The Wonderful World of HAP Regulations Genevieve Damico U.S. EPA, Region 5

Agenda Alphabet soup What are the regulated HAPs What are MACT standards Status of MACT

Agenda Cont’d. What is case-by-case MACT What is the MACT Hammer May 8, 2003 rule Review

Alphabet Soup 112(a) - Definitions 112(b) - List of Pollutants 112(c) - List of Source Categories 112(d) - Emission Standards

Alphabet Soup 112(e) - Schedule for Standards and Review 112(f) - Standards to Protect Health and the Environment (Residual Risk Program)

Alphabet Soup 112(g) - Modifications, Construction, and Reconstruction 112(h) - Work Practice Standards

Alphabet Soup 112(i) - Schedule for Compliance for New Sources, Early Reduction Program 112(j) - Equivalent Emission Limitation by Permit "MACT Hammer"

Alphabet Soup 112(k) - Urban Air Toxics Strategy 112(l) - State Programs: Delegation of Implementation & Enforcement Authority

Alphabet Soup 112(m) - Atmospheric Deposition to Great Lakes/Coastal Waters-Reports to Congress 112(n) - Studies: Utilities, Coke Ovens, POTWs, Mercury, Hydrogen Sulfide

Alphabet Soup 112(o) - National Academy of Sciences Study on Risk Assessment 112(p) - Mickey Leland National Urban Air Toxics Research Center

Alphabet Soup 112(q)-Savings Provision 112(r)-Prevention of Accidental Releases 112(s)-Periodic Reports on Measures Taken to Implement Section 112

What are the regulated HAPs? Listed in 112(b) 188 HAPs

What are the regulated HAPs? (Cont’d.) Air toxics are those pollutants that are known or suspected of causing cancer or other serious health effects, such as developmental effects or birth defects

What is a MACT standard? Technology based standard Source Category specific

What is a MACT standard? Cont’d. No less stringent than the top 12% controlled sources in a particular source category (the MACT floor)

What is a MACT standard? Cont’d. Most apply to major sources of HAPs (10 tpy of a particular HAP/25 tpy of an aggregate of HAPs)

http://www. epa. gov/ttn/atw/ eparules http://www.epa.gov/ttn/atw/ eparules.html (See next page in your handouts for table.)

MACT CFR Sub Parts Final Federal Register Compliance Date Project Lead Compliance Lead Aerospace Industry GG 9/01/95 (60FR45948) 9/01/98 Barbara Discoll 919-541-1051 Driscoll.barbara@epa.gov Len Lazarus 202-564-6369 Lazarus.leonard@epa.gov

Status of MACT 89 promulgated 5 proposed (This total includes the MON MACT as a single category.)

Future of MACT U.S. EPA is going back to the promulgated MACT and evaluating whether or not further reductions are necessary based on a risk assessment

What is case-by-case MACT? 112(g) of the CAA Construction or reconstruction of a major (10/25) process or production unit

What is case-by-case MACT? Cont’d. Implemented through preconstruction permit programs in general

What is the MACT Hammer? 112(j) of the CAA requires major sources to submit a permit application proposing source-specific MACT if the EPA misses a scheduled promulgation date by 18 mos.

May 8, 2003 rule Requires the application to be submitted 60 days after EPA misses a recently negotiated schedule http://www.epa.gov/ttn/atw/112j/

112(j) Conditions of the MACT determination must be incorporated into the Title V operating permit by the permitting authorities

Just a little review How many listed HAPs are there? What is the MACT floor? What is a major source of HAPs? What types are subject to 112(g)?