1

TECHNICAL MEMORANDUM

TO: Jodi Howard , U.S. EPA, Sector Policies and Programs Division/ Coatings and

Chemicals Group

FROM: Eastern Research Group, Inc.

DATE: April 11

, 2011

SUBJECT: Secondary Impacts of MACT Floor Level of Control for the Polyvinyl Chloride

and Copolymers (PVC) Production Source Category

1.0 Introduction

This memorandum presents the secondary impacts associated with control devices used to comply with the proposed standards for existing and new polyvinyl chloride and co polymer s (PVC) production units. Secondary impacts result from the generation of steam and/or the consumption of fuel, water, and electricity and generation of so lid wastes by control devices.

Section 2.0 presents the background for the proposed standards. Section 3.0 presents the secondary impact estimates associated with control devices necessary for PVC facilities to comply with two control options considered. This memorandum focuses only on secondary impacts associated with control devices and the generation of steam

. Section 4.0 summarizes the estimated secondary impacts that would r esult from the compliance of new units that may come online in the next 5 years. Section 5.0 summarizes the emissions resulting from increased fuel and electricity requirements for the control options.

2.0 Background

The U.S. Environmental Protection Agency (EPA), under section 112 of the Clean Air Act (CAA), is required to establish national emissions standards for Hazardous Air Pollutants ( NES HAP) emitted from PVC production facilities. The complete set of regulate d hazardous air pollutants ( HAP ) is listed in CAA section 112(b). The CAA requires EPA to determine the maximum achievable control technology (MACT) for each category or subcategory of sources. The purpose of the memorandum is to present the methodology used to determine the secondary impacts for the PVC production source category. To determine the secondary impacts for each subcategory, EPA must first determine the minimum stringency “floor” requirements. Development of the MACT floors for PVC units is described in a separate memorandum. 1

3.0 Secondary Impact Estimates for Existing Sources

To comply with the control options , facilities may need to install the following types of

control devices at PVC units:2 Additional steam stripping in exis ting resin stripping equipment to reduce vinyl chloride (VC) and total organic HAP emissions from equipment downstream of the resin stripper(s)

,

Additional steam stripping in existing wastewater stripping equipment to reduce VC

,

Thermal oxidizer ( TO ) to r educe VC and total organic HAP emissions from process vents for two facilities,

Product recovery condensers and scrubbers to reduce VC, hydrogen chloride ( HCl )

, and total organic HAP emissions from process vents

, and

Fabric filters (FF) and activated carb on injection ( ACI ) systems to reduce chlorinated dibenzodioxins and chlorinated dibenzofurans (CDD/CDF) emissions from process

vents

.

Electricity is required to operate the pumps and fans associated with FF, condenser

systems

, scrubbers, and TO . Also, wa ter is required to generate steam for resin and wastewater stripping operations and is also required for scrubbers

. FF and ACI systems require a method to dispose of the dust produced from the systems. Additionally, ACI requires the use of activated carbon. Supplemental fuel (i.e., natural gas) is required to operate the TO

.

Table 3

- 1 shows, for each of the control op tions, the estimated secondary impacts for the

source category

. The algorithms used in the cost analysis provide annual cost estimates for electricity, water, activated carbon requirements, and supplemental fuel as itemized components

of the annual costs for the control device. 3 These cost elements for the control devices anticipated to be installed to comply with the proposed standards were then summed to provide an estimate of the overall costs of electricity, water /steam , activated carbon, and supplem ental fuel. To estimate the secondary impact components (e.g., electricity, water, dust), the itemized annual cost of each component was divided by the unit price of the component used by the algorithm.3 Table 3

- 1. Secondary Impacts for MACT Floor Control

Emission

Point Controls Required for

Compliance Electricity Required (MWh /yr) Water Required (gal/yr) Activated Carbon Required (ton/yr) Dust

Produced (ton/yr) Supplemental

Fuel (ft 3 natural gas/yr)

Process Vents Fabric Filter (5 of 17) 2,033

- - 24.3

-

ACI (5 of 17)

- - 81.9 81.9

-

Condenser (3 of 17) 3,539

- - - -
Scrubber (1 of 17) 297 199,235

- - -

Thermal Oxidizer (2 of 17) 31 .2

- - - 31,510,937

Wastewater Steam (11 of 17)

- 13,953,847

- - -

Resin Steam (12 of 17)

- 365,963,724

- - - MWh/yr

– Megawatt hours per year Gal/yr

– gallons per year Ton/yr

– tons per year

Ft 3

– cubic foot

ACI

– Activated carbon injection4

4.0 Secondary Impact Estimates for New Units

EPA does not expect that any new PVC units w ill come online in the next five years

.

5.0 Secondary Air Pollutant Impacts

Emission factors from EPA’s Egrid 4 database were used to calculate emissions resulting from the electricity required for additional control devices, and emission factors from EPA’s AP

42 emission factor document 5 were used to calculate emissions resulting from the combustion of

additional fuel for thermal oxidizers . Increased electrical use from the control options will require additional fuel to be burned in power plants, resulting in emissions of carbon dioxide ( CO 2 ) and criteria pollutants, such as sulfur dioxide ( SO 2 ), nitrogen oxides ( NO

x )

, and carbon

monoxide ( CO )

. Emissions of these pollutants (caused by an increase in electricity) were also

estim ated using EPA’s Egrid database. The Egrid database summarizes emissions of criteria pollutants on a per electrical usage basis , in terms of pounds emitted per megawatt

- hour (lb/MWh) and on a national average or state average basis. For this analysis the national average

was used. The MACT floor control requirement indicates that two facilities would need to

install TO

, resultin g in supplemental fuel requirements, such as natural gas, to run the TO . The

TO algorithm indicates the amount of fuel needed by each unit. To estimate emissions from combustion of natural gas, emission factors from EPA’s AP

- 42 emi ssion factor document w ere used. Table 5

- 1 summarizes the resulting emissions of CO 2 , CO, NO

x , and SO 2 from combustion of natural gas supplemental fuel and increase electricity usage for MACT floor

control analyzed for existing sources. Table 5

- 2 shows the Egrid and AP

- 42 emis sion fa ctors
used for the calculations.5 Table 5

- 1 . Secondar y Air Pollutant Impacts for Existing Sources

Electricity Requi rements and Emissions a Supplemental Fuel Requir ements and

Emissions a Total Secondary Emissions

MWh/ yr CO 2

Emitted (tons/yr) NO

x

Emitted (tons/yr) SO 2

Emitted (tons/yr) Natural Gas

(ft 3 / yr ) CO 2

Emitted (tons/yr) CO

Emitted (tons/yr) NO

x

Emitted (tons/yr) CO 2 Emitted

(tons/yr) CO

Emitted (tons/yr) NO

x

Emitted (tons/yr) SO 2

Emitted (tons/yr)

5,900 3,921 5.7 15.5 31,510,937 1,891 1.3 1.6 5,811 1.3 7.3 15.5

a. Emissions estimated based on emission factors listed in Table 3. MWh/yr

– Megawatt hours per year Tons/yr

– Tons per year

CO 2 – Carbon dioxide

SO 2 - Sulfur dioxide

Ft 3

– cubic foot

CO

– Carbon monoxide

NO

x – nitrogen oxides

Table 5

- 2 . Emission Factors

Pollutant Electricity a Natural Gas b

(lb/MWh) (lb/10 6 scf) (lb/ft 3 ) (ton/ft 3 )

CO 2 1,329 120,000 1.20E

- 01 6.00E

- 05

CO

- 84 .0 8E

- 05 4.2E

- 08

NO
X 1.9366 100 1.00E

- 04 5E

- 08

SO 2 5.2589

- - -

a. National emission factors from Egrid 5 for EGUs.

b. Natural gas emission factors from AP

- 42. 6

lb/MWh

– pounds per megawatt hour

lb/10 6 scf

– pounds per million standard cubic feet

lb/ft 3

– pounds per cubic foot

ton/ft 3

– tons per cubic foot

CO 2 – Carbon dioxide

SO 2 - Sulfur dioxide

CO

– Carbon monoxide

NO

x – nitrogen oxides6

6.0 References

1. “ MACT Floor Analysis for the Polyvinyl Chloride and Copolymers (PVC) Production Source Category

. ” Memorandum from Eastern Research Group, Inc. (ERG) to Jodi Howard (EPA). April 2011.

2. “ Analysis of Beyond MACT Floor Controls for the Polyvinyl Chloride and Copolymers (PVC) Production Source Category

. ” Memorandum from Eastern Research Group, Inc. ( ERG) to Jodi Howard (EPA). April 2011.

3. “ Cost s and Emission Reduction s of the MACT Floor Level of Control for the Polyvinyl Chloride and Copolymers (PVC) Production Source Category

. ” Memorandum from Eastern Research Group, Inc. (ERG) to Jodi Howard (EPA). April 2011.

4

. EPA eGRID database eGRID2007 Version 1.1. Year 2005 summary tables located at www.epa.gov/cleanenergy/documents/egridzips/eGRID2007V1_1_year05_SummaryTab les.pdf

5

. U.S. Environmental Protection Agency, 1995. Compilation of Air Pollutant Emission Factors (AP

- 42), Fifth Edition, Volume 1: Stationary and Point Sources, Chapter 1:

External Combustion Sources

.