Control of Volatile Organic Compounds Emissions from Manufacturing

October 19, 1981
Attachment to June 16, 1982 letter
from C.D, Malloch, Monsanto to
J R Farm
SS~CIAYI~R*
RE: CXA Cc4H18menta on EPA Model Plant Zrnissions Factoxs for
Our Palymzzs/Resins Work Group kzs reviewed the draft docmerit
prepared as-paxt of the Agencyqr effort to develop an NS?S for Polyme,ts/Resins
Manufacture. The Croup has focused its attention primazily
on %%e aceuraey of the esdo~ie~s factors and their location
within in&ividualb precesses as based upen its ceLlectiva expexieace.
As you may haw, CHA fs a nonprofit trade asseciation mad9 up
of approxbate2.y 184 m anies i~ United States representing
mere ~~ 38 p estie production capacity
for basic iaduo4dal cfideels. ~~ member capanies have a direct
and czitieab interest fw enswing that E2A develops enission standards
when a dem~ns~ated need is preseoted, that are sde~tifisally
ar.6 techically sound, zeasenable, ~roee&uralPyworkcble , cost cffeceve,
and clsaxly autficsrized by the C f e a A5,z Ac*, . of our menber
companies produce Pohper a d llesia products a d may be hapacted
by any regulations which may be based on the subject docwewt,
while our cements provide what we believe are improvements to
Lye mogiel plant dssions factors, we do believe that the high degree
of vaziability betieen individual processes used to manufaskure
,",ie same ptoduct de?monstrates the I Mted usefulness of the model
plant concept, This point w ill be axc~olifiedin oux discussion ol
Lhe indivadual dssions fae-kors fos the specific products/processes.
I. Polypropylene - continuous slu,-hy, liquid phase process
A, mere art two Liquid phase precesses new in comercia%
we; the large particle slurry process and the solution
process, Most new Ifquid phase plants enploy ox will
empPey the solution process. A sizeable number: but nat
all of these n@w plants are using or will use LLae high
yield catalyst techolog. As a result, there are sme
sofution processes that stflL =equire catalyst de-ashiag