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Gossman Consulting, Inc.

 

NESHAPs MACT Rule

Frequently Asked Questions

 

 

Question 1

 

Am I “area” or “major”?  How do I determine this?

 

 

 

Answer 1

 

Any cement plant which emits more than ten tons per year of any one HAP or more than 25 tons per year of any combination of HAP is a “major” source.  All the rest are “area” sources.  Determination is based on examining all plant emissions for HAPs and totaling the results for individual and aggregate HAPs (§63.2).  In this manual, see Section II-C.  The EPA stated when proposing the rule in 1998 that “most if not all cement plants are major sources.”

 

 

 

Question 2

 

What difference does it make if I am “area” or “major”?  Is there a savings in demonstrating my facility is only subject to the “area” rules?

 

 

 

Answer 2

 

Area sources need not be concerned with monitoring particulate emissions from a number of sources in the facility (§63.1340).  In this manual, see Section II-C.

 

 

 

Question 3

 

I understand that there is now a limit on clinker production as there is for kilns which use hazardous waste as fuel, is this correct?

 

 

 

Answer 3

 

Not exactly.  The performance test is required to be executed at the “highest load or capacity level reasonably expected to occur.”  (FR 64 page 31928, 63.1349)  However, monitoring production rate is not required, nor is there a provision to report exceedences of the production rate utilized in the performance test.  But, think of this from the EPA enforcement person’s view:  The performance test was conducted at a certain “loading or capacity level”, but the facility has an X number of occasions since then where they operated at levels higher than that.  Therefore, the performance test is invalid and the performance test must be re-run at the higher capacity.

 

 

 

Question 4

 

When do I have to notify the EPA that our facility is subject to MACT as an area or major source?

 

 

 

Answer 4

 

October 12, 1999.  (§63.1353,  FR 64 page 31934, and §63.9)  A sample notification letter is included in Section II-B.

 

 

 

Question 5

 

Can we arbitrarily notify as an “area” or “major” and then change that designation later?

 

 

 

Answer 5

 

The required notification date of October 12, 1999 makes it very difficult to acquire the emissions data, (if the facility has not previously performed emissions testing).  There are estimations that can be made by experienced consultants based on “best engineering judgement.”  However, a definitive classification as an “area” or “major” requires a certain minimum of analysis which may not be available prior to the notification date.  While not stated publicly, representatives of EPA have indicated to GCI that selection of one or the other designation (area or major) supported by some justification and followed by a statement that subsequent emissions testing will determine the proper designation prior to the compliance date should be sufficient (§63.2).  In this manual, see Section II-B

 

 

 

Question 6

 

I don’t want to pay for a lot of expensive testing.  My raw materials doesn’t have a lot of kerogins, we have a modern baghouse, etc.  Why can’t I just do my performance test now?

 

 

 

Answer 6

 

If you have enough data on D/F emissions and APCD inlet temperatures, you may be able to do that.  But remember, the performance test must be performed at a “highest loading-expected” and a maximum APCD inlet temperature operating limit; the exceedence of which will result in reportable violations (FR 64 page 31929).  These APCD inlet temperature operating limits apply all the time.  A limit that is set too low will result in lost production.

 

 

 

Question 7

 

The regulation indicates that lowering the inlet temperature of the APCD will result in lower dioxins.  Should we go ahead and spend the money to lower this temperature now before we test for dioxins?

 

 

 

Answer 7

 

GCI provided comments on the then proposed HWC MACT regulation in 1997.  (http://GCISolutions.com/GCINOTES897.htm)  At that time, we pointed out that EPA’s assumption that the 400°F temperature was “readily achievable” was not necessarily so.  Nor does achieving an APCD inlet temperature below 400°F assure that the dioxin emissions rate will be below 0.4 ng/dscm.  Data included in Volume III of the Technical Support Document for HWC MACT supports our contention.  One kiln had an average PCDD/PCDF TEQ of 5.06 ng/dscm@7% while having an APCD inlet temperature of 383°F.  There were two other kilns which had TEQ averages of 0.79 ng/dscm and 0.59 ng/dscm at 400°F APCD inlet temperatures.  There were also kilns which had low dioxin emission rates at much higher APCD inlet temperatures, 0.37 ng/dscm@459°F, 0.2 ng/dscm@470°F and a remarkably low 0.06 ng/dscm@497°F.  Clearly, APCD temperature is not the only contributor to dioxin emissions.

 

 

 

Question 8

 

Will we have to hire a technician to perform all the monitoring, inspections and maintain records?

 

 

 

Answer 8

 

Not necessarily.  There is a considerable amount of work that must be done up front, such as writing the Operations and Maintenance (O&M) Plan and the Shut Down, Start up and Malfunction Plan, performing the needed tests to select operating parameters, executing the performance test and preparing the reports and documents.  Much of this can be done by a consultant or corporate staff person.  The day-to-day data acquisition, monitoring, inspections and recordkeeping can be distilled down into a series of routine jobs that can be performed by existing plant personnel as a part of their existing work loads.