Document 66va6OQ5Zawq124EbooMKww1

Injection; and Heat Exchangers) will collectively use an additional 1.77 trillion Btu's of energy annually (equivalent to unnecessarily burning about 88,000 tons of coal annually): This wasteful use of natural resources constitutes environmental harm. NI.A believes that a technology should not be considered "available" if its use would cause more harm to the environment that the benefits it would confer. 4. The Standards Cannot Be Implemented with Cost-Effective Technology No cost-effective technology is available, or could be available, to implement the standards established in the I.ime Rule. EPA estimates that the rule will cost the industry up to 52.4 billion over the next 20 years ($485 million in capital investment) or 5175 million annually. (NLA's cost estimates arc even higher: 5924 million capital investment and 5180 million annually.) As noted above, EPA's own risk assessment showed that even without controls, emissions from the industry presented an acceptable level of risk with an ample margin of safety. As a result, any costs expended to meet these standards are unreasonable, and, by definition, not cost-effective. This factor is particularly significant for small business sources that cannot spread compliance costs across multiple locations, and the U.S. Small Business Administration's Office of Advocacy raised serious concerns about the Lime Rule's feasibility and cost, leading EPA to reopen the rule for additional proceedings to address issues affecting small businesses. For all the reasons stated above, none of the technologies identified to implement standards in the Limo Rule are available within the period between the present and the compliance date of July 16, 2027, and an exemption should be granted extending the compliance date until July 16, 2029, to all the sources on the attached list, while EPA reconsiders the rule. B. 1T IS IN THE NATIONAL SECURITY INTERESTS OF THE UNITED STATES TO PROVIDE AN EXEMPTION FROM TILE LIME RULE COMPLIANCE DATE Lime production is essential to the national security of the United States. EPA's Lime Rule, if implemented, would both increase the cost of limo, and restrict the availability of lime products. This would have a negative impact on multiple other industries and activities, harming the national security interests of the United States. The U.S. Geological Survey has noted that the major markets for lime, in descending order of consumption are "steelmaking, chemical and industrial applications (such as the manufacture of fertilizer, glass, paper and pulp, and precipitated calcium carbonate, and in sugar refining), flue gas treatment, construction, water treatment, and nonferrous-metal mining." These arc all essential industries. See Regulatory Impact Analysis Jiff the Final Amendments to the National Emission ,S'iandards fie Hazardous Air Pollutants: Lime Manufilcturing Plants, EPA-452/R-24-014 (Juno 2024) at pp. 29-30. 8 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000249-00008 SC_EVERSPLIT0006024