Document rBaw41N13gqe3BrxNE2E2B89G

FILE NAME: EPA National Emission Standards DATE: 1973 Apr 12 DOC#: EPA009 DOCUMENT DESCRIPTION: Baltimore MD, Inter-Office memo RE EPA Hazardous Air Pollutant Standards: Summary Interpretation BALTIMORE COUNTY, MARYLAND INTER-OFFICE CORRESPONDENCE T O _______ FR O M ___ SUBJECT William.J u .__Phillips_____ Technical Services Section Date_ _April 12, 1973 EPA HAZARDOUS AIR POLLUTANT STANDARDS: SUMMARY INTERPRETATION A . GENERAL Asbestos, beryllium and mercury have been declared hazardous air pollutants and national standards have been promulgated (Federal Register, V. 38, no. 66, pp 8820-8850, April 6, 1973). No one may construct or modify any stationary hazardous air pollutant source, and all existing sources must register with EPA. In Maryland, the address to contact is: Director, Enforcement Division Environmental Protection Agency Region III Curtis Building Sixth and Walnut Streets Philadelphia, Pa. 19106 B. ASBESTOS (1) Mills, manufacturing plants - no visible emissions except [what would get through a well-designed baghouse]. The wording is that the fabric filter must operate at up to a pressure drop o 4 in. water gage and have air flow permeability no greater than 30 cfm'/ft. of cloth. T^is corresponds to an operating air to cloth ratio of under 3.0 cfm/ft. (see AP-51, p. 105). EPA officials say they put in the baghouse design specifications to effectively assure that these sources would be well controlled. (2) Demolition - Any demolition operator wishing to raze any institutional, commercial, or industrial building (including apartment buildings with more than 4 dwelling units) must notify the EPA Administrator at least 20 days in advance, including the information listed under 61.22 (d)(1). The procedures to be followed to reduce asbestos emissions in demolition are basically (1) wet and remove fireproofing insulation from all boilers, pipes, and load-supporting structural members, and (2) do not drop these friable asbestos materials but lower carefully or transfer to ground via dust-tight containers or chutes. (3) Sprayed asbestos - spray on materials used to insulate or fireproof buildings shall contain less than 1% asbestos on a dry weight basis. William L. Phillips April 12, 1973 pEaPgAe HA2ZARDOUS AIR POLLUTANT STANDARDS required under 61.22 (e)(2). 2 d materials must notify ln advance> including information existing sources are r e q u i r e ^ t ^ s e n ^ i n ^ y 11! also deals with requests for waivers AnrJ rp t e format for reporting information*specified^n foi?11 information which ' 1973 t0 EPA* Section 61.10 C. BERYLLIUM incinerators) shall n o t ^ x c e e r i o b g r L f ^ f bervir ^ SUrCeS (lnclud^ g possible exception where the comDanv ran ^ ylJrum m any day, with the in the vicinity are Under 0.01 ug/m? S t a ^ that.ambient beryllium levels m Appendix B to the regulations8 E^rb n * aampllng techniques are detailed July 6, 1973 stack emission t e s ^ ,, ? P^rator must provide to EPA by All operators must'register with EPA h v * A " T A n 1 obtained-under 61.13. Appendix A to Standards) by July 6 > 1973 as Per 61.10 (form in discussednherf?1SS1n Standard for beryllium Rocket Motor Firing will not be E. MERCURY reclaimers^an^chlor-alkali^lant a n " merCUr7 re proceSi 24 hour period. S add not exceed 2300 grams , mercury mercury, per submitted to''p a ^ L ^ i a (form in " ty 'July 6 - 1973 Per 61.10 BIC/mav attachment Barry I. Castleman, PHE Technical Services Section Division of Air Pollution and Industrial Hygiene \ 8832 RULES AND REGULATIONS (g) "Denuder" means a horizontal or vertical container which is part of a mer cury chlor-alkali cell and in which water and alkali metal amalgam are converted to alkali metal hydroxide, mercury, and hydrogen gas in a short-circuited, elec trolytic reaction. (h) "Hydrogen gas stream"' means a hydrogen stream formed in the chlor alkali cell denuder. . (i) "End box" means a container(s) located on one or both ends of a mercury chlor-alkali electrolyzer which serves as a connection between the electrolyzer and denuder for rich and stripped amalgam. <j ) "End box ventilation system" means a ventilation system which col lects mercury emissions from the endboxes, the mercury pump sumps, and their water colection systems. ,(k) "Cell room" means a structure(s) housing one or more mercury electro lytic chlor-alkali cells. 61.52 Emission standard. Emissions to the atmosphere from sta tionary sources subject to the provisions of this subpart shall not exceed 2,300 grams of mercury per 24-hour period. 61.53 Stack sampling. (a) Mercury ore processing facility. (1) Unless a waiver of emission testing is obtained under 61.13, each owner or operator processing mercury ore shall test emissions from his source, ) Within 90 days of the effective date in the case of an existing source or a new source which has an initial start up date preceding the effective date; or (ii) Within 90 days of startup in the cas of a new source which did not have an initial startup date preceding the ef fective date. . (2) The Administrator shall be noti fied at least 30 days prior to an emission test, so that he may at his option observe the test. (3) Samples shall be taken over such a period or periods as are necessary to accurately determine the maximum emissions which will occur in a 24-hour period. No changes in the operation shall be made, which would potentially in crease emissions above that determined by the most recent source test, until the new emission level has been estimated by calculation and the results reported "to the Administrator. (4) All samples shall be analyzed, and mercury emissions shall be determined within 30 days after the source test. Each determination will be reported to the Ad ministrator by a registered letter dislatched before the close of the next busi ness day following such determination. (5) Records of. emission test results and other data needed to determine total emissions shall be retained at the source and made available, for inspection by the Administrator, for a minimum of 2 years (bi Mercury chlor-alkali plant--hy-' drogen and end-box ventilation gas streams. (1) Unless a waiver of emission test ing is obtained under 61.13, each owner or operator employing mercury chlor alkali cell(s) shall test emissions from his source, (i) Within 90 days of the effective date in the* case of an existing source or the Administrator, for a minimum of a new source which has an initial startup 2 years. , date preceding the effective date; or ' (c) Mercury chlor-alkali plants-- (ii) Within 90 days of startup in the cell room ventilation system. case of a new source which did not have (1) Stationary sources using mercury an initial startup date preceding the ef chlor-alkali 'cells may test cell room fective date. . , . emissions in accordance with paragraph <2) The Administrator shall be noti-" (c)(2) of this section or demonstrate fled at least 30 days prior to an emission compliance with paragraph (c) (4) of this test, so that he may at his option observe the test. section and assume ventilation emissions of 1,300 gms/day of mercury. ' (3) Samples shall be taken over such (2) Unless a waiver of emission test a period or periods as are necessary to ing is obtained tinder 61.13, each owner accurately determine the maximum emis- - or operator shall pass all cell room air sions which will occur in a 24-hour in forced gas streams through stacks period. No changes in the operation shall suitable for testing, ' be made, which would potentially in (i) Within 90 days of the effective date crease emissions above that determined in the case of an existing souyqe or a new- by the most recent source fcesti until the source which has an initial startup date new emission has been estimated by cal preceding the effective date; or culation and the results reported to the (ii) Within 90 days of startup in the Administrator. . case of a new source which did not have (4) All samples shall be analyzed and an initial startup date preceding the mercury emisions shall be determined effective date. within 30 days after the source test. All (3) The Administrator shall be noti the determinations will be reported to fied at least 30 days prior to an emission the Administrator by a registered letter test, so that he may at his option observe dispatched before the close of the next the test. business day following such determina tion. (4) An owner or operator may carry out approved design, maintenance, and (5) Records of emission test results housekeeping practices. A list of ap and other data needed to determine total proved design, maintenance, and house emissions shall be retained at the source keeping practices may be obtained from and made available, for inspection by the Administrator. APPENDIX A - National Emission'Standards fo r Hazardous Air Pollutants . I . SOURCE REPORT Compliance Status Information ' Instructions; Owners or operators of sources of.hazardous pollutants subject to the National Emission Standards for Hazardous Air Pollutants are required to submit the information contained In' Section I to the appropriate Environmental Protection Agenty' , Regional Office before (date vihlch 1s 90 days a fte r tha standards are Is provided In s 61.04. . A. SOURCE INFORMATION. ` 1. Ident1ficat1on/Lbcat1on * Indicate the name and address of each source. . . . . A2.9 . ^ '''' .. `"'tefipAt/y hW ' ; A43 ` JL--I-- 1--- 1 I rI ,.l ..ltl.T.I.KL.. I - iI i .I ,,,tu I, ..t.. A68, ""STReT1ibDRESS"1 ' / ' 1 1 \ ,B19 ` . B33 ' 634 ............................1 , 1 U r 1 ' - W e a k ' - 1 ,638 \ 1 1 ' ' ' cu'uiuV 1 .! 1 1 : Z , Contact - Indicate the name and telephone number o f the owner o r operator o r other responsible o ffic ia l whom EPA may contact con cerning th is report . J---1__I_L Tfei'E1' " 1 ' B54 l--c B63 'Telephone1' - i--i--I__1 FEDERAL REGISTER, VOL. 36, NO. 66-- FRIDAY, APRIL 6, 1973 f. V V ( ;? /v' '3. Source Description - B riefly s ta te th a nature o f the source ( e .o .. "Chlor-alkali P?ant% o r "Machine Shop") . . * I i i t i 1--t - r t - l _ r t t t t t . , i , , , , , 4 , A lternative Hailing Address - Indicate a n .altern ativ e mailing address i f correspondence i s to be directed to a location d iffe re n t than th a t specified above. C44 CS3 C64 J _ J _i_1_1_Ic- Jm- , t C77. C.78C79 D75 D79. zip; cobE1 6. Compliance Status - The emissions from th is source can cannot meet the emission lim itations contained in the National Emission -Standards on o r before {date which is 90 days a fte r the promulgation of the standards). i Signature of1owner, op erato r'o r other' responsible o f f ic ia l r ' ?v-< ;.. ..; ROTE: I f the emissions from the source w ill exceed those lim its se t by tha National Emission Standards f o r Hazardous Air Pollutants, the source w ill be in violation and subject to Federal enforcement , tetions unless granted a waiver o f compliance by the Administrator ; .of .the Environmental Protection Agency. The information needed .for such tfatvers i s lis te d in Section I I o f th is form. I----------------------------------------------------- ; - 614 615 45 6! ,EPA USE ONLY L ^ J r ...,. , , , , 8. PROCESS INFORMATION. P art B should bg completed separately fo r each point of emission fo r each hazardous p o llu ta n t. t 1 FEDERAL REGISTER, VOL. 38, NO. 66< I. Process Description - Provide a b rief description o f each process (e .g ., "hydrogen end box" In a mercury chior-alkali plant, "grinding machine" in a beryllium machine shop). Use additional sheets i f necessaiy. ' - . G2I _l__ L. -I----1----L-^ l__L. J __!__!_' I E45 -1--1--1 2 P ollutant Emitted - Indicate the type o f hazardous p o llu ta n t em itted by the process. Indicate "AB" fo r asbestos, "BE" fo r beryllium , o r "HG" fo r mercury. : V . - G19 G20 " . I_J--I . 3. Amount o f Pollutant - Indicate the average weight o f the hazardous material.named 1n Item 2 which enters the process in pounds per month (based' on th e previous twelve months o f o p eratio n ), - ' t G54 .G60 -i__i__u. 4. Control Devices Indicate the type'of pollution control devices, i f any, used to reduce the-emissions from the process ( e .g ., venturi scrubber* baghouse, wet cyclone) and the estim ated percent o f the po llu tan t which the device removes from th e process s gas'stream ,, : , , H19 -' ' ' PRIMARY COiItROC b ' t V f t i 34 H51 H53 '' ' ` P^T^ktWoVAL EFFICIENCY H35 ' 1 " ` 50 ~IS4~'H 55 ' CONDARV'(jITrJl DEv/crfok" 1 1--1 ^P^ZIntW oVAL EFFICIENCY b. Asbestos Emission Control Devices Only < i . I f a baghouse is specified in Item 4a .give th e following Information: The a i r flow permeability in cubic f e e t per minute per square foot of fabric area: - A ir flow permeability cfm/ft2 ' FRIDAY, APRIL 6, 1973 imH.iWIIl X!"WMiw RWEi** '*;^-V'-'>^ vX '^ '^ ? ^ 'i^ **r''t'V' `\T^':-i'"""'?r-^ ''ITji ' 4 The pressure drop in Inches water gauqe across th e f i l t e r a t which the baqhouse 1s operated Operating pressure drop = _____________Inches w.g. I f th e baqhouse material contains synthetic f i l l yarn, check whether th is material is spun or not spun I [. I f th e baqhouse u tiliz e s a fe lte d fab ric , give the minimum thickness 1n inches and the density 1n ounces per square yard. Thickness * _________ inches Density = ___________ oz/yd2 11. I f w e t co llectio n device is specified in Item 4 a, give , th e designed u n it contacting energy in Inches water gauges U nit contacting energy * Inches w'.g. II. . f/t , A. WAIVER OF COMPLIANCE. Owners o r operators Of sources unable , to operate in conpltance with th e National Emission Standards f o r Hazardous A1r P ollutants by V EPA USE ONLY I , ! , /, I , 'V 5 c , ;sc (date which 1s 90 days 'a fte r the standards are promulgated) may request a Waiver o f comoliance from th e Administrator o f the Environmental Protection Agency fo r th e time period- . necessary t o in s ta l l appropriate control devices or-make m odifications . " to achieve compliance. The Administrator may grant a waiver of compliance .with the standard fo r a period not exceeding two years from the e ffectiv e -d a te of the hazardous p o llu ta n t standards i f he finds th a t such period , 1s necessary f o r the. in s ta lla tio n o f controls and th a t steps w ill be taken during th e period of the waiver to assure th at the health of persons w ill be protected from imminent endangerment. FEDERAL. REGISTER,- VOL. 38, s The reporting Information provided In Section I must accompany th is application. Applications should be sen t to the appropriate EPA . regional office. 1. Processes Involved - Indicate the process o r processes em itting hazardous pollutants to which emission controls are to be applied 2. Controls . . a. Describe the proposed type o f control device to be added o r . modification to be made to the process to reduce the emissions of hazardous p ollutants to an acceptable le v e l.. Use additional sheets 1f necessary. > . . b. Describe the measures th a t w ill be taken during the waiver perlod to assure th a t th e h ealth o f persons w ill be protected from Imminent endangerment. Use additional sheets i f necessary 3. Increments o f Progress -- sp ecify th e d ates by which the following . Increments of progress w ill be met. i - - - ; ; ' bate by which contracts f o r emission control systems' o r process ' modifications w ill be awarded; o r date by which orders w ill .be issued fo r the purchase o f th e component p arts to accomplish emission .control or process m odification. , V Date o f In itia tio n of. o n -s ite construction or in sta lla tio n of- - - . emission control equipment o r process change. - N p . ,6 6 -- fRtDAY,! APRIL', 6,- 1 9 7 3