MEMORANDUM

Date: December 16, 2013

Subject: Revised Cost Impacts Associated with the Final Pressure Relief Device 

Monitoring Requirements for the Pesticide Active Ingredient Production, 

Polyether Polyols Production, and Group IV Polymers and Resins Source 

Categories

From: Lesley Stobert, EC/R Incorporated

To: Nick Parsons, EPA/OAQPS/SPPD

______________________________________________________________________________

The purpose of this memorandum is to present the estimated cost impacts of the final 

requirements for pressure relief device (PRD) monitoring for the seven source categories that are 

subject to the Pesticide Active Ingredient Production (PAI), Polyether Polyols Production

(PEPO), and Group IV Polymers and Resins (P&R IV) National Emission Standards for 

Hazardous Air Pollutants (NESHAP) – 40 CRF 63, subparts MMM, PPP, and JJJ, respectively. 

These source categories are PAI, PEPO, and the following P&R IV source categories: AcrylicButadiene-Styrene (ABS) Production, Methyl Methacrylate-Butadiene-Styrene (MBS) 

Production, Polyethylene Terephthalate (PET) Production, Polystyrene Production and StyreneAcrylonitrile (SAN) Production. The addition of PRD monitoring requirements to the NESHAP 

for these source categories was proposed along with proposed changes evaluated under the 

EPA’s Residual Risk and Technology Review (RTR) program, under the statutory requirements 

of section 112(d)(6) and 112(f)(2) of the Clean Air Act (77 FR 1268, January 9, 2012). The final 

rule requirements specify that PRDs in organic hazardous air pollutant (HAP) service may not 

release to the atmosphere. To ensure compliance with this requirement, the final rule 

amendments require that owners or operators employ monitoring capable of immediately alerting 

an operator when there is an atmospheric release from a PRD in organic HAP service and 

capable of recording the time and duration of each pressure release. Owners or operators are 

required to report all pressure releases and an estimate of the amount of organic HAP released to 

the atmosphere with their next periodic report. This memorandum includes revised cost impact 

estimates for the seven source categories considering comments received on the proposed rule 

regarding the cost of PRD monitoring systems and also the number of PRDs expected at these 

types of facilities and revisions to the number of facilities in some of the source categories. 

Section 1 of this memorandum provides background information regarding the final PRD 

requirements, and Section 2 presents the estimated PAI, PEPO and P&R IV source category 

PRD monitoring requirement cost impacts. 

1.0 BACKGROUND

Section 112 of the Clean Air Act (CAA) establishes a comprehensive regulatory process 

to address emissions of HAP from stationary sources. In accordance with CAA section 112(c), 

the 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 the EPA to promulgate 
2

national technology-based emission standards for each listed category 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 

technology-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 control technology (MACT) standards. 

Section 112(d)(6) then requires the 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 than every 8 years. The residual risk 

review is described in section 112(f) of the CAA. CAA section 112(f)(2) requires the EPA to 

promulgate standards for each category or subcategory of CAA section 112(d) sources “if 

promulgation of such standards is required in order 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.”

In addition to the residual risk and technology reviews performed regarding the 

NESHAP, the EPA also reviews the existing provisions of the NESHAP during the RTR process. 

In 2008, the United States Court of Appeals for the District of Columbia Circuit vacated portions 

of two provisions in the EPA’s CAA section 112 regulations governing the emissions of HAP 

during periods of SSM. Sierra Club v. EPA, 551 F.3d 1019 (D.C. Cir. 2008), cert. denied, 130 S. 

Ct. 1735 (U.S. 2010). Specifically, the Court vacated the SSM exemption contained in 40 CFR 

63.6(f)(1) and 40 CFR 63.6(h)(1), that are part of a regulation, commonly referred to as the 

“General Provisions Rule,” that the EPA promulgated under section 112 of the CAA. When 

incorporated into CAA Section 112(d) regulations for specific source categories, these two 

provisions exempt sources from the requirement to comply with the otherwise applicable CAA 

section 112(d) emission standard during periods of SSM. In light of, and consistent with, Sierra 

Club v. EPA, the EPA is eliminating the SSM exemption in the PAI, PEPO and P&R IV 

NESHAP and require that the standards in these rules would apply at all times, including during 

periods of SSM.

As part of the elimination of the SSM exemption in these NESHAP, the EPA proposed 

and is finalizing requirements for the monitoring of PRDs in organic HAP service that release to 

the atmosphere and that a pressure release from such a PRD is a violation. To ensure compliance 

with this requirement, facility owners or operators are required to monitor PRDs in organic HAP 

service using a device or system that is capable of identifying and recording the time and 

duration of each pressure release and of notifying operators that a release has occurred. Owners 

or operators are required to report any pressure release and an estimate of the amount of organic 

HAP released to the atmosphere with the next periodic report.

2.0 COST IMPACTS

In order to estimate the costs associated with requiring monitoring of PRDs for P&R IV, 

PAI, and PEPO facilities, it was assumed that operators would install electronic indicators on 

each PRD in organic HAP service that vents to the atmosphere to identify and record the time 

and duration of each pressure release. However, owners or operators could use a range of 

methods to satisfy these requirements, including the use of a parameter monitoring system that 

may already have been in place on the process operating pressure that is sufficient to notify 
3

operators immediately that a pressure release is occurring, as well as recording the time and 

duration of that release. To estimate the cost of electronic indicators, analyses performed by the 

South Coast Air Quality Management District (SCAQMD) of California were referred to, which 

requires continuous monitoring of a percentage of PRDs at refineries by installing a monitoring 

device capable of recording the duration of each release and quantifying emissions. Wireless 

technology allows continuous monitoring of PRDs and makes it easier for operators to identify 

releases and leaks.1There are several monitoring devices that can be used, including acoustic 

sensors and pressure/differential pressure sensors. These sensor units communicate with a base 

radio that interfaces with the existing control system. The costs for PRD wireless monitoring are 

summarized in Table 2. These costs are based on an analysis documented by the SCAQMD for 

electronic monitoring devices for PRDs. 

To estimate PRD monitoring requirement costs, we made assumptions regarding PRD 

equipment component counts based on available information. For the PEPO source category, the 

model plant PRD equipment component counts developed for the original MACT standard were 

used.2For the PAI and P&R IV source categories, no information was readily available 

regarding PRD component counts. As a result, it was assumed that, for the P&R IV source 

categories, the simple, medium, and complex model plants developed for the chemical industry 

would best represent the P&R IV source category PRD equipment component counts.3For the 

PAI source category, equipment leak component counts were developed for model PAI plants 

during development of the NESHAP, however PRDs were not included in the component counts. 

Based on the other PAI equipment leak component counts, it was assumed that the number of 

PRDs at batch and continuous plants would best be represented by the simple and medium model 

plants developed for the chemical industry.4Table 1 presents the model plant PRD equipment 

component counts used for estimating PRD monitoring system costs for the PAI, PEPO and 

P&R IV source categories.

Table 1. Model Plants for PAI, PEPO and P&R IV Source Categories

Equipment 

Component 

Number of Components

P&R IV Source Category

PAI Source 

Category PEPO Source Category

Simple 

Model 

Plant

Medium 

Model 

Plant

Complex 

Model 

Plant

Batch 

Model 

Plant

Continuous 

Model 

Plant

Small 

Model 

Plant

Large 

Model 

Plant

Solvent 

Extraction 

Model 

Plant

PRD 2 45 76 2 45 8 11 34

 

1 Ellis, Kennard, SCAQMD. Final Staff Report for Proposed Amended Rule 1173 - Control of Volatile Organic 

Compound Leaks and Releases from Components at Petroleum Facilities and Chemical Plants. May 15, 2007. 

Docket No. EPA-HQ-OAR-2010-0869-0024.

2 Memorandum from Hendricks, D. and Joanne Seaman, EC/R Incorporated to Svendsgaard, D., EPA/OAQPS. 

Estimated Impacts for the Polyether Polyols NESHAP. April 25, 1997. (included in the Supplementary Information 

Document (SID) for the PEPO Proposed NESHAP)

3 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 Memorandum from Randall, D. and Karen Schmidtke, Midwest Research Institute to Banker, L., EPA/OAQPS. 

Model Plants for the Pesticide Active Ingredient Manufacturing Industry. April 30, 1997. (included in the 

Supplementary Information Document (SID) for the PAI Proposed NESHAP)
4

The capital costs estimated for PRD monitoring are summarized in Table 2. These costs 

are based on an analysis documented by the SCAQMD for electronic monitoring devices for 

PRDs.5The monitoring device cost provided by SCAQMD was based on vendor costs and 

ranged from $5,000 to $10,000, with an average of $7,500, and includes device parts, 

installation, and maintenance, as well as a data retrieval system. It was assumed for this analysis 

that these costs were presented in 2007 dollars and the costs were escalated to 2012 dollars. As a 

result, the total capital investment was determined to be $8,345 per PRD. According to the 

SCAQMD document, the cost of electronic monitoring systems is not linear, and facilities 

requiring a larger number of monitors are expected to benefit from economies of scale. 

Therefore, the sixth-tenths rule was applied to calculate initial costs.6In determining the 

annualized capital costs, it was assumed that the monitoring system would last for 10 years and 

the interest rate assumed was seven percent. No operating costs were estimated as they are 

assumed to be minimal.

Table 2. Total Capital Investment and Annualized Cost of Pressure Relief Devices for APR 

Source Category Model Plants

Model

Number of 

PRDs per 

Model 

Facilitya

PRD Costs per Facility

Capital 

Costsb

Annualized 

Capital Costsc

Pesticides Active Ingredients

Batch Model Plant 2 $12,649 $1,796 

Continuous Model Plant 45 $81,913 $11,632 

Polyether Polyols

Small Model Plant 8 $29,059 $4,126 

Large Model Plant 11 $35,177 $4,995 

Solvent Extraction Model 

Plant

34 $69,233 $9,831 

Group IV Polymers and 

Resins

Simple Model Plant 2 $12,649 $1,796 

Medium Model Plant 45 $81,913 $11,632 

Complex Model Plant 76 $112,180 $15,930 

Minor discrepancies are due to rounding.

a

See Table 1.

b Unit device installation cost of $7,500 in 2007 dollars escalated to 2012 dollars using Chemical Engineering 

(CE) Index resulting in a cost of $8,345 per unit. CE Index for 2007 is 525.4 and 584.6 for 2012. Facility capital 

investment calculated using sixth-tenths rule. Facility Cost ($) = PRD Unit Cost ($) * (No. of PRDs)^0.6

c Annualized costs calculated using capital recovery factor of 0.142, calculated based on 7 percent interest and 10 

year equipment life.

 

5 Ellis, Kennard, SCAQMD. Final Staff Report for Proposed Amended Rule 1173 - Control of Volatile Organic 

Compound Leaks and Releases from Components at Petroleum Facilities and Chemical Plants. May 15, 2007. 

Docket Item No. EPA-HQ-OAR-2010-0869-0024.

6 Sixth-tenths rule is used to adjust for economies of scale. Cost to Facility = cost of one PRD * (number of PRDs at 

facility)^0.6.
5

To estimate PRD monitoring system costs for PAI, PEPO, and P&R IV source category 

facilities, we assumed the most conservative source category model costs (the costs associated 

with the model plants for the source category that were estimated to have the most PRD 

equipment components). 

To estimate the PAI, PEPO, and P&R IV source category labor costs associated with 

PRD monitoring, recordkeeping and reporting, we assumed the following labor rates7:

Technical $54.66 ($26.03 + 110%)

Managerial $115.96 ($55.22 + 110%)

Clerical $38.14 ($18.16 + 110%)

We assumed that owners or operators will need to expend an additional 11 technical labor hours, 

0.55 managerial hours, and 1.1 clerical hours per facility annually for recordkeeping and 

reporting requirements associated with the final PRD provisions. This adds up to an additional 

$707 per year per facility. 

Tables 3, 4 and 5 present the estimated PRD monitoring costs per facility for the PAI, 

PEPO, and P&R IV source categories, respectively. Table 6 presents a summary of the 

nationwide estimated annual PRD monitoring requirement costs by source category.

 

7 These labor rates are based on the May 2012 National Occupational Employment and Wage Estimates for the 

United States, occupational codes 51-8091 for chemical plant and system operators (technical), 11-1021 for general 

and operations managers (managerial) and 43-6010 for secretaries and administrative assistants (clerical).

These rates represent salaries plus fringe benefits. The wages provided above were increased by a rate of 110 

percent to account for overhead.
6

Table 3. Summary of PRD Monitoring System and Associated Recordkeeping and 

Reporting Requirement Costs for the PAI Production Facilities

Company/Facility

Cost of PRD 

Monitoring System PRD Annual 

Recordkeeping 

and Reporting 

Labor Costs

($)

PRD

Total 

Annualized 

Costs

($)

Capital 

Costs($)

Annualized 

Capital 

Costs

($/yr)

Dow Chemical Company – Freeport, Texas 81,913 11,632 707 12,339

Arvesta Corporation – Perry, OH 81,913 11,632 707 12,339

Dow Chemical Company – Midland, MI 81,913 11,632 707 12,339

Monsanto Company – Muscatine, IA 81,913 11,632 707 12,339

Dow Chemical Company – Pittsburg, CA 81,913 11,632 707 12,339

American Cyanamid/BASF Corporation –

Palmyra, MO 81,913 11,632 707 12,339

Syngenta Crop Protection – St. Gabriel, LA 81,913 11,632 707 12,339

Du Pont – La Porte, TX 81,913 11,632 707 12,339

GB Biosciences Corporation – Houston, TX 81,913 11,632 707 12,339

Eastman Chemical Company – Batesville, 

AR 81,913 11,632 707 12,339

EI DuPont De Nemours & Company –

Axis, AL 81,913 11,632 707 12,339

Great Lakes Chemical – El Dorado, AR 81,913 11,632 707 12,339

Occidental Chemical – Luling, LA 81,913 11,632 707 12,339

Dow Agrosciences – Harbor Beach, MI 81,913 11,632 707 12,339

McLaughlin Gormley King Company –

Chaska, MN 81,913 11,632 707 12,339

Du Pont – Belle, WV 81,913 11,632 707 12,339

Bayer Crop Science LP – Institute, WV 81,913 11,632 707 12,339

Weylchem US – Elgin, SC 81,913 11,632 707 12,339

TOTAL 1,474,434 209,376 12,726 222,102
7

Table 4. Summary of PRD Monitoring System and Associated Recordkeeping and 

Reporting Requirement Costs for the PEPO Production Facilities

Company/Facility

Cost of PRD 

Monitoring System PRD Annual 

Recordkeeping 

and Reporting 

Labor Costs

($)

PRD

Total 

Annualized 

Costs

($)

Capital 

Costs($)

Annualized 

Capital 

Costs

($/yr)

Dow Chemical Company – Freeport, Texas 69,233 9,831 707 10,538

Lyondell Chemical Company – Channel View, TX 69,233 9,831 707 10,538

BASF Corporation – Wyandotte, MI 69,233 9,831 707 10,538

Dow Chemical Company U.S.A. – Midland, MI 69,233 9,831 707 10,538

Huntsman Petrochemical Corporation – Conroe, TX 69,233 9,831 707 10,538

Arch Chemicals, Inc. – Bradenburg, KY 69,233 9,831 707 10,538

Cognis Corporation – Charlotte, NC 69,233 9,831 707 10,538

Union Carbide Corporation – South Charleston, WV 69,233 9,831 707 10,538

Stepan Company – Elwood, IL 69,233 9,831 707 10,538

Shell Chemical LP – Geismar, LA 69,233 9,831 707 10,538

BASF Corporation – Geismar, LA 69,233 9,831 707 10,538

Rubicon, LLC – Geismar, LA 69,233 9,831 707 10,538

Roger W. Powell Plant – Pasadena, TX 69,233 9,831 707 10,538

Eastman Chemical Company – Longview, TX 69,233 9,831 707 10,538

Houston Plant – Houston, TX 69,233 9,831 707 10,538

Dow Seadrift Plant – Seadrift, TX 69,233 9,831 707 10,538

Huntsman Petrochemical Corporation – Dayton, TX 69,233 9,831 707 10,538

Union Carbide Corporation – Hahnville, LA 69,233 9,831 707 10,538

Croda Inc. – Mill Hall, PA 69,233 9,831 707 10,538

Milliken Chemical Dewey Plant – Inman, SC 69,233 9,831 707 10,538

Bayer Corporation – Institute, WV 69,233 9,831 707 10,538

Union Carbide Corporation – New Martinsville, WV 69,233 9,831 707 10,538

Bayer Material Science – Institute, WV 69,233 9,831 707 10,538

TOTAL 1,592,359 226,113 16,261 242,374
8

Table 5. Summary of PRD Monitoring System and Associated Recordkeeping and 

Reporting Requirement Costs for the Group IV Polymers and Resins Production Facilities

Company/Facility

Cost of PRD Monitoring 

System

PRD Annual 

Recordkeeping 

and Reporting 

Labor Costs

($)

PRD

Total 

Annualized 

Costs

($)

Capital 

Costs($)

Annualized 

Capital Costs

($/yr)

Dow Chemical Company – Freeport, TX 112,180 15,930 707 16,637

Dow Chemical Company U.S.A – Midland, MIa336,540 47,790 2,121 49,911

Eastman Chemical Company – Kingsport, TN 112,180 15,930 707 16,637

DAK Americas LLC – Moncks Corner, SC 112,180 15,930 707 16,637

Dart Polymer, Inc. – Owensboro, KY 112,180 15,930 707 16,637

Zeon Chemicals – Louisville, KY 112,180 15,930 707 16,637

Rohm & Haas Company – Louisville, KY 112,180 15,930 707 16,637

Emerald Polymer Additives LLC – Akron, OH 112,180 15,930 707 16,637

INEOS ABS – Addyston, OH 112,180 15,930 707 16,637

Chevron Phillips Chemical Company LP –

Marietta, OH 112,180 15,930 707 16,637

Nan Ya Plastics – Lake City, SC 112,180 15,930 707 16,637

3M Film Plant – Greenville, SC 112,180 15,930 707 16,637

Eastman Chemical Company – Columbia, SC 112,180 15,930 707 16,637

Invista S.A.R.L. – Spartanburg, SC 112,180 15,930 707 16,637

Dart Container Corporation – Leola, PA 112,180 15,930 707 16,637

Dow North America – Gales Ferry, CTb224,360 31,860 1,414 33,274

Arkema, Inc. – Axis, AL 112,180 15,930 707 16,637

Atofina Petrochemical Inc. – Carville, LA 112,180 15,930 707 16,637

General Electric Company, Inc. – Washington, 

WV 112,180 15,930 707 16,637

General Electric – Bethlehem, NY 112,180 15,930 707 16,637

M&G Polymers U.S.A. – Apple Grove, WV 112,180 15,930 707 16,637

Performance Fibers, Inc. – Moncure, NC 112,180 15,930 707 16,637

General Electric Company – Plastics – Ottawa, 

IL 112,180 15,930 707 16,637

3M Company – Decatur, AL 112,180 15,930 707 16,637

DAK Americas LLC Cape Fear Site – Leland, 

NC 112,180 15,930 707 16,637

Huntsman Expandable Polymer Company, LLC 

– Peru, IL 112,180 15,930 707 16,637

INEOS Americas, LLC – Channahon, IL 112,180 15,930 707 16,637

Dow Chemical Company – Pevely, MO 112,180 15,930 707 16,637

Mitsubishi Polyester Film, LLC – Greer, SC 112,180 15,930 707 16,637

Du Pont Teijin Films – Chester, VA 112,180 15,930 707 16,637
9

a

Facility has ABS, PS and SAN P&R IV source categories. Costs replicated for each source category and totaled for 

the facility.

b

Facility has ABS and PS source categories. Costs replicated for both source categories and totaled for the facility.

Company/Facility

Cost of 

PRD 

Monitori

ng 

System

PRD Annual 

Recordkeepi

ng and 

Reporting 

Labor Costs

($)

PRD

Total 

Annualized 

Costs

($)

Company/F

acility

Performance Fibers, Inc. – Salisbury, NC 112,180 15,930 707 16,637

TOTAL 3,814,120 541,620 24,038 565,658
10

Table 6. Estimated Costs of PRD Monitoring for the PAI, PEPO, and

P&R IV Source Categories

Source Category

Number of 

Facilities in 

Source 

Category

PRD 

Monitoring 

System 

TCI per 

Facility

($)

PRD Monitoring 

System TAC per 

Facility

($)

Annual R&R Labor 

Costs per Facility

($)

PRD Monitoring System 

Costs per Source 

Category

($)

Annual PRD 

Monitoring System and 

R&R Costs per Source 

Category

($)

Pesticide Active 

Ingredient Production 

(PAI)

18 81,913 11,632 707 1,474,434 222,102

Polyether Polyols 

Production (PEPO) 23 69,233 9,831 707 1,592,359 242,374

Group IV Polymers and Resins*

Acrylic-ButadieneStyrene (ABS) 

Production 

6 112,180 15,930 707 673,080 99,822

Styrene-Acrylonitrile 

(SAN) Production 3 112,180 15,930 707 336,540 49,911

Methyl MethacrylateButadiene-Styrene 

(MBS) Production

2 112,180 15,930 707 224,360 33,274

Polyethylene 

Terephthalate (PET) 

Production

13 112,180 15,930 707 1,458,340 216,281

Polystyrene 

Production 10 112,180 15,930 707 1,121,800 166,370

TCI – Total Capital Investment

TAC – Total Annual Cost

R&R – Recordkeeping and Reporting

* Note that the estimated costs allocated to source categories are based on production type at a given facility. Where a facility has co-located source categories, these 

facility costs are replicated for all of the co-located source categories. For example, if a facility has both an ABS and SAN production line, the costs are replicated 

for both source categories.