Control of Volatile Organic Compounds Emissions from Manufacturing

Mr. J. R. Famet Page 2
EPA
June 16, 1982
As noted, there is a 20-30 fold difference between the EPA and
CXA numbers shown. FOP the model plant in the draft CTG of
73.5 Gg capacity, the CMA missions would run from approximately
9-11 Mg/Yr. compared with the 246 Mg/Yr. emissions shown in the
draft CTG. No references were contained in the draft CTG which
allows backtracking to the EPA basis for the quoted emissions
factors. Since actual experfence indicates that the CMA emission
factors are appropriate, the emissions expected from existing
continuous polystyrene facilities are insignificant and as such, there
is no significant .nonoccupzneisaaal exposure. Monsanto contends the
CTG is not necessary for this fndustry segment.
e Therrsaal. llacFrneratioa is not an Appropriate Control:'.Device ,
If EPA persists, and issues a CTG for VOC emissions from polystyrene
units, then Monsanto disagrees with the selection of thermal incinera-
tion as the emission control device to use (see draft CTG on page' 5-1,
where EPA states "'Tke-1 incinerators are the only control device
evaluated .'')
Incinerators are not cost-effective control devices for control of
the insignificant V6C levels which emit from existing continuous
polystyrene units. As EPA stated on page 5-14 of the draft CTG
"For each model plant, the resulting combined stream was smaller than
the capacity of the siaallast off-the-shelf incinerator available."
Using EPAss cost nmbers of approximately $70,000 for direct and
indirect costs (see the draft CTG page 5-15, Table 5-7),and applying
CreA mission levels, the cost-effectiveness would run.from about
$6400 to $7800/Mg. VOC removed (as compared to EPA's number of
$320/~g.VOC) .
The cost-effectiveness levels would be even higher than this if a detailed
cost estimate were done taking into consideration factors such as:
1. Due to the insignificance of the VOC stream size, and the size of
the incinerator, auxiliary fuel would be needed to sustain burning,
hence, added operating cost.
2. The technology of compressing the styrene monomer vapors and trans-
. porting them for up to 1,000 ft., would promote.polymerization in
the pipe and hence buildup which would need to be removed. periodically.
This would also add to the operating cost.
As such, incineration is not an appropriate control device to use
on the insignificant VOC emissions which emit from existing continuous
polystyrene units. In addition, Monsanto strongly objects to the use
of its acf ylonitrile incinerator data contained in Monsan to 's submission
to EPA on November 8, 1979 (see reference 5 on draft CTG page A-27)
as being an equivalent technology base for styrene. The AN data was