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OAR Box 1252 

Prepped by Candice Davis 

Document Number: 

42) ll-B-2 

Docket Number: 

A-90-22 

Printed 5/21/2008 11:46:01 AM 

I 

Sheet 42 of 184 
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S0QP©QQTO0C I 

HEWIRAKliiyi n 

A=S©< 

DD-i-2 

Date: January 8, 1992 

To: David Markwordt, EPA/CP 

From: David Ocamb, Radian pi 

Subject: Comparison of Benzene ThrougRput 

Benzene Transfer Operations 

fer and 

1.0 INTRODUCTION 

The purpose of this memorandum is to present the results of a 

comparison of the benzene production capacity and the quantity of benzene 

loaded data. These data were developed as part of the HQM Transfer effort 

and the Benzene Transfer analysis under the Benzene Litigation program. The 

primary purpose of this memorandum is to present the data differences for 

HON Transfer versus Benzene Transfer. 

Discussed below in Section 2.0 1s the development of the HON Transfer 

data for benzene production and throughput. Section 3.0 presents the 

development of the production and throughput data generated during the 

Benzene Transfer analysis and Section 4.0 presents the comparison of the 

data from each analysis. 

2.0 HOW TRANSFER THROUGHPUT DEVELOPMENT 

As part of th© overall 

and capacity utilization) 

project t©aa for approxlaafc 

analysis u§o§ this dafta and 

of mtertol l@ad©d 

HOM effort, production data (naceplate capacity 

hav© been collected b^ th© K0J3 Industrial Profile 

©ly 450 product processes. Th© KOJ3 Transfer 

Section 114 Information to estimate the volume 

frora a product process. 

The HCJ3 Industrial 

produce benzene. These 

reformation of naphtha, 

pyrolysis gas. Reference I 

using one or 

© identified three prodyet processes which 

product processes include catalytic 

ation of toluene, and hydrogenation of 

provides niweplate capacities for all facilities 

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more of the above processes. Using these capacities, the total U.S. 

production of benzene by these three product processes was estimated to be 

1,278,000,000 gallons for 1989. 

In order to determine the quantity of benzene loaded at a facility, 

data collected under a Section 114 effort were used to develop scaling 

factors to relate throughput to production capacity. Two scenarios were 

developed from the Section 114 data to represent the type of transfer 

vehicle loaded and the quantity of production transferred. Scenario 1 

represents loading of tank trucks and railcars with a scaling factor of 7 

percent for estimating the benzene throughput. Scenario 2 represents a 

facility loading tank trucks, rail cars, and marine vessels. The scaling 

factor for estimating benzene throughput for Scenario 2 was 27 percent. 

Once the capacity data and scaling factors were developed, the volume 

of benzene loaded was estimated by assigning a scaling factor considering 

whether benzene 1s loaded by marine vessel. Based upon the analysis of 

available marine vessel data, benzene was determined not to be transferred 

by marine vessel. As a result, Scenario 1 was applied to the benzene 

producers and the benzene throughput predicted represents 7 percent of the 

product process capacity. Using the Scenario 1 scaling factor, the total 

volume of benzene loaded for 1989 as estimated by HON Transfer was 

89,482,000 gallons per year. 

3.0 IENZENE TRANSFER THROUGHPUT DEVELOPMENT 

Qwfcg the Benzene Litigation prograra, benzene production data were 

assedbHo^ as part of the Benzene Transfer project. Three raajor areas were 

studied as part of this effort Including bulk terminals, coke ovens, and 

benzene producers. The development of the benzene throughput for benzene 

producers 1s documented below. 

IAJH 
In order to generate transfer emissions, a benzene producers facility 

11st was developed for the United States. Reference 2 and Reference 3 were 

used to develop a plant 11st with 74 Individual facilities. Due to 

constraints of the Paper Work Reduction Act, only nine of the benzene 

producing corporation were contacted to estimate the nationwide transfer of 

benzene for 1988 (the base year for Benzene Transfer). Of the nine 

corporations contacted by telephone, only five provided benzene throughput 

and production data representing 10 individual facilities. Based upon the 

data collected during the telephone survey, the entire volume of benzene 

produced annually was assumed to be transferred off-site. 

Reference 3 provided 1983 benzene production data for the majority of 

the remaining 64 producers. The few producers without capacity data 

available in Reference 3 were assigned the average production capacity from 

this reference source. 

At this point, the benzene capacity data Included 1983 and 1988 values. 

A scaling factor of 3.07 was generated using the total U.S. capacities for 

1983 and 1988 documented in References 2 and 4. The scaling factor was 

applied to the facilities with 1983 production data to Inflate to the 1988 

level. However, due to a typographical error in the capacity units in 

Reference 4 discovered after completion of the Benzene Transfer effort, the 

correct scaling factor was actually 1. The total benzene product capacity 

for benzene producers assuming that 100 percent of production was 

transferred was 914,000,000 gallons during 1983. This value reflects 

applying the seal inn factor of 1 to the 1983 data. 

—„——-»»—«—-^-TM—»»'—^i»'«—i—" ^ • • .*..**••.< 
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4.0 COMPARISON OF THROUGHPUT DATA 

As discussed in the above sections, the total benzene production 

estimated by HON Transfer was 1,278,000,000 gallons and the total throughput 

was 89,482,000 gallons. Whereas, the total benzene production and 

throughput for Benzene Transfer was 954,000,000 gallons. 

The actual difference in the benzene throughput estimates is that the 

HON Transfer estimate reflects loading 7 percent of capacity versus 100 

percent loading for Benzene Transfer. If the U.S. production capacities are 

compared, the HON Transfer estimate is approximately 30 percent larger than 

the Benzene Transfer estimate. If the two throughput quantities are 

compared, the Benzene Transfer throughput is an order-of-magn1tude greater 

than the HON Transfer throughput. If the 7 percent allocation factor is 

applied to the Benzene Transfer capacity, the throughput predicted is 

66,780,000 gallons. The predicted Benzene Transfer throughput 1s again 

approximately 30 percent larger than the HON Transfer estimate. 

In conclusion, the benzene throughput estimates generated under HON 

Transfer have a documented basis from Section 114 data. The two loading 

scenarios under HON Transfer have a documented basis supporting all 

assumptions. In contrast, a small number of producers were contacted by 

telephone during the Benzene Transfer analysis and the throughput data are 

questionable. The falling assumption in the Benzene Transfer analysis is 

that 100 percent of production 1s transferred which is severely contradicted 

by the HON Transfer Section 114 survey. 

in unmnul l —III 
•mPMOTHMMi 

§.0 REFERENCES 

1. Standard Research Institute. Directory of Chemical Producers. 1989. 

2. Standard Research Institute. Directory of Chemical Producers. 1988. 

3. Memorandum. Markwordt, David H., EPA/OAQPS/CPB, to Kellam, Robert, 

EPA/OAQPS/SASD. "Industry Profile/Benzene Loading Facilities." 

August 30, 1989. 

4. Standard Research Institute. Directory of Chemical Producers. 1983. 

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