small MWC, new emission guidelines

[dvd.kvd@juno.com]

EPA has proposed  Emission Guidelines for Existing Stationary Sources:
Small Municipal Waste Combustion Units 
and
proposed rule Emission Guidelines for Existing Stationary Sources: Small
Municipal Waste Combustion Units

Deadline for public comments Oct 29.

www.epa.gov/TN/utaw/129/mwc/rimwc2.html

I'm from Utah & we have a Class B small MWC unit in Davis County, that I
don't know much about.


>From my print outs of the tables for dioxin/furans levels in the proposed
rule for existing source
	MACT Floor Emission Levels		Emission Limits

Class A	1000 ng/dscm			30/60 ng/dscm
Class B	  123  "				123     "
Class C	  837  "				125     "
National air Emission Impacts of these emission guideline for small MWC
units
	    Air emission reductions	% change from 98 baseline
Dioxins/furans	2.7 kg/yr			97


1.  Can you suggest to me some reasons  to justify setting  the emission
limits for dioxin/furans for Class B MWC units  at  the 30/60 level that
is given for Class A MWC units.

2.  The few stack tests done at this incinerator have revealed some
dioxin exceedances, but the management company so far has successfully
challenged the validity of the dioxin testing (I have been told EPA
approved this testing in 1995).  Any suggestions how to get the rule
strengthened in this area so the state regulators can't be bullied into
backing down.

3.  Any suggestions at all about what I might comment that could result
in a better rule.  I know energetic industry supporters are making
pleanty of comments.