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. 

1
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 

daily basis 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. 

2
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.2This 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.

2

In 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. 

3
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. The capital 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: 

ED,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); 

Wr = 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 concentration 

in 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%. 

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. 

Regulatory Alternatives

HAP Emissions 

(tpy)

Capital Cost 

($)

Annual Cost 

($)

Cost Effectiveness 

($/ton HAP removed)

1 (MACT floor- 6% EG) 147 ----- ----- -----

2 (Beyond-the-floor- 4% EG) 98 8,800,000 4,200,000 86,000

Table 2 -- Impacts Summary for Regulatory Alternatives 

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. 

5
Appendix A 

PCCT data collected by EPA 

Facility Wr or circ (lb/hr) Drift Factor (%) Evap Factor (%)

Cape Fear 525420 0.013 0.006

Intercontinental 234060 0.005 0.006

Hopewell 178642 0.002 0.006

Old Hickory 2302116 0.001 0.006

3M Greenville 388860 0.005 0.006

Salisbury 1800000 0.015 0.006

Kinston 2000000 0.3 0.006

Cape Fear 1801440 0.265 0.006

Churchill 1501035 0.15 0.006

Cape Fear 1801440 0.259 0.006

Kinston 2000000 0.3 0.006

Shell 2740000 0.005 0.006

Kinston 4500000 0.3 0.006

Eastman 6505000 0.02 0.006

Circleville 1212970 0.288 0.006

Shell 871000 0.2 0.006

Honeywell11865130 0.024 0.006

3M Decatur 288000 0.031 0.006

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: Docket Number 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 

Pollutant Emissions From the Production of Acrylonitrile 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 IV Polymer and Resins." 

Dear Sir or Madam: 

AlliedSignal is pleased to submit comments in duplicate on the Environmental Protection 

Agency's March 29, 1995 proposed "National Emission Standards for Hazardous Air 

Pollutant Emissions From the Production of Acrylonitrile 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 IV Polymer and Resins." [60FRI6090] As directed by Mr. Leslie Evans of EPA, 

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 CFR Part 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 of the largest Polyethylene Terephthalate (PET) production facilities of its 

type in the United States at its site in Moncure, North Carolina. This site will be gre'ady 

impacted by the proposedNESHAP standard because EPA failed 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 of compliance will be grossly higher 

than predicted by EPA in 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. 
EPA is encouraged to closely review the attached comments. AlliedSignal is available to 

respond to any questions or comments that EPA may 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) if you have any questions. We look forward to continued 

discussion with EPA in order to establish the proper MACT standards for the PET 

industry. Also enclosed is a self-addressed stamped envelope to be used for returning a 

date-stamped extra copy of our comments. 

Sincerely Yours, 

J~~/,y J. E. Cooper 

Director Environmental 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 

ENVIRONMENTAL PROTECTION AGENCY 

by 

ALLIED SIGNAL INC. 

May 26, 1995 

concernmg 

PART 63 -- NATIONAL EMISSION STANDARDS FOR HAZARDOUS 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) 

Docket No. A-92-45 
-", 

:..) 

~ 

tA._,~>._r., .. 

.,./ 

TABLE OF CONTENTS 

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

II. AN OVERVIEW OF THE POLYETHYLENE TEREPHTHALATE 

INDUSTRy .................................................... 2 

A. Overview of the Moncure Plant's Multiple End Finisher High Viscosity 

Process .................................................. 4 

B. Comparison of PET Continuous TP A Low Viscosity Process .......... 7 

C. Comparison of PET Continuous TP A High Viscosity Solid State 

Process .................................................. 8 

III. EPA'S PROPOSED MACT SUB CATEGORIZATION FOR PET 

MANUFACTURERS IS FAT AiL Y FLAWED AND-MUST BE IffiVISED IN 

THE FINAL RULE TO ESTABLISH AN ADDITIONAL SUBCATEGORY 

FOR A CONTINUOUS TP A HIGH VISCOSITY MULTIPLE END FINISHER 

PROCESS ...................................................... 8 

A. EPA Failed to Evaluate the Impact of the Proposed PET Continuous TP A 

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 Tower Water in the Vacuum System Contact Condenser 

Never Recognized 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. EP A Failed to Properly Evaluate the Use of an Ethylene Glycol Jet 

Vacuum System as a Process Change, Thereby Further 

Underestimating the Cost of Compliance for PET Continuous TP A 

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 PET Processes ..................... 18 
~ 

~ 

. ,; 

B. Implementation of the Proposed PET Continuous TP A MACT Standard 

Eliminate the Use of Cooling Tower Water in the Vacuum System Contact 

Condenser Would Create an Enormously Disparate Cost Impact on 

Allied Signal 's Moncure Plant . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .19 

C. EPA's Belief that Other Technologies are Feasible to Eliminate the Use of 

Cooling Tower Water in the Vacuum System Contact Condenser is Not 

Supported by the Proposal and is Technically Flawed ............... 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 

Must Establish A Separate PET MACT Subcategory for a Continuous 

TP A Multiple End Finisher Process ............................ 27 

1. Implementation of the Criteria Identified by EPA for Establishing 

Separate MACT Subcategories Within the Group IV Polymer and 

Resins Category Conclusively Supports the Further Desegregation 

of the PET Continuous TPA Subcategory into a New Subcategory. 

............................................. " ... 28 

2. EPA's Earlier Regulatory Treatment of the PET Industry Also 

Unequivocally Supports the Establishment of an Additional 

Subcategory . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3 1 

3. Existing Analytical Precedent in the Proposed Rule Supports the 

Creation of an Additional PET MACT Subcategory in the Final 

Rule .............................................. 33 

IV. FOR THE NEW PET MACT SUBCATEGORY WIDCH MUST BE 

ESTABLISHED BY EPA FOR THE CONTINUOUS TPA HIGH VISCOSITY 

MULTIPLE END FINISHER PROCESS, THE AGENCY MUST ADOPT AN 

ALTERNATIVE MACT STANDARD FOR CONTROLLING COOLING 

TOWER EMISSIONS ............................................ 34 

A. An Alternate MACT Standard for Cooling Towers in the PET Continuous 

TP A High Viscosity Multiple End Finisher Process ................ 35 

B. Evaluation of AlliedSignal's Alternate MACT Control for Cooling 

Towers in the PET Continuous TPA High Viscosity Multiple End 

Finisher Process ........................................... 35 

ii 
-

. :-.. ~ 

V. EPA SHOULD NOT DESIGNATE ALL WASTEWATER STREAMS FROM 

THE VACUUM SYSTEM AS GROUP I WASTEWATER STREAMS ..... .39 

A. Automatically Designating Wastewater Streams From PET Vacuum 

Systems as a Group I Stream Causes Confusion on How the 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 of the PET Industry .......... 41 

VI. TO OBVIATE THE CREATION OF MEANINGLESS MONITORING AND 

RECORDKEEPING REQUIREMENTS WHERE THE POTENTIAL FOR 

EMISSIONS IS MINIMAL, THE EQUIPMENT LEAK PROVISIONS OF THE 

PROPOSED RULE SHOULD SIMPLY NOT APPLY TO THE TP A 

CONTINUOUS PROCESS ....................................... .44 

VII. EPA SHOULD _MAKE THE STORAGE VESSEL REQUIREMENTS 

INAPPLICABLE TO THE PET CONTINUOUS TPA PROCESS .......... .48 

VIII. THE EMISSIONS AVERAGING PROVISIONS IN THE PROPOSED RULE 

REQUIRE MINOR REVISIONS AND, CONSISTENT WITH THE HON, 

SHOULD BE EXPANDED TO ALLOW ADDITIONAL POINTS TO BE 

AVERAGED ................................................... 48 

A. Section 6351O(a) of the Proposed Rule Appears to Contain a 

Typographical Error Which Affects the Scope of Emission 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 of the Rule Should be Expanded 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 Air Pollutant 

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 the MACT standards proposed by 'EP A for the PET process. 

AlliedSignal has invested a substantial amount of time and effort in reviewing the 

~ .... ' proposed rule, assessing the impact of the proposal on the Moncure Plant, and developing 

these comments. As conclusively demonstrated through these comments, EPA's proposed 

subcategorization of the PET MACT category does not properly account for the type of 

PET manufacturing process employed at the Moncure Plant. Because of this oversight, a 

real world application of the MACT standard proposed for cooling towers in the "PET 

continuous TP A" subcategory would result in an enormously disparate cost impact at the 

Moncure Plant. Using the statutory discretion available to EPA to 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 of manufacturing process used at the Moncure Plant. For this new subcategory, 

AlliedSignal has developed--and proposed in these comments--a MACT standard which 

1 
will result in a level of cost-effectiveness within the range found to be acceptable by EPA 

in the development of other PET MACT subcategories, as well as other polymer and 

resins MACT subcategories. 

In earlier discussions with EPA about the proposed PET MACT standards, 

AlliedSignai representatives provided Agency personnel with detailed information 

concerning many of the 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 of information before it, the Agency should bear in mind that AlliedSignai is firmly 

A committed to the development of a PET MACT standard which results in reasonable 

) 

impacts to its Moncure facility and that it will not hesitate to exercise its right to judicially 

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 of customers with two distinctly 

different products. Approximately 90% of the 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% of the US 

production capacity for high viscosity PET. 

Low viscosity PET resins are produced commercially from ethylene glycol (EG) by 

using either dimethyl terephthalate (DMT) or terephthalic acid (TP A) 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 of the new high viscosity PET installations are using the TP A process. 

For that segment of the PET manufacturing sector using TPA in a continuous 

process, the production of low viscosity resins and high viscosity resins are very different, 

$!_ with additional vessels and processing steps required for the production of higher viscosity . ;~.r/ 

resin. To the best of AlliedSignal'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 
PET MANUFACTURING BREAKDOWN 

DMT 

Low Viscosity 

Continuous Batch 

Multiple End Finisher 

Figure I 

A. Overview of the Moncure Plant's Multiple End Finisher High 

Viscosity Process 

AlliedSignal's Moncure Plant consists of a continuous operation which uses TP A 

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 manufacturing process, EPA's February 14, 1995 analysis of the continuous TPA process 

completely overlooked its many distinctions. See Document II-B-lO ("Process Description for PET'), pp. 

10-11. 

4 
At the Moncure Plant, esterification of ethylene glycol with TP A is performed in a 

series of vessels. The esterification vessels typically operate at a temperature between 260 

and 280°C and at an elevated pressure generated by the vaporization of glycol, 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. In this step, esterification is completed and the joining of the short 

molecular chains is promoted by the removal of ethylene glycol. The prepolycondensation reaction promotes increased viscosity of the reaction mass; therefore, 

transfer to the polycondensation reactor is by a gear pump. At the Moncure Plant, the 

ethylene glycol and other vapors are removed from the pre-polycondensation reactor 

through separate vapor lines into glycol spray condensers by 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 

5 
process is necessary in order to produce high viscosity PET and to maintain that viscosity 

for subsequent spinning. To the best of AlliedSignal'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 of that process. 

At the Moncure Plant, each of the polymerization process steps consists of reactor 

vessels under high vacuum. The material enters a first stage reactor (often called the prefinisher) which operates under a vacuum of approximately 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 of ethylene glycol. The liquid surface which is exposed allows for 

vaporization of ethylene glycol from the melt, resulting in an increase in polymer 

molecular weight and the resulting high viscosity melt product. The viscosity of the 

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 of the reactors by the vacuum system which, at the Moncure Plant, consists 

6 
of a 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 of PET Continuous TPA Low Viscosity Process 

In the PET continuous TP A low viscosity process, esterification and prepolycondensation are similar to 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 of a high viscosity process. 

The material leaving the single polymerization reactor of a low viscosity process is then 

extruded and quenched into a solid pellet or chip and represents the final product for the 

low viscosity PET 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 vacuum jet system under the very high vacuum 

necessary to raise the viscosity of the resin to the finished product requirements. The low 

viscosity process does not have any of these additional vessels or their associated vacuum 

systems. 

7 
C. Comparison of PET Continuous TPA High Viscosity Solid State 

Process 

In the PET continuous TP A solid state high viscosity process, the processing steps 

are very similar to those used in the low viscosity process, except that the solid chips or 

pellets are then subjected to an additional processing step. In this process, the solid chip is 

dried, fed to one or more crystallizers to raise the sticking point of the 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 PROPOSED MACT SUBCATEGORIZA TION FOR PET 

MANUFACTURERS IS FATALLY FLAWED AND MUST BE REVISED 

IN THE FINAL RULE TO ESTABLISH AN ADDmONAL 

SUBCATEGORY FOR A CONTINUOUS TPA HIGH VISCOSITY 

MULTIPLE END FINISHER PROCESS 

At § 63.500 of the 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. By using this 

subcategorization scheme, EPA has included all PET continuous TP A processes in the 

8 
same subcategory and has proposed to subject all PET continuous TP A processes to the 

same control requirements. 

This sub categorization scheme for the PET continuous TP A 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 of the proposed MACT standard for cooling towers. The fundamental 

differences that are part of the multiple end finisher process must be taken into account 

when developing a MACT 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 TP A in a continuous process having multiple end .--~/ 

I 

/ 

finishers. 

A. EPA Failed to Evaluate the Impact of the Proposed PET Continuous 

TPA MACT for Cooling Towers on the High Viscosity Multiple End 

Finisher Process 

In the preamble to its March 29 proposal, EPA defers to section 6.0 ("MACT 

Floors and Regulatory Alternatives") of the Basis and Purpose Document for a full 

explanation of the alternatives used to develop the MACT standard for each of the 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 TP A process. 

To begin with, EPA stated that the polymer NSPS (Subpart DOD) for the PETTP A continuous process limits ethylene glycol concentration in the cooling tower but that 

this particular provision was not included as a regulatory 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 of these alternatives, the use of ethylene glycol jets in place of 

steam jets in the vacuum system, as the basis for the proposed standard to eliminate the 

use of cooling 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 glycol jets in place of steam jets in the vacuum system~ (2) the use of mechanical 

vacuum pumps~ and (3) non-contact condensers in place of the typical contact barometric 

intercondenser. 

2 Basis and Purpose Document. Section 6.2.3.2. 

10 
" 

. \ 

~' 

1. EPA's Cost Estimate for Using an Ethylene Glycol Jet Vacuum 

System to Meet the Proposed Standard to Eliminate the Use of 

Cooling Tower Water in the Vacuum System Contact 

Condenser Never Recognized the Need to Have Multiple Jet 

Systems on the High Viscosity Multiple End Finisher Process 

As explained by document TI-B-27 in the Docket established for this rulemaking, 

the impact analysis for the proposed standard to eliminate the use of cooling tower water 

in the vacuum system contact condensers is based on the use of ethylene glycol jet vacuum 

systems as a replacement for the steam jet vacuum systems. EPA states in this document 

that cost data for ethylene glycol jets were available from a single source, but that such 

data were declared to be confidential business infonnation. 3 Although the document 

states that the costs provided were for a retrofit application of ethylene glycol jets, the 

retrofit capital costs were not provided and were approximated by EPA. Retrofit capital 

costs were said to be appro~mated by doubling the direct capital costs and using the 

provided indirect capital costs without modification. EPA supplied no infonnation to 

justify the assumption that retrofit capital costs can be approximated by doubling the 

known capital costs of a jet system. (As explained later in these comments, this 

assumption is grossly inaccurate.) Direct installation costs and indirect costs were 

approximated by EPA by assuming that such costs comprised 30% and 31 % of the 

purchased equipment cost respectively. 

Costs for each of the individual PET facilities were extrapolated by using two 

techniques, both of which were dependent on production capacity. The first technique, 

3 Document II-B-2, p.S. 

11 
used for existing facilities where a cost is not as closely related to production rate, was to 

use a 6110th scaling factor based on the ratio of the "extrapolated facility's" production 

rate and the CBI facility's production rate. The 6/10th scale factor was used for 

estimating cost of items that are not as strongly related to production rate, such as capital 

costs, fixed annual costs and semi-variable costs. For these calculations, the ratio of the 

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 of the 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 ofa plant. 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 of a sinele jet system 

is grossly inaccurate for the high viscosity multiple end finisher process since the high 

viscosity multiple end finisher process requires multiple jet systems to pull vacuum on the 

multiple reactors in order to raise the viscosity of the resin to its desired level. Even if all 

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 multiple jet systems. 

) 

12 
! ~' 

2. EPA's Cost Estimate Never Took Into Account the 

Requirement to Control Solids Level in the Process 

An inherent challenge in the design of any 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 vacuum jets and in any control devices used to 

control the reactor vent stream. In order to avoid process down time due to the buildup 

of solids in the jet system, it is necessary to either design a scrubber system to remove 

solids prior to the vacuum jet or to design the reactor with a spare vacuum jet system that 

can come on-line when an on-line jet is shut down to 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 of solids from one jet system while the 

other is operating. 

The need for a system to manage solids was completely ignored in EPA's cost 

analysis of the 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 single jet system, applied factors to represent 

retrofit, direct and indirect costs, and estimated the industry wide impact. An accurate 

evaluation of the cost must also include a scrubber system or a spare vacuum jet system to 

manage the build up of solids. 

l3 
¢~-. .::;....,' 

) 

EPA's failure 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 multiple jet systems, each of which require an approach to manage solids in order to 

avoid pluggage. Scrubbers to handle the solids in the PET processes are uniquely 

designed for that purpose and can cost in excess of $1,000,000. EPA therefore 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 Evaluate the Use of an Ethylene Glycol 

Jet Vacuum System as a Process Change. Thereby Further 

Underestimating the Cost of Compliance for PET Continuous 

TPA High Viscosity Multiple End Finishers 

EPA's proposed standard to eliminate the use of cooling tower water in the 

vacuum system contact condensers is based on replacing steam jet vacuum systems with 

ethylene glycol jet vacuum systems. The jet systems are not pollution control equipment 

typically associated with a MACT standard, but are an integral part of the manufacturing 

process. The jet systems create the vacuum in the polymerization reaction vessels. In the 

high viscosity multiple end finisher process, it is the jet systems that supply the high 

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

product. 

As noted in a July 11, 1994 letter to EPA from Carolina Eastman, EPA cannot 

solely base an emissions control standard on process changes. 4 In that letter, Eastman 

presented information on ethylene glycol jet vacuum systems but stated that it did not 

support the use of ethylene glycol jets as a MACT technology since the jet system was an 

integral part of the 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 

the basis for a MACT standard, EPA failed to recognize that the impacts of a process 

change are substantially different than the impacts of simply adding pollution control 

equipment to a process. These differences result in significant additional costs that EPA 

did not include in its analysis of the impact of its proposed rule and in the selection of 

proposed control methods. For example, one significant aspect of designating 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 of which are manufacturers of PET 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 of retrofitting its Moncure facility with ethylene glycol jet systems, attempts 

to get accurate cost estimates frequently involved direct contact with various vendors. In 

some cases, the license holder hesitated to license any of the technology to AlliedSignal 

since the owner of the 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 of the 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 of research 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 of process changes will require a lengthy period of 

time during which the process must be shutdown to complete the installation of equipment 

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 a process change which will, for the PET process, require a 

significant shutdown of the 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 glycol jet vacuum system. "During this time, the impact to AlliedSignal' s PET 

business would be two-fold. First, the simple loss of sales due to outage of production 

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 of production 

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 of equipment. The 

equipment is often an "add-on" to the end of the process and does not require a significant 

amount of additional process piping to make it functional. But in the case of the PET 

) 

17 
) 

MACT standard at issue, process equipment modifications such as incorporating vacuum 

jet systems, will be added to the middle of a process and will require a significant amount 

of additional process piping to complete the installation and make the unit functional. The 

costing methodologies that EPA uses for pollution control equipment, where the 

installation costs are a percentage of purchased equipment, will always understate the 

costs required to install a process change since items such as additional piping are never 

included. 

4. EPA's Impact Analysis Failed to Recognize That the High 

Viscosity Process Requires AdditionaLGlycol Recoyery 

Equipment as Compared to Other PET Processes 

Due to the requirements of products using the high viscosity resin to have 

consistent heat stability and other physical properties, the high viscosity process is 

designed to minimize the amount of diethylene glycol (DEG) present as a bound impurity 

in the final resin. In the PET process, various streams of ethylene glycol are returned to 

the process for further use. DEG is formed as an impurity in the process and must be 

removed from any recycled streams. The requirement to minimize DEG in these streams 

requires additional equipment to reduce the DEG level in the recycled stream. 

EP A's proposed use of ethylene glycol jets in place of steam jets would change the 

characteristics of the streams that are recycled back to the process, making the ethylene 

glycol concentrations much higher, creating more ethylene glycol to handle and causing 

more DEG to be formed due to the vaporization of ethylene glycol for use in the proposed 

18 
• . . ' 

) 

jet system (a factor that will have an additional impact on the high viscosity multiple end 

finisher process). The changes to the characteristics of the 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 in EPA's impact analysis, resulting in the creation of another 

factor which caused an understatement of the cost impact on the high viscosity multiple 

end finisher process. 

B. Implementation of the Proposed PET Continuous TPA MACT 

Standard to Eliminate the Use of Cooling Tower Water in the 

Vacuum System Contact Condenser Would Create an Enormously 

Disparate Cost Impact on AlliedSignal's Moncure Plant 

As discussed above, EPA's evaluation of the impact on the PET industry to meet 

the proposed standard to eliminate the use of cooling 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 of compliance that were never evaluated by 

EPA. EPA developed a facility-by-facility analysis of the cost of compliances for almost 

all of the existing facilities in the other 27 categories and subcategories, including the costs 

to meet various portions of the 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 glycol jets 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 of the ethylene glycol jet cost information inadvertently 

resulted in the exclusion from the docket of the PET industry cost analysis for all portions 

of the standard. 

Since EPA did not provide any information on the cost of compliance for PET 

facilities to meet the proposed standard to eliminate the use of cooing tower water in the 

vacuum system contact condenser, it is impossible for commenters such as AlliedSignal to 

completely compare the real cost of compliance 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 of the 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 TP A 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 of approximately $3,400,000 for each 

of the 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 of steam jet system and replace them with 

ethylene glycol jet systems and scrubber systems at the Moncure Plant. Replacing existing 

steam jet systems with ethylene glycol jets is the basis EPA used to develop costs 

estimates for PET facilities to come into compliance with the proposed standard to 

eliminate the use of cooling tower water in vacuum system contact condensers. 

AlliedSignal conducted this analysis in two ways, both of which are included with 

extensive amount of detail in Attachment I ( "AlliedSignal Cost Analysis - Annual Costs -

Glycol Jets and Scrubber") and Attachment II ("AlliedSignal Cost Analysis - Capital 

Costs - Glycol Jets and Scrubber''). 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 of compliance. 

The second approach, using AlliedSignal's cost estimates, is an accurate, up-todate engineering analysis of what 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 steam jets 

with ethylene glycol jets. 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 EP A. AlliedSignal strongly believes that 

the EPA approach is inaccurate and presents an out-of-date analysis for various costs. 

) 

21 
Although EPA'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 of the impact on the high viscosity multiple end finisher process. Using 

EPA's factors and cost estimate, the total capital cost for just retrofitting the Moncure 

Plant to a process using ethylene glycol jets is approximately $26,000,000. See 

Attachment n. This compares to EPA's analysis that the entire PET continuous TP A 

industry added together would incur a capital cost of approximately $40,000,000. The 

t:71!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 glycol jet 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 of emissions reduction. Attachments I and II 

:) 

22 
present a detailed item-by-item analysis of this option. A summary of the results of this 

analysis is presented in Table 1. 

It is important to recognize the cost of the items that EPA failed to incorporate in their 

analysis and which were discussed in our comments in Section IT. A. above. An ethylene 

glycol jet vacuum system is estimated to have a purchased equipment cost of $200,000 -

300,000. At the Moncure Plant, EPA's failure to recognize that the multiple vacuum jet 

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 EPA impact 

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) 

Moncure Plant 

Impact (using EPA 26,049 4,777 27,776 

factors) 

Moncure Plant 

Impact (using 55,000 24,000 140,916 

A1liedSignal cost 

estimatesl 

Table 1 Proposed Rule - Cost of Compliance 

analysis. EPA's failure to include a scrubber system to remove oligomers and other solids 

from each reactor results in EPA failing to recognize another $7,000,000 in capital costs. 

A cost effectiveness analysis using what AlliedSignal believes to be an accurate 

\ analysis of the true costs required to meet the proposed standard is more than 11,000% . I ~/ 

23 
higher than that estimated by EPA. It should be obvious to EPA that 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 

of the Clean Air Act. 

C. EPA's Belief that Other Technologies are Feasible to Eliminate the 

Use of Cooling Tower Water in the Vacuum System Contact 

Condenser is Not Supported by the Proposal and is Technically 

Flawed 

In Section 7 of the Basis and Purpose Document, 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 glycol jets in place of steam jets in the vacuum system was the method EPA used 

.-"' 

to determine the industry impact. EPA also states that mechanical vacuum pumps may be 

used and that non-contact condensers, in place of the 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 way justify a rule based on technologies it "believes" 

will work but for which it has not conducted a thorough technical evaluation and for 

which it has not developed accurate cost estimates. EPA acknowledges that "costs for 

these control technologies were not calculated.,,6 If EPA had conducted an accurate 

analysis of the 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 TP A process. The suggested controls are additionally impractical and 

costly for the high viscosity multiple end finisher process where the higher vacuum 

requirements of the 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 of non-contact shell and tube 

condensers to control emissions from the polymerization reactors at the Moncure Plant. 

Because of the vacuum in the polymerizatiQnreactors and.because the very high vacuu.m 

of the 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 other PET facilities, the existing building structures were never designed to 

accommodate vessels of such size. If large 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. If non-contact condensers 

on the steam jets were used, each reactor would need to have a spare jet system with noncontact condensers that could be used when cleaning of the other jet system condenser is 

25 
required. To minimize the cleaning requirements, a costly scrubber would be required to 

be installed before the jet system. The installation of a scrubber would also raise the 

licensing and patent issues discussed earlier, since the scrubber design is very specific to 

the demands of the PET process, and successful designs are protected by patents. 

All of the above factors are compounded in the PET continuous TP A high 

viscosity multiple end finisher process. The high vacuum requirements of the multiple 

reactors and the fact that there are several end finishers at the end of the polymerization 

section of a high viscosity process would require larger condensers on the jet 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 of this option as it has done 

.,' 

for other options. A preliminary assessment, assuming it is even possible to overcome the 

licensing and patent issues in a reasonable manner, indicates that the total capital 

requirement for this option is equal to or greater than retrofitting the process with ethylene 

glycol jets. 

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 of the polymerization 

26 
reactors, and the very high vacuum requirements of the end finishers in the mUltiple end 

finisher process, would dictate the use of a large number of mechanical 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 of this option 

precludes it from any further serious consideration. 

D. Using the Discretion Provided by CAA § 112CC)(n and rol(n. EPA Must 

Establish a Separate PET MACT Subcategory for a Continuous TPA 

Multiple End Finisher Process 

EPA's pr{)posed sub categorization for PET manufacturers using TP A on the basis 

of whether 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 TP A process having mUltiple end finishers in a unique PET manufacturing 

) 

niche. In the final rule, EPA must correct this oversight by exercising the discretion 

conferred upon the Agency by Congress in CAA § 1 12(c)(1)' and (d)(l)8 and creating for 

this particular process a new PET MACT subcategory. As described more fully below, 

there are a number of incontrovertible factors which mandate the development of an 

additional PET MACT subcategory. 

7 Following its general direction to EPA to publish a list of categories and subcategories of major 

sources of hazardous air pollutants 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 of sources 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 A in continuous processes 

having multiple end finishers within the context of CAA § Ill. Third, EPA has already 

recognized in the proposed rule that, with respect to one criterion (process differences), 

PET manufacturers using TP A in batch processes and manufacturers of other types of 

polymers and resins with major process differences warranted extensive subcategorization, 

even when only one facility was identified for a particular MACT subcategory. With 

respect to these latter two factors, EPA cannot elect to create subcategories for certain 

PET and other polymer and resins manufacturers and then ignore another segment which 

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

of CAA § 112 but which has also been determined by EPA to warrant separate regulatory 

) 

treatment within the context of CAA § Ill. 

1. Implementation of the Criteria Identified by EPA for 

Establishing Separate MACT Subcategories Within the Group 

IV Polymer and Resins Category Conclusively Supports the 

Further Disaggregation of the 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 of disaggregation of industry groups ... or the authority of the 

28 
Agency to distinguish among classes, types, and sizes of sources 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 

authority to define subcategories of sources 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 of sources during the 

course of establishing 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 to justify the creation 

ofa new subcategory." 59 Fed. Reg. 29,196, 29,20011 (June 6, 1994). 

Within the context of the proposed rule, the Agency chose to subcategorize four of 

the seven Group IV polymers and resins categories, creating five subcategories for ABS, 

three subcategories for SAN, three subcategories for polystyrene, and four subcategories 

for PET. Each of these four source categories "was subcategorized to account for major 

differences in production methods, raw material usage, or both." 60 Fed. Reg. at 16,092 

(emphasis added). In the case of the four subcategories for PET, the Agency made an 

29 
initial distinction between PET manufacturing on the basis of raw material usage (TP A 

and DMT) and a further distinction based on whether the process using each raw material 

was continuous or batch. 

While the Agency correctly began the process of subcategorization by delineating 

PET manufacturing according to raw material usage, the Agency evidently was unaware 

of several significantly different manufacturing processes employed by facilities using TP A 

as a raw material. As explained in detail in Section II, above, a significant distinction 

exists between manufacturers of low viscosity PET for the textile, apparel and resin 

markets and manufacturers of high 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 of a 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 TP A" 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 of technology 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 of AlliedSignal and EPA on May 11, 1995, EPA 

must further apply the latter of the two criteria identified in the proposed rule for initially 

establishing the four PET MACT subcategories to create in the final rulemaking an 

additional subcategory encompassing only those PET 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 Earlier Regulatory Treatment of the PET Industry Also 

Unequivocally Supports the Establishment of an Additional 

Subcategory 

On the heels of the enactment of the 1990 Amendments to the Clean Air Act, EPA 

promulgated an NSPS on December 11, 1990 which established standards of performance 

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, 

EP A expressly recognized the various process differences which exist for manufacturers of 

PET using TP A. In that regard, the Agency specifically defined the terms "continuous 

process," "end finisher," "low viscosity [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 of process, but also the differences between 

low and high viscosity PET and the number of finishers used in the manufacture of high 

viscosity PET. For process emissions standards established under this rule, the Agency 

first differentiated between PET manufacturers using TP A and DMT and then established, 

for users of TP A, one set of ethylene glycol control requirements for the production of 

low viscosity PET using single or multiple end finishers and high viscosity PET using a 

single end finisher and yet another set of standards for producers of high 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, that these critical TP A-based process differences existed. See 52 f_ Fed Reg. 36,678 (Sept. 30, 1987) . 

........ 

In the context of the current proposed rulemaking, EPA is statutorily bound to 

consider the earlier reasoning it employed in developing categories of regulation for the 

polymer manufacturing NSPS. 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 of source categories established pursuant to section 111 ... " EPA must, 

therefore, do more than simply repeat the requirements of the NSPS PET standards. 60 

Fed. Reg. at 16,094-95. The Agency must recognize in the final PET MACT rule that the 

categories of regulation established for the purposes of the recently promulgated NSPS 

apply with equal force to the general development of PET MACT subcategories and use 

32 
its earlier regulatory determinations to help support the specific development of a 

subcategory for PET manufacturers using TP A in a continuous process having multiple 

end finishers. 

3. Existing Analytical Precedent in the Proposed Rule Supports 

the Creation of an Additional PET MACT Subcategory in the 

Final Rule 

Viewed from several perspectives, precedent already exists within the proposed 

rulemaking for supporting the establishment of an additional subcategory for PET 

manufacturers using TP A in continuous processes having multiple end finishers. In the 

context of the 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 of an additional process permutation f_ "mass" and "emulsion"--and batch manufacturers on the basis of whether that type of 

.' , . ..-' 

process involved "suspension," "emulsion," or "latex." Here, the Agency recognized that 

additional process distinctions--like those present for PET manufacturers using TP A--

could reasonably support the creation of separate 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-TPA batch." See 60 Fed. Reg. at 

16,092. Thus, even if AlliedSignal's Moncure facility happened to be the only facility 

) 

33 
"'''', which uses TP A on a continuous basis with multiple end finishers, precedent would still 

exist in support of a separate MACT subcategory for such manufacturers. 

IV. FOR THE NEW PET MACT SUBCATEGORY WHICH MUST BE 

ESTABLISHED BY EPA FOR THE CONTINUOUS TPA HIGH 

VISCOSITY MULTIPLE END FINISHER PROCESS, THE AGENCY 

MUST ADOPT AN ALTERNATIVE MACT STANDARD FOR 

CONTROLLING COOLING TOWER EMISSIONS 

As explained in Sections II and III, above, the fundamental process differences that 

are part of the PET continuous TP A high 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 TP A high viscosity multiple end 

_,r~/ 

i 

" 

finisher process continues to allow cooling water to be used in the contact condenser, but 

controls the level of ethylene glycol in the tower water, thereby minimizing emissions. 

Attached in the confidential portion of this document is a detailed cost analysis for what 

would be necessary to modify A1liedSignal's Moncure Plant using this approach. See 

Attachment III ("AlliedSignal Cost Analysis - Annual Costs - Alternate Control 

Strategy") and Attachment IV ("AlliedSignal Cost Analysis - Capital costs - Alternate 

Control Strategy ''). 

34 
~ 

~ --_ .. ; 

A. An Alternate MACT Standard for Cooling Towers in the PET Continuous 

TPA High Viscosity Multiple End Finisher Process 

Cooling towers are the largest single source of ethylene glycol emissions at a PET 

continuous TPA multiple end finisher process. Following the approach established by 

EPA in the NSPS Subpart DOD, 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 

only HAP present in its process by conducting an evaluation to determine if acetaldehyde 

is present. The efforts to date have never been able to find a detectable amount of 

acetaldehyde. 9 

B. Evaluation of AlliedSignal's Alternate MACT Control for Cooling Towers on 

the PET Continuous TPA High Viscosity Multiple End Finisher Process 

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 

of ethylene glycol from the reactor stream. The recovered ethylene glycol will be sent 

back to our supplier to be further recovered and reused. 

9 AlIiedSignal operates its esterification vessels under pressure, which is believed to be unique 

among the other PET continuous TP A processes and may contribute to the lower acetaldehyde levels. 

Based on the analytical detection limit of acetaldehyde, it is believed that less than 400 pounds per year is 

generated in the process. 

35 
The current level of ethylene 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 of this analysis is shown in Table 2. 

Etllyleae G1yeol Water Feed Totll ADDUII IDeremeDtal IDeremeatal IaeremeDtal 

Levell" to DIJtlUaUoa StelmCost ADDUIleost Emlsslo. (MgIyr) Cost Effecdveaess 

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 EG Levels in Cooling Tower 

The ability to reduce the ethylene glycol emission from the cooling tower is 

• directly related to the amount of material fed to the recovery equipment. The additional 

material that must be sent to glycol recovery is represented by column 2. Using 

Allied Signal, s experience that it takes approximately 1.5 pounds of steam to recover 

ethylene glycol from a pound of water, and using a steam cost of $6 per 1000 pounds of 

(Slmg) 

steam, the annual steam cost for each level of glycol 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 of ethylene glycol in the cooling tower. The 

significant incremental cost increase for reducing the ethylene glycol levels in the cooling 

tower to a level 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 of this submission identified as Attachment III and IV. As 

was done to evaluate the costs to retrofit the Moncure Plant with ethylene glycol jet 

systems, AlliedSignal's evaluation of its 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 of compliance. 

The second approach, using Allied S ignal ' s cost estimates, is an accurate, up-todate engineering analysis of what 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 of approximately 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 of 40% 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 of this option is $35,564 per Megagram. 

Using the EPA factors for estimating annual and capital costs the cost 

effectiveness is $7,363 per megagram. The cost effectiveness using EPA's factors is at the 

high end of any option that EPA has chosen for any of the other Group IV polymer and 

resin subcategories.l1 Table 3 summarizes the results of AlliedSignal'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 TP A industry based on the proposed 

rule. 

Capital Cost : Cost Effectiveness Pen~cent Emission 

j Red u ction 

! Group IV PolymerlResins $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 of Cost 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 EPA for 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 show by document II-B-16 in the docket. 

38 
V. EPA SHOULD NOT DESIGNATE ALL WASTEWATER STREAMS 

FROM THE VACUUM SYSTEM AS GROUP 1 WASTEWATER 

STREAMS 

EPA proposes to automatically classify any wastewater stream from the vacuum 

system ofa PET 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 of the 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 of the 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 

EPA failed to include in its PET -MACT impact analysis. Moreover, such a classification 

will create a significant burden on PET facilities with no realization of HAP 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 PET Vacuum 

Systems as a Group I Stream Causes Confusion on How the HON 

Standards Are to Apply 

By way of background, Allied Signal supports the basic approach set forth in § 

63.132 of the HON for making Group I and Group II wastewater determinations. The 

basic approach in the HON rule is to evaluate the characteristics of the wastewater stream 

and to then designate a stream as a Group I or Group 2 stream in accordance with that 

evaluation. The HON designates as Group I any stream which meets anyone of the 

following two criteria: (1) any stream with a volatile hazardous air pollutant (VOHAP) 

concentration greater than 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 -TP A 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 of the HON. The proposed PET MACT standard for 

TP A vacuum system wastewater automatically designates the stream as Group I 

"regardless of the HAP concentration and flowrate for the stream." Thus, while the HON 

contemplates that an evaluation of the 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 of HAPs which exceed the same threshold levels. 

40 
In the case of AlliedSignal'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 of the 

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 Moncure Plant's vacuum system is expected to be less than this level as it is generated. 

These streams are largely comprised of ethylene glycol which, due to its vapor pressure, 

EPA has determined through the HON rule 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 of the 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 back to the process). Using the above example, it is unclear if a stream from the 

PET vacuum system, which has almost no volatiles, is required to be handled in this totally 

enclosed manner and, if it is, when the requirements stop. 

41 
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 of the PET Industry 

Pursuant to § 63.138 of the HON rule, 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 itself in the process or through destruction of the 

total HAP mass by 99%. The HON at § 63.111 defines "residual" as 

"any HAP containing water or organic that is removed from a wastewater stream by a 

waste management unit or treatment process that does not destroy organics 

(nondestructive unit} .... " By automatically designating PET vacuum systems as Group I 

streams regardless of flow and concentration, any material removed from the stream, 

including the oligomers, must be handled under one of these two options. The requirement 

• to control by 99% is independent of HAP concentration or amount of HAP. In order to ;.' 

achieve 99% destruction, it appears that the material would be required to be incinerated. 

By automatically designating streams from vacuum systems .. as Group I, EPA has not only 

caused confusion as to the type and amount of treatment a stream must receive, but it has 

also subjected solids, that may have no VOHAPS, to a costly requirement of 99% 

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) of the HON rule, 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 or residual 

42 
is 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 back to 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 if it were to be subject to the Group I/Group II 

determination of the HON. Nonetheless, by automatically designating a stream from 

vacuum systems as a Group I wastewater stream, regardless of flow 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 of the 

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 were justified 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 of volatile 

HAPs. The presence of volatile material in an amount greater than the threshold levels 

justified the special handling requirements because of the resulting reduction in volatile 

HAP emissions. This justification simply does not exist in the PET MACT 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 of the standard which automatically 

classifies a wastewater 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 of the 

HON for making Group I and Group II determinations. 

VI. TO OBVIATE THE CREATION OF MEANINGLESS MONITORING 

AND RECORDKEEPING REQUIREMENTS WHERE THE POTENTIAL 

FOR EMISSIONS IS MINIMAL, THE EQUIPMENT LEAK PROVISIONS 

OF THE PROPOSED RULE SHOULD SIMPLY NOT APPLY TO THE 

TPA CONTINUOUS PROCESS 

Section 63.509, of the proposed rule incorporates Subparts H and I of the HON 

rule as the basis for the equipment leak requirements for a PET continuous TP A high 

viscosity multiple end finisher process. The nature of the process and materials at the 

Moncure Plant is such that essentially all of the 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 of the requirements of Subpart 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. A leak detection and repair procedure is 

44 
already 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 "Raw Material Preparation" section of the Plant includes the 

unloading and transfer of raw materials to the process, paste preparation and the initial 

chemical reaction or esterification stage of the process. EG is 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 EG is 0.011 kPa at 200 C, which is well below 

the vapor pressure threshold (i.e. >0.3 kPa) for "light liquids" or liquids 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 of EG and TP A is performed in a series of vertical, 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 of gas/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 of the risk of an 

EG vapor expolsion. For that reason, following a process outage where changes have 

been made to esterification equipment, such as removal of transfer lines, control valves, 

rupture discs, agitator seals, etc., a routine 2 - 3 hour leak check is conducted by 

introducing hot EG vapors 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 of equipment startup for the past 24 years. 

The polymerization section of the process is carried out under vacuum conditions 

created by either vacuum pumps or steam ejectors. Operating pressure for polymerization 

vessels ranges from 2 torr to 0.5 torr. These pressure conditions are clearly operating in 

''vacuum service" as defined by § 63.161 of Subpart H. Section 63 .162 (d) of Subpart H 

specifically excludes equipment that is in vacuum service from the requirements of 

Subpart H. If a leak occurred in equipment under vacuum service, atmospheric oxygen 

would be sucked into a vessel or vapor line and no HAPs would be emitted. Should this 

event occur for 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 product quality concerns. For these product quality and safety reasons, leak detection 

and repair are already a high priority in the continuous TP A multiple end finisher process. 

Due to the predominant transfer of materials 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 of the proposed MACT standard for the continuous TPA multiple end finisher 

process should be eliminated. The cost of record keeping and implementing a formal 

equipment leak detection and repair program would far outweigh the benefits of 

decreasing an already low fugitive emission. 

Type of Eguipment 

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 of the polymers and resins industry (reference Table 6- 12. EPA-450/3-83-019a 

Polymer Manufacturing Industry - Background Information for Proposed Standards). 

47 
~-" .... \ 

) ~ vn. EPA SHOULD MAKE THE STORAGE VESSEL REQUIREMENTS 

INAPPLICABLE TO THE PET CONTINUOUS TPA PROCESS 

Since the PET continuous TP A process 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 of such a standard would simply create an unnecessary 

paperwork burden, EPA should make the standard inapplicable to PET continuous TP A 

facilities. 

vm. THE EMISSIONS AVERAGING PROVISIONS IN THE PROPOSED RULE 

REQUIRE MINOR REVISIONS AND, CONSISTENT WITH THE BON, 

SHOULD BE EXPANDED TO ALLOW ADDITIONAL 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 of points may be 

increased by three additional points if pollution 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 if pollution 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 if emissions averaging is used. In 

48 
... '\ addition, several other minor revisions to the emissions averaging provisions are 

I 

~ 

warranted. 

A. § 63.510(a) of the Proposed Rule Appears to Contain a Typographical Error 

Which Affects the Scope of Emission Averaging Provisions 

In the emission averaging section of the proposal at § 63.5IO(a), EPA states "[t]his 

section applies to owners or operators of existing sources who seek to comply with the 

emission standards in 63.503(a) of this subpart by using emissions averaging according to 

§ 63.503(f) of this subpart ... " 

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

.- 63.503(a) does not refer back to the § 63.505 continuous process vent provisions. This is ./ 

an error since process vents from continuous operations are a group of points 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. 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 

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 § 63.51 O(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 the HON procedures. The PET 

continuous TPA process 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 the HON. The 

PET continuous TP A process vents have a separate process based emission standard 

based on production rate. Therefore, subpart (g) and (h) appear to inadvertently omit a 

procedure for calculating credits and debits for the PET continuous TP A process vents. 

C. The Emissions Averaging Provision of the Rule Should be Expanded to Include 

Additional Points 

In its Basis and Purpose Document (Section 4.0), EPA explains that in selecting 

the number of emission points to allow in an emissions average for this proposal, 

i;a differences in the definition of a source category for the HON and the proposed rule were 

considered. EPA explains that the differences in the breadth of this definition is important 

because emissions averaging occurs on a source category/subcategory basis. The 

definition of source category in the HON includes the production of any chemical included 

on the HON list. Typically, facilities covered by the HON produce 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 of all 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, if the 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 

a total of 120 to 150 emission points across six emissions averaging plans. This results in 

a process 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 the Moncure Plant. At Moncure, 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 of emission averaging is not known at 

this time, all of these emission points have the potential to be incorporated into an 

emission averaging plan. Only one subcategory of the proposed standard applies to 

Moncure; therefore the proposal to restrict the use of emission 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.] 
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AITACHMENTm 

[The information which would normally appear in this section is"confidential business 

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ATTACHMENT IV 

[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.] 
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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.]