Control of Volatile Organic Compounds Emissions from Manufacturing

are improving and expanding the data base. The remark on p. 5-18
stated that extinguishing the flame of a flare is "conceivableu - not
likely. Although it is true that flares with cont.inuous pilots will
relight momentarily, all existing flares do not necessarily have
continuous pilots or automatic re1 ighting system's 'such as have come
into genera1 use in recent years.
ABSORBERS,
"'- 1
---~EssHEATERS AS RACT
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Summary of Comments
Various commenters were of the opinion that control devices other
than thermal incinerators should be included as RACT. Monsanto, CMA,
Gu1f. and Pol vsar commented thit cond&nsers were mord adproiri ate RACY
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for polystyrene manufacture than thermal incinerators because no
hiahl v volatile materilal is ~rksent in ~ol yst.yr&nfi mdnufacturing so
that condensation is less expensive and already in use by the industry.
DuPont wanted to ensure that cktalytic incin not preempted
because DuPont feels the cost is competitive 1 incineration.
Gulf and TCC were concerned that the repeated mention of thermal
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incineration implied that only thermal incineration was accepted as
RACT and that the States would, therefore, not allow alternative
control methods such as conderkers, process heaters br combinations
(Gulf) , or absorption or other! recovery techniqu& ((~cc). (The incl u
of flares as an alternate control technique was also'suggested; this
issue was discussed separately in that last section.)
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Response:
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While the May 1982 draft focused on thermal incinerators it was
not intended to give the impression that other control techniques
except flares, which were then disallowed, would not be capable of,
and thus acceptable for, achieving 98 percent reduction. For exampl e
the May 1982 draft CTG (on p. 4-1) set an emission reduction of 98 weight
percent VOC for polypropylene and high-densi ty pol yethyl ene pl ants add
an emission limit of 0.3 kg VOC/Mg polystyrene produced and stated
that "other control techniques such as refrigerated condensation thai
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can achieve the same degree of control should be considered equivalent
and acceptable." The May 1982 draft a1 so stated specifically that "Combustion
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