SEPA
PROTECTION
AGENCY
DALLAS, TEXAS
United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park. NC 27711
Air
EPA-453/R-95-003a
March 1995
Hazardous Air Pollutant
Emissions from Process
Units in the Thermoplastics
Manufacturing Industry--
Supplementary Information Document
for Proposed Standards
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EPA-453/R-95-0033
Hazardous Air Pollutant Emissions
From Process Units in the
Thermoplastics
Manufacturing Industry-
Supplementary Information Document
for Proposed Standards
Emission Standards Division
N
U.S. Environmental Protection Agency
Office of Air And Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
March 1995
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DISCLAIMER
This Report has been reviewed by the Emission Standards
Division of the Office of Air Quality Planning and
Standards, EPA, and approved for publication. Mention of
trade names or commercial products is not intended to
constitute endorsement or recommendation for use.
ii
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ENVIRONMENTAL PROTECTION AGENCY
Hazardous Air Pollutant Emissions from Process Units in the
Thermoplastics Manufacturing Industry —
Supplementary Information Document for Proposed Standards
1. The standards regulate organic hazardous air pollutant
(HAP) emissions from the production of acrylonitrile
butadiene styrene (ABS) resin, styrene acrylonitrile
(SAN) resin, methyl methacrylate acrylonitrile
butadiene styrene (MABS) resin, methyl methacrylate
butadiene styrene (MBS) resin, polystyrene resin,
poly(ethylene terephthalate) (PET) resin, and nitrile
resin. Only those thermoplastic product process units
that are part of major sources under section 112(d) of
the Clean Air Act (Act) will be regulated.
2. For additional information contact:
Mr. Leslie Evans
Organic Chemicals Group
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
Telephone: (919) 541-5410
3. Paper copies of this document may obtained from:
U.S. Environmental Protection Agency Library (MD-36)
Research Triangle Park, NC 27711
Telephone: (919) 541-2777
National Technical Information Service (NTIS)
5285 Port Royal Road
Springfield, VA 22161
Telephone: (703) 487-4650
iii
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OVERVIEW
This Supplementary Information Document (SID) contains
memoranda providing rationale and information used in
developing the Polymers and Resins Group IV Thermoplastics
proposal package. These memoranda were written by Pacific
Environmental Services, Inc. under contract to the U. S.
Environmental Protection Agency (EPA). The data and
information contained in these memoranda were obtained
through literature searches, industry meetings, plant
visits, and replies to section 114 letters sent to industry.
The memoranda included in this SID are referred to in
the Basis and Purpose Document and in the preamble to the
proposed rule. These memoranda were compiled into this
single document to allow interested parties more convenient
access to this information. The memoranda included herein
are also available from the docket (Docket A-92-45).
The memoranda included in this SID are listed below
along with their document numbers.
Document No. Description
II-B-13 P. Dautenhahn, PES, to L. Evans,
EPAiOAQPS. December 29, 1993. Summary
of Capture and Control Devices and
Pollution Prevention Technologies. 41
pages.
II-B-16 K. Meardon, PES, to L. Evans, EPA:
OAQPS. July 21, 1994. Collocation of
Group IV Resins Facilities. 5 pages.
II-B-19 K. Meardon, PES, to Group IV Resins
Docket No. A-92-45. December 21, 1994.
Estimated New Growth for Group IV Resins
Sources. 9 pages.
IV
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Document No. Description
II-B-20 B, King, PES, to L. Evans, EPAiOAQPS.
March 22, 1995. Process Vents Levels of
Control for Methyl Methacrylate
Butadiene Styrene (MBS) Sources - New
Level of Control More Stringent than
Existing Level of Control. 3 pages.
II-B-21 B. King, PES, to Group IV Resins Docket
No. A-92-45. March 22, 1995. Process
Vent MACT Floors Considered More
Stringent than the Hazardous Organic
NESHAP (HON) and Batch Processes
Alternative Control Techniques (ACT).
8 pages.
II-B-22 B. King, PES, to L. Evans, EPArOAQPS.
March 24, 1995. Methodology for
Estimation of Preliminary Monitoring,
Recordkeeping, and Reporting Costs for
the Economic Impact Analysis for the
Polymers and Resins IV NESHAP.
II-B-23 B. King, PES, to Group IV Resins Docket
No. A-92-45. March 24, 1995. Storage
Tank MACT Floors Considered More
Stringent than the Hazardous Organic
NESHAP (HON).
II-B-24 B. King, PES, to L. Evans, EPA:OAQPS.
March 24, 1995. Methodology for
Estimation of Secondary Environmental
Impacts.
II-B-25 B. King, PES, to L. Evans, EPA:OAQPS.
March 24, 1995. Baseline Emissions
Estimates for the Group IV
Thermoplastics.
II-B-26 B. King, PES, to L. Evans, EPAtOAQPS.
March 24, 1995. Methodology for
Extrapolation of Impacts for Facilities
Without Sufficient Data.
II-B-27 B. King, PES, to L. Evans, EPArOAQPS.
March 24, 1995. Summary of Cost,
Emission Reduction, and Energy Impacts
for Group IV Resins Sources.
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Document No. Description
II-B-28 B. King, PES, to Group IV Resins Docket
No. A-92-45. March 24, 1995. MACT
Floor Analysis and Development of
Regulatory Alternatives for Wastewater
Operations, Storage Vessels, Process
Vents, and Process Contact Cooling
Towers .
II-B-29 K. Meardon, PES, to Group IV Resins
Docket No. A-92-45. March 24, 1995.
Determination of MACT Floors for
Equipment Leaks.
VI
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PACIRC ENVIRONMENTAL SERVICES, INC.
MEMORANDUM
/^l - "I *- ' -f
JT-&-&
Central Park West
5001 South Miami Boulevard
PO Box 12077
Research Triangle Park. NC 27709-2077
(919)941-0333 FAX (919)941-0234
TO: Les Evans
U. S. Environmental Protection Agency (EPA)
FROM: Pam Dautenhahn
Pacific Environmental Services, Inc. (PES)
DATE: December 29, 1993
SUBJECT: Summary of Capture and Control Devices and Pollution Prevention
Technologies
The purpose of this memo is to summarize the capture and control devices and
pollution prevention technologies that have been provided in the Section 114 questionnaire
and information collection request OCR) responses for the polymers and resins in the Group
IV national emission standard for hazardous air pollutants (NESHAP).
PES has reviewed the answers to the optional questions, the information provided in
the Section 114 questionnaires for control devices, the information given in Table 4 of the
ICR, and any additional information provided in the clarification responses. This
information was used to compile the information given in Attachments A and B to this
memo. Attachment A provides information by facility on control devices and pollution
prevention technologies used by the industry to control emissions from storage, process
vents, wastewater, and waste; Attachment B provides information on control programs for
equipment leaks. The following discussion gives an overall summary of the controls being
used.
Tables 1 through 3 provide a breakdown of the information on controls by emission
type and type of control obtained on control technologies. Table 1 shows the number of
facilities that use some type of control device during their polymer manufacturing
process(es). Table 2 gives the number of facilities that use a specific type of control device.
Table 3 shows the types of control devices that are used in each manufacturing area.
STYRENE-BASED POLYMERS SUMMARY
Storage Tank Controls
The information in the attachment shows that approximately 26 out of 45 styrene-
based resin facilities control their storage tank emissions to some degree. Some facilities
control all of their storage tanks and others control only specific storage tanks. Some
facilities identified the type of tank, such as fixed roof, floating roof, or pressurized tanks,
WASHNGTON. D.C • RESEARCH TRIANGLE PARK, NC • LOS ANGELES, CA • ONCINNATI. OH
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Les Evans
December 29, 1993
PageS
being used for storage and others did not. The specific type of tank is generally not
identified in the attachment.
A few facilities use vapor return systems to the tank trucks when loading styrene into
the storage tanks to control working loss emissions. Several control technologies are being
used to reduce the breathing emissions from the styrene storage tanks. These technologies
include surface condensers, refrigeration systems, carbon adsorption systems, and industrial
boilers. The main purpose of most of the condensers is to keep the storage tanks at a
specific temperature, which in many cases reduces the breathing losses from the storage
tanks. In the case of the industrial boilers, these boilers are generally being used to control
process emissions with the raw material storage emissions being a minor addition.
Several control technologies are also being used on the storage of the other raw
materials. Carbon adsorption systems are being used on methyl methacrylate, ethyl acrylate,
ethylbenzene, and recycle tanks. Horizontal and pressurized storage tanks are being used on
butadiene storage with some tanks being further controlled with surface condensers. One
facility uses a steam-assisted flare on the emissions from butadiene bullet and sphere type
storage tanks. An air-assisted flare is also used on butadiene storage, unloading, and
sampling. Acrylonitrile storage tanks tend to be pressurized and vapor balancing is also used
when loading acrylonitrile. Many acrylonitrile tanks that are not pressurized tend to have
floating roofs. One facility has a double-sealed floating roof on acrylonitrile that results in
no emissions. Those facilities that use hydrochloric acid in their process use a scrubber to
pontrol the emissions from the storage of the acid.
Process Controls
Approximately 44 styrene-based facilities capture and/or control some of their process
emissions in one way or the other. Several facilities have made improvements in their
processes to increase conversion of the monomer and thus reduce monomer vapor emissions.
In many cases, material recovery processes are used to recover the unconverted monomer and
return it to storage for use in the process at another time.
Thermal incineration is used to control emissions from the reactors in some cases.
One facility collects all of the process emissions and sends them to a thermal incinerator for
destruction. Some facilities combine many of the emission points and send them to a burner
or incinerator. Steam-assisted flares are used at some facilities on various emission sources,
such as butadiene purification, which involves inhibitor stripping, reactors, and knock-out
drums.
Some facilities use scrubbers or mist demisters on their extrusion or die head systems.
Electrostatic precipitators are also commonly used on the die head/extrusion systems.
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Les Evans
December 29, 1993
Page 4
However, the electrostatic precipitators and mist demisters are designed to remove oil, mist,
smoke, and oligomers from a process area rather than significant hazardous air pollutant
(HAP) emissions.
Many processes have surface condensers on the reactors and/or the devolatilizers.
However, in general, the condensers represent an integral part of the process rather than a
control device. Some facilities use condensers followed by carbon adsorption on the reactors.
Liquid waste of monomer is also used in some cases as the fuel for burners used to control
the air emissions.
Wastewater Controls
Although very few facilities reported any detailed information about wastewater
generation and its air emissions, some did provide information and actually control the
emissions from the wastewater. One controls the emissions by collecting the emissions from
the wastewater sump along with the process emissions where they are sent to a thermal
incinerator. A few facilities collect the wastewater and send it through a carbon filter system
before dumping into the storm drain. Another facility hard pipes the wastewater into an
enclosed biological system where the air emissions from the system are treated by carbon
adsorption. Many facilities have a wastewater treatment system, but do not control the air
emissions occurring during treatment. Some facilities have covered manhole systems to the
treatment facility. Some facilities do not have any treatment system, but send the water to a
neighboring facility's treatment or to a industrial complex wastewater treatment system.
Waste Controls
Waste is reported even less frequently than wastewater. However, some liquid
styrene waste that is produced is sent to boilers as fuel, recycled, or collected and shipped
off-site for incineration.
Equipment Leak Controls
Most facilities have an equipment leak control program. Only a few facilities stated
that they do not have any equipment leak control programs.
Based on the information provided, there is a wide range of programs being used to
control equipment leak emissions. Most of the programs include those that are similar to the
CTG, NSPS, and HON equipment leak control programs. At least two programs target a
specific leak frequency for most of the components, and one program targets "no evidence of
leaks." One facility identified the use of continuous area monitors for the detection of
acrylonitrile and styrene with a leak detection level of 2 ppm.
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Les Evans
December 29, 1993
PageS
Some facilities apply their program depending on the HAP in the line (e.g., applies
only to those in acrylonitrile service). Some facilities vary the monitoring period according
to die particular HAP (e.g., monthly for butadiene, quarterly for acrylonitrile). Still others
may vary the leak definition depending on the component or HAP. None of the facilities
specifically indicated that components in heavy liquid service were part of their programs.
The following paragraphs summarize the various leak equipment control programs that
are similar to the CTG, NSPS, and HON type programs by component type. Following
these paragraphs, the other two types of programs are discussed.
CTG. NSPS. HON-tvpe Control Programs
Valves, gas service. Most facilities monitor valves in gas service either on a monthly
basis or a quarterly basis. The most common leak definition is 10,000 ppm, although 1,000
ppm is used fairly frequently. Many of the facilities noted that they are in the "skip period"
for monitoring (which allows them to monitor on a less frequent period) due to the low level
of leakers (i.e., less than 2 percent leaking). Other reported monitoring periods included
semi-annual and annual, and other leak definitions used included 100 and 500 ppm.
Valveg, Kgnt liquid service. The same basic monitoring frequency and leak
definitions used for valves in gas service are also used for valves in light liquid service.
Some facilities use sealless valves as a control.
Pumps, light liquid service. As for valves, most facilities reported either monthly or
quarterly monitoring of pumps in light liquid service. Except for a few instances, the
monitoring period used for valves and pumps were the same. Many facilities also noted
weekly visual inspections of pumps. A number of facilities reported the use of pumps with
double mechanical seals and the use of sealless pumps. Usually these pumps represented a
portion of all the pumps in use at the facility. The leak definition was usually the same as
that used for valves, and ranged from 100 ppm to 10,000 ppm.
Pressure relief devices. The types of controls reported for pressure relief devices
were generally spread over several types. A number of facilities identified "no detectable
emissions" (leak definition = 500 ppm) as the standard being complied with. Many
identified in-line rupture disks. Others noted a more typically monitoring of the PRO with
the leak definition varying among facilities. Two facilities indicated that some of the PRDs
were tied into a control device (a flare in one instance and possibly a thermal incinerator in
the other instance). A few facilities appear not to provide any control program.
Open-ended lines. Almost without fail, all of the facilities that reported open-ended
lines indicated that they all were capped or similarly controlled. Only in a few instances did
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Les Evans
December 29, 1993
Page 6
it appear that some OELs were uncontrolled at facilities that had equipment leak control
programs.
Compressors. Most facilities that reported the presence of compressors indicated the
use of barrier fluids as the control technique. A few noted that "if seen leaking, they are
fixed" as the level of control. A few others noted a monitoring program (e.g., quarterly or
annually with a leak definition of 10,000 ppm). In one instance, a facility indicated that a
closed purge system was being used to control emissions. Several facilities noted that their
compressors were under vacuum, which would exempt them from an equipment leak control
program.
Sampling Connections. Many of the facilities that reported the presence of sampling
connections indicated the use of a closed purge system. Many others indicated no control.
(Some companies reported the use of caps, etc., and/or monitoring but these controls are
associated with the sampling connections as an open-ended lines, and are not controls for the
actual sampling.) One facility indicated that three of the sampling connections are hooked
into a carbon bed adsorber, but no control efficiency was identified because, according to the
company, the carbon beds are used for odor control.
Flanges and other connectors. About one-half of the facilities indicated that they
monitored flanges and other connectors, while the other half indicated no control. For those
that did monitor, the monitoring period included monthly, quarterly, and annually. Leak
definitions also ranged widely, from as low as 100 ppm up to 10,000 ppm. One company
reported a policy of "inspect as suspect" of a leak. Another company also pointed out
specifically that they had eliminated a large number of flanges by incorporating welded joints
wherever possible.
Other Programs
At least two facilities implement a program whose goal is to maintain less than 0.5
percent leakers from valves (leak definition of 10,000 ppm) and less than 1 percent leakers
(leak definition of 10,000 ppm) from pumps, pressure relief devices, compressors, sampling
connections, and flanges and other connectors.
One facility has a similar program where the goal is to maintain less than 2 percent
leakers with a leak definition of 10,000 ppm.
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Les Evans
December 29, 1993
Page?
PET POLYMER SUMMARY
Storage Tank Controls
The information from the questionnaires and clarification responses shows that
approximately seven PET facilities control or capture any of their storage tank emissions.
Venturi scrubbers and one other type of scrubber are used on storage tanks at three of the
facilities. The scrubbers are used on tanks containing a variety of materials: ethylene glycol,
DMT, methanol and some unspecified raw materials (additives or catalysts). Condensers are
used on storage tanks at the other four PET facilities. A surface condenser is used at one
facility on the raw material storage tanks and a heat exchanger is used on the tank farm. The
condensers used at two other facilities are either for by-product storage or recycled/purified
material storage. One other facility uses a condenser on their methanol storage and a slot
hood during catalyst handling. In general, the condensers on storage tanks are used for
temperature control, and although they may reduce breathing losses from the tank, their
primary function is not as an emissions control device.
Process Controls
The information shows that only seven of the 22 PET facilities reported any type of
capture and/or control devices on their process vents. Various types of condensers are used
at many PET facilities. In many instances the condensers that are used in a PET
manufacturing process are an inherent part of the process and not designed for use as control
devices. For this reason, it is often difficult to determine if the condenser information
provided in the questionnaire responses is applicable as control technologies. For example,
one facility uses a number of barometric condensers, many in series, on their condenser and
reactor jets. These condensers may have been added to reduce emissions from the process,
but they may also be part of an elaborate recovery system. Another facility uses a surface
condenser on a vacuum system in their TPA continuous process. Condensers are used during
the esterifjcation process at one facility. One other facility also uses condensers on their
esterification process and on a vacuum pump. A facility mat uses a DMT continuous process
to produce PET has a heat exchanger on the ethylene glycol refining columns that are used
for ethylene glycol recovery/purification.
One of two types of incineration (either thermal or catalytic) is used at four PET
facilities. One facility uses thermal incineration on preheater surge bins, reactors, seal tanks,
and a knock-out tank. Many of the streams at this facility are combined and vent to the same
incinerator. Another facility uses both thermal and catalytic incineration. Thermal
incineration is used at this facility on the refining and vacuum systems on one of their
process lines. On another of their process lines, this same facility uses catalytic incineration
during the reaction and drying steps of a solid state process. A third facility uses thermal
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Les Evans
December 29, 1993
Page 8
incineration on their organic stripper column, and the fourth facility uses a thermal
incinerator for their reactor vents, vacuum pump, and crystaliizer/cyciones.
Three PET facilities use scrubbers on their processes. One facility uses two types of
scrubbers: packed bed scrubbers for refining, vacuum, reaction and drying systems on two of
their process lines, and a venturi scrubber on the reaction and drying steps on another line.
One facility produces PET using three different types of processes and all three processes use
scrubbers. The continuous TPA process at this facility uses scrubbers on distillation and
vacuum systems in addition to on the solid state reactor. During the DMT batch operation,
scrubbers are used on the reactor, ethylene glycol recovery and distillation, and during sludge
trailer loading. The DMT continuous process at this same facility uses scrubbers on
methanol recovery, vacuum, reactor, and sludge handling units. The third facility uses a
glycol scrubber on the esterification process.
One facility uses a slot hood on their ethylene glycol process tanks to capture the
emissions.
Wastewater Controls
Although many PET facilities have on-site wastewater treatment plants, only one
facility reported any specific control technologies for wastewater. This facility provided
information on their dioxane recovery as an emissions reduction project. Process wastewater
from various production areas at the facility is collected and fed to a distillation column.
The overheads from the distillation column are fed to a thermal oxidation unit that removes
99 percent of the combustible materials.
As part of an emissions reduction program, one other facility has implemented
changes to reduce the amount of ethylene glycol released from the process cooling water in
the cooling towers. This reduction of ethylene glycol has been accomplished by maximizing
the flow of the process water to the glycol distillation column, replacing the cooling tower
fill which increases the tower efficiency, and allowing the distillation column to operate
continuously during the summer. These changes have decreased the ethylene glycol present
in the cooling water by approximately 7.5 percent.
Waste Controls
Only one PET facility reported any type of control for waste handling. This facility
uses a scrubber to control the emissions during sludge or waste handling for their DMT batch
and DMT continuous processes. Another facility uses two wall fans in their waste handling
area for ventilation.
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Les Evans
December 29, 1993
Page 9
Equipment Leak Controls
Only one of the facilities reported a LDAR program for equipment leaks based on the
traditional programs identified in the various NSPS/NESHAP. At this facility, the program,
which is currently being implemented at only one process line, is based on the NSPS, where
valves and pumps are monitored monthly with a leak definition of 10,000 ppm. This facility
stated that all new lines will have a LDAR monitoring program, and that the site is
undergoing a major effort to begin compliance efforts for the proposed SOCMI HON.
One other facility noted that all pressure relief devices have rupture disks.
At least four facilities noted that their "LDAR" programs are based on repairing as
quickly as possible all visually detected leaks. One of these facilities stated that the main
emphasis of their LDAR program is to seal air leaks into the process rather than prevent
emissions to the atmosphere. Since it appears to be common maintenance practice, many of
the PET facilities may not have reported the repair of all visually detected leaks as a
"LDAR" program.
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ATTACHMENT A
SUMMARY OF CONTROL DEVICES AND POLLUTION
PREVENTION TECHNOLOGIES
The following sections summarize the current technologies being used by the different
companies for the processes used in the manufacturing of the polymers and resins in Group
IV. The technologies are given by each area of the process (i.e., storage, process,
wastewater, and waste).
STORAGE
Facility AR:
ABS
Facility Y:
ABS & SAN
Facility AA:
ABS, SAN, PS
Facility AM:
ABS, SAN, &
PS
Facility AL:
ABS & PS
Facility AN:
ABS & PS
Facility AQ:
ABS & PS
Facility A:
PS
Facility B:
PS
Uses double-seal floating roofs on the acrylonitrile storage tanks.
ABS: Uses a packed tower scrubber on monomer recovery the
monomer recovery system.
Uses a steam-assisted flare on the butadiene bullet and sphere tanks.
Uses a boiler on the rubber additive tanks and an oxidizer on the
rubber slurry tanks.
Uses process heaters (thermal incineration) on some storage tanks.
Uses an industrial boiler on ethylbenzene storage tanks. Uses vapor
balancing and pressure vessels with acrylonitrile storage.
Uses a surface condenser and burner on tanks containing a mixture of
HAP's. Uses surface condensers on sryrene storage tanks. Uses a
burner on a storage tank of ethylbenzene and styrene and a tank of
ethylbenzene. Uses vapor balancing on acrylonitrile storage tanks.
Uses an industrial boiler on emissions from some raw material and
recycle storage tanks.
Has a vapor transfer system on the styrene storage tank to the delivery
truck.
Has a carbon filter to capture the VOC's due to breathing from the
styrene storage tank.
Has underground styrene storage tanks with each being equipped with a
vent line to a single carbon canister for adsorption of
ethylbenzene/styrene emission vapors.
Has another underground tank which is a split tank. Each compartment
is equipped with a vent line connected to a single carbon canister for
adsorption of ethylbenzene/styrene emission vapors.
A-l
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Facility K: Has a vapor recovery system on the styrene storage tanks to the tank
PS trucks.
Facility P: Continuous PS: Uses a surface condenser on the styrene storage and
PS day tanks. Use a surface condenser on the ethylbenzene storage tank.
Suspension PS: Uses a surface condenser on the raw material storage
tanks.
Facility AE: Uses vapor return on the styrene storage tanks and the product storage
PS silos.
Facility AJ: Uses a refrigeration system on styrene storage tanks.
PS
Facility S: Continuous PS: Uses a surface condenser on ethylbenzene storage,
PS & EPS recycle storage, and purge tank. Use a surface condenser on other raw
material storage tanks.
EPS and Batch PS: Uses vapor return during styrene
loading/unloading. Uses a surface condenser on styrene storage.
Uses a venturi scrubber on the acid storage tanks.
Uses carbon adsorption on the styrene storage tanks.
Uses a surface condenser on the styrene storage tank.
Uses a surface condenser on some of the raw material storage tanks.
Uses fixed carbon beds on the storage tanks. On a couple of storage
tanks the facility also uses a refrigerated brine condenser.
ASA/AMSAN: Uses a packed bed scrubber on acrylonitrile storage
(also surface condenser), alpha-methyl styrene storage (also surface
condenser), mixture of acrylonitrile and styrene (also thermal
afterburner), mixture of acrylonitrile, styrene, and alpha-methyl styrene
(also thermal afterburner).
Facility AS: Uses a refrigerated surface condenser on the styrene and
SAN methylmethacrylate storage tanks to eliminate breathing losses. Uses
the process incinerator on the methlyethyl ketone storage tank.
Facility G: Uses carbon adsorption-canister type systems on styrene
MBS storage/unloading, methyl methacrylate storage, and ethyl acrylate
storage tanks. Uses a sphere for butadiene storage
Facility AF:
PS & EPS
Facility AG:
EPS
Facility Q:
EPS
Facility R:
EPS
Facility AT:
PS&
ASA/AMSAN
A-2
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Facility T:
MBS
Facility AC:
MBS
Facility W:
NITRILE
Facility U:
SAC
Facility AK:
SAC
Facility AW:
PET
Facility AX:
PET
Facility AY:
PET
Facility AZ:
PET
Facility BA:
PET
Facility BB:
PET
Facility BC:
PET
Uses horizontal and pressurized storage tanks plus surface condensers
on butadiene storage. Uses surface condensers on styrene and
methylmethacrylate storage tanks. (Company does not consider the
condensers as reducing emissions.) Uses a water spray scrubber on the
hydrochloric acid storage tanks.
Uses a flare on the butadiene storage, unloading, and sampling. Uses a
venturi scrubber on the acid storage tanks.
Uses a fixed carbon bed on the recovered monomer tank.
Has a carbon adsorption system with vapor return to the cargo tanks on
the styrene and methyl methacrylate storage tanks.
Uses pressure/vacuum vents on all raw material storage tanks.
Uses a venturi scrubber on ethylene glycol and DMT storage tanks.
Uses a surface condenser on raw material storage and tank farm. Use
heat exchanger (vent condenser) on tank farm.
Uses a venturi scrubber on methanol storage.
Uses condensers on crude glycol storage obtained from process lines.
Use condenser on by-product storage associated with continuous TPA
process.
Uses a scrubber on the raw material storage.
Uses a slot hood on catalyst handling. Use a condenser on methanol
storage.
PROCESS
Facility X:
ABS
Uses a gas collection system to collect emission from each point of the
process, with the emission discharges coming from enclosed
pressurized process equipment. The collected gases are then sent to a
thermal incinerator. Uses a surface condenser after the vacuum system
on the reactor. Uses a surface condenser after the vacuum system
associated with the thin film evaporator system.
A-3
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Facility AR:
ABS
Facility AU:
ABS & MABS
Facility Y:
ABS & SAN
Facility AA:
PS, ABS, &
SAN
Facility AM:
ABS, SAN & PS
Made a formulation change to increase conversion of monomers. Uses
a packed absorption column on reactor system. Uses a catalytic
incinerator for exhausts from absorber, latex treatment system, and
resin dewatering rotary filter.
Replaced rotary dryer with fluid bed dryer. Has a fume burner
(catalytic incinerator) on all vents in the process. Increased monomer
conversion. Plans to phase out use of open top reactors.
ABS: Uses closed hoods on the extrusion purge bin and pellet dryer
and a suspended hood on the extrusion pelletizer. Uses a steam
assisted flare on a knockout drum and the charge/purge and strip tank
associated with this drum. Uses a venturi scrubber on product drying-
cyclone. Use a baghouse on product drying-rotary dryer. Uses a
surface condenser on a rubber dissolver, initial polymer reactor, and on
a suspension reactor.
SAN: Uses a surface condenser on the reactor. Uses a baghouse on
the rotary dry-dust collector.
ABS: Uses a thermal boiler on feedstock premixing tanks, rubber
dissolvers, reactor charging, distillate recovery tanks, intermediate
storage tank, final product cooling-cooler, final product storage and
drying hold tanks, centrifuge, coagulation, product drying-high and
low vacuum vent, fluid bed and rotary dryers, spent feedstock storage.
Uses a steam assisted flare on the reactors, intermediate product
cooling-cooler, intermediate storage tank. Uses a canopy hood on
diehead/extruder stranding. Uses a vent scrubber on reactor-process
equipment, recycled feedstock storage, and spent feedstock storage
tank-rubber adds. Uses a fume scrubber and thermal oxidizer on
feedstock storage tank-rubber slurry and product stranding-extruder.
SAN: Uses a thermal boiler on feedstock premixing, feedstock
recovery, reactor system, product hold tanks, and spent monomer
storage tanks. Uses a canopy hood on die heads/extruder stranding.
Polystyrene processes: Uses a canopy hood on the die heads. Uses
thermal boiler on reactor-process equipment and spent feedstock storage
tank.
SAN: Uses a packed tower scrubber in the devolatilization area for
material recovery. Uses a cyclone on finishing operations.
ABS: Uses a packed absorption tower on the feed system. Uses a
demister filter on devolatilization and pelletizing.
PS: Uses process heaters (thermal incineration) as emission control
devices on the majority of the process tanks and equipment.
A-4
-------
Facility AL: PS: Uses a condenser on part of the emissions from devolatilizer and
ABS & PS pelletizer and use two condensers on the other pan. Uses a thermal
boiler on the condenser exhausts. Uses a demister element on the die.
ABS: Uses condensers in the devolatilization and palletizing areas.
Uses an industrial boiler on the feed preparation and the condensers
associated with the devolatilization and pelletizing areas. Uses a
demister element on the die.
Facility AN: PS: Uses a burner on the polymerization and devolatilization
PS & ABS emissions. Uses a demister filter on pelletizing.
ABS: Uses a burner on devolatilization. Uses a demister filter on
pelletizing.
Facility AQ: Uses process heater on exhausts from condenser off stripper and reactor
PS & ABS and exhaust from feed preparation. Uses a demister on die die.
Facility A: Has one process vent to the atmosphere, which is from the first stage
PS reactor. The condensate from a process stripper is recycled to the
ethylbenzene tank. Vapors from the tower in the continuous
polystyrene process are recycled to the ethylbenzene tank. Vapors
from die tower are recycled to the first stage reactor.
Facility B: All vessels are vented into a vapor recovery unit. The vapor recovery
PS unit consists of a 3 stage vapor condensing/recovery system. The
temperature of the HAP saturated air is progressively lowered as the
gaseous mixture passes through the three condensers. The condensate
is then recycled back to the raw material storage tanks.
Facility C: Uses thermal incineration on the emissions from the reactors.
PS
Facility D: Uses a surface condenser on the reactor and on the vacuum flashing
PS and reactor condenser units. Has a central vacuum system followed by
a recovery unit in which one solution from the recovery is sent to
styrene and toluene storage. The other solution from the recovery is
sent to off-site wastewater handling.
Facility E: Some fugitives are captured in a building vent. Uses an exhaust duct
PS manifold to all reactors. Uses condensers that are part of the
devolatilization area, which is under vacuum.
Facility F: Mass: A portion of ethylbenzene and styrene from the devolatilization
PS area is recycled. The devolatilization system is operated under a
vacuum. Has ceiling and wall fans throughout the process rooms. Has
a canopy hood over the extruder die outlet;,. .,
Suspension: Has a canopy hood over each 'reactor manway.
A-5
-------
Facility I:
PS
Facility K:
PS
Facility L:
PS
Facility O:
PS
Facility P:
PS
Facility R:
PS
Facility S:
PS
Facility Z:
PS
Facility AB:
PS
Facility AD:
PS
Facility AE:
PS
Facility AH:
PS
Has a condenser on their devolatilization step for one of their process
lines. Has suspended hoods on the die heads.
Has a packed bed scrubber on their organic trap system. Has a
countercurrent liquid spray scrubber on one of their extrusion baths.
Has a mist coalescer condenser on a different extrusion bath.
Vapor streams are hard-piped and directed to process heaters for
destruction. The process heater is fired on purged monomer.
Uses reverse osmosis treatment to reduce number of deionizer
regenerations. Deionizer is used on the acid between storage and
entering the mix tank.
Continuous PS: Uses a fume scrubber on the die heads. Uses surface
condensers on the boiling reactor and the devolatilization system. Uses
a surface condenser on the styrene mixture tank from devolatization and
condensers before the spent tank.
Suspension PS: Uses surface condensers on the prepolymerizer reactor
and the suspension reactor.
Uses surface condensers on the polymerization reactors and the
devolatilizers.
General Purpose PS: Uses a high energy ejector type scrubber on the
extrusion die fume exhaust. Use a surface condenser on all of the
reactors.
Continuous High Impact PS: Uses a high energy ejector type scrubber
on the granulation/pelletizer. Uses surface condensers on the
prepolymerizer reactors and on the devolatilizers from reactors.
Has a slot hood for each ventilation system.
Information is confidential.
Uses an electrostatic precipitator on extrusion. Has a vapor recovery
system on processing.
Uses an electrostatic precipitator on the die head extrusion cycle. Uses
a surface condenser on devolatilization system. Uses a surface
condenser on reactor and holding tank. Uses vapor recovery in each
area.
Uses a forced draft hood and an electrostatic precipitator on the die
head/extruder quench system. Uses a surface condenser on the
devolatilizer and the condensate recovery unit.
A-6
-------
Facility AI:
PS
Facility AJ:
PS
Facility AO:
PS
Facility AP:
PS
Facility M:
PS & EPS
Facility AF:
PS & EPS
Facility AG:
EPS
Facility AT:
PS&
ASA/AMSAN
Facility AS:
SAN
Facility G:
MBS
Facility T:
MBS
Uses a forced draft hood and an electrostatic prccipitator on the die
head/extruder quench system. Uses a surface condenser on the reactor
and the devolatilizer.
Uses a surface condenser on material recovery-devolatilization area.
Use a demister vessel on a different devolatilization area. Rubber
dissolver and feed tank are completely sealed and fully insulated. They
are maintained under constant pressure.
Uses a demisting element on die exhaust hoods for polymer dies and
pelletizing. Uses lower temperature to reduce emissions from
monomer recovery from monomer separation off reactor system.
Uses a demister on the die vent.
Uses reverse osmosis treatment to reduce number of deionizer
regenerations. Deionizer is used on the acid between storage and
entering the mix tank.
Uses a dedicated condenser on each polystyrene reactor vent. Uses a
venturi scrubber on the expandable polystyrene wash kettle.
Uses carbon adsorption systems in addition to surface condensers on
the reactors.
PS: Emissions from vacuum system appear to have a brine condenser
and an hydrotherm hot oil heater on them. Uses a carbon adsorption
system on extruder, slurry drum, feed filters before extrusion, product
kneaders before extrusion, and extrusion vents.
ASA/AMSAN: Uses a packed bed scrubber and a thermal afterburner
on reactor for ASA, reactor for AMSAN, water from vacuum jet vent
condenser, water from suspension reactor, water from reactor for ASA,
water from centrifuge, liquid from scrubber to reactor. Uses carbon
adsorption on extruder and on dryer.
Improved vent condenser efficiency by increasing cooling capacity.
Switched monomer service pumps to canned pumps. Increased purity
of styrene monomer. Uses a thermal incinerator on the condensers
used with the reactor and devolatilizer area. Uses a cyclone dust
collector on dryer.
Has a steam assisted flare on the butadiene purification-inhibitor
stripping and on the graft and rubber reactors. Use pressure tanks with
rupture disks for the monomer mix systems.
Reaction conditions were changed to drive die reaction closer to
completion. A natural gas fueled fire tube boiler is used on most of
the exhausts from the process. The reactor waste gas enters the boiler
through the burner in a separate fuel line.
A-7
-------
Facility AC: Uses a venturi scrubber on reactor tanks and mix/feed tanks. Uses a
MBS no assist flare on the reactor. Use a gas-fired boiler on a gas-fired
furnace on the dryer emissions.
Facility W: Uses vapor recovery on the process lines. Has a closed hood on each
NITRILE of the screening lines. Has a packed bed scrubber on each or the
screening areas. Has a baghouse on a new fines dryer. Uses a thermal
incineration on the vacuum pumps associated with the reactors-
condensers from the process lines.
Facility U: Has water cooled condensers on the reactors which are considered part
SAC of the process. Has water cooled condensers ont he thin tanks which
are considered part of the process. All vessels from this process feed
into a tank which represents the final control device acts as an air
cooled condensers. In addition, the facility is relatively new and has
been designed to have a minimal amount of HAP material entering any
waste stream.
Facility V: Has a packed bed scrubber on two reactors. Uses another packed bed
SAE & SAC scrubber on another reactor. Uses a surface condenser on the prefilters
and a scrubber on the feed tanks. Uses surface condensers on the
reactor systems and on the reactors and the strip tank. Has lowered the
purge rates of he inert gas on the exhaust from one of the reactors and
has decreased inert gas flow on one of the tanks.
Uses condensers on the reactors.
Has a barometric condensers on condenser jets, and reactor jets and
condensers. Some of the barometric condensers are used in series.
Uses thermal incineration on four preheater surge bins. Uses thermal
incineration on reactors and seal tanks from the process lines and one
line from the knock-out tank.
Facility AX: Uses venturi scrubbers on Line 1 vacuum systems. Uses thermal
PET incineration on refining and vacuum systems on Line 2. Uses a packed
bed scrubber on refining and vacuum systems on Line 3. Uses a
packed bed scrubber on reaction and drying on Line 4. Uses catalytic
incineration on reaction and drying on Line 5. Uses a venturi scrubber
on reaction and drying on Line 6.
Facility BA: Uses scrubbers on distillation, vacuum system, and solid state reactor
PET associated with continuous TPA process. Uses condenser associated
with continuous TPA process.
DMT Batch: Uses scrubbers on gas-solid reactor, ethylene glycol
recovery and distillation, and sludge trailer loading.
Facility AK:
SAC
Facility AV:
PET
A-8
-------
Facility BA: DMT Continuous: Uses scrubbers on methanol recovery condenser,
PET vacuum system, and ethylene glycol tanks. Uses heat exchanger on
ethylene glycol refining columns. Uses a scrubber on the solid state
reactor. Uses a scrubber on the ethylene glycol sludge handling.
Facility BC: Uses a slot hood on the ethylene glycol process tanks. Uses a thermal
PET incinerator on the organic stripper column.
Facility BD: Uses condenser on the primary esterifiers and esterification process.
PET Uses a glycol scrubber on the esterification process.
Facility BE: Uses a condenser on the esterification process and vacuum pump.
PET Maximized flow of process water to distillation column to reduce
ethylene glycol emissions from the process cooling tower.
Facility BF: Uses a thermal incinerator on the reactor vents, vacuum pump, and
PET crystalizer/cyclones.
WASTEWATER
Facility X:
ABS
Facility AM:
ABS, SAN, &
PS
Facility L:
PS
Facility AB:
PS
Facility AT:
PS&
ASA/AMSAN
Facility AS:
SAN
Facility T:
MBS
Facility W:
Nitrile
Facility AK:
SAC
Facility BD:
PET
Emissions from process water sump is sent to the gas collection system
and then to the thermal incinerator.
Aqueous waste is transferred by truck to wastewater treatment facility.
Uses a carbon filter to treat wastewater.
Uses a carbon filter to treat wastewater.
Uses two packed towers on decanter. Uses two packed towers on all
streams from ASA/AMSAN.
Collects wastewater and send off-site for disposal.
Has covered pits and the wastewater is sent to an industrial wastewater
complex for treatment.
Has two wastewater stripper columns that can each process wastewater
from either process line.
Uses a steam stripper after their adjustment tanks in their wastewater
treatment system.
. -li .-. .
Dioxane recovery project to reduce emissions from wastewater.
A-9
-------
WASTE
Facility AM:
ABS, SAN, &
PS
Facility AN:
PS & ABS
Facility AS:
SAN
Facility T:
MBS
Facility U:
SAC
Facility BE:
PET
Incinerates emissions from waste.
Some waste is treated on-site by burning in a boiler. All other waste
streams are packaged and shipped off-site for incineration.
Has some RCRA waste but stored in tanks with any emissions being
incinerated.
Collected waste monomer is sent off-site for disposal.
Uses a condenser on a liquid waste stream.
Uses wall fans in the wasted handling area.
Equipment Leaks
Facility AA: Upgraded equipment maintenance to reduce fugitive leaks in production
PS, ABS, & area.
SAN
Facility AL: Uses some sealless pumps and closed sample systems.
ABS & PS
Facility AN: Uses some sealless pumps.
PS & ABS
Facility AQ: Uses some sealless pumps.
PS & ABS
A-10
-------
ATTACHMENT B
SUMMARY OF LDAR PROGRAMS AT
STYRENE-BASED RESIN FACILITIES
B-l
-------
ABS - EQUIPMENT LEAKS : 12/29/93
CONTROLS?
FACILITY
X Monthly LOAR - AN only
Monthly LOAR - AN only
VMkly vis, nonthly LDAR - AN
• •
Mo detectable emissions
Csps, etc.
Barrier fluids, ttc
Closed purge/vent
Valves, Gas
Valves, LL
Valves. HL
Puips, LL
Punps, HU
PROS
DELS
Conpressors
Sam. Conns.
Flanges
TOTALS
Monthly LDAR at 10000 pom
Monthly LDAR at 10000 ppm
Weekly vis, Monthly LDAR at 10
• •
No detectable emissions
Caps, etc
Barrier fluids.
Closed purge/vent
inspect as suspect
TOTALS
Y Nonthly LDAR at 10000 ppm
Nonthly LDAR at 10000 ppn
• •
Weekly vis, Monthly LDAR
• • •
No detectable emissions; CVS
Caps, etc
Barrier fluids
Closed purge/vent
inspect as suspect
None TOTALS
AA Nonthly LDAR 81000 ppn LD
Month/quart LDAR 81000 ppn LD
»•
Month/quart. LDAR a 1000 ppn L
• •
No detectable emissions
Caps, etc.
Barrier fluids, etc
Closed purge/vent
Annual at 10000 ppm LD
Valves, Gas
Valves, LL
Valves, HL
Mips, LL
Pups, HL
PRDs
OELs
Coipressors
San. Conns.
Flanges
Valves, Gas
Valves. LL
Valves, HL
Pups. LL
Pumps, HL
PRDs
OELS
Coipressors
Se*. Conns.
Flanges
Valves, Gas
Valves, LL
Valves, HL
Punps, LL
Putps. NL
PRDs
OELs
Compressors
Sam. Conns.
Flanges
B-2
-------
ABS - EQUIPMENT LEAKS : 12/39/93
AA Monthly LDAR 91000 ppm LD
AA
AM
TOTALS.
Month/quart LDAR 81000 ppn LD
Month/quart. LDAR 8 1000 ppra L
Ho detectable emissions
Caps, etc.
Barrier fluids, etc
Closed purge/vent
Annual at 10000 ppn LD
Valves, Gas
Valves, LL
Valves, HL
Pumps, LL
Pumps, HL
PRDs
DELS
Compressors
San. Conns.
Flanges
TOTALS
Month/quart. LDAR a 1000 ppn L
• Month/quart. LDAR 8 1000 ppn L
Ho detectable emissions
Caps, etc.
Barrier fluids, etc
Closed purge/vent
Annualy at 10000 ppm LD
TOTALS
AL Quarterly LDAR at 10000
Quarterly LDAR at 10000
Q LDAR at 10000; 12 sealless
6 RDI/RD; 0 LDAR at 10000; aft
OLBs
Quarterly LDAR at 10000
1 w/CSS; none
Sight, smell, sound
TOTALS
Q LDAR at 10000 ppm
• •
Q LDAR at 10000 ppm
6 w/RDI; Q at 10000
OLBs etc
• •
Q LDAR at 10000 ppm
Valves, Gas
Valves, LL
Valves, HL
Pumps, LL
Pumps, NL
PROs
OELs
Compressors
Sam. Conns.
Flanges
Valves, Gas
Valves, LL
Valves, ML
Pumps, IL
Punps, ML
PROS
OELs
Compressors
Sam. Conns.
Flanges
Valves, Gas
Valves. LL
Valves, NL
Pumps, LL
Pumps, HL
PRDs
OELS
Compressors
Sam. Corns.
Flanges
TOTALS
B-3
-------
ABS • EQUIPMENT LEAKS : 12/29/93
AN Quarterly LDAR at 1000 ppro
Quarterly LDAR at 1000 ppm
• »
19 seolless; quarterly LDAR at
• •
6 with RDs; Quart LOAR at 200
OLBS; Q LDAR at 1000
Under vacua
OLBS; Q LDAR at 1000
Quarterly LDAR at 1000 ppm
AU
TOTALS
AQ Quarterly LDAR at 10000
Quarterly LDAR at 10000
5 seal less; wkly vis., Q LDAR
6 w/RDs; quarterly LDAR
OLBs
Quarterly LDAR at 10000
TOTALS
Quarterly LDAR at 10000, 12 se
Wkly Inspes; anth LDAR -10000
RDIs. 19 to controls (98X)
AU OLBs
Weekly Inspections
Annual Inspections at 500
TOTALS
AR Monthly LDAR at 500 ppa (NON)
Monthly LDAR at 500 ppa (ROM)
Monthly LDAR at 500 ppa (HON)
Caps, etc.
Closed purge <2 of the four)
Annual LDAR - at 500 ppa
TOTALS
AM 40 LOT
1ft sealless
Valves, Gas
Valves. LL
Valves, HI
Pumps, LL
Pumps, HL
PROS
OELs
Compressors
Sam. Conns.
Flanges
Valves, Gas
Valves, LL
Valves, HL
Pumps. LL
Pups, HL
PRDs
OELs
Compressors
Sam. Corns.
Flanges
Valves, Gas
Valves, LL
Valves, HL
Punps, LL
Pumps. HL
PRDs
OELs
Compressors
San. Corns.
Flanges
Valves, Gas
Valves, LL
Valves. HL
Puips. LL
Punps, HL
PRDs
OELs
Compressors
Saa. corns.
Flanges
Valves, Gas
Valves. LL
B-4
-------
ABS - EQUIPMENT LEAKS : 12/29/93
Valves, HL
8 - DNS; 6 sealless Pumps, LL
Pumps, HL
PROS
OLBs DELS
8 - DMS Compressors
CVS for 3 Sam. Conns.
Eliminated about 5000 Flanges
TOTALS
B-5
-------
MBS EQUIPMENT LEAKS • 12/29/93
CONTROLS?
FACILITY
Uk vis., quart. LDAR at 10000
Uk vis., quart. LDAR at 10000
Uk vis., quart. LOAR at 10000
» •
RDIs
Caps, etc.
DBVs
TOTALS
Monthly LDAR at 100 ppn
Monthly LDAR at 100 ppn
»•
Monthly at 100 ppn
ROIs
caps etc
Q LDAR at 100 ppn; barrier flu
Purge
Annual at 100 ppn
TOTALS
AC
RDIs on 6
Valves, Cas
Valves, LL
Valves, HL
Puips, LL
Pumps, ML
PRDs
OELs
Compressors
Sam. Conns.
Flanges
Valves, Gas
Valves, LL
Valves, ML
Punps, LL
Pumps, ML
PRDs
OELs
Compressors
San. Conns.
. Flanges
Valves, Gas
Valves, LL
Valves, HL
Purps, IL
Pumps, ML
PRDs
OELs
Compressors
Sam. Conns.
Flanges
TOTALS
B-6
-------
NITRILE EQUIPMENT LEAKS - 12/29/93
CONTROLS?
Valves, Gas
Quarterly LDAR at 10000 Valves, LI
Valves, KL
Quarterly LDAR at 500 Punps, LL
Punps, HL
PROs
OELs
Compressors
Sam. Conns.
Quarterly LDAR at 10000 Flanges
TOTALS
B-7
-------
POLYSTYRENE EQUIPMENT LEAKS • CONTINUOUS PLANTS
FACILITY
LOAR PROGRAM ?
COMPONENT
A Quarterly LDAR nt 10000
Quarterly LDAR at 10000
Ueekly vis, quarterly LDAR at 10000
Quarterly LDAR at 10000
Seal all
if see leaking, fix
If see leaking, fix
if see leaking, fix
Valves, Gas
Valves, LL
Valves, HL
Punps, LL
Piaps, HL
PRDs
OELs
Compressors
Sani. Corns.
Flanges
Quarterly LDAR at 10000
Quarterly LDAR at 10000
Ueekly via, quarterly LDAR at 10000
Quarterly LDAR at 10000
Seal all
if see leaking, fix
if see leaking, fix
if see leaking, fix
Valves, Gas
Valves, LI
Valves, HL
Punps, LL
Punps, HL
PRDs
OELs
Compressors
San. Conns.
Flanges
B "no evidence of leaks"
"no evidence of leaks"
--
•no evidence of leaks"
--
"no evidence of leaks"
Seal all
If see leaking, fix
if see leaking, fix
•no evidence of leaks"
Valves, Gas
Valves, LL
Valves, HL
Puips, LL
Punps, HL
PRDs
OELs
Compressors
San. Conns.
Flanges
Valves, Gas
Valves, LL
Valves, HL
Punps. LL
Punps. HL
PRDs
OELs
Coapressors
Saa. Conns.
Flanges
B-8
-------
POLYSTYRENE EQUIPMENT LEAKS • CONTINUOUS PLANTS
FACILITY
LDAR PROGRAM ?
COMPONENT
Quarterly at 1,000 ppn
Quarterly at 1,000 ppn
Weekly visual; Monthly at 10000
Valves, Gas
Valves, LL
Valves, HL
Punpa, LL
Putps, HL
quarterly at 1000 and per slght/snel I/sound PROs
OLBs OELs
barriers to enfssions Compressors
San. Conns.
fix if evidence of leaks Flanges
P Quarterly at 10,000 ppn
Quarterly at 10,000 ppn •
Weekly vis. monthly LDAR at 10000
• no detectable emissions
OLBs
barriers to Missions
closed purge/vent
annual at 10000
Valves, Gas
Valves, LL
Valves. HL
Pinps. LL
Putps, HL
PROS
OELs
Compressors
Sam. Conns.
Flanges
R Quarterly LDAR - 10000 ppn LD
Quarterly LDAR - 10000 ppn LD
Monthly LDAR • 10000 ppn
• *
Annual LDM • 10000 ppn LD
Capped
Annual LDAR - 10000 ppn LD
Annual LDAR • 10000 ppn LD
Valves, Gas
Valves, LL
Valves, HL
Punpa. LL
Pumps, HL
PROS
OELs
Compressors
San, Corns.
Flanges
S Uncontrolled
facility
Valves, Gas
Valves, LL
Valves. HL
Pwps, LL
Pusps. HL
PROS
OELs
Conpressors
San. Conns.
Flanges
B-9
-------
POLYSTYRENE EQUIPMENT LEAKS • CONTINUOUS PLANTS
FACILITY
LDAR PROGRAM 7
COMPONENT
Monthly at 100 ppm
Monthly ax 500 ppm
Quarterly at 100 ppra
Valves, Gas
Valves; LL
Valves, HL
Pumps, u.
Pumps. HL
PROS
DELS
Compressors
Sam. Conns.
Flanges
Monthly at 100 ppn
Monthly at 500 ppm
Quarterly at 100 ppn
Valves, Gas
Valves, LL
Valves, HL
Pimps, .LL
Pumps, HL
PROS
DELS
Compressors
San. Conns.
Flanges
Valves, Gas
Monthly LDAR at 100 ppn Valves, LL
Valves, HL
Monthly - pumps; quart, agitators at 100 pp Pumps, LL
Pumps, HL
Quarterly LDAR at 10000 PRDs
Seal all OELs
if see leaking, fix Conpressors
if see leaking, fix San. Conns.
quarterly at 100 ppn Flanges
K Quarterly LDAR at 10000
Quarterly LDAR at 10000
*•
Weekly vis, quarterly LDAR at 10000
Quarterly LDAR at 10000
Seal all
if see leaking, fix
if see leaking, fix
Valves, Gas
Valves. LL
Valves, HL
Pu*pe. It
Pumps, HL
PRDs
OELs
Conpressors
San. Corns.
B-10
-------
POLYSTYRENE EQUIPMENT LEAKS - CONTINUOUS PLANTS
FACILITY
LDAR PROGRAM 7
COMPONENT
quarterly it 100 ppm
Flanges
AA
Monthly LDAR at 1000 ppm
Weekly vis, monthly LDAR at 1000
*»
capped etc
Annual at 10000 ppm
Valves, Gas
Valves, LL
Valves, HL
Pumps, LL
Punps. ML
PROs
OELs
Compressors
Sam. Conns.
Flanges
AB Quarterly LDAR at 10000
Quarterly LDAR at 10000
• •
Quarterly LDAR at 10000
Quarterly LDAR at 10000
OLBs
Quarterly LDAR at 10000
Valves, Gas
Valves, LL
Valves, HL
Pups, LL
Pups, HL
PROs
OELS
Compressors
Sam. Conns.
Flanges
AD Maintain less than 0.5X at 10000 ppm
Maintain less than 0.5X at 10000 ppm
Nafntafn less than IX at 10000 ppm
Maintain less than 1X at 10000 ppm
Capped etc.
Maintain less than IX at 10000 ppm
Maintain less than 1X at 10000 ppm
Maintain less than 1X at 10000 ppm
Valves, Gas
Valves, LL
Valves, HL
Punps. LL
Pimps, HL
PROS
OELs
Compressors
San. Conns.
Flanges
AM 0 LDAR at 10000
Q LDAR at 10000
0 LDAR at 10000; wkly vis.
Q LDAR at 10000
Caps, etc.
Q LDAR at 10000
Valves, Gas
Valves, LL
Valves, HL
Punps. LL
Pumps, HL
PROs
OELs
Compressors
B-ll
-------
POLYSTYRENE EQUIPMENT LEAKS • CONTINUOUS PLANTS
FACILITY
LDAR PROGRAM ?
COMPONENT
Sam. Corns.
Flanges
AJ Q LDAR and M LDAR at 10000
0 LDAR and N LDAR at 10000
mm
Q LDAR and M LDAR at 10000
• •
Many with rupturt dfsks
mm
Mont/Annual at 10,000 ppn
Valves, Gas
Valves, LL
Valves, HL
Punps. LL
Punps, NL
PRDs
DELS
Compressors
San. Conns.
Flanges
AL 0 LDAR at 10.000
Q LDAR at 10,000
Weekly vis, Q LDAR at 10000
RDIs on 6
OLBs
Q LDAR. at 10.000
CCS for one
Valves, Gas
Valves, IL
Valves. HL
Punps. LL
Punps, HL
PRDs
OElS
Compressors
San. Conns.
Flanges
AN Quarterly LDAR at 1000
Quarterly LDAR at 1000
Quarterly LDAR at 1000
6 U/ROIs; Q LDAR at 200
OLBS
Under vacuu*
OLBa
Q LDAR at 1000
Valves, Gas
Valves, LL
Valves, HL
Punps, LL
Punps. HL
PRDs
DELS
Compressors
Sam. Conns.
Flanges
AQ Quarterly LDAR at 10000
Quarterly LOAR at 10000.
»•
weekly vts. Q LOAR at 10000; 7 seal less
7 H/RDts
OLBs
Valves, Gas
Valves. LL
Valves. ML
Puaps. LL
Punps. NL
PRDs
OELs
B-12
-------
POLYSTYRENE EQUIPMENT LEAKS - CONTINUOUS PLANTS
FACILITY
LDAR PROGRAM ?
COMPONENT
••
Q LDAR at 10000
**
AN Q LOAR at 10000
Q LDAR at 10000
—
0 LDAR at 10000; 2 with DMS
• •
2 with RDIs, annual LDAR at 10000
alt capped
*»
Q LDAR at 10000
0 LDAR at 10000
AO
Monthly at 10000 ppm
• •
Monthly at 10000 ppm
• •
3 with RDIs; annual at 10000
all capped
••
annual survey at 10000
annual -survey at 10000
AP
Maintain less than 2X leakers at 10000
..
0 LDAR at 10000; 17 H/DMS
'
RDIs
all plugged
-•
annual survey at 10000
""
AT quarterly at 10000 ppa>
quarterly at 10000 ppn
-•
quarterly at 10000 ppn
• -
RDIs, quarterly at 10000
Compressors
San. Conns.
Flanges
Valves, Gss
Valves, LL
Valves, HL
Punps, LL
Pumps, NL
PRDs
OELs
Compressors
San. Conns.
Flanges
Valves, Gas
Valves, LL
Valves, HL
Punps, LI
Punps, HL
PRDs
OELs
Compressor*
San. Conns.
Flanges
• Valves, Gas
Valves, LL
Valves, HL
Puaps. LL
Punps, HL
PRDs
OELs
Compressors
Saai. Conns.
Flanges
Valves, Gas
Valves. LL
Valves, HL
Puips, 11
Puips. HL
PRDs
B-13
-------
POLYSTYRENE EQUIPMENT LEAKS - CONTINUOUS PLANTS
FACILITY LDAR PROGRAM 7 COMPONENT
capped OELs
Conpr**tor»
San. Corns.
Flanges
B-14
-------
POLYSTYRENE EQUIPMENT LEAKS - EPS PLANTS
FACILITY
LDAJt PROGRAM ?
COMPONENT
C Quarterly LOAR at 10000
Quarterly LOAR at 10000
Weekly vft, quarterly LDAB at 10000
Quarterly LOAR at 10000
Quarterly LOAR at 10000
Valves, Ga*
Valves, LL
Valves, HL
Pimps, LL
Punps, ML
PHP*
OEL«
Compressor*
San. Conns.
Flanges
A6
Valves, Gas
Valves, LL
Valves, HL
Punps, LL
Pumps, HL
PRDs
OELs
Compressors
Sam. Conns.
Flanges
Monthly at 10000 ppn
Monthly at 10000 pps
Monthly at 10000 pp»
Valves, Gas
Valves, LL
Valves, NL
Puops. LL
Pumps, HL
PRDs
OELS
Compressors
Sam. Conns.
Flanges
S Uncontrolled facility
Valves, Gas
Valves, LL
Valves. HL
Punps. LL
Pusps. HL
PROs
OELs
Compressors
Sail. Conns.
Flanges
B-.15
-------
POLYSTYRENE EQUIPMENT LEAKS - EPS PLANTS
FACILITY
LDAR PROGRAM ?
COMPONENT
M Q LDAR at 10000
Q LOAR at 10000
Q LOAR at 10000; ukly vfs.
• •
Q LDAR at 10000
capped etc.
Q LDAR at 10000
Valves, Gas
Valves, LL
Valves, HI
Pumps, LL
Pumps. HL
PROS
DELS
Conpressors
San. Corns.
Flanges
N Q LDAR at 10000
Q LDAR at 10000
» •
0 LDAR at 10000; ukly vis.
0 LDAR at 10000
capped etc.
Q LDAR at 10000
Valves, Gas
Valves, LL
Valves, HL
Puips. LL
Pumps, HL
PRDs
OELs
Compressors
Sam. Conns.
Flanges
AF Quarterly LDAR at 10000
Quarterly LDAR at 10000
Quarterly LOAR at 10000
Quarterly LDAR at 10000
Valves, Gas
Valves, LL
Valves, HL
Punps, LL
Punps, HL
PRDs
OELs
Conpressors
San. Conns.
Flanges
B-16
-------
POLYSTYRENE EQUIPMENT LEAKS - BATCH PLANTS
FACILITY
LOAR PROGRAM 7
COMPONENT
E Quarterly LDAR at 10000
Quarterly LDAR at 10000
• *
Quarterly LOAR at 10000
• »
Quarterly LDAR at 10000
OLBs
Quarterly LOAR at 10000
Valves, Gas
Valves, LL
Valves, HL
Punps. LL
Punps, HL
PRDs
OELs
Conpressors
Sam. Conns.
Flanges
Valves, Gas
Valves, LL
Valves. HL
Pumps, LL
Punps. HL
PROS
OELs
Compressors
Sam. Conns.
Flanges
P Quarterly at 10,000 ppm
Quarterly at 10,000 ppm
Weekly vis, monthly LDAR at 10000
no detectable emissions
OLBs
barriers to emissions
closed purge/vent
annual at 10000
Valves, Gas
Valves, LL
Valves, HL
Punps, LL
Punps. HL
PRDs
OELs
Conpressors
Sam. Conns.
Flanges
S Uncontrolled
facility
Valves, Gas
Valves. LL
Valves. HL
Punps, LL
Punps, NL
PRDs
OELs
Compressors
Sam. Conns.
Flanges
B-17
-------
POLYSTYRENE EQUIPMENT LEAKS - BATCH PLANTS
FACILITY
LOAR PROGRAM ?
COMPONENT
M Q LDAR at 10000
Q LDAR at 10000
--
Q LDAR at 10000; wkly vis.
--
Q LDAR at 10000
capped etc.
Q LDAR at 10000
--
—
H Q LDAR at 10000
0 LDAR at 10000
• *
Q LDAR at 10000; wkly vis.
••
Q LDAR at 10000
capped etc.
Q LDAR at 10000
--
••
2
• •
~
«
•-
• •
--
• •
--
••
AE Maintain less than 0.5X at 10000 ppn
Maintain less than 0.5X at 10000 ppn
--
Maintain less than 1X at 10000 ppm
—
Maintain less than U at 10000 ppm
Capped etc.
Maintain less than 1X at 10000 ppm
Maintain lest than IX at 10000 ppm
Maintain less than 1X at 10000 ppm
Valves, Gas
Valves, LL
Valves, HL
Puips, LL
Pumps, HL
PROs
OELs
Compressors
San. Conns.
Flanges
Valves. Gas
Valves, LL
Valves, HL
Pimps, LL
Pumps, HL
PRDs
OELs
Compressors
Sam. Conns.
Flanges
Valves. Gas
Valves, LL
Valves, HL
Punps. LL
Pumps, ML
PRDs
OELs
Compressors
San. Conns.
Flanges
Valves, Gas
Valves, LL
Valves, HL
Puaps. LL
Pu«ps. HL
PRDs
OELs
Compressors
Sen. Conns •
Flanges
B-18
-------
POLYSTYRENE EQUIPMENT LEAKS • BATCH PLANTS
FACILITY IDAR PROGRAM ? COMPONENT
AI Q LOAR at 10000 Valves, Gas
Q LDAR at 10000 Valves, LL
Valves, ML
Q LOAR at 10000; wkly vis. . Punps, LL
Punps, HL
Q LOAR at 10000 PRDs
Caps, etc. OELs
Q LOAR at 10000 Compressors
Sam. Conns.
Flanges
AF -- Valves, Gas
Valves, LL
Valves, HL
Punps, LL
Pups, HL
PRDs
OELs
Compressors
Sam. Corns.
Flanges
B-19
-------
SAC EQUIPMENT LEAKS : 12/29/93
CONTROLS?
FACILITY
TOTALS
V Monthly LOAR at 10000
Monthly LOAR at 10000
• •
Monthly LOAR at 10000
Rupture disks
Caps, etc.
TOTALS
Valves, Gas
Valves, LL
Valves, HL
Punps. LL
Pups. HL
PROS
OELs
Compressors
Sam. Conns.
Flanges
Valves, Gas
Valves, LL
Valves, HL
Puaps, LL
Punps, ML
PROS
OELs
Conpressors
Sam. Conns.
Flanges
Valves, Gas
Valves, LL
Valves. NL
Punps, LL
Pinps, NL
PROs
OELs
Conpressors
San. Conns.
Flanges
TOTALS
B-2Q
-------
SAN AND AH/SAN/ASA EQUIPMENT LEAKS : 12/29/93
CONTROLS?
FACILITY PROCESS TYPE
AS
SAM • ContinuousOuarterty LDAR at 1000 ppm
Quart/Annual LDAR at 1000 ppn
DMS, quarterly LDAR at 1000 pp
20 to closed vent systen/devic
Caps, etc.
Quart/annual LDAR at 1000 ppn
TOTALS
SAN - Batch Monthly LDAR at 10000 ppm
Monthly LDAR at 10000 ppm
• •
Weekly via. monthly LDAR
No detectable emissions
Caps, etc.
Barrier fluids, etc
Closed purge/vent
Inspect as suspect
TOTALS
AM SAN • Continuous
Q LDAR at 500 ppm
Q LDAR at 500; 2 DMS
RDIs on 6; Q LDAR at 500
Number of OELs nAU capped
Isolok
Q LDAR at 500
TOTALS
AA SAM - batch
Monthly LDAR at 10000
Month/quart. LDAR 81000 ppn LD
Weekly vfs. Monthly LDAR 8 100
Mo detectable emissions
Caps, etc.
Barrier fluids, etc
Closed purge/vent
Annual at 1000 ppn LD
Valves, Gas
Valves, LL
Valves, NL
Pumps, LL
Pumps, HL
PRDs
OELs
Compressors
San. Conns.
Flanges
Valves, Gas
Valves. LL
Valves, HL
Pumps, LL
Pumps, HL
PRDs
OELs
Compressors
San. Conns.
Flanges
Valves, Gas
Valves, LL
Valves, HL
Pumps, LL
Pumps, HL
PRDs
OELs
Compressors
Sam. Conns.
Flanges
Valves, Gas
Valves, LL
Valves, HL
Pumps, LL
Pumps, HL
PRDs
OELs
Compressors
Sam. Conns.
Flanges
B-21
-------
SAN AND AM/SAN/ASA EQUIPMENT LEAKS : 12/29/93
TOTALS
AA SAN - continuous
AT ASA/AM/SAN
Month/quart LOAR at 1000 ppm
Month/quart. LDAR at 1000 ppm
No detectable emissions
Cape, etc.
Barrier fluids, etc
Closed purge/vent
Annual at 1000 ppm LD
TOTALS
the entire
facility la equipped
with 24 continuous
area monitors for
acrylonltrlle
and ttyrene with a
detection level
of 2 ppm
Valves, Gas
Valves, LL
Valves, HL
Pumps. LU
Pumps, HL
PRDs
DELS
Compressors
Sam. Conns.
Flanges
Valves. Gas
Valves, LL
Valves, HL
Punps. U
Punps. HL
PRDs
OELs
Compressors
Sam. Conns.
Flanges
TOTALS
B-22
-------
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: Les Evans
US Environmental Protection Agency
FROM: Ken Meardon
Pacific Environmental Services
DATE: July 21, 1994
SUBJECT: Collocation of Group IV Resins Facilities
Per your request, I have assembled information on the collocation of the production of
the resins that comprise the Group IV resins project. Table 1 summarizes the results of this
effort. Attached is a table that details the collocation.
As seen in Table 1, most of the PET (15 out of 23) and PS (24 out of 35) facilities are
not collocated. The three MBS facilities and the one NTTRILE facility are not collocated.
•Seven of 9 ABS facilities are collocated, 4 of the 5 SAN facilities are collocated, and the one
MABS facility is collocated. There is only one instance where there is a collocation between
PET and a styrene-based resin. For PET plants, all other cases of collocation are between
.different processes for producing PET. For the styrene-based resins, collocations occur between
source categories as well as among processes within a source category.
Please call me if you have any questions.
WASHINGTON UC • 'WSF Wll TP.IANC.tE I'ARK Nf.-LOT. ANGELES OA- CINCINNATI OH
-------
TABLE 1. SUMMARY OF COLLOCATIONS - GROUP IV RESINS
SOURCE
CATEGORY
PET
PS
MBS
SAN
ASA/AMSAN
ABS
MABS
Nitrile
SUBCATEGORY3
AH processes
TPA, C
TPA, B
DMT, C
DMT, B
AH processes
C
B
EPS
All processes
C
B
AH processes
Cm
Ce
Be
Bs
Latex
TOTAL NUMBER
OF FACILITIES
23
12
1
10
10
35
22
11
7
3
5
2
3
1
9
5
2
4
2
1
I
1
NUMBER OF
COLLOCATED
FACILITIES
8
7
1
6
4b
11
8
5C
3
0
4
2
2
1
7
5
1
4
2
0
I
0
NUMBER OF
NON-
COLLOCATED
FACILITIES
15
5
0
4
6
24
14
6
4
3
1
0
1
0
2
0
1
0
0
1
0
1
b
c
TPA = terephthalic acid; DMT = dimethyl terephthalate; Cm - continuous mass
Ce = continuous emulsion; Be = batch emulsion; Bs = batch suspension
C = continuous; B = batch; EPS = expandable polystyrene.
One facility is collocated with a polystyrene batch process.
One facility is collocated with a PET, DMT-B process.
-------
SUMMARY OF COMPANY AND POLYMERS PRODUCED
AT EACH FACILITY LOCATION
COMPANY
Allied Signal
DuPont
Hoechst Cleanese
ICI Films
Shell
Tennessee Eastman
Carolina Eastman
Eastman Kodak
Wellman
YKK
3M
American Polymers
Amoco Chemical Corp.
Arco Chemical Corp.
BASF Corp.
LOCATION
Moncure
Cooper River
Kinston
Cape Fear
Circleville
Florence
Old Hickory
Brevard
Spartanburg
Salisbury
Greer
Shelby
Fayetteville
Hopewell
Pt. Pleasant
Kingsport
Columbia
Rochester
Palmetto
Macon
Decatur
Greenville
Oxford
Joilet
Torrance
Willow Springs
Painesville
Monaca
Holyoke
Santa Ana
POLYMER(S) PRODUCED*
PET-TPA.C
PET-TPA.C and DMT.C
PET-TPA.C and DMT.C
PET-TPA.C and DMT.C
PET-DMT.C
PET-DMT.C
PET-DMT.C
PET-DMT.C
PET-TPA.C, DMT.C, and DMT-B
PET-TPA,Cb
PET-TPA.C
PET-DMT.B
PET-DMT,Bb
PET-DMT.B
PET-TPA.C; TPA.B; and DMT-Bb
PET-TPA.C; DMT.C; and DMT-B
PET-TPA.C and DMT,Cb
PET-DMT,Bb
PET-TPA.C
PET-TPA.C
PET-DMT, B and PS.B
PET-DMT.B
PS,C and semi-continuous
PS.C
PS,Bs
PS.Bs
EPS.Insitu
EPS.PI and PS.Bs
PS.C
PS.C
-------
SUMMARY OF COMPANY AND POLYMERS PRODUCED
AT EACH FACILITY LOCATION
BASF Corp cont.
BF Goodrich
BP Chemicals
Chevron Chemical
Dart Container Corp.
Dow Chemical
Elf Atochem
Fina Oil & CHemicai Co.
GE Plastics
Hunstman Chemical
Kama
Kaneka Texas Corp.
Monsanto Corp.
Novacor Chemicals
Joilet
South Brunswick
Lowland
Akron
Lima
Marietta
Leola
Ownesboro
Midland
Allyn's Point
Torrance
Hanging Rock
Joilet
Riverside
Carville
Washington, WV
Ottawa
Bay St. Louis
Selkirk
Chesapeake
Belprc
Peru
Rome
Hazelton
Muscatine
Addyston
Decatur- 1
Decatur - 2
Indian Orchard
PS,C
EPS-Insitu
PET-DMT.B
ABS-latex, batch
Nitrite
PS,C
PS,Bs
PS,Bs
ABS,Be; ABS,Cm; SAN.C; and PS.C
ABS,Cm and PS,C
ABS,Cm and PS.C
ABS,Cm and PS,C
PS.C
PS.C
MBS
PS.C
ABS,Be; ABS.Ce; and MABS
ABS,Ce
SAN.C
ASA/AMSAN and PS.C
PS,C and PS.B
PS.C
PS,C; PS,B; and EPS, insitu and PI
EPS, insitu
PS.C
MBS
ABS.Be; ABS.Bs; and SAN.B
ABS,Be; ABS,Bs; ABS,Cm; SAN.B; SAN.C; and PS,C
PS.C
PS.C
PS.C
-------
SUMMARY OF COMPANY AND POLYMERS PRODUCED
AT EACH FACILITY LOCATION
Rohm and Hass
Scott Polymers
Kentucky
Philadelphia
Saginaw - I
Saginaw • 2
Fort Worth
MBS
PS,Bs
EPS, PI and PS.B
PS,Bs
EPS.PI
KEY: PET = polyethylene terephthalate
TPA = terephthalic acid
DMT = dimethyl terephthalate
C = continuous
B = batch
PS = polystryene
Bs = batch, suspension
EPS = expandable polystyrene
PI - post-impregnation
Be = batch, emulsion
Ce = continuous, emulsion
Cm - continuous, mass
•These facilities also use a solid state process.
-------
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
DATE: December 21, 1994
SUBJECT: Estimated New Growth for Group IV Resins Sources
The purpose of this memo is to describe how new growth capacities for each source
category were estimated and which existing facilities were selected to represent that new
growth. PES reviewed the last 12 months of the Chemical Marketing Reporter in an effort
to quantify expected growth for each of the seven source categories that comprise the Group
IV resins. Information was found on ABS, polystyrene, and bottle-grade PET. Attached are
the pages from the CMR that were relevant.
Table 1 summarizes the results of the estimated new growth capacities. Table 2
summarizes those plants selected to reflect new plants that make up the estimated new growth
capacity. The following paragraphs discuss the estimated new growth and the selection of
existing facilities.
Table 1. Estimated New Growth
POLYMER
ABS
SAN
PS
PET
MBS
MASS
NTTRILE
CURRENT INDUSTRY
CAPACITY
(million pounds)
1785
530
6480
15823
64
-
-
AVERAGE ANNUAL
GROWTH RATE
(%)
4
4
3
3-5,10
3
3
3
TOTAL NEW CAPACITY
OVER FIVE YEARS
(mflUon pounds)
386
115
1032
4194
14
—
-
WASHINGTON. D.C. • RESEARCH TRIANGLE PARK. NC • LOS ANGELES. CA • CINCINNATI. OH
-------
Docket No. A-92-45
December 21, 1994
page 2
ABS Resin$
The CMR (3/21/94) projects new growth for ABS at between 3 and 5 percent per year
through 1998. The CMR shows a capacity of 1,785 millions pounds, which is very close to
your estimate of 1,850 million pounds (839 million kilograms). Using the CMR capacity of
1,785 million pounds, a growth rate of 4 percent (the mid-point), and assuming 4 percent per
year through 1999, additional capacity of 386 million pounds would be added over the next
five years.
There are four basic processes for producing ABS - batch, emulsion; batch,
suspension; continuous, emulsion; and continuous, mass. The batch processes comprise
about 30 percent of total capacity and the continuous process the about 70 percent.
Assuming the new growth mirrored the current distribution, about 115 million pounds of
batch capacity and 270 million pounds of continuous capacity are projected.
Based on current distribution of capacity among the four basic process types and the
size of individual facilities, the projected batch capacity could be reasonably represented as
two new facilities, one of each of the two basic batch processes and the projected continuous
capacity could also be represented as two new facilities, also one each of the two basic
continuous facilities. There are three dominant producers of ABS - Dow, GE, and
Monsanto. At least one facility from each of these producers was be selected for the new
growth analysis.
SAN Resins
No information specific to SAN growth was found. However, many facilities that
produce ABS also produce SAN since much of the SAN produced is used as a feedstock in
the production of ABS. Because of this, it may not be unreasonable to assume a similar
growth rate for SAN as above for ABS (i.e., 4 percent per year through 1999). If mis is
done, the total expected increase in capacity is estimated to be about 115 million pounds,
given an initial total capacity of about 530 million pounds.
As for ABS, about 30 of the current capacity is in batch production and about 70
percent in continuous production facilities. Given current facility size, the projected new
growth could be reasonable represented as one larger new plant using a continuous process
(Option 1) or two smaller plants, one using a continuous process and one using a batch
process (Option 2).
There are three facilities that produce SAN using a continuous process, each owned by
a different company. Two of the three facilities are collocated with ABS production. Since
specific information was found for growth in ABS resins and SAN is used as a feedstock to
ABS resins, a preference was made that new growth would occur with a collocated facility.
Of the two collocated continuous facilities, one has a much smaller capacity man the other.
-------
Docket No. A-92-45
December 21, 1994
page 3
Therefore, the larger facility was selected to represent new growth Option 1. This facility is
the Monsanto facility in Addyston, Ohio.
For Option 2, it was assumed that one smaller batch and one smaller continuous
process facility would be selected. Based on relative capacities and the preference for
collocated facilities, the two plants selected were Monsanto, Muscatine (batch) and Dow,
Midland (continuous).
Polystyrene
The CMR (4/25/94) projects new growth for PS at between 2 and 4 percent per year
through 1998. The CMR shows a US capacity of 6,480 millions pounds, which is nearly
identical to your estimate of 6,400 million pounds (2,904 million kilograms). Using the
CMR capacity of 6,480 million pounds, a growth rate of 3 percent (die mid-point), and
assuming 3 percent per year through 1999, additional capacity of 1,032 million pounds
would be added over the next five years.
. Basic processes used for producing general purpose and high impact PS are batch,
suspension; batch, bulk; and continuous. In addition, expandable PS (EPS) is produced
using a batch, in-situ process or a batch process followed by a post-impregnation step. Based
on past information, it is very unlikely that new batch facilities will be built for the
production of general purpose or high impact PS. Thus, it is not unreasonable to assume no
growth through this production process. On the other hand, there may be some growth for
EPS, but no information is available to suggest what a split between EPS and new continuous
PS processes might be. I think it reasonable to assume mat all new growth will be in the
continuous processes.
Based on the above assumptions (1,032 million pounds of new growth all by
continuous processes) and based on current plant size distributions, the new projected growth
would be equivalent to about four new facilities, which could be distributed as one smaller
size facility, two medium size facilities, and one larger size facility. Based on the producers
of PS using continuous processes, the BASF Holyoke facility was selected to represent a new
smaller facility, the Dow Midland and Novacor Decatur facilities to represent the two new
medium sized facilities, and the Chevron Marietta facility to represent the larger facility.
The CMR (9/3/93) projects new growth for solid-state bottle-grade PET resin at about
10 percent through 1997. The CMR shows a capacity for this type resin of 1,000.000
megagrams, which is very close to your estimate of 927,000 Mg (927 million kg). The
CMR does not report any growth information for the other portion of the PET industry.
-------
Docket No. A-92-45
December 21, 1994
page 4
For the solid-state, bottle-grade resins, assuming a 10 percent growth over the next
five years would add 991 million Ibs of capacity, which is essentially a doubling of the
current capacity. Thus, we could use all of the current facilities that produce solid state
resins as representative of new facilities being built over the next five years. This would
cover six facilities that use a TPA, continuous process, three mat use a DMT, continuous
process, one that uses a TPA, batch process, and four that use a DMT, batch process.
For the other PET resin types, I have arbitrarily assumed a 3 to 5 percent per year
growth rate. At 3 percent, this would add about 2,260 million pounds of capacity over the
next five years, which is about IS percent of current capacity. At 5 percent, this would add
about 3,900 million Ibs of capacity over the next five yean, which is about 25 percent of the
current capacity. New facilities are likely to be continuous, and would favor the TPA
process over the DMT process. I think a reasonable assumption would again be a 30/70 split
between DMT/continuous and TPA/continuous, respectively. If this is acceptable, new
DMT/continuous capacity is projected to be about 675 to 1,200 million Ibs and new
TPA/continuous capacity at about 1,600 to 2,700 million Ibs.
Based on current plant size, the 675 to 1,200 million Ibs of DMT/continuous capacity
would be equivalent to about 3 to 5 new plants, and the 1,600 to 2,700 million Ibs of
TPA/continuous capacity, about 6 to 10 new plants. For DMT/continuous processes, 3 for
the 10 facilities are already represented due to the new growth of solid state resins. The
remaining 7 facilities are all owned by DuPont. Six of the seven Dow facilities were selected
to approximate die total projected capacity growth. For TPA/continuous, 6 of the 12
facilities are already represented due to the new growth of solid state resins. All six of the
remaining facilities were selected to represent the projected capacity growth.
MBS. MASS, and Nitrite
No growth information was found on these three polymers. MBS is produced by
three facilities, with a total capacity of about 64,000 Mg. The uses of MBS are similar to
those for PS, which was estimated to have an average growth rate of about 3 percent per year
through 1999. We could assume the same for MBS, which would result in an additional
10,000 Mg of capacity over the next five years. All three MBS facilities have capacities
greater than this estimated growth in capacity. Rather than assuming incremental growth at
an existing facility, which would be difficult to do based on the available information, we
assumed that the new growth would be represented by one new additional plant. The one
facility selected was the one with a capacity closest to the estimated new growth, which is the
Elf Atochem facility.
Based on our information, only one plant produces MABS and only one plant
produces nitrile resins. Since the growth rate is so small, no new facilities were projected.
Furthermore, since MACT for these sources is likely to be identical for both the existing
plant and any new plant, the costs and impact estimates would be the same.
-------
Docket No. A-92-45
December 21, 1994
pageS
TABLE 2.
EXISTING FACILITIES SELECTED TO REPRESENT NEW GROWTH
SOURCE CATEGORY
MBS
SAN - Option 1
SAN -Option 2
PET
»
ABS, BE
ABS, BS
ABS, CM
-------
CHEMICAL PROFILE I Report Fr
ABSRESINS
: >•'-•;'-^V:--- 4,VU March21,;1994
PRODUCER.,;,. l:'*^-?&'£
DtamondPolymers,!Akron,Ohio
Dow, Allyn's Point, Conn..
Dow, Hanging Rocky Ohio.
Dow, Midland, Mich. __.l.^
Dow, Torrance, Calif.;
GE, Ottawa'' ff.\*r£^?;?l'^.ffi^^^ '?
GE. Port Pi^ni^M1??:' ';.y"': '>:'":^'\^;>^^^V^:;^^'''"^:-'_^^^{^MO :'•"?
irtMrW.Vji.'y/.j^jj^g^
'Millions of pounds per year of effective a^rylonrtrtle-b^'dlene-irtyVe^ resm tn- >
parity, Diamond Polymers added a third production line In Felwiiary/ralalng tts
capacity by 15 million pounds. Diamond was founded liu19W»ra|t.aJotof{yehture |
between Mitsubishi Rayon Company and NeMbht Polymers ln£^GF4 Mexican;!
subsidiary, GE Plastics Mexico, acquired the customer baseand EpofahIfiide-:'
;^nrt^3mm.3
mark of Industrlas Resistoi: Profle la^p
-... - - - . - . • -. --I . • r.
DEMAND I
1993: 1 .4 billion pounds; 1994: 1.5 billion pbumte; i998:^1.ff bijlion pourids: (In- v
_• ___ i_ _ ____ I ___ • *• '.•__»_* 'i_ ____ " f __ ^ _^. M^f ^_fin_. _ l_.~^I..'_j j_ »_ ^ «%«««^A!L 'JM^ ^ ^l*ttit^ _ i— '^ «*««**£ L.". -» -i
only 75 million pounds .per year at the start oil the deoade.>ig|
, after being r
•h^MM^ak^H " *'"•*.t • • •"'••» \ j ".-'•• j •/•". \ '>. •" HJ- .'^J-.- ;'j. '.*- V •'/••,'•.*. -, ",:,'l-i?*i - • *<*'.'tV'* ^'•«~*il*V* f^W v:^**ti"«B**"'"~''l~l •*"I''V1-*•(-"">. '* "lf "",'•
loW,:74c. per pound, same basis. Current: 95^1o^i p^rjourKJ, |H same basls.j.glij
USESV^^t:
-- 'Automotive, 25 perpent;appnanpes (including refrigerators), 20 percent; construe- ,•
tion, 20 percent; electronics (including business machines and tele^cbihmunicatipns), 12
percent; custom sheet (Including luggage, recreation[and leisure goods). 8 percent; oth- •
er (including furniture, toys and housewaras);-;i5"pefc^2£^^^ J
STRENGTH • - .': ^:::-£':^gj^}$^$^
Producers are bullish on virtually at ABS markets iri North America, the product en-
joyed 5 to 7 percent armualized growth in the fourth quarter of 1993, and this should;
continue throughout the first half of 1994. High yen values could help US exports.
WEAKNESS • - -. - : -: :•. . •• ' ;; .•..'.•;•
ABS markets in Europe and the Far East are in a recession, and companies hi those
regions are exporting low-cost material to the US, keeping prices down. Demand is
cyclical, and ABS is vulnerable to downturns in the housing and automotive markets. •
OUTLOOK ;, : / 'vo^, v-> ^v/V-v^!
Demand for ABS feH dramatically in 1991, foflowlng a recession in the housing and .
automotive industries, but It surged in 1992 and 1993. Producers expect a return to nor-
mal growth in 1994 and 1995..
By DON
NGL HEADACHE: CEO George Mite
Corporation, The Woodlands, says eaml
1994, but were held back by poor natural
natural gasoline) prices. Mitchell can pro
bat throughput daring the last three mom
Industry observers say die biggest cum
price of crude oiL
Because of die ability of several olefins <
appropriate price levels, demand for eduu
Another squeeze on pricing; when NGLs
must be replaced by higher-priced spot ni
To avoid this double-edged problem nc
gas streams until die pricing situation imp:
Mitchell spokesman Tony Lendni says tin
120,000 barrels daily of lighter ends as Foi
Comfort olefins plant and Dour starts up u
says of die weak NGL market, The bigge
HUNTER PROJECT DENIAL UPHE
deny an application by Hunter Industrial 1
in salt dome caverns near Dayton was upb
DistrictJudge W.Jeanne Meurer ruled *T
things."
The ruling was in response to an appeal
Natural Resource Conservation Commissi
January, 1993 (CMR, 1/11/93, pg. 41)..
Following the decision last week, Home
die possibility of farther appeals. The firm1:
pollution of Lake Houston, ten miles away.
, CLEAN FUELS PROJECT: Serv-Tech c
construction and management of a $40-mill
Torrance, Calif, refinery, to meet Federal (
Board standards for cleaner fuels. Work is*
completed in mid-1995.
DOW FREEPORT NPDES PERMIT: E
formulated National Pollutant Discharge El
TX0006483 for die Freeport chemical cornf
Operations.
Changes from die current permit include
previously discharged under anodier permit
exceed Texas Natural Resource Conservatit
Human Health standards.
Also, the permit addresses construction of
system and requires rwice-a-year chronic bk
EPA and TNRCC requirements.
CHANNEL DREDGING: The US Army <
and Port of Houston Authority have complei
responsibility for maintenance dredging of Bi
Bayou Channel, both connected to Houston i
industry transportation.
Amoco Appoints Kolon
-------
CHEMICAL PROFILE I Report From
ii''^^^^^^
_______ „ _____
'-'
j
?-:i'i'^
fcSi*:«»?A"^sJai3f-'
_
V'''-'^^^^
^nt»™n,P*u,IIL
^
idling fts plant* to BASF, which If expanding H»>U^ HL, facDtty by 40irJOIbn
altoto2M
a 355 mllHbn pounds by the and of thla year/a aacondquarter, Afl of the PS atthe f;
ompanya Addyaton; phk>^ plant la produced forlloMantouhderaiiD»lllhg
greemant; that faiBUhyrcapeeltx fall from 210 minion potu^lntelfonaanto
onvartad one
elpra, Ohio, jpiant,7 and ttw company plane to add arwther 4Sminibn pounda
trough dabotttonacUng at eiMthar site. Profile laat pubOahed OQ4/91; thla ravl-
ND-^giiMlS^B^^^-B^
1993:5.4 WJDon pounds; 1994:5.5 bOOon pounds; 1998:6 bfflton pounda (US de-':
ihd.i$ niughly 5 billon pounds per year. .The total.inchxiBs Cana^ahd.Meja^as^
4 as exports of 250 mllon to 350 mflUon pounds per year, but hot Imports of.epjmlf-.
-." '•"•'.••• •'".'. '•"..••.*.'•' '. '•'•'• ' .^:.;W:;..'TV.:::--"-""'v'i:-:'. '•'
'••'. --1. '.;.".'.'••'.' '.:'":" Continued on Page 17 . .. ;".'\:;;v.;.'v;.. •'.'.••.".'.',.:,•..-.'..,.;
ByDONRICHAR
GCF FRACTIONATOR BLAST: Explosions anc
ftcility of GulTCoast Fracdonaton shortly before 9£
personnel on-ate were hospiolized Late last week, r
nor the extent of the damage could be determined, al
restricted to the plant rite. The unit is down and an k
GCF has a design capacity to separate 80,000 barre
ethane,propane,butanes and natural gasoline. Theft
currendy undergoing a 40,000 barrel-a-day expansior
GCF is a partnership of Trident NGL Inc. a subsic
Inc (38.75 percent); L^uid Energy Corporation, »snt
Development Corporation (38.75 percent); and Cona
In 1993 die partnership had revenues of $28.5 millic
Trident also owns 100 percent of an 82,000-barrel-a-d
which was not damaged and continaes to operate.
UNION TEXAS OLEFENS: Average net daily prod\
La, rose to 1,312,000 pounds in 1993 from U78,000 po
company's annual report Output of ethylene and prop;
million gross pounds daily.
Union Texas hat a 42 percent interest In and operate
pounds a year of ethylene and 72 million pounds a year
new furnace will boost dteolefin plant's capacity by 4 p
natural gas liquids fracrionator at Rayne, La, and outpu
percent last yean The unit was upgraded with electron!
computer controls,
FORMOSA SHIPS CAUSTIC On March 10,30,000 <
made by Formosa Plastics Texas at Point Comfort was e
Calboun County Navigation District docks to Latin Am
its total incoming and outgoing traffic for 1994 will reach
totaling 384,000 tons overseas and 12 million barrels of p
service.
TNRCC LEVIES FINES: Texas Natural Resource Coi
fined Phillips Petroleum Company $537,742 for violation
regulations that occurred between 1985 and 1991 at die S
petrochemical complex Mobil Oil Corporation has been
at the Beaumont refinery between 1989 and 1992.
Also penalized were Firestone Syndiedc Rubber & Ltd
Unocal atNederland ($8,000), AUwaste Recovery System
Solutions Inc. Deer Park ($82,840), American Plating Cor
Chem Grind Chemical Corporation, Houston ($45,600) at
Corporation, Houston ($42,400)
SUPERFUND SITE SAGA: Texas Natural Resource C
Environmental Protection Agency are treating groundwin
remediation of die Industrial Transformer (Sol Lynn) Sup*
Astrodome,
Soil cleanup was completed in March, 1993 and ground*
placed under direction of Radian Corporation and Soudnw
(CMR, 3/14/93, pg. 45) The$2J7milIioocontraaiovoi»
175 million gallons of water over the next 10 yean
-------
CHEMICAL PROFILE
•'.''.•' v- -:..-'.: - '/. '•••• Continued from Page 41 ••'• •'. .>••••' £;•>••/•'"' v.-«v.' .
GROWTH ;. . .'=.-.-.. - .;"• -:-> '. - '• •:: ^V'^ '-• •'''•'• :'.- ^/ W ;V&f-^/. •
Historical (1984-1993): 2 to 3 percent per year; future: 2 to 4 percent per year
through 1998. •••.•.',', ...:".•'..-.:." :,; -;.'..'•»'...- -:. .-•'."-". • ' ~.' ••\-''*.&.'.£-';-: ...i ••:-:•.•.-•.
PRICE'.;; .; • • -.;.- ;^ ^;::>.;-;.;.:^; 'Ivvv^ :A.^£iv$s*S^; '.^-Xl :'i --
••'.. Historical (1981-1994): High, 80c; per pound, bulk crystal, hopper :cars f.o Jj.; low,
40c. per pound, same basis. Current: bulk crystal, hopper cars, fit afld,, 45c. per pound
fist; impact-grade, hopper cars, fit, aifld., 47c, per pound; list expandable beads, pack- '.
aging grade, 1 ,000*. lots, 53c. Jo Me: per pound, Hst'.^^«!i;^|}0|^|x^?;^:;
.f^:^£^^
-•:.. Packaging and ohe-tiini? use, ;4Q percent; expandable porystyrerw beads,,|5 per-;-
cent; electronics, 13 percent; resellers and ranipo^dlr^, 13permt;cc4vsumerand tan;!
stitutional products, \11 percent: furniture, building arid construction, 5 percent; other, 3
P?^.^!?^o^^^^^
,. Polystyrenejs us^ri^ '•.
omy improves. ' " "" •-••-- - ---••-••
ing is firming. F
neered formulations of^ PS;are'finding _ .. rr -.
\entertatfuhsrt efednwilc^'pa^^
il^
-. .<•: •,' Polystyrene is a mature product^ and rnarnifacturers are under ffre to tower ttveir pnv;.
duction coste;and d^yetop higlw^rfor^
ring Is recovenVig. Qrov^BTKJuW oxrtihue at GDP. but PS couW faBer if the economy
Third World Nations Tops
In Carbon Dioxide Emissions
Third worid nanons are now die largest pro-
ducers of carbon dioxide as they fuel their
economic development with increased use of
coal, oil and gas. Energy-related carbon diox-
ide emissions are growing much more slowly
in industrialized nations.
The 24 major industrialized countries now
produce 48 percent of die world's energy-re-
lated carbon emissions, down from 57 per-
cent in 1970, says Energy Department in a
new report That means mat die poorer de-
veloping nations are now me majority pro-
ducers of energy-related carbon at 52 per-
cent; up from 43 percent in 1970.
Between 1970 and 1992, carbon emissions
grew 82 percent in developing countries,
compared with a 28 percent increase in the
industrial nations, according to the Energy
Information Administration study. Overall,
world emissions of energy-related carbon
dioxide grew from 4 billion metric tons in
1970 to 6 billion in 1992.
Increased levels of carbon dioxide in the
atmosphere, due mainly to the burning of
t—:i A.-I. I—... ,
and die potential exists for large increases as
developing nations continue to demand
more modern lifestyles.
If me developing nations had used energy
and produced caibon at me same per capita
rates as the industrial countries in 1990,
worldwide carbon emissions would have
been triple die reported rate.
mini
FDA Registered, (
Backed byNapp
technol
199 MAW ST.. BOX 9OC
C2O1)77W9OO FA
\Y»«r Bridt* U the Reaoarcei
Xf\ JL • -Enzyme
"UIML. X-Glu, IF
CUSTOM SYNTHESIS A.
CHEMBRIDGE CORPORATION (70
One Northbrook Place, 5 Revere Drive, S
mam ERREGIERRE
INDUSTRIA CHIMICA S.pA
BERGAMO. ITALY
Amrinone
Anistotropine Methylbromide
-------
CHEMICAL PROFILE I Report From
Eastman Chemical (3 Sites)
• taVVUINUI WtlVIIMvaS \9-1f*m9j»wnm ••••••••»••••••••»;•• ••••••••.•••••••.•Ml ••>
^Hoechst Celanese ^JE^^^-^^J^^^^!^
M? Id AfnOTlC&St* FWWtt0VlII0« N«C •«• «JMij>»iri7i••PMiiii%itiVMlM''iMiir1*'r ' 11 i 'i _'_*"' r i'u*j^r*
.-- *»•_•_.•»• ^a»»J_•!_:••-•• vi'i-^ -»•_ I"-*** *•**•• •« ' -*^'i^t^*?^r^5.^£^V«^»*ti!!^^^v,9JH£«>t'.'..:, ?.:; ^'^:'-;:,.;;.-:.;
-; : Plastics are perceived as bad for the environment, and this could favor paper, aki- ;
rhinum and glass. PET Is a poor barrier to oxygen and carbon dioxide, limiting its use.:,'
as a beer container. ; ..••;-.•.;••.•..• - •••:••::.;••"..=:....;;-';; -i--'-..'-.'^;- ^v--':J-V?
_-;i.'.w^.-f;-.V!-,-^ ,••*;;•.;.-.....; ..:.:•'..; ';.';.;' V= i'.!"."!: .V/V ^••;'.;- '. ;';'-'; : : l! <-/;.* :,"H ,;;•;'. (
OUTLOOK •;-• ••;.• ;^:/•;•'.; ..".• - .-'•-;• ?-.y^>:':;^v-v;';;:^
• PET is one of the not products for tr»1990s. Two new producers are entering fte :
US market, and most current manufacturers plan sizeable expansions.
ByDONRICHAi
GNI EXPANDING CHEMICAL RECYCLIN
recycled ^chemicals processing capacity in Deer Pa
million pounds annually by year's end. Current pot
The plant, capable of recovering glycols, amines.
chemicals from side streams, started up in 1990 wit
process off-materials from chemical and odier indu
54>
A wipeu-fflm evapoiator and two batch reactor u
stainless steel, hare been added since "changing the
puts it GNI is currently eyeing specialty chemicab
FORMOSA PERMIT FROM TWO Formosa P
amended permit by Texas Water Commission to n
gallons daily of treated industrial water into Upper
process of lining up permits to operate the firm's ne
grycol-plasrics-ethylene dichkmde complex at Poii
The company, which promised to work with the
setde pending solid waste disposal cases, to become
Clean Texas 2000 program, and abide by other son
biggest hurdle: an NPDES permit from Environme
Environmental Impact Statement prepared by. US I
3/15/93, pg.41)i .
DIAMOND SHAMROCK RESULTS: The Saa
$4.3 million vs. a loss of $2&S million in 1Q.1992. T.
changes in accounting mandated by Financial Acco
margins from refining and pipeline projects were ak
Sales and operating revenues in die year 1992 for
$2^016 million from $2,575.9 million in 1991. But r
from $37.1 million die previous year. The firm is a ji
export facility completed last August at Bayporc
Diamond Shamrock also owns and operates an ur
storage facility at Mont Belvien, with 25 storage wd
62 pipeline connections. This represeno-nearry 12 f
i storage.
PERMITS SOUGHT: Environmental Protection
draft National Pollutant Discharge Elimination Sya
Chemicals Inc's Green Lake acrylonitrile and aceto
new limits for copper, zinc, cyanide, arsenic and dial
for die latter two metals. A permit also has been fora
Company refinery at Corpus ChristL A 30-day comi
Lyeadell Petrochemical Company has applied to
renewal of Permit No. 3130A for its barge terminal f
are listed as nitrogen oxides, carbon monoxide, pan!
hydrocarbons inchding but not limited » MTBE, a
andacetophenone. •
BAYOU Cmr BULLETS: Petrochemical and pet
Setpoinc he of Houston has opened has opened an t
Warrington, England, headed by Alan Dunkeriey...
Performance Chemicals, a Baker Hughes subsidiary,
treat carbon dioxide corrosion in refinery overhead t
Compaction Improvement
distributes fluorspar and strontium carbonate use to reduce the amount ofmnrcrinl
-------
-------
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: Leslie Evans
U. S. Environmental Protection Agency
FROM: Bennett King
Pacific Environmental Services
DATE: March 22, 1995
SUBJECT: Process Vents Level of Control For Methyl Methacrylate Butadiene Styrene
(MBS) Sources - New Level of Control More Stringent Than Existing Level of
Control
Purpose
This memorandum presents the analyses done to examine whether the level of control
for new MBS sources is more stringent than for existing MBS sources. Since the control
requirement (i.e., reduce emissions by 98 percent) is the same for new and existing sources,
the analysis focuses on a comparison of applicability criteria.
Methodology & Results
Three analyses were done as part of examining this issue. The first analysis examined
the percent emission reduction achieved by each facility under the new and existing
applicability criteria. The second analysis examined the total allowed emissions for each
facility for three situations: 1) under the existing controls, 2) under the new applicability
criteria, and 3) under the existing applicability criteria. Finally, the third analysis entailed a
vent-by-vent comparison across the three facilities between the new and existing criteria.
Based on the results of the three analyses, the new applicability criteria are at least as
stringent as the existing criteria.
Analysis 1
Under the first analysis, the percent reduction achieved by the new and existing
applicability criteria is compared for the three known facilities. For two out of the three
facilities, this analysis demonstrates that the new applicability criteria are more stringent than
the existing applicability criteria (Table 1).
WASHINGTON D C • RESEARCH TRIANGLE PARK NC • LOS ANC5EUFS OA • CIMCNNATI OH
-------
Table 1. Percent Reduction For Each Facility
Facility
AQ
AE
L
Existing
Control
89%
72%
17%
Existing
Criteria
92%
72%
66%
New
Criteria
89%
86%
97%
Under the second analysis, the allowed emissions under the existing and new
applicability criteria are compared. Under the existing criteria, emissions are approximately
77,400 Ib/yr, and under the new criteria, emissions are approximately 72,400 Ib/yr. For this
analysis, the new applicability criteria are more stringent.
Analysis 3
Under the thud and final analysis, the number of process vents and the emissions
associated with each were categorized under one of three possible scenarios: 1) controlled
by both the existing and new applicability criteria, 2) controlled by only the new applicability
criteria and not by the existing criteria, and 3) controlled by only the existing applicability
criteria, but not the new. Table 2 presents the results of this analysis.
Table 2. Vent-by-Vent Comparison
Number of Vents
Percent of
Emissions
Controlled by Both
New & Existing
26
92%
Controlled by New
Only
2
3.5%
Controlled by
Existing Only
9
4.5%
Several observations can be made concerning the data. First, the percent of emissions
controlled by only the existing criteria is a small amount of the total (less than 5 percent).
Second, the delta between emissions controlled by only the existing criteria and those
controlled by only the new criteria is even smaller (less than 1 percent). Given the
approximate nature of the emission estimating techniques, this analysis demonstrates that the
control achieved under the existing applicability criteria and that achieved under the new
criteria are, for all practical purposes, equivalent.
-------
Summary
In summary, one of the analyses clearly indicates that the new applicability criteria
are more stringent, and for two of the analyses, the results indicate that the new criteria are
at least as stringent as the existing. Therefore, on an overall basis, the new applicability
criteria can be judged to be at least as stringent as the existing criteria.
I:\n301\docu\mbsnew
cc: Ken Meardon, PES
Valeria Everette, PES
-------
PACIFIC ENVIRONMENTAL SERVICES, INC.
2T-&-2.I
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 A-92-45
FROM: Bennett King
Pacific Environmental Services, Inc.
DATE: March 22, 1995
SUBJECT: Process Vent MACT Floors Considered More Stringent than the Hazardous
Organic NESHAP (HON) and Batch Processes Alternative Control Techniques
(ACT)
Purpose
This memo presents the options considered for defining the MACT floor for process
vents for various subcategories and identifies the option selected by the EPA that appears in
the proposed rule. The subcategories for which MACT floors were defined in regulatory
terms are: existing sources producing methyl methacrylate butadiene styrene (MBS); existing
and new sources producing acrylonitrile styrene acrylate/alpha methyl styrene acrylonitrile
(ASA/AMSAN); and new sources producing styrene acrylonitrile (SAN) using a batch
process. Defining the MACT floor for certain subcategories was necessary because it was
determined that the MACT floors, as reflected in the existing level of control, for these
subcategories are more stringent than the appropriate HON process vent requirements or
Batch Processes ACT. Chapter 6 of the Basis and Purpose Document discusses the
relationship between the MACT floor, the HON and Batch Processes ACT, and regulatory
alternatives in more detail.
This memo discusses each subcategory (e.g., MBS) separately, identifying (1) why the
MACT floors were considered more stringent than the HON requirements, (2) the options for
defining the MACT floors, and (3) the advantages and disadvantages of each option.
Finally, the option selected by the EPA as the basis of the proposed standards for each
subcategory is identified.
WASHINGTON, D C • RESEARCH TRIANGLE PARK, NC • LOS ANGELES, CA • CINCINNATI, OH
-------
MBS
Background. There are three facilities that produce MBS. Based on the available
information, two of the facilities are controlling process vents that the HON for existing
sources would not require to be controlled. (Note: all three facilities ar equivalent to the
HON for new sources.) For each facility, each process vent was evaluated against the HON
applicability criteria of total resource effectiveness (TRE). In addition, the emissions
allowed under the HON were compared to the existing emissions. The finding that two
facilities were more stringent than the HON was based on the fact that either (1) process
vents were being controlled that the HON did not require to be controlled or (2) emissions
allowed after applying the HON applicability and level of control to each process vent were
greater than emissions under existing control.
Options for Defining the MACT Floor. The MACT floor can be defined as an
overall percent reduction for process vents (determined using a weighted average percent
reduction for the three MBS facilities) or as an overall emission factor for process vents.
Defining the MACT floor as an overall percent reduction yields a value of 83 percent (see
table below). Defining the MACT floor as an overall emission factor for process vents
yields a value of 0.000590 pound emissions per pound of product (Ib/lb). The estimation of
the overall emission factor uses data which are considered to be confidential business
information (CBI), and the derivation of this value is not shown.
DATA USED TO DETFJRMINE OVERALL PERCENT REDUCTION
Facility
A
B
C
Totals
Uncontrolled
Emissions (Ib/yr)
531,250
95,610
32,810
659,660
Existing Emissions
(Ib/yr)
58,440
26,770
27,230
112,440
Percent Emission
Reduction
89%
72%
17%
83%
-------
Options for Expressing the MACT Floor in the Regulation. Under either of the two
options for defining the MACT floor, it is possible to determine a TRE value that achieves
the emission reduction equivalent to the MACT floor (hereafter referred to as the equivalent
TRE). Further, it is possible to determine an emission factor that achieves emission
reduction equivalent to the MACT floor when it is expressed as an overall percent reduction.
As a result, there are at least three possible formats for expressing the MACT floor in the
rule: 1) TRE, 2) percent reduction, and 3) emission factor. Combinations of these formats
are also possible.
TRE Determination. Determining the equivalent TRE value for either definition of
the MACT floor followed the same process. The first step in determining the equivalent
TRE value associated with the percent reduction definition of the MACT floor was to
compare the percent reduction achieved by each facility on its process vents to the MACT
floor level of 83 percent (or, when the MACT floor is defined as an emission factor, the
emission factor achieved by each facility is compared to the MACT floor of 0.000590 Ib/lb).
For those facilities below the MACT floor level, the process vents that needed to be
rcontrolled in order to meet or exceed the MACT floor level were identified based on their
•stream characteristics; priority was given to those vents likely to be most cost effective to
control. Once this was done for each facility. The TRE values for the selected process
vents were examined and a TRE value representative of the individual process vent was
determined (hereafter referred to as the representative TRE). Specific data are not available
for all process vents. As a result, a range of likely stream characteristics that correspond to
the known emissions for each process vent were developed, and a range of TRE values were
determined based on the developed data.
The following criteria were used in selecting the representative TRE value for each
process vent requiring control:
• if stream characteristics are known, the lower of the three calculated TRE
values, one for each control device option (flare, thermal incinerator with 0%
heat recovery, and thermal incinerator with 70% heat recovery), was selected
as the representative TRE value
• if stream characteristics are not known, a two-step process was followed.
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First, the TRE value or range of values representing year-round (8760 hr/yr)
operation was selected for each control device option. This set of TRE values
was selected to be conservative. Second, the highest TRE value for the
control device option with the lowest range of values was selected.
Once the representative TRE value for each process vent required to be controlled was
determined, the highest representative TRE value for the set of process vents requiring
control was selected as the equivalent TRE.
For example, given the data in the table presented below, the representative TRE
value for stream 1 would be 3.2 and the representative TRE value for stream 2 would be 5.
The equivalent TRE value would be the highest value for the two streams requiring
control — 5.
EXAMPLE DATA FOR TRE DETERMINATION
Facility &
Stream ID
Str 1,
Facility A
Str 2,
Facility B
TRE'
TRE
Rangeb
TRE or Range of TREs for Control Device Options
Flare
9.3
4.8 to 16.5
Thermal
Incinerator
(0% heat
recovery)
3.2
3 to 5
Thermal
Incinerator
(70% heat
recovery)
3.8
4.7 to 6
Representative
TRE
3.2
5C
1 Stream characteristics are known.
b Stream characteristics are not known and the range of TRE values represent year-round
operation.
c Highest TRE value for the year-round range with the lowest range of values.
A different equivalent TRE value was determined for the two different options of
defining the MACT floor and different facilities were required to apply additional control.
Using percent reduction for defining the MACT floor results in an equivalent TRE value of
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5.0 and was based on facilities B and C applying additional control. Using the emission
factor definition, an equivalent TRE value of 3.7 was calculated and facilities A and C would
be required to apply additional control.
Determination of an equivalent TRE value under a third approach was considered.
This approach would entail evaluating the TRE values of the process vents currently being
controlled by each facility. Determining the equivalent TRE would define the MACT floor.
After an initial review of the data, it was determined that too many process vents were
represented by a wide range of TRE values due to missing stream data to utilize this
approach.
Determining an Emission Factor Equivalent to the MACT Floor of 83% Emission
Reduction. Another option for expressing the MACT floor in the regulation is to calculate
an equivalent emission factor; that is, an emission factor that achieves the same emission
reduction required by the MACT floor when defined as an overall percent reduction. To do
this, the streams requiring control in order to bring each facility up to the MACT floor level
of 83 percent emission reduction were determined. In most cases, the process vent
population did not allow a facility to precisely achieve 83 percent emission reduction, and a
facility achieved an emission reduction higher than 83 percent. The remaining emissions
(existing emissions less the emission reduction required to achieve at least 83 percent
emission reduction) and the production capacity were used to determine an overall emission
factor. The calculated emission factor was 0.000654 Ib/lb.
Expressing the MACT Floor in the Regulation. Five options for expressing the
MACT floor in the regulation were developed. The first three options are based on defining
the MACT floor as an overall percent reduction for process vents and the next two are based
on defining the MACT floor as an overall emission factor. The options are:
1) require facilities to control each process vent with a TRE less than or
equal to 5;
2) allow facilities to either (1) control each process vent with a TRE less than or
equal to 5 or (2) achieve an overall process vents emission reduction equal to
the MACT floor - 83 percent;
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3) require facilities to achieve an overall process vents emission factor equivalent
to the percent reduction MACT floor of 83 percent emission reduction -
0.000654 Ib emissions per Ib product.
4) require facilities to control each process vent with a TRE less than or
equal to 3.7;
5) allow facilities to either (1) control each process vent with a TRE less than or
equal to 3.7 or (2) achieve an overall process vents emission factor equal to
the MACT floor (i.e., 0.000590 Ib/lb).
These options all have slightly different emission reductions, annual costs, and cost-
effectiveness values as presented hi Table 1.
Table 1. OPTIONS FOR EXPRESSING THE MACT FLOOR
Option/Best
Controlled
Facility
I1/ A
2 / A
3 / A
4'/ B
5 / B
Description
TRE of 5
TRE of 5
or 83X
reduction
EF of
0.000654
TRE of 3.7
TRE of 3.7
or EF of
0.000590
Facilities
Requiring
Control
A, B, & C
B & C
A & C
A, B, & C
A & C
Emission
Reductions
Achieved
(Mg/yr)
25.88
18.2
20.14
21.17
15.03
Rough Order
Annual Cost
(*/yr)
203,250
141,060
299.420
151,530
114,060
Overall Cost
Effectivenes
s (S/Hg)
7,850
7.750
14,870
7,160
7.590
Percent
Reduction
Relative to
Uncontrolled
Emissions
91. 5X
89X
89X
90X
88X
" This option is more stringent than the MACT floor.
EF = emission factor
Cost effectiveness values for Options 1, 2, 4 and 5 are comparable. However, the
options that apply a TRE value alone without considering a facility's performance relative to
the MACT floor (options 1 and 4) are more stringent than the MACT floor and would need
to be justified on a cost effectiveness basis. These options are more stringent because with
-------
either option, the facility that is the "best controlled" (e.g., the highest emission reduction) is
required to apply control. Option 3 does not appear to be a favorable option due to the
significantly higher cost effectiveness value when compared to the other options.
Option Selected by EPA. There is very little difference between Options 2 and 5
from an impacts perspective. However, Option 2 requires the facility with the lowest
emissions per quantity of product (emission factor) at the existing level of control to apply
additional control; Option 5 does not. For this reason, the EPA selected Option 5 as the
basis for the proposed standards for this subcategory.
ASA/AMSAN
Background. Only one facility was identified as producing ASA/AMSAN, and all the
known process vents at this facility were controlled. Based on the calculated TRE's for these
process vents and/or application of the Batch Processes ACT applicability criteria, none of
these process vents required control. Based on this comparison, this facility was considered
to be controlling process vents more stringently than required by the HON/ACT for both
existing and new sources. Therefore, the MACT floor for both existing and new sources
needs to be based on the existing control level achieved at this facility. In addition, since
only one facility exists that produces this resin, the MACT floors will be the same for
existing and new sources and must ensure that this facility maintains its level of control.
Options & Selected Option. No options were developed for this subcategory.
Because of the limited data, need to maintain the current level of control at the one known
facility, and desire for simplicity, the EPA selected control of all process vents as the basis
for the proposed standards for this subcategory.
SAN. Batch
Background. There are two facilities that produce SAN using a batch process. Based
on the available information, one facility is controlling process vents as would be required by
the HON/ACT, and one facility is controlling process vents to a level more stringent than the
HON/ACT. The MACT floor for new sources needs to be based on this "best" facility.
-------
Options. The process vents found at facilities producing SAN using a batch process
are a mixture of batch and continuous process vents. As a result, defining the MACT floor
based on the TRE was not an option. Two options were identified that could account for the
mix of batch and continuous process vents. They are a percent reduction and an emission
factor. The percent emission reduction achieved by the "best" facility is 84 percent. An
emission factor could be estimated, but would have to be based on confidential production
capacity data.
Option Selected by EPA. The option selected by EPA as the basis of the proposed
standards for this subcategory is percent reduction. The confidential business information
concerns associated with an emission factor weighed against considering this option for the
proposed rule.
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— TO
PACIFIC ENVIRONMENTAL SERVICES, INC.
Central Park West
5001 South Miami Boulevard
POBox 12077
Research Triangle Park, NC 27709-2077
(919)941-0333 FAX (919) 941-0234
MEMORANDUM
TO: Leslie Evans
U. S. Environmental Protection Agency
FROM: Bennett King
Pacific Environmental Services
DATE: March 22, 1995
SUBJECT: Methodology for Estimation of Preliminary Monitoring, Recordkeeping, and
Reporting Costs for the Economic Impact Analysis for the Polymers and
Resins IV NESHAP
The purpose of this memorandum is to document the basis used to estimate
monitoring, recordkeeping, and reporting costs provided to the EPA for use in the Economic
Impact Analysis for the Group IV polymers and resins national emission standards for
hazardous air pollutants (NESHAP). The estimates for the Group IV NESHAP are based on
a preliminary cost analysis done for the Group I NESHAP (i.e. the NESHAP affecting
elastomer polymers and resin processes).
In estimating the preliminary monitoring, recordkeeping, and reporting costs used in
the Economic Impact Analysis, it was assumed that the total monitoring, recordkeeping, and
reporting costs would be similar to those estimated for the Group I NESHAP. In the
memorandum entitled "Preliminary Monitoring, Recordkeeping, and Reporting Costs for
Polymers and Resins I," it was determined that, in general, the total costs for monitoring,
recordkeeping, and reporting for the Group I NESHAP were approximately 30 percent of the
total annualized control costs. Many of the control requirements, as well as monitoring,
recordkeeping and reporting requirements for the Group IV NESHAP are quite similar to
those in the Group I NESHAP. Therefore, it was determined that an estimate of 30 percent
of the total annualized control costs is a reasonable estimate for Group IV and was used.
The memorandum documenting the preliminary cost analysis for the Group I NESHAP is
included as Attachment 1.
I:\n301\docu\mrr30%
cc: Ken Meardon, PES
Valerie Everette, PI
WASHINGTON. D C. • RESEARCH TRIANGLE PARK. NC • LOS ANGELES. CA • ONCWNATI. OH
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ATTACHMENT 1
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IriCOrDOTCLtcd Environmental Consulting and Research
MEMORANDUM
Date: August 9, 1994
Subject: Preliminary Monitoring, Recordkeeping, and Reporting
Costs for Polymers and Resins I
From: Phil Norwood,
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 hours 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
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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/Inspect6
Process/Compile and Review
Complete Reports
Record/Disclose
Store/File
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
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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 HbN 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 $5.3 million per year,
which is approximately 31 percent of the total control costs.
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TABLE 3. ESTIMATED MONITORING,
REPORTING, AND RECORDKEEPING COSTS
MRRa Costs
Subcategory 1000$/yr
Butyl Rubber $168
Halobutyl Rubber $168
Epichlorohydrin Elastomers $168
Ethylene-Propylene Rubber $838
Hypalon $88
Neoprene $503
Nitrile-Butadiene Latex $503
Nitrite- Butadiene Rubber by Emulsion $670
Styrene- Butadiene Latex $1,404
Styrene- Butadiene Rubber by Emulsion $351
Poly-/Styrene- Butadiene Rubber by Soln $439
TOTAL P&R IMRR COSTS ($/yr) $5,299
Total Control Costs ($/yr) $16,982
%MRR to total 31%
* Monitoring, recordkeeping, and reporting
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ATTACHMENT 1
HON SF-83 AND SUPPORTING STATEMENT
-------
-------
/,- i
83
Request for OMB Review
/v -F- fi
ortarrt •
nd instructions before completing form. Do not toe the same 5F 83
•fluest both an Executive Order 12291 review ana approval under
saperwork Reduction Act
swer all Questions in Part I. If this request is for review under £.0.
31. complete Part II and sign the regulatory certification. If this
est is for approval under trie Paperwork Reduction Act and 5 CFR
3. skip Part II. complete Part III and sign the paperwork certification.
Send three copies of tfta 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
TT L—Complete This Part for All Requests.
2. Agency cooe
.•paRntera/agency and Buntau/omce ongjnanng request
.lited States Environmental Protection Agency •
;fice of Air and Radiation /
ame 01 penon wno an ben answer questions regaromgtms request
anet S. Mever. MD-13; Warren R. Johnson. MD-13
Ictepnone numoer
| (919 ) 541-5254/51:
ueoi information coUecuon or nucnuKing •
ecordkeeping and'Reporting for. the Hazardous Organic NESHAP (HON) for the Synthetic Organic
hemical Manufacturing Industry (SOCMI) and Other Processes Subject to the Negotiated
•-filiation for Equipment Leaks
:g»i autnomy lor information coitecuon or rue tuDmmtngttiis reauen ior OMB revnw. the aumemea reguUtory conuet and tne program erficiat certify that the itquKcments rt E.0.12291 ana any appneaMe
•cy uiietuvej n*re uccn compute wnn.
•rjture ot program ottteat - *
punire 01 autnotaea regulatory conua
Date
Date
- (OMB uti only)
..._^.««M U !«*«. 9-
-------
111.—Complete This Part Only If the Request is tor Approval ol a Collection
of Information Under the Paperwork Reduction Act and S CFR 1320.
inn—Oesenw nte«. «•» «* »«eaed public in SO warns or less
•omulgated standard will require control of emissions of 110 hazardous air pollutants from
reduction of about 400 synthetic organic chemicals. Affected chemical plants would maintain
Is and submit initial and sometimes semiannual or quarterly reports of emission measurements
jlated information.
wrncffa
3 Regular tubmeuion
ecuon (enec* on*/ em)
i Ml csnlatotrf at nito
an (certttKMtionMtua*a)
w to
J Ejuiliiiy ngulitiun (no tiitnge propoMo?
3 Notice el proposed rulemakmg (NPRM)
Z) Fnal.NPRMMupmwutlypubfiilMd
6 riraJwmwrmfmai without pnorNPRM
*D Regular*iibnu»sion
BO Em«|meysubmasionree/tftaitian«tacM«Q
7. Enter date ol expected or actual Federal
Register publication at this stage of rukmaku
(moirtti.ety.re«fl: Feb. ?R .
pe ri ***** requested fence* entjent)
3 New'collection t
D Rewsionof a currently approved code
Exter»ionettnee«pir»tieneateola
without anvctiaiwe HI the tutaiuino or
4 D Reinstatement ol a previously approved collection for which approval
has expmd
in use without an OMB control number
1414.02
• •
• •
inuaucoonmg or aaaoum ounen
Toot annual rcsooncs(7ineJ tone* AM 9 . . .
Tcrtat hoif i fKnc 3 fimti fcnp 4f "
nnuat recomMcping ouroen
Total recerdheeomg noun (line J tomes line Z) . ..
Recardkeeointrcttmionoened
sal annual buraen
Resumed (tint J7-S Hut hne 18-3) . .....
Difference {line Jfcu An* 3? ........
JtpbruricM of OHtrmatm
A «*BB^B*^K^l^*
389
4
1.556
1341.18-
2,086,8?0--
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2,127,710
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t
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PART A OF THE SUPPORTING STATEMENT
1. Identification of the Information Collection
(a) Title and Number of the Information 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.11
(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'6. The Notification
of Compliance status is submitted to provide the information
necessary to demonstrate that compliance has been achieved. The
Periodic Reports 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. Meed 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.
%
(a) Respondents/SIC Codes.
Respondents are owners or operators of HAP-eraitting 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.
-------
(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, (l) Initial Notification, (2)
Implementation Plan, (3) Notification of Compliance Status, (4)
Periodic Reports, and (5) other reports, is detailed below.
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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 1 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.
-------
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 nay
duplicate information required by the standards. In such cases,
.a,copy of the report submitted to the State or local agency can
rbe 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 132O.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..
-------
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-
coropliance 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
of 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
$15.
(d) Bottom Line Burden Hours and Costs/Master Tables.
(i) The simple collection. The bottom line respondent
burden hours and costs, presented in Tables la and Ib, are
calculated by adding person-hours per year down each column
for technical, managerial, and clerical staff, and by adding
down the cost column. The estimated total nationwide burden
in the first 3 years of the rule is an estimated 2,127,710
hours per year (1,850,180 technical, 92,510 managerial and
185,020 clerical hours) at a cost of 68,364.37 thousand
dollars per«year.
-------
(ii) The Agency 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
2,017 clerical hours) at a cost of 760.37 thousand dollars
per year.
(iii) The complex collection. 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.
-------
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-------
Table 2. Annual Burden and Cost for the Federal Government
Burden Item
Average
Hours
per
Activity
(a)
Number of
Activities per
year
(b)
Estimated
Technical
Hours per
year
(cf
Estimated
Managerial
Hours per
year
(d)
Estimated
Clerical
Hours per
year
(e)
Annual Cost
in
^Thousands
per year
(f)
PERFORMANCE TESTS:
1) Initial
2) Repeat
LITIGATION:
40
40
2.080
14
3
3
560
120
6.240
28
6
312
56
12
624
20.69
4.43
230.57
REPORTS REVIEW:
1) Initial
2) Implementation
Plan or Permit
3) Compl. status
4) Review equip.
leak monitoring
5) Notification of
const. /recon.
6) Notification of
anticipated startup
7) Notification of
actual startup
8) Notif. of
performance test
9) Review of test
results
10) Review
periodic reports
2
20
40
7
6'
6
6
6
24
,4
124
124
124
742
6
6
6
6
6
18
TOTAL BURDEN AND COST (Salary)
248
2.480
4.960
5.194
36
36
36
36
144
72
20.162
12
124
248
260
2
2
2
2
7
4
1 .009
TRAVEL EXPENSES
25
248
496
519
4
4
4
4
14
<7
2.017
TOTAL ANNUAL COST
9.15
91.64
183.27
191.93
1.35
1.35
1.35
1.35
5.31
2.68
•
745.07
15.30
760.37
See attachment 3 for assumptions and further description of activities.
-------
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
JoeHovious - Union Carbide (203)794-5183
AH Khan Indiana Air Pollution
Control (219) 391-8297
Karen Olsen Texas Air Pollution
Control Board (512) 451-5711
i
Gus Von Bodungen Louisiana Department of
Environmental Quality (504) 394-5374
-------
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-------
Attachment 1
SOURCE DATA AND INFORMATION REQUIREMENTS
Information Requirements
Citation
NOTIFICATION
Notification of construction or reconstruction
Notification of anticipated date of initial startup
Notification of actual flate of initial startup
Notification of modification
REPORTING - INITIAL
Initial report requirements
Reporting of operating parameter levels
Statement of compliance or noncompliance
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
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
Record of periods of operation during which the
performance boundaries esdtablished during the most
recent performance tests are exceeded
Records of Monthly visual inspections
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, 63.151,
63.152
63.118, 63.147, 63.147,
63.181
Records of Annual visual inspections
63.123, 63.147, 63.148,
63.181
-------
Attachment 2
Assumptions and Item Descriptions for Tables la, 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 ner 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.
(s) Estimated Technical Hours per year is the product of (c) and (d).
If) Estimated Managerial Hours per year is 5% of (e).
(g) Estimated Clerical Hours per year is 10% of (e).
-------
Attachment 2 (continued)
Assumptions and Item Descriptions for Tables la and 2b
(h) 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:
(H* x S33/hourH.
-------
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 repon 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.
(D) 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, 1b 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) -HHm x $49/hour) + (HC x $15/hourl = (h)
1.000
Where:1
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.
7) 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).
-------
O 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: Bennett King
Pacific Environmental Services, INC.
DATE: March 24, 1995
SUBJECT: Storage Vessel MACT Floors Considered More Stringent than the
Hazardous Organic NESHAP (HON)
Purpose
This memo presents the options considered for defining the MACT floors for
storage vessels for various subcategories and identifies the option selected by the EPA as
the basis for the proposed standards. The subcategories for which the MACT floor was
defined in regulatory terms are: new sources producing styrene acrylonitrile (SAN) using
a continuous process; existing and new sources producing acrylonitrile styrene
acrylate/alpha methyl styrene acrylonitrile (ASA/AMSAN); existing and new sources
producing nitrite; new sources producing acrylonitrile butadiene styrene (ABS) using a
continuous mass process; and existing and new sources producing polystyrene using a
continuous process. Defining the MACT floor for certain subcategories was necessary
because it was determined that the MACT floors, as reflected in the existing level of
control, for these subcategories are more stringent than the appropriate HON storage
vessel requirements.
This memo discusses each subcategory (e.g., SAN, continuous) separately,
identifying (1) why the MACT floors were considered more stringent than the HON
requirements, (2) the options for defining the MACT floors, and (3) the advantages and
disadvantages of each option. Finally, the option selected by the EPA as the basis of the
proposed standards for each subcategory is identified.
WASHINGTON, D C • nESEARCI I TRIANGLE PARK, NC • LOS ANGELES, CA • CINCINNATI, OH
-------
SAN. Continuous
Background. There are three facilities that produce SAN using a continuous
process. Based on the available information, two of the facilities are controlling storage
vessels as would be required by the HON and, thus, were considered to be equivalent to
the HON. The third facility has five storage vessels, and the existing control at this
racility was considered to be more stringent than the HON requirements for new sources.
Based on these findings, the existing source MACT floor was determined to be equivalent
to the HON, and the new source MACT floor was determined to be more stringent than
the HON. As described in the general MACT floor memorandum (Docket No. A-92-45
Category n-B-28'). existing controls were compared to the HON requirements within the
vapor pressure ranges defined by the HON applicability criteria. For the analysis of new
source MACT floor, these vapor pressure ranges were: less than 0.1 psia, from 0.1 to 1.9
psia, and greater than 1.9 psia. Two of the five storage vessels are in the less than 0.1
psia vapor pressure range; the other three vessels are in the 0.1 to 1.9 psia vapor pressure
range. The existing level of control for the less than 0.1 psia vapor pressure range was
considered to be more stringent than or equivalent to the HON. The existing level of
control for the 0.1 to 1.9 psia vapor pressure range was also considered to be more
stringent than or equivalent to the HON. Overall, the existing control for this facility was
considered more stringent than the HON, and, as the "best" facility, it serves as the basis
for setting the MACT floor for new sources. Figure 1 illustrates the relationship of the
five storage vessels at this facility to the HON applicability criteria for storage vessels at
new sources. In addition to controlling more storage vessels than the HON would require,
this facility controls some storage vessels to different levels of control than required by the
HON. This facility controls one vessel through incineration, and since the new source
MACT floor must be based on the "best" performing facility, a control level equivalent to
incineration (i.e., 98 percent emission reduction) would be included as part of the MACT
floor definition. These differences played a part in determining that the existing control
for this facility is more stringent than the HON and in defining the MACT floor.
Options. Three options were identified for defining the MACT floor for new
sources. The first option was to define the MACT floor using the same applicability
-------
1?
"55
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a
5
• Controlled (4)
2.0
1.8
1.6
1.4
1.2
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0.8
0.6
0.4
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HON Applicability For
New Sources
f
-
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CONTROL
-
-
i i
• Uncontrolled (1)
CONTROL
•
•
• I A. I A ™
10 20 30 40 50 60 v 230
Vessel Capacity (1,000 gallons)
600
Figure 1. Comparison of Storage Vessel for "Best" SAN, Continuous Facility to
the HON Applicability Criteria for New Sources
-------
criteria as found in the HON (i.e., define vapor pressure and storage vessel capacities).
The second option was to define chemical-specific storage vessels and storage vessel
capacities. The third option was a combination of Option 2 and requiring the HON for
chemicals not specifically identified. These options are presented in Table 1.
TABLE 1. STORAGE VESSEL MACT FLOOR OPTIONS FOR
NEW SAN, CONTINUOUS FACILITIES
Option
1
2
3
Proposed Rule
Vapor Pressure
(psia)
0.0735 to < 0.1
0.1 to <1.45
^1.45
^1.45
Compound
Styrene
Maleic Anhydride
MMA
Acrylonitrile
MEK
Compound
Styrene
Maleic Anhydride
MMA
Acrylonitrile
MEK
Capacity
(gallons)
.£600,000
.£.40,000
> 8,000 to 40,000
.£40,000
Capacity
(gallons)
.£600,000
any size
.£40,000
>.40,OOP
.£8,000
Capacity
(gallons)
>.600,000
any size
.£40,000
.£40,000
.£8,000
Control Level
.£.90%
HON
.£.98%
HON
Control Level
.£,90%
HON
HON
HON
.£98%
Control Level
.£.90%
HON
HON
HON
.£98%
Any chemical not listed above: HON applicability and control level
KEY: MMA = methyl methacrylate; MEK = methyl ethyl ketone
Option 1 has the following advantages: (1) it creates a rule that is similar to the
HON and, thus, may be more familiar to industry and the EPA and (2) it is more generic
-------
than Option 2 in that it would be applicable to all chemicals, not just those known to be at
the "best" facility. Disadvantages of Option 1 are: (1) the vapor pressures proposed may
not actually reflect the maximum actual vapor pressure of the chemical and (2) the format
of the rule becomes more complicated (i.e., more levels are involved).
Option 2's advantages are: (1) by being chemical-specific, a facility avoids the need
to measure/calculate "maximum actual vapor pressure" and, thus, costs for determining
compliance are reduced and (2) the rule is much simpler to enforce and understand. A
disadvantage in being chemical-specific is that the applicability criteria may "miss" a
chemical used at a new facility that is not known to be used at the "best* facility. Based
on available information, one of the other two existing facilities has chemicals (ethyl
benzene) and other materials (recycle, tar and recycle) that are not found in the best
controlled facility. Second, without regarding the actual conditions at which a chemical is
stored, this option operates on a different premise for determining control/no control than
the HON. The HON premise considered that environmental conditions (i.e., storage
vessel temperature) should be considered at the specific facilities when determining
whether or not a storage vessel should be controlled. This option ignores the
environmental conditions of a storage vessel and requires control based solely on the
contents of the storage vessel.
Option 3 is an attempt to combine the advantages of Options 1 and 2 and avoid
Option 2's first disadvantage (i.e., miss a chemical at a facility).
Option Selected by EPA. While Option 2 has some strong advantages to it, its
disadvantages were considered too much to overcome. Option 3 deals with Option 2's
first disadvantage by applying the HON to other chemicals, but it does not resolve Option
2's second disadvantage. Further, while Option 2 will decrease compliance costs by
removing applicability determinations (i.e., vapor pressure determinations), these savings
may be offset by requiring control of vessels that under Option 1 would not require
control. Therefore, the EPA rejected Option 3. Based on these considerations, the EPA
selected Option 1 as the basis for the proposed standards. Figure 2 illustrates the
applicability criteria of Option 1 compared to the HON applicability criteria for storage
vessels at new sources.
-------
2.0
1.8
I 1-6
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£ 1.4
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5 0.6
0.4
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,
• Controlled (4)
• Uncontrolled (1)
HON Applicability For
New Sources
1
f
Definition of
MACT Floor
NO
CONTROL
i
CONTROL
•
. Definition of
MACT Floor
* • *
• i /v i /v _M
10 20 30 40 50 60 v 230
Vessel Capacity (1,000 gallons)
600
Figure 2. MACT Floor Applicability Criteria for New SAN, Continuous Sources
vs. HON Applicability Criteria
-------
ASA/AMSAN
Background. Only one facility was identified as producing ASA/AMSAN and all
the known storage vessels are controlled to achieve an emission reduction of 98 percent
through incineration. In a manner similar to new source MACT floor for SAN continuous
processes, the MACT floor must be based on the "best" performing facility for new
sources or the average of five "best" performing facilities for existing sources. Therefore,
a control level equivalent to incineration (i.e., 98 percent emission reduction) would be
included as part of the MACT floor definition since it is part of the "best" facility. Based
on their capacities and vapor pressures, only one of the storage vessels would require
control under the HON (See Figure 3). Based upon this comparison, this facility was
considered to be controlling storage vessels more stringently than the HON for both
existing and new facilities. Therefore, the MACT floor for both existing and new sources
needs to be based on the level of control being achieved at this facility. In addition, since
only one facility exists that produces this resin, the MACT floor will be the same for
existing and new sources and must ensure that this facility maintains its level of control.
Options. Four options were identified. The first three options are structured the
same as for SAN, continuous facilities, (i.e., vapor pressure and storage vessel capacity,
chemical-specific and storage vessel capacity, and a combination of Option 2 and the
HON). A fourth option considered was to simply require control of all storage vessels,
regardless of vapor pressure, chemical, or storage vessel capacity. Table 2 shows these
options.
The advantages and disadvantages of Options 1 through 3 are the same as discussed
previously for SAN, continuous facilities, although the degree of importance changes
somewhat. It seems, for example, that when dealing with only one known facility it
becomes more critical to set a correct vapor pressure (a disadvantage associated with
Option 1), that unknown chemicals are less likely to occur, and that deviating from the
HON's premise is less important (both disadvantages associated with Option 2). Option 3
becomes more attractive because of this shift in importance.
-------
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• Uncontrolled (0)
CONTROL
HON Applicability For
Existing Sources
_Jt „
HON Applicability For
New Sources
10 20 30 40
Vessel Capacity (1,000 gallons)
Figure 3. Comparison of Storage Vessel Controls for the Only ASA/AMSAN Facility to
the HON Applicability Criteria for Exisitng and New Sources
-------
TABLE 2. STORAGE VESSEL MACT FLOOR OPTIONS FOR
EXISTING AND NEW ASA/AMSAN FACILITIES
Option
1
2
3
4
Proposed Rule
Vapor Pressure
(psia)
0.077 to <0.47
£.0.47
Compound
AMST
ST/AN mix*
Acrylonitrile
Compound
AMST
ST/AN mix*
Acrylonitrile
Capacity
(gallons)
£.10,200
£.1,000
Capacity
(gallons)
£.10,200
£.1,000
£.20,000
Capacity
(gallons)
£.10,200
£.1,000
£.20,000
Control Level
>98%
£.98%
Control Level
£98%
£98%
£.98%
Control Level
£98%
£98%
£98%
Any chemical not listed above: HON
Control all storage vessels by at least 98%
KEY: * Styrene and acrylonitrile mixtures; AMST = alpha methyl styrene
Option 4 is the most simple to apply and covers the current situation directly. On
the other hand, it has the potential to cover storage vessels at new facilities that are not
represented by the existing facility.
Option Selected by EPA. Given that there is only one existing facility and no new
growth is projected for this subcategory, the EPA determined that it was most reasonable
to set the simplest rule that will maintain the current control scenario, which would be
achieved by either Option 2 or 4. Concern over setting the correct vapor pressure makes
-------
Option 1 less attractive. Between Option 2 and 4, the EPA favored Option 2 partly
because Option 4 may regulate storage vessels at the existing facility that are not currently
represented. On the other hand, Option 2 by itself would leave unidentified storage
vessels at the existing facility unregulated. Option 3 would avoid this last outcome.
Therefore, the EPA selected Option 3 for defining both the existing and new MACT floor
for storage vessels at ASA/AMSAN facilities.
ABSr Continuous Mass
Background. There are five facilities that produce ABS using a continuous mass
process. Based on the available information, two of the facilities are controlling storage
vessels as would be required by the HON, one facility is controlling storage vessels to a
level less stringent than the HON, and two facilities are controlling storage vessels to a
level more stringent man the HON. Since the majority of facilities (3 out of 5) control
storage vessels to a level less man or equivalent to the HON, the existing MACT floor
was considered to be equivalent to the HON. However, the new MACT floor must be
based on either of the two facilities controlling storage vessels to a level more stringent
than the HON.
Of the two facilities considered more stringent than the HON, one facility
controlled 40% of the total storage capacity that would not be required to be controlled by
the HON, and the other facility controlled 10% of the total storage capacity. The first
facility was selected as the "best" facility and serves as the basis for setting the MACT
floor for new sources. Figure 4 illustrates the relationship of the storage vessels at this
facility to the HON applicability criteria.
Options. Four options were identified. The first three options are structured the
same as for SAN, continuous and ASA/AMSAN facilities (i.e., vapor pressure and storage
vessel capacity, chemical-specific and storage vessel capacity, and a combination of Option
2 and the HON). Option 4 is a combination of Option 1 with one set of chemical-specific
and capacity and storage vessel criteria for styrene. These options are presented in
TableS.
10
-------
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1.8
¥ 1-8
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HON Applicability For
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nks) (3 U
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Figure 4. Comparison of Storage Vessel Controls for "Best" ABS, Continuous Emulsion
Facility to the HON Applicability Criteria for New Sources
11
-------
TABLE 3. STORAGE VESSEL MACT FLOOR OPTIONS FOR
NEW ABS, CONTINUOUS EMULSION FACILITIES
Option
1
2
3
4
Proposed Rule
Vapor Pressure
(psia)
0.0782 to <1.9
.>1.9
Compound
Styrene
Ethyl Benzene
Acrylonitrile
ST/EB/CU mix*
Compound
Styrene
Ethyl Benzene
Acrylonitrile
ST/EB/CU mix*
Capacity
(gallons)
£.12,000
>.10,000
Capacity
(gallons)
S> 12,000
£12,000
£49,000
Si 15,000
Capacity
(gallons)
£12,000
£12,000
£49,000
3s 15,000
Control Level
Same as HON
Same as HON
Control Level
Same as HON
Same as HON
Same as HON
Same as HON
Control Level
Same as HON
Same as HON
Same as HON
Same as HON
Any chemical not listed above: HON
Vapor Pressure
(psia)
0.0782 to <1.9
;>i.9
Capacity
(gallons)
> 12,000
_>10,000
Control Level
Same as HON
Same as HON
All styrene vessels ^ 12,000 Same as HON
12
-------
The advantages and disadvantages discussed for SAN, continuous facilities
concerning the first three options are applicable here. The advantages of the fourth option
are that it 1) carries with it the advantages of the first option and 2) ensures that styrene
storage vessels are controlled whereas they may not necessarily be controlled under Option
1. The disadvantages of the fourth option are the same as for the first option.
Option Selected by EPA. For the same reasons that Optjpn 1 was selected for
SAN, continuous facilities, the EPA considered Option 1 a strong choice for this
subcategory. However, styrene storage vessels are a specific concern for mis subcategory
because a large amount of styrene is stored and the reported vapor pressure of styrene
varies significantly within the gathered data. Option 4 addresses this concern by
specifically requiring that all styrene vessels above a certain capacity (i.e., 12,000 gallons)
be controlled. For this reason, the EPA selected Option 4 as the basis for the proposed
standards.
Selection of the Regulatory Alternative Beyond the MACT Flooy. As shown on
Figure 3, the "best" facility controls some of their styrene vessels and not others. In fact,
of the four styrene vessels, the three small vessels (i.e., 30,000 gallons) are controlled and
the one large vessel (i.e., 150,000 gallons) is not controlled. It is generally more cost
effective to control a larger vessel than a smaller one. Therefore, the EPA developed a
regulatory alternative to go beyond the MACT floor and require control of the larger
styrene vessel. The cost effectiveness of controlling this vessel was estimated to be
approximately $6,000 per ton of organic hazardous air pollutant (HAP) removed and no
adverse nonair environmental or energy impacts were expected to result from this option.
Considering this, the EPA judged these impacts to be reasonable and selected this
regulatory alternative as the basis of the proposed standards.
Nitrile
Background. Only one facility was identified as producing nitrile resin and all the
known storage vessels are controlled. Based on their capacities and vapor pressures, none
of the storage vessels would require control under the HON, and this facility was
considered to be controlling storage vessels more stringently man the HON for both
13
-------
existing and new facilities. Like ASA/AMSAN facilities, only one facility exists that
produces this resin, therefore the MACT floors will be the same for existing and new
sources and must ensure that this facility maintains its level of control.
Options. Because of the limited data for nitrile resin production (i.e., one facility
and one chemical stored), only one option was developed for defining the MACT floor.
Option Selected by EPA. The option selected by the EPA as the basis for the
proposed standards for this subcategory is a combination of the chemical-specific and
capacity criteria, similar to Option 2 for the other subcategories, and the HON. For
acrylonitrile storage vessels with capacities of 3,500 gallons or greater, control to the
HON level of control is required. All other chemicals must meet the HON requirements.
Polystyrene. Continuous
Background. There are 16 facilities that produce polystyrene using a continuous
process. Based on the available information, there are several facilities that are controlling
a majority of vessels that would not be required to be controlled by the HON for existing
sources or the HON for new sources. Therefore, the MACT floor was considered to be
more stringent than the HON for both existing and new sources.
The available data were used to determine the average of the best performing five
sources to define the existing source MACT floor. While there were several sources that
were more stringent than the HON requirements for new sources, there was only one
source with complete data. The new source MACT floor was based on data for this
facility.
Option Selected by EPA. Formal options were not developed for this subcategory.
Based on experience gained in defining the MACT floor for the previous four
subcategories, the following option was developed and selected as the basis for the
proposed standards. The MACT floor for both existing and new polystyrene continuous
sources is defined using the same criteria as in the HON (i.e., vapor pressure and vessel
capacity). Different criteria were developed for existing and new and are presented in
Table 4.
14
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TABLE 4. STORAGE VESSEL APPLICABILITY CRITERIA FOR
EXISTING AND NEW POLYSTYRENE CONTINUOUS SOURCES
Existing/New
Sources
Existing
New
Vapor Pressure
(psia)
> 0.28 to < 2.08
>i.2.08
>. 0.078 to < 0.09
^.0.09 to < 1.1
.> 1.1
Capacity
(gallons)
> 20,000
.>. 10,000
>. 29,500
^.12,000
>. 5,170
Control Level
same as the HON
same as the HON
same as the HON
same as the HON
same as the HON
15
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PACIFIC ENVIRONMENTAL SERVICES, INC.
JT-8-24
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: Leslie Evans
U. S. Environmental Protection Agency
FROM: Bennett King
Pacific Environmental Services
DATE: March 24, 1995
SUBJECT: Methodology for Estimation of Secondary Environmental Impacts
The purpose of this memorandum is to describe the methodology used to estimate the
secondary environmental impacts associated with the Group IV thermoplastics national
emission standards for hazardous air pollutants (NESHAP). This memoranda describes how
the secondary environmental impacts were estimated for those facilities for which there were
adequate data. For those facilities without adequate data, an estimate was extrapolated from
the estimates made for facilities with adequate data. This extrapolation procedure is
described in a separate memorandum (March 24, 1995, Methodology for Extrapolation of
Impacts).
The proposed standards are not expected to generate any adverse water impacts.
Depending on die methods selected to comply with the proposed prohibition of cooling tower
water in contact condensers, the amount of wastewater generated at poly(ethylene
terephthalate) (PET) facilities could decrease. The proposed standards are not expected to
increase the generation of solid waste at any Group IV thermoplastic facility. On the other
hand, the EPA judged that there would be energy impacts and associated secondary air
impacts as a result of the proposed rule, and these impacts were estimated and are presented
in this memorandum.
The estimation of energy impacts required to operate control devices is part of the
control cost and emission reduction estimation procedures associated with each control
device. The estimation procedures for control costs and emission reductions, as well as the
associated energy estimates, are described in a separate memorandum (March 24, 1995,
Summary of Cost, Emission Reduction, and Energy Impacts for Group IV Resins Sources).
Energy credits have been attributed to the control of equipment leaks. The estimation of
these energy credits is described in this memorandum. While this memorandum presents
both the energy and secondary air impacts, it only describes 1) the estimation of the
secondary air impacts of paniculate, sulfur dioxide (SOX), and nitrogen oxide (NOX)
associated with the energy impacts from the operation of control devices and 2) the
estimation of the energy credit associated with equipment leaks.
WASHINGTON. DC.- RESEARCH TRIANGLE PARK. NC • LOS ANGELES. CA • CNCMNATI, OH
-------
Results
Energy impacts include increased energy use (fuel) for the operation of control
equipment, energy credits attributable to the prevention of organic hazardous air pollutant
(HAP) emissions from equipment leaks, and secondary air impacts include the emissions of
particulates, SOX, and NOX associated with increased energy use. Under the proposed rule,
energy use is expected to increase by approximately 30,000 barrels of oil equivalent per year
(BOE/yr) for existing sources and 44,000 BOE/yr for new sources. At the same time,
energy credits attributable to the prevention of organic HAP emissions from equipment leaks
are approximately 17,000 BOE/yr for existing sources and 8,000 BOE/yr for new sources.
This results in a net increase of approximately 13,000 BOE/yr for existing sources and
36,000 BOE/yr for new sources. The emissions of secondary air pollutants associated with
this energy increase are 70 megagrams per year (Mg/yr) of all three pollutants for existing
sources and 80 Mg/yr for new sources.
These figures are related to the control of process vents, wastewater operations, and
equipment leaks. The impacts analysis for storage vessels was based on the use of internal
floating roofs which do not have any associated energy impacts. Further, the estimates above
do not include the projected energy savings associated with control of vacuum system air
emissions from the manufacture of PET. The majority of existing vacuum systems at PET
facilities are operated with steam jets, which are very energy intensive. The precise affect of
the proposed rule on the use of steam jets cannot be predicted with accuracy. However, it is
anticipated by the EPA that compliance with the proposed rule will, in almost all cases,
decrease the energy demand of the vacuum systems.
Tables 1 provides the secondary environmental impacts for each subcategory for
existing and new sources. The process total column contains the total estimated energy
requirement for the given subcategory. This number is comprised of steam, natural gas, and
electricity components. The fugitive energy credit column provides the total estimated
energy credit attributable to the control of organic HAP emissions from equipment leaks in
each subcategory. The total energy column contains the sum of the total estimated energy
requirements and energy credits. The three remaining columns provide the secondary air
impacts of particulates, SOX, and NOX.
For existing sources, five of the eighteen subcategories are estimated to require more
than 1000 additional BOE/yr of energy use and one of these is expected to require more than
10,000 additional BOE/yr. For both new and existing sources, energy savings are projected
for several subcategories.
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Table 1. Group IV Resins Secondary Impacts Summary Table
Subcategory
ABS. Cm
ABS, Ce
ABS, Be
ABS.Bs
ABS, Bl
MABS
MBS
Nitrite
PET. TPA, C
PET, TPA, B
PET, DMT, C
PET, DMT, B
PS, C
PS.B
PS, EPS
SAN.C
SAN, B
ASA/AMSAN
GRAND TOTALS
*************** EXISTING IMPACTS ***********************
Energy Impacts
Process Total
(BOE/yr)
173
13585
4077
272
0
22
1944
2
2351
0
192
6317
81
14
0
511
226
0
29767
Fugitive Energy^
Credit (BOE/yr)
-931
-274
-204
-28
-11
-14
-703
-23
-1567
-9
-3426
-2162
-5538
-574
-566
-228
-38
-426
-16719
Total Energy
(BOE/yr)
-757
13311
3873
245
-11
9
1241
-22
784
-9
-3234
4155
-5458
-560
-566
283
188
-426
13047
Secondary Air Impacts
Particulate
(Mg/yr)
0.01
0.72
0.28
0.02
0.00
0.00
0.12
0.00
0.29
0.00
0.01
0.31
0.01
0.00
0.00
0.07
0.03
0.00
1.87
SOx
(Mg/yr)
0.00
12.85
7.83
0.52
0.00
0.13
2.61
0.01
12.74
0.00
0.00
4.78
0.48
0.08
0.00
3.06
1.35
0.00
46.46
NOx
(Mg/yr)
0.10
9.07
3.10
0.21
0.00
0.03
1.37
0.00
2.56
0.00
0.11
4.10
0.09
0.02
0.00
0.58
0.26
0.00
21.60
-------
Table 1. Group IV Resins Secondary Impacts Summary Table
Subcategory
ABS, Cm
ABS. Ce
ABS, Be
ABS, Bs
ABS, Bl
MABS
MBS
Nitrile
PET, TPA, C
PET. TPA. B
PET. DMT, C
PET, DMT, B
PS, C
PS. B
PS, EPS
SAN.C
SAN.B
ASA/AMSAN
GRAND TOTALS
"**"*"""*• NEW IMPACTS *«««««*»««•"«
Energy Impacts
Process Total
(BOE/yr)
0
29219
0
272
3124
3083
0
399
6760
4
511
226
43598
Fugitive Energ
Credit (BOE/yr
-452
-194
-81
-26
Total Energy
(BOE/yr)
-452
29026
-81
247
Secondary Air Impacts
Participate
(Mg/yr)
0.00
1.48
0.00
0.02
SOx
(Mg/yr)
0.00
23.90
0.00
0.52
NOx
(Mg/yr)
0.00
19.15
0.00
0.21
NO NEW GROWTH PROJECTED FOR THIS SUBCATEGORY
NO NEW GROWTH PROJECTED FOR THIS SUBCATEGORY
-44
3080
0.16
2.74
2.06
NO NEW GROWTH PROJECTED FOR THIS SUBCATEGORY
-1567
-9
-2624
-1342
-1476
1516
-9
-2225
5418
-1473
0.32
0.00
0.02
0.33
0.00
12.74
0.00
0.00
4.78
0.02
2.99
0.00
0.23
4.36
0.00
NO NEW GROWTH PROJECTED FOR THIS SUBCATEGORY
NO NEW GROWTH PROJECTED FOR THIS SUBCATEGORY
-128
-33
383
193
0.07
0.03
3.06
1.35
0.58
0.26
NO NEW GROWTH PROJECTED FOR THIS SUBCATEGORY
-7975
35623
2.43
49.11
29.85
-------
Methodology
The estimated energy impacts reflect the energy associated with the application of
controls required to take a facility from existing control levels to the control levels of the
proposed rule. Once again, this memo describes 1) the estimation of the secondary air
impacts associated with the energy required to operate control devices and 2) the estimation
of the energy credits attributable to the control of organic HAP emissions from equipment
leaks.
Estimation of Energy Requirements and Secondary Air Impacts
As mentioned previously, estimates of energy requirements were made as part of
estimating emission reductions and costs associated with the application of controls and are
documented in a separate memorandum. Estimates of paniculate, NOX, and SOX emissions
are based on procedures documented in Chapter 7 of the background information document
(BID) for the Polymers Manufacturing New Source Performance Standards (NSPS) arid are
directly related to the estimated energy requirements (i.e., natural gas, electricity, and steam)
In brief, emission factors for paniculate, NOX, and SOX emissions associated with each form
of energy (e.g., steam) and the estimated energy requirement are used to estimate secondary
air impacts. Table 2 presents the emission factors associated with each form of energy.
Table 2. Secondary Air Emission Factors3
Form of Energy
Steam
Natural Gas
Electricity
Particulates
0.0729 lb/1,000 Ib
steam
0.01428 Ib/lO^tu
0.0004535 Ib/kWh
NOX
0.6256 lb/1,000 Ib
steam
0.2190 lb/106Btu
0.003887 Ib/kWh
sox
3.274 lb/1,000 Ib
steam
0.0005714
lb/106Btu
0.02034 Ib/kWh
aPolymer Manufacturing Industry - Background Information for Proposed Standards,
Chapter 7. U. S. Environmental Protection Agency. EPA 450/3-83-019a. October
1984.
Estimation of Energy Credits Attributable to the Control of Equipment Leaks
Energy credits were estimated to serve as a means of representing the benefit of
preventing the loss (i.e., emissions) of valuable organic HAP through the control of
equipment leaks. Energy credit estimates, as presented in Table 3, were determined by
multiplying the emission reductions (i.e., organic HAP not "lost") by the heating value for
individual organic HAP or by the average heating value for the set of organic HAP and then
-------
converting to barrels of oil equivalents (BOB). Since emissions and emission reductions of
organic HAP were not speciated, emission reductions were represented by the predominant
HAP emitted by each process (i.e., subcategory). This assumption is indicated on Table 3.
Table 3.
-------
Table 3. Equipment Leak Energy Credits
Subcategory
PS.C
PS.Bs
EPS
ABS.Ce
ABS.Cm
ABS.Be
ABS.Bs
ABS.BI
MABS
NHrile
MBS
SAN, C
SAN, B
AMSAN/ASA
PET. TPA.C
PET. TPA.B
PET. DMT.C
PET. DMT.B
Notes:
HAP Emitted
Styrene
Styrene
Styrene
Styrene
Butadiene
Acrylonitrile
Styrene
Butadiene
Acrylonitrile
Styrene
Butadiene
Acrylonitrile
Styrene
Butadiene
Acrylonitrile
Styrene
Butadiene
Acrylonitrile
Styrene
Butadiene
Acrylonitrile
Acrylonitrile
Styrene
Butadiene
Styrene
Acrylonitrile
Styrene
Acrylonitrile
Styrene
Acrylonitrile
Existing Source Credits
Ethylene Glycol
Ethylene Glycol
Ethylene Glycol
Ethylene Glycol
(BOE/yr)
5538
574
566
274
931
204
28
11
H
23
703
228
38
426
1567
9
3426
2162
New Source Credits
(BOE/yr)
1476
0
0
194
452
81
26
0
0
0
44
128
33
0
1567
9
2624
1342
a - The following heating values were taken from the HON database - styrene: 17606 Btu/lb, butadiene: 19165 Btu/lb,
and acrylonitrite: 9786 Btu/lb.
b - Heating value of 1 551 9 Btu/lb is average of styrene, butadiene, and acrylonitrite.
c - Assumed 1 49.700 BTU/gal oil (reference: Energy Reference Handbook. 1977) and 42 gal/barrel of oil.
d - Heating value of 1 8385.5 Btu/lb is average of styrene and butadiene.
e • Heating value of 13696 Btu/lb is average of styrene and acrylonitrite.A19
*
f - The following heating value for ethylene glycol was taken from Chapter 7 of the Polymers NSPS BID - 7,810 Btu/lb.
7
-------
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: Bennett King
Pacific Environmental Services, Inc.
DATE: March 24, 1995
SUBJECT: Baseline Emissions Estimates for the Group IV Thermoplastics
Purpose
This memorandum presents baseline emissions estimates of organic hazardous air
pollutants (HAP) for existing and new sources in the thermoplastic industry and provides
the methodology used to determine these emissions. The baseline emissions estimates are
estimates of the amount of organic HAP emitted from the industry prior to the application
of controls required by the proposed rule. The organic HAP emitted from the
thermoplastic industry includes styrene, butadiene, acrylonitrile, acetaldehyde, dioxane,
methanol, and ethylene glycol. The quantity of emissions for each individual organic HAP
was not determined, but acrylonitrile and styrene are estimated to comprise the largest
quantity of emissions. The organic HAP emitted by each subcategory are identified in
Table 1. These organic HAP are emitted from storage vessels, process vents, wastewater
operations, equipment leaks, and process contact cooling towers.
In general, emissions for storage vessels, process vents, wastewater operations, and
process contact cooling towers were taken directly from information submitted by each
facility when available. Exceptions to this are discussed in subsequent paragraphs.
Industry estimates of emissions were used because data were not provided to allow the
EPA to make independent estimates of emissions in all cases. However, in all cases, the
baseline emissions from equipment leaks were calculated by using component counts
provided by facilities and emission factors from EPA's Protocol document for equipment
WASHINGTON. D C • RESEARCH TRIANGLE PARK. NC • LOS ANGELES. CA • CINCINNATI. OH
-------
TABLE 1. MAJOR HAZARDOUS AIR POLLUTANTS EMITTED BY SUBCATEGORY
Subcategory
ABS
SAN
MABS
MBS
Polystyrene
PET
Nitrile
Major Organic HAP Emitted
acrylonitrile, butadiene, styrene
acrylonitrile, styrene
acrylonitrile, butadiene, styrene
butadiene, styrene
styrene
ethylene glycol, methanol, acetaldehyde, dioxane
acrylonitrile
ABS
SAN
MABS
MBS
PET
HAP
acrylonitrile butadiene styrene
styrene acrylonitrile
methyl methacrylate acrylonitrile butadiene styrene
methyl methacrylate butadiene styrene
polyethylene terephthalate)
hazardous air pollutant
leaks.1 The level of equipment leak control assumed for each facility was based on the
submitted information or was determined using other available information.2
Results
Baseline organic HAP emissions for each thermoplastic subcategory are presented in
Tables 2 and 3. As shown in the tables, the total nationwide estimated organic HAP
emissions are approximately 24,790 megagrams per year (Mg/yr) for existing sources and
14,930 Mg/year for new sources. Equipment leaks and process contact cooling tower
emissions comprise more than two thirds of the total baseline emissions for existing and
new sources. Of the remaining emissions, for both existing and new sources,
approximately 17 to 20 percent are from process vents, 1 percent are from storage vessels,
1 U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards.
Protocol for Equipment Leak Emission Estimates. EPA-453/R-92-026, June 1993.
2 Memorandum to Group IV Resins Docket No. A-92-45 from Ken Meardon.
Determination of MACT Floors for Equipment Leaks. December 22, 1994.
-------
TABLE 2. BASELINE ORGANIC HAP EMISSIONS FOR EXISTING SOURCES
Baseline Organic HAP Emissions for Existing Sources
(Mg/yr)
Subcategory
ABS, Be
ABS, Bl
ABS.Bs
ABS, Ce
ABS, Cm
MABS
Nitrile
SAN, B
SAN, C
ASA/AMSAN
MBS
EPS
PS, B
PS, C
PET TPA, C
PET TPA, B
PET DMT, C
PET DMT, B
TOTALS
Process
Vents
430
1
4
630
20
80
20
8
7
0
50
15
70
260
1,090
570
535
1,290
5,060
Storage
Vessels
6
0
1
15
6
2
0
3
4
0
3
3
10
60
3
1
80
100
310
Equipment
Leaks3
50
2
9
80
220
3
10
10
70
90
130
430
110
1,120
2,030
90
2,150
1,190
7,790
Wastewater
20
0
1
390
0
3
0
10
30
5
10
0
0
5
1,310
35
580
110
2,510
Cooling
Towers
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1,660
620
1,140
5,690
9,110
Total
500
3
15
1,110
240
90
30
40
110
100
190
450
190
1,440
6,090
1,320
4,480
8,390
24,790
-------
Footnotes to Table 2
a These values were determined by estimating equipment counts and applying SOCMI
factors taken from the EPA's Protocol document for equipment leaks which were
adjusted according to leak detection and repair (LDAR) programs.
Be = batch emulsion
Bl = batch latex
Bs — batch suspension
Ce = continuous emulsion
Cm = continuous mass
B = batch
C = continuous
PS = polystyrene
ASA = acrylonitrile styrene acrylate
AMSAN — alpha methyl styrene acrylonitrile
-------
TABLE 3. BASELINE ORGANIC HAP EMISSIONS FOR NEW SOURCES
Baseline Organic HAP Emissions For New Sources
(Mg/yr)
Subcategory3
ABS, B
ABS, Bl
ABS, Bs
ABS, Ce
ABS, Cm
MABS
Nitrile
SAN, B
SAN, C
ASA/AMSAN
MBS
EPS
PS, B
PS, C
PET TPA, C
PET TPA, B
PET DMT, C
PET DMT, B
TOTALS
Process
Vents
10
0
5
120
0
0
0
5
0
0
15
0
0
30
1,090
570
300
360
2,510
Storage
Vessels
0
0
1
1
2
0
0
3
1
0
0
0
0
15
3
1
80
40
150
Equipment
Leaksb
20
0
6
40
90
0
0
10
40
0
4
0
0
280
2,030
90
1,690
690
5,000
Wastewater
1
0
1
240
0
0
0
3
0
0
1
0
0
0
1,310
35
270
20
1,880
Cooling
Towers
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1,660
620
850
2,270
5,400
TOTAL
30
0
10
400
90
0
0
20
40
0
20
0
0
330
6,090
1,315
3,190
3,380
14,930
-------
Footnotes to Table 3
a See abbreviations from Table 5-1.
b These values were determined by estimating equipment counts and applying SOCMI
factors taken from the EPA's Protocol document for equipment leaks which were
adjusted according to leak detection and repair (LDAR) programs.
-------
and 10 to 12 percent are from wastewater operations. Based on the submitted data,
process contact cooling tower emissions are only present at poly(ethylene terephthalate)
(PET) facilities. The least amount of emissions are from the nitrile subcategory which
only contains one facility.
Methodology
This section describes 1) the estimation of emissions from equipment leaks, and 2)
why and when emissions data provided by industry were not used and independent
estimates were developed for storage vessels, process vents, wastewater operations, and
process contact cooling towers. In most instances, the emissions data provided by industry
were used; the development of independent emission estimates were the exception.
Equipment T^aV Emissions
Emissions data provided by industry for equipment leaks were not used. Instead,
emissions were estimated by determining the equipment component counts at each facility
(e.g. valves in gas service, pumps in light liquid service) and applying the appropriate
emission factors for each component category. Emission factors reported in the EPA's
Protocol document for equipment leaks were used. This approach to estimating emissions
for equipment leaks was taken to provide a consistent baseline for estimating the impacts
of various leak detection and repair (LDAR) programs in use for various subcategories and
to compensate for the fact that equipment leaks data provided by industry was not
complete. For the several facilities that provided specific and clear information, the
estimate of emissions were adjusted to account for low organic HAP concentrations and
reduced hours of operations. More information is available in the memorandum
"Determination of MACT Floors for Equipment Leaks"2 under the section titled
"Estimating Uncontrolled Emissions."
Exceptions to Industry Provided Data
As described earlier, the emissions estimates provided by industry for storage
vessels, process vents, wastewater operations, and process contact cooling towers were
used in the majority of cases. The exceptions to this are described in the paragraphs
below.
The first exception made is related to process vents, storage vessels, and
wastewater operations. Emissions and emission reductions were estimated based on
individual stream or tank characteristics as part of evaluating the application of controls.
Often these estimates did not correlate with the emissions data provided by industry.
When this situation occurred, the independent emissions estimates were used.
When emissions estimates were required under the first exception, emissions were
estimated using the methodologies found in the Background Information Document (BID)
-------
to the Hazardous Organic NESHAP (HON). In brief, storage vessel emissions were
estimated based on vessel capacity and the vapor pressure of the stored material. Both
breathing and working losses were estimated. Process vent and wastewater stream
emissions were estimated based on flowrate and organic HAP concentration. The HON
BID contains more detail, including example calculations. The appropriate chapters of the
HON BID have been placed in the docket (Docket No.A-92-45, Category II-A).
The second exception made is related to process contact cooling towers used in the
production of polyethylene terephthalate) (PET). As part of analyzing the regulatory
alternative for this emission point, the emissions data provided by industry were
manipulated through several assumptions. Independent emissions estimates were not made
as part of this manipulation.
Under the first assumption, average default emissions were assigned when a process
contact cooling tower was present and emissions data had not been provided by industry.
This assumption was made in an effort to verify the cost effectiveness of the evaluated
regulatory alternative across the entire industry. Second, emissions were adjusted to reflect
operations at full production capacity. This assumption was made to provide a
conservative evaluation of the regulatory alternative. Third, emissions associated with
some vacuum system condensate wastewater streams were assigned to the process contact
cooling tower to accurately reflect the emission reductions achieved by the second
regulatory alternative. In brief, the first regulatory alternative required control of some
vacuum system condensate wastewater streams but did not controlled the process contact
cooling tower emissions. The second regulatory alternative controlled these wastewater
streams and the process contact cooling tower emissions. Therefore, to accurately reflect
the emission reduction associated with the second regulatory alternative, the emissions
from these few wastewater streams were added to the process contact cooling tower
emissions; they were not included as wastewater emissions. Fourth, emissions from
process contact cooling towers associated with solid state PET processes were assigned to
the PET process or processes present at the facility where the solid state PET process was
located.
I:\n301\docu\baseline.val
cc: Ken Meardon, PES
Valerie Everette, PES
-------
, INC.
Central Park West
5001 South Miami Boulevard
PO Box 12077
Research Triangle Park, NC 27709-2077
(^ 9*1-0333 FAX <919> ™'023*
MEMORANDUM
TO: Leslie Evans
U.S. Environmental Protection Agency
FROM: Bennett King
Pacific Environmental Services
DATE: March 24, 1995
SUBJECT: Methodology for Extrapolation of Impacts
Purpose
This memorandum presents the methodology used to develop impacts (i.e., costs and
energy) for emission points for which sufficient data were not available upon which to make
individual estimates of impacts. For most facilities, data are sufficient to evaluate individual
emission points. However, for some emission points at facilities within certain
subcategories, data are not sufficient, and estimates of impacts for emission points within
these facilities were developed by extrapolating from the known impacts. Extrapolated
impacts were developed to support the economic impacts analysis.
Results
The extrapolation procedure was applied to process vents and storage vessels in the
polystyrene and acrylonitrile butadiene styrene (ABS) subcategories. For all other
subcategories, data were available to make individual estimates of impacts for all emission
points. For the other types of emission points (i.e., wastewater operations and equipment
leaks) at polystyrene and ABS facilities, it was not necessary to develop extrapolated impacts
for several reasons. For wastewater operations, analysis showed that no impacts were
expected as a result of the proposed rule. For equipment leaks, data required to develop an
individual estimate of impacts are available for all facilities.
Table 1 presents the data related to extrapolating total annual costs (dollars per year
($/yr)) to illustrate the methodology. Table 1 presents the individual emission point cost
WASHINUIIJN. U U • MbStAW .H I KIANOLh HAHK. NC • LOS ANGELES, CA • CINCINNATI, OH
-------
estimates used as the basis for the extrapolated impacts and the extrapolated cost impacts for
process vents. For each of the facilities within a given subcategory, the estimated impacts
are provided. The last column on each table identifies whether the estimated impacts were
made based on available data for the individual facility or based on the extrapolation
procedure. In all cases, the extrapolated impacts for storage vessels were zero, and these
results are not presented on Table 1.
Methodology
The two source categories for which extrapolation was done represent 9 subcategories.
Typically, one or more facility within each subcategory had individual emission point
estimates upon which to base the extrapolation. In one case, a subcategory (ABS using a
batch suspension process) did not have any facilities with individual emission point estimates
and it was assumed that a facility from a similar subcategory (ABS using a batch emulsion
process) could be used as the basis for extrapolation.
As mentioned earlier, in all cases the extrapolated impacts for storage vessels were
zero. Because there were no impacts associated with the proposed rule for those emission
points for which sufficient data were available, it follows that the extrapolated impacts would
also be zero. The remainder of the methodology discussion concerns process vents only.
For those facilities that required extrapolation, the following steps were followed to
develop an estimate of impacts. When extrapolating for existing source impacts, the process
vent baseline emissions for each facility were evaluated against a predetermined cutoff (2.2
tons per year (tpy)). The derivation of this emissions cutoff is discussed in a later paragraph.
When baseline emissions were greater than the emissions cutoff, a non-zero extrapolated
value was determined. When baseline emissions were equal to or less than the emissions
cutoff, the extrapolated value assigned was zero. When extrapolating for new source
impacts, the same procedure was followed with one exception. The first step for
extrapolating for new source impacts was to determine if a facility had been selected to
represent the projected new growth. If so, the extrapolation procedure continued, and if not,
an extrapolated value was not determined. (See the memorandum titled "Estimated New
-------
Growth for Group IV Resins Sources," dated December 21, 1994, for more details on the
projected new growth.)
Once a facility passed this initial "criteria," impacts were extrapolated using two
different methods. For the extrapolation of impacts associated with the application of
controls required by process vent provisions modeled after the Hazardous Organic NESHAP
(HON), impacts were extrapolated using the 6/10th rule. Impacts were extrapolated by
dividing the emissions for the "extrapolating facility" by the emissions for the "basis
facility," then this quotient was raised to the 0.6 power, and finally this product was
multiplied by the known impact. For the extrapolation of impacts associated with the
application of controls required by process vent provisions modeled after the Polymers
Manufacturing New Source Performance Standards (NSPS), impacts were based on an
average dollar (or energy amount) per megagram of emissions (e.g., $/Mg baseline
emissions). Impacts were extrapolated by multiplying the "impact factor" by the baseline
emissions of the "extrapolating facility." The decision criteria used to determine which of
the two methods described above should be used was based on the amount of data available.
If only one or two data sets were available for a subcategory, as was the case for impacts
associated with the application of controls required the HON, the 6/1 Oth rule was used. If
three or more data sets were available for a subcategory, the "impact factor" technique was
used.
The emissions cutoff referred to earlier, a value of 2.2 tpy, was determined to be the
minimum "size" emission point for which extrapolated impacts should be assigned. This
assumption was made to avoid extrapolating impacts to emission points that would not
require controls due to their small "size" (e.g., flowrates or hazardous air pollutant (HAP)
concentrations below applicability criteria). The value of 2.2 tpy was determined by
inspecting the group of process vents with the least amount of emissions that had to apply
controls as a result of the proposed rule.
I:\n301\docu\extrpol
cc: Ken Meardon, PES
Valerie Everette, PES
-------
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(\ -
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: Bennett King and Kenneth R. Meardon
Pacific Environmental Services
DATE: March 24, 1995
SUBJECT: Summary of Cost, Emission Reduction, and Energy Impacts for
Group IV Resin Sources
The purpose of this memo is to document the procedures used to estimate cost,
emission reduction, and energy impacts associated with the application of controls associated
with the proposed rule. The following paragraphs describe briefly the procedures used for
each type of emission point and refer the reader to specific docket items that contain more
detail.
Attachment 1 presents the cost and emission reduction impacts that were estimated
using the procedures described in this memorandum. Although energy impacts were
• estimated based on the procedures discussed in this memorandum, energy impacts are
^presented in a separate memorandum titled "Methodology for Estimation of Secondary
Environmental Impacts," dated March 24, 1995. Attachment 1 also includes some impacts
data associated with process vents at polystyrene and acrylonitrile butadiene styrene (ABS)
facilities that were developed by extrapolating from the data estimated using the subject
procedures. The memorandum titled "Methodology for Extrapolation of Impacts," dated
March 24, 1995, contains more detail on the extrapolation procedure and identifies which
facilities have "extrapolated" impacts.
Attachment 1 presents the costs and emission reductions for each facility. The
facilities are arranged alphabetically. In addition, summary tables for each subcategory are
included. The impacts data associated with the production of poly(ethylene terephthalate)
(PET) are considered to be confidential business information (CBI). Such information has
been deleted from the attached table, and is located in the U.S. Environmental Protection
Agency's CBI files. This confidential data is presented in a memorandum titled "Final Cost
Impacts for Polyethylene terephthalate) Facilities," dated October 28, 1994.
WASHINGTON, D C • RESEARCH TRIANGLE PARK, NC • COS ANUtLtS, CA • ONCINNAU OH
-------
Docket No. A-92-45
March 23, 1995
page 2
Storage Vessels
Storage vessels requiring control were assumed to be controlled through tank
improvements (i.e., installation of internal floating roofs) for the purposes of the impacts
analysis. A calculational spreadsheet for estimating impacts associated with tank
improvements was developed based on the procedures presented in the HON Background
Information Document (BID) and was used to estimate wastewater impacts for the Group IV
project. Storage vessel characteristics required to use the spreadsheet are storage vessel
capacity, storage vessel diameter, and annual emission reductions. Because the storage vessel
impacts were expected to be a minimal portion of the total impacts, it was decided, that only
tank improvements would be considered for developing impacts.
Detailed mforrnation on the storage vessel impacts procedure is presented in Volume
IB: Control Technologies of the HON BID (EPA-453/D-92-016b). Pertinent chapters of the
HQM BID, «"» avaii^hip in {ho ("fro'ip TV docket (Docket No. A-92-45, Item II-A-11).
Process Ventg
Two impact estimation procedures were used for process vents. One procedure for
process vents requiring control using a combustion device, and one procedure for process
vents requiring control using a condenser. Impacts for most continuous process vents were
estimated using the combustion device procedure, while impacts for all batch process vents
were estimated using the condenser procedure.
Process vents requiring control by a combustion device were those that were subject
to control under the provisions modeled after the Hazardous Organic NESHAP (HON)
process vent provisions. Process vents with a total resource effectiveness (TRE) value less
than or equal to 1.0 were required to be controlled. For purposes of the analysis, control
was achieved through the use of a combustion device and impacts for these process vents
were determined using the procedure developed and used for the HON. The process vent
stream characteristics used in the combustion device procedure are flowrate, hazardous
organic pollutant (HAP) concentration, molecular weight, heat content, emission rate, and
hours of operation. These data were either provided by industry as part of responding to
Section 114 questionnaires or were estimated based on available data. The procedure
assumes a fixed emission reduction of 98 percent and costs are estimated in 1989 dollars.
Energy impacts vary depending on the type of combustion device selected as optimal by the
procedure. This procedure is in a computer program format and is commonly referred to as
VENTCOST. Detailed information on the combustion device procedure is presented in
Volume IB: Control Technologies of the HON Background Information Document (BID)
-------
Docket No. A-92-45
March 23, 1995
page 3
(EPA-453/D-92-016b). Pertinent chapters of the HON BID are available in the Group IV
docket (Docket No. A-92-45, Item II-A-11).
Process vents requiring control by a condenser were those that were subject to control
under the provisions modeled after the Batch Processes Alternative Control Techniques
(ACT) document or after the Polymers Manufacturing New Source Performance Standards
(NSPS). In other words, the condenser procedure was used to estimate impacts for all batch
process vents and certain continuous process vents from polystyrene and PET processes that
required control. The condenser procedure was developed under the Polymers Manufacturing
NSPS rulemaking. Only one process vent stream characteristic is required to use the
procedure: emissions per mass of product produced. Like the combustion procedure, this
procedure is in a computer program format. The computer program version of this procedure
was available to PES through earlier EPA work. Costs are estimated in 1980 dollars and
were then escalated to 1989 dollars using the chemical engineering fabricated equipment cost
indices as follows:
Year Cost Index
1980 291.3
1989 392
Detailed information on the condenser procedure is available in the Group IV docket
.(Docket No. A-92-45, Item II-B-30).
Wastewater
Wastewater streams requiring control were assumed to be controlled through the use
of a steam stripper for the purposes of the impacts analysis. A calculational spreadsheet for
estimating impacts associated with steam strippers was developed under the HON and was
used to estimate wastewater impacts for the Group IV project.
The only wastewater stream characteristic required to use the spreadsheet is the
flowrate, expressed in gallons per minute (gpm). One change was made to the HON
wastewater impacts spreadsheet — the annualized capital cost factor was revised to reflect a
7% (rather than a 10%) interest rate over 15 years. Costs are estimated in 1989 dollars.
Detailed information on the wastewater impacts procedure is presented in Volume IB:
Control Technologies of the HON Background Information Document (BID) (EPA-453/D-92-
-------
Docket No. A-92-45
March 23, 1995
page 4
016b). Pertinent chapters of the HON BID are available in the Group IV docket
(Docket No. A-92-45, Item II-A-11).
Equipment Leaks
For equipment leaks, costing was based on the cost algorithm used in the HON. All
costs were estimated in 1989 dollars. In brief, costs were estimated for the purchase of an
analyzer; the labor costs associated with each leak detection and repair program, which varied
depending on the frequency of the inspections and the leak definition; and the costs for
various equipment used in complying with the standards (e.g., caps for open-ended lines).
were used. The costs were originally estimated in 1992 dollars, and were de-escalated to
\9S9 dollars usfng chemical engineering plant cost fndices as follows:
Tati COST IIIUCA. "
1992 358.2
1989 355.4
Material recovery credits were assumed for PET facilities using the dimethyl
terephthalate (DMT) process only. A recovery credit was estimated based on recovery of
methanol using a price of $0.068 per Ib of methanol.
Detailed information on the equipment leaks impacts procedure is presented in
Volume IB: Control Technologies of the HON Background Information Document (BID)
(EPA-453/D-92-016b). Pertinent chapters of the HON BID are available in the Group IV
docket (Docket No. A-92-45) at docket item II-A-1 1. Additional Group IV docket items
documenting the cost procedures are located at docket items II-B-11, II-B-12, and II-B-30.
Ethvlene Glvcol Jet Costing
As discussed in the Basis & Purpose Document and preamble to the proposed rule, the
impacts analysis for the proposed prohibition on the use of process contact cooling towers for
vacuum systems used in the production of PET is based on the use of ethylene glycol vacuum
jet systems as a replacement for the steam jet vacuum systems. Cost data for ethylene glycol
jets were available from a single source (Company XXX), and the cost data are declared to
be confidential business information (CBI) by Company XXX. The costs provided were for
a retrofit application of ethylene glycol jets, however, the retrofit related capital costs were
not provided and had to be approximated.
-------
Docket No. A-92-45
March 23, 1995
page 5
Costs were estimated for other PET facilities through the following procedure. First,
the capital, variable annual, and fixed annual costs for Company XXX were determined.
Recovery credits for ethylene glycol emission reductions were not estimated. Individual cost
components were extrapolated to other facilities using two techniques, both dependent on
production capacity.
The first technique was to use a 6/10th scaling factor based on the ratio of the
"extrapolated facility's" production and Company XXX's production. For these types of
calculations, the ratio of the extrapolated facility's production rate (or capacity) to Company
XXX's production rate (or capacity) was determined and raised to the 0.6 power. This
quotient
was multiplied by the appropriate cost component to determine the extrapolated cost. See the
equation below for an illustration of this technique.
Extrapolated Cost = (Extrapolated Facility Production Rate/Company XXX
Production Rate)*0.6 * Cost Component
The second technique uses a direct ratio of the production rates (or capacities) between
the "extrapolated facility" and Company XXX. The production rate (or capacity) ratio is
multiplied by the cost component to determine the extrapolated cost. See the equation below
for an illustration of this technique.
Extrapolated Cost = (Extrapolated Facility Production Rate/Company XXX
Production Rate) * Cost Component
Table 1 presents which extrapolation technique was used on each cost component.
The decision criteria for when to apply the 6/10th scaling factor and when to ratio directly
based on capacity reflects the sensitivity of a given cost component to production capacity.
Variable annual costs are directly related to the time of operation and/or amount of product
produced, therefore, these costs were extrapolated based directly on production capacity.
Other cost components are not as strongly related to production capacity, and these costs
were extrapolated using the 6/10th scaling factor.
-------
Docket No. A-92-45
March 23, 1995
page 6
Table 1. Application of Ethylene Glycol Jet Costs
to Other Facilities
Cost Category
Capital Costs
Variable Annual:
kjwrrrr**rax mi/iw OUSTS-,
Variable Amrttal:
variable costs
Fixed" Annuaf
Retrofit Application
6/1 Oth scaling factor
6/IOth scaling factor
Capacity ratio
6/TOtfi scafing factor
New Application
Incremental costs assumed
to be zero
6/10th scaling factor
Capacity ratio
Incremental costs assumed
to be zero
Table 1 also presents the differences between applying the known cost data to existing
or new facilities. The primary differences between a new or retrofit application are capital
costs and fixed annual costs (i.e., annualized capital costs). As mentioned previously, the
cost data provided by Company XXX were for a retrofit application, however, the retrofit
related capital costs were not provided. Retrofit capital costs were approximated by doubling
the direct capital costs and using the provided indirect capital costs without modification.
The capital costs for a new steam jet system were determined to be comparable to the costs
for a new ethylene glycol jet system. An estimate for a new steam jet system was made by
using the purchased equipment costs for a steam jet system, as provided by Company XXX,
and using the standard EPA factors for direct and indirect capital costs as shown in Table 2.
Direct installation costs include: foundation and supports; handling and erection; electrical;
piping; insulation and ductwork; painting; and site preparation. Indirect costs include:
engineering; construction and field expenses; contractor fees; start-up; performance test; and
contingencies. Based on the determination that capital costs were comparable, it was
assumed that the incremental costs between a new steam jet system and a new ethylene glycol
jet system were zero.
-------
Docket No. A-92-45
March 23, 1995
page?
Table 2. EPA Direct and Indirect Capital Cost Factors
Capital Cost Component
Direct Installation Costs
Indirect Costs
EPA Factor
30% of PEC
31% of PEC
PEC =* purchased equipment cost
Other assumptions that were made as part of extrapolating costs to other facilities are
related to emissions and emission reductions; these assumptions directly affect the evaluation
of the cost effectiveness of applying ethylene glycol jets. Emissions data on process contact
cooling towers were not available for all facilities. In order to develop emissions for all
facilities and as part of analyzing the impact of applying ethylene glycol jets for all facilities,
the emissions data provided by industry were manipulated through several assumptions.
Independent emissions estimates were not made as part of this manipulation.
Under the first assumption, average default emissions were assigned when a process
contact cooling tower was present and emissions data had not been provided by industry.
Second, emissions were adjusted to reflect operations at full production capacity. This
assumption was made to provide a conservative evaluation of the regulatory alternative.
Third, emissions associated with some vacuum system condensate wastewater streams were
assigned to the process contact cooling tower to accurately reflect the emission reductions
achieved by the use of ethylene glycol jets. Emissions were only included for "some" of the
vacuum system condensate wastewater streams because data were not available to estimate
emissions for all of these streams. The omission of emission reductions associated with these
streams for some facilities makes the impacts analysis of applying ethylene glycol jets more
conservative. Fourth, emissions from process contact cooling towers associated with solid
state PET processes were assigned to the PET process or processes present at the facility
where the solid state PET process was located. Finally, it was assumed that ethylene glycol
jets achieved a 98 percent emission reduction.
I :\n301 \docu\cost&er. mem
cc: Valerie Everette, PES
-------
ATTACHMENT 1
-------
SUMMARY TABLES
-------
MBS
Impacts Summary
By Sub-category
All Facilities
Existing
ftegutafeiy Atamitivt f 1
Total
«pK
(W
Variable
Fixad
Rccovtry
Total
Annu.ll?
Emiwion :
Reduction
**
StorajjfrTank*
^fgj^**'
•&?#&$ '""
$93.204
$174.426
$279,051
$0
$101.898
$68.140
$53,976
$0
$76,831
$66.534
$83,65$
($90.895)
$0
$178,729
$43,779
$137,631
18.19
109.32
5.00
$9.826
$400
$27,526
13241
$2,71*
9/12/94
-------
MBS
Impacts Summary
By Sub-category
Kaneka • Pasadena
(Option 1)
New
Rtgutetoiy AKwnatiy** 1
918.063
$405,446
$17.252
MBS
Rohm & Haas • Louisville
(Option 2)
fttjjulatory Alternative * 1
Total
-Capital
t«
Variable
Arimut
Fixed
Annual
M&I&!
Emlwfon
_$AVJfr *-^ *ZJ>
'Efmctiy
TOTALS
$106.394
$157.174
$279.051
$0
$138.150
$63,876
$53.976
$95.992
$34.955
$83.655
($84.941)
$6
$234.142
$43.889
$137.631
6.14
102.16
5.00
$38.134
$430
$27.526
S3.M9
MBS
Elf Atochem-Mobile
(Option 3)
Annual
$142,730
$0
$131,616
$0
$0
$91.572
$0
$0
$223,388
$0
$0
12.04
$18,554
par ^Hff n i ar ny-?>i
$223^88
-------
SAN.C
Impacts Summary
By Sub-category
All Facilities
Existing
ftogulatoiy AHwnatiy* *1
^ '
Total,
Capttal
Variabl*
Annual ..
Fixfd
Annual
ftoeovaiy
Total
^Cort ^
EflvcnmiMS
i •"•-.%
$194.786
$259.217
$0
$0
$56,976
$40.899
$0
$0
$25,033
$67.062
($27.407)
$0
$0
$54,602
$107.961
45.54
19.00
$1,199
$5.682
'-, \ » " '.. T OTALS
64.54
$2,519
9/12/94
-------
SAN.C
Impacts Summary
By Sub-category
Monsanto - Addyston
(Option 1)
New
RenuUtoiy Alternative ff 1
Total
Vartabl*
Anmtal
FteMl
>Aiinuat
Recovery
•dfotion
ifc»>i*mU'
,Cp*t
$0
$0
$0
$259,217
$40.899
$0
$0
$607
$67.062
($1^76)
$0
$0
$220
$107.961
19.00
$105
$5.682
TOTALS ,
$258,217
$41.7*9
($1376:
$108,181
21.10
$6.127
SAN.C
Dow-Midland
(Option 2)
N«w
rUflulttory Altomativt * 1
,, ..... ,.f..'
-------
SAN.B
Impacts Summary
By Sub-category
All Facilities
Existing
RtfluUtory AHamativt * 1
-
Total
Capital
'-($) "
Variabl*
Annual
Fixed
Annual
RMOVtiy
Total
Annual \
Emiaaion
Rfductton
TOTALS
$1,223
$81.858
$83,081
$0
$0
$1.255
$12.916
$14.170
$0
$0
$1,733
$21.177
$22.910
($4.223)
($4.223)
$0
$0
($1.236)
$34.093
$32.887
7.02
6.00
T3!6T
($176)
$5.682
$2.524
9/12/94
-------
SAN.B
Impacts Summary
By Sub-category
No Facilities
(Option 1)
Ntw
R*guUtoryAlt.rn.«y*f1
'
Total -,
V ""• '
CapHal
Variable
Aiiniul ^
Fbttd
Annual
\iirt
Total
Annual ,
Emission
Reduction
Storage TanJw
SO
$0
$0
so
so
so
so
so
so
so
so
so
10
$0
so
so
so
0.00
SAN.B
Monsanto • Muscatine
(Option 2)
Regulatory Alternative 11
Total
Capital
Variable
Annual
Fixed
Annual
Recovery
Annual
Emission
Cost
Effectiveness
S1.223
so
so
S963
$0
SO
SO
S1.544
SO
(S3.820)
SO
so
($1.312)
so
6.35
(S207)
$1^23
S963
S1.S44
$3,820)
$1,312}
6.35
I $207
-------
ASA/AMSAN
impacts Summary
By Sub-category
All Facilities
Existing
R«flutatory Attomativf * 1
'
Total
Capital „,,
Variablt
-•• Annual
Fixed
-Annual
Rtcovtry
'
Total
Annuat
; Emission
Rtductkm
Cost
Efftctivtnew
? imw
Storag»Tank«
$308,781
$238.177
$0
$0
$84.097
$51.636
$0
$0
$42,801
$75,686
($53.302)
$0
$0
$73.596
$127,322
88.61
5.00
$831
$25.464
$546,958
$135,733
$118,487
$53,302
$200,918
93.61
$2,146
9/12/94
-------
PS.C
Impacts Summary
By Sub-category
All Facilities
Existing
Regulatory Alternative It 1
Total
Capital
Variable
Annual
Fixed
Annual
^mission
Vents
Leaks
$32,700
$733,149
$10.777
$577.060
$8,579
$424.939
($154.311)
($588.346)
($134.955)
$413.652
162.14
897.10
($832)
$461
1267
1765.849
$587.837
$433.518
{$742,657)
$278.697
155127
11/29/94
-------
PS.C
Impacts Summary
By Sub-category
All Facilities
New
Capital
Variable
Fixed
Annul)
TbM
Cost
£ff«ctlv»nt*«
$2.045
$199.010
$1.204
$142.502
$538
$101.495
($3.277)
($156.809)
($1.535)1
$87.188
3.44
239.10
($448)|
$365
$201^55
$143.706
$102,033
(>160.0»6)
$85,653
242J4!
$353
11/29/94
-------
PS.Bs
Impacts Summary
By Sub-category
All Facilities
Existing
Regulatory Alternative * 1
Total
Capital
($)
Variable
Annual
Fixed
Annual
Racovwy
CmlMlon
Coat
$210,827
$87,128
$26,040
$104,528
$55,559
$60,958
($28,437)
($60.928)
$55,163
$104.558
33.21
92.90
$1.661
$1.125
'TOTALS
$297,955
$130,568
$116,518
1 $87 ,365)
$159,721
126.11
$1,267
11/30/94
-------
EPS
Impacts Summary
By Sub-category
All Facilities
Existing
RigqtotoiyAttemativ** 1
Total
Capital
t$)
Variable
Annual
Fixed
Annual
Coat
TOTAW
$112.917
$112,917
$61.390
$61,390
$47.915
$477915
($60.140)
$49.165
91.70
91.70
$536
^536
11/29V94
-------
ABS.Ce
Impacts Summary
By Sub-category
All Facilities
Existing
Rftgulatory Atternatfvt * 1
Tout
Capital
Variable
Annual
Fixed
Annual
Recovery
Total
Tanks
$3,537.793
$3.229
$427.671
$64.390
$880.164
$29.987
($11.098)
($27.498)
$1.296.737
$68.879
181.16
50.30
$7,158
$1.330
$3,541,022
$492,062
$910,151
($38,596)
$1,363,617
231.46
$5,891
11/29/94
-------
ABS.Ce
Impacts Summary
By Sub-category
All Facilities
New
Total
Capital
Variable
Annu«l
Racovtqt
$99.858
$3.391.735
$3.229
($339)
$836,198
$39.034
$34,141
$858.077
$18,558
($19.462)
$33,801
$1,692,275
$38,129
0.78
114.53
35.60
$43.335
$14.776
$1.071
$3.494.822
$874,892
$908,778
($19,462)
$1,7*4,206
150.91
$15690
11/29/94
-------
ABS.Cm
Impacts Summary
By Sub-category
All Facilities
Existing
Jqlatpry Alternative # 1
Total
Capital
Vartablt
Y" v!
f. X T
Total
;»iA
emission
;*•%%*
(?^1
Cost
$29,647
$176,822
$17,858
$88.648
$14.790
$74.746
($93.485)
$32.648
$69.909
15.47
171.00
$2.110
$409
TOTAIS
11/29/94
-------
ABS.Cm
Impacts Summary
By Sub-category
All Facilities
New
Regulatory Att»matlve*1
Total
Capital
Variable
Annual
Fixed
Annual
Recovery
cndtt
Total
Annual
Emission
deduction
Cost
$72,418
$76.198
($2,964)
$32,499
$24,760
$28,699
($45.430)
$21.796
$15.768
3.44
83.10
$190
$148,616
$29,635
$63.459
($48,430)
$37,863
88.84
$434
11/29/94
-------
ABS.Be
Impacts Summary
By Sub-category
All Facilities
Existing
ItMtifajmy.ftlttrnatlv* * .1
Total
Variable
Annual
Fxed
$409.420
$20.388
$161,442
$30.003
$122,131
$18,191
($20.446)
18.71
37.40
$15,156
$742
56TT
4429.808
$191.445
$140.322
($20,4461
11/29^4
-------
ABS.Be
Impacts Summary
By Sub-category
All Facilities
New
Total
Capital
ffl
variable
Annual -
- frfrrj ,
Anh«al
ToUl
Eff.
Cost
$17.848
$13,088
$9.211
($8.091)
$14,208
14.80
$960
$17,848
$13,088
$9,211
U30
$960
11/2894
-------
ABS.Bs
Impacts Summary
By Sub-category
AH Facilities
Existing
.Total
Cipttat
($)
Annual
Fixed
Ktcoy*ry
'^TCJM
:*>£.-
y *.£•••'i
$27.351
$666
$10,785
$1.534
$8.159
$1.243
($2.788)
($2.788]
$18.944
($11)
5.10
T5i
$90.208
($2)
128137
1M02
TOT
11/29/94
-------
ABS.Bs
impacts Summary
By Sub-category
All Facilities
New
fttgdafbiy Altmttttiv* * 1
" * " '
Total
Variable
Annual
Annual
; Recovery
Rtductipn
Co«
$27.351
$886
$10,785
$1.154
$8.159
$944
($2.569)
$18.944
($471)
0.21
4.70
$90.206
($100)
$28,237
$11,838
$8,103
»3,782
11/29/94
-------
ABS.BI
Impacts Summary
By Sub-category
All Facilities
Existing
AK«maOV« i 1
Total
Variable
Annual
FUed
Annual
Cwitt
Anpiul
$221
$372
$233
($1.093)
($489)
2.00
($244)
$221
$372
I $1,093)
$489
2.00
($244)
11/29/94
-------
MASS
Impacts Summary
By Sub-category
All Facilities
Existing
Regulatory Alternative * 1
S "" *
Tptal
Capital
"
Variable
Annual
Fixed
Annual
Recovery
Credit
Annual
iason
ReducUon
Effectivepws
$89,673
$10.603
$4.230
$23,629
$1.933
($36.113)
($1.366)
($1.881)
$4,797
37.97
2.50
($50)
$1,919
1W
TS35
172
$89,673
7OT3
$28.562
TSCT!
11/29/94
-------
Nitrile
Impacts Summary
By Sub-category
All Facilities
Existing
Regulatory Alternative ff 1
Total
Capital
Variable
Annul
Fixed
Recovery
Total
$8.770
$1,547
$7.125
$2,311
$3,498
03.267)
($4.460)
$591
$6.164
3.43
6.80
$172
$906
TOT/ttJS-
$8,770
$5,810
$8,755
os
11/29/94
-------
FACILITY SPECIFIC TABLES
-------
PS.C
Impacts Summary
by Facility
American Polymers-Oxford
Existing
Regulatory Alternative # 1
! % *j!i!^ '.
vA*W«s|ewatet -' v
, ^ ^tOTAS
Total
Capital
($)
$163
$163
Variable
Annual
' ($fyr)
$1.529
$1,529
Fixed
Annual.
(Vyr)
$944
$944
Recovery.
Credit
($/yr)
($984)
($984)
Total
Annual
($M
$1.489
$1,489
Emission
Reduction
' (M8/yr> -•
1.50
1.50
Cost
fm» . .t
cnectiveness
° v($fl*D) ,.
$992
$992
11Q9/&4
-------
PS.C
Impacts Summary
by Facility
Amoco Chemlcal-Joilet
Existing
Rtflulrtbiy Atomatlvt # 1
ToUl
Capital
($)
Variable
Annual
frfrfr *
.Annual
Rtcovtty
Cr«d1t
Annual
$10.622
$53,984
$3.325
$35.074
$2.799
$25,901
($62.696)
($45.643)
($56.572)
$15.132
65.82
69.90
($659)
$216
$64.806
$38,399
$28,700
($108,539)
($41,440)
135.72
($305)
11/29^4
-------
PS.Bs
Impacts Summary
by Facility
Amoco Chemical-Willow Springs
Existing
%
Regulatory Alternative f 1
Storage Tanks
s 2 'v' ^ VV*steWat*t- ~ o
*••, '^ 3? tb1jfti.S\ / „'
Total
Capital -.
$35.902
$12.087
$47,989
Variable
Annual
$4.302
$19.869
$24,171
Fixed
Annual
$9.461
$11.645
$21,107
Recovery
% ^tm>tt*
• vrean
($4.502)
($19.675)
($24,177)
Total
Annual
$9.261
$11.840
$21.101
Emission
Reduction
4.73
30.00
34.73
Cost
cnecuwnes*
$1,958
$395
$608
11/29A4
-------
PS.Bs; EPS
Impacts Summary
by Facility
Arco Chemlcal-Monaca
Existing
Rtfluittory Alternative * 1
^ , •. rvj«. \
*•
Total.
Capital
<$)-
Variable
Annual
Fixed
Annual
Raeovtiy
CiMit
Total
Artrtual
Emission
Rtf&etton
Cost
Effoetivttttst
$32,547
$11.074
$4.680
$11.496
$8.577
$7,014
($4.081)
($11.411)
$9.176
$7,098
4.02
17.40
$2,283
$408
$43,621
$16,176
$15,691
($15,492)
$16,275
21.42
$760
11/29/94
-------
PS,Bs
Impacts Summary
by Facility
Arco Chemlcal-Monaca
Existing
Regulatory Alternative # 1
Total
Capital
($)
.Variable
Annual
Fixed
Annual
Recovery
Ctvdit
*
Total
Annual
Emission
Redufctteh
Cost
$32,547
$11.074
$4.680
$11.496
$8.577
$7.014
($4.081)
($11,411)
$9.176
$7.098
4.02
17.40
$2.283
$408
$43,621
$16,176 $16,591 ($15,492) $16,275
21^2
$760
"These impacts are for both EPS and PS.B production. Data were not provided to allow distinction between the two processes.
11/29/94
-------
EPS
Impacts Summary
by Facility
Arco Chemical-Monaca
Existing
Regulatory Alternative * 1
Total
Capital
m
Variable
Annual
IfW
Fixed
Annual
Recovery
Credit
Total
Annual
, Emission
induction
Cost
Effectiveness
jStofageTanki
$11.074
$11.496
$7.014
($11.411)
$7.098
17.40
$408
$11,074
$11,496 $7.014 ($11.411)
$7,098
17.40
$408
"These Impacts are for both EPS and PS.B production. Data were not provided to allow distinction between the two processes.
11/29/94
-------
EPS
Impacts Summary
by Facility
Arco Chemical-Painesville
Existing
Regulatory Alternative # 1
Variable
.* •. ,• . .:•: .
Annual
Fixed
Annual
Recovery
Credit
Total
Annual
Emission
Reduction
'Cost
\ Storage Tank*
S '«£***.
' trocw
v% >
$16.467
$11.694
$7.076
($4.919)
$13.850
7.50
$1.847
$16,467
$11,694
$7,076
($4.919)
$13,850
7.60
$1,847
11/29^-1
-------
PS.C
Impacts Summary
by Facility
BASF-Holyoke
Existing
Regulatory Alternative # 1
»';-• ' •-•• ' ' •'" . ..' :
1 • . Storage Tanks : :
'•' : Process Vents : ; , '
I • Equipment Leaks ;.
•'• ' •.';"Was
-------
PS.C
Impacts Summary
by Facility
BASF-Holyoke
New
Regulatory Alternative #1
Storage Tanks. '..
:.: Process Vents : ..:
..:; Equipment Leaks . .
: ;;. WasteWater •
:TOTALS
Total
Capital
($)
$26.065
$26,065
Variable
.Annual
: ($Ayr) :
$2.428
$2,428
Fixed ;
Annual.
•:- (S/yr) .
$6,536
$6,536
Recovery
Credit
($/yr) :
($4.853)
($4,853)
Total :
Annual •••••
•-^.jm^-.
$4.112
$4,112
Emission
Reduction
%/yr) :
7.40
7.40
Cost
Effectiveness
X:::M$/MS)"-
$556
$556
11/29/94
-------
PS,C
Impacts Summary
by Facility
BASF-Joilet
Existing
Regulatory Alternative # 1
-
•t Storage Tanks
Process Vents
Equipment teaks
Wastewater
TOTALS
Total
Capital
($i
$1.337
$6,476
$7,813
Variable
Annual .
($/yr):.
$441
$72,999
$73.440
Fixed
. 'Annual
; • ($/yr)
$347
$38.453
$38,800
Recovery
: Credit
^Jyr) :
($6.308)
($52,795)
($59,103)
Total
Annual :
;: ($)yr) 7;
($5,520)
$58,657
$53,136
Emission
Reduction
;: (rtfli^r)
6.65
80.50
87.18
. Cost .
Effectiveness
:<$wio)
($830)
$729
$610
11/29/94
-------
PS,C
Impacts Summary
by Facility
BASF-Santa Ana
Existing
Regulatory Alternative # 1
- :' - ' ' •"..••'•'.
Storage Tanks
-.-.. '-Process Vents X •
. --.'-: ... Equipment Leaiw;: ::
: TOTALS
Total
Capital
($)
$468
$23.480
$23,948
Variable
: Annual .
($/yr)::: . :
$155
$1.827
$1,981
Fixed
Annual
t$/yr) ;
$122
$5.719
$5.841
Recovery
Credit
• (#yr);: :
($2.209)
($12,526)
($14.735)
Total
Annual :
•: • :-'($/yr) : .,'/•;
($1.932)
($4.981)
($6.913)
Emission
: Reduction
. . (Mg/yr) ::
2.33
19.10
21.43
Cost
Effectiveness
($/Mg) .
($829)
($261)
($323)
11/29/94
-------
EPS
Impacts Summary
by Facility
BASF-South Brunswick
Existing
Regulatory Alternative # 1
i ': : '•' '• . • • : •"• • ••'
:..'•• Storage Tanks
. ..Process Vents '..'.
• ;"•:; \EquipnrMJrit teaks ;•:> lv
. .: •: Wastewater :v :' ' '.:. :.'
'•w' • ' • . TOTALS -•'-.'•:-:' •'.' ••
Total
Capital
{$) .
$21.343
$21,343
Variable
Annual
($/yr)
$11.716
$11,716
Fixed
Annual
($/yr)
$9,870
$9,870
Recovery
Credit
:<$/yr)
($13.510)
($13,510]
Total
Annual
($/yrj
$8,075
$8.075
Emission
Reduction
(Mg/yrj
20.60
20.60
Cost
Effectiveness
; ($/Mg)
$392
$392
11/29/94
-------
ABS.BI
Impacts Summary
by Facility
BF Goodrich
Existing
Regulatory Alternative # 1
_: _ • . " 4
Storage Tanks .
Process Vents .:/
: : Equipment i*aks ...
•: •"'•' WastewateHv:: ..
TOTALS
Total
Capital
($)
$221
$221
Variable
Annual
($/yr)
$372
$372
Fixed
Annual
($/yr)
$233
$233
Recovery
Credit
<$/yr)
($1.093)
($1,093)
Total
Annual
<*/yr) :
($489)
($489)
Emission
Reduction
;{Mg/yr)
2.00
2.00
Cost
Effectiveness
v-(*/Mg)
($244)
($244)
11/29/94
-------
Nitrite
Impacts Summary
by Facility
BP Chemicals-Lima
Existing
Regulatory Alternative # 1
Storage Tanks
Process Vents
Equipment Leaks
Waslewater
$ TOTALS %
Total
Capital
v($V:: ••::••
$8.770
SO
$8,770
Variable
Annual .
{$/yo
$1,547
$7.125
$8.672
Fixed
Annual .
••:$&*:
$2.311
$3.498
$5,810
Recovery:
Credit:
vH$W--;;'
($3.267)
($4.460)
($7,727)
Total
Annual
'••.s;$jfi)V'.-
$591
$6,164
$6,755
Emission .
Reduction
^M&rf/i
3.43
6.80
10.23
. Cost
Effectiveness
f»($™igV?:'
$172
$906
$660
11/29/94
-------
PS.C
Impacts Summary
by Facility
Chevron Chemical-Marietta
Existing
Regulatory Alternative # 1
Storage Tanks
Process Vents
: ;JEquipm«int Leaks ;
.•'• ' :'.: ;Wasfewa'ter '.' : . .
. TOTAIS : : :
Total
Capital
($)
$83.685
$83,685
Variable
Annual
($ryr)
$140.036
$140,036
Fixed
Annual
($M
$74.706
$74.706
Recovery
.Credit
'•':-"($/yrV.-:;.
($135.823)
($135,823)
Total
Annual ..
>$:&&^::
$78,919
$78,919
Emission
Reduction
0:(«B/yr)
207.10
207.10
Cost
Effectiveness
v(V«g) •
$381
$381
11/29/94
-------
PS.C
Impacts Summary
by Facility
Chevron Chemical-Marietta
New
Regulatory Alternative # 1
»
! Storage Tanks
'Process Vents
; Equipment Leaks
•• Wastewater
4 TOTALS
Total
Capital
($)
$83.685
$83,685
Variable
Annual
(M
$140.036
$140,036
ft***..:
Annual
: ($/yr)
$74.706
$74,706
:. Recovery
Credit
($/yr) ..=.
($135.823)
($135,823)
Total
Annual. .
($^r) :
$78.919
$78,919
Emission
Reduction
VtifW).:
207.10
207.10
Cost
Effectiveness
; :.:-:($)Mg) '•
$381
$381
11/29/94
-------
PS.Bs
Impacts Summary
by Facility
Dart-Leola
Existing
Regulatory Alternative* 1
;.: ,: Storage TanKs. ::
'"''..'• . vFrpccsis Vents ;. • •'•'••••
."••':-•' :-:-Was'iewate'r.:' .:-:-. -V
: ^'.TOTALS
Total
Capital
"': '•'.'($)' "":
$102
$102
Variable
Annual
$1.895
$1,895
Fixed
Annual. .
$892
$892
Recovery
. .'.;CrBdlt:-.
($525)
($525)
Total .
Annual
$2,262
$2,262
Emission
Reduction
0.80
0.80
Cost
Effectiveness
$2,828
$2,828
11/29/94
-------
PS.Bs
Impacts Summary
by Facility
Dart-Owensboro
Existing
Regulatory Alternative # 1
. ... Storage Tanks
. '•'.- .Process Vents : :.
:i; : (Equipment Leaks '•&
V; .. :: Waslewater.:. . : ...•
^ •: TOTALS ^ t .-.?
Total
Capital
($)
$6.816
$6,816
Variable
Annual
<$/yr)
$22.890
$22.890
Fixed
Annual
Mr)
$11.093
$11,093
Recovery
Credit
($M
($4.001)
($4,001)
Total
Annual
($/yr)
$29.982
$29,982
Emission
Reduction
(Mgryr)
6.10
6.10
Cost
Effectiveness
($/Ms)
$4,915
$4,915
11/29/94
-------
PS.C; ABS.Cm
Impacts Summary
by Facility
Dow-Allyn's Point
Existing
Regulatory Alternative* 1
Storage Tanks
Process Vents
Equipment Leaks
Wastewater
•-r:v:TOTAlS •<:-";.•.
Total
Capital
($)
$2.045
$98.517
$100,562
Variable
Annual
"^<$W.^
$1.130
$56.653
$57,782
: Fixed
Annual
:
-------
PS.C
Impacts Summary
by Facility
Dow-AIIyn's Point
Existing
Regulatory Alternative # 1
;•: . ';• ;.. ....-: ".. • , •; -
, Storage Tanks
' Process Vents .
. Equipment Leaks
Wastewater
•^r.-..::TOTAlS---^:L.:.U.-
Total
Capital
($)
$2.045
$68.855
$70,900
Variable
Annual .
<*yr)
$1.130
$30,970
$32,100
Fixed
. Annual .
:<$/yr>
$538
$28,055
$28,594
Recovery
Credit
(i/yr)
($252)
($26,823)
($27,075)
Total
Annual
*$/yr) :
$1,416
$32,202
$33,618
Emission
'. Reduction .
(Mg^yr)
0.26
40.90
41.16
Cost
Effectiveness
I (VMfl)
$5.446
$787
$817
11/29/94
-------
ABS.Cm
Impacts Summary
by Facility
Dow-Allyn's Point
Existing
Regulatory Alternative # 1
Storage Tanks
Process.Vents
;; : Equipment Leaks .
.: Waslewater . :
TOTALS
Total
Capital
($)
$29.662
$29,662
Variable
Annual
(Vyr)
$25,683
$25,683
Fixed
Annual
($/yr)
$15.908
$15,908
Recovery
Credit
. ($/yr)
($26.046)
($28,046)
Total
: Annual
($/yr)
$13.545
$13,545
Emission
Reduction
fM&r)
51.30
51.30
Cost
Effectiveness
($/Mg)
$264
$264
11/29/94
-------
PS.C; ABS.Cm
Impacts Summary
by Facility
Dow-Hanging Rock
Existing
Regulatory Alternative # 1
¥ ••' ''• . •:'• •
•;•• Storage Tanks .
'..; • ProcessVents '-j'
; Equipment IJeaics
•'V'- "^Wastewaier-'--; . .
4-. TOTALS :.
Total
Capital
<$)
$238.632
$238,632
Variable
Annual
: iiw
$68.232
$68,232
Fixed:
' Annual
J$/yr);-
$78.763
$78,763
Recovery
Credit .
($/yr)
($97,372)
($97,372)
Total
Annual
($/yr) :
$49.623
$49,623
Emission
Reduction
(linger) :
162.30
162.30
Cost
Effectiveness
•: itmgY '•:
$306
$306
11/29/94
-------
PS.C
Impacts Summary
by Facility
Dow-Hanging Rock
Existing
Regulatory Alternative # 1
. . Storage Tanks .
Process Vents :<
: ; Equipment Leaks .x:.
' -• •:. "vVasiewaterx • . •''.•: "•
TOTALS •;
Total
Capital
' ••»)= ::
$162.434
$162.434
Variable
Annual
: ($/yr)
$35.733
$35,733
Fixed
Annual
(i/yo
$50,064
$50,064
Recovery
Credit
•• -WV /•:
($51.942)
($51,942)
Total
Annual
^^($^yrj;-:'
$33.855
$33,855
Emission
Reduction
::U
-------
ABS.Cm
Impacts Summary
by Facility
Dow-Hanging Rock
Existing
Regulatory Alternative # 1
* -
Storage Tanks.
Process.Venfs. •''•.
.-..:. '. Equipment Leaks .
Waslewater -," -;
K TOTALS-
Total
Capital
($)
$76.198
$76.198
Variable
Annual
WO
$32,499
$32,499
Fixed
Annual •
($/yr)
$28,699
$28,699
Recovery
Credit
($/yr)
($45.430)
($45.430)
Total
... 'Annual
:(«yr)
$15.768
$15,768
Emission
Reduction
(Mg/yr)
83.10
83.10
Cost
Effectiveness
($/Mg)
$190
$190
11/29/94
-------
ABS.Cm
Impacts Summary
by Facility
Dow-Hanging Rock
New
Regulatory Alternative # 1
Storage Tanks
Process Vents
J Equipment Leaks
Wastewater
TOTALS
Total
iCJiplial
$72.418
$76,198
$148,616
. Variable
Annual ; •':
($2.964)
$32.499
$29,535
Fixed
:. Annual.
$24.760
$28,699
$53,459
Recovery .
\; Credit' •••:
($45.430)
($45,430)
Tptal
;. Annual .,.•
$21,796
$15,768
$37,563
Emission
Reduction
3.44
83.10
86.54
Cost
Effectiveness
$6,336
$190
$434
11/29/W
-------
PS.C
Regulatory Alternative # 1
Storage TanXs
: Process Vents
Total
Capital
;<$)
Impacts Summary
by Facility
Variable
Annual
<$>yr)
Dow-Joilet
Fixed
Annual
Recovery .
Credit
Existing
Annual
Reduction
11.10
Effectiveness
($Wg) '
11/29/94
-------
PS.C; ABS.Be; ABS.Cm; SAN.C
Impacts Summary
by Facility
Dow-Midland
Existing
Regulatory Alternative # 1
Storage Tanks
.. • ' ' - ' -:. -"."••:" •• '••'. .' • '•'•
^Equipment Leaks >,:
"•':; -•'•': Wastewatef V :
TOTALS .:•-.
Total
Capital
<$)
$263.583
$263,583
Variable
Annual
($/yr)
$57.905
$57,905
Fixed
Annual
($/yr)
$34,536
$34,536
Recovery
Credit
. ($/yr):: v
($37,930)
($37,930)
Total
.Annual
•'- '••• ($^rj:::i":V,.
$54.510
$54,510
Emission/
Reduction
''"tMgiyF):'.':
63.00
63.00
Cost
Effectiveness
>:? :^$ffl)ifl) : :
$865
$865
-------
PS.C
Impacts Summary
by Facility
Dow-Midland
Existing
Regulatory Alternative # 1
Storage Tanks
. .. Process Vents
:V . Equipment Leaks ;... ;
' .r "'.-. Wastewater "-,."'••
.;:«f '• .TOTAUS^:;v :•
Total
Capital
($)
$63.258
$63,258
Variable
Annual
<$Vyr)
$4.638
$4,638
Fixed
Annual
Mr)
$16.881
$16,881
Recovery
Credit
Wyr)
($12.657)
($12.657)
Total
Annual
($Ayr)
$8,862
$8,862
Emission.
Reduction
(M*yr) .;
19.30
19.30
Cost
Effectiveness
:($/Mg)
$459
$459
11/29/94
-------
ABS.Be
Impacts Summary
by Facility
Dow-Midland
Existing
Regulatory Alternative # 1
Storage Tanks . : .>
Process Vents :;,
:; !;. AEquijpme%iit;Uat» ; ;
'•-. .:. . Wastewater . : .
:. TOTALS •
Total
Capital
($)
$17.848
$17.848
Variable
Annual
ii/yr)
$13,088
$13,088
Fixed
Annual
:($/yr)
$9.211
$9,211
Recovery
Credit
($Vyr)v:;:
($8,091)
($8.091)
Total
Annual .
•::. l;-;($/yr) '•-
$14.208
$14.208
Emission
Reduction
i(Mgfyr) ';•
14.80
14.80
Cost
Effectiveness
(Iffliig)
$960
$960
11/29/94
-------
ABS.Cm
Impacts Summary
by Facility
Dow-Midland
Existing
Regulatory Alternative # 1
:"'• Storage Tanks .... :
. ProcessVents .•'.. ' .
:. .,! Equipment Leaks ; '.
: Wasiewater ,: ;
.-•:••:. : TOTALS: ; .
Total
Capital
$4.289
$4,289
Variable
Annual
t**yo -
($4.092)
($4,092)
Fixed
.Annual
- - \*'7'l ••
($25)
($25)
Recovery
Credit
: \*/yo .
($2.023)
($2,023)
Total
. Annual
\vyn . .
($6.140)
($6,140)
Emission
Reduction
(Mg/yrj
3.70
3.70
Cost
Effectiveness
- - (*/Wg)
($1.659)
($1,659)
11/29/94
-------
SAN.C
Impacts Summary
by Facility
Dow • Midland
Existing
Regulatory Alternative # 1
Storage Tanks
Process Vents
- Equipment Leaks
Wastewater
TOTALS
Total
Capital
($)
$178.188
$178,188
Variable
Annual \
^ : <$Vyr) *>•!
$44.270
$44,270
Fixed
.Annual .
($/yr) :;
$8,470
$8,470
Recovery
Credit ..
•;:(*/yr)>;-
($15.159)
($15,159)
Total
Annual
,($/yr) v-i
$37.581
$37,581
Emission
Reduction
::-;(MgVyrK
25.20
25.20
Cost
Effectiveness
;.::>($rt«g) :
$1.491
$1,491
11/29/94
-------
SAN.C
Impacts Summary
by Facility
Dow - Midland
Existing
Regulatory Alternative # 1
Storage Tanks : :
: . Process Vents : . :
t; Equipment Leaks . :.
*•' . Wastewater . ? :
TOTALS
Total ;
Capital
($) "
$178.188
$178,188
Variable
Annual
$0
$0
$44,270
$0
$44,270
Fixed
Annual
$0
$0
$8,470
$0
$8,470
Recovery
: .tCreW-
($15.159)
($15,159)
Total
"'.Annual; '
$0
$0
$37,581
$0
$37,581
Emission
Reduction
-••••-.-:: -
-------
SAN.C
Impacts Summary
by Facility
Dow - Midland
New
Regulatory Alternative * 1
Storage Tanks
Process Vents :
Equipment Leaks -
: Wastewater: .
TOTALS
Total
Capital
($)
$178.188
$178,188
Variable
.Annual
<$/yr)
SO
SO
$44.270
so
$44,270
Fixed
"Annual
($/yr):
$0
$0
$8.470
$0
$8,470
Recovery
Credit
($V)
($15.159)
($15,159)
Total
Annual
' :'$%$,'?•
$0
so
$37.581
so
$37,581
Emission
Reduction
(MS/XT)
25.20
25.20
Cost
Effectiveness
:;-:::%($Hillj$vv':
$1.491
$1,491
9/12/94
-------
PS,C; ABS.Be; SAN.C
Impacts Summary
by Facility
Dow-Midland
New
Regulatory Alternative # 1
.' .. Storage Tanks .
' • . •••;'•• Process Vents;-: V '':•',.
':' ' • .'.' '. .' *• • \A/*»et AUf fl^Af " . " ' , • "- -•*; .
;._;• ••-• WWOlBWHWn ..".'•. ••'•
• ;:^':-;;:TOTAU:.%^-:"
Total
Capital
($) :.
$2.045
$259,294
$261,339
Variable
:. Annual .
? : ($/yr)
$1,204
$61,997
$63,201
Fixed
Annual
($fy>)
$538
$34.561
$35,099
Recovery
Credit
($Vr)
($3.277)
($35,907)
($39.184)
Total
Annual
• . . ($/y r)
($1,535)
$60,651
$59,116
Emission
Reduction
(Mgj/yr)
3.44
59.30
62.74
Cost
Effectiveness
($ffl|g) .-.:
($446)
$1.023
$942
11/29/94
-------
PS.C
Impacts Summary
by Facility
Dow-Midland
New
Regulatory Alternative # 1
.:.-.. . .. Storage T'nks '.
:'J/?::.;j%eeiis'&n£;; r ":•'",;
' : ./:;•: Equipment tiaks :.,.;.:'
•"''.'":':.• :?V^steVflrfer:: :^ • W
v;- .;••• TOTALS:'^- •••;•:
Total
Capital
•; •-'.•:($).• /
$2,045
$63,258
$65,303
Variable
'- Annual
W'Y
$1.204
$4,638
$5,842
Fixed
Annual.
-;:V:'^$^r);.^-:;
$538
$16.881
$17,419
Recovery
Credit
:;;:{&r) :
($3,277)
($12.657)
($15,934)
::T«tal .
: /.Annual .
^<&rWvJ
($1.535)
$8,862
$7,327
Emission
Reduction
••ftto^r)
3.44
19.30
22.74
Cost
Effectiveness
: •; <«Mg) ;-•
($446)
$459
$322
11/29/94
-------
ABS.Be
Impacts Summary
by Facility
Dow-Midland
New
Regulatory Alternative # 1
... .-.•:-.. : ,'••• •••.
.Storage Tanks
Process Vents
Equipment Leaks
Wastewater '
<• .TOTALS
Total
Capital
<$)
$17.848
$17,848
Variable
Annual
(Vyr)
$13.088
$13,088
Fixed
Annual
Mr)
$9.211
$9,211
Recovery
Credit
($W
($8.091)
($8.091)
Total
'.: Annual
($/yr) : :
$14,208
$14,208
Emission
Reduction
{Mflfyrjv
14.80
14.80
Cost
Effectiveness
($JMgj
$960
$960
11/29/94
-------
SAN.C
Impacts Summary
by Facility
Dow - Midland
New
Regulatory Alternative # 2
; Storage Tanks . : .
. ": ;;-Prbcess Vents ;..v'V. ;:
. ;;::;Eqqipm^nl.t6aks /,'.
vV'- '• Wastewater •'•?" \ -'•' >:-
: TOTALS :.:
Total
Capital .
($)
$178,188
$178.188
Variable
Annual
($'yO
$44,270
$44,270
Fixed
Annual
($/yr) ;
$8.470
$8,470
Recovery
Credit
... ($fyf)-:
($15,159)
($15,159)
Total
.Annual . .
:.5::.;---($fyr) ••••••?:.
$37.581
$37,681
Emission
Reduction
;:HWBfyr):
25.20
25.20
Cost
Effectiveness
; ,;,($/Wg) ...
$1.491
$1,491
11/29/94
-------
PS.C
Impacts Summary
by Facility
Dow-Riverside
Existing
-
Regulatory Alternative # 1
Storage. Tanks . : ;:
•:; Process' Vents''::.:1;
Equipment : teaks. :; -:x
;:'>' ''v^e^ifiF^^
:.: •;•' -TOTALS ;.-'.:" r
Total
Capital
($)
$2,077
$2,077
Variable
. Annual
($/yo
$14,886
$14,886
Fixed
Annual
(Vyr)
$6.637
$6,637
Recovery
Credit
($/yrj
($7.804)
($7,804)
Total
Annual
ivyr)
$13.719
$13,719
Emission
Reduction'
(Mgfyr)
11.90
11.90
Cost
Effectiveness
($/Mg)
$1.153
$1.153
11/29/94
-------
PS,C; ABS.Cm
Impacts Summary
by Facility
Dow-Torrance
Existing
Regulatory Alternative # 1
Storage Tanks :
/Process Vents •:•..
;;::> Equipment : teaiks . > ,.v
= • '.TOTALS :
Total
Capital .
($)
$92.016
$92.016
Variable
Annual
($/yr)
$52,867
$52,867
Fixed
Annual
($fyr)
$43.117
$43.117
Recovery
Credit
:::;.($/yr) :
($23,603)
($23,603)
: Total
Annual :i
'*••;'(&)$.?•?*
$72,381
$72,381
: Emission
Reduction
.:j;JM97jrr).
40.50
40.50
Cost
Effectiveness
"::.v($/Mg). .
$1.787
$1,787
11/29/94
-------
PS.C
Impacts Summary
by Facility
Dow-Torrance
Existing
Regulatory Alternative # 1
. Storage Tanks .
. . .Process Vents
X£.tequipmeht Leaks : .
:l;:'/- vVastewater "v .-.V
>v-: :..--. TOTALS ; : .:,!•.
Total
Capital
($)
$25.343
$25,343
Variable
Annual
.($/yr)
$21,674
$21.674
Fixed
Annual
($/yr)
$14,946
$14.946
Recovery
Credit
($/yr)
($8.788)
($8.788)
Total
Annual. :
($^r)
$27,832
$27,832
Emission
Reduction
(Mfl'yr)
13.40
13.40
Cost
Effectiveness
: ($/MB)
$2.077
$2,077
11/29/94
-------
ABS.Cm
Impacts Summary
by Facility
Dow-Torrance
Existing
Regulatory Alternative # 1
Storage Tanks
XV Process Vents -•
;,, EquiprnentM**:. :
' .'•"•"'•. Wastewater:;. ••••..
.TOTALS-::;
Total
Capital
($) '•-
$66.673
$66,673
Variable
Annual
($/yr)
$31,194
$31,194
Fixed
Annual
t$/yo
$28.171
$28.171
Recovery
Credit
; :($/yrj,;
($14.815)
($14,815)
Total
Annual
' ...: . ($/yr):....
$44.550
$44,550
Emission :
Reduction
i;(Mg/yry:'::
27.10
27.10
•..-.•Cost.-;.-
Effectiveness
:^:"WM'dl: ''••''
$1.644
$1,644
11/29^4
-------
MBS
Impacts Summary
by Facility
Elf Atochem-Mobile
Existing
Regulatory Alternative * 1
• ' :
Storage Tanks
Process Vents .. .
Equipment Leaks
Wastewater
TOTALS
Total
Capital
($)
$64,093
$64,093
Variable
: Annual
<$W
$0
$70,071
$0
$0
$70,071
Fixed
Annual .
<$W
$0
$52,387
SO
$0
$52,387
Recovery
:>Credit •:
.-tf£r)->
$0
: .Total
Annual
- ;;-:($^r}<^
$0
$122,459
$0
$0
$122.459
Emission
Reduetioh
R«^r):
12.05
12.05
Cost
Effectiveness
>^($/Mg)
$10.163
$10,163
9/12/94
-------
MBS
Impacts Summary
by Facility
Elf Atochem - Mobile
New
Regulatory Alternative* 1
Storage Tanks
. : Process Vents /
Equipment Leaks
. i::;Wastewater ..
TOTALS
Total
Capital
($)
$142.730
$142,730
Variable
Annual
i$/yr) ;
$0
$131,816
$0
$0
$131.816
Fixed
Annual.
'<$/yr) i
$0
$91.572
$0
$0
$91,572
Recovery
Credit
fev
$0
..",,Total;:
Ahhual
$0
$223.388
$0
$0
$223,388
Emission
Reduction
•tmtim
12.04
12.04
- .-."..P***:.:.:'-:
Effectiveness
:;-^i$«ifli:;:v
$18.554
$18,554
9/12/94
-------
PS.C
Impacts Summary
by Facility
Fina-Carville
Existing
Regulatory Alternative* 1
. . .Storage Tanks . ;
:;:.;':.;:v;Process'yiB.hl!S' V. \ ''•
;:*i;x'Equiprnent leaks . , ;.::
.:}• '..:' ^rWaslewaier '." ;.: :- :'C.
&i :'" ••.••;TOTAtS-vC T.: :-
ToUt
Capital
•w" =
$2,700
$56,079
$58,779
Variable
Annual
<$/yr)
$889
$72,587
$73,476
Fixed
Annual
(Vyr)
$702
$41.527
$42,229
Recovery
Credit
<$/yr)
($12.744)
($110,508)
($123,252)
Total
Annual
(»yr)
($11.153)
$3.606
($7,547)
Emission
Reduction
•tMgfyr)
13.40
168.50
181.90
Cost
Effectiveness
(i/Mg)
($832)
$21
($41)
11/29/94
-------
ABSCE
Impacts Summary
by Facility
GE Ottawa
Existing
Regulatory Alternative # 1
.Storage Tanks
: . .Process Vents
:;:.: Equipment teaks ;-;..^
' '•'•' : Wastewateri '. •••:
- •• : TOTALS
Total
Capital
($)
$3,229
$3,229
Variable
. Annual
($/yr)
$39,034
$39,034
Fixed
Annual
l$/yr)
$18,558
$18,558
Recovery
Credit
(i/yryv
($19,462)
($19.462)
Total
: Annual
•:^ff-^
$38,129
$38,129
Emission
.Reduction
-Mj/yr)^
35.60
35.60
Cost
Effectiveness
•v<$/M9) :;.
$1.071
$1.071
'1/29/94
-------
ABSCE
Impacts Summary
by Facility
GE Ottawa
New
Regulatory Alternative # 1
: Storage Tanks
Process Vents
Equipment Leaks
Wastewater
'-, TOTALS
Total
Capital
($) • '
$99,858
$3,391.735
$3,229
$3,494,822
Variable
Annual
:.{$^r)
($339)
$836,198
$39.034
$874,892
Fixed
Annual . •
• («yr)
$34.141
$856,077
$18.558
$908,775
Recovery
. Credit
:. 1$W /:
($19.462)
($19,462)
Total
Annual
<$/y»
$33,801
$1.692,275
$38,129
$1,764,206
Emission
Reduction
(Mfl/yr)
0.78
114.53
35.60
150.91
Cost
Effectiveness
($/Mg)
$43,335
$14.776
$1.071
$11,690
11/29/94
-------
PS.C; ASA/AMSAN
Impacts Summary
by Facility
GE Plastics-Selkirk
Existing
Regulatory Alternative # 1
. . : Storage Tanks
.; '.":.'..• Process Venfe;; . • .
. /;;:;§ EquipnvBht leaks.; ;: ;
""••:". ":; WasteWater" .;:-— ' "
TOTALS .
Total
Capital
tt)
$324.437
$238.177
$562.614
Variable
Annual
<$/yr) :
$119.804
$51.636
$171,440
Fixed
Annual
:.'<$w
$60.129
$75.686
$135,815
Recovery
Credit
:^^yr) •<'
($86,094)
($86,094)
Total
Annual /
($^rV :
$93,839
$127,322
$221,161
Emission
Reduction
;, (iftgjyr)
138.61
5.00
143.61
: COSt
Effectiveness
.::/($niig) .-
$677
$25.464
$1,540
11/29/94
-------
PS.C
Impacts Summary
by Facility
GE Plastics-Selkirk
Existing
Regulatory Alternative # 1
Storage Tanks.
• .'• Process Vents ::;, /,-.-•_
:/.:• Equipment Leal^...;:;;
-.-:• •• ;':.Wastewater--:. • .. •.
-V .x •'TOTAlSle:: •;••••
Total
Capital
($)
$15,656
$15,656
Variable
Annual
MO
$35.707
$35,707
Fixed
Annual
$17.328
$17,328
Recovery
Credit
($32.792)
($32,792)
Tptal
Annual
•:($/jrr) '•-::.
$20,243
$20,243
Emission
Reduction
: (Mg/yr) •.*
50.00
50.00
Cost
Effectiyeness
:;>; ($/MflV '•',
$405
$405
11/29/94
-------
ASA/AMSAN
Impacts Summary
by Facility
GE Plastics-Selkirk
Existing
Regulatory Alternative # 1
:. Storage Tanks ;
•"'-: . .Process.Vents ... .'••"•
Equipment Leaks .. .
' '.'•'".•'•:. vYastewater ••''
TOTALS
Total
Capital
($)
$308.781
$238,177
$546,958
Variable
Annual.
(Vyr) :
$64,097
$51,636
$135.733
Fixed
Annual
(VyV
$42,801
$75.686
$118,487
Recovery
Credit
: fr/yV); ;;
($53,302)
($53.302)
Total
Annual
^Mri^:.
$73.596
$127.322
$200,918
Emission.
Reduction .
miyr)
88.61
5.00
93.61
Cost
Effectiveness
' ($/M9) !
$831
$25,464
$2.146
11/29/94
-------
ABS.Be; ABS.Ce; MABS
Impacts Summary
by Facility
GE Plastics-Washington
Existing
Regulatory Alternative # 1
r4
34
28
Fixed
Annual
M$//r)
$903,793
$19,074
$922,866
Recov
Cnw
($/y
($47
($1:
($6(
Total
Annual
$1,294.856
$47,771
$1,342,626
Emission
Reduction
219.13
24.80
243.93
Cost
Effectiveness
(t/Mg)
$5,909
$1,926
$5.504
11/29/94
-------
ABS.Be
Impacts Summary
by Facility
GE Plastics-Washington
Existing
Regulatory Alternative # 1
Storage Tanks . .
- . Process Vents
.':'.". Equipment (leaks ..' .
: : Wastewater .
TOTALS
Total
Capital
($>
SO
$0
Variable
Annual
(*M
$12.667
$12,667
Fixed
Annual
($/y>)
$5.711
$5.711
Recovery
Credit
•:..a*yrK:-
($4.155)
($4.155)
Total
Annual
:•':-. WrTK'V:
$14.223
$14,223
Emission
Reduction
^Hflryr) ;
7.60
7.60
Cost
Effectiveness
: : t$/Mg) -
$1.871
$1,871
11/29/94
-------
ABS.Ce
Impacts Summary
by Facility
GE Plastics-Washington
Existing
Regulatory Alternative # 1
• -' :. ' -.' ' '.':.. • • •':
j Y;.: Storage Tanks . .
' ' -::: ?• 'Process Vents ' ;. ': .'
:.:h;:Equiprr«riit Leaks . '•/,_
:V-V ^VVi/astewater .: = •
-£..=• .'.:.:TOTALS.>,-- -f '.'.
Total
Capital
' "•-•!($) :';'.
$3,537.793
$0
$3.537,793
Variable
Annual
Mr)
$427.671
$25.357
$453,028
Fixed
Annual .
<$*r)
$880.164
$11.430
$891,593
Recovery
Credit;
: ($>yrj:;:
($11.098)
($8.036)
($19,134)
Total
Annual
x ::&yr).
$1,296.737
$28,750
$1,328,487
Emission
Reduction
(Mg/yr)
181.16
14.70
195.86
Cost
Effectiveness
($Wg)
$7.158
$1,956
$6,768
11/29/94
-------
MASS
Impacts Summary
by Facility
GE Plastics-Washington
Existing
Regulatory Alternative # 1
Storage Tanks
Process Vents
Equipment IjeaXs
•• Wastewater
TOTALS
Total
Capital
. .:($)
$89.673
$0
$89,673
Variable
V Annual. .
(iffr) ' .'
$10.603
$4.230
$14,833
Fixed
-..Annual
;i:::($r/r).
$23.629
$1.933
$25,562
Recovery.
Credit
""sflj/M'V'
($36.113)
($1.366)
($37.479)
: .Totaj
Annual.
'. '•"'•'{$#r)';:"'v.
($1.881)
$4.797
$2,916
Emission .
Reduction
.r.ntliiiiryrK:?;
37.97
2.50
40.47
Cost
Effectiveness
<£;;t$/MjgV:'-
($50)
$1.919
$72
11/29/94
-------
SAN.C
impacts Summary
by Facility
General Electric - Bay St. Louis
Existing
Regulatory Alternative # 1
Storage Tanks "".
.. Process Vents :
Equipment leaks
Wastewater -.'-,. ::
TOTALS
Total
Capital
($)
$16.598
$16,598
Variable
Annual
($/yr»
SO
$0
$11,817
$0
$11,817
Fixed
Annual
($/yr)
$0
$0
$15,956
$0
$15,956
Recovery
Credit
<$/yr>
($10,972)
($10,972)
Total
, Annual
:{$M i
$0
$0
$16,801
$0
$16,801
Emission
Reduction
-------
ASA/AMSAN
Impacts Summary
by Facility
General Electric - Selkirk
Existing
Regulatory Alternative # 1
Storage Tanks
Process Vents :
Equipment Leaks
: Wastewater :
TOTALS :
Total
Capital
($) ""?•
$308.781
$238.177
$546,958
Variable
: Aiiihual
Mr)
$0
$0
$84.097
$51.636
$135,733
Fixed
Annual
MO
$0
$0
$42,801
$75,686
$118,487
Recovery
: Ciidit "
WT)
($53,302)
($53,302)
Jotal
Annual
^<$>yr)
$0
$0
$73,596
$127,322
$200,918
Emission
Reduction
fcgV)
88.61
5.00
93.61
••:••. VCost
Effectiveness
^wfawigV
$831
$25.464
$2,146
9/12/94
-------
ASA/AMSAN
Impacts Summary
by Facility
General Electric • Selkirk
No new growth projected
New
Regulatory Alternative # 1
Storage Tanks
. Process .Vents
Equipment Leaks .
Waslewater '.•'.
TOTALS
Total
Capital
($)
$0
Variable
Annual
($/yr)
$0
$0
$0
$0
$0
Fixed
Annual
:{$/yr)
$0
$0
$0
$0
$0
Recovery
Credit
: {$JVr):::
$0
Total
.Annual
: ($Jyr)
$0
$0
$0
$0
$0
Emission
Reduction
(Mg/yr)
0.00
; Cost
Effectiveness
($ft«fl)
9/12m
-------
PS,C
Impacts Summary
by Facility
Huntsman Chemical-Belpre
Existing
Regulatory Alternative * 1
. Storage Tanks ::.: ••-•
.". Process Vents '.":
:. ''Equipment Leaks .;;,:
Wastewater ::
: TOTALS "" '-':--
Total
Capital
($)
$8.770
$46.670
$55,440
Variable
. Annual :
($/yr)
$2.612
$50.852
$53,464
Fixed
Annual
($/yr)
$2.309
$44.708
$47.017
Recovery
Credit .
($/yr)
($38,207)
($28.987)
($67,194)
Total
Annual
($/yr)
($33,287)
$66.573
$33,287
. Emission
.Reduction
: iwigjyr) :
40.11
44.20
84.31
Cost ..
Effectiveness
($/Mg)
($830)
$1.506
$395
11/29/94
-------
PS.C; PS.Bs
Impacts Summary
by Facility
Huntsman Chemical-Chesapeake
Existing
Regulatory Alternative #1
Storage Tanks '
. .' Process Vents . :•.•.:••
. r Equipment Leaks .!;.:.:•
• ' . Wastewater 70 '-•'-.
..:v::->rTOTALS;./;;.-:- •
Total
Capital
•<$)
$66.091
$0
$66,091
Variable
Annual .
(i^r) ;:
$7.918
$19.093
$27,011
Fixed
. Annual
tsw
$17.417
$13,749
$31,166
..Recovery
': Credit
($/yr).; •
($8.288)
($8.985)
($17,273)
iTotal
.;-;.,'• .-:. ':
Annual.
• ^r);:i;
$17.048
$23,857
$40,905
Emission
; Reduction
{ftB^rjf
13.10
13.70
26.80
Cost
Effectiveness
••t-H$*ia)y'
$1.301
$1.741
$1,526
11/29/94
-------
PS.C
Impacts Summary
by Facility
Huntsman Chemical-Chesapeake
Existing
Regulatory Alternative # 1
... Storage Tanks
Process Vents
• Equipment Leaks ,: .
Wastewater "..-
TOTALS
Total
Capital
<$)
SO
SO
Variable
Annual .
<$>yr)
S14.122
$14,122
Fixed
Annual
(S/yr)
$11,197
$11,197
Recovery
Credit
($/yr)
($6,624)
($6.624)
Total
Annual
($/yr)
$18,695
$18,695
Emission
Reduction
(Mg/yr)
10.10
10.10
Cost
Effectiveness
•(S/Mg)
$1.851
$1,851
11/29794
-------
PS.Bs
Impacts Summary
by Facility
Huntsman Chemical-Chesapeake
Existing
Regulatory Alternative # 1
Storage Tanks .
. Process Vents ;: .
,: . Equipment Leaks : . .
-• Waslewaiftr: ;; V
«. TOTALS :
Total
Capital
W
$66.091
$0
$66,091
Variable
Annual
($/yr)
$7,918
$4,971
•
$12,890
Fixed
Annual
($/yr>
$17.417
$2.552
$19,969
Recovery
Credit
($/yr)
($8.288)
($2,361)
($10,649)
Total
. Annual
: ($/yr)
$17.048
$5.162
$22,210
Emission
Reduction
: MB/yr}
13.10
3.60
16.70
Cost
Effectiveness
($/Mg) :
$1.301
$1.434
$1,330
11/29/94
-------
PS.C; PS.Bs; EPS
Impacts Summary
by Facility
Huntsman Chemical-Peru
Existing
Regulatory Alternative # 1
Storage Tanks
Process Vents
Equipment Leaks
Wastewater
* TOTALS
Total
Capital
<$)
$54,332
$66,038
$140,370
Variable
. Annual .
<$M
$6,808
$77.518
$84,326
Fixed
Annual
($/yr) V-
$14,317
$47,702
$62,019
Recovery
Credit: .
:l$Ayr):
($13.353)
($50.499)
($63,852)
; Total
Annual .
.::.<$/yr)::::
$7.772
$74.721
$82,493
Emission :
Reduction
(MoVr) •
16.11
77.00
93.11
Cost
Effectiveness
'••Wiite)^
$482
$970
$886
11/30/94
-------
PS.C
impacts Summary
by Facility
Huntsman Chemical-Peru
Existing
Regulatory Alternative # 1
Storage Tanks .
: .',. Process Vents .•
J _':>•' Equipment teaks .
"":•' -. Wastetfater "-.-.. .
TOTALS ;:: .
Total
Capital
<$)
$1.424
$46.905
$48,329
Variable
Annual
: . <$/yr)
$469
$44.207
$44,676
Fixed
Annual
(Sfyr)
$374
$27,763
$28,137
Recovery
Credit
'. ($/yr): .
($6.719)
($33,316)
($40,035)
Total
. Annual .
Wyr) ?\
($5.875)
$36.653
$32.778
Emission
.Reduction
•/.••/(MoJyr).-'. ':
7.07
50.80
57.87
Cost
Effectiveness
v;;.-{$iig) ".
($831)
$761
$566
11/29/94
-------
PS.Bs
Impacts Summary
by Facility
Huntsman Chemical-Peru
Existing
Regulatory Alternative # 1
.'-.= . . Storage Tanks .. .
;.:::: Process Vents.: - •....'.
.,'Hv Equipment Leaks '/>.- •.•
: ''•". . •'' Wastewater •;• • • :
:::*- :' 'TOTALS
Total
Capita)
($)
$52.908
$12.144
$65,052
Variable
Annual
. ::($tyr)
$6.339
$14.084
$20,423
Fixed
• Annual .
($/yr)
$13,943
$7,219
$21,161
Recovery
Credit :
;: ($/jrr) ;,S
($6.634)
($6.034)
($12,668)
Total
.Annual .
: ,($/yr)
$13.647
$15,269
$28,916
Emission
Reduction
; (Mgfyr) ••=:'
9.04
9.20
18.24
Cost
Effectiveness
: f$/Mg)
$1.510
$1.660
$1,585
11/30/94
-------
EPS
Impacts Summary
by Facility
Huntsman Chemical-Peru
Existing
Regulatory Alternative # 1
Storage Tanks
Process Vents
... Equipment Leaks
Total
Capital
($)
$26.989
Variable
Annual
MO
$19,227
$19,227
Fixed
Annual
l$W
$12.721
$12,721
Recovery
Credit
Mr) '••:•
($11,149)
($11.149]
Total
Annual
••l^yrr.:^
$20,799
$20,799
Emission
Reduction
:
-------
EPS
Impacts Summary
by Facility
Huntsman Chemical-Rome
Existing
Regulatory Alternative # 1
Storage Tanks
Process Vents
: . Equipment Leaks " :
'•'•': •", Wastewater . • '''•"."•'.-
=•- : TOTALS '•:'. ••'
Total
Capital
($)
$5.008
$5,008
Variable
Annual
($/yr)
($6,266)
($6.26$)
Fixed
Annual
MO
($1.169)
($1,169)
Recovery
Credit
($/yr)
($722)
($722)
Total
: Annual
($M
($8.157)
($8,157)
Emission
Reduction
Wyr)
1.10
1.10
Cost
Effectiveness
, ($mig)
($7.415)
($7,415)
11/29/94
-------
PS.C
Impacts Summary
by Facility
Kama-Hazelton
Existing
Regulatory Alternative # 1
Storage Tanks
/•!'• ••• ''• Process Vents '.• • . .
•...: Equipment Leaks
' . * .-"••:"•• . - -\:: : : •• •<. .', : •• ' •• :•:• •- •: . . "•
•;. ':-.-.";.-'>; Wastewater • ';
TOTALS
Total
Capital
($)
$5.334
$0
$5,334
Variable
. Annual
: ($>yr)
$1.756
$0
$1,756
Fixed
Annual
:($AyO
$1,387
$0
$1,387
Recovery
Credit .:
: ($/yr)
($25.176)
$0
($25,176)
Total .
Annual
($/yr) :
($22,033)
$0
($22.033)
Emission
Reduction
: (M9^rj
26.50
$0
26.50
Cost
Effectiveness
:($/Mg).-:
($831)
NA
($831!
11/29/94
-------
MBS
Impacts Summary
by Facility
Kaneka - Pasadena
Existing
Regulatory Alternative it 1
Storage Tanks
. . Process Vents .
Equipment Leaks
Wastewater . .
TOTALS
Total
Capital
($)
$17,252
$17,252
Variable
Annual
($W
$0
$0
$4.264
$0
$4,264
Fixed
Annual
<$/yr)
$0
$0
$1,580
$0
$1,580
Recovery
Credit'
($/yr)
($5,954)
($5,954)
Total
Annual '".
<$/yr)
$0
$0
($111)
$0
($111)
Emission
Reduction
(Mg/yr>
7.16
7.16
Cost
Effectiveness
($/Mg)
($15)
($15)
9/12/94
-------
MBS
Impacts Summary
by Facility
Kanaka - Pasadena
New
Regulatory' Alternative # 1
Storage Tanks . .
Process Vents
Equipment Leaks .
Wastewaler
TOTALS
Total
Capital
($)
$18,083
$405.446
$17.252
$440,781
Variable
Annual .
Mr)
$6.183
$136.592
$4.264
$0
$147,039
: Fixed
Annual
($/yr)
($3.367)
$94,900
$1,580
$0
$93,113
Recovery
Credit!:
<$>yr)
($5.954)
($5,954)
Total
Annual
-«\
$2.816
$231,492
($111)
$0
$234,198
EmiMion
Reduction
>iWrn
1.65
7.68
7.16
16.49
. ...::Co»t.,..
Effectiveness
-r(VMg)/-;:
$1.707
$30,142
($15)
$14,202
9/12/94
-------
Impacts Summary
by Facility
PS,C; ABS.Be; ABS.Bs; ABS,Cm;SAN,B;SAN,C
Monsanto-Addyston
Existing
Regulatory Alternative # 1
... Storage Tanks
."•;••;'. Process Vehts :
. . ; Equipment Leaks .
WasteWater
£ TOTALS •-.
Total
Capital
: ($)
$29.647
$7,816
$341.075
$378,538
Variable
Annual
<$W
$17,858
$6.445
$53.815
$78,118
Fixed
Annual
($/yr)
$14,790
$5.707
$88.239
$108,736
Recovery
Credit
(Wyr)
($8.250)
($8,250)
Total
Annual
($'yr)
$32.648
$3.902
$142.054
$178,604
Emission
Reduction
(Mg/yr)
15.47
14.07
25.00
54.S4
Cost
Effectiveness
($/Mg)
$2.110
$277
$5.682
$3,275
11/29/94
-------
SAN,B;SAN,C
Impacts Summary
by Facility
Monsanto • Addyston
Existing
Regulatory Alternative # 1
Storage Tanks
.Process Vents
Equipment Leaks
Wastewater
TOTALS
Total
Capital
($)
$0
$341.075
$341,075
Variable
Annual
($W :
$0
$0
$1.180
$53,815
$54.995
Fixed
Annual
($/yr)
$0
$0
$796
$88,239
$89,034
Recovery
Credit
MO
($1.679)
($1,679)
Total
Annual
<$*r)
$0
$0
$297
$142.054
$142,351
.Emission
Reduction
(rtgJyr)
2.77
25.00
27.77
Cost
Effectiveness
-($/«g)
$107
$5.682
$5,126
9/12/94
-------
PS,C
Impacts Summary
by Facility
Monsanto-Addyston
Existing
Regulatory Alternative # 1
•* . ' ' •
Storage. TanKs
' f ::". .!-.:: process Vehts ..'•.' : -V.
o'v Equipment Leaks .
-•: ': '^•WasiewateK-,--'-^-:
'.rs;- ;'T;-TOt*LSx:- •• .^..
Total
Capital
($)
$7.816
$7,816
Variable
Annual
($/yr)
$727
$727
Fixed
Annual
($Vr)
$1,937
$1,937
Recovery
. Credit
i$>yr)
($2,361)
($2,361)
Total
Annual
: (^) . .
$303
$303
. Emission
Reduction
•IM^/yr) ;
3.60
3.60
Cost
Effectiveness
($«ig)
$84
$84
11/29/94
-------
ABS.Be
Impacts Summary
by Facility
Monsanto-Addyston
Existing
Regulatory Alternative # 1
Storage Tanks
Process Vents
Equipment Leaks :
: . Wastewater ;'.
TOTALS
Total
Capital
($)
$0
$0
Variable
Annual
(*/yr)
$793
$793
Fixed
Annual
($/yr)
$683
$683
Recovery
Credit
Mr)
($820)
($820)
Total
Annual
($/yr)
$656
$656
Emission
Reduction
(Mg/yr) ;
1.50
1.SO
Cost
Effectiveness
(VMg)
$437
$437
It/29/94
-------
ABS.Bs
Impacts Summary
by Facility
Monsanto-Addyston
Existing
Regulatory Alternative # 1
'••'•'•- %
Storage Tanks: ; ~:;:
;:•.•• Process Vents "."'."•:. ;.':
V Equipment teaks / : ! :
•:'::''-:-;'vVastevwterv/X':-"
: f TOTALS : :
Total
Capital
($)
$0
$0
Variable
Annual
-------
SAN.B
Impacts Summary
by Facility
Monsanto - Addyston
Existing
Regulatory Alternative * 1
Storage Tanks
.Process Vents :
Equipment Leaks
Wastewater
TOTALS
Total
Capital
($)
SO
$81,858
$81.858
Variable
Annual \
($/yr);
$0
$0
$291
$12.916
$13,207
Fixed
Annual
($W
$0
$0
$189
$21.177
$21,366
Recovery
Credit :
(Wyr)
($403)
($403)
Total
Annual "
($/yr):
$0
$0
$77
$34.093
$34,169
Emission
Reduction
: (Mg/yr)
0.67
6.00
6.67
,::;HCo«t.;..:...
Effectiveness
s$?$aiaif&
$114
$5,682
$5,123
9/12/94
-------
ABS.Cm
Impacts Summary
by Facility
Monsanto-Addyston
Existing
Regulatory Alternative # 1
: .Storage Tanks :
:.:;:'. .• -Process Verits ..-.: ;:
:/ Equipment Leaks ;/•
Total
Capital
($) :
$29,647
SO
$29,647
Variable
Annual
($/yr)
$17,858
$3.366
$21,224
Fixed
Annual
MO
$14.790
$1,993
$16,783
Recovery
Credit
($>yr)
($3.171)
($3,171]
Annual
($/yr)
$32.648
$2.188
$34,836
Reduction
(MgTyr)
15.47
S.80
Effectiveness
($/Mg)
$2.110
$377
$1,638
11/29/94
-------
SAN.B
Impacts Summary
by Facility
Monsanto-Addyston
Existing
Regulatory Alternative # 1
Storage Tanks.
. . .Process Vents
. : Equipment Leaks
' ' '•' .-."•-''Wasfewater'^-..'.^-..'.'.--'
TOTALS:
Total
Capital
• ($):
$0
$81.858
$81.858
Variable
Annual .
<$>yr)
$291
$12,916
$13.207
Fixed
Annual
($/y>)
$189
$21.177
$21,366
Recovery
Credit
($/yr)
($403)
($403)
Total
. Annual
::($/y>)
$77
$34,093
$34,169
Emission
Reduction
Waft*)
0.67
6.00
6.67
Cost
Effectiveness
' :-n$7MgV:.:-'v
$114
$5.682
$5,123
11/29/94
-------
SAN.C
Impacts Summary
by Facility
Monsanto-Addyston
Existing
Regulatory Alternative # 1
Storage Tanks
''-. /Process Vents .:
: .. .Equipment Leaks . :.
. .' Wastewater :i.:.: ...
TOTALS =..•-..
Total
Capital
($)
$0
$259.217
$259.217
Variable
. Annual
: (Vyr)
$889
$40.899
$41.789
Fixed
Annual
($M
$607
$67.062
$67,669
Recovery
Credit
<$>yr)
($1.276)
($1,276)
Total
Annual
:($/yr)
$220
$107.961
$108,181
Emission
Reduction.
-------
SAN.C
Impacts Summary
by Facility
Monsanto - Addyston
Existing
Regulatory Alternative # 1
Storage Tanks
.Process Vents
Equipment Leaks
: Wastewater
TOTALS
Total
Capital
<$)
$0
$259.217
$259,217
Variable
Annual
<$M
$0
$0
$889
$40,899
$41,789
Fixed
Annual
<$/yr)
$0
$0
$607
$67.062
$67,669
Recovery
Credit
<$M
($1.276)
($1,276)
Total
Annual
<$W
$0
$0
$220
$107.961
$108,181
Emission
Reduction
(Mg/yr)
2.10
19.00
21.10
Cost
Effectiveness
<$/i«8) ;
$105
$5,682
$5,127
9/12/94
-------
SAN.B
Impacts Summary
by Facility
Monsanto - Addyston
New
Regulatory Alternative # 1
Storage Tanks :
.... ... Process Vents.: .
Equipment Leaks
Wastewater
TOTALS
Total
Capital
($)
$0
$81,858
$81.858
Variable
Annual
<$/yr)
$0
$0
$291
$12,916
$13,207
Fixed
Annual
($/yr)
$0
$0
$169
$21,177
$21,366
Recovery
Credit
<$W
($403)
($403)
.Total
Annual
^r)
$0
$0
$77
$34,093
$34,169
Emission
Reduction
ftgTyr)
0.67
6.00
6.67
;::Cpst
Effectiveness
iv:($/Mfl)
$114
$5,682
$5,123
9/12/94
-------
SAN,B;SAN,C
Impacts Summary
by Facility
Monsanto - Addyston
New
Regulatory Alternative # 1
Storage Tanks
. . Process Vents vi-
Equipment Leaks :-.
Wastewater :
TOTALS
Total
Capital
($)
$0
$341.075
$341,075
Variable
Annual
($/yr)
$0
$0
$1,180
$53.815
$54,995
Fixed
Annual .
($/yr)
$0
$0
$796
$88,239
$89,034
Recovery
Credit
($Vr)
($1.679)
($1,679)
Total
Annual
1$>yr)
$0
$0
$297
$142.054
$142,351
Emission
Reduction
(Mg/yr)
2.77
25.00
27.77
/.-.Cost .'•;:;
Effectiveness
($/Mg) :.•'-.
$107
$5.682
$5,126
9/12/94
-------
SAN.C
Impacts Summary
by Facility
Monsanto - Addyston
New
Regulatory Alternative # 1
Storage Tanks.
Process Vents :
Equipment Leaks
. Wastewater
TOTALS
Total
Capital
($)
$0
$259,217
$259,217
Variable
Annual
<$W
$0
$0
$889
$40,899
$41,789
Fixed
Annual
<$W
$0
$0
$607
$67,062
$67,669
Recovery
Credit
<$#r)
($1.276)
($1,276)
Total
Annual
(m
$0
$0
$220
$107,961
$108,181
Emission
Reduction
(Mg/yr);
2.10
19.00
21.10
Cost
Effectiveness
^
-------
ABS.Be; ABS.Bs; SAN.B
Impacts Summary
by Facility
Monsanto-Muscatine
Existing
Regulatory Alternative # 1
•Storage Tanks . .
. Proces^ Vents ; : .
%• Equipment Leaks-, ::
• Vi/a'stewater '':.'•::.-•'••'
TOTALS :
Total
Capital
($)
$436.771
$4.649
$441,420
Variable
. Annual
tiir) :••-.
$172.227
$5.572
$177,798
Fixed
Annual .
j {$^ir) ":"„
$130.290
$5.075
$135,365
Recovery
•Credit..
;>::-.$y:r'V 0
($13.769)
($13,769)
Total
Annual ..
:;:($/yr)>:;
$302,517
($3.122)
$299,395
Emission
Reduction
•.^{toifrift'v
16.92
24.55
43.47
Cost
Effectiveness
..: J<$/iWgl J
$15.989
($127)
$6,887
11/29/94
-------
SAN.B
Impacts Summary
by Facility
Monsanto - Muscatine
Existing
Regulatory Alternative # 1
'"'''. ,' . ' . :• '
Storage Tanks .
. . .Process Vents '.
Equipment Leaks
:• Wastewater
TOTALS
Total
Capital
($)
$1,223
$1,223
Variable
Annual
-------
ABS.Be
Impacts Summary
by Facility
Monsanto-Muscatine
Existing
Regulatory Alternative # 1
. . Storage Tanks :
Process Venls
: :; jEmiiprnent Leaks •'- v
vtastewater ; .
TOTALS
Total
Capital
($)
$409.420
$2,540
$411,960
Variable
Annual
($/yr)
$161.442
$3.454
$164.896
Fixed
Annual
Wr)
$122.131
$2.587
$124,718
Recovery
Credit
($/yr)
($7.380)
($7,380)
Total
Annual .
($>yr) :
$283.573
($1,339)
$282,234
Emission
Reduction
tMQ'yr} :
18.71
13.50
32.21
Cost
Effectiveness
: (VUg) :.
$15.156
($99)
$8,762
11/29/94
-------
ABS.Bs
Impacts Summary
by Facility
Monsanto-Muscatine
Existing
Regulatory Alternative # 1
' rV:-'.:'-: • •:"-'-::- :.' '-..
.-..'. Storage Tanfcs :: .
••.'. -.'V: \\process v"ehts:':-:...-'::.' :
?.:•.. /.'!:: Equipment te'aks;;. ; ',>
'":•;•.' : Wastewater. \. : .
• -i": •'-. TOTALS:?-. :••.,.
Total
Capital
($)
$27.351
$886
$28,237
Variable
Annual
($/yr) .
$10.785
$1.154
$11,939
Fixed
Annual
($/yr)
• $8.159
$944
$9,103
Recovery
Credit
Xityr)
($2.569)
($2,569)
Total
. -Annual •
•:'/ Wyr) vi
$18.944
($471)
$18,473
Emission
Reduction
(Mg^r)
0.21
4.70
4.91
Cost
Effectiveness
($/Mg). :
$90708
($100)
$3,762
11/29/94
-------
SAN.B
Impacts Summary
by Facility
Monsanto-Muscatine
Existing
Regulatory Alternative # 1
• " • " • ' • " ' , ••" .". ' '
. ._•. .Storgae Tanks .:...
'. '.'V .-{'Process Vents .;'>:'. .'.'
;•• :.;: :Equiprn$ntUi&s . ;;:
"'-.:' •"'/;. Wastewater.>.": ':--V
:; ..TOTALS ,..x :
Total
Capital
(*)
$1.223
$1.223
Variable
Annual
: <$/yr)
$963
$963
Fixed
Annual
(*W :
$1.544
$1.544
Recovery
Credit
($/yr) V"
($3,820)
($3,820)
Total
. Annual . ;
:-:^:($^r)fe4
($1.312)
($1,312)
Emission
Reduction
Xitig'yrjv
6.35
6.35
Cost
Effectiveness
•::;;'($>Mg)>::
($207)
($207)
11/29/94
-------
ABS,Bs;SAN,B
Impacts Summary
by Facility
Monsanto-Muscatine
New
Regulatory Alternative # 1
.• •?•;'£''• ':••'••• •>'>- • ••
Storage Tanks
Process Vents
.Equipment Leaks
Wastewater
* TOTALS
Total
Capital
: ($)
$27.351
$2.109
$29,460
Variable
Annual
($/yr)
$10,785
$2,118
$12,903
Fixed
Annual
--• ($fyr) . '•
$8.159
$2.488
$10,647
Recovery
Credit
:-; ^(i/yri?;--:.'
($6.389)
($6,389)
Total
Annual . .
•••::;;-':($3y':ri •'••'.
$18.944
($1.783)
$17,161
Emission
Reduction
. ^(Mijfyr>
0.21
11.05
11.26
Cost
Effectiveness
::<$Wlg) •
$90.208
($161)
$1,524
11/29/94
-------
ABS.BS
Impacts Summary
by Facility
Monsanto-Muscatine
New
Regulatory Alternative # 1
- • •••'.. .. • •-. - •••-•.-:
!, ; -.Storage Tanks ;
; . .Process Vents .'•';'
;-..';••:, Equipn^inf teaks ; • . -
"''-.- 1 v^^WastevWter -vf : r '••
••l--*/^' TOTALS '•••""-.^•:
Total :
Capital
:- ''•'.-$) • "."
$27.351
$886
$28,237
Variable
Annual
($fyr)
$10.785
$1.154
$11,939
Fixed
. Annual
($/yr)
$8.159
$944
$9,103
Recovery
.Credit
::(ilyT) ...
($2.569)
($2,569)
Total
Annual
' i$fyr)
$18,944
($471)
$18,473
Emission
Reduction
(MB/yr)
0.21
4.70
4.91
Cost
Effectiveness
($/Mg) -
$90.208
($100)
$3,762
11/29/94
-------
SAN.B
Impacts Summary
by Facility
Monsanto-Muscatine
New
Regulatory Alternative # 1
Storage Tanks . . .: . .
: Process Verits;:. :'.
^ J;; Equiprnertieaks ;..!' '
• ••;. ":'; Wastewaler . -V"'.
-*' v TOTALS .••••=;•.
TOUI
Capital
($)
$1,223
$1,223
Variable
Annual
($/yr)
$963
$963
Fixed
Annual'
-------
SAN.B
Impacts Summary
by Facility
Monsanto - Muscatine
New
Regulatory Alternative * 1
Storage Tanks : :
. Process Vents
Equipment Leaks.
Wastewater "•:
TOTALS
Total
Capital
<$)
$1.223
$1,223
Variable
Annual
<$Ayr)
$0
$0
$963
$0
$963
Fixed
Annual
(Vyr)
$0
$0
$1.544
$0
$1,544
Recovery
Credit
Mr)
($3.820)
($3,820)
Total
Annual
Mr)
$0
90
($1.312)
$0
($1,312)
Emission
Reduction
-------
PS.C
Impacts Summary
by Facility
Novacor Chemicals-Decatur
Existing
Regulatory Alternative # 1
-• ..: •" ••••'...
Storage Tanks •
Process Vents
! Equipment Leaks :,:•• .
'.«'" ':••.: •.:•.•:•.-.:•••..••:•.••-•..-. ::--. •.
j Wastewater ..
t :: TOTALS - :::
Total
Capital
($)
$26.002
$26,002
Variable
Annual
($/yr)
($4.601)
($4,601)
Fixed
Annual
($/jrr)
$3.372
$3,372
Recovery
Credit
(Vyr)
($3.476)
($3,476)
Total
Annual
($/yr)
($4.705)
($4.705)
Emission
Reduction
(Mg/yr)
5.30
S.30
Cost
Effectiveness
($
-------
PS,C
Impacts Summary
by Facility
Novacor Chemicals-Decatur
New
Regulatory Alternative # 1
... Storage Tanks I.
'. . .;.. .P.rbcesii:Verihs':'T.f'':;
.: : ••.$<: Equipment Leaks :•.••. :
.• ' " '• WastewaieJ1'";.^;'.; .'-.:
: TOTALS: •
Total
Capital :
($)
$26,002
$26,002
Variable
Annual
V : MO' ;
($4,601)
($4,601)
Fixed
Annual
: ($^r)
$3,372
$3,372
Recovery .
Credit .:
::-'{$:Jy't)>:ir
($3.476)
($3.476)
.Total
:V Annual..
:>.:•': -ii^r^NX
($4.705)
($4.705)
Emission
Reduction
5v(Mgfyi)::
5.30
5.30
-\cost,.;
Effectivtness
^tiiyigV};-:
($888)
($888)
11/29/94
-------
PS.C
Impacts Summary
by Facility
Novacor-lndian Orchard
Existing
Regulatory Alternative # 1
. Storage Tanks . .
Process Vents .
:.?. ..Equipniinl Leaks . .
^:,'r rVvastevrateV : '-. -" .•'•'
•jsfV- \: TOTALS;:;
Total
Capital
($)
$13,086
$13,086
Variable
Annual
($/yr)
($359)
($359)
Fixed
Annual
(Vyr)
$2,639
$2,639
Recovery
Credit
($/yr)
($2.164)
($2,164)
Total
. Annual .
($W
$116
$116
Emission
Reduction
(Mg/yr)
3.30
3.30
Cost
Effectiveness
($/MB)
$35
$35
11/29/94
-------
MBS
Impacts Summary
by Facility
Rohm & Haas - Louisville
Existing
Regulatory Alternative # 1
Storage Tanks
Process Vents ;:
. Equipment Leaks .:•'
Wastewater
TOTALS
Total
Capital
($)
$29.111
$157.174
$279.051
$465,336
Variable
Annual
($/yr)
$0
$31,827
$63.876
$53.976
$149,678
Fixed
Annual
($/yr)
$0
$24,444
$64,955
$83,655
$173,053
Recovery
Credit
($/yr) :.:>'
($84.941)
($84,941)
Total
• Annual
. '.. ($/yr);,;V
$0
$56,271
$43,889
$137,631
$237,791
Emission
Reduction
(Mg/yr)
6.14
102.16
5.00
113.30
•,; cost •:- .-:
Effectiveness
:^;'"{$/iilfl)s ' :
$9.165
$430
$27,526
$2,099
9/12/94
-------
MBS
Impacts Summary
by Facility
Rohm & Haas - Louisville
New
Regulatory Alternative # 1
Storage Tanks
Process Vents
Equipment Leaks
Wastewater
TOTALS
Total
Capital
($)
$106.394
$157,174
$279.051
$542.619
Variable
Annual
<$/yr)
0
138149.7
63875.5
53976
$256,001
Fixed
Annual
<*W
0
95992
64954.5
83655
$244,602
Recovery
Credit ;
<$Vr)
($84.941)
($84,941)
Total
Annual
<&r)Y
0
234141.7
43889
137631
$415,662
.Emission
Reduction
•fttfrr)
6.14
102.16
5.00
113.30
Cost
Effectiveness
•.:;;-($/Mjiya
•
$38,134
$430
$27,526
$3,669
9/12/94
-------
PS.Bs
Impacts Summary
by Facility
Rohm and Mass-Philadelphia
Existing
Regulatory Alternative # 1
:'". i:''. .-..:-. '• •'. • :'
'..•' . Storage tanks
Process Vents :: . .
Equipment teatcs
'-'•'•"•: Waslewater . '-:
.-- V ••-•^TOTALS •::.'•.-
Total
Capital
(jj
$23.379
$21.179
$44,558
Variable
Annual
' ($/yr)
$2,802
$24.445
$27,247
Fixed
Annual
(M :.
S6.161
$13.156
$19,317
: Recovery
Credit
:: ($/yr> :
($2.932)
($10.297)
($13,229)
Total
Annual .
:• .:($^r) •..;
$6.030
$27.304
$33,334
Emission
Reduction
;v(rtg1Vr):
2.32
15.70
18.02
Cost
Effectiveness
: <*Mg)
$2.599
$1.739
$1,850
11/29/94
-------
EPS
Impacts Summary
by Facility
Scott Polymers-Fort Worth
Existing
Regulatory Alternative # 1
Storage Tanks
:. Process Vents .:
-;- Equipment Leaks
- ;••_ > _ • .• ..x.":. :'.":.. ^.-.: ';'••• -*: ':-'- '"•'
.•^ •":••-• TOTALS: :>v:^
Total
Capital
($)
$12,332
$12,332
Variable
Annual
($/yr)
$4,993
$4,993
Fixed
Annual
($tyr)
$4.696
$4,696
Recovery
Credit
:<$/yr)
($6.755)
($6.755)
Total
Annual
($/yr) :,
$2,934
$2,934
Emission
Reduction
(Mg/yr)
10.30
10.30
Cost
Effectiveness
($/Mg)
$285
$285
11/29^4
-------
PS.Bs; EPS
Impacts Summary
by Facility
Scott Polymer- Saginaw-1
Existing
Regulatory Alternative # 1
: Storage Tanks
. .Process Vents .:
} ^Equipment Leaks
Waslewater : •••••
TOTALS
Total
Capital.
«)
$22,585
$22,585
Variable
Annual
(SW
$10.247
$10.247
Fixed
Annual
($/yr)
$9.097
$9,097
Recovery
Credit
•n|*/yr) •
($13.313)
($13,313)
Total
Annual
• ••:.'".($/y'ri'...'v:.
$6.031
$6,031
Emission
Reduction
•••:(«(B>yrj%
20.30
20.30
Cost
.Effectiveness
'•^$/Mg)-:.-
$297
$297
11/29/94
-------
PS.Bs
Impacts Summary
by Facility
Scott Polymers-Saginaw 1
Existing
Regulatory Alternative # 1
Storage-Tanks .
Process Vents ".
. ; .;.. Equipment teaks ..• .
•••"/••'.Waslewa'ter .::?r;.
:•-.-•• TOTALS : i
Total
Capital
($)
$2.881
$2,881
Variable
Annual
($/yo
$1,716
$1,716
Fixed
Annual
($tyr)
$1,388
$1,388
Recovery
Credit
($/yr)
($1.639)
($1,639)
Total
Annual
($/yr)
$1.465
$1,465
Emission
Reduction
: HMgAyrji :
2.50
2.50
Cost
Effectiveness
($/Mg)
$586
$586
11/29/94
-------
EPS
Impacts Summary
by Facility
Scott Polymers-Saginaw 1
Existing
Regulatory Alternative # 1
.. Storage TanVs .
/•-.-' v- Process Vents f: '• '--."•
•. - :> Equipmeriti^aksv;: :,:':
" '*> f-MSffiiiiv?^"'':
•-.-. •::---TOTALS:<--'.":-VV
Total
Capital
: •• ;($V
$19.704
$19,704
Variable
Annual
($WJ
$8.531
$8.531
Fixed
Annual
($/yr)
$7.709
$7,709
Recovery
. Credit
;"^r)l,.-
($11.674)
($11,674)
Total
. Annual
;^($Vr) :;:
$4,566
$4,566
. Emission
Reduction
?3im$
17.80
17.80
Cost
Effectiveness
i#^8V^-
$256
$256
11/29/94
-------
PS.Bs
Impacts Summary
by Facility
Scott Polymers-Saginaw 2
Existing
Regulatory Alternative # 1
Storage Tanks
' ••*.'• Process Vents ..; ;:
. . ;:. Equipment teaks,, v^;.
•;:-V. . toasiewateri. . v--'
*:' TOTALS
Total
Capital
($)
$2,909
$2.909
Variable
Annual
($fyr)
$1,990
$1.990
Fixed
Annual
($fyr)
$1,564
$1,564
Recovery
Credit
($tyr) .
($1.771)
($1,771)
Total
Annual
($'yr)
$1.783
$1,783
Emission
Reduction
(Mg/yr)
2.70
2.70
Cost
Effectiveness
($/Mg)
$660
$660
11/29/94
-------
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: Bennett King and Kenneth R. Meardon
Pacific Environmental Services
DATE: March 24, 1995
SUBJECT: MACT Floor Analysis & Development of Regulatory
Alternatives For Wastewater Operations, Storage
Vessels, Process Vents, and Process Contact Cooling
Towers
Purpose
This memo presents the results of the MACT floor analysis,
identifies the selected regulatory alternatives, describes the
general approach of the analysis, and presents the data used to
conduct the analysis. This memorandum addresses wastewater
-operations, storage vessels, process vents, and process contact
cooling towers. The determination of the MACT.floor for
equipment leaks is discussed in a separate memorandum.
The basic approach taken for determining the MACT floors and
developing regulatory alternatives was to 1) select a set of
existing federal rules and guidance documents which would serve
as a starting point for determining regulatory alternatives, and
2) compare the existing controls at the resin facilities for a
given subcategory to the set of rules/guidances. This comparison
determined whether or not the MACT floor, as expressed in terms
of the existing levels of control for a subcategory, was more
stringent than, equivalent to, or less stringent than the
selected set of rules/guidances.
When the MACT floor was found to be equivalent to or less
stringent than the selected set of rules/guidances, the
requirements of the rules/guidances were accepted as the
WASHINGTON. D.C - RESEARCH TRIANGLC PARK. NC • LOS ANGELES, CA • CINCINNATI. OH
-------
regulatory alternative. When the MACT floor was found to be more
stringent than the selected set of rules/guidances, the MACT
floor was defined in regulatory terms (i.e., applicability
criteria and level of control) and accepted as the regulatory
alternative. The exception to both of these statements is that
regulatory alternatives that were more stringent than the MACT
floor and the selected set of rules/guidances and were still
reasonable considering cost, emission reduction, nonair
environmental, and energy impacts were also considered as
regulatory alternatives.
Those instances where (1) the MACT floor was found to be
more stringent than the selected set of rules/guidances or 2). a
regulatory alternative was found to be more stringent than the
selected set of rules/guidances and the MACT floor are identified
in this memorandum, but are not discussed. The technical
analyses required to define MACT floors that are more stringent
than the selected set of rules/guidances are described in
separate memoranda. These memoranda are located in the Group IV
docket as items II-B-21 and II-B-23. Item II-B-21 discusses MACT
floors related to process vents, and Item II-B-23 discusses MACT
floors related to storage vessels. Policy decisions to go beyond
the MACT floor are discussed in the Basis and Purpose Document.
This memorandum presents a summary of the data used in the
analyses in the body of the memorandum. The raw data considered
in comparing the existing control level to the selected set of
rules/guidances are presented in appendices. Appendix A presents
data related to storage vessels, and Appendix B presents data
related to process vents.
Results
Tables 1 (existing sources) and 2 (new sources) present the
results of the MACT floor analysis and identify the selected
regulatory alternatives for storage vessels, process vents, and
-------
wastewater operations. (Note: tables are presented at the end
of the text.) The "MACT Floor Stringency" column in Tables 1 and
2 reflect the comparison of the MACT floor to the selected set of
rules/guidances. If this column indicates "<", this means that
the MACT floor, as reflected in the existing level of control, is
less stringent than the selected set of rules/guidances. If this
column indicates "-", this means that the MACT floor is
equivalent to the selected set of rules/guidances, and a ">"
means the MACT floor is more stringent than the selected set of
rules/guidances.
Table 3 shows the distribution of subcategories in the
relationship of existing and new source MACT floors to the set of
rules/guidance for storage vessels, process vents, and wastewater
operations. For example, for existing storage vessels, the
analysis found that for 15 out of the 18 subcategories the MACT
floor was less stringent than or equivalent to the selected set
of rules/guidances. In three cases, the MACT floor was
determined to be more stringent than the selected set of
rules/guidances.
The MACT floor analysis for process contact cooling towers
associated with PET production followed the general approach. A
cost effective regulatory alternative more stringent than the
MACT floor or selected set of rules/guidances was identified for
both existing and new sources, and was selected as the basis for
the proposed standards.
Description of the Approach
As described above, the approach taken for determining the
MACT floor and developing regulatory alternatives entailed
selecting a set of rules/guidances to serve as a starting point
and comparing the existing controls for each facility in a given
subcategory to the selected set of rules/guidances. This process
was done for each type of emission point.
-------
The set of rules/guidances selected as the starting point
for determining regulatory alternatives were the Hazardous
Organic NESHAP (HON), the Polymers NSPS (subpart ODD of 40 CFR
part 60), and the Batch Processes Alternative Control Techniques
(ACT) document. The HON was selected because the characteristics
of the emissions from storage vessels, continuous process vents,
equipment leaks, and wastewater streams at Group IV resin
facilities are similar or identical to those addressed by the
HON.
The Polymers NSPS, which covers certain process emissions at
polystyrene and PET facilities using a continuous process and
cooling tower emissions at PET facilities, was selected for the
same basic reasons as the HON. Although the Polymers NSPS was
developed under section 111 of the Clean Air Act and was targeted
to control volatile organic compound (VOC) emissions, the
requirements.for setting standards under section 111 are similar
to the requirements under section 112 of the 1990 Amendments.
Further, all of the hazardous air pollutant (HAP) identified from
polystyrene and PET facilities are also VOC.
Finally, the Batch Processes ACT was selected so that batch
process vents, which are not addressed by either the HON or the
Polymers NSPS, could be covered. As with the Polymers NSPS, the
Batch Processes ACT covers VOC emissions. Again, all of the HAP
identified from Group IV resin facilities are also VOC. Unlike
the HON and Polymers NSPS, the Batch Processes ACT is not a
regulation and, therefore, does not specify a level of control
that must be met. For the MACT floor analysis, the applicability
criteria associate with the 90 percent control level was used.
• For all three of these rules/guidances, the levels of
control required (or recommended) were already determined through
extensive analyses to be reasonable from a cost and impact
-------
perspective. Therefore, they represent "ready made" regulatory
alternatives.
For existing sources, the MACT floor was based on the five
best controlled facilities, and for new sources, the MACT floor
was based on the single best controlled facility.
For existing sources in subcategories with five or fewer
facilities, all of the facilities were included in determining
the existing source MACT floor. However, for those subcategories
with more than five facilities, the five best controlled
facilities had to be identified. This was done by examining the
types of control and the level of emission reductions being
achieved (e.g., emission factors, percent reductions). For
storage vessels, the level of control, vapor pressure, and tank
capacity were used to determine which facilities were best
controlled. For process vents, percent emission reduction was
used as the primary indicator of the best controlled facilities.
'For equipment leaks, percent reduction based on the actual leak,
detection, and repair (LDAR) programs was used to identify the
best controlled facilities. For wastewater and process contact
^cooling towers, the controls being applied at each facility were
examined; very few wastewater streams were controlled and none of
the process contact cooling towers were controlled.
After the facilities that comprised the MACT floor were
identified, a three step evaluation process was used to compare
the existing controls at the facilities for a given subcategory
to the set of rules/guidances and determine whether or not the
MACT floor, as expressed in terms of the existing levels of
control for a subcategory, was more stringent than, equivalent
to, or less stringent than the selected set of rules/guidances.
The first step evaluated the stringency status of individual
emission points; the next step evaluated the stringency status of
individual facilities; and the last step evaluated the stringency
-------
status of the subcategory. Stringency status means the
relationship of the existing levels of control to the selected
set of rules/guidances (i.e., more stringent than, equivalent to,
or less stringent than).
For the first step, the control/no control criteria of the
applicable rule/guidance was applied to the corresponding
emission point to determine whether or not control would be
required. The result was then compared to whether or not the
emission point was actually being controlled or not. Where the
emission point was uncontrolled, but the criteria being applied
indicated control, the level of control was considered for that
emission point to be less stringent than the rule/guidance.
Similarly, if the emission point was being controlled, but the
criteria indicated no control, the level of control was
considered to be more stringent than the rule/guidance.
If the emission point was not being controlled and the
criteria indicated no control, the level of control was
considered for that emission point equivalent to the
rule/guidance. If the emission point was being controlled and
the criteria indicated control, the level of control (e.g.,
percent reduction) was then compared to the level of control
required by the rule/guidance. If the level of control was less
stringent than the rule/guidance (e.g., 90 percent reduction was
being achieved, but the rule requires 98 percent reduction), the
level of control was considered less stringent than the
rule/guidance. Similarly, if the level of control being achieved
was equivalent to (or greater than) that required by the
rule/guidance, the level of control was considered equivalent to
(or more stringent than) the rule/guidance.
For existing sources, this process was done for each
emission point within each of the five best controlled facilities
within each subcategory. For new sources, this was done for each
-------
emission point within the best controlled facility within each
subcategory.
For the next step, within each facility, a determination was
then made as to whether the emission source type (e.g., storage
vessels) overall was being controlled less stringently,
eguivalently, or more stringently than the rule/guidance. In
making this determination, the stringency status decisions for
individual emission points were evaluated to determine the most
frequent answer (i.e., mode). When a "mode" was not evident
within the data, the stringency status was defaulted to be
equivalent to the selected set of rules/guidances. In other
words, the analysis looked for a "preponderance" of evidence
before determining that the MACT floor was less stringent than or
more stringent than the set of rules/guidances. For example, if
eight out of 10 storage vessels at a facility were determined to
be controlled less stringently and the remaining two more
stringently than the rule/guidance, a "preponderance" of evidence
was deemed to exist and the facility was considered to be
controlled less stringently overall for storage vessels.
'However, using another example, if three of five storage vessels
«at a facility were controlled less stringently than the
rule/guidance and two of the five storage vessels were controlled
more stringently, then a "preponderance" of evidence was deemed
not to exist, and the facility was considered to be controlled
equivalently to the rule/guidance. This was done for each type
of emission point at each facility.
In the third step, the stringency status for an individual
•subcategory was determined. The same type of decision rule was
applied to the set of individual facility stringency status
decisions as described in the above paragraph. For example, if a
subcategory has five facilities and the overall level of control
for storage vessels at three of the facilities was determined to
be less stringent than the rule/guidance and more stringent at
-------
the other two facilities, a "preponderance" of evidence was
deemed not to exist, and the facility was considered to be
controlled equivalently to the rule/guidance.
Discussion of Specific Analyses for Each Type of Emission Point
The specific analyses for each type of emission point are
described below.
Wastewater Operations
Very little data were received on wastewater operations from
the industry. Typically, data are not available for more than a
single stream at a facility, and there is typically only one
facility with data per subcategory. However, data are available
for 15 of the 18 subcategories and all 7 of the listed source
categories are represented.
Based on the information received, only one of the
facilities were controlling wastewater streams. (This one
facility is an acrylonitrile butadiene styrene (ABS) latex
facility, which is the only facility in its subcategory.) Thus,
the MACT floor for both existing and new facilities (except for
the ABS latex facility) was determined to be no control. A
comparison was then made to determine the relationship of the HON
requirements to the MACT floors. This was done by applying the
control/no control applicability criteria (i.e., concentration
and flow rate) from the HON to each individual wastewater stream
for which data were available. The data used to make these
decisions are presented in Appendix A, Table A-l. The wastewater
stream applicability criteria for the HON are available in 40 CFR
Part 63, Subpart F and G. The results of this comparison of
existing control and HON-required control and their relationship
are summarized on Table 4 for each facility within each
subcategory.
8
-------
Next, all the wastewater streams at a facility were examined
to determine the overall relationship of the HON to all of the
wastewater streams at a facility. As seen in Table 4, the
overall level of control for all but four facilities was
determined to be equivalent to the HON. For these other four
facilities, the overall level of control was determined to be
less stringent than the HON.
The last step was to determine the overall relationship of
the HON to the MACT floor for each subcategory. Table 5
summarizes this determination. As seen in Table 5, for all
subcategories except acrylonitrile styrene acrylate/alpha methyl
styrene acrylonitrile (ASA/AMSAN), the HON was determined to be
equivalent to the MACT floor. For ASA/AMSAN, the HON was
determined to be more stringent than the MACT floor.
Because the MACT floor was equivalent to the HON for the
majority of subcategories, it was assumed that the MACT floor was
equivalent to the HON for the three subcategories not represented
by the data — ABS by batch suspension, polystyrene by batch
suspension, and expandable polystyrene.
Storage Vessels
Storage vessel data are available for most Group IV
thermoplastic facilities. For the majority of subcategories,
data are available for at least 50 percent of the facilities
within the subcategory. All seven listed source categories are
represented by the data, and 17 of the 18 subcategories are
represented. The only subcategory not represented is
poly(ethylene terephthalate) (PET) produced using a batch
terephthalic acid (TPA) process.
Many storage vessels are controlled. A comparison was made
to determine whether or not the HON requirements for storage
vessels were more stringent than the level of control being
-------
achieved. This was done by applying the control/no control
applicability criteria (i.e., storage vessel size and vapor
pressure of the stored material) to each storage vessel within a
facility. The data used to make these decisions are presented in
Appendix A, Tables A-2 through A-x. The storage vessel
applicability criteria for the HON are available in 40 CFR Part
63, Subpart G.
As summarized in Table 6, the current level of control at
each facility was generally equivalent to that required by the
HON. There were several facilities, however, for which existing
control was determined to be more stringent than the HON (i.e.,
storage vessels were being controlled whereas the HON
applicability criteria would indicate no control required).
Next, the overall relationship of the HON to the level of
control at all of the facilities within a subcategory was
determined. As seen in Table 6, for each subcategory except
ASA/AMSAN, the HON was determined to be equivalent to the MACT
floor. For ASA/AMSAN existing and new facilities, the MACT floor
was determined to be more stringent than the HON requirements.
A different technique was used to determine the MACT floor
for the PS,C subcategory. Unlike the other subcategories, when
the individual storage tank determinations were made within each
of the vapor pressure ranges, it was unclear as to which were the
best five controlled facilities and which was the best controlled
facility. Since it was not possible to identify the five best
performing facilities (for the existing analysis) or the single
best performing facility (for the new analysis) based on controls
across all storage vessels, the best performers were picked
within each vapor pressure range. This means that a given
facility might be considered the single best performer for the
low vapor pressure range and another facility would be the single
best performer for the high vapor pressure range. Using this
10
-------
approach, the new source MACT floor for the PS,C subcategory is
based on the existing controls from two different facilities
across the vapor pressure ranges.
The data used in the analysis are presented in Tables 7
through 9. Table 7 presents the storage vessel data by vapor
pressure range on a facility basis considering the HON
requirements for existing sources. There were 8 facilities in
the "less than 0.75 psia" vapor pressure range where the MACT
floor was more stringent than the HON. In the "0.75 to 1.9 psia"
vapor pressure range, there were 4 facilities that were less
stringent than the HON and 1 facility that was more stringent
than the HON. In the "greater than 1.9 psia" range, there were 2
facilities that were more stringent than the HON and 1 facility
that was less stringent than the HON. This collection of data
was judged to show the existing source MACT floor to be more
stringent than the HON.
Table 8 presents the storage vessel data by vapor pressure
"range on an individual storage vessel basis for the best
performing facilities (based only the storage vessels in that
range) considering the HON requirements for existing sources. In
the "less than 0.75 psia" range, the 8 best performing facilities
were considered. In the other two ranges there are five or fewer
facilities with data, and all available data were considered.
This collection of data was also judged to show the existing
source MACT floor to be more stringent than the HON.
Table 9 presents the storage vessel data by vapor pressure
range on a facility basis considering the HON requirements for
new sources. This data indicates that there is at least one
facility in each vapor pressure range that is more stringent than
the HON. This collection of data was judged to show the new
source MACT floor to be more stringent than the HON.
11
-------
Process Vents
Process vent data are available for most Group IV
thermoplastic facilities. For the majority of subcategories,
data are available for at least 50 percent of the facilities
within the subcategory. Six of the seven listed source
categories are represented by the data, and 16 of the 18
subcategories are represented. The two subcategories not
represented are PET TPA,B and methyl methacrylate acrylonitrile
butadiene styrene (MABS).
As for storage vessels, many process vents are being
controlled. A comparison was made to determine whether or not
the HON requirements, the Batch Processes ACT criteria, or the
Polymer Manufacturing NSPS requirements for process vents were
more stringent than the MACT floor. This was done by applying
the applicable control/no control criteria from the HON, Batch
Processes ACT, and Polymer Manufacturing NSPS to each process
vent for which data were available. The criteria and their use
are discussed more completely below.
HON Criteria. To determine control/no control decisions for
the HON, the total resource effectiveness (TRE) value for each
process vent for which data are available was calculated. When a
process vent has a TRE value less than or equal to one, it is
required to apply controls under the HON requirements. The
criteria for estimating TRE values for process vents from new and
existing sources are different. The estimation of the TRE is
described in detail in the HON (40 CFR part 63, subpart G).
Tables A-x through A-x present the TRE values and the data used
to make the calculations. In some cases, a range of potential
vent stream characteristics was developed based on the available
data and multiple, theoretical TRE values were calculated. In
other cases, all the data required to calculate the TRE are
available and a single, definitive TRE value was calculated. The
12
-------
process vent applicability criteria for the HON are available in
40 CFR part 63, subpart G.
Batch Processes ACT Criteria. To determine the control/no
control decisions for the Batch Processes ACT, the applicability
criteria for this guidance document was evaluated for each
process vent for which data are available and which appeared to
be a batch process vent. In many cases, it is not possible to
•know definitively whether a process vent is a batch or continuous
process vent. For this reason, the analyses of the HON and Batch
Processes ACT overlap in many instances. There is no distinction
in the Batch Processes ACT between process vents at new or
existing sources. The data required for evaluating the Batch
Processes ACT applicability criteria are annual emissions, actual
flowrate, and a calculated flowrate. The results of these
evaluations are included in Tables 11 through 14. The columns on
Tables 11 through 14 are generically labeled as "HON/ACT Control
Required." When the Batch Processes ACT applicability criteria
were specifically analyzed, it is indicated in the body of the
column (e.g., ACT-N, ACT-Y, or ACT/H-N). The Batch Processes ACT
describes the applicability criteria in detail and is available
.in section II-B of the docket (A-92-45).
Polvmer Manufacturing NSPS. Threshold emission rates (i.e.,
applicability criteria) were developed under the Polymers NSPS to
set a point at which it was not cost effective to require an
existing source (i.e., modified or reconstructed) to meet the
emission limits. Therefore, to determine the control/no control
decisions for the Polymers NSPS, the emissions for each subject
process area (e.g., material recovery for continuous PET dimethyl
terephthalate (DMT) processes) for which data are available was
compared to the Polymers NSPS emission limits. The raw data
comparing each facility's emissions to the Polymers NSPS emission
limits is considered confidential business information since it
13
-------
reveals the production capacity of individual facilities. These
data are contained in the EPA's confidential files.
As seen in Tables 1 and 2, there are a few subcategories
where the MACT floor for process vents is more stringent than the
HON, but in the majority of cases the MACT floor is equivalent to
or less stringent than the HON.
Table 10 presents the existing level of control stringency
result for each individual facility for which data were available
and also presents the MACT floor decision for each subcategory.
The MACT floor for both existing and new sources is more
stringent than the HON/ACT for two subcategories. The remaining
MACT floors are either equivalent to or less stringent than the
HON/ACT/NSPS.
The results of this analysis for the PET subcategories are
summarized on Table 11. On Table 11, each facility for which
data were available is listed and the relationship between the
existing control level and the HON/ACT is indicated.
The next step in this type of analysis was to utilize the
results of each individual facility to determine the result for
the subcategory. For determining existing source MACT floor, the
results of the best performing five sources were considered; for
new source MACT floor, the single best performing source was
considered. As noted above, these subcategory decisions are also
presented on Table 10.
For facilities where control is required for a different set
of process vents than is being controlled, a more involved
analysis was required to determine the overall relationship of
the applicable rules/guidances to the facility. For these
facilities, the emissions being vented to the atmosphere under
the existing control level and the emissions that would be vented
14
-------
under the HON/ACT were compared. For purposes of comparison,
these two levels of emissions are expressed in terms of a percent
reduction, and the larger percent reduction reflects the more
stringent control scenario. The results of comparing emissions
was used to complement the simpler comparison of the number of
process vents. This type of analysis was used for the remaining
14 subcategories, and the results are presented on Table 12 for
methyl methacrylate butadiene styrene (MBS), Table 13 for SAN and
ASA/AMSAN, and Table 14 for polystyrene, ABS, MABS, and Nitrile.
Once the existing level of control stringency of each
individual facility was determined, the MACT floor stringency for
the subcategory was determined. For facilities with less than
five sources, all sources were included in the MACT floor
determination and its relationship to the HON/ACT/NSPS. Where
the same relationship existed, the relationship of the MACT floor
to the HON/ACT/NSPS was self-evident. Where different
relationships existed among facilities within a subcategory, the
majority ruled or, if this is still not clear, the same analysis
done for individual facilities is done for the five best
performing facilities (i.e., a percent reduction is determined
for the existing control level and for the HON/ACT control
level). For new source MACT floor, the single best performing
facility is determined based on percent reduction, and it is the
basis for new source MACT floor.
As discussed earlier, the HON and Batch Processes ACT were
evaluated simultaneously to determine the stringency of the MACT
floor against these two rules/guidances. After this analysis,
the impact of the Polymers NSPS on the determined MACT
floor/regulatory alternative was considered. The Polymers NSPS
affects some process emissions from new polystyrene facilities
using a continuous process and some process emissions from new
PET facilities using a continuous process. (Note: Section II of
the proposed preamble discusses the Polymers NSPS in more
15
-------
detail.) These requirements were considered in developing
regulatory alternatives for both existing and new polystyrene and
PET facilities using a continuous process.
For PET facilities, the analysis of process vents at
existing sources considered the threshold emission rates found in
the Polymer Manufacturing NSPS. With one exception, the analysis
showed that emissions from the facilities included in the
analysis were below the various emission limits in the Polymers
NSPS. For those situations where the emissions from the
facilities are below the Polymers NSPS emission limits, the
emission limits became part of the existing source MACT floor for
that subcategory. For those situations where the emissions from
the facilities are not greater than the Polymers NSPS emission
limits (i.e., process vents associated with material recovery at
PET facilities using a continuous DMT process), the emission
limits and the corresponding "threshold emission rate were
included as part of the regulatory alternative.
The analysis of new facilities entailed comparing the
appropriate process vent emissions against the emission limits;
threshold emission rates did not need to be considered since new
sources are required to meet the emission limits. In all cases,
the best performing facility was meeting the Polymers NSPS
emission limits and the emission limits were made part of the
MACT floor for new sources.
Process Contact Cooling Towers
The MACT floor for process contact cooling, towers at
existing sources, as reflected in the existing control level, was
determined to be no control for all PET subcategories as none of
the facilities with process contact cooling towers were
controlling the emissions from process contact cooling tower
water. Since none of the facilities that had process contact
cooling towers controlled emissions from the cooling towers, it
was qualitatively judged that the MACT floor was less stringent
16
-------
or equivalent to the Polymers NSPS requirements. (A facility
that does not control cooling tower emissions could be considered
equivalent to the Polymers NSPS if no control is required by the
Polymers NSPS.)
As mentioned previously, a cost effective regulatory
alternative that is more stringent than the MACT floor or
selected set of rules/guidances was available for this emission
point at existing sources. The basis for selecting this
regulatory alternative is discussed in detail in the Basis and
Purpose document (see Docket A-92-45, section II-A-10).
For new sources, the MACT floor was based on a facility that
used ethylene glycol jets, as opposed to steam jets, and did not
have a cooling tower. In addition to eliminating the need for a
cooling tower, the use of ethylene glycol jets prevents the
generation of the vacuum system wastewater streams. This level
of control was compared to the Polymers NSPS cooling tower
provisions and found to be more stringent. Therefore, the MACT
floor for new sources was described as "no process contact
cooling tower" and "no vacuum system wastewater." This option
was then considered as a regulatory alternative for existing
sources and was found to be reasonable considering cost, emission
reduction, nonair environmental, and energy impacts.
1:\n301\docu\mactflr2.ken
cc: Valerie Everette, PES
17
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TABLES
Note: Alphabetical codes are used to identify facilities in
some of the tables. Table A, presented first, provides the
facility codes and names. On the tables with facility
codes, there are typically two codes; one in parenthesis and
one not. The code not in parenthesis matches the codes
presented in Table A. Facility codes are also used in the
appendices, but are not done so consistently.
-------
TABLE A. FACILITY CODES AND FACILITY IDENTIFICATION
CODE
A (S) OR (19)
B(D
C(L)
D(Q)
E(I)
F(K)
G (M) or (25)
H(P)
I (E) or (28)
J (N) or (23)
K (R) or (21)
L (O) or (22)
M(F)
N (G) or (15)
0(V)
P(A)
Q(H)
R(W)
S (B) or (29)
T(C)
U(T)
V(U)
W(A)
X(U)
Y(V)
Z(W)
AA(T)
AB(S)
COMPANY
Allied Signal
DuPont
Hoechst Cleanese
ICI Films
Shell
Tennessee Eastman
Carolina Eastman
Eastman Kodak
Wellman
YKK
3M
American Polymers
Amoco Chemical Corp.
Arco Chemical Corp.
LOCATION
Moncure
Cooper River
Kinston
Cape Fear
Circleville
Florence
Old Hickory
Brevard
Spartanburg
Salisbury
Greer
Shelby
Fayetteville
Hopewell
Pt. Pleasant
Kingsport
Columbia
Rochester
Palmetto
Macon
Decatur
Greenville
Oxford
Joilet
Torrance
Willow Springs
Painesville
Monaca
-------
TABLE A. FACILITY CODES AND FACILITY IDENTIFICATION (CONTINUED)
CODE
AC(B)
AD(Y)
AE(X)
AF(C)
AG(D)
AH(Z)
AI(AA)
AJ(D)
AK(E)
AL(F)
AM(AJ)
AN(AL)
AO (AG)
AP(AH)
AQ(AI)
AR(AK)
AS(L)
AT(G)
AU (AO)
AV(AP)
AW (AN,)
AX (AM)
AY (I)-
AZ(H)
BA(J) ,
BB(K)
BC(AB)
COMPANY
BASF Corp.
BF Goodrich
BP Chemicals
Chevron Chemical
Dart Container Corp.
Dow Chemical
Elf Atochem
Fina Oil & Chemical Co.
GE Plastics
Hunstman Chemical
Kama
LOCATION
Holyoke
Santa Ana
Joilet
South Brunswick
Lowland
Akron
Luna
Marietta
Leola
Ownesboro
Midland
Allyn's Point
Torrance
Hanging Rock
Joilet
Riverside
Carville
Washington, WV
Ottawa
Bay St. Louis
Selkirk
Chesapeake
Belpre
Peru
Rome
Hazelton
-------
TABLE A. FACILITY CODES AND FACILITY IDENTIFICATION (CONCLUDED)
CODE
BD(AQ)
BE (AC)
BF(AD)
BG(AU)
BH
BI(N)
BJ(AE)
BK(AF)
BL(0)
BM(P)
BN(Q)
COMPANY
Kaneka Texas Corp.
Monsanto Corp.
Novacor Chemicals
Rohm and Hass
Scott Polymers
LOCATION
Muscatine
Addyston
Decatur- 1
Decatur- 2
Indian Orchard
Kentucky
Philadelphia
Saginaw - 1
Saginaw - 2
Fort Worth
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co*co*co*eo"co*5f5Z^Z*
S
-------
I
8
CO
S2
e
1
-------
TABLE 3. DISTRIBUTION OF SUBCATEGORIES BY
RELATIVE MACT FLOOR STRINGENCY8
Existing Source MACT Floor
New Source MACT
Floor
Storage Vessels
Process Vents
Wastewater
Streams
. <
0
2
1
-
15
14
17
>
3
2
0
<
0
2
1
-
13
14
17
>
5
2
0
a Number of subcategories where MACT floor is less stringent than (<), equivalent to
(-), or more stringent (>) than selected set of rules/guidances
-------
Table 4. Wastewater Stream Data Summary
J
1.
i
4
J
Subcategory
MBS
SAN, B & C
SAN.B
SAN.C
ASA/AMSAN
PET TPA.C
PET TPA.C
PET TPA.C
PET TPA.B
PET DMT.C
PET DMT.C
PET DMT.B
PET DMT.B
PET DMT.B
PET DMT.B
PET DMT.B
ABS, Latex
Nitrile
PS.C
PS.C
PS.C
PS.C
PS.C
PS.C
PS.C
ABS, Cm
Facility
BD (AQ)
BJ(AE)
AS(L)
BF (AO)
BE (AC)
AM(AJ)
AX (AM)
Footnote b
S(B)
Q(H)
0(V)
Footnote c
P(A)
Footnote d
AG(D)
M(F)
L(0)
R(W)
AH(Z)
AI(AA)
AQ(AI)
AR(AK)
AP(AH)
AO (AG)
AN (AL)
AX (AM)
BI(N)
AN (AL)
Number of Steams
Currently Being
Controlled
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
lof lf
None
No WW generated
None
None
None
None
None
None
None
Number of
Streams that would
be controlled by
theHON
None
lof 3
None
lof 3
None
None
3 of 6
None
2 of 3
lof 5
None
None
lof 6
None
lof 4
lof 1
lof 1
lof 2
Oof 1
lof 2
None
None
None
None
None
None
None
Relative Stringency of
Existing Control to
HON
[<,=.>]
-
=
=
=
=
-
-------
Table 4. Wastewater Stream Data Summary
ABS, Cm
ABS, Ce
ABS, Ce
ABS, Be
MABS
AO (AG)
AV(AP)
AU (AO)
AU (AO)
AU (AO)
None
None
None
None
None
None
None
None
None
None
8
S
-
=
-
* Controlled streams represent majority of wastewater volume at facility.
b There are 9 facilities that meet this scenario.
c There are 8 facilities that meet this scenario.
There are S facilities that meet this scenario.
* One of two streams meeting the HON. Judged not to be clearly more stringent than the HON.
* Partial control of stream only. Judged not to be clearly more stringent than the HON.
-------
Table 5. Relative Stringency of Existing Controls and MACT Floor
to HON Requirements for Wastewater Streams
Subcategory
MBS
Facility8
BI(AE)
AS(L)
BD(AQ)
Overall Stringency of MACT Floor to HON
SAN, C
BF(AD)
AM(AJ)
Overall Stringency of MACT Floor to HON
SAN, B
BF(AD)
BE (AC)
Overall Stringency of MACT Floor to HON
ASA/AMSAN
PET TPA, C
AX (AM)
9 Others
Q(H)
S(B)
Overall Stringency of MACT Floor to HON
PET DMT, C
8 Others
P(A)
Overall Stringency of MACT Floor to HON
PET DMT, B
S Others
AG(D)
Relative Stringency of
Existing Control to
Existing Source HON
Requirements
[<,=,>]
•
-
«
.
-
=
-
«
-
-
<
-
. =
<
-
-
=
-
-
-
Relative Stringency of
Existing Control to New
Source HON
Requirements
l<.=,>]
-
-
=
-
=
=
-
=
«
-
<
-
«=
<
=
=
=
-
=
=
-------
Table 5. Relative Stringency of Existing Controls and MACT Floors
to HON Requirements for Wastewater Streams (Continued)
Subcategory
Facility*
M(F)
L(0)
R(W)
Overall Stringency of MACT Floor to HON
PET TPA, B
EPS
PS, B
PS, C
0(V)
AQ(AI)
AR(AK)
AP(AH)
AO (AG)
AN(AL)
AX (AM)
BI(N)
Overall Stringency of MACT Floor to HON
MABS
Nitrile
ABS, Be
AU (AO)
AI(AA)
AU (AO)
Relative Stringency of
Existing Control to
Existing Source HON
Requirements
[<,=,>]
<
<
-
=
=
NDb
NDb
=
=
=
=T
=
=
«.
=
«
«
tm
Relative Stringency of
Existing Control to New
Source HON
Requirements
[<,=,>]
<
<
=
B
.
NDb
NDb
=
=
=
=
=
=
-
=
-
=
-
-------
Table 5. Relative Stringency of Existing Controls and MACT Floor
to HON Requirements for Wastewater Streams (Concluded)
Subcategoiy
ABS, Cm
Facility8
AN (AL)
AO (AG)
Overall Stringency of MACT Floor to HON
ABS, Bs
ABS, Ce
AV(AP)
AU (AO)
Overall Stringency of MACT Floor to HON
ABS.Latex
AH(Z)
Relative Stringency of
Existing Control to
Existing Source HON
Requirements
[<,=,>]
=
-
=
NDb
=
-
-
-
Relative Stringency of
Existing Control to New
Source HON
Requirements
[<.=,>]
-
-
is
NDb
=
=
-
=
a Only facilities with data are included. Facilities without data are assumed to be equivalent.
b No data for subcategory. Assumed equivalent to the HON.
-------
Table 6. Storage Vessel Data Summary
For All Subcategories Except PS, C
Snbcategory
MBS
Facility
BJ(AE)
AS(L)
BD(AQ)
Overall Stringency of MACT Floor to HON
SAN, C
BF(AD)
AW (AN)
AM(AJ)
Overall Stringency of MACT Floor to HON
SAN, B
BF(AD)
BE (AC)
Overall Stringency of MACT Floor to HON
ASA/AMSAN
PET TPA, C
1
AX (AM)
A (19)
1(28)
J(23)
K(21)
S(29)
Overall Stringency of MACT Floor to HON
PET DMT, C
0(25)
1(28)
Overall Stringency of MACT Floor to HON
Relative Stringency of
CXlStlflff NjfofMffM tO
Existing Source HON
Refitments
-
>
.
-
-
>
-
-
.
•
-
>
-
-
-
-
-
-
.
-
-
Relative Stringency of
Existing Control to New
Source HON
Requirements
-
-
.
-
-
>
-
>
«
-
-
>
-
«
-
-
-
.
-
-
-
-------
Table 6. Storage Vessel Data Summary
For All Subcategories Except PS, C
PET DMT, B
LC22)
1(28)
N(15)
Overall Stringency of MACT Floor to HON
PET TPA, B
EPS
AF(Q
BA(J)
AB(S)
Overall Stringency of MACT Floor to HON
MASS
ABS, Be
AU (AO)
BF(AD)
BE(AC)
AM (AD
AU (AO)
Overall Stringency of MACT Floor to HON
ABS, Cm
AN(AL)
BF(AD)
AO(AG)
AM(AJ)
AP(AH)
Overall Stringency of MACT Floor to HON
B
-
-
.
.«
B
>
.
.
-
B
««
.
.
m
-
«
>
-
>
-
ts
-
«
.
_a
=
>1>
-
.b
-
B
«
-
.
«
-
-
>
-
>
>
-------
Table 6. Storage Vessel Data Summary
For All Subcategories Except PS, C
ABS, Bs
BF(AD)
BE (AC)
Overall Stringency of MACT Floor to HON
ABS, Ce
AV(AP)
AU (AO)
Overall Stringency of MACT Floor to HON
ABS, Latex
Nitrile
PS, B
AH(Z)
AI(AA)
Y(V)
AY (I)
BA(J)
AK(E)
AL(F)
AB(S)
Overall Stringency of MACT Floor to HON
.
.
.
-
.
«
.
>
>
>
>
-
-
.
-
«
«
«
-
«
«
-
>
>C
>C
>C
-
-
-
.C
*No data. MACT floor assumed to be equivalent to the HON based on existing control levels for other 3 PET
subcategories.
bCannot define new source MACT floor based on this facility due to missing storage vessel size data.
Defaulted to HON as regulatory alternative.
cCanoot define new source MACT four on these facilities due to missing storage vessel size data and
"unknown" control efficiency. Defaulted to HON as regulatory alternative.
-------
Table 7. (Existing PS.C Storage Vessel Data Summary
Facility
AJ(D)
W(A)
AC(B)
X(U)
BF (AD)
AZ(H)
AY (I)
BA(J)
AO (AG)
AQ (AI)
AM(AJ)
AP(AH)
AR(AK)
AN(AL)
AX (AM)
AD(Y)
Summary3
Overall Summary
• • -.-
<0.75
=HON
>HON
>HON
>HON
=HON
>HON
>HON
>HON
>HON
=HON
=HON
>HON
=HON
=HON
=HON
=HON
8 >HON
>HON
Vapor pressure (psia)
k 0.75 < 1.9
NA
NA
NA
NA
sHON
NA
NA
NA
«HON
NA
>HON
HON
*HON
il.9
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
>HON
NA
NA
>HON
HON
1 HON
Summary of 5 best performing sources.
-------
Table 8. Existing PS.C Storage Vessel Analysis - Number
of Storage Vessels Per Vapor Pressure Range
Existing Control
<,=,> theHON
(No. storage vessels)
<
=
>
Summary
Overall Summary
Vapor Pressure Range (psia)
< 0.75a
1
7
37
>HON
2 0.75 and < 1.9
0
8
4
l* HON
* 1.9
0
3
5
> HON
> HON
These numbers represent the storage vessels at the 8 best performing facilities.
-------
Table 9, New PS,C Storage Vessel Data Summary
Facility
AJ(D)
AD(Y)
W(A)
AC(B)
X(U)
BF (AD)
AZ(H)
AY (I)
BA(J)
AO (AG)
AQ(AI)
AM(AJ)
AP (AH)
AR(AK)
AN (AL)
• AX (AM)
Summary
Overall Summary
<0.1
«HON
L =HON
>HON
>HON
>HON
«HON
>HON
>HON
>HON
>HON
=HON
«HON
=HON
=HON
=HON
=HON
>HON
Vapor pressure (psia)
* 0.1 < 1.9
«HON
NA
*HON
NA
NA
iHON
kHON
NA
NA
>HON
NA
=HON
>HON
>HON
>HON
=HON
>HON
i 1.9
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
=HON
NA
NA
>HON
HON
Facility
=HON
=HON
iHON
>HON
>HON
iHON
iHON
>HON
>HON
>HON
=HON
=*HON
=HON
=HON
>HON
=HON
>HON
>HON
-------
Next, all the wastewater streams at a facility were examined
to determine the overall relationship of the HON to all of the
wastewater streams at a facility. As seen in Table 4, the
overall level of control for all but four facilities was
determined to be equivalent to the HON. For these other four
facilities, the overall level of control was determined to be
less stringent than the HON.
*
The last step was to determine the overall relationship of
the HON to the MACT floor for each subcategory. Table 5
summarizes this determination. As seen in Table 5, for all
subcategories except acrylonitrile styrene acrylate/alpha methyl
styrene acrylonitrile (ASA/AMSAN), the HON was determined to be
equivalent to the MACT floor. For ASA/AMSAN, the HON was
determined to be more stringent than the MACT floor.
Because the MACT floor was equivalent to the HON for the
majority of subcategories, it was assumed that the MACT floor was
equivalent to the HON for the three subcategories not represented
by the data — ABS by batch suspension, polystyrene by batch
suspension, and expandable polystyrene.
Storage Vessels
Storage vessel data are available for most Group IV
thermoplastic facilities. For the majority of subcategories,
data are available for at least 50 percent of the facilities
within the subcategory. All seven listed source categories are
represented by the data, and 17 of the 18 subcategories are
represented. The only subcategory not represented is
poly(ethylene terephthalate) (PET) produced using a batch
terephthalic acid (TPA) process.
Many storage vessels are controlled. A comparison was Bade
to determine whether or not the HON requirements for storage
vessels were more stringent than the level of control being
-------
achieved. This was done by applying the control/no control
applicability criteria (i.e., storage vessel size and vapor
pressure of the stored material) to each storage vessel within a
facility. The data used to make these decisions are presented in
Appendix A, Tables A-2 through A-x. The storage vessel
applicability criteria for the HON are available in 40 CFR Part
63, Subpart G.
As summarized in Table 6, the current level of control at
each facility was generally equivalent to that required by the
HON. There were several facilities, however, for which existing
control was determined to be more stringent than the HON (i.e.,
storage vessels were being controlled whereas the HON
applicability criteria would indicate no control required).
Next, the overall relationship of the HON to the level of
control at all of the facilities within a subcategory was
determined. As seen in Table 6, for each subcategory except
ASA/AMSAN, the HON was determined to be equivalent to the MACT
floor. For ASA/AMSAN existing and new facilities, the MACT floor
was determined to be more stringent than the HON requirements.
A different technique was used to determine the MACT floor
for the PS,C subcategory. Unlike the other subcategories, when
the individual storage tank determinations were made within each
of the vapor pressure ranges, it was unclear as to which were the
best five controlled facilities and which was the best controlled
facility. Since it was not possible to identify the five best
performing facilities (for the existing analysis) or the single
best performing facility (for the new analysis) based on controls
across all storage vessels, the best performers were picked
within each vapor pressure range. This means that a given
facility might be considered the single best performer for the
low vapor pressure range and another facility would be the single
best performer for the high vapor pressure range. Using this
10
-------
approach, the new source MACT floor for the PS,C subcategory is
based on the existing controls from two different facilities
across the vapor pressure ranges.
The data used in the analysis are presented in Tables 7
through 9. Table 7 presents the storage vessel data by vapor
pressure range on a facility basis considering the HON
requirements for existing sources. There were 8 facilities in
the "less than 0.75 psia" vapor pressure range where the MACT
floor was more stringent than the HON. In the "0.75 to 1.9 psia"
vapor pressure range, there were 4 facilities that were less
stringent than the HON and 1 facility that was more stringent
than the HON. In the "greater than 1.9 psia11 range, there were 2
facilities that were more stringent than the HON and 1 facility
that was less stringent than the HON. This collection of data
was judged to show the existing source MACT floor to be more
stringent than the HON.
Table 8 presents the storage vessel data by vapor pressure
"range on an individual storage vessel basis for the best
performing facilities (based only the storage vessels in that
range) considering the HON requirements for existing sources. In
the "less than 0.75 psia" range, the 8 best performing facilities
were considered. In the other two ranges there are five or fewer
facilities with data, and all available data were considered.
This collection of data was also judged to show the existing
source MACT floor to be more stringent than the HON.
Table 9 presents the storage vessel data by vapor pressure
range on a facility basis considering the HON requirements for
new sources. This data indicates that there is at least one
facility in each vapor pressure range that is more stringent than
the HON. This collection of data was judged to show the new
source MACT floor to be more stringent than the HON.
11
-------
Process Vents
Process vent data are available for most Group IV
thermoplastic facilities. For the majority of subcategories,
data are available for at least 50 percent of the facilities
within the subcategory. Six of the seven listed source
categories are represented by the data, and 16 of the 18
subcategories are represented. The two subcategories not
represented are PET TPA,B and methyl methacrylate acrylonitrile
butadiene styrene (MABS).
As for storage vessels, many process vents are being
controlled. A comparison was made to determine whether or not
the HON requirements, the Batch Processes ACT criteria, or the
Polymer Manufacturing NSPS requirements for process vents were
more stringent than the MACT floor. This was done by applying
the applicable control/no control criteria from the HON, Batch
Processes ACT, and Polymer Manufacturing NSPS to each process
vent for which data were available. The criteria and their use
are discussed more completely below.
HON Criteria. To determine control/no control decisions for
the HON, the total resource effectiveness (TRE) value for each
process vent for which data are available was calculated. When a
process vent has a TRE value less than or equal to one, it is
required to apply controls under the HON requirements. The
criteria for estimating TRE values for process vents from new and
existing sources are different. The estimation of the TRE is
described in detail in the HON (40 CFR part 63, subpart 6).
Tables A-x through A-x present the TRE values and the data used
to make the calculations. In some cases, a range of potential
vent stream characteristics was developed based on the available
data and multiple, theoretical TRE values were calculated. In
other cases, all the data required to calculate the TRE are
available and a single, definitive TRE value was calculated. The
12
-------
process vent applicability criteria for the HON are available in
40 CFR part 63, subpart G.
Batch Processes ACT Criteria. To determine the control/no
control decisions for the Batch Processes ACT, the applicability
criteria for this guidance document was evaluated for each
process vent for which data are available and which appeared to
be a batch process vent. In many cases, it is not possible to
-know definitively whether a process vent is a batch or continuous
process vent. For this reason, the analyses of the HON and Batch
Processes ACT overlap in many instances. There is no distinction
in the Batch Processes ACT between process vents at new or
existing sources. The data required for evaluating the Batch
Processes ACT applicability criteria are annual emissions, actual
flowrate, and a calculated flowrate. The results of these
evaluations are included in Tables 11 through 14. The columns on
Tables 11 through 14 are generically labeled as "RON/ACT Control
Required.1* When the Batch Processes ACT applicability criteria
were specifically analyzed, it is indicated in the body of the
column (e.g., ACT-N, ACT-Y, or ACT/H-N). The Batch Processes ACT
describes the applicability criteria in detail and is available
.in section II-B of the docket (A-92-45).
Polymer Manufacturing NSPS. Threshold emission rates (i.e.,
applicability criteria) were developed under the Polymers NSPS to
set a point at which it was not cost effective to require an
existing source (i.e., modified or reconstructed) to meet the
emission limits. Therefore, to determine the control/no control
decisions for the Polymers NSPS, the emissions for each subject
process area (e.g., material recovery for continuous PET dimethyl
terephthalate (DMT) processes) for which data are available was
compared to the Polymers NSPS emission limits. The raw data
comparing each facility's emissions to the Polymers NSPS emission
limits is considered confidential business information since it
13
-------
reveals the production capacity of individual facilities. These
data are contained in the EPA's confidential files.
As seen in Tables 1 and 2, there are a few subcategories
where the MACT floor for process vents is more stringent than the
HON, but in the majority of cases the MACT floor is equivalent to
or less stringent than the HON.
Table 10 presents the existing level of control stringency
result for each individual facility for which data were available
and also presents the MACT floor decision for each subcategory.
The MACT floor for both existing and new sources is more
stringent than the HON/ACT for two subcategories. The remaining
MACT floors are either equivalent to or less stringent than the
HON/ACT/NSPS.
The results of this analysis for the PET subcategories are
summarized on Table 11. On Table 11, each facility for which
data were available is listed and the relationship between the
existing control level and the HON/ACT is indicated.
The next step in this type of analysis was to utilize the
results of each individual facility to determine the result for
the subcategory* For determining existing source MACT floor, the
results of the best performing five sources were considered; for
new source MACT floor, the single best performing source was
considered. As noted above, these subcategory decisions are also
presented on Table 10.
For facilities where control is required for a different set
of process vents than is being controlled, a more involved
analysis was required to determine the overall relationship of
the applicable rules/guidances to the facility. For these
facilities, the emissions being vented to the atmosphere under
the existing control level and the emissions that would be vented
14
-------
under the HON/ACT were compared. For purposes of comparison,
these two levels of emissions are expressed in terms of a percent
reduction, and the larger percent reduction reflects the more
stringent control scenario. The results of comparing emissions
was used to complement the simpler comparison of the number of
process vents. This type of analysis was used for the remaining
14 subcategories, and the results are presented on Table 12 for
methyl methacrylate butadiene styrene (MBS), Table 13 for SAN and
ASA/AMSAN, and Table 14 for polystyrene, ABS, MABS, and Mitrile.
Once the existing level of control stringency of each
individual facility was determined, the MACT floor stringency for
the subcategory was determined. For facilities with less than
five sources, all sources were included in the MACT floor
determination and its relationship to the HON/ACT/NSPS. Where
the same relationship existed, the relationship of the MACT floor
to the HON/ACT/NSPS was self-evident. Where different
relationships existed among facilities within a subcategory, the
majority ruled or, if this is still not clear, the same analysis
done for individual facilities is done for the five best
performing facilities (i.e., a percent reduction is determined
for the existing control level and for the HON/ACT control
level). For new source MACT floor, the single best performing
facility is determined based on percent reduction, and it is the
basis for new source MACT floor.
As discussed earlier, the HON and Batch Processes ACT were
evaluated simultaneously to determine the stringency of the MACT
floor against these two rules/guidances. After this analysis,
the impact of the Polymers NSPS on the determined MACT
floor/regulatory alternative was considered. The Polymers NSPS
affects some process emissions from new polystyrene facilities
using a continuous process and some process •missions from new
PET facilities using a continuous process. (Note: Section II of
the proposed preamble discusses the Polymers NSPS in more
15
-------
detail.) These requirements were considered in developing
regulatory alternatives for both existing and new polystyrene and
PET facilities using a continuous process.
For PET facilities, the analysis of process vents at
existing sources considered the threshold emission rates found in
the Polymer Manufacturing NSPS. With one exception, the analysis
showed that emissions from the facilities included in the
analysis were below the various emission limits in the Polymers
NSPS. For those situations where the emissions from the
facilities are below the Polymers NSPS emission limits, the
emission limits became part of the existing source MACT floor for
that subcategory. For those situations where the emissions from
the facilities are not greater than the Polymers NSPS emission
limits (i.e., process vents associated with material recovery at
PET facilities using a continuous DMT process), the emission
limits and the corresponding threshold emission rate were
included as part of the regulatory alternative.
The analysis of new facilities entailed comparing the
appropriate process vent emissions against the emission limits;
threshold emission rates did not need to be considered since new
sources are required to meet the emission limits. In all cases,
the best performing facility was meeting the Polymers NSPS
emission limits and the emission limits were made part of the
MACT floor for new sources.
Process Contact Cooling Towers
The MACT floor for process contact cooling, towers at
existing sources, as reflected in the existing control level, was
determined to be no control for all PET subcategories as none of
the facilities with process contact cooling towers were
controlling the emissions from process contact cooling tower
water. Since none of the facilities that had process contact
cooling towers controlled emissions from the cooling towers, it
was qualitatively judged that the MACT floor was less stringent
16
-------
or equivalent to the Polymers NSPS requirements. (A facility
that does not control cooling tower emissions could be considered
equivalent to the Polymers NSPS if no control is required by the
Polymers NSPS.)
As mentioned previously, a cost effective regulatory
alternative that is more stringent than the MACT floor or
selected set of rules/guidances was available for this emission
point at existing sources. The basis for selecting this
regulatory alternative is discussed in detail in the Basis and
Purpose document (see Docket A-92-45, section II-A-10).
For new sources, the MACT floor was based on a facility that
used ethylene glycol jets, as opposed to steam jets, and did not
have a cooling tower. In addition to eliminating the need for a
cooling tower, the use of ethylene glycol jets prevents the
generation of the vacuum system wastewater streams. This level
of control was compared to the Polymers NSPS cooling tower
provisions and found to be more stringent. Therefore, the MACT
floor for new sources was described as "no process contact
cooling tower" and "no vacuum system wastewater.11 This option
was then considered as a regulatory alternative for existing
sources and was found to be reasonable considering cost, emission
reduction, nonair environmental, and energy impacts.
1:\n301\docu\mactflr2.ken
cc: Valerie Everette, PES
17
-------
TABLES
Note: Alphabetical codes are used to identify facilities in
some of the tables. Table A, presented first, provides the
facility codes and names. On the tables with facility
codes, there are typically two codes; one in parenthesis and
one not. The code not in parenthesis matches the codes
presented in Table A. Facility codes are also used in the
appendices, but are not done so consistently.
-------
TABLE A. FACILITY CODES AND FACILITY IDENTIFICATION
CODE
A (S) OR (19)
BCD
C(L)
D(Q)
E(I)
F(K)
G (M) or (25)
H(P)
I (E) or (28)
J (N) or (23)
K (R) or (21)
L (O) or (22)
M(F)
N (G) or (15)
0(V)
P(A)
Q(H)
R(W)
S (B) or (29)
T(C)
U(T)
V(U)
W(A)
X(U)
Y(V)
Z(W)
AA(T)
AB(S)
COMPANY
Allied Signal
DuPont
Hoechst Cleanese
ICI Films
Shell
Tennessee Eastman
Carolina Eastman
Eastman Kodak
Wellman
YKK
3M
American Polymers
Amoco Chemical Corp.
Arco Chemical Corp.
LOCATION
Moncure
Cooper River
Kinston
Cape Fear
Circleville
Florence
Old Hickory
Brevard
Spaitanburg
Salisbury
Greer
Shelby
Fayetteville
Hopewell
Pt. Pleasant
Kingsport
Columbia
Rochester
Palmetto
Macon
Dccatur
Greenville
Oxford
Joilet
Torrance
Willow Springs
Painesville
Monaca
-------
TABLE A. FACILITY CODES AND FACILITY IDENTIFICATION (CONTINUED)
CODE
AC(B)
AD(Y)
AE(X)
AF(C)
AG(D)
AH(Z)
AI(AA)
AJ(D)
AK(E)
AL(F)
AM(AJ)
AN(AL)
AO (AG)
AP(AH)
AQ(AI)
AR(AK)
AS(L)
AT(G)
AU (AO)
AV(AP)
AW (AN)
AX (AM)
AYO)-
AZ(H)
BA(J) ,
BB(K)
BC(AB)
COMPANY
BASF Corp.
BF Goodrich
BP Chemicals
Chevron Chemical
Dart Container Corp.
Dow Chemical
Elf Atochem
Fina Oil & Chemical Co.
GE Plastics
Hunstman Chemical
Kama
LOCATION
Holyoke
Santa Ana
Joilet
South Brunswick
Lowland
Akron
Lima
Marietta
Leola
Ownesboro
Midland
AUyn's Point
Torrance
Hanging Rock
Joilet
Riverside
Carville
Washington, WV
Ottawa
Bay St. Louis
Selkirk
ftmutnfMiVp
Belpre
Peru
Rome
Hazelton
-------
TABLE A. FACILITY CODES AND FACILITY IDENTIFICATION (CONCLUDED)
CODE
BD(AQ)
BE (AC)
BF(AD)
BG(AU)
BH
BI(N)
BJ(AE)
BK(AF)
BL(0)
BM(P)
BN(Q)
COMPANY
Kanaka Texas Corp.
Monsanto Corp.
Novacor Chemicals
Rohm and Hass
Scott Polymers
LOCATION
Muscatine
Addyston
Decatur- 1
Decatur-2
Indian Orchard
Kentucky
Philadelphia
Saginaw - 1
Saginaw - 2
Fort Worth
-------
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-------
TABLE 3. DISTRIBUTION OF SUBCATEGORIES BY
RELATIVE MACT FLOOR STRINGENCY8
Storage Vessels
Process Vents
Wastewater
Streams
Existing Source MACT Floor
< - >
0 IS 3
2 14 2
1 17 0
New Source MACT
Floor
< - >
0 13 5
2 14 2
1 17 0
a Number of subcategories where MACT floor is less stringent titan (<), equivalent to
(-), or more stringent (>) than selected set of rules/guidances
-------
Table 4. Wastewater Stream Data Summary
Subcategory
MBS
SAN, B & C
SAN.B
SAN.C
ASA/AMSAN
PET TPA.C
PET TPA.C
PET TPA.C
PET TPA.B
PET DMT.C
PET DMT.C
PET DMT.B
PET DMT.B
PET DMT.B
PET DMT.B
PET DMT.B
ABS, Latex
Nitrile
PS.C
PS.C
PS.C
PS.C
PS.C
PS.C
PS.C
ABS, Cm
Facility
BD (AQ)
BJ(AE)
AS(L)
BF (AO)
BE (AC)
AM(AJ)
AX (AM)
Footnote b
S(B)
Q(H)
0(V)
Footnote c
P(A)
Footnote d
AG(D)
M(F)
L(0)
R(W)
AH(Z)
AI(AA)
AQ(AI)
AR(AK)
AP(AH)
AO (AG)
AN(AL)
AX (AM)
BI(N)
AN (AL)
Number of Steams
Currently Being
Controlled
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
loflf
None
No WW generated
None
None
None
None
None
None
None
Number of
Streams that would
be controlled by
theHON
None
lof 3
None
lof 3
None
None
3 of 6
None
2of3
lof 5
None
None
lof 6
None
lof 4
lof 1
lof 1
lof 2
Oof 1
lof 2
None
None
None
None
None
None
None
Relative Stringency of
Existing Control to
HON
-
-
-
-
(8
«
<»
«
<
-
-
«
=
s
-
<
<
«e
.f
«e
»
-
.
.
-
-
B
»
-------
Table 4. Wastewater Stream Data Summary
ABS, Cm
ABS, Ce
ABS, Ce
ABS, Be
MABS
AO (AG)
AV(AP)
AU (AO)
AU (AO)
AU (AO)
None
None
None
None
None
None
None
None
None
None
=
~
.
&
=
Controlled streams represent majority of wastewater volume at Facility.
There are 9 facilities that meet this scenario.
There are 8 facilities that meet this scenario.
There are 5 facilities that meet this scenario.
One of two streams meeting the HON. Judged not to be clearly more stringent than the HON.
Partial control of stream only. Judged not to be clearly more stringent man the HON.
-------
Table 5. Relative Stringency of Existing Controls and MACT Floor
to HON Requirements for Wastewater Streams
Subcategory
MBS
Facility*
BJ(AE)
AS(L)
BD(AQ)
Overall Stringency of MACT Floor to HON
SAN, C
BF(AD)
AM (AD.
Overall Stringency of MACT Floor to HON
SAN, B
BF(AD)
BE(AQ
Overall Stringency of MACT Floor to HON
ASA/AMSAN
PET TPA. C
AX (AM)
9 Others
Q(H)
S(B)
Overall Stringency of MACT Floor to HON
PET DMT, C
8 Others
P(A)
Overall Stringency of MACT Floor to HON
PET DMT, B
5 Others
AG(D)
Relative Stringency of
Existing Control to
Existing Source HON
D*miSmMMt«e
iSCTjuiiCIIICllla
K.-,>1
•
«
«
-
.
=
-
.
-
-
<
-
• -
<
.
-
=
-
.
-
Relative Stringency of
Existing Control to New
Source HON
Requirements
l<,-,>]
-
-
«
•§
.
=
-
-
-
•>
<
-
«
<
a*
-
-
-
-
-
-------
Table 5. Relative Stringency of Existing Controls and MACT Floors
to HON Requirements for Wastewater Streams (Continued)
Subcategory
Facility*
M(F)
L(0)
R(W)
Overall Stringency of MACT Floor to HON
PET TPA, B
EPS
PS, B
PS, C
0(V)
AQ(AI)
AR(AK)
AP(AH)
AO (AG)
AN(AL)
AX (AM)
BI(N)
Overall Stringency of MACT Floor to HON
MABS
Nitrite
ABS, Be
AU (AO)
AI(AA)
AU (AO)
Relative Stringency of
Existing Control to
Existing Source HON
Requirements
!<,=,>]
<
<
-
-
-
NDb
NDb
=
.
-
=
=
.
-
.
«
«
-
Relative Stringency of
Existing Control to New
Source HON
Requirements
[<.-,>]
<
<
«
-
«
NDb
NDb
8
=
-
s
=
=
-
«
.
•
-
-------
Table 5. Relative Stringency of Existing Controls and MACT Floor
to HON Requirements for Wastewater Streams (Concluded)
Subcategory
ABS, Cm
Facility*
AN(AL)
AO (AG)
Overall Stringency of MACT Floor to HON
ABS, Bs
ABS, Ce
AV(AP)
AU (AO)
Overall Stringency of MACT Floor to HON
ABS.Latex
AH(Z)
Relative Stringency of
Existing Control to
Existing Source HON
ReqdraMats
-
=
-
NDb
-
=
=
=
Relative Stringency of
Existing Control to New
Source HON
Requirement}
R
-
-
NDb
=
«
«
-
a Only facilities with data are included. Facilities without data are assumed to be equivalent.
b No data for subcategory. Assumed equivalent to the HON.
-------
Table 6. Storage Vessel Data Summary
For All Subcategories Except PS, C
Subcategory
MBS
Facility
BJ(AE)
AS(L)
BD(AQ)
Overall Stringency of MACT Floor to HON
SAN, C
BF(AD)
AW (AN)
AM(AJ)
Ovenll Stringency of MACT Floor to HON
SAN, B
BF(AD)
BE (AC)
Ovenll Stringency of MACT Floor to HON
ASA/AMSAN
PET TPA, C
i
AX (AM)
A (19)
1(28)
J(23)
K(21)
S(29)
Ovenll Stringency of MACT Floor to HON
PET DMT, C
0(25)
1(28)
Overall Stringency of MACT Floor to HON
Relative Stringency of
Existing Control to
Bahllng Source HON
iteirifHMnfs
!<,-,>]
-
>
.
-
-
. >
-
-
-
•
.
>
*
«
-
-
-
-
-
-
-
Relative Stringency of
Foisting Control to New
Source HON
[<,-.>]
-
-
-
-
-
>
-
>
-
-
-
>
-
-
-
-
-
-
-
-
-
-------
Table 6. Storage Vessel Data Summary
For All Subcategories Except PS, C
PET DMT, B
L(22)
1(28)
N(15)
Overall Striflgocy of MACT Floor to HON
PET TPA, B
EPS
AF(Q
BA(I)
AB(S)
Overall Stringency of MACT Floor to HON
MABS
ABS.Be
AU (AO)
BF(AD)
BE (AC)
AM(AJ)
AU (AO)
Overall Stringency of MACT Floor to HON
ABS.Crn
AN(AL)
BF(AD)
AO(AG)
AM(AJ)
AP(AH)
Overall Stringency of MACT Floor to HON
•i
«
«
.
.1
«
>
-
.
.
'
«
-
-
.
-
.
>
.
>
-
«
.
.
.
.*
-
>*
-
_b
-
-
.
•
-
«
-
-
>
-
>
>
-------
Table 6. Storage Vessel Data Summary
For All Subcategories Except PS, C
ABS, Bs
BF(AD)
BE (AC)
Overall Stringency of MACT Floor to HON
ABS,Ce
AV(AP)
AU (AO)
Overall Stringency of MACT Floor to HON
ABS, Latex
Nitrile
PS, B
AH(Z)
AI(AA)
Y(V)
AY (I)
BA(J)
AK(B)
AL(F)
AB(S)
Overall Stringency of MACT Floor to HON
»
-
.
.
.
IV
.
>
>
>
>
-
-
M
M
-
-
-
-
.
.
-
>
>C
>C
>c
-
-
.
.C
*No data. MACT floor assumed to be equivalent to the HON based on existing control levels for other 3 PET
Subcategories.
"Cannot define new source MACT floor based on this facility due to missing storage vessel size data.
Defaulted to HON as regulatory alternative.
cCannot define new source MACT four on d»ese facilities due to missing stooge vessel size data and
•unknown* control efficiency. Defaulted to HON as regulatory alternative.
-------
Table 7. (Existing PS.C Storage Vessel Data Summary
Facility
AJ(D)
W(A)
AC(B)
X(U)
BF (AD)
AZ(H)
AY (I)
BA(J)
AO (AG)
AQ(AD
AM(AJ)
AP(AH)
AR(AK)
AN(AL)
AX (AM)
AD(Y)
Summary8
Overall Summary
• -==-
<0.75
-HON
>HON
>HON
>HON
-HON
>HON
>HON
>HON
>HON
-HON
-HON
>HON
-HON
=HON
-HON
-HON
8 >HON
>HON
Vapor pressure (psia)
i 0.75 < 1.9
NA
NA
NA
NA
iHON
NA
NA
NA
-HON
NA
>HON
HON
*HON
*1.9
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
>HON
NA
NA
>HON
HON
1 HON
Summary of 5 best performing sources.
-------
Table 8. Existing PS.C Storage Vessel Analysis - Number
of Storage Vessels Per Vapor Pressure Range
Existing Control
<,=,> theHON
(No. storage vessels)
<
=
>
Summary
Overall Summary
Vapor Pressure Range (psia)
< 0.75*
1
7
37
>HON
* 0.75 and < 1.9
0
8
4
<-HON
* 1.9
0
3
5
> HON
> HON
These numbers represent the storage vessels at the 8 best performing facilities.
-------
Table 9. New PS,C Storage Vessel Data Summary
Facility
AJ(D)
AD(Y)
W(A)
AC(B)
X(U)
BF (AD)
AZ(H)
AY (I)
BA(J)
AO (AG)
AQ(AI)
AM(AJ)
AP (AH)
AR(AK)
AN (AL)
AX (AM)
Summary
Overall Summary
<0.1
«HON
«HON
>HON
>HON
>HON
=HON
>HON
>HON
>HON
>HON
«HON
«HON
=HON
«HON
=HON
«HON
>HON
Vapor pressure (psia)
i 0.1 < 1.9
«HON
NA
iHON
NA
NA
*HON
iHON
NA
NA
>HON
NA
=HON
>HON
>HON
>HON
=HON
>HON
* 1.9
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
*HON
NA
NA
>HON
HON
Facility
=HON
-HON
^HON
>HON
>HON
iHON
iHON
>HON
>HON
>HON
=HON
=HON
=HON
=HON
>HON
=HON
>HON
>HON
-------
Table 10. Process Vents Data Summary For All Subcategories
PET DMT, C
P(A)
KE)
Q(H)
B(J)
C(L)
G(M))
Overall Stringency of MACT Floor to HON
PET TPA, C
P(A)
S(B)
I(E)
Q(H)
C(L)
J(N)
K(R)
A(S)
Overall Stringency of MACT Floor to HON
PET TPA, B
PS, B
PS, C
Z(W)
W(A)
BF(AD)
AO (AG)
AP(AH)
AQ(AI)
AR(AK)
AN(AL)
=
=
=
=
=
—
=
=
=r
=
-
-
=
-
=
—
_a
<
ss
=
=
=
=
-
=
=E
=
18
a:
<
as
2=
as
:=
as
a:
=
=
:=
=
=
«a
<
=
=
=r
=
<
=
=
-------
Table 10. Process Vents Data Summary For All Subcategories
AX (AM)
AC(B)
BI(N)
Overall Stringency of MACT Floor to HON
=
=
=
=
=
=
<
-
a No data. Assumed to be equivalent to the HON.
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-------
APPENDIX A
RAW DATA TABLES FOR STORAGE VESSELS
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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 • RESEARCII TRIANGLE PARK, MC • LOS ANGELES. CA • CNONNATI. 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,
1 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.
-------
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.
-------
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FOOTNOTES TO TABLE 1
a V = valves; P = pumps; PRVs = pressure relief valves; OELs = open-ended lines; Comp. = compressors; Samp. Conn.
sampling connections; G = gas service; LL = 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
e 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)72 • 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
LDAR PERIOD
Annual
Quarterly
Monthly
f,
: 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 H
Detailed Discussion
For annual 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 pern. 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 ncre. 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)
6 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
Annual
Quarterly
Monthly
Uncontrolled
LEAK DEFINITION (ppm)
500
2.42
0.896
8.5
1000
3.3
2.26
0.83
8.3
10000
1.60
0.54
4.34
Uncontrolled
4.34
LIGHT LIQUID SERVICE VALVES EMISSION FACTORS (Ibs/hr)
LDAR PERIOD
Annual
Quarterly
Monthly
Uncontrolled
LEAK DEFINITION (ppm)
500
0.00257
0.00099
1000
0.00395
0.00273
0.00106
10000
Uncontrolled
0.0035 I
0.00141 II
1 0.00887
Estimated by averaging the emission factors for annual LDAR and monthly LDAR both with leak definition of 10,000
ppm.
8 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
500
1.00 I
13.6
LEAK DEFINITION (ppm)
1000
3.095
1.13
13.3
10000
2.33
•"•• " -••Jiii-i _ i •
0.79
7.48
Uncontrolled
I
I ™> I
-------
FOOTNOTES TO TABLE 1
(continued)
GAS SERVICE VALVES EMISSION FACTORS (Ibs/hr)
LDAR PERIOD
Annual
Quarterly
Monthly
HON
Uncontrolled
LEAK DEFINITION (ppm) |
500
0.00323
0.00121
0.00099
1000
0.00345
0.001298
Uncontrolled
10000 I
0.00429 H
0.00165 R
| 0.0131
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
LDAR PERIOD
Annual
Quarterly
Monthly
HON
Uncontrolled
LEAK DEFINITION (ppm)
500
7.2
4.49
17.6
1000 I 10000
6.5 || 3.75
4.02 I
4.02
17.1
1.77
Uncontrolled
1 1
7-48 | 7.48 |
LIGHT LIQUID SERVICE PUMPS EMISSION FACTORS (Ibs/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 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 ppn (see footnote d above) plus 5 percent
based on increased effectiveness of decreasing the leak definition from 10,000 ppm to 1,000.
1 Assumed to be 1 percent more effective than with leak definition of 1,000 ppn.
-------
FOOTNOTES TO TABLE 1
(continued)
ra Assumed 200 ppm leak definition had same emission factor as 500 ppm.
" 1993 Protocol document, p. 2-21:
1.90x10* x (500)0824 = 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 1X)
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
= 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
Pump seals, heavy liquid
service
Pressure relief valves
Open ended lines
Compressor seals
Connectors
AVERAGE
EMISSION
FACTOR
(kg/hr)'
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)*
0.000131
0.000165
0.00023
0.00187
0.00210
0.0447
0.00150
0.0894
0.000081
PERCENT OF
COMPONENTS
>10,000 PPMe
7.48
4.341
NA
7.48
3.048
3.6
1.91
9.13
1.55
PERCENT OF
COMPONENTS
<10,000 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.
-------
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.
e 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 (Y)
1.00 » X + Y
where: X • percent of components with >10,000 ppm
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
0.00156
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)
' Assumed to be midway in effectiveness between "uncontrolled11 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 Bay 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.
w Based on 100 percent control efficiency. 1993 Protocol document, P. 5-2.
-------
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-------
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
u
-------
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
813
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)
Dart, Leola
Amoco, Willow
Springs
Dart, 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
7&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
-------
TABLES
SUMMARY OF ESTIMATED PERCENT EMISSION REDUCTIONS
AND MACT FLOORS FOR EQUIPMENT LEAKS
SOURCE
CATEGORY/
SUBCATEGORY
MBS
Nitrile
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
Id, 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
-------
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
-------
EPA-453/R-95- 003a
j. Mti_irieN i -S
NO.
4. TITLE AND SUBTITLE Hazardous Air Pollutant Emissions
from Process Units in the Thermoplastics Manufac-
turing Industry—Supplemental Information
Document for Proposed Standards
S. REPORT DATE
March 1995
6. PERFORMING ORGANIZATION CODE
7. AUTHOHtSI
8. PERFORMING ORGANIZATION REPORT NO
I. PERFORMING ORGANIZATION NAME AND ADDRESS
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68D10116
12. SPONSORING AGENCY NAME AND AOORESS
Director, Office of Air Quality Planning and
Standards, Office of Air and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
13. TYPE Of REPORT AND PERIOD COVERED
1*. SPONSORING AGENCY CODE
EPA/200/04
IS. SUPPLEMENTARY NOTES
6. ABSTRACT
A proposed rule for the regulation of emissions of organic hazardous air pollutants (HAP)
and the following Group IV polymers and resins: acrylonitrile butadiene styrene (ABS)
resin, styrene acrylonitrile (SAN) resin, methyl methacrylate acrylonitrile butadiene styrene
(MABS) resin, methyl methacrylate butadiene styrene (MBS) resin, polystyrene resin,
polyethylene terephthalate) (PET) resin, and nitrile resin. This thermoplastics rule is being
proposed under the authority of Sections 112, 114, 116, and 301 of the Clean Air Act, as
amended in 1990. This Supplementary Information Document contains memoranda
providing rationale and information used in developing the proposed standards.
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
Air pollution
Pollution control
Hazardous air pollutant
IB. CISTRIdUTION STATEMENT
Release Unlimited
b.lOENTIFIERS/OPEN ENDED TERMS
Air pollution control
Thermoplastic polymer
manufacturing industry
19. SECURITY CLASS I Pus Repnrri
Unclassified
30. SECURITY CLASS iTIuspair-
Unclassified
C. COSATI ! nslJ.ut -..a
21 NO. OF "ACES
472
22. ""ICE
SPA Form 2230.1 (R«». 4.77) onevious COITION is OBSOLETE
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|