Control of Volatile Organic Compounds Emissions from Manufacturing

" DEFINITION OF INCINERATION AS MCT FOR THESE SOURCE
CATEeORIES AND EXCLUSIOW OF APPLICABLE AND APPROPRIATE .
ALTERNATE CONVROL TECHN1QUESo
-
FAILURE TO RECOGNIZE FLARES AS EQUIVALENT RACL
L~nr~rrro~s IN THE COST DATA USED TO* JUST!FY-RACT,
BECAUSE THESE PROBLEnS ARE EQUALLY APPLICABLE TO ALL THREE
POLYMERS INCLUDED IN THE Cr6, MY COMMENTS WILL PROVIDE A GENERAL OVERVIEW
OF THE NATURE OF THE PROBLEMS IDEMTI FIED, f0 ILLUSTRATE SPECIFIC POINTS
I WIU PRESENT EXAMPLES FOR INDIVIDUAL POLYMERS. HOW EVER^ THESE COMMENTS
SHOULD NOT BE CONSTSUED AS APPLYING ONLY TO ?HE SPECIFIC POLYMERS
MENTIONED SINCE TblEY 00 CROSS PRODUCT LINES.
I. Funem OF P w s Syayt~ To- CTk,
f H€ CT6 IDENTIFIES A TOTAL OF 17 PUNTS 1N OZONE NONATTAINMEWf
FROM 7WE 1982 COMPLIANCE DEADLINE. THESE PLANTS W I UJ THEREFoREJ BE
AN EXTENSION OF W E OZONE ARASNMENT DATE AND WE HAVE IDENTIFIED A
NO EXTENSIONS HAVE YET BEEN. FILED, '
IT
rS HIGHLY UNLIKELY THAT A U THESE
AREAS WILL ACHIEVE COMPLIANCE WITH THE OZONE STANDARD BY THE DEADLINE
TO THIS CTG,
IN ADDITION, THERE ARE SEVERAL ERRORS IN THE LIST OF PUNTS
IDENTIFIED BY AS BEING SUBJECT TO W E CTG. ~ O C O HAS PUBLICLY
ANNOUNCED mC;r IT WIU NOT REBUILD ITS NEW CASTLE POLYPROPYLENE PUN%