ALL4's Solution
ALL4 staff had assisted the client’s cement manufacturing and hazardous waste fuel firing activities for a number of years prior to the implementation of the MACT standards for hazardous waste combustors. Initially, ALL4 staff worked with the client in evaluating the Subpart EEE standards as they went through the development and promulgation process. Subsequently, the controversial Subpart EEE standards went through a number of iterations as a result of litigation and the facility has had to comply with both interim standards and replacement standards. Each set of standards imposed new and different emissions limits for hazardous air pollutants (HAP) emitted from the hazardous waste fired kilns. The standards also required the development of numerous plans, test and monitoring protocols, compliance testing, recordkeeping and reporting. ALL4 assisted the client in developing the following facility documents and plans related to compliance with Subpart EEE:
Documentation of Compliance,
Comprehensive Performance Test Plan,
Startup, Shutdown, and Malfunction Plan,
Operations and Maintenance Plan,
Continuous Monitoring System QA/QC Plan, and
Notification of Compliance.
In addition to supporting the client’s efforts in developing each of these documents for the Pennsylvania facility, ALL4 participated in corporate level planning for compliance with the various rule iterations and provided support in test planning and on-site support during actual testing activities. ALL4 continues to support the facility’s Subpart EEE and other applicable MACT rules activities with semi-annual recordkeeping and reporting services.