EPA-456/R-97-003
September 1997
http://www.epa.gov/ttn/uatw
MACT
IMPLEMENTATION
STRATEGY
U S Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, Uin noor
Chicago, IL 60604-3590
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
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Acknowledgments
Members of the Air Toxics Implementation Strategy Development Team, Advisors, and
special participants contributing to the preparation of this document are:
ATIS Development
Team Member
Brian Beals
Karen Blakemore
Belinda Breidenbach
Bob Colby
Deborah Elmore
Charlie Garlow
Kent C. Hustvedt
Bliss Higgins
Vasu Kilaru
Linda Lay
Sheila Milliken
Doug Neeley
Lee Page
Office
EPA Region IV
Louisiana Department of Environmental Quality (DEQ)
Office of Enforcement and Compliance Assurance/Office of
Compliance
Association of Local Air Pollution Control
Officials/Chattanooga/Hamilton County Air Pollution Control
Bureau
Information Transfer and Program
Integration Division/Information Transfer Group
Office of Enforcement and Compliance Assurance/Office of
Regulatory Enforcement
Emission Standards Division/Waste and Chemical Processes
Group
The State and Territorial Air Pollution Program
Administrators/Louisiana DEQ
Emissions, Monitoring and Analysis Division/Air Quality Trends
Analysis Group
Office of Enforcement and Compliance Assurance/Office of
Regulatory Enforcement
Information Transfer and Program Integration Division/Integrated
Implementation Group
EPA Region IV
EPA Region IV
11
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ATIS Development
Team Member
Acknowledgments - Continued
Office
Joanna Swanson
Sara Terry
Tony Wayne
Gil Wood
Advisors
Karen Blanchard
Racqueline Shelton
ATIS Development
Special Participant
Julie Andresen
Phillip Barnett
Gerri Pomerantz
Andy Smith
Ingrid Ward
Mary Ann Warner
Information Transfer and Program Integration Division/Operating
Permits Group
Office of Air Quality Planning and Standards/Planning, Resources
and Regional Management Staff
Emission Standards Division/Policy, Planning and Standards
Group
Information Transfer and Program Integration Division/Program
Review Group
Office
Information Transfer and Program Integration Division/Integrated
Implementation Group
Information Transfer and Program Integration Division/Program
Review Group
Office
Information Transfer and Program Integration Division/Program
Review Group
EPA Region IV
Information Transfer and Program Integration Division/Program
Review Group
Information Transfer and Program Integration Division/Program
Review Group
Information Transfer and Program Integration Division/Program
Review Group
Information Transfer and Program Integration Division/Program
Review Group
in
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Table of Contents
Section Page
Acknowledgments ii
List of Acronyms and Abbreviations vii
Glossary ix
1.0 Introduction 1-1
1.1 Purpose of this Document 1-3
1.2 Organization of this Document 1-3
1.3 Strategy Review and Measuring Success 1-4
2.0 Roles And Responsibilities Of Implementors 2-1
3.0 Systematic Communication 3-1
3.1 Information Exchange 3-2
3.2 Questions and Reaching Resolution 3-3
3.3 Scheduling 3-4
3.4 Tracking 3-5
4.0 Elements of a Successful Implementation Strategy 4-1
4.1 Education 4-1
4.2 Identifying the Source Population Subject to the MACT Standard 4-3
4.3 Outreach 4-4
4.4 Small Business Needs 4-6
4.5 Compliance Assurance 4-6
4.6 Enforcement 4-9
4.7 Reference Materials 4-9
4.8 Other 4-10
4.8.1 Resources 4-10
4.8.2 Permitting 4-11
5.0 Development of a Specific MACT Implementation Plan 5-1
5.1 Assessment of MACT Standards 5-2
5.1.1 Baseline Implementation Materials and Enhanced
Implementation Materials 5-2
5.1.2 Interview with MACT Development Team and
Representative Implementors 5-4
5.1.3 Diagnostic Questionnaire 5-5
5.1.4 Flow Charts for Enhanced Efforts 5-6
5.2 The Tool Development Agreement 5-6
5.3 Additional Elements of a Specific MACT Implementation Plan 5-8
IV
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Table of Contents (continued)
Appendices
Appendix A. Interview Questions for MACT Development Team and Implementors
Appendix B. Tool Development Agreement
Appendix C. Cost Estimates for Education and Outreach
Appendix D. Unified Air Toxics Website Information
Appendix E. AIRS Facility Subsystem Information
Appendix F. Example Specific Model Implementation Plan (for Ethylene Oxide Commercial
Sterilizers MACT Standard)
Appendix G. Source Identification Cookbook
Appendix H. Example Inspection Checklists
HI. Multimedia Inspection Checklist for Dry Cleaning Facilities
H2. Inspection Checklist for Chromium Electroplating and Anodizing
Appendix I. Contacts
11. Regional Air Toxics Coordinators
12. OAQPS and OECA NSPS and NESHAP Contacts
Appendix J. Small Business Regulatory Enforcement Fairness Act (SBREFA)
Appendix K. Master Compliance Timeline for Part 63 NESHAP
Appendix L. MACTRAX
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List of Tables
Page
1-1 Primary Implementation Roles During MACT Processes 1-6
2-1 OAQPS Roles and Responsibilities 2-4
2-2 OECA Roles and Responsibilities 2-7
2-3 Regional Office Roles and Responsibilities 2-8
2-4 State/Local/Tribal Roles and Responsibilities 2-9
5-1 Model Tool Development Agreement 5-17
List of Figures
1-1 A Roadmap to Successful MACT Implementation 1-7
3-1 Many Opportunities for Information Exchange 3-6
3-2 Communication Agenda 3-7
3-3 Example MACT Standard Implementation Timeline 3-8
3-4 Implementation Issue Resolution Process 3-10
5-1 Process for Developing a SMIP 5-10
5-2 Questionnaire for Determining Whether Materials Beyond the Baseline Level
are Needed 5-11
5-3 Flow Chart For Determining If Enhanced Technical Training Is Necessary 5-13
5-4 Flow Chart For Determining If Enhanced Source ID/Notification Is Necessary . 5-14
5-5 Flow Chart For Determining If Enhanced Public Outreach Is Necessary 5-15
5-6 Flow Chart For Determining If Enhanced Small Business Assistance Is
Necessary 5-16
VI
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List of Acronyms and Abbreviations
AFS
AIRS
AQSSD
AXIS
CBEP
EMAD
ESD
ITPID
MACT
MACTRAX
MWC
MWI
NESHAP
NETI
OAQPS
OECA
OGC
ORE
PRO
PRRMS
PTE
AIRS Facility Subsystem
Aerometric Information Retrieval System
Air Quality Strategies and Standards Division
Air Toxics Implementation Strategy
Community-Based Environmental Programs
Emissions Monitoring and Analysis Division
Emission Standards Division
Information Transfer and Program Integration Division
Maximum Achievable Control Technology
MACT Tracking System
Municipal Waste Combustion
Medical Waste Incineration
National Emission Standards for Hazardous Air Pollutants
National Enforcement Training Institute
Office of Air Quality Planning and Standards
Office of Enforcement and Compliance Assurance
Office of General Counsel
Office of Regulatory Enforcement
Program Review Group
Planning, Resources, and Regional Management Staff
Potential to Emit
vn
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List of Acronyms and Abbreviations (continued)
RATC Regional Air Toxics Coordinator
RO Regional Office
SBAP Small Business Assistance Program
SBREFA Small Business Regulatory Enforcement Fairness Act
SMIP Specific MACT Implementation Plan
STAPPA/ALAPCO State and Territorial Air Pollution Program Administrators/Association of
Local Air Pollution Control Officials
TDA Tool Development Agreement
TTN Technology Transfer Network
vm
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GLOSSARY
Air Toxics - Any air pollutant for which a national ambient air quality standard (NAAQS) does
, not exist (i.e., excluding ozone, carbon monoxide, PM-10, sulfur dioxide, nitrogen dioxide, and
lead) that may reasonably be anticipated to cause cancer, developmental effects, reproductive
dysfunctions, neurological disorders, heritable gene mutations or other serious or irreversible
chronic or acute health effects in humans.
Delegation - The act of conferring upon a state or local agency, the ability to implement and
enforce federal standards and requirements. The EPA retains concurrent enforcement authority.
Education - Activities, materials, and tools prepared mainly to help the implementors
understand the standard, locate sources, or otherwise implement the standard.
Enabling Materials - Activities, items, or tools prepared mainly for the industry being
regulated.
Implementation - Putting into action, carrying out, and completing the activities that promote
compliance with the MACT standard.
Implementation Materials - Activities, items, or tools prepared mainly for implementors with
specific information about the standard and the source being regulated.
Implementation Plan - A plan of action designed to promote compliance with the MACT
standard by identifying concrete measures, including preparation of implementation materials.
Implementors - The government agencies responsible for ensuring compliance with the MACT
standard or its approved equivalent.
MACT Partnership - An agreement between the EPA and a region/state/local agency or tribal
entity to share the responsibility of MACT standard development. EPA works with STAPPA,
ALAPCO and others to identify opportunities for partnerships for source category specific
regulations. The "Share-a-MACT" process is led by EPA with contribution from state and local
agencies and industry. The "Adopt-a-MACT" process is led by a region, state or local agency or
tribal entity with minimal contributions from EPA headquarters. EPA headquarters reviews,
approves, and promulgates the standard.
Maximum Achievable Control Technology (MACT) Standards - Emissions limitations
developed under section 112(d) of the Clean Air Act (National Emissions Standards for
Hazardous Air Pollutants). The limitations are based on the best demonstrated control
technology or practices in similar sources to be applied to major sources emitting one or more of
the listed toxic pollutants. This term is sometimes incorrectly used as a colloquialism to refer to
other technology-based emissions standards developed by the Emission Standards
Division/OAQPS.
IX
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Outreach - Activities, materials, or tools prepared mainly to locate affected industries or to
educate those industries and the general public.
SBREFA Guidance Document - A document to help small businesses understand the
requirements of a standard. Such documents are required by the Small Business Regulatory
Enforcement Fairness Act when a standard may have significant effects on small businesses. See
Appendix J.
Specific MACT Implementation Plan (SMIP) - A specific MACT Implementation Plan that
has been agreed upon by all involved parties, which clearly identifies tools, implementation
materials, roles and responsibilities of implementors, and a schedule for the implementation of a
MACT standard. Contains a Tool Development Agreement.
Tool Development Agreement (TDA) - A table of implementation materials potentially
developed for each MACT standard with assignment of the lead group for each item and
participants in the development of each item.
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1.0 INTRODUCTION
Section Summary
The purpose of this document is to present a strategy for activities that, if
followed, should be helpful in ensuring that MACT standard emissions
reductions are achieved This strategy is not mandatory, but does represent
the collective wisdom of many regulators and implementors as to activities
that should be worthwhile. Many of the activities are those that EPA, states
and local agencies have already been using successfully for some standards
and should be successful for other standards as resources allow. This is a
"living" document. That is, as more implementation experience is obtained,
EPA will make appropriate revisions. Communication and coordination
among the implementors is essential.
Section 112 of the Clean Air Act (CAA) has nineteen subsections [section 112(a) through
section 112(s)] with requirements pertaining to protection of the public and the environment
from adverse effects resulting from the use of and exposure to air toxics . The subsections
include many specific requirements regarding federal, state, local, and tribal programs (e.g.,
section 112(1), which applies to development and approval of state air toxics programs and
delegation of federal authorities; or section 112(r), which applies to accidental releases of air
toxics).
Separate from the effort to prepare this document, the Office of Air Quality Planning and
Standards (OAQPS) has developed a draft air toxics management model which addresses the
interrelationships of these nineteen subsections and their requirements. The draft model
incorporates setting goals, identifying necessary emission reductions, implementing emission
reduction and pollution prevention plans, and evaluating results. Currently, OAQPS is in the
process of developing the goals and performance measures. Other major efforts by OAQPS
include integration of section 112 air toxics requirements with other CAA programs such as the
Title V Operating Permit Program and the New Source Review/Prevention of Significant
Deterioration Program (NSR/PSD).
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The Air Toxics Implementation Strategy (ATIS) development team was originally
formed to develop a comprehensive plan of activities that should be helpful for implementors to
ensure that the emissions reductions from standards developed under section 112 are actually
achieved. However, since the air toxics management model is still draft and the goals and
performance measures are still under development, the team decided this document should focus
on the implementation of Maximum Achievable Control Technology (MACT) standards, the
cornerstone of the federal air toxics program. That is, two very high priorities for EPA are the
development and implementation of MACT standards. Many of the elements in the strategy are
intended to add administrative efficiencies and reduce duplicative efforts in the MACT
implementation process. Some of the early tasks of the ATIS development team focused on
developing checklists and other tools to ensure that implementation aspects are fully considered
during the development of MACT standards (e.g., efficient and effective integration with Title V
and other programs). However, those tools are not the focus of this document and thus, are not
appended.
Rather, this document focuses on several issues related to MACT implementation,
including the development of implementation plans, communication and coordination issues, and
allocation of different implementation tasks to specific federal, state, local, tribal, and other
entities. This document is available to all affected government entities and may serve as a
template or model for how the various stakeholders may work together to effectively and
efficiently implement MACT standards. Table 1-1 provides a general overview of different
phases of MACT development and implementation and identifies the primary roles of the
responsible entities during each phase. Figure 1-1 presents graphically the MACT
implementation process.
Other important air toxics issues such as integration of MACT implementation with other
air toxics programs (e.g., residual risk standards) and integration of air toxics programs with
criteria pollutant programs are not addressed in this document, but rather will be discussed in a
future document.
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1.1 Purpose of this Document
The purpose of this document is to provide a strategy for successful implementation of
MACT standards. This document provides helpful information for efficient and effective
promotion of compliance with MACT standards or their approved equivalents, by helping
implementors decide what should be done, who should do it, and when it should be done. This
document was developed for implementors (government entities tasked with ensuring
compliance with MACT standards); however, industry and the public may find some of the
information useful as well. This document includes recommendations for how to prepare a
Specific MACT Implementation Plan (SMTP) for a MACT standard. This document describes
the elements of such plans and roles and responsibilities of the implementors. It also includes a
systematic communication process for promoting an adequate understanding of the MACT
standards and for coordinating implementation activities. This document is intended to assist
implementors by outlining critical success factors and by identifying recommended materials and
activities.
These recommendations are flexible. This document provides information for the
implementors to identify appropriate implementation activities and ways to accomplish these
activities. EPA anticipates that the implementors will consider the information presented in this
document while they structure their strategy to meet their specific needs. For example, a
relatively simple standard affecting few sources in only one state may require less effort in
development of outreach brochures and other implementation tools than a complex standard with
numerous, small, affected sources located in many states.
1.2 Organization of this Document
Section 2.0 of this document describes the roles and responsibilities of implementors and
Section 3.0 briefly describes communications that need to occur systematically for
implementation efforts to have the highest likelihood of success. Section 4.0 describes
implementation elements that should be considered when developing a SMIP. Section 5.0
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describes a method for determining which implementation elements are appropriate for a SMIP
and describes the preparation of a Tool Development Agreement (TDA). Table and figures are
found at the end of the appropriate section to avoid interruptions in the text. Example interview
questions are included (see Appendix A) to help in deciding which implementation materials and
activities are appropriate for each MACT standard.
Reference materials and examples that implementors may find useful when developing
SMIPs are included in the appendices of this document. For example, a SMIP for the Ethylene
Oxide Commercial Sterilizers standard is included, as well as inspection checklists for dry
cleaning and chromium electroplating facilities.
1.3 Strategy Review and Measuring Success
The strategy presented in this document was developed by the ATIS development team
along with the managers of their respective organizations as participants, and others as informal
contributors. This strategy is considered a "living document" and comments are welcome. In
addition, information on air toxics implementation successes and example implementation tools
that can be shared with others is especially welcome. EPA and STAPPA/ALAPCO strongly
encourage state, local, and tribal entities to share their implementation tools and place them on
the EPA/STAPPA/ALAPCO Unified Air Toxic Website (see Appendix D for further information
about the website). Comments and information may be sent to the following address:
Mr. Gil Wood
Program Review Group (MD-12)
Information Transfer and Program Integration Division
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
Email: wood.gil@epamail.epa.gov
Implementation of MACT standards is included in the EPA Annual Performance Plans
and Annual Program Performance Reports, as required by the Government Performance and
Results Act and as a priority in the Performance Partnership Agreements between EPA and the
states. Mechanisms are being developed to measure and track implementation results. Also,
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EPA will evaluate the usefulness of this document, and update or revise it as needed. A critical
success factor for implementation activities is that the affected sources and implementors
understand the rules, policies, and protocols they are required to implement, including the
compliance requirements and when necessary, the appropriate enforcement response policies.
Thus, the availability of tools to assist in gaining this understanding and in assuring compliance
is an important part of this strategy. This document serves as one of the tools and as a reference
to other tools that should assist the implementors in their efforts.
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Table 1-1. Primary Roles During MACT Development and Implementation
Phase
Data Gathering
Proposal
Promulgation
Compliance
Continuous Compliance
Headquarters Role
Form MACT development
team
Determine data needs
Develop MACT
Help develop SMIP
Lead preparation of TDA
Complete development of
MACT
Track implementation
Provide guidance on residual
risk
Regional Office Role
Participate in MACT
Partnerships and Work
Groups
Participate in MACT
Partnerships and Work
Groups
Review/Comment
Lead development of SMIP
Participate in preparation of
TDA
Encourage delegation
Track implementation
Track compliance
Enforce, as needed
State/Local/Tribal Role
Participate in MACT
Partnerships and Work
Groups
Participate in MACT
Partnerships and Work
Groups
Review/Comment
Help develop SMIP
Plan outreach efforts
Participate in preparation of
TDA
Implement
Conduct outreach activities
Conduct compliance
assistance activities
Ensure compliance
Track compliance
Inspect
Enforce, as needed
Private Sector
Provide representative data
Review/Comment
Participate in preparation of
TDA
Develop compliance plan
Submit initial notification
Comply
Continuously comply
Keep records, monitor, and
certify annually
SMIP = Specific MACT Implementation Plan
TDA = Tool Development Agreement
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Clean Air Act (CAA)
Regulatory
Authority
Development of MACT Standards
that can be Implemented _
Efficiently and Effectively I
and that Achieve the
Requirements of the CAA
Consistent with EPA Goals
Identification
and Assignment
of Roles and
Responsibilities
for Implementors
Development of
Specific MACT
Implementation
\ Plans
Continuation of
Implementation
Activities
Development of
Implementation
Materials in
Accordance with Tool
Development Agreement
Compliance
Assistance
Provided,
as Needed
Compliance
With
MACT
Standard
Enforcement
Activities,
as Necessary
Note: Systematic communications among EPA, state, and local agencies, tribes, the regulatedi
community, and the public must occur to maximize successful implementation.
Figure 1-1. A Roadmap to Successful MACT Implementation
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2.0 ROLES AND RESPONSIBILITIES OF IMPLEMENTORS
Section Summary
This section identifies key players in the implementation process and defines
their roles and responsibilities.
This section provides recommended general roles and responsibilities of implementors in
the MACT implementation process. It is important for the implementors to communicate clearly
with each other and agree to specific roles and responsibilities for each MACT standard.
Regardless of who is ultimately responsible for each implementation task, it is important to
thoroughly identify the tasks to be completed, who will complete them, and the schedule for
completing them. The Office of Air Quality Planning and Standards (OAQPS) Program Review
•Group (PRO) will take the lead in ensuring that a timely and systematic process is established.
Also during MACT development, PRO will conduct an interview with the MACT development
team lead and representative implementors using the list of questions presented in Appendix A or
similar questions to make a preliminary determination of expected implementation needs.
The details of this section are primarily contained in Tables 2-1 through 2-4, which
identify and assign the numerous roles and responsibilities recommended to implement a MACT
standard. Although the implementors may agree to different roles and responsibilities for a
specific MACT, the rationale behind these recommended roles and responsibilities is explained
in this section.
Successful implementation of MACT standards is a large undertaking and requires
significant time and resources. First, there should be well-defined emission standards that
achieve the requirements of the CAA, are consistent with EPA goals, and are designed to be
implemented as efficiently and effectively as possible. All of the stakeholders, but especially the
regional offices and state, local, and tribal entities, should consider implementation aspects while
the standards are being developed. Ideally, there will be agreement among all of the
stakeholders on the standards and implementation aspects, and there will be a good faith effort
2-1
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by industry to comply. To bridge the gap between MACT standard development and
industry-wide compliance, implementors (in particular EPA [OAQPS, Office of Enforcement
and Compliance Assurance (OECA), Regional Offices], and state, local, and tribal entities)
should complete three broad-based tasks:
• Identify the affected regulated sources;
• Inform the affected regulated sources so that they may determine which
requirements apply to them, and understand how to comply with the
requirements; and
• Monitor and assure compliance.
The ultimate responsibility for completing these three tasks is generally delegated to the
state, local, or tribal entity. Considering the burden on the implementors and the similarity of
their needs, it is prudent for them to share the development of implementation tools and other
information, where possible. The primary groups typically responsible for MACT standard
implementation support are:
Emission Standards Division (ESD)/OAQPS/EPA;
• Information Transfer and Program Integration Division (ITPID)/OAQPS/EPA;
• Emissions Monitoring and Analysis Division (EMAD)/OAQPS/EPA;
• EPA Regional Offices;
Office of Regulatory Enforcement (ORE)/OEC A/EPA;
• Office of Compliance (OC)/OECA/EPA; and
• Air Office of state, local, and tribal entities (including both environmental
agencies and small business assistance offices).
To help the permitting authorities ensure that the three broad-based implementation tasks
mentioned above are successfully completed, the tasks are further subdivided into well-defined
subtasks that are assigned to specific parties. These subtasks and assignments are detailed in
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Table 2-1, OAQPS Roles and Responsibilities; Table 2-2, OECA Roles and Responsibilities;
Table 2-3, Regional Office Roles and Responsibilities; and Table 2-4, State and Local Offices
Roles and Responsibilities. The roles and responsibilities detailed in Tables 2-1 through 2-4
focus primarily on activities that take place during or soon after MACT standard development.
Note that while Tables 2-1 through 2-4 are detailed and explicit, they are intended to be
flexible. That is, the implementors should carefully consider all of the recommendations in this
MACT implementation strategy and agree on changes as appropriate to fit their specific
circumstances. Nonetheless, these tables provide an initial plan of action that identifies subtasks
and assignments currently envisioned for implementation of a MACT standard. Implementor
experiences have demonstrated that a detailed initial plan, ongoing review of execution of the
plan, and feedback mechanisms for adjustments to the plan are prudent for effective
implementation.
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Table 2-1. OAQPS Roles And Responsibilities
Activities
Develop MACT
Prepare SBREFA Compliance
Assistance Guides and other
small business outreach
materials for area source
standards and small businesses
Prepare a Specific MACT
Implementation Plan (SMIP) for
each standard that includes:
- How to identify sources
- Summary of requirements
- Applicability tables
- Compliance checklist
- Permit requirements
Develop training materials and
classes on newly promulgated
standards
Issue specific implementation
guidance where needed (e.g.,
section 1 1 l(d)/129 State Plans
for Municipal Waste
Combustors)
ITPID
Provides input on:
- Integration with other
programs, as needed
- Potential to Emit
- § 11 2(1) issues
Provides input and
coordinates with other
Small Business assistance
efforts and assists with
distribution of materials
Leads team effort to
develop SMIP according
to MACT Implementation
strategy that clarifies roles
and lays out process for
setting priorities and
systematic communication
Provides vehicle for
training and develops
course materials
Prepares guidance
(documents or policy
memoranda)
ESD
Develops MACT's that
achieve the requirements
of the CAA, are consistent
with EPA goals, and are
designed to be
implemented as
effectively and efficiently
as possible
Develops documents with
input from OECA on
compliance assistance
activities
Provides team member
Ensures technical
accuracy of SMIP
Provides technical experts
to lecture and review
materials
Provides technical experts
to participate in
development of
supporting guidance
EMAD
Provides input on test
methods and monitoring
Provides input, as
necessary (e.g., source
testing and monitoring)
Provides team member
Provides input on source
test methods and
monitoring
Provides technical experts
to lecture and review
materials relating to
source testing and
monitoring
Provides technical experts
as appropriate
AQSSD
Reviews MACT data
for coordination with
future residual risk
standards such as
Great Waters
Programs, Urban Air
Toxics Strategy, etc.
Provides input, as
necessary (e.g.,
health and
environmental
effects)
Provides team
member
Provides scientific
experts to lecture and
review materials
relating to health and
environmental
effects
Provides experts to
answer health and
environmental
effects questions,
when needed
PRRMS
Promotes Regional
office and state
participation through
memorandum of
agreement and
performance
partnerships
Provides input, as
necessary (e.g.,
planning and resources)
Provides team member
Provides development
plan, expertise, and
Regional office
coordination (e.g.,
Desk Officers)
Coordinates with ITPID
on policy and guidance
availability
Desk Officer assures
communication with the
Regional office
K)
AQSSD = Air Quality Strategies and Standards Division
EMAD = Emissions, Monitoring and Analysis Division
ESD = Emission Standards Division
ITPID = Information Transfer and Program Integration Division
OECA = Office of Enforcement and Compliance Assurance
PRRMS = Planning, Resources, and Regional Management Staff
SBREFA = Small Business Regulatory Enforcement Fairness Act
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Table 2-1. OAQPS Roles And Responsibilities (continued)
Activities
Coordinate efforts with other
implementing offices such as
OECA, Regional offices, states,
locals, and tribes
Report on National Progress in
meeting goals
Develop and maintain
communication networks
ITPID
Identifies obstacles to
implementation, takes
steps to overcome
obstacles, facilitates
conference calls,
workshops, visits, etc.
Prepares reports and
provides system operator
for information
management system
Helps develop goals,
review progress, refine
goals, and overcome
obstacles
Provides and maintains
Internet website and
coordinates responses as
needed
ESD
Participates as needed,
answers questions on
technical and policy
aspects of rules
Establishes goals for
MACT standards and
performance measures
- determines what reports
are needed
- receives reports
Leads development of
goals and priorities,
reviews progress, refines
goals, and overcomes
obstacles. Ensures
coordination of priorities
among program offices,
Regions, OECA and
states, local and tribal
entities.
Provides information on
MACT for website
Responds to questions
EMAD
Participates as needed,
provides technical
expertise as appropriate
Helps develop goals,
review progress, refine
goals, and overcome
obstacles
Provides information for
website
Responds to questions
AQSSD
Participates as
needed,
provides technical
expertise, as
appropriate
Helps develop goals,
review progress,
refine goals, and
overcome obstacles
Provides information
for website
Responds to
questions
PRRMS
Participates as needed,
provides input on
Regional office, state,
local and tribal needs
Helps develop
information systems
and encourages
participation of regions,
states, local and tribal
entities
Helps develop goals,
review progress, refine
goals, and overcome
obstacles
Provides information
for Internet websites in
coordination with
ITPID
N)
AQSSD «= Air Quality Strategies and Standards Division
EMAD * Emissions, Monitoring and Analysis Division
ESD = Emission Standards Division
ITPID * Information Transfer and Program Integration Division
QECA * Office of Enforcement and Compliance Assurance
PRRMS = Planning, Resources, and Regional Management Staff
SBREFA ** Small Business Regulatory Enforcement Fairness Act
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Table 2-1. OAQPS Roles And Responsibilities (continued)
Activities
Prepare enabling documents,
and implementation documents
and tools
Ensure MACT Delegations and
approval of state rules and
programs under Section 1 12(1)
Participate in monthly Air
Toxics Implementation calls
with EPA Regions to exchange
relevant experiences, to help
other implementors, and to
resolve issues
Provide guidance on Title V
permitting and other means to
ensure emission reductions
ITPID
Coordinates the
preparation of
implementation documents
and tools
Reviews for "Readability"
Coordinates Program and
Rule Equivalency reviews
with other Divisions,
OECA, and Regional
offices
Coordinates EPA
participation in monthly
calls
Provides guidance on
permitting and other
means to ensure emissions
reductions
ESD
Develops enabling
documents for industry, as
necessary
Provides input to ITPID
for implementation
documents and tools
Provides expertise on
MACT rule specifics and
equivalency
Participates in monthly
calls as needed
Provides expertise on
MACT rule specifics and
flexibility
EMAD
Provides input on source
testing and monitoring as
appropriate
Provides expertise on test
methods and monitoring
as needed
Participates in monthly
calls as needed
Provides expertise on test
methods and monitoring
AQSSD
Provides input on
health and
environmental
effects as appropriate
Provides expertise as
needed
Participates in
monthly calls as
needed
Provides expertise as
needed
PRRMS
Provides input on
readability and
relationship to overall
planning and
management
Coordinates with
Regional offices
Participates in monthly
calls as needed
Coordinates with
Regional offices
K)
AQSSD = Air Quality Strategies and Standards Division
EMAD = Emissions, Monitoring and Analysis Division
ESD = Emission Standards Division
ITPiD = Information Transfer and Program Integration Division
OECA = Office of Enforcement and Compliance Assurance
PRRMS = Planning, Resources, and Regional Management Staff
SBREFA = Small Business Regulatory Enforcement Fairness Act
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Table 2-2. OECA Roles And Responsibilities
Office Of Regulatory Enforcement
(ORE)
Participates in development of goals, priorities, and
tracking of results.
Develops enforcement response policy for toxics,
including penalty policies, as needed
Provides enforcement assistance to Regional offices
Answers questions from Regional office on applicability
determinations
Supports development of section 1 12 rules, including
MACT standards to ensure enforceability
Participates in regular calls and meetings with OAQPS
and Regional offices
Office Of Compliance
(OC)
Participates in development of goals, priorities, and
tracking of results.
Provides compliance assistance to Regional offices
Reviews and provides input on SBREFA guides and
enabling documents, as appropriate
Provides compliance checklists and implementation
manuals for inspectors
Answers questions from Regional offices on
applicability determinations (coordinates with OAQPS
and OGC as appropriate). Compiles answers on
Applicability Determination Index (ADI) on website
Supports development of MACT standards to ensure
enforceability
Participates in regular calls and meetings with OAQPS
and Regional offices
Tracks compliance in conjunction witli Regional
offices, states, local and tribal entities
National Enforcement Training Institute
(NET!)
Participates in development of goals, priorities, and
tracking of results.
Provides enforcement training
Conducts inspector training
K>
OAQPS = Office of Air Quality Planning and Standards
OGC = Office of General Counsel
SBREFA = Small Business Regulatory Enforcement Fairness Act
-------
Table 2-3. Regional Office Roles And Responsibilities
Activities
Processes 112(1) submittals
Delegates MACT standards
Conducts outreach to states and sources
Provides compliance assistance to states and sources
Ensures that agencies track and report compliance
Conducts inspections and takes enforcement actions
Implements standards and requirements prior to delegation and where states
and tribes do not take delegation
Makes 1 12(g) determinations when necessary
Reviews state plans under section 112(d) and/or section 129
Works with OAQPS, OECA and states with program goals
Reviews Title V permits and other means to ensure MACT's are
implemented
Reports to Headquarters on status of program implementation
Provides guidance and responds to technical and policy questions from
states, local, and tribal entities on toxics-related issues
Provides assistance to states on applicability determinations
Submits determinations in appropriate format to Applicability Determination
Index
Assists Headquarters in rule and guidance document development, including
Adopt-A-MACT
Participates in monthly Air Toxics calls with OAQPS, OECA, other
Regional offices, and state, local, and tribal entities
Programs Branch
Processes submittals
Encourages delegation
Completes delegation
Tracks delegation
Conducts outreach as needed to states and
sources
Implements as necessary
Implements 112(g) as necessary
Reviews plans as necessary
Assists OAQPS, OECA, and states with goals
as necessary
Reviews permits and other means as necessary
Provides Headquarters reports on program
implementation
Provides assistance as necessary
Coordinates applicability determinations with
OECA, OAQPS, and OGC
Supplies Applicability Determination Index
information as necessary
Assists Headquarters as necessary widi rule and
guidance document development
Participates in monthly air toxics calls
Compliance Branch
Conducts outreach to states and sources
as needed
Provides compliance assistance to states
and sources as needed
Assists agencies with tracking and
reporting compliance
Inspects and enforces as necessary
Implements as necessary
Implements 1 12(g) as necessary
Reviews plans as necessary
Assists OAQPS, OECA, and states with
goals as necessary
Reviews permits and other means as
necessary
Provides assistance as necessary
Provides input to Programs Branch
Supplies Applicability Determination
Index information as necessary
Assist Headquarters as necessary with
rule and guidance development
Participates in monthly Air Toxics calls
OO
The apportioning of the activities within the regional office in this chart is an example that will vary according to the organizational structure of the specific entities.
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Table 2-4. State/Local/Tribal Roles And Responsibilities
Activities
Air Toxics Section
Permits Section
Small Business Assistance
Program
Enforcement/Surveillance
Section
Participate in MACT and other
Section 112 program
development activities
Provides expertise and real-
world experiences
Participates in possible pilot
testing of specific proposed
MACT's at Work Group
closure
Participates in Presumptive
MACT and Adopt-a-
MACT programs
Provides expertise and
real-world experiences
Provides expertise and
real-world experiences
Provides expertise and real-world
experiences
Review schedule of upcoming
regulations and requirements and
plan work load
Plans work load
Plans work load
Plans work load
Plans work load
Review regulations, fact sheets,
implementation guidance, and
other relevant information on the
STAPPA/ALAPCO/EPA Unified
Air Toxics Website.
Leads state activities and
efforts and requests input
from other sections as
needed
Provides input to Air
Toxics Section as needed
Provides input to Air Toxics
Section as needed
Provides input to Air Toxics Section
as needed
Delegate authority
Determines if delegation
will be requested
Coordinates with Regional
office
Requests delegation
- delegation agreement
- state rulemaking
Coordinates with Air
Toxics Section
NESHAP ~ National Emission Standard for Hazardous Air Pollutant
OECA = Office of Enforcement and Compliance Assurance
STAPPA/ALAPCO
State and Territorial Air Pollution Program
Administrators/Association of Local Air
Pollution Control Officials
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Table 2-4. State/Local/Tribal Roles And Responsibilities (continued)
Activities
Air Toxics Section
Permits Section
Small Business Assistance
Program
Enforcement/Surveillance
Section
Locate and identify sources
Uses procedures in Source
Identification Cookbook to
find sources
Coordinates with Regional
office to share information
Provides helpful
information to Air Toxics
Section
Assists in identifying sources
Provides assistance when necessary
Conduct outreach and training for
affected sources, as well as other
compliance assistance activities
After sources are identified,
- distributes EPA guidance
- coordinates with Small
Business Assistance
Program
- contacts sources
- surveys sources
Provides input to Air
Toxics Section
Sets up and provides input
and support in outreach and
training for small businesses
Visits sites
Provides assistance when necessary
to
i
o
Make applicability
determinations such as Potential
to Emit determinations
Same system as Part 61
NESHAP (i.e., coordinates
with other sections and
Regional office per
memorandum of
agreement)
Inputs information into the
Applicability Determination
Index on website
Develops compliance
tracking system
Coordinates with OECA
and regional office
Provides input to Air
Toxics Section
Provides assistance when
necessary
NESHAP = National Emission Standard for Hazardous Air Pollutant
OECA = Office of Enforcement and Compliance Assurance
STAPPA/ALAPCO = State and Territorial Air Pollution Program
Administrators/Association of Local Air
Pollution Control Officials
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Table 2-4. State/Local/Tribal Roles And Responsibilities (continued)
Activities
Air Toxics Section
Permits Section
Small Business Assistance
Program
Enforcement/Surveillance
Section
Make compliance determinations
and regulatory interpretations
Coordinates with
Enforcement Section and
Regional office
Tracks determination and
provides information to
Regional offices as
necessary
Provides input as
necessary
Coordinates with Air Toxics Section
and Regional office
Permit sources
Provides training and
information and answers
questions
Reviews permit prior to
approval
Writes permit
Provides assistance when
necessary
Reviews permit prior to approval
Make Section 112(g)
determinations
Develops state program and
implements it accordingly
Coordinates with Air
Toxics Section
Coordinates with Air Toxics
Section
Coordinates with Air Toxics Section
Conduct compliance inspections
Provides mechanism to
include sources in
inspection schedule
Provides training/assistance
when necessary
Reviews compliance
reports
Coordinates with EPA
Federal Small Business
Assistance Program contacts
to provide compliance
assistance
Conducts source inspections, writes
inspection report, and recommends
enforcement action
NESHAP = National Emission Standard for Hazardous Air Pollutant
OECA = Office of Enforcement and Compliance Assurance
STAPPA/ALAPCO
State and Territorial Air Pollution Program
Administrators/Association of Local Air
Pollution Control Officials
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Table 2-4. State/Local/Tribal Roles And Responsibilities (continued)
Activities
Air Toxics Section
Permits Section
Small Business Assistance
Program
Enforcement/Surveillance
Section
Take enforcement actions where
appropriate
Submits, follows through,
and tracks enforcement
requests to Enforcement/
Surveillance Section
Coordinates with Federal
Small Business Assistance
Program
Has no involvement in
enforcement activities
May give 90 days to 1 year
"corrective period"
Coordinates with Air Toxics Section
on recommended enforcement action
Takes enforcement action
N)
NJ
Review permit applications,
plans, and reports
Evaluate testing and monitoring
results, and compliance extension
waivers
Review initial notifications,
implementation plans, and
periodic reports
Assigns MACT standards
to staff
Reviews and tracks requests
and reports
Requests additional
information as needed
Recommends enforcement
as needed
Reviews applications and
issues construction/
reconstruction permits
Provides input when
necessary
Provides assistance in contacting
source or sharing knowledge of
standard as needed
Provide assistance to small
businesses
Coordinates with Small
Business Assistance
Program
Provides input as needed
Provides assistance as
needed
Provides assistance when necessary
NESHAP = National Emission Standard for Hazardous Air Pollutant
OECA = Office of Enforcement and Compliance Assurance
STAPPA/ALAPCO = State and Territorial Air Pollution Program
Administrators/Association of Local Air
Pollution Control Officials
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Table 2-4. State/Local/Tribal Roles And Responsibilities (continued)
Activities
Air Toxics Section
Permits Section
Small Business Assistance
Program
Enforcement/Surveillance
Section
Report to EPA Regional office on
progress of implementing
program and identify obstacles
Discusses with EPA
obstacles requiring
attention prior to submittal
of report
Prepares report
Coordinates with other
sections
Provides input to Air
Toxics Section as needed
Provides input to Air Toxics
Section as needed
Provides input to Air Toxics Section
as needed
to
Participate in monthly Air Toxics
Implementation calls with
Regional office and monthly calls
with STAPPA/ALAPCO to
exchange relevant experiences
and to help implementors resolve
issues
Coordinates and
participates in monthly calls
Participates in monthly
calls as needed
Participates in monthly calls
as needed
Participates in monthly calls as
needed
Track compliance and reports to
databases
Provides input to the
Enforcement/Surveillance
Section as needed
Provides input to the
Enforcement/Surveillance
Section as needed
Provides input to the
Enforcement/Surveillance
Section as needed
Leads state efforts to track
compliance
All of the activities presented here should be included in the roles of the state, local, and tribal entity office. The apportioning of the activities within the state,
local, or tribal offices in this chart is an example that will vary according to the organizational structure of the specific entities.
NESHAP ~ National Emission Standard for Hazardous Air Pollutant
OECA « Office of Enforcement and Compliance Assurance
STAPPA/ALAPCO
State and Territorial Air Pollution Program
Administrators/Association of Local Air
Pollution Control Officials
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3.0 SYSTEMATIC COMMUNICATION
Section Summary
This section discusses the protocol for successful MACT implementation
strategy communications, which include PRG's roles, including the lead for
coordinating implementation tool development activities, how information
should flow among stakeholders, the process to resolve issues, the process to
schedule and track progress, and the Regional Air Toxics Coordinator's roles
after promulgation.
This section describes the recommended Systematic Communication protocols necessary
for successful completion of the MACT implementation strategy. These recommended protocols
serve to ensure that stakeholders transfer critical information in a complete and timely manner.
The need for systematic protocols is underscored by several factors:
• The Air Toxics Program is broad-based, affecting numerous stakeholders in the
public, industrial, and regulatory sectors.
• The large number and variety of stakeholders makes communication inherently
difficult to manage; systematic communication will ensure the transfer of critical
information that might otherwise be lost via informal communication.
• The MACT standards will be written and implemented over several years; the lessons
learned during the development and implementation of early MACT standards will
facilitate the development and implementation of later MACT standards.
The following subsections describe the elements of the communication system and
provide suggestions for executing and monitoring individual information management tasks.
Prior to promulgation, the Program Review Group (PRO) has the primary responsibility for
planning and coordinating the communications process. They should encourage open and timely
communication among the responsible parties so that the implementors and their managers can
reach consensus on implementation activities.
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3.1 Information Exchange
Figure 3-1 schematically illustrates the pathways of information exchange in managing
MACT implementation issues. As shown in the figure, there are numerous participants in the
communication process, including EPA, regulated sources, state and local agencies, tribal
entities, and the public. Information flows to and from each of these entities throughout the
implementation process through such means as internal and external EPA documents, MACT
rule development dockets, the Federal Register, electronic bulletin board systems, electronic
mail, internet websites, technical assistance calls, public meetings, and live and videotaped
workshops.
While Figure 3-1 emphasizes that the information flows to and from many stakeholders,
Figure 3-2 shows what information is exchanged. Some of the items shown in Figure 3-2 (such
as monthly meetings of OAQPS Division Directors) are associated with the ongoing overall
management of air toxics programs, while other items (such as training and outreach) may be
associated with a specific MACT implementation effort. Regardless of whether the items shown
in Figure 3-2 are considered part of the overall management and communication system or part
of an individual MACT implementation effort, successful implementation rests on coordination
of these efforts. The EPA Regional Air Toxics Coordinators have agreed to serve as a team to
ensure good communication and to discuss and resolve issues as necessary among OAQPS,
OECA, OGC, regional offices and the state/local/tribal entities.
The EPA/STAPPA/ALAPCO Unified Air Toxics Website is an invaluable means for
information exchange. It provides air toxic pollution information in a centralized location on the
internet, and is a source of information for the general public, federal, state and local
governments, and sources. The housing of information in an easily accessible, centralized
location greatly encourages sharing information in order to reduce duplication of effort. The
Unified Air Toxics Website contains six different areas of information (Basic Facts, EPA Rules
and Implementation, Pollutants and Sources, Technical Resources, EPA Programs, and State and
Local Agency Programs) that are described in detail in Appendix D. All implementors should
3-2
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continually review the information on the website for possible applications to their planned tasks
and should make their own implementation tools available to others in order to maximize
efficiency and effectiveness.
3.2 Questions and Reaching Resolution
Before promulgation of a standard, ESD usually has the primary responsibility for
developing the standard, which includes responsibility for integrating issues related to Title V,
NSR/PSD, compliance and enforcement, etc. Upon agreement between ESD and PRO, PRO will
have the lead in coordinating the tool development efforts among the implementors for specific
MACT standards with the highest priority implementation needs.
After promulgation, the Regional Air Toxic Coordinators coordinate implementation
efforts, including the management of technical and policy questions from states/local/tribal
entities, and discussion with the MACT development teams leads and/or implementation teams.
It is expected that questions or issues may arise throughout the MACT implementation process.
These issues should be resolved at the lowest level possible, (e.g., among the active
implementors or the Regional Air Toxics Coordinators) but to the degree that they cannot be
resolved at one level, they should be elevated as quickly as possible to the level at which they
can be resolved.
Industry should direct their technical and policy questions to state and local agencies.
Most questions should be answered by the state and local agencies by reading the MACT
standard, enabling documents, and implementation documents. To the degree that additional
information or guidance is needed, the state and local agencies may in turn direct their questions
to EPA regional offices. The EPA regional office personnel should coordinate these responses
with their Regional Air Toxic Coordinators. The Regional Air Toxic Coordinators should
coordinate with the Regional Air Toxic Coordinator's Team and subsequently to the MACT
development team lead as necessary. OECA provides assistance to the Regional Air Toxic
3-3
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Coordinators, the regional offices, and state and local agencies for applicability determinations,
inspection coordination, and compliance support, when necessary.
This post-promulgation communication system is derived from the principle that
questions should be answered by the authorities closest to the affected parties, that is, those that
are most likely to know the details of the specific situation, including state and local rules and
policies that may be relevant. The resolution process should consider the communication system
described in this document to ensure that the roles and responsibilities of the implementors are
executed (see Tables 2-1 through 2-4). EPA expects most questions to be answered at the local,
state, tribal, or regional office levels. This process is shown graphically in Figure 3-4. If
necessary, the Air Toxics Task Force (key managers in OAQPS, OECA, OGC, regional offices,
and state/local/tribal entities) can assist in resolving issues across the stakeholder's offices and
has agreed to meet on an as-needed basis. Prior to standard promulgation, OAQPS has the lead
responsibility for ensuring that unresolved issues are presented to the Air Toxics Task Force,
when necessary. This would be the responsibility of the Regional Air Toxic Coordinators after
standard promulgation.
3.3 Scheduling
Timeliness is critical in the systematic communication process. Implementation activities
should begin prior to promulgation and continue through compliance deadlines set forth in the
standard. The earlier the process begins, the more likely that necessary elements will occur. For
example, ITPID and ESD met to consider implementation aspects of the Medical Waste
Incinerator Emission Guidelines over one year prior to promulgation and the Implementation
Team kickoff meeting was six months prior to promulgation.
Figure 3-3, Example MACT Standard Implementation Timeline, provides a generic
schedule for executing education, source population identification, compliance assurance, and
enforcement activities. The timeline in the figure begins with the effective date for a MACT
standard and continues through five "periods" marked by initial notification, substantive
3-4
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compliance dates, performance tests, notification of compliance status, and compliance and
continuing periodic reports. This model timeline serves as an example and should be revised as
appropriate to meet specific implementation needs.
3.4 Tracking
Tracking activities and progress is another critical issue in the systematic communication
process. PRG/ITPID will maintain an internal database that tracks their SMIP subtask
commitments and the preparation of materials (preparers and reviewers). ITPID has developed
and will maintain the EPA/STAPPA/ALAPCO Unified Air Toxics Website as a vehicle for
many implementors to provide information about their activities and products. The Planning,
Resources, and Regional Management Staff has developed MACTRAX (see Appendix L) to be a
simple, easy-to-use system for states and regions to track their overall status on implementation
(i.e., delegations of MACT standards, source notifications received, and controls installed and
operating). Also, over the next few years, the AIRS Facility Subsystem (AFS) will be
re-engineered and will be an easy-to-use tool for EPA and states to track compliance and
emissions and prepare reports.
As implementation efforts are completed and individual sources come into compliance
with a specific MACT standard, the Regional Air Toxic Coordinators should identify follow-up
action items, as necessary. The Regional Air Toxic Coordinators should also provide feedback
to the MACT implementors in order to enhance the development of implementation materials
and improve the implementation process for other standards not yet completed or fully
implemented.
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EPA - HQ
OAQPS,
OECA,
OGC
Reports
and
Technical
Guidance
Computer r-
Based
Education
and Training
(e.g. Website)
Informal Information
State/Local/Tribal Entities
Public and Other Stakeholders
Figure 3-1. Many Opportunities for Information Exchange
-------
U)
OAQPS Internal
DD/ADD/GL (Monthly)
• Review Progress/Plans/Budgets
• Set Priorities
• Identify Stakeholder Interests
• Resolve Problems
OD (Quarterly)
• Review Progress
• Set Priorities
• Resolve Cross-office Issues
Implementation Team (Ongoing)
• Staff Support as Necessary,
Considering Resources and Priorities
OAQPS/OECA/
Regional Offices
Staff Level Calls (Monthly and as
Needed)
• Resolve Implementation Issues
• Develop Implementation
Recornrnendations
• Track and Report Progress
• Resolve Issues at Lowest
Organizational Level Possible
OAQPS/
Regional Offices
Visit (Annual)
•Highlight Successes
• Review Progress
• Identify Obstacles and Solutions
Semi-Annual Reports
• Report Progress
DD/APWDO Calls (Monthly)
• Agenda as Appropriate
DD/APMTOO Meeting (Quarterly)
• Agenda as Appropriate
OAQPS/OECA
DD (Quarterly)
• Review Progress/Plans/Budgets
• Set Priorities
• Resolve Problems
OAQPS/OGC/OECA
Regional Offices/
State/Local/Tribes
Toxics Task Force (As Needed)
• Review Progress/Plans
• Set Priorities
• Resolve Issues
STAPPA Air Toxics Call (Monthly)
• Agenda Set for Each Call
OAQPS Planning Management
Retreat (Annual)
• Review Progress
• Set Priorities
• Adjust Plans
"Aqueducf VBrown Summit
Working Meeting on Air Toxics
Implementation (Annual)
• Identify Staff Level Implementation
Issues
• Resolve Staff Level Implementation
Issues
Air Toxics Implementation
Conference (Annual)
• Review Progress with a Wide
Audience
• Provide Training and Outreach
OAQPS/OECA/
Regional Offices/Public
and Regulated Community
Website (Ongoing)
• Continual Dissemination of
Information - Regulations/Contacts
Outreach Efforts (Ongoing)
• Workshops/Serrinars
• Brochures/Pamphlets
DD = Division Directors
ADD = Associate Division Directors
GL = Group Leaders
OD = Office Directors
APM = Air Program Managers
DO = Desk Officers
Figure 3-2. Communication Agenda
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OJ
oo
Effective
Date
Initial
Notification
Substantive
Compliance
Dates
Performance
Tests
Notification of
Compliance
Status
Compliance &
Continuing
Periodic
Reports
Source: Model Implementation Plan for MACT Standards
Draft No. 5 - March 7, 1997
Figure 3-3. Example MACT Standard Implementation Timeline
-------
VO
• For existing sources, Period 1 is usually 120 days, and for new sources, Period 1 is usually 120 days from startup;
however, an individual standard may specify a much longer timeframe.
• For existing sources Period 2 may be up to three years, but new sources generally must comply at startup. In
other words, new sources usually do not have a Period 2.
• Period 3 is usually 180 days from the compliance date.
• Period 4 is usually 60 days.
• Period 5, measured as the time before the first periodic report is due, may be three, six, or twelve months, and
subsequent reporting periods may be adjustable depending upon the standard.
• Also note that the entries for each phase indicate a potential duration; it is always advisable to execute the phases
as expeditiously as possible. For example, the source population identification phase may extend past the initial
notification date as these notifications may identify more sources, but the much of the work for this phase should
be completed well before this date.
Figure 3-3. Example MACT Standard Implementation Timeline (Continued)
-------
Sources direct questions to the implementing authority (typically States)
i
If the implementing authority cannot answer, they
forward questions to their respective RO
If the RO contact can respond, they provide response and
send a copy to other ROs and HQ Representatives
If a RO contact cannot respond, they contact other
RATCs to figure out how to respond.
RATCs have the lead in providing response to the State and
sending copies to HQ representatives for a 10-day time limited HQ review
If the resulting action reflects a change in past application of a regulation
or policy, (requiring coordination with other HQ offices) the designated RO
contact develops and distributes a one page description of the issue and
schedules a meeting with appropriate parties
RATCs, OC, ORE, OGC, and OAQPS will determine who will provide response
Sub-Lead region* should send all responses to the Program Review
Group to compile and provide on the EPA Website
* Region IV is currently the sub-lead region for air toxics
RO = Regional Office
HQ = Headquarters
RATC = Regional Air Toxics Coordinator
OC = Office of Compliance
ORE = Office of Regulatory Enforcement
OGC = Office of General Counsel
OAQPS= Office of Air Quality Planning and Standards
Figure 3-4. Implementation Issue Resolution Process
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4.0 ELEMENTS OF A SUCCESSFUL IMPLEMENTATION STRATEGY
Section Summary
Considerations for a successful strategy such as education, source population
identification, outreach, small business issues, compliance assurance,
enforcement, reference materials, available resources, and permitting issues
are discussed.
The elements recommended for consideration and inclusion in any implementation effort
are described in this section. Examples of how the elements are actually used in a Specific
MACT Implementation Plan (SMIP) are presented in Section 5.0. This section specifically
describes education, source population identification, outreach, small business needs, compliance
assurance, enforcement, and how these elements are critical considerations in any strategy.
These elements are described in more detail in the following paragraphs.
4.1 Education
For purposes of this strategy document, education refers to educating the implementors
rather than educating the affected sources and the public, which is part of outreach. However, for
many rules, some of the sources of information and activities described below may serve the
goals of both education and outreach.
An important source of information is the SMEP which is prepared prior to promulgation
of each MACT (see Section 5.0). The SMIP will provide a summary of the rule and an action
plan for implementing the specific standard through all phases of implementation from education
through enforcement. The SMIP, written for the implementors, would propose specific
procedures for implementation associated with "trigger" dates within the standard such as
notification dates, compliance dates, reporting intervals, and stack test dates.
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The SMIP should be targeted for implementors, and should be as user-friendly as
possible, avoiding regulatory language in favor of more common language where possible. A
good example, the draft implementation plan for the Ethylene Oxide Commercial Sterilization
Facilities MACT standard, is included in this document as Appendix F. The materials in the
SMIP should use standard policies and procedures as much as possible and highlight significant
differences or issues. This is important because the state agencies, permit writers, inspectors, and
other staff have resource limitations. Materials in the SMIP do not replace the rule; if there are
any legal issues, the rule takes precedence. However, the rule should not be solely relied on
because of the need to quickly and efficiently transfer the needed information.
Even though the plan will provide a useful written summary for an implementing agency,
some training may also be necessary. EPA's traditional training courses for MACT standards,
primarily teleconference satellite courses, are excellent in fulfilling this need. EPA plans to
arrange these courses at optimum times for those standards that have the greatest need.
The implementors will be asked many questions that may be answered based on the
educational materials and training discussed above. EPA will also provide assistance to the
implementor for specific questions that are not covered in the materials discussed above. To
facilitate the process, the regional offices will identify a contact person for each standard or a
central contact who can then transfer the specific question to the appropriate regional office
person. In turn, appropriate OECA, OGC, and OAQPS contacts (see Appendix I) should be
identified and be available to the regions to address unique questions. Thus, there should be a
confirmed link at each level of the information ladder from EPA headquarters to the regions and
to the states.
To ensure national consistency to the appropriate degree and still allow for site-specific
applications as appropriate, periodic conference calls or electronic mail exchanges between the
contacts for a specific standard should be held following rule promulgation to exchange
questions and answers. The regional offices are expected to regularly communicate with the
state, local, and tribal entities in their region. Regional offices should also help build a body of
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frequently asked questions and answers for sharing among the implementors. For questions and
answers that are not straightforward, the Regional Air Toxics Coordinators should discuss
options and seek input and/or review from OECA, OGC, and OAQPS as appropriate. To
maintain consistency, these questions and answers should be discussed and drafted among the
group, and approved by the delegated authority. They should also be made available via the
Unified Air Toxics Website. In addition, the implementing agencies should take advantage of
the EPA's and STAPPA's electronic services.
As mentioned before, a SMIP could include lists of available resources such as EPA
Internet websites and websites of the states. In addition to providing access to official guidance
documents and formal response to questions, both EPA and STAPPA have electronic means to
share draft responses and issue papers among the implementors. Using such means to share
information can reduce the risk of an implementor responding incorrectly because of a lack of
understanding of the question. Sharing information is also important for reducing overlapping or
conflicting implementation efforts.
•4.2 Identifying the Source Population Subject to the MACT Standard
Identifying a regulation's affected source population is not always a clear process, but is a
necessary step during the early implementation of the rule. For some regulations that affect only
large facilities, this will not be a concern because most state or local programs are aware of all
the large facilities in their jurisdiction. However, in other cases, identifying the population may
be a daunting task if sources are numerous, small, or collocated. To simplify this process, EPA
has prepared a "Cookbook" to guide agencies through various identification techniques using a
screening process based on available data. The Cookbook was pilot tested in several states and
the results are included in the final version. The Cookbook is included as Appendix G to this
document.
Even after finding potential sources, some questions may remain about a rule's
applicability. While these questions generally need to be addressed on a case-by-case basis, EPA
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can provide information to assist in these efforts. The Applicability Determinations Index is a
useful tool to determine if a question has been previously addressed. EPA also can produce
example applicability determinations. For example, for the Hazardous Organic NESHAP
(HON), three applicability determination examples were produced which were very helpful and
possibly prevented some erroneous determinations.
Throughout the source identification process, the delegated agency will be the official
decision maker on applicability determinations. The delegated agency should maintain good
communications with EPA according to the terms of the delegation.
4.3 Outreach
Outreach is targeted for the general public and regulated community. Outreach
opportunities include using literature to disseminate information about an industry; attending
training courses, trade shows, or meetings; and coordinating with the Small Business Assistance
Program. In many cases, outreach efforts and source population identification are occurring at
the same time. For example, the Small Business Assistance Program may have information on
affected sources to provide to implementors as well coordinating with implementors to provide
information to affected small businesses.
Literature may include fact sheets EPA prepared during rule development or pamphlets
produced by the EPA regional office or a state/local/tribal entity to address specific needs of the
permitting authority or geographic area. EPA also considers preparing plain-English guides (or
other languages) for the regulations, especially those involving area sources or those affecting
small businesses. For example, the draft Plain-English Guide for Perchloroethylene Dry
Cleaners was a very useful and popular document at a Southern Dry Cleaners Show.
The SMIP should contain sections about pollution prevention opportunities so that the
regulated sources can be educated in that topic and pollution prevention activities can be
implemented as part of the compliance scheme. Technical summary sheets should have a section
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that highlights pollution prevention options in the rule and/or voluntary pollution prevention
measures the affected source category could take. The plan may also list regional contacts for
pollution prevention information.
Education efforts such as training courses may also provide outreach opportunities.
Some courses targeted for the implementors may also be appropriate for a public audience and
vice versa. To that end, implementors may be able to attend seminars sponsored by industry
organizations. Often EPA provides technical assistance to these seminars through expert
speakers and other materials. These seminars create excellent opportunities to train the
implementors while gaining some of the industry's perspective on the rules.
Other training opportunities include satellite downlink courses. These courses are usually
presented by EPA through a university grant and often have trade associations as joint sponsors.
These courses involve EPA, state, and industry representatives, and the resulting videotapes can
be distributed to an even wider audience.
Implementing agencies should also contact industry associations to arrange outreach
efforts. EPA can facilitate this effort by including names of associations contacted during
standard development and identify any assistance or information the associations may offer.
Such information can be included in the SMIP. The implementing agency should also offer to
attend trade shows and address association meetings. Many times the organizations desire the
regulatory agency's presence and will provide free space within the shows for displays about the
standards.
Just as during the education phase, the implementors should take full advantage of the
information available electronically. The EPA and state websites, and potential telephone
hotlines would particularly be useful in outreach efforts, if these resources are properly equipped
and advertised.
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The implementing agency should also remember that the time frame for completing the
source population identification and outreach may be up to three years or as short as six months.
The SMIP will quickly identify this time limit and provide recommendations an implementing
agency may consider to make appropriate plans.
4.4 Small Business Needs
The implementation strategy concepts apply both to MACT standards for large industry
and small businesses. All implementing agencies should coordinate with the Small Business
Assistance Program for their area to assure that they have an appropriate understanding of the
rules and access to training and literature. This coordination is very important to ensure
compliance with SBREFA and EPA's small business policies. Each implementing agency needs
to understand that small businesses may be major sources and that the Small Business Assistance
Program is a major participant for any rule affecting small business entities.
If a rule is subject to the Small Business Regulatory Enforcement Fairness Act
(SBREFA), there are specific requirements for the development and distribution of SBREFA
Compliance Guides. EPA must prepare one or more publications as small entity compliance
guides, explain in these guides the actions a small entity must take to comply, and distribute
these guides to small entities through comprehensive sources of information. For example, trade
associations may be appropriate for some industries, and the Small Business Assistance Program
may be appropriate for others. The CAA gives the EPA broad discretion under SBREFA with
regard to implementation, development, and distribution of the guides. Further information is
located in Appendix J, Small Business Regulatory Enforcement Fairness Act.
4.5 Compliance Assurance
After educating themselves, the regulated community, and the public, and after locating
the sources, the implementors must rum to assuring compliance with the rule. Although different
agencies have different organizations and procedures for compliance assurance, certain major
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activities are universal. First, the implementor must establish a system to track compliance.
There is no new tracking or reporting requirement mandated by this document, but rather, the
specific requirements will be agreed to as part of the Performance Partnership Agreement.
Systematic tracking supplies quick and easy analysis of a source's compliance status and the
success of the implementation efforts. Initially, the tracking includes receipt of notifications and
grows to periodic reports and inspection results. To accomplish this, the Aerometric Information
Retrieval System (AIRS) is available. An internal system, MACTRAX, is also an option as long
as the AIRS reporting commitments are still met. See Appendix L on the MACTRAX System.
If AIRS is used for tracking, the appropriate data should be entered. If an action code is
missing, the regional office should be notified to have it added. Stand-alone tracking systems
may also be established. This may be advantageous during the early implementation stages to
track all the initial notifications, compliance status notifications, and first periodic reports.
Stand-alone systems provide faster access to compliance data, and the report writing capabilities
may be more flexible. Nevertheless, all required data must be entered into AIRS, and the use of
a stand-alone system is a matter of preference.
Another compliance activity is inspections. Individual affected sources should be
targeted for regular inspections beginning after a rule's first substantive compliance date. If a
rule has staggered substantive compliance dates, then additional targeting is necessary. This is
especially important for the regional offices which have limited field presence. Whatever
targeting model is used, its weighting factors should be adjusted after a compliance date to
ensure that MACT sources are inspected. In subsequent iterations, the weighting factors can then
be reduced to normal levels merely to ensure continuous regular inspections. Example
inspection checklists are included as Appendix H.
While conducting inspections, the implementor will need to consider whether violations
will be addressed with compliance assistance or enforcement proceedings. Furthermore, because
of resource limitations, compliance assistance priorities should consider where assistance is most
needed and most effective. For example, sources which are expected to have difficulties in
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complying, like area sources, small businesses, or sources predominantly owned by persons who
may not understand English well may be the best candidates for compliance assistance. Also,
one should note that compliance assistance is only a part of compliance assurance. Assistance is
when the implementor helps define and works with the regulated source in how to achieve
compliance. Assurance is all the activities the implementor conducts to achieve, monitor,
maintain, and track industry compliance, short of enforcement. These activities are the
precursors to enforcement, when necessary, and naturally include compliance assistance.
Compliance assistance is also a major factor when dealing with small businesses. The
small business programs were created to provide information to small businesses requesting
compliance assistance. Compliance assistance will likely be the response for deficiencies found
at small businesses which report deficiencies voluntarily. Again, appropriate coordination with
the Small Business Assistance Program is critical during this phase of compliance assurance.
Please note that the Small Business Assistance Programs may also conduct site visits.
During this phase, EPA encourages the implementor to present pollution prevention goals
as part of the source inspections. The inspectors should have checklists so that they can easily
identify the necessary pollution prevention activities. Also, the checklists could have
suggestions for other prevention activities which are not required by the rule. The checklists
could be similar to the inspection checklists developed for the dry cleaning facilities MACT
standard (see Appendix HI). Since pollution prevention activities are not always required by the
rule, some states may not be able to incorporate pollution prevention into their inspection
scheme. If this is the case, a great effort at pollution prevention education during the outreach
phase of implementation is all the more important.
Lastly, all federal compliance assurance activities should be coordinated with the state,
local, and tribal entities (See Sections 2.0 and 3.0). This will avoid conflicts and help EPA focus
its resources.
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4.6 Enforcement
When a violation is discovered at a major source, the implementor should proceed
according to the guidance on "Timely and Appropriate Enforcement Response to Significant Air
Pollution Violators.1" The purpose of the guidance is to enable the implementors to focus
enforcement efforts on the highest priority of noncomplying sources and to do so in a timely
manner. The SMIP may include an Enforcement Response Plan (ERP) as guidance on specific
conditions when enforcement is necessary. For all enforcement actions, pollution prevention
benefits should be explained, and the use of pollution prevention projects should be encouraged
when an enforcement settlement is going to include supplemental environmental projects (SEPs).
4.7 Reference Materials
During rule development and certainly at promulgation, various participants need to gain
an understanding of the requirements in the rule and its associated infrastructure. Good sources
of information are the documentation that EPA generated during rule development such as
technical and general fact sheets, Federal Register notices, the rule itself, and the technical
support document that includes the basis for the rule. These documents are usually available
promptly on EPA's electronic bulletin boards/websites and specifically on the
EPA/STAPPA/ALAPCO Unified Air Toxics Website (See Appendix D for website information).
Sometimes additional information prepared by EPA and the state and local agencies is on the
website or available through hypertext links to other sites. In the near future, this website will
contain information on each MACT standard and its implementation. In order to share
information and to avoid duplicate efforts, this strategy recommends that EPA lead a joint effort
with STAPPA to coordinate the development of tools and make them available on the Unified
'Guidance on the Timely and Appropriate (T&A) Response to Significant Air Pollution
Violators (SVs). Memorandum from John S. Seitz and Robert Van Heuvelen,
U. S. Environmental Protection Agency, Office of Air Quality Planning and Standards, to Air
Directors and Regional Counsels. February 7, 1992.
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Air Toxics Website. It is essential to the SMIP that a list of available resources for the MACT
standard are mentioned with specific instructions on how to access them.
4.8 Other
During each phase of the implementation of a rule, the implementors will have to deal
with additional considerations that will impact their activities. Some may only affect certain
state, local, or tribal entities or geographic areas while others will be more universal. Some of the
universal considerations include resources, permitting, requests for compliance extensions and
waivers, and impact of SBREFA. The SMIP can provide some assistance with these issues, but
individual planning will be required to adapt the strategies to the structure of each regulating
agency.
4.8.1 Resources
A successful implementation strategy should consider all possible aspects of
implementation, including resources. The availability of resources is always a factor in how
much work can reasonably be performed. Choices will need to be made on where the resources
can be used most effectively and efficiently.
The implementation support activities will likely be in direct proportion to the resources
allocated for such efforts. During the MACT standard development process, PRG/ITPID, ESD,
OECA, and the implementors should discuss possible implementation efforts and prioritize them
with emphasis on the critical elements. The EPA/STAPPA/ALAPCO Committees on Air Toxics
and Training are two current venues that PRO is using to help prioritize needs.
Because implementation needs will likely continue to be greater than the directly
available resources, PRG/ITPID will pursue additional approaches for completing the identified
critical elements of the SMIP. PRG/ITPID may ask implementors to volunteer to prepare certain
materials or share costs with others to prepare specific items. For example, an industry trade
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group may be able to provide a list of affected sources or develop training materials, or a regional
office or state or local agency may be able to develop an inspection checklist or the SMIP. If
these approaches are still insufficient to complete the critical materials, PRO will alert EPA
managers and STAPPA/ALAPCO of the situation for resolution and they may bring the
discussion to the Air Toxics Task Force, if appropriate.
4.8.2 Permitting
Several issues may need to be addressed with regard to permitting. If the source is yet to
receive its operating permit, the implementor must ensure that the permit includes the applicable
requirements of the rule. Also, if the permit has been issued and is not going to expire within
three years, then the implementor must reopen the permit to include the applicable requirements
of the MACT standards. For rules that apply only to major sources there will be discussions
concerning potential to emit and ways to ensure that the source may keep its potential below the
MACT cutoffs and Title V requirements. In this case, the specific MACT implementation plan
could provide examples or ideas about limitations that would be appropriate for a Federally
Enforceable State Operating Permit (FESOP). Also, for sources that have requirements from
more than one regulation, the source may want to take advantage of the streamlining
opportunities afforded in the Title V White Paper 2.'
Other considerations may include requests for compliance extensions, waivers, and other
determinations. These requests must be processed according to the time frames in the rule or
general provisions. Much additional information on Title V and other policy and guidance is
available on the EPA Title V Operating Permit Program website and the EPA Policy and
Guidance website.
'White Paper Number 2 for Improved Implementation of the Part 70 Operating Permits
Program. Memorandum from Lydia N. Wegman, U. S. Environmental Protection Agency,
Office of Air Quality Planning and Standards, to EPA Regional Office Directors.
March 5, 1996.
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5.0 DEVELOPMENT OF A SPECIFIC MACT IMPLEMENTATION PLAN
Section Summary
This section defines and discusses "baseline" and "enhanced" efforts for the
development of implementation materials, decision making tools and
processes for determining recommended level of effort for a MACT Standard,
and the Tool Development Agreement (TDA).
This section describes activities recommended to effectively develop a Specific Model
Implementation Plan (SMTP) using the strategy presented in Section 4.0 and tailoring it to the
specific MACT standard. An assessment is made of the complexity of the standard and the
expected implementation needs. Based on that assessment, a SMIP is developed for that
standard which includes a Tool Development Agreement (TDA) that is agreed to by the
participants. The SMIP should reflect that follow-up and tracking activities are necessary after
promulgation. See Figure 5-1 for a flow diagram illustrating this process.
The implementation may require different levels of effort and resources for each MACT
standard. The Program Review Group (PRO) in the Information Transfer and Program
Integration Division (ITPID) has the lead role in encouraging the development of a SMIP, and
for coordinating the activities recommended for successful implementation as specified in
Section 4.0, as resources allow. PRG is specifically responsible for developing a TDA that
ensures that the critical implementation materials are prepared or the gap between the need and
the resources available is elevated to EPA managers and STAPPA/ALAPCO as discussed in
Section 4.8.1. As shown in Tables 2-1 through 2-5 (and Table 5-1), ITPID is not responsible for
all implementation activities, or the actual preparation of all implementation materials. Rather,
PRG/ITPID will focus on developing the TDA, coordinating the production of the materials, and
preparing some of the materials. Actual preparation of these materials will be shared among the
implementors (both EPA and non-EPA).
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5.1 Assessment of MACT Standards
5.1.1 Baseline Implementation Materials and Enhanced Implementation Materials
Certain implementation materials have been identified as "baseline" materials that would
be beneficial for every MACT standard. Any additional items are categorized as "enhanced"
materials. The following subsections describe the decision making process for planning the level
of effort for a MACT standard. For the purposes of this discussion and preparation of the TDA,
the following items are considered "baseline" implementation materials:
Administrative
• Contacts list (e.g., Permitting Authority, Regional Offices, ITPID, BSD, OECA,
OGC);
• Specific delegations guidance where generic guidance is not sufficient;
• Summary of recordkeeping and reporting requirements;
• Specific compliance certification/assurance and enforcement policies/guidelines
where generic guidance is not sufficient;
• Specific data reporting information (AIRS database training, MACT database
training, MACTRAX) where generic guidance is not sufficient; and
• Timeline: compliance schedule (i.e., summary of compliance deadlines).
Technical
• Fact sheets/summary of the standard;
• Currently available list of affected sources and locations;
• Examples of applicable reporting forms (e.g., initial notification, initial statement
of compliance for each control device, checklists);
• Inspector checklists;
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Summary of testing and monitoring requirements;
Summary of operations and maintenance plans/requirements (if required by
MACT);
Technical support document;
Specific guidance on relationships to Title V, NSR, Potential to Emit (PTE) where
generic guidance is not sufficient;
Sample calculations; and
Applicability flowcharts.
Other implementation materials have been identified as "enhanced" materials. These
items may be useful for implementation of certain MACT standards, in addition to the baseline
items. How to determine the need for the development of these additional materials is
discussed in the following subsections.
For purposes of this discussion and preparation of the TDA, the following items are
"enhanced" implementation materials to be considered:
Technical Training
• Satellite downlinking training sessions;
• Workshops (at 1 or more sites near implementors);
• CD-ROM interactive tools on training;
• Federal Register hypertext;
• VMS training tapes;
• On-site training and certification (i.e., at a source) (for implementors or perhaps
sources in conjunction with Small Business Assistance Program or Trade
Association);
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• Test method training; and
• Example conditions for Title V operating permits.
Source ID/Outreach/Small Business Assistance
• Source identification materials (beyond ESD list and Source ID Cookbook);
• Brochures/pamphlets/plain-English guides (outreach materials);
• Public meetings;
• Small business outreach materials;
• Small business assistance training; and
• SBREFA Compliance Guide (if necessary).
When determining if enhanced efforts may be needed, the implementors may want to
consider other important factors such as the potential for emission or risk reduction, the degree of
public interest in the standard or regulated industry, or other factors that can affect the overall
significance of a particular MACT standard. In any case, the implementor's judgement should
always prevail in dictating the starting point for any implementation effort as well as deciding
whether to incorporate additional implementation materials.
5.1.2 Interview with MACT Development Team and Representative Implementors
Tools are available to help PRG and all the implementors plan the expected
implementation needs for each MACT standard. A list containing several types of questions is
useful as a starting point for the initial information gathering phase (see Appendix A). PRG
takes the lead in scheduling and interviewing the MACT development team (usually ESD, but
may be a regional office or state partner, in the case of MACT Partnerships) and representative
implementors to get specific information on that standard and implementation needs. This
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information may be helpful in determining the necessary level of implementation effort. Ideas
for particular implementation materials may also be identified during the interview.
5.1.3 Diagnostic Questionnaire
A diagnostic questionnaire (Figure 5-2) has been developed as a tool to allow
implementors to systematically examine the different factors that may either justify or preclude
the need for implementation materials beyond the baseline. The questionnaire considers the
following factors:
• Complexity of the rule;
• Difficulty of determining applicability;
• Cost of compliance;
Number and size distribution of sources and companies;
• SBREFA requirements;
• Capabilities of trade associations (which affects the need assessments and
leveraging possibilities);
• Degree of controversy or acceptance of the rule by industry, state, local, and tribal
entities, and the public; and
• Capabilities/technical expertise within the industry.
Each of the factors in the questionnaire influences the level of effort recommended for
implementation of a particular MACT standard. For example, the presence of a small number of
facilities in a regulated industry would tend to reduce the necessary implementation effort.
Conversely, the presence of complex rule language would tend to increase the warranted level of
effort. The questionnaire contains diagnostic questions that review the effects of the various
factors and indicates whether enhanced materials would be useful for implementation of a
specific MACT standard.
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The availability of resources within the implementing agencies is always a factor in
determining how much work can reasonably be performed; however., the questionnaire
deliberately does not include available resources as a factor for consideration because the initial
determinations should be based on experience and technical expertise.
The questionnaire provides a format where points are assigned for each response. The
points are totaled and a score of six or greater indicates that additional efforts should be
considered.
5.1.4 Flow Charts for Enhanced Efforts
Flow charts are included as tools that may help determine where enhanced efforts would
be useful. Figures 5-3 through 5-6 are flow charts for determining if technical training, source
identification/notification, public outreach, or small business assistance may be necessary. Once
a decision is made that enhanced implementation materials may be needed, the specific areas
needing additional effort should be identified. The flow charts are intended to help with this
decision-making process.
5.2 The Tool Development Agreement
Table 5-1 presents one tool, the IDA, that should be used by the MACT development
team and implementors to reach preliminary agreement on the scope of the draft SMIP. PRO
will take the lead on planning the development of the SMIP and coordinating among the various
implementors. After consensus has been reached among the implementors on the preparation of
baseline implementation materials, the areas where enhanced efforts are needed, and the lead for
the preparation of each item/set of materials, the TDA for that MACT standard may be
developed.
The baseline elements are shaded and are listed first in Table 5-1, followed by the
enhanced elements. For each element listed, suggestions on the lead group and significant
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participants have been made. A blank TDA can be found as Appendix B to this document and
may be photocopied and used as a planning tool. The TDA contains three groups of columns
which include the following items:
Implementation Materials - The items in this column are the building blocks that make
up a complete MACT implementation plan. Some of the items in this plan will be specific to
each MACT standard while others may be general language unless otherwise specified. For
example, specific language may be used for delegation guidance exceptions and exceptions to
compliance certification/assurance and enforcement policies/guidelines. Items marked with an
asterisk represent those that will be general language unless the specific rule is an exception to
the normal guidance.
Y/N - The Y/N column is to be used for MACT-specific decisions on what materials will
be produced. This decision will be based on the knowledge and expertise of the implementors,
with the assistance of the decision making tools (Figures 5-2 through Figure 5-6 and
Appendix A).
Lead Group - If the material is identified as baseline or as a necessary enhanced tool for
a particular MACT standard, a lead group responsible for coordinating the preparation of that
piece of material will be identified as "lead" in this column. The lead group will not necessarily
be the preparer of the material.
Participants - The final group of columns indicates participants in each implementation
activity. Most of the implementation materials will need input or review from more than one
group. For each item, a check mark indicates whether a certain group is expected to participate
in the development of that material. This participation could be as a preparer or a reviewer, and
does not exclude any other group from participating in the development of that item. Table 5-1
distinguishes responsibilities among nine potentially responsible entities. The entities are
subdivided where responsibilities are specifically targeted for a particular group.
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During MACT development, at promulgation and at compliance dates, ITPID and BSD
will likely execute most of the efforts included for the baseline tools with some activities and
materials performed or prepared by the regional offices, OECA, state, local and tribal entities,
and the Small Business Assistance Program. However, the IDA can be tailored towards the
specific needs of the implementors, as appropriate. A model TDA has been prepared and is
included as Table 5-1. Again, all of these materials presume certain activities, roles, and
responsibilities by the implementors in order to facilitate efficient and effective preparation of
plans. The plans are designed to remain flexible so that additional ideas can be accommodated.
Because the MACT standards requiring enhanced implementation efforts are generally
more complex than those requiring only baseline efforts, more intensive and extensive planning
may be necessary. The SMTP may be coordinated with a working group or a team of
implementors. In some cases, it may also be appropriate for the working group or a team to
actively design and plan the SMTP. Such a Working Group or Team could include
representatives from ESD, ITPID, EMAD, OECA, OGC, regional offices, state, local and tribal
entities, the Small Business Assistance Program, and other entities, as needed. Ideally, these
representatives would develop a detailed plan of action during rule development for
implementation of the standard at promulgation. A key consideration in the SMIP and TDA is
the timing of the preparation and availability of the elements. For example, the timing of efforts
to promulgate the rule and develop implementation tools will have to be coordinated so that both
efforts are as effective and efficient as possible.
5.3 Additional Elements of a Specific MACT Implementation Plan
The assessment of the MACT Standard and preparation of the TDA should happen prior
to promulgation. Some tools may be drafted before promulgation, but many cannot be prepared
until after the final promulgation details are known and signed. Other aspects of the MACT
implementation process will also occur after promulgation, such as the following:
• Follow-up and tracking;
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• Compliance assurance; and
• Enforcement.
All elements discussed in Section 4.0 should be considered for every MACT standard at some
point in the implementation process. Each MACT standard will be unique and will need to be
given individual consideration when developing the SMIP. It may not be possible to predict the
effects of the standard, therefore, tracking with appropriate follow-up activity is necessary for
successful implementation.
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Post-
Promulgation
Follow-up
Activity
MACT Development
Process
Promulgation
Perform assessment of the
MACT Standard using
interview, questionnaire,
and/or flow charts as
needed
Complete Tools in TDA
Prepare SMIP
(includes TDA)
I
Perform follow-up and
tracking activities and
revise SMIP as needed
Begin drafting tools in
TDA that are not likely to
change during MACT
development process
Figure 5-1. Process for Developing a SMIP
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Instructions: For each question below, choose the response that best represents the situation
with your MACT standard. After answering all questions that apply, total your score by
adding the numbers in parentheses that correspond to the answer chosen.
Scoring: 6 total points or greater suggests a need to utilize enhanced implementation materials
beyond the baseline effort. See additional flow charts to determine what types of enhanced
efforts are needed.
1. How would you characterize industry's involvement in the development of the MACT
standard?
a. Positive (0)
b. Negative (1)
2. Does the MACT standard contain different requirements from what is already in practice
by most of the regulated industry?
a. Yes (1)
b. No (0)
3. How many states contain affected sources?
a. Less than 4 (0)
b. Between 4-10 (1)
c. More than 10 (2)
4. How many affected sources are there?
a. Less than 5 (0)
b. Between 5 & 30 (1)
c. More than 30 (2)
Figure 5-2. Questionnaire for Determining Whether Materials
Beyond the Baseline Level are Needed
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5. Is the average facility large or small? ("Large " is defined as being more than
500 employees and "small" being less than 500 employees for the purpose of this
question.)
a. Large (0)
b. Small (1)
6. Is the rule subject to SBREFA?
a. Yes (1)
b. No (0)
7. Is the rule complex? (e.g., the rule has many options for compliance)
a. Yes (1)
b. No (0)
8. Do the majority of the affected sources belong to a trade association?
a. Yes (0)
b. No (1)
9. Is it difficult for a source to determine applicability?
a. Yes (1)
b. No (0)
10. What is the cost to comply with this rule?
a. Minimal (0)
b. Significant (1)
TOTAL: points
Figure 5-2. Questionnaire for Determining Whether Materials
Beyond the Baseline Level are Needed (Continued)
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Is there more than one
option for the source for
control and/or
monitoring?
No
Yes
Is the source responsible
for determining which
controls or pollution
prevention options are
appropriate?
Yes
Probably not necessary to
conduct additional
technical training
No
May be helpful to
choose enhanced
implementation
materials from TDA in
area of technical
training
Figure 5-3. Flow Chart for Determining if Enhanced
Technical Training is Necessary
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Is it known which
sources are affected?
No
Yes
Is the number of
affected sources
expected to be large?
Yes
Not necessary to develop
additional
implementation tools to
identify sources
No
May be helpful to choose
enhanced implementation
materials from TDA for
Source ID/Notification
Assistance
Figure 5-4. Flow Chart for Determining of Enhanced Source
ID/Notification is Necessary
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Are you aware of any
actual or perceived
imminent health risks
associated with
emissions from this
source?
Yes
No
Has the public or
environmental
community been vocal
in the development of
this regulation?
No
Yes
STOP
May not be necessary to
prepare additional public
outreach materials
May be helpful to
prepare enhanced
implementation
materials from TDA in
area of public outreach
Figure 5-5. Flow Chart for Determining if Enhanced Public
Outreach is Necessary
5-15
-------
I
Does the average facility
employ less than 500*
employees?
No
Yes
\
STOP
May not be necessary to
prepare additional
implementation materials
aimed at small businesses
No
Is the rule subject
to SBREFA?
No
Are sources located in more
than one state?
Yes
Yes
Must prepare SBREFA
compliance guide
And
I
May be helpful to prepare
enhanced implementation
materials from TDA in area of
small business assistance
* There is a specific deflnition for small business for each SIC code. These definitions are based on
number of employees or dollar amount that the business must equal or be less than in order to
qualify as a small business. A large portion of these SIC codes use 500 employees as the
maximum number to qualify as a small business.
Figure 5-6. Flow Chart for Determining if Enhanced Small
Business Assistance is Necessary
5-16
-------
MACT:
Table 5-1. Model Tool Development Agreement
Implementation
Materials
Administrative
Contacts list for
implementors
PRO
Lead
at
promulgatior
Specific guidance
on delegations*
IIG
Lead
at
promulgation
Summary of
recordkeeping
and reporting
requirements
BSD
Lead
at
promulgatior
Specific guidance
on compliance
certification,
assurance, and
enforcement
policy*
OC
Lead
at
promulgation
Specific data
reporting aspects
of AIRS*
IMG
Lead
at
promulgation
Specific data
reporting aspects
of MACT
database*
IMG
Lead
at
promulgation
-------
MACT:
Table 5-1. Model Tool Development Agreement (continued)
Implementation
Materials
Specific data
reporting aspects
ofMACTRAX*
Timeline:
compliance
schedule
Technical
Fact sheets
(general,
technical, and
press release)
Summary of the
standard
Currently
available list of
affected sources
Examples of
applicable
reporting forms
(e.g., initial
notification,
initial statement
of compliance for
each control
device,
checklists).
Y/N
Y
Y
in
Y
Y
Y
Y
Lead
Group
PRRMS
BSD
nm
BSD
BSD
ESD
OC
Participants'
ESD
•
Lead
mm,
Lead
Lead
Lead
•
ITPID
OPG
m
IIG
HH
•
IMG
•
m
ITG
m
EOG
HH
•
•
PRG"
•
•
PP
•
•
•
•
OECA
OC
•
•
nn
•
•
•
Lead
ORE
•
in
•
PRRMS
Lead
mm
EMAD
•
nm
•
•
OGC
•
mi
•
•
RO1
•
•
HH
•
•
•
•
s/L/r
•
•
Hi
•
•
•
•
SBAP
tit
When
Available
at
promulgation
at
promulgation
nnm
at
promulgation
at
promulgation
at
promulgation
at
promulgation
-------
MACT:
Table 5-1. Model Tool Development Agreement (continued)
Implementation
Materials
Applicability
flow charts
Sample
calculations
Inspector
checklists
Summary of
testing and
monitoring
requirements
Operations and
maintenance
plans/
requirements
Technical
support
document
Special
relationships to
Title V, NSR,
PTE*
Y/N
Y
Y
Y
Y
Y
Y
Y
Lead
Group
BSD
BSD
OC
BSD
BSD
BSD
BSD
Participants*
ESD
Lead
Lead
"
Lead
Lead
Lead
Lead
ITPID
OPG
"
'
HG
"
"
"
*
*
*
*
IMG
"
*
*
*
*
*
*
ITG
"
"
"
*
*
*
*
EOG
"
"
"
l/>
^
"
^
PRG"
"
"
^
*
*
*
*
OECA
OC
"
^
Lead
1/1
^
^
^
ORE
^
^
^
^
"
'
*^
PRRMS
•
^
*
*
'
*
*
EMAD
^
*
^
1/1
*
'
"^
OGC
"
*
^
"
*^
ij
'
ROC
•
^
^
*
"
*
*
s/Lrr
*
*
*
'
'
v
'
SBAP
When
Available
at
promulgatior
at
promulgatior
at
promulgatior
at
promulgation
at
promulgatior
at
promulgation
at
promulgation
-------
MACT:
Table 5-1. Model Tool Development Agreement (continued)
Implementation
Materials
IIG IMG ITG EOG PRG
"CD-ROM"
interactive tools
on training
PRG
Lead
at
promulgation
Federal Register
hypertext
Ul
i
N9
O
PRG
Lead
1-3 months
after
promulgation
Workshops (site-
specific)
OC
Lead
(NETI)
1 -3 months
after
promulgation
Satellite
downlink
training sessions
PRG
Lead
1-3 months
after
promulgation
VMS training
tapes
PRG
Lead
6 months afte
promulgation
On-site training
and certification
OC
Lead
(NETI)
6 months afte
promulgation
Example
conditions for
Title V operating
permits
ESD
Lead
at
promulgation
-------
MACT:
Table 5-1. Model Tool Development Agreement (continued)
Implementation
Materials
Y/N
Lead
Group
Participants'
ESD
ITPID
OPG
IIG
FMG
ITG
EOG
PRG"
OECA
OC
ORE
PRRMS
EMAD
OGC
ROC
S/L/T
SBAP
When
Available
Test method
training
EMAD
Lead
1-3 months
after
promulgation
Source ID/
Outreach/Small
Business
in
NJ
Source
identification
effort (beyond
cookbook
information
provided in
Appendix G)
OC
Lead
at
promulgation
Brochures/
pamphlets/ Plain
English Guides
(outreach
materials)
PRG
Lead
at
promulgation
Small business
assistance
training
ITG
Lead
at
promulgation
Small business
outreach
materials
ITG
Lead
at
promulgation
SBREFA
compliance guide
(if necessary)
ESD
Lead
at
promulgation
-------
MACT:
Table 5-1. Model Tool Development Agreement (continued)
Participates as either a provider, preparer, or a reviewer (•)
PRO is responsible for coordinating development of the SMIP and the TDA upon request by BSD and negotiations between ESD and PRO .
Identify which regional office or which state/local agency
Generic EPA guidance will be used unless this rule is an exception to that guidance.
EMAD Emissions, Monitoring and Analysis Division
EOG Education & Outreach Group
ESD Emissions Standard Division
IIG Integrated Implementation Group
IMG Information Management Group
ITG Information Transfer Group
ITPID Information Transfer and Program Integration Division
OC Office of Compliance
OECA Office of Enforcement and Compliance Assurance
OGC Office of General Counsel
OPG Operating Permits Group
ORE Office of Regulatory Enforcement
PRO Program Review Group
PRRMS Planning, Resources and Regional Management Staff
RO Regional Offices
SBAP Small Business Assistance Program
S/L/T State/Local/Tribal Entities
NETI National Enforcement Training Institute
I
N>
NJ
-------
APPENDIX A
Interview Questions for MACT Development Team and Implementors
-------
-------
Interview Questions for MACT Developers and Implementors
to Help Jointly Determine What is Needed for Implementation
This list of questions was designed as an optional In-Person Oral Interview Guide or Tool for
informal discussions of currently available information (or where it may be obtained) as input
for the developers and representative implementors to jointly develop an implementation plan
(i.e., what is needed when) for a specific MACT standard. Precise answers are not necessary.
Nor do all questions need to be answered at the time of the interview. The initial goal is merely
to obtain enough information to develop a draft plan, including what tools are most needed..
Affected Sources
1. How many sources are affected?
What percentage are small?
How many small business or governments are affected?
Is rule subject to SBREFA?
2. Is it known which sources are affected?
How exhaustive is the inventory?
Is there a list of sources?
Does it include locations, addresses, telephone numbers, contacts?
Do you know anyone else that may have a source list?
3. Is this industry already Federally regulated? If so, how?
Are there State/local/tribal rules? If so, what is their general level of control?
4. How many States have affected sources?
How involved have the States and Regions been in developing this standard?
How ready are the States to implement this standard?
Applicability
5. Explain how the source determines if this rule applies to them.
Specifically, what does the source have to do to determine applicability?
Is this straightforward? That is, what is the level of difficulty for small and large sources to
determine applicability?
Where is this protocol described?
What additional information will the source need to obtain, develop, or record?
Cost of the Regulation
6. What is the cost to comply with this rule?
Benefits of the Regulation
7. What emissions reductions will be achieved?
Which pollutants? What are the general health risks associated with these reductions?
1
-------
Coordination with Stakeholders
8. What level of participation have you received from industry, trade groups, environmental
groups, States, locals, Tribes?
What outreach to States/locals/tribes and industry is necessary?
What education do the Regional Offices need?
Are they calling you with many questions? What would help them answer the questions?
What outreach/education has been requested by the Stakeholders?
What have you done or planned?
9. Who are the relevant trade groups?
How active do you expect them to be in educating their members?
10. Who is the Office of Compliance contact?
Office of Regulatory Enforcement?
Office of General Counsel?
Regional Office contacts?
State contacts?
Locals?
Tribes?
Permitting?
What has been the level of participation of these individuals in rule development?
Have they pointed out any implementation concerns?
Have they committed to help on implementation aspects?
Real-World Climate
11. What is the climate in EPA, Congress, industry, States, locals, tribes, and the public for this
rule? Is it a high-profile rule?
Who are the advocates for this rule?
Who are the adversaries for this rule?
12. Has EPA been sued or do you expect EPA to be sued on this rule?
Complexity of the Rule and Compliance Assurance
13. How complex are the requirements?
What are the control and monitoring requirements of the MACT?
How many options are there?
How does the source determine which controls or pollution prevention options are
appropriate?
Are the monitoring requirements consistent with the enhanced monitoring provision of
section 114(a)(3)? (timely, accurate, replicable) If not, how do they differ?
What are the monitoring system performance specifications and calibration and QA/QC
requirements? Monitoring data availability requirements?
Are any excursions from required monitoring parameters excused from consideration as
violations of the emission standard?
-------
What are the reporting and recordkeeping requirements?
14. Does the standard require the source to develop inspection/maintenance procedures and an
operating plan? What are the criteria for approvable procedures and plans?
15. Are inspector checklists needed? Would they be helpful to Regional Offices, states, locals,
tribes, industry? Are examples available?
16. Are there example forms or checklists for the source to use for demonstrating compliance?
17. What are the compliance dates?
18. Is there an Enabling Document available? Are there any gaps in the information available?
-------
-------
APPENDIX B
Tool Development Agreement
-------
-------
MACT:
Tool Development Agreement
Implementation
Materials
Y/N
Lead
Group
Participants*
ESD
ITPID
OPG
IIG IMG ITG EOG PRG"
OECA
OC ORE
PRRMS
EMAD
OGC
HO*
S/L/T
SBAP
When
Available
Administrative
Contacts list for
implctnentors
Specific guidance
on delegations*
Summary of
recoidkeepuig
and reporting
requirements
Specific guidance
on compliance
certification,
assurance, and
enforcement
policy*
Specific data
reporting aspects
of AIRS*
Specific data
reporting aspects
of MACT
database*
Specific data
reporting aspects
ofMACTRAX*
mm.
mm
'm?A
wm
'W%
Wtfa
ym
yM%
WB.
mm
Wk
mm
'mm.
mm
m,
Wm
mm
-------
MACT:
Tool Development Agreement (continued)
Implementation
Materials
Timeline:
compliance
schedule
Technical
Fact sheets
'(general,
technical, and
press release)
Summary of the
standard
Currently
available list of
affected sources
Examples of
applicable
reporting forms
(e.g., initial
notification,
initial statement
of compliance for
each control
device,
checklists).
Applicability
flow charts
Sample
calculations
Inspector
checklists
Y/N
nn
Lead
Group
nm
Participants'
ESD
m
ITPID
OPG
Hi
IIG
m
IMG
m
ITG
'm
EOG
ym,
PRGb
m,
OECA
OC
'mm
ORE
m
PRRMS
'mm
EMAD
m
OGC
m,
ROC
m
S/L/T
m
SBAP
m
When
Available
-------
MACT:
Tool Development Agreement (continued)
Implementation
Materials
Y/N
Lead
Group
Participants'
ESD
ITPID
OPG
HG IMG ITG EOG
PRG"
OECA
OC
ORE
PRRMS
EMAD
OGC
RCX
s/i/r
SBAP
When
Available
Summary of
testing and
monitoring
requirements
Operations and
maintenance
.plans/
requirements
Technical
support
document
Special
relationships to
Title V, NSR,
PTE*
Technical
Training
"CD-ROM"
interactive tools
on training
Federal Register
hypertext
Workshops (site-
specific)
Satellite
downlink
training sessions
-------
-------
APPENDIX C
Cost Estimates for Education and Outreach
-------
-------
COST ESTIMATES FOR EDUCATION AND OUTREACH
COST
$25,000
$ 2,800
$ 2,800
$ 400
$ 1,500
ACTIVITY
Estimated cost to develop one day of a classroom training course
(e.g., a four day course would be $100,000). This estimate also
holds for development of self-study materials and technical
manuals, with a manual of about 250 pages being roughly
equivalent to a 3 day classroom course (i.e, $75,000).
Studio usage for about 5 hours. Includes taping, re-takes and
some graphics support. This amount is also used in estimating
the studio costs for a 5 hour (one day) broadcast.
plus travel expenses. Estimated cost for field shoots using two
people and camera for about half a day.
Estimated hourly cost for uplink usage.
Estimated cost per minute for finished, broadcast quality video
tape. This is known as a NOVA quality video.
NOTES: • Costs associated with development of high quality CD-ROMS are not yet
available.
• These estimates or "Rules of Thumb" are only rough estimates that should be
helpful in early training and planning sessions. These estimates are still tentative
and are subject to change.
• These estimates can and must be substantially more refined as specific
requirements are known. So, the earlier the Education and Outreach Group
(EOG) becomes involved in the process, the more quickly a reliable cost estimate
can be made.
• The EPA/STAPPA/ALAPCO Training Committee is currently developing a
template for training efforts and has a continuing function of considering training
priorities and coordinating efforts.
For further information, contact Ron Townsend (919) 541-2498 for
MACT-specific planning efforts.
-------
-------
APPENDIX E
AIRS Facility Subsystem
-------
-------
AIRS FACILITY SUBSYSTEM
AIRS stands for Aerometric Information Retrieval System.
AIRS is the database management system for the national database for ambient air
quality, emissions (criteria and air toxics related), and compliance data, including
permit tracking.
The AIRS Facility Subsystem (AFS) is one of four subsystems under AIRS.
Re- engineering project currently scheduled to begin in fiscal year 1998.
Information included in AFS:
> Number and location of facilities in a source category
>• Types of control equipment with efficiency estimates
»• Emissions estimations from EPA Reference test methods
For more information, contact Chuck Isbell (ITPDD/Infbrmation Management
Group) at (919) 541-5448.
-------
-------
APPENDIX F
Example Specific Model Implementation Plan
for Ethylene Oxide Commercial Sterilizers MACT Standard
-------
-------
Example SMTP for Ethvlene Oxide Commercial Sterilizers
The following is a sample of what a Specific MACT Implementation Strategy should
resemble. It includes an explanation of the implementation phases for this regulation.
Additional implementation aids such as applicability flow charts or examples, source listings,
trade associations, specific source identification techniques, standard permit language, inspection
checklists, etc. are not included at this time but are under consideration.
Even though this regulation has already been promulgated, this sample implementation
strategy is written as if it was published with the rule. As a result, some sections will refer to
steps that may have already occurred.
Regulation Summary
Regulation:
Ethylene Oxide Sterilization Facilities
This regulation controls ethylene oxide emissions for sterilization or fumigation
operations.
Citation:
Published:
Effective Date:
Applicability:
Exemptions:
Categories:
Initial Notification:
40 CFR Part 63, Subpart O
59 FR 62585
December 6,1994
All sterilization sources using ethylene oxide in sterilization or
fumigation operations
beehive fumigators, research and laboratory facilities, and
operations at sources like doctor or veterinarian offices
Sources using less than 1 ton of ethylene oxide are only
required to keep records of 12 month rolling average of
ethylene oxide use
Sources using between 1 ton and 10 tons of ethylene oxide
Sources using 10 tons or more of ethylene oxide
2.
3.
1.
2.
April 5,1995 for existing sources, categories 2 & 3
120 days from startup for new sources, categories 2 & 3
-------
Compliance Dates: 1.
2.
Emission Points:
1.
2.
3.
December 6,1998 for sources with startup before
December 8,1998
Upon startup for sources with startup on or after
December 8,1998
Sterilization Chamber Vent
99% reduction for categories 2 & 3
Aeration Room Vent
99% reduction or 1 ppmv for category 3
Chamber Exhaust Vent
99% reduction for category 3
5300 ppmv for category 2
Performance Tests: June 4,1999 for existing sources, all emission points 180 days
after startup for new sources, all emission points
Notification of
Compliance Status:
August 3,1999 for existing sources, all emission points 60 days
after completion of performance tests for new sources, all emission
points
Phase One - Education
EPA will be offering satellite training on this regulation on {date}. The regional offices
should assess their own interest and that of their states and ensure appropriate attendance. The
satellite training will also be video taped. The video tape will be available from {location}, and
EPA expects the video to be available after {date}.
In addition to this training, EPA has issued a fact sheet which is available on the TTN
bulletin board along with the regulation and the background information document. On TTN,
the fact sheet and rule are dated November 23,1994 and located hi the "Recently Signed Rule"
section of the Clean Air Act board. The background information document, dated June 17, 1993,
is located in the "Title HI" section of the same board. Furthermore, the OAQPS Title HI online
Q&A bulletin board is available for inquiries about this rule. This information is also accessible
via the United Air Toxic Website at Http://www.epa.gov/oar/oaqps/airtox.
The following are a list of contacts for this rule:
OAQPS:
OECA:
Region 1:
Region 2:
Region 3:
Region 4:
David Markwordt
Karin Leff
{name}
{name}
{name}
Phillip Bamett
(919)541-0837
(202) 564-7068
(404) 347-2904
-------
Region 5: {name}
Region 6: {name}
Region 7: {name}
Region 8: {name}
Region 9: {name}
Region 10: {name}
In addition, this rule may impact small businesses; additional assistance regarding this
issue may be obtained the following regional small business contacts:
Region 1:
Region 2:
Region 3:
Region 4:
Region 5:
Region 6:
Region 7:
Region 8:
Region 9:
Region 10:
{name}
{name}
{name}
{name}
{name}
{name}
{name}
{name}
{name}
{name}
Each region should also establish a contact for each of its states and begin communication
regarding the regulation. Regular conference calls, either for this rule alone or as part of a larger
call, are appropriate.
Phase Two - Source Population Identification
Since this rule involves area sources, EPA recommends following the practices and
procedures for identifying sources presented in the "Cookbook" prepared by EPA. Following
these procedures, EPA does not anticipate any difficult applicability questions for these sources.
Phase Three - Outreach
EPA has prepared a fact sheet about this rule and is currently preparing an
implementation document that includes summaries of the requirements of the rule, applicability
flow diagrams, example recordkeeping and reporting forms, inspector checklists, and other
information to help implementation. The video of the satellite training course may provide
material to educate the regulated community about the rule. The implementing agency and
regions should be available for any trade shows related to this industry. Coordination with the
small business assistance program for this regulation is advised.
Source population identification and outreach for this rule should be executed quickly as
the initial notifications are due by April 5,1995 for existing sources. However, additional time
for outreach is provided in that the first compliance date is December 6,1998, for an existing
source.
-------
Although pollution prevention activities for this source category may be limited, affected
sources should be encouraged to investigate alternative sterilization techniques like antiseptic
washes and thermal drying or using an autoclave where such techniques may be appropriate.
Regional Pollution Prevention Contacts are:
Region 1
Region 2
Region 3:
Region 4
Region 5
Region 6:
Region 7:
Region 8:
Region 9:
Region 10:
{name}
{name}
{name}
{name}
{name}
{name}
{name}
{name}
{name}
{name}
Phase Four - Compliance Assurance
This phase does not begin in earnest until after December 6,1998. However, the initial
notification is necessary by April 5,1995. Appropriate information requests may be necessary to
obtain all initial notifications.
Beginning in December 1998, the implementing agency should include this source
category in their inspection planning. As part of this, the implementing agency needs to assure a
presence in the regulated community particularly during the early period after a compliance date.
If a state or local agency is implementing the rule and is inspecting all major sources, then the
major ethylene oxide sterilization facilities will be addressed. If the state is using the Inspection
Targeting Model or some other targeting method, the agency should assign enough weight to this
source category to insure appropriate coverage. Area sources within a state are somewhat
different. Compliance assurance may be achieved by a combination of techniques including
requiring reports, certifications, record keeping, etc. These factors are usually imposed through
the permitting process.
If EPA is the implementing agency, targeting of major and area sources for inspection is
also needed. Due to EPA's more limited number of inspectors, consideration of regional
resources is important. EPA can maintain a sufficient presence within the sector by using
regional personnel and perhaps contractors. Furthermore, even if EPA is not the implementing
agency, the regional office may wish to establish a small federal inspection presence among the
sterilization facilities.
As time moves beyond the compliance date, less emphasis to this sector may be applied if
compliance rates are good. However, after several years, the sector should be targeted again. In
order to determine compliance rates, the implementing agency must establish a tracking system.
-------
AIRS is available for this function. If an implementing agency uses another system other than
AIRS, the agency must also ensure that AIRS is updated in accordance with EPA policy on
minimum data elements.
Finally, as part of assessing compliance, the implementing agency needs to decide how to
deal with violations. Whatever the decision, the plan for each implementing agency should be
internally consistent and should include pollution prevention options. For this rule, compliance
assistance is not generally advised because there is a period of two and half years to prepare for
the requirements. As stated in phase three, affected sources should be encouraged to investigate
alternative sterilization techniques. Some area sources or small businesses may be granted some
assistance if they have trouble establishing initial compliance, such as an opportunity to re-test
Phase Five - Enforcement
Notwithstanding any discussion of compliance assistance, the implementing agency
should proceed with enforcement of violations involving an exceedance of an emission limit or a
failure to conduct monitoring. The agency may use its enforcement discretion regarding a single
reporting omissions, such as failure to submit timely an initial notification or a compliance
certification notification, provided prompt correction is made. Enforcement is appropriate for
repeat omissions involving any standard.
Since this rule regulates area sources, the regional offices should consider using field
citations for violations that merit an action. This would simplify the process for the source and
EPA. Also, whenever a SEP is considered as part of an enforcement case settlement, pollution
prevention activities should be encouraged.
Phase Six - Additional Activities
One of the major ancillary activities will involve the permitting of the sources. All
sources other than those using less than one ton of ethylene oxide are required to obtain a Title V
permit. The permit must contain:
1. the requirement for the initial notification;
2. the emission standards for sterilization chamber vents, aeration room vents, and
chamber exhaust vents;
3. the compliance date for each emission point;
4. the performance test requirement for each vent;
5. the requirement for the notification of compliance status;
6. the monitoring requirements;
-------
7. the reporting requirements; and
8. the applicable General Provisions.
Many of these requirements are highlighted in the regulation summary section at the
beginning of this report.
With respect to the General Provisions, the permit may reference the General Provisions
without restating each minute section or may explicitly state each portion. The implementing
agency should be advised that explicitly including all requirements in the General Provisions will
result in a larger permitting effort. Also, many times the General Provisions include options. To
address the options, the permitting agency must answer the following: does the permit contain all
options, growing even larger, or does the permit only contain the options appropriate for the
source? If the latter is used, the permit may have to be reopened every time a source switches
options. Regardless of the technique used to include the General Provisions, the reference table
within the regulation is an excellent guide between the two options.
For area sources, the Title V permitting requirement has been deferred for five years from
the approval of a state's Title V program. These source must submit their permit application
within 12 months of the expiration of the deferral period.
Other additional activities include processing of special requests: compliance extensions,
performance test waivers, etc. Sufficient resources should be allocated to cover the processing of
these requests. For this rule, such requests should not be excessive. However, there will be
performance tests for multiple emission points for each facility, and these results will need a
review. An implementing agency should anticipate most of these test results beginning in June
1998 and ending in August 1988.
Reference Materials
The following list contains reference materials for this rule and their location.
Background Information Document (BID), TTN - Clean Air Act Board, Title III
Section
• etc.
-------
Source Identification Cookbook
-------
-------
Source Identification Cookbook
Final Draft September 17.1997
ENABLING DOCUMENT
SOURCE IDENTIFICATION PROCEDURES FOR SOURCES
SUBJECT TO REGULATIONS UNDER SECTION 112(d) OF THE
CLEAN AIR ACT AS AMENDED IN 1990
Developed in Cooperation with
US Environmental Protection Agency
(Region 4, OAQPS, & OECA)
State of Georgia
State of New York
State of Florida
State of Illinois
[ PLEASE REVIEW AND SUBMIT ALL WRITTEN COMMENTS BY
OCTOBER 14,1996, WRITTEN COMMENTS SHOULD BE MAILED TO:
ANTHONY TONEY
US, EPA REGION 4
APTMD
ATLANTA FEDERAL CENTER, 12th FLOOR
100 ALABAMA STREET, N.W.
ATLANTA, GA 30303
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TABLE OF CONTENTS
Section Eag£
ACKNOWLEDGEMENT 1
NOTICE 2
1.0 INTRODUCTION 1-1
1.1 Purpose 1-1
1.2 Background 1-1
1.3 MACT Implementation Schedule 1-2
2.0 MACT SOURCE IDENTIFICATION PROCESS 2-1
2.1 Step 1 2-3
2.1.1 State/County/Local Business License Processes 2-4
2.1.2 County & City Chamber of Commerce 2-4
2.1.3 Regional Telephone Directory (i.e., WinPhone, PhoneDisc '95, etc.) .. 2-5
2.1.4 Databases of Corporate Affiliations (e.g., Business Dunn and
Bradstreet) 2-5
2.1.5 Department of Industry & Trade/Commerce 2-6
2.2 Step 2 2-6
2.2.1 State Department of Revenue 2-6
2.2.2 State and Local Agency Resources 2-6
2.2.3 Toxic Release Inventory 2-7
2.2.4 EPA's RCRA Hazardous Waste Disposal Notification Database 2-7
2.3 Step 3 2-8
2.3.1 Industry Representatives 2-8
2.3.2 Trade Associations 2-8
2.3.3 Equipment & Raw Material Suppliers/End Product Users 2-9
3.0 COLLOCATED SOURCES 3-1
3.1 Collocation, Federally Enforceable Limits, and PTE Policy 3-2
4.0 RESULTS OF PILOT TESTING FOR EXISTING MACTs AND STATE
GENERATED LIST 4-1
4.1 State of New York MACT Source Identification Pilot Study 4-1
4.1.1 CD-ROM Databases 4-1
4.1.2 Chromium Electroplaters 4-2
4.1.3 Wood Furniture Manufacturers 4-3
4.1.4 Conclusion 4-4
4.1.5 Other CD-ROM Databases 4-5
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TABLE OF CONTENTS (Continued)
Section
4.2 State Of Georgia Halogenated Solvent Cleaning
Machine Pilot Study .............................................. 4-5
4.2.1 Introduction .............................................. 4-5
4.2.2 Study and Results .......................................... 4-6
4.2.3 Conclusions .............................................. 4-6
4.2.4 Collocated Sources ......................................... 4-7
4.2.5 Wood Furniture Cookbook ................................... 4-8
4.3 Florida Source Identification Pilot Study ........... ................... 4-8
4.4 Illinois Environmental Protection Agency (IEPA) ...................... 4-10
APPENDIX A
APPENDIX B
APPENDIX C
APPENDIX D
APPENDIX E
APPENDIX F
APPENDIX G
IV
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ACKNOWLEDGMENT
This document was prepared by the U.S. Environmental Protection Agency as a result of
Brown Summit n, April 10-12,1995, in North Carolina. This document is the result of a joint
effort of the following workgroup: Anthony Toney, Linda Anderson-Carnahan, USEPA
Region 4; John Schaefer, EPA OAQPS; Jeff Kenknight, EPA OECA; Susan Fields, Nebraska
Department of Environmental Quality; Jimmy Johnston, Art Stelson and Cindy McAlpine,
Georgia Environmental Protection Division; Mary Sullivan Douglas, STAPPA/ALAPCO; Hank
Naour, Illinois EPA, Bureau of Air Quality; Sarah Laumann, Colorado Department of Health;
John Glunn and Alex Meng, State of Florida Department of Environmental Protection; Thomas
Gentile and Barbara Nuffer, New York State Department of Environmental Conservation.
EPA would like to thank all individuals that contributed their efforts toward the
development of this project. Your assistance is duly noted and appreciated.
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NOTICE
This document has been reviewed in accordance with U.S. Environmental Protection
Agency policy and approved for publication. Mention of trade names or commercial products
does not constitute endorsement or recommendation for use.
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1.0 INTRODUCTION
1.1 Purpose
The primary purpose of this document is to provide State and local environmental
regulatory agencies guidance for identifying and compiling a list of sources subject to regulation
under section 112(d) of the Clean Air Act as amended in 1990. In general, this document
contains guidelines and/or procedures on suggested activities which can be undertaken to identify
such sources subject to maximum available control technology (MACT) standards. Use of this
document will facilitate the efficient implementation of all MACT standards and ensure the level
of environmental protection mandated by the Act. The document assumes a general knowledge
of title III of the Act and the promulgated regulations thereto. Readers not familiar with these
programs should refer to the sections mentioned in the "Background" and to the General
Provision for MACT implementation, 40 CFR 63, Subpart A. This document should clarify
typical questions regarding source identification and should help facilitate the development of
comprehensive lists of affected facilities. As we learn more through the actual process of source
identification, this document will be revised accordingly. It is hoped that this document becomes
an evolving, "living document" that will experience continuous improvement through the fine
tuning of the source identification process.
1.2 Background
Critical to an agency's success in limiting hazardous air pollutant emissions is its ability
to identify sources subject to MACT standards. Listings of specific sources subject to MACT or
procedures that can be used to identify sources within a jurisdiction are necessary for a number
of reasons. The resources required of a regulatory agency to implement a standard will be a
function of the number of sources subject to the MACT. Further, because some sources will not
be required to obtain a title V permit, state and local agencies willing to oversee implementation
of such standards for non-Part 70 sources need to be able to gauge the resources required in order
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to make a commitment. Finally, sources must be easily and quickly identified to facilitate the
transfer of information on new standards.
During an April 1995 meeting of EPA OAQPS, OECA, OGC and Regional Offices with
State and Local air program representatives (Brown Summit n), one of the action items
identified included the development of a standard method to identify sources subject to MACT
standards. The workgroup convened on this action item envisioned the development of a
"cookbook" for this process.
1.3 MACT Implementation Schedule
With the promulgation of each MACT standard, there are several administrative actions
which must be undertaken in a relatively short time-frame. These requirements dictate the need
for a comprehensive listing of subject sources. A comprehensive listing of subject sources will
ensure the proper allocation of resources by the implementing agencies. Although MACT
requirements will vary depending on whether a source is an existing, new area or new major
facility, the main events for a facility subject to MACT standards (primarily major sources) are
listed below:
1. Source submits an initial notification no later than 120 days after the effective
date of a relevant standard.
2. Source submits a notification at least 60 days before conducting a performance
test; at least 30 days before conducting opacity and visible emission observations.
3. A source submits a notification of compliance status within 60 days after the
performance test.
The above listed activity deadlines may be overridden by the specific requirements listed
in an individual MACT standard.
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2.0 MACT SOURCE IDENTIFICATION PROCESS
Ideally, in the process of developing a MACT for a source category, EPA will attempt to
identify all of the subject facilities in the process of gathering information for the standard. It is
anticipated that specific information (i.e., names and addresses) on subject sources will
eventually be made available by EPA on an electronic database. Unfortunately, a survey of
MACT development project leaders suggests that a complete listing of sources has not and will
not be available in many cases. Furthermore, state and local agencies have sometimes found that
lists provided by EPA can be inaccurate, incomplete or outdated. Although this document will
be applicable to all MACT source categories, we have initially identified two generic groups of
hard to locate sources to which this document will predominantly apply: 1) small, numerous
sources (e.g., dry cleaners); and 2) co-located sources (e.g., halogenated solvent cleaning
operations). Appendix A contains a listing of the MACT categories and identifies those
standards for which a complete list of subject sources will likely not be available from EPA. The
table also contains the anticipated SIC codes for the source category, the estimated number of
subject facilities, their trade associations, and whether the sources are expected to be collocated
in other source categories.
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Contained in this section are procedures which can be used to assist in the identification
of sources potentially subject to MACT standards. The procedures outlined in this section
should provide the most effective mechanism for source identification. The initial steps of the
following source identification procedure are designed to provide a comprehensive list of sources
potentially subject to the standard in question. Subsequent steps in the source identification
process will serve to narrow down the list to the sources most likely to be subject to the standard.
This series of steps has been constructed so that at any time during the source identification
process, if the implementing agency feels comfortable that the list is adequate and sufficient, the
agency may decide that it is more efficient to contact all sources identified as opposed to taking
additional steps to narrow down the universe. Implementing agencies may wish to perform the
various steps as they deem appropriate given the nature of the source category and the agency's
available resources (i.e., it may be appropriate to omit early steps and perform the later steps).
While EPA does not have access to all information necessary to assist in identifying
every affected source, this document contains a prioritized list of resources which could greatly
enhance the process of source identification. Because many of the resources available to state
and local agencies use the Standard Industrial Classification (SIC) codes to identify facilities, the
first and primary step in the identification process is to compile a list of potentially applicable
SIC codes. A partial listing of SIC codes may be obtained from Appendix A and/or the
Background Information Documents (BID) for each source category as identified by Project
Number in Appendix D. During the standard development process, EPA attempts to identify a
list of facility SIC codes in which the processes subject to the MACT may be located. This
information is made a formal part of the BID and is maintained as a part of the docket for each
respective MACT standards. However, the list of SIC codes identified may not be
comprehensive because the facilities operating within each particular source category type are
not specific to that one manufacturing process. In the initial stages of MACT development,
OAQPS & ORD Environmental Criteria and Assessment Office make every effort to generate a
listing of potential sources subject to standard. After the proposal, information from the docket
may be secured from each respective MACT project lead. A list of the current MACT project
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leads has been included as Attachment D of this document. After the MACT standard has been
proposed, the docket information may be obtained from the EPA Docket Center or the OAQPS
MACT project lead. As previously mentioned, it is hoped that OAQPS will eventually make the
list of sources identified for each MACT available through an electronic bulletin board system.
Such a system would also allow users to share additional information on source identification
techniques as well as outreach materials developed by different agencies.
Source identification will usually be a multi-step process which may include the
following activities: (1) development of a list of potential sources; (2) determining which sources
are actually employing the regulated process/equipment or emit the hazardous air pollutant
(HAP); and (3) determining which sources are potentially major, those that will probably seek
synthetic area status, and those which are area sources. The reliability of these listings can be
greatly enhanced through the use of databases, correspondences/dialogue with possible sources,
site visits, agency knowledge and expertise, etc. Throughout the identification process, the
implementing agency should review the generated lists and determine their usefulness. If a list
consists of numerous sources which are obviously not subject to the specific standard, that
particular database may not be appropriate for this process. This situation may occur when the
SIC code is too broad. The recommended activities and/or resources for identifying sources are
listed below:
2.1 Stepl
The EPA will make every effort to provide as much information on specific sources as
possible. The EPA will distribute (or make reasonably available) to each Regional Office the
source identification information obtained during the standard development process. Each
Regional Office will in-turn disseminate information to the respective implementing agencies.
Using these lists and the information in this "cookbook", each agency should review the
information to determine if any additional identification activities are warranted. Additionally,
as a result of another Brown Summit II action item, EPA is working with state and local agencies
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to develop an interactive, electronic bulletin board system to disseminate and receive information
on section 112. It is anticipated that a list of identified sources subject to each MACT standard,
by state, will be available on this system.
Starting with the list of facility SIC codes in which the processes subject to the MACT
may be located (and any additional information available from the EPA), there are a number of
databases and information sources that can be used to locate the names and addresses of
potentially subject facilities. Lists developed from the following databases should be cross-
checked against each other to enhance the level of accuracy of the final product, to better define
actual functions of facilities (users vs. Sellers), and to eliminate duplicitave listings from the final
list. Outlined below is a listing of such databases and/or resources:
2.1.1 State/County/Local Business License Processes
Within each state, county, or local governmental structure, there should be an entity
responsible for issuing business licenses. These agencies should have the capacity to download
information via a computer based on SIC codes or facility types and provide a list of facilities
potentially subject to a specific MACT standard, including names and mailing addresses. These
resources are usually housed within the Revenue and License Departments. Generally, there is a
service charge for the compilation of this information.
2.1.2 County & City Chamber of Commerce
Chambers of Commerce offices have the capability of supplying a listing of facilities
within their jurisdictions or memberships that fall within specified SIC categories. These offices
may be contacted as to the specific procedures one must follow. There maybe a fee for such
services in some areas.
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2.1.3 Regional Telephone Directory (i.e., WinPhone, PhoneDisc '95, etc.)
This directory provides a comprehensive listing of all businesses which serve in some
capacity, e.g., sales, manufacturing, repair, etc., under the respective SIC codes. The list is not
always reliable because many listed organizations are not producers or users of the HAPs.
Additionally, the source's operations (e.g., name, location) may have changed, reducing the
accuracy of the information. One can specify the business type by either its SIC code or by
selecting a key word or phrase. A word of caution, the address provided by this database is the
physical location, not the mailing address. Telephone directories of this type may generally be
obtained from any retail store that sells software packages, e.g., Office Depot, Best Buys,
Compuworld, etc. PhoneDisc is a common brand name that is generally available. Additional
information on PhoneDisc can be obtained by calling 1-800-284-8353 or (617) 639-2900.
2.1.4 Databases of Corporate Affiliations (e.g., Business Dunn and Bradstreet)
Database software systems such as Dunn & Bradstreet contains a vast amount of useful
business information. Included in the database are parent companies headquartered in the United
States and their subsidiaries, affiliates, and joint ventures. Dunn and Bradstreet offers an easy
way to identify facilities (name and location) and corresponding information such as type of
business and contact persons, based on various forms of facility identification information,
including SIC codes. With Dunn and Bradstreet, one can enter the SIC code or type of business
and generate a listing of facilities within the database that are compatible with the specific search
parameters. Additionally, Dunn and Bradstreet publishes a multi-volume Directory of Corporate
Affiliations which is the hard copy form of the Dunn and Bradstreet CD ROM version. These
type software packages may be obtained at various local retail computer software stores (Dunn
and Bradstreet database system can be obtained by contacting 1-800-234-3867).
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2.1.5 Department of Industry & Trade/Commerce
Within each state's governmental structure, the State Department of Industry and Trade or
Commerce has the capability of compiling an annual listing of all manufacturing facilities
operating during that fiscal year. The sources can be identified by SIC or facility type. A copy
of this publication can be obtained through the respective state's Industry and Trade or
Commerce office. The fee for this directory is generally less than $100.00.
2.2 Step 2
To better refine the list of potential sources generated from the various databases, each
agency should then, to the extent possible, verify the list using the resources listed below which
should have available a more reliable list of known and currently operational facilities.
2.2.1 State Department of Revenue
By canvassing the data sources above, a comprehensive list of potential-subject sources
may be generated. However, these references may not be completely up to date. A cross check
against recent annual taxation records may serve to narrow the list to currently operating
facilities.
2.2.2 State and Local Agency Resources
Within each state and local agency there exists a wealth of knowledge relating to the
location, operation, and existence of sources located in the jurisdiction of the implementing
agency. Such in-house resources include: Enforcement staff, Small Business Assistance
Program, State.
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Pollution Prevention Assistance Programs, State/Local Municipal Waste Treatment
Programs, state and local emission inventories, etc. Both staff and program documents may
provide valuable leads and timesaving information. The Emission Inventory Development
Guidance published by EPA can serve as a valuable resource in the identification of sources.
2.2.3 Toxic Release Inventory
It may be possible for regulatory agencies to further refine the list of potential sources
subject to a MACT through the use of the TRI database. Using the HAPs targeted by the MACT
for subject facilities, a cross check of the list generated by the above steps against a TRI list of
facilities with air emissions of targeted HAPs may reveal companies that are less likely to be
subject to the standard, regardless of their SIC code. One drawback of TRI is that many
industries/sources are exempt from its requirements. Also, TRI does not cover all HAPs. The
TRI database may be used to identify covered sources missed in steps 1-7. In this case, a list of
sources filing TRI reports of major emissions of the targeted HAPs is reviewed. This technique
may be especially useful when attempting to identify co-located MACT sources. (See Section
2.1 below)
2.2.4 EPA's RCRA Hazardous Waste Disposal Notification Database
This database provides a cross-media search function for facilities which are currently
regulated by EPA. Searches within this database may be performed using specific facility
information such as SIC codes, chemical names, chemical releases, etc. Regulatory agencies can
manipulate this database to refine the list generated from steps 1-8 in the same way that the TRI
database is used.
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2.3 Step 3
The following are additional resources that can be consulted for information on subject
sources. In many cases, it may not be possible to secure facility names and addresses from these
sources. However, these entities may be amenable to performing various outreach efforts and
distributing information pertaining to the rules (e.g., source applicability and notification forms).
If it is possible to secure a list of facilities from these sources, agencies may wish to utilize this
approach rather than to rely on SIC codes to develop a list of subject sources.
2.3.1 Industry Representatives
One resource often overlooked is industry experts themselves. When contact is made
with a source owner, operator, or environmental officer, much useful information may be
obtained. It is important that an agency representative present such a request as an effort to help
potentially covered sources get the information they need to achieve compliance. Such a request
might be presented in this way: "Do you know of anyone else that might be subject to this rule?
I'd like to get the information out to everyone so they'd have as much lead time as possible to
consider the implications of the rule."
2.3.2 Trade Associations
Regulatory agencies can solicit from national, regional or state associations, lists of
members which identify location and contact personnel for the facilities, or at a minimum, a list
of industry types which may be subject to the particular MACT standard. Trade associations
providing state and local agencies with a list of potentially subject facilities for outreach purposes
may benefit by increasing membership through offering meetings at which EPA makes
presentations on MACT standards. Implementing agencies also have the opportunity to publish
articles, notices, or announcements in trade journals for the affected industries. Although
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developed by and for the State of Wisconsin, Attachment G contains a list of trade associations
generally located in each state which are related to various MACT categories.
2.3.3 Equipment & Raw Material Suppliers/End Product Users
Suppliers of raw materials (e.g., chlorinated solvents) and users of end products may
provide an additional resource of information on sources subject to MACT standards. Agencies
should contact the users or distributors of specialty products, materials, chemicals, or any raw
materials used in processes which are subject to MACT regulation, in an effort to obtain
information on the types of facilities, known users, etc.
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3.0 COLLOCATED SOURCES
For many Part 63 standards, the regulated process is a small part of an overall
manufacturing process (i.e., degreasers, cooling towers, etc.). In these cases, the primary SIC
code of the facility in which the processes are located may be chiefly indicative of the primary
manufacturing process, rather than possible subordinate activities. For such collocated sources,
the databases and information resources listed in steps 1-6 may fail to generate a comprehensive
list of sources comprising the regulated activities. Therefore, additional efforts may be required
to generate an accurate list of the most likely collocated sources.
First and foremost, collocated HAP sources are for the most part located at major HAP
sources. Such sources, because they are major, will be required to obtain title V permits, and
usually, will be required to file annual emission inventories to support the title V fee assessment.
This mechanism can be utilized both directly and indirectly.
By working with the title V and emission inventory staff, the Title V permit application
and annual emission inventory forms can be crafted to directly identify activities which are
routinely collocated, such as degreasers, cooling towers or small boilers. For example, the form
could include a question tied to to a positive report of halogenated organic compounds, such as
"does the facility employ halogenated degreasing processes?" For collocation of other HAP-
emitting activities subject to various actual or scheduled MACT standards, collocated activities
may be identified indirectly, through review of the actual title V permit applications or annual
emission inventories submitted by major HAP sources.
The permit application should identify all emission units responsible for emissions of
regulated pollutants, and provide enough information to identify most activities subject to major
MACT standards. If the application does not clearly indicate a source's status relative to other
MACT standards, HAPs reported in the annual emission inventory may suggest that collocation
may be involved.
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An example of a collocated source could involve chromium electroplating collocated
with miscellaneous metal parts and products (surface coating) or reinforced plastics composite
production (the primary activity identified by the facility SIC code). Chromium electroplating is
often associated with metal parts manufacturing which is included in several surface coating
source categories, and could easily be distinguished from galvanizing (which is not included in a
listed source category) in the operating permit application itself. On the other hand, chromium
electroplating is less common at facilities involved in reinforced plastic composite production,
but would be suggested by chromium emissions reported in the annual emission inventory.
To obtain a greater sense of reliability, the list of sources identified through these
activities may be refined through various outreach efforts including mail-outs or questionnaires
to verify their status relative to suspected source categories. The level of effort expended by this
process will be governed by agency confidence in the quality of the list at this stage, as well as
available resources.
3.1 Collocation. Federally Enforceable Limits, and PTE Policy
In a memorandum dated May 16,1995, from John Sietz, Director, EPA, OAQPS, relating
PTE timing issues, the applicability of MACT for collocated sources was presented. In brief, the
memo states that if a facility contains equipment or processes included in multiple source
categories, it is possible that after application of the initial MACT or an earlier MACT standard
reducing the HAP PTE, the status of the source relative to the remaining source categories may
be changed. If compliance with a MACT standard revises a facility's PTE to a level below major
source thresholds, the facility would not be subject to subsequent major source MACT standards.
Additionally, the memo indicates that a facility may elect to take federally enforceable
limits to lower its PTE below major source thresholds, thereby avoiding the applicability of
major MACT standard(s). This option is available to covered sources up until the first
compliance date in each major MACT standard. Therefore, a source subject to multiple MACT
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standards might avoid the applicability of all standards by limiting its source-wide PTE before
the first compliance date in any of the standards.
Voluntary federally enforceable limits may also be taken by a source subject to multiple
MACT standards when compliance with a given standard or standards does not sufficiently
reduce the source's PTE. Such a HAP source may avoid coverage under subsequent standards by
taking additional voluntary federally enforceable limits until its source-wide PTE is below the
major source threshold, provided that the limits are taken before the first compliance date in each
of the standards it wishes to avoid.
Neither of these scenarios would relieve the facility from the applicability of those
MACT standards whose initial compliance date passed before the necessary reductions in PTE
were achieved. This "once major, not always major" policy is expected to reduce the burden of
MACT standards on collocated sources. However, the policy does complicate the identification
of sources subject to major source MACT standards, particularly if those standards are
promulgated within a relatively short time. In situations such as these, agencies may wish to
identify sources which have equipment or processes covered by the MACT standard as an initial
step, and subsequently determine major source applicability through additional correspondence
or outreach.
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4.0 RESULTS OF PILOT TESTING FOR EXISTING MACTs AND STATE
GENERATED LISTS
A number of states pilot tested the MACT identification approaches using lists of sources
previously generated by the regulatory agency for existing MACT standards for comparison.
The following section documents the findings of these pilots.
4.1 State of New York MACT Source Identification Pilot Study
4.1.1 CD-ROM Databases
CD-ROM databases can be a valuable resource for identifying businesses in specific
industries. These businesses can be sorted by SIC (Standard Industrial Classification) codes or
Yellow Page headings. These databases can be used to create mailing lists of sources who may
be subject to regulations under Section 112(d) of the Clean Air Act as amended in 1990.
The best place to start a search for these databases is in your state library. The New York
State Library has a business CD-ROM database available for use by New York State employees.
We have used this resource extensively to explore the potential for creating source lists and
discovered positive as well as negative features. Other databases have been located but not
researched and will be listed as potential resources. Most of these databases are available on a
trial basis before purchase for your own research, and we recommend that this be done.
We tested the American Business Disc (ABD), from American Business Information, Inc.
(1-900-555-5211). The following information is contained on the disc:
1. Company name
2. Address
3. Phone number
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4. Number of employees
5 . Estimated sales volume
6. Credit rating code
7. SIC code
8. Line of business description
You can perform the following searches:
1 . Geography- city, state, ZIP code, county or total U.S.
2. Company name
3. Yellow Page keyword
4. SIC code
5. Employee size range
6. Sales volume
Although you can download or print these records this can only be done for 50 records at
a time. The company will prepare more extensive lists for you for a fee. Since some of our lists
were in the 2,000 sources range, this was a major problem.
We extensively researched two industries with source lists previously compiled from
other databases, chromium electroplaters and wood furniture manufacturers, to cross check the
capability of the ABD to reproduce a similar list. These two searches were analyzed separately.
4.1.2 Chromium Electroplaters
It is impossible to sort out chromium electroplaters from general electroplaters based on
either SIC codes or Yellow Page keywords. We used the SIC code for Electroplating, Plating
and Polishing 3471. We found 268 sources in New York State using the ABD database,
178 sources were identified using the New York State Department of Labor (DOL) list of SIC
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code 3471. The New York State Department of Environmental Conservation (DEC) currently
has 111 chromium electroplaters permitted in New York State. Only 67 of these 111 sources
were found on the ABD.
We have also cross-checked our permit information on chromium electroplaters with
notification forms received by the USEPA Region 2 Office. This cross-check indicated more
direct outreach to NESHAP affected sources is needed. The Region 2 list also identified 11
additional platers who were not found in our current permit system. However, 8 of these 11 were
listed on the ABD.
The ABD did not prove to be totally inclusive, but it contained more sources than the
DOL listing. Attachment F is a list generated using the ABD as well as a printout of a detailed
look at a specific business.
4.1.3 Wood Furniture Manufacturers
A useful resource to identify SIC codes to use for searches is contained in EPA's Sector
Notebook on the Wood Furniture Industry. Page 5 contains a listing of the codes to use for the
wood furniture manufacturing industry. The codes identified are 2511,2512,2517,2521,2531,
and 2541 are as follows:
SIC CODE
2511
2512
2517
2521
2531
2541
178
43
43
11
102
69
30
28
_32_
66
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This comparison is not very impressive for the ABD list. However, SIC codes are
frequently listed incorrectly on the DOL listings and since this particular industry has a large
number of similar SIC codes, the number of businesses could be due to inaccuracies in the
assignment of SIC codes.
We identified 21 sources on our DEC list of permitted facilities who were most likely to
be subject to the wood furniture NESHAP. We found 13 of the sources on the ABD.
One problem with searching by company name is that if you have any misspellings or
incorrect names you cannot find them on the ABD. Our permitted sources' names are not always
100% accurate or the names may have been changed slightly. These possible discrepancies may
also explain the low number for this count.
4.1.4 Conclusion
As you can see from these two very different analyses, the ABD has proven useful but
not foolproof. A listing of permitted sources from your state agency is the best place to start to
locate specific industries. However, we know that these lists are not complete and it is useful to
have a resource to create listings based on SIC codes or Yellow Page keywords. This database is
very useful when you want to do a search of businesses based on the number of employees (e.g.,
to target small businesses who would be eligible for the Small Business Stationary Source
Technical and Environmental Compliance Assistance Programs that are located in each state, as
mandated by the Clean Air Act). Also, you can search by sales volume and determine the largest
businesses, which may produce high emissions. Accuracy of company names is a must when
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using this database. The biggest problem with the ABD is the ability to download only 50
sources at a time.
4.1.5 Other CD-ROM Databases
Harris Publishing's New York Manufacturers Directory (1-800-888-5900). These
editions are available for other states. The information provided includes: company name,
address, phone and fax numbers, and SIC codes. It is available as a book or in DOS or Windows
versions on diskette or CD-ROM. The cost varies depending on the size of your state.
Demonstration diskettes are available.
American Business Information's American Yellow Pages (1-800-555-5666). This
database is for the United States. It includes Yellow Page headings and company names. It is
available on CD-ROM and you can perform searches by company name and Yellow Page
headings. You can download to many label formats to create mailings.
DDA PhoneDisc Business 95. This product was found in the catalog "Windows
Warehouse." The information provided includes: company name, business type, address and
phone number. Searches can be done based on each of these items.
4.2 State Of Georgia Halogenated Solvent Cleaning Machine Pilot Study
4.2.1 Introduction
A pilot study was initiated for EPA Region 4 by the State of Georgia's Environmental
Protection Division to explore methods of locating MACT Standard or NESHAP affected
facilities. The particular MACT Standards chosen for the pilot test were 40 CFR Part 63,
Subpart T, Halogenated Solvent Cleaning Machines, commonly called the Degreaser Standard.
Three approaches were explored:
4-5
-------
Subpart T, Halogenated Solvent Cleaning Machines, commonly called the Degreaser Standard.
Three approaches were explored:
1. Locating sources using the SIC code list supplied with the MACT Standard and
the ProPhone phone directory.
2. Locating sources using the SIC code list supplied with the MACT Standard and
the Georgia Manufacturing Index.
3. Locating sources using ProPhone and the SIC codes from sources submitting
Initial Notifications for the MACT Standard.
4.2.2 Study and Results
Using ProPhone and the Georgia Manufacturers Index (GMI), we were able to identify
matches for two SIC codes (3442 and 3691) contained in the MACT Standard. ProPhone had 27
matches for SIC code 3442 and 124 matches for SIC code 3691. GMI had 64 matches for SIC
code 3442 and 12 matches for SIC code 3691. Of the identified sources from GMI and
ProPhone, none were on our Initial Notification list. When the listings were reviewed by
inspectors, they indicated that none of the listed sources had degreasers. When compared to our
State listing, we found one additional source which had failed to report their existence due to an
oversight. When attempting to locate degreasers based on the list of SIC codes of reported
degreasers, the list from ProPhone and GMI expanded to more than 3,000 facilities which is the
opposite trend we anticipated. Thus, we concluded that the procedure we initially used, which
was to send every source in the GMI a degreaser informational packet, was the most effective
method to insure proper notification of every source in Georgia.
4.2.3 Conclusions
In conclusion, we found the SIC code list from the MACT Standard, the GMI, and
ProPhone directories did not adequately locate degreasers or halogenated solvent cleaning
machines in Georgia. In addition, we were only able to locate one additional source by actual
4-6
-------
inspection of the facilities and that source failed to notify us by oversight. Thus, we conclude
that the initial approach we used, mass mailing, was the most effective in publicizing the MACT
Standard and getting sources to report the existence of halogenated solvent cleaning machines.
The additional paragraph on collocated sources is included for additional insight.
4.2.4 Collocated Sources
One problem facing state regulators is the identification of collocated sources. To give
insight into this problem, we chose two related MACT Standards and made a list of sources
reporting both affected processes. The MACT Standards we chose were halogenated solvent
cleaning machines (40 CFR Part 63 Subpart T) and chromium electroplaters (40 CFR Part 63
Subpart N).
. •-. ;-: :,.' ;:v: :•../ Source • . .'*'.••.
Delta Airlines Technical Operations Center
Hercules Automotive Products, Inc.
Lockheed Systems Company
Northwest Airlines Technical Operations
Robins Air Force Base
Roper Pump Company
Location
Atlanta, GA
Pelham, GA
Marietta, GA
Atlanta, GA
Robins AFB, GA
Commerce, GA
SIC Code
4512
Unknown
3721
4512
9711
Unknown
As indicated in the sample above, with the exception of the majority of sources seemingly
being related to the aerospace industry, there isn't any particular trend indicating the collocation
of these processes. Thus, one could conclude that the locating process for these MACT
Standards would require individual searches for these processes. Lastly, the presence of one
process at a facility would not necessarily indicate both are present onsite.
4-7
-------
4.2.5 Wood Furniture Cookbook
The same procedures were conducted on the Wood Furniture MACT. Using the GA
Manufacturers Index, there were 465 sources identified. The WinPhone'96 database contained
950 sources with 85 duplicates within database. When comparing the two databases, there were
194 sources identified in Winphone that were also contained in the GMI database. However,
GMI had more complete data on sources. Sources potentially subject to the wood furniture
standard were listed in SIC codes: 2434, 2511,2512, 2517,2519,2521, 2531, 2541,2599, and
5712. SIC Code 5712 included manufacturers & retail stores. Code 5712B is manufacturers of
custom furniture. The other 5712's (A, C, etc) were retail stores, for which there were thousands
of listings. Those listed as only 5712 were included in our reporting, although, this approach
may have inadvertently included some retailers. The GMI database was seemingly was
incomplete. USEPA's AIRS database had only 5-6 sources. A survey of major and synthetic
minor sources only identified a few facilities. All of which were contained on GMI and/or
WinPhone.
4.3 Florida Source Identification Pilot Study
Over the last year, the Florida DEP and the Florida Air Toxics Work Group, composed of
district and county air program staff, have worked together to develop a mechanism for
identifying facilities potentially subject to upcoming MACT standards. This database, known as
TINS, or the Toxics Inventory System, is about to become fully functional and will play a role in
Florida's efforts to locate and outreach to facilities which may become subject to new federal air
rules.
The TINS database is a stand alone subpart of the Department's oracle Air Resources
Management System (ARMS) database and can be accessed through the same procedures. TINS
will contain information about facilities which may be subject to upcoming rules, and therefore
the files will remain separate from the ARMS system. However, when a qualified user provides
4-8
-------
the TINS database with the information that signifies that a TINS facility is subject to a
promulgated rule, the TINS facility file will be transferred to ARMS and thereafter directly
available through the ARMS database.
The TINS database uses publicly and commercially available industry databases such as
the Directory of Florida Industries, the Toxics Release Inventory, and others to generate files of
facilities that may be subject to an upcoming or recently promulgated rules. A form letter can be
automatically generated which identifies the MACT rule, its applicability, the initial notification
requirements and the address of the agency to receive the facility's notification form.
When a new or proposed MACT is issued, it is anticipated that the Department's Air
Toxics Section will develop the initial TINS facility identification files from an available
industry database and generate letters to the facilities informing them of the rule applicability and
notification requirements. Districts and local program staff may also review the TINS if, to their
knowledge, additional facilities exist that may be subject to the rule, enter the necessary facility
information and generate letters to those facilities.
After an affected facility sends an initial notification to the appropriate permitting agency,
the agency staff can enter a code in a TINS screen that indicates that the facility is subject to the
promulgated rule. When this occurs, the facility's file is transferred to the ARMS database and
the facility is subsequently tracked as a regulated facility. TINS can also generate reports, such
as identified facilities, returned notifications and MACT affected SIC codes.
The TINS database was developed primarily to help with identifying small area sources
such as vapor degreasers and chrome electroplaters that are subject to recently promulgated
MACT standards. We recognized that ARMS may not have records of these facilities, and they
may not be covered by the Toxics Release Inventory either. A versatile, yet simple computer
program was needed that could utilize various industry databases to identify these smaller
operations.
4-9
-------
As the list of candidate general permits continues to grow and the Department searches
for ways to make suitable facilities aware of this permitting mechanism, it may be feasible to use
the TINS database as a means for targeting appropriate facilities and for sending fact sheets to
the facility's address. The TINS database is navigated using the same commands as the ARMS
database and can be learned rather quickly.
Appendix C contains replicas of the computer screens in TINS and the directions for its
intended users. A sample form letter that can be generated from TINS is also attached. For more
information about the design and use of the TINS database, please call John Glunn at
(904) 488-0114. To learn more about the functional properties of TINS or for programming
information, please call Alex Men at the same number.
4.4 Illinois Environmental Protection Agency flEPA)
IP A has used a number of cookbook elements in determining the NESHAP effected
sources in Illinois; the top four sources are D&B, Department of Revenue for both the State and
Chicago, Department of Commerce, and Trade Associations;
These four resources supplemented our standard database (IEPA files, title V data, state
permitting data, AT telephone CD-ROM data) and resulted in significant increases in "hits" for
potential effected sources.
For the Dry Cleaning standard, the Allied Trade Associations resulted in an additional
260 Dry Cleaning sources for consideration; the Chicago Dept. of Revenue added an additional
10 chrome electroplaters; and the State DAR resulted in an additional 2400 solvent cleaning
"hits."
IPA is reviewing the CD-ROM telephone directory the Cookbook highlighted and is
expected to establish Agency-wide access to the database.
4-10
-------
One of the better sources has turned out to be the Allied Trades Associations. The
solvent cleaning suppliers have also been very cooperative in working with us and their
customers in learning about the standard and understanding the reporting and control
requirements.
4-11
-------
-------
APPENDIX A
-------
-------
APPENDIX B
-------
-------
FUEL COMBUSTION
Category
Industrial Boilers
Institutional/Commercial Boilers
Process Heaters
Stationary Internal Combustion Engines
Stationary Turbines
NON-FERROUS METALS PRODUCTION
Category
Secondary Lead Smelting
Primary Aluminum Production
Primary Copper Smelting
Primary Lead Smelting
Secondary Aluminum Production
Primary Magnesium Refining
11/15/2000
FERROUS METALS PROCESSING
Category
Coke Ovens: Charging, Top Side and Door Leaks
Ferroalloys Production
Steel Pickling - HC1 Process
Coke By-Product Plants
Coke Ovens: Pushing, Quenching, and Battery Stacks
Integrated Iron & Steel Manufacturing
Iron Foundries
Steel Foundries
MINERAL PRODUCTS PROCESSING
Category
Mineral Wool Production
Portland Cement Manufacturing
Wool Fiberglass Manufacturing
Alumina Processing
Asphalt Concrete Manufacturing
Asphalt Processing
Asphalt Roofing Manufacturing
Asphalt/Coal Tar Application - Metal Pipes
Chromium Refractories Production
Clay Products Manufacturing
Lime Manufacturing
Taconite Iron Ore Processing
PETROLEUM AND NATURAL GAS PRODUCTION
Promulgation
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
Promulgation
11/15/94
11/15/97
11/15/97
11/15/97
11/15/97
Promulgation
11/15/92
11/15/97
11/15/97
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
Promulgation
11/15/97
11/15/97
11/15/97
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
B-l
-------
Category
Petroleum Refineries - Other Sources Not Distinctly Listed
Oil and Natural Gas Production
Petroleum Refineries - Catalytic Cracking (Fluid and Other) Units and Sulfur
LIQUIDS DISTRIBUTION
Category
Gasoline Distribution (Stage 1)
Organic Liquids Distribution (Non-Gasoline)
SURFACE COATINGS PROCESSES
Category
Aerospace Industries
Magnetic Tapes (Surface Coating)
Printing/Publishing (Surface Coating)
Shipbuilding and Ship Repair (Surface Coating)
Wood Furniture (Surface Coating)
Auto and Light Duty Truck (Surface Coating)
Flat Wood Paneling (Surface Coating)
Large Appliance (Surface Coating)
Manufacture of Paints, Coatings and Adhesives
Metal Can (Surface Coating)
Metal Coil (Surface Coating)
Metal Furniture (Surface Coating)
Miscellaneous Metal Parts and Products (Surface Coating)
Paper and Other Webs (Surface Coating)
Plastic Parts and Products (Surface Coating)
Printing, Coating, and Dyeing of Fabrics
WASTE TREATMENT AND DISPOSAL
Category
Solid Waste, Treatment, Storage and Disposal Facilities (TSDF)
Publicly Owned Treatment Works (POTW) Emissions
Hazardous Waste Incineration
Municipal Landfills
Sewage Sludge Incineration
Site Remediation
Promulgation
11/15/94
11/15/97
11/15/97
Promulgation
11/15/94
11/15/2000
Promulgation
11/15/94
11/15/94
11/15/94
11/15/94
11/15/94
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
Promulgation
11/15/94
11/15/97
11/15/2000
11/15/2000
11/15/2000
11/15/2000
B-2
-------
AGRICULTURAL CHEMICALS PRODUCTION
Category
2,4-D Salts and Esters Production
4,6-Dinitro-O-Cresol Production
4-Chloro-2-Methylphenoxyacetic Acid Production
Captafol Production
Captan Production
Chloroneb Production
Chlorothalonil Production
Dacthal (tm) Production
Sodium Pentachlorophenate Production
Tordon (tm) Acid Production
FIBERS PRODUCTION PROCESSES
Category
Acrylic Fibers/Modacrylic Fibers Production
11/15/97
Rayon Production
Spandex Production
FOOD AND AGRICULTURAL PROCESSES
Category
Baker's Yeast Manufacturing
Cellulose Food Casing Manufacturing
Vegetable Oil Production
Promulgation
11/15/97
11/15/97
11/15/97
11/15/97
11/15/97
11/15/97
11/15/97
11/15/97
11/15/97
11/15/97
Promulgation
11/15/2000
11/15/2000
Promulgation
11/15/00
11/15/00
11/15/00
This comparison is not very impressive for the ABD list. However, SIC codes are
frequently listed incorrectly on the DOL listings and since this particular industry has a large
number of similar SIC codes, the number of businesses could be due to inaccuracies in the
assignment of SIC codes.
Acrylonitrile-Butadiene-Styrene Production
Butyl Rubber Production
Epichlorohydrin Elastomers Production
Epoxy Resins Production
Ethylene-Propylene Elastomers Production
Hypalon (tm) Production
Methyl Methacrylate-Acrylonitrile-Butadiene-Styrene Production
Methyl Methacrylate-Butadiene-Styrene Terpolymers Production
Neoprene Production
Nitrile Butadiene Rubber Production
Nitrile Resins Production
Non-Nylon Polyamides Production
Polybutadiene Rubber Production
Polyethylene Terephthalate Production
11/15/94
11/15/94
11/15/94
11/15/94
11/15/94
11/15/94
11/15/94
11/15/94
11/15/94
11/15/94
11/15/94
11/15/94
11/15/94
11/15/94
B-3
-------
Polystyrene Production
Polysulfide Rubber Production
Styrene-Acrylonitrile Production
Styrene-Butadiene Rubber and Latex Production
POLYMERS AND RESINS PRODUCTION
Category
Acetal Resins Production
Amino Resins Production
Flexible Polyurethane Foam Production
Nylon 6 Production
Phenolic Resins Production
Polycarbonates Production
Reinforced Plastic Composites Production
Alkyd Resins Production
Boat Manufacturing
Butadiene-Furfural Cotrimer (R-l 1) Production
Carboxymethylcellulose Production
Cellophane Production
Cellulose Ethers Production
Flexible Polyurethane Foam Fabrication Operations
11/15/2000
Maleic Anhydride Copolymers Production
Methylcellulose Production
Polyester Resins Production
Polymerized Vinylidene Chloride Production
Polymethyl Methacrylate Resins Production
Polyvinyl Acetate Emulsions Production
Polyvinyl Alcohol Production
11/15/2000
Polyvinyl Butyral Production
11/15/2000
Polyvinyl Chloride and Copolymers Production
PRODUCTION OF INORGANIC CHEMICALS
Category
Chlorine Production
Cyanuric Chloride Production
Hydrogen Cyanide Production
Sodium Cyanide Production
Ammonium Sulfate Production - Caprolactam By-Product Plants
Antimony Oxides Manufacturing
Fume Silica Production
Hydrochloric Acid Production
Hydrogen Fluoride Production
11/15/94
11/15/94
11/15/94
11/15/94
Promulgation
11/15/97
11/15/97
11/15/97
11/15/97
11/15/97
11/15/97
11/15/97
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
Promulgation
11/15/97
11/15/97
11/15/97
11/15/97
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
B-4
-------
Phosphate Fertilizers Production
Phosphoric Acid Manufacturing
Quaternary Ammonium Compounds Production
Uranium Hexafluoride Production
RODUCTION OF ORGANIC CHEMICALS
Category
Synthetic Organic Chemical Manufacturing
MISCELLANEOUS PROCESSES
Category
Commercial Dry Cleaning (Perchloroethylene) - Transfer Machines
11/15/92
Industrial Dry Cleaning (Perchloroethylene) - Dry-To-Dry Machines
Industrial Dry Cleaning (Perchloroethylene) - Transfer Machines
Chromic Acid Anodizing
Commercial Sterilization Facilities
Decorative Chromium Electroplating
11/15/94
Halogenated Solvent Cleaners
Hard Chromium Electroplating
Industrial Process Cooling Towers
Butadiene Dimers Production
Polyether Polyols Production
Pulp & Paper Production
Wood Treatment
Aerosol Can-Filling Facilities
11/15/2000
Benzyltrimethylammonium Chloride Production
Carbon Black Production
Carbonyl Sulfide Production
Chelating Agents Production
Chlorinated Paraffins Production
Dry Cleaning (Petroleum Solvent)
Ethylene Processes
Ethylidene Norbomene Production
Explosives Production
Friction Products Manufacturing
Hydrazine Production
11/15/2000
Leather Tanning adn Finishing Operations
Marine Vessel Loading Operations
Oxybisphenoxarsine/1,3-Diisocyanate Production
Paint Stripper Users
Photographic Chemicals Production
11/15/2000
11/15/2000
11/15/2000
11/15/2000
Promulgation
11/15/92
Promulgation
11/15/92
11/15/92
11/15/94
11/15/94
11/15/94
11/15/94
11/15/94
11/15/97
11/15/97
11/15/97
11/15/97
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
11/15/2000
B-5
-------
Phthalate Plasticizers Production 11/15/2000
Plywood/Particle Board Manufacturing 11/15/2000
Rocket Engine Test Firing 11/15/2000
Rubber Chemicals Manufacturing 11/15/2000
Semiconductor Manufacturing 11/15/2000
Symmetrical Tetrachloropyridine Production
11/15/2000
Tire Production 11/15/2000
AREA SOURCE CATEGORIES
Category Promulgation
Chromic Acid Anodizing (Area Sources) 11/15/94
Commercial Sterilization Facilities (Area Sources) 11 /15/94
Decortive Chromium Electroplating (Area Sources) 11/15/94
Halogenated Solvent Cleaners (Area Sources) 11/15/94
Hard Chromium Electroplating (Area Sources) 11/15/94
B-6
-------
APPENDIX C
-------
-------
APPENDIX D
-------
-------
Table D-l.
*^V ,-"' ^'vv * % ' ""'£*'•
• JU . - - ^, - Protect Title * "'- &
Acrylic/Modacrylic Fibers Production
Aerospace Coating MACT Standard and CTG
Antimony Oxides Production NESHAP
Architectural and Industrial Maintenance
Coatings
Asbestos MACT/GACT Standard
Asphalt Roofing and Processing NESHAP
Baker's Yeast Manufacturing MACT
Boat Manufacturing Neshap
Case-by-Case MACT Database (Guidance
Document)
Chlorine Manufacturing NESHAP
Chromium Chemicals Manufacturing
Chromium Elecroplating MACT Standard
Chromium Refractories Manufacturing
NESHAP
Coke By-Product Plants
Combustion (Gas) Turbines NESHAP &
NSPS
Consolidated Federal Air Rules
Cyanide Chemical Manufacturing
Dry Cleaning MACT Standard
Electric Utility Air Toxics Study
Ferroalloy Industry MACT Standard
Flexible Polyurethane Foam Fabrication Oper
MACT
Flexible Polyurethane Foam Production
Hazardous Organic NESHAP (litigation)
Hazardous Waste TSDF - RCRA Air Rules
Phase II
Hydrogen Fluoride Production NESHAP
Industrial and Commercial Waste Incinerators
Industrial Combustion Coordinated Rule
Making
*f*NNU
Hsmber
93/56
91/67B
96/13
89/12
80/41A
95/04
94/13
95/15
93/11
92/10
93/51
85/02A
95/07
95/28
95/10
95/25
93/57
85/06B
91/41
91/45
96/10
93/49
86/23
84/11 A
95/13
95/01
96/11
% ",,.-, -: V." frt^,"^
f y> v v=>->^ '••xvS;:
Protect &e^|
Anthony Wayne
Jim Szykman
Conrad Chin
Ellen Ducey
Susan Zapata
Juan Santiago
Anthony Wayne
Madeleine Strum
Susan Zapata
Iliam Rosario
Iliam Rosario
Lalit Banker
Susan Zapata
Lula Melton
Sims Roy
Richard Colyer
Phil Mulrine
George Smith
William Maxwell
Conrad Chin
David Svendsgaard
David Svendsgaard
Janet Meyer
Michele Aston
Richard Colyer
George Smith
Fred Porter
^ ™. ' T-* *^. .
(919)541-5439
(919)541-4516
(919)541-1512
(919)541-5408
(919)541-5167
(919)541-1084
(919)541-5439
(919)541-2383
(919)541-5167
(919)541-5308
(919)541-5308
(919)541-5420
(919)541-5167
(919)541-
(919)541-5263
(919)541-5265
(919)541-5289
(919)541-1549
(919)541-5430
(919)541-1512
(919)541-2380
(919)541-2380
(919)541-5254
(919)541-2363
(919)541-5265
(919)541-1549
(919)541-5251
D-l
-------
Table D-l. (Continued)
"% - '"" ' - ," - ,', : " , /-'^
:5y ^^^^^^'^^
[ndustrial-Commercial-Institutional Boilers
MACT
Integrated Iron & Steel Manufacturing
Integ. Rule for Paper, Film, & Foil Coatings
Internal Combustion Engine NESHAP &
NSPS
Iron and Steel Foundries MACT Standard
Landfills MACT
Lime Manufacturing NESHAP
MACT Generic Rule
MACT Partnerships Program Development
Manufacture of Tetrahydrobenzaldehyde
(THBA)
Medical Waste Incineration
Mineral Wool Production MACT Standard
Miscellaneous Cellulose Categories MACT
Miscellaneous Organic NESHAP (MON)
Municipal Landfills NSPS and 1 1 l(d)
Municipal Waste Combustion Standard II &
m
NESHAP for Ethylene Processes
NESHAP for the Rubber Tire Manufacturing
Industry
Nylon 6 Production
Off-Site Waste and Recovery Operations
MACT
Oil & Gas Production & Gas Transmission &
Storage
Organic Liquids (non-gasoline) Distribution
MACT
Other Solid Waste Incinerators
Petroleum Refinery MACT Standard
' tet 'XS i«*j*.4h. '^^
96/04
93/55
96/02
95/09
91/59
96/09
95/06
96/25
94/15
93/60
90/17
92/14
96/08
95/08
87/28
91/05
96/18
96/17
93/52
91/31
92/06
96/05
93/07
90/19
-; ^\
t^WjeetJUiSi
James Eddinger
Phil Mulrine
Dan Brown
Amanda Jo Agnew
James Maysilles
Martha Smith
Joseph Wood
David W.
Vlarkwordt
Fred Dimmick
John Schaefer
Richard Copland
Mary Johnson
Elaine Manning
Randy McDonald
Martha Smith
Walter Stevenson
Warren Johnson
Anthony Wayne
Mark Morris
Michele Aston
Martha Smith
Michele Aston
George Smith
James Durham
v ^ /"• '-V '
"il.v3ftC.J?tWwlilHp.Bf :
(919)541-5426
(919)541-5289
(919)541-5305
(919)541-5268
(919)541-3265
(919)541-2421
(919)541-5446
(919)541-0837
(919)541-5625
(919)541-0296
(919)541-5265
(919)541-5025
(919)541-5499
(919)541-5402
(919)541-2421
(919)541-5264
(919)541-5124
(919)541-5439
(919)541-5416
(919)541-2363
(919)541-2421
(919)541-2363
(919)541-1549
(919)541-5672
D-2
-------
Table D-l. (Continued)
1 , V/ ***fcstWe !/-'%
Petro. Refineries NESHAP: FCC Units,
Reformers...
Pharmaceuticals Production MACT
Phosphoric Acid/Phosphate Fertilizers Manuf.
Plywood & Particle Board Manufacturing
Polycarbonates Production
Polyether Polyols Production
Polymers and Resins I MACT Standard
Polymers and Resins II MACT Standard
Polymers and Resins III MACT
Polymers and Resins IV MACT Standard
Portland Cement MACT Standard
Primary Aluminum MACT Standard
Primary Copper Smelting MACT Standards
Primary Lead Smelting
Primary Magnesium Refining NESHAP
Printing/Publishing Industry MACT Standard
Production of Agricultural Chemicals
Publicly Owned Treatment Works (POTW)
NESHAP
Pulp and Paper Combustion MACT (MICG)
Pulp and Paper NESHAP CHEM. MILLS
NON-COMB (WCPG)
Pulp & Paper NESHAP Non-chem Mills
(WCPG)
Reinforced Plastic Composites Production
Remediation Activities MACT
Secondary Aluminum MACT Standard
Semichemical Pulp and Paper
Semiconductor Manufacturing MACT
Sewage Sludge Incineration NESHAP
95/02
93/50
93/53
95/11
93/63
93/62
90/26
84/01
91/54
92/12
91/44
91/43
91/61
94/11
96/12
91/42
93/59
91/30
91/38
86/1 5 A
86/15B
93/58
96/06
91/46
94/04
95/03
96/14
"£ % v "?^''&' f7K
Bob Lucas
landy McDonald
David Painter
Stephen Shedd
Mark Morris
David Svendsgaard
lobert Rosensteel
Randy McDonald
John Schaefer
lobert Rosensteel
foseph Wood
Steve Fruh
Eugene Grumpier
iCevin Cavender
Iliam Rosario
Dave Salman
Lalit Banker
Bob Lucas
Jeffrey Telander
Penny Lassiter
Elaine Manning
Madeleine Strum
Bob Lucas
Juan Santiago
Jeffrey Telander
David W.
Markwordt
Eugene Grumpier
919)541-0884
919)541-5402
919)541-5515
919)541-5397
919)541-5416
919)541-2380
919)541-5608
(919)541-5402
(919)541-0296
(919)541-5608
(919)541-5446
(919)541-2837
(919)541-0881
(919)541-2364
(919)541-5308
(919)541-0859
(919)541-5420
(919)541-0884
(919)541-5427
(919)541-5396
(919)541-5499
(919)541-2383
(919)541-0884
(919)541-1084
(919)541-5427
(919)541-0837
(919)541-0881
D-3
-------
Table D-l. (Continued)
Ship Building NESHAP
91/53B
Mohamed
Serageldin
(919)541-2379
Spandex Manufacturing MACT
96/07
Mary Tom Kissell
(919)541-4516
Stage I Gasoline Marketing MACT Standard
77/05A
Stephen Shedd
(919)541-5397
Steel Pickling - HCI Process MACT Standard
91/08B
James Maysilles
(919)541-3265
Vegetable Oil Production NESHAP
95/30
James Durham
(919)541-5672
Wood Furniture MACT Standard
91/22
Paul Almodovar
(919)541-0283
Wood Treatment MACT Standard
91/62
Eugene Grumpier
(919)541-0881
Wool Fiberglass Manufacturing MACT
91/47
William Neuffer
(919)541-5435
D-4
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APPENDIX E
-------
-------
NOTICE OF APPLICABILITY
Source NAME
Source Address
Dear
This notice is provided to the (implementing Agency) in response to the
publication of the following (state/federal) standards:
40 CFR 40, Part (60,61, 63, etc.), Subpart (A, NO, etc.)
or
(State) Title/Code (129, 2D. 1101, etc.), Chapter
Please send me an initial notice of applicability form
I have reviewed the applicability of this standard and have determined that this facility is
not subject. This determination is based on
All calculations required by the standard are attached. If no calculations or documentation are
required, this data will be maintained and made available upon request by the
(implementing agency). If additional information is needed, please contact me or
, of my staff, at ( ) XXX-XXXX, ext. XXXX.
Responsible Official Title
Date
E-l
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ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
DIVISION OF AIR POLLUTION CONTROL - PERMIT SECTION
2200 CHURCHILL ROAD
P.O. BOX 19506
SPRINGFIELD, ILLINOIS 62794-9506
NATIONAL EMISSION STANDARDS FOR
HAZARDOUS AIR POLLUTANTS:
COMMERCIAL ETHYLENE OXIDE
STERILIZERS AND
FUMIGATION OPERATIONS
INITIAL NOTIFICATION REPORT
x^"< * ' i^^^ctfiitxjicfc % -- \ -- ; >^4'h
FAOLITY ED #:
DATE:
FORM MUST BE SUBMITTED BY APRIL 5,1995
1. Print or type the following for each ethylene oxide (EO) sterihzer or fumigation operation at your facility.
Name of Owner/Operator:
Mailing Address:
City: State: Zip Code:
Physical Location (If Different Than Mailing Address)
Street Address:
City: State: Zip Code:
Contact Person:
Phone Number:.
2. Check the box below if your facility:
a. LJ does not use an ethylene oxide sterilizer or fumigator.
b. D is exempt per 40 CFR Part 63.360 (c) - (e):
• uses a beehive fumigator.
is a research or laboratory facility.
• provides medical services to humans or animals (eg. hospitals, clinics, doctors office).
c. C] uses EO in sterilization or fumigation operations.
If you checked boxes a or b, complete the signiture section only (paragraph 7) and return the form to the
address given at the top of this page. If you checked box c, continue with paragraph 3.
3. Provide the following for the EO sterilizer or fumigation operation:
Method of operation (check all operations facility uses):
a.
b.
D
ii)
I) D Sterilization Chamber Vent
ii) D Aeration Room Vent
iii) CU Chamber Exhaust Vent
Intended control methods to achieve compliance (check all controls that apply):
LJ acid-water scrubber
D catalytic oxidizer
E-2
-------
iii) O thermal oxidizer
iv) D other (describe):.
4. Provide the following dates for each EO sterilizer or fumigator (if applicable):
a. Date when construction or reconstruction commenced (mm/dd/yy):
b. Check the applicable date of initial startup (Note: the compliance date):
Compliance Date
C! Initial startup occurred on or before 12/8/97
12/8/97
D Initial startup occurred after 12/8/97
Compliance date = initial startup date
5. This facility is a(n):
i) D major source (Using one or more tons of EO)
ii) D area source (not major)
6. EO usage over the preceding 12 months (Check one box)
i) CD source uses less than one ton/year
ii) ED source uses one ton/year or more but less than ten tons/year
iii) LJ source uses 10 tons/year or more
2 Sterilization sources using less than 1 ton of ethylene oxide are not subject to the emission standards in 40
CFR Part 63.362, however, the recordkeeping requirements of 40 CFR Part 63.367(c) apply.
7. I CERTIFY THE INFORMATION CONTAINED IN THIS REPORT TO BE ACCURATE AND TRUE
TO THE BEST OF MY KNOWLEDGE.
Signature Date
Print or type the name and title of the Responsible Official for this facility:
Name Title
A Responsible Official can be:
• The president, vice president, secretary, or treasurer of a corporation that owns the facility,
or a duly authorized representative that is responsible for the overall operation of the facility,
• An owner of the facility,
• A principal executive officer if the facility is owned by the Federal, State, City, or County
government, ranking military officer if the facility is located at a military base, or
• A general partner of a partnership that owns the facility.
ETO-120694
E-3
-------
-------
APPENDIX F
-------
-------
The American Business Disc. 1995 Edition (c)
This infonnation may not be sold or otherwise provided to any party other than die Licensee. Data has been
seeded to detect unauthorized use.
Company Name: EMPIRE COATING INC
Address: 215 WEST AVE
City: ALBION State: NY ZIP: 14411
Company Name: RAYCO OF SCHENETADY INC
Address: 4 SAM STRATTON RD
City: AMSTERDAM State: NY ZIP: 12010
Company Name: O'DONNELL METAL MAINTENANCE
Address: 249 TRAVIS DR.
City: ATHENS State: NY ZIP: 12015
Company Name: RECORDS RESERVE COPR
Address: 56 HARVESTER AVE
City: BATAVIA State: NY ZIP: 14020
Company Name: US CHROME COPR OF NEW YORK
Address: 31 SWAN STREET
City: BATAVIA State: NY ZIP: 14020
Company Name: A & M MFG CO
Address: 275 FELDMEN CT
City: BAY SHORE State: NY ZIP: 11706
Company Name: TEK DEBURR INC
Address: 26 CLEVELAND AVE
City: BAY SHORE State: NY ZIP: 1 1706
Company Name: INDUSTRIAL ELECTROPLATERS INC
Address: 172 STATE ST
City: BINGHAMTON State: NY ZIP: 13901
Company Name: TRIPLE CITIES METAL FINISHING
Address: 4 NOWLAN RD
City: BINGHAMTON State: NY ZIP: 13901
Company Name: WILSON ELECTROPLATERS
Address: 6 EMMA ST
City: BINGHAMTON State: NY ZIP: 13905
Company Name: LIBERTY INDUSTRIAL FINISHING
Address: 550 SUFFOLK AVE
City: BRENTWOOD State: NY ZIP: 1 1 7 1 7
Company Name: ACE PLATING WORKS INC
Address: 800 E136THST
City: BRONX State: NY ZIP: 10454
Telephone: (716) 589-6842
Telephone: (518) 843-8316
Telephone: (5 18) 943-4878
Telephone: (716) 344-2600
Telephone: (716) 343-7077
Telephone: (56) 242-09 18
Telephone: (516) 667-7007
Telephone: (607) 723-7991
Telephone: (607) 722-3431
Telephone: (607) 770-4500
Telephone: (516) 273-4488
Telephone: (718) 665-6500
ABI offers many other business information services, including mailing lists, directories, on-line access,and Info
access. For more information, refer to the "Other Srevices" menu or contact us at (402) 593-4523
F-l
-------
The American Business Disc. 1995 Edition (c) (Continued)
This information may not be sold or otherwise provided to any party other than the Licensee. Data has been
seeded to detect unauthorized use.
Company Name: EMPIRE COATING INC
Address: 215 WEST AVE
City: ALBION
State: NY
ZIP: 14411
Telephone: (716) 589-6842
C Line of Business
71-02 METAL FINISHERS
Employees: 0010
Sales: $1 - $2.5 Million
Type of Location: Not available
Credit Rating: Good
Ad Year
A 1989
F-2
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APPENDIX G
-------
-------
Alphabetized List of Industry and Business Trade Associations
(e.g., from Wisconsin)
AFSCME, AFL-CIO, Wisconsin Legislative Council
ASFSCME County and Municipal Employees
Administrators and Supervisors Council
Alliance for Animals
Allied Construction Employers Association
American Auto Association of Wisconsin
American Automobile Manufacturer Association
American Camping Association, Wisconsin Section
American Electroplaters & Surface Finishers
American Furniture Manufacturer Association (AFMA)
American Institute Real Estate Appraisal
American Institute of Architects (Wisconsin Society)
American Lung Association of Wisconsin
American Product and Inventory Control Society
American Trucking Association
Animal Protective League Inc.
Associated Builders & Contractors of Wisconsin
Associated General Contractors of Greater Milwaukee
Associated Milk Producers, Inc.
Associated Recyclers of Wisconsin
Association of Consulting Foresters
Auto Dealers Association of Metropolitan Milwaukee
Automotive Service Association of Wisconsin
Badger State Car Wash Association
Bay View Business Association
Bowling Proprietors Association of Wisconsin
Building Owners and Managers Association of Milwaukee
Business and Industry Improvement Council
Chemical Coaters Association
Chicago Lung Association
Citizen's Natural Res. Assn. of Wisconsin, Inc.
Citizen's Commission for Clean Air
Citizens for a Better Environment
Civil Air Patrol, Wisconsin Wing
Clean Water Action Council of Northeast Wisconsin
Coalition of Wisconsin Aging Groups
Combined Health Appeal of Wisconsin
Common Cause In Wisconsin
Concerned Auto Recylers of Wisconsin
G-l
-------
Alphabetized List of Industry and Business Trade Associations (Continued)
(e.g., from Wisconsin)
Conference of Retail Associations
Construction Industry Manufacturers Association
Dairy Council of Wisconsin, Inc.
Environment Wisconsin Inc.
Farm Health & Safety Council of Wisconsin
Federal Reserve Bank of Chicago, Research Department
Forest History Association of Wisconsin
Forest Industry Safety and Training Alliance
Governor's Council On Tourism
Greater Milwaukee Florists Association
Greater Milwaukee Toxics Minimization Task Force
Hispanic Chamber of Commerce
Independent Community Bankers Association of Wisconsin
Independent Contract Lobbyists
Independent Insurance Agents of Wisconsin
Industrial Perforators Association
Industrial Recyclers of Wisconsin
Industry Relations Research Association
Institute Real Estate Management
International Dairy-Deli Bakery Association
Joint Organization for Better Sewer
Kitchen Cabinet Manufacturers Association
Lake Michigan Air Directors Consortium (LADCO)
Lake Michigan Federation
Lakes States Women In Timber
League of Wisconsin Municipalities
League of Women Voters Wisconsin Inc.
Lutherans for Life of Wisconsin Inc.
MRA - The Management Association
Madison Advertising Federation
Manufacturers of Emission Controls Association
Master Builders Association of Wisconsin
Mechanical Contractors Association of Wisconsin
Metro Milwaukee Association of Commerce
Midwest Equipment Dealers Association
Midwest Food Processors Association
Midwest Hardware Association
Milwaukee County Labor Council
Municipal Electric Utilities Wisconsin
G-2
-------
Alphabetized List of Industry and Business Trade Associations (Continued)
(e.g., from Wisconsin)
Milwaukee Indian Health Board, Community Health Centers
Municipal Environmental Association of Wisconsin
NAACP
NAACP-Milwaukee Chapter
National Agri-Business Association
National Association of Social Workers
National Cheese Exchange, Inc.
National Electrical Contractors Wisconsin
National Federation of Independent Business
National Paint & Coating Association
National Telemedia Council
Petroleum Marketers Association of Wisconsin
Planning Council for Health and Human Services
National Association of Wisconsin Theatre Owners
Post-secondary Agriculture Students
Printing Industries of Wisconsin
Professional Fire Fighters of Wisconsin
Professional Insurance Agents of Wisconsin
Protect Animal Life Inc.
Public Enterprise Committee
Public Relation Society of America
Public Safety Communication Officers
Sheet Metal & Air Conditioning Contractor Association
Soap and Detergent Association
Society of Automotive Historians, Wisconsin Chapter
Society of Real Estate Appraisers
Soil Science of America
Soil and Water Conservation Society
Southeast Wisconsin Regional Planning Commission (SEWRPC)
State Bar of Wisconsin
State Engineering Association
State Medical Society of Wisconsin
Tavern League of Wisconsin
Timber Producers Assn. of Michigan & Wisconsin
Trees for Tomorrow, Inc.
United Professional Quality Health Care
United States Small Business Association
United Transportation Union-Wisconsin Legislative Board
Urban League
G-3
-------
Alphabetized List of Industry and Business Trade Associations (Continued)
(e.g., from Wisconsin)
WATVA
WI Assn. of Plumbing-Heating-Cooling Contractors, Inc.
WI State Employees Union, AFSCME Council 24, AFL-CIO
WISCO
Washington County Land Conservation Council
Wilderness Watch Inc.
Wisconsin AFL-CIO
Wisconsin AFL-CIO Womens Committee
Wisconsin Academy of Sciences, Arts & Letters
Wisconsin Accountants Association
Wisconsin Agri-Business Council, Inc.
Wisconsin Agri-Service Assn., Inc.
Wisconsin Agriculture Association
Wisconsin Air Forces Association
Wisconsin Ambulance Service Association
Wisconsin American Public Works Association
Wisconsin Amusement & Music Operators
Wisconsin Apple Growers Association
Wisconsin Appraisers Coalition
Wisconsin Arborist Association Inc.
Wisconsin Asphalt Pavement Association
Wisconsin Assoc. for Health, Phy. Ed., Recreation & Dance
Wisconsin Association Future Farmers America
Wisconsin Association Homes and Services for Aging
Wisconsin Association Life Underwriters
Wisconsin Association for Adult & Continuing Education
Wisconsin Association for Environmental Education
Wisconsin Association for Middle Level Education
Wisconsin Association for Supervision and Curriculum Dev.
Wisconsin Association of Campground Owners (WACO)
Wisconsin Association of Fairs
Wisconsin Association of Incinerator Operators
Wisconsin Association of Independent College & Universities
Wisconsin Association of Lakes Inc.
Wisconsin Association of Manufacturers Agents
Wisconsin Association of Milk & Food Sanitarians
Wisconsin Association of Taxicab Owners
Wisconsin Association of Textile Services
Wisconsin Association of Vocational Agricultural Instructors
G-4
-------
Alphabetized List of Industry and Business Trade Associations (Continued)
(e.g., from Wisconsin)
Wisconsin Auto Collision Technical Association
Wisconsin Auto Merchandising Council
Wisconsin Automatic Merchandising Council
Wisconsin Automobile & Truck Dealers Association
Wisconsin Automobile Clubs in Association
Wisconsin Automotive Parts Association
Wisconsin Automotive Trades Association
Wisconsin Bakers Association
Wisconsin Bankers Association
Wisconsin Beef Council, Inc.
Wisconsin Berry Growers Association
Wisconsin Beverage Licensees Association
Wisconsin Biotechnology Association
Wisconsin Bowhunters Association Inc.
Wisconsin Broadcasters Association
Wisconsin Builders Association
Wisconsin Business Education Association
Wisconsin Business Womens Coalition
Wisconsin Cable Communications Association
Wisconsin Cast Metals Association
Wisconsin Cattlemens Association
Wisconsin Cattle women Association
Wisconsin Chapter American Fisheries Society
Wisconsin Chapter Association of General Contractors
Wisconsin Chapter Nature Conservancy
Wisconsin Chapter Tax Executives Institute
Wisconsin Chapter Wildlife Society
Wisconsin Cheese Makers Association
Wisconsin Chiropractic Association
Wisconsin Christmas Tree Producers Association
Wisconsin City Management Association
Wisconsin Coin Laundry Association
Wisconsin Communities & Economic Development
Wisconsin Community Education Association
Wisconsin Comptel
Wisconsin Concrete Masonry Association
Wisconsin Concrete and Pavement Association
Wisconsin Conference Journeymen Painters
Wisconsin Conference of Churches
G-5
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Alphabetized List of Industry and Business Trade Associations (Continued)
(e.g., from Wisconsin)
Wisconsin Consumer Packaging Council
Wisconsin Contemporary Gift Association
Wisconsin Coop Tobacco Growers Association
Wisconsin Council for the Social Studies
Wisconsin Council of Safety
Wisconsin Counties Association
Wisconsin Counties Mineral Resources Association
Wisconsin Counties Utility Tax Association
Wisconsin County Agents Association
Wisconsin County Executives and Administrators
Wisconsin County Forests Association
Wisconsin County Planning Directors
Wisconsin County Solid Waste Managers Association
Wisconsin Credit Union League
Wisconsin Dairy Products Association Inc.
Wisconsin Dairy Technology Society
Wisconsin Dental Association, Inc.
Wisconsin Dental Laboratory Association
Wisconsin Dietetic Association
Wisconsin Eagle Forum
Wisconsin Economic Development Association
Wisconsin Economics Education Council
Wisconsin Electric Cooperative Association
Wisconsin Electronic Sales and Service Association
Wisconsin Environmental Health Association
Wisconsin Environmental Laboratory Association
Wisconsin Equipment Lessors Association
Wisconsin Fabricare Institute
Wisconsin Farm Bureau Federation Coop
Wisconsin Farm Bureau Service Cooperative
Wisconsin Farm Equipment Association
Wisconsin Federated Humane Societies
Wisconsin Federation of Cooperatives
Wisconsin Fertilizer & Chemical Association
Wisconsin Forest Fire Fighters Association
Wisconsin Forest Productivity Council
Wisconsin Foundation for Independent Colleges
Wisconsin Funeral Directors Association
Wisconsin Grain Dealers Association
G-6
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Alphabetized List of Industry and Business Trade Associations (Continued)
(e.g., from Wisconsin)
Wisconsin Greyhound Owners Association
Wisconsin Grocers Association
Wisconsin Grounds Management Association
Wisconsin Groundwater Association
Wisconsin HMO Association
Wisconsin Hatcheries Association
Wisconsin Hazardous Material Responders
Wisconsin Health Care Association
Wisconsin Health Education Center
Wisconsin Health Information Management Association
Wisconsin Health Underwriters Association
Wisconsin Highway Users Conference
Wisconsin Hospital Association
Wisconsin Humane Society
Wisconsin Independent Businesses
Wisconsin Independent Merchants & Manufacturers Association
Wisconsin Independent Tire Dealers & Retread
Wisconsin Information and Referral Providers
Wisconsin Innkeepers Association
Wisconsin Installment Bankers
Wisconsin Institute of CPAs
Wisconsin Institute of Scrap Recycling Industries
Wisconsin Insulation Contractors Association
Wisconsin Insurance Alliance
Wisconsin Jewelers Association
Wisconsin Junior Limousine Association
Wisconsin Land Conservation Association
Wisconsin Land Title Association, Inc.
Wisconsin League of Financial Institutions, Ltd.
Wisconsin Leather Industries Association
Wisconsin Licensees Association
Wisconsin Limousine Association
Wisconsin Liquid Waste Carriers Association
Wisconsin Liquor Wholesalers Independent
Wisconsin Locally Owned Telephone
Wisconsin Manufactured Housing Association
Wisconsin Marketing and Management Association
Wisconsin Master Builders Association
Wisconsin Meat Processors Association
G-7
-------
Alphabetized List of Industry and Business Trade Associations (Continued)
(e.g., from Wisconsin)
Wisconsin Medical Group Management Association
Wisconsin Medical Record Association
Wisconsin Milk Haulers Association
Wisconsin Milk Marketing Board
Wisconsin Modular Housing Industry
Wisconsin Mortgage Bankers Association
Wisconsin Motorcycle Dealers Association
Wisconsin Movers Association Inc.
Wisconsin National Farmers Organization
Wisconsin Natural Food Associates, Inc.
Wisconsin Newspaper Association
Wisconsin Nurserymen's Association
Wisconsin Organic Growers Association
Wisconsin Paint & Coating Association
Wisconsin Painting & Decor Contractors
Wisconsin Paper Advertising Association
Wisconsin Paper Council
Wisconsin Park and Recreation Association
Wisconsin Petroleum Council
Wisconsin Pharmacists Association
Wisconsin Potato and Vegetable Growers Assc., Inc.
Wisconsin Precast Concrete Association
Wisconsin Primary Health Care Association
Wisconsin Professional Employee Council
Wisconsin Professional Florists Association
Wisconsin Psychiatric Association
Wisconsin Public Health Association Inc.
Wisconsin Public Health Association, Inc.
Wisconsin Pump & Well Suppliers
Wisconsin Railroad Committee
Wisconsin Ready Mixed Concrete Association
Wisconsin Real Property Listers Association
Wisconsin Realtors Association
Wisconsin Recreational Independent Inc.
Wisconsin Restaurant Association
Wisconsin Retail Bankers Association
Wisconsin Retail Hardware Association
Wisconsin Retail Lumbermen's Association, Inc
Wisconsin Road Builders Association
G-8
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Alphabetized List of Industry and Business Trade Associations (Continued)
(e.g., from Wisconsin)
Wisconsin Road Builders Association
Wisconsin Rural Development Center
Wisconsin Social Service Association
Wisconsin Society for Clinical Social Work
Wisconsin Society for Ornithology Inc.
Wisconsin Society of Biological Science
Wisconsin Society of Land Surveyors
Wisconsin Society of Mechanical Engineers
Wisconsin Society of Orthodontists
Wisconsin Society of Professional Engineers
Wisconsin Society of Science Teachers
Wisconsin Soft Drink Association
Wisconsin Software Publishers Association
Wisconsin Sporting Goods Association
Wisconsin State Brewers Association
Wisconsin State Council of Carpenters
Wisconsin State Cranberry Growers
Wisconsin State Firefighters Association
Wisconsin State Grange
Wisconsin State Health Council
Wisconsin State Telephone Association
Wisconsin Tavern Hosts
Wisconsin Teachers Credit Union
Wisconsin Teamsters Joint Council #39
Wisconsin Technology Education Association
Wisconsin Tourism Federation
Wisconsin Towing Association
Wisconsin Town Mutual Insurance Co. Association
Wisconsin Town Mutual Insurance Company Assn.
Wisconsin Towns Association
Wisconsin Towns Association
Wisconsin Transportation Development Association
Wisconsin Trappers Association Inc.
Wisconsin Tree Farm Committee
Wisconsin Truck Stop Operators Association
Wisconsin Trustees Association
Wisconsin Underground Contractors Association
Wisconsin Urban Transit Association
Wisconsin Utilities Association
G-9
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Alphabetized List of Industry and Business Trade Associations (Continued)
(e.g., from Wisconsin)
Wisconsin Veterinarian Medical Association
Wisconsin Warehousemans Association
Wisconsin Water Quality Association
Wisconsin Well Water Association
Wisconsin Wholesale Beer Dist Association, Inc.
Wisconsin Wildlife Federation Inc.
Wisconsin Wine and Spirit Institute
Wisconsin Wineries Association
Wisconsin Women for Agriculture
Wisconsin Woodland Owners Association Inc.
Wisconsin and Upper Michigan Florists Association
Wisconsin-Minnesota Canned Vegetable Council
Wisconsin Apartment Association
Women In Communications Inc.
Womens International Bowling Congress
G-10
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APPENDIX H
Example Inspection Checklists
-------
-------
APPENDIX HI
Multimedia Inspection Checklist for Dry Cleaning Facilities
-------
-------
Multimedia Inspection Checklist For
Dry Cleaning Facilities
(Taken directly from "Multimedia Inspection Guidance
for Dry Cleaning Facilities" OECA/EPA July 30, 1996.)
-------
-------
DRAFT
TABLE OF CONTENTS
I. GENERAL FACILITY AND MANAGEMENT INFORMATION 1
A. General Facility Information 1
B. Facility Management 2
II. DRY CLEANING PROCESS AREA 3
A. Dry Cleaning General Equipment Information .3
B. Refrigerated Condensers Performance Monitoring 4
C. Carbon Adsorber Performance Monitoring (complete if carbon adsorbers are
used) 4
D. Leak Detection 5
E. Miscellaneous Operation and Maintenance 6
III. PERC AND PERC WASTE HANDLING AREAS 6
A. Perc Storage and Dispensing 6
B. Satellite Waste Accumulation Area 6
C. Hazardous Waste Storage Area 7
D. Hazardous Wastes Shipping 8
E. Wastewater Management 8
IV. RECORDS AND FILES INSPECTION 9
A. Reporting 9
B. Recordkeeping 10
V. ADDITIONAL COMMENTS 11
-------
-------
DRAFT
MULTIMEDIA INSPECTION CHECKLIST FOR DRY CLEANING FACILITIES
I. GENERAL FACILITY AND MANAGEMENT INFORMATION
A. General Facility Information
1. Date of Inspection
2. Facility Name:
3. Facility Telephone Number:
4. Facility Address (physical location):
5. Mailing Address (if different):
6. Facility Owner Contact Information
(Name and phone):
7. Facility Operator/Manager (if different
From owner (Name and phone):
8. Inspector(s):
Name Title/Affiliation Phone Number
(1)
(2)
(3)
9. Original establishment date of facility:
-------
Multimedia Inspection Checklist DRAFT
10. Establishment date of current ownership:
11. Establishment date at current location:
12. Is a new annual perc consumption level calculated on the first of each month reflecting usage for the past 12
months? Yes [ ] No [ ]
Record most current annual perc consumption:
Gallons:
From (month, year) to (month, year)
Date calculated:
13. Size categorization of facility under federal air emissions regulations (based on information in Question 12):
[ ] Small area source
[ ] Large area source
[ ] Major source
14. Size categorization of facility under federal hazardous waste regulations:
[ ] CESQG
[ ] SQG
[ ] LQG
15. Does the facility have an EPA ID # as a generator of hazardous wastes?
Yes[ ] No[ ]
EPA ID #:
16. Does the facility discharge wastewater into a municipal sewer?
Yes[ ] No[ ]
NameofPOTW:
Permit # (if applicable):
If not, please explain.
B. Facility Management
17. Is the dry cleaner a member of a trade association? Yes [ ] No [ ]
If so, name of association:
If not, ensure that the dry cleaner is aware of the role of trade organizations in providing compliance assistance.
Distribute national or local trade association literature as appropriate to serve as initial contact points.
18. What types of training activities are conducted at the facility (include safety, emergency procedures, and
pollution prevention programs)?
-------
Multimedia Inspection Checklist
DRAFT
19. Has a pollution prevention or waste minimization plan been developed by the facility?
If so, describe:
Yes[ ] No[
20. Has the facility evaluated which wastes are probable candidates for reductions through pollution prevention
activities? Yes[ ] No[ ]
If so, list the wastes and describe pollution prevention activities currently being undertaken.
21. Is the facility owner familiar with multiprocess wet cleaning?
Has the facility considered experimenting with multiprocess wet cleaning?
Yes[ ] No |
Yes[ ] No[
H. DRY CLEANING PROCESS AREA
A. Dry Cleaning General Equipment Information
22. Supply the following information about the dry cleaning machines in use at the facility:
#
1
2
3
Type'
Date
Installed
New or
Existing
Manufacturer
and model
number
Perc flltration
system(s)"
Perc vapor
recovery
system'"
Installation date of
perc vapor
recovery system
'Dry-to-dry (D) or Transfer (T)
"List all types of filters used
'"Refrigerated condenser (RC) or carbon adsorber (CA)
23. New transfer machines are no longer allowed. Is the facility in compliance?
Yes[ ] No[
24. If existing transfer machines are used, has the facility performed a thorough cost analysis to determine what
the payback period would be on the purchase of a dry-to-dry machine? Yes [ ] No [ ]
25. Existing transfer machines in major sources must be surrounded in a room enclosure by September 23, 1996.
Is the facility in compliance? Yes [ ] No [ ]
26. Were any carbon adsorbers that are used as perc vapor recovery systems for drying process vapors installed
before September 22, 1993? Yes [ ] No[ ]
27. Does the facility use a carbon adsorber as a residual perc recovery system to vent aeration cycle vapors?
Yes[ ] No[ }
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Multimedia Inspection Checklist
DRAFT
B. Refrigerated Condensers Performance Monitoring
28. Are temperature sensors for refrigerated condensers installed for each machine in accordance with
manufacturers' specifications? Yes [ ] No [ ]
29. Are temperature sensors for all machines designed to measure temperatures from 32°F to 120°F to an accuracy
of±2°F? Yes[ ] No[ ]
30. Record temperature sensor readings if available:
Temperature Sensor
(a) Dryer airstream at condenser outlet (°F)
(b) Washer airstream at condenser inlet (°F)
(c) Washer airstream at condenser outlet (°F)
(d) Washer airstream net temp, drop {(b) - (c)} (°F)
(e) In compliance? (Y/N)
Machine
#1
Machine
#2
Machine
#3
Criteria for
compliance
Less than or equal to
45°F
none
none
At least 20°F
C. Carbon Adsorber Performance Monitoring (complete if carbon adsorbers are used)
31. Are sampling ports for carbon adsorbers properly located in accordance with federal regulations (8 duct
diameters downstream and 2 duct diameters upstream of any flow disturbance)? Yes [ ] No [ ]
32. Are they kept closed when not in use?
Yes[ ] No[
33. Indicate the established period desorption schedule for each machine (as necessary, as indicated by tests, but
at least weekly). Note the date when each adsorber was last desorbed and measure the perc concentration in
the exhaust with a colorimetric detector while the drying cycle is on. (Note: It is important to note that the
perc concentration should usually be measured at the end of a use cycle, just prior to desorption. A
measurement taken at any other time only ensures that the adsorber is in compliance at that time, not
necessarily for the duration of the use cycle. However, given time and logistical limitations, inspections
schedules generally cannot accommodate desorption schedules for each machine.
Machine
#
1
2
3
Indicate Periodic
Desorption
Schedule1
Date Last
Desorbed
Measured Perc
Concentration in
Exhaust Airstream
Use of Carbon Adsorber
(A,B, or C as indicated by
table below)"
Perc Concentration
Limit (as indicated
by table below)"
'Indicate schedule specifics (day of week, etc.)
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Multimedia Inspection Checklist
DRAFT
Carbon adsorber is used:
As main perc vapor recovery system
As residual vapor recovery system (tested during aeration
while the door is open)
As residual vapor recovery system (tested during aeration
while the door is closed)
Indicate with
A
B
C
Perc Limit (ppm)
100
100
300
D. Leak Detection
34. Is the odor of perc readily detectable anywhere in the facility?
If so, where?
Yes[ 1 No{
35. Is the leak detection program conducted weekly or biweekly as required?
Yes[ ] No[
36. Allow owner or designated representative to guide you through the facility and demonstrate procedures for the
weekly/biweekly leak detection inspection for each machine. The inspection should include the items listed
below. Tabulate results and record any leaks detected.
Inspection done by:
[ ] Sight, smell, and feel
[ ] Monitoring instrument (Type: )
#
1
2
3
4
5
6
7
8
9
10
11
Components:
Hose & pipe connections,
fittings, couplings, valves
Door gaskets & seatmgs
Pumps
Solvent tank & containers
Water separators
Muck cookers
Stills
Exhaust dampers
Diverter valves
Filter gaskets and searings
Cartridge filter housings
Signs of Leaking (Y, N, n/a)?
Machine
#1
Machine
#2
Machine
#3
Explain all "Yes" answers:
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Multimedia Inspection Checklist DRAFT
37. Are seals and gaskets periodically replaced before they become brittle? Yes [ ] No [ ]
38. What type of solvent leak detection systems are in use?
39. What other methods does the facility use to detect leaks? (e.g., drip pans, etc.)
40. In transfer machines, is the exhaust damper easily accessible? Yes [ ] No [ ]
If not, is there a suitable outlet downstream for testing the proper closure of the exhaust damper?
Yes[ ] No[ ]
E. Miscellaneous Operation and Maintenance
41. Are all machines operated as per manufacturer's specifications and recommendations?
Yes[ ] No[ ]
42. Are machine doors kept closed except when transferring clothes? Yes [ ] No [ ]
43. Are all spent cartridges drained at least 24 hours before disposal? Yes [ ] No [ ]
Alternatively, are they steam stripped before disposal? Yes [ ] No [ ]
HI. PERC AND PERC WASTE HANDLING AREAS
A. Perc Storage and Dispensing
44. Is perc stored on-site? Yes [ ] No [ ]
If so, is all perc stored in tightly sealed containers and free from leakage? Yes [ ] No [ ]
45. How frequently is perc delivery available?
46. How is perc delivered to the dry cleaning machines?
B. Satellite Waste Accumulation Area
47. Do satellite waste accumulation areas contain less than 55 gallons of accumulating wastes?
Yes[ ] No[ ]
48. Are all full containers sealed and dated less than 3 days (72 hours) ago? Yes [ ] No [ ]
49. Are all containers tightly closed and free from leakage? Yes [ ] No [ ]
50. Are all containers clearly marked as hazardous waste? Yes [ ] No [ ]
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Multimedia Inspection Checklist DRAFT
C. Hazardous Waste Storage Area
51. Are all containers tightly closed and free from leakage or deterioration? Yes [ ] No [ J
52. Are all containers clearly marked as hazardous waste? Yes [ ] No [ 1
53. Do all containers bear a date representing the day the container was filled and designated for
disposal/treatment? Yes [ ] No[ \
54. Are all the dates on the containers in compliance with on-site waste storage time limits for generators of
hazardous wastes? (No limit for CESQGs, 180 days for SQGs, 270 days for SQGs that must transport their
wastes 200 miles.) Yes [ } No[ ]
Note the date of oldest container:
If the time limit is exceeded, does the facility have the required EPA permit for storage facilities?
Yes[ ] No[ 1
55. The facility must not be storing quantities of waste in excess of the quantity storage limits. Determine whether
the facility is in compliance as follows:
Determine the total weight of all perc wastes in the storage area.
Each 15-gallon container can hold about 120 Ibs (55 kg) of perc waste.
Each 5 5-gallon container can hold about 440 Ibs (200 kg) of perc waste.
Maximum quantity limits are as follows: CESQG—2,200 Ibs; SQG—13,200 Ibs.
For 15-gallon containers:
x 120 Ibs/container = Ibs in storage # of full containers:
For 55-gallon containers:
x 440 Ibs/container = Ibs in storage # of full containers
On-site storage quantity limit (Ibs):
Is the facility in compliance? Yes [ ] No [ ]
D. Hazardous Wastes Shipping
56. Does the facility ship hazardous wastes off-site? Yes [ ] No [ ]
57. Does the facility track the wastes with a manifest form? Yes [ ] No [ }
58. Are all containers labeled with the 4-inch DOT POISON label? Yes[ J No[ J
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Multimedia Inspection Checklist DRAFT
59. Are all containers marked with the proper DOT shipping name and number? Yes [ ] No [ ]
E. Wastewater Management
60. Does the facility discharge industrial wastewater into the following?
Municipal sewer Yes [ ] No [ ]
On-site disposal system which meets the definition of injection well Yes [ ] No [ ]
Holding tank Yes [ ] No [ ]
For discharges to municipal sewers:
61. Does the facility have a current wastewater permit? Yes [ ] No [ ]
If not, has the facility applied for a new permit? Yes [ ] No [ ]
62. What parameters are limited and/or monitored in the facility's permit?
Parameter Limit Monitoring Frequency
(1)
(2)
(3)
63. Is monitoring conducted as required by the permit (with respect to sampling location, frequency)?
Yes[ ] No[ ]
64. Does the facility have a sampling point available which is representative of its process wastewaters discharged
tothePOTW? Yes[ ] No [ ]
65. Is the effluent currently in compliance with the limitations established in the Yes [ ] No [ ]
permits?
If not, describe all violations found, including parameter limit exceeded, date of violation, and any follow-up
samples or actions.
66. Has the discharge changed significantly since the permit was issued? Yes [ ] No [ ]
If so, was the permitting authority notified? Yes [ ] No [ ]
Describe the changes.
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Multimedia Inspection Checklist DRAFT
67. Describe any wastewater treatment employed at the facility.
68. If the facility discharges to a POTW, has it complied with the recordkeeping and reporting requirements
contained in 40 CFR 403.12(o)? Yes [ ] No [ ]
69. Has the facility ever discharged 15 kg of perc to the POTW within a calendar month?
Yes[ ] No[ ]
If so, were the proper authorities notified of the release? Yes [ ] No [ ]
For discharges to injection wells:
70. Does the facility have a Federal or State UIC permits? Yes [ ] No [ ]
71. Does the facility dispose of perc wastes and/or other hazardous chemicals in the injection well?
Yes[ ] No[ ]
For discharges to holding tanks:
72. Does the facility have the tank pumped out regularly by a licensed waste hauler for proper, legal disposal?
Yes[ ] No[ }
IV. RECORDS AND FILES INSPECTION
A. Reporting
73. Did the facility file an initial report with EPA (by June 18, 1994. or upon startup for new facilities)?
Ycs[ ] No[ ]
Date filed-
74. Did the facility file a compliance report (within 30 days of startup or 30 days after NESHAP regulations take
effect)?
Yes[ ] No[ ]
Date filed:
Note to inspector: Ask to see copies of the initial report and compliance report.
B. Recordkeeping
75. Are the results of temperature sensor monitoring for refrigerated condensers kept on record for the past 5 years
of operations? Yes [ ] No[ ]
Do the results show that all refrigerated condensers are in compliance with performance requirements?
Yes[ ] No[ I
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Multimedia Inspection Checklist DRAFT
76. Are the results of colorimetric tube monitoring for carbon adsorbers kept on record for the past 5 years of
operations? Yes [ ] No [ ]
Has a periodic (at least weekly) desorption schedule been established and adhered to for each adsorber?
Yes[ ] No[ ]
Does monitoring of adsorbers take place during the last run prior to description? Yes [ ] No [ ]
Do the results show that all carbon adsorbers are in compliance with performance requirements?
Yes[ ] No[ ]
77. Are monthly totals of perc purchase records kept on-site for the past 5 years? Yes [ ] No [ ]
78. Are records of weekly/biweekly inspections for leaks available for each machine for the last 5 years (or since
startup of facility)? Yes [ ] No [ ]
79. Are any detected leaks repaired within 24 hours whenever possible? Yes [ ] No [ ]
80. Are all needed repair parts ordered within 2 working days? Yes [ ] No [ ]
81. Are needed repair parts installed within 5 days of receipt? Yes [ ] No [ ]
82. Note any recurring problems:
83. Are copies of manifest forms maintained on-site for 3 years? Yes [ ] No [ ]
84. Are any return copies of manifest forms (from the waste receiving facility) missing?
Yes[ ] No[ ]
85. If so, have exception reports been filed and copies maintained on-site? Yes [ ] No [ ]
What action has been taken to determine the status of the waste shipment or notify the proper authorities?
86. Are copies of the design specifications and operating manuals for each dry cleaning system and each emission
control device kept on-site at the facility? Yes [ ] No [ ]
87. Has the solvent mileage been calculated for each machine? Yes [ ] No [ ]
If so, record the results (gallons perc/1,000 Ib clothes)
If not, does the facility owner understand how to calculate solvent mileage and how to use it as a waste
minimization indicator? Yes [ ] No [ ]
10
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Multimedia Inspection Checklist DRAFT
V. ADDITIONAL COMMENTS
11
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APPENDIX H2
Inspection Checklist for Chromium Electroplating and Anodizing
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DRAFT
Chromium Electroplating And Anodizing Inspection Checklist
Inspection Date
Facility Name
Facility Address
Attendees
I. EMISSION SOURCE TYPE* and CONTROL EQUIPMENT
small, existing hard packed-bed scrubber (PBS)
other hard composite mesh-pad (CMP)
decorative fume suppressant and/no
wetting agent
anodizing fume suppressant (FS)
* See details in Attachment 1 (Table 3-1 of the "Guidebook on How to Comply With the
Chromium Electroplating and Anodizing NESHAP).
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H. WORK PRACTICES
1. Operation and maintenance plan (O&M)
Yes No
2. Records of Quarterly inspections:
control devices
ductwork
monitoring equipment
3. Process operating time
4. For tanks using fume suppressant
a. Date and time of each addition of fume
suppressant
b. For trivalent decorative purchasing records of bath compounds:
Yes No
III. INITIAL PERFORMANCE TEST
Yes No
exemptions:
• decorative or anodizing with wetting agent and surface tension to a max. 45 dynes/cm
• decorative that use a trivalent chromium bath
IV. ONGOING COMPLIANCE MONITORING (Table 5-3 of the Guide).
For add-on pollution control specified in regulations (use monitoring parameters as per
initial performance test):
1. Composite mesh-pad scrubber
(check daily) pressure drop across the system
Initial test Actual
-------
2. Packed-bed scrubber
(check daily) Pressure drop across system
Initial test Actual
(daily) Velocity pressure at system inlet (i.e. velocity of the gas stream at the inlet
of the unit)
Initial test Actual
3. Packed-bed scrubber/composite mesh-pad system
(daily) Pressure drop across the mesh-pad system
Initial test Actual
4. Fiber-bed mist eliminator
(daily) Pressure drop across the mist eliminator
Initial test Actual
(daily) Pressure drop across the control device located upstream of the fiber bed that
prevents plugging
Initial test Actual
5. Wetting Agent or combination wetting agent/foam blanket fume suppressants
(@4 or 8 hours. See Attachment II, Table 5-3). Surface tension
Initial test Actual
6. Foam blanket-type fume suppressant
(every hour for every new tank solution. If no EE, @4 hours. See Attachment II,
Table 5-3) Foam blanket thickness
7. Fume suppressant/add-on control device
Combination of the above
For control system not specified in the regulations, EPA approved parameters:
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V. RECORDKEEPING (except decorative with trivalent bath*)
1. Inspection records
2. Equipment maintenance records
3. Records of the occurrence, duration and cause of excess emissions
4. Performance test results
5. Monitoring data
* for decorative electroplating with trivalent chromium bath submit initial notification
and an initial compliance status report
VI. REPORTING (except for decorative with trivalent bath*)
1. Initial notification
Yes No
2. Performance test notification
Yes No
3. Performance test data
4. EER's submission
Yes No
* notification and initial compliance status report
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APPENDIX I
Contacts
-------
-------
APPENDIX II
Regional Air Toxics Coordinators
-------
-------
REGIONAL AIR TOXICS CONTACTS
Janet Bowen
EPA Region I (CAP)
J.F.K. Federal Building
Boston, MA 02203-2211
PH: (617) 565-3595
Fax: (617) 565-4940
Umesh Dholakia
EPA Region II
290 Broadway
New York, NY 10007-1866
PH: (212)6374023
Fax: (212) 637-3901
Mike Markowski
Alice Chow (enforcement)
EPA Region III (3AT23)
841 Chestnut Building
Philadelphia, PA 19107
Mike (215) 566-2063
Alice (215) 566-2144
FAX: (215) 566-2114
Lee Page
EPA Region IV (AR-4)
100 Alabama Street, SW
Atlanta, GA 30303-3104
PH: (404) 562-9131
FAX: (404) 562-9095
Bruce Vamer
EPA Region V(AE-17J)
77 W. Jackson Blvd.
Chicago, IL 60604
PH: (312) 886-6793
FAX: (312) 353-8289
Belinda Breidenbach
Charlie Garlow, OECA
Belinda PH:(202) 564-7022
Charlie PH:(202) 564-1088
Belinda's FAX: (202) 564-0050
Charlie's FAX: (202) 564-0068
Robert Todd
EPA Region VI (6PD-R)
1445 Ross Avenue,Suite 700
Dallas, TX 75202-2733
PH: (214) 665-2156
Fax: (214) 665-7263
Richard Tripp
EPA Region VII
726 Minnesota Avenue
Kansas City, KS 66101
PH: (913) 551-7566
FAX: (913) 551-7065
Victoria Parker-Christensen
Ann-Marie Patrie (AP2-A)
Heather Rooney (8ENF-T) R VIII
999 18th Street, Suite 500
Denver, CO 80202-2405
VPC: (303) 312-6441
Ann Marie: (303) 312-6524
Heather: (303) 312-6971
FAX: (303) 312-6064
Heather's FAX: (303) 312-6409
Mae Wang
EPA Region IX (A-5-2)
75 Hawthorne Street
San Francisco, CA 94105
PH: (415) 744-1200
FAX: (415) 744-1076
Chris Hall
EPA Region X (OAQ-107)
1200 Sixth Avenue
Seattle, WA 98101
PH: (206) 553-1949
FAX: (206) 553-0404
Julie Andresen
EPA/OAQPS
RTF, NC 27711
PH: (919) 541-5339
FAX: (919) 541-2664
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APPENDIX 12
OAQPS and OECA NSPS and NESHAP Contacts
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-------
List of OAQPS and OECA NSPS and NESHAP Contacts
(11/07/96)
Regulation - Part 60
NSPS Subpart A:
General Provisions
NSPS Subpart D, Da,
Db, DC: Boilers
NSPS Subpart E:
Incinerators
NSPS Subpart Ea:
Municipal Waste
Combustors
NSPS Subpart F:
Portland Cement
NSPS Subpart G: Nitric
Acid Plants
NSPS Subpart H:
Sulfuric Acid Plants
NSPS Subpart I: Asphalt
Concrete Plants
NSPS Subpart J:
Petroleum Refineries
NSPS Subpart K, Ka,
Kb: Storage Tanks
NSPS Subpart L:
Secondary Lead
Smelters
NSPS Subpart M: Brass
& Bronze
NSPS Subpart N,Na:
BOF
OAQPS Contact
Jim Szykman
Rick Copland
Jim Eddinger
Fred Porter
Walt Stevenson
Joe Wood
Bill Neuffer
Mary Johnson
Fred Porter
Gail Lacy
Randy McDonald
Kevin Cavender
Eugene Grumpier
Phil Mulrine
Phone #
919-541-2452
919-541-5265
919-541-5426
919-541-5251
919-541-5264
919-541-5446
919-541-5435
919-541-
919-541-5025
919-541-5251
919-541-5261
919-541-5402
919-541-2364
919-541-0881
919-541-5289
OC Contact
Sally Mitoff
Belinda Breidenbach
Chris Oh
Joyce Chandler
Joyce Chandler
Scott Throwe
JeffKenknight
Dawn Banks- Waller
Scott Throwe
Tom Ripp
Dan Chadwick
Everett Bishop
Jane Engert
Jane Engert
Maria Malave
Phone #
(202) 564-7012
(202) 564-7022
(202) 564-7004
(202) 564-7073
(202) 564-7073
(202) 564-7013
(202) 564-7033
(202) 564-7034
(202)564-7013
(202) 564-7003
(202) 564-7054
(202) 564-7032
(202) 564-5021
(202) 564-5021
(202) 564-7027
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List of OAQPS and OECA NSPS And NESHAP Contacts (continued)
(11/07/96)
Regulation - Part 60
NSPS Subpart O:
Sewage Treatment
Plants
NSPS Subpart P:
5rimary Copper
Smelters
NSPS Subpart Q:
Primary Zinc Smelters
NSPS Subpart R:
Primary Lead Smelters
NSPS Subpart S:
Primary Aluminum
Reduction
NSPS Subpart T, U, V,
W, X: Phosphate
Fertilizer
NSPS Subpart Y: Coal
Preparation
NSPS Subpart Z:
Ferroalloy Production
NSPS Subpart AA: Steel
Plants, EAF
NSPS Subpart AAa:
Steel Plants, EAF &
AOD
NSPS Subpart BB: Kraft
Pulp Mills
NSPS Subpart CC:
Glass Manufacturing
OAQPS Contact
Eugene Grumpier
Eugene Grumpier
Al Vervaert
Kevin Cavender
Steve Fruh
David Painter
Juan Santiago
Conrad Chin
Phil Mulrine
Phil Mulrine
JeffTelander
Al Vervaert
Phone #
919-541-0881
919-541-0881
919-541-5602
919-541-2364
919-541-2837
919-541-5515
919-541-1084
919-541-1512
919-541-5289
919-541-5289
919-541-5427
919-541-5602
OC Contact
John Dombrowski
Jane Engert
Jane Engert
Jane Engert
Jane Engert
Cletis Mixon
Steve Howie
Chris Oh
Jane Engert
Maria Malave
Maria Malave
Maria Eisemann
Scott Throwe
Phone #
(202)564-7036
(202) 564-5021
(202) 564-5021
(202) 564-5021
(202) 564-5021
(202) 564-4153
(202) 564-4146
(202) 564-7004
(202) 564-5021
(202) 564-7027
(202) 564-7027
(202) 564-7016
(202) 564-7013
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List of OAQPS and OECA NSPS And NESHAP Contacts (continued)
(11/07/96)
Regulation - Part 60
NSPS Subpart DD:
Grain Elevators
NSPS Subpart EE:
Surface Coating, metal
furniture
NSPS Subpart GG:
Stationary Gas Turbines
NSPS Subpart HH:
Lime Manufacturing
NSPS Subpart KK: Lead
Acid Batteries
NSPS Subpart LL:
Metallic Mineral
Processing
NSPS Subpart MM:
Surface Coating, Auto
NSPS Subpart NN:
Phosphate Rock
NSPS Subpart PP:
Ammonium Sulfate
Manufacturing
NSPS Subpart QQ:
Graphic Arts, Rotograve
Printing
NSPS Subpart RR:
Pressure Sensitive Tape
& Label Coating
OAQPS Contact
Jim Berry
Mohammed
Serageldin
Sims Roy
Joe Wood
Kevin Cavender
Bill Neuffer
Dave Salman
David Painter
David Painter
Dave Salman
Dan Brown
Phone #
919-541-5605
919-541-2379
919-541-5263
919-541-5446
919-541-2364
919-541-5435
919-541-0859
919-541-5515
919-541-5515
919-541-0859
919-541-5305
OC Contact
Ken Harmon
Scott Throwe
Chris Oh
Scott Throwe
Jane Engert
Keith Brown
Suzanne Childress
Cletis Mixon
Steve Howie
Scott Throwe
Ginger Gotliffe
Seth Heminway
Phone #
(202)564-7049
(202) 564-7013
(202) 564-7004
(202) 564-7013
(202) 564-5021
(202) 564-7124
(202) 564-7018
(202) 564-4153
(202) 564-4146
(202) 564-7013
(202) 564-7072
(202) 564-7017
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List of OAQPS and OECA NSPS And NESHAP Contacts (continued)
(11/07/96)
Regulation - Part 60
NSPS Subpart SS:
Surface Coating, Large
Appliances
NSPS Subpart TT:
Surface Coating, Metal
Coil
NSPS Subpart UU:
Asphalt Roofing
NSPS Subpart W:
VOC leaks, SOCMI
NSPS Subpart WW:
Surface Coating,
Beverage Cans
NSPS Subpart XX: Bulk
Gasoline Terminals
NSPS Subpart AAA:
Woodstoves
NSPS Subpart BBB:
Rubber Tire
Manufacture
NSPS Subpart DDD:
Polymer Manufacture
NSPS Subpart FFF:
Flexible Vinyl and
Urethane
NSPS Subpart GGG:
Equipment Leaks,
Petroleum Refineries
OAQPS Contact
Mohammed
Serageldin
Gail Lacy
Juan Santiago
Rick Colyer
Gail Lacy
Steve Shedd
JeffTelander
Tony Wayne
Bob Rosensteel
Dan Brown
David Markwordt
Phone #
919-541-2379
919-541-5261
919-541-1084
919-541-5262
919-541-5261
919-541-5397
919-541-5427
919-541-5439
919-541-5608
919-541-5305
919-541-0837
OC Contact
Scott Throwe
Scott Throwe
Andrew Cherry
JeffKenknight
Scott Throwe
Julie Tankersley
Peter Bahor
Robert Marshall
Maria Malave
Sally Sasnett
Ginger Gotliffe
Tom Ripp
Phone #
(202) 564-7013
(202) 564-7013
(202)564-5011
(202) 564-7033
(202) 564-7013
(202) 564-7002
(202) 564-7029
(202) 564-7021
(202) 564-7027
(202) 564-7074
(202) 564-7072
(202) 564-7003
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List of OAQPS and OECA NSPS And NESHAP Contacts (continued)
(11/07/96)
Regulation - Part 60
NSPS Subpart HHH:
Synthetic Fiber
NSPS Subpart ffl:
SOCMI, Air Oxidation
NSPS Subpart JJJ: Dry
Cleaning
NSPS Subpart KKK:
Equipment Leaks,
Onshore Natural Gas
NSPS Subpart LLL:
Onshore Natural Gas
NSPS Subpart NNN:
SOCMI Distillation
Operations
NSPS Subpart OOO:
Non metallic Mineral
Processing
NSPS Subpart PPP:
Wool Fiberglass
Insulation
NSPS Subpart QQQ:
VOC from Petroleum
Wastewater
NSPS Subpart RRR:
SOCMI Reactor
Processes
NSPS Subpart SSS:
Surface Coating,
Magnetic Tape
OAQPS Contact
Susan Wyatt
Bob Rosensteel
Steve Shedd
David Markwordt
David Markwordt
Warren Johnson
Bill Neuffer
Bill Neuffer
Randy McDonald
Elaine Manning
Bob Rosensteel
Gail Lacy
Phone #
919-541-5674
919-541-5608
919-541-5397
919-541-0837
919-541-0837
919-541-5124
919-541-5435
919-541-5435
919-541-5402
919-541-5499
919-541-5608
919-541-5261
OC Contact
Belinda Breidenbach
JeffKenknight
Joyce Chandler
Dan Chadwick
Dan Chadwick
JeffKenknight
Keith Brown
Scott Throwe
Tom Ripp
Dan Chadwick
JeffKenknight
Steve Hoover
Phone #
(202) 564-7022
(202) 564-7033
(202) 564-7073
(202) 564-7054
(202) 564-7054
(202) 564-7033
(202) 564-7124
(202) 564-7013
(202) 564-7003
(202) 564-7054
(202) 564-7033
(202) 564-7007
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List of OAQPS and OECA NSPS And NESHAP Contacts (continued)
(11/07/96)
Regulation - Part 60
NSPS Subpart TTT:
Surface Coating, Plastic
Parts for Business
Machines
NSPS Subpart UUU:
Calciners and Dryers
NSPS Subpart VW:
Polymeric Coating of
Supporting Substrates
OAQPS Contact
Ellen Ducey
Bill Neuffer
Dan Brown
Phone #
919-541-5408
919-541-5435
919-541-5305
OC Contact
Maria Malave
Keith Brown
Maria Malave
Phone #
(202) 564-7027
(202) 564-7124
(202) 564-7027
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List of OAQPS and OECA NSPS And NESHAP Contacts
(11/07/96)
Regulation - Part 61
NESHAP Subpart A:
General Provisions
NESHAP Subpart B:
Radon from
underground Uranium
Mines
NESHAP Subpart C:
Berylium
NESHAP Subpart D:
Beryllium Rocket Motor
Firing
NESHAP Subpart E:
Mercury
NESHAP Subpart F:
Vinyl Chloride
NESHAP Subpart H:
Radionuclides from
DOE
NESHAP Subpart I:
Radionuclide Emissions
NESHAP Subpart J:
Benzene Leaks
NESHAP Subpart K:
Radionuclide from
Elemental Phosphorous
NESHAP Subpart L:
Coke
NESHAP Subpart M:
Asbestos
OAQPS Contact
Jim Szykman
ORIA (Office of
Radiation & Indoor
Air)
Al Vervaert
Al Vervaert
Eugene Grumpier/
Illiam Rosario
Bob Rosensteel
ORP
ORP
Jan Meyer
ORP
Lula Melton
S. Fairchild-Zapata
Phone*
919-541-2452
202-233-9370
919-541-5602
919-541-5602
919-541-08817
919-541-5308
919-541-5608
202-233-9370
202-233-9370
919-541-5254
202-233-9370
919-541-2910
919-541-5167
OC Contact
Belinda Breidenbach
Dan Chadwick
Jane Engert
Virginia Lathrop
Jane Engert
JeffKenknight
Joanne Callahan
Virginia Lathrop
Joanne Callahan
Virginia Lathrop
Rafael Sanchez
Joanne Callahan
Virginia Lathrop
Maria Malave
Tom Ripp
Phone #
(202) 564-7022
(202) 564-7054
(202) 564-5021
(202) 564-7057
(202) 564-5021
(202) 564-7033
(202) 564-5009
(202) 564-7057
(202) 564-5009
(202) 564-7057
(202) 564-7028
(202) 564-5009
(202) 564-7057
1
(202) 564-7027
(202) 564-7003
-------
List of OAQPS and OECA NSPS And NESHAP Contacts (continued)
(11/07/96)
Regulation - Part 61
NESHAP SubpartN:
[norganic Arsenic From
Glass Manufacture
NESHAP Subpart O:
Arsenic from Primary
Copper Smelters
NESHAP Subpart P:
Arsenic
NESHAP Subpart R:
Radon from
Phosphogypsum Stacks
NESHAP Subpart T:
Radon from disposal of
Uranium Mine Tailings
NESHAP Subpart V:
Equipment Leaks,
NESHAP Subpart W:
Radon from Operating
Mill Tailings
NESHAP Subpart Y:
Benzene Storage
Vessels
NESHAP Subpart BB:
Benzene from Transfer
Operations
NESHAP Subpart FF:
Benzene Waste
Operations
OAQPS Contact
Al Vervaert
Eugene Grumpier
Al Vervaert
ORP
ORP
Jan Meyer
ORP
Randy McDonald
David Markwordt
Bob Lucas
Phone #
919-541-5602
919-541-0881
919-541-5602
202-233-9370
202-233-9370
919-541-5254
202-233-9370
919-541-5402
919-541-0837
919-541-0884
OC Contact
Scott Throwe
Jane Engert
Jane Engert
Joanne Callahan
Virginia Lathrop
Joanne Callahan
Virginia Lathrop
Rafael Sanchez
Joanne Callahan
Virginia Lathrop
Rafael Sanchez
Rafael Sanchez
Rafael Sanchez
Phone #
(202) 564-7013
(202) 564-5021
(202) 564-5021
(202) 564-5009
(202) 564-7057
(202) 564-5009
(202) 564-7057
(202) 564-7028
(202) 564-5009
(202) 564-7057
(202) 564-7028
(202) 564-7028
(202) 564-7028
-------
List of OAQPS and OECA NSPS And NESHAP Contacts
(11/07/96)
Regulation - Part 63
NESHAP Subpart A:
General Provisions
NESHAP Subpart F-H,
TheHON
NESHAP Subpart L:
Coke Oven Batteries
NESHAP Subpart M:
Perc Dry Cleaners
NESHAP Subpart N:
Chromium
Electroplating
NESHAP Subpart O:
Ethyline Oxide
Sterilizers
NESHAP Subpart Q:
Industrial Process
Cooling Towers
NESHAP Subpart R:
Gasoline Distribution
NESHAP Subpart
T:Halogenated Solvent
Cleaning
NESHAP Subpart U:
Polymers & Resins
Group I
NESHAP Subpart W:
Epoxy Resins & Non-
nylon Polymides
OAQPS Contact
Jim Szykman
Jan Meyer
Amanda Agnew
George Smith
Lalit Banker / Phil
Mulrine
David Markwordt
Phil Mulrine
Steve Shedd
Paul Almodovar
Randy McDonald
Randy McDonald
Phone #
919-541-2452
919-541-5254
919-541-5268
919-541-1549
919-541-54207
919-541-5289
919-541-0837
919-541-5289
919-541-5397
919-541-0283
919-541-5402
919-541-5402
OC Contact
Belinda Breidenbach
JeffKenknight
Maria Malave
Joyce Chandler
Scott Throwe
Karin Leff
Mimi Guernica
Julie Tankersley
Tracy Back
Sally Sasnett
Sally Sasnett
Phone #
(202) 564-7022
(202) 564-7033
(202) 564-7027
(202) 564-7073
(202) 564-7013
(202) 564-7068
(202) 564-2415
(202) 564-7002
(202) 564-7076
(202) 564-7074
(202) 564-7074
-------
List of OAQPS and OECA NSPS And NESHAP Contacts (continued)
(11/07/96)
Regulation - Part 63
NESHAP Subpart X:
Secondary Lead
Smelters
NESHAP Subpart Y:
Marine Vessel Loading
NESHAP Subpart CC:
Petroleum Refineries
NESHAP Subpart DD:
Off-Site Waste &
Recovery Operations
NESHAP Subpart EE:
Magnetic Tape
Manufacture
NESHAP Subpart GG:
Aerospace
NESHAP Subpart II:
Ship Building and
Repair
NESHAP Subpart JJ:
Wood Furniture
Manufacturing
NESHAP Subpart KK:
Printing and Publishing
NESHAP Subpart JJJ:
Polymers & Resins
Group IV
OAQPS Contact
Kevin Cavender
David Markwordt
Jim Durham
Michele Aston
Gail Lacy
Jim Szykman
Mohammed
Serageldin
Paul Almodovar
Dave Salman
Bob Rosensteel
Phone #
919-541-2364
919-541-0837
919-541-5672
919-541-2363
919-541-5261
919-541-2452
919-541-2379
919-541-0283
919-541-0859
919-541-5608
OC Contact
Jane Engert
Virginia Lathrop
Tom Ripp
Ann Stephanos
Seth Heminway
Suzanne Childress
Suzanne Childress
Robert Marshall
Ginger Gotliffe
Sally Sasnett
Phone #
(202) 564-5021
(202) 564-7057
(202) 564-7003
(202) 564-7043
(202) 564-7017
(202)564-7018
(202)564-7018
(202) 564-7021
(202) 564-7072
(202) 564-7074
10
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APPENDIX!
Small Business Regulatory Enforcement Fairness Act (SBREFA)
-------
-------
Chapter 4
Develonment and Distribution of SBREFA Compliance Guides
Section
I.
II.
Subject
EPA's Approach to Compliance Guides
SBREFA Compliance Guide Template
Page
1
6
I. EPA'S APPROACH TO COMPLIANCE GUIDES
A. What does SBREFA require?
1. When the Agency prepares a regulatory flexibility analysis for a final rule, SBREFA
Section 212 also requires the Agency to:
a. designate one or more publications regarding such a rule or group of rules as
small entity compliance guides;
b. explain in the guide actions a small entity must take to comply with a rule or
group of rules; and
c. distribute the guides to small entities through "comprehensive sources of
information."
2. While compliance guides are not themselves judicially reviewable, they may be
considered as evidence of the reasonableness or appropriateness of any penalties or
damages in any civil or administrative action against a small entity. Accordingly, the
statute gives us broad discretion with regard to implementation of these requirements for
designation, development and distribution of the guides. The sections that follow
describe how the Agency has chosen to exercise this discretion, the specifics of which
may not necessarily be required by SBREFA. As we gain experience, we may issue
additional guidance.
Taken from "EPA Interim Guidance for Implementing the
Small Business Regulatory Enforcement Fairness Act and
Related Provisions of the Regulatory Flexibility Act,"
prepared by the EPA SBREFA Task Force
Februarys. 1997
4-1
-------
B. What is the goal in writing a compliance guide?
The primary goal of the guide is to help small entities- whether they are small
businesses, communities or non-profits- to comply with the regulation. You should
therefore write your guide with your audience in mind and recognize that this segment of
our regulated community may have trouble with standard government writing styles. We
suggest that you write in plain and simple language insofar as possible. (While small
entities are the primary audience for the guides, some of the compliance information may
also be applicable to large entities and you may choose to present these
similarities/differences as you develop your guide).
C. Who participates in the development of the Guides?
1. The lead rule-writing office is responsible for developing the rule-specific compliance
guide as part of the rulemaking process.
2. The regulatory development workgroup, as well as representatives from OECA, OGC,
OSBO, OPPT's Pollution Prevention Division, and regional offices can also provide
assistance/support, or develop sections of the guide, as appropriate. If your regulatory
development workgroup is not represented by the appropriate offices, you should work
through your Steering Committee representative to identify them.
3. Small entity representatives should typically be involved in reviewing the draft
compliance guide after the rule is promulgated so that we have the benefit of their
comments and advice in preparing the final version of the guide.
a. With the exception stated below (b.), draft compliance guides should not be
released to outside parties prior to the rule's promulgation.
b. In those unusual circumstances where the outline of the compliance guide is clear
to the lead program at the pre-proposal stage, then they may seek review and
feedback from small entity stakeholders at that stage.
c. You should share the draft compliance guide and solicit comment from small
entity stakeholders after promulgation, but will need to balance such review with
a commensurate concern for timely issuance of the guide.
D. When should I begin developing the guide and when will it need to be completed?
Taken from "EPA Interim Guidance for Implementing the
Small Business Regulatory Enforcement Fairness Act and
Related Provisions of the Regulatory Flexibility Act,"
prepared by the EPA SBREFA Task Force February 5,1997
4-2
-------
1. You should integrate development of the guide into the rulemaking process. Generally,
begin work on your guide as soon as you have enough information to do so. This point
will vary from rule to rule; sometimes it is clear even before the rule is proposed, and in
other cases not enough is known until just prior to final promulgation. In either event,
you should not schedule additional time during the rulemaking process for
development of the guide. The Agency will not ask for extension of any court
deadlines in order to complete compliance guides.
2. Keep in mind that the goal is to make the guide available after promulgation in sufficient
time for it to be of practical help to small entities in evaluating and implementing their
compliance options before the compliance deadline. You should make every effort to
issue the guide within two months of the promulgation of the final rule.
£. What are the other timing considerations in developing and issuing the Guide?
1. The constraints on outside participation during the final rule phase in development of the
Guide leave a relatively short time after promulgation to both take comment from small
entity stakeholders and issue the final Guide. This makes advance planning and drafting
essential.
Tip: Identify your small entity reviewers early in the process. You should
consider using those small entity representatives who participated in the
development of the proposed rule.
2. If the issuance of your guide may be delayed beyond a month or two, you should issue a
Fact Sheet or other brief description of the rule as an interim measure.
3. If your rule has a distant compliance date (e.g., two years or more), you may want to re-
issue the Guide closer to the compliance date.
F. What sorts of questions should I ask my small entity reviewers?
Some suggestions include:
• Is the format appropriate?
• Is the guide clear and easy to read and understand?
• Does the guide accurately describe the rule as published?
Taken from "EPA Interim Guidance for Implementing the
Small Business Regulatory Enforcement Fairness Act and
Related Provisions of the Regulatory Flexibility Act,"
prepared by the EPA SBREFA Task Force February 5.1997
4-3
-------
• Is the guide useful in planning for compliance?
G. How do I document development of the Guide?
1. If you are doing an Analytic Blueprint you should include plans for developing the guide,
including a time line, and the resources needed. If there is no Blueprint, you should
integrate it into your action or work plan.
2. When you submit your final rule to the Administrator for signature, you must also submit
a schedule for development and completion of the compliance guide.
3. Include your distribution strategy for the guide in the Communications Plan. This is in
addition to your notification plan for the announcement of the rule.
4. Ultimately, the lead office will input information related to the development of the guide
into OPPE's Regulatory Information System, which is currently under development.
Lead offices may also develop internal methods for tracking the development of the
guides.
H. What internal Agency concurrence do I need for the Guide and how do I get it?
You need concurrence from both OGC and OECA. Normally, you will ask members of
your workgroup from these offices to assure that appropriate levels of management in
their offices approve the draft. (OGC and OECA will determine the level of concurrence
they need within their offices). If you don't have OGC and/or OECA members on your
workgroup, contact your Steering Committee representative who will obtain/identify
contacts for you.
I. When the Guide is in final form, who can help me with distribution?
1. In addition to internal office distribution mechanisms, you should provide Guides to the
Office of the Small Business Ombudsman, the Office of Regional and State/Local
Relations, the Office of Communications, Education and Public Affairs. These offices
will distribute the Guide to their small entity contacts. (You should assure, to the extent it
is feasible, that these offices do not have duplicate distribution lists.)
2. Distribution must be consistent with the recommendations of the Enhanced Public Access
Task Force.
3. Other small business assistance providers include:
Taken from "EPA Interim Guidance for Implementing the
Small Business Regulatory Enforcement Fairness Act and
Related Provisions of the Regulatory Flexibility Act,"
prepared by the EPA SBREFA Task Force February 5.1997
4-4
-------
• State Technical Assistance Programs for Pollution Prevention
• State Small Business Assistance Programs
• Small Business Development Centers
• Manufacturing Extension Partnership Centers funded by MIST
• Northeast Waste Management Officials Association
• Illinois Hazardous Waste Research and Information Center
• Waste Reduction Resource Center for the Southeast, and
• the Small Business Administration, USDA and OSHA
J. How do we ensure that guides are kept up to date?
1. As a statutory matter, compliance guides may have evidentiary uses in litigation so it is
important that guides be reviewed and revised as needed. It is the responsibility of the
lead office to assure compliance guides are kept current. There is one case in which you
must review an existing guide and several others when revisions may be desirable:
a. Because we must generally review within ten years of promulgation any final
rules for which we conducted regulatory flexibility analyses, the guide will be
reviewed concurrently with the rule on or before the 10-year anniversary.
b. Other circumstances which may occasion revisions include:
• Changes in the rule which affect compliance
• Comments from the public suggesting revisions, or from OECA based on
their experience in enforcing the regulation. (See Appendix, Section C for
instructions on soliciting customer feedback).
• Litigation citing a guide as a reason to challenge the appropriateness of
proposed penalties.
2. You should indicate in every guide that there may be subsequent revisions to the guide
and include information about obtaining the revised guide. Place the most current guide
in the appropriate docket, on a special section in EPA's internet page, or other electronic
bulletin boards.
Note: OECA may, at a later date, develop sector-specific, multimedia guides which would
integrate rule-specific guides. OECA will notify program offices if and when it undertakes this
Taken from "EPA Interim Guidance for Implementing the
Small Business Regulatory Enforcement Fairness Act and
Related Provisions of the Regulatory Flexibility Act,"
prepared by the EPA SBREFA Task Force February 5.1997
4-5
-------
project and will coordinate development of such guides through the Agency's Regulatory
Steering Committee.
H. TEMPLATE FOR COMPLIANCE GUIDES
An Agency workgroup has developed the following template to help you in structuring
your compliance guide, and you should use it in accordance with the guidance given earlier in
the chapter. While SBREFA does not mandate a particular format, we urge you to adopt it so
that we may have general consistency across the Agency and to assure that significant
compliance issues are adequately covered. If your rule does not, for some reason, lend itself to
this template, you may use it as a checklist to ensure that all potentially relevant compliance
issues are covered.
The template is organized as follows:
• Non-italicized text indicates sections which should normally be included in the
compliance guide.
• We have also included standard language which you may choose to use if it is
appropriate to your rule, and it is presented in italics. You should adapt this standard
language to the specifics of your rule as necessary.
• Program offices have lead responsibility unless otherwise designated in bold.
Please make your best effort to write your guide in plain language using the guidance at
http://www.bhn.gov/nhp/NPR/plaineng.html.
Taken from "EPA Interim Guidance for Implementing the
Small Business Regulatory Enforcement Fairness Act and
Related Provisions of the Regulatory Flexibility Act,"
prepared by the EPA SBREFA Task Force February 5.1997
4-6
-------
[Insert standard publication header, including the date and appropriate publication number]
SMALL ENTITY COMPLIANCE GUIDE
[insert title of rule or program...]
I. INTRODUCTION
This document is published by the Environmental Protection Agency (EPA) as our
official compliance guide for small entities, as required by the Small Business Regulatory
Enforcement Fairness Act of 1996. Before you begin using the guide you should know that the
information in this guide was compiled and published on [INSERT PUBLICATION DATE]'.
EPA is continually improving and upgrading its rules, policies, compliance programs, and
outreach efforts. You can determine whether EPA has revised or supplemented the information
in this guide by calling [INSERT HOTLINE NUMBER OR INTERNET ADDRESS].
A. Who Should Use this Guide?
1. To the extent possible, the guide should identify all the types/categories of small entities
that will be subject to the rule's requirements. Bear in mind that other entities may be
indirectly affected but may not be required to comply. This section needs to make this
distinction clear to the reader.
Tip: Use the compliance table from the "Summary" section of your
rule's preamble to convey this information. Be sure to modify it if
necessary to target small entities.
2. In many cases, the guide will also be useful to larger entities subject to the rule. You may
wish to point out any similarities or differences at this stage but you should not go into
great detail on this subject.
B. What does the Guide Cover?
C. How do I use the Guide?
D. How do I Obtain a Complete Copy of the Rule?
Taken from "EPA Interim Guidance for Implementing the
Small Business Regulatory Enforcement Fairness Act and
Related Provisions of the Regulatory Flexibility Act,"
prepared by the EPA SBREFA Task Force February 5,1997
4-7
-------
List an 800 number, Federal Register citation or the Government Information Locator
Service.
II. WHAT DOES THE REGULATION REQUIRE?
A. What environmental/human health issue(s) does this rule address and why it is
important?
B. Summary of the New Regulation
1. Using plain English, summarize the rule in a narrative format. This should be a
simplified adaptation of the issues you discussed in the rule's preamble.
2. Additionally, provide a visual description (e.g., chart or flowchart) of the rule's
requirements as it applies to small entity operations or processes. "Operations" include
traditional facility-based operations and non-traditional based operations such as farms,
communities or schools.
C. Compliance Timetable
Identify in easy-to-read format (e.g., flowchart, time line, timetable) compliance dates for
notifications and other requirements.
D. How Does this Regulation Relate to Other Federal, State, and Local Requirements?
1. Each Program should develop specific template language concerning program
delegations and relationships to other requirements generally, or, where appropriate,
referring back to general provisions applicable to all regulations in a subgroup to which
the new regulation belongs (e.g., New Source Performance Standards under the Clean Air
Act). Programs have the flexibility to expand this section as appropriate, to address this
issue more specifically.
2. Meanwhile, here is suggested template language which may be appropriate in many
cases:
This compliance guide explains your federal compliance
obligations with respect to rule. There may be other state or
local requirements which apply to you which are different from, or
more stringent than, the federal requirements. For example, some
environmental statutes allow EPA to delegate environmental
Taken from "EPA Interim Guidance for Implementing the
Small Business Regulatory Enforcement Fairness Act and
. Related Provisions of the Regulatory Flexibility Act,"
prepared by the EPA SBREFA Task Force February 5,1997
4-8
-------
programs to a state. The state may then promulgate its own rules
which may supersede the federal requirements. For more
information on the rules that apply in your State, please contact
[INSERT CONTACT POINT].
HI. STEP-BY-STEP PROCEDURES FOR COMPLIANCE WITH THIS RULE
This is where you break down the rule into discrete subject areas using a step-by-step,
question/answer approach. Questions in this section will depend on the particular rule. All the
following questions are EXAMPLES of the types of questions that may be appropriate to
include.
A. How can I tell if I am subject to this rule?
B. What requirements am I subject to?
C. When do I need to comply ? (elaborate on flowchart, as appropriate)
D. What do I need to do to comply?
Be sure to address such questions as:
How does this rule affect my existing permit?
How much will it cost to comply with this rule?
E. What, when and how must I monitor or test?
F. What records do I need to keep and for how long?
Include sample forms and calculations.
G. What, when and to whom must I report?
Include sample forms.
H. How do I minimize harm if I think I am out of compliance? (Program lead/OECA
support)
Taken from 'EPA Interim Guidance for Implementing the
Small Business Regulatory Enforcement Fairness Act and
Related Provisions of the Regulatory Flexibility Act,"
prepared by the EPA SBREFA Task Force February 5,1997
4-9
-------
I. Where do I go for help?
Give information on federal, State and local contacts, Agency hotlines, or State Small
Business Assistance Program contacts.
J. What is pollution prevention and how can it affect my operations? (OPPT lead)
1. Discuss pollution prevention and its benefits, including how it may be used to help a
facility/operation save money and/or possibly avoid regulation.
2. To the extent that there are other pollution prevention opportunities, including those
which may make good business sense or could exempt a small entity from certain
requirements, the program, with support from OPPT, has the option to expand this
section and include this information.
K. Are there opportunities for flexibility or waivers ?
If this is applicable in a given rule, these opportunities can be highlighted here. For
example, there are circumstances in which the Safe Drinking Water Act allows temporary
variances or exemptions from maximum contaminant levels.
IV. OPTIONAL QUESTIONS AND ANSWERS ABOUT
FACILITY/OPERATIONS/PROCESSES
Here you want to anticipate questions of potential concern to the regulated community,
including how the rule fits into the overall regulatory program. Questions will depend on the
rule; the questions below are only EXAMPLES. [Tip: A self-audit checklist can be very helpful
to small entities and may be used alone or in conjunction with a question and answer format.]
A. How do I conduct a self-audit of my facility/firm/operation to help me evaluate
whether I am in compliance with this rule?
Provide Self-Audit Checklist (Program/OECA)
B. What are the implications of this rule for my existing permits?
Adapt this to your particular rule or program.
Taken from "EPA Interim Guidance for Implementing the
Small Business Regulatory Enforcement Fairness Act and
Related Provisions of the Regulatory Flexibility Act,"
prepared by the EPA SBREFA Task Force February 5 1997
4-10
-------
C. How Does this Rule Change How I Handle/ Store Wastes? (if guide were written for
RCRA rule)
V. THE COMPLIANCE ASSURANCE PROCESS (OECA LEAD)
This section should describe in clear, non-threatening terms why compliance is important,
the potential consequences of violating the law, and how the entity can work with us to identify
and correct its compliance problems, often without the need for a formal enforcement action or
penalty.
Draft this section to ensure that small entities understand:
• how EPA determines compliance
• what they must do if they discover a violation, and
• the available compliance assistance/enforcement options.
Include only information that is directly relevant to the rule. You may attach more
detailed information, or information you feel may be helpful, in an Appendix.
A. How Is My Operation's Compliance With Environmental Requirements
Determined?
Discuss compliance assistance, inspections, self-monitoring and the role of citizens.
B. If I Discover a Violation, How Can I Work With The Agency to Correct It?
Discuss compliance incentives policies: Small Communities Policy, Policy on
Compliance Incentives for Small Businesses, Self-Disclosure Policy.
C. If the Agency Discovers a Violation, What Might Be Its Response?
To maximize compliance, EPA implements a balanced program of
compliance assistance, compliance incentives, and traditional law enforcement.
EPA knows that small businesses which must comply with complicated new statutes
or rules often want to do the right thing, but may lack the requisite knowledge,
resources, or skills. Compliance assistance information and technical advice helps
small businesses to understand and meet their environmental obligations.
Taken from "EPA Interim Guidance for Implementing the
Small Business Regulatory Enforcement Fairness Act and
Related Provisions of the Regulatory Flexibility Act,"
prepared by the EPA SBREFA Task Force February 5.1997
4-11
-------
Compliance incentives, such as our Small Business Policy, encourage persons to
voluntarily discover, disclose, and correct violations before they 're identified by the
government. EPA's strong law enforcement program protects all of us by targeting
persons who neither comply nor cooperate to address their problems.
EPA uses a variety of methods to determine whether businesses are
complying, including inspecting facilities, reviewing records and reports, and
responding to citizen complaints. If we learn a person is violating the law, EPA (or
a State, if the program is delegated) may file an enforcement action seeking penalties
of up to $[INSERT STATUTORY MAXIMUM AMOUNT], per violation, per day.
The proposed penalty in a given case will depend on many factors, including the
number, length, and severity of the violations, the economic benefit obtained by the
violator, and its ability to pay. EPA has polices in place to ensure penalties are
calculated fairly. These policies are available to the public. In addition, any
company charged with a violation has the right to contest EPA's allegations and
proposed penalty before an impartial judge or jury.
In summary, EPA recognizes that we can achieve the greatest possible
protection by encouraging small businesses to work with us to discover, disclose, and
correct violations. That's why we 've issued self-disclosure, small business, and
small community policies to eliminate or reduce penalties for small and large entities
which cooperate with EPA to address compliance problems. In addition, we 've
established compliance assistance centers to serve over a million small businesses.
For more information on these and other EPA programs for small businesses, please
contact [INSERTPOINT OF CONTACT].
D. What is the legal status of this guide?
A judge can look at a compliance guide in determining what penalty is
appropriate and reasonable, although the content of the guide cannot otherwise be
reviewed by the court.
In this Compliance Guide, we have tried to make clear what you must do to
comply with the applicable law and regulation. This is the minimum required by
SBREFA. You'll notice, however, that here and there we have also included
suggestions for alternative approaches that may make compliance easier and
possibly even reduce costs. We hope you find this presentation of regulatory
requirements useful and the additional information helpful in reaching and
maintaining compliance.
Taken from "EPA Interim Guidance for Implementing the
Small Business Regulatory Enforcement Fairness Act and
Related Provisions of the Regulatory Flexibility Act,"
prepared by the EPA SBREFA Task Force February 5,1997
4-12
-------
APPENDIX
A. Glossary of Environmental Terms
Define terms which are relevant to the rule but which may be too basic to be defined in
the rule itself. For example, "permit," "pollution prevention," "process."
B. Where to Obtain More Information
This section gives supplemental information. Examples might include other existing
quality compliance guidance, pollution prevention guidance, pollution prevention case
studies, other media contacts, trade associations, or university assistance programs.
C. Questionnaire - How Useful Was This Guide?
Each guide should contain a brief questionnaire to solicit feedback from users as to the
usefulness, readability, and improvements needed for the guide. Questionnaires will be
returned to OPPE/RMD and then forwarded to the Agency contact. Please use the
following page:
Taken from "EPA Interim Guidance for Implementing the
Small Business Regulatory Enforcement Fairness Act and
Related Provisions of the Regulatory Flexibility Act,"
prepared by the EPA SBREFA Task Force Februarys 1997
4-13
-------
Date:
Title of Rule or Program:_
Name ofCommenter (optional): _
Please take a moment to let us know if you found this guide useful by answering the
following questions. Thank you, your feedback is important to us.
1. I could easily understand what requirements I must meet.
2. The guide is written in understandable language.
3. The guide helped me understand the steps I must take to comply with the rule._
4. If you have suggestions to improve the guide, please indicate below:
Please fold on dashed line, affix postage and return by mail. Thank-you.
Affix
Postage
Here
U.S. EPA
Regulatory Management Division
Mail Code 2136
401 M St. SW
Washington, DC 20460
Taken from "EPA Interim Guidance for Implementing the
Small Business Regulatory Enforcement Fairness Act and
Related Provisions of the Regulatory Flexibility Act *
prepared by the EPA SBREFA Task Force
February 5,1997
4-14
-------
APPENDIX K
Master Compliance Timeline for Part 63 NESHAP
-------
-------
Methods for Compilation of the Draft Master Compliance Timeline
The Draft Master Compliance Timeline was developed from an OAQPS/ESD document
that summarized milestone dates for each promulgated NESHAP listed in 40 CFR Part 63. In
general, the milestones are similar for each NESHAP. Where exceptions or unique milestones
were an issue, the information was noted in the Timeline.
The milestone dates listed are the latest possible dates by which the action item must be
completed. Thus, using the Secondary Lead Smelting NESHAP as an example, if an
Owner/Operator of a Secondary Lead Smelting Facility schedules ajerformance Test on
November 20,1997, instead of the latest possible date (stated in the standard) of December 20,
1997, the first Compliance Status Report must be submitted by January 19,1998 (i.e., within the
required 60 days) not on February 18, 1998.
Most NESHAPs follow the steps indicated in the table below, and these milestones are
included in the Master Compliance Timeline.
ACTION ITEM
Effective Date
O/O: Initial Notification Due
O/O: Submit Special Compliance Monitoring or
Implementation Plans
EPA/State: Review/Approve Special Compliance Monitoring
or Implementation Plans
O/O: Request for Compliance Extension
EPA/State: Approval for Request of Compliance Extensions
Compliance Date
O/O: Notice of Performance Test
MILESTONE DATE2
determined by the EPA
within 120 days of the effective date
varies by standard
varies by standard
12 months before the compliance
date
3 months after request
3 years after Effective Date
30 days before Performance Test
-------
EPA/State: Approval of Site-Specific Test Plan
Performance Test
Compliance Status Reports
Applicability Date for New Sources
Up to the Performance Test date
180 days after Compliance Date
First one is due within 60 days of the
Performance Test
determined, by the EPA
Source: Fruh, S., Summary of Compliance Dates for Promulgated Part 63 MACT Regulations, December, 1996.
O/O = Owner/Operator
* = Due to the various criteria for determining implementation dates under the Coke Ovens HAP, it
was not included in the Master Compliance Timeline (with the exception of the Applicability Date
for New Sources").
Because the following action items are only applicable to new sources (which are a small
percentage of the currently regulated population), they were not included in the Master
Compliance Timeline.
ACTION ITEM
O/O: Application for Approval to Construct/Reconstruct a
Major Emitting Source
EPA/State: Notice of Complete Information
EPA/State: Approval or Disapproval of
Construction/Reconstruction
O/O: Notice of Intended Startup
MILESTONE DATE
determined by the Owner/Operator
30 days from application
60 days from application
60 days before startup
Source: Fruh, S., Summary of Compliance Dates for Promulgated Part 63 MACT Regulations, March, 1997.
O/O = Owner/Operator
-------
MASTER COMPLIANCE TIMEUNE
TIMELINE CATEGORY
Applicabiltty Date for New Sources
S:;... ;:::». • .- . . .
Effective Data
O/O^ Initial Notification Due
O/O: Submit Special Compliance Monitoring or
EPA/State: Review/Approve Special Compliance
" ; . "•"!.." • •;••;'-:::'-'"••'"
O/O; Request fcf Compliance Extension
EPA/State: Approval of Request for Compliance
Extensions
Compliance Date
O/O: Notice of Performance test
•'•••.••. •••:••
EPA/State: Approval of Site-Specific Test Plan
Performance Test :
Compllanc* Status Reports
NOV-W
UQ&3&?
CokaOvi?*
l.«>
Dc«-«0
J«n-91
F«b-91
M«r-91
Apr-81
M«y-91
Jun-91
JUl-91
Aug-91
8«p-»1
Oct-»1
Nov-»1
.
'- OM41
O/O « Owner/Operator
-------
MASTER COMPUANCE TIMELINE
TIMELINE CATEGORY
Applicability Date for New Sources
Effective Pate
O/O: Initial Notification Due :
O/O; Submit Special Compliance Monitoring or
^ ^^^^^
EPA/State: Review/Approve Special Compliance
Monttoririti or implementation Plane
O/O? Request for Compliance Extension
EPA/State: Approval of Request for Compliance
Extensions J..
Compliance Date
O/O; Notice of Performance Test
EPA/State: Approval of Site-Specific Test plan
Performance Test . . I
Compliance Status Reports
J»n-92
Ftb-82
Mar-92
Apr-82
IMay-92
Jun-92
Jul-92
Aug-92
S*p42
Oct-«2
NOV42
C
I
)«!-W
J«v*>
NM»
MW-W
O/O • Owner/Operator
-------
MASTER COMPLIANCE TIMELINE
TIMELINE CATEGORY
Applicability Date for New Sources
Effective Date
O/O: Inttial Notification Due
O/O: Submit Special Compliance Monitoring or
Imptamentatlon Plans '
:PA/State: Review/Approve Special Compliance
Monitoring or Implementation Plant
O/Oi Request for Compliance Extension
EPA/State: Approval of Request for Compliance
Extensions
Compliance Date
O/O; Notice of Performance Test
EPA/State; Approval of Site-Specific Test plan
PerformancaTest
• > .• •:..
Comptlanoa Status Report*
Apr-93
May-93
Jun-93
Jul-93
Aug-93
5/H/22. tpokttlriat
^IOCMS Cooling
t«**r» ,
S«p49
**&*.&'.*
hyO«wiiA|}:. t-
pddBDM "'••
Oct-93
W7(!ft* '
^
NOV-W
wm?-?4&
'tfhiVMMittiMa^i' f* Va
IttJKHl^*'
^**W*g^jJ
^Wi^!*-
z^s^r
't'i'U'k'f l^i MM •
J«v»4
Ftb^4
O/O - Owner/Operator
-------
MASTER COMPLIANCE TIMELINE
O/Ol Initial Notification Due
O/O; Submit Special Compliance Monitoring or
Impfemaintation Plan*
'TTOMsiM^
^^^^^j^^^^R;*»
EPA/State: Review/Approve Special Compliance
Monitorlnftor implementation Plan*
O/O; Request for Compliance Extenaion
EPA/State; Approval of Request for Compliance
Extension* •;
Compliance Date
O/O: Notice of Performance Te«t
EPA/Stat*; Approval of Site-Specific Test Plan
Performance- Test
CompiianOfStatui Reports
O/O • Owner/Operator
-------
MASTER COMPLIANCE TIMELINE
TIMELINE CATEGORY
Applicability Date for New Sources
Effective Date
O/O: Initial Notification Due
O/Q: Submit Special Compllanot Monitoring or
Implementation Plans
: • •' :"•:' :':;. ...'•«•
EPA/State: Review/Approve Special Compliance
Monitoring or Implementation Plans
O/Oi Request for Compliance Extension
EPA/State: Approval of Request for Compliance
Extensions
Compliance Date
O/O: Notice of Performance test
EPA/State: Approval of Site-Specific Test plan
Performance Test
CompOanp* Status Reports ,,.,;v;-" • •
n ^ •> •'•'.'''•<..
Aug-34
$&j&£~: ,
$ocMrt.-
5«p-94
V>q4-tnltulM*f
TfWAMT^ ••
T(WMt« ,f r>
Oct-M
jflfryaf "Qg-sito
1rt/a*lM mild It amiMftf
SW*'"* 4.
iflajKRj' window
boj*w<«8wbp»rtH
Mi?d«r$OdMi /
Nov-94
CHC-M
Hflf ^I^M^^^fN**!*^!*, , M ?* , ^ '-
scsssfflssJK^^
fW^^2L^o^iii^v^^'"^«^^^^^vS
TITMyTO>*^P>!wTWin^M''9IW;:.J.j>> :xi«'MfA;^E^^-^C
•o^ipat-**^-^"^ •^fttlteAA^^j f'^W^P'^P'f §»>
JwvW
^w^M^ AWff^^'
rtb^o
O/O • Owner/Operator
-------
MASTER COMPLIANCE TIMELINE
TIMELINE CATEGORY
Mar-96
Apf-85
Applicability Date for New Source*
Effective Date
O/OMnttlal Notification Due
O/O; SubmK Special Compliance Monltorin0 or
Implementation Plant
EPA/State; Review/Approve Special Compliance
Monttormg or implementation Plan*
O/O: Request for Compliance Extension
EPA/State: Approval of Request for Compliance
Exten»lon« ' ," .
Compliance Date
O/O: Notice of Performance Tett
EPA/Slate: Approval of Site^pecifte Test Plan
PerformahceTest
Compliance Statue Report*
O/O - Owner/Operator
-------
MASTER COMPLIANCE TIMELINE
TIMELINE CATEGORY
Applicability Date for New Sources
Effective Date
0/0: Initial Notification Due
O/O: Submit Special Compliance Monitoring or
iiiipMnieiuaiKjii rianv
EPA/State: Review/Approve Special Compliance
Monitoring or Implementation Plans
O/Ot Request for Compliance Extension
EPA/State: Approval of Request for Compliance
Extensions
Compliance Date
O/Ot Notice of Performance Test
EPA/State: Approval of StonSpeclflc Test Plan
s«p-«s
%^*\rtui^t>ttiDM&x^
T^i', /;
Oct-96
S^iil
4fMlltbV¥: •'•'•' > -•':-•-
s?«***
$OCMt
NOV-W
Occ-W
^^S^^
Jm-N
™
F«t»4*
Itar-W
SW5Wf®||i8i)lMfc?
1*MM M^^^^Mnil
-------
MASTER COMPLIANCE TIMELINE
TIMELINE CATEGORY
May-96
Jun-96
Jul-86
Aug-M
Applicability Date for New Sources
Effect! ve Date
WM<
npMtainmt'.
M'^^^P^ffi^^'
Ifllflf .M^rrtV«u4MiMi«4
O/O: Initial Notification Due
*w*«Mp«»p*>f
Ek^iiinkiAA •• ' •••
8CHBIB1
O/O: Submit Special Compliance Monitoring or
Implementation Plan*
EPA/State: Review/Approve Special Compliance
MOnttOftng or Implementation Plans }
O/O; Request for Compliance Extension
EPA/State: Approval of Request for Compliance
Extension*
Compliance Date
-? ...... ^ .f v, "„ f . -.
O/O: Notice of Performance Test
EPA/State: Approval of Site-Specific Test Plan
Performance Test
2333$*
Compliance Status Reports
O/O » Owner/Operator
-------
MASTER COMPLIANCE TIMELINE
TIMELINE CATEGORY
Nov-99
Ctac-M
J«n-«7
Applicability Date for New Sources
Effective Date
EPA/State: Review/Approve Special Compliance
Monitoring or Implementation Plans
O/C: Request for Complianos Extension
PticntturvMimifMEn^rtii^ •;;
•milting »M ton* HAP*
j£*gt«£ti*l*Mi
»/»A«r..*rtrHji.
EPA/State: Approval of Request for Compliance
Extensions
Compliance Date
rM^^To|MMawri^^
" % % '
O/O: Notice of Performance Test
EPA/State: Approval of Site-Speclflc Test Plan
Performance Test
Compliance Status Report*
O/O • Owner/Operator
-------
MASTER COMPLIANCE TIMEUNE
TIMELINE CATEGORY
Apf-97
May-87
Applicability Date for New Source*
Effective Date
OIQi Initial Notification Dim
O/O; Submit Special Compliance Monitoring or
Implementation Plans
EPA/State; Review/Approve Special Compliance
Monitoring or Implementation Plane
O/O: .Request for Compliance Extension
EPA/State: Approval of Request for Compliance
3H6M Mj$Mpbutk%andShtpM^i>Bo8tll
-------
MASTER COMPLIANCE TIMELINE
TIMELINE CATEGORY
Jul-97
Aufl-97
Ort-87
NOV47
Applicability Date for New Sources
Effective Date
O/O; Initial Notittcatton Oil*
O/O; Submit Special Compliance Monitoring or
Implementation Plan*
WiM^*^:i»A^)W*tfa..
•teTBtob»monitor«d«#
EPA/State: Review/Approve Special Compliance
Monitoring or Implementation
O/Ot Request for Compliance Extension
', '
EPA/State: Approval of Request for Compliance
Extensions
Compliance Date
(V
-------
MASTER COMPLIANCE TIMELINE
'v
St^ib«j)iiasni>;«ftd Ship Repairfac^tef
SaconBi
TIMELINE CATEGORY
Applicability Date for New Source*
Effective Date
O/OMnttiat Notification Due
O/O; Submit Special Compliance Monitoring or
Implementation Plan*
EPA/St«te: Review/Approve Special Compliance
Monitoring or Implementation Plan*
O/O: Request for Compliance Extension
EPA/State: Approval of Request for Compliance
Extension*
Compliance Date
O/O: Notice of Performance Test
EPA/St*t«: Approval of SIte-Speclflc Test plan
PerfbrmancftTest
Compliance Status Report*
O/O • Owner/Operator
-------
MASTER COMPLIANCE TIMELINE
TIMELINE CATEGORY
Apr-98
Applicability Date for New Sources
Effective Date
O/O: Initial Notification Due
O/O: Submit Special Compliance Monitoring or
lmp(*m«ntatJon Plans
EPA/State; Review/Approve Special Compliance
Monitoring <* Implementation Plans
O/O! Request for Compliance Extension
EPA/State: Approval of Request for Compliance
Extension*
ftflftflfl
Compliance Date
O/O - Owner/Operator
-------
MASTER COMPLIANCE TIMELINE
TIMELINE CATEGORY
JiH-W
Aliff-98
$tp-W
Applicability Date for New Sources
Effective Date
O/O: Initial Notification Due
O/O; Submit Special Compliance Monitoring or
Implementation Plan*
EPA/State: Review/Approve Special Compliance
Monitoring or Implementation Plan*
ryiVmrttt itftd fifroiflt &tttut* I
O/Ol Request for Compliance Extension
XJ$ * f *- *«/ , ' !-
•' a", 3 As * V
EPA/State: Approval of Request for Compliance
Extension*
Compliance Date
Petfoteum RriiiMriaK Other Source* Nat Dwioftif iktod -
O/O: Notice of Performance Test
EPA/State: Approval of Sttc-Speciflc Test Plan
Performance Test
Compliance Status Reports
" ™- ^ f •* t f S&v*? ^ ••
^^^^"^w
U-' X & %
O/O « Owner/Operator
-------
MASTER COMPUANCE TIMELINE
TIMELINE CATEGORY
Oct-98
Nov-98
Dec-98
Jan-M
Applicability Date for New Sources
Effective Date
0/0: Initial Notification Due
O/O: Submit Special Compliance Monitoring or
Implementation Plans
EPA/State: Review/Approve Special Compliance
Monitoring or Implementation Plans
(wtth a control device:
altematfveSmit \wheh
notoccuHng)
1VSIM • Polymers and Resins Group I (pre-
10f1V98 • Polymers and Resins Group IV
(pm-compnance report) •-•='."
O/O: Request for Compliance Extension
EPA/State; Approval of Request for Compliance
10/1/99 • Off-Site Waste and Recovery
Operations _-. •• , ; •_ ;< !. ,
10WM - Polymers and Resins Group I (not
tor equip, leaks/compressors)
1J/1VM. Potvmen and Resins Group IV
Compliance Date
•Wood Fumibire ManutachJrina
Opentlons (tor sourps* •mttttr
-i^.- . ."> •^;\.-^M^rMl;^J-."
HAPsln19«6)
Bfty!«i:
0/0; Notice of Performance Test
UftOff • Asro^ao* MtrHJfadiinnfl
^q|«gj|pliliiiliJ
tS'WWf1
EPA/State: Approval of Site-Specific Test Plan
Performance Test
Compliance Status Reports
Resins and Non-
Nylon Potyamldes
O/O • Owner/Operator
1 Aooonflng to • July 29,1907 memorandum from Vie Director of OAQPS. the compliance date far Ethytone Oxide
-------
MASTER COMPLIANCE TIMELINE
: TIMELINE CATEGORY
Feb-99
Apr-M
M«y-9»
Jwvst
Applicability Date for New Sources
Effective Date
O/O* Initial Notification Due
O/O; Submit Special Compliance Monitoring or
|ntpiM«nentatioft Plan* >:: -;: .{ ' "]•'
EPA/State; Review/Approve Special Compliance g»S
Monitoring or implementation Plan* ;
^^^P^^^f* *^T? ^^WflB^^Wpv^
O/O; ReqUeflt for Compliance Extension
EPA/State: Approval of Request for Compliance
Extensions '..'•'
Compliance Date
O/O: Notice of Performance Test
EPA/State: Approval of Site-Specific Test plan
Performance test
Compliance Status Report*
O/O • Owner/Operator
v
feifiufcM'Atfhm fcitd
-------
MASTER COMPLIANCE TIMELINE
TIMELINE CATEGORY
Applicability Date for New Sources
Effective Date
0/0: Initial Notification Due
O/O: Submit Special Compliance Monitoring or
Implementation Plan*
EPA/State: Review/Approve Special Compliance
Monitoring or Implementation Plans
-,.••'•: . ' ' ' '
O/O: Request for Compliance Extension
EPA/State: Approval of Request for Compliance
Extensions
Compliance Date
O/O: Notice of Performance Test
EPA/State: Approval of Site-Specific Test Plan
Performance Test
^,.V.^^^;itV...':V/ "'&'. ••'' :'
Compliance SjMrtua Reports •
f> * f ' '•'.','••,•'.•
AU0-M
j/WSt- Petroleum
Refineries (marine tank
vestal* not electing
emissions averaging)
6ep-8$
ft^-r^jV™«»^R«w^<5rov*Por^mef»^S»rir»Qr9.ytVfj>ot«br equip,
6>ksteom.pfeftEocB^ ' %
9/1V99 * Murlmt tank HatiMi toadtnfl «Sp«rafJdn»
&22^-PitoBooWp«W»8M»g ......
^ *% : ^ ( '
>v / ^ ' ^' -- i
Oct-99
laiSiSt^SOq*, "..;;>:;:;:,
Wfls^M^MlaWl^'' ^ ^^^^^
iMM^O^w^'
H
11 1
lcrtfl**-»8Jitl^^^^
O*e4t
^^B^^^^i^D
3Eg^S3g|&iggg£sSS?
^H^^Hi
O/O • Owner/Operator
-------
MASTER COMPUANCE TIMELINE
TIMELINE CATEGORY
Applicability Date for New Sources
• ..:];_ ;:.'".
• .-'•••• ''".-.
Effective Date
O/Oi Inttlat Notification Due
' -\ :•::::•;'..-'••' .;.-.:•:.•
O/O: Submtt Special mpll«rK» Monitoring or
firt pMiHMit ttri)0li Pf M£ ' '' <: :v : ; • • . •• > '-
s ,.'', ': '''...,"-.
'• •'">'•':• ••'.
EPA/State; Review/Approve Special Compliance
Monitoring or Implementation Plant
O/Ot Request for Compliance Extension:
EPA/State: Approval of Request for Compliance
Extensions ;
'••••"-- ••'.'"''
Compliance Date
:•: -.'.'•
O/O: Notice of Performance Test
:•.
EPA/State; Approval of Site-Specific Test Plan
Performance Test
Compliance Status Reports
J*n-oo
JS^ TfWtW*<>RM*w
*P^«V '' , * , \'v '-
'' -''•. v> _. %5
iaaa?'^i«^i**jjp«ttw*)jf . "..
>
F«bXW
1/522 - Pp»yt»w wti f?wte« 1 ; ^ rf
JOJ^.M^f ?««*V««ilWMn8y i\;
teMvlloat •••.•• •• *''••'
" * ' V^/
•" "• "v
Z/g^*Po)yn»«««dR««iB«>
J/Il^-Potymf^wdRMrfrwqttwlV : :
Ji2432C*Oft^teWwi.«dR«ovWy; -
awallbnc ••-'
«ftv»miw»> , i tS»> .. ..*,
M»-00
fflffffiff *
fertfcfViK**..
^f4Ct,M)dlttt
!>™rt~«
Apr-00
M«H»
wm^***»
MtltinMMt! %%
^^WF^^ft
O/O • Owner/Operator
-------
APPENDIX L
MACTRAX
-------
-------
MACTRAX
• Used by the Regional Offices to transfer information to OAQPS.
• Identifies which State/Locals (S/L) are implementing each MACT standard:
> thru Title V delegation
>• thru implementation agreements
> by Regional Office
• Each Title V program will have a MACTRAX screen per standard
The information collected in MACTRAX for FY 1997 from S/L's with delegation
authority will be voluntary.
• The information to be collected in MACTRAX was included for the performance
measures for the Office of Air Research FY 1997-98 Implementation Plan.
• Regions are expected to incorporate performance measures in their FY 1998 State
agreements which would include providing (or at least requesting) the
MACTRAX reporting information for the end of the FY 1997 reporting cycle.
• The Region should identify the States that are not providing the information by
adding a note in the comment field of the delegation screen.
• The regions can use the source-specific information available in AIRS Facility
Subsystem (AFS) as the summary of the source category-specific information
needed in MACTRAX. State delegation information, which is not provided
through AFS, will still need to be entered into MACTRAX on the same time
schedule.
------- |