EPA-450/2-77-007b
October 1977
     FINAL STANDARDS SUPPORT
        AND ENVIRONMENTAL
         IMPACT STATEMENT
      VOLUME II: PROMULGATED
    STANDARDS OF PERFORMANCE
               FOR LIME
      MANUFACTURING PLANTS
      l.S. ENVIRONMENTAL PROTECTION
          Office of Air and Waste Management
        Office of Air Quality Planning and Standards
            Triangle Park, North (.arolina 2771 1

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                         EPA-430/2-77-007b
FINAL STANDARDS SUPPORT
    AND ENVIRONMENTAL
     IMPACT STATEMENT
 VOLUME II: PROMULGATED
STANDARDS OF PERFORMANCE
           FOR LIME
  MANUFACTURING PLANTS
       Emission Standards and Engineering Division
      U.S. ENVIRONMENTAL PROTECTION AGENCY
         Office of Air and Waste Management
       Office of Air Quality Planning and Standards
       Research Triangle Park, North Carolina 27711
              October 1977

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This report has been reviewed by the Emission Standards and Engineering
Division, Office of Air Quality Planning and Standards, Office of Air and
Waste Management, Environmental Protection Agency,  and approved for
publication.  Mention of company cr product names does not constitute
endorsement  by EPA. Copies  are available free of charge to Federal
employees, current contractors and grantees, and non-profit organiza-
tions - as supplies permit - from the Library Services  Office  (MD-35),
Environmental Protection Agency, Research Triangle Park, N.C. 27711;
or may be obtained, for a fee, from the National Technical Information
Service, 5285 Port Royal Road, Springfield, Virginia 22161.
                     Publication No. EPA-450/2-77-007b

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                         Final Standards Support and
                       Environmental Impact Statement

                         Lime Manufacturing Plants

                      Type of Action:  Administrative

                                Prepared by
c
 Don R. Goodwin/                                                    (Date)
 Director, Emission Standards and Engineering Division
 Environmental Protection Agency
 Research Triangle Park, North Carolina  27711


                                 Approved by
 David G. Hawkins                                                   (Date)
 Assistant Administrator
 Office of Air and Waste Management
 Environmental Protection Agency
 401 M Street, S.W.
 Washington, D. C.  20460
 Additional copies may be obtained at:

 EPA Library  (MD-35)
 Research Triangle Park, North Carolina  27711

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                               Table of Contents
                                                                      Page
  I.   Introduction 	     1

 II.   Summary of the Environmental  Impact of the  Standards  	     2

III.   Summary of the Economic Impact of the Standards  	     4

 IV.   Summary of Comments and Responses  	     5

Appendix A	    17

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                             I.   INTRODUCTION
     On May 3, 1977,  the Environmental  Protection Agency (EPA)  proposed  a
standard of performance for the  control  of participate matter emissions
from new or modified  lime manufacturing plants.   These standards were
proposed under section 111 of the Clean Air Act,  as amended.   The proposed
standards were to limit emissions of particulate  matter from  new, modified,
and reconstructed lime manufacturing plants by the use of the best demon-
strated system of emission reduction, considering cost.
     At the time the  standards were proposed, a standard support and
environmental  impact  statement (SSEIS,  Vol. 1) was published  and made
available to the public.  The public was invited  to comment on the standards
and the SSEIS during  a 60-day comment period.  Twenty-three comments were
received from industry, State and local pollution control agencies, and
Federal agencies.  On June 16, 1977, a  public meeting was held at the EPA
facility at Research  Triangle Park, North Carolina, to provide the public
and the National Lime Association an opportunity  to comment on the standards
and the support document.
     The purpose of this document is to summarize the economic and environ-
mental impacts of the standards and respond to the comments received.

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         II.  SUMMARY OF THE ENVIRONMENTAL IMPACT OF THE STANDARDS





     The environmental impact of the final standards is no different from



the detailed statement found in the Standards Support and Environmental



Impact Statement, Volume I, which support the proposed standards.



     It is estimated that the emission standards would reduce national



particulate emissions from lime manufacturing plants by about 13 gigagrams



(about 14,200 tons) through 1982.  The standards would reduce the



particulate emissions from new lime kilns by 70 percent below the levels



required by a typical State standard for existing sources.  The standards



would also reduce particulate emissions from new lime hydrators by 85



percent compared to the requirements of the average State standard.  The



maximum 24-hour average ambient air concentration of particulate matter



emitted from a typical lime kiln controlled to the level required by the



standards would be about 2.0 micrograms per cubic meter (yg/m ).



     The secondary environmental impacts of the standard are considered



minor.  There would be no impact on water pollution.  Solid waste handling



and disposal problems would be minimal.  All of the particulate collected



from the hydrators can be returned to the process.  When dry control systems



are used on the lime kiln, the additional amount of solid waste accumulated



is estimated to be about three percent.  A negligible amount of particulate

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matter, sulfur dioxide, and nitrogen oxides would be discharged into the
air by the power plant which supplies the additional electrical power
required by the lime plant to meet the standards.
     The expected distribution of control techniques to comply with the
standards is 80 percent by baghouse control and 20 percent by ESP control
     If dry control  systems were used exclusively, no impact on water
resources or waste treatment would be incurred and an energy savings of
about 1.0 percent for the industry would be realized in 1982.

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        III.   SUMMARY OF THE ECONOMIC IMPACT OF THE STANDARDS

     The control costs that new, modified, and reconstructed lime plants
would incur to meet the emission level  required by the standards are
considered reasonable.  Total  incremental  investment costs through 1982
to meet the standards are projected to  be about $3 million.  The annualized
costs in 1982, including depreciation and interest, are estimated to be
about $5 million.  The capital cost of  control for typical new lime plants
would be increased by about 3.5 percent.  The potential price increase that
would result from implementing the standards for new or reconstructed
kilns has been estimated to be about 80 cents per megagram of lime produced,
or an increase of approximately 2.6 percent.
     The detailed economic impact of the standards appears in the Standards
Support and Environmental Impact Statement,  Volume 1.

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                   IV.   SUMMARY OF COMMENTS AND RESPONSES


                            LIST  OF  COMMEflTERS


Comment No.

   LM-1              Woodville Lime  and Chemical  Company
                     George Judd

   LM-2              National  Lime Association
                     George A. Ziegler

   LM-3              U. S. Environmental Protection Aqency
                     Stationary Source Enforcement Oivision

   LM-4              St. Regis Paper Company
                     H. R. Emery

   LM~5              U. S. Environmental Protection Agency
                     Stationary Source Enforcement Division

   LM-6              National  Lime Association
                     George A. Ziegler

   LM"7              U. S. Environmental Protection Aqency
                     Stationary Source Enforcement ^vi

   LM-8              Commonwealth of Virginia
                     State Air Pollution Control  Board
                     John M. Daniel, Jr.

   LM-9              State of Tennessee
                     Department of Public Health
                     Harold E. Hodges

   LM-10             State of Indiana
                     State Board  of  Health
                     Harry D.  Williams

   LM-11             Dow Chemical USA
                     R. J. Moolenaar

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LM-12             Regional  Air Pollution Control  Agency,  Dayton,  Ohio
                  William T.  Burkhart

LM-13             Bethlehem Steel  Corporation
                  David il.  Anderson

LM-14             Transcript  - Public Meeting
                  Research  Triangle Park, North Carolina
                  June 16,  1977

LM-15             State of  Alabama
                  Air  Pollution Control  Commission

LM-16             State of  Texas
                  Texas Air Control Board
                  Charles R.  Barden

LM-17             U.  S. Department of the Interior
                  Larry E.  Meirotto

LM-18             Engelhard Minerals and Chemical Corp.
                  C.  Y. Hass

LM-19             National  Lime Association
                  Corrected Copy of Transcript (LM-14)
                  George A. Ziegler

LM-20             U.  S. Department of Health, Education  and Welfare
                  Joseph J. Corliss

LM-21             National  Lime Association
                  Submission  of Monitoring Test Data
                  George A. Ziegler

LM-22             U.  S. Energy Research and Developmant  Administration
                  W.  H. Pennington

LM-23             U.  S. Department of Commerce
                  Sidney R. Galler

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     The most significant comments  submitted  following  the  publication  of

the proposed standards on May 3,  1977,  are summarized and addressed  in

this section.  Because of the detailed, technical  nature of comments

concerning procedures and test data,  the relevant  comments  are given in

full in subsections 1, 2, and 6.  The other significant comments  are

summarized in the other subsections.

     1.  LM-1

     Comments:

     (a)  Substituting the printed  data for Plant  B into  EPA's formula  for ACFM,
and solving for P , gives the following values:

     1A = 30.0045" Hg
     IB = 47.4186" Hg
     2A = 21.0267" Hg
     2B = 39.8689" Hg
     3A = 20.4409" Hg
     3B = 30.2319" Hg

     Because of the extremely low and high pressures indicated by some  of
the tests, the results published  in the paper are  highly questionable.

     (b)  Plant C was operated at only 80.24  percent rated  capacity  of  the
ESP and less than 67 percent of the productive capacity ratinq of the kilns.
Plant C burns gas and produces a  number of tons  of dolomitic lime to treat
sea water.  Utilizing the highest hydrogen-containing  hydrocarbon (CH4) as
the only fuel, it follows that there are 122.5 Ib  of Ob/million  Btu's  on  848.7
Ib of air required per million Btu's.

     However, 1 mole of gas requires 2 moles  of air, and  because  1 mole of
air produces water and 1 mole of air produces C02, then 1 mole of air is
reduced 23.301 percent by weight because the  03 of the  air  is turned to water,

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and is removed from the calculation of gases by using DSCFM,  therefore,
there are 749.7 Ib of air in DSCF,  but 75 percent of the weioht of the
methane is carbon, and therefore 44.55011 x .75 = 33.41  pounds  of C must
be added to 749.7 Ib, or 783.11  Ib  of DSCF is required for a  million Btu's.
Of this 749.7 pounds, 122.5 Ib is C02 which leaves 660.6 Ib N2.

     Using 6.5 million Btu's per ton of lime, there would be  280.9 Ib of
C02 per million Btu's since there are 1826 Ib C02 per ton of  lime.

     783.11 Ib of gases produced by combustion + 280.9 Ib of  C02 = 1064.01
Ib of gases produced by one million Btu's.  Calculating the weight percent
and volume percent of C02 and N2 at 0 percent 02 gives:

     C02 = 37.91 percent by wt.  or  27.989 percent by vol.
     N2  = 62.09 percent by wt.  or  72.011 percent by vol.

     But according to the data in the EPA support document, the DSCF percent
by volume at 0 percent 02 is as  follows:

     C02 = 19.55882 percent by vol. or 27.645 percent by wt.
     \\2  = 80.44118 percent by vol. or 72.335 percent by wt.

     With this information, Plant C has to be burning 14 million Btu's/ton
of lime and because of its inefficiency the plant should not  be considered
unless 14.04 million Btu's is considered  an efficient plant.

     (c)  Plant E has 30,909 DSCFM  with 9.2 percent C02 and 13.5 percent
02 in the data for the average.   At 0 percent 02, this corresponds to
1T034 DSCFM and 25.76 percent CO? and 74.24 percent No,  by volume.  On  a
weight percent basis, this calculates to  be 59239 Ib/nr and 34.286 percent
C02 and 64.714 percent N2.  The  Ib  N2 per hour is 38336.

     When carbon burns, 13.69841 Ib of gases/lb of C are produced.  Hydro-
carbons [(CH2)p] produce 15,89795 Ib of dry gases/lb (CH2) .  Using the
nitrogen as a oasis, there would be 47780 Ib of combustion gases for (CH2)n
and 52347 Ib of combustion gases for C.

     For 55 percent C (.55 x 52347  = 28790) and 45 percent (CH2)  (.45  x
47780 = 21501) which equals 50,292  Ib of combustion gases.

     If all of the coal is (CH2) then 59,239 - 47780 = 11458  Ih of C02  from
calcination then there would be  7.29163 tons of CaO/hr or 175 tons lime/day.
If all of the coal is C, then 59239 - 52347 = 6892 Ib of COo  from calcination
then there would be 4.3859 tons  of CaO/hr or 105 tons of lime/day.  If  the C
is 55 percent and (CH2)  is 45 percent then 59.239 - 50292 =  8947 Ib of C02
from calcination then there would be 5.6936 tons of CaO/hr or 137 tons
lime/day.  Therefore, from the data there could not have been 240 tons  per
day of lime and is less than 90  percent of-rated capacity.

     (d)  There are questions as to the validity of the information obtained
by the groups doing the testing  for the EPA.  The data from Plant D indicates
that considerable difficulty was encountered in getting satisfactory test
                                     8

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results.  Plant D had at least four test attempts before satisfactory results
were obtained.  In addition, special  preparation of the operating plant was
necessary before satisfactory results could be obtained.

     Responses:

     (a)  Table C-4 of the support document is in error in report!nq the
actual  gas volumetric flow rates for  runs IB, 2A, and 3A.   The SCFMD values  were
inadvertently interchanged and the ACFM and gr/SCF values  were calculated from
the interchanged values.  The correct values are shown below.
Run Number
Flow rate - ACFM
Flow rate - SCFMD
Barometric Pressure
(in hg)
Emission rate (gr/ACF)
1A
23,894
13,241
30.02
0.0113
IB
31,753
16,973
30.02
0.0169
2A
20,109
11,081
29.94
0.0115
2B
42,289
22,481
29.94
0.0190
3A
28,621
15,718
30.22
0.0115
3B
30,442
16,206
30.22
0.0253
     The reported values for emission rate in gr/DSCF, Ib/hr, and Ib/ton are,
however, correct in the document.  These values were used in setting the
emission standard.  Therefore, the final outcome was not affected by the
erroneously reported values.

     (b)  The theoretical analysis presented assumes that the Orsat data
collected during the test program were sufficiently accurate for the purpose
of mass energy balances.  However, the test report states that the C02
results may be too low due to measurement error.  Therefore, it is incorrect
to conclude that there was an inefficient use of the energy input on the basis
of the Orsat data.

     In the test report, the Orsat data were used to calculate molecular
weight, which, in turn, was used to calculate the volumetric flow rate.
Moderate errors in the Orsat analysis generally do not have a significant
effect on the flow rate calculation.  In this case, the reported Orsat data
as compared to the theoretical would introduce less than one percent
difference in the volumetric flow rate and in the pounds per ton of feed
rate.

     (c)  As pointed out in (b) above, the calculations rely on the accuracy
of the Orsat data.  The Orsat data are used to calculate the volumetric flow
rate and moderate errors in the Orsat data do not significantly affect the
final results.

     (d)  There were three attempts to complete particulate tests at Plant
D.  The first tests scheduled were aborted when visible emissions far
exceeded expectations and a problem with the operation of the electrostatic

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precipitator was discovered.  To consider the results from this test as
representative would not be valid.  Consequently, this test was cancelled.
The second series of tests was conducted after the problem with the ESP was
thought to be resolved.  However, plant personnel determined that some
problems with the ESP still existed.  Because of this, the plant suggested
that a third test be conducted once maintenance, cleaning, and repair of
the control system was completed.  The third and final test program was
conducted and completed without mishap.  The production rates for the second
two tests were 106 percent and 86 percent of capacity.  Since the emission
rates for these tests were comparable, the results from both the second and
third tests were used in determining the emission standards.

     2.  LM-6, 14

     Comments:

     (a)  Another factor not considered by EPA in establishinn the particulate
standard is that, unique to lime kilns, the flue dust contains a large
percentage of calcium oxide, (up to 35 percent and higher).  When the flue
dust is subject to stack test procedures, it has the capability of recarbona-
ting and combining on the filter.  This adds gaseous weiqht, which is not
truly a part of the particulate emission, to the weight of the sample reported.

     (b)  The oxygen determinations, (19.5 percent), that were obtained during
the test are questioned and the only logical explanation is that the sample
was contaminated.  As further proof of this, the heat content calculations
show that if 19.5 percent oxygen at the stack were accurate, the kiln gases
were gaining heat while passing through the ductwork, I.D. fan and the'baghouse.
This is thermodynamically impossible since there is no heat source after the
gases have left the kiln.  The calculations were made from EPA test data of
June 11, 1974.

     (c)  With the extremely low velocities encountered at the gravity stack
discharges of a typical baghouse, it is questionable whether the test
procedures are accurate enough to justify a regulation as stringent as that
proposed.  With velocity pressures approaching and even reaching the bottom
of the scale of the inclined manometer, (0.01 inches water gauge), the
isokinetics and sampling rates must be questioned.  In accordance with
Method 2, presumably more precise micromanometers may not easily be adaptable
to field conditions and are not easy to use with pulsating flow.  It is
possible therefore, that errors of significant magnitude (as much as 40
percent), could be made.

     (d)  It is believed that much of the EPA plant data used to justify the
proposed standard is technically unsound.  For example, test data for Plant
E indicate the following errors:

     (1)  four of the six tests (2-2, 1-2,'3-1, and 3-2) were not isokinetic
as specified by EPA Method 5;

     (2)  the-pitot tubes were not within the specified range of Cp = 0.85 +_
0.02 but were Cp = .807 and .819; and
                                  10

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     (3)  EPA Method 1  specifies 24 point traverses for stacks of this
configuration while 22  point traverses were run.

     These test deficiencies would preclude use of the results for demon-
strating compliance and consequently, should not be used for setting
standards.  Plant C data show that the precipitator was receivina emissions
from only two kilns while it was designed to handle the gases from three
kilns and therefore was operated far below capacity.  Plant F was unable  to
meet the proposed standard and to suggest that a  higher valid pressure  drop
across the scrubber would have made it meet the standard is not valid.
Plant D was purposely cut back to 81 percent of capacity to permit testing
without excessive emissions, so it does not represent a realistic production
system.

     (e)  It should be  noted that the emission rate does not include  con-
densibles and that Method 5 had to be modified to include an orifice  meter
in the hot box ahead of the impinger train to insure isokinetic conditions.
We therefore request that the emissions standard for compliance by lime
hydrators be determined by filter catch only, excluding condensibles, and
that the proposed modifications to Method 5 be incorporated in the test
procedure.

     Responses:

     (a)  The capability of recarbonation exists, the extent to which this
occurs is small.  In the laboratory, CaO was exposed to pure C02 for  two
hours at ambient conditions.  There was only 1.5 percent mass qain.  Under
elevated temperatures (up to 150°C) that would be experienced during  EPA
Method 5 sampling, the  mass gains were less than 0.5 percent when calcium
oxide was exposed to 100 percent"^.  These laboratory results indicate
that this reaction is not a problem when sampling lime plant exhaust.  It
also should be noted that this reaction is capable of occurring in the  stack
stream as well as on the filter.  If this is the case, CaC03 would be
considered particulate  matter.

     (b)  A check of carbon balance data shows that the measured carbon
dioxide values are consistent with the process data but the oxygen data
appear to be incorrect.  However, these data were used only to establish
the molecular weight of the stack gas.  A large error in oxygen measurement
produces only a small error in the molecular weight determination. As  a
result, the mass emission rate values are not substantially affected.  A
1.0 percent error in molecular weight determination would introduce 0.5
percent error in the mass emission data.

     (c)  We agree that the measurement of flow velocities is a problem
with EPA Method 5, which uses the type-S pitot tube and gauge oil manometer.
The lower limit of velocity head measurement accepted within the criteria
set by EPA is 0.05 in.  ^0.  Using a 0.005'in. H20-division manometer,  this
corresponds to a +5 percent accuracy in the velocity measurement.  Other
alternative method's, e.g. a special velocity pitot, may be used to measure
lower gas velocities.
                                    11

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     As  for  the data collected for the standard, three test results were
from lime  plants controlled by baghouses.  Of these three, only Plant B
showed a significant number of velocity head value below 0.05 in f^O.  An
error analysis of these data showed that the maximum possible negative.
error in velocity determination which could have occurred for any one run
could have been as high as 16.3 percent.  The average maximum possible
negative error for all test runs was about 10.4 percent.  This possible
error in velocity measurement would produce a corresponding error in gas
flow rate determination and in mass emission rate calculation.  Calculating
the maximum  emission rate resulting from the possible error, the average
emission rate value for all runs is 0.243 Ib/ton.  Since this value is
well below the proposed standard of 0.3 Ib/ton and since the probable error
would be much less, this one test value would have little effect on the
emission standard.

     (d)(l)  In the case of Plant E and the over-isokinetic sampling rates,
a maximum adjustment to the emission rate can be made by multiplying the
measured concentrations by the isokinetic rate.   Applying this adjustment
to the results of tests from Plant E produces an adjusted average emission
rate of  0.091 Ib/ton which is well below the proposed standard.

     (d)(2)  The magnitude of the pi tot tube coefficient is not important as
long as  it is known.    EPA Method 2 specifies a procedure for calibrating
type-S pi tots.  The contractor who tested Plant E supplied calibrated pi tots
for this work and the procedure outlined in the method was followed.  The
specification in Method 5 that pi tot coefficients be 0.85 + 0.02 is in
reference to the nomograph used for establishing isokinetic sampling rates.
If no correction to the nomograph were made for pitots with coefficients
other than 0.35 used on the tests at Plant E, then errors will occur.  This
may account  for the non-isokinetic-sampling results.  However, as discussed in
(d)(l) above, the errors caused by non-isokinetic sampling have little or
no effect on the proposed emission standard.

     (d)(3)  A report prepared for EPA entitled "Particulate Sampling
Strategies for Large Power Plants Including Monumiform Flow" examines the
errors incurred by changing the number of sampling points for stack gas
particulate sampling.   It demonstrates that in general by, the expected error
in measurement of particulate concentration decreases with an increase in the
number of sample points over 24.   The largest expected error for 24 or more
sample points was less than 1.0 percent.  For Plant E, the decrease in the
number of sample points from 48 to 44 cannot be  expected to significantly
change the emission rate determination by more than 1.0 percent.   Because the
measured emission rate for this plant is much lower than the proposed emission
standard, any error caused by the decreased number of sample points will not
affect the proposed emission standard.

     (e)   The proposed emission standard is determined by the dry catch of
the Method 5 train and does not include the catch of the impinger section.
The procedure for measurement of sampling rate prior to moisture condensation
in the sample train is the recommended procedure in the support document.  This
recomended procedure will  be added to the test methods and procedures section
of the final  regulation.
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     3.  LM-2

     Comments:

     In the Response to the Remand .  .  .In Portland Cement Association vs.
Ruckelshaus (EPA-450/2-74-023). EPA carefully considered the extent to which
the visual observations of trained observers can be relied upon as  well as
the issue of whether a 10 percent opacity standard is reasonable for cement
kilns.   As a result of this study, EPA  relaxed the opacity standard to 20
percent to accommodate certain extreme  circumstances.  The same factors and
considerations used by EPA to relax the opacity for cement kilns are equally
applicable to the lime industry and to  not apply them is neither economically
or technically equitable.

     In addition, trained observers will  err in visual  observations by a
factor of 7 percent.  This could result in an actual 10 percent opacity being
read as greater than 15 percent, and therefore in violation of the  standard.

     Responses:

     Careful review of the EPA Response . . . Portland Cement Association vs.
Ruckelshaus shows that the standard for this industry was indeed "relaxed to
20 percent opacity to accomodate certain extreme circumstances."  (p. 111).
In fact, the standard was relaxed to accommodate the complete range of
available data.  Data were available from a cement facility operating slightly
above (0.339 Ib/ton) the promulgated mass emission rate (0.300 Ib/ton).  Emissions
from this source averaged 18 percent opacity measured at a stack diameter of
12'6" (slightly greater than 20 percent opacity when converted to a 15' exit
diameter).  In establishing the standard for lime kiln, the same approach was
taken and the 10 percent opacity standard reflects the range and variation of
the available lime kiln test data.  Mass emissions for Plant D (0.266 and
0.282 Ib/ton) were slightly below the proposed mass emission rate (0.30 Ib/ton).
The actual stack exit diameter at this  facilty was 1.6  meters.  However, in
the SSEIS document for lime kilns all opacity data were extrapolated to an
exit diameter of 3 meters to accommodate for the effect of larger stack diameters
on opacity.  The extrapolated values are given in parenthesis in what follows.
For Plant D a single six-minute average opacity reading of 11.5 percent (21
percent) was recorded.  But the average opacity for six days of observation
encompassing two test periods of July 8-10, 1974 and August 6-8, 1974 was
1.2 percent (2.2 percent).  The highest daily average of opacity for a single
observer was  4.1  percent (7.6 percent).  This facility was
operating near the mass  emission  rate  of 0.30  Ib/ton and  had  average
opacity emissions  well  under the  proposed  10 percent standard even when
the data were extrapolated to a three  meter  pathlength  to  account  for
large  stack diameters.   Thus, in  establishing  the  opacity  Standard for
lime kilns, the data  base supports a 10  percent opacity limit.  The  cement
standard was  not increased to account  for  aji observer  variation of 7 percent
as one commenter suggests.   As  indicated in  the introduction  to Method 9,
the potential  observer error is taken  into  account when the  standard is
enforced.

     4.   LM-11

     Comment;

     Experience with  continuous monitoring  systems has  not been satisfactory,
because opacity readings from the monitors  cannot  be related  to readings by
a visual  observer.  Monitors may  give  an indication of whether the opacity

                                       13

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is increasing or decreasing, but do not give good absolute numbers.   Therefore,
it is recommended that continous monitors not be used as a basis for determing
compliance with opacity limitation and that the requirement be deleted.

     Response:

     Instruments meeting EPA specifications have shown good agreement with
observers under good viewing conditions and the sort of problem the  commenter
notes has not proven significant.  It is true that observers can understate
opacity when visibility is restricted and this may account for the experience
cited by the commenter.  Without supporting data, it cannot be determined if
there is a problem.

     5.  LM-13, 6

     Comments:

     (a) Continous monitoring requirements for determing opacity are not
reasonable because multiple stack baghouses will require multiple monitoring
units unreasonable costs for installation and maintenance.

     (b)  Continuous monitoring requirements for determing opacity are not
reasonable because,other enforcement procedures are available to ensure proper
operation and maintenance of the control device.

     (c)  Method 5 testing is not feasible for roof-ridge or other non-stack
type baghouses.  Construction of such baghouses should not be precluded simply
because they cannot be tested by conventional techniques.  What testing or
equipment modifications would be required for performance testing should be
made explicit.

     Responses;

     (a)  EPA never intended to require a monitor on each stack of a multiple
stack baghouse.  In most cases, only a single monitor would be required but
in some cases two may be required at each baghouse installation.  Thus,
monitoring systems for multiple stack baghouses are not believed to  be excessively
expensive to install or maintain.  The instrument would be installed to simultane-
ously monitor emissions from several  stacks.  Since little data are  available
concerning such installations, requirements have not been established.  However,
EPA has provided some guidelines for instrument installation and reporting
requirements for such situations.

     (b)  Although periodic unscheduled inspections by enforcement personnel
are a form of monitoring, this type of monitoring does not preclude  the need
for continuous monitoring by instrumentation.  This is especially true since
there are areas of the country where the manpower available for performing
periodic inspections is inadequate.

     (c)  The regulations does require performance testing for all affected
facilities.  Furthermore, the regulation states that the method of testing is
Reference Method 5 unless approval of an alternative test method is  granted
by the Administrator.  Since each pressurized baghouse is unique in  design,
establishing a reference test procedure which applies to all baghouses is not
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feasible.  Because there are no established regulations regarding test pro-
cedures for non-stack baghouses at this time, it is necessary that the owner
devise a test plan and that approval by the Administrator be obtained before
it is implemented.

     6.  LM-6

     Comments:

     (a)  The various process conditions unique to the lime industry make a
20 percent opacity standard more reasonable than the 10 percent standard
proposed.

     (b)  The proposed 10 percent opacity standard is not valid because
erroneous test observation procedures were used which make the test data an
invalid basis upon which to set such a stringent standard.

     (c)  Since it is not possible to take accurate opacity readings on
kilns with wet scrubbers, kilns with other types of control would be dis-
criminated against.

     Responses:

     (a)  The test data indicate a 10 percent opacity standard is achievable
under the process conditions stated by the commenter.  (See response to LM-2)

     (b)  The alleged erroneous test procedures were reviewed and it was found
that none of the derivations from standard procedures would significantly
affect the test results.  A detailed response to the comments follows.

     Plant B

     The commenter notes that:

     (1)  there is no indication of which stacks were observed,

     (2)  wind direction is recorded as variable,

     (3)  an improper background was used.

     Review of the data indicates the stacks being observed were recorded
and the sky was used as the background.  Wind direction is not relevant,
because to observe the plume at anv other than at a right angle to plume
direction, increases observed opacity or there is no affect at all.

     Plant C

     The commenter notes that on one day of.the observations, wind direction
was not recorded.

     The method states that the observer should take sun angle more into
consideration than wind direction when choosing an observation position.
Furthermore, failure to read at right angles to the plume direction generally
would result in higher opacity readings, or there is no effect at all.  There-
fore, the test data are valid for the purposes for which they were used.
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     Plant D

     The commenter notes that,

     (1)  two-thirds of the opacity readings were discarded because they
exceeded 10 percent opacity,

     (2)  on August 6, both observers were facing the sun,

     (3)  on August 6, one observer was not at right angle to the plume.

     The data for the May, 1974, test were discarded, not because the test
exceeded the 10 percent opacity, but because the control device was not
functioning properly at the time of the observations.  The effect on observed
opacity caused by the inspectors' positions of either facing the sun or
being at right angle to the plume, would be to increase the opacity reading.
Therefore, the data are valid for the purposes for which they were used.

     (c)  The fact that plants with scrubbers may have a slight advantage
should not preclude the setting of an opacity standard.  In fact, any operator
of an affected facility has the choice of choosing the type of control system
to be used when the facility is designed.'  Thus, there is no real discrimination,

     7.  LM-14

     Comment:

     It is counter proposed that a new limit of 0.3 kilograms per megagram,
or 0.6 pounds per ton for lime kirns be set.   This will  achieve about one-half
of the efficiency improvement embodied in the EPA proposal.   A 0.35 pounds per
ton limit is proposed for hydrator emissions  to replace the  0.15 pound per ton
limit proposed by EPA.

     Response;

     A review of all  the data,  including test results,  cost  and the efficiency
of control  equipment available,  and the economic  impact  the  EPA standard  would
have on the lime industry,  indicates that the emission  limitations  for lime
kilns and hydrators are reasonable and achievable.   The  support'data  submitted
for the counter proposed standards were not adequate to  refute the  data
developed by EPA to support the  proposed standards.

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                            APPENDIX A
     This is a continuation of section A.3 entitled "Chronolog" of
Appendix A, Standards Support and Environmental Impact Statement,
Volume I;  Proposed Standards ot Performance tor Lime Manuracturing
Plants.~
April 20, 1977



May 3, 1977


June 16, 1977
September 13 to
October 4, 1977

October 26 to
November 2, 1977

October 28, 1977
Concurrence by EPA Assistant Administrators
completed and the proposed standard signed
by the EPA Administrator.

The proposed standard published in the
Federal Register.

Public meeting held at Research Triangle Park,
North Carolina, for National Lime Association
presentation.

Review of the standards package by the EPA
Working Group.

Review of the standards package by the EPA
Steering Committee in Mashington, D. C.

Drafts of the final standards and the comment
and response document sent to commenters, the
National Lime Association and several lime
companies.
                                 17

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                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
1. REPORT NO.
     EPA-450/Z-77-p07b
4. TITLE ANDSUBTITLE
 Standards Support  and  Environmental Impact  Statement,
 Volume II:  Standards  of Performance for Lime
 Manufacturing Plants
                                                           3. RECIPIENT'S ACCESSI Of*NO.
             5. REPORT DATE
                October.  1977
             6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
                                                           8. PERFORMING ORGANIZATION REPORT NO.
 Emission Standards  and  Engineering Division
9. PERFORMING ORGANIZATION NAME AND ADDRESS
 U. S. Environmental  Protection Agency
 Office of Air Quality  Planning and Standards
 Research Triangle  Park,  North Carolina  27711
                                                           10. PROGRAM ELEMENT NO.
             11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
 DAA for Air Quality Planning and Standards
 Office of Air  and  Waste Management
 U.S. Environmental  Protection Agency
 Research Triangle  Park, North Carolina  27711
                                                           13. TYPE OF REPORT AND PERIOD COVERED
             14. SPONSORING AGENCY CODE

                  EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
 Standards of performance for the control of  participate matter emissions  from
 affected facilities  at  new and modified lime  manufacturing plants are  being
 promulgated under  the authority of sections  111,  114,  and 301(a) of the Clean Air
 Act, as amended    The standards would require that particulate matter  emissions be
 reduced by over 99 percent below the uncontrolled levels, and by about 70 percent
 below the emission levels being achieved by  existing sources controlled to meet
 typical State standards.  Volume 1 discusses  the  proposed standards, and  an  analysis
 of the associated  environmental and economic  impacts is included in this  document.
 This volume contains a  summary of the public  comments  on the proposed  standards
 and EPA's responses, as well as summary economic  and environmental impact statements.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.IDENTIFIERS/OPEN ENDED TERMS
                           c.  COS AT I Field/Group
 Air pollution
 Pollution control
 Standards of performance
 Lime manufacturing  plants
 Particulate matter
Air pollution control
13. DISTRIBUTION STATEMENT
 Unlimited
19. SECURITY CLASS (This Report)
 Unclassified
                                                                         21. NO. OF PAGES
20
                                              20. SECURITY CLASS (Thispage)
                                               Unclassified
                                                                         22. PRICE
EPA Form 2220-1 (9-73)

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