Control of Volatile Organic Compounds Emissions from Manufacturing

The use of data from the CTG for air oxidation processes is not
adequate as a basis for KACT in this guideline document, and 98
percent conrrol efficiency is not achievable on ;a continuous .and
average basis.
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2. Discussion rhroughout the document infers' only incineraE
and boilers can achieve RACT.
There was only one reference to the use of process heaters and
one reference to the use of refrigerated condensers as possible methods
ro achieve RACT. In the reference to condensers, the efficiency was
quesrioned. There was no reference to the processing of vent streams
by orher units operated at the site or by neighboring units, nor was
inert reference rc cornbinations of control techniques such as the use
of ref rigerzic~ coxensers f oliouec by flare co:rrousrion. The
re:-,erh;:on cI' xerxs. Iriclcerarix. st.ggesis e speciiir coniroi ner?oc
cnc :ne autiioriiy to s?eciiy controi methods is quesrionable.
3. Tne documentation of flare efficiencv is not complete,
disregards or simolifies efficiency d,ata, and makes
irzccurax x~fe!r~es:s ;n ilare dssigr! anc oserarions.
Page 4-1 srares flare efficiency ". . . canno ntifiea in
absence of adequare test data . . .", yet four flare studies were
reviewed with one study containing 1298 test measurements. A portion
oi this data was disregarded because the flared vern gas was from a
petroleum industry. A petroleum industry vent gas i!; more variable in
composition which mats design more difficult and i!; mare susceptible
io efficiency problems than a plastics industry f
Tim description of a polymer plant flare states, "The
flares are mainly used to handle emergency blowdowns which requires
the control device to handle large volumes of gases with variable
co~qosirionr." This is true for iign ?yessure processes. but ?or f x
pressure, liquia pnase high-density polyethylene ma polypropylene
mznufacture. On page 3-12 good com~usrion ae!;ign for flares is
queszioned aue to lac^ of llcompletely well-aefirred" measurement
methods. Agericy or society approved methods give reliability to
measuremenr methods, but the lack of these methods should not detract
ircm tne evzluauor, of combustion design or tne merir of the flare
eiiicienc!. car&. The $rase on page 5-18 in reference ss flares srating,
". . . variarions in flow and hqar content of tne waste stream coulc
ext~nguishme ilarne . . ." is completely false as flares are aesigneti
with csnrinuous 2ilor ilames. .4 conrinuous pilot flame is essentia! to
ensure safe conaitions.
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. Cost calt:!anonc for ther ma1 incineraror .?sra!f arior: heed
On page 5-5 the escalation ind
labor cost of $1 1.1 Gihr (including overhead) is incorrect and should be
$19. :G/hr (including overhead and benefits), and the interest rate of 10
percent should be tlpazred to the 18-21) percent range. The COST
andiiyses drc C C ~inciuae the cost of & filter sys~en: uostream of tne
B-32
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