, TO:
,, FROM:

~ MEMORANDUM Group 

### IV Resins Docket, A-92-45 Kenneth R. Meardon Pacific Environmental Services, Inc. DATE: SUBJECT: Purpose April 10, 1996 Re'Evaluation of Equipment Leak Emissions and Costs at PET Facilities The purpose of this memo is to present the results of the re-evaluation of emission estimates and costs associated with the equipment leak program proposed for poly(ethy1ene terephthalate). (PET) production facilities. This memo is divided into two major sections as follows: 

### 1.
. Emission Factors and Estimates 2. Cost and Cost Effectiveness Estimates The memo concludes with two attachments: Attachment A shows the formulas used to cost the equipment leak programs at proposal and revised formulas usedin the revised analysis. Attachment 

### B presents the revised individual spreadsheets for each facility showing the estimated emission reductions and equipment leak program costs for the current program (if any) and the proposed standard 

### (HON) program. Emission Factors and Estimates c .- Based on comments received on the proposed rule, the emission factors used to estimate emissions from components at these facilities were re-examined and, in some instances, revised. Table 1 summarizes the previous emission factors used (i.e., those used before proposal, which were the average uncontrolled SOCMI emission factors) and the revised emission factors (i.e., those used after proposal in the re-analysis).TABLE 1 COMPARISON OF EMISSION FACTORS (lbs/hr/component) FOR COMPONENTS AT 

### PET FACILITIES Emission Factors (Ibs/hr/component) Component Average Uncontrolled Revised SOCMI Uncontrolled Valve, gashapor 0.0131 0.0131 Valve, light liquid 0.00887 0.00887 Valve, heavy 'liquid 0.000506 0.000506 Pump, light liquid 0.0438 0.0438 Pump, heavy liquid 0.0190 0.00463 Pressure relief device, gas vapor 0.2288 0.2288

~~~~ ~~~~ ~ Pressure relief device, light liquid 0.2288

~~ Pressure relief device, heavy liquid 0.2288 0.09852 Open-ended line, gashapor and light 0.00374 0.00374 liquid Open-ended line., heavy liquid 0.00374 0.0033 Compressors 0.5016 0.5016 Sampling connection, gashapor and 0.033 0.033 light liquid Sampling connection, heavy liquid 0.033 0.015 Flange, gashapor and light liquid 0.00403 0.00403 Flanges, heavy liquid 0.00403 0.00018

2rs rt 1. As seen in Table 1, the emission factors were lowered for all components in heavy liquid service (i.e., in ethylene glycol service) except valves. In general, for components in heavy liquid service other than valves, the revised uncontrolled emission factors are the 

### < 10,000 ppm SOCMI emission factors (see page 2-16 in "Protocol for Equipment Leak Emission Estimates, 'I EPA-453/R-93-026; June. 1993) (1993 Protocol document). For pressure relief devices (PRDs), the 

### < 10,000ppm emission factor for PRDs in gas service was applied to PRDs in liquid service (light or heavy). Although the 1993Protocol document does not di€ferentiate between typesof services for sampling connections, an emission factor for sampling connectionsin heavy liquid service was assigned and was assumed to be the same as for open-ended lines in heavy liquid service. The emission factor for valves in heavy liquid service did not change becausethere is 

### no reported difference in values for the 

### > 10,000 ppm SOCMI emission factor and the 

### < 10,000ppm SOCMI emission factor in the 1993Protocol document. Table 2 compares the estimates of current emissions from equipment leaks for each of - the subcategories from the analysis prior to the proposal with the estimates of current emissions using the revised emission factors in the,re-analysis. Table 3 compares the emission estimates 

### on an individual facility basis. TABLE 2 COMPARISON OF EMISSIONS AND EMISSION REDUCTIONS Emissions Emission Reductions Subcategory (Mg/yr) (Mg/yr) Previous Revised Previous Revised TPA, Continuous 704 903 1,034 2,150 DMT, Continuous 2.7 5.6 22 90 TPA, Batch 113b 473a 345b 2,030a DMT, Batch 1,136 1,790 1,931 5,460 TOTALS 316 408 530 1,190
a Includes the AlliedSignal facility. Does not include the AlliedSignal facility.

31

TABLE COMPARISON 

### OF EQUIPMENT 

### L AT PROPOSAL AND W

OMPANY 

### I POLYMER 

### 1 PRC

3M

### -Decatur PET -DMT Batch 3M

### - Greenville PET -DMT Batch EK - Rochester PET -DMT Batch Shell-Pt. Pleasant PET -DMT Batch h7;_ -Kingsnort PET - DMT kontir HC - Spartanburg PET

### - DMT bontin CE- Columbia PET- DMT kontir PuPont

### - Circleville PET-DMT ,kontir DuPont

### - Cooper River PET-DMT Contir DuPont-Florence PET - DMT Contir 3uPont- Kinston PET

### - DMT Contir PuPont

### - Old Hickory PET

### - DMT Fontir

ellman yI(K PET-TPA bontir HC

### - Spartanburg PET

### - TPA kontir CE

### - Columbia PET -TPA /Contir

~~~ DuPont

### - Cooper River PET -TPA Contir DuPont

### - Kinston PET 

### -TPA Contir KC - Salisburv
~PET-TPA Contir PuPont

### - Cape Far PET- TPA bontir

C- Greer bhell

## -Pt. pleasant PET

### -TPA patch



### 4 5 3AK 

### EMISSION ESTIMATES 

### TH REANALYSIS 

### I Previous 

### 1 Revised !EPAEstimate hPA Estimate ESS OfCurrent OfCurrent Emissions Emissions (Mdyr) (Mdyr) 364.5

### 1

. 196.0 154.4

### I 68.1 I 121.41 57.0 1 167.5 58.5 162.9 30.0 189.3 19.6 74.9 33.5 36.6 37.8 225.2 133.1 228.2 93.8 458.5 212.2 120.4 104.0 223.5 109.3 156.5 75.3 144.5 69.6 )US 456.5 218.9 >us 29.3 14.1 )US 120.8 ' 34.3 IUS 437.6 92.3 )US 23.2 12.4 )US 75.7 7.9 230.0 163.2 147.I 30.9 432.5 50.5 113.2 23.6 121.3 83.4 87.3 21.9 ,Cost and Cost-Effectiveness Estimates costs In re-examining the proposed standards, PES discovered a number of errors in the formulas used to estimate costs. These are "errors" in that the formulas used to estimate costs did not correspond to the algorithms usedto develop the equipment leak program costs for 

### the HON equipment leak program. Attachment A contains printouts of the formulas in the original spreadsheets used before proposal and in the revised spreadsheets usedafter proposal. The following paragraphs summarize the changes made to the formulas in the spreadsheets. Initial 

### LDAR Costs and Capital Costs. The costs for pumps, valves, and connectors should include costs for repairing leakers during the initial component survey. The cost algorithms in the analysis for the proposed rule did not include these initial repair costs. They have been added in the revised costing spreadsheets. This change increases the estimated costs. Annual Maintenance Costs. -Anerror in the formula for pumps was discovered in that the formula was "hard-wired'' for "subsequent leak frequency" and for "percent requiring further repair. 'I The revised spreadsheets now cross-reference the appropriate cells. This change decreases estimated annual maintenance costs. Leak Repair Costs. As for annual maintenance costs, the formula for leak repair costs for pumps was "hard-wired"for "subsequent leak frequency" and "monitoring frequency. I' The revised spreadsheets now cross-reference the appropriate cells. This change decreases estimated leak repair costs. Administrative Costs. Although no changes were made 

### to the formulae, these costs decreased _.-* as the result of the decreasein costs for annual maintenance and leakrepair. Replacement Pump Seals. The original spreadsheet overlooked these costs, which have been added to the revised spreadsheets. This change increases estimated capital costs. Annualized Capital Costs. A few formula errors were discovered in this equation. The annualized costs for pumps, valves, and connectors were corrected. For example, the original spreadsheet had an incorrect cross-referenced cell for connectors. A factor for replacement pump seals was added. The net effect is to increase annualized capital costs. Table 4 compares the previous and revised estimated costs for each subcategory. For both analyses, total costs for each subcategory were estimated usingeither company provided component profiles (i.e., the number of components in each type of service) or estimating component profiles for those facilities that did not provide component profile information. Attachment 

### B presents for each facility the detailed revised cost sheets for the HON program and, if there is one, for the current equipment leak programfor the facility. \ 5TABLE 4 COMPARISON 

### OF ANNUAL COSTS Annual Costs ($) I Subcategory Previous Revised TPA. Continuous 744,OOOa 184, 600b TPA, Batch 17,700 2,140 

### DMT, Continuous 

### 988,000 25 1,300 I I I I 

## I DMT, Batch 569,000 

## I 216,900 

# I a Includes the AlliedSignal facility. Does not include the AlliedSignal facility.
Cost-Effectiveness Estimates At proposal, the cost effectiveness was calculated for each facility. Since only a few facilities provided specific equipment componentcounts, many assumptions were made as to the counts,at the other facilities. The cost effectiveness of the proposed equipment leak program was then evaluated for the entire subcategory. After proposal, the cost effectiveness has been calculatedfor only those facilities that provided specific component profiles. Table 

### 5 presents the results of the cost-effectiveness caIculations for each of the subcategories based

### on the facilities that provided specific component counts using the revised emission estimates and costs. Table 6 sumarizes the cost effectiveness for all facilities in each of the subcategories using the revisedemission estimates and costs.

.6TABLE 

### 5 REVISED COST EFFECTIVENESS RESULTS FOR PET FACILITIES Number of Emission Subcategory Facilitiesa Reductions, Mg/yr TPA, contiquousb TPA, Continuousc 

### 5 49.8 1 1.15 DMT, Continuous 3 300 DMT, Batch 4 198 Annual Cost Effectiveness, Costs, $ 

### $/Mg

75,913 1,524

7,045 6,126 98,050 611 121,000 327
a 

### . These numbers reflect the number of facilities that provided facility-specific information on the number of components 

### and their type of service. It does not reflect the total number 

### of facilities 

### in the subcategory. All TPA continuous facilities except high viscosity PET with multiple end finishers. C TPA continuous.facilitiesproducing high viscosity PET with multiple end finishers. TABLE 6 REVISED ANNUAL COSTS AND COST EFFECTIVENESS, BY SUBCATEGORY

Subcategory Annual Costs, Cost Effectiveness, Emission Reduction, $ $/Mg Mg/yr TPA, Continuousa 184,600 1,620 113 TPA, continuousb 7,045 6,126 1.15 TPA, Batch 

## I 2,140 

## I 2.7 

## I 792 

## I DMT, Continuous 251,300 686 316 DMT, Batch 216,900 357 704 a All TPA continuous facilities except high viscosity PET with multiple end finishers. TPA continuous facilities producing high viscosityPET with multiple end finishers.ATTACHMENT A PRINTOUTS OF FORMULAS 

### USED TO CALCULATE 

### EMISSION 

### LEAK PROGRAM COSTS,. , l

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