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OAR Box 1107 

Prepped by Ollie Stewart 

Document Number: 

58) IV-B-8 

Docket Number: 

A-81-21 

Printed 4/11/2008 3:03:47 PM Sheet 58 of 90 
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A-8I-2I 

RADIAN 

CORPORATIO N 

MEMORANDUM 

DATE: July 29, 1985 

TO: Les Evans 

Chemical and Petroleum Branch 

FROM: R. H. Howie, K. K. Fidler 

Radian Corporation 

SUBJECT: Costs of Controlling Vinyl Chloride Emissions from EDC Storage 

Purpose 

The purpose of this memorandum is to present methods used for 

evaluating the cost effectiveness of controlling vinyl chloride (VC) 

emissions from ethylene dichloride (EDC) storage tanks. 

Summary 

The cost effectiveness of controlling VC emission from EDC storage is 

estimated to be greater than $8,600/Mg (1984 dollars). The achievable VC 

emission reduction from EDC storage at a typical EDC/VC plant is estimated 

to be 0.15 to 3.2 Mg/yr. Because all EDC production facilities are 

currently equipped with incinerators, ducting storage vent emissions to an 

existing incinerator was the control technique evaluated. This control 

technique would reduce VC emissions in EDC storage tank vents to 10 ppmv. 

The costs for incinerating storage tank emissions were estimated using 

previously developed cost information for control of benzene storage tank 

emissions. The VC emissions and achievable emissions reductions were 

estimated using model plant tank sizes and throughputs developed for benzene 

storage, AP-42 estimating techniques, and information provided by industry 

on VC concentrations in the vapor space of EDC storage tanks. 

Discussion 

VC Emissions from EDC Storage. VC emissions from EDC storage tanks at 

a typical EDC/VC plant were estimated based on storage tank sizes and 

throughputs for a large benzene producer (Reference 1). Table 1 describes 

the tanks included in the large benzene producer model plant. The large 

benzene producer model plant was selected as representative of EDC storage 

tanks and throughputs at a typical EDC/VC plant for the following reasons. 

The sum of throughputs for the final product storage tanks (rundown tank 

throughputs excluded) in Table 1 is 60 MM gal/yr. If EDC were the stored 

material (density of 10.5 lb/gal), this throughput would represent annual 

production of 630 MM lbs of EDC. In 1983, 17 EDC production facilities 

produced 11,247 MM lbs of EDC for an average of 660 MM lbs per facility 

(Reference 2). In addition, available data on EDC storage tanks verifies 

that the number and sizes of the model tanks are representative 

(Reference 3). 

Progress Center/3200 E. Chapel Hill Rd./Nelson Hwy./P.O. Box 13000/Research Triangle Park, N.C. 27709/(919)541-9100 
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AP-42 methods were used to estimate EDC emissions reductions from the 7 

model plant fixed roof tanks (Reference 4). A sample calculation for one 

tank is shown in Table 2. The estimated EDC emissions from all 7 tanks 

combined is 83 Mg/yr. Based on information from two industry sources, VC 

emissions are expected to be 0.11 to 2.35 percent of EDC emissions 

(References 5 & 6). Therefore, VC emissions from EDC storage are estimated 

to be 91 to 2,000 kg/yr for the model plant. 

Control Costs. The costs of piping, seals, pressure switches, blowers, 

and cleaning and degassing costs associated with venting storage emissions 

to an incinerator have been estimated previously for the large benzene 

production model facility (Reference 1). These costs are presented in 

Table 3 in 1979 dollars. The costs presented in Table 3 represent a vapor 

collection system connected to all tanks which is capable of handling 

emissions from a tank being filled at a maximum rate of 2,000 gpm. Piping 

costs include 600 feet of vapor collection pipe to connect each tank to the 

incinerator. 

Using a capital recovery factor of 0.1715 (15 year life, 10 percent 

interest, plus taxes, insurance, and administrative expenses) along with 

estimated maintenance costs at 1 percent of capital costs, the annualized 

cost was estimated: 

Annualized cost ($/yr) = $112,880 (0.1715 + 0.01) = $20,500 (1979 dollars) 

Cost Effectiveness. The cost effectiveness of controlling VC emissions 

from EDC storage at a typical plant is estimated as follows: 

Annualized control costs: $20,500/year (1979 dollars) 

VC emission reduction: 0.15 - 3.2 Mg/year 

Cost effectiveness ($/Mg VC) = Annualized control cost 

VC emission reduction 

= $6,400 to $137,000/Mg VC (1979 dollars) 

Updated Cost Effectiveness. The estimated cost effectiveness of 

controlling VC emissions from EDC storage were updated using gross national 

product deflator indices (References 7 & 8): 

3rd Quarter 1979 = 167.2 

3rd Quarter 1984 = 224.57 

Cost effectiveness ($/Mg VC) = $8,600 to $184,000 (1984 dollars) 
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' ^ 

REFERENCES 

1. U. S. Environmental Protection Agency. Benzene Emissions from Benzene 

Storage Tanks - Background Information for Proposed Standards. 

Research Triangle Park, North Carolina. EPA Publication No. 

450/3-80-034a. December 1980. pp. 3-21 and 7-35 through 7-43. 

2. Chemical Products Synopsis. Ethylene Dichloride. June 1984. 

Mansville Chemical Products Corp. Cortland, New York. 

3. Memo from Howie, R., Radian Corporation, to file. July 19, 1985. 4p. 

Summary of EDC Storage Tank Data. 

4. U. S. Environmental Protection Agency. Compilation of Air Pollution 

Emission Factors. Report No. AP-42; Supplement 12, Research Triangle 

Park, North Carolina. April 1981. 

5. Telecon. Komoroski, K., PPG Industries with Howie, R., Radian 

Corporation. June 20, 1985. Conversation on costs of controlling EDC 

storage tanks. 

6. Memorandum from Fidler, K., Radian Corporation to Dimmick, W. F., 

ESED:SDB. November 8, 1984. Summary of meeting with Vinyl Institute 

Representatives on October 30, 1984. 

7. U.S. Department of Commerce. Survey of Current Business. March 1980. 

U.S. Government Printing Office. Washington, D.C. p. 14. 

8. U.S. Department of Commerce. Survey of Current Business. May 1985. 

U.S. Government Printing Office. Washington, D.C. 
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TABLE 1. MODEL STORAGE TANKS FOR LARGE BENZENE PRODUCER0 

Tank 

No. 

1 

2 

3 

4 

5 (rundown) 

6 (rundown) 

7 (rundown) 

Tank Size (ft) 

Height Diameter 

39.8 

30 

41.8 

48 

30 

18 

30 

12 

9 

13 

15 

9 

5 

9 

Tank 

Volume 

(IO3 gal) 

770 

430 

1,050 

2,280 

260 

63 

170 

Annual 

Throughput 

(10° gal/year) 

10 

6 

14 

30 

31 

21 

21 

Annual 

Turnovers 

13 

13 

13 

13 

119 

119 

119 

Reference 1. 
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TABLE 2. EXAMPLE CALCULATION OF STORAGE TANK EMISSIONS 

Tank No. 1 

Height - 39.8 ft Stored Material Properties: 

(assume 100 percent EDC) 

Diameter - 12 ft Molecular weight = 99 lb/lb-mole 

3 Volume - 770 (10 ) gal True vapor pressure = 1.5 psia 

Annual throughput - 10 (10 ) gal 

Annual turnovers - 13 

Breathing Loss 

LR = 1.02 x IO'5 Mu ( P ) 0 '

6 8

 D1-73H0.51T0.5F QK (Reference 4) 

B v TO^P p c 

where: 

Ln = breathing loss (Mg/yr) 

M = molecular weight of product vapor (lb/lb mole); 

P = true vapor pressure of product (psia) 

D = tank diameter (ft) 

H = average vapor space height (ft) 

T = average diurnal temperature change in °F 

F = paint factor (dimensionless); 1.0 for clean white paint 

C = tank diameter factor (dimensionless): 

for diameter >_ 30 feet, C = 1 ? 

for diameter < 30 feet, C = 0.0771 D - 0.0013(D^) - 0.1334 

K = product factor (dimensionless) = 1.0 for VOL 
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TABLE 2. (Continued) 

LR = (1.02 x 10"5)(99)[ 1.5 ]0-

68(12)1-73(19.9)°-51(18)0,5(1.0H0.60)(1.0) 

B 14.7-1.5 

= 0.20 Mg/yr 

Working Loss 

Lw = 1.09 x IO"8 My PVNKn Kc (Reference 4) 

where: 

Lw = working loss (Mg/yr) 

M = molecular weight of product vapor (lb/lb mole) 

P = true vapor pressure of product (psia) 

V = tank capacity (gal) 

N = number of turnovers per year (dimensionless) 

K = turnover factor (dimensionless): 

for turnovers > 36, K = 180 + N 

n —6T ~ 

K = product facotr (dimensionless) =1.0 for VOL 

Lw = (1.09 x IO"8) (99)(1.5) (770,000)(13)(1)(1.0) 

= 16.2 Mg/yr 

Total emissions from Tank No. 1 = 16.4 Mg/yr 
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TABLE 3. INSTALLED CONTROL COSTS FOR SEVEN EDC STORAGE TANKS' 

Retired Equipment Installed Cost, 1979 Dollars 

Piping, pressure switches and 

backup pressure switches 

$67,840 

Two water seals and two backup 

water seals 

$12,480 

Cleaning and degassing of tanks 

Total Installed Costs 

$18,000 

$112,800 

Reference 1,