Crushing plant and limestone mine

Limestone Industry Association Requests Voluntary Emissions Testing from Member Facilities — Here’s What You Should Know.

February 15, 2022

In 2020, USEPA made several notable changes to the Lime Manufacturing Plants National Emission Standards for Hazardous Air Pollutants (NESHAP) guidelines.  Following these changes there has been speculation of new changes possibly on the horizon for lime processing facilities.  Additionally, the National Lime Association has called for voluntary emissions testing on lime kilns to stay ahead of potential EPA regulation changes.  What does this mean for your facility and what do you need to consider in advance of changes?  With decades of relevant experience in the industry, Montrose has a proven, integrated solution.  Some of the areas of consideration include:

Compliance Program Considerations
It may be advantageous to ramp up an in-house engineering program in advance of a structured compliance program.  Emissions measurements can be correlated to operating conditions in preparation for a compliance program.

Multiple Tests at Multiple Locations/Facilities
Engaging different vendors at multiple facilities can result in testing inconsistencies.  When looking for a testing vendor, look for one that gives you a single point of contact to manage your programs at each facility – ensuring consistent results in consistent report formats – Montrose can handle your ERT reporting for all locations.

Integration of Measurement & Laboratory Teams
Consistency in measurement and testing can be enhanced by selecting a vendor whose measurement and lab teams work together in a seamless way to deliver consistent, reliable results.  Ask questions to ensure testing methods are compatible with reporting standards.

Experience Matters
Does your vendor have relevant and verifiable direct experience in the industry?  While less-tenured vendors can take basic measurements, a more established vendor can combine Method 18 and PTR for your OHAPs project – potentially demonstrating lower emissions.

Choose the Right Vendor for Your Program
The measurements you collect today could impact future rulemaking down the road.  Using a relatively inexperienced vendor may negatively impact your results, quality and total cost later. Consider a more sophisticated and accredited vendor for your critical program – one with advanced technologies and capabilities exceeding standard program offerings.

What’s next?
If your lime processing operation is subject to revised USEPA requirements, a thorough review of the rules and regulations is in order. But you don’t have to navigate these changes alone – the Montrose integrated family of companies can provide the help you need, with decades of experience and a seamless program – from planning to sampling to testing to response and remediation, if necessary.  For more information, please contact us.

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