CISWI or PC NESHAP Compliance Demonstration Timelines and Milestones Considerations

If you’re like me, it’s hard to believe that it is May already.  Time seems to move faster every time I stop and think about it.  Why is this relevant?  The compliance date for 40 CFR Part 60, Subpart DDDD [Emissions Guidelines and Compliance Times for Commercial and Industrial Solid Waste Incineration (CISWI) Units] affected units is only a few short months away.

Are you, or could you possibly be, operating a CISWI kiln?

A cement kiln is regulated as an incinerator and is subject to the CISWI regulations when a Non-Hazardous Secondary Material (NHSM) is burned without a NHSM non-waste determination.  If you are not a CISWI kiln, here are two questions I urge you to consider today:

1. Does your operating permit include fuel descriptions with the word “waste” (e.g., waste wood, waste derived solid fuel)?
2. Do you burn any nontraditional fuels in your cement kiln?

If you answered yes to either of the questions above, have you developed a self-implementing non-waste determination, pursuant to the requirements of 40 CFR §241.3(d)(1), for each of the nontraditional fuels burned in the kiln?

ALL4 has been busy helping both corporations and individual facilities develop self-implementing non-waste determinations to ensure the associated kilns do not become subject to the CISWI rules.   Please contact me (see below) if you have questions concerning these regulations and the self-implementing non-waste determination process.

CISWI and PC NESHAP Compliance Demonstration Timelines and Milestones Considerations

The CISWI compliance date is “no later than” February 7, 2018, assuming that your state agency has not obtained  U.S. EPA approval of their state implementation plan (SIP) for 40 CFR Part 60 Subpart DDDD.  Deciding whether you want to remain a CISWI kiln or become a PC NESHAP regulated kiln is the first step in the process.  Regardless of the decision you make, you will be required to demonstrate compliance with a variety of CISWI or PC NEHSAP requirements.   A short list is provided below of some of these items to get you started.

• Compliance considerations when staying a CISWI kiln:
  • Submittal of final control plan and waste management plan
  • Testing plan, notification, and approval
  • Completion of performance test
  • Update site specific monitoring plans
  • Submit performance test results
  • Submit performance evaluation and test results and notification of compliance status

• Compliance considerations when becoming a PC NESHAP kiln:
  • Determine the date to cease combustion of solid waste
  • Determine the effective date of the waste-to-fuel switch and provide the required 30-days prior notice
  • Determine the compliance date for PC NESHAP
  • Submittal of notification of applicability
  • Air pollution control equipment and all monitoring systems necessary for compliance must be installed, operational, and certified, as applicable
  • Testing plan, notification, and approval
  • Completion of performance test
  • Update site specific monitoring plans
  • Submit performance evaluation and test results and notification of compliance status

I opened this blog by stating the compliance date for CISWI affected units is only a few short months away.  As you can see from lists above, there are many complex issues and requirements that necessitate planning, coordination, communication, documentation, and BUDGET.    Point being, time is running out.  Feel free to contact me if you would like to discuss anything related to NHSM non-waste determinations, CISWI, or PC NESHAP.  My contact information is (610) 933-5246, extension 120 or jkleinle@all4inc.com.

This article is available as a podcast episode on ALL4’s Air Quality Insider