|Gossman Consulting, Inc|
EPA has promulgated the long delayed MACT rule for cement kilns that do not use hazardous waste fuel. (http://www.access.gpo.gov/su_docs/fedreg/frcont99.html). The rule sets a three year compliance schedule, primarily for controls on dioxin emissions and particulates. The purpose of this Tech Notes is to identify key elements of the rule that might be potential stumbling blocks or otherwise overlooked.
Performance Testing Schedule
Dioxin testing is required every 2.5 years while particulate testing is required every five years. More importantly, retesting for dioxins must be done within 90 days of a "significant change in raw material components or fuel." The example given is the initiation or increases in solid waste (non-hazardous) as a fuel. Elsewhere in the document, EPA acknowledges that dioxin emissions come from organics in the raw materials and not the fuel. Interpretation of "significant change" thus becomes problematic.
O & M Plans
A written Operations and Maintenance Plan for both the kiln system and all APCD systems in the plant is required. An important compliance objective will be to develop a plan that meets the require-ments, including on-going documentation, without overburdening the plant or setting up unrealistic plans which would lead to illusionary violations. The O & M Plan must include procedures for an annual inspection of the combustion system. Results of this inspection are to be included in any semi-annual reporting.
Area Versus Major Source Determination
The preamble to the rule requires a facility to make a determination regarding its classification as either an area or major source including metals, organics and HCl. This preamble requirement does not seem to have made its way into the final rule language itself. In addition, there appears to be no apparent difference between the compliance requirements of the two classifications. Why spend money to make this determination if it is not required by the rule (only stated in the preamble), and when there is no purpose in so doing?
APCD Temperature Monitoring
Part of the dioxin control strategy includes setting temperature limits on the APCD inlet temperature based on dioxin testing. On-going monitoring requires a three-hour rolling average limit be monitored, recorded, and complied with. This compliance strategy involves calculating the rolling average using data prior to a shut-down and continuing upon start-up to constitute three hours worth of data. However, no definition of start-up or shut-down is provided. Is it kiln feed? kiln rotation? draft fan? fuel feed? The rule also requires that the temperature sensor calibration be verified at least once every three months.
Particulate Matter CEMs
EPA will require particulate CEMs but has deferred the deadline for installation for a future rule. They are strongly encouraging PM CEMs installation and have provided a "temporary exemption", for particulate emission limits in order to calibrate and test PM CEMs. It is not clear that this "temporary exemption" applies to limits that facilities have under existing state permits.
Raw Mill On and Off Testing
Under the new rule, dioxin testing will be required both when the raw mill is on and off for those plants with in-line raw mills. Plants with in-line raw mills frequently experience higher dioxin emissions while raw mills are off. The rule will require establishing separate APCD inlet temperature limits for both conditions. The change in limits would occur after a "transition period" which is not clearly defined. Operating in the "mill-off" condition for over nine hours to gather dioxin emission data may be a challenge for some facilities.
The final rule is not all bad. The THC limit for reconstructed kilns was removed. However, an anticipated averaging allowance for in-line raw mills seems to have been left out. As with many EPA rules, the issuance of this final regulation creates nearly as many questions as answers. The industry will need to initiate investigative, planned programs soon to achieve compliance three years from now.
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