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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 copolymers

(PVC) production units. Secondary impacts result from the generation of steam and/or the 

consumption of fuel, water, and electricity and generation of solid 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 result 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 

(NESHAP) emitted from PVC production facilities. The complete set of regulated 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:
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Additional steam stripping in existing 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 reduce 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 carbon 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, water 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 options, 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 supplemental 

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.
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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

(ft3natural 

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

Ft3– cubic foot

ACI – Activated carbon injection
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4.0 Secondary Impact Estimates for New Units

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

5.0 Secondary Air Pollutant Impacts

Emission factors from EPA’s Egrid4database were used to calculate emissions resulting 

from the electricity required for additional control devices, and emission factors from EPA’s AP42 emission factor document5 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 

(CO2) and criteria pollutants, such as sulfur dioxide (SO2), nitrogen oxides (NOx), and carbon 

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

estimated 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, resulting 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 emission factor document were 

used. Table 5-1 summarizes the resulting emissions of CO2, CO, NOx, and SO2 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 emission factors 

used for the calculations.
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Table 5-1. Secondary Air Pollutant Impacts for Existing Sources

Electricity Requirements and Emissionsa Supplemental Fuel Requirements and 

Emissionsa Total Secondary Emissions

MWh/yr

CO2

Emitted

(tons/yr)

NOx

Emitted

(tons/yr)

SO2 

Emitted

(tons/yr)

Natural Gas 

(ft3/yr)

CO2

Emitted

(tons/yr)

CO 

Emitted

(tons/yr)

NOx 

Emitted

(tons/yr)

CO2 Emitted

(tons/yr)

CO 

Emitted

(tons/yr)

NOx

Emitted

(tons/yr)

SO2 

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

CO2 – Carbon dioxide

SO2 - Sulfur dioxide

Ft3– cubic foot

CO – Carbon monoxide

NOx – nitrogen oxides

Table 5-2. Emission Factors

Pollutant

Electricitya Natural Gasb

(lb/MWh) (lb/106scf) (lb/ft3) (ton/ft3)

CO2 1,329 120,000 1.20E-01 6.00E-05

CO - 84.0 8E-05 4.2E-08

NOX 1.9366 100 1.00E-04 5E-08

SO2 5.2589 - - -

a. National emission factors from Egrid5for EGUs.

b. Natural gas emission factors from AP-42.6

lb/MWh – pounds per megawatt hour

lb/106scf – pounds per million standard cubic feet

lb/ft3– pounds per cubic foot

ton/ft3– tons per cubic foot

CO2 – Carbon dioxide

SO2 - Sulfur dioxide

CO – Carbon monoxide

NOx – nitrogen oxides
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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. “Costs and Emission Reductions 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.