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Gossman Consulting, Inc
 
GCI TECH NOTES© 
Volume 5, Number 01            A Gossman Consulting, Inc. Publication            January, 1999

MACT the Knife
Jim Woodford

The fate of the hazardous waste combustor (HWC) maximum achievable control technology (MACT) is now in the hands of EPA management.  It is anticipated that OMB will have the rule sometime in February with eventual release by the end of June, 1999.  This Tech Notes is a brief review of what has occurred up to this point and speculation on what we might expect as a final rule. The table below is a reproduction of Table II. F (page 24226) for cement kilns from the HWC notice of data availability (NODA) published in the Federal Register on May 2, 1997.

Table II.F. - Revised Standards for Existing and New Cement Kilns1 [burning hazardous waste]
 
HAP or HAP Surrogate
Existing Sources
New Sources
Proposed
standard
Revised
standard
Proposed
standard
Revised
standard
D/F (ng TEQ/dscm) 0.20 0.20 0.20 0.20
Hg (Fg/dscm) 50 72 50 72
PM (gr/dscf) 0.030 0.030 0.030 0.030
HCl/Cl2 (ppmv) 630  120 67 120
CO (ppmv) 100 100 100 100
HC (ppmv) 
     Main Stack2
     By-Pass

20 
6.7

20 
10

20 
6.7

20 
10
SVM (Fg/dscm) 57 670 55 670
LVM (Fg/dscm) 130 63 44 63
1 All emission levels are corrected to 7% O2.
2 Not applicable to preheater and/or precalciner kilns.

Many comments were submitted in response to the 4-19-96 publication of the HWC MACT and another round of comments were submitted in response to the 5-2-97 NODA.  Many of you submitted comments so there is no need to rehash all of that here.  In addition, Gossman Consulting, Inc. published Tech Notes containing HWC MACT information or specific comments in April, June, July and November 1996 plus January, March, May and August 1997.  Copies of these Tech Notes can be obtained by simply calling (847)683-4188 or downloading from the GCI Internet web site at http://gcisolutions.com. Some of the more significant concerns involved temperature control of PCDDs/PCDFs, regulation of raw materials, the accurate measurement of HCl emissions and appropriate metals limits for both semi-volatile metals or SVM, (lead and cadmium) and low volatility metals or LVM (arsenic, berillium, chromium and antimony).

EPA is being very tight lipped about specific limits in the final HWC MACT currently being reviewed by EPA management.  Various sources have indicated some of the following; that the HCl limits have moved back towards the original proposal numbers, that mercury numbers are either in the 60-80 Fg/dscm range or maybe at 120 Fg/dscm, that the SVM limit may be 240 Fg/dscm and that it may be allowable to substitute hexavalent chromium for total chromium.  Dioxins limits may be the same for Hazardous and Non-hazardous cement kilns.  But your guess is as good as any other guess at this time.

The following table addressing incinerator limits is a reproduction of Table II. E (page 24219) from the HWC notice of data availability (NODA) published in the Federal Register on May 2, 1997.

Table II. E Revised Standards for Existing and New Incinerators1 [burning hazardous waste]
 
HAP or HAP surrogate
Existing sources
New sources
Proposed
standard
Revised
standard
Proposed
standard
Revised
standard
D/F (ng TEQ/dscm) 0.20 0.20 0.20 0.20
Hg (Fg/dscm) 50 40 50 40
PM (gr/dscf) 0.030 0.015 0.030 0.015
HCl/Cl2 (ppmv) 280 75 67 75
CO (ppmv) 100 100 100 100
HC (ppmv) 12 10 12 10
SVM (Fg/dscm) 270 100 62 100
LVM (Fg/dscm 210 55 60 55
1All emission levels are corrected to 7% O2

The main overall concern on everyone's mind as we await the issuing of the final HWC MACT is where do I fit in?  There are of course many unanswered questions.  How are my emissions going to fit into the scheme of things?  Will I be forced to change raw materials?  Am I already in compliance?  Can I rely on the numbers from my last round of testing?  Many of these questions will need to be answered in the upcoming months.  There is also the so called "non-hazardous" [NHW] MACT for cement kilns that do not burn hazardous waste which has been projected to come out in the next few months as well.  The following table reflects information from Table 2 (page 14187) from the March 24, 1998 National Emissions Standards for Hazardous Air pollutants; [NESHAP] Proposed Standards for Hazardous Air Pollutants [HAPs] Emissions for the Portland Cement Manufacturing Industry.

Table 2. - Summary of Proposed Emission Limitsa for Affected Sources at Portland Cement Plants
[non-hazardous waste burning]
 
Affected source and pollutant Emission limit for existing sources Emission limit for new sources
NHW kiln and NHW in-line kiln/raw millb PM

NHW kiln and NHW in-line kiln/raw mill D/Fb,c
 
 
 

NHW kiln and NHW in-line kiln/raw mill THC

Clinker cooler PM
 
 

Raw material dryer and materials handling processes (raw mill system, finish mill system, raw material storage, clinker storage, finished product storage, conveyor transfer points, bagging, and bulk loading and unloading systems) PM.

Raw material dryer THC

0.15 kg/Mg dry feedd and opacity levelb no greater than 20 percent.

0.2 ng TEQ/dscm or 0.4 ng TEQ/dscm with PM control device operated at lees than or equal to 204°C.
 

None
 

0.05 kg/Mg dry feed and opacity level no greater than 10 percent.

10 percent opacity
 
 
 
 
 
 
 

None

0.15 kg/Mg dry feedd and opacity levelb no greater than 20 percent

0.2 ng TEQ/dscm or 0.4 ng TEQ/dscm with PM control device operated at less than or equal to 204°C.

50 ppmvd (as propane).
 

0.05 kg/Mg dry feed and opacity level no greater than 10 percent.

10 percent opacity.
 
 
 
 
 
 
 

50 ppmvd (as propane).

aAll concentration limits at 7% oxygen.
b Includes main and alkali bypass stacks.
cApplies to both major and area source Portland cement plants.
dIf there is an alkali bypass stack associated with the kiln or in-line kiln/raw mill, the combined PM emission from the kiln or in-line kiln/raw mill and the alkali bypass must be less than 0.15 kg/Mg dry feed.

 The issue with the greatest potential significance for the NHW MACT is what constitutes "reconstruction"?  The "costs less than 50%" rule clearly applies to reconstruction but is it 50% of the part being replaced or is it 50% of the entire facility?  If it is the part being replaced, then a new ESP would put you into the reconstruction category (and consequently more stringent regulations) but if it is 50% of a new facility then you would be in the clear on almost all upgrades.  The bottom line is that you need to know where your facility falls with respect to applicable regulations and plans need to be made (if they are not already in place) for making an up-to-date determination for your facility.  Next month's Tech Notes will suggest a plan to make that determination.