7-10 Air
Please provide rationale for basing the uncontrolled formaldehyde emission factor on the MACT Standard’s limit for controlled formaldehyde emissions.
7-10 For sources using an oxidation catalyst, the EPA MACT Standard for formaldehyde of 91 ppbvd @ 15% O2 is the limit for controlled emissions. Since the proposed facility intends to use an oxidation catalyst as a control device, please provide rationale for basing the uncontrolled formaldehyde emission factor on the MACT Standard’s limit for controlled formaldehyde emissions.
RESPONSE 7-10
| The combustion turbine formaldehyde emission factor was provided by the equipment manufacturer.
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RESPONDENT:
| Michael Feinblatt, ESS Group, Inc.
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DATE: | May 17, 2016
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