Westlake Chemical Corporation
Longview Operations
P.O. Box 8388
Longview, TX 75607
February 16, 2016
Joyce Spencer
Texas Commission on Environmental Quality – MC 205
Office of Legal Services
General Law Division
P.O. Box 13087
Austin, Texas 78711-3087
Re:
Rule Project Number 2006-034-117-EN
Proposed Rule on Chapter 117 Reformat, NOx Controls for DFW 8-Hour Ozone
Attainment Demonstration, and Revisions to the Residential Water Heater Rules
Dear Ms. Spencer:
Westlake Longview Corporation ("Westlake"), a wholly owned subsidiary of Westlake Chemical
Corporation, appreciates the opportunity to comment on the Texas Commission on Environmental
Quality’s (TCEQs) proposed rulemaking on the Chapter 117 Reformat, NOx Controls for DFW 8Hour Ozone Attainment Demonstration, and Revisions to the Residential Water Heater Rules.
The proposal prepared by the TCEQ provides requirements for the Northeast Texas attainment
area, to be implemented prior to March 1, 2009, to help the DFW area attain the eight-hour ozone
standard. These comments are structured to give the TCEQ feedback as to the feasibility of
accomplishing the proposed emission reductions for Westlake's Longview, Texas site.
For reasons detailed below, Westlake requests that the TCEQ remove two-cycle, lean-burn engines
from the East Texas Combustion Rule for the DFW SIP (Subchapter E, Division 4).
 Westlake believes that imposing controls on attainment areas outside of the immediate
DFW region is not technically justified.
 Current control technologies available for application to Westlake's existing two-cycle,
lean-burn type engines, are unproven. Furthermore, even if such technologies were to be
implemented, technology suppliers cannot guarantee that the emission limits for NOx,
proposed by the TCEQ, can be consistently met.
 The costs to install control technologies or proceed with engine replacement far exceed the
costs projected by the TCEQ. In addition, their potential impact on air quality in the DFW
non-attainment area is not large enough to justify such expenditure in an attainment area.
 The compliance deadline of March 1, 2009 is unattainable because of the large number of
compressor engines in this area. It would be technically infeasible for the limited number
of engine manufacturers to physically install add-on controls or supply replacement
engines within this limited timeframe.
Westlake Chemical Response: Rule Project Number 2006-034-117-EN
Page 2 of 5
Westlake offers the following comments on the proposed Chapter 117, Subchapter E,
Division 4, East Texas Combustion:
1. Imposing regulations on emission sources outside of the DFW non-attainment boundaries
to achieve compliance should be a last resort, and is not justified.
The East Texas Combustion Rule requires owners and operators of new and existing reciprocating
internal combustion engines with a horsepower rating of 50 or greater to reduce emissions of NOx
to a specified rate depending on the age and type of engine. It is unreasonable to impose penalties
on counties outside of the DFW region, especially when they are not even neighboring counties to
the DFW region and are located downstream of prevailing winds. Therefore, they have minimal, if
any, direct impact on the DFW groundlevel ozone. The Texas Commission on Environmental
Quality, Chapter 117 – Control of Air Pollution from Nitrogen Compounds, Rule Project No. 2006034-117-EN, Preamble page 21 states:
"The majority of NOx in the nonattainment area comes from onroad and nonroad
mobile sources. Therefore, NOx reductions from sources outside of Dallas-Fort
Worth eight-hour ozone nonattainment area must be made so the Dallas-Fort
Worth eight-hour ozone nonattainment area can demonstrate attainment with the
NAAQS for ozone."
If mobile sources are the major source of ozone in the DFW region, then the first step would
logically be to reduce emissions from the mobile sources. All potential source reductions within
the DFW region should be fully explored before imposing controls on attainment areas outside of
the DFW region.
The sources owned and operated by Westlake are located over 100-miles from the DFW area and,
due to prevailing weather patterns, have little to no impact on the DFW ozone levels. By the
TCEQ's own analysis, reducing the NOx emissions from all the East Texas combustion units will
reduce groundlevel ozone in the DFW area by only 0.2 – 0.3 ppb.1 The 0.3 ppb ozone reduction is
less than 0.5% of the permitted groundlevel ozone standard and is well within the margin of error
of the modeling program. Therefore, any action taken by East Texas combustion unit owners
would be insignificant to the overall DFW NOx reduction effort.
2. TCEQ’s proposed control technologies are not technically feasible for Westlake's
Engines.
In the proposed rule TCEQ states that the control technology of NSCR with an EGR kit can be
installed to meet the new emission limits it proposes for lean-burn engines.2 This statement is not
technically correct. EGR, which stands for Exhaust Gas Recirculation, is an untested and unproven
technology for large bore, slow speed, natural gas fueled engines (which is what Westlake owns
and operates). Representatives from Cooper-Bessemer (original engine manufacturer), Wartsila,
and Dresser-Rand have all communicated to Westlake that EGR technology is technically
infeasible with Westlake's engines. EGR is only applicable for lean burn diesel engines, which
Westlake does not own or operate.
Texas Commission on Environmental Quality, Chapter 117 – Control of Air Pollution from Nitrogen
Compounds, Rule Project No. 2006-034-117-EN, Preamble p. 22.
2
Texas Commission on Environmental Quality, Chapter 117 – Control of Air Pollution from Nitrogen
Compounds, Rule Project No. 2006-034-117-EN, Preamble p. 160.
1
Westlake Chemical Response: Rule Project Number 2006-034-117-EN
Page 3 of 5
The TCEQ also states that SCR (Selective Catalytic Reduction) is another possible control
technology for lean burn engines.3 As stated earlier, Westlake met with Cooper-Bessemer (original
engine manufacturer), Wartsila, and Dresser-Rand and received quotes for installing SCR type
controls on the 17 engines at the Longview facility. Several concerns make this option impractical
for Westlake's large bore, slow speed engines including: space constraints, marginal exhaust
temperatures and short catalyst life on two-cycle engines. Additionally, none of the
aforementioned technology vendors will guarantee that the performance will meet TCEQ proposed
requirements. The original engine manufacturer (Cooper-Bessemer) has tried to implement SCR
technology on this type of lean-burn engine, but was unsuccessful due to the low exhaust gas
temperature. In a June 11, 2003 Northeast Texas Air Care (NETAC) report it states that "…retrofit
with SCR equipment is not recommended as the 2-cycle design results in much higher contaminant
concentrations in the exhaust, which leads to rapid destruction of the catalyst."
Since EGR with NSCR as well as SCR are not viable options for Westlake's engines, the only
alternatives are clean/lean burn units or replacement with electric motors. Clean/lean burn
technology is a form of Low Emission Combustion (LEC) modifications as mentioned in the Texas
Commission on Environmental Quality, Chapter 117 – Control of Air Pollution from Nitrogen
Compounds, Rule Project No. 2006-034-117-EN, Preamble, p. 160. However, LEC modifications
have never been attempted on GMX-type engines. Thirteen (13) of the seventeen (17) engines
owned and operated by Westlake are GMX-type engines. Therefore, any attempt to install
clean/lean burn technology on the GMX-type engines would be unprecedented. Clean/lean burn
and replacement with electric motors are much more expensive than the estimates provided by the
TCEQ (see next section below).
3. The costs of compliance with the East Texas Combustion Rule far exceeds the costs
estimated by the TCEQ and could result in adverse economic impact to the Longview
area.
The actual cost to implement the improvements to the combustion sources owned and operated by
Westlake is much higher than the estimates provided by the TCEQ. Westlake owns and operates
seventeen (17) natural gas fueled (large-bore, slow speed) reciprocating internal combustion
engines, which are of the two-cycle, lean-burn variety. Cooper-Bessemer, Dresser-Rand, Wartsila,
and Enginuity have all examined Westlake's engines and have quoted cost figures of approximately
$1MM per engine for clean/lean burn technology or replacement with electric motors. This results
in a total cost of $17MM for just 17 engines as compared to the TCEQ's estimate of $20.5MM to
$81.3MM for all 297 lean-burn engines in the Northeast Texas area.4 The estimated cost to
Westlake alone is nearly equivalent to the lower range of the TCEQ cost estimate for providing
controls on all 297 lean-burn engines in the entire Northeast Texas region.
There are fundamental design differences between two-cycle and four-cycle engines that make the
cost to achieve the same emission rate much more expensive for two-cycle engines than for fourcycle engines. These fundamental differences result in exorbitant costs that are an unfair burden to
Westlake and other engine owners/operators of two-cycle engines in the East Texas region.
Westlake believes that the majority of the emissions in this area result from operation of the four3
Ibidem, p. 160.
Texas Commission on Environmental Quality, Chapter 117 – Control of Air Pollution from Nitrogen
Compounds, Rule Project No. 2006-034-117-EN, Preamble p. 201.
4
Westlake Chemical Response: Rule Project Number 2006-034-117-EN
Page 4 of 5
cycle engines which can be far more economically converted. The only two feasible options for
the reduction of NOx emissions from two-cycle engines are expensive and approach costs on the
order of $10,000 per ton of NOx removed. This cost far exceeds the TCEQ's estimate of less than
$2,000 per ton of NOx removed.
Due to the high cost of retrofitting and/or replacing existing engines, it is very likely that some of
the eight reactor lines at the Polyethylene No. 1 facility operated by Westlake at the Longview
plant would be shut down if the East Texas Combustion Rule is implemented as proposed.
Shutting down a portion of the eight reactor lines would result in the loss of jobs, both directly and
indirectly. The Polyethylene No. 1 facility employs approximately 100 people directly. In
addition, the Polyethylene No.1 facility feeds product to two other operating areas on the Longview
site (Polyethylene Processing and Epolene). Polyethylene Processing and Epolene employ an
additional 75 people that would likely be impacted by any partial shutdown of the Polyethylene
No. 1 facility. Finally, dozens of other jobs would be impacted indirectly (service groups that
provide support to the Polyethylene and Epolene production areas). Since the commission's cost
numbers are underestimated, the resulting conclusion regarding local employment impact is also
underestimated. The Texas Commission on Environmental Quality, Chapter 117 – Control of Air
Pollution from Nitrogen Compounds, Rule Project No. 2006-034-117-EN, Preamble page 201
states:
"The commission has reviewed this proposed rulemaking and determined that a
local employment impact statement is not required because the proposed rules do
not adversely affect a local economy in a material way for the first five years that
the proposed rules are in effect."
As demonstrated by the above argument, this proposed rule could have very adverse affects on
Westlake Longview Corporation's production facility and the surrounding community.
In addition to the upfront capital cost, there is also a large cost associated with installation of the
new controls. Due to the complexity of the control equipment and the congested operating area, it
is estimated that each reactor line will need to be decommissioned for a period of 4 to 8 weeks to
install the engine control equipment. There are 8 reactor lines in the PE No. 1 unit. This amounts
to between 8 and16 months of total downtime, severely curtailing the annual production capacity
and adversely affecting the economic viability of the PE No.1 unit.
4. It is technically infeasible for industry to meet the March 1, 2009 compliance deadline
proposed in the TCEQ DFW SIP.
The TCEQ requested comments on the technical feasibility of installing controls and the
availability of control equipment by March 1, 2009.5 It is not technically feasible for the
companies in the Northeast Texas area to engineer, order, install modifications and/or replace the
number of engines the East Texas Combustion Rule would mandate by March 1, 2009. If this
proposed rule is adopted by the TCEQ in May, 2007 then this leaves just 20 months to plan,
engineer, purchase, install, and test replacement engines or control technologies to meet the new
emission rates. This is an unreasonable timeframe to accomplish this task, especially considering
that there are approximately 297 lean burn engines in the 39 county area that will require controls.
It is not reasonable to expect that the limited number of engine manufacturers and suppliers will
Texas Commission on Environmental Quality, Chapter 117 – Control of Air Pollution from Nitrogen
Compounds, Rule Project No. 2006-034-117-EN, Preamble p. 5.
5
Westlake Chemical Response: Rule Project Number 2006-034-117-EN
Page 5 of 5
have the ability to make the extensive modifications and/or replacements required to comply with
the timing of this proposed rule.
In addition, note that the new rule requires emission testing within 60 days after controls or
replacement engines are installed. Since there are a limited number of testing companies available
to perform these tests, it may be unreasonable to complete all the tests required in this region
within that timeframe.
Westlake appreciates the agency’s consideration of these comments. If there are any questions,
please don't hesitate to contact either of us.
Sincerely,
Timothy McMeen
Environmental Coordinator
Longview Operations
Westlake Chemical Corporation
Tel:
(903) 237-6093
Email: tmcmeen@westlakechemical.com
Raymond E. Laplante, Jr.
Manager, Longview Plant
Westlake Chemical Corporation
Tel.
(903) 237-5021
Email: rlaplante@westlakechemical.com