THE HEALTH-BASED ALTERNATIVES OF THE MACT STANDARDS AND THE IMPLICATION AND IMPLEMENTATION FOR HWCS AND INDUSTRIAL FACILITIES

摘要

The U.S. Environmental Protection Agency (US EPA) has promulgated two MACT Rules in 2004, which are (1) the Proposed Standards for Hazardous Air Pollutants for Hazardous Waste Combustors (the HWC MACT rule) on April 20, 2004 and (2) the Final Rule of National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers and Process Heaters (the Boiler MACT rule). Both rules include health-based compliance alternatives for hydrogen chloride and chlorine. Plus, the boiler MACT rule allows industrial, institutional, and commercial facilities with boilers and heaters to use health-based alternatives to set the emission limit for manganese. This paper presents an analysis of the critical regulatory and technical issues associated with the health-based alternatives in the MACT rules, and the implications for implementation of the health-based alternatives for various facilities. By using site-specific parameters and operation information from three combustion facilities, this paper provides quantitative and qualitative comparisons between using the look-up tables provided in the MACT rules and conducting site-specific analysis to set up facility-specific emission limits. This paper also addresses the technical procedures for conducting a site-specific compliance demonstration of the health-based alternatives for individual facilities, and discusses the potential reductions in compliance costs and beneficial effects on future operations.