Attached please find the comments of the Portland Cement Association (PCA). If you have any questions or would like to discuss these comments in further detail, please contact Elizabeth Horner, PCA's Director and Assistant Counsel for Government Affairs, at 202-719-1973 or ehorner@cement.org.
Additions to List of Section 242.4 Categorical Non-Waste Fuels: Other Treated Railroad Ties
Activity
Portland Cement Association filed 1 comment on this docket between Jan 5, 2017 and Jan 5, 2017. 0 other organizations filed here. The comment window closed 3493d ago.
What Portland Cement Association filed (1)
Abstract
This action proposes to add other treated railroad ties to the list: 1) creosote-borate treated railroad ties that are processed and then combusted in the following types of units: units designed to burn both biomass and fuel oil as part of normal operations and not solely as part of start-up or shut-down operations, and units at major source pulp and paper mills or power producers subject to 40 CFR 63 Subpart DDDDD that combust CTRT and had been designed to burn biomass and fuel oil, but are modified (e.g. oil delivery mechanisms are removed) in order to use natural gas instead of fuel oil, as part of normal operations and not solely as part of start-up or shut-down operations; 2) copper naphthenate treated railroad tie combusted in units designed to burn biomass, and 3) copper napthenate-borate ties combusted in units designed to burn biomass.
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