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Fwd: EPA Haz Waste Combusto MACT
>>From: asagady@sojourn.com (Alexander Sagady)
>>Newsgroups: sci.environment,talk.environment
>>Subject: EPA Hazardous Waste Combusto MACT
>>Date: 15 Aug 1996 05:17:42 GMT
>>Organization: Sojourn Systems, Lansing, MI (USA)
>>Lines: 175
>>Message-ID: <4uubtm$7v7@tkhut.sojourn.com>
>>NNTP-Posting-Host: shell.sojourn.com
>>X-Newsreader: TIN [UNIX 1.3 950824BETA PL0]
>>Xref: news.ism.net sci.environment:6820 talk.environment:5509
>>
>>
>>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)
>>
>
>Tony Tweedale || "I'm not going to get involved in any
>Bx 7941 || of that peer-reviewed mumbo-jumbo."
>Missoula, MT 59807 || -Rep. John Doolittle (R-CA)
>406-542-1709,f 728-0867 ||
>
>||" 'Are the people being protected?'
>cmcr@ism.net ||___ is too narrow
>a question."
>(Cold Mountain, Cold Rivers || -API lobbyists meeting, 12 Dec. '94
>@ Internet Services of MT) ||
>----------------------------|| "A species goes out of existence every 20
>seconds. Surely one must come into existence every 20 seconds?" -Helen
>Chenowith (R-ID)
>
Tony Tweedale || "I'm not going to get involved in any
Bx 7941 || of that peer-reviewed mumbo-jumbo."
Missoula, MT 59807 || -Rep. John Doolittle (R-CA)
406-542-1709,f 728-0867 ||
||" 'Are the people being protected?'
cmcr@ism.net ||___ is too narrow a question."
(Cold Mountain, Cold Rivers || -API lobbyists meeting, 12 Dec. '94
@ Internet Services of MT) ||
----------------------------|| "A species goes out of existence every 20
seconds. Surely one must come into existence every 20 seconds?" -Helen
Chenowith (R-ID)