Control of Volatile Organic Compounds Emissions from Manufacturing

epresent excellent agreement for such "study" estimates.
Because these cost factors vary so widely, it is more meaningful
to compare the purchased or installed capital costs than the
annual ized.
The differences between the Polymers and Resins and Air
Oxidation CTG design parameters are re1 atively small and
impact the purchase costs only about 20 percent. (See
Appendix B of Air Oxidation CTG and Appendix E of this CTG.)
Moreover, the Enviroscience report "Control Device Evaluation
for Thermal Oxidizers" (December 1979) states that a VOC
control efficiency of 98 percent or greater is achievable
with a 1,500°F combustion temperature, the basis for the
GARD costs. Thus, it is likely, a1 though less certain than
for 1600°F, that the GARD incinerator can also meet the
98 percent emission reduction alternative listed in the CTG.
summarize: The GARD and Enviroscience thermal incinerator
costs can both meet the costing requirements of the CTG. The differences
between the two sets of costs fall within the accuracy 1 imits of the
CTG estimates. Further, the GARD data are as current and as well-founded
as the Enviroscience costs. Because of this, it makes little technical
difference which costs are used in the document. In deference to CMA,
thermal incinerator costs in this version of the CTG are based on
Envi roscience.
C.4.2. Cost Effectiveness Calculations
TCC noted that existing control levels for eight HDPE slurry and
solution process plants varied from - 696 percent (already meeting
RACT) to +92 percent of the uncontrolled emission rate for the model
plants. TCC, therefore, questioned the validity of the cost effectiveness
analyses, especially if the 98 percent reduction were based on uncontrolled
model plant levels. Similarly, Monsanto was concerned that the cost
effectiveness of RACT for polystyrene would be unreasonably high for
plants that were already well controlled.
Response:
TCC1s concern about the cost effectiveness of existing plants
with varying degrees of control is unwarranted. The 98 percent reduction