`A Case Study in Implementation of the NESHAPs for the Portland Cement Industry at a Major Source,` appeared in Cement Americas magazine, July/August 2003

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Courtesy of Trinity Consultants

Introduction

Located at 40 CFR 63, Subpart LLL, the Portland Cement (PC) MACT standard poses a significant regulatory hurdle to the cement industry-Facilities subject to its requirements had to complete initial performance testing and develop their first substantial semi-annual monitoring report by January 31, 2003. The final Portland Cement MACT rule was promulgated on June 14, 1999, and requires Portland Cement manufacturing plants to meet emissions standards reflecting the application of MACT. The standards were proposed in the Federal Register (FR) on March 24, 199S (63FR14132).

The Portland Cement MACT rule applies to all Portland cement manufacturing plants at any facility that is classified as either a HAP major source (i.e., has the potential to emit more than 10 tpy of any single HAP or more than 25 tpy of any combination of HAPs) or HAP area source (i.e., non-major), with the following exception. Portland cement kilns and in-line kiln/raw mills subject to the NESHAP for hazardous waste combustors (HWC) are not subject to Portland cement MACT standards; however, other affected sources at Portland cement plants where hazardous waste is burned in the kiln are subject to the Portland cement MACT standard. Facilities subject to the Portland cement MACT must comply with rigorous operating procedures, monitoring, and recordkeeping and reporting.

This article describes the major-source, PC MACT compliance program developed for a large, modern, single-line plant. The plant had a relatively simple design and abundant electronic data management capabilities; therefore, 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 EPA's recent clarifications of PC MACT, the rule still contains ambiguities that must be considered by plant managers. 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 compliance program.  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, and the compliance program is now included in new employee orientation.

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