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Latest Developments in the MACT Hammer MACT Standards

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									Latest Developments in
 the MACT Hammer &
   MACT Standards
    Bill Roth-Evans
    September 16, 2003



       trinityconsultants.com
                    Agenda
   What is a MACT Standard?
   What is the MACT Hammer and what are
    the chances it will impact my facility?
   What is the status of the outstanding MACT
    regulations?
   What are the issues surrounding Startup,
    Shutdown, and Malfunction Plans?
   What to do next?
     What is a MACT Standard?
   1990 Clean Air Act Amendments requires
    the control of hazardous air pollutant (HAP)
    emissions
        Created 188 categories of regulated HAPs
        Required EPA to develop new National Emission
         Standards for Hazardous Air Pollutants
         (NESHAPs) under 40 CFR Part 63
   Part 63 NESHAPs regulate HAP emissions
    by processes or facility types
        The level of control required is the Maximum
         Available Control Technology (MACT)
        In most cases, Part 63 NESHAPs apply to
         facilities that are major for HAPs (potential to
         emit > 10 tpy for an individual HAP or > 25 tpy
     What is a MACT Standard?
   EPA established deadlines for NESHAP
    regulation development (initial list published
    7/16/92)
        166 categories of major sources
        8 categories of “area sources” (i.e., not major
         for HAPs)
          Chromium Electroplating
          Halogenated Solvent Cleaning

          Perchloroethylene Dry Cleaning

   The original promulgation schedule was split
    into four “bins”
   Original Schedule for Promulgation
                  Promulgation    Comply      Residual Risk
    Comply

40 Categories     Nov. 1992      Nov. 1995        2001
    2003
(plus Coke Ovens)

25% of listed     Nov. 1994      Nov. 1997        2002
   2004
Categories

50% of listed     Nov. 1997      Nov. 2000        2005
   2007
Categories

All listed        Nov. 2000       Nov. 2003        2008
          What is Residual Risk?
   Second round of MACT development based
    on risk analyses (8 years after first round)
   EPA has not yet begun reevaluating final
    MACT standards based on residual risk
   EPA is trying to address residual risk now
    for some of the standards still being
    developed
        Residual risk mitigation through modeling to
         show no risk
            Proposed Boiler MACT and Wood Products MACT have
             requested comments on this
 MACT Hammer
CAA Section 112(j)
                MACT Hammer
   What is the “MACT Hammer”?
       If EPA misses the final promulgation deadline
        (11/15/00), then 18 months later each affected
        source must develop a "case-by-case MACT
        determination"
       November 15, 2000 plus 18 months is May 15,
        2002
       Anticipating that the MACT Hammer may be an
        issue, EPA proposed new 2 part approach and
        timeline on    April 5, 2002
         Sierra Club filed suit to move up Part 2 deadline (strong
          case)
         Proposed settlement between EPA and Sierra Club on
          December 9, 2002 with staggered deadlines for Part 2
          submittals
                   MACT Hammer
        Part 2 Applications due May 15, 2003
        (Hammer did not hit since all were promulgated “on time”)

   Municipal Solid Waste               Integrated Iron & Steel
    Landfills                            Manufacturing
   Paper & Other Webs                  Brick/Structural Clay and
    Surface Coating                      Clay Ceramics
   Flexible Polyurethane                Manufacturing
    Foam Fabrication                    Asphalt & Asphalt Roofing
   Coke Ovens
                                        HCl Production and Fumed
   Reinforced Plastics                  Silica
    Composites
   Semiconductor                       Engine and Rocket Testing
    Manufacturing                       Metal Furniture Surface
   Wood Building Products               Coating
    Surface Coating                     Printing, Coating, Dyeing of
   Refractory Manufacturing             Fabrics
            MACT Hammer
Part 2 Applications due October 30, 2003
 (All have been signed, but not all in Federal Register yet.
        EPA says no MACT Hammer for these either.)
   Combustion Turbines           MON
   Miscellaneous Metal           Organic Liquids
    Parts                          Distribution
    Surface Coating               Primary Magnesium
   Metal Pipe Asphalt/Tar        Metal Can Surface
    Application                    Coating
   Lime Manufacturing
                                  Plastic Parts and
   Site Remediation               Products Surface Coating
   Iron and Steel Foundries      Mercury Cell Chlor-
   Taconite Iron Ore              Alkali Plants (formerly
                                   Chlorine Production)
         MACT Hammer
Part 2 Applications due April 28, 2004

   Industrial Boilers and Process
    Heaters
   Plywood and Composite Wood
    Products
   Reciprocating Internal Combustion
    Engines
   Auto and Light Duty Truck Surface
    Coating
          MACT Hammer
Part 2 Applications due August 13, 2005
    Industrial Boilers and Process
     Heaters with hazardous waste
     combustion
    HCl Production with hazardous
     waste combustion
              MACT Hammer
   Many complicated (and some
    controversial) Title III standards to be
    finalized
       Boiler MACT, Wood Products, IC engines,
        etc.
   EPA not expecting to miss any
    deadlines
       EPA may finalize regulations, knowing that
        additional amendments are necessary to
        clean up concerns
   EPA has promised to give 60 day notice
    if promulgation deadline will be missed
    (no such notices to date)
                MACT Hammer
   Handouts provide status of the standards in
    the final “10-year” MACT bin.
   EPA signed each of the MACT standards in
    the October 30, 2003 MACT Hammer
    group at the end of August
       Lime Manufacturing
       Miscellaneous Organic Chemical Manufacturing
        (MON)
       Miscellaneous Metal Parts
       Plastic Parts and Products
       Site Remediation
MACT Hammer Part 2 Submittals
                    (If necessary)
   What must a Part 2 application contain if you
    have to submit one?
       HAPs emitted by each affected source
       Total controlled and uncontrolled HAP emissions
       Any Federal, state or local emission limits
       The control technology currently in place for
        each affected emission source
       Information relevant to establishing the MACT
        floor
       A recommended MACT floor
       Any other information required by the permitting
        authority
        MACT Hammer Part 2 Submittals
                        (If necessary)
   What may a Part 2 application contain?
       Recommended emission limits
       Specific design, equipment, or work practice
        standards
       Description of control technologies that will be
        applied including technical information on the
        design, operation, size, estimated control
        efficiency
       Relevant parameters to be monitored and
        frequency of monitoring to demonstrate
        continuous compliance
       Similar to if not part of a Title V permit
          MACT Hammer Part 2
   Agency must issue permit within 18 months
    of receiving a Part 2 application from a
    facility
   Can utilize the initially proposed MACT
   Incorporate standard at next Title V
    renewal
   If requested an applicability determination
    in Part 1, must resubmit request &
    supplement request within 60 days of
    finalization of MACT Hammer amendments
    (already past) or 60 days after EPA
    publishes a proposed MACT, whichever is
    later
       Startup, Shutdown and
       Malfunction Plan Issues
   Part of the compromise between Sierra
    Club and EPA were staggered MACT
    Hammer dates in return for requiring
    facilities to submit Startup, Shutdown,
    and Malfunction (SSM) Plans to
    regulatory agencies (and effectively the
    public)
   Changes to General Provisions of Part
    63 in the Federal Register (5/8/03)
    states that a source must submit copy of
    SSM Plan to Administrator if requested
          Startup, Shutdown and
          Malfunction Plan Issues
   Sierra Club withdrew its consent to the
    order holding their lawsuit in abeyance
    on June 10th
       “full public access to SSM plans was
        extremely important to Sierra Club and Sierra
        Club would never have entered into the
        settlement agreement without it”
       “SSM provisions in EPA’s final rule are not
        the same in substance as those set forth in
        our settlement agreement”
          Startup, Shutdown and
          Malfunction Plan Issues
   Sierra Club is now pursuing legal action
    on the MACT Hammer and continues to
    press for requiring SSM plan submittal
    and review
       Very concerned about “hand wave” SSM
        plans that do not identify all malfunction
        events and appropriate responses to minimize
        excess emissions
   The 5/8/03 General Provisions Final Rule
    also eliminated the need to submit
    information in semiannual Summary
             What To Do Next? (1 of 2)
   If EPA has proposed or finalized a MACT
    that may apply to your facility, read it
    carefully
       Look for applicability, exemptions, and
        whether you can comply
       If the rule is final, you will have 3 years for
        existing sources to comply
          Start planning now (capital planning, changing paints
           , etc.)
          New sources generally have to be in compliance
           upon startup
       Be prepared for additional changes to the rule
        as
           What To Do Next? (2 of 2)
   Evaluate the completeness of your SSM
    Plans for MACT standards you are already
    complying with
       Are all known malfunctions identified and are
        they truly malfunctions (e.g., not due to
        operator error)?
       Have all remedies to malfunctions been
        outlined?
       Do you reference current startup and
        shutdown procedures?
       Are you updating your SSM plan with each
        new kind of malfunction or remedy and
        keeping copies of each version of the SSM
     What To Do Down the Road?
   Identify which compliance options you will
    use
   Implement compliance early so that you
    can test your ability to maintain
    compliance
   Prepare employee training programs
       MACT standards often affect how everyone
        does their job (e.g., how to clean a paint gun)
   Implement some type of compliance
    management tool (e.g., customized
    database)
    If you have further questions...
   Please feel free to contact me at
       Phone: (636) 386-9500
       Email: bevans@trinityconsultants.com

								
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