Control of Volatile Organic Compounds Emissions from Manufacturing

would be applied to uncontrolled emission levels for a particular
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plant. The cost effectiveness is assessed in gerieral by using the
uncontrolled and expected existing control levels as the lower and
upper bounds of the analysis. However, the streams a1 ready control 1 id
by an existing flare or thermal incinerator are no longer required to
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be control 1 ed further. Therefore, a1 ready well (:Ionturol 1 ed pl ants
would be rewarded, even though the calculated cost effectiveness from
the revised cost analysis bashd on Enviroscience is leis than $550/~91
for a thermal incinerator and less than $160 for a flare if the same
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unit were used to reduce from 90 percent (selected arbitrarily to
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approximate the upper end of the range of existing control levels for
which additional control might be required) to 98 percent reduction.
Monsanto's concern regarding the high cost-effectiveness of
control for a1 ready we1 1 -controll ed polystyrene manufacturing f acil i ti es
was evidently based on the misunderstanding that incineration would be
required regard1 ess of exis ti ng control 1eve1 s. On the contrary, RACT
for polystyrene is defined as an emission limit that can be met by any
I combination - - of exi stina- and additional ~rocesses and control s. ow ever ,
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thermal incinerators were used as a worst case c!ost'an~lysis even
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after - -- the - acceotance - - of the 0.3 ka/rIq ". - emission 1 imi'k that was based on
the use of a condenser. If a plant a1 ready has low emissions, cost
effectiveness would not incr6ase unreasonably because less control or I
no control would be required to meet the emission 1 imi t.
C.4.3. Mi scell aneous
Gulf pointed out several suggestions about details in the cost
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analysis: the escalation index needs updating; (2) operating labor '
lincludina overhead) should be $19.10 rather than $11.10; (3) the
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Interest rate of 10 percent should be updated to 18-20 percent,
(4) inclusion of a filter system upstream of the incinerator to remove
polymers and entrained liquids, (5) inclusion of operating labor,
maintenance 1 abor , and el ectrici ty costs for th~~*reciprocating compressor
and maintenance labor costs for manifolding, (6) completion of justification
of the 90 percent efficiency used for existing flares in assessing I
reasonabl mess of retrofit, and (7) consideration of total sys tern
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cost, not only incinerator cost, for incremental cost effectiveness:
C-10
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