Must Feel Like Christmas – Portland Cement MACT Compliance
Posted: March 19th, 2015
Author: All4 Staff
It must feel like Christmas morning with all of those boxes full of monitoring equipment showing up at your facility and all of those elves running around getting the monitoring equipment installed. Amendments to the Maximum Achievable Control Technology (MACT) standard at 40 CFR Part 63 Subpart LLL, referred to as the Portland Cement (PC) MACT, require the installation of new monitoring systems for particulate matter (PM), total hydrocarbons (THC), hydrogen chloride (HCl), and mercury (Hg). Let’s not forget as we scramble around to get the monitoring systems installed that we have a lot of other activities that must be completed prior to the September 09, 2015 compliance date.
To assist you with the implementation of PC MACT, ALL4 will be featuring frequent blogs posts over the next several months. You’ll find insights on PC MACT implementation, and an interactive forum for questions or comments.
A snapshot of what ALL4 will be talking about is listed below:
- What should your Data Acquisition and Handling System (DAHS) be able to do?
- What data validation procedures are you using when building compliance averages?
- What are the Federal and state-specific certification requirements for PC MACT monitoring systems?
- What if my kiln is subject to another emission standard (NSPS, EEE, CISWI)?
- What about the non-kiln/non-clinker cooler equipment?
- How will clinker production rate be determined?
- How could my written standard operating procedures (SOPs) be affected by the PC MACT?
- What should my site-specific monitoring plan include and when is it due?
- How do I complete a performance evaluation on my monitoring systems?
- What recordkeeping and reporting requirements do I need to know now so I can ensure that the records are being kept prior to the compliance date?
- What do I need to conduct an initial performance test program?
- What training programs should be developed for my operators and instrumentation personnel?
Previous blog posts concerning the PC MACT address the following questions:
- What is the regulatory history of the PC MACT?
- Where there any changes to the PC MACT?
- How will my Operation and Maintenance (O&M) Plan be affected by the PC MACT?
- What about Affirmative Defense?
Stay tuned for our upcoming blog, which will provide information on what you should be considering with your DAHS vendor as you implement your compliance solution for the PC MACT. If you have any questions, please feel free to reach me directly.