, 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 used in 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 quid 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 

2 
rs 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 < 10,000 ppm emission factor for PRDs in gas service 

was applied to PRDs in liquid service (light or heavy). Although the 1993 Protocol 

document does not di€ferentiate between types of services for sampling connections, an 

emission factor for sampling connections in 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 because there is no reported difference in 

values for the > 10,000 ppm SOCMI emission factor and the < 10,000 ppm SOCMI 

emission factor in the 1993 Protocol 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 

DMT, Continuous 2,150 1,034 903 704 

Batch 90 TPA, 22 5.6 2.7 

2,030a 473a 345b 1 13b 

DMT, Batch 

TOTALS 5,460 1,790 1,931 1,136 

1,190 530 408 316 

a Includes the AlliedSignal facility. 

Does not include the AlliedSignal facility. 

3 
1 

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 

!EPA Estimate hPA Estimate 

ESS Of Current Of Current 

Emissions Emissions 

(Mdyr) (Mdyr) 

364.5 1 . 196.0 

154.4 I 68.1 

I 121.4 1 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 used to 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 used after 

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. -An error 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 decrease in costs for annual maintenance and leak repair. 

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 using either 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 program for the facility. \ 

5 
TABLE 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 component counts, 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 calculated for 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 revised emission 

estimates and costs. 

.6 
TABLE 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 

121,000 611 

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.facilities producing high viscosity PET with multiple end finishers. 

TABLE 6 

REVISED ANNUAL COSTS AND COST EFFECTIVENESS, BY SUBCATEGORY 

Subcategory Annual Costs, Emission Reduction, Cost Effectiveness, 

$ Mg/yr $/Mg 

TPA, Continuousa 1 84,600 113 1,620 

TPA, continuousb 7,045 1.15 6,126 

TPA, Batch I 2,140 I 2.7 I 792 I 

DMT, Continuous 251,300 

DMT, Batch 216,900 3 16 686 

704 357 

a All TPA continuous facilities except high viscosity PET with multiple end finishers. 

TPA continuous facilities producing high viscosity PET with multiple end finishers. 
ATTACHMENT A 

PRINTOUTS OF FORMULAS USED TO CALCULATE 

EMISSION LEAK PROGRAM COSTS 
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