1 

 

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: Analysis of Beyond MACT Floor Controls for the Polyvinyl Chloride and 

Copolymers (PVC) Production Source Category 

1.0 Introduction 

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

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

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

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

minimum stringency “floor” requirements. A previous memorandum 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 requirements of the floor, EPA must 

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

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

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

applying BTF regulatory options. 

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

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

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

stringent controls and Section 5.0 summarizes the results of the BTF analysis. 

2.0 Identification of More Stringent Controls for Existing Sources 

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

existing PVC unit is required to meet. As documented in a separate memorandum2, 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 dibenzodioxins and 

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

refrigerated condenser, activated carbon injection (ACI) and fabric filters; 
2 

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 wastewater would employ additional 

steam in existing stripper units. 

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

BTF options were evaluated and analyzed for each of the emission 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 fabric filters, in combination with existing 

controls, such as incinerators and acid gas scrubbers) are 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 emission reductions could be 

achieved by routing vent streams from process components downstream 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 emissions from the PVC dryer vent(s) were 

determined. 

2.3 Equipment Leaks

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

national emission standards for hazardous air pollutants (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 floor 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 costs and emission reductions were 

calculated on a per leak basis. 
3 

2.5 Storage Vessels

For storage vessels, data provided shows that fixed roof storage 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 material 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 pressure and storage capacity parameters 

was analyzed. 

2.6 Wastewater

For wastewater, EPA has previously determined for the HON 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 flow rates greater than 10 liters 

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

conducted for HON is applicable to PVC because the cost effectiveness 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 atmospheric emissions from the systems 

conveying the wastewater streams to the treatment systems are applicable to wastewater streams 

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

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

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

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

emissions from wastewater at existing sources. 

Additionally, wastewater generated during maintenance activities is not currently 

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

activities in the definition of wastewater subject to VC 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 indicated they store filter bags, strainers, and other 

removable separation media in closed and sealed containers that remain closed and sealed unless 

being actively filled or emptied. However, not cost or emissions 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 vessels 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 determined for the HON that a 

BTF option of treating streams with HAP concentrations greater than 1,000 ppmw (of 40 CFR 
4 

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 closed vent system and 

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

gal and store material with maximum true vapor pressures greater 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 reductions from applying the 

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

titled “Cost and Emissions Reduction of Complying with the 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 controls relative to the MACT floor 

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

control for VC was applied to the uncontrolled concentration 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 resin after being stripped would be 

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

VC concentration from current actual concentration levels to the MACT floor limits was 

previously calculated for the MACT floor cost and emissions 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 floor 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 organic HAP was comprised 
5 

of VC; therefore combustion properties of VC were assigned to total organic 

HAP. 

• Dryer exhaust flow rates were calculated first by determining a flow rate 

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

resin production. Dryer exhaust flow rates and non-confidential resin 

production rates were extracted from facility submitted survey information.4 

This average was then multiplied by 2006 facility capacity information to 

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

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

• Waste stream temperature and moisture content was calculated as an 

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

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 index). 

4.2 Heat Exchange Systems

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

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

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

system. The total flow or cooling water circulation rate 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 following was assumed: 

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

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

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

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

• 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 maximum 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 
6 

greater or equal to 4 psia (27.7 kPa) and the storage vessel 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 identify 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 API Publication 2517 would be 

used to determine vapor pressure, it was assumed that facilities 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 tank 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 industry via EPA’s section 114 

survey were analyzed to identify wastewater streams that 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 concentration and flow requirements were 

indentified. Wastewater generated during maintenance activities 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 to 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 additional 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 resins would result in a total 

capital investment (TCI) of approximately $350 million (2010$), an 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, respectively beyond the MACT floor 

level of control. The incremental cost-effectiveness 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 show that 5.78 tons per year of VC 

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

ton of VC. 

5.3 Storage Vessels
7 

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

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

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

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

or 40,000 gallons) and store material that meet the vapor pressure 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 affected existing sources are above 

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

wastewater generated from maintenance activities met the 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 effectiveness values are incremental above 

the MACT floor level of control. 
8 

Table 6-1. Summary of Beyond-the-Floor Analysis Results for Existing PVCPUs 

Emission 

Point BTF Option TCI (2010 $) TACa (2010 $) Vinyl Chloride HCl Total Organic HAP 

IER (tons/year) CE ($/ton) IER (tons/year) CE ($/ton) IER (tons/year) CE ($/ton) 

Process Vents None - - - - - - - - Resins 

Thermal Oxidizer for Dryer Vent(s) 

354,737,476 109,736,764 41 2,676,506 1,048 104,711 - - 

Equipment Leaks None - - - - - - - - Heat Exchange Systems 

5 ppb leak action level - 175,630 5.78 30,386 - - - - 

Storage Tanks HON capacity and VP cutoffs - - - - - - - - Wastewater 

HON 1,000 ppmw and 10 lpm – Maintenance Wastewater 

- - - - - - - - 

Other Emission Sources 

None - - - - - - - - 

a Calculated using a 7 percent discount factor. BTF – Beyond-the-floor TCI – Total capital investment for the BTF option TAC – Total annual cost for the BTF option IER – Incremental emission reduction CE – Cost effectiveness for the BTF option HON – Hazardous organic national emission standards for hazardous air pollutants VP – Vapor pressure ppmw – parts per million by weight ppb – parts per billion lpm – Liters per minute $/ton – Dollars per ton VC – Vinyl Chloride HCl – Hydrogen Chloride CDD/CDF – Chlorinated dibenzodioxins and chlorinated dibenzofurans HAP – Hazardous air pollutant 
9 

7.0 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, 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 Chloride and Copolymers (PVC) 

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

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

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

Chemical Manufacturing Industry -- Background Information for Proposed Standards 

Volume 1B: Control Technologies EPA-453/D-92-016b 
10 

Attachments 

Attachment A. Beyond-the-Floor Analysis for Resins 

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

Attachment C. Beyond-the-Floor Analysis for Storage Vessels 

Attachment D. Beyond-the-Floor Analysis for Wastewater 

Attachment E. Beyond-the-Floor Analysis for Other Emission Sources 
Attachment A 

Beyond-the-Floor Analysis for Resins 
Vinyl Chloride Total Organic HAP (fraction) Vinyl Chloride Total Organic HAP DSCFM

Formosa Delaware 15.4 28.1 0.98 15.1 27.5 101,882PolyOne Henry 9.1 9.1 0.98 9.0 8.9 89,343PolyOne Pedricktown 9.9 15.0 0.98 9.7 14.7 92,477

Dow Midland 0.3 52.7 0.98 0.320 51.65 15,357Formosa Baton Rouge 0.9 78.9 0.98 0.913 77.31 652,045Formosa Point Comfort 0.2 26.6 0.98 0.206 26.10 1,112,865Georgia Gulf Aberdeen 0.3 51.1 0.98 0.310 50.08 711,606Georgia Gulf Plaquemine 1.5 247.6 0.98 1.503 242.62 852,674

OxyVinyls Deer Park 0.2 14.4 0.98 0.236 14.13 391,854OxyVinyls Pasadena 1.5 235.5 0.98 1.452 230.76 1,493,747

OxyVinyls Pedricktown 0.3 23.3 0.98 0.287 22.79 249,219Shintech Addis 0.8 111.8 0.98 0.745 109.54 443,578

Shintech Freeport 0.4 54.5 0.98 0.368 53.40 2,272,752Shintech Plaquemine 0.4 56.5 0.98 0.378 55.37 924,775Westlake Calvert City 0.4 60.0 0.98 0.364 58.80 782,065Westlake Geismar 0.5 3.9 0.98 0.5 3.82 407,528

42.1 1068.9 41.3 1047.5

Part 63 Part 63

Floor Emissions, tons/yr

TotalsResins Beyond-The-Floor Analysis

Estimated Dryer Flow 

Company Facility TO Redux BTF Reductions, tons/yr Rate

A-1
Formosa Delaware

PolyOne HenryPolyOne PedricktownDow MidlandFormosa Baton RougeFormosa Point ComfortGeorgia Gulf AberdeenGeorgia Gulf PlaquemineOxyVinyls Deer ParkOxyVinyls PasadenaOxyVinyls PedricktownShintech AddisShintech FreeportShintech PlaquemineWestlake Calvert CityWestlake GeismarTotalsResins Beyond-The-Floor Analysis

Company Facility Moisture Temperature Supp Fue

Vinyl Chloride Total Organic HAP % oF 2010 2010 Ft

3.657 6.690 8.9 130.6 $3,917,879 $1,469,830 1

2.175 2.167 8.9 130.6 $2,409,618 $936,294 1

2.355 3.571 8.9 130.6 $3,620,766 $1,010,151 1

0.078 12.548 8.9 130.6 $676,134 $250,951 

0.222 18.784 8.9 130.6 $21,998,070 $8,470,901 70.050 6.340 8.9 130.6 $37,255,660 $14,355,682 1,3

0.075 12.167 8.9 130.6 $23,879,753 $6,966,456 80.365 58.945 8.9 130.6 $28,336,452 $8,307,374 1,00.057 3.433 8.9 130.6 $13,078,777 $3,877,817 4

0.353 56.063 8.9 130.6 $49,987,856 $14,504,200 1,80.070 5.538 8.9 130.6 $8,572,627 $2,511,001 3

0.181 26.614 8.9 130.6 $14,712,950 $4,368,024 50.090 12.973 8.9 130.6 $75,297,743 $22,002,896 2,70.092 13.452 8.9 130.6 $31,313,481 $9,035,925 1,10.089 14.287 8.9 130.6 $26,105,744 $7,640,876 90.120 0.929 8.9 130.6 $13,573,966 $4,028,385 4

$ 354,737,476 $ 109,736,764 12,7

TO TAC Pollutant Mass Flow Rate - ACA Input Stream Parameters lb/hr 

TO TCI

A-2
Attachment B 

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

CompanyName FacilityName Num of CTs CT ID Total Flow, gpm Costs to Repair, Repairs, event/yr Costs to Repair, $/year Vinyl 

CertainTeed Lake Charles 1 U-13 10,200 $6,755 1 $6,755 CertainTeed Lake Charles 1 U-19 5,000 $6,755 1 $6,755 Formosa Baton Rouge 1 U-10 2,175 $6,755 1 $6,755 Formosa Delaware City 1 U-14 4,000 $6,755 1 $6,755 Formosa Delaware City 1 U-73 4,000 $6,755 1 $6,755 Formosa Point Comfort - PVC 1 U-24 158,700 $6,755 1 $6,755 Georgia Gulf Aberdeen 1 U-66 2,000 $6,755 1 $6,755 Georgia Gulf Aberdeen 1 U-67 2,000 $6,755 1 $6,755 Georgia Gulf Aberdeen 1 U-68 2,000 $6,755 1 $6,755 Georgia Gulf Aberdeen 1 U-69 2,000 $6,755 1 $6,755 Georgia Gulf Plaquemine 1 unknown - assume 2 CTs 40,000 $6,755 1 $6,755 Georgia Gulf Plaquemine 1 unknown - assume 2 CTs 22,300 $6,755 1 $6,755 OxyVinyls Deer Park 1 unknown - assume 3 CTs 2,200 $6,755 1 $6,755 OxyVinyls Deer Park 1 unknown - assume 3 CTs 2,200 $6,755 1 $6,755 OxyVinyls Deer Park 1 unknown - assume 3 CTs 19,600 $6,755 1 $6,755 OxyVinyls Pasadena 1 U-1103 9,000 $6,755 1 $6,755 OxyVinyls Pasadena 1 U-1104 11,600 $6,755 1 $6,755 OxyVinyls Pedricktown 1 U-600 13,333 $6,755 1 $6,755 PolyOne Henry 1 U-1 39,000 $6,755 1 $6,755 PolyOne Pedricktwon 1 U-18 100 $6,755 1 $6,755 Shintech Addis 1 U-62 449 $6,755 1 $6,755 Shintech Freeport 1 U-45 360 $6,755 1 $6,755 Shintech Plaquemine 1 U-58 433 $6,755 1 $6,755 Dow Midland 1 CTW-1 4,800 $6,755 1 $6,755 Westlake Calvert City 1 U-89 22,800 $6,755 1 $6,755 Westlake Geismar 1 U-40 14,650 $6,755 1 $6,755 

TOTAL $175,630 

Vinyl Chloride

CE, $/ton

TOTAL $30,386

BT
Attachment C 

Beyond-the-Floor Analysis for Storage Vessels 
Emissions, lb/yr*

20,000 gal 40,000 gal

MTVP, 1 TO 5 TO 1 TO 5 TO VP, mm Hg Lowest

HAP psi S_Loss W_Loss Total W_Loss Total S_Loss W_Loss Total W_Loss Total 25 C emissions 

Methanol 1.85 557 49 606 243 800 20 C TrendMethylene chloride 6.78 3,693 246 3,939 1,229 4,922 6,006 491 6,498 2,457 8,464 79 1,176 972Hexane 2.35 1,763 171 1,933 853 2,616 92 571 1,113 

Acetaldehyde** 14.5 115 1,482 1,361Propylene oxide 8.48 3,724 211 3,935 1,054 4,778 6,015 422 6,437 2,109 8,124 125 606 1,469Vinylidene chloride 9.64 8,028 400 8,428 1,998 10,026 12,922 799 13,721 3,995 16,917 151 1,933 1,749Vinyl acetate 1.74 1,357 125 1,482 627 1,983 194 3,484 2,213Ethyl benzene 0.14 250 3,366 2,818Phenol 0.004 429 3,939 4,749Methyl isobutyl ketone 0.28 533 3,935 5,871Acetonitrile 1.41 523 48 571 241 764 601 8,428 6,605

Chloroform 3.00 3,183 301 3,484 1,507 4,690

Methyl tert-butyl ether 2.13 3,071 294 3,366 1,472 4,543

Ethylene dichloride 1.20 1,079 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 W

mmHg psia emissions, lb/yr

triethylamine 57 1.1 735

trichloroethylene 69 1.3 745benzene 95 1.8 1,025acrylonitrile 109 2.1 1,176carbon tetrachloride 115 2.2 1,241methyl chloroform 124 2.4 1,338MTBE 250 4.8 2,697acrolein 274 5.3 2,956carbon disulfide 359 6.9 3,874allyl chloride 368 7.1 3,971

Vapor pressure (25C) y = 10.79x + 120.07

R2 = 1

0

1,0002,0003,0004,0005,0006,0007,0008,0009,000

0 100 200 300 400 500 600 700

Emissions, lb/yr

Vapor pressure, mm Hg

Emissions vs Vapor Pressure

C-1
Emissions Needed to Achieve Cost Effectiveness of $3,500/ton

Volume

Degas (1989)

FlRoof 

(1989)

Cost 

Escal* TCI (2010) O&M

Emissions

, lb/yr

Emiss Red, 

lb/yr TAC** Rec. Cr.*** $/ton

Volume 20,000 $1,227 $8,817 1.80 $18,087 $1,809 1,997 1,897 $3,795 $949 $3,500

Volume 20,000 gal 75.7 m3 30,000 $1,510 $9,925 1.80 $20,593 $2,059 2,599 2,469 $4,320 $3,500Tank diameter 15.0 ft 4.6 m 40,000 $1,750 $10,807 1.80 $22,614 $2,261 2,497 2,372 $4,744 $1,186 $3,500

Height 15.0 ft 4.6 m 50,000 $1,963 $11,552 1.80 $24,338 $2,434 3,071 2,918 $5,106 $3,500

60,000 $2,155 $12,203 1.80 $25,858 $2,586 3,263 3,100 $5,425 $3,500

Volume 30,000 gal 113.6 m3 * Cost escalation conducted from 7/89 to 6/06.Tank diameter 17.2 ft 5.2 m ** TAC (annualized capital cost plus O&M, w/o recovery credit).

Height 17.2 ft 5.2 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)

Volume 40,000 gal 151.4 m3

Tank diameter 19.0 ft 5.8 m

Height 19.0 ft 5.8 mVolume 50,000 gal 189.3 m3Tank diameter 20.4 ft 6.2 mHeight 20.4 ft 6.2 mVolume 60,000 gal 227.1 m3Tank diameter 21.7 ft 6.6 mHeight 21.7 ft 6.6 m

bEmissions estimated for model tank in Atlanta, Georgia using TANKS4.

C-2
Turnovers: 1

mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg

39 52 78 103 129 155 39 52 78 103 129 155

psia psia psia psia psia psia psia psia psia psia psia psia

Volume TAC** 0.75 1 1.5 2 2.5 3 0.75 1 1.5 2 2.5 3

20,000 $3,795 539 678 957 1236 1515 1794 13616 10717 7455 5665 4534 3755

30,000 $4,32040,000 $4,744 606 1518850,000 $5,10660,000 $5,425

Turnovers: 5

mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg

39 52 78 103 129 155 39 52 78 103 129 155

psia psia psia psia psia psia psia psia psia psia psia psia

Volume TAC** 0.75 1 1.5 2 2.5 3 0.75 1 1.5 2 2.5 3

20,000 $3,795 2213 2910 4305 5700 7095 8490 2955 2133 1288 856 595 419

30,000 $4,32040,000 $4,744 800 11379

50,000 $5,10660,000 $5,425

Turnovers: 10

mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg mm Hg

39 52 78 103 129 155 39 52 78 103 129 155

psia psia psia psia psia psia psia psia psia psia psia psia

Volume TAC** 0.75 1 1.5 2 2.5 3 0.75 1 1.5 2 2.5 3

20,000 $3,795 4305 5700 8490 11280 14070 16860 1288 856 419 198 64 -25

30,000 $4,32040,000 $4,744 2990 2698

50,000 $5,10660,000 $5,425

Using methanol TANKS value in CMAS table, VP = 1.85

lb/yr Emissions $/ton including recovery credits

lb/yr Emissions $/ton including recovery creditslb/yr Emissions $/ton including recovery credits

C-3
Attachment D 

Beyond-the-Floor Analysis for Wastewater 

 
Stripper Outlets

Facility Name Originating Equipment Liters per Minute Acetaldehyde EDC MeOH MIBK VC

Lake Charles Polymer Plant Waste Water Stripper 0.03 0.40

Formosa Plastics Corporation Baton Rouge Wastewater Stripping Columns 102.92 0.3 0.14Georgia Gulf Chemicals Aberdeen Facility Waste Water strippers 79.49 0.70Georgia Gulf Chemicals Plaquemine Facility Waste Water Stripper 1.00OxyVinyls Deer Park Waste Water Stripper 0.018 0.07OxyVinyls Pasadena Waste Water Preheater E-422 480.69 0.04PolyOne Henry Waste Water Stripper Column 37.21 1.40

PolyOne Pedricktown Waste Water Stripping Column 1.86 1.46Shintech Addis Waste Water Stripper 111.45 40 0.26 0.01

Shintech Freeport HEAT EXCHANGER 202.79 39 0.259 0.01

Shintech Plaquemine Waste Water Stripper 28.55 40 0.3 0.01

Westlake Calvert City Water Stripper Col Feed Heat Exch 217.12 2.26 0.05Westlake Geismar PVC Plant Waste Water Stripper 99.33 1.72EDC - Ethylene DichlorideMeOH - MethanolMIBK - Methyl Isobutyl KetoneVC - Vinyl Chloride

Stream Parameters Average Concentration (ppmw)

D-1
Uncontrolled Streams

FacilityName Stream ID Originating Equipment Liters Per Minute Acetaldehyde Acetophenone Formaldehyde 

Lake Charles Polymer Plant W-4 Scrubber 448 Formosa Plastics Corporation Baton Rouge W-3 XDW Tanks 2569 

Georgia Gulf Chemicals Aberdeen Facility W-4 Unknown 208 OxyVinyls Deer Park W-308 Unknown 0.018 

OxyVinyls Pasadena W312 Unknown 390 0.49 0.31 0.11 OxyVinyls Pasadena W412 Unknown 484 0.39 0.25 0.09 OxyVinyls Pasadena W512 Unknown 308 0.39 0.25 0.08 OxyVinyls Pasadena W612 Unknown 497 0.39 0.25 0.09 OxyVinyls Pasadena W712 Unknown 438 0.39 0.24 0.08 OxyVinyls Pasadena W812 Unknown 483 0.39 0.25 0.09 OxyVinyls Pasadena W912 Unknown 872 0.39 0.25 0.09 PolyOne Henry W-1 Dewatering Pass Through 89 PolyOne Henry W-1 Dewatering Pass Through 128 PolyOne Henry W-1 Feed Tank PolyOne Henry W-2 Filter Press 1 PolyOne Henry W-1 Stripping Column for PVC Slurry 69 PolyOne Henry W-1 Stripping Column for PVC Slurry 23 Shintech Addis W-17 HEAT EXCHANGER 111 Shintech Addis W-19A Unknown 136 Shintech Addis W-19B Unknown 136 Shintech Freeport W-16 CENTRIFUGES 203 Shintech Plaquemine W-17 HEAT EXCHANGER 28 Shintech Plaquemine W-19 CYCLONE SCRUBBER 48 Westlake Calvert City W-9 Water Recycle System 486 

Westlake Geismar W-11 Dryer Feed Centrifuge (2) 824 Westlake Geismar W-12 Polymerization Reactors (6) 6 MeOH - MethanolMIBK - Methyl Isobutyl KetoneVC - Vinyl Chloride

Stream Parameters Average of Avg Conc (ppm

D-2
Attachment D - BTF Analysis for Wastewater



Vinyl chloride 

ppmw

Vinyl 

chloride 

lb/yr

Vinyl 

acetate 

ppmw

Vinyl 

acetate 

lb/yr

Methylene 

chloride 

(Dichlorom

ethane) 

ppmw

Methylene 

chloride 

(Dichlorom

ethane) 

lb/yr

Benzene 

(including 

benzene 

from 

gasoline) 

ppmw

Benzene 

(including 

benzene 

from 

gasoline) 

lb/yr

Bis(2-

ethylhexyl)

phthalate 

(DEHP) 

ppmw

Bis(2-

ethylhexyl)phthalat

e (DEHP) lb/yr

Dibutylphthal

ate ppmw

Dibutylphthal

lb/yr 

Georgia Gulf Aberdeen - - 

Georgia Gulf Plaquemine - - 

PolyOne Henry 22,243,957.00 185,641,365.62 2 371.2827 

Shintech Freeport 430,000.00 3,588,650.49 0.073 0.261971 0.001 0.003589 0.002 0.007177301 0.001 0.00358

Dow Texas City 333,916.00 2,786,762.37 50 139.3381 Westlake Calvert City 1,206,000.00 10,064,912.77 

Westlake Geismar 852,000.00 7,110,535.39 2.25 15.9987 

Average Concentration (ppmw) and lb/yr

Company/Facility Gallons/Year Pounds/Year

Stream 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 Equipment 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 

Chloride 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 

concentrations

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

Recovery 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 

concentrations

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 

equipment 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

Vessel Openings

Pumps/Exchangers

Reactor Openings

Filter Openings

Work Practices To Control Fugitive Emissions