Finalized PC MACT Amendments and Performance Specification 18

On July 1, 2015, the U.S. Environmental Protection Agency (U.S. EPA) finalized the proposed amendments to 40 CFR Part 63, Subpart LLL – National Emissions Standards for Hazardous Air Pollutants (NESHAP) for the Portland Cement Manufacturing Industry, which establishes Maximum Achievable Control Technology (MACT) standards for affected sources, and is commonly referred to as “PC MACT.” The major revisions to PC MACT include:

• Clarifications on the definitions of rolling average, run average, and operating day.
• Allows an additional month of flexibility for the due date of the annual performance test.
• Restores the prior emissions limits (as Table 2 to PC MACT) that apply until the September 9, 2015 compliance date.
• Includes corrections to Equation 8 regarding kilns with an alkali bypass and/or an inline coal mill with a separate stack.
• Provides a scaling alternative for sources that have a wet scrubber, tray tower, or dry scrubber relative to the hydrogen chloride (HCl) compliance demonstration.
• Adds a temperature parameter to the kiln startup and shutdown requirements and clarifies that the requirement presented in 40 CFR §63.1346(g)(3) is related to devices that control emissions of hazardous air pollutants (HAP).
• Clarifies language related to span values for HCl and Hg continuous emissions monitoring systems (CEMS).
• Makes technical corrections related to inadvertent typographical errors.

Another new document released this month by U.S. EPA is the promulgated performance specification (PS-18) and quality assurance (QA) requirements (Procedure 6) for HCl CEMS. This is important for facilities who are using an HCl CEMS to demonstrate compliance with the emission limits in PC MACT, as well as for other purposes. PS-18 establishes requirements for initial acceptance, including instrument accuracy and stability assessments for HCl CEMS used for compliance determination at stationary sources. Procedure 6 specifies the minimum QA requirements necessary for the control and assessment of the quality of CEMS data submitted to U.S. EPA for compliance purposes. PS-18 will not only be a useful tool in demonstrating compliance with operating and maintenance requirements for HCl CEMS, but will also serve as a resource in providing procedures and guidance when developing required PC MACT plans for facilities, like site-specific monitoring plans. Click the link to find out how ALL4 can help!