[Date Prev][Date Next][Thread Prev][Thread Next][Date Index][Thread Index]
EPA Hazardous waste burning standards are weak
August 15, 1996
TO: Air and Waste Folks
FROM: Alex Sagady (517) 332-6971 (reply to asagady@sojourn.com )
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.
EPA's comment deadline is August 19 (Monday) Comments can be
submitted by Email. Copies of the standard and the docket are
available on the WWW at EPA's Office of Solid Waste and Emergency
Response. Call me for instructions on getting to it if you can't
find it.
Alex
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 418øF 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 418øF 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)
Alex J. Sagady & Associates Email: asagady@sojourn.com
Environmental Consulting and Database Systems
PO Box 39
East Lansing, MI 48826-0039 (517) 332-6971 (voice); (517) 332-8987
(fax)