Under the 1990 Clean Air Act Amendments (CAAA), U.S. EPA is required to regulate sources of hazardous air pollutants (HAPs). Primarily, HAP emissions are regulated through National Emission Standards for Hazardous Air Pollutants (NESHAPs), which are codified under Title 40 Code of Federal Regulations (CFR) Part 63. NESHAPs address HAP emissions from a particular process, such as steel pickling processes using hydrochloric acid (HCI). Each NESHAP establishes the maximum available control technology (MACT) for that particular process based on the best-performing 12 percent of existing sources. Reductions are achieved through various means, such as product substitution, operating method changes, and pollution control equipment. As anyone who works at a facility that has recently had to comply with a NESHAP can attest, satisfying these requirements can be a major undertaking.
September 13, 1997, EPA proposed the National Emission Standards for Hazardous Air Pollutants for Steel Pickling -HCI Process facilities and Hydrochloric Acid Regeneration Plants (HCI Pickling NESHAP). The proposed rule was finalized on June 22, 1999, under 40 CFR Part 63 Subpart CCC. In general, this rule affects facilities using HCI to pickle carbon steel, HCI regeneration
plants, and associated HCI fixed storage vessels. Facilities with existing affected sources (i.e., equipment installed prior to September IS, 1997) must achieve compliance by June 22, 2001.l New sources (i.e., equipment installed or modified after September 18, 1997) must be in compliance on startup. The following sections discuss the applicability of this rule, its emission standards, and the compliance demonstration requirements facilities must meet in the near future.
`Facing the New Emission Standards for Hydrochloric Acid Pickling,` presented at the SUR