Comment submitted by Paul Mikutis, Akzo Nobel Polymer Chemicals

We are a manufacture of organic peroxides. Even though none of the urban HAPs are used as raw materials or produced as a product within our processes, acetaldehyde could be formed within our wastewater system. Some of our organic peroxide products are temperature sensitive and undergo decomposition, and can form a small amount of acetaldehyde. Please clarify whether incidental decomposition constitutes " process, use, produce, or generate". Thank you