Sources that demonstrate compliance with the IB-MACT standards for total selected metals (TSM) and/or hydrogen chloride (HCl) using the alternative health-based compliance (HBC) approaches must submit an eligibility demonstration by 9/13/2006. Any source electing to use either of the HBC approaches should conduct the necessary testing immediately. There is only a little over one month remaining to schedule the testing, finalize test results, and prepare the eligibility demonstration for submittal. In some cases, it may already be too late to meet the deadline.
For the many coal-fired sources affected by IB-MACT that fire bituminous coals (this includes some sources in the electric utility industry), the HBC approach may be the only alternative to meet the new HCl emissions standard. It is imperative that these sources conduct fuel sampling to determine the coal chlorine content. If the equivalent fuel HCl content is above the IB-MACT emissions standard of 0.09 lb/mmBtu, the source should immediately begin investigating the use of the HBC compliance option.
RMB Consulting &