MEMORANDUM

DATE: January 31, 2014

SUBJECT: Supplemental Technology Review for Equipment Leaks in Group IV Polymers

and Resins, Pesticide Active Ingredient Production, and Polyether Polyols Production Source Categories

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

TO: EPA Docket File (EPA

- HQ

- OAR

- 2011

- 0435 )

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. Thes e technology

based standards are often referred to as maximum achievable control technology (MACT)

standards. Section 112 also contains provisions requiring the EPA to periodically revisit these standards. Specifically, section 112(d)(6) states:

(6) REVIE W 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 three NESHAP: Group IV Polymers and Resins (P&R IV) under 40 CFR part 63, subpart JJJ ( subpart JJJ ), Pesticide Active Ingredient Production (PAI) under 40 CFR part 63, subpart MMM (subpar t MMM), and Polyether Polyols Production (PEPO) under 40 CFR part 63, subpart PPP (subpart PPP). Based on this technology review, the EPA proposed rule revisions to subparts JJJ, MMM, and PPP on January 9, 2012. Comments were received indicating that the E PA was deficient in its technology review and identified the following as improvements in technologies that EPA should consider for equipment leaks:

the use of low

- leak technologies; the use of passive optical gas imaging (OGI) devices; lowering the leak definition for valves, connectors and other equipment to 100 ppm and lowering the leak definition for pumps, compressors, and pressure relief devices to

500 ppm ; and requiring tighter timelines of minimization of leaks within 24 hours of identification an d repairs within seven days.

The purpose of this memorandum is to provide a supplemental technology review to address any deficiencies with the original technology review as expressed by the commenters.2

2.0 REVISED TECHNOLOGY REVIEW FOR EQUIPMENT LEAKS

Equipment leaks are emissions emanating from pumps, compressors agitators, pressure relief devices, sampling connection systems, open

- ended valves or lines, valves, connectors or 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.

This section presents the supplemental technology review conducted for equipment leaks in the P&R IV, PAI , and PEPO source categories. Section 2.1 presents a summary of the level of control required by the current MACT standards. Section 2.2 presents an analysis of each of the improvements in technologies for reducing equipment leak emissions that were identi fied by commenters to determine whether they are appropriate and cost effective for these source categories under section 112(d)(6).

2.1 Summary of Existing MACT Level of Control

For each of the source categories, each piece of equipment subject to the standards is required to comply with the provisions of 40 CFR part 63, subpart H. The relevant provisions of part 63 subpart H are as follows:

Valves in gas and vapor service: conduct monthly EPA Method 21 monitoring; leak definition of 500 ppm. Pumps in light liquid service: conduct monthly EPA Method 21 monitoring; leak definition of 1,000 ppm (repair required at 2,000 ppm). Connectors: sensory monitoring. Pressure relief devices (PRD) in gas/vapor service: operate with no detectable emissions (i.e., les s than 500 ppm) or equip with a rupture disk / or route to an air pollution control

device. Open

- ended lines (OEL) or valves: equip with a sealed cap or comparable device.

2.2 Evaluation of Potential Developments in Technology for Equipment Leaks

Based on comments received on the proposed amendments to subparts JJJ, MMM and PPP, the following control options were evaluated:

the use of low

- leak technologies; lowering the leak definition for valves, connectors and other equipment to 100 ppm and lowering the leak definition for pumps, compressors, and pressure relief devices to

500 ppm ; and requiring tighter timelines for minimization of leaks to within 24 hours of identification and repairs within seven days.

We did not evaluate the use of OGI devices, since the General Provisions for NESHAP at 40 CFR 63.11(c) through (e) already allows the use of OGI with an annual EPA Method 21 survey3

of all of the equipment as an alternative work practice to the traditional leak detection and repair (LDAR) monitoring program (e.g., EPA Method 21).

2.2.1 Model Plants for the P&R IV, PAI, and PEPO Source Categories

Cost estimates and emissions reductions for these control options were estimated using a model plant approach t o represent equipment counts found at different types of chemical and refining

facilities.

For the P&R IV source category, no information was readily available regarding component counts of model plants that were used for equipment leaks at facilities wi th P&R IV process units. As a result, it was assumed that the P&R IV source category could be best represented by the simple, medium, and complex model plants developed for the chemical industry. 1 Table 1 presents the model plant component counts for estim ating equipment leak impacts from the P&R IV source category.

For the PAI and PEPO source categories, model plant equipment component counts were developed for the original MACT standards and are also presented in Table 1. 2

, 3 For each model plant, the ty

pes of equipment included in this analysis are as follows: pumps in light liquid service; valves in gas/vapor and light liquid service; connectors in gas and light liquid service; pressure relief devices (PRDs); and open ended lines (OELs).

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

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

- HQ

- OAR

- 2010

- 0869

- 0029.

2 Memorandum from Randall, D. and Karen Schmidtke, Midwest Research Institute to Banker, L., EPA/OAQPS. Model Plants for the Pesticide Active Ingredient Manufacturi ng Industry. April 30, 1997. (included in the Supplementary Information Document (SID) for the PAI Proposed NESHAP)

3 Memorandum from Hendricks, D. and Joanne Seaman, EC/R Incorporated to Svendsgaard, D., EPA/OAQPS. Estimated Impacts for the Polyether Poly ols NESHAP. April 25, 1997. (included in the Supplementary Information Document (SID) for the PEPO Proposed NESHAP)4

Table 1. Mod el Plants for the P&R IV, PAI, and PEPO 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 Pumps (light liquid service) 15 40 56 14 33 2 13 5

Valves (gas/vapor service) 77 414 1,379 65 240 125 3 57

Valves (light liquid service) 380 1,179 1,980 340 1,100 166 392 218

Connectors (light liquid service) 731 2,662 7,410 1,100 1,500 409 385 219

PRDs 2 45 76 2 a 45 a 8 11 34

OELs 33 141 424 33 a 141 a 0 7 58

a No PRDs or OELs were included in model plants in the analysis for the original MACT standards. I t was assumed

that the number of PRDs and OELs at batch and continuous plants would best be represented by the simple and medium model plants developed for the chemical industry

.

2.2.2 Number of Facilities Represented by Each Model Plant Type

For each source category, the current number of facilities that would be represented by each of the model plant types was unknown. Therefore, the number of facilities represented by each type of model plant was assigned for the purposes of this analysis. Table 2 presents the distributi on of the currently identified facilities across the P&R IV, PAI, and PEPO model plants.

From documentation created during development of the P&R IV MACT standards, no information was found regarding the distribution of facilities across model plant types

. Therefore, it was assumed that there would be a relatively even distribution of the currently identified facilities across the model plants as follows: 33 percent of facilities would be represented by the simple model plant, 34 percent of facilities woul d be represented by the medium model plant, and 33 percent of facilities would be represented by the complex model plant.

During the development of the PAI MACT standards, 175 facilities were identified. 138 were represented by the batch model plant (79 p ercent), and 37 were represented by the continuous model plant (21 percent). The 18 currently identified PAI facilities were distributed across the batch and continuous model plants in the same proportions. As a result, it was estimated that

there are 14 c urrently identified facilities represented by the batch model plant and 4 represented by the continuous model plant.

For the PEPO source category, during the development of the MACT standards, there were 77 facilities identified in the source category. Tw enty were represented by small model plants (26 percent of the total facilities), 38 were represented by large model plants (49 percent of the total facilities), and 19 were represented by solvent extraction model plants (25 percent of the total

facilities ). The 23 currently existing facilities were distributed across the three model plants in5

the same proportions. Therefore, 6 are represented by the small model plant, 11 are represented by the large model plant, and 6 are represented by the solvent extract ion model plant.

Table 2. Distribution of Currently Identified Facilities Across Model Plants for the

P&R IV, PAI, and PEPO Source Categories

P&R IV Model Plants PAI Model Plants PEPO Model Plants

Simple Medium Complex Total Batch Continuous Total Small Large Solvent

Extraction Total

Number of

facilities during

MACT development Unknown a 138 37 175 20 38 19 77

Percent of

Total b 33 34 33 100 79 21 100 26 49 25 100

Number of currently

identified

facilities c 10 11 10 31 14 4 18 6 11 6 23

a No information was readily available regarding the model plants for the P&R IV source categories.

b An even distribution across model plants for P&R IV source categories was assumed.

c Number of currently identified facilities in each model plant categor y estimated by distributing according to percentage of facilities assumed to be in each category during MACT development.

2.2.3 Analysis of Low

- Leak Packing

Low

- leak packings for valves that significantly reduce emissions are in place in some facilities outside the P&R IV, PAI, and PEPO source categories, particularly at oil refineries. 4 Facilities and packing manufacturers have created emission testing protocols for low leak packings in order to study and test their effectiveness. 5 We analyzed the emissi ons reductions and costs that would be associated with requiring low

- leak valve technology for the P&R IV, PAI, and PEPO source categories.

To determine the baseline emissions from valves, we used the valve component counts for model plants (see Table 1) and applied emission factors to determine the baseline emissions. The emissions factors used were based on those used in a recent technology review for equipment leaks from chemical manufacturing process units and petroleum refineries (Uniform Standards

an alysis) 6 , 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 synthetic organic chemical manufacturing industry (SOCMI) subject to the Hazardous Organic NESHAP (HON) (71 FR 34434), HAP emissions were assumed to represent 56 percent of the total VOC em issions from the facilities subject to

the HON. While we have no information about the HAP to VOC ratio for the P&R IV, PAI, and

PEPO source categories, we assumed that the HAP to VOC ratio would be similar to that of

4 See Reference 1.

5 See Reference Error! Bookmark not defined.

. 6 See Reference 1.6

HON facilities, and we applied this ra tio to the equipment leak emissions factors used in the Uniform Standards analysis. The resulting emissions factors that were used for the P&R IV, PAI,

and PEPO source categories are shown in Table 3.

Table 3. Equipment Leak Emission Factors by Component Type

Component Type Emission Factor (kg/hr/component) a Emission factor adjusted for HAP (kg/hr/component) b
Valves in Gas/Vapor Service 2.03E

- 04 1.14E

- 04 Valves in Light Liquid Service 2.32E

- 04 1.30E

- 04

a See Table 6 of Reference 1.

b Emission factors adjusted to reflect the estimated HAP to VOC ratio (56%).

According to information used to estimate costs for low

- leak valves for HON facilities, the

installed cost of a low

- leak valve averaged $12,025 each, and the total capital investm ent and total annualized costs are proportional to the number of valves. 7 Therefore, assuming that emissions from valves are constant and that the cost per valve is constant, we calculated the capital and annual costs, along with the cost per ton of HAP re duction that would be associated

with these low

- leak valves for the P&R IV, PAI, and PEPO source categories. For this analysis,

it was assumed that low

- leak valves would achieve a 100 percent reduction in HAP emissions

from valve leaks.

As shown in Table 4, the estimated baseline HAP emissions from valves at the P&R IV, PAI, and PEPO model facilities ranged from 0.34 to 4 tons per year (tpy). Applying the cost per valve to the number of valves at these model facilities, estimated capital costs per facility ranged from $4.4 million to over $50 million, with annualized capital costs ranging from $600,000/year to over $7 million/year. Emission reductions were assumed to be 100 percent of the baseline emissions and were estimated to range from 0.34 to 4 tpy per model facility, and the cost effectiveness ranged from $1.71 million/ton to $1.80 million/ton of HAP reduction. On a source category basis, the estimated baseline HAP emissions from valves at facilities in the P&R IV, PAI, and PEPO source categories ranged from 10 to 67 tpy. Estimated capital costs per source category ranged from $117 million to $839 million, with annualized capital costs ranging from
$17 million to $119 million/year. Emission reductions were estimated to range from approximately 10 to 67 tpy per source category, and the cost effectiveness ranged from $1.74
million/ton to $1.78 million/ton of HAP reduction.

7 Memorandum from Oommen, R., ERG, Morrisville, NC, to McDonald, R., U.S. Environmental Protection Agency, OAQPS. Cost and Emission Reduction of Leakless Valves for HON facilities. June 1, 2006. Docket No.

EPA

- HQ

- OAR

- 2005

- 0475

- 01057 Table 4. Low

- Leak Valves Cost Analysis

a Calculated using emission factors adjusted for a HAP to VOC ratio of 56 percent, see Table 3 and Appendix 1 of this memorandu m.

b Based on model plants for each source category, see Table 1 of this memorandum.

c No cost basis for these values was presented in the SOCMI memorandum . Therefore, it was assumed that these costs were presented in 2005 dollars, and the cost per valve of $12,025 was adjusted to 2012 dollars using the Chemical Engineering Plant Cost Index (CE Index). The CE Index for 2 005 is 468.2 and is 586.4 for 2012.

d Includes capital costs plus a recovery credit of $500 per ton of HAP not emitted.

e Assumes 100 percent reduction in emissions.

f Cost effectiveness varies depending on the proportion of valves in gas/vapor service and the number in light liquid service.

g Estimated number of plants of each model plant types in the source category, see Table 2 of this memorandum.8

2.2.4 Reduced Leak Definitions

As stated above, facilities with processes in the P&R IV, PAI , and PEPO source categories are subject to the part 63, subpart H requirements. We analyzed the emissions reductions and costs that would be associated with requiring leaks to be repaired at lower detection limits for these source categories, consistent w ith some local or regional regulations, such as those of California’s Bay Area Air Quality Management District (BAAQMD). Table 5 presents a summary of the current equipment leak requirements and the options that were analyzed on a component basis.

Table 5 . Summary of Equipment Leak Requirement Options

Type of Equipment Requirements of P&R IV, PAI, and

PEPO MACT Standards a Alternative Option Investigated Pumps

– light liquid

service Monthly EPA Method 21 monitoring; leak definition of 1,000 ppm (repair not required until instrument reading of 2,000 ppm is reached) Same as current requirements but with lower leak definition of 500 ppm

Valves

– gas and light liquid service Monthly EPA Method 21 monitoring;

leak definition of 500 Same as current requireme nts but with lower leak definition of 100 ppm

a Represents compliance with part 63, subpart H.

To determine the baseline emissions from valves and pumps, we used the valve and pump component counts for model plants (see Table 1) and applied emission factors to determine the

baseline emissions and another set of emission factors to determine emissions at the more stringent leak definition levels. The emission factors used were based o n those used in the Uniform Standards analysis but modified to reflect the amount of VOC that are expected to be HAP, as discussed previously. The resulting emissions factors that were used for the P&R IV, PAI, and PEPO source categories in this analysis a re shown in Table 6.

Table 6. Equipment Leak Emission Factors by Component Type at Baseline and with More Stringent Leak Definitions

Component Type Baseline Emission Factor (kg/hr/component) a Emission Factor with More Stringent Leak Definition (kg/hr/co mponent) a Valves in Gas/Vapor Service 1.14E

- 04 1.14E

- 04 Valves in Light Liquid Service 1.30E

- 04 1.30E

- 04 Pumps in Light Liquid Service 3.89E

- 04 2.97E

- 04

a Emission factors from Table 6 of Reference 1, adjusted to reflect the estimated HAP to VOC ratio (56%).

Costs were determined for the valve and pump equipment leak baseline conditions and for the options for each model plant type for the P&R IV, PAI, and PEPO source categories based on information from the Uniform Standards analysis. Initial and ongoing monitoring costs were determined for the baseline LDAR program for these components and for a program with more stringent equipment leaks definitions. See Appendix 2 for detailed cost information.

As shown in Table 7, the estimated baseline HAP emissions from valves at the P&R IV, PAI, and PEPO model facilities ranged from 0.34 to 4.0 tpy. Estimated annual costs per facility9

ranged from $3,800/yr to over $ 81,000/yr. Emission reductions were approximately 11 percent of the baseline emissions and were estimated to range from 0.03 to 0.45 tpy per model facility, and the cost effectiveness ranged from $15,000/ton to $18,000/ton of HAP reduction, which

varied de pending on the proportion of valves in gas/vapor service and the number in light liquid service. On a source category basis, the estimated baseline HAP emissions from valves at facilities in the P&R IV, PAI, and PEPO source categories ranged from 10 to 67 tpy. Estimated annual costs ranged from $17,000/yr to $132,000/yr. Emission reductions were estimated to range from 1.1 to 7.5 tpy per source category, and the cost effectiveness ranged from $16,000/ton to $18,000/ton of HAP reduction.

For pumps, as shown in Table 7, the estimated baseline HAP emissions at the P&R IV, PAI, and PEPO model facilities ranged from 0.01 to 0.21 tpy. Estimated annual costs per facility ranged from approximately $300/yr to over $14,000/yr. Emission reductions were approximately 2 4 percent of the baseline emissions and were estimated to range from 0.002 to 0.05 tpy per model facility, and the cost effectiveness was approximately $29,000/ton of HAP reduction in each case. On a source category basis, the estimated baseline HAP emissi ons from pumps at facilities in the P&R IV, PAI, and PEPO source categories ranged from 0.08 to 0.4 tpy. Estimated annual costs ranged from $5,000/yr to $30,000/yr. Emission reductions were estimated to range from 0.16 to 1 tpy per source category, and the cost effectiveness was approximately $29,000/ton of HAP reduction for each source category.10 Table 7. Reduced Leak Definitions Cost Analysis

a Based on model plants for each source category, see Table 1 of this memorandum.

b Calculated using emission factors adjusted for a HAP to VOC ratio of 56 percent, see Appendix A of this memorandum.

c Estimated number of plants of each model plant types in the source category. See Table 2 of this memorandum.

d Includes a recovery credit of $500/ton of HAP not emitted.11

2.2.4 Limits on the Number of Components Awaiting Repair

The BAAQMD Regulation 8, Rule 18 limits the number of components awaiting repairs to

0.3 percent for valves, 0.025 percent for valves with major leaks (i.e., leaks greater than 10,000 ppm, including methane) and 1.0 percent for pumps and compressors. The BAAQMD also requires mass emission testing for non

- repairable components with high leak rates and places an emission limit of 15 lbs/day on non

- re pairable components. A similar rule in place for California’s South Coast Air Quality Management District (SCAQMD), Rule 1173, has limits for the number of components awaiting repairs of 0.5 percent for valves and 1.0 percent for pumps. As stated above, fa cilities with processes in the P&R IV, PAI, and PEPO source categories are subject to the part 63, subpart H requirements. These requirements allow a delay of repair for all components, under certain conditions, until the next process shutdown.

Background data for the proposed amendments to the BAAQMD Regulation 8 Rule 18 provides incremental costs associated with their amendment that lowers the number of components awaiting repairs from 0.5 percent for valves and 1.0 percent for pumps, compressors, and

pr essure relief devices to 0.3 percent for valves and 1.0 percent for pumps, compressors, and pressure relief devices. 8 The BAAQMD analysis was conducted for five refineries located in the Bay Area. The estimated reduction in VOC emissions from the Regulatio n 8 Rule 18 amendments over that of the current requirements was 73 tpy (or 43 percent). 9 In this analysis, the BAAQMD estimated that an incremental total annualized cost associated with their amendment ranged from $34,000 to $172,000/yr per facility. 10 The se costs are primarily related to the annual costs of conducting mass emission rate determinations and the cost to capture and control valves with excessive leaks. The BAAQMD estimated that the mass emission rate determinations would apply to 60 valves per facility (or about 0.13 percent of the average number of valves at a facility) and estimated that the annualized cost of conducting the mass emission rate determinations would be range from $20,000 to $114,000/yr, 11 with the midpoint of the range at $67,0 00/yr or $1,120/yr/valve. Of these 60 valves, the BAAQMD assumed that about 0.0025 percent of the total number of valves would be required to be controlled, or 2 valves per facility. The estimated annual cost of controlling these valves ranged from $15,000 to $58,000/yr per facility, 12 with a midpoint of $36,500 per year or $18,250/yr/valve.

We applied the BAAQMD approach to the P&R IV, PAI, and PEPO source categories model plants (see Table 1), assuming the BAAQMD incremental emissions reductions an d costs would apply to these source categories. The results of this analysis are presented in Table 8. As shown in Table 8, the annualized cost associated with mass emission rate determinations for the P&R IV, PAI, and PEPO source categories was estimated to range from $1,120/yr to $5,600/yr and the

annualized cost associated with control of valves with excessive leaks for each of the model plants was $18,250/yr. The total program annualized cost ranged from $19,000/yr to 24,000/yr.

The cost effectiveness r anged from $10,500/ton HAP reduction to $99,000/ton HAP reduction.

8 Doug las, Victor, Compliance and Enforcement Division, BAAQMD. Draft Staff Report: Proposed Amendments Regulation 8 Rule 18: Equipment Leaks Control Measure SS

- 16. December 2003.

9 In the draft staff report (see reference 8) emissions reductions were reported a s “organic emissions,” which we

assume to be VOC.

10 BAAQMD Costs were assumed to be in 2003 dollars. Costs escalated to 2012 dollars using the Chemical Engineering Plant Cost Index. CE Index for 2003 is 402 and for 2012 is 584.6.

11 See Reference 8.

12 See Reference 8.12

Table 8 . Analysis of Applying the BAAQMD Approach for Controlling Valves with Excessive Leaks to the P&R IV, PAI, and PEPO Source Categories

a See Table 2 for model plant parameters (i.e., component count).

b Rounded up to the nearest whole number of valves.

c Costs presented in BAAQMD draft staff report (See Reference 8) were escalated to 2012 dollars.

d Calculated by multiplying the cost per valve from the BAAQMD estimate t o the number of valves in each model plant.

## Appendix 1

Detailed Baseline Valve Emissions Estimation Information for P&R IV,

PAI, and PEPO Source CategoriesA1

- 1 P&R IV Baseline Emissions

Type of Equipment Emission Factor (kg/hr/component) Model Plant 1

- Simple Model Plant 2

- Medium Model Plant 3

- Complex

Baseline* No. of

Components Baseline

Emissions (tpy) No. of

Components Baseline

Emissions (tpy) No. of

Components Baseline

Emissions (tpy)

Valves
Gas/Vapor Service 1.14E

- 04 77 0.08 414 0.45 1,379 1.51

Light Liquid Service 1.30E

- 04 380 0.48 1,179 1.48 1,980 2.48

Valves Total 0.56 1.93 4.00

PEPO Baseline Emissions

Type of Equipment Emission Factor (kg/hr/component) Model Plant 1

- Small Model Plant 2

- Large Model Plant 3

- Solvent

Extraction

Baseline* No. of

Components Baseline

Emissions (tpy) No. of

Components Baseline

Emissions (tpy) No. of

Components Baseline

Emissions (tpy)

Valves
Gas/Vapor Service 1.14E

- 04 125 0.14 3 0.00 57 0.06

Light Liquid Service 1.30E

- 04 166 0.21 392 0.49 218 0.27

Valves Total 0.35 0.50 0.34A1

- 2 PAI Baseline Emissions

Type of Equipment Emission Factor (kg/hr/component) Model Plant 1

- Batch Model Plant 2

- Continuous

Baseline* No. of

Components Baseline

Emissions (tpy) No. of

Components Baseline

Emissions (tpy)

Valves
Gas/Vapor Service 1.14E

- 04 65 0.07 240 0.26

Light Liquid Service 1.30E

- 04 340 0.43 1,100 1.38

Valves Total 0.50 1.64

*Baseline emission factor represents emissions after 40 CFR part 63 subpart H controls. Emission factor is for total organic compounds (TOC) from Table 6 of the Memorandum from Hancy, C., RTI International, to Howard, J., EPA/OAQPS. Analysis of Emission Reduction Techniques for Equipme nt Leaks. December 21, 2011. EPA

Docket No. EPA

- HQ

- OAR

- 2010

- 0869

- 0029, and it is assumed that t he TOC is VOC, and 56% of this is HAP based on the HON RTR proposal (National Emission Standards
for Hazardous Air Pollutants for Organic Hazardous Air Pollutants from the Synthetic Organic Chemical Manufacturing Industry: Proposed Rule. 71 FR 34422, June 14, 2006.).

## Appendix 2

Detailed Cost Information for P&R IV, PAI, and PEPO LDAR Program with Reduced Leak Definitions for Valves and PumpsA2

- 1A2

- 2A2

- 3A2

- 4A2

- 5A2

- 6