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A Successful Approach to MACT Compliance

Nov. 16, 2004
Over 3,000 secondary aluminum plants were found to be operating outside of MACT standards. Each facility must determine if it is a "major" or "area" source of hazardous air pollutants. The Clean Air Act of 1990 forced secondary-aluminum ...

Over 3,000 secondary aluminum plants were found to be operating outside of MACT standards.

Each facility must determine if it is a "major" or "area" source of hazardous air pollutants.

The Clean Air Act of 1990 forced secondary-aluminum operations to become MACT (Maximum Achievable Control Technology) compliant. Over 3,000 facilities in the United States were found not to be compliant with the standards set by the U.S. Environmental Protection Agency, which were published in March of 2000.

Metalcasters were forced to reduce hazardous air pollutants (HAP) placing limits on, at least, dioxins/furans and hydrogen chloride. In addition, particulates and total hydrocarbons were subjected to the standards, depending on the amount of HAP emissions from the facility. Any source subjected to the standard that did not demonstrate compliance by the deadline (which was set for March 23, 2003) would be facing substantial fines.

Secondary-aluminum operations that processed materials other than clean charge were challenged to make modifications for compliance. But, how could modifications be made while production continues?

It can be done
Wabash Alloys operates five secondary-aluminum plants that were subject to the new standard. They faced the obstacle of meeting compliance quickly, and the anticipated capital costs for the construction part of the project represented the single biggest expenditure ever made by Wabash (excluding acquisitions.)

Wabash chose RMT Inc. to develop and execute a regulatory compliance strategy. By upgrading existing ventilation and air-pollutions control systems at the five plants, the reduction of particulate, dioxin/furan, HCl gas and organic air would meet the MACT standards.

The project team included regulatory, engineering, maintenance, and operating personnel from both Wabash and RMT. The partnership executed the turnkey design, permitting, procurement and installation of air-pollution control equipment at the five operations concurrently.

The plan included securing a one-year compliance extension and related permits, developing the scope of work for each facility, conducting a line-by-line price sensitivity analysis, designing a custom process-air capture system, managing compliance testing, and strictly adhering to a project health and safety plan during all on-site activities.

Remarkably, Wabash was able to meet the extended compliance deadline of March 23, 2004. RMT reports that it was able to save Wabash several million dollars by avoiding the procurements of new baghouses and instead installed an innovative air curtain push-pull ventilation system. Designed by RMT consulting engineer Bob Scholz, the air curtain keeps particulates from escaping the furnace hoods at reduced exhaust requirements. The result is a more effective use of existing baghouse capacity.

RMT managed all elements of the project, and Wabash continued on a normal production schedule. Using off-shifts and schedule flexibility, RMT minimized equipment downtime, projecting and controlling costs, and maintaining a safety performance standard of no related losttime accidents.

Work toward an understanding
There are success stories, but MACT compliance is an on-going battle for the secondary-aluminum industry. The Secondary Aluminum MACT standard has been modified several times after it was published as a final rule, which has happened across the board in other industries.

Companies now must comply with all state-related air regulatory programs while maintaining compliance with the federal MACT standards. While most states' compliance standards are very similar to the federal standards on conventional pollutants, it is in the regulation of air toxins that there is the greatest variation among states. Some states follow the federal standards, but others that have different rules governing other chemicals.

Each facility must determine if it is a major (greater that 10 tons/yr of a single HAP or 25 tons/yr of multiple HAPs) source, or if it is an area (smaller) source of HAPs. There are at least 15 industry categories that regulate both "major" and "area' sources of HAPs. Ambiguity between "major" and "area" sources may lead to fines if an facility is found to be in violation with applicable standards.

The American Foundry Society, the Non-Ferrous Founder's Society, and the North American Die Casting Assn. challenged the standards set by the U.S. EPA, which initially characterized all aluminum diecasters and foundries as " secondaryaluminum production facilities", subjecting them to the MACT standards.

In a settlement with the U.S. Dept. of Justice and the U.S. EPA, the standards were clarified now aluminum diecasters, foundries, and extruders that melt only clean charge, customer returns and internal scrap, and that do not operate a sweat furnace, chip dryer, or delacquering kiln, are not "secondary aluminum producers" and are not subject to the regulations under that rule. (In addition, "clean charge" and "internal scrap" were also clarified under the ruling.)

Other planning considerations
Before making the necessary compliance changes, metalcasters should consider working with the environmental and permitting agencies. Ask the environmental agencies about potential delays in the project, such as obtaining the correct permits and possible changes to the standards while the compliance project is underway.

Many facilities subject to MACT standards find that state permitting agencies are writing the entire MACT standard into their construction or Title V permits, and in many cases, this is being done at the request of the U.S. EPA regional offices with the intent of making a permit more inclusive for concern citizens to review.

This practice presents hazards for the facility. When the MACT is being written into a permit the facility must ensure that (1) all applicable MACT requirements have been appropriately included in the permit; (2) the permit writer has not made any inappropriate interpretations of the rule; (3) the flexibility provided for in the rule is carried into the permit; and (4) language is included in the permit so that future changes in the MACT standard can be quickly and easily incorporated into the permit.

Construction or Title V permits are toughest to comply with. Planned alterations cannot begin until a permit is issued, which is a timing problem. Operating permits, which came into law in 1990, establish emission limits, monitoring, and reporting requirements for the entire facility. They also require annual certification of the facilities' compliance. Some companies view operating permits as an operating license, since complete understanding of the requirements and setting them into practice is the best way to avoid noncompliance and fines.

Be prepared for additional costs. Along with normal operating costs and the cost of the compliance project, operators need to consider the costs of testing, both at the time to prove initial compliance, but also later down the road on renewal dates.

Be aware of deadlines. It is recommended that companies have the application for renewal to the state and federal authorities at least 30 to 60 days prior to the cutoff date, typically six months prior to the expiration date of the permit.

Inspection and data gathering must be managed in order for the inspection to run smoothly. Having knowledge of how the enforcement process works and understanding how potential penalties will be assessed will help prepare for inspections. Inform employees on procedures during the inspection and know what the legal rights and obligations of the company are during the inspection.