-------
CO
CO
CO
o
CO
CO
LJ
1
z
Q
LU
CO
CO
UJ
g
z
I
_l
o
QC
Z
o
o
UJ
CL
3
O
UJ
LL
O
I
2
CO
in
H
LU
in
l
O)
1=
I
CO
0
o> in
S.:
o
£ £
C OT
o vi
O 8>
8
CT
UJ
„
m-
^
cr
J.
(A
(0
o
CO
S
CO
8
0
CO
CM
CO
CO
CO
in
CO
o
m .2
.0 £
§•§ §•
C T3 E
-25
°II
ftft
«!I!
§•£".§
11§*
gg2 i
o I
£<
o
u
3
TJ
o
o
o
Stat
CCLU O
CO O Z
-------
I
I
I
I
I Attachment 6
Documentation of equipment leak emission factors
I
I
I
I
I
I
I
I
I
I
I
I
I
I
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
ODEI7 dD
PACIFIC ENVIRONMENTAL SERVICES, INC.
Central Park West
5001 South Miami Boulevard
PO Box 12077
Research Triangle Park. NC 27709-2077
(919)941-0333 FAX (919) 941-0234
MEMORANDUM
TO: Group IV Resins Docket No. A-92-45
FROM: Ken Meardon
Pacific Environmental Services, Inc.
DATE: March 24, 1995
SUBJECT: Determination of MACT Floors for Equipment Leaks
The purpose of this memo is to describe the methodology used to calculate the
MACT floors for the source categories covered by the Group IV Resins national
emission standards for hazardous air pollutants (NESHAP). The same basic
methodology, as described below, was used for each source category/subcategory.
Basic Methodology
The basic methodology consisted of estimating uncontrolled equipment leak
emissions, identifying the level of control at each facility based on that facility's specific
leak and detection repair (LDAR) program (if one was in place), applying the
"controlled" equipment leak factors to estimate emissions after control, and then
calculating the percent emission reduction achieved at each facility within each source
category/subcategory. The information on the percent reduction achieved by the specific
programs was then used to determine the MACT floors for each source
category/subcategory.
Each individual plant was grouped with all other plants on the basis of the type of
polymer or resin produced. Where a plant produced polymers or resins in more than
one source category/subcategory, the equipment components were separated, where
possible, according to the type of polymer or resin. If this was not possible, then all of
the components were included in each applicable source category/subcategory for
purposes of determining the MACT floors.
Estimating Uncontrolled Emissions
This step required determining (1) the equipment component counts at each plant
and (2) the emission factors for each component category (e.g., valve in gas service,
pump in light liquid service).
WASHINGTON D C • RESEARCH TRIANGLE PARK NC • LOS ANGELES CA • CINCINNATI OH
-------
A number of facilities provided information on the component counts at a plant.
Where these counts were provided, they were used directly in the estimation.
For facilities that did not provide equipment component counts, an estimate had
to be made for each component type. There are many variables that affect the number
of components at a facility. Such variables include, but are not limited to, the age of the
facility, the number of process lines, and the capacity of each line and of the facility.
Thus, for example, it is generally recognized that the number of components and thus
emissions are related to the capacity of a facility. However, sufficient information was
not available to perform any sophisticated analysis for estimating the number of
components for those facilities.
The available information on equipment components was identified and estimates
of the number of each component was made in terms of component per process line and
component per design capacity. The results of this analysis showed, that for this industry,
but unlike for the synthetic organic chemical industry (SOCMI), estimating the number of
components by components-per-capacity was not necessarily unreasonable. The size of
individual process lines within a subcategory was fairly similar and many of the facilities
are of the same generation. Therefore, for estimation purposes, it was decided to use
the information provided on individual facilities within the source category/subcategory,
calculate an average count for each component type, and then ratio the design capacity
of the target plant with the average design capacity of the plants that provided actual
equipment counts.
To estimate uncontrolled emissions, the emission factors reported in the 1993
Protocol document1 were used. These factors were used to provide a consistent baseline
for estimating the impact of various LDAR programs in use in the source categories.
For the several facilities that provided specific and clear information, the estimates of
emissions were adjusted to account for low HAP concentrations and reduced hours of
operation.
Identifying Level of Controls
A number of facilities provided information on the control programs being used to
reduce emissions from equipment leaks. Other facilities simply identified a LDAR
program, but did not provide any details. Still other facilities did not indicate any control
programs for equipment leaks.
For facilities that provided information on the specific programs, these programs
were used directly. For facilities that indicated that a LDAR program was being used,
U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards.
Protocol for Equipment Leak Emission Estimates. EPA-453/R-93-026, June 1993.
-------
I
I
I
I
I
i
l
I
I
l
I
l
I
l
l
i
l
i
i
but did not provide specifics, the State regulation that appears to be applicable to the
plant was used to estimate the specifics. In most cases, this resulted in assuming a CTG-
like level of control. In one or two instances, a LDAR program was indicated, but no
State program could be identified. It is assumed that the LDAR program was therefore
due to plant policy. For facilities that did not indicate any programs for equipment leaks,
no control was assumed unless the facility was located in a State with a LDAR program
that was obviously directed toward that plant or type of plant.
Controlled Emission Factors
The controlled emission factors associated with various LDAR programs used in
determining the MACT floors are summarized in Table 1. Table 2 shows the percent
reduction of the controlled emission factors over the uncontrolled emission factors. In
most instances, the controlled emission factors are based primarily on information found
in the 1993 Protocol document. The footnotes to Table 1 detail the derivation of the
controlled emission factors.
Calculation of Emission Reduction and Controlled Emission Rates
Using the equipment component counts, uncontrolled emission factors, and
controlled emission factors, the amount of emission reduction achieved by component
and for the entire plant was calculated for each plant. The percent emission reductions
were then calculated. Table 3 summarizes the estimated percent reductions for each
facility within each source category/subcategory.
MACT Floor Determination
MACT floors were then determined for existing and new facilities within each
source category/subcategory. For source categories with less than 5 source categories all
of the facilities were used to estimate the MACT floor. The MACT floor was calculated
by taking the average of the percent emission reductions achieved by each of the
facilities. Thus, for example, the four facilities producing ABS using the batch emulsion
process were estimated to reduce equipment leak emissions by 91.2, 84.1, 82.0, and 79.5
percent. The average of these four percent reductions is 84.2 percent, which was used to
represent the MACT floor for existing sources in this subcategory.
For source categories/subcategories with more than five facilities, the five facilities
with the highest percent reductions were identified, and the MACT floor was calculated
as the average percent reduction achieved by these five facilities. For example, the top
five polystyrene facilities using a continuous process were identified as achieving 85.8,
81.9, 80.8, 79.6, and 78.6 percent reduction. The average of these five percent reductions
is 81.3 percent.
-------
For new facilities, the MACT floor was identified as the best performing facility
within the source category/subcategory based on the estimated percent reduction. For
example, in the ABS, batch emulsion source category, the Monsanto, Addyston, OH,
facility was estimated to be reducing equipment leak emissions by 91.2 percent. This was
then selected as the MACT floor for new sources in this subcategory.
In all cases, the MACT floors estimated for existing and new sources were
equivalent to or less stringent than the HON.
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
i
I
a.
§
UJ
I
^ cc
UJ •*
ffi %
.
O£
UJ
t—
(J
t—
UJ
i
J
<
o
*•»
o
H
u
d
2
(A
0
CO
2
a.
SC
»
a.
z!
.J
>
.J
.J
0
>*
g
0 ** ?
v c &
«l
o
5
tfl
Of
a.
Kl
o
s
o
§
o
0
in
Kl
§
0
§
IM
O
i
o
o
3
o
o
8
in
o
o
o
d
Kl
O
I
-
£
• O
=
T)
CM
1A
§
o
o
"o;
u
^»
O
u
.3
o
u
O
o
o
to
o
o
o
o
o
o
o
CD
3
<
Kl
O
O
-5
^t
o
in
o
Kl
O
O
1
0
Kl
CO
O
o
o
o
o
o
,-
CD
^
<
TM
O
Kl
O
O
CO
o
o
o
o
o
-
c
o
•^
fe
in
*»•
o
1
"s
o
'k
o
"8
o
o
3
0
o
o
o
o
%
o
X
t
*•»
u
1
ooowd |
o
**
«—
0
"K
o
o
•
o
o
o
o
in
I
o
g
o
._
s?
o
— 1
X
L.
L.
§
o
\
o
g
o
~fM
m
^
o
in
O
O
in
>M
O
O
O
01
CM
i
O
§
in
te
a
X
c-
L.
o
.000166 I
o
IM
in
^
0
in
o
o
s.
in
C\J
o
o
o
c\J
S
o
0
o
o
(M
E
Of
o
.j
X
u
*rf
L.
1
.000166 |
o
S
Of
<
3
X
t.
4-*
L.
§
a
rvi
o
o
o
o
£
in
o
o
o
o
o
c»
§
0
s
o
o
1
X
4-1
1
o
0
o
o
o
o
o
o
Kj
O
0
o
,_*
a:
X
±j
|
T3
O
o
o
0
o
o
o
o
D
(M
O
O
O
s
in
|
X
4j
|
o
o
o
o
o
o
o
o
o
o
o
a:
S
X
^J
1
i
o
o
o
o
s
in
41
Ik
01 0
o at
o at
o'i
X UJ
"1
o
o
o
o
o
o
o
0
o
0
§
0
O
§
o
01
a
1
.002655 |j
o
JO
o
in
*—
O
CM
1
O
O
rvj
to
§
o
1
0
s
o
o
g
i
w
M
411
C
a
in
in
o
o
o
in
CM
CM
0
o
o
fc
s
§
o
Kl
O
o
o
o
o
o
o
._*
1
at
u
.J
s
CM
i
s
o
3
JI
O
fS
§
o
o
o
o
o
o
i
w
w
Vcr
-> in
u.
«j 01
C — '
*a x
X
01 1.
_ cu
"5 —
X O
-------
g
I
u
en
3
0
UJ
h-
<
*-
3
g
S
UJ
1
«
u
o
u
g
u
• •
t!
i
n
g
n
Sf
—I
a
_j
•
(L
_)
S
sT
_i
^
«
>
(9
>
§
. *~ *%
SSl
•8W
o
I
gf
-*
i
o
i
o
Kl
Kl
O
O
S
S
o
N.
o
o
1
o
o
5
o
o
o
(M
o
o
o
*
o
5
3
_J
«^
o
t)
. uj
o
z
"s?
i
o
r
4^
y
o.
U)
M
a
4-*
C
S
=2
O
>
's
^—
o
o
0
«
ro
•
o
i
§
M
X
I/I
«J
C
41
i
1
8
u
o
0
0
1
*2
5
u.
u
V
L.
L.
a
m
S
o
*
M
O
01
t.
«
5
0
t
t
m in
o
i
a.
8*
;*
h
— > B
U M
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
FOOTNOTES TO TABLE 1
" V = valves; P = pumps; PRVs = pressure relief valves; OELs = open-ended lines; Comp. = compressors; Samp. Conn.
sampling connections; G = gas service; LI = light liquid service; HL = heavy liquid service.
U.S. Environmental Protection Agency. Protocol for Equipment Leak Emission Estimates. EPA-453/R-93-026.
1993. page 2-10. (1993 Protocol document). Converted from kg/hr to Ibs/hr by: kg/hr x 2.2 = Ibs/hr.
June
c Estimated be averaging uncontrolled emission factors and emission factors for quarterly LDAR with leak definition of
10,000 ppm. For example, for valves in gas service: (0.0131 + 0.0043)/2 » 0.0087 Ibs/hr. For some components, this
is a conservative estimate as annual programs may not be effective in reducing emissions.
d Derivation of emission factors based on taking known values (shown in double-lined boxes in the following tables),
bounding unknown values, and taking mid-points as estimates of unknown emission factors. The first table shows
known and estimated leak frequencies. The second table shows the known and estimated emission factors. These
values were based upon the 1993 Protocol document data and equations, and apply only to connectors in gas/vapor
service and to connectors in light liquid service.
CONNECTOR LEAK FREQUENCIES
LOAR PERIOD
Annual
Quarterly
Monthly
Uncontrolled
LEAK DEFINITION (ppm)
500
0.25
0.125
0.063
3.9
1000
0.213
0.106
0.053
3.78
10000
0.138
0.069
0.0345
1.55
Uncontrolled
1.55
CONNECTOR EMISSION FACTORS (Ibs/hr)
LDAR PERIOD
Annual
Quarterly
Monthly
Uncontrolled
LEAK DEFINITION (ppm)
500
0.000286
0.000166
0.000102
1000
0.000334
0.000194
0.000124
10000
0.00052
0.000349
0.000264
Uncontrolled
1-55 |
Detailed Discussion
For annuaI LDAR, the leak frequency and emission factor at 500 ppm are known (0.25X and 0.000286 Ibs/hr). As
leak definition goes from 500 to 1000, the leak frequency will decrease. We also know that the emission factor will
increase as the leak frequency increases (within the same LDAR monitoring period). Using this information, emission
factors for 1,000 and 10,000 ppm were calculated as follows:
Annual at 1.000 pan. The leak frequency at 1,000 ppm will be less than 0.25X. Using this leak frequency and
the appropriate equation from page 5-19 of the 1993 Protocol document, we can calculate a "maximum" emission factor,
which is calculated to be 0.00017 kg/hr. Next, the emission factor at 1,000 ppm must be greater than that at 500
ppm, which we know to be 0.000134 kg/hr. These two emission factors "bound" the estimate for annual LDAR at 1,000
ppm. The emission factor for 1,000 ppm was then estimated as the mid-point of these two numbers, which is 0.000152
kg/hr (= (0.000134 + 0.00017)/2) or 0.000334 Ibs/hr.
Annual at 10.000 pom. The first step was to estimate the leak frequency at 1,000 ppm. In the previous step,
we estimated the emission factor at 1,000 ppm to be 0.000134 kg/hr. Using the appropriate equation on page 5-19 of
the 1993 Protocol document, we can "back-calculate" the equivalent leak frequency, which is calculated to be 0.213
percent. The leak frequency at 10,000 ppm will be less than 0.213 percent. Using this leak frequency in the
appropriate equation on page 5-19 yields an emission factor of 0.000321 kg/hr. We also know that the emission
factor will be greater than that at 1,000 ppm, which was estimated to be 0.00015 kg/hr. The emission factor for
10,000 ppm is then bounded by these two emission factors, 0.000152 and 0.000321 kg/hr. The emission factor for
10,000 is then taken again as the mid-point between these two estimates (0.000236 kg/hr or 0.00052 Ibs/hr).
Emission Factors for Quarterly and Monthly LDAR. In the absence of any information, leak frequencies were
assumed to decrease by 50 percent from annual to quarterly and 50 percent from quarterly to monthly. The resulting
leak frequencies were then used in the appropriate equations on page 5-19 to estimate emission factors.
-------
FOOTNOTES TO TABLE 1
(continued)
* Derivation of emission factors based on taking known values (shown in double-lined boxes in the following tables),
bounding unknown values, and taking mid-points as estimates of unknown emission factors. The first table shows
known and estimated leak frequencies. The second table shows the known and estimated emission factors. These
values were based upon the 1993 Protocol document data and equations. See footnote d for a detailed discussion of
the methodology used to estimate the unknown values. The leak frequency for annual at 1,000 ppm was based on the
mid-point of uncontrolled and quarterly at 1,000 ppm leak frequencies.
LIGHT LIQUID SERVICE VALVES LEAK FREQUENCIES
LDAR PERIOD
500
LEAK DEFINITION (ppm)
1000
Uncontrolled
Annual
3.3
Quarterly
Monthly
Uncontrolled
2.42
2.26
0.896
0.83
8.5
8.3
A.34
LIGHT LIQUID SERVICE VALVES EMISSION FACTORS (Ibs/hr)
LDAR PERIOD
500
LEAK DEFINITION (ppm)
1000
Annual
0.00395
Quarterly
Monthly
Uncontrolled
0.00257
0.00273
0.00099
0.00106
' Estimated by averaging the emission factors for annual LDAR and monthly LDAR both with leak definition of 10,000
ppm.
9 Derivation of emission factors based on taking known values (shown in double-lined boxes in the following tables),
bounding unknown values, and taking mid-points as estimates of unknown emission factors. The first table shows
known and estimated leak frequencies. The second table shows the known and estimated emission factors. These
values were based upon the 1993 Protocol document data and equations. See footnote d for a detailed discussion of
the methodology used to estimate the unknown values. The leak frequency for annual at 1,000 ppm was based on the
mid-point of uncontrolled and quarterly at 1,000 ppm leak frequencies.
GAS SERVICE VALVES LEAK FREQUENCIES
LDAR PERIOD
Annual
Quarterly
Monthly
HON
Uncontrolled
LEAK DEFINITION (ppm)
500
1000
3.095
1.13
1.00 |l
13.6 I 13.3
10000
2.33
0.79
Uncontrolled
7.48 || 7.48
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
i
i
i
i
i
FOOTNOTES TO TABLE 1
(continued)
GAS SERVICE VALVES EMISSION FACTORS (lbs/hr)
LDAR PERIOD
Annual
Quarterly
Monthly
HON
Uncontrolled
LEAK DEFINITION (ppm)
500
0.00323
0.00121
0.00099
1000
0.00345
0.001298
10000
0.00429
0.00165
Uncontrolled
II 0.0131 ||
h Derivation of emission factors based on taking known values (shown in double-lined boxes in the following tables),
bounding unknown values, and taking mid-points as estimates of unknown emission factors. The first table shows
known and estimated leak frequencies. The second table shows the known and estimated emission factors. These
values were based upon the 1993 Protocol document data and equations. See footnote d for a detailed discussion of
the methodology used to estimate the unknown values. The leak frequency for annual at 1,000 ppm was based on the
mid-point of uncontrolled and quarterly at 1,000 ppm leak frequencies.
LIGHT LIQUID SERVICE PUMPS LEAK FREQUENCIES
LIGHT LIQUID SERVICE PUMPS EMISSION FACTORS (lbs/hr)
LDAR PERIOD
Annual
Quarterly
Monthly
HON
Uncontrolled
LEAK DEFINITION (ppm)
500
0.0157
0.010
1000
0.0172
0.011
0.011
10000
0.024
0.0135
Uncontrolled
1
0.0438 |
Based on emission reduction of 44 percent from uncontrolled level. U.S. Environmental Protection Agency. Fugitive
Emission Sources of Organic Compounds -- Additional Information on Emissions, Emission Reductions, and Costs. EPA
450/3-82-010. April 1982. (1982 AID document) p. 4-61.
Based on 33 percent reduction, CTG.
Total estimated emission reduction effectiveness of 49 percent. Based on an estimated percent reduction of 44
percent for a quarterly LDAR program with a leak definition of 10,000 ppm (see footnote d above) plus 5 percent
based on increased effectiveness of decreasing the leak definition from 10,000 ppm to 1,000.
Assumed to be 1 percent more effective than with leak definition of 1,000 ppm.
-------
FOOTNOTES TO TABLE 1
(continued)
*" Assumed 200 ppm leak definition had same emission factor as 500 ppm.
" 1993 Protocol document, p. 2-21:
1.90x10'* x (500)0'824 = 0.00318 kg per hour
0.007 Ibs per hour
0 1993 Protocol document, p. F-4. The emission factor for pumps, light liquid service also applies to agitators.
p Calculated using the following equation:
(Uncontrolled Emission Rate - Emission Rate at IX)
Uncontrolled Emission Rate
Emission rates at 1X were calculated using the equations on p. 5-19 of the 1993 Protocol document. For example, the
average leak rate (kg/hr) for valves in gas service with a leak definition of 10,000 ppm can be calculated as
follows:
Average Leak Rate = (0.0781 x 0.01) + 0.000131
= 0.000912 kg/hr
s 0.00201 Ibs/hr
q Assume maintain 1X leakers means an average of 0.5X leakers actually occur. Used the leak rates for >10,000 and for
<10,000 (see first table in footnote s) to estimate emission factors based on percent leaking and not leaking. For
example.
For PRVs: kg/hr = (1.691 x 0.005) + (0.0447 x 0.995) » 0.05293
Ibs/hr = 0.05293 x 2.2 = 0.1164
' Assume maintain 0.5X leakers means an average of 0.25X leakers actually occur. Used the leak rates for >10,000 and
for <10,000 (see first table in footnote s) to estimate emission factors based on percent leaking and not leaking.
For example.
For valves in gas service:
kg/hr = (0.0782 x 0.0025) + (0.000131 x 0.9975) = 0.000326
Ibs/hr = 0.000326 x 2.2 = 0.000718
* Calculation of Emission Factors for "No Evidence of Leaks" Program; Leak Definition of 10,000 ppm.
CALCULATION OF PERCENT OF COMPONENTS WITH <10,000 PPM AND >10,000 PPM
EQUIPMENT TYPE
Valves, gas service
Valves, light liquid
service
Valves, heavy liquid
service
Pump seals, light liquid
service
Pimp seals, heavy liquid
service
Pressure relief valves
Open ended lines
Compressor seals
Connectors
AVERAGE
EMISSION
FACTOR
(kg/hr)*
l_ 0.00597
0.00403
0.00023
0.0199
0.00862
0.104
0.0017
0.228
.0.00183
> 10,000 ppm
Emission Factor
(kg/hr)*
0.0782
0.0892
0.00023
0.243
0.216
1.691
0.01195
1.608
0.113
< 10,000 ppm
Emission Factor
( kg/hr}6
0.000131
0.000165
0.00023
0.00187
0.00210
0.0447
0.00150
0.0894
0.000081
PERCENT OF
COMPONENTS
>1 0,000 PPMe
7.48
4.341
NA
7.48
3.048
3.6
1.91
9.13
1.55
PERCENT OF
COMPONENTS
<1 0,000 PPMe
92.52
95.659
NA
92.52
96.952
96.4
98.09
90.87
98.45
NOTE: Program assumed not applicable to sampling connections.
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
FOOTNOTES TO TABLE 1
(concluded)
Footnotes to first table in footnote s:
" 1993 Protocol document, p. 2-10.
b 1993 Protocol document, p. 2-16.
c Calculated based on average emission factor and the > 10,000 and <10,000 ppm emission factors. For
example, solving for valves in gas service as follows:
0.00597 kg/hr - 0.0782 (X) + 0.000131
1.00 * X * T
where: X = percent of components with >10,000 ppn
Y » percent of components with <10,000 ppm
CALCULATION OF NO EVIDENCE OF LEAKS (10,000 PPM LEAK DEFINITION) EMISSION FACTORS
EQUIPMENT TYPE
Valves, gas service
Valves, light liquid service
Valves, heavy liquid service
Pumps, light liquid service
Pumps, heavy liquid service
Pressure relief valves
Open-ended lines
Compressor seals
Connectors
EMISSION
FACTOR (kg/hr)
at 10,000 ppm*
0.005806
0.0098823
0.00023b
0.03756
0.03756
0.03756
0.0015°
0.03756
0.01058
PERCENT
<10,000
PPM
92.52
95.659
NA
92.52
96.952
96.4
98.09
90.87
98.45
PROGRAM EMISSION FACTOR
kg/hr
0.000555
.000587
0.00023
0.004539
0.00318
0.0444
0.00147
0.0845
0.000244
Ibs/hr
0.00122
0.00129
0.000506
0.00999
0.007
0.0977
0.00324
0.186
0.00054
* Calculated using correlation equations found on page 2-21 of the 1993 Protocol document.
b Based on average emission factor for source.
c Assumed same as <10,000 ppm emission factor.
Sample calculation:
Valves, gas service: 0.000555 kg/hr = (0.005806 x 0.0748) + (0.000131 x 0.9252)
1 Assuned to be midway in effectiveness between "uncontrolled" and "maintain less than 2X leakers (10,000 ppm)."
" Based on 90 percent control efficiency. 1993 Protocol document, p.5-2. Actual efficiency of a closed-vent system
depends on percentage of vapors collected and efficiency of control device to which the vapors are routed.
v Control efficiency of closed-vent system installed on a pressure relief device may be lower than other closed-vent
systems, because they must be designed to handle both potentially large and small volumes of vapor. 1993 Protocol
document, p. 5-2.
* Based on 100 percent control efficiency. 1993 Protocol document, P. 5-2.
-------
CM
UJ
—I
to
U
o
U
cr
ai
a.
a
1
UJ
i
a.
s
(0
fe
i
1/1 U
f*
«l
s
(A
g
X
O.
^
o.
X
>"
>
a
g
* «!• s
sift
~" «*T ^^
4)
O
?
ac
i
>
i
"S
2
g
1
_
fc
in
*
0
CM
CM
^
CM
CM
O
Kl
<0
Kl
i
o
to
1
^
5
s
„
o
Kl
in
in
in
-0
"
o
o
0
«w
CO
1
Kl
S
O
o
a
a
w-
_^
S
a
c/
Kl
5
a
Pi
3
CM
in
vt
in
S
CM
•O
I
o
ce
0
"L
**
5
.
L.
01
a
S
N.
o
CM
3
O
C
Kl
£
O
O
CM
«
a
X
L.
01
a
K
o
o
5?
0
L.
o>
1
s
CM
S
a
^
£5
§
o
o
ee
n
£
i
*
o
2
o
s
^
§
o
o
o
«•
oe
n
^
*
N.
O>
CM
fc
^_
S
co
§
o
o
in
ex
X
-C
-
CM
fc
S
^
SI
§
oc
o
X
.c
-
•«
§
0
s
8
in
4)
CO
CO CA
o 'i
Z Ul
o
£
»
s
0
c-
- fc
(0 — *
o1^
£ O
•0
s
o
3
eo
^
Kl
in
-
Kl
-0
CM
fc
in
in
co
N.
8
8
o
o
IA
CO
a
H-
o
•c
>
o
Z
-------
1
1
1
1
I
1
1
1
1
1
1
1
1
1
1
1
1
1
1
"en
oe
O
QC
a.
3
ot
*-
^
<
UJ
_J
^
z
tli
£
a.
§
Ul
trt
3
a:
<
rvj >
(^
"-^ It
* S
UJ
z
O
a.
5
u
m
o
i—
u
o
Of.
f—
z
UJ
u
a.
UJ
a
u.
o
>-
O£
<
Z
1
.0
or
g
UJ
2
UJ
Z
a.
i
Ul
i_
0
u
u
. .
6 c
a o
en o
.
u
en
S
M
a.
-j
Q.
_j
aT
j
_r
U
c
o
-*£ «
«
o
i
i
fc
s
*•
suspec
Ul
to
4^
I
•8
=
O
S
o
o
o
o
§
1
1
1
en
C
1
8
u
o
o
o
0
o
1
'5
Ik
u
ID
m
en
Z
a
0
o
1
1
n
Ul
o
at
i_
3
I
ae
o
o
1
01
•u
o
o
1
1
O)
ID a
u >
— 01
m en
O
o
1
P
!
en
a.
o
o
"8
1
u
1
1
I
II
(9
I
I
IA
II
I
H- ej
§•-
c/>
• S
U 41 >
a — L.
H. _ o>
4i ea
o T3
••— OJ
, 01
u
g-
•^
V*
•&
-------
TABLES
SUMMARY OF ESTIMATED PERCENT EMISSION REDUCTIONS
AND MACT FLOORS FOR EQUIPMENT LEAKS
SOURCE
CATEGORY/
SUBCATEGORY
ABS - Batch Emulsion
ABS - Batch
Suspension
ABS - Continuous -
Mass
ABS Continuous -
Emulsion
ABS - Latex
FACILITY
Monsanto, Addyston
GE, Washington
Dow, Midland
Monsanto, Muscatine
Monsanto, Addyston
Monsanto, Muscatine
Monsanto, Addyston
Dow, Midland
Dow, Torrance
Dow, Allyn's Point
Dow, Hanging Rock
GE, Washington
GE, Ottawa
BF Goodrich, Akron
PERCENT
REDUCTION
91.2
84.1
82.0
79.5
96.1
78.0
90.3
82.7
71.9
38.9
28.1
84.1
43.9
32.7
MACT FLOORS
EXISTING
FACILITIES
84.2
87.1
62,4
64.0
32.7
NEW
FACILITIES
91.2
96.1
90.3
84.1
32.7
14
-------
I
I
I
I
I
I
I
I
I
I
I
f
I
I
t
I
I
I
I
TABLES
SUMMARY OF ESTIMATED PERCENT EMISSION REDUCTIONS
AND MACT FLOORS FOR EQUIPMENT LEAKS
SOURCE
CATEGORY/
SUBCATEGORY
PS Continuous
FACILITY
Dow, Joilet
BASF, Holyoke
Monsanto, Addyston
Huntsman,
Chesapeake
Novacor, Indian
Orchard
Dow, Torrance
Novacor, Decatur
Huntsman, Belpre
Dow, Riverside
BASF, Santa Ana
Dow, Midland
BASF, Joilet
Dow, Allyn's Point
GE, Selkirk
American Polymers
Fina Oil, Carville
Dow, Hanging Rock
Amoco, Joilet
Huntsman, Peru
Chevron, Marietta
Kama, Hazelton
PERCENT
REDUCTION
85.8
81.9
80.8
79.6
78.6
76.9
75.9
72.5
70.8
70.7
59.5
51.5
47.4
46.8
33.0
25.7
23.9
22.1
0
0
*
MACT FLOORS
EXISTING
FACILITIES
81.3
NEW
FACILITIES
85.8
Insufficient information to estimate emissions and emission reductions.
15
-------
TABLES
SUMMARY OF ESTIMATED PERCENT EMISSION REDUCTIONS
AND MACT FLOORS FOR EQUIPMENT LEAKS
SOURCE
CATEGORY/
SUBCATEGORY
EPS
Batch
FACILITY
Huntsman, Rome
Scott, Saginaw (1)
Scott, Forth Worth
BASF, South
Brunswick
Arco, Monaca
Huntsman, Peru
Arco, Painesville
Huntsman,
Chesapeake
American
Polystyrene, Torrance
American Polymers,
Oxford
ARCO, Monaca
Scott, Saginaw (1)
Scott, Saginaw (2)
Dan, Leola
Amoco, Willow
Springs
Dan, Ownesboro (1)
Rohm and Haas,
Phila.
Dart, Owensboro (2)
Huntsman, Peru
PERCENT
REDUCTION
75.4
33.0
33.0
28.4
32.4*
0
0
78.5
69.9
33.8
32.4
30.7
30.7
29.7
26.5
0
0
0
0
MACT FLOORS
EXISTING
FACILITIES
40.4
49.0
NEW
FACILITIES
75.4
78.5
* Estimate based on equipment counts for entire facility, see PS-batch estimate.
16
-------
I
I
I
I
I
I
I
I
I
I
I
f
I
I
fi
I
I
I
I
TABLES
SUMMARY OF ESTIMATED PERCENT EMISSION REDUCTIONS
AND MACT FLOORS FOR EQUIPMENT LEAKS
SOURCE
CATEGORY/
SUBCATEGORY
MBS
Nitrite
SAN - Batch
SAN - Continuous
MABS
ASA/AMSAN
FACILITY
Elf Atochem
Kaneka
Rohm and Haas
BP Chemicals
Monsanto, Addyston
Monsanto, Muscatine
Monsanto, Addyston
Dow, Midland
GE, Bay St. Louis
GE, Washington
GE, Selkirk
PERCENT
REDUCTION
i
94.0
84.7
4.7
74.5
88.9
76.3
88.6
77.0
67.8
84.1
0
MACT FLOORS
EXISTING
FACILITIES
61.1
74.5
82.6
77.8
84.1
0
NEW
FACILITIES
94.0
74.5
88.9
88.6
84.1
0
17
-------
TABLES
SUMMARY OF ESTIMATED PERCENT EMISSION REDUCTIONS
AND MACT FLOORS FOR EQUIPMENT LEAKS
SOURCE
CATEGORY/
SUBCATEGORY
PET - DMT/BATCH
PET - DMT/CONT.
FACILITY
Hoechst-Celanese (HC),
Spartanburg
BASF, Lowland, TN
Tennessee Eastman
(TE), Kingsport, TN
HC, Shelby, NC
3M, Decatur, AL (1)
3M, Decatur, AL (2)
3M, Greenville, SC
ICI, Fayetteville, NC
ICI, Hopewell, VA
Eastman Kodak,
Rochester, NY
HC, Spartanburg, SC
DuPont, Copper River,
SC
DuPont, Circleville, OH
DuPont, Florence, SC
DuPont, Kinston, NC
DuPont, Old Hickory,
TN
DuPont, Brevard, NC
DuPont, Cape Fear, NC
Carolina Eastman (CE),
Columbia, SC
TE, Kingsport, TN
PERCENT
REDUCTION
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
MACT FLOORS
EXISTING
FACILITIES
0
0
NEW
FACILITIES
0
0
18
-------
I
I
I
I
I
I
I
I
1
I
I
I
I
I
I
I
I
I
I
TABLES
SUMMARY OF ESTIMATED PERCENT EMISSION REDUCTIONS
AND MACT FLOORS FOR EQUIPMENT LEAKS
SOURCE
CATEGORY/
SUBCATEGORY
PET - TPA/CONT.
PET - TPA/Batch
FACILITY
Carolina Eastman,
Columbia, SC (Plant 3)
Carolina Eastman,
Columbia, SC (Plant 2)
Hoechst-Celanese,
Salisbury, NC
Hoechst-Celanese,
Spartanburg
DuPont, Copper River,
SC
DuPont, Kinston, NC
DuPont, Cape Fear,
NC
Wellman, Palmetto, SC
YKK, Macon, GA
Tennessee Eastman,
Kingsport, TN
Hoechst-Celanese,
Greer, SC
Allied-Signal,
Moncure, NC
Shell, Pt. Pleasant, WV
'
Shell, Pt. Pleasant, WV
PERCENT
REDUCTION
28.1
28.1
3.2
, °
0
0
0
0
0
0
0
0
0
0
MACT FLOORS
EXISTING
FACILITIES
11.9
0
NEW
FACILITIES
28.1
0
19
-------
-------
Attachment 7
I
I
I
I
I
Component-specific summary of baseline equipment leak
m HAP emissions
I
I
I
I
I
I
I
I
I
I
I
I
I
-------
-------
MISSIONS
LU
10.
s
II
3
i =
V Q.
3'
• *
V LU
fm
S
CD
ILL
o
>-
CC
1 i
CO
Ia
§
LU
CO
™
1 *
• O
Q.
1 °
I u
^^
1
• i
: «
1
1
k_
5
CO
z
ff\
w
LU
Z
BASEL
LU en
Z_i T-j
-J ^ co
85
gK
0) ^
tr
i o3 °
c c o
CD =
Q.T3
1 °°
CO 5 CO
0) 3 00
s* o
1 "t
to OT en
CD co CO
Q) Q) O
-^ "5 °
tO >
CU CC
— o ro
£» 0 en
P c co
is
Q T-
Q.^ CM
Q. ^]
O1
Q. to o-
C TO
0 CD
O to
T
CC
CD
CM
CM
CM
S
in
0
CO
CM
o
o
• LULULU CDCOCD COCOCOCD
LU LU LU LU LU T. T. ZZZ ZZZ ZZZZ
-------
co
z
o
8
s
LJJ
O
111
LJJ
CQ
LL
O
CC
CO
o
LL
O
LU
a.
CO
I
I-
LJJ
Z
o
a.
§
o
O
\
5
CO
W^
CO
111
z
BASEL
LJJ
BASELIN
TOTAL
CD
1.1
(0 i
fA
^
Q.T3
1
to 12
fD g
> -i
1
O rn
5 c8
^ rn
CD CD
3 ->
(O ^
CL cr
~-~ "o
D) g
to D
II
11
*- ^t ^ co in o
in co N- "fr o>
co r** co r*» co
T- CM i- i-
CM O ^J- O) •* O
T- O h- h- O>
CM T- 1- T-
o o in in in o
o o o o o
^r m in co o> o
CO CO i- O> O
CM CM CO T- CM
in o co co co o
•si- CO CM CO CO
O O T- T- ^- O
O O CO i- CD
O CO CO
O) CO CM i- -^incoocn oooo
T-OOOOOT-OCDCMO)OCOOO OOOO
ooooooor-incMooocomT- oooo
CMOOOOOOOOOOOOOO OOOO
^^ CO CM C\J lO lO oo o en i^ to c^ O) ^^ oj Q) ^~ T— r**.
CD Kf ^^ ^f ^M ^" lO O CM CO O) ^™ ^^ ^f ^~ ^f *3" CO O)
cocMcooco-^ococoincMcoincMT- cor^mh-
T— T—
OOOOOT-OOOO-^-CMCM-^OCOCO oooo
oor^coooocococoT-T-oocoi- oooo
coococDco-^-T-T-oj'sroin^i-cM^- OCOCON
^-CO^^^^CM-^ T- CM i-
ino)c\ioooooocMT-coc\icoT-co in'«-^co
OOCMCOOOi-OCMT-CMO^--^O OOOO
^^ CO ^^ LO ^"^ ^^ CO ^^ ^«t" ^^ ^^ ^^ ^^ ^^ ^"^ ^^ ^"^ ^"^ ^
^3 ^^ ^J" ^D C5 CO T~~ C) ^J T™~ CM ^3 ^^ ^** C3 ^D ^3 ^D C
T- -si-in °^S^$2?!^ T^Tl
Ti I I I I i i iTTTTTT LULLJUJUJ
_i _j _i _i _i _i _i _i _i _i _j _i _i _i _i cr cc cc cc
cococococococococococococococo cocococ/
-------
I
I
I
I
ft Attachment 8
Facility-specific baseline emissions summary
I
I
1
I
I
I
I
I
I
I
I
I
I
I
-------
I
I
I
I
1
I
I
I
I
I
I
I
I
I
I
I
I
I
I
^^
^
5
w
c
o
55
w
E
UJ
a.
^[
X
o
c
"55
CO
CO *
2m
g
CO
«£
UJ
UJ
z
UJ
^A
CO
CO
g
ii
a
0-
CO
1
f
13
0
<
li-
ra
4-1
0
1—
c
CD w
E •*
•S" CD
^
UJ
«»
2 "3
5
T3
C
UJ
*2 '
C "^
CD «*
^ .55
(0
(A
(D "O
O C
O UJ
W 1
Q. £
Q
LL
CD
O)
cc
c
CO
bcategory/
Facility ID
a
CO
CO
O)
o>
CM
CO
in
00
TT
in
o>
o
^.
CO
CO
o
o"
tyl Rubber
BR-1
3
CQ
CM
i
CM
N."
CM
N-
CO
in
CO
^
o'
,_
o
y
c
•r»
Ml
•o
>>T-
li
Js UJ
C
O
'5.
UJ
o
00
*~
TT
00
CO
,,_
o
1^
r-.
CM
*•
CO
00
k.
CD
•d CO
ijj
C
_o
>.
Ai
i uj
">
s
UJ
0 r-
CO CO
C3) Tt
in CM
CO CO
CO CM
in o
T- CM
O CO
O CO
CO CD
CO CO
s» ^
CM T-
g10
in o
CM O
CM CO
1 1
CC CC
Q. £L
UJ UJ
CO CM
CM *t
co •§•
O) CO
CO
0
s
co"
O) CM
N- CM
5 CM
N-
T-
CO 1-
in o
co
0)
CD i^-
CO 00
f- CO
1-
m
0)
*•
CO h-
o in
00 CM
0)
O)
CM
r- o
^ r>.
in
00
to
2
•* in *T
1 1 S
cc cc 2,
Q- Q- o>
UJ UJ -g
3
CO
CO
O)
CM
^™
in
oo'
CO
CM
o
0
in
§'
CM
m
co"
CO
s
k.
CD
A
lobutylRub
HBR-1
CO
I
^ O)
o> in
CO
,
i- CM
CM" »-"
i- r»
o in
o in*
co in
CO ^f
CM CO
CO O
0) CM
^f CM
CM
O) h-
CD" T-"
CM
C *
£T ®T
So. 0.0
§;>: o uj
x1 «z
CO •*
S" o"
CO
CO
O)
O)
CO
r-
00 CM
co" in"
T- CO
CM
CM
^
cp q
T— ^"
^^
.^
Y-I
CVI
O O)
o" co
in i-
in
CO
CM
CO CO
CD W
O CM
CO
E
CO
o o
o o"
CM
in
5
CO
«
CM co 'r
1 1 £
OO 2,
UJ UJ §?
Z2I
o
^
3
CO
-------
k_
*-fc
^
"ra
5
(0
c
o
'w
w
I
UJ
D_
<
X
CD
c
15
CO *
2 CD
0
CO
CO
UJ
UJ
z
_J
UJ
CO
<
CO
o
u.
FACILITY-SPECI
7!
o
i_
*•«
| 0)
E .*
f a
or
UJ
1 ^
® 0)
£ «S
(0 >
> *
^*
TJ
C
UJ
fi
Is
> 00
CO
CD -0
W v
o c
O UJ
£J.
§
it
CD
O)
2
o
*<
CO
Subcategory/
Facility ID
,_
si
0
CM
CM
q
CO
o>
CO
c
CO
CM
in
x
9)
ca
Nitnle Butadiene L
NBL-1
in N.
O) - N-'
CM
0)
Tt
q o
o in
o
CO
0
•
CO CO
c c
o o>
0 0
in
CO
O CM
0 0
I
r^
NBL-2
NBL-3
Subcategory Totals
u.
m\
Q)
M
.U
J3
3
Nitrile Butadiene R
O) O
SCO
CO
CM
O) CO
oi T-'
in co
CM »-
CM CM
*- Is-
O) TT
CD
N- CO
O CO
CM
O O)
0 O
f CM
I I
DC DC
CD m
zz
h- 0)
CO hi
in
CO
GO
in
CO O)
in *t
T CO
CM
in
CM
^f
t- f-
cvi i-
in
h-
in TJ-
o o
*~
co in
CM in
co
^
*
CO
r-
CO
in o
o o
M-
T—
NBR-3
NBR-4
Subcategory Totals
^ co co in o>
co cp o> o> in
co r^ in o co
m ^- T- CM_
T~ '~
*- •*• TJ- co in
in cp N: Tt oi
CD l*«- CO t"^ CO
»- CM T- i-
CM
in
3
co"
(
CM
CO
s
00 *- O) O CO
CO O CD CM CM
T~
CO
in
CM
o •* o in co r^
•^ o o in T-^ in
-1% 8fc8
o
CO *"
><
n
k.
® CO O O CO O
n CO O O O) CO'
3 £
DC
c
CM
CO
o
•*•
CM"
O)
00
CO
CD
^
(0
•ts co T- o in co
m 0* 0 0 T^ T^
c
ffi
£
CO
^•'
— >, _1
£ 3
^jy Y CM co •<* w -g
§ CO CO CO CO CO *!
S= DC DC DC DC DC C7
S CO CD CO CD CO O
2 CO CO CO CO CO 0)
2 DC DC DC cr tr -a
•9 CO CD CD CD CD o
-^DL Q. Q. Q. D_ .0
0 3
Q. CO
r^
o
o
0
o
o
N.
o
1
PolysulfideRubber
PSR-1
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
k_
-^
5
to
c
o
to
to
E
LU
Q.
^£
X
CD
C
"3
to
OT m
MM Qj
O
CO
CO
5
LU
LU
Z
_J
LU
«£
m
O
LL
o
LU
Q.
CO
1
0
^f
LL
(0
+*
O
aMrt
S
= 5
cr
LU
is
^^ *•/
> 5
TJ
c
LU
CO |
*"* .i
CD JH
^> /v\
Ml
CO
CD ^
o c
O LU
£ I
i
LU
CD
O)
2
0
CO
•^
^t C.
0 >
COS
^^ «P
o u-
jQ
3
CO
ocNcniooo-tT-cooincnocoin
T- in CD h^ oi o in oo" oi 5 ® •r- o CD' ^
co co ^N||• c^i cr^ ^* CD t^' ^* ^^ ^^ f^ m o)
CM CO CM
N." T- oi CD" in CM i- co' **•' CD' in in" in" co" o
CMi-CDCM T-T-T-p-COCO ^"CMi-
r- in oo o> CM
CO
CO
§
^
co-oo^cnoooincocMinh-co-
OOOOCMCMOCMCMCOO^-COCOT-
co t T- in CM T- h-
CM CM
CO
o
CO
(0(0(0(0(0(0(0(0(0(0(0(0(0(0(0
ccccccccccccccc
incn^COCOt-CO-r-CMCOCOT-CDOO
CM CM CO" CD i- in CO CD' CM O CD i- O O C\i
CM
N
00
00
CM
CMcoincMcncoincocooin^cooo)
X-^OOOOOOOOT-OOOOO
CD
(0 '
-J
CO
00
CD
c —
Q) (0
=6 j5
sTi i i i i i i iTTTTTTc?
|CococococococococoWCOCOCOCOCO|
~ 3
CO CO
CO O O CD
*^J* ^5 CO T"
CO T- -r- ^t
O 00 O o co in
CO i- CM
CO
CD
S
CM
S
in o i- oo
en o T- co
^ »— CM
^.
oS
in h- T- co
W CM CO O)
in r^ ^- i^
CM T- CO
CD
to
CO
e co co in in
o to" i^ co CM"
!yj
3
c
in
o>
T—
LU
f^
^- CM O CM CM
^ CM O O iri
^3
3
CC
CO
N.
CD ...
C
o JS
^ £
CO ^- CM CO ^- f~
•S I I I 1 ^
.g LU LU LU LU 0
TT CC DC DC CC O)
03 CD CD CD CD ®
g CO CO CO CO flS
CD (j
>• -°
CO CO
-------
-------
I
I E /R Incorporated.
l
I
I
I
I
I
I
I
I
I
I
I
1
I
I
I
Environmental Consulting and Research
MEMORANDUM
Date: May 10, 1995
Subject: Subcategorization for the Elastomer Production Industry
(Polymers and Resins I)
To: Leslie Evans, ESD/OCG
From: Charlotte ClarK- and Phil NorwoodJ EC/R
This memorandum serves to discuss categorization and
subcategorization of sources within the Polymers and Resins I
emissions source grouping. These sources produce elastomers, or
synthetic rubbers, that are primarily used in the tire and
automotive products industries.
INTRODUCTION
The Clean Air Act as amended in 1990 (1990 Amendments)
required the U.S. Environmental Protection Agency (EPA) to
publish a list of and establish standards for all major and
certain area source categories and subcategories of sources
emitting any of 189 hazardous, air pollutants (HAP). Designation
of categories or subcategories is critical to a regulatory
effort, because the Maximum Achievable Control Technology (MACT)
standard is set based on a measure of central tendency (such as
average) of emissions achieved by all members of the best
performing 12 percent of the existing sources in the category or
subcategory.
Definition of Category and Subcategory
The terms category and subcategory are not defined in
Section 112. However, the preamble to the Initial Source
Category List defines a "category" of sources as "...a group of
sources having some common features suggesting that they should
be regulated in the same way and on the same schedule."*
Because no statutory definition of category or subcategory
existed, and in response to comments provided on the draft source
category list, the EPA elected in the source category list
Federal Register notice to use the term "category" to designate
all of the groupings of sources that emit HAP on the list.^ The
EPA made clear that this decision did not affect the authority of
the Agency to further disaggregate source categories into
subcategories when establishing standards at a later date. Such
subcategories would .be developed.in order to accurately reflect
differences in air emission characteristics within a source
category. . .
3721-D University Drive • Durham, North Carolina 27707
Telephone: (919) 493-6099 . Fax: (919) 493-6393
-------
For the purpose of this memorandum, the term source category
will be generally used to describe groups actually consisting of
original source categories (as included in the EPA's original
list). The term subcategory will be used to reflect further
divisions of listed source categories or the re-combination of
source and subcategories.
Elastomer Categories
The Initial Source Category List contained 39 production
categories for polymers and resins.3 For regulatory development
purposes, the EPA developed 4 groups of Polymer and Resin
production processes, which have been given the names Polymers
and Resins I-IV. Each grouping of polymer and resin products has
similar production processes, product end use, air pollution
emission characteristics, control device applicability and costs,
and regulatory schedule requirements. Nine polymer and resin
products that are considered "elastomers," or synthetic rubbers
and that have similar production, air pollution emission, and
market share characteristics were grouped together in the
Polymers and Resins I Group. For the purpose of this regulatory
effort, these nine source categories are collectively referred to
either as Group I Polymers and Resins or as the elastomer source
categories. Because these nine production categories have
significant similarities, they are being considered together for
regulation in the development of single National Emission
Standards for Hazardous Air Pollutants (NESHAP) for Elastomer and
Synthetic Rubber Production.
EPA's draft schedule published September 24, 1992 (57
FR 44147) slated the above categories of elastomers for NESHAP
promulgation by November 15, 1994. Due to the similarities
between the elastomer products and processes, and the fact that
all nine shared the same regulatory schedule, the EPA studied
these nine source categories together in the Polymers and
Resins I project. The EPA plans to propose the Polymers and
Resins I standard in May 1995, and promulgation is scheduled for
May 1995. Promulgation by this date will avoid the "hammer"
provisions of section 112(j) of the amended Clean Air Act.
The nine source categories for the production of elastomers
are listed below:
Butyl Rubber Production;
Epichlorohydrin Elastomers Production;
Ethylene-propylene Elastomers Production;
Hypalon™ Production;
Neoprene Production;
Nitrile Butadiene Rubber Production;
Polybutadiene Rubber Production;
Polysulfide Rubber Production; and
Styrene-Butadiene Rubber and Latex Production.
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
SOURCE CATEGORIES
For six of the source categories listed, subcategorization
was not necessary. The following paragraphs describe each of
these source categories. Figure 1 provides a schematic diagram
of all source categories and subcategories of elastomers
production.
Epichlorohydrin Rubber
Only one facility was identified that manufactures
epichlorohydrin rubber. Therefore, no variation is believed to
exist in production process or in HAP emitted, and no
subcategorization was warranted for the epichlorohydrin rubber
source category.
Ethylene-Propylene Rubber
The ethylene-propylene rubber (EPR) source category was not
divided into subcategories. Four facilities were identified that
manufacture EPR by the solution process, and one facility was
identified that manufactures EPR by the suspension process.
These plants manufacture several related EPR products — one a
co-polymer product that cannot be vulcanized, and one a
terpolymer product that can be vulcanized. Although some
variation exists in production process between these facilities,
the variations were not sufficient to result in differences in
the level of the standard. Therefore, subcategorization of this
source category was not warranted.
Hypalon™ Rubber
Only one facility was identified that manufactures Hypalon™
rubber. Therefore, no variation is believed to exist in
production process or in HAP emitted, and no subcategorization
was warranted for the Hypalon™ source category.
Neoprene Rubber and Latex
Three facilities were identified that manufacture neoprene
rubber and latex. All use similar production processes that have
similar HAP air emission characteristics. Therefore, for the
purposes of this regulatory effort, one source category was
appropriate.
Polybutadiene Rubber
Five facilities were identified that produce polybutadiene
rubber; all use a solution process. Although polybutadiene
rubber can be made using the emulsion process, no active
facilities were identified that use this process. All five
active facilities use similar production processes that have
similar HAP emission characteristics. Therefore, for the
purposes of this regulatory effort, one subcategory was
appropriate.
-------
«
IM
O.
8
z
O
N
s
JO
3
CO
WJ
i
1
01
I
X
u
CQ
-§
a:
» 5
c o
41 3
""S ^
«r? S?
.£>
•§
0>
O>
* I
I f
s
U
3 £
U 0.
^c
11
T1
*
-T g
X
a
s.l
0
^>
^ J3
— . t!
•3, a>
r^xj
3 «
CD 3
mc*
S 3
1 ss
<§ fi-
f 1
OB K
D
S
ll
3 -D
CQ 43
^Ǥ
rz3 ^*
to
2
1 1
« (i
^ J
2 I
-------
I
I
I
I
I
I
I
1
I
I
I
I
I
I
I
I
I
I
I
Note that, because of significant similarities between
production of polybutadiene rubber and styrene-butadiene rubber
by solution, these two products were combined into one
subcategory (see styrene-butadiene rubber discussion below).
Polysulfide Rubber
Only one facility was identified that manufactures
polysulfide rubber. Therefore, no variation exists in process or
HAP emitted, and no subcategorization was warranted for the
polysulfide rubber source category.
SUBCATEGORIZATION
Within three of the nine elastomer production source
categories, although product end use and production process are
similar, significant variations do exist in manufacturing process
and air pollution emissions. Therefore, the EPA has further
divided these three categories — butyl rubber, nitrile-butadiene
rubber, and styrene-butadiene rubber — into subcategories for
the purposes of regulation in the NESHAP. Another category,
polybutadiene rubber, was combined with one of the new
subcategories due to similarities in process and emissions. The
following sections of this memorandum describe the technical
basis for each subcategorization decision.
Butyl Rubber
The butyl rubber source category was divided into
subcategories for production of butyl rubber and production of
halobutyl rubber. One facility was identified that actively
produces butyl rubber, and one facility was identified that
actively produces halobutyl rubber. Butyl rubber is typically
made by a precipitation (slurry) polymerization process in which
isobutylene and isoprene are copolymerized in methyl chloride
solvent. Halobutyl rubber, or halogenated butyl rubber, is
produced by dissolving butyl rubber in hydrocarbon solvent
(typically hexane) and contacting the solution with gaseous or
liquid elemental halogens such as chlorine or bromine.
Halobutyl rubber was made a separate subcategory from butyl
rubber because of variations in both production process and HAP
emitted. The production process varies in that halobutyl rubber
is formed by using butyl rubber as the raw material and
performing two additional steps — solvent replacement and
halogenation. The HAP emitted varies, because hexane, a listed
HAP, is the typical hydrocarbon solvent used to make halobutyl
rubber in the solvent replacement process. Hexane is not used,
or emitted from the production of non-halogenated butyl rubber.
Further, halobutyl rubber has different end uses than butyl
rubber, because it resists aging to a higher degree than
nonhalogenated rubber, and therefore, is more compatible with
other types of rubber.4
-------
Nitrile-Butadiene Rubber and Latex
The nitrile-butadiene subcategory was divided into
subcategories for production of rubber and production of latex.
Manufacture of nitrile butadiene rubber (NBR) was identified at
four domestic facilities, and manufacture of nitrile butadiene
latex (NBL) was identified at 3 domestic facilities (none of
which also manufacture NBR). In both the rubber and latex
emulsion processes, butadiene and acrylonitrile monomers are
combined in a reactor with a soap solution and additives. The
unreacted butadiene and acrylonitrile are then removed. For
nitrile butadiene rubber, the polymer is coagulated and dried; in
the case of nitrile-butadiene latex, the polymer is not
coagulated or dried, but rather is blended with other specialty
ingredients. The coagulation and drying production steps cause
HAP emissions, and therefore, will be defined and regulated as
back-end operations under this NESHAP. Latex production does not
contain these production steps, and is not believed to produce
significant HAP after the steam stripping operations. Therefore,
NBR and NBL were differentiated into separate subcategories for
the purposes of this NESHAP.
Styrene-Butadiene Rubber
The styrene-butadiene rubber source category was divided
into subcategories for production of rubber by solution,
production of rubber by emulsion, and production of latex.
Four facilities were identified that produce styrene-
butadiene rubber (SBR) by solution. All of these facilities also
produce polybutadiene rubber by solution. Production of SBR by
solution uses the same equipment as production of polybutadiene
rubber by solution, and the processes are identical, except that
styrene is also added to the polymerization operation. For that
reason, one combined subcategory was created for production of
both SBR and polybutadiene rubbers by solution. This process is
subcategorized from the emulsion process, because of the use of
HAP solvents (not used in the emulsion process).
Four facilities were identified that produce SBR by
emulsion, and 15 facilities were identified that produce styrene-
butadiene latex (SBL) by emulsion. In both the rubber and latex
emulsion production processes, butadiene and styrene monomers are
combined in a reactor with a soap solution and additives. The
unreacted butadiene and styrene are then removed. For SBR, the
polymer is coagulated and dried; in the case of SBL, the polymer
is not coagulated or dried, but rather is blended with other
specialty ingredients. The coagulation and drying production
steps cause HAP emissions, and therefore, will be defined and
regulated as back-end operations under this NESHAP. Latex
production does not contain these production steps, and is not
believed to produce significant HAP after the steam stripping
operations. Therefore, SBR and SBL by emulsion were
differentiated into separate subcategories for the purposes of
this NESHAP.
-------
I
I
—
™
•
•
I
I
I
I
I
I
I
I
I
I
I
I
I
REFERENCES
1. U.S. Environmental Protection Agency. Initial List of
Categories of Sources Under Section 112(c)(l) of the Clean
Air Act Amendments of 1990: Notice. Federal Register.
July 16, 1992. 57 FR 31578.
2. Reference 1, p. 31579.
3. Reference 1, p. 31592.
4. Austin, G.T. Shreve's Chemical Process Industries. Fifth
Edition. New York, McGraw-Hill Book Company. 1984. p.
704.
-------
MEMORANDUM
Date: May 10, 1995
Subject: MACT Floors and Regulatory Alternatives for the
Elastomer Production Industry (Polymers and Resins I)
E /R Incorporated.
Environmental Consulting and Research
From: Phil Norwood, EC/]
To: .Leslie Evans, EPA/OAQPS/ESD/OCG
This memorandum presents the approach used to develop
maximum achievable control technology (MACT) floors and
regulatory alternatives for the Polymers and Resins I project.
This memorandum is organized in three sections. First, a brief
background of the project .and the regulatory process is provided.
Second, a discussion is provided of considerations taken in
determining MACT floors. Third, procedures used to determine
MACT floors are described, followed by a subcategory-specific
presentation of the results of the analysis. The final section
is a discussion of the development of regulatory alternatives
more stringent than the MACT floors.
BACKGROUND
Source Categories and Subcategorization
Title III of the amended Clean Air Act requires the
Environmental Protection Agency (EPA) to develop air emission
standards, for all major sources emitting any of the 189 hazardous
air pollutants (HAP's) identified in Section 112(b) of the Act:
On July 16, 1992 (57 FR 31676), the EPA published the initial
list of categories for which standards are expected to be
developed. This list included nine source categories of
"elastomers." These source categories are as follows.
Butyl .rubber
Epichlorohydrin elastomers
Ethylene propylene rubber
Hypalon™
Neoprene
Nitrile butadiene rubber
Polybutadiene rubber
Polysulfide rubber
Styrene-butadiene rubber
EPA's draft schedule published September 24, 1992 (57 FR
44147) slated the above categories of elastomers for NESHAP
promulgation by November 15, 1994. Due to the similarities
between the elastomer products and processes, and the fact that
all nine shared the same regulatory schedule, the EPA studied
these .nine source categories together in the Polymers and
3721-D University Drive • Durham, North Carolina. 27707
Telephone: (919) 493-6099 . Fax: (919) 493-6393
-------
Resins I project. The EPA plans to propose the Polymers and
Resins I standard in May 1995, and promulgation is scheduled for
May 199.6. Promulgation by this date will avoid the "hammer"
provisions of section 112(j) of the amended Clean Air Act.
Based on differences in processes, HAP emissions, and
emission control techniques, the EPA developed the
subcategorization plan shown in Figure 1. The rationale for
subcategorization is addressed in a separate memorandum.1 For
the purpose of this memorandum, the term "subcategory" will be
generally used to describe each of these elastomer processes,
although some of these process types actually consist of source
categories (as included in the EPA's original list),
subcategories of source categories, or the re-combination of
subcategories. The final 12 subcategories include:
Butyl rubber (BR)
Epichlorohydrin elastomers (EPI)
Ethylene propylene rubber (EPDM)
Halobutyl rubber (HBR)
Hypalon™ (HYP)
Neoprene (NEO)
Nitrile butadiene latex (NBL)
Nitrile butadiene rubber (NBR)
Polybutadiene and styrene-butadiene rubber by solution
(PBR/SBR-S)
Polysulfide rubber (PSR)
Styrene-butadiene latex (SBL)
Styrene-butadiene rubber by emulsion (SBR-E)
The approach discussed below for developing the MACT floors and
first regulatory alternatives was applied separately to each of
these subcategories.
Clean Air Act Requirements
The amended Clean Air Act contains requirements for the
development of regulatory alternatives for sources of HAP
emissions. Section 112(d) requires emission standards for HAP's
to reflect the maximum degree of reduction in emissions of HAP's
that is achievable "...taking into consideration the cost of
achieving such emission reduction, and any non-air quality health
and environmental' impacts and energy requirements..." This
control level is referred to as MACT.
The Clean Air Act also provides guidance on determining the
MACT "floor," which is the least stringent level allowed for MACT
standards. For new sources, emission standards "shall not be
less stringent than the emission control that is achieved in
practice by the best controlled similar source." For existing
sources, the emissions standards must be at least as stringent as
either "the average emission limitation achieved by the best
performing 12 percent of the existing sources" or "the average
-------
1
1
1
1
1
•
1
1 1
m s
1.1
1
o
_ GO
I - r
• cd
V o
Xi
ICO
1
??
CD
1*
•§
c
C3
i i
• C
• >>
"o
• ^
1
i
ItX)
K
1
1
1
1
0.
8
2
2s
o
13
£
K
» 8 *-
c ft >£•§
w^a
ft<
'>- »>
•o 2
>»u
j= e
§1
«J
&
•>,«
fs
m^
09
» P
*J
II
^ 3
co<«
IM
J8
s =
r? ^
1 f
f *
« £
Polysulflde
Rubber
4>
CU
1*1
3*
1-
S«
V3
u-
X)
x>
^
d>
.1
•o
n
3
•§.
§
Nitrile-Butadiene
Rubber
K '
» d
J i
1 1
CQ 0
! i
1 n
a Jj
« 1
g S g
i-il J
OQ 5 W
= !,«
U i"
& <£
co g
8
% a
W {X
1.5
I!
I3
ii
x S 1 '
1 f i
•3 al
O o UJ
g g ^
1 3
m =
CQ oa
=§ ^
1 3
z iz
-------
emission limitation achieved by the best performing 5 sources"
for categories or subcategories with less than 30 sources.
Two interpretations have been evaluated by the EPA for
representing the MACT floor for existing sources. One
interpretation is that the MACT floor is represented by emissions
level achieved by all members of the best performing 12 percent.
The second interpretation is that the MACT floor is represented
by the "average" of the best performing sources, where the
average is based on a measure of central tendency, such as the
arithmetic mean, median, or mode. In a June 6, 1994 Federal
Register notice, the EPA presented its interpretation of the
statutory language concerning the MACT floor for existing
sources. This interpretation is that the "average" is more
appropriate, given the statutory language. The determination of
MACT floors for the Polymers and Resins I subcategories was
consistent with this interpretation.
While the MACT floor represents the least stringent level of
control for a standard, the EPA can consider regulatory
alternatives more stringent than the floor. The Clean Air Act
specifies that the EPA consider cost, non-air quality health and
environmental impacts, and energy requirements in the evaluation
of regulatory alternatives more stringent than the MACT floor.
CONSIDERATIONS IN DETERMINING MACT FLOORS
Several fundamental decisions must be made before the MACT
floor can be determined for individual subcategories. These
decisions are discussed below.
Best Performing Facilities
One of the most basic decisions to be made is the
determination of the "best performing" facilities. All of the
subcategories in this project have less than 30 sources, meaning
that the MACT floor must be based on the best performing 5
sources. Only one subcategory, SBL, contains more than 5
sources. Therefore, for all subcategories except SBL, the MACT
floor is based on the "average emission limitation" of all
sources in the subcategory. The determination of the best
performing 5 SBL sources is discussed in the SBL section.
»
Grouping of Emission Sources
Two approaches were considered in the analysis to describe
MACT floors. One approach is to cluster all sources of emissions
at an affected source together. The EPA considered basing the
MACT floors on emission factors (weight of HAP emitted per weight
of product), including all emission source types at each of the
sources in the subcategory. A standard founded on this approach
would allow the owner or operator to control selected emission
points, as long as the facility-wide HAP emission factor was
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
below the level specified in the standard. This approach was
abandoned for several reasons, including confidentiality
concerns, the reliance on inconsistent data to determine the
floors, and the problems associated with the development of
standard methodologies to verify emissions that are applicable
for all sources in the subcategory.
A second approach is an analysis where emission sources are
considered by emission source type. This type of "plank"
analysis was used for this project. For this project, emission
points at elastomer facilities were assigned to one of five
emission source types: storage vessels, "front-end" process
vents, "back-end" process vents, wastewater streams, and
equipment leaks. The process "front-end" includes
prepolymerization, reaction, stripping, and material recovery
operations, while the "back-end" includes all operations after
stripping (predominately drying and finishing).
Additional grouping decisions may be made in the
determination of MACT floors within each'emission source type.
Consideration can be given to the following: equipment type,
equipment size, equipment contents, stream characteristics, and
other elements that can affect the emission potential of an
emission point or the ability to reduce emissions from the point.
For instance, the floor for storage vessels could be
determined without regard to size or contents, or storage vessels
of similar size containing the same material (i.e., all styrene
vessels 10,000 gallons or less) could be analyzed together.
Similarly, the average emission limitation could be determined
for all process vents, or process vents could be separated into
types according to the origin of the vent stream (reactor vent,
stripper vent, etc.) Process vent types could also be based on
generic parameters such as HAP content, flow rate, etc.
Format of the Average Emission Limitation
As discussed above, MACT floors for subcategories in this
project were identified using the "average" interpretation. The
MACT floor levels were established by determining some measure of
central tendency of the emission control for each emission source
type in each subcategory. The average emission limitation could
be expressed in several different formats, such as an emission
factor, a percent reduction, a work practice standard, a specific
type of equipment, or a variety of other options. The
environmental and cost impacts could change depending on the
choice of the MACT floor format.
Use of EON in Floor Determinations
As described above, many complexities exist in the
determination of MACT floors. Although, the EPA considered
direct approaches to determine the MACT floors, problems arose in
-------
each approach. Most of these problems were a result of the fact
that, while facilities in a subcategory produce the same product,
specifics of the process (and associated emission points) varied
considerably. Thus, comparison of control techniques was
inappropriate, when the origin and characteristics of streams of
the same emission source type were so different.
The EPA studied methods to simplify the MACT floor analysis,
and decided to use the Hazardous Organic NESHAP, or HON (40 CFR
63 subparts F, G, and H), in the MACT floor analysis. The
rationale for this conclusion is provided in this section.
First, many similarities exist in the equipment, emissions,
and control techniques between the elastomer industry and the
synthetic organic chemical manufacturing industry (SOCMI)
regulated by the HON. The HAP monomers and solvents used in the
elastomer industry are all SOCMI chemicals, and some elastomer
processes are co-located with SOCMI processes.
The HON contains emission limitations for five emission
source types: process vents, storage vessels, transfer
operations, wastewater, and equipment leaks. These source types
closely resemble those of Polymers and Resins I. For each
emission source type, applicability is based on "generic"
characteristics of an emission point such as HAP emissions, HAP
concentration, flow rate, size of the equipment, etc. These
characteristics are also common to Polymers and Resins I
emissions source types.
Another practical reason for using the HON requirements is
that the HON provides "ready-made" alternatives. The HON takes
into account equipment type, equipment size, equipment contents,
stream characteristics, and other important aspects of the floor
determination discussed above.
Due to the similarities between the SOCMI and elastomer
industries, and other reasons discussed above, the EPA concluded
that the HON requirements for storage vessels, process vents,
wastewater, and equipment leaks are appropriate to use to
determine the MACT floor for the elastomer industry. The
determination of the MACT floor using the HON is described in the
procedures section of this memorandum.
Other Emission Source Types
The HON requirements noted above apply to three of the five
elastomer emission source types and part of a fourth: storage
vessels, wastewater, and equipment leaks, as well as front-end
process vents from continuous processes. However, the HON
process vent provisions exempt vents from batch processes, and
some of the front-end operations in the elastomer industry are
operated in a batch mode. In addition, the process back-end
operations in the elastomer industry are unlike any operations in
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
the HON. Therefore, different approaches were needed to
determined the floors for these two emission source types.
Use of the Batch processes ACT for batch front-end process vents
The EPA also would have preferred a direct approach for
determining MACT floors for batch front-end process vents.
However, the variability in processes, the fact that vents were
seldom identified as batch vents, and the fact that many batch
vents were combined with continuous vents, made any direct
approach infeasible. Therefore, the EPA also looked for an
approach that was feasible to implement.
In 1993, the EPA published the guidance document, "Control
of Volatile Organic Compound Emissions From Batch Processes"
(EPA-453/R-93-017). This alternative control technique (ACT)
document provides guidance to State and local air pollution
regulatory agencies on the development of regulations for air
emissions from batch processes.
The guidance in the document is intended to apply to all
batch operations. While the polymer and resin process described
in the document (epichlorohydrin-based non-nylon polyamide) was
not an elastomer process, the equipment, emission sources and
control technologies for the industry studied are similar to
those in the elastomer industry.
A great deal of the analysis in the ACT was dedicated to the
generation of process vent applicability criteria for three
levels of control: 90, 95, and 98 percent control. As with the
HON, the applicability criteria are based on general vent stream
characteristics, and not on process-specific parameters. These
characteristics include the volatility of the organic material in
the vent stream, the annual emissions, and the average flow rate
of the stream.
Due to the similarities between the processes studied in the
ACT, and the general nature of the applicability criteria, the
EPA concluded that these criteria were appropriate to use in
defining the MACT floor for front-end process vents from batch
processes in the elastomer industry. The determination of the
MACT floor using the Batch ACT is also described in the
procedures section of this memorandum.
Back-end process vents
Many of the elastomer subcategories produce dry elastomer
products. As described in detail in the industry description
memorandum, the processes to "finish" the crumb rubber include
many unit operations that do not have process vents comparable to
SOCMI process vents. The emissions from many of the back-end
operations are not completely captured and vented to traditional
vent stacks. Finishing operations are often located in large
-------
8
warehouse-type buildings, and process fugitive emissions are
removed from the work space through roof fans and other general
building ventilation. In addition, the vents from the largest
emission source, crumb dryers, typically have large flow rates
and low HAP concentrations due to the high air flow necessary to
properly dry the polymer. HON process vent control methods are
not conducive to or cost-effective for these dryer vents.
Therefore, for the process back-end, the MACT floors were
determined on a subcategory-specific basis, as described in the
procedures section of this memorandum.
PROCEDURES USED TO DETERMINE MACT FLOORS
Two basic procedures were used to determine the MACT floors
for the Polymers and Resins I subcategories. The first, the HON-
based approach, compared existing levels of control with the
level of control that would be required at elastomer facilities
if the HON requirements were applied. This approach was used for
storage vessels, wastewater, and equipment leaks. For front-end
process vents, the same approach was used, except that the 90
percent control level from the Batch ACT was used for batch
processes, and the HON process vent provisions were used for
continuous processes. The 90 percent Batch ACT control level was
selected, because the estimated cost-effectiveness for this level
was comparable to the cost-effective of the HON continuous vent
provisions (approximately $3,000 per Megagram). A second
approach was used to assess the average emission limitation for
back-end process emissions, and was based on emission reduction
techniques used for each specific subcategory. Both of these
approaches are discussed in more detail below.
HON-Based Approach - Existing Sources
The concept of this approach is to determine how controls at
elastomer facilities compare to the level of control that would
be required by the HON (and by the Batch ACT). This type of
analysis does not define specific floors in terms of numeric
values. Rather, the conclusion of each floor analysis using this
HON-based approach is whether the MACT floor is less stringent
than, more stringent than, or equal to, the HON-level of control.
This section describes the general HON-based approach used for
all emission source types (i.e., storage vessels, front-end
process vents, wastewater streams, equipment leaks), followed by
specifics of the individual emission source types.
General approach
For each facility in each subcategory, the existing controls
were identified for each emission point. The existing level of
control was then compared to the level of control that would be
required by the HON/Batch ACT, and the emission point was noted
as being controlled at a level less stringent than the HON/Batch
ACT requirements (less than HON), a level equivalent to the
-------
After each emission point at each facility was
characterized, all emission points of a given emission source
type were grouped together and a facility-wide determination was
made for each emission source type. For instance, if an emission
point was controlled at a level less stringent than the HON, and
no other emission point of the same type was controlled at a
level more stringent than the HON, the facility was classified as
"less than HON" for that emission source type. If all controls
at the facility were equivalent to the HON levels, the facility
was classified as "equal to HON." If one or more points was
controlled at a level more stringent than the HON, and no point
of the same type was controlled at a level less stringent than
the HON, the facility was classified as "greater than HON."
A clarification is necessary related to uncontrolled
emission points. If an emission point was uncontrolled, and the
HON/Batch ACT would not require control for that point, the level
of control is equivalent to the HON/Batch ACT level of control.
Therefore, the floor for a subcategory could be the HON/Batch
ACT, when in fact all emission points of that particular emission
source type were uncontrolled.
If a facility reported different levels of control (in
comparison to the HON) within one emission source type, an
additional analysis was necessary to classify the facility. In
these situations, the. existing emission level was compared to the
emission level that would be required if HON controls were
applied. If the existing emissions were less than the HON-level
emissions, the facility was classified "greater than HON," but if
the HON-level emissions were lower, the facility was classified
"less than HON."
The floor for each emission source type was then defined for
each subcategory as less than, equal to, or greater than, the HON
level of control. This determination was based on the majority
of individual facility classifications for the subcategory.
Storage vessels
The applicability of the existing HON storage tank
provisions is based on tank size and vapor pressure of the total
organic HAP in the storage tank. Vessels meeting the
capacity/vapor pressure criteria must be controlled using one of
three control techniques: (1) an internal floating roof, (2) an
external floating roof, or (3) a closed vent system to a control
device (95 percent emission reduction). If the maximum true
organic HAP vapor pressure of the vessel contents is high enough,
the control option is limited to a closed vent system vented to a
control device. Pressure tanks (greater than 23 psi) are exempt
from the HON requirements.
-------
10
In order to evaluate the applicability of the HON provisions
to elastomer storage vessels, the maximum true vapor pressures of
monomers, solvents, and additives used at elastomer facilities
were estimated, and the level of control that would be required
determined.
For each facility in each subcategory, the existing storage
vessel controls were noted and summarized by individual HAP. The
existing level of control was then compared to the HON-level of
control for each vessel, and the MACT floors were determined as
discussed above in the general HON-approach section. Table 1
shows the level of control that would be required by the HON for
HAP's used in the elastomer industry.
Front-end process vents
The HON process vent provisions apply to continuous process
vents emitting streams containing more than 0.005 weight-percent
HAP. Control (98 percent) is required for each process vent with
a flow rate greater than or equal to 0.005 standard cubic meters
per minute, an organic HAP concentration greater than or equal to
50 ppmv, and a total resource effectiveness (TRE) index value
less than or equal to 1.
The Batch ACT process vent provisions apply to volatile
organic compound (VOC) emissions from batch process vents. In
this analysis, only the organic HAP emissions were considered.
The first level of applicability in the Batch ACT is based on
annual emissions. If annual HAP emissions, calculated before a
control or recovery device, are less than specified levels,
control is not required. For the 90 percent control level, these
"cutoff" levels are between 7,300 and 11,800 kilograms per year,
depending on the volatility of HAP's emitted. If annual
emissions were greater than the cutoff level, emissions were
input into an equation from the ACT to determine a cutoff flow
rate. If the actual flow rate of the batch vent stream is less
than the cutoff flow rate, 90 percent control is required.
EC/R applied the HON or Batch ACT criteria to each process
vent for which the necessary vent stream parameters were
provided. In some instances, EC/R was able to estimate the
necessary parameters. In situations where a continuous vent
stream was controlled using a thermal oxidizer or flare, EC/R
applied the HON criteria to the stream prior to the control
device, to assess whether the stream would have required control
based on the HON criteria. Similarly, in situations where a
batch vent stream was controlled using a control or recovery
device, the Batch ACT criteria were applied prior to the device.
The existing level of control was then compared to the level of
control that would be required by the HON or Batch ACT.
Information was seldom provided that identified whether the
vent was continuous or batch. The HON criteria were applied to
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
11
TABLE 1. EON STORAGE TANK REQUIREMENTS FOR ELASTOMER
RAW MATERIALS
HAP Stored
Control Required by HONa
Largeb Tanks Smallb Tanks
Acrylamide
Acrylic acid
Acrylonitrile
1,3-Butadiene
Carbon tetrachloride
Chloroprene
Epichlorohydrin
Ethyl Acrylate
Ethylene dichloride
FormaIdehyded
n-Hexane
Methyl chloride
Toluene
Styrene
Vinylidene chlorine
None
Control
Control
Restricted Control
Control
Control
None
None/Control
Control
None
Control
Restricted Control
Control
None/Control
Restricted Control
None
Control
Control
Restricted Control
Control
Control
None
None
None
None
Control
Restricted Control
None
None
Restricted Control
a The HON requires control by one of three methods: internal
floating roofs, external floating roofs, or closed vent systems
to a control device that achieves 95 percent control. "Control"
indicates storage vessels containing the noted HAP have choice of
one of these three options. "Restricted control" indicates that
the only acceptable control option is a closed vent system and a
control device. None/Control means that controls are not
required for existing sources, but control would be required for
vessels at new sources.
b Large vessels are those with capacities greater than 40,000
gallons. Small tanks are those with capacities between 20,000
and 40,000 gallons.
c Formaldehyde is stored as formalin, which is a 50 percent
formaldehyde solution in water. While the vapor pressure of pure
formaldehyde would require control by a closed vent system and a
control device, the vapor pressure of formaldehyde over water
would is quite low and would not trigger any HON control.
-------
12
all vents, unless the vent clearly originated from a batch
process, in which cases the Batch ACT was used. In a few
situations the vent appeared to be a batch vent, but this was not
explicitly stated. In these situations both the HON and Batch
ACT were.applied.
For each reported vent stream at each facility, EC/R
identified the vent as "greater than HON/ACT," "less than
HON/ACT," or "greater than HON/ACT." Then the front-end process
vent level of control for each facility was classified, and the
subcategory floor determined as discussed above in the general
HON-approach section.
Wastewater
The HON requires wastewater streams at existing sources that
have a total volatile organic HAP concentration of 1,000 ppmw or
greater and a flow rate of 10 liters per minute or greater (at
the point of generation), or a total volatile organic HAP
concentration of 10,000 ppmw or greater at any flow rate, to be
managed in controlled equipment and treated to reduce the HAP
concentration.
EC/R applied these criteria to uncontrolled wastewater
streams at each facility. Where possible, the wastewater stream
characteristics provided by industry were used. Where
appropriate data were not provided, EC/R extrapolated flow rates,
HAP concentrations, and emissions from other facilities in the
subcategory. The stream characteristics were then compared to
the HON applicability criteria to assess whether the HON would
require control. In situations where a wastewater stream was
controlled using a steam stripper or other HON-acceptable control
method, EC/R compared the flow and HAP concentration of the
stream prior to the control device, to assess whether the stream
would have required control based on the HON criteria.
It should be noted that the information regarding wastewater
control appears to be inconsistent. During meetings with
industry representatives, control of wastewater using steam
strippers has been indicated to be quite common in this
industry.2>3>4 However, the plant-specific data provided in
response to Section 114 information requests, which were used in
the floor analyses, do not show significant control.
Each wastewater stream, and in turn each facility, was
classified as "less than HON," "equal to HON," or "greater than
HON." The floor for wastewater for each subcategory was then
determined as discussed above in the general HON-approach
section.
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
13
Equipment Leaks
The HON equipment leak provisions require a combination of
leak, detection, and repair (LDAR) procedures and equipment
requirements. Six of the subcategories included in this project
are subject to the HON equipment leak provisions through
subpart I of part 63. Specifically, these subcategories are
EPDM, HYP, PBR/SBR-S, PSR, SBL, and SBR-E. Therefore, all
facilities in these subcategories are required to have a HON
equipment leak program in place. However, the requirements of
subpart I are HAP-specific and may not affect all components in
HAP service at the facility. Facilities that reported the use of
HAP's other than those covered by subpart I were assumed to not
be controlled to the HON level.
In order to compare the existing control levels to the HON
levels for the remaining subcategories, baseline control levels
were assessed for each type of component at each facility. These
levels were based on information submitted by the facility or on
State equipment leak regulations affecting the facility.
A qualitative assessment was then made for each facility to
determine whether the existing level of control was less than,
equal to, or greater than the HON. For facilities in these
subcategories, the baseline level of control was always
determined to be less than the HON.
HON-Based Approach - New Sources
The HON-based approach used for new sources was similar to
the existing source approach. The existing level of control for
each emission point was compared with the level that would be
required by the HON new source requirements. No difference
exists in the Batch ACT requirements for new and existing
sources.
After each emission point at each facility was characterized
as less than, greater than, or equal to, the new source HON, all
emission points of a given emission source type were grouped
together and a facility-wide determination was made for each
emission source type. This determination was conducted as
described in the existing source general approach discussion.
The new source floor was then defined for each emission
source type for each subcategory as less than, equal to, or
greater than, the new source HON level of control. This
determination was based on the single facility with the highest
level of control in the subcategory. If a single facility was
classified as equivalent to the new source HON, and no facilities
were classified as greater than the new source HON, the new
source floor was identified as the new source HON level of
control. However, if one facility was classified as greater than
-------
14
the new source HON, the determination of a new source floor
greater than the new source HON level was necessary.
Approach For Process Back-End Emissions - Existing Sources
As noted above, emissions from the back-end of elastomer
production processes are not amenable to HON-type applicability
and control provisions. In only one instance did a facility
report that add-on control was used to reduce back-end HAP
emissions [a facility producing polybutadiene rubber and styrene-
butadiene rubber by solution (PBR/SBR-S)]. However, facilities
in three subcategories [ethylene propylene rubber (EPR),
PBR/SBR-S, and SBR-E] reported permit conditions requiring that
the amount of residual HAP remaining in the polymer be reduced by
"improved stripping" prior to drying (i.e., "residual HAP
limits").
MACT floors were determined on a subcategory-specific basis
for the back-end emissions from these three subcategories. The
format for each floor is in terms of stripper performance, or the
amount of HAP remaining in the polymer after the stripping step.
In the cases of EPR and PBR/SBR-S, the floor is expressed as the
weight of residual HAP per weight of dry polymer. In the case of
SBR-E, the floor is expressed as the weight of residual HAP per
weight of latex leaving the stripper. These formats were
selected to be compatible with the formats of applicable State
permit conditions for the three subcategories.
A number of statistical parameters can be used to establish
the numerical level of the MACT floor, including the arithmetic
mean, median, or mode. Because the format of the floor is in
terms of HAP per polymer produced, and production data were often
claimed as confidential, the selection of any specific parameter
is complicated by the need to maintain confidentiality, and by
the small number of plants in each subcategory. That is, if the
floor for a given subcategory was based on a rigorously computed
arithmetic mean, companies could use the floor to calculate
production figures for their competitors. To avoid this problem,
the floor for each subcategory was established at a level between
the mean, median, and mode. The confidential files for this
docket contain a memorandum that describes in more detail the
basis of the MACT floors for back-end operations.^*
In each case, the floor is expressed as a maximum weekly
average residual HAP level. For SBR-E, the weekly floor was
computed from maximum weekly average HAP in latex data submitted
by the plants. For EPR and PBR/SBR-S, the weekly floors are
based largely on annual emissions and production data submitted
by the plants. A limited amount of weekly data were used to
adjust the annual data to allow for some temporal variability in
residual HAP levels.
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
15
The weekly time frame was selected for two reasons. First,
the waiting period to obtain residual monomer results for a given
sample will be up to three days for some categories. The weekly
timeframe allows a plant to compensate for a "bad" batch and
still achieve the standard. Second, some grades of polymer are
more difficult to strip than others. Because the MACT floor is
based on an overall average, some of the less strippable grades
may have residual HAP levels that exceed the average floor level.
A shorter timeframe might preclude plants from producing these
grades at all. The weekly timeframe gives plants the opportunity
to continue producing these grades, as long as average emissions
are below the standard.
Carbon disulfide emissions. The discovery of carbon
disulfide emissions from dryer vents at SBR-E facilities occurred
relatively late in the information gathering process for this
standard. Therefore, the amount of information available to
determine the floor for this emission source was limited. Data
were provided that indicated measured carbon disulfide
concentrations in dryer stacks. The MACT floor was calculated as
the average of the concentrations for those grades of SBR-E
polymer that used a sulfur-containing shortstopping agent in
their production.
Approach For Process Back-End Emissions - New Sources
The new source MACT floors for back-end process emissions
should represent the level achieved by the best-performing single
facility. However, a major problem exists in the use of this
approach, because the emission factor or residual HAP level for a
single facility is almost always confidential, so the actual
level of the standard could not be revealed.
Therefore, the following approach was used to set the new
source MACT floor. The ratio of the existing source MACT floor
emission factor/residual HAP level to the best performing single
facility emission factor/residual HAP was determined for each
subcategory. The arithmetic average of all subcategory ratios
was then applied to the existing source floor levels to determine
new source floors.
The following example is provided to illustrate this
approach. Assume' existing source MACT floor emission factors for
three subcategories were 5, 10, and 15 kilograms per Megagram of
rubber. The corresponding emission factors for the three best
controlled facilities in each subcategory were 2, 3, and 5,
respectively. The ratios of the best controlled source to the
existing source floor are therefore 0.4 (2-^-5), 0.3 (3-^10), and
0.33 (5-M5) . The arithmetic average of the ratios is 0.34. This
average ratio was then applied to each of the existing source
floors to set the new source level, which would be 1.7, 3.4, and
5.15 kilograms per Megagram.
-------
16
RESULTS OF ANALYSIS
Table 2 presents a summary of the MACT floors. In the
following sections, results of the analyses are presented. For
each subcategory, the existing and new source MACT floor
conclusions are provided, along with a brief discussion.
Attachment 1 to this memorandum includes a series of tables
detailing the facility-specific existing control levels and floor
conclusions.
Butyl Rubber
Butyl rubber is a single plant subcategory. Therefore, the
existing level of control at this facility represents the MACT
floor for the subcategory.
The three HAPs stored at the butyl rubber facility are
hexane, methyl chloride, and methanol. All of the storage
vessels are controlled in accordance with the HON. Therefore,
the floor for storage vessels was determined to be equal to the
HON.
All front-end process vent streams are controlled by a
flare. However, the streams would be classified as halogenated
vent streams under the HON. The HON does not allow the control
of a halogenated vent stream using a flare, but would require the
stream be controlled by an incinerator followed by a scrubber.
Therefore, the existing level of control for these vents is less
stringent than the HON. In addition, an uncontrolled maintenance
vent exists that appears to be a batch process vent. Application
of the Batch ACT criteria showed that this vent would require
control. The floor for front-end process vents was determined to
be less stringent than the HON/ACT.
Because no add-on control or permit conditions were reported
for the process back-end, the floor for process back-end
emissions was defined as no control.
Uncontrolled wastewater streams were reported by the
facility that would be subject to the HON control requirements.
Therefore, the floor for wastewater was determined to be less
stringent than the HON.
The facility reported that equipment leak emissions were
controlled by the combination of a leak detection and repair
program and some "leakless" equipment. However, elements of the
program were less stringent than the HON level, so the floor for
equipment leaks was determined to be less stringent than the HON.
In summary, the MACT floors for the butyl rubber subcategory
are as follows. For storage vessels, the floor was determined to
be equal to the HON. For front-end process vents, wastewater,
and equipment leaks, the floor was determined to be less
stringent than the HON (HON/ACT). For back-end process
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
H
A
a
MACT Floors
4>
a
v •
a .*
cu a
•H 0
9 iJ
h
0
-P
I
4»
S
Back-End Process
Emissions
M
•P
•O a
a 0
w ^
1
4J a
a M
S0
u
b 0
cu
o
&»
0
k
0
•P
en
fr
0
01
V
0
u
•9
u
z
o
X
V
z
g
V
no control
S
rtj
**^^
z
o
V
1
II
\
^
^1
4J
3
m
z
o
X
V
0
X
II
no control
H
u
rtj
•^^
z
o
X
V
o
X
II
c
•p^
Vl
•o
>^
o
M
0
•H
J2
u
•^4
Ok
u
z
o
X
V
z
g
II
MACT floor
emission factor
EH
rt
Z
O
X
V
I
V
01
Q)
•H
N^
Cu
o
Vj
0.
Q)
C
01
1— 4
^1
£
^J
W
Z
o
X
V
z
g
II
no control
g
rtj
'x^
Z
O
X
V
o
X
V
.-1
^
4J
3
.Q
0
(— t
cd
X
Z
o
X
II
z
g
II
no control
EH
O
'•C
*"S^
Z
O
X
II
§
X
II
%
c
0
f—\
nj
ft
^1
X
z
o
X
V
z
g
II
no control
EH
O
rtj
•"••^
Z
0
X
V
1
V
0)
c
0>
ft
0
01
z
z
o
X
V
z
g
II
no control
EH
U
rtj
•""^.^
Z
O
X
II
z
g
V
X
01
4J
cd
0>
c
01
*•-)
TJ
cd
-P
m
01
.-H
*«H
^
4J
z
z
o
X
V
z
g
II
no control
EH
U
rtj
•"•^
Z
O
X
II
z
o
X
V
01
XI
3
a
0)
c
0)
*^H
•a
cd
4J
3
m
o>
— i
^i
[ \
-H
Z
z
o
X
V
z
g
II
MACT floor
emission factor
EH
O
^••^
Z
o
X
II
z
o
X
II
0)
c
0) >i
jj ^J
CO Q)
s*"1^ O
0> XI
C 3
0) tf
T3 0)
cd C C
•P 01 0
3 -r4 -H
XI 'O 4J
>i (d 3
-H 4J '-t
O 3 O
cu m w
z
o
X
V
z
g
II
no control
H
O
•X^
Z
o
X
M
z
o
X
II
0)
•o
-•H
HH
i-H
3
(0
I-l
o
z
o
X
II
z
g
II
no control
EH
O
-X^
Z
O
X
II
1
II
X
01
4J
( I
(U
c
01
mf4
•a
cd
4J
3
n
0)
0)
^
4J
Z
o
X
II
z
g
II
MACT floor latex
styrene
concentration
g
rtj
^.^
Z
o
X
II
o
X
II
M
01
XI
3
01
c
01
.,-t
•o
cd
4-1 C
3 0
03 -H
0)
0) rH
C 3
0) g
s^
4-1 >l
CO XI
-------
18
emissions, the floor was determined to be no control.
Epichlorohydrin Elastomer
Epichlorohydrin elastomer is a single plant subcategory.
Therefore, the existing level of control at this facility
represents the MACT floor for the subcategory.
The HAP's reported to be stored at the epichlorohydrin
facility are epichlorohydrin, propylene oxide, ethylene oxide,
and toluene. All of the storage vessels are controlled in
accordance with the HON, so the floor for storage vessels was
determined to be equal to the HON.
All reported front-end process vent streams are controlled
by a flare. However, sufficient information was not provided to
estimate the stream characteristics prior to the flare. This
control, and therefore the floor, was assumed to be equal to the
HON/ACT.
Because no add-on control or permit conditions were reported
for the process back-end, the floor for process back-end
emissions was defined as no control.
No wastewater streams were reported by the facility that
would be subject to the HON control requirements, and no
wastewater control was reported. Therefore, the floor for
wastewater was determined to be equal to the HON.
The facility reported that equivalent leak emissions were
controlled by a leak detection and repair program. However,
elements of the program were less stringent than the HON level,
so the floor for equipment leaks was determined to be less
stringent than the HON.
In summary, the MACT floors for the epichlorohydrin
elastomer subcategory are as follows. For storage vessels and
wastewater, the floor was determined to be equal to the HON. For
equipment leaks, the floor was determined to be less stringent
than the HON. The floor for front-end process vents was assumed
to be equal to the HON/ACT. For back-end process emissions, the
floor was determined to be no control.
\
Ethylene Propylene Rubber
Five active facilities were identified that produce ethylene
propylene rubber. As discussed in the subcategorization
memorandum, four of the EPDM facilities employ a solution process
that uses a HAP solvent (hexane), and the fifth uses a suspension
process.1 The suspension process facility was included in the
determination of MACT floors using the HON-based approach.
However, the differences in the processes made consideration of
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
19
the suspension process inappropriate in the calculation of the
process back-end floor.
The HAP's stored at EPDM facilities include hexane and
toluene. Four of the five EPDM facilities reported existing
storage tank controls that were less stringent than the level of
control that would be required by the HON. The controls less
stringent than the HON included hexane tanks controlled by
condensers with control efficiencies less than the HON, and
toluene and hexane storage tanks with fixed roof uncontrolled
tanks. One facility did not report sufficient information to
determine a classification for storage tank controls. Because
four of the five facilities are controlled at a level less
stringent than the HON, the floor for storage vessels was
determined to be less stringent than the HON.
No EPDM facility reported a batch process, so the HON
process vent provisions were applied to all front-end process
vents. At one facility, the estimated TRE of a controlled stream
was greater than 1.0, so controls at this facility were more
stringent than the HON. One facility reported that a halogenated
vent stream was controlled by a boiler, and an uncontrolled vent
stream with a TRE less than i.o. Another facility also had an
uncontrolled vent stream with a TRE less than 1.0. Controls at
these two facilities were less stringent than the HON. One
facility reported controls in accordance with the HON. The final
facility did not report sufficient information for front-end
process vents. With two facilities equal to the HON, one less
than, and one greater than, the floor for front-end process vents
was determined to be less stringent than the HON/ACT.
One EPDM facility reported a residual HAP permit condition,
establishing that the reduction of back-end HAP emissions was
demonstrated for this subcategory. The average, mode, and median
annual emission factors were determined and adjusted to weekly,
as described in the approach section. For existing sources, the
floor was determined to be 7 kg HAP per megagram dry crumb
rubber, on a weekly average basis. The new source floor was
determined to be 4 kg/Mg. As noted above, the suspension process
EPDM facility was not included in the back-end floor analysis.
No wastewater streams exist at EPDM facilities with reported
(or extrapolated) characteristics that would require control by
the HON, and no wastewater controls were reported. Therefore,
the floor was determined to be equal to the HON for wastewater.
Four facilities reported that equipment leak emissions were
controlled by a leak detection and repair program, and one
facility also reported some leakless equipment. However,
elements of the programs at three of these facilities were less
stringent than the HON level. The program at the fourth facility
appeared to be very similar the HON. One facility did not report
any program. Because four of five facilities were less than the
-------
20
HON, the floor for equipment leaks was determined to be less
stringent than the HON.
In summary, the MACT floors for the ethylene propylene
rubber subcategory are as follows. For storage vessels, front-
end process vents, and equipment leaks, the floor was determined
to be less stringent than the HON (HON/ACT). For wastewater, the
floor was determined to be equal to the HON. For back-end
process emissions, the floor was determined to be the arithmetic
average of the back-end emission factors for the facilities using
the solution process.
Halobutyl Rubber
Halobutyl rubber is a single plant subcategory. Therefore,
the existing level of control at this facility represents the
MACT floor for the subcategory.
At the halobutyl rubber facility, hexane was stored in fixed
roof uncontrolled tanks, and control would be required by the
HON. Therefore, the floor for storage vessels was determined to
be less stringent than the HON.
At the butyl rubber facility, three halogenated streams are
controlled by a flare. The HON does not allow the control of a
halogenated vent stream using a flare, but would require the
stream be controlled by an incinerator followed by a scrubber. A
fourth vent stream entering the flare has a TRE greater than 1.0,
which is control more stringent than the HON. A comparison was
made between the existing HAP emissions level and the emissions
level that would result from application of only HON controls.
The result is that the HAP emissions at the existing level of
control were over three times greater than the emissions that
would result after application of the HON. This difference was
primarily due to the reduction in the Hcl emissions from the
flare. Therefore, the floor for front-end process vents was
determined to be less stringent than the HON/ACT.
Because no add-on control or permit conditions were reported
for the process back-end, the floor for process back-end
emissions was defined as no control.
No wastewater streams were reported by the facility that
would be subject to the HON control requirements, and no
wastewater control was reported. Therefore, the floor for
wastewater was determined to be equal to the HON.
The facility reported that equipment leak emissions were
controlled by a leak detection and repair program. However,
elements of the program were less stringent than the HON, so the
floor for equipment leaks was determined to be less stringent
than the HON.
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
21
In summary, the MACT floors for the halobutyl rubber
subcategory are as follows. For wastewater, the floor was
determined to be equal to the HON. For storage, front-end
process vents, and equipment leaks, the floor was determined to
be less stringent than the HON (HON/ACT). For back-end process
emissions, the floor was determined to be no control.
Hypalon™
Hypalon™ is a single plant subcategory. Therefore, the
existing level of control at this facility represents the MACT
floor for the subcategory.
At the Hypalon™ facility, all storage vessels are controlled
in accordance with the HON, and the floor for storage vessels was
determined to be equal to the HON.
This facility reported two uncontrolled front-end process
vents. Both vents had TREs greater than 1.0, and would not
require control by the HON. Therefore, the floor for front-end
process vents was determined to be equal to the HON.
Because no add-on control or permit conditions were reported
for the process back-end, the floor for process back-end
emissions was defined as no control.
No wastewater streams were reported that would require
control by the HON, and no wastewater control was reported.
Therefore, the floor for wastewater was determined to be equal to
the HON.
As noted earlier, Hypalon™ is one of the subcategories
subject to the HON equipment leak provisions. All components ih
HAP service at this facility are expected to be subject to the
HON requirements. Therefore, the floor was determined to be
equal to the HON for equipment leaks.
In summary, all MACT floors for the Hypalon™ subcategory
were determined to be equal to the HON (HON/ACT), except for
back-end process emissions. For back-end process emissions, the
floor was determined to be no control.
Neoprene
Three active facilities were identified that produce
neoprene. These three facilities were used in the determination
of MACT floors.
The primary HAP used in this subcategory is chloroprene, and
all three facilities reported that chloroprene storage vessels
were controlled at a level less stringent than the HON.
Therefore, the floor for storage vessels was determined to be
less stringent than the HON.
-------
22
Two of the facilities reported information for uncontrolled
front-end process vents where control would be required by the
HON. Therefore, the floor for front-end process vents was
determined to be less stringent than the HON.
Because no add-on control or permit conditions were reported
for the process back-end at any neoprene facility, the floor for
process back-end emissions was defined as no control.
No reported wastewater streams exist at neoprene facilities
with characteristics that would require control by the HON, and
no wastewater control was reported. The floor for wastewater was
determined to be equal to the HON.
All three neoprene facilities reported that equipment leak
emissions were controlled by a leak detection and repair program.
However, elements of all three programs were less stringent than
the HON, so the floor for equipment leaks was determined to be
less stringent than the HON.
In summary, the MACT floors for the neoprene subcategory are
as follows. For wastewater, the floor was determined to be equal
to the HON. For storage, front-end process vents, and equipment
leaks, the floor was determined to be less stringent than the HON
(HON/ACT). For back-end process emissions, the floor was
determined to be no control.
Nitrile Butadiene Latex
Three facilities were identified that produce nitrile-
butadiene latex. Each of these facilities also produce styrene-
butadiene latex, and equipment is sometimes shared between these
two products. A separate analysis was conducted for NBL,
although the primary product at one or more of these facilities
may be SBL, and not NBL.
The HAP's reported to be stored at NBL facilities include
acrylonitrile, styrene, ethyl acrylate, 1,3-butadiene, acrylic
acid, vinylidene dichloride, and formaldehyde (formalin). Each
facility reported that acrylonitrile was stored in fixed roof
uncontrolled tanks, which would require control under the HON.
Similarly, acrylic acid was stored in fixed roof uncontrolled
tanks at two facilities. The butadiene and vinylidiene chloride
were stored in pressure tanks. Because all three facilities were
controlling storage vessels at a level less than the HON, the
MACT floor was determined to be less stringent than the HON.
It is believed that at least some of the front-end
operations at NBL facilities are batch. However, information
submitted by the facilities did not identify which of the front-
end process vents were from batch processes. Therefore, the HON
and Batch ACT 90 percent applicability criteria were applied to
all vents for comparison with existing controls. Each facility
-------
I
I
I
I
I
i
i
i
i
i
i
i
i
i
i
i
i
i
i
23
controls one or more front-end process vents using a combustion
device. Both the HON and Batch ACT were determined to require
control for all these vents. Further, all uncontrolled vents at
these facilities would not be subject to control under either the
HON or Batch ACT. Therefore, the level of control for NBL front-
end process vents was determined to be equal to the HON/ACT.
As indicated by the word "latex" contained in the name of
the subcategory, the final product is a latex and not a dried
solid. Operations after the stripper at NBL facilities have
little HAP emission potential due to the low residual
acrylonitrile concentrations. The floor for NBL back-end process
emissions was determined to be no control.
No wastewater controls were reported at any NBL facility.
At two facilities, all reported streams were below the HON
applicability criteria. At the third facility, one uncontrolled
wastewater stream was reported for which the HON would require
control. Because two of three facilities were at the HON level,
the floor for wastewater was determined to be equal to the HON.
Because these facilities also produce SBL, each is subject
to the HON equipment leak provisions for components in styrene
and butadiene service used to produce SBL. Many of the
components in butadiene service are anticipated to be shared with
the NBL process. Therefore, an equipment leak program equivalent
to the HON is required at each NBL facility. However, each
facility was assumed to be controlled at a level less stringent
than the HON because components in acrylonitrile service are not
subject to the HON provisions. Therefore, the floor for
equipment leaks was determined to be less stringent than the HON.
In summary, the MACT floors for the nitrile butadiene latex
subcategory are as follows. For front-end process vents and
wastewater, the floor was determined to be equal to the HON
(HON/ACT). For storage and equipment leaks, the floor was
determined to be less stringent than the HON. For back-end
process emissions, the floor was determined to be no control.
Nitrile-Butadiene Rubber
Four active facilities were identified that produce nitrile
butadiene rubber.' At one facility, the NBR equipment is also
used to produce SBR by the emulsion process, as well as SBL.
Information submitted by this facility related to NBL production
was included in the floor analyses for this subcategory.
Industry requested that separate subcategories be created
for batch NBR and continuous NBR processes, because two
facilities use continuous processes and two use batch
processes6*7 The EPA recognizes differences in emissions and
control technologies for batch and continuous processes.
However, separate subcategories were not created because the EPA
-------
24
believes that the use of both the HON and Batch ACT process vent
provisions is satisfactory to address differences in batch and
continuous process vents. Furthermore, the EPA believes the HON
storage, wastewater, and equipment leak provisions are applicable
to batch processes, and that batch processes may be compared with
continuous processes using the HON-based approach described
earlier in this memorandum.
Two facilities reported storage vessel controls less
stringent than the HON. At one, acrylonitrile was stored in
fixed roof uncontrolled tanks, and the other facility vented an
acrylonitrile storage vessel to a scrubber with an efficiency
less than the 95 percent required by the HON. At one facility,
all HAP storage tanks are vented to a flare. The fourth facility
did not submit sufficient information to allow a classification
for storage vessels. Therefore, because two of three facilities
submitting sufficient information were controlled at a level less
than the HON, the floor was determined to be less stringent than
the HON for storage vessels.
The two continuous process facilities control front-end
process vents with combustion devices meeting the HON
requirements. These vents are estimated to require control under
the HON process vent provisions, making these two facilities
equal to the HON. At the two batch facilities, all front-end
process vents were uncontrolled, but all vents would not require
control based on the Batch ACT criteria. Therefore, the floor
for NBR front-end process vents was determined to be equal to the
HON/Batch ACT.
Because no add-on control or permit conditions were reported
for the process back-end at any NBR facility, the floor for
process back-end emissions was defined as no control.
Based on the available information, no wastewater streams
are estimated to exist at NBR facilities with characteristics
that would require control by the HON. Further, no wastewater
control was reported at any NBR facility. Therefore, the floor
for NBR wastewater was determined to be equal to the HON.
Two facilities reported that emissions from equipment leaks
were controlled by leak detection and repair programs. However,
elements of the programs were less stringent than the HON, so
these two facilities were determined to be less stringent than
the HON. For the facility that also produces SBR-E, a HON
program is in place for components in styrene and butadiene
service used to produce SBR-E. Many of the components in
butadiene service are estimated to be shared with the NBR process
at this facility. However, this facility was also assumed to be
controlled at a level less stringent than the HON because
components in acrylonitrile service are not subject to the HON
provisions. The final facility did not report any program to
reduce emissions from leaking equipment. Therefore, the floor
-------
25
for equipment leaks was determined to be less stringent than the
HON.
In summary, the MACT floors for the nitrile butadiene rubber
subcategory are as follows. For front-end process vents and
wastewater, the floor was determined to be equal to the HON
(HON/ACT). For storage and equipment leaks, the floor was
determined to be less stringent than the HON. For back-end
process emissions, the floor was determined to be no control.
Polybutadiene Rubber and Styrene-Butadiene Rubber by Solution
Four active facilities were identified that produce both PER
and SBR using the solution process, and another facility that
produces PER using the solution process. As discussed in the
subcategorization memorandum, the four facilities producing both
SBR and PER use a HAP (hexane or toluene) solvent. The facility
producing only PER reported the use of a non-HAP solvent.
Representatives of this company have indicated that one of their
two PER processes is in the process of switching to a HAP
solvent. The non-HAP process facility was included in the
determination of MACT floors using the HON based approach.
However, the differences in the processes made consideration of
the non-HAP process facility inappropriate in the calculation of
the back-end floor.
Two of the facilities reported storage vessel controls more
stringent than the HON. In both instances, this was because
styrene tanks, which would not require control under the HON,
were controlled with floating roofs. The three remaining
facilities controlled hexane, styrene, and butadiene in a manner
that was equivalent to HON controls. Therefore, the floor for
PBR/SBR-S storage vessels was determined to be equal to the HON.
It was assumed that all front-end process vents at these
facilities are continuous, so the HON process vent provisions
were used to determine the floor. At two facilities, all front-
end vents were combined and routed to a flare, and one or more of
the vent streams would not have required control under the HON.
Therefore, these two facilities were classified as greater than
the HON. One facility controlled all vents that would have
required control under the HON, and all uncontrolled vents would
not have required HON control. The final two facilities did not
report any control, and did not report any vent streams that
would have required HON control. Because three facilities were
determined to be equivalent to the HON, the floor for PBR/SBR-S
front-end process vents was determined to be equal to the HON.
One PBR/SBR-S facility reported a permit condition limiting
dryer emissions, and another reported that all dryer vents were
vented to a boiler. These instances establish that the reduction
of PBR/SBR-S back-end HAP emissions was demonstrated for this
subcategory. The average, mode, and median annual emission
-------
26
factors were determined and adjusted to weekly, as described in
the approach section. For existing sources, the floor was
determined to be 5 kg HAP per megagram dry crumb rubber, on a
weekly average basis. The new source floor was determined to be
3 kg/Mg. As noted above, the facility using a non-HAP solvent
was not included in the back-end floor analysis.
No wastewater streams exist at PBR/SBR-S facilities with
reported (or extrapolated) characteristics that would require
control by the HON, and no facilities reported wastewater
controls. Therefore, the floor for wastewater was determined to
be equal to the HON.
Producers of PER and SBR are subject to the HON equipment
leak provisions, but only for components in styrene and butadiene
service. Therefore, each PBR/SBR-S facility is required to have
a HON equipment leak program in place. However, each of the four
HAP solvent facilities was assumed to be controlled at a level
less stringent than the HON because components in hexane or
toluene service are not subject to the HON provisions.
Therefore, the floor for equipment leaks was determined to be
less stringent than the HON.
In summary, the MACT floors for the polybutadiene and
styrene-butadiene by solution subcategory are as follows. For
storage vessels, front-end process vents, and wastewater, the
floor was determined to be equal to the HON (HON/ACT). For
equipment leaks, the floor was determined to be less stringent
than the HON. For back-end process emissions, the floor was
determined to the average of the back-end emission factors for
the facilities using a HAP solvent.
Polysulfide Rubber
Polysulfide rubber is a single plant subcategory.
Therefore, the existing level of control at this facility
represents the MACT floor for the subcategory.
At the polysulfide rubber facility, ethylene oxide, ethylene
dichloride, and formaldehyde (formalin) were stored in accordance
with HON requirements. Therefore, the floor was determined to be
equal to the HON for storage tanks.
The front-end process vent information submitted by the
polysulfide rubber facility indicated that no control was
present. No control would be required by the HON, so the floor
was determined to be equal to the HON for front-end process
vents.
Because no add-on control or permit conditions were reported
for the process back-end, the floor for process back-end
emissions was defined as no control.
-------
I
I
I
I
I
I
I
I
I
i
i
i
i
i
i
i
i
i
i
27
No wastewater streams were reported by the facility that
would be subject to the HON control requirements, and no
wastewater control was reported. Therefore, the floor for
wastewater was determined to be equal to the HON.
The facility reported no information on the control of
emissions from equipment leaks. Therefore, the floor for
equipment leaks was determined to be less stringent than the HON.
In summary, the MACT floors for the polysulfide rubber
subcategory are as follows. For storage vessels, front-end
process vents, and wastewater, the floor was determined to be
equal to the HON. For front-end process vents, and equipment
leaks, the floor was determined to be less stringent than the
HON. For back-end process emissions, the floor was determined to
be no control.
Styrene-Butadiene Latex
As noted above, the styrene-butadiene latex subcategory was
the only subcategory containing more than 5 sources. Seventeen
facilities were identified that currently produce SBL. One of
these facilities began operations after the original information
requests were made, so this facility was not included in the
floor analyses. Another facility is a styrene-butadiene rubber
by emulsion facility that removes a stream of latex (after
stripping but prior to coagulation) from the rubber production
line and blends and finishes it to make a final latex product.
This facility was also not included in the MACT floor analyses.
The first step was to identify the best performing 5
facilities. Because the MACT floor analysis was conducted on a
"plank" basis, the best performing 5 facilities were determined
separately for each emission source type.
For storage vessels, the HON storage vessel provisions were
used to determine the best performing 5 facilities. Each SBL
facility was classified as less than, greater than, or equal to
the HON storage vessel control level. This analysis showed that
one facility controls storage vessels at a level more stringent
than the HON, six with controls equal to the HON, and six with
controls less stringent than the HON. A facility's relationship
to the HON was assumed to be a direct reflection of the level of
control. In other words, those facilities with controls greater
than the HON were considered to be the best controlled
facilities. Therefore, the best controlled five facilities
consist of four with controls equal to the HON, and one with
controls greater than the HON. The floor for SBL storage vessels
was determined to be equal to the HON.
For front-end process vents, an emission factor approach was
used to identify the best performing 5 facilities. The use of an
emission factor (HAP emissions per unit of production) would take
-------
28
into account process modifications and other pollution prevention
actions that decrease HAP emissions, eliminating the need for
add-on control. The five SBL facilities with the lowest emission
factors were identified as the best controlled. The HON/Batch
ACT approach was then used to determine the "average" control of
these five. Of these five, one was determined to control at a
level more stringent than the HON/ACT, and the remaining four
were classified as equal to the HON/ACT. Therefore, the floor
for SBL front-end process vents was determined to be equal to the
HON/ACT.
The final product is a latex, meaning a liquid rather than a
dried solid. Operations after the stripper at SBL facilities
have little HAP emission potential due to the low residual
styrene concentrations. The floor for SBL back-end process
emissions was determined to be no control.
Similar to storage vessels, a HON-comparison approach was
used to identify the five SBL facilities with the best wastewater
control. Actually, no SBL facility reported wastewater control
for any stream. Two facilities reported (or extrapolated)
streams that would require control under the HON, making them
less stringent than the HON. Therefore, the remaining 13
facilities, and the MACT floor for SBL wastewater, were
determined to be equal to the HON.
The HON was used to identify the best controlled facilities
for equipment leaks. Producers of SBL are subject to the HON
equipment leak provisions for components in styrene and butadiene
service. Several facilities reported the use of other HAP's in
the production of SBL, but seven reported the use of styrene and
butadiene only. Therefore, all components in HAP service at
these seven facilities are required to be controlled at the HON
level. No facility reported a program more stringent than the
HON level. Therefore, the floor for SBL equipment leaks was
determined to be equal to the HON.
In summary, all MACT floors for the styrene-butadiene latex
subcategory were determined to be equal to the HON, except for
back-end process emissions. For back-end process emissions, the
floor was determined to be no control.
Styrene-Butadiene Rubber by Emulsion
Four active facilities were identified that produce styrene-
butadiene rubber using the emulsion process. These four
facilities were used in the determination of MACT floors.
Two of the four SBR-E facilities reported existing storage
tank controls equal to the HON. One facility reported that
styrene was stored in tanks vented to a carbon adsorber, which is
more stringent control than the HON. The fourth facility did not
report sufficient information to allow a comparison to the HON
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
29
level of control. The majority of facilities in this subcategory
(for which information was available) controlled emissions equal
to the HON. Therefore, the floor for SBR-E storage vessels was
determined to be equal to the HON.
For front-end process vents, three facilities reported
control for all vents with TREs less than 1.0 and all streams
with TREs greater than 1.0 were uncontrolled. Therefore, these
three facilities were classified as equal to the HON. Sufficient
information was not available to reach a conclusion for the
fourth facility. Therefore, the floor for SBR-E front-end
process vents was determined to be equal to the HON.
Three of the four SBR-E facilities reported permit
conditions limiting the amount of residual styrene in the
stripped latex prior to coagulation. This establishes that the
reduction of SBR-E back-end HAP emissions was demonstrated for
this subcategory. Residual styrene in latex information was
provided by each of the four facilities. The average, mode, and
median maximum weekly residual styrene limits were determined as
described in the approach section. For existing sources, the
floor was determined to be 0.35 kg HAP per megagram latex, on a
weekly average basis. The new source floor was determined to be
0.2 kg/Mg.
One SBR-E facility reported a controlled wastewater stream
whose extrapolated flow and concentration were below the HON
applicability levels, making the wastewater controls at this
facility greater than the HON. Two facilities reported no
control, and no streams that would require control. The fourth
facility reported control for a stream that would not require
control under the HON, but also reported flows and concentrations
for two uncontrolled streams that would require HON control. For
this facility, a comparison was done between the existing
emission levels and the levels that would be present if control
was applied only to the HON streams. This revealed that total
plantwide emissions would be slightly lower at the HON level of
control, resulting in the classification of this facility as less
than the HON. With two facilities equal to the HON, one more
stringent, and one less stringent, the MACT floor for SBR-E
wastewater was determined to be equal to the HON.
As noted previously, producers of SBR are subject to the HON
equipment leak provisions for components in styrene and butadiene
service. No SBR-E facility reported the use of any HAP other
than styrene and butadiene, leading to the conclusion that all
components in HAP service are subject to HON control. Therefore,
the floor for equipment leaks was determined to be equal to the
HON.
In summary, all MACT floors for the styrene-butadiene rubber
by emulsion subcategory were determined to be equal to the HON,
except for back-end process emissions. For back-end process
-------
30
emissions, the floor was determined to be the average residual
styrene concentration in the stripped latex.
REGULATORY ALTERNATIVES BEYOND THE MACT FLOORS
Except in a few limited cases, only one regulatory
alternative was developed and analyzed for each subcategory.
Table 3 presents the regulatory alternatives by subcategory for
the Polymers and Resins I subcategories. The rationale for the
level of this alternative is discussed below.
If the MACT floor for an emission source type was determined
to be less stringent than the HON/ACT level of control, the
regulatory alternative included the HON/ACT level of control for
that emission source, and not the MACT floor. The rationale for
this action was that in the extensive evaluation of the HON
requirements, the EPA concluded that the cost and other impacts
of the HON-level of control were reasonable for storage vessels,
continuous process vents, wastewater, and equipment leaks.
Similarly, the EPA determined that the cost and other impacts
associated with the Batch ACT 90 percent level of control were
reasonable. Based on these previous analyses, the EPA determined
that an increased stringency of the single regulatory alternative
beyond the MACT floor level was acceptable.
While the EPA did make the general decision described in the
previous paragraph without regard to specifics of the elastomer
industry, industry specific considerations were considered in
subsequent analyses when the MACT floor was determined to be less
stringent than the HON/ACT. If special circumstances were
identified for a subcategory that increased the cost (or other
impacts) of the HON or Batch ACT controls to a level the EPA no
longer considered reasonable, a regulatory alternative less
stringent than the HON level (but at least as stringent as the
MACT floor) was identified and analyzed. The only occurrences of
this type were for process vents at the butyl rubber and
halobutyl subcategories, which are both single-plant
subcategories.
For butyl rubber and halobutyl front-end process vents, the
MACT floor was determined to be less stringent than the HON/ACT.
As discussed in the results section of this memorandum, both
facilities had unique circumstance related to a halogenated vent
streams controlled by a flare. This circumstance was that
halogenated vent streams were vented to a flare, resulting in
hydrogen chloride emissions. The HON would not allow a
halogenated vent stream to be controlled by a flare, meaning that
these facilities would need to install incinerators to control
the halogenated organic compound, followed by scrubbers to
control the hydrogen chloride generated by the combustion of the
halogenated organic. The only emission reduction that could be
attributed to the HON level of control would be the hydrogen
chloride emissions, while the full cost of the incinerators and
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
u
>
4J
g
V
4>
tree Regulatory AI
s
Oi
a
4J
U
•t^
X
w
4*
d
v «
8 X
•H «
r
1
?
4J
4
Z
Back-End Process
Emissions
n
•0 fl
a o)
H >
i
4J n
d u
88
»,g
a.
en
a
0
•P
H
fr
0
0>
t)
«J
u
•8
u
Z Z
0 0
X X
z z
O 0
X X
•-I 1-1
0 0
4J 4J
c c
O 0
u u
§ g
ffl ^ 01 *
Cn (Li 5 ri id
t^ C 4J S T3 ." T3 E-i
cj "4 S o Ji; o
in 4-* C | i— 1 X <"^ 13*
^" Pi 0) rn fH Id ^^.
^* £ O* O A\ W Z
° ".H^ £ ^ ft x
ffi o) id g c ,5 o
* > 81*4 ft
z z
O 0
X X
•H
^
3 M
ja H M
0
i-H 4J 4J
Id ^ rH
X < 4
*O D^ &1
CO) 01
(OK tf
r-4
+J
3
0)
z
o
z
o
X
no control
H
U
rt«
^•x^
z
O
X
z
0
X
01 01
1 t 1 1
n) ^ «
-KJ 0) J
0) -D
C 0) 0) -H 0)
^ 0) C C «W C
C Vj 01 0) ^ 01 M
•r4 ft '^ ••-( ^) •*-!
tl 0 "O "O W 13 4J
*o 0) id id ^i id I-H
>,Z 4J 4J ^ 4J <
J3 3303
0 - P3 ffl 0< BQ D<
n e oi
0 C 0) 0) - 0) K
f-l 0 r-i •-> V4 C
ja rH -H -^ o (u
U id >4 M -Q M
-^4 Qj 4J 4J JQ >i
d >"i"4 "4 3 4J
W X Z Z K W
Z
o
X
z
o
X
MACT floor
emission factor
H
O
-*^
z
s
z
0
X
0)
c
- 0) >i
01 M JQ
C >i
01 4J V4
rH W 01 M
J>"i"^» 0
ft 0) JQ 4J
O C 3 r-4
U Q) « <
*O Q) O^
0) id C C 0)
C 4J 0) 0 OS
0) 3 "4 -^
iH J3 *D 4J
>i >i IB 3
£ <-4 4J ^H
4J 0 3 0
w o< m w
Z
0
X
z
o
X
MACT floor latex
styrene
concentration
H
o
^^
z
o
X
z
o
X
01
JQ
3
(U
0) M
•O 4J
id <->
4-> C <
3 0
on -H o»
m oi
0) rH OS
C 3
0) E
V4 H
4-1 S
W JQ
-------
32
scrubbers would be incurred. This made the HON level of control
very cost-ineffective for these subcategories. An intermediate
regulatory alternative was developed that required the HON level
of control for all front-end process vents, except for
halogenated vent streams that were already vented to a flare.
The HON level of control was maintained as a second regulatory
alternative for both subcategories.
If the MACT floor was determined to be equal to the HON, the
regulatory alternative was set at the MACT floor (i.e., the
HON/ACT). If a MACT floor had been determined to be more
stringent than the HON/Batch ACT, the regulatory alternative
would have needed to reflect the MACT floor. However, as
discussed in the results section of this memorandum, this
situation did not occur for any emission source type for any
subcategory for existing sources.
During the development of the HON, alternatives more
stringent than the promulgated levels were considered and
rejected by the EPA. Therefore, controls more stringent than the
HON levels were not considered, because the EPA had previously
considered them unacceptable.
Similarly, the Batch ACT analyzed and estimated impacts for
control levels more stringent than the 90 percent level. As
noted above, the 90 percent level was selected because of the
relationship of the costs to the environmental benefits.
Therefore, consideration of batch process vent control levels
more stringent than the 90 percent Batch ACT level was
unnecessary.
Similar to existing sources, if the new source floor was
determined to be less stringent than the new source HON level,
the first regulatory alternative was raised to the new source HON
level.
REFERENCES
1. Memorandum, from Clark, C. and Norwood, P., EC/R Inc. to
Evans, L. EPA/ESD/OCG. Polymers and Resins I —
Subcategorization. April 28, 1995.
2. Radian Corporation. Draft Meeting Minutes. Styrene-
Butadiene Rubber by Emulsion Industry with EPA. September 20,
1993.
3. Radian Corporation. Draft Meeting Minutes. Ethylene
Propylene Rubber and Nitrile Butadiene Latex Industry with EPA.
September 22, 1993.
4. Radian Corporation. Draft Meeting Minutes. Styrene
Butadiene Latex Industry and EPA. September 22, 1993.
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
33
5. Norwood, P., EC/R Inc., to Evans, L., EPA/ESD/OCG. May 23,
1995. MACT Floors for Back-end Process Operations for the
Elastomer Production Industry (Polymers and Resins I).
6. Letter from Killian/ R. International Institute of Synthetic
Rubber Producers, to Evans, L. U.S. Environmental Protection
Agency. Requesting a separate subcategory for facilities
producing nitrile butadiene rubber by batch processes. October
8, 1994.
7. Letter from Herman, T. Zeon Chemicals USA, Incorporated, to
Norwood, L.P. EC/R Incorporated. Providing information on
differences in nitrile butadiene rubber batch and continuous
processes. August 8, 1994.
8. Telecon. Norwood, P. EC/R Incorporated with Butts, T. and
Eiselstein, C., Miles, Incorporated. Discussion of Miles
ethylene propylene rubber and polybutadiene rubber processes.
June 28, 1994.
-------
MEMORANDUM
Date: May 10, 1995
Subject: Potential for New Sources Producing Elastomers
(Polymers and Resins I)
To: Leslie Evans, ESD/OCG
From: Charlotte Clark,
I
I E /R Incorporated.
I
I
l
I
l
l
l
l
I
l
l
I
l
l
l
l
l
Environmental Consulting and Research
The purpose of this memorandum is to discuss the potential
for construction or reconstruction of affected sources that would
produce elastomers in the Polymers and Resins I source category.
Specifically, the memorandum discusses the potential for this new
source growth within 5 years of proposal of the standard, or by
2001. This potential was predicted using actual and projected
data on facility capacity, production, and growth.
CONCLUSION
No new sources that would be subject to the proposed rule
are expected to be constructed or reconstructed before 2001 for
three reasons. First, industry production capacity for these
elastomers currently exceeds demand by a significant margin, and
excess available capacity at domestic synthetic rubber producers
can easily accommodate the expected increase in demand over that
time period. In support of this, no company has identified any
plans to construct or reconstruct a facility that would be
subject to the proposed standard. Second, synthetic rubber
production has become a global market, and a significant amount
of unutilized capacity exists in other areas of the world.
Third, new elastomers products (not included in the categories
listed under this rule) have emerged that will, if successful,
reduce demand for the listed elastomers. Therefore, estimates of
impacts and costs performed for this regulatory effort assume no
construction or reconstruction of new sources in the first five
years of the standard.
BACKGROUND
The U.S. Environmental Protection Agency (EPA) is in the
process of establishing national emission standards for hazardous
air pollutants (NESHAP) for emissions of organic hazardous air
pollutants (HAP) from production of any of nine elastomeric
materials. .These nine products are identified by the following
source category designations:
• Butyl rubber
• Epichlorohydrin elastomers
• Ethylene propylene rubber
3721-D University Drive • Durham, North Carolina 27707
Telephone: (919) 493-6099 • Fax: <919) 493-6393
-------
Hypalon™
Neoprene
Nitrile butadiene rubber
Polybutadiene rubber
Polysulfide rubber
Styrene butadiene rubber and latex
An important component of the regulatory process is
identification of all facilities in the U.S. that are actively
producing any of the listed elastomers; these sites are termed
"existing" sources. Currently, 35 existing plant sites have been
identified that produce one or more of the elastomers listed
above. Because many of these produce more than one listed
elastomer on site, and because each elastomer product process
unit is defined as an affected source, 43 total existing affected
sources have been identified for this regulatory effort.
An additional component of the regulatory process is
consideration of the potential for construction of new production
sites or for significant reconstruction of existing production
sites. Assessment of this potential is important, because
regulations for new or reconstructed sources are likely to be
more stringent than for existing sources. Specifically, new
sources must be controlled to a level equal to the best
controlled similar existing source, whereas existing sources must
be controlled to a level equal to a central measure of some
percent of existing sources (for example, average of the best
performing 5 sources).
EVALUATION OF NEW SOURCE POTENTIAL
Potential for new sources was evaluated in three steps.
First, existing production capacity was compared to current
demand. Three sources were used to obtain capacity, production,
and demand information: Chemical Marketing Reporter1, Chemical
Engineering News2, and the International Institute of Synthetic
Rubber Producers (IISRP) ,3>4>5 Applicable excerpts from these
resources are included as Attachment 1.
Table 1 presents data on production capacity and demand for
six of the nine source categories; similar data for the other
three source categories — epichlorohydrin elastomer, Hypalon™,
and polysulfide rubber — are either not available or are
considered confidential. All three of the source categories not
presented in the table are single plant source categories;
further, the polysulfide facility is anticipated to be an area
source not subject to the MACT standard. Therefore, the six
listed source categories were considered to be representative of
the source categories not listed in the table. These data show
that, for 1993, domestic elastomers facilities operated at
between 43 and 86 percent capacity. Thus, production is well
below capacity industry wide, even considering a increase in
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
demand over the last couple of years.3
Table 1. Elastomer Production Capacity and Production in 1993
Elastomer
Butyl Rubber
Ethylene Propylene
Nitrile Rubber
Polybutadiene
Polychloroprene
Styrene Butadiene
Production Capacity in
1993, Mg/yr
350,000
378,000
133,500
656,000
163,000
1,030,000
Production in 1993,
Mg/yr
195,000
275,000
115,000
445,000
70,000
875,000
Production as a
Percent of Capacity
56
70
86
68
43
85
In the second step, demand was projected to the year 2001,
which is five years after proposal of the standard. The purpose
of this step was to consider whether new capacity would be needed
to meet increased demand by the year 2001. Because the
information cited above projected demand to 1998, demand to the
year 2001 was estimated using two approaches. In the first
approach, average annual growth was calculated for the 1994-1998
time period using information provided by IISRP, and this growth
percent was applied to each of the years 1999, 2000, and 2001.
In the second approach, a 1.5 percent annual growth factor was
applied to each subcategory or type of elastomer. This percent
was supplied by the IISRP.5 In both approaches, although both
the capacity and projection data include Canada, only one
significant synthetic rubber producer exists in Canada (a butyl
rubber facility), and therefore, the numbers were deemed
representative of US production, capacity, and demand.5
This second step resulted in projected demand for domestic
elastomer product that ranged from 46.2 to 94.7 percent of
domestic capacity. Only two elastomers had projected capacity
use of over 90 percent. Table 2 provides a summary of capacity
projections using both the approaches described above for all 6
source categories for which data are available. Again, these
data suggest that throughout the domestic industry, production
will continue to be well below domestic capacity, regardless of
the approach used to estimate future demand.
In the third step, industry and trade organization sources
were asked to provide input regarding whether facilities would be
constructed or reconstructed by the year 2001. These
representatives stated that no new or reconstructed growth is
-------
o
o
CM
0)
» w
0)
<1)-H
4J O
O 0)
•P -P
•O U
0)
-P 0)
o o
Q) >-l
•I-.3
O O
(0
>1^
4J d)
•H g
o o
ro jj
a u
(0 03
U -H
H
o c
-H -H
4J nJ
O 4J
3 V4
•O 0)
o u
OJ
0)
(0
EH
J9
•g
1
o.
o.
.
u
1
0.
a.
*•
i
»?
U h*
S--&
3s
"8 -
|K
I,
|l
Ǥ
I
nS*
|s
0 *"
.£•„
ll
I*
tf
•3 ,
s -?•
n ™
*.
li
^W IS
cu
w
^ u*
o *"
^
o
»o
S
v;
0
S!
S
S
00
8
Vi
rf
VI
0
S
g
vT
<*}
00
IS
g
1
g
1
m
01
O
S
o
a.
v;
O
5!
8
£
O\
0
"
Nitrile Rubber
V,
'"
8
S
V,
f2
§
8
^
^
i—^
1 Polybutadiene
M
*
S
*ft
w>
S
5
P"
^
o
8
Polychloroprel
(Neoprene)
f;
«0
S
2
V,
«*>
S
P
r-~
fi
m
^
g
u
1
g
a
S
s
•o
.2
1
«
o
e
S.
•s
1
ca
&
S
Ov
s
u
J
1
•§
00 "
G o
u o
5 r^
*l"
!•§
a. S
« >%
II
5
1
.1
-------
expected for three reasons.
First, industry sources stated that no plans for
construction of new sources or reconstruction of existing sources
have been identified that would result in affected sources
subject to the new source provisions of the draft rule.
Construction of one new source that would produce a listed
elastomer is planned, but the production process of this source
is not projected to cause the emission of any organic HAP.
Specifically, in October 1994, Union Carbide announced plans to
build a ethylene propylene rubber (EPR) unit at its Seadrift,
Texas facility.6 The unit would begin operation by late 1996,
would produce EPR through a gas-phase production process, and
would not require the use of any solvents. Solvents are the only
organic HAP expected to be emitted from the EPR process, because
although ethylene and propylene are volatile organic compounds
(VOC), they are not listed HAP.
Second, industry sources cited excess capacity in the
international market as further evidence that no new domestic
capacity will be needed by the year 2001. The increases in
demand over the last few years have been accommodated easily
through excess capacity both domestically and internationally.
European facilities currently operate at 50 to 55 percent of
capacity, facilities in the far east operate at 75 to 80 percent
of capacity, and Russian facilities operate at 25 percent of
capacity, for example.5 Should demand increase more than
expected, increased international production with import to the
US could fill the necessary demand without the need to construct
new or reconstruct existing facilities. Table 3 contains a
summary of the forecast by the IISRP of the five-year market for
various elastomer products.4
Third, industry sources believe that some new products (not
included in the categories listed under this rule) are under
development that will, if successful, reduce demand for the
listed elastomers. For example, Exxon and Dow have initiated a
joint venture to produce a new type of elastomer that would
compete directly with existing synthetic rubber products.
REFERENCES
1. Chemical Marketing Reporter. Chemical Profiles. March 28,
1994 - Polychloroprene; April 4, 1994 - Butyl Rubber; May 9,
1994 - Polybutadiene; May 30, 1994 - SB Rubber; June 6, 1994
- EP Elastomers; and June 13, 1994 - Nitrile Rubber.
2. "Facts and Figures for the Chemical Industry." Chemical &
Engineering News. July 4, 1994.
3. Worldwide Rubber Statistics - 1993. International Institute
of Synthetic Rubber Producers, Inc.
-------
4. Facsimile, from Theismann, B., International Institute of
Synthetic Rubber Producers, Inc. to Norwood, P., EC/R Inc.
July 14, 1994. Letter attaches 1994/1998 market forecast,
undated news release, and publication order form.
5. Telecon. Norwood, P., EC/R Inc., with Theismann, B.,
International Institute of Synthetic Rubber Producers
(IIRSP). July 14, 1994. Industry growth projections.
6. Carbide to enter ethylene-propylene rubber market. Chemical
and Engineering News. October 17, 1994. p. 33.
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
1
00
_§;
15
I 8
i\
o
I!
5 S
>o «? o
2
i i i
m •* oe
§;§;§;
.s s
o t'S
s s x
S.-T3 J= =
s 1 e §
S u « "2
«s
.2 3
I II.
S ?ia
•8S S I 2
jl|i|
lst.fl
i jj <2 -2 t
««-|!
mil
use
have doubled
st decade.
looks solid ov
ars. Build
next few y
and constru
healthy.
m
rt
o o"
r~ 5
0 8
8 u
.
B -i 1 1 -
S
a
|l
E u
o
14-1
(0
v-i id
0) U
xi o
XI M
3 O
CJ *W
U 4J
•H Q)
-P ^
Q) V-l
J3 id
-p a
c
w •
0)
^J -
3 •*
-P
U
c
H
id •
c •
o o
•H C
•P H
id
n oJ •
(HUM
•P Cd O
C QJ
H -
.p] 0)
* *o
ffi flh J^
'O O
- o
o c
o
c
id
g O 4J
w 2 id
•H O
Q) O-H
£! -P -H
0 :t
O 0
M C T5
>W M C
id
Q)
CO oo
M (Ti
0) 01
O rH
€
•H
W T5 •*
O 0\
0
id
a>
(0
o
a
.p
o
-P
3
(0
-P
O
a
x
a)
•H
-a
3
rH
O
c
o
•H
.p
0}
0)
o
T3
CO
-H
•o
E
Q)
Q
-------
00
Outlook
Weakness
f
CO
Annual
1994-1998
2f
0
Is
o2
S oo
i —
i
£
I
"O
*
Product is mature with almost no
growth for two decades.
8
§
Vulnerable to downturns in the
automotive market, which acco
for half of demand. Fierce
competition in rubber hose and
belting has kept pricing soft.
il .4
^ O p ( »* S
T> B « S I s .a
•3 C g . 0. 3 '5.
^ 5 fi 4
c o S t; B "§ o
<£•=•§ 3 S « S
>
Average growth ii sluggish and
sporadic. Exports have provided
windfall, although these are mostl
to the producers' overseas
divisions.
.2
» -3
Mature product. Natural and
solution styrene-buladiene rubb
have replaced some uses. Tire
industry is vulnerable to price
cutting, overcapacity, and peric
recessions in automotive sales.
o 'S ^
« S j£>
•iiil
•s o £ 8 w
8 § K 1 o
i -s e -s I
g1 5 - ^ «
•5 s .s js g>
*
—
«
2
n O
5^5
§
•o
I
Z
bl
Consumption is flat with little
change of real, long-term
improvement. Ux of performance
tires is increasing, and could help
product. Industry is gradually
shifting from emulsion
polymerization to solution polynM
technology.
w
Highly dependent on tire
manufacturing; vulnerable to
downturns in automotive Indus
4? 5 S o "2
O -C a S C
E c . g « .
0 00 C " jT M
g-3 0_ .2 Jj1 .S
* "O o ^ 0*
.2 g S 0 -2 .2
£ * fc* "2
litlll
*
6
wT vT o"
oo oo o^
S
*o
3
ffl
-------
ATTACHMENT 1
-------
-------
CHEMICAL PROFILE I Report F
POU/GHLORORRENI
PRODUCER : v":;::
DuPont, Laplace, La..™
OuPont, Louisville, Ky..
Miles, Houston, Tex—.
^CAPACITY* "$
-
Total,
i^f£-i£>l.163
DEMAND rif • «$<•'
1993:70,000 metric tons; 1994:70,000 metrtetpns; 1998:72,'qjpq metric; tons. (Fig-
ures represent . - . _ . ..._.
ric tons per year,
GROWTH
Historical
through 1998
.-. •'-".: . -" - -:••.-..- ••- -~.-*--lZ-'z, •=-.<•• :«-','-*'•««—"*••'. -~~-» "-•-
leal (1984-1993): minus 3 percent per year; future: 0 to 1 percent per year
ion --*•;.. • •• ••.-" , • *•• - •."-"•-••»' -: ' 4 • - •-.•J?"'<"ii---r-"-r.... <;. •-.' - .
'aa- -..>•:-. •-• . ••••^-.. -- »•-- 4^.'l ----•'-.-->» "S"A>-"'- -•--•-"•.. -
.- -• " • ' .--•" • --•••••--,-.- -'- .-.-.- •,..-; *'-'.-•.- • v-r-- •
PRICE :x-I-.; •.;• -.>'.:?1':.^ >^'- ^'^--
Historical (1981-1994): High, $1.51 per pound, general purpose grade, f.o.b. plant;
$1.91 per pound for"rubber, adhesive and latex grades; low, 87c. per pound, general
purpose grade. Current: 51.51 "per pound for general purpose grade; $1.91 per pound
for rubber, adhesive and latex grades. ' " ^. ;f , ..._' <•''-,'--''•"• .^--' '-"•".". .'._
USES ..' ." , "';.';"".". .';'..','". .-.":-..:£•'. :; .
Industrial (belts, hoses, flooring), 33 percent; mechanical, 30 percent;adhesives, 10
percent; latexes, 10 percent; wire and cable, 6 percent; cellular rubber, 4 percent; mis-
cellaneous, including consumer products, 7 percent • ~ • _' .
STRENGTH :. - ;
Losses to competing rubbers and elastomers has slowed, as easy substitutions
have already been made. The export market for US polychloroprene is growing, partic-
ularly to Latin America, Asia Pacific (except Japan) and countries with controlled
economies. Domestic sales are being helped by increasing exports of finished goods.
-» _ , -
WEAKNESS _f^V ' : '--':'.'(-
Slow erosion of the markets for thermoplastic rubbers and chlorinated polyethylene
will continue through 1995. The adhesive segment is threatened by environmental re-
strictions on solvents, and only part of the market is likely to adopt water-based poly-
chloroprene systems. r
OUTLOOK
Polychloroprene is an old-line elastomer passed its days of high growth. Future ap-
plications include use in modified asphalt, where it is displacing SBR, and automotive
engine mounts, where high under-the-hood temperatures are defeating parts made of
natural rubber. --,-.- .--
Bvl
MTBE PLANT PLANS DEVEL<
joint venture of Enterprise Products
Midsouth Pipeline Company, has aj
barrel-a-day methyl ten-butyl ethei
Belvieu.Tex.
The facility has been contemplatt
Engineering and design work is und
Construction most likely will take r
into production toward the fourth q
Elsewhere, the 15,000-barreI-a-d;
three months ahead of schedule, coi
take about half of Mitchell Energy I
Mitchell owns one-third, Enterprise
third.
And the 15,000-barrel-a-day MT
plant of Texaco Chemical at Port Is
speaking recently in Houston, repo:
unit following acquisition of Texao
CHEMICAL COMMUTING: T
has extended the deadline for Hous
the number of vehicles being driver
that a network of certified trainers c
Under the Employer Trip Redu<
1990, companies with more than 1C
Houston/Galveston must increase
a.m. by 25 percent or face fines. Plai
mid-1994, to go into effect by 1996,
Under new deadlines, employer:
September 15 and those with 100-1
Dow Chemical Company and othe
study by Texas Transportation Ins
meet ETRA requirements (CMR,
BRIO SITE CULPABLE: The B
point for recycling of hazardous w;
declared a Superfund site several y
Resource Conservation Commissii
found downstream in portions'of C
TNRCC says VOCs were confii
and levels of 1,1,2 -trichloroethane
parts per million.
CHINA PETROCHEMICALS:
Group Inc., Pasadena, Calif, has a
basic petrochemicals and derivativ
the next decade. Driving forces wi
movement toward a free market ei
RECYCLING AT NAN YA: N:
Plastics, will build a $2.5 million p
manufacturing location. When coi
recycled material.
Wttco Opens Center
iirMMrinon
and iron free dry aluminum sulfatc (alum) in
rh<. I !S Prior ri»>mir:il v:,v^ ir i^ n|...,«.,l t,>
ing, developing, and implementing |
"r,., ,.„,;,>„ ,,r,»,r.,r, ...... ,1 !;„.- „„.,,..
-------
CHEMICAL PROFILE I Report
PRODUCER
Exxon, Baton Rouge"
-~^:££&< "^'''i^t''^-^
oune! li. *•&•' *• *-•'-**••*?••••• •' "^ :~r_ ;'?!r-- 'f-^'•'•?'—':"*--iP-~-' 109.000 "i
,109,000 ~i
• - ~; _ . . ~ • . •lm>%Vi>^"fc^y^"^^^^"WJ^*^*>^iV>'*«'j»5^^*V»-^ '*VI' T"?•-.*",•"-»," »• •: •.-*.»,»•*',-?*•,.,,.„,-
1993:195,000 metnc tons; 1994:200,000 metnotons;-1998:210.000 metric-tons^
-- ~i w -'N"-i-vw--,-j:w,..^-«^a'r«»j>.'-?, •*-7rr:j«ai3:»i*.«.;'A-i«.>i-•:"' '-?--. .'--•• - ..-•»,.—• ">-
USES -^::-^^-•^i3^^^^?^-^^.:^,^ •-.;*••;,':;<..
-• . : ' .• •-••--;• -<--^T.-.'f.;«-.'. -Y» *"•»•* :!i>r.r«5w*>..«-.5 >*^U •^••'* ' •.-:. , •>'...-
Tires, tubes and related products/80 percent;':automotive products, 8 percent; ad-.
hesives, caulks and sealants, 6 percent;;pharmaceutical uses, 3 "percent; other, 3 per-
cent.
<*'i r^^m •^^•••i • - --•^"•--. i'-~- ' . "-V.'v-- , ~-*i- r- ;' _~^"-" . ".'.. ' -- -
STRENGTM ,.;.-•-:•; •->•- -7 i. ..V" vc >.-.->-: - ..-^-i-. -"V^-.-.- -••-;•->:-«--. •-.
- . . -:- .-- -- - .-".^-•..--/v..;.;- ,. - .v.. '':.,--•" ....,, ... .--•-.. .
Butyl rubber is a tried-and-true product with a large, established demand in tires and .
automotive goods. Production and pricing are stable, and demand should grow aslhe
economy picks up. - : -; -"*•£ .;-/. ~~'- ^^f.x5';^~;^:- ' r"I ' "•'. ''. ;":
WEAKNESS,;-, - .:\----:^r1r.^^;?l%^':-.
Butyl rubber is ah extremely mature market that grew very slightly in the 1980s and
should continue to grow at less than GDP in the 1990s. US butyl rubber production
peaked at 194,000 metric tons in'1979, and it has since fallen by'over one-quarter. Im-
ported tires remain a threat to domestic rubber consumption, and exports of butyl rub-
ber could fall after 1995, when Sovbutital opens a 90,000-metric-ton facility in Siberia.
OUTLOOK : ;
Overall growth for butyl rubber should remain sluggish, but demand for tire rubber
should be healthier than it was in the past decade. Small uses of butyl rubber remain
weak, but adhesives and sealants are promising markets. .
Bv
MONT BELVIEU LPG UPDAT
should reach 540,000 barrels a day I
ago. And as the raw NGL pipeline «,
fracrionator feeds could be availabk
problems.
C. R. Eldred, manager of Houston
division of Chevron USA Inc.'told
Woodlands March 24 that the Mon
storage/processing area in the \vorl.
Cost of environmental rcgularior
import capability; segregated stora;.
Mont Belvieu facilities could inc
next three to five years to comply \<
executive. One immediate problen
has been disposed of in caprock mu
process which could protract 400,0
Excluding ethane rejection, \vhk
he predicts that fracrionators will o
This means potential raw NGL su-
LPG imports will rise and fall, h
handling capacity on that basis. As
material, fluoride contamination h.
by defluorinarion and segregation .
butanes is also "an ever-increasing
fracrionators, reducing front-end fi
monitored more closely and these
MTBE FORECAST: S. Craig \V
world methyl ten-butyl ether (M'l
1993 to 25 million tons in 199S. \V
million tons in 1993 to 11.7 millior
The US butane demand picture
dehydrogenarion consumption of
and 83,000 barrels in 1998, while t
barrels in 1990 to 130,000 barrels i
Things to watch for. some non-
pressure (RVP) standards rather ti
with the Clean Air Act. Further, h
of a factor than earlier had been th
of MTBE requirements by 2000.
LPG WORLD HIGHLIGHTS:
director, told the conclave that de-
growth will surpass base demand >.
after 1996.He foresees an increasii
Also, increased world supplies am
pressures on the world butane ma
STERLING INJECTION WEI
proposes to reissue an exemption
Solid Waste Amendments (HS\V
Act (RCRA) for a hazardous wasu
St. South in Texas Citv.
BRIEFS
EM Offers USP Grades
tor of Luxate aliphatic diisocvanates in the Conn. The imnort/exoort comn.i
-------
I
CHEMICAL PROFILE I Report
Goodyear, Beaumont, Tex..
.. -v. ••/.• .-»*• <« .'•!*.«•• ••*. / :-«Jfl
•Metric tons per year,' net rubber basis, solution polymerize^ L .
ber. Firestone wasjjcquired by.BrldgestoneCpi^i^jo'n'qf Japanlh^QSB^The^
company produces small quantttiesibf hlgiwinyl pblytmtadiehe at Lake Charles,'::
La. Polysar was bought by BayerAG In 1990fandj^isjmwttiB>olysar Rubbervdi-:
vision of Miles Inc. Profile last published 4/IJ^i^is^vision,,_SI9IS4l.^^^^^;
DEMAND -",;
1993: 445,000 metric tons; 1994:-455,000 metric tons; 1998:480,000"metri_cjons. j
(Figures represent US'consumptionrrThey iriciude imports of 50,000 to 90,000 metric:
tons per year, but exclude'exports,.which surp"assed;l25,00p^_metric^tons m^992^^. '
RRnWTH - "•::•'" ^:'-' •"Tw.-":c-^ u -^: **>*-• _-~rs -— ••= -•••»---
unL/vv I n ., «, .^ •'-" •cr^.'slf-Jw*. "».-"~.i> 5c.M.~t,icv.^sr?s^t--s_jsicrta!is.-^s«fS'
Historical (1984-1993): 1 to 2~percent per yean future: 1 to 2 percent peTyear
ough 1998. • — -.-.- .,ii.v..i=Jl_^i .•£$£%£."3,'V"- ^"^ i^'"~ •J~;5""?3'*~ ^p^Jf":
through
..
Historical (1981-1994): High, 82c. per pound, clear rubber grade, t.l. or c.l.,.f.o.b.
works; low, 43c. per pound, same' basis. Current: 67.75 to 80c. per pound, list, clear
rubber grade; 67.75c. to 82c. per pound, list, clear plastic grade, same basis. Selling
prices follow butadiene. Rubber grade selling prices range from 45c. to 55c. per pound;'
plastic grade, 53c. to 62c. per pound. z&:-l/.&Z'.--g-.. "=. . ~. -. ' i":£;~* :\
USES ,;,:' -•;:-.-;?-;.- '. ^;-A:'- --' ,., :-. ;^^v
Tires and treads for automobiles, trucks and buses, 75 percent; high impact resin
modification, 22 percent; industrial products (conveyor belts, hoses, seals and gaskets)
and other, 3 percent ".'-;i -:_ ~-:^.* *-- "• , =•" •': - ;..«.?,>*--.
STRENGTH : ;,- -~^.';~--.>;- •:^-~^'-\
Use in the impact modification of styrenics is growing, and the tire retread market,.
which uses polybutadiene elastomers to improve tread wear, is enjoying 5 to 6 percent
annual growth. Exports are very strong and have grown from less than 25,000 metric
tons in 1986 to oveM 25,000 metric tons in 1992. ->^ :r" .;..."':
WEAKNESS - ";".''.'• ~ : - - -- •-••• '
Polybutadiene is.a mature product that has averaged only 1 to 2 percent annual
growth since the mid-1970s. Natural and solution SBR have taken some business from
polybutadiene. The tire industry remains vulnerable to price cutting, overcapacity and
periodic recessions in automotive sales.
OUTLOOK " ~
Average growth remains a sluggish 1 to 2 percent annual rate, but it is highly spo-
radic, and demand can rise or fall substantially in any given year. Exports have been a
windfall during the past eight years, but most of these exports are to the producers'
overseas divisions.
MARAVEN PROJECT CO>
of Maraven, a branch of Petrok
produce 234,000 barrels daily o
27,000 barrels of high-sulfur re
In addition to this expansion
(MTBE), tert-amyl methyl eth
under construction. An addidr
communications system for Vc
M. W. Kellogg of Houston, (
being Bechtel Corporation (H«
NJ.—is operating a worldwidt
together.
In addition, Kellogg is suppl
a program management team \
Maraven.
Partnering with AT&T and
F-W and data is exchanged vi.
communications satellite, to ar
system includes electronic ma:
network and video conference
John Menzies, Kellogg vice-
speaking from Caracas to Hou
costs over the life of the projec
expenses and salaries, the hool
He estimates that were it no
whereby funds for the Marave
communications network coui
owing to increased efficiencies
Allan V. Dyke, director of \\
Vennet experience will give h
we're in a very strong position
the scale of the Maraven proie
expansion program, the syster
TNRCC-RRC SPAT, CON
Commission last week was sor
news release charging TNRO
"hurting the state's fledgling a!
use of standards adopted bv C
Bill Campbell, assistant exe.
Protection Agency decisions a
page, TNRCC hopes to issue
to initiate a solution to altema
Until the recent rules chani:
Campbell says, TNRCC thou
saving Texas taxpayers the e.\
procedures.
HOWELL CORPORATIO
earnings of $2.5 million last vc
declined to $411 million from
& Chemicals unit netted S&5,(
from the $1.7 million loss on r<
i-4H-%ri
v-»l
tJI*rTiL!tij^7!*i
Sun Chemical's New Site JSQ 9001. The certification applies to the ings within its performance ad.
Sun Chemical Corporation. Fort Lee. N.I.. ninniifncrurL- of ranrnltim :iiul niobium rmwl- m>« nnir Tin- lir^r-in,,-,. ..v.,™
-------
I
CHEMICAL PROFILE I Report
SB RUBBER
i^/s----'
May30; 1994;
CAPACITY*
Ameripol-Synpol, (E) Port Neches, Tex..:......".
Bridgestone/Firestone, (S) Lake Charles, La.
Copolymer, (E) Baton Rouge, La.
General Tire, (E) Odessa, Tex..^.
Goodyear, (S) Beaumont, Tex. ™:,
Goodyear, (E) Houston, Tex.'
, Total.....
.».1 50,000
.95,000
:._20,ooo
i.305,000
~.~:.1,030,bOO
.Emulsion-polymerized solid rubber (E)........
Solution-polymerized solid rubber (S)
.' :;^-^86oJrJoo
'Metric tons per year of emulsion (E) and solution (S) polymerized solid styrene
butadiene rubber (SBR). Capacity figures are for net dry rubber, including ex-
tended oils. Ameripol's capacity includes a small amount of emulsion-polymer-
ized material. American Synthetic Rubber, Louisville, Ky., is wholly owned by
Michelin et Cie and produces some solution-polymerized SBR for captive use.
Bridgestone Corporation of Japan acquired Firestone in 1988. DSM of the Nether-
lands acquired Copolymer in 1989. Profile last published 5/27/91; this revision,
5/30/94. ..,.-.- "•-.- \ ; - . .-^.-.~.-..
DEMAND ,-..-.-: . ; .;-.. ... '- X-vU-
1993: 875,000 metric tons; 1994: 875,000 metric tons; 1998: 910,000 metric tons.
(Includes exports of 150,000 to 225,000 metric tons per year, but not imports of 60,000
to 70,000 metric tons.) . " . "• --.:.- "
GROWTH . ; .;/_'
Historical (1984-1993): minus 1 to 0 percent per year; future: 0 to 1 percent per
year through 1998.
PRICE
Historical (1981-1994): High. 64c. per pound, dry SBR type 1712, oil extended,
f.o.b. works; low, 42c. per pound, same basis. Current: 64c. per pound, list, same ba-
sis. Market price is roughly 40c. to 42c. per pound.
USES
Tires and tire-related products including tread rubber, 80 percent; mechanical
goods, 11 percent; automotive, 6 percent; other, including floor tile and shoe soles, 3
percent.
STRENGTH
Conversion of automobile tires to radial design has peaked, and exports of SBR are
strong. The domestic auto industry is healthy, and demand for SBR is growing again.
WEAKNESS"
SBR is highly dependent on tire manufacturing for the auto industry. The product
suffered a huge drop in demand between 1977 and 1985, and it remains vulnerable to
downturns in the automotive industry.
OUTLOOK
SBR consumption is flat and shows little chance of real, long-term improvement.
However, the product is finally growing again after a sharp decline between 1977 and
1985, and a modest drop from 1985 through 1990. The increasing use of performance
tires could help SBR, and the industry is gradually shifting from emulsion polymerization
to solution polymer technology.
Bv
EXXON BENICIA UPGRADE:
July at its Benicia, Calif., refinery 01
gasoline requirements of California
benzene, vapor pressure, olefins am
will cost an additional 12 to 17 cent
Ralph M. Parsons Company, Pas
construction sen-ices. The project i
addition of hydrotreating, fracriona
The venture also encompasses a •
(MTB.E) unit, to be built by Pasadc
Completion of the entire project is (
in California for cleaner-burning ga
MTBE UNIT OF BEF OPENS:'
plant of Belvieu Environmental Put
Belvieu, an estimated three months
Company, Enterprise Products Cor
Company.
The three also will provide equal
undergoing start-up. Sun will buy a
and marketing operations. Enterpri.-
DESULFURIZATION PILOT F
the nation's first continuous pilot pi:
remove sulfur from petroleum feed.1
offered by Energy BioSystcms Cory
desulfurizarion of petroleum feeds u
of Gas Technology, Chicago (CMR
Petrolite Corporation, St. Louis, r
the facility, which will be built by .V
research facilities in SL Louis. Depe
commercial biochemical desulfuriz:
MOTCO, BRIO DEVELOPME>
Con Inc for installation of a slum' v
block migration of underground cor
method will be employed at the troi
The Brio group, comprised of ma
(PRPs) as Motco—a who's who oft
suspended cleanup efforrs and dcclj
plan which could involve isolation <
incineration, which had been favore
STRESS ON C-5 SUPPLY: US d<
annually from 1985 to 1992, when it
polyisoprene for tires and the produ
But according to a study by Dc\V
piperylene and other C-5 based chei
for isoamylcne-bascd tert-amyl met
ROIIM AND HAAS TRANSAC
Coast Waste Disposal Authority nt t
be bought up by Rohm and I laas thi
BUSINESS BRIEFS
Zeneca Unit Changes Name • to markct an[j SL.n \K i;ni. «r••niv.,, i ..;i
-------
CHEMICAL PROFILE I Report
PRODUCER
Copolymer, Addis, La.
Du Pont, Beaumont, Tex..'.™
Exxon, Baton Rouge, La; "rTnn<
B
•Metric tons per year p^ethylene-prppylene (EPM)i and terpplyrner (EPDM) elas-
tomers. Capacity is based on"net rubbeTand doesjncrt IncTude'fiHere, sjuch as car-
bon black. EPDM accounte for 80 to 85 percent^Current p'fo^luction. DSM ac-
quired Copolymer in 1989, and BayerAG purcnased| Nova Corporation's Poiysar
rubber division in 1990. Union CarWdeJbperJdJa^emiworks facility in South
Charleston, W.Va., in 1992. Profllelast'published^^rs/gi; this revision, 6/6/94.;_
- ,--• • •. i f.-.jf •»*w*J6fiE;H^'ti(W*v'tVv»**~^T'~""'O-*•*-'• " -"^ "^
f*r~m m A » >*K - • -- — ^ *-»Jir •--' •' - ^3&&Z?' **"^I -1."'1?"'**-*•"'. "^^«". TiX"*7 -* s_ - - '
DEMAND ' -••^•::"-rf!W?>r;.'>-r '^^^J^v^^:^-:;^^-.;----':.^:'.
" 1993: 265,000 metric tons; 1994:; 27p,OOOjTietncJoris; 1998: 300,000 metric tons.
(Includes exports, which have doubled tpJBO.OOOJmefnc tons over thepast 10 years, but
not imports of 10,000 to 15,000 metric tons peFyeak)fw:l~--* -• :»V V . - • ~
GROWTH •• ''; --ir^lte^ ~*^^ r": "-•'• ,;': •.".".
Historical (1984-1993): 3 to 4 percent per_year; future: 2 to 3 percent per year
through 1998. . J..\/." "Jll./Zl^t^J'X~r^ T>;' : .'•"•'"""" " '
- Historical (1981-1994): High, $1:38 per pound, EPDM general purpose terpoly-
mer, standard grade, bulk, f.o.b. works;.low, 78c. per pound, same basis. Current:
$1.38 per pound, general purpose, standard grade. List prices vary considerably, de-
pending on grade and properties. '•"vT?.- '."0%'"-':' '•"'•-'".
USES ;j|
Automotive parts, 40 percent; building and construction, 18 percent; oil additives, 14
percent; industrial uses, 13 percent; wire and cable, 8 percent; miscellaneous, 7 per-
cent. - •- -,,. -;. ',~~ ' '•
STRENGTH ^~
Exports of EP elastomers have doubled over the past decade, and a healthy US
auto industry promises solid growth over the next few years. Building and construction
uses are healthy, particularly single-ply roofing, and wire and cable insulation is also
growing modestly.
WEAKNESS
Although the auto and construction industries are presently healthy, they are vul-
nerable to periodic downturns. Polypropylene poses tough competition for EP elas-
tomers, and most end uses offer only modest to flat growth.
OUTLOOK
EP elastomers grew faster than GDP during the 1980s. Their growth could taper off
in the 1990s, but the automotive and construction industries are presently healthy and
producers are gradually raising their capacities.
MITSUBISHI METALLOCEI'
market for extrusion coating heat
which 40 percent goes to light-du
40 percent is used in industrial an
Mitsubishi Petrochemical Corr
with Kernel 57 L, a mettllocene-i
speaking recently before MetCon
processability of the resin—a dra-
making the materials more attraci
METALLOCENE CATALYS
MetCon meeting by Dr. Norman
Argonne, III He concludes that o
million capital investment is requ
heterogenized catalyst system wi
cyclopentadienyl zirconocene di(
zirconocene basis).
He reckons the metallocene sy
given a trimethylaluminum price
finished polymer would be 3.9 ce
properties will support good dem
HOUSTON-GALVESTON E
vehicle emissions testing progran
Harris (City of Houston), Galves
The region is deemed a "severe r
Texas Natural Resource Cons-
program, called Texas Air Care,
vehicles to be tested ever)' other
reduction can be achieved only tl
industry already has reduced its i
PERMITTING: Environmenta
Pollutant Discharge Elimination
million-pound-a-year polyprop\
have been formulated for plants <
Biotech Corporation in Houston
Permits have been formulated
the Mobil Chemical polyethylen
Gulf Coast Waste Disposal Auth
Hampshire Chemical Corporatk
SETPOINT DOINGS: Serpoii
processing software house, says r
established an office in Leiden, cf
president. Mark L. Darby has bet
director of software products anc
industry sales.
ALUMINA PLANT GETS IS
alumina refinery of Kaiser Alum
quality certification, covering m:
alumina and alumina trihvdratc.
BUSINESS BRIEFS
Norton Opens Tokyo Office
Norton Performance Plastics Corporation,
Drug Administration approval lor its
polvpropylenc' him resin. I..\.von Chemical
Milford, Conn. The 14-acre site, e?
he completed hv Novfmhi-r will m
-------
]
]
CHEMICAL PROFILE I Report F
NITRlOElRJlBBER
V-sV
13,1994 _
PRODUCER ^V;vU^^l^?ju;-'?
DSM, (S) Copolyrher, Baton Rouge, La.~7...<:..~
Goodyear, (S) Houston, Tex. :.:1:.:^,.LV™-——':,
Goodrich, (L) Akron, Ohio -^ZZZZZZZZ.
W.R. Grace, (L) Owensboroi I
Polysar (Miles), (H) Orange, TexV,
Polysar (Bayer); (S) Sarhla, Ontf Canada ...^
Uniroyal,(S)
Zeon, (H) Houston, Tex.
Zeon, (S) Louisville,
Total"
CAPACITY*
l.....Hi5,bbo
..—:..:..2B,000
:.9,ioo
..3,000
:.—:.:..20,ooo
0,000
,........._-..;.:1,500
-"•" '"l~5,300
.-
l33,50a
"" *
•Metric tons per year of dry "rubber', latex and hydrogenated capacity. (S>—solid ~
rubber; (L)—latex; (H)—hydrogenated. Solid and latex capacity figures are flexi-•
ble, as some production units rah swing to make SB and PVC blends. BASF no *
longer produces at Sarnia, Ontj'br Chattanooga, Tenn. Polysar was acquired by
Bayer AG in May 1990; Ms US operations are run by Bayer's US subsidiary, Miles
Inc. Profile last published 5/20/91; this revision, 6/13/94. * '•-_ • ~ » :. xr;i;/ ,
DEMAND v:V:.;. . v>- ^.^:. •;.-. *? yc*>-_ "• .'• "-v^."" • • :S"^V ---.
1993: 115,000 metric tons; 1994:117,000 metric tons; 1998: 121,000 "metric tons.
(Consumption estimates are for North America and are based on forecasts by Interna-
tional Institute of Synthetic Rubber Producers. Data includes all types of nitrile rubber.)
GROWTH "Sw- v ,>:-r>iv "• _ - ; ;_..; _;
Historical (1984-1993): 0 to 1 percent; future: 1 to 2 percent per year through
1998. . -'<^: i'-J;::^^]^.Vr;"- -• -'•'"::••"•"•'-• •••' -:'- J.-.J-< .••--=•
PRICE •-. --;*-. -: vf ^^ffe- ."-"-.' •••'''- •••••• •-.'-- --:'-. ->
Historical (1981-1994): High, $1.60 per pound, medium to high acrylonitrile con-
tent, bulk, works; low, 85c. per pound, same basis. Current: (list) $1.40 per pound,
medium-acrylonitrile; $1.55 per pound, high-acrylonitrile. - - _-\v>^.; •
USES '. ~~- - -:;v:-^: ^-./.- ~ \ • '• i^t
Hose, belting and cable, 28 percent; O-rings and seals, 20 percent; latex, 15 per-
cent; molded and extruded products, 15 percent; adhesives and sealants, 10 percent;
sponges, 5percent;footwear, 2percent; other, 5percent. - ~:*~ :?'".
STRENGTH :-:_' "^ ~~~ ~~ . .\-'.: •;•-
A resurgent auto market is boosting nitrile rubber, and the product should grow, al-
beit slowly, for the rest of the decade. High-temperature NR is finding new uses in high-
tech auto applications, -r . . . -- . . 1 '-->';'".
WEAKNESS . r -: •{
Nitrile rubber is growing at less than GDP and is vulnerable to downturns in the au-
tomotive market, which accounts for roughly half of demand. Fierce competition in rub-
ber hose and belting has kept pricing soft in those areas in recent years.
OUTLOOK ~ ~
An upturn in the auto market is brightening nitrile rubber's outlook, though the prod-
uct is mature and has shown almost no growth for two decades. IISRP rates 1993 North
American consumption of solid nitrile rubber at 78,500 metric tons and expects it to
reach nearly 84,000 metric tons by 1998. The institute places 1993 nitrile latex con-
sumption at 36,300 metric tons and predicts it will reach 38,300 metric tons by 1998.
BvDi
NGL WEAK, MITCHELL EARN!
Development Corporation net eamm
million in Qj last fiscal year due to \\\
both revenues and volumes, and lowc
Operating earnings for the quarter *
from $25.2 million in last year's like p>
Ql 1994. Processing volumes fell by r
43,200 barrels per day because some r
temporarily shut down.
"The good news," says Mitchell, is
liquids, have rebounded by about S5 .
industry, which buys three-fourths 01
than-three-year slump, and new dem
planes—one that came on line this sp
GCF FIRE EFFECT: Mitchell's Qj
charge for insurance deducriblcs reb'
of the Gulf Coast Fracuonators NGL
Mitchell owns 38.75 percent of GC
NGL Holding Inc. (38.75 percent! ar
The unit is due back on line in Aueu
capacity to 120,000 barrels daily
FORMOSA OLEFINS ON LINE.
Point Comfort is now producing mar
propylene. The firm has been nvcaki
brought up to snuff toward the end o
Mounger's start-up prediction (CMI
yearofethylene and 500 million pou
HUNTER TO FIGHT ON. A Te
Resource Conservation Commissior
by Hunter Industrial Facilities Inc.. t
near Dayton was upheld in March ir
appeal by Hunter.
The firm reportedly will appeal .v.
next week or so. Hunter has sought t
dome.
The plan has been controversial tr
project was safe, but TNRCC chairr
Peggy Garner ruled that Hunter hat
the salt dome, failed to provide in ac
urgent need for the facility.
RISK MANAGEMENT FORML
chemical facilities, devised by E.I. dt
the Texas Chemical Council/Assoc
safety seminar in Galvcston.
The DuPont method invol\ e? ton
leadership and commitment, implen
process safer}1 and risk management
The presentation characterized tl-
owner-operators, employees, the pu
Dow's New Order Policy
IV... I "I I f
Paulo, has obtained ISO 9002 certification. Construccion S dc IIL de CY, wi
I}....] I .1 _- I - . -l 1 --' :- '
-------
I
I
I
::...L ii.r.: i • 1:. rUd j'j. :•. -",.1 .Jj
I
I
I
I
I
_
•
I
International Institute of
Synthetic Rubber Producers, Inc
Brttt Thelsmann
_ ! information and Systems Director
O ct> d> c> c> Mr> phii Norwood
, ECR Fax
™ Fax: 9194936393
I
I
II
| Message:
II Attached Is our 1 994/1998 forecast and our publication order form, Should
! you have any additional questions we look forward to assisting you further.
i
I Best Regards,
Br/07010.04
j 2077 South Gessner Road - Suite 133 - Houston, Texas 77063-1 123
Tel. US 7 13.783. 75 11 • Fax US 7 13.783.7253 • Data Fax US 713 783 1703 • Internet IBThetsrrxinn@ATTMAJLcom
-------
INTERNATIONAL INSTITUTE OF SYNTHETIC "URBER PROI L'CFRS IMC
2077 South Gas-sner Rnad • Si HB 133 • Houston. Texas ''VOT3-1123 • (/1 •"'• 783 «VM • t ax (713. 'nn-725;
For Further Information
Contact B. D. Theismann
(PR 94.04)
For Immediate Release
,<££. NEWS RELEASE
North American Synthetic Rubber Consumption Increased by 4.0% in 1993
to 2.8 Million Metric Tons — Future to Remain Stable
HOUSTON, TEXAS USA, 7February 1994—Synthetic Rubber (SR) consumption increased by 4%
in 1993 to a total of 2,784 thousand metric tons, reaching a high water mark in total SR consumption in
North America for the second year in a row, according to the International Institute of Synthetic Rubber
Producers (TISRP).
"This rate of growth out-paced our predicted growth rate of 2.9% for 1993," said Conrad
Jankowski, managing director of the HSRP. Jankowski added, "The SR industry also outpaced GDP
growth in North America, attributable to stronger dian expected new car sales and stronger than
expected results from non-tire, non-automotive elastomers. Record levels of consumption were
attained for Poh/butadiene rubber (BR) at 484 thousand metric tons, Styrene-butadiene rubber (SBR)
latex at 78 thousand metric tons, Carboxylated SBR latex rubber at 606 thousand metric tons, and
Acrylonhrile butadiene rubber (NBR) at 78.5 thousand metric ions."
"We expect 1994 to more closely reflect traditional rates of growth for SR," said Jankowski.
SR consumption in North America is expected to increase by 2.5% in 1994 to reach 2,853 thousand
metric tons.
In 1993, SR usage in tires was 45.3% of total SR consumption. Excluding Carboxylated latex,
tire usage represented 58.3% of SR consumption.
SBR latex exhibited the highest rate of growth at 10.7%, followed by Carboxylated lalex at
9.4%. Ethylene Propylene Rubber (EPR) increased by 3.8% SBR, both solid emulsion and solid
solution polymers, increased by 2.5%, while NBR and BR increased by 1.7% and 1.0% respectively.
For 1994, Carboxylated SBR latex is expected to continue a high level of growth at 5.8%.
EPR is expected to lead the more traditional SR elastomers at 3% growth, while Polychloroprene
rubber (CR), and NBR are expected to increase by 1.4%, and 1.3% respectivery. SBR latex is
—more-
-------
. . L . J'.'
Press Release Pa9* 2
IISRP North American SR Consumption Forecast
1994/1998
expected to increase by 2.7%. Among tire elastomers SBR is expected to increase by 1.4%, BR by
2.0%, Butyl CUR) by 1.3%, while Polyisoprene rubber (IR) consumption is expected to decrease by as
much as 8% in 1994. With the exception of CR, moat SR elastomers are expected to continue the
same pace of growth over the five-yeor period 1994/1998. CR is expected to slow to an annual
average growth rate of 0.6%. The IISRP consumption forecast projects that in 1998 SR consumption
in North America will be 3,176 thousand metric tons For an overall annual growth rate of 2.7%
Thermoplastic Elastomers (TPE's) ore expected to continue a 7% annual rote of growth
through the balance of fee 1990's.
Consumption of natural rubber (NR) reflected an increase of 2.3% in 1993 with consumption
of 1,043 thousand metric tons. Over the five-year period NR consumption is projected to average
1.3% annually.
The IISRP North American consumption forecast is prepared annually be the Institute's
Americas section statistical committee. The committee is made up of representatives from the major
SR producer in North and South America. HSR? member companies participating in the forecast are
Tolysar Rubber Corp.; DuPonl; Ameripol Synpol Corp.; Goodyear Tire & Rubber Co.; Uniroyal
Chemical Co.; American Synthetic Rubber Corp., Firestone Synthetic Rubber & Latex Co.; General
Tire, Inc.; Advanced Elastomer Systems; DSM Coporymer, Inc.; Zeon Chemicals USA, Inc.; EniChem
Flastnmer Americas Jnc.; and Shell Chemical Co.
The HSRP is an international not-for-profit trade association with about 50 corporate members
who produce 90% of the world supply of synthetic rubber Its members are domiciled in 21 countries.
Incorporated in 1960 and headquartered in Houston, Texas USA, the Institute also supports secretariat
offices in London and Tokyo.
(30)
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
u
a
o
a,
ti
os -
« S
"« 5
« o
C3 tin
en a
*S '•£
I S
£ 3
:n * a
| g |
- U "? ^
_" w 3 .u
<3 ^rf *^* t*
5 «J o5 $
i*-
s fe r
"S 5* o
£ z z
MS
^— E£ ^)
TJ ji 2
3 •£ C*
B t
e t
< C
O
a- «
s i
£
s B
CO
K
#
o
o
o
1
e
£
£
£
1
CO
T-
^
s
CO
"
(A
at
T-
#
•":
1/1
00
^
0)
s
^ s
. 1
u
«
• tz
J 1
z
£
»—
CO
CD
ro!
1
co
CM
0
£
1
#
CO
Q
1
CO
8
#
o
ifl
£
I
c
r
^
z
i!
T-
^.
o
CO
n
U)
CM
•O
n
«
es
K
!^
O
r
«
«•
^
?
Cl
C
<
w
i
i
(D
,j.
i
OJ
CO
CN
0
o
#
q
o
o
c
C1
#
1
c
a
a
CB
n
•0
O
CVl
o>
01
II
^
§•
€
5
1
X
o
a
•
o
e
-------
c/R Incorporated
TELEPHONE CALL SUMMARY
PROJECT NO.t ESD-225 CALL INCOMING I
OUTGOING
EC/R STAFF! Phil Norwood
DATEI July 14, 1994
CONVERSATION WITHi Britt Theismann
TITLE: Information and Systems Director
COMPANY: International Institute of Synthetic Rubber Producers (IISRP)
ADDRESS: Houston, TX
TELEPHONE NO.: (713) 783-7253
SUMMARY: Mr. Theisman, in his role as Information and Systems Director, is
responsible for all industry growth projections for the IISRP. He called
me in response to my call yesterday to Mr. Conrad Jankowski of the IISRP
inquiring about demand estimates for 2001.
Mr. Theisman indicated that IISRP projects synthetic rubber demand for
5 years into the future. 1998 estimates are currently available, and 1999
projections will be published in August. He said that these projections
include Canada, but there is only one significant synthetic rubber producer
in Canada (a Butyl Rubber facility).
I asked Mr. Theisman about a possible approximation that we could use
to estimate the 2001 demand. He suggested assuming a 1.5% annual growth
rate in demand. I asked whether it might be better to calculate the
projected annual percentage growth between 1994 and 1998, then apply this
annual percentage until 2001. He said that the Institute clearly feels it
would be better to assume a 1.5% annual - increase. This is because the
industry underwent a large decline several years ago, and has had a large
increase in the last couple of years. They believe it will now level out.
I explained that we were trying to predict whether any new synthetic
rubber facilities will be built before 2001. He said that he felt strongly
that no new facilities would be built, nor would existing capacity be
expanded, in the U.S. in the next 10 years. He gave several reasons for
this statement, including:
• The demand is well below capacity for most types of synthetic rubber,
even with the recent increases in demand
• Synthetic rubber production has become a global market, and there is also
unutilized capacity in other areas of the world. Examples included
Europe, which is producing 50-55% of capacity, and the Far East and
Russia, which are producing 75-80% and 25% of capacity, respectively.
• Exxon and Dow have initiated a joint venture to produce a new type of
elastomer. While this new elastomer is not a synthetic rubber, it will
compete directly with existing synthetic rubber products.
Mr. Theisman said that he would send me a recent press release with
the 1998 demand projections, as well as a list of related publications
available from the IISRP.
University Tower, Suite 404 • 3101 Petty Road
Durham, North Carolina 27707
(919) 493-6099
-------
I
I E /R Incorporated.
l
I
I
l
l
I
l
l
l
I
l
l
I
l
l
l
l
Environmental Consulting and Research
MEMORANDUM
Date: May 10, 1995
Subject: Estimated Regulatory Alternative Impacts for Elastomer
Production Facilities (Polymers and Resins I)
From: Phil Norwood, EC/R\
To: Leslie Evans, EPA/OAQPS/ESD/OCG
The purpose of this memorandum is to present the estimated
impacts of the hazardous air pollutant (HAP) control options for
existing sources that are associated with the regulatory
alternative(s) considered by the Environmental Protection Agency
(EPA) for the proposed elastomer production rule. This
memorandum is organized in five sections. The first section
briefly describes the regulatory alternative for which impacts
were developed. The second presents primary environmental
impacts, and is followed by sections on secondary environmental
impacts (air pollution, water pollution, and solid and hazardous
waste impacts), energy impacts, and costs.
As discussed in a separate memorandum,1 no new sources that
would be subject to the proposed rule are expected to be
constructed or reconstructed before 2001. Therefore, no impacts
were estimated for new sources.
DESCRIPTION OF THE REGULATORY ALTERNATIVE(S)
The proposed regulation for elastomer producers will address
HAP emissions from five general emission source types:
(1) storage, (2) process "front-end," (3) process "back-end,"
(4) equipment leaks, and (5) wastewater. The process "front-end"
includes prepolymerization, reaction, stripping,'and material
recovery operations, while the "back-end" includes drying and
finishing operations.
The regulatory alternatives considered for subcategories are
summarized in Table 1. Unique facility-specific circumstances
led to the consideration of an exemption for certain process
vents in the single facility subcategories of butyl and halobutyl
rubber. Throughout this memorandum, reference will be made to
the regulatory alternative, although it is recognized that the
EPA considered two separate alternatives. Details of the
determination of the maximum achievable control technology
"floors," and the establishment of the regulatory alternative,
are provided in a separate memorandum.2 The following briefly
summarizes the applicability and control requirements of the
regulatory alternative are summarized below.
3721-D University Drive • Durham, North Carolina 27707
Telephone: (919) 493-6099 • Fax: (919) 493-6393 .
-------
H
pa
M
0
H
4J
fl
g
0
41
t-t
b^
~
4)
fl
H
3
0
U
H
o
10
tn
fl
-H
•P
W
•H
M
U
•P
O
0 M
M O
3 Hi
IH
H*
h
O
jJ
i
n
fl
s
H
10
0
U ui
8|
*-3
"S3
fa
u
(Q
n
4J
T) fl
fl 0
H >
1
JJ M
fl U
O 0
-1 U
b. C
a
0
0»
a
c
j.
tf
Sf
14
0
0
4J
fl
u
jj
g
M
1 I
1 I
^H rH
P P
hi hi
jj jj
c c
0 0
u u
0 0
c c
m >* u *
•g ™ .Q 0 jj
* O* 0 i3 o id
''H -5 fl ^ "S "•• ^ U
O 4J C , rH 3, rH ft,
tS^ Qj Q) rH (d *"*«*
"**^ 5 ty o n o) z
2(1)0 i ^ ? O O
o x r-4 *i jj ij QJ x
z 0 10 S c ™ o
j= 5 o rl M
O n<
^ <2
1 §
H
>,
4J
3 1-
o M
rH JJ 4i
fl rH rH
B < <
•U BI O
GO 0
a A K
rH
^
JJ
3
a
i
I
rH
o
jj
C
0
u
0
H
U
<
z
a
B
z
§
^
X X
0 0
JJ JJ
fl *» id
» hj A) i~]
0 -O
C 0 0 -H 0
«. 0 C C > a >H
>-l2 JJ JJ rH JJ <
£ 3303
O «-CD CO Oi CO CT
ij a 0
o c 0 0 - 0 «
rH O rH rH hi C
X rH -r4 -^ 0) 0
u fl hi hi ja hi
•«™t CU 4J "U J3 ^i
O* ^i*^ *^ 3 4J
H E Z Z OS W
1
•B
a.
n «c c
rH rH JJ
«W fl Id
3 -U
H TJ -rt
O-l S
< D9 -r4
S 0 rH
h|
S
I-^.JQ hi ja
ft 0) JQ >iJ3 JJ
O C 3 JJ 3 rH
U Q) « W OS <
0* *f^
•o 0 « 0 en
0 rd C C C C 0
C 4J 0 O 0 O K
0 3 -H -H -r4 -r4
rH J3 "Q JJ "O ID
N Sfl g at rH
& rH JJ rH JJ 3
JJ O 3 O 3 E
Cd (^ CO CO CO Gd
rH
O
0
rH
O
hi
JJ
c
o
u
JJ
c
0
u
hi
0
•o
«
fe •
a
0
n
a •
0
u
O
ft
a
2
rn O
\O 3
C
JJ •*
4 ^j
« e
04 0
u
^
° £
J O
H
« 4J
34 Ll
J2 «
3 CU
T3 -r«
0
C *O
« c
JJ -*
c a
0 -P
u c
0
a u
jj
c o
0 JJ
§c
Q)
W £
H Q)
I *
hi O^
0
rH hi
0
a JJ
a e
0 0
J> ^
0 •
o> o
fl 0
hi U
tv o
JJ hi
(0 0.
n
u
ern
ft,
0
a
jJ
hi
fl
a.
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
The storage tank, wastewater, and equipment leak provisions
all are identical to those in the Hazardous Organic NESHAP (HON).
For storage tanks, required control measures range from floating
roofs to closed vent systems routed to a control device. The
applicability of the storage tank provisions, and the
determination of the level of control required, are based on the
size of the tank and the vapor pressure of the contents. In
general, the storage tank provisions apply only to pure solvent
and pure monomer storage vessels at elastomer facilities, since
the HAP concentrations (and resulting HAP vapor pressure) in raw,
intermediate, and final products are very low.
The applicability of the wastewater provisions is determined
by the wastewater flow rate and the HAP concentration at the
point of generation (i.e., at the exit of the process unit where
the wastewater is generated). A simple description of the
wastewater provisions is that the wastewater must be kept in
tanks, impoundments, containers, drain systems, and other vessels
that do not allow exposure to the atmosphere, until this
wastewater is recycled or treated to reduce the HAP
concentration.
The equipment leak provisions allow several compliance
options for facilities. In general, facilities are required to
develop and implement leak detection and repair (LDAR) programs
for pumps, valves, agitators, and connectors in HAP service.
Compressors, pressure relief devices, sampling connection
systems, open-ended valves or lines, and surge control vessels
and bottoms receivers in HAP service are subject to equipment
standards that require the installation of certain types of
emission-reducing, or emission-eliminating, equipment.
While the process vent provisions also closely resemble the
HON, there are a few differences. The HON requires the
calculation of the Total Resource Effectiveness (TRE) index for
each vent stream. A process vent with a TRE index at or below
the threshold value of 1.0 must be controlled. The control may
be in the form of a 98 percent reduction in emissions using add-
on control, or a process change that alters the vent stream
characteristics so that the TRE index is above 1.0. The
regulatory alternative for front-end process vents from
continuous processes are based on the HON TRE.
At the butyl rubber and halobutyl rubber facilities,
halogenated vent streams were vented to a flare, resulting in
hydrogen chloride emissions. The HON would not allow a
halogenated vent stream to be controlled by a flare, meaning that
these facilities would need to install incinerators to control
the halogenated organic compound, followed by scrubbers to
control the hydrogen chloride generated by the combustion of the
halogenated organic. The only emission reduction that could be
attributed to the HON level of control would be the hydrogen
chloride emissions, while the full cost of the incinerators and
-------
scrubbers would be incurred. Therefore, an intermediate
regulatory alternative was therefore developed that required the
HON level of control for all front-end process vents, except for
halogenated vent streams that were already vented to a flare.
The HON level of control was maintained as the second regulatory
alternative for both subcategories.
For batch processes, the regulatory alternative for front-
end process vents is based on EPA's Alternative Control
Techniques Document for Batch Processes.3 Similar to the TRE
method, this approach determines whether control is required
based on vent stream characteristics.
For three subcategories (ethylene propylene rubber,
polybutadiene/styrene butadiene rubber by solution, and styrene
butadiene rubber by emulsion) the regulatory alternative for
back-end process operations is a residual HAP limit. For
polybutadiene/styrene butadiene rubber by solution and ethylene
propylene rubber, this limit is in units of kilogram (kg) of HAP
per Megagram (Mg) of dry rubber processed in the strippers. The
units for styrene butadiene rubber by emulsion are kg HAP per Mg
of latex. The regulatory alternative does not require any
additional control for facilities in other subcategories.
The impacts analysis for this project is being conducted on
a facility-specific basis. Using information provided by the
facilities and applicable State regulations, a baseline level of
control was established for each facility. This baseline level
of control was then compared to the regulatory alternative level,
to determine which facilities would be required to install
controls to meet the provisions of the regulatory alternative.
Table 2 shows the instances where it is predicted that control
will be required.
Subpart I of 40 CFR 63 requires that certain components in
HAP service at styrene butadiene rubber and latex, polybutadiene
rubber, and Hypalon® facilities comply with the Subpart H
provisions (negotiated regulation for equipment leaks). For the
styrene butadiene rubber by emulsion and Hypalon® subcategories,
it was estimated that there are no additional components in HAP
service that are not now required to meet the Subpart H level.
Therefore, no emission reductions are achieved, or costs or other
impacts incurred,' at facilities in these two subcategories. This
is also true for the covered components at styrene butadiene
latex, styrene butadiene rubber by solution, and polybutadiene
rubber by solution facilities. However, it was determined that
there are components at facilities in these categories not
covered. Emission reductions and the costs for these components,
and for all other facilities, were calculated as the incremental
emission reductions and costs between the existing control
program and the Subpart H level. Six facilities reported no
equipment leak control program, and they would achieve emission
reductions and incur costs from an uncontrolled level.
-------
TABLE 2. PLANT-SPECIFIC IDENTIFICATION OF AREAS REQUIRING CONTROL
TO MEET THE REGULATORY ALTERNATIVE
Plant:
Storage
Location of F
Process
Front -End
redicted Emis
Process
Back-End
sion Control
Equipment
Leaks
Wastewater
Butyl Rubber
BR-1
Xa
X
X
Epichlorohydrin Rubber
EPI-1
X
Ethylene-Propylene Rubber
EPR-1
EPR-2
EPR-3
EPR-4
EPR-5
X
X
X
X
X
X
X
X
X
X
Halobutyl Rubber
HBR-1
X
Hypalon™
HYP-1
xa
X
Neoprene
NEO-1
NEO-2
NEO-3
X
X
X
X
X
Nitrile Butadiene Latex
NBL-1
NBL-2
NBL-3
Nitrile Butadiene Rubber
NBR-1
NBR-2
NBR-3
NBR-4
,
X
X
X
X
X
X
X
X
X
* Front-end process vent control required at the butyl rubber and halobutyl
rubber facilities to meet the first regulatory alternative. Additional front-
end process vent control is required to meet the second regulatory
alternative.
-------
TABLE 2. PLANT-SPECIFIC IDENTIFICATION OF AREAS REQUIRING CONTROL
TO MEET THE REGULATORY ALTERNATIVE
Plant
Storage
Location of P
Process
Front-End
redicted Emis
Process
Back-End
sion Control
Equipment:
Leaks
Hastewater
Polysulfide Rubber
PSR-1
Polybutadiene/Styrene Butadiene Rubber by Solution
SBR/PBRS-1
SBR/PBRS-2
SBR/PBRS-3
SBR/PBRS-4
SBR/PBRS-5
X
X
Styrene Butadiene Latex
SBL-1
SBL-2
SBL-3
SBL-4
SBL-5
SBL-6
SBL-7
SBL-8
SBL-9
SBL-10
SBL-11
SBL-12
SBL-13
SBL-14
SBL-15
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Styrene Butadiene Rubber by Emulsion
SBRE-1
SBRE-2
SBRE-3
SBRE-4
X
X
-
X
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
PRIMARY ENVIRONMENTAL IMPACTS
The primary purpose of the regulatory alternative is to
reduce HAP emissions. This section presents the nationwide
primary air pollution impacts (i.e., HAP emission reduction)
resulting from the application of the regulatory alternative
discussed above. The HAP emission reductions were calculated by
theoretically applying sufficient controls to each emission
source to bring them into compliance with the regulatory
alternative. Control technologies and the efficiencies used in
the calculation of emission reductions are shown in Table 3. It
should be noted that the reguired control was only incremental
for equipment leaks. That is, for process vents, storage tanks,
and wastewater, the controls were always applied to previously
uncontrolled sources.
Table 4 shows the subcategory-specific HAP baseline
emissions, by emission source type, and Table 5 shows the
expected HAP emission reductions. As shown in Table 5, the
regulatory alternative is expected to reduce HAP emissions by
almost 6,400 Mg/yr. This represents a 48 percent reduction from
baseline. Baseline HAP emissions from the Epichlorohydrin and
Nitrile-Butadiene Latex subcategories are expected to be reduced
by 77 and 85 percent, respectively. These percentages represent
the maximum reductions anticipated. It was projected that the
single facilities in the Hypalon® and Polysulfide Rubber
subcategories would not require any additional control to meet
the regulatory alternative level.
Around 49 percent of the total HAP emission reduction will
be achieved through the equipment leak provisions. The
combination of equipment leaks and process vents accounts for
80 percent (almost 6,000 Mg/yr) of the total expected HAP
emission reduction. Attachment 1 contains baseline emissions and
expected emission reductions for each facility.
SECONDARY ENVIRONMENTAL IMPACTS
While the primary impact of the regulatory alternative is to
reduce HAP emissions, the application of control technologies can
also have other environmental effects. These impacts can be
positive, such as1 a reduction in non-HAP volatile organic
compound air emissions; or negative, such as the generation of
additional wastewater or solid waste. In this section the
secondary impacts on air pollution, water pollution, and solid
and hazardous wastes are discussed.
Air Pollution
For the sources included in this project, the secondary air
pollution impacts are the increased criteria pollutant emissions
caused by the on-site combustion of organic HAP's and fuels.
-------
8
TABLE 3. CONTROL TECHNOLOGIES SELECTED TO COMPLY WITH
REGULATORY ALTERNATIVES AND ASSOCIATED EMISSION REDUCTIONS
Emission Source Type
Selected Control Technology
Percentage
Reduction
Storage Tanks
Process Vents
Wastewater
Equipment Leaks
Internal Floating Roof with liquid-
mounted primary seal, controlled
fittings, and rim-mounted secondary
seal
Thermal
Flare
Thermal
inc ineratorc
incinerator + scrubber
Steam stripper
Compressors: closed-vent system
Open-ended lines: gate valve
Sample connections: closed purge
system
Pressure-relief valves: rupture disk
assembly
Pumps, valves, connectors: leak
detection and repair programs
95"
98°
90'
100f
100f
100r
• All storage tanks needing control were fixed roof, uncontrolled tanks
containing a HAP material that required a floating roof.
b HON BID IB, page 2-57.
c VENTCOST, a process vent costing algorithm developed by Radian
Corporation, was used to calculate costs. VENTCOST costs out flares,
incinerators, and incinerators plus scrubbers, and selects the most cost-
effective alternative.
d HON BID IB, page 3-2 for flares, page 3-8 for incinerators, page 3-12
for scrubbers.
e Compound-specific fraction removed (Fr) values obtained from Table 9 of
promulgated HON. It was assumed that 100 percent of the organic material
stripped from the wastewater is returned to the process.
f Equipment Leak Protocol Document, page 5-2.
8 Since most facilities have some type of LDAR program, the emission
reductions were incremental from the existing level, rather than from
uncontrolled. The percentage reductions were obtained from page 5-8 of
the Equipment Leak Protocol Document.
-------
PS
O
O
H
1
n
D
CO
n
CO
z
o
H
to
GO
n
z
H
t4
H
00
rt
O
H
rH
id
jj
o
H
4J
0) 0)
E .*
cu id
•H 0)
&J
U
— u
VI
1 *
±. 01
-P
0 *
a *
5 5
•*" ;«
in »
2 S
•rt "^
s
ff\
d,
<£ -n
S e
**• i*
U
0) i
c to i
•rl 4J o
i r» ~
- s m
UJ »^
id
ro m
0)
s -g
o .S
u "
* i
c
0
Vl
fc.
01
o>
id
Vl
o
4J
co
Subcategory
CO
TJ-
en
CN
CN
ro
en
i1
i-H
O
rH
rH
r~
VO
n
o
Rubber
r—
><
4.
a
rH
VO
rH
r-
CN
i-H
r~
VO
rH
rH
0
rH
orohydrin
r"
£
U
v<
a
b)
CN
TT
ro
ro
00
00
O
*
r-l
0
CN
in
a>
en
rH
o
CN
CN
en
rH
Vl
a
£.
tt
a
a
"s
V
Cu
0)
C
0)
r>
*^
•*^
J=
4J
U
en
en
CN
rH
cn
VO
CM
0
rH
CO
CN
«J-
00
vO
in
vO
tyl Rubber
^
s.
p.
n
S
CO
on
CN
rH
O
on
CN
O
in
r~
C
C
n
C
X
rH
T
P-
O
CN
rH
rH
CN
•*»
0
CN
CN
in
n
•»
T
o
rH
O
<»•
CN
e Butadiene Latex
fm
,f
Vl
4-
2
r-
oo
in
in
CN
TJ-
00
in
rH
rH
00
ro
rH
Vl
e Butadiene Rubbe
^
•*•
Vl
4-
2
in
^
•*
ro
ro
•*
co
VO
CN
ro
0
*
CN
cn
vO
rH
^«
C
o
-r4
4J
3
tadiene/Styrene
ene Rubber by Sol
3 •*•
J3 T
>i id
rH JJ
0 3
O4 03
rH
O
0
o
o
rH
CD
T
>*.
j
0)
X
2
ro
ro
^1
rH
^1
•*
^
rH
en
vo
o
en
00
CN
en
e Butadiene Latex
c
01
Vl
Nj
I
n
r»
*C
0
rH
ro
CO
«T
co
CN
in
co
o
CN
00
X
.0
Vl
e Butadiene Rubbe
on
C -rl
01 CO
Vl rH
>i 3
w e
M b
i-l
VD
CN
ro
rH
CN
CO
r»
^
ro
0
rH
rH
^
rH
in
o
o
VO
**
en
rH
V
CN
O
r-
rH
PROJECT TOTAL
Of
cr>
CN
dP
00
dP
in
^>
dP
r-
f-H
dP
rH
Percent of Total
-------
n
X
§
O
H
i
n
D
CO
JH
n
O
H
E<
g
a
O
H
CO
CO
H
in
H
go g
*M OQ
0,0; 5
rH
(0
4J
O
4J
oi m
E .*
& n)
•rl 0)
— • H
D> .,
5 2
C 5
rj *j
t; n
" (d
•3 *
0)
a;
c "i
O £
S " •*
5 c o
6 0) "0
is?
*** f i C
y M
o ,
^
* c
o
Vl
0)
W
CO
O
4J
CO
VI
O
CP
01
4J
cO
u
.a
3
CO
dP dP
Tf CO
vo r-
vo ro
o m
vo r-
co n
cn cn
CM CM
CM CM
0 O
rH 00
rH in
CM CO
M
M M
4J 4J
rH f
4 *"
,0) a
« a
i
VI
01
«
^
3
m
dP
t>
„
CM
rH
O
CM
rH
*
C
1
1
1
1
1
1
S.
1
1
u
dP
CM
VD
t-
oo
o
«
CM
O
CM
O
rH
cn
cn
in
oo
CM
Vl
a
i
Q
0)
C
a
•r
c
i
a,
i
c
i
^i
j
4J
U
dP dP
vD O
CM co
CO CM
CO 00
CO CO
CM CM
co r-
CO OC
CN CM
VO VO
M
M M
JJ 4.
< a
O* cr
Q) 0
a «
i
Vl
0)
3
rH
4J
3
•Q
o
rH
cd
X
o
c
1
^.
(
1
dP
CO
„
in
vo
cn
00
in
CM
0)
C
(
Vl
a
i
i
in
00
in
ro
rH
rH
cn
X
a
d
0)
c
(
1
n
4
a
0
,f
Vl
4.
dP
CM
VO
„
vO
CO
VO
CO
"•
\
(
A
1
6
0)
C
1
t
(1
4
C
(
•?
V
4.
dP
en
iH
in
^
1-1
CO
vO
CM
CO
CO
01
0) >i
^J M
W 0)
01 J3
C 3
01 K
-r|
•0 0)
cfl C C
4J 01 O
3 -4 -rl
*Q *O J
^t flJ I
l-l 4J rH
0 3 O
ft. OQ W
O
O
01
T
vl
i
'
dP
p.
CM
VO
ro
CM
CO
CM
CM
CM
CM
O
X
0)
4J
(
0)
C
<
I
4
d
o
c
0)
1
1
4.
dP
CO
CM
ro
^f
(N
CO
in
cn
rH
£
14
CO
0)
G
O
^4
•a
a
4i
I
c
o c
0) "t
U rj
4J i
CO U
dP
co
ro
cn
ro
^
vO
vO
ro
rH
CO
10
rH
in
VO
in
o
CN
in
VC
cn
VO
M
4J
r>
a
t
C
|
|.
t
ft
h
c
c
dP
cn
^
00
dP
CM
ro
dP
O
r-
t
n
4J
(
H
^
(
4J
e
i
u
]
i
O.
dP
O
in
o
cn
in
^
VO
VO
CO
rH
CO
VO
H
in
vo
in
o
CM
rH
rH
CO
VC
H
1
^
jQ
(
K
1
f
j
ff
0
ft.
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
11
This combustion results in the emission of nitrogenous oxides
(NOX) , carbon monoxide (CO), particulate matter (PM), and sulfur
dioxide (SO2) .
The emission of these five criteria pollutants will also
occur as a result of the combustion of coal, oil, or natural gas
used to generate the additional energy needed for control
equipment. These off-site air impacts were not included in this
analysis, although energy impacts are addressed later in this
memorandum.
There is no on-site combustion associated with the selected
control technologies for either storage tanks or equipment leaks.
Therefore, no secondary air impacts are expected from these
technologies.
Table 6 presents the estimated secondary air impacts for
process vent and wastewater control technologies. The total
criteria air pollutant emissions are estimated to be around
282 Mg/yr, with NOX emissions from incinerators and boilers
accounting for around 258 Mg/yr. The emissions associated with
wastewater controls constitute only around 4.5 Mg/yr. Brief
discussions of the methodologies used to calculate the emissions
shown in Table 6 follow. More detailed information is included
in Attachment 2.
Process vents. Secondary air impacts from process vent
controls are a result of the combustion of organic HAP's (and
supplemental fuel) in flares and incinerators. Testing at a
polymer and resin process unit using an incinerator for VOC
control measured NOX ranging from 20.2 to 38.6 ppmv.4 NOX
emissions were calculated using 21.5 ppmv, which is consistent
with the procedures used in the SOCMI CTG.5 Measured NOX
concentrations in flare outlet streams are were lower than those
from incinerators, ranging from 0.4 to 8.2 ppmv.6 The
concentration used in this analysis was 8.2 ppmv. The outlet
flow rate from the incinerator or flare was used, in conjunction
with these concentrations, to calculate NOX emissions.
CO, PM, and SO2 emissions were calculated using emission
factors from AP-427 for natural gas combustion in boilers with
a total heat input design of between 10 and 100 million Btu/hr.
The emission factors used are 35 Ibs emitted per million ft3 of
natural gas burned for CO, 3 Ibs per million ft3 for PM, and 0.6
Ib per million ft3 for S02. The combined volume of supplemental
natural gas and organic HAP was multiplied by the emission
factors to estimate emissions.
Wastewater. Steam stripping was the control technology that
was analyzed for wastewater. Secondary air impacts associated
with steam stripper operation can occur from two sources:
(1) combustion of fossil fuels for steam generation, and
-------
CO
PS
H
r^«
I
§
u
H
CO
H
"p
L*
§
U
L.
0)
a
1
3
§
.£
**
3
01
at
•5,
3C
1
M
1
L.
< "o
§
U
c
«
8
U
U
a.
X
0
o
U
o
«
a.
X
O
O
U
CN
O
v%
I
a.
0
(0
V)
0 O
,-! ,-'
0 0
d d
0 0
d d
-0
QJ Ol
ae at
U
2
oc
X
alobut
z
-
o
s
d
o
o
d
o
d
!_
C
O
0
(/
§ §
ro 10
in in
d d
CM CM
O C3
d d
~ ~
o d
0 O>
in N.
in in
«- CM
»» CM
•o co
?o rn
. d d
-j- •«
•* M
~ ^
? 5
ae ae
i
<
>-
O
t—
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
13
(2) handling or combustion of the recovered organic compounds.
For the purpose of this evaluation, it was assumed that recovered
organics are handled properly.
It was assumed that steam is generated on-site in an
industrial boiler burning fuel oil with a thermal efficiency of
80 percent. The fuel oil consumption was calculated using a
heating value of 150,000 Btu per gallon of fuel oil. The fuel
oil was assumed to be #6 fuel oil, containing 1.5 percent sulfur
by weight. The emission factors for this situation are 3.15 Ib
emitted per 1000 gallons of fuel oil burned for PM, 0.285 lb/1000
gal for SO2/ 5 lb/1000 gal for CO, and 55 lb/1000 gal for NOX.8
Water Pollution
Potential water pollution impacts from several of the
control technologies are associated with the regulatory
alternative. The wastewater and equipment leak controls actually
have positive effects on water quality, although these effects
are minimal.
Steam strippers remove organic compounds from wastewater,
thereby improving the quality of the wastewater being discharged
to the wastewater treatment plant or to a publicly-owned
treatment works (POTW) facility. Therefore, their use has a
positive impact on water quality.
Reduction of organic HAP emissions from equipment in liquid
service may result in reduced loading to wastewater streams.
However, the nature of these organic materials is that they
evaporate to the air. Overall, the impacts, both positive and
negative, on wastewater from the equipment leak provisions would
be minor.
The potential for water pollution is also present with
storage tank improvements. Before an internal floating roof can
be installed or upgraded, the tank must be emptied and cleaned.
A small amount of wastewater will be generated during tank
cleaning, but it is not expected that this source of water
pollution will result in adverse impacts on water quality.
The largest impact on water pollution is associated with
process vent controls. Control of organic HAP emissions using
combustion does not result in any significant increase in
wastewater discharge, since no water effluents are generated by
the thermal incinerator or flare. However, the use of an
incinerator/scrubber system for control of halogenated organic
HAP vent streams results in increased water consumption.
In a scrubber control system, water is used to remove the
acid gas contained in the thermal oxidizer outlet stream. The
amount of wastewater generated is equal to the amount of water
needed by the scrubber to absorb the acid gas leaving the
-------
14
incinerator. It is estimated that almost 46 million gallons of
wastewater will be generated annually from acid scrubbers at
Butyl rubber, Ethylene-Propylene Rubber, and Neoprene facilities.
Almost 41 million of this total are from the butyl rubber
facility. A key assumption used in this analysis is that
17 gallons of scrubber water flow is required for each 1,000 scfm
of vapor entering the scrubber. This ratio was used in the HON
analysis.9 Details of this estimate are provided in
Attachment 3.
It is not expected that the increased wastewater flow will
affect plant wastewater treatment or sewer capacity. However,
the absorbed acid gas may cause the water leaving the scrubber to
have a low pH. This acidic effluent could lower the pH of the
total plant effluent if it is released into the plant wastewater
system. Some process units may recover the acidic scrubber
effluent for reuse or resale.
The water effluent guidelines for individual States may
require that industrial sources maintain the pH of water effluent
within specified limits. To meet these guidelines, the water
used as a scrubbing agent may need to be neutralized prior to
discharge to the plant wastewater system. The scrubber effluent
can be neutralized by adding caustic (NaOH) to the scrubbing
water. The amount of caustic needed depends on the amount of
acid gas in the waste gas from the combustion device.
The salt formed in the neutralization step must be purged
from the system and properly eliminated. The methods of disposal
include direct wastewater discharge or salt recovery. Salt
recovery is only justified for large vent streams containing a
high percentage of halogens. In developing the cost impacts
presented later in this memorandum, the cost of caustic needed
for neutralization was not included. Further, the costs
associated with the disposal of the salt were not judged to be
significant in comparison to the control costs, and, therefore,
were not included in the projected impacts.
The use of scrubbers to remove hydrochloric acid from the
incinerator exhaust gas also has the potential to result in small
increases in the quantities of organic compounds released into
plant wastewater. However, only small amounts of organic
compounds are released into the scrubber wastewater, and the flow
of wastewater from the scrubber is small in comparison to total
plant wastewater, especially in installations where there are
multiple chemical processing units using a central wastewater
treatment process unit. Therefore, the increase in the release
of organic compounds in plant wastewater is not likely to be
significant.
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
15
Solid and Hazardous Waste
In general, there are few solid or hazardous waste impacts
associated with the implementation of the regulatory alternative
for the subcategories included in this project. There are no
significant solid or hazardous wastes generated as a result of
storage tank control by tank improvements, or as a result of
process vent control using a thermal incinerator, flare, or
scrubber.
Solid waste from equipment replacement includes seals,
packing, rupture disks, and other used equipment components, such
as pumps and valves. Metal solid wastes such as mechanical
seals, rupture disks, and valve parts could be sold to companies
that can recycle the metal. Although additional monitoring of
equipment may result in a greater rate of replacement for faulty
equipment, it may also reduce equipment failure. Overall, no
significant impact is expected on solid waste as a result of
implementing the equipment leak provisions.
Solid and hazardous waste could be generated from the use of
steam strippers to control wastewater emissions. The possible
sources include organic compounds recovered in the steam stripper
overheads condenser, solids removed during feed pretreatment, and
wastes generated in the control of system vent emissions. System
vent emissions, if not sent to a combustion control device, may
be collected on a sorbent medium that requires either disposal or
regeneration. If the sorbent is disposed of, it creates
additional solid waste.
Although waste generation can increase for any nonrecyclable
organics that cannot be used as supplemental fuel, these organic
wastes would most likely have been removed otherwise from the
wastewater via the air (volatile organics only) or via an
oil/water separator. Similarly, solids removed from the
wastewater in cases where pretreatment is necessary would have
likely been removed in a clarifier or activated sludge unit.
ENERGY IMPACTS
The energy demands associated with the control technologies
for the regulatory alternative include the need for additional
electricity, natural gas, and fuel oil. The storage tank and
equipment leak controls are not expected to require any
additional energy. The total nationwide energy demands that
would result from implementing the process vent and wastewater
controls are presented in Table 7. Overall, the controls will
require around 1.18 x 1012 Btu annually. More detailed
information is provided in Attachment 4.
The amount of electricity required to operate the fans and
blowers was estimated by calculating the horsepower required to
-------
16
TABLE 7. ENERGY IMPACTS
Subcategory
Butyl Rubber - Reg Alt I
Reg Alt II
Ethylene Propylene Rubber
Halobutyl Rubber- Reg Alt I
Reg Alt II
Neoprene
Nitrile Butadiene Rubber
Polybutadiene/Styrene
Butadiene Rubber by Solution
Styrene Butadiene Latex
Styrene Butadiene Rubber by
Emulsion
TOTAL - Reg Alt I
Reg Alt II
Energy Impacts (106 Btu/
Process Vent Control
Electricity
96
595
7,261
0
72
42
43,070
0
10,195
60,664
61,235
Natural Gas
6,300
97,792
75,052
535
758
196
753,688
418
176,329
1,012,518
1,104,234
yr ) From
Wastewater
Control
Fuel Oil
6,575
6,575
3,375
8,088
5,363
23,401
23,401
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
17
transport the vent stream. Electricity to operate fans and pumps
for scrubbers and steam strippers was calculated in a similar
manner.
The use of a combustion device generally results in an
increased natural gas usage for device start-up, supporting
combustion of the vent stream, or to promote flame stability, if
the heat content of the vent stream is low. The fuel impacts are
equal to the design fuel requirement. The fuel requirements are
dependent on the flow rate and the heat content of the HAP
stream.
Wastewater steam strippers require additional energy to
produce the steam. As discussed in the secondary air pollution
impacts from wastewater control section, it was assumed that this
energy was generated through the combustion of fuel oil in a
boiler. The fuel usages are based on the steam stripper design,
and the boiler characteristics that were discussed previously.
COST IMPACTS
The costs to the affected industry due to the application of
the requirements of the regulatory alternative include the costs
of any control equipment that must be purchased, along with the
costs of the installation of that control equipment. There are
also costs for the operation of control equipment. There may
also be costs associated with certain work practices and other
programs that reduce HAP emissions. Finally, there are costs
associated with the required reporting, recordkeeping, and
monitoring. In the next section, the methodology used to
estimate the cost impacts is discussed, followed by a
presentation of the estimated costs.
Cost Estimation Methodologies
The costs can be separated into two basic types: (1) those
directly associated with control equipment or practices, and
(2) those associated with monitoring, reporting, and
recordkeeping.
Control costs
The methodologies used to estimate the capital and annual
control costs for the expected regulatory alternative are the
same as the methodologies used to estimate the costs of the HON.
These methodologies are described in detail in Volume IB of the
HON Background Information Document.10 Parameters used in the
costing analysis are shown in Table 8.
The regulatory alternative includes flexibility in the
manner in which compliance may be achieved. In order to estimate
capital and annual costs, a single option was designated for each
-------
18
TABLE 8. PARAMETERS USED IN POLYMERS AND RESINS I
COST ANALYSIS
Parameter
Value
Base Year
Chemical Engineering Plant Cost Index
Natural Gas Cost
Electricity Cost
Water Cost
Operating Labor Rate
Maintenance Labor Rate
Interest Rate
Raw Chemical Cost Used for Recovery
Credits
Equipment Life
Steam stripper
Flare, incinerator, scrubber
Internal floating roof
Closed-vent systems
Gate valves for open-ended lines
Closed-purge systems
Monitoring instrument
Rupture disks
Pump seals
July 1989
356
$3.03/ft3
• $0.0509/kwh
$0.22/ 1000 liters
$13.20/hr
$14.50/hr
7 percent3
$9.98/Mgb
15 years
10 years0
10 years
10 years
10 years
10 years
6 years
2 years
2 years
a In the HON cost analysis, an interest rate of 10 percent was
used.
b An average raw chemical cost of HAP's used in the elastomer
industry was calculated using 1989 chemical costs obtained from
Mannsfield's Chemical Products Synopsis.
c The HON BID assumed a 15 year equipment life for flares, and
10 years for incinerators and scrubbers. However, VENTCOST uses
a single capital recovery factor for all equipment.
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
19
emission source type. Table 9 provides more detail on how the
costs were developed.
For equipment leaks and storage tanks, EC/R developed
spreadsheets that calculated costs using the HON methodologies.
VENTCOST, a costing algorithm developed by Radian Corporation and
used in the HON impacts assessment, was used to estimate thermal
incinerator, flare, and scrubber costs for process vents.
Similarly, a spreadsheet developed by Radian was used to estimate
the cost of steam strippers for wastewater streams. Electronic
copies of these programs may be found in Section II-I of the
docket (Docket item numbers II-I-3 and 4).
Monitoring, reporting, and recordkeepinq costs
In addition to the control costs, the facilities will incur
monitoring, reporting, and recordkeeping (MRR) costs. At the
time of the initial impacts assessment, the exact details of the
MRR requirements of the proposed rule were not known, although it
was expected that they would resemble those in the HON.
Therefore, estimates of the MRR costs for the regulatory
alternative were made based on the HON MRR costs.
The HON SF-83 analysis11 was used to obtain average
facility MRR costs. For facilities in subcategories already
subject to the HON equipment leak requirements, adjustments were
made to the average facility MRR costs, since these requirements
would be present in the absence of an elastomer standard. A
nationwide total MRR cost was then calculated by multiplying the
number of plants by the appropriate average facility MRR costs.
The ratio of the annual MRR cost to the total annual control cost
was calculated, which was 0.31. This analysis is documented in a
separate EC/R memorandum,12 which is included as Attachment 5.
To estimate the MRR costs on a facility-specific basis, the
nationwide MRR cost to control cost ratio discussed above was
multiplied by the estimated facility-specific control costs. For
instance, if the annual costs associated with installation and
operation of an incinerator were $100,000, the estimated annual
MRR costs would be $31,000, making the total estimated annual
costs $131,000. On a facility-specific basis, this type of
analysis probably overstates the MRR costs for those facilities
where control is 'required, and understates the MRR costs for
facilities where no additional control is required (where there
would be no estimated MRR costs). However, this analysis does
provide a reasonable nationwide estimate for the entire Polymers
and Resins I project.
As noted above, it was necessary to estimate the MRR costs
before the details of the MRR requirements of the proposed
regulation were known. The impacts shown in this memorandum are
based on these earlier estimates. However, the results of the
SF-83 analysis for the proposed elastomer regulation13
-------
20
a
ca
Qj
>•«
H
^
M
U
3
*
09
CO
o
u
M
^f
1*4
09
0
H
j™<
PI
o
j
o
06
E
0
u
Eu
f*<
O
as
o
^^
PI
H
PS
U
09
H
Q
•
H
^•J
^.
M
JJ
a
o
8
a
U
On
u
S *M
•a o
»f i
VJ
4J a
OIK
TO
«._j
"
Oc
M
CO B
9
C
H
C
*
{
Q
t
.,
II
«
i
u
jj
id
J3
JJ 0) O
£ C O»
-4 JJ C
O *~4
U JJ C 0) JJ
JJ O O J3 Vl CO
CO) 4J O -H
O -r-> 0) -H >M X
o ja JJ *0
0) id • id
a>jj M-I o vi
id id to o jj pi
vi id o ai QI
0 >i 3 vi y
JJ Vl
co id c o> to 0)
ca o c o>£
M* 01 -4 -H C JJ
O 0) JJ JJ -^
u m m jj c
ai ai e o jj o
Ou C U r^ -M
>i O "w M-l TJ •
JJ 0) M-i 0) to
J3 C Oi v JJ Ji -4 c ui (d C
•-4 O -H rH 6 10
C JJ O JJ id "4 jj
O Z CO 0) JJ
TJ -H CO 01 M-l
0)0) X 0) O
js jj • oi -a o
JJ O tO Vl 0) Vl
•* 01 M-I id vi
to TJ "^ O TJ Q) O*
id ai jJ C 3 C
3 vi -H Vi id -i
ft— 1 0) JJ CO JJ
m -*4 J3 to jj id
~4 to o E JJ to o
£ « id 3 3 0 — 1
H 3 *M C 10 U ,
0 A
01 TJ
U 01
~4 C
O -*
O ^4
0)
jj
• 0)
H 0)
U
ja ">
0)
TS TJ
01
S3
E Vi
0) C
JJ 0
0) U
TJ
0)
to >
C JJ
0) U
> 0)
M-l
JJ M-l
U 0)
01 1
.Q 0)
3 O
en u
0 01
JD
vT a
0 Vl
JJ U
id to
Vl
01 +
c
-^ Vl
0 O
C JJ
•-4 id
V
- 0)
01 C
Vl "4
id u
rH C
(K -H
•e
fl
H
JJ
a
s
fh
M
M
4)
u
0
a.
TJ TJ
H CD 0)
(0 JJ 01 B •
80 > id o)
CD 01 JQ 3
JJ E-( r-l ft l-l
ca z vi a) £ TJ id
O U O 10 O 01 >
E > JJ id JJ
(JO) U X
, id vi o 0) ai
O JJ «M 01 JJ -I TJ
3 0) C
oi TJ c >i n -H
U 0) O CO -1
•^ C -H JJ JJ 0) U
o "4 a c c vi S
.C E 10 01 01 01 H
O Vl -^ > -4 3
CD E U CD
JJ 01 C
u i jj id
>t~l J« ^ tO
ja > o 3 c • en
0) n) c 0 >H C
TJ TJ JS -^ 0) O
0) TJ 0) > — »
c rH £ a) a ai m
-4 O JJ JJ "* -^ to
E Vi -^ o E -<
Vl JJ 3 0) 0) Vl S
01 C 'H O 0)
JJ O CD 01 0) JJ
01 U 0) CD O O Oi
TJ -H 3 id ft
CD Vl id TJ M-l S
to > O 0)
JJ — t O> > Vl C r-<
c jj a> co o id
01 O JJ C TJ -H JJ
> to id o «-i to o
M-l O —1 3 CO JJ
JJ M-l JJ JJ O -^
U 0) 3 id 3 E 0)
a) i a jj ai JS
•njJ -^ JJ jJ
.a co vi E id ai
30 O -1 J= J= C
CO O b fH JJ JJ O
Vl Vl
O 0)
JQ
vT 3
0 Vl
JJ O
id to
Vl
0) +
c
•-I Vl
u o
C JJ
•H id
Vl
- 0)
0) C
Vl ~4
id u
-< c
U. --I
•o
a
(d
1
*tf
u
a
0
ca
u
a
u
0
Vl
a,
CD
vi n u
0 id 0) C at
j= o vi jj at
c co -4 «w c id id
- (8 JJ & -H£V)-H
§C 0) CO O JJ
M Q) -»4 Vl ^i M-4 -H
Ul JJ C D> tO O ^ C
CJi C* 0 C id EM 4J JJ *r4
O 0) Cu-H JJ CO
vi E E vi o) c e
D. 3 O O CJ • Vl At
U O JJ -4 10 Vl JJ
^ to ^ c **4 Q u jj o —i
Q C* ^ O O Vl *H C
, CU O 0) 0) TJ
3 C O id 1 QiJJ ^H JJ VI
O — i M-I — i jj id nJ O
•HVI jj c a jj > e jj
> O JJ -< 0) < id -to
OIJJCCCQXITJJJO)
QI e > a id CD c
efl) c E -ITJ o
id o id ai n a) u
C O> O — 1 JJ Qu Ij
JC **4 O Id Vl U 3 3 O
JJ 01 Vl Id ~4 Oi M-l
-H c 0 co c CXTJ a
3-^jjjJO CVijJjJ
co-i to £ -i o to c
0) x: o o ai -H >, o>
•HOE jj 3 jj e a>
jj vi a •* S -
•^3-1 • e 03 r-i u to a>
rH O*ldTJ-^4 Q)**4 OIVl C
•v4 -^CDjJ-^UOO-*"!
o *M jj jj co jj id vi jj vi
Id O **^ Id Q) **4 M^ O< O O
M-l C E rH 0) JJ
VICD JJ vi o 2 c c
oocoaiid C
B E i-4 C
?• _, 3 id O
•g gj 04 > O
O' CD
U »4
-------
21
a
H
04
O
r3
H
>
W
a
H
OJ
H
03
EH
03
O
U
W
o
i_4
E
*
04
••
M
03
J3
H
H
04
O
t3
n
CONTR<
fe
O
2
0
H
EH
04
H
DJ
O
03
H
Q
•
A
B)
r3
P)
rt
H
M
JJ
fl
11
1
8
en
fl
•w -r|
0 41
ID
TJ 0
0 U
a
41 Ll
at o
SIM
^^
*a u
Q) U
+J C
u (d
fl) -H
rH *H
fl) CU
M a
3
a
SH
H
O
U
U
g
0
M
fl
0
•r»
n
M
•ri
i
c
o
-1 O
Q) JJ JJ JJ
j= tn u
JJ 3 01 >i
JO rH rH
O> 6 <»-l rH
c o oi id
-- 1 U i-i U
JJ -»
O TJ JJ "W
fl) fl) O "4
C (0 C U
CO 01
O -1 O &
O U TJ 0
C
C 01 TJ 01
O C U
O> id — t
TJ C >
Q) — » Ll 0)
tn JJ 0) TJ
id m TJ
J3 -4 Id rH «
x fl) o m
Q) 01 J= l-l JJ
Ll JJ C
id c >, c Oi
id Ll O >
0) 01 U
•M O > O»
o) 4J o id c
O O -1
o E Q) en tn
ai LI c tn
»4J -rt id
a m LI TJ O>
Ll >, O TJ 01
O U) tt Id TJ
m fl
0) 4J > <4H 0)
0) C O JC
Ll 0) Ll JJ
a > o jj
§0) rH
TJ 01 O O
U 01 O U Ll
tn — i 4->
Ll O > 01 C
O rH 0) .C O
bv. U TJ 4J U
E 0) 01
0) > JJ
JJ rH 0)
n id >i
>i > n>
to
0) 0)
JJ 4J O>
C Id Ll
0) O> 3
> Pj
rH
TJ rH TJ
0) id fl)
01 JJ dl
o m o
rH C rH
U — 1 O
*-s
•0
a»
I
•A
% 0)
4 3 : -2
« c jj
™ -r( U
"« TJ rH 01
M f» r^ W
•3 5 » c
5 * Ll TJ C
J » ° « 0
f* * a TJ o
tn r;
£ £ 0) Q> 0)
fl C Ll 1 i-H
§ | a, c o,
\ 1 o & 1
•^ -3 o o w
O1 O1
u u
>1
assemb]
.*
n
•H
TJ
01
Ll
3
JJ
a
Ll
0)
s
>
rH
a)
>
14-1
0)
[fj
01
Ll
1
0)
li
M
3
(Q
0)
0)
Ll
CU
JJ C
n M
0 >>
O rH
rH •
0) Id Ll
£ O 01
c jj -- i a
0 £ «w CU
TJ -H O 4J "H — t
C JJ id U U Ll
id id oi ai ai j>»
Ll rH Qi O
3 0) LI MH n
0 C O 01 E TJ
rH 01 MH Ll 0) 3 01
>w O> O 0) S
Ll JJ — 1 JJ — 1
c ai ai o > n id
0 JJ Ql C 01 rH
m a TJ 0) o
TJ id -rl O £
0) 3 Ll TJ >iJJ O
m jj LI — i
id «-i m m ai E
JQ 0 JJ > O JJ
E ffl O Ll -4
Tf JJ id O O c u
E & J3 Ll O
Ll Id H O -rl >i
01 01 D Ll
jj JG LI rH m ai
fl) JJ O • O •-» >
T) HH E LI E O
jj id 4J ai u
m id TJ ai c 0)
E 01 Li O Ll Ll
id c Oi jj o — i
oi o o a id o
L4 --I rH Id C
JJ JJ 0) Ll rH
ID id > oi o* o -
Ll 0) JJ C Ll C
JJ JJ TJ Id -4 41 O
O C 3 TJ C -rt
ai ai a ai TJ o 4->
•n o JJ JJ id O — 1
ju c in n TJ
3 O 0 id MH O TJ
w o o 3 o *J id
Ll
0)
Qt
04
•H
Ll
4J
n
c
01
JJ
to
Lt
0
4>
a
01
4J
M
a
-------
22
($4.1 million for all subcategories) are relatively consistent
with the preliminary estimates used in this analysis ($4.4
million).
Estimated Costs of Compliance
The estimated total capital investments and total annual
costs are presented by subcategory in Table 10. More detailed
cost information is provided in Attachment 6.
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
23
>*
06
8
W
o
g
CO
>«
0
CO
H
CO
O
U
CO
o
a
i
H
i
o
H
H
- 1-
silf
H-
i
*" o £ 51
I
u
^
^^
SO O
O O
nj O O
IM IM -O
grO
in
*O l*~
•O IM
«- O-
ro «—
» «
«- IM
ro ro
IM O
ro in
S3
»- CM
N. IM
CO ST
•"
«- O
o> -»
•O 0
»-
•o
U —
(
"x
3
m
!
^™
IM
IM
-
in
2
rx
o
C
u
T
-f"
o
J
Q
Ol
"g
co
•-
i
r\i
ru
R.
0
i
i
r-
in
o
N-
m
o
in
I
1
a.
01
£
£
HI
§§§
O O IM
«^
in -»
ro co
fO ro
IM ^
ro •-
IM CM
r>- in
CM
in ro
IM CO
«- -o
co o
CM O
to in
•a
0 —
•J_
1
a
X
i
o
o
o
o
o
o
o
c
)
10
%
o
o
in
IM
in
ro
N.
»
co
~
r*
r\
rx
IM
r«
o
•o
in
-^
C
1
l_
a
i
*
o
o
CO
in
CM
V
CO
in
IM
3
5
u
'"g
CD
01
L. i
Z — 1
g
"
in
-
-
I
i
§
5
01
^
CD
41
— 1
U J
•-•§
z ec
S
o
o
o
o
o
0
0
~
(
o
a.
""§
in
in
O
in
in
Kl
Kl
CO*
•o
o
S
CM
-*
K>
O
CO
^
ne/Styrene
ubber by
'Sec
ill
030
a. ca in
1
"
i^
S
.
1
g
s
§
-j-
-
i
at
L. 1
Vt -1
1
co
«o
CM
CM"
o
§
in
CM
g
0
CO
s?
M
adiene
mulsion
D
• ft
>•?
in IK
*%
CM m co
CM CO
o 5S
to in
-------
24
loped are cos
meeting the
pping as low
e
y
r
s
ons. The cost de
e level achieved b
ost of enhanced st
emi
t t
en
ace
•o
iv
„ g.
e
•i
1
fc
O
8
1
I
tk
Oft
S
u
g
8-
1
8
oc
1
^
g
**
I
a
C
u
o
«rf
1
•
M
*rf
1
U
U
X
u
?
o
ki
ee
AI
S
4^
Alterna
X
i_
o
44
a
a
V
OE
01
>
4>J
Alterna
X
i_
o
4>
a
"3
D)
01
ae
L.
Or
4^
<
X
U
O
fef
a
s
01
Of
o
4-i
1
4*
a
c
L.
V
4-*
<
X
c-
o
*J
ID
1
or
§
*«->
o>
c
o
civeness in g
^
01
«*.
•4-
01
•w
(A
O
U
(0
4-*
i
L.
|
^
L.
4^
§
U
O
4^
"8
4^
1
4-1
M
01
(A
4^
M
O
U
f
O1
f
01
-C
4^
O
4rf
1
X
z
_
(.
Q.
V
L.
CO
w
=
(tr
>
V)
(A
41
1
4-
ii
H-
«4-
Cl
1
V)
o
u
01
«A
OJ
£
h-
(D
0
4->
S
u
£
2
(A
C
o
M
V)
1
4-*
5
4-«
o
tf>
(A
c
Ol
>
•8
Q>
-AC
U
5
to sufficient
VI
0)
u
1
§
4-*
to
t_
Al
c
1
i_
o
01
^
n
Ol
«4-
0
4^
01
4-<
1
4->
tf>
0)
>*
u
4J
(A
|
H-
O
c
o
4^
_«
O
a.
a •
ipping. Extr
incineration
ZI -«
4-> O
V>
4-*
>> (A
•° s
4-*
«*. Of
S.C
««—
o. o
^
-g
go
2 S.
(A
0) O
-------
25
REFERENCES
1. Memorandum, from Clark, C. EC/R Incorporated, to Evans, L. ,
U.S. Environmental Protection Agency. Potential for New Sources
Producing Elastomers (Polymers and Resins I). May 10, 1995.
2. Memorandum from Norwood, P. EC/R Incorporated to Evans, L. ,
U.S. Environmental Protection Agency. MACT Floors and Regulatory
Alternatives for Elastomer Production Industry (Polymers and
Resins I). May 10, 1995.
3. Control of Volatile Organic Compound Emissions from Batch
Processes. Alternative Control Techniques. EPA-453/R-93-017.
United States Environmental Protection Agency, Research Triangle
Park, North Carolina. November 1993.
4. Lee, K.W. et al., Radian Corporation. Polymers and Resins,
Volatile Organic Compound Emissions from Incineration, Emissions
Test Report, ARCO Chemical Company, LaPorte Plant, Deer Park,
Texas. Volume I: Summary of Results. Prepared for the United
States Environmental Protection Agency, Research Triangle Park,
North Carolina. EMB Report No. 81-PMR-l. March 1982. pp. 12
through 15.
5. Control of Volatile Organic Compound Emissions from Reactor
Processes and Distillation Operations Processes in the Synthetic
Organic Chemical Manufacturing Industry. EPA-450/4-91-031. United
States Environmental Protection Agency, Research Triangle Park,
North Carolina. August 1993.
6. McDaniel, M. Engineering Science. Flare Efficiency Study.
Prepared for United States Environmental Protection Agency,
Washington, D.C. EPA-600/2-83-052. July 1983. p. 134 and
technical report data sheet.
7. Compilation of Air Pollutant Emission Factors. Volume I:
Stationary Point and Area Sources. AP-42 Fourth Edition. United
States Environmental Protection Agency, Research Triangle Park,
North Carolina. September 1985.
8. Reference 2, p. 1-3.2
9. Memorandum from Ferrero, B., Radian Corporation, to Project
File 6.1. Estimating Liquid to Vapor Flowrate Ratios in Scrubber
Columns. February 5, 1992.
10. Hazardous Air Pollutant Emissions from Process Units in the
Synthetic Organic Manufacturing Industry—Background Information
for Proposed Standards. Volume IB: Control Technologies." Draft
EIS. EPA-453/D-92-016b. United States Environmental Protection
Agency, Research Triangle Park, North Carolina. November 1992.
11. HON SF-83 and Supporting Statement
-------
26
12. Memorandum, from Norwood, P., EC/R Incorporated to Evans, L.
U.S. Environmental Protection Agency. Estimated Monitoring,
Reporting, and Recordkeeping Costs for Polymers and Resins I.
August 9, 1994.
13. SF-83 and Supporting Statement.
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
ATTACHMENT 1
FACILITY-SPECIFIC BASELINE EMISSIONS AND EMISSION REDUCTIONS
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
•^^
-^
s
10
c
o
'w
CO
1
HI
a.
^
I
0)
t^
=
CO
co .5
^M
g
CO
LLJ
UJ
Z
UJ
ff\
CO
CD
O
ll
^^
o
UJ
D.
CO
|
>-
U
o
<
U.
«
o
F-
E •*
afrt
IU
3 I
CT
UJ
CD a)
W 03
CO >
3> >
•a
c
HI
•2 '
c *^
® «
^ CD
CO
0) TJ
O C
O UJ
u- 1
Du *L
o
it
CD
0)
2
O
CO
?9
o >,
£ ^
CO ,<°
OIL.
X)
3
CO
CO CM O> O
N. ,- r^ co
^" CO 00 0)
cn T- T- in
cn CM "sr co
i— h* 00 CD
CM CM CO in
CO T- i-
m K -r- o
CO CO O O
in in r^ co
cn co h- oo
O i- CM 'it
T- T-_ CO
^
^" h» CO CM
r^ o co o
CO T- O>
a>
o T- JD 'st- m
CD O -O CO CM
v t^ 3
o5
c
CD
. | !_
•Q T J= T ^ T i
xj ' o J. ' cc cc
3 £ * 0- a> ct ct
ccm I111 Sujuj
> o >.
3 'a £
QQ UJ LLJ
•r- CO
00 CM
"fr CO
CM cn
co cn
CM r^-
o <3-
CM >
4-1
3
X)
O
CO
I
CO •'t
cn cn
CM_
in T-
oo" CM"
CO T-
CM
o o
o o"
in co
o oo"
00 CM
CM
in oo
co" cri
§ *
oo cn
S "*
' I'
£ °->
I ^X
cn
S
CO
CM
j^;
in
in
in
^>
CO
o
CM
CM
CM
^
CM
CD
C -i-
2 i
aO
O UJ
CO
25
CO
CO
co"
CO
^
0
o"
in
*~
CO
CO
o
O)
&
CM
1
O
UJ
^
C)
CO
CM
in"
CO
q
"*
CJ
CO*
^—
CO
^— I
CM
cn
o
CO
1
O
UJ
cn
c%
r»-
CM
S
.,_
CM
in
co"
o
CM
CO
^J
in
CO
in
5
CO
TB
•*-•
o
o
O)
^
-^
CO
-------
^
.>.
••k
O)
5
to
c
o
"to
CO
1
ID
Q.
<
I
V
C
"w
CO
CO £
Z m
o
CO
CO
2
LU
LU
_J
LU
CO
<
m
0
iT"
CILITY-SPEC
<
LL
CO
*j
O
h-
*->
| (0
E .*
•is
o-
LU
V m
y\ u/
«5« *-
M CO
CO >
5 $
i^1
T3
LU
w 1
si
Jr CO
> m
CO
CO
CD "O
O C
O LU
^^ 1
ct i
C
o
ul
CD
O)
2
o
+•«
CO
bcategory/
Facility ID
3
CO
i
o
CM
CM
O
00*
O>
CO
C
CD
CM"
in
^j
X
0>
^^
CB
trile Butadiene
NBL-1
^^
IE
in »>«.
oi ^t
CO
8
Y—
in N.
O) K
T—
CM
O>
^t
O O)
CD ID
O)
CO
o
T~
(0 CO
C C
O 0)
o o
in
co'
O CM
o o"
r^
,_j
(A
NBL-2
NBL-3
bcategory Total:
3
CO
en o r^ o>
SCO T- T-
00 CO Is*
CM i-
in
CD
CO
in
O) CO 00 O
CM T- m Tf
in CD •'d- co
T— Y—
CM
in
CM
-t
CM Y- Y- Y-
CM CM CM Y-
in
h-
Y- h- If) Tf
CD •f O O
CO Y-
co
^t
N. OD co in
o co CM in
CM
CO
i^
CO
o o> in o
*- o o" o o
Q)
X3
J3
3
^t
,_"
CC to
? *
c K
Q) O
T3 Y- CM CO •* T.
« 1 1 1 1 ^
•3 tr DC oc tr °
£mmmm g>
®22ZZ§
'£ -Q
•- 3
Z CO
<^-
CO
CO
in
Y-
m
CD
00
CO
§*
•^ o
D CO
— CO
O
CO
>.
JQ
s«
5 CO
.LJ
CC
Q)
C
CD
'•5
m
IU
3 °°
ffl °
C
0)
i_
><
4^
lybutadiene/S
PBR/SBRS-1
o
CL
CD 00
CD O)
r*. in
^~
•* "t
CD r-
h- co
CM
Y- O>
O CO
*""
o in
o in
&
o o
o o
i- O
o o
PBR/SBRS-2
PBR/SBRS-3
in o>
o in
O CO
*-_CM_
1F" ^~
CM
i
co"
co in
•<3- O)
r»- oo
Y"- T—
CM
CO
O CO
CM CM
CO
in
CM
CO N-
T- m
r*. co
r^ o
CM
CO
§
CM"
CO O
O) CD
in
'r~
o>
CO
co
T-
in oo
^_ T_
CO
t^
o'
o
o
o
o
N.
«fr 0
(A
PBR/SBRS-4
PBR/SBRS-5
bcategory Total;
u
co
0)
lysulfideRubb
PSR-1
o
Q.
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CO
CO
CO
2
HI
HI
z
HI
CO
m
o
o
HI
Q_
CO
I
>-
D
O
<
LL
^^
.>.
O)
5
(/)
c
o
'55
CO
E
HI
Q.
^
I
0)
c
is:
0)
CO
CD
^5
o
i-
c
CD w
E ••»•
.9- S
»^_ *4/
HI
I
0) o
g«
|*
T3
C
LU
CO |
*"" .i
Q) Q
> CD
CO
CM
CM
CO
O
CM
1
CD
CO
o>ino>o>^rT-cooino>o>CDin
CO ^^ O) ^D lO 00 O) ^^ CO <*-™ ^^ CO ^"
f^* ^^ oo ^"* co co ^^ ^~* ^~ r^ 10 ^^
CM CO CM
|s-
^.
CO
05 LO T~* co xj* O) c^ ^^ T"™ O) r^ ^^ 10
O5 CO LO CM *""* 00 ^^ CO LO IO IO CO ^D
^Q ^^ ^«_ ^_ ^— ^SH pQ CO ^f C\J ^^
CO
CO
^5 ^D ^"~ O) ^D CO IO CO CM IO h^ CO ^~
O O CJ CM O" CM CM CO" O •*' CO CO" T-
CD ^f t- in CM T- fs.
CM CM
CO
8
CO
C0c0(0(0(0c0c0(0c0(0c0(0c0
ccccccccccccc
^•CDCO'T-COi-CMCOCOT-COOO
CO' O T- in CO" CO CM O O T- O" CD CM
CM -r-
CM
fs.
00
00
CM
inojcncoincocooin'^-coocj)
o" o o" o c> o o T- o" o o" o" o
>
CO
CO
CO
(0
0
!il!i" jl**TTTTTT cT
CQmcDCDCQCQCDmmmmmm S*
CO CO CO CO CO CO CO g g g g g g |
o
jQ
3
CO
10
CO
CS
0
O5
CO
in
o>
in
in
CM
c m
o to
[55
3
E
HI
^
^*
te CM
^ w
13
cc
o -
c
0)
tyrene Butadi
SBRE-1
CO
CO
o
0
00
o
0
^^
^^
CM"
CO
JS.
0
o
CM
I
LU
CC
CD
CO
0)
O
CO
O
CO
T—
5
,_
CO
^
in
CO
CM
o
CO
I
HI
CC
CD
CO
CM
CO
CO
CO
s
T—
•<*
in
CM
CM
CO
CO
^-
cS
CO
O)
is.
CO
CO
in
oo
in
CM
in
O)
CM
in
CO
is.
CO
CO
SBRE-4
ubcategory Tol
CO
-------
0
0 - e
111
03m
£ "°
* rr £
0. «• 0
1
*rf
*^^ Q) «A
>. E •*
"» o. *
SE 3.5
«-» cr
e UJ
.0
73
5 i ta
0 0m
cc t> 3
M 5s
e 5 '
°S5
M
E 1
UJ UJ
o. £ '
i § "y
™» *" m
> 03
U
M __
0 T?
0 UJ
^m 1
Q. - °)
t €
=i 8
u £
< 3
U. CO
5? 5? j5
to r»
(O CO N-
co CM r^
S" CO CO
m CM
(Oh- i-
co co to
co co en
en en r-
CM CM i-
tq to
T— 1—
O 0
t CO
•^ co'
T- in
CM CO
,_
^
— ~i£.
i i T
••- -r- £L
m CO m "O
^ £
-O O
5 I
I I
CQ UJ
•^
W^ Vs W^
to in to
co co en
in m co
r>- en en
»- O CO
O CM CM
t CO CO
co CM cn
CM co eo
i- CM
CO
en
en
CO 0
en in
^
CM
CM
0
JO
•a
„ t- CM CO
« 1 1 1
o cc cc cc
•S 0_ o_ D.
g^LU Ul UJ
O
ot
1
1
0
£
UJ
5? $S
CM CO
t to
r>- cn
CM N.
O r-
f CM
j§ j? j? g?
CM in in o
tO CO CM O
00 CO 00
O CO CO
CM
N- Is"
CM !>«•
O i-
t CM
t 00 00
O CM CM
CM CO CO
C3 CM CM
'*"
O
d
CO
cn
cn
CO t Tj-
t 00 h^
oo co oo
CM
O
t CO CO
CM CM CM
to to
m
re
*-*
o
1—
^
o _ —
O) *- ~
Q> ^ r?
*^ ^ ^
t in « T-
1 1 £ '1 1
CC CC 3 _ 0.
CL a. co ai i T >:
UJ Ul _Q ' 1 I
•S co co
fy. X X
^"
5- c
= 0
1 1
n >,
X X
j? jS gS
i- CO O
f* CJ t
cn f*» en
CM CO -r^
in to co
CM
j?
CO
in
eo'
in
CO
co q cn
CM T^ T^
to co
h^
in
en
o
d
o
d
„_ ^
o" r^
cn to
CO
|sj
in
CM
0
d
w
(0
o
..^
o
O)
Si
t- CM CO «
III"
000?
UJ HI UJ CO
0
CJ
Q.
O
0
Z
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
•o
0)
DC
CO
.2
UJ
a.
co
O
U
o
UJ
DC
CO
CO
i
UJ
o
u.
o
UJ
a.
co
I
O
u.
0
O)
*••
0)
o
bw
CD
0.
o
c .-
O "QJ
"5 w
•3 ^
0> P
CE o
Ta
tj
1.
11
3 _l
cr
UJ
« OJ
*T **
CO "
T3
C
UJ
J2
^ JC
» ffl
>CQ
CO
2 -o
u c
o ui
k- |
"c
o
u-
0
01
(0
o
CO
o
><
'5
A
u.
o
D>
0)
IK
t\
O) CO CO
CD 00 Tj-
CO CM T-
d r^ N-'
CM CM i-;
CO' 1^ h-
r^
0)
in o CM CM h-
co 't in CD oo
CO CM CM t- t*~
TJ. CD T- oo cn
co CM in co Tf
in CM •>- T- r>-
O CD O CO CD
•«t CM in eo ^-
^~ ^~
T-
o>
5?
CM
CD
CM
in
CO
eo
CO
CO
q
d
q
d
o
6
o
d
O T-
6 T-'
i-
T-^
0) (A
(8 «
0 "5
1- 1-
>< >>
O > O
C3) J- 0)
cu O m
X *i A •=•
OJ^CMCO™ n^CMCO^JO
•5111^ 31111^
J-I-J-JD DCDCOCDCCCa
mmmco aCDCDCDCQco
£<£.'£.<£. g-ZZZZ
0) «
^ 'o
« 2
3 3
ffi CD
fl) dj
C
o
5
Q
CO
.a
cu
13
3
DC
O
C
Q)
'•5
(0
5
CQ
0)
c
0)
c
.2
CO
3
o
CM
O>
CM
CO
O)
c\i
CO
^»
T-
CO
DC
CQ
Q_
o>
CM
cn
T-
CM
CM
CM
1
CO
DC
CQ
CO
DC
CD
D_
CO
in
O)
o>
in
oi
0)
Y«
CO
1
CO
DC
CQ
CO
DC
m
Q.
vp vp
Jx Jx
1^- CM
* in
•r- CO
CO CO
U) CO
in h-'
eo •*
T— ^~
5?
^
CO
5
CO
CD
O
O
•* CM
6 T^
CO O
co in
CO
^J
CO
CO
o
o
o
o"
U)
a
"o
h-
>>
O
* in
1 I
CO CO
DC DC
CQ CQ
CO CO
DC DC
CQ m
Subcateg
Q. CL
b
o
o
si
|£
DC
0)
[D
j^
3
CO
CO
o
a.
_x
o
a.
-------
0
g> c .S
« .2 "3
•e T; «»
IIS
1=1
5
"5
'c
£< 1 £
Hi Q. «
«• ._ QJ
S. o--1
c UJ
.0
3 .
TJ 1 ,_
0 o> 35
1 ^
M
W
E 1
UJ U
o. £ '
< c IS
> m
(0
8-0
U C
O UJ
*" 1
a. «L
1
LL
0
CO O)
z «
O o
1- CO
0
D
O
UJ
DC
z
o
CO
CO
2
UJ Q
O^
>,
U. ^
o "S
Ul U.
Q. •**
CO £«
1 O
>- 0)
H »
U «
== U
O £
< 3
U. CO
CM 00 N- tD CM CO 0)
T-OO>N.OCOOCM
CACDO^COCMf^tO^
CM in i- in
CM
atocntocMh-toco
mi- -i-
Tf
6
CM
CO
CM
CM
,
X
"Si-CMCOtintDh-CO
-J 1 1 1 1 1 1 1 1
^cocococococococo
no
a
03
0
c
0
^*
CO
^S. ^>x ^V yv ^S. ^V QS, ^X 0N. ^S.
••-OtOCMtOCOCO^- ^tO
r^N-CM^tincM ^t •*-
oocoo^i-eofflin i-o
co^-omcncoooto oo o
CO CO 00 CO i- CM ^>
CO
CnOCMO^COCDCM
co^^omo^cooocM
CO CO ^t CO i- CO ,
CO
CO O i-
T-" c\i oo'
co r^ Tf
CM
CO
CM
CM
o
o"
o
(A
•5 i
«-! LU
o
l_ ^.
t £
O a>
D> n
& S
0,0^-cMco^ing =77
jj •& ^ UJ UJ
ScamcocacacDCO Smm
wcocococococo .scoco
•o
«
3
CQ
0
C
0
IM
^
CO
1^ CO CO
* CM CM
CM 00 T^
in a> co
00 O *
i- CM
o
o
T-
5
CM 00 O
in oS in
00 O O)
1^ T-
o
o
o
o
in
A
0
f^
o
O)
w •* "ffl
II t\
1 O
UJ UJ -Q
gg"
CO CO
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
ATTACHMENT 2
CALCULATION OF SECONDARY AIR POLLUTION IMPACTS
-------
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
O
u
inpcMpcocoeooo — oppoovv — cn
'
o
inocxjoooco — o — — oooor-oocMiDOioto
D)
w
c CM
.2 O
LU
a
ppp O|CM
*r d v ••rlcd
CM O O O
OOOOOOOO co CD
*- co o co
CM co v
-- 00 CM co in a>coov^*-f~r--
co CM CM »- o co ••- in «• vv
»- co •— co cn o oo
»- »- co CM o o o
5 5,cor^pcMcocOTfpo>
O ^j~ CO *~ O O (*•« O) f*» CO O ^" ^~ O O O O (D CO 00 0) ^ ^ CO CO
^2o> i- T- ^ * cMCMCOinin mm
•jj *• CM CM CM
£
CO
U j^T-Trco^coco^pincM'-ppp'reoinoD^cocooiO)
— o 3^ dcod^riri^r^dddddddirico'r^oi^ddd
>^2cn »-^^ cMCMcoinininm
Q !§S CM CMCM
O ^
OC c
Z 5gco^incMcqN.r^pcMcninfl;'--cocMoDN-^-cocMCMcoco
O O7TcocMCM'-:iricricocM'-;CMdddd'-:^CM^dod'-t^i^
X=2>r^inininr- inmco
H S
2 cn
UJ •;
> Jppppppppppppppppppppppp
7 "&id ddinddddcoddih^-cMdcdcoooaDoddci
^r k.cooof^cotococDcocoocor^coo^troococDcocD
O j:r^cooocMCMCMN-mcMincocnoo>^'^'OOh»r^>N>r^
P oocMCM»-'rv*roDr^ — v cM<-inKr^i^-r^.cooooooo
_i
_i
Q a>£cMinpinco'-coco^;cMina>cn^rincoo>oqcocMCDCM
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Calculation Methodology Description
Secondary air pollution from process vent control devices
• HAP MW is weighted-average molecular weight of all HAPs in
vent stream. For example,
a vent stream for facility EPDM-2 contains 302,178 Ibs/yr of
chloroprene (MW=65) and 25,000 Ibs/yr of hexane (MW=86).
302,178 + 65 = 4,649 Ib-moles chloroprene/yr
25,000 -i- 86 = 291 Ib-moles hexane/yr
Stream HAP MW = 327,178 total Ibs/yr + 4,940 total Ib-moles
=66.2 Ib/lb-mole
• HAP emission rate (Ibs/hr) and operating schedule (hrs/yr)
obtained from information provided by companies
• HAP flow is calculated from the HAP emissions rate assuming
ideal gas behavior. For example,
a vent stream for facility BR-l emits methyl chloride at a
rate of 33.2 Ibs/hr for 8760 hrs/yr. The volumetric flow
rate of HAP is
33.2 lb 8,760 hrs Ib-mole 392 ft3
X X X = 2.3 x 106 ft3/yr
hr yr 50.5 lb Ib-mole
• The natural gas flow rate and outlet flow rate were calculated
by VENTCOST.
• NOX emissions from incinerators and flares were calculated
assuming 21.5 ppmv and 8.2 ppmv, respectively, which is
consistent with the methodology used in the SOCMI CTG. For
example,
the outlet flow rate from the incinerator controlling a
stream at facility EPDM-1 is 23,906 scfm. The incinerator
operates 8760 hrs/yr. NOX emissions were calculated as
follows:
23,906 ft3 60 min 8,760 hrs 21.5 ft3 NOX
x x x -—f— x
min hr yr l x 106 ft3
1 Ib-mole 4'6 Ibs NOY Mg
, X X = 14.3 Mg NCL. emissions/yr
392 ft3 1 Ib-mole 2,200 Ibs
-------
Calculation Methodology Description
Secondary air pollution from process vent control devices
(continued)
The emission factors used to calculate SO^, PM, and CO
emissions are from AP-42 (page 1-4.2), which are emission
factors for natural gas combustion in boilers. The factors
used were for a furnace with a total heat input of between 10
and 100 million Btu/hr. These emission factors are
S02
PM
CO
- 0.6 Ibs emitted per million ft3 of natural gas burned
- 1-5 (3 used) Ibs per million ft3
- 35 Ibs per million ft3
The combined volume of supplemental natural gas and organic
HAP was multiplied by the emission factors to estimate
emissions. For example,
a vent stream at the SBRE-4 facility had a natural gas flow
rate of 59.1 x 106 ft3/yr, and a HAP flow rate of 0.4 x 106
ft3/yr. The annual CO emissions from the combustion of this
stream in a thermal incinerator are as follows:
59.5 x 106 ft3 35 Ibs NOX Mg 0.9 Mg CO emissions/yr
«»^»«B^^^_^_^^_^M>«^B^^_^«MM. ^^^BHB~—V^^_B_BM«^^^^^B ^^^•B^_B^^_^«.^^«_^^^»
yr 106 ft3 2,200 Ibs
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
o
cc
O
O
cc
LU
1--
LIJ
CO
<
$
5
o
cc
LL
Z
o
£3
D
d
CL
CC
CC
G
O
O
LU
CO
LL
O
Z
g
CL
*
o|g
u_ CD S
cc
CO -T--
c -^
i |s
a £o>
CO ^ <
ffo
cc 33-
§>
"5
o
-D
CO
c5
E
CO r<- O) CD O
O~> CO CO ID •»—
d d d d T-
O) CO CO IO O
o o o o i-
d d d o" d
00800
d d d d d
CD CM IO CO CO
o o o o o
d d d d d
§N- o o co
v— IO O CO
o> r^- ID oo
O5 ^f lO CM CO
CO T— CO CM ^i"
00 O) O) h- CD
CO | N .CM ,-yj CM
0
1 1 1 1 n
CQ CD 7^ CO CT
CO ~>
D
°°-TT-
_J ' W_J '
CD m £ CQ 5
03 CO CO Z
§
CO
in
CO
d
CM
o
d
CM
CM
d
0)
o
!1
0)
Q.
O
00
°
0*
C
CD
"o
(D
CD
"o
CO
1
c
_o
"co
"?
m
' §
1"
D)
C
E
D
to
^
-------
Calculation Methodology Description
Secondary air pollution from wastewater control devices (steam
strippers)
• Steam requirements calculated by Radian steam stripper costing
spreadsheet.
• Fuel oil required was calculated using the following:
- a heating value of 150,000 Btu per gallon of fuel oil
- it is a #6 fuel oil containing 1.5 percent sulfur by weight
the boiler has a thermal efficiency of 80 percent
For example, the fuel oil required to produce steam for a
stream at facility SBL-8 was calculated as follows:
4.68 x 109 Btu gal fuel oil 1
X X = 39,000 gal fuel oil/yr
yr 150,000 Btu 0.8
• The emission factors used are from AP-42 (page 1-3.2), which
are emission factors for fuel oil combustion in industrial
boilers. These emission factors are
PM - 3.15 Ib emitted per 1000 gallons of fuel oil burned
S02 - 0.285 lb/1000 gal
CO - 5 lb/1000 gal
NOX - 55 lb/1000 gal
• The fuel oil required was multiplied by the emission factors
to estimate emissions. For example,
the vent stream at the SBL-8 facility required 39,000 gal/yr
of fuel oil. The annual NOX emissions from the combustion
of this stream in a boiler to produce energy for steam is:
39 x 1,000 gal 55 Ibs NOy Mg 0.98 Mg NOX
X X emissions/yr
yr 1,000 gal 2,200 Ibs
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
ATTACHMENT 3
CALCULATION OF WATER POLLUTION IMPACTS
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
WASTEWATER GENERATED BY SCRUBBERS
Plant
BR-1 *
BR-1*
BR-1
EPDM-1
EPDM-1
EPDM-1
EPDM-1
EPDM-2
HBR-1
HBR-1&
NEO-1
NEO-1
NEO-2
NEO-2
SBL-2
SBRE-4
SBRE-4
SBRE-3
SBRE-3
SBR/PBRS-4
SBR/PBRS-4
SBR/PBRS-5
SBR/PBRS-5
Flow Rate
to Scrubber
(scfm)
4,133
251
1,595
0
0
0
0
114
0
1,617
284
220
62
157
0
0
0
0
0
0
0
0
0
hrs/yr
8,760
2,600
2,000
1,075
4,260
4,260
4,260
8,760
7,563
1,260
4,500
665
2,974
1,032
5,900
7,446
7,446
7,008
7,008
8,760
8,760
8,760
8,760
Water
Flow Rate
(1000gal/yr)
36,929
666
3,254
0
0
0
0
1,019
0
2,078
1,304
149
188
165
0
0
0
0
0
0
0
0
0
45,752
* These streams would not require control under Regulatory
Alternative I.
-------
Calculation Methodology Description
Wastewater generated by scrubbers controlling vent streams
• Flow rate to scrubber calculated by VENTCOST.
• Water flow rate calculated using the ratio of 17 gallons of
scrubber water flow per 1,000 scfm of vapor at the scrubber
inlet. This ratio represents an average liquid to vapor ratio
based on a vendor survey conducted by Radian in the
development of the HON. An example of this calculation is
as follows:
An incinerator at facility NEO-2 has an outlet flow rate of
157 scfm that is sent to a scrubber to remove HC1. The water
flow to the wastewater system is calculated as follows:
0.157x1000 ft3 17 gal 60 min 1,032 hrs 165 x 103
X ~ X X = gal/yr
1000 ft3 hr yr
1 Memorandum from Ferrero, B., Radian Corporation, to
Project File 6.1. Estimating Liquid to Vapor Flowrate Ratios in
Scrubber Columns. February 5, 1992.
-------
ATTACHMENT 4
CALCULATION OP ENERGY IMPACTS
-------
-------
CALCULATION OF ENERGY IMPACTS FROM
PROCESS VENT CONTROL
Plant
ID
BR-1*
BR-1*
BR-1
EPDM-1
EPDM-1
EPDM-1
EPDM-1
EPDM-2
HBR-1
HBR-1*
NEO-1
NEO-1
NEO-2
NEO-2
SBL-2
SBRE-4
SBRE-4
SBRE-3
SBRE-3
SBR/PBRS-4
SBR/PBRS-4
SBR/PBRS-5
SBR/PBRS-5
Annual
Electricity
Cost
$7,203
$222
$1,438
$0
$24,835
$32,177
$51 ,068
$147
$0
$1 ,078
$346
$130
$52
$99
$0
$23,91 8
$21,401
$56,319
$50,310
$213,791
$0
$214,080
$214,080
Electricity
10~6Btu/yr
483
15
96
0
1,666
2,159
3,426
10
0
72
23
9
3
7
0
1,605
1,436
3,779
3,375
14,344
0
14,363
14,363
61,235
Natural Gas
Use
1000ft3/yr
91 ,068
424
6,300
76
14,270
15,252
44,408
1,046
535
223
142
16
20
18
418
25,813
23,547
67,846
59,123
251,330
620
250,869
250,869
Natural Gas
10~6Btu/yr
91,068
424
6,300
76
14,270
15,252
44,408
1,046
535
223
142
16
20
18
418
25,813
23,547
67,846
59,123
251,330
620
250,869
250,869
1,104,234
tfould
under
Regulatory
-------
Calculation Methodology Description
Energy impacts of process vent control
• Annual electricity costs calculated by VENTCOST.
• Factors used to calculate the electrical energy are:
Cost of electricity - $0.0509 per Kw-h
.Energy conversation factor - 3,415 Btu/Kw-h
For example, a stream at facility SBR/PBRS-4, it was
estimated that the annual electricity cost would be
$213,791.
$213,791 Kw-h 3,415 Btu 14,363 x 10s Btu/yr
————_—_—_^_^—— ^ ——————— ^ —^———————- ^
yr $0.0509 Kw-h
• The natural gas use was calculated by VENTCOST.
• The energy expended through the use of natural gas was
calculated assuming a heating value of 1,000 Btu/ft3. For
example, a stream at EPDM-2 requires 1,046,000 ft3 natural gas
per year.
1,046,000 ft3 1,000 Btu 1,046 X 106 Btu/yr
yr ft3
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CALCULATION OF ENERGY IMPACTS FROM WASTEWATER CONTROL
Electricity
Requirements Fuel Oil Requirements
Plant Subcategory Kwh/yr 10^6 Btu/yr gal/yr 10^6 Btu/yr
SBL-8
SBL-11
SBRE-1
NBL-1
BR-1
SBL
SBL
SBRE
NBL
Butyl Rubber
21,257
8,130
19,479
12,272
23,862
72.6
27.8
66.5
41.9
81.5
39,000
14,917
35,750
22,500
43,833
5,850
2,238
5,363
3,375
6,575
290.25 23,400
-------
Calculation Methodology Description
Energy impacts of wastewater control (steam strippers)
Annual electricity costs calculated by Radian steam stripper
costing spreadsheet.
The factor used to calculate the electrical energy are:
Energy conversation factor - 3,415 Btu/Kw-h
For example, for the combined stream at facility SBRE-1, it
was estimated that the annual electricity demand would be
19,479 Kw-h.
19,479 Kw-h 3,415 Btu 66.5 x 10s Btu/yr
X =
yr Kw-h
The methodology for calculating the amount of fuel oil
required is discussed in Attachment 2.
The amount of fuel oil was multiplied by 150,000 Btu/gal to
obtain the energy from fuel oil used. For example, the
combined stream at facility BR-l uses 43,833 gallons of fuel
oil per year to produce steam.
43,833 gal 150,000 Btu 6,575 x 106 Btu/yr
yr gal
-------
ATTACHMENT 5
I
I
I
I
I
IEC/R MEMORANDUM PROVIDING THE BASIS FOR PRELIMINARY
MONITORING, REPORTING, AND RECORDKEEPING COST ESTIMATES
I
I
I
I
I
I
I
I
I
I
I
I
I
-------
I
InCOmorated Environmental Consulting and Research
-
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Date: August 9, 1994
Subject: Preliminary Monitoring, Recordkeeping, and Reporting
Costs for Polymers and Resins I
From: Phil Norwood, EC/R
To: Leslie Evans, EPA/OAQPS/ESD/CPB
This memorandum presents estimated monitoring,
recordkeeping, and reporting (MRR) costs for the Polymers and
Resins I project. These estimates are based on the MRR cost
estimates for the Hazardous Organic NESHAP (HON) , and are
intended to be a preliminary estimate. A more detailed analysis,
specific to the requirements of the selected regulatory
alternative for Polymers and Resins I, will be necessary at a
later date.
This estimation was made using the methodology from the HON
SF-83 analysis. Copies of the HON SF-83 and supporting statement
are included as Attachment 1. In the HON analysis, the average
technical hours per monitoring, reporting, and recordkeeping
activity were estimated for a representative facility. These
numbers were multiplied by the number of activities per year to
obtain an estimated number of technical hours per year for the
representative facility (source). The estimated technical hours
needed per source are shown in Table 1.
Warren Johnson of EPA, the author of the HON SF-83 and
supporting statement, indicated that the HON estimates include
costs for monitoring equipment. He said that monitoring
equipment costs were converted to technical labor hours, and that
these were included in the "gather information, monitor, and
inspect" activity. However, the SF-83 supporting information
does not provide details on this conversion.
For the Polymers and Resins I MRR cost estimate, EC/R used
the technical hou'rs per source estimates shown in Table 1, and
the other information shown in Table 2. Since it is expected
that many of the control requirements (as well as monitoring,
recordkeeping, and reporting requirements) for the Polymers and
Resins I regulation will be identical to those in the HON, this
should provide a.reasonable preliminary estimate for this
project. However, a future analysis should take into account the
actual monitoring, reporting, and recordkeeping requirements of
the Polymers and Resins I regulation. Also, the assumptions for
the HON representative plant should be examined and modified to
reflect a representative Polymers and Resins I facility.
University Tower, Suite 404 • 3101 Petty Road, Box 37 • Durham, North Carolina 27707
Telephone: (919)493-6099 • Fax: (919) 493-6393
-------
TABLE 1. TECHNICAL HOURS NEEDED TO COMPLY WITH
MONITORING, REPORTING, AND RECORDKEEPING REQUIREMENTS
Tech hrs/yr
per source
Activity
Read rule and instructions
Plan activities
Training
Create, Test, Research and Development
Gather info., Monitor/inspect
Process/Compile and Review
Complete Reports
Record/Disclose
Store/Rle
Overall*
167
276
111
2499
1250
20
151
35
27
Eq Leaks
18
12
10
1220
750
4
125
21
1
b Overall includes equipment leaks.
b This estimate incorporates costs of monitoring equipment
TABLE 2. OTHER INFORMATION USED TO CALCULATE
MONITORING, REPORTING, AND RECORDKEEPING COSTS
Other Labor
Managerial Hours 5% of technical labor hours
Clerical Hours (, 10% of technical laborhours
\
Labor Rates
Technical $33 per hour
Managerial $49 per hour
Clerical $15 per hour
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
For each subcategory, the overall technical labor hours per
event per source (shown in Table 1) were multiplied by the number
of facilities, to obtain the total estimated technical labor
hours per year for the subcategory. The managerial and clerical
hours were then calculated using the percentages in Table 2.
Each type of labor hour was then multiplied by the appropriate
labor rate in Table 2 to obtain the annual cost for each event.
The sum of the individual event annual costs represent the total
MRR costs for the subcategory.
Several subcategories (Hypalon™, Styrene-Butadiene Latex,
Styrene-Butadiene Rubber by Emulsion, and Polybutadiene
Rubber/Styrene-Butadiene Rubber by Solution) are already subject
to the HON equipment leaks provisions. For these subcategories,
the total technical labor hours needed per event per facility
were calculated by subtracting the equipment leak technical labor
hours from the overall. For instance, the technical hours per
year per source for training would be 111 - 10 = 101.
Table 3 shows the total estimated costs for monitoring,
reporting, and recordkeeping for Polymers and Resins I. The
total MRR cost for the project is around $5.3 million per year,
which is approximately 31 percent of the total control costs.
-------
TABLE 3. ESTIMATED MONITORING,
REPORTING, AND RECORDKEEPING COSTS
MRRa Costs
Sub category 1000$/yr
Butyl Rubber $168
Halobutyl Rubber $168
Epichlorohydrin Elastomers $168
Ethylene-Propylene Rubber $838
Hypalon $88
Neoprene $503
Nitrile- Butadiene Latex $503
Nitrile- Butadiene Rubber by Emulsion $670
Styrene- Butadiene Latex $1,404
Styrene- Butadiene Rubber by Emulsion $351
Poly ~/Styrene-Butadiene Rubber by Soln $439
TOTAL P&R I MRR COSTS ($/yr) $5,299
Total Control Costs ($/yr) $16,982
%MRR to total 31%
a Monitoring, recordkeeping, and reporting
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
ATTACHMENT 1
HON SF-83 AND SUPPORTING STATEMENT
-------
I
•x
.83
rlSO)
Request for OMB Review
-T3 - fj
- -
•ant
^instructions before completing form. Do not use the same SF 83
uest bom an Executive Order 12231 review and approval under
Bjtrwork Reduction Act
Kr all Questions in Part 1. If this request is for review under E.O.
Wcomplete Part II and sign the reguUtory certification. If this
rt is for approval under the Paperwork Reduction Act and 5 CFR
:p Part II, complete Part lit and sign the paperwork certification.
Send three copies of this form, the material to be reviewed, and for
paperwork—three copies of the supporting statement, to:
Office of Information and Regulatory Affairs •
Office of Management and Budget
Attention: Docket Library. Room 3201
- Washington. DC 20503
,—Complete This Part for All Requests.
irtmenvagency ana Sunuu/orncc originating request
»ed States Environmental Protection Agency •
ce of Air and Radiation t
2. Agency coo*
ten person oma can oen answer questions regaramgnus request
_t 5. Mever, MD-13: Warren R. Johnson, MD-13
lefepnone numoer
(919 ) 541-5254/51:
c» mtorrnauon couecuon or ruierruKing ,
Krdkeaping and'Reporting for. the Hazardous Organic NESHAP (HON) for the Synthetic Organic
ical Manufacturing Industry (SOCMI) and Other Processes Subject to the Negotiated
zulation for Equipment Leaks
I
~aumorny lor mionnauon coitecuon or rule (cce United Sates Coae. Puoac i*w. artxecuuve Oraer)
2 .„„ 7412 - _ 7414
1
.use
i
ea pubbc (tnec* *tl oat apply)
inormQuatt or housenolas
0 Sine or »ocal jwvemments
3 D Farms
4 0 Businesses or other for-orcfit
S LJ Feoeral agenaes or empicyees
o U Non-profit tnstrtunons
7 E Small businesses or or^nratiorts
' II.—Complete This Part Only if the Request is for OMB Review Under Executive Order 12291
[utxmwentrfief Number (RIN) '
—— — — ~~" _ ___ ,^_ __. or. None assigned O
i
i*ot suomtuion (cnecx ooe in eacn utegoryj
mtOeMtion
* Ma,or
_J Nonmaior
1 O Proposed or draft
2 Q Finai or intenmtoai. with pner proposal
3 O Final or interim final wrthout poor prcoeaal
Typ* et rvrww rceuenetf
1 D Standard
2 O Pending
3 O Emergency
4 LJ Statutory or judicial deadline
' 0" C°nUm r*oomn8 or r*eofak««o|ri8 requiremems tnat require OMB approval unoer tne Paperwork Reoucnon Aa
U2D?
|orrute.B there a reguUtory impact analysis attached? 1 D Yes 2 D N
lo, "did OMB waive the analysis? — ...'.....'..'.. 3 H Y 4 r~^ N
fi cation for Regulatory Submissions
•pmmtngthtj reouest tor OMB review, the authorized regulatory contact and the program official certify that the requirements of LO. 12291 ano any applicable
•irectrves nave been comoiieo with.
1
4Bre ot authorized regulatory contact
1
Date
Dote
-------
HI Complete This Part Only If the Request is for Approval of a Collection
cf intprmatlon Under the Paperwork Reduction Act and S CFR 1320.
nraci—Describe neeoX MM* "« «t*ee»0 Putabc m 5O«
rotnulgated standard will require control of emissions of 110 hazardous air pollutants from
reduction of about ADO synthetic organic chemicals. Affected chemical plants would maintain
is and submit initial and sometimes semiannual or quarterly reports of emission measurements
elated information.
D Regular tubmasian
arnwUan celiectiom contained In nttm
3 tooting ?9fuMjan (no ctiinge proposed)
3 Notice of proposed rulemakmg. (NPRM)
D Final. NPRM MIS prevtousr/pubiiilMd
2 D Ew«jency»unmtt«wn(certTte»»»on*n«eo*rf>
6 FuuAermtenrn final without prior NPRM
AQ Regular submission
BO Ei»mi«ncy«UDina»ionfce/ttfie»fJon«taerteo?
7. Enter Date of expected or actual Federal
Register publication at ttus stage of rutemakir
(month. Of jr. rtarJ- Fgb . ?R .
aeef imntm requested (cnecxanlyont)
D Newcollection ,
j Revnion of A cunently spprovvj
Extension of the operation date D! a cutrtmtyapomvi collection
witftotfl >tw ctuntt in the suosttncv or in tft> tncttioo of
4 R«nsatement of a premotaty ipproveti collection for which apprwii
tttU C3CPW0
5-O Existingcolieetionin use without an OMB control number
•
*ncy report term nutnoerts) f include JIMOJ /0/topuonf/
1414.02
•uiai teaonmg or ooctauve buraen
i umber of responofnci
oat annual responses (brie J tmesSntS) . , .
nuai recorouepmg ouroen
ttrnberof recorOkeepen ..".......
Jinual hours per reconiKeeoer.
atal rfforrtMrnteing tv^fff (Im» J f*"ff binff ,
•eeordkeeoin? mention oenod
at annual buraen
t current OMB memory
Xtrerenca(linejfcutot2?
agnation ofdttitrinc*
Trent (man neent) OMB contra number or mnment i
fDnn imffioenjJUy
389
4
1.556
1341.18-
2,086,870--
389
105
40.840
5 *«an
2,127,710
-0-
2.127,710
2,127,710
-0-
ijumoer
t
22. PuTpuaeot uiloiiitauuii collection (cnecka^ mtnyisiopty)
lQ Aopliotm for benefits
2 D Program evaluation
3Q General purpose stras&cs
4 f)CJ Reguiato^f or compliance
5Q Program punning or mana|ement
6 Q Research
7Q Audit
21. Freauency ot recoreaecping or reponmg (cnecx »u ma: aspty)
1 K! ReearflKeeomg
ntfOfOftf
3 D Weekly
4 D Monthly
5 ID "Quarterly
6 3 Semiannual))/
?O Annually
BD Biennially
1 D Voluntary
Questeo ezptrauon can
aars from promulgation (or approval if later)
2O Required to oatam or retain a benefit
3 SI Manoatofv
ttherexj
MM
«ialaferoe»orinstautic«Jsoratt>epnnMrypcnxMottfiecDllea>onremrttoFeo«ralefl
ses the ajency use sanptmf to
or prescribe the uu of camping or
l anaiysa
D*
^uatory autnomy tor me imorr
40 cn> 63
,:or.
FR.
,; or. Other (specify):
- tntnrTtihnTntntfnrnMP ipprnMLTlnntrcf held. Tin
rffrr*' ~ — •"•t^*-mT rmrnmntirr mUfm tnrr tnr n ........ iirmi nf j mr 1170
uue at program ottioai
•ector.-Office of Air Oualitv Planninc and Standards
Date
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
1
I
PART A OF THE SUPPORTING STATEMENT
1. Identification of the Information Collection
(a) Title and Number of the Inforrnation Collection.
"Reporting and Recordkeeping Requirements for the Hazardous
Organic NESHAP (HON) for the Synthetic Organic Chemical
Manufacturing Industry (SOCMI) and Other Processes Subject to the
Negotiated Regulation for Equipment Leaks."
(b) Short Characterization.
Respondents are owners or operators of processes in SOCMI
industires, styrene-butadiene rubber production, polybutadiene
production, chloride production, pesticide production,
chlorinated hydrocarbon use in production of chemicals,
pharmaceutical production, and miscellaneous butadiene use. It
is estimated that about 370 existing plants will be subject to
the standards. All sources must be in compliance with the
requirements of the standard for equipment leaks within 18 months
of the effective date of that rule. in addition, new sources
must be in compliance with the standard for process vents,
storage, transfer, and wastewater emissions (Subpart G) at
startup. Existing sources are not required to comply with Subpart
G until three years after the effective date of the rule.
Generally, respondents are required by law to submit onetime
reports of start of construction, anticipated and actual start-up
dates, and physical or operational changes to existing
facilities. In addition, Subpart G requires respondents to
submit five types of reports: (1) Initial Notification, (2)
Implementation Plan, (3) Notification of Compliance Status, (4)
Periodic Reports, and (5) several event triggered reports. The
Initial Notification report identifies sources subject to the
rule and the provisions which apply to these sources. In the
Implementation Plan, an owner or operator details how the source
will comply with the provisions of Subpart'G. The Notification
of Compliance Status is submitted to provide the information
necessary to demonstrate that -compliance has been achieved. The
Periodic Reports1'provide the parameter monitoring data for the
control devices, results of any performance tests conducted
during the period, and information on instances where inspections
revealed problems. Subparts H and I require the source to submit
an initial report detailing the equipment and process units
subject to, and schedule for implementing each phase of, the
standard. Owners and operators also have to submit semiannual
reports of the monitoring results from the leak detection and
repair program in the equipment leak standard, and quarterly
reports for all points included in an emissions average. All
records are to be maintained by the source for a period of at
least 5 years.
-------
All reports are submitted to the respondent's State agency,
if it has an approved Title V permit program implementation
authority, or the appropriate Environmental Protection Agency
(EPA) Regional Office. The reports required by Subparts G, H and
I are used to determine that sources subject to the rule are in
compliance with the rule.
2. Need for and use of the Collection.
(a) Need/Authority for the collection.
Section 112 of the Clean Air Act, as amended in 1990,
requires that EPA establish standards to limit emissions of
hazardous air pollutants (HAP) from stationary sources. The
sources subject to the proposed rule can potentially emit 149 of
the 189 HAP's listed in Section 112. Section 114 of the Act
gives the EPA authority to collect data and information necessary
to enforce standards established under Section 112.
Certain records and reports are necessary to enable the
Administrator to (1) identify sources subject to the standards
and (2) ensure that the standards, which are based on "MACT",
maximum achievable control technology, are being achieved.
(b) Use/Users of the Data.
The information will be used by Agency enforcement personnel
to: (1) identify sources subject to the standards; (2) identify
the control methodology being applied; and (3) ensure that the
emission control devices are being properly operated and
maintained on a continuous basis.
In addition, records and reports are necessary to enable EPA
to identify plants that may not be in compliance with the
standards. Based on reported information, EPA can decide which
plants should be inspected and what records or processes should
be inspected at the plants. The records that plants maintain
would indicate to EPA whether plant personnel are operating and
maintaining control equipment properly.
3. The Respondents and the Information Requested.
i
(a) Respondents/SIC Codes.
Respondents are owners or operators of HAP-emitting chemical
production processes that are used to produce any of the
approximately 400 listed SOCMI chemicals. Most of the processes
are classified in the four-digit Standard Industrial
Classification (SIC) Codes 2869 for Industrial Organic Chemicals
and 2865 for Cyclic Organic Crudes and Intermediates. However,
not all processes classified in these two SIC codes would be
regulated by this proposal.
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
t
I
I
I
(b) Information Requested.
(i) Data items. Attachment 1, Source Data and
Information Requirements, summarizes the recordkeeping and
reporting requirements.
(ii) Respondent Activities. The respondent activities
required by the standards are shown in the first column of
Tables la and Ib, which are introduced in Section 6(a).
4. The Information Collected—Agency Activities, Collection
Methodology, and Information Management.
(a) Agency Activities.
A list of Agency activities is provided in Table 2,
introduced in Section 6(c).
(b) Collection Methodology and Management.
Information contained in the one-time-only reports will be
entered into the Aerometric Information Retrieval System (AIRS)
Facility Subsystem (AFS) maintained and operated by EPA's Office
of Air Quality Planning and Standards (OAQPS) . Data obtained
during periodic visits by Agency personnel from records
maintained by the respondents will be tabulated and published for
internal EPA use in compliance and enforcement programs.
(c) Small Entity Flexibility.
Minimizing the information collection burden for all sizes
of organizations is a continuing effort on EPA's part. The EPA
has reduced the recordkeeping and reporting requirements to
include only the information needed by EPA to determine
compliance with the standards.
The burden to respondents has been minimized by requiring
the collection and reporting of information which is clearly
essential to ensure that sources comply with the standards.
(d) Collection Schedule.
Collection of data will begin after promulgation of the
rule, scheduled for February 1994.
The schedule for the submission of the five types of reports
required by Subpart G, (1) Initial Notification, (2)
Implementation Plan, (3) Notification of Compliance Status, (4)
Periodic Reports, and (5) other reports, is detailed below.
-------
The Initial Notification is due 120 days after the date of
promulgation for existing sources. For new sources, it is due
180 days before commencement of construction or reconstruction,
or 90 days after promulgation of Subpart G, whichever is later.
Existing sources must submit the Implementation Plan at
different times for emission points included in averages and
emission points not included in averages. The Implementation
Plan for emission points included in the average would be due 18
months prior to the date of compliance. The Implementation Plan
for emission points not included in an emissions average would be
due 12 months prior to the date of compliance. For new sources,
Implementation Plans would be submitted with the Notification of
Compliance Status. An Implementation Plan would be required only
for sources that have not yet submitted an operating permit
application.
The Notification of Compliance Status would be submitted 150
days after the source's compliance date for both new and existing
sources.
Generally, periodic Reports would be submitted semiannually.
However, there are two exceptions. Quarterly reports must be
submitted for all points included in an emissions average. In
addition, if monitoring results show that the parameter values
for an emission point are outside the established range for more
than l percent of the operating time in a reporting period, or
the monitoring system is out of service for more than 5 percent
of the time, the regulatory authority may request that the owner
or operator submit quarterly reports for that emission point.
After 1 year, semiannual reporting can be resumed, unless the
regulatory authority requests continuation of quarterly reports.
Other reports would be submitted as required by the
provisions for each kind of emission point. The due date for
these kinds of reports is tied to the event that precipitated the
report itself. Examples of these special reports include
requests for extensions of repair, notification of scheduled
inspections for storage vessel and wastewater management units,
process changes, and startup, shutdown, and malfunctions.
Subparts H and I, the equipment leak standards, would
require the submittal of an initial report and semiannual reports
of leak detection and repair experiences and any changes to the
processes, monitoring frequency and/or initiation of a quality
improvement program. The schedule for submission of these
reports is detailed below.
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
For existing sources, the owner or operator would be
required to submit the initial report within 90 days after the
applicability date of the standard. The standard establishes a
staggered implementation scheme with 5 groups of applicability
dates. The standard would apply to the first group of processes
6 months after promulgation. Thereafter, the standard would
apply to another group every 3 months until all processes are
implementing the program. For new sources, the initial report
shall be submitted with the application for construction, as
under Subpart G.
Every 6 months after the initial report, a report must be
submitted that summarizes the monitoring results from the leak
detection and repair program and provides a notification of
initiation of monthly monitoring or implementation of a quality
improvement program, if applicable.
5. Nonduplication, Consultations/ and Other Collection
Criteria.
(a) Nonduplication.
A search of EPA's existing standards and ongoing ICR's
revealed no duplication of information-gathering efforts.
However, certain reports required by State or local agencies may
duplicate information required by the standards. In such cases,
a copy of the report submitted to the State or local agency can
be provided to the Administrator in lieu of the report required
by the standards.
(b) Consultations.
Consultations with numerous representatives of the chemical
industry, environmental organizations, and state/local air
pollution control agencies were conducted throughout the rule
development. Table 3 provides a list of some of the persons
consulted. The standard was also discussed at meetings of the
National Air Pollution Control Techniques Advisory Committee
(NAPCTAC) held in January and November of 1991. A 90-day public
comment period was provided after proposal, during which all
affected parties, were given the opportunity to comment on the
proposed rule, 'in addition, a 30-day public comment period was
provided after supplemental notice on the proposed General
Provisions impacts on the HON, and certain Emissions Averaging
policy considerations. All received comments were considered and
some reflected in the development of the final rule.
-------
(c) Effects of "Less Frequent Collection.
If the relevant information were collected less frequently,
the EPA would not be reasonably assured that a source is in
compliance with the standards. In addition, EPA's.authority to
take administrative action would be significantly reduced;
Section 113 (d) of the CAA limits the assessment of administrative
penalties to violations which occur no more than 12 months before
initiation of the administrative proceeding. Since
administrative proceedings are less costly and require use of
fewer resources than judicial proceedings, both EPA and the
regulated community benefit from preservation of EPA's
administrative powers.
(d) General Guidelines.
Except for some equipment leaks provisions (Subparts H and
I) which only require 2-year retention, this rule requires that
facility owners or operators retain records for a period of
5 years, which exceeds the 3-year retention period contained in
the guidelines in 5 CFR 1320.6. The 5-year records retention
period is consistent with the provisions of the soon-to-be final
General Provisions of 40 CFR Part 63, and with the 5-year records
retention requirement in the operating permit program under
Title V of the clean Air Act.
(e) Confidentiality and Sensitive Questions.
(i) Confidentiality. Information obtained by EPA is
safeguarded according to the Agency policies set forth in
Title 40, Chapter 1, Part 2, Subpart B, Confidentiality of
Business Information. See 40 CFR 2; 41 FR 36902, September
1, 1976; amended by 43 FR 3999, September 8, 1978; 43 FR
42251, September 28, 1978; 44 FR 17674, March 23, 1979.
Even where the Agency has determined that information
received from a "person" in response to an Information
Collection Request (ICR) is eligible for confidential
treatment under 40 CFR Part 2, Subpart B, the Agency may
nonetheless disclose the information if it is "relevant in
any proceeding" under the statute [42 U.S.C. Section 7414
(C) ; 40 CFR^2.301 (g)]. The information collection complies
with the Privacy Act of 1974 and Office of Management and
Budget (OMB) Circular 108.
(ii) Sensitive Questions. Information to be reported
consists of emission data .and other information that are not
of a sensitive nature. No sensitive personal or proprietary
data are being collected,.
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
6. Estimating Burden and Cost of the Collection.
(a) Estimating Respondent Burden.
The existing source annual burden estimates for reporting
and recordkeeping are presented in Table la. The new source
annual burden estimates for reporting and recordkeeping are
presented in Table ib. These estimates are shown separately
since the technical hours for new sources must include compliance
at startup and periodic records burdens in addition to pre-
compliance requirements. Generally, with the exceptions of new
sources and some equipment leaks provisions, periodic reports and
recordkeeping requirements begin after the compliance date, which
is three years from promulgation.
In addition 'to Tables la and Ib, an extract of the equipment
leaks standards (Subparts H and I) contribution to the overall
existing source annual burden estimates for reporting and
recordkeeping is presented in Table 4. This is to highlight the
burden which can be directly attributed to the equipment leaks
standards (Subparts H and I) during the first three years after
promulgation. The equipment leaks standards were developed
through regulatory negotiation.
Information collection requirements include one-time-only
reports and periodic reports. The burden estimates for the one-
time only reports are treated/considered as average annual
burdens by dividing the cumulative three year total technical
hour estimate by three before including it in column (c),
"technical hours per year per source."
The estimates of total technical-hours per year per source
and the number of activities per respondent per year listed in
each table are based upon experience with similar information
collection requirements in SOCMI NSPS and the number of emission
points in each source.
(b) Estimating Respondent Costs.
The information collection activities for the first three
years for sources subject to the standards are presented in
Tables la and Ib. To stay consistent with the control cost
estimates, labor rates and associated costs are based on the 1989
Comprehensive Assessment and Information Rule (CAIR) economic
analysis, and estimated hourly rates are as follows: Technical
at $33, management at $49, and clerical at $15. The total burden
costs may be converted to 1992 CAIR rates by multiply the
technical hours by $49.0/hour (this includes assumed managerial
and clerical cost considerations). However, any conversions to
1992 CAIR rates should not be used to compare with control costs,
which are estimated in 1989 dollars.
-------
It is important to note that an average was taken of costs
covering a period of three years for reporting and recordkeeping
to a typical source. Therefore, total recurrent annual burden
hours would be as indicated in Table la for existing sources and
Table ib for new sources.
(c) Estimating Aaencv Burden and Cost.
Because the information collection requirements were
developed as an incidental part of standards development, no
costs can be attributed to the development of the information
collection requirements.
Because reporting and recordkeeping requirements on the part
or the respondents are required under Section 112 of the Clean
Air Act, no operational costs will be incurred by the Federal
Government. Publication and distribution of the information are
part of the AFS operated and maintained by OAQPS, with the result
that no Federal costs can be directly attributed to the ICR.
Examination of records to be maintained by the respondents
will occur incidentally as part of the periodic inspection of
sources that is part of EPA's overall compliance and enforcement
program and, therefore, is not attributable to the ICR. The only
costs that the Federal Government will incur are user costs
associated with the analysis of the reported information, as
presented in Table 2. Labor rates and associated costs are based
on the CAIR economic analysis, and estimated hourly rates are as
follows: technical at $33, management at $49, and clerical at
v .L^ •
(d) Bottom Line Burden Hours and Costs/Master Tables.
. . (il The simple collection. The bottom line respondent
burden hours and costs, presented in Tables la and ibT are
fa:C?1!£ed b? addin9 person-hours per year down each column
S«f, t;^hnica1' managerial, and clerical staff, and by adding
down the cost column. The estimated total nationwide burden
iour^n St 3 ?SarS °f the rUle is an estimated 2,127,710
185 o™ ^^ I1'850'180 technical, 92,510 managerial and
dollars rhOUrS) ^ * ^ °f 68'364*37 th°USand
8
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
(xi) The Aaencv Tally. The bottom line Agency burden
hours and costs, presented in Table 2, are calculated as in
the respondent table, by adding person-hours per year down
each column for technical, managerial, and clerical staff
and by adding down the cost column. In this case, the total
cost is the sum of the total salary cost and the total
travel expenses for tests attended. The estimated total
hours and costs in the first 3 years of the rule are 23 188
hours per year (20,162 technical, 1,009 managerial, and
e clerical hours) at a cost of 760.37 thousand dollars
, The complex collect inn. This section does not
apply since this is a simple collection.
(e) Reasons for Change in Burden.
This section does not apply because this is a new
collection.
-------
c
CO
D)
_c
"*J
k_
o
a
CD
DC
*£ w
O c
~ O
§:»
gg
T3 -1-
5 «
CD £
-o «
O 0
Q. c
w C
Q) 05
CO CT
3 • —
c ^55
c f Q.
< Si
**H %B
** ~
(!) — Q)
% 5 °- -
E •= E S "5
•E £ 3 >• ~
w U o
UL) X
^n in ^
*"^ ** «
d> •— 0)
•r o) Q- w
P S5 52 S =*
•S C 3 >•
in re o
tu ^ X
*D "• ^
• ID rt^
Q» *W QJ
* .y a- w
2 C « » -rr
E -c ^ v —
•^ t> — ^
«0 OJ O
u3 t- X
-ri S c S
^ ^3 .= o
5 i .2? 3 S
UJ 3 x O
2 uj c/>
ro cu »-
0)
•s o. o
£ « w fc 13
-t ^ •; 3 -w_
CJ 3 JJJ O
CD o o> 55
»- x >•
^
_T Q)
O Q. w
i_ to * 09
co o> Q. JJ —
•0 - •- 3 -0
i l ! s ~
2^
0) >.
en M C
ro ^ i_ -5
5> o S. - —
> X u
< <
0)
0)
•o
3
m
CN
CO
en
CO
CM
eg*
CO
en
»—
CO*
CO
en
q
CO
r^
in
en
r—
CD
f>.
CO
r>»
CD
^~
r^
•^-
CD
CO
•o
1| Read Rule an
Instructions
ID
in
co
CO
r>-
co"
O
'a-
CM
O*
O
CM
«—
in
CD
en
co
CM*
0
1—
p».
CO
CD
r^
CM
r^
TJ-
en
in
m
2) Plan Activitie
CO
CD
,_'
CN
ID
,_T
CO
^_
»—
Tf*
en
in
q
CM*
^
CO
»-__
^
t
r>«
ro
^.
i—
^—
en
*~
CO
in
O)
'c
'ro
^
(-
ro
0
V
r»
ID
CN
•d*
CO
CO
^_
1^-
CN"
en
CD
in
CO
CD*
Tt
en
CM
«-^
fN."
CM
en
p^
co
en
en
rf
•
CM
O
TJ-
*~
en
r».
^-
4| Create, Test,
Research &
Development
en
ID
ID
CO
^v
r>*
ID
r^
CO
CO*
^~
CO
CO
^
CO*
CN
o
in
r^
ro"
CO
^~
r««
CO
O
ID
CM
i»
O
0
m
in
CM
5} Gather Info..
Monitor/Inspect
r^
*—
Tf
r*.
CM
CM
•V
r*
^
r*.
CO
O
CM
^
r^
r*.
CO
O
CM
^
q
d
CM
I Process/Compi
& Review
CD
f»
en
en
CD
O
CN
CM
O
CD
ID*
^
o
CO
CN*
^
CM
O
CD*
in
r^
CO
^
in
t—
CM
in
ID
r^
w
"a
co
c:
0)
a
c
0
u
f~T
en
r-.
en
p»
*r
en
en
CM
^
en
rj-
CO
in
CO
en
0*
^v
r->
CO
&
CO
CM
in
r-»
a
) Record/Disclos
CO
Tf
^
d
r^
co
CM
O
q
,_"
_
o
in
r>.
i—
0
O*
r^
CO
r^
CM
^t
CO
CD
9) Store/File
CD
in
_.'
CO
CM
CD
f>.
CO
CN
CO
CO
^
CO
Tj-
•<3*
CO
CO
in
CO
eg
CO
(O
*~
H-
U5
0
CJ
2
-o
CD
in
o
in
to
n>
CM
+rf
0}
I
u
ro
«•<
re
v
a>
c/5
-------
c
CO
D)
o
Q.
CD
DC CO
H- C
O _O
•*- "w
II
03 -1-
~O 0)
CD M_
*- O
•O C
C Q)
0 E
a. §
s|
a
0) 0)
g «
3 -O
O £
C/D g
z
.d
.a
CD
I-
rr w
"> -D
o c !s
0 re g
_ ,- V) ?
w .£ 3 ^ -=
i j= 8.
< S
"° is
p!*-
i*1 **
uu X
"D ^3 te
Q, ~ 0
« » "• *•
2 cn in 10 —
! S § 5L-
5|5
I 3 |w
1 1 8 8 S
•5 W = >•
w «> °
uj 1- X
•0 g 2 S
P JZ 0>
~ * Q. 0 _
JC £ •- 3 "
« = S o —
0) 0 » M
1- X >•
«_ £
0 0. w
w M 0) O
w w Q. o _
-° .tr ± 3 £,
ljl«
Q> >.
O) W *^
iiii»
i1 <
Burden Item
00
CM
CD
CD
O
in
^~
in
CM
OJ
8
in
*
<»
CO
O
-in
OJ
•<*
cn
fx
CM
1) Read Rule and
Instructions
^
CD
CO
OJ
cn
CO
CD
o
OJ
CO
o
0)
CO
CD
CO
in
in
CO
Tt
0)
00
CO
2) Plan Activities
00
t^i
CD
CO
CO
CM
cn
CD
r*
CO
w
CM
CO
CM
CO
CO
CO
in
CO
O)
|c
re
£
m
o
CO
r^
CO
00
CM
cn
r»
CD
fx
cn
CO
CD
CO
00
CO
f">
CD
r^
00
CD
CD
CM
^
O
00
r->
^t
CM
4) Create, Test,
Research &
Development
0
v
r^
in
cn
»-
" tx
cn
CM
in
cn
rf
CD
CM
^
fx
cn
CM
in
CO
CO
5fr
CO
CM"
r>.
rt
O
CM
tr
5) Gather Info.,
Monitor/Inspect
o
CD
CD
CM
CM
fx.
CO
CO
o
CM
r^
CO
O
tf
00
o
v>
v>
re
J5
CM
+*
CD
U
re
«*
re
CD
o>
W
-------
1
1
• Table 2. Annual Burden and Cost for the Federal Government
1
•
1
1
1
1
1
1
1
1
1
1
1
1
Burden Item
Average
Hours
per
Activity
(a)
Number of
Activities per
year
(b)
Estimated
Technical
Hours per
year
eei imnrinnc =r,H 4,irrhor Hecr-rinri^r, nf or-»i.,iTiQr.
I
I
-------
Table 3. Persons Consulted on the Reporting and Recordkeeping
Requirements in the Rule Development
David Driessen Natural Resources
Defense Council (202) 783-7800
Larry Goodheart Chevron Corp. (510)242-4145
David Gustafson DOW Chemical USA (517) 636-2953
Joe Hovious • Union Carbide (203)794-5183
All Khan Indiana Air Pollution
Control (219) 391-8297
Karen Olsen Texas Air Pollution
Control Board (512) 451-5711
Gus Von Bodungen Louisiana Department of
Environmental Quality (504) 394-5374
-------
03
C
O
CO C
«
o r
Q. CD
0) Q.
DC .Q
M- ^
o c/)
4-J
w w
0 5
U .2
c'5
CD O
c Q_
m _3
||
o a
li
03
2
O
O
C/D
c
0)
UJ
O"
£
. DC
^ D3
03 .£
CO
f-
0)
j*:
•D
L.
O
o
0)
oc
8 Is
- c 5 |-
co i 3 *" —
3 o «K —
c x: «
< «>
^ fc,
S3h-
.§ § § | -2?
w O 0
uJ X
•o "5 <-
0) -= CD
m °> a «-
JS o> in co —
I 8 5 SL-
iSix1
Is lw
P f £ S •»
•Bo 3 >. —
tS a> o
UJ K X
Til "S
S | » 3 2
UJ .2 X O
*_ UJ 00
CD a) ^>
u c. »> ®
C » °- g -
£ " «- 3 U
w 3 ? o ~
S 0 » M
1- X >•
^
«_ 0)
0 C3. _
w in co eo
Qj CD Q. CJ
J3 -~ >- ±. JZ
> S o
3 - S. W
2^
0) >.
0) M —
*° ^ w "^ — -
k. 3 m > T^T1
cu o Q. - —
> T O
TJ-
CO
CM
CM
CM
in
•
in
CO
v
^>
rx
n
CO
»«•
,_
f^
CO
•fl-
^~
q
I Process/Compile
& Review
(O
CO
in
CO
r»
*«"
CO
CO
CD
•
^t
cn
CO
CM"
in
fs.
CO
CD
T
._
CO
in
CM
O
o
in
»—
d
w
"a
03
c:
03
CO
a
o
u
r~»
r~
TJ-
CM
CM
Tj-
rx
CO
O
CM
•*
r^
^_
CO
o
CM
<»
q
in
I RecordyDisclose |
CO
CO
tx
CO
r*.
CO
cn
rx
CO
^_
CO
-
t
CO
d
9) Store/File |
CO
CO
o
CO
cn
CM
CO
CO
O
CO
0
q
d*
0
CO
CO
*
0
CO
(-
W
O
O
r-»
OTAL BURDEN AM
(-
CD
JU
J2
co
C
0)
0)
O
O
M
o>
x ~
01 U
_ (0
ro •£
If
c S
— 0>
C "O
O i-
•S a>
c
° p
03 C
CU 3
c 18
>- a:
£ o
_ro ••-
D CM
C35 ^
£ H
0)
V U
—~ CO
a>
CO
.| CO
o-
V
0)
«rt
0)
to
M
u
TJ
b.
J3
0)
CO
CD
-------
I
I
I
I
I
Attachment 1
SOURCE DATA AND INFORMATION REQUIREMENTS
Information Requirements
Citation
I
I
I
I
I
I
I
I
NOTIFICATION
Notification of construction or reconstruction
• " Notification of anticipated date of initial startup
Notification of actual date of initial startup
Notification of modification
REPORTING - INITIAL
Initial report requirements
Reporting of operating parameter levels
Statement of compliance or noncompliance
REPORTING - SEMIANNUAL £ QUARTERLY
Exceedances of parameter boundaries established during
the most recent performance test
Any change in equipment or process operation that
increases emission levels above requirements of the
standard
Written report of performance tests
RECORDKEEPING
Record of data measured during each performance test
I
I
I
I
Record of periods of operation during which the
performance boundaries esdtablished during the most
recent performance tests are exceeded
Records of Monthly visual inspections
Records of Annual visual inspections
63.151, 63.182
63.151, 63.182
63.151, 63.182
63.118, 63.122, 63.130,
63.146, 63.151, 63.152,
63.182
63.117, 63.122, 63.129,
63.146, 63.151, 63.182
63.118, 63.122, 63.129,
63.146, 63.151, 63.182
63.151, 63.152, 63.182
63.105, 63.118, 63.122,
63.130, 63.146, 63.148,
63.151, 63.152, 63.182
63.118, 63.122, 63.130,
63.146, 63.151, 63.152,
63.182
63.117, 63.122, 63.129,
63.146, 63.151, 63.152,
63.182
63.117, 63.118, 63.123,
63.129, 63.130, 63.147,
63.148, 63.151, 63.152,
63.181
63.118, 63.123, 63.130,
63.147, 63.148, 63.J.51,
63.152
63.118, 63.147, 63.147,
63.181
63.123, 63.147, 63.148,
63.181
-------
Attachment 2
Assumptions and Item Descriptions for Tables 1a, 1b and 4
Assumptions are:
(A) that there are 371 existing sources with a 5% increase (new sources) in the first three
years after promulgation. The 5% increase (new sources) is expected to be new expansion at
existing facilities, as opposed to new facilities altogether, but given to possibility that this growth
could all occur as new facilities, this table assumes the startup of 18 new facility startups in the
first three years. Since new facilities must be in compliance at startup, the general periodic
recordkeeping and reporting burdens are included, which accounts for the difference in the
technical hours per source.
(B) that the average representative source, new and existing, will consist of the following
points of burden:
20 parameters to monitor at control devices throughout the facility
10 affected storage tanks of various capacities
3 affected major wastewater streams
4 affected transfer rack operations
1 overall leak detection and repair program for 2,000 points
1 emissions averaging program that involves 10 emission points
1 facility wide inventory of emission points. Group 1 and Group 2
(C) that there are 5% (.05) managerial and 10% (.10) clerical hours required for every
technical hour.
(D) that some activities necessary to generate reports involve creating records in the
process, and that these activities are assumed to be reports activities alone, to avoid double
counting these as records activities as well. Therefore, only items 8 and 9 are considered records
burdens directly.
Item Descriptions:
(a) Average Hours per Activity is back calculated by dividing (b) into (c). Since the
activities within each burden category can vary significantly, it is too inaccurate to assume an
average to use to calculate (c). Estimated activity technical hours are summarized to obtain (c)
first, then back calculate for (a) with an estimated (b).
(b) Estimated Number of Activities per year per source represents the assumed typical
number of separate activities a source may encounter during one year. This number may vary
from facility to facility depending on consolidation of activities, collocated readings, etc. Since so
much variability exists, it important to note that this is our best guess at an average facility
experience. This number was only used to back calculate (a).
(c) Technical Hours per year per source is the actual best estimate of the burden for each
burden item. The three year separate activity burdens were divided by three, where appropriate,
and then summarized to include in this column. The technical hours for new sources is higher
because some periodic compliance reports and records are required at startup. Existing sources
do not encounter these reports and record burdens for three years after promulgation.
(d) Estimated Number of Existing and New Sources reflect the number given in
assumption (A), above.
(e) Estimated Technical Hours per year is the product of (c) and (d).
(fj Estimated Managerial Hours per year is 5% of (e).
(g) Estimated Clerical Hours per year is 10% of (e).
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Attachment 2 (continued)
Assumptions and Item Descriptions for Tables 1a and 2b
(h) Estimated Annual COST in sThousands per year is the total cost of technical,
managerial and clerical hours and overhead using 1989 CAIR rates using this formula:
(H* x $33/hour» + (Hm x $49/hour) + (Hc x $15/hourl -= (h)
1,000
Where:
H1 is (el, or technical hours
Hm is (f), or managerial hours, and
Hc is (g), clerical hours
1} Read Rule and Instructions are the activities, less training, which involve
comprehending the provisions in the standard and understanding how they apply to the
respective points at a facility.
2) Plan Activities represents such burdens as design, redesign, scheduling as well as
drafting the implementation plan, and selecting methods of compliance.
3) Training represents the portion (assumed 40%) of activities from 1) Read Rule and
instruction which an average facility would elect to provide class room instruction for. The
standard does not require specific training itself.
4) Create. Test, Research & Development are the activities involving testing, retesting,
establishing operating range for parameters and analyzing point by point applicability. Monitor
related refit, calibration and maintenance activities are also included under this heading.
5) Gather Information. Monitor and Inspect are the activities involving physical inspections
of equipment, collection of monitored data and other related activities.
6) Process/Compile & Review are the activities that involve analysis of the information
collected for accuracy, compliance and appropriate reports and records required as a result.
7) Complete Reports represents the activities normally associated with filling out forms.
Since the standard requires no standard forms, these activities relate to the preparing of formal
reports and cover letters as appropriate.
8) Record/Disclose are activities which are solely recordkeeping which occur once the
appropriate report information has been extracted (see assumption (D)) above. These activities
involve software translation, duplication or archival processes normally associated with data
management and storage common to this industry.
9) Store/File are again activities which are solely recordkeeping which occur once the
appropriate report information has been extracted (see assumption (D) above). These activities
involve the management life cycle of records, from the time they are filed and boxed up, to the
time they are disposed.
\
TOTAL BURDEN AND COST is the sum of each of the columns (ej, (f), (g) and (h).
-------
Attachment 3
Assumptions and Item Descriptions for Table 2
Assumptions are the same as attachment 2, and:
(A) that EPA personnel would attend 10% of the performance tests. Performance tests
are required only for new sources in the first 3 years after promulgation. If the 18 new source
equivalents are considered to have 20 parameters each from 8 control devices (2.5 parameters
per control), this would mean the equivalent of 144 tests (8 x 18), approximately. Its important
to note, however, that EPA attendance is dependent upon EPA available resources, and not the
number of tests.
(B) that 20% of the initial tests must be repeated due to failure of initial test.
(C) that all existing and new sources must submit an initial report within 120 of
promulgation and an implementation plan or permit application within 12 or 18 months of the
compliance date. There are about 370 plant sites. The new sources are most likely to be
collocated within existing plants and be included in those existing source reports.
ID) that semiannual reports of results from equipment leak detection and repair program
are required by the equipment leak standard. Sources are required to comply with the equipment
leak standard by 6 months after promulgation.
(E) that travel expenses equal:
(2 people/trip)(17 trips)($400 travel/trip + $50 per diem/trip)
Item Descriptions:
(a) Average Hours per Activity are estimates of the specific activities and are the basis for
estimating the overall burden (unlike tables la, Ib and 4).
(b) Number of Activities per year represents the number of reports expected to be
reviewed and other related activities during the course of the year. Under the performance test
headings, these numbers are based upon assumptions (A) and (B), above. For one time reports,
the total number of reports expected over the three year period was divided by three to get an
annual average incorporating assumption (C), above.
(c) Estimated Technical Hours per year is the product of (a) and (b).
(d) Estimated Managerial Hours per year is 5% of (c).
(e) Estimated Clerical Hours per year is 10% of (c).
(f) Estimated Annual Cost in ^Thousands per year is the total cost of technical,
managerial and clerical hours and overhead using 1989 CAIR rates using this formula:
(HT x $33/hour) + (Hm x $49/hour)-MHC x $15/hour) = (h)
1.000
Where: '
H* is (e), or technical hours
Hm is (f), or managerial hours, and
Hc is (g), clerical hours
PERFORMANCE TESTS:
1) Initial represents the activities during EPA attendance at an initial performance test.
2) Repeat represents the same activities as 1) Initial, except for a repeat performance test.
LITIGATION: Represents the cost of litigating an average of three case per year.
-------
Attachment 3 (continued)
Assumptions and Item Descriptions for Table 2
REPORTS REVIEW:
1) Initial represents the EPA review of all initial reports received.
2) Implementation Plan or Permit Applications represents the EPA review of all
implementation plans, or permit applications if submitted in lieu of an implementation plan.
3) Compliance Status represents compliance status verification by the EPA for the
portions of the standard which a source must comply with before the compliance date (see
assumption (D) above).
4) Review equipment leak monitoring represents the review and screening of periodic
reports received as a result of the equipment leaks standard.
5) Notification of construction/reconstruction represents the EPA review of this
notification from new sources.
6) Notification of anticipated startup represents the EPA review of this notification from
new sources.
?) Notification of actual startup represents the EPA review of this notification from new
sources.
8) Notification of performance test represents the EPA review of this notification from
new sources.
9) Review of test results represents the EPA review of performance test results for new
sources.
10) Review periodic reports represents the EPA review of periodic reports for new
sources, only. Generally, periodic reports are not required from existing sources until after the
compliance date, which is 3 years after promulgation, except for equipment leaks which is
included under 4), above.
TOTAL BURDEN AND COST is the sum of each of the columns (e), (f), (g) and |h).
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
ATTACHMENT 6
DETAILED COST INFORMATION
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
re
M
o
o
u.
o
i
CO
u
U
u
a.
to
CO
t- in co CM o co
r^ co co co
« in co o>
a
S
10
C
O>
m v olw
co m to o
-• CO
Sco n •*!»
,v 153 § 5
co o
— CO
CM O» CO Iv CO O
rv o co «- N »-
o*
CO
o>
CM"
CM CM K O CD
SCO |v O> CM
CO » Iv t
"«*«»«» «»
CM «r co co i-|«-
co <- r~ o> o co
CM n n o> r-1 v-f
** i-" CM CO" CMIO
» » l» l»|t-
CO
CM"
«- *- CO ^
CO O CMJ»-
m o" coin*
o in CM »
r- M M CM
o r- t- o
•- T- « t
MM *»
v- «0 O|»
« n n co
co rv o CMICO
co rv o m T-
co co in ml *-
o" rv" co" oflV
CM iv to in •»
|» O
lin o
co in
858
•» CO O IV
co o t> a
m CO <*|CO
MM M
n iv eo CM *-
•» o co T- »
as in ^ »- m
a» «- ~n in co
**•»•»•»«>
in ^ CD o oa
co o olm
»- o o o
CM CM pi in
in a> CM I CM
«M »- U> N
..
rv co CM co I »-
T- «o M- co U-
M M M M CM
CO CD co CM
in T- »- CM T-
in cv T-ICO
co co o *•
^ at cojo
««• rv
co" o" . .
» .- » I
r- <• <
co IS
MCO
rv co
M CM
M M
CO O COl CM
m o co a
<- T- <• CM
o co rv co
CO CO «- CO
co ^ rvlin
T-' n" col in
CO O r- O
CO CM M CO
MM M
CM
»
CM
o
S
rv
e"
§
a
r-
CM"
CM
in tv a> r-ir-
fv in OICM
CM o co -
o co in a>
•4- CM rvim
co «- olco
y- CO CMJOI
rv" co" cil co"
•* (M «- CO
M M M W
in CM o col in
-sssls
CM » ^- _.
n o co rv
in o co
58«
M M M
CM CO CO CMICO
CM •«• CO Oli
SO) 0»|CM
o » rv
co_ in «J in
8" CM" co|oT
rv »- L-
»- M Ml CM
O v- CO I CO
Sco CM rv
_°. •d*
rv rv OH co
7- Iv CM CM
»- M M CM
o <- cola
CO CM COlcO
T- CO CMlcM
8555
MM M
^. to co co o
CM CM CM i- O)
-------
ft:
{2
(0
O
O
u.
O
B
s
3
co
u
i
1
IL
O O co O *~ I** eo —
> co m in CM o m co
_ _ B
«» «t €**»<* «»«»«»«ft
a> o f cole
* «• *- ^-Ico
CM •» col o
co" n in 1 co*
c»or-.
CM o »•
incooco co *- CMO
CM O CO
co 101 r-
- «»v>in T- CM
W W T- <* W«»CM<»<-CM W » «i O
•» W » V» •
CM CM ID •«••«•
*- ^
f. O T- «M CO
*r m a n »-
r- •» « h. a.
O CO T- h-
CM T- CO »
CO^ CM d> CO_
^ ** r^ ^" i-|O
•» *» *» *»!•»
CO I
CM O O
ecMcooancMCMT-
OtCMIf>a»CMf«COCOCMh»CMnO>COO|u>
4»ncoT-«»<»«»h-cM«a>«»n«» « o
•»*»•> •>«>«*>» 4» W
O O >-
> «* o »r
«- o"
^ CM
r- eo
» co co in
SR83
.
CM" V o" ** CM" CM co" €»«» •»»«»«» •»«
* a> co o o
CO O O W CM
01 a a r-
" " " " "
concoeoootococococNJojcoo otto
cM^anocMinOk^ioooicor- coin
*- a o
in T-
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1 I
^m o
u
IL
10
1
a
s
13
1
^
0.
1 I
0
1
'A
«B
o"
CM
«ft
Cft
«
O»
V
*»•
in
M
s
^
1 iC
n
o
&
<
a
a> $
cc i
•D ^
C 2-T
CM 5S
1
r- at
CM CM
CM m
e" co"
5
O>
~- in
; 3
in" o"
o> r-
r- co
«» »-"
«•
s s
o *
? 8
co" in"
<£> CM
« CM
4*
i &
i- in
CO f
r- •»
1A '
«»
CO O
" *
co in"
CO 01
5 2
CO r-
^ ^
•*• O
co" CM"
«9 T-
vt
m «
n i--
in »
co" co"
in o
in i-
«* »-"
«
T- *
O CM
CO CM
T-" O>~
t s
4» *»
O)
5
n
I
•R
ST
^5
CO ^J
-------
O
U
u.
o
2
S
M
O
LL!
U
ill
a.
n
I
fe|
||
*• i~*>
^^
f— tft
* ^r
tt«
Annual
asw/MRR
Indrect
8
\-S
*
"8
Q "fe
rrift
5* W
8-
o
Is
!a-~.
IT
2?
'8
u.
i
i
a
p* *- f
iv e» »•
*- ao ok
CM" in" CM"
•»•»«*
§rv m o o
^ in o o
r- rv a> o
JJJD
CO ^ Iv
S R 8
ID" in CM
i- r- oo
co_ co »-.
^ ** CM
44 M
»- O >-
»- 4» •-
01 00
CM" CM*
»- *• in
ao rv o
o eo in
co" »-" in"
CO ID ^
^ ^ cO
CO O *
in" co" of
CO i- »
^- r^ co
*-" ** T-"
« V)
iv rv ^
CO CO Iv
CM CM «»
CM" rv" o>"
»- o »-
ICo CM in
•><»«»
CM eo o
CM ID 0>
cf co" co"
<» CM ID
T- T- CM
in a> •v
gss
ID* V *-
to * i-
co in ^
» » rj>
M
eo co ^
^ v-~ N." O)
0) W 5f
SCO O
*> »."
I llpll
1 5"^
CM
*»
----- T- CM
CM" in" t»."
CM O> i-
CO h« r-_
4^ 4fr ^
*»
^- O T-
5_ S_
CM" CM"
«* «*
v O CM
£55
co" Co" Iv"
O ID CM
T- <» CM
r- *- CM
CO CO v-
eo "
CM K O>
co --- *
Slhs
1*^ <
i
r- Ot CO
CM CM CO
ao in o
CM" eo* co"
*»•»«•
§CM «D CO O O
ao ao eo o o
CM^ co T- in T- m
o" ID" o" n" co"
ao in »
£33
»-" 0* CM
Iv |v •«•
ID 03 CO
eo* <-* o"
»- » CM
»- O »-
CO «• CO
^ ^r
CO CO
ID ^ *-
eo co rv
*- CO *
o" in" in"
28?
o>~ ** oo"
•9 -^
o>~ *-" o"
o o o
CO ^f N
in" in" 1-*
CM O> CM
>» CO CO
•»"*» »
f- T- CM
tv T- aa
co o n_
in" CM N"
T- IV CO
O T- l-_
M 44
a> ^ co
CM rv o
T-" co" in"
tO O ID
CM *- CO
rv" ,-" «o"
00 T CO
T- CM *f
eo. CM_ o.
O) CM CM
o in o
I HrJ
l=2g
-------
1
1
1
1
1
1
1
1
• J
EC •§
IJJ Q
I *
' i
l |is
» n
*? u?
I f~
• . u
• 8
U
,. IL
• > £3
• 5
a
a
IM 2
S 2
• U-
o •>
u >•
Is 1
* 1
3 2
0 (0
1
£ N ° N °. * «*.
CM *-
<» *»
So a» o o Die? in
*» 0 *» «» >- CM »-
in »- *» o n CM
co in «_ co^
«» 4*
SnlcM at
v-i at oo
CM -r
* »- oj*^ ^1
co" col co" co"
CM *- n *•
« *>!*» *»
O) £J O) O>
frte » c J
an. s m .= J
* £2 E * -^
= 1 ta " ! S
*— »- -fi T^V^T"? ^ ^ J
" !i f &S&66 s^ j
1
NO C OK »•
co o a; *» a: T-'
g UJ UJ
o o op
o t» •» 5
at" CM"
T- <•
! 8 s !
4*
¥ S S
O CO
in" i-"
K
ID O O
K «» »
O O
o" «
; s
*»
o> 01 ]| ai fe
5 2 $ 2
J c ID CD
i *j" 5 T •! T ^V *? iTT
!i xx zzzz izzz
^ 0 0 1C
"S £
M
g S S SIS
M*
«t
h- o o olo
at «» •» *»!•»
•»
m o
S *
^
«»
So
«»
C9
<*
75 Ol 75 C
l§ f
S £
Q Q
ff ^J
w o w
*? T b.T T *?
II jgjjg
-------
W
O
U
5
«1
U
I
0.
it
%
0
0
8
OOOOOO OOOOOOOO O|O
»*»V>V>MV»V»V»V>V>V>V>V>W «»!•»
So o o olo
*»«»«» wt*
SO O O OIO
<• 4* 4» «!*»
n
CO*
CO
8
S
I
[1
ta
1-5
^ 5«5
h g Jg
f i|s
1 ss>
w
O *- CM TO T (f)
CM CO T 1O
- ? I. I. I. I. I. I. I. I. I. I. I. I. I. I. I.
» CO CO tt> CO O> CO CO CO CO CO CO CO CO CD CO CO COCOCOCO CO C0<
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1 6
w o
u
II
1 *
• 1
s
IS
g
o
u
_ 0.
• o
• 1
• t
3
u
1
fcS
!*!£
f \ *^
££
*
a s^
S 2
0 «
5^
fl
/?
—
g ts
il
^s
2t
I
>
s
0)
OS
«S
ff
CO
o
o
4»
O
w
o
<*
o
*»
en O)
fi 1 1
b
a 5
0) IK 3
fH 8 ff
DC -fi
3 "*
^^ ff n
w 5v
c 15 Is
CM 3$ 5S
1
-------
e
CO
0
u
IL
o
ce
X
s
a
CO
FACIUTY-SPECIFIC
|i
85
*0>
a!X ^
(T
i
*—» tt
fcr m
fl
1
||
£8
£
Subcategory / Factl
oooococ CM o CM o a:
oc cc • «> o cc
HJ UJ ^ UJ
o o o o> o o»
^ W *» O 4A O
o a
So o in o in
*» •» ^ <* •*
o o
in in
o o o o o o
o o o in o in
1 ID (D
o" o"
*» Vt
|
I g"^ <1|"^ *!_
0 5 1 I
OS £ I
o o o o oc
h- r** o c
8«
o o e
in" in
n o
«» «»
a> o o>
CM « CM
(D* W
O O O
o» o a»
CM « CM
CO CO*
CM CM
1st Rag Alt
2nd Rag Alt
Total
AvgCE
Incremental CE
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
p
m
o
u
u.
O
S
3
a.
CD
(i
f\ ^^
£s
3 rS S
S £*
1 ~S
1 |{
o
Is
C w
5o
— ^-.
£i<6
^^
If
O ^t
£s
- «
V o?
~ fl*
2 i
9
Si *<
5 «S-H
t ffl£
O
—
§s
5b
£®
2
S
1
a
cc a
oc r;
QJ O*
8 CM O O O O
co *»*»«» v>
isT
0
O CM O O O O
44 CO V» «» *» *9
o"
s
CM
«
S
CO
CM"
CO
S
CM
0
o
m
s
*- o o in
CM *-
S
in o « *» *»
TT to to
CM CO V>
I "2
."
n
»
CM O O O O O OIO O O O OIO O O OIO
co «*«•<* «• <* «*)•» *»«»*»*»|»» <• «• M|M
o"
S
CM O O O
CO C# ^ C#
co_
s
5 S J
o
» «•
SS £ S§ £ °£ °g SS SS
« S » Si UJ JJj ^ CM e»
CM T-
c\
o o co o o o 010 o o o 010 n co olco
O «• CM «» V> «* M «* «•<*<*<»«* r- O> 4* T-
a> co
Cft CM
CO «
CM «»
CO W •»
r»" »" co"
Es u
o o >- o o o olo o o o 010 in r- OICM
!-- *» O «* IA *» «•!«» «»«*«» «l<* O — «*|CM
i^ w -
8 S •» 4
2 S
*» **
CM CO «*
^" .
CM" a"
CO CM
» o a> co
n «o CM
T-~ CO" Co"
n n o
CM T- *•
3 •» » CO
§n n
o o
«" s a
CM CM ^
•s 551.. •? •? •?- 1-sS !•? 15
2 r>2)it2 2 28 o2A "2 "2
^rf W
9 L
a, ||
£| *
.^ tt jjj •^WTOTID
{/) &T g1 i erect or
^ 55 5 5^ y$ v$ S H~ f/fr j3 h
a £ w o 0> ffi
fi c S * S *
1 1 t - I J I :
£ *~ «D 1 «•« i ® i r i O I 1 1 1
^3 i o .f 58 •«• «™ * * i
_ 2j£ u— 5
i
Neoprene
NEO-1
NEO-2
NEO-9
Subcategory
i
-------
m
O
u
IL
O
K
(0
U
\L
a.
M
yi) u
^5
£1
0 *S
i oS
i 5**
ji!
o
1:5
£5
£S
•^*
If
SI
0 '«
V c?5
g rr
h- ^
3?
in CM
*» <•
P p *
85
in co
CO^ v^
CM" i-*
•» •>
CM M p
CM CM p
C^
•»
10 P O v-ICM O
a g eo o
O
^
^^
CO O O O CM 0»
8 »»»gfe
s : s
a CM «
T-* CM* »'
•» 4» •»
00 P P P <- 0
CM M>* CM*
O CO »
«<• IA p
*» *» ^
•»
s ;s
§ ii
° • ~
5 55
CM CM CO
S! 52
K °g
« CO CO
i-* p* m"
a i- «o
* CM »
co co ** i^ **
CM* CM*
» *
l» *»
w» w» ^r ^r wr w»
flO p
00 «
U
i
I
s
a
8
CO*
r-
K>
•»
$1.023.552
o
£
S'
11
t
2
P OC
cc
UJ
IS
PKPPPPPPPPPPPP pig p p p PIP p p p p PIP
p P
P P
J» «*
CO
8 8
*» «»
S It
3 !* .i
W£> IM C
CO u m
CO y CO
2 CO ID"?
P
•»
P
w
p
«
h 2 S '•§
f •e'oi
p
*»
P
4»
S
II
ffi
8 2 S > R
•M 3 3& T- CMC5T in^
CO 0-e.k 1 .1 I .1 .1 CD
I i b \ — yy}M%iMyi
2 CMOTin(or-coo>0'~wc''T'/' SST^T^ ?5Zffiffiffiffi£
0 1 1 1 1 1 1 1 1 1 1 1 1 1 1 I tt? tfff tf ft
f, 5||||s
i
COCOWCOCOCOWCOWCOCOCOCOCOCOCO CO CO CO CO CO CO CO CO CO CO CO
9 O
~3
5
§
0
»-
4»
O
S
CO
CM*
«»
$3.338.320
CM
CM
CM*
»
S
s
1
o
4*
» P
8
8
p
T-
•»
•*
f-
o
s
u
i
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1 £
m o
o
II
Ik
1?
5
s
2
3
13
o
&
u
Ul
i :
i
LL| CT
Si
? Is
i 5
B s
r C
Is
s
_
Bc|j
*» ^
^t £.Q
11 oS
i r
JK tl
R "5 ®
£ 1 1
^\
Sts
ll
I
|
f-. O O> O
2g *8
5 5
* ^~
in n"
h- a
Sr-
»
S 2
CM i-
< CO
O CO
co n
S 5
to" co"
CM ^
a in
CO CO
a> m
» co"
s s
CO T-
CM O
t ^ CO
in K
eo ^~
o
o
o
N i O r1^
CM 3S fl
i
-------
p
M
O
O
oe
S
3
w
o
a.
CO
I
fcl
^s
0 \
] I3c
5 j«
i s
8 „
5 "*Ek CD
. ^"O
§~
1
9 15
Jft
— *—.
i-*6
<•••.
§it
O "5
-•
3 $p
5 |
L
1 — t?
5 §2
C §E
1
C ffl
ID
£8
£•
i
I
1
1
o o o K cc
c c
UJ UJ
o o o
4» 4» 4»
O O O
******
8ss
sss
3 ^- fs- 00 O O
o CM i™ co rt o
CO V «O
** v> «
«*„.
» s s
CM" in co"
CO K CO
« co in
^ CO CM
in S o
S" co" »"
CM N.
*»55
r- o>
t^ in CM
»• co in
*» 4» 4»
22 a«-BS
S I-*12!1!
E 5"^ 1
O 5
O I
o o o cc ic
CC C
UJ uj
o o o
4» 4» 4*
O O O
******
sss
22S
00 O» N. O O
fs. CM
of co"
4»
CO <- O
CM v r^
CO i- o>_
CM in" rv"
in o> •«
4» r-. co
t co r»
CO ^ CM
in « o
N." co" co"
i- ^ CO
*» 44 4*
co in co
•» CO t^
r^ in CM
CM co" W
CM in co
4» in in
CO *- h.
CO O CO
^1 "P. N.
Stg
*> 4*
S23 ^
^l^ll
1""* 1
^
5
«> o o o cc
S g»-UJ
S25
i i
o" o"
4* 4»
0) 0 0>
CO CO
co* co"
S S
co" co"
CM O CM
CM 4* CM
CM" CM
CO CO
3 S
CM O CM
CO 4» CO
co" co"
S 3
o* o"
*» 4»
in CD «- o o
i- O> ^- O O
4» «fr
O> f CO
8 s a
co" co" co"
CM O CM
°. 1 *".
^ ** CO
K CM 5
CO CM S
CO O>" K
CO CM -v
r-. 10 co
z
SZ ^
llaBl
ffff^gll
to c < CD
i" -
fe
<5
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
12
w
o
u
u.
o
ec
3
M
U
LL
5
w
0.
m
jjS
g^
h-«a
.
i~
i_ O ^
I J±S
\ S*
E 2
3
ll
I"
^5 co co
OB O CM CO CO O T-
CM r-_ T- CM •» CM
4ft
Sat r~ co r*. CM
c» o co T- T-
110" T- CM" r." o" rv"
co m o t^ o> CM
IV 4ft T- CO l>- W
4ft 4ft «ft «ft 44
T- CM « CO CO i-
T- co T- h- at co
o> CM eo co at T-
in *• eo
i*- r* eo n in
SCO T- CM CO T-
T- in o CM m
4» 4» n ^ CM
4ft 4ft 4ft
co CM T- r^ T- at
T- co eo T- o co
» •". —. T °» »-.
O T- r^ CD h- CD
1*. CM CM CM 1^ O>
CO 4» «» T- T- 4»
4ft «• «»
in CD ID co co o
eo » « CM T- o
h* » T- r*. * ^ co
V T- co" co" oT eo"
Sco T- in co T-
4ft T- CO h- ^t
4ft 4ft 4» 4ft
< 1
O "^1
l? C
^ "• m T-CMO5Ttf>
CO 5T g1 ctcttrcri
CO CO
4ft 4»
0 O O 0 "-OOT- OOOO
CM CM"
CO CO
4» 4*
S ? |
u u
s if
CM" CM"
SCM CM
CO CO
V V
4ft 4ft
oo oo no occ cor~ rM«- o co o co o
CMO CMO no cc T~*~ ** o CM in n m
OO*-OKCMT- jy CO T-T-
T- CM CM T- CM
4ft 4ft 4ft 4ft
*• *• m «ft CD in n *• co i^ o in
CM CM ID VOCMlh. COCMinn
o co" oT r~" CD" col CD" o" n" CD" ai
f m t CM in CM o CM t~ co in
O CM CM 4*4* 4»T- 4ftr-4ftT-
pj- 4» 4» 4» 4ft 4»
4»
IT- r~ T- O T-T-T-CO OOCOCD
m co T- 4* o r- i-. o cootr^co
T- 4ft 4ft 4ft i»
co f« CM 4ft no T-|m o n in CD
co •* « in n injn o co in o_
i- in" o>" CD" co" ml in" in T- o" co
5 £> S **»**'«» **SSS
4ft
in T- T- o r^wolcM CMT-T-W
v T- T- 4» co o co r- co o co ^
CM o n ncoinlcM in^n^-
n co" CM" CD" a! VI o" co" o" CM" n"
CM in o> 4ftT-«ftn T-mnco
T-_ T- 4» 4»4ft 4»4ft4ft4ft
IO * 0) O V CM M« CM CD CO CM
o *t CM «ft o T- o CM T- n n c
co o> o r^ co CMlm co m o c;
eo" o" o" V co" col T-" CM" V o o>
««• CM o T- CM T-lm 4ft co n ir
» 4» T" 4» 4* «* 4» 4» 4» »
4ft 4ft
eo « « o n « coin in at o CM
m cc o> 4ft * co r-luj o r^ o n
K CM r*.* o>" i^ eMlcf V CM n" eo"
n * in CM n T- co «> T- r* n
0 * T- W 4ft 4ft 4ft 4» T- 4» T-
pj- V» *» 4ft 4*
4»
fg o>te
S H- 5$" ^
| | 3 I £
f | 1 A ||
2 ^* i" 03 ^3
r~ T~ ^j i TS i _O 'T i ^^ (P i i j i |
S& si fl ISii lllll
S 3 S 818
8 8
3 8
8 3
* O CO T- CM «3 O
CD o CD eo a o
•a •*• n coico
T- o o n CM
°. I0.'!IOJ<»
CM CD ** CD|CO
* c» in in
» 4* 4» •-
4* 4»
I» CO O !*• O
T- CM i- T- in
CD CO 4ft CO a
s « «•»
3 S 2 sis
in" CM" ** ril co"
o CM T- n
T- 4ft *»!*»
ICO CO CO COI-*
CO O> O> CM CM
eV * ** e»1 V
in n CM co
T- 4ft 4ft|4ft
CO T- CO COICM
CO O> CM CO O
co m T- CMJO
8 8"*?|S
T- 4ft 4* 4*
4ft
m Of oil-
h. CM m K *
<»" co" CM" •»] m
co r- 4* in n
CO 4ft «* *-
<* 4ft
ffl-S
I— 2
i i
g g
& « ro
WT-OI ro
h. 1 1 1
oooo
-------
t.
*;
OOOOOO OBOOCOOOO O|»-
M«*t»M«»MV»0«*V»£MMM <*|«
n o o oln
co <* *» M-ICO
n
S
882SSSS28SSS8S5|£ S888IS
SCM
«*
o
S
8
B
» o
5 S
IV
hT
B
m
*•
n
8
CC
Ul
o o o o olo
<•<••»«» «*|t»
S
B"
S
u*
p
M
O
o
U.
O
I
S
3
0)
o
0.
CO
I
3
*- m
co OIICM o
^- « o
Zc.
o o o 010 cc
cc
tu
O>|0>
^sla
s
«»• CM *f O» *• CM CMO*-^CM*-^CMnlcO
«»«»CMv «>«>f-v-CMn«»T-T- 40 (0
*> <*> *> •> VI Vt Vt VI **
vcoonoocMOinon^coi-
CMr-oo«»CMincoocAmcoCftco
•«• V-_ o» a r. o> — r>-_ i-_ o, CM CM o>
" i-^ o" h»" B" W CM o»" T^ B" n" in CM
<»in« «»«»<-^-«CO«»CMB
<*<* *»*>*»*» *> *»
a> co o to T- 10 to
" " "
o
o
.
CM o> co co CM! o
" " "
o o o olo
» <• •» wl*»
i-^ ^ i-^ co *
ex" in co"
CM«»o>
«• »
^ co evi in w^ co co
" eo" •» B" co" in" co"
MCM^coB^
«>«»«*T-
B CM O \m
r-T o" »-" co" col co"
« in a co o to
i- «»<«•» n co
«» *»*»«»•
O*
S
B
B
CM v- f^ CO CO|B
in in r^ o r^. co
O_ O_ * CM_ O O^
co" CM" in" V o cV
r~ w o> o no
•» CM B no
«* *» «* u^
o» o » r-. co|co
in co co CM|*-
in co" o" V a»liC
n n co in in co
«••*«»«»•* CM
•» in CD *»• N r»
o
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1 ?
• 8
O
IL
1?
5
11
£
8
• ;
5
1
tS
*!
SI
i £<*
! *
! 5s
t|
Is
5o
£g
B:S
UJ 0
<2,
2%
?S
* "^
. ^^
E 85
1 |*
LJ
^-.t
is
Is
Is
56
^S
^
'3
u_
9
|
0
\
o
s
o
«»
o
•»
o
*»
o
o
«»
o
w
o
«»
o
44
D) D)
*- 11
<
^
a |
® t 1
CE £ |
2 «
"2 1- IT
C 5 i ^a
r\i ^? S -9 ?
t\j CD m xx
1
-------
CO
o
o
u.
O
C
S
01
o
*L
o
UJ
Q.
(0
I
5
|
i
CO
Q.
U
a=I
gf
9?
K«
|l
s
I*
€-3
8
15 **
c 8
•io
&s
*~
|f
y S
H«a
• O
££ M
*
|l
5
v<
sis
jgn
^"^ C
li
-" r-"
O CO
•» 5
ooo
0 CO
O* CO*
8 8
000
o ** o
-j 5
** **
mom
: i'
<* «
s?os§
CM CM h^
*»
ss§
at at
CO* CO
CO CO
^- O t-
ot o>
CM* CM*
CO O CO
o o
2 S
in o in
SV
CO
it g2^
O 5-
0 S
e o o a 1C tc
tt o a> o oc
O CO O pc
5 «*-•"
,o.
g g
°. °.
i- O T-
CO «» CO
I— •»••••'
n co
a» o a>
CM CM
S«>"
in
o» o»
CM CM
N- O h-
sws
in in"
s s
in in*
ewall
IstFtegAlt
2nd Peg Alt
Total
AvgCE
Incremental CE
-5
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
^ w
o
o
X.
$
0
D)
2
o
•*-*
CO
in
in
CO
8.| I
o o J»
£ ""*
UJ
1g "4- -c-
S S O *•?
8 ^ "" '
O
•5
0
CC
D) •£_
5 £
S ^3
— o f ^
U. 0 U
* — {£
m •^* ?
jc £ 'in
™r CO
S,
CO
Q
.2-1-
in o ^
.>
CO tn ~m
£ .ffi 5
* **™^
±i w
o ^-
(0 O
Q. =
oS
T3
m
<-
^ c
C QJ
10 c
f~ o
O
J^
'o
10
u:
CO CO
m CM
i-~ co"
0> CO
U3 CO
CM >-'
«»
C C
S S
x ^
CM m
DC CC
CL Q.
UJ UJ
co in T eo
o o> •* in
r^-_ «» •* co
vt 5
•r- CM IO ID
O> h- CM ^
CM CO_
CM r^ T- "*
o" W i-~ co
«A *^ ** m
o o in in
co in co h-
in r> r> o>
o" »-"
c
in
£
in
.2
co
co
2 °
° I
*- .ia
§ I
8 =
1 I
O)
co
m
IF-
Q
m
.s o
5 I
o
m
CM
9
Q-
•O
a> -
Is
m M
•.2
,„ in
g .S3
2 E
in co
.ffi *
E -
O)
•*=
5
JO
^
e
u
o
u
"° o
C —t
«8 -D
-e £
a> g
o J8
I E«
o eo M
CO 0)
s
o
u
2
2
01.2
Ir
in
Q)
U
is
'5.
S "2£
» I5
CO Co
TJ 3 S
5 = 00
CO
TJ
"o
C
3
-------
o
O
i-i
c
V
>
(0
(0
a>
o
o
I
9
1
k
\
t
E
t
|
S
1
a
«
|
5
1
S
u
•c
S
«
»
o
o
1
1
<
1
J
C
C
•c
a
|
a
1
"c
^
V
8
—
,
•
c
«i
S
0
K
%
^
•o
£
,_
i
S*""!
.
1
%
1
T
C
a
8*"^
.
•;
i
|
1
c
c
j
S = a
3s-
SS8
23S
4ft
ssi
2 5 2
4ft
3SS
at w *•
S28
» in 0
at of V
«- v in
^ ^ «
4ft 4ft 4*
3 0 CM
S" *• 0"
CM CM
4ft 4ft 4ft
*r Ok ai
538
*!§
558
r» ^ p*
0 0" 0"
CM CO N.
- 4ft 4ft
4ft
*f f O
SS2
0 m *
8SS
*- n 0
«- n K
0 0 «
4ft 4ft 4ft
if*
Is*
0 at CM
I'll
5 5 •
S S S
Sol
CO CO CO
+ + -f
TJ "U ^
c c c
UJ UJ UJ
1 1 1
£22
U. U. U.
|TTT
*
m
Siisi
ssSs
O O 0 M 0
"RSS2
5822
4ft 4ft
SCO c c
li Z z
3
X
•-00^
0 in CM 0
CO* CM Of CO
*• 4* 4* 4ft
4ft
2S22
in »- co ^
4ft 4» 4ft 4ft
IA ^ CM O
8r~ O 0
. CM ^r o
S 4ft J* •»
8888
SSSS
co ^ o *r
8 S? ^" S
« « **5
sss;
n 0 o CM
•-" o" of o
CM CM *• CM
4ft 4ft 4ft 4ft
§ «>sa
|p"§
5se^
o 0 in v
o" 0" 0* co*
V CO CM CO
4ft 4ft 4ft 4»
0 •- CO T
0 in P- «-
CM IA IA K
49 4» «• 4ft
*- 0 CO 0
4ft 4ft 4ft 4ft
ssss
at 0 CM a
CM ^- 0 CM
*- 4* 4* 4ft
4*
at a at at
0000
0* 0* 0" 0'
ssss
S 5 5 S
a a a a
1111
CO CA CO CO
C + C C
°O TJ "O "O
c c c c
c c c c
UI UI UI UI
1 1 1 1
o o o o
u. ut u. u.
7 7 i i
• O O O O
| UI 111 UI UI
I2Z"
1
5.SSS
s ss
4* 4* 4ft
0 W CM
Sn CM CM
4ft 4ft
3s §§
4ft 4* 4ft
l«ii
I 52
SSSS
ssss
ssss
ssss
CO
S5SS
SSK&
0 0 W *
h> CM t*"* P*>
at M at at
4* 4» 4*
in n in in
?S88
8388
2'"s"2"
|
*0
jl II
•si 11
'cilill
1 1— U. r- r-
i
3 C C C C
CO HI UJ UJ HI
1 1 1 1
21111
2 CD CD CD CD
81 'e ^ IA m
f I I 1 1
E co co co to
5 oz cc cc cc
~ CD CD CD CD
| S0«oc««
J cc cc a: cc
* CD CO CD ID
f a. a. a. a.
fl.
S
s
s
s
o
4ft
O
4ft
S
s
^
^ P» CO CO
CM b. 0 IA
CM •£ 0 K
4ft 4* 4ft 4ft
§815
sst'i
4ft 4ft
SO O O
4» 4ft 4ft
O O O O
4ft 4ft 4» 4ft
SSSS
ssss
CM 0 N ^
V o" of e>
CO CM Ot IA
W CM T T
4» 4ft 4ft 4ft
SSSR
O CO ^ UI
*- CM h* 0
N. 0 0 fN.
*• O 0 CO
*- *- CM <\
4* 4* 4* W
U jj co c
S "" S ?
« 8 ^- --
•• »
111!
11111
7 « * « a
c £ £ £ £
B r- p- r- H-
UJ
*T,T,^,
k c c c c
5 UJ UJ ui ui
Jl i I I
% % % %
a a a •
_ co CD co a
*,,„.
3111
a ui ui ui ui
cc cc cc cc
I CD m m CD
• CO 09 CO 0
e <00>0>to
CO
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Equipment Leak Costs
Faeiliy
Butyl Rubber
BH-1
Capial Initial
Cost* Monitoring11
($)
(11,452
Epichlorohydrin Rubber
EPI-1
Ethylene- Propy
EPR-1
EPR-2
EPR-3
EPR-4
EPR-5
$442,763
tone Rubber
$81 .1 40
$116.746
$654.224
$760,418
$413.800
$2.035.334
Halobutyl Rubber
HBR-1
Hypalon'
HYP-1
Neoprene
NEO-1
NEO-2
NEO-3
$157.804
$0
$78,420
$2,454
$54.273
$135,147
Nitrite-Butadiene Latex
NBL-1
NBL-2
NBL-3
$20,845
$37,834
$11.061
$70,740
Nitrite-Butadiene Rubber
NBR-1
NBR-2
NBR-3
NBR-4
$64,465
$107,370
$70.138
$133.932
$375.914
<$)
$23,283
$0
SO
$0
$2.204
$0
s&
$2.204
$0
$0
$0
$0
SO-
SO
$0
$0
S515
$515
$0
$5.200
$3.062
SO.
$8.261
Polybutadiene/Styrene Butadiene
Rubber by Solution*
SBR/PBRS-1
SBR/PBRS-2
SBR/PBRS-3
SBR/PBRS-4
SBR/PBRS-5
$377.404
$4,010
$510,716
$535,364
$580.577
$2,017,080
Polysurfide Rubber
PSR-1
$0
Styrene— Butadiene Latex*
SBL-1
SBL-2
SBL-3
SBL-4
SBL-5
SBL-6
SBL-7
SBL-6
SBL-8
SBL-10
SBL-11
SBL-12
SBL-13
SBL-14
SBL-15
$22.117
$4,060
$02,647
$77.888
$0
$17,431
$8.387
$24.237
$42,380
$86,177
$133,027
$6,442
$53.202
$60,631
$11.116
$640.740
$0
$1.247
$4.380
$0
$a
$5,627
$0
$0
$202
$517
$0
$0
$0
$0
$0
$1,133
$2,363
$2,834
$107
$1,448
$0
S340
$0,034
Styrene— Butadiene Rubber by Emulsior
SBRE-1
SBRE-2
SBRE-3
SBRE-4
$0
$0
$0
SS_
$0
$5,806,964
$0
$0
$0
$£
$0
$48,023
Direct1
$370,818
$20.044
$21 .1 82
$27.131
$126.417
$177,001
$06.160
$448,800
$100.020
$0
$30,501
$123
$14.288
$54,002
$14.704
$23,612
$13.207
$51.522
$2,612
$84.536
$33,038
$59.302
$180.388
$35.750
$36,460
$80,064
$54,677
$59.256
$267.117
$0
$6,028
$6,845
$27,098
$14,638
$2,106
$5.520
$6,353
$21 .003
$17,543
$36.458
$41,292
$2,002
$22,383
$6,670
$5.230
$223,068
I
$0
$0
$0
$£
$0
$1,716,680
Annual Cost ($/yr)
Indirect"
$3,088
$158,011
$18,726
$51 ,705
$302,853
$428,340
$231.532
$1,123.245
$02,311
$0
$34.508
$408
$29.128
$64,224
$6,387
$10,305
$4.880
$30.272
$13,532
$50,401
$32.381
$63.475
$159.788
$78.052
$2.051
$295,477
$304,208
$330.076
$1,009,863
$0
$6,424
$1.178
$50,809
$47,003
$0
$3,720
$1,052
$12,180
$10,705
$41 ,1 00
$63,053
$3,284
$25.208
$32,087
$5.544
$315,416
$0
$0
$0
Sft
$0
$2,956,219
Ree Cred*
$2.011
$1.187
$282
$1.314
$2,376
$3.008
$2.161
$10.131
$2.311
$0
$623
$10
$317
$050
$161
$171
SZL
$403
$260
$1,400
$378
$1.486
$3,614
$1.320
$218
$1,081
$1,347
$1.460
$6.325
$0
$01
$66
$505
$166
$20
$72
$60
$137
$308
$634
$489
$50
$391
$132
ssa
$3.290
$0
$0
$0
S9_
$0
$31 ,1 31
Total
$370,004
$177.760
$30.626
$77.612
$516.805
$602,243
$325.530
$1.561,015
$100.028
$0
$73,566
$610
$43.100
$117.276
$20,030
$42,746
$17.716
$81 ,302
$15.884
$133,446
$65,041
$121.290
$336.561
$112.401
$38.203
$374,460
$357,538
$387.872
$1.270.655
$0
$13.261
$7,058
$77,412
$62,375
$2,086
$0,177
$8,245
$33,046
$37.030
$77.013
$103,856
$6.226
$47,200
$30,525
$10.685
$535,186
$0
$0
$0
SO.
$0
$4,641 ,776
HAP EmiMton
Reduction'
(Mfl/yr)
283.3
110.6
28.4
132.3
230.3
402.7
217.7
1020.5
232.8
0.0
8Z8
1.0
31.0
95.7
16.2
17.2
LI
40.6
26.2
150.1
38.1
149.7
364.1
132.9
21.0
199.5
135.7
147.1
637.1
0.0
9.1
6.7
50.0
16.7
2.0
7.3
6.0
13.8
31.0
63.0
40.2
5.0
30.4
13.3
2£
332
0.0
0.0
0.0
Q£
0.0
3,136
Cost—
EffectkeneM
-------
to
<+*
to
O
O
Q.
(Q.
'd
*-«
CO
E
CO
V
•*-<
CO
0)
^-i
CO
(0
8
•g § "3
1S
1
r
5 tt%
W fl)
o 8=5
&!
"C
^ m
1s
^
fS
o
6 6-=-
»• •§ T5 -^
l§ c? *•"
III
— -n
a
c 5 ^"
Pi
•Si2-
c
I9
>,
^
o
^
o
I
ja
S
"~ fc
2 S
IO CO
r- o
CM CO
CM O)
**
So
CM
s st
CO CM
s fc
IO CO
•9 10
§ 5
CM
f O ID
CM
10 *• r-
r CM »
o *r ^
CM CO
Butadiene
Styrene
Styrene
«- CM
I i
co co
CO ^
' i
s g
CO CO
CO CO
2
s'
en
5
CM
IO
S
s
!>;
CO
IO
n
i
^—
5'
10 N. en v-
» — CO CO
»- CM
V ^ CO CM
•i* i
l|||
^ ^
1 1
cc co
T
HI
cc
CO
co
111
tr
CO
CO
o
o
o
i
4»
O
to
Jj
o
^
9
CM
9
S
S
^«.
o>
i
8
en
Acrylonitrle
^
I
co
^
'
CO
m
IO O
CM ^
O 0
CM O
«B_ t^
2 S
7Z JV
0
K d co CM ei
^ CO CO •«-
(O «• CM IO -^ (O
oi r^ T co CM °.
^- co o co *- o
o o o a
•D TJ T3 -D
0 0 0 S 0 0
€ ? J-5-5J
•5, -5. 0-5.T5.*
t t ^f5!2
22 22
CM CO »»• _j
1 1 1 CM ^
OC EC CC | S
••c ^c ^ UL
? ? 5 "• UJ
CO CO CO >
o
_
1
cc
m
x>
JO
cc
CO
D
j:
'g _g
g-o
"a-S
HI
* ^5 c
50 s"-'
|D
feed tanks, feed prer
dudes direct Installal
Indirect Installaticn c
ig, and contingency
o -C £ t»
— o "i «
•> «> * ~
1'fl
£ S. « §•
III J
•"• *5 5
S" S | o
?1? 6
=52*5
•5 « £ •§
_c ic a. o
E S
•o *•
E 2
s 5
I!
4; CD
« «
I *
* 5
i 8
i I
I
a a
I I
I *
* I
! 1
I E
§ I
' I
i I
i I -
I s I
1
o •:
5 i
s •
• TJ
a TI
33*
TJ TJ 8
£ £ Q
-------
TECHNICAL REPORT DATA
(Please read Instructions on reverse before completing)
1. REPORT NO.
EPA-453/R-95-005a
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Hazardous Air Pollutant Emissions from Process Units
in the Elastomers Manufacturing Industry— Supplementary
Information Document for Proposed Standards
5. REPORT DATE
May 1995
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Emission Standards Division (Mail Drop 13)
Research Triangle Park, NC 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANTNO.
68-D1-0019
12. SPONSORING AGENCY NAME AND ADDRESS
Director
Office of Air Quality Planning and Standards
Office of Air and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
This document contains technical memoranda that provide rationale and information used to develop
the Polymers and Resins Group I Elastomers and Synthetic Rubbers proposal package. The memoranda
included in this document provide detailed background information for the Basis and Purpose Document
for the proposed standards (EPA-453/R-95-005a). The memoranda address industy characterization,
baseline emissions, subcategorization, MACT floors and regulatory alternatives, the potential for new
sources, and the estimated regulatory alternative impacts.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b. IDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Air Pollution
Pollution Control
Hazardous Air Pollutants
Air Pollution Control
Elastomers Manufacturing Industry
18. DISTRIBUTION STATEMENT
Release Unlimited
19. SECURITY CLASS (Repon)
Unclassified
21. NO. OF PAGES
296
20. SECURITY CLASS (Page)
Unclassified
22. PRICE
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION IS OBSOLETE
-------