Control of Volatile Organic Compounds Emissions from Manufacturing

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n G PROPO.SED INCINERATING GASES OF SIMILAR HEAT AND W)C CONTENT h
1~30~ F IN AN ~CINERATORWITH
A 0.75 TO 1.0 SECOND RESIDENCE TIME. IN
GENERAL, THE MORE CONSERVATIVE CRITERIA IN THE AIR OXIDATION f lG WILL
ASSWE ~P~ COMBUSTION OF ORGANICS AND WI IN A MORE
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EXPENSIVE'INCINERATORHAVING HIGHER SUPPLEMENTAL
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REOUIREMENTSI
PUT ANOTHER WAY3 IF ?HE SIZING AND OPERATING CRITERIA FOR THE INCINERATOR
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FOR AIR OXIDATION CHEMICALS ARE CORRECTj THEN THE DqS1 GN CR
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COST ESTIMATES FOR INCINERATION IN THE POLYMERS/RES INS CT6
PARISON OF TOTAL MHIALIZED CO& ~ T I ~ 1 T E ~
THE GARD REPORT WILL PREDICT INCINERATOR COSTS THAT ARE
25 PERCENT to 35 PERCENT LOWER THAN THE COSTS OF MBE PR
DATA BASE. WE BELIEVE THE HYDROSCI ENCE COST
REPRESENTATIVE CF INDUSTRY EXPERIENCE AND SHOUU BE USED
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FOR DETERMININO THE COST EFFE~IVEWESSOF THIS CTG.
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IN s YJ (MA HAS IDEWIFIED SEVERA~KEY DEFICIENCIESWITH
THE PRELIMINARY DRqFT m6 WHICH ABVERSELY AFFECT THE UTI
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CTG. TO THE STATESj AND INCORRECTLY ESTIMATE THE BENEFITS
ACCRUE FROS3 ITS IMPLEMENTATI ON, BELf EVES THAT A MOR
ASSESSMENT O f THE INDUSTRYj ITS EMISSIONS AND THE CONTRO
IN PUCE CAN BE USED TO DEWLOP A- CTG WHICH WILL DEFINE co
' RACT STRATEGIES THAT ARE WORKABLE FOR INDUSTRYj WHILE MEETING THE
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NEms OF WE STATES IN BRINGING NoNAnAINnENt A m s INTO cowLIA&,
IS GRATEFUL FOR HAVING HAD THE OPPORTUNITY TO ADDRESS THE
ITTEE TODAY. OUR WORK GROUP, WIU REMAIN AVAILABLE TO WORK WITH
RESINS INDUSTRY. THISCONCLUDES M? FORMAL ST I I WILL ATTEMPT
TO MSWER ANY QUESTIONS YOU MAY HAVE CONCERNING m PRESENTATION.
B-30
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