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Delegation of Area MACT Sources

Delegation of Area MACT Sources. Air Quality Technical Advisory Committee Meeting October 30, 2008 Ron Davis, Chief of Compliance and Enforcement Division Bureau of Air Quality PA Department of Environmental Protection. Background.

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Delegation of Area MACT Sources

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  1. Delegation of Area MACT Sources Air Quality Technical Advisory Committee Meeting October 30, 2008 Ron Davis, Chief of Compliance and Enforcement Division Bureau of Air Quality PA Department of Environmental Protection

  2. Background • The Clean Air Act requires the U.S. Environmental Protection Agency (EPA) to identify and list the area source categories that represent 90 percent of the emissions of the urban air toxics associated with area sources and subject them to standards under the CAA (section 112(d)). • EPA has identified a total of 70 area source categories which represent 90 percent of the emissions of the air toxics. • Of these 70 area source categories, EPA promulgated 39 area source MACT standards by June 2008; the remaining area source standards are under development.

  3. Delegated Area MACT Sources40 CFR Part 63 Subpart M: Perc Drycleaners Subpart N: Chromium Electroplating and Anodizing Tanks Subpart O: Commercial Sterilization Facilities Subpart T: Halogenated Solvent Cleaning Subpart X: Secondary Lead Smelting

  4. PADEP Intends to Accept Delegation of the Listed Area Source MACT Standards: Subpart Bx6 Gasoline Distribution Bulk Terminal, Bulk Plant and Pipeline Facilities Subpart Ax4 Municipal Landfills Subpart Ox6 Flexible Polyurethane Foam Fabrication and Production Subpart Px6 Lead Acid Battery Manufacturing Subpart Rx6 Clay Ceramics Manufacturing Subpart Tx6 Secondary Non-Ferrous Metals Subpart Zx5 Iron and Steel Foundries Subpart Nx6 Chemical Manufacturing Subpart Sx6 Pressed & Blown Glass Manufacturing Subpart Yx5 Stainless and Non-Stainless Steel Manufacturing (EAF) Subpart Ex3 Hazardous Waste Incineration Subpart Lx3 Portland Cement

  5. EPA Retains Primary Authority Subpart Cx6 Gasoline Dispensing Facilities Subpart Hx6 Paint Stripping and Miscellaneous Surface Coating Subpart Vx3 POTW Subpart Wx5 Hospital Sterilizers Subpart Zx4 Stationary Internal Combustion Engines Subpart Hx2 Oil & Natural Gas Production

  6. EPA Retains Primary Authority: No Known Sources in PA Subpart Dx6 PVC & Copolymer Production Subpart Lx6 Acrylic/Monacrylic Fibers Production Subpart Qx6 Wood Preserving Subpart Ex6 Primary Copper Smelting Subpart Fx6 Secondary Copper Smelting Subpart Gx6 Primary Nonferrous Metal Subpart Ix5 Mercury Cell Chlor-Alkali Subpart Mx6 Carbon Black Production

  7. Draft Implementation Agreement • The Agreement applies to certain area source MACT standards promulgated as of May 2008. • Delegation requests must be submitted to EPA within 6 months of the execution of the Agreement. • The Agreement includes the following compliance oversight approaches • Compliance Determination Plans • Modified Compliance Monitoring Strategy Plans • Compliance Assistance Emphasis

  8. Compliance Determination Plan • The Compliance Determination Plan may identify the following activities, in combination or individually, as providing adequate means for compliance determinations. • review and analysis of compliance reports required by the subject standard • response to complaints received • compliance assistance followed up with targeted compliance monitoring • traditional on-site Full Compliance Evaluation at a specified frequency and at a specified fraction of the regulated universe • other activities as defined in the Compliance Determination Plan

  9. Modified Compliance Monitoring Strategy (CMS) Plan For area source standards that require affected sources to obtain Title V operating permits, the compliance oversight obligations will be aligned with those established in the existing Compliance Monitoring Strategy Plan.

  10. Compliance Assistance Emphasis Potential Compliance Assistance and Outreach Activities • MAILING • COMPLIANCE ASSISTANCE WEBSITE • TRADE ASSOCIATION PARTNERSHIP • SMALL BUSINESS ASSISTANCE PROGRAM • ASSOCIATED PROGRAM OUTREACH • IMPLEMENT EXISTING PROGRAMS Potential Innovative Strategy Options • INTEGRATED COMPLIANCE ASSISTANCE • ENVIRONMENTAL RESULTS PROGRAM • COMMUNITY PARTNERSHIP • SECTOR WORKSHOPS

  11. Next Steps • Delegation Activities (FY09-FY10) • PADEP requests delegation to implement and enforce standards and EPA approves delegation requests. • Outreach and Compliance Assistance Activities (FY09-FY11) • EPA, in collaboration with PADEP, develops and implements a compliance assistance program and provides outreach materials. • PADEP confirms or supplements source category information provided by EPA. • PADEP updates source category information to reflect newly affected area sources.

  12. Next Steps • Compliance Assurance Activities (FY11-FY12) • PADEP provides compliance oversight for source categories delegated including the applicable modified CMS for major sources and/or State Compliance Determination Plan. • EPA provides compliance oversight for non-delegated area source categories. • EPA will promulgate additional Area MACT Standards by June 2009.

  13. Questions/Comments? Thank You…..! Ronald Davis Chief, Div. of Compliance and Enforcement Phone: 717-772-3369 rondavis@state.pa.us

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