TECHNICAL MEMORANDUM

TO: Jodi Howard, US EPA/OAQPS/SPPD/RCG

FROM: Eastern Research Group, Inc.

DATE: February 8 , 2012

SUBJECT: Revised Secondary Impacts for the Polyvinyl Chloride and Copolymers

(PVC) Production Source Category

1.0 Introduction

This memorandum presents revisions to the secondary impacts associated with control devices used to comply with the final standards for existing and new polyvinyl chloride and

co polymer s (PVC) production units. Secondary impacts result from the generation of steam

and/or the consumption of fuel, water, and electricity and generation of so lid wastes by control

devices.

Section 2.0 presents the backgrou nd for the final standards. Section 3.0 presents the

secondar y impact estimates associated with control devices necessary for PVC production facilities to comply with the final standards

. This memorandum focuses only on secondary impacts associated with control devices. Section 4.0 summarizes the estimated secondary impacts that would result from the compliance of new units that may come online in the next 5

years. Section 5.0 summarizes the emissions resulting from increased fuel and electricity requirements for the control options.

2.0 Background

The U.S. Environmental Protection Agency (EPA), under section 112 of the Clean Air Act (CAA), is required to establish national emissions standards for Hazardous Air Pollutants ( NES HAP) emitted from PVC production facilities . The complete set of regulated hazardous air pollutants ( HAP ) is listed in CAA section 112(b). The CAA requires the EPA to determine the maximum achievable control technology (MACT) for each cate gory or subcategory of sources. The purpose of the memorandum is to present the methodology used to determine the secondary impacts for the PVC production source category. T o determine the secondary impacts for each subcategory, the EPA must first determine the minimum stringency “floor” requirements

. Development of MACT for PVC units is describe d in a separate memorand a

. 1

3.0 Secondary Impact Estimates for Existing Sources

To comply with the final standards , facilities may need to install the following types of

control devices at PVC units:New resin stripping equipment to reduce vinyl chloride (VC) and total non

- vinyl chloride organic HAP (total non

- VC organic HAP) emissions from equipment downstream of the resin stripper(s)

,

Refrigerated p roduct recovery condensers to reduce VC, hydrogen chloride ( HCl )

, and total organic HAP emissions from process vents

, and

Flo ating objects to reduce VC and total organic HAP emissions from gasholder water

seals.

Electricity is required to operate the pumps and fans associated with the condenser

systems

. W ater is required to generate steam for resin s tripping ; however, it was assumed that no

incremental steam generation would be required in addition to current operations.

Table 3

- 1 shows, for the refrigerated condensers , the estimated secondary impacts for the

source category

. The algorithms used in the cost analysis provide annual cost estimates for electricity 2

. To estimate the secondary impact components (e.g., electricity), the itemized annual cost of each component was divided by the unit price of the component used by the algorithm.

Table 3

- 1. Secondary Impacts for MACT Floor Control

Emission Point Controls Required for Compliance Electricity Required (MWh /yr)

Process Vents Condenser ( 8 of 1 5 ) 5,349
MWh/yr

– Megawatt hours per year

4.0 Secondary Impact Estimates for New Units

The EPA does not expect that any new PVC units w ill come online in the next five years

.

5.0 Secondary Air Pollutant Impacts

Emission factors from the EPA’s Egrid 3 database were used to calculate emissions resulting from the electricity required for additional control dev ices. Increased electrical use from the control options will require additional fuel to be burned in power plants, resulting in

emissions of carbon dioxide ( CO 2 ) and criteria pollutants, such as sulfur dioxide ( SO 2 ) and nitrogen oxides ( NO

x )

. Em issions of these pollutants (caused by an increase in electricity) were

also estim ated using the EPA’s Egrid database. The Egrid database summarizes emissions of criteria pollutants on a per electrical usage basis , in terms of pounds emitted per megawatt

- hour (lb/MWh) and on a national average or state average basis. For this analysis the national average

was used. Table 5

- 1 summarizes the resulting emissions of CO 2 , NO

x and SO 2 from increase delectricity usage for MACT floor control analyzed for existi ng sources. Table 5

- 2 shows the

Egrid emission fa ctors used for the calculations.

Table 5

- 1

. Secondar y Air Pollutant Impacts for Existing Sources

Electricity Requi rements and

Emissions a

MWh/ yr CO 2

Emitted (tons/yr) NO

x

Emitted (tons/yr) SO 2

Emitted (tons/yr)

5,349 3,555 5.2 14.1

a

- Emissions estimated based on emission factors listed in Table 3. MWh/yr

– Megawatt hours per year Tons/yr

– Tons per year

CO 2 – Carbon dioxide

SO 2 - Sulfur dioxide

NO

x – nitrogen oxides

Table 5

- 2

. Emission Factors

Pollutant Electricity a

(lb/MWh)

CO 2 1,329

NO
X 1.9366

SO 2 5.2589

a. National emission factors from Egrid 5 for EGUs.

lb/MWh

– pounds per megawatt hour

CO 2 – Carbon dioxide

SO 2 - Sulfur dioxide

NO

x – nitrogen oxides6.0 References

1. “ Revised Maximum Achievable Control Technology ( MACT ) Floor Analysis for the Polyvinyl Chloride and Copolymers (PVC) Production Source Category

. ” Memorandum from Eastern Research Group, In c. to Jodi Howard, U.S. Environmental Protection Agency

. February 2012

.

2

. “ Revised C ost s and Emission Reduction s for Major Sources in the Polyvinyl Chloride and Copolymers (PVC) Production Source Category

. ” Memorandum from Eastern Research Group, I nc. to Jodi Howard , U.S. Environmental Protection Agency

. February

2012

.

3

. EPA eGRID database eGRID2007 Version 1.1. Year 2005 summary tables located at www.epa.gov/cleanenergy/documen ts/egridzips/eGRID2007V1_1_year05_SummaryTab les.pdf