1 MEMORANDUM

DATE: December 5, 2013

SUBJECT: Technology Review and Estimated Cost Impacts for the Acrylic and Modacrylic Fibers Production Source Category

FROM: Nick Parsons, EPA/OAQPS/SPPD/RCG

TO: EPA Docket File (EPA

- HQ

- OAR

- 2012

- 0133)

1.0 INTRODUCTION

Section 112 of the Clean Air Act (CAA) requires the U.S. Environmental Protection Agency (EPA) to establish technology

- based standards for listed source categories as na tional emissions standards for hazardous air pollutants (NESHAP). These technology

- based standards are often referred to as maximum achievable control technology (MACT) standards. The Acrylic and Modacrylic Fibers Production (AMF) MACT standards (promulgat ed under the Generic MACT standards at 40 CFR part 63, subpart YY) apply to major sources of hazardous air pollutant (HAP) emissions and applies to existing and new facilities that manufacture acrylic or modacrylic fibers. The NESHAP requires the use of MA CT to reduce HAP emissions from storage vessels, process vents, fiber spinning lines, wastewater streams, and equipment leaks.

Section 112 also contains provisions requiring the EPA to periodically revisit these standards. Specifically, section 112(d)(6) states:

(6) REVIEW AND REVISION.

– The Administrator shall review, and revise as necessary (taking into account developments in practices, processes, and control technologies), emissions standards promulgated under this section no less often than every 8 years.

To comply with this CAA requirement, the EPA conducted a technology review for the AMF MACT standards for major sources. For the purposes of reviewing a MACT standard, the EPA considers a “development” in practices, processes, and control technolog ies to be:

• Any add

- on control technology or other equipment that was not identified and considered during development of the original MACT standards.

• Any improvements in add

- on control technology or other equipment (that were identified

and considered dur ing development of the original MACT standards) that could result in

additional emissions reduction.

• Any work practice or operational procedure that was not identified or considered during development of the original MACT standards.2 • Any process change or p ollution prevention alternative that could be broadly applied to the industry and that was not identified or considered during development of the original

MACT standards.

• Any significant changes in the cost (including cost effectiveness) of applying contro ls (including controls the EPA considered during the development of the original MACT standards).

Section 2 of this memorandum presents background information for the AMF source category. Section 3 presents a summary of the sources of data that were used to conduct the technology review. Section 4 presents summaries identified developments in practices, processes, and control technologies and the estimated cost impacts of each.

2.0 BACKGROUND FOR THE ACRYLIC AND MODACRYLIC FIBER SOURCE

CATEGORY

On Octobe r 14, 1998, the EPA proposed NESHAP under the Generic MACT (GMACT) standards. The proposed rule included NESHAP for four small source categories, including acrylic and modacrylic fiber production. The EPA promulgated the final GMACT standards on June 29, 1 999, and withdrew the proposed wastewater provisions of the GMACT in a supplemental notice. After receiving and reviewing comments, EPA promulgated the final process wastewater provisions for the AMF source category on November 22, 1999 (64 FR 63695).

The AMF MACT standards regulate HAP emissions resulting from the production of synthetic fibers composed of acrylonitrile (AN), including: (1) acrylic fiber in which the fiber forming substance is any long

- chain synthetic polymer composed of at least 85 perce nt by weight of AN units; or (2) modacrylic fiber in which the fiber

- forming substance is any long chain synthetic polymer composed of at least 35 percent but less than 85 percent by weight of AN units. Modacrylic fibers are modified acrylic fibers in whic h larger amounts of non

- acrylonitrile polymers are added to make the copolymers used in the production process. Acrylic fibers are used to produce textile products (sweaters, hats, hand

- knitting yarns, rugs, awnings, upholstery, etc.) and some types of car bon fibers. Modacrylic fibers are also used in the manufacture of textiles, but are known for greater environmental resistance and flame retardancy.

The production of AMF involves polymerization reaction processes, wet or dry solvent spinning,

solvent re covery, and fiber processing (e.g., washing, stretching, crimping, drying). The polymerization processes used in acrylic and modacrylic fibers production are solution or suspension polymerization. In solution polymerization, acrylonitrile and comonomers ar e dissolved in a solvent to form a polymer solution (spin dope) that can be filtered and pumped directly to the subsequent fiber spinning process. Suspension polymerization is a process where acrylonitrile and comonomers are suspended in water in the prese nce of a catalyst where they polymerize under agitation. This forms solid bead of polymer that must be filtered, washed, dried, and redissoved in solvent to create a spin dope of adequate viscosity for the fiber spinning

process.3 The primary HAP associat ed with AMF is acrylonitrile. Other HAP emitted by AMF operations in small quantities include: dimethylformamide, cyanide compounds, vinyl chloride, vinyl bromide, vinylidine chloride, and vinyl acetate. Sources of HAP emissions from AMF are storage vessel s, equipment leaks, process vents, wastewater, and fiber spinning lines.

A single facility in the U.S. produces AMF and is subject to the AMF MACT standards: Cytec Carbon Fibers, LLC, in Greenville, SC.

The AMF MACT standards include a combination of equ ipment standards, work practice standards, operational standards and performance standards for each of the emission sources noted above. The AMF MACT standards reference numerous other 40 CFR part 63 MACT standards for requirements relating to specific sou rces of emissions including:

• Subpart F (for maintenance wastewater requirements),

• Subpart G (for process wastewater requirements),

• Subpart SS (for closed vent systems, control devices, recovery devices, and routing emissions to a fuel gas system or a process),

• Subparts TT and UU (for equipment leaks), and

• Subpart WW (for storage vessels).

Various control technologies were considered in the development of the AMF MACT standards

and in the referenced standards listed above , which are summarized in Tab le 1.4 Table 1. Summary of Practices, Processes, and Control Technologies Identified and Considered During AMF MACT Standards Development

Emission Source Practices, Processes, and Control Technologies

Storage Vessels Fixed roof, internal floating roof, external floating roof, closed vent system and control device, vapor recovery system, route emissions to a fuel gas system or a process

. Fiber Spinning Lines enclosure over the spinning and washing areas of the spinning line

vented to a control device wit h overall destruction efficiency of 85%, process modifications to reduce the amount of residual HAP in the fiber spinning solution prior to spinning and fiber processing

Process Vents Combustion devices, recovery devices, scrubbers/absorbers

Equipment Leaks Leak detection and repair (LDAR) program, specific equipment

modifications

Wastewater Hard pipe individual drain systems, covers, vent to flare, recovery

device or combustion device

AMF Facility

- Wide Alternative standard to limit facility

- wide acrylonitrile emissions to 1 pound acrylonitrile per ton of fiber produced for existing sources or 0.5 pounds acrylonitrile per ton of fiber produced for

new sources

3.0 SOURCES OF AVAILABLE CONTROL TECHNOLOGY INFORMATION

To identify developments in pr actices, processes and control technologies since the MACT standards were developed, we consulted the following sources of data:

• The EPA’s RACT/BACT/LAER clearinghouse

• Review of subsequent regulatory development efforts

3.1 RACT/BACT/LAER Clearinghouse Database

Under the EPA's New Source Review (NSR) program, if a company is planning to build a new plant or modify an existing plant such that criteria air pollution emissions will increase by a certain amount, then the company must obtain an NSR permit. The NSR permit is a construction permit which generally requires the company to minimize air pollution emissions by changing the process to prevent air pollution and/or installing air pollution control equipment.

The terms "RACT," "BACT," and "LAER" are acronyms for different program requirements relevant to the NSR program. RACT, or Reasonably Available Control Technology, is required on sources in areas that are not meeting national ambient air quality standards (non

- attainment5 areas). BACT, or Best Ava ilable Control Technology, is required on new or modified major sources in clean areas (attainment areas). LAER, or Lowest Achievable Emission Rate, is required on new or modified major sources in non

- attainment areas.

BACT and LAER (and sometimes RACT) are determined on a case

- by

- case basis, usually by State or local permitting agencies. The EPA established the RACT/BACT/LAER Clearinghouse, or RBLC, to provide a central data base of air pollution technology information (including past

BACT and LAER decis ions contained in NSR permits) to promote the sharing of information among permitting agencies and to aid in future case

- by

- case determinations. However, data in the RBLC are not limited to sources subject to RACT, BACT, and LAER requirements. Noteworthy p revention and control technology decisions and information may be included even if they are not related to past RACT, BACT, or LAER decisions. 1

The RBLC contains over 5,000 air pollution control permit determinations that can help identify appropriate tec hnologies to mitigate most air pollutant emission streams. It was designed to help permit applicants and reviewers make pollution prevention and control technology decisions for stationary air pollution sources, and includes data submitted by several U.S. territories and all 50 States on over 200 different air pollutants and 1,000 industrial processes.

The RBLC provides several options for searching the permit database on

- line to locate applicable control technologies. Our search of the RBLC specified all the Acrylic and Modacrylic Fibers subcategory under the Synthetic Fibers Production category, with permits dating back to 1999. The search results included the following data fields:

• RBLC ID;

• Facility Name, and State;

• Permit Date;

• Process name;

• Throughp ut;

• Pollutant;

• Control technology; and

• Percent efficiency of control.

The results of the search are presented in Attachment 1 for the AMF source category. The practices, processes, and control technologies identified are all examples of the types of emiss ion reduction techniques that were considered in the development of the AMF MACT standards. Therefore, this exercise did not reveal any developments in practices, processes, or control technologies.

3.2 Subsequent Regulatory Development Efforts

The AMF M ACT standards were promulgated in 1999. Since that time, the EPA has developed air toxics regulations for a number of additional source categories that emit organic HAP from

1 Technology Transfer Network: Clean Air Technology Center. RACT/BACT/LAER Clearinghouse Basic Information. http://www.epa.gov/ttn/catc/rblc/htm/welcome_eg.html

.6 the same type of emission sources that are present in the AMF source category. In subsequent air toxic regulatory actions, the EPA consistently evaluated any new practices, processes, and control techniques. A review of these subsequent air toxics regulations, including supporting documentation used in the rulemakings was conducted to d etermine if any practices, processes or control technologies could be applied to the AMF source category. However, this exercise did not reveal any developments in practices, processes or control technologies. The results of this analysis are presented in Attachment 2.

The technology review analyses for the National Uniform Emission Standards for Storage Vessels and Transfer Operations, Equipment Leaks and Control Devices (“Uniform Standards”) were also considered in this review. Although these analyses are not based directly on operations in the AMF source category, they are based on representative chemical manufacturing processes and refinery processes with similar types of equipment and emissions sources. Thus, it is expected that emissions control and compliance demonstration methods that have been determined to be cost effective for a model chemical manufacturing facility in the Uniform Standards analyses could potentially be cost effective for the same regulated material at similar emission points in the AMF source category. Potential developments in practices to control emissions from equipment leaks were identified through the review of the National Uniform Emission Standards for Storage Vessels and Transfer Operations, Equipment Leaks and Control

D evices, which is discussed further in Section 4.

4.0 IDENTIFIED DEVELOPMENTS IN PRACTICES, PROCESSES AND

CONTROL TECHNOLOGIES AND ESTIMATED COST IMPACTS

For storage vessels, process vents, spinning lines and wastewater, beyond what is currently required in the rule or is being proposed in this action, we did not identify: a ny add

- on control technology or other equipment that was not identified and consider ed during MACT development; any improvements in add

- on control technology or other equipment (that was identified and considered during MACT development) that could result in significant additional HAP emission reduction; any work practice or operational p rocedure that was not identified and considered during MACT development; any process change or pollution prevention alternative that could be broadly applied that was not identified and considered during MACT development;

or any significant changes in the cost (including cost effectiveness) of applying controls (including controls the EPA considered during MACT development). The identified developments in practices for equipment leaks emissions control are discussed below.

4.1 Equipment Leaks

Equipment le aks are emissions emanating from pumps, compressors, agitators, pressure relief devices (PRD), sampling connection systems, open

- ended valves or lines (OEL), valves, connectors, instrumentation systems, and closed

- vent systems and control devices. The amou nt of HAP emissions from equipment leaks is proportional to the type and number of equipment components, and the concentration of HAP constituents of the stream passing through the
components.7 4.1.1 Summary of Existing MACT Level of Control

The AMF MA CT standards for equipment leaks apply to the group of all equipment, intended to operate in organic HAP service 2 which are located at the plant site. The equipment leak standards apply to equipment that contains or contacts 10 percent by weight or more of AN and operates 300 hours per year or more. Each piece of equipment subject to the AMF MACT standards for equipment leaks is required to comply with the specific provisions of 40 CFR
part 63, subpart TT or subpart UU. A summary of the leak detection provi sions of 40 CFR part 63, subpart TT and UU are shown in Table 2. The repair requirements for both standards are to complete repair generally within 15 days of the detection of a leak, and both standards contain similar recordkeeping and reporting requireme nts.

Table 2. Summary of Subparts TT and UU Equipment Leak Detection Requirements

Equipment Type 40 CFR part 63 Subpart TT 40 CFR part 63 Subpart UU

Valves in gas and vapor and in and light liquid service Conduct monthly EPA Method 21 monitoring

Leak definition of 10,000 ppm Leak definition of 500 ppm

Pumps in light liquid service Conduct monthly EPA Method 21 monitoring

Leak definition of 10,000 ppm Leak definition of 1,000 ppm (repair required at 2,000 ppm)

Connectors in gas and vapor

and in and light liquid service Sensory monitoring Conduct annual EPA Method 21 monitoring, leak definition of 500 ppm

Agitators in gas and vapor and in and light liquid service Conduct monthly EPA Method 21 monitoring, leak definition of 10,000 ppm

Pumps, valves, connectors, and agitators in heavy liquid service; pressure relief devices in liquid service; and instrumentation systems Sensory monitoring

Pressure relieve devices in gas/vapor service Operate with no detectable emissions (i.e., less than 500 ppm)

or equipped with a rupture disk / or routed to an air pollution

control device

Open ended lines Equip with a cap or comparable device

4.1.2 Developments in Technology for Equipment Leaks

The practices, process and control technologies considered during MA CT development for equipment leaks at AMF facilities included LDAR and equipment modification or replacement.

2 In HAP service is defined in subpart UU (§63.1200) as gas from volatile organic liquids (VOL), VOC, HAP, or other chemicals or groups of chemicals regulated by the referencing subpart.8 As part of the Uniform Standards development, in 2011, the EPA conducted a general review and analysis of emissions reduction techniques for equip ment leaks that have been put in place at chemical production facilities and refineries. 3 According to this analysis, compared with what was considered during MACT development for the AMF source category, no entirely new developments in methods for control ling equipment leak emissions were found. However, LDAR programs incorporating more stringent leak detection limits were noted to exist. In this analysis, the impacts of requiring certain leak definitions, comparable to the leak definitions

contained in 40 CFR part 60, subpart VVa and the Bay Area Air Quality Management District (BAAQMD) of California Regulation 8, Rule 18 were investigated. The leak definitions of 40 CFR part 60, subpart VVa for valves in gas and vapor and in and light liquid service (500 parts per million (ppm)), pumps in light liquid service (1,000 ppm) and connectors in gas and vapor and in and light liquid service (500 ppm) are the same as those required by 40 CFR part 63 subpart UU. Consequently, we investigated the leak definition re quirements of 40 CFR part 60, subpart VVa or 40 CFR part 63, subpart UU in the technology review analysis to determine whether the leak definitions of these programs, as applied to the AMF source category, would be cost effective. As it is possible that it may be cost effective to monitor only certain components at certain levels, the analysis included independent calculations of the cost effectiveness of monitoring each component at the alternative levels. Also, as instrument monitoring of

connectors can b e an expensive component to an LDAR program, the costs of an LDAR program with the more stringent leak definitions were considered both without instrument connector monitoring (Option 1) and with instrument connector monitoring (Option 2). This investigati on was performed under consideration of whether there have been “Any significant changes in the cost (including cost effectiveness) of applying controls (including controls the EPA considered during the development of the original MACT standards).”

Tab le 3 presents a summary of the equipment leak options that were analyzed. This table only shows pumps, valves and connectors in gas and vapor and light liquid service, since the requirements for the other types of equipment are largely the same under 40 CF R part 63, subparts TT and UU, as shown in Table 2. As a result, those equipment types were not further analyzed in this comparison of emissions reductions and costs for Options 1 and 2.

3 Memorandum fr om Hancy, C., RTI International, to Howard, J., EPA/OAQPS. Analysis of Emission Reduction Techniques for Equipment Leaks. December 21, 2011. EPA Docket No. EPA

- HQ

- OAR

- 2010

- 0869

- 0029.9 Table 3. Summary of Equipment Leak Options for the AMF Source Category

Type of Equipment Subpart TT (Baseline) Alternative Options Subpart UU

w/o connectors

(Option 1) Subpart UU

w/connectors

(Option 2)

Pumps in light liquid service Monthly Method 21 monitoring;

leak definition of 10,000 ppm Monthly Method 21 monitoring; leak definition of 1,000 ppm (repair at 2,000 ppm) Monthly Method 21 monitoring; leak definition of 1,000 ppm (repair at 2,000 ppm) Valves in gas and vapor and

in and light liquid service Monthly Method 21 monitoring;

leak definition of 10,000 ppm Monthly Method 21 monitoring; leak definition of 500 ppm Monthly Method 21 monitoring; leak definition of 500 ppm

Connectors in gas and vapor

and in and light liquid

service Sensory Monitoring Sensory Monitoring Method 21 mon itoring; leak definition of 500 ppm

4.1.3 Alternative Means of Compliance by Component Type and for Entire LDAR Program

An analysis of the emissions reductions and costs of the options identified for equipment leaks was performed. For the AMF source category, there is currently only one facility in operation. As a result, component counts provided by this facility were used for this analysis (see Attachment 3) to represent the AMF source category. 4 Table 4 presents the component counts for estimating equipment leak impacts from the AMF source category.

Table 4. Component Counts for the AMF Source Category 5

Equipment Component Number of Components Pumps (light liquid service) 6 Valves (light liquid service) 160 Connectors (light liquid service) 650

PRD 12

OEL 62

Next using the component counts in Table 4, emission factors were applied to determine the baseline emissions and the emissions under Options 1 and 2 that would be expected by equipment component type. These factors were multiplied by the number of components of that

4 Portion of presentation from Cytec entitled Leak Detection and Repair ( LDAR) program for Fugitive Equipment

Leaks . (See EPA Docket EPA

- HQ

- OAR

- 2012

- 0133).

5 Actual facility equipment component counts were used (see Attachment 3).10 type and converted to tons per year (tpy) to arrive at the total emissions in tpy at the baseline (40 CFR part 63, subpart TT) and for Options 1 and 2 (40 CFR part 63, subpart UU with and without connector monitoring). The se emissions factors were based on those used in the Uniform Standards analysis, but because the factors used in that analysis are for total organic compounds, which for chemical manufacturing facilities are generally volatile organic compounds (VOC),

thes e factors were modified to reflect the amount of VOC that are expected to be HAP. Using emissions data supplied to the EPA by the Cytec facility for the year 2011, HAP emissions were estimated to represent 43 percent of the total VOC emissions from this so urce category. A summary of emissions from Cytec are shown in Attachment 4. The resulting emissions factors that were used for the AMF source category are shown in Table 5.

Table 5. Equipment Leak Emission Factors by Component Type 6

Type of Equipment Emission Factor (kg/hr/component)

Baseline Option1/Option 2 Pump Seals

– Light Liquid Service 1.08E

- 03 2.99E

- 04

Valves

- Gas/Vapor Service 1.51E

- 04 8.73E

- 05

Valves

- Light Liquid Service 1.68E

- 04 9.98E

- 05

Connectors

– Gas/Vapor and Light Liquid Service 1.32E

- 04 6.97E

- 05

Table 6 shows the amount of HAP estimated at the baseline and considering the more stringent leak definitions for each component. This table also shows the total HAP emissions expected at the baseline and under LDAR program Opti ons 1 and 2 for these components.

To determine the costs of the LDAR program at the baseline and for Options 1 and 2, the approach taken was the approach used for the Uniform Standards analysis. In determining the costs for the AMF source category, the same leak rates, repair times, labor charges and other administrative and miscellaneous costs were assumed (see Attachment 5 for detailed cost calculations for the AMF source category). 7 Table 6 shows the costs and cost effectiveness by component and as a total for all three component types for each option. The cost effectiveness of Option 1 is $1,486, and for Option 2 the cost effectiveness is $13,975. The incremental cost effectiveness of Option 2 is $18,768.

6 See Table 6 of Memorandum from Hancy, C., RTI International, to Howard, J., EPA/OAQPS. Analysis of Emission Reduction Techniques for Equipment Leaks. December 21, 2011. EPA Docket No. EPA

- HQ

- OAR

- 2010

- 0869

- 0029. A HAP to VOC ratio of 0.43:1 was applied to these Table 6 values.

7 See Attachment 5 for Model 1 of Memorandum from Hancy, C., RTI Internatio nal, to Howard, J., EPA/OAQPS. Analysis of Emission Reduction Techniques for Equipment Leaks. December 21, 2011. EPA Docket No. EPA

- HQ

OAR

- 2010

- 0869

- 0029.

.11 Table 6. Summary of Equipment Leaks Analysis Results for the AMF Source Category

Type of Equipment Cost Parameter Baseline (subpart TT) Option 1 (subpart UU, w/o connectors) Option 2 (subpart UU, w/connectors)

Pumps in light liquid

service HAP Emissions 0.06 0.02

HAP Emission Reduction From Baseline

-- 0.05 Capital Cost Above Baseline

-- $891

Annualized Cost Above Baseline

-- $157

Cost Effectiveness

-- $3,471

Valves in light liquid service HAP Emissions 0.26 0.15

HAP Emission Reduction From Baseline

-- 0.10 Capital Cost Above Baseline

-- $537

Annualized Cost Above Baseline

-- $66

Cost Effectiveness

-- $631

Connectors HAP Emissions 0.83 0.83 0.44

HAP Emission Reduction From Baseline

-- -- 0.39 Capital Cost Above Baseline

-- -- $17,421

Annualized Cost Above Baseline

-- -- $7,345

Cost Effectiveness

-- -- $18,768

Total LDAR Program Cost HAP Emissions 1.15 1.00 0.61

HAP Emission Reduction From Baseline

-- 0.15 0.54

Incremental Emission Reduction (baseline→option 1, option 1→2) 0.15 0.39

Capital Cost Above Baseline

-- $1,428 $18,849

Annualized Cost Above Baseline

-- $223 $7,568

Cost Effectiveness

-- $1,486 $13,975

Incremental Cost Effectiveness (baseline→option 1, option 1→2) -- $1,486 $18,768A

- 1 

# Attachment 1: Results of RBLC Database QueriesRBLCID Facility name ST Permit Date Process Name Through

‐ put Throughput

Units Pollutant Control Method %
Efficiency

*SC

‐ 0116 CYTEC CARBON

FIBERS, LLC SC 04/30/2008 AN STORAGE AND RECOVERY 0 Volatile Organic
Compounds (VOC) EXISTING WASTE HEAT RECOVERY BOILER OR

PROCESS HEATER/AFTERBURNER WITH

CARBON BED ADSORBERS AS BACK UP. 99

*SC

‐ 0116 CYTEC CARBON

FIBERS, LLC SC 04/30/2008 POLYMER PRODUCTION 0 Volatile Organic
Compounds (VOC) EXISTING WASTE HEAT RECOVERY BOILER OR

PROCESS HEATER/AFTERBURNER WITH

CARBON BED ADSORBERS AS BACK UP. 99

*SC

‐ 0122 CYTEC CARBON

FIBERS, LLC SC 04/30/2008 POLYMER PRODUCTION 0 Volatile Organic
Compounds (VOC) EXISTING WASTE HEAT RECOVERY BOILER OR

PROCESS HEATER/AFTERBURNER WITH

CARBON BED ADSORBERS AS BACK UP. 99

AL

‐ 0226 TORAY CARBON

FIBER AMERICA,

INC. (CFA) AL 03/06/2007 132,086 GALLON SOLVENT

DELIVERY STORAGE TANK

VENTED TO SCRUBBER Volatile Organic
Compounds (VOC) SCRUBBER TA2

‐ 2 0

AL

‐ 0226 TORAY CARBON

FIBER AMERICA,

INC. (CFA) AL 03/06/2007 211,338 GALLON

ACRYLONITRILE DELIVERY

STORAGE TANK VENTED TO

SCRUBBER Volatile Organic
Compounds (VOC) SCRUBBER TA2

‐ 2 0

*SC

‐ 0116 CYTEC CARBON

FIBERS, LLC SC 04/30/2008 OXIDATION AND

CARBONIZATION 0 Volatile Organic
Compounds (VOC) NATURAL GAS FIRED TWO

‐ STAGE THERMAL

OXIDIZER 0

*SC

‐ 0116 CYTEC CARBON

FIBERS, LLC SC 04/30/2008 SPINNING GP3 0 Volatile Organic
Compounds (VOC) 0

*SC

‐ 0116 CYTEC CARBON

FIBERS, LLC SC 04/30/2008 OXIDATION AND

CARBONIZATION (SIZING
EMISSIONS) 0 Volatile Organic
Compounds (VOC) 0

*SC

‐ 0122 CYTEC CARBON

FIBERS, LLC SC 04/30/2008 OXIDATION AND

CARBONIZATION 0 Volatile Organic
Compounds (VOC) NATURAL GAS FIRED TWO

‐ STAGE THERMAL

OXIDIZER 0

*SC

‐ 0122 CYTEC CARBON

FIBERS, LLC SC 04/30/2008 OXIDATION AND

CARBONIZATION (SIZING
EMISSIONS) 0 Volatile Organic
Compounds (VOC) 0

*SC

‐ 0122 CYTEC CARBON

FIBERS, LLC SC 04/30/2008 SPINNING GP4 0 Volatile Organic
Compounds (VOC) 0

TX

‐ 0242 AMERICAN ACRYL L.P. TX 04/21/1999 SUPPORT PROCESS UNITS Volatile Organic
Compounds (VOC) 28 LAER LDAR, MONITORING, EMISSIONS

FROM TANKS

ROUTED TO THE SCRUBBER (99.9% RECOVERY) 0

AL

‐ 0226 TORAY CARBON

FIBER AMERICA,

INC. (CFA) AL 03/06/2007 (2) ACRYLIC FIBER

MANUFACTURING PROCESSES W/ SCRUBBERS Acrylonitrile SCRUBBERS RA2

‐ 2, TA2

‐ 2, PA2

‐ 1, PA2

‐ 2, PA3

‐ 1,

PA3

‐ 2 0A

- 3 

# Attachment 2: Analysis of Subsequent RegulationsA

- 4 Regulatory Actions Where Practices, Processes, and Con trol Technologies Were Considered for Emission Sources Similar to Those at Acrylic and Modacrylic Fiber Production Sources

Source Category Subpart Date of

Final Rule Practices, Processes, and Control Techniques

Evaluated

Polycarbonates

Production YY 6/29/99 combustion devices, recovery devices, LDAR, equipment modifications, floating roofs, steam stripping, biological treatment

Acetal Resins YY 6/29/99 combustion devices, recovery devices, LDAR, equipment modifications, floating roofs, steam stripping, biological treatment

Hydrogen Fluoride YY 6/29/99 recovery devices, scrubbers, LDAR, equipment modifications

Polymers and Resins

III OOO 1/20/00 combustion devices, recovery devices, pollution prevention to achieve mass emission limit, LDAR, equipment modifications, floating roofs

Ethylene Processes YY 7/12/02 combustion devices, recovery devices, LDAR, equipment modifications, floating roofs, steam stripping, biological treatment

Spandex Production YY 7/12/02 combustion devices, recovery devices, equipment modifications, floating roofs

Miscellaneous Organic Chemical

Production and Processes (MON) FFFF 11/10/03 combustion devices, recovery devices, halogen reduction devices, LDAR, equipment modifications, pollution prevention, flo ating roofs, steam stripping, biological

treatment

Area Source

Standards

PVC & Copolymer

Production DDDDD

D 1/23/07 recovery devices, steam stripping

Acrylic Fibers/Modacrylic

Fibers LLLLLL 7/16/07 scrubbers, floating roofs, combustion devices, recovery devices, steam stripping, biological treatment, LDAR, equipment modifications, pollution prevention

Chemical Manufacturing VVVVV

V 10/29/09 combustion devices, recovery devices, LDAR, equipment modifications, floating roofs, steam stripping,

biol ogical treatment

Chemical Preparations BBBBB

BB 12/30/09 scrubbers, LDAR

Residual Risk

StandardsA

- 5 Hazardous Organic NESHAP (HON) F, G, H 12/21/06 No significant development in practices, processes or control technologies since promulgation of

the MACT standards

Pharmaceuticals GGG 4/21/11 No significant development in practices, processes or control technologies since promulgation of

the MACT standards

Polymers and

Resins I U 4/21/11 No significant development in practices, processes or control technologies since promulgation of

the MACT standards

Hydrogen Fluoride YY 12/16/08 No significant development in practices, processes or control technologies since promulgation of

the MACT standards

Acetal Resins YY 12/16/08 No sig nificant development in practices, processes or control technologies since promulgation of

the MACT standardsA

- 6 

# Attachment 3:

EPA Plant Visit for AMF MACT RTR (Non

- Confidential)

# EPA On

- Site Visit for AMF MACT RTR

Cytec Carbon Fibers, LLC 

# February 23, 2012

# Agenda

• Introduction to CCF

• Acrylic Fiber Process Overview (high level)

• Key Customers, Programs & Markets

• Site Regulatory Overview

• Acrylic Fiber Regulatory Overview

• Combustion Sources

• Leak Detection & Repair Program

• Startup, Shutdown & Malfunctions

• Insignificant, Unpermitted, Uncontrolled Sources

• Acrylic Fiber Detailed Process Review

• Plant Tour

• Q&A

• Next Steps

2

# Commitment to SH&E

# Commitment to SH&E

# Introduction to CCF

5

# Greenville, SC Site Aerial View

6

# History

1976: Union Carbide began commercial pitch

- based carbon fiber production at Greenville site

1982: First commercial PAN

- based carbon fiber line in the U.S. began production at Greenville site (GP1)

1986: Business acquired by Amoco

1989: Second PAN

- based carbon fiber line began production at Greenville site (GP2)

1994: Acquired PAN

- based carbon fiber line in Rock Hill, SC from BASF (carbon fiber production only, not acrylic fiber)



# 1999: Amoco acquired by British Petroleum (BP)

2001: Business acquired by Cytec Industries and

renamed CCF

7

# CCF Existing Facilities

• Greenville, SC (140 acres)

— Operations, Business and R&D

— One pitch carbon fiber facility

— Two P AN carbon fiber facilities (GP1 & GP2)

— Acrylic fiber is a precursor, not a final product

— Produces all acrylic fiber precursor for CCF

— 2011 Acrylic Fiber Production: ~3,000 tons

— GP3 PAN carbon fiber facility expansion broke ground in 2008



## • Rock Hill, SC (2 acres)

— One PAN carbon f iber facility



### — No acrylic fiber production on

- site

8

# CCF Today: People

Staff

• Greenville ~ 250 employees

• Rock Hill ~ 50 employees

• 4 Rotating 12

- hr Crews

• PhD Scientists

• Chemical & Mechanical Engineers 

# Strong 6

- Sigma Culture

• Black Belts & Green Belts



# Skilled & Motivated

Workforce

• Excellent employee relations

• Empowered work teams

• Non

- union

9 

## Greenville Rock Hill

South Carolina

# Acrylic Fiber Process Overview (high level)

10

# Acrylic Fiber Process Overview

• Acrylic Fiber

— A manufactured synthetic fiber in which the fiber

- forming 

# substance is any long

- chain synthetic polymer composed of at least 85 percent by weight of acrylonitrile units



# • Modacrylic Fiber

— A manufactured synthetic fiber in which the fiber

- forming substance is any long

- chain synthetic polymer composed of at least 35 percent by weight of acrylonitrile units but less than 85 percent by weight of acrylonitrile units



# • CCF produces acrylic fiber, not modacrylic fiber

11

# Acrylic Fiber Process Overview

• Solution Polymerization

— A process where AN and co

- monomers are dissolved in a solvent to 

# form a polymer solution (typically PAN). The PAN is soluble in the solvent. In contrast to suspension polymerization, the resulting reactor polymer solution (spin dope) is filtered and pumped directly to the fiber spinning process.



# • Suspension Polymerization

— A process where small drops of AN and co

- monomers are suspended in water in the presence of a catalyst where they polymerize under agitation. Solid beads of polymer are formed in this suspension reaction which are subsequently filtered, washed, refiltered , and dried. The beads must be subsequently redissolved in a solvent to create a spin dope prior to introduction to the fiber spinning process.



# • CCF utilizes solution polymerization, not suspension

12

# Carbon Fiber Manufacture :

Batch Solution
Polymerization Spinning of

Acrylic Fiber Oxidation of Fiber

Pre

- carbonization/

Carbonization of Fiber 

# Surface Treatment
and Sizing of Fiber 

# Carbon Fiber

AMF Affected Source



# Recovery

# Acrylic Fiber: Materials Used or Produced

• Polymerization

— Monomer (HAP)

• Acrylonitrile (AN)



# — Co

- monomer (non

- HAP)

— Solvent (non

- HAP)

— Additives (non

- HAP)

— Neutralizer (non

- HAP)



# • Spinning

— Polymer Spin Dope (residual AN)

— PAN White Fiber (non

- HAP )

— Solvent (non

- HAP)

— Process Oils (non

- HAP) 

# • Recovery (Solvent & AN)

— RAN Inhibitor (HAP)

• Hydroquinone (HQ)



# — RAN Inhibitor (non

- HAP)

— Neutralizers (non

- HAP)

14

# Solution Polymerization (high level overview)

15 

## Temp

Time 

## AN (HAP)
Co

- monomer (non

- HAP) Solvent (non

- HAP)



# AN is polymerized in a Batch process

Batch polymer

reactor

Spin Dope

# Fiber Spinning (high level overview)

16 

# Filters

Spinneret Wet Jet Spinning Coagulation Bath

Water Metering



# p ump Spin Dope

Solvent/AN

Solvent/AN Recovery Process Solvent controls the rate of coagulation & works to suppress AN to send to recovery process

# Drawing and Washing (high level overview)

Wash to r emove solvent Draw (stretch) to orient f iber

17

# Key Customers, Programs & MarketsMarch 12, 2012 19



## Large Commercial Transport Military & Space

Engines Business & Regional Jets

Rotorcraft



# Distinct Footprint Across Aerospace For Diverse Applications 

# Markets We Serve

# Summary of PAN Carbon Fiber Markets

• Aerospace / Commercial Aircraft

— Largest qualification base of any supplier



### — Leading share of North American market (Boeing 737, 747, 757, 767, 777 & 787)

— Growing presence in Europe (Airbus)

— Several Superior Supplier Awards

— Strict and intensive qualification process



# • Engines

— T650/35 offers superior thermal stability

— Baseline fiber on most engine programs



### • General Electric

• Rolls Royce

• Pratt & Whitney

20

# • US Military

— Partnered & Sole Source Provider to numerous large programs

— Lockheed F35 Joint Strike Fighter

— Boeing F18 Fighter

— Lockheed C130 Transport

— Boeing C17 Transport

— Apache Helicopter

— Predator

— Global Hawk



# • Business & Regional Jets

— Bombardier

— Gulfstream



# • Other Markets

— Missiles, Space & Satellites

21 

# Summary of PAN Carbon Fiber Markets (cont’d)

# Summary of Pitch Carbon Fiber Markets

• Leading supplier of friction materials 

# for aircraft/auto racing brakes and space/launch markets

— Similar to aerospace & military contracts, strict and extensive qualification process



# • Specific Qualified Major Programs

— Commercial Aircraft

• Boeing 767

, 777

• McDonald Douglas MD11

• Airbus A

- 330

, A

- 340



### — Military

• F

- 15 , F

- 16, B1B , B

- 2, C17

— Business & Regional Aircraft

22

# Aerospace Qualification Requirements

• Changes to process that initiate requalification starts process over again

• Extreme business risk if requalification is initiated as it opens existing long

- term contracts (including sole source arrangements) to competitors

• Supply interruptions due to requalification could shutdown commercial and military production

23

# Aerospace Qualification Requirements

• Advanced notification of Change to Aerospace Customers for each specification and each product form specification

• We have 12 products serving most military and commercial aerospace customers, each with their own specifications

• Typical Aerospace Qualification per specification



# — Requires 2 to 3 batches of carbon fiber

• Several hundred coupon fiber test program



## — Requires 3 to 6 batches of prepreg materials

• Several thousand coupon prepreg test program



## — Customer Part Build

– first part qualification

— Customer performs on

- site Audit & Process Control Document Audit

— Completed Qualification test and part build report

— New process or change added to Approved Supplier List



# — Typical time

- frame is 9 to 18 months per customer

24

# Summary

• Safety, Health and Environmental compliance is our highest priority

• Our focus is on meeting the fiber quality and performance requirements of the industry’s most demanding applications

• We are bound by long

- term commercial and military contracts with strict restrictions on process changes

• Product development investments in resources and Pilot Plant capabilities to develop new fiber technologies for composite systems

• Product quality improvement and waste reductions continue driven by focused efforts supported by Six Sigma tools

25

# Site Regulatory Overview

26

# Site Regulatory Overview

• Greenville site is a Major Source

• Two Title V Operating Permits issued by SCDHEC

— Pitch

- based Carbon Fiber Production

• Includes process subject to MON MACT



# — PAN

- based Carbon Fiber Production

• Includes process subject to AMF MACT & NSPS for Synthetic Fiber Production

• Includes units that will be subject to Boiler MACT



# — Site

- wide SO 2 

# limit <100 tpy to avoid PSD

— Site

- wide VOC limit <128 tpy to avoid SC BACT/LAER

• Excluding emissions from GP1 Spinning since BACT analysis was performed in 2005

— Seven (7) control options were evaluated and determined to not be economically 

### feasible based on average cost effectiveness of $74k

- $840k/ton VOC removed

— Consistent with EPA’s proposal in the October 24, 2011 Federal Register to not review/revise the NSPS for Synthetic Fiber Production ―since EPA is unaware of any new emission control technologies for the industry‖

27

# Co

- located Facility

• Pitch

- based Carbon Fiber P roduction

— Resin B production process

• Precursor to pitch

- based carbon fiber

• SIC Code: 2824 (NAICS Code: 325222)

• Complies with MON MACT, effective 5/10/08

— Reactors are Group 1 batch process vents

• Reduce HAP to < 20 ppmv TOC by routing emissions through CVS to control device



### — Based on vapor pressure, storage tanks are Group 2 and do not require control

• SC regulatory requirements for Opacity & PM



# — Pitch carbon fiber production process

• SIC Code: 3624 (NAICS Code: 335991)

• SC regulatory requirements for Opacity & PM

11/29
/11

# Co

- located Processes

• PAN

- based Carbon Fiber Production



# • Research & Development (exempt from AMF MACT)

— Research lab & development processes on

- site for PAN

- based carbon fiber process

— Primary purpose is to conduct R&D into new processes & products

— Operated under close supervision of technically trained personnel



### — Not engaged in the manufacture of products for

commercial sale in commerce

29 

## Acrylic Fiber Process (AMF MACT regulated process)

SIC Code: 2824 Carbon Fiber Process (not AMF MACT regulated process)

SIC Code: 3624



#  Solution Polymerization  Spinning Recovery  Drawing  Washing  Drawing 

#  Drying  Oxidation  Pre

- carbonization  Carbonization  Surface Treatment 

#  Sizing  Winding

# Site

- wide Emissions

• Required to submit a complete site

- wide emissions inventory for Pitch and PAN processes every 3 years

• Last emissions inventory submitted was for 2008

• 2011 emissions inventory due to SCDHEC by 3/31/12

• Currently validating and updating inventory for RTR

30

# Acrylic Fiber Regulatory Overview

31

# Acrylic Fiber Regulatory Overview

• AMF MACT

• NSPS



# • RMP/PSM

• SC Regulations

32

# AMF MACT Definitions

• Affected Source

— All emission points, in combination, listed below that are associated with a suspension or solution polymerization process unit that produces acrylic and modacrylic fiber located at a major source

• Storage Vessels

• Process Vents

• Fiber Spinning Lines

• Equipment Leaks (LDAR)

• Wastewater

33

# • Storage Vessels

— We reduce AN emissions by > 98 wt% by venting through a CVS to a control device meeting the requirements of Subpart SS

34 

# AMF MACT Requirements

If you own or operate... And if... Then you must... 1. A storage

vessel The stored

material is acrylonitrile a. Reduce emissions of acrylonitrile by 98 weight

- percent

by venting emissions through a closed vent system to any combination of control device meeting the requirements of subpart SS (national emission standards for closed vent systems, control devices, recovery devices, and routing to a fuel gas system or a process), as specified in § 63.982(a)(1) (storage vessel requirements) of this part, or 95 weight

- percent or greater by venting through a closed vent system to a recovery device meeting the requirements of subpart SS (national emission standards for closed vent systems, control devices, recovery devices, and routing to a fuel gas system or a process), § 63.993 (recovery device requirements) of this part; or

b. Comply with the requirements of subpart WW (national emission standards for storage vessels (control level 2)) of this part.

# • Process Vent

— The point of discharge to the atmosphere (or the point of entry into a control device, if any) of a gas stream from a unit operation

— Excludes the following gas stream discharges:

• Relief valve discharges

• Leaks from equipment subject to this subpart (i.e., LDAR)

• Gas streams exiting a control device complying with this subpart

• Gas streams transferred to other processes for use

• Gas streams transferred for fuel value

• Gas streams from storage vessels subject to this subpart

• Gas streams from waste management units subject to this subpart

• Gas streams from wastewater streams subject to this subpart

• Gas streams exiting process analyzers

• Gas stream discharges that contain < 0.005 wt% total organic HAP

35 

# AMF MACT Definitions

# • Process Vents

— We reduce TOC to a concentration < 20 ppmv by venting through a CVS to a control device meeting the requirements of Subpart SS

36 

# AMF MACT Requirements

If you own or operate... And if... Then you must... 3. A process vent

from continuous unit operations ( nonhalogenated ) The vent steam has a mass emission rate of

halogen atoms contained in organic compounds <0.45 kilograms per hour a , and

an acrylonitrile concentration ≥50 parts per million by volume b and an average flow rate ≥0.005 cubic meters per minute a. Reduce emissions of acrylonitrile by using a flare meeting the requirements of subpart SS, § 63.987 (flare requirements) of this part

or

b. Reduce emissions of acrylonitrile by 98 weight

- percent, or reduce TOC to a concentration of 20 parts per million by volume, whichever is less stringent, by venting emissions through a closed vent system to any combination of control devices meeting the requirements of subpart SS (national emission standards for closed vent systems, control devices, recovery devices, and routing to a fuel gas system or a process), as specified in § 63.982(a)(2) (process vent requirements) of this part.

# • Fiber Spinning Line

— The group of equipment and process vents associated with acrylic fiber spinning operations. The fiber spinning line includes (as applicable to the type of spinning process used) the blending and dissolving tanks, spinning solution filters, wet spinning units, spin bath tanks, and the equipment used downstream of the spin bath to wash, dry, or draw the spun fiber.

37 

# AMF MACT Definitions

# • Fiber Spinning Lines (existing)

— Since we use spin dope from solution polymerization process, requirement is to maintain records and report AN emissions

38 

# AMF MACT Requirements

If you own or operate... And if... Then you must... 5. A fiber spinning

line that is an existing source The spinning line uses a spin dope

produced from a solution polymerization process Maintain records and report emissions as specified in §§ 63.1109 through 63.1110. Control of spinning line AN emissions is not required

6. A fiber spinning

line that is an existing source The spinning line uses a spin dope

produced from a suspension polymerization process a. Reduce the AN concentration of the spin dope to less than 100 ppmw b , or

b. Reduce acrylonitrile emissions from the spinning line to less than or equal to 0.025 kilograms of acrylonitrile per
megagram of acrylic and modacrylic fiber produced

. (Note: 0.025 kg appears to be typo)

# • Equipment

— Each of the following that is in organic HAP service:

• Pump

• Compressor

• Agitator

• Pressure Relief Device

• Sampling Collection System

• Open

- ended Valve or Line

• Valve

• Connector

• Instrumentation System

39 

# AMF MACT Definitions

# • Equipment

— We comply with the requirements of Subpart TT (i.e., LDAR)

40 

# AMF MACT Requirements

If you own or operate... And if... Then you must... 7. Equipment as

defined under § 63.1101 It contains or contacts ≥10 weight

percent acrylonitrile c , and operates ≥300 hours per year Comply with the requirements of subpart TT (national emission standards for equipment leaks (control level 1)) or subpart UU (national emission standards for equipment leaks (control level 2)) of this part.

# • Process Wastewater

— Wastewater discarded from a process unit which, during manufacturing or processing, comes into direct contact with or results from the production or use of any raw material, intermediate product, finished product, by

- product, or waste product. Examples are product tank drawdown or feed tank drawdown, water formed during a chemical reaction or used as a reactant, water used to wash impurities from organic products or reactants, equipment washes between batches in a batch process, water used to cool or quench 

### organic vapor streams through direct contact, and condensed steam from jet ejector systems pulling vacuum on vessels containing organics.



# • Maintenance Wastewater

— Wastewater discarded from a process unit that was generated by the draining of process 

### fluid from components in the process unit into an individual drain system prior to or during maintenance activities. Examples of activities that can generate maintenance

wastewaters include descaling of heat exchanger tubing bundles, cleaning of distillation column traps, draining of low legs and high point bleeds, draining of pumps into an individual drain system, and draining of portions of the process unit.

41 

# AMF MACT Definitions

# • Wastewater

— What would be process or maintenance wastewaters if discarded, are instead routed to Recovery for reuse of solvent & removal of AN for off

- site disposal as a RCRA regulated hazardous waste

— Wastewater from Recovery process containing residual AN & solvent is



# sent to on

- site wastewater pretreatment system prior to discharge to POTW

— Since process wastewater generated from Recovery is Group 2 (i.e., annual average AN concentration <1,000 ppmw ), requirement per referenced HON MACT is to report in NOCS and maintain records

42 

# AMF MACT Requirements

If you own or operate... And if... Then you must... 8. An acrylic and modacrylic fiber production process unit that generates process

wastewater The process wastewater stream is a Group 1 or Group 2 wastewater stream Comply with the requirements

of § 63.1106(a).

9. An acrylic and modacrylic fiber production process unit that generates maintenance

wastewater The maintenance

wastewater contains organic HAP Comply with the requirements

of § 63.1106(b).

# AMF MACT Requirements

• Closed Vent System & Control Devices

— Emissions from storage vessels and process vents are 

# routed to a common closed vent system

— Normally, two thermal oxidizers are controlling in parallel, with multiple carbon adsorbers available as a backup in the event that both thermal oxidizers are out of operation at the 

# same time (such as during a power outage)

43 GP1 Sources GP2 Sources

WHRB

Thermal
Oxidizer Process Heater

Thermal
Oxidizer

GP2 Carbon Beds GP1 Carbon Beds

# AMF MACT Requirements

– Control Devices

• Waste Heat Recovery Boiler (thermal oxidizer)

— Included design evaluation in NOCS to demonstrate > 98 wt% control for storage vessels

— Source test on 12/19/06 demonstrated < 20 ppmv TOC for control of process vents



### — Monitor combustion temperature at least once every 15 minutes ( > 1400 ° F)



# • Process Heater (thermal oxidizer)

— Included design evaluation in NOCS to demonstrate > 98 wt % control for storage vessels

— Source test on 12/19/02 demonstrated < 20 ppmv TOC for control of process vents

— Monitor combustion temperature at least once every 15 minutes ( > 1450 ° F)



# • GP1 & GP2 Carbon Beds (carbon adsorbers )

— Only used as control device if both thermal oxidizers are not operating (e.g., power outage)



### — Included design evaluation in NOCS to demonstrate > 98 wt % control for storage vessels

— Performance test waiver approved due to minimal use & continuous monitoring system

— Monitor outlet AN concentration at least once every 15 minutes ( < 20 ppmv )

44

# Acrylic Fiber Regulatory Overview

• Fiber Spinning Lines

— 40 CFR 60, Subpart HHH

- NSPS for Synthetic Fiber Lines

• VOC emissions < 20 lb/ton solvent feed to spin bath (6

- month rolling average basis)



### • Each monthly calculation is considered a new performance test

• Comply with the limit through use of a solvent that has very low emissions due to high boiling point and low vapor pressure (no add

- on controls)

• Similar to the RTR for MACT regulations, EPA is under a statutory requirement to review, and revise if needed, NSPS regulations



### • On October 24, 2011, the EPA proposed in the Federal Register to not review certain NSPS regulations, stating the following in a technical support document:

45

# Acrylic Fiber Regulatory Overview

• Hazard assessment

• Process safety information

• Process hazards analysis

• Operating procedures

• Training

• Mechanical integrity

• Management of change 

# • Pre

- startup review

• Compliance audits

• Incident investigation

• Employee participation

• Hot work p ermit

• Contractors

• Emergency response

46 

# AN is also regulated by the Chemical Accident Prevention Provisions, which require development of a Risk Management Plan 

# (RMP) to address requirements similar to OSHA’s PSM regulations,

with the addition of an off

- site impact analysis:

46

# Acrylic Fiber Regulatory Overview

• GP1, GP2 and Recovery

— SC R.61

- 62.5, Std 4

- Emissions from Process Industries

• Opacity < 40% (GP1) / < 20% (GP2 & Recovery), semi

- annual visual inspection

• PM < 1.07 lb / hr (GP1) / < 1.68 lb / hr (GP2) (limit based on process weight rate)



# • Waste Heat R ecovery B oiler & Process H eater

— SC R.61

- 62.2, Std 3

- Waste Combustion & Reduction

• Opacity < 20%, semi

- annual visual inspection

• PM < 0.5 lb / MMBtu input, record combustion temperature at least every 15 minutes

47

# Combustion Sources

48

# Combustion Sources

• Waste Heat Recovery Boiler

• Process Heater



# • Zurn Boiler

• Utility Boiler

49

# Combustion Sources

• Waste Heat Recovery Boiler (WA

- 03300)

— Installed in 1982, 7.0 MMBtu /hr, ~8760 hrs/yr



# — Thermal oxidizer with backend heat recovery

— Combusts NG to control lean process off

- gas emissions

— Control device for AMF MACT HAP & other VOC/HAP



# — Potentially subject to upcoming Boiler MACT

— SC R.61

- 62.2, Std 3

- Waste Combustion & Reduction

• Opacity < 20%, semi

- annual visual inspection

• PM < 0.5 lb / MMBtu input, record combustion temperature at least every 15 minutes



# — Source test performed for AMF MACT on 12/19/06

• Demonstrated compliance with < 20 ppmv TOC limit

50

# Combustion Sources

• Process Heater (WA

- 21200)

— Installed in 1997, 2.0 MMBtu /hr, ~8760 hrs/yr



# — Thermal oxidizer with backend heat recovery

— Combusts natural gas & process off

- gas

— Control device for AMF MACT HAP & other VOC/HAP



# — Potentially subject to upcoming Boiler MACT

— SC R.61

- 62.2, Std 3

- Waste Combustion & Reduction

• Opacity < 20%, semi

- annual visual inspection

• PM < 0.5 lb / MMBtu input, record combustion temperature at least every 15 minutes



# — Source test performed for AMF MACT on 12/19/02

• Demonstrated compliance with < 20 ppmv TOC limit

51

# Combustion Sources

• Zurn Boiler (UT

- 24600)

— Installed in 1988, 62.5 MMBtu /hr, ~8760 hrs/yr

— Steam production is primary purpose



# — Combusts NG/(No. 2 fuel oil) to control lean process off

- gas

— Control device for VOC/HAP (non

- MACT)

— Subject to upcoming Boiler MACT



# — SC R.61

- 62.5, Std 1

- Fuel Burning Operations

• PM < 0.6 lb / MMBtu input, use fuel with sulfur content < 0.5 wt %

• SO 2 

### < 3.5 lb / MMBtu input, use fuel with sulfur content < 0.5 wt %

• Opacity < 20% (60% for soot blowing), semi

- annual visual inspection



# — SC R.61

- 62.2, Std 3

- Waste Combustion & Reduction

• Limits on Ni, Cd, Cr, As, Pb

, HCl (no monitoring based on knowledge of waste)



# — SC R.61

- 62.1(II)(E)

- Synthetic Minor

• NO

x 

### < 40 tpy to avoid PSD review,



### use < 1,125,000 gal/yr of No. 2 fuel oil

52

# Combustion Sources

• Utility Boiler (U01)

— Installed in 1982, 25.1 MMBtu /hr, ~8760 hrs/yr



# — Used for steam production

— Combusts natural gas (or No. 2 fuel oil)

— Subject to upcoming Boiler MACT



# — SC R.61

- 62.5, Std 1

- Fuel Burning Operations

• PM < 0.6 lb / MMBtu input, use fuel with sulfur content < 0.5 wt %

• SO 2 

### < 3.5 lb / MMBtu input, use fuel with sulfur content < 0.5 wt %

• Opacity < 20% (60% for sootblowing ), semi

- annual visual inspection

53

# Leak Detection and Repair (LDAR) Program for Fugitive Equipment Leaks

54

# LDAR Program Overview

• Comply with the requirements of Subpart TT

• Applicable to equipment that contains or contacts > 10 wt % 

# AN and operates > 300 hours per year

• Equipment subject to LDAR is identified in a written plan, on P&IDs, and in the field with yellow ID tags



# • EPA Method 21 Monitoring

— Performed with a flame ionization detector (FID)

— Contractor performs routine Method 21 monitoring

— Qualified CCF personnel perform non

- routine monitoring

55

# LDAR Program Overview

• If leak is detected, weatherproof and readily visible ID tag is attached to the leaking equipment



# • First attempt at repair within 5 calendar days

• Final repair within 15 calendar days

• Repairs performed in

- house or by contractor

56

# LDAR Program Overview

• Valves: 160 (includes 16 difficult

- to

- monitor)



# — Leak Definition: > 10,000 ppmv

• If located on CVS, leak definition is >500 ppmv in accordance with Subpart SS



# — Since <250 valves, accessible valves monitored quarterly

— Difficult

- to

- monitor valves monitored annually

— Monitoring performed by contractor

— Utilize EPA Method 21 for monitoring

57

# LDAR Program Overview

• Pumps: 6

— Leak Definition: > 10,000 ppmv /visual liquid dripping



# — Weekly in

- house visual inspection

• If observe visual liquid dripping:

— Repair to eliminate dripping, or

— Demonstrate using Method 21 that liquids dripping are not due to process fluid drips



# — Monthly Method 21 inspection performed by contractor

58

# LDAR Program Overview

• Agitators: 2

— Leak Definition: > 10,000 ppmv



# — Weekly in

- house visual inspection

• If observe visual liquid dripping from agitator seal, then prior to next required inspection:

— Monitor using Method 21 to determine if > 10,000 ppmv , and



## — Eliminate the indications of liquids dripping from the agitator seal



# — Monthly Method 21 inspection performed by contractor

59

# • Pressure Relief Device (PRD) in gas/vapor service 

# : 2 (w/RD)



# — Defined as safety device actuated by a pressure >2.5 psi

— Leak Definition: > 500 ppmv (N/A during pressure release)

• As soon as practical, but no later than 5 calendar days after the pressure release and being returned to regulated material service, must monitor PRD using Method 21 to


### confirm <500 ppmv

• Rupture Disk (RD) Exemption: If equipped with RD upstream of PRD, the PRD is exempt as long as replacement RD upstream of PRD is installed as soon as practical, but no later than 5 calendar days after each pressure release



# — Additional 7 stand

- alone rupture disks for total of 9

• Rupture disks are classified as connectors for purposes of LDAR per Subpart TT

• 7 rupture disks are equipped with an optical burst indicator and 2 operate under vacuum

• Weighted manway on AN Storage Tank monitored as a valve and has proximity switch

• Event activates alarm and is electronically recorded (some initiate process interlocks)

• Events are entered into incident reporting system and investigated

• Per file review, four (4) events (malfunctions) since AMF MACT
compliance effective date of 6/29/02

• Report to SCDHEC if event lasts for ≥1 hour

60 

# LDAR Program Overview

# • Pressure Relief Device (PRD) in liquid service 

# : 3 (w/RD)



# — Defined as safety device actuated by a pressure >2.5 psi



# — Leak Definition: > 10,000 ppmv (N/A during pressure release)

• Monitor using Method 21 within 5 calendar days if evidence of a potential leak to atmosphere is found by visual, audible, olfactory or other detection method

• If potential leak is repaired to eliminate all visual, audible, olfactory or other indications of a leak, then monitoring using Method 21 is not necessary



# — Relief Detection

• Each RD is equipped with a burst indicator (i.e., pressure alarm)

• Event activates alarm and interlocks process

• Entered into incident reporting system and investigated



### • Per file review, no PRD releases since AMF MACT compliance effective date of 6/29/02

• Report to SCDHEC if event lasts for ≥1 hour

61 

# LDAR Program Overview

# • Connectors: ~650

— Leak Definition: > 10,000 ppmv

• If located on CVS, leak definition is >500 ppmv in accordance with Subpart SS



# — Monitor using Method 21 within 5 calendar days if evidence of a potential leak to atmosphere is found by visual, audible, olfactory or other detection method



# — If potential leak is repaired to eliminate all visual, audible, olfactory or other indications of a leak, then monitoring using Method 21 is not necessary



# — Routine Method 21 monitoring of pumps, agitators, and

valves includes associated connectors

62 

# LDAR Program Overview

# • Open

- ended Valves or Lines: 62

— Each open

- ended valve or line is equipped with a cap, 

# blind flange, plug or a second valve to seal the open end at all times except during operations requiring process fluid flow or during maintenance

— Each open

- ended valve equipped with a second valve is operated so that the valve on the process fluid end is

closed before the second valve is closed

63 

# LDAR Program Overview

# Startup/Shutdown/Malfunction (SSM)

# Startup/Shutdown/Malfunction (SSM)

• Startup/Shutdown

— No excess emission events are anticipated from startup



# and shutdown activities

— Normal operating standards are followed and met during startup and shutdown activities

65

# Startup/Shutdown/Malfunction (SSM)

• Malfunction

— any sudden, infrequent, and not reasonably preventable failure of air pollution control equipment, process equipment, or a process to 

# operate in a normal or usual manner which causes, or has the potential to cause, the emission limitations in an applicable standard to be exceeded. Failures that are caused in part by poor maintenance or careless operation are not malfunctions



# • Malfunctions since 6/29/2002 compliance date:

— Three (3) rupture disks & one (1) weighted manway release

— Two (2) operating thermal oxidizer < minimum temperature



# — One (1) operating carbon adsorber > maximum AN concentration

— Entered into incident reporting system and investigated

— Report to SCDHEC if event lasts for ≥1 hour

66

# Insignificant/Unpermitted/Uncontrolled
Air Emissions Sources

67

# RAN Inhibitor Mixing

• Use hydroquinone (HQ) as inhibitor to stabilize recovered AN prior to shipping off

- site for disposal

— Mix HQ with non

- HAP solvent 1

- 2x/ wk for adding to recovered AN

— AP

- 42, Table 11.13

- 2, Glass Fiber Manufacturing

— Mixing & Weighing, Filterable PM

— Emission Factor = 0.6 lb PM/ton HQ



# — Emissions: ~4 lbs/yr

68

# Acrylic Fiber Detailed Process Review

# • Fiber Spinning Lines (existing)

— Since we use spin dope from solution polymerization process, requirement is to maintain records and report AN emissions

70 

# AMF MACT Requirements

If you own or operate... And if... Then you must... 5. A fiber spinning

line that is an existing source The spinning line uses a spin dope

produced from a solution polymerization process Maintain records and report emissions as specified in §§ 63.1109 through 63.1110. Control of spinning line AN emissions is not required

6. A fiber spinning

line that is an existing source The spinning line uses a spin dope

produced from a suspension polymerization process a. Reduce the AN concentration of the spin dope to less than 100 ppmw b , or

b. Reduce acrylonitrile emissions from the spinning line to less than or equal to 0.025 kilograms of acrylonitrile per
megagram of acrylic and modacrylic fiber produced

. (Note: 0.025 kg appears to be typo)

# • 11/98

- Amoco provided testimony at EPA Public Hearing

• 1/99

- Amoco submitted written comments as part of docket for proposed AMF MACT (A

- 97

- 17 & A

- 97

- 18)

• 5/99

- EPA’s Summary of Public C omments & Responses

• 6/99

- Preamble to Final AMF MACT

71 

# AMF MACT for Existing Fiber Spinning Lines

# • Preamble Language for Current Rule Remains Accur 

# ate

— Federal Register Vol. 64

- June 29, 1999



# • Significant Differences between Suspension and Solution 

# Polymerization Processes

— Solution polymerization spin dope contains, by product and process design, a significantly higher concentration of residual AN (p. 34862)

— Solution polymerization cannot utilize direct steam contact (p. 34862)



# • Design Limitations Still Valid

— In practice, there are no AMF production facilities which have enclosed and captured the emissions from their spinning lines and vented them to a control device. The 85% control requirement remains not applicable (p. 34861, 34862)

— The pollution prevention techniques utilized by suspension polymerization processes (e.g., steam stripping, scavenger solvents) remain not applicable (p. 34862)

— Difficulties & cost associated with control on high airflows with low concentrations (p. 34862)

— Industrial hygiene and worker safeguards and concerns remain valid (p. 34862)

72 

# AMF MACT for Existing Fiber Spinning Lines

# Fiber Spinning (high level overview)

73 

# Filters

Spinneret Wet Jet Spinning Coagulation Bath

Water Metering



# p ump Spin Dope

Solvent/AN

Solvent/AN Recovery Process Solvent controls the rate of coagulation & works to suppress AN to send to recovery process

# • Link to PFD

74 

# Acrylic Fiber Detailed Process Review

# Questions

75

# Remainder of Visit

76 

# • Tour

• Safety



# • Q&A

• Next Steps

# Next Steps

77 

# • Cytec will provide:

— Requested follow

- up materials (per CBI procedures)

— Validated emissions inventory data and parameters

— A list of issues with the current regulation (typos, provisions that are not 

# entirely clear, etc.) for EPA to consider



# • Future Activity that Cytec would like to Partner with EPA:

— Risk Assessment

— MACT Floor Determination

— Beyond

- the

- Floor Analysis, if applicable

— Review of Draft Regulatory Changes



# • Schedule & Timeline for RTR Process?

• Relevance of Upcoming Uniform Standards?

# THANK YOUA-  

# Attachment 4:

2011 Cytec EmissionsPollutant Type Pollutant Code Pollutant Name UOM South Carolina Department of

Health and Environmental Control

CAP 7439921 Lead TON 0.0001

CAP CO Carbon Monoxide TON 27.2505

CAP NH3 Ammonia TON 0.2822

CAP NOX Nitrogen Oxides TON 83.8025

CAP PM10

‐ PRI PM10 Primary (Filt + Cond) TON 4.4428

CAP PM25

‐ PRI PM2.5 Primary (Filt + Cond) TON 1.5038

CAP SO2 Sulfur Dioxide TON 0.1268

CAP VOC Volatile Organic Compounds TON 77.5708

GHG CH4 Methane TON 0.4582

GHG CO2 Carbon Dioxide TON 23,597.55

HAP 106467 1,4

‐ Dichlorobenzene LB 0.4711
HAP 107131 Acrylonitrile LB 66,430.34

HAP 110543 Hexane LB 707.762

HAP 120127 Anthracene LB 0.0001
HAP 123319 Hydroquinone LB 3.6

HAP 129000 Pyrene LB 0.0023

HAP 206440 Fluoranthene LB 0.0016
HAP 50000 Formaldehyde LB 30.0245
HAP 56553 Benz[a]Anthracene LB 0.0001

HAP 68122 N,N

‐ Dimethylformamide LB 8,926.97

HAP 71432 Benzene LB 0.8987

HAP 7439965 Manganese LB 0.1495

HAP 7439976 Mercury LB 0.1022

HAP 7440020 Nickel LB 0.8256

HAP 7440382 Arsenic LB 0.0787

HAP 7440439 Cadmium LB 0.4326
HAP 74908 Hydrogen Cyanide LB 4,331.89

HAP 75058 Acetonitrile LB 13.044
HAP 75070 Acetaldehyde LB 0.0519

HAP 85018 Phenanthrene LB 0.0085

HAP 86737 Fluorene LB 0.0029
HAP 91203 Naphthalene LB 0.2459

HAP 91576 2

‐ Methylnaphthalene LB 0.0095

VOC Emissions ton 77.57

HAP (AN) Emissions ton 33.22

HAP:VOC Ratio 42.8%A-8  

# Attachment 5: Equipment Leak Model Plant CostsATTACHMENT5ModelCostsforEquipmentLeaksfromAcrylicandModacrylicFibersSourceCategoryType of ComponentNumber ofComponentsInitialMonitoring Feeor Unit Cost($/comp)InitialMonitoringCosts ($/yr)(Capital)InitialLDARAdmin.CostsFrequencyof Monitoring(times/yr)SubsequentMonitoringFee ($/comp)or Charge(%)AnnualMonitoringCosts ($/yr)AnnualMaintenanceCosts ($/yr)Initial LeakFrequency(%)InitialNumberof LeaksSubsequentLeakFrequency(%)AnnualNumberof LeaksPercentRepairedOnLineRepairTime(hours)LaborCharge($/hr)AnnualOnLine LeakRepair Cost($/yr)PercentRequiringFurtherRepairRepairTime(hours)LaborCharge($/hr)AnnualOffline LeakRepair Cost($/yr)Monitoringto VerifyRepair ($)AnnualAdmin.Cost ($/yr)AnnualMisc.Charges($/yr)Pump Option 1 (1,000 ppm)66.24 $/hr, labor rate for repairPump Seals (UU)* Light-liquid service60.00 857.22121.50 232.05 52.92 13.48 0.81 0.26 0.19 100 16.00 66.24 198.41 0 80.00 66.24 0.00 0.2842.34* Heavy-liquid service00.00 0.00Replacement Pump Seals6282.71 228.66Annual Adminstrative and Repo092.72$0- Assume 300 hr per facInitial Planning and Training092.72$0- Assume 340 hr per facTOTALS$1,086 $0$232$53$198$0 $0 $0 $42Capital Costs$1,086Annualized Capital Costs $178Annual Expenses$526Annual Fixed Costs ($/yr) $220Annual Variable Costs ($/yr) $484$704Type of ComponentNumber ofComponentsInitialMonitoring Feeor Unit Cost($/comp)InitialMonitoringCosts ($/yr)(Capital)InitialLDARAdmin.CostsFrequencyof Monitoring(times/yr)SubsequentMonitoringFee ($/comp)or Charge(%)AnnualMonitoringCosts ($/yr)AnnualMaintenanceCosts ($/yr)Initial LeakFrequency(%)InitialNumberof LeaksSubsequentLeakFrequency(%)AnnualNumberof LeaksPercentRepairedOnLineRepairTime(hours)LaborCharge($/hr)AnnualOnLine LeakRepair Cost($/yr)PercentRequiringFurtherRepairRepairTime(hours)LaborCharge($/hr)AnnualOffline LeakRepair Cost($/yr)Monitoringto VerifyRepair ($)AnnualAdmin.Cost ($/yr)AnnualMisc.Charges($/yr)Baseline Monitoring (10,000 ppm)66.24 $/hr, labor rate for repairPump Seals (UU)* Light-liquid service60.00 153.89121.50 232.05 46.82 2.42 0.15 0.23 0.17 100 16.00 66.24 175.51 0 80.00 66.24 0.00 0.2537.45* Heavy-liquid service00.00 0.00Replacement Pump Seals6282.71 41.05Annual Adminstrative and Repo092.72$0- Assume 300 hr per facInitial Planning and Training092.72$0- Assume 340 hr per facTOTALS$195 $0$232$47$176$0 $0 $0 $37Capital Costs$195Annualized Capital Costs $32Annual Expenses$492Annual Fixed Costs ($/yr)$69Annual Variable Costs ($/yr) $455$524INCREMENTAL COSTS OF PUMPS OPTION 1Incremental Capital Costs ($) 891Annualized Capital ($/yr) 146Incremental Annual Expenses ($/yr) 34180ATTACHMENT5ModelCostsforEquipmentLeaksfromAcrylicandModacrylicFibersSourceCategoryType of ComponentNumber ofComponentsInitialMonitoring Feeor Unit Cost($/comp)InitialMonitoringCosts ($/yr)(Capital)InitialLDARAdmin.CostsFrequencyof Monitoring(times/yr)SubsequentMonitoringFee ($/comp)or Charge(%)AnnualMonitoringCosts ($/yr)AnnualMaintenanceCosts ($/yr)Initial LeakFrequency(%)InitialNumberof LeaksSubsequentLeakFrequency(%)AnnualNumberof LeaksPercentRepairedOnLineRepairTime(hours)LaborCharge($/hr)AnnualOnLine LeakRepair Cost($/yr)PercentRequiringFurtherRepairRepairTime(hours)LaborCharge($/hr)AnnualOffline LeakRepair Cost($/yr)Monitoringto VerifyRepair ($)AnnualAdmin.Cost ($/yr)AnnualMisc.Charges($/yr)Valves Option 1 (500 ppm)66.24 $/hr, labor rate for repairValves (UU)* Gas/vapor service00.00 0.0021.50 0.007.24 0.00 0.51 0.00 75 0.17 66.24 0.00 25 4.00 66.24 0.00 0.00* Light-liquid service1600.00 577.2321.50 480.004.84 7.74 0.51 1.63 75 0.17 66.24 13.54 25 4.00 66.24 108.11 2.45* Heavy-liquid service01.10 0.001Annual Adminstrative and Repo092.72$0- Assume 300 hr per facInitial Planning and Training092.72$0- Assume 340 hr per facTOTALS$577 $0$480$0$14$108 $2 $0 $0Capital Costs$577Annualized Capital Costs $82Annual Expenses$604686Type of ComponentNumber ofComponentsInitialMonitoring Feeor Unit Cost($/comp)InitialMonitoringCosts ($/yr)(Capital)InitialLDARAdmin.CostsFrequencyof Monitoring(times/yr)SubsequentMonitoringFee ($/comp)or Charge(%)AnnualMonitoringCosts ($/yr)AnnualMaintenanceCosts ($/yr)Initial LeakFrequency(%)InitialNumberof LeaksSubsequentLeakFrequency(%)AnnualNumberof LeaksPercentRepairedOnLineRepairTime(hours)LaborCharge($/hr)AnnualOnLine LeakRepair Cost($/yr)PercentRequiringFurtherRepairRepairTime(hours)LaborCharge($/hr)AnnualOffline LeakRepair Cost($/yr)Monitoringto VerifyRepair ($)AnnualAdmin.Cost ($/yr)AnnualMisc.Charges($/yr)Valves-Baseline Monitoring (10,000 ppm)66.24 $/hr, labor rate for repairValves (UU)* Gas/vapor service00.00 0.0021.50 0.000.34 0.00 0.34 0.00 75 0.17 66.24 0.00 25 4.00 66.24 0.00 0.00* Light-liquid service1600.00 40.1321.50 480.000.34 0.54 0.34 1.08 75 0.17 66.24 8.93 25 4.00 66.24 71.33 1.62* Heavy-liquid service00.00 0.0000.00 Nat. fac0.00 Nat. BatchAnnual Adminstrative and Repo092.72$01.00 Nat. Contf- Assume 300 hr per facInitial Planning and Training092.72$0- Assume 340 hr per facTOTALS$40 $0$480$0$9$71 $2 $0 $0Capital Costs$40Annualized Capital Costs $6Annual Expenses$562Annual Fixed Costs ($/yr)$6Annual Variable Costs ($/yr) $562$568INCREMENTAL COSTS OF VALVES OPTION 1Incremental Capital Costs ($) 537Annualized Capital ($/yr) 76Incremental Annual Expenses ($/yr) 42119ATTACHMENT5ModelCostsforEquipmentLeaksfromAcrylicandModacrylicFibersSourceCategoryType of ComponentNumber ofComponentsInitialMonitoring Feeor Unit Cost($/comp)InitialMonitoringCosts ($/yr)(Capital)InitialLDARAdmin.CostsFrequencyof Monitoring(times/yr)SubsequentMonitoringFee ($/comp)or Charge(%)AnnualMonitoringCosts ($/yr)AnnualMaintenanceCosts ($/yr)Initial LeakFrequency(%)InitialNumberof LeaksSubsequentLeakFrequency(%)AnnualNumberof LeaksPercentRepairedOnLineRepairTime(hours)LaborCharge($/hr)AnnualOnLine LeakRepair Cost($/yr)PercentRequiringFurtherRepairRepairTime(hours)LaborCharge($/hr)AnnualOffline LeakRepair Cost($/yr)Monitoringto VerifyRepair ($)AnnualAdmin.Cost ($/yr)AnnualMisc.Charges($/yr)Connectors Option 1 (500 ppm)66.24 $/hr, labor rate for repairConnectors* Flanges - gas/vapor* Flanges - light liquid650 23.80 15566.920.252.50 406.250.36 2.34 0.36 0.59 75 0.17 66.24 4.85 25 2.00 66.24 19.38 1.46* Flanges -heavy liquid1Annual Adminstrative and Repo5092.72$4,636Initial Planning and Training2092.72$1,854TOTALS$15,567 $1,854$406$0$5$19 $1 $4,636 $0INCREMENTAL COSTS OF CONNECTORS OPTION 1Capital Costs$17,421Annualized Capital Costs $2,474Annual Expenses$5,066Annual Fixed Costs ($/yr) $7,110Annual Variable Costs ($/yr) $430$7,540