Comment submitted by John Mousa, Ph.D., Pollution Prevention Manager, Alachua County Environmental Protection Department (ACEPD)

Alachua County is concerned about lack of MACT standard for Mercury emissions from Portland Cement plants. Alachua County requests that USEPA consider any or all of these changes to the proposed rules: 1) require the use of activated carbon technology to scrub mercury from cement kiln emissions; 2) ban the use of high mercury content flyash from power generating utilities in cement raw materials; 3) start collecting data on actual mercury content of raw materials used by cement kilns around the nation for the purpose of potentially setting national standards at a later date; 4) require continuous monitoring of actual mercury emissions from cement kiln stacks; and 5) allow individual states to set local standards for mercury emissions. Full comments in Attached Letter from ACEPD.