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 national 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 (promulgated 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 MACT 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 technologies 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 during 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 pollution 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 controls 

(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 October 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, 1999, 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 percent 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 which 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 carbon 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 recovery, 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 are 

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 presence 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 associated 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 vessels, 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 equipment 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 sources 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 Table 1.
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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 with 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 practices, 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-attainment 
5

areas). BACT, or Best Available 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 decisions 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 prevention 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 technologies 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;

• Throughput;

• 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 emission 

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 MACT 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.
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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 determine 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 

Devices, 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: any add-on control 

technology or other equipment that was not identified and considered 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 procedure 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 leaks 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 amount 

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. 
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4.1.1 Summary of Existing MACT Level of Control

The AMF MACT standards for equipment leaks apply to the group of all equipment, intended to 

operate in organic HAP service2 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 provisions 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 requirements.

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 MACT 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.
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As part of the Uniform Standards development, in 2011, the EPA conducted a general review 

and analysis of emissions reduction techniques for equipment 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 controlling 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 requirements 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 be 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 investigation 

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).” 

Table 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 CFR 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 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.
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 monitoring; 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 Category5

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).
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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). These 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), 

these 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 source 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 Type6

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 Options 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 International, to Howard, J., EPA/OAQPS. 

Analysis of Emission Reduction Techniques for Equipment Leaks. December 21, 2011. EPA Docket No. EPA-HQOAR-2010-0869-0029. 

.
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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 $18,768
A-1

Attachment 1:

Results of RBLC Database Queries
RBLCID 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 0
A-3

Attachment 2:

Analysis of Subsequent Regulations
A-4

Regulatory Actions Where Practices, Processes, and Control 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, floating 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, 

biological treatment

Chemical 

Preparations 

BBBBB

BB 12/30/09 scrubbers, LDAR

Residual Risk 

Standards
A-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 significant development in practices, 

processes or control technologies since promulgation of 

the MACT standards
A-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 PAN 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 fiber 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 

pump

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)

Draw (stretch) to orient fiber Wash to remove solvent

17
Key Customers, Programs & Markets
March 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 SO2limit <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 Production

— 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 houra, and 

an acrylonitrile concentration ≥50 parts per 

million by volumeband 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 ppmwb, 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 weightpercent acrylonitrilec

, 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

GP2 Sources GP1 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 permit

• 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 Recovery Boiler & Process Heater

— 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%

• SO2 <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

• NOx <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%

• SO2 <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 ppmwb, 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 Comments & Responses

• 6/99 - Preamble to Final AMF MACT

71

AMF MACT for Existing Fiber Spinning Lines
• Preamble Language for Current Rule Remains Accurate

— 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 

pump

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 YOU
A-

Attachment 4:

2011 Cytec Emissions
Pollutant 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 Costs
ATTACHMENT 5

Model Costs for Equipment Leaks from Acrylic and Modacrylic Fibers Source Category

Type of Component Number of Components

Initial 

Monitoring Fee

or Unit Cost 

($/comp)

Initial 

Monitoring 

Costs ($/yr) 

(Capital)

Initial 

LDAR 

Admin. 

Costs

Frequency 

of Monitoring

(times/yr)

Subsequent 

Monitoring 

Fee ($/comp) 

or Charge 

(%)

Annual 

Monitoring 

Costs ($/yr)

Annual 

Maintenance 

Costs ($/yr)

Initial Leak 

Frequency 

(%)

Initial 

Number 

of Leaks

Subsequent 

Leak 

Frequency 

(%)

Annual 

Number 

of Leaks

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Pump Option 1 (1,000 ppm)

66.24 $/hr, labor rate for repair

Pump Seals (UU) * Light-liquid service 6 0.00 857.22 12 1.50 232.05 52.92 13.48 0.81 0.26 0.19 100 16.00 66.24 198.41 0 

 * Heavy-liquid service 0 0.00 0.00Replacement Pump Seals 6 282.71 228.66Annual Adminstrative and Repo 0 92.72 

 - Assume 300 hr per facInitial Planning and Training 0 92.72 $0

 - Assume 340 hr per facTOTALS $1,086 $0 $232 $53 $198 

Capital Costs $1,086

Annualized Capital Costs $178

Annual Expenses $526

Annual Fixed Costs ($/yr) $220

Annual Variable Costs ($/yr) $484

$704

Type of Component Number of Components

Initial 

Monitoring Fee

or Unit Cost 

($/comp)

Initial 

Monitoring 

Costs ($/yr) 

(Capital)

Initial 

LDAR 

Admin. 

Costs

Frequency 

of Monitoring

(times/yr)

Subsequent 

Monitoring 

Fee ($/comp) 

or Charge 

(%)

Annual 

Monitoring 

Costs ($/yr)

Annual 

Maintenance 

Costs ($/yr)

Initial Leak 

Frequency 

(%)

Initial 

Number 

of Leaks

Subsequent 

Leak 

Frequency 

(%)

Annual 

Number 

of Leaks

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Baseline Monitoring (10,000 ppm)

66.24 $/hr, labor rate for repair

Pump Seals (UU) * Light-liquid service 6 0.00 153.89 12 1.50 232.05 46.82 2.42 0.15 0.23 0.17 100 16.00 66.24 175.51 0 

 * Heavy-liquid service 0 0.00 0.00

Replacement Pump Seals 6 282.71 41.05Annual Adminstrative and Repo 0 92.72 

 - Assume 300 hr per facInitial Planning and Training 0 92.72 $0

 - Assume 340 hr per facTOTALS $195 $0 $232 $47 $176 

Capital Costs $195

Annualized Capital Costs $32

Annual Expenses $492

Annual Fixed Costs ($/yr) $69

Annual Variable Costs ($/yr) $455

$524

INCREMENTAL COSTS OF PUMPS OPTION 1

Incremental Capital Costs ($) 891

Annualized Capital ($/yr) 146

Incremental Annual Expenses ($/yr) 34

180
ATTACHMENT 5

Model Costs for Equipment Leaks from Acrylic and Modacrylic Fibers Source Category

Type of Component Number of Components

Initial 

Monitoring Fee

or Unit Cost 

($/comp)

Initial 

Monitoring 

Costs ($/yr) 

(Capital)

Initial 

LDAR 

Admin. 

Costs

Frequency 

of Monitoring

(times/yr)

Subsequent 

Monitoring 

Fee ($/comp) 

or Charge 

(%)

Annual 

Monitoring 

Costs ($/yr)

Annual 

Maintenance 

Costs ($/yr)

Initial Leak 

Frequency 

(%)

Initial 

Number 

of Leaks

Subsequent 

Leak 

Frequency 

(%)

Annual 

Number 

of Leaks

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak

Repair Cost 

($/yr)

Valves Option 1 (500 ppm)

66.24 $/hr, labor rate for repair

Valves (UU) * Gas/vapor service 0 0.00 0.00 2 1.50 0.00 7.24 0.00 0.51 0.00 75 0.17 66.24 0.00 

 * Light-liquid service 160 0.00 577.23 2 1.50 480.00 4.84 7.74 0.51 1.63 75 0.17 66.24 13.54 

 * Heavy-liquid service 0 1.10 0.00 1

Annual Adminstrative and Repo 0 92.72 

 - Assume 300 hr per facInitial Planning and Training 0 92.72 $0

 - Assume 340 hr per facTOTALS $577 $0 $480 $0 $14 

Capital Costs $577

Annualized Capital Costs $82

Annual Expenses $604

686

Type of Component Number of Components

Initial 

Monitoring Fee

or Unit Cost 

($/comp)

Initial 

Monitoring 

Costs ($/yr) 

(Capital)

Initial 

LDAR 

Admin. 

Costs

Frequency 

of Monitoring

(times/yr)

Subsequent 

Monitoring 

Fee ($/comp) 

or Charge 

(%)

Annual 

Monitoring 

Costs ($/yr)

Annual 

Maintenance 

Costs ($/yr)

Initial Leak 

Frequency 

(%)

Initial 

Number 

of Leaks

Subsequent 

Leak 

Frequency 

(%)

Annual 

Number 

of Leaks

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak

Repair Cost 

($/yr)

Valves-Baseline Monitoring (10,000 ppm) 66.24 $/hr, labor rate for repair

Valves (UU) * Gas/vapor service 0 0.00 0.00 2 1.50 0.00 0.34 0.00 0.34 0.00 75 0.17 66.24 0.00 

 * Light-liquid service 160 0.00 40.13 2 1.50 480.00 0.34 0.54 0.34 1.08 75 0.17 66.24 8.93 

 * Heavy-liquid service 0 0.00 0.00 0

0.00 Nat. fac0.00 Nat. Batch Annual Adminstrative and Repo 0 92.72 

1.00 Nat. Cont f - Assume 300 hr per fac

Initial Planning and Training 0 92.72 $0

 - Assume 340 hr per facTOTALS $40 $0 $480 $0 $9 

Capital Costs $40

Annualized Capital Costs $6

Annual Expenses $562

Annual Fixed Costs ($/yr) $6

Annual Variable Costs ($/yr) $562

$568

INCREMENTAL COSTS OF VALVES OPTION 1

Incremental Capital Costs ($) 537

Annualized Capital ($/yr) 76

Incremental Annual Expenses ($/yr) 42

119
ATTACHMENT 5

Model Costs for Equipment Leaks from Acrylic and Modacrylic Fibers Source Category

Type of Component Number of Components

Initial 

Monitoring Fee

or Unit Cost 

($/comp)

Initial 

Monitoring 

Costs ($/yr) 

(Capital)

Initial 

LDAR 

Admin. 

Costs

Frequency 

of Monitoring

(times/yr)

Subsequent 

Monitoring 

Fee ($/comp) 

or Charge 

(%)

Annual 

Monitoring 

Costs ($/yr)

Annual 

Maintenance 

Costs ($/yr)

Initial Leak 

Frequency 

(%)

Initial 

Number 

of Leaks

Subsequent 

Leak 

Frequency 

(%)

Annual 

Number 

of Leaks

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Connectors Option 1 (500 ppm) 66.24 $/hr, labor rate for repair

Connectors * Flanges - gas/vapor * Flanges - light liquid 650 23.80 15566.92 0.25 2.50 406.25 0.36 2.34 0.36 0.59 75 0.17 66.24 4.85 25  * Flanges -heavy liquid 1Annual Adminstrative and Repo 50 92.72 

Initial Planning and Training 20 92.72 $1,854

TOTALS $15,567 $1,854 $406 $0 $5 

INCREMENTAL COSTS OF CONNECTORS OPTION 1

Capital Costs $17,421

Annualized Capital Costs $2,474

Annual Expenses $5,066

Annual Fixed Costs ($/yr) $7,110

Annual Variable Costs ($/yr) $430

$7,540