The Maximum Achievable Control Technology (MACT) Standards are air emission standards, set on an industry-by-industry basis, under Title III of the 1990 Clean Air Act Amendments. The MACT standards, established by the U.S. Environmental Protection Agency (US EPA) for facilities burning hazardous wastes, include both emission standards (e.g., how much mercury can be emitted by a facility per hour) and operating standards (e.g., the incinerator has to operate between a minimum and maximum temperature). These MACT standards also establish strict monitoring rules, applicable to both sorts of standards, which require the installation and continuous operation of many different pieces of monitoring equipment on the incinerator.
Veolia ES Technical Solutions has two incineration facilities that must comply with the MACT regulations for "hazardous waste combustors," in Port Arthur, TX and Sauget, IL. Both facilities accept a wide variety of hazardous wastes, in bulk and in drums, including liquids and solids. In addition, the Port Arthur location is one of only three incinerators in the United States authorized by US EPA to incinerate Polyclorinated Biphenyls (PCBs). Since each began operating as part of Veolia in 1999, they have achieved an excellent operating and compliance record.
Under the applicable MACT rules, an incinerator operator is required to notify the US EPA in writing any time an operating or emission standard is exceeded, however briefly, ten or more times in a sixty day period, and to report on the measures taken to prevent future violations of that standard.
"Our performance has been quite good since the Hazardous Waste Combuster MACT went into effect into 2004," says Grieg Siedor, Vice President, Law and Compliance Department and Chief Legal Officer. "We have had to submit only one letter reporting more than ten instances of exceeding a particular MACT parameter over a sixty day period. That letter was submitted on December 27, 2006 and reported that we had exceeded the carbon monoxide parameter. Some of our competitors, in contrast, have submitted dozens of letters reporting 10 or more MACT violations over a 60-day period."
"About six months before MACT compliance requirements went into effect, we began operating our Sauget, IL facility as though we were actually under the MACT standards," explains Siedor. "We wanted to do a better job of running our incineration facilities to be sure that we would be in compliance once the regulations went into effect. We slowed down our operations significantly, putting in less waste, until we could learn to meet the MACT standards. Of course, this slowdown had a negative financial impact on the company, but it was a price we were prepared to pay, because compliance is our number one concern. Now, we're back up to our original rates, because the learning process taught us how to run the incinerator better, how to destroy more wastes without compromising on compliance," Siedor concludes. "Because compliance is a survival issue for Veolia, we have made and will always make operational adjustments to assure compliance."