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GCI TECH NOTES©
Volume 6, Number 4 A Gossman Consulting, Inc. Publication November 2001
by
David Constans
As
everyone knows, the US Court of Appeals for the DC Circuit issued a
final ruling
on July 24, 2001 regarding the HWC MACT regulation.
Many are familiar with the gist of the ruling; that an interim
standard will be put in place and that a new final rule will be written
and
promulgated by June 14, 2005. This Tech
Notes will present the changes applicable for cement kilns from this
court
ruling. Warning – The Interim
Standards Rule and Final Standards Rule proposed by the EPA and
submitted to
the Court have not been released for publication. They could be
rejected
completely or be changed.
The EPA
will promulgate on or before February 14, 2002 a set of interim
standards. These standards will be the
existing HWC
MACT rule with certain court-mandated changes.
These changes Fall into three areas: 1.
Changes to emissions limits that must be met; 2.
Revisions to requirements for performance
testing compliance, applicable only to this interim emissions standards
period; 3. Changes
to monitoring and compliance provisions.
In brief,
the emissions limitation changes in the proposed interim standards for
cement
kilns are only applicable for mercury and the semi volatile metals
(lead plus
cadmium). It also appears that the
standard allowing the use of a hazardous waste mercury MTEC feed rate
limit is
to be a substitute to the requirement of 63.1204(a)(3) (Emission limits
for
existing kilns) and 63.1204(b)(2) (Emissions limits for new kilns) as
opposed
to a change in values in 63.1206(b)(10) (Alternative standards for
existing or
new cement kilns). This is important
because there are requirements in 63.1206(b)(10) which could be quite
onerous,
such as petitioning for this alternative standard and providing
extensive
justification and data.
The table
below presents the current existing HWC MACT emissions limits and the
proposed
interim standards limits.
Compliance
Testing and Testing Interval Changes
Section
63.1207, Performance Testing Requirements, is amended for the “Interim
Standards Rules” period to; 1) allow data-in-lieu of, regardless of the
age of
the collected data, to serve as documentation of compliance with the
interim
standards provided the data meets QA requirements and is sufficient to
establish operating parameter limits.
Previously data-in-lieu of could be not be taken from a test
sequence
initiated before March 30, 1998; 2) no performance tests after the
initial
performance test is required. The HWC
MACT regulation required a 61 month or less interval between
comprehensive
performance tests; 3) the confirmatory test is eliminated for the
interim
standards rules period. The HWC MACT
regulation had called for a 31 month or less interval between a
comprehensive
performance test and a confirmatory performance test.
Changes to
Monitoring or Compliance Provisions
A totally revised
Start-up, Shutdown and Malfunction Plan requirement is being proposed
as a part
of the interim standards rule.
It is also
proposed to delete the minimum power requirements for ”ionic wet
scrubbers”
(these are not the ESP’s commonly in use at cement kilns)
and to
delete the carbon bed age confirmatory emissions test.
Since there are no carbon beds being
utilized at cement kilns this will be of no interest to cement
manufacturing
facilities.
The EPA
has proposed a list of amendments to the HWC MACT rule in conformance
to the
court ruling. These are to be
promulgated on or before February 14, 2002.
Unlike the interim standards above these rules actually amend
the HWC
MACT rule. Eleven of the 13 proposed
amendments were revisions made to the 1999 HWC MACT rule in the direct
final
rule published on July 3, 2001. These
revisions are the result of petitions and data provided by the
regulated
community requesting clarification or modif-ication of specific
implementation,
monitoring or reporting requirements.
None of these proposed amendments affect the emission standards. The remaining 2 proposed amendments are in
the same vein, modifications of implementation or monitoring provisions.
Virtually
all of these proposed amendments are old news.
Their inclusion in the Final Amendments Rule is a way for the
EPA to
incorporate these modifications into the HWC MACT regulation. If you wish to have additional information
about these proposed amendments call GCI at 847-683-4188 and one of our
consultants will be happy to discuss your concerns.
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ORIGINAL HWC MACT RULE |
PROPOSED INTERIM
STANDARDS RULE |
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Dioxin Emission <0.2
TEQ ng/dscm @7%O2 or >0.2 but < 0.4
TEQ ng/dscm @7%O2 with APCD < 400°F |
Dioxin Emissions No Change |
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Mercury Emissions Limits Existing Kilns 120 ųg/dscm @7%O2 New Kilns
56 ųg/dscm @7% O2 (Use of MTEC feedrate
limits required petition and extensive data support.) |
Mercury Emissions Limits Existing Kiln No Change New Kilns
120 ųg/dscm @ 7% O2 Allows use of a MTEC
feedrate limit calculated not to exceed 120 mg/dscm @ 7% O2 without petition or data
support. |
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Semi Volatile Metals (Pb
& Cd) Existing Kiln 240 ųg/dscm @ 7% O2 New Kiln
180 ųug/dscm
@ 7% O2 |
Semi Volatile Metals (Pb
& Cd) Existing Kiln 330 ųg/dscm @ 7% O2 New Kiln
No Change |
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Low Volatile Metals (As,
Be & Cr) Existing Kiln 56 ųg/dscm @ 7% O2 New Kiln
54 ųg/dscm @ 7% O2 |
Low Volatile Metals (As,
Be & Cr) Existing Kiln No Change New Kiln
No Change |
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Particulate Emissions < 0.15 kg/Mg dry feed
and > 20% Opacity |
Particulate Emissions No Change |
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THC and CO Facility selects
appropriate requirements from options offered in regulation |
THC and CO No Change |
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HCL and Chlorine 130 ppmv dry @ 7% O2 |
HCL and Chlorine No Change |