The Wonderful The Wonderful World of HAP World of HAP RegulationsRegulations
Genevieve DamicoGenevieve Damico
U.S. EPA, Region 5U.S. EPA, Region 5
AgendaAgendaAlphabet soupAlphabet soupWhat are the regulated What are the regulated
HAPsHAPsWhat are MACT standardsWhat are MACT standardsStatus of MACTStatus of MACT
Agenda Cont’d.Agenda Cont’d.What is case-by-case MACTWhat is case-by-case MACTWhat is the MACT HammerWhat is the MACT HammerMay 8, 2003 ruleMay 8, 2003 ruleReviewReview
Alphabet SoupAlphabet Soup112(a) - Definitions 112(a) - Definitions 112(b) - List of Pollutants112(b) - List of Pollutants 112(c) - List of Source 112(c) - List of Source
Categories Categories 112(d) - Emission Standards112(d) - Emission Standards
Alphabet SoupAlphabet Soup112(e) - Schedule for 112(e) - Schedule for
Standards and ReviewStandards and Review 112(f) - Standards to Protect 112(f) - Standards to Protect
Health and the Environment Health and the Environment (Residual Risk Program) (Residual Risk Program)
Alphabet SoupAlphabet Soup
112(g) - Modifications, 112(g) - Modifications, Construction, and Construction, and ReconstructionReconstruction
112(h) - Work Practice 112(h) - Work Practice StandardsStandards
Alphabet SoupAlphabet Soup
112(i) - Schedule for Compliance 112(i) - Schedule for Compliance for New Sources, Early Reduction for New Sources, Early Reduction Program Program
112(j) - Equivalent Emission 112(j) - Equivalent Emission Limitation by Permit "MACT Limitation by Permit "MACT HammerHammer""
Alphabet SoupAlphabet Soup
112(k) - Urban Air Toxics 112(k) - Urban Air Toxics Strategy Strategy
112(l) - State Programs: 112(l) - State Programs: Delegation of Implementation & Delegation of Implementation & Enforcement Authority Enforcement Authority
Alphabet SoupAlphabet Soup 112(m) - Atmospheric Deposition to 112(m) - Atmospheric Deposition to
Great Lakes/Coastal Waters-Great Lakes/Coastal Waters-Reports to Congress Reports to Congress
112(n) - Studies: Utilities, Coke 112(n) - Studies: Utilities, Coke Ovens, POTWs, Mercury, Hydrogen Ovens, POTWs, Mercury, Hydrogen Sulfide Sulfide
Alphabet SoupAlphabet Soup112(o) - National Academy of 112(o) - National Academy of
Sciences Study on Risk Sciences Study on Risk Assessment Assessment
112(p) - Mickey Leland 112(p) - Mickey Leland National Urban Air Toxics National Urban Air Toxics Research CenterResearch Center
Alphabet SoupAlphabet Soup
112(q)-Savings Provision 112(q)-Savings Provision 112(r)-Prevention of Accidental 112(r)-Prevention of Accidental
Releases Releases 112(s)-Periodic Reports on 112(s)-Periodic Reports on
Measures Taken to Implement Measures Taken to Implement Section 112 Section 112
What are the What are the regulated HAPs?regulated HAPs?Listed in 112(b)Listed in 112(b)188 HAPs188 HAPs
What are the regulated What are the regulated HAPs? (Cont’d.)HAPs? (Cont’d.)Air toxics are those pollutants that Air toxics are those pollutants that
are known or suspected of are known or suspected of causing cancer or other serious causing cancer or other serious health effects, such as health effects, such as developmental effects or birth developmental effects or birth defectsdefects
What is a MACT What is a MACT standard?standard?
Technology based standardTechnology based standardSource Category specificSource Category specific
What is a MACT What is a MACT standard? Cont’d.standard? Cont’d.No less stringent than the No less stringent than the
top 12% controlled sources top 12% controlled sources in a particular source in a particular source category (the MACT floor)category (the MACT floor)
What is a MACT What is a MACT standard? Cont’d.standard? Cont’d.
Most apply to major sources Most apply to major sources of HAPs (10 tpy of a of HAPs (10 tpy of a particular HAP/25 tpy of an particular HAP/25 tpy of an aggregate of HAPs)aggregate of HAPs)
http://www.epa.gov/ttn/atw/http://www.epa.gov/ttn/atw/eparules.htmleparules.html
(See next page in your handouts for (See next page in your handouts for table.)table.)
MACTMACT CFR Sub CFR Sub PartsParts
Final Federal Final Federal RegisterRegister
Compliance Compliance DateDate
Project LeadProject Lead Compliance Compliance LeadLead
AerospaceAerospace
IndustryIndustry
GGGG 9/01/959/01/95
(60FR45948)(60FR45948)
9/01/989/01/98 Barbara DiscollBarbara Discoll
919-541-1051919-541-1051
[email protected]@epa.govepa.gov
Len Lazarus Len Lazarus 202-564-6369202-564-6369
[email protected]@epa.gov
Status of MACTStatus of MACT89 promulgated89 promulgated 5 proposed5 proposed(This total includes the MON (This total includes the MON
MACT as a single category.)MACT as a single category.)
Future of MACTFuture of MACTU.S. EPA is going back to the U.S. EPA is going back to the
promulgated MACT and promulgated MACT and evaluating whether or not evaluating whether or not further reductions are further reductions are necessary based on a risk necessary based on a risk assessmentassessment
What is case-by-case What is case-by-case MACT?MACT? 112(g) of the CAA112(g) of the CAA Construction or reconstruction Construction or reconstruction
of a major (10/25) process or of a major (10/25) process or production unitproduction unit
What is case-by-case What is case-by-case MACT? Cont’d.MACT? Cont’d.
Implemented through Implemented through preconstruction permit preconstruction permit programs in generalprograms in general
What is the MACT What is the MACT Hammer?Hammer?
112(j) of the CAA requires major 112(j) of the CAA requires major sources to submit a permit sources to submit a permit application proposing source-application proposing source-specific MACT if the EPA misses specific MACT if the EPA misses a scheduled promulgation date a scheduled promulgation date by 18 mos.by 18 mos.
May 8, 2003 ruleMay 8, 2003 rule Requires the application to be Requires the application to be
submitted 60 days after EPA submitted 60 days after EPA misses a recently negotiated misses a recently negotiated scheduleschedule
http://www.epa.gov/ttn/atw/http://www.epa.gov/ttn/atw/112j/112j/
112(j)112(j)
Conditions of the MACT Conditions of the MACT determination must be determination must be incorporated into the Title V incorporated into the Title V operating permit by the operating permit by the permitting authoritiespermitting authorities
Just a little reviewJust a little review How many listed HAPs are How many listed HAPs are
there?there? What is the MACT floor?What is the MACT floor? What is a major source of HAPs?What is a major source of HAPs? What types are subject to What types are subject to
112(g)?112(g)?