1984-01-01 EPA-450-3-82-013a PB84-143254 Proposed FCCU SO2 Standards BID

Office
of Air Ouality
Planning and Standards

Agency
Research
Triangle Park NC 27711
January 1984
~------~------------
ai,
iE~k~
Sulfur
Oxides
Emissions
`-D~-ft
from
Fluid Catalytic Cracking

Unit Regenerators
-
Background
Information
for Proposed Standards
~i~aa~lil~ar"~L
~Y8n~~aaa~l~-~l~8~
pa~-~B~J~s~~~rsa~a~g~,~
9~
~~a~s~bL~asernrse~;secsr~ak~a
-1Pm~k* ---rP~s~
rul
n
r-~~-~
EPA-450/3-82-013a
Sulfur
Oxides
Emissions
from
Fluid Catalytic Cracking

Unit Regenerators
Background
Information
for Proposed
Standards
Emission
U.S
Standards
ENVIRONMENTAt
Office
I :
and Engineering
of Air,
PROTECTION
Noise.
and
Division
AGENCY
Radiation
Office of Air Quality Planning and Standards

Research
Triangle
Park, North Carolina 27711
January
1984
Th is report has been reviewed by t he Fm ission Sta nda rds and Engi neeri ng Division, Off ice of Air
Ouality Planning and Standards, Office of Air, Noise, and Radiation, Environmental Protection
Agency, and approved for publication.
Mention of company or product names does not
constitute endorsement
by EPA. Copies are available free of charge to Federal employees,
current contractors and grantees, and non-profit organizations
- as supplies permit - from the
Library Services Office, MD-35, Environmental
Protection Agency, Research Triangle Park,
NC 27711;
or may
be obtained,
5285 Port Royal Road, Springfield,
for a fee, from
VA 22161.
the
National
Technical
Information
Service,
ENVIRONMENTAL PROTECTION AGENCY
Background
and-
Information
Draft
Environmental
Impart Statement
Catalytic
Cracking
Unit Regenerators
for.fluid
Prepared
by:
I .~c~ii
armer~
glrectbr,.
8.5.
Emission Standards and Engineering Div~sion
Environmental
Research
Protection.
friangJe.
1. . Theproposed
sulfur
Agency
Park,. North Carol:ina.

standards
oxides
27711~
of performance
from new, modified,
would limit-emissions
and reconstructed
fluid
of
catalytic
cracking unit regenerators.

Section 111' of the Clean Air Act
(42 U.S.C. 7411), as amended, directs
the Administrator
to establish
standards of performance for any category of new stationary
sourcesof
air pollution
that".
.. causesor
contributes
significantly
to air pollution
which may reasonably be anticipated
to endanger
public health or welfare."

affected,
are
2:.
since
located
at
EPA Regions V, VI, and IX ate particularly
most fludd
petroleum~
catalytic
refinerier;
cracking
unit
in these
regenerators
regions.
Copies of thi s document; have been ~sent to the followi ng Federal

Depar.tments:
Labor, health and human Services,
Defense, Transportation,
Agriculture, Commerce,Interior,
Foundation;
State.
the Council
and Territorial
and Energy; the National Science
on Environmental'
Air
Pollution
Quality;
Program
members of the
Administrators;-
the
Association
of Local Air Pollution- Control Officials;
EPA Regional'
Administrators;
Office and Management: and Budget; and other interested
parties.
3.
The cormnent period for review of this document is 75 days.

Mr.. Gltbert H. Wood, Standards Development Branch, telephone
(919) 541-5578, may be contacted- regarding the date of the conrment
peri ed.. ~
4.
For
additional
Mr.
James
Chemicals
information
F..
Durham
and~PetroleumBranch
U.S. Environmental
Research Triangle
Telephone:
5.
contact:
(MO-r3)
Protection
Agency
Park, NC 27711
(919) 541-5671
Copies. of this
document'may be obtained
U.S. EPA Library

Research
Triangle
National
Technical
(MO-35)
Park,
NC 27711
InformationService
5285 Port Royal Road

Springfield,
VA 22161
from:
TECHNICAL
REPORT
DATA
(Pleose rend Inaruclions on Ihr reverse be/o~e complering~

2.
12. RECIPIENT'S ACCESSION NO.
i. REPORT NO.
EPA-450/3-82-013a
.TITLE
AND SUBTITLE
REPORT DATE
Su'lfur Oxides Emissions
from FluidCatalytic
3anuarv 1984
Cracking Urlit Regenerators - Background Information
I~TRFoRM~NZ-oRCnNIZATloNCooE
for Proposed Standards

7. AUTHORIS)
Is. PERFORMING ORGANIZATION REPORT NO.
.PERFORMING ORGANIZATION NAME ANO AOORESS
Office of Air Quality

Environmental
Protecti
110. PROGRAM ELEMENT NO.
Planning and Standards

on Agency
I11.CONTRACTlGRANT
NO.
Research Triangle Park, ~NorthCarolina 277'11

12. SPONSORING AGENCY NAME AND A6~dRESS
DAAfor Air guality

Office
of Air,
'
J1B.I~VPE OF REPORT AND PERIOD COVERED
Planning 'and Standards
Noise,
U.S. Environmental
1' 68-02-3060
Interim
and Radiation
Protection
Agency
~esearch Triangle Park, North Carolina 27711

15.
SUPPLEMENTARY
Final
10.SPONSORING
AGENCY
CODE
EPA/200/04
NOTES
ABSTRACT
aStandards
of performance
to controlemissions
of sulfuroxides(50~fromnew,
modified.andreconstructedfluid catalytic crackingunit regenerarorsare being

proposed under Section 111 of the Clean Air Act. This documentcontains
information on the background and authority, regu~atory a~ternatives considered,
and envi ronmental
7.
and economi c impacts of the regulatory
...
al ternatives.
KEY ~NORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERSIOPEN ENDED TERMS IC. COSATI FieldlCroup
Air, pollution
Air Pollution Central
Pollution
Sulfur
control
Standards of performance
Industrial
Petroleum
Fluid
catalytic
JStationary
133
Sources
cracking
lg. SECURITY CLASS (nlis Reporrl
Unclassified
unl i mited
2~. NO. OP PAGES
347
20.SECURITY-CLASS
(TlliJp~gel ' 122.PAICE
Unclassified
Form 2220-1
Oxides
Processes
refineries
Sulfur
oxides
s~s-rRleurloN
STATEMENT
EPI
~------
(R*.
4-77)
PREVIOVS
EDITION
IS OBSOLETE
TABLE OF CONTENTS
Ti tl e
Page
List
of Tables
..........
List of Figures
Abbreviations
.....
xvii
XiX
.......
xx
Metric
1.0
Conversion
SUMMARY
. I ..
3.0
1.1
Regulatory Alternatives
1.2
Environmental Impacts ...

1.2.1 Air Emissions Impact
1.2.2
2.0
Table
x'
.......
Water and Solid
1'-1

...

1-1
1-1
Waste Impacts
1.2.3 Energy Impacts

1.3 Economic Impact .......
INTRODUCTI
ON........
1'1
.....
. .~.....
1-1
1-2
1-2
2-1
2.1
Background and Authority far Standards ......
2.2
Selection
2.3
Procedure for Development of Standards of

Performance
....

2-6
2.4
2.5
Consideration
Consideration
2-8
2-9
2.6
Impact on Existing Sources ......
2.7
Revision
of Categories
of Stationary
of Costs .......
of Environmental
of Standards
2-1
Sources
..

Impacts ......
of'Performance
.......
2-4
2-10
2-11
THE CATALYTICCRACKINGUNIT PROCESSAND

POLLUTANTEMISSIONS ......

3-1
3.1
3-1
3-1
General~ .~........
3.1.1
3.1.2
Introduction
Domestic
Catalytic
3.2
....
Growth
Fluid Catalytic
Cracking
Emissions.
........
3.2.1
Fluid
Trends
Cracking.
Catalytic
Equipment ......
Affecting
in Fluid
......
Processes
and

Cracking
3-4
Unit Process
I
Sulfur
3-2
3.2.2
Factors
3.2.3
from FCC Regenerators .....

Emissions from FCC Regenerators
3-4
Oxides Emissions

......
3-10
3-15
TABLEOF CONTENTS(Continued)
Title
4.0
Page
3.3
Emissions
3.4
References
Under Existing
Regulations
,,,,,,.
3120
,,,,,,,.,,,,,,,,,
3-25
EMISSION CONTROLTECHNZqUES .....,........
4-1
4.1
Introductian
4-1
4.2
Flue
Gas Desulfurization
4.2.1
Applicability
of FGD Systems to FCC
Regenerators
,,,,,,,,,,,..,.
4.3
,,,,,,,,,,,.,,,.,,.
4-7
4.2.3
Calcium-Based
FGD Systems .,.,,,,,,
4-14
4. 2.4
Double Alkali
FGD Systems ,,,,,,,,,.
4-17
4.2.5
Spray Drying FGD Systems
4, 2, 6
Wel'lman-Lord System...........,
,,,,,,,,,
-
4-25
4-28
Feed Hydrotreating
4-36
4.3.3
4.3.4
Process
,,,,,,,,,,,,,,.
Description
Potential
Emissions
Benefits
,,,,,,,,,,
Derived
Feed Hydrotreating
,,,,
Development Status
,,,,.,,,,,,,
Process
Changes
4-38
from
Zeolite
4.4.2
Transfer
4.4.3
New Regeneration
4.4.4
Other Process
Sulfur
Oxides Reduction
4.5.1
Process
4.5.2
Development Status
Reconstruction
4-39
4-41
Catalysts,
4-42
.,,,,,,,,,
Line (Riser)
.~
Cracking
Techniques,
Changes,
,,,,
,,,,.,,,,,
Catalysts
Description,
,,,,,,
,,,,,,,,
,,,,,,,,,,
of
4-42
4-43
...
4-43
4-44
4-44
4-45
,,,,,,,,,,,,
4-46
...................
General~Discussion
FCC
,-,,,,,,,
,,,,,,,,,,,,.,,
4,4, 1
References,
4-36
for Reducing FCC Regenerator
Oxides
Additional
,,,,,,,,,,,.
4-49
5.0 MOG!FICATION
ANDRECONSTRUCTION.
.........,
5.1
4-20
4.2.7 Citrate-Based FGDSystems ,,,,,,,,,
Sulfur
4,6
4-2
Sodium-Based FGD Systems
4.3.2
4.5
4~1
4.2.2
4.3.1
4.4
.............
Modification
Provisi'ons
,,,,,,,,,,,.
5-1
and
5-1
TABLE OF CONTENTS(Continued)
Title
Page
5.2
5.1.1
Modification
5.1.2
Reconstruction
Applicability
..........
........
of Modification
5-1
5-2
Provisions
FCCRegenerators.
Repair,
.
to
5.2.1
Maintenance,
and Replacement ...
5.2.2
5.2.3
Increasing Capacity. ...........

Increase in Hours of Operation
5.2.4
Change in FCCFeedstock Qua7ity. .....
5.2.5
Addition,
Applicability
of Reconstruction
to FCCRegenerators
5.3.1
Conversion
5-6
Provisions
5-6
to High Temperature
Regeneration
5.3.2
516
Addition or Replacement of Regenerator

Combustion Air Blower, Cyclones,
or other Regenerator
Internal
Components
5.4
References.
...........1
6. 1 Model Plants............
Regulatory Alternatives
6.2.1
6.2,2
6.2.3
6. 2.4
7.0
5-1
.........
Regulatory Alternative
Baseline
5-7
5-8
6.0 MODEL
PLANTS
AND
REGULATORY
ALTERNATIVES
.......
6.2
5-5
of a
System to Control Air Pollutants

5.3
5-3
5-4
5-5
......
Removal, or Disabling
5-3
6-1
6-3
I - The
Level
6-6
Regulatory Alternative IZ. ........

Regulatory Alternative III ........
Regulatory Alternative IV. ........
6-6
6-7
6-7
6.3 References. .....

ENVIRONMENTAL
IMPACTS............

5-10
7-1
7.1
7-1
Introduction
.....
7.2 Air Pollution Impacts of R~gulatory Alternatives.

7.2. 1 Primary Air Pollution Impacts ......
7.2;2 Secondary Air Poll'ution Impact ...
'. ..
-vi i
7-2
7-2
7-2
Title
Page
7.2.3
7.2.4
Dispersion
Modeling
Five-year
.,.,,,...,
7~4
Impacts of Regulatory
Alternatives
...............
7-7
7.3 OtherEnvironmental
Impactsof the Regulatory
Alternatives,
7.3.1
.,.,,..,,,,........
Water Pollution
Scrubbers
7.3.~2
Solid
Waste
8.0
7.3.3
Energy
7.3.4
Other
of Sodium-based
7-10
Impacts
of Sodium-based
,.,.,..,,...,...
7-13
Impact
of Sodium-based
Scrubbers,
7113
Impacts
of Sodium-based
Scrubbers.
7-15
Environmental
Impacts
Technologies
..,....,.....,,,..
of Other
Control
7-15
7.4.1
Dual Alkali
..,...,,..,..,.
7-18
7.4.2
Wellman-Lord
...............
7-20
7.4.3
Citrate
7.4.4
Spray
7.4.5
Sulfur
7.5
Environmental
7.6
References..,
COST ANALYSIS
8. 1
Introduction.
8. 2
Sodium-Based
8. 2. 1
8.2.2
8.3
Impacts
................
Scrubbers
7.4
7-10
.................
Drying
7-21
...............
7-21
Oxides Reduction
Impact
Catalysts
of Delayed
Standards
..,.
7-21
,...
7-22
.'...............
7-23
.,,.......,..,,.,..
..................
Flue
Gas
&1
8-1
Desulfurization
Capital
and Annual
High Energy Venturi
Costs
..,
Costs for Sodiurn-Based

Scrubbers.
.,,...
~2
8-2
Capital
and Annual Costs for Sodium-based
Jet Ejector
Scrubbers
,.,,.,..,.
8-14
8. 2.3
Water and Solid
WasteCost
8-18
8.2.4
Nationwide
Impacts
Other Control
Cost
Technology
8. 3. 1
Dual
Alkali
8.3.2
Wellman-Lord
Flue
Costs
Gas
.,,.,..,...,.,
Vfll
Impacts
,...
,,,.,.,,.
8-19
.,..,,,.,
8-19
Desulfurization
,,.
8-21
8-24
Title
Page
8. 3. 3 Citrate
FGDSystem Costs .........
&24
8. 3.4 Spray Drying ...............

8. 3. 5
9.0
8-28
Su'lfur Oxides Reduction
8.4
Other Cost Considerations
8. 5
Refe ren c e s
....
Catalysts
Costs.
.........
.'.
.......
9.2
9.3
General
9.1.2
Market
9.1.3
Financial
Profile
............
9-1
9-12
..
~ .........
9-23
Economic Analysis .............
9.2.1
Introduction
9.2.2
Economic Impact Methodology
9.2. 3
Economic Impacts
9.3.1
9.3.2
and Surranary .........
and Inflationary
Executive
Small
Order
Business
References
.......
9-26
9-43
Impacts
12291
.....
9-48
..........
Impacts
9-49
..........
~.
9-50
9-51
............
APPENDIX A I EVOLUTIONOF THE PROPOSED STANDARDS .....

A.1
Introduction
A.2
Chronology
9-26
9-26
.............
Regulatory Flexibility
9.4
9-1
..............
Profile
839
9-1
.............
Factors
Socioeconomic
8-35
Industry Characterization
9.1.1
8-28
..
ECONOMIC
IMPACT ...............
9.1
..........
A-i
A-2
A-2
APPENDIX B - INDEX fO ENVIRONMENTAL

CONSIDERATIONS ....
B-1
APPENDIXC - EMISSIONSDATA................
C-l
C.i
Introduction
C.2
Flue Gas Scrubber
C.3
C.4
..................
Emissions
C.2.1
Guarantee
C. 2. 2
EPA-Conducted
Sulfur
Oxides Reduction
C.3.1
Sulfur
Results
References
C-2
Test Data .....,
0-2
and Compliance Test Results

Source
Test
Catalyst
Oxides Reduction
...........
..............
Results
Test Data
Catalyst
..
...
C-3
.-
...
Test
I .....
ix
C-6
C-7
C-7
0-30
TABLEOF CONTENTS(Concluded)
iitle
Page
APPENDIX D - EMISSION MEASUREMENT

AND CONTINUOUS
MONITORING ..............,...
D-l
D.1
Emission
Measurement
Methods
Emission Testing
0.2
.....,.....
Program ......,..
0-2
to EPA Method 8 .......
0-5
0.1.2
Modification
0.1.3
Development of Modified Method 8 Train
Monitoring
0.2.1
Systems
0.2.2
and Devices
0-5
D-10
in vppm
.....,.......,,..,
0-10
GEMS
to Monitor SO, Emissions in Kilograms
SO, Per Kilogram Coke Burn-Off
0.4
..
....,...,
CWS Monitor SO, Emissions

Format
0.3
D12
Performance
Test Methods
0.3.1
Stack
0.3.2
Feed Sulfur
References
Emissions.
Format
..
,....,,,,...
0-14
.........,,,
levels
0-14
......
,.,...
D-15
...........,...,
~ . ~
APPENDIX
E - PROJECTED
GROWTH
INFCCU
CAPACITY
......
E.1
Introduction
E.2
Historical
E.3
Five-Year
E.4
References
0-13
.....,..,..,,,,,
0-18
E-1
5-2
FCC Growth Data

Growth Projection
.........,
5-2
.....,..,,
E-4
......,......,,,,,
EllO
APPENDIX F - ANALYSIS OF HEAVYOIL CRACKER
SOxE~4ISSIONS
AND
CONTROL COSTS
F.1
Introduction.
.....,......,,
,'..,
F-l
F,2 HOC
ModelPlant SOxEmissions..........
F-2
F.3
HOCModel Plant
F-2
F.4
References.
Control
.,...........,.,,..
Costs
..........
F,8
LIST
OF TABLES
Tab~
1I1
Page
Assessment
of Environmental
and Economic
for Each Regulatory Alternative
Impacts
Considered
.....
3-1
State Air Regulations for SO Emissions Applicable
to fluid Catalytic Cracking6nit Regenerators ....
3121:
4-1
FGDSystem Commercial Applications.
4-3
4-2
Analysis
of Elemental
and Coal.
..................
4-3
4-4
Compositions
Coal-Fired
Performance
of Coke

Comparison of Flue Gas Analyses

and Industrial
.........
Data for
for FCC Regenerators
Boiler
Operating
........
4-6
417
4-8
Industrial
Boilers
Sunrnary of Operating
Boiler Double Alkali
as
Summary of Operating
U.S.
March
1978.
4-13
for
......
4-18
and Planned Industrial

Systems. ............
Suimnary of Some Industrial

Systems ...................
the
Boiler
4-21
Spray Drying
....
Citrate
FGD Process
4-10
Performance
Feedstocks.
4-26~
Wellman-Lord Systems in
...................
4-9
4-6
.........
Based Systems
Summary of Committed Calci

U.S.
.~..
Sodium-Based
FGDSystems on FCC Unit Regenerators

4-5
4-5
...
Units
4-29
..............
Data for Hydrotreating

...................
4-35
of FCC
..
4-40
4-11Summary
of SOxReduction
CatalystPerformance
Oata.
4-47
6-1
Model
6-2
6-2
Summary of Regulatory
7-1
Annual
FCC Unit
Sulfur
Reductions
7-2
7-3
Oxides
Alternatives.
Emissions
Parameters
for
Dispersion
Model Analysis
Results
Projected
..............
for Each Regulatory

Model FCC Unit
of Dispersion
Emissions-from
7-4
Parameters
and
.........
6-9
Emission
Alternative
.....
7-3
Regenerator
.......
I .....
7-5
Modeling for Su7fur Oxides
Model FCC Units
and PSD Increments
New FCC Unit Construction
Schedule
....
..
7-6
7-8
1lST OF TABLES(Continued)
Table
7-5
7-6
Page
Projected
Schedu.le
FCC Unit ~odification/Reconstruction

..........,..,...,,
7-8
7-9
.,..........,.....,
~~ ~
7,9
Aqueous Discharges from FCC Unit Sodium-based

Scrubber Systems ..,,,,,....,.,.....
7-11
Annual Operating Electricity

Requirements for Sodiumbased Scrubber Systems and FCC Units ,,..,...,
7-14
Annual Operating Energy Requirements for Sodium-based

Scrubber Systems and FCC Units ...,...,..,.
7-16
7-10 Nationwide Fifth-Year

for Soaium-based
7-11 Fifth-Year
Control
8-1
7,8
Annual Impacts of Regulatory Alternatives

on Sulfur
Oxides Emissions from New and Modi fled/Reconstructed
FCC Units
7-7
..~
Operating Energy Requirements
Scrubbing
......,.,.,,,
7-17
Nationwide Environmental Impacts by
System and Regulatory
Alternative
......
7-19
Capital Cost for Sodium-Based High Energy Venturi

Scrubbing
System and Purge Treatment
for Model Units
8-2
Assumptions
8-3
Bases for Determining Annual Costs .,.,...,..
Used to Develop Annual Costs .......
8-3
8-6
g7
8-4 Annual Cost of Sodium-Based High Energy Venturi

Scrubbing for Model Units by Regulatory
Case 1 ............,,...,.
Alternative
~ ~ ~ ~ ~

Scrubbing for Model Units by Regulatory Alternative
Case 2
8-8
8-9
.......
8-6 Annual Cost of Sodium-8ased High Energy Venturi

Scrubbing for Model Units by Regulatory
Case 3 0I
Alternative
8-10
8-7 Annual Cost of Sodium~Based High Energy Venturl

Case 4 ....,..,.,..,.,..,.
, ~ ~ ~ ~

Scrubbing fo~r Model Units by Regulatory Alternative
Case 5
8-11
8-12
xi i
LIST OF TABLES(Continued)
Table
8-9
Page
Annual Cost
of Sodium-Based
High Energy
Venturi

Case 6 ...................
.....
8-13
8-10 Capital Cost for Sodium-Based Jet Ejector Venturi

Scrubbing System and Purge Treatment forModel Units
8-11 Annual
Cost of Sodium-Based
Scrubbing
Jet
Ejector
for Model Units by Regulatory
Venturi
Alternative
Case 7 ...................
8-12
Annual
Cost
of
..
Sodium-Based
Jet
Ejector
1 ............
8-13 Comparison of Fifth-Year
Nationwide
8-17
Scrubber
System
Costs
8-20
8-14 Dual Alkali Scrubbing

Weight Percent Sulfur
Alternative
System Costs Based on 1.5

Feed and Regulatory
I1I
8-15 Wellman-Lord
8-22
SO
Recovery
System Costs
Based on
1.5 WeightTerc~ntSulfurFeedandRegulatory
Alternative
IrI
8-16 Citrate FGDSystem Costs Based an 1.5 Weight Percent

Sulfur Feed and Regulatory Alternative
III
8-17 Spray Drying Costs Based on 1.5 Weight Percent
Feed and Regulatory Alternative

8-18 Statutes
Refining
9-2
Refineries
with
Units 1980...'.
Percentage
Products
913
Precipitator
Production
Refineries
Volume Yields
from Crude Oil
&29
8-33
8-36
Costs ...........
Fluid Catalytic
................
8-25
Sulfur
III
That May Be Applicable to the Petroleum

Industry
......
I ...........
8-19 Electrostatic
9-1
8-16
Venturi

Case 8 ...........
&15
8-37
Cracking
9-2
of Refined Petroleum
in the
of Petioleum
Products
1969-1978 .................
U.S.
1971-1978.
at United
....
9-7
States
9-8
LIST OF TABLES.(Continued)
Table
Page
9-4
Refinery
Facilities
9-5
Employment
of Major Companies ........
in Petroleum
and Petroleum
and Natural
Refining
Average Hourly Earnings
9-7
Estimated
1981 United
Composition........
of Selected
States
Demand Projections
9-9
Price Elasticities
for Major Refinery
By Sector . ..........,........
9-13 Price
Projections
....
9-13
Pool
9-14
for Major Petroleum
Products
...
9-15
Products
~ ~
.........,
9-11 Domestic Oil Exploration

Gasoline,
Fuel Oil
9-11
Industries
Gasoline
.'.....,,,,,,
9-8
9-12 Prices:
Residual
Gas Extraction
1969-1978 .........,
9-6
9-10 Crude Oil Statistics
9,9
.,,,...
and Discoveries
Distillate
.........,..,,.,,.
....,.
Fuel Oil,
9-17
9-19
.-
9-20
and
9,21
...............,..
9-22
9-14 Imports of Refined
Petroleum
Products
........
9-24
9-15 Exports of Refined
Petroleum
Products
.,....,.
9-25
9-16 Profit
Margins
..............,,.,,
9-17 Return on Investment

9-18 Petroleum
Refining
.................
9-28
- Income Data ......,..,
9-19 Refinery Product Yields
9-27
9-29
.............,.
9-32
9-20 Refinery Annual Revenue; Small Refinery; 64 Percent

Capacity
Utilization:
Before FCC addition
9-21 Refinery Annual Revenue; Small Refinery;

Capacity
Utilization:
After
FCC Addition
.,....
9-33
64 Percent
......
9-34
9-22 Refinery Annual Revenue; Large Refinery; 64 Percent

Capacity
9-23 Refinery
Capacity
Utilization:
Before FCC Addition
......
Annual Revenue; Large Refinery; 64 Percent

Utilization:
After FCC Addition
......
xiv
9-35
9-36
LIST OF TABLES (Continued)
Table
9-24
Page
Example:
Cash Flow Analysis;
Regulatory
9-25
9-26
9-27
C-3
Alternative:
Internal
Rates
= 64X
of Return
Flue
Flue
Flue
Flue
Plant
C-7
Flue
Plant
C-8
Flue
Plant
C-9
Flue
Plant
C-1O
C-ll
,..
Dioxide
Test
.,,,.....,
C-9
Test Data for

,.....,,..
C-10
Emissions
A, Guarantee
test
Gas Scrubber
Scrubber
Gas
Gas
Gas
Scrubber
B, Test
Scrubber
B, Test
Gas Scrubber
B, Test
Test
Flue
Plant
Gas
C,
Scrubber
Unit I
Flue
Plant
Gas Scrubber
C, Unit II.
Data
C113
Data
................
Emissions
Scrubber
B, Test
Test
Flue
,,,,,.,.,,.,,,.
Emissions
A, Compliance
B, Test
Test
Data for
9-47
Emissions
.,,,,,.,,
Gas Scrubber
Gas
9-45
Uti'litation
Summary of Sulfur
Dioxide Emissions
Sulfur Oxides Reduction
Catalysts,
Plant
C-6
Refinery
9-44
,,,,,,,,,,,,.,..,,.
Summary of Sulfur
Plant
C-5
9-40
Percent
Price Increases
by Regulatory
Large Model Unit ...................
Plant
C-4
Case 2,
,,,.,,.,,,
Alternative:
Gas Scrubbers
C-2
II
Percent
Price Increases
by Regulatory
Small ~iodel Unit ...................
Rate
CI1
Alternative
Test
C-14
Data
...................
Emissions
C-15
Test
Data
,,,,,,,,,,,,,,
Emissions
,
Test
Data
.........,.........
Emissions
C-17
Test
Data
.,.................
Emissions
C-18
Test
Data
...................
Emissions
...................
Emissions
..................
C-16
C-19
Test
Data
C-20
Test
Data
C122
xv
LlST OF TABLES(Concluded)
C-12 flue
Gas Scrubber
Test
C-13 Flue
Test
EPA-Conducted
C-16 Sulfur
Test
Emissions
Test
1,
Oxides
Test
Data Plant
C-24
D,
.
0-26
Emissions Test Data Plant A,
Source
rest
Oxides Reduction
E,
D, Compliance
...............,...
C-J4 Flue Gas Scrubber
Plant
Test Data Plant
.....
Gas Scrubber
Guarantee
C-15 Sulfur
Emissions
...,...............
....,.........
Catalyst
C-27
Test Data -
...................
Reduction
C-28
Catalyst
Test
Data Plant
1 ...................
F,
.....
C-29
D-l S02 ContinuousMonitoringCost .........,
D-ll
E-l
U.S. FC6UFresh Feed Capacity 1971-1980 .......
E-3
E-2
FCCU Regenerator
hew Unit
Construction
1971-1980
...
E-5
E-3 Projected U.S. FCCU

Fresh FBedCapacity .......
E-8
F-l
Assumptions
F-3
F-2
HOCModel Plant
Used to Develop HOCModel Plants

Sensitivity
Analysis,
.....
Parameters
Usedand ResultingSOxEmissions...,.....,
F-3
HOC Model Plant
Control
Costs
and Cost
xv~
Effectiveness
F-5
.
F-6
LIST
OF FIGURES
Figure
3-1.
Page
Statewide
Distribution
Fluid Catalytic
3-2.
Basic FlowDiagram
Location'of
of Refineries
with
Cracking Units As of January 1980 ..

of Petroleum
Catalytic
Refinery
3-3
Showing
Cracking Unit. ........
3-3.
Schematic
3-4.
Relationship Between Feed Sulfur and Coke Sulfur ..
3-11
3-5.
Comparison Between feedstock Sulfur/Coke Sulfur

Correlation and Actual FCCUnit Data ........
3~17
3-6
of a Fluid
Catalytic
Comparison Between Model Plant,

Actual FCC Unit Sulfur
4-1.
4-2.
4-3.
Cracking
3-5
Process
Pilot
Unit ....
Plant,
Oxides Emissions
and
Data ....
3-18
Layout of the Sodium-Based Venturi
Scrubbing System Applied to FCCRegenerators ....
4-9
Jet Ejector Venturi Scrubber ............
4-10
Process
Flow Diagram for a Typical
Calcium-Based
Wet Scrubbing System ............

4-4.
3-6
Simplified
Flow Diagram for a Sodium/Lime
Double Alkali
Process.
...........
4-16
4-20
4-24
4-5. SimplifiedFlowDiagram
for SprayDrying
Process
""
4-6.
Process Flow Diagram ~ellmam-Lord Process
4-7.
Flow Diagram for the Bureau of Mines Citrate

Process.
..........
.....
4-27
4-31
4-8
Flow Diagram for the F~akt~Boliden Citrate Process .
4-32
4-9
General
4-37
6-1.
Regulatory Alternatives.
CI1.
Results
Process
of Flue
Schematic
for Feed Hydrotreating
..........
Gas Scrubber
Results
of Flue
for Industrial
Gas Scrubber
6-5
Continuous
Monitoring at Refinery A ..............

C-2.
..
Continuous
Boiler A ..............
D-1. Manual Sampling Port Adapter ............
-xvii
CI11
Monitoring
C-12
0-3
LIST OF FIGURES (Concluded)

0-2.
0-3
E-l.
Experimental
EPA Method 8 Train'to
Scrubber
Include
Modified EPAMethod 8 with Acidified

Size
Distribution
Between
E-2. Projected
of
New Units
NH
IPA Impinger. .
0-7
0-9
Constructed
1971 and 1980...............
- E-6
U.S. FCC Fresh Feed Capacity
xv~~~
.......
E-7
ABBREVIATIONS
8ACT
Best
CFR
Code of Federal
CRC
Coke on Regenerated
ESP
Electrostatic
FCC
Fl u i d i ted Catal yt i c Crac ki ng
FGD
Flue
HTR
High Temperature
L/G Ratio
Liquid
Mg
Megagram
Mm3
Million cubic meters
NAAQS
National
sd
Stream
ed
Calendar
~S
Hydrode sul fu ri zat i on
Sm3
Standard cubic meters
Nm
Available
Control
Technology
Regulations
Catalyst
Precipitator
Gas Desulfurization
Regeneration
to Gas Ratio
Ambient Air Quality
Standards
day
day
Normal(standard, dry) cubic meters
xix
METRIC CONVERSION TABLE
Meter (m)
3.28
= feet (ft)
Cubicmeter(,3)
x 6.29
= ~arrel(oil)(bbl)
Cubicmeter(,3)
x 35.31
= cubicfeet (ft3)
Kilogram (kg)
2. 20
= pound (Ib)
Megagram (Mg)
1.10
= ton
Pascal(Pa)
x 14,5x 10'5
= poundsper square
inch absolute
Degrees Celsius (C")
0 x 1.8 + 32
(psia)
= degrees fahrenheit ("F)
PREFIXES
Multiplication
Prefix
Symbol
Factor
kilo
103
Mega
Fl
106
xx
1.0
1.1
SUMMARY
REGULATORY ALTERNATIVES
Standards of performance for sulfur

modified or reconstructed
fluid catalytic
petroleu~refining
Section
111
industry
of
the
Clean
Four regulatory
the baseline
control
Air
achieved
sulfur oxides regulations.

emissions from FCC units
sulfur
and Alternative
burn-off.
sulfur
these
1.2
1.2.1
the level
emissions
IV would
regulatory
oxides
to meet ~ost State
limit
to 9.8
these
that
emissions
either
catalysts
kg/1,000
will
and local
kg coke burn-off,
to 6.5 kg/1,000
kg coke
flue gas desulfurization

be used
by refiners
sulfur
or
to meet
Impact
oxides
in the fifth
emissions
from new, modified,
year under Regulatory
are 78,800 Mg, compared to 20,100,

~llternatives
II,
emissions
reduction
for Regulatory
III,
15,100,
Alternatives
II,
III,
The average
level
disposed.
in a wastewater
Imp~ementation
and IV, respectively.
discharge
of Regulatory
1-1
percent
are 74, 81, and 87 percent
Water and Solid ~laste Impacts

The application
of sodium-based scrubbers
results
I (baseline)
and 10,100 Mg under
from the baseline
and reconstructed
Alternative
for control
of sulfur
which must be treated
Alternatives
II,
I,
emission
alternati~er.
Air Emissions
FCC units
oxides
of sulfur
ENVIRONMENTAL IMPACTS
Total
1.2.2
of
Alternative
II would limit sulfur oxides
to 13.0 kg/1,000 kg coke burn-off.
Alternative
oxides
reduction
are considered.
by FCC units
It is anticipated
oxides
under the authority
Act.
represents
currently
~i~ould limit
are being developed
alternatives
level,
oxides emissions from new dnd

cracking (FCC) units in the
III,
and
or IV
IIT
wouldincrease wastewaterdischarges in the fifth year ~y 2.4 Mm3

Thp treated wastestrean would contain about 98 l"!g/yrof suspended
solids, 12 kg of dissolved solids, and 98 Mgof chemical oxygen demand.
Sodium-based scrubbing for sulfur oxides emissions control
does
not result in any incremental changes in the amount (dry weight! of

solid wastes produced over that resulting
from the particulate
NSPS.
Honevcr, the use of dual alkali flue gas desulfurization would produce
a calciuri~sludge and increase the volume of solid ~,aste to be disposed.
From preliminary information;
catalysts tq FCCunits will result
impacts
over
the
baseline
application of sul~ur oxides reduction

in negligible water and solid waste
level.
1.2.3
~Energy Impacts
The overall energy impacts of implementing Regulatory Alternatives
through IV are negligible.
However, the electrical
requirements would
substantially
increase for modified or reconstructed units with carbon
II
monoxidecombustionfurnaces to employsodiurn-basedscrubbing. Electricity

consumption
would rise
operate
ejector
jet
approximately
20 percent
for these units
to
venturis.
A more detailed analysis of environmental and energy impacts is

presented in Chapter 7. A summaryof these impacts for the regulatory
alternatives
1.3
is
ECON(T~IC
shown in Table
I~1PACT
The nationwide capital

through
1~1.
IV are developed
and annual costs of ~egulatory ~lternatives
for new, modified,
and reconstructed
II
FCC
units over the 5-year period from 1982~to ~1986. ~hese costs are based
on the application of sodiun~based flue gas desutfurization.
Table 1-1
summarizesthe economicimpacts of these costs for each of the regulatory

alternatives.
During this 5-year period. the nationwide cumulative capital

costs of Regulatory Alternative
II for the industry would be 972.1 million.
The nationwide fifth-year annual cost to the industry under Alternative II
wouldbe 932.1 million. Thenationwide 5-year cumulativecapital

costs for Regulatory Alternatives
Nationwide
annual costs
III and IV would each be 980.7 million,
of 835.3 million
and 936.7 million
would be
incurred in the fifth year for Alternatives III and IV, respectively
The costs to industry of Alternatives II through IV are expected to Se
1-2
Table 1-I.
ASSESSMENT
OF ENVIRONMENTAL
ANDECONOMIC
IMPACTS
FOKEACH
REGULATORY
ALTERNATIVE
CONSIDERED
Solid
Ada,inistrative
Air
Water
waste
Energy
impact
impact
impact
impact
impact
impact
-4f
II
+2f
-2*
-If
-1*
I11
+3+
-2*
-1*
-1*
-If
-2'
1V
+4*
-2~
-1*
-1*
-If
-2f
DelayedStandards
-4*
No Standards
-4*
action
Regulatory
Alternative
Regulatory
Altemative
Regulatory
Alternative
Regulatory
Alternative
KEY: + Beneficial impact

- Adverse impact
O No impact
1 Negligible
2 Small inipact
3 Moderate impact
4 Large impact
impact
' Short-term iinpact

*f Long-tenn impact
*f* Irreversible
impact
Noise
Economic
-2"
significantly
lower through
application
of sulfur
oxides
reduction
catalysts.
Economic analysis
indicates
that
the
impacts
of Alternatives
II
through IV are small bared on the use of flue gas desulfurization.

Expected
price
increases
in refined
products
to account
for
the costs
of the regulatory alternatives

are less than 0.40 percent for new,
modified, and reconstructed
units with flue gas ljesulfurization.
E~pected
catalysts.
price
increases
A detailed
would be less
economic analysis
1-4
for
sulfur
oxides
is presented
reduction
in Chapter 9.
2.
2.1
BACKGROUNDAND AUTHORITY iOR STANDARDS
Before
air
INTRODUCTION
standards
pollution
associated
examined
of performance
control
costs
methods
available
of installing
in detail.
Ilarious
levels
of these
standard.
alternatives
the economics
impacts
obtained
be able to see the

proposed
the
these
information
impacts
alternatives.
so that
considered
basis
for
impacts
on the
This document
studies
a
on
national
summarizes
interested
the
persons
by EPA in the development
will
of the
to
as
standards
source
of air
to air
pollution
health
or
the
Act.
Section
of perfo~mance
pollution
which "...
111 directs
for
741'1) as amended,
the
any category
causes,
which may reasonably
to
of new stationary
or contributes
be anticipated
herein-
Administrator
significantly
to endanger
public
welfare."
The Act requires
ref7ect,"...
that
standards
of performance
the degree of emission reduction
consideration
nonair quality
the
health
cost
determines
of sources."
The standards
or modification
of
achieving
and environmental
Administrator
publication
sources are established
111 of the Clean Air Act (42 U.S.C.
referred
establish
tion
industry,
are
technolo-
ten~ns of their
an the environment.
through
on different
by EPA as a prospective
of performance for new stationary
under Section
into
of.the
equipment
as regulatory
investigatedin
and the
standard.
Standards
after
are
and well-being
economy, and the

information
are expressed
based
rPgulation,
industry
the central
of control
is studied
The alternatives
as a Federal
to the affected
and naintaining
gies and degrees of efficiency

iach
are proposed
such
of which
commences
in the Federal Register.

2-1
achievable
emission
stationary
sources
which (taking
reduction,
and any
impact and energy requirements)
has been adequately

apply only
for
demonstrated
to stationary
after
for
sources,
regulations
are
that
the
category
the construcproposed
by
The 1977amendments to the Act altered

that
appTy to the process
of establishing
or added numerous provisions

standards
of performance.
i. EPA is required to list the categories of major stationary

sources
that have not already been listed and regulated under standards of performance. Regulations must be promulgated for these new categories on the
following
schedule:
a.
b.
c.
24 percent of the listed categories by August 7, 1980.

A governor of a State may. apply to the Administrator

not on the list
performance
2.
to add a category
to have 3 standard
of
EPAis required to review the standards of performance every
3.
and,
if appropriate,
revise
them.
E,JAis authorized to promulgate a standard based on design,
equipment,
work practice,
emission
4.
to the Administrator
revised.
four years
on
or may apply
levels
is
or operational
not
The ten~ "standards
"technological
new definitions
of performance"is
system of continuaus
clarify
procedures
when a standard
jased
feasible.
emission
redefined,
reduction"
and a new ta~m

is defined.
The
that the control system must be continuous and may
include a low- or non-polluting

process or operation.
5. The time between the proposal and promulgation of a standard
Section
111' of the Act may be extended
under
to six months.
Standards of performance, by themselves, do not guarantee protection

of health
or welfare
air quality levels,

emission limitation
because they are not designed to achieve any specific
Rather, they are designed to reflect the degree of

achievable through application of the best adequately
demonstrated technological system of continuous emission reduction, taking

into consideration the cost of achieving such emission reduction, any
nonair quality
health
and environmental
impacts, and energy requirements.
Congress had several reasons for including these requirementr.

standards
with
a degree
some States may attract
States.
growth.
of uniformity
industries
are needed to avoid situations
by relaxing
standards
relative
i i rst,
whete.
to other
Second, stringe'nt standards enhance the potential for long-term

Third, stringent standards may help achieve long-term cost savings
2-2
by avoiding the need for more retrofitting
when pollution ceilings may
be reduced
types
in the future.
Fourth,
certain
of standards
for coal-
burning sources can adverse~y affect the coal market by driving up the
price of low-su~fur coal or effectively excluding certain coals frm the
reserve
base because
their
untreated
pollution
potentials
are high.
Con-
gress does not intend that new source performance standards contribute to
these problems. Fifth, the standard~setting process should create
incentives
f6r
improved
technology.
promulgation of standards of performance does not prevent State or

local agencies from adopting more stringent emission limitations for the
same sources.
States
are free under Section 116 of the Get to. establish
even more stringent emission'limits than those established under Section 111
or those necessary to attain or maintain the Mational ~mbient Air 3uality
Standards'(NAAQS) under Section
be subject to limitations
under Section
110.. Thus, new sources may in some cases
more stringent
111, and prospective
than standards of performance
owners and operators
of new sources
should be aware of this possibility

in planning for such facilities,
A similar situation
may arise when a major emitting facility
is to be
constructed in a geographic area that falls under theprevention
of signif-
icant deterioration
of air qual.lty~ provisions
provisions require,
amongother things, that major emitting facilities
be constructed
in such areas
technology.
in
the
Act,
are to be subject
to best
available
These
means
an emission
limitation
based on the maximum degree
of each po\~utant
from,
subject
or which results
to regulation
irom,
any major
of
under this ~ct
emitting
facilitl/,
which the permitting authority,

an a case-by-case basis, taking
into account energy, environmental, and economic impacts and
other
to
control
The termBest Available ~ontrol Technology (BACT),as defined
reduction
emitted
of Part C of the Act.
costs,
deten~ines
is achievable
for such facility
through
application of production processes and available ~nethods, systems,

and techniques, including fuel cleaning or treatment or innovative
fuel c~mbustion techniques for control of each such pollutant.
In no event
shall
ogy" result
in emissi'ons of any pollutants which will exceed the
application
of "best
emissions
allowed-by
any applicable
to Sections
111 or 112 of this Act.
2-3
available
standard
(Section
controltechno~-
established
164(3))
pursuant
Although standards of performance are normally structured in ten~s of

numerical emission limits where feasible,
alternative
approaches are sometimes necessary.
In some cases physical neasurement of emissions from a
new source Ray be impractical or exorbitantly
expensive.
Section Ill(h)
provides that the Administrator may promulgate a design or equipment standard in those cases where it is not feasible to prescribe or enforce a
standard of perfonnance.
For example, emissions of hydrocarbons from
storage vessels for petroleum liquids are greatest during tank filling.
The nature of the emissions, high concentrations for short periods during
filling and low concentrations for longer periods during storage, and the
configuration of storage tanks make direct c?missio~measurement impractical.
Therefore, a more practical approach-to standards of performancefor storage

vssels
has been equipment
specification.
In addition, Section Ill(j)

waivers
of compliance
emission control
tor must find:
to penit
technology.
authorizestne Adninistrator to granr:

a source
to use innovative
continuous
In order to grant the waiver, the Administra-
(1) a substantial likelihood that the technology~Jill
produce greater emission reductions than the standards require or an equivalent reduction at lower economic energy or environmental cost; (2) the
proposed systernhas not been adequately demonstrated; (3) the technology

will not cause or contribute to an unreasonable risk to the public health,
welfare,
or safety;
(4) the governor
of the State
where the source
is
located consents; and (5) the waiver will not prevent the attainment or
maintenance of any ambient standard. A waiver may have conditions attached
to assure the source will not prevent attainment
of any NAAQS. Any such
condition wilt have the farce of a performance standard.

have definite
end dates and may be terminated
not met or if the system fails
earlier
to perfo~m as expected.
Finally, waivers
if the conditions
are
In such a case,
the
source maybe given up to three years to meet the standards with a mandatory
progress
2.2
schedule.
SELECTIONOF CATEGORIESOF STATIONARYSOURCES
Section 111 of the Act directs the Adninstrator to list categories

of stationary sources. The Administrator "... shall include a category
of sources in such ~ist if in his judgment it causes,
2-4
or contributes
significantly
endanger
to,
public
air
health
of perfon~nance
are
has been given
to the development
by considering
categories.
the
Clean Air Act.
broad
Often,
sou~c~s.
evaluated
level
or ~~e~fare."
(2) estimated
The approach
strategy
these
of the
"areas"
Source
(if
replacement
of existing
on
amount
future
Sources
these
year
for
or under
that
as:
could
be prevented
performance
standards
1977,
of
and (4) the
for
during
regulations,
of groYth and
of performance
new source
are
from standards
category,
that
by
(1) the
by State
be required
pollution
emitted
pollutants
such factors
required
the
or earlier,
the
in
source
were
were selected
criteria.
in
listed
air
development
these
the source
by standards
which
The Act amendments

used
of
implementing,
(3) projections
for
of interest
pollutants
emit
might
facilities
estimatedìncrementa1
that
that
for the source category,
promulgated
of standards
priorities
areas
Agency for
already
perfon;lance
category.
to
attention
assigning
specifies
involving
any)
of control
for
are actually
categories
control
levels
a preselected
and promulgation
of a system
and ranked by a process
of emission
Proposal
be anticipated
of the Clean Air Act of 1970, considerable
source
stationary
which may reasonably
to follow.
Since passage
to various
pollution
determining~
of August
priorities
for
by EPA. These are:

each such category
extent
all
major
emit,
or will
pollutant
specific
source
(1) the quantity
will
to which each such
1977 establish
criteria
categories
not
of air pollutant
be designed
may reasonably
to be
yet
emissions
to emit;
(2) the
be anticipated
to
endangerpublic health or welfare; and (3) the mobility and competitive

nature
of each such category
nationally
applicable
new source
The Administrator
according
to the
for
a source
program
techniques
for
the developing
the
necessary
considered.
standards
referred
with
sampling
investigation
For example,
priority.
to develop
and measuring
of standards,
these
different
substantially
2-5
immediately
categories
to develop
This might
control
emissions
differences
for
for
to earlier.
a high
is needed
need for
of performance.
standards
it may not be feasible
categgry
of research
and the consequent
Is to promulgate
schedule
I? some cases
of sources
in the
source
happen
techniquesor
may require
time
required
categories
a standard
when a
because
refinement.
In
to complete
must also
more time may be necessary
if
be
numerous pollutants
Further,
~ust be investigated
even late
of a standard
in the
may change.
from well-controlled
systematic
is,
projects
are
After
to be,
category
source category.
schedule
inability
for
to obtain
completion
emission
the development
in scheduling.
used
and resources
source
the
to pursue
a change
continue
initiated
the
in time
may force
and will
process
For example,
sources
fashion
ranking
development
from a single
data
process
Nevertheless,
to establish
the
in a
priority
order
in which
assigned.
has been chosen,
the types
of facilities
within the source category to which the standard will apply mus't ~e dettermined.
A source
pollution,
category
and emissions
insignificant
to
category
very
is better
sources.
expensive
served
For this
for
.do not apply
emissions
to all
facilities
all
pollutants
by the
2.3
may be selected
standards
or facilities
within
facilities,
the
sir
pollution
demonstrated
standards
often
the
Thus, although
by a standard
source
pollution
For the same reasons,
emitted.
that
from
of
is no adequately
a source.
to be covered
air
to the more severe
there
air pollutants
studies
may show that
from certain
at
cause
may vary
iconomic
technology
and because
that
facilities
control.
by applying
dards may not apply to all

category
to
control
reason,
controlling
facilities
from some of these
and of applicable
control
system
may have several
a source
of performance,
source category
stan-
not
may be covered
standards.
PROCEDURE FOR DEVEtOPMENT OF STANDARDS OF PERFORMANCE
Standards of perfon~ance
demonstrated control practice;
must (1) realistically

reflect
best
(2) adequately consider thecost,
the nonair
quality health and environmental impacts, and the energy requirements

such control;
(3') be applicable
to existing sources that are modified
reconstructed
as well
for all variations
as new installations;
of operating
and (4) meet these
conditions
being considered
of
or
conditions
anywhere in the
country.
best
The objective
of a programfor
technological
system
adequately
demons trated
developing
of continuous
emission
The standard-setting
standards
is to identify
reduction
process
that
involves
has been
three
principal phases of activity:

(1) infarmati3n gathering,
(2) analysis
tile information,
and (3) development of the standard of performance.
2-6
the
of
Ouring the information-gatheri
ng phase, industries
through a telephone survey, letters

representatives.
rnformation
and a literature
search
is
are queried
of inquiry, and plant visits
is also
gathered
conducted.
from ~nany of her
From the
knowledge
by EPA
sources,
acquired
about
the industry, EPA selects certain plants at which emission tests are con~
ducted to provide reliable data that characterize
She pollutant emissions
frrMI well-controlled
existing
facilities.
In the second phase of a project,
the information
about the industry
and the po'l~utants emitted is used in analytical studies.

Hypothetical
"model plants" are defined to provide a commonbasis for analysis.
The
model plant definitions,
national pollutant emission data, and existing
State regulations governing emissions from the source category are then
used
in establishing
alternatives
"regulatory
are essentially
EPA conducts
alternative
studies
on the
different
of the
These regulatory
levels
to dete~mine
economics
on the environment,
alternatives."
the
industry
of emission
control.
impact of each regulatory

and on the
and on energy consumption.
national
From several
economy,
possibly
applicable alternatives,
EPAselects the single most plausible regulatory
alternative
for a standard
category
as the basis
under
translated
for the source
study.
In the third
is
of performance
phase
into
of a project,
a standard
the selected
of perfonnance,
regulatory
which,
in
alternative
turn,
~5 written
in
the form of a Federal regulation.

The Federal regulation,
when applied to
newly constructed plants, will limit emissions to the levels indicated in
the selected
regulatory
alternative.
As early as is practical
in each standard-setting
project, EPA
representatives
discuss the possibilities
of a standard and the form it
might take with members of the National Air Pollution Control Techniques
Advisory Committee. Industry representatives
and other interested parties
also
participate
in these
The info~mation
Information
Oocument (BID).
ing the standard

control,
~ithin
in the project
groups,
Through this
is summarized
The SID, the standard,
are widely circulated
environmental
EPA.
meetings.
acquired
other
extensive
2-7
and a preamble
to the industry
government
review
agencies,
process,
in the Background
explain-
being considered
for
and offices
the points
of view of
expert
reviewers
are taken into consideration
as changes are made to the
documentation.
A "proposal package" is assembled and sent through the offices of EPA

Assistant Administrators for concurrence ~efore the proposed standard is
officially
endorsed by the EPA Administrator.
After being approved by the
EPAAdministrator,the preambleandthe proposedregulationare pubiished

in the Federal Register.
As a~part of the iederal Register announcement of the proposed
regulation, the public'is invited to participate in the standard-setting

process.
EPA invites
written
comments on the proposal
and also holds a
public hearing to discuss the proposed standard with interested

parties.
All public comments are summarized and incorporated into a second volume
of the 8ID. All infonation
reviewed and generated in studies in support
of the standard of performance is available to the public in a "docket" on
file
in ~ashington,
D. C.
Comments from the public

may be altered
in response
are evaluated,
and the standard
of performance
to the comments.
The significant
comments and EPA's position on the issues raised are
included in the ''preamble" of a "promulgation package," which also contains
the draft of the final regulation.
The regulation is then subjected to
another round of review and refinement
until
it is approved by the EPA
Administrator. After the Administrator signs the regulation, it is published

as a "final rule" in the Federal Register.
2. 4
CONSIDERATTON OF COSTS
Section 317 of the Act requires

respect
to
any standard
of the Act.
an economic impact assessment:~ith
of perfoimance
The assessment
established
is required
to contain
(1.) the costs of compliance with the regulation,

which the costaf
the regulation
compliance varies
and the development
under
Section
an analysis
of:
including the extent to
depending on the effective

of less
111
expensive
date of
or more efficient
methods of compliance; (2) the potential inflationary or recessionary

effects of the reguiarion; (3) the effects the regulation might have on
snell business with respect to competition; (3) the effects of the regulation
on consumer costs; and (5) the effects of the regulation on energy use.
Section 317 alsq requires
extensive
that the economic impact assessment Se as
as practicable.
2-8
The economic impact of a proposed standard

ad'dressed
both
in
absolute
would be incurred
as a result
control regulations.
and existing
the
plants
absence
detailed
analysis
and
in
tenns
of compliance
of
the
witli
control
typical,
is usually
costs
that
existing
State
An incremental approach is necessar,v because both new

would be required
of a Federal
would exist
State
tenns
upon an industry
standard
to comply with State
of performance.
This
regulations
approach
requires
of the economic impact from the cost diiferential
between
a proposed
standard
of performance
and the
in
a
that
typical
standard.
Ail; pollutant
potential
air
emissions
pollutants
may cause water pollution
may pose a solid
problems,
waste disposal
and captured
problem.
The
total environmentaP impact of an emission source must, therefore, be analyzed

and the costs
detemined
A thorough
the industry
potential
is also
whenever
possible.
study of the profitability
is essential
adverse
to the analysis
economic impactscan
essential
and price-setting
to know the
capital
so that
mechanisns
an accurate
estillate
of
of
be made for proposed standards.

requirements
for
pollution
It
cpntrol
systems already placed on plants so that the additional

capital requirements
necessitated
by these Federal standards can be placed in proper perspective.
Finally,
the
2~5
it
is necessary
additional
equipment
the availability
needed
of capital
to meet the
standards
to provide
of performance.
CONSIDERATION OF ENV.IRONMENTALIMPACTS
Section
--1
control
to assess
102(2)(C)
1369 requires
statements
Federal
agencies
on proposals
significantly
consideration
industries,
of Columbia
into
the
not be prepared
the
Clean
the
best
challenges
held
Essentially,
of emission
aspects
Court
reduction
actions
The objective
agencies
of proposed
actions.
of performance
for
impact
for
the Oistrict
statements
under Section
of Appeals
requires
impact
of Federal
of Appeals
environmental
the Court
2-9
environmental
process
to standards
States
that
Act (N',PA) of
of the human environment.
environmental
United
Policy
and other major Federal
by the Agency for proposed actions
Air Act.
system
detailed
decisionmaking
of all
the
Circuithas
to prepare
the quality
In a number of legal
various
Environmental
for legislation
affecting
of NEPA is to build
careful
of the National
need
111 of
has determined
the Administrator
that
to take
into account counter-productive

environmental effects
standard, as well as econoinic costs to the industry.
therefore,
the Court established
determination
under
In addition
Section
of a proposed
On this basis,
a narrow exemption from NEPAfor EPA
111.
to these judicial
determinations,
the Energy Supply and
Environmental Coordination Act (ESECA)of 1974 (PL-93-319) specifically

exempted proposed actions under the Clean Air Act from NEPArequirements,
according
to Section
7(c)(l),
"~o action
taken under the Clean Air Act
shall be deemeda major Federal action significantly
affecting the quality
of the human environment within the meaning of the National

policy Act of 1969." (15 U.S.C. 793(c)(1))
Nevertheless,
the Agency has concluded
that
Environmental
the preparation
of
environmental impact statements could have beneficial effects on certain

regulatory
actions.
Consequently, although not legally
requurred to do so
by Section 102(2)(C) of NEPA,EPAhas adopted a policy requiring that

environmental impact statements be prepared for various regulatory
including
standards
of performance
Tnis voluntary preparation
developed
under Section
actions,
111 of the Act.
of environmental impact statements,
however,
in no way legally subjects the Agency to NEPArequirements,

To implement this policy, a separate section in this document is
devoted solely to an analysis
of the potential
ated with the proposed standards.
aoth adverse and beneficial impacts in
such areas as air and water pollution,

increased
2.6
energy
consumption
environmental impacts associ-
increased solid waste disposal.
and
are discussed.
IMPACT ON EXISTING SOURCES
Section 111 of the Act defines a new source as "... any stationary
source,
the construction
or modification
of which is commenced ..."
after
the proposed standards are published. An existing source is redefined as a

new source if "modified" or "reconstructed" as defined in amendments to the
general provisions of Subpart A of 40 CFRPart 50, whic~ were promulgated

in the Federal Register on December 15, 1975 (40 FR 58416).
Promulgation of a standard of performance I-equiras States to establish
standards of performance for existing sources in the same industry under

Section Ill(d) of the Act if the standard for new sources limits emissions
of a designated pollutant (i.e., a pollutant for which air quality criteria
2-10
have
not
been
issued
hazardous pollutant
establish
control
under
Section
under Section 112).
such standards.
of existing
108 or which
General
has
not
been
listed
If a State does not act,
provisions
outlining
procedures
as
EPA must
for
sources under Section 111(6) were promulgated an
November17, 1975, as Subpart B of 40 CFRPart 6~ (40 FR 53340).

2.7
REVIS~ON 3F STANDARDS OF PERFORMANCE
Congress was aware that the level of air pollution control achievable
by any industry may improve with technological advances. 4ccordingly,
Section
least
111 of the Act provides
every 4 years,
Revisions
that
review and, if appropriate,
are made to assure
that
best systems that become available

be retroactive,
after
but will
the proposal
the Administrator
apply
the standards
of the revised
211
revise
continue
in the future.
to stationary
"...
sources
..."
shall,
at
the standards.
to reflect
the
Such revisions
will not
constructed
or modified
standards.
3.0
3.1
THE CATALYTIC
CRACKING
UNIT
AND POLLUTANT
EMISSIONS
is a petroleum
refinery
PROCESS
GENERAL
3. 1. 1
Introducti
on
Catalytic
cracking
hydrocarbon
molecules
broken
smaller
into
fracturing
in the
presence
molecules.
of a catalyst
The catalyst
of heavy distillates
process
allows
thigh molecular
in which
are
fractured
the
selective
or
weight hydrocarbons)
to light products (low molecular weight hydro~carbons). At many 2etroleum

refineries,
'\
catalytic
feedstocks
into
cracking
gasoline
is
used to convert
and middle
distillate
gas oils
blending
or residual
stocks.
Catalytic crackingis
also used to produce light olefins
and butylenes) for gasoline alkylation
and petrochemical
(e.g.,
propylenes
production,
and to produce
in heating
oils
and
cycle
fuel
this
or qualities
of desired
of catalytic
cracking
and other
yield
of heavy
yield
and quality
process,
use as blending
components
hydrocarbon cracking was accomplished by a thermal
However,
stocks
for
oils.
Originally,
process.
oils
process
products
not produce
from the
allowed greater
light
products
residuals
cracking
sufficient
heavy
yields
oils.
associated
has almost
feeds.
while
As a result
with
the
completely
quantities
~ne development
of gasoline
to be obtained
or fuel
of products
catalytic
did
blending
reducing
of the
improved
catalytic
replaced
the
cracking
thermal
cracking.
Fluidized
catalytic
cracking
(FCC) involves
the mixingof
feedstock with a stream of fine, suspended, catalyst

a "fluidited
bed").
Upon completion of the cracking
cracked
hydrocarbon
vapors
are
cracked
hydrocarbon
vapors
pass
separated
3-1
particles
reactions,
from the catalyst.
to a fractionating
the
(termed
the
The
column where
the
vapors are distilled
into the desired products.
The spent catalyst,
deactivated during the craclting process, is transferred to a regenerator.

There, a carbon residue called coke, which jeposits on the catalyst
particles
during the cracking reaction,
is burned off.
The reactivated
catalyst is then recycled back to the catalytic cracking process,

Sulfur oxides emissions result during catalyst regeneration from
oxidation
of sulfur
compounds bound in the coke.
Twoother types of catalytic cracking are also einployedby the

petroleum refining industry to produce gasoline blending stocks and
other products. These are referred to as Thermoforcatalytic cracking

and Houdriflowcatalytic cracking. In contrast to fluidized catalytic
cracking, these processes use movingcatalyst beds. As of January
1980 the Houdriflow process was used by 2 refineries
and the Thermofor
process
wasusedby15refineries.lSincetheseprocesses
arebeing
gradually phased out of usage, the remainder of this document i~i~l
deal only with fluid catalytic cracking.
3.1.2 DomesticGrowthTrendsin Fluid Catalytic Cracking

As of January 1980, FCCunits were in operation at 126 petroleum
refineries locatedin the UnitedStates (see Figure3-1).1 fhe FCC

units have a combinedthroughput capacity of about 0.8 x 106 cubic
metersof fresh feedper stream-day

(~.8Mm3/sd).
Although
individual
FCCllnit throughputcapacities range from380to 21,460m3/5d,lover
60 percent of the total FCCunit throughput capacity is attributable
to units larger than 7,100 in3/sd. The FCCunits located in California,
Louisiana,
and Texasaccount far about 54 percent of ihe total throughput
1-10
ca~paci
ty ,
units
is
A state-by-state listing of refineries operating FCC
presented
Nationwide
in 1971to 0.8
in Section
FCC processing
9,1,
capacity
has
increased
from ~.6
!~m3/5d
Mm3/sd
in 1980 in
response to increasing gasoline

demand.
Although total gasoline demandis expected to decline
over the next 10 years,ll total processing capacity growth is expected
1-10,11
to continuebecausethe FCC
unit has the flexibility to processresidual feeds, high sulfur gqs oils, and synthetic (coal-d2rived) feeds.
Also, the FCCunit is an importantcontributor to the high octane

unleadedgasoline pool and distillate productinventor,v.l2~1?,14
3-2
,~
'~''
t~I--i
uo~r~lo~~oli~o
~I~""
''z
O.i o5u.~lol*
.~ 1;I
*Irrulla~
,.,,
j" ` 1:3
I
'\I
IIEL'I
uru,~oll~o
~i
1_
('U
IM~ryland:
2,
,~
D
-L~,
\crna'
I\laska:
Ilnria II:
Figure 3-1.
Statewide Distribution
with Fluid Catalytic

As of
Januar~
Connecticut:
i~il7iilsyr
4-NeH
Jersey:
2
/l.c:4j
~'" / ~~~t~ ODelaHare:
1
27
~~chusetts:
~a~Rhode
Island:0
i~l'
'~ 9
'Y~nl.
-\
\C.V~_
i~o
:3
of Refineries
Cracking Units
191301
Annual throughput
capacity
growth similar
to that
experienced
between 1971 and 19130is expected to yield a total FCCprofessing

capacity
of 0.93 r~m'/sd id 1987.
unit construction
discussion
3.2
and additions
of industry
This growth will
to existing
came from both new
capacity.
growth is presented
A more detailed
in rlppendix E.
FLUID CATALYTICCRACKINGPROCESSES A~IDU4ISSI~ONS
Up to 50 percent of the total
crude oil input to a refinery may
be ultimatelyprocessed.in
the FCC
unit.l5 Figure3-2shows
a generalize~
flow diagram illustrating
the relationship
and other processes at a petroleum refinery.
between the FCC unit
FCCfeedstacks are
derived fromthe distillation
of crude oil and from other~refinery
process units.
tillation
units
from the atmospheric and vacuum discharged to the r'CC unit.

Other sources
Heavy gas oil

are typically
of gas oil are thermal cracking, lube oil extraction and dewaxing,
coking,
and deasphalting
processes.
Residual
feedstocks,
such as
vacuum
and atmosphericdistillation towerbottoms,are becoming
a more
important
FCC unit
feedstock
source.
usually blended with recycle all,
The FCC unit
feedstocks
a stream of partially
are
cracked hydro-
carbonsfromthe FCCfractionator, before beingchargedto the FCt.16

3.2.1 Fluid Catalytic Cracking Unit Process Equipment
An FCCunit consists of three basic sections: reactor, regenerator,
and fractionator.
Figure 3-3 presents a diagram of a generalized
FCC
unit. Variations in the design of FCCunits exist throughout the

petroleum refining industry, but basic product yields and operating
characteristics
3.2.1.1
are
similar.
Reactor.
take place in the reactor
Cracking reactions
section
and catalyst/product
of the FCC unit.
The reactor
separation
section
in a modern FCCunit usually consists of a riser reactor and a separator

vessel which contains a catalyst disengager and a steam stripper.
Preheated
feedstockr
are blended with recycle
and injected into a fluidized

bottom of the riser reactor.
approximately
oil from the fractionator
stream of regenerated catalyst near the

The catalyst temperature ranges from
590 to 6800C, and the catalyst
to feedstock
mass ratio
rangesfrom4 to 10.17ihe crackingreactionsbeginas the hot,

regenerated catal~st
contacts and vaporizes the feed.

3-4
As the vaporized
~111
lull
uwuc
ulrul
tur~
Irr
I~lu
rum
LL~RL
nlPorru
tuol
~II~I
uu
Iruule
rurlouls,
III mt
IIDPrll
rl
U'OI
C--,
I
I
L~1
,~
rlrroto
nvn
---rlluw
;~YIUIP
YLrIOD
or
IIOYY
11IIUI1
ILIIWL
OLYL
--~to
*ullll
cn
]P
I-
(~I
rtIr
~rl~ls~ol
YII
I~u
WOL
II
~-L~
n~wl
-I
IUL
vuuw
run.
B
~lr
tuslcr
wmn
w~ul
lur
or
Ilau
Iwl
urull
*u
*Dlu
w
I
Ylnrr
lururu~
11101L~
aul
lu~ul
PL~IDOI UIU~
LCr
uar~
rgur
~v~l
unur
Ivul~~U
~~u
mtlrt
OCODldlYU
Figure
3-2.
Basic
Flow Diagras'of
Petroleur
CatalyticCracking
Unit.l8
Refinery
1ULI
Showing Location
of
turll
Il~~w
En,lss
tolls
A tnlospfle
frac~lonator
_~ Gas
Sel,ara tor
Vessel
IleaL
Gasulllle
II
iJ/
-'
L Recycle
I~cac tor
Strlpplllg
Stcanl
w~~
Cycle
011
Feed
Oottonls
CO furnace
Riser
Llgl,t
CyclD,les
Particulnte
Colltrol
Device
!r
t Catalyst
I II
01
Ille~lenel-alur
Rcgel~erated
atak5.~-'
necycle Feed ----,(
fresh
Gas/Oil
reed
I ColllhustiollAir
t)luuer
Figure
3.3. Schrmatic
of a FluidCatalytic
Craclting
UnltlP
Recovery
re
hydrocarbons and catalyst

reactor
tnthe
particles
separator
vessel,
now upJard through the riser
the hydrocarbons
are cracked
into
lighter product molecules.

The cracking reaction is endothermic, so
the reacting mixture cools as it rises to the separator vessel.
During the cracking process in the riser, the catalyst rapidly loses
its
activity.
This occurs
as high molecular
sulfur compounds, originally

adsorbed
vation
on catalyst
and
present in the feed, are. preferentially
surfaces
of the catalytic,
weight aromatic
where they react
cracking
catalyst
also
to form coke."
occurs
Deacti-
through
the
absorptionof nitrogenandmetalcompounds.l5
:
The separator vessel is designed to separate or disengage the

catalyst particles from the cracked hydrocarbon vapors rapidly to
21,22
minimire secondary reactions.
Clultiple-stage cyclones installed
inside
the separator
vessel
remove most of the catalyst
fines
from the
cracked hydrocarbon vapors (products).

The products and the remaining
entrained catalyst fines exit overhead to the fractionator.
The
coke-laden
catalyst
particles
fall
through
a steam stripper
in the
separator vessel where additional entrained light hydrocarbons are

displaced from the void spaces around the catalyst particle using
15,23
steam as the displacing

agent.
Both steam and hydrocarbons are
then routed overhead with the products to the fractionator.
~Stripped
catalyst
is transferred
activity
and to generate
3.2.1.2
active
to the regenerator
Regenerator.
cracking
deposition
heat
sites
coke deposits
The combustion
products
for the cracking
reaction.
cracking
24,25
Coke,.which deposits on the catalyst,
on the catalyst
reduces catalyst
activity,
to renew catalyst
surface.
c.racking activity.
Consequently,
gases)
coke
to renew catalyst
are burned off the catalyst

(flue
blocks
are primarily
in the regenerator.
carbon monoxide
(CO),carbondioxide(C02),andwatervapor. Sulfuroxides(50,) and

nitrogen oxides (NOx)are also formeddue to oxidatian of sulfur and
nitrogen
compounds bound in the coke.
U~on entering
the reactor
the regenerator,
are suspended
elevated temperatures.
amount of air
into
the spent catalyst
in a nuidired
bed that
particles
is maintained
An air compressor (blower) injects
the regenerator
vessel
3-7
to nuidize
from
at
a regulated
the catalyst
particles and to sustain combustion of the coke. Combustiongases

resulting from catalyst regeneration pass through multiple-stage
cyclones before leaving the regenerator. These cyclones, located
within the regenerator, recover catalyst particles which become
entrained in the regenerator flue gas during regeneration.
These
cyclones are generally considered process equipment.
The flue gases are vented from the multiple-stage cyclones and
the regenerator through a pressure control valve. Normally, the flue
gases are passed through air pollution
some cases,
power recovery
equipment
control,
before
heatrecovery,
discharge
and in
to the atmosphere.
To comply with Federal, State, or local air pollution regulations,

many existing FCCunit regenerators are equipped with electrostatic
precipitators
(ESP) for final-removal of catalyst fines from the flue
gases. A carbon monoxide combustion furnace or boiler is often used
to control
carbon monoxide emissions
and to recover
waste heat.
In
some installations,
FCCregenerator flue gases pass through turbines
to recover some energy from the flue gas. The recovered energy may be
used to generate electricity.
NewFCCunit regenerators are required
to meet new source performance standards
(NSPS) for particulates
(l.D kg/1,000 kg coke burn-off) and carbon monoxide!5GOvppm). These

standards were promulgated March 8, 1974' (40 CFR60.102, 40 CFR60.103).
Catalyst coke is oxidized in conventional regeneration using an

amount of combustion air that is insufficient
to occur.
for complet-e combustion
This results in coke on regenerated catalyst
ranging from0.1 to 0.6 weight percent15'Z5and

large quantities
of carbon monoxide.
in the
(CRC)levels
generation
of
Carbon monoxide flue aas concen-
trations from these units can be about 10 volumepercent, representing
a carbondioxide/carbon
monoxide
ratio of about1.0.26'27Theselarge
quantities of carbon nonoxide are generated in the lower portion of
the regenerator fiuidized bed (dense bed) and pass through the upper
portion of the nuidized bed (dilute-phase) and internal cyclones.
The flue gases are then vented to pollution control equipment and to
the atmosphere.
Temperatures in the regenerator
are about 590"0 to
680"0, ~f excess oxygen is available within the regenerator, the

carbon monoxideundergoes exothermic combustion in the dilute phase or
internal cyclones, causing large temperature excursions and possible
3-8
damage to the catalyst,

monoxide
to
combustion
combust
carbon
cyclones,
furnaces
nonoxide
and auxiliary
are
in
often
equipnent.
used with
a controlled
Carbon
conventional
manner
outside
regenerators
the
regenerator
vessel.
The latest
regeneration
techniques
can reduce CRCto about
0.02 percent and flue gas COcontent to about 0.05 percent (S00 vppm).
The two methods used to achieve this improvementinclude high temperature regeneration
combustion;
(HTR) and catalytically
In HTR, combustion.takes
dense bed.
As the name implies.
promoted carbon monoxi~e
place
within
the regenerator
the
regenerator
dense bed and dilute
phase temperatures are higher than in conventional
regenerators.
The
energy released in the combustionof COto CO:!causes this temperature

i ncrease.
The dense
bed temperature
is near
7O0"C, and the
dilute
phase emperature is 730"C to 745"C, although both can be as high as

760"C during
more complete
catalyst
heat recovery
within
In catalytically
and
confine
bed.
the
This
temperature
15,27
HTRoperation.
The advantages
regeneration.
lower catalyst
the regenerator
carbon
results
of
carbon
in efficient
excursions
heat
to
transfer
and minimizes
at least
6700C to 700"0,
regenerator
dilute
units
efficiencies
Tne regenerator
and the
the
promote
dense
high
equipment damage due todilute
high regeneration
combustion..
are
better
catalysts
monoxide
and subsequent
to achieve
monoxide
inventory,
promoted carbon monoxide combustion,

combustion
technique
and low carbon monoxide emissions.
phaseafterburnin9.28I~talso permiitsexisting
constraints
of this
dense
phase
with
metallurgical
through
partial
bed temperature
temperature
is
is
580"C to
28,29 Promotersalso yield lowCRCratios and give benefits

similar to those derived fromHTR.30
720"C.
The activity
of all
catalysts,
especially
teolite
catalysts,
is
affectedbythe CRC.25
Sincelargeresidualcokedepositsinhibit
catalyst
activity,
promoters results
the low CRC obtained with HTRor carbon monoxide

in improved product yields,
reduced coke formation,
and improved unit
profitability.
combustion
occurs within
manoxide emissions
combustion
promoters,
30,31
the regenerator
Since complete carbon monoxide

and the NSPS for carbon
can be met through the use of HTRor carbon nonoxide

carbon
monoxide
required.
3-9
combustion
furnaces
are
not
3.2.1.3
fines passing
Fractionator,
Product vapors, steam, and some catalyst
through the separator vessel cyclones are vented from
the FCCuni t to the fractionator.

are separated
cycle
oils.
into
gases,
These
catalytic
products
are
refinery for further processing.

entering the fractionator settle
a sludge.
The catalyst
Within the fractionator,

gasoline,
sent
and light
to various
areas
the vapors
and heavy
within
the
Most of the entrained catalyst fines

to the bottom of the fractionator as
sludge in some refineries
is removed and mixed'
with the liquid recycle for reinjection into the riser reactor.l6
Fresh catalyst
is added periodically
to the FCC unit to make up for
catalyst
losses to the atmosphere and products.
3.2.2 'FactorsAffectins Sulfur OxidesEmissionsfromFCCRegenerators

The coke which deposits on the FCCcatalyst
during normal operations
primarily contains carbon, hydrogen, nitrogen, and sulfur.

oxides
emissions
result
when the
sulfur
that
is contained
is oxidized in the regenerator during coke burn-off.

parameters
which directly
or indirectly
affect
the
Sulfur
in the
cake
Thus, the operating

sulfur
content
of
the coke and the amount of coke burned off in a given period of time
ultimately affect sulfur oxides emissions. The quantity of sulfur
oxides emissions from the FCCunit regenerator can vary considerably
with feedstock quality, regeneration mode, catalyst type, and operating
conditions.
3.2.2.1
Feedstock I)uality.
is the most important
factor
the FCCunit regenerator.

influences
coke sulfur
The sulfur content of the FCCfeed
affecting
sulfur
oxides emissions
from
The amountof sulfur in an FCCfeed directly
and thus,
regenerator
sulfur
oxides
emissions.
A high sulfur feed may thus be generally expected to yield higher

sulfur
be
oxides emissions
found
in
the
than a low sulfur
feed since more sulfurwill
in a feedstock
which ends up as coke sulfur
coke.
The amount of sulfur
depends on the source of the feedstock. The correlation presented in

F'~ure 3-4 is derived from pilot plant data and shows a relationship
be;,~een feed sulfur
crude
oils.
yield
different.'ievels
and coke sulfur
At equivalent
levels
content
of feed
of coke sulfur,
J,10
for feedstocks
su.lfur,
and thus
different
different
from various
feeds
sulf~r
can
!~g~no
w ill. 1I1 "i
5.0
4.0C
(u.on ~lonr
3 ry~alc~J..:~o,~~n~
lo. Ll. PPCJ$
3.0
jorllnc~
20
~~c~
(n~lf. C.C.
wlnle
~rl lar lo~cmn.
:r~t~lnP
~u~i
ic Jn]0r.!,
\L:
as
o-s
~-~
c,
1,0
G-
u-
ol-
ii
3
v,
0.5
;r
0.4
0.3
0.2
0.1
0.1
0.2 0.3 0.4 0.5
Feed
Figure 3-4.
Sulfur
Sulfur,
1.0
wt.
Relationsh~p
2.0
3.0
Setween Feed
and Coke Sulfur33
oxidesemissians.32
Asshown
in Figure
3-4,at 1.0percentfeed
sulfur, California gas oil producesa coke containingapproximately
0.55 weight percent sulfur; WestTexasgas oils produceapproxinately
1.5 weight percent coke sulfur; and feeds derived from Kuwait stocks
produce 2.2 weight percent coke sulfur. Regenerator flue gas concentrations of sulfur oxides mayvary from about 400 ppmby dry volume
(vppn)to nore than 1,700 vppm~forunits processingthese gas oils.33

T;lis variation in levels of coke sulfur is related to the coke
forming tendency of the FCCfeed and to the molecular fon in which
the sulfur is boundin the hydrocarbonmolecules. Certain sulfur-bearing

hydrocarbonmolecules, called thiophenes, preferentially form coke on
the FCCcatalyst during the crackingreactions. Other sulfur-bearing

moleculestend to crack into hydrogensulfide and other light hydrocarbons.
The hydrogensulfide is vented with the products to the fractionator,
leaving l~ss sulfur to form on the catalyst.
Thus, the relative
quantity and molecular structure of the sulfur-bearing hydrocarbon
determines the amount of sulfur in'coke,32
FCCfeedstock sulfur content is approximately equal to the sulfur
content of the crude oil from which the gas oil is derived.S4
n range
of expectedsulfur contentsfor FCCfeedsmaybe derivedby identifying

the crude slates from which the feeds originate.
Given the unstable
nature of world crude oil supplies, it is difficult to identify possible

future refinery crude slates.
An analysis of historical
trends and
general crude sulfur content is required to bracket the potential

range of FCC feed sulfur
characteristics.
In 1978,"sweet"crudeoil (sulfurcontent7essthan0.5 weight

percent) processing accounted for over 53 percent of the total crude
processing
volume.35
Thetypicalsulfurcontentof crudeoil from
mid-continental United States oil fields,
such as those in Oklahoma
andLouisiana,is about0.3 weightpercent.36 Otheroil fields which

also yield crude oil with this or lower average sulfur contentj include
those in Africa, WesternEurope,and the Far East (IndonesSa).37Tt

is expected that this heavy reliance on sweet stocks will continue,
but decrease slightly from 54 to 49 percent through 1932.38
Refiners select and use crude stocks based on overall economics
and supply considerations.
The demandfor lower quality crude stocks
3-12
thigh sulfur content, low gravity) is expected to increase as supplies

of low sulfur
crude oil
become more expensive
and less
available.
As
a result, the type of crude oil processed by U.S. refineries is expected

to change. It is estimated that the average sulfur content of the
total crude processed in the U.S. will rise to 1.20 weight percent in
1985 and 1.3 weight percent in 1990. In 1976, the average crude oil
sulfur contentwas0.8 weightpercent.39 Scmerefiners expecttheir

future FCCfeeds to have a sulfur content near or above 2.0 weight
34,40,41,42 This is especially true if the highest sulfur.
percent.
feedstocks
from the Middle East (4.6 weight percent) and Mexico (5 weight
percent) are utilized.

Residue and reduced crude processing
are also expected
to become
important as refiners try to maximize useful liquid yields from each

unit volume of crude oil.
Several companies have developed an FCC-type
unit, known as a heavy oil cracker (HOC), which can handle these
residual
feeds.
43,44 Asphaltresidual treating (ART),a recently
developed FCC-like process,
improves the quality
of residual
and heavy
crude feedstocks by removing carbon residue and other impurities.

The sulfur content of most of these residual
feeds may exceed 2.0 weight
percent.
FCC feed sulfur
contents
may thus range from less
than 0.3 weight
percent to a value between 2.5 weight percent and 5.0 weight percent.
Regenerator flue gas sulfur oxides concentrations may range from less
than 200 vppm to over 2,500 vppm 'or these feeds.33
Contaminant metals arealso
present in all FCC unit
feedstocks
to
some degree. Concentrations are dependent on the crude oil source,

boiling fraction, and the degree of pretreating.
The metals deposit
on the catalyst and tend to nonselectively catalyze undesirable reactions.
These reactions
increase
result
in a decrease
in gas and coke yields,
in catalyst
thus greater
activity
and an
sulfur oxide emissions.
3.2.2.2 Regeneration Flode. Regeneration mode refers tothe

regeneration techniques commonlyused by refiners. As described in
Section
3.2.1.2,
refiners
employ conventional
regeneration,
high
temperature regeneration, and catalytically promoted carbon monoxide

combustion regeneration to renew catalyst cracking activity.
Each
regeneration technique affects howcompletely coke is burned off the
catalyst
particles.
3-13
The efficiency of coke burn-off directly affects coke yields,

conversion, gasoline yields, circulation rates, feed preheat requirements, and sulfur oxides emissions.
Regeneration efficiency is measured
by determining the ~eight percent carbon remaining on the regenerated
catalyst,
CRC. CRCaffects sulfur oxides emissions through its association with coke production,
ifficiently
regenerated catalysts,
and
catalysts with low CRCcomplete feed cracking reactions~witti less
catalyst coke production than catalysts with high CRC. This is because
coke onregenerated catalysts promotes undesirable coke forming
reactionsduringcrackin9.30
Reducing
CRC
thusreduces
cokeproduction
and
sulfur
oxides
emissions.
For a given FCC feed and feed rate,
FCCregenerators
sulfur
oxides
emissionf
from
using high temperature or carbon rnonoxide-promoted
regeneration
may thusbe
conventional
regenerators.
less
than
the
sulfur
oxides
emissions
from
3.2.2.3
Operating Conditions.
Fluid catalytic cracking units
have the flexibility
to produce a wide variety of products from a wide
variety of feedstocks.
Yields of certairi products may be optimized by
adjusting the operating conditions within the reactor and regenerator

sections.
Unit operations depend ~uponmarket demands, emission
limitations,
and processing capabilities
elsewhere in the refinery.
in optimizing FCCoperations for different product requirements,
the amount of coke producedfor each unit volume of feed (coke yield)
and the rate at which coke is produced (coke make rate) may vary. For
example, coke yield las weight percent of the feed) generally increases
as the light
product yield
from a given FCC feedstock
is maximized.
Similarly, coke make rate may be increased by increasing unit throughput at constant coke yield.
emissions
of sulfur
oxides
Both of these operational

from an FCC unit
changes increase
regenerator.
Refiners sometimes recycle a portion of heavy cycle oils to

increase yields of other products. Maximumdistillate
production is
obtained, far example, when refiners recycle heavycycle oil.

maximumgasoline yield is obtained when distillate
Conversely.
products are recycled.
Due to higher conversion of the feedstock to products, recycling may

result
in increas.ed
coke production
3-14
and therefore,
increased
sulfur
oxidesemissions.46Withcurrent zeolite catalyst technology,

distillate
recycleis rarelyused.23
3.2.3
Emissions from FCC Regenerators

Pollutant
emission
rates
can be estimated
for FCC regenerators
by
usinge~issionfactorsdescribed
in AP-42.17
Theseemission
factors
generally represent average emission levels and thus do not reflect
the complete range of emissions from individual FCCunits. The range
of FCCpollutant
emission rates may be determined by considering
the
typical ranges in feed sulfur, coke yield, and FCCcapacity, and by

evaluating the stoichiometric relationships involved in regenerating
FCC catalyst.
Catalyst regeneration is similar to solid fuel combustidn in a

boiler.
This is discussed
in more detail
in Chapter 4.
Flue gas
compositions and flow rates may be calculated by determining the coke

composition and formation rate and by calculating the amount of air
required to oxidize the coke. Coke for~nation rates vary depending on
the FCC and how iEis
operated.
Coke yield,
expressed
as a weight
percentage of the feed, varies between 4 weight percent and 6.5 weight
percentfar manyFCC
feeds.48The
feed
density
is assumed
to be
900kg/m3
Coke is composed of carbon, hydrogen, sulfur,
of nitrogen and metals.

hydrogen.
and small amounts
Coke may typically contain from 4 to 12 percent
15,23,25 The sulfur content of the coke mayrange from less
than 0.1 to 5 weight percent or more, depending on the type of feed

processed. Assuming that the nitrogen and metals content of coke is
negligible, carbon would represent the balance of coke composition.

terrain
regenerator
combustion air inlet
must also be assumed when calculating
and flue gas compositions
emissions.
Inlet
air
to the
regenerator may contain from 76.0 to 78.8 volume percent nitrogen,

20 volume percent oxygen, and from 1.2 to 4.0 volume percent water.
Thewatervaporcontentis typicalfar a GulfCoastlocation.l5

Emission
calculations
are
The air flow rates
discussed
below.
are dete~miried by calculating
the amount of
air required to burn the coke that is formed on the catalyst.

coke burn-off
the fresh
feed
rate
rate.
assumed for this

Coke sulfur
calculation
content
3-15
The
is 5 weight percent
is specified
by using
the
of
correlation
between feed sulfur and coke sulfur presented in Figure 3-5.
T~,iscorrelation34 is derived from pilot plant data sucli as presented

in Figure 3-4.
Data points showing the relationship
between feed
sulfur and coke sulfur for pilot and commercialFCCunit operations

have been plotted
representative
common
onto Figure 3-5 to show that
this
correlation
of feed sulfur-coke sulfur relationships
is
for many
FCC feedstocks.
Coke hydrogen content is assumed to be 4 weight percent and

carbon is assumed to represent the balance. Regenerator combustion
air is assumedto contain 78.8 volumepercent nitrogen, 20 volumepercent

oxygen, and 1.2 volume percent water. Flue gas compositions of carbon
monoxide and oxygen are assumed to be 0.05 and 2.0 volume percent,
respectively.
Fromthese assumptions, air flow rates entering and exiting the

FCCregenerator are determined stoichiametrically.
The results
of
this emissions analysis are plotted in Figure 3-6. A separate analysis

of emissions from HOC's and other FCCU-like processes, calculated as
described above, is presented in AppendixF. Data points showingthe

relationship between feed sulfur and sulfur oxides emissions for pilot
and commercialFCCunit operations have been plotted onto Figure 3-6
to show that the calculated model plant emissions are representative
of actual
FCC unit operations.
A sensitivity
different
analysis was perfo~med to determine the effect of
input values on calculated
FCC sulfur
oxides emissions.
Results of this analysis showthat calculated FCCemissionsare relatively

insensitive
to all
input values except coke sulfur
content
when sulfur
oxides emissions are reported in a concentrationor mass per unit of

coke burn-off format.54 Model plants are discussed in Section 6.0.
3.2.3.1
Sulfur Oxides. If the above conditions are ipplied to
FCCunits whichrangein throughputcapacityfrom800m3/sdto 211500n3/sd

and on feed sulfur contents which range from 0.1 weight percent to
3.5 weight percent, a vide range of FCCsulfur oxides emissions is
identi fi f~.
Flue gas -.ii7centrationsmayrange from less than 200 vppm
to approximately 3,000 vppm. Sulfur oxides mass emission rates may

range from approximately 7.5 kg/hr, to 4,700 kg/hr.
3-16
10
lu
o
cr
w
in
jC
w
ii
1.0
u.
-I
.
3
n:
u,
0.1
0.01
0.1
1.0
16.0
EEEDSTOCK
SULFURCONTENTIMIEIGHT
PERCENTI
~iBure
J-5. Coa~parison
Oetween
PilotPlantFeedstock
SulPur/Coke
SulfurCorrelation
and
Actual FCCUnit Data 3?
100
3.000
50
~l,ooo
d
LU
~5.,
gY 10
~.
50a
EP
rO
u,
ZO
5.0
tN
E3
100
E
w
a
50
1.0
ON 0.5
10
0.1
0.1
' 0.3
0.5
1.0
FEE~3 SULFUR
Figure 3-6.
1.5
3.5
(Wt.4/o)
Comparison between Model Plant, Pilot Plant, and Actual

FCC Unit
Sulfur
Oxides
Emissions
3-18
Data.
A portion of sulfur oxides is present as 503, as
a result
of
the
49
reaction:
502 ~ 1/2 02
-503
Fewdata exist whichadequately specify the concentrations of 503 in

the regenerator
flue gas.
Estimates
have ranged from 0.1 to 60 volume
percent of the total sulfur oxides. Typic.al503 levels maybe less

than
25,49
10 volume percent.
Recent, articles
suggest
that
at high
flue gas_excessoxygencontents, S03emissions maybe as sionificant

as
SO
2'JV In viewof the limited informationavailable on S03emis-
sions from FCC regenerators,
the calculated
sulfur
oxides emissions
from the FCCregenerators are reported as 502 emissions.

3.2.3.2
Particulate
flue gas essentially
Matter
consists
Emissions.
Particu.late
of catalyst
contained in the charging stock.
fines
matter
in
the
and some of the impurities
The emission factor for uncontrolled
fresh
particulateemissions
spansa rangefrom0.27to 0.98kg/m3
feed
(6 kg/1,000 kg of coke burn-off to 22 kg/1,000 kg coke burn-off).

Particu7ate
emissions
1 kg/1,000
Carbon
incomplete
to control
This
new sources
must
meet
the
NSPS level
of
kg of coke burn-off.
3.2.3.3
the
from
Monoxide
combustion
carbon
of catalyst
monoxide
is accomplished
Emissions.
flue
through
the
Carbon
coke.
monoxide
New sources
gas concentrations
use of special
New units
are
assumed
to
use
are
to less
from
required
than
regeneration
or through the combustion of the carbon aonoxide

incinerator.
results
500 vppm.
techniques
in a waste heat
modern
regeneration
tech-
nigue;described
in Section3.2.1.2to controlcarbon
monoxide
emissions
to
500 vppm.
3.2.3.4
Nitrogen Oxides Emissions.
Nitrogen oxides are formed
in the FCC regenerator by two mechanisms.
In the first,
nitrogen in
the combustion
air
combines
various
with
oxides,
in a temperature-dependent
reaction
to fon
nitrogen
oxides.
present in the coke combines wit~~ oxygen to form nitrogen

Thermal nitrogen oxides formation is thought to be low at
typical regenerator
of nitrogen oxides
nitrogen
oxygen
In the
second
mechanism,
temperatures
(675-735"0),
Therefore, the majority
is assumed to result from nitrogen present in the
coke.
The major
nitrogen
oxide
oxides
emissions
from conventional
specie
is nitric
regeneration
3-19
oxide.
15,25
Nitrogen
are approximately
20 vppm. Nitrogen oxides emissions are generally

from high temperature
conventional
regenerators
regeneration
Use of sulfur
oxides
and are,
FCC units
reduction
less than 200 vppm
on~average,
which utilize
catalysts
550 vppm for
promoter
rnay increase
catalysts.
nitrogen
oxides
emissions
beyond
theselevels.51 Effectivetechnologies
for ehe
control
of nitrogen
oxides
emissions
There are no applicable

nitrogen
oxides
emissions
3. 2.3.5
of VOO are
from conventional
carbon
Federal regulations
on the
boi~er.
concentration
Compounds (VOC)Emissions.
type
regeneration
monoxide
is
After
less
for controlling
from FCC units.
Volatile.Organic
dependent
have not yet been proven commercially.
than
of regeneration.
are
less
the
carbon
10 vppm.
than
Emissions
The VOC emissions
500 vppm before
monoxide
boiler,
The VOC emissions
the
the
VOC
from HTR are
less than10vppn.5ZThereare no applicableFederalregulations

governing
VOC emissions
3.2. 3. 6
Other
from FCC units.
Pollutants.
Other
pollutants
from FCC units
include cyanides as HCNand ammoniaas NH3 The concentrations of

both these
or
after
pollutants
carbon
is about 10 ppm for high temperature
monoxide
combustion
furnaces
used
regenerators
on conventional
regenerators.5Z
3.3
EMISSIONS
UNDER EXISTING
Nationwide
a function
emissions
regulations,
systems,
and feedstock
Emissions
emitting
and unit
limitation
existing
calculation
is expressed
States,
limit
the
entire
FCC regenerator.
sulfur
emission
that
to the
are
oxides
control
when the
State
sulfur
basis.
regulations
applicable
(e.g.,
the
FCC unit
is
emission
limits.
knowledge of the emission
on a throughput
refinery
is Set for~the
equal
capacities
of State
limits
FCC units
State
oxides
by assuming
requiring
emissions from the FCC~nit,

concent~8tion
capacity,
FCC sulfur
at a level
operating
The formats
from existing
quality.
oxides
This is a simple
oxides
FCC processing
may be estimated
sulfur
limits
of sulfur
of nationwide
emission
REGULATIONS
oxides
to sulfur
however, are inconsistent

under
whole refinery
a "bubble,"
rather
Table 3-1 summarizes State

3-20
oxides
and vary from
2,000 vppm) to mass limitations.

falls
mass
In some
and an emission
than specifically
and local
for the
regulations
for
Table 3-1. STATE

AIRREGULATIONS
FOR50, P~ISSIONS
APPLICABLE
TO
FLUID CATALYTIC CRACKING.UNIT REGENERATORS
EPA
Region
State
II
NewJersey
SO, EmissionRegulation
Existing Sources NewSources
2,000 vppm
2,000 vpp~
Comments
emission rate (mass units)

based
on stack
gas velocity,
height,
and gas
temperature
III
IV
NewYork
NAAQS"
NAAQS
Delaware
NAA4S
NAA4S
Pennsyl vs ni a
500 vpp~
500 vppn
Virginia
2,000vppn
2,000vppn
Kentucky
2,000 vppm
2,000 vppn
Missi ssi poi
2, 000 vppn
500 vppn
Illinois
2,000 vppm
2,000 vppn
Indiana
181-681
kg/hr
processregulatiansb
process regulations
Sourcec
Source Specific,
Specific
regulation
SIP
(approval
pending)
Indianapolis
28.2
kg/hr
"1 .
Source
to
be modified
Specific
using computer model and

process
Michigan
WayneCounty
NAAQS
300 vppm
parameters
process regulation
corrected
to
excess
NSPSdor
County will adopt most

stringent
new
regulation
sources
aNAAQS
- National AmbientAir Quality Standard for S02 at ground level.
bProcess regulations ~ General regulations applicable to many processes.
CSource specific regulations ~ regulations applicable to specific FCCunits.
when developed.
3-21
50 per-
air
existing
for
Standard
NAAqS
NAAQS
cent
dNSPS - F~lewSource Performance
to
Table 3-1. STATE

AIRREGULAT~ONS
FORSO, 04I5SI~ONS
APPLICAaLE
TO
FLUID CATALYTIC
CRACKING
UNIT REGENERATORS
(Continued)
EPA
Reg i on
SOxEmissionRegulation
State
Existing
Fiinnesota
~Aaqs
Ohio
0.62-3.0
Sources
new Sources
Comments
NAA9S
kg/
1000 k.g feed

Source
Specific
VI
Wisconsin
NAA4S
NAAQS
Arkansas
NAAQS
NAAQS
Louisiana
2, 000 vppm
2, 000 vppn
New Mexico
4,545 kg/day
Source specific
lation
(includes
regulation)
total
reguSIP
SO emissions
from ref:nery
10 kg/100
kg SO
releaSed
2 kg/100
kg SO
relea2ed
refineries
releasing
4,545 kg and
27,272 kg/day
of sulfur
in process;
90 percent control
refineries
releasing
27,272 kg/day of sulfur
in
process;
98 percent
control
VI
Oklahoma
NAAQS
Texas
NAAQS
NAAQS
individual county
regulations
8ACTa
VTI
Kansas
NAAqS
Missouri
NAAqS
source specific
NAAQS
NAAqS
if
NSPS
exceeded,
facilities
with 454.5 ~g SO,/hr
will be required
to
ambient
reduce
agACT,Best available control technology.

3-22
standard
emissions
is
Table 3-1.
STATE
AIR REGULATIONS
FORSOxEIIISSIONS
APPtICABLE
TG
FLUID CATALYTICCRACKING
UNIT REGENERATORS
(Concluded)
EPA
SOxEmission Regulation
Region
State
Nebraska
Existing Sources NewSources

SO
emissions
also
~a~not exceed
1971
Comments
AP-42
esti~ates
emission
emissions
NSPS
~III
Colorado '
2.0 kg/m
0.86 kg/m
Montana
Ambient
Ambient,
processed
processed
total S02 emissions

from refinery
NSPS
Utah
Ambient
source
lation
for
specific
regubeing developed
plants
attainment
in
areas
NSPS
IX
Wyoming
Ambient
NSPS
Ca~ifornia
Ambient
Ambient
2,000vppn
0.82 kg/m3
applicable
feed
7/1/81
0.38 kg/m3
applicable
feed
7/1/85
SCA9MDa
BAA
QMD
b
1,000 vppn
BACT
Hawai i
Pmbi ent
Ambient
Washi ngton
1,000 vppn
1,000 vppn,
NSPS
aSouth Coast Air gua~ity ManagementDistrict.
bgay Area Air Qua~ity ManagementDistrict.
3-23
non-
FCC regenerators.
For many of these regulatory
formats,
calculation
of nationwide emissions requires knowledge of the FCCregenerator

exhaust gas flow rates.
This flow rate may change on a weekly basis
and is affected by the feedstock quality, catalyst type, and other
process
variables.
This makes calculation
of nationwide
emissions
difficult.
In addition, Lowest Achievable Emissions Rate (LAER)
provisions may apply to some of the affected FCCregenerators.
LAc'R
limits
FCC regenerator
any, of the affected
emissions
to 300 vppm.
FCC regenerators
It is unclear
would be subject
which, i'f
to these
requirements.
19
Nationwide emissions of sulfur oxides from FCCregenerators
can
be ap~roximatedby using the EPAemission factors published in AP-42.47

The AP-42emission factors for FCCu,nit regenerators are averaged
values obtained from emission tests of typical FCCunit operations.
These
tests
currently
oxides
represent
the
level
of sulfur
achieved by FCC units
regulations.
emission
to meet most State
The emission
from FCC regenerators
oxides
factor
3
for
is 1.413 kg/m of fresh
su'lfur
feed.
nationwideFCCfresh feed capacityof 800,000m3

/sd,
January
1980 baseline
413, 000 Mg/year.
emission
of sulfur
The feed sulfur/sulfur
in Figure 3-6 is used to estimate
sulfur
model plants
6.0.
discussed
in Section
324
control
and local
oxides
47
53
sulfur
emissions
For a total
the
nationwide
oxides from FCC units
oxides relationship
oxides emissions
is
illustrated
from the
3.4
1.
REFERENCES
Cantrell,
A.
Annual Refining
Survey.
Oil and Gas Journal.
78(12):1361157. March 24, 1980. Docket Reference NumberiI-I-71.f

2.'
Cantrell,
A. Annual Refining Survey.
69(12):9 8-121. March 22, 1972. Docket Reference rlumber II-I-5.f
3.
Cantrell,
70(13):138-156.
March 27, 1972. nocket Reference Number IIII-6.*
4.
Cantrell,
A.
Annual Refining
Survey.
71(14): 1021121. April 2, 1973;

5.
Cantrell,
72(13):8 5-103. April 1, 1974. Docket Reference Number I~-I-13.f
6.
Cantrell,
A.
Annual Refining
73(14):100~118.
7.
Cantrell,
A.
Survey.
April 7, 1975.
Annual
74(13):130-153.
Docket Reference Number II-I-10."
Refining
Docket Reference ~lumberII-I-16."
Survey.
March 29, 1976.
.Oil and Gas Journal.
Docket Reference
rlumber II-I-23.*
8. Cantrell, A. AnnualRefining Survey. Oil and Gas Journal.

75(13):99-123.
9.
Cantrell,
A.
March 28, 1977.
Annual Refining
Docket Reference Number IIII-29."
Survey.
76(12):114-140. rlarch 20, 1978. Docket Reference NumberTl-I-37.*

10.
Cantrell,
A.
Annual Refining
Survey.
77(13):129-153. March 26, 1979. Docket Reference NumberII-I-57.f

II.
Petroleum Use Study Forecasts
Hydrocarbon Proces~ing.
Number
Sharp Decline
59(6):13.
in Demand Growth.
June 1980.
Docket Reference
II-I176.~
12. Murphy,J.R., and M. Soudek. ModernFCCUnits Incorporate ~any

Design Advances.
1977.
13.
Reference
Gallagher, j.P.,
Number
75(2):76.
January 17,
11-1-28."
W.H. Humes, and J.O. Siessnan.
Cat Cracking To
Upgrade Synthetic Crudes. Chemical Engineering Progress.

June
14.
Docket
1979.
Docket
Hoffman, H.L.
Proces si ng .
Reference
Number
75(6):56.
TIII-59.+
Components for Unleaded Gasoline.
59(2 ) :S9. February 1980.
Hydrocarbon
Docket Reference Number
11-1-49."
15.
Letter
and Attachments
from Flynn, J.P.,
Exxon Company U.S.A.,
to
Farmer, J.R.,
U.S. Environmental
Protection
Agency.
May 8, 1981.
Comments on BID, Volume I, Chapters

II-D-SO.f
3-25
3-6.
Docket Reference
Number
16.
Screening Study to Determine Need for SO and Hydrocarbon NSPS
for FCCRegenerators. U.S. Environmentar ?rotectipn Agency.
Research Triangle
August
17.
1976.
Park,
p. 19.
Number
No. EPA1350/3-77-046.
Number II-A-2."
~ovember 24, 1975.
p. 47.
Docket Reference
11-1-21."
Supplement No. 8 for Compilation of Air Pollutant Emission Factors,

Third Edition. U.S. Environmental Protection Agency. Research
Triangle Park, N.C. Publication No. AP-42. May 1978. p. 9.1-2.
Docket
19.
Publication
Reference
Complete Combustion of Carbon ;4onoxide in Cracking Process.
Chemical Engineering.
18.
N.C.
Docket
Reference
Flumber
II-I-41.*
Guidelines for Lowest'Achievable Emission Rates from 18 Major

Stationary Sources of Particulate,
~itrogen Oxides, Sulfur Dioxide,
or Volatile
Organic
Compounds.
U.S.
Environmental
Protection
Agency. Research Triangle Park, N.C. Publication

3-79-024.
20.
April
1979.
p. 3.4-2.
No. EPA-450/
Docket Reference
Number II-A-7.,
B7azek, J.L., R.E. Ritter, D.N. Hallace.

Hydrotreating FCCFeed
Could Be Profitable.
72(42):104, October 14,
1974.
Docket
Reference
Number
11-1-14."
21. Ford, W.D,, G.J. D'Souza, and J.R. Murphy. FCCAdvancesMerged

in NewDesign.
Docket
22.
Reference
Number
76(21):66.
II-~-43.+
May 22, 1978.
F~uid Catalytic
Cracking With Molecular Sieve Catalysts.
Chem Engineer.
May 1969.
p. 15.
Petroj
Docket Reference Number II-I-2.+
23. Letter and Attachments from Murphy, J.R., The r~.'rl. Kellogg Company,
to Farmer, J.R.,
24.
25.
U.S. Environmental Protection Agency. May 7,
1981.
Cor~Hnentson BID, Volume I, Chapters
Number
11-0-49."
Reference 22.
p. 13.
Docket Reference
3-6.
Docket Reference
Number 11-1-2."
Letter and Attachments from Grossberg, A.L., Chevron Research
Company,to Farmer, J.R., U.S. EnvironmentalProtection Agency.

May 4, 1981.
Reference
Comments on BID, Volume I, Chapters
Number
3-6.
Docket
II-0-47.f
26. Shields, R.J.i R.J. Fahrig, and C.J. Horecky. FCCRegeneration

Technique Improved. The Oil and Gas Journ~l. 2~(22):45. May
29,
27.
1972.
Docket
Reference
Number
11-1-7."
Upson, L.L. Catalytically Promoted Combustion Improves F6C

Operations. National Petroleum Refiners Association Paper AM-79-39.
(Presented at the 1979 NPRAAnnual Meeting.) March 25-27, 1979.
p. 2.
Docket
Reference
Number II-I-55.+
3-25
28.
Chester,
A.W. and F.O. Hartzell.
Partial
Monoxide Combustion FCC Regeneration
with
and Complete Carbon

Promoted Cracking
Catalyst Systems.
National Petroleum Refiners Associatio~ Paper
AM-79-36. (Presented at the 1979 NPRAAnnual Meeting.)
rlarch
2527, 1979. pp. 2, 13. Docket Reference Nu~llberIIII-56.~'
29.
Magee, J.S.,
R.E. Ritter;
Advances.
1979.
Hydrocarbon
Docket Reference
30.
Reference
29, p.
31.
Reference
16, p. 21.
32.
Sulfur
Reference
33.
34.
128.
Number
G.P.,
May 19,
1975.
Docket
Docket
Pacific
Reference
Aalund,
Reference
Control
in FCCProduct.
Manda, M.L.,
L.R.
September
Study
Number II-I-64.*
Number II-A-2."
-- Main Text.
i9ay 1978.
South Coast
p. 6.18.
J.D. McKinney,, and T.C. Readel.
Distribution
;Journal.
128.
Docket
II-I-40.*
Reference
73(21):74-75,
Number TI-I-17.,
Ponca City,
Number
Feed Sulfur
Environmental
Conoco, Incorporated,
35.
Docket Reference
Management District.
Huling,
Docket
58(9):127-
Number I~-I-~;ii~.*
DioxidelSulfate
Air Quality
and L. Rheaume. A Look at FCC Catalyst

Processing.
Services,
Inc.
Oklahoma.
Trip
Report:
August 14, 1980.
II-8-12.*
Sour Crude Technology
Set for 80's.
Oil and Gas
78(12):79.
March 24, 1980. Docket Reference Number
16, p. 70.
Docket Reference
11-1-73."
36.
Reference
37.
Cuddington,
K.S.
High Sulfur
Petroleum Reserves.
1980.
38.
39.
Docket
U.S. Refiners
79(14):52.
40.
Number
with Largest
78(12):96.
March 24,
11-1-72."
for Crude-Oil
Refiners.
1980.
Docket Reference
Major Problems.
Number II-I-74.f
April 6, 1981. Docket Reference Number11-1-89."
Letter and Attachments

from Albaugh, D., Marathon Oil Company, to
Goodwin, D.R., U.S. Environmental
Protection
Agency.
March 20,
1981.
Reference
41.
Facing
Content Associated
Reference
A Heavy, Sour Taste

87(10);96.
May 19,
Number II-A-2.f
Letter
Response to Section
Number
114 infonation
request.
Docket
Ashland
Petroleum
II-D-41.+
and Attachments
from
Prichard,
J.J.,
Company, to Goodwin, D.R., U.S. Environmental

May 27,
Docket
1981.
Reference
Response
Number
to Section
TI-D-53.~
3-27'
Protection
114 information
request.
Agency.
42.
Letter and Attachments from Layson, W.E., Chevron U.S.A., Incorporated,

to Goodwin, D.R., U.S. Environmental Protection Agency. March 24,
1981.
Response
Reference
43.
114 information
Hemler, C.L.,
C.W. Strother,
Residual
of
Association.
request.
Docket
II-D-42."
Conversion
Meeting.)
44.
to Section
Number
Paper
B.E. McKay, and G.D. Flyers.
Stocks.
National
AFi-79-37.
March 23-27,
Petroleum
(Presented
1979.
at the 1979 blPRA Annual
Docket Reference
Number II-I-52.f
Murphy, J.R.
The Refinery of the Future.
Pullman Kellogg,
Houston, Texas.
(Presented at the Second European Petroleum and
Cas Conference.
Amsterdam.)
Reference
Number
II-I-75.*
45.
Reference
12, p. 72.
36.
Murcia,
A.A.,
1979.
r1. Soudek,
Docket
47.
Reference
48.
lilurcia,
A.A.,
Reference
G.P.
4uinn,
1980.
Number
and G.J.
p. 9.1-6.
Docket
M. Soudek,
C.P.
Association.
Paper
NPRAAnnual Meeting.)
Number
Reference
D'Souza.
Quinn,
and G.J.
AM-79-38;
Septembe r
D'Souza.
March 25-27, 1979.
FCCU
National Petroleum
(Presented
at
p. 22.
the 1979
Docket Reference
II-I-53.*
Reference
50.
McArthur, D.P., H.D. Simpson, and K. Baron.
16.,
p. 27.
Docket
Reference
Number II-A-2."
Catalytic
FCCSO Emission Looking Good. Oil and Cas ~ournal.
Februa~y23, 1981. Docket Reference NumberII-i-87.*

Memorandumfrom Bernstein,
G., Pacific
Inc., to Docket NumberA-79-09.
of NO,emissions study.
16, pp. 32-34.
Environmental
Control
of
79(8):57.
Services,
May 21, 1982. Results of analysis
Docket Reference NumberII-B-21."
52.
Reference
53.
U.S. Department of Transportation.
DC~cket Reference
Petroleum Refineries
in the United
January 1, 1980.
Docket Reference
Flumber II-A-2.*
Energy Infon~atidn
Administration.
States
a-nd U.S. Territories.
Number II-I-67.+
Memorandumfrom Bernstein,
G., Pacific Environmental Services,
Inc., to Docket Number A-79-09. April 28, 1982. Results of
Sensitivity
Docket
jg.
Add
53:134.
Number II-I-41.*
49.
54.
Docket
II-I-63.+
Design Criteria for Processing Flexibility.

Refiners
pp. 2-3.
Number II-~-?B.*
Hydrocarbon Processing.
Reference
la.
May 20-22,
Docket
Fl exibi7 i ty to FCCs.
51.
Catalytic
Refiners
Analysis
Reference
No.
of Input
Selection
on Model
II-B-26."
Plant 50x Emissions.
Memorandum
from Bernstein,
G., Pacific Environmdntal'Services,
to Docket Number A-79-09.
September 20, 1982.
Similarity
Inc.,
in Control
Costs between Heavy Oil Crackers and Asphalt Residual Treating Process.
Docket
Reference
No.
II-B-29."
3~28
fReferences can be located in Docket NumberA-79-09 st the U.S.

Environnental Protection Agency Library, Haterside F~lalll~~lashin~ton,n.C.
3-29
4.0
4.1
~EIISS~ON CONTROL TECHNI9UES
INTRODUCTIGN
There are four basic
techniques
oxides emissions from fiuidized

(1)
Flue gas desulfurization
(2)
Feed hydrotreating
(3)
FCC unit
(4)
Sulfur reductidn
process
applicable
catalytic
to controlling
sulfur
cracking (FCC) unit regenerators:
changes
catalysts
Flue gas desulfurization processes remove sulfur oxides from the

flue gases vented from the FCCunit regenerator. The sulfur oxides
areconverted to a liquid waste, solid waste, or salable product.
Sulfur oxides emissions from the regenerator can be controlled indirectly
by using hydrotreating to reduce the sulfur content of the FCCunit

feedstock.
FCCunit process changes can reduce the amount of coke
deposited on the catalyst and, subsequently, reduce the amount of

sulfur
oxides
controlling
vented
from the regenerator.
regenerator
An emerging technique
sulfur oxides emissions involves the use of
special FCCunit sulfur oxides reduction catalysts.

1 _,
techniques
4.2
is discussed
in the following
Each of the
sections.
FLUE GAS DESULFURIZATION
Flue gas desulfurization

oxides
for
from a waste gas stream.
(FGD) involves the removal of sulfur

Two broad categories
are used to
classify FGDprocesses:
(1) disposable FGDsystems (often referred to
as "throwaway" syst~ms) and (2) regenerable FGDsystems. Disposable
FGDsystems use processes
where all
waste streams
ate discarded.
Regenerable FGDsystems use processes where the waste stream is treated

for regeneration of the sorbent and often the recovery of salable
sulfur compounds such as elemental sulfur and sulfuric acid.
4-1
Over100different FGD
processeshavebeenproposed.l However,
manyof these processeshavenot beendevelopedbeyondthe laboratory
or pilot plant phase.
Currently, there are six ;GDsystems that are
in commercialuse in the United States.

applications
The six systems and their
are summarized in Table 4-1.
Six FGDsystemshave been selected as candidatesfor application

to FCCunit regenerators.
Sodium-based
a
a
The FGDsystems selected
are:
FGD systems
Calcium-based FGDsystems
Double alkali FGDsystems
Wellman-Lord FGD systems
Citrate
FGD systems
Spray drying
FGD systems
Sodium-basedFGDsystems are currently being used to control

sulfur oxides emissions from FCCunit regenerators. 4 citrate scrubber
is currently under construction for FCCunit regeneratorapplication.

Thecalcium-based,doublealkali, and spray drying F6Dsystemsare
currently operating or being installed at industrial and utility
boiler locations in the UnitedStates. Flowrates and characteristics
for flue gasesfromFCCunit regeneratorsare similar to flue gases
fromindustrialandutility boilers.2 Similaritiesbetween

boilers
and FCCunit'regenerators are discussed in Section 4.2.1. Other FGD
systems not discussed here, such as magnesiumoxide, have only been
installed at a limited numberof industrial/utility boilers.
4.2.1 Applicabilityof FGD

Systemsto FCCRegenerators
Sodium-based
scrubbingsystemshave been effectively applied to
sevenFCCregenerators at five refineries to control both particulate
and sulfur oxides emissions. These seven FCCregenerators with
sodium-based
scrubbersrepresent11percentof nationwide
FCG
processing
capacity.ll0
Theperformance
characteristics
of sodium-based
scrubbers
are discussed in Section 4.2.2.
Citrate scrubbers have been demonstrated
in utility boiler applications. A citrate scrubberis currently under

construction for an FCCunit regenerator application. Performance
characteristics for this scrubber system are discussed in Section 4.2.7.
Applicationof the calcium-based.doublealkali, Wellman-Lord,

and
spray drying FGDsystems presently used on utility
4-2
and industrial
TABLE ?-1.
FGD SYSTEMCOMMERCIAL
APPLICAfIONS
Number of Operational
FGD Systems
FGD
Process
FCCUnit
Industrial"
Regenerators
Utilitya
aoilers
Boilers
Sodium
based
119
Calcium
based
28
Double
alkali
21
b
Spray drying
Magnesium
oxide
1
3c
Wellman-Lord
Citrate
a~eference
10
le
4C
la,d
3.
bThis represents the numberof contracts signed for spray drying

systems as of February 1981.
CReference
See Reference
2.
4.
dAs of November1979, 1 industrial
boiler application
eunder construction.
4-3
was planned.
boilers
may depend on similarities
between FCC regenerator
and boiler
flue gases. FCCregenerator flue~gas compositions are dictated by the

catalyst coke composition. Boiler flue gas compositions depend on the
properties
of
the
boiler
fuel.
The coke formed on the FCC catalyst

is a carbonaceous material
similar to the coal used in solid fuel-fired
industrial
boilers.
Approximate elemental
analyses
of catalyst
coke and bituminous
coal
are shownin Table 4-2. The catalyst coke is burned off the catalyst
during regeneration by adding air to the regenerator.' The regeneration
process is thus similar to the combustion processes which take place
in boilers.
Given the similarities
solid fuels,
the combustion process which takes place in the FCC
regenerator
those
may be expected
derived
from
A comparison
between catalyst
to yield
coal-fired
coke and other
flue gases which are similar
to
boilers.
between FCC regenerator
flue gases and industrial
boiler flue gases is presentedin Table4,3.10 FCCregeneratorflue

gas compositions
were determined
from a survey
data, stoichiometric relationships,

Boiler
flue gas parameters
of State
emission
test
and from AP-42emission factors.9
are calculated
values for a field
erected
watertube boiler which burns high sulfur Eastern United States coal.lD
As suggested by the information presented, the ranges in concentration
of mast FCCregenerator flue gas constituents overlap the boiler flue
gas concentrations.
FGDsystems installed
on FCC regenerators
will
thus experience similar inlet concentrations as boiler FGDsystems.

The primary difference between FCCregenerator flue gases and
boiler flue gases is the particulate emissions. Boi~er particulate

emissions are primarily fly ash, while catalyst
fines comprise the
majority of regenerator particulate emissions. Both fly ash and

catalyst fines are erosive and maycause abnormalwear in an improperly
designedor operatedFGD
sys~em.11'12
Hydrocarbon emissions from FCCregenerators
may be higher than
those from boilers, especially if they are uncontrolled (see Table 4-3).
The effects of hydrocarbon concentration
4-4
on scrubber operation are not
Table
4-2.
ANALYSIS OF aMENTAL COMPOSTTIONSOF

COKE AND COAL
Composition (wt. Z)
Selected
Catalyst
Coals, Ash
Coke5,6,7
Element
Carbon
U.S.
84.5 ~ 96.0
Free, DryBasis8
74.0 - 90.4
Hydrogen
4.0-
12,0
4.8-
5.7
Sulfur
0.0 -
4. 5
0.3 -
4,0
Nitrogen
0.0 -
1.0
0.9 -
1.7
Other:
Koisture
Volatile
Matter
Ash
"Not available.
4-5
NAd
1.0 - 31.0
NA
17,7 - 49.3
NA
3.3 - 11.7
Table 4-3,
COMPARISON
OF FLUEGASANALYSES
FOR
FCC REGENERATORS
ANDINDUSTRIALCOAL-FIREDBOILERa
Industrial
Coal-Fired
FCCRegenerator
Unit Capacity
Flue
Gas
Flow
Boilerb
800-21,500m3/sdc
52M1~
Rate
(Nm~/min)
280-8,500d
Flue GasTemperature(OC)
2,700
230-420e~f
210
Flue Gas Composition
N2vol.%".
02V01.X"
C02vol. ~"
ai-s4s,h
81.0
0.1-8.0i'9
g-16j'f
COvol, I"
4.2
14.6
0-6,9f,i
Particulates(g/nS)O 0.4-1.5k
50, (vppm)O
NO,(vppm)O
9.6
120-1,600e'l
64-250 k
Hydroca
rbons(gjn3)0
Moisture~
vol. %
2,800
410
i. Ok
IO-23m'f
7.5
a~ncontrolled emissions,
bEs~imated
forhighsuifurEas:ern
U.5.coal(3.54wt.1 5)assuming
120
percent
theoretical
air
for
the
boiler.
See Reference
10,
CReference 14,
Reference
15,
eReference
16,
Reference
17,
9~eference
I~.
Reference
19,
'Reference 20,
Reference
21,
kCalculated QrMnAP-42 emission factor

21,500
mJ/s~;
Reference
See
Reference
9,
22,
mReference 23,
"Dry basis,
OWet basis.
4-6
for 9500 m'/min air
flow and
known; presently
operating
FCCregenerator
FGDsystems may remove some
hydrocarbons
fromtheflue gasstream.l3
Other
differences
in flue
expected to invalidate
the applicabi~ity
There are two specific
to FCCregenerator
gas compositions
areas
flue gas.
and are
not
of FGDsystems to FCCregenerators.
of concern
in applying
FGD systems
FCCunits are very durable and can often
operate continuously from 2 to 4 years.

an FCCunit application
are minor
Therefore, any FGDsystem for
should have a similar
on-line reliability.
Also, becauseof potentially significant S03emissions,the select'ion

of a regenerable system may be limi.ted to ones that can tolerate
sulfates.
The scrubbing systems identified

units
have had varying
ensure acceptable
certain
degrees
of on-line
FGDreliability
precautions
here for application

reliability
for FCCregenerator
should be exercised.
to FCC
to date.
To
applications
Plugging of the capture
system can be minimized through the use of venturi collectors (not

tray towers or packed towers) and a continuous wash of the mist eliminator.
Spare capture modules should also be used so maintenance can be performed
on-line.
Other portions
problems routinely
use on FCC units
shutdown.
have redundant equipment.

have very high reliability
have potential
maintenance
Sodium-based FGDsystems in
due to the use of redundant
Someof these scrubbers hav~ run for over 38 months without
equipment.
a
of the FGD systems that
116
4.2.2 Sodium-Based
FGD
Systems24
-.i
4.2.2.1
Process Description.
Sodium-based FGDproceSses are
capable of achieving high sulfur oxides removal efficiencies
over a
wide range of inlet sulfur oxides concentrations. However,these

processes consume a premium chemical and produce an aqueous~waste for
disposal which contains sodium sulfite and sulfate salts.
Sodium-based
FGDsystems currently
use an aqueous solution
of sodium hydroxide
(NaOH),
sodiumbicarbonate(NaHC03),
or sodiumcarbonate(NA2C03)
to
absorb
sulfur
oxides
frcm the
flue
gases.
Sodium alkali
sorbents
are
highly reactive relative to calcium-based sorbents.

Also, the reactant
liquid is a clear solution rather than a slurry because of the high
4-7
solubility
of sodiurn salts.
which take
place
The sulfur
oxides absorption
reactions
are:
2NaOH
t 502 - N~aZS03
+ H?O
2NaHC03
+ 502 -Na25a3c H20+ C02
Na2C03
+502
'Na2S03+ C02
Na2503
+ 502t H20---,2NaHSa3
Simultaneously some sodium sulfite
gases
to produce
sodium
reacts with the oxygenin the flue
sulfate:
NaZS03
+ 1/202
- Na2SOq
The resulting product is primarily a sodium sulfite, bisulfite, and

sulfate solution which is removedfrcxn the process for disposal.
4.2. 2. 2 System Design. A generalized flow diagram for the
sodium-based FGDsystem as applied to the FCCunit regenerator is
presented
three
basic
(1)
in Figure 4-1.
This system may be described
in terms of
processes:
Reagent preparation
(2) Particulate removaland sulfur oxides absorption

(3)
Waste preparation
and disposal
The reagents used in FCCapplications of sodium-basedFGDsystems

are either sodium hydr~xide (NaOH)or sodium carbonate (Na2CO~)
Sodium systems currently
in use on utility
and industrial
boilers
employ sodium hydroxide,
sodium carbonate,
or sodiurn bicarbonate
(NaHC03)
as the sorbent. Storage silas are required for solid or
liquid reagents; mixing tanks are required for solid reagents.
For FCC-applied sodium-based scrubbing systems, particulate
removal and sulfur
oxides absorption occur in a venturi scrubber.
Two
scrubber designs, the jet ejector and high energy venturi scrubber,
are in use on FCCunits. Selection of venturi type depends upon the
pressure of the flue gas exiting the regenerator.l3,26

The jet ejector rzn.turi scrubber, shown infigure 4-2, consists
of a spray nozzle ane ~enturi throat. The scrubbing liquor, sprayed
into the venturi throughthe nozzle at 513 to 925kPa,27inducesa

draft, drawing regenerator flue ga~sinto the scrubber. Thus, the
jet-ejector venturi operates with negligible pressure drop. This type
4-8
(sptio"a'.!..................................................~.faF
Gas
Flue
rJas
Distribution
Nozzle
Venturi
Scrubber
Blower
Reheater
~ir
?v
~L~1
Separatbr
Vessel
Fuel
~as
IYake-up
water
Caustic
Storage
Tank
pH Hanitor
Polymer
Addition
System
Clarifier
Sulfite
Oxidatian
Reactor
Thickener
51u
Water
Effluent
Discharge
Air
~ompressor
Figure 4-1~. Process Layout of the Sodium-8ased

Venturi
Scrubbing Sys~em
FtC Regenerators
4-9
Qeplied
to
SCRUBBING
LIQUID
SPRAY
NOZfLE
OIRTY
GAS
ilii,iII\\
Illllll\lj\
VENTURI
TO
LIQUIO
SEPARATOR
Figure 4-2.
Jet Ejector Venturi Scrubber
4 -10
DRUM
of venturi
boilers
has been applied
which cannot
to existing
be backpressured
FCC units
with carbon monoxide
to use a high
energy
venturi
scrubber.7 Thehigh energyventuri scrubber,a wet-wallventuri, has

been applied to two new FCCunits with high temperature regeneration
and an overall
flue gas pressure
liquid-to-gas
(L/G) ratios
drop of about 10.3 kPa.
for the jet ejector
scrubber are 5.7 to
13..4m3of scrubbingliquor per 1,000m3of flue gaz.

ratios
for the high energy venturi
scrubber
Typical
Typical
L/G
m3
are 0.7 to 4.0 m3/1,000.
of flue gas.12
Sulfur
brides
removal
occurs
by reaction
between
the sadium-based
scrubbing liquor and the sulfur oxides in the gas stream.

removal occurs by inertial
entrained
particulates.
interactions
venturis
occur
are used
impaction of the scrubbing

These solid-liquid
within
the venturi
in industrial
Particulate
liquor
and gas-liquid
scrubber.
and utility
mass transfer
Contactors
bailer
with the
other
than
applications.
In
these applications, the contactors operate at low pressure drops and

are designed only for sulfur oxides control.
A separate control
device
is usually
required
Gases frcm the venturi
to control
pass
into
particulate
emissions.
a separator
vessel.
Here the
flue gases are separated from entrained scrubbing liquor. The flue
gases are directed to a stack, reheated if necessary, to maintain
plume buoyancy, and vented to the atmosphere. The scrubbing liquor
collected
scrubber
in the separator
with
a small
purge
vessel
is recirculated
stream
sent
back to the venturi
to the wastewater
treatment
system.
Changes in flue gas flow rates
by altering
ratio.
are compensated for in the scrubber
the scrubbing liquor flow rate to maintain a constant L/G
In the jet
ejector
venturi
scrubber,
the scrubbing
liquor
pressure at the spray nozzle affects the flue gas flow rate and the
scrubbingliquorflowrate.28
As flue gas sulfur oxides react with the reagent in the scrubbing
liquor, the pH of the liquor falls, reducing the sulfur oxides removal
efficiency
of the scrubbing
system,
To maintain
scrubber
efficiency
and liquor
pH between 6 and 7 as well as to min~mize corrosion
and
erosion,7'2qsodiumcarbonate,hydroxide,or bicarbonateis addedto

the
scrubbing
liquor.
4-11
A portion of the recirculating

liquor is continuously removed
from the scrubber system. This stream,.consisting
of collected
particulate and spent scrubbing liquor (mostly sodium salts), is
directed
to oxidation
and clarification
tanks or ponds to reduce
chemical oxygen demand and remove suspended particulates.

The treated
stream is then disposed to surface water, evaporative ponds, orinjected
into deepwells. Solid wastesare mostcommonly

disposedin a landfill.30
4.2.2.3 Development
Status. Sodiumscrubbingsystemsare commer~ially
available technologies.
These systems have been applied to seven FCC
unit regenerators at five petroleum refineries,
and to 80 percent of
the commercialindustrial boilers with FGDequipmentin the U~5.31

Table 4-4 summarizes the location
systems presently
applied
and perfonnance
of sodium-based
FGD
to FCC regenerators.
4. 2. 2.4` System performance. A scrubber vendor claims that up to

94 percent reduction in sulfur oxides has been achieved by sodium-based
scrubbersin actual FCCunit emissiontests.13 Fromavailable FCCunit

performance test data summarizedin Table 4-4 and found in AppendixC,
a 37 percent
removal efficiency
was achieved
on one FCC unit with an
inlet S02concentration
of 280ppm.37Scrubber
sulfuroxidesoutlet
concentrations
of 9 to 100 vppm have been observed
(see Appendix C).

oxides levels
FCC tests
Although designed to accommodate inlet sulfur
as high as 3,000 vppm, the performance of sodium-based
scrubbers applied to FCCunit catalyst

assessed
in other
at high inlet
sulfur
regenerators
has not been
oxides concentrations.
Since model unit
regenerator flue gas sulfur oxides concentrations
are as high as 2,700
vppm, it is necessary
concentrations
to evaluate
scrubber
outlet
under
these conditions,
Information on sodium-based scrubber operation at
high
concentrations
sulfur
oxides
coal-fired industrial boilers.

similar
was obtained
from EPA tests
of
FCCU
catalyst regenerator flue gas is
to the flue gases generated
by fossil
fuel-fired
boilers
in
flow rate, temperature, and in the composition of nitrogen, oxygen,

carbon dioxide,
nitrogen oxides.
carbon monoxide, particutates,
sulfur
oxides,
and
Thus, sulfur oxides control technologies applicable
to fossil fuel-fired boilers are also applicable to FCCUcatalyst

regenerators.
Fossil
fuel-fired
boilers
oxides when burning high sulfur
emit high concentrations

fuels.
4-12
At one facility
of sulfur
EPA conducted
TAULF
4-4. PERFORMANCE
DATA
FOR
OPERATING
SODIUM-BRSEO
FGD
SY~TEMS
ONFCC
UNIT
REGENERRTORS
Rlrflou
RerlllerylSrNbbrr
LoLal8nTyD.
Fxroll
Bayuay, HJ
Rate
502Inlet
j02Outlel
502Removal
Cancentra~lonConcentrdtlanElflclency
lorb.nt llh31.ln) (*PPR)
(Yppm)
(I)
THDJet
EJeclor
Warte
nlsposal
nclludD
Reference
To Surface
Sodluu-bJsed
- 8.540t
Elxon
8a1on
One
Jet Ejector
Rouge.
Venturl
LA
System
(2 FCC
Unltr)
8oth FCC
Uolts
fxxon
Ollr
HR
ISb~.9
Ha
far
Uater
L5
To Surface
Sodlum-bPsrd8.230(
1.5-118
HA
llater
i. 32.33
To Surface
Hater
7. 34.35.36
P
r
Baytonn.
Jet fjectur
1X
Venturl
Units)
FCCUnit
(2~LC
forEoch Sodlum-bared3.520(
c
5,575
660
I.Olo
94
61eIw,36994
Harathon
To Surface
Garyvllle.
LA
Illgh
Energy
Venturl
Sodlum-based 3.700d
280-390f
9-27
93-97
Water
3.7
NIA
To Surface
7.5
95
Hater
37.38
SoulhHestern
Corpur
thrlstl.
HighEnergy
TX
Venturl
Sodlum-based
1.740
I,fi9O
N/A
150
"Dlsposalrollowlllgtreatmentfor chemicaloxygendelsand(8011)
and suspendedsolids.
btalculared
CAfter
fronlludss eln(sslon rate.
CO holler.
dlllghte~llperature
regeneration(HTA).
e5crubber star-t-up 12/80; unit has not yet been tested.
fleported as total sulfur oxides.

90ry.
115
a continuous
installed
percent
sulfur
monitoring
program
on a sodium-based
scrubber
system
on a boiler that was burning coal with 3.25 to 3.73 weight

sulfur.
During a 2-day period
dioxide
concentrations
an hourly basis.
Outlet
in the testing,
scrubber
inlet
ranged from about 1,670 to 2,760 vppm on
concentrations
varied
during
this
period
from
about9 to 55 vppm,and represent emissionreductionsof up to 98 percent.39

The performance
ranges
of other
sodium-based
from 80 to 98 percent
control
scrubbers
of sulfur
on industrial
dioxide
at
boilers
inlet
concentrationsrangingfromi50 to 2,100vppm.40Thus, sodium-based

scrubbing systems will substantially
dioxide
range
concentrations
reduce high flue gas sulfur
and are therefore
of FCCU catalyst
regenerator
applicable
sulfur
Venturi scrubbers installed
dioxide
over the expected

emissions.
on FCCregenerator
flue gas streams
also control particulate

emissions.
Tests performed at a new FCC
regenerator
show the unit to be in compliance with the new source
performance standard for particulate
burn-off).29
emissions (1 kg/1,000 kg coke
This unit employs a high energy venturi
scrubber.
Emissions from one FCCregenerator with a jet ejector scrubber system

are well within the particulate new source performance standard (NSPS)
although 14 is not a new source (see Appendix C for a summaryof
results).'"
well
In this
below
the
new
case,
source
State
particulate
emission
limitations
are
standard.
4.2.3 Calcium-BasedFGD
5ystems41
4.2.3.1
aqueous slurry
of insoluble
from the flue gases.
Calcium-based 500 systems use an
calcium compounds to absorb sulfur
oxides
Lime (calcium oxide, CaO) or finely ground li~e-
stone (calcium carbonate, CaC03)is mixedwith water to form a slurry.

The absorption of sulfur oxides by the slurry involves both gas-liquid
and liquid-solid
many side
reactions.
mass transfer.
The overall
The chemistry
reactions
is complex and involves
are:
Lime
50i+ CaOc 1/2H2 O----~CaSO3 a1/2H2 O
SDp+1/202 +Ca0+2H20~
CaS04~2H20
Limestone
S02+ CaC03
+1/2H20--, CaS03~1/2H20
c C02
4-14
S02+1/202 t CaC03+ ZH20-,

The resulting
product
precipitate,
is a calcium sulfite
System Desion.
A generalized
based FGDsystem is presented

can be divided
into
(1)
Reagent
(2)
Sulfur
oxides
(3)
Solids
separation
(4)
Solids
disposal
boiler
grinding,
flow diagram for a calcium-
in Figure 4-3.
four
process
for disposal.
The basic
design
of the
components.
preparation
The reagent
utility
and calcium sulfate
which is removed from the process
4.2.3.2
system
CaS04'2H20
+ C02
absorption
preparation
for calcium-based
applications
often
consists
and/or lime production.
FGD systems used for
of limestone
crushing
and
For an FGDsystem designed for the
significantly
lower flue gas flow rates typical of an industrial
boiler or FCC unit regenerator,
lime or preground limestone would
probably
ii
be purchased
and delivered
to the facility.
Thus, the reagent
preparationsystemfor an FCCunit regeneratorapplicationwould

consist
of storage
silos
and either
lime slaking
or limestone
slurrying
equipment.
The absorptionof
(often
referred
(e.g.,
venturi
on the specific
to
a stack.
sul;fur
oxides
to as an "absorber").
scrubbers,
solids
tank
precipitation
A continuous
to
is designed
the
effluent
contactor
Various types of contactors
FGDsystem design.
The absorber
in a gas-liquid
packed towers, spray towers) are used depending

liquid
Gases from the absorber

effluent
or hold tank where calcium sulfite

The hold
occurs
flows
to a reaction
and sulfate
to provide
adequate
crystals
residence
as well as for dissolution

stream
are vented
is pumped from the
vessel
precipitate.
time
for
of the calcium
hold
tank
reagents.
and circulated
absorber.
A purge stream from the hold tank is sent to a solid-liquid

separator
to remove the solids
dewatering can be accomplished
the
location
The solids
nonnally
of the
content
disposal
from the system.

Solids separation
or
using a variety of methods depending on
site
of the waste
and the
sludge
ranges from 30 to 85 percent
4-15
method of disposal
from a calcium-based
by weight.
used.
FGD system
REHEATER
_FAN
TO STACK
S02ABSORBER
STEAM
MAKE-UP WATER
FLUE GAS
LIME
LIME
OR
SLAKER
LIME STONE
CRUSHING SLURRY EFFLUENT

HOLD
TANK
AND
GRINDING
SOLID-LIqUID
SEPARATOR
SECOND
STAGE
soLIo-Lrguro
SEPARATOR
OR
SETTLING
SOLID WASTE
figure4-3. Processflowdiagram
for a typicalcalcium-based
wetscrubbing
system
42
Sludge disposal
is one of the major disadvantages
FGDsystems in comparison to other

sludge
is generally
materials
types of FGDsystems.
sent to a pond or landfill
companies have attempted

or other
to process
salable
of calcium-based
Dewatered
for disposal.
Some
the waste sludge into building
products,
but additional
developmental
work
remains.
4.2.3.3
Development Status.
are currently
commercially
the mostcommon
control
recent
type
available.
of FGD systems
sulfur
oxides
survey
reported
operation
Both lime and limestone FGDsystems
emissions
that
Calcium-based
used
in the United
from utility
under construction
Calcium-based
boiler
(refer
two
industrial
to Table 4-5).
on FCC unit
and
in the
United
States
FGDsystems have been installed
regenerators.
4.2.3.4
achieved
were in
FGDsystems have recently
locations
No calcium-based
at 35 facilities,
been
at
to
boilers.
FGD systems
being planned at 16 facilities.

installed
States
coallfired
lime or limestone
at 28 facilities,
FGDsystems are
System Performance.
sulfur
oxides
removal
Calcium-based FGDsystems have
efficiencies
of
at
least
90 percent
for
flue gasstreamsfromc0al-firedutility boilers44andatleast 88per~ent

for
flue
gas streams
fran
industrial
boilers.
Inlet
sulfur
oxides
concentrations
for indust~ia~boilersmayrangefrom200to 2,000ppm.45
A summaryof the design characteristics
calcium-based
in
Table
FGD sys.tems
applied
for operating and planned
to industrial
boilers
is presented
4-5.
4.2.4~OoubTe
AlkaliFGD
Systems46
4.2.4.1
referred
to as "dual
solution
to absorb
based
alkali
sulfur
solution
Although there
most developed.
alkali
use an aqueous
oxides
from the
flue
is used to regenerate
the
sodium/calcium
The principal
system
chemical
double
gases.
the
Absorption
2NaOH
+ S02
- Na2S03+ H20
Na2003+502---) Na2S03+002
4-17
alkali
A second
active
process
for
calcium-
sodium solution.
processes
alkali
reactions
are:
FGDsystems (also
sodium-based
are other types of double alkali
been investigated,
double
a'lkali'l)
Double alkali
which have
is the
a sodiun/calcium
Table
4-5.
SUMMARYOF COMMITTED CALCZUM-BASEC SYSTEMS FOR
U.S. INOUSTRIAL
BOILERS
AS OF ~ARCH
197843
Scrubber
503 Oes~gn
Reagent,
Location
Yen~or
scmim
Type
Lime,
Koch Engi-
2,400
Coal
0.8
#Ad
850
Coal
2.2
95
1.600
Coal
3.6
90
1,250
Coal
3.0
94
1,100
Coal
3.5
95
Armco Steel,
Eliddle~own, OH
Air F1OW
Company and
Fuel
Removal
:f~lfur
Efficiency '6
neering
Carborundum
Lime,
Abrasives,
Buffalo,
Catbarundum
Environmental
NY
systems
Rickenbacker
LimelLine-
Air
Base
stone.
OH
Research
Cottreil-Bdhco
Force
Columbus,
Bunge, Inc.
Cairo,
Lime,
IL
Dravo Corp./
National
Lime Assoc.
Pfizer,
East
St.
Inc.
Louis,
tL
Lime,
Pflzer.
Inc.
aNot available.
4-18
Na2S03c 1/202
- NapSOq
Na2S03+ S02 c H20
~ 2FlaHS03
Regeneration
~1/2H 2 O
Ca~OH)2
~ 2NaHS03 - Na2S03+ CaSO
3
Ca(0Hj2c Na2S03
+ 1/2H2 O ---~2NaOH
+ CaSO
+ 3/2H 2 O
~1/2H
Ca(OH)2+Na2S04+ZH~O~TZNaOH+
CaS04'2H20
The sodium hydroxide
calcium
sulfite
(NaOH) solution
and calcium
sulfate
4. 2. 4. 2 System Design.
alkali
FGD system
alkali
FGD sy~tem~ures
based
in Figure
technology
in the process.
precipitate
A generalized
is presented
is
removed
for
The
disposal.
flow diagram for a double
4-3.
In general,
the
common to sodiun-based
double
and calcium-
FGD systems.
The reagent
slaker,
preparation
and mix tanks.
contactor.
The type
design.
equipment
Absorption
effluent
is
of contactor
the
effluent
flows
alkali
recirculated
to
varies
There the precipitated
back
to
The reactor
calcium
effluent
salts
FGD system
to a stack.
is
A portion
The
which
is
lime
in a gas-liquid
the
contactor.
into
silos,
occurs
depending.on
the
vessel
of storage
oxides
are vented
a reaction
solution.
consists
of sulfur
Gases from the contactor
the
based
i:
is recycled
remainder
added
the
of
of
calcium-
pumped to a thickener.
are separated
from the solution.
The regenerated NaOH

solution is returned to the reagent hold tank.
Sludge containing
concentrated
the calcium
in a vacuum filter
The solids
are washed,
to
sodium
recover
landfill
the
for
to about
generally
salts.
disposal.
with
The washed
solids
50 percent
solids
by weight.
one or two displacement

solids
The filtrate
is further
are
then
and wash water
sent
are
washer
toa
pond
recycled
to
thickener.
4.2.4.3
commercially
Double
at
sulfite~sulfate
alkali
10 industrial
Development Status.
offer
double
FGD systems
boiler
alkali
are
Several process vendors currently

FGD systems
presently
sites.
FGD systems ap.plied to industrial
Table
operating
4-6
boilers.
4-19
in the United States.
summarizes
or planned
double
The smallest
for
use
alkali
application
or
SCRUBBED
OIS
GAS
70
S1'ACK
SCRUBBER
SCRUBBER
FEED
>"
5~
d_l
FLUE GAS
II'
THICKENCH
SCRUBBER
EFFLUENT
f"
TU
LIME
H~O
VYAStl
IIOLDING
VVATER
REACTOR
LIME
SLAKER
~VASTE
CALCIUM
SALTS
VACUUM
FILTER
Figure 4.4.
S!mplifled ~~low
alkali proces
diagr~~gfor
a sodiunlline
TINK
Table
SUMMARY
OFOPERATING
AND
PLANNEO
INDUSTRIRL
ROILER
DOUBLE
ALKALI
SYSTEMS4B
4-6.
Installation/Location
ARCO
Polymers
vendoror
Size
No. of
Devel
oper
SCM/m FGD
lknits
502
Inlet
Fuel
TypeC '15
FHC
5,900
ZURN
1,900
FMC
6, 700
ZURN
ZURN
Haste
Remuva\
(X)
Disposal
180
90
Landfill
3.2
2.000
200
90
Landfill
3.2
2.000
200
90
Landfill
3.2
2,000
200
'JO
Landfill
1.100
~C
3.2
2,000
200
90
Landfill
4.000
3.2
2.000
200
g0
Landfill
230
1.000
95
90.5
Landfill
3, LOO
800-1.300
80-130
90
Landfill
Grissom
AirForceBase
Nep
tunel 910
NAd
NAd
Landfill
Bunter
Alrpol
28
96
Landfill
PA
Caterpillar Tractor Co.

East
8,600
(vppll~) (vppn)
a
502
i, B00
Monaca,
FnC
502
Outlet
Peorla,
IL
Caterpillar Tractor to.

Joliet,
IL
CaterpiIlar Tractor Co.

Hap)eton,
IL
Caterpillar Tractor Co.
;lorton,
IL
Caterpillar
Tractor Co.
Mosrville.
IL
Firestone
Tire and Rubber
Pottstown.
General Motors Corp.

Panma.
RIC
2.5-3.0
NY
G.M.
2.5
OH
Hill,
IH
Santa Fe Energy Corp.

Ba~ersfleld.
FnC
2.000
3.0-3.5
1.5
NAd
710
CA
dlnle(502and~elcent
S02renavdlare ar r.porfedLoPEOCo
byFGD
ry~tanoprr.lor~. YlluePreportedmayrepresenfanyfhing
frrm
single point wet chenlical determinations
may not
be EPA approved.
Calculated.
CCoal - C
Oil
-O
dHor available.
to continuous monitoring results.
Methods used to detennine the values reported may or
is
treating
treating
a 230 Sm~/min gas stream,
a 8,600 Sm'/min ~as stream.
have been installed
4.2.4.4
achieved
flue
and the
on FCC unit
oxides
gas streams
removal
application
No double alkali
is
FGDsystems
regenerators.
System Performance.
sulfur
largest
Double alkali
efficiencies
from coal-fired
boilers
FGDsystems have
of at
with
least
inlet
90 percent
for
concentrations
as
high as 2,000 ppm and as low as 800 ppm.
Design features
and performance
characteristics
FGD systems
presented
Table
for
operating
dual
alkali
are
in
4-6.
4.2.5 SorayOryi?gFGD
Sv5tems47
4.2.5.1
alkaline solution to absorb sulfur
unlike
the other
spray
drying
with
water.
alkaline
types
of FGD systems
FGD system
are
Consequently,
solution
Spray drying FGDsystems usa an

oxides from the flue gases.
However,
discussed,
insufficient
the
or slurry,
flue
the L/G ratios
to saturate
gas sulfur
dispersed
for
the gas stream
oxides
react
with
the
in the gases as fine droplets.
The droplets are quickly dried by the heat contained in the flue gases
and become solid
soda
ash
or
particles.
lime.
oxides proceeds
The alkaline
Reaction
between
the
solution
alkaline
both during and following
is prepared using
solution
and
sulfur
the drying process.
The
mechanismsof the S02 removal reactions are not well understood, it

has
not
been
predominantly
atomized
oxides
determined
in the
droplets
whether
liquid
being
and the slightly
reactions
for
this
phase,
dried,
oxides
spray
are
removal
by absorption
or by reaction
moist
process
sulfur
dried
shown
into
between
solids.
occurs
the
finely
gas phase
The overall
sulfur
chemical
below.
S02 + Na2C03 - NaZS03

c C02
S02 c Can+ 1/2H20 ~CaS031/2H20
In addition
the
to these primary reactions,
following
sulfate
salts
reactions:
Na2S03+ 1/202
- Na2SOq
S03 + NaZC03 --NapSO~+ C02

SOpC CaO+ 1/202 '2H 2 O
4-22
-CaS04,2H2 O
are produced by
The resulting
unreacted
product
sorbents
control
which
equipment.
not collected
drying
is
a dry mixture
of sodium
are
using
collected
Generally,
upstream
FGD systems
particulate
both
sulfur
conventional
matter
of a spray drying
provide
or calcium
oxides
and
particulate
in the
FGD system.
salts
flue
gases
is
Thus, spray
and particulate
emission
control.
4.2.5.2
drying
System Design.
FGD system is presented-
combustion
device
130 to 160"0.
finely
atomized
device
enter
mist
for
dryer
slurry
with
and are routed
reactant
particulate
in the
is
removed
removal
baghouse.
above
solids
saturation
collection
Accessory
facilities.
include
dry storage,
Facilities
for
transporting
normally
flue
gases.
hot
dryer
as a
Gases
exit
particulatecol
lection
(ESP) or baghouse where

Systems
using
oxides
to maintain
toavoid
reagent
a mix tank,
a baghouse
sorption
flue
gas
condensation
for
occurring
temperature
on the
to the
the
preparation
preparation
and associated
collected
ultimate
spray
disposal
from boiler
flue
dryer
site
facilities
and pumps.
waste
are
Spray drying
gases
and dry waste
tanks
with baghouse or ESP collection
Development Status.
oxides
the
of reagent
In general,
associated
4.2.5.3
sulfur
point
consists
handling
it
the
between
surfaces.
equipment
disposal
into
sulfur
be taken
generally
sprayed
disposal.
at this
device
temperatures
precipitator
additional
Caremust
Flue gases from the
to a conventional
for
report
at
is
contact
such as an electrostatic
spent
flow diagram far a spray
in Figure 4-5.
a- spray
The alkaline
the spray dryer
well
A generalized
product
similar
and
to those
devices.
FGDsystems
have been demonstrated
for removing
by pilot-scale
testingon industrialboilersizedsystems(280to 560m3/mill)

at
several
utility
locations
in the
United
States
where low sulfur
coals
werebeingburned.50This technPlogy
is currentlybeingoffered
commercially
been sold
by several~ companies.
for
industrial
applications.
FCC unit
drying
90 percent
boiler
applications
No spray drying
FGD systems
FGD systems
and 10 for
utility
have been installed
have
boiler
on
regenerators,.
4.2.5.4
spray
Four spray drying
System Performance.
F.GDcan achieve
for
low-sulfur
Pilot
sulfur
uti~ity
oxides
plant
removal
and industrial
4-23
studies
have shown
efficiencies
coal-fired
up to
boiler
Lime SlurrY
~conomiZer
particulate
Stack
C,~~ectio~
Boiler
SpraY
\Rir Preheater\
\ Dryer
inducedDraft
Fan
Combustion
Air
49
dia9rl'
forspray
dryinl
process
Figure
4-5-Si.plified
f\OV
applications.
Removal efficiencies
from 75 to 85 percent
guaranteed by vendors for recent installations

systems
4.2.6
have Seen
of spray drying FGD
industrial boiler sites (refer to Table4,7).51
at
4,52,53
Wellman-Lord System
4.2.6.1
regenerable
sodium sulfite-bisulfite
from the flue

sulfur
gas.
dioxide
sulfate.
concentrated
system to remove sulfur
The sodium sulfite
in the flue
stream
of
processed
liquor
of the sodium su7fite
sulfur
dioxide.
to elemental
The Wellman-Lord process
and regeneration.
scrubbing
This
sulfur
at the refinery
consists
of two basic
The principal
ct~emical reactions
with
and sodium
produces
dioxide
sulfur
dioxide
reacts
gas to form sodium bisu'lfite
Thermal regeneration
further
The Wellman-Lord system utilizes
a
can
sulfur
stages,
be
plant.
absorption
for these stages
are:
Absorption
2S03+ S02 + H20

2C03+ S02
~ Na2S03+ COZ
ZNa2503
+ 02
r-
- 2NaHS03
r 2Na2S04
2Na2S03
+ 503+ H20
- 2NaHSOj
i na2S04
Regeneration
ZNaHS03 - Na2S03+ H20+ 502

4.2. 6. 2 System Design.
Lord system is presented
throat
venturi
scrubber
of the flue gas.

tray-type
absorber
The scrubbed
vented
t~o the
flue
particulate
Flue gas enters

removal,
gas then passes
the flue gas passes
gas
then
passes
through
a variable
cooling,
through
and saturation
a mist-eliminator.
counter~currently
through
absorbing
liquor.
a mist-eliminatornd
is
stack.
in the
the evaporator,
for
flow diagram of the Wel7man-
with sodillm sulfite-bisulfite
Spent scrubbing
is heated
in Figure 4-6.
The flue
Within the absorber,
A generalized
liquor
evaporator
the sulfur
is filtered
to regenerate
dioxide
4-25
to remove suspended
the
is stripped
scrubbing
solids
liquor.
from the scrubbing
and
In
Table 4-7.
Companyand Location
Yendor
Sorbent
Strathlllore
H1Lrropol
Lime
Hheelabrator-
time
Woranoco,
h,
SUMMARY
OF SOME
INDUSTRIAL
BOILER
SPRAY
DRYING
SYSTEMS51
Paper Ca.,
(s un/m)
620
Fuel
502
SOp
Inlet
Outlet
X Sulfur
(vppm)
(vppm)
Coal
2-2.5
NA
NA
Coal
1-2
800-2,500
NA
Type
S02Relnoval
Efficiency"
($)
75
PIA
Celanese.
Cumberland, MD
(TI ~
Frye/nockwell
International
Nn - Not available.
"Deslgn.
Size
1.400
60-80
Reheat
Absorber
Regenerated
Absorber
To Stack
Feed Solution
FlueTGas
[II
ist Effect
2nd Effect
End
Evaporator
Evapora tot
ProductTo
Plaiit
I~akcWater
~lsele
IIl~ollj,Na
l~lriypul.
To nsh
-~__
Pond
Rich
5olutinn
pSDj
Stnrdge
""t'e-ul'
feed
Vent
Cooler
Sciubbcr
Uissolving lank
IT-J-
lycol
Chillcl
('I11.!JC Nd
'Solids
Centri
FJ2
F~gure 4-6.
5 Lcal\
Process Flow DiagramWellman-LordProcess
liquor,
regenerating
quantities
the sodium sulfite.
of sodium sulfate,
thiosulfate,
formed during
formed during regeneration,
This purge solution
may contain
The scrubbing
liquor
is then
with steam.
and sodium
solids
solution.
by weight.
Soda ash
to replenish sodium lost to purge.
returned
Vapors from the evaporator

dioxide
absorption,
from the absorbing
27 percent
is added to the scrubbingiquor
sulfur
A purge stream removes small
to the
are cooled,
absorber.
condensed,
and stripped
The vapors flow to a sulfur
dioxide
of
compressor
system.. Fromthe compressor sulfur dioxide can be further processed

in a Claus,
liquid
In general,
storage
su`lfur dioxide,
reagent
and handling
or other
preparation
oxides
plants,
frc~
include
soda ash
equipment.
4.2.6. 3 Development Status.

sulfur
end plant.
facilities
flue
seven sulfuric
Wellman-Lord systems for removing
gas have been installed

acid
plants,
three
on seven
industrial
Claus
boilers,
sulfur
and four
utility boilers.4
4.2.6.4
Systemperformance. Actual performance achieved by
Wellman-Lord systems is 90 percent
or greater
removal of sulfur
dioxide.
A summaryof operating Wellman-Lord systems in the U.S. is presented

in
fable
4.2.7.
4-8.
Citrate-Based
4.2.7.1
available,
A third,
55,56,57,58,59,60
Twocitrate
the Bureau of Mines process
processes are currently
and the Flakt-Boliden
process.
the Peabody process, has been used in one pilot plant study
and represents
with
FGDSystems
a specific
application
of the Bureau of Mines process
modification.
The Bureau of Mines and Flakt-Boliden
citrate
processes
are
essentially the samein terms of S02 removal. Bothprocesses use a

citric acid buffered solution to absorb 502 from the flue gases. The
basic reactions
which occur during
SO + H O---tHSO
22
H + Cit
+
3
--HCl't
+ H+
=
H+c Citt ----~H,Cit
H1~Cii--~H;Clt
Where:~Cit
= citrate
absorption
ion
4-28
are:
Table4-8. SUMMARY
OFOPERATING
HELLMAN-LORO
SYSTERS
INTHC
U.5.54
Design S02
Conll,dlly
/(-UCa t i 01~
Feed Gas
Date
Orlglll
Sulfuric
Plant
1000 Nnl"/hr
Dis pos i et or,
i sc fill)
ppm
~ of SOE
76
(45,000)
lee 6,000
out 500
Recycle to acid plant
Sttl. Oil of Califl,mia

ZI Se'JU"dO. CaliTurllla
Septelnber 1972 Claus plants
51
(30,240)
in 10,000
out 250
Recycle to Cl~aus plant
Allieel Chelalcal
Calunel.
Illinois
Novelnber
Ulill Chelllical
Curtis
bay, Maryland
Std. Oil of California
1972
Sulfuric
plants
acid
51
(29.850)
1112.700
out 250
necycle
to acid
plants
May 1973
Sulfuric
plants
Acid
133
(18,n46)
in 4,000
out 250
Recycle
to acid
Iilants
August 1974
Claus plant
in 10.000
Recycle to Claus plant
Stgulldo.
Northern
(3U,n00)
January 1935
CI~USplant
51
(30,000)
Califorllia
Indiana
Public
Decunber
1976"
Coal-fired
527
(3 L0,000)
Indiana
Pulllic
Nm
Service
Nexico
Waterflow,
in 2,200
out
Aecycls to Claus plant
250
Elallental
sulfllr
200
(115HW)
Co.
of
Novell,ber
1978
Cnal-f
boiler
New Muxicu
public
Service!
New Hexico
250
in 10.000
out
boiler
Cary,
Co.
of
Illteqrated
s~lsllcllded
ired
--
--
'H)% rt~lloval
Elelllental
sulfl~r
--
--
SK)X rellloval
Elelnental
~ulfl~r
(314 nw)
Novellll,el
1970
Uoal - f i red
boiler
New ~lexico
*I'la~~t operation
in,luly
51
out
Service
*CI:irrt
'
California
Std. 011 of CdJifUnljd
UnterfloH.
Acid
Collcrl~Lration
July
fl
1970
Gas Flow
Olin Chelnicdlf
Paulsbu~u. New Jersey
Ricluiioiid,
'p
Completion
(306 MU)
as of Jarluary
i,
1916.
ol,er~tlu~~ of Ll~e plallt. Has in Dec~llber 1976; I\owever, Lhe I~lellalan-lord systall began ope,-ationr
1976, before canpletion of the Allied sulfur recovery unit.
The first equation accounts for over 90 percent of the SD2removal
fromthe flue gases.61

provide
buffering
The three
to keep the
citrate
disassociation
equilibria
pH in the optimum range
for
absorption
(4 to 5 for the Bureauof Ninesprocess,603 to S for tKe Flakt-Boliden

process.
"
For specific
applications,
the
exact
pH needed
(determined
by the S02 concent.ration in the feed) is maintained by adding sodium

hydroxide
or
soda
ash
to
form
the
sodium
citrate
absorbent
solution.
Duringthe absor;ltion process, someof the S02, approximately
1.5 percent of the amountahsorbedfor the Bureauof Minesprocess63

andless than 1 percentfor the Flakt-Bolidenprocess,64is oxidized.
forming sulfate
ions and, thus,
sulfuric
acid by the following
reaction:
H~O+ H++ !/202---~HS04

3
In addition, the S03 that'is

forms
sulfuric
neutralized
the
acid
in
the
not removedin the gas scrubbing system

citrate
solution.
through the addition
following
The
of caustic
sulfuric
acid
is
(NaOH), or soda ash, by
reaction:
H2S04+ 2NaOH ,Na2SOqc 2H20

The resulting
the citrate
Glauber's
solution
salt,
a secondary
decahydrate
is continuously
by vacuum~ crystallization.
may then
feedstock
4.2.7.2
system
sodium sulfate
be disposed
System Design.
can be considered
Flue
or sold
for
sulfate,
use as
industry.
Both the Bureau of Mines and the Flakt-8oliden
in terms
gas
The crystallized
of as a waste
in the chemical
removed from
of the
following
steps:
pretreatment
S02 absorption
Absorbent
a
Sulfur
Purge
~ generalized
regeneration
product
recovery
treatment
flow diagram
for
the Bureau of Mines system
and the
Flakt-Boliden system are shown in Figures 4-7 and 4-8, respectively.

Flue Gas Pretreatment.
In both systems, the off gases are cleaned
prior
to entering
variety
the absorber.
of high ~r'ficiency
mist precipita~Jrs
particulate
collectors
(wet ESP) or venturi
precleaning
is designed
acid
A waste
mist.
Off gases may be cleaned first
stream
from the
4-30
and then by Plectrostatic
scrubbers.
to remove particulates,
scrubber
by a
This flue gas
chlorides,
is generated
and sulfuric
and needs
to
GPIS
GLEI.ING
1 502*BSOAPTION
1 SULFUR
PRECIP17E~TION
I SULFP~TE
I
5UCFURI H~SGENERP;TION
AND
AND
COOL1NG I
RECOUERY
To 905 rehealer
and slocL
GleonLdand'_
cooled pos I
REMOVAL
ISOLUTION
~EGENEAAflON
)
H2S-GOZ
Racycla
liqu~r
I
GOp
p
w
Flus
S)eom
gos
Sultur
Sollur
powderl I
slurry
HLO
liquor
Acid
Sodium
rul(old
uu~,er
ondsolid I
poc)lculoles
Mollsn
Figure 4-7.
rullur
Flow Diagram for.the Bureau of Mines Citrate Process
i CHq
~EAN
GA5
CCEDENSOR
ALTERNATIVE
PUNfS
SIRIPPER
""2
Liq.
-II
ABSORBER
G,
h,
HzSOI
115-
~lue
_JElectrortpClf
Gar
1SO'F
~7~
Cooler
Preclplts
STEACI
H~KE
UQ
SODIUN
ZUPHATE
Figure4-8. FlowDiagram
for the Flakt-Baliden
CitrateProcess
15
be disposed
of in an environmentally
acid mist helps

Sodium
to minimize
sulfate
formation
acceptable
sodiumrulfate
would
increase
manner.
formation
the
purge
Removal
of
in the absorber.
requirements.
Offgasesare typicallycoaledto 46to 660C

duringpretreat~ent.65
SO, Absorption.
In both systems, the cooled, saturated
the bottom of a packed-column

current
to the
absorbent
absorption
(i.e.,
the
gases enter
tower where they flow counter-
sodium-citrate
buffered
solution).
The absorption process is pHdependent. As S02 enters the absorbent

solution,
the
pH decreases.
the pM in the desired
The citrate
acts
as a buffer,
range for absorption.
Absorption
maintaining
takes
place
at
atmospheric
pressurebetween38 and540C.66Thecleanedgasesare
releasedto the atmosphere,
after passingthrougha demister.67
Absorbent Regeneration.
The two systems differ in both theabsorbent
regeneration
and the rulfur product recovery steps.
In the Bureau of
Mines system, the absorbent, now loaded with S02, is sent to a closed
reactor
that
is agitated
In the
reactor,
and operates
the SO,-laden
at 52 to 54"0 and about 206 kPii.
absorbent
is reacted
with
hydrogen
sulfide (H2S) The following reaction takes place:
HS03
c H++ 2H2S
--)35 c 3H20
This reaction
regenerates
the absorbent
and produces
elemental sulfur and regenerated absorbent.

with the offgases
prior
to entering
aslurry
of
Unreacted H2S is combined
a catalytic
(orthermal)
incinerator.
Within the incinerator, the H2SIs oxidized to 502;_ The combinedgas

stream
then
enters
the
off gas pretreatment
system.
Tn the Flakt-Boliden system, the S02-laden absorbent is pumped

from the bottom
tower.
of the
The stripping,
absorption
tower
which may take
to the
place
top of a stripping
at atmospheric
pressure
or
undervacuum,70
is acconplishedby steamtreatmentin countercurrent
flow to the S02-laden absorbent. The steam accepts the Sap from the
citrate
solution,
This stripping
reversing
process
the
chemical
thus regenerates
reactions
given
the absorbent
in Section
and produces
4.2.4.1.
mixture of S02 and water that exits the stripper at the top.
Sulfur Product Recovery.
sulfur-regenerated
sulfur
is separated
In the Bureau of Mines system, the elemental
absorbent
from the
slurry
absorbent
4-33
leaves
the reactor.
by either
oil
The elemental
or air
flotation.
The flotation
sulfur
process results
slurry,
the other,
slurry is treated
the
in two separate streams; one is a concentrated

absorbent.
The concentrated
sulfur
to remove the sulfur from the slurry by melting the
regenerated sulfur and decanting the remaining absorbent.

sulfur drawn off is a high-quality
molten yellow sulfur.
The Inolten
In the Flakt-Bolidensystem,the mixtureof S02andwater leaving

the stripping
tower
is cooled
in a condenser
where most of the water
is separated. Thecondensate,containingonlya smallamount

of S02,
is returnedto the strippingtower. Theconcentrated
S02gas canbe
conveyed
sulfur,
directly
to a C~aus plant
to a contact
plant
fo~ the production
for sulfuric
of elemental
acid production,
or to a
refrigeration unit for condensationto liquid 502

Purge Treatmen.t. In both systems, the absorbent reclaimed during the
absorbent regeneration
step contains small amounts of sodium sulfate.
Before the absorbent is recycled to the absorption tower, a small
stream
is sent
sulfate
are
to a crystallizer
selectively
where the
crystallized.
sodium citrate
The sulfate
and sodium
is removed as
Glauberls salt by cooling the solution to a temperature well above the

freeting
point
of water.
4.2.7.3
Developmental Status.
The Bureau of Mines citrate
process
was devised in 1968 for application in the nonferrous smelting industry.

A pilot plant was constructed and operated in 1970 at the MagmaCopper
Company's San Manuel smelter in Arizona. Another pilot plant was
constructed at the Bunker Hill base metal smelter in Kellogg, Idaho,
in 1976. The first commercial unit was completed in 1979 at a powerplant

owned and operated by-St. Joe Minerals to.
The F'lakt-Boliden process
is based on work begun in the early 1970s by the Boliden Companyof

Sweden, the Norwegian Technical Institute Sintef, and Flakt (Svenska
Flaktfabriken).
A pilot plant using the Flakt-Boliden~ process has
been used at the Boliden'works in Sweden, treating capper and lead
smelter flue gases. The Electric PowerResearch Institute is sponioring

a pilot plant at TVA'sColbert Steam Plant in Alabama. Although
neither process has beenapplied to any FCCunit regenerator,
one is
currently underconstructionto control S02emissions~ftom

the iCt
unit
regeneratorat
the Saber refinery
Table 4-9 summarizes the application

4-34
in Corpus Christi,
of citrate
Texas.
process systems.
Table 4-9.
CITRATEFGDPROCESSUNITSa
6as vo\ula
IDCdtjoI1
~gllaCoppuror
tl-eatcd
Feedgas uri9in
Nll'/la
Cuplrrwurllrr
8.5
50,
50,
concc~~tration,
vpPll RuouvJ1,
I
10.000-15.000 43-11)
I)isposition
ofSOf
~lelllcntal
sulfur
5611 HIIIUL~J. ATiLOlld

(8urcau
of Mines)
OunterHill
Kellogg,I~al~o
Leadrprlter
28
Coal-firedboiler
57
Copper,lead, and
83
Coal-fired power
4.420
3,000-10.000
(typlcally s.nnn)
r90
F~lelnentll
sulfur
1,000-2,006
95-97
~lelllellLJ~
sulfur~
5,000-50,000
90-39
LiquidS02
i9i)
Elellr~llJ1sulTur
(Bureau of Mines)
4500 hours
operation
Pfiltr T~rre
Ilaute,
Indiana
Bolidrl~
AL;t(ebolag
SltelleltrhlM, Sueden
(FlattJ
Oprat(undl
Sept.
1976
P
w:
(typicdlly 30.0011)
since
St. doe Minerals
MOlldCd,
PenllSy)Yd(tia
Ln
2lne slllelters
bol)r~
2,000
(desiyn)
(Oureau of Mines)
Early
1980 startup
scheduled
fur tills 60-00 power boiler
fGU systLtru
tennessee YolleyAut~Hlrity
ruscuabla. A)dbalM
Co~l-TlreJPOner
boiler
(Flatr)
Startup
p)ll,nc~d
for early
1980
5itr
to be selected
IOU-Wt coal-tired
(Fldkt)
power boiler
Site selection
In inld-1979
hbrl-
e*pectrd
Relirlillg Cowlpany
Corpus Chrlsti,
StdTLUP planned
Hcferelrr
56.
lexas
for 1983
FCC ul,it
rfgenerator
P,OOL~4.000
(Iypically. 2.400)
L)O
4.2.7.4
System Performance.
The pilot plant studies of the
aureauof MinesprocesshaveshownS02removalefficiencies over

90 percent
and up to 99 percent.
it has been stated
that
sulfur
recovery effic~fencies can be in excess of 99 percent for refinery

applications.
The Flakt-Boliden process_is also capable of removingover 90 percent

of the S02 from the flue gas." A summaryof the design characteristics
of previous, operating,
fable
4.3
and planned citrate
process systems is found in
4-9.
FEED HYDROTREATING
Hydratreating
is a refinery
process used to pretreat
catalytic
cracking feeds and other process feeds by removingmetal, nitrogen,

and sulfur
compounds.
Hydrotreating
is also used to stabilite
and to
improvethe quality~of finished products (e;g. kerosine, fuel oils,

lubrication oils) prior to being sold. The decision by a refiner to
install a hydrotreating unit is based primarily on process and economic
considerations.
Feeds are hydrotreated
to remove sulfur
to lower the
sulfur content of refinery products; to removemetals, nitrogen,

sulfur compoundsto prevent poisoning of catalysts used in refinery
processes and, consequently,
selectivity,
achieve longer runs, better cracking
and improved product yield;
and to remove corrosive
compounds
to prolongthe operatinglife of refinery processequipment.73
The hydrotreating of feedstocks prior to processing by catalytic
cracking
removes sulfur
compounds from the FCC feed.
The amount of
sulfur contained in coke deposits on the cracking catalysts and ultimately

converted to solfur oxides in the FCCregenerator
is determined by the
characteristics of sulfur compoundsin the FCCfeed. In general,

processing a high sulfur FCCfeed results in higher FCCregenerator
sulfur oxides emissions than processing a low sulfur FCCfeed. Therefore,
feed hydrotreating
oxides emissions
4.3.1
will contribute
to lowering FCCregenerator
sulfur
to the atmosphere.
Process Description
Many
commercial
hydrotreating
processes
are available.74Although
variations
exist
between these processes
the basic operations
similar.
A gene~alized diagram of the hydrotreating
in Figure
4-9.
4-36
are
process is shown
Reactor
Iligh
Sulfllr
I PIehealer
reed
I~efillery
Ilynrogcll
\/
Fuel
6as:
and
LicJllt
Ilycll~ocarb0n~
P
w
UPSIIJ FIII` i zed
Sc(,al-a~ion
I',olll~ct
slid
I'ui-ification
((ecycle
Ilydrogen
Figure 4-9.
General process
schematic for feed hydrotreating
The FCCfeedstock to be treated is combinedwith hydrogen gas and

preheated
enters
to about 370"C at high pressures.
a reactor
containing
cataly~tswhich
This combined feedstream

initiate
reactions
between
the hydrogen and the hydrocarbon molecules. Depending on how sulfur

is bound to the hydrocarbon molecules, sulfur in the hydrocarbon
molecules can be replaced by hydrogen to form primarily saturated
hydrocarbons,
hydrogen
~ulfide,andothergases.75 Hydrogen
also
reacts
with
nitrogen
compounds
in the
feedstock
to form a~nnonla.
There is a net consumption of hydrogen during this process.

Effluent from the reactor vessel is cooled and separated into its
liquid and gaseous components. The gaseous fraction contains mostly

unreacted hydrogen, hydrogen sulfide, and ammonia. ~oth the hydrogen
sulfide
and ammonia are scrubbed from the light
are disposed or recovered separately.

recovered
and returned
to the reactor.
hydrocarbon
stream and
The unreacted hydrogen is

Thedesulfurized
liquid
fraction
is separated into light and heavy hydrocarbon products that are used
as feedsrocks for fluid catalytic cracking units and other refinery

processes
or are
sold
products.74,75
as finished
4.3.2 Potential for ReducingFtC RegeneratorSulfur OxidesEmissions

Reductions in sulfur oxides emissions from FCCregenerators
related
to the amount of sulfur
are
removed from the FCC feedstock.
Hydrotreating units (HDT)are capable of reducing FCCfeedstock sulfur

74-78
levels to over 98 percent.

Coke sulfur and regenerator sulfur
oxides emissions, however, are not reduced by equivalent amounts.
Pilot
plant
studies
and commercial operations
have shown that when
various FCCfeedstocks containing 1.7 to 2.8 weight percent sulfur are

desulfurized 88 to 96 percent and charged to an FCCunit, coke sulfllr
and sulfur oxidesemissionsare only reduced62 to 94 percent.79'80

This difference
in the feedstock
straight
in sulfur reductions is attributable
char~cteristlcs.
FCC feedstocks
to variations
are a combination
of
chain, ring, multiple ring, and other hydrocarbon molecules.
The sulfur present in the feedstock may be bound in relatively simple

molecules such as mercaptans or in complex ring molecules called
thiophenes. Feedstocks which have relatively high proportions of
polyaramatic compoundsand thiophenes are more difficult

than those feedstocks
that
contain
4-38
simple sulfur
to hydrotreat
compounds.
More
hydrogen and higher desulfurization

pressure)
aromatic
severity (higher temperature and
are required to achieve high reductions

and thiophenic
Whenhydrotreated
feed sulfur
feedstock
feeds.
feeds are charged to the FCCunit,
distributes
contains
between the products
primarily
simple sulfur
coke sulfur and regenerator

sulfur oxides
the reductions
in FCC feed sulfur content.
contains high proportionsof

reductions
in coke sulfur
and sulfur
sulfur
These hydrotreated
and sulfur
with
identical
oxides
sulfur
emissions
contents..
and thiophenes,
emissions
reductions.
in
however,
may be considerably
The sulfur-containing
aromatic
feedstocks
If the HDT
emissions may approximate

If the HDT feedstock
oxides
which remain in hydrotreated
form coke.
and the coke.
the remaining
compounds, reductions
polyaromatics
lower than the FCC feed sulfur

molecules
of sulfur from
76,79,81,82
feedstocks
preferentially
thus yield higher coke
than other
hydrotreated
feedstocks
76, 79,81,82 Performancedata for
hydrotreating of FCCfeedstocks is presented in Table 4-10.

4.3,3 Additional Benefits Derived FromFCCFeed Hydrotreatinq
There are many properties of high sulfur FCCfeeds which make
these potential feedstocks undesirable.
Feeds which contain sulfur in
non-thiophenic forms give high hydrogen sulfide yields and high sulfur
gasoline when charged to an FCCunit.
Sulfur in thioph_e_niccompounds
yields high sulfur cycle oils and high sulfur in coke."

High molecular
weight ring compounds in aromatic feeds preferentially
adsorb on the
FCCcatalyst and form coke. The high nitrogen and metals contents
either poison the FCCcatalyst or increase the yields of undesirable
productssuchas cokeandgas.87
Hydrotreating
of potential
FCCfeedstocks,
including gas oils,
deasphalted oils, atmospheric tower bottoms, and various residual

feeds, improves the feed cracking characteristics
and reduces feed
sulfur, nitrogen, and metals contents.
Desulfurized FCCfeedstocks
exhibit improved yields of gasoline blending stocks, lower product
sulfur levels,
and reduced coke and gas yields over untreated
feedstocks.
for
5,81,82,89Agasolineyield improvement
of up to 20 percent
desulfurized
Also,
over
FCC throughput
untreated
FCC feedstocks
may, in some cases,
has been observed.
be increased
due to higher
first passconversion
of the feedintousefulproducts.5Theseyield
4-39
Table
4-10.
PERFORMANCE
DATA FOR HYDROTREATING
OF FCC FEEUSTOCKS
Sulfi~r
Crude Oil
WT
~ource
Sulfur Cclltent (wt.9;)
Feedrtoc~
H)T
Feed nDT
Producf
TCC AecJenerator
Id)T
Aaduction
50 Emlsslorls
Unit
(:ppndry)
~peb
Ref.
NRa
~avy Gas Oil
i. 76
0. 24
86
IIR
83
HR
~tavy
2.20
0.2
90
NR
84
Atlll. Residua
2.2
0.33
81
660
18
Arm.
Residua
2.93
0.12
96
330
IB
Kuwait
Arm.
Resldua
3.8
0.20
92
660
78
Iuwltt
Atin.
Aesidua
3.8
0. 10
91
Z1U
IB
Soutl~ Loulslana
Arm. Residua
O. 46
0. 05
07
78
Yest Texas
Gas Oil
1.15
0.21
88
470
00
Yest Texas
Gas Oil
2.59
0.24
91
314-500
85
Kuwait
Gas Oil
2.66
O.11
96
236
80
AldSkdll
Atm. Rrsidua
1.59
0.3
81
520
86
Yest
Light
Texas
Ardbidn
Gas Oil
P
P
~IR - Hot r.epul.trd.

6 = Conndrci.)
~T
unit
P ; Piler
plant
1DT unit.
I1A
and product quality shifts result from the hydrogenation and saturation
of organic sulfur and polyaromatic compounds in the feed. The magnitude
of the yield and quality siJifts depends on the quality of the untreated
feedstock
and the degree
The hydrotreating
benefits
of hydrotreating.
of FCCfeedstocks may also result
beyond the reduction
inFCC regenerator
sulfur
in air quality
oxides emissions.
Because there are no government or industry-wide sulfur content specifications for gasoline, catalytic cracked gasoline is normally not
hydrotreated prior to blending with other gasoline stocks. However,
by removing sulfur compounds, hydrotreating of FCCfeedstocks reduces
the sulfur
sulfur
content
contents
of gasoline
in gasoline
obtained
result
by catalytic
cracking.
in reduced, sulfur
Lower
oxides emissions
114
to atmosphere from the combustion of gasoline

4.3.4
Development Status
As of January 1979, 31 refineries
portion of their FCCcharge stock.
in motor vehicle
were pretreating
The total
all
engines.
or a
U.S. FCCfeed hydrotreating
capacitywas142,000
m3/sdor about18percentof the total FCC
fresh
feed capacity.
It is expected
that
this
percentage
will
increase
as
refiners increasetheir ability to processhighsulfur crudes.91

Economic and process
refiner
that
to install
considerations
an FCC feed
an FCC feed hydrotreater
hydrotreating
to install
hydrotreating
a hydrotreating
process
selected
the decision
unit.
would be installed
regenerator sulfur oxides limitation.

refiner
affect
It
solely
by a
is unlikely
to comply with
The investment required by a
unit varies
with the type of
and the types of feedstocks
to be
treated.
Typical capital costs for hydrotreating units range from
3
92
$2,000 to 910,000 per cubic meter of feed pgr stream day (w /sd).
In general, the costs for hydrotreating gas oils are at the lower end
of the range and the costs for hydrotreating residuur~ are at the upper
endof the range. Forexample,

the capitalcostfor a 2,500m3/sd
hydrotreating
desulfurization
unit processing Middle East vac_uumgas oil at 90 percent

is approximately
98 million,"
The capital
cost for
an 8,000m3/sdhydrotreatingunit processingArabianHeavyresiduumat
98 percent
desulfurization
is approximately
980 million.''
net consumption of hydrogen occurs during hydrotreating,
4-41
Because a
hydrogen
costs
can be significant.
In most refineries,
handle normal hydrotreating
sufficient
requirements is available
hydrogen to
as a byproduct
fromcatalyticreformin9.73
However,
if separate
hydrogen
:nanufacturing
facilities
are needed, the capital
at a specific
refinery
will
example hydrotreating
A major process
install
costs for a new hydrotreating
be higher
than
the costs
estimated
unit
for
the
decision
to
units.
consideration
a hydrotreating
influencing
a refiner's
unit is the need to protect catalysts
to poisoning by sulfur, nitrogen,

feedstocks.
Wit~out hydrotreating
susceptible
and metal compounds in process

the feedstock, catalyst
life is
greatly reduced. Therefore, the cost of hydrotreating is justified by

longer catalyst life, better product yields, and better product quality.
Other process considerations
include a refiner's
desire to protect
refinery equipment from corrosive compounds and to meet finished
product
4.4
specifications.
PROCESS
CHANGES
Since sulfur oxides emissions from the FCCregenerator

for
any given
feedstock,
by the
amount of coke fonned
are determined;
on the
FCC
catalyst, process adjustments which decrease coke production may also

reduce sulfur oxides emissions. Three technological developments have
given FCCoperators considerable flexibility
in controlling product
yields,
operating
conditions,
and Sulfur
oxides
emissions.
These
are:
(1)
Zeolite
catalysts
(2) Transfer line (riser) cracking

(3) High temperature or carbon monoxide-promoted regeneration.
Other process changes, such as adjustments in the type and quantity of

feed recycle,
may also be used to reduce regeneration
sulfur
oxides
em issions.
4.4.1
Zeolite
Catalysts
Catalyst evolution has resulted

which have higher
cracking
activity,
in high activity
greater
liquid
stability over early amorphous

catalysts.95,96
catalysts
zeolite
yields
High activity
can reduce the production of coke on FCCcatalysts
comparedto older catalysts.
catalysts
and improved
zeolite
when
Aromaticcompounds
preferentially forn
4-42
coke on the FCCcatalyst and increase sulfur oxides emissions;because
of their highactivity, zeolite catalysts can promotethe dehydrogenation

of feed aromaticcompounds
and, therefore, reducesulfur oxides emissions.
Theamountof time the catalyst is in contactwith the FCChydrocarbon
feed and other factors such as feed temperaturemayresult in greater
cokeformation.95Refinersmayperiodicallyadjust the contacttime

to maximize the yields
of certain
products. 97 To control sulfur
oxides emissionsfromthe regenerator, a refiner maychooseto minimize

catalystjhydrocarbon contact times and cake production.
4.4.2
Transfer Line (Riser) Cracking
Thedevelopment
of zeolite catalysts spurred the development
of
transfer line or riser cracking. Transfer line cracking refers to the
action of crackingthe FCChydrocarbonfeed partially or entirely

within the pipe that transfers the regenerated catalyst and feed
hydrocarbonsto the separator vessel. In early FCCunits, most
hydrocarbon
crackingoccurredon a fluidized bedof catalyst, hydrocarbonr,
and steam inside what is now called the separator vessel.
Short contact time riser cracking techniques result in optimal
utilization of high activity zeolite catalysts. Zeolite catalysts in

conjunctionwith riser crackingenable the refiner to reducecoke
fonmation.98In part, the degreeof control is dependenton the
characteristics
4.4.3
of the FCChydrocarbon feed.
NewRegeneration Techniques
Variables associated with regeneration have an impact on regenerator

emissions. The efficiency of coke burn-off during the regeneration
processdirectly affects the productionof cokeduringthe hydrocarbon

crackingreactions, and thus affects emissionsfromthe regenerator.
Regeneration
efficiencyis measured
by determining
the weightpercent
of carbon that remains on the regenerated catalyst (CRC). Since large
coke deposits thigh CRC)inhibit zeolite catalyst activity, it is

usually desirable to minimizeCRCby efficiently burningoff the coke
deposits.99
Newtechniques have been developed to simultaneously increase
regeneration
efficiency
andreduce
theemissions
of carbon
monoxide
fromthe FCC.regenerator.Hightemperatureregenerationuses higher
4-43
temperatures than conventional regeneration to burnoffcatalyst coke
deposits. Carbonmonoxide
oxidation-promoted
regenerationuses catalysts
to promote the complete
combustion
of carbon monoxide,
Conventionalregenerationtechniquespresently used by most

refiners yield CRCon the order of 0.1 to 0.6 weightpercent.7,100,101
Thelatest regenerationtechniquescan reduceCRC

to about0.02 weight
percent.
It is difficult to separate emissions effects which result from

process changes involving catalysts, riser cracking, or complete
regeneration techniques.
It has been estimated that the combined
effect of these process changes has been a 40 percent reduction in
sulfur oxides emissionsfromunits whichhaveused the pracesses.94

Processchangeswhichinvolve catalysts, riser crackingvariables, and
regenerator conditions mayalter coke production from over 6 percent
to 4 percent by veight of the FCCfeed for commonly
used feedstocks.l02
Sucha changewouldbe expectedto~yield greater than 33 percent
reductions
in regenerator
sulfuroxidesemissions
for a givenfeedstock
if coke sulfus
remains
constant.
4.4.4 Other Proces_sChanges

Other process changes which affect regenerator sulfur oxides
emissionsinvolvechangesin the cokema~ke

rate. Often, small portions
of the heavy FCCproducts are recycled from the fractidnator for
additional cracking to increase the yields of certain products.
Maximum
gasolineyield is obtained,for example,by recyclinga portion
of thedistillate product
material.l03Thisaction,however,
increases
coke production and mass emissions of sulfur oxides. It has been
estimated that a 5 volumepercent decrease in heavyoil recycle would
result in a decrease in cokeproductionof 0.3 weightpercent.l04 An
increasein conversionincreasesgasolineproduction.Thisaction,
however,also increases coke production and massemissions of sulfur
oxides.
4.5
SULFUROXIDESREDUCTION
CATALYSTS
Anemergingtechnologyfor the control of FCCregeneratorsulfur

oxides emissions uses special catalysts which influence the novenent
4-44
of sulfur
within
regeneration
are
emissions
the
with
the
cracked
limited
sulfur
formed
transformed
scale
bench
oxides
oxide
preventing
and pilot
sulfide
and
while
82,105-108
tests.
capacity
catalysts.
as 90 percent
tests,
in commercial
processing
and
as high
plant
utilize
These
capabilities
vessel,
fractionator
Reductions
reduction
reduction
thus
hydrogen
to the
has been obtained

500 unit
catalyst
and separator
into
vapors
plant.
during
catalysts,
FCC reactor
sulfur
of nationwide
sulfur
special
hydrocarbon
reduction
generation
have
are
in small
up to 80 percent
oxides
In the
refinery
been achieved
first
on these
oxides
to the
About a percent
Sulfur
atmosphere.
sulfur
ultimately
have
FCC unit.
captured
to the
captured
vented
the
catalysts
and typically
achieve
30 to 40 percentsulfur oxideemissionsreductionovernormalcatalysts.tll
4. 5. 1 Process
Description
Although
the
sulfur
reaction
several
oil
reduction
companies
catalyst
mechanisms
and catalyst
sulfur
involved
are
oxides
similar
vendors
control
82,109
are
developing
technique,
and
are
the
summarized
below:
Regenerator
Reactions:
S tin coke) + 02
S02 ~ 1/2 02
-S02
5u?fur Burning
- S03
502 Oxidatian
Sa3 + netal tin catalyst)

Reactor/Separator
MS+ H20
sulfur
in the
trioxide
with metals
fon~ metal
sulfates
The regenerated
reactor
as
catalyst
Metal
Sulfate
Reduction
coke
Sulfide Hydrolysis
is oxidized
FCC regenerator.
to sulfur
The sulfur
dioxide
trioxides
aluminum or magnesium) in the special

which
catalyst
in normal
' MS+ 4H20

'MO + H2S
in the
(usually
Metal
Sulfate
Formation
Reactions:
MS04+ 4H2
Sulfur
- MS04
are
stable
and the metal
FCC operations.
4-45
under
internal
sulfates
are
and
combine
catalyst
to
regenerator
conditions.
then
to the
routed
Interpretations
of the reaction mechanismswhich convert the
metal sulfates to hydrogensulfide in~the reactor/separator vary

slightly.
Pmocosuggests that the metal sulfates are reduced in the
presence of the hydrocarbon feed and that the metal sulfides
are
hydrolyzed in the steam stripper section of the separator vessel.79

Patents issued to Chevronindicate that the steam stripper may not be
involved
in thesulfidehydrolysis.100
In eithercase,the hydrogen
sulfide thus formedis vented to the FCCfractionator with the product
stream. Thehydrogensulfide is eventually separated fromthe liquid

products and processed i~ntoelemental sulfur at the refinery sulfur
recovery plant.
The catalyst
is returned to the regenerator vessel to
burn off coke deposits and to begin the sulfur oxides capture process.
As with conventional fluid catalytic cracking, the process is continuous.
The sulfur active catalysts may be present in several forms in
the catalyst inventory. It mayeither be incorporatedinto the cracking

catalyst or addedas a separate solid whichwouldconstitute a portion
of the total
4.5.2
FCC catalyst
inventory.
DevelopmentStatus
Sulfur oxides reduction catalysts have beenunderdevelopment

f
several years.
Many bench scale and pilot
plant tests
have been
conducted, and a limited numberof commercialtests have been performed.
Re;ults of benchscale, pilot.plant,
and
commercial
tests
show
that
sulfur oxides emissions reductions are high as 90 percent have been
achievedwith development
sulfur oxides reductioncatalysts.ll2
Severalproblems
havebeenencountered
by someof the processdevelopers
in obtaining pilot plapt results in commercial
operations. Nevertheless,
a recent ccimmercial scale test of a commercially available
sulfur
oxides reduction catalyst, summarizedin AppendixC, and other commercial

scale tests of developmentalsulfur oxides reduction catalysts, summarized
in Table4-11, showthat sulfur oxides reduction catalysts are capable

of reducingthe regeneratoremissionsfroman FCCunit processinga
1 percent sulfur feed by about 80 percent.l06' 108,112 Based on these
commercialtest data, sulfur oxides reduction catalysts are expected
to achieve 80 percent reduction
in sulfur oxides emissions from FCC
units processing Z~to 2 percent sulfur feeds whendeveloped.

4-46
Table 4-11. Summary

of 50, REDUCTIO#
CATALYST
PERFORMANCE
DATA11Z
Feed
FCC Unit
Regeneration
Company
ARCO
ARCO
Contrelled SO,
5Ll.1fur
Level
Estimated
Emission
(Weight
Reduction
50
dlb
(Percent)
cmms s~on
?evel
(kg/1,00OCg
Mode
Percent)
coke burn-off)
Conventional
.
1,10
73
HTR with
1.18
57
14.7
0.31
30
7.i
0.99
94
1.6
1.19
88
d.Z
5.0'1'
B.SC
'd
CO Promoter
4RCO
HTR with
to
thevton
7ranoter
Conventional
with
CO
Promoter
Chevron
Conventional
ui th tO
Promoter
Chevron
--
0.45
67
Mobil
HTR
1.27
72
Mobil
HTR
1.0
66
10.1
iexaco
H7R
1.26
57
15.1
API
Conventiona~
1.16
41
30.0
Ilt
10.0
with
CO
Promoter
Oavison
Conventional
0;48-0.58
45
~av~son
Conventional
0.48-0.58
58
8.5C
Davison
- Conventional
0.56
66
7.1'
Davison
Conventional
0.52
-55
9.0t
Davison
Conventional 0.48-0.58
80
4.0t
dEstimated percent reduction Has obtained by comparing actual SO
emissionswith SO reductioncatalysts in use to estimatedbase~ine
emissions. EstimHted baseline emissions were obtained by using the

average feed sulfur level during catalyst testing and the 50, emissionsl
feed
sulfur
relationship
iound
in Figure
3-6.
bEstimated percent emission reduction may include the effects of first

generation 50 reduction catalysts
reduction cat%lyst.
CEmisslon's originally
cole
burn-off
as well as the developmental 50x
reported in vppmwere converted to k9/1,000 kg
by using
Figure
dThe low SO emission:evels
3-6.
obtained during testing do not represent
equilibriu~ conditions~and do not indicate that long-term operation

under
these
conditions
would
be feasible.
eDue to problems with the operation of the FCCunit which predated the
test.
50 teductlon
catalyst
addition
was terminated
desired fevel of emission reduction was achieved.

f Unit was operated
in the partial
CO combustion mode.
before
the
This ~ay have
affected the 50 reduction capabilities of the SOxreduction catalyst

being evaluatedl
4-47
In someinstances, emissions of oxides of nitrogen iNOx)have

increased
two to seven.fold
when operating
the sulfur
oxides
reduction
catalysts
at highsulfuroxides
reducrion
levels.98
Ilhen
NOx
8nissi~ns
iJere controlled
by altering
the catalyst,
problems with rapid deactivation
of catalyst sulfur oxides retention capabilityl05andyield debits

(reductions
in product quantity and quality)
oxides emissions
sulfur
oxides
data from FCC units
reduction
catalysts
were encountered.
Nitrogen
operating with and without
were obtained
in order
the
to evaluate
NOxemissions increases due to the use of the catalysts. Ananalysis

of these data showedthat NOxemissions increases resulting fromuse
of these
catalysts
are
not
signficant.
However,
CO promoted
conventional
regenerationFCCunits appearto havehigh NOxemissionswithout

sulfur oxidesreductioncatalysts, and evenhigherNOxemissionswith
sulfur
is
oxides reduction
unknown
due
to
the
catalysts.
limited
The significance
number
for
catalyst emissiontests performed.ll3
4-48
sulfur
oxides
of this
increase
reduction
4.6
1.
2.
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November 1979. p. 1-5. Docket Reference
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Number II-A-10.'
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and Attachments
from Murphy, J.R.,
to Farmer, J.R., U.S. Environmental Protection

1981. Comment on BID Volume I, Chapters 3-6.
Number
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3.
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4.
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3-6.
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Telecon.
Reference
Number
Sorrentino,
C.,
Mands, M. Pacific
1980.
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7.
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1981.
4.
6.
p. 2-3.
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Number
and Development
Services,
of FCC~ operation
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and format
with
October 28,
of standard.
Docket
~I-E-6~.*
and Attachments
Farmer, J.R.,
Amoco Research
Environmental
Discussion
p.
II-B-12.,
from Flynn,
U.S. Environmental
J.P.,
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Agency.
to
May 8, 1981.
II-0-50.*
8.
Babcock and 5lilcox.

New York, New York.
Number
9.
10.
Steam,
1975.
Its Generation
and ~se.
38th Edition.
pp. 5-11, 5-15.
Docket Reference
11-1-15."
Supplement No. 8 for Compilation of Air Pollutant Emission Factors

3rd Edition, (Including Supplements 1-7).
U.S. Environmental
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P.,
Pacific
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Services,
Inc., to Docket Number A-79-09. April 22, 1982. Comparison of

Theoretical Flue Gas Composition for an ;CC Unit Regenerator and
a Coal-Fired
Boiler
Unit.
Number II-B-21.*
11.
Reference 1.
12.
Mands, M., Pacific Environmental Services,

Inc. Trip Report.
Ex'xon Comp~ny, U.S.A., Baton Rouge, Louisiana.
July 24, 1980.
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Reference
p. 2-55.
Docket Reference
Number
II-B-10.*
4-49
13.
Cunic,
J.D.,
S.A.
Diamond,
P.E.
Reeder,
and I.M. Williams.
FCC
Stack Scrubbers Do Double Duty. The Oil and Gas Journal.
May 22,
14.
15.
1978.
Docket
Reference
76(23):72.
Number TI-1-42.*
Cantrell,
Ailleen.
Annual Refining Survey. Oil and Gas Journal.
78(12):130-157.
March 24, 1980. Docket Reference Number 11-1-71."
Letter
and Attachments
from Westphal,
F.A.,
Exxon Company, U.S.A.,
to Londres,
E.J.,
New Jersey Bureau of Air Pollution
Control.
February 14, 1979.
Wet scrubber
emission
tests.
Docket Reference
Number
16.
II-D-2.'
Stack Sampling at Champlin Petroleum, Corpus Christi,

Texas, on
October 28-29, 1975. Texas Air Control Board. Austin, Texas.
Account
Number
17.
No. 110-656-2.
November 26,
1975.
Docket
Reference
11-1-22."
Stack Sample at Shell Refinery, Deer Park, Texas, on July 14-15,

1977.
Texas Air Control
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Austin,
Texas.
Account
Reference Number II-I-33.f
No. 112-062-0.
18. Stack Sampling at Shell Oil Company- Odesqa Refinery, Odessa,

Texas, on October 19-20,
Texas.
Account
Number
19.
Texas Air Control

3,
1976.
No. 110-392-0.
Austin,
Reference
16,
Account
No. 113-279-2.
11-1-27.+
Petroleum, Borger, Texas, on June 24,
Texas Air Control

July
Texas.
Number
1975.
Board.
Docket
Ausrtin, Texas.
Reference
Account
Number 11-1-18.'
11-1-9.'
Stack Sampling at Union 76 Refinery, Nederland, Texas, on July 8-9,

1976.
July
Texas Air Control

27,
1976.
Docket
Board.
Reference
Austin,
Texas.
Account No. 114-147-3.
Number 11-1-25."
Stack Sampling at Mobil Oil Corporation Beaumont Refinery on

February 9-10,
Account
24.
Austin,
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Stack Sampling at Exxon Refinery, Baytown, Texas. Texas State

Department of Health.
January 22-26, 1973. Docket Reference
Number
23.
Board.
Docket
Stack Sampling at Phillips

and 25, 1975.
22.
November 8, 1976.
Stack Sampling at Texaco, Inc., Port Arthur, Texas, on November3-4,

1976.
21.
Texas Air Control Board.
II-I-26.f
December
20.
1976.
No. 112-064-6.
1977.
Texas Air Control
No. 109_145-0.
Reference
i.
April
4,
pp. 2-147 to 2-160.
1977.
Board.
Austin,
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Texas.
Number
Number II-A-10."
25. ExxonResearch and Engineering Company. Fluid Catalytic Cracking

Unit Flue Gas Scrubbing.
p.
14.
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Reference
Florham Park, New Jersey.
Number ~I-I-50.+
4-50
March 1979.
26.
Reference 25.
pp.2-3.
27.
Reference 13.
p. 70.
28.
Reference 25.
p. t.
29.
Manda, M., Pacific Environmental Services, Inc. Trip Report:

Marathon Oil Company, Garyville, Louisiana.
September 24, 1980.
Docket
30.
Reference
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Reference
Houston.
Reference
30.
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Docket
Reference
October
Docket Reference
34.
April
Number II-A-16.f
Services.
Baton Rouge, Louisiana.
June 15, 1978.
Services.
Emission Testing
June 20, 1979.
for Exxon Company,
pp. 4-6.
Docket
II-I-60."
Sulfur Dioxide Sampling and Continuous Monitoring at Exxon aaytown

Refinery, Baytown, Texas. Texas A.ir Control Board. Austin,
Texas.
Docket
35.
p. 3.
Number II-I-44.*
Kemron Environmental
Number
1980.)
for Exxon Company. U.S.A., Baton Rouge, Louisiana.
U.S.A., Baton Rouge, Louisiana.

.Reference
28-31,
Number II-A-16.~L~
p. 2.
Kemron Environmental
33.
Docket Reference'Number 11-1-50."
Dickerman, J.C. Applicability of FGDSystems to Industrial

Boilers, EPA-6O0/9-81-019b, Vol. 2, Radian Corporation, Durham,
North Carolina.
(Presented at the PA Symposiun on Flue Gas
1981.
32.
Docket Reference Number II-I-42.f
Number II-B-13."
Desu~furization.
31.
Account No. 07-HG-0232-0.
Reference
Number
January
11, 1979. p. 4.
II-I-48.f
Stack Sampling at Exxdn Refinery,
Baytown, Texas, on September 5-5,
1975.
Texas Air Control
Account number 104-703-5.
Austin, Texas.
November 19, 1975.
Board.
II-I-20.f
36.
Stack Sampling at ExxonRefinery, Baytown, Texas, on April 21-22,

1976.
Account number 104-703-5.
Austin, Texas.
37.
~etter
.June 25, 1976.
and Attachments
Texas Air Control
Board.
from Albaugh,
D., Marathon Oil Company, to
GoodHin, D.R., U.S. Environmental Protection Agency. March 20,

1981. Response to Section 114 information request.
Docket
Reference
38.
Continuous
Number
IT-0-41.*
Sul~ur Dioxide Monitoring
Marathon Oil Company, Garyville,
of a Petroleum
Louisiana.
Refinery,
Emission Measurement
Branch, U.S. Environmental Protection Agency. Research Triangle

Park, North Carolina.
August 5, 1981.
II-A-18.*
4-51
39.
Continuous Emission Monitoring for Industrial

Motors -Corporation
Assembly
Division,
Volume I, System Configuration
Test Period.
Triangle
Number
St:
and Results
North Carolina.
General
Ilissouri.
of the Operational
U.S. Environmental Protection
Park,
Boilers,
Louis,
Agency. Research
June 1980.
Docket Reference
II-A-11."
40. Referencei.
p. 2-153. OocketReferenceNumber
II-A-lO.t
41.
Reference
i.
pp. 2-7 to 2-79.
42.
Reference
1.
p. 2-9.
EPA Industrial
Boiler
43.
Docket Reference
Docket Reference
FGD Survey:
Number TI-A-1O.~C
Number II-A-10."
First
Quarter
1979.
U.S.
Environmental Protection Agency. Research Triangle Park, N.C.

Publication No. EPA-600/7-79-067b. April 1979. pp. 109, 113,
148,
44.
159.
Docket
Evaluation
Reference
Number II-A-8."
of Three 20 M~ Prototype
Processes.
Electric
EPRI FP-713.
Flue Gas Desulfuriration
Power Research Institute.
March 1978.
p. 4-5.
Pale Alto, California.
Docket Reference
Number
11-1-36."
45.
Ref~rence
i.
p. 2-67.
46.
Reference
i.
pp. 2-79 to 2-111.
47.
Reference
1.
pp. 2~161 to 2-171.
48.
Reference
i.
p. 2-84,
49.
Reference
i.
p. 2-164.
50.
Docket Reference
2-93.
Number II-A-lO.f
Docket Reference
Docket Reference
Docket Reference
Docket Reference
Number II-A-lO.f
Number II-A-10.~
Number II-A-10.+
Number II-A-lO.f
Kelly, M.E. and J.C. Dickerman. Current Status of Dry flue Gas
Desuifurization
Systems.
Volume 2, EPA-600/9-81-019b.
Radian
Corporation.
Durham, North Carolina.
(Presented at the EPA
Symposium on Flue Gas Desulfurization.
Houston, Texas.
October 28-31, 1980).

Number
51.
Reference
52.
Reference i.
53.
April 1981.
p. 3.
50.
pp. 3 to 7.
Docket Reference
pp. 2-111 to 2-131.
Fluid Catalytic
Cracking Emission Control by the Wellman-Lordànd
and Constructors.
54.
Docket
Reference
i.
Number II-A-17.+
the Davy Saarberg-Hoelter FGOprocesses.

1981.
Docket Reference
II-A-17.f
Lakeland, Florida.
Reference
p. 2-119.
DavyFlcKeeEngineers
Report No. 1491/0.
Number II-A-14.+
Docket Reference
4-52
Number II-A-lO.f
March
55.
Madenburg, R.S. and R.A. Kurey. Citrate Process Demonstration

Plant - A Progress Report.
In Proceedings:
Symposium an Flue
Gas Desulfurization.
U.S. Environmental
N.C.
Publication
Reference
56.
Hollywood, FL, November1977 (Volume IT).

Protection
Agency.
Research Triangle
Park,
pp. 707-735.
Docket
No. EPA-600/7-78-058b.
Number
II-A-21.*
Control Techniques for Sulfur Oxide Emissions from Stationary

Sources.
U.S. Environmental Protection Agency. Research Triangle
Park,
N.C.
Publication
pp. 4.2-122 to 4.2-132.
No. EPA-450/3-81-004.
April
1981.
Docket Reference NumberII-A-23.*
57. Madenburg,R.S. and T.A. Seesee. H2SReducesS02to Desulfurize

Flue Gas. Chemical Engineering.
Docket
58.
Reference
Farrington,
SO
Number
James and Sue Bengtsson.
Feasibility
Control.
Publication
Docket
60.
Number
Nissen,
Environmental
on citrate
Solution
Absorbs
pp. 88-89.
Docket
of Primary Capper Smelter ~leak Sulfur Dioxide Stream

U.S. Environmental
Protection
No. EPA-600/2-80-152.
July
Reference
Telecon.
Citrate
June 16, 1980.
R~~erenceNumberII-I-93.+
59.
Jlily 14, 1981. Po. 88-89.
II-I-94.+
Bill,
Services,
p. 712.
Bureau of Plines with Meardon, Ken, Pacific

incorporated.
. February
11, 1982.
Reference
62.
Reference 58. p. 88.
63.
Reference
57.
p. 89.
Docket
64.
Reference 58.
p. 88.
Docket Reference
Number 11-1-93."
65.
Reference
59.
p. 163.
Docket Reference
Number II-A-22.1
66.
Reference
58. p. 89.
67.
Reference
59.
68.
Reference 57.
69.
Reference
70.
Reference 58.
p. 89.
Docket Reference Number !I-I-93.f
71.
Reference 57.
p. 88.
Docket Reference
72.
Reference 58.
p. 88.
Docket Reference Number 11-1-93."
p. 89.
57. p. 89.
Docket Reference
Number II-A-21.*
Docket Reference Number II-I-9`3.f

Reference
Docket Reference
Number II-I-94.f
Number IL-I-93.*
Docket Reference Number I1-A-22."

Docket Reference Number 1:-1-94."
Docket Reference Number I!-I-94.f
4-53
Information
Docket Reference Number TI-E-5.+
61.
p. 163.
OH.
fI-A-22.*
scrubber operation.
55.
Agency.
Cincinnati,
1980.
pp. 153-171.
Number 11-1-94.'
73.
Refining Processes Handbook. Hydrocarbon Processing.

September-1980.
74.
75.
Reference
Sulfur
Docket
73.
Reference
pp. 97-134.
Dioxide/Sulfate
Docket
76.
pp. 6.88
to 6.89.
11-1-79."
South Coast
El Monte, California.
Docket
14, 1974.
McCullock, D.C.
Docket
Reference
Reference
Number
Yanik, S.J.,
May
Plumber II-I-40.*
Number II-I-14.*
J.A.
Docket
Ilnproves FCCUPerformance.
73(27):56.
July 21, 1975.
Docket
11-1-19."
Frayer,
G.P. Huling,
Data on Gulf HDSProcess.
May 1977.
Reference
Feed Hydrotreating
The Oil and Gas Journal.

78.
ilunber
Ritter, R.E., J.J. B7azek, and D.N. Wallace. Hydrotreating FCC

Feed Could Be Profitable.
The Oil and Gas Journal.
72(41):102.
October
77.
Reference
Control Study - Main Text.
Air quality ManagementDistrict.

1978.
59:97-98.
Number II-I-79.*
Reference
and A.E. Somers.
Number
II-I-Si."
Latest
56(5):98.
79. Letter and AttachmentsfromSorentino, C., Amoco

Oil Company,
to
Ilanda, M., Pacific Environmental Services,
1980.
Responses to request
Reference
80.
Number
Huling,
G.P.,J.D.
Docket
data.
October 15,
Docket
II-D-28.,
McKinney, and T.C. Readal.
in FCCProduct. The Oil and Gas Journal.
1975.
Incorporated.
for FCC operations
Reference
Number
II-I-17.I
Feed Su7fur Distribution
73(18):73. May19,
81. Manda,Pi., Pacific Environmental

Services, Inc. Trip Report:
Shell Oil Company, Housfon, Texas;
Number
82.
July 23, 1980.
Docket Reference
II-B-9.+
Manda, M., Pacific Environmental Services, Inc. Trip Report:

Chevron U.S.A., Incorporated, Richmond, California.
April 3,
1980.
Docket
Reference
Number II-B-3.f
83.
Reference
73.
p. 114.
Docket Number 11-1-79."
84.
Reference
73.
p. 108.
Docket Number II-I-79.*
85. Letter from Sorrentino, C., AmocoOil, to J. Farmer, EPA. January 3,

1981.
86.
114 Response.
Docket
Reference
HDSFCCEquals More Gasoline.

May 17, 1976.
Docket
87.
Reference
p, 99.
88.
Reference 78.
pp. 100-101.
89.
Reference
p. 99.
78.
76.
Number II-D-54.,
Reference
p. 115.
Number
Docket Reference
Flumber II-I-31.I
Docket Reference Number II-I-31.*
Docket Reference
4-54
Plumber II-I-14.f
90.
Reference 70.
p. 97.
91.
Aalund, L.R., Sour Crude Technology Set for the 80's.
and Gas Journal.

Number
The Oil
78(12):78. March24, 1980. DocketReference
II-I-73.f
92.
Reference 73.
p. 97-144.
93.
Reference
p. 107.
94.
Vasalos, I.A., E.R. Strong, C.K.R. Hsieh, and G.3. D'Souta.

New.
Cracking Process Controls FCCUsulfur oxides.
The Oil and Gas
Journal.
75(25):142,
June 27, 1977. Docket Reference Number
73.

II-r-32.~*
95.
Magee, J.S., Ritter, R.E., et.a~.

HowCat Cracker Feed Co~positio~
Affects Catalyst Octane Performance. National Petroleum Refiners
Association Paper AM-80-48. !Presented at the 1980 NPRAAnnual
Meeting.) March 23-25, 1980. p. 4. Docket Reference Flumber
11-1-70."
96.
Magee, J.S. and Ritter,

Catalyst
Technology.
R.E.
Recent Advances in Fluid Cracking
National
Petroleum Refiners
Association
Paper AM-79-35. (Presented at the 1979 NPRA

AnnualMeeting.)
March 25-27, 1979.
97.
p. i.
Docket Reference
Number II-I-54.f
Fluid Catalytic Cracking with Molecular Sieve Catalysts.

Petro/
ChemEngineering. 41(5):15.. May 1969. Docket Reference Number
II-Z-2.f
98.'
Reference 95.
99.
Magee, J.S., Ritter, R.E., and Rheaume, L. A Look at FCCCatalyst

Advances. Hydrocarbon Processing. 58(9) :128. ~September1979.
Docket
100. Shields,
p. 5.
Reference
R.J.,
Number
Fahrig,
II-I-64.*
R.J.,
and Horecky, C.J.
Technique Improved. The Oi~ and Gas Journal.

1972.
101. Letter
Docket
Reference
Number 11-1-7.'
and Attachments
from Grossberg,
FCC Regeneration
70( 22) :45.
May 29,
A.L., Chevron Research
Company,to Farmer, J.R., U.S. Environmental Protection Agency.

May 4, 1981. Commentson BID Volume I, Chapters 3-6. Docket
Reference
Number
II-D-47.'
102. Murcia, A.A., M. Soudek, G.P. Quinn, and G.J. D'Souza.
Design Criteria
for Processing Flexibility.
FCCo
National Petroleum
Refiners Association Paper AM-79-38. (Presented at the 1980 NPRA

Annual Meeting.)
March 25-27, 1979. Docket Reference ~lumber
11-1-53."
103. Reference 102.
p. 8.
4-55
104. Letter from D.P. Martin, Gulf Oil Company,~toG. Sernstein,

Pacific
Environmehtal
Services,
Incorpbrated.
Information
unit feed sulfur contents,~coke make rates,

~ovenber
17,
1980.
Docket
Reference
on FCC
and recycle.
Number IT-D-33.*
105. Manda,M., pacific Environmental Services, Inc. Trip Report:

Standard Oil of Indiana (ACIOCO),
Chicago, Illinois.
April 1,
1980.
Docket
Reference
Number II-B-l.*
106. Telecon. Beyaert, B., ChevronU.S.A., Incorporated, with ~anda, G.

Pacific Environmental Services, Incorporated. November21, 1980.
Chevron's commercial sulfur oxides Catalysts.
Number
Docket Reference
ZI-E-3.f
107. Manda,M., Pacific Environmental Services, Inc. Trip Report:

Atlantic Richfield Petroleum Products Company,Harvey, Illinois.
April
2,
1980.
Docket
Reference
Number II-B-2.,
108. Letter and Attachments from Buffalow, O.T., ChevronU.S.A.,
Incorporated,
to Goodwin, D.R., U.S. Environmental Protection
Agency. June 29, 1981. Response to Section 114 infor7lation
request.
Docket
Reference
Number
II-D-57.*
109. ChevronResearch Company. Catalyst for RemovingSulfur from a

Gas.
United States Patent No. 4,152,`298.
Reference
Number
110. Johnson, J.M.
II-I-58.+
Presentation
May1, 1979. Docket
at the NAPCTAt
Meeting on Behalf of
the American Petroleum Institute.
In: National
Air Pollution
Control Techniques Advisory Committee,Minutes of Meeting, Decenber 1

and 2, 1981. U.S. Environmental Protection Agency, Research
Triangle Park, North Carolina. December 22, 1981. p. II-19.
Docket
Reference
Number
II-B-18.*
Ill. National Air Pollution Control Techniques Advisory Committee,

Minutes of r~leeting, December 1 and 2, 1981. U.S. Environmental
Protection Agency. Research Triangle Park, North Carolina.
December 22, 1981. p. 11-51.
Docket Reference NumberII-B-18."
112. Memorandum
from Bernstein, G., Pacific Environmental Services,
Inc., to Docket NumberA-79-09. April 28, 1982. Results of

Analyses of Commercial Tests of Developmental Sulfur Oxides
Reduction Catalyst Performance. Docket Reference ~lumberII-B-25.*
113. Memorandum
fromBernstein, C., Pacific EnvironmentalServices,
Inc., to DocketNumber
A-79-09. May21, 1982. Results of Analysis
of NO, Emissio.nsStudy. Docket Reference NumberII-B-20.+
114. Memorandumfrom McDonald, R., U.S. Environmental
Agency, to Docket NumberA-79-09.
Protection
March 23, 1982. Sulfur Oxides
and Nitrogen Oxides Related to Catalytic Cracking of Hydrodesulfurized

Gas Oil.
Docket
Reference
Number II-B-19.f
4-56
115. Letter
and attachments
from Gill,
W., Texas Air Control
Board,
to
Rhoads, T.W., Pacific Environmental Services, Inc. December 15,

1981. Compliance Test for the Southwestern Refining Company FCC
Unit.
Docket
Reference
Number
II-D-85."
116. Questions and Answers on Refining Technology; Transcription

of
NPRA98~ Synposia, 1975-1979 and Comprehensive Five-year Index.
National
Petroleum
p. 79-69.
*References
can
Refiners
Docket Reference
be located
Association.
Washington,
D.C.
Number II-I-109."
in Docket
Number
A-79-09
at
the
U.S.
Environmental Protection Agency Library, Waterside Mall, Washington, D.C.
4-57
5.0
In accordance
MODIFICATION AND RECONSTRUCTION
with the provisions
Federal Regulations
(CFR), Sections
of Title
40 of the ~tode of
60.14 and 60.15,
an existing
facility can become dn affected facility and, consequently, subject to

the standards of perfon~nance if it is modified or reconstructed.
An
"existing facility,"
defined in 40 CFR60.2, is a facility of the type
for which a standard
or modification
of performance
is promulgated
of which was commenced prior
and the construction
to the
proposal
date
of
the applicable standards.

The following discussion examines the
applicabi~ity of modification/reconstruction
provisions to the fluid
catalytic
5.1
cracking
unit
regenerator.
GENERALDISCUSSION OF MODIFICATIONAND RECONSTRUCTION

PROVISIONS
5.1.1
Modification
Modification
is defined
in960.14
change to an existing facility
not be considered
emission
rate.
i.
Routine
2.
An increase
expenditure
In the
as defined
Use of an alternative
function
is the
repair,
in the
and replacement,
production
in the hours
proposal of the standard,
rate
not
requiring
a capital
of operation,
fuel
or raw material
the existing
alternative
The addition
of any changes
in ~60.2,
4.
that
irrespective
which will
include:
maintenance,
An increase
5.
exceptions to this definition
changes
3.
accommodate
to which the standard'applies.
modifications,
these
or operational
which results in an Increase in the
emission rate of the pollutant(s)
Paragraph (e) of 460.14 lists
as any physical
fuel
facility
of air
prior
to
was designed to
or raw material,
or use of any system
reduction
if,
pollutants,
or device
whose primary
except
when an emission
control system, is removed or replaced by a system considered to be

less
environmentally
beneficial,
5-1
6. fhe relocation or change in ownership of an existing facility.

As stated in paragraph (b), emission factors, material balances,
continuous
monitoring
systems,
or manual emission
tests
are to be used
to determine emission rates expressed as kg/hr of pollutant.
Paragraph (c)
affirms that the addition of an affected facility
to a stationary
source through any mechanism -- new conrtruction,
modification,
or
reconstruction -- does not makeany other facility within the stationary

source subject to standards of performance. Paragraph (f) provides
for superseding any conflicting provisions. And, (g) stipulates that
compliance be achieved within 180 days of the completion of any modification.
5.1.2
Reconstruction
Under the provisions of 960.15, an existing facility
becomes an
affected facility upon reconstruction, irrespective of any change in

emission rate.
Reconstruction
is the replacement of components of an
existing facility to such an extent that: (1) the fixed capital cost
of the new componentsexceeds 50 percent of the fixed capital cost
that wouldbe required to construct a comparableentirely newfacility,

and (2) it is technologically and economically feasible to meet the
applicable standards of performance. Whenthe replacementof components

of an existing facility
meets the cost criterion for reconstruction,
the Administrator of the EPAshall determine whether the replacement

constitutes
determination
reconstruction.
of reconstruction
As stat~d in 960.15(f), the Administrator's

will
be based on:
(1) The fixed capital cost of the replacementsin comparisonto
the fixed capital
cost that would be required to construct
comparablenewfacility;
(2) the estimated life of the facility
after the replacements comparedto the life of a comparable

entirely new facility; (3) the extent to which the components
being replaced cause or contribute
to the emissions from the
facility; and (4) any economicor technical limitations on compliance
with applicable
t~e
proposed
standards
of performance
which are inherent
in
replacements.
The purpose of the reconstruction
provision is to ensure that an
ownerOr operator does not perpetuate an existing facility by replacing
all but minorcomponents,

supportstructures, frames, housing,etc.,
rather than totally replacing it in order to avoid being subject to
applicable per~ormancestandards. In accordancewith 960.5, EPAwill,

upon request,
determine
if an action
5-2
taken constitutes
reconstruction.
5.2
APPLICABILITY OF MODIFICATIONPRO\IISIONS TO FCC REGENERAfORS

Several
encountered
presented
changes,
either
physical
or operational,
while expanding or moderniting
that
an existing
below along with the anticipated
effect
could be
FCC unit
on sulfur
are
oxides
emissions.
5.2.1
Maintenance, Repair, and Replacement

Maintenance,
considered
in
sulfur
repair,
routine
oxides
~60.14(e)(l).
to occur
for
and component
a source
emissions
are
~Anincrease
as a result
regenerator
necess
category
not
irrespective
considered
modifications
maintenance
under
is not expected
or replacement
of FCC
usually
repair,
operates
or replacement
for 2 to 6 years continuously

of internal
components
is
1,2 After this time, the unit is shut dawnandourged so
ary.
that the regenerator can be inspected for wear.

a turnaround.
maintenance
surfaces
of any changes
components.
maintenance,
called
which are
in su'lfur oxides emissions
of normal
The FCC regenerator

before
replacement
During
or repairs
by catalyst
This procedure is
the 2 to 4 week turnaround
may be required
particles
period,
due to the erosion
or to the build-up
routine
of internal
of coke deposits
an
certain components.3
Routinemaintenance
or repair performed
during
an FCC unit regenerator turnaround may include inspecting and, if
necessary, repairing the air distribution
system, standpipe, slide
valves, plenum chamber, catalyst
overflow weir, and regenerator grid
and seals.
The regenerator refractory
lining is also inspected for
wearandpatched,if necessary.4Routinemaintenance
andrepair of
the
FCC regenerator
effect
on
sulfur
would normally
oxides
FCC'unit regenerator
replacement
be expected
to decrease
or have no
emissions.
internal
components may require
due to excessive
erosion
For example, the regenerator
internal
or corrosion
periodic
of internal
surfaces.
cyclones may be replaced
after
typicalservicelife of 10years.3 If the cyclones

are replaced
with
equivalent cyclones, particulate
emissions usually decrease
increased catalyst capture efficiency
of the new cyclones.
due to the
However,
the new cyclones are not expected toaffect

sulfur oxides emissions
fra~ the FCCunit regenerator.
Cycl.one replacement may contribute
to
the
cost
of
reconstruction.
This
is
5-3
discussed
in Section
5.3.
5.2.2
Increasing Capacity
An increase
in capacity
is not considered
a modification
under
~960.14 if the increase can, be accomplished without incurring a capital

expenditure
on the existing
facility.
A capital
expenditure
is defined
as "an expenditure for a physical or operational change to an existing

facility
which exceeds the product of the applicable
guideline
repair
allowance
percentage'
specified
'annual asset
in the latest
edition
of Internal RevenueService Publication 534 and the existing facilit~''s

basis, as defined by Section 1012 of the Internal RevenueCode" (40 CFR,
960.2).
A refiner maydecide to i.ncrease the capacity of an existing FCC

unit to improve the yield pattern of certain products, meet product
demands, and increase profitability.
FCCunit capacity may be increased
by incrcasfng the regenerator combustion air flow rate, increasing the

regenerator
internal
pressure,
or throughoxygen
enrichment
of the
regeneratorcombustion
air,5 Thesechangesmaybe achievedwithouta
capital
expenditure as defined by Section 1012 of the Internal
Revenue
Code.
In c7anycases FCCunit capacity is determined by the quantity of
coke whichcan be burnedoff within the regenerator. A common

technique
employed by a refiner to increase FCCunit capacity is to install an
additional blower to the unit's air distribution system. The additional
blower increases
the.catalyst
the quantity
bed and increases
allows more catalyst

quantity
of combustion
catalyst
cake burn-off
to be fed to the riser
of fresh feed that
air which moves throuah
can be processed.
rate.
This
reactor and increases the

An alternate
means of
increasing regenerator coke burn-off capacity is through oxygen enric~ment
of the regeneratorcombustion
air,5 Theincreasedcokeburn-off rate
may result
in an increase
in sulfur
oxides emissions.
The increased
air flow rate requirles increased gas handling capacity in the regenerator
cyclones and more downstreamflue gas handling equipment, such as
coolers
and precipitators.
FCCunit fresh feed capacitymay be increased by reducing the

coke make rate especially when the unit is airblower limited, or by
reducing
the amount of tecycle
oils
processed
in the unit.
The coke
make rate can be reduced by processing high quality feedstocks or by

5-4
hydrotreating.
Catalyst
conversion
all
eliminated
through catalyst
alternate
reduce
selection,
thecoke
use of recycle
unit.
improved regeneration,
make rate.
selection,
oi~s
Recycle
increased
instead
fresh
feed
capacity
pressure.
similar
regenerator
into
or through
the
FCC
to increase
FCC unit
by increasing
the
rate.
increase
in sulfur
The increased
by modifying
replacement,
may install
from the
allows
rate
emissions.
Regenerator
the compression
equipment
addition
existing
thin internal
the catalyst
are
air
coke
may result
in an
internal
pressure
through
of a booster
compressor.
liners
pressure
more combustion
and increases
coke burn-off
or through
internal
regenerator
combustion air flow rate.
pressure
the catalyst
oxides
increased
regenerator
internal
with
burn-off
or downstream
be increased
of the
of increasing
to come in contact
increased
can also
The results
to that
The increased
blade
conversion,
or
capacity.
FCC unit
internal
nay be reduce~
of reinjection
These changes would allow the refiner
and decreased
rotor
compressor
In addition,a
in the regenerator
is
or
upstream
refiner
to reduce the
metaltemperature
of the shell.6
5.2.3
Increase
in Hours of Operation
An increase
increase
in emissions
in the hours
from an existing
of operation
under 960.14(e)(3).
FCC units
365 days per year.
An exception
for maintenance.
of operation
5.2.4
is unlikely
of their
FCC units.
Change in FCC Feedstock

Changes
sulfur
feed,
sulfur
crude
content
in FCC feedstock
feeds,
supply
on average,
to this
that
due to an
a ~odification
24 hours per day,
is when the unit
refiners
or product
down
the hours
quality
quality,
in recycle
emissions
is shut
would alter
such as a change to higher
a change to a higher contaminant
or an increase
oxides
is not considered
operate,
It
facility
from the
rate,
may result
FCC unit'
metals content
in an increase
regenerator.
demand may necessitate
Changes
a change
in
in the
in feedstdck
quality.
A change to a higher sulfur content feed may not only increase
regenerator sulfur oxides emissions, but also result in corrosion of
certain
levels
regenerator
present
internal
components
in the gases contained
5-5
due to the
within
higher
sulfur
the regenerator.
change in sulfur oxides emissions whichresults
from a change in
feedstock quality is not considered a modification provided the existing

facility
was designed
to accommodate
that
feedstock.
For a specific feedstock and unit throughput, hydrodesulfurization

will decrease the sulfur oxides emissions from the FCCunit regenerator.
In general, HDScan remove the sulfur from high sulfur feeds and
decreasesulfur oxidesemissionsfromthe regenerator.7However,

HDS
can also increase the yields of certain
desirable
products and ir,iprove
overall feedcrackingcharacteristics.8 Thismayenablea refiner to

increase
unit capacity
regenerator
sulfur
or process
oxides
higher
sutfur
feeds and thus increase
emissions.
5.2.5 Addition, Removal,or Disabling of a Systemto Control Air

Pollutants
The addition or use of any system or device whose primary function

is to reduce air pollutants,
qr device by a less
under
efficient
one, is not considered
a modification
960.14.
The intentional
removal or disabling
component of an existing
increase
5.3
except the replacement of such a system
in sulfur
FCC unit
oxides
of any emission central
regenerator
emissions
which would cause an
would be a modification.
APPLICABfLITYOF PECONSTRUCTION
PROVISIONSTO FCC REGENERATORS
FCCunits operate for long periods of time without major servicing.

Manyunits installed in the early 1940's are still operational.
There
are only a few expansions or modernizations to the FCCregenerator
which may contribute
5.3.1
to the
cost
of reconstruction.
Conversion to High Temperature Regeneration

An action
unit regenerator
that might be considered
as a reconstruction
of the FCC
is the conversion to high temperature regeneration
(HTR). HTRrevampingof an FCCregenerator generally requires the

replacement of cyclones, the plenumchamber, cyclone diplegs, the
regenerator
grid and seals,
components
must be constructed
and the catalyst

from stainless
overf7ow weir.
steel
rather
These
than
carbon
steel in orderto withstandthe highertemperatures.9It is possible

that an HTRrevamp may exceed 50 percent of the capital
an entirely
new F%Cunit regenerator.
5-6
cost to construct
5.3.2 Additionor Replacementof RegeneratorCombustion

Air S~ower,
Cyclones, or Other ~e4enerator Internal Components
A~though the addition or replacement of regenerator combustion
air blowers, internal cyclones, or other internal components was discussed. in Sections 5.2.; and 5.2.2 under ~odification, this activity
maycontribute to the reconstruction of an FCCunit regenerator.

cost of a ma:or turnaround may exceed 50 percent of the capital
of a new FCC regenerator.
5-7
The
cost
5..4
REFERENCES
1. Fluid Cata-lytic Crackingwith Molecular Sieve Catalysts.

Che~ Engineering.
41:12.
May 1969.
Petro/
11-1-2."
2.
Luckenback, E.C. Howto Update A Catalytic Cracking Unit.

Chemical Engineering Progress. 75:56. February 1979. Docket
Reference
Number
II-I-49."
3. Mands,M.L., Pacific EnvironmentalServices, Inc. Trip Report:

Conoco, Incorporated, Ponca City, Oklahoma. August 14, 1980.
Docket
Reference
Number II-B-1~."
4. Mands, M.L., Pacific Environmental Services, Inc.
Trip Report:
Oklahwna
AefiningCompany.Oklahoma
City, Oltlahoma.August13,
1980.
Docket Reference
Number II-8-11.*
5. Macerate, F. and S. Anderson. O EnrichmentCanStep UpFCC

Oil
Output.
Docket
6.
and
Reference
Gas Journal.
9):101-106.
Number 11-1-88."
Reference 2, p. 58.
~arch
2,
1981.
Docket Reference Number II-I-49.~
7. Ritter, R.E., J.J. 8lazek, and D.N. Wallace. Hydrotreating FCC

Feed Could be Profitable.
October 14, 1974.
72(41):99-100,
Docket Reference Number II-I-1~::
8. Screening Study to Determine Need for SO and HydrocarbonNSPS
for FCCRegenerators. U.S. Environmenta~

Protection Agency.
Research Triangle Park, N.C. Publication No. EPA-450/3-77-046.
August 1976.
9.
Reference
p. 54.
8, p. 21.
Docket Reference
Docket Reference
Number II-A-2.f
Number II-A-2.*
"References can be located in Docket NumberA-79-09 at the U.S.
Environmental
Prptection AgencyLibrary, Waterside~all, Washington,D.C.
5-8
6.0
MODELPLANTS AND REGULATORY

ALTERNATIVES
The purpose of this chapter is to define model plantr and identify
regu'latory alternatives.
Model plants are parametric descriptions bf
types of plants that, in EPA's judgment, will be constructed, modified,
or reconstructed.
The model plant
parameters
are used as a basis
for
estimating the environnental, economic, and energy impacts associated

with the application of regulatory alternatives
to the model plants.
6.1
MODEL PLANTS
Each FCC unit

technical
and, hence,
standpoint.
each regenerator
FCC unit
types
is unique from a
and sizes,
flow rates,
feedstock
quality, regeneration mode, recycle rates,. air flow rates, and emission
rates vary from one unit to another.
For this reason, no single model
plant can adequately characterize the FCCunits.

model FCC units
were specified
in terms of some appropriate
to span the range of anticipated

flow
rates,
Table
and
total
FCCunit sizes,
parameters
feedstock quality,
emissions;
6-1 lists
energy, cost,
Accordingly, several
model
FCC unit
parameters
used
in the environmental,
and economic analyses of the regulatory
of six model
FCC units
alternatives.
Model FCC units
have been selected.
A
are
based primarily on FCCunit capacity and on the sulfur content of the

regenerator flue gas. Two different flue gas flow rates and three
different
typical
flue
gas sulfur
literature,
Model unit
historical
FCC units
concentrations
were chosen to represent
ranges of processing capacity and feed sulfur.
The selection
selected
oxides
of model
information
FCC unit
obtained
parameters
during
plant
is based
visits,
on published
and calculations.
capacities
are identified
on the basis of current and
FCC construction,
as described in Appendix E. The two
capacities,
2,500 m /sd and 8,000 m /sd,
which are presently
being constructed
6-1
are representative
orwhich
have been
of
Table 6-1.
_
Exhal~stGas Coclll,ositiona~~dFlou Rates
Sulfur Oxides'
PartlculdLed
FCC
fresl~
Feed
Capacity
MODELFCC UNIT PARAMETERSa
Feed
Recycle
Rate
Sulfur
Content
Coke
8urn-off
Rateb
Air
Enlssions
Ellli
ssions
(Lg/103Lrg---~T;O-J~
Flow
Rate
Coke
Coke
(,n3/5d) (~lltq) (tglllT)(SIW3llllin)

(vppm)Burn-off)
2,500
8.000
375
1.200
Exhaust
GasTem-
Content
peraturee
(ky/hr)
Burn-off)
(vol. X)
("C)
1).0
47
10
0.05
200
0.3
4.102
954
1.5
4.615
944 1,440
46.0
46
10
0.05
200
3.5
4.546
934 2, 700
00.0
45
10
0.05
2(H)
0.3
15.064
13.0
150
10
0.05
200
1.5
14,885 3;030 1.400
46.0
149
10
0.05
200
3.5
14.562
88.0
146
)O
0.05
200
3.056
400
Carbon
Ilonox
ide
400
2.991
2.700
~A~slanes
5 wt. percentcokeyield,a cokecckllpositian
of 4 welg)lt
perce~,t
hydrolJell. coke slllfur content fra~l Figure 3-5, and the
balal,cecarbon. 2 percent excess oxyge~l

in flue gas, alld500vppmCOi~lflue cJas.
Calculationsbasedon coke burn-off foniiulain 40 CFR60.102,March8. 1974.
Sul~ur
cial.;.;;
i:!,issiuns
reportedas 502
d0ack
calclllale~l
~run
cotltrollcd
outletanission
rateof1tg/lOHO
kgcake
bul.n-o~f,
drslllnillg
90percent
control.
eAfter heat recovery.
constructed
current
in the last
10 years.
Recycle
U.S. average FCC recycle
rates
capacity
are based
on the
of approximately
15 percent
of the fresh feed.l

Air
flow
described
rates
and
in Chapter 3.
Bnissions
Coke yield
of the fresh
feed.
Coke sulfur
the
sulfur
content
FCC feed
sulfur
and coke sulfur
FCC unit
sulfur
emissions
oxides
are
calculated
are
and by using
3-5).
enissi~ons
identified
the
and high su~fur
feeds,
methods
by specifying
correlation
between
This correlation
are representative
for many common FCC feedstocks.
1.5, and 3.5 weight percent
the
is assumed to be 5 weight percent
levels
(Figure
by using
and thus model'

of actual
Feed sulfur
are representative
feed
FCC unit
levels
of 0.3,
of low, intermediate,
respective?y.
The regenerator
flue gas excess oxygen is assumed to be two
volume percent and the carbon nonoxide concentration
is assumed to be
500 vppm. These values are consistent
with current technologies
for
meeting the carbon nonoxide emission
su7fur
oxides
monoxide
emissions
combustion
feeds yield
furnaces
regenerator
requirements.
which would result

firing
fluegas
13 kg/1,000 kg coke burn-off,
Excluding the
from FCC units
sulfur-containing
sulfur
with
fuel,
carbon
the
oxides concentrations
three
of
46 kg/1,~00 kg coke burnloff,
and
88 kg/1,000 kg coke burn~off. These correspond to regenerator flue

gas sulfur oxides concentrations of 400 vppm, 1,400 vppm, and 2,700 vppm,
respectively.
are dependent
These emissions
only on feed
are calculated
sulfur
content.
as sulfur
Changes
dioxide
and
in coke yield
from
4.0 to 6.5 and greater weight percent of fresh feed do not result in
significant
variations
in sulfur oxides emissions when reported as
kg/1,000 kg coke burn~off or as vppm. Thus, sulfur oxides emissions
reported
as kg/1,000 kg coke burn-off
the
yield.
coke
Emissions
nitrogen
6.2
pollutants
oxides are discussed
a minor portion
specified
of other
of the total
or in vppm are independent
Including
cyanides,
in Chapter 3.
FCC regenerator
as part of the model unit
of
ammonia, and
Since these emissions

emissions,
they
are
are not
emissions.
REGULATORYALTERNATIVES
Regulato~iy alternatives
be taken
to reduce
emissions
arepossible
from a source.
6-3
courses
of action
In this
case,
that
could
regulatory
alternatives identify sulfur oxides emission leve.ls which FCCregenerators

could achieve-by using demonstrated control technologies.
As discussed
in Chapter 4, FCCsulfur oxides emissions may he reduced by using flue

gas desulfurization
(FGD)or sulfur oxides reduction catalysts.
These
control technologies form the bases for the emission levels defined by
the regulatory alternatives.
Hydrodesulf~Jrization is a process used
by refiners to improveproduct quality and yields.

of hydrodesul furization,
it is expected that
refiners
Due to the expense

will
install
these process units primarily for yield and quality improvements

rather than sulfur oxides control.
Therefore, hydrodesulfurizatian
is
not considered as a control technology for this analysis.

To assess the environmental, energy, and economic impacts of
using FGDor sulfur oxides reduction catalysts to meet the regulatory

alternatives,
the affects
of these control technologies on the FCC
unit and its operation must be known. The impacts of using FGDare
easily quantified due to the large body of literature
on this subject.
Also, sodiurn-basedFGDsystems have been installed on FCCregenerator

flue gas streams, and they do not impact unit operations or product yields.
Sulfur oxides reduction catalysts are an emergingtechnology
which have not been used in long-term commercial operations.
Their
effects on product yield, sulfur plant operation, and emissions have
not been completely determined.
Impact analyses for this
technology may thus contain significant
uncertainties.
control
To reduce the uncertainty involved in calculating the impacts of

each model plant and~regulatory alternative combination, the impacts
will be evaluated based on the use of sodium-based FGDsystems alone
to meet the regulatory alternatives.
Although the emission levels for
the regulatory
alternatives
are based on the performance of sulfur
oxides reduction catalysts and flue gas desulfurization,

impacts are
evaluated by assuming that the FGDsystem reduces model plant sulfur
oxides omissions to the levels defined by the regulatory alternatives.
These levels of scrubbing represent the amountby which model plant

sulfur oxides emissions must be reduced to meet each regulatory
alternative.
Four regulatory
alternatives
have been selected.
These are
illustrated graphically in Figure 6-1. iach regulatory alternative,

6-4
100,
13.000
90
80
70 1-
60 I-
Alterllative
2,009
(Baseline)
50
40
1,000
g00
30
800
I
0
0
'E
rY
WO
~S
a\
Ln
oc ~
-I
700
600
20
500
AlternativPII 13 k 1.000k coke burn-off)
400
Rlternatlve 1I1 (9.B kg/1.000tg coke burn-off!
399
io
0.9
7.0
AlternativeIV(6.5 kg/1,000kg cokeborn-off)
200
C/
1-
-1
v,
5.0
4.0
3.0
O~
0.0
6.0
,E
~P
100
90
80
70
60
2.0
50
so
I.ol
--~----
Sulfur Content of Fresh Feed (weight percent)
Figure 6-1. RegulatoryAlternatives
its technological
following
basis,
and level of scrubbing is discussed in the
sections.
6.2.1 RegulatoryAlternative i - The Baseline Level

Baseline
control
is defined
as the level
of emission
reduction
currently achieved by an industry and is typically dictated by State

or local regulations.
As discussed in Chapter 3, the baseline level
represents the level of control required for existing FCCunits to be
in compliancewith most State and local sulfur oxides regulations.

The baseline level (Alternative I) is illustrated in Figure 6-1.
Baseline sulfur oxides emi.ssions range from 13 to 88 kg/1,000 kg coke
burn-off (400 to 2,700 vppm) for commonlyused FCCfeedstocks of0.3
to 3.5 weight percent
6.2.2
sulfur,
Regulatory
Alternative
respectively.
II
ZI would require
that
sulfur
oxides
emissions from FCCunits be limited to 13 kg sulfur oxides/1,000 kg

coke burn-off (400 vppm). The equivalent levels of scrubbing required
to meet Regulatory Alternative II are: 85 percent for.the 3.5 weight
percent sulfur feedstock model units to reduce flue gas sulfur oxides
content from 88 to 13 kg/1,000 kg coke burn-off (2,700 to 400 vppm),

71 percent for the 1.5 weight percent sulfur feedstock model units to
reduce flue gas sulfur oxides content from 46 to 13 kg/1,000 kg coke

burn-off (1.400 to 400 vppm), and little or no scrubbing for the
0. 3 weight percent sulfur feedstock model units whose baseline sulfur
oxide emissions are 13 kg/1,000 kg coke burn-off (400 vpp~). The
economic,
environmental,
andenergyimpactsfor Regulatory
AlternativeTI
will be determined based on these levels of scrubbing.
Thebasis for this alternative is to allow refiners an opportunity

to use sulfur oxides reduction catalysts to meet this regulatory
alternative.
Dependinguponthe sulfur levels of FCCunit feeds
charged to their
units,
~ost refiners
will
be able to utilize
the
sulfur oxides reduction catalyst technology, while a few may use flue
gas desulfurization. The emerging sulfur oxides reduction catalyst
technology can be used to meet Regulatory Alternative I'I when feeds up
to approximately 2.3 weight percent sulfur are charged to the FCC
unit.
6-6
6.2.3
III
IIIwould
require that sulfur oxides
emissions from FCC units be limited to 9.8 kg sulfur oxides/1,000
coke burn-off
(300 vppm).
The levels
Regulatory Alternative ITI are:

sulfur
feedstock
model units
of scrubbing
required
kg
to meet
89 percent for the 3.5~weight percent
to reduce
flue
gas sulfur
oxides
content
from 88 to 9.8 kg/1,000 kg coke burn-off (2,700 to 300 vppm), 79 percent

for the 1.5 weight percent sulfur feedstock model units to reduce flue
gas sulfur oxides content from 46 to 9.8 kg/1,000 kg coke burn-off

(1,400 to 300 vppm),.and 25 percent for the 0.3 weight percent sulfur
model units
to reduce--flue
gas sulfur
9.8 kg/1,000 kg coke burn-off

and environmental
based
on these
As with
Alternative
II,
the
an opportunity
basis
the
sulfur
Alternative
for
alternative.oxides
this
to use suffur
feeds charged to their
to utilize
from 13.0 to
III will
be determined
of scrubbing.
to meet this regulatory

of FCC unit
emissions
(400 to 300 vppm). The energy; economic,
impacts of Regulatory
levels
allow refiners
oxides
alternative
oxides
is to
reduction
catalysts
Depending on the sulfur

units,
reduction
most refiners
catalyst
levels
are expected
technology,
while
few may use flue gas desulfurization.

The.emerging sulfur oxides
reduction catalyst technology can be used to meet this alternative
when feeds up to about 1.7 weight percent sulfurare
charged to the
FCC unit.
6.2.4
Regulatory Alternative IV
Regulatory Alternative IV would require that sulfur oxides emissions
from FCC units
be limited
to 6.5 kg sulfur
oxides/L,000
kg coke burn-off
1200 vppm). The levels of scrubbing required to meet Regulatory

Alternative
feedstock
IV are:
93 percent
model units
for the 3.5 weight percent
to reduce flue
gas sulfur
sulfur
oxides emissions
from
88 to 6.5 kg/1,000 kg coke burn-off (2,700 to 200 vppm), 86 percent

for the 1.5 weight percent sulfur feedstock model units to reduce flue
gas sulfur oxides emissions from 46 to 6.5 kg/l,000 ~g coke burn-off
(1,400 to 200 vppm), a?d 50 percent for the 0.3 weight percent sulfur
feedstock
model units
to reduce
sulfur
oxides
emissions
from 13 to
6.5 kg/1,000 kg coke burn-off (400 to 200 vppm). The energy, economic,
and environmental
these
levels
impacts of Regulatory
of scrubbing.
6-7
Alternative
IV are based on
This alternative
scrubbing.
the entire
is based on the use of sodium-based flue gas
This alternative
range of expected feed sulfur content,
and maintained
flue
gas scrubber.
FCCunits are processing

percent
catalysts
can be met on a continuous
sulfur
or less
It
is expected
feeds containing
may be able
to meet Regulatory
over
by a properly operating
that
refiners
whose
approximately 1.0 weight
to use sulfur
Alternative
basis,
oxides
reduction
IV.
Table 6-2 presents a summary of the model units, the regulatory

alternatives,
and the equivalent scrubbing levels for each regulatory
alternative.
6-8
Table
6-2.
SUMMARY OF REGULATORY ALTERNATIVES
Feed
Model
Regulatory
Alternative
(Baseline)
I1
Unit
Size
Sulfur
Level
[m3/sd)
2,500
Sulfur
and
(wt.
0.3
Oxides
Emissions
Equivalent
kg/100D kg coke burn off (vppmJ

X)
Control
Uncontrolled
Level
13 (400
O
and
3.5
88
2.700
0.3
1.5
13
46
400
1
13
13
400
400
3.5
1I1
IV
2,500 and
8,000
2,500
8,000
Level
8,000
2,500
8,000
Scrubbing
and
0
71
85
O.j
13 (400)
9.B (300)
25
3.5
88 12.700
9.8
300
89
0.3
1.5
13
400
i,
6.5
6.5
200
200
50
86
3.5
88
6.5
200
93
1.5
9.8
79
6.3
REFERENCES
i.
Cantrell,
A. Annual Refining Survey. Oil and Gas Journal.
78(12):130-157.
~arc~ 24, 1980. Docket Reference Number II-I-71.+
*References
can
be located
in Docket.Number
A-79-09
at
the
0.5.
Environmental.Protection AgencyLibrary, Waterside Mall, Washington, D.C.

6-10
7.0
7.1
ENVIRONMENTAL
IMPACTS
INTRODUCTION
Sodium-based scrubbing is the demonstrated control technology
applied to FCCunits, and it is expected that this wouldbe the most

widely applicable control system upon implementation of a regulatory
alternative.
As such, the environmental
impacts analyses are focused
upon sodium-basedscrubbing. However,refiners mayopt to utilize

alternative control technologies as discussed in Chapter 4.0. These
other control technologies may be an attractive
alternative to sodium-based
scrubbing particularly
for FCCunits at refineries
ability or wastewater discharges are restricted.

environmental
impacts for other control
where water avail-
In Section 7.4, the
technologies
are discussed and
comparedto sodium-basedscrubbing. The environmentalimpacts for all

of the other
control
technologies
are based on the same parameters
the sodium-based scrubber systems.

emissions levels for the regulatory
basis
for
the
Table 6-2 lists the sulfur oxides

alternatives
which serve as the
analyses.
The focus of this analysis

or decrease
as
over the baseline
is to determine the incremental increase

control
level
in air
pollution,
water
po~lution, solid waste, and energy impacts of the regulatory alternatives.

The baseline control level reflects existing levels of control of FCC
unit sulfur oxides emissions as required by State and local regulations.
This level is represented by Regulatory AlternativP I.
This chapter first addresses the air pollution impacts of implementing

each of the regulatory alternatives.
The sulfur oxides emission
reductions are indepenaent of the control technology applied, and,
therefore, sodium-based scrubbing as well as other control technologies
would result in the same reductions.
Water pollution, solid waste,
and energy impacts for sodium-based scrubbing are addressed in
7-1
Sections 7.3.1, 7.3.2, and 7.3.3, respectively. Theenvironmental

impacts associated with other control technologies are discussed in
Section
7.2
7.4.
AIR POLLUTION
IMPACTS
OF REGULATORY
ALTERNATIVES
Thefollowingdiscussion on dir pollution impactspertains to the

application of each control technology discussed in Chapter 4.0.
In
addition to sodium-$ased
scrubbing,these controls include dual alkali,
Wellman-Lord,citrate,
spray drying, and use of sulfur oxides reducfion
catalysts.
7. 2. 1 Pri_maryAir Pollution Inpacts
EmissionsfrommodelFCCunits include particulate aatter, sulfur

oxides, and carbon monoxide. Since particulate and carbon monoxide
emissions are already controlled by newsource performancestandards
(NSPS), only sulfur oxides emissions are discussed here.
Annualsulfur oxidesemissionsandemissionreductionsby regulatory

alternative for the model units are presented in Table 7-1. Annual
sulfur oxidesemissions
frommodelunits rangefrom260to 11,100megagrams
per year; emission reductions from the baseline level range from
zero to 93 percent dependingon regulatory alternative and modelunit.
7.2.2 SecondaryAir Pollution Impact
Secondaryair pollutanfs whichresult fromthe use of pollution

control equipmentare not usually associated with an uncontrolled
facility.
Nosecondaryair pollution problemsare anticipated due to
the applicationof sodium-based

or other scrubbersto FCC
unit regenerators.
In someinstances, nitrogen oxides (NOv)emissions from Ftt units
increasedwhenoperatedwith sulfur oxides reduction catalysts in
place. Nitrogenoxidesemissiondata fromFCCunits operatingwith

and without the sulfur oxides reduction catalysts were obtained in
order to evaluateNOx
emissionsincreasesdueto the use of the catalysts.
Ananalysisof thesedata showed

that NO,emissions
increasesresulting
fromuse of these catalysts are not significant.. However,CDpromoted
conventional regenerationftC units appear to have high NO,emissions
without
sulfuroridesreduction
catalystsandevenhigherNOx
emissions
with sulfur oxides reduction catalysts.
The significance of this
increase is unknown
due to the limited numberof
tests
performed.
uue r;oFneIim~reanumber
of SO~wri
SOxreductioncatalyst
7-2
Table
7-1.
ANNUAL SULFUR OXIDES EMISSIONS
AND EJY1ISSION REDUCTIONS
FOREACHREGULATORY
ALTERNATI'JEa
Annual
Regulatory
Al ternative
Fresh
Annual
Model
Feed
Sulfur
Unit
Sulfur
Oxides
Site
(m /sd)
Content
(wt. I)
Emissions
(ng/rr)
0.3
2,500
I
~Baseline)
8,000
1.5
3.5
II
8,000
2,500
III
8,000
2,500
IV
8,000
. Sulfur
in
Oxides
Emissions
from
Baseline
(Mg/yr)
oxides
emissions
Reduction
from
Basel ine
520
O
O
0.3
1,650
1.5
3.5
5,950
11,100
O
O
520
1.5
3.5
0.3
1.5
3.5
520
520
1,650
1,650
1,650
1,340
2,970
O
4,290
9,500
71
85
O
71
85
0.3
390
1.5
390
1,470
130
25
79
3.5
390
3,100
89
0.3
1.5
3.5
1,240
1,240
1,240
410
4,710
9,910
25
79
89
0.3
260
1.5
260
1,600
260
50
86
3.5
0.3
260
830
3,230
830
93
j0
1.5
830
5,120
86
3.5
830
10,300
93
aAssumes that the FCCunit operates 357 days per year, 24 hoursper
Sulfur
Percent
1,'860
3,480
0.3
2,500
Reductions
calculated
on'the
basis
of 400 vpprn for
feed
day.
sulfur
content of 0.3 Yeight percent, 1,400 vppm for feed sulfur content'of
1.5 weight percent, and 2,700 vppm for feed sulfur content of 3.5 ~eight
percent.
bTotalsulfuroxide5calculated
as SOZ
7-3
7.2.3
Dispersion
Modeling
Mathematical
concentration
modeling of the ambient air
of sulfur
from model FCCunits.
oxides
atmosphere
at various
the
distances
This analysis of pollutant dispersion enables
assessment of the effect

near the FCC unit.
in the
is used to predict
of each regulatory
alternative
on air quality
All modeling was conducted using the CRSTERmodel.
Since FCCunits are likely to be located in urban/refinery areas

characterized by considerable surface roughness and heat'ing from
combustion
sources,
concentrations
the
urban
were examined
mode of the model was used.

at distances
from 0.1
to 10 km downwind
of the FCCunit to detenr~ine the maximumdispersion

input
variables
used
cases
(Regulatory
units
charging
in the model appear
Alternative
in Table
I and Regulatory
0.3 weight percent
sulfur
for
particulate
control),
whereas
all
impacts.
7-2.
feedstocks),
other
baseline
II for
the model FCC
precipitators
cases
Other
For the
Alternative
parameters are based on the use of electrostatic
Emission
(required
use sodium-based
scrubbing. Dispersion modelingresults are shownin Table 7-3.28

The results
of scrubbers
of the dispersion
to FCC units
modeling indicate that the application
may increase
ground level
concentrations
of
sulfur oxides. Scrubber stack gases are cooler and have a lower plume
rise than the baseline case and therefore, increased ground level
concentration
ground level
of sulfur
sulfur
oxides.
oxides
From Table
concentrations
7-3,
1- and-3-hour
maximum
are higher for Alternative
III
than Alternative I (the baseline case) for an FCCunit processing a
0.3 weightpercent sulfur feedstock. ihe increase in groundlevel

sulfur oxides concentrations due to scrubbers may be mitigated through
use of greater
for
stack heights or exit velocities
the model plants
Prevention
in Table
of significant
than those specified
7-2.
deterioration
(PSD) increments
are
presented in Table 7-3 to allow comparisons with the dispersion modeling

results.
Based on these results, PSD regulations would preclude the
construction of new FCCunits in Class I (pristine) air quality areas
regardless of regulatory alternative.
Modeling results show that FCC
un~s meeting Alternative
II,
III,
or IV and all but those FCC units
processing high sulfur feeds under Alternative
7-4
I could operate in PSD
P: ; ;::"
i;
TabIe 7-2. PARAMETERS

FORMODEL
FCCUNITREGENERATOR
DISPERSION
MODEL
ANALYSIS
Feed Sulfur
FCC~resh
Feed
C~p~city
(uJ/sd)
2,5110
Sulfur
Oxides
Content
Stack Exit
Emission
Stack.
Stack
Hegul
atory
1\1
ternative
(Ueigh
t
Percen
C)
Telllpe
riltore
("K)
HatBa
(ylsJ
Ileight
(In)
Hiame
tcr
(m)
1, 11
0.3
473
17
46
1.3
11.2
1.5
473
60
46
1.3
11.2
3.5
473
113
46
1.3
11.2
11
1.5,3.5
340
17
68
1.2
16.2
111
0.3,1.5.3.5
340
13
68
1.2
16.2
IV
0.3,1.5.3.5
340
68
1.2
16.2
0.3
473
54
57
2.6
9.4
1.5
413
193
57
2.6
9.4
3.5 ~
173
360
57
2.6
0.4
340
54
68
2.2
16.2
2.2
16.2
2.2 ~
16.2
I, 11
~u
Slack Exit
Velocity
(In/s)
cn
8,000
aHeported
as SUE
11
1.5,3.5
111
(1.3, 1.5. 3.5
340
40
~ 68
IV
0.3, 1.5.3.5
340
E7
68
Table
7-3.
RESULTS
OF DISPERSION
MODELING FOR SULFUR OXIDES
EMISSIONS
FROI~
MODEL
FCC UNITSANDPSD INCREMENTSa
teed
fCC Frerh
Sulfur
Fred
CII)ICILj.
(b3Isd)
Su\fur
OxIcles
naximunlGround Lrvrl Sulfur Orldrs Collcentrntlonsb
Con~enr E.i~~
ion
Rtlqulatory
(He (ght
Rate
~( Irmst
percenl)
19/5)
lue
L,II
0.3
Concentration
17
1.5
60
3.5
113
1111g/n3)andOlrtbnrrtin Ll)DowaHllld
frollSourer
I-llour npxllwsa
Distance
3-llour HPrislum
Concentration
Distance
18
0.5
24-llour Ilaxinum
Concentration
23
Distance
102
0.6
2.0
)61
0.6
214
0.5
81
2.0
680
0.6
517
U.S
)52
2.0
Annual Marllllun
Concentration
Distance
2.5
2.0
8.8
Z.O
17
2.0
2.500
17
198
0.6
113
0.6
20
0.6
2.0
2.0
111
11
0.3.1.5.3.5
1.5.3.5
13
151
0.6
86
0.6
16
0.6
1.5
2.0
IY
0.3,1.5.3.5`
93
0.6
53
0.6
10
0.6
0.9
2.0
0,
1, 11
0.3
50
137
1.0
82
1.0
26
3.0
2.1
3.0
1.5
193
491
1.0
291
'
1.0
91
3.0
7.7
3.0
3.5
350
916
l.O
503
1.0
170
3.0
14
3.0
t1,000
YS0
Incrmlellts
LRrferel~cr 28.
blrpor~ed.r
Y)Z
11
1.5,3.5
59
25)
0.6
145
0.5
30
3.0
3.2
3.0
111
0.3.1.5.3.5
40
188
O.d
LOI
0.5
22
3.0
2.4
3.0
IY
0.),1.5.3.5
27
127
0.6
72
0.5
15
3.0
1.6
3.0
Clarr 1
Class 11
Class 111
25
512
700
5
91
182
2
20
40
Class
II areas.
FCC units
could
operate
regardless of regulatory alternative.

Sulfur oxides emissions under all
in PSD Class
regulatory
III
areas
alternatives
are in
compliance with national ambient air quality standards (NAAQS).

Primary
NAAQSlimit
annual
concentrations
to a0 micrograms/m3
(arithmetic
mean), and secondary NAAQS

to 1,300 micrograms/m~ maximumfor any
3-hour period. The modeled FCCunit maximumground level sulfur
oxides concentration
is realited
by an 8,000 m"/sd.model unit charging
a 3.5 weight percent sulfur feedstock.
In this worst case, the modeled
3-hour
emissions
and annual
maximum sulfur
oxides
ate
14 mg/m' at 3 km
downwind
of the FCCunit and543ng/m31 kmdownwind
of the FCCunit,
respectively.
7.2.4
Five-Year Impacts of Regulatory Alternatives
The projected number of affected new and modifi ed/reconstructed

model FCC units are presented by year in Tables 7-4 and 7-5. From
historical
that
FCC growth data presented
10 new FCC units
Table 7-4, units
will
built
in Appendix E, it is expected
be constructed
in 1985 will
in this
period.
probably be designed
As shown in
to process
higher sulfur feeds than those buil~t in 1982.

The available
growth data,
suirmrarized in Appendix E, also indicate
that up to 70 different units may increase throughput and omissions in

a 5-year period. Many of these throughput and emission increases,
however, occur as a result
of normal unit turnarounds,
changes in feed availability,
involving the FCCunit.

reconstruct
unit optimization,
2-8
routine
or construction
maintenance,
not
The actual number of units which modify or
thus may vary from only a few to 70.
For the purposes of
this analysis,
it is estimated that 10 percent of the units which may
increase capacity,
7 units, would be modified or reconstructed
between
1982and 1987.9 Tab~e7-5 describes the projected distribution of

modifi ed/reconstructed
facilities
These growth projections
that
is used in the impact analysis.
are used to estimate future (1982 through
1986) impacts of the regulatory alternatives

on sulfur oxides emissions.
Future impacts are determined by applying the model unit emission
rates in Table 7-1 to the projected distribution
of affected facilities
from Tables
by regulatory
7-4 and 7-5.
alternative
The resulting
in Table 7-6.
7-7
annual
impacts
are presented
Table 7-4.
PROJECTEDNEWFCC UNIT CONSTRUCTION

SCHEDULEa
FCC
Uncontrolled
New Unit
Flue Gas
Fresh Feed
Sulfur
Capacity
Year
(m3/sd)
1982
1983
1984
1985
1986
Sulfur Oxides
Content
Concentrationb
(wt ",)
(vppm)
2,500
0.3
400
8,000
0.3
400
2,500
8, 000
2,500
1.5
1.5
1.5
1,400
1,400
1,400
8,000
l.S
1,400
2,500
8,000
2,500
1.5
1.5
3.5
1,400
1,400
2,700
8,000
3.5
2,700
dFCC
Ijnitgrowth.projections
ared'---~--SbTotalsulfuroxidesreportedas 50
Table 7-5.
PROJECTED
FtC UNITMODIFICATION/RECONSTRUCfION
SCHEDULEa
Modified/Reconstructed
FCCUnit Fresh
Sulfur
Feed Capacity
Year
(m3/sd)
1982
8,000
1983
Content
(wt.~~
1.5
2,500e
1.5
8,000
1984
1985
1.5
8,000
2,500
1.5
1.5
8,000
1986
1.5
8,000
3.5
Uncontrolled Flue
Gas Sulfur Oxides
Concentrationb
(vppm)
1,400
1,400
1,400
1,400
1,400
1,400
2,700
aFCC
unit growth
projections
aredisc~--~--f-
bTorai
sulfur
oxides
reporied
seSOZ
CThismodified/reconstructed
FCC
unit is assumed
to havea carbon
monoxide
boiler.
7-8
Table 7-6.
ANNUAL
IMPACTSOF REGULATORY
ALTERNATIVES
ON SULFUR
OXIDES D4ISSIONS FROMNEWAND MODIFIED/RECONSTRUCTED
FCC UNITS"
Number of
Annual
New
and Modified/
Regulatory
Alternative
I
(Baseline)
1I
III
IV
Year
1982:
1983
1984
Annual
Sulfur
Reconstructed
Oxides
Emissions
Units
(Mglyr)
3
7
Sulfur Oxides
Emissions
Reducti~on
(M9IYr)
8,120
23,700
10
37,500
1985
14
53,100
1?86
17
78,800
1982
1983
1984
1985
1986
3
7
10
14
17
3,820
8,160
12,000
16, 300
20,100
4,300
15,500
25,500
36,800
58,700
1982
1983
3
7
2,870
6,130
5,250
17,600
1984
10
9,000
28,500
1985
1986
14
17
12,300
15, 100
40,900
63,800
1982
1983
3
7
1,920
4,100
6,200
19,600
1984
10
6,020
31,500
1985
1986
14
17
8,200
10,100
44,900
68,700
afotal sulfur oxides reported as S02
7-9
'
In the fifth year, total
sulfur oxides emission reductions for
new and modified/reconstructed FCCunits range from zero for Regulatory

Alternative
7.3
I to 68,700 Mg for Regulatory
Alternative
IV.
OTHERENVIRONMENTAL
IMPACTSOF THE REGULATORY
ALTERNATIVES
7.3.1 WaterPollution Impactsof Sodium-basedScrubbers

7.3. 1.1 Quality and Quantity of Liquid WasteDischarges. The application
of sodium-based scrubbers for control of sulfur oxides results in a
wastewater discharge which must be treated and disposed. The scrubber
effluent contains catalyst fines as suspended particulate and sodium
salts (sodium sulfite, sodium sulfate, sodium bisulfite) as dissolved

solids. Presently, the scrubber effluent from systems in operation on
FCCregenerators is treated to adjust pH imbalances by alkali addition.
Oxidation and settling tanks are used to reduce chemical oxygen demand
andsolids contentof the wastestreamprior to discharge.l0,l!

The scrubber system controls both particulate and sulfur oxides
emissions. Except for alkali consumption, scrubber operation and the
volumeof wastewater discharged will remain approximately constant to

maintain particulate
removal efficiencies.
Therefore, model unit
throughput rather than sulfur content of the flue gas or regulatory

alternative affects the volumeof scrubber effluent to be disposed.
The quantity of wastewater discharged from sodium-based scrubbers
is about0.07m3/,3freshfeed.l0Thescrubber
effluent,treatedas
described previously, is assumedto contain'5 weight percent dissolved
solids as reported for sodium-based scrubbers in industrial boiler
For FCCunit applications, the percentage of dissolved
applications.ll
solids in the scrubber effluent is reported by the vendor to be proportional

to the sulfur content of the flue gas.
One refiner
treated purgestreamcontains40 9/m3suspended

3
oxygendemandof 40 g/m
10
reports that the
solids,
and
chemical
However,the vendor claims that the purge
treatment is designed to reduce the total dissolved solids and chemical
oxyoen
demand
of thepurgestream
to 1009/m3
and509/m3~
respectively.l2
A j-:irription of wastewaterdiEchargesfromthe modelunits is developed
based on the reported refinery effluent discharges.
Discharges from the two model unit sizes are P~esented in Table 7-7.
For these modelunits, annual scrubber discharges to receiving waters

7~10
Table 7-7.
A9UEOUSDISCHARGES
FROMFCC UNIT
SODIUM-BASED SCRUBBER SYSTEMS
Chemical
FCCFresh
U~stewater
Suspended
Feed
Capacity
Dischargea Solidsb
(m3/sd)
(m3/yr)
(Mg/yr)
2,500
8, 000
62,500
200,000
2.5
8. O
aAssumes a linear relationship
Dissolved
Oxygen
SolidsC
Oemandb
(Mg/yr)
(Mglyr)
3,100
10,000
2.5
8. 0
between discharge and flue gas flow
rates. Calculatedon the basis of 0.07m3of wastewater

d~scharge
per
3 of fresh feed, 357daysof operation per year. Reference10.
bReference 10.
tReference 11.
Dissolved solids represent approximately 5 weight
percent of the wastewaterdischarge. To calculate massdischarge of

dissolved solids,
1 Mg/m3
the density of the wastewater is assumed to be
rangefrom62.500
to 200,000
m3/yr,
suspended
solidsdischarges
range
from 2.5 to e.0 Mglyr, dissolved solids discharges range from 3.100to
10.000Mg/yr,and chemicaloxygendemandrangesfrom2.5 to 8.0 Mg/yr

for the 2,500 and 8,000 m'/sd modelunits, respectively.
7.3.1.2 Disposal Techniques. The five refineries with sodium-based
scrubbers in operation for FCCunit sulfur oxides control are in or
near coastal
locations.
The scrubber effluent
is treated to reduce
chemicaloxygendemand,suspendedsolids content, andto adjust pHas

describedpreviously. Theeffluent is then dischargedto large rivers
or coastal waters.
The dissolved solids content of the treated scrubber
effluentis approximately
5 percent.l0Because
of this, discharge
of
the treated wastesto surface watermaybe restricted, especially in
inland locations, due to refinery dischargepermits. However,
discharge
of scrubber effluents to surface water maystill be possible. If a
sufficient volumeof wastewaterfromelsewherein the refinery is

available and of low dissolved solids content, the dissolved solids
content of the scrubber wastewater may be diluted to within permit
limitations. Refinery effluent flows range from 1.2 to 6.0 m3 of
wastewaterjm3
crudecharge.l3
Alternativesto discharge of the treated wastes to surface water
include discharge to municipal wastewater treatment facilities or
evaporation ponds.
These are popular alternatives
for industrial
boiler applications. Otheralternatives includedeepwell injection,

flash evaporation, or reverse osmosi's. These latter alternatives are
not widelyusedin boiler applicationsat presentll and,therefore,

may not gain acceptance
for FCC unit applications.
7.3.1.3 Applicable Regulations. The applicable regulations

relative to scrubber wastewaterdischarges are dependentupon the
disposal technique being used. Oischargesto receiving streams,
territorial
seas, or pceans must satisfy the requirements of National
PollutionDischarge
Elimination
System(NPDES)
andOceanDischarge
Criteria underthe WaterpollutionCentralAct. Discharges
to pudlicly
ownedtreatment works (POTW)
will have to satisfy pretreatment requirements
for the POTW's.Wheneffluents are being disposed of by deep well
injection or evaporation pond, the requirements of the Safe Orinkina
7-12
Water Act, the Underground Injection Control Program, and State and
local pollution control agenices must be met. These regulations are
specific to each receiving stream, WTIW,and to the groundwater use
and geology of each location in question. State water pollutant

regulations may, in some cases, b~emore stringent than Federal water
pollution
regulations.
7.3.2
Solid Waste Impacts of Sodium-based Scrubbers

Sodium-based scrubbers
applied
to FCC units
control
emissions
of
sulfur oxides and particulate matter (catalyst fines).

Control of
particulate emissions from new FCCregenerators is required by an
existing NSPS. Particulate matter is removed from the flue gas by the
scrubber
and collected
in the
scrubber
wastewater
sludge.
Small amounts of polyelectrolyte
treatment
unit
as a
(from 1.5 to 4.5 kg/day for
the model units) are added to the scrubber effluent

treatment to enhance removal of suspended solids."-
during wastewater
Sulfur oxides
emissionscontroldoesnot rezult:in anyincrementa~

changesin the
amount (dry weight) of solid wastes produced over that resulting
.the particulate
from
NSPS.
7.3.3 Energy Impact of Sodium-basedScrubbers

The overall energy impact of sodium-based scrubbing systems on
FCC units is negligible.
However, the scrubber system would add to
the electrical
requirement of an FCCunit.
annu.al electrical
units.
requirements
forscrubber
Table 7-8 presents the

systems and for FCC
14-17 Thescrubbersystem.increasesthe total electrical
consumption for FCCunits using a high energy venturi by about 2 percent

and approximatel.y 20 percent
scrubder.
for units
Modified/reconstructed
as.sufficient
ejector
I.ine pressure
will require a jet ejector

to induce a draft through the
is not available
carbon monoxidebdiler, which is unpressurized.

ejectors
venturis
do not
as discussed
have
this
in Section 4.2.2.2,
requirement.
7-13
through
the
Additional energy is
thus consumed by the pumps which spray the scrubbing

the jet
venturi
FCCunits which employ a carbon
monoxide combustion furn~ace regeneration

venturi.
The jet ejectors are required
venturi
using a jet
liquor
through
The high energy
Table
7-8. ANNUAL
OPERAIING
ELECTRICITY
REUUIREM~NTS
FOR SODIUM-BASED
SCRUBBER
SYSTEMSANDFCC UNITS
-----~Total
Annual Clrctricity
FCCUllit
FreshFeed
nequirallerlt for
Electricity
Annual Electricity
Scrubb~r
andUastewater
Csy;ciry Ireatment
Syr~eR
(m /sd)
FCCUiits
witb Niyh
Energy
(TJ)
2,500
8,000
Iln~~u~l
L.U
3.J
Requil.elllent
for
RCunirc
(TJ)
neqlliraller~tfor
Scnll,herSystan
Scrul,l,erSYStUII
1IIJ
~CC
Unit Llactricily
Rtilluirelllrlll
(1J)
As a Percent of Total
46
14()
47
152
2.1
2.2
46
149
57
190
19.3
21.6
Venturiz
FCCLhlits
withJet Ejector
2,500
8,O(H)
11
41
Vellturis
P
I:::"1";.X':',:C.''L
UsI~
.Ilarcruhlwr
eaLII
qlc..Lr
151
ddyr
perye.r.24Ilourr
pr dayCli.verrion
~artorr:
T.);lnl?
~bul.r.
bHcftrullce
12~ It i~
shown in Tdble 7-5.
units HOUIJrequlre.a
electricity
expectedthat Illostnewal~d
Iliodif
ied/reconstructed
FCC
llllit5will ellll,loy
~~igh
erlergyvelltllrTs.Ilowever,
as
units
two Illodified/roconstructccl
jet ejector
venluri with d
drl: expected to utilize
a carbon Illoiloride callhustion fur~ldce.
These FCC
sudiuln-basc?d
scrubb~rsystelll. Tilejet ejector type venturi reql~iresddditil,llal
to (,ullpthe scrubbillg ~iclc~or

t)lrouyl, the jet ejectors.
ECalculatciii
as an averagevaluefrai Hefercnce~
14. I!,, 16.
In assessing nationwide energy impacts for the sodium-based
scrubber system, it is expected that all new units and five of the
seven projected modified/reconstructed units will utilize a high
energy venturi. It is anticipated that all neH units will use high
temperature regeneration and that conventional promotedregeneration
or high temperature regeneration will be used in the case of five
modified/reconstructed
units.
Twomodified/reconstructed
units are
expected to use conventional-unpromotedregeneration, and hen~cejet

ej ector' venturi s . These units are assumedto beòne 2,500 m'/sd unit
and one 8,000 mj/sd unit charging a 1.5 weight percent sulfur feed as
noted
in Table
7-5.
A comparison of the scrubbing system total energy requirement to
the FCCunit's energy requirement is presented in Table7-9. The

scrubbing system energy requirement for units with the high energy
venturi and the jet ejector venturi is less than 1 and 2 percent of
that for the total FCCunit, respectively.
From Table 7~10, nationwide
fifth-year energy requirements ate approximately 24,000 TJ under
RegulatoryAlternative II and 26,900TJ for RegulatoryAlternatives III

and
IV.
7.3.4 Other Impacts of Sadium~basedScrubbers

7.3. 4. 1
Noise.
scrubber operation.
An increase
in n~oise is expected as a result
of
Sources of noise are pumps, agitators, and fans
associated with the scrubber and wastewater treatment systems. This

increase in noise is not significant when compared to noise levels
associated
7.3.4.2
with
the FCC unit
Irreversible
and supporting
and Irretr~evable
equipment.
Commitment of F(esources.
This analysis has assumed that implementation of each regulatory

alternative other than Regulatory Alternativ~ I will require installation
of sodium-based scrubbers. This will necessitate the additional use
of natural resources, especially alkali.
However, the commitmentof
these resources is expected to be small compared to national use.
7.4 ENVIRONMENTAL
IMPACTS
OFOTHER
CONTROL
TECHNOLOGIES18
This section
discusses
the environmental
impacts that
control technologies which may be used as an alternative
7-15
result
from
to sodium-based
Table~-9. ANNUAL
OPERATING
ENERGY
REQUIREMEN~s
FORSODIUM-BASED
SCRUBBER
SYSTEMAND FCC UNITS
Total
Allnualflleryy
FCCUrllt
Fresh Feed
Require~nent
for
Scrubberand Uastewater
Capacity
Treat~nentSystan'b
(m3/sd)
FCC
Units
wiLI1
Ilig)l a
2.500
8.000
~UC
Unit6
Hitll jet
2.500
B, OOU
energy
ejector
vunturis
IrJ)
1.2
3.8
13
vL.nturise
Ener(iy
Allnual
Ellergy
Aegulrellle~lt
for
FCCUnttc
Recluirenent
for
Scr'ubber Systelll
and FCCUl,it
Scrubber Systall
Ener?)y nec(uirelllent
(38)
(1J)
As a Percent of Total
690
691
0.17
2,200
690
42
An~lllal
2.200
2.204
0. 17
703
2,242
1.H
1.9
cn
Assullles
6hat the FCCunit and scrubbercac),
3.6 x 1U J.
operate357daysper year, 24Iloursper day. Conversion

Factors:TJ = 101?J. kW11
=
Btu 1055 J.
13.The
cunponellts
ofthescrubber
syste~ll
energy
requiroaents
inclu~le
c~Re~rrence
electricity
Calculated as d~laverage value froll, Rr~ererlcr?s
sredlo,
and
fuel
It is expected
rcquirullcrlts
that new FCE ullits
dlld steam.
14,IS, 16. Cul,ponents

of theFCC
unite~~eryy
recluirelllents
illcludl'
electricity,
gas.
a~ld
of theIllodified/recoostructed
FCC
unitswill usehighenergyvei~turis.Theelectrical
for these units are based some
on a hilJII elleryy vellturi systeln.
e)(od
1fled/rrculls
tructnlFCC
onits Hitll cJrtollalonox
itle
systtrll.
The jet ejector venturi rc?quires
furnacesHill requllt!a jet rjectl,r v~rlturiwith the sutliulll-hdsod

scrul,her
additional eneryu to pulllplicluor LhroucJI1

tile jet ejectors.
lable 7-10. NATIONWIDE

FTFTH-YEAR
OPERATING
~EIERGY
RE9UIREMENTS
FOR SODIUM-BASED SCRUBBING
Reilulatory
Alternative
II
FCC Ullit
Fresh Feed
III
Nuslber
of
CapacIty
Affected
(PI3/5d)
facilities
and
Iv
Nulnber
#dtion*lde
Flflh-Yrdr
of
Eller9y RequirelllenL
(TJ)
Natio~wlde Fifth-Year
Affected
Ellergy Hequirallent
(TJ)
Facilities
-----~-
---------L
hew FCCUnits
2,500
3,460
9. 150
with high
8.000
17,63(1
19,840
2,500
B,nflO
1
1
703
2.242
L
1
703
2.242
el,er~Jy venturls
FCC LkliLs
H1U~ jet
ejector
vei,turis
Total
t;
24,000
26.900
'NatlollwidefifrlI-yrar el,ergy requlrellents are obtained by I~~ultiplyll~g

tile Illoclelunit reqctiranents frun Tilblu 7-9 by tile
pr~,jectedyrowt)Ifor tile fifth year 9lvell ill Tables 7-4 andl~-5. It is assullled6tkattuclIllodif ied/rrconstructed units will
require
jet
ejector
ve~lturis.
Convèrslol, Factors:
TJ E 10
J, kWh - 3.6 n 10 J.
Otu E 1055 J.
bCllergy
require~nentb
are lowerunderAe~ulafory
AlternativeII becauseno control is requiredfor units processing(1.3*I:ight
B'rcent sulfur feed (apyroxinlately400 pyln502)-
scrubbers. Thesecontrol technologiesinclude: dual alkali, Uellman-Lord,

citrate,
and spray drying flue gas desulfuritation
reduction
and sulfur oxides
catalysts.
Nationwideimpactsfor eachalternative control technologyare

determined by assuming that all projected units subject to standards
of performance utilize the control technology discussed. Table 7-11
compares the nationwide environmental impacts of these alternative
control technologies with that of sodium-based scrubbers.
7.4.1
Dual
Alkali
Thedual alkali FGD

systemscan be applied to most000units;
however, a vendor has indicated that in circumstances where the flue
gas sulfur oxides.,concentration is below 800 ppmv, a single alkali
scrubberwouldbe employed.In these cases, there is so muchnonregenerable

sulfate present that a dual alkali system is unjustifiable.
In order
to assess the nationwide impacts of the dual alkali system, it is
assumedthat sodium-based
scrubberswouldbe employed
for units treating
low sulfur oxides flue gas concentrations. As shown-in Table 7-4,
this would affect the two projected model units with feed sulfur
contents of 0.3 weight percent. The nationwidedual alkali impacts

include sodium-basedscrubbing impacts for these units.l8
Dual alkali FGDsystemsuse an aqueoussodium-basedalkali solution

to absorb sulfur oxides from the flue gases.
A calcium-based al ka7i
solution is then used to regenerate the active sodiumsolution.
Duringthis regenerationprocess, a calciumsulfite/sulfate precipitate
is formed.Thispreci~pitate
is removed
for disposal. Sludgecontaining
the calcium sulfite/sulfate
solids is concentrated in a vacuumfilter
to about50 percentsolids by weightand sent to a landfill for disposal.l9

Projectedfifth-year solid wasteimpactsare 228Gg,246Gg, and
263 00 far AlternativesII, III, and IV, respectively.l8
Liquidwastesfromdual alkali scrubbingare negligible, and
water consumptionis low in comparisonto the sodium-basedsystem.
The fifth-year nationwidewater consumptionreported in Table 7-11 is
754,000
mJforeachregulatory
alternative.
Thenationwide
energy
impacts of the dual alkali system are comparable to the sodium-based
system. Dualalkali scrubbingwouldrequire 94.4 TJ energy in the

7-18
Table
7-11.
FIFTH-YEAR NATIONWIDEENVIRONMENTAL
IMPACTS,
BYCONTROL
SYSTEM
AND
REGULATORY
ALTERNATIVE18
Lill"ill \.]a51rs
Ellcl`yy COIISIII:ll)t(UII
Totdl
PLI.U.LICr
Ilrf~n
So~l(UIIIUdSed
RccJu
I~Lury
S~lid \ldsres
II
11)5
Nc~J.
2, LIP)
lug
IC~) __L~03lliL~~_
(61)
I1I
Uclllllall-lurd
Udl~!r
Y~,lullle
I:OD
(HrJ)
01
Col,sullljltio~l
Tutl
I)il
C~lulvdle~ll
(Mg)
33
1~
IJ
111
4.421)
91.4
2. 703
(113 --
Heg.
2.411)
122
90
911
4.960
96.4
2.420
IY
NE9
2,140
12?
38
90
4.~60
g~~q
2.420
II
llcq.
278
0.4
ll.L\62
1.779
L. 11,5
IZ.5 ~
1,023
1II
Ne:J.
3(11)
0.4
13,294
1.411
82.9
2,01)3
IV
Nrg.
312
1).4 13.E94
2.024
l.n61
?2. 1
2.313
11
228
WA
NA
71,4
91.4
2.311
111
246
10,5
10.5
99.4
2.491
Uusl AILdli~
NeglLyihle
263
~ Nh
13. 1
IY
13. L
10.5
LQ.S
5.8
Negliyible
Nn
rU\
NA
NcyI icJil,le
268
111
6. 3
Negliglblr
HA
NA
NA
IlrtJ)icJi8lr
W1
1,560
IV
6.8
Nryligible
IUA
IIA
NA
nc~l iyible
3tll
7.!i61)
11
15.4
Heglitliblr
04
Nn
#A
1,050
2(14
5.120
C1
U3
Cllr~tr
------
II
Sllri~yUryl~ly
dUd5sJ ull39.8GJyrrlu
263
---
2113
-~---
1.2!16
9').4
2.13;1
--
6.740
111
170
Negligib1u
IUA
NA
1,177
2211
5.130
IV
3L~)
Hcg\ ilJiblr
nA
Nn
1.117
220
Ij~lJI1
tuel oil
(6
(6r
lu
--
harrel-)
Utu ptr harrel-).
----
b~Cldl~lt~li iulpdctsrellortrd irlcludr L)leimp~cts01 Sl)~liulll-b~Sed

SCTUl,b.TS
lOTtht: pTOjCCII:d
FCCLllljtSHilJI lced-suIIor COlltCllt
O( ().~ weipllt
(,erce~lt1400vppo). OEluwBuOva(wusulfur dlo~x~icle
fllle 915 Eoscentrarlon. a sillglu dlI(a)I 5Crllbbel.15 Llst!lI
becauseof tile large IIIIUUIII
UF
IIIIIITe?lenerdble
S(ljiUIIISU\fdte IITUdUCL~.~)II!dUd) aJkdli scrubber har negligible lirluld ndstr.
CNA- Not ayplicdble.
Refrrellce 1~.
fifth
year of the standard.
Energy requirements are a function of FCC
unit size and are not dependent on the level of sulfur oxides control.l8,19
7.4.2
Wellman-Lord
The Wellnan-Lord system utilizes
a regenerable sodium sutfite
bisulfite system to removesulfur dioxide from the flue gas. A variable

throat venturi scrubber serves to removeparticulate matter and, in
addition, cools and saturates the gas stream. Water consumption
figures
are
indicated
in Table
7-11.
Spent scrubbing liquor (sodium bisulfite)

stage
is filtered
to remove suspended solids
from the absorption

and is heated
evaporator for regeneration to sodium sulfite.

small quantities
of sodium sulfate
A purge stream removes
and sodium thiosulfate,
during regeneration, from the absorbing solution.

composed of the sulfate
in an
formed
Liquid wastes,
purge and the water purge streams, are treated
in several ways. Somefacilities route the purge streams to existing

refinery wastewater treatment plants, someuse the purge streams as
raw material for other processing units (i.e.,
sulfuric
acid dilution
water), and still others ocean dump. The water purge from a Wellman-Lord
installation will require minimal treatment, i.e., neutralization tit
is only slightly acidic) and settling/filtration
for removalof suspended
solids. In manycases, simple pending will result in deposition of

most of ~~e suspended solids(depending on specific gravity of the
solids).
Projected fifth-year liquid waste impactsare presented in

Table 7-11. The GOD,TDS,and SS of the water purge stream will
depend, to a certain
extent,
on the GOD, TDS, and SS of the water
make-upto the Wellman-Lord

plant. For example,if well water (untreated)
containing 200 mg/l TDSand 40 mg/l CODis used as make-upto the
scrubber, the water purge will contain approximately 1,500 mg/l TDS
and 300 mg/l GOD. In other words, there is a concentration
ratio of
about 7.5:1. In addition, the water purge will contain 5.0 weight
percent maximum
SS, which consist of solids removedfrom the FCCU
gas,
plus whatever SS were present
in the make-up water,
concentrated
7.5 times. The sulfate purge contains approximately 72 percent water
and 28 percent Sodiumsalts, with 000 and SS levels of 42,000mg/l and

100 mg/l,
respectively.18,20
7-20
7.4.3
Citrate
The citrate
FGDsystem has negligible
water and liquid waste
requirements. Thesystemdoes, however,producea solid waste product,

Glauber'ssalt (crystalline sodium-sulfate,naS04' 10 H20) Glau~~er's
salt is producedat a rate of 67.3 kg per Clg.ofsulfur recovered.
Glauber's salt is produced in a filter
including diatomaceous earth,
as a stable landfill
material.
citrate
22
cake with other minor constituents

salts,
sulfur
and catalyst
Table 7-11 reports
fin'es
the fifth-year
nationwide volume of solid waste at 5.8, 6.3, and 6.8 Gg for

Alternatives
II,
The citrate
III,
system has comparably high electrical
requirements.
UnderRegulatoryAlternative II scrubberswouldconsume268T3,and
23,24
Alternatives III and IV would consume301 TJ each.

Electricity
is consumedby high horsepowerpump and agitator loads required to
move and mix viscous
7.4.4
slurries.
Spray Drying
The use of spray drying FGDwould impose much less severe water
and wastewater requirements upon implementation of the regulatory
alternatives.
Nationwidewater consumption in the fifth year would
amountto 1,050,000m3underAlternative II and 1,177,000m3under

Alternatives III and IV.18 In addition, spray drying does not produce
a signifi~ant
vo?ume
of liquidwastes.26
Solid wastes from the application of spray drying to FCCunits is
a filter cake which builds upon the fabric filter bags. The filter
cakes consist of calcium sulfate and catalyst fines. It is assumed
that the spray drying systemwill achieve90 percent control of particulate

emissions; however, it has never been demonstrated for FCCunits. The
nationwide solid waste impacts given in Table7-1l amount to 75.4 Gg,
18,27
170091and357 69 for Alternatives II, III, and IV, respectively.

7.4.5
Sulfur Oxides Reduction Catalysts

As discussed in Section 4.5.2, su7fur oxides reduction catalysts
are an emerging control technology in fluid catalytic cracking.
Sulfur oxides reduction catalysts are not expected to have any incremental
impactuponsolid or liquid wastesor energyconsumption

overbaseline.
7-21
7.5
ENVI~RONMENTAL
I~PACT OF DELAYED
STANDARDS
Delay in implementationof each regulatory alternative except

Regulatory Alternative I would adversely impact air quality at the
rate shown in Table 7-6.
The annual sulfur oxides emissions reduction
column represents the lost emissions reductions for each year the
standard is delayed. No adverse solid, water, or energy impacts are
expected
from delaying
regulatory
action.
7-22~
7.6
REFERENCES
i.
Memorandum
from Bernstein, G., Pacific Environmental Services,
Inc.,
to Docket Number A-79-09.
May 21, 1982.
Results
of Analysis
of ~10,
Emissions
Study. DocketReferen~e
Flumber
II-B-2C).f
2.
Letter and Attachments from Larson, W.E., Chevron U.S.A., Incorporated

to Goodwin, D., U.S. Environmental Protection
Agency. March 24,
1981.
p. 4.
Response to Section 114 letter
and expansions.
3.
Letter
Docket Reference
and Attachments
from Laque,
on FCCunit alterations
Number II-0-42.X
W.E.,
Rock Island
Refining
Corporation to Goodwin, D.R., U.S. Environmental Protectio~

Agency. March 18, 1981. p. 3. Response to Section 114 letter
on FCC unit
alterations
and expansions.
Docket
Reference
Number
II-D-40.I
4.
Letter
and Attachments
from Adamsi J.T.,
Jr.,
ARtO Petroleum
Products Companyto Goodwin, D.R., U.S. Environmental Protection

Agency. April 3, 1981, p. 3. Response to Section 114.letter on
FCC unit
alterations
and expansions.
Docket
Reference
Number
II-D-43.f
5.
Telecon.
Manda, Michaet, Pacific Environmental Services,
with Scharff, Davis, Champ7in Oil Company. May 4, 1981.
in capacity of Champlin FCCunits.

6.
Telecon.
Manda, Michael,
Pacific
Inc.,
Growth
Docket Reference Number II-E-1.*

Environmental
Services,
Inc.,
with Cox, Lyman,Charter Oil Company. April 16, 1981. Growth in

capacity of Charter FCCunits.
Docket Reference Number II-E-l.f
7.
Telecon.
Manda, Michdel, Pacific Environmental Services,
with Segar, Tom, Koch Refining Company. April 16, 1981.
in capacity of Charter FCCunits.

8.
Telecon.
Manda, filichael,
Pacific

Environmental
with C7odi, Charles, Mobil Oil Company.

expansion activi~ty on FCC unit at Joliet,
Docket
9.
Reference
Number
17, 1981.
No. A-79-09.
Services,
Inc.,
April 23, 1981. Lack of

Illinois,
refinery.
II-E-I.*
Memorandum. Manda, Michael,

to Docket
Inc.,
Growth
Pacific
Environmental
Growth Projections
Docket Reference
for
Services,
FCC Units.
Inc.
July
~lumber 11-8-16.+
10. Letter and Attachments from Albaugh, D., MarathonOil Company,to

Coodwin, D.R., U.S. Environmental Protection
Agency. Clarch 20,
1981. Response to Section 114 i.nformation request.
Docket
Reference
Number
II-D-4l.f
7-23
11. TechnologyAssessmentReport for Industrial Boiler Applications:

Flue Gas Oesulfurization. U.S. EnvironmentalProtection Agency.
Research Triangle Park, North Carolina.
Publication E~umber
EPA-600/7-79-178i. November1979. p. 6-13. Docket Reference
Number
12.
II-A-lO,f
Letter and Attachments from Cunic, J.D., Exxon Research and
Engineering Company,to Goodwin,D.R., U.S. Environmental Protection

Agency. November23, 1981. Docket Reference NumberII-0-65.~
13. Jones, H.R. Pollution Control in the PetroleumIndustry. Moyes

Data Corporation. Park Ridge, NewJersey.
Docket
14.
1973. p. 144.
Number II-I-8.+
Letter and Attachments from Cunic, J.O.,~ Exxon Research and

Engineering Company, to Durham, J.F., U.S. Environmental Protection
Agency. January 23, 1981. Information on sodium scrubber costs.
Docket
15.
Reference
Reference
Number II-0-37.~
Letter and Attachments from Adams, J.T., Jr., ARCOPetroleum

Products Company, to Goodwin, D.R., U.S. Environmental .Protection
Agency. April 3, 1981. Response to Section 114 information
request.
Docket
Reference
Number II-D-43.f
16. Letter and Attachments from Larson, W.E., ChevronU.S.A., Inc.,

to Goodwin,D.R., U.S. Environmental Protection Agency. March 24,
Reference
Number
II-D-42.+
Docket
17. Letter and Attachments from Pritchard, James J., Ashland Petroleum
Company,
to Goodwin,D.R., U.S. EnvironnentalProtection Agency.
May27, 1981. Responseto Section 114 information request.
Docket
Reference
Number II-D-53.*
18. Memorandum
fromRhoads,T.W., Pacific EnvironmentalServices,
Inc., to Docket A-79-09. April 27, 1982. Environmentaland cost

impact
analyses
citrate,
Number
for
the
sodium-based
and spray drying FGDsystems.
dual
alkali,
Wellman-Lord,
Docket Reference
II-B-23."
19. Telecon. Czuchra, P.A., FMCCorporation, with Osbourn, 5.,

Pacific EnvironmentalServices, Inc. January 13, 1982. Dual
alkali
scrubber
costs.
Docket Reference
Number II-E-5.*
20. Letter and Attachmentsfrom Pedroso, R.I., DavyMcKee

Corporation
to Rhoads,Thomas,Pacific EnvironmentalServices. Inc. Fe6ruary24,
1982.
Docket Reference
Number II-D-92.*
21. Telecon. Madenburg,D., Morrison-Knudsen,

wit, Meardon,K.,
Pacific Environmental Services,
informatio.
Docket Reference
7-24
Inc.
January i, 1982. Citrate
Number II-E-5.*
22.
Telecon.
Nissen, B., U.S. Bureau of Mines, with ~eardon,
Pacific Environmental Services, Inc. February 11, 1982.
information.
23.. Telecon.
Pacific
Number~IIIE-5.*
Madenburg, D., Morrison~Knudsen, with Meardon, K.,

Services.,
Docket Reference
Inc. January 6, 1982.
Citrate
Number II-E-5.~'
felecon.
Nissen, B., U.S. Bureau of Mines, with ~eardon,K.,
Paci.fic Environmental Services, Inc. January 12, 1982. Citrate
information.
25. Telecon.
Pacific
Docket Reference
!~unber II-E-5.~f
Madenburg, O., M~rrison-Knudsen, with Rhoads, T.W.,

Environmental
information.
26.
Reference
Environmental
information.
24.
Docket
K.,
Citrate
Docket
Services,
Reference
Inc. March 4, 1982.
Citrate
Number TI-E-5.+
letter and Attachments from Petti, V.J., Wheelabrator-Frye, Inc.,

to Rhoads, T.W., Pacific Environmental Services, Inc. February
12, 1982.
Dry scrubbing
capital
and operating
cost parameters
for catalytic cracking towers. Docket Reference NumberII-0-88.*

27.
Tel ec on .
Petti,
V.J.,
Wheelabrator-Frye,
Inc.,
with ~hoads,
T.W., Pacific EnvironmentalServices, Inc. March 1, 1982. Spray

drying information. Docket Reference NumberII-E-5.t
28.
nenaranaun
from Cole, H., Environmental
Protection
Agency, to
Farmer, J., Environmental Protection Agency. Dispersion Estimates

for SO Emissions from Fluid Catalytic Cracking Units (FCCU).
April r4, 1982. Docket Reference NumberII-B-22.*
*References can be located in Docket NumberA-79-09 at the U.S:

Environmental Protection Agency Library, Waterside Mall, Wash~ngton, D.C.
7-25
8.0
8.1
COST ANALYSIS
INTRODUCTION
The capital costs, annual costs, and cost effectiveness
of
implementingRegulatory Alternatives II through IV are estimated for

each new and modifled/reconstructed
model FCCunit.
These estimates
are used to determine the economic impacts of the regulatory
alterna-
tives upon the petroleumrefining industry. The economicimpact

analysis is presented in Chapter 9.0. Nocontrbl costs are associated
with Regulatory~Alternative I as thi s is the baseline level.
As discussed in Section 6.1, this cost analysis
is founded on the
application
of sodium-based
scrubber
technology
to model
FCC
unit flue
gas parameters. Thecapital and annual cost of treating and disposing
of the scrubber waste stream to surface water is included in the
scrubber system costs. A description of a sodium-basedscrubbing

system is provided in Section 4.2; modelunit flue gas parameters are
presentedin Section ~.1. To ensure a common

cost basis, Nelson~Cost
Indexes are used to adjust costs to fourth quarter 1980 dollars.
Although several vendors market sulfur oxides scrubber systems
that canbeappliedto FCC

regenerators,the sodium-based
scrubbers
presentlyin use on FCCregeneratorsat five refineries are licensed
by onevendor. The vendor provided capital and annual costs for
two modelunits. ThesemodelFCCunits have throughput capacities of
2,500and8,000m3fresh feed/streamdayanda flue gas sulfur oxides

concentration of 1,400 vppn. Scaling and other factors provided by
the vendor allow determination of annual scrubber costs for all other
modelunits.Z
A discussion of costs for other flue gas desulfurization .systems
and sulfur oxides reduction catalysts is presented in Section 8.2.
While
onlythesodium-based
scrubber
system
hasbeenwidely
applied
to
8-1
FCCunits at present, these alternative control technologiesnay also

be applied tb FCt units' upon implementationof newsource perfor~ance
standards for sulfur oxides.
electrostatic
precipitator
And, in Section 8.3 the costs for an
(ESP) ai.e included in the discussion of
other costs. Thecost for particulate emissionscontrol is included

in the baseline costs, RegulatoryAlternative I, becausethe existing
NSPSrequires particulate control. Therefore, a credit for particulate
control, based on ESPcosts, is applied to the total annual costs for
flue gas desuifurizationsystemswhichcontrol particulates in addition

to
sulfur
8.2
:7
oxides.
SODIUM-SASED
FLUEGAS DESULFURIZATION
COSTS
'T
This section presents the capital and annual costs for sodium-based
scrubbing and wastewatertreatment systems. As discussed in Sections 8.2.1

and 8.2.2, the cost for sodium-based scrubbing applied to FCCunits is
dependentuponthe type of venturi scrubber used. A high energy

venturi scrubber wouldbe employedby FCCunits operating under high
temperature regeneration (HTR)or conventional promotedregeneration.
FCCunits which operate with a carbon monoxidecombustion furnace
would utilize
a jet
ejector
type venturi,
8.2.1 CapitalandAnnualCostsfor Sodium-based

HighEnergy'lenturi
Scrubbers
Thehigh energyventuri relies uponline pressurefromthe regenerator

to force flue gas through the venturi without fans. .Highenergy
venturis are expected to be used by all newFCCunits and modified/.
reconstructed
units unless the unit relies
upon a boiler for carbon
monoxidecombustion. It is estimated that five of the seven projected
modified/reconstructed
units in Table7-5 will utilize high energy
venturis.
Thecapital cost of the sodium-based

scrubbersystem(including
wastewatertreatment) is primarily a function of the regenerator flue
gas flow rate and, hence, FCCthroughput.
It is not dependent on the
inlet concentration
of sulfur oxidesin the flue 9a5.2 Scrubber
systemcapital costs for the 2,500 and 8,000 m3/sd
presented in Table 8-1.
$6.8 million.
The total
respectively.
8-2
capital
model
units
are
costs are $4.0 million and
J!
Tab~e8-1. CAPITAL
COSTFORSODIUM-BASED
HIGHENERGY
VE~NRI
SCRU831NGSYSTEMANDPURGEfRU~TMENTFOR ~1ODEL
UNITS
3
2,500 m /sd
Model Unit
8,000 m /sd
Model Unit
2.3
4.0
1.0
1.7
3.3
5.7
Contingency'
0.7
1.1
Total Capital Cast
4.0
6.8
-0.8
-1.4
Total
Indirect
Total
Costs b
Direct
Costs
Direct
and Indirect
ESPCdpitalCostCreditd
aCosts are reported in millions
fourth quarter 1980, delivered
See
Reference
of dollars, adjusted to
to a Gulf Coast location.
2.
bFlaterials and labor.

CTwentypercent of total direct and indirect costs.
From
Table
8-19.
8-3
The regulatory alternatives, showngraphically in Figure 6-1,

require sulfur oxides control efficiencies
to 93 percent,
feedstock quality and regulatory alternative.

using the sodiun-based
scrubber
gas stream.
For a particular
The annual cost of
system to control
is dependent on the quantity of sulfur
oxides
regulatory
Sulfur
removed
alternative
with inlet
sulfur
collection
from
the
I"
flue
is a direct
at the scrubber
cost com.ponent,alkali, varies significantly
oxides concentratipn
The other utility
oxides emissions
there
relationship between the sulfur oxides concentration

inlet.and the utility costs.2
Only one utility
depending on
and regulatory
alternative.
costs are constant because of the particulate
requirements of the scrubbing system.
To meet the particulate
NSPS,the scrubber liquid-to-gas ratio must remain constant throughout

the
range
of expected
sulfur
oxides
loadings
and removal
efficiencies.
Since the regenerator flue gas flow rate is constant for a given model
unit throughput,
scrubber
liquor
recirculating
pumps, waste treatment
equipment,
andotherequipment
operateat constant
conditions.Thus,
only alkali
consumption changes with flue gas sulfur
oxides
variations.
Alkali consumptionis assumedto vary proportionally with the scrubber

inlet loading2 andwith the level of sulfur oxides control required
for each regulatory
alternative.
The assumptions used to develop annual costs are summarized in

Table 8-2. Table 813 provides the bases for dete~nining annual costs.
Maintenance, capital cost recovery, tax, insurance. and administrative
costs
are calculated
Table
8-1.~
by applying
the ap'propriate
capital
cost ~rom
Annual costs for each model unit meeting Regulatory Alternatives II

through IV are presented in Tables 8-4 through 8-9. Two annual.costs
are reported for each model unit since either caustic soda or soda ash
may be used as the alkali.
Annual sulfur
oxides
emission
reduction
and cast effectiveness are reported for each modelunit and regulatory
alternative.
Annul: emission reductions are reported in P/lglyr, and
cost effectivenes~
, reported in g/Mg sulfur oxides removed. The
higher
annual
cos~
cost effectiveness.
scrubber
control
;dlue
with
caustic
soda
is
used
Because it may not be possible

efficiencies
to meet the levels

8-4
to
calculate
to scale
down the
of the regulatory
alternatives las little as 25 percent in some cases), a second net

cost, emission reduction, and cost effectiveness is shown for "full
scrubbing." Full scrubbing is defined here to meancontrol to 50 vppm

for the low sulfur model plants,
93 percent control
for the high
sulfur model plants to meet regulatory alternative IV, and 90 percent

control for allother cases. The costs have been revised to reflect
the higher degree of caustic consumptionand the emission reductions

have been revised to reflect the correspondingly high reduction in SO,
emissions.
8-5
Table8-2.
ASSUMPTIONS
USEDTO DEVELOP
ANNUAL
COSTS
Assumptions
i. NewFCCunits utilite high temperatureregeneration. Existing

units utilize either conventional regeneration with carbon
monoxide combustion promoters or a carbon monoxide combustion
furnace to combustcarbon monoxidein a controlled manner outside

the regenerator vessel. Sodium-based scrubbers will utili~e
high energy venturis unless the unit is equippedwith a carbon

monoxide
boiler.
2. The cost of treating the scrubber waste stream is included in

the scrubbersystan annual costs. The scrubber purge treatment
unit consists of below-groundpending for sedimentation of the
suspended solids (catalyst
fines)
and surface aerators
in below-
groundpondsto reduce the chemicaloxygendemandof the purge
streantoacceptable
levels
priortodischarge.
Inland
disposal
using evaporative ponds is discussed in Section 8.2.3.
Other
systems that have no wastewater discharge are presented in

Section
8.3.
3. Caustic(or soda ash) consumption is proportional to the amount

of sulfur oxides removedfor each regulatory alternative. All
other
utilities
remain
constant.
4. FCC
unit andscrubbersystemoperate357daysperyear (appraximately
98 percent availability),
based on a typical FCCunit, turnaround
of about 3 weeks every 3 years.
5.
Solid wastes consist primarily of catalyst fines.
The amountof
solid waste to be~disposedis calculated assuming90 percent
collection of 0.85 g particutate/Nm3into
the
scrubber.
6. The capital recovery factor (CRF)is based on a 10 percent

interest rate and~an expected service life of 15 years for the
scrubberandpurgetreatmentsystem.3
8-6
.i
Table 8-3.
Direct
BASESFOR DETERMINING
ANNUAL
COSTS
Operating
Costs;~;;0~rVI'S'
~Llll~
VV~*~
814.35/houra
Maintenance (includes materials,

manning, and overhead)
1.5 percent of total

cost
capital
Utilities
Electricity
b0.0652/kWhc
Water
$0.0625/m3d
Compressed
Air
s0.706/1,000
m3d
Caustic
$220/Mse
(8100/Mg)f
Soda (Soda Ash)
Steam
Polyelectrolyte
WasteDisposal
Indirect
Tax,
Operating
Insurance,
611.09/1,000
kgd
98.25/k99
B16.50/M9C
.Costs
and Administration
Capital RecoveryFactor
4 percentof total capital costd

13.15 percent of total capital
cost
"~ncludes 40 percent overhead. Reference 3.

See
Reference
2.
CCost from Reference4, updated to September 1980.

See
Reference
Reference 3.
4.
etiquid caustic soda, 100 percent.
F.O.B. Gulf Coast. Reference 5.
fLlk soda ash, light, 99 percent. F.O.B. Wyoming.Reference6, 7.

9Polymer3300, an anionic polyacrilomide settling agent. Fifty pound
bags, F.O.B.
Dallas, Texas.
Reference 8.
&7
'~'T?
Table 8-4.
ANNUAL
COSTOF SODIUM-BASED
HIGH ENERGY
VENTURI
SCRU8BING
FORMODEL
UNITSBYREGULATORY
ALTERNATIVE
- CASEla
Annual Cost, is thousanls'of
Reg. Ilt.
Direct
Operating
Il'
Reg. 41t. III
dollarsb
~eg. lit.
TV
50sts
Labor
44.0
44.0
nainten~nCe
60
50
1a.4
18.4
Water
a.4
8.4
Compressed Air
0.3
0.3
Jtilities
Electricity
Caustic Soda
36.5
(Soda.4sh)
73.6
[22.5)
(45.1)
Steam
0.9
r).g
Polyelectrolyte
4;0
4.0
5.8
5.8
Uaste Disposal
Indirect
Operating
Tax, Insurance,
Costs
and
Administration
Capital Retovery Cost

Total
Annual
-,
160
150
526
526
Cost
~it~ Caustic
Soda
(5oda A5h)
ESP Credit
860
900
(050)
(870)
-200
-200
NET ANNUAL COST
Uith Caustic
Soda
(Sod4rlsh)
Emission
700
(670)
130
260
5,080
2,690
760
760
450
450
1,690
1,590
Reduction
(MgSO, renavedlyr)
Cost
660
(650)
O
Eftectiveness
(S/Mg50x renoved)
FULL SCRUBBINGe
Net
Annual
Cost
With Caustic
Emission
Soda
Reduction
(Hg50, removed/yr)
Cost
Effectiveness
(3/Mg50, rencved)
"sdscdan data avai'~ble in Reference2. Casei: 2,500m3/sd;r~del

unit,
0.3 ~eight
~crEent sulfur
feedstock.
.bnumbers
maynot addto totals dueto rounding.Fourthquarter1950
dollars.
CNocontrols necessaryto meetthis regulatoryalternative.

ds,,~ on net annualcast with caustic soda.
egasedon central to 50 vppmwith caustic soda. leferenceS5.
878
Table 8-5.
ANN~ALCOSf OF SODIUM-BASED
HIGH ENERGY
VENT~LlI
SI;RUBBING
FOR#ODEL
UNITS
BYREGUU\TORY
ALTERNATI'IEa
- CASE
2
Annual Cost,
Direct
Operatiny
Costs
Labor
in thousands
of ddllars
Reg. Alt. ii
Reg. 41t. III
Reg. Alt. IV
44.0
44.0
44.0
60
60
60
19.4
18.4
18.4
8.4
8;4
0.3
0.3
Maintenance
Utilities
Electricity
Uater
8.4
Compressed Air
0.3
Caustic
Soda
(Soda Ash)
'
301
418
456
(234)
(256)
(2!9)
Steam
0.9
Polyelectrolyte
4.0
~. 4.0
4.0
5.8
5.8
s.B
Uaste Disposal
Indirect
Tax,
Operating
Insurance,
Costs
and
Administration
Capital Recovery Cost

Total
Annual
0.9
0.9
160
160
160
526
526
525
Cost
W~th Caustic
Soda
(Soda Asn)
ESP Credi t
1,210
1.240
1,280
(1,060)
(i,oao)
(1,100)
-200
-200
1.010
1,040
-7-00
NET ANNUAL COST
Uith Caustic Soda
(Soda Ash)
Emission
1.080
(860)
(sao)
(900)
1,340
1.470
1,600
760
710
680
Reduction
(Mg
50xramved/r)
Cost Effectiveness'
(S/Mg
50, removed)
FULLSCRUBBINGd
Net
Annual
Cost
~ifh Caustic
Emission
Soda
1.100
1.100
1,670
1.670
Reduction
(Mg50, removed/yr) 1,670

Cost
1.100
Effectiveness
(f/Mg50, removed)
660
660
d8ased on data available

In Reference 2. Case 2:
unit, l.S ueight percent sulfur feedstcck.
660
2.500 m'/sd
model
bNumbers
maynot add to totals due to rounding. Fourthquarter
1980
dollars.
CBased on net annual cost uith
caustic
soda.
dS,,~ ,, 90 percentcontrol rith caustic soda. Reference45.

8-9
iable
8-6.
ANNUALCOST OF SODIUM-BASEDHI~GHENERGYVENTURI
SCRUBBING
FORMODEL
UNITSBY REGULATORY
ALTERNATIVEa
- CASE3
Annual
Reg. Alt.
Oiroct
Operating
Cost,
in thousands
II
Reg. Alt.
--s~---
of dollars
III
Rea. Air.
;V
Costs
Labor
44.0
44.0
ad.g
naintenance
60
60
60
18.4
18.1
18.1
~ 8.4
8.1
8.4
0.3
0.3
0.3
--3
Utilities
Electricity
Water
Compressed Air
Caussic Soda
846
(SodaAsh)
884
(519)
ij42i
920
(564)
Steam
3.9
0.9
3.9
Polyelectrolyte
4.0
4.0
4.0
5.9
5.8
5.8
Waste Disposal
Indirect
Tax,
Operating
Insurance,
Costs
and
Administration
rotat
Annual
160
160
165
526
j26
525
Cost
With Caustic Soda
(SodaAsh)
ESP Credit
1.670
1,710
1.740
(1,300)
(1,370)
:1.390)
-200
-200
-200
NET ANNUAL COST
With Caustic Soda
(Sada Ash)
Emissian
1.470
1,510
1,500
(1,140)
(1, 170)
!1, 190)
2.970
3,100
3,230
490
490
dSO
1.520
1,520
1,540
3, 130
3,130
3,230
490
440
180
Reduction
(MgSOx'"OYedlyr)
Cost Effectivencssc
(f/Mg50, removed)
FULLSCRUBBINGd
Net
Annual
Cost
With Caustic Soda

Emission
Reduction
(Hg50, removed/yr)
Cost
Effectiveness
(JIM950x removed)
ag,sedondata availaolein Reference

2. Case3: 2,500m'/sdmodel
unit,
3.5 weighe percent
sulfur
feedstock.
blumbers
maynotaddto tPralsdue:o rounding.
Fourth
quarter
1980 dollars.
'8ascd on net annual cost uitk caustic soda.
ds,,w,, goper~ent
control'ar alternatives
II andIII and"3percen~
control
for alternative
IY wit~ caustic
8-10
soda.
Reference 45.
_'
Table 8-7.
ANNUAL
COSTOF SODIUM-BASED
HIGHENERGY
VENTURI
SCRUBBING
FOR
WOOEL
UNITS
BYREGULATORY
RLTER~ATIVE~
- CASE
4
Annual
Reg. dlt.
0-rect
Labor
Operating
test,
II'
in thousands
Reg. Alt.
Costs
III
of
dollars
Rag. Alt. IY
44.0
Maintenance
44.0
102
132
Utilities
Electricity
j8.7
js.i
Uater
25.1
25.1
3.3
0.3
Csmoressed Air
Caustic Soda
/Soda Asn)
Steam
Polyelectrolyte
Waste Disposal
Indirect
Tax,
Operating
Insurance,

Annual
236
(73)
j116)
2.6
2.6
12.0
12.0
18.5
18.6
Costs
and
Administration
Total
118
272
272
894
894
Cost
With Caustic
Soda
(Soda Ash) ~
ESP Credit
1,550
1,670'
(l,soo)
(i,jao)
-330
-330
NET ANNUAL COST
With Caustic
Soda
(Soda Ash)
Emtrsion
1,340
(1.250)
410
830
2,980
1,610
1.510
1.510
1,440
1,440
1.050
1,050
Reduction
(Mg50, renoved/yr-)
Cost
1,220
(1,1?0)
Erfectiveness
(S/MgSD,removed)
FULLSCRUBBINGe
Net
Annual
Cost
With Caustic
Gnission
Soda
Reduc~~on
(MgSO,renoved/yr)
Cost
Effectiveness
(S/Mg
50, removed)
d8ased on data available
unit,
0.3 weight
percent
in Reference 2.
sulfur
Case 4:
8,000 m'/sd model
:eedstock.
bNumberssay not add to totals due to rounding. Fourth quarter

1980
dollars.
CNocontrols necessary to neef this regulatory alternative.

ds,,~ ,,,,t
annual cost with caustic rods.
egased on control to 50 vppmwith caustic soda. Reference 15.
8-11
Table8-8. ANNUAL
COST
OFSOOIUM-BASED
HIGH
ENERGY
VENTORI
SCRUBBING
FOR
NODEL
ONITS
BYREGUBATORY
~LTERNATIVEa
~ CASE
5
Annual Cost, in thousands o' dollarsb
Reg. Alt. II
Direct
Operating
Reg. Alt. III
Reg. 41t. [Y
44.0
54.0
Costs
Labor
44.0
Naintenance
102
102
IoB
Utilities
Electricity
58.7
56.7
58.7
Uater
25.1
25.1
25.1
0.3
0.3
0.3
CompressedAir
Caustic Soda
1,220
(SodaAsh)
Steam
ilaste Disposal
Tax,
Operating
Insurance,
'2.6
2.6
12.0
It.O
12.0
18.6
18.5
1C.G
Casts
Capital RecoveryCost
Annual
(902)
and
Administration
Total
1,460
lats)
2.6
Polyelectrolyte
Indirect
1,340
(755)
j :ij
272
272
272
894
894
894
Cost
With Caustic Soda
(SodaAsh)
E5P Credit
2,650
2,770
2,890
(2,180)
(2,260)
(2,331)
-330
-330
-330
NET ANNUAL COST
WithCaustic Soda
(SodaAsh)
Emission
2,320
2,440
2.560
(1,850)
(1,928)
(2,000)
4.290
4.710
5,123
540
518
500
Reduction
(Mg50, renoved/yr)
Cost Effectiveness'
(3/Mg50, removed)
FULLSCRUBBINCd
Net Annual
Cost
With Caustic Soda
2.630
2.630
2,630
(HgSO,removed/yr) 5,350
5.350
5,350
490
490
Emission
Cost
Reduction
Effectiveness
(S/Mg50, removed)
490
a8asedondataavailablein Reference'. Case5: a,000m3/sdmodel

unit,
1.5 weight percent
sulfur
feedstock.
bNumbers
maynot add to totals due to rounding.
1980
dollars.
Fourth quarter
C8asedon net annual cost Htth caustic soda.
ds,,,don90perFeot
cPntrol
withcausri,roda.9eference
cl.
8-12
i.
i:a
Table
8-9.
ANNUALCOST OF SODI~M-BASEDHIGH ENERGYVENTURI
SCRUBBING
FORMODEL
UNIfS BYREGULATORY
ALTERNATZVEa
- CASE6
Annual
peg. Alt.
Direct'~perating
Costs
Labor
naintenanCe
Cost,
II
in
thousands
Reg. ~lt.
$4.0
of dollars
III
Reg. Alt.
44.3
102
Iv
14.0
102
102
Utilities
Electrlci ty
58.7
58.7
Water
25.1
25.1
0.3
0.3
Compressed Air
Caustic
Soda
(Soda Ash)
Steam
Polyelectrolyte
Waste Disposal
Indirect
Tax,
Operating
and
Capital. RecoveryCost
Annual
25.1
0.3
2.710
2.830
2,950
(1,675)
(1,750!
(1.820)
2.6
2.6
2.6
12.0
!2.0
12.0
18.6
18.6
18.6
Costs
Insurance,
Administration
Total
58.7
272
272
272
894
894
894
'Cost
With Caustic Soda
(Soda Ash)
ESP Credit
4.140
4,260
4.370
(3,100)
(3,180)
[3,250)
-330
-330
-350 .
NET ANNUAL COST
With Caustic
Soda
(Soda Ash)
Emission
3.810
3.930
4,040
(2770)
(2,850)
(2,920)
Reduction
(Mg50, removedlyr) 9.500
9,910
10,300
400
390
Cost Effectivenessc
(s/MgSO,removed)
400
FULLSCRUBBINGJ
~et
Annual
Cost
With Caustic
Emission
Soda
3,950
3,950
Reduction
(M9SDxre~noved/yr)9,990
Cost
9,990
10,300
Effectiveness
(f/MgSO,raooved)
400
agasedondata availablein Reference
2.
unit,
4,040
3.5 weight percent
julfur
bOO
390
se 6. 8,000m3/sd~odel
feedstock.
bnumbers
rmynot add to totals due to rounding. Fourthquarter 1980dollars.
CBased an net annual cost with caustic
soda.
da,sed on 10 percent control for alternatives II and I~I and 93 percent

for alternative
Iv with caustic
soda.
8-13
Reference
45.
FromTables. 8-4 through 8-9, net annual costs for model units
rangefrom~about
$1.1millionfor a 2,500m3/sd
unitprocessing
0.3weight
percent~sulfur
and meeting Regulatory Alternative
; J
III to 94.0 million
for an 8,000 m /sd unit processing 3.5 weight percent sulfur and
meeting
Regulatory
Alternative
ZV.
For these
two units,
annual sulfur
oxides emission reductions range from 130 to 10,300 Mgand cost
effectiveness ranges from95,080 to 9390/Mgsolfur oxides removed,

respectively.
8.2.2Capital
andAnnual
testsforSodium-based
jet~Ejectar
Venturi
i~
Scrubbers
Jet ejector venturis wouldbe utilized with sodium-based

scrubbing
for FCCunits equipped with a carbon monoxidecombustion furnace.
Under these conditions, additional energy is required to movethe
regenerator flue gas through the scrubber and out the stack. A jet
ejector~type venturi serves- this purpose.
It is estimated that two of the modified/reconstructed
units
projected in Table 7-5 will employa jet-ejector type venturi. And,
in orderto assessnationwide
impacts
of sadium-based
scrubbing,
it is
assumed that these two units are characterized
by one small and one
large FCCmodel unit, each charging a 1.5 weight percent sulfur feedstock.
The capital costs for sodium-basedscrubbingwith a jet-ejector

type venturi are higher than that of high energy venturi scrubbers.
The higher costs are attributed to the additional piping, pumps,and
spray nozzles that comprise the jet ejector scrubber system as discussed
in Section 4.2.2.2. FromTable 8-10, the total capital costs for jet
ejector sodium-basedscrubbingsystems applied to 2,500 m3/sd and
8,00(1
m3/1d
model
unltlareJ5.5million
and59.6million,
respectively.
Annualcosts far sadium-basedscrubbingare also higher with jee
ejector venturisas compared

to the highenergyventuris. Thehigher
cost is largely due to the additional electrical requirementof jet
ejector venturi scrubbers as discussed in Section 7.3.3.
Tables 8-11
and8-12itemizethe annualcostsfor a 2,500m3/sdunit andR,000m3/sd

unit baseduponjet ejector venturi scrubbers. Thecost effectiveness
for these units ranges from 81,120/M9sulfur oxides removedfor a
small model unit Regulatory Alternative II to 9740/Mgsulfur oxides
removedfor a large model unit under Regulatory Alternative III. As
in Tables 8~3 through 8-9, a separate cost and emission reduction is
shown for a 90 percent, "full scrubbing" case.
8- 14
l_i
Table 8-10.
CAPITAL
COSTFORSODZUM-BASED
JET EJECTOR
VENTURI
SCRUBBINGSYSTEMAND PURGETREATMENTFOR
MODELUNITSa
Total Direct
2,500m3/sd
8,000m3/sd
Model
Model
3.3
5.6
1.3
2.4
4.6
8.0
Contingency"
0.9
1.6
Total Capital Cost
5.5
9.6
-0.8
-1.4
Indirect
CostsP
Unit
Costs
Total Direct
and Indirect
ESPCapitalCostCreditd
Unit
aCosts are reported in millions of dollars, adjusted to

fourth quarter 1980, delivered to a Gulf Coast location.
See
Reference
2.
b~,terials and labor.

CTwentypercent of total direct
From
Table
8-19.
&15
and indirect
costs.
::4
1::9
1~
Table 8-71.
ANNUAL
COST OF SODIUM-BASED
JET EJECTORVENTURI
--~1
SCRUBBING
FOR MODEL
UNITS BY REGULATORY
ALTERNATIVEa
- CASE 7
Annual
Cost,
in thousands
Reg. Alt. [1
Oirect
Operating
Reg. ~lt.
-s
of dollars
[11
~eg. Alt. IY
Costs
Labor
44.0
44.0
4$.0
ilaintenance
82.i
gZ.5
81.i
ii
Utilities
Electricity
235
235
235
uarer
8.1
g.a
a.4
Compressed Air ~
0.3
0. 3
0.3
Caustic Soda
381
418
456
(soda Ash)
j?34)
(256)
(279)
Steam
0.3
0.9
0.o
Palyelectrolyre
4.0
4.0
Q.O
5.8
5.8
5.8
Waste Disposal
Indirect
Operating Costs
Tax, Insurance,
and
Administration
Total
Annual
220
220
220
723
723
723
Cost
With Caustic Soda
1,700
(SodaAsh)
1,740
1,780
(1,563)
(1,580)
( 1,600)
-200
-200
-iao
1,500
(1,360)
1,540
(1,380)
1.580
(1.400)
ESPCredit
NET ANNUAL COST
With Caustic Soda

(SodaAsh)
Emission
Reduction
(PlgSOx'emaved/y~)
1,?40
1.470
~ 1.600
1,120
l.(jSO
990
1.600
1,600
1,600
1,670
:,670
1,670
Cost Effectivenessc
(9/n9 50x removed)

FULL5tRU89INtd
Net Annual
Cost
With Caustic Soda

Emission
Reduction
(M950, rengved/yr)
Cost
Effectiveness
(5iMg50x "Oved)
960
960
d3ased
ondataavailablein Reference
2. Case7: 22,500
~
unit,
1.5 weighs percent
bNum~ers
may not
1480 dollars,
sulfur
add to totals
feedstock.
due to rounding.
960
3'~ model
n'isd
Fourth quarter
CBasedon net annual cost *i~h caustic soda.
dgased
on90percentcontrolwithcausticsoda, Reference
45.
8-16
_1
Table
8-12.
ANNUAL COST OF SODIUM-BASED JET EJECTOR VENTURI
SCRUBBING
FORWODEL
UNITSBYREGULATORY
ALTERNATIVE"
- CASE8
Annual
Reg. n't.
Direct
Operating
Costs
Labor
cost,
rI
in
Reg. ~lt.
44.5
HaintBnance~
thousands
III
of dollars
Rag. 41t. I~
44.0
34.0
144
144
134
7-54
754
754
Utilities
Electricity
Water
CompressedAir
Caustic
Soda
0.3
0.3
1,340
1,460
(902)
2.6
2.6
2.6
12.0
12.0
12.0
18.6
18.5
~ 18.6
Waste Disposal
tests
and
Administration
384
Annual
0.3
(829)
Polyelectrolyte
Total
25.1
(755)
Steam
Opera~ing
Insurance,
25.1
1.220
(Soda Ash)
Indirect
Tax,
25.1
384
1,251
1,261
384
1,261
Cost
With Caustic
Soda
(Soda AshJ
3,870
3,990
4,110
(3,400)
(3480)
(3,550)
-330
-330
ESP Credit
-330
NET ANNUALCOST
With Caustic Soda
(Soda Ash)
Eml ssf on
3.540
3,660
3.780
(3.070)
(3.150)
(3,220)
4.290
4.710
5,120
830
780
740
Reduction
(Hg50, removed/yr)
Cost Effectiveness"
(S/Mg
50, removed)
EULLSCRUBBINGd
Net
Annual
Cost
With Caustic
Emission
Soda
3,850
3.850
5.350
5.350
5,350
Reduction'
(MgSO,removed/yr)
Cost
3.850
Effectiveness
(S/Mg
M, renoved)
720
720
720
'8asedon dataavailablein Reference
2. CaseB: 8,000m3/sdmodel
unit,
l.S weight percent
sulfur
feedstock.
bnunbers maynot add to totals due to rounding. Fourth quarter

1980 dollars.
CBased on net annual cost with caustic
soda.
dgased on 90 percent Control with caustic soda. Reference 45.

8-17
8.2.3 WaterandSolid WasteCost Impacts

Thepurgestreamfromthe sodium-based
scrubberis treated prior
to discharge to coastal waters. Thewastewatertreatment systemcosts
are included with the scrubber system costs in Tables 8-1 and 8-4
through8-12. Thetreatmentsystemrepresentsapproximately
25percent
of the total direct cost reported in Tables 8-1 and 8-10, and 30 percent
of.the annualcost of utilities reportedin Tables8-4 through8-9

and 8-11
and 8-12.
1~
Thefive refinerieswithsodium
scrubbersin placefor sulfur
oxidescontrol are in or near coastal locations and dischargethe
treated scrubber wastewaterto large rivers or coastal waters. Refiners
in inland locations considering the sodium-basedscrubber for FCC
sulfur oxides control maynotbe able to discharge the treated scrubber
wastestreamto inland bodies oQwater due to water quality considerations
and discharge permits. For these inland refiners, vapor compression
distillation, muitistagedflash evaporation,evaporationponds,reverse

osmosis, or deep well injection
of the scrubber effluent.9
may be viable approaches
for disposal
Of the 102 sodium scrubber systems currently
in use on industrial boilers, about80 use evaporationpondsand

10 use centralized water treating systems. The remainderuse varied
approachesrangingfromdischargeto city sewersto deepwell injection.

The use of sodium-basedscrubbers, however,maynot be feasible
for someinlandFCCunits. Onelimiting factor is the availability of

sufficient waterto operatethe scrubbingsystem. Asecondlimiting
factoris theabilityto disposewastewater

produced
bythis scrubber
system. Basedon industrial boiler use, evaporationpondswouldbe
the likelymethod
for wastedisposal. However,
the useof evaporation
ponds is limited to certain geographic areas of the country where
annualevaporationrates exceedthe annualrainfall.l0 Analternative

to evaporation ponds is to dilute the wastewaterand discharge to
surface waters (providingthe necessarywater resourcesexist).

Dueto the problemsassociated with sodium-basedscrubbers mentioned
above, it is an-.icipatedthat somerefi.nerswill opt to employcontrol

technologieswi:h less severe water and wastewaterdischargerequirements.
8-18
These control systems are discussed in Chapter 4, and their
environmentalimpacts are presented in Section 7.4. Costs for these

alternativecontrol
technologies
are presented in Section 8.3.11
No additional solid waste cost impacts are anticipated through

addition
8.2.4
of sodium-based
scrubbers
for
control
of sulfur
oxides.
Nationwide Cost Impacts
The projected nationwide cost impacts for sodium-basedscrubbing
are presentedin Table8-13alongwiththe costs for the other control

technologies discussed in Section 8.3.
The nationwide cost impacts
assumethat all FCCunits subject to standards of performancewill

employthe samecontrol technology. Theseprojections are calculated
usinganticipatedFCC
unitconstruction,modification,andreconstruction
from Tables 7-4 and 7-5 and the capital
model
and annual costs for each
unit.
The. cumulative 5-year capital
costs forsodium-based scrubbing
are 672.lmillion for RegulatoryAlternative II and 980.7million for
RegulatoryAlternativesIII and IV. Annualcosts in the fifth year of

the standard, 1986, are based on scrubbingwith caustic soda. Annual
costs in the fifth year of the standard are ~32.1 million, 935.3 million,
and k36.7million for RegulatoryAlternativesII, III, and IV, respectively.

8.3
OTHERCONTROL
TECHNOLOGY
COSTS
Thefollowingsections present costs for alternative control

technologieswhichmaybe applied to FCCunits to control sulfur
oxidesemissionsto the level of the regulatoryalternatives. While

these control technologies are not presently commercially applied to
FCCregenerators.it is likely that these couldbe consideredas

necessary for specific applications.
These control technologies,
discussedin Chapter4.0, are analyzedan similarcost basesas the

sodjum-basedscrubber in order to comparethe costs of the different
systems.Thecostsare updated
to fourthquarter1981dollarsusing
Nelson Cost Indexes and many assumptions used in the sodium-based
scrubberare used in the other systems. For example,all capital

costs.include
i:
a 2O;percent contingency, and the annual costs assume a
15-year
life for determining
the capital recoverycosts for each
system. Thesameunit costs for utilities andoperatinglaborand
materials are also used in each system.
&19
Table 8-13.
COMPARISON
OF FIFTH-YEAR
NAT~ONMIDE
SCRUBBERSYSTEM COSTS
(Thousandsof Fourthauarter 1980Dollars)
j::1
Nationwide
Costsa'b
III
IV
Five-Year Capital Cost
Sodium
Based
Uellman-Lord
72,100
106,000
80,700
116,000
80,700
119,000
DualAlkali
35,700
45,700
47,200
Citrate
SprayDrying
56,100
53,200
60,500
59,700
60,500
59,700
32,100
35,300
36.700
Fifth-Year Annual Cost
SadiumBased
Sodium Based (full
scrubbing)
35,000
37,300
37,500
Wellman-Lord
28,200
31,200
3=,900
DualAlkali
Citrate
SprayDrying
16,400
25,900
15,900
19,100
18,100
20,100
20,100
5,430
32,600
"The costs reported assumethat all
new and nodified/reconstructed
units will employ the scrubbing system costed.
FCC
bThenationwidecasts for eac~scrubber systemare calculated by multiplying

the costs per modelunit by the projectednumberof modelunits subject
to standards of performanceunder each regulatory alternative. A
schedule of modelunits subject to the regulatory alternatives is
provided
in Tables 7~4 and 7-5.
Reference
8-20
ii.
An itemized
cost table
for each control
technology
is presented
for a ?,500m3/sdand8,000m3/sdmodelunit assuming

a 1.5 percent
suTfur feedstock subject to Regulatory Alternative
III.
This scenario
corresponds to a 1,400 vppmsulfur dioxide inlet concentration and

control to 300 vppm. Table 8-13 presents a comparison of the nationwide
control costs based on the different control technologies and regulatory
alternatives.
The nationwide costs report the cumulative 5-year
capital cost and the fifth year annual cost for each control technology.
The nationwide costs assume that all affected facilities
employ the
same control.technology.
This analysis provides a basis for comparing
the system costs; however, it is unlikely that any one control system
will be relied upon for all FCCunits,
In addition, the sodium-based
system costs are from actual FCCregenerator application experience.

Other systems will likely incur increased costs to increase their
on-line reliability
8.3.1
Duai Alkali
to match that of the FCCunit.

Flue
Gas Desulfurization
The costs of applying dual alkali scrubbers to FCCunits are

presented in this section. Cost informationwas obtained froma dual
12,13 The itemized capital and annual costs for the
alkali
vendor.
model units are given in Table 8-14 for a 1.5 weight percent sulfur
feedstock. 8ecause the dual alkali system employs a packed tower
absorber, the system does not afford the secondary advantage of
particulate control as was the case for sodium-basedscrubbers.

Therefore,
credited
the annual costs

to the dual
alkali
of an electrostatic
system
precipitator
are not
costs.
Accordingto the dual alkali vendor, the dual alkali system is

not feasible for flue gas concentrations of less than 800 vppm sulfur
dioxide. Lowscrubber suffur dioxide inlet concentrations would
result in a high level of nonregenerablesulfate present in the scrubbing
liquor.l5 Entheseapplications,a single alkali systemwouldbe

applied.~ Hence,in order to determinenationwidecost impacts, sodiumbased scrubbing costs as discussed in Section 8.2 are used for the
projected units processing feedstocks with low sulfur content (0.3 weight
percentsulfur, correspondsto a 400vppmin!~t sulfur dioxidelevel).

Nationwide costs
are reported
in Table 8-13.
8-21
Table 8-14. DUALALKALISCRUBBING

SYSTEM
COS~TS
BASED
ON 1.5 WEIGHT
PERCENT
SULFUR
FEEDANDREGULATORY
ALTERNATIVE III
(Costs Reported in Thousandsof Dollars)a
2,500 m /sd
Model
CAPITAL
Unit
8, 000 m' /sd

Model Unit
COSTS
Equipment
827
1,504
Construction
Engineering
451
226
818
404
Total Capital Costs

ANNUAL COST
1,504
------2,726
Direct Operating Costs
Operating
Labord
31
61
Maintenance'
23
41
27
LimeS
80
248
Electricityh
50
157
96
301
60
109
198
358
547
1,305
Utilities
SodaAshf
Water'
WasteDlsposalj
Indirect Operating Costs
Tax,
Insurance,
and Administrationk
Cdpital RecoveryCostl
TOTAL
ANNUAL
tOSTS
EMISSION
REDUtTIDN
(WgSOZremoved/
year
COSTEFFECTIVENESS
(BdMgof
S02 removed)
Footnotes are on the next page.
8-22
1,470
4,710
372
277
c7
Table 8-14.
DUALALKALISCRUBBING
SYSTEMCOSTSBASEDON
1.5 WEIGHTPERCENTSULFURFEED ANDREGULATORY

ALTERNATIVEIII
(Concluded)
aNelson cost indexes were used to adjust costs to fourth quarter 1980
dollars.
bReferences 12, 13.
CThecapital costs include 20 percent contingency. Reference14.
d0peratinglabor cost basedon 814.35per man-hour.Operator~abor
are 6 man-hours/day for the small model plant; 12 man-hours
requirements
per day for the large model plant.
Reference 15.
eMaintenancecosts are calculated as 1.5 percent of the total capital

costs.
Reference
4.
Soda ash costs are based on use of 100 percent soda ash at 8100/Mg.
Soda ash requirement for the small unit is 9.07 kg/hour;

model unit, 31.8 kg/hour. References 6, 7, 15.
gLime costs are based on $62/Mg lime.
for the large
Lime requirement for thc small
unit is 149 kg/hr; and 467 kg/hr for the large model unit.
Reference 15.
hElectricity costs based on 80.0652/kWh.Electricity requirementsare

90 kU for the small model unit; 280 kU for the large model unit.
References
4,
15.
iUater costs are based on B0.0625/m. Water requirements for the small
model unit are 0.0464 m3/min, for the large model unit, 0.132 m3/min.
References
4,
15.
JSased on waste disposal cost of 91ti.50/Mg. Waste disposal requirements

for the small model unit are 5,831 Mg/year; for the large model unit,
18,271 Mg/year.
References 4, 15.
kCalculated as 4 per~ent of the total capital cost.
ReferenceQ.
Cost is basedon a life of 15years and10 percent interest. tapital
is calculated by 0.1315 x total capital cost. The vendor

cost
indicates a service life ranging from 15 to 25 years. References 4, 15.
recovery
8-23
8.3.2
Wellman-Lord
Capital and annual costs for the Wellman-Lord

flue gas desulfurization
systemwere
providedby a vendor for the FCCunit parametersgiven in
18-20
Table
6-2.
Both capital and annual costs for this system are
dependentuponflue gas air flow rates and the degree of sulfur oxides
removal required.
process consists
As discussed in Section4.2.6.1,
of two stages.
The capital
the Wellman-Lord
cost for the absorber
stage is depend~~tuponair flow and the regenerator uponsulfur

oxides removal.'" Itemiled costs for the Wellman-Lord
system as
applied to FCCunits is presented in Table 8-15. These casts are
basedon a 1.5 weightpercentsulfur feedstockandcontrolto Regulatory

Alternative:III,400vppm
502
The Wellman-Lord
vendor indicated that the sulfur dioxi.derecovered
would be further processed at an existing Claus plant for sulfuric
acid or elemental sulfur. Usinga mass ratio of 2:1 sulfur dioxide to

elemental sulfur, a product credit was applied to the total annual
costs based on elemental molten sulfur. Credit for particulate control
is also includedin the net annualcosts; however,it has not yet been
determinedwhetherthe venturi scrubber will satisfy the particulate
emissions limit because the system has not been applied~to commercial
FCC units.
8.3.3 Citrate FGDSrsten Costs
The capital and annual costs for a citrate flue gas desulfurization
system have been scaled according to the modelunit parametersby
applying
factorsprovided
bya citrate vendor.llThecapitalcosts
for citrate systems are dependentuponthe flue gas flow rate and the
flue gas sulfur dioxideconcentrationfor the FCCunit application.

Operatingcosts for a citrate systemare also dependentuponthe
amountof sulfur oxides reduction. Far example,the citrate system
requires both citric acid and soda ash in amountswhichvary with
sulfur dioxide removal from the inlet flue gas.
the citr'ate systemrecovers elemental sulfur, and hence, this

recovered product is credited to the total annual costs. In addition,
the annual costs of an electrostatic precipitator are credited to the
citrate annual costs because the citrate system venturi scrubber would
provide particulate control. However,vendors caution that it remains
8-20
Table8-15. ~WELLMAN-LORD
S02RECOVERY
SYSTEM
COSTS
BASEDON 1.5 WEIGHTPERCENTSULFURFEED ANDREGULATORY
ALTERNATIVE III
(CostsReportedin Thousands
of Dollars)~
2,500 m'/sd
Model
,,,..,.,.,.,
,,,,,b ,C
TOTAL CAPITAL COSTS
Unit
8,000 m.'/sd
Model
Unit
5,000
8,200
200
328
175
287
65
93
10
30
96
203
651
200
328
658
1,078
ANNUAL COSTS
Operatinglabore
Labor and Supplies f
Maintenance
Utilities
Elec~ricity9
Water
Soda Ash
Steamj
Indirect Ooerating Costs
Tax, Insurance,
and Administration
Capital
Recovery Cost 1
TOTAL
ANNUAL
COSTS
PRODUCT
RECOVERY
CREDllm
ESPCREDIT"
1,534
-102
-200
2,871
~327
-330
NETANNUAL
COST
1,232
2,214
EMISSION
REDUCTZON
(Mg502 removed
lyear)o
1,470
4,710
COST EFFECTIVENESS (B/M9 of
50, removed)
Footnotes
are
on the
next
838
page.
8-25
470
Table8-15. WELLMAN-LORD
S02RECOVERY
SYSTEM
COSTS
BASEDON 1.5 WEIGHTPERCENTSULFURFEEDAND
REGULATORY
ALTERNATIVE
III (Continued)
aNelsoncost indexes were used to

dollars
b'rotal
19.
Costs
except as nofCd.
adjust
costs
to fourth
quarter
1980
capital costs include 20 percent contingency. References17,

supplied
relate
to a
gas flow of 3030 scmm (8,500 mj/sd unit).
For other gas flows, costs were adjusted according to.information

provided
by vendor.
Reference
18.
Annualcasts are determinedbasedon 347operatingdays per year.
egasedon 4 percentof total capital cost. Reference

21.
fg~sedon3.5 percentof total capitalcost. Reference

21.
9Based on small unit electrical
requirement of 115.7 kW, large unit
166 kWand electricity cost of g0.0652/kWh.References4, 18, 20.
hWaterrequirementis the net make-up
to the
scrubber.
For
the
small
unit, this is 0.098 m'/min, for the large unit 0.314 m3/nin. Water
cost is 80.0625/m3.
References 4, 18, 20.
'Soda ash requirement for the large model unit is 0.112 Mg/hr. Requirenents
for small modelunit are scaled according to respective air flow rates.
Soda ash cost is 8100/Mg for 100 percent
20.
soda ash.
References
4, 18,
Steamrequirementsare a function of the quantity of sulfur dioxide

stripped
from the evaporator
flue gas and were supplied for the large
unit (3030scmm).asStreamrequirementsfor the small unit (950scmm)
may be determined
and the ratio
of
large unit.
the
the product of the large unit steam requirements
quantity of sulfur dioxide removed relative
Steamcost is 811.09/M9. References4, 18, 20.
kTax,insurance,
andadministration
is basedon
capital
cost.
Reference
4.
4 percent
to the
of total
Basedon 15-year expectedservice life and 10 percent interest rate.
The capital
Reference
recovery cost is calculated
4.
8-26
as 0.1315 x total
capital
cost.
-s
Tab~e8-15. WELLMAN-LORD
S02RECOVERY
SYSTEM
COSTS
BASEDON t.5 WEIGHTPERCENTSULFURFEED
AND REGULATORY
ALTERNATIVEIII
~Concluded)
mproduct recovery credit is based on the annual ~eductions in sulfur

dioxide emissions (Mglyr) from the baseline case and a product recovery
credit of b138.80 per Mgof elemental molten sulfur. Reference 22.
"The annual costs for an electrostatic
precipitator (ESP) are credited
because the system includes a variable throat venturi for flue gas
saturatidnand particulate control.

Reference
ESPcosts aregiven in Table 8-23.
17.
OCalculated from scrubber inlet SO, concentration
92 percent removal efficiency.
of 1,400 vppm and
Modelunit air flow rates are 945 scmm
for the small model unit and 3030 scmm for the large model unit.
8-27
unprov.enwhether the venturi will provide adequate particulate control
for compliance
with the existing FCCunit regeneratorNSPS.29itemized
capital
8.3.4
and annual costs
are reported
in Table 8-15.
Spray Drying
Capital and annual costs for spray drying are given in.Table 8-17
for model units on a comparable basis as the sodium-based scrubber
costs. Spray drying costs are primarily a function of regenerator

flue gas air flow rates,
However,annual costs for this scrubber
systemare also determined

bythe amount
of sulfuroxidesreduction
required. The costs for waste disposal, electricity, and pebble lime
vary with the level of control.30 The annual costs for an electrostatic
precipitatorare creditedto the spraydryingcosts becausethe system
controlsparticulateemissions
in additionto sulfurdioxideemissions.33
8.3.5 Sulfur OxidesAeductionCatalysts Costs
The use of sulfur oxides reduction catalysts as a sulfur oxides
emissioncontrol technique has thus far been confined to pilot tests

and a few commercial tests; hence, the available cost information is
limited. Twocommercialscale test demonstrationsof this control
technologyfromtwo3,500mJ/sd500units eachprocessingapproximately
1 weightpercent feed sulfur incurred a S900/Mgincremental cost for
sulfuroxidesemission
reduction.35Theoperating
cost for the control
additive in these tests was reported to be about $1,400/dayor
approximately
80.40/m3
of freshfeed;catalyst
costis S1,800/Mg
as
loaded.35
Sulfur
oxides
reduction
catalyst
costsof 50.30
to SP.60/m3
of freshfeedhavebeenreported.34,36
Fifth-yearnationwide
annual
costs far the catalyst technologycan be determinedusing anticipated
FCCunit construction and reconstruction fromTables 7-4 and 7-5 and
the catalyst
cost figures from above.
The fifth-year
nationwide
annual costs of Regulatory Alternatives II through IV calculated this
wayare 910to ~20million, assumingthe catalyst technologyis applicable

to all modelunits for each of these alternatives.
Nocapital costs
are anticipated for the catalyst technology. The cost of sulfur

oxides reduction catalysts per amountof sulfur oxides removed can be
calculated by dividing the fifth-year nationwidecosts by the emissions

reductions in the fifth year, asreported in Table 7-6. Costs determined
this way are approximately 9200 to 9400/Mgsuffur oxides removed.
8-28
Table
8-16.
CITRATE FGD SYSTEM COSTS
BASEDON 1.5 WEIGHT

PERCENT
SULFUR
FEEDANDREGULATORY
ALTERNATIVE TII
(Costs Reportedin Thousandsof Dallars)a

3
2,500
m /sd
Model
Unit
8,000
m /sd
Model
Unit
CAPITAL COSTS
Direct Costsb
Indirect
CostsC
d
Contingency
TOTAL
CAPITAL
COSTSe
1,720
2,310
616
827
584
784
2,920
3,920
ANNUAL COSTS
DirectOperating'
Costs
OperatingLaborf
General Maintenance9
h
Operating Materials
260
260
149
149
14.3
45.0
Ut ii i t.i es
Electricity
186
Waterj
Steam
Negligible
349
Waste Disposal
2.4
415
Negligible
781
7.5
Indirect Operating Costs

Tax, InSuranCe,
and Administration
Capital RecoveryCost"
TOTAL
ANNUALIZED
COSTS
PRODUCT
RECOVERY
CREDITO
ESPCREDTTP
NETANNUAL
COST
EMISSION REDUCTION
(Mg
S02'emovedlyear)
COST EFFECTIVENESS (B/Mg of
SO, removed)
Footnotes
are
on the
next
page.
&29
117
157
384
515
1,460
~298
~200
962
~3,330
-940
-330
1,060
1,470
4,710
654
225
Table 8-16.
CITRATEFGDSYSTEMCOSTS
BASEDON 1.5 WEIGHT

PERCENT
SULFUR
FEEDANDREGULATORY
ALTERNATIVE
III
(continued)
aNelsoncost indexes were used to adjust costs to fourth quarter 1980

dollars
except as noted.
bsasedon 2.18 x
calculated
major equipment cost.
based on a citrate
equipment
cost
equipment
costs
of
81.3
million
for citrate
FGDwere adjusted using the following
equation:
Major Equipment
31.3 x 0.45 x
Major equipment costs were
instaIlation which incurred a rnaJor

(Januaryi, 1979,dollars). ~ajor
Cost =
4,800
scr~n
.7
.7
+ 81.3x 0.55x 2500ppm X1'177
Where: a = design flue gas flow rate of cit.rate systembeing

costed,
scmm
b = flue gas SO, concentration of systembei-ngcosted,

ppm
1.177 = escalation factor to adjust to fourth quarter 1980

dollars.
References
4, 23, 24.
CBased
on0.78x the majorequipment
cost. Theindirectcosts include
engineering costs as 14 percent of the total capital costs.
Reference 4.
dgased
on2bpercentof total capitalcost. Reference
4.
eRepresents
3.7 x major.equipment
costs. References
4, 23, 24.
Model unit labor hour requirement is 17,136 man-hours
per
operators and 1,017 nan-hours per year for supervisors.

814.35 per man-hour.
References 25, 26.
year
for
Labor cost is
qBased
onlaborrequirement
of 5,200
man-hours
peryear,914.35
per
man-hour,
and material as 100 percent of maintenancelabor. Reference4,
25.
h0perating
materialsincludecitric acidandsodaarh.
Small
model
unit
requites 5.1 Mg/yrof citric acid and 61.8 li~g/yrof soda ash. Large
model
unit requires
16.3 Mglyrof citric acid and 195 ~glyr of soda
ash.
Citric
acid cost
is BZ,570/Mg
and soda ash cost is S100/Mg.
References
G, 7, 27, 28.
8-JO
Table 8-16.
CITRATEFGD SYSTEMCOSTS
BASEDON 1.5 WEIGHT

PERCENT
SULFURFEEDANDREGULATORY
ALTERNATIVE
III
(continued)
i Electricity
cost is Q0.0~52 per kWh. Basis for electricity

was calculated using the following equation:
requirement
electricity
required
ik)ih
x 106)=8.2x 106
~a6 0.7
Where a = gas flow of citrate
References
4, 23,
system being costed, scmm
28.
jsasis for water requirement for non-water cooled citrate systemwas

given as 151 mj per year,
cost is 90.0625 per ms.
for an annual expenditure
of S9.50.
Water
References 4, 25.
ksased on sulfur flow being the major determinant of steam consumption,

79,600
Mg of steam
8,100 Mg of sulfur
different
amounts
consumed per year for a citrate system recovering

for relating
per year, and assuming a relationship
of sulfur
recovered
the same as'for
sulfur
concentrations
in footnote b for major equipment costs; steam consumption was calculated
using the following equation:

a
SteamRequired= 79,600 MgB,100Mg
0.7
Where: a = kg of sulfur recovered for citrate
system whose steam
requirement is being determined. Small nodel unit =

2,141 Mg; large model unit = 6,776 Mg.
References
23,
28.
1Theonly majorwaste productis
crystalline
soilium sulfate,
Glauber's
salt. The basis for the waste disposal requirements is the assumption
that the ratio of Glauber's salts produced to sulfur recovered is
constant, 67.4 kg Glauberls salt per Mgsulfur recovered. Therefore,

requirements are: small modelunit (21141Mgper year recovered
large model unit (6,776M9 per
per
year waste. Waste disposal
year recovered.sulfur) = 456.7 Mg
cost is 916.50 per Mg. References 23, 28.
sulfur)
= 144.3 Mg per year waste;
mgasedon 4 percent of total capital cost.
Reference4.
"Basedon an expected service life of 15 years and an interest rate of

10percent. Capitalrecovery cost is calculated by 0.1315 x (total
capital
cost).
Reference 4.
8-31
Table 8-16.
CITRATE
FCDSYSTEM
COSTS
BASED
ON1.5 WEIGHT
PERCENT
SULFUR
FEEDANDREGULATORY
ALTERNATIVE
III (concluded)
OProductrecoverycredit for elementalmolten sulfur is based on 5~38.~ per

Hg. Amount
of recoveredproduct is 2,151 149per year for the small
model
plant22,and28.6,776Mgper year for the large Rodelplant.
References
PCosts of an electrostatic
typical citrate
scrubber;
precipitator (ESP) are cred.ited because a

system recovering elemental sulfur utilizes a venturi
however,
vendors caution that it remains unprovenwhether the

citrate
FGDwill provide complete particulate control. ESPcosts are
given in Table 8-19. Reference 29.
8-32
Table 8-17.
SPRAYDRYINGCOSTSBASEDON 1.5 WEIGHTPERCENT
SULFUR
FEEDANDREGULATORY
ALTERNATIVE
Ila
(Costs Reported in Thousands of Dollars)
2,500
Model
TOTAL CAPITAL COSTSb
m'/sd
Unit
1,780
3,000 m'/sd
Model Unit
4,720
Operating Labor
29.8
29.8
Maintenance Laborc'
29.8
29.8
Replacement
#ateriald
35.6
94.4
Utilities
Pebble Liaee
110
344
112
335
Electricity
Water9
1.8
Waste disposal
Indirect Operating Costs;

Tax, Insurance, and Administratin'
CapitalRecovery
Costj
ESP CREDIT
217
71.2
189
234
TOTAL
ANNUAL
COSTS
693
-200
NETANNUAL
COST
6.1
68.4
621
1,866
-330
493
1,536
E1ISSION
REDUCTION
(MgS02Removed/year)
1,470
4,710
CDST
EFFECTIVENESS
(sFlg of S02Removed)
335
326
Footnotes
are
on the
next
page.
8-33
Table8-17. SPRAY
DRYING
COSTS
BASED
ON1.5 UEIGHT
PERCENT
._j
SULFUR
FEEDANDREGULATORY
ALTERNATIVE
III (Concluded)
"Nelson cost indexes were used to adjust
dollars.
costs
to fourth
quarter
1980
Capital casts include contingencycosts of 20 percent, al.thoughvendor

estimates mayinclude only 5-10 percent contingency. Dependingupon
specifications (i,e,, standards for motors, punps, vessel thickness,
etc.)
actual
total capitalcostsmayvaryby15-20percent.
References
30, 31.
CBased
on1 man-year
per unit (2,080hoursperman-year)
andlabor
charge
of 814.35,
Reference
30.
dgased
on2 percentof total capitalcost.
e
~$
ii
Reference 30.
Basedon pebbleline requirementsof: 2,500mJ/sdunit = 5.99 Mg/day

(6.6 tonlday), 3,000m'/sd unit 18.78Mglyear(P0.7 tonlday). The
cost of pebble lime is 942.18 Mg(846,50/ton),
References 30, 32,
Basedon electricity requirementsof: 2,500ml/sd unit = 200kl~i;8,000m3/sd

unit = 600 kW. Annual electricity
requirements of:
; .i
2,500m7/sd unit =
1,713,600kWh;8,000 mi/ad unit = 5,140,800kWh. Electricity cost =

bO,0652/kWh.References4, 30,
9s,sedonwaterrequirements
of: 2,500
m3/sd
unit 29,190
m3/yr;
8,000og/sd
unit = 97,290, water cost = 80.0625/ms
haasedonwastedisposalcost
are:
2,500 m'/sd unit
References
4, 33.
of
4,148
References 4, 30,
916.50/M9.
Waste disposa~
Calculated as 4 percent of the total capital cost,
Reference 4,
Cost is based on a 15-year life and 10 percent interest.

recovery
cost
is
calculated
requirements
Hg/yr; 8,000 m3/sdunit = 13,126 Mg/yr,
Capital
as 0.1315x total capital cost. Reference4.
fhe annual costs for an electrostatic precipitator are credited to the

spray drying costs because particulate emissions are controlled in
addition to S02 emissions. Reference33,
8-34
~;j
8.4
OTHERCOST CONSIDERATIONS
Thecost
reference
impacts have thus far been discussed
to sulfur
oxides.
However,
other
exclusively
factors
affect
the
with
costs
to the industry in applying control technology to meet the levels of

control specified under the regu.latory alternatives.
Compli ance with
several exi.sting environmental, safety, and health statutes impose
other costs on the refining
listed
in Table
industry.
A summary of these
statutes
are
8-18.
Although specific costs to the industry to comply with most of

the provirions, requirements, and regulations of the existing statutes
are unavailable,
few refineries
are expected to close solely
the cost of compliance with the standards.
However, the total
due to
costs
may accelerate closings promptedfrom changing crude supplies and
productdemand.37
The costs incurred by the petroleum refining industry to comply
with all health, safety, and environmental regulations
are not expected
to preventcompliance
with the regulatoryalternative for sulfur
oxides emissions from FCCunit regenerators.
Nevertheless, they will
likely impact the choice of control techniques refiners will employ to
meet the regulatory alternatives.
This is evidenced in that flue gas
desulfurization,
alternatives,
which forms the basis
of the costs
simultaneously offers the refiner
for the regulatory
the benefit of particulate
emissionreduction
required by the existing FCC unit particulate
emission NSPS. However, should a refiner choose to utilize
hydrodesulfurization
or sulfur oxides reduction catalysts
for sulfur oxides
control, additional costs would be incurred to control particulate

emissions. Table 8-19 provides capital and annualized electrostatic
i, 37-44
precipitator costs incurred to control particuiate emissions.
8-35
TableB-1S. STATVTES
TNAT
MnY
BEAPPLICABLE
TOTHE
PEIROLEUM
REFINING
INDUSTRY
Applicable provision, regulation or
requlrtncnt of statute
Statute
Applicable provision. reJulatlon

requlrenlent of statute
Statute
Clean Air Act and ARelldments u State Illlplallentallunplans
(Iccupatlonal Salcty L Ilealth

Act
o HatLullal anlss(oll standards for

hazardous
air
a Ualtlng-rorLlng surface standards

a Means of egress standards
pllutants
Benzene fugitive emissions
a Occupatlonai health and ellvironnlental
o New source
~er~onMnce
standards
FCC unit carbon monoxide

Petroleum storage vessels
a General envlroruaelntalcontrol
standards
a Fledlcal
a fire
penalts
Water pollution Act)
and first
protection
aid starldards
standards
a CcYnpressedgas and coulpressed

air
OD
standal-ds
standards
YOC
permits
a Non-attPlrment construction
standards
raaterlal
a personal protective egulpnent
C16ussulfur recovery plants

o PSD construction
control
o Ibzardous
FCL:
unit part(culte matter
CleanWaterAct (Federal
or
a Dischargepennlts
CoastalZoneManagement
Act
equipment
a Welding.brazing. andcutting
standards
WI
O\
a Effluent I(r~ltatlons guidelines

a Newsource performancestandards
o States amyveto federal permits

for plants to be sited in
coastal
o Control of oil spills and discharges
Rational EnvironmentalPolicy
a Pretreatlnent requlrelnents
Safe printing Wirer Act
Act
statements
o Requires undergroundInlectlon
control
a Monitoring
Ibrlne
Sanctuary
Toxic
Substances
Act
and reporting
a Penlllttln(Jof Industrial pro~ects
ACt
that Ilnplnge on wetlands or

plblle waters
Control
ResourceConservationand
Recovery Act
pennits
a Ocean dumping pennlts

a RecordLeeplng
and reporting
o premanufacture
notification
a LahellncJ. recordkeeplng
a Reporting retlulrelllents
o Toxicity
a fnvirorvllental
zone
a Requires erlvironlnentalImpact
testing
impact statfarnts
o Permits for treatment. storage. and

disposal of hazardous wastes
a Establlrlles
Ila2ardous
o Establlslles
reporting.
Il~onltorlng
hazardous
system to tract
wastes
recor.dteeping.
labeling p~~d
system
wastes
for
o Superfund
;..-~...
-li
ii;... I
_1
E;::,,3
i.,j
;;~:;
Table 8-19. EFECTROSTATIC

PRECIPITAaOR
COSTS
(Fourth quarter
Cost Te~ms
CAPITAL
1980 Dollars)
2,500 m /sd Unit
8,000 m /sd Unit
COSTS
Equipment Costs
261,000
435,000
Auxiliaries'
34,800
65,200
Instrumentsand Controisd
29,600
50,000
Taxes and Freight"
23,600
Control
Device
Installation Costsf
492,000
Total Capital Costs
40,000
832,000
841,000
1,422,000
16,100
16,100
ANNUAL COSTS
Direct
Costs
Operating Labor9
General
~aintenanceh
16,80(1
Replacement
Partsi
660
16.800
1,110
UtilitiesJ
9,250
29,700
WasteDisposalk
6,430
20,600
Total
49,200
84,300
Overheadl
19,600
19,600
Property
fax, In;i~urance,and
Administration
33,600
56,900
Capital RecoveryCost"
os, 800
Indirect
Total
Direct
Costs
Costs
Indirect
Costs
Total Annualited Costs

Footnotes
are
on the
next
page.
8-37
167,100
152,000
244,000
201,000
328,000
Table 8-19.
ELECTROSTATIC
PRECIPITATOR
COSTS(Concludet~).
aCost indexes were used to bring costs to fourth

References
1, 39,
40.
Removalefficiency
quarter
1980 dollars.
95 percent; drift velocity = 0.076 m/sec; plate
area for the 2,500 m~/sd unit = 1,000 mZ, for the 8,000 m3/sd unit =
3,200 m2 air flow for the 2,500 m3/sd unit t 27 m3/rec, for the
8,000 m3/sd unit
= 87 m3/sec.
Reference
38.
CAuxiliaries
includebypass
ducting:~9.7mlength,127cmdiameter,
6.4 mncarbon steel, insulated; 2 elbows 6.4 rrrm

carbon steel, insu1ated;
2 expansionjoints;
2 round dampers with automatic controls; and a 23
un x 4.5 m screw conveyor.
References 4, 41, 42.
Instrument and controls calculated as 10 percent of control device

and auxiliary
equipment
cost.
Reference
4.
eTaxesand freight calculated as 8 percent of control device and

auxiliary
equipment
cost.
Reference
::
4.
fIncludesindirect anddirect installation costs and
20 percent
calculated as 142 percent of purchased equipmentcost.
contingency
Reference4.
9Includesoperatorandsupervisorcosts. Operatinglabor costs are

based on 1.25 operator man-hoursper shift, 3 shifts per day, 365 days
per year and 810.25 per man-hour. Supervisor labor costs are included
by adding 15 percent to the operator costs.
Reference 4.
Includes labor and material.costs.

Maintenance labor costs are based
on 0.74 man-hours-per shift, 3 shifts per day, 365 days per year, and
910.25 per man-hour. Material costs are equal to 10P percent of
maintenance
labor
costs.
Reference
4.
fgasedon0.078percentof total capitalcosts. Reference

43.
JBased
on0.135watts~m2
platearea, 8,760hoursperyear,$0.0652
per
kWh,and 1,000 mZplate area for the small ESPand 3,200 m' plate
area for the large
ESP.
Reference
4.
ktostto remove
wasteis basedonsl6.50/metric
ton.
updated
to September
Overhead calculated
(labor
only).
1980,
see Reference
3.
as 80 percent operating
Reference
4.
Cost
from Reference
labor and maintenance
mCalculated
as 4 percentof total installed capital cost. Reference
4.
"Capitalrecovery
cost basedon20yearsoperatinglife, and10percent
.annual interest
rate.
Capital recovery factor

8-38
= 0.1175,
Reference 4.
4,
8.5
1.
2.
REFERENCES
Nelson Cost Indexes.
1981.
Docket
Reference
Letter
and Attachments
79(14):147.
April 6,
Number II-I-90.X
from Cunic, J.D.,
Exxon Research
and Engineering
Company,toDurham, J.F., U.S.Environmental Protection Agency.

Regarding the ~ost of Exxon's high energy venturi scrubber.
January 23, 1981. Docket Reference NumberII-D-37."
3.
U.S. Department of Labor. Bureau of Labor Statistics.

Current
Number
4.
Business.
60:5-13.
Capital and Operating Costs of Selected Air Pollution Control

Systems. U.S. Environmental Protection Agency, Research Triangle
Docket
Reference
Telecon.
Bernstein,
Reference
No. 450/5-80-002.
December 1978.
Cunic, J., Exxon Research and Engineering Company, with

Incorporated.
Number
Long term price for caustic
soda.
Docket
IIIEI6.~
Telecon.
Vaccio, K.,. Allied Chemical Corporation - Specialty
Chemicals Division, with Rhoads, T.W., Pacific Environmental
Services,
Incorporated.
December 9, 1981. Price for soda ash.
Docket
7.
EPAPublication
Number II-A-S.f
December 15, 1981.

6.
Survey of
Docket Reference
II-I182.*
Park, North Carolina.
5.
October 1980.
Telecon.
Reference
Menrel,
T.W., Pacific
1981.
Number IIIE-6.f
Price
R., FMC-Industrial
Chemical Group, with Rhoads,
Environhenta~ Services,
for soda ash.
Incorporated.
Docket Reference
December 9,
Number II-E-6.+
8. Telecon. Rogers,J., Beu Laboratorieswith aernrtein, G., Pacific

Environmental Services,
Incorporated.
and price of polyelectrolyte.

9.
Dickerman, J.
Boilers.
Flue Gas Desulfurization
Volume Il,
EPA-600/7-79-167b,
Durham, North Carolina.

Flue Gas Desulfutization.
July 1979. p. 5.
February 4, 1981.
Identification
Docket Reference NumberII~E16.*

Applications
to Industrial
Radian Corporation.
Presented at the U.S. EPASymposiumon

Las Vegas, Nevada. March5-8, 1979.
Docket Reference NumberII-A-9.f
1O. TechnologyAssessment Report for Industrial Boiler Applications:

Flue Gas Desulfurization.
U.S. Environmental
Protection
Agency.
Research friangle Park, North Carolina.

Publication No.
EPA-600/7179-178i. November 1979. pp. 1-21 to 1-23. Docket
Reference
Number
II-A-10."
11. Memorandum. Rhoads, T.W., Pacific
Environmental
Services,
Inc.,
to
DocketA-79-09.Environmental
andCostImpactAnalysisfOrthe
Sodium-based, Du41 Alkali, Wellman~Lord, Citrate, and Spray Drying
FGDsystems. April 27, 1982. Docket Reference NumberII-B-23.~C
8-39
12. letter
from Czuchra,
Pacific
P.A.,
Environmental
FMCCorporation,- to Bernstein,
request for dual alkali scrubber cost information.

Number
13.
II-D158.f
Docket Reference
Tefecon.
-,
Czuchra, P.A., FMCCorporation, with Osbourn, S., Pacific

Environmental Services, Incorporated. December14, 1981. Dual
alkali
14.
G.,
Services, Inc. July 15, 1981. Response to
scrubber costs.
Telecon.
Docket Reference Number II~E-5.'
Czuchra, P.A.,FMCCorporation, with Rhoads, T.~.,
Pacific cnvironnental Services, ~ncorporated. February 23, 1982.

Dual alkali scrubber costs.
Docket Reference NumberTI-E~5.~
15. Telecon. Czuchra, P.A., FMCCorporation, with Osbourn, S., Pacific

Environmental Services, Incorporated. January 13, 1982. Dual
alkali
scrubber
costs.
Docket Reference NumberII-E-5."
;3
-3
16.Telecon. Czuchra, P.A., FMC

Corpor~tion, with Rhoads,T., Pacific
Environmental Services, Inc.
Augustl2, 1981. Clarification
of
dual alkali scrubber costs and particulate control. DocketReference

Number
II-E-S,f
17. FCCEmissionControlby the Wellman-lord

and DavySaaberg-Hoelter
FGDProcesses. Submitted to the 0.5. Environmental Protection
Agencyby DavyMcKeeCorporation, March 1981. Docket Reference
Number
II-A-1~."
18. Letter and attachmentsfromPedroso,R.I., navyFlcKee

Corporation
to Rhoads,T.W., Pacific EnvironmentalServices, Incorporated.
February 24, 1982.
19. Telecon.
Docket Reference Number II-0-92.f
Pedroso, R., Davy McKeeCorporation,
with Rhoads, T.W.,
Pacific EnvironmentalServices, Incorporated. March2, 1982.

Docket Reference
20.
Number II-E-5.f
Telecon.
Pedroso, R., DavyMcKeeCorporation, with ~sbourn, 5.,

Pacific EnvironmentalServices Incorporated, March8, 1982.
Docket
Reference
Number II-E-5.+
21. Demonstration
of Wellman-Lord/Allied
ChemicalFGD
Technology:
Demonstration Test, First Year.Results.
0.5. Environmental Protection
Agency. ResearchTriangle Park, N.C. Publication No. EPA-60D/7-74-014b.

September1979. pp. 2-1 to 2-6. DocketReferenceNumberII-A-25.*
22. ChemicalMarketingReporter. January 4, 1982. Price for elemental
molten sulfur.
23. Telecon.
Pacific
Citrate
Maden~urg, D., Morrison-Knudsen, with ~eardon, K.,

Services,
Incorporated.
January 6, 1982.
costs.
Docket Reference Number II-E-~.R
Environmental
24. Telecon. Madenburg,D., Morrison-Knudsen,

with Rhoads,T.W.,
Pacific Environmental Services, Incorporated.
Citrate
costs.
Docket Reference Number II-E-S.t

8-40
March 4, 1982.
25. Telecon.
Madenburg, D., Morrison-Knudsen, with Meardon, K.,
Pacific
Environmental
Citrate
costs.
Servi~es,
Docket
Incorporated.
Reference
January
7, 1982.
Number SI-E-5."
26. Telecon.
Nissen, B., U.S. Bureau of Mines, with r~~leardon, K.
Incorporated.
February 11, 1982.
Citrate
costs.
Docket
Reference
27. Chemical Marketing Reporter.

acid.
Docket
Reference
28. Telecon.
Nissen, 8.,
Pacific Environmental
costs.
Docket
Number II-E-5."
January 4, 1982.
Price for citric
Number 11-1-98."
U.S. Bureau of Mines, with Meardon, K.

Services,
Inc. January 12, 1982. Citrate
Reference
Number II-E-5.'
29. Telecon.
Haminishi, H., MorrisonlKnudsen, with Rhoads, T.W.,
Inc. March 3, 1982. Citrate
scrubber
information.
Docket
Reference
Number II-E-5.t
30. Letter and attachments from Petti,

V.J., WheelabratdrlFrye,
Inc.,
to Rhoads, T.W., Pacific Environmental Services,
Inc.
February
12, 1982. Dry scrubbing capital and operating cost parameters for
catalytic cracking towers. Docket Reference Number II-D-88.f
31. Telecon.
Petti,
Pacific
costs.
V.J.,
Wheelabrator-Frye,
Inc.,
with Rhoads, T.W.,
Environmental
Services,
Inc;. March 3, 1982.
Docket Reference
Number II-E-5.'
32. Telecon.
Spray
drying
Thigpen, E., Ashland Chemical, with Rhoads, T.W., Pacific
Environmental
Services,
Inc.
cost.
Reference
Number II-E~6.*
Docket
February 22, 1982.
Pebble lime
33. Telecon.
Petti, V.J., Wheeabrator-Frye,
Inc., with Rhoads, T.W.,
Inc. March 1, 1982. Spray drying
information.
Docket Reference Number II-E-5."
34. frip Report. Standard Oil of Indiana (Amoco). Chicago, Illinois.

April 1, 1980. Sulfur Reduction Catalyst Costs. Docket Reference
Number
35. Letter
II-B-T.+
and attachments
from Buffalow,
O.T.,
Chevron, U.S.A.,
Incorporated, to Goodwin,D., U.S. Environmental Protecti~n Agency.
June 29, 1981.

and expansions.
Response to Section 114 letter on FCCunit alterations

Docket Reference Number II-D-57.+
36. Davis, J.C. FCCUnits Get Crack Catalysts. ChemicalEngineering.

84(11):79.
June 6, 1977.
Docket Reference Number II1I-92."
37. Economic Impbct of EPA's Regulations on the PetroleumRefining

Industry. Part III - Economic Analysis. EPA-230/3-76-004. April
1976.
Docket
Reference
Number II-A-1.+
8-41
38. Air Pollution Engineering Manual. Second Edition.

Protection
Agency.
Publication
Number
Plo. AP-40. p. 154.
May 1973.
Docket Reference
II-I-Il."
39. Nelson Cost Indexes. Oil and Gas Journal.

1981.
U.S. Environmental
Docket
Reference
79(22):117. June 1,
Number II-I-91.*
40. NelsonCost Indexes. Oil and GasJournal. 76(14):147. April 3,

1978.
Docket
41. Telecon.
Reference
Number 11-1-38."
Bump, B., Research Cottrell-Air
Pollution Division
with
Rhoads, T.H., Pacific Environmental Services, Inc. December17,

1981.
Application
Docket
Reference
of electrostatic
Number
precipitators
to FCC units.
II-E-5.*
42. Peters, MaxS. and Klaus D. rimmerhaus. Plant Design and Economics
for Chemical Engineers.
1968.
p. 110.
Docket
2nd Edition.
Reference
McGraw-Hill Book NewYork.
Number II-I-95.*
43. Katari, V., L. Yveino, E. Schind7er, and T.H. Devitt.
PEDCo,
Cincinatti, Ohio. Evaluation of Particulate. Matter Control Equi pment

for CopperSemlters. U.S. EnvironmentalProtection Agency,RegionIX.
Publication
No. 909/78-001,
Docket Reference
Number II-A-?4.,
44. Memorandum
from Rhoads, T.W., Pacific Environmental Services,
Inc., to Docket A-79-09. April 27, 1982. Electrostatic precipitator
costs for fluid catalytic
Number
cracking model units.
Docket Reference
II-B-24.*'
45. Memorandum
from Hustvedt, K.C., U.S. Environmental Protection
Agency, to Durham,J.F., U.S. Environmental Protection Agency.

May24, 1982. Cost and emission reductions for full scrubbing.
Docket
Reference
Number
II-B-27.,
"References can be located in Docket NumberA-79-09at the U.S. Environmental

Protection Agency Library, Waterside Mall, Washington, D.C.
8-42
9.0
9.1
ECONOMIC IMPACT
INDUSTRYC~RACTERIZATZON
9.1.1
General
profile
9.1.1.1 Refinery and Catalytic CrackingCapacity. OnJanuary i, 1980,

there were 311 petrole~n refineries
operating in the United States and Puerto
Rico with a total crude capacity of over 3 million m3pet steamday.l Of

those ref~ineries 128 operated fluid catalytic
cracking (FCC) units with a
combinedfresh feed capacity of morethan .8 million m3per stream day.l

Like overall refinery capacity, over 50 percent of FCCcapacity is located in
three states:
Texas (28~), Louisiana(15Z), and California (10~). Table 9-1
summarizes FCCcapacity
by state,
company, and location.
Approximately30 to 40 percent of the liquids processed by a petroleun

refinery pass through the FCCunit. Catalytic cracking is used by the
refiner to produce motor fuels and blending stocks from the heavier portions
of crude oil, by catalytically splitting the large hydrocarbonmolecules in
heavygas oil feedstocks into smaller molecules. Catalytic cracking is

also used to increase the yield and quality of gasoline blending stocks and
middle
d i sti-l late
fuel s .
It should be noted that inthe
production and capacity tables that fol~
low, a distinction is often madebetween stream days (i.e., sd) and calendar
days (i.e., ed). The basic difference between the two terms is that "Stteam
days" refers to the maximum
Capacity of a refinery or unit on a given opetdt-
ing day, while "calendar day" prohuctionrepresents the averagedaily production over a one-year period. Since most refineries do not operate 365 days
each year, stream day numbersare always slightly larger than those for
calendar
days.
9.1.1.2
Rei i nery Pr oduct i on .
In terms of total
national
output,
the
percentage yields of various refined petroleim products have remained constant over recent years, although several exceptions ate noted below. The
9-1
Table 9-1. REFINERIES

WfiwFWID tAT~LrTIt
CRnCKlht UNITS (fCtU)
~.
C~pm~
mdgefin(n~
LOc~elon
iresn
!980a
ieec
CaP~c~-t~--Ke~v'r~T~'
~~eSn;:S~S::DdCltY
~ ~.,
ARKANSAS
ToscoCorp.- El Dorado
2,466
123
CALIFORNIA
Atlantic Richfield Co. - Carson
thevronU.S.A.
U.S.A.Inc. El Segundo
Chevron
Inc. - Rlchmond
Lxxonto. U.S.A.- Benecia
Gulf 011 Co. U.Z. - Santa Fe Sbrings
nobil Oil Corp. - Torrance

PowerineOflto. - Santa Fe Springs
Shell Oil Co, - Martinet
Shell Oil to. - Yllmlnqton'
TexacoInc. - Wilmlngton
Tolco Corp. - Avon
OnionOil of California- Yilaingtan
8,909
8.279
l,t72
7.795
1,749
10,023
2,148
9.545
1.94~
9,545
5,564
4,452
7.472
48
'1
48
id
795
7,154
1.113
1.097
16
COLORADO
Asanrra0il Inc. - Ca~nerce

City
DELAWARE
Getty Refining and narlreting Co. - Delaware

tlty
9.857
2.385
HAuAl I.
ChevronU.S.A. Inc. - Hon4luli
3.498
ILLINOIS
Amoca
0il Co. - Wood
River
C'latt0il 6 Refiningterp. - BlueIsland
Clart 011 b Refining tarp.
- Hartfard
MarathonOil to. - Robinson
Mobil0i1 Corp. . Joliet

Shell Oil Corp.. WoodRiver
TexacoInc. - Lawrenceville
TexacoInc. - L~c~port
Union Oil Co. of Calif;
- LemPnt
6.359
318
4.452
159
4,134
6.041
15.163
5.405
0,759
159
64
14.944
9,221
795
INOIAHA
~noco Oil Co.
Whiting
EnergyCooperative
Inc. - EastChicago
Indiana Fann Bureau Cooperative Association,

Inc., - Mountvernon
Roc~ Island Refining terp. -'Indlanaoolis
22,258
7,154
1,590
795
1.113
2,703
KANSAS
CRA,Inc. -tofferyville
=RA.Inc. - Phillipsburg
~.941
1.~51
ncPherJon
Fister Refining Co. - El Corado
PhilliDs ?etrcleum Co. - Kansas City
3,180
1.749
tcttr
RefiningandMarketing
Co. - El Oorado 4.428
National Cooperative
Refinery Association
Total Petroleun Inc. - ArkansasCity
5,326
2.607
238
!27
2,703
636
2,655
KENtLltKr
Ashlanb Oil Inc. - Catlettsburg
AshlandOil Inc. - Louisville
9-2
4.857
1.510
ii
Table 9-1.
(Continued)
CIYnPdnI
and
bfininq
i.calian
rresh-~e~ca Capac~tr
-Reryc~
;f~;;dj
LOUlfrAHA
Cities Service to. - Late Charles

Conoco - YeJtlJe
Exlon Co. U.S.A. - Baion Rouge
GoodHope Industries Inc. - GoodHope
23,847
4,865
25,437
10,334
Gulf Oil Co. U.S. - Belie thaose
14,149
Marathon Oil Co. - Garyville

Murphy0il terp. - neraux
Placid Refining Co. - Port Alien
11,924
5,612
2,623
2,226
159
159
4,293
2.544
207
Shell Oil Co. ~ Horco

Tenneco 011 to. - Chalmette
Texaco Inc. -Convenf
15,898
3,577
6.577
336
318
MlCHIkAH
Marathon 011 to. - Detroit

Total Petroleun Inc. -Alma
nINNESOTA
Ashland
Oil
Inc.
- St. Paul
Part
3,498
Concco - Wrenshall
1,510
KochRefining to. - Rosemont
8, 426
159
8,903
318
6,677
1,908
2.385
3.339
1,908
334
79
1.590
471
199
382
79
21.463
4,769
890
64
MISSISSIPPI
thevron O.S.A. Inc. ~ Pascagoula

MISSOURI
PmocoOil Co. - Sugar ercelt

FH)KIAHA
~noco -Billlngs
ExxonCo. U.S.A. - Billings
Farracrs Onion Central ExchangeInc. - Laurel
Phillips Petroleum Co; - Great Falls
NEBRASKA
CRA,~Ine.- Scottsbluff
NEW 3ERSEr
Exxonto. U.S.A. - Linden
Texaco Inc. - Westv~lle
6,359
HEY MEXICO
NavajoRefining Co. -.Artesia

P~ateau inc. - Blaa~field
Shell Oil to. - tallup
874
l,loS
79
572
NEW YORK
Ashland
Oil
Inc.
- Buffalo
3.498
NORTH [WCOTA
Pmoco Oil Co. - Maodan
4,134
827
OHIO
Ashland Oil Inc. - Canton
4,r34
Gulf Oil to. U.S. - Toledo
3,148
31B
Standard Oil to. of Ohio - Lima
5,994
8,700
1.240
2.623
Sun Co. Inc. - Toledo
7,949
1,192
Gulf 0i1 Co. U.S. - Cleves

Standard Oil Co. of Ohio - Toledo
2,862
318
Tn
OKLAHOMA
thanplinPctrolc~ncc., Enid
Conoco - Ponca City
HudsonRefining Co. Inc. ~ tur~ing
Kerr McteeCorp.- Yynnewood
OklahanaRefining to. - Curil
SunCo.Inc. - Ouncan
SunCo. Inc. - Tulsa

TexacoInc. -Tulsa
YickeisPetroleuntoro. - Ar~bre
-7
3,100
48
7,154
1,192
3,180
1.~13
64
159
3,975
1.669
4.769
2,862
223
3,418
159
PERr(S'ILVANIA
8P01l terp. ~ narcutHoot
Gulf Oil Co. U.S. - Ph~ladc~phla
5un Co. Inc. ~ MarcusHoot
UnitedRefiningCo. ~ Uarran
7,631
254
13,450
1.033
1:,924
2.385
1,908
32
TEXAS (Inland)
American
Petrafina Co. of Texas - Big Spring
Chevron U.S.A. inc.
Dfanond
Shanrock
- El Paso
Corp. - SunrzJ
La Gtoria 011 and Gasto. - T~ler

Phillips Petrole~rm
Co. - Borger
Shell Oil Co. - Odessa
TexacoInc. - Pmarlllo
TexacoInc.` -EIPaso
Winston Refining Co. ~ Forth Yorth
3,657
l,498
5.167
1.540
8.267
1,669
1,272
1.113
556
795
1,653
874
238
TEXAS (eulr)
kmricanPetrofinaCo.of Texas- Port Arthur 5,q0S
Pmoco011 Co. - Tuar City

Atlantic
RSchfield
Cd. - Houston
29.253
12,001
Chaplln PetrolelrmCo. ~ CorpvsChristi

10,970
Charter international Oil Co. -Couston
7.313
Coastal States PetroleunCo. - CorpusChristi 3,021
CrownCentral Petrole~rm
Corp. - Pasedena
7,949
Enxonto. U.f.A.- Baytown

Marathon
Oil to. - TexasCity
Gulf Oil Co. U.S. - Port Arthur
27,027
19,078
5,041
no~~l Oil terp. - Beaunont

15,739
Phillips PetroleM1to. - SweeneJ
5,882
Shell
Oil
to.
Deer
Park
11,129
Soutkwestcm
RefiningCo. Inc.-brpus Christi 1,908
SunCo. Inc.. CorpusChristi
3,975
luaco Inc. - Port Artkur
TexasCity Refining Inc. - TexasCity

Union
Oil
t4.
of
Cdl~fornia- lederland
21.463
318
5,246
795
2.38~
954
159
827
111
1,033
6,359
6.001
636
UTAH
pmoco
Oil Co.- Salt LakeCitr
ChevronU.S.k. Inc. - Salt Lake City

Plateau Inc.- Rooswelt
2,862
636
1,862
159
4,452
795
827
YIRSInIA
Pmoco
0i1 Co.- lortfo*n
UASHINtTON
Shell 011 to. - Anacortes

TexacoInc. - AnacorteS
5.7E3
4.769
2,103
YIStONSI#
nurphyOil terp.. Superior
9-4
1,510
159
::
Table
9-1.
(Continued)
-
~resn
Ccmp.nJ
andRefinins
Locati.n
YYOMI NC
~eepl;apaciry
aeEycie
Imli/Sd)
(.3/Sd)
PmocoOil Co. - Gasper
2.067
238
HuskyOil Co. - C~eyenne

HusLyail Co. - Cody
1.590
604
397
181
1.03~
6,359
636
Sinclair Oil Corp. - Sinclair

Texaco Inc. - rasper
3,339
1,113
PUERTO RftO
Caribbean tulf Refining Corp. - Bayamon

Com~on*ealthOil Refining to., Inc.-Panuelas
TOTAL
aReferenct
i,
PP
24-36.
9-5
509, 709
55.958
percentageyields of refined petroleumproductsfromcrude oil for the years
1469through1978are summarized
in Table9-2, whileTable9-3 notes the
average daily
output
of the major products.
Pmong'
the major productsof U.S. refineries are gasoline and distillate
fuel dil, accountingfor about44 and22 percentof total refinery-output

respectively. Mherproduttsof refineries are residuaIfuet oil, jet fuel,
and petrochemical
:j
feedstocks.
Throughthe 19701sresidual fuel oil and petrochemicalfeedstockshave

accountedfor increasing shares of total refinery output. These increases
can be traced to the use of residual fuel oil in industrial applications and
the growth in petrochemicalmarkets due to the increased production of
synthetic rupber, fibers, plastics, and other materials manufacturedfrom
petrachemicals. ihe Increasedoutput of residual fuel oil and-petrochemicals

have beenbalanced by declining output of gasoline and kerosene.
9.1.1.3 RefineryOwne_rship,
YerticalandHorizontal
Integration.A
largeportionof domestic
refiningcapacityis owned
andoperatedby large,
vertically integrated oil companies,both domesticand international. The
remainder is controlled by independentrefiners such as Charter, Crown
Central Petroleim, Holly, fosca, and UnitedRefining.

Table9-4 lists twentycompanieswith the greatest capacity to process
crudeoil. Baseduponthe capacitiesnoted, anda total domesticcapacityof
3,005,000
m3per streamday,l the 4- and.8-firmconcentration
ratios are
29 and48 percent, respectively. Since there ate currently 158`companiesl
engagedin refining activities, these ratios are indicativeof a highdegree

of ownership concentration of refinery capacity.
Refineryaw~ershipis but one aspect of the vertical integration of the
majorail companies.Suchcompanies
are integrated"backward"
in that they
ownor lease crudeoil productionfacilities, bothdomesticand international,
as well as themeans to transport crude by wayof pipeline and tankers. Cn
the other hand, "forward" integration is less -extensive in that most retail
outlets are operated by franchise agreements as noted below.
Withregard to transportation by pipeline, the majoroil capanies

havebeen the mainsourceof capital for the constructionend operationof
9-6
ps
Table9-2.
PERCENTAGE
VOLUME
YIELDSOf REFINEDPETROLEUM
PRODUCTS
FROMCRUDEOIL IN ME U.S. 1971-1978a
Pra~duct
Motor Gasoline
3et Fuel
Ethane
1971 r972 -Tm3 r974 -1475 r976 -I977 r~78

46.2
7.4
0.2
46.2
7.2
0.2
45.6
6.8
0.2
45.9
6.8
0.1
46.5
7.0
0.1
45.5
6.8
43.4
6.6
0.1
44.1
6.-6
0.1
2.9
2.8
2.8
2.6
2.4
2.4
2.3
2.3
2.1
22.0
S.6
2.7
1.8
22.2
6.8
2.9
1.7
22.5
7.7
2.9
1.3
21.8
8.7
3.0
1.2
21.3
9.9
2.7
1.1
21.8
10.3
3.3
1.2
22.4
12.0
3.6
l.Z
22.4
12. O
3.6
Special Naphthas
0.7
0.7
0.7
0.8
0.6
0.7
0.5
0.6
Lubricants
1.6
1.5
1.5
1.6
1.2
1.3
1.2
1.2
Wax
0.2
0.1
0.2
0.2
0.1
0.1
0.1
Coke
2.6
2.8
2.9
2.8
2.8
2.6
2.5
2.5
Asphalt
3.8
3.6
3.5
3.7
3-2
2.8
2.9
2.9
Road Oil
Still Gas
Miscellaneous
0.2
3.8
0.4
0.2
~.9
0.4
0.2
3.9
0.4
0.2
3.9
O.S
0.1
3.9
0.7
0.0
3.7
1.0
0.1
3.6 1.0
0.1
3.6
1.0
Liquefied Gases
Kerosene
Distillate Fuel Oil
Res'idual Fuel Oil
Petroc~em. Feedstocks
Processing Gain
Total
aReference
0.1
- 3.4 - 3.3 - 3.6 - 3.9 - 3.7 - 3.5 - 3.6 - 3,6

100.0
100.0
100.0
100.0
100.0 100.0 100.0 100.0
2.
9-7
Table 9-3. PRODUCTION

3F PETROLEW
PROOUCTS
ATUNITED
STATES
REFINERIES
1969-1978"
(1.000mi/ed)
Motor
Year
Gasoline
1969
1970
1971
Oisti Ilate
Residu-l
Fuel Oil
Fuel Oil
872
909
951
370
391
397
116
112
120
------Jet F ef
NGL and
140
131
133
45
42
38
54
55
57
135
35
57
1972 1,000
419
127
1973
1974
1975
449
424
154
170
137
133
35
25
60
54
422
197
138
24
49
1,039
1,011
1,037
~976
1,088
465
219
!46
24
1977
1,118
521
279
155
- 27
1978
1,140
501
266
155
24
aReference
17,
and
2.
174.
Section
V~I.
-~
54 ~
56
Tables 5, 6, 64, 7, 7a, 14, 15, 16, 16a,
bNGL
= NaturalGasLiquids;LRG
=LiquefjedRefineryGases.
:j
9-8
Table 9-4.
REFINERY
FAC'rLITIES
OF MA30R
COMPANIES"
Numbe
Company
Refineries
Exxon
(1,000
m3/cd)
251
Cfievron
:
Pmoco
Shell
Texace
Gulf
~bil
12
10
8
12
7
7
ARCO
133
4
4
S
93
78
77
So h i ol BP
3.
72
Ashland
73
Phillips
68
Conoco
Coastal States
7
3
58
47
46
Champl
in
38
Tosco
Marathon
UnionOil
Sun
Cities Service
Getty
aReference
3,
P. 075.
9-9
233
197
183
168
145
142
35
'35
r,
these facilities, due largely to the huge investmentsrequired. Onthe other
hand,tankerownership
is dividedamong
the majoroil companies
andindependent operators~hocharter tankers:e oil companies
endtraders.0 Thepresence of independenttanker operators is a result of~relatively small financial requirements, comparedto pipeline ownership.
Whilemanyof the low-volume

refinery productsare marketeddirectly
by the refiners themselves,the sale of gasoline on the retail level is
handledprimarilyby franchiseddealersandindependent
operators. Themajor
refinersdo, however,
havea highdegreeof controloverthe distributionof
their
products with regard to market area.
This is so since the major refin-
ers select sites for the construction of service stations before the facili-
ties are leasedto independent

operatorsunderfranchiseagreements.The
major refiners do maintainthe direct operation of someservice stations for
ra
purpose
of measuring
the strengthof the retail market.However,
nomore
i.
than 5 percent of all facilities in operation are managedin this fashion.5
Many
of the finns that operaterefineries, notablythe larger oil
companies,are diversified as well as vertically integrated. Anatural
area of diversification for refiners is the manufactureof petrochemicals
andresins. Pmonq
the firms that haveinterests in'hese areas are: Clark
Oil andRefining,GettyOil, OccidentalPetrole~Pn,
andPhillips Petroieun.
Ashland
Oil's construction
divisionoperatesthe largest highway
paving
campanyas well as tko shipyards; ExxonEnterprises develops and manufae-
tures varioushigh-technology
products. TneKerr-McGee
CorpPrdtion
is the
largest supplierof commercial
gradeuraniLrm
far electricity generationand
-j
also manufactures
agriculturalandindustrialchemicals.MobilOil Corp.is
owed by Mabilterp, whichownsboth Montgomery
Wardand Co. and Thetontainer
Corporat
i on of Pmer
ica. Thetharter Co., the largest of the independent
refiners, is also engagedin broadcasting,insurance,publishing,andcommercial printing,
9.1.1.4 RefineryEmployment
andWages.Totalemplo4~nent
at domestic
petroleumrefineries has grownsteadily since the mid-1960's,'withminor
disruptionsdueto the recessionsof 1970and1974. AsT?bleg-j demonstrates, there were163thousand~orkers employedat refineries in 1978.6
Wi
th 289refineriesoperating
that year,7average
emplo~ment
at eachrefinery
is approximately
564 persons.
9-10
,i
Table 9-5.
EMPLOYMENT
IN PETROLE~ANDNATURAL
GASEXTRACTION
AND PETROLEUMREFINING 1969-1978a
(1,000
Workers)
Year
Petroleumand-~atura~GasExtraction
PetroleumRefi nIng
1969
279.9
144.7
1970
270.1
153.7
1972
264.2
1972
268.2
152.3
1973
277.7
149.9
1974
304.5
155.4
1975
335.7
154.2
1976
360.3
157.1
404.5
160.3
417.1
163.0
1977
1978
aReference
2.
'
Section
V.
fable
152.7
2.
9-11
The average hourly earnings of petroleumrefinery workers have consis-
tently exceededaveragewagerates for boththe miningandmanufacturing
industries.8 Petrolevnrefineryhourlyearningshavealso exceeded

those
for other
sectors
of the oil
industry
as noted in Table 9-6.
9.1.1.5 tasoline Pool. Thelargest single productproducedat petrcleun refineries is motorgasoline. This product is essentially a blend of
the productsof several different refinery units including the catalytic
cracking
unit. Table9-7provides
a s~mmary
of the estimated
contributions
of individualrefinerystreamsto the gasolinepool. Asnotedin that Table
FCCgasoline is estimated to makethe largest sPngle contribution to total
gasoline
output.
9.1.2 Market
Factors
9.1.2.1'Demand
Determinants.1980DOiprojectiansconcludethat, On
the nationallevel, existingrefinerycapacityis capableof satisfyingthe

future domesticdemandfor refined petrclevnproducts.r0 Expansionsand
modifications
will, however,
be undertaken
in orderto allowthe processing
of greater proportionsof high-sulfur crudes, and to permit the productionof
increasing levels of high-octane unleaded gasoline. It is also possible that
shifts in demandon the regional level maycall for capacity expansionsat

existing
refineries.l0
Evidenceof sufficient refining capacity is provided by Table 9-8. In
that table estimates of percent refinery capacity utilization, along with

daity deTiandleveis for the four majorrefinery productr, are presentedunder
several~assLmptionsregarding the kotld price of oil. In each case the
projected utilization late is well below~the1978 level of 86 percent.
Reduceddriving and greater vehicle'efficiency have combinedto reduce
the future demand

for motorgasoline. AsTable9-8 indicates, it is unlikely
that gasoline demandwill, within the forecast period, reach those levels
observed
during 1978. Thisconclusion
holdstrue regardlessof specific
assumptions concerning the future of world oil prices.
Reduced
total gasolinedemand
doesnot, however,implythat existing
gasoline productionfacilities are currently capableof meetingfuture
gasoline requirenents.
In particular the continued phase-out of leaded
gasolineanddemand
for higheroctaneratings will require someadditions
to refinery capacity. Consequently,refiners can be expected to increase
9-12
.:::~
Table
9-6.
AVERAGEHOURLYE~ARNIIIGSOFSELECTED:NDUSfRlESa
(Average Hourly Wage)
Petiole~n
Petroleum and
Year
Refining
Natural GasExtraction
1969
4.23
3.43
3.19
3.61
1970
4.49
3.57
3.36
3.85
1971
1972
1973
1974
4;82
5.25
5.54
5.96
3.75
4.00
. 4.29
4.82
3.57
3.81
4.08
4.41
4.06
4.41
4.73
5.21
1975
6.90
5.34
4.81
5.90
1976
7.75
5.76
5.19
6.42
6.88
fetal
Manufacturing
1977
'8.44
6.23
5.63
1978
- 9.32
7.01
6.17
aReference
2.
Section
V.
Table
i.
9-13
-Total
Mining
7.67
7.67
Table 9-7.
ESTIMATED1981 UNITEDSTATESGASOLINEPOOLCOMPOSITIONa
Pmount
Stream
X oi
(1.000,000m3/cd)
Total
Reformate
355
29.9
FCC Gasoline
408
34.4
162
13.7
17
1.4
75
6.3
15
30
22
1.3
2.5
1.9
15
1.3
86
7.3
Alkyl at e
Raffinate
Butanes
Caker Gasoline
Natural Gasoline
Light Hydrocrackate
Isometate
Straight
Run Naphtha
Total
aReference
1,186
9.
9-14
.100.O
Table
9-8.
World
Oil Price
DEMANDPROJECTIONS FOR MA~OR PEIROLEUM PRODUCfSa
Reiinery
Capacity
Year (1979 g/m3) (1 000 m3/cd)

1978
Capacity
Product Demand
(1,000mj/cd)
Utilization -Motor Oistillate Residual~et

(Percent)
Gasoline
fuel Oi7
Fuel Oi~ Fuel
97
2,719
86
1,176
572
477
175
Low
170
3,068
70
1,017
493
223
238
Mid
201
3,068
65
986
461
207
175
High
245
3,068~
64
922
445
191
223
Low
170
3,148
74
541
238
270
Mid
233
3,148
66
938
493
191
191.
High
277
3,148
63
859
461
175
238
Low
170
3,211
76
588
207
318
Mid
258
3,211
45
986
493
111
207
High
352
'3,211
60 .
859
429
1985
1990
1,017
1995
aReference
10,
p.
115.
9-15
1,097
95
254
catalytic
cracking,
catalytic
reforming,
and alky~ation
capacities
in order
to maintain octane requirements.ll

Distillate
boilers,
fuel oirs are used in home heating, utility
and as diesel
fuel.
In all applications
and industrial
demand is expected to fall
with the erception of diesel fuel.l0 Oecliningdemandis essentially

due to the availability
utility
and industrial
As indicated
all
of lower cost substitutes,
cases
in Table
in particular
coal fired
boilers and natural gas for home heating purposes.

9-8,
the demand for distiltate
with the exception
of low crude oil
fuel
prices
oil
declines
:1
in
in 1995.
Residual fuel oil is used as a bunker fuel in large ships, large utility
and industrS~al boilers,
and in the heatingof
some buildings.
Residual fuel
oil competes with coal for use as a fuel in the applications noted above.
fable 9-8 shows that the demandfor residual fuel oil falls steadily under
all price scenarios.
This is so because the ability to crack residual fuel
into more va7uable-lighter
products ensures that its price will not fall to
that~point
where it
can serve
The elasticity
as a cost-effective
teplacement
far coal.l2
of demand is a measure of the percentage change in demand
yelative to a percentageci~ange~in
price. ~With.
renar_dto the elastj;;ty of..
demand for petrole~n
products,
~ostecbnametTic
short-run demand is n.ot sensitive
studies
to pric'e'changes.
conclude
that
Estimates made by the.
Department of Energy and sunmarized in Table 9-9, support this conclusion.l3

Since all values in the table ate less than one, the general conclusion is
that short-term demand is not particularly

9.1.2.2.
Supply Determinants.
unlikely thatthe
tional
that
developments,
dependence
upon
~As noted in the previous section,
domestic refining
disruptions
me major thrust
to price changes.
it is
supply oi refined petroTeum~praducts will be restricted
reason of inadequate
sible
sensitive
capacity.
in the flow of imported

in particular,
of national
imported
energy
political
policy
for
It is, however, quite posoil
could
instability
is thetefore
result
from interna-
in the Middle East.

the reduction
of
oil.
Attempts to reduce dependenceupon imported oil have focused upon three

major
areas:
reduced
consumption
through
conservation,
and increased
domestic
production through both the decontrol of domestic oil prices and the development of a synthetic fuels industry.
While price decontrcl and synthetic fuels
deveTopnent may have a significant
impact in terms of import reductions, these
9-16
Tab le 9-9.
PRICE ELASTIC.iTIES
FOR MAJOR REFINERY PRODUCfS BY SECTOR"
(1985)
Sector '
Product
Elasticity
Res i dent i al
Distillate
Oil
-0.37
CorrPnerical
Distillate
Oil
-0.41
Distiltate
Oil
--0.53
Industrial
Residual
Liquid
Transportation
Oil
Gas
-0.45
Gasoline
Disti7late
-0.29Oil
~ResidualOil
Jet
aReference
10,
pp.
332-3,
short-term
-0.36
Fuel
elasticities.
-0.66
-0.10
-0.42
measures
other
are essentially
hand,
has
offered
mid- to long-term
more immediate
solutions.
Conservation,
on the
results.
The effects of recent conservation efforts, including decreased gasoline

consrmption,
observed
and conversion of facilities
in Table 9-10.
In particular,
after reaching a historic
to coal and natural

imports
of crude oil
gas, can be
I~
have leveled-off
high of 384 million m3 in 1977, while recent
reportsl4 indicate that the reductionof importshas continuedinto 1980.

The results
of conservation
efforts
can also
be observed
in the fact
that
year-endstocks of crudeare currently at the highest levels recordedin

the recent
past.
Thephasingout of pricecontrolsoncrudedomestic
oil andrefinedpetroleu~ products was completed on January 28, 1981 with the issuance of E.O.
12287, which revoked the price and allocation controls granted to the Depart~
ment of Energy under the EmergencyPetroleum Allocation Act of 1973. The
progressive decontrol of domestic crude oil prices has increased exploration,
:j
and~is expected to increase stocks of already proven reserves.

Recent
increases in both drilling activities
and proven reserves are noted in Table
9-11.
The developnent of a domestic synthetic fuels industry will have little
impact upon energy supplies over the next~five years since significant output.
is not anticipated
until
the late
1980s.15
9.1.2.3 Prices. Table 9-12 indicates.recent price levels for gasoline,

distillate fuel oil, and residual fuel oi.l. For each product, apattern of
stable prices, followed by rapid price increases in 1974 and 1979, can be
observed. The increases in both years are attributed to the pass-through of

increases
in the price of crude oil supplied by the OPECnations.
Future refined product prices will continue to rise in response to

increases in the long-term price of both imported and domestic crude.
9-13 presents recent DOEprojections of world oil, gasoline, distillate
oil,
residual
fuel
oil,
9..1.2.4
Imports.
and jet
Table
fuel
fuel prices.
Imports of both crude oil and refined
products are
expected to decline through the mid-1980's. In the case of crude oil, the
fall in import levels can be attributed to sharp increases in the price of
OPECoil, and the increased production of domestic crude prompted by its
price decontrol.
9-18
Table 9~10.
CRUDEOIL STATISTICSd
(1,000,000 m3/year)
Domestic
Yeat
Production
1970
Domestic
eS
Imports
VearSEnd-Stocks as Percent
Consumption
Exp_orts
Stocks
of Consumption
559 .
77
633
0.8
44
6.94
1971
549
98
649
0.1
41
6.36
1972
549
129
680
' 0.1
39
5.76
1973
534
188
723
0.1
39
5.33
1974
486
202
688
0.2
42
6.13
1975
465
238
703
. 0.3
43
6.14
1976
452
308
760
0.5
45
5.97
1977
457
384
841
2.9
55
6.57
1978
485
369
854
9.2
60
7.01
1979
474
13.6
68
376
850
aReference'3, p. 073.
9-19
8.05
Table
9-11.
DOt1ESTICOIL EXPLORAfION AND OISCOVERIES

New Reserves
Year
- Explo~atory
WellsDrilled
1970
1971
1972
1973
7,693
7,000
8,357
'
Added
(i,ooo,ooom3)
1,566b
15
20
7,466
18
1974
8,619
36
1975
9,163
28
1976
9,234
11
1977
9,961
25
1978
10,667
32
1979
10,484
38
aReference
3, p. 072.
bIncludes Prudhoe Bay, Alaska.
9-20
-1.
Table 9-12.
PRICES: GASOLINE,DISTELLA~E
FUELOIL, ANDRESIDUAL
FUELOIL
GasoTine
Year
aist~i\late
(h/liter)
Fu~T Oil
(I/liter)
Who~esalea Retaila
Wholesale" Retail'
Residual
Fuel
(h/liter)
Wholesales
1968
1969
4.4
4.5
8.9
9.2
2.7
2.7
4.6
4.1
1.5
1.5
1970
4.7 `
9.4
2.9
4.9
1.9
1971
1972
1973
1974
1975
4.8
4.7
5.2
8.1
9.5
9.6 '
9.5
10.3
13.8
15.1
3.1
3.1
3.6
5.6
8.2
5.2
5.2
6.0
9.5
10.3
2.6
3.0
3.4
6.8
6.8
1976
'10.3
15.7
8.7
11.0
6.6
1977
1978
11.2
11.8
16.7
17.4
9.8
9.9
12.5
13.4
7.9
7.4
1979
16.4
23.2
14.3
19.2
aExcludes
tax:
Reference
bService station prite,

Section
cReference
VI,
Table
3,
4.
2, Section
10.2
P. 079?
regular gasoline,i.ncludes
VI, Table 5.
9-21
tax:
011
Reference 2,
Table
9-13.
PRICE PROJECTIONSa
-(1979 S/m3)
Wor
Id Oi1
Year
1978
Motor
Price
97
Gasoline
Distillate
Residual
Fuel Oil
Fuel Oil
153
107
Jet
Fuel
80
113
175
195
204
221
1985
Low
Mid.
970
201
240
277
185
211
High
245
320
252
243
263
Low '
170
241
187
176
197
Mid
233
309
242
232
252
High
277
352
295
279
314
Low ~
Mid
170
258
240~
338
!90
267
178
255
199
279
High
3~2
432
365
~52
387
1990
1995
"Aeference 10, p. 115.
-9
i
_I
'9-22
I.~i
Low sulfut
(sweet) crudes are generally
more desirable
fur (sour) crudes because the~refining of the latter

investmentin
desulfurization
capacity
than high sul-
requites a larger
such as hydrorefining
and hydrol
treating uni:s.~ White current crude imports ate more than half sweet,
only 15 percent of OPEt'stotal oil reserve is sweetcrude.lb tonsequently, it is unlikely that the sweet-sour crude import balance will
remain constant. The price differential between the t~ro will eventually
make sourcrude
processing
a necessary
investment.
Withregardto refined petrolecm

products,the importation
of most
of these pioducts
is expected'to
Table 9-14 shows that
for
decline
the major
as it has since the mid-1970's.
refined
products,
imports
peaked dur-
ing 1973-1974. In general, imports of refined products have beenrela-

tively small comparedwith production at domestic refineries (see Table
9-4). For this reason, the potential far foreign trade disruption is minimi'zed.
9.1.2.5
Exports. Exports of crude oil and refined petrole~n ptc-
ducts are a smalt portion
of total
U.S. pioduction,
and aount
to less
than 8 percent of the volune imported.l7 All exports are controlled

by a strict
ticensiri~g po'licy administered by the U.S. Department of Ccm-
merce. Recently, crude~oil expqrts have increased in response to the

Canada-UnitedStates` Crude Oil Exchangeprogram. The program is mutually
beneficial
ciency
ports.
bath
in that acquisition
of transpottation.
Table 9-13 srPnmarizes
costs are minimized through improved effi-
recent
trends
in major refined
product
ex-
fhe decline in exports through the 1970s can be attributed

increased
domestic
demand and the expansion
of foreign
to
refining
ca-
pacity.
9.1.3
Financial
profile
Despitethe recent softening in product prices, the oil industry

is generally regarded as financially strong. This optimistic outlook
is attributed
to:
inc~gases in proven domestic reserves
and decreases
in the prices
and the level
9-23
of imported oil.
and production,
Table 9-14.
IMPORTSOF REfINED PETROLEUM

PRODUCTSa
(1,000 m3/cd)
Motor
Distillate
Year
1969
Gasoline
10
Fuel Oil
22
1970
11
24
1971
1972
Residual'
r-71
Jet Fuel
20
Kerosene
O.S
NGLand LRG
6
243
23
0.6
24
252
29
0.2
17
11
29
277
31
0.2
28
1973
21
62
295
34
0.3
38
1974
32
46
252
26
0.8
34
1975
29
25
194
21
0.5
29
1976
~21
23
225
12
1.4
31
1977
34
40
216
12
3.0
32
1978
31~
27
214
14
1.7
N/A
1979b
27
14
178
11
1.4
N/A
"Reference
2.
Section
Fuel Oil
201
YII.
bReference 18.
9-24
Table
9-15.
EXPORTS OF REFINED
PETROtEUM PRODUtTSa
(1,000 m3/cd)
Motor
Year
Distiflate
Gasoline
Fuel
Oil
Residual
Fuel
Oil
Jet
Fuel
Kerosene
NGL and
1969
0.3
0.5
7.3
0.8
1970
0.2
0.5
8.6'
1.0
1971
0.2
1.3
5.7
0.6
0.2
4.1
1972
0.2
0.5
5.2
0.3
4.9
1973
0.5
1.4
3.7
0.8
4.3
1974
0.3
0.3
2.2
0.3
4.0
1975
0.3
0.2
2.4
0.3
0.3
4.0
1976
0.5
0.2
0.2
5.6
4.3
4.1
1977
0.3
0.2
1.0
0.3
2.9
1978
0.2
` 0.5
2.1
0.2
N/A
aReference 2.
Section
VII.
9-25
LRG'
Profit margins (i.e.,

net profit/sales)
and return on investment (i.e.,
net profit/total
investment) for both major oil cbmpanies and independent
refiners
are sisnmarized
served
is one of increases
year
period
in Tables
in both margins
The general
and returns
pattern
through
ob-
the five
noted.
It should
be noted
that
are for capanies
that
the profitabi~i~y
of refining
profitability
the margins
refine
of refining
crude
oil
activities
and returns
presented
in both tables
but are not necessarily
activities
s~rmmatizes the determination

9.2
9-26. and 9-17.
themselves.
indicative
An indication
of
of the
atone is provided by Table 9-18, which
of industry
profit
margins
by quarterly
intervals.
L~
ECONOMIC ANALYSIS
9.2.1 IntroductionandS~na~
In the following
sections
the economic impacts of the regulatory
alter-
natives are estimated based on the costs of sodi~n-based flue gas desulfuriza-
tion.
Economicimpacts are presented in terms of the potential price,
prqfitabi7ity,
and capital
availability
consequences of each regulatory
alternative.
For reasons noted in the following sections,-it

is most likely that the
regulatory alternatives
presented in Chapter 6 will result in slight increases
in the prices of refined pettole~m pradue'ts.
In most cases the mwim~n price
increases possiblg are less than 0.4 percent.
It is not expected that the
regulatory
ments
alternatives
at existing
would cause
along
the
used
results
are based upon observation
with the capital
previous section.
methods
of planned
FCC invest~
refineries.
These conclusions
conditions
the postponement
of the
economic
application
market
estima.tes
discussed
in the
that follow a complete description
of the
and annual
In the sections
to project
of current
impacts
of
those
is
cost
presented
methods
are
in Section
noted
trends
9.2.2
in Section
and
while
9.2.3.
9.2.2
Economic impact Methodology

9.2.2.1
Price Impact Methodoloa_y. The complete pass-through of the NSPS
control costs presented in Chapter 8 wilt cause increases in the prices of refined
petrole~m
mated through
unit
products.
the expression
and regulatory
the refinery
The extent
alternative,
of such prsce
of the annualized
control
as a percentage
in which the new unit is likely
increases
costs,
of the annual
to be constructed.
have been estiof each model

revenues
of
The percen-
tages ate therefore indicators of the extent to which refinery revenues, and
9-26
ii-~
Table
9-16.
'PROFIT
MARGINSa
1975
1976
1977
1978
19t4
1.9
1.7
3.0
3.1
8.9
5.6
5.4
4.5
4.6
5.4
4.9
5.0
4.2
4.4
5.5
3.9
3.6
3.1
3.2
4.5
Petroleun
6.7
7.2
6.0
5.0
11.1
Oil (Calif.)
4.6
4.5
4.9
4.8'
6.0
2.7
0.1
2.4
2.5
3.4
3.3
3.3
3.0
~ 4.6
4.0
3.9
3.9
3.0
7.5
3.3
3.3
3.4
4.7
8.1
4.8
6.8
6.4
6.5
7.2
4.3
5.5
4.8
2.5
5.5
1.6
1.6
3.6
Integtated-International
British
Petroleun
Exxon' Corp.
Gulf
Oil
Mobil
Corp.
Royal
Dutch
Standard
Tesoro
Petroleun
Texaco,
'5.3
Inc.
Integrated-Domestic
Gnerada
Hess
Ashland
Oil
Atlantic
Richfield
Cities
Clark
Service
Oil
Conoco,
and Refining
0.9
Inc.
Earth
Resources
Getty
Oil
Kerr-McGee
4.6
5.8
4.4
4.8
6.4
4.5
4.6
4.5
2.9
4.1
8.6.
8.5
9.9
9.3
12.5
7.3
6.9
5.5
5.7
6.0
4.4
4.4
Marathon
Oil
4.5
5.6
4.6
Phillips
Petroleum
6.7
7.2
8.2
' 10.2
9.4
6.3
7.6
7.3
7.4
7.8
' 7..9
7.7
7.6
7.2
8.1
5.1
4.7
5.2
8.7
15.0
5.0
6.6
5.6
4.9
6.6
4.6
5.0
5.9
6.4
6.6
1.0
1.5
1.3
1.2
8.7
1.2
2.4
2.0
2.8
6.8
Shell
Oil
Standard
Oil
(Indiana)
Standard
Oil
(Ohio)
Sun Co.
Union
Oil
of
California
Refiners
Cha~terCo.
Crown
Central
Petrole~
Holly
Corp.
3.1
4.0
3.8
3.5
2.6
Tosca
Corp.
N/A
0.9
l.Z
1.6
4.1
1.8
0.8
2.1
2.1
3.4
United Refining
aReference
12, P. 088'.
9-27
Table
9-17.
RETURNON INVESTMENTa
1975
1976
1977
1978
2.0
2.1
4.3
4.1
11.8
Exxon Corp.
Gulf Oil
Mobil Corp.
7.8
5.6
5.6
7.6
6.3
5.5
6.5
5.4
5.1
6.9
5.4
.5.2
9.5
8.2
' 8.0
Royal Dutch Petrole~Pn
6.8
8.4
8.0
6.0
13.5
Standard Oil (Calif;)
6.3
6.6
7.1
7.0
10.2
Tesoro Petralelm
9.0
4.0
0.2
5.3
9.9
Texaco, Inc.
4.8
4.9
5.0
4.4
8.1
5.5
6.3
5.2
4.5
1.7
6.7
'1'2.9
8.2
5.9
6.6
7.1
6.3
. 3.0
8.0
12.8
7.5
6.0
6.7
6.8
5.7
4.5
6.0
20.9
8.0
4.2
8.8
6.7
3.0
4.9
6.4
7.2
7.4
11.3
20.2
8.9
7.9
.10.6
9.7
8.5
11.2
Integrated-lnternational
British PetroleiPTI
Integrated~Domestic
Pmerada Hess
Ashland.0ll
Atlantic Richfield
Cities Service
Clark Oil and Refining
Conoco, Inc.
Earth Resources
Getty Oil
Kert-MeGee
Marathon Oil
Phi 17i os ~Pe
trol eun
Shell Oil
Standard Oil (Indiana) ~
Standard Oil (Ohio)
Sun Co.
Union Oil of California
10.1
8.9
6.9
6.1
7.3
6.7
8.0
7.8
8.5
9.4
8.5
2.6
7.8
6.3
6.1
9.5
8.7
8.4
2.3
6.6
7.0
5.5
11.1
8.3
8.0
5.0
6.8
7.3
7.3
11.5
8.4
9.6
13.4
10.2
8.7
3.2
3.2
5.3
5.1
11.1 ~ 10.6
2.6
2.8
3.4
6.4
9.9
4.2
29.1
16.8
8.0
14.2
6.2
11.0
8.4
3.6
5.2
6.3
Refiners
Charter Co.
CrownCentral Petroleim
Holly Corp.
rosco Corp.
2.0
2.9
9.1
N/A
UnitedRefining
5.0
aReference
12, p. 087-088.
9-28
2.1
5.6
Table 9-18.
PETROLEUM
REFINING- INCOME
DATAa
($1,000,000)
1978
1
Sales
Net
1979
3
41.75 43.88 46.17 48.52
r980~
3
50.72 54.71 63.68 73.58 79.80
Income
Before -Tax
Net Income
X Net
3.05.
3.77
4.14
4.23
4.65
6.16
6.62
7.81
8.55
2.55
3.15
3.41
3.66
3.95
5.25
5.71
6.84
8.04
6.11
7.18
7.39
7.54
7.79 9.60
8.97
9.30
10.08
9.30
10.08
Income
to Salesb
aRefetence
12,
P. 082.
bprofit margin.
9-29
thus the prices

profit
of refined
petroleun
margin on sales of refining

Th~eannualiz~d cost estimates
presented
tables
in Tables
separate
contents
would need to increase
if the
activities
is to remain unaffected.
used to project price increases are
8-9,
cost estimates
of feedstocks,
vs. soda ash.

described
8-4 through
products,
and Tables
8-11 and 8-12.
In those
are made for various model units,
regulatory
alternatives
Refinery revenue estimates
sulfur
and the use of caustic
soda
have been made through the method
below.
The addition
of FCC eapacity
enables
a refinery
to increase
the
value of Its product mix, producingmoreof the higher priced cDm;

ponents.~
Therefore
an~important
element
in both the price
and profit-
ability analysesis the estimationof increasedrevenuesmadepossibleby the

added FCC capacity.
been
estimated
Refinery
according
reSenues
before
to a three-step
and after
the FCC addition
process:
Estimate~refined
product yields
before and after
Estimate
refined
product
with
Estimate
refinery
prices
revenues
have
before
price
and after
FCC~ddition,
decontrol,
and
FCC addition.
Eachof the steps notedaboveare discussedin greater detail following.

the
identification
revenues.
of six.assumptions used to allow the estimation of refinery
Sources
First,
of data
are also
noted fotthe
assumptions
listed
below.
it is~assimed that the smaller model unit (2,500 m~/sd) is
addedto a small refinery (8,000 m3/sd)20,while the larger modelunit

(8,000 m3/sd) is constructed at a large refihery (40,000m3/sd).20
Second, the product yields for a typical refinery, orlented':oward gasoline production are: gasoline (51.'1X), distiiiate
(26.OX), residual (13.92),
and kerosene(9.02~2, wt~fl.ethe ratio of;FCCcapacity to crude distillation

capacity for such a refinery is 40 percent.21
Third,
it
is ass~med that
the addition
of FCC capacity
will
increase
the refinery FCCto crude distillation
ratio so that the average ratio before
and after
Therefore,
the addition
is 4P percent.
increased fCC capacity 32 percent (i.e.
the small refinery
will have
2,500/8,000) from 29 to 56 percent,
wi~i~ethe large refinery will showa fO percent increase (i.e. 8,000/40,000)

from
30 to 50 percent.
Fourth, the'product
tillate
yields
far FCC output are:
(21.0~), and residual (11.0=j;21
9-30
gasoline
(68.0=),
dis-
Llj
fifth, it is assrPnedthat additional FCCcapacity will operate at full

capacity and that the total crude distillation capacity of the refinery
remains
unchanged.
Sixth, the price decontrol of domestic crude and refined petroleun
produCts will add s25.20/m3to the average price of crude and this
increaje will be passed-onto the price of refined, product5.22

The first
step in the revenue estimation
process is the determination
of refinery product yields before and after the addition of FCCcapacity.
This has been accomplishedthroughthe assu~ptionthat 2,500m3/sd.of the

non-kerosene output of the smaller refinery
will take the form of the FCC
product yields noted in the fourth assimption, while the remainder of output
will
continue
in the form of the typical
refinery
yields
presented
in the
.secondass~Rtion. Likewise,the larger refinery will have8,000m3/sdof

its non-kerosene output take. the foim of the FCt product yields.
Non-kero-
sene output is of'concern since the output of kerosene should not be signi-
ficantlyalteredby a changein Ftt capacity. Theresults of this procedure

are presented in Table 9-19.
The decontrol
of domestic crude oil
and refi'ned
petroleum
prod'ucts
was completed on January 28, 1981 with the issuance of 8.0. 12287. _However,
all
costs
and revenues
1980 (lV) dollars.
reported
in this
znalysis
are expressed
in terms of
So that the effect of decontroi upon product prices, and
thusrefineryrevenues
maybe accuratelyeeflected,the November
1980prices23
of refinery productshavebeenadjustedto includethe pass-through
of %25.2/m3
as noted inthe
sixth ass~rmption.22 Product prices used in this analysis
are: gasoline(%262.3/m3),
distillate oil (s2~8.4/m3~,
residual oil
(5164.2/m3),and kerosene(%243.4/m?).
Finally,
total
annual refinery
revenues have been estimated based upon
crude capacity utilization of 64 percent24 and 357 operating days each

year.
after
The determination of annual revenues, for both refineries

the addition
of FC~ capacity,
is smmarired
before and
in Tables 9-20 through 9-23.
For piirpose of price increase estimation, refinery revenues after the installation
of additional
FCt capacity
are of concern.
However, in the profit-
ability analysis described in the following section, the increase in revenues

made possible by the additional FCCcapacity is of interest.
9.2.2.2.
Profitability ImpactMethodology. ~n order to estimate the
consequences of the full absorption of NSPScontrol costs, an Internal Rate
Table 9-r9.
REFINERY
PRODUCT
YIELD~
(percent)
Produtt
SmaT1
R~finer_r
LargeF~efinery
Gasoline
48.4
51.1
53.8
4.9.4
51.1
52.8
Distillate
27.7
26.0
24.3
27.1
25.0
24.9
Residual
14.9
13.9
12.9
14.5
13.9
13.3
Kerosene
9.0
9.0
9.0
9.0
9.0
9.0
Total
100.0100.0 10D.D 10D.O100.0100.b
aperc~nt of crude throughput processed by FCC.
9-32
Table 9-20.
REFINERY
ANNUA~
REVENUE;
SMALL
REFINERY
(8,0~0 m3/sd);
64 PERCENT CAPACITY UTILItATION:
Total
Outputa
Product
Product
BEFORE FCC ADDITIDN
Produc t-
Yie7db
(m_3/sd) (percent)
Product
Volime
Pric~e
(m~/sd)
(f/m')
Product
Revenue
(5 1980 IV)_
Gasoline
5,120
48.4
~ 2,478
252.3
649,979
Distillate
5,120
27.7
1,418
238.4
338,051
Residual
5,120
14.9
763
164.2
125,285
Kerosene
5,120
9.0
461
243.4
112,207
Revenue/ad
1,225,522
x sdlyear
Annual
ag,000 m3/sd x 0.64.

bTable 9-19.
CReference
23,
wholesale
prices,
November 1980.
9-33
Revenue
357
$437,511,354
Table 9-21; 'REFINERY

ANNUAL
REVENUE;
SMALL
REFlNERY
(8,000 m3/sd);
64 PERCENTCAPACITYUTILTZATION: AFTER FCC AOOITION
Product
Gasoline
Distillate
Residual
Kerosene
Tota~
Product
Produc
t Product
Product
Output~~
Yieldb
Volune
Pricec
Revenue
53.8
24.3
12.9
9.0
2,755
1,244
660
461
262.3
238;4
164.2
243.4
722,637
296,570
108,372
112,207
(m3/sd) (percent) (m3/sd) (S/m3) (5 1980IV)

5,120
5,120
5.120
5,120
Revenue/sd
x ad/year
Annual
Revenue
a8,000 m3lsd x 0.64.
b;,ble 9-19.
CReference 23, ~afesale
prices,
November 1980.
9-34
1,239,786
357
5442,603.602
Table9-22.
REFINERY
ANNUAL
RE~ENUE;
tARGEREFINERY
(40,000 rn3/sd);
64 PERCENT CAPACITY UTILIZATION:
.Total
Product
Cutout"
Yie~db
Praduct
(m3/sd)
(percent)
Gasoline
25,600
49.4
Distillate
25,600
Residual
Kerosene
JEFORE FCC AOOITION
Product Product
Product
VolLme
Price'
Revenue
(mJ/sd)_
(f/mj)
($ 1980 I\1)
12,546
262.j
3,317,046
27.1
6,938
238.4
1,654,0~9
25,600
14.5
3,712
164.2
609,510
25,600
9.0
2,304
243.4
560,794
Revenue/sd
6,141,369
x sd/year
Annual
Revenue
"40,000 m3/sd x 0.64.

bT,ble
9-19.
CReference
23, wholesale
prices,
November 1980.
357
52,192,468,733
Table9-23. REFINERY
ANNUAL
REYENUE;
LARGE
REFINERY
(40,000m3/sd~;
64 PERCENTCAPACITYUTILIZATION:AFTERFCC AODITION
rotal
Product
Product Product
Product
Vo1une
Revenue
Outputa
yieldb
Gasoline
25,600
52.8
13,517
262.3
3,545,509
Distillate
25,600
24.9
6,374
238.4
1,519,562
Residual
25,600
13.3
3,405
154.2
559,101
Kerosene
25,600
9.0
2,304
243.4
560,794
Product
Pricec
:r
(m?/sd) (percent).jm~/sd) (3/m3) (5 1980IV)
Revenue/ad
x sdlyear
Annus
6,184,966
357
Annual RRevenue%2,208,03t,B6t
"40,000 m3/,d x 0.64.
bTable 9-19.
CReference23, wholesale prices, November1980.
9-36
of Return (IRR) analysis has been conducted.

an estimate of an investment's profitability
all
variables
that
influence
This type of analysis provides

thrbugh both the inspection of
~ash flows over the life
of the
investment,
and
the expression of profitabitity

in terms of a single percentage rate or IRR.
Analysis of the change in the IRR, caused by the inability to pass-through NSPS
contralcosts,
serves as the basis for conclusions with regard to the impact
of such costs
upon the incentive
in question.
It should be noted that in this
increases
and decreases
attributable
related
to the
to construct
in refinery
installation
NSPS control
revenues
and operation
and operate
the refinery
application
the focus is upon
and costs
that
units
are directly
of FCC capacity
and the
equipnent.
In the'following
disc~ssion, the use of IRR analysis in the estimation
of potential profitability
impacts is explained.
First, all variables that
affect
the
and data
investment
sources
decision
are presented
along with the ass~mptions
used in the assigrpnent of va.lues
to these
variables.
made
his
is followed by a sample of the method by which annual cash flows are determined and evaluated
profitability
discussed
th~ IRR.
impacts of NSPScontrols,
bled and evaluated
descriptions
to identify
to allow
their
In the estimation
several 4ariables have been. assem-
incorporation
into
present~d below each of thesevariables

in terms
of
its
use
in the model.
the
lRR model.
is identified
In addition,
used to quantify each of the variables, are noted.

With regard to the prices of refinery products,
prevailing
of potential
sources
In the
and
of data
those price levels
in Nova~Tiber
of 1980, including the previously described adjustment
for price decontrol, have been used.22 It has else been assuned that the
refinery produces four products; gasoline, distillate
oil, residual oil, and
kerosene, which in reality account for over 86 percent of the voltrne produced
at domestic refineries.2
In this analysis the following constant prices have
beenused;galoline
(s262.3/m3).
dlstilTaie
oil (523~.41m3j,
residual
oil iS164.2im3),
kerosene (5243.4/m3). Noinflation adjustmentswere made.
It is:assm~ed that the refinery
has ~57 operating
days each year, and
that the raie of crude ~apacity utilization is 64 pe~tent.24

Crude acquisition
casts
have been determined
according
to an average
refiner acquisition cost of ls213.2/m3. This crude price is essentially

identical to that reported'for January If, 198225
9-37
attributable to price decontrol22. Heavietcrudes are estimated to be

3.7 percent cheaper than the average quality
refineries .26
crudes processed at domestic
Operating and maintenance costs far additional FCCcapacity are s3.02/m3
ands2.86/m3for the 2,500m3/sdand8,$00m3/sdFCtunits respectively.27
Costsjneludedare materials,laborand~:maintenance
supervision,utilities,
indirect
costs,
and plant
overhead.
Concerningdepreciation, annual charges have been determined based upon

accelerated depreciation
over 5 years.
She use of a 5-year asset life is
in accordance with the Accelerated Cost RecoverySystem(ACRS)defined by the

EconomicRecoveryTax Act of 1981.28 The required capital investment
in the FCCand supporting units is %8,869/m3/sdbased upon 7,949 m3/sd
capacity.29-Baseduponthis estimateanda scale-upfactor of .85, the

small model unit is assumed to require an investment of 526,373,000, while
the large
model unit
requires
s7O,884,000.
Uith regard to debt terms it has been assMed that part of the investment is financed throug~h debt and will be done so at a real rate of 10 percent
over 10 years.
It is assumed that
the investment
will
be fi:nanced at 40 percent
debt and 60 percent equity as is customary in the refining industry.30

Concerning NSPScontrol costs, such'cosfs have been presented in Chapter
8. ~towever, in qrder to allow consideration of the tax-reducing effects of
interest paqments, all capital charges have been separated into their depteciation
and interest
components.
The Federal tax rate
is ass~med to be 46 percent,
the rate on taxable
inccme on earnings in exce~s of $100,000 annually.31 It is also ass~sned

that the investment tax credit is taken on new investments. The credit
cannot exceed 10 percent of the investment and cannot be carried forward more
th an fifteen -years.32
Working capital or funds required to finance accounts receivable and
inventories are included in the IRR model as 10 percent of the additional
sales trehted by the new investment.33

working capital
last
year
that
In the model it~is assumed that
is financed from equity and is recovered at the end of the

the new unit
is operated.
Since the investment time horizon i? the lRRmodel is tO years, and

since the FCC unit has a depreciable
the
unit
after
10 years
is
assumed
life
of 5 years,
to be zero.
9-38
the salvaae value of
:i
Several
situations
have been evaluated
in order
to estimate
levels
of profitability
for FCC additions made under various circumstances-such
as, small vs. large units and refineries,
quality of crude oil used, and
level
of NSPS control.
The example presented
below pertains
to a small
FCt unit (2,500 m3jsd), added to a small (8,000 m3/sd) refinery, and
subject to control co'sts specific to Case 2, Regulatory Alternative II
(Table
8-5).
Since the new unit
ability
of the unit
refinery
revenues
below,
is evaluated
and costs.
are representative
and cash
the
is installed
flow
totals
that
FCC addition.
at an operating
through
the
inspection
Consequently,
or decreases
would
at the
For this
reason,
the
the profit-
of changes
all dollar
of increases
accrue
refinery,
amounts discussed
in cost,
refinery
revenue,
in the
profitability
of
,-.
the
is
flows
specific
in Table 9-24.
explained
o
new unit
can
of the refinery
to
the
investment
The line-by~line
to be discussed
determination
are
of annual
sunma-
cash flows
below.
Row 1, Revenue,
(sales)
represents
made possible
annual
revenue
revenues
after
of
FCC addition.
The cash
rited
tax
absence
the
be evaluated without the need to estimate the profitability

before
in
the
increase
throughthe
addition
before
the
the FCC addition

Costs,
made possible
through theahitity
heavier,
less
expensive
heavier
crudes
are
crudes.
estimated
crudes.
revenues
of FCC capacity.
is
the.difference
4437,511,000
5442,603,000
Row 2, Crude Acquisition
age quality
addition
of 55,092,000
FCC addition
in reffne~y
(Table
between
(Table
9-20)
the cost
reduction
to process greater
to be 3.7
Since the refinery
and
9-21).
represents
As noted
The
in the
percent
amounts of
previous
cheaper
section,
than
has crude capacity
aver-
of
8,000 m3/sd, and is bperatina at 64 percent of capacity, and

since the FCCaddition has capacity of 2,500 m3/sd, it is esti-
I'
mated
that
48.8 percent
total
crude
cost
reduction
processed,
(i.e.
2,500 ; (8,000
can be replaced
is therefore.l.e056
x 0.64))
by heavier
percent
(i.e.
of the
crude.
$8.8
Total
x 0.037).
Zince annual crude costs before the addition are 5389,695,000
9-74
Table 9-24.
EXAMPLE: CASIIFLOWANALYSIS;CASE 2, REGULATORY

ALTERNATIVE
11
(%l,ooo 1900 Iv)
Year
_ 02
1. REVENUE
5,092
2. Crutle ncquisition Cost
5,092
BV
85
5,092
5,092
L1~6~--I~7---1SFT~--7~~T~--m~----gf
5,092~ 5,092
5,092
5,092
5.092
5,092
-7,036 -7,036 -7,036 -7,036 -7,036 -7.036 -7,036 -7,036 -7,036 -7,036
3. q,erating and Maintenance

4. I)cpreciation
2,695
3,9'36
5. Interest
1,055
2,61)5
5,002
2,695 ~ 2.695
5,530
5,530
2,695
5,538
2,695
2,695
2,695
2,695
2,695
740
651
544
127
290
156
909
916
036
670
2.450
2.113
2,033
331
900
331
701
339
672
334
672
334
672
334
334
334
334
334
9. interest:
NSI)S
10. Total Cost: NSPS(7t...9)
320
1,139
300
1,330
270
1,204
254
1,260
227
1,233
197
531
165
492)
130
464
90
424
47
301
11. TOTAL
COST(6+10)
1,004 3,700 3,397 3,293 3,170 -3,159 -3,29B -3,450 -3,613 -3,004
12. EARNINGS
IIEFORE
TAX(I-11)
13. TaKLial,ility (~2 x 0.46)
3,2UO 1.304 1,.695 1.793 1,1)111 0,251 0.390 0,512 0,711

1,512
600
700
020
000 3.795 3,059 3,929 1,007
6. Total Cost (2 +. .5)

7. Operating and'~aintendflte:
0. ncprec i at i on : NSPS
NSPS
19. Inveslnicnt Tax Crerlit

15. TOTALTI\X (13-19)
140
16. ~~RNINGS
AFTER
TAX(12-15)
17. Depreciation
ill. Deprecialion:
1,364
NSI'S
3.140
3,956
100
543
70$
346
57
76
'~02
1,315 -3,630 -3.797 -3,914 -4,043 -4,1115
000
3,795
3,859
1,217 1,619 1,317 1,034 1,4156 4,531
5,002
701
5,530
5,530
612
672
5,530
3.929
4,007
4,613 4,704
Salvage
23.
4.004
509
Valtie
22. PI-incil,al RePaiillent: NSPS
4,092
672
19. IlorkingCapital Recovery
20.
0.096
4,092
662
201
720
noi
221
cui
243
267
sss 1,066 1,173 1,290 1,419 1.561

294
323
356
391
130
473
NET CASII FLOW (16-117~-111c19~
20 %1-22)
6,713' 6,n0~ 6,705 6,379 5.981 3,067 3,002 2,1132 2,855 3,279
`24. Discollnt Fdctor
25. Pisco!mcctlCdsliFlow(23 x 24
0.742
0.551
$,9D1 3~2~,
0.409
.1_11_
0.301
0.226
775 1,931) 1,352
i I.I
0.167
512
0.124
372
0.092
270
0~069
197
0.051
167
,,l,~,d
(i.e. 5213.2 x 8,000 x 0.64 x ~57) the estimated potential redu~tion in crude acquisition
costs is 57,036,000 (i.e.9389,695,000
0.018056).
Row3, Operating and Maintenanceexpenses are based upon FCC
operating andmaintenance
cosfs of 43.02/m3. Annualoperating
and maintenance cost increases are therefore
53.02
52,695,000 (i.e.
x 2,500 x 357),
Rowa, Depreciation,is based uponthe decelerated (ACRS)

depreciation of a capital expenditure of 526,373,000 over S years.
ACRS~
allows annual depreciation charges to be 15 percent for the first
year, 22percentfor the second~

year, and21percentfor the third,
fourth,
and fifth
years.
Row5, Interest, for eachyear is baseduponthe interest/principal

repa~ment schedule for a loan of 910,549,000 (i.e. f26,373,000 x
0.4 (debt portion)) at 10 percent for 10 years.
Row6, Total Cost, is the sumof cost increases related to the 600
addition
and indicated
in rows 2 through
5.
Row7, Operating and Maintenance: NSPS,Costs are taken from

Table 8-5. Operating and maintenance costs attributable to NSPS
are.tota'l'net
annual costs (5860,000) less the capital tecovery
costs (5526,000) which ate acc'ounted for separately in rows 8
and 9.
Such casts
are therefore
5.334,000 in each year.
Rowg, Depreciation: NSPS,is based upon the accelerated jAtRS)
depreciation of a capita! expenditure of 53,200,000.

Row9,:Interest:'
N5P5, for each year is determined through the
calculation of the interest/piincipal
repaqment schedule for a loan
of 53,200,000at real rate of 10 percent :or 10 years.

o
Row10, Total Cost:

controls
and indicated
NSPS, is the sum of all costs related to NSPS

in rows 7 through
9.
Row11, Total Cost, is the total of all costs related to both the
.FCC unit and the NSPScontrol equipllent. It is therefore representative of the net change in total refinery costs that are attribut-
able to the purchase, installation

unit
and its
related
NSPS control
and operation of the new ;CC

equipment.
Row12, Earnings Sefore Tax,.is obtained by subtracting
the
change in refinery costs (roH 11) from the increase in refinery

9-4"1-
revenues (row 1) to determinethe net change in pre-tax earnings

attributable
controlled
FCC addition.
Row13, Tax Liability, is calculated based upon a marginal tax

rate
to the
of 46 percent.
Row14, investment Tax Credit, is determined by allowing a credit

of 10 percent of the added investment,
A single ~ar's
credit
shouldnot exceedthe first 525,000in tax liabi~ity plus93percent of liability
over 425,000.
Since the situation
described
in Table 9-24 requites a total .Investmentof $29,573,000(i.e.,

525,373,000for the FCCunit and43,200,000for NSPS
control equipment), the total investmenttax credit available is 42,957,000.
o
Row15, Total Tax, is each year's tax liability

inlestment
tax
less that rear's
credit.
Row16, EarningsAfter Tax, is the total of annualearningsafter

all taxes have been paid. Earnings after tax is one componentof
annual
net
cash
flow.
Rows17 and 18, Depreciation, entail the "adding back" of depteciation expenses for both the FCCunit and NSP5control equipnent. Depreciation is added back'since it is a non-cash expense and is included as-a cost simply to alloQ the determination of annual tax
liab i.l ity.
Row19, WorLingCapftal Recovery, must be added'to the final year's

cash flow since those funds that had been required to finance
accounts receivable andinventories will no longer be needed when
the unit is sold after
working capitalrecovered
o
the end of .the tenth yeat.
The amount of
is 5509,000 since this amount was finan-
ced by equity in the first

year.
Row 20, The Sa7vage Value of the fully
depreciated
Onit is assuned
to be zero because it fs unlikely that the unit will be liquideted.
Rows 21 and 25, Principal Repa~snent, are deducted from the annual
cash flows since they are not tax deductible expenses.
Row23, Net CashFlow, is a summary

of all ~czshflows (i.e. earnings
after tax,~'depreciation,
working
capital recovery,andsalvagevalue)
and deduction of principal repa~ments.
9-47
.
-
Fina~ly Rows24 and 25 are presented to illustrate

determination
of the IRR. The IRR for-uneven
the mechanics of the
annupl cash flows can only be
calculated through an iterative procedurethat graduallyidentifies the

discount factor (or IRR) that equates the sim~of the discounted cash flows
with the original equity investment. The IRRis therefore an indication of

the profitability
of an investment over its entire life.
In the example presented
the IRR is 34.7 percent.
This is sb since
when each year's discount factor (R~w24), which is determined by;

Discount
Factor;,Year
(1.347)."
is applied to the annual net cash flows (Ran 23), the sun of the discounted
cash flows(516.3million) is equalto the original equity inves~nentmadeat

the beginningoi`1982. In this case the equity investment-ig the sL~m
of
f15.8 million (equity portion of total investment) and S0.5 million in
working capital.
A procedure identical to that described above has been performedfor 26

situations
feedstock
representing various assirmptions related to model unit size,

sulfurlevels,
venturi
system used (i.e.,
high energy vs, jet
ejector) andNSPS
regulatoryalternative; Theresults of that analysisare
presented
9.2.3
and disc~usssedin
Economic
9.2.3.1
Section9.2.3.2.
Impacts
Price Impacts. As noted in Section 9.2.2.1 maximllinpotential
price increases hh)rebeen estimatedthroughthe expressionof annualiredcontrol costs as a percentage of the annual-revenues of the refineries
at which
newFCCunits are likely to be constructedandmodifiedor reconstructed.

The results
of that procedure are summarized in Tables 9-25 and 9-26 for
small and large units,
respectively.
According~'tothe results presented in the tables noted above, maximum

price increases for refined petrole~rmproducts are relatively small and
and thus the demand for such products should be unaffected.
likely therefore that the profitability

be impacted by the costs related
to this
It is mast
of refining activities will not

NSPS.
Theprice increasesnotedaboveare in all cases less than 0.4 percent,

and are judged to be small in light oi volatile price movementsin the refined
Table 9-25.
PERCENT
PRICEINCREASES
BYREGULATORY
ALTERNATTVE:
SMALL
(2,500 m3/sd) MODEL
UNIT
High Energy VentuTi

0.3
Percent
Sulfur
Caustic Soda
0.00
0.15
0.16
SodaAsh
0.00
0.15
0. 15
1.5Percent
Sulfur
3.5
I:
Caustic Soda
0.23
0.23
0.24
Soda Ash
0.19
0.20
0.20
0.33
0.26
0.34
0.26
0.35
0.27
Caustic Soda
0.34
O.JS
0.36
Soda Ash
O 31
Percent
Sulfur
Caustic Soda
Soda Ash
3et Ejector Venturi
1.5
Peicent
Sulfur
9-44
-~--
Table
9-26.
PERCENT PRICE INCREASES BY REGULATORYALTERNATIVE:
LARGE(8,000 m3/sd) MODEL

UNIT
II
III
IV
0.00
0.06
0.06
0.00
0.05
0.06
O.11
0.11
0.12
0.08
0.09
0.09
0.17
0.18
0.18
0.13
0.13
0.13
0.16
0.17
:0.17
0.14
0.15
High Energy Venturi

0.3
Percent
Sulfur
Caustic
Soda
Soda
1.5
Percent
Sulfur
Caustic
Soda
Soda
3.5
Ash
Ash
Percent
Sulfur
Caustic
Soda
Soda Ash
Jet
Ejector
Venturi
1.5
Percent
Sulfur
Caustic
Soda
Soda
Ash
'0.14
9-45
ptoduc ts market.
wholesale prices
For example, escalating crude prices alone have caused the

of motor gasoline. distillate
oil, and residual fuel oil to
increase 28.7, 20.1, and 32.5`percent respectively from November1979 to Nov~nber 1980.
Furthermore the previously
discussed
decontrol
of domestic crude is
expected to increase average crude prices by an additional 13 percent, an increase that
industry
analysts
agree will be passed-on to consumers.22
~nese
developments along with the generally low elasticity of demandfor petrofe~m

products (see fable 9-9) indicate that the NS?Srelated control costs should be
ultimately paid by the consmner in the form of slight product price increases.
9.2.3.2 Profitability
Impacts. As noted in the previous section it is
most likely that the economicimpactsof this standard will be expressedin

terms of product price increases, and thus the profitability
of both new and
modtfi ed/reconstruc
ted un i ts should be unaff ected .
estimates
unit profitability
reductions have been madein order to assess the unlikely
event that small product price increases
As explained in Section 9.2.2.2,
are resisted
However,
of
new
by consumers.
the IRRmethod allows the expression
of the profitability of a multi-year investment as a single percentage rate.

Therefore the comparisonof those rates, or Internal Rates of Return (IRRs)
both before and after NSPS control, provides an indication of the extent to
~ui~ichprofitability
may be reduced if related cost increases must be absorbed
by refiners.
Becausethe costs of NSPSvary according to both the suliur content

of FCCfeedstocks
and the use of caustic
proces~, estimates of profi;ahility

profitability
impacts
soda vs. soda ash in the control
reductions also vary.
in terms of IRRs after
=~
For this reason
NSPS have been estimated
as ranges, wherethe upper limits are de~inedaccordingto the use of 1.5

percentsulfur
feedstock
and soda ash, while the lower limits
are estimated
based upon high (3.5~) sulfur feedstocks and the more expensive caustic
soda.
Table 9-27 summarizes the ranges of profitability

estimated for addit iona i ~FCC c spae i ty. The table notei both the uncontrolled or baseline
IRR for each unit as well as IR8s for each regulatory alternative.
The extremes of profitabilit~ reduction noted in Table 9-27 wouldnot,
if actually incurred, reducethe profiiability of newFCCcperationsto the

point where planned investments would be postponed.
situations
allow the possibility
This is so since all
of a return greater than 18 percent wniCh

O,b(i
ii;
Table
9-27.
INTERNAL RATES OF RETURN
REFINERY UTILIZATION
RATE = 64",
Small (2,500 m3/sd)

Regulatory
Model Unit
Aiternati;e
Lowa
No Controlc
RighT7
Large (8,000 m3/sd)

Model Unit
-Lbwa
37.7
Ki9hP
44.9
High Energy Venturi

Reg. Alt. II
31.3
Reg. Alt. III
31.1
Reg. Alt: IV
30.9
34.7
34.5
34.5
39.6
39.4
3'9.3
42.8
42.7
42.6
Jet Ejector Venturi

Reg. Alt. II
Reg. Alt. III
31.1
30.8
31.9
31.8
40.4
40.2
41.1
41.0
Reg. Alt. IV
30.6
31.7
40.0
40.9
aAssmnes
caustic
soda
and 3.5X sulfitt'feedstock
with
high
energy
venturi,and
1.5Pd sulfur f.eedstock with jet ejector ventuti.
bAssunes soda ash and I.SX sulfur feedstock for both uenturi
syst8ns
cWithout
the
use of Accelerated
are 31.0 and 37.3 percent
Cost
fotthe
Recovery,
No Control
wnall and large
9-47
units
IRR's
respectively.
has been estimated as the average cost of equity to those firms that maybe
affected by NSPS. The cost of equity noted above has been estimated based
uponthe reported stock prices of'and earnings pe~ share of 31 integrated
companies and independent refiners for 1979.35
oil
9.2.3.3 Capital Availability.

Compliance with each of the regulatory
alternatives requites that additional capital expenditures be made for the
purchase and installation of control equipnent. Comparison of the cap~Lal
control costs (Tables 811 and 8-10) to the 866 unit capital costs noted in
Section 9.2.2.2 indicates that the capital requirements of the snail unit
. ~
could increase 12.1 and 17.8 percent under the high energy and jet ejector
venturi systems respectively. For the larger unit the percentage increases
;-,
are 7.6 and 11.6 for
]~
the sane systeTis.
While the capital requirements noted above will cause affected refiners
to seek additional financing, it is not expected that capital availability

difficulties
vati
will be encountered.
This conclusion is based upon tK, obsgr-
ons.
First, the IRRanalysis described in previous sections has implicitly

indicated that even with the addition of nan-productive control equipment
the profitability of the investment is maintained. Morespecifically, since

the control equip~en't was assmnedto have been financed from debt the pa~y~ack
of that debt is assured, This observationis evidenceto those whowould

provide debt financing that the debt can be repayed.
Second, the overall trends in earnings and cash generation
exhibited
by the industryhaveled to steadily decreasingdebt-to-equityratios. Such

ratios are in manycases less than ~Opercent,36 an indication that many
companies may finance the control
expenditures
much larger
the use of outside
9.3
expenditures,
without
noted above, as well as other

funds.
SOCIOECONOMIC
ANDINFLATIONARY
IMPACTS
Section 9.2 has described the potential economic impacts of NSPSupon

the petroTe~T1 refining
segment of the economy. In this section broader
economic impacts are examined including inflationary, Pmplcq~ment,

balance of
trade,'and small business impacts. In addition the significance of the
impacts of the reguf atory alternatives
Order
12291
is
from thee point-of-view
assessed.
9_48
of Executive
~d
9.3.1
Executive
Order
12291
Accordingto the directives of Executive Order 12291"najor rules" are

those that
are-projected
to have any of the following
effect
impacts:
an annual
a major increase in costs or prices for consumers, individual

industries,
Federal',
geographic
on the economy of S:00 million
regions,
significant
State~, or local government agencies,
States-based
or
innovation,
enterpri-ses
in domestic
or on theabilityof
the United
to compete with foreign-based
or export
enter-
markets.
In each of the fol~lowing sections these ctiteria

to the proposed
or
adverse effects on competition, emploqment, invest-
ment, productivity,
prises
or more,
are examined in relation
standard.
9.3.1.1
Fifth-Year Annualized Costs. Table 8-13 provides a simu~aty ofthe determination.of
the fifth-year
annualited costs of this standard.
As
indi.cated, such casts ate calculatedthrough

alized costs related
to each FCC unit type and sulfur
each unit expected to be constructed'over

costs are therefore
tory Alternatives
9.3.1.2
the multiplication
estimated
level,
of the annu-
by the nunber of
the five-year period.
Fifth-year
as 832.1, 935.2, and $36.7 million
for Regula-
II, TII, and IV respec'tl'vely.
Inft ationary Impacts. As noted in Section 9.2.3.1 poten~
tial price increases for refined petroleun products are

than 0.4 percent. For reasons detailed in that section
most like~y~t6 be lower than thase~indicated as refiners
control inputs. 'Refined product price i?creases of the
are expected to cause virtually no increase in the rate
estimated to be less
price increases are
aTiployless costly
magnitude estimated
of inflation.
9.3.1.3 Emplo~entImpacts. Asdescribed in Section 9.2 the reguletory

alternatives
are not expected to have any impact upon the demand for the
products of, or profitability

of, new FCCunits.
upon refinery employmentare anticipated.
9.3.1.4
9.1.2.5,
Balance
of Trade
very small portions
Impacts.
of the total
ks noted
For this reason no impacts

in Sections
9.1.2.4
and
domestic production ofrefined
petroleim products ate traded internationally.

For this reason, along
with the very low price impacts estimated, no potential For impact upon
the United States balance of trade-is indicated.
9-49
9.3.2 SmallBusiness Impacts- RegulatoryFlexibility

The Regulatory Flexibility Act of 1980 requires the identification of
potentially adverse impacts of Federal regulations upon small business
entities. The Act specifically requires the completionof a Regulatory

Flexibility Analysis in those instances wheresmall business impacts are
possible. The following discussion is intended to certify that this
regulation will not have a significant economic impact on a substan.tial
numberof snail busir,esses, thus eliminating the need to perforn a
Regulatory
FlexibilityAnalysis.
The conclusions noted above have been based upon the definition and
consideration
of
three
factors:
"'7
the maximum size of a small business;

the number of small businesses
the expected economic impacts.
affected;
and
With regard to size, the Small Business Administration (SBA)has defined
small petroleumrefineries as those that employfewer than 1,500 persons.
This total, whichincludessubsidiaries and other affiliated operations,

has been specified by SEA(13 CFR, Part 121) for the purpose of its various
loan and assistance
programs.
Concerningthe numberof small businesses affected, if the prospective

affected facilities were distributed proportionately betweenlarge and
small refiners,
two or three units would be built by the small refiners.
However,due to the discontinuanceof the entitlements program,very
-;3
little construction is anticipated at the small refineries.

Thus the
percentage of small refining businesses affected will be well below the
.4
level
of
concern.
In addition, the economic impacts are expected to be minor even for

the small refiners.
As noted in the previous sections, the cost of this
#SPSshould be capable of being included in the prices of refined petroleum

products, and in all cases price increases are less than 0.4 percent.
Therefore, because the standard does not affect a substantial numberof
smai7businessesandwill not entail significant economicimpacts,a Regulatory

Flexibility
Analysis
has not
been conducted.
9-50
9.4
REFERENCES
1.
Petroleum
Refineries
in the United States
Department of Energy.
(sb).
~ashington,
D.C.
and U.S. Territories.
Publication
January 1, 1980. Docket Reference NumberII-T-67.+'
2.
American Petroleum Institute.

Tables 4-4A. November 1978.
3.
Standard and Poor's.

p. 074.
Basic Petroleum Databook. Section VII.

Docket Reference Number IT-I-45.f
Industry Survey's - Oil. August 7, 1980 (jection 2)
4.
Reference 3, p. 081.
5.
Docket Reference Flumber II-I-78.f
6.
Reference 2.
7.
U.S.
No. 00E/EIA-0111
Section V, Table 2.
Cantrell, A. Annual Refining Survey. Oil and Gas Journal.

March 26, 1979.
Docket Reference
2, Section
8.
Reference
9.
Cost of Benrene Reduction in Gasoline to the Petroleum Refining Industry.

U.S. Environmental
April 1978.
V, Table i.
77(3):127.
Number II-I-57.*
Protection
p. 1-3.
Docket Reference
Agency.
Number II-I-45.X
OAQPS. EPA-450/2-78-021.
Docket Reference Number II-A-3.*
10. Energy Information Administration. U.S. Department of Energy. Annual

Report to Congress 1979. Vol. 3, p. 114. Docket Reference NumberII-I-46.+
11.
Hoffman, H.L., Components for Unleaded Gasoline. Hydrocarbon Processing.

59(2):57,59.
February 1980. Docket Reference Number II-I-69.1
12.
13.
Docket Reference Number IT-I-46.'
14.
Reference
15.
16.
Carter,
3, p. 061.
C.P.
Docket Reference
Number II-I-S9.I
What Worldwide Analyses Imply.
58(9):103. September1979. DocketReference Number11-1-65."

17. Beck, J.R.
Production Flat; Demand,Imports Off.
Oil and Gas Jburnal.
18(4):108. January 28, 1980. DocketReference PlumberII-I-68.*

18.
Johnson, Axel, R.
Refining for the Next 20 Years.
55(9):109. September1979. DocketReference NumberII-I-66.*
9-51
19. Reference 3, p. 082. Docket Reference NumberII-I-78.f
20. Developmentof PetroleumRefinery Plot Plans. U.S. Environmental

Protection Agency. ResearchTriangle Park, N.C. Publication
No. EPA-450/3-78-025,June 1978. DocketReference NumberII-A-4."
21.
Carter, C.P. Is MoreRefining Needed? HydrocarbonProcessing.

59(11):171-175. November1980. DocketReference FlumberII-I-83.*
22.
The Chase
1981.
23.
~lanhattan
Bank.
Docket Reference
Reference 22, p. 3.
The PetroleumSituation. 5(1):2.
Number II-I-85.R
January
Docket Reference NumberII-I-SS.f
24. Reference 10, p. 115.- Docket Reference NumberII-I-46.f

25.
Oil
and Gas Journal.
Number
80(11):145,
II-I-97.f
March 15, 1982. Docket Reference
26. Annual
Reportto Congress
1979. Vol.2. U.S.Department
of Energy.
Washington, D.C. pp. 77-79. Docket Reierence Number11-1-47."
27.
Gutherie,
K.M.
Capital and Operating Costs for 54 Chemical Processes.
ChemicalEng~neer~ng. June 15, 1970. DocketReference Number11-1-4.+

28.
Prentice-Hall,
Inc.
1981.
p. 22.
Handbookon the EconomicRecovery Tax Act of
29. 1980RefiningProcessHandbook.Hydrocarbon
Processing.59(9):148.
September 1980.

31. Reference 28, p. 26.
Docket Reference Number~I-I-96.+
32. Reference 28, p. 35. Docket Reference NumberIIIT-96.*

33. Reference 3, p. 085. Docket Reference Number~I-I-78.~
34.
The Chase Ilanhattan
1980.
aank.
Docket Reference
The Petroleum Situation.
Number II-T-84."
4(12):4.
December
35. Reference 3, p. 091. Docket Reference Number11-1-78."

36. Reference 3, p. 084. docket Reference Number11-1-78."
38. ;;c;erence 1, p. 24-35.. Docket Reference NumberI~~I167.~~
"References
can
be
located
in Docket Number A-79-09 at the U.S. Environmental
Protection AgencyLibrary, #aterside Mall, Washington,D.C.

9-52
APPERDLX A
A-i
APPENDIXA.
A.1
EVOLUTION
OF THE PROPOSED
STANDARDS
INTRODUCTION
TheCleanAir ActAmendments
of 1970strengthenedthe Air 4ualitr
Act of 1967by inCluding authority to promulgate standards of performance
for major newsources. (Section 111) and to promulgate national emission
standards far existing sources of hazardous pollutants (Section 112).
During the 1977 hearings on the Clean Air Act, Congress received
testimony on the need for more rapid sta'ndarddevelopnent.
r--1
3
There was
concern that not all sources which had the potential to endanger
public health or welfare were controlled.
These concerns were reflected
in the Clean Air Act Amendments

of 1977. The Amendments
require
promulgation of the new source performance standards (NSPS)on a
greatly
accelerated
schedule.
As providedfor
standard
setting
under Section 111 of the Clean Air Act, the
mechanism also includes
promulgated standards.
a 4-year review of all
As a result of this review, FCCunit regene-
rator sulfur oxides emissions were identified as a pollutant to be

studied, to determine the needfor an NSPSfor new and modified facilities.
NSPSdevelopment for the control of sulfur oxides emissions from FCC
unit
regenerators
began
in March 1980.
Informationwasgatheredthroughplant visits to petroleunrefineries,
Section 114 info~7nationrequest letters to oil companies,and telephone
contactsto industryreprese?tatives, consultants. and equipment

manufacturers. In addition, a literature
of emission test results,
this effort
A.2
are listed
survey, including examination
was conducted.
chronologically
The major events relating

~elow.
to
CHROFJOLOGY
The following
chronology lists
important
events that occurred
during the development of the background information document for the

fluid catalytic cracking unit regenerator NSPS.
A-2
CHROFIOLOGY
Date
3/8/74
Activity
Particulate
and carbon monoxide NSPS
promulgated
for
unit
10/??/79
fluid
regenerators
The results
standards
of the 4-year
and
EPA's
the development
SO
catalytic
emissions
cracking
(39 FR 9315).
review of
intent
to
undertake
of an NSPS to limit
frcm fluid
catalytic
cr~ckingunit catalyst regenerators

announced in the Federal
Register
(44 FR 60759).
3/5/80
For;nal kickoff
and
the
Services,
4/1/80
Initial
meeting held between EPA
contractor,
Inc.
Pacific
Environmental
(PES).
meeting held with representatives
of Amoco to establish
contact
among the
organizations
and provide
background
information
oncurrent
catalyst
technology,
hydrodesul furization,
4/2/80
Initial
of
meeting
ARCO to
and scrubbers.
held with representatives
establish
contact
amono
the
organizations
and provide
background
information
on current
catalyst
technology,
hydrodesulfurization,
and scrubbers.
4/3/80
Initial
meeting held with representatives
of Chevron
organizations
information
to establish
con-tact
and provide
on current
catalyst
hydrodesulfurization,
4/3/80
among the
background
technology,
and scrubbers.
Meeting held with Bay Area Air Quality
ManagementDistrict
(California)
to discuss
their 502 emission limit for FCCU's.

5/21/80
A visit
was made to the New Jersey
Department of Environmental
Protection
(NJDEP) to acquire
information
on Ex~on
FCCU in Linden, New Jersey.
5/22/80
A visit
Board
A-3
was made to the fexas Air Control

(TACB) to obtain
emission
data.
CHRONOLOGY
(Continued)
Date
Activity
6/18/80
Meeting held with the American Petroleum
Institute
(API) Stationary
Source Advisory
Committee to establish
protocol and acquaint
the Stationary
Source Advisory Committee with
the FCC;Jnew source performance standard study.

7/23/80
An initial
meeting was held with
representatives
of Shell Oil Company
to discuss some of the control capabilities
of hydrodesulfurization.
7/23/80
An initial
meeting was held with
representatives
of Pullnan Kellogg to
discuss
residualcracking
activities
and typical
FCt maintenance
procedures.
7/24/80
A plant visit
was made to the Exxon
Company U.S.A. refinery
in Baton
Rouge, Louisiana,
to view the operation
of the jet-ejector
8/13/80
scrubber
and to assess
the potential
for emissions
A plant
was made to the Oklahoma
visit
Refining Companyrefinery
City, Oklahoma, to obtain
hydrodesulfurization
testing.
in Oklahoma
information
on
and small refinery
operations,
8/14/80
A plant
visit
Refinery
obtain
information
and small
9/24/80
A plant
was made to the Conoco Oil
in Ponca City,
refinery
visit
Oklahoma,
to
on hydrodesul furization
operations.
was made to the Marathon
Oil Company Refinery
in Garyville,
Louisiana,
to gather background
information
on the
control
of FCCU regenerator
sulfur
oxides
emissions
with wet gas scrubbers.
10/28-31/80
12/8/80
PESstaff memberattended the EPAsymposium

on Flue
Gas Desulfuritation.
Section
114 letter
sent
to the Marathon
Oil Company Refinery in Garyville,

Louisiana, on FCCUscrubber performance.
A-4
CHRONOLOGY
(Continued)
Gates
2/19-~0/81
Activities
Section 114 letters
sent to Amoco, ARCO,
Rock Island Refinery,

Phillips
Ghevron, Texas City Refining,
Petroleum,
and Ashland
on FCCU modifications.
3/18/81
Received Rock Island Refining Corporation's

response
3/20/81
the
Section
114
114
letter.
Draft 5ID Chapters 3-6 mailed to

industry,
environmental
and Stateagencies
4/3/81
j
letter.
Received Chevron's response to the

Section
3/26~81
114 letter.
Received Marathon Oil Company's response

to
3/24/81
to the Section
for
oiganizations,
comments.
Received ARCOlsresponse to the Sectionll4

letter.
4/13-5/29/81
Received commentsof draft BTDChapters 3-6

from
American
Petroleum
Institute,
Chevron
Research Company, Davy McKee Corporation,

Mobil Oil, Amoco Oil, and M.W. Kellogg.
5/4-6/2/81
Source testing
Refinery
5/22/81
SeCtion 114 letter

information
catalyst
5/27/81
to the
oxides
reduction
Section
114 letter.
Received Chevron's response to the

114
reduction
letter
on sulfur
catalyst
oxides
technology.
Received response to Section 114 letter

from Texas City
8/27/81
sent to Chevron for
on sulfur
Received Ashland Petroleum Company's
Section
8/24/81
Louisiana.
technology,
response
7/6/81
at the Marathon Oil Company
in Garyvill
Refining.
Meeting held with API to discuss project

status
and baseline
assessment
A-5
program.
nitrogen
oxides
emissions
CHRONOLOGY
(Continued)
Dates
10/7/81
Activities
Section
114 letter
on baseline
NO
emissions from FCCUregenerators

existing
data
~nd
on SO and NO emissions
from suifur oxides Peductiof~catalysts

sent
10/15/81
to
Chevron.
Section 114 letter
on baseline NO
emissions from FCCU

regenerators ~nd
existing data an SO and NO emissions
from sulfur oxides Peductio#catalysts
sent to Southwestern Refining Company,
Atlantic
Richfield
Company,
Phillips
Petroleum Company, Standard Oil of Indiana,

Texaco, l"lobil Oil Corporation,
Gulf Oil
Company, and Union Oil of California.
10/27/81
NAPCTAC
package distributed to Federal
agencies,
industry,
and public
interest
groups.
10/28/81
Notification of NAPCTAC
meetingsent to
the
Philadelphia
Department
of Public
Health and Colorado Department of

Health.
11/5/81
Notice of NAPCTAC
meeting published in
Federal
11/6/81
Register.
Letter sent to Davison Chemical Division,

W.R. Grace and Companyrequesting existing
commercial and pilot
plant
test
data on
sulfur oxides reduction catalysts.

Meeting held with API to discuss the
baseline NO emiss ions assessment program

and industrg responses to the Section 114
letters requestingNOxtest data.

Letter sent to Englehardt Corporation
requesting
plant test
existing commercial and pilot

data on sulfur oxides reduction
catalysts.
Letter sent to Filtrol Corporation

requesting existing
plant
test
catalysts.
A-6
commercial and pilot
data on sulfur
oxides
reduction
ia
CHRONOLOGY
(Continued)
Dates
Activities
11/23/81
Received API response to EPAinformation
request for FCCU

NO,emissions data.
11/24/81
Received Texaco U.S.A. commentsregarding
EPArequest for P~Ox

emissions testing.
12/1/81
NAPCTAC
meeting held at the Royal villa
12/1/81
Received ARCO
commentsregarding EPA
Hotel in Raleigh,
information
North Carolina.
request
for FCCUNO emission
data and the API alternative

12/8/81
pl~n.
Received Mobil Oil Corporation's comments

regarding EPA information request for
FCCU
NO,emission data.
12/9/81
Received Southwestern Refining Company

comments regarding
NO emission
data
EPA request
for FCCU
and the API alternative
pl~n
12/9/81
Received Standard Oil Companycomments

regarding EPA request for FCCUNO
emission data and the APIalterna~ive

plan.
12/14/81
Received FMCCorporation response to EPA

request for dual alkali capital
and
operating
12/14/81
costs.
Letter sent to ExxonResearch andEngineering

Company requesting
test
for
Exxon
Southwestern
12/14/81
12/15/81
test
scrubber
Refining
data on guarantee
on FCCU at
Company's refinery.
Letter sent to Texas Air Control Board
requesting
results of FCCUscrubber
compliance test conducted at Southwestern
Refining Company's refinery.
ReceivedMobil FCCU
NO,emissions test
data.
12/16/81
Response to API's alternative
obtain
existing
plan to
FCCUNO emissions
data prior to initiatin~ additional

testing
A-7
sent
out.
test
CHRONOLOGY
(Continued)
Dates
Activities
12/17/81
Received ARCOcomments on 10/23/81 draft

preamble,
12/18/81
regulation,
Received
Texaco
10/23~81 draft
and BID.
U.S.A.
comments
preamble,
on
regulation,
and
BID:
12/22/81
Received Phillips
Petroleum Company
12/22/81
-4
preamble,
comments on 10/23/81 draft

regulation,
and B~D.
i.:i
Letter sent to Catalyst Recovery, Inc.,

requesting
existing
effects
sulfur
of
test
data on the
oxides
reduction
catalysts on 50x and NOxemissions.

12/29/81
Received Gulf Oil Companyresponse to

EPA information
emission
1/05/82
request
for FCCUNO
data,
Received Texaco U.S.A. response to EPA

information
request
for
FCCU NO emission
data.
1/13/82
Received Chevron U.S.A. summary of FCCU
NOxemission data.
1/13/82
Received Phillips
regenerator
1/15/82
PetroleumCompany FCCU
emission
data.
Received Standard Oil Companyresponse

to EPA information
emission
1/22/82
test
request
for
FCCU NO
data,
Received from Texas Air Control Board

the results
of a compliance
test conducted
on the Southwestern
Refining
Company
FCCU scrubber.
1/27/82
Letter sent to Davy McKeeCorporation

requesting
review
and comments on cost
and environmental
with
1~29/82
impact analysis
the Wellman-Lord
associated
FGD process.
Letter to FMCCorporation requesting

review
and
impact
analysis
alkali
scrubbing
A-8
comments
on cost
associated
system.
and
with
environmental
dual
i~
CHRONOLOGY
(Continued)
Dates
Activities
2/04/82
Letter sent to Morrison-Knudsenrequesting
review and comments on cost and environmental

impact analysis
associated
with citrate
FGD process.
2/04/82
Letter
sent to U.S. Bureau of ~ines
requesting
review and comments on cost
and environmental
impact analysis associated
with
2/04/82
citrate
Letter sent to Wheelabrator-Frye, Inc.,

requesting
2/11/82
FGD process.
review
and comments
on cost
and environmental
impact analysis
with
FGD.
spray
drying
.associated
Received Mobil Oil Companycomments on

draft preamble, regulation, and BID for
FCCU
regenerator 50x emissions.
2/11/82
2/12/82
2/17/82
ReceivedARCO
resubmissionof NO,emissions
data
from
ARCO FCC units.
Received Wheelabrator-frye information

on spray drying
cost parameters
capital and operating

for FCCUapplications.
~Received APT-solicited refinery NO

emissions
2/19/82
three
test
data.
Received additional API-solicited refinery
NO,emissions test data.

2/22/82
Received from ExxonResearch and Engineering

Company results
of guarantee
tests
conducted
on 5/6/81 at the FCCU scrubber
at Southwestern
Refining
Company.
2/24/82
Received DavyMcKeeresponse to information

request concerning cost of Wellnan-Lord
502 recovery process.

2/24/82
Received Mikropul Corporation response

to telecon
costs
A-9
for
request
FCC units.
for spray drying
CHRONOLOGY(Concluded)
Dates
2/25/82
Activities
Letter sent to SouthwesternRefining
Company requesting
cost and operational
information regarding the wet gas scrubber

system.
3/24/82
Letter sent to the AmericanPetroleum

Institute
stating that SO, reduction
significant
cata.lysts
do not cause
increases
in NO, emissions and that
additional NO, test data are not necessary.

3/30/82
Received Chevron commentson the

draft
4/30/82
preamble,
regulation,
10/23/81
and BID.
ReceivedSouthwesternRefiningCompany
response to cost and operational information

request
regarding
the wet gas scrubber
system.
3/24/83
Graft regulatory package sent to the

Office of Managementand Budget for
review,
as
required
under
Executive
Order 12291 and the Paperwork Reduction

Act
11/29/83
1980.
Sent to OMB
revisions to the regulatory
package based on commentsmade by OMB
in
12/15/83
of
November.
Regulatorypackageconcurredon by OMB.
A-10
APPENDIX
B-1
APPENDIX
INDEXrO ENVIRONMENTAL
CONSIDERATIONS
This appendixconsists of a reference systemwhichis cross-indexed
withthe October
21, 1974,FederalRegister(39FA37419)containing
the Agency
guidelinesfor the preparationof Environmental
Impact
Statements. This index can be used to identify sections of the document
whichcontain data and informationgermaneto any portion of the
Federal Register guidelines.
812
'~
APPENDIX
INDEX TO ENVIRONMENTALIMPACT CONSIDERATIONS
Agency Guidelines
Action
for Preparing
Environmental
Regulatory
Iinpact Statements
(39 FR37419~
(1) Backgroundand suolnaryof regulatory

alternatives
Statutory basis for proposing standards
LocationWithinthe Backgrounn
InformationDocument.
The regulatory al'ternatives are surmrarired in
Chapter I, Section
Affected industry
is sununarized in Chapter 2, Section 2.1,
A discussion of the industry affected by the

alternatives
is presented
Section 3.1, pages 3-1 through 3-4.

the "business/economic"
Affected
sources
of the
industry
in Chapter 9, pages 9-1 through 9-26.
A de~cription
of the activities
Section
level
nature
in Chapter 3,
Details of
are presented
regulatory alternatives
Existing regulations at State or local
pages 2-1
2-4.
regulatory
page I-I.
The statutory basis for the proposed standards

through
a,
1.I,
3.2,
pages
to be affected
by the
is presented in Chapter 3,
3-4 through
3-14.
A discussion of existing regulations is included

in Chapter 3, Section
3.3,
pages 3-19 through
3-22.
Availability
of control technology
A discussion of available emission control

techniques
through
(2)
Environmental, energy, and economic impacts

of regulatory alternatives
is presented
in Chapter 4, pages 4-11
4-34.
Various regulatory alternatives are discussed in

Chapter 6, Section 6.2, pages 6-3 through 6-10.
Agency Guidelines
for Preparing
Regulatory
Action Environmental
Impact Stateinents
(39 FR 37419)
Envirownental
n
on
Location Within the Rackground Infonnati~n~
impacts
The environmental
alternatives
impacts o~ the various
are presented
in Chapter
unlen
regulatory
7, Sections
7.3, and 7.4, pages 7-1 through 7-ii.

Energy impacts
The energy impacts of the various

alternatives
Section 7-5,
Cost impacts
Cost impacts of the various

are discussed
through
Economic impacts
regulatory
are discussed
in Chapter
pages 7-11 through 7-13.
in Chapter
7,
regulatory.
8, Section
alternatives
8.1,
pages
8-1
8-17.
The economic impacts of the various regulatory

alternatives
are presented
in Chapter
9.2 and 9.3, pages 9-26 through 9-50.
9, Sections
7.2,
APPENDIX
EMISSIONS TEST DATA
C-l
APPE;UDIX
C.1
INTRODUCTION
Emissions source test data from fluid, catalytic cracking (FCC)

units are used in this document to support the development of baseline
emissions, model FCC units, and performance of pollution control
equi pment. These data and descriptions
of the FCC units and control
:?
technologies-tested are summarized in this appendix. Emission test

data were obtained from industry, from State and local pollution
control agencies, and from an emission source test conducted-by the
"a
:J:
U.S. EnvironmentalProtection Agency. The samplingand analysis
:9
methods used in these source tests are EPAMethod 5 for particulate

matter, EPAMethod 7 for nitrogen oxides, and either EPA'lethod 6 for
sulfur~dioxide or EPA~~ethod8 for su~fur dioxide, sulfur trioxide,
and
sulfuric
acid
mist.
A summary of the flue gas scrubber

in this appendix is eound in Table C-l.
catalyst
test data presented in detail

Sulfur oxides reduction
performance data are summarized in Table C12. These tables,
figures, and the summaries of individual

flue gas scrubber and sulfur
oxides reduction catalyst
test reports are located at the end of this
appendix.
From Table CI1, flue gas scrubbers have demonstrated sulfur
dioxide
control
efficiencies
as high as 97 percent.
From Table C-2,
sulfur dioxide emissions reductions up to 83 percent have been demonstrated.

C.2
FLUE GAS SCRUBBER EMISSIONS TEST DATA
Available
FCC unit
flue gas scrubber
emissions
test
data consist
of 12 source test reports for 4 refineries operating FCCunits.

Eleven of these tests were conducted to determine compliance or vendorguaranteed
performanceg one test
was conducted by the U.S. Environmental
protection Agency for this study.

with sodium-based
oxides
emissions
flue gas scrubbers

control.
0-2
All four FCCunits are equipped

for particulate
matter
and sulfur
C.?.1
Guarantee and Compliance Test Results

Guarantee
meets
tests
the vendor's
determine
if
are
performed
guidelines.
the
to verify
Compliance
controlled
FCC unit
that
the
tests
emissions
are
are
flue
gas
scrubber
performed
within
to
allowable
limitations.
A description
below.
are
of each
FCC unit
also
flue
provided,
FCC unit
and flue
gas scrubber
gas scrubber
compliance
is provided
and guarantee
test
data
by refinery.
C.Z.1.1Refinery
A.1'RefineryAoperatesa singleF5Cunit with
a design
fresh
regeneration
feed capacity
is utilized
the regenerator.
of 11,500 m'/sd.
for
complete
The FCC unit
carbon
processes
Yigh temperature
nonoxide
atmospheric
distillation
The f~ue gases

recovery
these
i:
devices
heat
turi' scrubber.
single
scrubbing
the
liquor
reaction
sulfur
from the
vessel.
within
of the
flue
the
devices,
regenerator
gases
the
the
sulfur
gases.
pass
toapproximately
flue
gases
enter
through.two
150jC.
the high
heat
From
energy
ven-
of four venturis mounted upon a
The flue gases mix with a sodium alkali-based
oxides and catalyst
from the
'CC unit
The scrubber consists
separator
heavy gas oil cut from
tower.
which coal
recovery
in
a 0.2 to 0.3 weight percent
su~fur feedstock obtained from a hydrotreatsd

the
combustion
venturis.
oxides
with
finer
The flue
As a result
the
of this
scrubbing
las particulate
gases
liquor,
matter)
and scrubbing
mixing
and
both
are removed
liquor
pass
into
the separator vessel. Here, entrained scrubbing liquor is separated

from the
flue
atmosphere.
the
small
The scrubbed
Additional
separator
purge
treatment
gases.
vessel
stream
alkali
is
and the liquor

removes
flue
gases
are
then
added to the'scrubbing
is recycled
sodium salts
to the
and particulates
vented
to
liquor
from
uenturis.
to a'wastewater
plant.
High energy venturi scrubber design flue gas inlet pressures vary
from 108 to !12 kPa, Typical design liquid-to-gas
(L/G) ratios for
the highenergyventurisErubber
are 0.7 to 4.0 m3of scrubbing
liquor
3 of flue gas.Z ThepHof the scrubbingTiquaris naintained
at 5 ~a 7 througha 0.004to 0.006m3/min
additionof alLali.
per
1,000 m
C-3
Aguarantee
test3andcwnpliance
test,4performed
in April1980
and September1980, respectively, are-summarizedin Tables C-3 and
C-4, respectively. FromTable C-3, uncontrolled emissions at the
scrubber inlet are, on average, 8.1 kg sulfur dioxide/1,000 coke
burn-off, 1.9 kg sulfur trioxide/!,000 kg cokeburn-off, and0.2 kg

sulfuric acid mist/1,000 kg coke burn-off. Uncontrolledparticulate
ennissionsat the scrubber inlet are 4.4 kg/1,000 kg coke burn-off.
Controlledjulfur dioxideemissionsrangefrom0.2 to 0.3 kg/1,000kg

coke burn-off, controlled sulfur trioxide emissions vary from0.02 to
0.03kg/1,000kg cokeburn-off,andsulfuric acid mist emissionsrange

from0.07 to 0.1 kg/1,000 kg coke burn-off. Controlled particulate
emissions fromTables '-3 and 0-4 range from 0.1 to 0.4 kg/1,000 kg
coke burn-off. These results showemission reductions of 97.5 percent
I~
in rulfur dioxide. 99 percent for sulfur trioxide, 55 percent for

sulfuric acid'mist, and 95 percent for particulate matter emissions.
C.2.1.2Refinery
82 Refinery
5 operates
twoFCC
unitswitha
combined
fresh feed capacityof approximately
25,400m3/sd.5Theflue
gases from the two FCCunits are combinedin a commonductand routed
through a carbon nonoxidecombustionfurnace. Followingthe carbon

monoxidecombustion furnace, the gases enter the jet ejeitor venturi
scrubber. The scrubber contains five jet ejector venturis; only four
are normally used during operation. The jet ejector consists of a
spray nozz7e and venturi, The scrubbing liquor, sprayed into the
venturithrough
the nozzleat 513to 925kpa,6induces
a draft, drawing
regenerator flue gas into the venturi,
operates with negligible
pressure drop.
Thus, the jet ejector venturi

These venturis
utilize
sodiun-basedscrubbing liquor to removeboth particulate matter and

sulfur oxides from the flue gases.
The flue gases flow from the
venturis into a separator vessel for demisting then to atmosphere.

Additional alkali is addedto the scrubbing Tiquor fromthe separator
vessel and the liquor is recycled back to the scrubbers.
purge stream removes particulates
and sodlum salts
A small
to a wastewater
treatment plant. Three circulating pumpsare available to provide

scrubbing liquor to the scrubbers. Onlyone pumpis normallyrun.
0-4
The design L/G ratio
for jet ejector venturis is typically
6.7 to
13.4n3of scrubbing
liquorper 1.000m3~of
flue9a5.6
Five
FCC unit
scrubber
emissions
source
tests
between December 1977 and June 1980 to determine

sion limitations.
The results
of these tests
7~11
were conducted
compliance
with emis-
are summarized in
Tables C-5 through C-9. From these tables, controlled particulate

emissions range from 1.1 to 2.4 kg/1,000 kg coke hum-off; controlled
su? fur dioxide
emissions
0.2.1.3
range from 0.2 to 3.7 kg/l,OCO kg coke burn-off.
Refinery C. Refinery C operates two FCCunits with a
combined fresh feed capacity of approximately 27,000 m3/sd.5These

units utilize
conventional regeneration
and are equipped with carbon
monoxide combustion
furnaces.
The refinery
has two jet
ejector
ven-
turi scrubbersystems,onefor eachFCC

unit.l2 Theoperationof each
of these
scrubber
systems is similar
to that
described
for Refinery
9.
above.
Compliance
13,14perfon~edin September
1975far Unit I and
tests,
April 1976 for Unit II, are summarized in Tables C-10 and C-ll,
respectively.
For Unit I, controlled particulate emissions are about
0.8 kg/1,000 kg coke burn-off.
The typical sulfur dioxide conten_t of
the nue gas at the scrubber inlet for this unit is 1,010 vppn."
No
coke burn-off
dioxide
rate was reported.
emissions
su7fur-trioxide
From Table C-10, controlled
are about 3.1 kg/1,000

emissions
are
kg coke burn-off..
0.08 kg/1,000
re.ported sulfur dioxide control: efficiency
sulfur
Controlled
kg coke burn-off.
The
for the Unit I scrubber is
94 percent.l2 Thetypical sulfur dioxidecontentof the flue gas it

the scrubber
inlet
rate was reported.
for Unit II is 660 vppn.
Again, no coke burn-off
From Table C-ll, controlled
sulfur dioxide emissions
are.0.3 kg/1,000 kg coke burn-off, and controlled

sulfur trioxide
emissions are 0.08 kg/1,000 kg coke burn-off.
The reported sulfur
dioxide control efficiency
for the Unit II scrubber is 94 percent.
Controlled particulate
emissions for Unit II are 1.2 kg/1,000 kg coke
burnloff.
0.2.1.4
fresh
Refinery D. Refinery O operates one FCCunit with a
feed capacity
of 4,450 m3/sd.l5 The unit
utilizes
high
temperature
regeneration and is equipped~with a high energy venturi scrubber

system.
C-5
Acompliance
t,,t116 performed
in Ma~y
1981,is summarized
in
TableC-r2anda guarantee
test,l7 performed
in flay1981,is summarized
in Table 0-13. For this refinery's FCCunit, controlled particulate
emissions are 0.3 to 0.5 kg/Z,000 kg coke burn-off.
Ti~esulfur dioxide
content of the flue gas from the scrubber is 2.3 to 2.8 ~9/1.000 kg
cokeburn-off, and controlled sulfur trioxide emissionsare 0.5 kg/1,000kg

coke burnloff.
Nitrogen oxides emissions were also tested.
The
nitrogen oxides content of the flue gas at the scrubber outlet is
168 vppm, or 3.8 kg/1,000
0,2.2,
EPA-Conducted
coke burn-off.
Source
Test
Results
The U.S. EnvironmentalProtection Agencyconducted two test

programsto evaluate the performance of flue gas scrubbers. Onetest
was conductedon a flue gas scrubber controlling sulfur dioxide enissions
;'j
from an FCCunit.
:ii
controlling
The second test was conducted on a similar scrubber
sulfur dioxide Missions
from an industrial
boiler.
The
industrial boiler test results are included to illustrate the performance

of flue gas~scrubberssimilar to those used on FCCunits on high inlet
sul fur
dioxide
concentrations.
0.2.2.1 Refinery A. A description of the FCCunit operated at

Refinery A is provided in~5ection 0.2.1.1, Tests conducted by EPA
include 14-day continuous monitoring ofsulfur
dioxide emissions Into
and out fromthe Rue gas scrubber and individual tests of sulfur
dioxide, sulfur trioxide, sulfates, nitrogen oxides, hXdrocar~ons,and
parti culate~ emissi ons, Coke burn-off rates were not available for all
test
parameters
measured ~ Therefore,
reported in terms of coke burn-off.
not all
of the test
.~
data are
Results of the test programat
this refinery are summaritedin Table C-14. Continuousmonitoring
data are illustrated graphicallyin FigureC,1.19 Uncontrolledsulfur

dioxide emissions ranged from 12.6 to 24.4 kg/1,000 kg coke burn-off,
uncontrolled sulfur trioxide emissions ranged from2.6 to 8.8 vppm,
andsulfatesemissions
ranged
from7.5to 23.2vpp. Oncontrolled
particulate emissions ranaed from 2.9 to 6.4 kg/1,000 kg coke burn-off.
Controlledsulfur dioxideemissionsrangefrom0.4 to 4.0 1(9/1,000

kg
coke burn-off. Sulfur trioxide emissions range from 0.3 to 1.4 and
sulfates from 2.5 to 10.8 vppn. Controlled particulate emissions
0-6
1~
range from 0.2 to 0.9 kg/1,0O0 kg coke burn-off.
Nitrogen oxides
emissions at the scrubber outlet averaged 93 vppm(dry) and total C1,6

hydrocarbons averaged 22.7 vppr~. Scrubber control
83 percent for particulates,
93 percent for sulfur
for
sulfur
trioxide,
C.2.2.2
and 56 percent
Industrial
Boiler
A.L"
and Wilcox F~lverized coal-fired

sub-bituminous,
between
tion
3.25
particulate
Boiler
A is a Babcock
The coal fired in the unit is
of 10 percent
The boiler
and a sulfur
and an electrostatic
boiler
is shown graphically
flue
in Figure
genera-
passes
precipitator
for
the flue gas scrubber.
of EPA-conducted 30-day continuous

in the
content
has a maximum steam
Flue gas from the boiler
collectors
concentrations
scrubber
Industrial
matter removal prior to entering
Results
dioxide
percent.
of 150,000 Ib/hr.
through mechanical
sulfates.
unit.
with an ash content

and 3.73
capacity
for
efficiencies
averaged
dioxide, 83 percent
monitoring
gas entering
C-2.
Sulfur
of sulfur
and exiting
dioxide
the
concentrations
in the flue gas entering the scrubber ranges from 1,623 to 2,154 vppm
dry. Flue gas sulfur dioxide concentrations out from the scrubber
rang~ from 21 to 66 vppn dry. The average control efficiency of the
scrubber
C.3
over the 30-day test
is 97.1 percent.
SULFUR OXIDES REDUCTION CATALYST TEST DATA
Available
consist
tests
period
sulfur
of a source
were conducted
oxides
test
report
oxides
dioxide
trioxide.
C.3.1
Sulfur
sulfur
for
catalyst
each
by the catalyst
formance of sulfur
and
reduction
reduction
Oxides.Reduction
emission
test
of two refineries.
developer
catal~ysts
Catal~ltTest
data
These
to evaluate
the per-
on emissions
of sulfur
Results
C.j.l.l RefineryE.Z1RefineryEoperatesa qingleFCC

unit
with a fresh
feed capacity
of approximately
3,500 m'/sd.
The FCC unit
is operated in a complete carbon nonoxide combustion mode. The FCC

feedstock
is a 1 weight
percent
sulfur
vacuum gas oil
Sumatra and Alaska North Slope crudes.

catalyst
back
works by transferring
to the
reactor.
to hydrogen sulfide.
unit
products
Within
sulfur
the
The sulfur
oxides,
reactor,
The hydrogen sulfide
and is ultimately
processed
plant.
C-7
the
derived
oxides
from
reduction
formed in the regenerator,

sulfur
oxides
are
reduced
is removed with the FCC

in the refinery
sulfur
For this test proyram, the sulfur oxides reduction catalyst Has
gradually added to represent approximately lO percent of the total FCC
unit catalyst inventory, The sulfur oxides reduction catalyst was

maintained at 10 percent of the inventory during steady state by addition to replace reduction catalyst lost due to normal attrition.
At
the completion of the test, the addition of sulfur oxides reduction
catalyst to the FCCunit catalyst inventory was stopped. Su1fur

oxides emissions gradually increased as the amount of sulfur oxides
reducion catalyst in the FCCunit catalyst invent.ary decreased due to
normal attrition.
Testing was conducted prior to the addition of the
reduction catalyst, during steady state whenthe reduction catalyst

represented 10 percent of the FCCunit catalyst inventory, and again
several weeks after
reduction catalyst
addition
has ceased,
The sulfur oxides reduction catalyst test for Refiriery E is

summarizedin Table C-15. Sulfur oxides emissions dropped from 12.2 to
2.5 kg/1,000 kg coke burn-off after addition of the sulfur oxides
reduction catalyst to the circulatory catalyst inventory. Nitric

oxide emissionsincreased from 110 to 700 vppn after addition of the
catalyst.
C.3.1.2Refinery
F.21LikeRefinery
E,Refinery
Foperates
a
single FCOunit with a fresh feed capacity of approximately3,500m3/sd.
~ne FCCunit operates in the completecarbon rnonoxidecombustionmode,
and the feedstock is a 1 weight percent sulfur vacuumgas. oil derived
from
two
Texas
crudes.
Sulfur oxides reduction catal-ysts were added as describedabove

for Refinery E. The test results for Refinery F are summarizedin
Table C-16. Sulfur oxides emissions decreased from 9.9 to between
3.4 to 5.0 kg~1,000kg coke burn-offafter catalyst addition. Nitrogen

oxidesemissionsincreased fromabout 710to 1,100to 1,300vppn.
C-8
Table
C-l.
SUMMARYOF SULFUR OXIDES EMISSIONS
TEST DATA FOR FLUE GAS SCRUBBERS
Feed
Sulfur
Content
(wt.X of
fresh
Application
Refinery A
feed)
0.210.3
0.32-0.60
Sulfur
Loadings
(kg50xas 502/1.000
kg eokeburn-off)
Scrubber
Scrubber
Inlet.
Outlet
% Reduction
9.8
0.3
97
13.7
Refinery
B N/Aa
i/
Oxides
1.0
93
N/A
N/Rb
N/A
N/A
N/A
N/A
N/A
1.5*
3.7*
N/A
N/A
N/A
N/A
3.7f
N/A
N/A
N/A
0.2*
N/A
N/A
N/A
N/A
N/A
3.2
0.7
N/A
N/A
Refi nery D
N/A
N/A
0.1
0.3"
95
d
N/A
N/Ae
97.1
Refinery
0.26
5.1*
Indus~rial
Boiler A N/AC
N/A
aNot available.
b~,portedas 55.2 vppmwet only.

CCaal fired bailer.
Coal sulfur content ranges from 3.25 - 3.73
weight percent.
dAeportedas 1,800vppmdry only.

eReported as 46 vppmdry only.
+Ca~cu~ated
from test results.
Emissionsrepresent S02only.
c-8.
Ta~~e C-2.
SUMMARY
OF SULFUROXIDESEM~~SIONS
TEST
DATAFOR SULFUROXIDES REDUCTIONCATALYSTS'

Feed
Sulfur
Content
(wt.% of
Refinery
Sulfur Dioxide Loadings
(kg SOxd5 SO2/1,000

kg coke burn-off)
fresh
Before
feed)
catalyst
0.99 - 1.07
1.00 - 1.37
addition
. 12.2
9.9
Wi th
catalyst
in place
% Reduction
2.5
80
3.4
66
~3
-B
i;i;
C-10
28.0
26.0
24.
=
2"
~
22.
Scrubber
t\Inlet
20.
Q
18.16.
2JYL3~~
12.
8.
6.
Scrubber
Outlet
4.
2.
10 ' 11
Time
(days)
Figure C-3. Results of Flue Gas Scrubber ContinuousMonitoring
at RefineryA1R
12
10,000
9,000
8,000
7,000
6,000
5,000
4,000
3,000
m
z:
2,000
"?
1,000
wJ
~-
r.
Scrubber
InTet
I~
90 ~L
o a
soS
70 -C
~C
601.
50
40
30
20 _L~
~crubter Outlet
10
ro
15
20
2~
3d
3~
T~ME (days)
FIgure C-Z. Results of Flue Gar Scrubber Continuous

~cnitaring
for Industrial
Gailer'A19
-_j
C,a2
TABLE
C-3. FLUEGASSCRUBBER
EMISSIDnS
TESTDATAa
PLANT A, GUARANTEE TEST
Seruder
49 *Obr
[nl.r
Sc~usDr lutle
Olu
114199
1/15/8
0936
~lll/gD
(/1518
12(5
1600
FCC Fmn led

01449 r~~a. n11~0
Gmrn~
5
111518_
0960
Ir4q
1/1881(115/60
1295
1555
Il.iOO
(1.500
ou
rCC Fmn
Ced
lul(ur Cor~nt. n.
cod 81449
I~L(rmC
44,
0.1-0.3
~. 1-0.3
tO/lr
L1.591.0
L6.591.1
ecle.:
IOZ.O
SCrul#
O~1~F nu
nu
no
Wh
4444
ILd
14
IIIL
144444.
Ed4la
sna
144. r~/~n
bl
044
101.0
1i.3
lor.~
see no
91.6
pe.l
1151.0
d'lsln
1.560
f.bYI
3.91
].~r0
s.s
1.601.0
1.(50
3.630
1.120
3.610
Oeo`
1919014. a/+
19/1.000 18 ed)
PlrC(CYL
10C
E11111D4'
~LI
'C
~bn
Fslntos
~lu~s~
eedd6
leo rt
Id.
le/l.IO 19 spebrc~~
Col~cClaMar~,L
a.
11111
hBLS
0.2
a.r
0.2
0.02
3.1
a.ol
Z.L
L.B
raehdd
s.r
'88
9.0
6.L
:soJ
R1o66
0.0
U.~
6.0
12.6
0.2
n.5
1.9
6.6
0.3
0.2
O.Z
O.P
0.32
pp~t
hbll
h~l
l.lr
3.91
I.n
1.(
L,
3.9
o.t
95
~a~1~9~P~o~i
6.30
a.oz
o.ol
2.1
5.90
P.~
346
o.I
805
ne~DB
sLJ-
93
L(.B'
I~I
3.9
91
98
l.s
56
r~~M 5 I~~~D~d6
0.4
0.61
P.I
0.II
o.oI
o.ot
p.Js
9)
n~4aB
1.4
~.s
I.n
o.5*
?C
99
nsr~cl
1.(7
1.55
Id.
::I~Pm
~~lolpr~tr
Collat(ol
lllle(oO.
rl
81
htlal(
11
:::~
rrcmnl(ol.IOLCI.O~-rm
111 111
E(ll(~
~l(llp~
(II SO?)
1911.88
19 COb~r~l~l
19,4
hChod~
h~M~
161
226
10.(
119
II
It.l
IIU.
CeI1CC(O. llllC(al.
O.L
L.O
16
nedds
re
II.I
6.5
bth~n
Caatrl(on.
1Pl lro
81
208
136.4
18440
ddi8
149441114.
14141141
~WotL
r~k
lnlltao
II
91
TILrCI~
sulru~e
16.2
Is
6410144.3
044484844
ILm
D.P
Is
132
9.~
Y/~
Tarhaa
rr(~dr
16.2
96
281
E~~o~e
lull~~m 1r 494 brrrlt
bmlo
11.9
56
2.5
5.P
did,
Collems
In
to~a~Lo~ rR1~
~Llbr
21.3
116
O.U
'AI
UIU
~ll~gLl~m~~
1.C
In
5.4
10/4
larnaP+
OlsU~
28.1
120
0.OI
P.L
1.3
1.6
65
50
Rl~o~l
MlodB
).I
8.1
La~
9.0
14
11I
In
C-13
11.9
1D.1
0.3
ii
5.1
4
4191949 3.
o.R
55
5.0
41
6.2
93
c.o
91
:I
TABLE6-4.
FLUEGASSCRUBBER
EM~SSIONS
TEST DATAa
PLANT A COMPLIANCE TEST
-il
Scrubber
Run:lunber
3afe
9/3/80
3/3/80
slJjso
rime
!,'40
1554
1105
FCt
Fresh
Daea
Average
Feed
Charge Rate, m'lsd

General
Outlet
FCC Fresh
N/A
N/~
N/A
Feed Sulfvr
i7ntenf, wt. :
N/A
robe 3urn-oif Rare,
18,100
N/~
!7,200
i7,200
~/A
:7.530
~g/hr
Isol(ineric Rafio,:
Scr~bber
inlet
101.37
102.62
;la*
Sate, Nm'/min
4,390
41030
J,D50
4,150
Flew Rate, Nm':min 3,530
3,530
3,530
3,570
Regeneratar
Stack
Inter
Gas tempera-
ture, OC
Gas
98.34
63.9
63.5
63.7
is.s
19.9
ZO.j
18.47
18.36
18. 17
18.3
~olccular Ycigh~ af S~ack

Gas, tg/kg-mole, dry
30.07
30. 4;
30.4
!0. 15
P.?
d.t
j.4
5.1
14.4
lj.q
:4.0
0.3
7.3
0.0)
0.3
6.0
0.02
n~j
i.O
3.03
C.4
6.9
0.33
average StaEk
Gas 'lelocity,
53.8
n/s
Oata
noisture toneent,
: vol.
02 Concentra~lon.:
'"2 ConeentratiPn, =
COCancen~ration,:
Emission
Rare,
kg/1,000
P,rttculate
imissionl
kg coke
~urn-o~f
kg/hr
9/#ml
Scrubber
Collection
Efficfency, :
N/A
Test ~ethad
dJara Pm Reference 4.
Mefhod5
C-14
N/a
~ee.CIPa5
N/A
~lethod i
uln
TABLE
C-5. FLUEGASStRUBBER
EMISSIONS
TESTOATRa
PLANT B,
TEST
Scrubber
Run Nlalber
Gate
12/10/77
12/13/77
12/19/77
Time
N/X
Ftt
Fresh
Fed
Charge
Feed
ve,
Sulfur
:
Rate ~n~lsd
Generat
FCC Fresh
Content,
Oata
Outlet
Coke Burn-of9 Rate,
YIA
veraqe
N/P,
N/~
N/A
~IA
Nln
N/A
N/A
HIR
NIR
N/A
NIA
tg/hr
IsoLinetic
Ratis.:
Stac~e Gas Te~peratore.
ii/A
lilA
56
63
63
12.9
12'.7
54
'C
Average S~acL Gas

~clac~~ty.
13.1
n/s
Gas
.Oata
Flue Gas Flow Rite,
0,440
4,530
10.300
9.:60
b~lmin
Ilolsiure Content.:
:Iolecular
ut.
at
30.7
30.6
23.5
30.7
30.7
Rate,
kg11,000 k9 cole
bum-off
Particulate
23.4
Stacf~
Gas, kgjkg~ole
Emission
22.1
k9/hr
g/Ha'
nln
N/A
uln
Nln
45.1
0.08
59.0
0.10
54.0
0.09
52.7
0.09
Emissions
Collection
Test
Efficiency,
~lernod
Emission
Rate,
tg11.000
k9 cote
burn-off
Sultur
Lg/hr
Concentration,
vppn
N/A
nlA
:cetkod'5
;(etkod
NIA
HIX
5
N/A
riethod
NIA
5
aln
101.6 .
95.7
122.0
54.4
50.9
60.3
nlR
u/A
~ln
--
uln
106.4
55.26
wet
Collection
rest
~a~a
from Reference
Nethad
Efficiency,
~!cthod
I$thod
~lcthod
HIP,
6
7.
IThea*crage51)msstdn c~ncentrarlon
raport~aan a dry birlr ~s ~2.:vppnd.TheO.
content of eke2flue gas v45 not r~parted. as such the 502 emission rate could not bC
reported on a dry, 02-Creebasis.
C-15
TABLEC-6,
FLUEGASSCRUBBER
EMISSIONSTEST DATAa
PLANT B, TEST 2
~T1
Scrubber
~un:lunber
Date
5/10/78
j111/78
j111/78
rime
0230
1045
0000
U/~
il/J
n/4
Fcln
1I/A
FCC Frerh
~veraPe
Feed Ch~rge
Rare, :,l/sd
;~neral
Oars
Outlet
FtC Fresh
Feed
Sulfur
Content, ut. :
;iln
1
CokeSum-off Rate,
36,000b
Lg/hr
isokinetic
qg
97
90.9
?7.3
Stack Gal re?Pera-
65. 6
65.5
65.6
55.6
~veragP Staci Gas
s,8
It.l
L1.6
33.5
~ure
Ratio, I
"C
'leioci
ty i RIS
nue
Gas E~owRite,
~bn~~min
7,~70
8.970
a, 300
s,lsa
Gas
Data
'lolsture Content,:
i5
24.9
t5
Stack Bas kg/lgmole
29.9
30.6
30.5
30.3
C02 COncentratian,:dy
9.6
15.9
15
13.5
tO Concentration, I dry
0.4
nalccular
He~ght of
o,Conc~n~r~rl~n.:
dy J.B
N2Concentra~~on,:dy
Emission
fs
0.5
1~1
0.3
4.9-
81.5
81.2
81.1
91.3
96.2
82.5
76.7
85.1
n/r,
V/A
Rare,
Lgll.ODO
t, r*e
burn-off
kg/hr
Partlculate
Emissions
25
g/Nm~
0,22 .
Collection Efficiency,
:esr'lethod
0.15
~IA
:lethod 5
I~etkod 5
0.1!
2.4
0.17
i~:ll
~~eehod5
Emission
Rate,
~9/1.000
1(9 coke
burn-off
Lg/hr
Sulfur
illaxide
Enis5ions
Concentration,
vppm
vet
Collection Eff!c!encly,
rest ne~bod
Data
f+a
Reference
I.jb
~.2
90.7
64.0
52.3
1.55
43.3
35.7
25.9'
N/A
NIP
N/A
n/A
i~e~hod6
r(ethad 6
:I~tho~ 6
3.
; ~
bColte
burn-offrate calculatedRan
nitrogen
scrubber outlet test data. Cal;ula~ian assumes no

air con~ains
73.8
t0.9 percent oxygen, and
and the nue gas flow
ratepercent
at Cnenitrogen,
sclub~er,utlet
~qualr rke regeneraror
In coke, anbiene
1.2 percent rater,
Flue gas f113Wrate
:I
on a dry basis.
CThe.v.rape
102
slir?il~n
c.ncntr.ri~n
rcp~rtl
onad~,Jt-fre.~rir i, ~L.S
uopm.
C-16.
TABLE
C-7. FLUE
GA3
SCRUBBER
EMISSIONS
TEST
DATA"
PLANT B, TEST 3
Scrubber
Run Number
Bate
12/28/78
12/28/78
12/29/78
Time
OZ10
0412
3926
FCt
General
Outlet
Fresh
Feed
~verage
Charge
Rate, nl/sd
;Iln
N/A
:IIP
:I/A
rtln
Nln
H/A
I~IP
Data
FCC Fresh
Feed
Sulfur
Content, ut. ~
Ccte
Surn-a~f
Rite.
kg/hr
Isotlnetle
Stact
15.4(1Cb
Ratla,:
Gas Tenpera-
rure,
103
103
11)9
105
64
73
~Z
71
13.2
15.0
14.0
L4.1
Ot
~verage Stack Gas

Velocity,
n/s
Flue Gas Flow Rate,
4.060
9.390
8.640
9.030
Fh~/~n
Gas
Dare
;blsturr
Content, Z
29.5
34 ~
34
30.2
.Sta~~ Gas, Irg/kg~noie
30. 7
30,5
30.5
30.6
t02 Concentration,
:dry
16
15.1'
15.4
!5.5
:~olcular
ilelgnl
CO Concentration,
oe
Z dry
02Conentratron.
~dn
2.i
1.4
2.1
HpConcenfratlon,
t dry
81.5
82.9
82.7
82.4
72.4
0.13
79.4
0.14
57.2
O.11
Enisslon
Z.O
Rate.
L~~L:9 co~e
Part~culate
k9/hr
g/Nma
1.5b
69.6
Enissions
Test
~~etkod
Enisslon
~/A
Iletkod
N/A
5
Ae~kod
NIA
5
:lelkod
n/A
5
Rate,
L~/b~~OZ:9
cab
kg/hr
Sulfur
Dfoxide
Emissions
116.6
Concentratian,vppm
56.7
194.6
188.2
85.7
89.9
166.i
77.4t
ret
Collection
Test ~(ethad
dData frcm Reference
EFflcicncy.
H/A
,~ethod 6
N/A
~ln
rlethod 6
I~e~had 6
~/A
9.
bCote burnaff rate calculated cron sc~ubber outlet test data. Calculation assumesno
i
nitrogen fn coke, arn~ient air contains 78.8 percent nitrogen, 20.0 per~ent o~ygen, and
1.2 pe~cnt rater, and the flue gas ~low rate at the scrubber autlec equals the regenerator
flue gas flow rate an a dry basis.
CTke
average502emission
concentration
reportedan a dry, Op-Free
basis i9 128vppmi.
C-17--
"Tr
TABLEt-8.
FLUEGASSCRUBBER
EE1ISSIONS
TESTDAIAa
PLANT B, TEST 4
-r:
fcrubber
Cn :lumber
Date
5/31/79
5/3;/;9
6/1/79
Time
3949
1556
091?
FtC Fresh
l;aneral
Data
~uclet
;eed
Feed
Content,
vt.
2*era~e
;1i
Cha rge
nate, ~J/sd
FCC Fresh
:Iln
:I/A
N/.1
N/A
Fl/n
N/A
iT~
R/~
Sulfur
Coke 3urn-off Rite,
jj~1000
L;9/hr
:1
Tsotinc~ic Ratio, '.
LOO
103
103
102
Stacl Cas Tempera-
70
72
71
71
Average Stacl: 341
11.6
11.6
11.(
Ll.j
ture,
Ot
~elocicy.
Gas
~/s
Flue Gas ;1~ Rate,
8.210
r(m~lmin
8.210
8.120
8.;80
Os re
rloisture
Content.:
:(olecul~r
26
25.9
25.7
25.9
30.57
30. 57
30.57
30.57
16
16
16
BJ.~
83.7
' 83.7
58.0
0.138
64,9
6.132
75.7
0.156
54.5
0.142
nlA
Nln
H/I\
V/A
Yelght of
Staclr Gas, kg/kgmole
m,concFntrarron.
:dy 16
COConEentratlon.:dry
02Consntratlon.
, dy
N2Conccntrlf~on.:dry
0.3
0~3
::1
93.7
Emission
Rate..
Lg/1.000
coke
burn-of7
P,rticulate
Emissions
Lg/kr
g/r~m~
Collection Effi~~ency,
rest I~ethoa
Emission
Method 5
l.6b
Method 5
I(erhod 5
uo.n
105.23
191.97
162.54
109.5
59.4
1(37.2
92.0
n/n
ri/A
N/A
N/A
Rate
kg/1,00O kg coke
burn-off
tg/kr
SulCur
Ofo.~de
b~ ssi ons
Concentration, vppn
nt
Collection
.b
1. ,
Ef~~clcncy,
e
Test Method
Method6
:(ethod 6
Method S
dDat9TropReference10.
bto~sburn-offrate calculafedfrcm scru0ber
outlet test data.
nitrogen in coke, ambient air contains 78.3 percent nitrogen,

1.2 percent wa~er. and tne
Calculation assumes no
tO.O percent olygen, and
flue 915 flow rare at the scrubber ourlee equals the regenerator
flue gas flou rate on a dry basis.
C~heaverage
502anisslon
concentration
reponed
ona dry,02-freebasisis 125.6
vppnd.
C-18
,.S
TABLE
C-9. FLUEtP~SSCRUBBER
EMISSIONS
TESTOATAa
PLANT B, TEST 5
Scrubber
Xu~ :;unber
6/4/90
6/4/30
Time
1638
1136
1432
aln
:Iln
II/A
s/4
;I/A
W/A
Fresh
Feed
Charge
'CC Fresh
Feed
Sulf;lr
Rate.. n'lsd
rt.
Coke Burn-off
!sokinetic
Ratio, :
102.24
132.35
70
91.26
66
109.55
69
68
'C
Xrerage Stac~
Cas
N/1
26,340"
Stack Das Tmperature,
~iver~ge
Rate,
4g/nr
leloci
'lue;as
5/3/50
Content,
tas
Date
rtt
;eneral
lata
Outlet
7.4
ty,
il~
7.9
7.9
7.9
mis
Rate,
:h~/nin
j,a70
5,880
5,250
6,000
3ata
Iloisture
Content.
:Iolecular
I~eigkt of
Stack ;as,
kg/kg~0le
e0, Concentration,
: dry
21.97
23.56
17.93
21.1
30.57
30.42
33,39
j0, 5
11
14
13.a
13.9
20 Concentra~~on.:dry
II, Concentrlt~on.
5.8
4.6
4.6
5.0
81.4
81.6
25.6
30.3
:drT
Nt~Conccntratlon.
:dy ' 80.2
Emission
Rats,
"'~3;~9L;'
'"''
Lg/hr.
?artlculate
1.096
29.9'
g/Nml
0.085
0.072
0,081
28.6
9.08
Emissions
(Filteraale)
:ollection Efficiency,
Test ~lethod
Emission
NIA
Rernod 5
N/A
Ii/A
Nln
r!ethod 5
~lethol 5
Rate,
~g~:;~~oD~:g
co~F
Emission Rate, ;(g/hr
Sulfur
Sioxide
Concentration,vppn
Emissions
3.8
8.1
6.2
5.7
3.1
6.7
5.2C
uee
~Ollec~:an
Test
~Dara fra
0.Zb
6.8
Reference
Efficiency,
I!ethod
II/A
;letkod
Ii/a
6
:I~~hod
rIln
5
Netkad
!I/A
6
11.
bCokeburn-off rate calculated frcm scrubber outlet ~est data.
Calculation assumesno
nitrogen in cole. ambient air contains 79.3 percent nitrogen.
20.3 percent oxygen, and
1.2 percent
outlet
Flue
gas
flou
uater,
rate
and the Clue gas Flow rate

on a dry
at the scrubber
wuals
:ke regenerator
basis.
CTheaverage502emission
cancentration
reDortedan a dry, ')2-ireebasis is 3.5 vppnd.
C-19
;AsLE C-10.
F~UE tAS SCRUBBER

EMISSIONSTEST OATAa
PLANT C, UNrT I
jcrubber
Run !lunbeT
Date
;:ne
'CC ;resh;eed
Rate,
~~l!~d
Charrle
'CC Fresh
Sulfur
O~~let
9!3/75
2;5/!5
?/5/75
:jI0
0056
1149
B/d
Feed
Content.
Cote
vt.
5urn-off
Isokinetic
Y/A
N/A
Ratio.:
-.f
NIP
j5,:00b
Gas :~noeta-
:ure,
ii/A
Rate,
kg/hr
jtack
'.
i id
'I/A
O2nerai
Data
~verage
93.5
96.5
99.3
36.5
59
70
59
jg
iO.?
10.i
.i
OC
4veraqe
S~act 5ds
velocity,
~/s
!0.4
F~ue Gas zlov Rate,
6,040
Lllmin
i,Z20
5,930
5,060
udS
Ja ea
:(olsture
Cjn~enr,
t8.6
27.6
29.0
29.n
:~olecular Yeight of
Stacr Gas. 4a/tg~ole
?5.8
26.a
26.9
26.1
CO? 'oncentrario~.
13.0
i1.5
5.6
5.5
5.5
5.3
:drv
iO Concentration.:dry
02 Concentra~ian,:.dy
112Concentration.:dry
82.4
82.9
82.8
33.3
0.09
25.8
0.07
25.1
0.07
Co!lec~ian iificiency,
r~lA
:I/A
:r/A
~/d
Test :leekod
'I/A
N/A
H/A
ii/A
233.8'
47.8'
SJ.qC
188.2
37.6
43.7
Emission
Rate
Lg/1.000
~ar~ic~late
Enissions
82.7
Lg co~e
lurn~~f
tp/hr
g/Nm'
o.a"
hissian
Rate,
cg/1.000
rg c~Le
burn-of~~
Lg/kf
Sulfur
Dioxide
EnlssiPns
b"ce"tra~lon.
vppn
3.1
111.8
89.8
Vet
Co!leetion Efficiency,
~/A
!1/A
rest i;ethod
:c/A
N/n
C-20
a/r
i.i
0.09
N/A
?l/A
TABLE
C-10. FLUE
GAS
SCRUBBER
EMISSIONS
TEST
DATAa
PLANTC, UNIT I iConcluded)
Scrubber
Run Number
1
inission
Rate,
45/1.~03
rg
hum-off
Dlltlet
cole
~g/hr
Iverage
7.~ej
3.tC
Z.aC
2.7"
uppm
2.1
1.3
1.8
Efficiency,
Nid
~/A
N/A
~/A
N!n
Sulfur
Tr~a~lde
Emissions
Concentration,
1.?
wet
Collection
rest
rleehod
Concentration,
vppl vet
SulfiJr
Concen~ra~ion.
vppm dry,
Glides
O,-iree
N/A
rc/n
rl/A
190
39.4
45.5
341
74.1
87.3
157
237
50.0
55.5
3.Zb
113
N/A
N/A
H/d
N/A
P1.5
rn~ss~onr,
(as SO?)'
EnissionRate,
kg/1,000
Lg/hr
Cg cote burn-off
Collection
aData from Reference 13.
t,Loke burn-off
rate
calculated
Efficiency,
Fran scrubber
outlet
rest
data.
Calculation
assumes no
nit*agen in c3lte. unolenr air contains 78.8 percent nitrogen, Z0.0 percent oxygen, and
l.Z percent *ater, and ~he nue gas nau rare at the scrubber outlet equai s the regenerator
flue gas rlov rate an a dry basis.
CCalculated crcn test results.
C-21
'-"
TABLEC-ll:
FLUEGASSCRUBBER
EE1ISSIONS
TESTOATAa
PLANt C, UNIT II
;;ruober
?un 'lumoer"
nu~iee
Average
Dare
i/11/76
4/22/16
4/22/76
-ine
!553
1122
L535
1/4
:1/4
FiC Fresh Feed Charge
~neral
~aee
!0,600C
Jara
i~C ;rexh
seed
Content.
Zulfvr
r.
Coke 3urn-off
NIP
!I/A
Rare,
u/~
i1.100e
~g/hr
Iso~lnc~ic
Ratio,:
g9.5
Stack bs
rnngerature,
'C
lverage
Stack Gas
Yelocity.
Gas
10
IO2.0
69
.15.2
iai.~
lCo.s
72
70
13.i
13.5
I/s
'lue Gas clirr Rate,

;(nl./nin
3,630
3.210
3,740
3.750
Data
:loisture
Content,:
;tolecular
Ueiaht
4.0
24.9
?4.4
24.1
Stack Gas, tg/kg-male
27.5
27.4
27.5
27.5
to; Concentration, ~ dry
15.a
15.1
!5.4
15.6
1.9
1.6
1.6
1.7
of
CO Concentration,
~ dry
O, Concentration, : dry
H2 Concentration.:dy
82.3
BJ.O
83,0
83.1
23.0
ZB,Z
26.0
25,7
Emission
Rate,
L9/1,000
Lg coke
bur~-off
Particviare
Enirsiona
ka/hi
giam~
0.10
Co!lectlon Eff~clency.
Test :lethoo
EniSslon
Sulfur
3ioxide
E~iissions
5.12
:J/p
N/P,
NIPI
N/1
n/a
Rate,
k9/1,500 rg coke
burn-off
tg/hr
Concentration. vppn
5.0d
6.8d
7.Id
6.9
8.9
~.6
Rt
Co'ection
1.2C
0.1Z
Efficiency,
;esr Ilethod
N/A
N/A
C-22
~/a
N/A
~/A
0."e
6.'d
8.5
TABLE
C-ll. F~UE
GAZ
SCRUBBER
EMISSIONS
TEST
OATAa
PCANTt, UNIT II (Concluded)
Scrubber
Run :lumber
2
Emission
Trioride
inissions
Average
Rate.
kg11.000
~gcol(e
burn-off
kg/hr
Sulfur
Outlet
;oncentration,
vppm
O.OBe
1.5d
1.8d
I.Bd
Z.1
1.9
2.0
2.0
N/A
nlA
N/I\
N/A
~/n
N/A
N/A
1.3"
uet
Collection
Efficiency,
Test Ilethod
Concentration.
vppn ver
Sulfur
Concentration,
vppm dry,
Oxides
02-Free
~15510n~
(as 502)
12.9
10.8
L1.5
15.6
16.6
Emission Rate.
kg/l,OOa kg colte burn-off
kg/hr
Collection
"Data irm
8.9
Reference
Efficiency,".
10.4
L5.0
O.:e
6.5
8.2
~/A
8.6
N/A
7.7
H/A
14.
b~un one vas voided due to unacceptable

Ctapacity obtained from Reference L5.
Is~~ine~!e percentag~.
dCalculated ~ran test data.

eCoke burnoff rarecalculated
from ecNbber autlet.test
data.
Calculation
assumes no
nitrogen in cole, ambient air contains 78.8 percent nitrogen, ?0.0 percenr oxygen, and
1.2percentrefer, andthe flue gas flowrate at the scrubberoutlet equalstke regenerator
flue
gas flow rate
on a dry basis.
C-23
TABLE
C-12. FLUEGASSCRUBBER
EMISSIONSTEST ~ATAa
PLANTD, COMPLIANCE
TEST
Scrubber Ou~let
Run~umber
3ara
5/19/81
5/19/81
5/19/81
T~me
1425
1754
1952
N/A
N/A
:(/4
Fresh'Feea
N/4
FCC Fresh Feed Sulfur
Content,wt. ',
N/A
NIA
[soLineticRatio,',
Scrubber
Inlet
95.9
Inlet
Stack Gas rempera-
99.0
9,763
97.9
1.701
1 7:6
;iln
nin
n/A
gg
57
57
57
15.0
15.1
15.9
15.3
16.5
16.6
16.6
30.7
30.7
!0.8
30.7
2.3
2..5
2.3
2.5
16.1
16.2
16.6
16.3
'C
Average StaEf Gas

Velocity,
m/s
rbistureContent,'.Vol. 16.8
No,ecular
98.9
N/A
reiskt
::
Flow
Rarer ;Im~/min
ture,
N/A
Flow
Rate, :Im~/nin
Regenerator
N/A
Rate,
~g/hr
bata
Average
Charge
Rate, n1/5d
Coke Sum-off
Cas
Gate
Ftt
3eneral
H/n
of
Stack Gas, kg/kgmole,
dry
dry
Concentration,i dry
CDConcentration,
-.dry
Emission
ROb
Rate
kg/l,OOO kg coke
Particulate
Emissions
bum-off
kg/hr
R/A
3.9
9/Nm3
0.028
Co:lection
Efficiency, NIP,
Testrlethod
n/p,
4.6
0.033
?1/4
PlcChod
5 'ncthad5
N/A
5.3
0.030
n/n
4.3
0.030
N/A
nethad5 i~ethod
S
Emission Rate,
kg/1,000 kg coke
bum-off
N/A
Lg/hr
Sulfur
O1oXlde
Emissions
0.79
Concentration,
vppm
4/A
1.0
Test rbrhod
0.1
1.3
13
2.9
3.7
4.5
!.7
N/A
n/A
N/A
~/A
d'Y
CollectionEfficiency,
N/A
netkod 6
C-24
;lethod 6
::
TABLE
t-12.
FLUEW\5StRUBBER
UMISSIONS
TESTDATAa
PLANTO, COMPLIANCE
TEST (Concluded)
Scrubber
~un :(umber
1
Enlsslon
Qutlet
~verage
Rare,
1(9/1,000 kg coke
~um-off
kg/hr
:I/n
0.21
0.14
BIA
o.l8
3.02
0.12
Sulfut
rriox~de
hi~sions
C~ncenrration.
vo0n
0.4
0.6
0.5
Ory
Collection
Test
SulPur
Ox~des
Efficiency,
IIethcd
Concentration,
vppn dry
Concentration,
vppn
?IIA
Y/A
NIP,
nln
Illn
1/A
5/A
3.3
4.3
5.0
4.2
3.7
4.9
j.g
4.7
0.9
1.2
l.S
0.1
L,2
dry,
O,-free
t~ission~
(a5 ~02)
Enlsslon
Rate,
49/1.300
~gihr
kg coke burn-off
Collection
Efficiency.:
inission
n/A
N/A
~/A
N/A
Rate,
tg/1.300
kg coke
bu m-off
N/A
k9/hr
~/A
N/A
3.8
35.8
33.3
29.9
33.0
18_6,4
171.7
145.9
168.0
N/A
H/a
NltrPgen
Oxidc~
Concentration,
bissions
Collection
Teet
a0afa
vppn
vet
from Reference
Efficiency,
Method
Ilethod
16.
b;l0L detected.
C-25
rletkod
N/A
7
;lethod
N19
7
:bthod
TABLEC-13.
FLUEGASSCRUBBER
EMISSIONS
TESTDATA"
PLANT D, GUARANTEETEST
--
---
Scruhncr Inlet
Uste
__
Cuncral
Data
-'
no5
1140
AveraIJe
5/6/01
1410
0041---- 1131)- 1417
Feed
Change rate, Inl/sd

FCC Fresh
Scrul,berOutlet
Avera~Je
5/6/01 5!6/81 5/6/81
__
FCC Fresll
H/A
NIA
Feed
Su`lfurContent,wt. Z
0.26
Coke W~m-ofT Rate, kg/hr

Isoklnetlc
Ratio,
I/A
9.116
H/A
11)2
9 ,1125
0.841
----
ll,r195
Inc
10)
lo~
1.838
1.063
1,041
41
11
133 35
42
139
41
11Ii
Flue Cas Flow Rate,
)bol~nln
AverDye
cf~
Stack
1146~_
Velocity,
a/s
5145Tallpfraturr,'l:
~___~
1,900
(,g)l
43
355
44
331
cc
336
Emission Rate,
Irg/l.OUO kp coke Iwnl-off
9/LI~
Partlculare
Elnisrions
1.093
L,841
Gas
44
341
N/A
tyl)lr
0.2
N/A
H/A
n.3
0.02
2.1
0.02
2.2
0.3
0.02
2.5
0.3
0.0?
2.5
Z
I/A
Tes
t Irtllod
CO"C~I~1'U"dTy
Evlisslunn
kg/hr
154
14L1
150
5~9
49
46
5.1
46
I.n
Ilrtllod6
Ibtllod6
tg c~,Le bur-ll-olf
nlox lilt!
I.l:lisslons
144
Ilctll~rJIletlloll5
rletlluJ5
L0.5
1.5h
Rate,
kg/L,000
SNICur
Ilolllu~l
5 Ilethorl
5 Helhod
5
43
Collection E~Ticirncy,~
lest Ilcthod
i.s
96
Ilrthod 6
"l)ara Irlrl Reference17.
Ilethod 6
Ilrthull6
11.3
3.2
96
93
Ilcthod6
Itetllod6
2.3
!15
lle111~,116
bl)ledvcl,geSO
2 el;llsslon
collcentratilln
pt tilescrubber
outlet,reporten
ona dry,np-free
basisis 8.0vpls:al.
i.
I :
L._
i: -1
1.:-_1;-1]
Table
FLUE
GA5
SCRUBBER
EMISSIONS
TEST
DATAa
C-14.
PLANTA, EPA-CONDUCTED
SOU~CETEST
Number
of
04 ta
Minimum
Dates
General
Oata
N!n
N/A
0.32
0.60
0.45
26 daily
12,800
17.200
15.300
266 hourly
N/A
5/27-30/81
$urn-oiP
2.9
scrubber outlet
3.22
g/Nm3
scrubber inlet
scrubber
tg/hr
scrubber
outlet
inlet
'
B.e
6.d
1.5
C.9
'0. IS
0.72
0.10
C.06
0.41
38.6
118.7
17.2
0.007
scrubber outlet
7.6
Emissions Reduction, wt.:
12.4
8
8
83.3
59.1
83.3
tg/1.000
cokeburn-off
scrubberkginlet
12.6
24.i
18.6
scrubber outlet
RemovalEfficiency, wt.:
0.4
82.2
4.0
38.2
1.3
93.0
339
15.8
92.9
397
Z5.5
95.7
370
19.9
94.6
9
9
9
2.6
8.8
4.a
0.3
1.4
0.8
Dates
5117-28/81
Dioxide
Emissions
Cent i nuous(by
Monitoring)
Dares
5/e7-30/81
Sulfur
Dioxide
(vppn)
scrubber inlet
scrubber outlet
Removal Efficiency,
Sulfur [b~ides
Emissions (by
Stack Tests)
scrubberoutlet
Removal Efficiency,
Dates
Orides
Emissions
94.4
84.4
wC.:
1.5
2.5
38.0
23.2
10.8
80.8
15.0
6.3
jg.0
9
8
8
~rleZ
17.9
0.0
21.5
2.4
19.7
i.;
0.0
2.5
Concentration
(vppn)
:1tdrdca~onr
Hydrocarbons
C~.Cg
Hydrocarbons
TOTAL
01,6Hydrocarbons
nDT
PETECTEO
1.3
18.7
RatDEtECTm
26.6
22.7
85.4
99.1
5/7-8/81
Scrubber
Dltlet
(vppn dry)
Concentration
"Oara
from
Reference
is.
5/27-29/81
266 hourly
80.4
01
Hydrocarbon
~, Hydrocarbons
Dates
266 hourly
5/8-9/81
Scrubber
Ihdr~c~~~n
Emissions
266hourly
wt.b
(vppn)
scrubber Inlet
scrubber outlet
Removal Efficiency,
Nitrogen
wr.Z
Sulfur Trioxiae
(vppn)
scrubber fnlef
Sulfates
j,
PolnrS
Fresh Feed Sulfur Content, vt.Z
~9/1.000 k9 coke
scrubber inlet
Sulfur
Fresh Feed Rate, m'/sd
Dates
Emissions
Average
j/5-30~81
Coke Burn-off Rate, Lg/hr
Partlculate
Maximum
only.
C-27
33.1
TABLE
C-15. SULFUR
OXIDES
REDUCTION
CATALYST
TESTDATAa
PLANT
E, TEST
1
Pretest
Dates
GeneralData
Fresh FeedRate~,m3/sd
Fresh Feed Sulfur Content, wt.%
CokeBurn-off Rate, kg/hr
Regenerator Flue Gas Temperature, "C
Gas
Steady State
8/18/80
11/13/80
3,300
3.000
0.99
1,07
7 480
690
660
1,380
i, 130
2.3
2.a
Flue Gas Flow Rate,
Data
SmJ/mi
n
02 Concentration, Vol.%
Emission Rateb
Particulate
Emissions
kg/1,000 kg coke burn-off

kg/hr
g/Nm9
Emission
Sulfur Dxid~s
Emissfons
Emissions
Emissions
Emissions
kg/hr
kg/l,OCOkg coke burn-off
2.5
350
77.5
10.4
60
10.9
1.7
Rate
vppm
r63
kg/hr las NO)
25.8
kg/1,000kg ~~ke
burn-offlas NOZ) 3.4
NAe
:IA
~A
Rate
vppm
110
kg/hr
11.4

Reference
86
15.6
Rate
YPPTI
Emission
Nitric Oxide
0.23
vppn
413
kg/hr las 50 j
91.3
kg/1,000kg 2oke
burn-offlas S0p) 12.2
Emission
NitrogenOx~des
2.7
16.9
Rate,
Emission
Sulfur Oiox~de
2.2
16.5
0.19
1.5
700
59.5
94
21.
bSamp7ing
datesfor pretestandsteady-state
respectively.
C~etchemicalanalysis.
dInstrumental
anaiysis.
eNot available.
period are 8/8/83 and 11/4/80,
~:J
C-28
TABLE
C-16. SULFUR
OXIDES
9EDUCTION
CAT~~LYST
TEST
OATAa
PLANT F, TEST 1
Pretest
Dates
12/2/80
Fresh Feed Rate, m!/sd
3,400
Steady
1/24/81
State
3/18/81
3,020
3,020
1.0
1.06
1.37
6,210
5,940
5,900
677
682
670
1,270
1,230
1,180
2.5
2.55
303
103
General
Data
Fresh Feed Sulfur Content, wt.X

Coke Burn-off Rate, kg/hr
Regenerator Flue Gas Temperature, "C

Gas
Flue Gas Flow Rate,
Data
Smj/min
O, Concentration, Vol.%
Emission
Sulfur Oxid&s
aiiiianr
vppn
Rate
vpp
kg/hr
300
kg/l 000 kg coke burn-off

Emission
61.1
9.B
85
16.7
2.8
100
18.9
3.2
Rate
707
vppm
kg/hr (ds NO)
103
kg/1,000
kg~okeburn-off
las N02) 16,6
Nitrogen
155
iglnr
iaikgZOS~i;~
burn-off
(ail021
61.7
Zi~.Z
29.3
kg/1,000
9.9
3.4
5.0
Emission
Suifur
Diox~de
Emissions
Rate,
2.0
1,071
~51
. 25.4
1,306
177
30.0
Oxides
Emissions
Emission Ratec
590
vppll
kg/hr
"Reference 21.
byet chemical analysis.

CInstrumental analysis.
0-29
86.3
13.9
1,050
148
24.9
1,200
163
27.6
C.4
i.
REFERENCES
Manda,M.L., Paci:ic EnvironmentalServices, Inc. Trip Report:
Marathon Oil Company,Garyville,

Docket
2.
Reference
Louisiana.
Exxon Company,U.S.A., Baton Rouge, Louisiana.

Reference
Number
TI-B-lO.*
Goodwin,
D.R.,
Reference
U.S.
Environmental
Number
Protection
ZI-D-41.+
Agen~y.
request.
March
Docket
20,
Emission testing for MarathonOil Company,Garyville, Louisiana,
on July 16, and September2, 1980. KemronEnvironmenta7

Services,
Baton Rouge, Louisiana.
II-I-80.
5.
July 24, 1980.
Letter and AttachmentsfromAlbaugh,D., MarathonOil Company,to

1981. Response to Section 114 infonation
4.
September 24, 1980.
Bernstein, G., Pacific Envil-on~nentalServices, Inc. Trip Report:

Docket
3.
Number 11-3-13."
September 1980.
.a
Cantrell,
Oil and Cas Journal.
78(12):136-157. March24, 1980. Docket Reference l'lumberII-I-7l.f

6.
Cunic, J.D., S.A. Diamond, P.E. Reeder, and L.F1. \lilliams.
FCC
Stack ScrubbersDoDoubleDuty. Oil and GasJournal. 76(23):70.

May 22,
7.
1978.
Docket
Reference
Number 11-1-42."
EmissionTesting for ExxonCompany,8aton Rouge, Louisiana.
Kemron
EnvironmentalServices, BatonRouge,Louisiana. December
20,
1977.
a.
Docket Reference
Number IZ-I-34.+
EmissionTesting for ExxonCompany.KemronEnvironmentalServices,

BatonRouge,Louisiana. June 15, 1978. DocketReferenceNumber
11-1-44.'
9.
EmissionTesting for ExxonCompany

Refinery, BatonRouge,Louisiana.
~emronEnvironmentalServices, Baton Rouge, Louisiana. March2,
1979.
Docket Reference
Number 11-1-51."
1O. Emission Testing for ExxonCompany,U.S.A., Baton Rouge, Louisiana.

KemronEnvironmentalServices, Baton Rouge, Louisiana. June 20,
1979. Docket Reference NumberTI-I-60."
11. Emission Testing for the ExxonRefinery, Baton Rouge, Louisiana.

KemronEnvironmentalServices, Baton Rouge, Louisiana. June 13,
1980.
Docket Reference
Number 11-1-77.'
12. Letter and Attachments from Flynn, J.P., ExxonCompanyiJ.S.A., to
Farmer,J.R., U.S. EnvironmentalProtection Agency. May8, 1981.
Commentson BID Volume I, Chapters 3-6.

II-D-50."
C-30
~"
13.
Stack Sampling at Exxon Refinery, Baytown, Texas, on September 4-5,

1975.
Account
number 104-703-5.
Novembe`r 19, 1975.
Texas
Docket Reference
Air Control
Board.
Number II-I-?O.f
14. Stack Samplingat ExxonRefinery, Baytown,Texas, on April 21-22,

1976.
Account
25, 1976.
15.
number 104-703-5.
Docket Reference
Cantrell,
A.
Texas A~r Control
Board.
June
Number II-I-24.*
Annual Refi-ning Survey.
79(13):110-150~ March 30, 1981. Docket Reference NumberII-I-99."

16.
Letter
and Attachments
Rhoads, T.,
Pacific
from Gill,
W., Texas
Air Control
Environmenta~ Services,
Inc.
Board,
to
December 15,
1981,
Compliance test for the Southwestern R~fining CompanyFCC
unit.
Docket
Reference
Number
II-D-85.f
17. Letter and Attachmentsfrom Cunic,-J.D., ExxonResearchand

Engineering Company to Bernstein,
G., Pacific
Services,
Inc.
February 22, 1982. Guarantee
scrubber
Number
18.
19.
at
Southwestern
Refining
Company.
Environmental
test for sadiurn-based
Docket
Reference
IZ-D-91.+
Cantrell,
7_5_(13):99-123. Ctarct~ 28, 1977. Docket Reference ~lumber 11-1-29."
Petroleum
Refineries:
FCCU Catalyst
Regenerator
Report, Marathon Oil Company, Garyville,

Summary of Results.
U.S. Environmental
Emission
Louisiana,
Protection
Test
Volume I:
Agency.

EMBReport No. 80-CAT-8.
April 1982. Docket Reference Number II-A-18A.+
20.
Continuous
Emission Monitoring
for Industrial
Boilers,
General
Motors Corporation Assembly Division, St. Louis, Missouri, Volume I,

System Configuration and Results of the Operatfonal Test Period.
U.S. Environmental
Protection
North Carolina.
June 1980.
21.
Letter
and Attachments
Agency.
Research Triangle
Park,
Docket Reference
Flumber II-A-11.~"
from Buffalow,
O.r.,
Chevron
U.S.A.
Incorporated,
to Coodwin, D.R., U.S. Environmental Protection

Agency. June 29,
Docket
Reference
*References
Number
II-D-57."
can be located
in Docket
Number A-79-09
at
the U.S.
Environmental.
Protection AgencyLibrary, WatersideMall, tlash~ngton,D.C.
0-31
APPENDIX D
E31ISSIONMEASUREMENT
ANDCONTINUOUS
MONITORING
D-1
D.1~IISSION
MEASUREMENT
METHODS
D.1.1 EmissionTesting Program
A single emissiontest programfor NSPS

development
wasperformed
by EPA/EMB.
Theobjectiveof this test program
wasto obtain approxi-
mately14daysof continuous
emissions
data froma fluid catalytic
crackingunit (FCCU)
fed with0.2 to 0.3 percentsulfur feedandequipped
with a highenergyventuri-wetscrubbersystem(HEV-I~SS)
for SO,control.
Thehost site wasMarathon
Oil Company's
refinery. Garyville,L~uisiana.
Continuous
emissionsmonitoringwasperformed
for 12 daysan both the
inlet and outlet of the HEV-WSS
in order to determine SO2
removal
-?i
-3
efficiency, Relativeaccuracy
of the continuous
emissions
monitoring
system was determined using the modified Method8 reference method.
Relative accuracywaswithin the specifications of proposedPerformance
Specifications
2 and3, FederalRegister,Volume
44, No.197,October10,
1979,andFederalRegister,volume
46, No.16, January26, 1981. Oataon
S02/S03
andparticulatesulfate, nitrogenoxides,hydrocarbon
andparticulate
emissionswerealso collectedduringthis test program.Additionally,
samplesof the productfeed to the fl'uid catalytic crackingunit and
samples of the scrubber purge water were collected.
0.1.1.1 ScrubberInlet. Volumetric

flowandmoistureweredetermined
by EPAReference
Methods
i, 2, 3, and4 with the followingminor
modifications:
..
a) Because
the HEV-MSS
inlet sampling
portwasunderhightemperature
and pressure (360"Fand 40 inches of water), special port
adapters and~samplingprobes had to be fabricated for the test
program(Figure D-l). Dueto the close-proximityof the

scrubber disengaging drum to the south port on the. scrubber
inlet, the manualsampling probe could only be used on the
west part. However,fromprevioustest information,l sampling

from one port was determined to be equivalent for this site.
b) Moisturewasdeten~inedbymeasuring
the moisturecollected in
theimpinger
trainduring
eachmodified
Method
8502iS03
test.
502/503and particulate sulfate weredeterminedusing EPA

Method 8 with the following modifications:
8-2
Reference
Gate
Monor~ll
Assemb_ly
o
I
Ilea
Impinger
Valve
------~
-C2~
Collar
ter
Oox I ) gd 10Slmpl~lg
Probe
~ox
-I
II
It G.,
F\DH
Spacial
Port Adapter
k~
A~semb\y
Slack
Figure 0-1. Manualsampling port adapter.
Hall
a) A heatedfilter housedin a standardRACR

train heater boxwas
used. Theboxtemperatu-re
wasmaintainedat approxinately
3500Fand the filter medium
usedwasReeveAngel934Hglass
fi ber.
_:J
b) 100miof acidified80percentisopropanol
(IPA)wasplacedin
the first impinger(1.0 N hydrochloricacid addedto 20 parts
water).
c) Packed
glass woolplugwasplacedbetween
the IPAimpinger
and
first hyd'rogen
peroxide(HZ02)impingerto preventparticulate
sulfates from carrying over into the H202 impinger.
In addition, continuous monitors for SO2'
C02' CO,02 and temperature
wereinstalledandoperatedaccording
to the procedures
outlinedin
performance Specifications
2 and 3, Federal Register,
Volume 44, No. 197,
October10, 1979,andFederalRegister, Volume

46, No.16, January26,
1981, except for thefollowing
modifications:
The conditioning period was 105 hours instead of 168 hours.
Thiswasdueto the timeconstraintsof this test program.
b) Relativeaccuracy-was
performed
fromthe9ththrough
12thday
of the continuous emissions monitoring program. This was
necessary because of the relatively
short (12 days) continuous
emissions monitoring program.
Therelative accuracytests used EPAMethod3 and modifiedMethod8
as referencemethods.TheSOp'analyseswereperformed
in accordance
with EPA Method 6, Section
4.
The02 and002analyseswereby the arsat
method.
In order to determine emissions data in
terms of kilogramsof SOx

per 1,000kilogramscoke burn-off, a correlation wasestablished between
the volumetric
flowrate into the regenerator(recorded
by the company's
flow rate instrumentand furnished to EPA)and the volumetricflow rate
into andout of the scrubber. Thiswasaccomplished

by comparing
scrubber
inlet andoutletvolumetr:ic
flowratesdetemined
duringmanual
testing
to the flowrate into the regeneratorrecordedby the ompany
duringthe
-ame period
of
time.
0.1.1.2 ScrubberOutlet. Vol;i~rtricflowandmoistureweredetermined

by EPAReference
Methods
i, 2, 3, and4 with the followingminormodification:
a)
Moisturewasdeterminedin the samemanneras described for

the scrubber
inlet.
0-4
_.i:
~/503andparticulatesulfate weredetermined
in the samemanner
as
describedfor
the
scrubber
inlet.
Nitrogen oxides emissions were determined. by EPAMethod.7.

emissions were determined
by EPAMethod 3 and analysis
Hydrocarbon
performed in the
field by GC/FID
for C1 - Cg carbon fractions.
Continuous
monitorsfar 502, COp,02 andtemperaturewereinstalled
as described
ior
0.1.1.3
the
scrubber
Product
inlet.
Feed toFCCU.
Dllring this
test
program,
the
refinery's hydrodesulfurization system was off-line, and all feedstock

to the FCCUwas suppl'ied from storage tanks. Daily analysis for sulfur
content
of the feedstock
the results.
furnished
to EPA. Grab samples of thefeedstock
to EPA at each storage
0.1.1.4
to the FCCUwas perfonned by the refi?ery

tank
Scrubber Purge Water. Grab samples of the scrubber purge

storage~tank
were analyzed for total dissolved sol'ids, total

D.1.2
were furnished
change.
water were taken at each feedstock

chemical
and
change.
The samples
suspended solids,
and
oxygen demand.
Modification
toEPAMethod
Previous evaluations by EPAand others indicated thatEPA Method 8,
as written, mayproduceerroneous SQ, concentration results due to
ammonia
(NH3)
concentrations
presentin FCCU
f'luegasstreams.(In the
presenceof isopropanol, free ammonia
reacts with 502 to fern a patticulate
sulfate
in the first
impinger.)
Existing
test
data that would
indicate the NH3concentrationsin flue gas streamsfromhigh temperature

regenerators were not available; therefore, it was necessary to modify
the EPAMethoda samplingtrain to ensure no NH3interference in the
502/503samplingperformed
duringthis test program.
Control tests during the test programindicated no NH3concentrations
present at this site becauseno interference was detected in the 502/503

analyses.
0.1.3
Development of Modified Method 8 Train
Twomethodsfor removingNH3were considered:

1) Place an impingerupstreamof the 502/503train witha concentrated
sulfuric acid (H2S~q)

sc'ubber (50 percentby wt.). AnyFIH3
in the gas sample would form ammoniumsulfate
in this impinger
withthe502andS03passing
through
unreacted;
and
0-5
2) Placean impinger
upstream
of the S02/S03
train witha weak
(1.0 N) hydrochloric acid (HC1) scrubber.
4nmoniumchloride
is formedin this impinger

with the S02andS03passingthrough
unreacted.
The HC1 impinger was chosen because sulfuric
acid
T~
mist was Se1ieved to be present in the flue gas to be tested
:_i
andalso anyH2S04
scrubbercarryoverwouldaddS04=
to the SO
impinger,
HC1 would
not.
0,1.3.1 LaboratoryEvaluationof ilet~od8 SamplingTrain With

HC1Impinger. A series of 11 sampleruns were conductedin the laboratory
using a noncertified
calibration
gas containing
25 vppm of
nitrogen base ~(a tag attached to the gas cylinder indicates

concentration
was analyzed
SO21"
ddry
:1
that the SO
to be 25.8 vppm).
; 6
The proposed, modified Method8 sampletrain (see Figure 0-2)
consijted of a heatedprobeandfilter foilowedby a 1.0 NHC1scrubber
r-;i
(to removeammonia),80 percent IPA impinger,~a cold filter, and' two

3 percent H202impingers each containing 100 mi of solution. A final
impinger
contained
Silicagel. Ouring
thelaboratory
tests, theprobe
and filter
were kept between 300 to 350"F, and the solution of the first
impinger was changed often
and injected
with a fixed amount ofNH.OH
solution to representapproximately
40 vppmNH3in the calibration gas.
The volumeof calibration gas drawn through the sample train varied from
3 to 4.5 dscf and was sufficient
range using
0.01
N barium
for analysis to fall within the accurate
perchlorate
titration.
Sampling and Analysis
The laboratory evaluat~onof the experimentalMethod8 sampling

train was performed in six phases.
Phase i:
These six phases are as described:
Sampleruns i, 3, and 17 were conducted by simultaneous,
dropwiseinjection of 0.03 N'NH40H

into the HC1scrubber (40 vppm).
Concentrations
of 502 in the HZ02
we'e measured
as 24.4, 24.1. and25.0
vppm, respectively.
No sulfates
80 percent IPA impinger.
Phase 2:
were detected
in the HC1 scrubber
and
On sample run 2, the HC1scrubber was 7eft out and ammonia
injection was madedirectly into the 80 percent IPA impinger. Analysis
far 502In the H202impingersrevealedonly 5.4 vppm, Nosulfate was

detected in the IPAimpinger, nor was any sulfate detected after treating
an aliquotfromthe IPAimpinger
with3 percentHZOZ
0-6
:"
ILU)LRITYR~tLYSOR
Heated
,eoer
rltOT
~~eEVALVE
U"heated
Filter
Filter
r:I I~I
~nEFIMOHrnR
j
(,,,1
(,,,
TUIL1~~I~RAIURESErtOR
~------r t-~----
/:
1CEVERSE
nPZ
PITQI TUBE
'(
).
I;
i"
~I ijII
I~i
I~
II1
r;!
PITOT
iI
::
OtI
11
~r.
I:
1: ;
i'P"
VACVfUI
UHE
LIANOMETER
Ic~ BATH
IWPINCE~S
TnERLIOIlETERS
~C~H~I Sciubber
sr~Ass
VALVE
OAltlCE
VACUUM
GAUGE
HAIN VALVE
~fP
L,
DAI
A)R-TIGHr
RIMP
TEET UETER
Figure D-2. Experimental
EPA Method 8 Train
to Include NHJScrubber
D-7:
Phase 3:
Sample runs 4, 5, 6, and 7 were conducted as control
(no HC1 impinger/no NHOH injection).
The respective
standards
analyses for SO
in the H202impingerswere 23,8, 24.8, 26.1, 23.5 vppm. Duringsample

run 6, the solution in the 80 percent IPA impinger was accidentally left
out.
No sulfate
was found in the IPA impingers.
Phase 4: During sample runs 8, 9, and 10, the HC1scrubber and 80 percent
IPA impingers wer'e combined into one impinger. The impinger contained a
100 ial solution
of 80 parts
IPA and 2'0 parts
of 1.0 N.HC1 solution
and
is referredto as "acidified
80percentIPA."Known
quantitiesof NH40H
solution were injected
in the acidified
80 percent IPA impinger to
represent 40 vppmof NH3 The resulting analyses of these runs were
--
28.1, 27.7, and 26.7 vppmS02

Phase 5:
The calibration
gas was analyzed.by a TECOSeries 40/pulsed
fluorescent Z02analyzer. The value for this run was 27.95 vppmSO2'
Phase 6: The acidified 80 percent IPA impingers on sample runs 8, 9,
and 10 and the HC1 impinger in sample run 11 were spiked with 10 mi of
0.1 NH2S04
solution (exactly 49.0 milligramsH2SOq
per sample). By
titration analysis, the H2S04recovery was 49.9, 49.9, 48.6, 49.9 milligram
per sample, respectively.
The spiking represented approximately 100 to
140 vppmH2504
Discussion
and Recwnmendations
TheS~2recoveryinvolvedphases1~through5. TheHZS04
mist
recovery
was evaluated
in phasC 6.
Phases 1 and 3 indicate a re~at;vely goodagreementbut solnewhat
lowervalues than the analyzed25.8 vppnS02

Phase 2 was evaluated further since the lower value of 5.4 vppm SO
indicateda reaction betweenNH3andS02in the impingertrain. A
portionof the IPAimpinger

solutionwastreatedwith3 percentH202
and
analyzed,
but no significant
effect
was noticed.
As a result of the foregoing tests, the first impinger of the EPA

Method 8 was modified (see Figure 0-3) by using the acidified IPA solution
described in Phase 4. Analysis was done using Barium - Thorin titration.
0.1.3.2 Field Test Analysis roblems.
During the field test
program, S03 could not be determined in the field due to difficulty
0-8
in
1;
~~IArLRAIURESfHrOR
)ROBE
lITO'l
'IUBE
TEMPERATURE
~EYSOR
PROBE
HEATED.
FILTER
COMPARTMENT
I,,
,!VALVEECK
GLASS ~OOL
;;
REVERSE TIPE
P1107
THERMOME'TER
: ;
: I
.-I
?1
TUBE(II~%-~9~~
II 'O
""
::
U~~
i'r
,,I,I PO
I~
:bi
PIT6T
,I
O i: :
1~
I;i;
ii
be
VACVUL1
ii
LINE
~NO~ETER
ACIDIFIEO
1C~BATH
IMPINGEILS
THERMDPIETERS
~80%d' IPA
8~-PASS
ORIFICE
C/1
VALVE
C/)
~1
tP
3~-~
~I~n~b~
~vatvuM
GAUGE
HRIN
o33
AIR-TIC~T
PUH.P
DR'I TEST IKTER
Figure 013. Modified EPAMethod a with acidified
D-9
IPA impinger.
VALVE
determining end-point in the Thorin titration.

This problem did not
appear to be due to the HC1in the IPA imping,er, but due to soirie other
interferen~e.
The503and particulate sulfate (SO4,'sampleswerelater analyzed

in a laboratory by ion chromatographic analysis.
0.2
MONITORING SYSTEMS AND DEVICES
A varier;, of 502 monitoringsystems are available for use at FCC

unit catalyst
regenerator
of FCCunitcatalyst
1.
facilities.
regenerator
Due primarily
to the similarities
exhausts and those of coal-fired
steam
generatorexhausts,no Substantivedifficulties in adaptingexisting 502
;.i
monitoringtechnologyare anticipated.
-,
would be performed as an indication

of control
systems.-
This section
It is assumedthat monitoring
of proper operation and maintenance

will
present
a brief
overview of the
cost, composition,and reliability of S02 continuousemissionmonitoring

systems (CEMS)requiredto
monitor emissions in two different
fonats.
Theseformats are (1) parts ~er million, by volume(vppm)and (2) kilograms

S02 per 1,000 kilograms coke burnoff.
0.2.1 OEMS
Monitor SO, Emissions in vppmFormat
Performance specifications
have been proposed adequate to evaluate
theacceptability
of S02GEMS
in this format.2TWO
typesof continuous
502monitorsare commercially
availableto measure
502emissions.
Extractive monitoring systems:withdraw a small, representative sample of
the flue gas; transport
the sample to the gas conditioner;
and after
proper conditioning, measurethe 502 content of the flue gas. ln-situ

monitoring systems perform the required analysis of the flue gas inside
the stack without the need to transport Or condition the gas sample.
In-situ analyzers must be extremely rugged to circumvent ,Tiaintenance
problems associated with the normally harsh stack environment.
The capital cost of a GEMS

is estimated to be in the range of
869,000to $90,000per site (including the initial performancetest),

depending on the type of system chosen by the companyand the complexity
of the Ynstallation
requirements.
Equipment costs were obtained
from
vendors:3'4 other costs are based on engineering estimates.

Annual
operating cost per site is estimated to be in the range of 871,000 per
year.
Table D-l provides
a more thorough brea~down of estimated
D-iO
costs.
TAOLE
D-1. SO:,CONTINUOUS
MONITORING
COST
Total
Initial
Option
Equi pnent
Cost
installation
OutletEulission J39,000-60.L10n' 120,000
Rrfunnallce
Cost
610,000
(vpplll)
' Monitors
Re~en!llce
60
CnCi tal
Cost
Routine
Labor
Materials
JFJ9,000 110,000
to
)11000
Total I~nllualOperatillg Cost
6111000
100,000
ConLi~luuus
Auttmated
Initial
12,000
___
---
12.000 j50/sdrl~le
___
3ln,OUUE
nethotl
alncl~~des
.estialateof 620,000for data acqcllsitlunsysten. Ral~cJe
providedI,ecauseof variedCostof Ilifrerentty~e
502 "lO"itorlncJsystans.
''lncludrs both labor and Iraterlals.
CAlllnlal
cost is highlydependellt
o~lthe sanlpling
frequency.Costpresellterl
is fur dailyone-point
saaplin!l.Mlllt(point
salnplincJ rould add proportionately.
FCCUcatalyst
regenerator
exhausts are s.imilar to those of coal-fired
steamgenerators;therefore, the continuous502monitoringtechnology

proven acceptable for steam generators
should be applicable
to FCCU
catalyst regenerators. 502 monitorshave been installed on someFCCU

catalyst
regenerators,
The Emission Measurement Sranch (EMB)has not
"~
gathered information on the operational history of those GEMS;however,

properly designed systems should be capable of meeting the performance
specifications proposed by EPA. Reliability of the GEMS

system to date
at steam generators and industrial boilers appears to vary widely depending
:,1
on the type of flue gas desulfurization systememployed.502 monitors
--q
installed
greater
on sodium-based scrubbers appear to have a reliability

than 90 percent
while those
installed
on lime/limestone
of
scrubbers
had a reliability of 37 to 85 percent based on short ten (30- to 90-day)
EPA
tests.5 Theprimary
problems
st the latter sites appeared
to be in
particulate
plugging of the sampling probe in the stack.
Redesign of
this should improve the reliability

of the GEMS. Information submitted
by one company indicates 88 percent reliability
of one system at a
lime/limestone
scrubbersystwnovera periodof 1 year.6 Reliabilityat
FCCUcatalyst regener~ators is expected to be similarly affected by the
type
of control
system
employed.
EPA
hasdeveloped
Method
65that makesuseof the combined
SOZ
and
002 measurementcapabilities of -Methad6Ain a long-term samplingmethod.
Method 68 can be operated intermittantly
(2 to 4 minutesper
hour at
1 liter per ninute for 24 hours) using a timing switch to obtain
-~
representative
.j
daily samples,
Alternatively,.a
70w-f1ow (50 mi per
minute) pumpmay be used to sample continuously over 24 hours or intermittant~y over longer periods (3 to 7 days) to obtain a longer term,
average value. Method 68 can be applied as an emission monitoring
method by operating the equipnent automatically at the appropriate
emission points and analyzing the collected samples on-site.
Manpower requirements
are less
for Method 68.than
for Method 6 as
only one test train is operated at a.test point instead of the three
test runs that constitute aMethod 6 run. One person can p.repare fresh
chemicals, remove the used collection section, replace with the fresh
frain, and analyze the collected samplesin less than 1/2 day. The
0-12
training
Costs
necessary
of chemicals
is a knowledge of simple laboratory

and manpower should
be less
than
techniques.
$50 per test
Annual costs would range from about b3,000 for one point,
to 958,000
for multipoint,
daily
run.
weekly samples,
measurements.
0.2.2 GEMS
to Nonitor 50, Emission'sin Kilograms SO, Per Kilogram
CokeBurn-off Format. Monitoring502 emissions in kilogramsSOe

per 1,000 kilograms coke burn-off requires that the following parameters
be used
in the
ca'lcu~ation:
a Controldeviceexhaustgas S02(vppm)
a Control device exhaust gas C02 (vppm)
~ Control device exhaust gas 02 (vppm)
a Control
device-exhaust
gas
~ Control
device
gas velocity
exhaust
temperature
pressure
a Control device exhaust gas moisture
(percent)
a Controldevice inlet gas CD2(vppm)

~ Control
device
inlet
gas velocity
~ Control device
a Control device
inlet
inlet
gas moisture (percent)

gas CO(vppm)
a Control
inlet
gas
device
temperature
Air rate to FCCUcatalyst

Based on U~B experience
pressure
regenerator
(0 std conditions)
to date with GEMS,primarily
at steam
generators whereonly two parametersare measured(502 and diluent 02 or
C02)the reliability of a systemwith12 to 14parameters

wouldbe
extremely low. Sufficient information on the reliability
of the individual
components has not been obtained to allow an accurate predictit~n of this
reliability,
however.
The second major problem with monitoring
relative
accuracy of the GEMSisunknown.
format is that
the
Performance specifications
would need to be developed for such a system.

relative
in this
As with reliability,
accuracy of the GEMSwould be a function
the
of the combined errors
of the precision and accuracy of the various system componentstin

relation
to. the reference
methods).
Development of a new performance
specification would take a minimumof 3 years to propose. Notice of

intent to require such monitoring could be incorporated into the
regulation with applicability
automatically being delayed until proposal
and promulgation.
0-13
Thecapital cost to monitorS02in the kgS02per 1,000kg coke

burn-off format is estimated to be in the rangPof 9ao,oooto g100,ooo.
Theadditional costs beyondthose shownin Table0-i are for twovelocity

pressuremonitorsand a control deviceexhaustgas C02monitor.-The
or;herparameters itemized earlier are assumedto be installed for process
monitoringpurposes. Annualoperating costs wouldincrease slightly due
primarily to additional supp7ies required.
0.3
PERFORMANCE
TESTMETHODS
D.3.1
Stack
Emissions
- ii
Reference Method8, "Detern~inationof Sulfuric Acid Mist and Sulfur
DioxideEmissionsfromStationarySources,"in conjunctionwith Reference

Methods1, 2, 3, and 4, as require~, are recommended
for deteimining
sulfur oxides(50x)emissionsreportedas sulfur dioxide. Ii the recommended

standard is a concentration format (vppm),then Method8 wouldbe required
at
the
control
device
ij
exhaust.
Onemodification in the calcul8tion procedures specified in Method8

will be required to calculate the total sulfur oxides with sulfur dioxide
(S02) as the surrogate compound.Currently, Method8 specifies that the

isapropanol (including probe washand filterj analyses results be reported
as sulfuric acid.
To report the isopropanol (including probe wash and
filter) anal!sesresults as S02,the regulationshouldindicatethat

equation 8-3 be specified in Section 6.5 of MethodBin lieu of equation
8-2. The total sulfur oxides emission concentration as SO, would then
be calculated as the sumof the results from Sections 6.5 ~nd 6.6 of
Method
8.
Method8 has provisions [subject to Administrator approval) for
determiningfilterable particulate matter alongwith sulfur dioxideby

inserting a ?~ated filter betweenthe probe and isoprppanolimpinger.
Sufficient infomation is not currently available to recommend

an acceptable
analysis procedureto obtain total sulfur oxidesfromthis sampling
arrangement..Therefore,it is recommended
that the sourceuse separate
sampling trains to determine filterable
particulate
matter and total
sulfur oxides. Additional metnoddevelopmentwork is planned to determine

if an acceptable analytical
procedure can be specified.
0-14
.i
If the recommended
standard is in 3 kilogramSOxper 1,000 ki~ogram
coke Sum-off
fonnat,
then Reference Methods i, 2, 3, 4, and 6 would be
required at the control device exhaust to determine 502 emission rates
in kilogramsSo, per unit time. In addition, Methods

i, 2, 3, and4
would be required after the catalyst regenerator and prior to the control
device.
In addition,
the air flow rate
into the FCCUcatalyst
regenerator
would be required.
Calculation procedures for 50, emissions should be the sane as for

particulate
matter.
Since the particulate
matter NSPSrequires the
plant to supply the air flow rate (QRA)i"to the FCCU

catalyst regenerator,
it also should be acceptable for S02
The testing
performedby
EPA utilized
a modified Reference ~ethod a
procedureto determinethe S0g/S02ratio and to guard against interferences
due to possible
provides a detailed
free ammonia in the stack gas.
Section 0.1
discussion of the procedures used by ERA.
The cost for conducting a performance test using the procedures

above are estimated to range from 92,500 to $3,500, plus travel time,
travel costs, and subsistence.
The test would require three test runs
at each affected facility.
The test woul~drequire about 10 person days.
There would be no substantial
test
0.3.2
in either
Feed
emission
Sulfur
difference
in cost
to conduct
a performance
format.
Leve~l
A perfoimance test method which can be used on a continuing basis

is required to ensure that the sulfur content of the FCCUfeed is maintained
less
than a.certain
level.
The performance test
method needs to specify
the FCCUfeed sampling location,

the sampling frequency, the sample
sulfur content analysis method, and the procedure for applying the
analysis results to determine compliance with the standard.
The feed processed by an FCCUis a blend of feedstock streams
obtained directly from various process units (e.g., atmospheric and
vacuum distillation
units) or pumped from storage tanks.
These feedstock
components are termed fresh feed.

feedstocks
are combined
FCCUriser/reactor.
into
For many FCCUdesigns, the fresh
a single
feed
stream
for
However, for some FtCU designs,
0-15
injection
into
the fresh feed
the
components are injected
into the riser/reactor
at multiple
locations.
Prior to injectior, of the combinedfresh feed into the FtCU,manyrefiners

add a smallamount of recycle oil pumpedfrom the F~CUfractionator.
Presently, refiners routinely samplethe FCCU

fresh feed upstreamof the
point where recycle oil is added.
Because the addition of recycle oil
doesnot affect SOxemissions fromthe FCCU

regenera-tor, it is not
reasonable to require refiners to modifytheir FCCU
feed samplinglocations.
Therefore, the performancetest methodwouldrequire the samplingof the
FCCU
fresh feed. For~FCCVls
processi~g
a singlefresh feedstfeam,
refiners would be required to sample the~feed at only one location.
Wherethe fresh feed is injected into the FCCU

at multiple locations,
sampling
the fresh feedat eachlocationwouldbe necessary.
Refinerscan vary the FCCU
fresh feed crxnponenrs
and, thus, change
i :i
the sulfur contentof the fresh feedon a daily or evenhourlybasis.
?I~
turrently, most refiners manuallysamplethe FCCU

fresh feed once per
day. Automatedsampling equipmentfor sampling the ~ot, pressurized
FCCU
fresh feedhas not beendemonstrated.Consequently,
the required
frequencyat whichsamplesare to be collected must be comprehensiveto

ensure that fluctuations in FCCU
feed sulfur levels are measured,yet at
the sametime, be practical with'respect to manualsamplingtechniques.
AlthoughFCCU
fresh feed sulfur content maychangeon an hourly basis,
requiring samplesbe collected on'ceper hour is not practical using
manualsamplingtechniques. Analternative interval is to sampleonce
per 8-hour shift. This interval is frequent enoughto measuremajor
fluctuationsin the fresh feedsulfur level andis reasonableconsidering

current refinery sampling practices.
Therefore,
the performance
test
methodwould require the sampling of FCCU

fresh feed once every &hous
shift.
Refiners utilize a variety of analytical methodsfor determining

the sulfur content of the FCCUfresh feed. The type of methods used can
vary fromone refiner to another. For compliancepurposes, a performance

test method needs to be specified which will give consistent
results
for
all refiners. TheAmericanSociety for Testing and Materials (ASTM)

has
specified
four analytical
test
methods for detemination
D-1S
of sulfur
in
.J
petroleum products. These are ASTM0129 (General BombMethod),, ASTM01266

(LampMethod), ASTM01552 (High Temperature Method), and ASM 02622
(X-Ray~Spectrographic Method). Selection of the~ASTMmethod to be used
for compliance determination
and cost.
All four
repeatability
test
feed
are comparable.
sulfur
a refiner
results
The analytical
Consequently,
in terms of repeatability
to allow
yield
is presently used by refiners
analyses.
methods
results
of the ASTMmethods
and reproducibi7ity.
perform these tests

of routine
is based on repeatability,
to'utilize
the~costr
Since
all
four
similar
required
to
to perform other types
of using the different

AST~1methods
any one of the four
0-17
having
equipnent
and reproducibility,
deteninations.
reproducibility,
yield
it-is
methods
for
similar
reasonable
FCCU fresh
0.4
i.
REFERENCES
Test Report, Entropy Environmentalist,

Reference
2.
Inc., April 1980. Docket
II-A-19.,
Federal Register, Vol. 46, No. 16, January 26, 1981, Page 8352.
Docket
3.
Number
Reference
Telecon.
DuPont.
Number
II-I-2.f
Norwood, T.L., TRW,Incorporated,

February 12, 1981.
Price quotation
with Whitmore, C.,

for a DuPont ~odel
460 S02 monitor. Docket Reference NumberII-E-6.+

4.
'1
Letter and Attachments from Zweben, R., Contraves Coerz Corporation

to Norwood, T., TRW, Inc.
February 23, 1981. Price quotation for
an SO /CO in-situ monitor with remote display.
Docket Reference
Numbe~
I1?0~6~*~5.
Sednan,Charles a. Sulfur DioxideEmissionData For ~n Industrial
Boiler NewSource Performance Standard. ~ ~Presented at EPASymposium

on Flue Cas Desulfurization,
EPA 600/9-81-019,
6.
Letter
Docket
and Attachments
Houston, Texas, October 28-31, 1980.)
Reference
F~umber rI-A-20.+
from White, R.L., Texas Utilities
Generating
Companyto Sedman, C.B., U.S. Environmental Protection Agency.

January
16, 1979.
Response
DuPont 463 stack monitoring
fReferences
can be located
to request
system.
for
information
on the
Docket Reference Number II-D-63.f
in Docket Number A-79-09 at the U.S. Environmental
Protection Agency Library, Waterride Mall, Washington, O.C.
0-18
APPENDIX E'
PROJECTED GROWTHINFCCU CAPACITY
E-l
APPENDIX E.
E.1
PROJECTED GROWTHI~ FCCU CAPACITY
INTRODUCTION
The number of new, modified,

over the five-year
section.
period
and reconstructed
from 1982 througn
These projections
FCCunits
anticipated
1985 is determined
are used in Chapters
in this
7, 8, and 9 to detor-
mine the environmental, energy, and economic impacts of the regulatory

alternatives.
E.2
HISTORICAL
FCC GROWTH DATA
Total nationwide growth in FCCfresh feed capacity
is dependent
upon three factors; newunit construction, increases to existing

capacities,
and decreases
s hutdown.
changes
to existing
By reviewing available
in refinery
estimation
literature
FCC throughput
of total
capacities
due to removal or
and recording the individual
capacities
from 1971 to 1980 an
nationwide growth in FCC fresh feed capacity
was
made.
FCCfresh feed capacities
Table E-l.
for the years 1971 to 1980 are shown in
As the table indicates, nationwide FCCfresh feed capacity

3
has increased from about 616,200 m /sd in 1971 to 803,900 m /sd in

1980.
1-11
This'representsa net growthof approximately

187,900m3/rd.
This net growth includes not only capacity
increases
due to new unit
construction and throughput increases but also, decreases in capacity

caused by plant closures and decreases in individual FCCthroughput.
To accurately represent gross nationwide FCCfresh feed capacity
increases
existing
from 1971 to 1980, new unit

capacity
must account
construction
for plant
closures
and increases
or decreases
to
in
capacity.
The decrease in capacity from 1971 to 1980 war approximately

64,500
m3/,d1-11 or an average annual decrease of about 7,200 m3/sd-yr.
Gross nationwide FCCcapacity increases are deten~ninedby adding the

total
1971 to i980 decreases
Thus,
in this
time period,
to the 1971 to 1980 net capacity

new unit
construction
and increases
increase.
to
existing capacity (gross nationwide growth) amountedto 252,300m3/sd.

E-2
'~
TABLE E-l.
U.S.
1971-1980
FCCU FRESH FEED CAPACITY

(January
1)
1-11
YEAR
FRESH FEED CAPACITYm /sd
1971
616,164
1972
634,332
1973
641,531
1974
673,052
1975
692,075
1976
706,529
1977
735,589
1978
739,827
1979
759,021
1980
803-,929
E-3
Table E-2 lists
FCCunit regenerator
new unit construction
from
1971 to 1980. During this periodi 18 new FCCunits were cons.tructed,

or an average
of approximately
2 new units
per year.
The FCC fresh
feedcapacity
increase
dueto this newunitconstruction
was97,500
m3/sd,
or approximately 39 percent of the gross nationwide capacity
The remaining 61 percentof
increase.
the gross nationwide capacity increase,
approximately154,800m'/sd, were attributable to increases in existing

capacity. In the 5-year period from 1975to 1980, 70 different existing
units contributed
Figure
constructed
most
8,000
E.3
to these gross nationwide FCCcapacity
E-l presents
m /sd,
the size
between 1971 and 1980.
common new units

3
and 12,000
constructed
3
d~stribution
of the new FCC units
As the figure
had
illustrates,
the
capacities near i,500 m3/sd,
m /sd.
s~
A 5-year growth projection of FCC'fresh feed capacity can be

obtained if a linear approximation is made using a least-squares fit
to the historical
FCCfresh feed capacity data. The result of the
linear approximation is graphically presented in Figure E-2. The

projected annual capacities generated by the linear approximation are
presented in Table E-3. As the table indicates, FCCfresh feed capacity
is expectedto increase fromappr~ximately828,500m3/sdin 1982to

927,100m"/sd in 1987. This represent~sa projected net growth of
98,600 m"/sd from 1982 to 1987. To account for projected decreases in
capacity caused by plant closures or decreases in individual refinery

capacity, it is assumed that the projected average annual decrease in
FCCthr5~ughputis thesame as the historical decrease in capacity,
7,200 m'/sd-yr. The resulting gross FCCfresh feed capacity increase

due to new unit construction
and increases
to existing
plants
is about
m'/sd
Growth due strictly to new unit construction is determined by

assuming that about 39 percent of the gross nationwide FCCcapacity
growth is due to new unit construction.
This reflects
the historical
constructionpattern. Between1982and 1987,about52,150m3/sd

the gross FCCcapacity growth may be provided by new units.
units
are fabricated
:i
increases.
FIVE-YEARGROWTH
PROJECTION
134,500
each year between-1982
E-4
and 1987, a total
of
If 2 new
of
TABLE E-2.
FCCU REGENERATOR
NEWUNIT CONSTRUCTION
1971-
1980
1-11
FRESH
YEAR
.
UNIT
RND
LOtATION
1971
Gulf Oil Co~pany,Belle
1972
Mobil Oil Corporation, Joliet,
1973
FEED
tAPAtITY
m3isd
Chasse, LA
'11,446
IL
Mobil Oil Corporation,
Beaumont, TX
Conoco, Commerce City,
CO
10,492
8,743
2,226
Sun Oil Company,Toledo, Ohio .
7,949
Conoco, Ponca City,
4,759
OK
Arizona Fuels Corporation,
Roosevelt,
1974
Good Hope Rfg., Good Hope, LA

Texas City Rfg., Texas City, TX
1975
No New Units
UT
954
2,385
4, 292
--
--
1976
Navajo Refining, Artesia, NM

Champlin Petroleum Corporation, Corpus-Christi,
1977
1478
No New Units
1979
GoodHope Rfg., Good Hope, W

Plateau
Incorporated,
Conoco, Lake Charles,
TX
827
6,518
Bloomfield,
7,631
NM
LA
795
4,864
Marathon Oil Company,Garyville, LA

MurphyOil Corpotation, Meraux, LA
11,923
3,942
Placid Rf~., Port Alien, LA
2,623
DiamondShamrock Corporation, Sunray, TX
5,167
E-5
;I!
z
~
cn
3-5
NEW UNIT
5-7
7-9
CAPACITI~S
9-11
11-/3
1971-1980
(1000 M3/SDJ
S17E DISIÌ(IIIUTION
OF NEWUNITSCONSTRUCTED
DETUEEN
1911 dnd IY00
:...:
i.
li_L~
k.-: J
I.U
ACTUAL CAPACITY
09 1
----
PROJECTfD
CAPACITY
LEASTS9UARE
FIT TO 1971-1980 OATA
mh 0.8
0.1
0.6
~
m
0.5
-_
0.a
o.~
0.2
0.1
1971 1972 1973 1974 1975 '7r
1977 1978 19)9 1900 1901 1902 )903 1984 191351986 1907
YEAR
rigllre E-2. PIojccted(!.S~FCCFresh Feed Capacity
TABLE E-3.
PROJECTEDU.S.
FCCU FRESH FEED CAPACITY
1981
-1987
YEAR
FRES~
FEED
CAPACITY
m3/sd
;981
808,740
1982
828,470
1983
848,200
I,!
1984
'
867,940
~985
887,570
1986
90 7,400
1987
927,130
FOR PRr3JECTION: CAPACITY=19731. 8'(YEAR)-38279992

Based on a least
capacity
data
squares
from
E18
1971
linear
to
1980
fit
to
i_.$
10 new units
will
of new units
built
be in operation
between
1971
by 1987.
and
Based on the
1980,
these
size
new units
distribution
will
have
capacitiesof about2,500,3/5band8,000n3/5j. Fiveof eachPf

these
units
are
expected
The remaining
to
be constructed.
portion
of the gross
nationwide
FCC capacity
growth,
82,000m3/sd,is attributableto increasesin existingcapacity. As

many as 70 units
may contribute
number,
however,
does not reflect
capital
expenditure,-which
modification
five
units
tion
which
would
been
become
subject
Of the
modifications
twelve
or
This
without
from the
to
On this
10' percent
of the 70 potential
Thus,
seven
units
after
proposal
only
years
distribution
reconstruction
reconstructions
capacity
an estimate
contacted,
regenerator
in the
of the number of
modification
refiners
and
12-27
pr air
reconstruc-
two performed
blower
The other
which could
refiners
increased
upstream or downstream from the FCCU

basis
it
units
would modify
are expected
of
the
FCC unit
reconstructions.
by debottlenecking
regenerator.
The
exempted
to provide
to the FCCU catalyst
throughput
five
increases.
in capacity
who have increased
was conducted
provisions,
catalyst
increases
is specifically
of refiners
years
alterations
have
capacity
provisions.
A survey
last
to these
was concluded
to modify
that
only
about
or reconstruct.
or reconstruct
in the
of the standard.
unit
was determined
are more likely
sizes
involved
by observing
to occur
in
that
with
modification
modifications
large
FCt units.
and
and
On
this basis, it wasspecifiedthat five units *ith a,~0083/5dcapacity

and two units
modified
between
with
2,500 m'/sd
1982
and
capacity
1987.
E-9
would be reconstructed
or
E.4
REFERENCES
1.
Cantrell,
A. Annual Refining Survey Oil and Gas Journal.
78(12):130-157,
March 24, 1980. Docket Reference Number II-I-71.R
2.
.Cantrell,
68(14).

April 6, 1970. Docket Reference Flumber 11-1-3."
3.
Cantrell,
69(12):73.
March 22, 1971. Docket Reference Number11-1-5.'
4.
Cantrell,
A. Annual Refining
70(13):84.
March 27, 1972.
Survey.
Docket Reference Number IZ-I-6.*
5.
Cantrell,
71(14).
A. Annual Refin~ng Survey.

April 2, 1973. Docket Reference Number II-I-10.,
6.
Cantrell,
72(13).

April 1, 1974. Docket Reference Number 11-1-13.'
7.
Cantrell,
A. Annual Refining Survey,
73(14):98.
April 7, 1975.' Docket Reference Number II-I-16.+
8.
Cantrell,
74(13):129,
March 29, 1976. Docket Reference Number II-I-23.*
9.
Cantrell,
A. Annual Refining
75(13):98.
March 28, 1977.
10.
Cantrell,
A. Annual Refining~Su'rvey.
011 and Gas Journal.
76(12):113.
March 20, 1978. Docket Reference Number 11-1-37."
11.
tantrell,
A. Annual Refining
77(3):127.
12.
March 26, 1979.
Survey.
Docket Reference Number I~-I129.f
Survey.
Docket Reference Number TI-I157.f
Telecon.
Bernstein,
Inc.
with Parks, P.D., Texas City Refining, Int.
January 29, 1981.
Increases in reported FCC capacity.
13. Telecon. Bernstein, 6., Pacific EnvironmentalServices, rnc.

with Childs, L., Phillips
14.
Increases
in reported
Telecon.
Bernstein,
with Holder,
in reported
15.
Petroleum Company. January 29, 1981.
FCC capacity.
Docket Reference
Number II-E-I.*
L., Charter
FCC capacity.
Oil Company.
Docket
January 29, 1981.
Reference
Inc.
Increases
Number IIIE-1.*
Telecon. Bernstein, G., Pacific Environmental Services, Inc.

with Mobetia, P., Ashland Petroleum Company. january 29, 1981.
Increases
in reportedFCC
capacity.
E-10
Docket Reference
Number II-E-1.+
16.
Telecon.
Bernstein,
G., Pacific
Environmental
Services,
Inc.
with Daniels,
J., ARCOHouston Refinery.
January 29, 1981.
Increases
Number
17.
18.
in reported
FCC capacity.
Telecon. aernstein,
G., Pacific Environmental Services, Inc.
with Laque, W.E., Rock Island Refining Corporation.
January 29,
1981.
Increases
Number
II-E-1."
in reported
Increases
Pacific
in
Docket Reference F~umberII-E-l.f
in reported
FCC capacity.
Docket Reference
II-E-l.f
Telecon.
Segar, T., Koch Refining Company with8ernstein,
Pacific
Environmental
in reported
21.
Docket Reference
Telecon.
Bernstein,
G., Pacific
Envi~onmental
Services,
Inc.
with Scharff,
D., Champlin Oil Company. February 2, 1981.
Number
20.
FCC capacity.
Telecon.
Clodi, C., Mobil Oil Company with Bernstein,
6.,
Environmental
Services,
Inc.
January 29, 1981.
Increases
reported FCCcapacity.
19.
Docket Reference
IE-E-1.*
Telecon.
Services,
FCC capacity.
6ernstein,
Inc.
February
6.,
4, 1981.
Increases
Docket Reference Number II-E-1I*
6.,
Pacific
Environmental
Services,
Inc.,
with Arnett, D., Amoco Oil Company. February 5, 1981. Increases

in reported FCC capacity.
Docket Reference Number II-E-1.*
22. - Telecon, Ebbeses, R., Amoco Oil Company with Bernstein,
G.,
Pacific
Environmental
Services,
Inc.
February 5, 1981. Increases
in reported
23.
FCC capacity;
Tef econ.
Edmunsen, J., Chevron U.S.A., Inc. with Bernstein-,
6.,
Pacific
Environmental
Services,
Inc.
February 11, 1981.
Increases
in reported FCCcapacity.
24.
Letter
and Attachments
Docket Reference NumberII-E-1.*
from Prichard,
J.J.,
Ashland
Company to Goodwin, D.R., U.S. Environmental
Petroleum
Protection
Agency.
May27, 1981. Response to Section 114 information request.

25.
Docket
Reference
Number
Letter
and Attachments
II-0-53.,
from Larson,
W.E.,
Chevron U.S.A.,
Inc.
Goodwin, D.R., 6.5. Environmental Protection Agency. March 24,

1981. Response to Section 114 info~mation request.
Docket
Referenc'e
26.
Letter
Plumber II-0-42.f
and Attachments
from Adams, J.T.,
Jr.,
ARCOPetroleum
Products Company to Goodwin, D.R., U.S. Environmental
Protection
Agency. April 3, 1981. Response to Section 114 information

request.
Oocket Reference Number II-D-43.*
E-ll
to
27. Letter and AttachmentsfromAlbaugh,D., MarathonOil Company

to
Goodwin,D.R., U.S. EnvironmentalProtection Agency. March20,
Reference
Number
II-D-41.*
Docket
--
+References can be l.ocated in Docket Number A-79-09 at the U.S.
Environmental
Protection AgencyLibrary, 'nlatersideMall,Washington,D.C.
E-12
APPENDLX
Analysisof HeavyOil CrackerSOxEmissions

and
Control
F--l
Costs
APPE~IDIX
F. ANALYSIS
3FHEAVY
OILCRACKER
SOx
EMISSIONS AND CONTROL COSTS
F.1
INTRODUCTION
Heavyoil crackers (HOCls)are fluid catalytic cracking (FCC)

units that process residual and other heavy oil feedstocks.
These HOC
feedstocks contain complexsulfur compoundswhich typically form coke.

As a result, a greater portion of the sulfur in HOCfeedstocks forms
coke than FCCgas oil feeds.
In addition,
HOCfeedst~cks have a
higher coke nake rate than gas oil feeds. Thus, sulfur oxides
maySe greater fromHOC
units than fromother other FCCunits.
emiss~ons
Therefore,
sulfur oxides control costs may differ for HOCand other FCCunits.
these reasons, industry representatives
:a
ior
commentedthat HOC'sshould be
consideredsep8ratelyfromother FCCunits for development

of a suifur
oxides
emissions
standard.
Appendix F analyzes sulfur oxides emissions and emissions control
costs for HOC'scontrolled by sodium-basedscrubbers. This analysis

was performedto determineif HOClsshould be considered separately
from FCCunits for developmentof a sulfur oxides emissions limit.
In
addition, results of this analysis are appropriate for asphalt residual
treating(ART)
SOx
controlcosts.l
F.2 HDC
MOOEL
PLANT
SOxEMISSIONS
HOC
modelplants were developedbased on info~ation providedby
anHOC
operator.2
Operating
parameters
wereprovided
asa rangeand
are presented in Table F-l.
The parameters used to develop ~OCmodel
plants~were selected from this range.
HOCmodel plantswere constructed in the sameway as FCCunit
modelplants, discussedin Chapter6. HOC

modelplant flue gas compositions
and flow rates were calculated by selecting the coke compositionand
formation rate from Table F-l, and by calculating the amountof air
required
to
oxidize
the
coke.
Modelplant sulfur oxides emissions are dependentuponparameter

selection. Since most of the HOCoperating parameterswere provided
as a range, it is necessary to determine the sensitivity of model
plant sulfur oxidesemissionsto parameterselection. This wasaccompiished

by varying one parameterat a time, selecting the highest and lowest
F-2
Table
F-l.
ASSUMPTIONSUSED TO DEVELOPHOC
MODEL PLANTS
Combustion
Air Composition
02 c0"tent = 20 percent
H,O content
--
1.2 percent
N2content P 78.2 percent

Flue Gas Composition
Excess02 content 1 2 percent

:i
COcontent~
negligible
Nonhydrotreated Feeds
Hydrotreated Feeds
Feedstock
Densi ty
Su~fur contenta
900 kg/m3
1-4 weight percent
900kg/m3
0.3-0.45 weight percent
CokeCompositiona
Sulfur content
2.75 x feedstock
sulfur
Coke make rate
Coke hydrogen content

a~eference
content
8-15 weight ~ercent
Not available
2.
F-3
3 to 3.5 x feedstock
su~fur
content
8-12 weight percent
5-8 weight percent
value for the parameter, then calculating HOCmodel plant emissions.
HOC
modelplant parametersused and results of the sensitivity analysis
are presented in Table F-2.
The parameters which were varied are feed
sulfur content (Case i), coke sulfur content (Case 2), coke make rat~
(Case 3), and coke hydrogen content (Case 4).
Results of the sensitivity analysis showthat HOC

modelplant
sulfur oxides emissions are npst sensitive to the feed sulfur content.
From
Table
F-2,HOC
m~del
plantsulfur
o~ides
missions
range
irlm
530vppm(17.9 kg/1,000kg cokeburn-off) to 6,500vppn(209kg/l,ODO

kg
coke burn-off).
F.3 HOC
MODEL
PLANT
CONTROL
COSTS
Sulfur prides control costs were developed for the HOCmodel
plants by using model plant flue gas characteristics and the costs and
assumptions presented in Chapter 8 for sodium-basedscrubbers. For
'iD
s:~
thi5 analysis, utility costs are assumedproportional to the HOC

model
plant air flow rate to the scrubber. Nocredit was taken in this
analysis for scrubber particulate control.
represent
a c~nservative
estimate
of control
:~
Therefore, the res~lts

costs.
Results of the cost analysis~are presented in Table F-3 for each
of the HOC
modelplants developedand represent an analysis of the
sensi'tivityof controlcoststo HOtmodelplantparameter

selection.
jli
:i
Annualcosts for the sodium-basedscrubber.rangefrom about 88 million

for Case 2A to 820 million for Case 18. Cost effectiveness for the
HOC
modelplants rangesfrom$39~/M9
SD,removed
for Case1Bto about
g1,600/Mg
SO,removed
for Case1A.
For comparison,
the cost-effectiveness
values
reported
inChapfer
8 forsodium-based
scrubbers
applied
to FCC
units processinggas oils range from8400to 65,OBO/Mg
SOX removed.
This analysis shows that HOCsulfur oxides control costs,
in
terms
of
cost effectiveness, are rimilar to FCtcontrol cPsts. As such, this

analysis does not support the developmentof separate regulatory
alternatives
for
HOC's.
Annual sulfur oxides cont;u' costs for the high feed sulfur HOC
model plant (Case 18) are $20 million.
The corresponding cost
effectivenessfor this modelplant is $390/M9

SO,removed.ThisHOC
modelplant is based on high sulfur residual feeds. Thesefeeds, and
F-4
Table
F-2.
SENSITIVITY
ANALYSIS,
PARAMETEHS
USEDAND
HOC MODELPLANT
RESULTING
SOxEMISSIONS
____-~-------------~Feedstock
Sulfur
Content,
ModelPlant
height
Cast! Size,In3/sd Percent
71
cn
Coke Make
Rate, Gleight
Percento~
FreshFeed
r0
Emissions
~gTT;bo~i~TSr~----_CokeCanposltlon(wt_.)
Ilydroyen
Sl~lfurCarbon Coke
Ounl-off vppn
Base
1A
0,000
8,01)1)
1.5
0.3
10
10
6.5
6.5
4.5
0.9
89
92.6
89.7
17.0
2,700
530
10
B,OUO
3.5
10
6.5
10.5
83
204
6.500
2A
8,0110
1.5
10
6.5
4.1
0~.4
29
34
8,000
B,nll0~
i.s
1.5
10
8
6.5
lj~5
5.3
4.5
88.2
89
39
8,000
1.5
12
65
4.5
89
4A
8,000
1.5
10
4.5
49
8,oau
io
4.5
___
82.3
105
09.7
Co~nlnents
Change in feetl sulfur
content.
Cl,ancJe in coke sulfur
content.
2,500
3.200
2,100
89.7
2.700
30.5
09.7
2,800
81.5
89.7
2.600
ChallcJe In coke IIIJke rate.
,
CllancJe in coke hydrogen conte~~t.
Table F-3. HOCMODEL

PLANT
CONTROL
COSTS
ANDCOSTEFFECTIVENESS"
Air FlowRate SOxEmission Annual

into
Scrubber
Reduction
Cost
Cost Effectiveness Percent Change
Case
Sm3/minMg/yr
BASE
6,340
20,500
9,500
460
1A
6,500
2.000
3,100
1,570
18
6,130
51,300
20,200
390
24
6.359
18,500
8,000
400
28
6,310
24,300
10,800
450
-2
3A
5,070
16,400
7,800
38
7,610
24,600
11,200
450
-2
4A
6.130
20,600
9,500
460
48
6,550
20,400
9,500
476
)1,000's
8/~(9
SOx
Relroved from
Base
240
-
-15
480~----~
Costsprovidt?d
arebasedoncontrolling
ellissions
to Regulatory
Alternative
1I1,300vppm.
:. :.:
I:
;1..J
L- i
L~;LIJ
crudes from which they are derived, are typically sold to refiners
a reduced cost.
Therefore, the high annual control costs forthis
model plant would be offset by the lower crude costs.

doubtful
that
HOC's would process
hydrotreating.
at
Secondly, it is
these heavy feedstocks
without
Hydrotreating would reduce the sulfur content of the
feedstock
and,- tfieref'ore,
emissions
control.
reduce the annual cost of sulfur
F17
oxides
F.4
REFERENCES
i.
Menorandum
from Gernstein, George, Pacific EnvironmentalServices,
rnc., to DocketA-79-09. September20, 1982. Similarity in
Control Costs between Heavy Oil Crackers and the Asphalt Residual
Treating
2.
Process.
Docket Reference Number II-B-29.*
Telecon. Barrett, J., Phillips Petroleun ompany,

;rifh Bernstein,
G., Pacific EnvironmentalServices, :ncorporated. February 22,

1982.
Docket Reference Number iI-E-7.+
"References can be located in Docket NumberA-79-09at the U.S. Environnental

Protection AgencyLibrary, Waterside Mall, Washington,O.C.
F-8

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Office

Planning and Standards

Triangle Park NC 27711

Fluid Catalytic Cracking

Fluid Catalytic Cracking

Office of Air Quality Planning and Standards

Park, North Carolina 27711

5285 Port Royal Road, Springfield,

for a fee, from

ENVIRONMENTAL PROTECTION AGENCY

Emission Standards and Engineering Div~sion

Park,. North Carol:ina.

from new, modified,

cracking unit regenerators.

public health or welfare."

EPA Regions V, VI, and IX ate particularly

Copies of thi s document; have been ~sent to the followi ng Federal

and Energy; the National Science

The cormnent period for review of this document is 75 days.

U.S. EPA Library

5285 Port Royal Road

(Pleose rend Inaruclions on Ihr reverse be/o~e complering~

Su'lfur Oxides Emissions

Cracking Urlit Regenerators - Background Information

for Proposed Standards

Is. PERFORMING ORGANIZATION REPORT NO.

.PERFORMING ORGANIZATION NAME ANO AOORESS

Office of Air Quality

110. PROGRAM ELEMENT NO.

Planning and Standards

Research Triangle Park, ~NorthCarolina 277'11

DAAfor Air guality

J1B.I~VPE OF REPORT AND PERIOD COVERED

Planning 'and Standards

~esearch Triangle Park, North Carolina 27711

modified.andreconstructedfluid catalytic crackingunit regenerarorsare being

and economi c impacts of the regulatory

KEY ~NORDS AND DOCUMENT ANALYSIS

b.lDENTIFIERSIOPEN ENDED TERMS IC. COSATI FieldlCroup

Air Pollution Central

2~. NO. OP PAGES

Environmental Impacts ...

Water and Solid

1.2.3 Energy Impacts

Background and Authority far Standards ......

Procedure for Development of Standards of

Impact on Existing Sources ......

THE CATALYTICCRACKINGUNIT PROCESSAND

from FCC Regenerators .....

EMISSION CONTROLTECHNZqUES .....,........

of FGD Systems to FCC

FGD Systems .,.,,,,,,

FGD Systems ,,,,,,,,,.

Spray Drying FGD Systems

for Reducing FCC Regenerator

4.2.7 Citrate-Based FGDSystems ,,,,,,,,,

Sodium-Based FGD Systems

and Replacement ...

Increasing Capacity. ...........

Change in FCCFeedstock Qua7ity. .....

Addition or Replacement of Regenerator

System to Control Air Pollutants

Regulatory Alternative IZ. ........

6.3 References. .....