vxEPA
           United States
           Environmental Protection
           Agency
           Office of Air Quality
           Planning and Standards
           Research Triangle Park NC 27711
EPA-450/3-82-011a
October 1982
           Air
Synthetic Fiber            Draft
Production Facilities —   EIS
Background Information
for Proposed Standards

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                         EPA-450/3-82-011a
      Synthetic Fiber
 Production  Facilities —
Background Information
for Proposed  Standards
    Emission Standards and Engineering Division
    U.S. ENVIRONMENTAL PROTECTION AGENCY
       Office of Air, Noise, and Radiation
    Office of Air Quality Planning and Standards
    Research Triangle Park, North Carolina 27711

            October 1982

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                                                 I
This report has been reviewed by the Emission Standards and Engineering Division of the Office of Air Quality Planning
and Standards, EPA, and approved for publication. Mention of trade names or commercial products is not intended to
constitute endorsement or recommendation for use. Copies of this report are available through the Library Services
Office(MD-35), U.S. Environmental Protection Agency, Research Triangle Park, N.C. 27711, or from National Technical
Information Services, 5285 Port Royal Road, Springfield, Virginia 22161.

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                    ENVIRONMENTAL PROTECTION AGENCY

                        Background Information
                               and Draft
                    Environmental Impact Statement
               for Synthetic Fiber Production Facilities
                             Prepared by:
Don R.  Goodwin I
Director, Emission Standards and Engineering Division
U.S.  Environmental Protection Agency
Research Triangle Park,.NC  27711
October 8, 1982

   (Date)
1.   The proposed standards of performance would limit emissions of
     volatile organic compounds from new, modified, and reconstructed
     synthetic fiber production facilities.  Section 111 of the Clean
     Air Act (42 U.S.C. 7411), as amended, directs the Adninistrator
     to establish standards of performance for any category of new
     stationary source of air pollution that ". . . causes or contributes
     significantly to air pollution which may reasonably be anticipated
     to endanger public health or welfare."  EPA Regions I, II, III,
     and IV are particularly affected, since most synthetic fiber
     production facilities are located in these regions.

2.   Copies of this document have been sent to the following Federal
     Departments: Labor, Health and Human Services, Defense, Transportation,
     Agriculture, Commerce, Interior, and Energy; the National Science
     Foundation; the Council on Environmental Quality; members of the
     State and Territorial Air Pollution Program Administrators; the
     Association of Local Air Pollution Control Officials; EPA Regional
     Administrators; and other interested parties.

3.   The comment period for review of this document is 60 days.
     Mr. Gene Smith may be contacted regarding the date of the comment
     period.

4.   For additional information contact:

     Mr. Gene Smith
     Standards Development Branch (MD-13)
     U.S. Environmental Protection Agency
     Research Triangle Park, NC  27711
     telephone: (919) 541-5578

4.   Copies of this document may be obtained from:

     U.S. EPA Library (MD-35)
     Research Triangle Park, NC  27711

     National Technical Information Service
     5285 Port Royal Road
     Springfield, VA  22161

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                           TABLE OF CONTENTS
SECTION                                                          PAGE
1.0  SUMMARY	     1-1
     1.1  Regulatory Alternatives  	     1-1,
     1.2  Environmental/Economic Impact  	     1-1
2.0  INTRODUCTION	     2-1
     2.1  Background and Authority for Standards ......     2-1
     2.2  Selection of Categories of Stationary Sources. .  .     2-4
     2.3  Procedure for Development of Standards of
          Performance	     2-6
     2.4  Consideration of Costs	     2-8
     2.5  Consideration of Environmental Impacts ......     2-9
     2.6  Impact on Existing Sources	     2-10
     2.7  Revision of Standards of Performance ........     2-11
3.0  INDUSTRY DESCRIPTION	     3-1
     3.1  General Information   	     3-1
     3.2  Manufacturing Process	     3-23
     3.3  Baseline Emissions 	     3-44
     3.4  References	     3-50
.4.0  EMISSION CONTROL TECHNIQUES	     4-1
     4.1  Introduction	     4-1
     4.2  Gas Absorption Equipment	     4-2
     4.3  Gas Adsorption Equipment	     4-9
     4.4  Condensation 	 .......     4-17
     4.5  Distillation	,  . .  .     4-18
     4.6  Enclosures	     4-21
     4.7  Incineration	     4-27
     4.8  Emission and Process  Testing  	     4-32
     4.9  Summary	     4-33
     4.10 References  	  .....     4-36
 5.0  MODIFICATION AND  RECONSTRUCTION	     5-1
     5.1  Background	     5-1
     5.2  40 CFR Part  60 Provisions for Modification  and
          Reconstruction	     5-1

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                     TABLE OF CONTENTS (Continued)
SECTION
PAGE
     5.3  Applicability to Synthetic Fiber Manufacturing
          Plants	I	     5-4
     5.4  References	\	     5-10
6.0  MODEL PLANTS AND REGULATORY!ALTERNATIVES  	    6-1
     6.1  Model Plants  . . . . L	    6-1
                                i
     6.2  Regulatory Alternatives	    6-6
     6.3  Acrylic Fiber Model Plants and Regulatory
          Alternatives  . . . . i	    6-14
     6.4  Cellulose Acetate Fiber  Model Plants and
          Regulatory Alternatives	    6-32
     6.5  References	;.	    6-44
7.0  ENVIRONMENTAL IMPACT . . . L	    7-1
     7.1  Introduction	    7-1
     7.2  Air Quality Impact  . (.	    7-1
     7.3  Water Quality Impact  :	    7-7
     7.4  Solid VJaste Impact  .	    7-8
     7.5  Energy Impact . . . . j	    7-10
     7.6  Other Environmental Impacts  .._....	    7-11
     7.7  Other Environmental Concerns   	    7-11
     7.8  References	!.	    7-15
8.0  COST ANALYSIS	    8-1
     8.1  Synthetic Fibers Cost Analysis of Regulatory
          Alternatives  . . . . j	    8-1
     8.2  New Facility Costs  . ,	    8-1
     8.3  Modified or Reconstructed Facilities  	    8-6
     8.4  Cost Effectiveness  . !	    8-15
     8.5  References	i	    8-22
9.0  ECONOMIC IMPACT	j.  . .	    9-1
     9.1  Industry Characterization 	    9-1
     9.2  Economic Impact Analysis  	    9-69
     9.3  Potential Socioecohomic  and  Inflationary  Impacts.  .    9-92
     9.4  References	    9-95
APPENDIX A - EVOLUTION OF PROPOSED STANDARDS   	    A-l
                                j
     A.I  Introduction  . . .	    A-3
     A. 2  Chronology	i	    A-4
APPENDIX B - INDEX TO ENVIRONMENTAL CONSIDERATIONS   .....    B-l

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                     TABLE OF CONTENTS (Concluded)
SECTION
PAGE
APPENDIX C - EMISSION MEASUREMENTS AND DETERMINATIONS ....    C-l
     C.I  Introduction	    C-3
     C.2  Direct Gas-Phase Measurements 	    C-3
     C.3  Calculation of VOC Emissions Indirectly by
          Material Balance  	    C-ll
     C.4  Baseline Emission and Emission Factors	    C-17
     C.5  Determination of Maximum Performance Test
          Variation 	 	 .....    C-19
     C.6  Testing of Solvent Vapor Concentrations
          within Recommended Enclosures 	 ....    C-24
APPENDIX D - EMISSION MEASUREMENT METHODS 	    D-l
     D.l  Emission Measurements Methods 	    D-3
     D.2  Monitoring Systems and Devices  . .	    D-5
     D.3  Performance Test Method	    D-5
APPENDIX E - METHODOLOGY FOR COMPUTING WEIGHTED AVERAGE
             COST OF CAPITAL FOR PRODUCERS OF ACRYLIC AND
             MODACRYLIC AND CELLULOSE ACETATE AND TRIACETATE
             FIBERS	    E-l
APPENDIX F - GLOSSARY	    F-l
                                    vn

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                            LIST OF TABLES
Table
Page
1-1  Matrix of Environmental, Energy, and Economic Impacts
     of Regulatory Alternatives .'...'	      1-3
3-1  Relative Production Percentages of Man-Made Fibers .  .      3-2
3-2  Synthetic Fiber Manufacturing Companies  	      3-3
3-3  Input Polymers for Melt Spinning	      3-14
3-4  Typical Input Materials for Dry Spinning	      3-17
3-5  Input Materials for Wet Spinning   	      3-20
3-6  Acrylic and Modacrylic Fiber Production Routes ....      3-28
3-7  General Parameters of Wet and Dry Spun Acrylic Fibers.      3-29
3-8  Typical Specialty Fibers .	      3-45
3-9  Baseline Emissions from Typical Synthetic Fiber
     5lants 	 .......... 	      3-46
3-10 OSfft Limits for Exposure to Solvents and Other
     Compounds Used in the Manufacture of Acrylic and
     Cellulose Acetate Fibers . . 	      3-49
4-1  Advantages and Disadvantages of Employing Condensation
     as a Control Technique .. .[ .............      4-19
4-2  Summary of Control Techniques  	      4-35
6-1  Baseline Model Plant Parameters  	      6-5
6-2  Emission Factors for Baseline end Control Options A
     and B	      6-12
6-3  Summary of Control Options and Regulatory
     Alternatives	;	      6-13
6-4  Acrylic Fiber Process Techniques 	      6-14
6-5  Parameters for Model Plant 1;	      6-16
6-6  Parameters for Model Plant 2<	      6-23
6-7  Parameters for Model Plant 3	      6-28
6-8  Parameters for Model Plant 4|	      6-34
                                 i
6-9  Parameters for Model Plant 5[	      6-40
                                 E
7-1  Projected 1987 VOC Emissions^ Under Regulatory
     Alternatives I (Baseline), II and III	      7-2
7-2  Energy Impact of Regulatory Alternatives in 1987 ...      7-13
                                  vm

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                      LIST OF TABLES (Continued)
Table                                                            Page
8-1  Baseline Costs	      8-3
8-2  Capital and Annual Operating Costs Associated with
     Model Plant Options	      8-4
8-3  Increases in Capital and Annual Operating Costs
     Associated with Each Regulatory Alternative   	      8-5
8-4  Component Capital Costs and Annualized Costs  for
     Model Plant 1, Alternative II and III	      8-7
8-5  Component Capital Costs and Annualized Costs
     for Model Plant 2, Alternative II and III. ......      8-8
8-6  Component Capital Costs and Annualized Costs
     for Model Plant 3, Alternative II and III	      8-9
8-7  Component Capital Costs and Annualized Costs
     for Model Plant 4, Alternative II and III	      8-10
8-8  Component Capital Costs and Annualized Costs
     for Model Plant 5, Alternative II and III	      8-11
8-9  Component Capital Cost Factors for Absorption/
     Adsorption Stripping as a Function of Equipment
     Costs	      8-12
8-10 Basis for Estimating Annualized Costs for Regulatory
     Alternatives	      8-14
8-11 Regulatory Alternative II Cost Effectiveness  Compared
     to Baseline Costs	      8-17
8-12 Regulatory Alternative III Cost Effectiveness Compared
     to Baseline Costs	      8-18
8-13 Comparison of Cost Effectiveness of Regulatory
     Alternatives II and III	      8-19
8-14 Projected 1987 Cost Effectiveness of Regultory
     Alternatives 	      8-21
9-1  U.S. Man-made Fiber Production 	      9-3
9-2  Value of Shipments by Fiber Type, 1977   	      9-4
9-3  Domestic Production of Acrylic and Modacrylic Staple,
     Tow, and Fiberfill (Excluding Waste) 	      9-10
9-4  Domestic Producers of Acrylonitrile, 1981	  .      9-12
9-5  Total Shipments of Acrylic and Modacrylic Staple
     and Tow	      9-16
9-6  Domestic Production of Acrylic and Modacrylic by
     Fiber Type	  .      9-17
9-7  Domestic Producers of Acrylic and Modacrylic  Staple
     and Tow and Capacity History	      9-19
9-8  End-Use Market of Acrylic and Modacrylic Staple and
     Tow by Capacity, 1975	      9-21
                                 ix

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                      LIST OF TABLES (Continued)
     Significance of Fiber Divisions to Domestically
     Owned Acrylic and Modacrylic Fiber Producing Firms.
9-10 Domestic Producers of Acrylic and Modacrylic Fibers
     Ranked by Capacity, 1975   J	'...'.
9-11 Production and Production Capac ty of Acrylic and
     Modacrylic Fibers, 1960-1980 	
9-12 Financial Data for Domestically Cwned Producers
     of Acrylic and Fiodacrylic Fiber, 1977-1979 . . .  .
9-13 Acrylic and Modacrylic Staple and Tow Shipments by
     Apparel End Uses	.'	
9-14 Acrylic and Modacrylic Staple and Tow Shipments by
     Home-Furnishings End Uses  .'	
9-15 Shipments of Acrylic and Modacrylic Staple and Tow
     by Industrial and Other Consumer End Uses  	
                                 !
9-16 Shipments of Acrylic and Modacrylic Fiber Waste by
     End Use	J	
9-17 Domestic Shipments of Acrylic and Modacrylic Fibers by
     End Use	J	
9-18 Total Shipments of Non-Cellililosic Staple and Tow . .  .
9-19 Acrylic and Modacrylic Fibeif Imports.	
9-20 Acrylic and Modacrylic Capacity Shortfalls over
     1982-1987	J	
9-21 Domestic Producers of Cellulose Acetate and Triacetate
     Fibers, 1980	\	
9-22 Domestic Production of Cellulose Acetate and
     Triacetate	*	
9-23 Production and Producing Capacity of Acetate and
     Triacetate Textile Fiber . . 	 .  .
9-24 Production of Cigarette Filtration Tow 	
9-25 Domestic Acetate and Triacetate Textile Fiber
     Production Capacity  	
9-26 Financial Data for Domestic Producers of
     Cellulose Acetate and Triacetate Fibers, 1977-1979 .
9-27 Significance of Fiber Divisions to Cellulose Acetate
     and Triacetate Fiber Producing Firms 	
9-28 Consumption by End-Use Market of Acetate Yarn  . . .
9-29 Acetate Yarn Shipments by Apparel End Uses 	
9-30 Acetate Yarn Shipments by Home-Furnishing and
     Industrial End Uses  ....  	
Page

9-23

9-25

9-26

9-27

9-29

9-30

9-31

9-31

9-33
9-35
9-37

9-45

9-49

9-50

9-52
9-52

9-54

9-55

9-55
9-57
9-58

9-59

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                      LIST OF TABLES (Continued)
Table                                                            Page
9-31 Exports of Cellulose Acetate Filtration Tow   	      9-61
9-32 Production and Shipments of Acetate Yarn	      9-62
9-33 Cellulose Acetate Yarn and Cigarette Filtration Tow
     Capacity Shortfalls over 1982-1987   	      9-70
9-34 Capital and Operating Costs for Three Model Acrylic
     Fiber Plants	,	      9-72
9-35 Discounted Plant Costs and Implicit Price for Model
     Acrylic and Modacrylic Fiber Plants  	      9-76
9-36 Time Trend for Inputs	      9-83
9-37 Capital and Operating Costs for Two Model
     Cellulose Acetate Fiber Plants    	      9-85
9-38 Discounted Plant Costs and Implicit Price for Model
     Cellulose Acetate Fiber Plants  	      9-87
C-l  Summary of Test Results from Facility A	      C-5
C-2  Summary of Test Results from Facility B	      C-8
C-3  Emissions as Determined from Solvent Use Data from
     Representative Plants	      C-12
C-4  Overall Nongaseous Losses	      C-13
C-5  Comparison of Solvent Inventory Variation with
     Total  Solvent Feed    	      C-14
C-6  Monthly Solvent Inventory Change  as Percentage
     of Solvent Makeup	      C-15
C-7  Solvent Inventory  Impact on Solvent Loss
     Determination	      C-18
C-8  Baseline  Emissions  	      C-20
C-9  Normal Emission Variability	      C-21
C-10 Normal Emission Variability	      C-22
C-ll Normal Emission Variability	      C-23

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                            LIST OF FIGURES
                                i
Figure                          ;                                 Page
3-1  Process Flow Diagram for Melt, Wet or Dry Spun
     Synthetic Fibers	      3-9
3-2  Extruder	      3-11
3-3  Spinning Unit Assembly with Spinneret	      3-12
3-4  Generalized Spinneret  .	      3-13
3-5  Dry Spinning Process Diagram .., .	      3-15
3-6  Dry Spinning Cell	      3-18
3-7  Wet Spinning Process Diagram	,.  .      3-21
3-8  Crimping System Diagram  .:	      3-24
3-9  Spandex Fiber Dry Spinning;	      3-42
4-1  Schematic Diagram of a Packed Tower	  .      4-4
4-2  Schematic Diagram of a Bubble-Cap Tray Tower 	      4-6
4-3  Carbon Adsorption Process  '•	      4-11
4_4  Carbon Adsorption Methods  '	  .      4-13
4-5  Spinning Machine with Enclosure.	      4-23
4-6  Sectional View of Direct-Flame Afterburner  	      4-29
4-7  Catalytic Incinerators Uti]itzing Heat Recovery   .  .  .      4-31
                                [
6-1  Generalized Flow Diagram for the Baseline Solvent
     Spinning Process	     6-3
6-2  Generalized Flow Diagram for the Solvent Spinning
     Process Under Control Option A  	  .      6-8
6-3  Generalized Flow Diagram for the Solvent Spinning
     Process Under Control Optipn B	      6-9.
6-4  Acrylic Fibers Wet Spinning Baseline Control,
     Model Plant 1	i	      6-15
6-5  Regulatory Alternative II  for Model Plant 1,
     Acrylic Fibers Wet Spinning	      6-18
6-6  Ducts and Enclosures for Acrylic Fibers Spinning  and
     Washing Steps	      6-19
6-7  Regulatory Alternative IIII for Model Plant  1,
     Acrylic Fibers Wet Spinning	      6-21
                                I
6-8  Acrylic Fibers Dry Spinning Baseline Control,
     Model Plant 2	      6-22
6-9  Regulatory Alternative II  for Model Plant 2,
     Acrylic Fibers Dry Spinning   	      6-24
                                  xn

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                      LIST OF FIGURES (Concluded)
Figure                                                           Page
6-10 Regulatory Alternative III for Model Plant 2,
     Acrylic Fibers Dry Spinning  	      6-26
6-11 Modacrylic/Acrylic Dry Spinning Baseline Control,
     Model Plant 3	      6-27
6-12 Regulatory Alternative II for Model Plant 3,
     Modacrylic/Acrylic Dry Spinning  	      6-30
6-13 Regulatory Alternative III for Model Plant 3,
     Modacrylic/Acrylic Dry Spinning  	      6-31
6-14 Cellulose Acetate Filtration Tow Dry Spinning Baseline
     Control, Model Plant 4 	      6-33
6-15 Regulatory Alternative II for Model Plant 4,
     Cellulose Acetate Filtration Tow 	 ....      6-36
6-16 Regulatory Alternative III for Model Plant 4,
     Cellulose Acetate Filtration Tow 	      6-38
6-17 Cellulose Acetate Filament Yarn Dry Spinning Baseline
     Control, Model Plant 5 	      6-39
6-18 Regulatory Alternatives II and III for Model Plant 5,
     Cellulose Acetate Filament Yarn  	      6-42
7-1  Energy Requirement for Adsorption-Solvent Recovery
     System	      7-12
7-2  Energy Requirements for a Typical Cross-Flow Packed
     Scrubber	      7-12
9-1  Market With a Supply Discontinuity	      9-80
9-2  Domestic Market for Cellulose Acetate Filtration Tow .      9-90
C-l  Solvent Inventory Impact on Solvent
     Loss Determination	      C-16
                                  xm

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                              1.0  SUMMARY

1.1  REGULATORY ALTERNATIVES
     Standards of performance  for new, modified, or reconstructed
affected facilities at solvent spun synthetic and semi synthetic fiber
manufacturing plants are being proposed under Section 111 of the Clean
Air Act.  The proposed standard would limit volatile organic compound
(VOC) emissions, the major air pollutant emitted from synthetic fiber
plants.
     The regulatory alternatives evaluated in this document would
reduce VOC emissions from affected facilities at synthetic and semi-
synthetic fiber production plants which use an organic solvent in
dissolving the polymer or in the precipitation bath.  This would
include such fiber types as acrylic, modacrylic, cellulose acetate,
and spandex.
     Three regulatory alternatives were considered:  Alternative I
would require no additional control  beyond baseline; Alternative II
would require a 31 to 55 percent reduction in VOC emissions by capturing
VOC emissions from the areas of highest concentration and/or the areas
most easily controlled; and Alternative III would require a 60 to
76 percent reduction by extending the capture techniques to additional
processing points and by capturing a larger portion of all fugitive
and stack emissions.  The demonstrated use of high .efficiency solvent
recovery systems at existing plants and the increasing value of the
recovered solvent suggest that improvement in recovery system efficiency
is the only reasonable alternative for VOC control.
1.2  ENVIRONMENTAL/ECONOMIC IMPACT
     Under Regulatory Alternative II, which suggests control  of VOC
emissions from those areas of greatest VOC concentrations, projected
1987 VOC emissions from new synthetic and semisynthetic fiber capacity
                                1-1

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would be reduced by as much as 5.6 gigagrams  (Gg).  This  is equivalent
to a reduction of VOC emissions of as much as 44  percent  when compared
to baseline (Regulatory Alternative  I) emissions  projected for  the
same year.
     If Regulatory Alternative III were  implemented,  1987 VOC emissions
would be reduced by up to 63 percent over projected baseline emissions.
                                !
VOC emissions in 1987 from new synthetic and  semisynthetic capacity
would be reduced by as much as 8.5 Gg.
     The fifth-year water pollution  and  solid waste impacts of  Regulatory
Alternatives  II and III each represent minimal  increases  over baseline
figures.  The control options are based  on the  use of carbon adsorbers
or absorption scrubbers to reduce VOC emissions.   Insignificant amounts
of water pollution and solid waste would be generated by  the control
equipment required, and nearly all captured VOC's would be reclaimed.
Therefore, both Alternatives II'and  III  would have little or no adverse
impact on water quality or solid waste.
     There would be only a minimal apparent increase  in energy  consumption
at a given plant as a result of !either Alternative II or  III.   A.
typical plant in the  industry would  increase  energy use by about 2  and
3 percent as  a result of implementing Alternatives II and III,  respectively.
     Capital  and operating costs for manufacture  of each  of  the fiber
types considered were developed and  analyzed.   Total  (fixed  plus
working)  capital costs of emission control equipment  required at model
plants analyzed range from $1.3 to $8.2  million for Regulatory
Alternative  II, and $3.0 to $10;4 million  for Regulatory  Alternative III.
Increases in  annual operating costs  for  additional emission  control
equipment at  these model pi ants!range  from $0.3 million  to $1.4 million
for Alternative  II, and  $0.6 to^$1.7 million  for  Alternative  III (see
page 8-5).  .                  ,!
     The  economic  effects  on the  industry  were projected  to  the fifth
year following  proposal, and reflect the most likely  circumstances.
The  total annualized  costs  to  the  entire industry would  be  as much  as
$7.4 million, but  this would be'offset  to  a  large extent  by  additional
solvent  recovery resulting  from; improved emission control.   The net
annualized  cost  in 1987  would  amount to $1.2  million  for  either Regulatory
Alternative  (see  pages 8-21  and:9-93).

                                 1-2

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     The complete economic impact analysis appears in Chapter 9.  A
summary of the economic impacts of the proposed emission limits is
also presented in Table 1-1.
             Table 1-1.  MATRIX OF ENVIRONMENTAL, ENERGY, AND
               ECONOMIC IMPACTS OF REGULATORY ALTERNATIVES
Administrative
Action
Alternative I
Alternative II
Alternative III
Air
Impact
0
+3**
+3**
Water
Impact
0
0
0
Solid
Waste
Impact
0
_!**
_;[**
Energy
Impact
0
_!**
_!**
Economic
Impact
0*
_!**
_!**
        KEY

   +  Beneficial Impact
   -  Adverse Impact

   0  No Impact
   1  Negligible Impact
   2  Smal1 Impact
   3  Moderate Impact
   4  Large Impact

   *  Short-Term Impact
  **  Long-Term Impact
 ***  Irreversible Impact
                                1-3

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                             2.  INTRODUCTION

2.1  BACKGROUND AND AUTHORITY FOR STANDARDS
     Before standards of performance are proposed as a Federal  regulation,
air pollution control methods available to the affected  industry and  the
associated costs of installing and maintaining the control equipment  are
examined in detail.  Various levels of control based on  different  technolo-
gies and degrees of efficiency are expressed as regulatory alternatives.
Each of these alternatives is studied by EPA as a prospective  basis for a
standard.  The alternatives are investigated in terms of  their impacts on
the economics and well-being of the industry, the impacts on the national
economy, and the impacts on the environment.  This document summarizes the
information obtained through these studies so that interested  persons will
be able to see the information considered by EPA in the  development of the
proposed standard.
     Standards of performance for new stationary sources  are established
under Section 111 of the Clean Air Act (42 U.S.C. 7411)  as amended, herein-
after referred to as the Act.  Section 111 directs the Administrator  to
establish standards of performance for any category of new stationary
source of air pollution which "... causes, or contributes significantly
to air pollution which may reasonably be anticipated to  endanger public
health or welfare."
     The Act requires that standards of performance for  stationary sources
reflect,"... the degree of emission reduction achievable  which (taking
into consideration the cost of achieving such emission reduction,  and any
nonair quality health and environmental impact and energy requirements) the
Administrator determines has been adequately demonstrated for  that category
of sources."  The standards apply only to stationary sources,  the  construc-
tion or modification of which commences after regulations are  proposed by
publication in the Federal Register.
                                  2-1

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     The 1977 amendments to the! Act altered or added numerous provisions
that apply to the process of establishing standards of performance.
     1.  EPA is required to list the categories of major stationary sources
that have not already been listbd and regulated under standards of perform-
ance.  Regulations must be promulgated for these new categories on the
following schedule:            i
     a.  25 percent of the listed categories by August 7, 1980.
     b.  75 percent of the listed categories by August 7, 1981.
     c.  100 percent of the listed categories by August 7,  1982.
A governor of a State may apply to the Administrator to add a category
                               i
not on the list or may apply to; the Administrator to have a standard  of
performance revised.
     2.  EPA is required to review the standards of performance every
four years and, if appropriate,! revise them.
                               I
     3.  EPA is authorized to promulgate a standard based on design,
equipment, work practice, or operational procedures' when a  standard based
on emission levels is not feasible.
     4.  The term "standards of performance" is redefined,  and a  new  term
"technological system of continuous emission reduction" is  defined.   The
new definitions clarify that the control system must be continuous and may
include a low- or non-polluting process or operation,
     5.  The time between the proposal and promulgation of  a standard under
Section 111 of the Act may be extended to six months.
     Standards of performance, by themselves, do not guarantee protection
of health or welfare because they are not designed to achieve any specific
air quality levels.  Rather, they are designed  to reflect the degree  of
emission limitation achievable through application of the best adequately
demonstrated technological system of continuous emission reduction, taking
into consideration the cost of ;achieving such emission reduction, any
nonair quality health and environmental impacts, and energy requirements.
     Congress had several reasons for including these requirements.   First,
standards with a degree of uniformity are needed to avoid situations  where
some States may attract industries by relaxing  standards relative to  other
States.  Second, stringent standards enhance the potential  for long-term
growth.  Third, stringent standards may help achieve long-term cost savings
                               12-2

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by avoiding the need for more retrofitting when pollution ceilings may

be reduced in the future.  Fourth, certain types of standards  for coal-

burning sources can adversely affect the coal market by driving  up the

price of low-sulfur coal or effectively excluding  certain coals  from  the

reserve base because their untreated pollution potentials are  high.   Con-

gress does not intend that new  source  performance  standards  contribute  to

these problems.  Fifth, the standard-setting  process should  create

incentives for improved technology.
     Promulgation of standards  of  performance does not  prevent State  or

local agencies from adopting more  stringent emission limitations for  the

same sources.  States are free  under Section  116 of the Act  to establish

even more  stringent emission limits than those established under Section  111

or those necessary to attain or maintain the  National Ambient  Air Quality

Standards  (NAAQS) under Section 110.   Thus, new  sources may  in some  cases

be subject to  limitations more  stringent than standards of performance

under Section  111, and  prospective owners  and operators of new sources

should  be  aware  of this  possibility  in planning  for  such  facilities.

     A  similar situation may arise when a  major  emitting  facility is  to be

constructed  in a geographic  area that  falls under  the  prevention of  signif-

icant deterioration of  air  quality provisions of Part  C of  the Act.   These
provisions require, among  other things, that  major emitting  facilities  to
be constructed in  such  areas are to  be subject to  best available control

technology.   The term Best  Available  Control  Technology (BACT), as defined

in the  Act,  means

      ...  an  emission  limitation based  on  the  maximum degree  of
      reduction of  each  pollutant subject  to  regulation under this Act
      emitted from,  or which results  from,  any major emitting facility,
      which the permitting  authority,  on a  case-by-case basis,  taking
      into account  energy,  environmental,  and  economic  impacts  and
      other costs,  determines  is achievable for such facility through
      application of  production processes  and  available methods, systems,
      and  techniques,  including fuel  cleaning  or treatment or innovative
      fuel  combustion  techniques for control  of each such  pollutant.
      In no event shall  application of "best available control  technol-
      ogy" result in  emissions  of any pollutants which  will  exceed the
      emissions allowed  by any  applicable standard established pursuant
      to Sections 111  or 112 of this Act.  (Section 169(3))
                                2-3

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     Although standards of performance are normally structured  in  terms of
numerical emission limits where: feasible, alternative approaches are  some-
times necessary.  In some cases physical measurement of emissions  from a
new source may be impractical ojr exorbitantly expensive.  Section  lll(h)
provides that the Administrator may promulgate a design or equipment  stand-
ard in those cases where it is  pot feasible to prescribe or enforce a
standard of performance.  For ekample, emissions of hydrocarbons from
storage vessels for petroleum liquids are greatest during tank  filling.
The nature of the emissions, high concentrations for short periods during
filling and low concentrations  for longer periods during storage,  and the
configuration of storage tanks  make direct emission measurement impractical.
Therefore, a more practical approach to standards of performance for  storage
vessels has been equipment specification.
     In addition, Section lll(j;) authorizes the Administrator to grant
waivers of compliance to permit' a source to use innovative continuous
emission control technology.  In order to grant the waiver, the Administra-
tor must find:  (1) a substantial likelihood that the technology will
produce greater emission reductions than the standards  require  or  an  equiva-
lent reduction at lower economic energy'or environmental cost;  (2) the
proposed system has not been adequately demonstrated; (3) the technology
will not cause or contribute to| an unreasonable risk to the public health,
welfare, or safety; (4) the governor of the State where the source is
located consents; and (5) the waiver will not prevent the attainment  or
maintenance of any ambient standard.  A waiver may have conditions attached
to assure the source will not prevent attainment of any NAAQS.   Any such
                                i
condition will have the force of a performance standard.  Finally, waivers
have definite end dates and may! be terminated earlier if the conditions are
not met or if the system fails  [to perform as expected.  In such a  case, the
source may be given up to three| years to meet the standards with a mandatory
                                I
progress schedule.              \
2.2  SELECTION OF CATEGORIES OFj STATIONARY SOURCES
     Section 111 of the Act directs the Adminstrator to list categories
of stationary sources.  The Administrator "... shall include a  category
of sources in such list if in his judgment it causes, or contributes
                               !2-4

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 significantly to,  air pollution which may .reasonably be anticipated to
 endanger  public  health or welfare."  Proposal  and promulgation of standards
 of  performance are to follow.                            '   '".
      Since  passage of the Clean Air Act of  1970, considerable attention
 has  been  given to  the development of a system  for assigning priorities
 to  various  source  categories.   The approach specifies areas of interest
 by  considering the broad  strategy of the Agency for implementing the
 Clean Air Act.   Often, these  "areas" are actually pollutants  emitted fay
 stationary  sources.   Source categories that emit these pollutants are
 evaluated and ranked  by a process involving such factors as:   (1) the
 level of  emission  control  (if  any) already  required by State  regulations,
 (2)  estimated levels  of control  that might  be  required from standards of
 performance  for  the source category, (3) projections of growth and
 replacement'of existing facilities for the  source category, and (4)  the
 estimated incremental  amount of air pollution  that could be prevented in
 a preselected future  year by standards of performance for the  source
 category.  Sources for which new source performance standards  were
 promulgated  or under  development during 1977,  or earlier,  were selected
 on these  criteria.
     The  Act  amendments of August 1977 establish specific  criteria to be
 used in determining priorities  for all  major source categories not yet
 listed by EPA.   These  are:  (1)  the quantity of air pollutant  emissions
 that each such category will emit,  or  will  be  designed  to  emit;  (2)  the
 extent to which  each  such  pollutant may reasonably be anticipated to
 endanger  public  health  or  welfare;"" and' (3)  the  mobility and competitive
 nature of each such category of  sources  and the consequent  need  for
 nationally applicable  new  source  standards  of  performance.
     The Administrator  is  to promulgate  standards  for these categories
 according to  the schedule  referred  to  earlier.
     In some  cases it may  not be  feasible immediately to develop  a standard
 for a source  category with a high  priority.   This  might  happen when  a
 program of research is needed to  develop control  techniques or because
 techniques for sampling and measuring  emissions  may  require refinement.  In
 the developing of standards, differences in the  time  required  to  complete
the necessary investigation for different source categories must  also  be
considered.    For example,   substantially more time  may be necessary if
                               2-5

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numerous pollutants must be investigated from a single  source  category.
Further» even late in the development process the schedule  for completion
of a standard may change.  For ;example, inability to obtain  emission  data
from well-controlled sources in time to pursue the development process  in  a
systematic fashion may force a change in scheduling.  Nevertheless, priority
ranking is, and will continue to be, used to establish  the  order  in which
projects are initiated and resources assigned.
     After the source category has been chosen, the types of facilities
within the source category to which the standard will apply  must  be deter-
mined.  A source category may have several  facilities that  cause  air
pollution, and emissions from some of these facilities  may  vary from
insignificant to very expensive to control.  Economic studies  of  the  source
category and of applicable control technology may show  that  air pollution
control is better served by applying standards to the more  severe pollution
sources.  For this reason, and because there is no adequately  demonstrated
system for controlling emissions from certain facilities, standards often
do not apply to all facilities iat a source.  For the same reasons, the  stan-
dards may not apply to all air ipollutants emitted.  Thus, although a  source
category may be selected to be covered by a standard of performance,  not
all pollutants or facilities within that source category may be covered
by the standards.
2.3  PROCEDURE FOR DEVELOPMENT ,OF STANDARDS OF PERFORMANCE
     Standards of performance must  (1) realistically reflect best
demonstrated control practice; 1(2) adequately consider  the  cost,  the  nonair
quality health and environmental impacts, and the energy requirements of
such control; (3) be applicable to existing sources that are modified or
reconstructed as well as new installations; and  (4) meet these conditions
for all variations of operating conditions  being considered  anywhere  in  the
country.                       '
     The objective of a program for developing standards is  to identify  the
best technological system of continuous emission reduction  that has been
adequately demonstrated.  The standard-setting process  involves three
principal phases of  activity:
the  information,  and  (3)  development  of the  standard  of performance.
(1)  information gathering, (2) analysis of
                                2-6

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     During the information-gathering phase, industries are queried
through a telephone survey, letters of inquiry, and plant visits  by  EPA
representatives.  Information is also gathered from many other  sources,
and a literature search is conducted.  From the knowledge acquired about
the industry, EPA selects certain plants at which emission tests  are con-
ducted to provide reliable data that characterize the pollutant emissions
from well-controlled existing facilities.
     In the second phase of a project, the information about the  industry
and the pollutants emitted is used in analytical studies.  Hypothetical
"model plants" are defined to provide a common basis for analysis.   The
model plant definitions, national pollutant emission data, and  existing
State regulations governing emissions from the source category  are then
used in establishing "regulatory alternatives."  These regulatory
alternatives are essentially different levels of emission control.
     EPA conducts studies to determine the impact of each regulatory
alternative on the economics of the industry and on the national  economy,
on the environment, and on energy consumption.  From several possibly
applicable alternatives, EPA selects the single most plausible  regulatory
alternative as the basis for a standard of performance for the  source
category under study.
     In the third phase of a project, the selected regulatory alternative
is translated into a standard of performance, which, in turn, is written in
the form of a Federal regulation.  The Federal regulation, when applied to
newly constructed plants, will limit emissions to the levels indicated in
the selected regulatory alternative.
     As early as is practical in each standard-setting project, EPA
representatives discuss the possibilities of a standard and the form it
might take with members of the National Air Pollution Control Techniques
Advisory Committee.  Industry representatives and other interested parties
also participate in these meetings.
     The information acquired in the project is summarized in the Background
Information Document (BID).  The BID, the standard, and a preamble explain-
ing the standard are widely circulated to the industry being considered for
control, environmental  groups, other government agencies, and offices
within EPA.  Through this extensive review process, the points  of view of
                               2-7

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 expert  reviewers  are taken into consideration as changes are made to the
 documentation.
     A  "proposal  package"  is assembled and sent through the offices of EPA
 Assistant  Administrators  for concurrence before the proposed standard is
 officially endorsed  by the EPA Administrator.  After being approved by the
 EPA Administrator, the preamble and the proposed regulation are published
 in the  Federal  Register.
     As  a  part  of the Federal  Register announcement of the proposed
 regulation,  the public is  invited  to participate in the standard-setting
 process.   EPA invites written  comments on the proposal and also holds a
                                 i
 public  hearing  to discuss  the  proposed standard with interested parties.
 All public comments  are summarized and incorporated into a second volume
 of the  BID.  All  information reviewed and generated in studies  in support
 of the  standard of performance iis  available to the public in a  "docket" on
 file in  Washington,  D.  C.      '  !
     Comments from the public  arje  evaluated,  and the standard of performance
may be  altered  in response to  the  comments.
     The significant comments  an|d  EPA's position on the issues  raised are
 included in  the "preamble" of  a ^'promulgation package," which also contains
 the draft  of the  final  regulation.   The regulation is  then subjected to
another  round of  review and  refinement until  it is approved by  the EPA
Administrator.  After the  Administrator signs the regulation, it is published
as a "final  rule" in  the Federal! Register.
2.4  CONSIDERATION OF COSTS      :
     Section 317  of  the Act  requires  an economic impact assessment with
respect  to any  standard of performance established under Section 111
of the Act.  The  assessment  is  required to  contain an  analysis  of:
 (1) the  costs of  compliance  with! the  regulation,  including the  extent to
which the  cost  of compliance varies  depending on the effective  date of
the regulation  and the  development  of less  expensive or more efficient
methods  of compliance;  (2) the  potential  inflationary  or recessionary
effects  of the  regulation;  (3)  the  effects  the  regulation  might have on
small  business  with  respect  to  competition;  (4)  the effects  of  the regulation
on consumer costs; and  (5) the  effects  of the regulation on  energy use.
Section  317 also  requires  that  the  economic impact assessment be as
extensive as practicable.
                               2-8

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      The  economic impact of a proposed standard upon an industry is usually
 addressed both  in absolute terms and in terms of the control costs that
 would be  incurred as  a result of compliance with typical, existing State
 control regulations.   An incremental approach is necessary because both new
 and  existing  plants would be required to comply with State regulations in
 the  absence of  a  Federal  standard of performance.   This approach requires a
 detailed  analysis of  the economic impact from the cost differential that
 would exist between a proposed standard of performance and the typical
 State standard.
      Air  pollutant emissions may cause water pollution problems, and captured
 potential  air pollutants  may pose a solid waste disposal  problem.   The
 total  environmental impact of an emission source must, therefore,  be analyzed
 and  the costs determined  whenever possible.
      A thorough study of  the profitability and price-setting mechanisms of
 the  industry  is essential  to the analysis so that  an accurate estimate of
 potential  adverse economic impacts  can be made for proposed standards.  It
 is also essential  to  know the capital  requirements for pollution control
 systems already placed  on plants so that the additional  capital  requirements
 necessitated  by these Federal  standards can  be placed in  proper  perspective.
 Finally,  it is necessary  to  assess  the availability of capital to  provide
 the  additional control  equipment needed to meet the standards of performance.
.2.5   CONSIDERATION OF .ENVIRONMENTAL IMPACTS
      Section  102(2)(C)  of the National  Environmental  Policy Act  (NEPA) of
 1969  requires Federal agencies  to prepare detailed environmental  impact
 statements on proposals for  legislation and  other  major  Federal  actions
 significantly affecting the  quality of  the human environment.  The  objective
 of NEPA is to build into  the  decisionmaking  process of Federal agencies a
 careful consideration of  all  environmental aspects  of proposed actions.
      In a number  of legal  challenges  to standards  of  performance for
 various industries, the United  States  Court  of Appeals for  the District
 of Columbia Circuit has held  that environmental  impact statements need
 not  be prepared by the Agency  for proposed actions  under Section 111 of
 the  Clean Air Act.  Essentially, the  Court of  Appeals  has determined that
 the  best system of emission  reduction  requires  the  Administrator to take
                               2-9

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 into account counter-productive environmental  effects of a proposed
 standard,  as well  as economic costs to the industry.   On this basis,
 therefore, the Court established a narrow exemption from NEPA for EPA
 determination under Section 111.
      In  addition  to these judibial  determinations, the Energy Supply and
 Environmental Coordination Act; (ESECA) of 1974 (PL-93-319) specifically
 exempted proposed  actions under the Clean Air  Act from NEPA requirements.
 According  to Section 7(c)(l), hNo action taken under  the Clean Air Act
 shall  be deemed a  major  Federal  action significantly  affecting the quality
 of  the human environment withih the meaning of the National  Environmental
 Policy Act of 1969." (15 U.S.C^  793(c)(l))
      Nevertheless,  the Agency has concluded that the  preparation of
 environmental  impact statements  could  have beneficial  effects on certain
 regulatory actions.   Consequently,  although not legally required to do so
 by  Section 102(2)(C) of  NEPA,  EPA has  adopted  a policy requiring that
 environmental  impact statements  be  prepared for various regulatory actions,
 including  standards  of performance  developed under Section 111 of the Act.
 This voluntary preparation  of environmental  impact statements, however,
 in  no  way  legally  subjects  the Agency  to NEPA  requirements.
     To  implement  this policy,ia separate section in  this  document is
 devoted  solely to  an analysis  of the potential  environmental  impacts associ-
 ated with  the  proposed standards.   Both  adverse and 'beneficial  impacts in
 such areas  as  air  and water pollution,  increased  solid waste  disposal, and
 increased  energy consumption  are discussed.
 2.6  IMPACT  ON EXISTING  SOURCES
     Section  111 of  the  Act defines  a  new source  as "... any  stationary
 source,  the  construction  or modification of which is  commenced ..."  after
 the proposed, standards are  published.  An  existing  source  is  redefined as a
 new source  if  "modified"  or "reconstructed" as  defined in  amendments to  the
 general  provisions of Subpart  /ji  of  40  CFR  Part  60,  which were promulgated
 in the Federal Register  on  December  16,  1975 (40  FR 58416).
     Promulgation of a standard  of  performance  requires States  to  establish
 standards of performance  for existing  sources in  the  same  industry under
 Section  lll(d) of the Act if the  standard  for new sources  limits  emissions
of a designated pollutant (i.ej,  a  pollutant for  which  air quality criteria
                               12-10

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have not been issued under Section 108 or which  has  not  been  listed  as  a
hazardous pollutant under Section 112).  If a  State  does  not  act,  EPA must
establish such standards.  General provisions  outlining  procedures for
control of existing sources under Section lll(d) were  promulgated  on
November 17, 1975, as Subpart B of 40 CFR Part 60  (40  FR  53340).
2.7  REVISION OF STANDARDS OF PERFORMANCE
     Congress was aware that the level of air  pollution  control achievable
by any industry may improve with technological advances.  Accordingly,
Section 111 of the Act provides that the Administrator "... shall, at
least every 4 years, review and, if appropriate, revise  ..."  the standards.
Revisions are made to assure that the standards  continue  to reflect  the
best systems that become available in the future.  Such  revisions will  not
be retroactive, but will apply to stationary sources constructed or  modified
after the proposal of the revised standards.
                               2-11

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                        3.0  INDUSTRY DESCRIPTION
3.1  GENERAL INFORMATION
     Man-made fibers include two types of products, the semi synthetics ,
or cellulosics (e.g., viscose rayon and cellulose acetate) and the true
synthetics or noncellulosics (e.g., polyester, nylon, acrylic and modacrylic,
spandex, and polyolefin).  These seven fiber types comprise over 99
percent of the total production of man-made fibers in the U.S.  Table 3-1
lists these fibers and gives the approximate relative-production percentage
of the. total man-made fibers market they held -in 1980.  Table 3-2 lists
the rnan-made fiber production facilities, plant locations, and fiber
types as of 1980.
     Semi synthetics are  formed when naturally occurring polymeric materials
such as cellulose are dissolved or dispersed into a suitable solvent,
and then spun into fine  filaments.  True synthetics result  from the
formation (polymerization) of long chain molecules from (usually) petroleum
derivatives.  The polymer is then dissolved or melted and spun into
fiber form.  Figure 3-1  gives a generalized schematic process diagram
for the  production of synthetic fibers.
3.1.1  Man-Made  Fiber Processing
     The major fiber spinning processes  are melt, dry, and  wet spinning.
Reaction spinning is also used but to  a  far lesser extent.  The spinning
process  used for a  particular polymer  depends on its melting  point, melt
stability,  and solubility in organic solvents.  A detailed  description
of each  of  these spinning processes  is given below, along with a description
of the most  significant  post-spinning  fiber treatment  processes.  Process
descriptions and diagrams for each individual fiber type  are  provided  in
Chapter  6.
     3.1.1.1  Viscose Rayon.  Rayon  fibers  are  defined  by the  Federal
Trade Commission as  "a manufactured  fiber composed  of  regenerated cellulose,
as well  as  manufactured  fibers  composed  of  regenerated  cellulose  in

                                   3-1

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                Taiile 3-1..  RELATIVE PRQQlinrrOl  PERCENTAGES
                            OF M-lffiDE FIBERS1"45
Semi syri t h etfcsz  CeTiTiUiliose Acetate and; Triacetate
                  Rayon:
Synthetics::       Pcrlyester
J..Q percent
                  Acr^lfc and MoctecryT f c
                 •Spandex;
                                                      ..  93..S percent
                                     3-2

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Table 3-2.  SYNTHETIC FIBER MANUFACTURING COMPANIES
                        (1980)
                                                   2,5

Company
ACS Industries
Allied Chemical
Alrac Corp.
Ameliotex, Inc.
American Cyanamid
American Enka
American Kynol, Inc.
American Hoechst
American Mfg. Co.
Amoco Fabrics Co.
(Subsid. Standard
Oil Co.)
Amtech, Inc.
Andray Products
Arlin Mfg. Co.
Armstrong Cork Co.
Avtex
Badische
Location
Woonsocket, RI
VJalthourville, GA
Hopewell, VA
Columbia, SC
Moncure, NC
Chesterfield, VA
Irmo, SC
West Conshohocken, PA
Stamdford, Conn.
Rocky Hill, NJ
Milton, FL
Painesville, OH
Lowland, TN
Enka, NC
Central , SC
Sanborn, NY
Spartanburg, SC
Delaware City, Del .
Honesdale, PA
Layfayette, LA
St. Louis, MO
Bainbridge, GA
Hazel hurst, GA
Nashville, GA
Odenton, MD
East Orange, NJ
Lowell, MA
Charlotte, NC
Front Royal , VA
Meadville, PA
Williamsburg, VA
Anderson, SC
Fibers Produced
PYO
PYO
N
P,N
P
N
N
N
N
S
A
P
R,N
N
P,N
NO
. P
P
PYO
PYO
PYO
PYO '
PYO
PYO
PYO, N, P
PYO
PYO
PYO
R,P
V,P
R,P
A
P,N
                             3-3

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   Table 3-2.  SYNTHETIC FIBER MANUFACTURING COMPANIES  (Continued)
Company
Location
                                                       Fibers Produced
Barnet Southern Corp.
Beaunit Corp.
Bernis Co. Inc.
Berkley & Co.
Camac Corp.
Carborundum Company
Carolina Eastman
   (Eastman Kodak)
Carter Moore  Process.
   Corp.
Celanese Fibers Co.
 Chadbourn,  Inc.
 Chadbourn  Indust.  Div.
 Chadol  Division
 Chase  Bag  Co.
 Chevron
  (Standard Oil)
 Chevron Chem.  Co.
   (Standard Oil)
 Columbia Rope Co.
   Cordage Group  Div.
 Concorde Fibers  Inc.
 Courtaulds, N.A.
 Crowe Rope Co.
   Div of A. Crowe
   & Sons, Inc.
Spartanburg, SC
Elizabethton, TN
Sti Louis, MO
Tajladega, AL
Spirit Lake, IA
Bnstol, VA
Niligra Falls, NY
Columbia, SC

Summervine, SC
Rock Hill, SC
Cumberland, MD
Narrows, VA
Summit, NO
 Galinesville,  GA
  i
 Orange,  CA
 New  Orleans,  LA
 Guayama,  PR

 Dayton,  TN

 Auburn,  NY

 Columbia, MD
 LeMoyne, AL
  I
 Warren,  ME
NonCellulosics
     P, N, PYO
     PYO
     PYO, N
     N, PYO
     NO
     P

Noncellulosics
     AC
     AC
     AC
     PBI
     N
     PYO
     PYO
     N
      PYO

      PYO

      PYO
      N
      PYO
                                     3-4

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  Table 3-2.  SYNTHETIC  FIBER MANUFACTURING  COMPANIES (Continued)
Company
Diversified Indust. Inc.
Synthetic Indust. Inc.,
Tennessee Fibers, Subs id

DuPont Corp.











E.8. Indus. Inc.
Exxon Corp.


Falk Fibers & Fabric

Fiber Indus. Inc.
(Celanese Co.)


FIBRON, Inc.
Fibrex (Sol vex Corp.)
Firestone
FNT Indus. Inc.
General Fiber &
Location

Subs id.
Chickamauga, GA
Pecatur, TN
Charleston, SC
Camden, SC
Waynesboro, VA
Cape Fear, NC
Old Hickory, TN
Richmond, VA
Martinsville, VA
Chattanooga, TN
Seaford, DE
Wilmington, NC
Kins ton, NC
Parkersburg, W VA
Simsbury, CN
Summerville, SC
Kingrnan, TX
Tracy, MN
Fuquay-Varina, NC
Yanceyville, NC
Greenville, SC
Shelby, NC
Florence, SC
Salisbury, NC
Chatanooga, TN
Humacao, PR
Hopewell, VA
Menoininee, MI
LaGrange, GA
Fibers Produced


PYO
PYO
P,N
A,N,P
A,N,P
P
P
AR,N,P
N,P
N,P
N,P
P,N
P,N
N
PYO,N,P
PYO
PYO

P
N
P
P
P
P
PYO
P
N,P
PYO
PYO
  Fabrics Corp.
Georgia Synthetics, Inc.
Elberton, GA
PYO
                                    3-5

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Table 3-2.  SYNTHETIC FIBER MANUFACTURING COMPANIES (Continued)

Company
Globe Mfg. Co.
Goodyear
Guilford Mills
Hanover Mills
Hercules, Inc.
Hoover & Allison Co.
International
Harvester Co.
Indian Head, Inc.
Kay ser- Roth Corp.
Keller Indus. Inc.
Lambeth Corp.
Lawrence Hose Co.
(subs. Consolidated
Foods Corp.)
Meyers Fibers, Inc.
Monofi laments, Inc.
Monsanto Fibers Co.
Moultrie Cotton
Mills, Inc.
Newton Filaments, Inc.
North American Rayon
NSI, Inc.
Location
i
Gastonia, NC
Fall River, MA
Scottsboro, AL
Point Pleasant, W VA
Gainesville, GA
Yanceyville, NC
Coving ton," VA
Oxford, GA
Xenia, OH
i
New Orleans, LA
Blue Mountain, AL
i
Creedmoor, NC
[
i
Swainsboro, GA
New Bedford, MA
Burlington, NC
Ansonville, SC
Waynesboro, VA
Decatur, AL
Sand Mountain, AL
Pensacola, FL
Greenwood, SC
Fayetteville, NC
. Moultrie, GA
Homer, NY
Elizabethton, TN
Soperton, Ga
. Fibers Produced
S
S
P
P
N
N
PYO
PYO
PYO
PYO
PYO
N
PYO
PYO
PYO
P
N,P,PYO
A,P,N
P,N
N
N
P,N
PYO
PYO
R
PYO
                                  3-6

-------
Table 3-2.  SYNTHETIC FIBER MANUFACTURING COMPANIES  (Continued)

Company'
Olvind Lorentzen
Osterneck Co.
Poncar Plastic Corp.
Phillips Fibers, Inc.


Plant Indus. , Inc.
PI atari 1 Co.
Rohm and Haas
Shakespeare Co.
Star Fibers, Inc.
v
Shuford Mills, Inc.
Sunburst Yarns, Inc.
Sunshine Cordage
Synthon Textile, Inc.
Tennessee Eastman
(Eastman Kodak)



Texfi Indus., Inc.



Thiokol Corp.
Tubbs Cordage

Location
Guilder! and Center, NY
Lumberton, NC
Miami, FL
Rocky Mount, NC
Spartanburg, SC
Guayama, PR
Houston, TX
Birdsboro, PA
Fayetteville, NC
Columbia, SC
Edgefield, SC

Hickory, NC
Afton, VA .
Miami, FL
Asheville, NC
Columbia, SC
Kingsport, TN



Asheboro, NC
New Bern, NC
Kins ton, NC
Liberty, NC
Waynesboro, VA
Reading, PA
Orange, PA
Fibers Produced
PYO
PYO
PYO
P
PYO
N,P
PYO
N
N.P
N,P
N

PYO
N
PYO
P
P
A,P
AC,P
N,P
PYO,P
P
P
P
P
PYO
PYO
PYO
  Uniroyal, Inc.
  Uniroyal Fiber & Textile Div. Winnsboro, SC
N,PYO
                                      3-7

-------
Table 3-2.  SYNTHETIC FIBER MANUFACTURING COMPANIES (Concluded)
I









A
AC
N
NO
V
Company
Vectra Corp.
(sub. Standard
Oil)
Volplex Corp.
Well Indus. Inc.
Waltn'ch Plastic
Wellington Tech.
Wellman, Inc.
Whitaker, Fred,
Yadtex, Inc.
s Acrylics R
= Acetate S
= Nylon P
- Novel oid PBI
= Vinyon PC
Location
i
Odenton, MD
Canandaigua, NY
Beverly, NO
Tennent, NJ
Ind. Pilot Mountain, NC
Leesville, SC
Summerville, SC
Trussville, AL
Johnsonville, SC
Co. Ra,leigh, NC
i
Mount Airy, NC
i
= Rayon iAR = Aramid
= Spandex PYO = Polyolefin
= Polyester >
= Polybenzimidazole
= Polycarbonate
Fibers Produced
PYO
V,PYO
PYO
PYO
PYO
PYO
PYO
PYO
N,P
P
P
                                      3-8

-------

-------
which substituents have replaced not more than 15 percent of the hydrogens
of the hydroxyl groups."  A number of important variables in the viscose
process can be manipulated to cjbtain fibers of substantially different
characteristics.  Broadly categorized, the rayon fiber types include
regular (conventional) rayon, modified high tenacity rayon, high-wet-modulus
rayon, and polymosic rayon.  Rayon fibers are made from chemical cellulose
(dissolved wood pulp), sodium hydroxide, carbon disulfide, and sulfuric
acid.  Essentially, the series jof chemical reactions by which viscose is
made consist of the following stages:  (1) Wood cellulose and concentrated
caustic soda react to form soda cellulose.  (2) The soda cellulose
reacts with carbon disulfide to form sodium cellulose xanthante.  (3) The
                               i
sodium cellulose xanthate is dissolved in dilute caustic soda to give a
viscose solution.  (4) The solution is ripened.  (5) It is extruded into
sulfuric acid which regenerates the cellulose, now in the form of long
filaments  (viscose rayon).
     3.1.1.2  Melt Spinning.  Melt spinning uses heat to melt the polymer
to a viscosity  suitable for extrusion into filaments, which are then
cooled with air to solidify the filaments.  Resins used in this process
must be stable at high temperatures to prevent decomposition.  Nylon 6
and 66, polyester, and polyolefin polymer chips are all melt spun.
     The polymer chips can be melted by numerous methods.  The trend is
towards melting and immediate extrusion of the polymer chips in an
electrically heated screw extruder  (See Figure 3-2).  Alternately, the
molten polymer  is  processed in!an inert gas atmosphere, usually nitrogen,
and is metered  through a  precisely machined gear pump to a filter assembly
consisting of  a series of metal gauzes interspersed in layers of graded
sand  (See  Figure 3-3).  The filtered molten polymer is then extruded at
a  constant rate, at high  pressure, through a  (typically) nickel or
stainless  steel spinneret  (see'Figure 3-4).   The extruded liquid polymer
filaments  are  cooled  using an air stream; the solid filaments formed
converge at a  guide to  produce a  "spun yarn"  or  "filament yarn."  Some
filaments  are  conditioned  before  converging  (such  as  steam conditioning
for  nylon  66).
      After converging, the  fiber  is  further treated,  depending  on the
desired fiber  characteristics.; Treatments include drawing,  lubrication,
crimping,  heat-setting, winding,  cutting  and/or  twisting.

                               !     3-10

-------
Section through an extruder
1  Housing wall
2  Screw
3  Filling hopper
4  Heating elements
               Figure  3-2. Extruder
                      3-11

-------
        1
1
   Spinning unit assembly with spinneret
   1  Base         '
   2  Spinneret     :          6  Sand container
   3  Perforated plate         7  Screw connection
   4  Supporting sieve         8  Sand filter
   5  Sieve round             9  Seals
Figure 3-3.  Spinning[Unit Assembly With Spinneret
                     3-12

-------
SPINNING SOLUTION
OR DOPE
   FIBERS
   Figure 3-4.   Generalized Spinneret
            3-13

-------
     Input materials (polymers), fibers, and their generic type are'
listed in Table 3-3 for several representative melt-spun fiber types.
     Since melt spinning does not require that the fiber polymer be
dissolved in a solvent, but instead be melted prior to extrusion, melt
spinning emission rates are considerably slower than those of dry and
                               i
wet spun fiber processes.  Due |to the lower volume of volatile organic
                               I
compounds (VOC) from the melt spinning of synthetic fibers and because
VOC's are the most significant air pollutant emitted from these plants,
an NSPS for this method of fiber production is not presently being
developed.
     3.1.1.3  Dry Spinning.  Dry spinning involves the use of a solvent
to dissolve the polymer chips, j The polymer solution is extruded into a
zone of heated gas or vapor; the solvent evaporates leaving a solidified
filament that is further processed.  Figure 3-5 presents a flow diagram
for a typical dry spinning process.  This process is used for easily
dissolved polymers such as cellulose acetate, acrylics, and modacrylics.
Higher spinning speeds are possible in dry spinning, and this process is
generally used to produce continuous filament yarns.
            Table 3-3.  INPUT POLYMERS FOR MELT SPINNING
                                                        6,8
      Fiber Type
   Input Polymer
      Nylon
      Nylon
      Nylon
      Polyester
      Polyester
      Olefin
      (polypropylene)
      Olefin
      (polyethylene)
iPolyhexamethylene adipamide
jPolycaprolactam
iPolyhexamethylene sebacamide
[Polyethylene terephthalate
[Poly  1,4 dimethyl dicyclohexyl
jterephthalate  or  polyethylene
terephthalate
i
iPolypropylene

'Polyethylene
                                   3-14

-------
                                                          fC
                                                          &.
                                                          en
                                                          
-------
     After leaving  the  spinneret,  the  polymer solution passes  through a
spinning cell which consists  of 
-------
          Table 3-4.  TYPICAL INPUT MATERIALS FOR DRY SPINNING
                                                              6,8
      Fiber
       Polymer
       Solvent
Acrylic


Modacrylic


Cellulose Acetate

Spandex

Vinyon
 Polyacrylonitrile


 Polyacrylonitrile/
 Polyvinyl  Chloride

 Cellulose  Acetate

. Polyurethane

 Polyvinyl  Chloride/
 Polyvinyl  Acetate
DM F, DM Ac
Tetramethylene Sulfone

Acetone
Acetone

DMF
                                                 Acetone,
                                                 Methyl Ethyl Ketone
                                    3-17

-------
Schematic dry spinning plant
 1  Spinning tank
 2  Cooling water supply
 3  Spinning head
 4  Gear spinning pump   '
 5  Annular spinneret     |
 6  Carrier gas
 7  Gas heater           ',
 8  Spinning shaft        i
 9  Shaft shell           [
10  Solvent recovery      '
11  Orifice              [
12  Finish application rolls
13  Haul-off rolls
14  Can coiling           !
       Figure  3-6.   Dry  Spinning Cell
                        13-18

-------
discussed in detail in subsequent sections of Chapter  3.  The  spinning
solution is extruded through spinnerets  into a  precipitation bath.
Precipitation or coagulation ensues by diffusion  of  the  solvent  out  of
the thread into the precipitation bath and by diffusion  of  the precipitant
into the thread.  Between the processes  employed,  there  is  a wide  variation
in the percentage composition of. the coagulation  or  precipitation  baths
and in the temperatures applied.  Wet spun filaments will undergo  a
variety of additional processing steps depending  on  the  end use.
     Equipment required for wet spinning includes  a  solution vessel, a
metering pump, a filter, a spinneret, and a coagulant  tank. Holding
tanks are employed  if the products  require "aging" of  the polymer  before
spinning.  All processes include a  recovery system to  separate the
coagulant and solvent.  Table 3-5 lists  the fiber types, polymers,
solvents, and coagulants used in wet spinning.   Figure 3-7  presents  a
process flow diagram for a typical  wet spinning process.
     Filaments extruded from the spinneret are  further processed in  a
variety of methods  depending on the end  use desired.  A washing  step
immediately after  extrusion  is commonly  employed  to  remove  solvent and
other impurities.   This washing step can occur  either  continuously or in
batches.
     The  important  variables affecting fiber  properties in  wet spinning
are concentration  and temperature of the polymer  solution (dope) and the
composition and  characteristics of  the spin-bath.
     Air  pollutant  emission  points  in wet spinning processes  that use
organic solvents  are similar to those of dry  spinning, with the  solvent
losses  being generally  less  than  in dry  spinning. Wet spinning  processes
employing  solutions of  acids or salts emit only small  quantities of
unreacted  monomer,  and  are  therefore  relatively clean  from  an  air pollution
standpoint.-
      3.1.1.5   Reaction  Spinning.  This  process  may resemble wet  or dry
spinning,  but  always  involves  a continuous chemical  reaction  within the
fiber after extrusion which  extends the  polymer chain  length  or provides
cross-linking  between chains.
      This method of fiber  formation is  similar to that utilized  in
nature  (i.e.,  silk worms,  spiders), and  is basically the extrusion of a
                                    3-19

-------
                   Table 3-5.  INPUT MATERIALS FOR WET SPINNING6'8'9
  Fiber
    Polymer
   Solvent
    Coagulant
Aery!ic
Polyacry 1 on 1 tr i 1 e
Modacrylic
Rayon
Po.lyacrylonitrile-
polyvinyl chloride
copolymer
Cellulose
Dimethylacetamide
(DMAc)

Concentrated
Aqueous ZnClg

Aqueous NaSCN
Acetonitrile
DMAc

Acetone

Aqueous
Sodium Hydroxide.
Aqueous DMAc
                                                              Dilute
                                                              Aqueous

                                                              Aqueous NaSCN
Aqueous Acetonitrile
Aqueous DMAc

Water

Dilute
Sulfuric Acid
                                        3-20

-------
                                 §
                                               res

                                               CD
                                                O)
                                                o
                                                e
                                               Q-
                                                cn
                                                c:
                                               •r-*
                                                O-
                                                O!
                                                i
                                               CO
                                                CD
3-21

-------
pre-polymer (partially polymerized mixture), in which the chemical .
reaction (polymerization) proceeds to form the final solid polymeric
fiber after the spinning of the fiber.
     Reaction spinning is not used in production of the major commodity
fibers, and its use in productibn of the specialty fibers is limited.
     3.1.1.6  Post-Spinning Fiber Treatment Processes.
     3.1.1.6.1  Lubrication.  Surface lubrication, plasticizing, and
static protection are the three;major functions of lubrication.  Sub-
sequent handling and processing; is improved when the lubricant is added
immediately after filament formation.
     For melt spun and dry spun! yarns, the lubricant is applied before
winding onto a spin bobbin.  Inj staple finishing it may be applied by
passing through a bath or by spjraying.  The lubricant is usually added
after the washing step in the case of wet spun fibers.  Most applica-
tions of the lubricant occur at- the spinning stage, by contacting the
filament immediately after spinning with the lubricant on a ceramic
wheel.
     Typical antistatic lubricants are polyoxyethylene attached to
aliphatic hydrocarbon chains, Ipng-chain alky! quarternary ammonium
salts, hydroxyalkylamine salts of long chain fatty acids, high boiling
aliphatic esters, hydrocarbon o|ils, and fluid silicones.  The lubricant
is applied as a solution or emulsion in water.  Both the composition of
                               i
the lubricant and the amount applied to the fiber depend on the chemical
composition of the fiber and the end use.  These lubricants are not
liberated in significant amounts in the fiber production process and do
not pose an air pollution problem.
     3.1.1.6.2  Drawing.  Most of the fibers undergo drawing.  Drawing,
or the stretching of yarn, introduces molecular orientation to the spun
fiber and thus produces a stronger fiber.  Optimum draw ratios exist for
each type of fiber.  Drawing of fibers is accomplished by stretching
them between two or more rollers:  one feeds the undrawn yarn and the
next roller, rotating at a greater speed, collects and feeds the drawn
yarn to another roller or to subsequent processing.  The ratio of the
surface speeds of the feed and draw rollers is defined as the draw
ratio.
                                    3-22

-------
      3.1.1.6.3   Fiber modifications.   Finally,  the fibers  may undergo
 some  fonn of  physical modification  to  produce a specified,  marketable
 product.  Modifications  include  false-twist  texturing  to produce inter-
 filament cohesion,  heat  setting  or  heat  relaxation to  produce dimensional
 stability, crimping to add  bulk  and resilience, and cutting to produce
 staple  products  similar  to  natural  fibers.   Figure 3-8 presents  a  diagram
 of a  crimping system.
 3.1.2   Production
      Projected growth rates and  a detailed description of  economic
 conditions in the synthetic fibers  industry  can be found in Section  9.1.
 3.1.3   Location
     Nearly all  of  the man-made  fiber  production  facilities are  located
 in eight states: Virginia, West  Virginia, North Carolina,  South  Carolina,
 Georgia, Tennessee, Alabama, and Florida.  Plant  locations,  and  the  type
 of fiber produced can be found in the  subsequent  sections  dealing  with
 each  individual  fiber type.
 3.2  MANUFACTURING  PROCESSES
      The synthetic  fibers manufacturing  industry  can generally be
 characterized as having a stable commodity fiber-producing  portion and  a
 relatively dynamic  specialty fiber-producing portion,  into  which new
 fiber types and  production methods  are frequently  being  introduced.
 Still other solvent-spun fiber types are being  produced  at  bench and
 pilot-scale levels and may or nay not expand to  full production   '
 (e.g.,  solvent-spun rayon).  In addition, many  solvent-spun  fiber  types
 are produced in other countries that are not currently  produced  in the
    2
 U.S.   Clearly, therefore, it would be inappropriate for purposes  of
 this study to describe each one of  the almost infinite  varieties of
 fiber types and associated production methods employed within  the  fibers
 industry.  Rather, there are several basic solvent-spun  synthetic  fiber
 processes that can be identified and described  that adequately represent
most segments of the industry.
     All fiber spinning processes share certain fundamental characteristics,
Basically,  the object is to extrude a liquid or semi-solid  polymer with
a desired cross section, solidify it, then collect  it  in a  bale  or wind
 it on some type spool  or bobbin.   In most processes the  solid  fiber is
                                   3-23

-------
Diagram of a stu.ffar-box crimping system
1  Rollers for introducing the tow
2  Stuff er box
3  Tempering (only with certain types)
4  Tow              !
       Figure 3-8.  Crimping System Diagram
                        3-24

-------
subjected to further processing to enhance  its mechanical  properties;  in
others, the fiber is taken up essentially as  a finished  product.   Those
broadly identifiable process stages which are common  to  all  solvent-spun
synthetic fiber processes include: (1)  preparation  of the  spinning
solution.  In this stage, polymer is dissolved in an  organic solvent,
and the solution is blended with additives  and filtered  to complete  the
preparation of the dope for spinning.   (2)  Spinning of the fiber,  that
is, the actual formation of the fiber filaments.  Polymer  solution (or
dope) is forced or extruded through a device  called a spinneret  to
create the fiber.  (3) Processing of the formed fibers.  This might
include lubrication, washing, drying, heat  setting, finishing, or  crimping.
(4) Solvent recovery.  Because of the large amount  of solvent used (a
pound of polymer is typically dissolved in  2  to 3 pounds of  solvent),
the economics of the industry require that  almost all  of the solvent
used in dissolving be recovered for reuse.  Typically, solvent is  recovered
most efficiently and economically at the spinning step from  the  spin-cells
or spin baths into which polymer solutions  are extruded.  .About  94 to
97 percent of the solvent used is recycled  directly from the spinning
step alone.  Thus, a primary solvent recovery system  is  an integral  part
of all  solvent spinning processes.
     In addition to the above stages of synthetic fiber  production,  this
chapter will  be limited to the production processes that involve the
spinning (or forming) of the fiber from a solution  of polymer or pre-
polymer and organic solvent(s).  There are  a  number of fiber types that
employ organic solvents in their production;  these  include acrylic,
cellulose acetate, modacrylic, polybenzimizole, spandex, triacetate,
vinyon, etc.   There are basic similarities  in the production sequences
for all these fiber types.   Three fiber types .have been selected for
detailed process descriptions, since these  types exhibit typical and
characteristic production sequences.   Acrylic and modacrylic fibers
include all fibers consisting of at least 35  percent  polymerized
acrylonitrile.  Cellulose acetate fibers include all  cellulosic fibers
with an acetylation of 15 percent or greater  (includes triacetate).
Spandex fibers include all  dry and reaction-spun spandex fibers  in which
the fiber forming substance is a long chain synthetic  polymer comprised
of at least 85 percent of a segmented polyurethane.

                                   3-25

-------
3.2.1  Process Descriptions - Acrylic and Modacrylic Fiber Production
     Acrylic fibers are based on the polymerization of acrylonitrile
(AN).  The monomer AN is derived from propylene and ammonia.  Polyacrylo-
nitrile is produced by the synthetic fibers industry with two methods:
suspension polymerization and solution polymerization.  The polymers
formed are generally atactic and have an average molecular weight of
100,000 to 150,000.            :
                                  c o
     3.2.1.1  Forming the Polymer.
     3.2.1.1.1  Suspension polymerization.  The suspension polymerization
process is accomplished by suspending small drops of acrylonitrile and
comonomers in water using violent agitation and a stabilizer which
prevents coalescence of the monomer drops.  Polymerization occurs in the
presence of a catalyst that is isoluble in the monomer.  Typically, the
reaction is carried out to about 65 to 85 percent completion.   Insoluble
beads of polymer are formed that are subsequently filtered, washed,
refiltered, dried, milled, andjstored as powder.  Monomers are  recovered
from the filtration and washing steps and recycled to the polymerization
reactors.                      i
     3.2.1.1.2  Solution polymerization.  A mixture of about 96 percent
acrylonitrile and 4 percent methyl acrylate is blended with dimethylforma-
midea catalysts, and activators; it  is then fed into a reactor  over a
10- to 20-hour period.  The polymerization temperature is maintained at
a constant level by means of circulating fluids in the vessel jacket.
     Following the polymerization, the reactor effluent is passed to a
diluter for mixing with dimethylformamide containing a small percentage
of water.  The diluted stream  is pumped to a horizontal film evaporator
operating at reduced pressures.  The residual monomer and a portion of
the dimethylformamide are stripped from the polymer stream.  Pure dimethyl-
formamide is added to the polyacrylonitrile solution leaving the evaporator.
The resulting solution generally contains less than 1 percent residual
AN monomer.
     The solution polymerization method offers the advantage that the
polyacrylonitrile can be used  directly in the spinning process  without
the need of drying and redissolving  the polymer.
                                    3-26

-------
     Either batch or continuous reaction modes may be employed,  and
either wet or dry spinning may be used to form the fibers.   Polyacry-
lonitrile may be spun only from solutions and a variety of spinning
solvents are used by industry.  Table 3-6 indicates the various  methods
used domestically to produce acrylic and modacrylic fibers.  Additional
parameters for wet and dry spinning acrylic fibers can be found  in
Table 3-7.                                                     ~
     3.2.1.2  Domestic Acrylic Fiber Manufacturing Processes.
     3.2.1.2.1  Producer A.  Polyacrylonitrile is fed to a polymer
purification system where it is washed to remove any remaining free
monomers or.catalyst residuals.  The purified polymer is subsequently
dissolved in a solution of NaSCN.  This results in a single  phase,
3-component system of sodium thiocyanate, water, and polyacrylonitrile.
     The resulting solution is blended and stored.  It is then put
through a primary filtration operation to remove any suspended solids,
and is then sent to a deaeration area.  Various additives are  incorporated
into the mixture to give the fiber product certain desired qualities.
     At the spinning stage, dope is extruded into a dilute aqueous NaSCN
solution.  A washing step removes all traces of solvent from the fiber.
The water that is utilized in extrusion, prestretching., and  washing'
steps is routed to a solvent recovery system after it leaves the spin
bath.
     Following the washing step, the fiber bundle is drawn on  rollers  to
provide molecular orientation and to impart strength to the  fibers,  and
is then dried.  A subsequent relaxing operation is employed  which allows
controlled disorientation of the fiber molecules to enhance  dyeability.
In the subsequent finishing and tempering stage, a lubricant and antistatic
agent is added.  A crimp is added to the fibers to give them bulk.   The
dried product is boxed or baled for storage and shipment.
     The solvent recovery system at this company employs multiple effect
evaporators to remove the water and concentrate the NaSCN solution
exiting the washing stage.  After evaporation of the water in  the recovery
unit, the concentrated NaSCN solution is returned to the dissolving
step.  The wastewater from the recovery system is routed to  a  wastewater
treatment area where it is treated and disposed of by one of two methods:
                                    3-27

-------
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                                                                                       3-28

-------
     Table 3-7.   GENERAL PARAMETERS OF WET AND DRY SPUN ACRYLIC
                                FIBERS5'7
                                    Wet Spinning
                     Dry Spinning
Percent polymer in dope
Pressure across dope
 filters and spinning
 branches
Number of spinneret holes
Haul-off speeds
Draw ratio
20-25

7-12 bars
3000-60000
5-20 m/min
1.2 to 1.6
25-35

10-15 bars
300-2000
250-500 m/min
Variable
depending on
spin gas
temperatures,
gas flow rate,
and haul-off
speeds
                                    3-29

-------
(a) a deep well disposal system, or (b) a biological treatment center.
Biologically treated waters are disposed of by spray irrigation or are
discharged to surface waters.
     3.2.1.2.2  Producer B.  This acrylic manufacturing facility  is
comprised of two separate plantsj with basically similar processing
steps.  One plant produces polyacrylonitrile homopolymer.  The second
plant copolymerizes acrylonitrile (AN) and other monomers to produce
products with characteristics suited to various end uses.  Both plants
employ solution polymerization.  Polymerization is followed by a  vacuum
removal step which facilitates recovery of unreacted monomer and  thereby
reduces acry.lonitrile emissions that occur during the spinning operations.
     In the spinning process, po|lymer is dissolved in an aqueous  solution
of zinc chloride, and is extrudecl into a coagulation bath containing a
dilute zinc chloride/water solution.  The coagulated polyacrylonitrile
fibers are then washed thoroughly with water in a counter-current bath
                                i
to remove zinc chloride and other residuals, including monomer.   A
substantial portion of the unreacted monomer returns with the wash water
to be recovered during solvent purification.  Monomer loss during spinning
and washing, however, is reported to be the major source of process
                            Q
emissions to the atmosphere.    !
     Washing is followed by stretching, drying, crimping, cutting, and
baling of the fibers.  Selected (products are also dyed on-line
continuously.
     Unreacted monomer is carried over from the polymerization reactor;
a portion of this monomer is removed by vacuum stripping of the polymer
prior to storage.   It is estimated that this vacuum flash step following
polymerization releases a majority of the unreacted AN for recovery.
The remaining monomer is released from the polymer  in the spinning and
washing stages.  The majority of the unreacted AN, however, is absorbed
in the dilute solvent used in the spinning and washing steps; the remaining
residual monomer is volatilized and is emitted to the atmosphere.
The major source of emissions to the atmosphere during acrylic fiber
production at this plant is volatilization of residual unreacted  monomer
during the spinning and washing [operations.  Testing by  the company has
shown that no residual monomer remains in the fiber product.   It  can
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therefore be concluded that all residual monomer  is  released  in  the
spinning, washing, and drying stages.   It is believed that  all monomer
release occurs during spinning and washing of the fibers  and  that  the
stretching and drying steps account for only insignificant  amounts of
          i     8
monomer release.                                                     .;
     There are no direct or add-on emission control  systems for  reduction
of AN emissions applied to the plant spinning facilities.   Recovery  of  a
portion of the unreacted AN present in  the spinning  solution  by  pro-
cessing wet-spinning and fiber washing  solutions serves as  an  indirect
control method.
     The spin bath and fiber handling equipment are  partially  enclosed
in order to increase the air flow rate  (e.g., venturi effect)  across the
polymer arid to reduce AN levels in the  spinning room.  Room air  is
removed from above the enclosure, and the collected  gases are  routed to
an outlet stack.  The partially enclosed spinning area also serves as a
means to maintain AN levels below the OSHA limits.
     3.2.1.2.3  Producer C.  Polyacrylonitrile is formed  by suspension
polymerization from acrylonitrile.  The polymer is filtered, and the
resulting slurry is blended and stored.  The blended polymer  is  extruded
in the form of noodles, dried in a hot air dryer and stored.   Dtmethyl-
formamide is subsequently mixed with the pulverized  polymer powder and
sent to a large blending tank.
     At the mixing stage pulverized polymer falls into a mixer.  DMF is
sprayed onto the pulverized polymer.  After being thoroughly mixed, the
resulting solution of polymer in DMF falls into a blending tank  or
storage vessel where the solution is agitated.  The  spinning dope is
pumped through a heat exchanger which heats the polymer solution.  The
heated solution is filtered through plate and frame  filter presses.
These filters are hooded to reduce worker exposure to DMF during the
time when the filter media is being changed.   The used filter media
(cellulose) is placed in bins and is repeatedly leached with water.  The
water used for leaching is sent to the weak feed line of the DMF recovery
system.
     The spinning solution is then pumped through spinnerets (containing
several hundred holes) using a metering device.   The head of the spinnerets
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is kept hot by a steam jacket.  Hot nitrogen gas  enters  at  the  top  of
the spinning cell and moves cocurrently with the  emerging filaments.
                               i
The DMF is volatilized or extracted by the nitrogen  gas  from  the  emerging
filaments as they travel down the length of the spinning cell.  Water  is
applied to the fiber at two points, and the water run-off is  drained and
processed for recovery of DMF. \ A set of rolls pulls  the fiber  away from
the spinning cells.  Fiber from multiple spinning positions converge to
form a single rope or tow which is piddled (deposited)  into cans  for
temporary storage.  Air and solvent vapor from the can  being  filled is
ducted to a scrubber, while the air and vapor from filled cans  awaiting
movement is .merely vented to the atmosphere.  Before a  filled can is
moved, a cover is placed on top of the can to reduce occupational  exposure
to DMF.
     The cans containing the spun fiber are transported  to  subsequent
washing and drawing operations.  Hot water extracts  residual  DMF,  which
is then sent to  the dilute DMF  (weak stream) recovery system.
     Excess water is drained from the tow, and the fibers are crimped.
After crimping,  the tow is piddled into a creel can.  The tow is  then
cut wet to form  staple prior to drying, or is sent directly to  a  dryer
uncut.  At the dryer, several tow bands are dried side  by side.  The
steam, solvent vapor, and hot air from the drying operation are exhausted
                               j
to the atmosphere.  After drying, the tow is placed  in  cartons  for
shipment or storage.           !
     Work areas  are monitored for DMF concentration  at  numerous points.
Samples from these points are fed into three centralized Miran  Infrared
Gas Analyzers.   These points are monitored at a rate of one per minute
per analyzer.
     DMF and nitrogen, vented from the spinning cell, are routed  to a
condenser. . The  nitrogen gas from the condenser is sent back  to the top
                               i
of the spinning  cell where it is reheated and again  used in evaporating
the DMF from the extruded filaments.  The condensed  solvent is  sent to a
"strong feed" holding tank (termed "strong feed"  because this portion  of
the recovery stream is very high in DMF concentration).  The  liquid
stream from the  strong feed holding tank  is next  routed to  the  bottom  of
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a large distillation column where the DMF is recovered.  This distillation
column separates the solvent from water by driving off the lower  boiling-
point aqueous phase.
     Aqueous DMF streams from the spinning, washing,  and drawing  operations
are sent to a weak feed holding tank  (termed weak feed because  these
liquid waste streams contain low concentrations  of DMF).   In  addition,
the gaseous exhaust (emissions) from  the end or  bottom of  the spinning
lines is sent to a scrubber.  The scrubber solution  containing  DMF  and
water is also fed into the weak feed  line.  The  liquid from the weak
feed holding tank is vaporized and sent to the top of the  distillation
column.
     Pure DMF recovered from both the strong and weak feed 'streams  from
the distillation column is sent through a cooler (heat exchanger) and
solvent deionization process.  It is  subsequently stored  in a solvent
storage tank along with any make-up solvent needed in the  process.  The
stored DMF  is then ready for use  in dissolving additional  polymer.
     The technology utilized by this  plant represents the  most  effective
methods and equipment  for controlling VOC emissions  observed  in the
industry.   Emissions are captured and controlled at  more  points and
areas than  is the average or  industry-wide practice.  Because of  its
above-average emission control techniques, it  is the only  facility
considered  to be operating  at better  than baseline control  as described
in this document.   Indeed,  because  it is  not an  average  facility,  it
forms a basis for the  best  technological  system  of continuous emission
reduction that  "the Administrator of  EPA  determines  has  been  adequately
demonstrated" as required  in  the  Clean  Air Act.
     A new, modified,  or reconstructed  facility  would not be  required  to
operate at  levels demonstrated by this  facility  in  the  absence  of a new
source standard; in fact,  the  average industry-wide  practice  is
characterized by less  stringent  capture and  control. Therefore baseline
control for the dry-spun acrylic  fiber  model  plant  will  be quantified
and  described as the  expected  average practice,  and  not precisely existing
conditions.
      3.2.1.2.4   Producer D.   This company's  modacrylic  polymer product
 is  a mixture  of two different polymers:   a  co-polymer of acrylonitrile
 and  vinylidene  chloride  and a homopolymer of N-isopropylacrylamide.

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     Polymer powder is stored in silos prior to fiber production.  When
needed, the polymer powder is dissolved  in acetone  and filtered.   Filtered
dope is extruded through spinnerets downward into enclosed  cabinets
20 to 30 feet long.  Hot, dry air  is passed through  the cabinet,  and
acetone solvent evaporates into! this heated stream.  The  solidified
fibars exiting the multiple cabinets are collected  into a bundle  (or
tow), then passed through a washing step.  After the wash,  the  fiber  is
crimped, dried, cut, baled, and1 stored prior to shipping.
     Acetone evaporated at spinning is recovered from the spinning
cabinet air via a water scrubber system.  Major acetone losses  occur  as
solvent evaporates from the tow as  it passes through the  washing,  crimping,
and drying process-stages.  The1 volatilized acetone from  the  drying
operation is sent to scrubbers  for  recovery.   Activated carbon  beds are
                                i
used to recover acetone from stbrage tank vents.
     3.2.1.2.5  Producer E.  Acrylonitrile is  polymerized by  the  suspension
polymerization process to form  polyacrylonitrile.   The dry  polymer (AN)
is blended with solvent  (DMAc)  and  delusterarits  in  the mixing stage.
The dry polymer is fed (metered) into a  mixing area to form a slurry
(partially dissolved polymer plus  solvent).  The slurry is  pumped to
heatersj as heat is applied, the polymer is completely dissolved.   The
polymer solution is fed  into large holding tanks  (from the  bottom to
reduce air entratnment), and is then pumped to one  of several filter
                                i
presses.  Hoods over the presses collect the solvent vapor, and ducts
carry the vapor to the roof.
     The dissolved and filtered polymer  is then  pumped through  a final,
small filter and then to the sp-inneret jets.   The  fibers  are  extruded or
spun into a coagulation  bath of solvent  and water.   The coagulation bath
is continuously drained  to the  [solvent recovery  area.  A  counter-current
water wash flows across  the wash area, and  into the coagulation bath.
This wash water is relatively  Ijow  in solvent concentration  as it first
flows over the moving fiber, but gains in  solvent  concentration as it
moves toward and into the coagulation or spin  bath. The  gain is due  to
the  continuous diffusion of solvent out  of the extruded  fibers.  This
spin bath mixture  is drained continuously  and  piped to  the  solvent
recovery area.                  |
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     The tow bundles  then  proceed  down  the process  line to the finish
area.  Typically, this  is  a  bath of  lubricants  and  antistatic agents.
Following the finish  application,  the tow is  passed over heated rollers.
The steam and vapor released  at these points  is  collected by vent slots
in the spinning, washing,  and drawing equipment.  These vents manifold
into a large duct which  leads to the roof and atmospheric discharge.
     A small percentage  of the fiber produced at  this  company is dyed on
the process line at a customer's specifications.  The  dyeing is performed
on selected products  at  the  spinning/finishing/and  drawing machines.
     After drawing, the  fiber leaves the  main process  line equipment  and
is fed to a crimping  machine.  The fiber  at this  point is dry to the
touch.  The crimping  involves  heating the fiber and pressing the fiber
tightly against itself,  to form wrinkled  or crimped fiber.  A vacuum
duct is installed at  the exit of the crimper  to cool the fiber and
collect the vapor, which is vented to the roof.   After this, a conveyor
transports and loads  the tow  into  carts for temporary  holding and movement
to subsequent processing.
     The fiber is then transported to a large vessel where heat and
pressure are applied.  This process  is termed stress relieving.   The
heated and pressurized air and vapors are vented  to the atmosphere.
     Next, the fiber  is  put through  a recrimping  process,  since the
stress relieving removed most of the crimp induced  earlier.   As in the
first crimping stage, vacuum  ducts are installed  at the crimper box and
underneath the conveyor  to cool the  fiber and collect  the vapors,  which
are vented to the atmosphere.
     A small portion  of  the unrecrimped continuous  tow is  baled for
shipment at this point.  Most  of the recrimped tow  is  carried to a
fiber-cutting operation.   The  cut  fiber is then blown  into a baling
machine.  A tamper presses the loose staple into  a  500 pound bale, which
is automatically weighed,  bound, labeled,  and covered  with plastic wrap.
     This type fiber  plant using wet-spinning techniques  is  equipped
with a solvent recovery  system to  recover dimethylacetamide  in  the
solvent/water stream  that  came from  the spinning, washing,  and  drawing
stages.  Distillation is used  to separate water from solvent in the
recovery system.   The water from distillation is  recycled  to the spinning
operations and solvent is  recycled to dope preparation.

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17-24
3.2.2  Domestic Cellulose Acetate Manufacturing Processes
     There are three companies in the United States that produce acetate
fibers at five plant locations!  Acetate fiber consumption  is nearly
equally split between the textile fiber market and the acetate nontext ile
market, cigarette filtration tow.
     Acetate is the second oldest man-made fiber  and has become one of
the more important fibers in the United States.   Even though more than
15 other man-made fibers have since been introduced, none has been able
to duplicate the aesthetic properties of acetate  at a comparable price.
     Cigarette filters made from cellulose acetate tow are  widely used.
These filters provide the best balance between low price and taste when
compared with other materials.; Cigarette filtration tow is made from
the same cellulose acetate flake as textile fibers; therefore, it has
                               !
the same percentage of acetylation.
     3.2.2.1  Cigarette Filtration Tow.
     3.2.2.1.1  Producer A.  Dried cellulose  acetate flakes are stored
and dissolved in acetone, and a pigment is added.  Dissolving occurs  in
a closed, agitating mixer.  The resulting batches are blended, filtered,
and sent through a metering pump which provides a constant  flow of the
dope to the spinneret head.
     Cellulose acetate dope is! forced through  the spinneret, and the
extruded filaments are quenched with air from  the scrubber. The solvent
evaporates, leaving a filament! of  cellulose  acetate.  Acetone-laden  air
exiting from the spinning cabinet  (also called a  quench  stack)  is  sent
to a cold water scrubber and recycled to the  quench  stack.  This air  is
conditioned for humidity and temperature before entering the quench
stack.  The cellulose acetate  [filaments exit  the  quench  stack  and  are
collected into a bundle or tow(.  Since cigarette  tow  is  used for filtering,
the fibers, are smaller, and the  holes  in the  spinneret  are  smaller and
more numerous than those for filament or staple yarn.   The  post-spinning
treatment of the fiber  consists  of lubrication,  crimping,  and  drying.
     All solvent evaporating fjrom  the extruded fiber (or filament)  in
the  interior of the spinning cabinet (or quench  stack)  is  sent to  a
scrubber for recovery.   Emissions  from  the  drying process  are  collected
and  ducted to carbon  beds  for  acetone  recovery.   These  beds recover 92
                                    3-36

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to 95 percent of the acetone released at the drying stage.  Fugitive
emissions from other post-spinning operations are not controlled.
     3.2.2.1.2  Producer B.  Initially, cellulose acetate resin, which
is prepared in-house, is mixed semi-continuously with titanium dioxide
(TiOg) and acetone to make the dope.  The resulting batches are blended,
then filtered in stages.  The final stage is at the spinneret and  serves
to protect the spinneret, rather than acting as a final filter for the
dope.  Cellulose acetate dope enters the main header  (manifold) and is
routed to the spinning machines, which are called metiers.  Each metier
consists of a group of parallel spinning cabinets.  The dope  is then
metered through a pump and into the spinneret head.   The extruded  filaments
are quenched by room air drawn into the cabinet.  The evaporation  of  the
solvent leaves a filament of cellulose acetate, which is collected into
a bundle or tow.
     The fiber tow travels from the spinning machines to a crimper.
Each spinning line has its own crimping equipment. 'Rollers force  the
tow bundle into the crimper boxes, while water  is sprayed onto the
rollers.  At this stage, acetone is present  in  the water, and there is a
measurable evolution of solvent vapors.  After  passing through the
crimper the tow band is sent to the dryer, which serves to dry the tow
and strip some of the finish oils.  The dryers  are characterized as a
2-stage system that uses low pressure steam  followed  by hot air.   The
cigarette tow dryers exhaust directly to the solvent  recovery system,
manifolding first to an air conditioning unit with cooling and heating
elements.  The production process  is completed  at the finishing and
baling operations.
     These vapor-laden air streams are manifolded into the solvent
recovery system, which leads to carbon adsorption beds.  When saturated
with acetone, these beds are subjected to steam-desorption; the water-
acetone mixture is then distilled  and condensed to recover the acetone.
     Since a common solvent (acetone) is used  in the  manufacture of
acetate fiber, staple, and cigarette tow, the usual practice  to manifold
all the solvent-laden air ducts into a common  solvent recovery system.
The solvent recovery system generally includes  one or more units of
carbon bed adsorbers with associated air coolers, fan, valves, etc.
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Each adsorption unit has three or four carbon bed  adsorbers operating  on
a sequential timed cycle.  In normal operation, two or three of these
adsorbers would be adsorbing solvent from the solvent-laden air stream,
while the third is being desorbed with low-pressure steam.  The desorbed
solvent and steam passes through a condenser, and  then the acetone-water
mixture is separated by means of distillation.
     3.2.2.2  Cellulose Acetate Yarn.17"24
     3.2.2.2.1  Producer A.  In the cellulose  acetate yarn  process  both
continuous and batch cellulose acetate polymerization processes  are
employed.  The spinning process is; essentially the  same  as  those previously
mentioned, but post-spinning treatment varies.   Immediately after spinning,
the cellulose acetate filament is wound on  bobbins.  Some product specifi-
cations require a twist be put into the filament, after  which  the fiber
is wound on cores and packaged for[ shipment.   The yarn may  also  be  wound
on beams for weaving and packaged |for shipment.
     All solvent evaporating from the extruded fiber (or filament)  in
the interior of the spinning cabinet is sent to  a scrubber  for recovery.
No additional solvent recovery is practiced even though  the fiber contains
up to 20 percent solvent by weight.
     3.2.2.2.2  Producer B.  Polymer, solvent, and  other additives  are
mixed in a tank by mechanical agitation.  The  heat  of solution aids in
the dissolving of certain products.  From the  mixing tank the  dope  is
sent to successive surge or holding tanks to store  the dope before  being
pumped to filters.  Filter presses are not  hooded but use normal  room
air ventilation to remove solvent [that has  been  released at the  presses.
The filter media is periodically removed from  the presses and  is steamed
in ovens.  This mixture of steam and solvent is  sent to  solvent  recovery.
All waste polymer is redissolved and sent back to the primary  filter
presses.  The. filtered dope is sent to the  spinning area.
     Portions of dope are drawn from the main  header and pumped  to  the
spinning machines (metiers).. Each metier consists  of a  group  of side-by-
side spinning cabinets; in each cabinet dope is  taken off the  branch
header and passed through individual final  filters.  The dope  is then
pumped at a controlled rate through a spinneret  at  the  top  of  the cabinet.
Room air can be pulled in at the top, bottom,  or center  of  the spinning
                                    3-38

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cabinet depending on desired fiber characteristics.  The quench  air
flows cocurrently with the direction of the emerging filaments if  it
enters at the top of the cabinet, countercurrently  if  it enters  the
bottom of the cabinet, and in both directions  if  it enters the middle  of
the cabinet.
     Filaments emerging from the spinning cabinet are  brought together
and taken up on a bobbin or pirn.  The fiber is subsequently removed
from the bobbins or pirns and wrapped on beams or cones for shipment.
     As the filament yarn fibers come out of the  spinning cabinet, they
contain significant residual solvent.  Room air surrounding the  spinning
cabinets contains solvent which has evaporated from the yarn after it
leaves the cabinets.  Each metier is equipped  with  a duct for exhaust  of
vapor-laden air to the solvent recovery system.   At sale, the residual
solvent content is down to about 1 percent.  Therefore, the difference
in residual solvent content is emitted into the extrusion (spinning)
room or the twisting/beaming/coning rooms (textile  area).  The extrusion
room air is diluted in order to meet/maintain  the'OSHA worker exposure
concentration limits on the solvents.
     Improved solvent recovery could be achieved  by increasing the
concentration of solvent in the room air ducted to  the solvent recovery
area.  However, in order to balance the desire for  maximum solvent
recovery with the need for protection of workers  from  solvent exposure,
this company has developed a sophisticated system of in-plant air  manage-
ment.  This system involves the re-use of plant air from the three basic
process areas of the fiber plant.  Room air from  the dope preparation
area  (dissolving, mixing, filtering) and room  air from the twisting/coning/
beaming areas, both of which contain low levels of  solvent, are  vented
(transported) to the spinning room at a predetermined  flow rate.  The
spinning room air is then used to supply the quench air for the  spinning
cell solvent evaporation.  This process air, which  contains a high
concentration of solvent, is vented together with a fixed amount of
spinning room air containing a low level of solvent to the solvent
recovery system.  To accomplish this air management scheme properly, the
plant maintains a slight negative room pressure.  The  plant carefully
monitors this negative pressure as it is an important  operating  parameter
with  regard to operation of the solvent recovery  system.

                                   3-39

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                 .25-28
     The solvents recovered include methylene chloride, acetone,, and
methanol.  A common capture and recovery system is used to collect all
the solvent-laden air from the spinning cells, together with a portion
of the air from the spinning room.  The inlet solvent concentration of
                                i
the gases at the carbon adsorption system is relatively constant.
     The carbon beds are regenerated on a time cycle basis, which is
                                t
adjusted through analysis of exijt stack conditions.  Gas chromatographs
sequentially monitor all the carbon beds for concentrations of all three
solvents.  In each recovery unit there are three carbon beds receiving
vapor-laden air while one is stemming or regenerating.
     There are separate distillation columns for each solvent fraction.
The wastewater remaining after distillation contains a small amount of
solvent and is sent to the waste( treatment plant.
3.2.3  Domestic Spandex Fiber Manufacturing Processes'
     Spandex is a generic name for polyurethane fiber.  The Federal
Trade Commission defines spandex yarns as "a manufactured fiber  in which
the fiber forming substance is a long chain synthetic polymer comprised
of at least 85 percent of a segmented polyurethane."  Urethane is the
product of reacting a polyester |prepolymer with a diamine cross-linking
agent.  Between the urethane groups there are long chains which  may be
polyglycols, polyesters, polyamides, or copolymers of them.
     Spandex is produced by two companies in the United States,  each
employing a different manufacturing process.  In some respects,  one
process is similar to that used for acetate textile yarn, in that the
fiber is dry-spun and immediately wound onto take-up bobbins, then
twisted or processed in other ways.  This spandex manufacturing  process
is referred to as dry-spinning. \ The other process is substantially
different than any other fiber forming process used by domestic
synthetic fiber producers.  This manufacturing process is referred to as
reaction-spinning.              '
     3.2.3.1  Producer A.  This facility employs tetrahydrofuran as the
principal raw material; its ring is opened, and the resulting straight
chain compound is polymerized tq give a low molecular weight polymer.
This polymer is then treated with an excess of di-isocyanate.  The
reactant, together with any unreacted di-isocyanate, is next reacted
with some diamine, with monoamine added as a stabilizer.  The final
3-40

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polymerization stage is carried out in dimethylformamide solution, and
then the spandex is dry-spun from this solution.  Thus, this manufac-
turing process is characterized by use of solution polymerization and
dry spinning with an organic solvent.  Polymer (or copolymer) is dissolved
in solvent, blended with additives, filtered, dry spun, and processed.
     Immediately after spinning, spandex yarn is wound onto a bobbin as
continuous filament yarn.  The yarn is later transferred to large spools
for shipment or further processing in another part of the plant.  As the
fibers are initially wound onto bobbins, they may still contain as much
as 5 to 10 percent residual solvent.  This residual solvent continuously
evaporates into room or building air until 3 to 4 percent (by weight)
remains in the fiber.
     The major emissions from the spandex dry spinning process are
volatilized solvent losses which occur at a number of points in the
overall production scheme.  Solvent emissions occur during filtering of
the spin dope, spinning of the fiber, treatment of the fiber after
spinning, and during the solvent recovery process.  Figure 3-9 presents
a process flow diagram, with emission points shown for this segment of
the spandex fibers industry.
     Overall emissions from spandex fiber dry spinning are considerably
lower than from other dry spinning processes.  It appears that the
single most influencing factor that accounts for the lower emissions is
that, because of the nature of the polymeric material and/or spinning
conditions, the amount of residual solvent in the fiber as it exits the
spin cell is considerably lower than other dry spun fibers (e.g., 5 to
10 percent versus 15 to 20 percent).  This situation may be due to the
lower solvent-to-polymer ratio that is utilized in spandex dry spinning
(e.g., 1.5 to 2.0 for spandex versus 2.5 to 3.5 for acrylics and acetates),
Thus, the multi-stage condensation/distillation system which is used as
the primary solvent recovery system serving the spin cell exhaust gas,
although basically the same as in other dry spin processes, is overall
more efficient in terms of recovery of total solvent used.
     3.2.3.2  Producer B.  This reaction-spun spandex fiber manufacturer
forms their fiber by pumping a polyester prepolymer through multihole
                                   3-41

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3-42

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spinnerets at a constant rate into a bath containing  a dilute  solution
of ethylenediarnine in toluene.  The ethylene diamine  reacts with
isocyanate end groups on the resin to form long-chain, cross-linked
polyester elastometric fiber.  The cross-linking  reaction  continues  for
the duration of the process.  The fiber  is transported from the bath via
a heated conveyor belt, through a 2-stage oven where  solvent  is evaporated.
The first stage of the oven  is heated with steam  coils,  and the second
stage is heated with infrared heaters.   After drying, the  fiber is
lubricated and collected on  tubes for shipment.   Fiber sizes  range  from
10 to 7,000 denier.
     Potential VOC emissions are from the spin bath,  the heated conveyor
belt, and the drying oven.   Essentially  all  air  that  enters the spinning
room is drawn into the hooding that  surrounds the spin bath and conveyor
belt.  This stream is ducted to a carbon adsorption  (CA) system.  The
first stage of the oven  is  also vented  to the carbon  adsorber. Due to
the relatively low concentration of  solvent  in the dryer second stage
exhaust  (e.g., maximum concentration  of about  30 ppm  solvent), it is not
vented to the CA  system.  The gas streams from the spinning  roan  and
oven are  combined and cooled in  a heat-wheel  type exchanger  prior to
entering  the  bed.
     The  carbon  is regenerated with  steam,  and  the condensed  steam  and
solvent  is sent  to solvent  recovery.  There  is  some diamine  and  prepolyrner
 in  the aqueous phase  of  the condensate.   After  decantation of the toluene,
gentle agitation  causes  the remaining organics  to coalese, which  simplifies
 separation from  the  aqueous phase.   The toluene  is then  purified  in a
flash distillation column.
     The concentration  of  the inlet stream  to the CA unit is  maintained
 at  less  than  25  percent  LEL.  The  spinning  room  toluene  concentration is
 around 50 to  60  ppm.   The  oven exhausts are designed to maintain a
maximum  concentration of 25 percent LEL.
 3.2.4  Other  Fibers
      In  addition to  acrylic, modacrylic, cellulose acetate,  and spandex
 fibers,  there are numerous  organic solvent spun fibers manufactured on a
 small  scale,  relative to the commodity fibers.   Due to  the wide variety
 of these fiber manufacturing processes, specific  products and processes
                                    3-43

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will not be discussed.  Table 3-8 lists  some  of  these  fibers  along  with
their producers.
3.3  BASELINE EMISSIONS
     To determine the impact of possible Federal  emission  limitations,
it is necessary to determine the degree  of  control  imposed by State
Implementation Plans and any other  control  regulations.  The  baseline
control used in the analysis of NSPS  impacts  it  that  level  that  is
typical of the industry under consideration.   The impacts  of  an  NSPS  are
then calculated as incremental,impacts beyond the impact of the  baseline
control.
     Emission levels for fiber manufacturing  facilities  in the U.S. were
established using state air pollution control  information, plant visits,
and information submitted  to EPA in response  to  letters  of inquiry.
These emissions are summarized  in Table  3-9.   The most significant
emissions from these facilities are the  solvents used  in the  spinning of
the fiber.  Solvent recovery is an  integral portion of the manufacturing
processes due to the relativel^ high  economic value of the solvent.
Solvent-based fiber manufacturing facilities  recover  between  94  and
98 percent of the total solvent they  use for  economic  reasons, rather
than environmental or regulatory incentives.   Nonetheless, the industry
                               i
uses such a large amount of solvent (typically 2 or 3  pounds  for each
pound of fiber) that the 2 to  6 percent  of  solvent lost  represents  a
substantial tonnage of VOC emissions.
3.3.1  Acrvlic Fiber Production
     VOC emissions from the acrylic fiber industry include acrylonitrile,
the polymer-forming chemical, and the various organic  solvents used to
dissolve the polymer  (i.e., dimethylformamide, dimethylacetamide and
acetone).  Processes employing  aqueous solutions of acids  or  salts  as
polyacrylonitrile solvents have little or no  solvent-related  emissions
(i.e., NaSCN and ZnCl2).       ;        •
     3.3.1.1.  Wet Spun Acrylics.   Major.emission points for  wet spun
acrylic fibers are the filtration,  spinning,  washing,  drying, and crimping
steps where solvent is volatilized  into  room  air and  normally vented
directly to the atmosphere.  A  plant  of  this  type represents  the processes
and air pollution emission control  technology currently  in use in the
wet spinning segment of the acrylic fibers  industry.   Such a  production
                                    3-44

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      TABLE 3-8.   TYPICAL SPECIALTY FIBERS
Fiber Trade Name

  Teflon
  Vyrene
  Blue C Elvra
  Lycra
  Spandelle
  Glospun
  Vinyon
  Polybenzinidazole
  Nomex
  Kevlar
  Numa
  Kynol
Manufacturer

  DuPont
  U.S. Rubber Co.
  Monsanto
  DuPont
  DuPont
  Globe Mfg. Co.

  Celanese
  DuPont
  DuPont

  Carborundum
                         3-45

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             -i

                I
                s-
01


CO
 OJ
 CB
                        g
                                               «S S-
                                                                         —

                                                                         •r-  -r-  O)  CU
                                                                         ra  its in  CM
•*-  wi  •«->   a.  a.
                                                                             E  cn
                                                                            «-  -
                                                                      tu  ^-  «r-
                                                                      QJ  OJ r-
                                          3-46

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or process sequence is considered as  "baseline  control."  The  process
lines are essentially open to room  air.   Ventilation  hoods  are located
above the spinning and washing  areas  and  at  other  major processing
points..  The existing ventilation systems are  designed  around  high  air
flow rates with  little emphasis on  enclosures  to reduce air volume  flow.
     There are no VOC emissions from  nonorganic solvent wet spinning
processes (i.e., aqueous  solutions  of acids,  NaSCN and  salts,  ZnC^)
resulting from the volatilization of  solvent.   Acrylonitrile emissions
from these processes would be essentially the  same as the organic-based
wet spun solvent process.
     3.3.1.2  Dry Spun Acrylics.  Sources of emissions  include filtering,
spinning, washing, drawing,  steaming, and drying.   Air  pollution emissions
from dry spun acrylic fiber  production include residual monomer (acry-
lonitrile) and solvent  (dimethyl formarnide).
     3.3.1.3  Dry Spun Modacrylic.   The manufacturing stages are quite
similar to those of  dry  spin acrylic fibers.  The 'major baseline emissions
from this dry spinning  process  are  volatilized solvent  losses which
occur  at  a number of positions  in  the overall  production scheme.  Solvent
emissions  occur  during  dissolving  of the polymer, blending of the spinning
solution  (dope), filtering  of the  dope, spinning of the fiber, processing
of the fiber  after  spinning, and during the solvent recovery process.
 3.3.2   Cellulose Acetate
      3.3.2.1  Cellulose  Acetate Cigarette Filtration Tow.  The post-spinning
fiber  processing steps  in domestic  plants are typically open to room
 air;  the  exception  is the dryer, from which emissions may be controlled.
 Since  the fibers as  spun contain as much as 20 percent residual solvent,
 significant  amounts  of solvent are volatilized from the fibers into the
 room  air.   These fugitive emissions are  as high as 85  kg VOC per 1,000
 kg of  dry .polymer produced.
      3.3.2.2  Cellulose Acetate Textile  Yarn.  Filtration, spinning, and
 post-spinning stages are the significant sources of VOC emissions in the
 manufacture of  cellulose acetate textile yarn.  In the process sequence,
 the stages including and preceding spinning are identical to  those  of
 acetate filtration tow.   Immediately  after  spinning, acetate  textile
 yarn is wound onto a bobbin as continuous filament yarn, with no further
 treatment.  The yarn is subsequently  transferred  to  larger  spools  (beams

                                    3-47

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or cones) for shipment or further, processing  (twisting or winding, for
example) in another part of the pflant.  A portion of the yarn  is sold
directly in packages from the spinning machine.
     As the fibers are initially wound onto bobbins, they may  still
contain as much as 20 percent resjidual solvent.  This residual  solvent
continuously evaporates into room or building air until equilibrium  is
reached at around 1 percent (by weight) residual solvent.   On  an industry-
v/ide basis, these fugitive emissions are about  150  kg VOC per  1,000  kg
of polymer processed.
3.3.3.  Existing Regulations
     3.3.3.1.  State and Local Re'gulations.   There  are no State or local
emission regulations which apply [specifically to the production of
man-made fibers.  Of the eight States that  contain  almost all  man-made
fiber production facilities, most employ a  ceiling  or guideline regulating
VOC's which is similar to California's Rule 66.  Two of these  eight
States have little or no volatile! organic compound  emission control
regulation whatsoever.  These eight States  are  listed below with their
general VOC regulations.
     Alabama:  Volatile organic compound.emissions  shall be limited  to
40 pounds/day or 8 pounds in any  1 hour, or emissions shall  be reduced
by 85 percent.
     Florida:  No person shall store, pump, handle, process, load,
unload, or use in any process or  installation volatile organic compounds
or organic solvents without applying  known  and  existing vapor emission
control devices or systems deemed necessary and ordered by  the department.
All  persons shall use reasonable |care to  avoid  discharging, leaking,
spilling, seeping, pouring, or dumping VOC's  or organic solvents.
     Georgia:  There are no general  regulations concerning  VOC emissions
in Georgia except for certain designated  industries.  Synthetic fiber
manufacturing  is not included  in  this group of  industries.
     North Carolina:  Volatile organic compound emissions  are regulated
similarly to the restrictions of  Rule 66  in California  (anything  in
excess  of 40 pounds/day must  be  reduced by  85 percent).
     South Carolina:  No applicable  VOC regulations.
     Tennessee:  General VOC  regulations  state  that in  a  county of over
100,000 people  all new sources must  not  emit  over  100 tons/year,  otherwise
                                 I
                                    3-48

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the source would be subject to the lowest achievable emission rate
(LAER).  If a county's population is less than 100,000, a source must
use reasonable and proper controls.
     Virginia:  The only -effective VOC regulations are those that apply
to northern Virginia.  These are similar to California's Rule 66.
     West Virginia:  There are no effective VOC regulations, except  for
control of noxious odors.
     In summary, State regulatory agencies currently do not impose VOC
limitations which significantly affect man-made fiber spinning.  Although
numerous control devices exist for capture and recovery of organic
solvents and other volatile organic compounds released in spinning
operations, these are operated mainly for worker protection reasons  and
for economic purposes.
     3.3.3.2  OSHA Regulations.  Organic solvents used in the manufacture
of acrylic and cellulose acetate fibers are controlled by existing OSHA
regulations for exposure within the working area. • Acrylonitrile, the
monomer used in acrylic fiber production is also governed by these
regulations.  Table 3-10 lists these VOC's and their corresponding
Threshold Limit Values (TLV) for an 8-hour day.
     In order to meet these regulations most fiber producers (especially
acrylic) include additional ventilation capacity and capture systems to
reduce worker exposure.  In some instances it is economically feasible
to route this additional solvent-laden gas to the solvent recovery area,
thereby increasing the percentage of solvent recycled.
             Table 3-10  OSHA LIMITS FOR EXPOSURE TO SOLVENTS
               AND OTHER COMPOUNDS USED IN THE MANUFACTURE
                 OF ACRYLIC AND CELLULOSE ACETATE FIBERS
Acetone
Dimethylacetamide (DMAc)
Dimethylforamide (DMF)
Acrylonitrile
TLV/T1/JA 8-hour day
     1,000 ppm
        10 ppm
        10 ppm
         2 ppm
                                   3-49

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3.4  REFERENCES

1.   Man-Made Fiber Producers Base Book.  Textile Economics  Bureau,
     Incorporated.  New York, New York.  1977.
                               i
2.   Chemical Economics Handbook.  Stanford  Research  Institute.  Menlo
     Park, California.  March 1978.  Fibers-540.000.

3.   Parr, J.L.  Industrial Process Profiles for Environmental Use.
     U.S. Environmental Protection Agency.   November  1976.   Chapter  11  -  The
     Synthetic Fibers Industry.

4.   Shreve, R.N.  Chemical Process Industries.  New  York, New York.
     McGraw-Hill Book Company. ;  1967.
                               I
5.   Telecon.  Chiti, M., Research Triangle  Institute with Berard, R.,
     Pacific Environmental Services, Inc.  March 25,  1981.   Discussion
     of comprehensive list of fiber manufacturers.

6.   Moncrief, R.W.  Man-Made Fibers.  London, Boston.   Newes-Butterworths.
     1975.

7.   Welfers, Dr. E.  Process and Machine Technology  of  Man-Made Fiber
     Production.  International  Textile-Bulletin.   (Schlieren/Zurich.)
     World Spinning Edition: 174-204.  February, 1978.

8.   Click, C.N. and Moore, D.O. Emission, Process  and Control Technology
     Study of the ABS/SAN, Acrylic Fiber, and NBR Industries.  Pull man-Kellogg,
     Inc.  Houston, Texas.  Report to  EPA, Contract No.  68-02-2619,
     Task No. 6.  April 1979.  i

9.   Report of the Initial Plant Visit to American  Cyanamid  Company
     Santa Rosa Plant, Milton, Florida.  Prepared for the Office of  Air
     Quality Planning and Standards, U.S. Environmental  Protection
     Agency, during development  of New Source Performance Standards  for
     the synthetic fibers industry.  Pacific Environmental Services,
     Inc.  Research Triangle Park, North Carolina.  April 11, 1980.
                                                                          '
10.  Report of the Plant Visit to Badishe Corporation Synthetic  Fibers
     Plant, Williamsburg, Virginia.  Prepared for the Office of Air
     Quality Planning and Standards, U.S. Environmental  Protection
     Agency, during development1  of New Source Performance Standards  for
     the synthetic fibers industry.  Pacific Environmental Services,
     Inc.  Research Triangle Park, North Carolina.  November 28, 1979.

11.  Report of the Initial Plant Visit to DuPont Corporation Waynesboro
     Plant, Waynesboro, Virginia.  Prepared  for the Office of Air Quality
     Planning and Standards, U.S. Environmental Protection Agency,
     during development of New Source  Performance Standards  for  the
     synthetic fibers industry.  Pacific Environmental Services, Inc.
     Research Triangle Park, North Carolina.  May 1,  1980.
                                    3-50

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12.   Report of the Initial Plant Visit to DuPont Corporation May Plant,
     Camden, South Carolina.  Prepared for the Office of Air Quality
     Planning and Standards5 U.S. Environmental Protection Agency,
     during development of New Source Performance Standards for the
     synthetic fibers industry.  Pacific Environmental Services, Inc.
     Research Triangle Park, North Carolina.  April 29, 1980.

13.   Report of the Initial Plant Visit to Monsanto Company acrylic fiber
     plant, Decatur, Alabama.  Prepared for the Office of Air Quality
     Planning and Standards, U.S. Environmental Protection Agency,
     during development of New Source Performance Standards for the
     synthetic fibers industry.  Pacific Environmental Services, Inc.
     Research Triangle Park, North Carolina.  April 1, 1980.

14.   Economic Impact Assessment for Acrylonitrile.  Enviro Control,
     Incorporated.  Rockville, Maryland.  Occupational Safety and Health
     Administration.  February 1978.

15.   Development Document for Effluent Guidelines Limitations and Mew
     Source Performance Standards for the Synthetic Resins Segment of
     the Plastics and Synthetic Materials Manufacturing Point Source
     Category.  Environmental Protection Agency.  Washington, D.C.
     March 1974.

16.   Industrial Process Profiles for Environmental Use:  Chapter 11.
     The Synthetic Fibers Industry.  EPA-600/2-77-023k.  Industrial
     Environmental Research Laboratory.  U.S. Environmental Protection
     Agency.  Cinncinatti, Ohio.  February 1977.

17.   Reports of the Phase II Plant Visit to Celanese  Fibers Company
     Celriver acetate plant, Narrows, Virginia.  Prepared for the Office
     of Air Quality Planning and Standards, U.S. Environmental Protection
     Agency, during development of New Source Performance Standards for
     the synthetic fibers industry.  Pacific Environmental Services,
     Inc.  Research Triangle Park, North Carolina.  May 28, 1980.

18.   Report of Phase II Plant Visit to Celanese Fibers Company Celco
     acetate plant.  Rock Hill, South Carolina.  Prepared for the Office
     of Air Quality Planning and Standards, U.S. Environmental Protection
     Agency, during development of New Source Performance Standards for
     the synthetic fibers industry.  Pacific Environmental Services,
     Inc.  Research Triangle Park, North Carolina.  August 11, 1980.

19.   Report of Initial Plant Visit to Tennessee Eastman Company, Kingsport,
     Tennessee.  Prepared for the-Office of Air Quality Planning and
     Standards, U.S. Environmental Protection Agency, during development
     of New Source Performance Standards for the synthetic fibers industry.
     Pacific Environmental Services, Inc.  Research Triangle Park, North
     Carolina.  December  13, 1979.

20.   Correspondence from  Edwards, J.C., Tennessee Eastman Company to
     Manley, R., Pacific  Environmental Services, Inc.  December 2, 1981.
     Subject process information.
                                   3-51

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21.  Report of November 10, 1981 meeting between  representatives  of
     Tennessee Eastman Company and EPA in  Durham,  N.C.   Prepared  for  the
     Office of Air Quality Planning and Standards,  U.S.  Environmental
     Protection Agency, during development of  New  Source Performance
     Standards for the synthetic fibers industry.   Pacific  Environmental
     Services, Inc.  Research Triangle Park, North  Carolina.   December
     21, 1981.                 1
                               i

22.  Report of September 30, 1981 plant visit  to Tennessee  Eastman
     Company, Kingsport, Tennessee.  Prepared  for  the Office  of Air
     Quality Planning and Standards, U.S.  Environmental  Protection
     Agency, during developmentj of New Source  Performance Standards for
     the synthetic fibers industry.  Pacific Environmental  Services,
     Inc.  Research Triangle Park, North Carolina.   October 1981.
                               I
                               t
23.  Report of January 2, 1982 plant visit to  Tennessee  Eastman Company,
     Kingsport, Tennessee.  Prepared for the Office of Air  Quality
     Planning and Standards, U.S. Environmental Protection  Agency,
     during development of New Source Performance  Standards for the
     synthetic fibers industry.}  Pacific Environmental Services,  Inc.
     Research Triangle Park, North Carolina.   March 2, 1982.

24.  Report of the August 11, 1980 plant visit to  Celanese  Fibers Company
     Celco plant, Narrows, Virginia.  Prepared for the Office of  Air
     Quality Planning and Standards, U.S.  Environmental  Protection
     Agency, during development! of New Source  Performance Standards for
     the synthetic fibers industry.  Pacific Environmental  Services,
     Inc.  Research Triangle Park, North.Carolina.   September 1980.

25.  Correspondence from Mullen1, T.W. Jr.,  DuPont  (Waynesboro Plant)  to
     Manley, R.,  Pacific Environmental Services,  Inc.  June 9, 1981.
     Subject spandex process information.

26.  Report of the Plant Visit to Globe Manufacturing Company, Gastonia,
     S.C.  U.S. Environmental Protection Agency Office of Air Quality
     Planning and Standards, Research Triangle Park, N.C.   December 1,
     1981.                     !

27.  Correspondence from Legendre, R., Globe Manufacturing  Company to
     Grumpier, D.C., U.S. Environmental Protection  Agency.  June  26,
     1980.  Patent and process 'information.

28.  Report of November 12, 1981 meeting between  representatives  of
     Globe Manufacturing Company and EPA in Durham, N.C.  Subject solvent
     recovery and costs.  Prepared for the Office  of Air Quality  Planning
     and Standards, U.S. Environmental Protection  Agency, during  development
     of New Source Performance Standards for the synthetic  fibers industry.
     Pacific Environmental Services, Inc.   Research Triangle  Park, North
     Carolina.  December 2, 198^.

29.  Volatile Organic Compound Emission Inventory  for Tennessee Eastman
     Company.  U.S. Environmentjal Agency Region IV.  Atlanta,  Georgia.
     EPA 904/9-78-023.  December 1978.
                                   3-52

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30,   Synthetic Fibers Industry, Emission Test Report Monsanto Textiles
   .  Company, Decatur, Alabama.  U.S. Environmental Protection Agency,
     OAQPS.  Research Triangle Park, N.C.  EMB Report 80-SNF-2.
     February 1981.

31.   Synthetic Fibers Industry, Emission Test Report El du  Pont de  Nemours
     and Company May Plant, Camden, South Carolina.  EMB Report 80-SNF-l.
     U.S. Environmental  Protection Agency.  February 1981.
                                    3-53

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                    4.0  EMISSION CONTROL TECHNIQUES

4.1  INTRODUCTION
     As identified in Chapter 3 of this document,  volatile  organic
compounds (VOC's) are the most significant  air  pollutants released  to
the atmosphere during the manufacture of organic solvent spun  fibers.
Due to the economic value of solvents used  in the  synthetic  fibers
industry, capture and recovery of these solvents is an  integral  portion
of the manufacturing process.   Presently,  domestic synthetic  fiber
manufacturing processes recover 94 to 98+ percent  of  the solvents used
in fiber formation.  Therefore, solvent capture and recovery techniques
presently employed in the synthetic fibers  industry are also indirect
methods of VOC air pollution emission control.  In most cases,  capture
systems with subsequent solvent recovery are applied  only during the
actual spinning of the fiber; the majority  of VOC  emissions  from the
pre-spinning (solution mixing and filtering, etc.) and  post-spinning
(washing, drawing, crimping, heat setting,  and  drying,  etc.) operations
are not recovered for reuse.  Potential for additional  solvent recovery
and further VOC emission control exists at  these locations  in  the
manufacturing process.
     There are five basic techniques employed  in the  synthetic fibers
industry to recover solvent  from wet, dry,  and  reaction spinning
processes:
     1.  Gas Absorption
     2.  Gas Adsorption
     3.  Condensing
     4.  Distillation
     5.  Enclosure and Capture Systems.
These collection devices recover solvent from  spinning  cell  solvent-laden
air during dry spinning and  recover solvent from the  spin bath and
                                4-1

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wash water in wet spinning.  These streams  contain  high  concentrations
of solvent and therefore possess the greatest  potential  for  economic
and efficient solvent recovery.
                               i
     In addition to the capture and recovery of  solvent  during  the
actual spinning step, many wet* dry, and  reaction  spinning operations
incorporate hoods or complete enclosures  as capture systems  along
pre-spinning and post-spinning[process  lines to  prevent  worker  exposure
to solvent and unreacted monomer.  Quantities  of solvent released
during these portions of the manufacturing  process  are much  smaller
than those released during theiactual spinning of  the fiber,  and  are
usually vented to the atmosphere.  Recovery of solvent at these
processing points is usually not attempted  because  of the relatively
                               i
high air flow rates necessary to reduce solvent  and monomer  concentrations
around the process lines to acceptable  concentration levels  determined
by limits on worker exposure,  i
     A detailed description of the solvent  capture-and recovery techniques
presently employed in the synthetic fibers  industry is presented
below.  Because recovery process techniques may  be  specific  to  fiber
type or spinning method, a discussion of  the different recovery methods
for each of the various spinning operations will be treated  separately.
In addition to these methods of VOC emission control, a  discussion of
other techniques available to the synthetic fibers  industry  to  control
VOC emissions will also be presented.
4.2  GAS ABSORPTION EQUIPMENT2'3
                               i
     Absorption equipment is designed to  promote interphase  diffusion
between the solute gas and the absorbent  liquid.  The mechanism governing
absorption techniques is believed to occur  via a physical interaction
dissolving the solute gas into the absorbent,  or a chemical  reaction
between the two phases.  Absorption requires a high degree of exposure-
surface-area to guarantee good\contact  between the vapor-1aden  gas  and
the liquid absorbent.  The efficiency of  an absorber unit is dependent
upon the rate of mass transfer;which takes  place betv/een the gas and
the liquid.  Characteristics of the liquid  absorbent such as volatility
                               j
and viscosity, as well as solubility properties  of the solute gas  in
the liquid absorbent, significantly contribute to  absorber efficiency.
                                 4-2

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In an effort to maximize the effectiveness of  absorption  techniques  in
reducing or recovering process stream VOC emissions,  a  variety  of
absorption equipment has been designed  to achieve  good  contact  between
the gas and the absorbent.  These units  are  typically identified  as
packed towers, plate or tray towers, spray chambers,  and  venturi
absorbers.
                    2 4
4.2.1  Packed Towers '
     It has been shown,that systems of  this  type achieve  high rates  of
absorption.  Packed tower adsorbers are  vertical columns  filled with
an irregularly-shaped packaging material.  A liquid  absorbent is
introduced .near the top of the column through  liquid  distributors and
is sprayed or otherwise distributed over the packing  to wet  the entire
surface.  Absorbent liquid flows downward through  the column in a
direction countercurrent to the solute  gas which is  introduced  at the
bottom of the tower.  This solid-liquid  medium provides for  a large
surfdce-to-volume ratio of absorbent to  absorbate,-which, in  turn
determines the effective contact area for the  solute  gas.  Consequently,
the concentration of the solute gas stream decreases  as it rises
through the column due to the high absorption  rate of the gaseous
constituents onto the liquid absorbent,  which  is distributed on the
surface of the packing material.  Fresher absorbent  is  available  for
the more dilute gas stream in a zone just above any given contact
area.  Figure 4-1 presents a schematic  diagram of  a packed tower.
     When the active adsorption sites of the solid-liquid medium
become saturated with solute gas constituents,  the system is defined
as having reached load point.  Size and  operating  characteristics of a
packed tower are basically derived from, four design  parameters: column
diameter, pressure drop, number of transfer  units, and  the height of
the transfer unit.
4.2.2  Plate or Tray Towers'
     Plate or tray towers, are designed  to provide  contact between the
solute gas stream and liquid absorbent  through a series of plates
(trays) arranged in a step-like manner.  Bubble-cap plate towers  are
the most common example of plate-type absorbers.   Typically  the plates
permit deposition of the gas onto the liquid surface  through plate
.2,4
                                4-3

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                          t GAS OUT
            LIQUID-
            If
                                  LIQUID DISTRIBUTOR

                                  PACKING
                                  RESTRAINER
                                  SHELL
                                  RANDOM
                                  PACKING
                                  LIQUID
                                  RE-DISTRIBUTOR
                                  PACKING SUPPORT

                                  	 GAS IN



                                  	 LIQUID OUT
Figure  4-1.  Schematic  ;Diagram of a  Packed Tower"
                             4-4

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openings covered with caps.  Vapor rises through  the  plate  apertures
and exits the caps via peripheral slots which direct  the  gas  onto  that
portion of the plate which is immersed in liquid.   Liquid travels
through the column in a cascade fashion by entering the top of the
tower, flowing across each plate, and down through  each series of
plates by way of downspouts.   Design parameters for plate or  tray
towers include: gas velocity, temperature, liquid flow patterns, plate
spacing, and depth of liquid on the plate.  The number of stages
necessary to theoretically remove a given percent of  the  solute gas
from the gas stream is divided by the actual number of plates required
for the same system in order to determine the overall efficiency of
the tower.  Figure 4-2 illustrates the design of  bubble-cap tray
towers.
4.2.3  Spray Chambers2'4
     A more simplistic approach to accomplishing  interphase contact
between the solute gas and the liquid absorbent is'exemplified by
spray chamber absorbing units.  Typically, this device consists of an
empty chamber equipped with a series of nozzles which spray a liquid
over the cross section of the vessel as the gas passes through the
spray.  The size of the spray droplets affects the  efficiency of this
type absorber by determining available surface area for contact between
the two phases.  Spray nozzles can be selected to provide droplet
sizes ranging from 500 to 1,000 microns.  Solubility  characteristics
of the solute gas-absorbent mix will also contribute  to percent removal
or recovery values for process stream pollutants.
4.2.4  Venturi Absorbers2'4
     Venturi absorbers, like spray chambers, can be. used  to reduce
gaseous emissions.  The venturi type absorber accomplishes  interphase
contact between the solute gas and the liquid absorbent by  introducing
the gas and the liquid into the throat of the venturi at different
velocities.  High gas velocities required by the venturi serve to
increase the effective collision between the gas and  liquid streams.
Power requirements necessary to provide such high velocities can be
large, due to the fact that energy is dissipated in the form of a
                                4-5

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                                 I I f GAS OUT
                  SHELL—  •

                  TRAY	


                 DOWNSPOUT -
               TRAY
               SUPPORT RING -
                TRAY
                STIFFENER-
                  VAPOR	
                  RISER

                   FROTH—-
                           ,^y-p:-^
^-LIQUID IN
                                            BUBBLE CAP
                                           SIDESTREAM
                                          'WITHDRAWAL
 .INTERMEDIATE
  FEED
                                         — GAS IN
                                         ~ LIOUID OUT
Figure  4-2.   Schematic Diagram of a  Bubble-Cap Tray  Tower"
                                  4-6

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pressure loss.  Venturis have the advantage of obtaining  a  high  degree
of liquid-gas mixing, but have the disadvantage  of  short  contact
times.  High velocity requirements can also generate  an entrainment
problem, which usually necessitates the use of a mist eliminator
downstream in the system.
4.2.5  Gas Absorption Equipment as Currently  Employed by  the  Synthetic
                       _j^
       Fibers Industry
     4.2.5.1  Dry Spun Acrylic Fibers.1'12  Dry  spinning  of acrylics
is performed by extruding a solution of polymer  in  an organic solvent
(usually dimethylformamide) through a spinneret  plate into  a  spinning
cell.  A column of hot inert gas that is  above the  boiling  point of
the solvent  is circulated in the direction  of the  emerging  spinning
solution.  The solvent evaporates  into the  spinning cell  leaving a
solidified filament.  The solvent-laden gas stream  is routed  to  a wet
scrubber.  Approximately 90 percent of the  total solvent  introduced
into the system is recovered at the spinning  cell.-  Capture and  recovery
of solvent from the  spinning cell  quench  gas  serves as an indirect
means of controlling  VOC emissions.
   •  At the  exit of  the spinning column the fiber  contains  from  15 to
30 percent solvent by weight.  Most of this residual  solvent is  removed
from  the spun fiber  in the  subsequent washing, drawing,  crimping, and
drying  process stages.  Some residual solvent remains in  the final
product.  Partial enclosures are used around  pre-  or post-spinning
stages  to capture volatilized  solvent so  that OSHA standards for
occupational  exposure in  the work  area can  be met.   These enclosures
are  vented to the atmosphere;  no attempt  is made to recover or control
these emissions via  conventional air  pollution  control equipment.
                                          1  12
      4.2.5.2 Dry Spun Cellulose Acetate. *    Recovery of solvent
from the spinning of cellulose acetate fibers is accomplished in the
same manner  as solvent  recovery  from  dry  spinning of acrylic fiber.
Air  entering at  the  top  of  the spinning  cabinet  flows cocurrently with
the  direction of  the extruded  filaments  and removes volatilized solvent
 (acetone) from the  acetate  filaments.  The  air stream or quench gas,
containing  high  concentrations of  acetone,  exits the spin cell  and is
sent to a solvent  recovery  device.  When  wet  scrubbing is used  as the
                                 4-7

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                                          4
recovery device, the acetone in solution with water  is  transported  to
a distillation column where the acetone is separated  for  recovery and
reuse.                         [
     As the fiber exits the spin cell  it contains  as  much  as  20  percent
acetone by weight.  The remaining post-spinning  processes  are  usually
uncontrolled, and residual acetone  in  the fiber  is allowed  to  evaporate
                               I
into the room air.  Because the TLV for acetone  is relatively  high,
and stringent precautions are not necessary  to minimize worker exposure,
little or no attempt is made to capture and  remove fugitive acetone
emissions along the other portions  of  the process  line.   Instead,
general room air ventilation is used to maintain the  solvent  concentration
at acceptable levels.  Emissions from  the filtering of  the  dope  prior
                                  13
to spinning are also uncontrolled.
4.2.6  Gas Absorption Equipment Performance
     VOC control efficiencies of scrubbers are known  to exceed 99 percent.
Absorption is highly dependent I upon  solubility for" effectiveness.
High solubilities tend to reduce the column's liquid-gas  ratio by
minimizing the required liquid flow  rate for a given  efficiency.
Concentration of the exhaust stream  influences the selection  of  absorber
design.  If very low concentrations  of a highly  soluble VOC are  directed
to the absorber, the size of the tower can be relatively  small and
gas-liquid throughputs can be optimized.  In the case of  highly  concentrated
streams of a fairly insoluble material, long residence  times  and/or
larger towers are necessary to promote contact.  Acetone,  DMF  and DMAc
are infinitely soluble in water, thus  a favorable  equilibrium  can be
established that will promote effective VOC  removal efficiencies.
     The total emission rate of the  vapor-laden  gas stream, more than
any single parameter, governs the size of the absorber  unit.     Temperature
is also an important variable to be  considered in  the design  of  an
absorber.  The gas volume affects the  size of the  collector regardless
of the method of absorption chosen.  The exhaust gas  flow  rates  and
concentrations of the solvents at synthetic  fiber  plants make  VOC
scrubbing using water as the absorbent a practical control  technique.
     Packaged towers, plate towers,  and spray chambers  are  the types
of absorption devices most effective for VOC collection.   However,
4-8

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there are advantages and disadvantages for each system, and  final
                                                                    2
selection should be based on the following comparative  information:
     •  if the gases tend to be corrosive, as are DMF and DMAc,  packed
towers are generally less expensive than plate towers;
     •  if throughput is the same, packed towers will exhibit  smaller
pressure drops than plate towers;
     •  liquid "hold-up" is usually less in  a packed tower;
     •  packed towers tend to plug more readily than do plate  towers;
     •  plate towers are better suited for continuous temperature
variations;
     •  spray chambers demonstrate a lower absorption efficiency than
both packed and plate towers.
4.3  GAS ADSORPTION EQUIPMENT15"17
     Gas adsorption equipment (primarily carbon beds) has been used
for solvent recovery by the synthetic fibers industry and other indus-
tries for many years.  In general terms, the principle  behind  adsorption
as it applies to the synthetic fibers industry may  be described as
follows:  the "activated" carbon constitutes the adsorbent,  and the
organic solvent that is removed from a gaseous stream is referred to
as the adsorbate.  Adsorption occurs at the  gas-solid interface of  the
adsorbent.  The mechanism of adsorption is believed to  be a  combined
effect of:  physical adsorption of the adsorbates without a  chemical
change; Van der Waals forces between the carbon surface and  the gas
that acts to form layers of gas molecules; and capillary action that
occurs in the fine pores of the absorbent material. Adsorption is  an
exothermic process, and cooling may be necessary to prevent  excessive
heat buildup.
     There are several variables which affect the performance  of
carbon adsorbers, and most are related mathematically to the adsorptive
capacity of the carbon.  Adsorptive capacity defines the weights of
adsorbate that can be retained on a given weight of carbon,  and is
                1 ft
expressed below:
               Adsorptive  Capacity  =
                                           Vm
                                        log  {Co/c1)
                                 4-9

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where, adsorptive capacity  , gs  g  adsorbent

     Vm = liquid molar volume  of  adsorbate  at  normal  boiling  point
      T = absolute temperature
     Co = concentration of  adsorbate at  saturation
     Ci = initial adsorbate concentration into adsorber.
The liquid molar volume of  a|n  individual adsorbate  is  related  to  the
individual molecular weight and density  of  the solvent at  its  boiling
point.  The greater the Vm  of  the adsorbate, the  higher the molecular
weight and boiling point.   iji  other words,  carbon generally has a
greater adsorptive capacity for higher boiling point  and higher molecular
weight solvents.  The remova^l  of  solvents by physical  adsorption  is
practical for adsorbates with molecular weights  over  45.
19
     Adsorption equipment  is designed  to  collect  and  retain  vapors  on
the adsorbent material until, the absorbent  becomes  saturated.   Adsorber
units can allow for either regeneration  (desorption)  or  disposal  of
the used adsorbent material.;  Nonregenerative systems  are units  that
do not reuse spent absorbent and require  that the adsorbent  material
be removed for regeneration or incineration.
     The adsorption cycle  takes place  in  two stages:  adsorption  and
regeneration.  Initially,  the adsorption  rate of  gaseous vapors  is
rapid and complete; but as the adsorbent  is saturated, collection
efficiency of the system decreases.  Regeneration requires that  a hot
gas, usually steam, be passed upward through the  bed,  which  drives  off
                            i
adsorbed compounds.  Following regeneration but prior  to the control
system being put on-stream, cooling and drying of the  bed is necessary
due to the temperature and water content  of the adsorbent.   Insufficient
cowling and drying will result in reduced efficiency.  If the desorption
feature is an integrated component of  the solvent recovery system,
then the vapor-laden effluent is condensed  and separated by  decantation
or distillation.  Figure 4-3; shows a typical carbon adsorption  process
employed in the synthetic fibers industry.
     Adsorbers can have fixed, moving, or fluidized beds, and can be
opened either vertically or horizontally.  The simplest  adsorber
design is a vertical cylindef containing  a  fixed  bed  adsorbent  sandwiched
                                4-10

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                          •=£ OL _J D-
                          0 0 _, _
                                                           to
                                                           t/1
                                                           ID
                                                           O
                                                           O

                                                           D-
                                                           O
                                                           to
                                                           -a
                                                           (O
                                                           O
                                                           O)
           o
           a-
           =1 >
4-n

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between screens.  Typically, tfixed  bed  adsorbers  are  a  two-unit  system;
one adsorber cleanses the vapor-laden stream,  while the second bed
undergoes regeneration.  Three-bed  adsorber  units  usually  employ one
bed for adsorbtion, a second bed  for regeneration, while the  third  bed
undergoes cooling and drying.;   Figure 4-4  illustrates three different
configurations for carbon adsorption that  could be employed in the
synthetic fibers industry.  Fixed bed adsorbers may be  designed  in  a
cone shape.  This type of construction  allows  for  a large  adsorbent
surface area exposure.  Higher  gas  flow rates  at  lower  pressure  drops
are accommodated by cone-shaped units in contrast  to  a  flat bed  system
using the same total weight of  adsorbent.    Horizontal  beds  are also
employed, with the carbon beds  enclosed in a cylinder.
     A moving bed configuration passes  activated  carbon through  an
adsorption zone.  Due to fresh  adsorbent continually  being fed into
the adsorbing zone, moving bed  adsorbers demonstrate  higher collection
efficiencies than stationary bed  systems.  Disadvantages include wear
on moving parts, more rapid attrition of adsorbent, and higher steam
                             !                           17
requirements for desorption due to  shorter carbon  beds.
4.3.1  Applicability to The Synthetic Fibers Industry
     4.3.1.1  Dry Spun Cellulose  Acetate and Triacetate.'
Three fiber producers are currently employing  carbon  adsorption  as  a
means of recovering solvents from their cellulose  acetate  production
lines.  In one case, volatilized  solvent (acetone) from the drying
process is sent to carbon beds  for  acetone recovery.  Steam is used to
strip the solvent from the carbon beds, then the  condensed steam and
acetone is distilled.  Approximately 92 to 95  percent of the  acetone
                             i
released at the drying stage is recovered  by the  carbon adsorber.
     In another case, acetone-laden air from the  spinning  cells  discharges
into several carbon beds.  Again, steam is used to strip the  acetone
from the carbon beds.  Once stripped, the  acetone-laden stream is
condensed, cooled, and pumped to  stills where  the acetone  is  separated
from the solution and recovered for reuse.   It is  reported that  this
                             i
system routinely achieves 98 [percent efficiency after capture of the
vapor.
6-11
                                4-12

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VAPOR-LADEN
 AIR IN
                                CARBON
                                CYLINDRICAL
                                SHELL HOUSING
                                           VAPOR-FREE
                                            AIR OUT
                                                                     VAPOR-FREE
                                                                       AIR OUT
FRESH CARBON
 DISPENSER
SPENT CARBON
  COLLECTOR
                                                                    VAPOR-LADEN
                                                                      AIR IN
          VAPOR-LADEN
           AIR IN


                                                                             VAPOR-FREE
                                                                               AIR OUT
                          Figure 4-4.   Carbon  Adsorption Methods
                                                4-13

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     The third producer employing carbon adsorption as a means of
solvent recovery from their cellulose acetate production lines uses  a
common adsorption system which serves both filament and tow  product
lines.  The two solvent recovery processes associated with filament
extrusion operations and tow extrusion operations  are housed  in  separate
facilities.  Two vapor-air ducjts and a room-air duct connect  the two
facilities.  The solvent recovery system is common to both operations
inasmuch as all absorbers are interconnected via the room air and
vapor ducts.
     Some of the room air is mpved directly via the room air duct  from
the filament extrusion building to the tow extrusion building.   Heated
room air is drawn into the filament spinning machines as quench  air.
Concentrated solvent vapor-laden air from the spinning machines  is
ducted to adsorption units.  The recovery process  differs in the
production of the two types of fiber, textile filament and tow only  in
that the vapor-laden air is cooled before ndsorptton in the  filament
recovery system by means of a wet (spray) cooler;  while in the tow
recovery system, the vapor laden air is cooled using dry coil heat
exchangers.  As with the other adsorber systems mentioned previously,
steam is introduced into the bottom of the carbon  beds to desorb
                              i
acetone.  Condensers and distillation stills are used to recover
98 percent of the collected acetone for reuse  in fiber production.
     This same fiber producer also employs carbon  adsorption at  another
filament yarn facility.  However, a different  solvent  recovery strategy
is used.  This system involves the reuse of  plant  air  from the three
basic process areas of the fiber plant.  Room  air  from the dope  preparation
area  (dissolving, mixing, filtering) and room  air  from the twisting/
coning/beaming area, both of which contain low levels  of solvent,  are
                              i
vented to .the extrusion room at a predetermined flow rate.   The  extrusion
room  air is then drawn into the spin cell to supply the quench  air for
solvent evaporation.  Quench air containing  a  high concentration of
solvent is vented together witjh a fixed amount of  extrusion  room air
(which contains a low level of solvent) to the carbon  adsorption
system.  The  solvents recovered at this facility  include methylene
chloride,  acetone,  and methanol.  Again, steam is  used  to desorb the
                                 4-14

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solvents.  A separate distillation column is used for each solvent
fraction.  Solvent recovery at this facility is approximately 95  percent.
                                                              20
     4.3.1.2  Wet-Spun Spandex Fibers  (Reaction Spun Spandex).    As
identified in Chapter 3 of this document, wet spinning of spandex
fibers or reaction spinning is performed by extruding a polyester
prepolymer through spinnerets at a constant rate  into a solution  of
(usually) ethylenediamine in toluene.  A chemical reaction precipitates
the polymer, which is withdrawn from the bath and placed on  a moving,
heated conveyor belt.  The chemical cross-linking reaction continues
for the duration of the process.  From the heated conveyor the  fiber
is drawn through an oven, then wound on packages.
     Air pollutant emissions from the  reaction-spun spandex  process
line originate at the spin bath, the heated conveyor belt, and  from
the oven.  Essentially, all air that enters the spinning room is  drawn
into the hooding that surrounds the spin bath and conveyor belt.  This
stream is ducted to a carbon adsorption system.   The first stage  of
the oven is also vented to the carbon  adsorber.
     The carbon is regenerated with steam.  Condensed steam  and solvent
is sent to the solvent recovery area.  There is some diamine and
prepolymer in the aqueous phase of the condensate.  After decantation
of the toluene, gentle agitation causes the remaining organics  to
globulate, which makes them easy to separate from the aqueous phase.
The toluene is purified in a flash distillation column.
     Overall solvent recovery associated with the reaction-spun spandex
process is currently not as efficient  and economical as in other  fiber
production processes.  Over 99 percent of the organic vapors evolved
in the reaction-spun process are captured and sent  to solvent recovery.
However, a rather complex fouling phenomenon in the carbon bed  decreases
the solvent recovery efficiency to less than 90 percent rather  quickly.
Apparently, unreacted prepolymer and diamine cause  such severe  carbon
bed fouling within the adsorption system that the carbon pellets  are
cemented into a hardened asphalt-like  solid.  The consequential removing,
shipping, and reactivation of the carbon is a large expense  to  the
producer.   It appears from an investigation into  the carbon  fouling
problem that there is no short-term solution to the lower solvent
recovery efficiency associated with the reaction-spun spandex process.

                                4-15

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4.3.2  Gas Adsorption Equipment Performance
     Custom packaged carbon adsorption designs feature  flow  rate
accommodations of less than TOO scfm to 80,000 scfm.  Review of exhaust
flow rate data from the synthetic fibers  industry,  show that flow
rates from uncontrolled emission sources  range from 5,000  acfm to
60,000 acfm.  On the average:, VOC exhaust gas characteristics are
reported to range from 100 ppm to 3,000 ppm, falling well  within
design specifications.  As identified in  the previous section, carbon
adsorption efficiencies rangp from 92 to  98 percent.  Several factors
are attributable to this range of collection efficiencies.   Recent
industry efforts to recover residual acetone have  included the treatment
of all dryer exhaust gas for solvent recovery.   As  a result  of high
moisture content in the gas ;stream and the presence of  finish oils
which contaminate the carbon beds, the adsorption  efficiencies achieved
on treatment of this gas stream are somewhat lower  than other carbon
                        21 22
adsorption applications.  '    Therefore, based  on- industry  operating
experience, a recovery efficiency of about 92 percent is normally
expected for carbon adsorption systems servicing streams with high
moisture content.
     It appears that solventrladen air streams containing  two or more
VOC's, such as that encountered at the facility  that produces cellulose
triacetate textile filament |yarn, may result in  several  adverse effects
upon the carbon adsorption system.  Adsorption of  organic  compounds
having higher molecular weights will tend to displace those  having
lower molecular weights.  Lighter compounds will tend to be  separated
or partitioned from the heavier and will  pass through the  bed at  a
faster rate.  This will increase the mass transfer zone, and may
require additional carbon bed depth, or shorter  operating  cycles.
                            i
Also, carbon retentivity may be reduced in accord  with  the above,  and
                            i
breakthrough conditions may result for lower-boiling materials.   The
LEL of the mixture will also vary directly as the  LEL of the individual
components.  Thus, safety considerations  might require  more  or possibly
                            i
less dilution air with multiple organic feeds.   Due to  the adverse
                            I
effects associated with solvent-laden air streams  containing two  or
more VOC's, the carbon  adsorption efficiency of  any given  system  will
                                 4-16

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tend to be lower with a multiple organic feed  than with  a  single
             23
organic feed.    Therefore, the typical efficiency for a system handling
a multiple organic feed is expected to be approximately  95 percent.
                 1 IQ ?4 ?£,
4.4  CONDENSATION i»iy»^»«
     Recovery of condensible vapors is accomplished  by passing vapor-air
or vapor-inert gas mixtures over relatively cold  surfaces,  resulting
in direct condensation of the vapors.  The principle of  condensation
of solvent vapors is the operation of the condenser  at increased
pressure or reduced temperature to change the  solvent from its vapor
to the liquid phase, simplifying recovery or further processing.
     The two types of condensers that can be employed are  contact  and
surface condensers.  Contact condensers require that the coolant
physically mix with the vapor-laden gas stream, and  this method is the
more efficient of the two. . However, in contact condensation, the
condensate is contaminated with the coolant liquid,  and  further treat-
ment is necessary for condensate recovery.  For this reason, the
surface-type condensers are usually utilized in cases where the condensate
will be recovered for reuse, rather than being incinerated or sent to
waste treatment.
     Most surface condensers are the shell and tube  type.  The coolant
flows through the tubes, and the vapor condenses  on  the  shell side.
The amount of cooling required depends on the  inlet  vapor  concentration
and flow rate and the design concentration of  the exit gas.  Also, the
presence of any contaminating substances that  might  be deposited on
the cooled surfaces might inhibit heat transfer and  reduce condensation
efficiency.  Also, the inlet vapor temperature is important, since the
entire stream must be cooled to the condensation  temperature of the
compound being removed from the stream.
4.4.1  Applicability to the Synthetic Fibers IndustryJ
     Condensers are used throughout the synthetic fibers industry, and
are used both independently for solvent recovery  or  as part of a
larger recovery system that may include scrubbers or carbon beds.  In
those cases where condensers are used independently,  the solvent is
usually recovered from a closed loop.  Spin cell  gas (such as heated
nitrogen) that contains a high concentration of solvent  vapor is
16-21
                                4-17

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ducted to the condenser, where the solvent  is  recovered economically
(due to the high concentration) for  immediate  reuse or storage.  When
used alone for vapor control, refrigeration  is  the usual means  of
achieving the low temperatures necessary for efficient condensation.
Temperatures as low as -120°(r are normal.   In  other cases,  condensers
may collect the steam and concentrated vapor from carbon beds  (during
the regeneration cycle), to be followed by  distillation or  decantation
to separate the solvent from1 the condensed  mixture.
4.4.2  Performance Characteristics
     The operation efficiencies and  costs for  condensers depend on  the
following:,
     •  the concentration and nature of the  vapors in the gas  stream
     •  the average temperature difference  between the inlet  gas and
the coolant                 !
     •  the nature of the coolant or refrigerant
     •  the presence of noncbndensible gases  in the inlet gas  stream
     •  the presence of particulates or other  contaminants  (oils,
etc.) in the inlet stream
     •  utility costs
     •  recovery credit for reclaimed solvents
      In the closed loop operation, where  contamination  is low and
vapor concentration  is relatively high, recovery  efficiencies are
dependent  on several variables, but  are reported  greater  than 96 percent
for some saturated hydrocarbons.   In uses where ambient  air is mixed
with  the vapor  and some contamination is  present,  usual  efficiencies
of  about 90 percent  are reported.   Advantages  and disadvantages of
                            i                                             I
condensation as a control  technique  are given  in  Table  4-1.             <
4.5   DISTILLATION
                           p£
4.5.1  General  Description
      Distillation  is the  separation  of compounds  usually in the liquid
phase by partial vaporization  of  the mixture and  separate recovery of
the vapor  and  residual  liquid.  The  lower the boiling point of a
constituent, the greater  its  proportion  in  the vapor phase, and the
lower its  concentration  in  the residual mixture.   The degree of separation
of  the  various  compounds  introduced depends on the properties of the
compounds  and  the  characteristics of the  distillation process.  Usually,
                                 4-18

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    Table 4-1.  ADVANTAGES AND DISADVANTAGES OF EMPLOYING
                                                22
             CONDENSATION AS A CONTROL TECHNIQUE
                         ADVANTAGES
1.   Proven technology in other nonrelated industries.

2.   Recovered heterogeneous mixtures of organic solvents
    could be burned in a process boiler.

3.   Heat exchangers and low temperature cooling coils can
    reduce cooling requirements (sometimes up to 75 percent).

4.   May perform best as an integral part of other air pollution
    control  equipment.
                        DISADVANTAGES


1.  At a solvent concentration in the 100 to 200 ppm range,
    refrigeration costs would be very expensive.

2.  Large air volumes or particulate matter can reduce
    condensation efficiencies by as much as 50 percent.

3.  Cooling requirements are more demanding for heated exhaust
    streams, such as from dryers.
                           4-19

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distillation refers to the vaporization process  in which the vapor
evolved is recovered, usually;by cooling or condensation.
     In batch distillation, the mass of material to  be distilled  is
heated to the boiling point oV the material to be recovered in  a
                              i
container, and the vapors pass upward through a  column, then to a
condenser.  This process continues until the distillate concentration
in the residual material is reduced to an  acceptably low level.
     In continuous distillation, a feed stream is partly vaporized
while the vapor and liquid portions are continuously withdrawn.
Startup of such a unit is the same as in batch distillations except
that no product is removed via the overhead column.   When  steady  state
conditions are achieved, the  feed is continuously added at some inter-
mediate point in the column,  j The portion  of the column above  the feed
point is the enrichment section, and the section below the feed point
is known as the stripping section.  Vapor  is continuously  withdrawn
and condensed.  This type distillation is  used in -conjunction  with
steam distillation in some applications.
     Steam distillation is the vaporization of the  feed by blowing
live steam through it, and fe|ed of the steam/vapor/volatiles mixture
into the separation column.   This is especially  useful when excessive
temperatures should be avoided.
                                                      16-21
4.5.2  Applicability to the Synthetic Fibers  Industry
     Synthetic fiber producers use distillation  extensively  in solvent
recovery systems.  Separation and purification of the solvent  used  in
preparation of the spinning solution  is a  critical  step  in fiber
manufacture.  Manufacture of  ;all but  the most  exotic and  expensive
fibers requires recovery and  reuse of the  solvent for economic reasons.
     The solvent fed to distillation  is usually  mixed with water, or
is even a .mixture of several  solvents, each with a  particular  function
in the overall process.  A peculiar  phenomenon  occurs when several
solvents are used and recovered that  should be mentioned.  While
separation and recovery efficiencies  of 98 percent  and greater are
common for distillation of a  single  solvent from a  water/solvent
mixture, lower efficiencies  are observed  in multi-solvent systems.
This apparently results from  the  characteristics of the various
                                 4-20

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azeotropes formed, and more of each solvent  is  removed  from  the  system
than would otherwise occur.   (It may  also  be possible that lower
efficiencies result from varying carbon  adsorption  efficiencies  among
the constituents, and other phenomena  such as preferential breakthrough.)
     In dry spinning, the solvent  is  removed from the vapor  stream  by
use of carbon adsorbers or scrubbers,  and  the solvent/water  mixture is
then separated by distillation.  In wet  spinning, a solution of  polymer
                                                                 12
in solvent is extruded through a spinneret into a spinning bath.
The spinning bath contains solvent diluted with water such that  it
causes the fibers to coagulate at  the  proper rate.   The main feature
of wet spinning is the mass transfer  of  solvent; precipitation or
coagulation of the fiber ensues by diffusion of the solvent  from the
fiber into the bath, and by diffusion  of the water  into the  thread.
The resulting spin bath liquid contains  large amounts of  solvent.
This solvent-laden liquid stream is routed to a distillation column
where the solvent is recovered for reuse.  Liquid 'streams from the
washing and drawing portions  of the process  are also treated for
solvent recovery.
     The most important aspect of  distillation  as it affects the
fibers industry is the extreme importance  of maximum separation  and
recovery efficiency.  Since thousands  of tons of solvent may pass
through a distillation column at a typical fiber plant  within a  single
year, even small changes in efficiency would potentially  result  in  the
loss or savings of thousands  of dollars.
4.6  ENCLOSURES27
4.6.1  Applicability to the Synthetic  Fibers Industry
     A major source of VOC emissions  at  synthetic fiber plants that
utilize an organic solvent to dissolve the polymer  is solvent loss
which occurs as the fibers proceed from  the  exit of the spinning
cabinet through the various texturizing  processes.   Residual  solvent
is volatilized into room and  building  air  at those  processing steps
not directly served by the solvent recovery  collection  system.   Room
and building air is, in most  cases, then collected  by ventilation
systems and either discharged or recirculated in air conditioning
                                4-21

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systems.  In either case, the solvent  is maintained  at  concentrations
well below the lower explosive limit and the  threshold  limit  value  for
the particular solvent.  These post-spinning  fugitive solvent emissions
are eventually directed to the atmosphere.  Because  enclosures  designed
to completely envelope process emission sources  so as to  collect  and
effectively capture solvent vapors are not  typically utilized by  the
industry as a component of the solvent recovery  system, residual
solvent volatilized into the!room and  building air is lost  to the
process.
     One method for reducing;post-spinning  fugitive  emissions would
involve an,upgrading of ventilation systems serving  the fiber processing
lines in order to capture a larger portion  of the volatilized solvent.
Collected gas could then be Rented to  a control  device  such as  an
absorption scrubber or carbon adsorption system.  Enclosure of  the
spinning and post-spinning process line with  collected  gas  sent to  a
high efficiency control device would likely provide  the best  system of
emission reduction.
     Plant visits conducted during this NSPS  development,  have shown
that the use of enclosure systems on spinning cell exits  and  fiber
processing lines in the synthetic fibers industry is technologically
         c i ri po on          ;
feasible. *  '  '    Total enclosure systems  in  use  at  existing synthetic
fiber plants are attached to|or  comparatively near the  source of  the
pollutant.  Figure 4-5 shows:a spinning machine  with one  type of
enclosure system.  The enclosure functions  to reduce the  volume of
dilution air required to transport solvent-laden air from the workplace.
The vapor concentration can be controlled so  that the control equipment
size and cost are minimized and  control efficiency is optimized.
     Immediately following the spinning operation, fibers are moved to
and through various process operations.  The  fiber at and near the
point of exit from the spinning  cell contains substantial residual
solvent (as much as 30 percent by weight).  This solvent  evaporates
into the air surrounding the;process line.  As the solvent  evaporates,
the vapor-laden air (VLA) can be captured by  hooding or enclosures
surrounding that particular process operation.   The  VLA could be
subsequently moved via ductsj to  a control device (scrubber, carbon
bed, etc.) or to an atmospheric  discharge point.

                                 4-22

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ENCLOSURE
DOOR
                                                                                            ENCLOSURE
                                                                                             DOOR
                     \
                       BASE-OF
                    SPINNING MACHINE
            SIDE VIEW
                                                          PROMT VIEW
                Figure  4-5.  Spinning  Machine  With  Enclosure
                                         4-23

-------
     The amount of solvent which would be ultimately collected by  the
control device is a function of several parameters:
     1.  Control device (scrubber, carbon bed) efficiency,
     2.  Leakage of VLA from iducting,
     3.  Air in-leakage to ducting,
     4.  VLA flow rate, temperature, humidity, i.e., physical parameters
of the VLA itself,
     5.  Degree of enclosure (how much of the fiber processing line  is
enclosed by hooding; how much is open to room air),
     6.  Design of enclosure ^determines air in-leakage and dilution
of VLA), length of enclosure (determines residence time) and size  and
number of worker access doors,
     7.  Evaporation rate of solvent from the fiber (a function of
several complex parameters, the most significant of which are fiber
type, temperature, physical movement, and concentration of solvent
vapor around the fiber bundle).
     Ultimately, each enclosure should be as nearly a "complete enclosure"
as possible with minimum sized openings where access is required.  Any
large opening in the capture system should be equipped with a self-closing
door to minimize the amount of dilution air.  However, permanent
openings designed to allow air flow and openings used intermittently
for worker access are often necessary.  Covers for worker access
openings should be designed to prevent air in-leakage when closed.
                             t
The entire capture system should be designed in accordance with good
ventilation practice (e.g., Handbook of Ventilation for Contaminant
Control, McDermott; and Industrial Ventilation - a Manual of Recommended
                 91 on
Practice, ACGIH).  'JU
4.6.2  Safety Considerations of Enclosure Systems'
     The three requirements for an explosive mixture are fuel (solvent),
oxidizer (air), and heat.  Since the amount of solvent contained
within the fiber as it exits [the spin cell is process-dictated, that
                             I
value is considered a constant (not a variable for purposes of this
discussion).  The velocity arid amount of air into which the solvent
evaporates are variable quantities, up to the limits of the fiber  to
                             i
withstand the impinging air flow.  As important from a recovery standpoint
31
                                4-24

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is the limit on air flow posed by the cost of air/solvent vapor treatment
in the recovery device.  A compromise is therefore necessary between
the risk associated with higher concentrations, and the costs of
treating larger air volumes.
     The most significant factor in explosion/fire prevention within
the recommended enclosures is maintenance of the solvent concentration
at desired levels.  Estimates show the concentration within the enclosures,
that will result from application of the recommended control options,
will not approach the LEL for any of the solvents considered.  For
example, the flow rate of 15,000 cfm and evaporation rate of about
7 kg/hr of acetone will yield about 3,000 ppm or about  15 percent of
the LEL under normal conditions.  If this concentration is not exceeded,
the explosion risk is almost nil.  Whether the  concentration is allowed
to increase to near explosive levels is critical, however.  This can
be prevented by proper design and use of exhaust fans, dampers, monitoring
equipment, etc.  An appropriate combination of  automatic and manually
operated fail safe measures, plus effective supervision of the equipment
should prevent hazardous situations from occurring.
     Solvent-laden air streams which are transported to control equipment
are normally maintained at concentrations at or below  25 percent of
the lower explosion limit (LEL) of the solvent.  Although 25 percent
of the LEL is often regarded as the maximum allowable  solvent concentration,
insurance and safety requirements will sometimes permit even higher
solvent  concentrations.  The Handbook of  Industrial  Loss  Prevention
notes that flammable vapor  concentrations of up to  50  percent of  the
LEL may  be tolerated if approved continuous vapor concentration  indicator
controllers  are used.
     The monitors  should be set to first  adjust the inflow of dilution
air at  relatively  low  concentrations, then  activate alarms at higher
concentrations, and finally shut down the spinning  machines  when  unacceptable
levels  are reached.  Several monitors should be utilized  for redundancy
and added safety  margin.  At  some  concentration level, perhaps  near
the alarm level,  operator access doors  should  be opened,  either
automatically  or  manually when  the alarm  level  is  reached.   In  addition,
power for operation of the  exhaust fans  should be  received  from at
                                 4-25

-------
least two independent sources such  as  electrical  power  and  steam
turbines.  Nonelectrical meajns of purging  could  be  utilized as  well,
such as steam aspirators or air  pressure tanks which  could  evacuate or
force air/solvent vapors out of  the enclosed  areas.
     Another preventive measure  could  be the  installation of distribution
pipes and nozzles for blanketing the area  with either nitrogen  or
carbon dioxide when explosivb mixtures  are reached.   This would both
blanket the area and dilute the  potentially explosive vapors.   This
system would be effective for both  prevention of explosive  conditions
and extinguishing of fires once  started.   There  should  be some  means
of controlling the inert gas or  carbon  dioxide so that  employees  are
not overcome.
     The ignition of flammable vapors may  occur  as  a  result of  spark
discharge of static electricity.  Changes  may be generated  by friction
between surfaces such as fibprs  and guides, or even by  movement of  the
fiber through the spin cell atmosphere.  The  rotating metal  take-up
wheels moving against small Quantities  of  waste  fiber could also
generate a static charge or heat from mechanical  friction.   Protection
against these hazards should! begin  with determination of the locations
where static charges are likely  generated,  and installation or  use  of
means for gradual dissipation of these  charges without  spark discharges.
All metal parts, for example!, should be mutually grounded.   (Note that
water and steam pipes are unreliable for use  as  conductors  or grounds.)
     It has been shown that lexplosions  in  chemical  process  plants are
usually the result of nonroutine leakage of flammable materials.
Thus, prevention should incljude  strict  housekeeping and prompt  repair
of leaking lines, particularly lines containing  pure  solvents or
solvent/water mixtures, or spinning dope.   A  spill  of any of these
would quickly result in flammable air/vapor mixtures  above  or near  the
spill.
     There are other relevanjt factors bearing on explosive
characteristics.  Decreases in ambient  temperature  and  pressure reduce
the range of flammable mixtures  that will  ignite.   There is also
evidence that increases in filow  velocity will decrease  the  flammable
limits.  If the diluent air ris cooled,  the explosive  range  is narrowed
                                4-26

-------
(LEL increased and UEL decreased).  The conclusion  is  therefore  that
if the ventilation inlet air to the enclosures  is cooled, moved  rapidly,
and/or drawn out under negative pressure, the possibility of  ignition
will be reduced.  In addition, the reduction in  temperature would  have
the added effect of causing slower evaporation  of acetone from the
moving fibers.
     Still another important air conditioning parameter  from  a fiber
characteristic as well as safety standpoint is  humidity.  It  is  important
to keep a minimum of 55 to 60 percent relative  humidity, both to
reduce static discharge and to reduce breakage  due  to  brittle fibers.
     As a minimum, the design of the process and recovery systems,
particularly the enclosure systems, should consider all  the foregoing
preventive measures, and industry experience in  reducing the  risks of
explosive conditions as far as economically possible.  The equipment
and procedures must be able to function not only in normal service,
but especially during emergency or nonroutine periods.   Explosive
conditions may be avoided with proper and adequate  selection  of  monitoring
and control instrumentation and adequate supervision of  the process
and monitoring equipment.
     The use of capture/enclosure devices similar to those described
above, for use on synthetic fiber spinning and  processing lines, have
also been recommended in other studies regarding specific segments of
the fibers industry.  These studies have received considerable review
by the industry.  They include:
     •  Economic Impact Assessment for Acrylonitrile
          by Enviro Control, Inc., Contract No.  J-9-F6-0229,  February 21,
          1978, for Occupational Safety and Health  Administration
     •  U.S. Department of Labor Emission, Process,  and  Control
          .Technology Study of the ABS/SAN, Acrylic  Fibers, and NBR
          Industries, by Pullman Kellogg, Contract  No. 68-02-2619,
          April 20, 1979,. for ESED, OAQPS, U.S.  Environmental Protection
          Agency.
4.7  INCINERATION32'35
     An alternative means of reducing VOC emissions, other than  by
increasing the solvent recovery efficiency, is  incineration of the
                                4-27

-------
solvent vapor.  Incineration! control devices operate on the principle
of combustion, through oxidation of gas stream constituents into
(primarily) products of carbon dioxide and water.   Process exhaust
streams which flow into the incinerator will likely be below  25 percent
of the LEL.  Hence, to effectively accomplish combustion, fuel must  be
added to the diluted vapor before incineration occurs.  Devices which
add fuel to diluted vapor streams and  incinerate  the combined  stream
are referred to as afterburners.  Other energy needs within the plant
can often be supplemented by the heat  produced during combustion.  Two
types of afterburners may be used to reduce  process emissions, direct
flame (thermal) and catalytic oxidizers.
     Thermal incinerators consist of a mixing chamber designed to
provide contact between the [vapor-laden gas  stream  and the burning
flame, followed by a combustion chamber.  The efficiency  of a  thermal
afterburner is affected by the air-fuel-vapor concentration ratios,
residence time required for complete combustion,  and sufficient tempera-
ture to ensure complete oxidation of the  combustibles.  Burner type
and placement also determine thermal afterburner  efficiency.   Multi-jet
and mixing-plate burner types prove most  effective  in maximizing  flame
and vapor-laden air content.  Incomplete  combustion of gas constituents
may permit  carbon monoxide, aldehydes, or other  reactive  compounds  to
be exhausted from the unit.| Natural gas, LPG,  and  distillate and
residual fuel oils are used\ to fuel  afterburners  and create  the  potential
for reactive halogens, sulfur oxides,  and organic acids to be exhausted
into the atmosphere if low combustion  efficiencies  are encountered.
Figure 4-6  shows the design features of  a direct  flame afterburner.'
     The design of catalytic afterburners is similar to direct flame
(thermal)  units except that combustion is initiated through  use  of a
catalyst..  A  catalyst  is  a substance that changes the  rate of a  chemical
reaction without altering the composition of the  catalytic material.
Catalytic  afterburners employ a  solid  active surface' on which the
combustion  process occurs.  Preheated  process  gases are  directed
through a  heated catalytic bed,  usually  a honeycomb network  of platinum
or palladium, which promotes oxidation.   Thin layers  of  the  catalytic
metal  are  deposited on an inert  substrate of variable  shape.   The
36
                                 4-28

-------
                                                      FLAME SENSOR-


                                                   BURNER.


                                            REFRACTORY-


                                          INSULATION-


                         TURBULENT EXPANSION ZONE-


                                  STEEL SHELL —
                                                                            STRAIGHTENING

                                                                            VANES
         COOLIN6 AIR

       INDUCTION SYSTEM
                                                                   CAS SYSTEM
                                                                    control
                                                          -CONTROL PANEL
                                                          (roraot* optional)
                                             UNITIZED MOUNTING
                                          •SAMPLE PORT


                                    TEMPERATURE SENSOR
                      -BLOWER

                     -INSULATION
Figure  4-6.    Sectional  View  of  Direct-Flame Afterburner3
                                4-29

-------
                                37
catalytic material provides a large surface  area  containing  active
sites upon which the gas molecules can  react.   Catalytic  afterburners
thus require less fuel and operate at lower  temperatures  than  direct
flame types.
     Maintenance for catalytic systems  is  frequent.   Certain constituents
of the process gas stream such as polymeric  compounds  or  particulates
may not burn properly, causing a buildup on  the substrate and  thereby
deactivating the catalyst.  Various cleaning methods  to remove such
coatings will reactivate the catalytic  material.  The  catalyst may
also be deactivated through clirect reactions with phosphorous,  sulfur,
and heavy metals present in the effluent gas stream.   In  an  effort to
minimize operational problem?, inlet gas stream concentrations  are
usually limited to 25 percent of the LEL and ignition  temperatures
maintained between 540° to 650°C (1000  to  1200°F).  Figure 4-7
illustrates the use of catalytic incinerators for heat recovery.
     VOC control efficiencies of direct flame afterburners can  reach
98 percent; catalytic afterburner VOC control efficiencies are  reported
to be between 81 and 96 percent.    Effectiveness of  incineration
technology in reducing VOC emissions is dependent upon: the  vapor
ignition temperature; chamber size and  turbulence; effluent  flow rate;
as well as afterburner design.  Typical design  flow rates  for
                            i
direct-flame afterburner packages range from 250 to 50,000 scfm/unit,
while catalytic afterburners'are designed  to accommodate  flow  rates
ranging from 400 scfm to 40,000 scfm.   Custom-built units, capable of
handling larger flow rates, are available.   However,  industry-supplied
data indicate that conventional packaged designs are  suitable  for
treating typical process exhaust streams.
     Incineration is an emission control technique that could  be used
to reduce.VOC emissions from!the synthetic fibers industry.  Presently,
however, synthetic fiber facilities do  not utilize the option  of
incineration to control V.OC's.  Primarily  this  is because existing
control equipment was installed to recover increasingly expensive
solvent for the purpose of cost optimization.   Incineration  is  a
destructive method of emission control  directly opposing  solvent
reclamation efforts.  The results of a  study which examined  the economic
4-30

-------
                             01SCK1R6E TO ITHOSPHERE
                           'l
            RETURN TO OVEN-*
                              -P£BFOR«TEO PL«TE
                                      PREHEIT BUBNEBS
           Catalytic incinerator utilizing direct-
                      heat recovery
                                           •DISCHARGE TO ATMOSPHERE
           PERFORATED PLATE
           Catalytic  incinerator utilizing  indirect
                       heat recovery
Figure  4-7.   Catalytic Incinerators  Utilizing Heat Recovery
                                4-31

-------
feasibility of incineration as a VOC control technique in the synthetic
                             ;                     00 30
fibers industry appear to substantiate this claim.  '    In the report,
six individual incineration systems were analyzed to determine capital
and annual operating cost.  The six systems included three separate
cases; each case was analyzed for both thermal and catalytic Incinerators.
The Case 1 situation involved incineration with no recuperative heat
recovery.  Case 2 represented incineration with primary heat recovery
at an efficiency of 35 percent.  Case 3 involved the use of primary
heat recovery at 35 percent efficiency and secondary recovery at
55 percent efficiency.  The six incineration systems were then compared
with the cost of a low and high efficiency carbon adsorption system.
The result of the study indicated that the cost of incineration is
significant; and when compared with a solvent recovery system, such as
a carbon adsorption system, incineration does not appear to be an
economically viable control option for the synthetic fibers industry.
Other disadvantages to incineration include:
     •  Fuel  is continuously Burned regardless of whether the exhaust
stream is intermittent or has fluctuating concentrations;
     •  Incompletely combusted VOC's  including the auxiliary fuel may
be potent smog precursors;
     •  Secondary air pollutants  (NO  , SO , CO) present  in afterburner
                                    X    X
exhaust, may  contribute to air pollution problems;
     •  Low sulfur content fuels  are  recommended  for operation of
incinerators; however, these  fuels are expensive  and not always available.
     •  The energy impacts required to raise  the  contaminant air
stream to 1,500°F may be significant.
     •  Gas streams with very low VOC concentration may  require
significantly more fuel to achieve temperatures around  1,500°F.
4.8  EMISSION AND PROCESS TESTING
     Volatile organic compound  (VOC)  emissions were  the  principal  type
                             i
of air pollutant encountered  during the testing of emissions from
fiber producing plants.  These emissions result primarily from organic
solvents used during fiber producing  operations.   Processes tested
under the emission measurement program utilized either  dimethylformamide
 (DMF) or dimethylacetamide  (DMAc) as  the spinning  solvent.
                                 4-32

-------
     Baseline emission values have been determined by combining  and
reducing data obtained from a variety of sources.  By integrating
Information acquired through literature searches, EPA 114  responses,
plant surveys, and emission test data, mass balance calculations have
been performed.  For the purpose of determining a plant's  compliance,
there are two methods theoretically available for calculating  emissions:
direct measurement of emissions and indirect determination by  mass
balance.
     Two sites were chosen for field testing for direct measurement  of
VOC emissions.  One plant operated a dry spinning process,  whereas the
other plant operated a wet spinning process.  Vents and stacks were
identified and prioritized according to the relative amount of VOC's
emitted to the atmosphere.  In order to determine solvent  vapor
concentrations and distribution within enclosures such as  those  described
in Section 4.6, testing was performed at one plant that already  utilizes
this type capture technique.  Emission test reports have been  issued
and describe in full the testing procedures and methods employed (see
Appendices C and D).
     In addition to direct measurement of VOC's via field  testing, EPA
also obtained solvent use information from six different fiber plants
covering the previous 2 years (1979-1981).  The solvent use information
can be indirectly used to determine VOC emission rates, since  makeup
flow rates are exactly equivalent to the total of nongaseous losses
(as determined by prior actual measurements) and air emissions.  This
solvent use data is summarized in Appendix C.  The amount  of makeup
solvent is measured by totalizing flow meters, an inexpensive, simple,
and continuous method of indirectly determining VOC emissions.
4.9  SUMMARY
     A description of the solvent capture and recovery techniques
presently employed in the synthetic fibers industry was presented in
this chapter, and five techniques employed in the synthetic fibers
industry to recover solvent from wet, dry, and reaction spinning
processes were outlined.  They include gas absorption, gas  adsorption,
condensing, distillation, and enclosure and capture systems.
                                4-33

-------
     Table 4-2 summarizes the more common recovery process technologies
currently in use in the industry, along with the fiber types utilizing
these techniques.
                                 4-34

-------















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4.10  REFERENCES

1.   Moncrief, R.W.  Man-Made!Fibres.  Newnes-Butterworks.   London,
     Boston.  1975.           ;

2.   Air Pollution Engineering Manual.  Air  Pollution  Control  District
     County of Los Angeles.   U.S.  Environmental  Protection  Agency.
     Research Triangle Park,  N.C.   Publication  No.  AP-40.   May 1973.
     pp. 207-229.

3.   Radian Corporation. Control Techniques  for Volatile Organic
     Emissions from Stationary Sources.   U.S.  Environmental Protection
     Agency.  Research Triangle  Park,  N.C.   Publication No. EPA-450/2-78-022.
     May 1978.  pp. 70-83.

4.   Perry, R.H.  and C.H.  Chitton.  Chemical  Engineers' Handbook,
     Fifth  Edition.  McGraw-Hill Book  Company,  Incorporated.
     New York, New York.   1973.

5.   Control  Techniques  for Hydrocarbon  and  Organic Solvent Emissions
     from Stationary Sources.  U.S. Public Health Service.   Washington,
     D.C.   Publication No.  AP-68.  March 1970.  114 p.

6.   Report of the  Initial Plant Visit to Tennessee Eastman Company
     Synthetic Fibers Manufacturing Facility in Kingsport,  Tennessee.
     Prepared during Development of New  Source Performance Standards
     for the  Synthetic  Fibers Industry'.   December 13,   1979.

7.   Letter arid  attachments from Mohney,  W.K., Avtex Fibers,  Incorporated,
     to Manley,  R.9  Pacific Environmental Services, Incorporated.
     April  14,  1981.   Response to Section 114 information  request.

8.    Report of  the Phase II Plant Visit to Celanese Fibers  Company
     Celco  Acetate Fiber Plant in Narrows, Virginia.   Prepared during
     the Development of New Source Performance Standards for  the
     Synthetic  Fibers  Industry.   August 11, 1980.

9.    Letter and  attachments from  Pullen, J.C., Celanese Fibers Company, ,
     to Zerbonia, R.A.,  Pacific Environmental Services, Incorporated.
      July  3,  1980.  Response'to Section 114 information request  (Celco
      Acetate  Fiber Plant,  Narrows, Virginia).

 10.  Report of the Phase  II  Plant Visit to Celanese Fibers  Company
      Celriver Acetate Plant  in Rock Hill, South  Carolina.   Prepared
      during the Development  of New Source Performance  Standards  for
      the Synthetic Fibers  Industry.  May 28, 1980.

 11.  Letter and attachments  from  Pullen, J.C., Celanese Fibers  Company,
      to Zerbonia, R.A., Pacific Environmental  Services,  Incorporated.
      July 3,  1980.  Response to Section  114 information request  (Celriver
      Acetate Fiber Plant,  Rock Hill,  South  Carolina).
                                 4-36

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12.   Welters, E.  Process and Machine Technology of Man-made  Fiber
     Production.  International Textile Bulletin.  World  Edition.
     February 1978.   pp. 153-262.

13.   Memorandum and  attachments from Gladding, D.., Pacific  Environmental
     Services, Inc., to Grumpier, D., and Chaput, L.,  U.S.  Environmental
     Protection Agency.  November 3, 1981.   Impacts of Possible  Reduction
     of the Threshold Limit Value (TLV) for  Acetone on Cellulose
     Acetate Fiber Manufacturers.
14.   Bethes, Robert M.  Air Pollution Control Technoloc
     Reinhold Company.  New York, New York.  1978  p.  31
                                                            Van  Nostrand
15.   Hydrocarbon Pollutant Systems Study, Volume  I - Stationary  Sources,
     Effects and Controls.  U.S. Environmental  Protection  Agency.
     Research Triangle Park, N.C.  Publication  No. APTD-1499.  October
     1972.   377 p.

16.   Reference 3.  pp. 52-70.

17.   Reference 2.  pp. 189-198.

18.   Grant, R.M., M. Manes, and S.B. Smith.  Adsorption  of Normal
     Paraffins and Sulfur Compounds on Activated  Carbon.   AICHE  Journal.
     J3(3):403.  1962.

19.   Surface Coating of Metal Furniture.  Background Information of
     Proposed Standard - Draft EIS.  EPA 450/3-80-007a.  September
     1980.

20.   Trip Report.  Plant Visit to Globe Manufacturing  Company, Gastonia,
     North  Carolina.  September 16-17, 1981.

21.   McDermott, H.J. Handbook of Ventilation for  Contaminant  Control.
     Ann Arbor Science Publishers, Inc.  Ann Arbor, Michigan.  1976.
     368 p.

22.   Control of Volatile Organic Emissions  from Existing Stationary
     Sources - Volume I: Control Methods for Surface-Coating  Operations.
     U.S. Environmental Protection Agency.  Research Triangle  Park, NC.
     Publication No. EPA 450/2-76-028.  November  1976.   166 p.   ,

23.   VIC Manufacturing Company.  Carbon Adsorption/Emission Control  -
     Benefits and Limitations.  Minneapolis, Minnesota,  p. 7-8.

24.   Letter and attachments from Wieland, K. and  Waldrop,  R.,  Edwards
     Engineering Corp., to Manley, R., Pacific  Environmental  Services,
     Inc.  January 15, 1982.  Use of Condensers for Organic Vapor
     Recovery.

25.   Reference 3.  pp. 83-92.
                                4-37

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26.  Reference 4.  pp. 13-19 to 13-24.

27.  Memorandum and addendumifrom Manley,  R.,  Pacific  Environmental
     Services, Inc., to Grumpier, D., et.al.,  U.S.  Environmental
     Protection Agency.  October 2,  1980.   Capture  Efficiencies  of
     Enclosures and Impact on the NSPS  Development  for the  Synthetic
     Fibers Industry.

28.  Report of the Initial Plant Visit  to  DuPont  Corporation  May
     Plant, Camden, S.C.  Prepared during  development  of  New  Source
     Performance Standards for the Synthetic  Fiber  Industry.  April 29,
     1980.

29.  Report of the Plant Visit to American Enka Company Viscose  Rayon
     in Lowland, Tennessee.  Prepared during  development  of New  Source
     Performance Standards for the Synthetic  Fiber  Industry,,  January  22,
     1980.'

30.  Industrial Ventilation:  A Manual  of  Recommended  Practice,  Twelfth
     Edition.  American Conference of Governmental  Industrial Hygienists.
     Committee on Industrial Ventilation.   Lansing, Michigan.   1972.
     337 p.                  :

31.  Memorandum and attachments from Manley,  R.,  Pacific  Environmental
     Services, Inc., to Grumpier, D. and Chaput,  L., U.S. Environmental
     Protection Agency.  December 8, 1981.   Discussion of Potential
     Safety (Explosion) Problems Associated  with  the Use  of Enclosures.
                             i

32.  Report, of Fuel Requirements, Capital  Cost and  Operating  Expense
     for Catalytic and Thermal Afterburners.   CE  Air Preheater  Industrial
     Gas Cleaning Institute.  Stamford, Conn.   EPA  Report No. EPA-
     450/3-76-031.  September 1976.

33.  Memorandum and addendum from Mascone,  D.,  EPA  to  Farmer, J.,
     EPA/CPB, Office of Air Quality  Planning  and  Standards.   June 11,
     1980.  Thermal Incinerator Performance  for NSPS.

34.  Reference 2.  pp. 437-531.

35.  Reference 3.  pp. 24-52.

36.  Large Appliance Surface Coating Industry - Background  Information
     for Proposed Standards. •• U.S. Environmental  Protection Agency.
     Research Triangle Park, N.C.  June 6,  1980.  p. 4-8.

37.  Reference 36.  p. 4-9.  ;

38.  Air Pollution:  Control Techniques for  Hydrocarbon and Organic
     Solvent Emissions from Stationary  Sources.   NATO  Committee  on the
     Challenges of Modern Society.   Brussels,  Belgium.  October  1973.

39.  Memorandum and attachments from Zerbonia,  R.A., Pacific  Environmental
     Services, Incorporated, to Docket  No.  A-80-7.  November  10,  1981.
     Control Costs and Regulatory Alternative Development for Reaction
     Spun Spandex Fiber Process (Carbon Adsorption  vs.  Incineration).
                                4-38

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                  5.0  MODIFICATION AND RECONSTRUCTION

5.1  BACKGROUND
     Emission limitation standards promulgated under Section lll(b) of
the Clean Air Act apply to all facilities within the regulated  source
category that are constructed, modified, or reconstructed  after the
date of proposal of the standards.  Uncertainties may arise as  to  the
determination of whether any existing facility has been  "modified" or
"reconstructed."  These issues are addressed in Sections 60.14  and
60.15, respectively, of Title 40 of the Code of Federal  Regulations,
which defines conditions under which an "existing facility" may become
                                    1 2
subject to standards of performance. *   An "existing facility,"
defined in 40 CFR 60.2(aa), is an apparatus of the type  for which  a
standard of performance is promulgated and the construction or  modifi-
cation of which was commenced prior to the date of proposal of  that
standard.
     The following discussion examines the applicability of the
modification/reconstruction provisions to any facilities for the
manufacture or processing of synthetic fibers in existing  fiber manufac-
turing plants, and details conditions under which existing facilities
could become subject to standards of performance for new stationary
sources.  The enforcement division of the appropriate EPA  regional
office should be contacted regarding any questions on modification or
reconstruction applicability.
5.2  40 CFR PART 60 PROVISIONS FOR MODIFICATION AND  RECONSTRUCTION
5.2.1  §60.14 Modification
     §60.14 states:
     ".  . ., any physical or operational change to an existing  facility
     which results  in  an increase in the emission rate  to  the  atmosphere
     of  any pollutant  to which a  standard applies shall  be considered
                                   5-1

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                                     ,,1
     a modification within the meaning  of  Section  111  of  the  Act.
     Upon modification, an existing facility  shall  become an  affected
     •facility for each pollutant to which  a standard applies  and  for
     which there is an increase in the  emission  rate to the atmosphere.
          Paragraph (b) clarifies what  constitutes  an  increase  in  emissions
in kilograms per hour and the procedures for  determining  the  increase
including the use of emission factors,  material  balances,  continuous
monitoring system and manualiemission tests.   Paragraph (c) affirms
that the addition of a facility subject to performance standards  to  a
stationary source does not make any other  facility  within that  source
subject to standards of performance.  Paragraph  (f) simply provides
for superseding any conflicting provisions.
     Paragraph (e) lists cerjtain physical  or  operational  changes  which
by themselves are not considered modifications.  These changes  include:
     (1)  Facility maintenance, repair, and replacement which are
determined by the Administrator to be routine.
     (2)  An increase in the!production rate  not requiring a  capital
expenditure as defined in §60.2(bb).
     (3)  An increase in the!hours of operation.
     (4)  Use of an alternative fuel or raw material  if prior to  the
standard, the existing facility was designed  to  accommodate that
alternate fuel or raw material.   (Conversion  to  coal,  as  specified in
§lll(a)(8) of the Clean Air  Act,  is also exempted.)
     (5)  The addition or use of  any system or device  whose primary
function is the reduction of air  pollutants,  except when  an emission
control system is removed or| replaced by a system  considered  to be
less efficient.
     (6)  The relocation or  change in ownership  of an  existing  facility.
     An increase in the production rate of an existing facility is
designated as a modification only  if there is an increase in  the
emission rate and the total  jcost  necessary to accomplish  the  change
constitutes a "capital expenditure."  Capital expenditure is  the
product of the facility's original cost, as defined by Section 1012  of
the  Internal Revenue Code, and  the appropriate "annual asset  guideline
5-2

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repair allowance percentage" (AA6RAP).  The 1978 edition of  Internal
Revenue Service Publication 534  sets the AA6RAP for  the synthetic
fiber manufacturing industry at 16 percent.  Therefore, if the  total
cost of increasing the production rate of an existing  synthetic fiber
manufacturing facility exceeds 16 percent of the facility's  original
cost, and if this change causes increased emissions,  the facility
would be considered to have been modified.
5.2.2  §60.15 Reconstruction
     §60.15 states:
     "An existing facility, upon reconstruction, becomes an  affected
     facility, irrespective of any change in emission  rate.   'Recon-
     struction' means the replacement of components of an existing
     facility to such an extent that:  (1) the  fixed  capital  cost of
     the new components exceeds 50 percent of the  fixed capital  cost
     that would be required to construct a comparable  entirely  new
     facility, and (2) it is technologically and economically feasible
                                                              2
     to meet the applicable standards set forth  in this part."
     Reconstruction, as defined in 40 CFR 60.15, occurs when  the fixed
capital cost of replacement components of an existing  facility  exceeds
50 percent of the fixed capital cost that would  be required  to  construct
a comparable entirely new facility, and it is technically and economically
feasible to meet the applicable standards.  After  receiving  notice
from the owner or operator as required under 40  CFR 60.15(d), the
Administrator will determine whether the proposed  replacement constitutes
a reconstruction.  In accordance with 40 CFR 60.15(f),  the Administrator's
decision is based upon the following:  (1) the  fixed  capital  cost of
the replacement components, (2) the estimated life of  the facility,
(3) the extent to which the components being replaced  cause  or  contrib-
ute to the emissions from the facility, and (4)  any economic  or
technical limitations on compliance that are inherent  in the  proposed
replacements.  Investigation of the synthetic fibers manufacturing
industry does not reveal any history of changes  that ^ould render a
line subject to the reconstruction provision.   Repair  or rebuilding of
an existing facility where costs would exceed 50 percent of  the cost
of replacing the facility would be unusual.
                                  5-3

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5.3  APPLICABILITY TO SYNTHETIC FIBER MANUFACTURING PLANTS
5.3.1  General
     Investigation of the processes used by manufacturers of synthetic
fibers does not reveal any particular practice which can be readily
classified as a modification or reconstruction.  A number of potential
actions have been identifiedjwhich, under certain circumstances, may
indeed be so classified.  The following sections are concerned with
alterations common to those process facilities which would be affected
by the application of the modification and reconstruction provisions.
In Sections 5.3.2 and 5.3.3, other practices specific to each process
facility are discussed.
5.3.2  Modifications
     Investigation of the processes used by manufacturers of synthetic
fibers does not reveal any particular practice, other than the direct
addition of production equipment, which can be readily classified  as a
modification.  There are, however, a number of routine alterations
common to synthetic fiber production facilities which would not likely
be affected by the application of the modification provision, even
though many of these changes|can affect solvent emissions, some positively
and some negatively.  Some examples are:  changes in fiber properties
                             i
such as denier; variation injdrawing, washing, and stretching operations;
routine alterations in co-polymer to co-polymer and polymer to solvent
ratios; changes in additives and finishing oils; and normal variation
in spin and wash bath temperatures.  Any increase in VOC emissions
effected by these routine changes in the manufacturing process would
not be considered a modification since they are considered to be
within the normal operation of a facility as designed.
     5.3.2.1  Production Rate Increases.  An increase in production
rate at an existing facility|is not in and of  itself a modification
under §60.14 if the increase!can be accomplished without incurring a
capital expenditure at the affected facility.*  If a capital expenditure
*Capital expenditure is defined as "an expenditure  for  a  physical  or
 operational change to an existing facility which exceeds  the  product
 of the applicable annual asset guideline  repair allowance percentage
 specified in the latest edition of  Internal  Revenue  Service Publica-
 tion 534, and the existing facility's basis,  as defined  by Section 1012
 of the Internal Revenue Code."  (40 CFR 60,  Sect.  60.2[bbj).
                            :      5-4

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less than the product of the most recent  annual  asset  guideline  repair
allowance published by the Internal Revenue Service  (Publication 534)
and the facility's basis is made to increase  capacity  at  an  existing
facility and also results in an increase  in emissions  of  a regulated
pollutant to the atmosphere, a modification is not considered  to have
         A
occurred.   Any fiber manufacturing plant  is  designed  for a  maximum
production capacity, which is directly related to the  maximum  capacity
of the spinning cells and the number of these spinning cells or  cabinets.
Process stages other than spinning (e.g.,  dissolving/blending  or
drying) may have capacities which exceed  the  total plant  capacity for
finished fiber.  Thus, an increase in the  production capacity  of a
plant is possible without a capital expenditure  if only those  facilities
which limit fiber production (de-bottlenecking)  are modified.  For
example, an increase in the plant production  capacity  might  be
accomplished by changing from batch processing to continuous processing
or the addition of spinning cabinets (or  spinnerets).  If the  additional
line(s) were part of a facility for which  NSPS are established,  it
would be subject to NSPS if the addition  caused  an increase  in VOC
emissions and if the capital expenditure  criteria were met.
     5.3.2.2  Change in Raw Materials.  A  modification in the  polymer
and/or co-polymer introduced into the process will likely have a minor
effect on the solvent (VOC) emissions.  The change in  emissions  would
probably not be measurable, and the overall effect would  be  negligible.
Changes in solvent use practices may result in a rise  of  the VOC
emission rate from fiber manufacturing facilities.  One possible
change would be an increase in the volatility of the solvent caused by
temperature increases.  This would result  in  an  increase  in  the  quantity
of VOC emitted per unit of product.  Another  change would be the use
of solvent with a lower boiling point, although  this change  of solvent
within a plant is not common in the industry.
     Another possible change would be to  increase the  ratio  of solvent
used per unit of product.  This change might  be  necessitated for
desired product characteristic changes.  This would create an  additional
load on the solvent recovery system while  maintaining  constant product
                                  5-5

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output.  Additionally, increasing solvent used  per unit  of  fiber
produced would increase costs of solvent recovery and  cost  per  unit  of
fiber.
     A further change which would affect VOC emissions would  be a
change in water (or other solvent) content  of the primary solvent,
thus altering the boiling pojint of the mixture.  This  is more likely
to actually occur within the|  industry, although the  net  change  in  VOC
emission would be very small>
     These changes would not!  likely be considered to be  modifications
and would not cause the facility to be subject  to the  standard(s),
because the changes primarily involve a switch  in raw  material  which
the facility was designed to  accommodate.
     5.3.2.3   Alternative Fuel.  The use of an alternative fuel would
not be considered a modification if the existing facility were  designed
to accommodate the alternative.
     5.3.2.4  Addition of a System to Control Air .Pollutants.  The
addition or use of any system or device whose primary  function  is  to
reduce air pollutants, excepjt the replacement of such  a  system  or
device by a less efficient one, is not by itself considered a modi-
fication under §60.14.  For example, the replacement of  a relatively
inefficient scrubber with a fnore efficient  scrubber  in an existing
installation, for the purposje of improving  solvent recovery (solvent
that would otherwise be emitted to the atmosphere) would not be considered
a modification under §60.14(e)(5).
     5.3.2.5  Maintenance, Repair, and Replacement.  Maintenance,
repair, and component replacement which are considered routine  for a
source category are not considered modifications under §60.14(e)(1).
An increase in emissions is Inot expected to occur as a result of
normal maintenance or replacement of fiber  production  components.
     Routine maintenance would  involve periodic cleaning, replacement
                            i
of parts, and lubrication of  moving parts.   Routine  maintenance should
not have any noticeable effect on emissions, since VOC is introduced
to the system only when the process is in operation.
     Several components can be expected to  require replacement  as  a
matter of routine due to the  unit being in  continuous  service for  long
periods of time.  These components may include  spinneret heads, fiber
                                   5-6

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guides, scrubber nozzles, and drive gears.   Replacement with  equivalent
components should not affect emissions and would  be  considered  exempt
under §60.14(e)(l).
     5.3.2.6  Equipment Relocation and Change  of  Ownership.   Relocation
of equipment would not constitute a modification.
     5.3.2.7  Removal or Disabling of a  Control Device.   The  intentional
removal or disabling of any emission control component of an  existing
installation which would cause an increase of  emissions would be  a
modification.  An existing facility that is  modified becomes  an affected
facility subject to the NSPS.
5.3.3.  Reconstruction
     The term reconstruction means the replacement of components  to an
extent that the fixed capital cost of the new  components  exceeds
50 percent of the fixed capital cost that would be required  to  construct
a comparable, entirely new facility  (40  CFR  60.15).   Repair  or  rebuilding
of an existing facility at a cost exceeding  50 percent of the cost of
an entirely new facility is unusual.  There  are no general conditions
which can be classified as a reconstruction.   As  stated previously,
production rate increases are usually met by adding  new lines to
existing facilities rather than rebuilding lines  in  existing  facilities.
The one common exception is conversion of cellulose  acetate  textile
yarn capacity to filter tow capacity.  Determination of whether any
repair or rebuilding activities constitute reconstruction must  be made
by the Administrator on a case-by-case basis.
     If a previously closed plant were to reopen,  it would not  be
subject to NSPS unless one or more of the facilities for  which  standards
had been promulgated were altered sufficiently to meet reconstruction
criteria.  Then, only those facilities which had  been altered and for
which standards exist would be subject to NSPS.
     Determination of reconstruction is  based  on  the capital  cost of
all new construction and other technical  and economic considerations.
The Administrator will consider if it is technically and  economically
feasible to meet the applicable standards in making  any reconstruction
determination.  For synthetic fiber production facilities, retrofitting
solvent recovery equipment to existing plants  can pose certain  problems.
                                   5-7

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The amount of physical space .necessary to  install ventilation  and
ductwork to capture solvent from process lines  is a  definite constraining
factor.  Equipment and personnel must be able to move  down  process
line aisles without being hindered; therefore,  installation of enclosures
at some existing facilities may not be possible without  a complete
reconstruction of the entire spinning area.
     Also, the cost of installing a control  system  in  an existing
plant is greater .than the cost of the systan for a new facility with
the same exhaust gas parameters because of special design considerations.
In retrofitting systems, additional costs may be encountered because
of such items as demolition requirements, crowded construction working
conditions, scheduling construction activities  with  production activities,
and longer inter-connecting piping.  These constraints must be taken
into account when costing the retrofitting of recovery equipment at
synthetic fiber plants.  Availability of space, additional  ducting,
                             i
and additional engineering mijst also be considered.
     Configuration of equipment in the existing plant  governs  the
location of the control system.  Depending on process  or stack location,
long ducting runs from ground level to the control device,  stack,  and
reprocessing equipment may be required.  Costs  may  increase considerably
if the control equipment must be placed on the  roof  and  requires steel
structural support.  It is estimated that  rooftop installation can
double the installation costs.
5.3.4  Cellulose Acetate Filament Production Change  to Filter  Tow
       Production
     An alteration in cellulose acetate production which would possibly
qualify as modification or reconstruction  is the change  from cellulose
acetate filament production to cellulose acetate filter  tow production.
The changes necessary to alter a given filament process  line to permit
filter tow production would be the removal of bobbin winding equipment
and the addition of one or more fiber crimpers  arid dryers.  Also,  a
finishing step would be added (prior to the  crimping step)  to  provide
desired fiber characteristics.
     The spinning step would |be essentially  unchanged, and  of  the
                             \
total VOC released., most of the volatilized  VOC is generated at this
                                   5-8

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step.  Therefore, the changes in the post spinning processing  steps
will affect only the residual solvent content of the fiber after the:
spinning step.  Whereas VOC was released relatively slowly into the
room air from the bobbins, containing filament yarn, the filter tow
process line addition of a dryer should cause a major  portion  of the
solvent to be released in the heated drying  area, which would  be more
easily collected and controlled.  The total  solvent ultimately released,
however, would be essentially the same in both cases;  only the rate of
release from a given mass of fiber would be  changed, if the  dryer were
uncontrolled.
                                   5-9

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5.4  REFERENCES              ;

1.   U.S. Environmental Protection Agency.   Code  of  Federal  Regulations.
     Title 40, Protection of Environment, Section 60.2(h),  Definitions.
     Washington, D.C.  Office of the  Federal  Register.   Revised  as  of
     July 1, 1977.  p. 6.

2.   U.S. Environmental Protection Agency.   Code  of  Federal  Regulations.
     Title 40, Protection of Environment, Section 60.15,  Reconstruction.
     Washington, D.C.  Office of the  Federal  Register.   July 1,  1977.
     p. 18.

3.   Tax Information on Depreciation.   U.S.  Department  of the Treasury.
     Internal Revenue Service.  Washington,  D.C.   Publication 534.
     1978. .p. 29.

4.   Standards of Performance for New Stationary  Sources.  Subpart  A,
     40 CFR 60.15 (44 FR 55173).
                                   5-10

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             6.0  MODEL PLANTS AND REGULATORY ALTERNATIVES
     Model plants are parametric descriptions of the types of plants
that, in EPA's judgment, will be constructed, modified, or reconstructed.
The model plant parameters form the basis for estimating the environmental,
economic, and energy impacts associated with the application of  the
regulatory alternatives to the model plants.  Regulatory alternatives
are ways in which EPA could regulate emissions from solvent-spun
synthetic and semisynthetic fiber manufacturing plants.  This chapter
will define the model plants and identify the regulatory alternatives
as applied to synthetic fiber manufacturing plants..
6.1  MODEL PLANTS1"6
     The model plants chosen to represent the portion  of the synthetic
fibers industry under consideration for new source performance standard
(NSPS) development are described in this chapter.  This study concentrates
on the production processes which involve the spinning  (extrusion) of
the fiber from a solution of polymer or prepolymer and  organic solvent(s).
     All fiber spinning processes share certain fundamental similarities.
Basically, the object is to extrude a liquid or semi-solid polymer in
a desired cross section and then solidify it before mechanically
taking it up with a collection device.  In most processes the solid
fiber is subjected to further mechanical processing to  enhance its
properties; in others, the fiber is taken up essentially as a finished
product.  Those broadly identifiable process stages which are common
to all solvent-spun synthetic fiber processes include:  (1) preparation
of the spinning solution.  In this stage, polymer is dissolved in an
organic solvent; the solution is blended with additives and filtered
to complete the preparation of the dope for spinning.   (2) Spinning of
the fiber, that is, the actual formation of the fiber  filaments.
Polymer solution (or dope) is forced or extruded through a device
called a spinneret to create the fiber.  (3) Processing of the
                                 6-1

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formed fibers.  This might include lubrication, washing,, drying,  heat  .
setting, finishing, or crimping.   (4) Solvent  recovery.  Because  of
the large amounts of sol vent |used  (a pound of  polymer  is typically
dissolved in 2 to 3 pounds of solvent), the economics  of the  industry
require that almost all of the solvent used in dissolving  be  recovered
for reuse.  Typically, solvent is  recovered most efficiently  and
economically at the spinning step  from the spin-cells  or spin baths
into which polymer solutions are extruded.  About 94 to 97 percent of
the solvent used is recycled directly from the spinning step  alone.
Thus, a primary solvent recovery system is an  integral part of all
solvent spinning processes.  iFigure 6-1 presents a general iz:ed process
flow diagram illustrating these common production stages.
     Beyond the similarities, there are many differences among processes.
Besides having a stable commodity  fiber-producing portion, the industry
is also comprised of a relatively  dynamic specialty fiber-producing
portion, into which new fiber types and production, methods are frequently
being introduced.  Still other solvent-spun types are  being produced
at pilot scale levels, and may or  may not expand to full production
(solvent-spun rayon, for example).  Consequently, production  parameters,
such as fiber spinning rates, processing sequences, and polymer/solvent/
fiber processing ratios that ;vary  from one fiber producer  to  another
and sometimes within each plant lead to a wide variety of  fiber types
and production methods for which model plants  could be developed.
     Thus no single model plant could adequately characterize the
organic solvent-spun synthetic fibers industry, since  each synthetic
fiber manufacturing process is unique.  It would be nearly impossible
to develop a model plant and |associated economic analysis  for each
conceivable fiber type.  Therefore, several model plants were developed
such that any organic solvent-spun fiber process (currently existing
or unknown) could be technically represented by one of them,,
     This chapter presents five model plants and two basic fiber  types
for technical analysis.  The five  model plants were developed to
represent the differences in^spinning operations due to resin type,
the spinning processes, and the fiber processing stages subsequent to
the spinning step.  Selection of specific model plant  operating parameters
                                 6-2

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were based on published literature,  information obtained during  plant
visits, and industry responses to  EPA  requests for  information.   This
information, as well as material balance  calculations  and  EPA-conducted
emission tests, was used to develop  baseline  emission  factors.
     The model plants were selected  to be  representative of  basic
organic solvent-spun manufacturing processes  and  not  individual  fiber
plants.  However, in order to provide  a basis for economic analysis,
data regarding fiber type and spinning solvent were assigned to  each
model plant.  In this regard.the model  plants represent wet-spun
acrylic, dry-spun acrylic, dry-spun  modacrylics,  dry-spun  acetate
filter tow, and dry-spun acetate filament  and staple.  Model  plants
were then developed as parametric  descriptions of the  types  of plants
that in EPA's judgment are most likely to  be  constructed,  modified, or
reconstructed.  The model plant parameters  are summarized  in Table  6-1.
     As noted above, the model plants  can  be  classified as representative
of two basic fiber types:  acrylic and modacrylic fibers,  which  cover
all fibers consisting of at least  85 percent  and  35 percent  polymerized
acrylonitrile, respectively; and cellulose  acetate  fibers, which cover
                            i
all cellulosic fibers having a percentage  of  acetylation of  15 percent
or greater (includes triacetate).
     During the course of this study,  model plants  were also developed
to characterize spandex fibers.  Spandex  is a manufactured fiber in
which the fiber-forming substance  is a long chain synthetic  polymer
comprised of at least 85 percent of  a  segmented polyurethane.  Spandex
is manufactured with two different processes  domestically; one,  a
reaction-spinning process, is a substantially different process  than
any used for other fiber types by  any  manufacturer  in  the  U.S.   The
second process used in the production  of  spandex  is the conventional
dry-spinning process which in some respects is similar to  that used
for acetate textile yarn; the fiber  is dry spun and immediately  wound
onto take-up bobbins, then twisted or  processed in  other ways.   In  the
development of the model plants for  these spandex processes, it  was
not possible to identify technically demonstrated or  economically
viable methodology that conclusively reduced  emissions (or improved
solvent recovery) over existing baseline  conditions.   There  are  no
more stringent control optiojns or  regulatory  alternatives  available

                                 6-4

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for these fiber processes.  This precludes the need for the development
of an economic analysis for the spandex processes at this time.
Therefore, the model plants and related information regarding the
                               I
spandex processes were not included in this chapter of the BID but
                               ;                       7-13
have been placed in the public idocket for examination.
     It should be noted that in all model plant cases a solvent recovery
system is included as an integral part of the process.  This solvent
recovery system is essential for the economic operation of all solvent-spun
synthetic fiber production facilities.
6.2  REGULATORY ALTERNATIVES14729
     The purpose of this section is to define various regulatory
alternatives or possible courses of action EPA could take to reduce
                               i
VOC emissions from the synthetic fibers industry.  The regulatory
alternatives were developed following the study of the synthetic
fibers industry and the available control techniques.  Section 111 of
the Clean Air Act, as amended, requires that standards of performance
reflect the degree of emission!control achievable through application
of the best demonstrated technological system of continuous emission
reduction which (taking into consideration the cost of achieving such
emission reduction, any nonair[quality health and environmental impact,
and energy requirements) has been adequately demonstrated.
     The most effective emission control technology currently used in
the industry involves capture of a large portion of the solvent vapor
generated during fiber manufacture by enclosing entire segments of the
process line.  The enclosures Were originally designed and constructed
in such a way as to minimize infiltration of solvent vapor into room
air in order to prevent worker exposure as well as minimize the capture
and unnecessary treatment of uncontaminated room air.  This technology
(referred to as Control Option A) can be applied to corresponding
process stages in all wet and dry solvent-spun fiber manufacturing
facilities.  When applied to process stages which typically emit  the
largest amounts of solvent vapor (e.g., spin cell exits or fiber
dryers), emission reductions from 31 to 47 percent below  baseline  are
achieved.  (Baseline refers to1those emission levels which are expected
to occur in the absence of  additional control.)  Furthermore, the  technology
                                  6-6

-------
can be extended to additional processing points (e.g., washing, drawing,
crimping, etc.) to arrive at a more stringent control level for these
facilities (referred to as Control Option B).  An emission reduction
of 60 to 76 percent beyond the baseline emission rate is expected
using the extended control enclosure systems.  Figures 6-2 and 6-3
present generalized schematics depicting these control options.  In
addition to solvent recovery, the plant can also indirectly control
worker exposure t'o solvents and monomers with low threshold limit
values (TLV's).  Capture systems are not expected to  interfere with
the normal processing of the formed fiber or create any unusual operational
or safety problems.
     A different approach which has the potential of  achieving similar
levels of emission control (solvent recovery) has also been demonstrated
in the fibers  industry.   In short, the system uses a  plant ventilation
or air management scheme in which air for the (post spinning) fiber
take-up room is taken from the dope preparation and fiber processing
areas.  A fraction of the take-up room air is then used as spin cell
evaporation gas and is subsequently sent to solvent recovery  (carbon
adsorption).   Another fraction of the fiber take-up room air  is used
to dilute the  high concentration process gas sent to  solvent  recovery.
Since the level of control is dependent upon the amount of take-up
room air sent  directly to carbon adsorption, it is possible to achieve
emission reductions similar to those involving the use of enclosures
through optimization of the volume of room air treated.  The  air
management system is used because the post spinning process steps  for
this fiber type are somewhat unique.  The technology  is feasible
because the high Threshold Limit Value  (TLV) for the  solvent  (acetone
at a TLV of 1,000 ppm) allows the vapor concentration in the  fiber
extrusion (or  take-up) room to reach a level that can be effectively
treated.  Some producers  also use this control system with a  combination
of solvents.   One solvent is used to produce one particular fiber  type
and another solvent or combination of solvents is used to produce  a
second fiber type within  the same buildings.  A mixture of volatilized
solvents  is captured and  sent to  a single control or  recovery device.
The individual solvents are  then separated in the distillation stage.
The only operational criteria for use of the air management scheme  are

                                  6-7

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that each solvent be present at a concentration suitable for capture
and that individual solvent TLV'si are not exceeded.  A significant
reduction in solvent TLV would likely restrict the use of  this  type of
control scheme; the alternative would be the use of  an enclosed winding
or take-up area.
     During the investigation of the synthetic fibers industry, it was
determined that within the acrylic fibers segment of the industry
there are manufacturing processes that do not  involve the  use of an
organic solvent.  Although a viable control option for some plants,
this inorganic solvent production process was  not considered applicable
to the entire fibers industry.  There are no readily identifiable
inorganic solvent processes available for some acrylic or  modacrylic
fibers; acrylic fibers manufactured using an organic solvent spinning
process cannot be reproduced exactly using  inorganic processes.  Also,
inorganic processes are available for other fiber types, such as
cellulose acetate.
     There were also other reasons for eliminating  its consideration
as a control option for the proposed standards.  While the inorganic
process would result in an almost complete  elimination of  solvent  VOC
emissions, it would also generate a significant water pollution problem.
Further, the inorganic solvent process  (or  portions  of the process)  is
under patent, and a number of complex legal and economic issues could
be raised if the proposed standards effectively forced a company to
use a specific process that may be owned and protected by  a competitor.
The mutual competitive positions of the several acrylic fiber  producers
would be substantially altered, and their customers  (textile firms,
carpet manufacturers, etc.) would be forced to alter their processes
and products to accommodate whattwould  in fact be different products.
The acrylic fibers produced using the large variety  of processes have
certain specific but different characteristics that  are well  known and
expected by the purchasers for quality  control reasons.   For  these
reasons, the inorganic solvent process  is not  considered  a control
option available to all segments 1 of the synthetic  fibers  industry  and
was not used as a  basis for any regulatory  alternative.
                                  6-10

-------
     Table  6-2 presents  baseline emissions and summarizes the total
VOC  emissions from  each  model  plant.   Also presented are the emission
rates  and percent emission  reduction  associated with Control Options A
and  B.
     The baseline controlled  model  plants  and Control  Options A and B
provide the basis for  three regulatory alternatives available to EPA
for  regulation of VOC  emissions  from  wet and dry solvent-spun fiber
plants.  The three  alternatives  are based  on emission  control techniques
representative of three  distinct levels of control.  Table 6-3 summarizes
these  alternatives  and the  control  options available to the industry
to achieve  each level.
     Alternative I, referred  to  as  baseline, is equivalent to no
additional  regulatory  action.  For  this alternative, VOC emission
levels would be the same as those currently achieved.   It is important
to note that there  are no State  or  local emission  regulations which
apply  specifically  to  the production  of man-made fibers, nor is there
a Control Techniques Guideline (CTG)  recommended emission limit.   Of
the  eight States containing fiber production facilities, most employ a
ceiling or  guideline regulating  VOC's  which is  similar to California's
Rule 66.  Economic  incentives  rather  than  regulatory requirements,
however, dictate recovery of  the solvents  used  in  the  processes.
Therefore,  the VOC emission levels  represented  in  Alternative I (with
the exception of Model Plant  2)  reflect typical  industry control
practices rather than  levels  imposed  by regulations.   Baseline control
for Model Plant 2 reflects  expected or  average  control  levels.   A new
dry-spun acrylic manufacturing facility might not  necessarily control
solvent VOC emissions to  the extent now controlled  by  the only current
dry-spun acrylic manufacturer.
     Alternative II is based on  Control  Option  A and requires the use
of efficient vapor capture  systems  for  process  stages  other  than  the
actual  spinning step (i.e., spin  cell  exits  and  dryer  exhausts)  or .the
recirculation of a portion  of room  air  to  the process.   Regulatory
Alternative III is based  on Control  Option  B which  extends  the capture
and collection systems to additional processing  points  (e.g.,  washing,
drawing, crimping, heat  setting,  etc.)  in  the case  of  line  enclosures
and to increased air volumes in  the case of  air  management.

                                  6-11

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6.3  ACRYLIC FIBER MODEL PLANTS: AND  REGULATORY ALTERNATIVES30"40
     Polyacrylonitrile resins used to make  acrylic  and modacrylic
fibers are produced by suspension or solution polymerization.   Either
batch or continuous reaction modes may be employed,  and  either  wet  or
dry spinning may be used to form the fibers.  In  addition,  a variety
of spinning solvents are used by industry.  These include organic
solvents such as dimethylformamide (DMF), dimethylacetamide (DMAc)  or
acetone and aqueous solutions of acids or salts such  as  zinc chloride
and sodium thiocyanate.
     In an attempt to accurately represent  the acrylic fibers  industry
through definition of model plant parameters, three  separate model
plants are presented.  The three model plants are characterized according
to the process techniques presented  in Table 6-4.

              Table 6-4.  ACRYLIC FIBER  PROCESS TECHNIQUES
Model
Plant   Polymerization
Number      Medium
                         Polymerization
                           Operation
Spinning       Spinning
Process        Solvent
1
2
3
Suspension
or
Solution
Suspension
or
Solution
Suspension
Batch
or
Continuous
Batch
or
Continuous
Continuous
Wet
Dry
Dry
Organic
Organic
Organic
solvent,
solvent,
solvent,
DMAc
DMF
Acetone
6.3.1  Model Plant 1
     6.3.1.1  Regulatory Alternative  I, Baseline  Control.   This  plant
is characterized by use of suspension or solution  polymerization  and
wet spinning with an organic solvent.  The model  plant  block  or  schematic
diagram is presented in Figure 6-4; Table 6-5  presents  tha  relevant
model plant parameters.  Major emission points, for wet spun  acrylic
fibers, are the filtration, spihning, washing, drying,  and  crimping
steps where solvent is volatilized  in room air.   The  diagram  includes
identification of the major emission  points which  are normally vented
directly to the atmosphere.  This plant represents the  processes  and
                                 6-14

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                   Table  6-5.    PARAMETERS  FOR  MODEL  PLANT  1
General information                    ;
     Type of Plant
     Spinning Process
     Polymerization Medium
     Spinning Solvent
     Production Capacity
     Capacity Utilization              ,
     Raw Materials
     Hours of Operation
     Pollutants

Process Rates (Per 1,000 kg fiber)
     Raw Materials In (PY)
     Solvent Use (TS)
     Polymer Fiber Produced (PS)
     Residual Solvent in Fiber (RS)
     Miscellaneous Non-Gaseous Solvent Loss
       (Includes Distillation Loss)
 Acrylic Fibers Plant
 Wet Spinning
 Suspension or solution
 Dimethylacetamide (DMAc)
 45.36 Gg/Year (100 MMPPY)
 95 percent
 Polyacrylonitrile, 98 percent
 8,400 hours per year
 DMAc
 1,000 kg, PAN, 20 kg other materials
 3,000 kg, DMAc
 1,000 kg, Acrylic Fiber
     5 kg, DMAc

    25 kg, DMAc
                                       Alternative I
Process Variables (Per 1.000 kg fiber) i (Baseline)

     Make-up Solvent (MS)
70 kg
  Alternative II
(Control  Option A)

       56 kg
Emission Sources (Per 1.000 kg fiber)
     Filtering/Dissolving (El)
     Spinning/Washing (E2)
     Crimping/Drying (E3)
     Cutting/Baling (E5)
     Solvent Recovery Area  (E4)
     Miscellaneous  Fugitives
        Emission Totals
                                                                           Alternative  III
                                                                         (Control  Option  B)

                                                                                43 kg
                                                                                 1  kg
                                                                                 1  kg
                                                                                 1  kg
                                                                                 1  kg
                                                                                 4  kg
                                            40 kg
                26 kg
                           13  kg
Exhaust Gas Characteristics
     Filtering/Dissolving (El)


     Spinning/Hashing (E2)


     Crimping/Drying (E3)


     Cutting/Baling Area (E5)



Scrubber £1
     Controlled Emission Source
     Scrubber Type
     Scrubber Efficiency
     Feed Gas
     Feed Gas Flow Rate
     Feed Gas Solvent Concentration
     Scrubbing Liquid Flow Rate
     Residue Gas Solvent Concentration

Scrubber 12
     Controlled Emission Source
     Scrubber Type
     Scrubber Efficiency
     Feed Gas
     Feed Gas Flow Rate
     Feed Gas Solvent Concentration
     Scrubbing Liquid Flow Rate
     Residue Gas Solvent Concentration
 Intermittent Flow:   140 M3/Min (5,000 ACFM)
 Temperature:   27°C  (80°F)
 Solvent Concentration:   25 ppmv
 Continuous Flow:  4,250  M3/Min  (150,000 ACFM)
 Temperature:   50°C  (120°F)
 Solvent Concentration:   100 ppmv
 Continuous Flow:   1,700 M3/Min (60,000 ACFM)
 Temperature:   82°C  (180°F)
 Solvent Concentration:  250 ppmv
 Fugitives
 Temperature:   27°C  (80°F)
 Solvent Concentration:    5 ppmv
 Spinning/Washing
 Bubble cap tower
 98+ percent
 Air/DMAc
 570 M3/Min (20,000 ACFM)
 650 ppm DMAc (1.2 kg/min)
 500 kg/hr D.M.  water
 15 ppm (.02 kg/min)
 Crimping/Drying
 Bubble cap tower
 98+ percent
 Air/DMAc
 1,700 M3/Min (60,000 CFM)
 250 ppmv,  DMAc (1.2 kg/min)
 2,000 kg/hr, D.M. water
 15 ppmv
                                            6-16

-------
air pollution emission control technology currently  in-use  in  this
particular segment of the acrylic fibers industry.   This  particular
production or process sequence is considered as  "baseline control."
     For a wet-spinning capacity of 45.36 Gg (100 MMPPY), it is  assumed
that eight spin baths, each 3m x 5m, and eight washers, each 3m  x  15m,
are needed together with appropriate fiber processing  equipment  to
complete the eight spinning lines.  The process  lines  are essentially
open to room air.  Ventilation hoods are located above the  spinning
and washing areas and at various other major processing points.  The
existing ventilation systems are designed around high  air flow rates
with little emphasis on enclosures to reduce air volume flow.
     6.3.1.2  Regulatory Alternative II, Control Option A.  Since
major VOC emissions for this production sequence occur at spinning  and
washing, an option for VOC emission control is to enclose these  process
steps; the collected gases are then directed to  a solvent recovery
scrubber.  The enclosures would be reasonably tight  i'n order to  limit
the volume of gas to be treated.  The enclosures would be sufficient
to cover the equipment, tied together with proper manifolding, and
equipped with doors at the correct spacing to permit operator  access.
The enclosures would be tight enough to restrict the air  flow  to about
20,000 SCFM.  If a flow of 20,000 SCFM is used,  the  VOC concentration
can be maintained well below the solvent lower explosive  limit (1.8 percent
by volume).  With a capture efficiency of 90 percent and  a  solvent
recovery (absorption/stripping) efficiency of 98 percent, the  emission
reduction would amount to about 14 kg per 1,000  kg of polymer  fiber.
Use of a solvent scrubber to treat gas streams from  spinning,  washing,
drawing, and drying would reduce VOC emissions and recover  additional
spinning solvent.  Figure 6-5 provides a schematic diagram  of  this
control option as applied to Model Plant 1.  Table 6-5 contains  the
model plant parameters for this option.  Figure  6-6  shows the  enclosures
in isometric and in plan and elevation views.
     6.3.1.3  Regulatory Alternative III. Control Option  B. This
control option incorporates the VOC control measures outlined  in
Option A and includes the additional control of  the  emissions  from  the
filtering, crimping, and/or steam setting dryer. These processes,
which are normally vented directly to the atmosphere,  would be collected,
and the exhaust gas stream would then be vented  to a solvent recovery
                                 6-17

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 Figure 6-6.   Ducts and  Enclosures  for
Acrylic Fibers  Spinning  and Washing Steps
                     6-19

-------
scrubber similar to the one described  in Option A.   The  total  gas
volume flow would be about 60,000 ACFM.  Assuming  a  capture  efficiency
of 90 percent and a control devijce efficiency  of 98  percent,  the
emissions reduction from baseline emissions  resulting  from Option  B
would be about 27 kg per 1,000 kg of polymer fiber.   Figure  6-7 presents
the model plant schematic for this process with Option B applied.
Details on the process parameters are  contained in Table 6-5.
6.3.2  Model Plant 2
     6.3.2.1  Regulatory Alternative I, Baseline Control.  .This plant
is characterized by use of suspension  or solution  polymerization and
dry spinning with an organic solvent.  The model plant block  or schematic
diagram is presented in Figure 6-8; Table 6-6  presents the parameters
and technical details corresponding to the dry spinning  model  plant
schematic.  For a dry spinning capacity of 45.36 Gg  (100 MMPPY), four
spinning lines, each with 50 spinning  cells  per side,  are needed
together with appropriate fiber processing equipment to  complete the
model plant layout.  This plant sequence represents  "baseline control"
for the dry spinning of acrylic fibers.
     6.3.2.2  Regulatory Alternative II, Control Option  A.   The spinning,
washing, steaming, and drying processes are  the major VOC emission
sources in the dry spinning of acrylic fibers.  Option A for  this
process involves collecting the spinning emissions  (solvent  volatilized
as the fibers exit the spin cell and move to the processing  stages)
with appropriate enclosures and venting the  solvent  containing gases
to a solvent recovery scrubber rather  than to  the  atmosphere.   If  a
flow of 15,000 ACFM (spinning) is used for the gas stream, the solvent
concentration can be maintained well below the solvent lower  explosive
limit (2.2 percent by volume).  Assuming a capture efficiency of
90 percent and a recovery/control efficiency of 98 percent,  the VOC
emission reduction would amount to about 14  kg of  VOC per 1,000 kg of
polymer fiber produced from the spinning cell  exits.  Total  solvent
recovered from Option A control would  also be  about  14 kg per 1,000  kg
of polymer.  Figure 6-9 provides the schematic diagrams  of this control
option as applied to Model Plant 2.  Table 6-6 lists the appropriate
parameters for this control option in  relation to  the schematic diagrams.
     6.3.2.3  Regulatory Alternative III, Control  Option B.   This
control option for the dry spinning of acrylics includes capture  and
treatment of the steaming and,drying process steps exhaust gases  as
                                 6-20

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                Table 6-6.   PARAMETERS FOR MODEL  PLANT  2
General Information

     Type of Plant
     Spinning Process
     Polymerization Medium
     Spinning Solvent
     Production Capacity
     Capacity Utilization
     Raw Materials
     Hours of Operation
     Pollutants

Process Rates (Per 1,000 kg fiber)

     Raw Materials In (PY)
     Solvent Use (TS)
     Polymer Fiber Produced (PS)
     Residual Solvent in Fiber (RS)
     Miscellaneous Non-Gaseous Solvent Loss
Acrylic Fibers Plant
Dry Spinning
Suspension or solution
Dimethylformamide (DMF)
45.36 Gg/Year (100 MMPPY)
95 percent
Polyacrylonitrile, 98%, 2% other material
8,400 hours per year
DMF
1,000 kg, PAN, 20 kg other materials
2,200 kg, DMF
1,000 kg, Acrylic Fiber
    5 kg, DMF
   20 kg, DMF
                                       Alternative I   Alternative II      Alternative III
Process Variables (Per 1.000 kg fiber)  (Baseline)(Control  Option A)   (Control  Option B)
     Make-up Solvent (MS)                   70 kg           56 kg               42 kg

Emission Sources (Per 1,000 kg fiber)          .       •
     Filtering/Dissolving (El)              ,1kg
     Spin Cell Exits (E4)                   15 kg
     Wash/Draw/Crimp (E2)                    2 kg
     Piddle/Waste System (E5)                6 kg
     Steaming/Drying (E3)              .     15 kg
     Solvent Recovery Area                   1 kg
     Miscellaneous Fugitives                 5 kg
        Emission Totals                     45 kg
                  kg
                  kg,
                  kg
                  kg
               15 kg
               31 kg
   kg
   kg
   kg
   kg
 1 kg
 2 kg
 5 kg

18 kg
Exhaust Gas Characteristics
     Filtering/Dissolving (El)


     Spin Cell Exits (E4)


     Steaming/Drying (E3)


     Hash/Draw/Crimp (E2)



Scrubber #1
     Controlled Emission Source
     Scrubber Type
     Scrubber Efficiency
     Feed Gas
     Feed Gas Flow Rate
     Feed Gas Solvent Concentration
     Scrubbing Liquid Flow Rate
     Residue Gas Solvent Concentration

Scrubber #2
     Controlled Emission Source
     Scrubber Type
     Scrubber Efficiency
     Feed Gas
     Feed Gas Flow Rate
     Feed Gas Solvent Concentration
     Scrubbing Liquid Flow Rate
     Residue Gas Solvent Concentration
Intermittent Flow:  140 M3/Min (5,000 ACFM)
Temperature:- 38°C (100°F)
Solvent Concentration:  10 ppmv
Continuous Flow: fugitive emissions
Temperature:  38°C (100°F)
Solvent Concentration:  Variable
Continuous Flow:  1,700 M3/Min (60,000 ACFM)
Temperature:  82°C (180°F)
Solvent Concentration: 300 ppmv
Continuous Flow: 5,700 M3/Min (200,000 ACFM)
Temperature:  38°C (100°F)
Solvent Concentration:  10 ppmv
Spinning (E4)
Bubble cap tower
98+ percent
Air/DMF
425 M3/Min (15,000 ACFM)
1,000 ppm DMF (1.3 kg/min)
400 kg/hr D.M. water
20 ppm (.03 kg/min) DMF
Streaming/Drying (E3)
Bubble cap tower
98+ percent
Air/DMF
1,700 M3/Min (60,000 CFM)
300 ppmv, DMF (1.28 kg/min-)
2,000 'kg/hr, D.M. water
10 ppmv DMF (0.02 kg/min)
                                          6-23

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well as those from the spinning cell exit.   The  total  exhaust  gas
stream from the steaming and drying stages would  be  vented  to  a  solvent
recovery scrubber similar to the one described  in Option  A.  The
enclosures on these process stages would  be  reasonably tight in  order
to limit the fugitive losses.   If a flow  of  60,000 CFM is used to
characterize the combined exhaust gas stream, solvent  concentrations
are maintained well below the lower explosive limit  (2.2  percent by
volume).  The dryer air flow rate is related directly  to  product
quality control and, as a process variable,  cannot be  reduced  to
increase the solvent concentration.  Assuming a  capture efficiency  of
about 90 percent at the steaming/drying stage and a  control device
efficiency of 98 percent, the total VOC emission  reduction  measured
from baseline control resulting from application  of  Option  B controls
would be about 27 kg of VOC per 1,000 kg  of  fiber.   Figure  6-10  presents
the model plant schematic for this model  plant with  Option  B applied.
Details on the process parameters are contained  in Table  6-6.
6.3.3  Model Plant 341"50
     6.3.3.1  Regulatory Alternative I, Baseline  Control.   This  model
plant is based on suspension polymerization  and  dry  spinning with
acetone as the organic solvent.  The processing  or manufacturing
stages are quite similar to those of the  preceding model  plants.
Polymer (or copolymers) is dissolved in solvent,  blended, filtered,
dry spun, drawn, washed, crimped, and dried.  For this segment of the
acrylic fiber industry, a model plant capacity of 20 Gg per year
(44 MMPPY) was selected.  For this dry spinning  capacity, two  spinning
lines, each with 50 spinning cells per side, are  required as well as
the appropriate downstream fiber processing  equipment.
     The major emissions from this dry spinning  process are volatilized
solvent losses which occur at a number of points  in  the overall  pro-
duction scheme.  Solvent emissions occur  during  dissolving  of  the
polymer, blending of the spinning solution,  filtering  of  the dope,
spinning of the fiber, treating of the fiber after spinning, and
during the solvent recovery process.  Figure 6-11 presents  a process
flow diagram, with emission points shown, for this segment  of  the
acrylic fibers industry.  Table 6-7 includes the  model  plant param-
eters relevant to the diagram.  This production  or process  sequence is
considered as "baseline control" for this model  plant.
                                 6-25

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                  Table  6-7.   PARAMETERS  FOR MODEL  PLANT 3
General Information
     Type of Plant
     Spinning Process
     Polymerization Medium
     Spinning Solvent
     Production Capacity
     Capacity Utilization
     Raw Materials

     Hours of Operation
     Pollutants

Process Rates (Per 1.000 kg fiber)
     Raw Materials In (PY)

     Solvent Use (TS)
     Polymer Fiber Produced (PS)
     Residual Solvent in Fiber (RS)
     Miscellaneous Solvent Loss
Modacrylic Fibers Plant
Dry Spinning
Suspension
Acetone
20 Gg/Year (44 MMPPY)
95 percent
Polyacrylonitrile and Vinylidene Chloride,
  98 percent, 2% other material
8,400 hours per year
Acetone
1,000 kg, Polymer/copolymer,
  20 kg other materials
2,500 kg, Acetone
1,000 kg, Modacrylic Fiber
    5 kg, Acetone
   10 kg, Acetone
Alternative I
Process Variables (Per 1,000 kg fiber) :
Make-up Solvent (MS)
Emission Sources (Per 1,000 kq fiber)
Filtering/Dissolving (El)
Spinning/Washing/Cr imping (E2)
Drying (E3)
Solvent Recovery Area (E4)
Spinning Scrubber
Emission Totals
Alternative II
(Baseline) (Control Option A)
155 kg 101 kg
5 kg 5 kg
57 kg 57 kg
55 kg 1 kg
23 kg 23 kg
140 kg
86 kg
Alternative III
(Control Option B)
48 kg
5 kg
3 kg
•1 kg
23 kg
JJa
33 kg
Exhaust Gas Characteristics
     Filtering/Dissolving (El)


     Spinning/Washing/Crimping (E2)


     Drying (E3)
ScrubberII
     Controlled Emission Source
     Scrubber Type
     Scrubber Efficiency
     Feed Gas
     Feed Gas Flow Rate
     Feed Gas Solvent Concentration
     Scrubbing,Liquid Flow Rate
     Residue Gas Solvent Concentration

Scrubber $2
     Controlled Emission Source
     Scrubber Type
     Scrubber Efficiency
     Feed Gas
     Feed Gas Flow Rate
     Feed Gas Solvent Concentration
     Scrubbing Liquid Flow Rate
     Residue Gas Solvent Concentration
Intermittent Flow:  140 M3/Min (5,000 ACFM)
Temperature:  27°C (80°F)
Solvent Concentration:   1,000 ppmv
Continuous Flow: Fugitive Emissions
Temperature:  27°C (80°F)
Solvent Concentration:  1,000 ppmv
Continuous Flow:  425 M3/Min (15,000 ACFM)
Temperature:  60°C (140°F)
Solvent Concentration: 2,300 ppmv
Dryer (E3)
Bubble cap tower
98+ percent
Air/Acetone
425 M3/min (15,000 ACFM)
2,300 ppmv (2.0 kg/min), Acetone
600 kg/hr D.M. water
40 ppm (.04 kg/min), Acetone
Spinning/Washing (E2)
Bubble cap tower
98+ percent
Air/Acetone
425 M3/Min (15,000 CFM)
2,300 ppmv (2.0 kg/min)  Acetone
600 kg/hr, D.M. water
40 ppmv (0.04 kg/min),  Acetone
                                            6-28

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      6.3.3.2   Regulatory Alternative II. Control Option A.  The major
 VOC  emissions  from  this  fiber production process occur at the spinning
 cell  fiber  exit,  during  drawing  and washing of the spun fibers, and
 during  drying  of  the  fiber tow.   Option A for this production sequence
 involves  the collection  of the exhaust gases from the fiber dryer
 (which  contain  significant amounts  of volatilized solvent) and treatment
 of these  gases  in a solvent recovery system.  The solvent recovery
 system  may  consist  of either a solvent scrubber or a carbon adsorption
 system.   For the  purpose of the  model  plant analysis, it is assumed
 that  a  scrubber is  used.   Assuming  a solvent recovery efficiency of
 98 percent, the emission reduction  would amount to about 54 kg solvent
 per  1,000 kg of polymer  processed.   Capture efficiency at drying is
 nearly  100  percent, since 100 percent  of the dryer exhausts are routed
 to the  control  device.   Figure 6-12 shows  the schematic diagram of
 this  control option as applied to Model  Plant 3; Table 6-7 contains
 the model plant parameters  for this option.
      6.3.3.3   Regulatory Alternative III.  Control  Option B.   The major
 VOC emissions from  this  fiber production process occur at the spinning
 cell  fiber  exit,  during  drawing  and washing  of the spun fibers,  and
 during  drying of  the  fiber  tow.   Option  B  for this production sequence
 would require enclosure  of  the post spinning processing stages with
 the collected gases sent to  a solvent  recovery scrubber or carbon bed;
 a scrubber  is specified  for  the  model  plant  analysis.   The exhaust
 gases from  the  fiber  dryer would  also  be treated in  a solvent recovery
 system.   The process  enclosures  would  be tight enough to limit the
 volume  of gas to  be treated  to about 15,000  ACFM (not including  dryer
 exhaust).  At this flow  rate,  the VOC  concentration  can be maintained
well   below the  lower  explosive limit (2.6  percent  by  volume).   Capture
efficiency at post spinning  processing stages  would  be  90  percent.
 Dryer emissions would be  100  percent captured.   Assuming  a control
device efficiency of  98 percent  (after capture), the  VOC  emission
reduction from  baseline  control will amount  to  about  54 kg  per 1,000  kg
polymer fiber from the dryer  and  about 53  kg  per 1,000  kg  of  polymer
fiber from the  spinning,  drawing, and washing  stages.   Figure 6-13
shows the schematic diagram  of this  control  option as  applied  to  Model
Plant 3; Table  6-7 contains  the model plant  parameters  for this  option.

                                 6-29

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6.4  CELLULOSE ACETATE FIBER MODEL  PLANTS AND  REGULATORY  ALTERNATIVES51"68
     In order to characterize the plants utilized  in  production  of
                             [
cellulose acetate fibers, two|basic model plants were selected.   One
represents the cigarette filtration tow segment of the cellulose
acetate industry, and the second represents  the textile fibers segment.
For both segments of the industry,  the polymer dissolving and spinning
portions of the model plants are identical;  the major difference in
the two fiber processes is in the post spinning process segments.
For the cellulose acetate fiber industry, a  model  plant capacity of
                             I
22.7 Gg (50 MMPPY) per year was selected.  The polymer consists  of
100 percent cellulose acetate; both model plants use  acetone as  the
solvent.  For a capacity of 22.7 Gg (50 MMPPY), it is  assumed that
four spinning lines, each with 50 spinning cells per  side,  are required
along with the appropriate post spinning fiber processing equipment to
complete the model plants.
6.4.1  Model Plant 4
     6.4.1.1  Regulatory Alternative  I. Baseline Control.   This model
plant represents the production sequence utilized  in  the  manufacture
of cellulose acetate cigarette filtration tow.  Dried  acetate flakes
are dissolved in a solvent, blended,  filtered, and sent to  the spinning
machines.  The post spinning treatment of filter tow  fibers includes
finish application, crimping,|and drying.  The post spinning fiber
processing steps are typically open to room  air; the  exception being
the dryer which is normally controlled.  Since the fibers emerging
from the spin cells contain as much as 15 to 20 percent residual
solvent, significant amounts of solvent are  volatilized into the room
air.  Figure 6-14 presents the model  plant schematic  diagram, and
Table 6-8 contains the relevant model plant  parameters  for  this  segment
of the industry.  This model plant  represents  the  processes and  (solvent
recovery) air pollution control technology currently  in use in this
particular segment of the cellulose acetate  fibers industry.  This
production or process sequence is considered as "baseline control."
     6.4.1.2  Regulatory Alternative  II, Control Option A.  The  major
emissions from the manufacture of cigarette  filtration  tow  occur in
the post spinning fiber processing  stages.   Residual  solvent in  the
                                 6-32

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                  Table  6-8.    PARAMETERS  FOR  MODEL  PLANT  4
 General  Information
      Type  of Plant
      Spinning Process
      Polymerization  Medium
      Spinning Solvent
      Production  Capacity
      Capacity Utilization
      Raw Materials
      Hours  of Operation
      Pollutants

 Process  Rates (Per 1,000 kg fiber)
      Raw Materials In  (PY)

      Solvent Use (TS)
      Polymer Fiber Produced (PS)
      Residual 'Solvent  in F'iber  (RS)
      Miscellaneous"Solvent Loss (ML)
 Cellulose  Acetate Filtration  Tow  Plant
 Dry  Spinning
 Solution
 Acetone
 22.7 Gg/Year  (50  MMPPY)
 95 percent
 Cellulose  Acetate, 98%,  2%  other  material
 8,400 hours per year
 Acetone
 1,000  kg,  Cellulose Acetate,
   20 kg  other materials
 3,000  kg,  Acetone
 1,000  kg,  Acetate  Filter Tow
 Negligible
 10 kg  Acetone
                                       Alternative I   Alternative II      Alternative III
Process Variables  (Per  1,000 kg fiber)  (Baseline)   (Control Option A)  (Control Option B)
     Make-up Solvent  (MS)                  130 kg           77 kg               54 kg
Emission Sources (Per 1,000 ka fiber)
Filtering/Dissolving (El)
Spinning/Finishing (E2)
Crimping (E3)
Solvent Recovery Area
Dryer Carbon Bed Exhausts (E4)
Spin Enclosure Carbon Bed
Exhausts
Emission Totals
2 kg
60 kg
25 kg
28 kg
5 kg
> 120 kg
2 kg
6 kg
25 kg
28 kg
5 kg
1 kg
6/ kg
2 kg
6 kg
2 kg
28 kg
5 kg
1 kq
44 kg
Exhaust Gas Characteristics
     Filtering/Dissolving (El)


     Spinning/Finishing (E2)


     Crimping (E3)



Carbon Adsorber #1

     Controlled Emission Source
     Adsorber Type
     Adsorption Efficiency
     Feed Gas
     Feed Gas-Flow Rate
     Feed Gas Solvent Concentration
     Residue Gas Solvent Concentration

Carbon Adsorber iZ
     Controlled Emission Source
     Adsorber Type
     Adsorption Efficiency
     Feed Gas
     Feed Gas Flow Rate
     Feed Gas Solvent Concentration
     Residue Gas Solvent Concentration
Intermittent Flow:  140 M3/Min (5,000 ACFM)
Temperature:  27°C (80°F)
Solvent Concentration:   1,000 ppmv in room air
Continuous Flow: Fugitives
Temperature:  27°C (80°F)
Solvent Concentration:   1,000 ppmv in room air
Continuous Flow:  Fugitives
Temperature:  50°C (120°F)
Solvent Concentration:  1,000 ppmv in room air
Spinning/Finishing (E2)
Fixed Bed w/steam regeneration
98+ percent
Air/Acetone
425 M3/Mih (15,000 ACFM)
2,500 ppmv (2.5 kg/Min), Acetone
50 ppm
Spinning/Finishing/Crimping
Fixed Bed w/steam, regeneration
98+ percent
Air/Acetone
570 M3/Min (20,000 CFM)
2,650 ppmv, (3.5 kg/min),  Acetone
   50 ppmv
                                           6-34

-------
fiber is volatilized into the room or building air which is then
vented to the atmosphere.  Option A for this production process would
require the treatment of all dryer exhaust gases for solvent recovery
and the enclosure of the spin cell exits and the tow line up to the
crimping stage.  The captured gases containing solvent vapor would be
vented directly to a solvent recovery system.  The solvent recovery
system may consist of either a solvent scrubber or a carbon adsorption
system.  For analysis of this model plant case, it is assumed that a
carbon adsorption system is used to recover the solvent; carbon adsorption
systans are in use at nearly all cellulose acetate fiber plants for
solvent recovery.
     Assuming a 90 percent capture efficiency and a 98 percent solvent
recovery efficiency for the spin cell enclosures and solvent recovery
system, respectively, the VOC emission reduction would be about 53 kg
solvent per 1,000 kg of polymer fiber processed.  Figure 6-15 provides
a schematic diagram of this control option as applied to Model Plant 4.
Table 6-3 lists the model plant parameters corresponding to the
figure.  The carbon adsorption system used to recover solvent from the
spin cell enclosures involves fixed bed adsorption with steam
regeneration.  The system includes carbon beds, blowers, condensers,
piping, valves, and instrumentation.
     6.4.1.3  Regulatory Alternative III, Control Option B.  Option B
for the control of VOC emissions from the manufacture of cigarette
filtration tow requires, in addition to the treatment of all dryer
exhaust gases, the use of process enclosures for control of fugitive
emissions at all the post spinning fiber processing stages where
residual solvent is volatilized into room air, including the crimping
stage.  Enclosures can be placed at the exit of the spinning cells and
along the fiber processing line, up to the fiber dryer.  The collected
gases are then directed to a solvent recovery system.  The enclosures
would be sufficient to cover the equipment, tied together with proper
manifolding, and equipped with doors at the correct spacing to permit
operator access.  The enclosures would be tight enough to restrict the
air flow to about 20,000 ACFM.  If a flow of 20,000 ACFM is used, the
solvent  (VOC) concentration can be maintained well below the solvent
                                 6-35

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 lower  explosive  limit (2.6 percent by volume).  The solvent recovery
 system may  consist  of either a solvent scrubber or a carbon adsorption
 system.   For  the purpose of the model  plant analysis, it is assumed
 that a carbon  adsorption system is used since these solvent recovery
 systems  are in use  at nearly all  cellulose acetate fiber plants.
     Assuming  a  90  percent capture efficiency and a 98 percent solvent
 recovery efficiency,  the VOC emission reduction from baseline control
 will amount to about  76  kg of VOC per 1,000 kg of polymer processed.
 Figure 6-16 provides  a schematic  diagram of this control  option as
 applied  to  Model  Plant 4.   Table  6-3 lists the model  plant  parameters
 corresponding,  to the  figure.   The carbon adsorption system  involves
 fixed  bed adsorption  with  steam regeneration.   The system includes
 carbon beds, blowers,  condensers,  condensate decanter,  piping, valves,
 and instrumentation.
 6.4.2  Model Plant  5
     6.4.2.1   Regulatory Alternative I.  Baseline Control.   The cellulose
 acetate  textile yarn  process  is represented  in this model plant.   The
 process  stages prior  to  fiber exit from  the  spinning  cell are identical
 to those of acetate filtration  tow.   Dried acetate flakes are dissolved
 in a solvent,  blended, filtered,  and sent  to the spinning machines.
 Immediately after spinning,  acetate  textile  yarn is wound onto a
 bobbin as continuous  filament yarn,  with no  further treatment.   The
yarn is  later  transferred  to  larger  spools for shipment or  further
 processing  in  another  part  of  the  plant.   As  the fibers are initially
wound onto  bobbins, they may  still contain as  much  as 15  to 20 percent
 residual  solvent.  This  residual  solvent continuously evaporates  into
 room or building air until  equilibrium is  reached  in  the  fiber at
around 1 or 2 percent  (by weight)  residual solvent.   These  fugitive
emissions are about 145  kg  VOC per 1,000 kg  of polymer processed on  an
 industry-wide basis.   Figure 6-17 presents the  model  plant  schematic
diagram,  and Table 6-9 contains the  relevant model  plant parameters
for the production sequence considered as  baseline  control.
     6.4.2.2  Regulatory Alternative II, Control Option A.  This
control alternative involves the use of a gross  in-plant air management
scheme to achieve optimum solvent recovery.  The air management  system
                                 6-37

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                  Table 6-9.   PARAMETERS  FOR MODEL PLANT 5
General Information
     Type of Plant
     Spinning Process
     Polymerization Medium
     Spinning Solvent
     Production Capacity
     Capacity Utilization
     Raw Materials

     Hours of Operation
     Pollutants

Process Rates (Per 1.000 kg fiber)      ;
     Raw Materials In (PY)             •
     Solvent Use (TS)
     Polymer Fiber Produced (PS)
     Residual Solvent in Fiber (RS)
     Miscellaneous Non-Gaseous Solvent Loss
     Total Solvent Evaporated to
       Room Air
                            Yarn
Cellulose Acetate Textile
Dry Spinning
Solution
Acetone
22.7 Gg/Year (50 MMPPY)
95 percent
Cellulose Acetate 98 percent,
  2 percent other materials
8,400 hours per year
Acetone
  1,000 kg,  Acetate,  20  kg  other  materials
  3,000 kg,  Acetone
  1,000 kg,  Acetate Textile Yarn
     10 kg,  Acetone
     20 kg,  Acetone

    122 kg,  Acetone
Process Variables (Per 1.000 kg fiber) • (Baseline)
                                       Alternative I   Alternative II
                                Alternative  III
     Make-up Solvent (MS)

Emission Sources (Per 1.000 kg fiber)
175 kg
        (Control Option' A)  (Control  Option B)
               96 kg               70 kg
Filtering/Dissolving (El)
Spinning/Winding (E2) (E3)
Solvent Recovery Area
Miscellaneous Fugitives
Emission Totals
5 kg
105 kg .
30 kg
5 kg
145 kg
1 kg
30 kg
30 kg
_Oa
66 kg
1 kg
4 kg
30 kg
_5_Jkg
40 kg
Exhaust Gas Characteristics
     Filtering/Dissolving (El)
     Spinning/Winding (E2) (E3)
     Total Air to Extrusion Room
       From Filtering/Winding
     Room Air Used as Process Air
       in Alternatives II and III
     Room Air Lost as Fugitives
       (El, E2, E3, and Misc.)
     Room Air Sent Directly to
       Recovery
  Intermittent Flow:   Fugitive  Losses
  Temperature:   27°C  (80°F)
  Solvent Concentration:    1,000  ppmv

  Continuous  Flow:  Fugitive  Losses
  Temperature:   27°C  (80°F)
  Solvent Concentration:    1,000  ppmv

  Continuous  Flow:  3,500  M3/Min (125,000  ACFM)
  Temperature:  27°C (80°F)
  Solvent Concentration:   1,000 ppmv

  Continuous  Flow:  3,500  M3/Min (125,000  ACFM)
  Temperature:  27°C (80°F)
  Solvent Concentration:   1,000 ppmv

  Continuous  Flow:  700 M3/Min  (25,000  ACFM)
  Temperature:  27°C (80°F)
  Solvent Concentration:   1,000 ppmv

  Continuous  Flow:  1,400  M3/Min (50,000 ACFM)
  Temperature:  27°C (80°F)
  Solvent Concentration:   1,000 ppmv
                                            6-40

-------
requires the re-use of plant air from the  three  basic  process  areas  of
the fiber plant.  Room air from the dope preparation area  (dissolving,
mixing, filtering) and room air from the twisting/coning/beaming
areas, both of which contain low levels of solvent, are  vented
(transported) to the extrusion room at  a predetermined flow rate.  The
extrusion room air can then be used to  supply  the  process  or evaporation
air for the spinning-cell solvent  evaporation  system.  The solvent-rich
process air, together with a fixed amount  of  solvent-lean  extrusion
room air, is then vented directly  to a  solvent recovery  system.   The
ratio of process air to  (direct) room air  may  vary somewhat depending
on the individual plant.  To properly accomplish the  air management
program, the plants would likely maintain  a slight negative room
pressure of about 0.1 to 0.2 inches of  water.
     For a cellulose acetate textile yarn  plant capacity of 22.7  Gg/year
(50 MMPPY), a total of about 125,000 CFM would be  sent to  the solvent
recovery system.  Of this amount,  about 125,000 CFM,  nearly all  the
gas would be from the spinning cells; little  or no air would be  taken
directly from the extrusion  room.  Figure  6-18 and Table 6-9 present
the relevant model plant parameters for this  option.   Since this  model
plant  represents that segment  of the cellulose acetate fiber industry
which  produces  textile filament yarn, consideration has  been given to
the fact that a plant of this  type might  utilize more  than one solvent
in  the production of acetate fibers.   Solvent-laden air streams  would
therefore contain two or more  VOC's, and  carbon adsorption efficiency
of  any given system will tend  to  be  lower on  a multiple organic  feed
versus a single organic  (see Chapter 4  for discussion).   To account
for this, a  lower overall  recovery efficiency is assigned  to this
model  plant  control  scheme,  95 percent  as  opposed to 98 percent.
Assuming a 95 percent  solvent  recovery  efficiency from the control
device,  the  VOC emission reduction would  amount to about 79 kg of VOC
per 1,000 kg of polymer  processed.  The solvent recovery system may
consist  of either a  solvent scrubber  or a carbon adsorption system.
For the  purpose of  the model  plant analysis,  it is assumed that a
carbon adsorption system is used.   The  carbon adsorption system involves
fixed  bed  adsorption with  steam regeneration.  The system  includes
                                  6-41

-------
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6-42

-------
 carbon  beds,  blowers,  condensers,  piping, valves, and instrumentation.
 Design  parameters  include operating capacity, carbon requirements,
 flow  rates,  temperatures, bed depth,  pressure drop, loading time, bed
 area, cycle  time,  and  regeneration requirements.
      6.4.2.3   Regulatory  Alternative  III. Control Option B.  The
 control alternative  involves  use of the same in-plant air management
 scheme  described in  Option  A.   The difference is  that this Option
 calls for the  treatment of  an additional  50,000 ACFM of extrusion room
 air.  A total  of about 175,000 CFM would  be sent  to the solvent recovery
 system.  Of  this amount 125,000 CFM would be from the spinning cells,
 and 50,000 CFM would be taken directly  from the extrusion room.
 Extrusion room make-up air  of 50,000  CFM  would  be drawn  from the
 pre-spinning and post-spinning process  areas.   A  bypass  system is
 necessary to ensure the room  air concentration  does  not  exceed 1,000 pprn.
 This  control option would also require  measures to adequately control
 the loss of extrusion room  air to  the atmosphere  from the building
 door, windows, etc.  A negative pressure  of about 0.1 to 0.2 inches  of
water would likely be maintained in the buildings to  prevent losses.
Total solvent loss as fugitives in  room air would then  amount to about
 13 kg of solvent per 1,000  kg  of polymer.   Figure 6-18 and  Table 6-9
present the relevant model  plant parameters  for this  option.   Assuming
a 95 percent solvent recovery  efficiency  from the carbon  beds,  the VOC
emission reduction will amount  to  about 105  kg  per 1,000  kg  of polymer.
                                 6-43

-------
 6.5  REFERENCES
 3.


 4.




 5.



 6.
7.
8.
9.
10,
11.
 Chemical  Economics Handbook.  Stanford Research Institute.  Menlo
 Park,  California.  March 1978.  Fibers-540.000.

 Parr,  J.L.   Industrial Process Profiles for Environmental Use.
 U.S.  Environmental Protection Agency.  November 1976.  Chapter 11 - The
 Synthetic Fibers Industry.

 Moncrief, R.W.   Man-Made Fibers.  London, Boston.  Nevves-Sutterworths.
 1975.

 Click,  C.N.  and Moore, D.O. Emission, Process and Control Technology
 Study  of  the ABS/SAN,  Acrylic Fiber, and NBR Industries.   Pullman-Kailogg,
 Inc.   Houston,  Texas.   Report to EPA, Contract No. 68-02--2619,
 Task  No.  6.   April 1979.

 Welfers,  Dr. E.   Process  and Machine Technology of Man-Made Fiber
 Production.   International  Textile Bulletin.  (Schlieren/Zurich.)
 World  Spinning  Edition:  174-204.  February,  1978.

 Zerbonia,  R.  and Lathan,  G. Phase I  Source Category Survey Report.
 Prepared  for the Office  of  Air Quality Planning and Standards,
 U.S. Environmental Protection Agency, during development  of New
 Source  Performance Standards for the synthetic fibers industry.
 Pacific Environmental  Services,  Inc.  Research Triangle Park,
 North  Carolina.   February 14, 1980.

 Report  of the Initial  Plant Visit to DuPont  Corporation Waynesboro
 Plant,  Waynesboro, Virginia.  Prepared for the Office of  Air
 Quality Planning and Standards,  U.S. Environmental Protection
 Agency, during  development  of New Source Performance  Standards
 for the synthetic fibers  industry.   Pacific  Environmental Services,
 Inc.   Research  Triangle  Park, North  Carolina.   May 1, 1980.

 Correspondence  from Mullen,  T.W.  Jr.,  DuPont (Waynesboro  Plant)
 to Manley, R.,  Pacific Environmental  Services,  Inc.   June 9,
 1981.   Subject  spandex process  information.

 Report  of the Plant Visit !to Globe Manufacturing  Company, Gastonia,
 S.C.  U.S. Environmental  Protection  Agency Office  of  Air  Quality
 Planning  and Standards, Research  Triangle  Park,  N.C.   December 1,
 1981.

 Correspondence from Legendre,  R., Globe  Manufacturing Company  to
 Crumpler,  D.C.,   U.S. Environmental Protection  Agency.   June  26,
 1980.   Patent and  process information.

 Report  of November  12, 1981  meeting  between  representatives  of
Globe Manufacturing Company  and  EPA  in Durham,  N.C.   Subject
solvent recovery  and costs.   Prepared  for the  Office  of Air
Quality Planning  and Standards,  U.S.  Environmental  Protection
Agency, during development  of New Source Performance  Standards
for the synthetic  fibers  industry.   Pacific  Environmental  Services,
Inc.  Research Triangle Park, North  Carolina.   December 2,  1981.
                             6-44

-------
12.   Trip Report.  Plant Visit to Globe Manufacturing Company, Gastonia,
     North Carolina.   September 16-17, 1981.

13.   Memorandum and attachments from Zerbonia, R.A., Pacific Environmental
     Services, Incorporated, to Docket No. A-80-7.  November 10,  1981.
     Control  Costs and Regulatory Alternative Development for Reaction
     Spun Spandex Fiber Process (Carbon Adsorption vs.  Incineration).

14.   Welfers, E.   Process and Machine Technology of Man-made Fiber
     Production.   International Textile Bulletin.  World Edition.
     February 1978.  pp. 153-262.

15.   Air Pollution Engineering Manual.  Air Pollution Control District
     County of Los Angeles.  U.S. Environmental Protection Agency.
     Research Triangle Park, N.C.  Publication No. AP-40.  May 1973.
     pp. 207-229.

16.   Radian Corporation. Control Techniques for Volatile Organic
     Emissions from Stationary Sources.  U.S. Environmental Protection
     Agency.   Research Triangle Park, N.C.  Publication No. EPA-450/2-78-022.
     May 1978.  pp. 70-83.  .

17.   Control  Techniques for Hydrocarbon and Organic-Solvent Emissions
     from Stationary Sources.  U.S. Public Health Service.  Washington,
     D.C-.  Publication No.  AP-68.  March 1970.  p. 114.

18.   VIC Manufacturing Company.  Carbon Adsorption/Emission Control -
     Benefits and Limitations.  Minneapolis, Minnesota,  pp. 7-8.

19.   McCabe,  W.L.'and Smith, J.C.  Unit Operations of Chemical Engineering,
     Second Edition.  McGraw-Hill Book Company.  1967.  pp. 517-539.

20.   Peters,  M.S. and Timmerhaus, K.D.  Plant Design and Economics  for
     Chemical Engineers.  McGraw-Hill Book Company, Second Edition.
     1968.  pp. 614-655.
                                                    fj
21.   Perry, R.H.  et al.,  Section 14:  Gas Absorption and Solvent
     Extraction.   Chemical Engineer's Handbook.  McGraw-Hill Book
     Company, Fourth Edition.  1963.  p. 14-24 through  14-34, and
     p. 18-1 through 18-25.

22.   Calvert, J.  et al. "Wet Scrubber System Study" Volume I.  Scrubber
     Handbook.  APT, Incorporated.  EPA R2-72-118A, CPA 70-95.  July  1972.

23.   Letter and attachments from Massey, N.A., Process  Simulation
     Consultant,  AAA Technology and Specialties Company Incorporated,
     to Zerbonia, R.A., PES, Incorporated.  October 1,  1980.  Computer
     Runs to Simulate the Absorber/Stripper Columns.

24.   Telecon.  Bjorness, R.A., Metex Process Equipment  Corporation,
     with Berard, R.E., PES, Incorporated.  September 15, 1980.   Cost
     data for binary absorption columns of varying parameters.
                                 6-45

-------
25.
26.
27.
28.
     Cheremisinoff, P.N. and Ellerbusch, Fred.   Carbon Adsorption
     Handbook.  Ann Arbor Science Publishers,  Incorporated.   1978.

     McDennott, H.J.  Handbook !of Ventilation  for  Contaminant Control
     Ann Arbor Science Publishers, Incorporated.   1976.   p.  101-185.
     Industrial Ventilation-A Manual of Recommended  Practice.
     Conference of Governmental Industrial Hygienists.   1980.
American
     Click, C.N. and Moore, D.O. Emission, Process,  and  Control  Technology
     Study of the ABS/SAN, Acrylic Fiber, -and NBR  Industries;  Pullman-Kellogg.
     (Report to EPA, Contract rjo. 68-02-2619, Task  No. 6).   April 1979.
     Appendix D.

29.  Economic Impact Assessment for Acrylonitrile.   Enviro  Control,
     Incorporated.  (Report tojOSHA, Contract No.  J-9-F-6-0229,  Task  3).
     February 21, 1978.

30.  Report of the Initial Plant Visit to American  Cyanamid  Company
     Santa Rosa Plant, Milton,'Florida.  Prepared  for the Office of
     Air Quality Planning and Standards, U.S. Environmental  Protection
     Agency, during development of New Source Performance Standards
     for the synthetic fibers industry.  Pacific Environmental Services,
     Inc.  Research Triangle Park, North Carolina.   April 11,  1980.

31.  Report of the Plant Visitjto Badishe Corporation Synthetic  Fibers
     Plant, Williamsburg, Virginia.  Prepared for  the Office of  Air
     Quality Planning and Standards, U.S. Environmental  Protection
     Agency, during development of New Source Performance Standards
     for the synthetic fibers industry.  Pacific Environmental Services,
     Inc.  Research Triangle Park, North Carolina.   November 28,  1979.

32.  Reference 7, p. 1.

33.  Report of the Initial Plant Visit to DuPont Corporation May
     Plant, Camden, South Carolina.  Prepared for  the Office of  Air
     Quality Planning and Standards, U.S. Environmental  Protection
     Agency, during development of New Source Performance Standards
     for the synthetic fibers industry.  Pacific Environmental Services,
     Inc.  Research Triangle Park, North Carolina.   April 29,  1980.

34.  Report of the Initial Plant Visit to Monsanto  Company  acrylic
     fiber plant, Decatur, Alabama.  Prepared for the Office of  Air
     Quality Planning and Standards, U.S. Environmental  Protection
     Agency, during development of New Source Performance Standards
     for the synthetic fibers industry.  Pacific Environmental Services,
     Inc.  Research Triangle Park, North Carolina.   April 1, 1980.

35.  Reference 8, pp. 3, 7.
                                 6-46

-------
36.   Report of January  27,  1982,  plant visit to DuPont Company May
      Plant, Camden, S.C.   Prepared  for the Office of Air Quality
      Planning and  Standards,  U.S. Environmental  Protection Agency,
      during development of  New  Source Performance Standards for the
      synthetic fibers industry.   Pacific Environmental Services, Inc.
      Research Triangle  Park,  North  Carolina.   March 2, 1982.

37.   Synthetic Fibers Industry,  Emission Test Report Monsanto Textiles
      Company, Decatur,  Alabama.   U.S.  Environmental Protection Agency,
      OAQPS.  Research Triangle  Park,  N.C.  EMB Report 80-SNF-2.
      February 1981.

38.   Synthetic Fibers Industry,  Emission Test Report El du Pont de Nemours
      and Company May Plant, Camden,  South Carolina.  EMB Report 80-SNF-l.
      U.S. Environmental  Protection  Agency.   February 1981.

39.   Statement from Earnhart, C.R.,  DuPont  Company, to National Air
      Pollution-Control  Techniques Advisory  Committee.  September 22,
      1981.  Proposed NSPS for synthetic  fibers production' facilities.

40.   Report of meeting  with Earnhart,  C.R., DuPont Company, and EPA/PES
      synthetic fibers NSPS  project  team.   November 1981.   Technical
      and economic  issues.

41.   Report of Initial  Plant Visit  to  Tennessee  Eastman Company,
      Kingsport,  Tennessee.  Prepared  for the  Office of Air Quality
      Planning and  Standards, U.S. Environmental  Protection Agency,
      during development of  New Source  Performance Standards for the
      synthetic fibers industry.   Pacific Environmental  Services, Inc.
      Research Triangle  Park, North Carolina.   December 13, 1979.

42.   Report of Meeting  between Tennessee Eastman  Company representatives
      and EPA in Durham,   N.C.  Prepared for  the Office of Air  Quality
      Planning and  Standards, U.S. Environmental  Protection Agency,
      during development of  New Source  Performance Standards for the
      synthetic,fibers industry.   Pacific Environmental  Services, Inc.
      Research Triangle  Park, North Carolina.   October 28,  1981.

43.   Volatile Organic Compound Emission  Inventory for Tennessee Eastman
      Company.  U.S. Environmental Agency Region  IV.   Atlanta,  Georgia.
      EPA 904/9-78-023.   December 1978.

44.   Correspondence from Edwards, J.C.,  Tennessee Eastman  Company  to
     Manley, R.,  Pacific Environmental Services,  Inc.   December 2,
      1981.  Subject process information.

45.   Report of November  10, 1981 meeting  between  representatives of
     Tennessee Eastman  Company and EPA in Durham,  N.C.   Prepared for
      the Office  of Air  Quality Planning  and Standards,  U.S. Environmental
      Protection  Agency,  during development  of  New Source  Performance
      Standards for the  synthetic fibers  industry.   Pacific Environmental
     Services,  Inc.  Research Triangle Park,  North  Carolina.   December  21,
      1981.
                                 6-47

-------
46.  Report of September 30, 1981 plant visit  to Tennessee  Eastman
     Company, Kingsport, Tennessee.  Prepared  for the  Office  of  Air
     Quality Planning and Standards, U.S. Environmental  Protection
     Agency, during development of New Source  Performance Standards
     for the synthetic fibers ;industry.  Pacific Environmental Services,
     Inc.  Research Triangle Park, North Carolina.   October 1981.

47.  Report of January 2, 1982, plant visit  to Tennessee Eastman Company,
     Kingsport, Tennessee.  Prepared for the Office  of Air  Quality
     Planning and Standards, U.S. Environmental Protection  Agency,
     during development of New Source Performance Standards for  the
     synthetic fibers industry.   Pacific Environmental Services,  Inc.
     Research Triangle Park, North Carolina.   March  2, 1982.

48.  Report of the Initial Plant  Visit to Tennessee  Eastman Company
     Synthetic Fibers Manufacturing Facility in Kingsport,  Tennessee.
     Prepared during Development  of New Source Performance  Standards
     for the synthetic fibers industry.  December 13,  1979.

49.  Statement from Ritchie, Tom, Tennessee  Eastman  Company,  to  National
     Air Pollution Control Techniques Advisory Committee.   September  22,
     1981.  Proposed NSPS for synthetic fibers production facilities.

50.  Report of meeting with Vaughn McCoy, et al., Tennessee Eastman
     Company, and EPA/PES synthetic fibers NSPS project  team,,  December 1,
     1981.  Technical and economic issues.

51.  Reports of the Phase II Plant Visit to  Celanese Fibers Company
     Celriver acetate plant, Narrows, Virginia.   Prepared for the
     Office of Air Quality Planning and Standards,  U.S.  Environmental
     Protection Agency, during development of  New Source Performance
     Standards for the synthetic  fibers industry.   Pacific  Environmental
     Services, Inc.  Research Triangle Park, North  Carolina.   May 28,
     1930.

52.  Report of Phase II Plant Visit to Celanese Fibers Company Celco
     acetate plant, Rock Hill, South Carolina. Prepared for the
     Office of Air Quality Planning and Standards,  U.S.  Environmental
     Protection Agency, during development of  New Source Performance
     Standards for the synthetic  fibers industry.   Pacific  Environmental
     Services, Inc.  Research Triangle Park, North  Carolina.   August  11,
     1980.

53.  Reference 41, p. 1.

54.  Reference 42, p. 2.  .

55.  Reference 43, p. 2-1.

56.  Reference 44, p.l.

57.  Reference 45, p. 1.

58.  Reference 46, pp.  1,  2.

                                  6-48

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59.  Reference 47, p. 1.

60.  Report of the August 11, 1980, plant visit to Celanese  Fibers
     Company Celco plant, Narrows, Virginia.  Prepared  for the  Office
     of Air Quality Planning and Standards, U.S. Environmental  Protection
     Agency, during development of New Source Performance Standards
     for the synthetic fibers industry.  Pacific Environmental  Services,
     Inc.  Research Triangle Park, North Carolina.  September 1980.

61.  Letter and attachments from Pullen, J.C., Celanese  Fibers  Company,
     to Zerbonia, R.A., Pacific Environmental Services,  Incorporated.
     July 3, 1980.  Response to Section 114 information  request (Celco
     Acetate Fiber Plant, Narrows, Virginia).

62.  Report of the Phase II Plant Visit to Celanese Fibers Company
     Celriyer Acetate Plant in Rock Hill, South Carolina.  Prepared
     during the Development of New Source Performance Standards for
     the synthetic fibers industry.  May 28, 1980.

63.  Letter and attachments from Pullen, J.C., Celanese  Fibers  Company,
     to Zerbonia, R.A., Pacific Environmental Services,  Incorporated.
     July 3, 1980.  Response to Section 114 information  request (Celriver
     Acetate Fiber Plant, Rock Hill, South Carolina).

64.  Letter from Pullen, J.C., Celanese Fibers Company,  to National
     Air Pollution Control Techniques Advisory Committee.  September 8,
     1981.  Proposed NSPS for synthetic fiber production facilities.

65.  Report of meeting with Pullen, J.C., Celanese Fibers Company, and
     EPA/PES synthetic fibers NSPS project team.  December 3, 1981.
     Technical and economic issues.

66.  Reference 49, pp. 11-43, 44, 47, 48.

67.  Reference 50, pp. 1,2.

68.  Letter and attachments from Pullen, J.C., Celanese  Fibers  Company,
     to Manley, R., Pacific Environmental Services, Incorporated.
     June 2, 1982.  Comments on draft background information document.
                                 6-49

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                        7.0   ENVIRONMENTAL  IMPACT

7.1  INTRODUCTION
     Volatile organic compound  (VOC)  emissions  occur at a multitude of
sources within a synthetic fiber  plant.  These  emissions occur both
inside and outside the  plant during  several  processes,  some  of which
are polymer/solvent mixing and  preparation,  spinning,  and fiber processing.
Chapter 6 discusses several  model  plants that were used to determine
VOC emissions from these  various  stages.
     Total VOC emissions  nationwide  resulting from the  manufacture of
the synthetic fiber types being investigated in this study were estimated
for 1982.  This assumed fiber production at  95  percent  capacity for
each plant.  Estimates  were  made  of  emissions in  1987,  assuming the
implementation of the various regulatory alternatives.   Chapters  3
and 6 contain a more complete discussion of  the Regulatory Alternative I
(baseline) emission levels.
     This chapter presents an assessment of  the regulatory alternatives
discussed in Chapter 6.  The impacts  of these alternatives associated
with air, solid waste,  energy consumption, and  other environmental
concerns will be discussed in the  following  sections.
7.2  AIR QUALITY IMPACT
     The air pollution  impact of  each regulatory  alternative  is determined
by comparison of VOC emissions  from various  systems  installed  on  the
appropriate process stages or points  to control  VOC  emissions.   In
order to analyze the incremental  air  quality  impact  of  the resulting
levels of VOC emission reduction,  annual VOC  emission rates under each
regulatory alternative were determined and then employed  to project
5-year impacts on national air  quality.
     Table 7-1 shows,  for each  fiber  type, the  amount of  fiber  produced
at synthetic fiber plants that  would  fall  into  one or more of  the five
model  plant categories.   Production figures  for 1987 for  each  fiber
                                7-1

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 type  were  derived  by  projecting the highest and lowest expected growth
 rates as determined  in the economic analysis (Chapter 9).  The table
 also  projects  the  1987 emissions and emission reductions resulting
 from  the implementation of each regulatory alternative.  For the
 purposes of  this analysis,  it is assumed that minor production increases
 achieved through debottlenecking will  not result in emission increases,
 and would  therefore not subject the facility to a new source standard.
 7.2.1 Wet and  Dry-Spun Acrylic and Modacrylic Fibers
      Existing  acrylic fiber production facilities were assumed to be
 operating  at essentially full  capacity in 1982,   The projected capacity
 shortfall  in 1987  is  expected  to be 73.6 Gg, in  a high-growth scenario,
 and zero Gg  in  a low-growth scenario.   In order to meet the expected
 demand under the high-growth  scenario,  two new facilities will  be
 required.  Each facility will  have  an  annual capacity of 45.4 Gg
 (100  million pounds)  (see Chapter 6).   However,  it is expected that
 the facilities  will only be operating  at 81 percent capacity.
 Assuming new plants are needed,  the production increase in 1987 will
 amount to  a 20  percent  cumulative increase over  1982 production.   (See
 Chapter 9  for further discussion  of projected  growth.)
      There will be a  corresponding  increase in VOC emissions  resulting
 from  this  production  increase.   Under  Regulatory  Alternative  I  (baseline)
 conditions, the expected  emissions  increase from  facilities  potentially
 subject to the  NSPS would be zero to 3,300 Mg/year,  under the  low-  and
 high-growth scenarios,  respectively.
      If Regulatory Alternative  II were  implemented, at these  same
 facilities, the annual  emissions  would  be  zero to 2,280 Mg,  depending
 on the growth rate.   The  emission reduction  resulting from  the
 implementation of this  alternative  would  be  zero  to  1,020 Mg/year.
      If Regulatory Alternative  III were  implemented  at  these facilities,
 the annual  emissions would  be zero  to  1,320  Mg, depending  on the
 growth rate.   The emission  reduction resulting from  the implementation
 of this alternative would be zero to 1,980 Mg/year.
     Since demand for acrylic fibers can be  met substantially with
production  from either wet or dry spinning processes, the two have
been combined for the purpose of estimating  the environmental  impact
                                7-3

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of increased production.  As well, the  impact  of  any  new modacrylic
fiber production is considered; along with  acrylic production.
7.2.2  Cellulose Acetate Cigarette Filtration  Tow
     Existing cellulose acetate filtration  tow manufacturing facilities
were assumed to be operating at essentially full  capacity  in 1982.
The projected capacity shortfall in 1987 is expected  to be 43.7  Gg
under a low-growth scenario and 95.1 Gg under  a high-growth scenario.
In order to meet the expected  (demand, two  new  facilities will  be
required under the low-growth  scenario, and four  new  facilities  under
the high-growth scenario.   (Each facility,  as  described in Chapter  6,
has an annual capacity of 22.7iGg (50 million  pounds).)  These facilities
are expected to operate at 95  percent capacity.   The  increase  in
production from 1982 to 1987 is projected  to be 43.1  Gg/year under  the
low-growth scenario, and 86.3  Gg/year under the high-growth scenario.
This amounts to a 22 to 43 percent increase over  the  period.   (See
Chapter 9.)
     There will be a corresponding increase in VOC emissions resulting
from this production increase.  Under Regulatory  Alternative I (baseline)
conditions, the expected emissions increase from  facilities potentially
subject to the NSPS would be 5J,170 to 10,350 Mg/year, under the  low-
and high-growth scenarios, respectively.
     If Regulatory Alternative  II were  implemented at these same
facilities, the annual emissions would  be  2,890 to 5,780 Mg, depending
on the growth rate.  The annual emission reduction resulting from
implementation of this alternative would be 2,280 to 4,570 Mg.
     If Regulatory Alternative[III were implemented at these facilities,
the annual emissions would be  1,890 to  3,790 Mg,  for the low-  and
high-growth scenarios, respectively.  The  emission reduction resulting
from the implementation of thU alternative would be 3,280 to  6,560 Gg/year.
7.2.3  Cellulose Acetate Textile Yarn
     It is assumed that all increases in demand for cellulose  acetate
textile yarn between 1982 and  1987 will be  met either through  debottle-
necking or through increases in capacity utilization of equipment
already in place in 1982.  (See Chapter 9  for  an  explanation of  the
projections for this fiber type.)  It is further  assumed for the
purpose of this analysis that these modest  increases in production

                                7-4

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 will not result in emission increases, and would therefore  not  be
 subject to an NSPS.  (See Chapter 5 for further discussion  of the
 facilities potentially affected as a result of such modifications.)
      Therefore, for the purpose of this analysis and projection of
 environmental  impact, there will be no emission reduction at acetate
 textile yarn manufacturing plants between 1982 and 1987 resulting from
 implementation of Regulatory Alternatives II or III.
 7.2.4  Dry-Spun Spandex Fibers
      By 1987,  it is expected that an additional 0.5 to 2.5  Gg of
 spandex will  be produced annually.  Additional capacity at  up to one
 new typical-size facility (potentially subject to an NSPS) will  be
 required to meet the expected  demand.   Baseline emissions from facilities
 of  this type  are already lower than the levels that would be required
 under either  Regulatory Alternative II or III.  Therefore, no model
 plant or control  options were  developed to analyze the production of
 this type fiber and the cost and effects  of additional  control  equipment.
 Assuming the emission levels at existing  facilities are duplicated at
 the  new facilities,  the expected emission increase in 1987 can  be
 estimated.   Under the low-growth scenario, there  would be essentially
 no  emission  increase.   Under the high-growth  scenario,  the emissions
 increase would  be  30  Mg annually.   There  would be  no  emission reduction
 directly attributable to the implementation of the NSPS,  since there
 would  be no regulatory  impact  except to ensure that any new  facilities
 perform at  least  as well  as  existing facilities.
 7.2.5   Other Solvent-Spun  Fibers
     For the reasons  given  in  Section  6.1, model  plants and  regulatory
 alternatives were  not devised  for  analysis of  hypothetical new plants
 producing all possible  fiber types.  However,  it  is possible that
 there will be an  increase  in production of several  fiber  types for
 which  no model plants were developed.   There would  also be a corresponding
 emission  increase  resulting  from this new  production.   However,  the
 total of  all these emission  increases  is expected  to  be substantially
 lower than the increases from  new  production of the commodity fibers.
Therefore, for the purpose of  evaluating the environmental impact of
the regulatory alternatives, no emission reduction  attributable  to the
                                7-5

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alternatives is considered for other  solvent-spun  fibers  than  those
specifically mentioned.
7.2.6  Total VOC Emission Reduction
     Most VOC emissions from synthetic  fiber manufacturing  facilities
are generated at solvent-spun fiber production  facilities,  as  explained
in earlier sections.  Baseline emissions  in 1980 from  these facilities
are given in Table 3-9, in Chapter 3.   These are the types  of  facilities
that would potentially be subject to  an NSPS.   Applying  the appropriate
growth rates for affected fiber types and  spinning methods,  Regulatory
Alternative I emissions would increase  by  5,170 to 13,680 megagrams
during the 1982-1987 period, depending  on  the collective  industry
growth rate.
     Under Regulatory Alternative II, a decrease in VOC  emissions  of
2,280 to 5,590 megagrams would b;e realized over the corresponding
baseline emissions under Regulatory Alternative I  in 1987.   This would
amount to a reduction of 41 to 4;4 percent.  VOC emissions from the
manufacture of affected solvent-jspun  synthetic  fibers  in  1987  under
Regulatory Alternative II controls would  be 2,890  to 8,060  megagrams.
     Regulatory Alternative III controls  placed on the manufacture of
affected synthetic fibers would reduce  VOC emissions from affected
facilities within the synthetic fibers  industry 3,280  to  8,540 megagrams.
This would be a reduction of 62 to 63 percent from baseline emissions.
                                I                          •  •
VOC emissions released from affected  synthetic  fiber manufacturing
plants in 1987 under Regulatory Alternative III controls  would be
1,890 to 5,110 megagrams.
     Emission reductions could be significantly greater  than the
amounts indicated in this chapter.  If  new fiber manufacturing equipment
were installed at existing facilities,  and the  additions  resulted  in
overall emission increases, then the  entire affected facility  would
potentially be subject to the NS;PS.   (See  Chapter  5, Modification  and
Reconstruction for further- discussion of  applicability.)  If the existing
facility were formerly generating VOC emissions at levels greater  than
allowed under the NSPS, but were' to retrofit sufficiently to achieve
NSPS-allowed levels, then an emission reduction would  be  achieved  that
is not specifically forecast in this  chapter.
                                7-6

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 7-2.7   Secondary  Air Pollution Impact
     Secondary  air  pollutants  are those emissions which are not usually
 associated  with a baseline controlled facility, but which result from
 the  use of  pollution control equipment required under Regulatory
 Alternatives  II or  III.   VOC emission control  devices and techniques
 which may be  incorporated include,  at a minimum, those discussed in
 Chapter 4.
     Secondary  air  pollution problems due to the use of carbon adsorption
 are  expected  to be  minimal.  Gases  may be emitted if the VOC stream
 contacts the  carbon bed  before it is  adequately cooled following
 desorption.   Proper cooling procedures following regeneration should
 reduce  thermal  decomposition of  VOC's.
     Secondary  air  pollutants  from  scrubbers are not expected to be
 significant,  especially  when compared to the contribution of pollutants
 from other  operations  in a plant.   The exhaust stream is typically
 1 to 2  percent  of the  inlet vapor concentration.  While incinceration
 would result  in reductions in  the emissions  of solvent vapor, there
 would be significant secondary air  pollution impacts,  resulting from
 the formation of  oxides  of nitrogen,  oxides  of sulfur,  and carbon
 monoxide.   However,  since recovery  of solvents is essential  to economical
 operation,  incineration  is not expected  to be  a viable technique for
 this industry.
 7.3  WATER  QUALITY  IMPACT1"7
 7.3.1  Model Plants Utilizing  Scrubbers  as Control  Devices
     Adverse environmental effects  resulting from the  operation of  a
 scrubber (absorber) could  include improper disposal  of  the organic-laden
 liquid effluent, undesired emissions  from the  scrubber  stack resulting
 from interaction within  the scrubber,  loss of  absorbent  to the atmosphere,
 and increased water usage.  However,  add-on  water scrubbing  systems
 usually mean only minimal  increases in the existing  water  treatment
 facilities at a plant.
     Water used in scrubbing the solvent vapor  from  the  gas  stream  is
piped to distillation columns where 98 to S9+  percent of the  solvent
 is separated from the water.   The exact  amount  would depend  on  temperature,
solvent/water ratio, and the azeotrope formed by  the solvent  and
                                7-7

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water.  The water stream leaving  the  column  is  normally  routed  back  to
the process; thus any solvent remaining  in the  water would  be reintroduced
to the process.
     Water streams may also be directed  to pi ant-operated waste treatment
                                I
facilities for disposal.  The cpncentration  of  solvent in the waste
stream from the scrubber is very  low,  since  maximum recovery of solvents
is necessary.  Therefore, the actual  solvent loading in  the waste
stream sent to a waste treatment  plant is expected to be minimal.
7.3.2  Plants Utilizing Aqueous!Salt  Spinning Process in Acrylic Fiber
       Manufacturing
     Of the,various processes used  in  acrylic fiber production,,  the
aqueous salt spinning processesigenerate the least VOC emissions.
This is the case since no organic solvent is introduced  into the
process, and no VOC is volatilized  during any of the spinning or
processing stages.
     However, the use of a salt (zinc  chloride  or sodium thiocyanate,
for example) in aqueous solution  creates potential water pollution
problems which must be alleviated in  a wastewater treatment plant at
the manufacturing facility prior'  to ultimate disposal.   Since this
study addresses major VOC emission  points and this type  process  has  no
major solvent VOC emission points,  then  the  aqueous salt spinning process
is excluded from consideration.   There will,  therefore,  be  no increased
water pollution impact at plants  utilizing this process  as  a result  of
the implementation of the NSPS.
7.4  SOLID WASTE IMPACT1'4~8
7.4.1  Plants Utilizing Distillation  Columns  as an Integral Part
       of the Solvent Recovery System
     A very minimal amount of organic material  will accumulate  and
form "still' bottoms," usually a heavy, tar-like compound, after extended
column operation.  This material  is typically removed during column
cleanout and landfilled.  The amount  of  increase would be relative to
the increase in solvent recovered.  Relative  to the total amount of
solvent distilled and to the amount of "still bottoms" generated, the
increase due to the application of  Regulatory Alternative II or III
would be negligible and not measurable.
                                7-8

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 7.4.2  Filtration Media Disposal
      Since the  use of filter media is proportional to the amount of
 polymer/solvent mixture filtered  (and sent to spinning), any increase
 in  solvent recovery as a result of this NSPS would have no effect on
 filtration media use.   An increase or decrease in production rate,
 however, would  directly affect the quantity of filter media used and
 disposed.
 7.4.3  Plants Utilizing Carbon Adsorption9
      Carbon adsorption is proposed as one of the alternative control
 techniques in several  of the model  plants noted in Chapter 6.  The
 carbon  in  use is  typically washed  annually, and from 5 to 15 percent
 (10 percent on  the average)  of the carbon is lost as fines at each
 washing.
      Although the increased  requirement of carbon for collection of
 incremental  increases  of solvent  (due to the control  alternatives)
 should  theoretically  be proportional  to the increased solvent con-
 trolled, this study assumes  no excess capacity exists at any given
 carbon  adsorption  control  device.   Therefore,  the smallest increase in
 capacity of carbon  adsorption  is that of one totally new unit,  consisting
 of three adsorption beds  (one  in use, one cooling,  and one desorbing).
      Using  existing units  as models,  the average  bed  contains approximately
 25,000  pounds (11,300  kilograms) of carbon at  30  pounds/square  foot
 (480  kg/m  ).  A 3-bed  unit will contain approximately 75,000 pounds
 (34,000 kg)  carbon, 10  percent of  which will  be  lost  (waste) annually.
      Thus,  the  additional  carbon waste  generated  as  a result of Regulatory
Alternative  II or  III will be  approximately 3,400 kg  (7,500  pounds)
annually for each  affected facility,  or as  much  as  27,000  kg
 (60,000 pounds)  total  for  all  such  facilities.
 7.4.4  Miscellaneous Waste Streams
     Waste  polymer and  inorganic compounds  from the  polymer  preparation
area  are carried by the wastewater  stream  to the  liquid  waste system.
Waste polymer and  inorganic compounds collected  in  the solvent  recovery
system are usually processed to reduce  solvent content.  The resulting
solids are  then  mixed with water and  pumped  to the  liquid waste system.
                                7-9

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     Spun waste from the spinning area  is washed  to  remove  solvent  and
is buried in a sanitary landfill, or  redissolved  in  the  appropriate
solvent and reintroduced into the process at  the  polymer/solvent
mixing area.
     The main waste streams are from  the polymer  preparation  area,  the
solvent recovery area, and the domestic sewage.   These streams  are
reduced to sludge by standard wastewater treatment.   Approximately
2,400 pounds per day are generated  at a plant producing  100 million
pounds of fiber product per year.   No measurable  increase  in  the
amount of any sludge is expected from application of the proposed
control alternatives.                                ^
7.5  ENERGY IMPACT5'6>8>10
     The fiber manufacturing industry is energy  intensive,  with  substantial
amounts of electricity, coal, oil,  and  natural gas being consumed.
For example, a typical fiber plant  producing  100  million pounds  of
fiber annually will consume from 15 to  30 million kWh of electricity,
120 to 150 million tons of coal, 7,500  to 8,000 million  cubic feet  of
natural gas, and 400 to 600 thousand  gallons  of oil.   (These  figures
are for entire plants, however, and not only  the  affected  facilities.)
     With reference to solvent recovery, energy  is required to  supply
steam for carbon bed regeneration.  The amount of steam  required is
approximately 3 pounds of steam per pound of  organic vapor adsorbed.
Energy in the form of a cooling water system  is used  to  cool  the gas
streams to optimum adsorption temperatures.   Electrical  energy  is
required to move the large volumes  of air utilized in the  process.
Also, blowers are required to overcome  the  pressure  drop encountered
by the gas moving through the adsorption bed.  A  balance must be
reached between the adsorption efficiency prescribed by  the density
and thickness of the bed and the increased  electrical requirement to
overcome the increased pressure drop.
     The two regulatory alternatives  above  baseline  control have
assumed grass roots installation of control devices  will be required.
No existing excess capacity of control  devices will  be utilized  in  the
control analysis.  Thus, the additional solvent recovered  in  the
various options is calculated to require new  control  devices, and the
                                 7-10

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minimum additional energy requirement  is  that  for  operation  of  a new
scrubber or adsorption unit and the  associated distillation  columns.
     .Typical energy requirements  of  an  adsorption  system  are indicated
in Figure 7-1; an adsorber with an inlet  flow  rate of 20,000 scfm and
25 percent LEL will require 2.75  million  BTU/hour  (total  energy requirement),
A scrubber operating at similar flow rates will  require approximately
300,000 BTU/hour total energy  input  (see  Figure 7-2).
     For typical plants in the synthetic  fibers industry,  an increase
in energy consumption would result from compliance with either  Alter-
native II or III.  The increase will also depend on the growth  rate of
a given fiber type.  The incremental energy  increase required to
operate the additional control equipment  for each  plant type under
Regulatory Alternatives II and III are  shown in Table 7-2.   Energy
requirements required under Regulatory  Alternatives II and  III  in 1987
under a low-growth scenario would be 42 and  88 terajoules  (39 and
83 billion Btu) per year, respectively.   Energy requirements for
increased control at all affected facilities in 1987 under Alternatives  II
and III would be 224 and 430 terajoules (210 and 403 billion Btu) per
year, respectively, in 1987 under the  high-growth  scenario.   These
overall energy increases would amount  to  less  than 3 percent of the
total energy (2,700 terajoules or 2,500 billion Btu)  required to
operate all equipment at a typical synthetic fiber manufacturing plant
(not just the incremental control equipment).
7.6  OTHER ENVIRONMENTAL IMPACTS
     No other adverse environmental  impacts  are expected  to  arise from
the implementation of standards of performance for synthetic fiber
manufacturing, regardless of the  regulatory  alternative selected as
the basis for standards.
7.7  OTHER ENVIRONMENTAL CONCERNS
7.7.1  Irreversible and Irretrievable  Commitment of Resources
     The alternative control systems will require  installation  of
additional equipment in new sources  for each alternative  emission
control system.  This requirement will  necessitate the additional  use
of steel and other resources.  The commitment  of resources will  be
small compared to national use of each  resource.   Ultimately, a large
quantity of these resources may be salvaged  and recycled.  No significant
                                7-11

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9oi -aaarioaa
                                                                    Csl
                                                                     OJ
     7-12

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    Table 7-2.   ENERGY  IMPACT3  OF  REGULATORY  ALTERNATIVES IN 1987

                          LOW-GROWTH  SCENARIO
Fiber Type Regulatory Alternative IIb
Acrylic/
Modacrylic 0 terajoules
Acetate Filter
Tow 42 (21)3
Acetate
Filament Yarn 0
Regulatory Alternative III

0 terajoules

88 (44)3

0
Total
                     42 terajoules
                                                   88 terajoules
                         HIGH-GROWTH SCENARIO
Fiber Type
Acrylic/
Modacrylic
Regulatory Alternative IIb Regulatory Alternative IIIb
140 (70)c terajoules 254 (127)c terajoules
Acetate Filter
Tow

Acetate
Filament Yarn
                     84 (21)c


                      0
                                                  176  (44)
                                                    0
Total

a
                    224 terajoules
                                                  430 terajoules
 These values reflect the energy impact of the expected number of
 affected facilities in operation in 1987.


3These energy impacts are the incremental  energy required to operate
 additional  control equipment required by the alternatives.


'The numbers in parentheses represent the impact of a single affected
 facility.
                                7-13

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amounts  of  space  (or land)  are required to install  control  equipment
because  all  control  systems  can be located within little additional
space.   Therefore, negligible  land commitment is expected for additional
control  devices.
7.7.2  Environmental  Impact  of I Delayed  Standards
     Delay of standards  proposal  for  the  synthetic  fiber manufacturing
industry will haye minor negative environmental  effects  on  water and
solid waste.  However, delay in  implementation  of standards will
generate additional  VOC  emissions  at  the  significant  rates  described
earlier  in this chapter.
     No  emerging emission control  technology  appears  imminent that
could achieve greater emission[reductions  or  result in  lower costs
than those represented by the  emission  control  alternatives considered
here.  Consequently, delaying  standards to allow further technical
developments appears to  present;  no tradeoff of  higher solvent emis-
sions in the near future for lower emissions  in  the longer  term.
7.7.3  Environmental  Impact  of ;No  Standards
     Growth projections  are  presented in  Chapter 9.   The increase  in
production of organic solvent  spun fibers  will  cause  or  contribute
significantly to nationwide  VOC  emissions,  should no  additional  control
be imposed.  The administrator ,has  found  that this  may  reasonably  be
anticipated to endanger  public health or  welfare.
     Essentially no  adverse water  and solid waste impacts are associated
with the alternative emission  control systems proposed  in this  section.
Therefore, as in the case of delayed  standards,  there is no tradeoff
of potentially adverse impacts  in  these areas against the negative
result on air quality that would  result from  nonimplementation  of
          i
additional control.
                                7-14

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7.8  REFERENCES

1.   Report of the Initial Plant Visit to American Cyanamid Company
     Santa Rosa Plant, Milton, Florida.  Prepared for the Office of
     Air Quality Planning and Standards, U.S. Environmental Protection
     Agency, during development of New Source Performance Standards
     for the synthetic fibers industry.  Pacific Environmental Services,
     Inc.  Research Triangle Park, North Carolina.  April 11, 1980.

2.   Report of the Plant Visit to Badishe Corporation Synthetic Fibers
     Plant, Williarnsburg, Virginia.  Prepared for the Office of Air
     Quality Planning and Standards, U.S. Environmental Protection
     Agency, during development of New Source Performance Standards
     for the synthetic fibers industry.  Pacific Environmental Services,
     Inc.  Research Triangle Park, North Carolina.  November 28, 1979.

3.   Report of the Initial Plant Visit to DuPont Corporation Waynesboro
     Plant, Waynesboro, Virginia.  Prepared for the Office of Air
     Quality Planning and Standards, U.S. Environmental Protection
     Agency, during development of New Source Performance Standards
     for the synthetic fibers industry.  Pacific .Environmental Services,
     Inc.  Research Triangle Park, North Carolina.  May 1, 1980.

4.   Report of the Initial Plant Visit to DuPont Corporation May
     Plant, Camden, South Carolina.  Prepared for the Office of Air
     Quality Planning and Standards, U.S. Environmental Protection
     Agency, during development of New Source Performance Standards
     for the synthetic fibers industry.  Pacific Environmental Services,
     Inc.  Research Triangle Park, North'Carolina.  April 29, 1980.

5.   Report of the Initial Plant Visit to Monsanto Company acrylic
     fiber plant, Decatur, Alabama.  Prepared for the Office of Air
     Quality Planning and Standards, U.S. Environmental Protection
     Agency, during development of New Source Performance Standards
     for the synthetic fibers industry.  Pacific Environmental Services,
     Inc.  Research Triangle Park, North Carolina.  April 1, 1980.

6.   Report of Initial Plant Visit to Tennessee Eastman Company,
     Kingsport, Tennessee.  Prepared for the Office of Air Quality
     Planning and Standards, U.S. Environmental Protection Agency,
     during development of New Source Performance Standards for the
     synthetic fibers industry.  Pacific Environmental Services, Inc.
     Research Triangle Park, North Carolina.  December 13, 1979.

7.   Report of the Plant Visit to Globe Manufacturing Company, Gastonia,
     S.C.  U.S. Environmental Protection Agency.  Office of Air Quality
     Planning and Standards.  Research Triangle Park, N.C.  December 1,
     1981.
                                7-15

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8.   Reports of the Phase II  Pl;ant Visit  to  Celanese  Fibers  Company
     Celriver acetate plant,  Najrrows,  Virginia.   Prepared  for the
     Office of Air Quality Planning and Standards,  U.S.  Environmental
     Protection Agency, during 'development of New Source Performance
     Standards for the synthetic  fibers industry.   Pacific Environmental
     Services, Inc.  Research Triangle Park,  North  Carolina,   flay 28,
     1980.

9.   Cheremisinoff, P.M. and  Eljlerbusch,  Fred.   Carbon Adsorption
     Handbook.  Ann Arbor Science Publishers,  Incorporated.   1978.

10.  Report of Phase II Plant Visit to Celanese  Fibers Company Celco
     acetate plant.  Rock Hill,; South  Carolina.   Prepared  for the
     Office of Air Quality Planning and Standards,  U.S.  Environmental
     Protection Agency, during development of .New Source Performance
     Standards for the synthetic  fibers industry.   Pacific Environmental
     Services, Inc.  Research Triangle Park,  North  Carolina.   August
     11, 1980.
                                7-16

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                          8.0  COST ANALYSIS

8,1  SYNTHETIC FIBERS COST ANALYSIS OF REGULATORY ALTERNATIVES
8.1.1  Introduction
     The following sections present estimates of the capital  and     • --   •
annual costs for each model plant and regulatory alternative  described
in Chapter 6.0.  These cost estimates are used to ascertain the economic
impact of the regulatory alternatives upon the solvent spun synthetic
fibers industry in Chapter 9.0.  To ensure a common cost  basis, Chemical
Engineering cost indices were used to adjust both process  and control
equipment to mid-1980 dollars.
     This chapter also includes estimates of the cost effectiveness  of
each alternative.  Cost effectiveness is typically estimated  by comparing
the total annualized control cost to the annual reduction  of  emissions
achieved.  The various control alternatives are ranked based  on their
relative cost effectiveness in  Section 8.4.
8.1.2  Model Plants/Regulatory Alternatives
     As explained in Chapter 6, the five model plants were developed
to be representative of the portion of the synthetic fibers industry
which includes wet and dry solvent spinning of the fiber.  The models
describe two fiber types, acrylic and cellulose acetate.   All fiber
types considered are solvent spun; wet spun acrylic fibers employ
dimethylacetamide; dry spun acrylics use dimethylformamide; dry spun
modacrylic,. eellulose acetate filament, and cigarette tow all employ
acetone as a spinning solvent.
8.2  .NEW FACILITY COSTS
8.2.1  Baseline Model Plant Costs
     The baseline model plants were developed to be representative of
basic organic solvent-spun manufacturing processes that  in EPA's
judgment are most likely to be constructed in the absence of  additional
                              8-1

-------
regulatory action.  Baseline capital costs  include  the  costs  for  tank
farms, chemical receiving and storage, dope preparation equipment,
spinning equipment, fiber processing equipment,  solvent recovery
equipment, manufacturing buildings, warehouse, quality  control
laboratory, and other ancillary manufacturing facilities  and  equipment.
Not included in baseline capital costs are  utility  generation, waste
treatment, streets, parking, land [purchase,, and  general support facilities
(cafeteria, medical facilities, administrative offices).  The baseline
annual costs are the costs of operating and maintaining the facility.
These include direct costs such as operating labor, maintenance labor
and equipment, utilities, and laboratory charges; fixed charges of
local taxes and insurance; and other general expenses such as plant
overhead, administration, and research.  These costs do not include a
depreciation factor.
     The purpose for estimating the baseline costs  of the five model
plants in question is to demonstrate the difference in  annualized
capital and operating costs among the various spinning  techniques.
Table 8-1 presents these costs along with the capital costs associated
with the baseline solvent recovery systems, which capture solvent only
from the spin cells, cabinets, or baths.
                                                     •
8.2.2  Costs of Regulatory Alternatives
     This section summarizes the assumptions used in developing the
control costs for the model plants and various control  options.   The
technical operating parameters are presented in  Chapter 6 and are not
repeated here.  Table 8-2 presents capital  and annual operating costs
associated with Regulatory Alternatives II  and III.  Table 8-3 compares
capital and annual operating costs under Alternatives II  and  III  that
additional emission control systems would add to the baseline costs.
Under Alternative II the additional costs of recovery equipment would
add 2.9 to 9.8 percent to the baseline capital costs and  an additional
1.1 to 4.5 percent to baseline anrjual operating  costs,  depending  on
the model plant in question.  Under Alternative  III capital costs
would increase by 6.3 percent to 12.4 percent; annual operating costs
would increase by 1.9 to 6.3 percent, depending  on  the  model  plant  in
question.
                               8-2

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                TABLE 8-2.  CAPITAL AND ANNUAL  OPERATING  COSTS
                     ASSOCIATED WITH MODEL  PLANT  OPTIONS
                            (Millions  of dollars)
Model Plant

Regulatory Alternative I
  (Baseline)
   Capital Costs


   Annual
   Operating Costs
Regulatory Alternative  II

   Capital Costs


   Annual
   Operating Costs
Regulatory Alternative  III

   Capital Costs


   Annual
   Operating Costs
72.2
51.6
69.5
46.3
45.1
23.1
67.1
25.7
83.. 6
27.1
76.0     72.5     46.4     70.1     91.8



52.2     46.8     23.4     26.4     28.5
78.7     75.0     48.1     71.3;    94.0



52.6     47.2     23.7     26.6:    28.8
NOTES:   1.   Figures  above  for  annual  costs  do not include recovery credits
             for  solvent, or  capital 'recovery costs.

         2.   Costs  are presented for  entire  affected  facility, with
             incremental  additional costs included in figures for
             Regulatory Alternatives  II and  III.

         3.   Annual costs do  not include raw materials processed, i,,e.,
             polymer, finish, and solvent.
                                      8-4

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-------
     Tables 8-4 through 8-8 display the capital outlay expenditures
and annualized costs for each regulatory alternative for model plants
1 through 5.  All equipment associated with absorption/adsorption
stripping columns are expressed as a fractional function of the major
equipment costs in Table 8-9.  From these  initial  investments, one can
estimate such capital related changes as plant overhead, property
taxes, insurance, and general administration; these charges are called
fixed annual operating costs.  To them are added  recurring direct
costs such as utilities, materials, and labor for operation and maintenance
of the equipment during its life.!  These annual costs do not  include
the costs of .capital and depreciation, raw materials, and distribution
or selling costs.  Table 8-10 provides the basis  for estimating the
annual operating costs for the regulatory  alternatives for model
plants 1 through 5; these estimates are presented in Tables 8-4 through  8-8.
Credits for increased amounts of recovered solvent resulting  from
increased capture and control of solvent vapor are not presented.
8.3  MODIFIED OR RECONSTRUCTED FACILITIES
     As defined in Chapter 5 of this report,  synthetic fiber  facilities
may undergo "modification" or "reconstruction" thereby bringing the
facility under the purview of the standard.   Retrofitting solvent
recovery equipment to existing synthetic fiber plants  poses certain
problems.  The amount of physical space necessary to  install  ventilation
ductwork to capture  and transport solvent  from process lines  is  a
definite constraining factor.  Equipment and  personnel must be able  to
move  along  process line aisles without  being  excessively hindered;
therefore,  installation of enclosures  at some existing facilities  is
not possible without a  complete  reconstruction  of the  entire  spinning
area.
      Scrubbers,  condensers,  distillation  columns, and  carbon  beds
require  additional utility distribution  systems  and larger  load  capacities
to accommodate them.  This could  cause  an  overload problem  at existing
plants.   Additional  utility  equipment  may  also pose space problems.
      The cost  of  installing  a  control  system in  an existing  plant that
has been modified,  reconstructedI  or expanded may be greater  than the
cost  of  a system for a  new faciljity with  the same exhaust gas parameters
because  of special  design  considerations.   In retrofitting  systems,

                                   8-6

-------
 Table  8-4.   COMPONENT CAPITAL  COSTS AND OPERATING COSTS  FOR
               MODEL  PLANT 1, ALTERNATIVE II  AND III
Direct Costs
1) Equipment Costs
Enclosures
Ducting ,
Adsorption/Stripping Columns
Fan, Pumps, Compressors
Instruments and Controls
Taxes
Freight
Total
2) Installation Direct Costs
Foundations and Supports
Erection and Handling
Electrical
Piping
Insulation
Painting
Site Preparation
Facilities and Buildings
Total
3) Installation Indirect Costs
Engineering and Supervision
Construction and Field Expenses
Construction Fees
Start-up
Performance Test
Contingencies
Total
Grand Total
DIRECT OPERATING COSTS
1) Operating Labor
a) Operator
b) Supervisor
2) Operating Materials
3) Maintenance
a) Labor
b) Material
4) Utilities
5) Waste Disposal
INDIRECT OPERATING COSTS
6) Overhead •
7) Property Tax
8) Insurance
9) Administration
Total Cost
CREDITS
10) Recovered Solvent
Component
Alternative II
Pol 1 ars
605,000
183,000
284,000
36,000
16,600
33,200
83,100
1,240,900
133,000
664,800
11,100
332,040
11,100
11,100
55,400
554,000
1,772,900
166,200
166,200
221,600
11,100
11,100
221,600
797,800
$3,811,600
Operat
Alternative II
Dollars
54,000
8,100
7,500
54,000
25,000
152,500
38, 100
117,800
38,100
38, 100
76,200
$609,400
570,000 kg/yr
Capital Costs
Alternative III
Do! 1 ars
806,500
274,500
723,000
79,000
28,200
56,500
141,200
2,108,900
226,000
1,129,800
18, 800
564,900
18,800
18,800
94,200
941,500
3,012,800
282,500
282,500
376,600
18,800
18,800
376,600
1,355,800
$6,477,500
ing Costs*
Alternative III
'Dollars
54,000
8,100
12,000
54,000
50,000
306,800
64,800
142,900
64,800
64,800
129,600
$951,800
1,140,000 kg/yr
*Annualized capital costs not included; see Table 9-34.
                                  8-7

-------
   Table 8-5.   COMPONENT  CAPITAL COSTS AND  OPERATING COSTS FOR
                  MODEL PLANT 2,  ALTERNATIVE  II AND  III
 Direct Costs
                                                   Component Capital Costs
                                            Alternative II          Alternative  III
                                               Dollars
Do!1ars
1) Equipment Costs
Enclosures
Ducting
Adsorption/Stripping Columns
Fan, Pumps, Compressors
Instruments and Controls
Taxes
Freight
Total
2) Installation Direct Costs
Foundations and Supports
Erection and Handling
Electrical
Piping
Insul ation
Painting
Site Preparation
Facilities and Buildings
Total
3} Installation Indirect Costs
Engineering and Supervision
Construction and Field Expenses
Construction Fees
Start-up
Performance Test
Contingencies
Total
Grand Total


DIRECT OPERATING COSTS
1) Operating Labor
a) Operator
b) Supervisor
2) Operating Materials
3) Maintenance
a) Labor
b) Material
4} Utilities
5) Waste Disposal
INDIRECT OPERATING COSTS '
6) Overhead
7 I Property Tax
8) Insurance
9) Administration
Total Costs
CREDITS ...
10) Recovered Solvent •• :.'

484,000
137,500
212,500
32,000
13,000
26,000
65,000
970,000

104,000
519,600
8,700
259,800
8,700
8,700
43,300
433,000
1,385,600

129,900
129 ,900
173,200
8,700
8,700
173,200
623,500

$2,979,200
Operating
Alternative II
Pol 1 ars

54,000
8,100
5,900

54,000
20,000
119,200
29;, 800

' 113, 000
29,800 "
29,800
59,600
$523,200

570,000 kg/yr

'605,000
255,500
656,500
79,000
23,900
47,900
119,700
1,787,500

191,500
957,600
16,000
478,800
15,900
16,000
79,800
798,000
2,553,600

239,400
239,400
319,200
16,000
16,000
319,200
'1,149,200

$5,490,300 ,
Costs*
Alternative III
Dol 1 ars

54,000 :
8,100
• 10,000

54,000 , ' -•
40,000
319,200
48, -000

133,000
55; 000 ' .
- 55,000
110,000
$886,300

1,173,000 kg/yr
*Annua1ized capital costs-not included;'see Table 9-34..
                                         8-8

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        Table  8-6.   COMPONENT  CAPITAL COSTS AND OPERATING  COSTS FOR
                         MODEL  PLANT  3, ALTERNATIVE II AWD  III
                                                         Component Capital Costs
                                                   Alternative II          Alternative III
 Direct Costs

 1) Equipment Costs
        End osu res
        Ducting
        Adsorption/Stripping  Columns
        Fan, Pumps,  Compressors
        Instruments  and  Controls
        Taxes
        Freight
        Total
 2) Installation Direct Costs
        Foundations  and  Supports
        Erection and Handling
        Electrical
        Piping
        Insulation
        Painting
        Site Preparation
        Facilities and Buildings
        Total
3) Installation Indirect Costs
        Engineering  and Supervision
        Construction and Field Expenses
        Construction Fees
        Start-up
        Performance  Test
        Contingencies
        Total

Grand Total
                                                       Dollars
                                                       125,000
                                                       230,000
                                                        22,000
                                                         5,700
                                                        11,300
                                                        28,300



                                                        45,200
                                                       226,200
                                                         3,800
                                                       113,100
                                                         3,800
                                                         3,800
                                                        18,900
                                                       188.500
                                                       603,300


                                                        56,500
                                                        56,500
                                                        75,400
                                                         3,800
                                                         3,800
                                                      •  75.400


                                                    $1,297,000
                                                                             Dollars
   248,000
   235,000
   353,000
    36,000
    13,100
    26,200
    65,400
   976,700


   104,600
   523,200
     8,700
   261,600
     8,700
     8,700
    43,600
   436.000
 1,395,100
   130,800
   130,800
   174,400
     8,700
     8,700
   174,400


$2,999,600
DIRECT OPERATING COSTS
                                                             Operating
                                                 Alternative II
                                                     Dollars
                                                                       Costs*
                                                                        Alternative III
1) Operating Labor
a) Operator
b) Supervisor
2) Operating Materials
3) Maintenance
a) Labor
b) Material
4) Utilities
5) Waste Disposal
INDIRECT OPERATING COSTS
6) Overhead
7) Property Tax
8) Insurance
9) Administration
Total Costs
CREDITS
10) Recovered Solvent

54,000
8,100
4,300
54,000
13,000
45,200
12,900

105,900
12,900
12,900
26,000
$349,200

1,024,000 kg/yr

54,000
8 100
10 \ 500
54,000
31,500
134,000
30,000

124,400
30,000
30,000
60,000
$566,500

1,980,000 kg/yr
*Annualized  capital costs not included;  see Table  9-34.
                                              8-9

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       Table 8-7.  COMPONENT CAPITAL COSTS AND  OPERATING COSTS FOR
                     MODEL PLANT 4,  ALTERNATIVE  II  AND III
Direct Costs
1) Equipment Costs
End osu res
Ducting
Adsorption/Stripping Columns
Fan, Pumps, Compressors
Instruments and Controls
Taxes
Freight
Total
2) Installation Direct Costs
Foundations and Supports
Erection and Handling
Electrical
Piping
Insulation
Painting
Site Preparation
Facilities and Buildings
Total
3) Installation Indirect Costs
Engineering and Supervision
Construction and Field Expenses
Construction Fees
Start-up
Performance Test
Contingencies
Total
Grand Total
DIRECT OPERATING COSTS
1) Operating Labor
a) Operator
b) Supervisor
2) Operating Materials
3) Maintenance
a) Labor
b) Material
4) Utilities
5) Waste Disposal
INDIRECT OPERATING COSTS
6 Overhead
7 Property Tax
8 Insurance
9 Administration
Subtotal
SHUTDOWN COSTS
10) Labor and Lost Production
Total Costs
CREDITS
11) Recovered Solvent
Component Capital Costs
Alternative II Alternative III
Dollars Pol 1 ars
242,000 423,000
120,000 180,000
650,000 820,000 :
100,000 125,000
111,200 154,800
33,400 46,500
83,400 116,100
1,340,000
89,000
155,700
44,500
22,200
11,100
11,100
55,600
556,000
945,200
166,800
83,400
222,400
22,200
11,100
• 222,400
$3,013,500
Operating
Alternative II
Pol 1 ars
54,000
8,100
7,500
54,000
90,400
42,300
30,100
176,800
30,100
30,100
60,200
583,600
120,000
$703,600
1,140,000 kg/yr
1,865,400
123,800
216,700 '
61,900
30,900
15,500
15,500
77,400
774,000
1,315,700
232,200
116,100
309,600
30,900
15,500
309,600
1,013,900'
$4,195,000
Costs*
Alternative III
Don ars
54,000
8,100
19,000
54,000
125,800
105,000
41,900
166,600
41,900
41,900
83,800
742,000'
120.000
862,000 ;
1,620,000 kg/yr
*Annualized capital costs not included; see Table 9-37.
                                   8-10

-------
       Table 8-8.   COMPONENT CAPITAL COSTS AND OPERATING  COSTS FOR
                     MODEL PLANT  5, ALTERNATIVE II AND  III
Direct Costs
1) Equipment Costs
Enclosures
Ducting
Adsorption/Stripping Columns
Fan, Pumps, Compressors
Instruments and Controls
Taxes
Freight
Total
2) Installation Direct Costs
Foundations and Supports
Erection and Handling
Electrical
Piping
Insulation
Painting
Site Preparation
Facilities and Buildings
Total
3) Installation Indirect Costs
Engineering and Supervision
Construction and Field Expenses
Construction Fees
Start-up
Performance Test
Contingencies
Total
Grand Total
DIRECT OPERATING COSTS
1) Operating Labor
a) Operator
b) Supervisor
2) Operating Materials
3) Maintenance
a) Labor
b) Material
4) Utilities
5) Waste Disposal
INDIRECT OPERATING COSTS
6) Overhead
7) Property Tax
8) Insurance
9) Administration
Total Costs
CREDITS
10) Recovered Solvent
Component Capital Costs
Alternative II Alternative III
Dol 1 ars Do! 1 ars
1,750,000
1,210,000
155,000
46,700
93,500
233,600
3,488,800
249,200
436,100
124,600
62,300
31,200
31,200
155,700
1,557,500
2,647,800
467,300
233,600
623,000
62,300
31,100
. 623,000
2,040,300
$8,176,900
Operating
Alternative II
Dol 1 ars
54,000
8,100
'102,700
54,000
245,300
205,300
81,800
331,700
81,800
81,800
163,500
$1,410,000
1,600,000 kg/yr
1,950,000
1,835,000
187,000
59,600
119,200
297,900
4,448,700
317,700
556,000
158,900
79,400
39,700
39,700
198,600
1,986,000
3,376,000
595,800
297,900
794,400
79,400
39,700
794,400
2,601,600
$10,426,300
Costs*
Alternative III
Pol 1 ars
54,000
8,100
119,600
54,000
285,000
239,100
104,300
371,400
104,300
104,300
208,600
$1,652,700
2,240,000 kg/yr
*Annualized capital costs not included; see Table 9-37.
                                    8-n

-------
                TABLE 8-9.  COMPONENT CAPITAL COST FACTORS
                   FOR ABSORPTION/ADSORPTION STRIPPING
                    AS A FUNCTION OF EQUIPMENT COSTS
Direct Costs
Equipment, f.o.b.
  Manufacturer
Instruments and Controls
Taxes
Freight
Foundations and Supports
Erection and Handling
Electrical
Piping
Insulation
Painting
Site Preparation
Facilities and Buildings
Absorption Factor    Adsorption Factor
      1.000
      0.015
      0.030
      0.075
      0.120
      0.600
      0.010
      0.300
      0.010
      0.010
      0.050
      0.500
1.000
0.015
0.030
0.075
0.080
0.140
0.040
0.020
0.010-
0.010
0.050
0.500
Indirect Costs
Engineering and Supervision
Construction and Field Expenses
Construction Fee
Start-up
Performance Test
Contingencies
      0.150
      0.150
      0.200
      0.010
      0.010
      0.200
0.150
0.075
0.200
0.020
0.010
0.200
NOTES:  1.  Ducting costs include all ductwork, elbows, tees, expansion
            joints, dampers, and transition pieces of stainless steel.
        2.  Costs include stainless steel components on adsorbers.,
            absorption column internals, distillation column internals,
            condensers, and piping where solvent liquid or vapor
            contacts surface.
        3.  Distillation columns are included as a cost of each control
            option regardless of solvent recovery method.  This scenario
            was assumed in order to provide a worst-case cost.  Critical
            design parameters for Costing the distillation (stripping)
            columns included column diameter, number of plates, type
            and spacing of plates,'operating pressure, heat  input to
            the reboiler and heat output from the condenser.
                              8-12

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                TABLE 8-9.  COMPONENT CAPITAL  COST  FACTORS
                   FOR ABSORPTION/ADSORPTION STRIPPING
               AS A FUNCTION OF EQUIPMENT COSTS  (Concluded)
NOTES:  4.  Carbon adsorber costs are for basic custom built systems,
            not package units.  Equipment costs include  preconditioning,
            blowers, three adsorbers, activated carbon,  condenser,
            storage tank, all process valves, distillation  system,
            instrumentation/controls, and accessories.

        5.  Absorption and stripping columns are bubble  cap tray  and
            plate towers. The costs of absorption and stripping towers
            are a function of the size, thickness, and materials  of
            construction.  The design parameters used in costing
            include the column diameter, column height,  operating
            pressure, column pressure drop, number of transfer units,
            tray efficiency, tray spacing, tray material, column  shell
            material, thickness of shell wall, and liquid and gas flow
            rates.  The cost of the fabricated vessel includes the
            cost of the shell plus the cost of two heads, a skirt for
            support, flange-type nozzles.  To these  are  added the tray
            cost and support plates.  Ancillary equipment such as fans
            and blowers are included under separate  entry.
        6.  In order to avoid the potential build-up of  an  explosive
            concentration, air flow and solvent concentration monitoring
            instrumentation with machine shutdown capability are
            included in Model Plant 4 costs under "Instrument and
            Controls."  Multiple monitors and numerous monitoring
            locations are incorporated for redundancy and added safety
            margin.  Also included in the costs for  "Fans,  Pumps,
            Compressors" are the costs associated with back-up exhaust
            fans with power for operation received from  two independent
            sources (e.g., electrical and steam turbine).  Back-up may
            also involve a nonelectrical means of purging such as
            steam jet ejectors which could force the solvent/air
            mixture out of the enclosures.  The equipment costs asso-
            ciated with the prevention of excessive risk amount to
            about 10 percent of the total  capital  cost of the control
            options.

        7.  Model  Plant 5 costs for adsorption/stripping columns
            include extensive pretreatment of the gas stream for
            contaminant removal  and dehumidification.  The equipment
            consists of filter,  cooler,  and reheater to condition the
            gas before entering  the adsorbers.
                              8-13

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                 TABLE 8-10.  BASIS FOR ESTIMATING ANNUAL OPERATING COSTS
                                 FOR REGULATORY ALTERNATIVES
  Direct Operating Costs

      Operating Labor
        Direct Operator
        Supervision

      Operating Materials

      Maintenance
        Labor
        Materi al

      Utilities
        Water
        Electricity
        Steam

      Waste Disposal

  Indirect Operating Costs

      Overhead
      Property Tax

      Insurance

      Administration

  Credits

      Recovered Solvent.
                                   $108,000/yr/rnan/shift
                                   15 percent of direct labor

                                   Per plant control process
                                   Equal to operating labor
                                   3 percent of total capital costs
                                   $0.25/1000 gal.
                                   $0.04/kWh
                                   $4.0/1000 Ibs.

                                   L percent of total capital  costs
                                   80 percent of operating and maintenance
                                   Tabor plus maintenance materials

                                   1 percent of total capital costs

                                   1 percent of total capital costs

                                   2 percent of total capital costs
                                   Dependent on  specific  plant  process  and
                                   recovery system
NOTE:
Model Plant 4 annual operating cost includes the costs of shutdown of  the
spinning machines- resulting from the. application and use of enclosures  on  the
spin cell exits and tow line-.  The costs represent the increased  labor  necessary
to restart the machines and the. production  lost during the shutdown  period.
                                            8-14

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additional costs may be encountered because  of  such  items  as  demolition
requirements, crowded construction working conditions,  scheduling
construction activities with production  activities,  and longer inter-
connecting piping.  Availability of space, additional ducting,  and
additional engineering must be considered.   These  constraints must  be
taken into account when costing the retrofitting of  recovery  equipment
at synthetic fiber plants.  Estimating the additional installation
cost or retrofit penalty  is dependent on the many  factors  peculiar  to
the individual plant.
     Configuration of equipment in the existing plant governs the
location of th.e control system.  Depending on process or stack location,
long ducting runs from ground level to the control device,  stack, and
reprocessing equipment may be required.   Costs  may increase considerably
if the control equipment  must be placed  on the  roof  and requires steel
structural support.   It is estimated  that rooftop  installation can
double the structural costs.  In addition, labor would  probably have
to be done at premium wage rates in accordance  with  governmental
regulations  and/or union  agreements.  Other  cost components that may
increase  because of space restrictions and plant configurations are
contractor's fees and engineering  fees,  which are  estimated at 15 percent
and 20 percent for a new  facility, but may be expected  to  increase  to
20 percent and 30 percent for a retrofit. These fees depend on the
difficulty of the job, the risks involved, and  the current economic
conditions.
     The  annual operating costs of control systems for
modified/reconstructed facilities  are calculated similarly to those
for new facilities.  The  cost items may  be equal to  or  greater than
costs for new facilities, depending on the specific  layout of the
control equipment and affected facility.
8.4  COST EFFECTIVENESS
8.4.1  Model Plants
     Cost effectiveness,  expressed in annualized costs  per megagram of
emission  reduction, for Regulatory Alternatives II and  III for model
                               8-15

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plants 1 through 5 are presented  in Tables  8-11,  8-12,  and  8-13.   All
costs, production levels, emission reductions,  etc.,  are  based  on
model plant parameters described;  in Chapters  6  and  8.
     Under Alternative II, model  plant  1  shows  a  zero cost  effectiveness
when compared to baseline, Alternative  I; the costs of  controls for
emission reduction are offset by;  the value  of the recovered solvent.
Model plant 3 shows a net gain of $182/Mg under Alternative II; the
additional solvent that could be  recovered  beyond baseline  would
result in decreased annualized costs.   Model  plants 2,  4, and 5 show
positive cost effectiveness of $166, $166,  and  $588 per Mg  VOC  reduction,
respectively, when compared to Alternative  I.
     Under Alternative III, model plants  1  and  3  show a net gain  or
annual savings of $350 and $193 per Mg  of emission  reduction, respectively,
when compared to the baseline.  Model plant 2 would experience  a  zero
cost effectiveness under this alternative.  However, model  plants 4
and 5 would incur positive increases in annual  costs of $120 and  $442
per Mg of emission reduction, respectively, above the baseline  case.
     Compared to Alternative II,  the application  of Alternative III to
the model plants would result in  decreased  annualized costs Of  control
and thus in decreasing cost per Mg of emission  reduction, as presented
in Table 8-13.
8.4.2  Projected 1987 Cost Effectiveness
     The projected capacity shortfalls  as presented in  Tables 9-20 and
9-30 of Chapter 9 lead to the following conclusions concerning  likely
capacity additions by synthetic fiber producers by  1987:
     (1) The projected capacity shortfall arising from  the  high growth
projection for acrylic and modacrylic fibers  would  support  additional
plant capacity.  For this analysis, it  is assumed that  capacity is
constructed-in increments of model plant capacity,  and  that plants of
model plant 2 type would be built.  Two plants, each with 45.36 Gg
capacity, would be constructed by 1987  since  there  would  be significant
capacity shortfall if only one were constructed.  These two plants
would each operate at 81 percent  capacity utilization in  1987.   (Table 9-11
in this BID indicates that this capacity utilization rate is well
within the range of historical values.)
                                8-16

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-------
      (2) The projected capacity shortfall arising from the low growth
 projection for acrylic and modacrylic fibers would not support additional
 capacity.   This shortfall  would likely be met by debottlenecking
 current production processes.
      (3) The projected capacity shortfall arising from the high growth
 projection for cigarette filtration tow would support additional
 capacity by 1987.   Again,  it is assumed that capacity is constructed
 in  increments  of model  plant capacity.  Four plants, each with 22.7 Gg
 capacity,  would be constructed.  These four plants would each operate
 at  95  percent  capacity utilization.  A capacity shortfall of 4.3 Gg
 would  still  exist,  but this shortfall  would not support an additional
 plant.
      (4) The projected  capacity shortfall arising from the low growth
 projection for cigarette filtration tow would also support additional
 plant  capacity by  1987 (capacity that would be constructed in increments
 of  model plant capacity).   Two  plants, each with 22.7 Gg capacity,
 would  be constructed.   These two plants would each operate at 95  percent
 capacity utilization.   Excess capacity of 1.7 Gg would exist.
      (5) The projected  capacity shortfalls arising from either the
 nigh or  low  growth  projections  for  cellulose acetate textile yarn
 would  not  support  additional capacity  by 1987.
     Based on  the  above conclusions,  comparisons of annualized costs
 per megagram of  emission reduction  were made for those plants that  are
 most likely  to be  built in  the  next 5  years.   All  three regulatory
 alternatives were  examined.  Compared  to the baseline, Alternatives II
 and III  result in  emission  reductions  of 5.6 and 8.5 Gg/year, respectively,
 by  1987.   Using  these  emission  reduction figures,  annual ized  costs  per
megagram of  emission reduction  for  typical  plants  would  be  as much  as
 $392 and $2Q2, respectively, for Alternatives  II and III.
     At  these  same  plants,  Alternative III  would result  in  an annual
total emission reduction of. about 3.0  Gg/year  more than  Alternative II.
Alternative  III would have  an annual cost of $2.4  million  more than
Alternative  II;  however, the value  of  the additional  solvent  recovered
would decrease the  annual cost  by roughly the  same amount.   Thus,
there would  be no net cost  per  megagram  of  emission  reduction to  the
 industry in  implementing Alternative III  over  Alternative  II.   Table  8-14
presents the projected  1987 cost effectiveness of  the  regulatory  alternatives,
                                   8-20

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           Table  8-14.   PROJECTED 1987  COST EFFECTIVENESS
                      OF  REGULATORY ALTERNATIVES

Growth
Scenario
1982-1987
Number of
Affected
Facilities
1987
Alternative II*
Solvent
Credit
(105$)
Alternative III1
Solvent Credit
Baseline
Annual Cost
(106$/yr)
Alternative II
Annual Cost
(106$/yr)
Alternative III
Annual Cost
(106$/yr)
Alternative II
Net Annual Cost
(106$/yr)
Alternative III
Net Annual Cost
(106$/yr)
Alternative II
Emission
Reduction (Mg)
Alternative III
Emission
Reduction (Mg)
Alternative II
Cost
Effectiveness
($/Mg)
Alternative III
Cost
Effectiveness
($/Mg)
Acrylic/Modacrylic
high low
2 0
1.1 0.0
2.2 0.0
108.0 0.0
108.4 0.0
108.4 0.0
0.4 0.0
0.4 0.0
1020
1980
392
202
Cellulose Acetate 1
Filter Tow | Totals
high low
4 2
3.0 1.5
4.3 2.1
128.0 64.0
128.8 64.4
128; 8 64.4
0.8 0.4
0.8 0.4
4570 2280
6560 3280
175 175
122 122
high low
6 2
4.1 1.5
6.5 2.1
236.0 64.0
237.2 64.4
237.2 64.4
1.2 0.4
1.2 0.4
5590 2280
8540 3280
215 175
141 122
*Amount of solvent recovered multiplied  by solvent cost, $1.09/kg DMF and
 $0.62/kg acetone.
                                 8-21

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8.5  REFERENCES

 1.  Neveril, R.B. et.al.  Capital and Operating Costs of Selected Air
     Pollution Control Systems.  CARD, Inc.  EPA-450/5-80-002.
     December 1978.  pp. 5-31 to 5-38 and 5-50 to 5-65.

 2.  Air Pollution Engineering Manual.  AP-40.  Environmental Protection
     Agency.  OAQPS.  May 1973.  pp. 220-227.

 3.  Foust, A.S., et. al.  Principles of Unit Operations.   John Wiley
     & Sons, Incorporated., 1960.  pp. 11-14.

 4.  McCabe, W.L. and Smith, J.C.  Unit Operations of Chemical Engineering,
     Second Edition.  McGraw-Hill iBook Company.  1967.   pp. 517-539.

 5.  Reference 4, pp. 549-607.

 6.  Peters, M.S. and Timmerhaus, K.D.  Plant Design and Economics for
     Chemical Engineers.  McGraw-Hill Book Company, Second  Edition.
     1968. pp. 614-655.

 7.  Vatavuk, W.M. and Neveril, R.B.  Estimating Costs of Air Pollution
     Control Systems; Part I:  Parameters for Sizing Systems.  Chemical
     Engineering.  October 6, 1980. pp. 165-168.

 8.  Handbook of Chemistry and Physics, Forty-Eighth Edition.  The
     Chemical Rubber Company.  1967. pp. F-10.

 9.  Perry, R.H. et. al. Section 14:  Gas Absorption and Solvent
     Extraction.  Chemical Engineer's Handbook.  McGraw-Hill Book
     Company, Fourth Edition.  1963.  pp. 14-24 through  14-34.

10.  Reference 9, Section 18:  Liquid-Gas Systems, pp. 18-  through 18-25.

11.  Reference 9, Section 13:  Distillation, pp. 13-7, 13-21 through
     13-29, 13-51 through 53.

12.  Calvert, J. et. al. "Wet Scrubber System Study" Volume I.  Scrubber
     Handbook.  APT, Incorporated.  EPA R2-72-118A, CPA  70-95..  duly
     1972.

13.  Letter from Zerbonia, R.A., PES, Incorporated, to Natho Massey,
     AAA Technology and Special Company, Incorporated.   September; 3,
     1980.  Use of "Concept Program to Simulate Absorption/Distillation
     Columns.

14.  Letter and attachments from Massey, N.A., Process Simulation
     Consultant, AAA Technology and Specialties Company, Incorporated,
     to Zerbonia, R.A., PES, incorporated.  October 1, 1980.  Computer
     Runs to Simulate the Absorber/Stripper Columns.

15.  Telecon.  Bjorness, R.A., Metex Process Equipment Corporation,
     with Berard, R.E., PES, Incorporated.  September 15, 1980.  Cost
     data for binary absorption columns of varying parameters.
                              8-22

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16.  Telecon.  McCallister, Bill, Vulcan Manufacturing Company with
     Berard, R.E., PES, Incorporated.  September  10,  1980.   Cost  data
     for binary absorption columns of varying  parameters.

17.  Telecon.  Breeding, Larry, Glitsch, Incorporated, with  Berard,
     R.E., PES, Incorporated.  September 22, 1980.  Cost data for
     binary absorption columns of varying parameters.

18.  Control Techniques for Volatile Organic Emissions from  Stationary
     Sources.  Environmental Protection Agency/OAQPS, EPA-450/2-78-022.
     May 1978.  Chapter 3, pp. 24-51, pp. 70-82.

19.  Parmele, C.S. et. al. "Vapor-Phase Adsorption  Cuts Pollution,
     Recovers Solvent" Chemical Engineering.   December 31, 1979.
     pp. 58-70.

20.  Reference 1, pp. 5-39 through 5-50.

21.  Cheremisinoff, P.N. and Ellerbusch, Fred.  Carbon Adsorption
     Handbook.  Ann Arbor Science Publishers,  Incorporated.  1978.

22.  Reference 2, pp. 189-198.

23.  Reference 18, pp. 52-69.

24.  Vatavk, W.M. and Neveril, R.B.  "Estimating  Costs of Air Pollution
     Control Systems Part III: Estimating the  Size  and Cost  of Pollutant
     Capture Hoods."  Chemical Engineering.  December 1, 1980.  pp.  111-115.

25.  McDermott, H.J.  Handbook of Ventilation  for Contaminant Control.
     Ann Arbor Science Publishers, Incorporated.  1976.  pp. 101-185.

26.  Industrial Ventilation-A Manual of Recommended Practice.  American
     Conference of Governmental Industrial  Hygienists.  1980.

27.  Vatavuk, W.M. and Neveril, R.B.  "Estimating Costs of Air Pollution
     Control Systems - Part IV: Estimating the Size and Cost of Ductwork."
     Chemical Engineering.  December 29, 1980.  pp. 71-73.

28.  Reference 1, pp. 4-15 through 4-29.

29.  Click, C.N. and Moore, D.O.  Emission, Process, and Control  Technology
     Study of. the ABS/SAN, Acrylic Fiber, and  NBR Industries; Pullman-Kellogg,
     (Report to EPA, Contract No. 68-02-2619, Task  No. 6).   April 1979.
     Appendix D.

30.  Economic Impact Assessment for Acrylonitrile.  Enviro Control,
     Incorporated.  (Report to OSHA, Contract  Mo. J-9-F-6-0229, Task 3).
     February 21, 1978.

31.  Reference 1, pp. 4-47 through 4-66.
                              8-23

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32.  Letter and attachments from Sonntag, D.F., Amcec Corporation, to
     Zerbonia, R., PES, Inc.  December 4, 1981.  Budgetary proposals
     for the supply and installation of solvent recovery systems.

33.  Telecon.  Quade, Jack, DCI Corporation, with Gladding, D.,  PES,
     Inc.  October 6, 1981.  Preliminary cost figures for a carbon
     adsorption solvent recovery system.

34.  Letter and attachments from Davis, W.L., Nuclear Consulting
     Services, Inc., to R. Zerbonia, PES, Inc.  November 13,  1981,
     Budgetary proposals for the supply and  installation of solvent
     recovery (carbon adsorption) systems.

35.  Letter from Detjen, E.P., VARA International,  Inc.,  to  Gladding,
     D.. PES, Inc.  October 29, 1981.  Quoted budget prices for
     (3) carbon adsorption solvent recovery  systems.

36.  Telecon.  Shaw, Nathan, VIC Manufacturing Company, with  Gladding,
     D., PES, Inc.  October 8, 1981.  Preliminary costs for carbon
     adsorption solvent recovery systems.

37.  Telecon.  Spencer, R., Raysoly, Inc., with Gladding, D.  PES,  Inc.
     October 1981.  Preliminary costs for carbon adsorption solvent
     recovery systems.

38.  Letter from Hoi den, J.T., Sutcliffe Speakman,  Inc., to Gladding,
     D., PES, Inc.  December 24, 1981.  Budget costs for three solvent
     recovery systems.

39.  Letter from Pullen, J.C., Celanese Fibers Company, to National
     Air Pollution Control Techniques Advisory Committee.  September  8,
     1981.  Proposed NSPS  for synthetic fiber production facilities.

40.  Report of meeting with Pullen, J.C., Celanese  Fibers Company, and
     EPA/PES synthetic fibers NSPS; project team.  December 3,  1981.
     Technical and economic issues.

41.  Statement from Ritchie, Tom, Tennessee  Eastman Company,  to  National
     Air Pollution Control Techniques Advisory Committee.  September  22,
     1981.  Proposed NSPS  for synthetic fibers production facilities.

42.  Report of meeting with Vaughn McCoy, et.al., Tennessee Eastman
     Company,.and EPA/PES  synthetic fibers NSPS project team.
     December 1,  1981.  Technical and economic issues.

43.  Statement from Earnhart, C.R., DuPont Company, to National  Air
     Pollution Control Techniques Advisory Committee.  September 22,
     1981.  Proposed NSPS  for synthetic fibers production facilities.

44.  Report of meeting with Earnhart, C.R.,  DuPont  Company, and  EPA/PES
     synthetic fibers NSPS project team.  November  1981.  Technical  and
     economic issues.
                               8-24

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45.  "Thermal Incinerator Performance for NSPS",  EPA Memorandum  from
     D. Mascone to J. Farmer, EPA/CPB, June  11,  1980 and  Addendum July
     22, 1980.

46.  Reference 1.

47.  Reference 18.

48.  Report of Fuel Requirements, Capital Cost  and  Operating  Expense
     for Catalytic and Thermal Afterburners, CE  Air Preheater Industrial
     Gas Cleaning Institute, Stamford, Conn.  EPA Report  No.
     EPA-450/3-76-031, Setpember 1976.
                               8-25

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                         9.0  ECONOMIC IMPACT

9.1  INDUSTRY CHARACTERIZATION
9.1.1  Industry Overview
     Manmade fibers are of two types:  cellulosic, and  nonce!lulosic
or synthetic.  Data on the production of cellulosic fibers  are  classified
by the U.S. Department of Commerce in Standard  Industrial Classification
(SIC) code 2823, Cellulosic Manmade Fibers.  Data on  the  production of
noncellulosic fibers are classified in SIC 2824, Synthetic  Organic
Fibers, Except Cellulosic.  Cellulosic fibers are known generically as
cellulose acetate, cellulose triacetate, and rayon..  They are produced
from cellulose, the fibrous substance in plants, especially that
derived from spruce and other soft woods.  Most noncellulosic fibers
are polyester, nylon, acrylic, modacrylic, or polyolefin.   The  feedstocks
for these fibers are polymerized petroleum derivatives.   The three
types of cellulosic fibers, together with these five  types  of noncel-
lulosic fibers* currently comprise approximately 99 percent of  manmade
fiber production.
     The first manmade fiber manufactured in the United States  was
rayon in 1910.  By 1930, U.S. production of rayon, acetate,  rubber,
glass, nylon, and vinyon supplied 10 percent of the fibers  used by
domestic textile mills.  Commercial production  of saran (1941), metallic
(1946), modacrylic (1949), acrylic (1950), polyester  (1953),  triacetate
(1954), spandex (1959), aramid (1961), and olefin (1961)  fibers followed.
By 1979 manmade fibers comprised 75 percent (4,413.8  gigagrams*)  of
domestic mill consumption.  The use of cotton fiber by  U.S.  mills
declined from 81 percent to 24 percent over the period  1940-1979; the
use of wool declined from 8 percent to less than 1 percent.
*0ne gigagram equals 1,000 megagrams or  2,207 x  10   pounds.
                                9-1

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     The most significant growth in the manmade fibers  industry  occurred
between World War II and the 1974-75 recession.   Historical  production
data by fiber type are presented in Table 9-1.  Data  for  1979  are
presented in absolute and percentage terms to  illustrate  the relative
importance of each fiber type by quantity of production.  Table  9-2
provides quantity of production and value of shipments  data  by fiber
type for 1977, the most recent year for which  value of  shipments data
are available.  Nylon fiber prices have historically  exceeded  polyester
fiber prices, causing an incongruity in percentage.of production and
percentage of value data.
     9.1.1.1  Role of the Synthetic Fibers Industry in  the U.S..  Economy.
The shares of 6NP, employment, and new capital expenditures  contributed
by the manmade fibers industry to the national economy  provide a
measure of the industry's significance.  The most recent  data  available
to calculate these shares are published by the U.S. Department of
Commerce.  Industry data were .obtained by summing the relevant variables
from SIC 2823, Cellulosic Manmade Fibers, and  SIC 2824, Synthetic
Organic Fibers, Except Cellulosic, from the  1977  Census of Manufactures.
Domestic economy aggregates were obtained from the Survey of Current
Business.
     In 1977, the manmade fibers industry supplied 0.17 of  1 percent
of GNP and 0.1 of 1 percent of total employment.   New capital  expenditures
by the industry were 0.27 of 1.percent of expenditures  on new  plant
and equipment by all industries|that year.
     These ratios.underestimate the overall  significance  of  manmade
fibers in the economy.  As intermediate products, the fibers have
important interindustry linkages.  They supply approximately three-fourths
of the fiber (by weight) used by domestic textile mills,  which in  turn
supply apparel, home-furnishings, and industrial  markets. Most  types
of manmade fibers have other end uses as well.  For example, about
half of the production of cellulose acetate  is consumed as cigarette
filtration tow.  Nylon fibers are used in air  hoses,  racket  strings,
ropes and nets, tire cord, and thread.  Olefin fibers are used to
produce nonwoven felts, ropes and cordage, and sewing thread.  Rayon
has applications in medical and surgical products (it is  no  longer
                                 9-2

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used in the production of tire cord).  Modacrylics are used to  produce
filters, paint rollers, and wigs, in addition to their more prevalent
use in textiles manufacture.
     Some manmade fibers such as aramid and vinyon are consumed  entirely
by markets other than the textile industry.  Aramid fibers are  used  to
produce tires, ropes and cables, mechanical rubber goods  (such  as
gaskets) and structural supports for aircraft and boats.  Vinyon
fibers are used primarily by industries as a bonding  agent for  nonwoven
fabrics and products.  None of the manmade fibers has any significant
final  (as opposed to intermediate) demand.
     The manufacture of manmade fibers consumes intermediate  goods
produced by other industries, most significantly the  petrochemical and
organic chemicals industry.  Data on the most important materials used
by the nonce!lulosic and cellulosic fibers industries are provided in
the 1977 Census of Manufactures.  Principal material  inputs include
synthetic organic chemicals (especially acetic anhydride, acrylates
and methacrylates, acrylonitrile and glycols), inorganic  chemicals
(especially sodium hydroxide and sulphuric acid), plastic resins
(especially polypropylene and nylon resins), liquified petroleum and
refinery gases (ethane and ethylene, propane and propylene, butane,
butylene, and isobutane), natural gas, and paper and  paperboard containers.
Producers of cellulosic fibers additionally purchase  a significant
amount of wood pulp.
     9.1.1.2  The Synthetic Fibers of  Interest.  Fiber polymer  is
extruded through three major processes:  melt spinning, wet spinning,
(including reaction spinning) and dry  spinning.*  In  wet  and  dry
spinning, the fiber polymer must be dissolved in a solvent to produce
an extrudable solution.  The principal fibers produced by wet or dry
spinning are acrylics, modacrylics, and all cellulosics.  The solvents
used to dissolve the fiber polymers are of two generic types, volatile
organic compounds (VOCs) and aqueous salts.  The use  of VOCs  results
in fugitive emissions of the hazardous chemicals along the process
*A more detailed description of the production processes  for  each  of
 the manmade fibers is contained in Chapter  3.
                                9-5

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line.  Approximately 77 percent of current production  capacity  '   for
                                                          O
acrylic and modacrylic fibers and all  production  capacity   for  cellulose
acetate and triacetate fibers use volatile organic  solvents.
     Nylon, polyster, and olefin fibers  are  produced by melt  spinning,
which uses heat rather than solvent to melt  the fiber  polymer for
extrusion.  Melt spinning can be used  for these fibers because  heat
does not degrade the polymers.  Because  no solvent  is  needed, emissions
of volatile organic solvents do not occur.
     Wet spinning (but not including reaction  spinning) and dry spinning,
which use volatile organic chemicals as  solvents, are  the production
processes for which the EPA recommends further control of VOC emissions.
Maninade fibers falling under these proposed  New Source Performance
Standards (NSPS) include cellulose acetate and triacetate,  acrylic and
modacrylic, and some specialty fibers  such as  vinyon that are produced
in relatively small amounts.  Although some  spandex fibers  are  produced
by dry spinning, production of this fiber will not  be  affected  by the
NSPS because these plants already meet the recommended levels of
emission control.  Rayon fibers are currently  produced by the viscose
process, which is a significant source of carbon  disulfide  and  hydrogen
sulfide emissions.  However, the EPA was unable to  identify control
technology that would result in emission reductions beyond  existing
control levels.  Furthermore, industry sources report  that  in all
likelihood there will be no further expansion  of  viscose  rayon  capacity.
New nonviscose processes, which do not require the  use of sulfur-containing
compounds are being developed, and it  appears  that  producers  of rayon
will not increase capacity until a nonviscose  process  can be  implemented.
Viscose rayon processes have therefore been  excluded from the source
category subject to the proposed NSPS.
     Model plants reflecting new capacity in the  acrylics and modacrylics
industry and the cellulose acetate industry  were  constructed  by the
EPA.  Costs for the model plants^were  estimated for three alternative
levels of VOC control.  A profile of each of these  two industries is
provided as the first step in the economic analysis.
                                9-6

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9.1.2  Acrylic and Modacrylic Fibers   ;
     9.1.2.1  Production
     9.1.2.1.1  Product description.  Acrylic and modacrylic fibers
are noncellulosic (synthetic) fibers produced from the polymer polyacryloni-
trile.  Polyacrylonitrile is made from acrylonitrile, a propylene and
ammonia derivative.  Acrylic fibers are defined by the U.S. Federal
Trade Commission as "manufactured fiber in which the fiber-forming
substance is any long chain synthetic polymer composed of at least
                                             Q
85 percent by weight of acrylonitrile units."   The remaining 15 percent
or less of the fiber consists of comonomers, generally acrylates,
methacrylates, or vinyl monomers.  Modacrylic fibers are defined as
formed from a polymer composed of "less than 85 percent but at least
35 percent by weight of acrylonitrile units, except fibers qualifying
as lastrile or anidex."   Modacrylic fibers are made from copolymers
consisting of polyacrylonitrile and other materials such as vinylidene
chloride, vinyl chloride or vinylidene dicyanide.
     9.1.2.1.2  Production technology.*  Acrylonitrile is converted
into fiber polymer through suspension polymerization or solution
polymerization.  All acrylic fibers and approximately half of modacrylic
fibers domestically produced are manufactured through suspension
polymerization.
     In suspension polymerization acrylonitrile and comonomers are
polymerized in the presence of a catalyst.  Insoluble beads of polyacryloni-
trile polymer are formed that must be dissolved in a solvent to produce
an extrudable solution.  Monomers are recovered from the filtration
and washing steps and recycled to the polymerization reactors.
     In solution polymerization, acrylonitrile and comonomers are
dissolved in either an organic solvent such as dimethylformamide  .
(DMF), dimethylacetamide (DMAc) or acetone, or in a concentrated
aqueous solution of sodium thiocyanate (NaSCN) or zinc chloride (ZnCl2).
A catalyst is added to initiate the polymerization reaction.  The
polyacrylonitrile formed is soluble and therefore extrudable.  The
*A11 information on production processes has been taken from Chapter 3.
                                9-7

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filtration, washing, drying, grinding,  and  redissolving  steps  that
follow suspension polymerization are  avoided.
     After polymerization, the [solution  is  extruded  through  spinnerets
to form filaments.  During the extrusion  process,  the  solvent  in  which
the polyacrylonitrile was dissolved  is  removed.  The polymer resolidifies,
forming fibers.  Approximately |55  percent of domestic  acrylic  fibers
and 30 percent of domestic modacrylic fibers are produced  by wet
spinning; the remainder are produced  by dry spinning.
     In wet spinning, the solution is extruded  into  a  spinning  bath
containing solvent and water.  The diffusion of solvent  from the
filament to the bath, and the diffusion of  water to  the  filaments
results in a swollen gel filament  that must be  densified in
post-treatment of the fibers.
     In dry spinning, the polyacrylonitrile in  solvent is  extruded
through a spinneret into a column  of  hot  inert  gas.  Acetone and  DMF
are the preferred solvents for polymer solutions that  are  dry  spun.
As the solvent evaporates, the filaments  solidify.   The  solvent is
condensed in a solvent recovery section and recycled to  the  dissolving
step.  Both wet- and dry-spun fibers  require washing,  drawing,  finishing,
crimping, drying, stapling, and packing.
     Regardless of the polymerization or  extrusion process,  solvent is
captured and reused.  Volatile organic solvent  is  captured by  precipitation
or enclosures, scrubbed, and returned to  the polymerization, dissolving
and spinning steps.  Aqueous salt  solvents  (used only  in wet spinning)
are recovered by precipitating the solvent  from the  used solvent  bath
in a captive wastewater treatment  facility.
     Domestic acrylic and rnodacrylic  fiber  producers perform at least
polymerization of the input acrylonitrile.  Only two producers  purchase
acrylonitrile; the rest manufacture  it from captive  or purchased
propylene and ammonia.    The producers spin, cut, crimp,  and  bale the
fiber.  None of the producers are  integrated forward to  the  manufacture
of textiles.
     For the most part, the production technology  is well  established;
however, variations exist.  As noted  previously, either  suspension or
                               :9-8

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solution polymerization may be used.  Polymerization may  be  either
batch mode or continuous regardless of  the  polymerization process.
The solvent used to dissolve the polymer.may  be  either  a  volatile
organic compound or an aqueous salt.  The production technology  is
available for sale by the producers.
     9.1.2.1.3  Production history.  Modacrylic  fibers  were  first
commercially produced in the United States  in 1949  by Union  Carbide
Corporation.  Acrylic fibers in the form of continuous  monofilarnent
yarns were first produced in 1950 by E.  I.  du Pont  de Nemours  &  Company,
Inc.  Du Pont began producing acrylic staple  in  1952, and discontinued
production of acrylic ^onofilament yarn in  1956.  Only  small  amounts
have been produced since that time.  Data on  annual domestic production
of  acrylics and modacrylics for the period  1960-1980 are  presented in
Table 9-3.  Production of acrylic and modacrylic continuous  filament
yarn has never been significant, and therefore data are not  available.
Acrylic continuous filament yarn production from 1950 to  1956 and 1963
to  1965, and modacrylic yarn production from  1948 to 1954, is  believed
to  have totaled little more than one fifth  a  gigagram  (less  than one
                              13
half million pounds) annually.    Between 1960 and  1973,  output  increased
from 61.5 to 336.2 gigagrams, but it declined in 1974 and 1975,  falling
to  237.6 gigagrams.  Since 1975, production has  steadily  increased,
rising to 353.4 gigagrams in 1980.  The decline  in  output from 1973 to
1975 is explained by higher input (propylene) prices and  decreased
demand due to the worldwide recession occurring  in  those  years.
     9.1.2.1.4  Role in U.S. economy.   The  adrylics and modacrylics
fiber  industry contributed 0.0001 of 1  percent of total GNP, 0.006 of
1 percent of total employment,  and  0.003 of 1 percent  of  expenditures
on  new plant and equipment by all  industries  in  1977.
     These ratios are not mathematically significant from zero given
the accuracy of the data from which they were calculated.  As a measure
of  the importance of the acrylic and modacrylics industry to the
aggregate economy, these ratios  are misleading.   Because  acrylic and
modacrylic fibers are intermediate  products,  the industry functions as
both a demander of outputs of certain  industries and a  supplier of
inputs to other industries.
                                 9-9

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TABLE 9-3.  DOMESTIC PRODUCTION OF ACRYLIC AND
    MODACRYLIC STAPLE, TOW AND FIBERFILL
(EXCLUDING WASTE)11 12

1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978
1979
1980
Production
(gigagrams)
61.5
63.5
77.0
95.0
130. 3
166.9
159.9
180.2
236.0
241.4
222.8
247.0
283.5
336.2
285,9
237.6
281.3
321.1
328.7
344.8
353.4

(million
pounds)
135.7
140.1
170.0 ,
209.7
287.7
368.4
352.9 ,
397.7
521.0
533.0
491.9
545.2
625.9
742.1
631.2
524.6
621.0
708.8
725.7
761.1
779.2
                      9-10

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     The most significant purchases  by  acrylic  and  modacrylic  fiber
producers are acrylonitrile or the  inputs  to  its  production (propylene
and ammonia) and solvents such as acetone,\ DMAc,  DMF,  and  aqueous
salts.  The most significant market  for acrylic and modacrylic fibers
is the textile  industry, specifically knitting  and  weaving  mills,  and
carpet and rug manufacturers.  Textiles produced  from  acrylic  and
modacrylic fibers in turn supply manufacturers  of apparel,  blankets,
and draperies and curtains.  Acrylic and modacrylic fibers  compete
primarily with the wool  industry in  supplying the apparel market and
the nylon and polyester  industries  in supplying the home-furnishings
market.
     9.1.2.1.5  Factors  of production.  Acrylonitrile,  the  basic raw
material of acrylic and  modacrylic fiber production, is  produced by
reacting a mixture of propylene, ammonia,  and air in the presence  of a
catalyst.  Acrylonitrile is used as  an  intermediate in  the  production
of acrylic and modacrylic fibers, acrylonitrile-butadiene-styrene
(ABS) resins, styrene-acrylonitrile  (SAN)  resins, nitrile elastomers,
adiponitrile (a raw material in Nylon 66),  and  acrylamide monomers  and
polymers.
     In 1979, approximately 39 percent  of  the acrylonitrile produced
domestically was used in the manufacture of acrylic and modacrylic
fibers.  Another 17 percent was used to produce resins  such as  ABS,
3 percent was used in nitrile elastomers,  and 20  percent was used  in
miscellaneous applications including the manufacture of  intermediates
(such as adiponitrile) for the production of nylon.  The residual
                         14
21 percent was exported.
     Currently,  four firms manufacture  acrylonitrile; three are also
producers of acrylic and modacrylic fibers.  Table  9-4  lists these
producers, their plant locations, and plant capacities  as of January 1,
1981.   Two other firms have discontinued production of  acrylonitrile.
Union Carbide produced acrylonitrile between 1954 and 1966  in  a
small-scale operation in Institute,  West Virginia.  B.  F. Goodrich
produced acrylonitrile in a pilot plant at the  Avon Lake Technological
Center in the 1950s  and  in Calvert City, Kentucky,  from 1954 to 1972.
Both companies discontinued manufacture of the  product because their
                                9-11

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                                                            9-12

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plant capacities were too small to be competitive with  the  larger
producers.
     As indicated by Table 9-4, Monsanto Company recently expanded  its
acrylonitrile capacity by 50 percent.  Two other acrylonitrile  producers
are in the process of constructing new plant capacity.   Du  Pont has  an
acrylonitrile plant under construction at Victoria,  Texas,  that is  to
be completed by the fourth quarter of 1982.  The new plant  is  intended
to replace existing capacity.  Standard Oil Company  of  Ohio's  subsidiary,
Vistron Corporation, has additional capacity of 181  gigagrams  per year
under construction at Green Lake, Texas.  The  plant  is  expected to  be
completed in the fourth quarter of 1981.
     Both Eastman Kodak Company (Tennessee Eastman)  and Monsanto are
increasing propylene production capacity.  Eastman Kodak began  adding
50 percent to its current capacity of 181 gigagrams  per year  in 1981;
Monsanto has recently doubled  its current capacity of 249 gigagrams
per year in a joint venture with Conoco, Inc.
     Production of modacrylic  fibers requires  chlorinated vinyl
comonomers in addition to acrylonitrile as inputs to polymerization.
None of the modacrylic fiber producers manufactures  its own comonomers.
     The other raw materials used in acrylic and modacrylic fiber
production are primarily solvent and finish.   The solvents  used  by
domestic producers of acrylic  fibers are aqueous NaSCN  and  ZnClg, DMF
and DMAc.  Solvents used by domestic producers of modacrylic fibers
are DMF, DMAc, and acetone.
                                            19
     Du Pont manufactures both DMAc and DMF.    The  firm utilizes DMF
in its production of both acrylic and modacrylic fibers.  Monsanto
purchases DMAc for its production of the two fibers.  American  Cyanamid
Company and Badische Corporation produce only  acrylic fibers; they.use
an aqueous salt (NaSCN) and zinc chloride, respectively, for solvent.
Tennessee Eastman, which produces only modacrylic noncellulosic  fibers,
uses captively produced acetone as a solvent for these  fibers and for
its cellulose acetate textile  fibers and cigarette filtration tow.
     The final raw material used in the production of acrylic and
modacrylic fibers is finish.   The cost and availability of  finish were
determined by the EPA to have  negligible impacts on  production.
                                9-13

-------
     The 1977 Census of Manufactures reports that 5,700 persons are
employed in plants primarily producing acrylic and modacrylic fibers.*
Production workers involved in the polymerization and spinning steps
are semiskilled and are trained on the job for 1 year.  There are
usually two production workers per spinning line; acrylic and modacrylic
fiber production is capital rather than labor intensive.
     Producers of acrylic and modacrylic fibers can easily switch
between production of the two fibers.  Although raw materials differ—
production of modacrylic fiber requires a copolymer of acrylonitrile
and a chlorinated vinyl comonomer, and production of  acrylic fiber
requires a polyacrylonitrile polymer—both fibers are produced with
solvents such as DMF, DMAc, or acetone.  Processes for dissolving the
polymer in solvent and spinning the fibers are interchangeable between
the two types of fiber; therefore, the same capital machinery .can be
used for both.  Indeed, Eastman Kodak is reported to  use the same
polymerization, solution prepa'ration, and spinning equipment to manufacture
both modacrylic and cellulose'acetate fibers; hence the use of acetone
as the solvent for both fiber types.  Polymerization  and extrusion
facilities are general to all fiber types.  Machinery for texturizing
and cutting tow is specific to staple production; machinery for spinning
yarns from staple fibers is specific to yarn production.
     The relative amounts of acrylonitrile and comonomer, and the
relative amounts of polymer and ; sol vent, used to  produce acrylic and
modacrylic fibers may be varied, yielding fibers  with distinct
characteristics.  For example, the chlorinated vinyl  comonomers used
in modacrylic fiber production may be used to produce flame-resistant
fibers.  The relative amounts of polymer and solvent  employed  in wet
spinning are varied according to the denier of fiber  being manufactured.
There does not appear to be much potential for the substitution of
capital for labor in the polymerization and spinning  processes of
*This employment  figure  is  subject  to  error in  both  directions  due to
 the Census method of  classifying plants  by primary  product.   First,  the
 figure  excludes  employment in  plants  that manufacture acrylic  and mod-
 acrylic fibers as a secondary  product.   Second,  the figure includes
 employment that  is not  related !to  acrylic or modacrylic production in
 plants  that manufacture acrylic or modacrylic  fibers as a primary product,

                                9-14

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acrylic and modacrylic fibers.  Substitution of capital equipment for
solvent is evidenced by the increased recovery rate of solvent resulting
from emissions control equipment.
     9.1.2.2  Supply Conditions.  The most recent data for domestic
shipments of acrylic and modacrylic staple, tow, and waste fiber dis-
aggregated by apparel, home-furnishings, and industrial end uses
indicate that apparel consumed 68 percent of acrylic and modacrylic
               9fi
fibers in 1975.    Acrylic and modacrylic fibers were primarily used
to produce craft yarns; sweaters; pile fabrics; top-type fabrics for
shirts, blouses, and light-weight dresses; anklets and socks; and
bottom-type fabrics for pants, sportswear, and tailored clothing.   In
the home-furnishings market, which consumed almost 27 percent of
acrylic and modacrylic staple, tow, and waste fibers, the primary end
uses were carpets, rugs, and blankets.  The residual industrial uses
were primarily doll hair and fabric for toys, fiberfill, and stuffing.
Table 9-5 provides a breakdown of domestic shipments .by acrylic and
modacrylic staple and tow for the years 1970-1975.  The primary distinctions
of modacrylic fibers compared to acrylic fibers are that they duplicate
more closely the feel and appearance of natural fur, they dye more
easily and, due to the comonomers present  in the polymer, they may  be
modified  to be flame resistant.  A more detailed analysis of the end
uses for  acrylic and modacrylic fibers  is  provided in  Section 9.1.2.3.
     Acrylic and modacrylic fabrics are produced from  high-bulked
yarns spun from staple.  The yarns are  combinations of high- and
low-shrinkage staple.  Applying heat to the yarn causes the high-shrinkage
staple to squeeze the low-shrinkage staple to the  surface, making the
yarn bulky, fluffy,  and soft.  Mechanically crimping the staple fiber
gives the yarn even more bulk.  Therefore, the demand  is for acrylic
and modacrylic staple fiber,  and production of continuous monofilament
yarn has  been discontinued.
     Table 9-6 illustrates  the  relative magnitude  of production of
acrylic  and modacrylic fibers.  The table  indicates  that after  the
first few years, relative production stabilized  at a bit more  than
90  percent acrylic fiber.
                                 9-15

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       TABLE 9-5.  TOTAL SHIPMENTS OF ACRYLIC
           AND MODACRYLIC STAPLE AND TOW21
                     Cgigagrams)
Year
1970
1971
1972
1973
1974
1975
Acrylic
201.8
223.4
266.3
316.2
246.4
233.4
Modacry 1 i c
17.8
16.9
19.1
30.0
23.1
17.4
Totala
219.6
240, 2
285.4
346.2
269.5
250.8
Excludes waste; includes domestic shipments and exports.
                        9-16

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   TABLE 9-6.  DOMESTIC PRODUCTION OF
ACRYLIC AND MODACRYLIC BY FIBER TYPE12 13
               (gigagrams)

1948
1949
1950
1951
1952
1953
1954
1955
1956
1957
1958
1959
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978
1979
1980
Aery 1 i c
0.0
. 0.0
F0.5
0.5
5.0
6.8
11.8
26.3
32.2
43.9
45.8
58.9
56.6
59.3
71.1
87.4
119.6
153.1
144.5
163.1
215.2
222.0
205.2
229.7
264.6
305.3
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Modacrylic
FO.l
FO.l
0.5
0.9
0.9
0.9
0.9
1.8
2.3
3.6
3.2
4.5
5.0
4.1
5.9
7.7
10.9
14.0
15.4
17.2
20.8
19.5
17.7
17.2
19.0
30.8
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Total
FO.l
FO.l
Fl.O
1.5
5.8
7.7
12.7
28.0
34.3
47.6
49.2
63.2
61.5
63.5
77.0
95.0
130.3
166.9
159.9
180.2
236.0
241.4
222.8
247.0
283.5
336.2
285.9
237.6
281.3
321.1
328.7
344.8
353.4
Acrylic as
percent of total
0
0
F50.0
33.3
86.2
88.3
92.9
93.9
93.9
92.2
93.1
93.2
92.0
93.4
• 92.3
92.0
91.8
91.7
90.4
90.5
91.2
92.0
92.1
93.0
93.3
90.8
-
-
-
-
-
-
—
                  9-17

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     9.1.2.2.1  Domestic producers.  The domestic producers of acrylic
and modacrylic fibers are listed in Table 9-7.  Plant-specific capacity
data for 1970 and 1974-1981 are also presented.  Minor additions; to
capacity are evidence of improvements in the efficiency of capital
machinery.  The only plant closure occurred in June 1975, when Union
Carbide discontinued modacrylic fiber production in Charleston, West
Virginia.  The capital equipment of the plant was dismantled; the
capital machinery specific to spinning fibers was scrapped by Union
Carbide as no buyer could be found.    Union Carbide's plant had an
annual capacity of 10 gigagrams (22 million pounds) of fiber, which
was consumed in all modacrylic fiber markets and was particularly
important in the deep-pile fabrics, drapery, scatter-rug, and hairpiece
markets.25  Union Carbide was never able to generate sufficient demand
for this fiber to result in a profitable operation.
     Two of the producers, American Cyanamid and Badische Corporation,
will not be affected by the proposed NSPS because neither uses a
solvent that is a volatile organic compound.  American Cyanamid uses
an aqueous salt for solvent; Badische Corporation uses zinc chloride.
     In 1977, shipments by all domestic producers of acrylic and
modacrylic fibers  (yarn, staple, tow and waste) were valued at
$495.8 million by the Bureau of the Census.  Shipments by quantity
were estimated to be 336.3 gigagrams (741.4 million pounds).  The
implied average producer price is therefore $1.48 per kilogram
($0.67 per pound).  Shipments of acrylic and modacrylic staple were
estimated to have a value of $370.2 million and to total 259.1 gigagrams
(571.3 million pounds), for an implied producer price of $1.43 per
kilogram  ($0.65 per pound).  The:residual shipments of 77.2 gigagrams
(170.2 million pounds), valued at $125.6 million, can be assumed to
consist of multifilament yarn, tow, and salable waste.  Shipments of
monofilament yarn  in  1977 were estimated by the Bureau of the Census
to be zero; this  is consistent with data collected by the Textile
                  oc
Economics Bureau.
     The  relatively low value-to-weight ratio of the fibers, plus
their bulkiness,  tends to make shipping cost an important consideration
in the purchase decision of a fiber user.  As a consequence, a fiber
                                9-18

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9-19

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 producer who is closely located to his customers has a competitive
 advantage.   One would expect,  therefore, that fiber producers would
 locate  near fiber-consuming industries,  and this appears to be the
 case.   Acrylic  and modacrylic  fiber producers are concentrated in the
 southeastern United States, near the center of the domestic textile
 manufacturing industry.
     9.1.2.2.2   Industry structure and capacity.  Table 9-8 illustrates
 the  end-use markets that the various producers supplied in 1975,  the
 most current year  for which such data are available.  All  producers
 compete in  the  market for textilie staple and tow (for both apparel  and
 home furnishings).   American Cyahamid and Monsanto are the two competitors
 in the  market for  acrylic fiber for carpet.   End use of acrylic and
 modacrylic  staple  and tow in textile manufacture was approximately
 72 percent  of all  end uses in  1975.   Carpet manufacture accounted for
                             27
 about 27 percent of end  use.
     Many qualitative data indicate that the acrylic and modacrylic
 staple  and  tow  produced  by the various companies are differentiated
 and  have segmented  end  uses within apparel,  home-furnishings,  and
 industrial  segments  of  the market.   However,  no  detailed quantitative
 data are available  to confirm  or deny this  implication that the fibers
 produced by  the  various  companies  are not substitutable for one another.
     All  manufacturers  of acrylic  and modacrylic fibers have captive
 polymerization  facilities.   Eastman  Kodak and Badische purchase acrylonit-
 rile for polymerization;  the other three manufacturers make acrylonitrile.
 American  Cyanamid  produces  acrylonitrile from purchased propylene and
 captive  ammonia.  Monsanto  has  captive supplies  of  both propylene and
 ammonia.  Du  Pont produces  acrylonitrile from captive  supplies and
 supplemental  purchases of propylene  and  ammonia.   None of  the  modacrylic-
 fiber manufacturers  (Du  Pont,  Eastman, Monsanto)  produces  its  own
                                                  OQ
 vinyl chloride or vinylidene chloride comonomers.
     American Cyanamid manufactures  and  sells products in  five major
 areas:    agricultural  chemicals  including fertilizers,  pesticides,
 animal  feed,  and veterinary products;  consumer toiletries,  hair
 preparations, and perfumes; Pharmaceuticals;  industrial  and  specialty
                                              OQ
chemicals; and Formica construction  products.     American  Cyanamid
                                9-20

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31
 does not manufacture textiles from its acrylic fibers, but sells the
 fibers as an intermediate good (staple and tow forms) to textile
 manufacturers.   The firm does manufacture acrylic sheet and acrylic
                   30
 molding compounds.
      Eastman Kodak  is the world's largest producer of photographic
 products, manufacturing amateur and professional  films and equipment
 and  related  supplies.  In addition to synthetic textile fibers (acetate,
 modacrylic,  and  polyester),  Eastman Kodak produces plastics and chemicals.
 The  company  does not manufacture textile products from its fibers.
      Du Pont is  the largest  domestic chemical  producer, manufacturing
 nylon,  polyester,  acrylic and specialty fibers; chemicals and pigments;
 elastomers,  films,  engineering resins and other plastic products; and
 medical,  printing,  electronic, explosives and  agricultural  specialty
          32
 products.     Du  Pont produces aramid, nylon,  olefin,  polyester, spandex
                   33
 and  Teflon fibers,    which are sold directly  to textile producers.
 The  firm  also manufactures acrylic finishes and coatings and filled
                           34
 acrylic building products.
     Monsanto is the fourth  largest producer  of chemicals in the
 United  States.   Primary products  of the company are  herbicides, insecticides,
 nitrogen  fertilizers,  industrial  and specialty chemicals, intermediates,
 plastics  and resins,  process controls and electronics, chemical and
                                                       35
 environmental systems,  and nylon  and polyester fibers.    A producer
 of acrylonitrile, Monsanto makes  ABS and  SAN resins  as well  as acrylic
 and  modacrylic fibers.   Manmade  fibers  generated  approximately 17 percent
                             OC
 of Monsanto's sales  in  1979.
     Badische Corporation  has  been fully  owned by BASF-Ag of West
 Germany since 1978.   Prior to  that,  the company was partly  owned  by
 BASF and  Dow Chemical,  under the^name Dow Badische Company.
     Table 9r9 indicates the relative importance  of fiber sales to
 each domestically owned  producer of  acrylic or modacrylic fibers.   It
 is evident from  the  companies  that make acrylic and modacrylic fibers
 that the  industry is  a  part  of the chemical industry.   Production  of
 acrylic and modacrylic  fibers  is  closely  linked with  the production of
 the  polymers and solvents  used as  inputs.  The fiber  producers sell  to
diverse markets, but do  not  themselves  compete in  textile,  carpet or
other end-use markets.

                                9-22

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      The  capacity  data for the industry,  presented in Table 9-10,
 indicate  a  high degree of concentration.   There is a small  number of
 firms.,  and  currently more than 70  percent of total capacity is owned
 by the  two  largest firms,  Du  Pont  and  Monsanto.  Further,  both the
 acrylic and modacrylic segments  of the industry are dominated by two
 companies.  In the case of acrylics,  Du Pont and Monsanto  operate more
 than  70 percent of total  capacity; in  the case of modacrylicsa Eastman
 Kodak and Monsanto operate more  than  85 percent of total  capacity.
     Table  9-11 provides  production and production capacity time-series
 data for the aggregate domestic  acrylic and  modacrylic industry.
 Growth  in capacity was rapid  in  the years 1960-1974; the  compound
 annual  average rate of growth  was  nearly  10  percent, compared to a
 rate  of just less  than 1  percent from  1974 to 1980.
     Capacity increases were  supported by the growth in production
 from 1960 through  1973, with  only  minor and  temporary setbacks in 1966
 and 1970.  A drastic decline  in  production (some 30 percent)  occurred
 over the years 1974 and  1975.  Since  1976, production has  again  increased,
 although capacity  has  remained stable.   Consequently, by  1980 the
 operating rate for the industry  was approximately 90 percent.  The
data presented in  Table 9-6 indicate that most production  growth (and
 absolute production) has  occurred  in acrylic  rather  than modacrylic
fibers.  All production is  in  staple and  tow  forms of fiber;  the
 production of waste fiber  (approximately  5 percent)  is  ancillary.
     9.1.2.2.3  Industry  performance.   Table  9-12 contains  annual
financial  data for  the domestically owned  producers  of  acrylic and
modacrylic fibers  for  the years  :1977 through  1979.   It  is  evident that
net sales for the  four companies have  kept pace with,  and  probably
exceeded,  the rate  of  inflation  over the  period.   The earnings before
 interest and taxes  of  Du  Pont  and  Eastman  Kodak have also  kept pace
with inflation.   Hith  the exception of Du  Pont,  all  companies  increased
their nominal  levels of long-term  debt  over the period; however  it is
not evident that any firms  increased real  levels  of  long-term  debt.
All four of the companies appear to be  financially sound overall.  The
caveat must be added that these  [aggregate  financial  data shed  no light
on the financial  status of the mpdacrylic- and  acrylic-producing
                                9-24

-------
                 TABLE 9-10.  DOMESTIC PRODUCERS OF ACRYLIC
              AND MODACRYLIC FIBERS RANKED BY CAPACITY, 197510
Company
E. I. du Pont de Nemours &
Co. , Inc.
Monsanto Co.
American Cyanamid Co.
Dow Badische Co.a
Eastman Kodak Co.
Company
E. I. du Pont de Nemours &
Co. , Inc.
Monsanto Co.
American Cyanamid Co.
Dow Badische Co.a
Company
Eastman Kodak Co.
Monsanto Co.
E. I. du Pont de Nemours &
Co. , Inc.
Rank
1,2
1,2
3
4
5
Rank
1
2
3
4
Rank
1
2
3
Percent of
total acrylic and
modacrylic capacity
38.0
32:4
15.6
9.0
5.0
Percent of
acrylic capacity
40.6
32.3
17.2
9.9
Percent of
modacrylic capacity
53.3
33.3
13.3
Cumulative
percent
36.2
70.4
86.0
95.0
100.0
Cumulative
percent
40.6
72.9
90.1
100.0
Cumulative
percent
53.3
86.6
99.9
Dow Badische Co. was a joint venture of Dow Chemical Company (U.
Overzee, N.V.  In June 1978, the company was sold to BASF-Ag of
was later renamed Badische Corp.
S.A.) and BASF
W. Germany and
                                     9-25

-------
        TABLE  9-11.   PRODUCTION  AND  PRODUCTION  CAPACITY OF
           ACRYLIC AND  MODACRYLIC  FIBERS,  1960-198012  3S  39
Year
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978
1979
1980
Capacity9
(gigagrams)
93.8
97.4
103.3
119.1
152.7
202.0
228.8
243.7
278.6
292.2
298.5
316.2
341.6
356.5
373.3
374.6
393.7
393.7
391.8
394.1
394.1
Total
production
(gigagrams)
61.5
63.5
77.0
95.0
130.7
166.9
159.9
180.2
236.0
241.5
222.8
247.0
283.5
336.2
285. 9
237.6
281.3
321.1
328.7
344 . 8
353.4
Capacity
utilization
(percent)
66
65
75
80
86
83
70
74
85 ;
83 :
75
78
83
94
77
63
71
82
84
87
90
November of the year.
                               9-26

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9-27

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 divisions of the firms.  As shown  in Table 9-9,  fiber  sales  by  Du  Pont
 and possibly Monsanto do not appear to have declined in  real  terms,
 but those of Eastman Kodak and American Cyanamid have.   Given the
 escalating costs of polymer and solvent, this would seem to  indicate
 that these firms are experiencing declining rates of return  for fiber
 production.   The outlook for capacity increases without  prior improvement
 in rates of  return is bleak.
      9-l»2.3  Demand Conditions.  The demand for acrylic and modacrylic
 fibers is driven by the demand for final products that are several
 processing and marketing steps removed from the production of the
 fibers themselves.   For example, a substantial portion of the demand
 for acrylic  and modacrylic staple and tow comes from the knitting
 mills  of the textile industry,   these mills,  in turn, respond to
 consumer demand for sweaters,  socks, shirts,  etc.,  as expressed through
 retail  and wholesale apparel markets.
     Textile mills  often blend  acrylic and modacrylic fibers with
 other  types  of fibers  to make  textile yarn.   The demand for the fibers
 is therefore derived from consumer demand  for a highly reworked> mixed
 fiber  product.   Once spun into  yarn, the fiber is woven into cloth to
 be cut  and sewn into apparel,  linking  final  consumer demand with the
 output  of acrylic and  modacrylicifibers.   The demand for acrylic and
 modacrylic fiber used  in automobile interiors  or household  carpeting
 depends  on consumer  demand  for  automobiles  and home  construction.
     9.1.2.3.1   Fiber  end uses.   The Textile  Economics  Bureau conducts
 periodic  surveys to  determine the  end  uses  that  support fibers production.
 The results  of  the surveys  are  reported  first  in  the periodical,
 Textile Organon, and then  in more  comprehensive  form every  five  years
 in the Man-Made  Fiber  Producers' Base  Book.  The  most detailed end-use
data for  acrylic and modacrylic  fibers published  from the surveys
 apply to  staple  and  tow  shipments.   This is expected  since  staple  and
tow have  accounted for approximately 95 percent of acrylic  and modacrylic
shipments  in recent years.
     The end-use data may be further partitioned  into three general
classes:  apparel,  household'furnishings, and  industrial  and  other
consumption.   Tables 9-13 to 9-15 present time-series data for acrylic
                                9-28

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9-30

-------
        TABLE 9-15.  SHIPMENTS OF ACRYLIC AND MODACRYLIC STAPLE AND TOW
                  BY INDUSTRIAL AND OTHER CONSUMER END USES43
                                  (gigagrams)
End use
1968   1969   1970   1971   1972   1973  1974  1975
Flock
Doll hair, toys, etc.
Fiberfill and stuffing
Felts
Filtration
Bags and bagging
Coated and protective
fabrics
Other industrial and
consumer uses
Total
0
0.
0.
0
0.
9.

0.
5.
15.

5
1

2
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2
2
4
0
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0.2
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4.5
19.2
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1
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4.3
 Other industrial and other consumer uses include narrow woven fabrics,
 medical, surgical and sanitary fabrics, transportation upholstery, sewing
 thread, paper and tape reinforcing, paint roller covers, wiping cloths,
 tobacco shade cloth, and other.
              TABLE 9-16.   SHIPMENTS OF ACRYLIC AND MODACRYLIC
                            FIBER WASTE BY END USE44
                                  (gigagrams)
End use
1968   1969   1970   1971   1972  1973  1974  1975
Pile fabrics
Other apparel
Blankets
Needle-punched carpets
Other carpets and rugs
Drapery
Upholstery
Nonwoven structures
Filling and stuffing
Rope, cordage and twine
Other domestic
Total domestic
Exports
Total waste
1.
0.
1.
1.
1.


0
0

0
6.
0.
6.
7
2
5
7
5






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1.9


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1.4
9.6
1.4
0.5
5.3
1.4
1.2


0
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0
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0.3
11.2
0.3
0
6.7
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1.6


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1.8

0
10.6
0
10.6
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0
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0
2.


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0.
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2
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4

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0
9.0
                                    9-31

-------
  and modacrylic staple and tow shipments to various end uses within
  each of these three classes.   In 1975,  the last year for which fairly
  disaggregated end-use data are available,  apparel  end use accounted
  for 71  percent of domestic shipments to domestic processors of fiber.
  Home-furnishings  end  use  accounted  for  26  percent of such shipments;
  the  residual  was  consumed  in  industrial  and other consumer applications,
  Within  the various  apparel  categories,  the largest end uses were
  estimated to  be in  craft yarns (25.6 percent),  sweaters (20.1 percent),
  pile fabrics  (20.0  percent),  anklets and socks  (12.6 percent)  and
  top-type fabrics  (12.6 percent).  Among home-furnishings  end uses,
 most of the fiber shipped  in  1975 was used  in tufted-face .broadloon
  rugs (61.0 percent) and blankets  (26.9  percent).   Doll  hair,  toys,
 etc., accounted for 40.6 percent of  industrial  use of acrylic  and
 modacrylic fibers.
      These data series illustrate the recent variations and  trends  in
 the end use of acrylics and modacrylics.  The fluctuations  in  the
 shipments to apparel end uses appear to reflect changes in  style, such
 as the popularity of polyester knits in the mid-1970s,  and world
 events,  such  as the increased use of sweaters associated with  the rise
 in energy prices after 1973.  Shipments  of acrylic and modacrylic for
 use in  blankets have risen dramatically since 1972-1973, while the use
 of acrylic and modacrylic  in rugs appears to have fallen off since
 1968 due to competition from nylon fibers.   Data that distinguish
 between  acrylic and  modacrylic end use are  not available.
      Shipments of  acrylic  and  modacrylic waste by end use  are presented
 in  Table 9-16.   This table  shows ithat over  the period 1968-1975.,  the
 use of acrylic and modacrylic  waste  in pile fabrics and needle-punched
 carpets  was phased out, while  its  use in  blankets  (over 52 percent  of  "
 waste shipments  in 1975) and filling  and  stuffing  grew considerably.
     Time-series data  on domestic shipments  of acrylic and modacrylic
 staple,  tow, and waste by the  three principal  classes  of end use  and
 exports  are presented  in Table  9-17,  As mentioned  previously,  the
 apparel  end use dominates acrylic and modacrylic consumption,  and most
of the remaining shipments  are  to the home-furnishings industry.
                                9^-32

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      Acrylic and modacrylic fibers can be blended with other fibers
 when spun into yarn.  Such blending may enhance the characteristics of
 other fibers as well as substitute for them.  As a result, the market
 role of acrylic and modacrylic fibers relative to other fibers is
 difficult to establish.  Because of the characteristics of acrylics
 and modacrylics, they appear to! compete most directly with natural
 fibers such as wool  or cotton in the sweater, sock and pile-fabric
 markets.   On the basis of end-use data for bottom-type and top-type
 fabrics,  acrylic and modacrylic fibers appear to compete also with
 natural  fibers and  polyester.   End-use data indicate competition with
 nylon and polyester fibers in the carpet market.  The data presented
 in  Table  9-18 show  that the role of acrylics and modacrylics in the
 staple and tow market declined dramatically relative to that of nylon
 and polyester between 1960 and 1975.
      In  summary, the market for acrylic and modacrylic fibers is both
 diverse and driven  by consumer demand several  steps•removed from
 actual fiber production.   Shipments of acrylic and modacrylic fibers
 are 95 percent staple and tow, most of which is spun and knit into
 apparel.   Other fibers  may either complement or substitute for acrylic
 or  modacrylic staple and  tow,  depending on the particular fiber and
 end use considered.   While it appears that acrylics and modacrylics
 have at least maintained  their competitive position relative to natural
 fibers, they have been  losing  portions of their apparel  and home-
 furnishings market to polyester and nylon.   Foreign competition in the
 acrylic and modacrylic  fiber market is indirect,  coming principally
 from imports  of finished  consumer goods.
      9.1.2.3.2 Foreign  trade.   Exports of acrylic  and  modacrylic  fiber
 staple and  tow have  grown faster  than domestic consumption.   Between
 1963 and  1980,  annual compound growth in  exports was  17.9  percent,  as
 compared  with  6.5 percent growth  in shipments  to domestic  processors.
 Even  so,  exports of  staple and tow accounted  for only  24.1 percent of
 all  shipments  of acrylic  and modacrylic staple and  tow in  1980.
 Exports of  waste have been very small  or  insignificant in  recent
years.
                                9-34

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                                               9-35

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      Imports of acrylic and modacrylic fibers, shown in Table 9-19,
 have generally declined since the early 1970s.  In 1980, staple and
 tow imports were 6.0 gigagrams.  Of course, fiber produced abroad is
 most likely to be imported in the form of finished goods such as
 imported clothes.  Textile Organon refers to "substantial imports of
 finished products, such as neckties, sweaters, blankets, tablecloths,
 rugs,  hosiery, shirts, suits and dresses, etc., (which) are not included
 in the (end-use) survey ...."
     9.1.2,4  Projections.  Projections of growth for the acrylic and
 modacrylic fibers industry contained in published sources vary consid-
 erably.   Consequently, with a current industry capacity utilization
 rate of  90 percent,  the various growth projections yield strikingly
 different results for projecting dates for capacity additions.  The
 following paragraphs summarize the projected growth rates contained in
 published sources.
     Data Resources,  Inc., (DRI) in  its publication Chemical  Review
 (Winter  1979)  forecast quantity of production  of  acrylic fibers  for
 the  years 1982,  1985,  1990 and 1995,  with  a base  year of 1978.4/  The
 implied  average  annual  growth  rates  compounded  annually are 0.7  percent
 through  1982,  5.6 percent  in  the period 1982-1985,  1.8 percent in
 1985-1990,  and 1.5 percent from 1990  to 1995.   The  implied  average
 annual growth  rate (compounded annually)  over  the  period from  the  base
year to  1990 is  2.3  percent.   The  capacity  shortfalls  projected  by DRI
 (assuming maximum capacity utilization  of 92 percent) were 25  gigagrams
 (56  million pounds)  in  1985,  63 gigagrams  (138  million  pounds) in
 1990, and 96 gigagrams  (211 million  pounds)  in  1995.
     DRI  also projected growth  in  domestic  consumption  for these same
years.   The implied  average annual growth  (compounded annually)  for
the  period 1978  to 1990 is  3.4  percent.  The difference  in the projected
                                 i
growth rates for domestic  consumption  and for production  are due to
projected growth rates  for imports, exports, and changes  in inventory
levels over the  period.
     As mentioned, 1978 data were  the most  recent available at the
time URI projected growth  rates.  The projections are therefore  somewhat
dated.   In contrast with other  projections  and  in light  of the general
                                9^36

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TABLE 9-19.  ACRYLIC AND MODACRYLIC FIBER IMPORTS12 3S
                      (gigagrams)
Year
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978
1979
1980
Staple and tow
6.5
13.0
8.8
15.8
22.3
15.6
12.0
21.8
19.3
19.4
8.8
3.8
7.5
7.4
8.2
5.9
6.0
Waste
1.0
1.5
1.4
1.6
2.2
1.9
2.5
3.7
4.6
4.4
3.1
2.0
2.5
1.6
N/A
N/A
N/A
Total
7.5
14.5
10.2
17.4
24.4
17.5
14.5
25.5
23.9
23.9
11.8
5.8
10.0
8.9
N/A
N/A
N/A
                         9-37

-------
 economic conditions of the years  1979 to  1980,  the  DRI projectons
 somewhat overstate growth in those years.
      Chemical and Engineering News (C&EN) in the December 1,  1980,
 issue reports that demand for acrylic fibers grew at an average annual
 rate of 3.8 percent from 1976 to end-of-the-year 1979, and that growth
 in 1980 was comparable.  C&EN reports that some acrylic fiber producers
 expect growth in demand of 5 percent in 1981.   However, some producers
 are forecasting "long-term growth for acrylic fibers at no more than
                     48
 1 percent per year."   These growth projections are less than satisfactory
 because they are difficult to interpret.  The bases and sources for
 the projections are not clear, making it difficult to determine their
 reliability and appropriateness.
      Textile Industries in February 1979 forecast rates of growth in
 domestic mill  fiber consumption (domestic shipments plus imports) for
                                                40
 cellulosic, noncellulosic and synthetic fibers.    The original  sources
 for the data were the  Textile Economics Bureau and International
 Research Associates.   Growth in domestic mill consumption of all
 fibers  is projected  to result from reduced imports,  increased exports
 and increasing population.   For acrylic and  modacrylic fibers, the
 projected average annual  rates  of growth in  domestic mill  consumption
 are 1.9  percent through 1982 and 1.6  percent in the  period 1982-1987.
 These projections  do not  specifically address projected growth in
 production; however, the  qualitative  statement  that  imports  of fiber.
 will  most likely decline  suggests  that  these growth  rates  do  not
 overestimate comcomitant  growth  in production.
      The final  published  source  of data  for  projected  growth  in the
 acrylics  and modacrylics  fiber  industry  is the  January  1981  issue  of
                 50
 Textile  Organon.    The Organon  summarizes a  speech  by  Dr. David  K.
 Barnes of Du Pont that  presented  Du Font's forecasts of growth  in
 domestic  consumption of various  noncellulosic synthetic fibers,.
 Domestic  consumption of acrylic  fibers was forecast  to  grow at an
 average  annual rate of  2.7 .percent during  the period 1979  to  1985.
 Again, this forecast is not equivalent to  a forecast for growth in
 domestic production because growth or decline in import and export
markets  is  not addressed.  However, imports of  acrylic  and modtitcrylic
                                9-38

-------
  fibers have generally declined since the early 1970s, so that  it would
  not appear that projected growth of 2.7 percent in domestic mill
  consumption would overestimate growth in domestic production.
       To supplement these forecasts from published sources, EPA estimated
  regression equations  using time-series data on domestic production of
  acrylic and modacrylic  fibers.   These regression equations provided
  "in-house" projections  that were additional  indicators of likely
  growth  in  domestic  production  of acrylic and modacrylic fibers.  The
  annual  production data  used to  estimate  the  regression equations  were
  collected  by the Textile  Economics  Bureau  for the  years 1960-1979.
       The regression equations estimated  a  relationship between  production
  and time.   This relationship was  used  to estimate  production  at future
  points  in  time.  The equations  estimated were of two  forms.   The  first
  estimated  the values of a  and b  in  the following equation:
                        production = a(year)  + b  .
 The second regression equation estimated values of c  and d in the
 following equation:
               natural  log  (production) = c(year) + d.
 Both equations  are linear equations; the second is identified as
 "log"-linear,  because  the equation is  estimated given values that are
 the natural logarithms  of the production  data.
      Because of  the  cyclical nature of acrylic and  modacrylic fiber
 production, particularly in the  years  1973  to 1979, regressions  were
 run  on three distinct time intervals of data.  The  first case included
 annual  production data over the  entire period 1960  to 1979.   The
 second and  third cases used subsets  of the  data employed in  the  first
 case.   The  second case employed  annual  production data from  the  years
 1970 to  1979 only, and the  third  case  used  data from  1975  to  1979
 only.
     The log-linear regression equation projected growth  in domestic
 production  of acrylic and modacrylic fibers of 8.7  percent using
 1960-1979 production data,  3.5 percent using  1970-1979  data, and
9.0 percent using 1975-1979 data.  The growth  rate  projected using
1970-1979 data was determined to have the best  statistical fit to the
                                9-39

-------
 data.  Also?  this time interval'allows  for some adjustments by  producers
 In resppqsfi |g  general economicicpnditipns,  and captures the effects
 of the leye]  of maturity of the1 industry  and pf market cycles of  the
 industry.
      Linear regression equations, do not project a constant growth  rate
 as dp logrlipear regression equations,,  byt rather estimate a discrete
 growth rate assoctatgd with every ppi.nt in time.   Again, the time
 interval 1970-1§7§  provided a prp.jle
-------
Year
1980
1981
1982
1983
1984
1985
1986
1987
Growth
Rate
%
1.9
1.9
1.9
1.6
1.6
1.6
1.6
1.6
Estimated
Production
(gigagrams)
351.4
358.0
364.8
370.7
376.7
382.6
388.7
395.0
Estimated
Production
Capacity
(qiqagrams)
394.6
394.6
394.6
394.6
396.5
402.7
409.2
415.8
Estimate
Capacity
Shortf al 1
(qigagrams)
0
0
0
0
1.9
8.1
14.6
21.2
     Estimated production capacity is the larger  of  1)  the  capacity
estimated to be in place in 1980 and 2) the capacity  required,  at  a
95 percent capacity utilization rate, by estimated production.  The
production capacity estimated to be in place  in 1980  is  394.6 gigagrams
(see Table 9-7).  Estimated capacity shortfall is the difference
between the estimate of current capacity, and the capacity  needed  to
meet the production estimates at a 95 percent capacity  utilization
rate, that is, the column "Estimated Production Capacity".
     The second published growth projection, from the January 1981
issue of Textile Organon, was a projection of 2.7 percent growth
through 1985.  Again 1979 was used as the base year, with production
of 344.8.  (The projection has been extended to 1987 for comparative
purposes.)
Year
1980
1981
1982
1983
1984
1985
1986
1987
Growth
Rate
%
2.7
2.7
2.7
2.7
2.7
2.7
2.7
2.7
Estimated
Production
(qigagrams)
354.1
363.7
373.5
383.6
393.9
404.6
415.5
426.7
Estimated
Production
Capacity
(qigaqrams)
394.6
394.6
394.6
403.8
414.6
425.9
437.4
449.2
Estimated
Capacity
Shortf al 1
(gigagrams)
0
0
0
9.2
20.2
31.3
42.8
54.6
     Estimated production capacity and estimated capacity shortfall
were calculated as described above.
     As mentioned, in-house linear and log-linear regressions were
estimated to project further estimates of growth in the  acrylics  and
                                9-41

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modacrylics market.  Both projections were based upon  annual production
data from 1970-1979.  These data are:
                                Year
                                1970
                                1971
                                1972
                                1973
                                1974
                                1975
                                1976
                                1977
                                1978
                                1979
                             Production
                             (qigagrams)
                                222.8
                                247.0
                                283.5
                                336.2
                                285.9
                                237.6
                                281.3
                                321.1
                                328.7
                                344.8
Two equations were estimated.  The first was a direct linear equation
and was of the form:
                               prodt =
                             (t)
where
prod = production estimated in year t
t    = year, t = 1970, 1971,...1979
     = intercept of fitted line
     = slope of fitted line
The coefficients estimated were:*
                    prod. = -19395.08000000 + 9.96909091(t)
                        r     (7142.500)       (3.617)
                                    R2 = 0.487
This equation was then used to make projections of production for the
years 1980-1987.
          Year-
    Growth   Estimated
     Rate   Production
            (qiqagrams)
1980
1981
1982
1983
1984
1985
1986
1987
2.9
2.8
2.7
2.7
2.6
2.5
2.5
2.4
343.7
353.7
363.7
373.6
383.6
393.6
403.5
413.5
Estimated
Production
Capacity
(qiqaqrams)
394.6
394.6
394.6
394.6
403.8
414.3
424.7
Estimated
Capacity
Shortf al 1
(qiqaqrams)
0
0
0
0
9.2
19.7
30.1
                                             435.3
                                             40.7
*The standard error for each estimated value is provided  in parentheses
 beneath each estimated value.
                                9-42

-------
     Estimated production is obtained by substituting the value of the year
in the regression equation obtained from historical data.  For example,
substituting t = 1980 into the direct linear equation for acrylic and
modacrylic fiber yields:
                     prodt = -19395.08 + 9.96909091 (1980)
                     prod  = 343.7
                         I*
     Estimated production capacity and estimated capacity shortfall were
calculated as described above.
     The second equation estimated was log-linear and was of the form:
                             In(prodt) =   +   (t)
All definitions from above hold.  The coefficients estimated were:*
                   ln(prod.) = -64.14961461 + 0.03535337(t)
                          t     (25.414)       (0.013)
                                      R2 = 0.485

This equation was used to project production levels of:

Year
1980
1981
1982
1983
1984
1985
1986
1987

Growth
Rate
3.5
3.5
3.5
3.5
3.5
3.5
3.5
3.5

Estimated
Production
(gigagrams)
347.3
359.7
372.7
386.1
400.0
414.4
429.3
444.8
Estimated
Production
Capacity
(gigagrams)
394.6
394.6
394.6
406.4
421.1
436.2
451.9
468.2
Estimated
Capacity
Shortf al 1
(gigagrams)
0
0
0
11.8
26.5
41.6
57.3
73.6
     Estimated production is obtained by substituting the value of the year
in the regression equation obtaned from historical data.  For example,
substituting t = 1980 into the log-linear equation for acrylic and
modacrylic fiber yields:
                 log (prodt) = -64.14961461 + 0.03535337 (t)
*The standard error for each estimated value is provided in parentheses
 beneath each estimated value.
                                9-43

-------
                 log  (prodt) = 5.85005799
                       prodt = 347.3
     Estimated production capacity, and estimated capacity shortfall
were calculated as described above.
     Table 9-20 presents the range of projected capacity shortfalls  in
1987.  The range was constructed from the highest and the lowest
estimates of the four estimates for capacity shortfall presented
above.  Two assumptions are included in these calculations.  They  are:
(1)  Any capacity shortfall before 1982 will be met  by debottlenecking
     existing capacity or by constructing new capacity prior to 1982
     (the first year that the NSPS will be  in effect).  Thus, only the
     capacity shortfall occurring in the years 1982-1987 will support
     new capacity in 1982-1987.
(2)  Because all the model plants are capable of producing modacrylics,
     it is assumed that all new capacity built will  have the configuration
     of Model Plant 2, as Model Plant 2 is  the least costly of the
     three plants (see Section 9.2.2.2).
9.1.3  Acetate and Triacetate Fibers
     9.1.3.1  Production
     9.1.3.1.1  Product description.  All cellulosic fibers (acetate,
                                                                 i
diacetate, triacetate, and rayon) are composed of cellulose acetate,
produced by combining cellulose with acetate from acetic acid and
acetic anhydride.  This process is called acetylation.  The cellulosics
are differentiated by the percentage of hydroxyl groups that are
acetylated in the cellulose molecule.  According to  the U.S. Federal
Trade Commission classification, rayon has  less than 15 percent acetylation,
cellulose acetate or diacetate has 15 to 92 percent  acetylation, and
                                                              g
cellulose triacetate has not less than 92 percent acetylation.
     9.1.3.1.2  Production technology.  Complete acetylation of cellulose
is the first step in the production of both acetate  and triacetate.*
Cellulose acetate for textile fiber production is obtained by controlled
partial hydrolysis of cellulose triacetate.  The cellulose acetate or
throughout this chapter the term acetate refers to both acetate and
 diacetate fibers.
                                9-44

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triacetate polymer is then usually dissolved in a solvent for extrusion.
Fiber is produced by dry spinning, in which the filaments are extruded
into a column of hot inert gas.  As the filaments dry, the acetone
solvent evaporates, leaving a fiber of almost pure cellulose acetate
or triacetate.  After spinning, treatment of the fiber varies with the
end use anticipated.  Acetate yarn is lubricated and wound onto a
bobbin as continuous filament yarn with no further treatment.  Cigarette
filtration tow (cellulose acetate) is lubricated, crimped and dried.
     9.1.3.1.3  Production history.  Cellulose acetate fibers were
first produced commercially in the United States in 1924 by the Celanese
Corporation.  The fabric woven from these fibers is characterized by
drapability, softness, and shrink and mildew resistance.  The fabrics
are sold both as end products and for manufacture into top-type and
bottom-type apparel, lingerie, linings, draperies, and upholstery.,
The alternate primary use of cellulose acetate fibers is cigarette
filtration tow.
     Cellulose triacetate fibers were first produced in the United
States in 1954, also by Celanese Corporation.  The fibers contain a
higher ratio of acetate to cellulose than do acetate fibers.  Fabrics
woven from these fibers are characterized by shrink and wrinkle resistance
and pleat retention.  The fabrics are marketed both as end products
and as inputs to dress, skirt, and sportswear manufacture.
     9.1.3.1.4  Role in U.S. economy.  The shares of GNP, employment,
and new capital expenditures contributed by the cellulose acetate and
triacetate fibers industry provide measures of the significance of the
industry in the national economy.  The most recent industry data
available to calculate these shares are contained in the 1977 Census
of Manufactures.  Data from this source are not disaggregated for the
acetate and triacetate industry, but grouped with the rayon industry.
This larger industry is defined as SIC 2823, Cellulosic Manmade Fibers.
     The cellulosic fibers industry contributed 0.04 of 1 percent to
total GNP and 0.02 of 1 percent to total employment in 1977.  Of the
expenditures on new plant and equipment by all industries that year
the cellulosics fiber industry accounted for 0.02 of 1 percent.
                                9-46

-------
     Like acrylic and modacrylic fibers,  cellulosic  fibers  are  intermediate
goods.  They consume output of the wood  pulp  and  petrochemical  industry
and are used as inputs to the textile  and cigarette  industries.   To
the extent that these fibers are major consumers  of  particular  petro-
chemicals, or have poor substitutes  in their  alternative  end-use
applications, they may be a critical factor in  the economic health  of
other industries.  This is most probable  in the cigarette filtration
tow application of the fibers.
     9.1.3.1.5  Factors of production.  The principal  materials  used
to produce acetate and triacetate fibers  are  wood or cotton 1 inters
pulp, acetic acid, acetic anhydride  and acetone.  The cellulose  pulp
used for polymer production must be  of high purity and have an  alpha
cellulose content of approximately 94  percent.  Wood pulp is  less
expensive than cotton 1 inters pulp and is  currently  preferred by
acetate and triacetate fiber producers.   Domestic sources of  wood pulp
are ITT Rayonier, Inc., International  Paper,  Buckeye Cellulose,  and
Weyerhaeuser Company.  Some wood pulp  is  imported for acetate manufacture,
The solvent currently used by the industry is acetone,  but  other
solvents such as a chlorinated hydrocarbon are  also  compatible with
the process.
     The major producers of acetate  and triacetate,  Celanese  Corporation
and Eastman Kodak, have captive sources of acetic acid.   All  producers
have captive sources of acetic anhydride.  Eastman Kodak  also has a
                          51
captive source of acetone.    The principal feedstocks, wood  pulp and
acetone, appear to have a variety of alternative  uses.  This makes  a
more competitive and observable market for inputs than  was  the case
for acrylic and modacrylic fibers production.
     Acetone is of particular interest because  it is the  volatile
organic chemical (VOC) that the proposed  standards aim  to control.  It
is a petrochemical produced both as  a  coproduct with phenol  and  by
dehydrogenation of isopropyl  alcohol.  The market for  phenol determines
the output of acetone as a coproduct.  In general, acetone  capacity
has been underutilized in recent years and this,  in  conjunction  with
the possible entry of new competitors  to  acetone  as  a  methyl methacrylate
feedstock, seems to insure ready supplies of  acetone in the near to,
                    52
intermediate future.

                                9-47
51

-------
     Acetate and triacetate fibers producers integrate the acetylation
step with fiber spinning and product finishing.  The technology is
well understood and both it and the equipment can be readily purchased.
     The other principal purchased inputs to the production of acetate
and triacetate fibers are labor and equipment.  The majority of the
five plants currently producing these fibers were built  in the 1930s
and 1940s.53  The production of these fibers is said to  be mature.
Productivity is being increased by debottlenecking but no major changes
in the technology itself, or in the ratio of process inputs, is foreseen.
Increased solvent recovery, whether due  to  the  proposed  standards; or
to economic considerations, may be the most dramatic instance of
factor substitution considered by producers.  A fundamental limitation
on factor'substitution  is the technically fixed ratio of cellulose
acetate polymer to polymer fibers; the polymer  already accounts for
the bulk of production  costs.
     9.1.3.2  Supply Conditions.
     9.1.3.2.1  Domestic producers.  The domestic  acetate  and triacetate
fiber producers and their production capacities are  listed  in Table -9-21.
Three companies produce fibers at five plant locations:  Celanese
Corporation  (with three plants), Eastman Kodak, and  Avtex  Fibers,  Inc.
Two acetate plants were closed in the mid-1970s; Du  Pont closed a  22.6
gigagram-per-year plant in Waynesboro, Virginia, and Celanese Corporation
closed a  13.6 gigagram-per-year plant  in Rome,  Georgia.  Both plants
produced  cellulose acetate yarn.
      In 1980, cellulose acetate and  triacetate  fibers  in all forms
ranged from  $2.40 to  $2.98  per  kilogram, or $1.09  to $1.35 per  pound
 (see  Section 9.2.3.4).  Given the  bulkiness of  the output,  this  is a
relatively low  value-to-weight  ratio.  As  would be expected, fiber
producers  are  located  relatively  close to their customers  in  order to
minimize  transport  costs  and  thereby enhance their competitiveness.
Like  acrylic  and modacrylic producers,  acetate and triacetate  fiber
producers are  clustered in  the  southeastern United States.
      Production of  acetate  and  triacetate fibers  in the United  States
from 1960 to 1980  is  shown  in Table 9-22.   At the  beginning of this
period, yarn accounted  for  58 percent  of output of the acetate  fibers
                                 9^48

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industry.  Staple and tow accounted for 42 percent of the output, with
approximately 15 percent going to the textile market and 27 percent
going to cigarette filtration tow.  From 1960 to 1970 yarn production
grew fairly steadily at an average annually compounded rate of approximately
7 percent.  In the early and mid 1970s, yarn production went  into a
severe slump; production declined every year until 1978 and 1979.
Yarn production in 1979 was only 38 percent greater than in 1960, and
production again fell in 1980.  Production of staple and tow  for
textile fibers fell steadily, comprising only 0.1 of 1 percent of
total acetate and triacetate production in 1979.  Production  of cigarette
filtration tow, on the other hand, increased dramatically over the
period 1960 to 1979  (6.6 percent average annually compounded  growth),
constituting nearly 53 percent of total output  of cellulose acetate
and triacetate fibers in 1979.  Total output has increased at an
average  annual rate of 3.0 percent per year.
     The role of U.S. acetate and triacetate textile fiber in world
production is substantial.  As shown  in Table 9-23, the United States
produced over 42 percent of world acetate  and triacetate textile  fiber
in  1978.  While this  is a slight decline in the percentage of world
production from the  early years of the decade  (46 to 50 percent),  it
does not appear to represent  a direct loss of the U.S. share  of the
world market since such a small quantity of this yarn  is exported  from
the United States  and  imports of foreign fiber  are negligible.  Table  9-23
also shows, however,  that U.S. capacity was expected to fall  below
40  percent of world  capacity  in 1980.  The declining share of the
United  States  in world production of  textile yarn may  ultimately
result  in more  indirect  if not direct world competition for  domestic
acetate  and triacetate fiber  producers.
     U.S. production  of cigarette filtration  tow has had  a larger and
more stable role  in  the world market  than  acetate yarn production.   As
shown  in Table  9-24,  the United States accounted for 51 percent  of
world  cigarette filtration tow production  in  1978.  The world/U.S.
 interface in  this  market  is  particularly critical  because  so  much of
U.S. produced  filtration tow  is exported,  and  because  cigarette  exports
themselves are  a  substantial  and  growing market for  U.S.  producers.
                                 9-51

-------
                     TABLE 9-23.   PRODUCTION AND PRODUCING
                       CAPACITY OF ACETATE AND TRIACETATE
                                 TEXTILE FIBER59
                                   (gigagrams)
                                United States
World
                 Production
                 1972                182
                 1973                198
                 1974                164
                 1975                137
                 1976                130
                 1977                128
                 1978                137

                 Producing capacity
                 1979                148
                 1980                148
 377
 399
 359
 316
 309
 310
 324
 359
 371
            TABLE 9-24.  PRODUCTION OF CIGARETTE FILTRATION TOW60
                                 (gigagrams)

Europe
United States ,
Other American
Asiac
Total
1971
38
94
18
23
173
1972
43
102
19
26
190
1973
45
116
22
28
211
1974
48
124
25
30
227
1975
49
130
26
36
241
1976
58
137
27
37
259
1977
67
144
27
39
277
1978
73
150
31
40
294
Belgium, West Germany and United Kingdom
Brazil, Canada, Columbia, Mexico and Venezuela
Japan and South Korea
                                      9-52

-------
     9.1.3.2.2  Industry structure and capacity.  The production of
cellulose acetate and triacetate is very concentrated; the largest
firm (Celanese Corporation) controls 52.5 percent of the total acetate
and triacetate capacity.  Celanese and Eastman  Kodak together control
over 93 percent of the total capacity, with the remaining 6.9 percent
belonging to Avtex.  Distinguishing between textile yarn and cigarette
tow increases the degree of market concentration:  Celanese owns
70 percent of textile acetate and triacetate yarn and staple capacity,
and Eastman Kodak owns 66 percent of cigarette  tow capacity.  Qualitative
data suggest that the producers of cellulose acetate and triacetate
fiber do not compete directly with one another  because each has expanded
into distinct end-use markets; each producer determines the market
practices for the major end-use categories that it dominates.    The
degree of industry concentration suggests weak  local competition as
wel 1.
     Aggregate production capacity for the' textile fiber portion of
the acetate and triacetate industry is shown in Table 9-25.  These
capacity figures reflect the trends in production discussed above and
reflect a recent estimate of capacity decline (1979 to 1980).  While
these figures are only for textile fiber capacity, they show considerable
annual variation and suggest that marginal adjustments in capacity are
relatively easy.  A comparision of these capacity figures with the
corresponding production figures in Table 9-22  shows that in 1979
capacity utilization was approximately 90 percent.  Historical data
for this industry indicate, however, that this  rate does not imply
capacity expansion.
     Cigarette filtration tow capacity data were not available as a
time series.  The production series, in conjunction with recent firm
data and contacts with the industry, suggest that this capacity has
been expanding steadily due to debottlenecking  and conversion of
equipment from cellulose acetate yarn.
     9.1.3.2.3  Industry performance.  Table 9-26 provides financial
data for the years 1977 through 1979 for the publically owned producers
of cellulose acetate and triacetate fibers.  It is evident that net
sales and earnings before interest and taxes have at least maintained
                                9-53

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pace with,  if not exceeded, the  rate  of  inflation  over  this  period.
Celanese reduced its nominal  (and real)  amount  of  long-term  debt  over
these years; Eastman Kodak increased  its  nominal debt,  but its  real
level of debt apparently fell.   Both  companies  appear to  be  financially
sound.  However, aggregate firm  data  such  as  these indicate  little
about the profitability of the fiber  divisions  within these  companies.
Net sales data for these companies and for Avtex Fibers are  presented
in Table 9-27.  It appears that  only  Celanese has  increased  its fiber
sales in real terms.  Fiber sales by  both  Eastman  Kodak and  Avtex over
this period are negative when netted  of  inflation.   Given the escalating
prices evidenced for polymer  and solvent,  it  would appear that  at,
least Eastman Kodak and Avtex Fibers  (and  possibly Celanese) have been
experiencing declining rates  of  return in  their fibers  divisions.
Avtex1 position over this period appears  to be  especially difficult
because 100 percent of its sales are  due  to fiber  production.
     These data on aggregate  fiber sales  indicate  little  about  the
profitability of cellulose acetate and triacetate  fiber production.
However, the data do suggest  that manmade  fiber manufacturing in
general has not been earning  rates of return  that  would suggest capacity
additions without cost reductions or  price increases.
     9.1.3.3  Demand Conditions.  The demand  for acetate  and triacetate
fibers, like that for acrylic and modacrylic  fibers, is driven by a
wide variety of end uses.  Consequently,  the  complex set  of  complementarity
and substitutability relationships at both final and intermediate
points of production affect demand.  This  is  perhaps particularly true
of acetate and triacetate fibers because  of the role of the  cigarette
industry as a principal  consumer of these  fibers.
     9.1.3.3.1  Fiber end uses.  Table 9-28 presents time-series data
of general  end-use categories for the shipments of  acetate and triacetate
textile yarn.  From 1964 to 1975, apparel  end use  was the dominant
general  category (86 percent of shipments  to  domestic consumers in
1975).  Use in home-furnishings was modest (12.7 percent); industrial
and other end uses accounted for the  residual (1.3 percent).
     A more detailed array of end uses for 1968-1975 is presented in
Tables 9-29 and 9-30.  Within the apparel  end uses, underwear and
                                9-56

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nightwear, and bras and foundations, have been rapidly declining
sources of demand.  Shipments of top-type fabrics and bottom-type
fabrics also decreased over this period.
     Cigarette filtration tow production for 1960-79 is presented  in
Table 9-31.  Over the period from I960 to 1975, shipments to U.S.
manufacturers grew at an average annually compounded rate of approximately
5 percent.  The most interesting aspect of filtration tow end use  is
the rapidly growing role of exports both absolutely and relative to
U.S. production.
     9.1.3.3.2  Foreign trade.  Data for export shipments of acetate
and triacetate textile yarn are contained in Table 9-32.  Export
shipments have far exceeded domestic industrial end use, yet accounted
for just over 10 percent of total production in 1980.
     As mentioned, exports of cigarette filtration tow have grown
rapidly, averaging 14 percent compounded annually over the period
1960-1975.
     9.1.3.4  Projections.  Projections of growth for cellulose acetate
and triacetate fibers were found in two publications, the Chemical
Economics Handbook and Textile Industries.  The Chemical Economics
Handbook (SRI International) contains growth projections published in
November 1976.  Consumption of all cellulose acetate fibers, both  for
textile use and for cigarette filtration tow, were projected to decline
                                                             73
an average of 0.3 percent per year over the period 1975-1981.
     SRI also provided distinct projections for the two types of
acetate fibers.  Consumption of cellulose acetate and triacetate
textile fibers was projected to decline at an average annual rate  of
                                         74
3.5 percent over the period 1975 to 1981.    Imports and exports of
these fibers do not constitute significant markets; exports of acetate
yarn accounted for just over 10 percent of total production of acetate
yarn in 1980  (see Table 9-32).  Data for imports of acetate yarn are
not available disaggregated from data for imports of acetate and rayon
yarn; however in 1978 imports of these two fibers together were only
               no
12.5 gigagrams.    The projected growth rate for domestic consumption
is therefore applicable without much error to growth in production.
                                 9-60

-------
TABLE 9-31.  EXPORTS OF CELLULOSE ACETATE FILTRATION TOW 58 67 68 69
                            (gigagrams)
Production3
Year United States
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978
1979
49
53
58
60
70
71
69
72
73
77
84
94
102
116
124
130.
137d
144d
150^
166e
World
56
64
74
82
100
109
118
123
128
136
154
173
190
211
227
259d
232d
277d
294°
314e
U.S. exports
7
9
12
12
22
22
19
20
24
27
22
20
25
32_
39C
.47C




Exports as
percent of total
U.S. production
14
17
21
20
31
31
28
28
33
35
26
21
25
28
31
36




 Reference 67

 Reference 68

°Reference 58
j
 Reference 69

Reference 4
                                9-61

-------

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-------
      SRI  forecast  growth  in  production of acetate fiber for cigarette
filtration tow  at  an  average annual  rate of 4.8 percent over the
period  1975 to  1981.  This growth  rate was the result of projected
growth  in export markets  of  5.7  percent and growth in domestic consumption
                               75
of 4.3  percent  over the period.    However, as mentioned,  this projected
growth  in domestic consumption does  not offset the projected decline
in domestic consumption of acetate textile fiber,  giving a net effect
of 0.3  percent  dec!ine in consumption  for all  cellulose acetate fibers.
      Textile Industries in its February 1979  issue projected that
domestic mill consumption of rayon and acetate textile fibers together
                                                                 49
would decline 2.0 percent per year over the period 1977 to 1987.
This  projection is not as straightforward as  the  SRI  projections  in
that  acetate textile  fiber growth  is not projected independently of
the growth or decline in  the market  for rayon.   In 1979,  rayon comprised
65 percent of production  of  rayon  and  acetate  textile fibers; therefore
market  conditions particular to  rayon  may be  dominating those of the
acetate textile fiber market in  this aggregate projection.
      Shortcomings exist in these projections  from  published  sources.
The projections from  the  Chemical  Economics Handbook  are for the
period  1975-1981.  The projections were derived from  data  no more
recent  than 1975.  These projections are not  applicable for  forecasting
growth through  1987, given general economic conditions  from  1976-1980
and the specific effects that the higher prices of petroleum-derived
products evidenced during 1976-1980 have on  the costs  of  producing
solvent-spun cellulose acetate fibers.   The projections  from Textile
Industries are less than satisfactory  due  to the aggregation of  the
rayon and acetate markets.
     Because of these shortcomings, the  EPA estimated  regression
equations using historical production  data  for each of  the two types
of cellulose acetate fiber,  textile fiber  and  cigarette  filtration
tow.   The regression equations conducted  in-house  estimated  projected
growth in the production of  these two  fibers.
     The regression equations estimated  a  relationship  between  production
and time.  This relationship was used  to  estimate  production  at future
                                9-63

-------
points in time.  The equations estimated were of two forms.  The first
estimated the values of a and b in the following equation:
                       production = a(year) + b  .
The second regression equation estimated values of c and d  in the
following equation:
              natural log (production) = c(year) + d.
Both equations are linear equations; the second is identified as
"log"-linear, because the equation is estimated given values that are
the natural logarithms of the production data.
     For each type of fiber both log-linear and linear equations were
estimated.  As was the case with acrylic and modacrylic fibers, the
two specifications were each estimated for three time intervals of
annual production data: 1960-1979, 1970-1979, and 1975-1979.    :
     For cellulose acetate textile fibers, the regressions  estimated
for data for 1975-1979 were judged to be the best for'the purpose of
forecasting future production.  The log-linear growth equation projected
growth in production to be 1.0 percent at an annually compounded rate.
The growth rates estimated by linear regression were a range from
1.0 percent growth in 1981 declining to 0.9 percent growth  in 1987.
Log-linear regressions on production data for 1960-1979 and for 1970-1979
both estimated negative growth rates for acetate textile fiber consumption.
Both evidenced a 0.6 percent average annual decline in production.
     The growth rates estimated by regression of 1975-1979  production
data were selected as the best indicators of future growth  in production
of cellulose acetate textile fibers.  This time interval was chosen
because of a stabilization in the demand for these textile  fibers,
which occurred in the late 1970s (see Table 9-32).
     For cigarette filtration tow, the best statistical fit was provided
by the regression equations run on the 1970-1979 production data.  The
log-linear regression equation projected growth in production of
cellulose acetate filtration tow at an average annual rate  of 7.2 percent.
The linear regression model projected average annual growth of 4.7
percent in 1981, declining to 3.6 percent in 1987.
                                9-64

-------
     As was the case with the regression equations  estimated  for
acrylic and modacrylic fibers, the equations do  not explicitly  take
into account the distinct effects of underlying  market forces.   Such
influences as national economic trends, interfiber  competition
(substitutability, relative prices), and growth  or  decline  in import
and export markets are captured to some extent in the  annual  production
data.  However, there is some error in using this data as a basis  for
projection in that first, the effects are not estimated separately and
second, the historical effects will not necessarily pertain in  the
future.
     Specifically in the case of production of solvent-spun fibers
from petroleum-derived polymer, the future effects  of  continually
escalating polymer and solvent costs may not be  as  they were  historically.
It is not clear to what extent the growth rates  derived by  regression
of historical production data are accurate in light of these  shortcomings.
     Of the published and derived growth rates for  cellulose  acetate
fibers, those from published sources were not considered accurate  for
projection of capacity shortfalls in 1987.  The  Chemical Economics
Handbook projections were based on data no more  recent than 1975,  and
were only applicable for growth through 1981.  The  Textile  Industries
projection was for rayon and cellulose acetate textile fibers together;
the applicability of the projection to consumption  of  cellulose  acetate
textile fiber alone is uncertain.  Therefore, only  the growth projections
estimated by in-house regression were used to project  capacity shortfalls.
     As mentioned, for cellulose acetate yarn, regressions  estimated
using annual  production data from 1975-1979 were chosen  due to a
stabilization in the demand for these textile fibers that occurred  in
the late 1970s.    These annual  production data  are:
                                Year
                                1975
                                1976
                                1977
                                1978
                                1979
Production
(qigagrams)
   136.5
   130.0
   127.7
   136.3
   143.6
                                9-65

-------
The first regression, in direct linear form, estimated the equation to
be:*
                     prod+ = -2628.94000005 +  1.40000000  (t)
                         *     (3975.230)       (2.01)
                                     R2 = 0.139

The estimated production levels and growth rates were:
Year
1980
1981
1982
1983
1984
1985
1986
1987
Growth
Rate
%
1.0
1.0
1.0
1.0
0.9
0.9
0.9
0.9
Estimated
Production
(gigagrams)
143.1
144.5
145 j 9
147.3
148.7
150.1
151.5
152.9
Estimated
Production
Capacity
(gigagrams)
150.6
152.1
153.6
155. 1
156.5
158.0
159.5
160.9
Estimated
Capacity
Shortf al 1
(gigagrams)
2.6
4.1
5.6
7.1
"8.5
10.0
11.5
12.9
     Estimated production is obtained by substituting  the value of  the
year in the regression equation obtained.   Estimated production capacity
is the larger of 1) the capacity estimated  to  be  in place in  1980,  and
2) the capacity required, at a 95 percent capacity utilization rate,
by estimated production.  The capacity of cellulose acetate yarn
estimated to be in place in 1980 is  148.0 gigagrams (see Table 9-23).
Estimated -capacity shortfall is tip  difference between  the estimate of
current capacity, and the capacity needed to meet the  production
estimates at a 95 percent capacity utilization rate, that is, the
column "Estimated Production Capacity."
     The second equation estimated was log-linear and  resulted in the
following equation:*                                                .
                   ln(prod.) = -14.58050188 +  0.00987012(t)
                          r     (28.744)       (0.015)
                                     R2  = 0.133
*The standard error for each estimated value  is  provided  in  parentheses
 beneath each estimated value.
                                9-66

-------
The equation was used to project production levels of:
Year
1980
1981
1982
1983
1984
1985
1986
1987
Growth
Rate
%
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
Estimated
Production
(gigagrams)
142.9
144.3
145.8
147.2
148.7
150.2
151.6
153.2
Estimated
Production
Capacity
(gigagrams)
150.4
151.9
153.5
154.9
156.5
158.1
159.6
161.3
Estimated
Capacity
Shortf al 1
(gigagrams)
2.4
3.9
5.5
6.9
8.5
10.1
11.6
13.3
     Estimated production, estimated production  capacity,  and  estimated
capacity shortfall were calculated as described  above.
     To project capacity shortfalls in the cigarette  filtration  tow market,
regressions were estimated using annual production  data  from  1970-1979.

These data are:
                              Year
Production
(gigagrams)
    83.8
    93.8
   101.9
   116.0
   123.7
   130.0
   136.8
   143.6
   149.9
   165.3
The direct  linear estimation was:*
                    prod.  =  -16251.09555556  + 8.29333333(t)
                         t     (749.821)         (0.380)
                                     R2  =  0.986
*The  standard  error  for  each  estimated  value  is  provided  in  parentheses
  beneath  each  estimated  value.
                                 9-67

-------
The equation was used to project production levels of:
Year
1980
1981
1982
1983
1984
1985
1986
1987
Growth
Rate
%
4.9
4.7
4.5
4.3
4.1
3.9
3.8
3.6
Estimated
Production
(qiqaqrams)
169.7
178.0
186.3
194.6
202.9
211.2
219.5
227:8
Estimated
Production
Capacity
(qigagrams)
178.6
187.4
196.1
204.8
213.6
222.3
231.1
239.8
Estimated
Capacity
Shortf al 1
(qiqagrams)
4.6
13.4
22.1
30.8
39.6
48.6
57.1
65.8
     Estimated .production is obtained by substituting the value of the year
in the regression equation obtained.  Estimated  production capacity  is the
larger of 1) the capacity estimated to be  in place  in 1980 and 2) the
capacity required, at a 95 percent capacity utilization  rate, by estimated
production.  The capacity of cigarette filtration tow estimated to be in
place in 1980 was 174.0 gigagramss based upon  1979  production of 165.3
gigagrams (see Table 9-22) and  a 95 percent utilization  factor.*  Estimated
capacity shortfall is the difference between the estimate of current
capacity, and the capacity needed to meet  the  production estimates at a
95 percent capacity utilization rate, that is, the  column "Estimated
Production Capacity."
     The second equation, estimated by log-linear regression, was:**
                   ln(prodj =  -136.92203615 + 0.07177904(t)
                          t     (10.443)        (0.005)
                                      R2 = 0.963
*Note that this capacity of  174.0 Gg,  together  with  estimated  capacity  of
 148.0 Gg for cellulose acetate yarn,  is  a  total  capacity  for  cellulose
 acetate and triacetate fiber  of 322  Gg.  This  contradicts the data  of
 Table 9-21 (total capacity  =  296 Gg).  The reported production data, the
 reported capacity data, and/or the capacity utilization assumption  have
 associated errors.
**The standard error for each  estimated value is  provided  in parentheses
  beneath each estimated value.
                                 9^-68

-------
The equation was used to project production  levels  of:
Year
1980
1981
1982
1983
1984
1985
1986
1987
Growth
Rate
%
7.2
7.2
7.2
7.2
7.2
7.2
7.2
7.2
Estimated
Production
(gigagrams)
181.4
194.9
209.4
224.9
241.7
259.7
279.0
299.7
Estimated
Production
Capacity
(gigagrams)
.190.9
205.2
220.4
236.7
254.4
273.4
293.7
315.5
Estimated
Capacity
Shortfall
(gigagrams)
16.9
31.2
46.4
62.7
80.4
99.4
119.7
141.5
     Estimated production, estimated production capacity,  and  estimated
capacity shortfall were calculated as described above  for  the  linear
estimation.
     The projected capacity shortfalls, a range for each of  the  two
cellulose acetate fiber types, are presented  in Table  9-33.  The
1982-1987 capacity shortfalls are based on the assumption  that any
capacity shortfall occurring before 1982 will be met by debottlenecking
existing capacity or by constructing new capacity  prior to 1982  (the
first year that the NSPS will be in effect).  Thus, only the capacity
shortfalls arising in the years 1982-1987 will support new capacity in
1982-1987.
9.2  ECONOMIC IMPACT ANALYSIS
9.2.1  General Methodology
     The purpose of this analysis is to estimate the economic  impacts
of the regulatory alternatives presented in Chapter 6.  These  alternatives
will affect only new fiber producers who use  volatile  organic  compounds
as solvents.  Most organic  solvent-spun fibers are either acrylic/modacrylic
or cellulose acetate/cellulose triacetate.  The other  specialty  fibers
produced with VOC solvent make up only 2.9 percent of  solvent-spun
fiber capacity.    Consequently, the economic impact analysis  focuses
on possible capacity expansion for acrylics and acetates and the
impact of the regulatory alternatives on the  cost, output  and  price of
these fibers.
     The impact analysis for each fiber type  begins with a discounted cash
flow analysis based upon the capital and operating costs developed by the
EPA for each of the modelplants.  This analysis provides  estimates of the
                                9-69

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relative cost of each of the model plants and the cost  impacts  of  the
various emission control alternatives for each model plant.  These
values are therefore the basis for estimates of the cost  impact and
assessment of the financing burdens placed on the firms of the  industry
by the proposed emission controls.
     The discounted cash flow analysis also provides an implicit price
estimate for the output of each of the model plants under the alternate
levels of emission control.  These price estimates, in  conjunction
with the industry profiles, provide a basis for estimating the  market
impacts of the proposed regulations.  The market impacts  of  interest
include effects on price, sales, production and capacity.
9.2.2  New Acrylic and Modacrylic Facilities
     For each of three types of model acrylic fiber plants,  cost
estimates were made for three alternate levels of VOC emissions control.
Regulatory Alternative I, or the "baseline" level of control, utilizes
a design based on current industry practice for new facilities.
Regulatory Alternatives II and III represent VOC emissions control
beyond the baseline level.  Regulatory Alternative II represents
application of additional controls to the primary remaining  source of
emissions from a new plant.   Similarly, Regulatory Alternative III
represents the application of additional controls to the  second most
significant remaining source of VOC emissions.  As mentioned in the
industry profile, expansion of acrylics capacity by American Cyanamid
or Badische Corporation (together nearly one-fourth of  1980  industry
capacity) will not be affected by these proposed regulatory  controls
so long as neither company utilizes volatile organic solvents.
     9.2.2.1  Model Plant Cost Estimates.  The fixed capital  costs
estimated by the EPA for the various degrees of VOC emissions control
for the three model plants are summarized in Table 9-34.  These figures
show that under the control technologies considered by  EPA,  increases
in VOC emissions control are associated with increases  in the fixed
investment made in the plants.  These increases were nontrivial;
Regulatory Alternative  Ill's fixed capital costs were between 6 and
9 percent greater than the baseline.  In addition to fixed capital
costs, Table 9-34 shows working capital costs.  Working capital, the
                                 9-71

-------










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average cash on hand required by the firm  in  order  to  finance  purchases
of labor, materials and product inventory, was  estimated  to  be one-twelfth
of the annual operating costs.  The cost of maintaining this average
cash balance was estimated to be the present  value  of  the finance
charges.
     In order to assess the significance of these costs for  the acrylic
market in general, and new plant choice in particular, the fixed and
working capital cost data were combined with  associated operating
costs.  These additional expenses are  summarized in Table 9-34.   They
are based upon 95-percent plant capacity utilization and  physical
input requirements derived in Chapter  6.
     Solvent costs for DMAc and DMF were estimated  using  mid-1980 bulk
prices from the Chemical Marketing Reporter:   $1.51 per kilogram for
                                     78
DMAc, and $1.09 per kilogram for DMF.    Acetone was estimated to cost
$0.62 per kilogram in mid-1980, based  on conversations with  producers
                 78 80
of this chemical.  '    Because of increased  solvent recovery  associated
with greater VOC emissions control, the make-up solvent required by
each of the plants declines significantly between the  baseline and
Regulatory Alternative III.  The associated solvent costs drop by $1.8
million for Plant 1, $1.3 million for  Plant 2 and $1.2 million for
Plant 3.
     The regulatory alternatives promote improved solvent recovery at
new, modified, and recontructed synthetic fibers plants,  and this  will
reduce the makeup solvent requirements of these plants.   These reductions
are the basis for the computation of a solvent  recovery credit:   the
amount of solvent saved times the market price  of the solvent.   These
credits are employed in the economic analysis as an offset to  the
capital equipment and operating costs  of improved solvent recovery.
     Several producers have disputed the use  of the market price as a
means of valuing a unit of solvent saved.  Specifically,  firms which
produced the solvent used in their synthetic  fiber  production  activities
claimed the market price was inflated  relative  to the  internal  accounting
value used in firm investment and operating decisions.  They therefore
contended that the use of the market price overstated solvent  recovery
credits and understated the economic impact of  the  proposed  standards.
                                9-73

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     The market price is nontheless considered to be the appropriate
price for computing the solvent recovery credit.  This is based upon
the principle, generally accepted in economics, that in a competitive
setting market prices represent the social opportunity cost of resources.
Internal price of accounting cost valuation often reflect sunk cost or
market structure phenomena which, while real enough to the firm, do
not best reflect the value of a good to the economy as a whole.  It is
this later perspective which should be the basis for the economic
analysis of a standard.
     Furthermore, since the standard would be applied to new sources,
it is not clear that internal accounting costs used in association
with old plants would even be viewed by the firms as the appropriate
measure of the worth of solvent.  This is especially true for a vertically
integrated firm, which would require new solvent capacity if it is to
continue to supply its synthetic fiber facilities with solvent.  The
opportunity cost of solvent to such a firm is the market price of the
solvent from another source.
     Polymer costs were difficult to estimate because no well-developed
market for polyacrylonitrile exists.  Acrylic manufacturers actually
purchase the monomer acrylonitrile and polymerize it in-house to
produce polyacrylonitrile.  The decision to examine the spinning and
finishing phases of production in Isolation from polymerization in
this analysis has the effect of requiring the estimation of internal
or accounting price for a major process input.  The price of polyacrylo-
nitrile was estimated by taking the mid-1980 price of acrylonitrile
from the Chemical Marketing Reporter and adding a processing value of
$0.33 per kilogram.*  This procedure yielded a polyacrylonitrile price
estimate of  $1.16 per kilogram.  For Plant 3, the modacrylic plant,
the polymer price was adjusted to reflect the 40-percent vinylidene
chloride/60-percent acrylonitrile mix that is standard for modacrylic
polymer.  The mid-1980 price of vinylidene chloride was estimated at
$0.62 per kilogram.  Again, a processing value of $0.33* per kilogram
*Derived from data in the Chemical Economics Handbook Marketing  Research
 Report on Acrylic and Modacrylic Fibers.
                                9-74

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was added to incorporate value added in polymerization.  Modacrylic
polymer price for Plant 3 was therefore estimated to  be  $1.07  per
kilogram.  The quantity of polymer required as  input  does not  vary by
level of emissions control; therefore the polymer costs  for each model
plant do not vary by regulatory alternative.
     The category "Other Operating Expenses" shown  in Table 9-34
includes labor, administration, utilities, and  insurance costs.  These
expenses rose slightly as a result of increased  VOC emissions  control.
     Operating expenses plus working capital make up  around 95 percent
of the annual expenses incurred by the firms operating these model
plants.  The cost of additional emission control equipment, while a
significant fraction of fixed costs, is not a major portion of the
overall expenditures anticipated by a firm considering building and
operating a new acrylic facility.
     9.2.2.2  Present Discounted Cash Flow Analysis.  The capital and
operating costs for each model plant and each option  were employed as
inputs in a cash-flow model to estimate the net present  cost  and
implicit producer price for each plant for each alternative.   The
objective of this analysis is to determine  (1)  which  of  the model
plants would be least costly, and  (2) what  impacts  on costs  (and
prices) the various levels of VOC  emission control  would have. The
results of this analysis are summarized in Table 9-35.
     The present discounted costs  are shown for each  plant both before
and after normalization by plant capacity.  'The discount rate  employed
to make these discounted cash flow calculations  was the  estimated
weighted average cost of capital  (WACC) for firms  producing  acrylic,
modacrylic, and cellulose acetate  fibers.  The  WACC was  adjusted by  an
estimate of long-run inflationary  expectation so as to yield  a real
discount rate of 4.74 percent for  use in the analysis.   The details  of
these calculations and adjustments are contained in Appendix  E.
     The 4.74 percent estimate of  the industry's real weighted average
cost of capital was the highest of the range of WACCs estimated.  The
EPA chose this estimate for the discounted cost and implicit  price
calculations because an industry's required rate of return  (for which
the WACC is a proxy) is a component of costs, and  hence  the higher the
                                 9-75

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           TABLE 9-35.   DISCOUNTED PLANT COSTS AND IMPLICIT PRICE FOR

                    MODEL ACRYLIC AND MODACRYLIC FIBER PLANTS9




Model
plant
Plant 1
(capacity of
45.36 Gg/yr)


Plant 2
(capacity of
45.36 Gg/yr)


Plant 3
(capacity of
20 Gg/yr)






Level of
control
Baseline
Regulatory
Alternative
Regulatory
Alternative
Baseline
Regul atory
Alternative
Regulatory
Alternative
Baseline
Regulatory
Alternative
Regulatory
Alternative

Discounted
cost of
plant
(million
1980 dollars)
1,778.6

II 1,777.6

III 1,772.3
1,670.3

II 1,671.7

III 1,669.4
771.9

II 768.4

III 765.2
Normalized
discounted
cost of plant
(million dollars
per gigagram
capacity)
39.2

39.2

39.1
36.8

36.9

36.8
38.6

38.4

38.3


Implicit price
of fiber
(dollars
per kilogram)
2.61

2.60

2.60
2.45

2.45

2.45
2.57

2.56

' 2.55
 Present discounted values were computed using the following economic parameters:
thirty year plant life, 4.74 percent real rate of discount,  fourty-nine percent
effective tax rate, ninety-five percent plant utilization,  and ten percent
investment tax credit.
                                         9-76

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WACC, the higher the product price must be  to  recover  all  costs.   The
EPA has chosen that estimate of the  range of WACC  estimates  that
portrays the "worst case" scenario,  in the  sense that  the  higher  the
WACC, the greater would be the economic burden associated  with  investing
in additional capacity.
     Model Plant 2 is the most attractive alternative  among  the two
acrylic fiber plant types:  its present discounted costs are approxi-
mately 6 percent lower than those for Model Plant  1.   The  modacrylic
plant, Model Plant 3, costs less than the other two model  plants
because of its smaller capacity.  When normalized  to an equal  capacity,
the cost of the modacrylic facility  is slightly less than  the cost of
Model Plant 1, but greater than that of Model  Plant 2.
     The striking thing about the discounted plant costs is  that  costs
for two of the three model plants decline as emissions control  increases.
.For the third model plant (Model Plant 2),  Regulatory  Alternative III
is no more costly than baseline control, and Regulatory Alternative  II
is only slightly more costly.  Even  in present-value terms,  in  which a
dollar of initial investment is weighted more  heavily  than a dollar  of
future operating costs, the model plants, for  the  most part, become
more attractive investments as the level of emissions  control  increases.
The driving force behind this result is the annual  saving  in the  cost
of solvents.  With greater emissions control,  the  value of the additional
solvent that is captured and recycled more  than offsets the increased
cost of the additional control equipment and maintenance.
     9.2.2.3  Profit and Price Impact of Emissions Control.   Given the
results of the discounted cash-flow  analysis,  the  profit and price
impacts of emissions control are easy to bracket.   At  the  extremes,
the change in costs associated with  increased  emission control  may be
absorbed entirely by consumers, in the form of price changes, or  by
producers, in the form of changes  in the cost  of doing business.   In
the case of acrylic and modacrylic fibers,  increased emissions  control
confers benefits to the party or parties impacted  by the change,  with
only one exception, moving from baseline control to regulatory
Alternative  II control for Model Plant 2.   The outcome for the full-price
increase and full-cost absorption cases are shown  below.
                                 9-77

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                           Full-cost  pass  through
                                  (percent)
   Level of control
Baseline to Regulatory
  Alternative II
Baseline to Regulatory
  Alternative III
                                           Price  change
Plant 1    Plant 2     Plant 3
 -0.4
 -0.4
0.0
0.0
-0.4
-0.8
   Level of control
Baseline to Regulatory
  Alternative II
Baseline to Regulatory
  Alternative III
                           Full-cost  absorption
                           (million  1980 dollars)
Present value of cost change
Plant 1    Plant 2     Plant 3
 -1.0
 -6.3
+1.4
-0.9
-6.7
Increased emissions control increases the cost of new facilities  in
only one case, and in no case increases the price of output.
     These results do, however, deserve some qualification.  The
declines in the present discounted cost of the plants as emission
control increases are very small, all less than 1 percent of total
discounted costs.  Declines of this magnitude may well be the result
of minor errors in cost estimation.  The apparent consistency in  the
cost trends across plants may actually'reflect nothing more than  a
consistent error in the raw data or cost estimation procedure.
     Furthermore, since these control technologies involve the  installation
of relatively straightforward enclosure systems, these cost trends
suggest that acrylic producers might well retrofit their current
spinning lines.  Although the Du Pont plant was built with such enclosures,
the other acrylic producers have not retrofitted their facilities.
While recognizing these considerations, the EPA believes that for the
range of control and technology choices examined here, the economic
                                9-78

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impact on the cost or price of acrylics from new production capacity
is relatively small and is quite likely to be negative.
     9.2.2.4  Capacity Projections Reconsidered.  Ordinarily, one
would expect that the supply of synthetic fiber would  be  a fairly
smooth function of the price of output and the price of inputs.  The
synthetic fiber industry has recently emerged from  a period of soft
demand relative to capacity.  Theoretically, in such circumstances
firms will remain in production so long as they are able  to cover
their variable costs.  Firms operating plants whose revenues  from
production do not cover the variable costs of that  production will
close those plants.  As noted in the industry profile,  Union  Carbide
left the acrylic and modacrylic industry  in  1975, by closing  its
modacrylics plant.  Industry earnings are only now  beginning  to  recover
from the soft demand experienced during the  1974-1975  recession.
     In such circumstances, it is quite likely that additions to
capacity must be preceded by a significant increase in the price of
fiber relative to operating costs.  Established plants may continue to
produce at the lower prices because the capital costs  are sunk.
However, new capacity can only be justified  when the price is high
enough to make the expectation of future  earnings and  profits competitive
with other investments.  This set of circumstances  may result in a
discontinuous supply function for acrylic and modacrylic  fibers, as
pictured in Figure 9-1.  In that figure the  current capacity  of  the
industry is Q|.  The supply function SQ SQ is discontinuous  at Q^:
increases in industry supply beyond Q| will  require a  price  P2   PQ-  .
With the supply function, SQ SQ, the dynamics of industry capacity
expansion may be characterized as follows.   For a demand  function DQ
DO, the industry is operating well below  capacity,  price  is  PQ,  and
output and consumption of fiber are equal at QQ.  Over time,  however,
the demand for the fiber increases  (shifts to the right)  to  D-j^ Dp  but
capacity and production remain at Q| once that  capacity is reached.
The price of fiber, however, rises to  P^  Further  increases  in  demand
result only in price changes until price  P2  is  attained.   At  that
price new capacity is financially justified  and shifts in demand to D2
D2 result in output increases  (to Q2) with little or  no further  effect
                                 9-79

-------
Price
     P1
     po
                     Q0       Q1         Q2
                         Quantity Produced
             Figure 9-1.   Market With a Supply Discontinuity
                               9-80

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on the price P2<  While this is a highly stylized portrayal of a
dynamic market situation, it underscores the possibility that new
acrylic and modacrylic capacity will not automatically be constructed
as current-capacity is approached.  A price barrier may first have to
be overcome.  This characterization of supply and demand is intended
to reflect the conditions of the current acrylic and modacrylic market.
In the following paragraphs, the current market situation and the
position of the current market equilibrium  (En) are considered.
     As noted above, the evidence of an earnings slump and firm withdrawal
support the notion of a discontinuity in supply.  Another indication
of the existence of a supply discontinuity, as well as of the particular
position of the market equilibrium, might be obtained through a comparison
of the current market price and implicit price for the fiber, which
emerged from the discounted cash flow analysis.  Ranges for these
values are presented below.

                                               Prices
                                         (dollar per kilogram)
                                       Market
                    Implicit
   Acrylic
Model Plant 1
Model Plant 2
  Modacrylic
Model Plant 3
1.94-2.4982'83'84   2-60-2'61
1.94-2.4982'83'84   2.45
2.38-2.58
         85*
2.55-2.57
     Because Model Plants  1 and  2  are  also  capable  of  producing  modacrylic,
 it  is anticipated  that a firm  constructing  new  acrylic or modacrylic
 facilities would build a plant like  Model Plant 2,  which  is  the  least
 cost plant.  The implicit  price  estimated for Model  Plant 2  falls  just
 within  the high end  of the range for acrylic prices reported for
 mid-1980.
 *These  prices  are  for  January  1981,  not mid-1980.   Mid-1980 prices were
  not  available from  the  source.
                                 9-81

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      The market prices presented here are a very broad range, reflecting
 differences  in the prices of various types of acrylics, for example,
 thick fibers for use in manufacturing carpets and thin fibers for use
 in  apparel.
      Additionally,  market prices for acrylic and modacrylic fibers
 have  recently been quite volatile.   By March 1981, acrylic fiber
                                                  OO Qfl
 prices were  reported ranging from $2.31 to $2.69,  '   and modacrylic
                                                  ojr
 prices were  reported ranging from $2.60 to $2.80.    Given the recent
 increases in prices for inputs  to acrylic and modacrylic production
 (see  Table 9-36),  it is quite likely that modacrylic and acrylic price
 increases were lagging behind input price increases.  If indeed a
 supply discontinuity existed in the market for acrylic and modacrylic
 fibers between the market prices for these fibers in mid-1980 and the  .
 implicit prices necessary to justify new capacity construction, this
 price differential  appears to have  been traversed.  It seems quite
 reasonable that producers of acrylic and modacrylic prices would no
 longer be deterred  from capacity addition, in that current market
 prices of acrylic  and  modacrylic fibers justify the construction of
 new plants.   Therefore,  the cost associated  with constructing plants
 to meet  either baseline levels  of control  or NSPS levels of control  do
 not seem to  be prohibitive to construction of new plants to meet the
 capacity shortfall  projected for the acrylics and modacrylics fiber
 industry (see Section  9.1.2.4 above).
 9.2.3 New Acetate  and Triacetate Facilities
      The fixed  capital  costs  estimated  for two  types of new acetate
 fiber capacity were  presented in Chapter 8.   The model  plants considered
 both  employ  acetone  solvent and  dry  spinning but produce different
 finished  products due  to  processing  differences.   Plant 4 produces .
 cigarette filtration tow  and  Plant  5  produces textile fibers.   As  in
 the case  of  acrylics and  modacrylics  three degrees  of VOC emission
 control  are  analyzed:   Regulatory Alternative I,  the baseline or
 current  industry practice  for new plants;   Regulatory Alternative  II,
 application  of  additional  controls  to the  major remaining  source of
VOC emissions;  and Regulatory Alternative  III,  additional  control  of
both  the  first  and second most significant remaining  sources.
                                9-82

-------
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                                                      y
     9.2.3.1  Model Plant Cost Estimates.  The fixed  capital  costs  as
estimated by the EPA for various degrees of control are  summarized  in
Table 9-37.  These data show that fixed equipment  costs  increase with
the level of VOC emissions control.  The size of this increase  varies
substantially between the plants.  Between the baseline  level of
control and Regulatory Alternative III, fixed capital  costs  rise
6.3 percent for Plant 4 and 12.4 percent for Plant 5.  As  in the case
of acrylic and modacrylic model plants, the working capital  costs were
estimated to be the present value of maintaining an average  cash
balance equal to one-twelfth of annual operating costs.       ;
     Estimated annual operating expenses for the cellulose acetate
model plants are also summarized in Table 9-37.  These operating costs
v/ere developed in a fashion similar to that described above  for acrylics.
     The costs were estimated for the physical input  requirements
presented in Chapter 6, assuming 95-percent capacity  utilization.
Cost of solvent was assumed to be $0.62 per kilogram  and was based  on
EPA communications with producers of this solvent.  '   Because of
the increased recovery of solvents for additional  levels of  VOC control,
the cost of solvent for Plant 4 dropped $0.7 million  per year of
operation between the baseline and Regulatory Alternative  II, and $1.0
million per year of operation between the baseline and Regulatory
Alternative III.  Similarly, the cost of solvent for  Plant 5 dropped
$0.9 million and $1.3 million per year between the baseline  and Regulatory
Alternatives II and III, respectively.
     The cost of cellulose acetate polymer was estimated to  be  $1.95
per kilogram, as reported in the July 28, 1980,  issue of the Chemical
Marketing Reporter.  The cost of pblymer per year  of  operation  does
not vary by level of emissions control because the quantity  of  polymer
required as a process input is constant.
     Other operating expenses rose, slightly as the level of  VOC emissions
control increased.  These increases were 3.5 percent  for Model  Plant  4
and 6.3 percent for Model Plant 5 as emissions control increased from
the baseline to Regulatory Alternative III.
     9.2.3.2 Present Discounted Cash Flow Analysis.  The effect of
these opposing expenditure movements on the discounted cost  of  the
                                 9-84

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   plants is shown in Table 9-38.  The results for Model Plants 4 and 5
   are different from those for the acrylic and modacrylic plants,, where
   discounted costs were found to decline as emission control  increased.
   In the case of the cellulose acetate plants, discounted costs and
   associated implicit prices either are stable or increase as the level
   of emission control increases.  Solvent recovery credits are not
   sufficiently large in some cases to completely offset increases in
   capital and operating costs due to increasing levels of emission
   control.
        9.2.3.3  Profit and Price Impact of Emissions Control.  A<; is the
   case for acrylics and modacrylicss the estimated price and  cost impacts
   of the proposed levels of VOC emissions control for cellulose acetate
   fibers were based upon the results of the discounted cash flow analysis.
   This was done for each of the extreme cases:  full-price pass through
   to consumers and full-cost absorption of the price impact by producers.
   These calculations are presented below.
                            Full-cost pass through
                                   (percent)
                                                Price change
      Level of control
   Baseline to Regulatory
     Alternative II
   Baseline to Regulatory
     Alternative III
  Level of control
Baseline to Regulatory
  Alternative II
Baseline to Regulatory
  Alternative III
     Plant 4
      +0.3
      +0.3
  Plant 5
   +1.7
   +1.7
                          Full-cost absorption
                         (million 1980 dollars)
Present value of cost change
  Plant 4           Plant 5
   +3.0
   +2.6
+16.2
+16.8
                                   9-86

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           TABLE 9-38.
  DISCOUNTED PLANT COSTS AND IMPLICIT PRICE FOR

MODEL CELLULOSE ACETATE FIBER PLANTS3


Model
plant
Plant 4
(capacity of
22.7 Gg/yr)
Plant 5
(capacity of
22.7 Gg/yr)


Level of
control
Baseline
Regulatory
Alternative
Regulatory
Alternative
Baseline
Regulatory
Alternative
Regulatory
Alternative

Discounted
cost of
plant
(million
1980. do liars)
1184.4
II 1187.4
III 1187.0
1233.0
II 1249.2
III 1249.8
Normalized
discounted
cost of plant
(million dollars
per gigagram
capacity)
52.2
52.3
52.3
54.3
55.0
55.1


Implicit price
of fiber
(dollars
per kilogram)
3.47
3.48
3.48
3.62
3.67
3.68
aPresent discounted values were computed using the following economic parameters:
thirty year plant life, 4.74 percent real rate of discount, fourty-nine percent
effective tax rate, ninety-five percent plant utilization,  and ten percent
investment tax credit.
                                         9-87

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     The increases in emissions control increase the price of fiber
produced by new facilities when moving from the baseline level of
control to Regulatory Alternative II for both Model Plants 4 and 5.
However, no further price increases result from the move from Regulatory
Alternative II level of control to Regulatory Alternative III level of
control.  The output of Model Plant 4 is estimated to  increase 0.3 percent
due to either of the regulatory alternatives; the output of Model
Plant 5 is estimated to increase 1,7 percent due to either of the
regulatory alternatives.  Full cost impact absorption  by producers
results in increases in the present value of costs of  operation in all
cases except that of moving from Regulatory Alternative II to Regulatory
Alternative III with Model Plant 4.  The present value cost increases
range from $2.6 million to $16.8 million.
     The same qualifications mentioned with respect to the accuracy of
the acrylic and modacrylic implicit price and cost results also apply
to the results for cellulose acetate fibers.  In addition, it should
be noted that the relative price of solvents has recently been rising
very rapidly.  If the trend continues, the credits for additional
solvent recovery will grow faster than the costs of installing additional
recovery equipment, and cost savings or price reductions might result.
     9.2.3.4  Capacity Projections Reconsidered.  As discussed in
Section 9.2.2.4, there is some evidence that a discontinuous supply
function may characterize the synthetic fiber industry.  To assist in
determining whether such considerations might adversely affect the
projections of new cellulose acetate capacity presented in Section 9.1.3.4,
the implicit prices calculated from the discounted cash flow analysis
for cellulose acetate were compared with the mid-1980  market prices of
these fibers.  This comparison is presented below.
                                               Prices
                                        (dollars per kilogram)	
                                       Market
Model Plant 4
   (cigarette filtration tow)
Model Plant 5
   (textile fibers)
   2.40
                                             86
2.67-2.98
         82
Implicit
3.47-3.48

3.62-3.68
                                 9-88

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     For cigarette filtration tow, the implicit prices are nearly
50 percent greater than the observed market price in mid-1980.
Additionally, the market price reported in March of 1982 for cigarette
                               87
filtration tow was $2.71-$2.76,   still substantially below the implicit
price suggested by the model plant analysis.  This divergence of
approximately one dollar per kilogram between mid-1980 market tow
prices and the implicit price required to make new plant construction
profitable at first glance suggests that new plants would not actually
be constructed at the rate projected above in Section 9.1.3.4.
     In the past, manufacturers of cellulose acetate fibers have
converted cellulose acetate yarn and staple capacity to cigarette
filtration tow capacity, apparently due to increases in tow prices
that provided greater earnings opportunities than were available from
yarn or staple production.  If firms were able to continue to convert
cellulose acetate yarn and staple capacity to filtration tow capacity,
the capacity shortfall for cigarette filtration tow could be met by
converted plants that would not fall under the NSPS, so long as emissions
did not increase and conversion costs were less than 50 percent of the
capital costs estimated for a new facility.  A representative of
Tennessee Eastman reported that conversion of yarn facilities to tow
facilities had been accomplished previously in approximately one year,
and for less than 50 percent of estimated capital costs for a new
         oo
facility.    Economic theory suggests that producers will continue to
convert yarn and staple capacity to tow capacity if the price of tow
increases relative to the price of yarn.  However, industry analysts
state that the cellulose acetate yarn market is currently stable and
that yarn capacity has already been converted to the extent that
                               QQ on
producers are willing to do so.  *
     Assuming that there will be no further conversion of capacity, as
industry suggests, the market price of cigarette filtration tow must
rise to approximately $3.47 per kilogram, before producers will build
new capacity, even at the baseline level of control.
     Figure 9-2 depicts the hypothesized domestic market for cellulose
acetate filtration tow.  Domestic demand for cellulose acetate filtration
tow is currently D D .  The demand curve DQDo intersects the supply
                                9-89

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 Price
 Per
 Kilogram
R, ($3.471	
P0 ($2.40)
                                                       Quantity of Tow
      Figure 9-2.  Domestic Market for Cellulose Acetate Filtration Tow
                                      9-90

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curve S S  at quantity Q , which reflects that  the  industry  is  currently
operating at maximum capacity utilizaton, and at  price  PQ, equal  to
$2.40 per. kilogram.  Demand for cigarette filtration  tow  is  highly
price inelastic, as reflected in the nearly vertical  demand  curve,
D D .  The market price for tow will move to P,,  equal  to $3.47 per
 o o                                          *•
kilogram, only if demand shifts from DQDO to D-^D^.
     The supply curve S S  is depicted as a vertical  line between
price P  and price P,, reflecting perfectly inelastic supply of tow to
the domestc market between these two prices.  Three assumptions are
required to characterize this segment of the supply curve in this
manner.  First, as price moves from PQ to P^t domestic  producers will
continue to export that amount of tow that they were  exporting  at
price P .  Second, as price moves from PQ to Pp  domestic cigarette
producers will continue to import the same amount of  tow  as  they
imported at P .  Third, domestic cigarette producers  will  not substitute
other materials for tow in cigarette production (i.e.,  paper or charcoal),
     Given that demand is highly inelastic and  that supply is perfectly
inelastic, little shift in demand is required to  raise  market price
from PQ ($2.40) to ?l ($3.47).
     The elasticity of demand for cigarette filtration  tow was  estimated
by the EPA and indeed found to be highly inelastic.  Elasticity of
demand refers to the percent change in the quantity demanded of a
product due to a 1 percent change in the price  of that  product.  The
price elasticity for tow was derived from the price elasticity  for
cigarettes (estimated to be -0.5)90 and the cost  share  of filter tow
in cigarettes (estimated by the EPA to be 0.015).  Cigarette filtration
tow was estimated to have an elasticity of demand of -0.0075, that  is,
a 1 percent change in its price would result in only a  .0075 percent
change in the quantity of tow demanded.
     Characterizing supply as perfectly inelastic between PQ and P-^
requires three assumptions, as mentioned above.  The first assumption,
that cigarette producers will not substitute paper  or charcoal  filters
for cellulose acetate filtration tow, is supported  by evidence (in  the
Chemical Economic Handbook's Marketing Research Report  on Cellulose
Acetate and Triacetate Fibers) that cigarette smokers prefer the taste
                                 9-91

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of cellulose acetate filters to that of paper filters, and  that  charcoal
filters have decreased in popularity in recent years.
     The other two assumptions, regarding foreign  trade  effects,  are
that neither the quantity of tow exported (approximately a  third  of
domestic production) nor the quantity of tow imported  (currently  none)
will be affected by the rising price of domestic tow.  It is  likely
that increases in the price of domestic tow will have  some  effect upon
these two components of foreign trade.  However, these effects were
not incorporated due to the lack of necessary data and the  scope  of
this analysis.
     Using these supply assumptions, the demand elasticity  estimates,
and the projected rate of growth for cigarette filtration tow, the EPA
estimated the time it would take for demand to shift from DQDo to
D-,D-,, and found this time interval to be less than one month.  The
uncertainty regarding the supply assumptions and demand  elasticity and
rate of growth estimates brings into question the  accuracy  of this
estimate of the time required for the demand shift.  However, even
given this uncertainty, it is reasonable to conclude that the time
interval will not be of such great duration as to  significantly  delay
construction of new plants.
     Turning to the market for cellulose acetate textile fibers,  the
implicit price is substantially greater than the market  price for
these fibers.  Given the estimated 1982-1987 capacity  shortfall  of 7.3
to 7.8 gigagrams, and the contention that industry would be inclined
to build in plant unit capacities of 22.7 gigagrams, the EPA  has
concluded that there will be no additions to cellulose acetate yarn
capacity in the period 1982-1987.  This conclusion is  qualitatively
supported by an analyst within the cellulose acetate yarn industry who
characterizes the growth in demand for these fibers as stable.
9.3  POTENTIAL SOCIOECONOMIC AND INFLATIONARY IMPACTS
     Executive Order 12291 requires that the inflationary impacts of
major legislative proposals, regulations, and rules be evaluated. The
proposed NSPS would be considered a major action (thus requiring  the
preparation of a Regulatory Impact Analysis) if any of the  following
criteria apply:
                                9-92

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curve S S  at quantity QQ, which reflects that the  industry  is  currently
operating at maximum capacity utilizaton, and at price PQ, equal  to
$2.40 per. kilogram.  Demand for cigarette filtration tow  is  highly
price inelastic, as reflected in the nearly vertical demand  curve,
D D .  The market price for tow will move to P,, equal to $3.47 per
 o o                                          -1-
kilogram, only if demand shifts from D0DQ to DjDp
     The supply curve S S  is depicted as a vertical line between
price P  and price P,, reflecting perfectly inelastic supply of tow  to
the domestc market between these two prices.  Three assumptions are
required to characterize this segment of the supply curve in this
manner.  First, as price moves from PQ to Pp domestic producers  will
continue to export that amount of tow that they were exporting  at
price P .  Second, as price moves from PQ to Pp domestic cigarette
producers will continue to import the same amount of tow  as  they
imported at P .  Third, domestic cigarette producers will  not substitute
other materials for tow in cigarette production  (i.e., paper or charcoal),
     Given that demand is highly inelastic and that supply is perfectly
inelastic, little shift in demand is required to raise market price
from PQ ($2.40) to PI ($3.47).
     The elasticity of demand for cigarette filtration tow was  estimated
by the EPA and indeed found to be highly inelastic.  Elasticity of
demand refers to the percent change in the quantity demanded of a
product due to a 1 percent change in the price of that product.  The
price elasticity for tow was derived from the price elasticity  for
cigarettes (estimated to be -0.5)90 and the cost share of filter tow
in cigarettes (estimated by the EPA to be 0.015).   Cigarette filtration
tow was estimated to have an elasticity of demand of -0.0075, that  is,
a 1 percent change in its price would result in  only a .0075 percent
change in the quantity of tow demanded.
     Characterizing supply as perfectly inelastic between PQ and P-^
requires three assumptions, as mentioned above.  The first assumption,
that cigarette producers will not substitute paper  or  charcoal  filters
for cellulose acetate filtration tow, is supported  by  evidence (in  the
Chemical Economic Handbook's Marketing Research  Report on Cellulose
Acetate and Triacetate Fibers) that cigarette smokers  prefer the taste
                                 9-91

-------
of cellulose acetate filters to that of paper filters, and that  charcoal
filters have decreased in popularity in recent years.
     The .other two assumptions, regarding foreign  trade  effects,  are
that neither the quantity of tow exported (approximately a third  of
domestic production) nor the quantity of tow imported  (currently  none)
will be affected by the rising price of domestic tow.  It is  likely
that increases in the price of domestic tow will have  some effect upon
these two components of foreign trade.  However, these effects were
not incorporated due to the lack of necessary data and the scope  of
this analysis.
     Using these supply assumptions, the demand elasticity estimates,
and the projected rate of growth for cigarette filtration tow, the EPA
estimated the time it would take for demand to shift from D0DQ to
DjD,, and found this time interval to be less than one month.  The
uncertainty regarding the supply assumptions and demand  elasticity and
rate of growth estimates brings into question the  accuracy of this
estimate of the time required for the demand shift.  However, even
given this uncertainty, it is reasonable to conclude that the time
interval will not be of such great duration as to  significantly  delay
construction of new plants.
     Turning to the market for cellulose acetate textile fibers,  the
implicit price is substantially greater than the market  price for
these fibers.  Given the estimated 1982-1987 capacity  shortfall  of 7.3
to 7.8 gigagrams, and the contention that industry would be  inclined
to build in plant unit capacities of 22.7 gigagrams, the EPA  has
concluded that there will be no additions to cellulose acetate yarn
capacity in the period 1982-1987.  This conclusion is  qualitatively
supported by an analyst within the cellulose acetate yarn industry who
characterizes the growth in demand for these fibers as stable.
9.3  POTENTIAL SOCIOECONOMIC AND INFLATIONARY IMPACTS
     Executive Order 12291 requires that the inflationary impacts of
major legislative proposals, regulations, and rules be evaluated,, The
proposed NSPS would be considered a major action (thus requiring  the
preparation of a Regulatory Impact Analysis) if any of the following
criteria apply:
                                9-92

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               ABBREVIATIONS USED IN THE FIBERS INDUSTRY
     Abbreviations/Monomers

     AN  - Acrylonitrile,  vinyl  cyanide H2C = CH - C = N
     AMS - Alpha Methyl  Styrene,  CgH5 - C (CH3) = CH2
     BD  - Butadiene,  Divinyl, HgC = CH - CH = CH2
     MA  - Methyl Acrylate, H2C   CH - COOCHj
     MMA - Methyl Methacrylate,  HgC = C(CH3) - COOCH3
     STY - Styrene,  vinyl  benzene, CgHg - CH  CH2
     VA  - Vinyl Acetate,  CH3 -  COO - CH = CH2
     VC  - Vinyl idene  Chloride,  CH2 = C - C12
2VP - 2 Vinyl  Pyrridine
                                  - N - CH = CH
     VC  - Vinyl  chloride,  CH2 = CH - Cl
2.    Abbreviations/Polymers
     A8S - Acrylonitrile Butadiene Styrene resin
     NBR - Nitrile Butadiene Rubber elastomer
     PAN - Polyacrylonitrile
     SAN - Styrene Acrylonitrile copolyiner
     SBR - Styrene Butadiene Rubber elastomer
     PBR - Polybutadiene Rubber elastomer
3.    Abbreviations/Solvents
     AC
     STC
     ZC1
     DMAC
     DMF
       Acetone, CH
       Sodium Thiocyahate,  NaSCN
       Zinc chloride, ZnCl.-,
       DiMethyl Acetamide,  CH3CON(CN3)2
       D1Methyl Fomiamide,  HCON(CH3)2
MW 53
MW 118
MW 54'
MW 86
MW 100
MW 104
MW 86
F',l 97
MW 105
MW 62.5
                                 F-ll

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                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
 I, REPORT NO.
  EPA-450/3-82-011a
                              2.
                                                            3. RECIPIENT'S ACCESSION-NO.
4. TITLE AND SUBTITLE
  Synthetic  Fiber Production  Facilities- Background
  Information  for Proposed Standards
                             5. REPORT DATE
                               October  1982
                             6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
                                                            8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
  Office of Air Quality Planning  and Standards
  Environmental  Protection Agency
  Research  Triangle Park, North Carolina  27711
                                                            10. PROGRAM ELEMENT NO.
                             11. CONTRACT/GRANT NO.

                               68-02-3060 ;
 12. SPONSORING AGENCY NAME AND ADDRESS
  DAA for Air Quality Planning  and Standards
  Office of Air, Noise, and  Radiation
  U. S. Environmental Protection  Agency
  Research  Triangle Park, North Carolina  27711
                             13. TYPE OF REPORT AND PERIOD COVERED
                               Final
                             14. SPONSORING AGENCY CODE

                               EPA/200/04
15. SUPPLEMENTARY NOTES
10. ABSTRACT
       Standards of performance  to  control emissions  of volatile organic
  compounds  (VOC) from new, modified, and reconstructed synthetic fiber
  production facilities are being proposed under  section 111  of the Clean
  Air Act. This document contains information on  the  background and authority,
  regulatory alternatives considered, and environmental  arid economic impacts
  of the  regulatory alternatives.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                b.lDENTIFIERS/OPEN ENDED TERMS  C. COS AT I Field/Group
  Air pollution
  Pollution control
  Standards of performance
  Industrial  processes
  Synthetic fibers
  Volatile organic compounds
                  Air Pollution Control
                  Organic Vapors.
                  Stationary Sources
  13 B
(VOC)
18. DISTRIBUTION STATEMENT
   Unlimited
                19. SECURITY CLASS (ThisReport)
                  Unclassified
21. NO. OF PAGES

  396
                                              2O. SECURITY CLASS (This page)
                                                Unclassified
                                                                          22. PRICE
EPA Form 2220-1 (9-73)

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