Document 0gjRz0bD9xN7ZR6jGnqqMwEeO

Interoffice Communication To From Date Subject Distribution D. A. Kuhn Decembe r 2 1, 1977 EPA Benzene Standard (Conoco) DEC 22 till In a conversation with Dave Patrick of EPA on December 19* 1977, I learned that a benzene emission control standard for alkylbenzene manufacture has low priority with the EPA. Patrick is in charge of developing standards for benzene and works for 'Don Goodwin, at Research Triangle Park. It is EPA's opinion that the emissions for alkylbenzene produc tion are quite low. Many other sources and processes represert much greater potential for public exposure and so will be regu lated first. Patrick cited automobiles as the largest source of community exposure to benzene, followed by petroleum product's distribution and marketing. Petroleum production and refining are low priority because benzene emissions are thought to be small. Only six chemical processes are scheduled for study now. Maleic anhydride is the most important because it is an oxidation process where the exit vent contains large quantities of benzene vapor. A draft proposal will be available in April,1978. EPA will also seedy manufacture of nitrobenzene, ethylbenzene, styrene, cyclohexane! an c ethy1ene.EPA1s ethylene study will concentrate on its manufacture from heavy feedstocks. EPA is apparently somewhat overwhelmed with the enormity of the task of regulating benzene. The rulemaking proceedings may extend over a lengthy period. Probably the earliest impact at Conoco will be felt in marketing with the refining in chemicals deferred quite far into the future. Patrick mentioned a possibil ity that a common standard for benzene storage could be promul gated early. It would seem prudent for us to concentrate our first efforts on that aspect of controlling benzene emissions. I offered our help to produce a good quality standard.Patrick declined to accept it just now because it is too early in the game. He did say he was going to send Chemicals a 114 letter asking a few questions about alkylbenzene production. I agreed to touch base with him from time to time to learn his progress and find out when we should begin working with him. MCD 000001816 Distribution Page 2 December 21, 1977 If any of the recipients of this letter would like to talk with please give me a call. ke -Distribution Dick Darling Debs Gamb1in Don Sanders/ R . E . Lehmkuh1 Jack E. Cear1ey 0. Roy Ba r res i Dennis Boesha rt Don R. Bonberger R. L. Johnson Aus tin McC1oud Gordon Regan R. M. Robin son Cora 11e Sanders Don B. Eicher Ray C. Allred J. J. Doyle Art F. Gallagher Ken C. Hunt Oran D. Steffey C. L. Whetstone, M. D. mcd OOOOOlBlf