Barring a last minute extension, the EPA will begin finalizing the Proposed Rule for the hydrochloric acid pickling process NESHAP (40 CFR Part 68 Subpart CCC) in the next few months. The court mandated deadline for the new air emission standard is May 1999. This standard will apply to all new and existing steel pickling facilities that use a solution where 50-percent or more by weight of the acid in the solution consists of hydrochloric acid. Steel pickling for the purposes of this regulation is defined as the chemical removal of iron oxides and scale formed during hot rolling or forming of semi-finished steel products through contact with an aqueous solution of hydrochloric acid.
The NESHAP specifically excludes operations which are undertaken to remove light rust, or for the activation of the metal surface. The regulation will also apply to virgin and regenerated hydrochloric acid storage tanks, as well as hydrochloric acid regeneration systems located at steel pickling facilities. The emission standards for existing pickling facilities require a 97.5-percent collection efficiency in the air pollution control device, or a maximum HCl concentration of 10 ppmv in the offgas of the air pollution control device. The standards for existing HCl regeneration systems requires a 97.5-percent collection efficiency for HCl in the air pollution control device, or a maximum concentration of HCl of 8 ppmv in the offgas of the air pollution control device. New acid pickling facilities are required to achieve a 99-percent collection efficiency in the air pollution control device, or a maximum concentration of HCl of 3 ppmv in the offgas from the air pollution control device. New acid regeneration plants are required to achieve a 99-percent collection efficiency for HCl in the air pollution control device, or a maximum concentration of 3 ppmv HCl in the offgas of the air pollution control device. Additionally, both new and existing acid regeneration plants may emit a maximum chlorine concentration of 4 ppmv in the offgas of the air pollution control device.
Owners or operators of affected new or existing HCl storage tanks will be required to install and operate the tanks in such a manner that the tanks are at all times, except during loading and unloading operations, either in a closed loop or so that the tanks are vented to the pickling facilities air pollution control device. New facilities are those where construction was initiated after September 18, 1997. Regulated facilities must comply with the regulation within two years of the regulation being finalized.
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