The Curious Case of the CPT(Abstract)

摘要

On September 30, 1999, the United States Environmental Protection Agency (USEPA) promulgated the National Emission Standards for Hazardous Air Pollutants for Hazardous Waste Combustors (HWC NESHAP). By March 30, 2004, all facilities subject to Phase I of this rule (incinerators, cement kilns, and lightweight aggregate kilns) were required to conduct a comprehensive performance test to demonstrate compliance with the rule. Nearly six years later, the Phase I facilities are repeating this effort, while units subject to the Phase II standards (boilers and hydrochloric acid production furnaces) are enjoying their first go-around with the process. Has this six year's time made the process any easier? This paper explores the elements of these tests - from developing, submitting, and receiving approval of your test plan, to receiving that all-so-desired finding of compliance, and evaluates how the process has evolved over the past six years. We will compare 2004 experiences to those of today, will review how agency review and approval of plans has progressed, and will discuss common problems that have been experienced.