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 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 standards 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. 
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• 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 significant 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 category 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 emissions 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. 
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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 Vessels 

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 developed, 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 permit 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 for 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 (attainment 
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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 determined 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 to 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 evaluated 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. 
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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: any 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 cost 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 repair 
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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 during 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 definitions 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.
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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 liquid 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 equipment (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 Uniform 
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Standards analysis.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 developed 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 Facilities3 

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 facilities 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 percent 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 HON 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 Factors by Component Type4

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/OAQPS. 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 Techniques 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.
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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 component 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 reductions. 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 Queries
RBLCID 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

 

 RBLC SEARCH FOR THE 

POLYCARBONATE PRODUCTION SOURCE CATEGORY

9/19/2012 Page 1
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 modifications, 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 Costs
Model Plant - Simple

Type of Component Number of Components

Initial 

Monitoring Fee

or Unit Cost 

($/comp)

Initial 

Monitoring 

Costs ($/yr) 

(Capital)

Initial 

LDAR 

Admin. 

Costs

Frequency 

of Monitoring

(times/yr)

Subsequent 

Monitoring 

Fee ($/comp) 

or Charge 

(%)

Annual 

Monitoring 

Costs ($/yr)

Annual 

Maintenance 

Costs ($/yr)

Initial Leak 

Frequency 

(%)

Initial 

Number 

of Leaks

Subsequent 

Leak 

Frequency 

(%)

Annual 

Number 

of Leaks

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Pump Option 1 (1,000 ppm)

66.24 $/hr, labor rate for repair

Pump Seals (UU) * Light-liquid service 15 0.00 2143.06 12 1.50 580.13 132.31 13.48 2.02 0.26 0.47 100 16.00 66.24 496.02 0 

 * Heavy-liquid service 0 0.00 0.00

Replacement Pump Seals 15 282.71 571.64Annual Adminstrative and Repo 0 92.72 

 - Assume 300 hr per facInitial Planning and Training 0 92.72 $0

 - Assume 340 hr per facTOTALS $2,715 $0 $580 $132 $496 

Capital Costs $2,715

Annualized Capital Costs $444

Annual Expenses $1,315

Annual Fixed Costs ($/yr) $550

Annual Variable Costs ($/yr) $1,209

$1,759

Type of Component Number of Components

Initial 

Monitoring Fee

or Unit Cost 

($/comp)

Initial 

Monitoring 

Costs ($/yr) 

(Capital)

Initial 

LDAR 

Admin. 

Costs

Frequency 

of Monitoring

(times/yr)

Subsequent 

Monitoring 

Fee ($/comp) 

or Charge 

(%)

Annual 

Monitoring 

Costs ($/yr)

Annual 

Maintenance 

Costs ($/yr)

Initial Leak 

Frequency 

(%)

Initial 

Number 

of Leaks

Subsequent 

Leak 

Frequency 

(%)

Annual 

Number 

of Leaks

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Baseline Monitoring (10,000 ppm)

66.24 $/hr, labor rate for repair

Pump Seals (UU) * Light-liquid service 15 0.00 384.73 12 1.50 580.13 117.04 2.42 0.36 0.23 0.41 100 16.00 66.24 438.79 0 

 * Heavy-liquid service 0 0.00 0.00

Replacement Pump Seals 15 282.71 102.62Annual Adminstrative and Repo 0 92.72 

 - Assume 300 hr per facInitial Planning and Training 0 92.72 $0

 - Assume 340 hr per facTOTALS $487 $0 $580 $117 $439 

Capital Costs $487

Annualized Capital Costs $80

Annual Expenses $1,230

Annual Fixed Costs ($/yr) $173

Annual Variable Costs ($/yr) $1,137

$1,310

INCREMENTAL COSTS OF PUMPS OPTION 1

Incremental Capital Costs ($) 2,227

Annualized Capital ($/yr) 364

Incremental Annual Expenses ($/yr) 85
Model Plant - Simple

Type of Component Number of Components

Initial 

Monitoring Fee

or Unit Cost 

($/comp)

Initial 

Monitoring 

Costs ($/yr) 

(Capital)

Initial 

LDAR 

Admin. 

Costs

Frequency 

of Monitoring

(times/yr)

Subsequent 

Monitoring 

Fee ($/comp) 

or Charge 

(%)

Annual 

Monitoring 

Costs ($/yr)

Annual 

Maintenance 

Costs ($/yr)

Initial Leak 

Frequency 

(%)

Initial 

Number 

of Leaks

Subsequent 

Leak 

Frequency 

(%)

Annual 

Number 

of Leaks

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Valves Option 1 (500 ppm)

66.24 $/hr, labor rate for repair

Valves (UU) * Gas/vapor service 77 0.00 415.54 2 1.50 231.00 7.24 5.57 0.51 0.79 75 0.17 66.24 6.52 25 

 * Light-liquid service 380 0.00 1370.92 2 1.50 1140.00 4.84 18.39 0.51 3.88 75 0.17 66.24 32.16 25 

 * Heavy-liquid service 0 1.10 0.00 1

Annual Adminstrative and Repo 0 92.72 

 - Assume 300 hr per facInitial Planning and Training 0 92.72 $0

 - Assume 340 hr per facTOTALS $1,786 $0 $1,371 $0 $39 

Capital Costs $1,786

Annualized Capital Costs $254

Annual Expenses $1,725

$1,980

Type of Component Number of Components

Initial 

Monitoring Fee

or Unit Cost 

($/comp)

Initial 

Monitoring 

Costs ($/yr) 

(Capital)

Initial 

LDAR 

Admin. 

Costs

Frequency 

of Monitoring

(times/yr)

Subsequent 

Monitoring 

Fee ($/comp) 

or Charge 

(%)

Annual 

Monitoring 

Costs ($/yr)

Annual 

Maintenance 

Costs ($/yr)

Initial Leak 

Frequency 

(%)

Initial 

Number 

of Leaks

Subsequent 

Leak 

Frequency 

(%)

Annual 

Number 

of Leaks

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Baseline Monitoring (10,000 ppm)

66.24 $/hr, labor rate for repair

Valves (UU) * Gas/vapor service 77 0.00 19.31 2 1.50 231.00 0.34 0.26 0.34 0.52 75 0.17 66.24 4.30 25 

 * Light-liquid service 380 0.00 95.31 2 1.50 1140.00 0.34 1.28 0.34 2.56 75 0.17 66.24 21.22 25 

 * Heavy-liquid service 0 0.00 0.00 0

0.00 Nat. fac0.00 Nat. Batch Annual Adminstrative and Repo 0 92.72 

1.00 Nat. Cont f - Assume 300 hr per fac

Initial Planning and Training 0 92.72 $0

 - Assume 340 hr per facTOTALS $115 $0 $1,371 $0 $26 

Capital Costs $115

Annualized Capital Costs $16

Annual Expenses $1,605

Annual Fixed Costs ($/yr) $16

Annual Variable Costs ($/yr) $1,605

$1,621

INCREMENTAL COSTS OF VALVES OPTION 1

Incremental Capital Costs ($) 1,672

Annualized Capital ($/yr) 238

Incremental Annual Expenses ($/yr) 121
Model Plant - Simple

Type of Component Number of Components

Initial 

Monitoring Fee

or Unit Cost 

($/comp)

Initial 

Monitoring 

Costs ($/yr) 

(Capital)

Initial 

LDAR 

Admin. 

Costs

Frequency 

of Monitoring

(times/yr)

Subsequent 

Monitoring 

Fee ($/comp) 

or Charge 

(%)

Annual 

Monitoring 

Costs ($/yr)

Annual 

Maintenance 

Costs ($/yr)

Initial Leak 

Frequency 

(%)

Initial 

Number 

of Leaks

Subsequent 

Leak 

Frequency 

(%)

Annual 

Number 

of Leaks

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Connectors Option 1 66.24 $/hr, labor rate for repair

Connectors * Flanges - gas/vapor * Flanges - light liquid 731 23.80 17506.80 0.25 2.50 456.88 0.36 2.63 0.36 0.66 75 0.17 66.24 5.46 25 

 * Flanges -heavy liquid 1Annual Adminstrative and Repo 50 92.72 

Initial Planning and Training 20 92.72 $1,854

TOTALS $17,507 $1,854 $457 $0 $5 

INCREMENTAL COSTS OF CONNECTORS OPTION 1

Capital Costs $19,361

Annualized Capital Costs $2,749

Annual Expenses $5,120

Annual Fixed Costs ($/yr) $7,385

Annual Variable Costs ($/yr) $484

$7,869

 1