Control of Volatile Organic Compounds Emissions from Manufacturing

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CoHPlTIONS OF 10 TIMES NORMAL STEAL RATE.
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IN ALlL CASES THE HEASU
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EFFICIENCY WAS GREATER THIN 95 PERCENT.
BARE^ MEMORIAL LABORATORIES HAS co ED A STUDY FOR !PA TO
DEMONSTM MEASURING TECHNIQUES FOR USE AT TOWERSa THE S T ~ Y
WAS CONDUCTED OVER A THREE-~AYPERIOD USING A JOHN ZINCFACILITY FLA
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PROPANE. ALTHOUGH THE TEST HAS LONG BEEN COMPLETEDJ THE BATTELLE STUDY
HAS NOT BEEN WEAVAILABLE (EVEN IN DRAFT FORM) I FOR l l .PUBLIC REVIEW AND I
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CWENTI WE HAVE LEARNED, HOWEVERj THAT ( OT A SPECIF1 C
ABLE TO ACHIEVE A DESTRUCTION EFFICIENCY OF GREATER THAN 95 PERCEN'~
WEH - WITH A SMOKf NG FLARE* CM CONTENDS THAT THE CTG SHOUD NOT BE
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ISSUED fN FINAL FORM UNTIL VHE RESULTS OF THIS CAN BE
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EVALUATEDe
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IN ORDER FOR EPA TO BE CONSISTEM WITH THE.SPIRITJ IF NOT
EXPRESS LANGUAGE OF THE RECENTLY ISSUED EXECUINE O~DERtb. 1229lI
(FEBRUARYVJ19811, EPA IS UNDER AN AFFIRMATIVE DUTY ~b AUOW &SE
CONTROL OPTIONS THAT DATA DEMONSTRATE WILL ACHIEVE THE ENVIRONMENTAL
OBJECTIVES OF THE REGULATIONJ Bllf AT A LOWER COST TO INDUSTRY IN THIS
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REGARD^ THE AGENCY SHOUU NOT PRECLUDE SUCH TECHNICALLY S~XJNO AND COST-
EFFECTIVE CONTROL TECHNIQUESJ UNLESS THE AGENCY IESTABLISHES AN
ADMINISTRATIYE RECORD THAT CLEARLY DOCUMENTS THESE COST-EFFECTIVE
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CONTROL TECHNIQUES WILL OFFSET A SIGNIFICANT ENVIROF(MENTAL BENEFIT THAT
COOID OTHERWISE RESULT 8
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