The floor emission levels for semivolatile metals for cement and lightweight aggregate kilns are 650 g/dscm and 1,700 g/dscm, respectively. Part of our data base consisted of test conditions in which extra semivolatile metals were spiked into the feed stream prior to testing, and this may account in part for why these floor levels are elevated beyond what is thought to be MACT levels of control. For that reason, we looked at the cost of going beyond the floor for SVM. The Agency considered a cost-effectiveness of $500,000 per megagram of reduced emissions in context of concern about the health effects of lead emissions, particularly to children, and considering that the floor emission level for incinerators is 240 g/dscm.
For more information, see http://www.epa.gov/epaoswer/hazwaste/combust/.
The semi-VOA metal standard for cement/lightweight aggregate kilns that reduce lead/cadmium emissions at a cost of approximately $500,000 per megagram. How can EPA consider these standards to be cost-effective?
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