Control of Volatile Organic Compounds Emissions from Manufacturing

COMMENTS BY THE TEXAS CHEMICAL COUNCIL
ON THE MY, 1982 DRAFT CONTROL TECHNIQUE GUIDELINE (CTG)
FOR CONTROL OF VOLATILE ORGANIC COMPOUND (VOC) EMISSIONS
FROM THE MANUFACTURE OF HIGZ-DENSITY POLYETHYLENE,
POLYPROPYLENE, AND POLYSTYRENE
The Texas Chemical Council (TCC) is an association of
85 chemical companies having more than 67,000 employees in Texas
and representing approximately 40% of the chcrnical industry in
the State. Many of the polyethylene and polypropylene plants
covered by the CTG are in Texas and, thus, the proposed guide-
lines are of concern to us.
A. Review of Previous Comments
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This draft CTG is very similar to the April, 1981 version
reviewed at the June 2-3, 1981 National Air Pollutant
Control Technique Advisory Committee meeting and we are
disappointed that it does not more fully reflect the
TCC comments submitted to the EPA than (Ref. 1). Most
of our previous comments. are still pertinent an2 are
srmuaarized below as they relate to the present CTG.
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. 1. The CTG Does Not Fulfill It's Stated Purpose
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The TCC continues to believe that the omission of
- absoxption, and other poIlutant recovery techniques,
and the definition of Keasonably Available Control
.. Technology (RACT.) excIusively in terms of thermal
. 'incineration is not very useful in helping the states
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roceed with their own assessment of RACT - the
$ideli.nels stated gurpose. The rezscnigg used in
Secti~n3-1 to dismiss these other technologies
presents no data and is largely specious.
2, KA1m'Shouf d Allow Several Technolosies
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In,our May 29, 1981 comments we: set forth what we
thought were excellent reasons why RACT should allow
severax abatement technologies. We still think they
are valid and that a 98% reduct:ion requirement is
unduly stringent for RACE when compared to New Source
Perf onnance Standard (NSPS) requirements and the
levef of 'regulation on mobile and other sources.
Restating the RACT recommendation to a 98% reduction
in Section 4.1 of the present document from thermal
incineration (under conditions to give a 98% reduction)
in the ApriL, 1981 version does not really address
our concern.
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