On June 22, 1999, EPA promulgated the Final Rule for the hydrochloric acid pickling process NESHAP (40 CFR Part 68 Subpart CCC). This standard will apply to all new and existing steel pickling facilities that pickle steel using an acid solution containing a minimum of 6-percent hydrochloric acid by weight. Additionally, the baths must be operated at a temperature 100�F or greater. The regulation will also apply to new and existing hydrochloric acid storage tanks, as well as hydrochloric acid regeneration systems located at steel pickling facilities. The emission standards for existing pickling facilities requires either a maximum HCl concentration of 18 ppmv in any gases, or a 97.5-percent collection efficiency in 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 25 ppmv in the exhaust gas of the air pollution control device. The new rule also requires that acid regeneration plants emit less than 6 ppmv of Cl2.
New continuous acid pickling facilities are limited to either a maximum concentration of 6 ppmv in the exhaust gas from the control device, or a 99-percent collection efficiency in the air pollution control device. For new batch pickling processes, the exhaust gas standard is either 18 ppmv or 99-percent collection efficiency. 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 12 ppmv HCl in the exhaust gas of the air pollution control device. Additionally, new acid regeneration plants may emit a maximum chlorine concentration of 6 ppmv in the exhaust gas of the air pollution control device.
Owners or operators of affected new or existing HCl storage vessels will be required to cover and seal all openings and route emissions to an air pollution control device or alternative control system. In addition, acid storage vessels would be required to use an enclosed line or local fume capture system vented to an air pollution control device or alternative control system at each point where acid is exposed to the atmosphere. New facilities are those where construction was initiated after September 18, 1997.
In addition to the above requirements affected owner/operators must demonstrate compliance through specific performance testing and develop specific enforceable operating parameters for each scrubber system. They must conduct a minimum of quarterly scrubber inspections and maintain records of inspection results, maintenance conducted and corrective action for any problems found. Each owner/operator must meet specific system monitoring, record keeping, notification and reporting requirements as set in the regulation.
Existing regulated facilities must comply with the regulation by June 22, 2001. New or reconstructed facilities must be in compliance immediately upon startup.
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American Wire Producers Association
801 North Fairfax Street, Suite 211
Alexandria, VA 22314-1757
Tel (703) 299-4434 | Fax (703) 299-9233 | E-mail info@awpa.org | Web: www.awpa.org
