United States      Office of Air Quality       EPA-450/3-84-008
           Environmental Protection  Planning and Standards     March 1984
           Agency        Research Triangle Park NC 27711
           Air


Jftk
EPA     Lime Manufacturing   EIS
         Plants -
         Background
         Information
         for Promulgated
         Standards

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                               EPA-450/3-84-008
Lime Manufacturing Plants -
   Background Information
 for Promulgated Standards
      Emission Standards and Engineering Division
              U.S. Environmental Protection
              Region 5, Library (PL-12J)
      U.S. ENVIRONMENTAL PROTECTION AGENCY
           Office of Air and Radiation
        Office of Air Quality Planning Standards
      Research Triangle Park, North Carolina 27711

                March 1984

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This report has been reviewed by the Emission Standards and Engineering Division of the Office of Air Quality Planning
and Standards, EPA, and approved for publication. Mention of trade names or commercial products is not intended to

n«nStlt^eoncd0rSement °r recommendati°n ^r use. Copies of this report are available through the Library Services
Office (MD-35), U.S. Environmental Protection Agency, Research Triangle Park, North Carolina 27711; or, for a fee from
the National Technical Information Services, 5285 Port Royal Road, Springfield Virginia 22161
                                    Publication No. EPA-450/3-84-008

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                     ENVIRONMENTAL PROTECTION AGENCY
                          Background Information
                                and Final
                      Environmental Impact Statement
                      for Lime Manufacturing Plants
                               Prepared by:
                                                        r (Date)
Jack R. Farmer
Director, Emission Standards and Engineering Division
U.S. Environmental Protection Agency
Research Triangle Park, NC  27711

1.  The promulgated revised standards of performance will limit parti cul ate
    matter emissions from rotary lime kilns to 0.6 pound  per ton, and
    the visible emission standard has been raised to 15 percent opacity.
    Section 111 of the Clean Air Act (42 U.S.C. 7411), as amended, directs
    the Administrator to establish standards of performance for any
    category of new stationary source of air pollution that "... causes
    or contributes significantly to air pollution which may reasonably be
    anticipated to endanger public health or welfare."  Lime manufacturing
    plants are located in all areas of the nation.

2.  Copies of this document have been sent to the following Federal
    Departments:  Labor, Health and Human Services, Defense, Transportation,
    Agriculture, Commerce, Interior, and Energy; the National Science
    Foundation; the Council on Environmental Quality; members of the
    State and Territorial Air Pollution Program Administrators; the
    Association of Local Air Pollution Control Officials; EPA Regional
    Administrators; and other interested parties.

3.  For additional information contact:

    Mr. C. Douglas Bell
    Standards Development Branch (MD-13)
         Environmental Protection Agency
U.S.
Research Triangle Park,  NC
Telephone:   (919) 541-5578
                                27711
4.  Copies of this document may be obtained from:

    U.S. EPA Library (MD-35)
    Research Triangle Park, NC  27711

    National Technical Information Service
    5285 Port Royal Road
    Springfield, VA  22161

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                             TABLE OF CONTENTS

Section                                                             Page

1    SUMMARY	  l-l

     1.1   Summary of Changes Since Proposal 	  1-2

     1.2   Summary of Impacts of Promulgated Amendments  	  1-2
           1.2.1  Alternatives to the Promulgated Action 	  1-2
           1.2.2  Environmental  Impacts of the Promulgated
                  Action	  1-3
           1.2.3  Energy and Economic Impacts of the Promulgated
                  Action	1-3
           1.2.4  Other Considerations
                  1.2.4.1  Irreversible and Irretrievable
                           Commitment of Resources 	  1-3
                  1.2.4.2  Environmental and Energy Impacts of
                           Delayed Standards	'.  .  .  1-4
                  1.2.4.3  Urban and Community Impacts 	  1-4

2    SUMMARY OF PUBLIC COMMENTS   	  2-1

     2.1   Costs and Benefits of the New Source Performance
           Standards	2-1
           2.1.1  Costs	  2-1
           2.1.2  Costs and Benefits	2-3
           2.1.3  Mobility and Competition .  .  .  :	2-3
           2.1.4  Emissions	2-4
           2.1.5  Executive Order 12291  	  2-5
           2.1.6  Health Impacts	2-6

     2.2   Applicability Date	2-7

     2.3   Best Demonstrated Technology  	  2-10
           2.3.1  Use of Wet Scrubbers	2-10

     2.4   Mass Emission Standard	2-12
           2.4.1  Mass Emission  Level	2-12
           2.4.2  Stone Feed	2-14

     2.5   Visible Emission Standard 	   2-15
           2.5.1  Achievability  of the Opacity  Standard  	   2-15
           2.5.2  Correlation of Opacity Data with Mass Emission
                  Rates	2-20
           2.5.3  Effect of Particle Size on Visible Emissions  .  .   2-22
           2.5.4  Plant D Tests	2-22
           2.5.5  Specific Affected Facility Visible Emission
                  Standards	2-23
           2.5.6  Reference Method 9 Accuracy and Reliability   .  .   2-25
           2.5.7  Failure To Use All  Data Reviewed	2-27
           2.5.8  Miscellaneous	2-27

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                       TABLE OF CONTENTS (continued)

Section                                                             page

     2.6  Test Methodology   	2-27
           2.6.1  Isokinetic Conditions  	  2-27
           2.6.2  Production Capacity  	   2-28
           2.6.3  Pi tot Tube Specifications and Velocity
                  Traverses	2-31
           2.6.4  Climatic Conditions  	   2-32

     2.7   Continuous Monitoring 	   2-33
           2.7.1  Continuous Monitor Reliability 	   2-33
           2.7.2  Use of Continuous Emissions  Monitoring
                  Results	2-34
     2.8   Miscellaneous	2-35
           2.8.1  Temperature of Lime Production	2-35
           2.8.2  Continuous Monitoring of Positive-Pressure
                  Fabric Filters 	   2-35
                              LIST OF TABLES


Table                                                              page

2-1  List of Commenters	2~2

2-2  Adjusted Plant B and Plant E Test Results	2-29

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                                1.   SUMMARY

     New source performance standards for lime manufacturing plants were
proposed on May 3,  1977 (Docket No.  A-80-53/74-5-I-G-2; hereinafter
"Docket No. A-80-53/74-5" will  be omitted from the docket references in
this document).  Final  rules were promulgated on March 7, 1978 (I-K-3).
As promulgated, standards of performance for lime manufacturing plants
limited particulate emissions from rotary lime kilns to no greater than
0.15 kilogram per megagram (kg/Mg) [0.30 pound per ton (lb/ton)] of
limestone feed.  The opacity of the exhaust gases from rotary lime kilns
was limited to less than 10 percent.   The particulate emission limit for
any lime hydrator was 0.075 kg/Mg (0.15 Ib/ton) of limestone feed.
     The National Lime Association (NLA) filed a petition for review of
the lime manufacturing standards with the United States Court of Appeals
for the District of Columbia Circuit.  On May 19, 1980, the Court of
Appeals remanded the standards.
     The lime manufacturing plant standards were reviewed, and on September 2,
1982, a response to the Court remand and several amendments to the
standards were proposed in the Federal Register (47 FR 38832) (III-A-1).
The standards of performance for lime manufacturing plants are based on
the use of fabric filters or electrostatic precipitators (ESP's).
Because of the costs involved in the operation of wet scrubbers as
compared to fabric filters and ESP's, scrubbers were not considered best
demonstrated control technology.  However, the proposed remand response
made it clear that the standards do not preclude the use of wet scrubbers.
The proposed amendments to the standards of performance raised the
particulate matter emission limit from rotary lime kilns to 0.30 kg/Mg
(0.60 lb/ton) of limestone feed.  The visible emission limit for exhaust
                                   1-1

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gases from rotary lime kilns remained at 10 percent opacity.  The standard
for hydrators was deleted.   Public comment was invited.
     A public hearing was held on November 18, 1982, and the public
comment period was extended until December 20, 1982.  Eleven speakers
presented comments on the proposed remand response at the public hearing,
and 13 written comments were received.   These comments are summarized
and responses are presented in this document, which serves as the basis
for the revisions that have been made to the proposed amendments to the
standards.
1.1  SUMMARY OF CHANGES SINCE PROPOSAL
     In response to the public comments, certain changes have been made
in the proposed amendments  to the standards.
     The most significant change to the proposed standards is to raise
the visible emission standard from 10 to 15 percent opacity.
     Another change to the  proposed standards is to permit visible
emission observations in lieu of continuous monitoring of visible emissions
for positive-pressure baghouses.   There are technical problems in obtaining
accurate readings from a single continuous monitor on positive-pressure
baghouses, and the cost of  multiple continuous monitors is considered to
be unreasonable.   Thus, certified visible emission observers may be used
to monitor the visible emissions of the exhaust gases from rotary lime
kilns equipped with positive-pressure baghouses.   Continuous monitors,
however, will continue to be required for negative-pressure baghouses
and ESP's.
     There is also a change to the proposed standards that expands the
definition of stone feed to include iron-oxide additives used in the
production of iron-bearing  lime because these additives become part of
the final product.
     The excess emission reporting frequency has been changed from
quarterly to semi-annually.   In addition, for rotary lime kilns that use
wet scrubbers to control emissions, if the pressure drop of the scrubber
is greater than 30 percent  below the rate established during the perfor-
mance test, this information must be reported to the Agency on a semi-annual
basis.
                                   1-2

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1.2  SUMMARY OF IMPACTS OF PROMULGATED AMENDMENTS
1.2.1  Alternatives to the Promulgated Action
     The regulatory alternatives are discussed in Chapter 6 of Volume  I
of the standards support and environmental impact statement (Volume  I
SSEIS) for the existing standards (EPA-450/2-77-007a).  These regulatory
alternatives reflect the different levels of emission control that were
analyzed in determining best demonstrated technology, considering costs,
and nonair quality health, environmental, and economic impacts for lime
manufacturing plants.  These alternatives remain the same.
1.2.2  Environmental Impacts of the Promulgated Action
     The environmental impacts resulting from the existing standards are
described in Chapter 6 of the Volume I SSEIS.  In remanding the lime
standards, the Court did not question the original analysis of economic,
energy, or environmental impacts.   The impacts of the amended standards,
based on the original analyses, are summarized below:
     The amended standards would reduce particulate matter emissions
from a rotary lime kiln by about 40 percent below those allowed under a
typical State implementation plan (SIP).   This would result in a particulate
matter emission reduction of about 1,300 tons industry wide in the fifth
year following proposal.   This estimate is based on a projected growth
of 20 new, modified, or reconstructed rotary lime kilns in 5 years.
     For rotary lime kilns,  the solid waste generation industry wide in
the fifth year would increase by about 0.2 percent relative to that
under a typical  SIP.   There would be no adverse water, noise,  or radiation
impacts associated with these standards.
     Because the amended standards would not regulate hydrators,  particulate
matter emissions from these sources  would increase by about 140 tons
annually, based on our estimate that three new hydrators  will  be built
in the next 5 years.
1.2.3  Energy and Economic Impacts of the Promulgated Action
     Energy and economic impacts resulting from the standard are discussed
in Chapters 6 and 7 of the Volume  I  SSEIS,  respectively.   No changes in
these impacts have occurred  since  the standard was proposed.
                                   1-3

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1.2.4  Other Considerations
     1-2.4.1  Irreversible and Irretrivable Commitment of Resources.
The regulatory alternatives defined in Chapter 6 of the Volume I SSEIS
would not preclude the development of future control options nor would
they curtail any beneficial use of resources.   The alternatives do not
involve short-term environmental gains at the expensive of long-term
environmental losses.   The alternatives yield successively greater
short- and long-term environmental benefits, with the alternative upon
which the final  standards are based providing the greatest benefits.
Further, none of the alternatives result in the irreversible and
irretrievable commitment of resources.  No change in these considerations
has resulted since proposal of the standard.
     1.2.4.2  Environmental and Energy Impacts of Delayed Standards.  As
discussed in Chapter 6 of the Volume I SSEIS,  delay in the amended standards
would cause a similar delay in realizing the beneficial impacts associated
with the standards because enforcement of the standards was suspended
upon remand of the standards.   No changes in the potential effects of
delaying the standards have occurred since proposal  of the existing
standards.
     1.2.4.3  Urban and Community Impacts.   Urban and community impacts
of the standards are considered under economic impacts in Chapter 7 of
the Volume I SSEIS.  No changes in these impacts have occurred since the
standards were proposed.
                                   1-4

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                      2.  SUMMARY OF PUBLIC COMMENTS

     A list of commenters and their affiliations is presented in Table 2-1.
Eleven individuals representing seven lime companies, two consulting
firms, and one trade association (NLA) presented oral testimony at the
public hearing.  In addition, 14 written comments were received, 11 of
which were from organizations commenting at the public hearing.   The
remaining three were from two lime companies and one attorney.
     The comment letters often contained several comments.  Each comment
is addressed separately, and the commenter is identified by the appropriate
docket number.
2.1  COSTS AND BENEFITS OF THE NEW SOURCE PERFORMANCE STANDARDS
2.1.1  Costs
     Comment:   One commenter (IV-D-6) stated that the incremental cost
effectiveness of emission reduction increases from $25 per ton of
particulate matter removed for baseline SIP control to $364 per ton for
the new source performance standards.  The commenter contended that this
increase is enormous and raises a question of whether the standard can
be justified on a cost basis.
     Response:   The cost effectiveness of the standards is at the lower
end of the range of cost effectiveness ($1,000-$3,000 per ton in 1983
dollars) associated with particulate matter control for other industries
regulated by a new source performance standard.   It is, therefore,
considered to be reasonable.
     Comment:   One commenter (IV-D-2) states that the cost of preliminary
collection devices (i.e., cyclones) was not included in the economic
analysis of the lime plant new source performance standard.   He  further
states that the sizes of existing ESP's and whether the ESP's are single
                                  2-1

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                       TABLE 2-1.  LIST OF COMMENTERS'
No.
ORAL
1.

2.
3.
4.

5.

6.
7.

8.
9.


10.
11.
Commenter
TESTIMONY:
NLA (L. J. Minnick)

Dravo Lime Co. (J. Thompson)
Martin Marietta (G. Judd)
Mississippi Lime Co. (H. Shell,
Consultant)
Continental Lime Co. (M. D. Roach,
Consultant)
Genstar (B. McCandlish)
Edward Levy Co. /Detroit Lime Co.
(M. 0. Johnson)
Marblehead Lime Co. (D. Carman)
Chemical Lime, Inc. (L. Rice)
(comments based on experience of
Dow Chemical Co. )
Marblehead Lime Co. (J. Kerwin)
Allied Products Co. (C. Dennard)
Date of
comment

11/18/82

11/18/82
11/18/82
11/18/82

11/18/82

11/18/82
11/18/82

11/18/82
11/18/82


11/18/82
11/18/82
Docket
No.

IV-F-1

IV-F-1
IV-F-1
IV-F-1

IV-F-1

IV-F-1
IV-F-1

IV-F-1
IV-F-1


IV-F-1
IV-F-1
Pageb
No.

7-11
105-113
11-31
32-39
39-46

46-65

66-70
71-77

77-81
81-87


87-96
97-105
WRITTEN COMMENTS:
1.
2.

3.
4.

5.
6.
7.

8.

9.

10.
11.
12.
13.
14.
Continental Lime Co. (J. B. Jordan)
Martin Marietta Chemicals
(L. C. Hanson)
G. R. Repper, Attorney
Tenn-Luttrell Lime Co. (J. Cardosa,
Jr.)
Continental Lime Co. (J. B. Jordan)
Marblehead Lime Co. (J. M. Kerwin)
National Lime Association (A. March,
Attorney)
Genstar Cement and Lime Co.
(W. W. McCandlish)
Mississippi Lime Co. (R. V. Zener,
Pepper, Hamilton, and Scheetz)
Chemical Lime Co. (L. Rice)
Continental Lime Co. (J. B. Jordan)
Dravo Lime Co. (J. Thompson)
Marblehead Lime Co. (J. M. Kerwin)
Marblehead Lime Co. (J. M. Kerwin)
10/01/82
10/20/82

10/20/82
10/29/82

11/10/83
11/18/82
11/18/82

12/06/82

12/17/82

01/17/83
01/31/83
01/31/83
02/02/83
02/04/83
IV-D-1
IV-D-2

IV-D-3
IV-D-4

IV-D-9
IV-G-2
IV-G-3

IV-D-5

IV-D-6

IV-G-4
IV-G-5
IV-G-6
IV-G-7
IV-G-8



















 A transcript of the oral  testimony presented at the public hearing and
 copies of all  correspondence received from commenters appear in
bDocket A-80-53.
 Page numbers locate testimony within the public hearing transcript.
                                    2-2

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or multi-field units were not examined.   He believes that the cost of
99.7-percent-efficient ESP's cannot be justified.
     Response:  In the background information document supporting the
original  new source performance standards (NSPS) (I-G-1), the size,
design, costs, and use of preliminary collection devices (i.e., cyclones)
and ESP's were analyzed.   As discussed in the response to the preceding
comment,  the control costs are considered to be reasonable.
2.1.2  Cost and Benefits
     Comment:   One commenter (IV-F-1; pp. 102-103) asserted that the
regulation may not result in significant environmental improvement.  The
commenter concluded that  the regulation will consume the time, effort,
and money of the Government and the industry with little tangible and
measurable improvement.
     Response:  As recorded in the docket and discussed in the Volume I
SSEIS, emission reductions of 7,200 to 10,000 tons a year are expected
in 1987.   Thus, there will be significant environmental improvement
associated with the standards.
2.1.3  Mobility and Competition
     Comment:   One commenter (IV-D-6) noted that in the development of
national  standards, the mobility and competitive nature of the industry
are evaluated to preclude the establishment of "havens" for industries
in areas  of less-strict pollution regulations.   The lime industry is
limited in mobility to sites where customers are close by because of the
cost of shipping lime.  This makes it impossible for an outside plant to
compete with plants located close to customers.   Therefore,  the commenter
believes  that mobility and competition are not factors in the lime
industry, "havens" are not an issue, and there is no justification for a
national  lime standard.
     Response:  An assessment of the mobility and competitive nature of
an industry is only one of three considerations taken into account in
establishing the priority of regulation for source categories.  As noted
in Section 2.1.4 below,  lime manufacturing plants are a significant
contributor and, thus, new source performance standards are appropriate.
                                  2-3

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     In addition, the availability of raw materials or markets does not
necessarily dictate the location of a production facility.  If a market
is located in or near several States with an adequate source of raw
materials, a producer has the option of locating a plant in the State
that most suits his needs.   This gives a producer the option of locating
a plant at a site that is most favorable to him with regard to environmental
regulations.   Therefore,  there is a potential for mobility and competition
in the lime industry.
2.1.4  Emissions
     Comment:   One commenter (IV-D-6) contends that growth in the lime
industry between 1977 and 1982 was overestimated by 200 percent and,
therefore, the emission impacts of the lime industry were overestimated.
The commenter noted that when the lime new source performance standards
were first proposed, the Administrator was directed by the Clean Air Act
to include sources that may contribute significantly to air pollution.
The commenter stated that under the present statute the Administrator
can include a source that does cause or contribute significantly to air
pollution endangering public health and welfare.   Therefore,  the question
of whether lime does contribute significantly to air pollution should be
reexamined.
     Response:   The precise rate of growth in an industry is  not a prime
consideration in developing a new source performance standard.   Growth
projections are used to provide estimates of the nationwide impact of
new source performance standards on the industry.   Growth in  the lime
industry is lower than originally predicted; however,  significant growth
has occurred.   At least 16  new lime kilns have been installed in the
past 5 years,  and growth  is expected to continue,  both in additional
production capacity and in  replacement capacity for outmoded  production
facilities.
     Section  lll(b)(l)(A) requires the Administrator to list  source
categories that in his judgment ".  .  .  caused, or contributed
significantly to, air pollution which may reasonably be anticipated to
endanger public health or welfare."  Lime manufacturing plants meet this
"significant  contributor" test.   The amendment of this test by the 1977
Clean Air Act Amendments  was intended to ".  .  .  emphasize the preventive
                                  2-4

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 or  precautionary  nature  of  the  act"  and  "...  to  assure  consideration
 of  the cumulative  impact of all  sources  of a  pollutant  in setting  .  .  .
 emission  standards,  not  just the  extent  of the  risk  from  the  emissions
 from  a single source or  class of  sources of the pollutant."   [H. R.  Rep.
 No. 95-294, 95th  Cong. 1st  Sess.  at  49-50 (1977)].   The amendment  does  not
 justify deli sting  lime plants.
      Comment:  One commenter (IV-0-6) believes  that  the assumed baseline
 control level of  1.0 Ib/ton was  in error because lime plants  may be
 subject to more stringent State or local emission  limits.  For example,
 the State of Missouri imposed a 0.7852 Ib/ton emission  limit  on the
 commenter's facility.
      Response:  The baseline control level assumed in analyzing the
 impacts of any new source performance standard represents the average
 State or  local control level imposed on lime plants  throughout the
 United States.  Research of State and local regulations indicated  that
 1.0 Ib/ton of limestone  feed generally represented the baseline control
 level imposed on new lime plants.  Some plants may be subject to stricter
 State or  local limits while other plants are subject to more  lenient
 limits.
 2.1.5  Executive Order 12291
     Comment:   One commenter (IV-D-6) asserted that  the analysis called
 for by Executive Order 12291 should be done since the health benefits of
 new source performance standards for lime plants would not be significant.
 The commenter believes that the regulation of lime plant emissions,
 based on the absence of significant health benefits,  would amount to
 "regulating for regulation's sake."
     Response:   Executive Order 12291 directs that the costs and benefits
 of major rules be analyzed.   A rule is considered to  be a major rule if
 (1) the  national,  annualized compliance costs total more than $100  million
 in the fifth year following adoption of the rule;  (2) the standards
cause a  major increase in prices or production costs; and (3) the standards
cause significant adverse effects on domestic competition, employment,
investment,  productivity, innovation, or  competition  in foreign markets.
     The  amended standards  would reduce particulate matter emissions
from a rotary  lime kiln  by  about 40 percent below those allowed under a
                                  2-5

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typical SIP.  This would result in a particulate matter emission reduction
of about 1,300 tons industry wide in the fifth year following proposal.
This estimate is based on a projected growth of 20 new, modified, or
reconstructed rotary lime kilns in 5 years.   The solid waste generation
industry wide in the fifth year would increase by about 0.2 percent
relative to that under a typical SIP.  There would be no adverse water,
noise, or radiation impacts associated with these standards.  The fifth
year annualized cost of the incremental emissions reduction from a
typical SIP baseline to the level of the standards, including depreciation
and interest, would be about $0.5 million (1981 dollars) assuming all
rotary lime kilns use fabric filter controls.   Thus, the new source
performance standards for lime plants are not a major rule as defined by
the Executive Order and, therefore, no regulatory impact analysis is
required.
2.1.6  Health Impacts
     Comment:  One commenter (IV-D-6) stated that new source performance
standards are based on an analysis of economic, environmental, energy,
and health impacts.  The commenter believes that this analysis should
focus on health effects in determining the value of a standard.   Because
there is little evidence of adverse health effects, a legislative policy
decision should conclude that national ambient air quality standards are
sufficient to regulate emissions from lime plants.
     The commenter stated that particulate emissions from the lime
industry do not harm man and may be beneficial since they tend to neutralize
acid aerosols and react quickly with water vapor and carbon dioxide to
form carbonates.  The commenter cited evidence to show that lime emissions
do not pose adverse health impacts.  The commenter also stated that the
analysis supporting the new source performance standards did not point
to any harmful effects from lime plant emissions but instead pointed to
the alleged harmful effects of particulate matter in general.
     The commenter contended that the risk assessment of particulate
emissions is based on the toxicity of certain particulate species.   The
commenter noted that toxicity is correlated to chemical composition.
The commenter contended that the chemical components of lime plant
emissions are nontoxic and nonacidic.
                                  2-6

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      The  commenter concluded that the  lime  standard  should  be  removed
 based on  the  lack of evidence that  lime emissions  cause  significant
 health effects.
      Response:  The Clean Air Act directs that  new source performance
 standards  are  to be developed for an industry if ".  .  .  it  causes, or
 contributes significantly to, air pollution which  may  reasonably be
 anticipated to endanger public health  or welfare."   Particulate matter
 is a  criteria  pollutant, and its impact on public  health and welfare is
 well  documented.  This issue was addressed fully in  the background
 materials  associated with the original promulgation  and was addressed by
 the Court.  The Court stated:
           We think the danger of particulate emissions' effect on
      health has been sufficiently supported in  the Agency's .   . .
      previous  determinations to provide a rational basis for the
      Administrator's finding in this case.  Moreover, whatever its
      impact on public health, we cannot say that a dust "nuisance"
      has  no impact on public welfare.  (627 F.2d at 431, n.  48.)
 Based on  Congressional intent with respect to the  Clean Air Act, the
 Court stated that it ".  .  .  could not  say that  the Administrator's
 determination  is arbitrary,  even if the dust were  shown innocuous to
 public health."  For these reasons,  new source  performance standards for
 lime manufacturing plants are considered reasonable.
 2.2  APPLICABILITY DATE
     Comment:   Several commenters (IV-D-2, IV-D-5,  IV-D-6) believe that,
 because several of the Court-defined issues were amended by the September 2,
 1982, proposal, the appropriate effective date  for the new source
 performance standards should be either the date of proposal  or of promulga-
 tion of the amendments.
     One commenter (IV-Q-6)  stated that Congress intended to limit the
 period between proposal  and  promulgation to 90 days to reduce  the
 uncertainty of companies  waiting to  commence construction.   The applica-
 bility date of May 1977  would prolong this period to  5 years.   Such a
prolonged period of uncertainty goes far beyond Congressional  intent.
     The commenter also  requested that the proposed amendment,  which
 relaxes the rotary lime  kiln particulate matter emission limit from
0.15  kg/Mg (0.30 Ib/ton)  to  0.30 kg/Mg (0.60 Ib/ton), be treated in the
                                  2-7

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same manner as other amendments to new source performance standards for
electric utility steam generators and petroleum storage tanks (i.e., the
amendments should apply from the date of proposal of the amendments;
they should not apply retroactively to the date of proposal of the
original standards).
     Response:  Section lll(a)(2) of the Clean Air Act clearly states
that "new sources" subject to new source performance standards are those
sources which commence construction or modification after proposal of a
standard of performance.   New source performance standards for lime
manufacturing plants were proposed on May 3, 1977 (42 FR 22506). and
sources constructed or modified after that date are, therefore,  new
sources subject to the standard.
     The fact that standards are remanded does not exempt those sources
constructed or modified prior to the proposed remand response.  United
States v.  City of Painesville.  644 F.2d 1186 (6th Cir.  1981), cert. den.
102 S.Ct.  392 (1981).   Similarly, revision of standards to more accurately
reflect the performance of best demonstrated technology in response to a
remand does not exempt sources.   See, Portland Cement Association v.
Train, 513 F.2d 506 (D.C.  Cir.  1975), cert.  den.  423 U.S.  1025 (1975).
Finally, the fact that promulgation is delayed until well  after the
original proposal does not, in  itself, exempt sources.   See,  Commonwealth of
Pennsylvania v.  EPA, 618 F.2d 991, 1000 (3rd Cir.  1980).   (See docket entry
IV-B-4 for further discussion.)
     Comment:   One commenter (IV-D-1) stated that applying the amended
new source performance standards to all sources that commenced construction
after the original Federal Register proposal of May 3,  1977,  would be
consistent with the intent of Section 111 of the Clean Air Act,  Congress,
and judicial decisions.   The commenter contended that if the  applica-
bility date were changed to September 2,  1982, those lime plants that
commenced construction or modification between May 3, 1977, and  September 2,
1982, would operate under the original new source performance standards
emission limitation (0.30 Ib/ton of feed), while plants that  commenced
construction after September 2,  1982, would operate under the amended
new source performance standards (0.60 Ib/ton of feed).   This would
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place  an  unfair burden on older plants and could place  the  older  plants
at a competitive disadvantage compared to plants constructed  after
September 2, 1982.
     [This commenter later requested that the above comment letter  be
removed from the docket because the comment was submitted in  error
(IV-Q-9).  The commenter stated that the lime new source performance
standards should apply only to sources that commence construction after
September 2, 1982.  However, items entered into the docket  cannot be
removed.  Section 307(d)(4)(8)(i) provides in part that "[p]romptly upon
the receipt by the agency, all written comments and documentary information
on the proposed rule received from any person for inclusion in the
docket during the comment period shall be placed in the docket."  A
memorandum to the docket can be submitted to explain an error or to
amend a document.]
     One commenter (IV-G-8) asked what the effects of changing the
applicability date would be.
     Response:   The effect of a September 2, 1982, applicability date is
not quite as the commenter describes.   Rather, if the applicability date
were changed to September 2,  1982, lime plants that commenced construction
or modification between May 3, 1977, and September 2,  1982,  would operate
without any applicable new source performance standards.  This action,
although different from that contemplated by the commenter,  would place
lime plants that installed control equipment to meet the original  new
source performance standards  at a competitive disadvantage compared to
lime plants that did not make such an effort to comply with the standards.
More specifically, the principal  effect of a September 2,  1982, applic-
ability date would be to relieve those plants which chose  not to install
control technology that would meet the new source performance standards
from the requirement to do so.   In the preamble to the proposal,  comments
were solicited on  the applicability date in response to preproposal  industry
comments alleging  that unreasonable impacts would occur at some lime plants
if the original  proposal  date remained applicable.   Each comment received
during the public  comment period was considered,  and no unreasonable impacts
associated with  the original  applicability data were identified.   Therefore,
the applicability  date of the standards remains  May 3,  1977.
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2.3  BEST DEMONSTRATED TECHNOLOGY
2.3.1  Use of Wet Scrubbers
     Comment:  Two commenters (IV-F-1/IV-D-7, IV-D-6) stated that the
choice of wet scrubbers to control particulate emissions from new rotary
lime kilns is reasonable.   The first commenter (IV-F-1/IV-D-7) states
that a wet fan scrubber on a rotary lime kiln at a new plant subject to
the new source performance standards should be considered best demonstrated
technology because it is achieving the 0.60 Ib/ton mass emission standard.
     The second commenter (IV-D-6) stated that two kilns currently under
construction should be exempt from the NSPS because:   (1) scrubbers are
not considered to be best demonstrated technology and this company had
no choice other than to install  scrubbers,  and (2) the scrubbers used
for their two new kilns are designed to meet the State emission limit
rather than the new source performance standards because the commenter
believed that no new source performance standards were in effect.   The
commenter maintains that there was not enough space to install an ESP or
baghouse at this location; there was only sufficient room to install a
scrubber.   Rearranging the production area  to accommodate a baghouse or
ESP would be unreasonably expensive.  Further, baghouses were not considered
suitable for these kilns because the necessary precooling of the kiln
exhaust gas stream would preclude recovery  of carbon dioxide (C02).
Electrostatic precipitators were not considered suitable because it was
believed that there would be explosion hazards associated with their
application to rotary lime kilns.   The commenter further maintains that
in the circumstances prevailing at this company, wet scrubbers must be
declared the best demonstrated technology.   Finally,  the commenter
states that operating the wet scrubbers to  achieve emissions of 0.60 Ib/ton
would require an energy expenditure equivalent to about $1,400 per ton
of additional particulate matter removed beyond the State requirement of
approximately 0.78 Ib/ton.  This commenter  believes that this additional
cost is unreasonable.   Therefore,  the commenter believes rotary lime
kilns controlled by wet scrubbers should be exempt from the new source
performance standards.
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      Response:   The new source performance standards do not require
 Installation of any specific emission control  technology.   Plant operators
 may install  any control  device which meets the numerical  emission limits
 included in  the new source performance standards.   Under  Section 111 of
 the Clean Air Act,  however,  standards of performance must  be based on
 the degree of emission reduction achievable through application of the
 best technological  system of continuous  emission reduction (taking into
 consideration the  cost of achieving  such emission  reduction, and any
 nonair  quality  health  and environmental  impact and energy  requirements)
 which has been  adequately demonstrated.   Analysis  of the performance,
 costs,  and other impacts  associated  with the use of a wide variety of
 emission control  technologies  indicates  that fabric filters and ESP's
 represent best  demonstrated  technology for the control  of  particulate
 matter  emissions  from  rotary lime  kilns.   Wet  scrubbers are not considered
 best demonstrated  technology because  of  the high energy costs  associated
 with their use.  However,  venturi  scrubbers have demonstrated  the  ability
 to  achieve the  level of the  proposed  standards  and  can  be  used to  meet
 the  standards.   A  company  may  choose  to  use a  scrubber  to  meet the
 standards  if  it  is  willing to  incur the  high operating  costs that would
 be  associated with  the pressure  drop  necessary  to meet the  standards.
      In  investigating  and  considering  the  situation  described  by second
 commenter, it was  found that four  kilns  have been removed  and  that  two
 larger  kilns are to be installed in their  place.  The four  kilns were
 bounded  at each end with  feedstock and product  handling facilities.
 Because  the new  kilns are  longer than  the  space  that the four  old kilns
 had  occupied, the product  handling facilities were moved back  to accommodate
 the  additional length of the new kilns.  The product handling  facilities,
 however, could have been moved to accommodate the space requirements of
 the  new  kilns with fabric  filters or ESP's  instead of just being moved
 to accommodate the space requirements of the new kilns with  scrubbers.
     The inlet gas stream to baghouses can be precooled in a variety of
ways.  This commenter noted that an air-to-air heat exchanger would be
 suitable for  cooling the inlet gas stream for the purpose  of C02 recovery
but was  not considered because of space limitations.  As explained
above, space  was not a crucial limitation.  Experience with an ESP on a
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lime kiln in a similar industry indicates that the potential for an
explosion is eliminated if automatic controls are installed that permit
the exhaust to bypass the ESP when the kiln malfunctions and combustible
gases are passed through the kiln.  In conclusion, this company could
have used a baghouse or ESP to control emissions from the new kilns.
Consequently, the standards do not include an exemption for rotary lime
kilns which use wet scrubbers to control particulate matter emissions.
2.4  MASS EMISSION STANDARD
2.4.1  Mass Emission Level
     Comment:  One commenter (IV-D-3) stated that the amended standard
of 0.30 kg/Mg (0.60 Ib/ton) is not justified by the data base and concludes
that the appropriate emission standard for lime kilns is 0.25 kg/Mg
(0.50 Ib/ton).   The commenter pointed out that in setting the original
standard, the emission limit was about 6 percent greater than the tested
emissions from the worst performer of the four plants included in the
data base.   The amended standard is about 30 percent greater than the
worst-case controlled emission level  of the five plants now included in
the data base.   The commenter concluded that,  absent further justification,
the amended particulate matter emission standard is  too lenient and
should be reduced from the proposed level of 0.30 kg/Mg (0.60 Ib/ton) to
0.25 kg/Mg (0.50 Ib/ton).
     Response:   The precise level  at  which a standard should be set to
reflect use of best demonstrated technology is a matter of judgment.   A
level  of 0.25 kg/Mg (0.50 Ib/ton)  could have been selected for the final
standard, but the margin of safety would have  been very small  [about
5 percent based on a 0.25 kg/Mg (0.50 Ib/ton)  standard at Plant A].   It
is reasonable to provide a higher  margin to ensure that all  new sources
that install  the emission control  technology upon which the final  standards
are based will  be able to meet the standard.   Establishing the standard
at 0.30 kg/Mg (0.60 Ib/ton) provides  a margin  that is somewhat larger
and still ensures that best demonstrated technology  will  be installed.
     Comment:   Two commenters (IV-D-5,  IV-G-7) stated that the standard
of 0.30 kg/Mg (0.60 Ib/ton) does not  consider  the addition of  coal
emissions to  total  emission rates.  The demand for burning coal  to
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manufacture lime is growing rapidly and should be considered when setting
the standard.   Therefore, the commenters support a 0.5 kg/Mg (1.0 Ib/ton)
emission limit.
     Reponse:   Three of the kilns tested during development of the new
source performance standards were coal-fired units.   Thus, the measured
emissions included emissions generated by the combustion of coal in the
kilns.  Plants A, B, and E have coal-fired kilns, and their average
emission rates were 0.23, 0.11, and 0.14 kg/Mg (0.46, 0.22 and 0.28 Ib/ton),
respectively.   Therefore, the achievability of the standards is adequately
demonstrated for coal-fired rotary lime kilns.
     Comment:   One commenter (IV-D-2) believes that the emission limit
for rotary lime kilns may be unachievable and that the appropriate limit
is 0.50 kg/Mg (1.0 Ib/ton) of feed.  The commenter has applied typical
baghouse and ESP collection efficiencies (99.7 and 97 percent, respectively)
to emission factors from "Compilation of Air Pollutant Emission Factors"
(AP-42) and determined that controlled rotary lime kiln emissions from a
baghouse would be 0.29 kg/Mg (0.57 Ib/ton) and from an ESP would be
2.85 kg/Mg (5.7 Ib/ton).  The commenter notes that the AP-42 controlled
lime kiln emission factor is 0.50 kg/Mg (1.0 Ib/ton) of product and
states that the new source performance standards require a lower value.
     The commenter presented information about the allowable emission
rates in the States of Ohio and Michigan.  The commenter claims that the
new source performance standards would require a substantial decrease in
these allowable rates and would require a large investment.  The commenter
notes that the costs to reduce emissions increase as the emissions are
reduced to zero.  Therefore, the commenter believes that a standard of
0.50 kg/Mg (1.0 Ib/ton) of feed would provide cleaner air and would be a
compromise between existing and proposed allowable emissions.
     Response:  Section lll(a) of the Clean Air Act requires that standards
of performance reflect "... application of the best technological
system of continuous emission reduction which (taking into consideration
the cost of achieving such emission reduction, and any nonair quality
health and environmental impact and energy requirements) the Administrator
determines has been adequately demonstrated."  The lime plant new source
performance standards are based on performance tests of plants that
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incorporate the best technological systems of control.  The costs of the
proposed standard were estimated for typical facilities and are considered
to be reasonable.  In remanding the lime new source performance standards,
the Court did not question the technological basis for the standard nor
the economic, energy, or environmental analyses.
     AP-42 emission factors are used to project or estimate typical
emissions.   AP-42 values are often based on estimates or incomplete
data.  In contrast, the new source performance standards are based on
actual tests of well-designed and well-operated modern control equipment,
and the data from the tested lime plants support the achievability of
the amended new source performance standards.   Consequently, the standard
has not been increased to 0.50 kg/Mg (1.0 Ib/ton).
     Comment:   One commenter (IV-0-2) agrees that baghouses and ESP's
can be designed to accommodate a great range of particle sizes and high
gas velocities.   However, the commenter notes that particle resistivity
changes as  the moisture content and temperature of the exhaust gas
change and that any operating variable that will alter temperature or
moisture content has a great effect on the collection efficiency of the
ESP.   He further notes that an ESP designed to handle high temperature
gases cannot be operated efficiently at low temperatures.
     Response:   The writer's comments about sizing, moisture content,
and temperature of the gas stream relative to ESP's are correct.   However,
they were considered and accounted for in the development of the new
source performance standards as discussed in the background information
document.   The test data used in setting the level  of the standard show
that properly designed and operated control  devices can achieve the
standard.
2.4.2  Stone Feed
     Comment:   One commenter (IV-F-1,  IV-G-2)  stated that a few plants
produce a few thousand tons each year of a product called "dead-burned
dolomite."   Dead-burned dolomite is a sintered or double-burned form of
dolomitic quicklime,  which is further stabilized by the addition of iron,
that is chemically inactive and is  employed primarily as a refractory for
lining open-hearth steel  vessels.   The feed material  for this  product is
usually about 80 percent dolomitic  limestone and 20 percent iron oxide
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(mill  scale).   The commenter noted that while dead-burned dolomite is a
lime product,  its components are not included within the stone feed
definition in  the regulation.   The commenter, therefore, questioned the
reasonableness of the definition of stone feed and requested that the
definition be  changed to include iron-oxide additives used in the production
of dead-burned dolomite.
     Response:  It is appropriate to include the iron-oxide additive in
the definition of stone feed because the iron becomes part of the final
product.   Therefore, the definition of stone feed has been changed to
include mil 1  scale.
2.5  THE VISIBLE EMISSION STANDARD
2.5.1  Achievability of the Opacity Standard
     Comment:   One commenter (IV-F-1, IV-G-6) stated that a 10 percent
visible emission standard is not achievable on a continuous monitoring
basis.   The commenter reviewed a study of rotary lime kiln dynamics,
particle composition, and particle size distribution at the control
device inlet and concluded that long-term variation in visible emissions
would be expected during normal kiln operation and that visible emissions
data gathered  to develop the standard do not reflect this variation.
The study presented the theory that this variation was caused by unique
properties of  the hydrate particles generated prior to the baghouse that
are smaller than the other dust particles generated in the kiln.   The
commenter stated that the visible emission standard should be attainable
by a majority  of lime plants,  that it should consider the vagaries of
normal  kiln practice, and that it should be commensurate with the mass
emission standard (IV-G-6, p.  38).   In the absence of visible emission
data taken from a number of kilns over a period of a year, the commenter
believes that  a reasonable standard would be 20 percent opacity.
     A second  commenter (IV-D-5) stated that, given the variable conditions
inherent with  lime and fly ash stack plumes, a visible emission limit of
20 percent opacity would be more realistic than the visible emission
limit of 10 percent opacity.   The commenter contended that a visible
emission limit of 10 percent opacity would result in constant conflict
between EPA inspectors and plant operators, costing the operators $5,000
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to $7,000 per stack test to prove compliance with the mass emission
standard.
     A third commenter (IV-F-1, p. 40) stated that even though the
0.30 kg/Mg (0.60 Ib/ton) mass emission standard was based on EPA stack
tests, none of the opacity data given in Table 9 of the preamble to the
proposed revision (47 FR 38852) were obtained when mass emissions were
actually at the 0.30 kg/Mg (0.60 Ib/ton) level.   The commenter stated
that the highest mass emission level recorded during testing was 0.12 kg/Mg
(0.23 Ib/ton).
     Response:   Two points mentioned by these commenters require
clarification.   First, compliance with the visible emission standard is
not determined by continuous monitors but rather with Reference Method 9.
As explained in Section 2.6 of this document, continuous monitoring data
would be used to determine if the rotary kiln control  device has been
properly operated and maintained.   Second, the highest mass emission
level for a 3-test average recorded during testing was 0.23 kg/Mg
(0.46 Ib/ton),  not 0.12 kg/Mg (0.23 Ib/ton).
     The first commenter's study of rotary lime kiln dynamics does
provide some support for his theory that hydrate particles are formed
prior to the baghouse inlet.   The study does  not,  however, include any
data about particle characteristics or concentration at the baghouse
outlet, and no Reference Method 9 visible emission data were submitted.
The absence of these data does not,  in itself,  invalidate the commenter's
theory or conclusion.   However,  existing fabric filter theory and studies
have demonstrated that particle characteristics  and concentrations at
fabric filter outlets are invariant over a broad range of fabric filter
inlet particle characteristics and concentrations.   In addition,  the
extensive data base supporting the visible emission standard (discussed
below) covers the range of particle characteristics,  concentrations, and
kiln operations  expected in the industry and  demonstrates the achievability
of a standard more stringent than that suggested by the commenter.
Thus, the study's conclusions  cannot be corroborated.   Moreover,  during
the study,  the  fabric filter controlling emissions from the kiln under
study was operated at air flows  ranging from  27  to 62  percent greater
than design values.   This causes  actual  air-to-cloth ratios that are
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higher than design values.   The bag fabric will be stressed more than it
was designed for and uncaking may occur, which could provide less than
the design control efficiency.   Thus, the particle behavior observed
during the study may not represent behavior that would occur if the
control device air flows were at design specifications.
     In contrast to this study, the promulgated lime plant visible
emission standard is supported by over 1,200 Reference Method 9 visible
emission tests from six rotary lime kiln control device exhaust stacks
for which Reference Method 5 mass emission data were gathered.   Each of
these Reference Method 9 visible emission tests consists of 24 individual
visible emission observations made during a 6-minute period.  The Reference
Method 5 test data include individual tests where the mass emission levels
were as high as 0.29 kg/Mg (0.58 Ib/ton).   The highest raw visible emission
data point is 6.7 percent.   After normalizing the visible emission data to
a 3.0-meter (9.8-foot) stack diameter, more than 71 percent of the Reference
Method 9 visible emission data exhibit opacities of 0 percent,  and
99.7 percent exhibit opacities of less than 10 percent.  Only 4 of the over
1,200 test data points exceed 10 percent opacity, and the maximum value is
10.6 percent opacity.
     The data base that supports the final standard differs in one respect
from the data base that supports the proposed standard.  In October 1983,
mass and visible emission data from an NSPS-subject kiln performance test at
the Tenn-Luttrell Lime Company were submitted.   The Tenn-Luttrell data show
that the NSPS mass emission limit was achieved but the visible emission
limit was not—two of the 6-minute average opacities were 10.6 percent and,
thus, exceeded the standard.   The visible emission data submitted by Tenn-
Luttrell cannot be normalized to an equivalent stack diameter for comparison
with the data from the kilns in our data base.   This is because the
Tenn-Luttrell baghouse compartments exhaust cleaned gases into a continuous
roof monitor or monovent before the gases are exhausted in turn to the
atmosphere and can be observed.  The visible emission plume that exits from
the monovent does not have a fixed diameter and does not exit through an
aperture of known diameter such as a stack or stubstack.   Without a known
and constant plume diameter,  the opacity values recorded for the Tenn-
Luttrell baghouse cannot be normalized, and we must rely on the actual data.
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     The Agency analyzed the Tenn-Luttrell test report and  investigated  the
NSPS-subject  rotary kiln and baghouse.  This analysis of the participate
matter emission test methods and procedures followed and data collected
(IV-B-5) indicates that these methods and procedures are adequately docu-
mented, conform to the appropriate reference methods, and are calculated
properly.  This is also the case with the average opacity values calculated
for the visible emission data.   However, an examination of  the visible
emission observer's notes accompanying each 15-second observation indicates
that about two-thirds of all of the recorded opacities originate in just 4
of the baghouse's 10 compartments.   This could be an indicator of either
poor air flow distribution in the baghouse or leaking bags  in the
four compartments.
     To investigate this problem further, EPA staff visited this rotary
kiln and baghouse (IV-B-8).   Plant personnel  agreed that there might be
poor distribution of air flow in the compartments.   Discussion with plant
personnel served to highlight other problems  that have hampered proper
visible emission observations of the baghouse.   It was also learned that
the visible emission data contained in the test report do not represent
constant visible emissions from the baghouse.   Rather, during the
performance test,  visible emissions were evident only when each compartment
was returned to operation after having been cleaned.   At all other times,
the baghouse had no visible emissions.   However, from a design perspective,
there is little to distinguish  the  components  of this baghouse from those of
other baghouses that form our data  base and constitute best demonstrated
technology.   Moreover,  plant personnel  have been aggressive and thorough in
their attempts to  rectify all  perceived problems with their baghouse.
     On balance,  then,  the Agency has concluded that this baghouse should
not be rejected as unrepresentative of best demonstrated technology.
Therefore,  although 99.7 percent of 1,247 average opacity values  support a
visible emission standard of 10 percent,  it is  the  Agency's judgment that
the level  of the standard should accommodate  the 10.6 percent average
opacity value that is  the highest observed opacity  from the Tenn-Luttrell
test report and the four data points  from two  plants  in the data  base of
tested plants that exceed 10 percent  (the maximum is  a 10.6 normalized
opacity).
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      Establishing  the  visible  emission  standard  at  15  percent  opacity
 would ensure  that  the  visible  emission  limit  is  achievable,  and  it  would
 ensure consistency with our  response  to the remand  of  the  portland
 cement visible emission standard,  in  which the final standard  was
 established based  on consideration of the complete  range of  data from
 best  demonstrated  facilities.
      The  relevant  variables  upon which  opacity depends  are stack diameter,
 particle  size, particle shape, particle refractive  index,  particle
 density,  and  concentration.  Lime manufacturing  plant  stack  diameter was
 accounted for by normalizing the raw  opacity  data to the largest stack
 diameter  likely to be  installed in this industry.   The  particle charac-
 teristics at  the tested plants are representative of the industry.
 Although  there may be  some variation  in the particle characteristics of
 the emissions from rotary lime kilns, the tested plants cover  the variation
 likely to be  found in  the industry.   In setting  the visible  emission
 standard,  any variation is taken into account by selecting the highest
 6-minute  average opacity and then incorporating  a reasonable margin of
 safety.   The  data base, therefore, adequately supports  the selection of
 a 15  percent  visible emission standard.
      Comment:   One commenter (IV-G-7) stated that there are  some plants
 that  can  meet the mass emission standard but cannot comply with the
 visible emission standard of 10 percent opacity.   The commenter stated
 that  the  mass emission limit is the real standard and that visible
 emissions  are only a rough indicator and should include a margin of
 safety to  account for  lime plants that will  have problems complying with
 the visible emission standard.   The commenter concluded that a 20 percent
 opacity standard would include this margin of safety.
      The  commenter also submitted two stack test reports dated July 1975
 and December 1978 and included photographs of visible emissions for two
 baghouses during the December test.   The commenter stated that the
 emission  rates for the 1975 and 1978 stack tests  were 0.34 and 0.31 Ib/ton,
 respectively,  but visible  emissions were near 20  percent opacity.   The
commenter concluded that the plant could comply with the mass emission
 standard but could not meet the visible  emission  standard of 10 percent
opacity.
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     Response:  Although the kilns and baghouses were not designed to
comply with the mass emission and visible emission standards of the new
source performance standards, the 1978 Reference Method 5 test report
indicates that mass emissions from the baghouses were less than 0.6 Ib/ton.
However, no Reference Method 9 visible emission data were taken during
the mass emission tests to substantiate any problems.  The photographs
of visible emissions from the baghouses appear to indicate visible
emissions during the mass emission tests.   However, accurate visible
emission readings cannot be determined from these photographs, and the
plume evident in the photograph appears to be a combination of two
plumes from the two adjacent baghouses.  Therefore, the information
presented by the commenter does not provide a basis for revising the
visible emission standard.   As discussed previously,  the visible emission
standard of 15 percent opacity is based on over 1,200 Reference Method 9
visible emission tests, 99.7 percent of which exhibited less than 10 percent
opacity, and none of which exceeded 11 percent opacity.
     Finally, as described in Section 2.5.5 of this document,  if this
facility were subject to the new source performance standards  and met
the mass emission limit but not the visible emission  limit,  Section 60.11(e)
of the General Provisions of 40 CFR Part 60 ensures that it would be
treated equitably.   This provision, upon demonstration of certain criteria
(see Section 2.5.5), permits a facility that meets the mass  emission
standard to obtain an individual  visible emission standard tailored to
its unique circumstance.  This individual  standard is automatically
approved once the facility demonstrates that it meets the requirements
of Section 60.11(e).
2.5.2  Correlation of Visible Emission Data With Mass Emission Data
     Comment:   Two commenters (IV-F-1) assert that no correlation between
mass emissions and visible emissions is obvious either from data supporting
the visible emission standard or from data obtained at one commenter's
company.   The commenters conclude that the visible emission  standard
should be relaxed to a value more representative of similar  processes
(i.e.,  the 20 percent visible emission standard used  by most States for
chemical  and mineral  kilns).
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      Response:  The comment about the correlation between  mass  and
 visible emissions requires clarification.   In general,  a correlation
 does  exist between particulate matter and visible emissions.  However,
 this  correlation is demonstrated not with mass emission data  (i.e.,
 pounds of particulate matter per ton of  feedstock) but  rather with data
 on the particulate matter concentration  in  the exhaust  gas  stream from
 the control device.
      There are situations in which it is difficult to establish a correla-
 tion  between particulate matter and visible emissions.  Such would be
 the case when much of the visible emission  data consist of  visible
 emission observations of zero percent opacity.  The rotary  lime kiln
 visible emission data present such a situation because  71 percent of the
 over  1,200 Reference Method 9 test results  are zero percent opacity.
 Both  because 99.7 percent of the Reference Method 9 test data are below
 10 percent opacity and because of the high proportion of 6-minute averages
 that  are equal to zero, this situation does not impugn  the visible
 emission standard.
      Although the test-program that developed the data  base was not
 designed to establish a single invariant correlation (as Portland Cement,
 986 F.2d 375 [1973], points out, such a correlation is  not required), an
 analysis of the visible emission data with respect to the particulate
 matter emission data has been performed, and a statistically significant
 correlation has been established.   Furthermore,  a 95 percent confidence
 interval  was established on the regression line arising from the correlation,
 and this interval  indicates that the maximum expected average opacity
 for the period of a test is less than 10 percent.   The  regression analysis
 does  not include data from one observer at Plant C because this observer's
 opacity readings were not recorded as required by Reference Method 9.
As discussed in the response in Section 2.5.1, the analysis also does
not contain the data that were obtained recently from the Tenn-Luttrell
 Lime Company.   For  all  of the above  reasons and because of the rationale
provided in Section 2.5.1,  a rotary  lime kiln visible emission standard
of 15 percent opacity is expected  to be achievable.   Consequently,  the
visible emission standard has not  been  relaxed to  20 percent opacity as
had been  requested  by the commenter.
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2.5.3  Effect of Particle Size on Visible Emissions
     Comment:   One commenter (IV-F-1) presented four general  comments
about the effect of particle size on visible emissions.   He stated that
actual information on particle size distribution after the control
device (i.e.,  particle size distribution in the outlet gas stream) was
not examined.   He also stated that particle size distribution before the
control device is not a good indicator of the particle size distribution
after the control device.   The commenter believes that the analysis sup-
porting the new source performance standards was based on the assumption
that the particle size distribution after the control  device  does not
include a significant number of particles whose size affects  light
scattering and, hence, visible emissions, and that this assumption is
false.  In addition, the commenter believes that visible emission levels
are not a consistent predictor of a source's failure to comply with the
mass emission level.
     Response:  It is correct that inlet (to the control device) particle
size distribution is not indicative of outlet particle size distribution
and that it is outlet particle size distribution that affects visible
emissions.   The analysis supporting the new source performance standards
does not assume otherwise.   The significant number of particles whose
size affects light scattering is taken into account through the standard-
ized procedures of Method 9 for observing visible emissions and through
the empirical  approach followed in setting standards.   To account for
possible variation in outlet particle size, the visible emission limit
is based over 1,200 Method 9 6-minute average visible emission observa-
                        i
tions during mass emission tests at plants that are representative of
the industry, normalized to a common path length of 3.0 m (9.8 ft).
(See Section 2.5.1.)  As discussed in the port!and cement remand response,
compliance with the opacity limit is a good indication of compliance
with the mass emission standard.
2.5.4  Plant D Tests
     Comment.   One commenter (IV-F-1) quoted from the proposed preamble
(47 FR 38854) as it pertained to test data from a kiln at Plant 0:
"Thirty-two percent of the particles emitted from this kiln were in the
size range that is expected to produce the greatest light scattering,
i.e., less than 2 microns.   And yet Plant 0 easily achieved the promulgated
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 opacity  limit  and  the  mass  emission  limit."   The  commenter stated that
 the  above  condition  was  achieved  because  the  plant  operator was  requested
 to  increase  the  operating temperature  above normal  and decrease  the
 production rate  of the kiln to  70 percent of  design capcity during the
 emission test  at this  facility.
      Response:   The  plant operator at  Plant D was not  requested  to
 increase the operating temperature above  normal or  to  decrease the
 production rate  of the kiln.  The three test  runs were conducted at 100,
 106,  and 86  percent  of design capacity.
      For the test  in question,  the inlet  control  device temperature
 ranged from  372° to  378°C (702° to 712°F)  for the three test runs  performed
 on three successive  days.   Near the  end of the first test,  the ESP inlet
 temperature  had  increased to 377°C (710°F), at which time  it was  noticed
 that  visible emissions from the stack were improving.   The  plant  chemist
 was asked  if he  could  maintain the inlet  temperature between 371°  and
 377°C (700°  and  710°F) for  the second test, which would start the  next
 day.  The  next day the visible emissions were 0 percent opacity,  and the
 process operator stated that the  ESP inlet temperature  had  not dropped
 below 371°C  (700°F)  for the  last  16  hours.  In an earlier test program
 at this facility,  during which no  requests were made to maintain  any
 particular temperature, the  inlet  control device temperature  ranged from
 362° to 385°C (683°  to 725°F).   Consequently,   the fact  that  the  inlet
 temperature  was between 371° and  377°C (700°  and 710°F)  for  the test in
 question did not cause kiln operation outside  of normal  operating  conditions.
 2.5.5  Specific Affected Facility  Visible Emission  Standards
     Comment:  Two commenters (IV-F-1) stated  that  variance procedures
 afforded lime plants that meet the mass emission standard but do not
 meet the visible emission standard would be burdensome,  time  consuming,
 and expensive.   The commenters  supported their statements by  asserting
 that, as a purely  economic  issue,  the $10,000  cost of proving compliance
 and the possibility of incurring this cost every quarter would place an
 undue burden  on the industry.
     Another  commenter (IV-F-1)  stated that variances for affected
 facilities  that meet the mass emission limit but do  not meet the  visible
emission limit  imply a lack  of  faith  in the visible  emission standards.
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     Another commenter (IV-Q-4) does not endorse the proposed procedure
of requiring a lime plant to obtain a variance for the visible emission
standard when the mass emission standard is being met and proposes that
a visible emission standard of 20 percent opacity would be more appropriate.
The commenter disagrees that new lime plants will have stack diameters
less than 3.0 m (9.8 ft).   This company states that it has a new plant
with a stack larger than 3.0 m (9.8 ft) in diameter.
     Response:   The procedure referred to by the commenters does not
involve a variance.  Rather, Section 60.11(e) 40 CFR 60 provides that
owners or operators of any affected facility from any source category
that meets the mass emission standard but does not meet the visible
emission standard may apply for an individual visible emission standard
tailored to the unique circumstances of their facility.  This standard
is good for the life of the affected facility and is automatically
approved upon demonstration that:  (1) the facility is in compliance
with the mass emission standard; (2) the facility and associated air
pollution control equipment were operated and maintained in a manner to
minimize the opacity of emissions during the performance tests; (3) the
performance tests were performed under the conditions approved by the
Administrator; and (4) the facility and associated air pollution control
equipment were incapable of being adjusted or operated to meet the
applicable opacity standard.
     There are no costs associated with this procedure beyond those of
the initial performance test and report, which are required within
180 days after startup (General Provisions § 60.8).  This cost is typically
$10,000 and constitutes a small fraction of a plant's annual operating
budget.  In view of the environmental benefits associated with the
performance test procedure, the $10,000 cost is considered reasonable.
     The provisions of 40 CFR 60.11(e) do not reflect a lack of confidence
in the rotary lime kiln visible emission standard.  Quite the contrary,
the extensive data base supporting the visible emission standard indicates
that recourse to these provisions will be needed rarely, if ever.
     The commenter1s belief that a standard of 20 percent opacity would
be more appropriate is not supported by any data.  As discussed previously,
analysis of over 1,200 Reference Method 9 visible emission test results
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collected during development of the visible emission  standard  support  a
standard of 15 percent opacity.
     Available stack diameter data indicate that  lime plants are  unlikely
to be constructed with stacks greater than 3.0 m  (9.8 ft)  in diameter.
Although one stack with a diameter greater than 3.0 m (9.8  ft) was  found
in a survey of 16 new plants, the trend  in the industry  is  toward smaller
stacks or roof monitors.  The one larger stack has a  diameter  of  5.0 m
(16.3 ft), but such a diameter is considered unlikely to recur.   The
opacity of visible emissions will be much lower from  the smaller  diameter
stacks than from larger stacks.
2.5.6  Reference Method 9 Accuracy and Reliability
     Comment:  Several commenters (IV-F-1) stated that the  visible
emission standard of 10 percent opacity, would be difficult to enforce.
The commenters asserted that the ±7.5 percent observational error associated
with visible emission reading is almost as high as the allowable opacity
limit.  The commenters were concerned that, because the visible emission
standard is so low, it would be possible for a transmissometer to show
compliance while a visible emission reader observes noncompliance.  The
commenters concluded that since enforcement is dependent upon visible
emission readings, the standard must make allowances  for the inherent
inaccuracies of the visible emission reading process.   The commenters
further concluded that a 20 percent opacity limit would be more reasonable
with respect to enforcement.
     Response:   The response to the portland cement plant remand discusses
in great detail the reliability and accuracy of Reference Method 9 and
accompanying certification techniques for determining compliance with
visible emission standards.   On the basis of this response, the visible
emission standard included in the new source performance standards for
Portland cement plants was affirmed by the Court on appeal  (Portland Cement
Association v.  Train,  513 F.2d 506).
     The data gathered in responding to the remand for portland cement
plants convincingly demonstrate that visible emission observers can,
with a high confidence level, read the opacity of visible emissions  to
within a positive error not exceeding 7.5 percent during single 6-minute
observations.   The error tolerance is  taken into account in the enforcement
process,  as provided explicitly by the Reference Method  9 regulations.
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     There are four categories of factors that can affect opacity:
(1) factors related to the source category and its operations, (2) factors
related to opacity observations, (3) factors considered in the determination
of compliance, and (4) factors with an insignificant or non-prejudicial
effect on apparent plume opacities.   As discussed in detail  in the "EPA
Response to Remand Ordered by U.S.  Court of Appeals for the  District of
Columbia in Portland Cement Association v.  Ruckelshaus (486  F.2d 375,
June 29, 1973)", factors in categories two, three, and four  are taken
into account in the Reference Method 9 procedures or in compliance
procedures.  The first category includes factors such as effluent con-
centration, stack diameter, mean particle size,  polydispersity of emissions,
refractive index, particle density,  and stack gas temperature.  The
factors are specific to the source  category and  its operations and are
considered in the development of visible emission standards.   Although
these factors can significantly affect the apparent opacity  of visible
emissions, the maximum expected effects of normal variations  in these
factors on visible emissions are used to ensure  that the visible emission
standard for a source category is established at a level no  more restrictive
than the corresponding concentration or mass standard.  In addition to
the above consideration of these factors, should a source have a stack
of larger than expected diameter or have other anomalous operating
conditions which preclude achieving the visible  emission standard,  the
provisions of 40 CFR Section 60.11(e) allow the  owner or operator to
petition for establishment of an individual visible emission  limit.
Thus, ample consideration of the effects of these factors is  provided.
     The use of visible emission standards is technically sound and
provides the most practical and inexpensive means to ensure  that control
equipment necessary for a source to meet mass standards is properly
maintained and operated.  Moreover,  as discussed in Section  2.5.1,  the
visible emission standard of 15 percent opacity  is based on  over
1,200 Reference Method 9 visible emission tests  performed concurrently
with the Reference Method 5 tests that support the mass emission standard.
2.5.7  Failure To Use All Data Reviewed
     Comment:  One commenter (IV-F-1/IV-G-3) believes that visible
emission data submitted by the Arizona Department of Health  Services
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were ignored.  These data demonstrate that a visible emission standard
of 10 percent opacity cannot be achieved.
     Response:  The data referred to by the commenter are for a gravel
bed filter control device.   Gravel bed filters were evaluated during the
development of the new source performance standards; however, they were
not selected as best demonstrated technology because of their high mass
emission levels and costs.   Also, the gravel bed filter is not represen-
tative of the control techniques used in the industry.   Therefore, the
test referred to by the commenter cannot be used to evaluate the achiev-
ability of the visible emission standard.
2.5.8  Miscellaneous
     Comment:  One commenter (IV-G-3) stated that National Lime Association
(NLA) representatives were assured that a visible emission standard
would be proposed commensurate with the increase in the mass emission
standard.
     Response:  The NLA was assured that the visible emission standard
would correspond to the mass emission limit, as is true for all  new
source performance standards.   After review of over 1,200 Reference
Method 9 visible emission tests that constitute the data base for the
visible emission standard,  the standard is considered to be commensurate
with the mass emission standard.
2.6  TEST METHODOLOGY
2.6.1  Isokinetic Conditions
     Comment:  One commenter (IV-F-1/ IV-G-3) stated that the mass
emission tests at Plants B and E were not within the isokinetic limits
specified by Reference Method 5.  Therefore, the commenter concluded
that the tests at Plants B and E do not adequately demonstrate the
achievability of the proposed standards.
     Response:  Sampling at probe tip velocities equal  to the gas stream
velocity is a condition known as isokinetic sampling.   Errors in measured
concentrations may occur under conditions of nonisokinetic sampling
because of the inertia of some particles  and may result in biased concen-
tration measurements.
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     Section 6.12 of Reference Method 5 (40 CFR Part 60 Appendix A--
Reference Method 5) specifies that test results are acceptable if they
are within ±10 percent of isokinetic.  A procedure is available to
calculate the maximum error which can occur because of anisokinetic
sampling.  The approach accounts for the inertial effects of particulate
matter and the maximum effect they might have on the measured particulate
matter concentration.
     The probe tip velocity during the emission testing at Plant B
ranged from 93.7 to 107.0 percent of the isokinetic velocity, and the
mass emission rate ranged from 0.033 to 0.11 Ib/ton (Table 2-2).   The
velocities are within ±10 percent of isokinetic values.   Therefore, the
Plant B tests are considered acceptable and adequately demonstrate the
achievability of the standards.
     The tests at Plant E show that for four test runs,  the probe tip to
gas stream velocity ratios ranged from 111.2 to 117.9 percent (Table 2-2)
of isokinetic.   The corresponding emission rates ranged  from 0.018 to
0.034 Ib/ton.  These emission rates were adjusted using  the procedure
referred to above.   The adjusted emission rates ranged from 0.018 to
0.036 Ib/ton (Table 2-2).   Because the adjusted mass  emission rates do
not exceed the proposed mass emission limit of 0.60 Ib/ton, data from
the Plant E tests are considered to be acceptable and demonstrate the
achievability of the standards.
2.6.2  Production Capacity
     Comment:  One commenter (IV-F-1/IV-G-3) stated that the tests at
Plants C, D, and E were conducted below the design production capacity
of the kilns.  The commenter stated that the tests at Plant C were
conducted with only two of the three available kilns  in  operation and
that this was stated to be ".  .  .  the normal operating mode of the
plant."  However, the control  equipment at Plant C was designed to
accommodate three kilns instead  of two and, therefore, the data from the
tests are invalid.   The commenter further stated that Plant D was operating
at 81 percent of capacity during tests.   The commenter concluded  that,
because the tests were not conducted under conditions representative of
design production conditions,  the results of the tests do not adequately
demonstrate the achievability of the standards.   The  commenter supported
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           TABLE 2-2.  ADJUSTED PLANT B AND PLANT E TEST RESULTS
Plant Run No.
B 1A
IB
2A
2B
3A
3B
E 1-1
2-2
1-2
3-1
3-2
2-3
Percent
isokinetic
103.6
104.1
99.7
93.7
103.7
107.0
96.3
112.2
111.2
117.9
115.6
108.5
Emission
rate3
Ib/ton
0.039
0.077
0.033
0.115
0.046
0.110
0.041
0.018
0.027
0.024
0.034
0.018
Adjusted
emission rate
Ib/ton
N.N.C
N.N.
N.N.
N.N
N.N
N.N.
N.N.
0.018
0.028
0.025
0.036
N.N.
Decision
A
A
A
A
A
A
A
A
A
A
A
A
.Data from test reports.
CA = Accept stack test.
 N.N. = Not necessary.
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his conclusion by citing Essex Chemical Corporation v. Ruckelshaus,
486 F.2d 427, at 436 (O.C.  Cir.  1973) for the proposition that, where
tests are conducted with plants operating at less than capacity, "... the
relevancy of the test results is at best minimal."
     Response:   Plant C has three operating rotary lime kilns, each
rated at 250 tons/day, and emissions from all three kilns are ducted to
the same ESP.  Plant C seldom operates all three kilns at the same time,
and usually only two are on-line.   In a letter dated September 4, 1974,
information was requested from Plant C on operating conditions during
the May 1974 tests and on any nontypical conditions.   Plant C responded
on October 8, 1974, stating that two kilns were in operation during the
test and that operation on these dates was normal.   There is no indication
that operation of two rather than three kilns at Plant C is abnormal.
Therefore, the operation of two kilns is considered to be the normal
operating mode of Plant C.
     Emission testing is usually conducted at the maximum production
rate for a given plant, which, in most cases, is within approximately 10
to 15 percent of design capacity.   During the emission testing at Plant D,
the production rates ranged from 86 to 106 percent of design capacity
(I-G-1, p. C-5).   [The 81 percent stated by the commenter is an error.]
Although the tests at Plant D were conducted at -14 percent to +6 percent
of design capacity, the test results show that the emission levels
between test runs in both Plant D tests were consistent, averaging
0.275 Ib/ton.  Emission testing at Plant E was performed at 91 percent
of capacity.   Consequently, the test results at Plants D and E are
considered valid.
     The Essex Chemical Corporation case cited by the commenter refers
to a situation where testing was performed at 52 percent of capacity
and, as the Court stated in the remand of the lime manufacturing plant
new source performance standards,  the regulations there in question,
unlike those for lime plants, expressly required performance tests while
the affected facility operated at the maximum pollutant production rate.
Thus, the case is not relevant to this situation.
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2.6.3  Pitot Tube Specifications and Velocity Traverses
     Comment:   One commenter (IV-F-1/IV-G-3) stated that there were
errors in the Plant E emissions tests:
     1.   The pi tot tubes were not within the specified pi tot coefficient
(C ) range of 0.85 ± 0.02, but instead were 0.807 and 0.819.
  r*
     2.   Reference Method 1 specified 24 points per traverse (48 total
sample points) for stacks of this configuration, while 22 points per
traverse (44 total sample points) were sampled.
     The commenter further stated that the errors would have a profound
effect on the test data.  Therefore, the Plant E tests do not adequately
demonstrate the achievability of the standard.
     Response:  Reference Method 2 states that the type-S pi tot tube
shall have a known coefficient, determined by one of the procedures
outlined in the method.   The 0.85 coefficient noted by the commenter is
a nominal coefficient used to set up the nomograph used for establishing
isokinetic sampling rates during an actual test.  Where the exact pi tot
coefficient is known, the method specifies it must be used in the equations
provided, in place of the nominal 0.85 coefficient, to determine the
actual test run isokinetic rate.   The contractor who tested Plant E
supplied calibrated pitots for this work, and the procedure outlined in
the method was followed.  The minor variations between the nominal
coefficient used in the nomograph and the actual coefficients used in
the calculations accounted for the nonisokinetic sampling rates for the
tests.
     Sampling too close to the stack wall (i.e., within I inch) can bias
the sample because of flow turbulence and, thus, as in the case of
Plant E, sampling is not conducted when the probe is near the wall.  A
report entitled "Particulate Sampling Strategies for Large Power Plants
Including Nonuniform Flow" examines the errors incurred by changing the
number of sampling points for stack gas particulate sampling.   It
demonstrates that the expected error in measurement of particulate
concentration decreases  as the total number of sample points over 24
increases.   The largest expected error for 24 or more sample points is
less than 1.0 percent.   For Plant E, the decrease in the total  number of
sample points  from 48 to 44 cannot be expected to change the emission
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rate determination by more than about 1 percent.   Thus, these errors
would not have a significant effect on the test data because the highest
Plant E emission rate, adjusted for error as noted in Section 2.5.4.1,
was 0.036 Ib/ton.
2.6.4  Climatic Conditions
     Comment:   One commenter (IV-F-1) stated that the statement in the
proposal preamble that ".  .  .  stack gas exit velocity is not an independent
variable because it depends on the gas flow rate and stack diameter ..."
is erroneous.   He indicated that excess moisture is present in the gas
stream during the winter months as a result of the feedstock laden with
snow and ice that is added to the kiln.   The commenter states that this
moisture increases the stack gas velocity and, thus, increases visible
emissions.
     Response:  The velocity of the gas stream is dependent on the gas
flow rate and the stack diameter.   The addition of moisture to the gas
stream will  increase the volume (cubic feet) and, thus, the gas flow
rate (cubic feet per minute).   The velocity at which the gas stream
moves through the viewer's line of vision has no effect on the opacity
of visible emissions.  The commenter appears to be indicating that an
increase in moisture content during some months of the year in certain
geographical areas would increase the visible emissions of the exhaust
gas stream.   Although the addition of moisture could increase the apparent
opacity of visible emissions under certain conditions, Reference Method 9
has specific procedures for the reading of plumes with high moisture
contents.  These procedures require reading of the plume at the point of
dissipation of the moisture.   Thus, compliance with the standards is not
adversely affected by the addition of moisture to the plume.
     The capacity of a kiln is a function of its evaporative load.
Addition of large quantities of water to the kiln would decrease the
capacity.  Thus, the mass emissions would be expected to decrease.
Consequently, the visible emissions should decrease or remain at about
the same level.
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2.7  CONTINUOUS MONITORING
2.7.1  Continuous Monitoring Reliability
     Comment:  One commenter (IV-F-1) stated that transmissometers
necessary to fulfill the continuous monitoring requirement are subject
to a high frequency of false readings and require excessive maintenance.
The commenter concluded that continuous monitoring is unachievable
because there does not seem to be any instrumentation that can provide
reliable continuous monitoring.
     The commenter further stated that imposing three monitoring
requirements—Reference Method 5, Reference Method 9, and continuous
opacity monitoring—amounts to overkill.   Therefore, the commenter
recommended that the continuous monitoring requirement be deleted from
the regulation.
     The commenter also felt that wet scrubbers should have the same
visible emission monitoring requirements that fabric filters and ESP's
have.
     Response:   Studies indicate that continuous monitors are in operation
in many industries, and when they comply with the performance specifications
included in 40 CFR 60, Appendix B, these monitors perform accurately and
reliably.
     Reference Methods 5 and 9 are test methods to determine compliance
with standards of performance.   They are not performed on a continuous
basis (although for facilities that choose to use certified visible
emission observers instead of transmissometers for monitoring positive-pressure
fabric filters,  Method 9 could be said to be used on a continual  basis).
Thus,  the requirement to monitor visible emissions (or pressure drop and
liquid flow rate in the case of wet scrubbers) is the only "monitoring"
requirement.   This requirement is considered reasonable because continuous
monitoring provides the information necessary to ensure proper operation
and maintenance of the control  system.   Without continuous monitoring,
neither the plant operator nor enforcement personnel  can determine
whether control  equipment is operating properly or is in need of maintenance
without costly performance testing to determine compliance with the
standard.
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     Scruobers  are  not  subject  to  the  lime  plant  visible emission standard
because  the  formation of  steam  plumes  from  scrubbers  maKes  it difficult
to  accurately determine plume opacities.   It  is difficult to  determine
wnere  the  steam  plume from  a scruboer  on  3  rotary  lime  kiln  actually
dissipates and  tne  visible  emissions begin.   However, the pressure  drop
ana  liquid flow  rate monitoring and  "ecording  requirements *ill  ensure
that scrubbers  are  operated and maintained  properly.
     Comment:  One  commentar (IV-0-5)  contends that the  most  reliable
system to  verify compliance with the standard would be a  realistic
visible  emission standard rather than  a continuous monitoring system.
The commenter also  stated that  the requirement to  record  readings  f"om a.
continuous monitor  should be dropped because  it is an unfair  ourcen.
     Response:  T'ne cost of continuous monitoring  (or pressure drop  and
liquid flow monitoring in the case of wet scrubbers) on  other than
positive-pressure faerie filters is small (about S3,000  annually).   The
data gathered by continuous monitors ara necessary to indicate problems
in operation and maintenance of the control device.  Consequently,
collecting and recording these data d-o not  impose  an unreasonable ourden.
As discussed in Section 2.5.1,  the 15 percent visible emission standard
is reasonable.
2.7.2  Use of Continuous Emissions Monitoring Results
     Comment:  One commenter (IV-r-I) vas concerned about *netner trans-
missometer data woula be usaa by enforcement personnel as evidence of
noncomplianca witn the stanaaras.
     Response:  The continuous  monitoring "esults  are not jsea to Determine
violations of the standards unaer the 'ederal  NS?S.  ~he curoose of  the
continuous monitoring requirement is to orovide plant operators ana
enforcement personnel with information about whether a control device  is
properly operated and maintained.   If the data recorded  by the transmis-
someter  inaicata visible emissions approaching or  exceeding the visible
emission standard,  then  plant operators are forewarned tnat the contro1
device needs  maintenance.   Although transmissometers are not  the-metnoa
used to determine compliance,  data generated by the transmissometers are
used to cita  plants for  failure  to properly operate and  maintain the
equipment.   In addition,  to the  extent that continuous monitoring data
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indicate visible emissions in excess of the standard over a period of
time, an enforcement agency may require a plant to perform a performance
test to determine compliance with either the mass emission standard or
the visible emission standard.
2.8  MISCELLANEOUS
2.8.1  Temperature of Lime Production
     Comment:   One commenter (IV-F-1) stated that some important facts
were not addressed in the preamble (47 FR 38851) in the discussion of
particle sizes at various stages in the production of lime.  The commenter
stated that calcining lime by going from 1000°C (1832°F) to 1648°C
(2998°F) as the preamble indicated would ruin the quality of the lime.
     Response:  The discussion on temperature, referred to by the commenter,
is included in the preamble only to show how particle sizes tend to
increase with increasing process temperature.   This information was
obtained from "Chemistry and Technology of Lime and Limestone" by
R. S. Boynton (Interscience Publishers, 1967) (II-I-4).   Boynton states
that as the temperature in the kiln increases to 1000°C (1832°F), the
0.1-um crystals coalesce into larger particles of approximately 1 |jm in
diameter.   At 1100°C (2012°F), these coalesced lime particles are irregular
spheres greater than 1 urn, and at 1648°C (2998°F) (the temperature
required for the sintering of dead-burned lime), the particles are
approximately 100 urn in diameter.   This discussion does not imply that
the calcining process is normally run from 1000° to 1648°C (1832° to
2998°F).
2.8.2  Continuous Monitoring of Positive-Pressure Fabric Filters.
Although not specifically mentioned by any commenters, there may be some
difficulties associated with the use of continuous monitors on positive-
pressure fabric filters.  Positive-pressure fabric filters have either
multiple exhaust points or a single exhaust point running the length of
the fabric filter.   To monitor visible emissions adequately,  continuous
monitors must be mounted at each emissions point or a single monitor
must be positioned to monitor the visible emissions across a s.ingle
"line of sight."  In some instances,  the distance to be traversed by the
beam from a single monitor positioned on the "line of sight"  exceeds the
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capability of the monitor.  Thus, in these cases, multiple monitors
would be required to monitor visible emissions adequately on a positive-
pressure fabric filter.   Installation of these monitors greatly increases
both the capital and operating costs required to monitor visible emissions,
and these increased costs are considered to be unreasonable.
     In lieu of transmissometers, observations of visible emissions
discharged to the atmosphere from positive-pressure fabric filters can
be employed on a routine basis to ensure proper operation and maintenance
of the control device.   The final standards, therefore, require that if
a continuous monitor is not installed on a positive-pressure fabric
filter, a certified visible emission observer must monitor and record
the opacity of visible emissions from each compartment or exhaust point
once per day during normal kiln operation.   For each site of visible
emissions,  three 6-minute observation sets must be performed in accordance
with Reference Method 9.   Reference Method 9 is used to determine
compliance with the control device visible emission standard.   Accordingly,
reports of such tests from positive-pressure fabric filters may be used
to determine compliance with the control device visible emission standard.
The monitoring requirements for control  devices other than positive-pressure
fabric filters remain unchanged.
     In addition to reevaluating these continuous monitoring requirements,
the Agency has examined the monitoring and reporting requirements for
wet scrubbers.   Wet scrubbers are not subject to the visible emission
standard,  but they are subject to requirements for monitoring and recording
of the pressure drop and liquid flow rate.   The purpose of these require-
ments is to provide a means for the EPA  and owners of facilities controlled
with scrubbers to ensure proper operation and maintenance of the scrubber.
To be consistent with this purpose and with the requirement that visible
emissions  from other control  devices in  excess of the standard be reported
on a quarterly basis, the Agency is adding a performance specification
and reporting requirement for wet scrubbers.   Section 60.343(e) of the
regulation  requires that any periods during which the scrubber pressure
drop is greater than 30 percent below the rate established during the
performance test be reported to the Agency on a semi-annual  basis.   The
                                  2-36

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Agency has decided that all excess emission reports will be required
semi-annually rather than quarterly.
                                  2-37

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                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
i  REPORT NO.
  EPA-450/3-84-008
                                                            3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
  Lime Manufacturing Plants—Background Information  for
  Promulgated  Standards of Performance
             5. REPORT DATE
               March 1984
             6. PERFORMING ORGANIZATION CODE
7 AUTHOR(S)
                                                            8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS

  Office of  Air Quality Planning  and Standards
  U.S. Environmental  Protection Agency
  Research Triangle Park, North Carolina  27711
                                                            10. PROGRAM ELEMENT NO.
             11 CONTRACT/GRANT NO.

               68-02-3059
12. SPONSORING AGENCY NAME AND ADDRESS
                                                            13. TYPE OF REPORT AND PERIOD COVERED
  Director  for  Air Quality Planning  and Standards
  Office of Air and Radiation
  U.S. Environmental  Protection  Agency
  Research  Trianale Park. North  rarnlina_ 27711
             14. SPONSORING AGENCY CODE

               EPA/200/04
13. SUPPLEMENTARY NOTES
16. ABSTRACT


       Standards  of performance  for  the control of  particulate matter emissions from
  rotary lime  kilns at new, modified,  or reconstructed  lime manufacturing  plants are
  being promulgated under the authority of Sections  111,  114, and 301(a) of the Clean
  Air Act, as  amended.  Tnese standards would apply  to  those affected facilities that
  commence construction on or after  May 3, 1977, the date of original proposal.  This
  document contains a summary of the public comments on the proposed revised standards
  and the EPA's  responses, as well as  summary economic  and environmental impact
  statements.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                               b.lDENTIFIERS/OPEN ENDED TERMS
                           e. COSATi field/Group
  Air Pollution
  Pollution  Control
  Standards  of Performance
  Lime Manufacturing Plants
  Particulate  Matter
Air Pollution  Control
is. DISTRIBUTION STATEMENT
  Unlimited
                                               19. SECURITY CLASS /This Report!
                                                 Unclassified
                                                                          21. NO. OF PAGES

                               45
                                               20. SECURITY CLASS (This page)
                                                 Unclassified
                                                                          •22. PRICE
SPA Form 2220-1 (Rev. 4-77)   PREVIOUS EDIT,ON is OBSOLETE

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•i* En*lfonf"«"tat Protection Agmey
Wgtofl 5, Library (PI-12J)

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