### MEMORANDUM

DATE: October 28, 2011 SUBJECT:Impacts Assessment for Process Contact Cooling Towers for the PET Continuous TPA High Viscosity Multiple End Finisher Subcategory FROM:Alden West, EC/R Inc. Lesley Stobert, EC/R Inc. TO:Paula Hirtz, EPA Nick Parsons, EPA
This memorandum presents the impacts of regulatory changes within the provisions of the Group IV Polymers and Resins MACT standards that apply to the PET continuous TPA high viscosity multiple end finisher subcategory. Specifically, this memorandum will present the cost and emissions impacts associated with the development of a maximum achievable control technology (MACT)floor and regulatory alternatives for Process Contact Cooling Towers (PCCT), which are currently unregulated within this subcategory. First, a brief background of the project and the source subcategory is provided. Second, a discussion is provided of the procedures used in determining the MACT floor and choosing a regulatory alternative more stringent than the MACT floor. The final section is a discussion of the cost and emissions impacts of the regulatory alternatives. BACKGROUND Industry and Process Description High viscosity resin, which forms a small portion of the PET resin industry, is primarily used in high strength applications such as the manufacture of seat belts or tire cords. At PET manufacturing facilities that produce high viscosity resin, a steam jet vacuum system is usually used to create the vacuum required to vaporize ethylene glycol from the product and increase its viscosity. Steam exiting the jet vacuum is sent to a contact condenser where it is condensed by the cold water from a PCCT. Ethylene glycol and other hazardous air pollutants (HAP) contact the water in the condenser, and the water is recirculated to the PCCT. The P&R IV MACT standard defines a PCCT system as “a cooling tower system that is designed and operated to allow contact between the cooling medium and process fluid or gases” (40 CFR §63.1312). The primary HAP emitted from PCCT, ethylene glycol, is emitted by drift or evaporation. Drift occurs when some of the cooling water becomes entrained in the air stream and is carried out of the tower as droplets. Drift eliminators are usually incorporated into the tower design to remove “drift” droplets from the air stream before exiting the tower. Drift eliminators rely on inertial separation caused by multiple directional changes in airflow to prevent the escape of water.

### Regulatory History

The PET continuous TPA high viscosity multiple end finisher subcategory was created due to significant differences between the high viscosity multiple end finisher process and other high viscosity and continuous TPA processes. It is the only PET source subcategory where standards for PCCT were determined to be cost effective. Standards for PCCT in this source subcategory were originally promulgated in the September 12, 1996 Federal Register publication of NESHAP for Group IV Polymer and Resin source categories. On August 29, 2000, the EPA took action to indefinitely stay the compliance date for the PCCT provisions for this subcategory because the EPA was in the process of responding to a request to reconsider portions of the Group IV Polymers and Resins MACT standards that could result in changes to the emission limitation for PCCT in this subcategory (65 FR 52319). Since that date, the petitioner has dropped its petition, which requested that the EPA reconsider the existence of the PET continuous TPA high viscosity multiple end finisher subcategory. As a result of the indefinite stay of the compliance date for PCCT emissions, there are currently no active regulations limiting HAP emissions from PCCT in this source subcategory. As PCCT are potentially major sources of emissions for the one facility (currently owned by Performance Fibers Holdings, Inc., formerly Honeywell) in this source subcategory, the EPA is reconsidering the emissions and cost data available to assist in the promulgation of new standards. In order to determine the appropriate control technologies and emission limitations to control HAP from PCCT, it was necessary to establish a MACT floor and determine the impacts that such a limitation (MACT floor) would have on the one facility in the source subcategory. DETERMINATION OF THE LEVEL OF THE STANDARD Determination of the MACT Floor Section 112(d) of the Clean Air Act provides guidance on determining the MACT “floor”, which is the least stringent level allowed for the MACT standards. For new sources, emission standards “shall not be less stringent than the emission control that is achieved in practice by the best controlled similar source.” For existing sources, the emission standards must be at least as stringent as either “the average emission limitation achieved by the best performing 12 percent of the existing sources” or “ the average emission limitation achieved by the best performing 5 sources” for categories or subcategories with less than 30 sources. As there is only one facility in this source subcategory, the control level currently being achieved by this facility represents the MACT floor. According to the facility’s Title V operating permit, issued January 28, 2005, it is regulated by the Polymers Manufacturing new source performance standards (NSPS). The Polymers Manufacturing NSPS requires the facility to maintain an ethylene glycol concentration in the PCCT at or below 6.0 percent by weight, averaged on a dailybasis over a rolling 14-day period of operating days. As we assume the facility is in compliance with this standard and we have no information to suggest substantially greater emissions reductions are achieved by this facility, the 6.0 percent by weight ethylene glycol concentration limit for this facility represents the MACT floor.

### Determination of Regulatory Alternatives More Stringent than the MACT Floor

In addition to the control level represented by the MACT floor, the EPA can consider regulatory alternatives more stringent than the floor, often referred to as “beyond-the-floor” alternatives. The original PCCT regulations promulgated in the Group IV Polymer and Resin NESHAP established an ethylene glycol concentration limit of 4.0 percent by weight for PCCT in this source subcategory based on the information available on controls and costs. We identified this 4.0 percent concentration limit as a beyond-the-floor option. IMPACTS ANALYSIS There are no impacts expected as a result of the facility meeting the MACT floor because the emissions level currently being achieved by this facility (6% ethylene glycol concentration in the PCCT) represents the MACT floor. The one facility that employs the continuous TPA high viscosity multiple end finisher process submitted a comment letter to the EPA on May 26, 1995, before promulgation of the final Group IV Polymers and Resins MACT standards. In the comment letter, the facility argued for the establishment of a separate subcategory for its unique multiple end finisher process. 1 

### The facility also provided its own analysis of the impacts that would result from reducing the ethylene glycol concentration in the cooling water from 7% down to 3% at 1% increments.2 

### This impacts assessment uses the estimated costs from the 1995 comment letter as the basis for determining the cost effectiveness of the beyond-the-floor alternative. The comment letter is provided in Appendix B
. This analysis assumes that the facility maintains an ethylene glycol concentration of 6%, which is the upper limit required by the Polymers Manufacturing NSPS. If the facility’s actual concentration was maintained below 6%, it could at any time raise the concentration up to 6% within the boundaries of current regulation. Therefore, this analysis studies the maximum impacts to the facility that would result if the 4% concentration limit was promulgated, based on the difference between the regulatory limits imposed by the current NSPS standard and the potential beyond-the-floor alternative. Cost Analysis The analysis from the 1995 comment letter identified the need to update the existing ethylene glycol recovery system as the primary capital cost associated with the ethylene glycol reduction alternative, and the need to increase the amount of steam used to strip ethylene glycol from the contaminated water as the primary annual cost. The facility claimed that the total capital cost to modify the existing ethylene glycol recovery system would be $5,900,000
. The facility also provided total annual cost figures for the additional steam that would be required at each

1 Comments to the Environmental Protection Agency by AlliedSignal Inc. From J.E. Cooper, Director Environmental Quality, AlliedSignal Inc. To Docket Number 1-92-45, US EPA. May 26, 1995. 2In the 1995 comment letter referenced above, the facility states that the actual current ethylene glycol concentration in the cooling towers is just under 7%. The facility also states that it is not subject to the Polymer Manufacturing NSPS because it is not an “affected facility”. The facility would later become subject to the NSPS and is now required to comply with the 6% ethylene glycol concentration limit.

### ethylene glycol concentration increment. The additional cost of steam to reduce the ethylene

glycol concentration in the PCCT from 6% to 4% was given as $2,190,175/yr. For our current analysis, we adjusted these cost values from 1995 to 2011 dollars to account for inflation. This adjustment yields a present-day capital cost of $8,783,761 and an annual steam cost of $3,260,673. Thecapital cost amortized at 7% over 15 years would be $964,410/yr. The total present-day annual cost to reduce the ethylene glycol concentration was calculated as $4,225,083 (annualized capital and steam costs). Emissions Reduction Analysis Although the 1995 comment letter does provide the emissions reduction that would be expected at each percent reduction in ethylene glycol concentration, there is no supporting documentation provided to confirm these numbers. Instead, our analysis relies on PCCT data collected by the EPA from facilities in all PET subcategories after promulgation of the original Group IV Polymers and Resins MACT standards. This data, provided in Appendix A, was used to calculate emissions based on several variables, including the cooling water recirulation rate, the ethylene glycol concentration, and the drift and evaporation factors. To determine emissions from the PCCT at this facility at different concentrations of ethylene glycol in the cooling water, the following equation was used:

where: E D,E 

### = ethylene glycol emissions from drift and evaporation (lb/hr), multiplied by 8,760 hrs/yr and divided by 2,000 lb/ton to get tons/yr (tpy); W r 

### = water recirculation rate in the cooling tower (lb/hr); EG% = percent ethylene glycol concentration in the cooling tower water; Drift% = percentage of the ethylene glycol load that will contribute to drift; Evap% = percentage of the ethylene glycol load that will evaporate. Based on the EPA data for this facility, the PCCT cooling water recirculation rate is 1,865,130 lb/hr and the evaporation and drift factors are 0.006% and 0.024% respectively. The annual emissions calculated for the “existing” scenario of 6% ethylene glycol concentrationin the cooling water was 147 tons per year (tpy), and the emissions calculated for the beyondthe-floor alternative scenario of 4% ethylene glycol concentration was 98 tpy. Therefore, the emissions reduction that could be achieved by the beyond-the-floor alternative is 49 tpy. Although our emissions reduction analysis did not rely on the information submitted by the facility in its comment letter, our analysis provides a similar emissions reduction estimate. The 1995 comment letter stated that the incremental emission rate was 24 Mg/yr. This equates to a 26.5 tpy emission reduction for each percent ethylene glycol in the cooling water that is reduced, and a 53 tpy reduction from reducing the ethylene glycol concentration from 6% to 4%.

### Impacts Summary

Table 2 present the impacts of each regulatory alternative. The total annual cost scaled to 2011 dollars based on information from the 1995 comment letter was divided by the emissions reduction from the EPA data to provide the cost effectiveness of the beyond-the-floor regulatory alternative.

The estimated emission reduction from the beyond-the-floor alternative is 49 tpy and the cost effectiveness is $85,714/ton HAP removed. Although there is some uncertainty in the emissions and cost estimate, it is clear that the total cost is substantial compared to the emissions reduction that would be expected.

### Appendix A

PCCT data collected by EPA

1This facility is currently owned by Performance Fibers Holdings, Inc. and is the only facility that uses the continuous TPA high viscosity multiple end finisher process.

### Appendix B

### .. -.": 

# '. 411iedSignai AlliedSignallnc. 

# A

- '--I**~** 

# - 

# vsjV-D 

# -19
E' N GIN E ERE D MATERIALS P.O. Box 1139**M.Orrist~~,~** 07962-1139

# RECE.\V~U JUN 2 !J, 

### 1997 OAQPS AIR
.O\\J May 26, 1995 OOCKET CONTROL RO I \ US Environmental Protection Agency Air Docket Section (LE-131) Attention: DocketNumber A-92-45 401 M Street, SW Washington, DC 20460**r.=~~~**

### __ ----__

# mr~ ®[!

# JJU,~

# U~ I MAY' r 

## !S<;') 

## 1

# ~ L--
____

# ,-1**J:~'\** J"' ':i r,(lf'a''"ET -"" r-, !'-',.,;' "-",
............ 1" 

### Re: 60FR16090, Proposed "National Emission 

### STancliiRfS-t"Or az Air PollutantEmissions From the Production ofAcrylonitrile Butadiene Styrene (ABS) Resin, Styrene Acrylonitrile (SAN) Resin, Methyl Methacrylate Butadiene Styrene (MABS) Resin, PolystyreneResin, Poly(Ethylene Terephthalate) (PET) Resin, and Nitrile Resin (Group IVPolymer and Resins." Dear Sir orMadam: AlliedSignal is pleased to submit comments in duplicate ontheEnvironmental Protection Agency's March 29, 1995 proposed "NationalEmission Standards for Hazardous Air PollutantEmissions From the Production ofAcrylonitrile Butadiene Styrene (ABS) Resin, Styrene Acrylonitrile (SAN) Resin, Methyl Methacrylate Butadiene Styrene (MABS) Resin, Polystyrene Resin, Poly(Ethylene Terephthalate) (PET) Resin, and Nitrile Resin (Group IVPolymer and Resins." [60FRI6090] As directed by Mr. Leslie Evans ofEPA, the attached information being sent to the docket has been redacted to exclude confidential business information. Such confidential information is being separately submitted to Mr. Evans for EPA's review and confidential inclusion in the docket for this rule in accordance with 40 CFRPart 2. AlliedSignal Inc., headquartered in Morristown, NJ, is an advanced technology company with businesses in aerospace,

### autoinoti~e products and engiffeered materials. AlliedSignal '-. operates one ofthe largest Polyethylene Terephthalate (PET) production facilities ofits type in the United States at its site in Moncure, North Carolina. This site will be gre'ady impacted by the proposedNESHAP standard because EPAfailed to understand and accurately identify the proposed standard's impact on PET production processes such as those used by AlliedSignai. As such, the actual costs ofcompliance will be grossly higher than predicted by EPAin its proposal. In the attached comments, AlliedSignal presents a basis for creating an additional PET MACT subcategory and adopting, for that subcategory, an alternate control standard that represents a far more cost-effective MACT standard.

### EPAis encouraged to closely review the attached comments. AlliedSignal is available to respond to any questions orcomments that EPAmay have regarding its PET process or on establishing an cost-effective control strategy. Please contact me (201-455-5040) or Alan T. Roy (201-455-4907) ifyou have any questions. We look forward to continued discussion with EPAin orderto establish the properMACT standards for the PET industry. Also enclosed is a self-addressed stamped envelope to be used for returning a date-stamped extra copy ofour comments. Sincerely Yours,

# J~~/,y J. E. Cooper DirectorEnvironmental Quality



### xc: Mr. Leslie Evans Organic Chemicals Group-Emissions Standards Division (MD-13) US Environmental Protection Agency Research Triangle Park, North Carolina 27711**:~~** ."COMMENTS
TO THE
ENVIRONMENTALPROTECTION AGENCY 

### by
ALLIEDSIGNAL INC. May 26, 1995

concernmg
PART 63

-- NATIONAL EMISSION STANDARDS FORHAZARDOUS AIR POLLUTANTS FOR SOURCE CATEGORIES
SUBPART V

-- National Emission Standards for Hazardous Air Pollutant Emissions from Thermoplastics Production 

### 60 Fed Reg. 16,090 (March 29, 1995)
DocketNo. A-92-45-", 

# :..)**tA._,~>._r.,** ..**~** .,./ TABLE OF CONTENTS

I. INTRODUCTION
............................................... 1


### II. AN OVERVIEW OF THE POLYETHYLENE TEREPHTHALATE 

### INDUSTRy
.................................................... 2 A. Overview oftheMoncure Plant'sMultiple End Finisher High Viscosity Process
.................................................. 4 B. Comparison ofPET Continuous TPA LowViscosity Process
..........7 C. Comparison ofPET Continuous TPA High Viscosity Solid State Process
.................................................. 8 III. EPA'S PROPOSED MACT SUBCATEGORIZATIONFORPET MANUFACTURERS IS FATAiL Y FLAWED AND-MUST BEIffiVISED IN THEFINAL RULE TO ESTABLISH AN ADDITIONAL SUBCATEGORY FORA CONTINUOUS TPA HIGH VISCOSITYMULTIPLEEND FINISHER PROCESS
......................................................8 

### A. EPAFailed toEvaluate the Impact ofthe Proposed PET Continuous TPA MACT for Cooling Towers on the High Viscosity Multiple End Finisher Process
.................................................. 9 

### 1. EPA's Cost Estimate for Using an Ethylene Glycol Jet Vacuum System to Meet the Proposed Standard to Eliminate the Use of Cooling TowerWater in the Vacuum System Contact Condenser NeverRecognized the Need to Have MUltiple Jet Systems on the High Viscosity Multiple End Finisher Process
...............10 2. EPA's Cost Estimate Never Took Into Account the Requirement to Control Solids Level in the Process
. . . . . . . . . . . . . . . . . . . . . . .12 3. EPAFailed to ProperlyEvaluate the Use ofan Ethylene Glycol Jet Vacuum System as a Process Change, Thereby Further Underestimating the Cost ofCompliance for PET Continuous TPA High Viscosity Multiple End Finishers
.................... 14 4. EPA's Impact Analysis Failed to Recognize That the High Viscosity Process Requires Additional Glycol Recovery Equipment as Compared to Other PETProcesses
.....................18**~ ~**  . ,; B. Implementation oftheProposed PET Continuous TPA MACT Standard Eliminate the Use ofCooling TowerWaterin the Vacuum System Contact CondenserWould Create an EnormouslyDisparate Cost Impact on AlliedSignal'sMoncure Plant
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .19 C. EPA'sBeliefthat Other Technologies are Feasible toEliminate theUse of Cooling TowerWaterin the Vacuum System Contact Condenser isNot Supported by the Proposal and is TechnicallyFlawed
............... 24 1. Non-contact Condensers
............................... 25 2. Mechanical Vacuum Pumps
............................ 26 D. Using The Discretion Provided By CAA 

### § 112(C)(I) And (0)(1), EPA MustEstablish A Separate PET MACT Subcategory for a Continuous TPA MultipleEnd Finisher Process
............................ 27 1. Implementation ofthe Criteria Identified by EPA for Establishing SeparateMACT Subcategories Within the Group IVPolymer and Resins Category Conclusively Supports theFurther Desegregation ofthe PET Continuous TPA Subcategory into a New Subcategory.



### ............................................. "
... 28 2. EPA'sEarlier Regulatory Treatment ofthe PET Industry Also Unequivocally Supports the Establishment ofan Additional Subcategory
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3 1 3. Existing Analytical Precedent in the Proposed Rule Supports the Creation ofan Additional PETMACT Subcategory in the Final Rule
..............................................33 IV. FORTHENEWPET MACT SUBCATEGORY WIDCH MUSTBE ESTABLISHED BYEPAFORTHE CONTINUOUS TPA HIGH VISCOSITY MULTIPLEEND FINISHERPROCESS, THE AGENCY MUST ADOPT AN ALTERNATIVE MACT STANDARD FOR CONTROLLING COOLING TOWEREMISSIONS
............................................34 A. An Alternate MACT Standard for Cooling Towers in the PET Continuous TPA High Viscosity Multiple End Finisher Process
................ 35 B. Evaluation ofAlliedSignal's Alternate MACT Control for Cooling Towers in the PET Continuous TPAHigh Viscosity Multiple End Finisher Process
...........................................35

ii

# -

. :- ..**~** V. EPA SHOULD NOT DESIGNATE ALL WASTEWATER STREAMS FROM THE VACUUM SYSTEMAS GROUP I WASTEWATER STREAMS
..... .39 A. Automatically Designating Wastewater Streams From PET Vacuum Systems as a Group I Stream Causes Confusion on Howthe HON Standards are to Apply
......................................39 B. Automatically Designating Wastewater Streams from PET Vacuum Systems as a Group I Stream Creates Additional Cost Impacts that EPA Failed to Include in Its Impact Analysis ofthe PET Industry
.......... 41 VI. TO OBVIATE THE CREATION OF MEANINGLESS MONITORINGAND RECORDKEEPINGREQUIREMENTS WHERE THEPOTENTIALFOR EMISSIONS IS MINIMAL, THE EQUIPMENT LEAK PROVISIONS OF THE PROPOSED RULE SHOULD SIMPLYNOT APPLY TO THE TPA CONTINUOUS PROCESS
....................................... .44 VII. EPA SHOULD_MAKE THE STORAGE VESSEL REQUIREMENTS INAPPLICABLE TO THEPET CONTINUOUS TPA PROCESS
.......... .48 VIII. THE EMISSIONS AVERAGING PROVISIONS IN THE PROPOSED RULE REQUIRE MINORREVISIONS AND, CONSISTENT WITH THE HON, SHOULDBEEXPANDED TO ALLOW ADDITIONAL POINTS TO BE AVERAGED
................................................... 48 A. Section 6351O(a) oftheProposed Rule Appears to Contain a Typographical Error Which Affects the Scope ofEmission Averaging Provisions
... "
.......................................... 49 B. The Emission Averaging Provisions Appear to Inadvertently Overlook the Process Standards Contained in 

### § 63.505(b)(3) as Sources that Can be Included in an Emission Average
...........................'
... 49 C. The Emissions Averaging Provision ofthe Rule Should beExpanded to Include Additional Points
....................................50

iii

### I. INTRODUCTION
These comments are submitted by AlliedSignal Inc. in response to the Environmental Protection Agency's (EPA) proposed rule and request for comment on "PART 63

-- National Emission Standards for Hazardous Air Pollutants for Source Categories, Subpart V

-- National Emission Standards for Hazardous AirPollutant Emission from Thermoplastics Production." 60

### Fed Reg. 16,090 (March 29, 1995). Because 

### it owns and operates a polyethylene terephthalate (PET) Plant in Moncure, North Carolina, AlliedSignal has a significant interest in the proposed rule as it specifically pertains to theMACT standards proposed by'EPA for the PET process. AlliedSignal has invested a substantial amount oftime and effort in reviewing the

# ~ ....' proposed rule, assessing the impact ofthe proposal onthe MoncurePlant, and developing these comments. As conclusively demonstrated through these comments, EPA's proposed subcategorization ofthe PET MACT category does not properly account for the type of PET manufacturing process employed at theMoncurePlant. Because ofthis oversight, a real world application ofthe MACT standard proposed for cooling towers in the "PET continuous TPA" subcategory would result in an enormously disparate cost impact at the Moncure Plant. Using the statutory discretion available to EPAto account for fundamentally different processes when developing MACT categories and subcategories, the Agency must establish an additional MACT PET subcategory which accounts for the type ofmanufacturing process used at the Moncure Plant. Forthis new subcategory, AlliedSignal has developed--and proposed in these comments--a MACT standard which

1will result in a level ofcost-effectiveness within the range found to be acceptable by EPA in the development ofotherPETMACT subcategories, as well as other polymer and resins MACT subcategories.

In earlier discussions withEPA about the proposed PETMACT standards, AlliedSignai representatives provided Agency personnel with detailed information concerning many ofthe issues raised in these comments. To the extent that EPA needs additional information beyond what has already been provided to the Agency in these earlier discussions and in these comments, AlliedSignal representatives are available to respond to any inquiries and comments which the Agency may have. As it considers the totality ofinformation before it, the Agency should bear in mind that AlliedSignai is firmly 

# A committed to the development ofa PETMACT standard which results in reasonable ) impacts to its Moncure facility and that it will not hesitate to exercise its right tojudicially and/or administratively challenge a final standard which does not result in such impacts.



### ll. AN OVERVIEW OF THE POLYETHYLENE TEREPHTHALATE INDUSTRY
The PET resin industry serves a wide range ofcustomers with two distinctly different products. Approximately 90% ofthe PET industry produces a low viscosity resin that goes into end uses such as bottle production. The remaining 10% produces a high viscosity resin that is typically converted to fiber and goes into end uses such as tire cord or seat belts and other high strength applications. AlliedSignal currently operates a

2

### PET Plant in Moncure, North Carolina that represents approximately 40% ofthe US production capacity for high viscosity PET.

Lowviscosity PET resins are produced commercially from ethylene glycol (EG) by using either dimethyl terephthalate (DMT) or terephthalic acid (TPA) as the raw material. Both processes first produce the intermediate bis-(2-hydroxyethyl)-terephthalate (BHET)
monomer and then polymerize it to PET under reduced pressure with heat and catalyst. Most ofthe new high viscosity PET installations are using the TPAprocess.

Forthat segment ofthe PET manufacturing sector using TPA in a continuous process, the production oflow viscosity resins and high viscosity resins are very different, 

# $!_ with additional vessels and processing steps required for the production ofhigher viscosity

.**;~.r/** 

### resin. To the best ofAlliedSignal's knowledge, two methods, the solid state process and the multiple end finisher process, are used to produce the high viscosity resin. See 

### Figure I. 

### As explained in detail below, the differences between the high viscosity and low viscosity processes, and the differences between the high viscosity solid state process and the high viscosity multiple end finisher process, significantly impact the selection of control technologies and have a significant impact on the cost-effectiveness evaluation of any control technologies.

3

### PETMANUFACTURING BREAKDOWN

DMT Low Viscosity Continuous Batch Multiple End Finisher 

### Figure I
A. Overview ofthe MoncurePlant's Multiple End FinisherHigh Viscosity Process


### AlliedSignal's Moncure Plant consists ofa continuous operation which uses TPA
as a raw material and produces high viscosity PET using a three-stage process. 1 

### The three stages are referred to as esterification, pre-polycondensation and polycondensation (often referred to as polymerization). At Moncure, the material leaving the final polymerization reactor is directly and continuously fed, as a melt product, to the fiber spinning process.

Although the Moncure Plant provided a response to EPA's ICR Questionnaire which explained the Plant's manufacturingprocess, EPA's February 14, 1995 analysis ofthe continuous TPAprocess completely overlooked its many distinctions. See Document II-B-lO ("Process Description for PET'), pp. 10-11. 4At theMoncurePlant, esterification ofethylene glycol with TPA is performed in a series ofvessels. The esterification vessels typically operate at a temperature between 260 and 280°C and at an elevated pressure generated by the vaporization ofglycol, inhibitor and reaction product water. Agitation is provided in the first vessel by a turbine agitator and draft tube, which provides recirculation as well as pumping action to move material from the first to the second stage. Agitation for the second and third vessels is provided by the boiling action as vapors are released. The vapors (glycol, water, inhibitors and byproducts) are removed to the glycol condenser/recovery system to maintain reactor pressure. The pre-polycondensation step is performed under moderate vacuum in two cylindrical reactors. Inthis step, esterification is completed and thejoining ofthe short molecular chains is promoted by the removal ofethylene glycol. The prepolycondensation reaction promotes increased viscosity ofthe reaction mass; therefore, transferto the polycondensation reactor is by a gearpump. At the Moncure Plant, the ethylene glycol and other vapors are removed from the pre-polycondensation reactor through separate vaporlines into glycol spray condensersby vacuum pumps.
The last stage, polycondensation or polymerization reaction, is carried out in two continuous steps; this process is referred to as a multiple finisher process. To accomplish high viscosities and reduce subsequent viscosity loss between the final finishers and fiber spinning, multiple final finishers are required. Thus, the process is referred to as a multiple end finisher process. The additional step accomplished by the mUltiple end finisher



### 5process is necessary in orderto produce high viscosity PET and to maintain that viscosity for subsequent spinning. To the best ofAlliedSignal's knowledge, AlliedSignal's Moncure Plant is the only known domestic producer that relies solely on the multiple end finisher process for its PET. AlliedSignal believes that there are no more than three other domestic facilities that may operate a train that has multiple end finishers and that other

,such trains will typically have a solid state or low viscosity PET resin line that is an integral part ofthat process.
At theMoncurePlant, each ofthe polymerization process steps consists ofreactor vessels underhigh vacuum. The material enters a first stage reactor (often called theprefinisher) which operates under a vacuum ofapproximately 2 torr. The material is then fed to three parallel end finisher reactors which operate at a very high vacuum, sometimes as low as 0.5 torr.
Exposing the low melt viscosity material to a sudden decrease in plessure results in flash vaporization ofethylene glycol. The liquid surface which is exposed allows for vaporization ofethylene glycol from the melt, resulting in an increase in polymer molecular weight and the resulting high viscosity melt product. The viscosity ofthe product is controlled by regulating the vessel's operating pressure. Once the temperature, level and shear rate are set, pressure control is used to assure constant product viscosity.
Glycol vapors, with some oligomer content, are removed from the product discharge end ofthe reactors by the vacuum system which, at the Moncure Plant, consists

6ofa two steam ejector systems with barometric intercondensers. The vapor line temperature is maintained at or above the reactor temperature to minimize solids build up. 

### B. Comparison ofPET Continuous TPA Low Viscosity Process
In thePET continuous TPA low viscosity process, esterification and prepolycondensation are similarto the high viscosity multiple end finisher process. Significant process differences occur in the low viscosity process with the material exiting the pre-polycondensation vessel. In the low viscosity process, the material leaving prepolycondensation is processed in a single polymerization reactor. This reactor operates under a vacuum that is slightly different than the pre-finisher ofa high viscosity process. The material leaving the single polymerization reactor ofa low viscosity process is then extruded and quenched into a solid pellet or chip and represents the final product for the low viscosityPET train.

The primary difference as compared to the high viscosity multiple end finisher process is that, in the high viscosity process, the material is further processed by directly feeding the material to multiple end finishers. The high viscosity process end finishers operate under a much higher vacuum than the single reactor in a low viscosity process. Each end finisher operates with its own vacuumjet system under the very high vacuum necessary to raise the viscosity ofthe resin to the finished product requirements. The low viscosity process does not have any ofthese additional vessels ortheir associated vacuum systems.

7

### C. Comparison ofPET Continuous TPA High Viscosity Solid State Process
InthePET continuous TP A solid state high viscosity process, the processing steps
are very similar to those used in the lowviscosity process, except that the solid chips or pellets are then subjected to an additional processing step. Inthis process, the solid chip is dried, fed to one or more crystallizers to raise the sticking point ofthe polymer, and subsequently fed to a solid state reactor system. Typical residence times for the solid stating process are approximately 24-28 hours. After "solid stating," the high viscosity PET chip material is cooled and stored for subsequent spinning/processing into high

## ~ viscosity PET tiber
.

..**~/**



### ill. 

### EPA'S PROPOSEDMACT SUBCATEGORIZATIONFORPET MANUFACTURERS IS FATALLY FLAWED AND MUST BEREVISED IN THEFINALRULE TOESTABLISH AN ADDmONAL SUBCATEGORY FORA CONTINUOUS TPA HIGH VISCOSITY MULTIPLE END FINISHERPROCESS
At 

### § 63.500 ofthe proposed Subpart V, EPA outlines the 28 categories and subcategories included in its proposal for "Group IV Polymers and Resins." The PET
source category is broken down into four subcategories, depending on the raw material used (DMT or TPA) and whether or not the process is continuous or batch. Byusing this subcategorization scheme, EPAhas included all PET continuous TPA processes in the

8

### same subcategory and has proposed to subject all PET continuous TPA processes to the
same control requirements. This subcategorization scheme for the PET continuous TPA process ignores the fundamental processing differences that exist between the high viscosity multiple end finisher process and other PET continuous TPA processes. As explained in detail below, the high viscosity multiple end finisher process was never properly evaluated during the development ofthe proposed MACT standard for cooling towers. The fundamental differences that are part ofthe multiple end finisher process must be taken into account when developing aMACT standard. EPA's failure to correctly evaluate this process has created a disproportionately large impact on the high viscosity multiple end finisher process. To rectify this oversight, EPA must create in the final rule a new PET

## ~ subcategory for manufacturers using TPA in a continuous process having multiple end**.--~/**

I / 

### finishers.

A. EPA Failed to Evaluate theImpact ofthe Proposed PET Continuous TPA MACT for Cooling Towers on the High Viscosity Multiple End FinisherProcess


### In the preamble to its March 29 proposal, EPA defers to section 6.0 ("MACT Floors and Regulatory Alternatives") ofthe Basis and Purpose Document for a full explanation ofthe alternatives used to develop the MACT standard for each ofthe Group IV subcategories. Section 6.2.3.2 discusses "Process Contact Cooling Towers" and

9

### summarizes the approach EPA used to develop the cooling tower standard for the PET 

# --. continuous TPAprocess.

To begin with, EPA stated that the polymerNSPS (Subpart DOD) for the PETTPAcontinuous process limits ethylene glycol concentration in the cooling tower but that this particularprovision was not included as aregulatory alternative "because other techniques (which are described below) were identified for controlling emissions from process contact cooling towers and were detennined to be both more effective and less costly.,,2 EPA used one ofthese alternatives, the use ofethylene glycoljets in place of steamjets in the vacuum system, as the basis for the proposed standard to eliminate the
use ofcooling tower water in 

### vacuum system contact condensers for all PET facilities. EPA went on to state that it "believes (emphasis added) there are several technically feasible methods for limiting/minimizing emission from vacuum systems generated wastewater." The proposal goes on to list the following three alternatives: (1) use of ethylene glycoljets in place ofsteamjets in the vacuum**system~** (2) 

### the use ofmechanical
vacuum**pumps~** 

### and (3) non-contact condensers in place ofthe typical contact barometric intercondenser.

2 Basis and Purpose Document. Section 6.2.3.2. 10"

. \**~'** 

### 1. EPA's CostEstimate for Using an Ethylene Glycol Jet Vacuum System to Meet the Proposed Standard to Eliminate the Use of Cooling TowerWater in theVacuum System Contact CondenserNeverRecognized the Need to Have Multiple Jet Systems on the High Viscosity Multiple End FinisherProcess

As explained by document TI-B-27 in the Docket established for this rulemaking, the impact analysis for the proposed standard to eliminate theuse ofcooling towerwater 

### in the vacuum system contact condensers is based onthe use ofethylene glycoljetvacuum systems as a replacement for the steamjet vacuum systems. EPA states in this document that cost datafor ethylene glycoljets were available from a single source, but that such datawere declared to be confidential business infonnation. 3 Although the document states that the costs provided were for a retrofit application ofethylene glycoljets, the retrofit capital costs were not provided and were approximated by EPA. Retrofit capital costs were said tobe**appro~mated** by doubling the direct capital costs and using the provided indirect capital costs without modification. EPA supplied no infonnation to justifythe assumption that retrofit capital costs can be approximated by doubling the known capital costs ofajet system. (As explained later in these comments, this assumption is grossly inaccurate.) Direct installation costs and indirect costs were approximated by EPAby assuming that such costs comprised 30% and 31% ofthe purchased equipment cost respectively.

Costs for each ofthe individual PET facilities were extrapolated by using two techniques, both ofwhich were dependent on production capacity. The first technique,

3 Document II-B-2, p.S. 11used for existing facilities where a cost is not as closely related to production rate, was to
use a 6110th scaling factor based onthe ratio ofthe "extrapolated facility's" production rate and the CBIfacility's production rate. The 6/10th scale factor was used for estimating cost ofitems that are not as strongly related to production rate, such as capital costs, fixed annual costs and semi-variable costs. Forthese calculations, the ratio ofthe extrapolated facilities production rate (or capacity) to the CBI production rate (or capacity) was determined and raised to the 0.6 power. This quotient was multiplied by the appropriate cost component to determine the extrapolated cost.

The second technique uses a direct ratio ofthe production rates (or capacities) between the "extrapolated facility" and the CBI plant. This technique was used to**!t~** estimate costs at existing facilities for items such as variable annual costs that are more

__

,r' directly related to the production rate ofaplant. The production rate (or capacity) ratio is multiplied by the cost component to determine the extrapolated cost.

EPA's approach to estimating costs by applying only the cost ofa sinelejet system is grossly inaccurate for the high viscosity multiple end finisher process since the high viscosity multiple end finisher process requires multiplejet systems to pull vacuum onthe multiple reactors in orderto raise the viscosity ofthe resin to its desired level. Even ifall other costing approaches were accurate, which they are not, EPA's approach is flawed since it never recognized the high viscosity process with multiple end finishers and the need to have multiplejet systems. 

### )

12!**~'** 

### 2. EPA's CostEstimate Never TookInto Account the Requirement to Control Solids Level in the Process

An inherent challenge in the design ofany PET process is to develop a system for handling the oligomers and other solids that are carried overhead from the process vessels. Solids buildup regularly occurs in the vacuumjets and in any control devices used to control the reactor vent stream. In orderto avoid process down time due to the buildup ofsolids in thejet system, it is necessary to either design a scrubber system to remove solids prior to the vacuumjet orto design the reactor with a spare vacuumjet system that
can come on-line when an on-linejetis shut downto allow for the solids to be removed. The current standard at AlliedSignal's Moncure Plant is for each reactor to have a spare
vacuum system, thereby allowing for the removal ofsolids from onejet system while the otheris operating.

The need for a system to manage solids was completely ignored in EPA's cost analysis ofthe regulatory alternative used in the proposed standard to eliminate the use of cooling tower water in vacuum system contact condenser. As explained above, EPA simply took a capital cost estimate for a singlejet system, applied factors to represent retrofit, direct and indirect costs, and estimated the industry wide impact. An accurate evaluation ofthe cost must also include a scrubber system or a spare vacuumjet system to manage the build up ofsolids.

l3

## ¢~-

..::;....,'



### ) EPA'sfailure to identify the need for equipment to handle solids buildup in the PET continuous TP A process has a disproportionate impact on the high viscosity multiple end finisher process. As explained above, the high viscosity multiple end finisher process has multiplejet systems, each ofwhich require an approach to manage solids 

### in orderto avoid pluggage. Scrubbersto handle the solids in thePET processes are uniquely designed for that purpose and can cost in excess of$1,000,000. EPAtherefore grossly underestimated the cost impact to the high viscosity multiple end finisher process by not including equipment for each end finisher that is necessary to deal with the solids issue. EPA's analysis also would have resulted in underestimating the impact on the low viscosity process since a method to handle solids was not even included for the single polymerization reactor.



### 3. EPA Failed to Properly Evaluatethe Use ofan Ethylene Glycol Jet Vacuum System as a Process Change. Thereby Further Underestimating the Cost ofCompliance for PET Continuous TPA High Viscosity Multiple End Finishers
EPA's proposed standard to eliminate the use ofcooling tower water in the
vacuum system contact condensers is based on replacing steamjetvacuum systems with ethylene glycoljet vacuum systems. Thejet systems are not pollution control equipment typically associated with a MACT standard, but are an integral part ofthe manufacturing process. Thejet systems create the vacuum in the polymerization reaction vessels. In the high viscosity multiple end finisher process, it is thejet systems that supply the high

14vacuum requirements to the additional end finisher vessels to produce the high viscosity product.

As noted in a July 11, 1994 letterto EPAfrom CarolinaEastman, EPA cannot solely base an emissions control standard on process changes. 4 In that letter, Eastman presented information on ethylene glycoljetvacuum systems but stated that it did not support the use ofethylene glycoljets as a MACT technology since thejet system was an integral part ofthe production process and not a control technology. AlliedSignal fully
concurs with this position, incorporates Eastman's letter by reference and objects in the

".'. ..... - strongest possible terms to the imposition ofMACT standards which require such a manufacturing process change.**,f.~**

.... I

.-**~**.

.-' To the extent that a**manufact~ring** process change may be properly considered as thebasis for a MACT standard, EPAfailed to recognize that the impacts ofa process change are substantially different than the impacts ofsimply adding pollution control equipment to a process. These differences result in significant additional costs that EPA did not include in its analysis ofthe impact ofits proposed rule and in the selection of proposed control methods. For example, one significant aspect ofdesignating such a process change as MACT involves the licensing and patent considerations associated with PET process technology. PET process technology patents are held by several companies,
some ofwhich are manufacturers ofPET and in direct competition with other producers in the industry. Some vendors work directly with a firm that owns a technology, marketing 

## ) 4 Document II-D-222. 15

### and selling that technology to others. In all such cases, a licensing agreement and fee is required before the technology can be used. As AlliedSignal was investigating the cost implications ofretrofitting its Moncure facility with ethylene glycoljet systems, attempts to get accurate cost estimates frequently involved direct contact with various vendors. In
some cases, the license holder hesitated to license any ofthe technology to AlliedSignal since the owner ofthe technology and AlliedSignal were producers and competitors in the PET market.

Since AlliedSignal's Moncure Plant relies solely on the high viscosity multiple end finisher process, it is possible that only a single vendor would have the technical knowledge, licensing ability and experience in the multiple end finisher process. It should
• be obvious that any time that market conditions create a single supplier, supply and

f 

### demand will force the ultimate price ofthe system much higher. Furthermore, AlliedSignal is limited in its ability to design and install its own technology. Such an effort would take an enormous amount ofresearch and development and would be limited by patent infringement implications. In any case, it is unlikely that such an effort could be successfully completed in time to design, install and operate a new vacuum system prior to the MACT compliance deadlines.

In addition, implementation ofprocess changes will require a lengthy period of time during which the process must be shutdown to complete the installation ofequipment associated with the change. Such downtime is normally not considered as a cost by EPA 

## )
16

### when establishing control requirements. The downtime associated with meeting a standard which requires control equipment is a much shorter period oftime since the control equipment installed is usually end-of-the-line "add-on" equipment. Normally, a standard does not dictate aprocess change which will, for the PET process, require a significant shutdown ofthe plant. AlliedSignal estimates that it would need to shut its process down for at least six weeks in order to "retrofit its existing process with an ethylene glycoljetvacuum system. "During this time, the impact to AlliedSignal'sPET business would be two-fold. First, the simple loss ofsales due to outage ofproduction capability would have significant monetary impact. This cost was never incorporated into EPA's impact analysis. Second, due to this outage time and the loss ofproduction AlliedSignal would not be able to satisfy its customer base, thereby losing market share.
• In a highly competitive market such downtime would create far reaching business impacts for which it is difficult to assign a precise a monetary value. Nevertheless, EPA cannot overlook such impacts when it analyzes the costs associated with retrofitting a manufacturing process.
The design requirements and cost estimates for process changes also differ from those associated with a pollution control project, resulting in higher costs. These costs" also were never included in EPA's impact analysis. For example, it is typical that many pollution control devices will be developed and sold as a package ofequipment. The equipment is often an "add-on" to the end ofthe process and does not require a significant amount ofadditional process piping to make it

### functional. But in the case ofthe PET )
17

### ) MACT standard at issue, process equipment modifications such as incorporating vacuum jet systems, will be added to the middle ofa process and will require a significant amount ofadditional process piping to complete the installation and make the unit functional. The costing methodologies thatEPA uses for pollution control equipment, where the installation costs are a percentage ofpurchased equipment, will always understatethe costs required toinstall a process change since items such as additional piping are never included.



### 4. EPA's Impact Analysis Failed to Recognize That theHigh Viscosity Process RequiresAdditionaLGlycol Recoyery Equipment as Compared to OtherPETProcesses
Dueto the requirements ofproducts using the high viscosity resin to have consistent heat stability and other physical properties, the high viscosity process is designed to minimize the amount ofdiethylene glycol (DEG) present as a bound impurity in the final resin. Inthe PET process, various streams ofethylene glycol are returned to theprocess for further use. DEGis formed as an impurity in the process and must be removed from any recycled streams. The requirement to minimize DEGin these streams requires additional equipment to reduce the DEG level in the recycled stream.

EPA'sproposed use ofethylene glycoljets in place ofsteamjets would change the characteristics ofthe streams that are recycled back to the process, making the ethylene glycol concentrations much higher, creating more ethylene glycol to handle and causing
more DEGto be formed due to the vaporization ofethylene glycol for use in the proposed

18

# •

. .'



### ) jet system (afactor that will have an additional impact on the high viscosity multiple end finisher process). The changes to the characteristics ofthe recycled ethylene glycol streams requires changes to the equipment used for handling recycled ethylene glycol and reducing DEG, such as additional evaporators or glycol recovery distillation units. These costs were not included inEPA's impact analysis, resulting in the creation ofanother factor which caused an understatement ofthe cost impact on the high viscosity multiple end finisher process.



### B. Implementation oftheProposed PET Continuous TPA MACT Standard to Eliminate the Use ofCooling TowerWater in the Vacuum System Contact CondenserWould Create an Enormously Disparate Cost Impact on AlliedSignal's Moncure Plant
As discussed above, EPA's evaluation ofthe impact on the PET industry to meet the proposed standard to eliminate the use ofcooling tower water in the vacuum system contact condenser never properly evaluated the numerous additional unique impacts on the high viscosity multiple end finisher process. The failure to properly evaluate these impacts results in substantial additional costs ofcompliance that were never evaluated by EPA. EPA developed a facility-by-facility analysis ofthe cost ofcompliances for almost all ofthe existing facilities in the other 27 categories and subcategories, including the costs to meet various portions ofthe standards for storage vessels, process vents, equipment leaks and wastewater. By stark comparison, no such information for the PET industry
was publicly presented for review and comment. EPA's effort to maintain the cost

5 Document II-B-27. 19

### information for the ethylene glycoljets supplied by one facility as confidential business information resulted in very little information in the docket being available on costs of compliance to the PET industry. As 

### a consequence, it appears that EPA's effort to maintain the confidentiality ofthe ethylene glycoljet cost information inadvertently resulted in the exclusion from the docket ofthe PET industry cost analysis for all portions ofthe standard. Since EPA did not provide any information on the cost ofcompliance for PET facilities to meet the proposed standard to eliminate the use ofcooing tower water in the
vacuum system contact condenser, it is impossible for commenters such as AlliedSignal to completely compare the real cost ofcompliance for the high viscosity multiple end finisher process to those costs estimated by EPA. Nevertheless, based on the scant information

_ which could be gleaned from the docket, AlliedSignal was able to develop an initial

..-......**~'** 

### understanding ofthe cost impacts for its Moncure Plant. AlliedSignal began its analysis by noting that the March 29 preamble does set forth the capital costs, annual costs and cost effectiveness analysis for the entire PET continuous TPA subcategory as a whole, which consists of 12 facilities, including AlliedSignal's Moncure Plant. This information shows that EPA estimated that the total capital cost for all 12 facilities to come into compliance with this rule would be $40,790,000, or an average ofapproximately $3,400,000 for each ofthe 12 PET continuous TPA facilities in this category, with annual costs averaging $2,970,000 per year and a cost effectiveness of$1,230 per megagram.

I )


### 20

### AlliedSignal conducted an intensive engineering evaluation to thoroughly evaluate what would be required to eliminate the use ofsteamjet system and replace them with ethylene glycoljet systems and scrubber systems at the Moncure Plant. Replacing existing steamjet systems with ethylene glycoljets is thebasis EPAused to develop costs estimates for PET facilities to come into compliance with the proposed standard to eliminate the use ofcooling tower water in vacuum system contact condensers. AlliedSignal conducted this analysis in two ways, both ofwhich are included with extensive amount ofdetail in Attachment I ( "AlliedSignal CostAnalysis

- AnnualCosts

- GlycolJets andScrubber") 

### and Attachment II ("AlliedSignal CostAnalysis

- Capital Costs

- GlycolJets 

### andScrubber''). 

### AlliedSignal's analysis was done in two ways: (1) using only EPA factors to determine capital costs and annual costs and (2) using a

# ~ quantity based estimating method supplemented by AlliedSignal factors and cost estimates

.",.-' 

### to determine the cost ofcompliance.

The second approach, using AlliedSignal's cost estimates, is an accurate, up-todate engineering analysis ofwhat AlliedSignal believes it would actually cost for the Moncure Plant to be in compliance with the proposed standard to eliminate the use of cooling tower water in vacuum system contact condensers and replace existing steamjets with ethylene glycoljets. An 

### analysis using the EPA factors is presented in order to evaluate the impact on the high viscosity multiple end finisher process in a manner that is consistent with the approach normally used by EPA. 

### AlliedSignal strongly believes that the EPA approach is inaccurate and presents an out-of-date analysis for various costs. )
21

### AlthoughEPA's approach is presented, AlliedSignal does not support its use. EPA's approach relies on outdated information and, therefore, is not an accurate procedure for conducting regulatory impact analysis.
AlliedSignal's evaluation supports the fact that the several critical facts that EPA did not take into account, as presented in Section II, above, resulted in a huge underestimation ofthe impact on the high viscosity multiple end finisher process. Using EPA's factors and cost estimate, the total capital cost forjust retrofitting the Moncure Plant to a process using ethylene glycoljets is approximately $26,000,000. 

### See Attachment

## n. This compares to EPA's analysis that the entire PET continuous TPA industry added together would incur a capital cost ofapproximately $40,000,000. The 

### t:7

1 

# !i\ retrofit capital costs and EPA's annual cost factors result in an annual cost of

'.**~.,** 

### approximately $4,800,00 and a cost effectiveness of$27,800 per megagram. 

### See Attachment I. 

### This cost effectiveness, using EPA's cost factors, is greater than 2,000% higher than EPA's estimate for the PET continuous TPA category for the entire rule.
Using AlliedSignal's engineering procedures, the second approach developed by AlliedSignal reflects the actual costs that are expected to occur in order to retrofit the Moncure with an ethylene glycoljet system. This estimate resulted in a total capital cost in excess of$55,000,000. The expected annual cost is in excess of$24,000,000, and the cost effectiveness is $140,916 per megagram ofemissions reduction. Attachments I and II 

### :)
22present a detailed item-by-item analysis ofthis option. A summary ofthe results ofthis analysis is presented 

### in Table 1.

It is important to recognize the cost ofthe items that EPAfailed to incorporate in their analysis and which were discussed in our comments in Section IT. A. above. An ethylene glycoljet vacuum system is estimated to have a purchased equipment cost of$200,000

- 300,000. At the Moncure Plant, EPA'sfailure to recognize that the multiple vacuumjet systems are necessary in the high viscosity multiple end finisher process results in more than $1,000,000 

### in capital cost not being included in the EPAimpact Average Capital Annual Cost Cost Effectiveness Cost ($1000) ($1000) ($/megagram) Average per Facility PET 3,400 2,970 1,230 Impact (from 3/29/95 preamble)

MoncurePlant Impact (using EPA 26,049 4,777 27,776 factors) MoncurePlant Impact (using 55,000 24,000 140,916 A1liedSignal cost estimatesl Table 1Proposed Rule

- Cost ofCompliance analysis. EPA's failure to include a scrubber system to remove oligomers and other solids from each reactor results in EPAfailing to recognize another $7,000,000 in capital costs.

A cost effectiveness analysis using what AlliedSignal believes to be an accurate \ analysis ofthe true costs required to meet the proposed standard is more than 11,000%

. I**~/** 23higher than that estimated by EPA. It should be obvious to EPAthat the fatal flaws in EPA's analysis results in a tremendous cost to the high viscosity multiple end finisher process that was completely unanticipated by EPA. Any control option that predicts a cost effectiveness near $140,000 per megagram is absurd and unsupported by any reading ofthe Clean Air Act. C. EPA's Beliefthat OtherTechnologies are Feasible to Eliminate the Use ofCooling TowerWater in the Vacuum System Contact Condenseris Not Supported by the Proposal and is Technically Flawed
In Section 7 oftheBasis and PurposeDocument, EPA states that 

### it "believes" that there are several technically feasible methods for limiting/minimizing emissions from the wastewaters generated from the PET vacuum systems. As discussed above, using**:~** ethylene glycoljetsin place ofsteamjets in the vacuum system was the method EPAused .-"' to determine the industry impact. EPA also states that mechanical vacuum pumps may be used and that non-contact condensers, in place ofthe typical contact barometric intercondenser, may be used. CAA 

### § 112(d)(3) unequivocally provides that MACT standards must be based on
an "emission control that is achieved in practice
...." 42 U.S.C. 

### § 7412 (d)(3) (emphasis added). Plainly, EPA cannot in any wayjustify a rule based on technologies it "believes" will work but for which it has not conducted a thorough technical evaluation and for which 

### ithas not developed accurate cost estimates. EPA acknowledges that "costs for these control technologies were not calculated.,,6 IfEPA had conducted an accurate analysis ofthe suggested other control technologies, it would have discovered that the ) .'" 6 Basis and Purpose Document p. 7-11
. 24

### suggested controls are impractical and costly for controlling emissions from the reactors in the PET continuous TPAprocess. The suggested controls are additionally impractical and costly for the high viscosity multiple end finisher process where the higher vacuum requirements ofthe final polymerization reactors greatly impact the ability to use such technology and would require multiple devices for the multiple end finishers. 1. Non-contact Condensers AlliedSignal investigated the potential use ofnon-contact shell and tube condensers to control emissions from the polymerization reactors at the Moncure Plant. Because ofthe vacuum in the polymerizatiQnreactors and.because the very high vacuu.m ofthe end finishers in the multiple end finisher process will result in high vapor flow rates that need to be controlled by the condensers, such condenser units would need to be

### r~ ... / extremely large. At the Moncure Plant, for example, the condensers for the initial

) ) 

### polymerization reactor are estimated to be several feet in diameter and the condenser to handle the final reactors would be even larger. At the Moncure Plant, as can be expected to occur at otherPET facilities, the existing building structures were never designed to accommodate vessels ofsuch size. Iflarge non-contact condensers had to be installed, it would be necessary to substantially modify the existing structure.

As discussed earlier, a challenge for all PET processes is the ability to manage oligomers and other solids that are generated in the reactors. Ifnon-contact condensers
on the steamjets were used, each reactor would need to have a sparejet system with noncontact condensers that could be used when cleaning ofthe otherjet system condenser is

25

### required. To minimize the cleaning requirements, a costly scrubber would be required to be installed before thejet system. The installation ofa scrubber would also raise the licensing and patent issues discussed earlier, since the scrubber design is very specific to the demands ofthe PET process, and successful designs are protected by patents.

All ofthe above factors are compounded in the PET continuous TPAhigh viscosity multiple end finisher process. The high vacuum requirements ofthe multiple reactors and the fact that there are several end finishers at the end ofthe polymerization section ofa high viscosity process would require larger condensers on thejet systems, multiple condensers, multiple structural changes and multiple scrubbers. Due to the overwhelming challenges associated with the need to modify structures at an existing**~** 

### facility, AlliedSignal did not perform an in-depth cost analysis ofthis option as it has done
.,' 

### for other options. Apreliminary assessment, assuming it is even possible to overcome the licensing and patent issues in areasonable manner, indicates that the total capital requirement for this option is equal to or greater than retrofitting the process with ethylene glycoljets.

2. Mechanical Vacuum Pumps 

### The second alternative that EPA "believes" may be used to eliminate the use of cooling tower water in the vacuum system contact condensers is the sole use of mechanical vacuum pumps. This option is completely impractical in the PET continuous TPA process. The high vapor volumes and vacuum requirements ofthe polymerization



### 26

### reactors, and the very high vacuum requirements ofthe end finishers in the mUltiple end finisher process, would dictate the use ofa large number ofmechanical vacuum pumps for each reactor. AlliedSignai estimates that more than 100 mechanical vacuum pumps would be required to retrofit its PET process. The completely impractical nature ofthis option precludes it from any further serious consideration.

D. Using theDiscretion Provided by CAA § 

### 112CC)(n and rol(n. EPA Must Establish a SeparatePETMACT Subcategory for a Continuous TPA Multiple End FinisherProcess 

### EPA'spr{)posed subcategorization for PET manufacturers using TPA on the basis ofwhether the process involved is either continuous or batch is flawed and must be revised to further account for the fundamental processing differences which place the

# ~ continuous TPA process having mUltiple end finishers in aunique PET manufacturing



## ) niche. In the final rule, EPA must correct this oversight by exercising the discretion conferred upon the Agency by Congress in CAA § 

### 112(c)(1)' and (d)(l)8 and creating for this particularprocess a new PET MACT subcategory. As 

### described more fully below, there are a number ofincontrovertible factors which mandate the development ofan additional PET MACT subcategory.

7 Following its general direction to EPA to publish a list ofcategories and subcategories ofmajor sources ofhazardous airpollutants in a manner consistent with the source categories developed under CAA § 111, CAA § 112(c)(I) provides that "[n]othing in the preceding sentence limits the Administrator's authority to establish subcategories under this section, as appropriate
...." 42 U.S.C. § 7412(c)(l). 8 "The Administrator may distinguish among classes, types, and sizes ofsources within a category or subcategory iIi establishing [MACT] standards
...." 42 U.S.C. § 7412(d)(1). 27

### First, the criteria which EPA has identified in an earlier rule and in the proposed rule for establishing a separate subcategory are easily met by PET manufacturers using TP

### A in 

### continuous processes having mUltiple end finishers. Second, EPA has already made a regulatory distinction for PET manufacturers using TP

### Ain continuous processes having multiple end finishers within the context ofCAA § 

### Ill. Third, EPA has already recognized in the proposed rule that, with respect to one criterion (process differences), PET manufacturers using TP

### Ain batch processes and manufacturers ofother types of polymers and resins with major process differences warranted extensive subcategorization,
even when only one facility was identified for a particularMACT subcategory. With respect to these latter two factors, EPA cannot elect to create subcategories for certain PET and otherpolymer and resins manufacturers and then ignore another segment which

_ not only independently meets the subcategory criteria identified by EPA for the purposes ofCAA § 

### 112 but which has also been determined by EPA to warrant separate regulatory



### ) treatment within the context ofCAA § 

### Ill.

1. Implementation ofthe Criteria Identified by EPA for Establishing SeparateMACT Subcategories Within the Group IV Polymer and Resins Category Conclusively Supports the FurtherDisaggregation ofthe 

### PET Continuous TPA Subcategory into a New Subcategory



### When the Agency identified in 1992 the industry categories for which it would eventually promulgate MACT standards, it took great pains to explain that "[t]his decision does not affect the degree ofdisaggregation ofindustry groups...or the authority ofthe

28Agency to distinguish among classes, types, and sizes ofsources in establishing emission standards. During the standard setting process, the Agency may in some cases find it appropriate to...further divide a category. This decision does not affect the Agency's authorityto define subcategories ofsources at a later date." 57 Fed Reg. at 31,57911 (July 16, 1992). How such categories and subcategories would eventually be established would depend on similarities in: Process operations (including differences between batch and continuous operations), emissions characteristics, control device applicability and costs, safety, and opportunities for pollution prevention. The Agency anticipates that all of the above criteria, and perhaps others, can be accounted for appropriately by the Agency only after gathering significant information for each listed category ofsources during the
course ofestablishing emission standards."Id. at 31,58013 (emphasis added). More

### r~f1_ recently, the Agency reiterated that it "retains flexibility, for example, to conclude that the

.. "/

,**~,-** production processes used at particular sources in the relevant category are sufficiently different from processes used at other sources in the same category tojustify the creation ofanew subcategory." 59 Fed. Reg. 29,196, 29,20011 (June 6, 1994).

Within the context ofthe proposed rule, the Agency chose to subcategorize four of the seven Group IVpolymers and resins categories, creating five subcategories for ABS, three subcategories for SAN, three subcategories for polystyrene, and four subcategories for PET. Each ofthese four source categories "was subcategorized to account for major differences in production methods, raw material usage, orboth." 60 

### Fed. Reg. at 16,092 (emphasis added). Inthe case ofthe four subcategories for PET, the Agency made an

29

### initial distinction between PET manufacturing on the basis ofraw material usage (TPA and DMT) and afurther distinction based on whether the process using each raw material
was continuous or batch.

While the Agency correctly began the process ofsubcategorization by delineating PET manufacturing according to raw material usage, the Agency evidently was unaware ofseveral significantly different manufacturing processes employed by facilities using TPA
as a raw material. As explained in detail in Section II, above, a significant distinction exists between manufacturers oflow viscosity PET for the textile, apparel and resin markets and manufacturers ofhigh viscosity PET for the tire and industrial markets. Both high and low viscosity manufacturers rely on continuous and batch processes. But, as also**t~** 

### described in significant detail in Section II, above, continuous low viscosity manufacturers
use a single finisher system, while continuous high viscosity manufacturers use either a multiple end finisher system or a solid state reactor downstream ofa single finisher system. Thus, significant process differences exist not only between continuous high and low viscosity manufacturers but within the high viscosity manufacturing segment. Yet the "continuous TPA" subcategory for PET manufacturers fails to reflect these further distinctions, leading to the Agency's erroneous proposal to establish MACT for this subcategory solely on the basis oftechnology applicable to continuous low viscosity single finisher systems.

- 

### )

.**.~.** 30, j Faced with the information submitted to the Agency in these comments, and at the meeting held between representatives ofAlliedSignal and EPA on May 11, 1995, EPA must further apply the latter ofthe two criteria identified in the proposed rule for initially establishing the four PETMACT subcategories to create in the final rulemaking an additional subcategory encompassing only thosePET manufacturers using TP A in continuous processes having multiple end finishers. As conclusively demonstrated in Section 

### ill, above, these contrasting process differences create an enormously disparate cost impact for continuous high viscosity manufacturers with multiple end finishers faced with implementing a MACT standard predicated on a low viscosity single finisher system, thereby eliminating any possible conclusion by the Agency that the process differences discussed above amount to nothing more than a theoretical distinction without a "real world" difference. 

### 2. EPA's EarlierRegulatory Treatment ofthe PETIndustry Also Unequivocally Supports the Establishment ofan Additional Subcategory On the heels ofthe enactment ofthe 1990 Amendments to the Clean Air Act, EPA promulgated anNSPS onDecember 11, 1990 which established standards ofperformance for VOC emissions from the polymer manufacturing industry, including manufacturers of PET using TPA. In this NSPS, which was codified at 40 C.F.R. Part 60 Subpart DDD, EPA expressly recognized the various process differences which exist for manufacturers of PETusing TPA. In that regard, the Agency specifically defined the terms "continuous process," "end finisher," "lowviscosity [PET]," "high viscosity [PET]," [PET] manufacture using [DMT]," and "[PET] manufacture using [TPA]." 40 C.F.R. 

### § 60.561.

31

### Through these definitions, EPA recognized not only the distinction in the PET industry based on raw material usage and continuity ofprocess, but also the differences between low and high viscosity PET and the number offinishers used in the manufacture ofhigh viscosity PET. For process emissions standards established underthis rule, the Agency first differentiated between PET manufacturers using TPAand DMT and then established, for users ofTPA, 

### one set ofethylene glycol control requirements for the production of low viscosity PET using single or multiple end finishers and high viscosity PETusing a single end finisher and yet another set ofstandards for producers ofhigh viscosity PET using multiple end finishers. Compare id. 

### § 

### 60.562-1(c)(ii)(B) with 

### § 

### 60.562-1(c)(ii)(C). Without prompting from commenters, EPA recognized as early as 1987, when it first proposed this NSPS, thatthese critical TPA-based process differences existed. See 52 

# f_ Fed Reg. 

### 36,678 (Sept. 30, 1987)
.

........ 

### In the context ofthe current proposed rulemaking, EPA is statutorily bound to consider the earlierreasoning it employed in developing categories ofregulation for the polymer manufacturingNSPS. CAA § 

### 112(c)(1) specifically provides that "[t]o the extent practicable, the categories and subcategories listed under this section shall be consistent with the list ofsource categories established pursuant to section 111
..." EPA must, therefore, do more than simply repeat the requirements ofthe NSPS PET standards. 60 Fed. Reg. 

### at 16,094-95. The Agency must recognize in the final PET MACT rule that the categories ofregulation established for the purposes ofthe recently promulgated NSPS apply with equal force to the general development ofPET MACT subcategories and use

32

### its earlier regulatory determinations to help support the specific development ofa subcategory for PET manufacturers using TPAin a continuous process having multiple end finishers. 3. Existing Analytical Precedent in the Proposed Rule Supports the Creation ofan Additional PETMACT Subcategory in the Final Rule 

### Viewed from several perspectives, precedent already exists within the proposed rulemaking for supporting the establishment ofan additional subcategory for PET manufacturers using TPAin continuous processes having multiple end finishers. In the context ofthe ABS category, the Agency realized that a subcategory distinction could not be solely based on the difference between continuous and batch manufacturers and further subdivided continuous manufacturers on the basis ofan additional process permutation 

# f_ "mass" and "emulsion"--and batch manufacturers on the basis ofwhether that type of .'

, ...-' 

### process involved "suspension," "emulsion," or "latex." Here, the Agency recognized that additional process distinctions--like those present for PET manufacturers using TPA-- could reasonably support the creation ofseparate subcategories beyond the initial difference between batch and continuous operations.

Just as significantly, the Agency has seen the necessity for establishing subcategories for certain categories, even when to do so would result in only one facility within a given subcategOIY. Subcategories having only one identified facility consist of "ABS-batch latex," "SAN-ASNAMSAN," 

### and "PET-TPAbatch." See 

### 60 Fed. Reg. 

### at 16,092. Thus, even ifAlliedSignal's Moncure facility happened to be the only facility 

### )
33"'''', 

### which uses TPA on a continuous basis with multiple end finishers, precedent would still exist in support ofa separateMACT subcategory for such manufacturers.
IV. FORTHENEW PETMACT SUBCATEGORY WHICH MUST BE ESTABLISHED BY EPA FORTHE CONTINUOUS TPA HIGH VISCOSITY MULTIPLE END FINISHERPROCESS, THE AGENCY MUSTADOPT AN ALTERNATIVE MACT STANDARD FOR CONTROLLINGCOOLING TOWEREMISSIONS
As explained in Sections II and III, above, the fundamental process differences that
are part ofthe PET continuous TPAhigh viscosity multiple end finisher process must be taken into account when developing a MACT standard for this particular subcategory. In 

### the following sections, A1liedSignai presents and evaluates an alternative MACT standard which must be adopted in the final rule for this new subcategory. A1liedSignal's**~** 

### alternative control technology for the PET continuous TPA high viscosity multiple end**_,r~/**

i 

### " finisher process continues to allow cooling water to be used in the contact condenser, but controls the level ofethylene glycol in the tower water, thereby minimizing emissions. Attached in the confidential portion ofthis document is a detailed cost analysis for what would be necessary to modify A1liedSignal's Moncure Plant using this approach. See 

### Attachment III ("AlliedSignal CostAnalysis

- Annual Costs

-Alternate Control Strategy") 

### and Attachment IV ("AlliedSignal CostAnalysis

- Capital costs - Alternate ControlStrategy'').

34**~**

### ~ --_..; 

### A. An AlternateMACT Standard for Cooling Towers in the PET Continuous TPA High Viscosity Multiple End FinisherProcess


### Cooling towers are the largest single source ofethylene glycol emissions at a PET continuous TPA multiple end finisher process. Following the approach established by EPAin theNSPS SubpartDOD, AlliedSignal's alternative would focus on the level of ethylene glycol'present in cooling tower water and maintain that level at 4%, which is 33% less than that required by the NSPS. AlliedSignal has verified that ethylene glycol is the onlyHAP present in its process by conducting an evaluation to determine ifacetaldehyde is present. The efforts to date have never been able to find a detectable amount of acetaldehyde. 9


### B. Evaluation ofAlliedSignal's Alternate MACT Control for Cooling Towers on thePET Continuous TPA High Viscosity Multiple End FinisherProcess
In 

### order to maintain the ethylene glycol level in the cooling tower system at or below 4%, the existing ethylene glycol recovery system would have to be upgraded. Modification to the distillation system would be required to allow for additional recovery ofethylene glycol from the reactor stream. The recovered ethylene glycol will be sent backto our supplier to be further recovered and reused.

9 AlIiedSignal operates its esterification vessels under pressure, which is believed to beunique among the otherPET continuous TP A processes and may contribute to the lower acetaldehyde levels. Based onthe analytical detection limit ofacetaldehyde, it is believed that less than 400 pounds peryear is generated in the process. 35

### The current level ofethylene glycol in the cooling towers at the Moncure Plant is**~**.. 

### just under 7%.10 

### The NSPS standard for the PET mUltiple end finisher process is 6%. 

### AlliedSignai evaluated both the cost and cost effectiveness to reduce the ethylene glycol from 7%

### to 3% 

### in 1% 

### increments. A summary ofthis analysis is shown in Table 2.

EtllyleaeG1yeol WaterFeed TotllADDUII IDeremeDtal IDeremeatal IaeremeDtal Levell" to DIJtlUaUoa StelmCost ADDUIleost Emlsslo. (MgIyr) CostEffecdveaess COOUDg Tower (PPH) Reduedoa 7% 22,200 S1,750,248 6% 27780 S2,190,175 S439927 24 5% 38890 S3,066,088 $875913 24 4% 55,560 $4,380,350 $1,314,262 24 3% 111,110 $8,759,912 $4,379,562 24



### Table 2. Incremental Cost for Decreasing EGLevels in Cooling Tower 

### The ability to reduce the ethylene glycol emission from the cooling tower is
• directly related to the amount ofmaterial fed to the recovery equipment. The additional material that must be sent to glycol recovery is represented by column 2. Using AlliedSignal,s experience that it

### takes approximately 1.5 pounds ofsteam to recover ethylene glycol from a pound ofwater, and using a steam cost of$6 per 1000 pounds of (Slmg)



### steam, the annual steam cost for each level ofglycol in the cooling tower was calculated in column 3. The emissions from the cooling towers are linearly correlated to the amount of ethylene glycol in the tower and are based on a windage rate including evaporation and drift losses and the cooling tower circulation rate.

10 The NSPS standard does not currently apply to the Moncure Plant because it is not an "affected facility." 36 S18330 $36,496 S54,760 $182,481

### The last column in the table above shows the incremental cost per megagram of incremental emission decrease for each level ofethylene glycol in the cooling tower. The significant incremental cost increase for reducing the ethylene glycol levels in the cooling towerto alevel less than 4% 

### was considered by AlliedSignal not to be reasonable.

The capital cost and total annual costs for this alternate approach are provided in detail in the confidential section ofthis submission identified as Attachment III and IV. As


### was done to evaluate the costs to retrofit the Moncure Plant with ethylene glycoljet systems, AlliedSignal's evaluation ofits alternative approach is presented in two ways: (1) 

### using only EPA factors to determine capital costs and annual costs; and (2) 

### using AlliedSignal factors and cost estimates to determine the cost ofcompliance.

The second approach, using AlliedS ignal' s cost estimates, is an accurate, up-todate engineering analysis ofwhat AlliedSignal believes it

### would actually take for the Moncure Plant to be in compliance with the suggested alternate approach. The alternate approach reduces emission from the current level ofapproximately 172 

### Mg/yr to 98 

### Mg/yr
or 43%. 

### This compares favorably with EPA's analysis that the MACT as proposed would achieve a nationwide HAP 

### reduction of40% 

### from the PET continuous TPA subcategory. 

### See 60 

### Fed. Reg. at 16,109.

37'.",

## ~) Using the AlliedSignal factor, the total capital cost for the Moncure Plant to complete this installation is $5.9 million, with a total annual cost of$2.6 million. The resulting cost effectiveness ofthis option is $35,564 perMegagram.
Using the EPAfactors for estimating annual and capital costs the cost effectiveness is $7,363 permegagram. The cost effectiveness using EPA's factors is at the high end ofany option that EPAhas chosen for any ofthe other Group IVpolymer and resin subcategories. l1 Table 3 summarizes the results ofAlliedSignal's evaluation and compares the capital cost, cost effectiveness and percent emission reduction that would
occur at the Moncure Plant using AlliedSignal's proposed approach and that which EPA predicts would occur for the entire PET continuous TPA industry based on the proposed rule. 

### Capital Cost : Cost Effectiveness**Pen~cent** Emission j Reduction ! Group 

### IVPolymerlResins $1,259,871 12 ! $1,050 Mg 47 

# !**L.(!.:~~.~~.~!:y'.~y'g)................................................** . ..............................................1.......................................................
. ...................................................

## ..1 ! Pet Continuous TPA $3,400,000! $1,230 Mg 40 !

## L.(!.:~~~~.~!:Y..~y.g)................................................ . .............................................

## .i.
...................................................**~..** 

## . ...................................................

# .J i AlliedSi nal Alternative $5,900,000 

## i $7,400 M 43 

## i Table 3. Comparison ofCost for Alternate Compliance Option
As can be seen by this table, AlliedSignal's proposed alternate is consistent with the impact and emission reductions present by EPAfor the proposed rule.

II The ABS, continuous emulsion subcategory is shown with a cost effectiveness of<$7,160 per Mg. 12 Calculated using total capital cost of$98,000,000 as presented in the preamble and detennining impact for 78 facilities as showby document II-B-16 in the docket. 38

### V. EPA SHOULD NOTDESIGNATE ALLWASTEWATERSTREAMS FROMTHE VACUUM SYSTEM AS GROUP 1 WASTEWATER STREAMS 

### EPA proposes to automatically classify any wastewater stream from the vacuum system ofaPET facility as a "Group I stream," as this term is defined by the HON Rule. 

### See proposed 40 C.F.R. § 

### 63.507-2. Group I streams are required to meet the requirements ofthe HON contained in 40 C.F.R. §§ 

### 63.132

- 63.148, which include treatment requirements for wastewater and residuals and standards for equipment such as individual drain system, containers and tanks.
Automatically classifying wastewater streams from the vacuum system as Group I, regardless ofthe HAP concentration and flow rate, will cause a significant amount of confusion on how the HON standards will apply and create additional cost impacts that EPAfailed to include in its PET-MACT impact analysis. Moreover, such a classification will create a significant burden on PET facilities with no realization ofHAP emission decreases. Finally, the classification would simply be unnecessary under the cost effective alternative for control discussed in Section IV, above. For these reasons, as explained in detail below, EPA should not automatically designate wastewater streams as Group I.

39

### A. Automatically Designating Wastewater Streams From PETVacuum Systems as a Group I Stream Causes Confusion on How the HON Standards Are to Apply Byway ofbackground, AlliedSignal supports the basic approach set forth in 

### § 63.132 ofthe

### HON for making Group 

### I and Group 

### II wastewater determinations. The basic approach in the

### HON rule is to evaluate the characteristics ofthe wastewater stream and to then designate a stream as a Group I orGroup 2 stream in accordance with that evaluation. The 

### HON designates as Group I any stream which meets anyone ofthe following two criteria: (1) any stream with a volatile hazardous air pollutant 

### (VOHAP) concentration greaterthan 

### 10,000 parts per million; or 

### (2) streams with a flow rate greater than 

### 10 liters per minute 

### and a 

### VOHAP concentration greater than 

### 1,000 ppm.

The proposed MACT standard for the PET

-TPA facility incorporates this same concept for all streams except for streams for the vacuum system, where the stream is designated as Group I regardless offlow and HAP concentration. The PET-MACT proposal at 

### § 63.508 then requires all Group 

### I streams to comply with the standards contained in 

### §§ 63.132

- 63.148 ofthe 

### HON. The proposed PETMACT standard for TPA vacuum system wastewater automatically designates the stream as Group I "regardless ofthe HAP concentration and flowrate for the stream." Thus, while the HON contemplates that an evaluation ofthe stream characteristics has taken place, resulting in a determination that the VOHAP concentrations exceed the threshold levels which require treatment, the 

### § 63.138 treatment requirements are based on the assumption that there are levels ofHAPs which exceed the same threshold levels.

40Inthe case ofAlliedSignal's mUltiple end finisher process, this result creates confusion on how to apply the 

### § 63.138 treatment options since the wastewater streams from the vacuum system will have VOHAP concentrations that already meet some ofthe treatment options contained in 

### § 63.138. For example, one available option in the HON is to treat the stream to a VOHAP concentration less than SO ppmw. The wastewater from the MoncurePlant's vacuum system is expected to be less than this level as it is generated. These streams are largely comprised ofethylene glycol which, due to its vapor pressure, EPAhas determined through the HONrule that is not a volatile HAP, that it has little or
no emission potential and that it is not cost-effective to treat.

It is simply unclear in the proposed standard whether or not this stream requires treatment. Furthermore, under the HON rule, all equipment that handles a Group I stream must be designed in accordance with the standards ofthe HON. This, for example, requires Group I streams to be handled only in a drain system that is enclosed and that has all vapors directed to a control device. Such management is required by the HON rule until such time that the stream meets the treatment requirements of

### § 63.138 (or is recycled backto the process). Using the above example, it is unclear ifa stream from the PET vacuum system, which has almost no volatiles, is required to be handled in this totally enclosed manner and, ifit is, when the requirements stop.

41

### B. Automatically DesignatingWastewater Streams From PETVacuum Systems as a Group I Stream Creates Additional Cost Impacts that EPA Failed to Include in Its Impact Analysis ofthePETIndustry Pursuant to 

### § 63.138 ofthe HONrule, any residual removed from a Group I wastewater must be controlled for air emissions by directing vapors to a control device and by further managing the residual itselfin the process orthrough destruction ofthe total HAP mass by 99%. TheHON at 

### § 63.111 defines "residual" as "anyHAP containing water or organic that is removed from a wastewater stream by a waste management unit ortreatment process that does not destroy organics (nondestructive unit}
...." By automatically designating PET vacuum systems as Group I streams regardless offlow and concentration, any material removed from the stream, including the oligomers, must be handled under one ofthese two options. The requirement
• to control by 99% is independent ofHAP concentration or amount ofHAP. In orderto ;.' achieve 99% destruction, it appears that the material would be required to be incinerated. By automatically designating streams from vacuum systems..as Group I, EPAhas not only caused confusion as to the type and amount oftreatment a stream must receive, but it has also subjected solids, that may have no VOHAPS, to a costly requirement of99% destruction. Nonetheless, nowhere in EPA's cost impact analysis does the requirement to destroy non volatile solids by 99% show up in its impact analysis.

Under 

### § 63
.132(j) ofthe HONrule, an owner/operator that sends a Group I wastewater stream, or a residual removed from a Group I stream, to an offsite location for treatment or for sale for any purpose, must ensure that the wastewater stream orresidual

42is ultimately treated in accordance with the requirements of

### §§ 63.132-63.138. In the PET

-TP A process, it is common for ethylene glycol to be sent backto vendors for recycle. The ethylene glycol at the Moncure Plant has little or no volatile material, and would not be considered a Group I stream ifit were to be subject to the Group I/Group II determination ofthe HON. Nonetheless, by automatically designating a stream from
vacuum systems as a Group I wastewater stream, regardless offlow and HAP concentration, all ethylene glycol from the reactors that may be recycled at an off-site location could only be handled at a site that meets all the equipment standards ofthe HON. This includes the requirements to collect vapors from wastewater and residuals and direct them to a control device and the requirement to destroy residuals by 99%.**'\}ll:'"** '-."**~:.j~**...;q ". Once again, the requirement to manage Group I streams and residuals from Group

... I in this rigorous a manner when they are sent off site is never included in EPA's impact analysis. It is important to keep in mind that these standards werejustified in the HON because the only streams that must meet these requirements are those that were evaluated 

### in accordance with the HON and found to have more than a threshold amount ofvolatile HAPs. The presence ofvolatile material in an amount greater than the threshold levels justified the special handling requirements because ofthe resulting reduction in volatile HAP emissions. Thisjustification simply does not exist in the PETMACT standard. Wastewater from the PET vacuum systems must be handled in this manner regardless of HAP concentration and flow rate because the rule automatically classifies the streams as Group 1 streams.

43\ 

### In 

### summary, EPA must delete that portion ofthe standard which automatically classifies awastewater stream from a vacuum system as a Group I stream. To further rectify the issues raise above, EPA must adopt the approach employed in § 63.132 ofthe HONfor making Group I and Group II determinations.

VI. TO OBVIATE THE CREATION OFMEANINGLESS MONITORING AND RECORDKEEPINGREQUIREMENTS WHERE THE POTENTIAL FOREMISSIONS IS MINIMAL, THE EQUIPMENTLEAK PROVISIONS OFTHEPROPOSED RULE SHOULD SIMPLY NOTAPPLY TO THE TPA CONTINUOUS PROCESS 

### Section 63.509, ofthe proposed rule incorporates Subparts H 

### and I ofthe HON 

### rule as the basis for the equipment leak requirements for aPET continuous TPAhigh viscosity multiple end finisher process. The nature ofthe process and materials at the Moncure Plant is such that essentially all ofthe equipment which would be covered under Subpart H is either "in heavy liquid service" or "in vacuum service." Section 63.162 provides for an exclusion ofthe requirements ofSubpart H for equipment that is in
vacuum service. Section 63.169 requires that pumps, valves, connectors and agitators in 

### heavy liquid service be monitored within five calendar days by the method specified in 

### § 63.1S0(b) ifevidence ofa potential leak is found. As explained below, sources producing PET using the continuous TPA multiple end finisher process have equipment which is in "heavy liquid" service or "vacuum" service. Thus, the relatively small amount of equipment in organic hazardous air pollutant service emits an insignificant amount of fugitive emissions compared to point sources. Aleak detection and repair procedure is



### 44already in place for the equipment in gas/vapor service for safety and process quality control reasons. To impose an additional leak detection and equipment identification requirement would create an unnecessary recordkeeping and administrative burden.

PET is manufactured at AlliedSignal's Moncure Plant by the continuous reaction ofTPA and EG. The "RawMaterial Preparation" section ofthe Plant includes the unloading and transfer ofrawmaterials to the process, paste preparation and the initial chemical reaction oresterification stage ofthe process. EGis handled in heavy liquid service as it is pumped from tank cars to a storage tank and from the storage tank to the production building. The vapor pressure of EGis 0.011 kPa at 200 C, which is well below the vapor pressure threshold (i.e. >0.3 kPa) for "light liquids" orliquids that contribute to
• fugitive emissions. Any leaks from heavy liquid service would be detected visually as dripping liquid, not as vapor leaks to the atmosphere. Overhead pipe bridges are routinely inspected to detect leaks.

Esterification ofEGand TPA is performed in a series ofvertical, cylindrical, staged vessels. The esterification vessels operate at 260

- 2800 C and at positive pressure, which is created by the vaporization ofEG, inhibitor and water (reaction product). Pressures decrease through the esterification vessels from about 150 psi in the first vessel to approximately 15 psi in the last vessel. Vapor composition ranges form about 42% EG /56% water in the first esterification vessel to 59% EG/40% water in the final esterification vessel. The types ofgas/vapor equipment associated with the esterification

45

### stage are listed in Table 4 along with calculated emissions using SOCMI emission factors. While the factors used in 

### these emission calculations are believed to be higher than actually occur, they still demonstrate that equipment leaks are very small compared to point source emissions, making a leak detection/repair requirement unnecessary.
Esterification vapor leaks present serious safety concerns because ofthe risk ofan EGvapor expolsion. Forthat reason, following a process outage where changes have been made to esterification equipment, such as removal oftransfer lines, control valves, rupture discs, agitator seals, etc., aroutine 2 - 3 hour leak check is conducted by introducing hotEGvapors into the system to identify vapor leaks. Leaks, are repaired by tightening flange bolts before introducing raw materials into the process. Leak detection

### ~ has been a successful part ofequipment startup for the past 24 years.
The polymerization section ofthe process is carried out under vacuum conditions created by either vacuum pumps or steam ejectors. Operating pressure for polymerization vessels ranges from 2 torrto 0.5 torr. These pressure conditions are clearly operating in ''vacuum service" as defined by § 

### 63.161 ofSubpart H. Section 63.162 (d) ofSubpart H specifically excludes equipment that is in vacuum service from the requirements of SubpartH. Ifa leak occurred in equipment undervacuum service, atmospheric oxygen wouldbe sucked into a vessel or vapor line and no HAPs would be emitted. Should this event occurfor a PET process, leaks into the vapor condenser/recovery system would adversely impact the ability to maintain vacuum in the vessel, resulting in PET degradation

46

### and productquality concerns. Forthese product quality and safety reasons, leak detection and repair are already a high priority in the continuous TPA multiple end finisher process.

Due to the predominanttransfer ofmaterials in "heavy liquid" service, the low vapor pressure of EG, the low potential for VOC emissions from equipment leaks «2,100 kg/yr) in 

### the process raw materials preparation section and the vacuum conditions that prevent equipment leaks in the process polymerization section, the equipment leak provisions ofthe proposed MACT standard for the continuous TPA

### multiple end finisher process should be eliminated. The cost ofrecord keeping and implementing aformal equipment leak detection and repair program would far outweigh the benefits of decreasing an already low fugitive emission.

Type ofEguipment Agitator Seal Flanges Manhole Covers Rupture Disc Valves (vapor service) Sampling Connections Pumps Compressors Pressure Release Devices Open-ended lines Number of Units 2 70 10 10

8 2 

## o o o o SOCMI Emission Factor (kglhr/sourcel 0.0494 0.00083 assume 0.00083 0.00083 0.0056 0.015 0.0494 0.228 0.l04 0.0017 TOTAL Calculated Annual Emissions 0.0988 0.0581 0.0083 0.0083 0.0448 0.03 0.0 0.0 0.0 0.0 0.2483 kglhr Annual Emission Calculation: 0.2483 kglhr x 24 hr/day x 365 days/yr = 2,175 kglyr ofVOC Table 4. Equipment Leak Determination Moncure Piantil13 Emission estimates calculated using SOeM! emissions factors chosen to represent the fugitive emission characteristics ofthe polymers and resins industry (reference Table 6- 12. EPA-450/3-83-019a PolymerManufacturingIndustry

- BackgroundInformationfor ProposedStandards).
47**~-"**....\)**~** 

## vn. EPA SHOULD MAKE THE STORAGE VESSEL REQUIREMENTS INAPPLICABLE TO THE PET CONTINUOUS TPA PROCESS 

### Since the PET continuous TPAprocess does not handle any raw material or product that has a vapor pressure high enough to exceed the threshold levels requiring control, for any size vessel, no emission reduction will be achieved by promulgating the standard. Because the existence ofsuch a standard would simply create anunnecessary paperworkburden, EPA should make the standard inapplicable to PET continuous TPA facilities.



## vm. THEEMISSIONS AVERAGING PROVISIONS IN THE PROPOSED RULE REQUIRE MINORREVISIONS AND, CONSISTENT WITH THE BON, SHOULDBEEXPANDED TOALLOWADDITIONAL POINTS TO BE AVERAGED 

### The "emissions" averaging provisions contained in proposed § 

### 63.510 are essentially the same as the emission averaging provisions contained in the HON. The proposed emission averaging scheme would allow emission averaging among five collocated existing emission points in the same subcategory. The number ofpoints may be increased by three additional points ifpollution prevention measures are to be included in the average. The HON rule provides for emissions averaging among 20 points, with the option to raise the number to 25 ifpollution prevention measures are included. Consistent with the HON Rule, the emissions averaging provisions in the proposed MACT for the Group IV Polymer and Resins should be modified to allow for 20 points to be included in the emission average with the option to increase to 25 ifemissions averaging is used. In



### 48...'\ addition, several other minor revisions to the emissions averaging provisions are I**~** warranted.

A. § 63.510(a) ofthe Proposed Rule Appears to Contain a Typographical Error Which Affects the Scope ofEmission Averaging Provisions
Inthe emission averaging section ofthe proposal at 

### § 63.5IO(a), EPA states "[t]his section applies to owners oroperators ofexisting sources who seekto comply with the emission standards in 63.503(a) ofthis subpart by using emissions averaging according to 

### § 63.503(f) ofthis subpart
..."

This section appears to contain two typographical errors. First, the referenced 

### §

.- 63.503(a) does not refer backto the 

### § 63.505 continuous process vent provisions. This is ./ an error since process vents from continuous operations are a group ofpoints that EPA intends to include 

### in the emission averaging. Second, 

### § 63.5IO(a) refers to §63.503(t),
even though the referenced § 63.503(f) does not exist.

B. TheEmission Averaging Provisions Appear to Inadvertently Overlookthe Process Standards Contained in § 63.505(b)(3) as Sources that Can be Included in an Emission Average
The emissions averaging provision at § 63.510(a) indicate that the 

### § 63.505 continuous process vents will be allowed to be included in an emission average. However, the methods for generating credits and debits in 

### § 63.51O(g) and (h) include only methods for addressing those sources that are determined to be Group 1 and Group 2 process vents

49

# ---' and have their control standards established by following theHON procedures. The PET continuous TPAprocess vent standards at § 63.505(b)(3) are not developed by following the HON and are not determined to be Group I or Group 2 sources using theHON. The PET continuous TPA process vents have a separate processbased emission standard based onproduction rate. Therefore, subpart (g) and (h) appear to inadvertently omit a procedurefor calculating credits and debits for the PET continuous TPA process vents.



### C. TheEmissions Averaging Provision ofthe Rule Should beExpanded to Include Additional Points
Inits Basis and PurposeDocument (Section 4.0), EPAexplains that in selecting the number ofemission points to allow in an emissions average for this proposal, 

# i;a differences in the definition ofa source category for the HON and the proposed rule were considered. EPA explains that the differences in the breadth ofthis definition is important because emissions averaging occurs on a source category/subcategory basis. The definition ofsource category in the HON includes the production ofany chemical included
onthe HONlist. Typically, facilities covered by the HONproduce multiple chemicals in multiple process units at one plant site. The HON allows an affected source to include no
more than 20 points in an emission average; this is increased to 25 points where pollution prevention measures are used to control emission points to be included in an average. The 20 to 25 point limit would apply to the combination ofall process units at a given facility.

50

### The proposed MACT for Group IV Polymer and Resins includes standards for 18 categories/subcategories, and the emissions are limited to averaging emission points from single subcategory. EPA states that some sites may contain multiple subcategories, and
one site has been identified that may have six collocated subcategories. Thus, ifthe HON emission point limit were directly applied to this rule, this plant site would be allowed to included 20 to 25 emission points per subcategory; combined, this would potentially equal
atotal of120 to 150 emission points across six emissions averaging plans. This results in
aprocess that EPA deems to be too burdensome for the permit agency to administer.
Expanding the approach EPA has taken could provide additional cost-effective flexibility for theMoncure Plant. AtMoncure, several emission points exist in the raw

### fr~ material handling section, esterification section and in the polymerization section.**~** ...-. .1 

### Additional emission points from wastewater tanks, storage vessels and similar equipment may be impacted by the MACT standard. Taken together, there are more than 20 emission point sources that have the potential to be affected by the MACT. Although a final compliance plan for the Moncure Plant to meet MACT is dependent on the standard that is ultimately promulgated, and the exact use ofemission averaging is not known at this time, all ofthese emission points have the potential to be incorporated into an emission averaging plan. Only one subcategory ofthe proposed standard applies to Moncure; therefore the proposal to restrict the use ofemission averaging to 5-8 points markedly reduces compliance options. For this reason, EPA should expand the rule to allow 20 emission points to be included in an emissions averaging plan, thereby providing

51

### the potential for more flexibility and greater cost effectiveness to be incorporated into a final compliance plan.

Dated: May 26, 1995.

52

### ATTACHMENT

## n
[The information which would normally appear in this section is"confidential business information" which has been removed and separately submitted to EPA in accordance with 40 C.F. 

### R. Part 2.]

## "'"**~)**



# •

. "';

....",' AITACHMENTm


### [The information which would normally appearin this section is"confidential business information" which has been removed and separately submitted to EPA 

### in accordance with 40 C.F. R. 

### Part 2.]

# •

.. -,"" 

### ATTACHMENT IV
[The information which would normally appear in this section is"confidential business information" which has been removed and separately submitted toEPA in accordance with 

### • 40 C.F. R. 

### Part 2.]

### ~ . ",' ',_.;.,..r" 

### ATTACHMENT I
[The information which would normally appear in this section is"confidential business information" which has been removed and separately submitted to EPA in accordance with 40 C.F. R. 

### Part 2.]