A Case Study in Implementation of the National Emission Standard for Hazardous Air Pollutants for the Portland Cement Industry at a Major Source
The regulations at 40 CFR 63, Subpart LLL are commonly known as PC MACT because the rule establishes the maximum available control technology for hazardous air pollutants (HAPs) from portland cement plants in the United States. There are 188 HAPs specified in Section 112 of the Clean Air Act Amendments of 1990. Two classifications of HAP emitters are specified in 40 CFR 63. Major sources of HAPs annually emit 10 tons per year (tpy) or more of a single HAP, or 25 tpy or more for all HAPs combined. Area sources emit less than these threshold amounts. Portland cement plants have been found to be insignificant emitters of HAPs and more plants than originally expected qualified as area sources prior to the effective date of PC MACT, June 14, 2002. Only two HAPs, hydrogen chloride and formaldehyde, have been reported to exceed the 10-tpy threshold and have been the cause of major source designations for several plants. All cement plants must be concerned with the control of dioxin and furan emissions from kilns and in line kiln/raw mills. As a surrogate for metallic HAPs, existing major sources also must be concerned with the control of particulate matter (PM) emissions from the entire plant. Both major and area sources have an administrative burden for planning, testing, monitoring, recordkeeping and reporting. That burden is much heavier for a major source of HAPs. More modern cement plants with extensive electronic monitoring of the plant and its processes are able to more easily cope with the administrative requirements of PC MACT. This article explains the major-source, PC MACT compliance program developed for one of Trinity Consultant’s (Trinity’s) clients at a large, modern, single-line plant. Because of the plant’s relatively simple design and abundant electronic data acquisition, the program at such a plant represents the base case for PC MACT compliance. Compliance activities at older or more complex major sources are the essentially identical but are more extensive and more troublesome to execute. Despite recent “clarifications” of PC MACT by the Environmental Protection Agency, the rule still contains ambiguities and uncertainties that must be considered by the management of each plant. This facility decided to accept the most stringent but practicable interpretation of PC MACT and to develop its compliance program accordingly. Existing procedures at the plant were modified as required to accommodate the monitoring and recordkeeping requirements of PC MACT. Because many plant personnel must be involved in PC MACT compliance, Trinity and its client used a team approach to develop the PC MACT compliance program and procedures. In addition to Trinity staff, the team included the client’s operating, maintenance and environmental staff personnel. Ultimately, every employee in the plant received an appropriate level of training regarding PC MACT compliance. The PC MACT compliance program is included in new employee orientation.