National Emission Standards for Hazardous Air Pollutants for Source Categories; National Emission Standards for Hazardous Air Pollutants for Steel Pickling FacilitiesHCl Process

Federal RegisterSep 18, 1997

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SUMMARY: This action proposes national emission standards for hazardous

air pollutants (NESHAP) for new and existing hydrochloric acid (HCl)

process steel pickling lines and HCl regeneration plants pursuant to

section 112 of the Clean Air Act (Act) as amended in November 1990.

Steel pickling lines that employ the HCl process and associated HCl

acid regeneration plants have been identified by the EPA as potentially

significant emitters of hydrochloric acid, a chemical identified in the

Act as a hazardous air pollutant (HAP). Chronic exposure to HCl has

been reported to cause gastritis, chronic bronchitis, dermatitis, and

photosensitization. Acute inhalation exposure may cause coughing,

hoarseness, inflammation and ulceration of the respiratory tract, chest

pain, and pulmonary edema. Hydrochloric acid regeneration plants have

been identified as significant emitters of HCl and chlorine

(CL2), the latter of which is also identified in the Act as

a HAP. Acute exposure to high levels of CL2 in humans

results in chest pain, vomiting, toxic pneumonitis, pulmonary edema,

and death. At lower levels CL2 is a potent irritant to the

eyes, the upper respiratory tract, and lungs. This rulemaking will

affect steel pickling lines that use HCl as the primary acid, acid

regeneration plants, and acid storage tanks. The purpose of the

proposed rule is to reduce emissions of HCl by about 8,360 megagrams

per year (Mg/yr) and CL2 by about 19 Mg/yr. The NESHAP

provides protection to the public by requiring all HCl pickling lines,

acid regeneration plants, and acid storage tanks to meet emission

standards that reflect the application of maximum achievable control

technology (MACT).

DATES: Comments. Comments on the proposed rule must be received on or

before November 17, 1997.

Public Hearing. If anyone contacts the EPA requesting to speak at a

public hearing by October 9, 1997, a public hearing will be held on

October 20, 1997, beginning at 10 a.m.

ADDRESSES: Comments. Written comments should be submitted (in

duplicate, if possible) to: Docket No. A-95-43 at the following

address: U.S. Environmental Protection Agency, Air and Radiation Docket

and Information Center (6102), 401 M Street, SW., Washington, DC 20460.

The EPA requests that a separate copy of the comments also be sent to

the contact person listed below. The docket is located at the above

address in Room M-1500, Waterside Mall (ground floor).

A copy of today's notice, technical background information

document, and other materials related to this rulemaking are available

for review in the docket. Copies of this information may be obtained by

request from the Air and Radiation Docket and Information Center by

calling (202) 260-7548. A reasonable fee may be charged for copying

docket materials.

Background Information Document. The background information

document (BID) for the proposed standard may be obtained from the

docket or the U.S. Environmental Protection Agency by contacting Mary

Hinson, Emission Standards Division (MD-13), Research Triangle Park, NC

27511, telephone number (919) 541-5601.

Public Hearing. If anyone contacts the EPA requesting a public

hearing by the required date (see DATES), the public hearing will be

held at the EPA Office of Administration Auditorium, Research Triangle

Park, NC. Persons interested in presenting oral testimony or inquiring

as to whether a hearing is to be held should notify the contact person

listed below.

FOR FURTHER INFORMATION CONTACT: Jim Maysilles, Metals Group, Emission

Standards Division (MD-13), U.S. Environmental Protection Agency,

Research Triangle Park, NC 27711, telephone number (919) 541-3265,

facsimile number (919) 541-5600, electronic mail address

``[email protected].''.

SUPPLEMENTARY INFORMATION:

Regulated Entities

Entities potentially regulated by this action are those industrial

facilities that perform steel pickling using the HCl process. Regulated

categories and entities include:

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Examples of regulated

Category entities

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Industry.................................. Steel pickling plants (SIC

3312, 3315, 3317) using HCl

process.

Federal Government:

Not affected.

State/local/tribal governments:

Not affected.

------------------------------------------------------------------------

This table is not intended to be exhaustive, but rather provides a

guide for readers regarding entities likely to be regulated by final

action on this proposal. This table lists the types of entities that

the EPA is now aware could potentially be regulated by final action on

this proposal. To determine whether your facility is regulated by final

action on this proposal, you should carefully examine the applicability

criteria in section V.A of this document, and in Sec. 63.1155 of the

proposed rule. If you have any questions regarding the applicability of

this action to a particular entity, consult the person listed in the

preceding FOR FURTHER INFORMATION CONTACT section.

Technology Transfer Network

The text of today's notice also is available on the Technology

Transfer Network (TTN), one of EPA's electronic bulletin boards. The

TTN provides information and technology exchange in various areas of

air pollution control. The service is free, except for the cost of a

phone call. Dial (919) 541-5742 for up to a 14,400 BPS modem. The TTN

also is accessible through the Internet at ``TELNET

ttnbbs.rtpnc.epa.gov.'' If more information on the TTN is needed, call

the HELP line at (919) 541-5348. The HELP desk is staffed from 11 a.m.

to 5 p.m.; a voice menu system is available at other times.

Electronic Access and Filing Addresses

The official record for this rulemaking, as well as the public

version, has been established under Docket No. A-95-43 (including

comments and data submitted electronically). A public version of this

record, including printed, paper versions of electronic comments, which

does not include any information claimed as confidential business

information (CBI), is available for inspection from 8 a.m. to 5:30

p.m., Monday through Friday, excluding legal holidays. The official

rulemaking record is located at the address in ADDRESSES at the

beginning of this document.

Electronic comments can be sent directly to EPA's Air and Radiation

Docket and Information Center at: ``A-

[[Page 49053]]

and-R-D[email protected].'' Electronic comments must be submitted

as an ASCII file avoiding the use of special characters and any form of

encryption. Comments and data will also be accepted on disks in

WordPerfect in 5.1 file format or ASCII file format. All comments and

data in electronic form must be identified by the docket number (A-95-

43). No CBI should be submitted through electronic mail. Electronic

comments on this proposed rule may be filed online at many Federal

Depository Libraries.

Outline

The information in this preamble is organized as follows:

I. Statutory Authority

II. Initial List of Categories of Major and Area Sources

III. Background

A. Description of Steel Pickling Source Category

B. Emissions

C. Summary of Considerations Made in Developing This Rule

IV. NESHAP Decision Process

A. Source of Authority for NESHAP Development

B. Criteria for Development of NESHAP

C. Determining the MACT Floor

V. Summary of Proposed Standards

A. Sources to be Regulated

B. Emission Limits and Requirements

C. Compliance Provisions

D. Monitoring Requirements

E. Notification, Recordkeeping, and Reporting Requirements

VI. Summary of Environmental, Energy, and Economic Impacts

A. Facilities Affected by This NESHAP

B. Air Quality Impacts

C. Water Quality Impacts

D. Solid Waste Impacts

E. Energy Impacts

F. Cost Impacts

G. Economic Impacts

VII. Rationale for Selecting the Proposed Standards

A. Selection of Source Category and Pollutants

B. Selection of Affected Sources

C. Selection of Basis and Level for the Proposed Standards for

Existing and New Sources

1. Background

2. Selection of MACT

D. Selection of Format

1. Pickling Lines and Acid Regeneration Plants

2. Acid Storage Tanks

E. Selection of Emission Limits

1. Continuous Pickling Lines

2. Batch Pickling Lines

3. Acid Regeneration Plants

F. Selection of Monitoring Requirements

1. Pickling Lines

2. Acid Regeneration Plants

G. Selection of Test Methods

H. Selection of Notification, Recordkeeping, and Reporting

Requirements

I. Solicitation of Comments

VIII. Administrative Requirements

A. Docket

B. Public Hearing

C. Executive Order 12866

D. Enhancing the Intergovernmental Partnership Under Executive

Order 12875

E. Unfunded Mandates Act

F. Regulatory Flexibility Act

G. Paperwork Reduction Act

H. Clean Air Act

I. Statutory Authority

The statutory authority for this proposal is provided by sections

101, 112, 114, 116, and 301 of the Clean Air Act, as amended (42 U.S.C.

7401, 7412, 7414, 7416, and 7601).

II. Initial List of Categories of Major and Area Sources

Section 112 of the Act requires that the EPA promulgate regulations

requiring the control of HAP emissions from major and area sources. The

control of HAP emissions is achieved through promulgation of emission

standards under sections 112(d) and 112(f) and operational and work

practice standards under section 112(h) for categories of sources that

emit HAP.

An initial list of categories of major and area sources of HAP

selected for regulation in accordance with section 112(c) of the Act

was published in the Federal Register on July 16, 1992 (57 FR 31576).

``Steel Pickling--HCl Process'' is one of the 174 categories of sources

listed. The category consists of facilities engaged in the pickling of

steel using HCl as the pickling acid. This category does not include

facilities that pickle steel with other acids. The listing was based on

the Administrator's determination that HCl steel pickling facilities

may reasonably be anticipated to emit hydrochloric acid, one of the

listed HAP, in quantities sufficient to designate them as major

sources. Information subsequently collected by the EPA as part of this

rulemaking confirms that more than three-fourths of HCl pickling

facilities emit or have the potential to emit HCl at levels greater

than 9.1 megagrams per year (Mg/yr) (10 standard tons per year (tpy))

and therefore are major sources.

III. Background

A. Description of Steel Pickling Source Category

The ``Steel Pickling--HCl Process'' source category includes any

facility engaged in the pickling of steel using hydrochloric acid as

the pickling acid. Steel pickling is the process in which the heavy

oxide crust or mill scale that develops on the surface of steel during

hot forming or heat treating is removed chemically in a bath of aqueous

acid solution. Removal of the oxide layer is necessary to prepare the

surface for subsequent shaping or finishing. The source category does

not include facilities which pickle steel using acids other than HCl.

The category includes both continuous and batch pickling

operations. In the continuous pickling process the steel is fed through

a sequence of tanks in a countercurrent direction to the flow of the

acid solution; next, the steel is passed through a series of rinse

tanks or a rinsing section. In the batch pickling process, the steel is

immersed in an acid solution until the scale or oxide film is removed,

lifted from the bath, allowed to drain, and then rinsed by spraying or

immersion in rinse tanks.

To obtain current data on the industry, the EPA compiled data

supplied by the industry in response to an information collection

request (ICR) issued in May 1992. Facilities on the mailing list were

identified from trade publications and other generally available

information. Information reported included capacity and annual

production or processing rate as well as design information for

existing air pollution control systems. Some data were reported for

acid storage tanks.

Data were also reported on HCl regeneration plants, which are

operated at several facilities that conduct HCl pickling. Regeneration

plants are an integral part of the pickling operation at those

facilities.

Based on the sources of information used to develop the mailing

list and the completeness of responses, the EPA believes that the

reported information comprises a data base that adequately describes

the industry and its air pollution control equipment for development of

the MACT standards.

According to the data base, one Federal agency and 77 privately

owned companies operated 101 steel pickling facilities and 10 acid

regeneration facilities during 1991. Operations were located in 20

States in seven EPA Regions. Eight of the facilities operating acid

regeneration plants are collocated with pickling facilities, while two

are stand-alone custom or toll facilities. Therefore, a total of 103

facilities in this source category were operating in 1991. Many of the

facilities are located adjacent to integrated iron and steel

manufacturing plants or mini-mills that produce electric-furnace steel

from scrap.

Five types of pickling processes have been identified. Table 1

summarizes the number of facilities and production for each process

type.

[[Page 49054]]

Table 1.--HCl Steel Pickling and Acid Regeneration Processes

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Number of

Process plants Number of lines or units 1991 Production (10 \6\)

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Continuous Pickling:

Continuous Strip...................... 36 64 (lines).................. 33.3 tons.

Push-Pull Strip....................... 19 22 (lines).................. 4.5 tons.

Rod/Wire.............................. 20 55 (lines).................. 0.6 tons.

Tube.................................. 4 11 (lines).................. 0.5 tons.

Batch Pickling.......................... 26 59 (lines).................. 0.9 tons.

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Pickling Total *.................. 101 211 (lines)................. 39.8 tons.

Acid Regeneration....................... 10 13 (units).................. 98.0 gal.

----------------------------------------------------------------------------------------------------------------

* Four facilities perform batch and continuous rod/wire pickling processes. Eight facilities have acid

regeneration plants on site. The total number of facilities is 103.

Steel pickling operations are characterized by the form of metal

processed and the type of pickling equipment used. The principal forms

of steel pickled include coils of sheet or strip, rod, wire, pipe, and

various discreet shapes. Pickling operations may be continuous,

semicontinuous, and batch.

A reported 39.8 million tons of steel, valued at about $18 billion

based on the price of hot-rolled strip, were pickled in 1991,

representing 65 percent of the industry capacity.

Hydrochloric acid used in the pickling bath can be recovered as

regenerated acid, typically 16 to 20 percent HCl, from the spent pickle

liquor. A marketable iron oxide product is also produced as a byproduct

of the spray roasting or fluidized bed roasting processes used in the

acid plants. Waste liquor conversion and acid recovery are complete in

both of these processes. Annual facility capacities range from 3.15 to

38.9 million gallons of acid.

In 1991, actual production of regenerated acid from the ten

facilities was 98 million gallons, which is estimated to be more than

40 percent of pickling acid requirements for the industry for that

year. Without the savings provided by use of the regenerated acid,

additional costs would be incurred for treatment or disposal of the

waste pickle liquor (K062) that are otherwise avoided.

B. Emissions

Pickling lines of all types employ processing tanks that contain

HCl solution. Emissions of HCl in the forms of HCl gas and mist of HCl

in water are formed at the surface of the acid bath. The EPA estimates

that pickling facilities emit approximately 8,920 Mg/yr of HCl at the

current level of control.

Acid regeneration plants produce emissions containing HCl that is

not recovered as acid solution and also Cl2, which is formed

as an unwanted byproduct of the process. The EPA estimates that acid

regeneration facilities emit about 390 Mg/yr of HCl and 35 Mg/yr of

Cl2. Emissions in the forms of HCl gas and acid mist from

tanks used to store virgin or regenerated acid are released from

uncontrolled tank vents. An estimated 24 Mg/yr of HCl is emitted from

tanks nationwide.

C. Summary of Considerations Made in Developing This Rule

The Clean Air Act was created in part to protect and enhance the

quality of the Nation's air resources so as to promote the public

health and welfare and the productive capacity of its population. (See

section 101(b)(1)). Section 112(b) of the Act lists HAP believed to

cause adverse health or environmental effects. Section 112(d) of the

Act requires that emission standards be promulgated for all categories

and subcategories of major sources of these HAP and for many smaller

``area'' sources listed for regulation under section 112(c) in

accordance with the schedules listed under section 112(e). On December

3, 1993, the EPA published a schedule for promulgating these standards

(58 FR 63941).

In the 1993 Amendments to the Act, Congress specified that each

standard for major sources must require the maximum reduction in

emissions of HAP that the EPA determines is achievable considering

cost, health and environmental impacts, and energy requirements. In

essence, these MACT standards would ensure that all major sources of

air toxic emissions achieve the level of control already being achieved

by the better controlled and lower emitting sources in each category.

This approach provides assurance to citizens that each major source of

toxic air pollution will be required to effectively control its

emissions. At the same time, this approach provides a level economic

playing field, ensuring that facilities that employ cleaner processes

and good emission controls are not disadvantaged relative to

competitors with poorer controls.

Emission data collected during the development of this rule show

that pollutants that are listed in section 112(b)(1) and are emitted by

HCl steel pickling processes include hydrochloric acid and chlorine.

Hydrochloric acid and chlorine emissions would be reduced by

implementation of the proposed emission limits and equipment and

operating standards.

Adverse health effects from exposure to HCl and Cl2 have

been documented.1 Chronic occupational exposure to HCl has

been reported to cause gastritis, chronic bronchitis, dermatitis, and

photosensitization in workers. Prolonged exposure to low concentrations

may also cause dental discoloration and erosion. Acute inhalation

exposure may cause coughing, hoarseness, inflammation and ulceration of

the respiratory tract, chest pain, and pulmonary edema in humans. No

information is available on the reproductive, developmental, or

carcinogenic effects of HCl in humans. The EPA has not classified HCl

with respect to potential carcinogenicity.

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\1\ Hydrochloric Acid. Hazardous Substance Data Bank. National

Library of Medicine. National Institute of Health. Printouts dated

August 13, 1992 and November 12, 1993. See also: Hydrogen Chloride.

Integrated Risk Information System. U.S. Environmental Protection

Agency. Printout dated July 10, 1995.

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Acute exposure to high levels (>30 parts per million (ppm) of

Cl2 in humans results in chest pain, vomiting, toxic

pneumonitis, pulmonary edema, and death.2 At lower levels

(2 is a potent irritant to the eyes, the upper

respiratory tract, and lungs. Limited information is available on the

chronic effects in humans. A recent epidemiologic study reported no

[[Page 49055]]

adverse effects in workers exposed to Cl2 at 0 to 64 ppm

over an average of 20 years. No information is available on the

developmental, reproductive, or carcinogenic effects in humans via

inhalation exposure. The EPA has not classified Cl2 for

carcinogenicity.

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\2\ Chlorine. Hazardous Substance Data Bank. National Library of

Medicine. National Institute of Health. Printout dated August 18,

1993. See also: Chlorine. Integrated Risk Information System. U.S.

Environmental Protection Agency. Printout dated September 1, 1995.

---------------------------------------------------------------------------

The EPA does recognize that the degree of adverse effects to health

can range from mild to severe. The extent and degree to which the

health effects may be experienced is dependent upon: (1) The ambient

concentrations observed in the area (e. g., as influenced by emission

rates, meteorological conditions, and terrain), (2) the frequency and

duration of exposure, (3) characteristics of exposed individuals (e.g.,

genetics, age, pre-existing health conditions, and lifestyle) that vary

significantly with the population, and (4) pollutant-specific

characteristics (e.g., toxicity, half-life in the environment,

bioaccumulation, and persistence).

IV. NESHAP Decision Process

A. Source of Authority for NESHAP Development

Section 112 specifically directs the EPA to develop a list of all

categories of all major and such area sources as appropriate emitting

one or more of the HAP listed in section 112(b). (See section 112(c)).

Section 112 of the Act replaces the previous system of pollutant-by-

pollutant health-based regulation that proved ineffective at

controlling the high volumes and concentrations of HAP in air

emissions. The provision directs that this deficiency be redressed by

imposing technology-based controls on sources emitting HAP, and that

these technology-based standards may later be reduced further to

address residual risk that may remain even after imposition of

technology-based controls. A major source is any source that emits or

has the potential to emit considering controls 10 tpy or more of any

one HAP or 25 tpy or more of any combination of HAP. The EPA published

an initial list of source categories on July 16, 1992 (57 FR 31576),

and may amend the list at any time.

B. Criteria for Development of NESHAP

The NESHAP are to be developed to control HAP emissions from both

new and existing sources according to the statutory directives set out

in section 112, as amended. The statute requires the standard to

reflect the maximum degree of reduction of HAP emissions that is

achievable taking into consideration the cost of achieving the emission

reduction, any nonair quality health and environmental impacts, and

energy requirements.

Emission reductions may be accomplished through application of

measures, processes, methods, systems, or techniques, including, but

not limited to: (1) Reducing the volume of, or eliminating emissions

of, such pollutants through process changes, substitution of materials,

or other modifications, (2) enclosing systems or processes to eliminate

emissions, (3) collecting, capturing, or treating such pollutants when

released from a process, stack, storage, or fugitive emissions point,

(4) design, equipment, work practice, or operational standards

(including requirements for operator training or certification) as

provided in subsection (h), or (5) a combination of the above. (See

section 112(d)(2)).

To develop a NESHAP, the EPA collects information about the

industry, including information on emission source characteristics,

control technologies, data from HAP emissions tests at well-controlled

facilities, and information on the costs and other energy and

environmental impacts of emission control techniques. The EPA uses this

information to analyze possible regulatory approaches.

Although NESHAP are normally structured in terms of numerical

emission limits, alternative approaches are sometimes necessary. In

some cases, for example, physically measuring emissions from a source

may be impossible, or at least impractical, because of technological

and economic limitations. Section 112(h) authorizes the Administrator

to promulgate a design, equipment, work practice, or operational

standard, or a combination thereof, in those cases where it is not

feasible to prescribe or enforce an emissions standard.

If sources in the source category are major sources, then a MACT

standard is required for those major sources. The regulation of the

area sources in a source category is discretionary. If there is a

finding of a threat of adverse effects on human health or the

environment, then the source category can be added to the list of area

sources to be regulated.

C. Determining the MACT Floor

After the EPA has identified the specific source categories or

subcategories of major sources to regulate under section 112, it must

set MACT standards for each category or subcategory. Section 112 limits

the EPA's discretion by establishing a minimum baseline or ``floor''

for standards. For new sources, the standards for a source category or

subcategory cannot be less stringent than the emission control that is

achieved in practice by the best-controlled similar source, as

determined by the Administrator. (See section 112(d)(3)).

The standards for existing sources can be less stringent than

standards for new sources, but they cannot be less stringent that the

average emission limitation achieved by the best-performing 12 percent

of existing sources (excluding certain sources) for categories and

subcategories with 30 or more sources, or the best-performing 5 sources

for categories or subcategories with fewer than 30 sources. (See

section 112(d)(3)).

After the floor has been determined for a new or existing source in

a source category or subcategory, the Administrator must set MACT

standards that are no less stringent than the floor. Such standards

must then be met by all sources within the category or subcategory.

Section 112(d)(2) specifies that the EPA shall establish standards

that require the maximum degree of reduction in emissions of hazardous

air pollutants

* * * that the Administrator, taking into consideration the cost

of achieving such emission reduction, and any non-air quality health

and environmental impacts and energy requirements, determines is

achievable * * *

In establishing standards, the Administrator may distinguish among

classes, types, and sizes of sources within a category or subcategory.

(See section 112(d)(1)). For example, the Administrator could establish

two classes of sources within a category or subcategory based on size

and establish a different emissions standard for each class, provided

both standards are at least as stringent as the MACT floor for that

class of sources.

The next step in establishing MACT standards is the investigation

of regulatory alternatives. With MACT standards, only alternatives at

least as stringent as the floor may be selected. Information about the

industry is analyzed to develop model plant populations for projecting

national impacts, including HAP emission reduction levels, costs,

energy, and secondary impacts. Several regulatory alternative levels

(which may be different levels of emissions control or different levels

of applicability or both) are then evaluated to select the regulatory

alternative that best reflects the appropriate MACT level.

The selected alternative may be more stringent than the MACT floor,

but the

[[Page 49056]]

control level selected must be technically achievable. In selecting a

regulatory alternative that represents MACT, the EPA considers the

achievable emission reductions of HAP (and possibly other pollutants

that are co-controlled), cost, and economic impacts, energy impacts,

and other environmental impacts. The objective is to achieve the

maximum degree of emissions reduction without unreasonable economic or

other impacts. (See section 112(d)(2)). The regulatory alternatives

selected for new and existing sources may be different because of

different MACT floors, and separate regulatory decisions may be made

for new and existing sources.

The selected regulatory alternative is then translated into a

proposed regulation. The regulation implementing the MACT decision

typically includes sections on applicability, standards, test methods

and compliance demonstration, monitoring, reporting, and recordkeeping.

The preamble to the proposed regulation provides an explanation of the

rationale for the decision. The public is invited to comment on the

proposed regulation during the public comment period. Based on an

evaluation of these comments, the EPA reaches a final decision and

promulgates the standard.

V. Summary of Proposed Standards

A. Sources To Be Regulated

The proposed NESHAP would apply to new and existing pickling lines

that use an acid solution in which 50 percent or more by weight of the

acid in solution is HCl, HCl regeneration plants, and adjunct tanks

used to store virgin or regenerated HCl at steel pickling facilities or

acid regeneration plants that are major sources or are part of a major

source. A steel pickling line employing a pickling solution in which

less than 50 percent by weight of the acid in solution is HCl would not

be subject to the proposed NESHAP.

B. Emission Limits and Requirements

Emission limits are being proposed for HCl and Cl2. For

existing continuous and batch pickling lines, HCl emissions would be

limited to either: (1) Emissions from an air pollution control device

(APCD) with a minimum HCl collection efficiency of 97.5 percent; or (2)

an HCl concentration no greater than 10 parts per million by volume

(ppmv) in the APCD or process exhaust gas. For new or reconstructed

continuous and batch pickling lines, HCl emissions would be limited to

either: (1) Emissions from an APCD with a minimum HCl collection

efficiency of 99 percent; or (2) a maximum HCl concentration of 3 ppmv

in the exhaust gas.

Emissions of HCl from existing acid regeneration plants would be

limited to a maximum concentration of 8 ppmv HCl in the exhaust gas. A

limit of a maximum concentration of 3 ppmv HCl in the exhaust gas is

proposed for new or reconstructed acid regeneration plants.

Emissions of Cl2 from existing and new acid regeneration

plants would be limited to either a maximum concentration of 4 ppmv

Cl2 in the exhaust gas or an optional source specific

maximum concentration limitation to be established for each source. The

way in which the optional limitation is established is described in

section VII.E of this document, ``Selection of Emission Limits''.

Under the proposed rule, the owner or operator of an existing or

new tank used to store virgin or regenerated acid would be required to

cover and seal all openings on the tank and route emissions from the

atmospheric vent to an APCD. Acid loading and unloading would be

conducted either through enclosed lines or with a local fume capture

system, ventilated through an APCD, at each point where the acid is

exposed to the atmosphere.

C. Compliance Provisions

Compliance with the standards would need to be achieved within 24

months of promulgation for existing sources, and upon startup or the

promulgation date, whichever is later, for new or reconstructed

sources. As provided by section 112(i), an owner or operator may

request the Administrator or applicable permitting authority in a State

with an approved permit program to grant 1 additional year if necessary

to install controls.

For pickling lines and acid regeneration plants, an initial

performance test would be required to demonstrate compliance. Sampling

locations for all compliance tests would be determined by EPA Method 1

in appendix A to 40 CFR part 60. Stack gas velocity and volumetric flow

rate would be determined by EPA Method 2; gas analysis would be

conducted according to EPA Reference Methods 3 and 4 in appendix A to

40 CFR part 60. Testing of HCl and Cl2 emissions would be

performed using EPA Method 26A, ``Determination of Hydrogen Halide and

Halogen Emissions from Stationary Sources--Isokinetic Method'', in 40

CFR part 60, appendix A. If testing is conducted to demonstrate

compliance with a collection efficiency limitation, sampling at the

APCD inlet and at the outlet must be simultaneous. An average of three

runs of sufficient duration to provide adequate samples for the

expected concentration would be used to determine compliance. The owner

or operator also would establish limiting values for control device

operating parameters and regeneration process operating conditions

based on the values measured during this test.

The installation of the required ventilation systems for acid

storage tanks would be confirmed to the satisfaction of the

Administrator by means of a visual inspection.

D. Monitoring Requirements

The proposed NESHAP allows two monitoring options for HCl, one

option for Cl2. For HCl, the owner or operator must either:

(1) Monitor and record control device operating parameters and perform

annual emission tests; or (2) operate a continuous emission monitoring

system (CEMS) for the measurement and recording of HCl emissions. If a

wet scrubber is used, the control device operating parameters monitored

would be the pressure drop across the scrubber and the acidity of the

scrubber effluent. The allowable range of values for pressure drop

would be either the range of values recorded during multiple

performance tests or a value within 1-inch of water column of the

average value measured during the three test runs of one compliance

test. Acidity would be monitored either by the use of instruments that

measure acidity continuously or manual tests made once each shift for

each operating day. If a device other than a wet scrubber is used, the

owner or operator must monitor parameters appropriate for that device.

Each owner or operator also must develop and implement a written

program to ensure the proper operation and maintenance of each emission

control device and submit the written program to the applicable

permitting authority as part of the operating permit. If a wet scrubber

is used, the plan must include the minimum elements contained in the

operating manual, e.g., it must: Require the manufacturer's recommended

maintenance at the recommended intervals for pumps, scrubber fans and

motors, and the exhaust system; require cleaning of the scrubber

internals and mist eliminators at sufficient intervals to prevent

fouling; and require periodic inspections of each scrubber to identify,

repair, or replace specified elements as needed. If another type of

control device is used, the owner or operator must develop and submit a

similar written plan appropriate for the

[[Page 49057]]

device for approval by the applicable permitting authority.

If a defect is found during an inspection, the owner or operator

must initiate corrective action procedures to remedy the defect within

1 working day of detection. Failure to perform the inspection as stated

in the written maintenance plan or to initiate corrective actions would

be a violation of the maintenance requirement.

Operation of the control device with excursions of operating

parameters outside the ranges established during the initial

performance test requires initiation of corrective action as specified

by the maintenance requirement. Failure to initiate the required action

is a violation of the maintenance requirements.

If excursions of control device operating parameters occur more

often than six times during any 6-month reporting period, the owner or

operator is required to install a CEMS and comply with all the

requirements applicable to a continuous monitoring system (CMS) that

are specified in Sec. 63.8 in subpart A of 40 CFR part 63. For

compliance with the exhaust gas concentration requirement, the CEMS

shall be employed to monitor the process or control device exhaust gas.

For compliance with the collection efficiency requirement, the CEMS

shall be employed to monitor the APCD inlet and outlet gas streams. For

compliance with the collection efficiency requirement, a single

analyzer may be used to monitor both streams, with each stream being

monitored 50 percent of the time during each 24-hour period.

For Cl2, the owner or operator must perform annual

emission tests and monitor and record roaster operating conditions.

Operating conditions would include process offgas temperature and a

measure of excess air fed to the process, the latter of which would

consist of a measure of air feed rate, combustion fuel feed rate, and

feed rate of iron in the spent liquor or any other acceptable

combination of parameters. The operator could establish new allowable

operating parameter values by conducting another performance test.

The owner or operator of a pickling facility would be found in

violation of the emission limit if an annual performance test or

reduced data from the CEMS show that the HCl emission limitation is

being exceeded. The owner or operator of an acid regeneration plant

would be found in violation of the emission limit if an annual emission

test shows that the HCl and/or Cl2 emission limitation is

being exceeded, if reduced data from the CEMS show that the HCl

emission limitation is being exceeded, or if the acid plant roaster is

operated under conditions outside the values established during the

initial performance test.

E. Notification, Recordkeeping, and Reporting Requirements

The owner or operator would be required to submit notifications

described in the general provisions (40 CFR part 63, subpart A), which

include initial notification of applicability, notifications of

performance tests, and notification of compliance status.

As required by the general provisions, the owner or operator would

be required to submit a report of performance test results; develop and

implement a written startup, shutdown, and malfunction plan and report

semiannually any events where the plan was not followed; and submit

semiannual reports of excess emissions if any measured emissions are

greater than the limits, or if any monitored parameters fall outside

the range of values established during the performance test. If excess

emissions are reported, a quarterly report would be required until

there have been no excess emissions for one year; the owner or operator

could then report semiannually unless excess emissions reoccur.

The owner or operator also would be required to maintain records

required by the general provisions and records needed to document

compliance with the standard. These records would mainly include

operating parameter measurements, a copy of the written maintenance

plan, and APCD inspection records.

All records must be retained for at least 5 years following the

date of each occurrence, measurement, maintenance, corrective action,

report, or record. The records for the most recent 2 years must be

retained on site; records for the remaining 3 years may be retained off

site but still must be readily available for review. The files may be

retained on microfilm, microfiche, on a computer, or on computer or

magnetic disks. The owner or operator may report required information

on paper or a labeled computer disk using commonly available and

compatible computer software.

VI. Summary of Environmental, Energy, and Economic Impacts

A. Facilities Affected by This NESHAP

The proposed standards would apply to all HCl steel pickling

facilities and HCl regeneration facilities that are major sources or

are part of a major source. The EPA estimates that approximately 80

pickling facilities and all 10 regeneration facilities emit HCl in

amounts that are greater than major source levels (i. e., greater than

10 tpy). At least one regeneration facility is a major source for

Cl2.

Sixty-nine pickling facilities control emissions from all lines

(119). In the remaining 32 facilities, 90 of 92 lines are uncontrolled.

Twelve of the 13 acid regeneration processes are equipped with control

systems. Of an estimated 369 storage tanks, about one-third, at 40

pickling and 4 acid regeneration facilities, are equipped with control

equipment.

Many of the 69 controlled pickling facilities not already meeting

the requirements of the proposed rule could possibly achieve compliance

with minor equipment modifications or changes in operating conditions.

Of the 32 facilities that would require additional control systems, 17

are batch picklers and 12 are continuous rod and wire picklers.

Many acid regeneration facilities may be able to comply with the

proposed NESHAP using existing control equipment and operating

procedures. Three plants are known to already meet the proposed

standard for HCl, three plants are known to meet the standard for

Cl2. Other plants may already be in compliance or able to

comply using only improved operating or maintenance procedures.

All impacts were estimated by determining the effect of the

proposed regulation on model plants that were developed to represent

the industry rather than estimating the impact on each facility on a

case-by-case basis, which was considered impractical. Seventeen model

plants were developed to represent the five types of pickling

operations and one acid regeneration process. The model plants include

small, medium, and large plant size variations (except for continuous

tubing pickling, for which only small and large size variations were

used) with associated emission control systems.

B. Air Quality Impacts

At current levels of control, nationwide HCl emissions from this

source category are estimated to be 9,330 Mg/yr; 6,980 Mg/yr for

continuous pickling lines, 1,940 Mg/yr for batch pickling lines, 390

Mg/yr for acid regeneration plants, and 24 Mg/yr from acid storage

tanks. Nationwide Cl2 emissions from acid regeneration

plants are estimated to be 35 Mg/yr. Application of the proposed

standards would reduce HCl emissions by approximately 8,360 Mg/yr to

about 970 Mg/yr from all regulated sources, or about 90 percent, and

Cl2 emissions by

[[Page 49058]]

approximately 19 Mg/yr to about 16 Mg/yr, or about 54 percent.

C. Water Quality Impacts

The additional amount of water discharged from wet scrubbers would

increase by approximately 460,000 cubic meters per year (m\3\/yr) over

current levels: 320,000 m\3\/yr from continuous pickling processes,

130,000 m\3\/yr from batch pickling processes, and 6,000 m\3\/yr from

acid regeneration plants. The portion of this water that would need to

be treated on site prior to discharge is projected to be small because

the scrubber discharge water can be, and is in many cases, recycled to

the pickling process to provide makeup water and recover the acid

values collected by the scrubber. The additional wastewater to be

treated would be insignificant compared with the amount of waste pickle

liquor generated by pickling operations. Treatment of both waste

products can be accomplished by the same procedures.

D. Solid Waste Impacts

The volume of sludge generated by additional control could increase

by up to 1,680 Mg/yr: 1,370 Mg/yr from continuous pickling processes,

280 Mg/yr from batch pickling processes, and 30 Mg/yr from acid

regeneration plants. The sludge is produced by the treatment of

scrubber discharge water. This amount of sludge is insignificant

compared with the amount of sludge generated by treatment of waste

pickle liquor. Also, the amount of sludge generated would be reduced

proportionally by the amount of scrubber discharge water that is

recycled to the pickling process, as described above in paragraph C,

Water Quality Impacts.

E. Energy Impacts

Additional energy use is expected to result from implementation of

the proposed standards. Increases would result from operation of

additional ventilation systems and emission control devices. Energy use

is expected to increase by about 10.2 million kilowatt hours per year

(kWh/yr) over current levels. About 7.1 million additional kWh/yr would

be needed for continuous pickling lines, 3.0 million kWh/yr for batch

lines, and 140,000 kWh/yr for acid regeneration plants.

F. Cost Impacts

Nationwide capital costs of the proposed standards are estimated at

$20 million with annual costs for operation and maintenance of about

$7.1 million. Capital cost estimates include costs for purchasing new

emission control devices (assumed to be scrubbers) for uncontrolled

lines, upgrading existing scrubbers (assumed to be 40 percent of the

cost of a new unit), and installing vent piping from acid storage tanks

to the pickling line control device. Annual costs for these facilities

are based on costs calculated for the model plants. Estimates of annual

costs for facilities with existing controls include improved

maintenance consisting of operating labor, shift supervision,

materials, and overhead for each emission source based on the type and

size of model plant. Annual costs were also added for upgrading

existing scrubbers and for new control devices (assuming scrubbers),

the costs for increased pressure drop, solids (sludge) disposal,

wastewater treatment costs, and additional energy requirements.

Cost-to-sales ratios and percent increase in the cost of production

statistics were estimated in order to determine the level of impact

this regulation will have on steel pickling facilities and steel

producers that conduct pickling activities. The analysis was completed

on a national basis and for all 17 model plants. In addition, the

ratios were evaluated on two alternative bases. The first utilizes all

facilities in the industry to estimate the control cost per ton of

steel produced. The second estimates the cost of control using only

those facilities that will be required to install controls. The control

costs were compared to the market price per ton of the relevant type of

steel for each model plant to compute cost-to-sales ratios for each

model plant. An average market price for steel was used to compute the

national average ratio. Cost of production was estimated to be 93

percent of market price.

Nationally, the control costs for the steel pickling industry are

0.033 percent of sales revenues and represent a 0.035 percent increase

in the cost of production. For those facilities that will be required

to install controls to meet the MACT standard, the costs represent

0.052 percent of revenues and an increase in the cost of production of

0.056 percent. The costs for individual model plants vary from a low of

0.011 to a high of 0.79 percent increase in the cost of production and

from 0.010 to 0.73 percent of revenues for all facilities in the

industry. The costs range from 0.023 to 1.15 percent increase in the

cost of production and from 0.021 to 1.07 percent of sales for the

individual facilities required to install emission controls and incur

costs.

The cost-to-sales ratios and percent increase in the cost of

production are well below 1 percent for the industry as a whole and for

the portion of the industry required to incur control costs as a result

of this regulation. The costs on a model plant basis approximate or are

less than a 1 percent increase in the cost of production and are an

equivalent percent of sales for all model plants. The magnitude of the

costs relative to production cost of the industry and sales revenues

leads to a conclusion that this standard will not significantly

adversely impact firms in the steel pickling industry. The results also

indicate that a more sophisticated economic impact analysis is not

required. No plant closures are anticipated nor are significant

employment losses. Significant regional impacts are also not expected.

Costs for model pickling and acid regeneration facilities and acid

storage tanks are given in the background information document, along

with additional information on the model plant parameters.

G. Economic Impacts

Estimated annual costs of emission control for pickling steel would

range from approximately $0.10 per ton of steel processed for large

operations to $8.00 per ton of steel for facilities with low production

rates. For producers of hot-rolled products, the estimated contribution

of pickling and coiling to total steel production costs in 1992 was

$7.27 per ton, or 2.3 percent of the total production cost. Based on

these values, the cost of adding emission control systems can be

proportionally higher for small producers and of comparable magnitude

to the cost of pickling, but would still be small compared with the

total cost of the steel product. The economic impact of the proposed

rule on the industry as a whole is projected to be minor.

VII. Rationale for Selecting the Proposed Standards

This section describes the rationale for the decision made by the

Administrator in selecting the proposed standards.

A. Selection of Source Category and Pollutants

Steel pickling facilities emit HCl, and acid regeneration

facilities emit HCl and Cl2. Both HCl and Cl2 are

among the HAP listed in section 112(b) of the Act.

In the most common type of continuous coil process used for steel

strip, individual coils are welded end-to-end and continuously run

through a series of, typically, three to four horizontal pickling

tanks. Virgin or regenerated acid is added near the end where the strip

exits; the pickling solution then cascades over weirs

[[Page 49059]]

toward the strip entry, countercurrent to the motion of the strip. The

pickling liquor is typically maintained at 170 to 200 deg.F by live

steam injection or by internal or external heat exchange. The pickling

section of a line may be up to 400 feet long. Following pickling, the

material is rinsed with fresh water in another series of tanks to

remove residual acid liquor. The rinsed material is then dried with

heated air.

Hydrochloric acid is emitted as HCl gas by evaporation from the

surface of the acid bath in the pickling tanks. Emissions may be

substantial because of the high vapor pressure of HCl at high

concentrations and temperatures. Also, mist of HCl in water can be

produced by mechanical action such as agitation of the bath by steam

sparging and movement of the steel through the bath.

A second, less common, type of continuous operation uses a vertical

spray tower in which pickle liquor is sprayed onto moving strip in

multiple vertical passes in an enclosed tower. Spray rinsing with fresh

water follows. Currently, a total of three units are in operation in

the country. Emissions are of a form similar to those from horizontal

tanks, and emission control requirements are virtually the same.

Push-pull lines are physically similar to continuous lines. In this

process, each coil is threaded through the pickling tanks separately.

Push-pull lines are generally shorter than continuous lines because the

speed is usually slower. The pickle liquor usually is maintained at

180 deg.F or higher by external heat exchangers. Emissions are the same

as those produced by continuous coil lines.

Continuous rod/wire and tubing lines are similar to but smaller

than continuous strip lines. Emissions are of the same form as those

from continuous coil and push-pull lines.

In batch lines, rod or wire in coils, pipe, and metal parts are

dipped into the pickling tank until the scale is dissolved. When

pickling is completed, the material is lifted from the bath, allowed to

drain, and rinsed by spraying or by immersion in one or more rinse

tanks. To reduce emissions, particularly from draining, batch pickling

temperatures are usually lower, typically 100 to 105 deg.F, than for

continuous operations. Emissions from batch lines are produced in the

same way as those from continuous lines and also from acid that is

entrained in the steel removed from the bath, most of which

subsequently flows or drips back into the bath.

Of the 13 acid regeneration plants identified at ten facilities,

twelve are spray roaster designs; the other plant is a fluidized bed

roaster. In the spray roasting process, waste pickle liquor is fed into

a venturi evaporator where it is mixed with hot gas from the spray

roaster. The liquor cools and cleans the gas of carryover iron oxide

particles, while the gas evaporates some of the water and HCl in the

liquor. Concentrated pickle liquor from the evaporator is fed to the

roaster, in which the liquor is evaporated by hot gas fed to the

chamber at about 1,200 deg.C. The ferrous chloride reacts with oxygen

and water vapor to form ferric oxide and HCl. The gases are drawn into

the absorber, where the contained water and acid are condensed and

combined with blowdown from the wet scrubber to form an acid solution

containing 16 to 20 percent HCl. Exhaust from the absorber is usually

drawn through a wet scrubber, which also acts as a final recovery

system for HCl, provided that water without chemical additives is used

as the scrubbing medium.

Equipment for the fluidized bed roasting process is similar, and

emission control requirements are virtually the same as those for the

spray roasting process.

Emissions of HCl that are not collected by the absorber or the wet

scrubber are released from both types of regeneration plants.

Acid regeneration plants also emit Cl2. Formation of

Cl2 increases as the operating temperature in the roaster

decreases and as excess air increases. These processes are normally

operated with sufficient excess air to insure that conversion to ferric

iron is complete.

Acid storage tanks are present at nearly all facilities to contain

the acid needed for pickling operations and the acid solution produced

by the regeneration plants. These storage tanks are typically totally

enclosed, except for loading and unloading of acid, with emissions from

the atmospheric vent commonly routed to the pickling or acid plant

emission control device or to a dedicated control device. Emissions

from tanks in the form of HCl gas and acid mist are released from

uncontrolled vents, especially during filling.

Emission tests at six continuous horizontal, one continuous

vertical, and two push-pull steel pickling facilities and one acid

regeneration facility showed that without controls, all of these

facilities were major sources for HCl and the acid plant was a major

source for Cl2. With existing controls, one of the

continuous horizontal pickling facilities was still a major source for

HCl and the acid plant was still a major source for both HCl and

Cl2.

In order to assess emissions from other types of pickling

operations, the EPA used an air emissions model for predicting HCl

emission rates from open surface baths. This model, submitted to the

EPA by a private engineering company that is experienced in the design

and evaluation of emission control systems for steel pickling

operations, takes into account the essential factors that affect

emissions, including temperature, HCl concentration, concentration of

dissolved ferrous chlorine, and air velocity across the tank surface.

Application of this model showed that without controls, pickling

operations of all five types can emit more than 10 tpy of HCl.

In view of the above findings, the EPA has determined that the

source category includes all five types of pickling operations and also

acid regeneration plants and that pickling operations are subject to

regulation for emissions of HCl and acid plants for emissions of HCl

and Cl2, two of the HAP listed in section 112 of the Act.

The standards being proposed would apply to all new and existing steel

pickling lines that use the HCl process and all new and existing HCl

regeneration plants.

The emission, equipment, and work practice standards being proposed

would substantially limit emissions of HCl from the above sources.

Lesser reductions of Cl2 emissions from acid regeneration

facilities would be achieved. The standards address HCl and

Cl2 directly rather than surrogates.

B. Selection of Affected Sources

The proposed standards apply to three types of emission sources at

steel pickling and acid regeneration facilities:

(1) Continuous and batch pickling lines using HCl as the pickling

acid, (2) HCl regeneration plants, and (3) acid storage tank sources.

Affected process sources include all acid tanks employed in HCl

pickling lines and all acid regeneration plants. In order to prevent

acid fumes from invading the working environment, most pickling tanks

are equipped with close fitting, overhead, push-pull, or side draft

hoods exhausted through induced draft fans. Emissions from these tanks

are found in the process exhaust gases that are discharged to the

atmosphere. Standards are therefore being proposed to limit emissions

of HCl from pickling tank exhaust gas vents.

Acid regeneration plant emissions are contained in the gases

exhausted from the acid recovery or absorber unit. The proposed

standards would limit HCl and Cl2 emissions from absorber

exhaust gases.

[[Page 49060]]

Fumes from the vents of acid storage tanks that are open to the

atmosphere contain emissions of HCl. Acid storage tank vents were

therefore selected for regulation. The proposed regulation would limit

emissions of HCl from storage tanks by requiring that the tank

atmospheric vents be equipped with APCDs and that any lines or vents

used for transport of acid into or out of the tanks be enclosed or

equipped with a local ventilation system exhausted through an APCD.

A fourth source considered for regulation was waste and wastewater

treatment operations. The spent pickle liquor is typically managed by

on site pretreatment and discharge to a publicly owned treatment works

(POTW) or removal by waste disposal contractors. Available data

indicate that wastewater treatment emissions are not significant

because the low vapor pressure of HCl inhibits volatilization. For

example, at 86 deg.F the vapor pressure of HCl over a solution

containing 4 percent HCl in water is below 0.0008 millimeters of

mercury.3

---------------------------------------------------------------------------

\3\ Perry, R.H., D.W. Green, and J.O. Maloney, eds. Chemical

Engineers' Manual. 6th ed. McGraw-Hill. New York. 1984. p. 3-64.

---------------------------------------------------------------------------

C. Selection of Basis and Level for the Proposed Standards for Existing

and New Sources

1. Background

As described previously in the NESHAP decision process discussion,

section 112 establishes a minimum baseline, or ``floor'', for

standards. For new sources, the standards cannot be less stringent than

the emission control achieved in practice by the best controlled

similar source. The standards for existing sources can be less

stringent than standards for new sources, but they cannot be less

stringent than the average emission limitation achieved by the best

performing 12 percent of existing sources for categories and

subcategories with 30 or more sources or the best performing five

sources for categories or subcategories with fewer than 30 sources.

When setting standards above the floor, the EPA may distinguish

among classes, types, and sizes of sources within a category or

subcategory. Furthermore, consideration must be given to the

incremental impacts on emission reduction, cost, economics, energy, and

other environmental concerns. The objective is to achieve the maximum

degree of emissions reduction without unreasonable adverse impacts.

Subcategorization within a source category is considered only when

there is enough evidence to demonstrate clearly that sources contained

in the source category are significantly dissimilar. The criteria to

consider include process operations (including differences between

continuous and batch operations), emission characteristics, control

device applicability and costs, safety, and opportunities for pollution

prevention.

Steel pickling processes are differentiated by the form of metal

treated and the configuration and operating cycle of the process. The

different types of continuous processes vary little except in size and

ancillary equipment. Batch operations differ significantly from

continuous operations in three ways: (1) The physical arrangement of

the unit must allow the steel to be placed into and withdrawn from the

top instead of the ends of the tank, (2) emissions may vary

substantially between the immersion and draining phases of the

operation, and (3) emission capture requirements are different for the

two types of operations.

Pickling tanks for all types of continuous lines are typically

equipped with lids or close fitting hoods. Emission capture systems for

batch pickling tanks may consist of two separate units: A push-pull

ventilation system to capture fumes from the tank surface, and a side

draft hood to capture fumes from steel that is suspended above the tank

to drain. Although some batch picklers use canopy hoods, at least 15 of

the 26 batch facilities employ side draft hoods. Emissions ventilated

through these hoods vary substantially because the drain phase occurs

for only a portion of the pickling cycle. Because of the different

emission characteristics, the EPA proposes to regulate continuous/

semicontinuous pickling lines and batch pickling lines as separate

subcategories.

The EPA also examined the processes, the process operations, and

other factors to determine if separate classes of units, operations, or

other criteria have an effect on air emissions. Acid emission rates are

affected by tank size, acid concentration and temperature, iron

concentration, ventilation system, gas flow rate, bath temperature

control method, and degree of agitation in the tank. The performance

requirements for an emission control system may be affected by these

process variables. A qualitative review of the data revealed that

processes that employ steam sparging for bath temperature control

tended to produce more HCl emissions than processes employing heat

exchange, but no differences in control device requirements or control

efficiencies could be attributed to differences in temperature control

method. No effect of other process variables on control device

requirements or control efficiency could be identified. The EPA

therefore did not identify separate subcategories of sources based on

process variables.

2. Selection of MACT

The EPA has taken alternative approaches to establishing MACT floor

conditions for new and existing sources depending on the type, quality,

and applicability of available data. The three approaches most commonly

examined include reliance on: (1) Information on State regulations and/

or permit limitations, (2) source test data that characterize actual

emissions discharged by sources, and (3) use of a technology floor and

an accompanying demonstrated achievable emission level that accounts

for process and air pollution control device variability.

No Federal air emission standards currently apply to steel pickling

or acid regeneration sources. Four states have established emission

limits for HCl, which range from 0.73 to 3 pounds per hour of HCl. At

least 18 states and territories have established ambient air limits for

HCl; these limits are values for allowable concentrations of HCl

outside the facility boundaries or in adjacent neighborhoods downwind

from the source.4 These limits vary widely. For example,

one-hour exposure limits range from 75 to 2,000 g/m\3\, and

24-hour limits range from 2.03 to 700 g/m\3\. Similarly, at

least 18 states and territories have established ambient air limits for

Cl2.5 One-hour exposure limits range from 29 to

69 g/m\3\, and 24-hour limits range from 3.6 to 75 g/

m\3\. These standards cannot be directly related to the requirements of

this rule.

---------------------------------------------------------------------------

\4\ World-Wide Limits for Toxic and Hazardous Chemicals in Air,

Water, and Soil. M. Sittig. Noyes Publications. Park Ridge, NJ.

1994. pp. 425-426.

\5\ Reference 4. pp. 178-179.

---------------------------------------------------------------------------

Applicable test data to characterize actual emissions from pickling

lines are available for only 10 of the 152 continuous pickling lines

and none of the 59 batch pickling lines. These data points are too few

to establish 12 percent MACT floors for pickling lines; 18 points would

be required for continuous lines and seven points for batch lines.

By comparison with the limited utility of state regulations and

source test data, a substantial body of information is available on the

types, configurations, and operating conditions of air pollution

control devices applied across the industry. This information was

collected through the

[[Page 49061]]

comprehensive survey by the EPA of known HCl steel pickling facilities

that was conducted in 1992 through the information collection request

(ICR), which was approved by the Office of Management and Budget for

NESHAP information gathering. This survey produced substantial

information on the design and operation of emission control equipment

but little information on actual emissions. The EPA therefore used the

technology floor approach to establishing MACT for pickling lines.

For acid regeneration plants, sufficient source test data are

available to pursue an actual emissions approach for determining MACT

floors. Only five data points would be required to establish the floor

for acid regeneration plants because there are fewer than 30 plants in

this subcategory. Enough data were available to construct average or

median emission values for both HCl and Cl2.

Continuous pickling lines. Wet scrubbers are the only kind of

device known to control HCl emissions from pickling lines of all types.

MACT for continuous pickling lines is therefore wet scrubbing. The two

variations of scrubbers employed are packed bed and sieve tray.

Data from the ICR responses show that emissions from 107 of 152

continuous pickling lines are controlled, including 60 of 64 continuous

coil, all 22 push-pull coil, 19 of 55 rod/wire, and five of 11 tubing

picklers. Twenty-five lines are controlled with sieve tray scrubbers,

41 with vertical packed bed scrubbers, 16 with horizontal packed bed

scrubbers, 14 with packed bed scrubbers of unidentified configuration,

eight with scrubbers in series, and three with unidentified types of

systems.

The use of a droplet eliminator (DE) in conjunction with a wet

scrubber is considered standard practice, and mesh pad or chevron

(vane) type DEs were identified in 13 control systems; they are assumed

to be employed in the majority of systems. Data were available to

determine the effectiveness of vertical packed bed and sieve tray

scrubbers in combination with both types of DEs. No distinction could

be made in the effectiveness of the mesh pad and chevron devices. Both

types are therefore considered to be equally effective.

The effectiveness of a scrubber may depend on the collection medium

used. The medium used in pickling line scrubbers is either

unneutralized water from plant or public sources or water to which an

alkaline substance has been added. Most of the wet scrubbers employed

to control pickling emissions use water as the collection medium, but

alkaline solution is used in some units. In principle, the use of

alkaline solution could result in increases of HCl removal efficiency

by reducing the vapor pressure of HCl in equilibrium with the scrubbing

solution. In practice, however, increased efficiencies were not

observed for pickling process scrubbing systems that could be

attributed solely to the use of alkaline medium. Also, the equilibrium

vapor pressure of HCl for weak hydrochloric acid solutions is

inherently very low. The EPA concludes that use of an alkaline

collection medium does not constitute a more effective level of control

than the use of water for this application.

The characteristics of the scrubbers constituting the existing

source and new source levels of control were determined by evaluating

the results of emission tests conducted on units currently employed in

the industry. Ten valid sets of emission test data on scrubbers applied

to representative continuous strip and push-pull strip pickling lines

were collected. All tests were conducted on sieve tray and vertical

packed bed scrubbers. Fundamental design measures of performance for

units of these types include the number of trays in sieve tray

scrubbers and the depth of the packing in packed bed scrubbers.

The data from these tests are presented and discussed in detail in

the background information document. The data are from four source

tests conducted by the EPA and six tests conducted by industry. All

data sets consist of results from sampling runs conducted under

conditions representing normal scrubber and pickling line operations,

and all data sets include simultaneous inlet and outlet measurements.

Six tests include a minimum of three sampling runs each, three

tests include two runs each, and one test consists of one run. Of the

six tests that include three or more sampling runs each, two were

conducted on sieve tray scrubbers with six and three plates,

respectively, and four were conducted on vertical packed bed scrubbers

that contained packing ranging from 5 to 10 feet in depth. One sieve

tray unit was equipped with a mesh pad DE, the other with a chevron DE.

Two packed bed units were equipped with mesh pad DEs, two with chevron

or vane DEs. Thus, all four combinations of scrubber and DE type are

represented in these six tests. Of the three tests that included two

sampling runs each, all were conducted on vertical packed bed scrubbers

with mesh pad DEs. The test with one sampling run was conducted on a

five-plate sieve tray scrubber equipped with a chevron DE.

Of the remaining lines using the same types of devices, at least 10

employ sieve tray scrubbers with a number of trays in the range of

those tested (3 to 6) and 15 employ vertical packed bed units with

packing depth in the same range as those tested (5 to 10 feet). Thus,

on these design criteria, the control devices tested represent those

employed by at least 35 lines. No scrubber designs employed in this

source category have been demonstrated to be more effective than these.

The EPA therefore assumes that the best controlled 12 percent (18

lines) are found in this group of 35.

All tests were conducted using either EPA Method 26A in appendix A

to 40 CFR part 60 or a method equally valid for this application. Field

evaluations indicate that Method 26A is an acceptable procedure for

measuring HCl from municipal waste combustors at levels as low as 3

ppmv.6 The EPA considers the method to be equally valid for

measuring emissions from pickling and acid regeneration sources.

Emission reduction efficiency values on the above tests were adjusted

on the premise that measured outlet HCl concentrations below 3 ppmv may

not be accurate enough to determine numerical emission standards.

Reported outlet concentrations of less than 3 ppmv were assumed to be 3

ppmv for purposes of calculating reduction efficiencies and determining

the numerical emission limits.

---------------------------------------------------------------------------

\6\ Laboratory and Field Evaluation of a Methodology of

Determination of Hydrogen Chloride Emissions from Municipal and

Hazardous Waste Incinerators. U.S. Environmental Protection Agency.

Office of Research and Development. Atmospheric Research and

Exposure Assessment Laboratory. EPA-600/3-89-064. 1989.

---------------------------------------------------------------------------

Reduction efficiencies for HCl for the ten scrubbers range from

99.9 to 92.7 percent; HCl outlet concentrations range from 3.0 to 92

ppmv.

The best controlled lines are two lines that achieve both 99

percent or greater HCl collection efficiencies and 3 ppmv or lower HCl

outlet concentrations. One line is served by a six-plate sieve tray

scrubber and one by a packed bed scrubber. These control devices are

the most effective devices demonstrated in this application and

therefore constitute the new source MACT floor for continuous pickling

operations.

For the remaining eight scrubbers, neither sieve tray nor vertical

packed bed units as groups were superior to the other type of device.

The existing source MACT floor therefore is sieve tray scrubbers with 3

to 5 trays and vertical packed bed scrubbers with 5 to 10 feet of

packing.

[[Page 49062]]

The EPA is required to consider levels of control more stringent

than the floor level if such levels exist. No higher level of control

exists for new sources than the level proposed. For existing sources,

the new source level of control is more stringent and therefore was

considered. As discussed below in section VII.E of this document,

``Selection of Emission Limits'', the proposed emission limits for

existing source MACT are 97.5 percent minimum HCl reduction efficiency

or 10 ppmv maximum HCl outlet concentration. According to a cost

analysis, the additional cost of controls to reduce emission levels

from either an outlet concentration of 10 to 3 ppmv HCl or increase

reduction efficiencies from 97.5 to 99 percent is estimated to be $20.7

million for capital costs and $3.0 million for annual costs. The

associated emission reduction is estimated to be 450 Mg/yr. The cost

effectiveness is therefore $46,000 per Mg of HCl reduction for capital

cost, $6,700 per Mg for annual cost. The EPA considers this burden to

be excessive and therefore is not proposing the higher level of control

for existing sources. By comparison, the cost effectiveness of the

proposed rule is $2,400 per Mg of HCl reduction for capital cost and

$850 per Mg of reduction for annual cost for pickling lines and acid

regeneration units combined.

Batch pickling lines. According to data from the ICR responses,

only 14 of the 59 batch pickling lines are controlled, although 36

lines are equipped with local ventilation. As with continuous picklers,

wet scrubbers are the only type of control device identified. MACT for

batch pickling lines is therefore wet scrubbing. Nine lines employ

vertical packed bed scrubbers, two employ horizontal packed bed units,

and two employ wet scrubbers of unknown types.

No valid test data are available for batch operations. The MACT

floor must therefore be determined by an assessment of scrubbers of

these types in similar applications, e. g., continuous pickling lines.

Of the vertical packed bed systems employed, at least five scrubbers

have packing depths equal to or greater than those found in continuous

pickling line scrubbers (5 to 10 feet) and would be expected to perform

as well as those units. The use of DEs will be inferred by the fact

that they are standard equipment in similar types of applications. The

existing source MACT floor technology therefore includes packed bed

scrubbers of the same capability as the packed bed scrubbers in the

existing source MACT floor technology for continuous pickling lines.

The expected level of performance is assumed to be the same as that for

existing continuous lines. The EPA therefore believes that selection of

the same existing source MACT floor for batch pickling lines as for

continuous lines is justified.

Unlike continuous pickling, data are not available on batch

pickling to allow differentiation in terms of scrubber performance. No

distinction could be made among the scrubbers constituting the existing

source MACT floor. Consequently, the new source MACT floor is the same

as the existing source MACT floor for this subcategory of sources.

The EPA considered one higher level of control than the MACT floor,

namely the level of control for new continuous pickling sources, for

application to both existing and new batch pickling sources. According

to a cost analysis, the additional cost of controls for existing batch

pickling lines to reduce emission levels of existing sources from

either an outlet concentration of 10 to 3 ppmv HCl or increase

reduction efficiencies from 97.5 to 99 percent was estimated to be

$610,000 for capital costs and $140,000 for annual costs. The

associated emission reduction is estimated to be 61 Mg/yr. The cost

effectiveness is therefore $10,000 per Mg of HCl reduction for capital

cost, $2,300 per Mg for annual cost. This burden is considerably lower

than the additional burden required for existing continuous lines to

reduce emissions to new source levels instead of existing source

levels. The emissions reduction that would be achieved, however, is

very low; 61 Mg/yr is less than one percent of the total of 8,360 Mg/yr

that would be achieved by implementation of the proposed rule. In view

of the minimal gain to be achieved, the EPA proposes that the more

stringent level of control not be required for existing batch pickling

sources.

The EPA proposes that the new source level of control for

continuous pickling lines be required for new source batch pickling

lines because the control technologies are virtually identical for both

subcategories of sources.

Acid regeneration plants. Ten acid regeneration facilities, eight

of which are collocated at pickling facilities, operate 13 regeneration

plants. Based on information submitted in ICR responses from all 10

facilities, the following control devices are employed to reduce

emissions. Nine plants use single-stage vertical packed bed scrubbers

with water as the collection medium. Each scrubber is equipped with a

DE and packing that ranges from 6 to 25 feet in depth. Two plants use

two-stage vertical packed towers, with water as the collection medium

in the first stage and alkaline solution in the second stage. One plant

uses two-stage packed tower absorption, which is similar to single

stage absorption followed by a stage of scrubbing; the second absorber

is followed by a venturi scrubber that uses alkaline solution. The

thirteenth plant is uncontrolled.

Similarly to EPA's technical judgement on the effectiveness of

scrubbing with alkaline media versus unneutralized water for HCl

control on pickling lines, the EPA does not believe that the use of

alkaline media in scrubbers necessarily enhances control over the use

of unneutralized water for HCl control on acid regeneration plants,

even though the use of alkaline media does enhance Cl2

control. Consequently, any improvement in HCl control by the control

systems that employ dual stages of absorption or scrubbing plus use of

an alkaline medium is due in EPA's opinion to the existence of multiple

stages rather than the use of alkaline media.

Because the source category includes fewer than 30 acid

regeneration plants, the MACT floor for existing sources is determined

by the average emission limitation achieved by the best controlled five

plants.

HCl collection efficiency data were available for only one plant.

Collection efficiency could therefore not be used as a basis for

determining MACT. By comparison, scrubber outlet concentration data

were available for five plants; this information was used to determine

the MACT floors for new and existing sources.

Measured scrubber outlet concentration values are 0.9, 1.0, 3.1,

16, and 137 ppmv HCl. The 137 ppmv value is far out of line with the

other values and is considered to be the result of a malfunction in the

acid regeneration plant, specifically inefficient absorber operation.

This value is therefore not included in any determinations.

Referring to the limitation of the test method employed discussed

previously in this section, concentration values below 3 ppmv cannot be

measured with assurance. Measured values of less than 3 ppmv are

assumed to be 3 ppmv for the purpose of determining MACT and the

numerical emission limit. The outlet concentration values used were

therefore 3, 3, 3.1, and 16 ppmv HCl.

New source MACT for HCl control is based on the lowest exhaust gas

concentration achieved in practice by the best similar source or

sources. Three plants currently achieve measured HCl

[[Page 49063]]

concentrations of 3.1 ppmv or lower and constitute MACT. These plants

employ two-stage scrubbing with vertical packed bed scrubbers or two-

stage absorption followed by a venturi scrubber. Consequently, the

floor and MACT for new sources is the level of control demonstrated by

two-stage scrubbing or two-stage absorption.

If the MACT floor for existing sources is to be determined by the

median of the concentrations achieved by the best 5 controlled plants,

the value will be 3 ppmv (3.1 ppmv rounded off). If the floor is to be

determined by the average of the concentrations achieved by the best 5

controlled plants, a fifth value will have to be assumed. The assumed

value would be 16 ppmv because it cannot be determined that any of the

other 8 plants employing single-stage scrubbing performs at either a

higher or lower level than the plant for which information is

available. The average of 3, 3, 3.1, 16, and 16 ppmv is 8 ppmv.

In choosing between using the average or the median concentration

to determine the MACT floor, the EPA considered the capabilities of the

control technology currently in use and also the relative costs and

benefits of the two options. As described above, three plants have been

shown to achieve the 3 ppmv HCl median value. These include two plants

that employ two-stage scrubbing with vertical packed bed scrubbers and

a third plant that employs two-stage absorption and single-stage

scrubbing with a venturi scrubber. Nine of the twelve plants that are

controlled, however, employ single-stage scrubbing, which has not been

demonstrated to be capable of achieving the 3 ppmv level of control.

Also, according to a cost analysis that is presented later in this

section, the incremental annual cost of increasing control from 8 ppmv

to 3 ppmv is $7,600 per Mg of HCl reduction, which EPA considers to be

excessive. Based on these considerations, the EPA is proposing to use

the average level of control, 8 ppmv HCl outlet concentration, to

determine the existing source MACT floor. Although no single-stage

scrubber employed in an acid regeneration plant has been demonstrated

to meet this level of control, it would be more achievable than 3 ppmv.

Also, the existing source level of control proposed for pickling lines

is a similar value, 10 ppmv, and the scrubbers used to control pickling

lines are mainly single-stage units.

MACT for chlorine emission control was determined from the best

five controlled plants for Cl2. Collection efficiency data

were too limited to be used. Data were available from three plants; two

were the plants that use two-stage scrubbing with alkaline media in the

second stages, and the third was a plant that uses single-stage water

scrubbing. Chlorine reduction was virtually nil from the latter plant

because water does not absorb Cl2 effectively. The secondary

scrubbers using alkaline solution reduce Cl2 emissions from

5.1 to 2.1 ppmv and from 7.8 to 0.27 ppmv. Respective Cl2

collection efficiencies are 53 and 94 percent, a wide variation for two

identical units operated with the same goal. The EPA consequently

believes that neither MACT nor a numerical emission limit for

Cl2 can be determined from collection efficiency data.

Outlet Cl2 concentration data were available from four

plants. Measured values are 0.3, 2.1, 3.3, and 60 ppmv. As discussed

previously in this section, EPA Method 26A in appendix A to 40 CFR part

60 is considered acceptable for HCl concentrations as low as 3 ppmv.

Although no lower limit is given for Cl2, the EPA believes

that the limit would be similar to that for HCl considering the details

of the test method. Consequently, the actual Cl2 outlet

concentrations are taken to be 3, 3, 3.3, and 60 ppmv.

The 60 ppmv value appears to be high enough compared with the other

values to be considered a result of inefficient operation and therefore

was not included in the data used to determine MACT or the numerical

limit.

The existing source MACT floor for Cl2 control was

determined from the median level of achievement of the best five

performing sources, i. e., the third best controlled source. Because

the best performing three plants have virtually identical performance,

all three technologies constitute MACT. Two of these plants are those

that employ two-stage scrubbing with caustic media in the second

stages. The third plant uses only single-stage scrubbing with water.

The latter facility, however, controls Cl2 emissions through

control of process operating conditions. The existing source MACT floor

for Cl2 control therefore is scrubbing with an alkaline

medium or control of plant operating conditions.

Wet scrubbing systems that do not use alkaline solution as the

collection medium do not effectively control Cl2 emissions.

Scrubbing with alkaline solution, however, has a significant

disadvantage in that the scrubber blowdown cannot be recycled to either

an acid plant or a pickling process but must be disposed of; thus,

alkaline scrubbing creates an additional waste product.

By comparison, control of process conditions does not create a

waste product nor require a control device. Formation of Cl2

in acid regeneration can be reduced by increasing the operating

temperature and decreasing the amount of the excess oxygen in the

roaster.7 These processes are normally operated with

sufficient excess air to insure that conversion of ferrous iron to

ferric iron is complete. At least one facility, however, operates under

conditions that are chosen to reduce Cl2 formation. The EPA

therefore believes that regeneration plants can be operated to minimize

Cl2 formation while maintaining product quality. The

facility that operates with a specific goal of reducing Cl2

formation has measured a Cl2 concentration of 3.3 ppmv in

the process offgas. As discussed above, the facility operating two

regeneration plants has measured Cl2 concentrations in the

process offgases prior to alkaline scrubbing of 5.1 and 7.8 ppmv, which

are of the same order as 3.3 ppmv. The EPA believes that controlling

process operating conditions can result in reducing Cl2

formation to a demonstrated concentration level and therefore proposes

that control of process operating conditions be included in the MACT

floor for reducing Cl2 emissions from acid regeneration

plants. Because of the limited data available to support this

conclusion, the EPA solicits comment on this selection of MACT.

---------------------------------------------------------------------------

\7\ Chlorine Control of Pickling Acid Regeneration Plants. E.

Th. Herpers, B. Schweinsberg, N. Ozer, and J. Bozcar. International

Chemical Engineering Symposium Series No. 57. pp. BB1-BB14.

Available from University of California, Los Angeles, PSTL/

Interlibrary Loans, 8251 Boelter Hall, Los Angeles, CA 90024-1598.

---------------------------------------------------------------------------

New source MACT for Cl2 control is determined by the

single best performing plant. The outlet concentration values of 3, 3,

and 3.3 ppmv are virtually identical, and therefore the best performing

plant could be any one of the best three. The new source MACT floor for

Cl2 control is therefore the technology used by all three

plants, i.e., the same as the existing source MACT floor.

As in the case of the standard for pickling lines, the EPA

considered levels of control more stringent than the MACT floor. For

HCl control, no higher level of control exists for new sources than the

level proposed. For existing sources, the new source level of control

is more stringent and therefore was considered. The additional cost of

controls to reduce outlet concentrations from 8 to 3 ppmv HCl is

estimated to be $2.9 million for capital costs and $1.0 for annual

costs. The associated

[[Page 49064]]

emission reduction is estimated to be 133 tpy. The cost effectiveness

is therefore $22,000 per Mg of HCl reduction for capital cost, $7,600

per Mg for annual cost. The EPA considers this burden to be excessive

and therefore is not proposing the higher level of control for existing

sources.

For Cl2 control, no higher level of control is known

than that proposed, and therefore no higher level could be considered.

Acid storage tanks. Storage tanks typically provide complete

enclosure of the acid. Based on data from ICR responses, 40 pickling

facilities and four regeneration plants employ emission control systems

on tanks used for storage of virgin and regenerated acid. A total of 24

of the 40 pickling facilities and all four regeneration plants vent

tank fumes to the scrubbers that service the associated pickling

process or acid plant. The control systems at the remaining 16

facilities were not determined to be more or less effective than the

pickling process and acid plant control systems at the 24 facilities.

The MACT floor for existing acid storage tanks therefore includes

covering and sealing all openings on the tank, except during loading

and unloading of acid, and routing emissions from the atmospheric vent

to a control device. The EPA is not requiring that fumes be vented to

the same control device used to service the associated pickling line or

acid plant because the tank may be in a remote location; in this case,

a separate device may be used.

At least 15 facilities control acid fumes during acid transfer to

and from the tanks by either conducting the transfer through sealed

lines and connections or providing local ventilation through a control

device at the point of transfer. The existing source MACT floor

therefore also includes acid transfer fume control through either a

sealed connection or use of local ventilation at the transfer point

through a control device.

The effectiveness in HCl control of these systems could not be

differentiated, and thus no one system that was more effective than the

others could be identified. The new source MACT floor is therefore the

same as the existing source floor.

D. Selection of Format

Section 112 of the Act requires the Administrator to prescribe

emission standards for HAP control unless, in the Administrator's

judgement, it is not feasible to prescribe or enforce emission

standards. Section 112(h) defines two conditions under which it is not

feasible to prescribe or enforce emission standards: (1) If the HAP

cannot be emitted through a conveyance device designed and constructed

to emit or capture the HAP; and (2) if the application of measurement

methodology to a particular class of sources is not practicable because

of technological or economic limitations. If it is not feasible to

prescribe or enforce emission standards, then the Administrator may

instead promulgate equipment, work practice, design, or operational

standards, or a combination thereof.

Format options for numerical emission standards or limits include

mass concentration (mass per unit volume), volume concentration (volume

per unit volume), mass emission rate (mass per unit time), process

emission rate (mass per unit of production or other process parameter),

and degree or percentage of reduction.

1. Pickling Lines and Acid Regeneration Plants

A mass emission rate for HCl is not proposed for pickling lines

because of the large variation in the size of the operations. The EPA

did not propose a process emission rate because no correlation between

HCl emissions and the amount of steel processed or the amount of acid

used has been established. For acid regeneration plants, mass and

process emission rates are not proposed for HCl or Cl2

because too little information is available to establish any applicable

relationship.

Wet scrubbers constitute MACT for HCl for pickling lines and acid

regeneration plants. Control systems of this type are normally designed

for a target emission reduction efficiency for these applications. For

these reasons, EPA proposes that a minimum HCl reduction efficiency be

established for subcategories where sufficient data are available to

establish a numerical limit.

Concentration of a soluble pollutant in the scrubber outlet gas

cannot be reduced below the value that corresponds to the equilibrium

vapor pressure of the pollutant in contact with the inlet scrubbing

medium. Furthermore, depending on temperature and humidity, some HCl

may be present as an aerosol or in water droplets as well as a gas. The

effect on control efficiency of the presence of aerosol or droplets is

not known. High reduction efficiencies for process gases that contain

low concentrations of HCl or HCl in aerosol or droplet form may

therefore not be achievable. The EPA therefore proposes that a maximum

exhaust gas concentration be established as an alternative to reduction

efficiency in recognition of these limitations of MACT.

As discussed previously in section VII.C of this document,

``Selection of Basis and Level for the Proposed Standards for Existing

and New Sources'', technical information on acid regeneration processes

plus measured Cl2 exhaust gas concentration values for three

plants suggest that these processes can be operated under conditions

that achieve a target outlet gas concentration of Cl2.

Based on the above considerations, the EPA is proposing: (1) The

options of meeting either an HCl reduction efficiency limit for APCD

performance or an HCl exhaust gas concentration limit for pickling

lines; and (2) meeting an HCl exhaust gas concentration limit for acid

regeneration plants. The EPA is also proposing a Cl2 exhaust

gas concentration limit for acid regeneration plants.

2. Acid Storage Tanks

An equipment standard is proposed for acid storage tanks because

emission measurements may be neither practicable nor cost-effective.

Also, if the air pollution control system that services the associated

pickling process or acid regeneration unit is used to control tank

emissions, the need for making a separate measurement is precluded.

E. Selection of Emission Limits

1. Continuous Pickling Lines

Several types of information were available to determine the

proposed emission limits for HCl:

(1) Emission tests conducted by a method valid for this source; (2)

emissions data derived by other means; (3) emissions data reported by

the facility with no basis given; and (4) information from vendors and

designers that would indicate an expected level of performance. For

purposes of this discussion, the term ``valid'' means data from tests

conducted by EPA Method 26A, ``Determination of Hydrogen Halide and

Halogen Emissions from Stationary Sources--Isokinetic Method'' in

appendix A to 40 CFR part 60, or an applicable equivalent method. The

EPA decided to use only data from tests conducted by valid methods.

In selecting the emission limits for pickling line sources, the EPA

decided to select limits that could demonstrably be met by a compliance

test, i. e., a test conducted using EPA Method 26A (40 CFR part 60,

appendix A) with a minimum of three sampling runs. Referring to the

discussion in section VII.C above, the two scrubbers

[[Page 49065]]

constituting new source MACT are a six-tray scrubber and a packed bed

scrubber. The six-tray scrubber was tested with three sampling runs.

The average measured HCl outlet concentration was 2.0 ppmv, and the

average measured HCl collection efficiency was 99.96 percent. The

average scrubber inlet HCl loading for the three runs was 5,150 ppmv,

which is the highest of all scrubbers tested. The packed bed scrubber

was tested with 11 sampling runs. The average measured HCl outlet

concentration was 1.6 ppmv, and the average measured HCl collection

efficiency was 99.5 percent. The average scrubber inlet HCl loading was

260 ppmv, which is near the low end of the range for all scrubbers

tested (the lowest being 98 ppmv). For the three worst consecutive runs

of the eleven, the average measured HCl outlet concentration was 2.6

ppmv, and the average measured HCl collection efficiency was 98.9

percent. Except for one run, all collection efficiencies were above 99

percent, and all measured outlet concentrations were below 2.0 ppmv.

In view of this information, the EPA believes that the proposed

numerical limit options of 99 percent HCl collection efficiency and 3

ppmv HCl outlet concentration are reasonable and can be met in

compliance tests. Although the measured collection efficiency achieved

by the best scrubber is considerably better than 99 percent (i.e.,

99.96 percent), the EPA believes that this level of efficiency is

achieved primarily because of the exceptionally high inlet scrubber

loading. This level of efficiency may not be demonstrable for scrubbers

with lower inlet loading, even at the middle of the expected range,

because the required outlet concentration would be too low to measure

with accuracy.

Four lines currently achieve a 3 ppmv or lower exhaust gas

concentration limit and/or a 99 percent or greater reduction efficiency

based on actual test results. Twenty-one additional lines would meet

the standard based on reported outlet concentrations or reduction

efficiencies.

Existing source MACT consists of the level of control that is

achieved by the remainder of the scrubbers for which test data are

available. Data from three or more runs are available for four of the

scrubbers constituting existing source MACT. The averages of the runs

were as follows:

------------------------------------------------------------------------

HCl outlet

HCl collection efficiency (percent) concentration

(ppmv)

------------------------------------------------------------------------

98.1..................................................... 62

97.5..................................................... 42

97.0..................................................... 12.7

94.7..................................................... 8.0

------------------------------------------------------------------------

In section VII.D of this document, ``Selection of Format'', EPA

presented its rationale for proposing options of collection efficiency

or outlet concentration. Because each owner or operator of a pickling

facility has two options for meeting the proposed standard, the EPA

decided to derive each numerical limits from the best performing

scrubbers for that option. For collection efficiency, three scrubbers

are clearly the best. The average performance for these three is 97.5

percent efficiency. For outlet concentration, two scrubbers are

superior. The average performance for these two is 10 ppmv

concentration. The numerical standards proposed for existing sources

are therefore 97.5 percent minimum HCl reduction efficiency and 10 ppmv

maximum outlet HCl concentration.

Seven continuous pickling lines meet the maximum 10 ppmv exhaust

gas concentration standard and/or the minimum 97.5 percent reduction

efficiency standard based on actual test results. Fifty additional

lines would meet the standard based on reported outlet concentrations

of 10 ppmv or lower or reduction efficiencies of 97.5 percent or

higher.

2. Batch Pickling Lines

Referring to the discussion above in section VII.C of this

document, given that MACT for existing batch lines is the same as MACT

for existing continuous lines, the EPA believes that selection of the

same emission limits for existing batch pickling lines as for existing

continuous lines is justified. The numerical standards proposed for

existing sources are 97.5 percent minimum HCl reduction efficiency and

10 ppmv maximum outlet HCl concentration. New source MACT for batch

pickling lines is the same as existing source MACT for batch lines.

However, as discussed in section VII.C of this document, the EPA is

proposing the same level of control for new batch lines as for new

continuous lines because the control technologies for the two

subcategories of sources are indistinguishable from each other. The

numerical standards proposed for new sources are therefore 99 percent

minimum HCl reduction efficiency and 3 ppmv maximum outlet

concentration.

3. Acid Regeneration Plants

Referring again to the discussion in section VII.C of this

document, the proposed HCl outlet concentrations derived in determining

the existing source and new source MACT floors were 8 ppmv and 3 ppmv,

respectively.

Two plants currently meet the HCl exhaust gas concentration limit

of 3 ppmv based on test results. A third plant achieves an outlet

concentration of 3.1 ppmv HCl. No additional plants meet the 8 ppmv

limit based on actual test results available; one additional plant

meets the 8 ppmv limit based on reported outlet concentration.

As discussed in section VII.C of this document, the levels of

control achieved by the new and existing MACT floors for Cl2

control are virtually the same. The proposed maximum outlet

concentrations for new and existing sources are therefore the same.

Because only one of the three plants for which Cl2

emission data are available was tested with three sampling runs, the

EPA considered results of individual runs in establishing the

Cl2 numerical limit. Measured values for Cl2

outlet concentrations from one plant were 1.1, 1.9, and 3.4 ppmv;

values measured for the second plant were 0.16 and 0.38 ppmv; and

values measured for the third plant were 3.0 and 3.6 ppmv. Because of

the limited number of data points, the EPA decided to propose an

emission limit of 4 ppmv Cl2 to accommodate the uncertainty

of meeting a lower limit in a compliance test.

Three plants are known to meet the 4 ppmv Cl2 maximum

outlet gas concentration limit based on test results. The EPA notes

that one plant that achieves this limit employs single stage scrubbing

without the use of alkaline solution; the limit is achieved through

process control. No additional plants meet this limit based on reported

information.

The EPA is not aware that all existing acid regeneration plants are

designed to operate at conditions under which this limitation can be

achieved and therefore proposes that a plant can be operated at a

higher concentration provided that it can demonstrate that a

concentration of 4 ppmv cannot be achieved within the design operating

conditions of the unit. Each facility will be allowed to conduct a

demonstration test at maximum design operating temperature and minimum

excess air consistent with iron oxide production of acceptable quality

while measuring Cl2 concentration in the exhaust gas. The

measured concentration will become the standard for that regeneration

plant.

[[Page 49066]]

As in the case of existing sources, a new source would have the

opportunity to conduct a demonstration test at maximum design

temperature and minimum excess air to establish a higher concentration

limitation. However, a new source would also have to provide a reason

why the process could not be designed to operate under conditions that

would allow it to meet the 4 ppmv Cl2 limitation.

F. Selection of Monitoring Requirements

The EPA evaluated the hierarchy of monitoring options available for

the HCl pickling process and proposed control equipment. This hierarchy

includes measurement of HCl and C12 by a CEMS, installation

of measurement devices for continuous monitoring of process and control

device operating parameters, and periodic performance tests. Each

option was evaluated relative to its technical feasibility, cost, ease

of implementation, and relevance to the process or control device.

CEMSs provide a direct measurement of emissions. Monitors for HCl

and C12 emissions are commercially available. Although these

systems have not yet been demonstrated for pickling and acid

regeneration operations, the EPA believes that HCl monitors can be used

for these applications; the technical feasibility of monitoring

C12, however, is in question. The nationwide capital cost of

this option (CEMSs for all scrubbers) is estimated at $18 million, with

annual costs of $9.2 million for operation and maintenance, quality

assurance and quality control performance evaluation, and reporting/

recordkeeping requirements. Because of the high cost of using CEMSs

compared with the cost of monitoring control device and process

parameters, the EPA is not considering requiring the use of CEMSs to

demonstrate compliance.

Another option is monitoring process and/or control device

operating parameters plus conducting annual emission tests. Process

parameters were not selected as indicators for HCl emissions because a

good correlation does not exist between production and emission rates.

Control device operating parameters were selected instead because

measurements outside a range of values established during an initial

performance test would indicate the control device was not operating

properly. The estimated nationwide capital costs of this option are

$450 thousand; annual costs are $1.5 million.

Annual emission tests by Method 26A in appendix A to 40 CFR part 60

would not require a capital investment. The estimated cost assumes the

use of a test contractor and includes time for participation by plant

personnel.

The EPA believes that reasonable assurance of compliance is

achieved through monitoring control device operating parameters and

annual emission tests.

1. Pickling Lines

The proposed NESHAP offers the owner or operator a choice of two

monitoring options for HCl. The owner or operator would either install,

operate, and calibrate devices for the continuous measurement and

recording of scrubber pressure drop and scrubbing medium acidity and

conduct annual performance tests by Method 26A in appendix A to 40 CFR

part 60 or install and operate a CEMS and comply with all the

requirements in the general provisions in subpart A of 40 CFR part 63

that apply to a CMS.

A number of facilities may be able to meet the proposed HCl

emission limits if the existing control systems were maintained in

improved working order. To ensure continued proper operation of the wet

scrubber control devices, the proposed NESHAP includes a requirement

for the development and implementation of a written maintenance

program. The elements required to be included in the maintenance plan

are:

Perform the manufacturer's recommended maintenance at the

recommended intervals on fresh solvent pumps, recirculating pumps,

discharge pumps, and other liquid pumps, and exhaust system and

scrubber fans and those motors associated with pumps and fans;

Clean the scrubber internals and mist eliminators at

intervals sufficient to prevent buildup of solids or other fouling that

degrades performance below emission limits or standards;

Conduct a periodic inspection of each scrubber and (1)

clean or replace any plugged spray nozzles or other liquid delivery

devices, (2) repair or replace missing, damaged, or misaligned baffles,

trays, and other internal components, (3) repair or replace droplet

eliminator elements as needed, (4) repair or replace heat exchanger

elements used for temperature control of fluids entering or leaving the

scrubber, and (5) check damper settings for consistency with the air

flow level used to maintain compliance and adjust as required;

Initiate appropriate repair, replacement, or other

corrective action within one working day of detection; and

Maintain a daily record (i. e., checklist), signed by a

responsible plant official, showing the date of each inspection for

each requirement, the problem, a description of the repair,

replacement, or other action taken, and the date of repair or

replacement.

In addition to correcting defects detected during inspections, the

owner or operator would be required to ensure that the equipment is

being operated at an appropriate level of reliability, i.e. without the

need for continual or unusually frequent repairs or alterations that

require down time. Excursions of control device operating parameters

that occur with unacceptable frequency would indicate that some aspect

of the maintenance program or procedures is flawed. Occurrences more

frequent than an average of once per month over any reporting period

would be unacceptable, and the owner or operator would be required to

install a CEMS and comply with all requirements that apply to a CMS, in

order to provide assurance of compliance. A frequency of once per month

would correspond to operation out of compliance approximately five

percent of the operating time, assuming one day of such operation for

each occurrence and also assuming that the process will experience some

down time each month for routine maintenance.

2. Acid Regeneration Plants

Monitoring requirements for HCl for acid regeneration plants are

the same as those for pickling lines.

For Cl2 monitoring, process parameters were selected to

determine compliance with the Cl2 emission limit for acid

regeneration plants because process control is the means by which

Cl2 emissions are reduced. The cost of would be

insignificant because these parameters are currently monitored

routinely as part of normal operation.

For Cl2 control, the owner or operator would install (if

necessary), operate, and calibrate devices for the continuous

measurement and recording of roaster temperature, rate of addition of

iron in the spent liquor process feed, combustion gas feed rate, and

air or oxygen feed rate.

To ensure proper operation of the acid regeneration plant,

development and implementation of a written maintenance program is

required. Elements required to be included in the plan are:

Perform the manufacturer's recommended maintenance at the

recommended intervals on all required systems and components;

Initiate appropriate repair, replacement, or other

corrective action within one working day of detection; and

[[Page 49067]]

Maintain a daily record (i.e., checklist), signed by a

responsible plant official, showing the date of each inspection for

each requirement, the problem, a description of the repair,

replacement, or other action taken, and the date of repair or

replacement.

In addition to continuously monitoring process operating

parameters, the owner or operator would conduct annual performance

tests by Method 26A in appendix A to 40 CFR part 60.

G. Selection of Test Methods

The proposed NESHAP would require an initial performance test to

determine compliance. The initial test would consist of emission

testing of the exhaust gases from the scrubbers used to control HCl

emissions from pickling lines and acid regeneration plants.

Test Method 26A in appendix A to 40 CFR part 60 has been developed

and validated for the measurement of HCl and Cl2 emissions.

The following methods, also from 40 CFR part 60, appendix A, would be

used for sampling and analysis. EPA Method 1 would be used to determine

the number and location of sampling points. Method 2 would be used to

determine gas velocity and volumetric flow rate. Method 3 would be used

for gas analysis, and Method 4 would be used to determine the

volumetric moisture content of the gas. The EPA selected these methods

for use in the proposed rule because these methods and equivalent

procedures are those used by EPA and other parties to collect the data

upon which the proposed emission limits are based. Consistent with the

methods and standard practice, the initial compliance test would

consist of three runs by Method 26A conducted under conditions

representative of normal operation. Compliance would be determined

based on the average of the three runs. Simultaneous measurements and

sampling must be done at the APCD inlet and outlet if compliance with

the collection efficiency limitation is being demonstrated.

H. Selection of Notification, Recordkeeping, and Reporting Requirements

The proposed rule requires the owner or operator to comply with the

notification, recordkeeping, and reporting requirements in the general

provisions in subpart A of 40 CFR part 63.

Recordkeeping requirements for all MACT standards are established

in Sec. 63.10(b) of the general provisions in subpart A of 40 CFR part

63. In addition to these requirements, for wet scrubber operations the

proposed NESHAP would require the owner or operator to maintain a copy

of the scrubber maintenance program with records of inspections and

repairs, records of pH or acidity levels taken manually (if

applicable), and records of certification for accuracy of monitoring

devices (if applicable). For acid regeneration operations, the owner or

operator would maintain records of certification for accuracy of

monitoring devices. All requirements that apply to a CMS would apply if

a CEMS is used.

I. Solicitation of Comments

The EPA seeks full public participation in arriving at its final

decisions, and strongly encourages comments on all aspects of this

proposal from all interested parties. Full supporting data and detailed

analyses should be submitted with comments to allow the EPA to make

maximum use of the comments. All comments should be directed to the Air

and Radiation Docket and Information Center, Docket No. A-95-43 (see

ADDRESSES). Comments on this notice must be submitted on or before the

date specified in DATES.

Commenters wishing to submit proprietary information for

consideration should clearly distinguish such information from other

comments, and clearly label it ``Confidential Business Information''

(CBI). Submissions containing such proprietary information should be

sent directly to the following address, and not to the public docket,

to ensure that proprietary information is not inadvertently placed in

the docket: Attention: Jim Maysilles, c/o Ms. Melva Toomer, U.S. EPA

Confidential Business Information Manager, OAQPS (MD-13); Research

Triangle Park, NC 27711. Information covered by such a claim of

confidentiality will be disclosed by the EPA only to the extent allowed

and by the procedures set forth in 40 CFR part 2. If no claim of

confidentiality accompanies the submission when it is received by the

EPA, the submission may be made available to the public without further

notice to the commenter.

VIII. Administrative Requirements

A. Docket

The docket is an organized and complete file of all the information

considered by the EPA in the development of this rulemaking. The docket

is a dynamic file because material is added throughout the rulemaking

development. The docketing system is intended to allow members of the

public and industries involved to readily identify and locate documents

so that they can effectively participate in the rulemaking process.

Along with the proposed and promulgated standards and their preambles,

the contents of the docket will serve as the record in the case of

judicial review. (See section 307(d)(7)(A) of the Act.)

B. Public Hearing

If a request to speak at a public hearing is received, a public

hearing on the proposed standards will be held in accordance with

section 307(d)(5) of the Act. Persons wishing to present oral testimony

or to inquire as to whether a hearing is to be held should contact EPA

(see ADDRESSES). To provide an opportunity for all who may wish to

speak, oral presentations will be limited to 15 minutes each.

Any member of the public may file a written statement on or before

November 17, 1997. Written statements should be addressed to the Air

and Radiation Docket and Information Center (see ADDRESSES) and refer

to Docket No. A-95-43. A verbatim transcript of the hearing and written

statements will be placed in the docket and be available for public

inspection and copying, or mailed upon request, at the Air and

Radiation Docket and Information Center.

C. Executive Order 12866

Under Executive Order 12866 (58 FR 51735, October 4, 1993), the EPA

must determine whether the regulatory action is ``significant'' and

therefore subject to review by the Office of Management and Budget

(OMB) and the requirements of the Executive Order. The Executive Order

defines ``significant regulatory action'' as one that is likely to

result in a rule that may:

(1) Have an annual effect on the economy of $100 million or more or

adversely affect in a material way the economy, a sector of the

economy, productivity, competition, jobs, the environment, public

health or safety, or state, local, or tribal governments or

communities;

(2) Create a serious inconsistency or otherwise interfere with an

action taken or planned by another agency;

(3) Materially alter the budgetary impact of entitlements, grants,

user fees, or loan programs, or the rights and obligations of

recipients thereof; or

(4) Raise novel legal or policy issues arising out of legal

mandates, the President's priorities, or the principles set forth in

the Executive Order.

Pursuant to the terms of Executive Order 12866, it has been

determined that this rule is not a ``significant regulatory action''

because none of the

[[Page 49068]]

listed criteria apply to this action. Consequently, this action was not

submitted to OMB for review under Executive Order 12866.

D. Enhancing the Intergovernmental Partnership Under Executive Order

12875

In compliance with Executive Order 12875, we have involved State

regulatory experts in the development of this proposed rule. No tribal

governments are believed to be affected by this proposed rule. Although

not directly impacted by the rule, State governments will be required

to implement the rule by incorporating the rule into permits and

enforcing the rule upon delegation. They will collect permit fees that

will be used to offset the resources burden of implementing the rule.

Comments have been solicited from state partners and have been

carefully considered in the rule development process. In addition, all

states are encouraged to comment on this proposed rule during the

public comment period, and the EPA intends to fully consider these

comments in the development of the final rule.

E. Unfunded Mandates Act

Title II of the Unfunded Mandates Reform Act of 1995 (UMRA), Pub.

L. 104-4, establishes requirements for Federal agencies to assess the

effects of their regulatory actions on State, local, and tribal

governments and the private sector. Under section 202 of the UMRA, the

EPA generally must prepare a written statement, including a cost-

benefit analysis, for proposed and final rules with ``Federal

mandates'' that may result in expenditures by State, local, and tribal

governments, in aggregate, or by the private sector, of $100 million or

more in any one year. Before promulgating an EPA rule for which a

written statement is needed, section 205 of the UMRA generally requires

the EPA to identify and consider a reasonable number of regulatory

alternatives and adopt the least costly, most cost-effective, or least

burdensome alternative that achieves the objectives of the rule. The

provisions of section 205 do not apply when they are inconsistent with

applicable law. Moreover, section 205 allows the EPA to adopt an

alternative other than the least costly, most cost-effective, or least

burdensome alternative if the Administrator publishes with the final

rule an explanation why that alternative was not adopted. Before the

EPA establishes any regulatory requirements that may significantly or

uniquely affect small governments, including tribal governments, it

must have developed under section 203 of the UMRA a small government

agency plan. The plan must provide for notifying potentially affected

small governments, enabling officials of affected small governments to

have meaningful and timely input in the development of EPA regulatory

proposals with significant Federal intergovernmental mandates, and

informing, educating, and advising small governments on compliance with

the regulatory requirements.

The EPA has determined that this rule does not contain a Federal

mandate that may result in expenditures of $100 million or more for

State, local, and tribal governments, in the aggregate, or the private

sector in any one year. Thus, today's rule is not subject to the

requirements of sections 202 and 205 of the UMRA. In addition, the EPA

has determined that this rule contains no regulatory requirements that

might significantly or uniquely affect small governments because it

contains no requirements that apply to such governments or impose

obligations upon them. Therefore, today's rule is not subject to the

requirements of section 203 of the UMRA.

F. Regulatory Flexibility Act

The Regulatory Flexibility Act (RFA) generally requires an agency

to conduct a regulatory flexibility analysis of any rule subject to

notice and comment rulemaking requirements unless the agency certifies

that the rule will not have a significant economic impact on a

substantial number of small entities. Small entities include small

businesses, small not-for-profit enterprises, and small government

jurisdictions.

Only four companies in the steel pickling industry are considered

small entities. Of these four, one company is expected to meet the

standard. Two companies are projected to be nonmajor sources based on

calculations using an emissions estimating model along with information

supplied by these firms. It is not anticipated that these three firms

will be adversely impacted by the regulation. The remaining small firm

employs a scrubber that may meet the emission limitation. If this firm

incurs emission control costs, the costs would likely relate to

upgrading existing equipment or improved maintenance practices. Any

regulatory impacts for this firm are not expected to be significant.

Based on this information, the EPA has concluded that this proposed

rule would not have a significant economic impact on a substantial

number of small entities. Therefore, I certify that this action will

not have a significant economic impact on a substantial number of small

entities.

G. Paperwork Reduction Act

The information collection requirements in this proposed rule have

been submitted for approval to the OMB under the requirements of the

Paperwork Reduction Act, 44 U.S.C. 3501 et seq. An information

collection request (ICR) document has been prepared by EPA (ICR

No.1821.01), and a copy may be obtained from Sandy Farmer, OPPE

Regulatory Information Division, U.S. Environmental Protection Agency

(2137), 401 M Street SW., Washington, DC 20460, or by calling (202)

260-2740.

The proposed information requirements are based on notification,

recordkeeping, and reporting requirements in the NESHAP general

provisions (40 CFR part 63, subpart A), which are mandatory for all

owners or operators subject to national emission standards. These

recordkeeping and reporting requirements are specifically authorized by

section 114 of the Act (42 U.S.C. 7414). All information submitted to

the EPA for which a claim of confidentiality is made is safeguarded

according to Agency policies in 40 CFR part 2, subpart B.

The proposed rule would require maintenance inspections of the

control devices but would not require any notifications or reports

beyond those required by the general provisions. The proposed

recordkeeping requirements require only the specific information needed

to determine compliance.

The annual monitoring, reporting, and recordkeeping burden for this

collection, per respondent (averaged over the first 3 years after the

effective date of the rule) is estimated to be 410 labor hours per year

at a total annual cost of $14,800.

This estimate includes a one-time performance test and report (with

repeat tests where needed); one-time submission of a startup, shutdown,

and malfunction plan with semiannual reports for any event when the

procedures in the plan were not followed; semiannual excess emission

reports; maintenance inspections; notifications; and recordkeeping.

There are no capital/startup costs associated with these reporting and

recordkeeping requirements. Operational and maintenance (O and M) cost

burden is estimated at $13,800/yr. per respondent. These O and M costs

are for performance testing, which is anticipated to be conducted by

outside contractors.

Burden means the total time, effort, or financial resources

expended by persons

[[Page 49069]]

to generate, maintain, retain, or disclose, or provide information to

or for a Federal agency. This includes the time needed to review

instructions; develop, acquire, install, and utilize technology and

systems for the purpose of collecting, validating, and verifying

information; processing and maintaining information, and disclosing and

providing information; adjust the existing ways to comply with any

previously applicable instructions and requirements; train personnel to

respond to a collection of information; search existing data sources;

complete and review the collection of information; and transmit or

otherwise disclose the information.

An Agency may not conduct or sponsor, and a person is not required

to respond to, a collection of information unless it displays a

currently valid OMB control number. The OMB control numbers for EPA's

regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.

Comments are requested on the EPA's need for this information, the

accuracy of the provided burden estimates, any suggested methods for

minimizing respondent burden, including through the use of automated

collection techniques. Send comments on the ICR to the Director, OPPE

Regulatory Information Division; U.S. Environmental Protection Agency

(2137), 401 M Street SW., Washington, DC 20460; and to the Office of

Information and Regulatory Affairs, Office of Management and Budget,

725 17th Street NW., Washington, DC 20503, marked ``Attention: Desk

Office for EPA.'' Include the ICR number in any correspondence. Because

OMB is required to make a decision concerning the ICR between 30 and 60

days after September 18, 1997, comment to OMB is best assured of having

its full effect if OMB receives it by October 20, 1997. The final rule

will respond to any OMB or public comments on the information

collection requirements contained in this proposal.

H. Clean Air Act

In accordance with section 117 of the Act, publication of this

proposal was preceded by consultation with appropriate advisory

committees, independent experts, and Federal departments and agencies.

This regulation will be reviewed 8 years from the date of promulgation.

This review will include an assessment of such factors as evaluation of

the residual health risks, any overlap with other programs, the

existence of alternative methods, enforceability, improvements in

emission control technology and health data, and the recordkeeping and

reporting requirements.

List of Subjects in 40 CFR Part 63

Environmental protection, Air Pollution Control, Hazardous

substances, Reporting and recordkeeping requirements, Steel pickling.

Dated: August 28, 1997.

Carol M. Browner,

Administrator.

For the reasons set out in the preamble, part 63 of title 40,

chapter I, of the Code of Federal Regulations is proposed to be amended

as follows:

PART 63--NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS

FOR SOURCE CATEGORIES

1. The authority citation for part 63 continues to read as follows:

Authority: 42 U.S.C. 7401 et seq.

2. Part 63 is amended by adding subpart CCC to read as follows:

Subpart CCC--National Emission Standards for Hazardous Air Pollutants

From Steel Pickling Facilities--HCl Process

Sec.

63.1155 Applicability.

63.1156 Definitions.

63.1157 Emission standards for existing sources.

63.1158 Emission standards for new or reconstructed sources.

63.1159 Compliance dates and maintenance requirements.

63.1160 Performance testing and test methods.

63.1161 Monitoring requirements.

63.1162 Notification requirements.

63.1163 Reporting requirements.

63.1164 Recordkeeping requirements.

63.1165 Delegation of authority.

63.1166-63.1174 [Reserved]

Appendix A to Subpart CCC of Part 63--Applicability of General

Provisions (40 CFR part 63, subpart A) to subpart CCC

Subpart CCC--National Emission Standards for Hazardous Air

Pollutants From Steel Pickling Facilities--HCl Process

Sec. 63.1155 Applicability.

(a) The provisions of this subpart apply to all new and existing

steel pickling facilities that pickle steel using an acid solution in

which 50 percent or more by weight of the acid in solution is

hydrochloric acid (HCl) and/or regenerate spent HCl from steel pickling

operations that are major sources or are parts of facilities that are

major sources. The provisions of this subpart do not apply to

facilities that pickle using other acids or mixtures of acids in which

the acid in solution is less than 50 percent HCl by weight or to

facilities that regenerate other acids.

(b) For the purposes of implementing this subpart, the affected

sources at a steel pickling facility subject to this subpart are as

follows: batch and continuous pickling lines, acid regeneration plants,

and virgin or regenerated acid storage tanks.

(c) Appendix A to this subpart specifies the provisions of subpart

A that apply and those that do not apply to owners and operators of HCl

steel pickling facilities and acid regeneration plants. The following

sections of part 63 apply to this subpart as stated in subpart A and

appendix A to this subpart: Sec. 63.1 (Applicability), Sec. 63.2

(Definitions), Sec. 63.3 (Units and abbreviations), Sec. 63.4

(Prohibited activities and circumvention), Sec. 63.5 (Construction and

reconstruction), Sec. 63.7 (Performance testing requirements),

Sec. 63.12 (State authority and delegations), Sec. 63.13 (Addresses of

State air pollution control agencies and EPA Regional Offices),

Sec. 63.14 (Incorporations by reference), and Sec. 63.15 (Availability

of information and confidentiality). The following sections of part 63

apply to the extent specified in this subpart and appendix A to this

subpart: Sec. 63.6 (Compliance with standards and maintenance

requirements), Sec. 63.8 (Monitoring requirements), Sec. 63.9

(Notification requirements), and Sec. 63.10 (Recordkeeping and

reporting requirements). Section 63.11 (Control device requirements)

does not apply to this subpart.

Sec. 63.1156 Definitions.

Terms used in this subpart are defined in the Clean Air Act, in

subpart A of this part, or in this section as follows:

Acid regeneration plant means the collection of equipment and

processes configured to reconstitute fresh hydrochloric acid pickling

solution from spent pickle liquor using a thermal treatment process.

Acid storage tank means a vessel used for the bulk containment of

virgin or regenerated hydrochloric acid.

Batch pickling line means the collection of equipment and vessels

configured for pickling metal in any form but usually in discrete

shapes where the material is lowered in batches into a bath of

hydrochloric acid solution, allowed to remain until the scale is

dissolved, then removed from the solution, drained, and rinsed by

spraying or immersion in one or more rinse tanks to remove residual

acid.

Closed-vent system means a system that is not open to the

atmosphere and that is composed of piping, ductwork,

[[Page 49070]]

connections, and flow-inducing devices that transport emissions from a

process unit or piece of equipment (e. g., pumps, pressure relief

devices, sampling connections, open-ended valves or lines, connectors,

and instrumentation systems) to a control device or back into a closed

system.

Continuous pickling line means the collection of equipment and

vessels configured for pickling metal strip, rod, wire, tube, or pipe

that is passed through an acid solution in a continuous or nearly

continuous manner and rinsed in another vessel or series of vessels to

remove residual acid. This definition includes continuous spray towers.

Spray tower means an enclosed vertical tower in which hydrochloric

acid pickling solution is sprayed onto moving steel strip in multiple

vertical passes.

Steel pickling means the chemical removal of iron oxides and scale

that is formed on steel surfaces during hot rolling or forming of semi-

finished steel products through contact with an aqueous solution of

hydrochloric acid. This definition does not include operations for the

removal of light rust or for activation of the metal surface prior to

plating.

Steel pickling facility means any facility that operates one or

more batch or continuous steel pickling lines or one or more acid

regeneration plants.

Sec. 63.1157 Emission standards for existing sources.

(a) Pickling lines. (1) No owner or operator of an existing

affected pickling line at a steel pickling facility shall cause or

allow to be discharged into the atmosphere from the affected pickling

line a hydrochloric acid (HCl) emission rate corresponding to a

collection efficiency of less than 97.5 percent.

(2) As an alternative to the requirement of paragraph (a)(1) of

this section, no owner or operator of an existing affected pickling

line at a steel pickling facility shall cause or allow to be discharged

into the atmosphere from the affected pickling line any gases that

contain HCl in excess of 10 parts per million by volume (ppmv).

(b) Acid regeneration plant. (1) No owner or operator of an

existing affected acid regeneration plant shall cause or allow to be

discharged into the atmosphere from the affected acid regeneration

plant any gases that contain HCl in excess of 8 ppmv.

(2) In addition to the requirement of paragraph (b)(1) of this

section, no owner or operator shall cause or allow to be discharged

into the atmosphere from the affected acid regeneration plant any gases

that contain chlorine (Cl2) in excess of either 4 ppmv or an

optional maximum concentration limitation to be established for each

source. The maximum concentration limitation shall be established

according to Sec. 63.1160(c)(2) of this subpart.

(c) Acid storage tank. The owner or operator of an existing

affected acid storage tank shall provide and operate, except during

loading and unloading of acid, a closed-vent system for each tank.

Loading and unloading shall be conducted either through enclosed lines

or each point where the acid is exposed to the atmosphere shall be

equipped with a local fume capture system, ventilated through an air

pollution control device.

Sec. 63.1158 Emission standards for new or reconstructed sources.

(a) Pickling line. (1) No owner or operator of a new or

reconstructed affected pickling line at a steel pickling facility shall

cause or allow to be discharged into the atmosphere from the affected

pickling line an HCl emission rate corresponding to a collection

efficiency of less than 99 percent.

(2) As an alternative to the requirement of paragraph (a)(1) of

this section, no owner or operator of a new or reconstructed affected

pickling line at a steel pickling facility shall cause or allow to be

discharged into the atmosphere from the affected pickling line any

gases that contain HCl in excess of 3 ppmv.

(b) Acid regeneration plant. (1) No owner or operator of a new or

reconstructed affected acid regeneration plant shall cause or allow to

be discharged into the atmosphere from the affected acid regeneration

plant any gases that contain HCl in excess of 3 ppmv.

(2) In addition to the requirement of paragraph (b)(1) of this

section, no owner or operator shall cause or allow to be discharged

into the atmosphere from the affected acid regeneration plant any gases

that contain Cl2 in excess of either 4 ppmv or an optional

maximum concentration limitation to be established for each source. The

maximum concentration limitation shall be established according to

Sec. 63.1160(c)(2) of this subpart. Also, the owner or operator shall

explain in writing to the Administrator's satisfaction why the process

could not be designed to operate under conditions that would allow it

to meet the 4 ppmv Cl2 limitation. The explanation shall be

submitted to the Administrator within 30 days after completion of the

emission test made according to Sec. 63.1160(c) of this subpart.

(c) Acid storage tank. The owner or operator of a new or

reconstructed affected acid storage tank shall provide and operate,

except during loading and unloading of acid, a closed-vent system for

each tank. Loading and unloading shall be conducted either through

enclosed lines or each point where the acid is exposed to the

atmosphere shall be equipped with a local fume capture system,

ventilated through an air pollution control device.

Sec. 63.1159 Compliance dates and maintenance requirements.

(a) Compliance dates. (1) The owner or operator of an affected

existing steel pickling facility and/or acid regeneration plant subject

to this subpart shall achieve initial compliance with the requirements

of this subpart no later than ____________ [Insert date 2 years from

publication of final rule in the Federal Register].

(2) The owner or operator of a new or reconstructed steel pickling

facility and/or acid regeneration plant subject to this subpart that

commences construction or reconstruction after September 18, 1997 shall

achieve compliance with the requirements of this subpart immediately

upon startup of operations or by ____________ [Insert date of

publication of final rule in the Federal Register], whichever is later.

(b) Operation and maintenance requirements. (1) The owner or

operator of an affected source shall comply with the requirements of

Sec. 63.6(e) of subpart A of this part.

(2) In addition to the requirements specified in paragraph (b)(1)

of this section, the owner or operator shall develop and implement a

written maintenance plan for each emission control device. The owner or

operator shall submit the plan no later than the date of compliance to

the applicable permitting authority. For a scrubber emission control

device, the written program must include the minimum elements contained

in the operating manual provided by the manufacturer and:

(i) Require the manufacturer's recommended maintenance at the

recommended intervals on fresh solvent pumps, recirculating pumps,

discharge pumps, and other liquid pumps, in addition to exhaust system

and scrubber fans and motors associated with those pumps and fans;

(ii) Require cleaning of the scrubber internals and mist

eliminators at intervals sufficient to prevent buildup of solids or

other fouling;

(iii) Require an inspection of each scrubber at intervals of no

less than 3 months with:

[[Page 49071]]

(A) Cleaning or replacement of any plugged spray nozzles or other

liquid delivery devices;

(B) Repair or replacement of missing, misaligned, or damaged

baffles, trays, or other internal components;

(C) Repair or replacement of droplet eliminator elements as needed;

(D) Repair or replacement of heat exchanger elements used to

control the temperature of fluids entering or leaving the scrubber; and

(E) Adjustment of damper settings for consistency with the required

air flow.

(iv) If the scrubber is not equipped with a viewport or access

hatch allowing visual inspection, alternate means of inspection

approved by the Administrator may be used.

(v) The owner or operator shall initiate corrective action within

one working day of detection of an operating problem and provide

appropriate repair, replacement, or other corrective action. Failure to

initiate or provide appropriate repair, replacement, or other

corrective action is a violation of the maintenance requirement.

(vi) The owner or operator shall maintain a record of each

inspection, including each item identified in paragraph (b)(2)(iii) of

this section, that is signed by the responsible plant official and that

shows the date of each inspection, the problem identified, a

description of the repair, replacement, or other corrective action

taken, and the date of the repair, replacement, or other corrective

action taken.

(3) In addition to the requirements specified in paragraphs (b)(1)

and (b)(2) of this section, the owner or operator of each acid

regeneration plant shall develop and implement a written maintenance

program. The program shall require:

(i) Performance of the manufacturer's recommended maintenance at

the recommended intervals on all required systems and components;

(ii) Initiation of appropriate repair, replacement, or other

corrective action within one working day of detection; and

(iii) Maintenance of a daily record, signed by a responsible plant

official, showing the date of each inspection for each requirement, the

problems found, a description of the repair, replacement, or other

action taken, and the date of repair or replacement.

Sec. 63.1160 Performance testing and test methods.

(a) The owner or operator shall conduct an initial performance test

for each process or emission control device to determine and

demonstrate compliance with the applicable emission limit or

performance standard according to the requirements in Sec. 63.7 of this

part and in this section.

(1) Following approval of the site-specific test plan, the owner or

operator shall conduct an emission test for each process or control

device to measure either the mass flows of HCl at the inlet and the

outlet of the control device (to determine compliance with the

applicable collection efficiency standard) or the concentration of HCl

(and Cl2 for acid regeneration plants) in gases exiting the

process or the emission control device (to determine compliance with

the applicable emission concentration standard).

(2) Compliance with the applicable emission concentration or

collection efficiency standard shall be determined by the average of

three runs. Each run shall be conducted under conditions representative

of normal process operations.

(3) Compliance is achieved if either the average collection

efficiency as determined by the HCl mass flows at the control device

inlet and outlet is greater than or equal to the applicable collection

efficiency requirement or the average measured concentration of HCl or

Cl2 exiting the process or the emission control device is

less than or equal to the applicable emission concentration

requirement.

(b) During the emission test for each emission control device, the

owner or operator using a wet scrubber to achieve compliance and

electing to monitor emission control device operating parameters as

described in Sec. 63.1161(a)(2) of this subpart shall establish as

site-specific operating parameters the pressure drop across the

scrubber and the maximum acidity of the scrubber effluent.

(1) The owner or operator shall determine the operating parameter

monitoring values as the average of the values recorded during each of

the three runs constituting the test. An owner or operator may conduct

multiple performance tests to establish a range of compliant operating

parameter values.

(2) As an alternative to the requirement specified in paragraph

(a)(1) of this section, the owner or operator may set as the compliant

value for pressure drop the average value measured over the three test

runs of one compliance test and accept 1 inch of water

column from the pressure drop value as the compliant range.

(c)(1) During the emission test for Cl2 at an acid

regeneration plant, the owner or operator shall establish as site-

specific operating parameters the minimum process offgas temperature

and the maximum proportion of excess air fed to the process as

described in Sec. 63.1161(d)(2) of this subpart. The owner or operator

shall determine the operating parameter monitoring values as the

average of the values recorded during each of the three runs

constituting the test. An owner or operator may conduct multiple

performance tests to establish a range of compliant operating parameter

values.

(2) During this emission test, the owner or operator may establish

an optional maximum concentration limitation for Cl2. If the

owner or operator can demonstrate to the Administrator's satisfaction

that the plant cannot meet the 4 ppmv maximum concentration limitation

by operating the plant within its design parameters, the plant shall be

operated at maximum design temperature and with the minimum excess air

that allows production of iron oxide of acceptable quality while

measuring Cl2 concentration in the process exhaust gas. The

measured concentration shall be the maximum concentration allowed for

that plant.

(d) The following test methods in appendix A to part 60 of this

chapter shall be used to determine compliance under Secs. 63.1157(a),

63.1157(b), 63.1158(a), and 63.1158(b) of this subpart:

(1) Method 1, to determine the number and location of sampling

points;

(2) Method 2, to determine gas velocity and volumetric flow rate;

(3) Method 3, to determine the molecular weight of the stack gas;

(4) Method 4, to determine the moisture content of the stack gas;

and

(5) Method 26A, ``Determination of Hydrogen Halide and Halogen

Emissions from Stationary Sources--Isokinetic Method'', to determine

the HCl mass flows at the inlet and outlet of a control device or the

concentration of HCl discharged to the atmosphere and also to determine

the concentration of Cl2 discharged to the atmosphere from

acid regeneration plants. If compliance with a collection efficiency

standard is being demonstrated, inlet and outlet measurements shall be

performed simultaneously. The minimum sampling time for each run shall

be 60 minutes and the minimum sample volume 0.85 dry standard cubic

meters (dscm) [30 dry standard cubic feet (dscf)]. The concentration of

HCl and Cl2 shall be calculated as follows:

CHCl (ppmv)=0.659 CHCl (mg/dscm),

CCl2 (ppmv)=0.339 CCl2 (mg/dscm),

where:

C (ppmv) is concentration in ppmv and C(mg/dscm) is concentration

in milligrams per dry standard cubic meter

[[Page 49072]]

as calculated by the procedure given in Method 26A in appendix A to

part 60 of this chapter.

(e) The owner or operator may use equivalent alternative

measurement methods approved by the Administrator.

Sec. 63.1161 Monitoring requirements.

(a) The owner or operator of a new, reconstructed, or existing

steel pickling facility or acid regeneration plant subject to this

subpart shall:

(1) Conduct annual performance tests to measure the HCl mass flows

at the control device inlet and outlet or the concentration of HCl

exiting the control device according to the procedures described in

Sec. 63.1160 of this subpart. If an annual performance test shows that

the HCl emission limit is being exceeded, then the owner or operator is

in violation of the HCl emission limit.

(2) In addition to conducting annual performance tests, if a wet

scrubber is used as the emission control device, install, operate, and

maintain systems for the measurement and recording of the:

(i) Pressure drop across the scrubber, which shall be measured and

recorded at least once every 24-hour period, and

(ii) Acidity of the scrubber effluent, which shall be measured and

recorded at least once every 8-hour period.

(3) If an emission control device other than a wet scrubber is

used, install, operate, and maintain systems for the appropriate

measurement and recording of the operating parameters.

(4) Each monitoring device shall be certified by the manufacturer

to be accurate to within 5-percent and shall be calibrated semiannually

in accordance with the manufacturer's instructions.

(5)(i) Operation of the control device with excursions of operating

parameters listed in paragraph (a)(2) of this section outside the

ranges established during the initial performance test will require

initiation of corrective action as specified by the maintenance

requirement in Sec. 63.1159(b)(2) of this subpart. Failure to initiate

the required action is a violation of the maintenance requirements.

(6) Failure to record each of the operating parameters listed in

paragraph (a)(2) of this section is a violation of the monitoring

requirements.

(b) As an option to the requirements of paragraphs (a)(1) through

(a)(6) of this section, the owner or operator of a new, reconstructed,

or existing steel pickling facility or acid regeneration plant subject

to this subpart may do the following:

(1) Install, calibrate, certify, operate, and maintain according to

the manufacturer's specifications a continuous emission monitoring

system (CEMS) capable of measuring HCl concentrations in the ranges

required to demonstrate compliance with this standard. Any owner or

operator employing a CEMS shall be subject to all the requirements

applicable to a continuous monitoring system (CMS) specified in

Sec. 63.8 of subpart A of this part and in this section.

(i) If the compliance option chosen is collection efficiency

(Secs. 63.1157(a)(1) or 63.1158(a)(1) of this subpart, whichever

applies), then the air pollution control device inlet and outlet gases

shall both be monitored. The owner or operator may employ a single

analyzer to monitor both streams, with each stream being monitored 50-

percent of the time during each 24-hour period.

(ii) If the compliance option chosen is concentration

(Secs. 63.1157(a)(2), 63.1157(b)(1), 63.1158(a)(2), or 63.1158(b)(1) of

this subpart, whichever applies), then the air pollution control device

or process offgas shall be monitored continuously.

(c) If excursions of the control device operating parameters listed

in paragraph (a)(2) of this section outside the ranges established

during the initial performance test occur more often than six times

during any 6-month reporting period, the owner or operator shall

install a CEMS and comply with the requirements specified in paragraph

(b)(1) of this section.

(d) The owner or operator of a new or existing acid regeneration

facility subject to this subpart shall also:

(1) Conduct annual performance tests to measure the concentration

of Cl2 exiting the process or the control device according

to the procedures described in Sec. 63.1160 of this subpart. If an

annual performance test shows that the Cl2 emission limit is

being exceeded, then the owner or operator is in violation of the

Cl2 emission limit.

(2) In addition to conducting annual performance tests, install,

operate, and maintain systems for the measurement and recording of the:

(i) Process offgas temperature, which shall be monitored and

recorded continuously, and

(ii) Excess air feed rate, which shall be measured and recorded at

least once every 8-hour period. Proportion of excess air shall be

determined by a combination of total air flow rate, fuel flow rate,

spent pickle liquor addition rate, and amount of iron in the spent

pickle liquor or by any other combination of parameters approved by the

Administrator.

(3) Each monitoring device must be certified by the manufacturer to

be accurate to within 5-percent and must be calibrated semiannually in

accordance with the manufacturer's instructions.

(4) Operation of the process with operating parameters listed in

paragraph (a)(2) of this section in exceedance of the ranges

established during the initial performance test is a violation of the

emission limit specified in Secs. 63.1157(b)(2) or 63.1158(b)(2) of

this subpart, whichever applies. Failure to record each of these

parameters is a violation of the monitoring requirements.

(e) The owner or operator of an affected acid storage tank shall

inspect each tank monthly to determine that the closed-vent system and

either the air pollution control device or the enclosed loading and

unloading line, whichever is applicable, are installed and operating

when required.

Sec. 63.1162 Notification requirements.

(a) Initial notifications. As required by Sec. 63.9(b) of subpart A

of this part, the owner or operator shall submit the following written

notifications to the Administrator:

(1) The owner or operator of an area source that subsequently

becomes subject to the requirements of the standard shall provide

notification to the applicable permitting authority as required by

Sec. 63.9(b)(1) of subpart A of this part.

(2) As required by Sec. 63.9(b)(2) of subpart A of this part, the

owner or operator of an affected source that has an initial startup

before the effective date of the standard shall notify the

Administrator that the source is subject to the requirements of the

standard. The notification shall be submitted not later than 120

calendar days after the effective date of this standard (or within 120

calendar days after the source becomes subject to this standard) and

shall contain the information specified in Secs. 63.9(b)(2)(i) through

63.9(b)(2)(v) of subpart A of this part.

(3) As required by Sec. 63.9(b)(3) of subpart A of this part, the

owner or operator of a new or reconstructed affected source, or a

source that has been reconstructed such that it is an affected source,

that has an initial startup after the effective date and for which an

application for approval of construction or reconstruction is not

required under Sec. 63.5(d) of subpart A of this part, shall notify the

Administrator in writing that the source is subject to the standards no

later than 120 days after initial startup. The notification shall

contain the information specified

[[Page 49073]]

in Secs. 63.9(b)(2)(i) through 63.9(b)(2)(v) of subpart A of this part,

delivered or postmarked with the notification required in

Sec. 63.9(b)(5) of subpart A of this part.

(4) As required by Sec. 63.9(b)(4) of subpart A of this part, the

owner or operator of a new or reconstructed major affected source that

has an initial startup after the effective date of this standard and

for which an application for approval of construction or reconstruction

is required under Sec. 63.5(d) of subpart A of this part shall provide

the information specified in Secs. 63.9(b)(4)(i) through 63.9(b)(4)(v)

of subpart A of this part.

(5) As required by Sec. 63.9(b)(5) of subpart A of this part, the

owner or operator who, after the effective date of this standard,

intends to construct a new affected source or reconstruct an affected

source subject to this standard, or reconstruct a source such that it

becomes an affected source subject to this standard, shall notify the

Administrator, in writing, of the intended construction or

reconstruction.

(b) Request for extension of compliance. As required by

Sec. 63.9(c) of subpart A of this part, if the owner or operator of an

affected source cannot comply with this standard by the applicable

compliance date for that source, or if the owner or operator has

installed BACT or technology to meet LAER consistent with

Sec. 63.6(i)(5) of subpart A of this part, he/she may submit to the

Administrator (or the State with an approved permit program) a request

for an extension of compliance as specified in Secs. 63.6(i)(4) through

63.6(i)(6) of subpart A of this part.

(c) Notification that source is subject to special compliance

requirements. As required by Sec. 63.9(d) of subpart A of this part, an

owner or operator of a new source that is subject to special compliance

requirements as specified in Secs. 63.6(b)(3) and 63.6(b)(4) of subpart

A of this part shall notify the Administrator of his/her compliance

obligations not later than the notification dates established in

Sec. 63.9(b) of subpart A of this part for new sources that are not

subject to the special provisions.

(d) Notification of performance test. As required by Sec. 63.9(e)

of subpart A of this part, the owner or operator of an affected source

shall notify the Administrator in writing of his or her intention to

conduct a performance test at least 60 calendar days before the

performance test is scheduled to begin to allow the Administrator to

review and approve the site-specific test plan required under

Sec. 63.7(c) of subpart A of this part, if requested by the

Administrator, and to have an observer present during the test.

(e) Additional notification requirements for sources with

continuous emission monitoring systems. The owner or operator of an

affected source using a CEMS shall furnish the Administrator written

notification that applies to a CMS as specified in Secs. 63.9(g)(1)

through 63.9(g)(3) of subpart A of this part.

(f) Notification of compliance status. The owner or operator of an

affected source shall submit a notification of compliance status as

required by Sec. 63.9(h) of subpart A of this part when the source

becomes subject to this standard.

Sec. 63.1163 Reporting requirements.

(a) Reporting results of performance tests. As required by

Sec. 63.10(d)(2) of this part, the owner or operator of an affected

source shall report the results of the initial performance test as part

of the notification of compliance status required in Sec. 63.1162 of

this subpart.

(b) Progress reports. The owner or operator of an affected source

who is required to submit progress reports under Sec. 63.6(i) of

subpart A shall submit such reports to the Administrator (or the State

with an approved permit program) by the dates specified in the written

extension of compliance.

(c) Periodic startup, shutdown, and malfunction reports. Section

63.6(e) of subpart A of this part requires the owner or operator of an

affected source to operate and maintain each affected emission source

and associated air pollution control equipment in a manner consistent

with good air pollution control practices for minimizing emissions (at

least to the level required by the standard) at all times, including

during any period of startup, shutdown, or malfunction. Malfunctions

must be corrected as soon as practicable after their occurrence in

accordance with the startup, shutdown, and malfunction plan.

(1) Plan. As required by Sec. 63.6(e)(3) of subpart A of this part,

the owner or operator shall develop and implement a written startup,

shutdown, and malfunction plan that provides a detailed description of

the procedures for operating the emission source or control system

during a period of startup, shutdown, or malfunction and a program of

corrective action for malfunctioning process and air pollution control

equipment. If applicable, Sec. 63.8(c)(1)(i) of subpart A also requires

that the plan shall identify all routine or otherwise predictable

malfunctions for a CEMS used to comply with the standard.

(2) Reports. As required by Sec. 63.10(d)(5)(i) of subpart A of

this part, if actions taken by an owner or operator during a startup,

shutdown, or malfunction of an affected source (including actions taken

to correct a malfunction) are consistent with the procedures specified

in the startup, shutdown, a

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