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
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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
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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.
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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
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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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