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Return to Advocacy > Regulatory Comments > Environmental Protection Agency (EPA)
June 20, 2008
Docket ID No.: EPA-HQ-OAR-2007-1018
United States Environmental Protection Agency
EPA Docket Center (6102 T)
New Source Performance Standards for Nonmetallic Mineral Processing Plants Docket
1200 Pennsylvania Ave., NW
Washington, DC 20460
Re: The following are comments submitted on behalf of the Industrial Minerals Association – North America (IMA-NA) regarding the proposed amendments to the Standards of Performance for Nonmetallic Mineral Processing Plants (NMPP).
The Industrial Minerals Association – North America (“IMA-NA”) appreciates the opportunity to comment on the proposed amendments to the New Source Performance Standards (“NSPS”) for Nonmetallic Mineral Processing Plant(s) (“NMPP”) that the Environmental Protection Agency (“EPA”) recently published in the Federal Register on April 22, 2008.
IMA-NA is an association that represents 46 companies who produce industrial minerals such as ball clay, bentonite, borates, calcium carbonate, feldspar, industrial sand, mica, soda ash and talc, and 60 associate member companies that provide goods and services to the industry. IMA-NA typically represents 75 percent or more of the production for each of these minerals in the United States. IMA-NA members are committed to the goals of sustainable development and operating in an environmentally friendly manner. The proposed changes to NSPS Subparts OOO and UUU stand to impact the majority of our membership.
IMA-NA would like to congratulate EPA on their work in completing these proposed revisions. IMA-NA is largely supportive of many of the provisions contained in the proposed rule. We believe a number of these amendments will work to improve the efficiency of the inspection process and decrease the burdens on both the inspector and operator. To this extent, IMA-NA supports the proposed visible emission (VE) limit being based on five 6-minute averages during
a 30 minute observation period. IMA-NA is also supportive of the proposed amendment for the advanced notification of performance tests being reduced from 30 days to 7 days. Such
provisions will ensure that there will be a more efficient inspection process in the future.
While IMA-NA is largely supportive of many provisions within the proposal, there are some issues that we would like to see addressed prior to the rule being finalized next year. IMA-NA is
disappointed at the sharp reductions proposed in particulate matter (PM) and fugitive VE limits for crushers, screens, and conveyors. While it is accurate that many of our operations currently are able to meet these limits, the costs associated with ensuring that they reach those new limits is substantial higher than EPA has estimated in the proposal. IMA-NA would like to stress that an even further reduction in these limits would be very difficult for our members to achieve without extraordinary costs and burdens.
The following are some issues IMA-NA would respectfully request EPA address regarding the proposed amendments prior to the amendments being finalized:
I. Suggested Changes in Preamble for Shredders
IMA-NA would like to suggest that EPA amend the text as related to “crushers” to further address shredders, slicers and deagglomerators. While the text in the definition of Crusher and Crushing appears to be adequate, we believe that there should be a clarification in the preamble to better describe the equipments handling of clumps and the intent to exclude this equipment from the definition of a crusher. IMA-NA would like to suggest the following text be used in lieu of the text used in the proposed rule:
Crushers. Industry representatives requested that we clarify the meaning of crusher and grinding mill by adding a definition of crushing. The new definition of crushing would help to clarify that crushers and grinding mills do not include equipment that simply breaks up clumps of material (e.g., certain deagglomerators, slicers or shredders processing material that has become stuck together naturally or during hauling/processing) but does not further reduce the size of the material. The current definition of crusher employs the word crush and the current definition of grinding mill uses the word crushing. To capture both terms, we are proposing to add a new definition: Crush or crushing which means to reduce the size of nonmetallic mineral material by means of physical impaction of the crusher or grinding mill upon the material.
II. Exemption for Vents in 60.672 (e)(2)
IMA-NA would also like to seek clarification on another issue. Baghouses have been exempt
from the applicable stack PM concentration limit and associated performance testing. IMA-NA
is in agreement that this exemption should exist; however, it remains unclear as to why Vents in 60.672 (e)(2) are being forced to meet the applicable stack emission limits and compliance
requirements.
Building vents and individual storage bin baghouses have the same opacity limit of 7 percent. Vents are likely to have very low velocities. Even with method 5I, there is the potential for problems with isokinetic conditions, and long testing times to get the required sample volume. With a 7 percent opacity limit and low velocities, actual mass emissions from a vent would be very low. Vents are also more likely to be in locations that are difficult to access to the point of potential safety concerns arising. It would seem appropriate that if baghouses controlling emissions from individual enclosed storage bins are exempt from stack PM, then the building vents should be exempt from the applicable stack PM concentration limit and associated performance testing as well.
III. Georgia Mining Association Economic Analysis
IMA-NA has had the opportunity to review the comments prepared by the Georgia Mining Association (“GMA”) related to the economic impact of this proposed rule. IMA-NA supports the findings by GMA in their economic analysis. While a significant number of stack tests show compliance with a standard of 0.014 gr/dscf, operators have been able to accomplish this by overcomplying with the current standards as a matter of risk management. In order to meet this new lower standard, future baghouses will have to be designed for significantly higher efficiencies than are currently available. IMA-NA supports GMA’s request that EPA review the economic analysis of the costs involved for operators to achieve this new proposed standard.
IV. Conclusion
IMA-NA appreciates the opportunity to comment on the proposed amendments to the NMPP. We are largely supportive of many of the provisions included within the proposal, especially those which will increase the efficiency of the inspection process and ease the burdens on both the operators and inspectors. We respectfully request that EPA review the proposed changes included herein and include them in the final rule. IMA-NA further requests EPA to revisit the economic analysis of the costs to operators in achieving the new lower standard prior to finalizing the rule. Thank you for your attention to this very important matter.
Respectfully Submitted,
Mark Ellis
President
Cc: Office of Information and Regulatory Affairs, Office of Management and Budget; Mr. Bill Neuffer, EPA
173 Fed. Reg. 21559 (April 22, 2008)
240 CFR 60.670
340 CFR 60.730
4See 40 CFR 60.675 (c)(3) 73 Fed. Reg. 21575 (April 22, 2008)
5See 40 CFR 60.675 (g) 73 Fed. Reg. 21575 (April 22, 2008)
673 Fed. Reg. 21562 (April 22, 2008)
7See Comments filed by the Georgia Mining Association (p.4 -5). GMA completed an economic analysis that showed the possible costs companies faced could be as high as $100,000 per baghouse to achieve the proposed new limits.
873 Fed. Reg. 21564 (April 22, 2008)
973 Fed. Reg. 21573 (April 22, 2008)
1073 Fed. Reg. 21573 (April 22, 2008)
11See Comments filed by Georgia Mining Association (p. 5)
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