The final rule is expected to be published in the Federal Register in early to mid-2003. Companies with existing tunnel kilns that are subject to the rule will have three years from the time the final rule is published in the Federal Register to comply, so it’s possible that compliance might not be required until 2006. However, any company that constructed a new tunnel kiln or revamped its existing kilns after July 22, 2002, will need to comply with the final rule as soon as it is published. Additionally, any company that is planning a plant expansion or a kiln revamp in 2003 will need to be in compliance upon initial startup of their kiln(s).
The “MACT hammer” might further complicate the situation. This issue arose when the EPA missed the November 18, 2000, deadline mandated by the Clean Air Act to issue nationwide MACT standards for hazardous air pollutants (HAPs). Without the new provisions of the MACT final rule, state and local governments were to begin setting their own emissions standards on a case-by-case basis 18 months after the deadline (May 15, 2002). Under the MACT hammer provision, facilities would also be required to submit detailed permit applications to states so that state-permitting agencies could determine MACT standards for each individual facility. Although this requirement has not yet been triggered on a national level, some states have already begun the permit application process, and companies in these states could be forced to comply with strict emission standards as early as 2004.
The Brick Industry Association (BIA) Task Force and other industry groups are continuing to lobby for changes to the final rule, and many brick manufacturers have decided to take a “wait and see” approach. However, while it may be wise to hold off on purchasing the actual control technology, companies can begin taking a number of steps now to ensure that they will be prepared to meet the new regulations.
Despite the EPA’s apparent endorsement of some of these systems in the proposed rule, not all APCDs have been proven to remove the required level of pollutants. Additionally, what works for one plant might not be the right solution for another facility. According to Lars Hansen, sales manager for Procedair Industries, Englewood, Colo., one of the most important things companies can begin doing right now is educating themselves about the MACT rule and the various options for compliance.
“Companies should contact different scrubber vendors and have them visit their plants and give presentations so they can educate themselves. Most suppliers will be happy to come and help them in that process,” Hansen said.
Independent consultants can also help companies ensure that they select the right type of control device. “When companies are evaluating different technologies, it can be difficult to maintain an objective viewpoint. An independent reviewer can help guide the equipment selection process and ensure that the proper level of control is selected,” said Andy Turnbull, president of Lucas Process Systems in Charlotte, N.C.
“Companies that can’t tolerate a liquid discharge but still want to use a wet scrubber have some options,” Mueller said. “For example, in one CECO system that is being installed right now, a specialty filter dewaters scrubber sludge so that the liquid waste is cleaned of practically all solids. The remainder is a dry waste, which can go to a landfill. For companies that can’t tolerate any liquid waste, a spray dryer can also be used.”
Operating flexibility is another issue to consider. “Companies need to look at the operating range of any scrubber they’re considering, and also look at the operating range at which they run their tunnel kiln,” recommends Don Denison, president of Denison Engineering and a representative for ENCERTEC, Inc. “When times are hard, it’s common for tunnel kilns to run at half, or even a third of their speed, so companies need to have a scrubber that can handle the slower speeds, as well as high speeds for times when plants are running at full capacity. Not all scrubbers can meet that level of flexibility.”
The amount of support a company needs from its vendor might also be a factor in the decision-making process. Some suppliers offer complete turnkey installations, including everything from the initial system design, to handling all of the necessary components and access platforms, to employee training and startup of the final system. While this option can be more expensive, it provides a “one-stop solution” for companies with few in-house resources. Companies that have their own environmental and engineering teams on staff or that want to become more involved in the process might prefer to purchase a simpler system and handle some of the work themselves.
According to Fred Mueller from CECO Filters, the initial cost of an APCD is going to be governed by 1) the amount of HAPs in the stack emissions; 2) whether any discharge treatment from the scrubber system is required (e.g., filters and spray dryers for wet systems); and 3) the kiln capacity. “In general, the higher the emissions and the larger the kiln, the higher the cost of the scrubber system,” Mueller said.
However, cost isn’t always proportional to capacity. With many scrubbers, there are some economies of scale. “The cost starts slowing down with the larger kiln sizes (above 50 to 70 million standard brick equivalent [SBE] per year) because there are a lot of components—instrumentation, piping, auxiliary, controls, etc.—that are pretty much fixed, regardless of size. The building that houses the scrubber is also generally fixed, and as the size of the scrubber goes up, that structure wouldn’t change too much. So the cost increase [for companies operating at capacities above 70 million SBE] would be insignificant,” Mueller said.
“Companies don’t want to spend a lot of money for something that doesn’t improve production or help their bottom line, so it can be appealing to buy the lowest-cost technology they can find. But in many cases, they will end up spending more money in the long run by buying something cheaper, either because they’ll have to do it over or they’ll have to constantly deal with problems,” Hansen said.
Plants should consider factors such as power consumption, the cost of fresh reagent (or water) and the cost to dispose of the waste reagent (or wastewater). Many suppliers will compile detailed operating cost data upon request. There can also be a number of “hidden costs” that should be taken into account. For example, the types of controls will vary from system to system, with the more sophisticated controls likely carrying a higher price tag. With higher-priced turnkey installations, employee training, initial startup and troubleshooting are generally part of the package.
“When plants compare proposals, it is important that they look at all of these details to find out where the differences really are,” Hansen said.
“I don’t want to simply provide someone with an erector set because if something goes wrong, it can be difficult to pinpoint and resolve the problem. If the system is provided as an entire package, only one supplier is responsible for solving the problem,” said Fred Mueller from CECO Filters.
However, Andy Turnbull from Lucas Process Systems cautioned that companies should be sure to select services that are suited to the vendor rather than trying to force a business relationship that is not well suited to either party. “Brick manufacturers often assume that all vendors provide a turnkey approach, when in fact many are smaller, device-oriented specialists. Companies need to keep in mind that additional items such as installing the foundation or supplying a stack, for example, are not always a part of the air pollution vendor’s scope, and they can often save a significant amount of money if a team approach is used.”
“Many companies are just looking for vendors to give them a price—they don’t want to take any ownership of the situation. Instead, the industry as a whole needs to be collectively looking at and working with vendors to refine options and find ways to save money,” said Turnbull.
“It is important to follow the rules that the local agencies have set up and to send in any required reports on time. Not doing so can create a number of problems, including potential fines,” Hansen said.
Additionally, since states will have the flexibility to mandate stricter standards than those published in the final MACT rule, companies should try to go beyond minimum compliance efforts. “Some states—Texas, for example—have taken the attitude that sulfur needs to be controlled as well, even though that isn’t part of the federal standard. Companies should be prepared to be held to stricter controls than what the federal MACT is mandating,” Hansen said.