characterization data and strong evidence to the contrary, synfuel products
by their very nature (new chemicals from a more “exotic" source) should be
considered more hazardous. Under this scenario nearly all synfuel products
would be given a positive ranking, thereby reducing a ranking system's
usefulness as a guide in prioritizing regulatory and R&D activities.
Acquiring detailed characterization data and not necessarily concentrating
on products that are known to present greater environmental concern would
be emphasized under the second scenario.

ATTRIBUTE RATING PROCEDURE

Table 10 presents the assessment of the environmental concerns for
various synfuel products relative to their petroleum analogs on a “barrel-
per-barrel" basis. As indicated by the headings in the table, the relative
ranking considers potential for exposure, emission, toxic hazard, cost of
control, and adequacy of existing regulations. A (+) ranking 1s assigned
to a product for an environmental attribute 1f the product 1s judged to
present greater environmental concern than the petroleum analog; a ranking
of (0) indicates that the environmental concern would be similar
to or less than that of the petroleum product. Factors considered
in assigning ratings to each product for each environmental attribute
along with some examples of product ratings are presented in Table 11.

PRODUCTS RANKING

Table 12 presents the results of synfuel products ranking. The
products are ranked tnto three groups: those eliciting the most concern,
ranked as “1"; those indicating “modest" concern, ranked as "2"; and those
generating a “low” level of concern at the present time, ranked as "3", As
noted in the table, in the near term (1980-1987 period), synfuel products
of concern are primarily the shale oil products and medium-Btu gas and SNG
from coal gasification. Shale oil refinery feed elicits the most
regulatory attention; other shale oil products and medium-Btu gas elicit
modest concern, and SNG requires a low level of attention.

For the 1988-1992 period, when products from SRC II and the F-T
processes will also be marketed, the products eliciting the most concern
would be shale oil refinery feed, fuel methanol, SRC II fuel o11, and
gasifier tars and oils. F-T products and LPG from SRC II are ranked as
low priority products during 1988-1992. During the 1993-2000 time frame,
shale o1l refinery feed, medium-Btu gas, gasifier tars and oil, and fuel
oils from the three liquefaction processes are given "1" rankings; F-T
products are assessed as "3", and all other products are given a "2"
ranking.

The rankings generally indicate the greatest level of environmental
concern and regulatory requirements for shale oil refinery feed and coa
liquids. These liquids have been demonstrated to be more hazardous than
petroleum crude and fuel oils (a major factor in assigning a “1" ranking).
This and the fact that shale o1] products will be the synfuels that are

-18-


Zt

TABLE 6. SUMMARY OF AVAILABLE DATA PERTAINING TO PHYSICAL AND CHEMICAL CHARACTERISTICS

OF DIRECT COAL LIQUEFACTION PRODUCTS

Syncrudes have lower viscosities and pour points than petroleum crudes, Kinematic viscosity at 100°F values
ot 22 and 1.1 to 1 6 cst for SRC II whole process 011 and H-Coal syncrude, respectively (vs. 6.14 and 18 9
cst for an Arabian light and an Arabian heavy crude, respectively). A pour point value of -80°F for SRC II
whole process 011 (vs -30°F for the two Arabian crudes) The lower viscosities and pour points for syncrudes
indicate better handling and transfer characteristics

Syncrudes have a high nitrogen content (0 17 wt % for H-Coal using low sulfur coal to 0 85 wt % for SRC II
whole process oi], vs. 0 1 wt % for crude 011). The nitrogen reduced to about 50 ppm by moderate hydrotreat-
ing and to less than 1 ppm by severe hydrotreating

The sulfur content of raw syncrudes (0 04 to 0.49 wt.%) would classify them as low sulfur feed The sulfur
content 1s reduced to about 20 ppm or less by hydrotreating

SRC II whole process 017 has an aromatic content of 55 volume % Included in that value 1s almost 9% phenols.
The aromatic content 1s reduced to 49% by "intermediate severity" hydrotreating and to 4% by “severity hydro-
treating"

Naphtha from SRC II, H-Coal and EOS contain 16 2, 18.2, 18 6 and 25.3 vol % aromatics and 3.2, 3.1 and 7 4
vol % phenols, respectively Hydrotreatment appears to increase aromatic content and eliminate phenols.
The hydrotreated naphtha from the three processes contain 19 to 2] vol % aromatics

Direct liquefaction naphthas have low octane numbers (40 to 70) and hence are not suitable for direct use as
gasoline Hydrotreating/platforming or hydrocracking/platforming produces gasoline stocks with octane
numbers ranging from 91.5 to 99 8

Gasoline or naphtha from direct liquefaction processes are less volatile than petroleum-derived leaded or
unteaded gasoline The distillation end point for petroleum-derived gasoline 1s 340-345°F vs. 382-411°F and
365-459°F for liquefaction naphtha and gasoline, respectively

Coat liquefaction naphtha can be processed to gasoline, having gross compositions (% aromatics, olefins,
saturates, etc ) similar to petroleum-derived gasoline.

The 011 distillates from EDS process are very low 1m nitrogen and sulfur (0 2-0.6 ppm and 2-139 ppm,
respectively) Except for a lower gravity (2 5-27 9 vs. 30°)and higher flash point (136 vs 100°F), the
distillates meet the specifications for No. 2 fuel 011].

SRC II fuel 011 (5 75 1 middle to heavy distillate ratio) 1s very similar to No. 6 fuel 01) 1n character-
istics, except for lower gravity (11° vs 25° API), heating value (17,081 vs 19,200 Btu/1b ), pour point
(-30°F vs. 95°F) and flash point (150 vs. 200°F)and higher nitrogen content (1.02 vs 0.23 wt %).

Jet and diesel fuels obtained from H-coal and SRC II syncrudes meet the specifications for these products.


expected to first enter the market on a large scale, are the major factors
that flag near-term environmental concerns for shale oi] products in
general and shale oil fuel and refinery feed in particular.

DATA LIMITATIONS AND RELATED PROGRAMS

As noted previously, there are a number of major gaps in the existing
data base that preclude accurate analysis of the environmental concerns
associated with a future large-scale utilization of synfuel products in the
U.S. These gaps relate to: (a) present uncertainties regarding the size
of the industry, specific synfuel technologies that will be used and
Product slates that will be produced, locations of production facilities
and product distribution systems, and the specific areas of synfuel use;
and (b) lack of adequate characterization data on synfuel products and on
the analogous petroleum products that they will partially or totally
replace. The first category of data limitations impacts the regional
environmental implications and synfuel production scenarios and market
analyses that were developed; whereas the second category of limitations
introduces uncertainties in the estimated characteristics of synfuel
products and the analysis of environmental concerns. Both types of data
limitations impact the regional environmental implications and the ranking
of the synfuel products.

At present, the first category of data gaps can only be partially
filled (for example, through an engineering analysis to determine optimum
product slates). Many of the gaps in the second category, however, can and
should be filled through testing and evaluation of synfuel products
obtained from existing U.S. pilot plants and commercial facilities abroad.

A number of chemical and biological/ecological testing programs are
currently under way that are expected to substantially improve the quality
of the existing data base on synfuel products. These programs are
conducted and sponsored largely by DOE and EPA. In addition, a number of
product performance testing efforts are under way or are planned that
provide excellent opportunities for cost-effective collection of end use
environmental data. These programs include testing shale-derived jet fuels
in commercial and military aircraft engines (U.S. Air Force, Wright-
Patterson AFB; U.S. Navy); standing diesel engine tests with SRC II and
shale oi] diesel fuels (DOE Bartlesville Energy Research Center); testing a
spectrum of synfuel gasoline and jet fuels in ground and air transportation
vehicles (U.S. Department of Transportation); and evaluation of the use of
synthetic fuels in utility boilers (Electric Power Research Institute).

EPA is currently exploring the possibility of joining these programs to
simultaneously acquire environmental end use data.

CONCLUSIONS

e In the next 20 years significant quantities of synfuel products
are expected to enter the marketplace and in certain regions a
very high percent of the currently used products will be replaced
by their synfuel-derived analogs.

-22-


TABLE 1.

CANDIDATE SYNFUEL TECHNOLOGIES AND THEIR STATUS OF DEVELOPMENT

Technology

DESCRIPTION

OEVELOPIENT STATUS

O11 Shale

Heating 011 shale to about 480°C to extract shale 011

Heating accomplished via surface retorting, in situ retorting
or modified in situ retortang

Crude shale 011 can be upgraded to produce syncrude for
use as refinery feedstocks or boiler fuel

Closest to commercialization of atl synfuel technologies
for production of large volumes of liquid fuels

Surface retorting more advanced than in-situ retorting
AV) technologies demonstrated at pilot scale or larger
Several production facilities planned for operation in 1980's

Direct Coal
Liquefaction

.

.

Coal, hydrogen and a coal-derived liquid mixed at high
temperature and pressure to produce additional coal-derived
011, which 1s separated and refined to liquid fuels

Three major processes under development SRC If, H-coal
and Exxon Donor Solvent (EDS} Processes differ in the way
hydrogen 1s made to react with coal

SRC II Pilot plant under operation, 6700-ton/day of coal
demonstration unit under design and scheduled for operation
an 1984-85

H-Coal 600-ton/day of coal pilot plant under construction,
testing to begin soon

EDS 250-ton/day of coal pilot unit under construction,
testing to begin soon

indirect Coal
Liquefaction

Coal reacted with oxygen and steam in a gasifier to produce
a synthesis gas, after removal of C02 and other impurities,
CO and Hz in the gas reacted catalytically to produce several
products ranging fron lightweight gases to heavy fuel o1!
{Fischer-Tropsch process) or to methanol which 1s then con-
verted to gasoline (tobiT-4 process}

Fischer-Tropsch 8000-ton‘day of coal plant (SASOL 1) produc-
ing over 10,000 bbl/day of Iyquids in commercial operation
since 1956 in South Africa, a 40,000-ton/day of coal unit
(SASOL-11} will begin operation soon

Mob11-M Commercial plant to produce 12,500 byl/day of gasoline
from reformed natural gas planned for New Zealand 1n 1984-35

Coal Gasification

Reacting coal, Steam and air/oxygen to produce low-Btu (80-150
Btu/scf} or medium-Btu( 300-500 Btu/scf} gas, medium-Btu gas
purtfied and upgraded to SNG (+1000 Btu/scf)

Gasifiers differ 1n design and operation, depending on type
of coal used and products desired

°

Low-Btu gas Extensive commercial experience 1n US with
gasifiers operating near atmospheric pressure, applications are
smal}-scale operations producing gas for captive use in
industrial and process heating

Nedium-Btu gas extensive commercial experience exists for
Lurgi fixed-bed process, several projects using the Texaco
process for captive applications (chemical feedstocks and
on-site power generation) 1n planning and design stages

High-Btu gas plans for SNG production using Lurg technology
announced by pipeline and gas utility companies



-6L-

TABLE 10.

RELATIVE ASSESSMENT OF THE ENVIRONMENTAL HAZARDS ASSOCIATED
WITH SYNFUELS PRODUCTS AND PETROLEUM ANALOGS

PRONUCT

EXPOSURE

EMISSION
FACTOR

TOXIC
HAZARD

Cost of

ADEQUACY OF
EXISTING REGULATIONS

Transport
&

Storage | End Use

Transport|
&

Storage | End Use

Transport
&

Storage

End Use

Control

g

CWA

H i
RCRA_!

TSCA_

Crude shale 011 (fuel)

nale Oi! refinery feed

Shale jet fuel

Shale diesel fuel

~_SnaTe_residuats

+l etelel ele

“shale gasoline

Low-/Medium-Btu_gas (coal)

~SNG (coal)

Gasifier tars and oils

— Gasifier phenol

~F-T CPG

—F-T mediuin Btu gas

F-T_SNG

TFT heavy fue orl

gasoline

_Wegasoline

F-1 diesel fuel

errr are O+folo}+t+

la}alolajolojalolajcjo |ololalo|clo

“Fuel methanol

SRC_II fuel 011

—3RCTT naphtha

SRC_TT LPG

EDS fuel o1t

EDS naphtha

[THs TPG

Pl2|+ Je/2}+ jele|+ |+leje}ejcjojc|elojojole jojojolo)+)+

lojolo Jolole jololo jojalojojalajajolojolalo jolajojolo|o

la!Q}O Jololo Jojojo Jojololojolalajolojolalo jojojololo|o

O}O} + lola} + Jolol+ |+olojolofojojo}+|+/o]+ +/+] +]+jol+

lo}+}+ loj+l+ fol+]+ Jololololololojo}+|+lal+ joj +lolo}+}+

lol +)+ Jof+l+ fol+|+ lololofojolojolol+|+lof+ +/+] +/+)+[+

JOJO} + Jolo}+ Jolal+ Jolololo) +ojajolo}+jo} + |+/+/+/+lo}+

Jo} + lofol+ fola}+ |+lojololajalolajo|+lol+ |+]+!+/+lo}+

lof+|+ lof+]+ lol+}+ fo

lo}+]+ jof+]+ Jol+l+ [++] +/+] +lojcfojol+jol+

lajolo ree lololo F|



-l2-

TABLE 12. PRIORITY RANKING OF SYNFUEL PRODUCTS FROM THE STANDPOINT OF ENVIRONMENTAL CONCERNS*

Product 1980-1987 1988-1992 1993-2000

Crude shale oil (fuel)
Shale oil refinery feed
Shale jet fuel

Shale diesel fuel
Shale residuals

Shale gasoline

Medium Btu gas (coal)
SNG (coal)

Gasifier tars & oils
Gasifier phenol

F-T LPG

F-T medium-Btu gas
F-T SNG

F-T heavy fuel oi1

F-T gasoline |
Mobil-M gasoline
F-T diesel fuel

Fuel methanol -

SRC II fuel o71 -
SRC II naphtha -
SRC II LPG -

EDS fuel oi] -
EDS naphtha -
EDS LPG -

H-coal fuel oi] - -
H-coal naphtha - -
H-coal LPG - -

Prrr tee nryt wn wnnwn—nw

WN = WWWWWWWNHHWNH YONYNNY—!

WN WHA YOY — WWWWHWWWKHHWH] MNYNYNM—!I

*Degree of concern: most=1, modest=2, and low=3; - indicates product not
produced or not used as indicated


content of the synfuels (and the high arsenic content of the crude shale
011) can also be lowered to meet appropriate fuel specifications by the use
of certain refining processes (for example, hydrotreating to reduce FBN)
Another example of controlling undesirable product characteristics through
process control (or in-plant treatment) is the elimination of traces of
carbon monoxide and nickel carbonyl in SNG by proper operation of the
methanator.

The data in Table 9 identify two products as highly hazardous because
of mutagenic, tumorigenic, and cytotoxic properties. These are crude shale
011 and fuel oils from coal liquefaction processes. These hazardous
properties, which are characteristic of high boiling and tarry coal and
petroleum materials, are caused by the presence of substances or classes of
substances such as polycyclic aromatic hydrocarbons, hetero- and
carbonyl-polycyclic compounds, aromatic amines and certain inorganics (for
example, arsenic in crude shale oil).

In general, synfuel product characteristics that cause environmental
concern in any wide-scale utilization scenario relate to the known or
potential presence of toxic substances (including carcinogenic compounds
associated with crude shale oi] and heavy distillates from coal
liquefaction and hazardous aromatics), fuel-bound nitrogen, volatile
components, and minor and trace elements. Potential environmental concerns
relating to anticipated product uses generally fall into three categories:
Occupational exposure, public exposure, and general environmental
pollution. The occupational hazards affect workers manufacturing and using
the products and personnel involved in facility maintenance and product
distribution services. Public exposure primarily relates to air pollution
resulting from product uses such as the use of gasoline in automobiles
(affecting motorists at service stations), and hazardous fugitive emissions
from storage tanks, product transfer points, leaks/spills, and product uses
(for example, products produced from petrochemicals). In the genera
category of environmental pollution, major contributors would include
accidental spills, sludges from product storage tanks and sp111 cleanups,
and solid, liquid, and gaseous wastes associated with combustion and
combustion-related air pollution control.

BASIS FOR PRIORITY RANKING OF SYNFUEL PRODUCTS

As noted previously, the objective of the study is to provide input to
the EPA effort for: (1) assessing the environmental implications of a
mature synfuel industry and of large-scale utilization of synfuel products;
and (2) planning and prioritizing regulatory and research and development
programs. Accordingly, a system was developed and used to rank the synfuel
products from the standpoint of environmental concerns and to identify
those products and areas of concern that should receive more immediate and
greater regulatory and R&D attention. The ranking is based on the data
presented previously and 1s subject to the limitations of the existing
product characterization data and the assumptions used in developing the
productions and use scenarios; the product rankings will most likely change
as more data become available, especially for those products for which

-16-


TABLE 3. ESTIMATED QUANTITY OF SYNFUEL PRODUCTS USED IN THE U.S. UNDER SCENARIO II

-3-

1980-1987 1988-1992 1993-2000
Product Amount % of total Amount % of total | Amount % of total
{MMBPD) in U.S. (MMBPD) in U.S. (MMBPD} = in U.S.

Crude shale 011 (fuel) 0.0008 0.05 0 0 0 0
Shale oi] refinery feed 0.07 0.45 0.41 0.24 0.43 2.4
Shale jet fuel 0.015 1.2 0.09 6.5 0.09 6.8
Shale diesel fuel 0.042 1.2 0.23 6.5 0.23 6.8
Shale residuals 0.007 0.2 0.04 1.3 0.04 1.3
Shale gasoline 0.13 0.2 0.07 0.9 0 it)
Medium-Btu gas (coal) 0.09 0.9 0.27 2.8 0.45 4.7
SNG (coal) 0.042 0.4 0.17 1.8 0.25 2.6
Gasifier tars, oils 0.004 0.04 0.01 0.1 0.01 0.1
Gasifier phenol 0.004 0.04 0.01 0.1 0.02 0.2
F-T LPG 0 0 0 0 0 0
F-T medium Btu gas 0 0 0.01 0.06 0.01 0.1
F-T SNG 0 0 0.03 0.33 0.07 0.7
F-T heavy fuel of] 9 0 0.001 0.02 0.001 0.03
F-T gasoline 0 6 0.02 0.2 0.03 0.4
Hob11-gasol ine it) 0 0.05 0.66 Q.1 1.3
F-T diesel fue} 0 ie) 0.002 0.04 0.01 0.1
Fuel methanol 0 0 0.14 1.8 0.23 3.0
SRCII fuel of] 0 0 0.03 0.3 0.09 1.3
SRC II naphtha ie) 0 0.02 0.2 0.05 0.8
SRC II LPG 0) 0 0.006 0.4 0.02 1.6
EDS fuel oi1 0 0 0 0 0.06 1.0
EDS naphtha 0 tt) 0 0 0.03 0.6
EDS LPG i) 0 tt) 0 0.01 0.9
H-coal fuel 011 ie) 0 0 0 0.06 0.4
H-coal naphtha 0 0 0 0 0.03 0.2
H-coal LPG : 0 0 0 0 0.01 0.1



Table 2. MAJOR END USE APPLICATIONS OF SYNFUEL PRODUCTS

Likely Major
Major Synfuel Products End Use Applications

High- and medium-Btu gas Food, textile, pulp and paper,
chemicals, iron and steel industries;
residential/commercial heating

Low-Btu gas Small boilers, kilns, pelletizing

LPG glass, electronics, chemical industries;
domestic cooking and heating; automotive

Gasoline Transportation

Naphtha Petrochemical industry; solvents;
varnish; turpentines

Middle distillates Transportation, gas turbines,

(kerosene, diesel, residential and commercial heating

light fuel o11)

Residues Industrial, utility and marine fuel;
metallurgical oils; roof coatings; wood
preservatives, lubricants

Based on different assumed levels of impacts exerted by these factors,

three scenarios or forecasts for synfuel industry buildup to the year 2000
were developed. These scenarios are:

e National goal scenario driven by federal incentives (Scenario I;
medium buildup rate)

e Nominal production scenario (Scenario II; low buildup rate)

e Accelerated production scenario representing an upper bound for
industry buildup (Scenario III; high buildup rate).

The scenarios, shown in Figure 2, project the total quantities of
shale oi], low-/medium-Btu gas, high-Btu gas and liquids from coal that
would be expected to enter the market under the assumed sets of conditions.
Based on discussions with major synfuel suppliers and users and industry
and government planners, Scenario II was selected as the more realistic of
the three scenarios and was used for analysis of regional impacts and
environmental issues. This scenario is consistent with the general
consensus among technical experts and potential major suppliers that shale
oil is more nearly cost competitive and closer to conmerctalization than

“5.


->-

Ol
SHALE

GASIFICATIONS

MAJOR SYNFUEL PRODUCTS/

BY-PRODUCTS
Indirect. Coal Direct Coal

901 Shate Goal Gasification Liquefaction

oducts Products Products

THE
ad

feo ae

ue {eg . Marine

Dtesel, Fuels. Lupercants)

Kerosene Napntiha

Ligne Feet 011) it
Residuals arcais

(eg. marine Patrocnenrcal

A

‘Lupricants)

\d Commercial

mnetration of Shale O11 into the Utilities an

NOTE Per hesidential sector 1 expected to be mnimal and
therefore not highlighted

PE

TRANSPORTATION ,
SECTOR

f
lll

INDUSTRIAL

eee TTT

@ RESIDENTIAL
SECTOR

FIGURE 1.

SYNFUEL UTILIZATION DURING 1985-2000



little or no data are currently available. It should also be noted that
the specific approach used represents only one of many approaches that

could be used to rank synfuel products from the standpoint of environmental
concerns.

The product ranking system 1s based on:

e Reported or estimated environmentally significant characteristics
of synfuel products relative to those of their petroleum analogs,
based on considerations of exposure potential, combustive and
evaporative emissions, toxic hazards, cost of control, and the
extent of regulatory protections under key existing environmental
legislations. Products for which the environmental risks and
control needs are greater and for which less protections can be

anticipated under existing regulations have been given a higher
ranking.

° The estimated quantity of products used, both in absolute terms
and as percentages of the total (synfuel and petroleum) used
nationwide (Table 3)and regionally. The greater the amount of
the product used and the percentage of usage, the greater the
potential for presenting environmental hazards, and hence a
higher positive ranking.

e Considerable scientific and engineering judgement. Because of
the lack of a solid data base, heavy reliance had to be placed on
the professional judgement of experts most familiar with the
domestic energy supply and demand picture, synfuel production/
refining technologies, expected environmental characteristics of
synfuel products, applicable controls, and regulatory needs.

Two approaches were examined for ranking the synfuel products, based
on: (1) the limited product characterization data currently available
(Table 9) supplemented by engineering judgement where appropriate; and (2)
the premise that in the absence of detailed characterization data, and
unless the available data indicate otherwise, 1t would be reasonable to
assume that a synfuel product would be more hazardous than its petroleum
analog. The first approach was selected and used to develop product
rankings.

Under the first approach, a synfuel product would not necessarily be
considered more hazardous because of the mere lack of detailed
characterization data. Instead, assignment of a more positive ranking to a
product is supported by actual data or 1s based on strong indications of
greater potential hazards. Under the first scenario, prioritization of
regulatory and R&D activities does not have to await collection of
additional data, which should proceed concurrently as a separate effort.

The second approach operates on the premise that 1f there is any room
for error in ranking synfuel products, it would be more advisable to err on
the safe side. This scenario asserts that, in the absence of detailed

-17-


high-Btu gasification or coal liquefaction, and that commercial coa
liquefaction facilities will not probably come on-line before the early
1990's. Synfuel industry buildup and product utilization patterns are
analyzed for three time frames: 1980-1987, 1988-1992, and 1993-2000. Table
3 presents the product-by-product estimates of synfuel utilization in the
U.S. For comparison, the estimated quantities are also expressed as
percentages of the total amount of products (synfuel and non-synfuel) used.

It should be noted that, even though on a national scale, the
projected synfuel utilization would account for small fractions of the
total product usage, in some regions a very high fraction of the currently
used products are expected to be replaced by synfuel products. As noted in
Table 4, by the year 2000 it is expected that 36 percent of all refinery
feed and 48 percent of all middle distillate used in EPA Region VIII would
originate from shale oil.

TABLE 4. PROJECTED UTILIZATION OF SHALE OIL PRODUCTS IN EPA
REGION VIII (REGION OF MAXIMUM PRODUCT USE) AS
PERCENTAGES OF TOTAL PRODUCT QUANTITIES USED

1988-1992
&

PRODUCT 1980-1987 1993-2000

Crude (fuel) 1.3 -

Refinery Feed 13.3 35.6
Middle Distillate 37.6 48.3
Gasoline 4.8 2.3
Residuals 15.6 6.6

SYNFUEL PRODUCT UTILIZATION AND EPA REGIONS OF MAXIMUM IMPACT

EPA regions where synfuel products would most likely be utilized are
identified in Figure 3. Table 5 summarizes the projections of synfuel
product utilization patterns in the EPA regions impacted. As noted in the
table, except for oi] shale in the 1988-1992 and 1993-2000 time frames and
for direct coal liquefaction in the 1993-2000 time period, the
transportation, distribution, and use of products are expected to be
confined to the regions where each synfuel is produced. Consequently,
environmental impacts associated with product utilization are expected to
be confined primarily to the production regions, except for impacts
associated with the natural transporation of pollutants across regional
boundaries (for example, transportation of air pollutants emitted from
combustion sources). The projections indicate that up to the year 2000

-7-


Based on gross characteristics, synfuel products appear to be
similar to petroleum products, but detailed characterization data
are not available for many of the synfuel and petroleum products
with which to assess and compare their safety.

Large-scale transportation, distribution, and end use of certain
synfuel products (for example, heavy distillates derived from
coal liquids and shale oil) can present significant threats to
the environment and the public health.

Essentially all synfuel-related environmental projects that are
planned or currently under way relate to the design and operation
of synfuel plants and not to the subsequent distribution and
utilization of products. The present study constitutes the first
attempt to focus attention on the potentially broad and
far-reaching environmental implications of large-scale marketing
and utilization of synfuel products.

A number of major test and evaluation programs are planned or
currently under way to assess the combustion characteristics and
general performance of synfuels relative to those of petroleum
products. These programs provide excellent opportunities for
collecting the environmental data needed for assessing the
relative safety of synfuel products, determining the adequacy of
the existing control technologies, and identifying regulatory
needs.

RECOMMENDATIONS

Based on the results and conclusions of the study, the following
recommendations are offered:

More systematic approach to product characterization and testing.

Much of the currently available synfuel product characterization
and testing data are fragmentary and cannot be correlated. The
results generally do not cover all parameters of environmental
interest and have been obtained in “1solated" studies using
samples from different batches of products. Better coordination
among various on-going and planned studies (perhaps through
establishing a "test tracking" system that would promote
exchanges of information among various studies) 1s recommended to
avoid duplication of effort and to ensure generation of
appropriate environmental data in a most cost-effective manner.

Collection of environmental data in conjunction with planned

performance testing programs. Several synfuel product

performance testing efforts are being planned by various
governmental agencies; 1t is most appropriate and timely to
review these programs and take full advantage of opportunities
for simultaneous collection of environmental data. Collection of
environmental data, which can be correlated with product

-23-


PROJECT SUMMARY:

ENVIRONMENTAL ASPECTS
OF SYNFUEL UTILIZATION

December 1980

by

M. Ghassemi and R. lyer

TRW
ENVIRONMENTAL ENGINEERING DIVISION
Redondo Beach, CA 90278

EPA Contract No. 68-02-3174
Work Assignment No, 018

EPA Program Element No, CCZN1A

Project Officer: J. McSorley

Industrial Environmental Research Laboratory
Office of Environmental Engineering and Technology
Research Triangle Park, N.C, 27711

Prepared for:

U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Research and Development
Washington, D.C. 20460


oL

FABLE 5

ESTIMATED UTILIZATION PATTERNS FOR SYNFUEL
PRODUCTS IN EPA REGIONS IMPACTED*

Synfuel Time Frame Production Refining Uti lization/Products
Shale 011 1980-1987 vinst VII VIII md distillate (57), gasoline (13), residuals (7}
1988-1992/ VI1I(410) VEIt (210) VEIL amid distillate (155), gasoline (36), residuals (19)
1993-2000 v= (200) v residuals (18)
{ vy & VIE.md distillate (148), gasoline (34)
Low-/med1 um- 1980-1987 1v(30) - Lv. gas (30)*
Btu Coal gas V1(30) - VI gas (30), tars/oils (0 98-1 9}, phenols (0 15-0.30),
naphtha (0.25-0 72
VIII(30) - VIII gas (30), tars/o1ls (0.98-1 9), phenols (0.15-0 30),
naphtha (0.25-0.72)
Indirect Coal 1988-1993 VIII(100) VIII(100) VIIL gasoline (64 5), mid distsllates (2.5), residuals (0 7),
Liquefaction SNG (32 6), LPG (0.1), tars/o1ls and phenols
Products 1993-2000 v1I1(200) VIII (200) VET. gasoline (129), SNG (65. 3) diesel fuel (5 0),
residuals (1.4), LPG (0.2
1v(150) 1v(150) Vv gasoline (150)
111(300) 111 (300) HII. gasoline (300)
Direct Coal 1988-1992 ¥(50) ¥(50) v naphtha (15.4), mid distillate (18.7), residuals (10),
Liquefaction LPG (5.9)
Products 1993-2000 111(50) 111(50) HIT naphtha (15 4), md distitiate (18.7), resrduals ao),
LPG (4 5
Tv (100) Iv (100) VI LPG (10.6)
¥ (200) Vv (200) Iv mid distillate (37 4), naphtha (30.8), residuals (20.0),
LPG (9.0)
v naphtha (61 6), md distillate (74.8), residuals (40.0),

LPG (20 2)

* cumbers shown im paranthesis are product quantities in 103 BPC 011 equivalents

* See Figure 3 for states covered by each EPA region

Production and utilization patterns for 1988-1992 and 1993-2000 are the same as shown
§ Use of Texaco process, which does not generate tars, 011s and phenols, 1s anticipated


SHALE OIL
LOW /MEDIUM-Btu GAS.

INDIRECT COAL LIQUEFACTION SHALE OIL

INDIRECT COAL LIQUEFACTION
DIRECT COAL LIQUEFACTION REGION!

wo

REGION Vit

jeoto

INDIRECT COAL LIQUEFACTION
DIRECT COAL, LIQUEFACTION

REGION IT

PUERTO RICO

eDP3

iv
VIRGIN ISLANDS

LOW-/MEDIUM Btu GAS
DIRECT COAL LIQUEFACTION

LOW-/MEDIUM-Btu GAS
DIRECT COAL LIQUEFACTION

o* Coy
. INDIRECT COAL LIQUEFACTION

saw

Figure 3. EPA Regions of Synfuel Products Utilization (1990's)


MILLIONS OF BARRELS OF OIL/DAY

MILLIONS OF BARRELS OF OIL/DAY

MILLIONS OF BARRELS OF OILIDAY

3.0

20

10

)

SHALE OIL PLANTS

LOW/MEDIUM BTU GAS PLANTS

1 1

COAL LIQUIDS PLANTS

L 1 i
1986 1988 1980 1992 1994

1 it
1996 1998 2000

YEAR 1984
SCENARIO} NATIONAL GOAL
30
20
10F
OVeAR 1984 1986 1988 1990 1992 1994 1996 1998 2000
SCENARIO I] NOMINAL PRODUCTION

60
sob
sop
30b
2oh
sob

0 mers 1 L

YEAR 1984 1986 1988 1990. +1962 19941996 1998 2000

FIGURE 2.

SCENARIO Ill ACCELERATED PRODUCTION

FORECASTS FOR SYNFUEL INDUSTRY BUIL

~6-

D-UP


-02-

TABLE 11.

RELATIVE TO PETROLEUM/NATURAL GAS ANALOGS)

FACTORS CONSIDERED IN ENVIRONMENTAL ATTRIBUTE RANKING (SYNFUEL PRODUCTS

Attribute

Factors Considered

Example

Exposure/Transport and Storage

Exposure/End Use

£mission Factor/Transport
and Storage

Emission Factor/End Use
Toxic Hazard/Transport and

Storage
Toxic hazard/End Use

Cost of Control
Adequacy of Existing Regulations
Clean Air Act (CAA)

Clean Water Act (CWA)

Resource Conversation and
Recovery Act (RCRA)

Toxic Substances Control
Act (TSCA)
'

Potential for environmental contamination and public exposure
from releases due to accidents, spills and fugitive emissions

Potential for exposure due to end uses (e g , occupational
exposure or exposure to combustion products)

Amount of material released as a result of transport and
storage activities (without regard to pollutant mobility and
number of people potentially exposed)

Amount of pollutants released as combustive and evaporative
emissions

Potential for human and ecological toxicity 1m connection
with transport/storage activities

Toxicity of combustive and evaporative emissions

Added control costs for regulated pollutants (especially
NOx)

Potential emissions of hazardous substances other than
pollutants covered by existing standards

Estimated adequacy of available contro! technologies for
wastewaters containing synfuel products

Estimated hazards posed by synfuel wastes

Mandate of the act to regulate new products, new uses,
or products produced using different processes presenting
unreasonable risks

(+) ranking for crude shale 011 and direct liquefaction
fuel 011s because of higher content of water soluble
compounds

(0) ranking for all products, products will be used

1n the same manner as petroleum products

(0) ranking for all products, no higher volatility or
greater potential for accidental spills indicated

(+) ranking for low-/medium-Btu gas due to higher emis-
sions of trace elements and heterocyclics

(+) ranking for crude shale 011 because of greater
mutagenicity

(+) ranking for crude shale 011 due to greater amounts
of carcinogenic substances and higher emissions of

NO, when used as fuel

(+) ranking for shale 011 gasoline due to possibly
more rapid deactivation of catalytic converter

(eg , by arsenic and PNA‘s)

(+) ranking for fuel methanol due to emssion of
aldehydes

(+) ranking for direct liquefaction fuel ols due

to estimated Tower biodegradability

(+) ranking for low-/medium-Btu gas due to estimatec
more hazardous nature of sludges produced from atr
pollution control (when used as fuel)

(G) ranking for all products, assuming adherence to
the mandate of the Act



with the projected widespread utilization of synfuel products. A related
EPA program, currently under way, extends the effort to an analysis of the

trade-offs of various product slates for minimizing end use environmental
impacts.

The present study consists of: (1) a projection of synfuel production
and product utilization over the next twenty years, and (2) a ranking of
products from the standpoint of environmental concerns. The data base used
consists of information obtained from mayor process developers, potential
product users, and published literature.

CANDIDATE TECHNOLOGIES AND PRODUCTS

Synfuel technologies likely to be used in commercial plants over the
next 20 years are 011 shale, coal gasification (low-/medium-Btu and SNG)
and coal liquefaction (direct and indirect). Brief descriptions of these
technologies and their development status are presented in Table 1. Major
products and by-products of these technologies and their anticipated
general uses are indicated in Figure 1; their specific likely end uses are
Visted in Table 2.

SYNFUEL INDUSTRY BUILDUP SCENARIOS

The development of a synfuel industry in the U.S. within the next 20
years will be influenced by a large number of factors, the most important
of which are:

e Avatlability of capital for financing the massive construction
costs

e Willingness of process developers, the private investment sector
and government to accept the technological risks involved tn the

construction of the "first-of-a-kind" integrated coal and shale
facilities

e U. S. Government energy policies and prices of domestic and
imported natural gas and 011

e Availability of skilled manpower, raw material, and equipment for
plant construction and operation

e Timely development of the supporting infrastructure necessary for
energy product manufacture, distribution, and use

e Environmental regulatory requirements, and the time and effort
required to acquire technical data to support permit applications
and obtain approval

. Effort and time required to attain full commercial status for
technologies/processes currently under development

-2-


el

TABLE 7. COMBUSTION TEST RESULTS FOR SRC II FUEL OILS
*
Investigators SRC II Fuels Tested Equipment/test Results
Singh, et al MD, HD, MD/HD blend, Sub-scale @ All fuels burned well
(ASHE Publication 3.1 No 2/SRC II blend, gas-turbine like © no significant handling problem
80-GT-67, March, 1980) 11 Wo 2/SRC II blend Combustor © max excess NOx levels (with HD) 20 to 130 ppm above baseline
@ increase 1n smoke levels with decreasing hydrogen content &
increasing aromaticity of fuels
© decrease in % emissions of fuel-bound nitrogen (FBN) with
increase 1n fuel FBN and outlet temperature
Bauserman, et al 5-1 MD/HO Full-scale combustor  @ NO, emisston for blend containing 9 63% FBN 30 to 120 ppm
(Paper presented at used in \Wlestinghouse higher than No. 2 distillates
Gas Turbine Conference, 30-to 9G-M engines, @ decrease in smoke value with increase 1n exhaust temperature
New Orleans, LA , 187-h corrnsinn test @ corrosion/deposition problems similar to petroleum-derived
Narch 19-13, 1980) using various alloys products
and SRC II solvent
wash
Babcock and W11cox Co 5 75 1 MD/HD Package boiler ® easy pumping/handling during test program (replaced hydrocarbon
(EPRI Report No FP-1028, Ambient monitoring seals with teflon/viton seals as precaution)
dune 1979) # no benzene/phenol emitted, based on ambient monitoring data
# NO, emssions for blend higher than for No.2 and No 5
# No tendency to smoke despite higher aromaticity
® lower particulate emission in comparison with No 5 017
@ ash composition for blend similar to that for No 5 011 except
for Fe, Ca, Mg, Cr, Mn and Sn which were higher
KVB, Inc 21 NO/HO 44-MW field borler © no major operation (burner optimization, boiler deposits,etc )
(EPRI Report No FP-1029, problems in comparison with No 6 fuel 01]
fay 1979. @ NOx emissions about 70% higher than for No 6 fuel o11
© lower particulate emissions compared to No 6 fuel 011, emssions
less than proposed NSS of 0 03 1b/M Btu
@ PNA emissions for both blend and No 6 less than 6 u/M3 (6x10-6
lb/M Btu)
© tendency for incomplete combustion comparable to No 6 fuel 011

(0 levels below 50 ppm)

“SRC 11 fuels MD = mddle distillate

HD = heavy distillate


“Gt

Direct Liquefaction
Syncrude {H-Coal,
SRC I, EDS)

SRC IT fuel oft

H-Coal fuel of)

EDS fuel off
SRC II naphtha

H-Coal naphtha
EDS naphtha

SRC IT gasoline
¥.Coal gasoline
EDS gasoline |

Indirect Liquefaction
FT gasoline

FT by-product.
chemica?

Mobs Te-M gasol ine
Methanp! |

Gasification |

ae

Low/medium-Btu gas

Gasifier tars, oils.

phenols

Higher aromatics and nitrogen

Higher aromatics and nitrogen

Higher nitrogen content

Higher nitrogen, aromatics

Higher nitrogen, aromatics
Higher nitrogen, aromatics
Higher aromatics

! Higher aromatics

Higher aromatics

Lower aromatics; N and $ nfl

(Gross charactertstics similar

; to petroleum gasoline)

Traces of metal carbony?s
and higher CO

(Composition varies with coal
type and gasifier design/
operation

(Composition vartes with coal
and gasifier types, highly
aromatic materials}

Higher NO, emissions

Higher NO, emissions

Higher NO, emissions

il

N/A

Higher aldehyde emssions

(Emissions of a wide range of trace and
minor elements and heterocyclic organics)

TABLE 9. REPORTED KNOWN DIFFERENCES IN CHEMICAL, COMBUSTION AND HEALTH .
EFFECTS CHARACTERISTICS OF SYNFUELS PRODUCTS AND THEIR PETROLEUM ANALOGS
Product Chemical Characteristics Combustion Characteristres Health Effects Characteristics _
Shale git Higher aromatics, FBN, As,Hg, Mn Higher emissions of NOx, particulate and More mutagenic, tumorigenic, cytotoxic
(possibly) certain trace elements
Gasol ine Higher aronatics Slightly higher NOx and smoke em{ssions
vet fuels Higher aromatics Slightly higher NO, and smoke emtsstons Eye/skin irritation, skin sensitization
same as for petroleum fuel
oFK Higher aronatics Slightly higher NO, and smoke emisstons Eye/skin irritation, skin sensitization
same as for petroleum fuel
Residuals Higher aromatics

Middle distillates non-mutagenic, cytotod-
city similar to but toxicity greater than
No 2 diesel fuel, burns skin

Heavy distillate Considerable skin carci n=
ogenicity, cytotoxicity, mutagenicity and
cell transformation

Severely hydrotreated non-mutagenic, non-
tumorigenic, low cytotoxicity

Non-mutagenic, extremely low tumorigenicity
cytotoxicity and fetotoxicity

Non-mutagenic

iil

Non-carcinogentc

Affects optic nerve

Non-mutagenic, moderately cytotoxic



PROJECT SUMMARY
ENVIRONMENTAL ASPECTS OF SYNFUEL UTILIZATION
M. GHASSEMI AND R. IYER

This study reviews the environmental concerns relating to the
distribution, handling, and end use of synfuel products likely to enter the
marketplace by the year 2000, and assigns priority rankings to these
products based on environmental concerns to aid EPA in focusing its
regulatory and research activities, Major products and by-products from
oil shale, coal liquefaction, and coal gasification technologies are
considered.

Based on current developmental activities, three likely scenarios for
shale and coal-based synfuel plant buildup are projected. The type and
quantity of synfuel products and by-products likely to enter the market are
identified and their regional market penetration is estimated. The
environmental analysis consists of a review of the available data on the
physical, chemical, and health effects characteristics of synfuel products
and environmental significance of the characteristics; an analysis of the
potential environmental impacts and regional implications associated with
the production and use scenarios considered; and a ranking of the products
from the standpoint of environmental concerns and mitigation requirements.

The results indicate that: (a) significant quantities of synfuel
products are expected to enter the marketplace during the next 20 years;
(b) large-scale transportation, distribution, and end use of certain
synfuel products can present significant threats to the environment and
the public health; (c) based on gross characteristics, synfuel products
appear to be similar to petroleum products, but detailed characterization
data are not available with which to judge their relative safety; and (d)
synfuel test and evaluation programs currently under way or planned provide
excellent opportunities for collecting some of the required environmental
data.

This 1s a summary of the complete project report, which can be
purchased fran the National Technical Information Service.

INTRODUCTION

To date, most synfuel-related environmental assessment programs have
focused on the technologies for synfuel production and on emissions from
production facilities. The present study constitutes the first major
effort by EPA to examine environmental concerns that would be associated

-1-


performance, in conjunction with a systematic product
characterization effort (recommended above) can provide valuable,
timely inputs to the evolution of the synfuel industry and would
ensure that: (1) environmental considerations are included in
the selection of processes, equipment, and product slates for
commercial facilities; and (2) the drafting of specifications for
synfuel products and new source performance standards for synfuel
plants and emissions standards for facilities using synfuel
products are based on the best available technical and
engineering data.

Consideration of end use environmental implications in the
selection of the product slates and 1n the development of the
synfuel industry. Synfuel processes and the subsequent refining
Operations can produce a range of products for a spectrum of

end use applications. By proper selection of the refining steps
(and the operating mode for some synfuel processes), the product
slate can be altered to favor the production of those products
that present fewer and more controllable end use environmental
impacts. Studies should be undertaken to define the engineering
and economics of selecting environmentally acceptable product
slate possibilities for various synfuel technologies. In this
connection, better coordination and exchange of technical data
should be promoted among process developers, regulatory agencies
and potential users and planners to ensure that process
"specialization" from a product slate viewpoint 1s taken into
account 1n synfuel conmmercialization programs.

Compilation of characterization/performance data on analogous
petroleum products. Because of the Targe-scale and widespread
utilization of petroleum products, these products have generally
come to be viewed by the public as environmentally innocuous.
Accordingly, the specifications for petroleum products have
primarily emphasized performance with little attention to
environmental consideration. Very little data are available (or
if available, have not been published) on potential pollutants
and toxicological and ecological properties of many of the
petroleum products to provide a baseline for assessing the safety
of synfuel products. It 1s recommended that the potentia

sources of data on petroleum products be contacted in an effort
to compile all available data and identify data gaps. It is also
recommended that the synfuel product testing and characterization
efforts recommended above include parallel testing of petroleum-
derived analogs.

-24-


PROJECT SUMMARY:

ENVIRONMENTAL ASPECTS
OF SYNFUEL UTILIZATION

December 1980

by

M. Ghassemi and R. lyer

TRW
ENVIRONMENTAL ENGINEERING DIVISION
Redondo Beach, CA 90278

EPA Contract No. 68-02-3174
Work Assignment No. 018

EPA Program Element No. CCZN1A

Project Officer: J. McSorley

Industrial Environmental Research Laboratory
Office of Environmental Engineering and Technology
Research Triangle Park, N.C. 27711

Prepared for:

U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Research and Development
Washington, D.C. 20460


under Scenario II, the environmental impacts of synfuel product ut?l1zation
would be expected to be largely limited to EPA Regions V and VIII for o11
shale; to EPA Regions IV, VI, and VIII for medium-Btu gas; to EPA Regions
III, IV, and VIII for indirect coal liquefaction products, and to EPA
Regions III, IV, and V for direct liquefaction products.

ENVIRONMENTALLY SIGNIFICANT CHARACTERISTICS OF SYNFUEL PRODUCTS

The environmental and health effects data currently available on
synfuel products are very limited and pertain mainly to certain primary
products (for example, crude shale oil or coal liquefaction syncrudes).
Very little data are avatlable on many of the secondary synfuel products
(for example, methanol and gasoline derived from coal) or on emissions
associated with end uses. Several combustion tests conducted with synfuel
products (primarily shale oil fuels} have been aimed primarily at the
evaluation of handling and performance characteristics. In general, the
product/emissions characterization has been in terms of gross properties
(for example, ultimate analysis, composition by chemical class, and
emissions of smoke and particulates during combustion), which by themselves
do not provide an adequate basis for assessing environmental significance.
The current product characterization data base 1s a collection of results
of sampling and analysis and performance testing that have been conducted
by different investigators using samples/batches of products obtained from
pilot plants operated under varying conditions. Accordingly, significant
inconsistencies exist in the reported results, which further hamper
assessment of the environmental safety of synfuel product utilization.
This assessment is also hindered by a lack of data on analogous petroleum
and natural gas products that the synfuel products will replace and that,
because of their large-scale and widespread utilization, have generally
come to be viewed by the public as environmentally innocuous. To
illustrate the type of data available on synfuel products, the reported
data on the physical and chemical characteristics of direct coal
liquefaction products and the combustion and health effects characteristics
of SRC II fuel oils are summarized in Tables 6, 7, and 8, respectively.

Table 9 identifies the differences 1n chemical, combustion, and health
effects characteristics of synfuel products and their petroleum analogs,
based on the reported characterization data. As noted in the table, for
the majority of products for which data are reported, these differences
primarily relate to the higher content of aromatics and fuel bound nitrogen
(FBN) and greater emissions of NOx during combustion. Although no test
data for synfuel products are available, high concentrations of aromatics
in fuels have been shown to enhance production of PNA's during combustion.
No actual data have been reported on the specific substances that comprise
the aromatic or FBN fractions in various synfuel products (or their
petroleum counterparts). In the case of fuels, high aromaticity has been
generally implicated in an increase in smoke production; the limited
combustion data which are currently available, however, do not indicate

that ail aromatic synfuels have higher smoke levels. High FBN content can
raise the level of NO. emissions; the excess NO. emisstons of synfuels are

believed to be correctable by combustion madifivéations. The nitrogen

-ll-


-bL-

TABLE 8. SUMMARY OF HEALTH EFFECTS DATA FOR SRC II PRODUCTS AND (WHERE AVAILABLE)
FOR PETROLEUM ANALOGS

Test

Naphtha

Light Fuel 011

Heavy Distillates

Ames Mutagenicity

Cytotoxicity (on cultured
mammalian cells)

Skin-parnting

Acute and subchronic
toxicity

Maternal and fetal
toxicity (rats)

Toxtesty via skin
absorption

No mutagenic activity for
SRC II (revertants/ug <0 01)
or petroleum naphtha

180 vg/ml dose required to
produce 2 50% reduction in
relative plating efficiency
(RPE), no comparative data
for petroleum analog

(RPEgg for crude petroleum
190-380 3/1)

As with petroleum naphtha
extreme low tumorigenic activity,
tumor incidence 1/46 at 20 mg/
application after 456 days

(vs 48/46 at 0 005 mg/applica-
tion for benzo(a)pyrene,

a known carcinogen)

Moderately toxic Acute gavage
rat Lg 2 3 g/kg, Subchromic
(5 days}°gavage sat LO5q

0 96 g/kg

No significant enhanced
toxicity to embryo or the
fetus (risk only slightly
higher than for the mother)

Unlike petroleum naphtha, shows
some acute effect at a high
dose levels (1 6 9/Kg)

No measurable mutagenic activity
(revertants/yg <0 01) mutagenic
activity demonstrated for certain
petroleum distillates

RPEsq 200 ya/mi (vs 259 ug/ml for
DieSel 01] No 2 and O 3 ya/ml for
cadmium chloride)

More toxic than diesel o1] (acute
rat LOsg=3 75 q/Kg vs 11 8 g/kg).
sub acute gavage rat LOgg=1 48 9/Kg

Same as for naphtha

Unlike the petroleum products,
can cause skin burns

Most mutagenic of the three SRC 11
products ra 40 : 23 revertants/yg)

with an RPEgg of 30 yg/nl,

most cytoxie of all synfuel pro-
ducts tested, very active 1n
effecting cell transfornation

highly potentTM, 12% and 100%
tumor incidents after 456 days
at 0 23 and 2 3 mg/application,
respectively, 35% of tumors
malignant

LDgq about the same as for
naphtha and light fuel ov)

Same as for naphtha

*No comparable data available for petroleum analog, but industrial

fuels ofls have been shown to present considerable skin carcinogenicity hazard.