MACT requirements

The statutory requirements addressed by each option are identified in the seventh column of Table X titled Statutory program. The specified compliance dates for each statutory program are also shown in the table, as are the implementation times for each option. Since the maximum achievable control technology (MACT) requirements have not yet been specified by EPA, projects directed toward those requirements have not yet been undertaken. That being the case, the implementation times identified indicate that options 5, 8, and 9 may have difficulty achieving timely compliance with these regulatory requirements. To proceed with the analysis, requirements that might be imposed under MACT were hypothesized to specify the performance characteristics of the associated pollution prevention options. It should be noted that only those options related with compliance with the Benzene Waste NESHAP (National Emissions Standard for... 

Demo II tests have shown that the GPCR off-gas does not meet the EPA syngas criterion. The stack gas from the PGB did meet the BIF emission requirements but may not meet the new EPA MACT requirement and therefore may be subject to RCRA regulations. 

The 1990 Clean Air Act Amendments Hst 189 hazardous air pollutants (HAPs) that the EPA must regulate to enforce maximum achievable control technology (MACT) to standards which are to be set by the year 2000. The 33/50 project calls for reduction of emissions of 17 specified solvents to predetermined levels by 1995. The SARA statute provides a mechanism by which the community can be informed of the existence, quantities, and releases of toxic chemicals, and requires that anyone releasing specific toxic chemicals above a threshold level to annually submit a toxic chemical release form to the EPA. The status of various ketones under these regulations is shown in Table 4. 

The 1990 CAAA introduced a new level of control for hazardous (toxic) air pollutants (HAPs). As a result, EPA has identified 189 HAPs for regulation. Rather than rely upon ambient air qnahty standards to set acceptable exposures to HAPs, the CAAA requires that EPA promulgate through the end of the decade Maximum Achievable Control Technology (MACT) standards for controlling HAPs emitted from specified industries. These standards are based on the level of control estabhshed by the best performing 12 percent of industries in each of the categories identified by EPA. 

When owners wish to build a new source which will add a specific amount of a specific pollutant to an area that is innonattainment with respect to that pollutant, they must, under U.S. federal regulations, document a reduction of at least that amount of the pollutant from another source in the area. They can effect this reduction, or "offset," as it is called, in another plant they own in the area or can shut down that plant. However, if they do not own another such plant or do not wish to shut down or effect such reduction in a plant they own, they can seek the required reduction or offset from another owner. Thus, such offsets are marketable credits that can be bought, sold, traded, or stockpiled ("banked") as long as the state or local regulatory agency legitimizes, records, and certificates these transactions. The new source will still have to meet NSPS, BACT or MACT, and/or LAER standards, whichever are applicable. 

Emissions from hazardous waste combustors are regulated under two statutory authorities RCRA and the CAA. The MACT standards set emission limitations for dioxins, furans, metals, particulate matter, total chlorine, hydrocarbons/carbon monoxide, and destruction and removal efficiency (DRE) for organics. Once a facility has demonstrated compliance with the MACT standards by conducting its comprehensive performance test (CPT) and submitting its notification of compliance (NOC), it is no longer subject to the RCRA emission requirements with a few exceptions. RCRA-permitted facilities, however, must continue to comply with their permitted emissions requirements until they obtain modifications to remove any duplicative emissions conditions from their RCRA... 

To control the emission of organics, these units must comply with similar DRE requirements to the other hazardous waste combustion units. Owners or operators of MACT combustion units must select POHCs and demonstrate a DRE of 99.99% for each POHC in the hazardous wastestream. Sources that bum hazardous waste have a required DRE of 99.9999% for each POHC designated. Additionally, for dioxins and furans, U.S. EPA promulgated more stringent standards under MACT. For example, MACT incinerators and cement kilns that bum waste with dioxins and furans must not exceed an emission limitation of either 0.2 ng of toxicity equivalence per dry standard cubic meter (TEQ/m3) or 0.4 ng TEQ/m3 at the inlet to the dry particulate matter control device. This unit of measure is based on a method for assessing risks associated with exposures to dioxins and furans. 

The NESHAPs were issued by U.S. EPA for air quality protection from HWCs. The standards implement a section of the CAA by requiring HWCs to meet HAP emission standards reflecting the application of the MACT.30... 

U.S. EPA s recommendations regarding stack emission tests, which may be performed at hazardous waste combustion facilities for the purpose of supporting MACT standards and multipathway, site-specific risk assessments, where such a risk assessment has been determined to be necessary by the permit authority, can be found in the U.S. EPA document on Risk Burn Guidance for Hazardous Waste Combustion Facilities.32 The applicability of the new standards has been demonstrated in the management of hazardous waste incinerators, whose performance was shown to clearly surpass the regulatory requirements in all tested areas.33... 

Recently, refiners have begnn to nse TSSs to control particulate matter from FCCs for environmental reasons. MACT11 regulations require that FCC particulate emissions be reduced to less than 1 lb particulate per 1000 lb coke bum (this limit is the same as the NSPS limit for particulate matter). There are four TSS technology companies licensing TSSs to meet the MACT II/NSPS limits. Figure 18.5 contains a sketch of a UOP TSS unit. 

The TSS has less potential for maximum emission control as the WGS and electrostatic precipitator (ESP). While all three technologies were designed to meet NSPS/ MACT, only the WGS and ESP can meet more stringent requirements. TSS performance can typically achieve d50 grade efficiency down to 2 microns. Most reported performance values result in emissions of 0.4-0.8 Ib/Mlb coke. Future PM2 5 regulations are a concern for TSS applications. By definition, TSS units cannot effectively remove small particles due to the cyclonic operation. 

In 1995, the amendments to the Clean Air Act included requirements for maximum achievable control technology (MACT) for pollutants, including dioxins and metals. The EPA has since promulgated regulations that will have to be met by a modified baseline process for the Pueblo site (EPA, 1999). In addition, EPA is reviewing the effects of dioxins on human health because some evidence indicates dioxins may be more harmful in the food chain than previously thought (Kaiser, 2000). If dioxin emission standards are modified, analytical procedures will need to be reviewed. 

The USEPA is responsible for creating and enforcing the NESHAPs for all hazardous air pollutant sources. The CAA states that new or existing major sources must have emission standards based on the maximum available control technology (M ACT) to reduce hazardous air pollutant emissions. The MACT standards are based on the performance of the best 12% of the control devices in the same source category. These MACT emissions requirements were extended in 1997 to cover wastewater biosolid incinerators at publicly owned treatment works (POTWs) that have the potential to discharge cadmium, lead, and mercury (Richman, 1997). 

In October 2005, under authority of the Clean Air Act and RCRA, the EPA issued its final national emission standards for hazardous air pollutants from hazardous waste combustors. The standards require hazardous waste combustors to meet hazardous air pollutant emission standards reflecting the application of maximum achievable controllable technology (MACT). These standards are applicable to any hazardous waste incinerator, including the chemical agent disposal facilities. In some states, separate air permits are issued to hazardous waste incinerators, while in others the RCRA permit requirements are adopted or changed to implement the requirements of the new MACT emissions standards for controlling the following pollutants ... 

In October 2005, the EPA issued a final rule updating the RCRA emission standards for hazardous waste incinerators based on maximum achievable control technology (MACT) that is commonly employed under the CAA. Therefore, hazardous waste incinerators are subject to MACT combustion unit performance standards and operating requirements, in addition to RCRA standards. 

The general provisions of the MACT standards are contained in CAA regulations (40 CFR 63 Subpart A). Sources of hazardous air pollutants are required to demonstrate compliance with emission limitations by conducting a comprehensive performance test (CPT). If compliance is demonstrated, the facility s management files a notice of compliance (NOC) with the state regulatory body. Sources can use any combination of control technologies to achieve the emission standards. 

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