Document Z49epb1ZNkZ679LYvbD9R6X5V
. Hi*
DEC-07-1992 10=00 FROM CMA
TO 914124342137 P.01
CHEMICAL MANUFACTURERS ASSOCIATION
CHEMSTAR FAX
To: Ethylene Dichloride>Panel Members
Jim Barter Thomas Grumbles William Hayes W.C. Holbrook Phillip Ostrowski Thomas Robinson
PPG Industries Vista Chemical Dow Chemical BFGoodricb
Occidental Vulcan Chemicals
412-434-2137
713-588-3456 517-636-9899 216-447-6459 716-278-7297 205-877-3102
Date:
December 7, 1992
it of pages (including cover)-------------- ------ 2
If there are any problems with this transmission, please call
202-887-1146.
:
Re: Generic CMA Request for Information
Attached is a list of data needs which generic CMA would like to include in its comments bn the HON. If you have any questions or can provide any information, please call Richard Sigman at 202-887-1313 or Gary 0TDea at 202-837-13^3.
SL 063860
2501 M Sir&et, NW, Was^'ngror DC 20007 202'S8~-n0C
** 202-387-1237 Telex 83617 iCMA WSH;
DEC-07-1992 10=00 FROM CMA
TO 914124342137 P.02 'lb
November 20,1992
Subgroup General
Monitoring and Recordkeeping
Monitoring and Recordkeeping
Monitoring and Recordkeeping Applicability
Multi-Media Impacts
Multi Media Impacts Emissions Averaging
Phase-In
CMA HON DATA NEEDS
Data Need
Status/Response
Information from companies that use control technologies other than those specified in the HON which should be included as reference technologies.
Estimate of person-hours needed to comply with the recordkeeping and reporting provisions
Comments or suggestions on the types of monitoring systems discussed in the HON (e.g., charts, data averaging, and data compression) and whether other types of systems exist
Verification that plant condensers on tanks can achieve a 95% control efficiency
Comments on applicability provisions as they relate to plant operations
Examples ("honor stories") from companies that have tried to get permits for combustion devices but had difficulty due to the production of NOx emissions.
Survey of the size of incinerators and NOx emissions planned for HON compliance.
Plant input on which emissions averaging option they prefer. (1) the quarterly "allowable" limit that is based on an emissions cap or (2) EPAs option that requires that debits not exceed credits by more than 25-35% in any one quarter.
Plant input on whether they think that construction permits will be required to install HON controls. If so. tow many permits will be needed, and how long is it currently taking to get permits.
SL 063861
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