ENV-14-2 Reducing Compliance Risk for Dilute VOC Control Operation in Plastics Production

Description:

Air emissions from polyethylene (PE) production are receiving more scrutiny as fracking and the shale gas boom has generated cost effective feedstock for ethane cracking and ethylene production. With the advent of self-reporting under the Title V program, it is important to ensure that appropriate Federal Regulatory applicability is evaluated and assigned for emission sources. This distinction can be unclear, especially in the case of voluntary air pollution control devices. Process design may have included control for dilute VOC vent streams that are below regulatory thresholds for control. To reduce future deviation risk, an applicability exercise is used to systematically characterize the exemption criteria of potentially applicable requirements. A vapor oxidizer example for a generalized production line is used in this paper to demonstrate a two-part compliance strategy to alleviate unnecessary compliance burden.