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TECHNICAL MEMORANDUM

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

Chemicals Group

FROM: Eastern Research Group, Inc.

DATE: April 11, 2011

SUBJECT: Analysis of Beyond MACT Floor Controls for the Po lyvinyl Chloride and

Copolymers (PVC) Production Source Category

1.0 Introduction

The U.S. Environmental Protection Agency (EPA), under sect ion 112 of the Clean Air

Act (CAA), is required to establish emissions standards f or Hazardous Air Pollutants (NESHAP)

emitted from polyvinyl chloride and copolymers (PVC) producti on facilities. The complete set

of regulated HAP is listed in CAA section 112(b). To do s o, EPA must first determine the

minimum stringency “floor” requirements. A previous memo randum documents the maximum

achievable control technology (MACT) floor analysis for existing and new PVC units. 1



# EPA must also examine more stringent “beyond-the-floor” (BTF) regulatory options to

determine MACT. Unlike the minimum stringency requirement s of the floor, EPA must

consider various impacts of the more stringent regulat ory options such as costs and emissions

reductions in determining whether MACT standards are to ref lect BTF requirements. This

memorandum describes the cost and emissions reductions fo r existing PVC units achieved by

applying BTF regulatory options.

Sections 2.0 and 3.0 discuss the selection of more stringe nt controls or emissions levels

than the floor level reviewed for this analysis for exi sting and new sources, respectively. Section

4.0 discusses the methodology used to estimate costs and emi ssions reductions of the more

stringent controls and Section 5.0 summarizes the result s of the BTF analysis.

2.0 Identification of More Stringent Controls for Existing S ources

The MACT floor analysis for existing sources results i n emissions levels that each

existing PVC unit is required to meet. As documented in a s eparate memorandum 2 

# , the

emissions reductions and costs of the MACT floor level of control were estimated using the

following assumptions:

1. Units that needed to meet the MACT floor for emissions of vinyl chloride (VC),

hydrogen chloride (HCl), total organic HAP, and chlorinated dibe nzodioxins and

chlorinate dibenzofurans (CDD/CDF) from process vents would add a (an additional)

refrigerated condenser, activated carbon injection (ACI) and fabric filters;

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2. Units that needed to meet the MACT floor for residual VC and total organic HAP in

resin would employ additional steam in existing stripper units;

3. Units that needed to meet the MACT floor for equipment leaks would implement a

leak detection and repair (LDAR) program equivalent to the program required by 40

CFR part 63 subpart UU;

4. Units that need to meet the MACT floor for heat exchange systems would

implement an LDAR program with a leak action level of 41 parts per billion (ppb) of

volatile organic compounds (VOC);

5. All units currently meet the MACT floor for storage vessels ; and

6. Units that needed to meet the MACT floor for wastewate r would employ additional

steam in existing stripper units.

7. All units currently meet the MACT floor for other emis sion sources.

BTF options were evaluated and analyzed for each of the e mission sources listed above

from existing sources.

2.1 Process Vents

The control technologies that would be needed to achieve the MACT floor levels for

process vents (i.e., enhanced VC recovery, ACI and fabri c filters, in combination with existing

controls, such as incinerators and acid gas scrubbers) ar e generally the most effective controls

available for reducing VC, HCl, total organic HAP, and CDD/ CDF. Therefore, no BTF

technologies were identified for these pollutants.

2.2 Resins

For stripped resins, it was determined that additional emiss ion reductions could be

achieved by routing vent streams from process components do wnstream of the stripper (e.g., the

PVC dryer vent(s)) to a thermal oxidizer (TO). The TO would theoretically achieve at least a 98

percent reduction of the residual HAP left in the resin (after the MACT floor levels have been

met by stripping the resin) that is emitted in the dryer vent stream(s). The incremental emissions

reductions and costs for installing a TO to control emiss ions from the PVC dryer vent(s) were

determined.

2.3 Equipment Leaks

The MACT floor level of control is generally equivale nt to the hazardous organic

national emission standards for hazardous air pollutant s (HON), which is considered the most

effective control of emissions from equipment leaks. Therefore, no BTF control options were

identified for equipment leaks.

2.4 Heat Exchange Systems

For heat exchange systems, the existing source MACT flo or level of control is a LDAR

program with a leak action level of 41 ppb. A BTF option equivalent to the new source MACT

floor leak action level of 25 ppb was analyzed. Average co sts and emission reductions were

calculated on a per leak basis.

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2.5 Storage Vessels

For storage vessels, data provided shows that fixed roof st orage vessels in the affected

sources are used to store low volatile material in small volume tanks. However, several storage

tanks with capacities greater than 20,000 gallons (gal) were identified that have the potential to

emit several tons of HAP per year depending on the mater ial stored and the number of turnovers.

A BTF option of requiring floating roof tanks meeting the requirements of 40 CFR part 63

subpart WW for storage vessels meeting specific vapor press ure and storage capacity parameters

was analyzed.

2.6 Wastewater

For wastewater, EPA has previously determined for the HO N that a BTF option of

treating streams with HAP concentrations greater than 1,000 parts per million by weight (ppmw)

(of 40 CFR part 63 subpart G Table 9 HAP) and annual average flo w rates greater than 10 liters

per minute (lpm) is cost-effective ($670 per ton in 2010 dollar s). The analysis previously

conducted for HON is applicable to PVC because the cost e ffectiveness of wastewater treatment

depends on the wastewater flow and HAP concentration, not on the type of process unit the

wastewater stream is coming from. The same treatment systems (steam stripping or

biotreatment) and the same measures to prevent atmospheri c emissions from the systems

conveying the wastewater streams to the treatment syste ms are applicable to wastewater streams

that meet these criteria. Furthermore, 35 percent of PV C facilities are collocated with chemical

manufacturing process units that are subject to the HON an d could potentially route PVC

wastewater streams (if any) that meet the total HAP c riteria to existing HON wastewater

treatment processes to meet these limits. Consequent ly, this was evaluated as a BTF option for

emissions from wastewater at existing sources.

Additionally, wastewater generated during maintenance ac tivities is not currently

regulated by 40 CFR part 61 subpart F. Including wastewater gen erated during maintenance

activities in the definition of wastewater subject to V C reduction was evaluated as a BTF option.

2.7 Other Emissions Sources

For other emission sources, an additional work practice used to minimize emissions from

PVC facilities was identified. One facility indicat ed they store filter bags, strainers, and other

removable separation media in closed and sealed containe rs that remain closed and sealed unless

being actively filled or emptied. However, not cost or e missions reduction data was available for

the work practice; therefore it was not analyzed as a BTF option.

3.0 Selection of More Stringent Controls for New Sources

Except for emissions from wastewater and storage vessel s no technologies or methods

were identified to achieve emission limits that would be more stringent than the MACT floor

limits or work practices for new units based on the best performing PVC facilities. The control

technologies and work practices necessary to achieve the MACT floor levels are generally the

most effective controls available.

As discussed above for wastewater, EPA has previously dete rmined for the HON that a

BTF option of treating streams with HAP concentratio ns greater than 1,000 ppmw (of 40 CFR

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part 63 subpart G Table 9 HAP) and annual average flow rates greater than 10 lpm is costeffective for new sources ($1,300 per ton in 2010 dollars for new sources). Additionally,

including wastewater generated during maintenance activities in the definition of wastewater

subject to VC reduction was evaluated as a BTF option.

Requiring floating roof tanks or fixed roof tanks routed to a clo sed vent system and

control device for storage vessels that (1) have a stor age capacity equal to or greater than 40,000

gal and store material with maximum true vapor pressures gre ater or equal to 0.75 pounds per

square inch absolute (psia) or (2) have a storage capacity equal to or greater than 20,000 gal and

less than 40,000 gal and store material with maximum true vapor pressures greater or equal to 4

psia appears to be cost-effective ($2,000 to $12,000 per ton of HAP).

4.0 Methodology Used to Estimate Costs and Emission Reductions

The methodology used to calculate costs and emissions re ductions from applying the

more stringent controls followed the same procedures as those discussed in the memorandum

titled “Cost and Emissions Reduction of Complying with th e MACT Floor Level of Control for

the Polyvinyl Chloride (PVC) and Copolymers Production Source Category.” 2



# 4.1 Resins

Emissions reductions from application of the BTF contro ls relative to the MACT floor

limits were calculated using the following procedure. Fir st, the reduction efficiency of the BTF

control for VC was applied to the uncontrolled concentrati on of VC estimated in the stripped

resin exiting the resin stripping operation to determine the total reduction the control would

achieve. It was assumed that all VC remaining in the re sin after being stripped would be

removed by the drying operation and exit the process through t he dryer vent(s). The reduction in

VC concentration from current actual concentration le vels to the MACT floor limits was

previously calculated for the MACT floor cost and emissi ons reduction analysis. 2 

# For VC and

total organic HAP, the incremental reduction between the more stringent BTF control and the

MACT floor was calculated by subtracting the MACT floo r emissions reductions from the

reductions achieved by the more stringent control.

The EPA Air Compliance Advisor (ACA) 3 

# program was used to estimate the cost of a

regenerative thermal oxidizer (RTO) for each facility . The main inputs to the program are:

• Dryer exhaust total organic HAP flow rate (mass);

• Dryer exhaust volumetric flow rate; and

• Dryer exhaust temperature and moisture content.

The above inputs were calculated as follows:

• Pounds per hour of total organic HAP at MACT floor emission levels were

used as the initial pollutant input to the program. To yield a conservative

fuel cost estimate, it was assumed that all total orga nic HAP was comprised

# 5 of VC; therefore combustion properties of VC were assi gned to total organic

HAP.

• Dryer exhaust flow rates were calculated first by dete rmining a flow rate

factor calculated from an average value of dryer flow r ate divided by annual

resin production. Dryer exhaust flow rates and non-confi dential resin

production rates were extracted from facility submitted survey information. 4



# This average was then multiplied by 2006 facility capacity i nformation to

obtain a theoretical maximum flow rate for each faci lity. In instances where

facilities 2008 production was greater than the 2006 capacity, t he 2008 nonconfidential production information was used.

• Waste stream temperature and moisture content was calcu lated as an

average of the data provided by OxyVinyls - Pedricktown. OxyVi nyls –

Pedricktown was the only facility to provide supplemental dryer exhaust

testing information.

An RTO cost scenario was completed for each facility . Costs were calculated in 2008

and 2010 dollars (based on Chemical Engineering general cost in dex).

4.2 Heat Exchange Systems

Responses to EPA’s section 114 survey of the industry ind icated that there are 27 cooling

towers at existing PVC production facilities. It was as sumed that each of these towers

corresponds to a single heat exchange system and the co oling tower is the emission point for the

system. The total flow or cooling water circulation ra te through each tower was extracted from

survey data or was estimated based on available data. To estimate the average costs and

emission reductions to meet the BTF option, the follow ing was assumed:

• Each system would have to make 1 repair per year, per towe r,

• Repair costs are $6,755 per repair, per tower,

• There would be a 16 ppb reduction in the VC and total VOC con centration

in the cooling tower water as a result of the repair, a nd

• The leak frequency is 97.5 days.

Average costs and emission reductions were calculated on a per leak basis and are

detailed in Attachment B.

4.3 Storage Vessel

The vapor pressure and storage capacity parameters for the BTF option are those from 40

CFR part 60 subpart Kb: (1) the material stored has a maximu m true vapor pressure greater or

equal to 0.75 psia (5.2 kilopascal (kPa)) and the storage vessel has a capacity equal to or greater

than 40,000 gal (151 cubic meters), or (2) the material stored has a maximum true vapor pressure

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greater or equal to 4 psia (27.7 kPa) and the storage vesse l has a capacity equal to or greater than

20,000 gal (75.5 cubic meters) but less than 40,000 gal (151 cubic meters) . Data supplied by

industry via EPA’s section 114 survey were analyzed to identif y storage vessels meeting the

aforementioned criteria. However; no storage vessels meeting the subpart Kb criteria were

identified. Although a test method such as ASTM D2879-10 or AP I Publication 2517 would be

used to determine vapor pressure, it was assumed that facil ities currently incur a cost to

determine vapor pressure, therefore, no additional cost was estimated. As a theoretical case, the

emission reduction and cost of retrofitting a fixed roof t ank with an internal floating roof was

calculated for a 40,000 gal tank storing methanol using EPA cost estimation equations. 5 

# This

analysis can be found in Attachment C.

4.4 Wastewater

To asses BTF costs for wastewater, data supplied by industr y via EPA’s section 114

survey were analyzed to identify wastewater streams th at have HON Table 9 HAP

concentrations greater than 1,000 ppmw and annual average flow rates greater than 10 lpm.

However; no wastewater streams meeting the concentra tion and flow requirements were

indentified. Wastewater generated during maintenance activit ies was also analyzed to determine

if any additional treatment would be required to meet the MACT floor wastewater standards.

However; no wastewater generated during maintenance activities contained a VC concentration

greater than 10 ppmw. Although facilities would be required t o use an additional test method,

such as Method 305 to determine methanol concentrations, the cost of Method 305 compared to

Method 8260B was assumed to be negligible, therefore, no a dditional cost was calculated. The

wastewater data set can be found in Attachment D.

5.0 Results

5.1 Resins

Applying BTF control to further reduce emissions from resi ns would result in a total

capital investment (TCI) of approximately $350 million (2010$), a n additional total annualized

cost (TAC) of $110 million (2010$), and would achieve additional VC and total organic HAP

reductions of 41 tons per year and 1,048 tons per year, respect ively beyond the MACT floor

level of control. The incremental cost-effectivenes s was estimated to be $2.7 million per ton of

VC reduced, and $105,000 per ton of total organic HAP reduced.

5.2 Heat Exchange Systems

For existing sources, the results of the BTF analysis sh ow that 5.78 tons per year of VC

would be reduced at a TAC of $175,630. The resulting cost-effectiv eness per leak is $30,386 per

ton of VC.

5.3 Storage Vessels

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The results of the BTF analysis for storage vessels sh ow that cost effectiveness ranged

from $2,000 to $12,000 per ton of HAP reduced by this option, depending o n the number of

turnovers assumed. Based on information submitted by PVC and copolymer production

facilities, no storage vessels from affected sources t hat meet the capacity levels (20,000 gallons

or 40,000 gallons) and store material that meet the vapor pre ssure levels of subpart Kb were

identified. Therefore, no additional costs and emission reductions were estimated for this option.

5.4 Wastewater

Based on the analysis, no wastewater streams from af fected existing sources are above

the 10 liters per minute flow rate and 1,000 ppmw concentratio n limit. Additionally, no

wastewater generated from maintenance activities met t he 10 ppmw VC treatment criteria.

Therefore, no additional emission reductions or costs for this option were estimated.

6.0 Results

Table 6-1 summarizes the results of the BTF analysis for all emission points for existing

PVC units. All emission reductions, costs, and cost eff ectiveness values are incremental above

the MACT floor level of control.8Table 6-1. Summary of Beyond-the-Floor Analysis Results for Existing PVCPUsEmissionPointBTF OptionTCI(2010 $)TACa(2010 $)Vinyl Chloride HCl Total Organic HAP CDD/CDFIER(tons/year)CE($/ton)IER(tons/year)CE($/ton)IER(tons/year)CE($/ton)IER(tons/year)CE($/ton)Process Vents None - - - - - - - - - -ResinsThermalOxidizer forDryer Vent(s)354,737,476 109,736,764 41 2,676,506 1,048 104,711 - - - -EquipmentLeaksNone - - - - - - - - - -HeatExchangeSystems5 ppb leakaction level- 175,630 5.78 30,386 - - - - - -Storage TanksHON capacityand VP cutoffs- - - - - - - - - -WastewaterHON 1,000ppmw and 10lpm –MaintenanceWastewater- - - - - - - - - -OtherEmissionSourcesNone - - - - - - - - - -aCalculated using a 7 percent discount factor.BTF – Beyond-the-floorTCI – Total capital investment for the BTF optionTAC – Total annual cost for the BTF optionIER – Incremental emission reductionCE – Cost effectiveness for the BTF optionHON – Hazardous organic national emission standards for hazardous air pollutantsVP – Vapor pressureppmw – parts per million by weightppb – parts per billionlpm – Liters per minute$/ton – Dollars per tonVC – Vinyl ChlorideHCl – Hydrogen ChlorideCDD/CDF – Chlorinated dibenzodioxins and chlorinated dibenzofuransHAP – Hazardous air pollutant

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7.0 References

1. “MACT Floor Analysis for the Polyvinyl Chloride and Copo lymers (PVC) Production

Source Category.” Memorandum from Eastern Research Group, Inc. (ERG) to Jodi

Howard, U.S. Environmental Protection Agency. April 2011.

2. “Cost and Emissions 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, U.S . Environmental Protection

Agency. April 2011.

3. “Air Compliance Advisor.” U.S. EPA. 22 June, 2007. 24 Sept. , 2010.

http://www.epa.gov/ttnecas1/ACA.htm

4. “Baseline Emissions Estimates for the Polyvinyl Chlori de and Copolymers (PVC)

Production Source Category.” Memorandum from Eastern R esearch Group, Inc. (ERG)

to Jodi Howard, U.S. Environmental Protection Agency. Apr il 2011.

5. US EPA Hazardous Air Pollutant Emissions from Process Units in the Synthetic Organic

Chemical Manufacturing Industry -- Background Information fo r Proposed Standards

Volume 1B: Control Technologies EPA-453/D-92-016b

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Attachments

Attachment A. Beyond-the-Floor Analysis for Resins

Attachment B. Beyond-the-Floor Analysis for Heat Exch ange Systems/Cooling Towers

Attachment C. Beyond-the-Floor Analysis for Storage Ves sels

Attachment D. Beyond-the-Floor Analysis for Wastewate r

Attachment E. Beyond-the-Floor Analysis for Other Emi ssion Sources

# Attachment A

Beyond-the-Floor Analysis for ResinsVinyl ChlorideTotal Organic HAP(fraction)Vinyl ChlorideTotal Organic HAPDSCFMFormosaDelaware15.428.1 0.9815.127.5101,882PolyOneHenry9.19.1 0.989.08.989,343PolyOnePedricktown9.915.0 0.989.714.792,477Dow Midland0.352.7 0.980.32051.6515,357FormosaBaton Rouge0.978.9 0.980.91377.31652,045FormosaPoint Comfort0.226.6 0.980.20626.101,112,865Georgia GulfAberdeen0.351.1 0.980.31050.08711,606Georgia GulfPlaquemine1.5247.6 0.981.503242.62852,674OxyVinylsDeer Park0.214.4 0.980.23614.13391,854OxyVinylsPasadena1.5235.5 0.981.452230.761,493,747OxyVinylsPedricktown0.323.3 0.980.28722.79249,219ShintechAddis0.8111.8 0.980.745109.54443,578ShintechFreeport0.454.5 0.980.36853.402,272,752ShintechPlaquemine0.456.5 0.980.37855.37924,775WestlakeCalvert City0.460.0 0.980.36458.80782,065WestlakeGeismar0.53.9 0.980.53.82407,52842.11068.941.31047.5Part 63Part 63Floor Emissions, tons/yrTotalsResins Beyond-The-FloorAnalysisEstimated Dryer FlowRateCompany FacilityBTF Reductions, tons/yrTO ReduxFormosaDelawarePolyOneHenryPolyOnePedricktownDow MidlandFormosaBaton RougeFormosaPoint ComfortGeorgia GulfAberdeenGeorgia GulfPlaquemineOxyVinylsDeer ParkOxyVinylsPasadenaOxyVinylsPedricktownShintechAddisShintechFreeportShintechPlaquemineWestlakeCalvert CityWestlakeGeismarTotalsResins Beyond-The-FloorAnalysisCompany FacilityMoistureTemperatureSupp FuelElectricityVinyl ChlorideTotal Organic HAP%oF20102010Ft^3/yrkWh/yr3.6576.690 8.9130.6 $3,917,879 $1,469,830 122,802,3106,770,1142.1752.167 8.9130.6 $2,409,618$936,294 107,931,3535,936,8712.3553.571 8.9130.6 $3,620,766 $1,010,151 111,505,6116,145,1710.07812.548 8.9130.6 $676,134$250,95118,210,0001,020,4810.22218.784 8.9130.6 $21,998,070 $8,470,901 786,867,98743,328,7140.0506.340 8.9130.6 $37,255,660 $14,355,682 1,344,871,28773,950,4290.07512.167 8.9130.6 $23,879,753 $6,966,456 859,376,23847,286,5710.36558.945 8.9130.6 $28,336,452 $8,307,374 1,026,528,05356,660,5710.0573.433 8.9130.6 $13,078,777 $3,877,817 473,485,14926,038,8570.35356.063 8.9130.6 $49,987,856 $14,504,200 1,801,709,57199,260,2860.0705.538 8.9130.6 $8,572,627 $2,511,001 300,841,58416,560,7140.18126.614 8.9130.6 $14,712,950 $4,368,024 534,287,12929,476,0000.09012.973 8.9130.6 $75,297,743 $22,002,896 2,746,501,650151,025,7140.09213.452 8.9130.6 $31,313,481 $9,035,925 1,116,996,70061,451,7140.08914.287 8.9130.6 $26,105,744 $7,640,876 944,408,58151,968,5710.1200.929 8.9130.6 $13,573,966 $4,028,385 492,574,25727,080,429354,737,476$109,736,764$12,788,897,459703,961,210TO TACStream ParametersPollutant Mass Flow Rate - ACA Inputlb/hrSecondary ImpactsTO TCI

# Attachment B

Beyond-the-Floor Analysis for Heat Exchange Systems/Cooling Tow ersAttachment B. Heat Exchange Systems - Beyond-the-Floor AnalysisCompanyName FacilityNameNumof CTsCT IDTotal Flow,gpmCosts toRepair,Repairs,event/yrCosts toRepair, $/yearVinyl Chloride Other VOCCertainTeedLake Charles1U-1310,200$6,7551$6,7550.149290.14929CertainTeedLake Charles1U-195,000$6,7551$6,7550.073180.07318FormosaBaton Rouge1U-102,175$6,7551$6,7550.031830.03183FormosaDelaware City1U-144,000$6,7551$6,7550.058550.05855FormosaDelaware City1U-734,000$6,7551$6,7550.058550.05855FormosaPoint Comfort - PVC1U-24158,700$6,7551$6,7552.322842.32284Georgia GulfAberdeen1U-662,000$6,7551$6,7550.029270.02927Georgia GulfAberdeen1U-672,000$6,7551$6,7550.029270.02927Georgia GulfAberdeen1U-682,000$6,7551$6,7550.029270.02927Georgia GulfAberdeen1U-692,000$6,7551$6,7550.029270.02927Georgia GulfPlaquemine1unknown - assume 2 CTs40,000$6,7551$6,7550.585470.58547Georgia GulfPlaquemine1unknown - assume 2 CTs22,300$6,7551$6,7550.326400.32640OxyVinylsDeer Park1unknown - assume 3 CTs2,200$6,7551$6,7550.032200.03220OxyVinylsDeer Park1unknown - assume 3 CTs2,200$6,7551$6,7550.032200.03220OxyVinylsDeer Park1unknown - assume 3 CTs19,600$6,7551$6,7550.286880.28688OxyVinylsPasadena1U-11039,000$6,7551$6,7550.131730.13173OxyVinylsPasadena1U-110411,600$6,7551$6,7550.169790.16979OxyVinylsPedricktown1U-60013,333$6,7551$6,7550.195150.19515PolyOneHenry1U-139,000$6,7551$6,7550.570830.57083PolyOnePedricktwon1U-18100$6,7551$6,7550.001460.00146ShintechAddis1U-62449$6,755 1$6,7550.006570.00657Shintech Freeport 1 U-45 360$6,755 1 $6,755 0.00527 0.00527ShintechPlaquemine1U-58433$6,7551$6,7550.006340.00634DowMidland1CTW-14,800$6,7551$6,7550.070260.07026WestlakeCalvert City1U-8922,800$6,7551$6,7550.333720.33372WestlakeGeismar1U-4014,650$6,7551$6,7550.214430.21443TOTAL$175,6305.7805.780Vinyl ChlorideCE, $/tonTOTAL$30,386BTF Emission Reduction,

# Attachment C

Beyond-the-Floor Analysis for Storage VesselsEmissions, lb/yr*20,000 gal40,000 galMTVP,1 TO5 TO1 TO5 TOVP, mm Hg LowestHAPpsi S_Loss W_Loss Total W_Loss Total S_Loss W_Loss Total W_Loss Total25 C emissions10.78992 120.069692Methanol1.85557 49 606 243 80020 C TrendMethylene chloride6.78 3,693 246 3,939 1,229 4,922 6,006 491 6,498 2,457 8,46479 1,176 972Hexane2.351,763 171 1,933 853 2,61692 571 1,113y=10.79*VP+120.1Acetaldehyde**14.5115 1,482 1,361Propylene oxide8.48 3,724 211 3,935 1,054 4,778 6,015 422 6,437 2,109 8,124125 606 1,469Vinylidene chloride9.64 8,028 400 8,428 1,998 10,026 12,922 799 13,721 3,995 16,917151 1,933 1,749Vinyl acetate1.741,357 125 1,482 627 1,983194 3,484 2,213Ethyl benzene0.14250 3,366 2,818Phenol0.004429 3,939 4,749Methyl isobutyl ketone0.28533 3,935 5,871Acetonitrile1.41523 48 571 241 764601 8,428 6,605Chloroform3.003,183 301 3,484 1,507 4,690Methyl tert-butyl ether2.133,071 294 3,366 1,472 4,543Ethylene dichloride1.201,079 98 1,176 488 1,567> 4 psi ----->> 0.75 psi ----->* Emissions = breathing losses (S_Loss) + working losses (W_Loss). Default values for Atlanta, Georgia.** Unable to model acetaldehyde tank emissions due to vapor pressure.Estimated S and WmmHg psia emissions, lb/yrtriethylamine57 1.1 735trichloroethylene69 1.3 745benzene95 1.8 1,025acrylonitrile109 2.1 1,176carbon tetrachloride115 2.2 1,241methyl chloroform124 2.4 1,338MTBE250 4.8 2,697acrolein274 5.3 2,956carbon disulfide359 6.9 3,874allyl chloride368 7.1 3,971Vapor pressure (25C)y = 10.79x + 120.07R2 = 101,0002,0003,0004,0005,0006,0007,0008,0009,0000 100 200 300 400 500 600 700

Emissions, lb/yrVapor pressure, mm HgEmissions vs Vapor PressureEmissions Needed to Achieve Cost Effectiveness of $3,500/tonVolumeDegas(1989)FlRoof(1989)CostEscal* TCI (2010) O&MEmissions, lb/yrEmiss Red,lb/yr TAC** Rec. Cr.*** $/tonVolume20,000$1,227 $8,817 1.80 $18,087 $1,809 1,997 1,897 $3,795 $949 $3,500Volume20,000 gal75.7 m330,000$1,510 $9,925 1.80 $20,593 $2,059 2,599 2,469 $4,320$3,500Tank diameter15.0 ft4.6 m40,000$1,750 $10,807 1.80 $22,614 $2,261 2,497 2,372 $4,744 $1,186$3,500Height15.0 ft4.6 m50,000$1,963 $11,552 1.80 $24,338 $2,434 3,071 2,918 $5,106$3,50060,000$2,155 $12,203 1.80 $25,858 $2,586 3,263 3,100 $5,425$3,500Volume30,000 gal113.6 m3* Cost escalation conducted from 7/89 to 6/06.Tank diameter17.2 ft5.2 m** TAC (annualized capital cost plus O&M, w/o recovery credit).Height17.2 ft5.2 m***Based on $500/ton (approx average of methylene chloride and ethylene dichloride from Platts)Equation: Emissions = 0.0191 x volume + 1442.7 (R2=0.99)Volume40,000 gal151.4 m3Tank diameter19.0 ft5.8 mHeight19.0 ft5.8 mVolume50,000 gal189.3 m3Tank diameter20.4 ft6.2 mHeight20.4 ft6.2 mVolume60,000 gal227.1 m3Tank diameter21.7 ft6.6 mHeight21.7 ft6.6 mbEmissions estimated for model tank in Atlanta, Georgia using TANKS4.Turnovers:1mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg39 52 78 103 129 155 39 52 78 103 129 155psia psia psia psia psia psia psia psia psia psia psia psiaVolumeTAC** 0.75 1 1.5 2 2.5 3 0.75 1 1.5 2 2.5 320,000$3,795 539 678 957 1236 1515 179413616 10717 7455 5665 4534 375530,000$4,32040,000$4,7446061518850,000$5,10660,000$5,425Turnovers:5mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg39 52 78 103 129 155 39 52 78 103 129 155psia psia psia psia psia psia psia psia psia psia psia psiaVolumeTAC** 0.75 1 1.5 2 2.5 3 0.75 1 1.5 2 2.5 320,000$3,795 2213 2910 4305 5700 7095 84902955 2133 1288 856 595 41930,000$4,32040,000$4,7448001137950,000$5,10660,000$5,425Turnovers:10mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg39 52 78 103 129 155 39 52 78 103 129 155psia psia psia psia psia psia psia psia psia psia psia psiaVolumeTAC** 0.75 1 1.5 2 2.5 3 0.75 1 1.5 2 2.5 320,000$3,795 4305 5700 8490 11280 14070 168601288 856 419 198 64 -2530,000$4,32040,000$4,7442990269850,000$5,10660,000$5,425Using methanol TANKS value in CMAS table, VP = 1.85lb/yr Emissions$/ton including recovery creditslb/yr Emissions$/ton including recovery creditslb/yr Emissions$/ton including recovery credits

# Attachment D

Beyond-the-Floor Analysis for WastewaterStripper OutletsFacility NameOriginating Equipment Liters per Minute Acetaldehyde EDC MeOH MIBK VCLake Charles Polymer PlantWaste Water Stripper0.030.40Formosa Plastics Corporation Baton Rouge Wastewater Stripping Columns102.920.30.14Georgia Gulf Chemicals Aberdeen Facility Waste Water strippers79.490.70Georgia Gulf Chemicals Plaquemine Facility Waste Water Stripper1.00OxyVinyls Deer ParkWaste Water Stripper0.0180.07OxyVinyls PasadenaWaste Water Preheater E-422480.690.04PolyOne HenryWaste Water Stripper Column37.211.40PolyOne PedricktownWaste Water Stripping Column1.861.46Shintech AddisWaste Water Stripper111.4540 0.26 0.01Shintech FreeportHEAT EXCHANGER202.7939 0.259 0.01Shintech PlaquemineWaste Water Stripper28.5540 0.3 0.01Westlake Calvert CityWater Stripper Col Feed Heat Exch217.122.26 0.05Westlake GeismarPVC Plant Waste Water Stripper99.331.72EDC - Ethylene DichlorideMeOH - MethanolMIBK - Methyl Isobutyl KetoneVC - Vinyl ChlorideAverage Concentration (ppmw)Stream ParametersUncontrolled StreamsFacilityNameStream IDOriginating Equipment Liters Per Minute Acetaldehyde Acetophenone Formaldehyde MeOH MIBK VCLake Charles Polymer PlantW-4Scrubber4480.00Formosa Plastics Corporation Baton RougeW-3XDW Tanks25690.10Georgia Gulf Chemicals Aberdeen FacilityW-4Unknown2080.00OxyVinyls Deer ParkW-308Unknown0.0180.07OxyVinyls PasadenaW312Unknown390 0.490.310.110.00OxyVinyls PasadenaW412Unknown484 0.390.250.090.00OxyVinyls PasadenaW512Unknown308 0.390.250.080.00OxyVinyls PasadenaW612Unknown497 0.390.250.090.00OxyVinyls PasadenaW712Unknown438 0.390.240.080.00OxyVinyls PasadenaW812Unknown483 0.390.250.090.00OxyVinyls PasadenaW912Unknown872 0.390.250.090.00PolyOne HenryW-1Dewatering Pass Through892.00PolyOne HenryW-1Dewatering Pass Through1282.00PolyOne HenryW-1Feed Tank0.00PolyOne HenryW-2Filter Press12.00PolyOne HenryW-1Stripping Column for PVC Slurry692.00PolyOne HenryW-1Stripping Column for PVC Slurry232.00Shintech AddisW-17HEAT EXCHANGER11140 0.26 0.01Shintech AddisW-19AUnknown1360.05Shintech AddisW-19BUnknown1360.05Shintech FreeportW-16CENTRIFUGES20339 0.259 0.01Shintech PlaquemineW-17HEAT EXCHANGER2840 0.3 0.01Shintech PlaquemineW-19CYCLONE SCRUBBER480.10Westlake Calvert CityW-9Water Recycle System4862.26Westlake GeismarW-11Dryer Feed Centrifuge (2)8240.00Westlake GeismarW-12Polymerization Reactors (6)61.88MeOH - MethanolMIBK - Methyl Isobutyl KetoneVC - Vinyl ChlorideAverage of Avg Conc (ppmw)Stream ParametersAttachment D - BTF Analysis for WastewaterVinyl chlorideppmwVinylchloridelb/yrVinylacetateppmwVinylacetatelb/yrMethylenechloride(Dichloromethane)ppmwMethylenechloride(Dichloromethane)lb/yrBenzene(includingbenzenefromgasoline)ppmwBenzene(includingbenzenefromgasoline)lb/yrBis(2-ethylhexyl)phthalate(DEHP)ppmwBis(2-ethylhexyl)phthalate (DEHP) lb/yrDibutylphthalate ppmwDibutylphthalatelb/yrTOH ppmw TOH lb/yrGeorgia Gulf Aberdeen --0Georgia Gulf Plaquemine --0PolyOne Henry22,243,957.00185,641,365.622371.28272 371.2827312Shintech Freeport430,000.003,588,650.490.0730.2619710.0010.0035890.0020.0071773010.0010.00358865 0.077 0.276326088Dow Texas City333,916.002,786,762.3750139.338150 139.3381183Westlake Calvert City1,206,000.0010,064,912.770Westlake Geismar852,000.007,110,535.392.2515.99872 15.99870463Average Concentration (ppmw) and lb/yrCompany/Facility Gallons/Year Pounds/YearStream Parameters

# Attachment E

Beyond the Floor Analysis for Other Emission Sources

# Attachment E - BTF Analysis for Other Emission Sources

Equipment Type HAP Emissions Control Work Practice



# Compressors E quipment is cleared to less than 10,000 ppm per Vinyl

Chloride NESHAPs

Closed loop process and vapor recovery system.

Equipment opening evacuation procedures.



# Equipment Clearing Procedures direct emissions to the

recovery area and incinerator



# Equipment only opened at or below VCM NESHAPS

concentrations

Water wash before opening and blown with Nitrogen

Methyl Acetate wash before opening and blown with

Acetone Wash before opening and blown with Nitrogen



# Equipment is cleared to less than 10,000 ppm per Vinyl

C hloride NESHAPs

Foam Trap Equipment Clearing Procedures direct emissions to the

recovery area and incinerator

The equipment is purged to the incinerator prior to opening

the equipment for maintenance.



# Equipment only opened at or below VCM NESHAPS

c oncentrations

Vessel is heated & undergoes 4 cycles of vacuum

degassing and N2 purging prior to opening.



# The vessel is purged to the incinerator prior to opening the

equipment for maintenance.



# Equipment is cleared to less than 10,000 ppm per Vinyl

Chloride NESHAPs

Steam Sweep & Recovery



# Equipment Clearing Procedures direct emissions to the

recovery area and incinerator



# Stripping and evacuation

R ecovery Separators Closed loop process and vapor recovery system.

Equipment opening evacuation procedures.

Equipment Clearing Procedures direct emissions to the

recovery area and incinerator



# Equipment only opened at or below VCM NESHAPS

c oncentrations

Evacuation procedure to recovery system before opening

Recovery in stripping



# Equipment is cleared to less than 10,000 ppm per Vinyl

Chloride NESHAPs

Steam Sweep & Recovery



# The vessel is purged to the incinerator prior to opening the

e quipment for maintenance.

Wash Columns Equipment is cleared to less than 10,000 ppm per Vinyl

Chloride NESHAPs

Waste Water Stripper Equipment Clearing Procedures direct emissions to the

recovery area and incinerator 

# Stripping Column

V essel Openings Pumps/Exchangers

Reactor Openings Filter Openings Work Practices To Control Fugitive Emissions