Control of Volatile Organic Compounds Emissions from Manufacturing

APPENDIX C. MAJOR ISSUES AND RESPONSES
The major issues raised in the comment letters on the May 1982
draft of the CTG document are summarized in this appendix, as well as
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EPA1s responses to the comments. (The comment 1 etters themselves are
included as Appendix B.) The major issues which are discussed (and
the corresponding section of this appendix) are: the inclusion of
flares as RACT ( 1 )
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the acceptability of* other control devices, such
as condensers, catalytic incinerators, absorbers, adsorbers, and
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process heaters (C. 2) ; the stringency of RACT and 98 reduction (C.3); the basis of the cost analy
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of the CTG regarding the inclusion of both polystyrel(e (C.5) and the
high density polyethylene 1 iquid phase solution procesr (C. 6). Minor
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corrections or updates regarding the chemical reactidn mechanisms of
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missions or the status of individual plants were rectified without
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Turzner comenr; oy trn.
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C.l THE INCLUSION OF FLARES AS RACT
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Summary of Comments:
Several commenters (the Texas Chemical Council - TCC, the chemical
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Manufacturer's Association - CMA, and Gulf Oil chhikalk Co. - Gulf)
were of the opinion that flares should be included i RACT as equivalhnt
control to thermal incinerators. TCC felt that flares should be
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included, especially in light of recent tests by Battelle and John
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Zink, Co. for EPA (Howes et.al., Chapter 4, Ref. 9). CMA noted the
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forthcoming - joint CNA/EPA flare efficiency study (using the methods
developed by Battelle and John Zink, Co.) and sug~gested that any
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language precluding the use of flares would be inappropriate especially
since they were a1 ready acceptable for the SOCMI Di sti 11 ation NSPS.
Gulf remarked that the quantified flare efficiency rksh ts ob four
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studies were disregarded. Gulf also disagreed wi~th several statements
regarding flares in the draft CTG: (1) that polymer plant flares are
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