POI emission numbers in this…

ERO number

019-2771

Comment ID

53499

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Individual

Comment status

Comment approved More about comment statuses

Comment

POI emission numbers in this application are based on the future use of a thermal oxidizer that will cut some emissions dramatically, and others by 50% or more. However several findings from Entegris Air Quality Peer Review conducted by RWDI No 2103192 raise several concerns:
● Does not include sufficient detail to validate the expected emission rates and the mitigating effects of the thermal oxidizer.
● The method of calculating emissions from by-products of combustion from the thermal oxidizer were not provided.
● In addition to the main treatment process reactors, there are numerous references to other equipment and operations that are also ducted through the air treatment system, including material transfer operations, filtration, distillation, holding tanks, etc. No details were provided on how the contributions from these sources were considered in the emission calculations. This raises the possibility that emissions may be underestimated.
● Emissions from “Specific Future Processing” were simply listed as “Provided by Entegris” and could not be validated.
● Overall, the calculation of process emissions does not have sufficient information provided to allow RWDI to understand details on the process or the calculations involved, so Pinchin’s conclusions cannot be validated.
● There are many other findings in the RWDI report that require clarification or confirmation.