!RECEIVED

EASTIVIAN

August 9, 1999

AIRBORNE EXPRESS

1/_., ~-'r:S

I:cl~,rna~ ~}~~"k.S> c:)~Pilny P. O.ll,ox 431

Kingsport, Tennessee 37662

----liOI+:C+l-H0-4-49'H99~--------

OAQPSAIR

DOCKET CONTROL ROOM

Air and Radiation Docket and Information Center (6102)

Attn: Docket No. A-92-45

U.s. Environmental Protection Agency

401 M Street SW

Washington, D.C. 20460

iAUG'1 6 1999

~-_ .... -- .~ .. __ ._- ..- Er.'" ,s.lR DOC,<ET

Subject:

Reference:

Eastman Chemical Company Comments On U.S. Environmental

Protection Agency's Proposed Denial of Petition for Reconsideration -

Group IV Polymers and Resins Equipment Leak Provisions

64 Federal Register 30456; June 8, 1999

Dear Sir or Madam:

Enclosed arc Eastman Chemical Company's (Eastman) comments on the abovereferenced Proposed Denial of Petition for Reconsideration. Eastman's comments can be

swnmarized as follows:

•

•

•

Eastman has no objection to provisions from 40 CFR 63 Subpart H referenced

by 40 CFR 63.1331 relating to compressors, sampling connections, pressure

relief devices, and open-ended lines. Additionally, Eastman has no objection

to provisions in 40 CFR 63.1331 relating to equipment in heavy liquid service.

However, EPA's analysis combines these subcategories with the portion of

the program requiring Method 21 monitoring (pumps, valves, and connectors

in gas/vapor or light liquid service), thereby obscuring the true costeffectiveness ofthe latter program.

EPA's reanalysis ofthe cost-effectiveness ora Method 21 ba<:jed Leak

Detection and Repair Program (LDAR) applied to equipment in gas/vapor or

light liquid service still relies on use of default SOCMI average emission

factors for initial emission estimates for nearly 50% of covered equipment in

their database. Use ofmore representative data supplied by the polyethylene

terephthalatc (PET) manufacturers as well as data provided by the Chemical

Manufacturers Association (CMA) provide convincing evidence that the

SOCMI factors overly conservative. Substitution ofthe weighted average

initial leak rates provided by the PET manufacturers for the SOCMI factors in

EPA's analysis shows that EPA's estimates of emission reductions are nearly

ten times too high.

While EPA has adjusted several ofits assumptions in its cost algorithm in

response to Petitioners' comments, it still has not adequately addressed the

,

l1esponslblc

'i~Care€>

A Public ConunilmCllt
Eastman Comments

August 9. 1999

Page 2

costs ofsetting up the program for components subject to routine Method 21

monitoring.

• EPA should make the necessary adjustments to its cost-effectiveness analysis

as outlined in these comments. When it docs, EPA will find that the Method

21 program for components in gas/vapor and light liquid service is not costeffective. In response to this finding, EPA should revise the regulations to

extend the sensory based program for heavy liquid service (40 CFR

63.133 1(a)(6» to components in gas/vapor and light liquid service.

Eastman has reviewed comments filed by KoSa on this proposed denial and is in full

agreement with those comments. Ifthere are any questions concerning these comments

or additional information is needed, please contact either of us at our telephone numbers

shown below.

~i~/ihIA/> R~ s~p;l~{. ~~ssett Environmental Associate

(423)~27 atJ11

p~O.~

David A. Golden

Senior Attorney

(423)229-8329

cc: Mr. Keith Barnett, EPA OAQPS
Eastman Chemical Company Commcnts

On u.s. Environmental Protection Agency's

Proposed Denial of Petition for Reconsideration - Group IV Polymcrs and Resins

Equipment Leak Provisions

64 Federal Register 30456; June 8, 1999

nackground

On January 23, 1997, Eastman Chemic..1Company (Eastman) and I-Ioechst Celanese Corporation (now

known as KoSa) filed a Request for Administrative Stay and Petition for Reconsideration for applicable

portions ofthe National Emission Standards for Hazardous Air Pollutants promulgated at 40 CFR 63.1331

which require the detection and repair of c<luipment leaks by affected sources manufacturing polyethylene

tercphthalate (PEl).

EPA subsequently granted the stay, but on June 8, 1999 proposed in the Federal Register (64 FR 30456) to

deny the petition for reconsideration and extended the stay until February 27, 200 I.

Eastman and KoSa's (the "Petitioners") petition claims that the leak detection and repair program proposed

for both heavy liquid and light liquid service components at PET f.,cilities is not cost-effective and that

since EPA concluded that the MACT floor for equipment leaks is "no control", EPA has no basis for the

standard under section I 12(d) ofthe Clean Air Act.

EPA claims ill the proposed denial that aner responding to Petitioners' comments and adjusting their

analysis, that no change in the standard is warranted:

"Based on the results oCthe new analysis, the EPA still judges the equipment leak program as

promulgated to be cost-effective for PET facilities. TIlerefore, the EPA has determined that there

is no need to remove the equipment leak standards from the promulgated rule for Group IV

Polymers and Resins and no need to modify any provisions within the equipment leak program of

40 CPR part 63, subpart H." (64 PR 30462)

Eastman's Position

Eastman believes that EPA's conclusion is erroneous and the equipment leak provisions relating to

utilization of Method 21 monitoring of equipment in gas/vapor and light liquid service are not costeffective. Eastman has no objection to provisions from 40 CFR 63 Subpart H referenced by 40 CFR

63.1331 relating to compressors, sampling connections, pressure relief devices, and open-ended lines.

Additionally, Eastman has no objection to provisions in 40 CFR 63.1331 relating to equipment in heavy

liquid service.

Detailed Technical Comments

The following comments support Eastman's beliefthat changes arc warmnted to provisions relating to

pumps, valves, and connectors in light liquid service.

I. Uncontrolled emission factors provided by the Petitioners and olher PET manufacturers arc more

representative of PET processes than EPA's SOCMI factors.

EPA's initial logic in referencing Subpart H standards for gas/vapor and light liquid service was

that it believed the Method 21 based leak detection and repair program is cost-effective. This is an

extension ofthe justifieation for the Subpart H standards. However, the conclusion that this

program is cost-effective hinges on the estimate ofthe uncontrolled (hereafter referred to as

"initial average leak rate") equipment leak emissions as well as estimates ofthe costs of the
program. Lacking more representative data from the IJETsource category, EPA assumed the socalled "SOCMI" factors as the delimit initial average leak rates.

In promulgating the Polymers and Resins Group IV standards, EPA failed to consider any other

data to support continued use ofthe SOCMI factors. Now that the SOCMI industry has

widespread experience and data from startup and operation ofSubpart H programs under the HON

over the last 5 years, it is clear that the SOCMI factors are grossly conservative and that initial

average leak rates are several times less than what those tactors indicate. EPA lIIade no effort to

examine this data which is readily available in periodic reports submitted by HaN sources across

the nation.

Subsequently, the Petitioners provided this data from HaN sources within their representative

companies. Although EPA applied these company specific leak rate factors to the Petitioners'

equipment count estimates in its reunalysis oflhe cost-effectiveness of tlte LDAR standurds, it

qualifies this use as follows:

"Il is important to lIote tltnt tlte EPA is using the petitioners' leak frequency rates ()f

.malysis purposes only in responding to the petitioners' comments, and is not accepting

them as valid. The level ofdetail associated with the ICflk freque~cy rates and

inconsistencies in the presentation ofthe data (as discussed in the following parngraph)

make it impossible to verify the accuracy ofthe leak mte data. In addition, there is no

certainty that these leak frequency rates arc applicable to the petitioners' PET facilities,

because the monitoring and repair program in IJlace for the submitted data at the time of

the reported initialmeasurcments may not reflect the uncontrolled leak frequency from

the PET facility. Two petitioners submilted infonnation on the equipment leak

frequencies for a number ofnon-PET facilities. Upon request, they also provided data to

support those reported leak frequencies. In reviewing the supporting data, there appear to

be a number ofinconsistencics, some ofwhich would affect the estimated leak frequency.

For example, in the infonnution submitted by one petitioner these inconsistencies

include: (I) The number ofleaking components reported in the summarization table do ...)

not match the monitoring results in the audit report; (2) start dates do not match between

the summari7.ation table and the audit report; (3) total number of components in the

summari7.ation table do not always match the number tested in the audit report; and (4) it

is unclear what "net" readings refer to and it is possible that this is an incorrect

accounting of leakers. In another petitioner's data, concerns arc: (I) the data shects do not

match the numbers in the screening results table; and (2) it is unclear what "adjusted"

readings, which arc presented for many ofthe process units and their leaking

components, refer to and it is possible that this is an incorrect accounting ofleakers.

Notwithstanding these technical uncertainties, the EPA has used the petitioners' leak

frequCl1cy rutes in the reanalysis." (64 FR 30458)

Eastman acknowledges there were somc minor discrepancies between the summary table and the

audit report. After discussing the issue with the EPA contractor, Kenneth Meardon of Pacific

Environmental Services, Eastman offers the following comments to address these concerns with

the data: The audit report generated by the LDAR software shows the number ofcomponents

tested along with the number of "pass/fail" and the number of leakers. lne number of"failures"

docs not always match the number of "Ieakers". The software vendor has informed Eastman that

this particular report may be prone to this type of error. There were four cases where the summary

table appeared to connict with the audit report for total number of components. In these cases,

there was one number of components on the initial monitoring run and more in a later fun. Since

there were no leakers found in any ofthese runs, the larger number was used in the summllry table.

The last issue raised by EPA questioned the usc of"net" readings in that it may result in an

inaccurate count ofleakers. The "net" reading is the difference between the maximum reading otT

of the monitor and the background reading. "Net" readings were used to compare to the leak

definition to detennine leakers for connectors only. ntis is in accordance with Subpart H (40 CFR

63. I80(c».

Eastman Comments.doc

9-Aug-99

Page 2 01'8

J '~
In order to clear up any inconsistencies and to present a more refincd analysis ofEastman's initial

average leak rates for the HON facilities at its Tennessee and South Carolina sites, Eastman

presents II better method to estimate its leak rotes. The leak rates estimated in the petition for the

Tennessee and Carolina Eastman sitc's were based on the fraction ofcomponenls exceeding the

leak definition and use of equations relating average leak rate to fraction leaking at SOCMI units

(these equations are found in Table 5-4 offrom EPA's Protocol for Equipment Emission

Estimates (1995». However, a better method of estimating average leak ratcs is to usc actual

screcning valucs (in ppmv) and EPA's correlation equations found in Table 2-9, 2-11 (DefaultZero Values), and 2-13 (Pegged Emission Rates) from EPA's Protocol for Equipment Emission

Estimates (1995). The following excerpt from the Protocol Document supports this method of

estimating leak rates:

"2.3.3 EPA Correlation Approach

't11is approach olTers an additional rcfinement to estimating emissions from equipment

leaks by providing an equation to predict mass emission rate as a function ofscreening

vallie for a particular equipment type. Correlations developed by the EPA relating

screening values to mass emission rates for SOCMI proccss units and for petroleum

industry process units are prcsented in tables 2-9 and 2-10, respectively."

"The EPA Correlation Approach is preferred when actual screening values arc available.

Correlations call be used to estimate emissions for the cntire rangc of non-zero screening

values, from the highest potential screening value to the scrcening value that represents

the minimum detection limit ofthe monitoring device. This approach involves entering

the non-zero, non-pegged screening value into the correlation equation, which predicts

the TOC mass emission rate based on thc screening value. Default zero emission rates arc

used for screening valucs of zero ppmv and pegged emission rates are used for "pegged"

screening values (the screening value is beyond the upper limit measured by the portable

screening device)."

Eastman has been able to extract screening values from its LDAR data management software into

Excel spreadsheets and estimate average leak rates using the correlation equations. This method

should render any concerns about use ofthe previously submitted audit report and determinations

of leak fractions moot. These spreadsheets arc attached to the electronic c-mail submittal of these

comments. 'nle revised initial avcrage leak rates are shown below:

Component Leak Rate Based on Leak Rate Based

Fraction Leaking on Correlation

(Ib/hr/component) Approach

(Ib/hr/component)

,', "/i , ". :",'.~ re~Jlessee Eastman

Pumps (light liquid) 0.01013 0.00385

Valves (glv) 0.00158 0.00030

Valves (light liquid) 0.001835 0.00082

Connectors (glv & 0.000523 0.00038

light liquid)

Carolina Eastman

Pumps (light liquid) 0.022792 0.00143

Valves (glv) 0 0.000026

Valves (light liquid) 0 0.00013

Connectors (g1v & 0.000164 0.000047

light liquid)

Eastman disagrees with EPA's logic that the initial leak rates for the Petitioners' non-PET

facilities arc not applicable to PET facilities "because the monitoring and repair program in place

Eastmnn Comments.doc

9-Aug-99

Page 3 or8
for the submittcd data at the lime ofthe reportcd initialmcasurcltlcnts may Hut renccl the

uncontrolled leak frequency from the PET facility." On the contrary, this data obtained from nonPET facilities is more representative ofthe Petitioners' PET facilities than the SOCMI factors. In

the case ofEastman's initial average leak rale data from its HaN facilities, Eastman believes it is

the best data available to estimate initial leak rates from its PET facilities for the following

reasons:

• 'l1le HaN facilities are co-located with the PET facilities.

• TIle ages offacilities representing the HaN data set are representative ofthe age ofthe PET

f'lcilitics.

• Similar engineering and construction standards were used for both the lION and PET

facilities.

• Similar maintenance practices are employed.

• Piping in both liON and IJET facilities arc in similar chemical service (temperature and

pressure).

• Much ofthe liON data is from piping in methanol service (methanol is the primary IIAP in

gas/vapor and light liquid service in PET facilities).

Thesc argument,; cannot be made for the representativeness of thc SOCMI factors when applied to

the PET facilities.

EPA makes another point in its describing its uncertain usc ofthe Petitioners' data:

"Whilc these two petitioners state that they currently have in place a program that repairs

leaks through coordination with their maintenance staff, they do not provide any

information documenting the effectiveness of n sensory program relative to a monitoring

program for components in gas/vapor or light liquid service. But whatever their

effectiveness, the EPA has used their data in the reanalysis." (64 FR 30458)

Again, Eastman disagrees with this point The Petitioners' non-PET initial leak rate data the

documentation ofthe effectiveness ofa sensory program. At Eastman, informal sensory based

(i.e. operator housekeeping walkdowns) programs have been employed plantwide for many years.

The practice has been for operators that find leaks using sight, sound, and smell to tag leaks and

write work orders for repair ofthe leaks. While records ofthese leaks and repairs are not

maintained due to company record retention guidelines, the initial Method 2 Imonitoring runs

under the HaN demonstrate the effectiveness ofthis practice. The initial average leak rates

Eastman provided excluded any equipment components that were already under a LDAR program

(e.g. NSPS Subpart VV, RCRA Subpart BB), so this data docs represent leak rates ofequipmcl1t

subject to Eastman's infomlal maintenance program. Eastman has employcd thc same basic

practice at both the co-located HaN and PET facilities. TIlere is 110 basis for EPA making the

negative assumption as opposed to the positive assumption that these leak rates are not

representative ofthe effectiveness of Eastman's sensory based program at its PET facilities.

As stated above, EPA used the Petitioners' data despite its reservations but only used them for the

Petitioners' portion ofthe source category. However, as shown below, EPA did not consider these

emission factors as representative ofthe rest of the source category:

"In responding to the petitioners' comments, the EPA performed the equipment leak

reanalysis using revised emission factors for the petitioners' facilities based on the

equipment leak frequency rates presented by the petitioners. In addition to the petitioners,

only one other company submitted data from which facility-specific leak frequencies

could be derived. The EPA used these data to calculate facility-specific emission factors

for the reanalysis for that facility. The leak frequency rates and the resulting facilityspecific emission factors were not extended to analyses ofother companies' facilities for

several reasons: (I) The other companies either have not questioned the EPA emission

E.1stman Comments.doc

9-Aug-99

Page 4 of8
/ estimates or have concurred with Ihcm, (2) Ihe equipmcnt leak IJrogrdtns to control

emissions employed by the petilioners at their facilities may not represent programs

practiced by olher companies, and (3) several companies stated that they do not have any

equipment leak programs," (64 FR 30458)

EPA has chosen to make this decision based on lack of infomlation from the other affected

companies in the PET source category rather than recognizing the logic that the Petitioners' data is

more representative ofthe PET source category than the SOCMI factors. EPA's statement that

other companies have not qucstioncd the SOCMI factors or have concurrcd with them carries no

weight in this argument. Ifthese companies have had no expcrience operating a Subpart H or

equivalent program, they would have no reason to question the SOCMI factors. 'lheir silence is

not a persuasive argument to support EPA's decision. It is doubtful the companies EPA states

have concurred with the SOCMI factors would maintain that concurrence irthey were aware of

Ihe leak rates experienced by Petitioners. Eastman believes that most PET manufacturers employ

the same basic maintenance practices as Eastman. It is doubtful that these companies would

tolerate visible leaks from piping carrying orgunic chcmicals. EPA should investigate the

possibility that the Petitioners' factors arc representative rather than maintaining the position that

the Subpart H program is cost-effective. Further, it is EPA's responsibility under the Clean Air

Act to ensure that MACT standards above the Ooor arc indeed cost-effective.

To further support that initial leak rates from Ihe SOCMI industry are far below EPA's SOCMI

factors, Eastman also refers EPA to data submitted by the Chemical Manufacturer's Association

(CMA) to the EPA relating to the developing Miscellaneous Organic NESHAP (MON). 111is data

is summarized below and the CMA letter is attached (Attachment I) to these comments:

Component Leak Facilities! Number Initial Leak

Delinition Processes Monitored Rate

(ppmv)

Connectors 500 38 144,792 0.12%

Connectors 10,000 5 19,912 0.84%

Pumps 500 2 121 0.00%

Pumps ],000 4 683 1.9%

Pumps 2,000 3 82 0.00%

Pumps 5,000 5 374 10.43%

Pumps 10,000 23 662 1.96%

Valves 500 17 62,299 0.50%

Valves 5,000 I 483 0.00%

Valves 10,000 24 21,185 0.58%

Shown below is a comparison of the SOCMI leak rates to the weighted average leak rates for the

CMA data set determined using the equations in Table 5-4 of EPA's Protocol Document:

Component CMA Average Leak SOCMI Leak Rate Ratio SOCMI to

Rate (Ibfhr) CMA Leak Ratcs

(Ib/hr)

Connectors @ 500 0.00016 0.00403 9.8

ppmv

Pumps 0.0165 0.0438 2.7

Valves 0.00081 0.00887

"

All ofthis data, as well as the Petitioners' data, support the conclusion that the SOCMI factors are

not representative ofthe initial average leak rales from the SOCMI industry generally, and the

PET industry, specitically.

Eastman Comments.doc

9-Aug-99

Page 5 of8
Eastman recommends that EPA use the Petitioners' estimates of initial average leak rates along

with any other companies' estimates that arc based on actual initial Method 21 screenings to

calculate weighted average initiaillveragc leak rates for the PET source category. Using the

Petitioners' estimates along with thc factors used by EPA for the ICI Fayetteville facility, Eastman

has calculated weighted average leak rates. TIle spreadsheet file used for this calculation is

attached (Attachment 2). IfEPA receives additional estimates from other companies, this

spreadsheet should be updated and final weighted average leak rates calculated.

The table below compares these weighted average leak rates to the SOMI factors. TIle CMA

factors arc also shown to verify that these recommended factors arc conservative.

Componcnt SOCMI PET Weighted CMA Data Set

Factors Average Factors (Iblhr)

_ .. (Ib/hr) (Ib/hr)

Pumps (light liquid) 0.0438 0.0172 0.0165

Valves (g/v) 0.0131 0.00176 0.00081

Valves (light liquid) 0.00887 0.00108 0.00081

Connectors (glv & light liquid) 0.00403 0.000541 0.00041

Based on the data provided in the docket (Docket Item No. VI-I3-20, Attachment I), Eastman has

determined that EPA estimates an emission reduction of 712 Mg per year due to the proposed

LDAR program. However, 303 Mg per year arc attributed to emission reductions from one-time

modifications of compressors, sampling connections, pressure relief devices, and open-ended

lines, leaving 409 Mg per year allributed as the benefits ofthe Subpart H Method 21 program for

gas/vapor and light liquid service. Using the recommended PET Weighted Average Factors above

(note these should be updated if additional data is obtaiiled from other companies) for all facilities

in EPA's database, Eastman estimates the reductions at only 48 Mg per year.

2. EPA has not accounted for all onhe cosL" to setup and begin a LDAR program in its costeffectiveness calculations

TIle Petitioners raised several issues related to EPA's estimate ofthe cost ofoperating a Method

21 based LDAR program. EPA responses to these comments are found in Table 2 oCthe

November 24, 1998 memorandum "Summary of Responses to Petitioners' Comments" (Docket

Item VI-B-19). EPA adjusted the cost algorithm to address Petitioners' comments related to the

fixed costs ofimplementing a LDAR program (e.g. planning and training costs, software purehase

lind development, contractor trip charges, and general program supervision and coordination).

However, EPA's cost algorithms still omit significant costs incurred up-front to set up the LDAR

program. EPA assigns a cost of$4.65 per component as the initial monitoring fcc for components

subject to Method 21 monitoring for processes with more than 500 componcnts (subcontractor run

program). EPA breaks this down into $2.15 to identify and document components (includes

locate and tag) and $2.50 for the initial screening. Based on a 1993 memorandum (Docket No. A93-48). EPA assigns $0.75 (or initial setup and screening of valves and connectors and $3.75 for

pumps for processes with less than 500 components (in-house program).

EPA specifically rejected the Petitioners' recommendation to include costs for creating/updating

facility drawings to reflect individual components in the program. EPA's response reads:

"TIle petitioners do not provide a separate cost cstimate for Item 3, creating/updating

facility drawing to reflect individual components in the program. The Group IV rule

does not require the creating or updating of a facility drawing. l11crefore, no costs were

assigncd to this item in the revised costing."

This is not a reasonable rationale to exclude these costs. While the rule docs not explicitly require

drawings to be updated, it docs require (I) a list of equipment identification numbers be recorded

Eastman Conullents.doc

9-Aug-??

Page 6 of8
/

(with some provision for groups of connectors on a nll1 of pipe) (40 CFR 63. I8 I(h» and (2) "each

piece of equipment in a process unilto which this subpart applies shall be identified such that it

Cllll be distinguished readily from equipment not subject to this subpart" (40 CFR 63. 162(c». In

order to comply with these provisions, Eastman has found it necessary to somewhere document

the component" subject to the rule. '111e logical place to make this documentation is the Process

and Instrumentation Diagrams (P&lDs). Eastman has found that usc ofthe P&lDs is the most

practical means to ensure changes to the process are incorporated into the LDAR program.

Proposed changes are approved through Management ofChange or Ihrough Capital ProjeCl"i.

Both ofthesc require drawing updatcs. TIle requiremcnt to idcntify all LDAR components adds to

the workload burden to maintain up-to-date drawings. P&IDs do not includc actualnumbcrs of

connectors because this is either shown on piping spool sheets or field detennincd during

construction. These drawings must be verified with actual field conditions and connectors must be

indicated on the P&lDs. Also, unique identifiers must he assigned 10 each component, including

connectors. Eastman has nearly 20,000 componcnts subject to Subpart H Method 2 I monitoring

at its Tcnnessee facility and Ims found that the most cost-effective menns to comply with Subpart

H and ensure complinnce with the rule is to make usc of a data management software systcm.

This system requires unique identifiers for each and every component in the database. TIlis in tum

leads to the need to physically tag each component with a barcode so that monitoring can be

expedited and data downloaded from the monitor into the database.

EPA states in its response that the $2.50 monitoring charge found in Attachment F included the

work to gather atlthe pertinent data on each component and the initial populalion ofthe software

system based on a statement on the vendor quote that the quotes included "dala entry". However,

this has nol been Eastman's experience and believes this is not the correct interpretation. The

$2.50 isjust the charge to come out and screen a component lll1d tag leakers. Initial selup of the

program (field identification ofsubjecl components, documentation on P&lDs, unique ID

assignment, creating spreadsheet of component data, creation of barcodes, and tagging) is

nomlally handled as a separate charge. EPA uses $2.15 per compunentto cover locating, tagging,

and documenting the components and claims the $2.05 charge found in Attachmenl F for "Locate

and Tag" covers all other initial set-up charges. Eastman believes this charge coversjust the

material and labor costs to create and hang tags. However, as explained further below, our

experience has shown this cost is not consistent with actual projects we have encountered and

would not cover a contractor's costs to hang the tags. It certainly would not be adequate to cover

the costs to figure out which components arc subject to the OIle, create unique IDs, document

component information on P&lDs and populate the software.

To veritY and substantiate estimates given earlier by the Petitioners, Eastman has identified a

recent project where we hired a contractor to sel up a ncwly constOlcted process for a LDAR

program. 111is particular process is subject to NSI'S Subpart VV. It includes 750 components

that must be tagged and cntered into the LDAR database. Attachment 3 is the spreadsheet

provided by the contrdctor documenting the number of hours spent on each task. Also shown in

Altachment4 are calculations converting this data 10 minutes per task per component. Shown

below is Eastman's breakdown and estimates ofthe initial costs to set up and screen the

components;

Cost Item Comments Source Unit Cost

Walkdown and Field Identify and documcnt Eastman Project - 3 $1.80

Verification components & gather data minutes per component

Create & Issue Drawings Eastman Project - 2 $0.90

minutes per component

Creatc Data Forms & Tags Eastman Project - 5 $3.40

minutes per component

Hang Tags Easlman Project - I I $6.90

minutes per component

Populate software Enter componellt data into Eastman Estimate (2 $1.20

database. mi~ute:"E:!..~ol11ponent) --_. ----

Eastman Comments.doc

9-Aug-99

Page 7 of8
\

P

costs is justified and that EPA's estimatc of$ll.65 is unreidistic. Eastman believcs, that, regardless

or the number uf components and wheUler or not lhe prog.r:mt is run by a subcontractor, thc initial

costs arc about the So.mc. In eithcr ense,thc same data must be gathered and documented. The

only S<lvings on initial setup we sec may be tlmt software does 110t have to populated. If there is a

diITerencc, it may be more cosUy per component fut a process with less than 500 components just

due to economy ofsCillc. ·OIUS. EPA's eslinmlcslor an in·house progrnrn appear unrc..,listic as

well.

Tng Cost (malerial) AUac!llllcnt f, Venuor $1.00

Quotc

MonitorinG Charge Docs flot incluue initial set· Attachmcnt F, Vendor $2.50

"Po Quote ./' "'\

Total $17.70 +-

'nlis llllUlysis demonstrates lhat llle Petitioncrs' estimate of $ 16.25 per compon{nbmjOitill.l sc~

Eastman Comments.doc

9-l\ug·99

Page 8 or8
{

Attachment 1

Letter from CMA to EPA Documenting .

CMA Member Company Survey

Initial Leak Rates
October 29, 1991

Mr. Randy McDonald

Organic Chemicals Group

Emission Standards Division (MD-I3)

U.S. Environmcntal Protection Agency

Rescarch Tri.mgle I'ark, NC 27111

Dear Randy:

'1l1C Chcmical Manufactures Association (CMA) has worked with thc EnvironlJlcntal Protection

Agcncy (EPA) ovcr thc past year to provide data as it relates to continuous, batch and fonnulation chemical

manufacturing processcs to support the devclopment ofthe Miscellaneous Organic NESIIAP (MaN). '111e

purpose ofthis correspondcnce is to provide EPA with additional information for consideration in the

development ofthe MON. CMA is a nonprofit trade association whose member companies represent more

than 90 percent of the productive capacity of basic industrial chemic.ds in thc United States.

Our member companies have worked cxtensively ovcr thc lust four years to implement the

Hazardous Organic NESIIAP (HaN) Maximum Achievable Control Tcchnology (MACT) standard. Based

on this experience we bclieve there arc additional compliance options which, if provided for in the

wastewater and equipmcnt leak portions ofl-lON, would have allowed more cost-eflective achievement of

the environmental objectives ofthat rule.

While we believc those provisions of the HaN could be improved, EPA should also allow the

HaN as a compliance option for those facilities that become subject to the MON MACT standard. Many

CMA member facilitics will have both MaN and HaN processcs present at the same plant site. It is

prefcrable that compliance with thc HON be considered one ofthe options to comply with MaN

requirements in order to allow sourccs to avoid the rcgulatory burden associated with dcveloping two

separatc compliancc programs for a single site.

Our comments below focus on additional equipment leak and wastewater options that CMA

believes the Agcncy should consider (in addition to the HaN) as it develops the MaN MACT rule. CMA

urges thc Agency to consider these new options as it develops the MON.

Fugitive Emissions:

In recent years, many CMA member companies have performed fugitive emission monitoring on

equipment which had not previously been subject to leak dctcction and repair (LDAR) rcquirements. 11le

results ofthis monitoring indicatcs that equipmcnt leak rates are far Icss than EPA has typically estimated

in determining thc cost effectiveness ofthe equipment leak provisions of MACT standards.

CMA reccntly pollcd its Clean Air Task Group to gather infonnaliun on recent fugitivc emission

monitoring. Data cullected from the monitoring is summarized in the table below. 11lis data represents

initial monitoring results from over 250,000 componcnts in47 processes at facilities operated by 17 CMA

member companies. Regulatory drivers for the monitoring were the HaN and Polymers and Resins IV

MACT standards, Benzene NESHAP, New Source Pcrfonnance Standard (NSPS) VV, and various s~te

programs. These data are from a wide range of chemical and polymer proccsses, and can be expected to bc

representative of equipment leak rates at facilities which will be subject to the MON. For reference, the

initial leak rates from Table G-I, Determination of LDAR Control Effcctiveness at SOCMI Process Units,

from the EPA 1995 Protocol for Equipment Leak Emission Estimates are also shown in the table. These

values have onen been the basis for detennining the cost effectiveness of cquipment leak requiremcnts in

MACT. .
I

At the actual leak rates shown in the tablc, LOAR requirements based on the subpart H orthe

"ION would not be cost effective, as the emis.~i()n reductions would be quite small. In addition, the newly

obtained initial leak rates are "generally equivalent" to or lower than EPA has predicted in Table 0-1 of the

11)95 protocol documcnt for facilities after implementation of a leak detcction and repair program. 111e

liON and various statc programs should not be considered a higher level of control in floor determinations

until it can be demonstrated thal emissions are actually lower with such programs. We urge EPA to

consider other rcgulatory alternatives in developing the MON cquipmcntleak provisions.

Summary or Initial Equipmcnt Lcaks Monitoring Results

EPA Expected

LCllk Initial Expcctcd Cycle Avg.

Definition Fllcilitiesl Number Numbcr Lcak Initial Leak Ratc

COl1llJOncnt (ppm) Proccsses Monitored Leaking Rlllc Leak Ralcl aftcr LDAR1

Connectors 500 38 144,792 173 0.12% 3.9% 0.25%

Conncctors 10,000 5 19,912 168 0.84%

Pumps 500 2 121 0 0.00%

Pumps 1,000 4 683 13 I.lJooJi, 17.1% 4.02'Yo

Pumps 2,000 3 82 0 0.00%

Pumps 5,000 5 374 39 10.43%

Pumps 10,000 23 662 13 1.96% 7.5% 1.77%

Valves 500 17 62,299 312 0.50% 8.5% 0.79%

Valves 5,000 I 483 0 O,()O%

Valves 10,000 24 21,185 123 0.58% 4.3% 1.00%

Total 47 250,593 841 0.34%

Wastewatcr Provisions:

Regarding wastewater provisions for the MON, CMA believes the floor for continuous processes

is no control. However, if the Agency plans to develop a MACT standard based on cost-effectiveness,

CMA encourages the Agency to pursuc the approach of excluding from control requirements those streams

which have an inherently low emission potential. The proposed phannaceutical MACT, which provides a

higher concentration threshold exemption for streams with low vapor pressure and/or high water solubility

and does not require closed individual drain systems for POTWs treating soluble hazardous air pollutants

(HAP), is a good start in this direction. CMA looks forward to working with the Agency to further explore

the use of Henry's Law Constant and other factors as a mcans to rank wastewater streams so that emission

control programs are focused on streams where lhe most environmental benefit will be achieved.

CMA would like to schedule a meeting to specifically address the fugitive emission and

wastewater portions of the MON rulemaking. If you have

additional questions regarding the contents oflhis letter, please contact me al (703) 741-5249.

Sinccrely,

Rasma I. Zvancrs

Senior Manager

Environmental Policy

, From T'lblc (i-I, /995 Protocolfor Eqllipmetlt Leak Emissiotl /::'~tinrates (EPA-453/R-95-017)
Attachment 2

PET Weighted Average Emission Rates

0.0003 0.002303 0.0131 0.002303 0.000026

0.00018 0.00018 0.00018 0.00018 0.00018

0.00463 0.00463 0.00463 0.00463 0.00463

2434

75060

22207

1059

1047

Totals

170

11289

o

a:

4

35

121

1633

1336

248

56

o

280

112

3900

9647

OJ

1531

o

346

152

4543

20172

34 Of 2

I I I

808 Of 861

19 68 19

161 61 14!

447 1115! 447

2101 4177 2101

3873 0 470

0.00031 0.0023031 0.0003 0.0000261 0.002303 0.002303

I \ I

0.00463 0.00463 0,00483 0.004631 0.00463 0.00463

0.00365 0.0226851 0.00385 0.00143 0.022685 0.022685

0.00082\ 0.002661 0.000821 0.000131 0.00266 0.00265

0,00038 0.000923: 0.00038 0.000047 0.000923 0.000923

0.00018 0.000181 0.00018 0.00018 0.00018 0.00018

I

HC-! : ! He i I

TE - Sparanbur iE - CE, TPA·lsali~b~ry, HC·Greer,i

OMT.e 1 g,TPA-C I OMT,S C TPA-C TPA-C

0.000506 0.000506 0.0005061 0.0005061 0.000506 0.000506

148

S61

201

5111

29191

1894

14000

204

141

14

250

3112'

2273

70251

79

350

o

24

2213

5684

12851

37

15

o

695

146

493

3352

a

191

a

16

447

167

21011

0.000381 0.000923 0.000926 0.000923 0.000047

0.00385 0.022685 0.04269 0.022685 0.00143

0.00082 0.00266 0.000955: 0.00266 0.00013

I 1 I

• HC- ; ICI HC,

TE· (' Shefby,D IFayettevill Spartunbu' CE,OMT.

DMT,e MT-8 e,OMT-B rg.OMT.C C

0.000506 0.000506 0.00050S 0.000506 0.000506

0.00266

30!

3364

4311

116i

736i

3401

l 0.000923J

i 0.022685

! 0.002303

! 0.000506

I 0.000181

I I HC· .

ISpart,OM I'

I T.B

i 0.00463

I

Pumps, light liquid

Valves. heavy liquid

Conn/Flanges. glv or II

Valves. light liquid

Valves, heavy liquid

ConnfFlanges. heavy liquid

Counts

Pumps. heavy liquid

Valves. gas/vapor

Uncontrolled Emission Factors

(Ib/hrlcomponent)

Valves. light liquid

Valves, gas/vapor

Pumps, heavy liquid

Pumps. light liquid

Conn/Flanges. heavy liquid

Conn/Ranges. glv or II

Emissions (Ib/yr/process)

Valves, gaslvapor

Valves. light liquid

Valves. heavy liquid

Pumps. light liquid

Pumps, heavy liquid

Conn/Flanges. glv or II

Conn/Flanges. heavy liquid

0.9926i

0.3086[

0.37241

0.0907

0.1389

0,3138

0.6055·

0.0000

0.1369

0.2262

0.0616

0.0880

0,0000

0.37821

0.0852

0.3884

0,3517

0.0000

0.0695

0.4550

0.6034

0.0000

0.3343

1.1198

1.0246

0.3658

1,1899

1.0231

0.4698

0.6650

1.5747(

0.3176

0.6528

2.0980

1.2645

0.0018

0.0664

1.47701

0.02861

0.6852

0.0890

2.5200j

0.0048

0.6626

0.2262

0.1309

0.08S0·

1.4717

0.3782

0.01841

0.00001

0.56421

0.00001

0.3148i

0.0000

0.7519j

0.0042

0.07051

0.22621

0.0077

0.0880

0.1786

0.37821

0.0040

0.0000

2.2988

0.0000

0.7038

0.0163

3.6310

0.2579

0.0000

1.9734

1.27041

1.1482

0.2584

1.7365

0.0092

0.0000

0.8263

0.0000

0.5602

0.0323

0.2405

Weighted-Average

Emission Factors

(Iblhrlcomponent)

1.76E.Q3

1.0aE.Q3

S.06E·04

1.72E.(I2

4.63E.(l3

5.41E..04

1.80E.(J4

Weighted Average.xls

8/9/Qq

L L
(,

Attachment 3

Contractor Documentation

OfLabor for

Initial LDAR Program Setup
LOARSUM.xts

r- LDAR SUMMARY II

CREATE

DWG, TAGGED NON-TAGGED 1st 9E FiELD CATAFORMS HANG ISSUE TOTAL

AREA TYPEDWG, COUNT CWG.NO, ITEMS ITEMS WALK DRAFT VERIFY AND TAGS TAGS 9EDWG'S HOURS

I

I', PARA REV. DWGS. 1 234·9E·372 12 0 4 2 2 4 8 2 22:1

2 234·9E·373 5 0 2 2 2 2 2 21 12'

3 233B·9E·546 3 0 2 2 Z 2 2 2 d

I

AlEO REV. DWGS. 1 291·9E·121 11 0 4 2 2 4 8 2 221i

2 291·9E·122 3 0 2 2 2 2 2 21 12i;,I

Ii 60X REV. DWGS. 1 2338·9E·546 37 0 4 2 4 4 8 2 2411 I 2 2338·9E·547 63 0 6 2 6 4 10 2 3011

"

,. 2, 2

ii NEW DWGS. 1 2338·9E·591

(HaN) 4 0 2 2 2 2 2 2 12

2 233B·9E·591

(NSPS) 126 484 10 4 10 4 12 2 42

3 2338·9E·592 30 125 4 2 4 4 8 2 24,1

4 233B·9E·593 34 149 4 2 4 4 8 2 Z4',

5 233B·9E·594 58 218 6 3 6 4 10 2 31'1 I 6 233B·9E·595 86 401 6 3 6 4 12 2 33/

7 233B-9E·597 28 126 4 2 4 4 6 2 22

8 233B·9E·598 23 107 4 2 4 4 6 2 221 9 233B·9E·599 49 217 6 3 4 4 8 2 27

10 2338·9E-600 46 223 6 3 4 4 8 2 27 I 11 2338·9E-601 42 170 6 3 4 4 8 2 27 I 12 291·9E·131 90 391 6 3 6 4 12 2 33

I I i

i

;uc:lTAES'1! !IE 460'

3/11/99

l L

5,32 AM

L .'
, .- tL

Attachment 4

Eastman Comments

Unit Costs for Initial LDAR Program Setup

Minutes Per

Total Number of Task Per Cost@

Task Hours Components Component $37/hr

Walkdown &Field Verification 166 3361 3 $1.8

Create and Issue Drawings 86 3361 2 $0.9

Create Data Forms and Tags 68 750 5 $3.4

Hang Tags 140 750 11 $6.9

Unit Cost.xls

8/9/99