MACT Support

MACT Support

Industry:
Cement

Service Area:
Air Quality Compliance

Client's Challenge

ALL4’s client is a major manufacturer of Portland cement that operates two long-wet kilns that fire a variety of fuels including hazardous waste fuels.  The facility is subject to a number of different Subparts of the National Emissions Standards for Hazardous Air Pollutants for Source Categories also known as the Maximum Achievable Control Technology or MACT standards.   Since the facility fires hazardous waste fuels, a critical rule for the facility is 40 CFR Part 63, Subpart EEE the MACT standards for hazardous waste combustors.  ALL4 was asked to assist in all aspects of the client’s planning for, and demonstrating compliance with Subpart EEE.

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.

The Results

All4’s client continues to use hazardous waste fuels to replace fossil fuels in the cement manufacturing operations.  The Subpart EEE hazardous waste combustor MACT rule imposes a number of operating requirements related to using the waste for fuel that are not found in other MACT standards.  Parametric operating limits are established during performance testing and exceeding these limits triggers the need to automatically cut off the hazardous waste feed to the combustor.  ALL4 was able to assist the client with identifying and establishing the critical operating parameter limits.  ALL4 continues to provide on-going support to all phases of the facility’s MACT compliance efforts.  Using ALL4 services allows the plant to maintain daily compliance efforts knowing that additional support is available any time it is needed.

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