Control of Volatile Organic Compounds Emissions from Manufacturing

If not, we think they should not lw included in the
summary.
This &G (p. 5-17,18) lists four flare studies;
Du Pont, National Ai2 Oil Burner, Union Carbide,
and Seigel. Reference 4 also lisl=s four flare
studies; Du Pont, Union Carbide, Seigel, and Zink/
Battelle. Why were the Zink/Battr%Lle studies which
showed high destruction afficienc:ies and which were
rua for thC EPA left out of this study? And why was
the National Air Oil Burner repor.1: left out of
Reference 4?
The CTG1sdiscussion of flares states that "The uncertainity
associated with flare combustion contrasts
starkly with our knowledge of inciinerators and boilers.
Evidence to show the thoroughness of cornbustian effi-. -
ciency in these devices is ponderous." One can be
ignorant of anything if they refuse to study it and the
data presented in Appendix A is hardly ponderous. Six
plant scale test results are presemted and these show
destruction efficiencies ranging from -70.3 to 99.9%.
If the EPA applied the same critiaal criteria to incinerators
as they do to flaxes they would have to conchdh
incheratot efficiencies arc sig2ificantly lass .
thsa 98%. Based on information fmm in-house experts
.%.
we tfrink all combrrs.tion devices w iLl give high destrue- .
efELcienc3.e~if the polxutant dues not by-pass and
rtctuaIly: expetrhnces the fIame, Thus even new incinerators
can: &vet. poor ~esultsuch as the Ptztra-tex
data lif by-passing occus,
. I
The TCC? does not we
- -thinkit .is time the EPA judged data for flares by
tfig same criteria as they use fez boilers and incherators..
- We realfze flare efficiency is not readily
measure&'but the test of a control technique should
be its cost effectiveness and effj.ciency, not its
ease of gnforcement,
Fhz;slfy, as the: EPR is probably atraze, flare tests
by tfia Chemical Manufacturers Association should be
underway now at the John Zink pIartt, Results from
this study will.be available short:ly and should be
inchdad -b anz.fiaal appraisal of flare destruction
efficiency,