale Price of
Malathion
(c/kilogram)
242

242

% of Wholesale Price Increase
Price of Malathion of Malathion
Attributed to MA (
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     Agricultural  chemicals,  such as  malathion,  are  the  second  largest
users of MA (10 percent of MA demand).   The current  wholesale price of
malathion is $2.42/kilogram and MA accounts for  11 percent  of this price.
Should HA prices go up, the price of malathion could rice  from  1.0 to 2.4
cents/kilogram.  Such an increment is relatively insignificant  compared
to the total cost  of the product, representing an increase  of only 0.4
to 1.0 percent over the present price of malathion.
     Another market for MA is fumaric acid (five percent of MA  demand),
which is primarily used as a  food acidulant.   MA accounts  for approximately
73 percent of the  total price of fumaric production.  This  large percent-
age is reflected in the maximum potential price  increase of fumaric
acid  (2.5 to 6.3 cents/kilogram).  This increase represents a 2.7 to  6.7
percent increase over the current sale price of  94 cents/kilogram.
5.3.4  Employment  and Balance of Trade
      Imposition of a benzene control  standard could  affect employment in
the MA industry and could alter the present balance  of trade.   The MA
industry presently employs approximately 330 individuals; under a 97  or
99.5  percent control standard, two manufacturers — Tenneco and  Denka--
have  indicated that capital expenditures for controls would prompt closure.
These companies represent 15 percent of the total domestic capacity.   If
they  close, approximately 50 workers could lose their jobs.
      Regarding balance of trade, foreign competition exacerbated by  benzene
control costs  for U.S. producers could result in the U.S. producers  losing
                                      5-81

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 up  to  15  percent  of  their market to imports.  This number is based on
 the present  import penetration of five percent in the total domestic
 market and the  potential  for U.S. briquette sales--10 percent of the
 total  domestic  market—to lose to foreign competition.  The assumption
 of  a 15 percent market  loss to imports is highly conservative; more
 likely, imports will  penetrate little or no more of the domestic market
 over the  next five years  (see section 5.3.2.5).
 5.3.5   Fifth Year Impacts
     This subsection  summarizes the following aggregate economic impacts
 occurring five  years  after the standards are proposed:
     (1) the total annualized costs,
     (2) the net  increase  in national  energy consumption; and
     (3) the inflationary  impact on the cost of MA.   At that time, it is
 assumed that the  plants will be running at full  capacity.
     At the 97  percent  standard, total annualized costs would be about $3.7
 million.  This  includes the annualized capital costs, and operation and
 maintenance costs of  the  control  equipment and monitoring equipment.
The additional  consumption of energy excluding benzene or heat  recovery
credits will  be approximately 220 trillion joules.   Furthermore,  the
price of MA would rise two percent over the current  list  price.*   This is
equivalent to about 1.6 cents per kilogram assuming  the  full  cost is  pass-
ed through to the consumer.
     At the 99.5  percent  standard, total  annualized costs would be about
*
 Derived by taking the increased total annualized cost (including monitoring
 costs) for the entire inductry and dividing by total inJur.try capacity (229 Gg),
This approach was taken since it is not clear at this tir.e uhich company will
emerge as the price leader.
                                    5-82

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$5.3 mill-ton.  The additional  energy consumption would be 650 trillion
joules.  MA prices would rise 2.3 cents per kilogram, or 2.8 percent
of the current list price.
                                     5-83

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                               References

 1.   See Section 5-2.
 2.   Personal communication with two representatives from Tenneco.
 3.   See Table 5-10.
 4.   Personal communication with a representative from Denka.
 5.   Ibid.
 6.   Chemical Profile. Maleic anhydride, February 13,  1978.
 7.   Personal communications with representatives from Ashland  and  U.S.  Steel
 8.   Ibid.
 9.   Personal communication with a representative from Amoco.
10.    Chemical Profile. Maleic anhydride, February 13,  1978
11.    Personal communication with Mr. Baker from Ashland's MA  division,
      April  18, 1978.
12.    Personal communication with Mr. Todd at Koppers.
13.    These figures were calculated from data obtained  from Mr.  Fred
      Magnusson, Department of Commerce.
14.    Ibid.
15.    Personal communication with two representatives from Denka.
16.    Ibid.
17.    Ibid.
                                   5-84

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             APPENDIX A
EVOLUTION OF THE PROPOSED STANDARD

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        DATE
COMPANY, CONSULTANT,
      OR AGENCY
         NATURE OF ACTION
  LOCATION
    June 8, 1977


July 28-29, 1977
Sept. 28-29, 1977


  October 20, 1977

  October 25, 1977
  November 17, 1977
  December 21, 1977

  January 24, 1978
  February 2, 1978

  March 13-17, 1978
  March 20-24, 1978
  May 24, 1978
  June 2, 1978
  June 28, 1978
       EPA
Publication in the Federal Register
of decision to list benzene as a
hazardous air pollutant under Section
112 of the Clean Air Act.
Reichhold Chemicals, Inc.  Plant visit.
Manufacturing Chemists
Association Air Quality
Committee
Monsanto Chemical
Intermediates Company
Koppers Company, Inc.
Denka Chemical Corp.
Monsanto Chemical
Intermediates Company
Amoco Chemicals Corp.
Monsanto Chemical
Intermediates Company
Reichhold Chemicals, Inc.
Denka Chemical Corp.
Reichhold Chemicals, Inc.
        EPA
        EPA
Meetina with engineers from EPA and
Hydroscience, Inc. to review progress
on the study of the maleic anhydride
industry and control technology.
Plant visit.
Section 114 request for information.
Plant visit.
Section 114 request for information.

Plant visit.
Test data supplied to EPA.

Carbon adsorption test by EPA.
Incinerator test by EPA.
Plant visit and pretest survey.
Draft SSEIS mailed to Working Group
Meeting with Working Group to review
comments on draft SSEIS.
Morris, Illinois
Washington, D. C.


St. Louis, Mo.

Pittsburgh, Pa.
Houston, Texas
St. Louis, Mo.

Chicago, Illinois
St. Louis, Mo.

Morris, Illinois
Houston, Texas
Elizabeth, New Jersey
Durham, N. C.
Durham, N. C.

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           APPENDIX B
MATRIX OF ENVIRONMENTAL IMPACTS



              OF



 ALTERNATIVE CONTROL SYSTEMS

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                                    MATRIX OF ENVIRONMENTAL IMPACTS OF ALTERNATIVE CONTROL SYSTEMS
Alternative
Existing Plants
A. 99.5% control
B. 97% control
New Plants
A. Substitution
of feedstock
(n-butane)
Delayed Standard
No Standard
impact on
Benzene
+4
+3
+4
-2
0
impact
on HC
+4
+3
-2
-2
0
Other Air
Impacts
-2
-1
0


Water
Impact
-1
-1
0


Solid Waste
Impact
-1
-1
0


Energy
Impact
-4
-3
0


Air Quality
Impact
+2
+2
-1


Space
Impact
-1
-1
0


Noise
Impact
-1
-1
0


CD
I
   Key   + Beneficial impact

         - Adverse impact
0  No impact
1  Negligible impact
2  Small impact
3  Moderate impact
4  Large impact

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                             APPENDIX D
D.I   Emission Measurement Methods
    D.1.1   General  Background
    For stack sampling purposes, benzene will,  except in the
case of systems handling pure benzene, exist in the presence
of other organics.   Accordingly, methods for benzene analysis
consist of first separating the benzene from other organics,
followed by measuring the quantity of benzene with a flame
ionization detector.  However, among various stack testing groups
concerned with measuring benzene, non-uniformity in procedures
could exist in the following areas:  (1) sample collection,
(2) introduction of sample to gas chromatograph, (3) chromato-
graphic column and associated operating parameters, and (4) chro-
matograph calibration.
     Two of the possible approaches for benzene sample collec-
tion are grab samples and integrated samples.  Since emission con-
tration may vary considerably during a relatively short period of
time, the integrated sample approach offers a greater advantage
over the grab sample approach because emission fluctuations due to
process variations are automatically averaged.  In addition, the
integrated approach minimizes the number of samples that need to be
analyzed.  For integrated samples, both tubes containing
activated charcoal and Tedlar bags have been used.  However,
charcoal sampling tubes were basically designed for sampling ambient
concentration levels of organics.  Since source effluent concen-
trations are expected to be higher (particularly since organics other
than benzene could be present) there would be uncertainty

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                               2
involved with predicting sample breakthrough, or when sampling
should be terminated. Bag samples would also offer the potential
for the best precision, since no intermediate sample recovery
step would be involved.
     Based on the above considerations, collection of an integrated
sample in Tedlar bags appears to be the best alternative.  This
conclusion is in agreement with an EPA funded report whose purpose
was to propose a general measurement technique for gaseous organic
emissions.   Another study of benzene stability, or deterioration
in Tedlar bags was undertaken to confirm the soundness of this
        2
approach .  This study showed no significant deterioration of benzene
over a period of 4 days.  Consequently the integrated bag technique
was deemed suitable; however, anyone preferring to use activated
charcoal tubes has this option, provided that efficiency at least
equal to the bag technique can be demonstrated, and procedures to
protect the integrity of the sampling technique are followed.
     A collected gas sample can be introduced to a gas chromato-
graph either through use of a gas-tight syringe or an automated
sample loop.  The latter approach was selected for the reference
method since it has a lower potential for leakage and provides a
more reproducible sample volume.
     Several columns are mentioned in the literature which can
be suitable for the separation of benzene from other gases; '
most notable among them have been 1,  2, 3 - tris (2-cyanoethoxy)
propane for the separation of aromatics from aliphatics;  and
Bentone 34 for separation of aromatics.  A program was undertaken

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                                3
to establish whether various organlcs that were known to be
associated with benzene In stack emissions interfered with the
benzene peaks from the two columns.  The study revealed the
former column to be suitable for analysis of benzene In gasoline
vapors, and the latter column to be suitable for analysis of
benzene emissions from maleic anhydride plants.     It should
be noted that selection of these two columns for inclusion in
Method 111 does not mean that some other column(s) may not work
equally well.  In fact, the method has a conditional provision
for use of other columns.
     Calibration has been accomplished by two techniques, the
most common being the use of cylinder standards.  The second
technique involves injecting known quantities of 99 Mol percent
pure benzene into Tedlar bags as they are being filled with known
volumes of nitrogen.  The second technique has been found to
produce equally acceptable results; both are included in Method 111.
     0.1.2  Field Testing Experience
     Based on the study of benzene stability in Tedlar bags,
possible interferences by various process associated gases, and
calibration methods, and as a result of a field study and tests
conducted at sources of benzene emissions, a new draft of Method 111
was prepared for determining compliance with benzene standards or
NESHAPS.   This method is the same as the originally investigated
method, except that the audit procedure has been refined,  and an
appendix has been added to aid in the verification of benzene peak
resolution.

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                               4
     Two maleic anhydride manufacturing plants were tested during
the development test program.  One of these plants employed a
carbon adsorption system and the other employed a thermal oxidizer
(incinerator) to control organic emissions. Method 111  was used
to collect and analyze for benzene emissions.  The SP 1200/Bentone 34
gas chromatographic column described in the method was used to
resolve the benzene.  No major deviations from Method 111 were required.
At the plant employing the carbon adsorption system, a liquid drop-
out was required to prevent intermittent entrained liquid from being
introduced into the integrated bag sample.  This liquid entrapment
was caused when an undried steam-desorbed carbon bed was reiintroduced
into the control system and the liquid entrainment occurred during
five percent of the sampling time.  A rotameter was also installed
at the inlet to the integrated bag sample at this plant because
the rigid container housing the bag sample could not be adequately
sealed.  Neither of these two deviations are considered to have
effected data validity.
     In all  testing, the sampling lines and integrated bags were
maintained at or slightly above the source temperature during col-
lection and analysis to prevent condensation of any organics
present that would normally be a vapor at the source temperature.
A third plant employing carbon adsorption is scheduled for testing.
A discussion of this test will  be included at a later time.   How-
ever, it is anticipated that Method 111  can be employed.
     Organic acid and aldehyde emission data were also collected

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                                5
during the test program.   Data were collected to adequately determine
emissions in terms of concentration, mass rate, and control system
mass removal efficiency.   The results of these studies will be in-
cluded at a later time.
D.2  Performance Test Methods
     The recommended performance test method for determining benzene
emission concentrations at maleic anhydride plants is Method 111.
The method uses the Method 106 train for sampling, and a gas chroma-
tograph/flame ionization detector equipped with a column selected
for separation of benzene from the other organics present, for analysis.
     If dilution air is present, Method 3 must also be used.
     Subpart A of 40 CFR 61 requires that facilities subject to Stan-
dards of Performance for New Stationary Sources be constructed so as
to provide sampling ports adequate for the applicable test methods, and
platforms, access, and utilities necessary to perform testing at those
ports.
     Assuming that the test location is near the analytical labora-
tory, and that sample collection and analytical equipment  is on
hand, the cost of field collection, laboratory analysis, and
reporting of benzene emissions from a single stack is estimated
to be $2500 to $3500 for a compliance test effort.  This figure
assumes a cost of $25/man-hour.  While this amount would be
reduced approximately 50 percent per stack if several stacks are

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                               6
tested, it does presume that all benzene samples  would  be  col-
lected and analyzed in triplicate.
     If the plant has established in-hour sampling capabilities
and were to conduct their own tests and/or do their own analyses,
the cost per man-hour could be less.
D.3  Continuous Monitoring
     No emission monitoring instrumentation,  data acquisition,
and data processing equipment for measuring benzene from maleic
anhydride plant stack gases that are readily available  (on an
"as complete systems" basis) have been determined to date.
However, EPA has only recently begun to explore the development
of specifications for benzene monitoring, and it  is felt that
such specifications, which would employ a package of individually
commercially available items, are feasible.
     For a chromatographic system that reports benzene  concentra-
tion, the installed cost of the chromatograph and its auxiliaries
is $30,000.  This figure would increase by approximately $10,000
for the additional hardware necessary to report a benzene  mass
emissions rate in terms of benzene feedstock.   Depending on the
operating factor, the direct operating cost varies from about
$1,200 to $l,400/year.
  Includes:  gas chromatograph with dual  flame  detector,  automatic
  gas sampling valve,  air sampler,  post run  calculator, and  gas
  regulators.

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References
     1.  Feairheller, W. R.; Keiraner, A. M.; Warner, B. J.; and
Douglas, 0. Q. "Measurement of Gaseous Organic Compound Emis-
sions by Gas Chromatography," EPA Contract No. 68-02-1404,
Task 33 and 68-02-2818, Work Assignment 3.  Jan., 1978.
     2.  Knoll, Joseph E.; Penny, Wade H.; Midgett, Rodney M.;
Environmental Monitoring Series Publication in preparation.
Stability of Benzene Containing Gases in Tedlar Bags.  QAB/EMSL
U. S. Environmental Protection Agency.
     3.  Bulletins 743A, 740C, and D.  "Separation of Hydro--
carbons" 1974.  Supelco, Inc.  Bellefonte, Pennsylvania 16823.
     4.  Volume 10, No. 1 "Current Peaks," 1977.  Carle Instru-
ments, Inc. Fullerton, California 92631.
     5.  Communication from Joseph E. Knoll.  Chromatographic
Columns for Benzene Analysis.  October 18, 1977.
     6.  Communication from Joseph E. Knoll.  Gas Chromatographic
Columns for Separating Benzene from Other Organics in Cumene and
Maleic Anhydride Process Effluents.  November 10, 1977.

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