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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

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


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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.


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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


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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


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EPA Retains Primary Authority MACT Standards:

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


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EPA Retains Primary Authority: No Known Sources in PA MACT Standards:

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


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Draft Implementation Agreement MACT Standards:

  • 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


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Compliance Determination Plan MACT Standards:

  • 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


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Modified Compliance Monitoring Strategy (CMS) Plan MACT Standards:

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.


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Compliance Assistance Emphasis MACT Standards:

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


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Next Steps MACT Standards:

  • 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.


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Next Steps MACT Standards:

  • 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.


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Questions/Comments? MACT Standards:

Thank You…..!

Ronald Davis

Chief, Div. of Compliance and Enforcement

Phone: 717-772-3369

[email protected]


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