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## LEAGUE OF WOMEN VOTERS O F TEXAS 1212 Guadalupe St. , Suite 107 • Austin , TX 78701-1800 (512) 472-1100 • Fax (512) 472-4114 • lwvtexas@lwvtexas

.org

August 16, 2012 EPA Docket Center (61 02T) National Emission Standards for Hazardous 

### Air Pollutant From the Portland Cement Manufacturing Industry Docket Docket ID No. EPA-HQ-OAR-20 11-0817 1200 Pennsylvania Ave., NW Washington, DC 20460
On behalf of the League of Women Voters ofTexas and the League ofWomen Voters of the United States, we want to thank you for holding this hearing in Arlington , Texas. Unfortunately, we must express our disappointment for EPA ' s proposal to dilute the previously proposed regulations to reduce and better monitor the emissions ofthe Portland cement manufacturing industry. Texas has 11 ofthe 93 cement manufacturing facilities in the U.S. While the 93 faci lities average less than two kilns per facility , many ofthe facilities in Texas have a number ofkilns, including the largest, TXl in Midlothian, with five kilns. Ofthe 1 1 cement manufacturing facilities in Texas, eight are arrayed along the limestone deposits ofthe Interstate 35 corridor between Dallas-Fort Worth to the North and San Antonio to the South. This area had a 2010 population of almost 11 million, representing over 43 percent ofthe Texas population

. So the impacts ofthe cement kiln emissions affect a large population.
Our specific comments are as follows: Compliance deadline. We support implementation in 2013 as originally proposed. Delaying implementation of stricter emission standards until September 2015 would keep our air dirtier and embolden the industry to continue its efforts to defeat even these watered-down standards. Mercury continuous emission monitors CCEMS). We continue to support CEMS for mercury emissions because we understand that when EPA monitored mercury emissions at select cement plants , their emission readings were significant ly higher than the formula-based, self-reported numbers currently used to report emissions. Actual mercury emission data are needed to ascertain the probable impact ofemissions on the surrounding watersheds. We also support CEMS for monitoring other emissions because without accurate monitoring, it is difficult to determine compliance with emission standards.Emission Standards for Startup, Shutdown, and Malfunction

. We support emission standards for startup, shutdown, and malfunction equal to normal operating conditions. We do not support industry monitoring of startups and shutdowns via recordkeeping. as the new regulations propose
. Standards for Mercury, Hydrogen Chloride, and Total Hydrocarbons (THCs). We support keeping the emission standards for these pollutants at their current proposed levels.
Particulate Matter (PM

- We are concerned about the new particulate matter emission standards given the negative health impacts ofthis form ofair pollution.
Midlothian, Texas, in the Dallas-Fort Worth Consolidated Metropolitan Area (CMSA) , has the largest concentration ofcement plants 

### in the U.S. The Midlothian cement kilns are also the largest stationary source of air pollution in the Dallas-Fort Worth (CMSA). Thus the previously proposed emission standards would greatly enhance the region's ability to meet air quality standards.
Thank you for the opportunity to comment on these proposed regulations. Please reconsider the dilution ofthe previously approved rules , which had the potential to greatly enhance the air and water quality in Texas and the nation.
Sincerely,

Linda Krefting, President League of Women Voters ofTexas
Eli sabeth MacNamara, President League ofWomen Voters ofUnited States