From: David Gossman <DGOSSMAN@concentric.net>
Newsgroups: sci.environment,talk.environment
Subject: Re: EPA Hazardous Waste Combusto MACT
Date: Fri, 23 Aug 1996 22:39:37 -0500

Alexander Sagady wrote:


> August 15, 1996
>
> TO: Air and Waste Folks
>
> FROM: Alex Sagady  (517) 332-6971
>
> Below are some tables I developed of EPA's information plus a little
> narrative about the extremely weak standards that are up for comment
> right now till 8/19  (Monday).  These are Maximum Achievable Control
> Technology standards for hazardous waste combustors (cement kilns,
> light weight aggregate kilns and hazwaste incinerators).
>
> MACT is supposed to be the equivalent to the best controlled source
> for new waste combustors and to the average of the best 12% for
> existing waste combustors.
>
>
> The percentage numbers are from EPA's narrative on the standards.
>
>
> The citation at the end is the applicable section of the Clean Air
> Act....
>
> Most hazardous waste is disposed of in cement plants (60-70%) who
> win big with the proposed numbers.
>
>
>
> The Net Result of EPA's Use of Expanded MACT Pools, Its Statistical
> Methods and Its Proposed Standards is to Allow Substantial Numbers of
> Waste Combustor Sources to Escape Emission Control Upgrades
>
>       The three tables below summarizes all of EPA's
> characterizations as to the ability of existing sources to meet each of
> the
> proposed expanded MACT Floor limitations, beyond the floor
> limitations and other standards published in the proposed rule:
>
> HWI=  Hazardous Waste Incinerator
> CK=   Waste-Burning Cement Kiln
> LWAK= Light Weight Aggregate Kiln
>
>
> Waste       Pollutant         Limit              Percent of
> Combustor                                        Existing Sources
> Type                                             Meeting Limit
> ----------------------------------------------------------------------
>
> HWI         PCDD/PCDF         418xF Inlet or     45% all test cond
>                               0.20 ng/dscm
>                               (Exp MACT Floor)
>
> HWI         PM                0.08 gr/dscf       95%
>                               Exp MACT Floor
>
> HWI         PM                0.03 gr/dscf       70%
>                               BTF Limit
> (of 30% who don't meet BTF limit, 9% can meet limit throug design,
> operation and
> maintenance upgrades; 11% would require new ESP, FF or IWS)
>
> HWI         HG                130 ug/dscm        70%
>                               (Exp MACT Floor)
>
> HWI         SVM               270 ug/dscm        65%
>                               (Exp MACT Floor)
>
> HWI         LVM               210 ug/dscm        80%
>                               (Exp MACT Floor)
>
> HWI         Total Chlorine    280 ppmv           90%
>                               (Exp Mact Floor)
>
>
>
> Waste       Pollutant         Limit              Percent of
> Combustor                                        Existing Sources
> Type                                             Meeting Limit
> ----------------------------------------------------------------------
>
> CK          PCDD/PCDF         418xF Inlet        50%
>                               (Exp MACT Floor)
>
> CK          PCDD/PCDF   0     .20 ng/dscm        75%
>                               (BTF Limit)
>
> CK          PM                0.03 gr/dscf       30%
>                               (Exp MACT Floor)
>
> CK          HG                130 ug/dscm        80%
>                               (Exp MACT Floor)
>
> CK          HG                50 ug/dscm         57%
>                               (BTF Limit)
>
> CK          SVM               57 ug/dscm         33%
>                               (Exp MACT Floor)
>
> CK          LVM               130 ug/dscm        80%
>                               (Exp MACT Floor)
>
> CK          Total Chlorine    630 ppmv           100%
>                               (Exp MACT Floor)
>
>
>
> Waste       Pollutant         Limit              Percent of
> Combustor                                        Existing Sources
> Type                                             Meeting Limit
> ----------------------------------------------------------------------
>
>
> LWAK        PCDD/PCDF         0.20 ng/dscm       100%
>                               (BTF Limit)
>
> LWAK        PM                0.049 gr/dscf      100%
>                               (Exp MACT Floor)
>
> LWAK        PM                0.03 gr/dscf       80%
>                               (BTF Limit)
>
> LWAK        HG                72 ug/dscm         70%
>                               (Exp MACT Floor)
>
> LWAK        SVM               12 ug/dscm         38%
>                               (Exp MACT Floor)
>
> LWAK        LVM               340 ug/dscm        92%
>                               (Exp MACT Floor)
>
> LWAK        Total Chlorine    2100 ppmv          85%
>                               (Exp MACT Floor)
>
> LWAK        Total Chlorine    450 ppmv           38%
>                               (BTF Limit)
>
>       Congress very specifically limited the discretion of the
> Environmental Protection Agency in selecting standards that reflect
> Maximum Achievable Control Technology under the Clean Air
> Act.  Congress provided:
>
> "(3)  New and existing sources.
>
> "The maximum degree of reduction in emissions that is deemed
> achievable for new sources in a category or subcategory shall not
> be less stringent than the emission control that is achieved in
> practice by the best controlled similar source, as determined by
> the Administrator.  Emission standards promulgated under this
> subsection for existing sources in a category or subcategory may
> be less stringent than standards for new sources in the same
> category or subcategory but shall not be less stringent, and may
> be more stringent than-"
>
>       "(A)  the average emission limitation achieved by the
>       best performing 12 percent of the existing sources (for
>       which the Administrator has emissions information),
>       excluding those sources that have, within 18 months before
>       the emission standard is proposed or within 30 months
>       before such standard is promulgated, which ever is later,
>       first achieved a level of emission rate or emission reduction
>       which complies, or would comply if the source is not
>       subject to such standard, with the lowest achievable
>       emission rate (as defined by section 7501 of this title)
>       applicable to the source category and prevailing at the time,
>       in the category or subcategory for categories and
>       subcategories with 30 or more sources, or"
>
>       "(B)  the average emission limitation achieved by the best
>       performing 5 sources (for which the Administrator has or
>       could reasonably obtain emissions information) in the
>       category or subcategory for categories or subcategories
>       with fewer than 30 sources."  (emphasis supplied)  42
>       USC 7412(3), (A-B)

I am afraid that your comments at best are amusing and at worst a sad
commentary on the hype that EPA and others have fed you.  The facts are
that:

1.  Only one cement plant of all those burning waste currently meets the
MACT standard as proposed and it has an unusual design not readily
adapted to most other plants.

2.  EPA made up a large portion of the database used to create the
standard - don't believe me read the background documents where they
explain how they did it.

3.  If the rule goes through as proposed about half those cement plants
bruning waste will probably stop.  This will not benefit the enviroment
since there is very little diference in cement plant emissions when
burning coal vs waste.

4.  There are numerous situations in this rule where EPA has
intentionally or not actually increased risk to human health and safety
as well as the enviroment.

I invite you to take a closer look at the actual rule itself rather than
just the numbers you quote.  The simple fact is that cement plants
burning waste are already more heavily regulated than any other
combustion device anywhere via the BIF regulations.  EPA's pursuit of
the MACT standard is a purely political action by those whom believe
that eliminating legitimate and safe ways to actually reuse and dispose
of hazardous waste will somehow prevent its generation in the first
place.  If you believe that sort of hype I would suggest you stop
flushing the toilet and by no means take out the garbage.  See if you
and your family can live under the conditions you propose to shove down
the throats of others first.