# E C



# / R Incorporated Providing Environmental Technical Support Since 1989

501 Eastowne Dr., Suite 250  Chapel Hill, North Carolina 27514 Telephone: (919) 484

- 0222  Fax: (919) 484

- 0122 

### MEMORANDUM

Date: November 7 , 2011

Subject: Impacts of Control Options to Address Residual Risks for the Pesticide Active Ingredient, Polyether Polyols, and Polymers and Resins IV Production Source Categories

From: Lesley Stobert, EC/R Incorporated

To: Paula Hirtz, EPA/OAQPS/SPPD Nick Parsons, EPA/OAQPS/SPPD

______________________________________________________________________________

The purpose of this memorandum is to pre sent the estimated impacts of control options identified to reduce hazardous air pollutant (HAP) emissions and risks from seven source categories that are subject to the Pesticide Active Ingredient (PAI) , Polyether Polyols (PEPO)

, and Group IV Polymers and Resins Production National Emissions Standards for Hazardous Air Pollutants ( NESHAP )

– 40 CRF 63, subparts MMM, PPP, and JJJ, respectively. These source categories are Pesticide Active Ingredient Production, Polyether Polyols Production, Acrylic

Butadiene

- Styrene (ABS) Production, Methyl Methacrylate

- Butadiene

- Styrene (MBS)

Production

, Polyethylene Terephthalate (PET) Production

, Polystyrene Production , and Styrene

Acrylonitrile (SAN) Production . The control options are being evaluated un der EPA’s Risk and Technology Review program, which is addressing statutory requirements under section 112(f)(2 ) of the Clean Air Act. Section 1 provides background information, followed by a summary of the risk results for these source categories in Secti on 2. Section 3 summarizes th e estimated impacts of the 112(f

)(2) option s.

1.0 BACKGROUND

Section 112 of the Clean Air Act (CAA) establishes a comprehensive regulatory process to address emissions of hazardous air pollutants (HAP) from stationary so urces. In accordance with CAA section 112(c), EPA identifies categories and subcategories of major sources that emit one or more of the HAP listed in CAA section 112(b). CAA section 112(d) (2) then calls for EPA to promulgate national technology

- based emi ssion standards for each listed cate gory or subcategory of sources. For “major sources” that emit or have the potential to emit any single HAP at a rate of 10 tons or more per year or any combination of HAP at a rate of 25 tons or more per year, these tec hnology

- based standards must reflect the maximum reductions of HAP achievable (after considering cost, energy requirements, and non

- air health and environmental impacts) and are commonly referred to as maximum achievable contro l technology (MACT)

standards. S ection 112(d)(6) then requires EPA to review the CAA section 112(d) technology

based standards and to revise them “as necessary, taking into account developments in practices, processes, and control technologies,” no less frequently t han every 8 years. The residual risk review is described in section 112(f) of the CAA. CAA section 112(f)(2) requires EPA to promulgate standards for each category or subcategory of CAA section 112(d) sources “if

### 2

promulgation of such standards is required in orde r to provide an ample margin of safety to protect public health . . . or to prevent, taking into consideration costs, energy, safety, and other relevant factors, an adverse environmental effect

.

The Group IV Polymers and Resins NESHAP (40 CFR 63, subpart JJJ) regulates HAP

emissions from seven source categories. In the current action, EPA is addressing five of the

seven Group IV Polymers and Resins source categories

– ABS Production, MBS Production

, PET Production

, Polystyrene Production , and S AN Production

. T he other two source categories, Methyl Methacrylate

- Acrylonitri le

- Butadiene

- Styrene Production and Nitrile Resins Production

, are not addressed because t here are no longer any operating facilities and none are anticipated to begin operation in the future. S ources of HAP emissions from the Group IV Polymers and

Resins source categories investigated in the RTR include storage vessels, process vents, wastewater operations, heat exchange systems, equipment leaks , and for some PET facilities,

process contact co oling towers

. T he emission sources regulated by the NESHAP are storage tanks, process vents, equipment leaks, wastewater operations , and heat exchange systems

. For one subcategory of PET, equipment leaks are not currently regulated by the NESHAP. In

addi tion, process contact cooling towers are currently not regulated sources of HAP emissions.

The PAI and the PEPO NESHAP (40 CFR 63, subparts MMM and PPP) regulate HAP emissions from the PAI and PEPO source categories. Sources of HAP emissions from these source categories i nclude storage vessels, process vents, wastewater operations, heat exchange systems, and equipment leaks . The PAI source category also has HAP emissions from bag dumps and product dryers. All of these HAP emissions sources are regulated by the PAI and the

PEPO NESHAP.

2.0 SUMMARY OF RISKS

The EPA performed an assessment of the residual risks from the Group IV Polymers and Resins, PAI, and PEPO source categories in order to determine whether additional regulation

would be ne cessary under CAA section 112(f). 1 

### The data used for this assessment was the 2005 NEI, which was updated based on reviews of the data by the American Chemistry Council (ACC)

, the Society of Chemical Manufacturers and Affiliates (SOCMA) and the EPA. Table 1 contains a summary of the results of this assessment.

Table 2 summarizes the contribution of emission point types to the maximum source

category risks , and Attachment 1 provides more detail of these contributions . While it was generally not possible to discern from the NEI data the exact type of each emission point , it was possible to distinguish whether an emissions point was a fugitive or a point source. In most cases, it was assumed that fugitive emissions were attributed to equipment leaks. It should also be noted that the assessment of residual risks accounted for all emissions at the facilities, regardless of whether the NESHAP currently regulate the sources of these emissions. Also, because the MBS and the SAN source categories were shown to be “low risk,” the emission point contributions to the risks were not investigated for these source categories . In addition,

1 U.S. EPA, Office of Air Quality Planning and Standards. Draft Residual Risk Assessment for 7 Source Categories. September 2011.

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because noncancer risks are “low” for each source category investigated, the emission point

contributions to these noncancer risks were not investigated.

Table 1. Summary of Estimated Inhalation Risks for the PAI, P EPO , and Group IV Polymers and Resins Production Source Categories Based On Actual Emissions Levels

Source Category Maximum individual cancer risk (in a million) 1 Maximum chronic

noncancer TOSHI 2

Pesticide Active Ingredient (PAI) Production 7 0.7

Polyether Polyols (PEPO) Production 30 0.8

Polymers and Resins IV 3

Acrylic

- Butadiene

- Styrene (ABS) Production 30 0.2

Methyl Methacrylate

- Butadiene

- Styrene (MBS) Production 0.4 0.007

Polyethylene Terephthalate (PET) Production 9 0.5

Polystyrene Production 2 0.004

Styrene

- Acrylonitrile (SAN) Production 0.03 0.0002

1 Maximum individual excess lifetime cancer risk.

2 Maximum target organ specific hazard index (TOSHI). Target organ system represented by the TOSHI varies across source categories. Maximum TOSHI is based on respiratory effects for the PAI, PEPO, SAN, and P ET source categories and neurological effects for polystyrene production, and reproductive effects for MBS and ABS.

3 Risks were not estimated for the Methyl Methacrylate

- Acrylonitrile

- Butadiene

- Styrene Production or the Nitrile

Resins Production source c ategories.

### 4 Table 2. Contribution of Emission Point Types to Risks

Source Category Percentage Contribution to

Maximum Cancer Risks from Point

Sources Percentage Contribution to Maximum Cancer Risks from Fugitive Sources

Pesticide Active Ingredient (PAI) Production 0% 100%

Polyether Polyols (PEPO)

Production 53% 47%

Polymers and Resins IV

Acrylic

- Butadiene

- Styrene (ABS) Production 100% 0%

Polyethylene Terephthalate (PET)

Production 0% 100%

Polystyrene Production 0% 100%



### 3.0 IMPACTS OF RISK REDUCTION OPTIONS

One risk reduction option was identified for each of the source categories, which is the use of leakless valves. The risk reduction impacts of requiring leakless valves were evaluated in three steps. First, an estimate was obtained of the emissions from valves. The data set used for the RTR risk assessment did not have emissions broken down by type. However, we assumed that all the fugitive emissions were equipment leaks. Using information from the development

of the MACT standards, we determined a percentage of equipment leaks that were attributed to valves. Applying this percentage to the fugitive emissions for a source category, we determined

the emissions that could be attributed to valves. It was assumed that le akless valves would achieve a 100 percent reduction in emissions.

In the evaluation of risk reduction options for the Hazardous Organic NESHAP (HON), the EPA estimated the costs of requiring leakless valves. 2 

### The capital and annual cost per ton of

basel ine emissions from valves was calculated and applied to these source categories to obtain estimated cost impacts. These values were just under $1.8 million capital cost per ton of valve emissions and around $240,000 per year per ton of valve emissions.

The risk reductions were estimated by assuming that the risk from the valve emissions was proportional to the fraction of mass emissions. For instance, if emissions from valves made up 10 percent of the total equipment leak emissions for a source category, it was assumed that 10 percent of the fugitive emissions were due to valves. If the maximum cancer risk due to fugitive emissions was 10, then it was assumed that 10 percent of that risk, or 1

- in

- 1 million, was due to

2 National Emission Standards for Hazardous Air Pollutants for Organic Hazardous Air Pollutants from the Synthetic Organic Chemical Manufacturing Industry: Proposed Rule. 71 FR 34422. June 14, 2006.

### 5

valves. If leakl ess valves were installed and these valve emissions were eliminated

, the

maximum cancer risk would then be estimated to be 9

- in

- 1 million. Table 3 shows the impacts of requiring leakless valves. Attachment 2 shows more detail of these estimates.6 

### Table 3. Estimated Impacts of Leakless Valves

Source Category Baseline

Emissions (TPY) Emission

Reduction (TPY) Capital

Costs (million $) Annual

Costs (million $) Cost Effectiveness

($/TPY reduced) Baseline Max

Cancer Risk Max Cancer Risk

With Leakless

Valves In Place

Pesticide Active Ingredient (PAI)

Production 34 8 101 1 8 0.6 2 4.7 24 4 ,000 7 3

Polyether Polyols (PEPO)

Production 438 59 104 .3 14 .3 244 ,000 30 20

Polymers and Resins IV

Acrylic

- Butadiene

Styrene (ABS)

Production 206 6 1 1.3 1 .5 244 ,000 30 30

Polyethylene Terephthalate (PET)

Production 1,181 123 219.8 30. 1 244,000 9 7

Polystyrene Production 91 5 9.2 1.3 244 ,000 2 2A

- 1



### A TTACHMENT 1 : Equipment Leak Contributions To Cancer Risk sA

- 2A

- 3A

- 4



### A TTACHMENT 2 : Equipment Leaks Impacts Assessment

Table A

- 1. Baseline Emissions *

Source Category MACT Baseline Equipment Leaks Emissions (TPY)

% Valves Total Valves Other

Polyether Polyols a 1,790 654 1,136 36.5%

PAI e,f 3,410 NA NA 53.0%

P&R IV

PET b,c 6,019 222.2 843.5 20.9%

ABS d 398 NA NA 20.9%

Polystrene d 1,356 NA NA 20.9%

* References:

a Memorandum. Summary of Nationwide Baseline Emissions for Polyether Polyols Production Facilities. Seaman, J., EC/R, to Svendsgaard, D., EPA/OAQPS/ESD/OCG. Table 6. April 29, 1996. Contained in Hazardous Air Pollutant Emissions from the Produ ction of Polyether Polyols

-- Supplementary Information Document for Proposed Standards . EPA

- 453/R

- 97

- 010c. May 1997.

b Total emissions from memorandum. Baseline Emissions Estimates for the Group IV Thermoplastics. King, B., PES, to Group IV Re sins

Doket No. A

- 92

- 45. Table 2. March 24, 1995. Contained in Hazardous Air Pollutant Emissions from Process Units in the Thermoplastics
Manufacturing Industry

-- Supplementary Information Document for Proposed Standards. EPA

- 453/R

- 95

- 003a. March 1995.

c Valves , other and % valves based on data from file PET equipment leak summary data.xlsx

d Emissions data per component not available, assumed same % valves as that of PET.

e Percentage values from memorandum. Environmental Impacts for the Pesticide Active Ingredient Production NESHAP. Randall D. and Karen Schmidke, MRI, to Banker, L., EPA/ESD/OCG. Attachment 2. April 30, 1997. Contained in Hazardous Air Pollutant Emissio ns from

the Pe sticide Active Ingredient Production Industry

-- Supplementary Information Document for Proposed Standards. July 1997.

f Total emissions from memorandum. Baseline Emissions for the Pesticide Active Ingredient Production Industry

-- Pesticide Active Ingredient Production NESHAP. Randall D., Karen Schmidke, and Charlie Hale, MRI, to Banker, L., EPA/ESD/OCG. Table 3. April 30,

199 7. Contained in Hazardous Air Pollutant Emissions from the Pesticide Active Ingredient Production Industry

-- Supplementary
Information Document for Proposed Standards. July 1997.

Costs of Leakless Valves * Cost/ton

Total Capital Cost $5,700,000,000 $1,781,250

Total Annual Cost $780,000,000 $243,750

VOC Emission Reduction (tpy) 3,200

Assumption: All organic HAP are VOC so VOC cost effectiveness = HAP cost effectiveness

* Reference:

National Emission Standards for Hazardous Air Pollutants for Organic Hazardous Air Pollutants From the Synthetic Organic Chemical
Manufacturing Industry: Proposed Rule. 71 FR 34422, June 14, 2006A

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Table A

- 2. HAP Reductions and Costs from Use of Leakless Valves

Table A

- 3. C ancer Risk Reductions from Use of Leakless Valves