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Transcript of Lunch Networking activities 12:20 MACT Standards 12:45.
Lunch
Networking activities 12:20MACT Standards 12:45
Air Quality 101 Workshop: MACT
StandardsJanuary 2006Sherry Davis, CHMM
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
NESHAPs vs. MACTsNational Emission Standards for Hazardous Air
Pollutant (NESHAP) standardsAnd
Maximum Achievable Control Technology (MACT) standards
Both regulate hazardous air pollutants (HAPs) known as toxic air pollutants or air toxics; cause cancer, serious health effects, reproductive problems, birth defects, adverse environmental and ecological effects.
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
NESHAP and MACT Regulate Toxic Air PollutantsWhere do air toxics go?
Depends on environmental conditions Type of pollutant, chemical and physical properties Depends on persistence in the environment-metals
How are populations exposed to HAPs? Breathing contaminated air Eating or drinking contaminated food and water Eating contaminated soils (young children) Skin contact (swimming or touching contaminated
soil or surfaces)
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
Toxic Air Pollutants
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
NESHAPsIn the beginning…
EPA had to identify hazardous air pollutants (HAPs) and identify and develop standards to prevent any adverse human health effects with an “ample margin of safety.” All were risk-based. Courts directed EPA to determine safe air
pollutant levels without technological or cost concerns (NESHAP).
This process proved to be tedious, long, and costly; development was slow…and unacceptable
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
MACTSThe solution….
1990 Clean Air Act (CAA) Amendments established a new and fairly complex program to regulate HAP emissions from the industrial sources responsible for the HAP being emitted. This required developing and promulgating
“technology-based” standards. These were based on emissions levels from
“best-performing” facilities in each industry sector.
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
MACTs and NESHAPsSources subject to MACT/NESHAP standards
are classified as either major sources or area sources.
Major sources emit 10 tons per year of any of the listed HAPs, or 25 tons per year of a mixture of HAPS
Area sources consist of smaller-size facilities that release lesser quantities of HAPs into the air. Area sources emit less than 10 tons per year of a single HAP, or less than 25 tons per year of a combination of HAPs.
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
MACTs
Development of a MACT standard - Sets standards for both existing and new
emission sources. Reviews current level of emissions achieved by
best-performing similar sources through clean processes, control devices, work practices, or other methods such as pollution prevention.
Uses these emission levels to set a baseline, often referred to as the "MACT floor" for the new standard.
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
MACTsEach MACT standard must achieve a level of emissions
control at least equivalent to the MACT floor.
MACT floor differs for “existing” and “new” sources emissions must not be less than the average emission level
achieved by controls on the best performing 12% of existing industry sources-if 30 or more sources exist;
If less than 30 sources, then the “floor” is equal to average current emissions limitation achieved by the best-performing five sources in the category.
EPA can establish a more stringent standard when it makes economic, environmental, and public health sense to do so.
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
MACT “Hammer”When Congress amended the CAA in 1990 it included
a mandate that MACT standards be adopted for many industrial facilities over the next 10 years.
EPA established a 2, 4, 7, and 10 year schedule to finalize
Section 112(j) included a provision that would mandate site-specific MACT standards if the industry-wide standard wasn’t developed by May 15, 2002.
Establishing site-specific MACT standards for each major source of HAPs would be an immense burden for both industry and government regulators, this provision was called the "MACT hammer."
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
MACT HammerUnfortunately, the EPA missed the May 15 deadline
for many source categories.
Anticipating this, EPA issued a final rule on April 5, 2002 to extend until May 15, 2004 the deadline for companies to submit detailed applications that state air agencies would use to determine HAP emission limits on a case-by-case basis. Lawsuit resulted in May 15, 2004 deadline
being moved up to May 15, 2003
How many companies have “site specific” MACT in Kansas?
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
MACT scheduleApproximately 88 MACT Standards promulgated
since 1990 (40 CFR Part 63)
Approximately 40 additional MACT Standards with compliance dates 2005 through 2007
Compliance dates are in place for 48 MACT Standards
Compliance date typically 3 years after promulgation for existing sources
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
General MACT reqt'sNotification Requirements;
Performance Testing: If performance test is required, you must notify
the administrator in writing 60 days before the test is scheduled.
Recordkeeping and Reporting Requirements:Applicability Determinations: If your facility determines that your source is
not subject to a relevant standard or other requirement, you shall keep a record of the applicability determination on site for a period of 5 years.
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
General MACT req’ts
Recordkeeping and Reporting Requirements: Periodic Startup, Shutdown, Malfunction Reports: Start-up, Shutdown, and Maintenance (SS&M)
reports must be submitted semi-annually.
Recordkeeping and Reporting Requirements: Most MACT standards require REPORTING –
please review your files to ensure your facility is submitting all necessary reports to KDHE and copying the EPA.
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
2006 MACTsFFFF – Misc. Organic Chemical Production and Processes
(MON)
http://www.epa.gov/ttncaaa1/t3/fr_notices/mocmfc0702.pdf 40 CFR Subpart 63.2430 - 63.2550 Initial Notification: 3/9/04 Compliance Date: 11/10/06
RRRR -Metal Furniture Surface coatinghttp://www.epa.gov/ttncaaa1/t3/fr_notices/scmf_pr.pdf 40 CFR Subpart 63.4880 - 63.4981 Initial Notification: 5/24/04 Compliance Date: 5/23/06
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
2006 MACTsWWWW – Reinforced Plastic Composites Production http://www.epa.gov/ttncaaa1/t3/fr_notices/rpc_fr.pdf
40 CFR Subpart 63.5780 - 63.5935 Initial Notification: 8/19/03 Compliance Date: 4/21/06
GGGGG – Site Remediation
http://www.epa.gov/ttncaaa1/t3/fr_notices/sr_pr.pdf 40 CFR Subpart 63.7880 - 63.7957 Initial Notification: 2/5/04 Compliance Date: 10/8/06
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
2006 MACTsHHHHH – Miscellaneous Coating Manufacturing
http://www.epa.gov/ttncaaa1/t3/fr_notices/mcm_fr.pdf 40 CFR Subpart 63.7980 – 63.8105 Initial Notification: 4/9/04 Compliance Date: 12/11/06
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
2007 MACTs EEEE - Organic Liquids Distribution (Non-
Gasoline), Subpart: 63.2330 - 63.2406
MMMM - Miscellaneous Metal Parts and Products (surface coating), Subpart: 63.3880 - 63.3981
PPPP - Plastic Parts/ Products (surface coating), Subpart: 63.4480 - 63.4581
ZZZZ - Reciprocating Internal Combustion Engines RICE), Subpart: 63.6580 - 63.6675
DDDDD -Industrial, Commercial, and Institutional Boilers and Process Heaters, Subpart: 63.7480 - 63.7575
YYYY - Stationary Combustion Turbines (CT), Subpart: 63.6080 - 63.6175
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
Is your business covered?It is company’s responsibility to find out if a MACT
applies to their industry and their operations.
Where can you go to find a list of regulated sources and the promulgation dates ? http://www.epa.gov/ttn/atw/mactfnl.html
KDHE has adopted all MACT standards in the CFR through July 1, 2003 and are currently working on 2004 and 2005.
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
Area Source MACTsThe Clean Air Act (CAA) required EPA to:
Identify a list of at least 30 air toxics that pose the greatest potential health threat in urban areas;
Identify area source categories that represent 90 percent of the emissions of the "listed" air toxics and subject them to standards under the CAA (section 112(d)).
EPA identified 70 area source categories which represent 90 percent of the emissions of the 30 listed air toxics.
Achieve at least a 75- percent reduction in risk attributable to area source emissions
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
Area Source MACTs Of these 70 area source categories, 15 are
currently regulated and the remaining area source standards are under development or will be developed in the future.
Remember: these MACT rules are for non-major emissions sources Less than 10 tons of any one HAP Less than 25 tons of any combination of HAP
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
Area Source MACTsCollectively, area sources are important air toxics
contributors especially in urban areas
Represent about 50 percent of national stationary source emissions
Many emit air toxic metals which are also fine PM
However, individual area sources are small emitters , many sources emit less than 100 pounds of HAP
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
Area Source MACTsStandards may be based on generally available
control technology (GACT) or Maximum Achievable Control Technology (MACT)
The advantages of GACT Allows more flexibility There is no floor to calculate Cost effectiveness is considered
MACT is average of the best performing 12% (30 or more sources) or average of best performing five (<30 sources).
Typical standard development will take 4 to 5 years to develop.
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
Area Source MACTsEPA is developing a program of voluntary
initiatives to obtain air toxic emission reductions from area sources in urban communities that will:
Utilize assistance of industry trade associations or similar organizations
Complement the rulemaking process – not replace it
These programs will be self-certifying.
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
Area Source MACTs Area sources must submit a notification
form to KDHE if their business is covered by an area source MACT
Area sources may or may not need a construction or operating permit; most sources are expected to be exempted from federal permitting requirements (no Title V needed for area sources).
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
Urban Area Source Toxics acetaldehyde acrolein acrylonitrile arsenic compounds benzene
beryllium compounds 1,3-butadiene cadmium compounds carbon tetrachloride
chloroform chromium
compounds
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
Urban Area Source Toxicscoke oven emissions
dioxin 1,2-dibromoethane
1,3-dichloropropene ethylene oxide ethylene dichloride (1,2-
dichloroethane) formaldehyde hexachlorobenzene
hydrazine lead compounds
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
Urban Area Source Toxicsmanganese compounds
mercury compounds methylene chloride (dichloromethane)
nickel compounds polychlorinated biphenyls (PCBs) polycyclic organic mater (POM)
propylene dichloride, quinoline
1,1,2, 2-tetrachlorethanetetrachloroethylene (perchloroethylene)
trichloroethylene vinyl chloride,
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
Area Source’s Currently Regulated?
Chromic Acid Anodizing Commercial Sterilization Facilities* Decorative Chromium Electroplating* Dry Cleaning Facilities* Halogenated Solvent Cleaners* Hard Chrome Electroplating* Publicly Owned Treatment Works Municipal Waste Combustors
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
Area Source’s Currently Regulated?
Hazardous Waste Incineration Medical Waste Incineration Portland Cement Manufacturing Secondary Aluminum Production* Secondary Lead Smelting Municipal Landfills Mercury Cell Chlor-Alkali Plants
*exempt from Title V permit, but must meet MACT requirements
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
Area Source MACTsThese industry have court-ordered
proposal and promulgation deadlines: Other Solid Waste Incineration - Promulgated
11/30/05 (COMPLETED) Oil and Natural Gas Production - Proposal signed
6/30/05; promulgation due 12/21/06 Stationary Internal Combustion Engines -
Proposal 10/31/06; promulgation 12/20/07 Hospital Sterilizers - Proposal 10/31/06;
promulgation 12/20/07 Gasoline Distribution Stage I - Proposal
10/31/06; promulgation 12/20/07
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
Area Source MACTs
If your business is covered by one of the above area source MACTs you can download the rule and find specific implementation information at:
http://www.epa.gov/ttn/atw/urban/arearules.html
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
Future Area Source MACTs55 Area source categories which will be
subject to standards; all standards will be initiated by Oct. 2006
Acrylic Fibers/Modacrylic Fibers Production Lead Acid Battery Manufacturing Ag Chemicals & Pesticides Manuf. (started 2004) Asphalt Processing & Asphalt Roofing
Manufacturing Misc. Organic Chemical Manuf. (MON) Autobody Refinishing Paint Shops (started 2004) Nonferrous Foundries, nec. (started 2004) Brick & Structural Clay
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
Future Area Source MACTs Oil & Natural Gas Production (12/06 promulgation)
Carbon Black Production Clay Ceramics (started 2004)
Chemical Manufacturing: Chromium Compounds Other Solid Waste Incinerators
(Human/Animal Cremation) (11/05 promulgation)
Chemical Preparations (started 2004)
Paint Stripping Operations (started 2004)
Copper Foundries Paints & Allied Products Manufacturing (started 2004)
Cyclic Crude & Intermediate Production (started 2004)
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
Future Area Source MACTs Pharmaceutical Production Electrical & Electronic Equipment: Finishing
Operations Plastic Parts & Products (surface coatings) (started
2004)
Fabricated Metal Products, nec. Plastic Materials and Resins Manufacturing Fabricated Structural Metal Manuf Plating & Polishing (started 2004)
Ferroalloys Production: Ferromanganese & Silicomanganese
Polyvinyl Chloride & Copolymers Production Flexible Polyurethane Foam Production (started 2004)
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
Future Area Source MACTs Prepared Feeds Manufacturing Flexible Polyurethane Foam Production Primary Copper (not subject to Primary Copper
Smelting MACT) Fabricated Plate Work (started 2004)
Primary Metals Products Manufacturing Gasoline Distribution (Stage I) (2007 promulgation date)
Primary Nonferrous Metals- Zinc, Cadmium and Beryllium
Heating Equipment, except electric Pressed & Blown Glass & Glassware
Manufacturing (started 2004)
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
Future Area Source MACTs Hospital Sterilizers (12/07 promulgation date)
Secondary Copper Smelting Industrial Boilers (started 2004)
Secondary Nonferrous Metals (started 2004)
Industrial Inorganic Chemical Manufacturing (started 2004)
Sewage Sludge Incineration Industrial Organic Chemical Manufacturing Stationary Internal Combustion Engines (12/07
promulgation)
Industrial Machinery & Equipment: Finishing Operations
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
Future Area Source MACTs Synthetic Rubber Manufacturing Inorganic Pigments Manufacturing Stainless & Non-stainless Steel Manufacturing:
Electric Arc Furnaces (EAF) (started 2004)
Institutional/Commercial Boilers (started 2004)
Steel Foundries (started 2004)
Iron Foundries (started 2004)
Valves & Pipe Fittings Iron & Steel Forging Wood Preserving
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
Area Source MACT ResourcesWant details on proposed area source MACTs?
Proposed area source MACTs can be found at: http://www.epa.gov/ttn/atw/urban/arearules.html
Sources that are subject to an area source MACT must file a notification form with KDHE (if state has not adopted send to EPA; if unsure send to both.)
Forms can be downloaded from EPA’s Website: http://www.epa.gov/ttn/atw/gp/gppg.html(hardcopies are also available at each workshop on resource table)
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
Comment on Proposed Rules!Want to comment on an area source MACT that
affects your industry?Rules currently open for comment can be found at:
http://www.regulations.gov/fdmspublic-rel11/component/main Agency: choose “Environmental Protection
Agency” Document type: “Proposed rule” Keyword: type in the words “area source MACT
(or NESHAP) for (name of your industry) Choose “any word” if not sure of MACT name or
“exact phrase” if you do know the name of the rule
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
MACTs
KDHE staff to call about MACTs: Mindy Bowman: 785-296-6421 Mary Mahaffey: 785-296-1548 Jim Stewart: 785-296-1556 Rasha Allen: 785-296-1693 David Peter: 785-296-1104
Or, you can call the Kansas SBEAP at: 800-578-8898
Questions?
SBEAP: 800-578-8898 Jan. 2006 Air Quality 101 Workshop
MACTs Any questions or comments?