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 NSR Permit
Parts C and D of Title I of the Federal Clean Air Act – What are NSR Requirements and Exemption Rules found in 40 CFR Parts 51 and 52?

The EPA’s new interpretation of what qualifies for the exemption could call into question virtually every process improvement project at a plant. Historically, companies have avoided time-consuming NSR permitting for many process improvement projects by taking advantage of the routine maintenance exclusion. However, EPA has provided guidance which states that a project is probably not routine if:

  • Major equipment components are replaced
  • Efficiency or capacity is significantly enhanced
  • Facility economic life is extended substantially
  • It is rarely (if ever) performed
  • It is costly in both relative and absolute terms

For a summary of NSR Permit Compliance Strategies found in our Cement Industry Bulletin, October 2000, or NSR Rules found in 40 CFR Parts 51 and 52, e-mail us at info@rmtinc.com.

EH&S Management Systems
Environmental Health & Safety (EH&S) management systems have become a strategic tool used proactively by companies that find value in integrating environmental protection and worker health and safety with economic performance goals. These companies are changing the EH&S department from a cost center to a profit center. In the past four years since the publication of ISO 14001, thousands of organizations worldwide have implemented environmental management systems (EMSs), and their experience has shown real positive impacts on the bottom line. Furthermore, implementing a certified EMS is fast becoming a prerequisite for trade. The hurdles to implementing an ISO-certifiable EMS can seem overwhelming, given the enormous volume of compliance-related tasks and reports already required of the EH&S department. But, those who have invested the time to understand the concept of EH&S management systems are recognizing that the benefits far outweigh the initial drawbacks.

For more information on Environmental Health & Safety Management Systems, e-mail us at info@rmtinc.com.

MACT Standards for Hazardous Waste Burning Cement Kilns
On September 30, 1999, the U.S. Environmental Protection Agency (USEPA) promulgated final hazardous air pollutant (HAP) emissions standards for hazardous waste incinerators, cement kilns, and lightweight aggregate kilns under joint authority of the Clean Air Act Amendments of 1990 (CAAA) and RCRA. These Maximum Achievable Control Technology (MACT) standards limit emissions from both new and existing facilities in each equipment category. Pollutants regulated under the rule are dioxins and furans (D/F); mercury; total chlorine (HCl/Cl2); semi-volatile metals (SVM), including lead and cadmium; low-volatility metals (LVM), including arsenic, beryllium, and chromium; particulate matter (PM); carbon monoxide (CO); and hydrocarbons (HC).

For a summary of the MACT Standards for hazardous waste-burning cement kilns, e-mail us at info@rmtinc.com.

MACT Summary for Portland Cement Manufacturers
On June 14, 1999, the United States Environmental Protection Agency (USEPA) issued its final rules for implementation of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Portland cement manufacturing industry. These rules, which are referred to as the Maximum Achievable Control Technology (MACT) Standards, establish emission limits and monitoring requirements for sources considered major under the NESHAP regulations. Major sources are those that emit or have the potential to emit at least 10 tons per year of any single hazardous air pollutant (HAP) or 25 tons per year of any combination of HAP. Also included are standards for plants that are classified as area sources. Area sources are stationary sources of HAP that are not major. The standards are more extensive for new greenfield plants. (Reference 40 CFR 63, Subpart LLL, 63.1340 to 63.1359)

For a summary of the MACT Summary for the Portland cement manufacturing industry, e-mail us at info@rmtinc.com.

 

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