Control of Volatile Organic Compounds Emissions from Manufacturing

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IN SUWRYj THE AGENCY, BY RELYING UPON AN INNACCURATE
WEPRESE)ICTATION OF WE INDUSTRYj HAS DEVELOPED QUESTIONABLE MODEL PLANT
COHFfGURATIONS FROM WHICH UNCONTROLLED EMISSIONS FACTORS WERE OBTAINED*
As A RESULr, THE WISSIONS FROM THE INDUSTRY HAVE BEEN OVERSTATa AND
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WE ACTUAL MISSIONS REDUCTIONS THAT W IU BE OBTAINED BY IMPLEMENTING
THE C76 wru.fiost LIKELY BE MUCH SMALLER,
111, LACK OF FLEXIBILITYFOR THE STATES IN IMPLEMENTING
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THE CLEAN AIR ACT REQUIRES'THATSTATE IMPLEMENTATION PLANS FOR.
NOHATTAIWENT AREAS MUST INCLUDE MCr REQUI REMENTS FOR STAT1 ONARY
SOURCES. EPA HAS PERMIRP) STATES TO DEFER THE 49DPIS.ION OF RACT
REGULATIONS UWTL AFTER ?HE AGENCY HAS DMfO
SOURCE CATEGORIES THE 06's ARE TO PROVIDE STA'TE AND LOCAL AIR
POLLUTION CONTROL AGENCIES WITH q~ INFORMATION
MBY DEVELOP SPECIFIC REQUIREMENTS, THE
MANDATES COMBUSTION OF THE MISSIONS AT THE 98 PERCENT LEVEL AND CR
THAT THERMAL INCINERATI.ON IS THE ONLY FEASIBLE AqPROACH TO EMISSIONS
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CONTROL. THIS APPROACH SEVERELY CONSTRAINSTHE !STATE's ABILITY TO
'SELECT THE MOST COST-EFFECTSVE CONTROL STRAtEGIE!$ FOR STATIONARY ,
SOURCES UNDER THEIR JURISDIVION,
IT15 m's POSIwr1ON THAT IF A c?G 3s HEEDED FOR A SPECIFIC
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SOURCE CATEGORY, IT SHOULD BE DEVELOPED COWSISTEMTWITH THE GOALS
AND REQUIREMENTS 6~ THE CLEAN AIR ACT, AS SUCHr THE CTG MUST BE ABLE
70 DESCRIBE FOR 'ME STATES THE APPROPRIATE
UNDER A VARIEN OF SPECIFIC CIRCUMSTANCES WITHOUT DICTATING TO THE
STATES HOW TO CONTROL SOURCES UNDER THE1R JURISD [ CTI OM. THE m6 SHOUU
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PROVIDE AN ACCURATE DESCRIPTION OF THE INDUSTRYJ ITS EMISSIONS AM
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