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Lunch. Networking activities 12:20 MACT Standards 12:45. Air Quality 101 Workshop: MACT Standards. January 2006 Sherry Davis, CHMM. NESHAPs vs. MACTs. National Emission Standards for Hazardous Air Pollutant (NESHAP) standards And

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  1. Lunch Networking activities 12:20 MACT Standards 12:45

  2. Air Quality 101 Workshop: MACT Standards January 2006 Sherry Davis, CHMM

  3. NESHAPs vs. MACTs National Emission Standards for Hazardous Air Pollutant (NESHAP) standards And 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. Jan. 2006

  4. NESHAP and MACT Regulate Toxic Air Pollutants Where 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) Jan. 2006

  5. Toxic Air Pollutants Jan. 2006

  6. NESHAPs In 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 Jan. 2006

  7. MACTS The 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. Jan. 2006

  8. MACTs and NESHAPs Sources 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. Jan. 2006

  9. 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. Jan. 2006

  10. MACTs Each 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. Jan. 2006

  11. 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." Jan. 2006

  12. MACT Hammer Unfortunately, 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 emissionlimits 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? Jan. 2006

  13. MACT schedule Approximately 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 Jan. 2006

  14. General MACT reqt's Notification 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. Jan. 2006

  15. 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. Jan. 2006

  16. 2006 MACTs FFFF – 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 coating http://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 Jan. 2006

  17. 2006 MACTs WWWW – 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 Jan. 2006

  18. 2006 MACTs HHHHH – 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 Jan. 2006

  19. 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 Jan. 2006

  20. 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. Jan. 2006

  21. Area Source MACTs The 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 Jan. 2006

  22. 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 Jan. 2006

  23. Area Source MACTs Collectively, 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 Jan. 2006

  24. Area Source MACTs Standards 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. Jan. 2006

  25. Area Source MACTs EPA 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. Jan. 2006

  26. 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). Jan. 2006

  27. Urban Area Source Toxics acetaldehyde acrolein acrylonitrile arsenic compounds benzene beryllium compounds 1,3-butadiene cadmium compounds carbon tetrachloride chloroform chromium compounds Jan. 2006

  28. Urban Area Source Toxics coke oven emissions dioxin 1,2-dibromoethane 1,3-dichloropropene ethylene oxide ethylene dichloride (1,2-dichloroethane) formaldehyde hexachlorobenzene hydrazine lead compounds Jan. 2006

  29. Urban Area Source Toxics manganese compounds mercury compounds methylene chloride (dichloromethane) nickel compounds polychlorinated biphenyls (PCBs) polycyclic organic mater (POM) propylene dichloride, quinoline 1,1,2, 2-tetrachlorethane tetrachloroethylene (perchloroethylene) trichloroethylene vinyl chloride, Jan. 2006

  30. 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 Jan. 2006

  31. 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 Jan. 2006

  32. Area Source MACTs These 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 Jan. 2006

  33. 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 Jan. 2006

  34. Future Area Source MACTs 55 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 Jan. 2006

  35. 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) Jan. 2006

  36. 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) Jan. 2006

  37. 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) Jan. 2006

  38. 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 Jan. 2006

  39. 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  Jan. 2006

  40. Area Source MACT Resources Want 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) Jan. 2006

  41. 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 Jan. 2006

  42. 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? Jan. 2006

  43. MACTs • Any questions or comments? Jan. 2006

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