# !RECEIVED EASTIVIAN August 9, 1999
AIRBORNE EXPRESS 

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### Kingsport, Tennessee 37662

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### OAQPSAIR 

### DOCKET CONTROL ROOM

Air and Radiation Docketand Information Center(6102) Attn: DocketNo. A-92-45 U.s. Environmental Protection Agency 401 M StreetSW Washington, D.C. 20460 

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# - Er.'" ,s.lR DOC,<ET



### Subject:

Reference: Eastman Chemical Company Comments On U.S. Environmental Protection Agency's Proposed Denial ofPetition for Reconsideration

- Group IV Polymers and Resins Equipment Leak Provisions
64 Federal Register 30456; June 8, 1999
Dear SirorMadam:
Enclosed arc Eastman Chemical Company's (Eastman) comments on the abovereferenced Proposed Denial ofPetition for Reconsideration. Eastman's comments canbe swnmarized as follows:



# •

•

• Eastman has no objection to provisions from 40 CFR 63 Subpart Hreferenced by 40 CFR 63.1331 relating to compressors, sampling connections, pressure reliefdevices, 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, andconnectors in gas/vapororlight liquid service), thereby obscuring the true costeffectiveness ofthe latterprogram.
EPA's reanalysis ofthe cost-effectiveness ora Method 21 ba<:jed Leak Detection and Repair Program (LDAR) applied to equipment in gas/vaporor light liquid service still relies on use ofdefault SOCMI average emission factors for initial emission estimates for nearly 50% ofcovered 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 thatthe 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 ofemission 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



# ,

# 'i~ l1esponslblc Care€> A Public ConunilmCllt

### Eastman Comments 

### August 9. 1999 

### Page 2 

### costs ofsetting up the program forcomponents subjectto routine Method 21 monitoring.

• EPA should make the necessary adjustments to its cost-effectiveness analysis as outlined in these comments. When itdocs, EPA will find thatthe Method 21 program for components in gas/vaporand light liquid service is notcosteffective. In response to this finding, EPA should revise the regulations to extend the sensory basedprogram 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 KoSaon this proposed denial and is in full agreement with those comments. Ifthere are any questions concerning these comments or additional information is needed, please contacteitherofus at ourtelephone numbers shown below.

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

# (423)~27 

# atJ 11

# p~O.~ David A. Golden SeniorAttorney (423)229-8329

cc: Mr. Keith Barnett, EPA OAQPS

### Eastman Chemical Company Commcnts On 

# u.s. Environmental Protection Agency's Proposed Denial ofPetition for Reconsideration

- Group IV Polymcrs and Resins EquipmentLeak Provisions
64Federal Register 30456; June 8, 1999
nackground
On January 23, 1997, Eastman Chemic

..1Company (Eastman) and I-IoechstCelanese 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 at40 CFR 63.1331 which require the detection and repairofc<luipment leaks by affected sources manufacturing polyethylene tercphthalate (PEl).
EPA subsequently granted the stay, buton June 8, 1999 proposed in the Federal Register (64 FR 30456) to deny the petition for reconsideration and extended the stay until February 27, 200I.
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 forthe standard under section I12(d) ofthe Clean AirAct.
EPA claims ill the proposed denial that anerresponding to Petitioners' comments and adjusting their analysis, that no change in the standard is warranted:
"Based on the results oCthe new analysis, the EPA stilljudges the equipment leakprogram as promulgated to be cost-effective for PET facilities. TIlerefore, the EPA has determined that there is no need to remove the equipmentleakstandards from the promulgatedrule for Group IV Polymers and Resins and no need to modify any provisions within the equipment leakprogram of 40 CPR part63, subpart H." (64 PR 30462)
Eastman's Position
Eastman believes that EPA's conclusion is erroneous and the equipment leakprovisions relating to utilization ofMethod21 monitoring ofequipment in gas/vaporand light liquid service are not costeffective. Eastman has no objection to provisions from 40 CFR 63 Subpart Hreferenced by 40 CFR 63.1331 relating to compressors, sampling connections, pressure reliefdevices, 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 supportEastman'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 PETmanufacturers arc more representative ofPETprocesses 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 repairprogram is cost-effective. This is an extension ofthejustifieation for the Subpart H standards. However, the conclusion that this program is cost-effective hinges on the estimate ofthe uncontrolled (hereafterreferred to as "initial average leak rate") equipment leak emissions as well as estimates ofthe costs ofthe

### program. Lacking more representative data from the IJETsource category, EPA assumed the socalled "SOCMI" factors as the delimit initial average leakrates.
In promulgating the Polymers and Resins Group IV standards, EPA failed to considerany other data to supportcontinued use ofthe SOCMI factors. Now that the SOCMI industry has widespread experience and data from startup andoperation ofSubpart Hprograms underthe HON overthe last5 

### years, it 

### is clearthatthe SOCMI factors are grossly conservativeand that initial average leakrates are several times less than whatthose tactors indicate. EPA lIIade no effort to examine this datawhich is readily available in periodic reports submitted by HaN 

### sources across the nation. Subsequently, the Petitioners providedthis data from HaN 

### sources within theirrepresentative companies. Although EPA applied these company specific leak rate factors to the Petitioners' equipmentcountestimates in its reunalysis oflhe cost-effectiveness oftlte 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 thatthese leak frequency rates arc applicable to thepetitioners' PET facilities, because the monitoring and repairprogram in IJlace for the submitteddata atthe time of the reported initialmeasurcments may notreflectthe uncontrolled leak frequency from the PET facility. Two petitioners submilted infonnation on the equipment leak frequencies for a numberofnon-PET facilities. Upon request, they also provided datato supportthose reported leak frequencies. In reviewing the supportingdata, there appearto be a number ofinconsistencics, some ofwhich would affectthe estimated leak frequency. Forexample, 

### in the infonnution submittedby onepetitionerthese inconsistencies include: (I) 

### The numberofleakingcomponents reported 

### in the summarization tabledo ...) not match the monitoringresults in the auditreport; (2) 

### startdates do notmatch between the summari7.ation table and the audit report; (3) 

### total numberofcomponents in the summari7.ation table do not always match the numbertested in the audit report; and (4) 

### it is unclearwhat "net" readings referto and it is possible thatthis is an incorrect accounting ofleakers. In anotherpetitioner's data, concerns arc: (I) 

### thedata shects do not match thenumbers in the screeningresults table; and (2) 

### it is unclearwhat "adjusted" readings, which 

### arc presentedfor many ofthe process units and theirleaking components, referto and it is possible thatthis is an incorrect accounting ofleakers. Notwithstanding these technical uncertainties, the EPA has used thepetitioners' leak frequCl1cy rutes in the reanalysis." (64 

### FR 30458)


### Eastman acknowledges there were somc minordiscrepancies between the summary table and the audit report. Afterdiscussing the issue with the EPA contractor, Kenneth Meardon ofPacific Environmental Services, Eastman offers the following comments to address these concerns with the data: The audit report generatedby the LDARsoftware shows the number ofcomponents tested along with the numberof"pass/fail" and the numberofleakers. lne numberof"failures" docs notalways match the numberof"Ieakers". The software vendorhas informed Eastman that this particularreport may be prone to this type oferror. There were four cases where the summary table appeared to connictwith the auditreport for total numberofcomponents. In these cases, there was one numberofcomponents on the initial monitoring run and more in a laterfun. Since there were no leakers found in any ofthese runs, the largernumber was used in the summllrytable. The last issue raised by EPA questioned the usc of"net" readings in that it may result in an inaccurate countofleakers. The "net" reading is the difference between the maximum reading otT ofthe monitorand the background reading. "Net" readings were used to compare to the leak definition to detennine leakers forconnectors only. ntis is in accordance with Subpart H (40 

### CFR 

### 63.I80(c».



### Eastman Comments.doc 9-Aug-99 Page 2 01'8 

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### In orderto clearup any inconsistencies and to presentamore refincd analysis ofEastman's initial average leakrates for the HON facilities at its Tennessee and South Carolina sites, Eastman presents II 

### bettermethod to estimate its leakrotes. The leakrates estimated in the petition forthe Tennessee andCarolina Eastman sitc's were based on the fraction ofcomponenls exceeding the leakdefinition and use ofequations relating average leak rate to fraction leaking at SOCMI units (theseequations are found inTable 5-4 offrom EPA's Protocol for Equipment Emission Estimates (1995». 

### However, abettermethod ofestimating average leakratcs is to usc actual screcning valucs (in ppmv) and EPA's correlation equations found inTable2-9, 2-11 

### (DefaultZero Values), and 2-13 

### (Pegged Emission Rates) from EPA's Protocol for EquipmentEmission 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 rcfinementto estimating emissions from equipment leaks by providing an equation to predict mass emission rate as 

### a function ofscreening vallie for aparticularequipmenttype. 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 beused to estimate emissions for the cntirerangc ofnon-zero screening values, from the highest potential screening value to the scrcening value that represents the minimum detection limitofthe monitoringdevice. This approach involves entering the non-zero, non-pegged screening value into the correlation equation, which predicts the TOC mass emission rate basedon thc screening value. Defaultzero emission rates arc used for screening valucsofzero ppmv and peggedemission rates are used for "pegged" screening values (the screening value is beyond the upper limit measured by the portable screeningdevice)."
Eastman has been able to extractscreening values from its LDARdatamanagementsoftware into Excel spreadsheets and estimate average leakrates usingthe correlationequations. This method shouldrender any concerns aboutuse ofthepreviously submitted auditreport and determinations ofleak fractions moot. These spreadsheets arc attachedto the electronic c-mail submittal ofthese comments. 'nlerevised initial avcrage leakrates are shown below: Component Leak Rate Basedon 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 thatthe initial leakrates for the Petitioners' non-PET facilities arc 

### not applicable to PETfacilities "because the monitoring and repair program in place

Eastmnn Comments.doc 9-Aug-99 Page 3 or8

### for the submittcd data at the lime ofthereportcd initialmcasurcltlcnts may Hutrenccl the uncontrolled leak frequency from the PET facility." On thecontrary, 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 dataavailable to estimate initial leakrates 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 arerepresentative ofthe age ofthe PET f'lcilitics.

• Similarengineering and construction standards were used for both the lION and PET facilities.

• Similarmaintenance practices are employed.

• Piping in both liON and IJET facilities arc in similarchemical service (temperature and pressure).

• Much ofthe liON data is from piping in methanol service (methanol is the primary IIAP in gas/vaporand light liquid service in PET facilities).
Thesc argument,; cannotbe made for therepresentativeness ofthc SOCMI factors when applied to the PET facilities.
EPA makes anotherpoint in its describing its uncertain usc ofthe Petitioners' data:
"Whilc these two petitioners state that they currently have in place a program thatrepairs leaks through coordination with theirmaintenance staff, they do not provide any information documenting the effectiveness ofn sensory program relative to a monitoring program for components in gas/vapor orlight liquid service. But whatever their effectiveness, the EPA has used theirdata 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. operatorhousekeeping 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 repairofthe 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 equipmentcomponents 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 atboth the co-located HaN and PET facilities. TIlere is 110 

### basis for EPA makingthe negative assumption as opposedto the positive assumption that these leak rates are not representative ofthe effectiveness ofEastman'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 considerthese emission factors as representative ofthe rest ofthe 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 othercompany submitted data from which facility-specific leakfrequencies 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 ofothercompanies' facilities for several reasons: (I) 

### The othercompanies eitherhave notquestioned the EPA emission

E.1stman Comments.doc 9-Aug-99 Page 

### 4 of8

# /

estimates orhave concurred with Ihcm, (2) Ihe equipmcnt leak IJrogrdtns to control emissions employed bythe petilioners at their facilities may not represent programs practiced by olhercompanies, and 

### (3) several companies stated that they do nothave any equipment leakprograms," (64 FR30458)
EPA has chosen to make this decision based on lack ofinfomlation from the otheraffected companies in the PETsource category ratherthan recognizing the logic that the Petitioners' data is more representative ofthe PET source category than the SOCMI factors. EPA's statementthat othercompanies have not qucstioncd the SOCMI factors orhave concurrcd with them carries no weight in this argument. Ifthese companies have had no expcrience operating a Subpart H or equivalent program, they wouldhave no reason to question the SOCMI factors. 'lheirsilence 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 experiencedby 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 pipingcarrying orgunic chcmicals. EPA should investigate the possibility that the Petitioners' factors arc representative ratherthan maintaining the position that the Subpart

### Hprogram is cost-effective. Further, itis EPA's responsibility under the Clean 

### Air Act to ensure that MACTstandards above the Ooorarc indeed cost-effective.
To further supportthat 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 

### acomparison ofthe SOCMI leak rates to the weighted average leakrates for the CMA data set determined using the equations in Table 5-4 ofEPA'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 ofinitial average leak rates along with any othercompanies' estimates that arc based on actual initial Method 21 screenings to calculate weighted average initiaillveragc leakrates 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 leakrates. TIle spreadsheet file used for this calculation is attached (Attachment2). 

### IfEPA receives additional estimates from othercompanies, this spreadsheet shouldbe 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 peryeardue to the proposed LDAR program. However, 303 Mg peryeararc attributed to emission reductions from one-time modifications ofcompressors, samplingconnections, pressure reliefdevices, and open-ended lines, leaving409 Mg peryear allributed as the benefits ofthe Subpart 

### H Method 21 program for gas/vaporand light liquid service. Using the recommended PET Weighted Average Factors above (note these should be updated ifadditional data is obtaiiled from othercompanies) for 

### all facilities in EPA's database, Eastman estimates the reductions at only48 Mg peryear.
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 November24, 1998 memorandum "Summary ofResponses 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, contractortrip charges, andgeneral program supervision and coordination). However, EPA's cost algorithms still omit significantcosts incurred up-front to set up the LDAR program. EPA assigns a costof$4.65 percomponent as the initial monitoring fcc for components subject to Method 21 

### monitoring for processes with more than 500 componcnts (subcontractorrun 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 (orinitial setup and screening ofvalves 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 notprovide aseparate costcstimate for Item 3, creating/updating facility drawing to reflect individual components in the program. The Group IV rule does not require the creating orupdating ofa facility drawing. l11crefore, no costs were assigncd to this item in the revised costing."
This is not areasonable rationale to exclude these costs. While the rule docs not explicitly require drawings to be updated, itdocs require (I) 

### a list ofequipment identification numbers be recorded

Eastman Conullents.doc 9-Aug-?? Page 6 of8

# /

(with some provision for groups ofconnectors on a nll1 ofpipe) (40 CFR 63. I8 I(h» and (2) "each piece ofequipment in a process unilto which this subpart applies shall be identified such that it Cllll be distinguished readily from equipmentnot subjectto this subpart" (40 CFR 63. 162(c». In orderto comply with these provisions, Eastman has found it necessary to somewhere document the component" subjectto 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 LDARprogram. Proposed changes are approved through ManagementofChange orIhrough Capital ProjeCl"i. Both ofthesc require drawing updatcs. TIle requiremcnt to idcntify all LDARcomponents adds to the workload burden to maintain up-to-date drawings. P&IDs do not includc actualnumbcrs of connectors because this is eithershown on piping spool sheets or field detennincd during construction. These drawings mustbe verifiedwith 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 ofa 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 vendorquote that the quotes included "dalaentry". However, this has nol been Eastman's experience and believes this is not the correct interpretation. The $2.50 isjustthe charge to come out and screen a componentlll1d tag leakers. Initial selup ofthe program (field identification ofsubjeclcomponents, documentation on P&lDs, unique ID assignment, creating spreadsheet ofcomponent data, creation ofbarcodes, and tagging) is nomlally handled 

### as a separate charge. EPA uses $2.15 percompunentto cover locating, tagging, and documenting the components and claims the $2.05 charge found in Attachmenl F for "Locate andTag" covers all other initial set-up charges. Eastman believes this charge coversjust the material and laborcosts 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 notcovera 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 earlierby the Petitioners, Eastman has identified a recent project where we hired a contractor to selup a ncwly constOlcted process for a LDAR program. 111is particularprocess is subjectto 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 contrdctordocumenting the numberofhours spent on each task. Also shown in Altachment4 are calculations converting this data 10 minutes pertask 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 & gatherdata 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 HangTags Easlman Project

- I I $6.90 minutes per component Populate software Entercomponellt data into Eastman Estimate (2 $1.20 database.**mi~ute:"E:!..~ol11ponent)** 

## --_.
---- Eastman Comments.doc 9-Aug-99 Page 7 of8

# \

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

### orthe numberufcomponents and wheUlerornot 

### lheprog.r:mt is run by 

### a subcontractor, thc initial costs arc about 

### theSo.mc. In eithcrense,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. Ifthere is a diITerencc, it may 

### be more cosUy per component fut 

### aprocess with less than 500 componentsjust due

### to economy ofsCillc. ·OIUS. EPA's eslinmlcsloran 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 percompon{nbmjOitill.l

# sc~

Eastman Comments.doc 

### 9-l\ug·99 Page 8 or8

### { 

## Attachment 1
Letterfrom CMAto EPADocumenting

. CMAMemberCompany Survey Initial LeakRatesOctober 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 membercompanies represent more than 90 percentofthe productive capacity ofbasic industrial chemic.ds in thc United States.
Our member companies have worked cxtensively ovcr thc lust four years to implementthe Hazardous Organic NESIIAP (HaN) Maximum Achievable Control Tcchnology (MACT) standard. Based
on this experience we bclieve there arc additional compliance options which, ifprovided 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 ofthe HaN could be improved, EPA should also allow the HaN as a compliance option for those facilities that become subject to the MON MACTstandard. Many CMA member facilitics will have both MaN and HaN processcs present at the same plantsite. It is prefcrable that compliance with thc HON be considered one ofthe options to comply with MaN requirements in orderto 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 MACTrule. CMA urges thc Agency to considerthese new options as it develops the MON. Fugitive Emissions:
In recent years, many CMA membercompanies have performed fugitive emission monitoring on equipment which had not previously been subject to leakdctcction 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 ofMACTstandards.
CMA reccntly pollcd its Clean AirTask Group to gather infonnaliun on recent fugitivc emission monitoring. Data cullected from the monitoring is summarized in the table below. 11lisdata 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 ofchemical and polymerproccsses, and can be expected to bc representative ofequipment leak rates at facilities which will be subject to the MON. For reference, the initial leak rates from Table G-I, Determination ofLDAR 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 ofcquipment 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 ofthe 11)95 protocol documcnt for facilities after implementation ofa leak detcction and repair program. 111e liON and various statc programs should not

### be considered a higher level ofcontrol in floor determinations until it can be demonstrated thalemissions are actually lower with such programs. We urge EPA to consider otherrcgulatory alternatives in developing the MON cquipmcntleak provisions. Summary

# orInitial 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 wastewaterprovisions for the MON, CMA believes the floor for continuous processes is no control. However, ifthe Agency plans to develop a MACTstandard based on cost-effectiveness, CMA encourages the Agency to pursuc the approach ofexcluding 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 watersolubility and does not require closed individual drain systems for POTWs treatingsoluble hazardous airpollutants (HAP), is a good start in this direction. CMA looks forward to working with the Agency to furtherexplore the use ofHenry's Law Constant and other factors as a mcans to rank wastewaterstreams so thatemission control programs are focused on streams where lhe mostenvironmental benefit will be achieved.
CMA would like to schedule a meeting to specifically address the fugitive emission and wastewaterportions ofthe MON rulemaking. Ifyou have additional questions regarding the contents oflhis letter, please contact me al (703) 741-5249. Sinccrely,

Rasma I. Zvancrs SeniorManager Environmental Policy

, From T'lblc (i-I, /995 Protocol for 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·

. 

## I Spart,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. glvor 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

### (, 

# Attachment3
ContractorDocumentation
OfLaborfor
Initial LDARProgram SetupLOARSUM.xts


# r- LDARSUMMARY 

### II CREATE DWG, TAGGED NON-TAGGED 1st 9E FiELD CATAFORMS HANG ISSUE TOTAL AREA TYPEDWG, COUNT CWG.NO, ITEMS ITEMS WALK DRAFT VERIFY ANDTAGS 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 6 3 8 2 27 42 170 4 4

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 Numberof 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