DRAFT



### 1 MEMORANDUM

DATE: December 5, 2013

SUBJECT: Technology Review and Estimated Cost Impacts for the Polycarbonate Production

Source Category

FROM: Nick Parsons, EPA/OAQPS/SPPD/RCG

TO: EPA Docket File (EPA

- HQ

- OAR -2012-0133)



## 1.0 INTRODUCTION

Section 112 of the Clean Air Act (CAA) requires the U.S. Environmental Protection Agency (EPA) to

establish technology- based standards for listed source categories as national emissions sta ndards for

hazardous air pollutants (NESHAP). These technology- based standards are often referred to as

maximum achievable control technology (MACT) standards. The Polycarbonate Production (PC)

MACT standards (promulgated under the Generic MACT standards at 40 CFR part 63, subpart YY)

apply to major sources of hazardous air pollutant (HAP) emissions at existing and new facilities engaged

in the production of a special class of polyester formed from any dihydroxy compound and any

carbonate diester or by ester exchange. The NESHAP requires the use of MACT to reduce HAP

emissions from storage vessels, equipment leaks, process vents from continuous unit operations and

combined vent streams, and wastewater.

Section 112 also contains provisions requiring the EPA to periodically revisit these standards.

Specifically, section 112(d)(6) states:

(6) REVIEW AND REVISION.

– The Administrator shall review, and revise as necessary

(taking into account developments in practices, processes, and control technologies), emissions

standards promulgated under this section no less often than every 8 years.

To comply with this CAA requirement, the EPA conducted a technology review for the PC MACT

standards for major sources. For the purposes of reviewing a MACT standard, the EPA considers a

“development” in practices, processes, and control technologies to be:

• 

### Any add -on control technology or other equipment that was not identified and considered during

development of the original MACT standards.

• 

### Any improvements in add -on control technology or other equipment (that were identified and

considered during development of the original MACT standards) that could result in additional

emissions reduction.

• 

### Any work practice or operational procedure that was not identified or considered during

development of the original MACT standards.DRAFT



### 2 • 

### Any process change or pollution prevention alternative that could be broadly applied to the

industry and that was not identified or considered during development of the original MACT

standards.

• 

### Any sign ificant changes in the cost (including cost effectiveness) of applying controls (including

controls the EPA considered during the development of the original MACT standards).

Section 2 of this memorandum presents background information about the PC source category. Section

3 presents a summary of the sources of data that were used to conduct the technology review. Section 4

presents estimated cost impacts for identified developments in practices, processes, and control

technologies.

2.0 BACKGROUND FOR THE POLYCARBONATE PRODUCTION SOURCE

CATEGORY

On October 14, 1998, the EPA proposed NESHAP for the Generic MACT (GMACT) standards. The

proposed rule included NESHAP for four small source categories, including polycarbonate(s)

production. The EPA promulgated the final GMACT standards on June 29, 1999, and withdrew the

proposed wastewater provisions of the GMACT in a supplemental notice. After receiving and reviewing

comments, the EPA promulgated the final process wastewater provisions for the PC source categor y on

November 22, 1999.

The PC MACT standards regulate HAP emissions from PC process units at major sources. The PC

source category includes the production of a special class of polyester formed from any dihydroxy

compound and any carbonate diester or by ester exchange. Polycarbonate is a thermoplastic polymer

typically produced by the reaction of bisphenol-A (BPA) with phosgene, in the presence of pyridine or

other catalyst. The most common process used in the manufacture of PC is interfacial polymerization,

with methylene chloride used as a solvent in the polymerization reaction. Polycarbonate is a good

electrical insulator with excellent optical clarity and high heat and impact resistance, making it useful in

a variety of applications including optical media, electrical components, and automotive applications.

Sources of HAP emissions regulated by the PC MACT standards include: storage vessels, equipment

leaks, process vents, and wastewater.

The PC MACT standards include a combination of equipment standards, work practice standards,

operational standards and performance standards for each of the emission sources noted above. The PC

MACT standards reference numerous other 40 CFR part 63 MACT standards for requirements relating

to specific sources of emissi ons including:

• Subpart F (for maintenance wastewater requirements),

• Subpart G (for process wastewater requirements),

• Subpart SS (for closed vent systems, control devices, recovery devices, and routing emissions to

a fuel gas system or a process),

• Subparts TT and UU (for equipment leaks), and

• Subpart WW (for storage vessels).

Various other practices, processes, and control technologies were considered in the development of the

PC MACT standards and in the referenced standards listed above , which are summarized in Table 1.DRAFT



### 3 Table 1. Summary of Practices, Processes, and Control Technologies Identified and Considered

During Polycarbonate Production MACT Standards Development

Emission Source Practices, Processes, and Control Technologies

Storage Vessel s Fixed roof, internal floating roof, external floating roof, closed vent

system and control device, vapor recovery system, route emissions to

a fuel gas system or a process

Process Vents Combustion devices, recovery devices, scrubbers/absorbers

Equipment Leaks Leak detection and repair (LDAR) program, specific equipment

modifications

Wastewater Steam stripping, biological treatment, recycling the wastewater

stream

Combustion and

Recovery Devices/

Technologies Flares, absorbers/scrubbers, carbon adsorbers, condensers,

incinerators (thermal, catalytic), boilers, process heaters

Four facilities in the U.S. produce PC and are subject to the PC MACT standards. These facilities

include:

• Sabic Resins – Burkville, AL

• Sabic Resins – Mount Vernon, IN

• Bayer MaterialScience – Baytown, TX

• The Dow Chemical Company – Freeport, TX.

3.0 SOURCES OF AVAILABLE CONTROL TECHNOLOGY INFORMATION

To identify developments in practices, processes and control technologies since the MACT standards

were develo ped, the following sources of data were consulted:

• The EPA’s RACT/BACT/LAER clearinghouse

• Review of subsequent regulatory development efforts

3.1 RACT/BACT/LAER Clearinghouse Database

Under the EPA's New Source Review (NSR) program, if a company is planning to build a new plant or

modify an existing plant such that criteria air pollution emissions will increase by a certain amount, then

the company must obtain an NSR permit. The NSR per mit is a construction permit which generally

requires the company to minimize air pollution emissions by changing the process to prevent air

pollution and/or installing air pollution control equipment.

The terms “RACT,” “BACT,” and “LAER” are acronyms fo r different program requirements relevant to

the NSR program. RACT, or Reasonably Available Control Technology, is required on sources in areas

that are not meeting national ambient air quality standards (non

- attainment areas). BACT, or Best

Available Control Technology, is required on new or modified major sources in clean areas (attainmentDRAFT



### 4 areas). LAER, or Lowest Achievable Emission Rate, is required on new or modified major sources in

non- attainment areas.

BACT and LAER (and sometimes RACT) are determi ned on a case- by

- case basis, usually by State or

local permitting agencies. The EPA established the RACT/BACT/LAER Clearinghouse, or RBLC, to

provide a central data base of air pollution technology information (including past BACT and LAER

decisions contained in NSR permits) to promote the sharing of information among permitting agencies

and to aid in future case- by -case determinations. However, data in the RBLC are not limited to sources

subject to RACT, BACT, and LAER requirements. Noteworthy prevention and control technology

decisions and information may be included even if they are not related to past RACT, BACT, or LAER

decisions. 1



### The RBLC contains over 5,000 air pollution control permit determinations that can help identify

appropriate technologies t o mitigate most air pollutant emission streams. It was designed to help permit

applicants and reviewers make pollution prevention and control technology decisions for stationary air

pollution sources, and includes data submitted by several U.S. territories and all 50 States on over 200

different air pollutants and 1,000 industrial processes.

The RBLC provides several options for searching the permit database on- line to locate applicable

control technologies. Our search of the RBLC specified the Polycarbonate Production subcategory under

the Chemicals Manufacturing category, with permits dating back to 1999. The search results included

the following data fields:

• RBLC ID;

• Facility Name, and State;

• Permit Date;

• Process name;

• Throughput;

• Pollutant;

• Control technology; and

• Percent efficiency of control.

The results of the search, which identified one facility, are presented in Attachment 1 for the PC source

category. The facility identified did not have more stringent requirements than the PC MACT standards.

The practices, processes, and control technologies shown in Attachment 1 are all examples of the types

of emission reduction techniques that were considered in the development of the PC MACT standards.

Therefore, this exercise did not reveal any developments in emissions reduction practices, processes or

control technologies.

3.2 Subsequent Regulatory Development Efforts

The PC MACT standards were promulgated in 1999. Since that time, the EPA has developed air toxics

regulations for a number of additional source categories that emit organic HAP from the same type of

emission sources that are present in the PC source category. In subsequent air toxic regulatory actions,

the EPA consistently evaluate d any new practices, processes, and control technologies. A review of

these subsequent air toxics regulations, including supporting documentation used in the rulemakings was

1 Technology Transfer Network: Clean Air Technology Center. RACT/BACT/LAER Clearinghouse Basic Information.

http://www.epa.gov/ttn/catc/rblc/htm/welcome_eg.html

.DRAFT



### 5 conducted to determine if any practices, processes or control technologies could be applied to the PC

source category.

The technology review analyses for the National Uniform Emission Standards for Storage Vessels and

Transfer Operations, Equipment Leaks and Control Devices (“Uniform Standards”) were considered in

this review. Although these analyses are not based directly on operations in the PC source category, they

are based on representative chemical manufacturing processes and refinery processes with similar types

of equipment and emissions sources. Thus, it is expected that emissions control and compliance

demonstration methods that have been determined to be cost effective for a model chemical

manufacturing facility in the Uniform Standards analyses could potentially be cost effective for the same

regulated material at similar emission points in the PC source category. Potential developments in

practices to control emissions from equipment leaks were identified through the review of the National

Uniform Emission Standards for Storage Vessels and Transfer Operations, Equipment Leaks and

Control Devices, which is discussed further in Section 4.

Other MACT standards were examined for practices, processes or control technologies could be applied

to the PC source category. This exercise did not reveal any practices, processes , or control technologies

that could be applied to the PC source category. The results of this analysis are presented in

Attachment 2.

4.0 IDENTIFIED DEVELOPMENTS IN PRACTICES, PROCESSES, AND CONTROL

TECHNOLOGIES AND ESTIMATED COST IMPACTS

For storage vessels, process vents and wastewater, beyond what is currently required in the rule or is

being proposed in this action, we did not identify: a ny add -on control technology or other equipment

that was not identified and considered during MACT development; any improvements in add-on control

technology or other equipment (that was identified and considered during MACT development) that

could result in significant additional HAP emission reduction; any work practice or operational

procedure that was not identified and considered during MACT development; any process change or

pollution prevention alternative that could be broadly applied that was not identified and considered

during MACT development; or any significant changes in the cost (including c ost effectiveness) of

applying controls (including controls the EPA considered during MACT development). The identified

developments in practices for equipment leaks emissions control are discussed below.

4.1 Equipment Leaks

Equipment leaks are emissions emanating from pumps, compressors, agitators, pressure relief devices

(PRD), sampling connection systems, open-ended valves or lines (OEL), valves, connectors, and

instrumentation systems. The amount of HAP emissions from equipment leaks is proportional to the

type and number of equipment components and the concentration of HAP constituents of the stream

passing through the components.

4.1.1 Summary of Existing MACT Level of Control

The PC MACT standards for equipment leaks apply to the group of all equipment that contains or

contacts material that is 5 percent by weight or more of organic HAP and operates 300 hours per year or

more. Each piece of equipment subject to the PC MACT standards for equipment leaks is required to

comply with the specific LDAR provisions of 40 CFR part 63, subpart TT or subpart UU. A summary of

the leak detection provisions of 40 CFR part 63, subpart TT and UU are shown in Table 2. The repairDRAFT



### 6 requirements for both standards are to complete repair generally within 15 days of the detection of a

leak, and both standards contain similar recordkeeping and reporting requirements.

Table 2. Summary of Subparts TT and UU Equipment Leak Detection Requirements

Equipment Type 40 CFR part 63

Subpart TT 40 CFR part 63

Subpart UU

Valves in gas and vapor and in

and light liquid service Conduct monthly EPA Method 21 monitoring

Leak definition of 10,000 ppm Leak definition of 500 ppm

Pumps in light liquid service Conduct monthly EPA Method 21 monitoring

Leak definition of 10,000 ppm Leak definition of 1,000 ppm

(repair required at 2,000 ppm)

Connectors in gas and vapor

and in and light liquid service Sensory monitoring Conduct annual EPA Method

21 monitoring, leak definition

of 500 ppm

Agitators in gas and vapor and

in and light liquid service Conduct monthly EPA Method 21 monitoring, leak definition

of 10,000 ppm

Pumps, valves, connectors,

and agitators in heavy liquid

service; pressure relief devices

in liquid service; and

instrumentation systems Sensory monitoring

Pressure relieve devices in

gas/vapor service Operate with no detectable emissions (i.e., less than 500 ppm)

or equipped with a rupture disk / or routed to an air pollution

control device

Open ended lines Equip with a cap or comparable device

4.1.2 Developments in Technology for Equipment Leaks

The practices, process and control technologies considered during MACT development for equipment

leaks at PC facilities included LDAR and equipment modification or replacement. As part of the

Uniform Standards development, in 2011, the EPA conducted a general review and analysis of

emissions reduction techniques for equipment leaks that have been put in place at chemical production

facilities and refineries. 2 

### According to this analysis, compared with what was considered du ring MACT

development for the PC source category, no entirely new developments in methods for controlling

equipment leak emissions were found. However, LDAR programs incorporating more stringent leak

detection limits were noted to exist. In this analysis, the impacts of requiring certain leak definitions,

comparable to the leak definitions contained in 40 CFR part 60, subpart VVa and the Bay Area Air

Quality Management District (BAAQMD) of California Regulation 8, Rule 18 were investigated. The

leak defini tions of 40 CFR part 60, subpart VVa for valves in gas and vapor and in and light liquid

service (500 parts per million (ppm)), pumps in light liquid service (1,000 ppm) and connectors in gas

and vapor and in and light liquid service (500 ppm) are the same as those required by 40 CFR part 63

subpart UU. Consequently, we investigated the leak definition requirements of 40 CFR part 60, subpart

2 Memorandum from Hancy, C ., RTI International, to Howard, J., EPA/OAQPS. Analysis of Emission Reduction Techniques

for Equipment Leaks. December 21, 2011. EPA Docket No. EPA

- HQ

- OAR

- 2010

- 0869

- 0029.DRAFT



### 7 VVa or 40 CFR part 63, subpart UU in the technology review analysis to determine whether the leak

definitions of these programs, as applied to the PC source category, would be cost effective. As it is

possible that it may be cost effective to monitor only certain components at certain levels, the analysis

included independent calculations of the cost effectiveness of monitoring each component at the

alternative levels. Also, as instrument monitoring of connectors can be an expensive component to an

LDAR program, the costs of an LDAR program with the more stringent leak definitions were considered

both without instrument connector monitoring (Option 1) and with instrument connector monitoring

(Option 2). This investigation was performed under consideration of whether there have been “Any

significant changes in the cost (including cost effectiveness) of applying controls (including controls the

EPA considered during the development of the original MACT standards).”

Table 3 presents a summary of the equipment leak options that were analyzed. This table only shows

pumps, valves and connectors in gas and vapor and light liqu id service, since the requirements for the

other types of equipment are largely the same under 40 CFR part 63, subparts TT and UU, as shown in

Table 2. As a result, those equipment types were not further analyzed in this comparison of emissions

reductions and costs for Options 1 and 2.

Table 3. Summary of Equipment Leak Options for the PC Source Category

Type of

Equipment Subpart TT

(Baseline) Alternative Options

Subpart UU

w/o connectors

(Option 1) Subpart UU

w/connectors

(Option 2)

Pumps in light

liquid service Monthly Method 21

monitoring;

leak definition of

10,000 ppm Monthly Method 21

monitoring; leak definition of

1,000 ppm

(repair at 2,000 ppm) Monthly Method 21

monitoring; leak definition of

1,000 ppm

(repair at 2,000 ppm)

Valves in gas

and vapor and

in and light

liquid service Monthly Method 21

monitoring;

leak definition of

10,000 ppm Monthly Method 21

monitoring;

leak definition of 500 ppm Monthly Method 21

monitoring;

leak definition of 500 ppm

Connectors in

gas and vapor

and in and

light liquid

service Sensory

Monitoring Sensory

Monitoring Method 21 monitoring; leak

definition of 500 ppm

4.1.3 Alternative Means of Compliance by Component Type and for Entire LDAR Program

An analysis of the emissions reductions and costs of the options identified for equipment leaks was

performed. For the PC source category, no information was readily available regarding equipment leak

emissions by specific type of potentially leaking equip ment (component) or of the number of these

components present at PC facilities. As a result, it was assumed that the PC source category could be

best represented by one or more the model plants developed for the chemical industry in the UniformDRAFT



### 8 Standards a nalysis. 3 

### It was further assumed that of these model chemical manufacturing plants, the

“Simple” model plant would be most representative of the PC source category. Table 4 presents the

model plant component counts for chemical manufacturing facilities dev eloped during the EPA’s 2011

review of equipment leak reduction techniques for the Uniform Standards.

Table 4. Model Plants Equipment Component Counts for

Chemical Manufacturing Facilities 3



### Equipment Component Number of Components

Simple

Model Plant Medium

Model Plant Complex

Model Plant

Pumps (light liquid service) 15 40 56

Valves (gas/vapor service) 77 414 1,379

Valves (light liquid service) 380 1,179 1,980

Connectors (light liquid service) 731 2,662 7,410

PRD 2 45 76

OEL 33 141 424

Next assuming the “Simple” model chemical manufacturing plant is representative of a PC facility,

emission factors were applied to determine the baseline emissions and the emissions under Options 1

and 2 that would be expected by equipment component type. These factors were multiplied by the

number of components of that type at the “Simple” model plant and converted to tons per year (tpy) to

arrive at the total emissions in tpy at the baseline (40 CFR part 63, subpart TT) and for Options 1 and 2

(40 CFR part 63, subpart UU with and without connector monitoring). These emissions factors were

based on those used in the Uniform Standards analysis, but because the factors used in that analysis are

for total organic compounds, which for chemical manufacturing faciliti es are generally volatile organic

compounds (VOC), these factors were modified to reflect the amount of VOC that are expected to be

HAP. In a previous risk and technology review action for the HON (71 FR 34434), HAP emissions were

assumed to represent 56 p ercent of the total VOC emissions from the organic chemical manufacturing

facilities subject to the HON. While we have no information about the HAP to VOC ratio for the PC

source category, we assumed that the HAP to VOC ratio would be similar to that of HO N facilities, and

we applied this ratio to the equipment leak emissions factors used in the Uniform Standards analysis.

The resulting emissions factors that were used for the PC source category are shown in Table 5.

Table 5. Equipment Leak Emission Facto rs by Component Type 4



### Type of Equipment Emission Factor (kg/hr/component)

Baseline Option 1/Option 2

Pump Seals

– Light Liquid Service 1.41E

- 03 3.89E

- 04

Valves

- Gas/Vapor Service 1.97E

- 04 1.14E

- 04

Valves

- Light Liquid Service 2.18E

- 04 1.30E

- 04

Connectors

– Gas/Vapor and Light Liquid Service 1.72E

- 04 9.07E

- 05

3 See Table 3 of Memorandum from Hancy, C., RTI International, to Howard, J., EPA/OA QPS. Analysis of Emission

Reduction Techniques for Equipment Leaks. December 21, 2011. EPA Docket No. EPA

- HQ

- OAR

- 2010

- 0869

- 0029.

4 See Table 6 of Memorandum from Hancy, C., RTI International, to Howard, J., EPA/OAQPS. Analysis of Emission

Reduction Techniq ues for Equipment Leaks. December 21, 2011. EPA Docket No. EPA

- HQ

- OAR

- 2010

- 0869

- 0029. A HAP

to VOC ratio of 0.56:1 was applied to these Table 6 values.DRAFT



### 9 Table 6 shows the amount of HAP estimated at the baseline and considering the more stringent leak

definitions for each component. This table also shows the total HAP emissions expected at the baseline

and under LDAR program Options 1 and 2 for these components.

To determine the costs of the LDAR program at the baseline and for Options 1 and 2, the approach taken

was the approach used for the Uniform Standards analysis. In determining the costs for the PC source

category, the same leak rates, repair times, labor charges and other administrative and miscellaneous

costs were assumed (see Attachment 3 for detailed cost calculations). 5 

### Table 6 shows the costs and cost

effectiveness by componen t and as a total for all three component types for each option. This

information is presented for one model facility and as a total for the PC source category, based on four

facilities in the source category with these model plant costs and emissions reduc tions. The cost

effectiveness of Option 1 is $1,013, and for Option 2 the cost effectiveness is $7,338. The incremental

cost effectiveness of Option 2 is $13,230.

5 See Attachment 5 for Model 1 of Memorandum from Hancy, C., RTI International, to Howard, J., EPA/OAQPS . Analysis

of Emission Reduction Techniques for Equipment Leaks. December 21, 2011. EPA Docket No. EPA

- HQ

- OAR

- 2010

- 0869

-

0029.

.

### 10 Table 6. Summary of Equipment Leaks Analysis Results for the PC Source Category

Type of

equipment Cost Parameter 

### Model Plant: Simple PC Source Category (4 Facilities)

Baseline

(subpart TT) Option 1

(subpart UU,

w/o connectors) Option 2

(subpart UU,

w/connectors) Baseline

(subpart TT) Option 1

(subpart UU,

w/o connectors) Option 2

(subpart UU,

w/connectors)

Pumps in light

liquid service HAP Emissions 0.20 0.06 0.81 0.23

HAP Emission Reduction From Baseline

-- 0.15

-- 0.59

Capital Cost Above Baseline

-- $2,227

-- $8,909

Annualized Cost Above Baseline

-- $375

-- $1,501

Cost Effectiveness

-- $2,549

-- $2,549

Valves in light

liquid service HAP Emissions 0.95 0.56 3.79 2.24

HAP Emission Reduction From Baseline

-- 0.39 1.55

Capital Cost Above Baseline

-- $1,672 $6,687

Annualized Cost Above Baseline

-- $165 $661

Cost Effectiveness

-- $427 $427

Connectors HAP Emissions 1.21 1.21 0.64 4.85 4.85 2.56

HAP Emission Reduction From Baseline

-- -- 0.57

-- -- 2.29

Capital Cost Above Baseline

-- -- $19,361

-- -- $77,445

Annualized Cost Above Baseline

-- -- $7,583

-- -- $30,331

Cost Effectiveness

-- -- $13,230

-- $13,230

Total LDAR

Program Cost HAP Emissions 2.37 1.83 1.26 9.46 7.32 5.03

HAP Emission Reduction From Baseline

-- 0.53 1.11

-- 2.14 4.43

Incremental Emission Reduction

(baseline→option 1, option→2) -- 0.53 0.57

-- 2.14 2.29

Capital Cost Above Baseline

-- $3,899 $23,260

-- $15,597 $93,041

Annualized Cost Above Baseline

-- $541 $8,123

-- $2,162 $32,494

Cost Effectiveness

-- $1,013 $7,338

-- $1,013 $7,338

Incremental Cost Effectiveness

(baseline→option 1, option 1→2) -- $1,013 $13,230

-- $1,013 $13,230

### A-1 .



# Attachment 1:

Results of RBLC Database QueriesRBLCID Facility name ST Permit Date Process Name Through

‐

put Throughput

Units Pollutant Control Method %

Efficiency

AL

‐ 0190 GE PLASTICS AL 07/13/2001 BISPHENOL ACETONE

(BPA) PRODUCTION UNIT 799 MMLB/YR Volatile Organic

Compounds (VOC) 0

AL

‐ 0190 GE PLASTICS AL 07/13/2001 BRINE RECOVERY UNIT 31 MMLB/YR Volatile Organic

Compounds (VOC) STRIPPER 0

AL

‐ 0190 GE PLASTICS AL 07/13/2001 FURNACE, HOT OIL, 10

MMBTU/H 10 MMBTU/H Volatile Organic

Compounds (VOC) GOOD

COMBUSTION

PRACTICES 0

AL

‐ 0190 GE PLASTICS AL 07/13/2001 FURNACE, HOT OIL, 20

MMBTU/H 20 MMBTU/H Volatile Organic

Compounds (VOC) GOOD

COMBUSTION

PRACTICES 0

AL

‐ 0190 GE PLASTICS AL 07/13/2001 PHOSGENE PRODUCTION

UNIT, SCRUBBERS 463 MMLB/YR Volatile Organic

Compounds (VOC) SCRUBBERS 1 & 2 0

AL

‐ 0190 GE PLASTICS AL 07/13/2001 RESIN PRODUCTION UNIT,

ABSORBER 920 MMLB/YR Volatile Organic

Compounds (VOC) ABSORBER P84 0

AL

‐ 0190 GE PLASTICS AL 07/13/2001 RESIN PRODUCTION UNIT,

BAGHOUSE 920 MMLB/YR Volatile Organic

Compounds (VOC) 0

### A-3 

# Attachment 2:

Analysis of Subsequent Regulations

### A-4 Source Category Subpart Date of

Final

Rule Practices, Processes, and Control Techniques

Evaluated

Acrylic and Modacrylic

Fibers YY 6/29/99 combustion devices, recovery devices, LDAR, equipment

modifications, floating roofs, steam stripping, biological

treatment, pollution prevention

Acetal Resins YY 6/29/99 combustion devices, recovery devices, LDAR, equipment

modifications, floating roofs, steam stripping, biological

treatment

Hydrogen Fluoride YY 6/29/99 recovery devices, scrubbers, LDAR,

equipment modifications

Amino/Phenolic Resins OOO 1/20/00 combustion devices, recovery devices, pollution

prevention to achieve mass emission limit, LDAR,

equipment modifications, floating roofs

Ethylene Processes YY 7/12/02 combustion devices, recovery devices, LDAR, equipment

modifications, floating roofs, steam stripping, biological

treatment

Spandex Production YY 7/12/02 combustion devices, recovery devices,

equipment modifications, floating roofs

Miscellaneous Organic

Chemical Production

and Processes (MON) FFFF 11/10/03 combustion devices, recovery devices, halogen reduction

devices, LDAR, equipment modi fications, pollution

prevention, floating roofs, steam stripping, biological

treatment

PVC & Copolymer

Production DDDDDD 1/23/07 recovery devices, steam stripping

Acrylic and Modacrylic

Fibers LLLLLL 7/16/07 scrubbers, floating roofs, combustion devices, recovery

devices, steam stripping, biological treatment, LDAR,

equipment modifications, pollution prevention

### A-5 Source Category Subpart Date of

Final

Rule Practices, Processes, and Control Techniques

Evaluated

Chemical

Manufacturing VVVVVV 10/29/09 combustion devices, recovery devices, LDAR, equipment

modifications, floating roofs, steam stripping, biological

treatment

Chemical Preparations BBBBBBB 12/30/09 scrubbers, LDAR

Hazardous Organic

NESHAP (HON) F, G, H 12/21/06 No significant development in practices,

processes or control technologies since promulgation of

the MACT standards

Pharmaceuticals GGG 4/21/11 No significant development in practices,

processes or control technologies since promulgation of

the MACT standards

Group I Polymers and

Resins U 4/21/11 No significant development in practices,

processes or control technologies since promulgation of

the MACT standards

Hydrogen Fluoride YY 12/16/08 No significant development in practices,

processes or control technologies since promulgation of

the MACT standards

Acetal Resins YY 12/16/08 No significant development in practices,

processes or control technologies since promulgation of

the MACT standards

### A-6 

# Attachment 3:

Equipment Leak Model Plant CostsModel Plant - SimpleType of ComponentNumber ofComponentsInitialMonitoring Feeor Unit Cost($/comp)InitialMonitoringCosts ($/yr)(Capital)InitialLDARAdmin.CostsFrequencyof Monitoring(times/yr)SubsequentMonitoringFee ($/comp)or Charge(%)AnnualMonitoringCosts ($/yr)AnnualMaintenanceCosts ($/yr)Initial LeakFrequency(%)InitialNumberof LeaksSubsequentLeakFrequency(%)AnnualNumberof LeaksPercentRepairedOnLineRepairTime(hours)LaborCharge($/hr)AnnualOnLine LeakRepair Cost($/yr)PercentRequiringFurtherRepairRepairTime(hours)LaborCharge($/hr)AnnualOffline LeakRepair Cost($/yr)Monitoringto VerifyRepair ($)AnnualAdmin.Cost ($/yr)AnnualMisc.Charges($/yr)Pump Option 1 (1,000 ppm)66.24 $/hr, labor rate for repairPump Seals (UU)* Light-liquid service150.002143.06121.50 580.13 132.31 13.48 2.02 0.26 0.47 100 16.00 66.24 496.02 0 80.00 66.24 0.00 0.70105.85* Heavy-liquid service00.00 0.00Replacement Pump Seals15 282.71 571.64Annual Adminstrative and Repo092.72$0- Assume 300 hr per facInitial Planning and Training092.72$0- Assume 340 hr per facTOTALS$2,715 $0$580$132$496$0 $1 $0 $106Capital Costs$2,715Annualized Capital Costs $444Annual Expenses$1,315Annual Fixed Costs ($/yr) $550Annual Variable Costs ($/yr) $1,209$1,759Type of ComponentNumber ofComponentsInitialMonitoring Feeor Unit Cost($/comp)InitialMonitoringCosts ($/yr)(Capital)InitialLDARAdmin.CostsFrequencyof Monitoring(times/yr)SubsequentMonitoringFee ($/comp)or Charge(%)AnnualMonitoringCosts ($/yr)AnnualMaintenanceCosts ($/yr)Initial LeakFrequency(%)InitialNumberof LeaksSubsequentLeakFrequency(%)AnnualNumberof LeaksPercentRepairedOnLineRepairTime(hours)LaborCharge($/hr)AnnualOnLine LeakRepair Cost($/yr)PercentRequiringFurtherRepairRepairTime(hours)LaborCharge($/hr)AnnualOffline LeakRepair Cost($/yr)Monitoringto VerifyRepair ($)AnnualAdmin.Cost ($/yr)AnnualMisc.Charges($/yr)Baseline Monitoring (10,000 ppm)66.24 $/hr, labor rate for repairPump Seals (UU)* Light-liquid service150.00384.73121.50 580.13 117.04 2.42 0.36 0.23 0.41 100 16.00 66.24 438.79 0 80.00 66.24 0.00 0.6293.63* Heavy-liquid service00.00 0.00Replacement Pump Seals15 282.71 102.62Annual Adminstrative and Repo092.72$0- Assume 300 hr per facInitial Planning and Training092.72$0- Assume 340 hr per facTOTALS$487 $0$580$117$439$0 $1 $0 $94Capital Costs$487Annualized Capital Costs $80Annual Expenses$1,230Annual Fixed Costs ($/yr) $173Annual Variable Costs ($/yr) $1,137$1,310INCREMENTAL COSTS OF PUMPS OPTION 1Incremental Capital Costs ($) 2,227Annualized Capital ($/yr) 364Incremental Annual Expenses ($/yr) 85Model Plant - SimpleType of ComponentNumber ofComponentsInitialMonitoring Feeor Unit Cost($/comp)InitialMonitoringCosts ($/yr)(Capital)InitialLDARAdmin.CostsFrequencyof Monitoring(times/yr)SubsequentMonitoringFee ($/comp)or Charge(%)AnnualMonitoringCosts ($/yr)AnnualMaintenanceCosts ($/yr)Initial LeakFrequency(%)InitialNumberof LeaksSubsequentLeakFrequency(%)AnnualNumberof LeaksPercentRepairedOnLineRepairTime(hours)LaborCharge($/hr)AnnualOnLine LeakRepair Cost($/yr)PercentRequiringFurtherRepairRepairTime(hours)LaborCharge($/hr)AnnualOffline LeakRepair Cost($/yr)Monitoringto VerifyRepair ($)AnnualAdmin.Cost ($/yr)AnnualMisc.Charges($/yr)Valves Option 1 (500 ppm)66.24$/hr, labor rate for repairValves (UU)* Gas/vapor service770.00 415.5421.50 231.007.24 5.57 0.51 0.79 75 0.17 66.24 6.52 25 4.00 66.24 52.03 1.18* Light-liquid service3800.00 1370.9221.50 1140.004.84 18.39 0.51 3.88 75 0.17 66.24 32.16 25 4.00 66.24 256.75 5.81* Heavy-liquid service01.10 0.001Annual Adminstrative and Repo092.72$0- Assume 300 hr per facInitial Planning and Training092.72$0- Assume 340 hr per facTOTALS$1,786 $0$1,371$0$39$309 $7 $0 $0Capital Costs$1,786Annualized Capital Costs $254Annual Expenses$1,725$1,980Type of ComponentNumber ofComponentsInitialMonitoring Feeor Unit Cost($/comp)InitialMonitoringCosts ($/yr)(Capital)InitialLDARAdmin.CostsFrequencyof Monitoring(times/yr)SubsequentMonitoringFee ($/comp)or Charge(%)AnnualMonitoringCosts ($/yr)AnnualMaintenanceCosts ($/yr)Initial LeakFrequency(%)InitialNumberof LeaksSubsequentLeakFrequency(%)AnnualNumberof LeaksPercentRepairedOnLineRepairTime(hours)LaborCharge($/hr)AnnualOnLine LeakRepair Cost($/yr)PercentRequiringFurtherRepairRepairTime(hours)LaborCharge($/hr)AnnualOffline LeakRepair Cost($/yr)Monitoringto VerifyRepair ($)AnnualAdmin.Cost ($/yr)AnnualMisc.Charges($/yr)Baseline Monitoring (10,000 ppm)66.24$/hr, labor rate for repairValves (UU)* Gas/vapor service770.00 19.3121.50 231.000.34 0.26 0.34 0.52 75 0.17 66.24 4.30 25 4.00 66.24 34.33 0.78* Light-liquid service3800.00 95.3121.50 1140.000.34 1.28 0.34 2.56 75 0.17 66.24 21.22 25 4.00 66.24 169.40 3.84* Heavy-liquid service00.00 0.0000.00 Nat. fac0.00 Nat. BatchAnnual Adminstrative and Repo092.72$01.00 Nat. Cont f - Assume 300 hr per facInitial Planning and Training092.72$0- Assume 340 hr per facTOTALS$115 $0$1,371$0$26$204 $5 $0 $0Capital Costs$115Annualized Capital Costs $16Annual Expenses$1,605Annual Fixed Costs ($/yr)$16Annual Variable Costs ($/yr) $1,605$1,621INCREMENTAL COSTS OF VALVES OPTION 1Incremental Capital Costs ($) 1,672Annualized Capital ($/yr) 238Incremental Annual Expenses ($/yr) 121Model Plant - SimpleType of ComponentNumber ofComponentsInitialMonitoring Feeor Unit Cost($/comp)InitialMonitoringCosts ($/yr)(Capital)InitialLDARAdmin.CostsFrequencyof Monitoring(times/yr)SubsequentMonitoringFee ($/comp)or Charge(%)AnnualMonitoringCosts ($/yr)AnnualMaintenanceCosts ($/yr)Initial LeakFrequency(%)InitialNumberof LeaksSubsequentLeakFrequency(%)AnnualNumberof LeaksPercentRepairedOnLineRepairTime(hours)LaborCharge($/hr)AnnualOnLine LeakRepair Cost($/yr)PercentRequiringFurtherRepairRepairTime(hours)LaborCharge($/hr)AnnualOffline LeakRepair Cost($/yr)Monitoringto VerifyRepair ($)AnnualAdmin.Cost ($/yr)AnnualMisc.Charges($/yr)Connectors Option 166.24 $/hr, labor rate for repairConnectors* Flanges - gas/vapor* Flanges - light liquid731 23.80 17506.800.252.50 456.880.36 2.63 0.36 0.66 75 0.17 66.24 5.46 25 2.00 66.24 21.79 1.64* Flanges -heavy liquid1Annual Adminstrative and Repo5092.72$4,636Initial Planning and Training2092.72$1,854TOTALS$17,507 $1,854$457$0$5$22 $2 $4,636 $0INCREMENTAL COSTS OF CONNECTORS OPTION 1Capital Costs$19,361Annualized Capital Costs $2,749Annual Expenses$5,120Annual Fixed Costs ($/yr) $7,385Annual Variable Costs ($/yr) $484$7,8691