National Emission Standards for Hazardous Air Pollutants from the




НазваниеNational Emission Standards for Hazardous Air Pollutants from the
страница44/44
Дата11.10.2012
Размер1.55 Mb.
ТипДокументы
1   ...   36   37   38   39   40   41   42   43   44

Develop waste disposal requirements


Comment: One commenter (2816) stated that EPA’s sector-based approach should include consideration of solid waste impacts and should reinvigorate its efforts to develop stringent regulations governing the disposal of wastes generated by portland cement kilns

Response: Comments on regulatory measures for cement kiln dust waste are beyond the scope of this proceeding.

Comment: One commenter (2895) stated that site specific regulation of CKD should be in each facility’s Title V permit. The commenter asked how CKD will be disposed of without creating water and solid waste problems if it is not recycled into the kiln.

Response: Site specific permitting issues relating to waste management are beyond the scope of this proceeding.

Comment: One commenter (2844) stated that the technical, economical and environmental implications of landfilling or blending cement kiln dust rather than recycling it to the kiln are significantly negative and should be avoided.

Response: EPA took this issue into account in determining not adopt beyond the floor standards as part of its consideration of non-air quality impacts.

More stringent dioxin/furan standards


Comment: One commenter (2828) suggested that EPA set more stringent standards for dioxins and furans. The commenter stated that the cement industry represents a high and disproportionate cancer risk. The science of dioxin/furan monitoring has improved to the point that commercial dioxin/furan CEMS are available, and analytical laboratories can measure dioxin/furan at significantly lower levels thanks to technologies such as gas chromatography-mass spectrometry (GC-MS-MS). The commenter suggested that EPA should establish stringent dioxin/furan emission standards, based on a comprehensive study of dioxin/furan emissions from the current fleet of kilns, and recognizing that the RTO technologies already in place at some kilns, and likely to be installed at other kilns in the future are bound to be extremely effective (99%+) at destroying dioxin/furan. EPA should require dioxin/furan CEMS for monitoring (or at the very least quarterly monitoring) for any cement kiln not using an RTO to control emissions. EPA should consider the beyond-the-floor possibilities for dioxin/furan control that are now possible with the advent of SCR systems on cement kilns. If EPA continues recent practice of trying to integrate MACT and NSPS rulemaking for particular industries, then the establishment of SCR-driven NOx standards in the Portland Cement NSPS would integrate and support the establishment of SCR-driven dioxin/furan standards in the Portland Cement MACT rules.

Response: EPA did not reopen or reconsider the 1999 standard for CDD/CDF and so is not addressing this comment.

Comment: One commenter (2911) stated that EPA’s dioxin standards do not satisfy the requirement of §112 that standards must reflect the average emission level achieved by the best performing 12 percent of sources for which EPA has emissions information. The commenter provided additional arguments in support of this statement. The commenter petitioned EPA to revise its dioxin standards for cement kilns under the authorities described in Kennecott Utah Copper Corp. v. Department of Interior, 88 F.3d 1191 (D.C. Cir. 1996).

Response: EPA did not reopen or reconsider the 1999 standard for CDD/CDF and so is not addressing this comment here. EPA will consider the commenter’s petition request separately from this rulemaking.

Comment: One commenter (2144) stated that consideration should be given to more frequent measurement of dioxin and furan (D/F) from cement kilns or to the possibility of requiring D/F-CEMS. One D/F test per 30-month period followed by continuous temperature measurement and control is not sufficient to ensure year round compliance at some kilns. In the short run, increase the minimum frequency of dioxin/furan testing to once every 12 months and begin assessment of D/F-CEMS.

One commenter (2867) emphasized the need for more dioxin/furan testing to a minimum of once every 12 months and recommended that EPA begin assessment of dioxin/furan-CEMS.

Response: EPA did not reopen or reconsider the 1999 standard for CDD/CDF and so is not addressing this comment.

Regulatory approach allows flexibility in fuels


Comment: One commenter (2846) supported EPA in developing a regulatory approach that maximizes the usefulness of secondary materials. The commenter recommended using a straightforward qualitative principle-based approach to defining solid waste that recognizes the inherent advantages of useful energy recovery and materials handling practices under §112 regulation. Such an approach can be more universally applicable to not only existing materials, but also for new materials and processes not yet developed. Trying to be too prescriptive could inhibit new technology development and implementation and work against high level national goals.

Response: EPA acknowledges the commenter’s support. On the matter of defining solid waste, that involves issues beyond the scope of this rulemaking.

Solid waste as fuel


Comment: One commenter (2816) supported EPA’s inclusion of cement kilns that combust secondary materials in the proposed rule. One commenter (2895) stated that EPA should provide a conclusive definition of solid waste, and in particular, define the HAP emitted when these solid wastes are used as fuel.

Response: This issue is beyond the scope of this rulemaking. The definition of solid waste for purposes of section 129 is part of a different regulatory proceeding. See 75 FR 31844, June 4, 2010. EPA is also performing a concurrent rulemaking, the Commercial and Industrial Solid Waste Incinerator rulemaking under section 129 of the CAA that will regulate kilns that burn non-hazardous solid waste. At the time that rule becomes final, kilns burning solid waste (as defined in the to-be-completed rulemaking) will be regulated under to-be-adopted standards for commercial and industrial solid waste incinerators whenever they are burning solid waste.

Require natural gas


Comment: One commenter (2893) suggested that EPA require the use of natural gas where available as less-polluting alternative to other fossil fuels or other hazardous fuels.

Response: EPA acknowledges that the use of natural gas would reduce emissions of mercury and other HAP in comparison to coal. We have considered this approach but rejected it as an approach that would be available to all cement plants on a nationwide basis. (71 FR 76520, December 20, 2006).

Alternatives to cement and concrete


Comment: One commenter (2893) suggested volcanic ash as an alternative to some conventionally manufactured cement, and alternative materials as substitutes for the use of concrete in certain applications.

Response: Investigating alternatives to conventionally manufactured cement, and exploring substitutes for concrete that may be used in certain applications is beyond the scope of this rulemaking.

Benefits to industry of sector approach


Comment: One commenter (2898) agreed with EPA’s discussion of its sector-based approach and of the impacts of the rule, stating that it is a useful reminder for the portland cement manufacturing industry that complying with the emission standards may help the industry meet other pollution requirements. The commenter suggested that EPA discuss changes in production practices or processes that may help facilities comply with the emission standards. While this discussion should in no way influence the final standards promulgated as the MACT floor, a fuller discussion of these alternatives to incorporate consideration of potential co-benefits will make EPA’s discussion a more useful tool for the facilities trying to meet the standards and for the communities living near these facilities as they evaluate the actions of the facilities in their midst. Moreover, these co-benefits are important considerations in any evaluation of the technologies for beyond-the-floor standards. The commenter described aspects of energy efficiency, adjusting the composition of cement, and cleaner fuel as examples of actions that could provide these co-benefits.

Response: EPA acknowledges the commenter’s support of EPA’s sector-based approach.

CO and combustion practices


Comment: One commenter (2928) stated that high CO levels are very often an indication of poor combustion practices and should also be kept as low as practical.

Response: A discussion of the EPA’s decision not to regulate CO can be found in the preamble.



1At proposal, EPA also presented long term mercury data from an Essroc kilns showing relative standard deviations similar to the range of the relative standard deviations of the best performing kilns, based on 30-days of data, again suggesting that EPA had properly assessed variability of mercury inputs. 74 FR at 21143.

2 EPA notes the support of commenter 2898 in this regard.

3See Section 4.1.2.1 of the Credible Evidence Rule Response to Comment Document, available at <http://www.epa.gov/ttncaaa1/t1/fr_notices/certcfin.pdf>.
1   ...   36   37   38   39   40   41   42   43   44

Похожие:

National Emission Standards for Hazardous Air Pollutants from the iconI organic air pollutants I 1 Volatile Organic Compounds (vocs)

National Emission Standards for Hazardous Air Pollutants from the iconR315 Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities

National Emission Standards for Hazardous Air Pollutants from the iconPolitics of Hazardous Chemicals and Etiologic Agents on Water, Land and Air The Ticking Time Bomb Explodes

National Emission Standards for Hazardous Air Pollutants from the iconAs satisfying the skills standards set forth by the National Skills Standards Board

National Emission Standards for Hazardous Air Pollutants from the iconOffice of Air Quality Planning and Standards

National Emission Standards for Hazardous Air Pollutants from the iconNational Institute of Standards and Technology

National Emission Standards for Hazardous Air Pollutants from the iconAnsi (American National Standards Institute)

National Emission Standards for Hazardous Air Pollutants from the iconAmerican National Standards Institute ansi

National Emission Standards for Hazardous Air Pollutants from the iconNational Institute of Standards and Industrial Technology Act 1993

National Emission Standards for Hazardous Air Pollutants from the iconApplication for the Reassessment of a Hazardous Substance under Section 63 of the Hazardous Substances and New Organisms Act 1996

Разместите кнопку на своём сайте:
Библиотека


База данных защищена авторским правом ©lib.znate.ru 2014
обратиться к администрации
Библиотека
Главная страница