News
09/10/09
Air and Radiation Docket and Information Center - Jennifer Lane Mesaros
U.S. Environmental Protection Agency
Washington, DC 20460
RE: Comments on Proposed Rules on National Emissions Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry, Docket ID No. EPA-HQ-OAR-2002-0051
To U.S. EPA,
I am commenting as someone who completed over 2 years of academic research on the social costs and benefits of burning tires in a cement kiln. This said to illustrate I have knowledge about the lack of current regulations imposed on cement kilns, the hazardous pollutants emitted regularly by these kilns and the insufficient controls and monitoring of these emissions. The proposed regulations are overdue and desperately needed to protect the environment and its citizens.
The following paragraphs illustrate my comments to the proposed legislation most of which encourage the passing of the new standards with a few points of contention. After doing my own research I can appreciate the effort that went into this report and offer gratitude to the EPA staff for their efforts. This document is the first I have seen that reflects my vision of the Environmental Protection Agency. It speaks truth about environmental concerns, holds those responsible accountable and aims to protect against known but preventable dangers such as air pollution. As Lisa Jackson stated in her interview today on the Diane Rehm show, the EPA’s mission is to protect health and the environment.
1. A conclusive definition of “solid waste” is overdue and has been a timely issue for me as our local kiln has proposed the use of scrap tires as fuel for the past few years. The definition is needed and until it is determined my hope is all cement kiln regardless of fuel type will be regulated equally. I also respectfully disagree with EPA’s comment that, “the combustion of secondary materials as alternative fuels did not have an appreciable effect on the amount of HAP emitted by any source.” (p 15) My research into many scientific reports conducted by the EPA as wells as conversations with EPA employees leads me to conclude that there was not enough relevant data to compare HAP effects from alternative fuel sources. I found other scientific data that shows there is an appreciable difference in HAPs when some alternative fuels are used. The long standing belief by the local, state and federal EPA as a whole that alternative fuels do not increase HAPs is in my opinion based on politics and not science. I strongly urge a new investigation under the new administration before the new definition of “solid waste” is determined.
2. If non-volatile metal HAPs like arsenic, cadmium, beryllium and lead will have set emission standards by using particulate matter as a surrogate then particulate matter testing must be done using continuous emission monitoring systems that have the ability to test particulates 2.5 microns and smaller. From my understanding the use of CEMS for PM2.5 would then test compliance for non-volatile metal HAPS and PM2.5. I am thrilled to read that opacity monitors will no longer be considered a viable testing source in favor of more accurate means. I am living in a non-attainment area for particulate matter, it is necessary to accurately monitor these types of emissions in order to determine high area sources for corrective means. In addition, to PM CEMS the use of a bag leak detector would ensure the bag is working at all times and the CEMS would ensure the bag is working well enough.
3. The use of continuous emission monitoring systems during shutdown, startup and malfunctions is especially important since the system is not working properly therefore enhancing the possibility of increased emissions. Our local cement kiln has reported on average 2 malfunctions a month many times stating no solution or cause to the malfunction which may last several minutes to several hours. What exudes from the stack during these times is unknown and must be monitored.
4. The regulation for mercury is overdue and a welcome change. The efforts made by many to begin the regulation of this insidious emission is appreciated and greatly supported.
5. The use of CEMS to test for various emissions is the best means available today. In order to protect the effectiveness and relevance of the CEMS data regulation must clearly state how the location, calibration and ongoing accuracy of the CEMS will be determined and by whom within the Title V permit. An independent third party accompanied by an EPA representative would provide the best scenario possible along with transparent monitoring using online reporting for public view.
6. If CKD is not going to be recycled into the kiln how will it be disposed of on a regular basis? Where will it be safely disposed of to avoid run-off and high concentration contamination? Site specific regulation stated clearly in the Title V permit must be a priority and checked routinely by EPA.
7. Subcategories – The allowance for increased emissions through subcategories is not in the best interest of the public or wildlife. A minimum amount must be applied to all kilns. Subcategories have the potential of increasing limits for those already high and risk or perhaps encourage kiln owners to apply for sub-categorization to allow for excess emission limits instead of focusing efforts on emission reduction. If a quarry tests high for mercury why not restrict the quarry from being used and close kilns who cannot comply with new standards. The EPA mission is to protect health and the environment, not cement kilns that are unable to meet emission standards due to local inputs, lack of funding for pollution controls or their otherwise inability to upkeep or update their kiln.
8. The awareness expressed regarding the short duration and “snapshot in time” of stack testing is significant. I reiterate what is already noted in the proposed legislation, CEMS data are superior to the results of a single stack test for characterizing long term performance and best performance. Again, how often will the CEMS performance and calibration be checked and by whom?
Thank you for taking the time to read my comments has I have done my part to comment. This proposed ruling builds my trust in the EPA under the new administration to make rules and regulation based on science and not politics or in favor of big business. The EPA’s apparent refocus on the protection of health and the environment is encouraging. As President Obama has expressed, we do not have to choose between the environment and a growing, prosperous economy. This sentiment I hope will be kept in mind when cement kiln owners debate these new regulations with the EPA.
Thank you again for your time. I look forward to tracking the outcome of this proposed legislation in the days to come.
Sincerely,
Jennifer Lane Mesaros
Washington, DC 20460
RE: Comments on Proposed Rules on National Emissions Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry, Docket ID No. EPA-HQ-OAR-2002-0051
To U.S. EPA,
I am commenting as someone who completed over 2 years of academic research on the social costs and benefits of burning tires in a cement kiln. This said to illustrate I have knowledge about the lack of current regulations imposed on cement kilns, the hazardous pollutants emitted regularly by these kilns and the insufficient controls and monitoring of these emissions. The proposed regulations are overdue and desperately needed to protect the environment and its citizens.
The following paragraphs illustrate my comments to the proposed legislation most of which encourage the passing of the new standards with a few points of contention. After doing my own research I can appreciate the effort that went into this report and offer gratitude to the EPA staff for their efforts. This document is the first I have seen that reflects my vision of the Environmental Protection Agency. It speaks truth about environmental concerns, holds those responsible accountable and aims to protect against known but preventable dangers such as air pollution. As Lisa Jackson stated in her interview today on the Diane Rehm show, the EPA’s mission is to protect health and the environment.
1. A conclusive definition of “solid waste” is overdue and has been a timely issue for me as our local kiln has proposed the use of scrap tires as fuel for the past few years. The definition is needed and until it is determined my hope is all cement kiln regardless of fuel type will be regulated equally. I also respectfully disagree with EPA’s comment that, “the combustion of secondary materials as alternative fuels did not have an appreciable effect on the amount of HAP emitted by any source.” (p 15) My research into many scientific reports conducted by the EPA as wells as conversations with EPA employees leads me to conclude that there was not enough relevant data to compare HAP effects from alternative fuel sources. I found other scientific data that shows there is an appreciable difference in HAPs when some alternative fuels are used. The long standing belief by the local, state and federal EPA as a whole that alternative fuels do not increase HAPs is in my opinion based on politics and not science. I strongly urge a new investigation under the new administration before the new definition of “solid waste” is determined.
2. If non-volatile metal HAPs like arsenic, cadmium, beryllium and lead will have set emission standards by using particulate matter as a surrogate then particulate matter testing must be done using continuous emission monitoring systems that have the ability to test particulates 2.5 microns and smaller. From my understanding the use of CEMS for PM2.5 would then test compliance for non-volatile metal HAPS and PM2.5. I am thrilled to read that opacity monitors will no longer be considered a viable testing source in favor of more accurate means. I am living in a non-attainment area for particulate matter, it is necessary to accurately monitor these types of emissions in order to determine high area sources for corrective means. In addition, to PM CEMS the use of a bag leak detector would ensure the bag is working at all times and the CEMS would ensure the bag is working well enough.
3. The use of continuous emission monitoring systems during shutdown, startup and malfunctions is especially important since the system is not working properly therefore enhancing the possibility of increased emissions. Our local cement kiln has reported on average 2 malfunctions a month many times stating no solution or cause to the malfunction which may last several minutes to several hours. What exudes from the stack during these times is unknown and must be monitored.
4. The regulation for mercury is overdue and a welcome change. The efforts made by many to begin the regulation of this insidious emission is appreciated and greatly supported.
5. The use of CEMS to test for various emissions is the best means available today. In order to protect the effectiveness and relevance of the CEMS data regulation must clearly state how the location, calibration and ongoing accuracy of the CEMS will be determined and by whom within the Title V permit. An independent third party accompanied by an EPA representative would provide the best scenario possible along with transparent monitoring using online reporting for public view.
6. If CKD is not going to be recycled into the kiln how will it be disposed of on a regular basis? Where will it be safely disposed of to avoid run-off and high concentration contamination? Site specific regulation stated clearly in the Title V permit must be a priority and checked routinely by EPA.
7. Subcategories – The allowance for increased emissions through subcategories is not in the best interest of the public or wildlife. A minimum amount must be applied to all kilns. Subcategories have the potential of increasing limits for those already high and risk or perhaps encourage kiln owners to apply for sub-categorization to allow for excess emission limits instead of focusing efforts on emission reduction. If a quarry tests high for mercury why not restrict the quarry from being used and close kilns who cannot comply with new standards. The EPA mission is to protect health and the environment, not cement kilns that are unable to meet emission standards due to local inputs, lack of funding for pollution controls or their otherwise inability to upkeep or update their kiln.
8. The awareness expressed regarding the short duration and “snapshot in time” of stack testing is significant. I reiterate what is already noted in the proposed legislation, CEMS data are superior to the results of a single stack test for characterizing long term performance and best performance. Again, how often will the CEMS performance and calibration be checked and by whom?
Thank you for taking the time to read my comments has I have done my part to comment. This proposed ruling builds my trust in the EPA under the new administration to make rules and regulation based on science and not politics or in favor of big business. The EPA’s apparent refocus on the protection of health and the environment is encouraging. As President Obama has expressed, we do not have to choose between the environment and a growing, prosperous economy. This sentiment I hope will be kept in mind when cement kiln owners debate these new regulations with the EPA.
Thank you again for your time. I look forward to tracking the outcome of this proposed legislation in the days to come.
Sincerely,
Jennifer Lane Mesaros