(156a) Balancing Between MACT Compliance and Production Requirements

This presentation will focus on the challenges faced by a chemical manufacturing company in their attempt to balance Maximum Available Control technology (MACT) applicability under the Clean Air Act and process modification with production increase. This company manufactured specialty coatings at a plant in Pennyslyvania and was operating an older production process for the past few years and as such was under any MACT triggers. However this company decided to upgrade the process and increase production to meet market demand. This would have resulted in the applicability to the National Emission standards for Hazardous Air Pollutants for Miscellaneous Organic Chemical Manufacturing (MON MACT) pursuant to 40 CFR part 63, Subpart FFFF. Meeting the MON MACT requirements would result in significantly increased capital and operating costs and potentially impact project viability.

This presentation will highlight the various options the company considered in the decision making process which included MACT avoidance options as well as options that were available to meet MON MACT requirements and project vaibility. The MACT avoidance options included distrubution of production to different locations in the US, process design as well as overseas production to avoid MACT costs. MACT options that were evaluated included various technical options for controls and asscoiated costs. This discussion will present teachnological and economic feasibility that was conducted for all the options that were considered and how the company reached its conclusion on the option that was implemented in order to meet air compliance as well as its business requirements. The option choosen was a compromise solution that allowed the company to maintain its Pennslyvania operations but achieve air compliance with optimal cost.