Document 654mw60GneK2nOXbYoVqYOkL9

successfully achieve the mercury standards before the current compliance date. Thus, this technology should be deemed currently unavailable. Overall, EPA's candidate control technologies identified as necessary for lime kilns to comply with the Proposed Rule will require significant research and development, pilot plant experimentation, and great expense (and uncertainty). Furthermore, their application to achieve the very low levels of HAP emissions from lime kilns is far from demonstrated in practice and may not be achievable for many lime kilns. Accordingly, a two-year extension of time for compliance is clearly appropriate for all affected sources in the lime industry. For additional information on issues with control technologies in the lime industry, see Appendix A of the National Lime Association comments on EPA Lime Rule, EPA-HQ-OAR 2017-0015 (Feb. 21, 2023). 4. The Technologies That Would Be Required Under the Rule Witl Cause More Environmental Harm Than Benefit As noted above, EPA found that to comply with the standards for organic HAPs some sources would need to install RTOs. These units require substantial energy to operate, normally provided by natural gas. Combustion of gas in these units will generate many tons of carbon dioxide and other greenhouse gases, as well as NOx and carbon monoxide that would be released into the atmosphere. In addition, any natural gas unnecessarily consumed in this process would be a wasted resource that could have been used for another beneficial purpose such as heating homes, producing cleaner electricity, or storage for future use. Since EPA's risk assessment shows that use of these devices is not necessary to address any unacceptable risk, their operation will result in more potential harm to the environment than benefit. The treatment technology that will be needed to address DT and mercury is ACI. Use of this technology is likely to result in carbon residues appearing in lime kiln dust, which is a byproduct of lime manufacturing, and which is typically sold in commerce. The presence of carbon residues in this material may render it unusable and thus unsalable, increasing the amount of solid waste that would require disposal. Again, this constitutes unnecessary harm to the environment. To control HC1, EPA finds that lime plants will need to use DSI, in which lime product is injected into the kiln gases--wasting that product. Lime is a valuable resource that can be used for many environmentally beneficial purposes. But EPA's rule would force lime companies to use significant amounts of their own product to reduce HC1 emissions that EPA has twice found to pose acceptable risk with an ample margin of safety. Instead of using that lime for unneeded HC1 emissions reductions, that same lime could be used to make other much more significant environmental improvements. For example, lime is used to scrub sulfur dioxide emissions, to treat drinking water, to treat acid mine drainage, and in many other applications. EPA's own analysis acknowledged that the imposition of new emissions standards will result in secondary impacts from projected controls required for compliance. EPA expects lime plants to use 1.12 million additional gallons of water per year to address HC1 controls with wet packed tower gas absorbers ("WPTGAs"). EPA predicts that solid waste from WPTGAs, Dry Sorbent Injection, and Activated Carbon Injection will increase solid waste by 13,400 tons per 7 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000258-00008 SC_EVERSPLIT0006054