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MODEL PLANT WITH CATALYST EXTRACTION
UNCONTROLLED COMPONENTS FOR LDAR PROGRAM
Equipment
Tvoe
Total Number
Total with
HON Level of
Control
Compressors i 01 0
Open-ended
Lines
Sampling
Connections
Pressure
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Devices
valves in
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vatves in
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263
13
110
315
906
24
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18
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Total Number
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176
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116
12
67
113
435
11
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Average
Number
Uncontrolled
o:
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6
34
57
218
5
2191
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MODEL PLANT WITH CATALYST EXTRACTION
UNCONTROLLED COMPONENTS FOR LDAR PROGRAM
Equipment
Tvoe
Compressors
Open-ended
Lines
Sampling
Connections
Pressure
Relief
Devices
valves in
Vapor
Service
valves in
Light Liquid
Service
Pumps in
Light Liquid
Service
Connectors
Total Number
0
263
13
110
315
906
24
Total with
HON Level of
Control
Total with
HON
Equivalent
Control
Total Number
Uncontrolled
l
Average
Number
Uncontrolled
oi oi oi o:
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0
25
18
4
1988! 616.28
147
1
43
176
453
9
116
12
67
113
435
11
934 i ' 437
58 i
1
6
34!
57\
218
5
2191
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MODEL PLANT WITH CATALYST EXTRACTION
INPUT TABLE FOR LDAR PROGRAM COSTS
Equipment Type
Total
Uncontrolled
Compressors
Open-ended Lines
Sampling Connections
Pressure Relief Devices
Valves in Gas/Vapor Service
Valves in Light Liquid Service
Pump Seals in Light Liquid Service
Connectors
Total Components
0
58
6
34
57
218
5
219
597
Control Equipment
Monitoring Instrument
Replacement Pump Seal
Compressor
Pressure Relief Device
Rupture Disk
Holders, Valves, Installation, etc.
Open-ended Lines
Sample Connections
Base Cost
(Juiv1989$)
6,500
180
6,240
78
3,852
102J
408!
Initial Leak Detection and Repair
Program
Value
Monitoring Fee ($/component)
Initial Leak Frequency (fraction)
Valves in Gas/Vapor Service
Valves in Light Liquid Service
Pump Seals in Light Liquid Service
Connectors
Leaks Requiring Further Repair
Valves
Connectors
Pumps
Hours for Repairs
Valves
Pumps
Connectors
2.5
0.114
0.065
0.2
0.021
0.25
0.25
0.75
4
16
2
-------
MODEL PLANT WITH CATALYST EXTRACTION
INPUT TABLE FOR LDAR PROGRAM COSTS
Annual Leak Detection and Repair
Program
Value
Monitoring Fee ($/component)
Additional Pump Monitoring Time (hr)
Initial Leak Frequency (fraction)
Valves in Gas/Vapor Service
Valves in Light Liquid Service
Pump Seals in Light Liquid Service
Connectors
Leaks Requiring Further Repair
Valves
Connectors
Pumps
2
0.0083
0.02
0.02
0.1
0.005
0.25
0.25
0.75
Maintenance Program
Value
Calibration/Maintenance for Monitoring
Instrument (July 1989$)
Annual Maintenance Charge for
Compressors, Pressure Relief Devices,
Open-ended Lines, and Sampling
Connections (percent of capital costs)
Replacement Pump Seal Cost (July
1989$)
Miscellaneous Charges for
Compressors, Pressure Relief Devices,
Open-ended Lines, and Sampling
Connections (percent of capital costs)
Miscellaneous Charges for Pump Seals
(percent of capital costs)
$4,280.00
5
$180.00
4
80
Economic Data
Value
Interest Rate
Economic Life (years)
Pump Seals
Rupture Disks
Monitoring Instrument
All Other Equipment
CRF Values
2 Years
6 Years
10 Years
Chemical Engineering Plant Cost Index
July 1989
August 1996
Recovery Credit
Average Emission Reduction (Mg/yr)
Raw Material Cost (July 1989$/Mg)
Labor Rate ($/hour)
0.07
2
2
6
10
0.5531
0.2099
0.1425
356.0
382.1
10.4
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ATTACHMENT 8
CALCULATION OF STEAM STRIPPER COSTS
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Calculation Methodology Description
Steam Stripper Costs
From the EPA/SPI questionnaires responses, it was determined
that only two facilities have Group 1 wastewater streams. As
both of these facilities would fall under the classification, of a
large model plant, it was assumed that small and catalyst
extraction model plants do not have Group 1 wastewater streams.
Consequently, the average of the wastewater flow rates reported
by the two large facilities was used to estimate steam stripper
costs for large model plants.
The HON wastewater spreadsheet was used to calculate the
cost of the steam stripper.
-------
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A. CAPITAL COSTS
1) Steam Stopper Column
Di = inside diameter, ft = 1.3
Lt TI = tangent-to-tang length. ft= 29.0
Ts = est wall thickness, ft = 0.0521
rno(ss304), Jb/ft*3 = 501
Weight of the column:
Ws = pi'Di( Tl * 0.8116*Di)Ts*mo
Ws. Ib = 3.286
BE SURE WEIGHT. DIAMETER. AND TOWER HEIGHT ARE WITHIN THE LIMITS
FOR ALL EQUATIONS
The weight equation for calculating steam stnpper column cost
is the same for carbon and stainless steel, but the densities of
the two metals are different.
- density of carOon steel = 490 lb/ft*3
- density of stainless steel = 501 fb/ft*3
a. Chemical Engineering Magazine. December 28. 1981. pg. 180.
COST INDEX = 230.9
-Shell, skirts, nozzles, and manholes
Cbs = exp{6.823 + 0.14178 (In Ws) •»• 0.02468 (In Ws)*2]
9020 Ib < Ws < 2.470.000 Ib
WEIGHT TOO SMALL
Cbs. S = . 14,608
Cbs(304ss). S = Cbs'Xcol = 43971
Xcol.304ss = 3.01 (Based on Vendor data)
-Platforms and Ladders
Cbp = 151.81*01*0.63316^1*0.80161
3 ft < Oi < 24 ft : 57.5 ft< U < 170 ft
DIAMETER TOO SMALL
LENGTH TOO SHORT
Cbp, $ * 2707
-Cost of Trays - 304 stainless sieve trays
Cbt = (Number of trays)'278.38*exp(0.1739*0]
2ft
-------
STEAM STRIPPER COSTING PROCEDURE: BASED
ON ASPEN PRINTOUT - 300LPM (80GPM) CASE
STEAM/FEED RATIO. KG STEAM/KG WW-
WASTEWATER FEED RATE. GPM:
TAG:
FLOW RATES TCI:
FEED FLOW. KG/HR:
BOTTOMS FLOW. KG^WR:
STEAM FLOW, KG^R:
OVERHEAD FLOW.KGMR:
PRI COND H2O, KG/S:
0.040
16.7750
S111.150
S415,586
0.333818375
3802.33
3766.19215
152.182596
188.318694
3.82909831
GPM:
GPM:
tCWhr
GPM:
GPM:
16.8
16.6
426415.6
0.8
60.8
TDAC S34.830
TIAC $76.320
DENSITY H2O = 8.33lb/gal
DENSITY Steam = 8.00lb/gal
Kilogram. Kg - 2.205 Ib
EQUIPMENT
PREHEATER AREA. M*2: 50.7502412
PRI COND AREA. MA2: 4.58713858
COLUMN DIAMETER. M: 0.34893212
NTU: 16.25
NO. OF COLUMN TRAYS: 10
ACTIVE HEIGHT. FT: 15
TOTAL HEIGHT. FT: 29
FTA2:
FT*2:
FT:
546.0
49.4
1.3
WATT=9.486E-04 8TU/S
1,750 based on teiecon with
Rob Goldman of Edwards Eng.
0.13 ft»2 area based on
teiecon with Rob Goldman of
Edwards Engineering.
-------
(53.83 -i- 40.71 -(tower wall thicknessOn))
0.375 inches < Ts < 2 inches
THICKNESS OKAY
no. of manholes = 10
mt diam, in = w (THIS IS INHERENT IN THE CURVE)
Manhole cost S = 14.269
-Nozzles Fig 15-25 (SUGGEST USING: ONE.6 inch(ovemeads); ONE.4 incft(feed):
TWO.4 incn(steam); and ONE.4 inch(bottoms)
Nozzles cost a SUM[(no. of nozzlesCfincnes of nozzle)!*
(24.57 * 35.94'(towerwall thickness, in))
0.375 inches < Ts < 2 inches
THICKNESS OKAY
sum[(no. noz)(in noz.)] = [(4*4"}+(TS")] = 22
Nozzles cost, 5 = 1.035
-Trays Fig 15-26 304 stainless only
Trays cost = (no. of trays)'214.54-exp(0.2075*Di)
2 ft < Oi < MS ft
DIAMETER TOO SMALL
Trays cost, 5 = 2.828
-Udders Tables
S.43/lb of ladder. 30lb/ft of ladder
Ladder height = column height = 29
Ladder cost, S = 374.1
-Platforms and Handrails Table 9
5.43/Ib ( d=4ft. 1700th )
Assume a linear relationship - 425 ib/tt of diameter
P and H cost, S = 243.22
-Insulation Fig 15-27
Use foamglass (ave)
Assume 3" thick (ave)
S10/R2
A (ft*2)= 142.28125
Insulation cost $ = 1422.8125
Total column cost. S - 42.944
• TOTAL COLUMN COST, S = 46.699
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2) Feed TanKs - Chemical Engineering Magazine January 25.198Z P6 144-46.
COST INDEX = 230.9 (sum CE index (Jan-Aprt4))
Cb = exp(2.331 + 1.3673 (In V) - 0.063088 (In V)*2]
i.300gal
-------
5) Primary condensers-Chemical Engmeermg Magazine November 21,
1988. pg. 66 - 75. Ftgs. 1 & 2. cost index = 343
Assume fixed-tube, single shell, single pass exchangers and
12 foot length tubes.
Pri Cond cost » 2228.8*exp(0.0041 rA,ft*2)
150ft*2*(122 ft H2O)'(8.33 Ib/gaD*
(min/60 s)*(lbf/lb)/[0.64n(0.00l341 hp)/(0.7376 ft Ibl/s)J
Overhead hp = 0.0
GROUP A FLOW TOO SMALL GROUP A: HP TOO SMALL
GROUPS: HP TOO SMALL
OVERHEAD PUMP. S = 2.256
Total Cost of Pumps = sum of (feed.bottoms.overhead)
TOT PUMP COST. S = 26.218
Conversion from hp to kw-hr/yr is (W)/(0.001341hp)'(KW/1000W>*
(8424 hr/yr)
-------
7) Flame arrestors - Casts gwen by Penny Lassiter from a tetecon
by A. Giteiman (RTT). Eacft arrester is estimated at $100. Cost
is in September 1986 dottars. COST INDEX = 319
From an RT1 report from Paul Peterson to Susan Thomloe. EPA7CPB.
dated January 18, 1988: it is assumed that vent lines from the storage
tanks, condensers, and decanters each had flame arresters in place.
The current approach assumes that these vent lines are routed bade to the
feed storage tank for the steam stnpper and a that there is a single
flame arrester on the vent line from the storage tank to the control device.
Cost of 1 arrester, S = too
8. ANNUAL COSTS - Utility costs BASIS: 8424 hr/yr operation
Utility costs consist of electricity, steam, and water costs
1) Electricity - Electncrty is needed for pumps and for
refrigeration.
a. Pumps - electricity use is calculated under the capital costs
Pump Electncrty use * (Total pump use in hp)"0.7457KW(mech.)/hp-(8424 hr/yr)
Tot Pump Use. HP * 2.46
PUMP ELECT USE. KW-H/yr = 15,462
TOTAL ELECT USE. KW-H/YR= 15.462
2) Steam - Steam is needed for stripping the organics.
Steam cost is estimated at $9.26/Mg (S4.20/lbm).
This cost is presented in July 1989 dollars. There is no cost index.
The steam is 400 psig sard steam with a heat content of 2802 KJ/kg
(1206 BTU/lnm).
The heat loss through the column is 5% of the heat input
Telecon. Kristine Scott, Radian with Rob Stepian, APV Crepaco.
steam use = (steam ftow.kg/hr)'(Mg/10A3 kg)'(1.05)*(8424hr/yr)
Steam use. Mg/yr = t .345
3) Water - Cooling water is used in the primary condenser.
Water use = (Pri cond H2O flow.gpm)'(60 min/hr)-(3.785Iiters/gal>*
(8424hr/yr)*(fraction lost to cooling tower evaporation and
slowdown - 0.04)
WATER USE, L/YR = 4 653 791
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E9R
A-96-38
n-B-7
Incorporated 1996 EPA Outstanding Small Business Contractor
MEMORANDUM . . -
DATE: May 16, 1997
SUBJECT: The Definition of an Extended Cookout as a Control
Technique for the Polyether Alcohol Production Industry
FROM: . Joanne C. Seaman, EC/R Incorporated
TO: David Svendsgaard, EPA/OAQPS/ESD/OCG
This memorandum defines an extended cookout (ECO) as a
control option for ethylene oxide (EO) and propylene oxide (PO)
(epoxide) emissions -from the production of polyether alcohols
made with epoxides. Also included in this memorandum is the
description of the default- onset point for the ECO which can be
used by facilities that prefer to accept this value in lieu of
calculating their own onset point for the'ECO.
BACKGROUND
. 'Polyether alcohols made with epoxides are predominately
produced in a.batch process. Epoxide emissions from the'batch
reactor vent result, in part, from the release of unreacted '
epoxide when the reactor is opened during any stage' of the batch
reaction cycle. Typically, during a batch where an extended
cookout (ECO) is not practiced,, the operator finishes adding the
epoxide to the reactor, and the reaction is stopped by either
cooling the reactor or neutralizing the catalyst. The reactor is
then opened in order to vent excess gas pressure, and transfer
the .reacted product to other equipment for additional handling
(such as catalyst removal or product purification) or transfer
the reacted product directly to product storage if further
processing is not required. Facilities maximizing production
from a reactor would typically empty the reactor as' quickly as
possible to start a new batch cycle. The reactor is emptied
despite raw material economics that indicate that it 'would be
advantageous to keep the product in the reactor, and the reactor
emissions are typically vented to a control device.
Facilities that practice ECO use this as an alternative to,
or in addition to add-on control devices to control epoxide
emissions from process vents. Extended cookout reduces the
amount of unreacted epoxide in the reactor by allowing it to
react for a longer time period, thereby reducing epoxide
emissions. For an ECO, the product continues to react in the
South Square Office Research Triangle Park Office
3721-D University Drive • Durham. North Carolina 27707 2327 Englert Drive. Suite 100 • Durham. North Carolina 27713
Telephone: (919) 493-6099 • Fax: (919) 493-6393 Telephone: (919) 484-0222 • Fax: (919) 484-0122
-------
reactor for longer than is calculated to be economically
advantageous. This additional reaction period (or ECO) reduces
the emissions of epoxide that otherwise would vent to a control
device or may make an add-on control device unnecessary to
achieve the required epoxide emission reduction. Since the
epoxide that would have been vented is converted to product, the
producer's raw material usage decreases.
A facility using ECO, however, assumes the disadvantage of
decreased annual throughput, because the reactor is used for
emission reduction cookout rather than to react another batch
immediately. Additionally, there is the potential for decreased
product quality, due to the possibility of secondary reactions
occurring during the ECO. When a producer uses ECO, it is going
beyond the economic balance of raw material savings versus
production capacity. The ECO is being used to reduce emissions
and the lost capacity is not compensated by the recovered raw
material.
CALCULATION FOR THE ONSET OP AN EXTENDED COOKOUT
The calculation for the onset of an ECO assumes that a
producer will operate a cookout as long as it is economically
viable; that is, as long as the value of the epoxide recovered as
product exceeds the value of the production lost due to the ECO
batch time. Beyond this point, the producer has no economic
incentive to continue to cookout the remaining epoxide. At this
economic breakpoint the cookout becomes an emission control .
Therefore, that economic breakpoint is considered the onset of
ECO for the purpose of evaluating the emission reduction.
For the purpose of determining a "default" ECO onset,
representatives from Union Carbide Corporation performed a
calculation for four product classes. This calculation required
the following confidential information: the batch size,- the
epoxide concentration at the end of the epoxide feed step; the
batch time without the extended cookout, the amount of time the
reactor runs on line per year; the cost of the epoxide; and, the
product variable margin (profit of the product, dollar per pound
The calculation takes into account only the liquid phase
epoxide. Some epoxide in the vapor phase is also recovered and
reacted into useful product during cookout, but this is normally
small and may be ignored without affecting the break point.
Also, this analysis does not take into account the capital
charges for the reactor itself/ it only takes into account 'the
annual lost production due to longer batches. A capital
utilization charge per hour of reactor batch time could be
included in the calculation; this would reduce the time required
to reach the economic breakpoint . This was not done in this
calculation for the sake of simplicity.
-------
Equations
Union Carbide has data to show that a first order reaction
rate fits the base-catalyzed alcohol alkoxylations its facilities
conduct using either a monol or polyol starter. Based on this
knowledge, the rate constant was calculated for each product used
in the evaluation of ECO. The rate constant was determined .by
solving the rate equation for K, and then inserting the epoxide
concentration at the end of the epoxide addition (C0) and at any
given time (Ct) , as indicated in Equation 1.
c =c *e''*•''
£.pox, c Epox.,a
Equation 1.
where:
C spox.t = the concentration of the epoxide in the
reactor liquid at a given time, weight percent (wt
percent);
C EPOX.O - the concentration of the epoxide in the
reactor liquid after the usual end of the reaction
phase, wt percent;
K = reaction rate constant, I/hours;
t = time, hours.
Next, the amount of epoxide converted to product (pounds per
batch) as a result of an ECO was calculated as presented in
Equation 2.
E con = E to - E cf
Equation 2.
where:
E con = the amount of epoxide converted to product as a
result of the cookout, pounds per batch (Ib/batch) ;
E co = the amount of epoxide in the reactor at the end
of the usual batch time, Ib/batch. Calculated by
multiplying the concentration from Equation 1
(CEPOX.O) with the batch size;
E tf = the amount of epoxide in the reactor at the end
of the cookout interval, Ib/batch. Calculated by
multiplying the concentration from Equation 1 (CEpdx,t)
with the batch size.
Next, the value of the epoxide converted into additional product
was calculated. This savings was calculated with Equation 3 .
-------
where:
.co = E con * B/yr * Cost Epox
Equation 3.
Val rpox-co = Value of the epoxide converted to product,
dollars per year ($/yr);
E con = the amount of epoxide converted to product as a
result of the cookout, pounds per batch (Ib/batch') ,
from Equation 2;
B/yr = number of batches per year at the extended
cookout rate,
Cost Epox = cost of the epoxide, dollars per pound.
Then, the amount of production lost, in dollars lost per
year, as a result of the reactor being used longer for an ECO was
calculated by multiplying the difference in the number of batches
made without an ECO and the number made with an ECO, at that
given cookout time, by the product variable margin ($/lb) .
Equation 4 illustrates this calculation.
PL = (B w/o CO/yr - B w/CO/yr) * BS * Prof
Equation 4.
where:
PL = production lost due to the cookout, $/yr;
B w/o CO/yr = number of batches that would have
occurred without the cookout, batches/yr;
B w/CO/yr = number of batches at the cookout rate,
batches/yr;
BS = batch size, Ib/batch, and;
Prof = the profit made on the product, $/lb.
Finally, the incremental economic analysis was calculated by
first determining the cost analysis at time 2. The cost analysis
was calculated as the difference between the value of epoxide
converted minus the lost production, -as presented in Equation 5.
CAt = Val Epox, co, t - LPe
Equation 5.
where:
CA = cost analysis at a given cookout time;
Val Epox, Co = value of the epoxide converted to product
for that given time, $/yr, from Equation 3, and,-'
LP = lost production for that given time, $/yr from
Equation 4.
To be conducted incrementally, the cost analysis conducted at
time 2 is subtracted from the cost analysis done at time 1.
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Extended Cookout Onset Determination
These calculations were made on a spreadsheet at one tenth
of an hour intervals, and the incremental cookout economics
calculated. The break-even point, or the "onset" of an ECO, was
identified as the point in time when the incremental cookout
economics changed from a positive to--a negative value.
The break-even point was identified for four different
classes of products made by Union Carbide. For all four classes
of products, it was determined that the break-even point occurred
prior to the point in time when the combined unreacted epoxide
concentration in the reactor liquid is equal to 25 percent of the
concentration of the epoxide at the end of the epoxide feed step.
The variables used in these calculations are considered
confidential business information, and therefore cannot be
reproduced for this memorandum. However, the individual facility
can recreate this calculation for the products made at that
facility and document a different ECO point of onset. The rule
will be written to reflect flexibility in setting a point of
onset for an ECO.
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MEMORANDUM
TO: David Svendsgaard
FROM: Linda Chappell
SUBJECT: Economic Analysis for the National Emissions Standards for Hazardous Air
Pollutants (NESHAP) for the Polyether Polyols Industry
DATE: May 21,1997
A brief discussion of the economic analysis and regulatory flexibility analysis conducted
for the Polyether Polyols NESHAP follows.
I. ECONOMIC IMPACTS
The goal of the economic impact analysis is to estimate the market response of the
polyether polyols industry to the emission standards and to determine any adverse effects that may
result from the regulation. Polyether polyols are classified as a thermoset resin and typically
produced as an intermediate product or as an input into other products. The majority of polyether
polyols are used for the manufacture of urethanes, surface-active agents, functional fluids, and
synthetic lubricants. Approximately 79 facilities owned by 36 different companies produce
polyether polyols domestically, and 72 of these facilities may potentially be affected by the
regulation. The polyether polyol facilities are dispersed throughout the country in 22 different
states with the largest concentration of 18 facilities in Texas. Of the 36 companies producing
polyether polyols, seven are classified as small businesses.
Since the nationwide annualized cost of this regulation of $7.7 million represents
approximately 0.06 percent of the estimated 1996 sales revenues for domestically produced
polyether polyols, the EPA determined that the regulation is not likely to have a significant impact
on this industry as a whole. For this reason, a streamlined economic analysis is performed. The
goal of this streamlined analysis is to determine whether individual facilities producing polyether
polyols and companies owning those facilities are likely to be adversely impacted by the
regulation. Facility-specific impacts are examined to assess the likelihood of facility closures and
employment impacts.
A. Analytical Approach and Control Cost Estimates
Three different model plants (small, large, and catalyst extraction model plants) are
developed to estimate facility and nationwide annualized and capital control costs for the
regulation. The capital and annualized costs for each of the model plants, as well as estimates of
the nationwide costs are shown on Table 1. The capital costs for the regulation are estimated to
1
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be $10.1 million and the annualized costs $7.7 million. (All values are shown in 1996 dollars.)
Table 1
Model Plant and Nationwide Control Cost Estimates - Polyether Polyols NESHAP
(Thousands of 1996 dollars)
Model Plant/ Nationwide
Small1
Large1
Catalyst Extraction1
Nationwide Totals
Capital Costs
$106.7
516.1
222.6
$10,060.0
Annualized Costs
$89.4
292.1
283.1
$7,670.0
Capital and annualized model plant control cost estimates represent the maximum costs of compliance that any model plant will incur as a result of
the regulation, and this estimate may overstate costs for some affected facilities.
Compliance costs are assigned to each facility assuming that each facility must control all
emission points. For example, the small model plant category includes control cost estimates for
three emission points that consist of process vent scrubbers, fixed-roof storage tanks, and
equipment leaks. Specific facilities may not require controls for all emissions points. However,
the analysis assumes that each facility incurs the maximum costs of compliance for plants within a
model plant category. This assumption results from insufficient facility-specific data and is
necessary to ensure that the costs incurred by any affected facility are not understated. The
Agency recognizes that, by using this assumption, it is overstating the costs incurred by many
affected facilities.
Capital costs are annualized at a seven percent discount rate to compute the annual costs
of capital. Then, the annualized capital costs are combined with annual operating and
maintenance costs, recordkeeping, monitoring, and reporting costs, and other annual costs to
compute the total annualized costs to comply with the proposed rule.
Model plant annualized control costs are compared to facility-specific revenues for each of
the 72 facilities that will be impacted by the regulation. A cost-to-sales ratio is developed to
estimate the impact each facility is likely to experience as a result of the regulation. Since
polyether polyols are frequently produced at multi-product facilities and in some cases by firms
owning multiple facilities, revenue data specific to the polyether polyols production of each
facility are not readily available. For this reason, revenues are estimated using the production
and/or capacity data available for facilities in this industry and an estimate of the market price per
pound paid for polyether polyols during 1996 of $1.05. Actual production data are available for
only 12 companies that responded to an Information Collection Request administered through the
Society of Plastics Institute for the EPA. Based upon the production and capacity data for the 12
surveyed facilities and capacity information obtained from other data sources, an estimate of
annual production for each of the 72 facilities is obtained. Facility-specific revenues are
calculated by multiplying the price per pound of polyether polyols of $1.05 by the estimated
-------
production for each facility.
The cost-to-sales ratios are computed for each facility in the three model plant categories
by dividing model plant costs by the estimated facility-specific revenues. A cost-to-sales ratio
exceeding one percent is determined to be an initial screening criteria for a significant facility-
specific impact.
Facility-Specific Impacts
Descriptive statistics including the estimated minimum, maximum, mean, and median cost-
to-sales ratios for the 72 facilities are shown for each model plant category on Table 2. While the
mean cost-to-sales ratios for each model plant category are well below one percent and as such
determined not to be significant, the maximum cost-to-sales ratio in the catalyst extraction model
plant category exceeds one percent. To examine the impacts more closely, a frequency
distribution of cost-to-sales ratios is developed. This distribution is shown on Table 3.
Table 2
Facility Impacts of the Proposed Polyether Polyols NESHAP
Model Plant Size/ Statistic
Small Model Plant:
Minimum
Maximum
Mean
Median
Catalyst Extraction Model Plant:
Minimum
Maximum
Mean
Median
Large Model Plant:
Minimum
Maximum
Mean
Median
Total Annual Cost / Estimated Sales
Revenue ("/o)1
0.028
0.881
0.280
0.192
0.169
1.542
0.448
0.373
0.139
0.232
0.145
0.139
' Assumes that the mean sales for facility with data available are the sales levels for facilities for which data are unavailable.
Only one facility out of the 72 facilities impacted is expected to experience a cost-to-sales
ratio exceeding one percent. The facility for which costs exceed one percent of sales is estimated
to produce about 23 million pounds of polyether polyols per year. Total annualized compliance
costs are estimated to be about 1.5 percent of annual sales for this facility, which is classified in
-------
the catalyst extraction model plant category. This facility is owned by a large, financially strong
company. Company sales were more than $2 billion in 1996, with net income more than $200
million. The compliance costs are an insignificant share of those resources, so it is probable that
the company will choose to comply with the regulation, rather than shutting down their polyether
polyol production.
Based on the foregoing, the EPA concludes that the proposed NESHAP for polyether
polyols will impose costs that are negligible on the majority of facilities. For only one facility out
of 72 in the industry do costs exceed one percent of sales. Based on an analysis of the costs of
compliance compared to facility and company financial data, the Agency finds it unlikely that the
company owning this facility will choose to close it, because the company is financially robust and
the costs are a small share of the company sales and net income. The generally small scale of the
impacts suggests that there will be no significant impacts on markets for the products made using
polyether polyols, such as polyurethanes.
Costs do not exceed one percent of company sales for any of the companies owning
facilities producing polyether polyols. Thus, the Agency concludes that no company will be made
likely to incur bankruptcy as a result of this regulation.
REGULATORY FLEXIBILITY ANALYSIS
The Regulatory Flexibility Act (RFA) provides that, whenever an agency promulgates a
final rule under 5 U.S.C. (MARK) 553, after being required to publish a general notice of
proposed rulemaking, an agency must prepare a final regulatory flexibility analysis unless the head
of the agency certifies that the final rule will not have a significant economic impact on a
substantial number of small entities. Pursuant to section 605(b) of the Regulatory Flexibility Act,
5 U.S.C. 605 (b), it is certified that this rule will not have a significant impact on a substantial
number of small entities.
The EPA analyzed the potential impact of the rule on small entities and determined that
only seven of the 36 polyether polyol producing firms are small entities — not substantial number
of entities. Of these seven, no small companies will experience an increase in costs as a result of
the promulgation of this rule that is greater than one percent of revenues. Therefore, the Agency
did not prepare an initial regulatory flexibility analysis.
Although the statute does not require the EPA to prepare an RFA because the
Administrator has certified that the rule will not have a significant economic impact on a
substantial number of small entities, the EPA did undertake a limited assessment, to the extent it
could, of possible outcomes and the economic effect of these on small polyether polyol producing
entities as previously discussed.
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Table 3
Frequency Distribution: Total Annual Compliance Cost/Facility
Sales by Model Plant Category
Model Plant/ Frequency Distribution
Total Number of Facilities
Small Model Plant Cost-to-Sales Ratio1:
0 to 0.2 percent
0.2 to 0.5 percent
0.5 to 1 percent
1 to 5 percent
over 5 percent
Total Small
16
3
3
0
0
22
Catalyst Extraction Model Plant Cost-to-Sales
Ratio1:
0 to 0.2 percent
0.2 to 0.5 percent
0.5 to 1 percent
1 to 5 percent
over 5 percent
Total Catalyst Extraction Model Plant
1
12
1
1
0
15
Large Model Plant Cost-to-Sales Ratio1:
0 to 0.2 percent
0.2 to 0.5 percent
0.5 to 1 percent
1 to 5 percent
over 5 percent
Total Large Model Plant
29
4
2
0
0
35
1 Assumes that the mean sales for facility with data available are the sales levels for facilities for which data are unavailable.
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