Comment on FR Doc # E6-06771

EPA-R03-OAR-2006-0280 COMMENTS A. The Frog, Switch & Manufacturing Company V-Process #1, #2, and #3: What is the basis for the VOC content limit of "10% by volume" in condition 5 of the plan approval? In section 3.2.2 of the company's RACT proposal, the use of water-based washes is shown as a technically feasible control option with an estimated VOC reduction potential of 100%. There appears to be no documentation on the basis for the "10% by volume" limit. No-bake Mold Wash and Core Wash: What are the results of the study required in condition 6 of the plan approval? The purpose of the study was to establish VOC content limits. In sections 3.2.3 and 3.2.4 of the company's RACT proposal, the use of water-based washes is shown as a technically feasible control option with an estimated VOC reduction potential of 100%. There appears to be no VOC content limit or emissions cap for RACT. Casting Painting: Shouldn't this process also be subject to the VOC limits for miscellaneous metal parts and products under 25 PA Code 129.52 (surface coating processes)? There is no discussion on this issue in the documentation and no related conditions in the plan approval. B. Merck & Co. Wastewater Treatment Plant: Shouldn't there be overall RACT requirements pertaining to the wastewater treatment plant regarding handling, treatment, and disposal of all process wastewater containing VOC? In order for condition 5 of plan approval OP-49- 0007B to be enforceable, shouldn't plan approval 49-313-0321 be included in the documentation and SIP submission? The cooling tower had accounted for about "47% of the total VOC emissions from the system" but there is no information on the fate of the cooling tower VOCs after replacement of the cooling tower with heat exchangers. There are no RACT requirements pertaining to measurement and testing for proper operation of the biological treatment process. C. Dart Container Corporation Operating permit 36-2015 does not address RACT for the cleaning solvents, which are estimated to be 30 tons per year of emissions. Also, the current control of VOC emissions from the pre-expanders should be included in the operating permit as part of the RACT requirements. The use of a concentrator in series with an oxidation control device for the dilute VOC gas streams from the cup production plants should be evaluated for technical and economic feasibility. A "proven success" for a similar plant is not a pre-condition for RACT evaluation.