Control of Volatile Organic Compounds Emissions from Manufacturing

Mv NAME IS RICHARD A. SYMULESKI , I AM THE ENVIRONMENTAL CONSERVATI
COORD~NATOR FOR THE ~ O C CHEM; O CALS CORPORATI OIN SUBS1 D.1 ARY OF
OIL OF INDIANA. I AM SPEAKING TO YOU TODAY ON BEHALF OF WE C~WICAL
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~NVFACTURERS ASSOCIATION' s PROCESS EMI SSI ONS REGULATI
1 ONS TASK CROUP AND I
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PRODUCTION CAPACITY OF BASIC INDUSTRIAL CHEMICALS WITHIN THIS GOUNTRYt
WE ARE PLEASED TO HAVE THE OPPORTUNITY TC PRESENT OUR VIEWS AND
CONCERNS TO TMI s CO~IYTEE ON THE PRELIMINARY DRAFT CONTROL TECHNIQUES
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GUIDELINE FOR THE CONTROL OF VOLATILE DRGANIC COMPOUNDS FROM THE
PANUFACTURE OF HIGH DENS IN POLYETHYLENE, POLYPROPYLENE AtiD POLYSTYRENE
RESINS, CiW MEMBER COMPANIES HAVE A CONTINUING INTEREST IN ENSURIN
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THAT EPA DEVELOPS, WHEN HEEDS WARRANTJ CONTROL TECHNIQUES GUIDELINES
(CTG'S) THAT ARE TECHN1CAIJ.Y SOUND, REASONABLEJ ADMI N I STRATI VELY FEAS IBLE
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DEVELOPMENT. OF THIS flG. TO DATE OUR EFFORT H,hS BEEN LIMITED qY
EPP. TO TRACKING THEIR REGULATORY DEVELOPRENT EFFORTS. AS A RESULT)
INITIALLY IDENTIFIED SIX MAJOR PROBLEM AREAS IN THE PRELIMINARY
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INCLUDE:
THAT COULD BE IMPACTED BY THE CTG,
LIMITATIONS
IN THE DESCRIPTIOK OF THE INDUSTRY) ITS ~
EM1 SS I ONS FACTORS. AND IN THE DEF I NEII MODEL PUNTS t
~ C OF K ADMINISTRATIVE FLEXIBILITY 7'0 THE STATES IN
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IMPLEMENTATI ON OF REASONAELY AVA I WILE CONTROL
TE~HNOLOGY (RACT) ,
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