Public Comment from Robert Vandenberg on FR Doc # E8-08005

This pertains to the control of volatile organic compound (VOC) emissions by establishing reasonable available control technology (RACT) requirements for marine vessel and barge loading. I would question why (RACT) is being considered and not (BACT) of (MACT). It seems that the (RACT) requirement would allow for <95% DRE. There is (BACT) Best available control technology in the industry that may not be cost effective, however is allows for >99% DRE. There is also (MACT) most achievable control technology that is cost effective and is > 99.9% DRE. Open flares = 95% DRE under $100,000 in cost Thermal Oxidizers = 99% DRE Over $ 200,000 in cost Ventura or fume oxidizers = 99.9% DRE at $100,000 in cost The Ventura or fume oxidizers should be considering as they can be tested unlike open flares and for a slightly higher capital and 99.9% DRE is achievable.