Lessons from HWC MACT Compliance Feasibility Studies Applicable to BIF MACT

Abstract

Recent engineering evaluations were performed for a number of clients to evaluate whether existing incinerators will achieve compliance with HWC MACT Phase I. These studies examined the facilities' capabilities of complying with HWC MACT and determined where the units would not comply with the rules promulgated September 30, 1999. By reviewing test data, operating data, waste characterization data, and design information, and performing mass and energy balance modeling, estimates of emissions were developed and compared with the MACT limits. This allowed determination of the potential noncompliance points so that process modifications and/or add-on alternative technologies could be evaluated for achieving compliance. In addition, the Continuous Monitoring System (CMS) and the Continuous Emission Monitoring Systems (CEMS) were evaluated to verify compliance with the operational and recordkeeping requirements for the promulgated rules. Phase II of the HWC MACT for boilers and industrial furnaces (BIFs) is anticipated to be proposed in early 2004. This paper will present some of the lessons learned from the Phase I rule evaluations that may be applicable to sources subject to the Phase II rule.