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Control of Volatile Organic Compounds Emissions from Manufacturing

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c.Jnissions factors- However, different process 'trains<br />

dedicated to widely differins polymers may have signifr-<br />

cant differences in their emissions factors.<br />

B. Recent process hprovements have included a shift to the<br />

use <strong>of</strong> vacuum pumps to generate process vacuums. These<br />

pumps consume less energy than steam eductors and also nave<br />

Lower emissions factors. Industry ' s experience with t.?.?e<br />

use <strong>of</strong> vacuum pumps arc substantially different than one<br />

would expect when reviewing &he model plant emissions fac-<br />

tors. Our experience indicates that the -following emissions<br />

factors are more typical <strong>of</strong> newer continuous polystyrene<br />

process technolow :<br />

Tankage 0.01 - 0.02 kg VOC/1000 k@ resin<br />

Styrene Recovery Unit 0.05 - 0.06 kg VOC/1000 kq resin<br />

Condenser Vent<br />

Extruder Quench Vent 0.009- 0.01 kg VOC/1000 kg resin<br />

We trust that these comxnents will be cor,hi.de&d as you revise the<br />

draft model plant emissions factors. We thank: you for givins us the<br />

cpportunity to review this materf a1 and are wi.llin5 tc meet w i ~ you !<br />

to discuss our concerns in gzeater detail. a.ch Symuleski, the Work<br />

Gxoup leader w ill contact you for follow-up in this regard.<br />

Sf ncerely,<br />

Janet So Matey<br />

Manager<br />

Air 3rosrams<br />

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