PC MACT HCl CEMS – Does July 25, 2017 Sound Familiar?
Posted: April 6th, 2017Authors: JP K.
July 25th, 2017 is the expiration date for the 1-year additional compliance alternative for sources required to use a hydrogen chloride (HCl) continuous emission monitoring system (CEMS) to demonstrate compliance with the Portland Cement MACT (i.e., PC MACT or 40 CFR Part 63, Subpart LLL) HCl emission limit.
It’s now April…what is your compliance strategy after July 25th, 2017?
Before I talk strategy, let us first revisit the issue that triggered the 1-year additional compliance alternative.
- The monitoring and compliance provisions of the PC MACT require sources subject to limitations on HCl emissions to conduct performance testing by using HCl CEMS that meets the requirements of Performance Specification 15 (PS-15), PS-18, or any other PS for HCl CEMS promulgated in 40 CFR Part 60, Appendix B.
- I acknowledge that there are alternatives to using HCl CEMS if the kiln emissions are controlled, but those alternatives are NOT the focus of this blog.
- The quality assurance procedures for HCl CEMS require the use of National Institute of Standards and Technology (NIST)-traceable calibration gases for HCl.
- The full range of HCl calibration gases required to support HCl CEMS were not widely (commercially) available prior to the September 2016 PC MACT compliance date.
- Due to NIST-traceable calibration gas availability issues, the U.S. Environmental Protection Agency (U.S. EPA) amended the PC MACT (direct final rule) prior to the September 2016 compliance date to provide a 1-year additional compliance alternative for sources using HCl CEMS.
- U.S. EPA anticipated that NIST-traceable calibration gases for HCl would be available in sufficient quantities prior to the expiration date (July 25th, 2017) of the temporary alternative.
The obvious compliance strategy is to purchase NIST-traceable calibration gases and certify an existing HCl CEMS in accordance with a PS for HCl CEMS in 40 CFR Part 60, Appendix B and operate the CEMS in accordance with the original PC MACT requirements by July 25th, 2017. We are nearing [already possibly into] the typical lead-time needed to obtain NIST-traceable HCL calibration gas. With that being said…
Did you order your NIST-traceable HCl calibration gas yet?
Assuming you haven’t had success procuring sufficient quantities of the HCl NIST-traceable calibration gas needed for long term operation, what does your HCl compliance demonstration look like after July 25th, 2017? Are you hoping that U.S. EPA extends the expiration date for the additional compliance alternative? Will you continue operating an HCl CEM as a continuous parametric monitoring system (CPMS)? Will you conduct another stack test? Will your site-specific monitoring plans require updating? Will your employees require training or tools for new compliance methodologies? Is your data acquisition and handling system (DAHS) properly configured to evaluate compliance with the HCl emission standard using HCl CEMS? Are you documenting decisions, making notifications or submittals concerning this matter?
My next statement might bum you out — this blog isn’t going to provide a blanket compliance strategy recommendation nor do I have a top secret solution. In many cases, compliance strategies need to be site-specific, and the details of your situation may vary from the next. I strongly recommend you do not “bury your head in the sand” and place your compliance on the hopes of what others may do (e.g., request another extension and that U.S. EPA will approve it). The window for determining your options is closing. U.S. EPA is clear in the direct final rule that owners/operators must have HCl CEMS that meets the requirements of a PS for HCl CEMS in 40 CFR Part 60, Appendix B in place and operational by the July 25th, 2017 expiration date.
My ALL4 colleagues and I have been enjoying helping folks with PC MACT compliance. We are proud of our ability to “become our client” in our approach to managing and executing projects. If you find yourself working through this issue or any other PC MACT related matters, help is only a phone call or email away. My contact information is (610) 933-5246, extension 120 or firstname.lastname@example.org.