United States Office of Air Quality EPA-450/3-82-011 b
Environmental Protection Planning and Standards March 1984
Agency Research Triangle Park NC 27711
Air I ~~~~~
vvEPA Synthetic Fiber Final
Production EIS
Facilities—
Background
Information for
Promulgated
Standards
-------
EPA-450/3-82-011b
Synthetic Fiber Production Facilities-
Background Information for
Promulgated Standards
Emission Standards and Engineering Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
March 1 984
-------
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
avialable through the Library Services Office (MD-35), U.S. Environmental Protection Agency, Research
Triangle Park, North Carolina 27711, or, for a fee, from National Technical Information Services, 5285 Port
Royal Road, Springfield, Virginia 22161.
-------
ENVIRONMENTAL PROTECTION AGENCY
Background Information
Final Environmental Impact Statement
Synthetic Fiber Production Facilities
Prepared by:
Jac/R. Farmer
Director, Emission Standards and Engineering Division
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
1. The promulgated standards of performance will limit emissions of
volatile organic compounds (VOC) from new and reconstructed
synthetic fiber production facilities. Section 111 of the Clean
Air Act (42 U.S.C. 7411), as amended, directs the Administrator 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: Office of Management and Budget; 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. For additional information contact:
Mr. Robert L. Ajax
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
n
-------
AL
-------
TABLE OF CONTENTS
Chapter ' Page
1.0 SUMMARY 1-1
1.1 Summary of Changes Since Proposal 1-1
1-.2 Summary of Impacts of the Promulgated Action 1-1
1.2.1 Alternatives to Promulgated Action 1-1
1.2.2 Environmental Impacts of Promulgated Action . . 1-1
1.2.3 Energy and Economic Impacts of Promulgated
Action ]_1
1.2.4 Irreversible and Irretrievable Commitment
of Resources 1-2
1.2.5 Environmental and Energy Impacts of Delayed
Standards 1-2
1.2.6 Corrections and Clarifications 1-2
2.0 SUMMARY OF PUBLIC COMMENTS 2-1
2.1 Selection of Source Category 2-1
2.2 Selection of Best Demonstrated Technology 2-4
2.3 Selection of Format of the Standards 2-14
2.4 Environmental Impact 2-16
2.5 Costs and Economic Impacts 2-20
2.6 General 2-33
APPENDIX A Calculation of Enclosure Capture Efficiency A-l
APPENDIX B Safety Concerns With the Use of Enclosures B-l
APPENDIX C Revised Text and Table From BID Chapter Eight. . . . C-l
LIST OF TABLES
Number Page
2-1 List of Commenters on the Proposed Standards of Performance
for Synthetic Fiber Production Facilities 2-2
2-2 Summary of Growth Projections Considered 2-22
-------
LA
-------
1.0 SUMMARY
On November 23, 1982, the Environmental Protection Agency (EPA)
proposed standards of performance for synthetic fiber production
facilities (47 FR 52932) under authority of Section 111 of Clean Air
Act. Public comments were requested on the proposal in the Federal
Register. There were 6 commenters composed mainly of industry and
industry association representatives. Also commenting was one State
environmental agency. The comments that were submitted, along with
responses to these comments, are summarized in this document.
1.1 SUMMARY OF CHANGES SINCE PROPOSAL
There have been no changes, other than editorial or typographical,
made to the regulation since proposal.
1.2 SUMMARY OF IMPACTS OF PROMULGATED ACTION
1.2.1 Alternatives to Promulgated Action
The regulatory alternatives are discussed in Chapter 6 of the
proposal BID. These regulatory alternatives reflect the different
levels of the emission control from which one is selected that represents
the best demonstrated technology, considering costs, nonair quality
health, and environmental and economic impacts on the synthetic fibers
industry. These alternatives remain the same and are described in
Chapter 6 of the proposal BID.
1.2.2 Environmental Impacts of Promulgated Action
The environmental impacts of the promulgated standards are described
in Chapter 7 of the proposal BID, and are essentially unchanged.
The analysis of environmental impacts in the BID Volume I,
with the changes noted in BID Volume II, now becomes the final
Environmental Impact Statement for the promulgated standards.
1.2.3 Energy and Economic Impacts of Promulgated Action
The energy impacts of the promulgated action are described in
Chapter 7 of the proposal BID, and remain unchanged since proposal.
1-1
-------
Economic impacts are described in Chapter 8 and 9. The values for
cost-effectiveness of the standards at facilities [projected in 1987
have been adjusted for accuracy, but still indicate the standards will
achieve emission reductions at reasonable cost.
1.2.4 Irreversible and Irretrievable Commitment of Resources
These impacts are discussed in Chapter 7 of the proposal BID, and
remain unchanged since proposal.
1.2.5 Environmental and Energy Impacts of Delayed Standards
Table 1-1 in the proposal BID provides a summary of the impacts
associated with the proposed standards. Delay in implementation of the
standards could result in additional VOC emissions, as described in
Chapter 7 of the proposal BID.
1.2.6 Corrections and Clarifications
Comments received from tie public following proposal included
notation of several minor typographical and mathematical errors in the
proposal BID and preamble. These are discussed in detail in Chapter 2
of this document and docket item II-B-2. None of the errors will
result in changes in the environmental or economic impacts of the
standards.
1-2
-------
2.0 SUMMARY OF PUBLIC COMMENTS
The list of commenters and their affiliations is shown in Table 2-1.
Six comment letters were received. A summary of the comments and EPA's
responses to them are presented in this chapter under the following
headings:
1. Selection of Source Category
2. Selection of Best Demonstrated Technology
3. Selection of Format of the Standards
4. Environmental Impacts
5. Costs and Economic Impacts
6. General
2.1 SELECTION OF SOURCE CATEGORY
2.1.1 Comment (IV-D-1, IV-D-2, IV-D-3, IV-D-4, IV-D-6):
Five commenters said that the proposed NSPS is not needed because
there will be no capacity additions in the solvent-spun synthetic fibers
industry in the next 5 years.
Response:
EPA does not agree with the commenters that there will be no
capacity additions in the next 5 years (see responses to Comments 2.5.1,
2.5.2, 2.5.8, 2.5.9, 2.5.14). Even if the commenters' projections
are correct, however, EPA believes the NSPS would still be warranted.
If growth is projected to occur, whether within 5 years or beyond 5
years, the issue is whether best control technology should be a factor
in that growth. The 5-year period has no special significance in the
decisions as to whether or not an NSPS is warranted. The 5-year period
is often a reasonable indicator of growth. However, such factors as
cyclic growth, the current economic downturn, etc., can result in
situations where projected growth in the next 5 years is not indicative
necessarily of long-term trends. Since an NSPS is intended to achieve
long-term benefits, it is important to look beyond 5 years. Even if
growth is not certain, however, it is still not unreasonable to promulgate
the NSPS. EPA has been developing it for over 3 years, and most of
2-1
-------
Table 2-1. LIST OF PERSONS SUBMITTING COMMENTS ON THE
PROPOSED STANDARDS
Docket Entry Number3 Commenter and Affiliation
IV-D-1 James C. Pullen
Manager, Environmental Activities
Celanese Fibers Company
Charlotte, North Carolina 32414
IV-D-2 Charles W. Jones., President
Man-made Fiber Produces Association, Inc
Washington, D.C. 20036
IV-D-3 (transmittal letter)
Robert R. Romano, Ph.D
Manager, Air Programs
Chemical Manufacturers Association
Washington, D.C. 20037
(body of comment)
Geraldine V. Cox, Ph.D
Vice President and Technical Director
Chemical Manufacturers Association
Washington, D.C. 20037
IV-D-4 (transmittal letter)
Robert L. Stoots, Jr.
Coordinator Agency Relations
Tennessee Eastman Company
Kingsport, Tennessee 37662
(body of comment)
James C. Edwards
Manager, Clean Environment Program
Tennessee Eastman Company
Kingsport, Tennessee 37662
IV-D-5 Daniel J. Goodwin
Manager, Division of Air Pollution
Control
Illinois Environmental Protection
Agency
Springfield, Illinois 62706
IV-D-6 David T. Modi
Attorney, Environment Division
E.I. duPont de Nemours and Company
Wilmington, Delaware 19898
aThe docket number for this project is A-80-7.Dockets are on file at
EPA Headquarters in Washington, D.C., and at the Office of Air Quality
Planning and Standards in Durham, N.C.
2-2
-------
the Agency resources for this project have already been spent. Since no
extra effort is required, and since early promulgation of these standards
would enhance the ability of facility owners to plan for whatever future
growth will be necessary, establishment of the standards at this time is
reasonable. Consequently, EPA believes the NSPS will be beneficial in limiting
VOC emissions from new or reconstructed synthetic fiber production facilities
when they are built, regardless of whether it is within 5 years or beyond.
2.1.2 Comment (IV-D-2):
One commenter claimed that the proposed regulation is unnecessary
because no new or significantly modified facilities that produce acrylic,
modacrylic, and cellulose acetate fibers will be built or required in the
next 5 years. This commenter referred to past communications for support
of this position, but did not cite the pertinent supporting portions.
He also claims the background information document (BID) for the proposed
standard contains significant errors of an economic and technical nature,
but no specific errors were noted. He summarizes by requesting that
EPA "---discontinue this needless activity."
Response:
As stated in the response to Comment 2.1.1, EPA believes that the
NSPS will be beneficial in limiting VOC emissions from affected facilities
when they are built, regardless of whether it is within 5 years or beyond,
and that there will be significant growth in this industry in the future.
The communications that have been provided by others have been carefully
considered, and it is EPA's conclusion that none affects EPA's assessment
of the benefits of the standards. The communications referred to in the
above comment overall do not show, in EPA's opinion, that the standards
are "needless." The commenter has provided no specific support for his
comment. Absent this information, EPA must conclude that it has made a
reasoned judgment based on the best information available, and that
there is not sufficient justification for discontinuing development of
the standard; the preponderance of information available shows that the
standards will result in emission reductions at reasonable cost from a
category of sources that contributes significantly to ozone pollution.
2.1.3 Comment (IV-D-6):
One commenter questioned the significance of VOC emissions from
synthetic fiber plants by pointing out the small percentage of VOC
2-3
-------
emissions^ contributed by the synthetic fiber industry to total VOC
emissions from all sources. He estimated that the fiber industry
baseline emissions are about 0.2 percent of emissions from all sources
and that the emission reduction achieved by the standard would amount
to 0.05 percent, or less, of total VOC emissions.
Response:
EPA agrees that VOC emissions from the synthetic fibers industry are
a small percentage of total VOC emissions; however, most VOC emissions
come from a large number of relatively small sources (when compared,
for example, with sources of particulate matter or sulfur dioxide,
which can be much larger). There are no relatively large individual
sources of VOC emissions; rather, emissions from all these industries
combined create the ozone danger Congress intended standards of perfor-
mance to address. Since these emissions can be reduced only by controlling
each type of contributor, most of these individual contributors must be
viewed as significant, even though emissions from each may seem small
when compared to the total. More specifically for this industry, EPA
considers synthetic fiber plants to be significant sources regardless
of the percentage of VOC emissions they contribute to the total. For
example, a typical dry spinning acrylic plant controlled to baseline
levels would emit about 1,900 megagrams of VOC per year. The NSPS
would reduce those emissions by about 1,100 megagrams per year. Section
302(j) of the Clean Air Act defines a major stationary source as one
that emits 100 tons (91 megagrains) or more of an air pollutant. For
these reasons, EPA believes that there is no reason to alter its con-
clusion, established by rulemaking at 40 CFR 60.16, that the synthetic
fiber production industry is a significant contributor of VOC emissions
and should be listed for regulation by an NSPS.
2.2 SELECTION OF BEST DEMONSTRATED TECHNOLOGY
2.2.1 Comment (IV-D-3, IV-D-4):
Two commenters said that it is not appropriate to transfer enclosure
technology used in some acrylic fiber production to filter tow production
because of fundamental differences in the types of solvents, raw
materials used, curing rates, aad resulting emission rates. The two
commenters provided conflicting views, however, concerning the weight
2-4
-------
and resulting curing rates of acrylic fibers as compared to filter tow.
Commenter IV-D-3 indicated that filter tow fibers are lighter and thus
would have a faster curing rate while commenter IV-D-4 indicated the
opposite would be true.
Response:
Neither commenter explained why the difference in emission rates
they believe to exist between acrylic and filter tow fiber spinning
would cause the use of enclosures for filter tow to be inappropriate.
Commenter IV-D-3 did provide a comparison between the variables causing
different emission rates for modacrylic and filter tow fiber production
but did not explain how these variables would affect the effectiveness
of enclosures. All the variables discussed by the commenters were
carefully considered by EPA during development of the proposed NSPS, as
indicated in Chapter 4 and Appendix C of the proposal BID. Unfortunately,
most of the data regarding solvents, raw materials, fiber size, and
curing rates are claimed to be confidential by the companies from which
they were obtained and, therefore, could not be discussed in detail
either in the BID or in this document. After consideration of these
variables, however, EPA concluded that properly designed and operated
enclosures are the most effective means of capturing VOC emissions from
all spinning facilities (with the exception, perhaps, of acetate filament
yarn - see 47 FR 52937, the preamble to the proposed NSPS).
A thorough investigation revealed no design, operational, or
safety problems associated with enclosures. In addition, in correspon-
dence to and meetings with EPA personnel during development of the
proposed NSPS, representatives of commenter IV-D-4 made the following
statements: "The design and installation of an enclosure system does not
pose any formidable problems." (Attachment 1 to docket item II-E-92),
and ". . . technically, enclosures could be designed to effectively
capture VOC emissions from the spin cell area and provide worker access."
(Page 2 of docket item II-D-68).
One representative noted that his company has studied the possibility
of recovering fugitive acetone emissions from their filter tow process.
He noted that enclosures are the most viable capture system to pursue
but that it is not now economically attractive. He estimated that an
2-5
-------
enclosure system would have an approximate 5-year return on investment
(docket item II-D-68).
Finally, enclosures are being successfully used on a filter tow
spinning facility in Japan, confirming EPA's position that they are
appropriate as control technology on new and reconstructed filter tow
facilities that would be subject to the NSPS.
2.2.2 Comment (IV-D-3, IV-D-4):
Two commenters claimed that enclosures do not meet the requirements
for best demonstrated technology for the cigarette filter tow industry
because they have not been demonstrated for domestic facilities.
Commenter IV-D-3 also stated that enclosure technology has not been
demonstrated for many acrylic fiber production areas and is not
representative of technology employed by this category.
Response:
The commenters' use of the term "best demonstrated technology" is
a reference to Section lll(a)(l)(C) of the Clean Air Act, which specifies
that a standard of performance "... reflects the degree of emission
reduction achievable through the application of the best system of
continuous emission reduction 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." EPA
normally refers to this system of continuous emission reduction as
"best demonstrated technology" or BDT.
The commenters have interpreted the Section 111 requirement that
the system be adequately demonstrated as meaning that it be in actual
use at each type of existing facility in the category of sources being
regulated and that it be achieving the level of the NSPS for which it
is the basis. EPA interprets the requirement more broadly. Control
technology can be considered BDT if it can be shown to be the best
system demonstrated for the category of sources, not necessarily on the
category of sources. This means that a system used in an entirely
different industry using a different process from the one being regulated
can be BDT if its performance would not be affected by the differences
in the sources. Similarly, a system used in some segments of the
industry being regulated, or in some parts of the process, but not
2-6
-------
others, can be considered BDT for all segments or all parts of the
process if investigation of the relevant variables reveals no reason that
it cannot be designed, installed, and operated so that it achieves the
same emission control under all the conditions in which it would be
applied.
This interpretation of the term "demonstrated" has been upheld in
the courts. As stated by the D.C. Circuit in Portland Cement Association
v. Ruckelshaus, 486 F.2d 375, 391 (1973):
"We begin by rejecting the suggestion of the cement manufacuturers
that the Act's requirement that emission limitations be 'adequately
demonstrated' necessarily implies that any cement plant now in
existence be able to meet the proposed standards. Section 111
looks toward what may fairly be projected for the regulated future,
rather than the State of the art at present, since it is addressed
to standards for new plants - old stationary source pollution
being controlled through other regulatory authority."
EPA believes that enclosure technology as a means of capturing VOC
emissions from sources in synthetic fiber processing facilities meets
these criteria (as explained in the response to comment 2.2.1) and
therefore represents BDT for the industry.
2.2.3 Comment (IV-D-3, IV-D-4):
Two commenters stated that the 90 percent capture efficiency for
enclosures that is part of the basis for the NSPS is not supported by
adequate documentation or data. They also contended that since enclosures
must be opened frequently to allow worker access to equipment, the 90
percent capture efficiency is not supportable. Commenter IV-D-3 estimated
that enclosures could capture no more than 86 percent of VOC emissions.
He apparently based this efficiency on an estimate that enclosures
would be open, rendering the system ineffective, for 8 to 19 percent of
the time and that overall out-of-service time for the enclosures would
be about 14 percent.
Response:
As indicated in the preamble to the proposed NSPS (47 FR 52936),
the 90 percent capture efficiency used by EPA to calculate achievable
emission reductions was based on solvent use and emission data collected
for fiber production facilities of several companies. Emission tests
were conducted and solvent mass balance data collected at acrylic fiber
plants that use enclosures (docket items II-A-19, II-A-20, II-B-99).
2-7
-------
Although these data indicated that the tested plants were achieving
about 95 percent capture with their enclosures, EPA selected 90 percent
to account for the more frequent opening of enclosures to allow worker
access that is necessary at filter tow facilities (estimated at 14
percent based on information provided to EPA by commenter IV-D-4 (docket
item II-D-68)).
In order to respond to commenter IV-D-3's concern that the opening
of enclosures for as much as 19 percent of the time would further
reduce the capture efficiency of the enclosures to 86 percent, EPA
recalculated the efficiency. (For the detailed calculation, see Appendix A.)
The calculation indicates that under these worst-case conditions, the
lowest capture efficiency would be over 91 percent, not the 86 percent
claimed by the commenter. Therefore, EPA continues to believe that
enclosures on fiber processing facilities can consistently achieve
greater than 90 percent capture.
2.2.4 Comment (IV-D-3):
One commenter criticized EPA for not having a standardized method
for measuring capture efficiency and referred to a memorandum written
by EPA's contractor that indicated the lack of a test method to measure
capture efficiency created a problem in determining emission rates.
The commenter also cited a memorandum written by EPA's Office of General
Counsel regarding capture efficiency as it relates to the NSPS for
rubber tire manufacturing. The memo discussed the need to specify an
acceptable method for measuring capture efficiency since it was an
integral part of the rubber tire standard.
Response
Although an acceptable test method for directly measuring
capture efficiency of enclosures at synthetic fiber plants would have
been helpful during development of the proposed NSPS, it was not
essential and is not needed to show compliance with the standard. EPA
was able to determine capture efficiencies of enclosures through use of
solvent mass balances, emissions data, and other industry-provided
information (see response to comment 2.2.3) to determine the level of
VOC emission control reflected in the standard.
The standard itself does no_t require determination of capture
efficiency. Rather, it requires a calculation involving plant records
2-8
-------
of solvent flow and/or polymer flow Into and out of the affected facility.
While the OGC opinion may be appropriate for the rubber tire NSPS, it
is not relevant to the synthetic fibers NSPS because it requires a
different means of demonstrating compliance that does not involve
determination of capture efficiency.
2.2.5 Comment (IV-D-3. IV-D-4):
Commenter IV-D-3 asserted that capture efficiency of an enclosure
is decreased by the efficiency of the ultimate control device (e.g.,
carbon beds). He noted that if a carbon bed is estimated to be 92
percent efficient, then the total capture efficiency of the enclosure
could be no more than 80 percent (0.86 x 0.92 = 0.79). Commenter IV-D-4
said, "... because vapors captured by the enclosure must be routed
subsequently to other control devices (e.g., carbon beds), a 90 percent
enclosure efficiency is'not supportable or realistic."
Response:
Both commenters are apparently referring to overall control efficiency
rather than capture efficiency. Capture efficiency is the amount of
a substance collected or captured by the enclosure compared to the
amount released by the source enclosed. Thus, any downstream treatment
by a control device has no bearing on capture efficiency. It should
also be noted that in'the BID the only application for which a carbon
bed was specified to be 92 percent efficient at synthetic fiber production
facilities is one treating filter tow dryer emissions which have unusually
high relative humidity. All other carbon beds operated in the synthetic
fibers industry can achieve over 95 percent efficiency, as discussed in
the BID and preamble.
2.2.6 Comment (IV-D-3, IV-D-4):
Two commenters claimed that the use of enclosure technology on
filter tow facilities would create a safety hazard because acetone
concentrations within the enclosures could build up to explosive levels
within 30 seconds. They acknowledged that a foreign producer uses
enclosures in filter tow facilities but believed that the fundamental
differences (spinning line speeds) in the foreign and domestic operations
make transfer of this technology to domestic operations inappropriate.
They expressed concern that the manual activation of safety systems
2-9
-------
used by the foreign producer would not be fast enough to rely on to
prevent an explosion within the 30 seconds it would take for a potential
explosion to occur.
Response:
The safety of enclosures on filter tow facilities was a subject of
several meetings and communications between EPA and commenter IV-D-4
during development of the proposed NSPS (docket items II-B-76, II-B-92,
II-E-87, II-E-89, II-E-91, II-E-92, II-E-94, and others). All the
points regarding safety raised in their comment on the proposed NSPS
were considered by EPA prior to proposal. As discussed in Chapter 4 of
the proposal BID, EPA is aware that domestic producers would not rely
solely on manual activation of safety features to avoid explosions
within enclosures. The system envisioned by EPA would be designed such
that the exhaust fans would be interlocked mechanically, electrically,
or otherwise with the spin cell extrusion pumps. Should the exhaust
fans fail, fiber would no longer be produced, additional solvent would
not be released into the enclosure, and the enclosure doors would open
automatically. This would allow dilution and diffusion of the solvent
vapor into the room air.
EPA does believe that manually opening the enclosure doors is a
reasonable and dependable backup or failsafe method of preventing the
buildup of explosive vapor concentration. It should be noted that
workers currently must observe the machines constantly to respond
immediately to spinning machine malfunctions and "roll breaks," or
"feed wheel wraps." (These terms, used by two different fiber producers,
both refer to the malfunction in which fiber exiting the spin cell is
wrapped around the godet roll. The wrap will become larger as more
fiber is wound, and will cause more serious problems if not cut and
removed quickly.) Thus, workers are always available to open the
enclosure doors should the automatic opening system fail to operate
when needed.
EPA believes that due to the automatic safety features
that would be designed into an enclosure system, the occurrence of an
exhaust fan shutdown with the simultaneous continued release of solvent
into a closed enclosure is very unlikely. Should such a situation
2-10
-------
occur, however, EPA agrees with the commenters that workers would need
enough time to respond to avoid an explosion. The commenters suggest
that the workers may have no more than 30 seconds to manually open the
enclosure doors but do not provide any supporting data.
To evaluate this claim, EPA calculated the amount of time required
for solvent concentrations to reach the lower explosive limit (LEL)
within an enclosure under worst case conditions. Data collected prior
to proposal of the NSPS (primarily from commeter IV-D-4) were used to
make the calculations.
Two situations were evaluated: one is a pilot enclosure system
designed by commenter IV-D-4 and the other is a system for a hypothetical
50 million pound per year plant. For both situations, it is assumed
that fiber spinning continues after the exhaust fan stops suddenly and
the enclosure doors remain closed. EPA's calculations indicate that it
would take 2.4 minutes to reach the LEL at the pilot system and 5.1
minutes to reach the LEL at the hypothetical plant. There would be an
adequate amount of time in either situation for a worker tending the
machines to manually open the enclosure doors if the automatic door
opener fails. (See Appendix B for the detailed calculations).
Thus, EPA believes that the enclosure systems that represent BDT
for the proposed NSPS do not pose any risk of explosion that cannot be
alleviated by proper design and operation.
2.2.7 Comment (IV-D-3, IV-D-4):
One Commenter (IV-D-4) claimed that the use of enclosures on
spinning machines would negate current fire protection measures. He
claimed that "enclosure systems connected to a control device would
have unlimited oxygen supply and ready ignition sources." Another
commenter (IV-D-3) noted that the spinning cabinets in use at domestic
filter tow plants are isolated from each other, and cabinet fires are
prevented from flashing over to other cabinets. He claimed the tow
line enclosure would provide a connection between all the cabinets
along a spinning line, so that a fire in one cabinet along a spinning
line could ignite all the cabinets. This commenter also noted the
danger of an "unlimited supply of oxygen," where enclosures are
used.
2-11
-------
Response:
The comments that an enclosure system would create an unlimited
oxygen supply, ready ignition sources, a.nd a convenient route for fire to
spread from one to several or all the spinning cabinets on a line reflect
an incorrect appraisal of a properly designed and fail-safe enclosure
system.
Before responding, it is first important to make clear that fire can
potentially propogate in two ways in a situation such as this. In one,
the flame would propogate along the surface of the fiber, the potential
for which would be the same with and without enclosures. In the other,
the flame would propogate through the vapor space, a phenomenon described
here as flashover.
The commenters in this case appear to be referring to flashover.
This can only occur when there is a limited supply of oxygen, which causes
vapor concentrations to be in the "explosive range." When there is too
little oxygen, the vapor exceeds the upper explosive limit (UEL). When
there is an excess of oxygen, the vapor concentration is below the lower
explosive limit (LEL). In neither case is fire or explosion of the vapor
possible.
The comments about an unlimited oxygen supply apparently refer to
the continuous flow of air drawn into the enclosure by its exhaust system.
The volume of air drawn into the enclosure, however, is established by
the design of the enclosure and exhaust system so that the solvent vapor
concentration is maintained well below the LEL during normal spinning
operation. In other words, the vapor in the enclosure could neither
ignite nor support a flame, and, as a consequence, a fire in one cabinet
could not spread via the enclosure to other cabinets. The reference to
an unlimited oxygen supply being a hazard or safety concern is, therefore,
inappropriate.
The only upset condition germane to the discussion of oxygen supply
or the flashover of fire from one to other spinning cabinets is the
malfunction of the enclosure's primary exhaust system concurrent with
continued spinning. In this situation, the air (oxygen) supply is no
longer continuous nor unlimited but is fixed by the volume of the enclosure,
2-12
-------
If no other safety features alleviate the malfunction, the solvent vapor
concentration might approach explosive limits, (see the response to
Comment 2.2.6 and Appendix B for a determination of the time required).
However, the enclosure should be designed and equipped with secondary
exhaust systems, alarms, automatically opening doors, and line shutdown
interlocks with the spinning pumps. In addition to these mechanical
features, operators are always standing by to correct this and other
malfunctions. At worst, then, the malfunction would cause the safety
mechanisms to create conditions identical to current operating conditions
without an enclosure, i.e., the spun yarn and solvent would be exposed to
the spinning room atmosphere.
With respect to the commenter's claim concerning an increased number
of ignition sources, no further information was provided. No system
designs considered to reflect BDT would affect the type or number of
ignition sources already available. Note, however, that with the enclosure
doors closed, worker access is prevented, and the solvent vapor is physically
separated from the workers, from sparks or flames caused by tool malfunctions,
and from any other ignition sources.
EPA concludes that enclosures can be designed and installed to create
an effective solvent vapor capture system while maintaining operating
conditions that pose no greater risk for fires or explosions than current
operating conditions without enclosures.
2.2.8 Comment (IV-D-1):
One commenter requested that enclosures for crimpers at filter
tow facilities should be considered an emission control option to be
used only if necessary to meet the NSPS. He discussed difficult operating
and maintenance problems that would be caused by crimper enclosures.
He also indicated that the amount of residual solvent remaining on the
tow by the time it reaches the crimper is miniscule.
Response:
EPA recognizes that the installation of enclosures on crimpers
at existing plants would present unreasonably difficult operating and
maintenance problems. However, EPA believes enclosures could be
appropriately designed and operated for new facilities subject to the
NSPS so as to present no particularly difficult operational problems.
2-13
-------
Information provided in Table 6-8 of the BID, which reflects
data received from several manufacturers, indicates that residual
solvent at the crimper would not be "miniscule" but would amount to a
significant percentage of total VOC emissions from the entire facility.
However, if it is miniscule, control equipment would not be needed.
It should be noted that the NSPS is an emission limit, not an equipment
standard, and does not itself require enclosures for crimpers.
2.2.9 Comment (II-D-3, II-D-4):
Two commenters claimed that the use of enclosures would create
worker exposure problems whenever worker access is necessary because
the enclosures would concentrate acetone vapor to levels higher than
permitted by OSHA and internal guidelines. The commenters further
claimed that because of "rapid production rates and need for immediate
worker access," it would not be possible to purge the'enclosure prior
to opening the access doors.
Response:
The commenters are correct in stating that the solvent vapor would
be more concentrated with enclosures than without. However, testing at
a plant that uses enclosures (docket item I1-8-99) revealed that when
a door is opened for worker access, substantial flow of air into the
enclosure causes considerable dilution. Secondly, the tested plant
uses a spinning solvent that is far more toxic than acetone (the TLV is
10 ppm vs. 1,000 ppm for acetone) and has effectively dealt with the
personnel exposure problem through the use of work practices, as described
below. It is therefore apparent that plants using acetone in spinning
should as well be able to effectively control their solvent vapor so as to
avoid personnel exposure problems.
One Japanese manufacturer has installed enclosures at filter tow
spinning facilities not only for solvent recovery but also to limit
worker exposure to acetone. In that country, the exposure limit is 200
ppm, compared to the OSHA limit in the U.S. of 1,000 ppm. The enclosures
are always under negative pressure created by the exhaust fan. Tests
showed (docket item II-B-99) that when an enclosure door is opened
there is a large inflow of room air past the worker and into the enclosure,
2-14
-------
flushing the immediate area. Thus, there is is no need for a special
system purge prior to opening an access door, and there would be no
resulting production delay.
Where many doors are opened at once, as in the case of a "roll
break," the concentrated vapor within the enclosure is immediately
diluted and diffused into room air. This is the procedure followed by
the Japanese acetate filter tow manufacturer, who also reports no
problems with worker exposure. This is all the more significant in
light of the lower personnel exposure limit. Therefore, EPA believes
that worker exposure to acetone vapors can be effectively controlled to
safe levels.
2.2.10 Comment (IV-D-1, IV-D-3, IV-D-4):
Three commenters said that although air management can be an
effective tool to control solvent concentration pockets and reduce
worker exposures, its use as an air emissions control technique is
limited. Therefore, it should be considered only an optional and not
mandatory method to be used if the affected facility cannot otherwise
achieve the NSPS. Commenters IV-D-1 and IV-D-3 said that the costs and
energy impacts of treating the large volumes of air in such a system
should be evaluated. Commenters IV-D-3 and IV-D-4 said that air
management has not been successfully demonstrated for domestic fiber
production areas.
Response:
The air management control option to which the commenters refer
was used by EPA as the basis for the VOC emission level achievable at
cellulose acetate filament yarn processing facilities. Although they
claimed the use of air management is "limited," the commenters did
not identify or explain its limitations as a control technique. The
standards do not require that air management be used, but this option
is the best system that EPA found for controlling emissions at filament
yarn processing facilities. It is currently being used at a filament
yarn plant operated by commenter IV-D-1. Thus, it has been demonstrated
for the type of facility for which EPA selected it as BDT. The increased
costs and energy impacts associated with treating the large air volumes
2-15
-------
associated with this system were analyzed by EPA (see Chapters 7 and 8
of the BID) and were found to be reasonable.
2.3 SELECTION OF FORMAT OF THE STANDARDS
2.3.1 Comment (IV-D-1, IV-D-3, IV-D-4):
Two commenters suggested that the format of the standards should be
changed to kg VOC per Mg fiber extruded (the proposed format was kg VOC
per Mg solvent used). Commenter IV-D-1 suggested that the standards
should be expressed in both formats. All the commenters said that many
plants already keep records of solvent loss compared to the amount of
fiber extruded. Commenters IV-D-3 and IV-D-4 also indicated that the
proposed format would require unjustified expensive monitoring of
multiple process streams and burdensome recordkeepirig because the costs
would be several times higher than the $5,000 estimated by EPA. They
further claimed that the proposed format would allow VOC emissions to
increase with increased solvent usage, and commenter IV-D-3 said that
the proposed format would encourage such an increase.
Response:
The format for the proposed standards was selected by EPA to
provide maximum flexibility to owners and operators of affected facilities
in determining compliance. After a careful review of the commenters1
points, EPA concludes that the format should not be changed. Even
though the format is expressed in units of VOC emissions per unit
solvent used, the procedures for demonstrating compliance in 40 CFR
60.603 allow the option of determining VOC emissions per unit of fiber
extruded using existing plant records, as recommended by the commenters.
To convert the result to units of the standards as expressed in
40 CFR 60.602, a simple multiplication of the solvent-to-polymer ratio
for the affected facility is all that is required. Thus, the regulation
accomplishes what the commenters suggested while allowing owners and
operators to choose the procedure that is best suited to the situation.
It also reflects the use of BDT at each facility, whereas an emissions
per unit fiber format would not. A format of that type would have to
be based on an assumed solvent-to-polymer ratio, which varies from plant
to plant as discussed below.
2-16
-------
JPA disagrees with the commenters' statement that the format of
the standards would encourage increased use of solvent and higher VOC
emissions. The commenter is apparently assuming that a company would
change its solvent-to-polymer ratio to reduce the ratio of VOC emissions
to solvent used. Information provided to EPA by all of the fiber
producers indicates that a company very carefully selects a solvent to
polymer ratio for process reasons, and that it usually has a small
variability tolerance. To adjust the ratio in order to achieve apparent
VOC emission reductions would likely adversely affect fiber quality.
EPA believes that the marginal changes in apparent VOC emission reduc-
tions following a ratio adjustment would not justify such radical
process changes.
EPA does not believe that the costs of solvent flow meters and
associated recordkeeping are unreasonably expensive. Information
(docket item II-B-38) submitted by several vendors of flowmetering
equipment shows that totalizing flow meters with an accuracy of
± 1 percent over the operating range typically cost no more than
$5,000 each. Some equipment of the type required costs as little as
$2,000 per meter, including peripheral equipment. To be certain that
the cost of metering equipment was not understated, new information
was gathered after receiving the comment (docket item number IV-D-7
and IV-D-8).
This new information confirms that the totalizing flow meters cost
less than $5,000 per unit. The number of units required at an affected
facility depends on the facility's choice of format for reporting, the
particular layout of pipes and tanks, and the process itself. However,
EPA estimates that no more than 12 meters would be needed at a new
facility to comply with the monitoring requirements (assuming the owner
or operator chooses to meter all solvent flows rather than use the
plant records procedure described above). At a maximum cost of $5,000
each, the total cost for the meters would be $60,000. Recording costs
would be very small since only monthly totals would be recorded.
Therefore, the maximum cost for monitoring would be about 1 percent
of the capital cost for the VOC emission control equipment, which in
turn would be about 8 percent or less of the capital cost for new
2-17
-------
facilities. EPA considers these monitoring costs to be reasonable in
light of the usefulness of accurate monitoring to assure the emission
reductions intended under the standards.
2.4 ENVIRONMENTAL IMPACT
2.4.1 Comment (IV-D-6):
One commenter questioned the accuracy of the baseline emission
rate and resulting emission reduction values for Model Plant 2 (dry-
spun acrylic facility). He claims the only domestic dry-spun acrylic
manufacturing facilities in the United States currently emit at lower
rates than estimated for baseline (32 vs. 45 kg/1000 kg fiber) by
controlling emissions from spin cell exits. As a result, emission
reductions and solvent recovery credits are overstated, he claims.
Response:
The issue raised by the commenter is whether EPA should have
assumed that a new dry-spun acrylic plant would install the same VOC
emission control equipment currently used at existing plants. DuPont
is currently the only domestic producer of dry-spun acrylic fibers.
However, another company could enter the market in the future using a
process different from DuPont1s. The main reason that DuPont captures
the dimethylformamide solvent (DMF) emitted at the spin cell exits is
to protect worker health. DMF is highly toxic, with a threshold limit
value (TLV) of 10 ppm. DuPont's capture and recovery of DMF results
in a lower emission rate than would occur at a plant using a less
toxic solvent that could be removed from a work area through room
ventilation and exhausted to the atmosphere. Therefore, EPA believes
it is appropriate to evaluate the impacts of the NSPS against the
baseline assumptions that were presented in the BID.
To respond to the commenter's concerns, however, EPA calculated
the emission reduction that would occur if new dry-spun acrylic facilities
were identical to the DuPont plants. The VOC emission reduction at
acrylic plants that is attributable to the NSPS would be about 1,500 Mg
rather than about 2,000 Mg estimated in Table 8-14 of the BID. Even if
the lower emission reduction were accurate, the cost per megagram of
emission reduction would be as much as $266/megagram, instead of the
$200/megagram projected by EPA. These costs are considered reasonable.
2-18
-------
2.4.2 Comment (IV-D-6):
The commenter claims that in Table 6-6 of the BID, the Alternative
III emission rate for Model Plant 2 should be 20 kg instead of 18 kg.
This error, combined with the overstatement of the baseline emission
rate (discussed in comment 2.4.1) results in an overestimated emission
reduction potential.
Response:
The commenter does not indicate the basis for the 20 kg emission
rate; however, confidential information provided earlier by this com-
menter (docket item II-D-94) was apparently the basis of this claim.
Examination of solvent use and emission figures for two plants in the
document reveal only minor variance from the EPA-developed values given
in the BID, even when compared item for item within the totals. Further,
emission value variation between the two plants described in the confi-
dential document was slightly greater than the variation between the
values for the plants and the EPA values. Therefore, EPA believes that
stated emission values in the BID reflect the conditions expected at
facilities operating under Alternative III controls.
2.4.3 Comment (IV-D-6):
One commenter noted an apparent mathematical error on the model
plant representing Alternative III for dry-spun acrylics (page 6-23,
Table 6-6). The make-up rate for Regulatory Alternative III should be
43 kg he claims, not 42 as shown, since the constituents are 18 kg
(emissions), 20 kg (nongaseous losses) and 5 kg (residual in the fiber)
for a total of 43 kg.
Response:
The correct value for total make up at the model plant is 42 kg
per 1,000 kg fiber as presented in the BID. The apparent error
noted by the commenter results from rounding up of the make-up rate
constituent values to whole numbers for presentation in the BID. The
value of 43 kg is the total of the rounded values.
2.4.4 Comment (IV-D-6):
The commenter stated that the EPA emission reduction estimate
projected for 1987 is not accurate because there will be no new facilities
subject to the NSPS through 1985.
2-19
-------
Response:
EPA's growth projections are discussed in Section 2.5 of this
document. EPA continues to believe that growth will occur and that
significant emission reductions will result from the NSPS. The projected
1987 emission reductions are estimates and may be more or less than the
actual reductions that will occur.
2.4.5 Commenter (IV-D-6):
One commenter noted that emissions for model plants (47 FR 52938,
3rd column, 1st paragraph) and 1987 projected facilities were not
computed with the same capacity utilization; emissions for the former
were computed based on 95 percent utilization, while the 1987 projected
acrylic dry-spun affected facilities were based on 81 percent utilization.
He thus claimed that EPA was "looking for the figure that is largest."
Response:
The 95 percent utilization rate was assumed for model plants to
reflect normal operating conditions under a full market demand situation.
EPA would be remiss if this condition were not evaluated, since it
will be experienced by some or all new plants at least some of the
time. On the other hand, there are other periods when plants are not
fully utilized. A correct overall, long-term perspective on an annual
basis must consider both. Therefore, a utilization rate of 81 percent
was assumed as an annual average for new plants for a typical year.
EPA was not "looking for the figure that is largest," but was trying to
estimate emissions and costs under high production as well as nominal
conditions. Using 95 percent instead of 81 percent to estimate emissions
for individual plants did not affect EPA's decisions regarding the
significance of the sources. Either utilization rate would cause
emissions of more than 1,000 tons per year from an individual plant
operating under baseline conditions.
2.4.6 Comment (IV-D-3):
One commenter felt that Regulatory Alternative II for acrylic/
modacrylic production facilities (Model Plants 1 and 3) failed to
include emission reduction requirements for polymer solutioning, or
cutting and baling areas. This commenter claimed that "solvent losses
2-20
-------
from these areas will typically account for approximately 33 percent
recovery of total solvent lost."
Response:
The commenter is correct in saying that EPA did not include
emission reduction requirements for these areas. Model Plants 1 and 3
were developed to characterize wet-spun acrylic and dry-spun modacrylics,
respectively. These model plants were reviewed on several occasions by
industry representatives, and appropriate revisions were made to
subsequent drafts; the parameters given in the BID reflect the most
accurate information available to EPA.
Emission values for each 1,000 kg of acrylic fiber, as listed on
pages 6-16 and 6-28 of the BID show that filtering/dissolving
("solutioning") amount to only 1 kg of the 40 kg emissions, and that
total solvent lost (which equals makeup) equals 70 kg. Likewise, the
emission value shown for the cutting/baling area is 1 kg of the 40 kg
emission losses or 70 kg total losses. Emission values for each 1,000
kg of modacrylic fiber show that emissions from solutioning amount to 5
kg of the 140 kg emissions or 155 kg total solvent loss. Industry
reports that the solvent residual in the fiber after drying is very low
(as low as 0.5 percent by weight). Thus, it is not possible that
substantial amounts of solvent, relative to total solvent loss, could
be released after the drying stage; the negligible solvent released in
the cutting and baling area is not sufficiently concentrated to permit
economic recovery. None of these emission values approaches 33 percent
of total solvent loss or total solvent emissions.
EPA did not include emission reduction requirements for these areas
because the emissions are small relative to either total emissions or
total solvent loss, and it would not be technically or economically
feasible to attempt recovery. However, should there be a new process
development that causes more solvent to be emitted at these points, they
would probably need to be controlled to achieve compliance with the
NSPS.
2.5 COSTS AND ECONOMIC IMPACTS
2.5.1 Comment Summary (IV-D-6, IV-D-3, IV-D-4);
One commenter (IV-D-6) claimed that the 1982 and 1987 production
forecasts for acrylics as given in Table 7-1 are overstated. He further
stated that current capacity will be adequate through 1987. Two
2-21
-------
commenters (IV-D-3, IV-D-4) claimed that the in-house regression equations
used by EPA to project growth in the industry are oversimplified, and
do not yield results consistent with traditional and historically
proven industry forecasting authorities (Stanford Research Institute,
Textile Industries, and the Chemical Economics Handbook). Citing a
current domestic production capacity utilization rate of 74 percent
(Textile Organon. July, 1982), commenter IV-D-3 stated that reliable
industry forecasts predict that no new production capacity will be
needed during the next five years.
Response:
EPA made its 1983-87 growth projections for acrylic and modacrylic
fibers and cellulose acetate arid triacetate fibers using both published
sources referenced by the commenters and in-house regression analyses.
Published projections definitely were not ignored. In fact, the pro-
jections sections of the Synthetic Fibers Production Facilities BID
(pp. 9-36 to 9-44, 9-60 to 9-69) discuss nearly all of the sources
suggested by the commenters. EPA found that many of the projections
reviewed did not cover the time period (1983-1987) and/or variable of
interest. Where appropriate, EPA did use the published projections as
well as its regression results in performing its analysis.
EPA also found that there was quite a difference in the growth
rates forecast by the published projections. EPA addressed these
variations by selecting a projection range bracketed by a high and low
production projection for all three solvent spun synthetic fiber
commodities projected in Chapter 9. These commodities were: acrylics
and modacrylics, acetate textiles, and acetate filter tow. For two of
these commodities, acrylics/modacrylics and acetate textiles, the low
growth projection embraced the contention of some of the commenters
that there would be no new plant construction in the projection period
(BID, p. 7-2).
Table 2-2 provides a summary of the projections considered. Both
Textile Industries and Textile Organon have published projections for
domestic consumption of acrylic and modacrylic fibers, but neither
source specifically addresses production. Projections have appeared in
Chemical and Engineering News but the bases and sources of these projections
are not specified, and the period of "long-term" 1 percent growth is not
2-22
-------
Table 2-2. SUMMARY OF GROWTH PROJECTIONS CONSIDERED
Fiber products
projected
Acrylic fiber
production
Acrylic fiber
demand
Acrylic fiber
-domestic
mill con-
sumption
Acrylic fiber
-domestic
consumption
Acrylic fiber
production
Acetate textile
fibers
Cigarette filtra-
tion tow
Acetate and
rayon domes-
tic fiber
consumption
Acetate textile
fiber produc-
tion
Cigarette filter
tow production
Source*/
date
DRI
Winter 1979
C&EN
12/1/80
Texti 1 e
Industries
2/79
Texti 1 e
Organon
1/81
Regression
analysis,
1982
CEH
11/76
Textile
Industries
2/79
Regression
analysis,
Regression
analysis,
1982
Period of
projection
1978-90
1982-85
"long-term"
1982-87
1979-85
1981-87
1975-81
1975-81
1977-87
1981-87
1981-87
Projected annual
growth rate
(%)
2.3
5.6
< 1.0
1.6
2.7
2.8
to 2.4
-3.5
4.8
-2.0
1.0
to 0.9
4.7
to 3.6
or 7.2
C81)
C87)
('81)
C87)
('81)
C87)
*Full references contained in Chapter 9 of BID
2-23
-------
dated. Data Resources, Inc. (DRI), in its publication Chemical Review
(Winter, 1979), provides production projections through 1987 based on
data through 1978. DRI's compound growth projection of 2.3 percent from
1978-1990 compares favorably with EPA's linear regression. The Textile
Industries projection was ultimately used by EPA for the lower bound
projection of acetate fiber production.
Published growth projections for cellulose acetate and triacetate
textile fibers in Textile Industries do not separate acetate from rayon
fibers and rayon production greatly exceeds acetate fiber production.
Thus, rayon dominates the classification and the projection. The
acetate textile projections available from the Chemical Economics
Handbook (CEH) were based on 1975 data. Newer projections are now
available from CEH, but these projections still cover only the first
part of the projection period. Currently, CEH projects very modest
growth in total acetate and triacetate fiber production through 1984.
Acetate textile fiber production is projected to decline, but increases
in cigarette filtration tow production are expected to slightly outweigh
this decline. The growth projections EPA ultimately used, in conjunction
with current capacity utilization, resulted in forecasts of no new
acetate textile fiber plants under either the low or high growth estimates
and two to four new cigarette filtration tow plants under the low and
high growth estimates, respectively.
The regression estimates employed by EPA to supplement published
projections have been constructed in accordance with accepted methodology.
The regression methodology employed is discussed in Chapter 9 of the
BID, and, for the purposes of projecting emission potential, is as
complete and sophisticated as is possible given data and resource
availability.
2.5.2 Comment (IV-D-1):
One commenter contended that, while the demand for domestically
produced cigarette filter tow is likely to grow over the projection
period, additional production of that commodity could be met by shifting
acetate textile fiber capacity to filter tow production. This would be
feasible because the commenter projects a decline in acetate textile
fiber demand and production.
2-24
-------
Response:
While EPA does not project any new acetate textile fiber plants,
its examination of recent production levels (1975-1979) indicated a
stabilization in production of the product after dramatic production
declines in the 1970-1975 period. By 1980, most of the excess capacity
in the acetate textile fiber sector had been eliminated. (Capacity
utilization in 1980 was over ninety-two percent.) Moreover, the time
trend in production over the 1975-1979 period showed a slight increase
(one percent per year). As a result, EPA concluded that during the
projection period, excess acetate textile fiber capacity would not be
available to augment the current cigarette filter tow capacity.
Consequently, any substantial increase in the demand for production of
cigarette filter tow would necessitate new plant construction.
2.5.3 Comment (IV-D-6):
One commenter claimed that the credit for recovered solvent was
overstated because the full market price was used in calculating the
credits. The commenter explained that a fiber producer who also is a
manufacturer of the solvent in question will not get the credit for
full savings, but only for the actual costs of manufacturing and
transportation.
Response:
The decision to use the market prices of solvents to calculate
recovery credits was based on generally accepted economic principles.
In a competitive setting, market prices represent the opportunity cost
of resources. Internal accounting valuations often reflect sunk costs
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. The
economic concept of opportunity cost as reflected in market prices
should be the basis for an economic analysis of a standard. To argue,
as these commenters have, that the internal opportunity cost of their
solvent production equipment is zero is in conflict with the premium
(as embodied in price) that the external market appears to place on
that equipment.
2.5.4 Comment (IV-D-1, IV-D-3, IV-D-4):
The commenters noted that capital costs for model plants did not
include costs for utilities and polymer manufacturing. They indicated
2-25
-------
that if present domestic acetate fiber plants run at full capacity,
there would likewise be no excess polymer capacity available to supply
a new filament or cigarette tow spinning facility. Commenter IV-D-1
cited the high cost of polymer manufacturing equipment (stainless steel,
etc.) and utilities such as coal-fired steam boilers, which when added
to the cost of a new spinning facility, would drive the product cost
beyond the competitive range with substitute fibers or imports. Another
commenter (IV-D-4) said the actual cost to a manufacturer for increased
fiber production should include the cost of new polymer manufacturing
capacity.
Response:
The commenters are correct that the model plants for cellulose
acetate fiber production do not include polymer manufacturing capacity
(e.g., acetate flake capacity), and the capital costs of polymer
production facilities are not included in new plant costs. This does
not mean that polymer costs are ignored. In the analysis, market prices
are used to estimate polymer costs to new plants. In a competitive
setting, market price represents the economic opportunity cost of any
resource. In particular, market price covers all the costs of production,
including payments on principal and interest, and therefore embodies
the capital costs associated with the production of the polymer.
Estimating future polymer prices therefore involves more than just
forecasting the cost of future plants. If the polymer industry is
operating near capacity (as is claimed), then the current market price
used in the analysis may actually reflect a price premium corresponding
to the additional cost of bringing new capacity on line.
2.5.5 Comment (IV-D-3, IV-D-4):
Two commenters claimed that the baseline capital cost for a new
filter tow plant should be $104 million instead of $67.1 million shown
in the proposal BID. Commenter IV-D-4 said that, as the builder of the
last filter tow plant in the world, his company is uniquely qualified
to provide cost data to EPA and had provided actual cost information
documenting a $104 million estimate.
Response:
We agree with commenter IV-D-4 that his company is well qualified
to estimate capital cost for new filter tow plants. The information
2-26
-------
supporting the $104 million estimate was carefully considered by EPA as
was other information provided by his company and other companies. In
response to an earlier similar claim, EPA explained in a letter to com-
menter IV-D-4 (docket item II-C-138), how the $67.1 million was derived
and why it was considered to be the best estimate after evaluating all
available information. The commenters have not provided any additional
cost data to support their comment. Therefore, EPA believes the capital
cost estimates for new filter tow plants should not be changed.
2.5.6 Comment (IV-D-3):
One commenter said that, based on a survey of actual costs, the
additional capital cost required to achieve Alternative II control at
acrylic/modacrylic production facilities (Model Plant 1) is understated.
Where the Agency estimated the Alternative II incremental capital cost
at $3.8 million, the commenter estimated it to be $6.3 million.
For Model Plant 4, the commenter disputed the incremental capital
cost estimates contained in the BID associated with the increased
control from Alternative II to Alternative III. Specifically, the BID
estimates an incremental capital cost of $1.2 million; the commenter
estimates these same costs at about $7.4 million, and claims EPA has
understated these costs by 516 percent.
Response:
Because some of the text and a related table provided by this
commenter made confusing and inappropriate comparisons, EPA contacted
this commenter and asked for clarification. However, the commenter did
not believe any revisions were necessary.
The commenter's claim concerning incremental capital costs for
Model Plant 1, Alternative II were not supported by any information or
data. For Model Plant 4, the commenter has inappropriately compared
incremental costs to arrive at the 516 percent value above. He correctly
shows the BID-reported incremental capital costs between Alternative II
and Alternative III at $1.2 million. He claims this value should be
$7.4 million, but the table of costs provided by the commenter shows
that $7.4 million is his estimate of the additional cost required above
baseline to meet Alternative III control. The commenter has thus
2-27
-------
incorrectly compared a baseline to Alternative III incremental cost
($7.4 million) with the EPA Alternative II to III incremental cost
($1.2 million).
Further it should be noted that the commenter has reported 1981-based
costs, and is comparing these costs directly with 1980-based costs.
Application of an inflation factor of about 10 percent for that period
would significantly narrow the difference between the BID values and
the commenter's stated values. The commenter's 1981 value of $7.4
million, if reduced by about 1C) percent for inflation, would be $6.7
million for comparable 1980 dollars. EPA reports (BID Table 8-3) the
incremental cost of control above baseline to Alternative III at $4.2
million. The appropriate comparison is therefore $4.2 with $6.7 million,
a difference of 37 percent, not: 516 percent.
EPA has received capital cost information from six plants that
manufacture acrylic and/or modacrylic fibers. The reported costs for
relevant process areas and items of control equipment at the various
plants did not cluster about a single value, but rather showed a range
of values. EPA recognizes that; there are legitimate reasons for the
variations, such as non-process related options, materials and quality
of construction, and variations; in the processes themselves. The values
presented in the BID will therefore not necessarily reflect any given
plant's costs exactly; EPA believes that the BID-presented costs are
reasonably valid representations of costs at new or reconstructed
facilities.
2.5.7 Comment (IV-D-3, IV-D-4):
Two commenters claimed that because the baseline capital cost for
a new filter tow plant was underestimated by EPA, a re-evaluation
of the cost-effectiveness using $104 million as the baseline capital
cost would show the standards to be unduly burdensome. Commenter
IV-D-3 also suggested that the same would be true for acrylic/modacrylic
fiber facilities.
Response:
The baseline capital cost referred to by the commenters is the
amount needed to build a new facility in the absence of the NSPS. It
is used as a "baseline" against, which to compare the costs associated
with control equipment to achieve the NSPS. Thus, it does not affect
2-28
-------
the cost-effectiveness of the NSPS. Cost-effectiveness is a comparison
of the increase in annualized costs (beyond baseline) to achieve the
NSPS to the increase in the amount of emission reduction (beyond
baseline). Thus, while the amount of baseline capital cost may affect
a company's decision to build a new plant, with or without an NSPS in
effect, it does not affect the cost-effectiveness of the NSPS. A
higher baseline facility cost does result in air pollution control
costs becoming a smaller percentage of the total cost of producing a
product.
2.5.8 Comment (IV-D-3, IV-D-4);
Two commenters said that filter tow producers could not afford to
build a new filter tow production facility because the high capital
cost of a new plant would require a price increase of 50 percent if
EPA's capital cost estimate for a baseline plant of $67.1 million is
used, or 75 percent if the commenters1 estimate of $104 million is
used. The commenters claimed that there would be no new plants built,
therefore, particularly since current prices of domestically produced
filter tow are under serious pressure from foreign competition.
Commenter IV-D-3 suggested that substitutes for filter tow might be
used by cigarette manufacturers if the price of filter tow increased
significantly. He also recommended that EPA recalculate the growth
forecast for filter tow by incorporating the 40 percent export market,
considering the effect of price increases on the export market, and
considering the excess capacity currently available. He also took
issue with the EPA position that the demand for cigarettes is highly
inelastic. The commenter felt that this assertion was disputed by
recent significant decreases in cigarette consumption in both the
United Kingdom and West Germany after the imposition of excise taxes.
In addition, the commenter cited the American Tobacco Institute estimation
of a 3 to 8 percent decline in 1983 domestic consumption of cigarettes
following the imposition of an $0.08 per pack excise tax.
Response:
Acetate filter tow manufacturers have a legitimate concern about
the international competitiveness of new facilities. Foreign exports
make up about 40 percent of their market. It should be noted, however,
that the high implicit prices for filter tow from new facilities
2-29
-------
originates almost exclusively from the cost of the facility, not from
the cost of air pollution control. To the extent that foreign producers
share the conditions that have resulted in such an increase in the
baseline cost of cigarette filter tow from a new facility, the export
market for domestic tow producers will probably remain strong.
Interaction between domestic and international makers of cigarette
filter tow also depends on differing demand trends across markets. In
particular, market penetration of filtered cigarettes is lower abroad
than in the United States and will probably continue to increase outside
the United States. Increased consumption of filtered cigarettes will
result in increased demand for filtration tow. Thus the world market
for tow will probably continue to grow.
Since available data and resources did not permit detailed analysis
of the demand and supply relationship discussed above, estimates of the
net effect of potential positive or negative influences on the compet-
itiveness of domestic tow producers in the international market could
not be made. EPA therefore selected the neutral assumption that domestic
manufacturers would maintain their market share.
EPA's position that price increases for cigarette filter tow will
have little effect on the export market derives in part from an assumption
that the price elasticity of export demand is similar to the price
elasticity of domestic demand. The estimate of the price elasticity of
domestic demand for cigarette filter tow was derived from the price
elasticity for cigarettes themselves. Cigarette demand is generally
found to be highly price inelastic (see Source 90, BID). The demand
for cigarette filter tow is estimated to be even more inelastic because
it is only a small part of a cigarette cost. Accordingly, an increase
in cigarette filter tow price is not expected to have a major impact on
secular growth in acetate filter tow consumption.
The EPA analysis does not ignore the possibility of substitution
in cigarette filter production, but it does judge such substitution to
be of limited potential. It is believed that cigarette manufacturers
experiment with alternate materials principally for longrun purposes,
especially for incorporation in new brands. Since filter design affects
2-30
-------
the taste and therefore the desirability of a cigarette, manufacturers
are extremely hesitant to substitute filter materials in existing
brands (p. 9-91 of BID).
It is recognized that the U.S. position in the world filter tow
market is not what it once was. However, the bulk of the decline in
U.S. market share occurred some years ago. Throughout the 1970's the
United States was responsible for 54 percent of world filter tow produc-
tion. According to the most recently available data, the U.S. share
appears to have been sufficiently stable over the last decade to
justify an assumption of continued maintenance of its world market
share.
2.5.9 Comment (IV-D-3, IV-D-4, IV-D-6):
One commenter (IV-D-6) said that EPA's capital cost estimate of
$70 million for a baseline acrylic/modacrylic plant was too low.
Commenters IV-D-3 and IV-D-4 said that the cost estimate for the
cigarette filter tow plant was too low. All the commenters concluded
that the underestimated capital costs resulted in implicit price
estimates for the fibers that were too low. They suggested that higher
capital cost estimates would result in correspondingly higher implicit
fiber prices that would remove any incentive to build new plants.
Response:
EPA does not believe that larger new plant capital costs would
dramatically change the results of the implicit price analysis. This
is because so much of the product cost is related to the cost of
operating inputs, and not to capital equipment (pp. 9-72 and 9-85 of
the BID). In order to test this contention, EPA ran the implicit price
model with the capital cost values suggested by the commenters. It was
found that the implicit price of acrylics increased only four to nine
cents over the baseline price of $2.45/kg; the implicit price of cigarette
filter tow increased fourteen cents over the baseline analysis price of
$3.47.
2.5.10 Comment (IV-D-3):
While granting that it may be possible to design adequate safety
controls and monitors for enclosure systems at filter tow facilities,
one commenter stated that the Agency has failed to adequately account
for the incremental cost of such safety equipment systems. He referenced
2-31
-------
the December 8, 1981, memorandum titled, "Discussion of Potential Safety
(Explosion) Problem Associated with the Use of Enclosures (Synthetic
Fibers NSPS, ESED Project 80/15), (docket item II-B-86) and noted in
his comment that equipment costs associated with the prevention of
excessive risks were, "substantially greater than the total direct cost
of $3.2 million estimated by EPA for the Alternative II control system
stated in the BID, Page 8-10." He quoted the memorandum to read, "the
equipment costs associated with the prevention of excessive risk are
...5 percent of the total capital cost for a new spinning process."
Response:
The equipment cost referred to in the December 8, 1981, memorandum
was estimated to "amount to less than 5 percent of the total capital
costs for a new spinning process." The wording was incorrect. It
should have read "amount to less than 5 percent of the total control
equipment capital costs above the baseline level for a new spinning
process", not the total cost of a baseline plant. The commenter, in
applying the 5 percent to the total capital cost for a new spinning
process EPA baseline plant, arrived at a safety equipment cost of $3.4
million (.05 x $67.1 = 3.4).
Based on this, the commenter concluded that the $3.4 million
safety equipment cost represented a "substantially greater" cost than
the total direct cost of $3.2 million estimated by the EPA for the
Alternative III entire control system, as stated in the BID, Page 8-10.
The incremental capital costs above the baseline level for an acetate
filter tow manufacturing plant (EPA model plant 4) are estimated to be
$3.0 million, which represents 4.5 percent of the total capital cost
associated with a baseline plant (Table 8-3 of BID). Consequently,
the safety equipment costs are $0.15 million (0.05 x 3.0 = 0.15) and
not $3.4 million, as was previously interpreted from the cited memorandum.
2.5.11 Comment (IV-D-3);
One commenter noted that the capital investment required to achieve
emission reductions at polymer solutioning and cutting/baling areas in
acrylic or modacrylic fiber plants would be $8.8 million. He noted
that EPA had failed to include emission reduction requirements for
these areas.
2-32
-------
Response:
As shown in the response to comment number 2.4.6, the standards are
not based on control of emissions from these areas because they are
relatively small compared to total solvent emissions, and more difficult
or expensive to capture relative to other emission points in the same
plants. Because these emissions were not considered to be controllable,
no capital or other costs were associated with these emission points.
2.5.12 Comment (IV-D-3):
One commenter indicated that Agency-generated operating costs
associated with the regulatory alternatives are underestimated. This
was supported, in the commenter's opinion, by the Agency not including
the following two factors in its cost estimates:
(1) the additional cost of the water required to strip the solvent
from the scrubber system and to maintain the solvent level in
the fiber at or within product or process specifications, and
(2) the cost of the additional horsepower required to operate the
large scrubber system.
Response:
Although not specifically delineated, the incremental costs for
the items mentioned were included in the Regulatory Alternative II and
III costs of increased control in Tables 8-4 through 8-8 in the BID.
Docket items II-B-32, II-I-3, II-B-41, II-D-66, II-D-68, and II-D-22
provide complete information on the development of control costs for the
factors noted by .the commenter.
2.5.13 Comment (IV-D-6):
One commenter claimed that the operating conditions for scrubber #2
at a dry-spun acrylic fiber plant were incorrect. This scrubber is
used to control and recover solvent emissions from the steaming/drying
portion of the process, and requires 2,000 kg/h of demineralized water
to achieve 98 percent scrubber efficiency, according to Table 6-6 in
the BID. However, the commenter claims that engineering calculations
performed for a similar scrubber indicate 3.5 times as much water would
be required to achieve 98 percent efficiency.
Response:
The amount of water estimated for the scrubber was based on
information from several manufacturing plants relevant to gas flow,
scrubbing liquid flow, scrubbing efficiency, and other parameters. As
2-33
-------
well, manufacturers of scrubbing equipment were contacted for their
assistance in determining correct parameters, and appropriate informa-
tion was given to a firm that generates computer-aided scrubber parameters
to obtain its estimate. All the above were considered in determining
the model plant parameters the commenter questions. Assuming the
commenter is correct, however, the increase in water usage would have a
minimal effect on costs for utilities (an increase of about $2,900, or
less than 1 percent of the $319,200 utilities cost in Table 8-5).
2.5.14 Comment (IV-D-6):
One commenter emphasized that a large portion of the current
acrylic fiber production was and is being exported (29 percent in 1979,
25 percent in 1980, 28 percent in 1981). He claims that should the
domestic demand increase to the point where total demand approaches
total capacity, the industry would not consider new capacity, but
instead simply reduce the export percentage to accommodate the domestic
demand. This is asserted because, he claims, the domestic market is
"more attractive." Thus, the commenter concludes, there is no need for
new capacity, even though total production may soon approach existing
capacity.
Response:
EPA performed an analysis using historic data on domestic and
export acrylic shipments to determine whether the export market was a
residual market as the commenter contended. This analysis is described
in docket item II-B-84. It shows that the data suggested that domestic
shipments and export shipments tend to move in the same direction,
increasing and decreasing together. In addition, there is no correlation
between the changes in the annual observations of the variables contained
in the two time series. These facts suggest that the export market is
not simply a residual market for the acrylic producers, that will be
curtailed when domestic consumption of acrylics increases.
2.6 GENERAL
2.6.1 Comment(IV-D-6):
This commenter noted that Table 1-1 in the proposal BID expressed
the expected Alternative II and III emission reductions as being a
"moderate" impact, while an earlier draft of the BID (July 1981)
2-34
-------
expresses a larger reduction but characterized this as being a "small"
impact. "There is an obvious inconsistency here in the assessment
process," this commenter claims.
Response:
The first draft (July 1981) was in error; an 8,500 Mg per year
emission reduction is not a small impact.
2.6.2 Comment (IV-D-6):
One commenter pointed out what he felt to be an inconsistency
between the Regulatory Alternative II 1987 projected emission reduction
shown on page 6-12 and 7-2 (31 percent to 44 percent) and the Alternative
II emission reduction (31 percent to 47 percent) stated on page 52936,
3rd column, last paragraph of the Federal Register notice. These
reductions are expressed for dry-spun acrylic and cellulose acetate
filter tow production facilities, respectively.
Response:
The 31 percent to 44 percent range noted refers specifically to
reductions achieved at the two type plants projected to be constructed
by 1987, acrylic/modacrylic and cellulose acetate filter tow. Emission
reductions for Alternative II shown in table 6-2 are for ^1_I_ the model
plants developed, and not only for the projected facilities. The
correct emission reduction range associated with all the model plants
developed for Alternative II is 31 percent to 55 percent. This percentage
reduction range as shown on Table 6-2 is consistent with table 6-3,
"Summary of Control Options and Regulatory Alternatives."
The emission reduction range noted by the commenter on page 52936
of the Federal Register notice should reflect the emission reductions
achievable through the use of enclosures when applied to certain process
stages of the model plant types that can utilize enclosures (that is,
all but Model Plant 5, for acetate filament.) The correct range at
these plants as derived from Table 6-2, Table 7-1, or as noted the
table on page 52938 of the Federal Register proposal notice is
31-44 percent. Thus, the range shown on page 52936, 31-47 percent, is
indeed in error.
2.6.3 Comment (IV-D-6):
In reference to Chapter 8.0, Cost Analysis, one commenter claimed
that the annual cost figures for two acrylic/modacrylic fiber plants
(baseline, Alternative II, and Alternative III) presented in Table 8-14,
2-35
-------
Projected 1987 Cost Effectiveness of Regulatory Alternatives," page 8-21,
do not correspond to the Model Plant estimates in Table 8-11, "Regulatory
Alternative II Cost Effectiveness Compared to Baseline Costs," page 8-17,
and Table 8-12, "Regulatory Alternative III Cost Effectiveness Compared
to Baseline Costs," page 8-18.
Response:
The appropriate projected 1987 Model Plant annual cost figures for the
baseline, Alternative II, and Alternative III estimates found in Table
8-14, were not derived directly from Table 8-11 and Table 8-12.
For each selected model plant, the value for "Total Annual Expenses"
from Tables 9-34 and 9-36, less polymer costs and adjusted for
81 percent capacity utilization, was multiplied by the projected number
of new affected facilities for the years 1982 through 1987, to reflect
the associated growth scenario.
Thus, the values in Table 8-14 reflect expected 1987 utilization
rates and resultant costs; the values in Tables 8-11 and 8-12 reflect
the model plants and their associated costs, all of which were based on
95 percent capacity utilization. (See Response 2.4.5.)
Because of rounding of solvent recovery credits, cost-effectiveness
estimates for Alternative II and Alternative III and the totals associated
with the high growth scenario have been slightly affected. These minor
modifications are reflected in the revised Table 8-14 and associated
text. (See Appendix C.)
2.6.4 Comment (IV-D-6):
One commenter noted that the summary paragraph on capital and
annual costs (47 FR 52939) was not found in the BID, and that it was
difficult to trace the development of the various figures.
Response:
Several reported values on Tables 8-14 involve compounded rounding.
Direct comparison of this table in the BID to the specific values in
the Federal Register notice is not possible. The values in each are,
however, correct and comparable when rounding is accounted for. Appendix
C includes for convenience a revised Table 8-14 and the accompanying
text. Because of the difficulty this commenter had in tracing some of
the figures in the Federal Register notice, the derivations and corrected
values are provided below:
2-36
-------
Capital costs of installed control equipment for Regulatory
Alternatives II and III are $18.0 and $27.8 million respectively. From
Table 8-3, these values are derived by adding twice the Model Plant 2
capital costs and four times the Model Plant 4 capital costs, for each
alternative.
The capital costs of implementing Alternative II at individual
projected plants is shown on BID Table 8-3 as $3.0 million; for Alterna-
tive III the costs range from $4.2 to $5.5 million.
"Annualized costs" for operating control equipment at all projected
plants should instead read "annual operating costs," and are derived
from BID Table 8-3 by adding twice the annual operating costs for Model
Plant 2 and four times the annual operating costs for model plant 4.
The corrected values thus determined are $3.8 million for Alternative
II and $5.4 million for Alternative III.
The values for "additional solvent recovered" read for Alternatives
II and III respectively, $3.8 million and 6.2 million (in the FR notice);
the correct values should be $3.89 million and $6.20 million. These
values are also found on the revised BID Table 8-14, in Appendix C. In
the Federal Register notice, the "Net Annualized Costs" of $1.2 million
to the industry for either alternative, and individual plant costs
of as much as $0.2 million are found on the revised and original
Table 8-14.
The phrase "Net Annualized Costs" as used in the table and the
Federal Register notice means "increase in net annualized costs above
baseline."
2.6.5 Comment (IV-D-3, IV-D-4):
Two commenters agreed with EPA's decision to exempt modified
facilities from the NSPS.
Response:
No response necessary.
2.6.6 Comment (IV-D-2):
The commenter supports EPA's decision to delay development of an
NSPS for viscose rayon.
Response:
No response necessary.
2-37
-------
2.6.7 Comment(IV-D-3):
One commenter requested that information provided during development
of the NSPS by three fiber producers be incorporated into the docket.
This information from Celanese Corporation, E.I. duPont de Nemours and
Company, and Eastman Kodak Company, is dated 7/3/80, 9/22/81, 11/30/81,
12/2/81, 12/3/81, 12/23/81, and 4/23/82, according to the commenter.
Response:
These comments were included in the rulemaking docket prior to
proposal of the NSPS and were carefully considered by EPA in developing
the proposed NSPS. The issues they raise are fully discussed in the
BID, the preamble to the proposed standards, and the comment summaries
and responses in this document. (See docket entries II-D-52, II-B-89,
II-D-70, II-D-71, II-E-93, II-D-76, and II-D-97.)
2.6.8 Comment (IV-D-6):
One commenter noted an apparent inconsistency in values given for
recovered solvent (BID Tables 8-4, 8-5, 8-6, 8-7, 8-8) and the supposed
origin of these values in the model plant parameters given in Chapter 6.
He notes that if the emission rates and indicated reductions as shown
for the model plants are multiplied by the expected production rates,
then the resulting emission figures do not agree with the recovered
solvent figures on the Chapter 8 tables.
Response:
The commenter has erroneously compared rounded values with values
calculated from more precise basic data. Tables 8-4 through 8-8 show
recovered solvent amounts, and these precise values are used for
computing the economic value of the solvent, as reported in Chapter 8.
The derivation of these amounts; is shown in docket Item II-B-90. In
other places in Chapter 8, however, these values were rounded for
simplicity from thousands of kilograms to gigagrams,, then the rounded
values used in subsequent calculations (see Tables 8-11, 8-12, 8-13,
and 8-14). The latter (rounded) values were used for descriptive purposes,
not exact evaluations. Where economic impacts were considered, however,
the more precise values were used (Tables 8-4 through 8-8).
Also, it should be noted that the emission values given for the
various model plants in Chapter 6 have themselves been rounded to whole
numbers. Any minor variation in these values, when multiplied by large
2-38
-------
production amounts, would result in apparent real differences.
Emission reductions thus computed may not be as precise as the emission
reductions shown on Tables 8-4 through 8-8 and on docket item II-B-90.
Thus, it can be seen that the variations are not errors of fact
but rather the result of compounded rounding errors. No changes to the
figures are considered necessary.
2.6.9 Comment (IV-B-5, IV-B-6):
A number of editorial comments were made by two commenters, and
these are summarized in docket item IV-B-2.
Response:
None of the editorial comments or changes affect the standards,
and no further response is necessary.
2-39
-------
2-40
-------
APPENDIX A
CALCULATION OF ENCLOSURE CAPTURE EFFICIENCY
Although not required by the standards, EPA has assumed in developing
model plants for the industry that enclosures would achieve at least
90 percent capture efficiency. This efficiency was in part based on
solvent mass balance data collected at plants where enclosures are now
in use. In addition, both concentration and flow values at the enclosures
were measured at one of the plants. These measurements and the information
obtained from several fiber producers are the basis for EPA's calculation
of enclosure capture efficiency, as described below.
EPA's test data indicate that while all enclosure doors are closed,
the continuous exhaust creates negative pressure within the enclosure;
consequently, vapor leakage from the enclosures does not occur. In
fact, there is significant inflow of room air into the enclosures
through all available openings, cracks, sheet metal joints, etc. Thus,
while operating normally and with doors closed, the enclosure would
exhibit complete capture and exhaust of any VOC released within the
enclosure. For this reason, 100 percent capture during periods of
normal operation was assumed for the time periods when the doors are
closed.
During a portion of production time, one door is open, and capture
efficiency is then dependent on face velocity into the enclosure through
the opening, whether negative pressure still exists within the enclosure,
and the degree of turbulence at the edges of the door opening. Testing
performed on enclosures revealed that when one or two doors are opened,
there is significant flow of room air into the enclosure. This flow is
great enough to prevent diffusion of vapor into the room, (docket
items II-A-15 and II-B-99) The only VOC losses at the door would be
very low amounts due to turbulence. Room air concentration measurements
made 4-5 feet from an opened door did not show any increase beyond
background levels, although the VOC concentration within the enclosure
was significantly greater than background levels. As well, measured
exhaust flows from the entire spin cell enclosure were greater than the
A-l
-------
air flow into the enclosure via one or two open doors. Therefore, the
remainder still comes in via the aforementioned cracks, leaks, and
other openings. Since negative pressure is maintained even with one or
two doors open, then it is seen that capture is still essentially
complete. For the purposes of calculating overall efficiency, 99
percent will be assumed.
About half the time enclosures would need to be open, access to
the entire line is necessary to repair "roll breaks" (tow line breaks).
Because of this, all doors would be opened initially, then closed one
by one as fiber from each spin cell is rethreaded and adjusted, (docket
item II-B-76) [During this period, all doors would not necessarily be
left open for the entire repair operation. All the doors would be
opened initially, then closed one by one as repairs are made, until
only one door remains open as the last spin cell is tended. It is then
seen that the average area of opening (number of doors open) is half
the entire possible area (all doors open), during the time access of
any kind is required. This concept will not directly be used in
computations, but is made to further support later developed values.]
Following the opening of all the enclosure doors, the concentration
within the enclosures, initially at about 5,200 ppm or 20 percent LEL
as reported by industry personnel (II-C-125 and II-E-86), would quickly
be reduced due to diffusion and dillution, and approach room air VOC
concentrations. The equilibrium concentration reached within the
enclosure will be at least as great as the room air concentration.
OSHA limits the room air concentration of acetone to 1000 ppm, and
industry personnel report typical room air concentrations at about
800 ppm.
While the doors are opened and spinning repairs made, the enclosure
exhausts will continue to operate. A finite amount of solvent VOC is
captured as long as the exhausts continue to operate, regardless of
the position of any of the enclosure doors. The exhausted VOC concentration
will of course be lower than under normal operation, but will be at
least as great as the room air concentration, shown above as about
800 ppm. The important point is that the enclosure exhibits some
degree of capture, even with all doors opened. The amount of capture
A-2
-------
can be expressed as the ratio of vapor concentration with the doors
closed to the vapor concentration with the doors opened. This ratio
provides an indication of the efficiency of the entire enclosure.
Concentration of captured vapor with doors opened x 100
Concentration of captured vapor with doors closed
PPm x 100 = 15%
5200 ppm
Capture efficiency was also based on information provided by the
industry concerning the amount of time a hypothetical enclosure would
be opened for required worker access: "...worker access to the
individual spin cells is required approximately 14 percent of total
production time." He noted that... during the time when worker access
is necessary the enclosures would be less effective in capturing VOC
emissions. During approximately half of the time access is required,
it would be necessary to open at least one of the enclosure doors. The
remaining time would require all of the enclosure doors to be open.
[He] further estimated that approximately two-thirds of the time
worker access is required, the spinning operation continues. The
remaining one-third of the time requires a process shutdown.
One industry representative (IV-D-3) has indicated that during as
much as 19 percent of total production time, access to the spinning
machines is required. (This is significant, since one or more doors
to a hypothetical enclosure would be opened during this period, and
enclosure capture efficiency would conceivably be reduced.) Combining
this information with the information in the preceeding paragraph, it
is estimated that all doors would be opened (at least initially) during
9.5 percent (about one-half) of the total required access time, and one
or two doors would be opened during the other 9.5 percent of the time.
In addition, of the time access is required (19 percent), spinning
continues for about 12.7 percent (two-thirds) of the time, and the
process is shut down for the remaining 6.5 percent (one third).
Information is not now available to reveal how these simultaneous
events overlap (that is, for example, whether the process shutdown
occur with one door open or with all doors open, on average). For the
A-3
-------
purpose of computing capture efficiency, the two extreme cases will be
considered; actual capture efficiency would fall between the two
extremes.
A. The first situation would yield the highest capture efficiency:
19%
9.5% One door open
9.5% All doors open
12.7% Spinning continues
6.3% Process
shutdown
81%
/^Doors closed
74Spinning
YAcontinues
81% of the time doors are closed and spinning continues ....100% capture
9.5% of the time one door is open and spinning continues.... 99% capture
3.2% of the time all doors are open and spinning continues.. 15% capture
6.3% of the time process is shut down
These values could be used at this point to calculate overall
capture efficiency, except for a further consideration. Since the
process is shut down for a portion of the total time, it is not appropriate
to consider capture or lack of capture during this period. Thus, the
period of shutdown should be eliminated from consideration, or factored
out in some appropriate manner. The spinning process continues for
about 93.7 percent of total time (100 - 6.3); this should be considered
as the available time, during which capture efficiency may be considered:
93.7 percent of total time = 100 percent available time
100% = LQ67
This is the factor by which all other reported vaues should be
multiplied to provide corrected values.
Thus, correcting for process shutdown:
1.067 x 81.0 percent x = 86.4 percent available time
1.067 x 9.5 percent x = 10.1 percent available time
1.067 x 3.2 percent x = 3.4 percent available time
A-4
-------
These values are then multiplied by the appropriate capture efficiency
to determine overall capture:
86.4 percent available time x 100 percent capture = 8640
10.1 percent available time x 99 percent capture = 1010
3.4 percent available time x 15 percent capture = 51_
9701
9701 4 100 = 97%
overall capture efficiency
B. The second case and most conservative value is determined as follows
19% 81%
9.5% One door open
6.3% Process
shutdown
9.5% All doors open
12.7% Spinning continues
J7/Doors closed
£< Spinning
//continues
81% of the time doors are closed and spinning continues 100% capture
9.5% of the time all doors are open and spinning
conti nues 15% capture
3.2% of the time one door is open and spinning
conti nues 99% capture
6.3% of the time the process is shutdown
Determine the factor for the period of process shutdown:
93.7 percent of total time = 100 percent of available time
100% = 1.067
93.7
Again, correcting for process shutdown:
1.067 x 81.0 percent total time = 86.4% available time
1.067 x 9.5 percent total time = 10.1% available time
1.067 x 3.2 percent total time = 3.4% available time
The corrected values are again multiplied by the appropriate
capture efficiency to determine overall efficiency:
A-5
-------
86.4 percent available time x 100 percent capture = 8640
10.1 percent available time x 15 percent capture = 151
3.4 percent available time x 99 percent capture = 337
9T28
9128 * 100 = 91.3%
This value represents the worst case, most conservative conditions.
For the purposes of model plant parameters and calcuations relative to
solvent recovery, this value is rounded down, again conservatively, to
90 %.
A-6
-------
APPENDIX B
SAFETY CONCERNS WITH THE USE OF ENCLOSURES
In developing control options for the standards, EPA has envisioned
enclosures that would capture solvent vapor evolved from the spun
fiber, and vapor pumped or pulled along with the fiber as it leaves the
spin cell. In the absence of enclosures, this vapor would be diluted
with room air and exhausted to the atmosphere. By limiting dilution
air and controlling the vapor concentration, the enclosures would actually
permit the solvent vapor within the enclosure to be concentrated sufficiently
to make the solvent economically recoverable using carbon adsorption or
scrubbing, but not so concentrated as to present a hazardous condition.
The amount of solvent released into an enclosure is dependent on
two sets of parameters: those related to the fiber and its spinning
step, and those related to the design and operation of the enclosure.
Fiber-related parameters include extrusion rate, fiber denier (size)
and shape, type of solvent, the size of the opening at the base of the
spin cell through which the extruded fiber exits, and the pressure
maintained within the spin cell. The enclosure-related parameters are
air temperature and the relative pressures in the spin cell and the
enclosure.
To insure high quality, a fiber manufacturer would attempt to keep
all of these parameters constant for a given product; under steady-
state conditions the amount of solvent released into an enclosure would
be constant. For this reason, it should be possible to design the
exhaust rate of the enclosure such that the solvent vapor concentration
can be maintained at any desired level. One company has claimed that
the exhaust flow rate for a new 50 million pound per year facility
would be about 12,000 cfm, and the concentration would be about 5200 ppm
or 20 percent of the LEL for acetone. (II-D-71, II-D-81, II-E-86).
The obvious conclusion is that during normal operation, explosive
conditions would not exist nor could the solvent vapor in the enclosure
support a flame.
B-l
-------
The discussion reduces to the safety of the enclosure only during
upset conditions (for example, when an enclosure exhaust fan fails).
Based on information provided by the industry, the following conditions
occuring simultaneously could possibly create unsafe situations:
(1) the enclosure's primary anc backup exhaust systems fail, (2) the
evolution of solvent vapors into the enclosure continues, and (3) the
enclosure doors remain closed at least until the lower explosive limit
is reached. EPA believes preventive measures can be included in the
design of the exhausts, enclosures, spinning equipment, and safety
mechanisms such that explosive conditions would be avoided. Obviously,
there could be many variations of this system, but as a minimum the
following are significant design considerations:
• The primary exhaust system would be connected to a warning
(horn, light, etc.) system.
• A backup exhaust system would also be connected to the
primary system for automatic emergency activation.
• The primary and/or backup exhaust systems would be interlocked
such that failure of one or both would cause the spinning
machine to shut down, and the enclosures doors to open.
• The enclosure doors would be spring-loaded or otherwise set
to be opened, and pneumatically or mechanically
held shut under normal operation.
o Employees that constantly tend the machines would recognize a
malfunction (fan failure) and could open the enclosure doors
manually if the automatic system failed. Estimates show
they would have a minimum of 2 1/2 minutes before flammable
conditions developed, (see page B-5)
t Once the doors are opened, any vapor present would quickly
diffuse into the room., preventing any further buildup
toward the LEL, i.e., the concentration in the area of the
enclosure would quickly approach that of the spinning room.
Regardless of the exact design, the general approach is feasible,
and in fact, representatives of two domestic companies have noted that
their firms either operate such systems or have agreed that such designs
are feasible. In summary, the design of the enclosure, exhaust fans,
B-2
-------
spinning pumps, and safety interlocks would prevent the vapor concen-
tration within the enclosures from reaching an explosive or flammable
level.
Nevertheless, some industry officials have questioned the use of
enclosures, and have claimed that the enclosures would provide "ready
ignition sources", an "unlimited oxygen supply", and would "negate
current fire protection measures."
With respect to "ready ignition sources," (see docket items IV-D-3
and IV-D-4) no further information was provided by the commenters to
identify these sources. No changes are being considered that would
affect the number or type of ignition sources already existing. The
enclosures do not increase the risk associated with additional ignition
sources. In fact, since the enclosure vapor is not flammable, if there
is a source of ignition, then the flame could not be transmitted to
other spin cells through the enclosure.
The existing ignition sources are: (1) the fiber itself, (2) cabinet
fires, and (3) static electricity. Although these sources do currently
exist, the presence of enclosures would not affect the level of risk
from these ignition sources, based on the discussion of fail safe
mechanisms. Note that with doors closed, worker access is prevented,
and possible ignition sources such as nonapproved tools are separated
from the vapor.
The commenter's claim of unlimited oxygen supply may be a reference
to the continuous flow of air into the enclosures that is generated by
the exhaust fans. There appears to be a concern that in the event of a
fire within an enclosure,* air would be continuously provided and would
thus promote a still larger fire. Although the exhaust fans continuously
draw room air into the enclosures, it is difficult to recognize how
this situation would somehow provide an unlimited oxygen supply. The
only entrances for air are via the small opening for spun fiber at the
base of the spin cabinet, the cracks between doors and other places, or
through designed vents. Because these are restrictive openings, they
would not provide an "unlimited" supply of oxygen, but as discussed
earlier, the continuous flow of air (oxygen) prevents the vapor concen-
tration from approaching explosive or flammable levels. If the exhaust
*Such a fire is assumed to be possible only for the sake of discussion.
B-3
-------
were to fail, the failsafe mechanisms would, by opening the enclosure
doors, preclude the development of explosive conditions and duplicate
currently existing conditions.
Determination of Minimum Time to Achieve LEL
To insure that the worst-case conditions are examined, however, a
situation in which the above design features nevertheless fail will be
considered. The most important factor then becomes how long it will
take for an explosive concentration to develop within the enclosure,
and the length of time it will take for a nearby operator to recognize
the condition and manually open the enclosure door;;.
To determine the explosion risk under abnormal conditions, EPA
has collected relevant information from a number of plants, and has
calculated the minimum time to reach the LEL, given the data received
from the industry. Because the information describes both real and
hypothetical cases, two separate calculations were made.
A. Determination of Time to LEL Based on Pilot System
To determine minimum time to reach the LEL, it is necessary to
determine: (1) the mass of vapor released during a given period
(2) the size of the particular enclosure (3) the LEL concentration
(4) the density of the solvent vapor (5) initial concentration within
the enclosure:
1) An industry representative reported in earlier communications
that the dope extrusion rate at a pilot enclosure was 5.2 Ibs/min
(2.36 Kg/min). He also reported that 5 percent of the weight of the
extruded dope would evaporate as solvent between the spin cell exit
and the crimper (the area enclosed). Thus, 0.05 x 2.36 Ibs/ min =
0.118 kg/min = evolution rate of solvent.
2) It was also reported in the same communication that the
enclosure volume was 200 ft3. (5.66 m3).
3) The LEL for acetone, used at this facility, is about 2.6 percent
by volume (minor variations would result from temperature,
changes and levels of 03 and other gasses.) This also may be
expressed as 26,000 ppm.
8-4
-------
4) The density of the solvent (acetone) vapor at 80 °F is
about 0.067 kg/ft3. (2.37 kg/m3).
5) The steady-state concentration is 20 percent LEL = 5200 ppm
Using the above, minimum time to LEL can be determined for the
enclosure, assuming the exhaust fan stops suddenly and completely and
that all enclosure doors remain closed.
Calculate weight of acetone within the enclosure initially:
5.66m3 x 5200 ppm x 2.37 kg/m3 = Q.Q70 kg
Calculate weight of acetone within the enclosure at the LEL:
5.66m3 x 26,000 ppm x 2.37 kg/m3 = 0.349 kg
The difference is the additional acetone required to achieve LEL:
0.349 kg - 0.070 kg = 0.279 kg
We know the rate of evolution is 0.118 kg/min, therefore it will
take 0.279 •* 0.118 = 2.4 minutes to achieve the lower explosive limit
within this enclosure.
B. Determination of Time to LEL Based on Hypothetical Facility
One company has provided information on enclosures at a hypothetical
50 million pound/year plant (22.7 gigagrams). This company has suggested
that although their pilot enclosure has operated at about 8-10 percent LEL,
the optimum concentration would be about 20 percent LEL. As well,
such enclosures would exhaust enclosure air and solvent vapor at about
12,000 cfm (339.8m3).
1) These two parameters determine the mass of solvent that
would be released into the enclosure, since mass x flow
rate = concentration. The vapor at 20 percent LEL (5200 ppm)
exhausted from the enclosure would contain the following mass:
exhaust rate x concentration x density (80°F) = mass exhausted
339.m3 x 5,2000 parts acetone x 2.37 kg = 4.19 kg
min 1000,000 parts air iiiT rnTn
2) It is also necessary to determine the volume of a hypothetical
enclosure as a preliminary step to determining time required
to achieve LEL. Information provided earlier by one company
noted that a pilot system that could extrude 2.36 kg of
dope/minute was enclosed, and the volume of this enclosure
was about 5.66m3. A plant that produces 50 million
B-5
-------
pounds per year would extrude 200 million pounds (90.7 gigagrams)
of dope, assuming a typical 3:1 solvent-polymer ratio. We can
further assume about 95 percent utilization of such a plant,
or 8400 hours/year operation. The extrusion rates can then be
expressed as follows:
90.7 gigagrams/yr = 10,780 Kg/hr = 180 Kg/min
We can assume that the pilot enclosure volume and extrusion rate
would be scaled up to the 22.7 gigagram million pound/year plant thusly:
extrusion rate at large plant = enclosure volume at large plant
extrusion rate at pilot plant enclosure volume at pilot plant
180 kg/min _ x m3
2.36 kg/rnin~ 5.66 m3
x = 432 m3 = total enclosure volume for a
22.7 gigagram/year plant
3) Now the time to achieve the lower explosive limit can be
determined for the full size plant, given a sudden and
complete loss of exhaust and also given that all enclosure
doors remain closed.
The initial concentration within was already set at 20 percent of
the LEL; the resulting mass is then determined:
5200 ppm x 424.5m3 = 2.36m3 pure acetone vapor
At the lower explosive limit of 26,000 ppm, the enclosure would contain:
26,000 ppm x 424.5m3 = H.lm3 pure acetone vapor
Thus, the difference is the additional vapor required to reach
the LEL:
Il.lm3 - 2.2m3 = 8.9m3
The density of acetone at 80°F is:
2.37kg/m3
Therefore, the weight of additional acetone would be:
2.37kg/m3 x 8.9m3 = 21.1 kg
We have already determined that the evolution rate of acetone
into this enclosure is 4.18 kg/min. Therefore, the time to reach LEL =
21.1 kg •* 4.18 kg/min = 5.1 minutes, or about 5 min. 6 sec.
B-6
-------
Summary
The times calculated above, 2.4 minutes and 5.1 minutes, both
show that there is adequate response time for nearby operating personnel
to open the enclosure doors, shut down the spinning machine, or otherwise
respond to the malfunctions.
One domestic manufacturer of acetate filter tow has begun a pilot
system to study the use of enclosures. They claim that because the
system is fairly new, conclusions should not be made with regard to
long-term use or benefits. However, they do report that thus far no
explosive situations have developed during the operation of this
system.
One Japanese manufacturer of acetate filter tow that uses enclosures
as envisioned by EPA was questioned concerning the safety of their
enclosures. Their response is self-explanatory:
"Electric power of the exhaust fan comes from the same power line
of spinning machines. If power were to fail, extrusion of acetate
dope in the spinning machines would stop at the same time when
the exhaust fan is down. Therefore there would not be the development
of explosive conditions in the enclosures with no further generation
of acetone vapor.
If only an exhaust fan were to fail, alarm bell and light in the
control room tell an emergency in the exhaust fan and a room
attendant inform promptly operators in the spinning area of the
exhaust fan emergency. Then operators rush to open all the
enclosure doors. To make doors wide open, there will be no
development of explosive condition.
There have never been any operational and safety problems such as
fires or explosions resulting from a build up of the solvent vapor
within the enclosures since we ran for more than two years with the
use of enclosures." [Now almost four years; this correspondence
was received in April 1982.]
B-7
-------
APPENDIX C
REVISED TEXT AND TABLE FROM
BID CHAPTER EIGHT
The following pages are revised versions of pages 8-19
through 8-21 of the October 1982 Draft Background
Information Document for Synthetic Fiber Production
Facilities.
C-l
-------
(BID page 8-19)
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 gaii 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
9-33 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.)
C-2
-------
(BID page 8-20)
«
(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
high 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 as much as 5.5 and 8.5 Gg/year,
respectively, by 1987. Annualized costs per megagram of emission
reduction for typical plants would be as much as $412 and $200 respectively,
for Alternatives II and III.
Because the Alternative III increased costs of control over Alternative
II are ofsett by increased solvent recovery, Thus, there is net cost
per megagram of emission reduction to the industry in implementing
Alternative III over Alternative II. Table 8-14 presents the projected
1987 cost effectiveness of the regulatory alternatives.
C-3
-------
(SID page G-21)
Table 8-14. PROJECTED 1987 COST EFFECTIVENESS
OF REGULATORY ALTERNATIVES
Cel lulose- ^estate
Acryl ic/Moaacryl ic filter ~ow 'otals
Srowtn
Scenario
1982- L987
Numoer of
Affected .
Facilities3
1987
Alternative II
Solvent Recovery
Credit3
(10S5)
Alternative III
Solvent Recovery
Credit8
(10°$)
3asel ine
Annual Cost
(105S/yr)
Alternative II
Net Annual Cost
(105S/yr)
Alternative III
Net Annual Costc
(10SS/vr
Alternative II
Increase in Net
Annual Cost Over
Baseline
(106$/yr)
Alternative III
Increase in Net
Annual Cost Over
Sasellne
(I05S/vr)
Alternative II
Emission
Reduction (Mg)
Alternative III
Emission .
Reduction (Mg)
Alternative II
Cost
Effectiveness
(S/Mg)
Alternative III
Cost
Effectiveness
(S/Mg)
nl9" low high low ngn low
2042 52
I-06 0.0 2.33 1.41 3.39 1.41
2-18 0-2 1.02 2.01 5.20 2.01
108.0 0.0 12.0 64.0 236.0 64.0
1°8'* 0.0 128.3 54.4 237.2 64.4
I08-* 0.0 128. 3 54.4 237.2 S4.4
0.4 ' 0.0 0.3 0.4 1.2 0.4
0.4 0.0 0.3 0.4 1.2 0.4
972 — 4560 2280 5532 2280
2000 — 5480 3240 3480 3240
412 — 175 175 217 175
200 — 123 123 142 ;23
All values projected assume 31 percent cauacity utilization for acryl ic/moaacryl ic
facilities and 95 percent for acetate filiar tow facilities.
'Amount of solvent recovered multiplied by solvent cost, S1.39AQ 3MF ana
>0.a2/kg acetone.
These values inciuae solvent recovery creaits, but do not include polymer
See also Tables 9-34 and 9-37.
Emission reduction is from Tables 3-4 cnrougn 3-3, Line 10 "Recovered Solvent "
C-4
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1 REPORT NO. 2.
EPA- 450/3-82-011 b
4. TITLE AND SUBTITLE
Synthetic Fiber Production Facilities-
Background Information for Promulgated Standards
7 AUTHOH(S)
9. PERFORMING ORGANIZATION NAME ANO AOOH6SS
Office of Air Quality Planning and Standards
Environmental Protection Agency
Research Triangle Park, North Carolina 27711
12. SPONSORING AGENCY NAME ANO ADDRESS
DAA for Air Quality Planning and Standards
Office of Air, ;Joise, and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, Nortii Carolina 27711
3. RECIPIENT'S ACCESSION»NO.
5. REPORT DATE
March 1984
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-3060
13. TYPE OF REPORT ANO PERIOD COVERED
14. SPONSORING AGENCY CODE
EPA/ 200/04
15. SUPPLEMENTARY NOTES
Standards of performance to control emissions of volatile organic
compounds (VOC) from new and reconstructed synthetic fiber production facilities
are being promulgated under the authority of Section 111 of the Clean Air Act.
This document contains a detailed summary of the public comments on the proposed
standards (47 FR 52932), responses to these comments, and a summary of changes to
the proposed standards.
7.
------- |