Control of Volatile Organic Compounds Emissions from Manufacturing

has acknowledged after discussion with vendors. A1 so, Petro-tex
increased the efficiency of control 1 ing emissions from its 0x0 Butadiene
process from 70 percent to over 98 percent through relatively low cost
(in comparison to total capital cost) modifications that improved
mixing. Although the air oxidation process emission test data are of
value in assessing incineration capabilities in general, it is true I
that they do involve other chemicals and processes, some of which,
however, would be expected to be more, not less, difficult to control .)
Since the May 1982 draft was published, final results became available
for EPA emissions testinq at a polypropylene facility. The results of
this studv ~rosram showed VOC destruction efficiencies of mixtures of
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gaseous, 1 iquid, and sol id wastes greater than 99 .71'p$rcent' for '
temperatures of 1,600°F and greater and 1.5 seconds residence time.
Therefore, 98 percent should be readily attainable for 0.75 seconds
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residence time since kinetic studies show that residence time is
beyond 0.5 to 0.75 sec is not a determining factor of reduction efficiency
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(see p. D36).
In order to ensure that RACT is readily achievable at a reasonable
cost, and to avoid giving a competitive disadvantage to a1 ready welli-
control led facil ities (another concern of the TCC) , existing incinerators
and flares will be considered to achieve RACT without the need for
modification or replacement. Also, in order to prevent a potential
safety hazard (from cornbusting high-oxygen content streams) and a -
potentially unreasonable cost effectiveness, RACT for product finishing
and product storage operations was changed from 98 percent to 0.35 kg
VOC/Mg product from the extruder on in the manufacturing process
(e .g ., pel1 etizing and product storage).
Regarding CMA's comment that RACT is not consistent with the
other VOC regulations under development: RACT is not more stringenk
than the NSPS for PP liquid phase and HDPE liquid phase slurry. The
only difference with the SOCrlI Distil 1 ation NSPS, besides the SOCMI
Distil 1 ation NSPS's anticipation of the joint CMA/EPA flare testing
results is the use of a total resource effectiveness (TRE) index. the
SOCHI Air Oxidation CTG also employs a TRE index and exempted'streams
a1 read-Y control 1 ed by a thermal incinerator. The Polymers and Resins
CTG allows States to decide whether to require testing and subsequdnt