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 

copolymers (PVC) production units. Secondary impacts result from the generation of steam 

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

devices.

Section 2.0 presents the background for the final standards. Section 3.0 presents the 

secondary 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 

(NESHAP) 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 category 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. To determine the secondary impacts for each 

subcategory, the EPA must first determine the minimum stringency “floor” requirements. 

Development of MACT for PVC units is described in a separate memoranda.

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 product recovery condensers to reduce VC, hydrogen chloride (HCl),

and total organic HAP emissions from process vents, and

Floating 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. Water is required to generate steam for resin stripping; 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 

electricity2. 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 15) 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 will come online in the next five years.

5.0 Secondary Air Pollutant Impacts

Emission factors from the EPA’s Egrid3database were used to calculate emissions 

resulting from the electricity required for additional control devices. Increased electrical use 

from the control options will require additional fuel to be burned in power plants, resulting in 

emissions of carbon dioxide (CO2) and criteria pollutants, such as sulfur dioxide (SO2) and

nitrogen oxides (NOx). Emissions of these pollutants (caused by an increase in electricity) were 

also estimated 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 CO2, NOx and SO2 from increased
electricity usage for MACT floor control analyzed for existing sources. Table 5-2 shows the 

Egrid emission factors used for the calculations.

Table 5-1. Secondary Air Pollutant Impacts for Existing Sources

Electricity Requirements and 

Emissionsa

MWh/yr

CO2

Emitted

(tons/yr)

NOx

Emitted

(tons/yr)

SO2 

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

CO2 – Carbon dioxide

SO2 - Sulfur dioxide

NOx – nitrogen oxides

Table 5-2. Emission Factors

Pollutant

Electricitya

(lb/MWh)

CO2 1,329

NOX 1.9366

SO2 5.2589

a. National emission factors from Egrid5for EGUs.

lb/MWh – pounds per megawatt hour

CO2 – Carbon dioxide

SO2 - Sulfur dioxide

NOx – nitrogen oxides
6.0 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, Inc. to Jodi Howard, U.S. Environmental Protection 

Agency. February 2012.

2. “Revised Costs and Emission Reductions for Major Sources in the Polyvinyl Chloride 

and Copolymers (PVC) Production Source Category.” Memorandum from Eastern 

Research Group, Inc. 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/documents/egridzips/eGRID2007V1_1_year05_SummaryTab

les.pdf