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Unrted States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EPA 450/3-92/007(b)
March 1994
Air
Guidelines for MACT
Determinations under
Section 112(g)
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Table of Contents
Introduction iv
Chapter 1.0 An Overview of the MACT Determination Process....!
1.1 Overview of Statutory Requirements 1
1.2 Overview of the Regulatory Requirements 4
1.3 Overview of MACT Determination 6
Chapter 2. 0 The MACT Determination 9
2.1 Criteria for the MACT Determination 9
2.2 Compliance Provisions... 14
2.3 Available Control Technologies 21
Chapter 3 . 0 The MACT Analysis 23
3.1 Overview of the MACT Analysis Process 24
3.2 A Detailed Look at the MACT Analysis 30
3.3 Determining the MACT-Affec'ted Source on a
Case-by-Case Basis 44
3.4 Similar Emission Units 57
3.5 Subcategorization. 62
Chapter 4.0 The MACT Floor Finding 63
4.1 Calculation of the MACT Floor 66
4.2 Method 1- Computing the MACT floor using
existing State and Local Regulations 73
4.3 Method 2 - Computing the MACT Floor using
Control Efficiency Ratings 78
4.4 Method 3 - Computing the MACT Floor using
Emission Reduction Ratios (ERR) . . .- ,80
4.5 Exceptions to the Emission Reduction
Ratios 85
4.6 Other Methods to Compute
the MACT Floor 86
Chapter 5.0 Costs, Non-Air Quality Health and Environmental
Impacts and Energy Requirements 87
5.1 Costs Impacts 89
5.2 Environmental Impacts 92
5. 3 Energy Requirements 93
Chapter 6.0 Information Sources 96
References 108
Appendix A Examples of MACT Analyses A-l
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Appendix A Examples of MACT Analyses A-l
Appendix B Forum of Anticipated Questions B-l
Appendix C Definitions C-l
Appendix D List of Major Source Categories D-l
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LIST OF FIGURES
Figure 1 Stages of the MACT Determination Process 7
Figure 2 Example Notice of MACT Approval 17
Figure 3 The MACT Analysis 26
Figure 4 . Emission Units Affected by a Modification 46
Figure 5 Drainage Collection System 48
Figure 6 Combining Emission Points into a
MACT-affected Emission Unit 51
Figure 7 Using State or Local Air Pollution Regulations to.
compute the MACT Floor 74
Figure 8 Evaluation of State Regulations
for Emission Unit X 76
Figure 9 Using Emission Reduction Ratios
to Compute the MACT Floor 82
ill
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Introduction
This guidance document is designed to clarify the statutory
and regulatory requirements for MACT determinations as required
by Section 112(g) of the Clean Air Act (the Act) as amended in
1990. It sets forth procedures for determining emission
limitations based on maximum achievable control technology for
major sources that construct, reconstruct or modify.
The manual is divided into six chapters and a four section
appendix. Chapter 1 of this manual provides an overview of the
statutory and regulatory requirements and overviews the MACT
determination process. Chapter 2 outlines the criteria a
permitting agency should use when evaluating applications. It
also discusses compliance provisions and the definition of
available information. Chapter 3 describes the process for
selecting a control technology that meets the criteria discussed
in Chapter 2. Chapter 4 provides a detailed description of MACT
floor calculation procedures. Chapter 5 describes the analysis
that may be required to assess the costs of achieving the
emission reduction, and any non-air quality health and
environmental impacts and energy requirements associated with use
of different control options. Chapter 6 discusses the national
databases that may assist in the collection of available
information.
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Part A of the Appendix illustrates examples for defining a
MACT-affected emission unit, and selecting a ^control technology
to meet MACT. Part B is a question and answer forum. It is
designed to deal with detailed questions on applicability and
other issues. Part C of the Appendix contains a glossary of
terms and definitions. In Appendix D, a complete list of source
categories of major sources is provided. This listing is current
only to the date of this publication. Readers are referred to
the Federal Register for any changes to this listing.
It is hoped that this guidance document contains useful
information for implementation of Section 112(g) of the Act. For
more information on MACT determinations, the reader is advised to
read 40 CFR Part 63, Subpart B, and Section 112 of the Act.
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Chapter 1.0
AN OVERVIEW OP THE
MACT DETERMINATION PROCESS
1.1 An Overview of Statutory Requirements
The provisions of Sections 112(g) of the Clean Air Act as
amended in 1990 (The Act) become effective in a State on the date
that interim, partial or full approval is granted to the State's
(or local's) Title V permit program. Under Section 112(g), a
MACT determination is required for major sources that propose to
construct or reconstruct (as defined by 40 CFR Part 63, Subpart
B,) before the promulgation of a relevant Section 112(d) or
•
112(h) emission standard. MACT determinations are also required
for major sources that propose to modify (as defined by 40 CFR
Part 63, Subpart B) before and after the setting of a relevant
Section 112(d) or 112(h) emission standard. Readers are referred
to 40 CFR Part 63 to determine if a relevant emission standard
has been promulgated for a relevant source category.
A MACT determination is a process by which a permitting
agency determines that the emission points that will be affected
by the construction, reconstruction or modification achieve a
maximum achievable control technology (MACT) emission limitation.
When a relevant Section 112(d) or 112(h) emission standard has
been promulgated for the source category, the MACT determination
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process will ensure that the affected emission points comply with
the promulgated standard. When no relevant emission standard
exists, a case-by-case determination of the MACT'emission
limitation is required. This emission limitation will require
the maximum degree of reduction of hazardous air pollutant
emissions (HAPs) taking into consideration the costs of achieving
such emission reductions, and any non-air quality health and
environmental impacts, and energy requirements. For construction
and reconstruction of major sources, the MACT emission limitation
will be no less stringent than the emission control that is
achieved in practice by the best controlled similar source. For
modified major sources the MACT emission limitation will be no
less stringent than:
the average emission limitation achieved by the best
performing 12 percent of the existing sources (for which the
Administrator has emissions information), excluding those
sources that have, within 18 months before the emission
standard is proposed or within 30 months before such
standard is promulgated, whichever is later, first achieved
a level of emission rate or emission reduction which
complies, or would comply if the source is not subject to
such standard, with the lowest achievable emission rate (as
defined by Section 171 (of the Act)) applicable to the
source category and prevailing at the time, in the category
or subcategory for categories and subcategories with 30 or
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more sources; or,
the .average emission limitation achieved by the best
performing 5 sources (for which the Administrator has or
could reasonably obtain emissions information) in the
category or subcategory for categories or subcategories with
fewer than 30 sources.
These minimum requirements for the MACT emission limitation are
termed the "maximum achievable control technology (MACT) floor".
Section 112(g) also directs EPA to establish guidelines for
carrying out the requirements of Section 112(g) of the Act.
These requirements are contained in Chapter 40, Part 63, Subpart
B of the Code of FederaLJRecmlation.
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1.2 Overview of the Regulatory Requirements
*
The owner or operator or a major source is required to
obtain or revise a Title V permit or obtain a Notice of MACT
Approval (NOMA) before construction, reconstruction or
modification of the major source. This document will contain the
MACT emission limitation and other requirements to ensure
federally enforceability of the emission limitation. If a
relevant emission standard has already been established pursuant
to Section 112(d) or Section 112(h), modifying sources may only
be required to submit a notification of the proposed change. A
notification is acceptable if the emission point will continue to
meet the emission standard without a change in, or addition of a
different control technology. In some instances, the MACT
standard may provide specific procedures for dealing with
modifications. In such cases, the MACT standard should be
followed in lieu of Section 112(g). Section 112(g) does not
affect construction and reconstruction of major sources after a
relevant standard. Readers are referred to the provisions of
Section 112(i)(a) for more information.
In preparing the application for a Title V permit or a
Notice of MACT Approval, the owner must recommend a level of
control and appropriate monitoring, reporting and recordkeeping
parameters for control of HAP emissions from each existing source
or constructed or reconstructed source within the source
category. The recommended level of HAP emission control should
\
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be based on the maximum achievable control technology (MACT), and
<• .
be no less stringent than the MACT floor (when information is
available to determine the MACT floor level of control.)
Chapter 3 of this manual discusses a process for developing
the information required in the Title V permit application or
application for a Notice of MACT Approval. The process is termed
the "MACT analysis". This analysis includes a MACT floor
finding, establishing a MACT emission limitation and selecting a
control technology to meet this emission limitation.
Once the MACT analysis is complete, the owner or operator
can prepare the Title V permit application or application for a
Notice of MACT Approval. The application for a Title V permit
should be prepared in accordance with the provisions contained in
40 CFR Part 63 and 40 CFR part 70 or CFR Part 71 whichever is
applicable to the major source.
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1.3 An Overview of the MACT Determination
To meet the regulatory requirements implementing Section
112(g) of the Act, EPA developed a recommended process for
obtaining a MACT determination. Figure 1 diagrams the steps for
this recommended process. For most major sources, the process
will begin with a MACT analysis conducted by the owner or
operator. The objectives of the MACT analysis are to: (1)
Determine a level of control equal to the MACT floor; (2)
Identify MACT; (3) Establish the MACT emission limitation; and
(4) Select a control strategy to meet this required level of
emission control.
The MACT analysis is broken into three tiers. The steps and
process for each tier are detailed in Chapter 3 of this manual.
After receiving an application, the reviewing agency will
have a specified period of time to review the application to make
a completeness determination, and then an additional period of
time to approve or disapprove the application. Before issuing a
final approval notice, the permitting agency will provide an
opportunity for comment from the public, EPA, and all affected
States. When a Notice of MACT Approval is.issued, it will
contain the MACT emission limitation(s), the required control
technology and all compliance requirements. Compliance
requirements, and the Notice of MACT Approval are discussed in
Chapter 2.
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Figure 1
Stages of the
MACT Determination Process
Stage 1 Conduct a MACT Analysis.
Make a MACT floor finding
Identify MACT
Establish a MACT emission limitation
Select a control technology
Stage 2 Submit Application for MACT Determination.
Stage 3 Await Agency Review.
Completeness
Public, EPA and Affected State Review
Approve or Disapprove
Stage 4 Receive Notice of MACT Approval.
Stage 5 Begin Construction, Reconstruction, or Modification.
Stage 6 Obtain an Applicable Part 70 or Part 71 Permit Revision.
(This stage maybe done concurrently with the other stages or after
obtaining a MACT Determination.)
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Finally, the provisions of the MACT determination will be
incorporated into a Part 70 or Part 71 permit, whichever is
applicable to the major source. This may occur concurrently with
the MACT determination, or sometime after the determination
process.
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Chapter 2.0
The MACT Determination
2.1 Criteria for the MACT Determination
The process of reviewing the Title V permit application or
the application for a Notice of MACT Approval to determine the
(MACT) emission limitation is called a MACT determination. For
case-by-case MACT determinations under Section 112(g), the MACT
emission limitation should be comparable to the emission
limitation(s) and requirements that would likely be imposed if a
Section 112(d) or Section 112(h) emission standard had already
been promulgated for that source category. The Clean Air Act
establishes specific criteria for setting a hazardous air
pollutant emission standard under Sections 112(d) and Section
112(h). These criteria should also be used when determining the
MACT emission limitation under Section 112(g).
In conducting the MACT determination, the permitting agency
must determine if the owner or operator has recommended an
appropriate MACT emission limitation(s) or other requirements for
the MACT-affected emission unit (discussed in Chapter 3), given
the expected performance of the maximum achievable control
technology (MACT). To approve the application, it should meet
the following criteria:
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March 1994
(•a) When a relevant emission standard has been promulgated
pursuant to Section 112(d) or 112(h) of the Act, the
application demonstrates that the emission unit will
comply with the MACT emission limitation and other
requirements of the relevant standard.
(b) When a relevant emission standard has been proposed
pursuant to Section 112(d) or 112(h) of the Act, the
application demonstrates that the emission unit will
meet the emission reductions and other requirements of
the proposed rule, unless an alternative control level
or requirement can be adequately supported.
•
(c) When a relevant emission standard has not been
promulgated or proposed pursuant to Section '112(d) or
Section 112(h):
(1) The application documents a MACT floor finding
based on all available information, and
(2) When a positive MACT floor finding is made, the
application demonstrates that the emission unit
will meet a MACT emission limitation that is at.
least equal to the MACT floor and achieves the
maximum degree of emission reductions of the
hazardous air pollutants with consideration to the
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March 1994
costs, non-air quality health and environmental
impacts and energy requirements associated with
the emission reduction; or,
(3) When a negative MACT floor finding is made, the
application demonstrates that the emission unit
will meet a MACT emission limitation that achieves
a maximum degree of emission reductions with
consideration to costs, non-air quality health and
environmental impacts, and energy requirements,
and that this emission limitation was established
after evaluating all commercially available
control technologies that can be identified
through available information and that have been
successfully demonstrate in practice for a similar
source.
(d) When a MACT emission limitation can not be prescribed
due to the nature of the process or pollutant, the
application designates a specific design, equipment,
work practice, operational standard, or a combination
thereof, that achieves a maximum degree of emission
reduction.
The MACT floor finding is a determination of whether a level
of HAP emission control that is equal to the MACT floor can be
determined using, available information. The MACT floor finding
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is discussed further in Chapter 4. The definition of available
information is discussed in Section 2.3 of this Chapter.
The MACT emission limitation could be expressed as a
numerical emission limitation on the total quantity of HAP
emissions from the source in tons per year (tpy); or, it could
be expressed as a ratio of tons emitted to production unit
produced. The MACT emission limitation could also be a
performance standard based on the expected efficiency of MACT in
reducing HAP emissions. If it is infeasible to prescribe a
specific numerical limitation or reduction efficiency, the MACT
emission limitation can also be expressed based on a design,
equipment, work practice, operational standard, or any
combination of these.
If an individual hazardous air pollutant is of particular
concern, a MACT limitation should also be placed on that
pollutant based on the expected level of reduction with MACT in
place. Reviewing agencies should determine whether it is
appropriate to impose.a total HAP emission limitation and/or an
individual MACT emission limitation on a specific hazardous air
pollutant. In addition to recommending the MACT emission
limitation, the reviewing agency should specify any requirements
that are necessary in order to make the emission limitation
federally enforceable as a legal and practical matter. This
involves establishing appropriate operational or production
limits and monitoring parameters to ensure compliance with the
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MACT emission limitation. The following section discusses
compliance provisions in greater detail.
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2.2 Compliance Provisions
Each Title V permit and Notice of MACT Approval must contain
sufficient testing, monitoring, reporting, and recordkeeping
requirements to ensure that the MACT emission limitation is
federally enforceable as a legal and practical matter.
In order to be federally enforceable, operational limits or
production limits must be imposed on the source in addition to a
blanket emission limitation. . For example, a blanket 40 tpy MACT
emission limitation on HAPs would not be federally enforceable.
In addition to the blanket emission limitation, a source may be
required to comply with a production limitation that limits the
amount of gallons -used per hour in the operation; or the source
may be required to comply with an operational limitation on its
hours of operation and emission rate.
Production limits are restrictions on the amount of final
product that can be manufactured or otherwise produced at the
source. Operation limitations are other restrictions on the
manner in which a source is run. Operation limitations include
limits on quantities of raw material consumed, fuel combusted,
hours of operation, or conditions which specify that the source
must install and maintain controls that reduce emissions to a
specified emission rate or level.
When the permit or Notice of MACT Approval requires an add-
on control, operating parameters and assumptions that can be used
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to determine the efficiency or emission rate of the devise should
be specified in the document. For example, a source may have a
MACT emission limitation that requires a control devise to be
installed and operated at a 95% efficiency rate. An operational
limit on the range of temperatures that the devise can be
operated under could be sufficient to ensure federal
enforceability, if operating the control devise within this
temperature range ensures that the devise achieves a 95%
destruction efficiency.
If establishing operating parameters for control equipment
is infeasible in a particular situation, a short term emission
limit (e.g. Ibs/hr) would be sufficient provided that such limits
reflect the operation of the control equipment, and additional
requirements are imposed to install, maintain, and operate a
continuous emission monitoring system (GEM) or other periodic
monitoring that yields sufficiently reliable data to determine
the source's compliance with the MACT emission limitation. Such
monitoring may be instrumental or noninstrumental and may consist
of recordkeeping designed to serve as monitoring.
If parameter monitoring of a production or operational limit
is infeasible due to the wide variety of coatings or products
used or the unpredictable nature of the operation, emission
limits coupled with a requirement to calculate daily emissions
may be required. For instance, a source could be required to
keep the records of the daily emission calculation, including
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daily quantities and the HAP content of each coating used.
For either operation or production limitations to be
enforceable as a practical matter, the limitations should extend
over the shortest practicable time period, generally not to
exceed one month. If it is not practicable to place a monthly
limit on the source, a longer time can be used with a rolling
average period. However, the limit should not exceed an annual
limit rolled on a monthly basis.
In addition to conveying practical enforceability of,a MACT
emission limitation, the Title V permit or Notice of MACT
Approval should require testing or instrumental or non-
instrumental monitoring that yields data this is representative
of the source's operations and can be used to certify the
source's compliance with the terms and conditions of the Title V
permit or Notice of MACT Approval. Such testing or monitoring
requirements may be in the form of continuous emission monitoring
systems, continuous opacity monitoring systems, periodic testing,
or it.may consist of recordkeeping designed to serve as
monitoring. If periodic testing is required, the specific EPA
approved method or equivalent method that is to be used should be
specified in the permit or notice if such methods exist. Figure
2 contains a suggested format for the Notice of MACT Approval.
16.
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Figure 2
Example Notice of MACT Approval
Notice of MACT Approval
CFR 40, Part 63, Subpart B
Maximum Achievable Control Technology Emission Limitation
for
Constructed, Reconstructed or Modified Source
This notice establishes federally enforceable maximum
achievable control technology emission limitation(s) and
requirements for Name of manor source for the MACT-affected
emission unit(s) located at location all MACT-affected emission
units. The emission limitations and requirements set forth in
this document are federally enforceable on effective date of
notice.
A. Major source information
1. Mailing address of owner or operator:
2. Mailing address for location of manor source:
3. Source category for major source:
4. MACT-affected emission unit(s): List all emission
unit(s) subject to this Notice of MACT Approval along
with.the source identification number if applicable.
5. Type of modification, construction or reconstruction:
Describe the action taken by the owner or operator of
the major source that triggered the requirements of 40
CFR Part 63, Subpart B,
6. Anticipated commencement date for construction,
reconstruction or modification:
7. Anticipated start-up date of constructed, reconstructed
or modified emission unitfs):
8. List of the hazardous air pollutants potentially
emitted by MA_CT-affected emission unitfs^ : List all
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March 1994
hazardous air pollutants that are or could possibly be
emitted from the affected emission unit(s).. Any
pollutant not listed in this section can not be emitted
by the emission unit without an amendment to the Notice
of MACT Approval.
B. MACT Emission limitation
1. The above stated owner or operator shall not exceed the
following emission limitation(s) for the above stated
MACT-affected emission unit(s). Write in emission
standard or MACT emission limitation for overall
hazardous air pollutant emissions from each affected
emission unit. If the permitting authority determines
that an individual pollutant emission limitation is
appropriate, it should also be listed in this section.
2. The above stated owner or operator shall install and
operate the following control technology(s), specific
design equipment, work practice, operational standard,
or combination thereof to meet the emission standard or
MACT emission limitation listed in paragraph 1 of this
section. List all control technologies to be installed
by the owner or operator and which emission units the
control technologies will reduce HAP emissions from.
3. The above stated owner or operator shall adhere to the
following production or operational parameters for the
technologies listed in paragraph 2 of this section.
State all production or operational parameters. For
example:
The owner or operator may, subject to [name of
agency] approval, by pass the emission control
device for a limited period of time for purposes
such as maintenance of the control device.
The owner or operator shall operate and maintain
the control equipment such that it has a 95%
hazardous air pollutant destruction efficiency.
The owner or operator shall not operate the MACT-
affected emission unit for greater than 6 hours in
any 24 hour period of time.
C. Monitoring requirements
For each MACT emission limitation and operational
requirement established in Section B (MACT emission
limitation) the above stated owner or operator shall comply
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with the following monitoring requirements. State all
monitoring requirements. For example:
After installing the control equipment required to
comply with Section(B)(1) visually inspect the internal
floating roof, the primary seal, and the secondary
seal, before filling the storage vessel
The owner or operator shall calibrate, maintain and
operate a continuous monitoring system for the
measurement of opacity of emissions discharged from the
control device required in Section(B)(2) according to
the following procedures:
D. Reporting and Recordkeeping Requirements
List all reporting and recordkeeping requirements in this
section. For example:
The owner or operator shall maintain at the source for
a period of at least 5 years records of the visual
inspections, maintenance and repairs performed on each
secondary hood system as required in Section(B)(2).
E. Other requirements
I. The above stated owner or operator shall comply with
all applicable requirements specified in the general
provisions set forth in Subpart A of 40 CFR Part. 63,
including but -not limited to notification operation and
maintenance, performance testing, monitoring,
reporting, and recordkeeping requirements. If there are
any specific requirements that the reviewing agency
would like to clarify, those requirements should also
be stated in this paragraph. This paragraph could also
include requirements for emergency provisions and
start-up and shut-down procedures.
2. In addition to the requirements stated in paragraph 1
of this section, the owner or operator will be subject
to these additional requirements. Any additional
requirements not specified in Subpart A of 40 CFR Part
63 should be stated in this paragraph. If the
reviewing agency wishes to require a mandatory retest
of a failed performance test that should be stated in
this paragraph, along with any other, requirements
specified by the reviewing agency.
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F. Compliance Certifications
•»
The above stated owner or operator shall certify compliance
with the terms and conditions of this notice according to
the following procedures: This sections should include a
description of the terms and condition that the owner or
operator will use to certify compliance, as well as, the
format and frequency of the certification.
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2.3 Available Control Technologies
Before issuing a permit or NOMA, the permit agency must
assure that the MACT emission limitation achieves a degree of
emission reduction equal to or greater than the MACT floor. To,
do this the agency will need to make a MACT floor finding, or
verify the finding made by the applicant.
For the purposes of Section 112(g) MACT determinations,
emission information is considered available or reasonably
obtainable to the permitting agency if the information can be
obtained from EPA's Office of Air Quality, Planning and Standards
or Regional offices, the EPA's National MACT database or other
publically available databases (See Chapter 6), or from within
the permitting^agency itself. A permitting authority is not
required to search for available information if a Section 112(d)
or Section 112(h) proposed standard is used to establish the MACT
floor.
It is not necessary for the MACT floor to be determined
based on emissions information from every existing source in the
source category if such information is not available. Once a
permitting agency has obtained available information, the MACT
floor can be determine using this information if it is
representative of the source category. For example, suppose
there are 100 sources in a source category. Control technology X
and Y are generally considered to achieve the greatest amount
emission reductions among existing sources. Thirty sources in
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March 1994
the category use these technologies. The floor could be
determined based on these technologies, even if information was
not available on the other seventy sources.
EPA realizes that the information that is reasonably
available or obtainable for the permitting agency is'not
necessarily reasonably available to the owner or operator.
Owner's or operator should submit an application for a Title V
permit or a Notice of MACT Approval based on information that the
owner or operator is able to obtain. The permitting agency
should use the completeness of application review period to
determine if the owner or operator should consider additional
information that is reasonably available to the permitting
authority. An amended application should be submitted if
additional information should be consider in the MACT analysis.
Information that is made available subsequent to the completeness
determination need not be consdiered before issuing the Title V
permit, or Notice of MACT Approval if the information was not
reasonably available at the time of the completeness
determination.
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Chapter 3.0
The MACT Analysis
For most source categories, the process of recommending a
level of control involves a number of decisions either on the
part of the owner or operator preparing an application for a
Title V permit or NOMA, or a permitting agency who is reviewing
the application. First, it must be determined in which source
category each of the affected emission points belong. Then,
affected emission units must be identified. Emission units could
be an aggregration of affected emission points from within the
same source category. Or, a single emission point could be
considered an emission unit.
For each affected emission unit, the application submitted
by an owner or operator must recommend a MACT emission limitation
that is no less stringent than the MACT floor, but could be more
stringent if a greater degree of HAP emission reductions can be
achieved with consideration to the costs, non-air guality health
and environmental impacts and energy requirements associated with
achieving the additional emission reductions. A MACT floor
finding, a determination of MACT, and a consideration of control
technologies to meet a MACT emission limitation must be included
in the application submittal. The process by which these
decisions are made have been termed the MACT analysis. The
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following sections of this Chapter describe a MACT analysis
process that EPA has developed to meet the requirements of 40 CFR
Part 63, Subpart B as described in Section 2.1 of Chapter 2.
Other programs may also meet the regulatory requirements of that
subpart.
3.1 Overview of the MACT Analysis Process
The MACT analysis uses available information to make a MACT
floor finding. There are several possible situations that may
arise in the course of conducting a MACT analysis. First, the
MACT floor could be determined based on emission reductions
currently being achieved by controlled emission units in the
source category. This is known as a positive MACT floor finding.
Other possible outcomes are that the MACT floor can not be
determined, or that the MACT floor equals "no control". It -may
not be possible to calculate a MACT floor due to the nature of
the pollutants emitted from the source, the lack of available
data, or because there are less than five sources in the source
category. A MACT floor could equal "no control" if a substantial
number of sources within the category are not currently
controlling HAP emissions. In either cases, EPA believes that a
more detailed analysis is required in order to determine the
appropriate level of control. Therefore, a negative MACT floor
finding is made.
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Because of the variety of situations that could arise, the
MACT analysis-has been divided into three tiers. Figure 3
diagrams the steps for Tier I, Tier II and Tier III of the
analysis. A MACT floor finding is made during Tier I. Tier II
evaluates all commerically available and demonstrated controls
that could be applied to the emission unit after a negative MACT
floor finding is made. Tier III uses the information developed
in Tier I or Tier II to establish a MACT emission limitation.
Ordinarily, the analysis would begin with Tier I. However,
if an owner or operator agrees to establish the MACT emission
limitation based on the control technology that achieves the
greatest degree of emission reductions, then it would be
necessary to complete only Tier III of the analysis. In such a
•
case, a positive MACT floor finding is assumed because the
emission reductions achieved would meet or exceed the minimimum
level of control required by the floor. If a positive MACT floor
finding is made, it is only necessary to complete Tier I and Tier
III of the MACT analysis. This analysis allows the applicant or
permitting agency to compare the costs, non-air quality health
and environmental impacts and energy requirements associated with
using control technologies that obtain a level of HAP emission
reductions that are equal to or greater than the MACT floor. If
the MACT floor can not be determined or is equal to "no control"
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PROPOSAL
March 1994
(a negative MACT floor finding), the applicant is also required
to complete Tier II of the analysis.
During Tier I, the applicant or the permitting agency will
determine the MACT-affected emission unit, and make a MACT floor
finding for each of these emission units. The applicant or the
permitting agency can make a MACT floor finding by using
available emissions information to determine: (1) if a specific
MACT floor level of control can be calculated; or (2) if there is
a previous case-by-case MACT determination for an emission unit
within that source category. The procedures detailed in
Chapter 4 explain several acceptable methods for determining.a
MACT floor level of control.
If a negative MACT floor finding is made the owner or
operator would move to Tier II of the MACT analysis. The purpose
of Tier II is to identify all commercially available and
demonstrated control technologies using available information,
including work practices, and pollution prevention methods that
could reasonably be applied to the emission unit subject to the
MACT determination. Available control technologies include but
are not limited to: reducing the volume of, or eliminating
emissions of pollutants through process changes, substitution of
materials or other techniques; enclosing systems or processes to
eliminate emissions; collecting, capturing, or treating
pollutants when released from a process, stack, storage or
fugitive emission point; using designs, equipment, work
27
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PROPOSAL
March 1994
practices, or operational standards (including requirements for
operator training or certification); or, a combination of any of
these methods. Strategies for identifying available control
technologies are discussed later in this chapter.
Once a list of available control technologies is developed,
each control technology should be evaluated to consider the
costs, non-air quality health and environment impacts, and energy
requirements associated with using each control technology. The
control technology(s) achieving the maximum degree of HAP
emission reductions taking into consideration the costs of
achieving such emission reductions and the non-air quality health
and environmental impacts and energy requirements should be
selected as MACT. Once MACT has been selected through either
Tier I or Tier II of the analysis, the applicant should move to
Tier III.
In Tier III, a MACT emission limitation (s)* should be
established based on the degree of emission reductions that can
be achieved through the application of the maximum achievable
control technology (MACT); or, a design, equipment, work practice
or operational standard, or combination there of, should be
designated if it is infeasible in the judgement of the permitting
agency to prescribe or enforce a specific MACT emission
limitation based on MACT. The applicant or the permitting agency
should also suggest operating conditions and appropriate
monitoring parameters to make this emission limitation federally
28
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PROPOSAL
March 1994
enforceable.
Once the owner or operator has made a MACT floor finding,
established a MACT emission limitation, and selected a control
technology to meet this limitation, the owner and operator should
apply for a Title V permit, or Notice of MACT Approval in
accordance with the procedures contained in 40 CFR Part 63,
Subpart B and 40 CFR Part 70.
29
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PROPOSAL
March 1994
3.2 A Detailed Look at the MACT Analysis
*
Tier I - Making a MACT floor finding
Step 1 — Identify the MACT-affected emission unit(s) and
relevant source categories
In accordance with the provisions established in 40 CFR Part
63, Subpart B, the owner or operator is required to identify all
emission points increasing emissions due to a proposed
modification of the major source, and all emission points that
will emit HAPs due to construction or reconstruction of the major
source. These "affected emission points" will be grouped into
emission units (MACT-affected emission units). Emission points
may only be grouped into a single emission unit if they are
within the same source category. Therefore, the affected
emission points must assigned to the appropriate source
categories.
On July 16, 1992 the EPA published a notice of source
categories in the Federal Register (57 FR 31576.) This list may
be periodically updated in future Federal Register notices to
reflect changes to this list due to addition or deletion of
source categories. A background information document,
"Documentation for Developing the Initial Source Category List"
EPA-450/3-91-030, is also available to describe the types of
processes in each source category. Both the Federal Register
30
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PROPOSAL
. March 1994
notice and the background information document can be used by the
owner or operator to determine the source category for the major
source. A listing of major sources can be found in Appendix D.
This list should be consider current only to the date of
publication of this guidance manual.
Each emission units that is designated will be subject to a
MACT determination. When a relevant emission standard has been
proposed, the application should designate a MACT-affected
emission unit that is consistent with the existing source
definition, or affected emission points in the proposed emission
standard. When no relevant emission standard has-been proposed,
the MACT-affected emission unit will be determined on a case-by-
case basis. Section 3.3 of this chapter discusses principles for
determining the MACT-affected emission unit on a case-by-case
basis.
Step 2 — Make a MACT floor finding
The owner or operator will need to determine if there is
enough information available about other emission units to
calculate a level of HAP emission control that is equal to the
MACT floor for each type of emission unit undergoing review. For
emission units requiring a new source level of control, the MACT
floor (or best controlled similar source) can be determined using
emissions information on similar emission units from within and
outside of the source category. (Section 3.4 clarifies the term
31
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PROPOSAL
March 1994
similar emission unit.) For modifying emission units, the MACT
floor should be calculated "using only emissions information on
other emission units within the source category. In many cases,
the determination of the level of control achieved by the best
controlled similar source may be less difficult then determining
the existing source level of control. Modifying sources may
chose to apply this level of control and move quickly to Tier III
of the analysis.
The easiest method for determining a specific level of
control equal to the MACT floor is to rely on a MACT
determination that was previously made for a similar emission
unit within the source category. The owner or operator is
referred to any existing Federal, State or local data bases as
well as the public record to determine if a MACT determination
for a similar emission unit has recently been made. This MACT
determination can be used to establish the MACT floor, a MACT
emission limitation, and select a control technology as long as
there is no reason to believe that the MACT floor may have
changed since the effective date of that determination. Reasons
to believe that the MACT floor may have changed would include,
but are not limited to, the passing of a State regulation in a
particular State that specifically regulates that type of
emission unit. And, the close down or start up of a number" of
major sources within the source category.
If no previous MACT determination was made, the owner or
32
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PROPOSAL
March 1994
operator or penniting agency will need to make its own MACT floor
finding. Chapter 4 discusses three ways to establish a MACT
floor: using (1) State and local regulations, (2) control
efficiencies and (3) emission reduction ratios. Use of any of
these methodologies to determine the floor depends on the format
of available information. It is possible that a hybrid of these
approaches may be necessary, or none of the methods may be
appropriate given the format of the available information. These
methods are provided in this guidance document to demonstrate the
types of methodologies that would be appropriate for establishing
a MACT floor.
If the MACT floor can not be determined or if it is equal to
"no control", a negative MACT finding is made. Under these
circumstances the owner or operator should discontinue Tier I of
the analysis and begin with Tier II as later outlined in this
chapter.
Step 4 — Identifying MACT
When a positive MACT floor finding is made, the owner or
operator will need to identify control technologies that reduce
HAP emissions from the MACT-affected emission unit to the maximum
extent and to a level that is at least equal to the MACT floor.
For emission units requiring a new source level of control,
consideration can be given to transfer and innovative
technologies used to control emissions from other emission units
33
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PROPOSAL
March 1994
that may not have met the definition of similar but nevertheless
use technologies that can be applied to the. MACT-affected
emission unit.
The control technology that achieves the maximum degree of
HAP emission reductions with consideration to costs, non-air
quality health and environmental impacts, and energy requirements
is MACT. The Act does not provide direction on the signficance
of one factor to another. EPA believes that it is inappropriate
to provide specific guidance for determining the amount of
consideration that should be given to any one factor. Such
decisions will need to be made based on the information available
at the time of the MACT determination. However, under no
circumstances should the MACT emission limitation be less
stringent than the MACT floor.
In general, a control option that reduces overall HAP
emissions to the greatest extent should be identified as MACT;
however, there may be occasions when the hazard to human health
and the environment from a particular HAP warrants the selection
of a MACT specifically for the control of that HAP.
Identification of more than one control technology may be
necessary when an emission unit has multiple HAP emissions. An
owner or operator is advised to consult with the permitting
agency to determine if this is the case. After this step .is
completed an owner or operator should skip to Tier III of the
analysis.
34
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PROPOSAL
March 1994
Tier II - Considering all control technology
Step 1 — List available control technologies
Using available information, the owner or operator or
permitting agency should develop a list of commercially available
control technologies that have been successfully demonstrated in
practice for similar emission units. Similar emission units are
discussed in more detail in Section 3.4 of this chapter. In
addition, the owner or operator may wish ta consider innovative
technologies and transfer technologies that might reasonably be
applied to the MACT-affected emission unit.
Step 2 — Eliminate technically infeasible control technologies
All control technologies that could not be applied to the
MACT-affected emission unit because of technical infeasibility
should be eliminated from the list. A technology is generally
considered technically infeasible if there are structural,
design, physical or operational constraints that prevent the
application of the control technology to the emission unit. Cost
to install and maintain the control technology is not considered
a factor in determining technical feasibility. An owner or^
operator should be prepared to justify the elimination of a
control technology in the application for avMACT determination.
35
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PROPOSAL
March 1994
Step 3 — Conduct an impacts analysis
The owner or operator or the permitting agency should
conduct a detailed analysis on all of the available control
technologies. The efficiency of each control technology in
reducing overall HAP emissions should be determined. A reviewing
agency may require an owner or operator to select MACT based on
the degree of emission reductions achieved for one or more
specific HAPs when the risk to human health and the environment
warrants establishing MACT emission limitations specifically for
these HAPs. Otherwise, MACT should be selected based on an
overall reduction of all HAP emissions. It should be noted that
the application of more than one control technology may be
necessary in order to address multiple HAP emissions.
After determining the control efficiency of each available
control technology, the owner or operator should identify the
control technology(s) that allows for a maximum degree of HAP
emission reductions with consideration to the costs of achieving-
such emission reductions, and the non-air quality health and
environmental impacts and energy requirements. This is the MACT.
See Chapter 3 of this guidance document for a more detailed
discussion on the analysis of the costs, non-air quality health
and environmental impacts, and energy requirements. •
36
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PROPOSAL
March 1994
Tier III —— Establishing a MACT emission limitation
An owner or operator of a modifying major source can avoid
completing Tier I and Tier II of the MACT analysis or minimize
the degree of analysis required if the MACT emission limitation
is based on a control technology that achieves the greatest
degree of emission reductions or meets the level of control
required for new sources. The owner of operator is referred to
existing EPA control technology guideline documents (CTG) and
background information documents (BID). These documents may help
identify best control strategies for the control of HAPs from a
given type of emission unit. An owner or operator could also
develop a list of available control technologies (similar to that
which would be developed under a Tier II analysis) and establish
a MACT emission limitation based on the control technology that
achieves a maximum reduction in hazardous air pollutant emissions
with consideration to the costs of achieving the emission
reductions, and the non-air quality health and environmental
impacts, and-energy requirements. However, minimal consideration
should be.given to cost in such an analysis.
Step I — Establish a MACT emission limitation (MEL)
The owner or operator should determine the degree of
emission reduction that pan be obtained from the MACT-affected
emission unit, if MACT is applied, and properly operated and
maintained. The MACT emission limitation should be based on an
37
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PROPOSAL
March 1994
.overall reduction of all HAP emissions; however, if possible,
the efficiency of the MACT in reducing each potential HAP
emission should also be stated. The permitting agency will also
have the discretion to establish a MACT emission limitation for
an individual HAP when the risk to human health and the
environment warrants such an emission limitation, or when such a
limitation is necessary to make the overall HAP emission
limitation federally enforceable. If it is not feasible to
establish a specific numerical or efficiency limitation, then a
specific design, process, or control technology should be
designated.
When control efficiencies are used to establish a MACT
floor, the MACT emission limitation (MEL) can be computed by
multiplying the efficiency of MACT by the uncontrolled emission
level (UCEL) of the emission unit as follows:
MEL = UCEL * MACT efficiency
The UCEL for emission units requiring a new or existing
source level of control is the maximum amount of HAP that could
be emitted from the unit under current design specifications and
at full capacity utilization. For existing emission units, the
UCEL could be computed as the amount of HAP that could be emitted
from the unit under design specification used within the past
five years and at full capacity utilization if the source has
used a source reduction method to reduce its total capacity to
38
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PROPOSAL
March 1994
to emit. EPA recognizes that' many major sources are adapting
innovative measures to reduce the source's total capacity to emit
HAPs. By allowing a five year period of time to compute the
uncontrolled emissions, sources can take credit for good control
measures that might otherwise not be recognized in a calculation
of UCEL and controlled emissions.
For example, in 1992, an owner and operator of a major
source used trichloroethylene in a degreasing operation. In
1993, the owner or operator switched to a water-based solvent in
the degreasing operation. In 1994, the owner or operator wishes
to change to use a low-VOC based solvent because the water-based
solvent performed poorly. If a Section 112(g) MACT determination
is conducted for the emission unit, the uncontrolled emission
level would be computed using trichloroethylene in the
calculation. (Although, the owner or operator may be required to
meet a level of emission reductions equal to use of the water-
based solvent if this technology is determined to be MACT.)
Acceptable methbds for computing the UCEL are:
(a) Engineering calculation using material balance or
emission factors;
(b) Actual emission data from the similar emission unit;
(c) Average annual hourly emission rate multiplied by hours
of operation;
(d) Emission limits and test data from EPA documents,
including background information documents;
39
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PROPOSAL
March 1994
(e) Equipment . vendor emission data and guarantees;
(f) State emission inventory questionnaires for comparable
sources ;
(g) Federal or State enforceable permit limits; or,
(h) For equipment leaks use, "Protocols for Generating
Unit-Specific Emission Estimates for Equipment Leaks of
VOC and VHAP," EPA-453/R-93-026.
When an emission reduction ratio (ERR) is used to determine
the MACT. floor, the MACT emission limitation can be computed by
multiplying the uncontrolled emission level by the emission
reduction ratio of MACT using the following formula:
MEL - UCEL * (1 -
See Section 4.4 of this manual for more information on the
emission reduction ratio.
•
Step 2 — Select a control technology to meet the MACT emission
limitation
Once the MACT emission limitation is established, the owner
or operator should- propose a control strategy, that allows the
emission unit to to obtain the required MACT emission limitation
In many cases, this will be through the application of the MACT
40
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PROPOSAL
March 1994
technology. However, in some cases, the emission unit may
already be controlled to a some extent with an existing control
devise. The owner or operator could demonstrate that using
additional control strategies in combination with existing
controls will allow the emission unit to achieve the required
emission reductions. For instance, an emission unit may
currently be controlled with a baghouse. MACT for the emission
unit may be an electric static precipitator. The emission unit
may be able to meet the MACT emission limitation by installing a
series of baghouses in lieu of the electric static precipitator.
The amount of additional control required (ARC) can be computed
by subtracting the MACT emission limitation from the controlled
emission level (GEL) as follows:
ARC = CEL - MEL
The CEL is the maximum amount of HAP that could be emitted
from the unit under current design specification and at full
capacity utilization taking into consideration the application of
federally enforceable controls. Acceptable methods for making
this calculation are:
(a) Engineering calculations using material balance or
emission factors;
(b) Any reported or measured emission that offers a true
representation of yearly emissions;
(c) Average annual hourly emission rate multiplied by hours
41
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PROPOSAL
March 1994
of operation;
(d) Emission limits- and test data from EPA documents,
including background information documents;
(e) Equipment vendor emission data and guarantees;
(f) State emission inventory questionnaires for comparable
sources;
(g) Federal or State enforceable permit limits; or,
(h) For equipment leaks use, "Protocols for Generating
Unit-Specific Emission Estimates for Equipment Leaks of
VOC and VHAP," EPA-450/3-88-010.
If ARC is equal to zero or is a negative number, no
additional control is required. The emission unit is currently
meeting the criteria for MACT. If ARC is a positive number, the
owner or operator must reduce hazardous emissions by this amount.
In some cases, it may only be necessary for the sourde to
establish federal enforceability of existing State requirements
to meet the MEL.
Owners or operators are reminded that the application of a
case-by-case MACT to an emission unit does not exempt that owner
or operator from complying with any future emission standards
affecting that emission unit. The MACT floor emission limitation
as calculated on a case-by-case basis should be considered only a
relative indicator of the future MACT emission standard. Changes
in technology or application of controls to under-controlled
42
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PROPOSAL
March 1994
sources may shift the MACT floor to a higher control level,
-additional emissions information may be- available that generates
a different level of control for the MACT floor, or a control
technology that is more effective in controlling HAP emissions
may be selected based on the relative cost of applying that
technology on a nationwide basis. Owners or operators may wish
to consider these factors when selecting a control technology to
meet the MACT emission limitation.
Step 3 — Establish appropriate monitoring, reporting and
recordkeeping parameters
The owner or operator or the permitting agency should
identify monitoring parameters to assure compliance with the MACT
emission limitation. Section 2.2 of Chapter 2 discusses
•
compliance provisions in greater detail.
Step 4 — Prepare application for a Title V permit or Notice of
MACT Approval
Once a control technology(s) is identified and the MACT
emission limitation(s) is established, the owner or operator
should prepare an application for a Title V permit or Notice of
MACT Approval consistent with the procedures contained in 40 CFR
Part 63, Subpart B.
43
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PROPOSAL
March 1994
3.3 Determining the MACT-affected emission unit
Sections 63.42 and 63.43 of 40 CFR Part 63, Subpart B define
the emission points that are affected by the proposed
construction, reconstruction, or modification of a major source.
For construction or reconstruction of a major source, all new
emission points at the major source are affected. A modifying .
major source may have several affected emission points.
The first type of emission point that could be affected by a
modification is one that will increase actual emissions of a HAP
by greater than de minimis amounts, without being offset. Also,
when a new emission point is added to an existing major source,
and that emission point will have the potential to emit or will
emit greater than de minimis amounts of a HAP, without being
offset, that emission point is also affected by the modification.
A third type of emission point could be affected by a
modification if an owner or operator modifies a major source such
that the sum of emission increases of a HAP from multiple
emission points is greater than de minimis amounts. In this
instance,'all emission points that contribute to the greater than
de minimis increase in emissions of that HAP are affected by that
modification.
For example, an owner or operator modifies an operation such
that vent A will increase emissions of HAP X by 6 tpy; Vent B
will increase emissions of HAP X by 2 tpy; and, Vent C will
increase emissions of HAP X by 0.5 tpy. The de minimis amount
44
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PROPOSAL
March 1994
for HAP X translates to 3 tpy. Vents A, B, and C would all be
affected by the modification because the total increase of HAP X
from the major source is greater than de minimis amounts for that
HAP. Figure 4 illustrates this example.
In another example, an owner or operator of a major source
increases its production capacity, with an associated capital
expenditure. The production material is currently passed through
one of two treatment units. To accommodate the increased
production rate the owner or operator proposes to add a third
treatment unit. At any given time, only two of the treatment
units will be used while the third is off-line for maintenance.
The emission increase from the physical or operation change
occurs from each of the emission points depending on which are in
operation. In this situation, all three emission points
contribute to greater than de minimis increases and would all be
affected by the modification.
A final example can be1 explained with a wastewater
conveyance system. An owner or operator adds a spray coating
booth to an existing coating operation. This change also
requires additional drains to be added to the wastewater
conveyance system. The additional paint load to the wastewater
will cause an emission increase in not only the additional drain
but all existing drains. Controlling the drains may prevent or
45
-------
March 1994
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March 1994
reduce emissions from these affected points, but in doing so it
causes the emission release to occur further downstream. These
downstream emission points may contribute to greater than de
minimis increases. (See Figure 5.) The owner or operator would
be required to select a control technology for MACT that would
remove the HAP from the stream before it proceeds downstream, or
the downstream emission points that would increase in emissions
will be affected by the modification. If the owner or operator
had not added a spray booth, but had simply added a drain to the
existing water conveyance system, the owner or operator would
only be required to control that drain, (if it contributes to an
above de minimis increase.) There would not be an increase in
the HAP loading to the water conveyance system. Therefore, the
downstream emission points would not be affected, because the
emission potential of the downstream emission points would not
change with the addition of the drain.
A fifth type of emission point can be affected by a
modification at an owner or operator's discretion. The option
may be preferred when controlling emissions from multiple
emission points obtains a greater degree of emission control than
could be achieved by applying control technologies to a single
affected emission point within the process unit. When making
case-by-case MACT determinations, EPA would like to focus on
pollution prevention, recycle and reuse control strategies. By
allowing an.owner or operator to combine affected emission points
47
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March 1994
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PROPOSAL
March 1994
with other points within a process unit, an overall greater HAP
emission reduction from the major source can be achieved. This
is especially true when a major source constructs or
reconstructs. Combining emission points into one affected
emission unit could be a much more cost-effective method of
control than point-by-point compliance.
For example, a major source in the surface coating of light
duty auto trucks source category proposes to add a drying oven to
the paint coating operation to accommodate an increased
production rate. HAP emissions from the major source will have
greater than de minimis increases for a HAP due to this
modification. After reviewing existing databases, the owner or
operator determines that an incinerator operated at a 98%
efficiency meets the emission limitation required by the MACT
floor. Instead of installing an incinerator, the owner or
operator could control emission points from the spray booth and
bake oven through the use of water-based paints. In this
situation, it would be appropriate for the owner or operator to
include the emission points from the booth as affected emission
points.
Likewise, suppose a waste treatment operation modifies by
adding an aerobic degradation tank. If the focus of the MACT
determination were limited to the tank, some type of
covering/venting system may be required. However, if other
emission points such as those associated with flocculation or
49
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PROPOSAL
• March 1994
neutralization are combined with the emission points associated
with the aerobic degradation tank, a steam stripper could be
added to reduce the overall volatile organic content of the
operation and provide for an even greater reduction in HAP
emissions from the emission unit. Again, the owner or operator
could opt to have these emission points affected by the
modification. Figure 6 illustrates this example.
Once all the affected emission points are identified, they
need to be group into MACT-affected emission units. A MACT
affected emission unit could be combrised of either a single
affected emission point, or a combination of affected emission
points. Each MACT-affected emission unit will require a MACT
determination to establish the appropriate emission limitation.
There are four basic principles to follow when designating
the MACT-affected emission unit. The principles can be
summarized as. follows: 1} When a relevant Section 112(d) or
Section 112(h) standard has been proposed, the owner or operator
and the. permitting agency should refer to the relevant standard
to determine the MACT-affected emission unit; or, (2) When a
source category on the source category list is designated as a
specific piece of equipment, the MACT-affected emission unit is
that piece of equipment or apparatus; or, (3) The EPA's Office
of Air Quality Planning and Standard's should be consulted to
determine if a suggested method for grouping of affected emission
50
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PROPOSAL
March 1994
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PROPOSAL
March 1994
points is available; or, (4) Emission points should be combined
into a single MACT-affected emission unit when the combination of
points leads to a much more cost-effective method of control, and
achieves a greater degree of emission reductions when compared to
point-by-point compliance.
The best indicator of how a source category may be regulated
after the promulgation of a relevant -standard is found in a
proposed standard. For this reason, EPA believes that owners or
operators and permitting agencies should follow the guidelines in
the proposed standard for determining the MACT-affected emission
unit for a Section 112(g) MACT determination. Although there may
be no proposed standard for the source category, information on
the source category may have been collected which allows EPA to
recommend a specific method for determining the emission unit for
a Section 112(g) MACT determination. Therefore, EPA should be
consulted before attempts are made to define the MACT-affected
emission unit on a case-by-case basis. EPA can be contacted
through the Control Technology Center Hotline operated by the
Office of Air Quality Planning and Standards at (919)-541-0800.
When an affected emission point(s) is associated with a
piece of equipment or apparatus specifically listed on the source
category list, that affected emission point(s) is the MACT-
affected emission unit. The source category list (See Appendix
D) contains sources that are defined by a manufacturing or
process operation, or as an individual piece of equipment. In
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developing the source category list, EPA determined that some
individual pieces of equipment have the potential to emit major
amounts. For example, under the fuel combustion industrial
grouping, stationary internal combustion engines are listed as a
source category of major sources. When a source category is
designated by a single type of apparatus, the EPA believes that
the intent is for emission limitations and requirements to be
placed on that specific piece of equipment. As such, if a
Section 112(g) determination is conducted for any piece of
equipment from one of these source categories, the specific piece
of equipment or apparatus should be designated as the MACT-
affected emission unit. Other examples of apparatus that are
listed as a source category of major sources are municipal waste
incinerators, process heaters, and stationary turbines. The
owner or operator should review the list found in Appendix D to
determine other source categories that could be defined as the
MACT-affected emission unit.
Otherwise, individual affected emission point can be
considered a MACT-affected emission unit, or a group of affected
emission points can be combined into one affected emission unit.
There are several ways in which emission points could be combined
to form an emission unit. A few points could be combined, an
entire process unit could be included in the MACT-affected
emission unit, or the MACT-affected emission unit could be as
large as the source category.
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For example, a single emission point such as a storage tank
could be consider the MACT-affected emission unit. Or, emission
points from a distillation column, a condenser and distillate
receiver could be consolidated into one emission unit. Larger
groupings of emission points maybe appropriate when a single
control technology can be used to control the aggregation or when
a pollution prevention or waste reduction strategy is considered.
For instance, affected emission points from the entire wastewater
treatment operation could be considered one emission unit. As
explained in an earlier example, collectively, a single steam-
stripper could be used at the beginning of the operation to
remove HAPs from the wastewater and prevent downstream emissions
from occurring, or a process modification such as' changing the
paint can reduce emissions throughout the process.
Another reason to combine affected emission points into a
single emission unit is that many major sources are already
subject to regulation under 40 CFR Part 60 and Part 61. In
promulgating these standards, "affected facility" definitions
were developed to designate the apparatus to which a standard
applies. It may make sense to use these same designation for the
"MACT-affected emission unit". It should be noted that a
particular piece of apparatus or equipment should not be excluded
from a MACT determination because of an applicability "cut-off"
established under a Part 60 or Part 61 regulation.
Emission points could be consolidated into an. emission unit
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that is as large as the source category boundary for several
reasons. First, the MACT floor needs to be calculated
specifically for the MACT-affected emission unit. The
information that is available to calculate the MACT floor may
only be available for the source category as a whole, not
individual points within the category. Also, the operations
within some-source categories are quite variable. Either the
nature of the process requires a large latitude of flexibility in
establishing the emission unit that should be controlled, or the
types of facilities within the category are so diverse that it
only makes sense to compare the existing sources on a source
category wide level. In these instances, a source category wide
MACT-affected emission unit could allow some emission points to
be under controlled while others are controlled to a level that
would exceed the level of control that would be placed on that
individual point• through the application of MACT. Permitting
agencies are cautioned that it would be generally inappropriate
to include emission points associated with equipment leak
emissions into such a MACT-affected emission unit.
There are some situations which would not make the
combination of emission points reasonable. First, the combined
emission unit can not generate an emission unit that is so unique
that it precludes comparing the emission unit to other sources in
the source category. Second, the combining of emission points
should reduce emissions from all of the affected emission points
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within the MACT-affected emission unit through use of a control
technology that affects all of those emission point, or involves
recycling or reuse, or constitutes an overall source reduction
strategy as defined in the Pollution Prevention Act, P.L. 101-
503. The types of activities that would be considered pollution
prevention or source reduction measures include changes in
technology, process or procedures, reformulation or redesign of
products, and substitution of raw materials. A decrease in
production rate alone would not constitute a source reduction
strategy unless the rate reduction was associated with a
pollution prevention measure such as increasing efficiency of the
operation.
Determining the MACT-affected emission unit on a case-by-
case basis is a complex undertaken. While this document includes
this step as a separate component of the Tier I approach, in
actual practice the identification of methods to control specific
groups of emission units will be an integrated process with the
identification of control technology options. Some aggregations
of emission points may be inappropriate because the information
available to calculate the MACT floor would dictate combining
emission points into certain emission units, or because controls
applied to the unit would not achieve a MACT level of control
when compared to point-by-point compliance or some other
combination of emission units.
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3.4 Similar Emission Units
There are at least two occassions in which an applicant is
required to evaluate control technologies used by emission units
in other source categories: (1) When a MACT floor can not be
determined for existing emission units during Tier I of the MACT
analysis; and, (2) When an owner or operator is constructing or
reconstructing an emission unit. Whether control technologies
from other sources categories should be considered in the MACT
analysis depends on whether the emission unit is "similar". Two
questions should be answered to determine if an emission unit is
similar: 1) Do the two emission units have similar emission
types, and 2) Can the emission units be controlled with the same
type of control technology. If the two emission units do have
similar emission types and are controllable with the same control
technologies then the two emission units are considered similar
for the purposes of a case-by-case MACT determination under
Section 112(g).
The EPA developed an emission classification system to be
used for determining emission types for case-by-'case MACT
determination. The five emission classifications are as follows:
Process vent or stack discharges - the direct or indirect
discharge of an organic liquid, gas, fume, or particulate by
mechanical or process-related means. Examples would be
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emission discharges from columns and receiving tanks from
distillation, fractionation, thin-film evaporation, solvent
extraction, air and steam stripping operations, absorbers,
condensers, incinerators, flares, and closed-looped
biological treatment units.
Equipment leaks - fugitive emissions from the following
types of equipment: valves, pumps, compressors, pressure
relief devices, sampling connection systems, open-ended
valves and lines, flanges, agitators, sampling connection
systems, and valve connectors.
Evaporation and breathing losses - emissions from storage or
accumulation of product or waste material; for example:
stationary and mobile tanks, containers, landfills, and
surface impoundments, and pilings of material or waste. .
Transfer losses - emission of an organic liquid, gas, fume,
vapor or particulate resulting from the agitation of
material during transfer of the material from one unit to
another. Examples of such activities are filling of mobile
tanks, dumping of coke into coke quench cars, transfer of
coal from bunker into larry car, emptying of baghouse
hoppers, and sludge transfer.
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Operational losses - emissions resulting from the process
* ,
operation which would result .in fugitive emissions if
uncontrolled by hoods or vacuum vent, or other vent systems,
Examples of operation loses are emission resulting from
spray coating booths, dip-coating tanks, quenching towers,
lubricating stations, flash-off areas, or grinding and
crushing operations.
The classification scheme has been developed to serve as a
general guide in identifying available control options. When
using the list of classifications, consideration should be given
to the concentration and the type of constituents of a gas
stream. While two pieces of apparatus are classified within the
same emission type, this dpes not automatically mean that the
emission points can be controlled using the same type of control
technology. For instances, storage tanks and landfills are both
listed in the evaporation and breathing losses classification,
but it is unlikely that a storage tank and landfill would be
controlled with the same technology. In order for an emission
unit to be considered similar it must fit both criteria: have a
similar emission type and be controllable with the same
technology.
For example, suppose a major source within the captan
production source category (a source listed on the source
category list in Appendix D,) proposes to modify by adding
\
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additional product accumulation vessels (tanks) and additional
» .
pipes, pumps, flanges and valves to direct the product to the
tanks. After reviewing a database during Tier I of the MACT
analysis, the owner or operator determines that there are no
regulations controlling HAP emissions from pumps within the
source category. And, there is not enough emission information
available on other emission units within the source category to
•calculate a MACT floor. During Tier II of the analysis, the
owner or operator discovers that the Synthetic Organic Chemical
Manufacturing Industry (SOCMI) source category is currently
subject to regulations controlling equipment leaks. Because the
pipes, pumps, and flanges all have equipment leak emissions, the
emission units in the SOCMI source category would be considered
similar emission units. And, the regulations for SOCMI equipment
leaks should be considered for the control of the MACT-affected
emission unit during Tier II of the analysis. When determining
the existing source level of control, identification of a similar
emission unit does not mean that the controls will automatically
be applied to the MACT-affected emission unit. Costs, non-air
quality health and environmental impacts, and energy requirements
should be used to assess the technologies ability to meet MACT
criteria.
Now, suppose that this same change to the major source is
considered construction of a major source rather than a
modification. After reviewing available information, the owner
i
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or operator determines that the best controlled tank within a
source category does not have state-of-the-art controls. Yet,
tanks from outside the source category storing similar organic
liquids use state-of-the-art controls vented to an emission
control device. Such tanks are clearly "similar". The controls
these tanks would be considered in establishing the best
controlled similar source.
It is not always appropriate to consider all transferrable
technologies when determining the best controlled similar source.
It would be inappropriate to consider a transfer technology when
the emission units have different emission types. For example,
within source category X, spray booths tend to be uncontrolled
due to gas streams with low concentrations and relatively high
airflows. Source category Y uses incineration to control
emissions from spray boothes with high concentrations and low
airflow volumes. The emissions from these sources are clearly
not similar, and controls for category Y would not be used to
determine the best controlled.similar source for category X.
However, if it is technologically feasible to apply the controls,
these same controls could be considered to establish a new source
level of control beyond the best controlled similar source, if
consideration is given to cost, non-air quality health and
environmental impacts, and energy requirements.
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3.5 Subcategorization
When the source category list was developed, sources with
' some common features were grouped together to form a "category".
During the standard-setting process, EPA may find it appropriate
to combine several categories or further divide a category to
distinguish among classes, types, and sizes of sources. EPA
chose to establish broad source categories at the time the source
category list was developed because there was too little
information to anticipate specific groupings of similar sources
that are appropriate for defining MACT floors for the purpose of
establishing emission standards.
The broad nature of some source category descriptions may
pose some difficulty in establishing an appropriate MACT emission
limitation for a MACT-affect emission unit on a case-by-case
basis. Subcategorization within a source category for the
purposes of a case.-by-case MACT determination should be
considered only when there is enough evidence to clearly
demonstrate that there are air pollution control engineering
differences. Criteria to consider include process operations
(including differences between batch and continuous operations),
emissions characteristics, control device applicability and
costs, safety, and opportunities for pollution prevention.
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Chapter 4.0
m t
The MACT Floor Finding
During Tier I of the MACT analysis, an owner or operator or
the permitting agency is required to make a positive or negative
MACT floor finding. A positive finding would be made if there is
enough information to determine a emission control level that is
at least equal to the MACT floor. A negative MACT floor finding
would be made if: (1) the MACT floor equals "no control"; (2) a
\
MACT floor can not be determined due to the nature of the
pollutant or process; or, (3) there is not enough emissions
information to compute a MACT floor.
The EPA recognizes that computing the MACT floor for a MACT-
affected emission unit may be time consuming and burdensome for
the owner or operator or the permitting agency. To avoid
calculating a specific emission control level that equals the
MACT floor, the applicant can propose to meet the greatest degree
of emission control. This control level will meet or exceed the
level of emission 'reduction required by a MACT floor finding,
therefore, a positive MACT floor finding is assumed.
Owners or operators and the permitting agency should refer
to existing EPA control technology guidelines (CTG), background
information documents (BID,) existing New Source Performance
Standards (40 CFR Part 60,) or existing National Emission
Standards for Hazardous Air Pollutants (40 CFR Part 61) to
identify control strategies that obtain the greatest degree of
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emission reductions for-a given MACT-affected emission unit. The
• ,
greatest level of contro.l can also be established by conducting a
costs, the non-air quality health and environmental impacts, and
energy requirements analysis on all commercially-available and
demonstrated control technologies. Minimal consideration should
be given to cost impact in such an analysis. If the new source
level of control is known for an emission unit, a modifying major
source may opt to meet this level of control in lieu of making a
specific MACT floor finding.
An owner or operator could also avoid calculating a specific
MACT-floor by referring to existing databases to document whether
a MACT determination for another similar emission unit in the
source category has recently been made. This MACT determination
could be used to establish the MACT floor for the MACT-affected
emission unit provided there is no reason to believe that the
control technology no longer represents MACT. This was
previously discussed in Section 3;1.
Because the above methods will not always clearly identify a
control technology or emission limitation that meets the MACT
floor, an owner or operator or the permitting agency may be.
required to review existing emissions information to make a
specific MACT floor finding. Section 4.1 of this chapter
discusses the calculation procedure for, determining an "average
emission limitation". This procedure establishes a hierarchical
system for determining the average emission limitation using the
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arithmetic mean, median or mode.
Using the calculation procedures discussed in Section 4.1,
the EPA has established three acceptable methods for determining
a MACT floor. If the emissions information is available, all
three methods should be considered before the owner or operator
concludes that a MACT floor can not be found. The three methods
include using: (1) existing State and local air toxic control
regulations; (2) control efficiency ratings; or (3) emission
reduction ratios. Each of these methods is discussed in greater
detail later in this Chapter.
The first method compares air pollution regulations in
different States. This method is likely to require the least
amount of data search and analysis. The second and third methods
base the MACT floor on a level of emission reductions, allowing
the MACT-affected emission unit more flexibility in determining
control technologies to meet the MACT floor. The second method
is applicable only when the control technologies under
consideration can be assigned an efficiency rating for HAP
emission reductions. This is most-likely to occur with add-on
control devises. The third method can be used for add-on control
devises, work practices, recycling, reuse or pollution prevention
strategies. Depending on the format of available information, a
hybrid of the three approaches may be necessary.
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4.1 Calculation of the MACT Floor
Section 112(d) of the Act instructs EPA to set emission
standards for new sources based on the emissions control achieved
in practice by the best controlled similar source and to set
emission standards for existing sources based on an average
emission limitation achieved by the best performing 12% of
existing sources or best performing five sources in the source
category. For new sources the direction provided by the Act is
relatively clear. For existing sources, further clarification is
required by EPA to determine how an average emission limitation
should be computed.
The word average can have several different meanings,
including arithmetic mean, median and mode. EPA has developed
•
the following hierarchy for determining the average emission
limitation that is equal to the MACT floor. First, if the
emissions data that is to be used to calculate the floor is in
the form of a numerical expression, (i.e. 95% reduction), the
MACT floor should be determined by taking the arithmetic mean of
the best performing 12% of existing sources or the best
performing five sources. An arithmetic mean is calculated by
summing all of the data and dividing by the number of data
elements in the calculation. The following example illustrates
this concept:
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Example 1
The following emission limitations are representative of the
best performing 12% of existing source:
% reduction
99 Average emission limitation =
99
95 656/7 = 93.7%
93
92
• 89
89
Total 656
# of sources = 7
Under some circumstances the arithmetic mean results in a
number that may not correspond to the application of a specific
control technology. For instance suppose the arithmetic mean of
emission limitations of the best performing 12% of exist sources
is equal to 92.3%. Application of control Technology X would
provide a source 91% control, while application of Technology Z
would limit the source's emissions by 96%. . In most cases, when
the arithmetic mean can not be specifically achieved by the
application of a control technology, the MACT floor should be
elevated to the level of control associated with the control
technology that exceeds the MACT floor. In Example 1, the MACT
emission limitation should be no less stringent than 95% control.
This concept would not make sense if there is a large discrepancy
between the amount of emission reductions that can be achieved by
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available control options. This is illustrated with the
following example:
Example 2
An arithmetic mean is computed for the best performing
12% of storage tanks. There are 10 sources among the best
performing 12% of storage tanks. Two tanks are controlled
by 99%, the remaining 8 tanks are not controlled. The
emissions limitations considered in the floor calculation
are:
% reduction
99
99 average emission limitation =
0
0 ' 19.8% reduction
0
0
0
0
0
0
Total 198
# of sources = 10
In this example, no technology corresponds to 19.8% control, and
«•
it might be inappropriate to elevate the MACT floor to 99%
control.
If there is a large discrepancy between the amount of
emission reductions that can be achieved by available control
options, the median should be used in lieu of the arithmetic mean
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to determine the average emission limitation equal to the MACT
floor. A median is the value that falls in the- middle of a set
of numbers when those numbers are arranged in an increasing order
of magnitude; in other words, there will be an equal number of
values above and below the median. If the middle falls between
two values, the median is equal to the arithmetic mean of those
two numbers. This situation will occur when there is an even
number of values in the set of numbers. When computing the
average emission limitation for the best performing 12% of
existing sources, the median will always be equal to the lowest
emission limitation achieved by the best 6% of sources in the
source category. For example:
•
Example 3
There are 84 sources in the source category.. The
number of sources in the best performing 12% of source is
equal to 10. The median is to be computed for the following
emissions data:
% reduction
24
26 There are a total of 10 numbers
30 the median would be the arithmetic
30 mean of the 5th and 6th numbers
33 in the column.
40
56 median = (33 + 40)/2 = 36.5
88
93
99
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,...., , .'.,.,. . March 1994
Like the computation of the arithmetic mean, the value
obtained for the median may not always correspond to a specific
control technology. If there is a control technology that
obtains slightly greater emission reduction than the median, the
MACT floor should be based on that control technology. For
instances, in Example 3, the MACT floor would be equal to 40%
emission reductions. This value coincides with the lowest
emission limitation achieved by the best performing 6% of
sources. However, if there is a large discrepancy between the
control technologies used to establish a median such that no
technology could realistic obtain a reduction close to the
median, the mode should be used to calculate the MACT floor.
A mode is the most frequent occurrence among a set of data.
In Example 1, there are two modes, 99% and 89% emission
reductions. In Example 2, the mode would be equal to 0% emission
reductions; and the mode in Example 3 would be 30. When there is
more than one mode in the data set, the MACT floor should be
based on the least degree of emission control. However,
• existence of more than one mode may be an indicator that the MACT
floor should be established at a level of control more stringent
than the MACT floor.
The mode may also be used as a method to compute an average
emission limitation if the emissions data for a source category
is not based on a numerical number. This could occur if sources
were regulated by several different equipment or work practice
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standards. Unless a specific level of emission reduction can be
associated with each different standard or unless the standards
can be ranked in some order of increasing level of control, an
arithmetic mean and median can not be calculated. A mode could
be used if one of the control options was used more frequently by
one of the best performing 12% of existing sources. For example:
Example 4
There are 44 tanks in the source category. Five sources are
among the best performing 12% of existing sources. These
five tanks are subject to the following regulations in the
source category:
3 of the 5 must be covered and vented to a carbon
canister;
2 of the 5 must use a fixed roof
The mode would be to cover and vent the tank to a carbon
canister.
The following sections of this chapter detail the three
acceptable methods for computing a MACT floor. It should be
noted that when the best controlled similar source is being
determined for constructing or reconstructing major sources/ all
references to using emissions information from within the source
category should be ignored. Identifying the MACT floor for
constructing and reconstructing major sources requires that the
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emission information used to determine the best controlled
w
similar source not be limited to within the source category.
Readers are referred to Section 3.4 of this chapter for a
definition of similar emission unit.
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4.2 Method 1 - Computing the MACT Floor Using Existing State and
Local Regulations '
The steps for computing a MACT floor using this method are
listed in Figure 7. The following describes these steps.
Step (A) Conduct a geographical survey
Determine the number of existing similar emission units in
the source category, and conduct a survey to determine the
geographical location of these similar emission units. Group the
emission units according to the state or locality in which they
are located.
Step (B) Review State or local air pollution regulations
Review the different State or local air pollution control
•
regulations that are applicable to the emission unit in each
State or locality where an emission unit is located.
Step (C) Rank the State or local air pollution regulations
For the State and local regulations identified in Step B,
rank the regulations in order of stringency. The regulations
that require the greatest level of control should be listed
first.
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Figure 7
Using State or Local
Air Pollution Regulations
to Compute the MACT Floor
Step A Conduct a Geographical Survey
Step B Review State and Local Air Pollution Regulations
Step C Rank the Regulations according to Stringency
Step D Determine the Percentage of Emission Units Complying with
each Stringency Level
Step E Determine MACT Floor
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Step (D) Determine the number of emission units regulated by
each stringency level.
For each level of stringency identified in Step (C) , a
percentage of emission units required to comply with the
regulations should be computed.
Step (B) Make a MACT floor finding
For constructing or reconstructing major sources, the MACT
floor will equal the most stringent State or local regulation
applying to a similar emission unit. For a modified major
source, the MACT floor will either be equal to the arithmetic
mean of the best 12% of existing emission units in the source
category, or the best 5 existing emission units in the source
category. If the arithmetic mean can not be calculated, the
median or mode should be used to compute the MACT floor for
existing sources.
Figure 8 illustrates the following example of this concept:
In Step (A), the owner or operator determines that there are 42
similar emission units in the MACT-affected emission unit's
source category. Sixteen of the sources are located in State A,
five in State B, three in State C, and 18 in State D. A specific
numerical value can not be determined for all of these
regulations, but it is possible to list the regulations in order
of stringency. Upon reviewing the regulations in these four
States, it is determined that States A and B have the most
75
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Figure 8
Evaluation of State Regulations
for Emission Unit X
STATE
A
B
C
D
TOTAL
STRINGENCY*
1
1
2
3
# OF SOURCES
16
5
3
18
42
Total # of emission units
# of emission units within the top
6% of existing emission units
Stringency level top 6 emission
units must comply with
MACT floor
42
=3 (42 * 0.06)
= 1
regulations
in State A or B
* Stringency is rated 'from the most stringent State regulation
beginning at 1 and increasing in number as the regulation is
rated less stringent.
76.
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stringent regulations for this source; and, they are equally
stringent. These State regulations are followed in stringency by
State C. State D is the least stringent state; there are no
regulations and the sources are uncontrolled.
State A and B regulate 50% of the sources. Using the median
to compute the MACT floor, the MACT floor would be equal to the
least stringent regulations governing the most strictly regulated
3 sources (42 * 0.06 rounded to the next largest whole number.)
In this case, the MACT floor would be equal to either State A or
State B's regulations.
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4.3 Method 2 ~ Computing the MACT Floor using Control
Efficiency Ratings .-..-.
To use this method to calculated the MACT floor, the owner
or operator will evaluate emission units that use add-on control
devices or other methods whose HAP control efficiencies have been
clearly demonstrated. The MACT floor and MACT emission
limitation can be computed as follows:
Step (A) Determine HAP emission reduction efficiency for each
control device.
For each emission unit in the source category, the
ability of each control technology to reduce HAP emissions should
be determined as a percentage of reduction efficiency. For
constructing and reconstructing emission units, the reduction
efficiency should be computed for all similar emission units.
Acceptable methods for determining the efficiency rating are:
1) Equipment vendor emission data and guarantees;
2) Federal and State enforceable permits limits on
operation of the control technology;
3) Actual reported efficiency from the similar emission
unit.
Step (B) Calculate the MACT floor
For constructing and reconstructing emission units, the MACT
floor equals the level of emission reductions that can be
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obtained by the control technology with the highest emission
control rating. For existing emission units, the MACT floor
equals the arithmetic mean of the best five or the best
performing 12% of control efficiency ratings. Or, if the median
is used the MACT floor equals the lowest control efficiency
rating achieved by the best 6% of sources if there are greater
than 30 sources in the source category; or, the MACT floor equals
the lowest control efficiency rating among the best 3 sources if
there are less than 30 sources in the source category. Under
most circumstances, it should not be necessary to use the mode to
compute an average emission limitation; however, if it is used,
the MACT floor would be equal to the most frequent control
efficiency rating among the best performing 12% of existing
sources or the best performing five sources.
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4.4 Method 3 - Computing the MACT floor Using Emissions
Reduction Ratios (ERR)
The emission reduction ratio is a fraction of uncontrolled
emissions to controlled emissions. The MACT floor is computed
using the emission reduction ratios. To compute the emission
reduction ratio for each emission unit, the owner or operator
must review emissions data or other information to determine
uncontrolled and controlled emissions levels for these units.
The step-by-step process is detailed below and summarized in
Figure 9.
/
Step (A) Compute an uncontrolled emission level (UCELr) for each
emission unit
For modifying sources an UCEL should be computed for each
emission unit in the source category. For constructing and
reconstructing sources, a UCEL should be computed for each
similar source. The UCEL for an emission units is the amount of
HAP that could be emitted from the unit under current design
specification at full capacity utilization.
Acceptable methods for computing the UCEL are:
(a) Engineering calculation using material balance or
emission factors;
(b) Actual emission data from the similar emission unit;
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(c) Average annual hourly emission rate multiplied by hours
"Of operation;
(d) Emission limits and test data from EPA documents,
including background information documents;
(e) Equipment vendor emission data and guarantees;
(f) State emission inventory questionnaires for comparable
sources;
(g) Federal or State enforceable permit limits; or,
(h) For equipment leaks use, "Protocols for Generating
Unit-Specific Emission Estimates for Equipment Leaks of
VOC and VHAP," EPA-453/R-93-026.
See Section 3.2 for a more detailed discussion of UCEL and its
use.
Step (B) Compute a controlled emission level (GEL) for each
emission unit
The CEL is the maximum amount of HAP that could be emitted
from the unit under current design specification and at at full
capacity utilization taking into consideration the application of
federally enforceable controls. Acceptable methods for making
this calculation are:
(a) Engineering calculations using material balance or
emission.factors;
(b) Any reported or measured emission that offers a true
representation of yearly emissions;
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Figure 9
Using Emission Reduction Ratios
to Compute the MACT Floor
Step A Compute an Uncontrolled Emission Level (UCEL) for each
emission unit.
Step B Compute a Controlled Emission Level (CEL) for each emission
unit.
Step C Compute an Emission Reduction Ratio (ERR) for each emission
unit.
ERR = UCEL - CEL
UCEL
Step D Determine the MACT Floor.
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(c) Average annual hourly emission_rate multiplied by hours
of operation;
(d) Emission limits and test data from EPA documents,
including background information documents;
(e) Equipment vendor emission data and guarantees;
(f) State emission inventory questionnaires for comparable
sources;
(g) Federal or State enforceable permit limits; or,
(h) For equipment leaks use, "Protocols for Generating
Unit-Specific Emission Estimates for Equipment Leaks of
VOC and VHAP," EPA-450/3-88-010.
Step (C) Compute the emission reduction ratio (ERR) for each
emission unit:
ERR - UCEL - CEL
UCEL
Step (D) Determine the MACT floor.
For construcing and reconstructing sources the MACT floor
would be equivalent to the highest ERR. For existing sources,
the MACT floor equals the arithmetic mean of the best five or
best 12% of ERRs. If the median is used, the MACT floor equals
the lowest ERR among the best 6% of ERRs or the best three ERRs
depending on the number of sources in the source category. If
the mode is used, the MACT floor equals the most frequently
*
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occurring ERR among the best performing 12% of sources or best 5
sources depending on the number of sources in the source
category.
For example, suppose a major source determined that there
are four emission units in the top 12% of existing emission units
for the source category. These four emission units had emission
reduction ratios of 0.90, 0.92, 0.93, and 0.99. The control
technologies used by these best performing 12% of similar source
are a wet scrubber, a solvent change, a condenser, and an
incinerator. The arithmetic mean for these values equals 0.935.
If this value does not correspond to the application of a
specific control technology, the MACT floor would be equal to an
emission reduction ratio of 0.99. If it is determined that
elevation of the MACT floor to this level is infeasible, then the
median should be computed for these sources. The median would be
equal to best performing 6% of sources or the lowest of the
highest two emission reduction ratios. This is equal to 0.93.
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4.5 Exceptions Emission Reduction Ratios
In most circumstances the emission reduction ratio, is a
reliable method for calculating the MACT floor. However, there
are some circumstances when a very low emission reduction ratio
could be computed for a well-controlled emission unit. This may
occur if pollution prevention strategies are used for greater
than five years at the major source, or a process has an
inherently low potential to emit hazardous air pollutants. The
owner or operator could be reducing emissions to the maximum
extent possible without being able to credit the pollution
prevention strategy in computing the uncontrolled emissions. The
uncontrolled and controlled emission rate could be nearly the
same, causing the emission reduction ratio to be a very low
number. A reviewing agency should keep such situations in mind
when making a MACT determination. In such instances, the
pollution prevention method should not be eliminated as a
candidate to meet the MACT floor.
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4.6 Other Methods to Compute the MACT Floor
As future MACT standards are proposed or promulgated for
different source categories, more methods for determining the
MACT floor could be developed. The reader is referred to the
Federal Register to locate any other methods for calculating the
MACT floor that have been approved by the EPA and used in
developing a MACT standard under Section 112(d) or 112(h) of the
Act.
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Chapter 5
»
Costs/ Non-air Health
and Environmental Impacts,
and Energy Requirements
Section 112(d) of the Act specifies that if control
technology alternatives are being considered to establish an
emission standard that would result in emission limitations more
stringent than the emission "floor"; or, if insufficient data
exists to specify an emission limitation based on the MACT floor,
then control technology alternatives must be evaluated by
considering costs, non-air quality health and environmental
impacts, and energy requirements associated with the expected
emission reductions.
The costs, non-air quality health and environmental impacts,
and energy requirements discussed below, are illustrative only and
not intended as an exclusive list of considerations for MACT
determinations. Some of these factors may not be appropriate in
all cases, while in other instances, factors that are not
included here may be relevant to the MACT determination. The
discussion does not address the evaluation of each factor nor the
weighing of any factor relative to another. Such determinations
should be made on a case-by-case basis by the owner/operator and
permitting agency. For the purpose of this discussion, terms
sush as "emission control system" or "MACT system" refer to
design, equipment, or operating standards and inherently less
v
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polluting processes, as well as add-on control equipment.
» ,
In general, the impact analyses for MACT determinations
should address the direct impacts of alternative control systems.
Indirect energy or environmental impacts are usually difficult to
assess, but may be considered when such impacts are found to be
significant and quantifiable. Indirect energy impacts include
such impacts as energy to produce raw materials for construction
of control equipment, increased use of imported oil, or increased
fuel use in the utility grid. Indirect environmental impacts
include such considerations as pollution at an off-site
manufacturing facility which produces materials needed to
construct or operate a proposed control system. Indirect impacts
generally will not be considered in the MACT analysis since the
complexity of consumption and production patterns in the economy
makes those impacts difficult to quantify. For example, since
manufacturers purchase capital equipment and supplies from many
suppliers, who in turn purchase goods from other suppliers,
accurate assessment of indirect impacts may not be possible. Raw
materials may be needed to operate control equipment, and
suppliers of these resources may change over time. . Similarly, it .
is usually not possible to determine.specific power stations and
fuel sources which would be used to satisfy demand over the
lifetime of a control device.
In most cases, duplicative analyses are not required in
preparing the MACT impact analyses. Any studies previously
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performed for Environmental Impact Statements, water pollution
permits, or other programs may be used when appropriate;
however, the permitting agency may consider any special economic
or physical constraints which might limit the application of
certain control techniques to an existing emission unit, such as
retro-fitting costs that would not be borne by a new unit, or the
remaining useful life of the emission unit. The result may be
that the level of control required for an existing emissions unit
may not be as stringent as that which would be required if the
same unit were being newly constructed at an existing plant- or at
a "greenfield" facility. However, in no event shall the level of
control yield an emission limit less stringent than the MACT
floor when information is available to compute the MACT floor.
5.1 Cost Impacts
Cost impacts are the costs associated with installing
operating, and maintaining alternative emission contro.l systems
(add-on emission control devices or process changes.) Normally,
the submittal of very detailed and comprehensive cost data is not
necessary. Presentation of the quantified costs of various
emission control systems (referred to as control costs,) coupled
with quantities of HAP emission reductions associated with each
of the emissions control systems, is usually sufficient.
Once the control technology alternatives and emission
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performance levels have been identified, total capital investment
and total annual cost should be developed. Total capital
investment (purchased equipment plus installation) and total
annual costs of each emission control system should be presented
separately. Total annual coasts are comprised of operation and
maintenance costs ("direct annual costs11,) administrative changes
("indirect annual costs"), plus overhead, taxes, insurance, and
capital recovery costs minus recovery credits (credit for product
recovery and by-product sales generated from the use of control
systems and other emission reduction credits.) These costs
should be reported in equal end-of-year payments over the time of
the equipment. Total annual costs should be reported on an
overall basis, as well as an incremental basis. The various
emission control systems should be presented or arrayed in terms
of increasing total annual cost. The incremental annual cost of
a particular emission control system is the difference in its
cost and the cost of the next less stringent control.
A method for determining the excessiveness or acceptability
of control costs is the comparison of the cost-effectiveness of
alternative control systems. Average cost-effectiveness is the
ratio of total annual costs (calculated using the above
guidelines) to the total amount (tons or Mg) of HAP removed.
Incremental cost effectiveness is calculated using the same
procedure as outlined for calculating incremental annual cost.
Generally, cost-effectiveness falling within the range of
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previously acceptable MACT decisions are not considered
excessive. Therefore, consistency with the relative 'cost, or
cost effectiveness, of a past MACT determination for a similar
source is an indication that such a cost is reasonable for the
MACT determination in question.
For most MACT determinations, a cost analysis focusing on
incremental cost-effectiveness of various MACT alternatives is
sufficient. The analysis should include and distinguish the
various components used to calculate the incremental cost-
effectiveness of the control alternatives (i.e., lifetime of the
equipment, total annual costs, tons of total HAP, removed, etc.).
If there is reason to believe that the control costs place a
significant burden on the entity being controlled, then the cost
analysis should include financial or economic data that provide
an indication of the affordability of a control relative to the
source. For example, if the per unit cost is a significant
portion of the unit price of a product or if the economic status
of the industry is declining, then the cost analysis should
present the relevant economic or financial data. Financial or
economic data should include parameters such as after-tax income
or total liabilities. An example of a financial criterion used
to determine affordability would be the ratio of a facility's
capital costs to the facility's parent company's total
liabilities. This ratio would provide an assessment of the
company's capital structure.,
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5.2 Environmental Impacts
• ,
The environmental impacts concentrate on collateral
environmental impacts due to control of emissions of the
/
pollutant in question, such as solid or hazardous waste
generation, discharges of polluted water from a control device,
visibility impacts (e.g. visible steam plume), or emissions of
other air pollutants. The applicant should identify any
environmental impacts associated with a control alternative that
has the potential to affect the selection or rejection of that
control alternative. Some control technologies may have
potentially significant secondary environmental impacts.
Scrubber effluent, for example, may affect water quality and land
use, and, similarly, technologies using cooling towers may affect
visibility. Other examples of secondary environmental impacts
could include hazardous waste discharges, such as spent catalysts
or contaminated carbon. Generally, these types of environmental
concerns become important when sensitive site-specific receptors
exist or when the incremental emissions reduction potential of
one control option is only marginally greater than the next most
effective option..
The procedure for conducting an analysis of environmental
impacts should be made based on a consideration of site-specific
circumstances. In general, the analysis of environmental impacts
starts with the identification and quantification of the solid,
liquid, and gaseous,discharges from the control device or devices
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under review. Initially, a qualitative or semi-quantitative
screening can be performed to narrow the analysis to discharges
with potential for causing adverse environmental effects. Next,
the mass and composition of any such discharges should be
assessed and quantified to the extent possible, based on readily
available information. As previously mentioned, the analysis
need only address those control alternatives with any
environmental impacts that have the potential to affect the
selection or rejection of a control alternative. Pertinent
information about the public or environmental consequences of
releasing these materials should also be assembled. Thus, the
relative environmental impacts (both positive and negative) of
the various alternatives can be compared with each other.
Also the generation or reduction of toxic and hazardous
emissions other than those for which the MACT determination is
being made and compounds not regulated under the Clean Air Act
are considered part of the environmental impacts analysis. A
permitting authority should take into account the ability of a
given control alternative for regulated pollutants to affect
emissions of pollutants not subject to regulation under the Clean
Air Act in making MACT decisions. Consequently, the ability of a
given control alternative to control toxic or hazardous 'air
contaminants other than those for which the MACT -determination is
being made, should be considered in the MACT analysis.
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5.3 Energy Impacts
Energy impacts should address energy use in terms of
penalties or benefits associated with a control system and the
direct effects of such energy use on the facility. A source may,
for example, benefit from the combustion of a concentrated gas
stream rich in volatile organic compounds; on the other hand,
extra fuel or electricity is frequently required to power a
control device or incinerate a dilute gas stream. If such
benefits or penalties exist, they should be quantified to the
extent possible. -
In quantifying energy impacts, the application could
estimate the direct energy impacts of the control alternative in
units of energy consumption at the source (e.g., Btu, Kwh,
barrels of oil, tons of coal). The energy requirements of the
control options could be shown in terms of total and/or
incremental energy costs per ton of pollutant removed. In many
cases, because energy penalties or benefits can usually be
quantified in terms of additional cost or income to the source,
the energy impacts analysis can be converted into dollar costs
and, where appropriate, be factored into the cost analysis.
Indirect energy impacts (such as energy to produce raw
materials for construction of control equipment) are usually not
considered. However, if the reviewing agency determines, either
independently or based on a showing by the applicant, that an
indirect energy impact is unusual or significant, the indirect
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impact may be considered. The energy impact should still,
* t ,
however, relate to the application of the control alternative and
not to a concern over energy impacts associated with the project
in general.
The energy impact analysis may also address the concern over
the use of locally scarce fuels. The designation of a scarce
fuel may vary from region to region, but in general a scarce fuel
is one which is in short supply locally and can be better used
for alternative purposes, or one which may not be reasonably
available to the source either at the present time or in the near
future.
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Chapter 6.0
Sources of Information
There are currently several programs under development to
house and disseminate toxics information. Some of these programs
are designed for specific, narrow purposes, while others are
employed in a broader range of uses. Many data collection
programs are designed for immediate interface with the AIRS
toxics program, which^ is currently under development.
The purpose of this chapter is to present various sources of
toxics information available in a database format. EPA believes
the requirements of 112(g) can be less burdensome to both
industry and States by employing a database system to calculate
the 12% floor which may involve using complex mathematical
algorithms and procedures.
BACT/LAER CLEARINGHOUSE INFORMATION SYSTEM (BLIS)
The BACT/LAER Clearinghouse, or the BACT/LAER Information
System (BLIS) is a database consisting of best achievable control
technology (BACT) determination information on specific sources,
to a process level. Database parameters include facility
information; process description; pollutant information; control
device type, installation date, efficiency; and calculation
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method; and stack test information if it exists.
Participation in BLIS is on a voluntary basis. If
participation in BLIS increases, it may be able to provide
sufficient information to determine the 12% floor with increasing
accuracy.
BLIS has undergone substantial revision. Additional fields
for use with toxics work have been added, changes to improve
"user-friendliness" of the system, such as menus and help screens
have been added, and BLIS is now available on the TTN Bulletin
Board.
JEIOG PROGRAMS
«
The Joint Emissions Inventory Oversight Group (JEIOG),
support for a data system for air toxics emissions inventories
focuses on the expressed requirements of the urban area source
program (UASP, Section 112(k), of the CAAA) and the Great Waters
Program (GWP, Section 112(m)).
Under the JEIOG programs, there are both short term,
immediate needs and long-term needs. Since the UASP data
collection effort is scheduled to be completed by mid-1994, JEIOG
may need to select a system for immediately use by the Urban Area
Source Program.
Urban Area Source Program
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The Urban Area Source Program (UASP) is collecting emission
inventory data for use by mid -1994 to meet the CAA November 1995
date for development of a national strategy for control of HAP
emissions in urban areas. The inventory focuses on an adequate
number of urban areas to "understand the urban area source
problem." Baltimore, Chicago and Houston are the leading
candidate cities. Other cities could be added (such as
Milwaukee, Detroit or Seattle) as the resources become available.
The primary data need is for a single year "snapshot" of
emissions data for use in developing the national control
strategy plan. As of the date of this writing, JEIOG has not
committed to any single system for storing the UASP data. AIRS
i
is under consideration with other database systems.
Great Waters Program
The Great Waters program requires HAP emissions data for
most of the U.S. and portions of Canada. The Great Lakes region
probably requires the most attention. Biennial assessments as
reports to Congress are required under the Great Waters program.
The first report is expected in November 1993. Emissions
inventory data are used primarily for input to models for the
assessment of the relative atmospheric loading of toxic
pollutants into the Great Lakes and other waterways. Updates of
the emission inventory are anticipated to support the periodic
assessments and for input to refined models as they become
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available.
GENERIC ICR DATA (SECTION 114)
Under the Authority of Section 114, EPA developed a survey
to obtain the information needed to calculate regulatory floors
for both new and existing stationary sources (See Appendix ).
This survey is commonly referred to as a "generic ICR", or
information collection request. It is customized within narrow
parameters for each source category, and comes in both a "long
form" and a "short form". EPA sends the survey to facilities at
the time it initiates regulatory development for the affected
source category. In other words, the survey is not sent to
facilities in all source categories at the same time.
•
In the generic ICR, EPA requests information regarding each
compound identified as a HAP that is used in or emitted by any
operations, including fugitive emissions sources, occurring from
the source category at the facility.
Recipients of the form are required to fill out the
information request as completely as possible from existing
information. .At a minimum, the facility must provide (1)
information of the presence of HAP emissions and (2) HAP emission
estimates based on previously obtained test data or on
engineering calculations provided there is a basis for such
calculations.
Since the Generic ICR data is collected by EPA from
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industries, it is called "Agency data". As such, it can not be
used to update (or replace) existing data which was obtained from
States, or "State data". The ICR data is currently stored and
analyzed on a commercial database software files. The Agency is
evaluating options to make the ICR data "safe" (without
confidential information) and accessible to States on a workfile
within AIRS/AFS.
XATEF: TOXIC EMISSION FACTORS
/
The requirements of the CAAA dictate immediate sampling and
analysis to obtain data for determination of emission factors.
These emission factors will be used to determine control
measures. EPA developed screening methods for the development of
air toxics emission factors, and applies the screening to test
results as they become available for use. The EPA is enhancing
the XATEF system for housing and manipulating the data. The
XATEF system is being redesigned to export toxic emission
factors, in a form similar to the AFSEF package for criteria
pollutants. The new system should be available by the fall of
1992.
The toxic emission factors available through the XATEF
system will be rated A (most reliable, based on several tests
meeting high confidence criteria) through E (least reliable,
having limited available information), similar to the way
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criteria emission factors are presented JLn the AP-42.
Toxic emission factors are being developed for 400 toxic
compounds, of which about 170 are on the list of 189 HAPs in
Section 112(b). About 40 of these have been targeted as
"critical" pollutants because they are found in a wide variety of
industries, and/or are. especially toxic. This group of about 40
toxic compounds have a rating of A or B, enabling users to arrive
at the most accurate emissions estimates presently possible.
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AIRS/APS NATIONAL OPERATING PERMIT SYSTEM
The EPA promulgated a new part 70 of Chapter I of title 40
of the Code of Federal Regulations (CFR) on July 21, 1992,
establishing provisions for the Operating Permit Program, and the
minimum data elements of State operating permit programs, states
must develop and submit programs for issuing operating permits to
major stationary sources of HAPs.
The requirements of Section 112(g)(2) (A&B) are triggered by
the effective date of a permit program under Title V in any
State. Section 112(g)(3) states that "the Administrator (or the
State) shall establish reasonable procedures for assuring that
the requirements applying to modifications under this section are
reflected in the permit".
The most far-reaching program established under the CAAA is
that'of a national operating permit program under Title V. The
National Air Data Branch (NADB) is developing a database as a
subsystem under AIRS/AFS to handle the new data coming in from
States Title V permit programs. This database is generally
referred to as the permit system. The permit system is under
design to provide much of the information needed for determining
the MACT floor both for case-by-case MACT determinations and for
MACT standards. It is expected that this system will become
available for use by the fall of 1993.
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AEROMETRIC INFORMATION RETRIEVAL SYSTEM (AIRS) TOXICS PROGRAM
The Aerometric Information Retrieval System (AIRS) was
designed and executed to accommodate the expansion of emissions
data. AIRS Facility Subsystem (AFS) is the stationary source
component of this system and replaced the old NEDS as the data
repository for point source data (e.g./ electric utilities,
industrial plants and commercial enterprises). Enhancement of
AIRS continues to support the new programs designated by the
CAAA. The National Air Data Branch (NADB) is currently
considering data support of the requirements under Section 112
for HAP. '
NATICH
•.
The National Air Toxics Information Clearinghouse (NATICH)
has been established by EPA to support State and local agencies
in the control of non-criteria air pollutants. The NATICH
program has both a database and a reporting capability.
The database component of the clearinghouse contains
information on various air toxics regulatory programs •
administered through State and local agencies. Elements such as
permitting, source testing, ambient monitoring, agency contacts,
acceptable ambient, limits and guidelines, and program overviews
are all contained within the database. Information is collected
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on an annual basis by voluntary submittal from participating
agencies.
Since its introduction in 1984, NATICH has undergone
periodic modifications in an attempt to expand and meet the 'needs
of the user community. In the fall of 1989, a link was
established between NATICH and the Toxic Release Inventory System
(TRIS). A modification is in the planning stages to move the
database from the NCC's IBM mainframe onto the OAQPS TTN Bulletin
Board System for easier and wider accessibility.
STATE AIR OFFICE DATABASES
•
Emissions Standards Division (BSD) staff have been working
with STAPPA/ALAPCO to better characterize the toxics information
available in database form and hard copy within the State air
offices.
Most States have compiled pollutant information in some form
in response to State Implementation Plan (SIP) requirements.
Many States also have toxics information collection systems, as
well as State requirements for toxics programs in the air
offices. Most States find that although internally their system
is widely used (intra-State system), to down load or upload data
on an inter-State basis is nearly impossible (with the primary
exception to this being States within a transport region, and
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then usually under limited circumstances). Many States have
expressed a keen interest in a National database that each State
could down load State-specific data into, and upload multi-State
retrievals from. This capability is met by three main systems in
EPA: BLIS, AIRS, and NATICH.
Many States use the Aerometric Information Retrieval System
(AIRS) to input their information and perform calculations and
retrievals. When a converter (an interface between AIRS and the
State system) is used, the data can be input directly into the
State system" and the converter then enters it into the
appropriate fields in AIRS. Data can also be retrieved from AIRS
into the State format with a converter.
Since many data sources are fed into AIRS/AFS, the system
becomes a repository of a vast amount of data. A great deal of
this will be useful for case-by-case MACT determinations and MACT
standards. This advantage is expected to" become more visible as
the search for the 12% floor for a source category becomes a
common occurrence.
Some State data is not generally found in the State systems
because it is not needed for their current reporting
requirements. However, much of the information missing from the
database system can be found in the files documenting source
categories and processes of industry reports. States may wish to
enhance their current systems to hold such additional data fields
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and data elements from their participating industries.
OTHER SOURCES OF INFORMATION
TRADE JOURNALS
Caution should be taken when employing these sources,
especially in noting the method of emissions estimation, number
of tests which were used in developing estimates, and the
conditions'under which tests were conducted. Other factors which
may affect the emissions estimates should also be identified, and
the effects of their differences quantified as accurately as
possible. Because results applicable to only one facility can
not be completely accurate for other facilities, this source of
information is not regarded as highly accurate.
This source of information may be somewhat biased as trade
journals are commonly published and•funded by the industry
members of a trade association. However, these journals are
completely acceptable as long as the results used, can be
substantiated.
TOXIC RELEASE INVENTORY SYSTEM (TRIS)
This is a source of data that was used to identify HAP
emitters. The TRIS database contains emissions data reported by
individual industrial facilities as required under Section 313 of
the Emergency Planning and Community Right-to-Know Act of 1988.
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Emissions data in TRIS are reported on a plant wide basis.
Standard Industrial Classification (SIC) Codes are reported in
TRIS but the entries are usually not specific enough to identify
categories of sources. The TRIS database is reportedly capable
of identifying plants emitting pollutants listed in Section
112(b).
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List of References
Air Pollution Training Institute (APTI). December 1983.
Overview of PSD Regulations. EPA 450/2-82-008.
Air Pollution Treaining Institute (APTI). June 1983. Air
Pollution Control Systems for Selected Industries.
EPA 450/2-82-006.
Environmental Protection Agency (EPA). May 1992. Facility
Pollution Prevention Guide. EPA, 600/R-92/088.
Environmental Protection Agency (EPA). February 1992.
Documentation for Developing the Initial Source Category
List. EPA, 450/3-91-030
Environmental Protection Agency (EPA). June 1991. Hazardous
Waste TSDF - Background Information for Proposed RCRA Air
Emission Standards. EPA, 450/3-89-023 (a) and (c).
Environmental Protection Agency (EPA). October, 1990. New Source
Review Workshop Manual. EPA, Research Triangle Park, NC
(Draft Document).
Environmental Protection Agency (EPA), January 1990. OAQPS
Control Cost Manual. EPA, 450/3-90-006.
Environmental Protection Agency (EPA). September 1986. Control
Technologies for Hazardous Air Pollutants.
EPA, 625/6-86-014.
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Appendix A ,
The following detailed examples presented in this
(
manual are for illustrative purposes only. Numbers and values
presented in this Appendix do not necessarily reflect any known
cases and are not meant to establish any US EPA position
regarding MACT determinations for a particular emission unit.
These examples are fictitious and are designed to highlight many
of the subtle aspects of the .MACT determination process. In many
cases, the scenarios and available control technologies have been
grossly oversimplified to streamline the presentation of the
examples.
The proceeding examples assume that an owner or operator has
already determined that the major source will be constructed,
reconstructed or modified.
A - 1
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PROPOSAL
March 1994
Example 1
Using Control Efficiency Ratings to Determine the MACT floor
Descrj.pt ion of Mai or Source:
A by-product coke plant proposes to construct a new
quenching tower to accommodate an increased production rate.
Hazardous emissions can be released when the hot coke in the
quench car is sprayed with water to decrease the coke's
temperature. Phenol and naphthalene emissions can occur in the
gaseous state. Other pollutants can sorb to particulate matter
and be collectively released. In this example, there will be an
increase in hazardous emissions by greater than a de minimis
amount from this major source that will not be offset. The owner
or operator will need to conduct a MACT analysis to recommend a
MACT and an MACT emission limitation to comply with the MACT
floor for existing major sources. No relevant standard exists
for the source, so a case-by-case MACT determination would apply.
The owner or operator will begin with the Tier I analysis.
Steps 1) Identify the MACT-affected emission unit(s)
MACT-affected source: quenching tower and coke car
# of existing sources: 36
The equipment used in.this production process include the
quenching tower, the coke car, water delivery system, and water
A - 2
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PROPOSAL
March 1994
storage system. Emission will increase at all these emission
points. Therefore, they are all affected by the modification.
The owner or operator decides to consider the quenching tower and
coke car as one affected emission unit, the water delivery system
and water storage system as another affected emission unit. The
example will be continued for only the quench tower/coke car
emission unit.
Step 2) Identify the source category for the major source and the
MACT-affected emission unit
source category: coke ovens: pushing, quenching,
and battery stacks
Rationale: The major source is a facility engaged in
metallurgical coke production by the destructive distillation of
coal. Given this information and description of major sources
listed in EPA-450/3-91-030 "Documentation for Developing the
Initial Source Category List", the major source fits the
description of the source category "coke ovens: pushing,
quenching and battery stacks."
A - 3
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PROPOSAL
March 1994
Step 3) Make a MACT floor Finding
Techno locry
1) Use clean water
to quench coke
with baffles at the top
of the quench tower
of plants using %efficiencv
10 not
quantifiable
2) Use covered quenched car.
Cool outside of car.
Water does not impact
coke. Place car on cooling
rack after quenching for
additional heat
dissipation.
almost 100%
3) Wet scrubber, connected
to fixed duct system
4) Wet scrubber, mobile unit
attached to coke quench car
5) Dry quenching with inert
gases. Heat transported to
waste-heat boiler
10
14
80-90%
80-90%
99-100%
A - 4
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PROPOSAL
March 1994
The owner or operator has decided to use the control
efficiency ratings to determine the MACT floor. There are a
total of 36 existing sources. Because an exact efficiency is not
know for each emission unit in the source category and accurate
MACT floor can not be computed using an arithmetic mean. The
median will be computed instead. The MACT floor is equivalent to
the emission reductions achieved by the emission limitation that
can be achieved by the three best performing emission units in
the source category. This equates to between an 80-90% emission
reductions. Technologies which meet this criteria are numbers 2,
3, 4, and 5. A specific numerical emission level can not be
established in this instance because the emission rate will vary
with the purity of the coke. The MACT floor will be established
based an operational efficiency associated with use of control
technologies 2, 3, 4 or 5. •
Step 4 Select a control technology as the MACT
Technologies 2, 3, 4, or 5 could be chosen as MACT. Number
I could also be consider because its control efficiency is not
quantifiable. If the owner wished to consider technology 1, a
more detailed analysis would be required to prove that the
technology could obtain an equal or greater amount of emission
reductions. In this case, the efficiency of technology 1 will
vary by the concentration of hazardous constituents. Using clean
A - 5
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PROPOSAL
March 1994
water could result in a less toxic release when the concentration
of toxins in the hot coke are less, but increased emissions could
result with increased concentrations. The other proposed
technologies would operate at a relatively constant efficiency
rate, regardless of the pollutant concentration. Therefore,
technology number 1 would be considered inferior and should be
eliminated as a potential candidate.
,The owner or operator should consult with the reviewing
agency to determine whether a costs, non air quality health and
environmental impacts and energy requirements analysis is
required for the available control technologies. If not, the
owner or operator could select any of these control technologies.
If an analysis is required, the control technology achieving a
maximum degree of reduction in emissions of the HAPs should be
selected based on the costs, non-air quality environmental and
health impacts and energy requirements analysis. After selecting
the technology the owner or operator would proceed to Tier III of
the analysis. In Tier III, the appropriate operation conditions
and design specification would be prescribed in addition to the
MACT emission limitation. .
A - 6
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PROPOSAL
March 1994
Example 2
When the MACT floor is Determined
using Emission Reduction Ratios
Description of Maior Source
A surface coating operation proposes to treat a new product
with its existing equipment consisting of a dip-tank priming
stage followed by a two-step spray application and bake-on enamel
finish coat. Minor changes to the existing equipment that
requires a capital expenditure will be made. The product is a
specialized electronics component (resistor) with strict
resistance property specifications that restrict the types of
coatings that may be employed. Because of the type of coating
required, the source will increase HAP emissions above a de
minimis level in all stages of the surface coating operation.
This increase in emissions will not'be offset. There is no
standard currently in effect for this source category; therefore,
a case-by-case MACT determination is required. The owner or
operator will begin with Tier I of the analysis.
A - 7
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PROPOSAL
March 1994
Step 1) Identify the MACT-affected emission unit(s)
MACT-affected emission units - 1. dip-tank
2. feed and waste lines in
prime coating operation
3. spray coat booth, spray
coat application equipment
4. drying oven
5. storage tank in prime
coating operation
6. storage tank in finish
s coating line
There are two process units influenced by the modification,
the prime coating line and the finish coating line. Equipment
within the prime coating line that have affected emission points
are a dip-tank, storage containers, feed line to supply new
coating into the dip-tank, a waste line to drain the dip-tank.
Because the feed line and waste lines have equipment leak
emissions, these emission ppints must be combined to form a MACT-
affected emission unit. The owner or operator will consider the
dip-tank and each storage container a separate affected emission
unit. The three MACT-affected emission units in this process
unit are the dip-tank, the storage container, and the feed and
waste lines.
The finish coating line consists of two spray booths, spray
A - 8
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PROPOSAL
March 1994
application equipment, paint supply system, a storage container,
and a drying oven. The owner or operator combines affected
emission points to form the following MACT-affected emission
units: the spray application equipment and spray booths; the
paint supply system, the storage container, and the drying oven.
For simplicity of this example, the MACT analysis will be.
continued for only the spray application equipment and spray
booths.
Step 2 - Determine the Source Category
Source category - Miscellaneous metal parts and products
(surface coating)
•
Rationale: The major source is a facility engaged in the surface
coating of an electronic resistor for calculators. Given this
information and the descriptions of source categories in EPA
450/3-91-030 "Documentation for Developing the Initial Source
Category List", the major source would be included in the
miscellaneous metal parts and products (surface coating).'
A - 9
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PROPOSAL
y March 1994
step 3) Hake a MACT floor finding
Steps A and B: Computing the Uncontrolled Emissions and
Controlled Emissions
Overview Analysis of emissions information for similar emission
units within the source category:
Technolocry # of sources using
1) water-based coat 2
2) low-VOC solvent/high
solids coat
3) electrostatic spray
application to enhance
transfer efficiency
4) low voc solvent/high solids 8
coating with electrostatic
spray application
5) powder coat paint with
electrostatic spray
application
6) high-voc solvent coating 8
A - 10
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PROPOSAL
March 1994
Detailed analysis
Source
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
Technology
t
6 ' '
3
2
3
3
6
6
3
2
2
6
6
6
3
2
3
4
5
4
3
4
4
Uncontrolled
emissions
(tons/yr)
10
26
48
86
98
26
35
78
69
' 15
11
12
23
85
141
25
159
126
35
25
68
46
Controlled
emissions
(tons/yr)
10
14
22
56
55
22
34
55
25
11
11
12
22
52
89
20
100 '
11'
14
16
22
10
Emission
reduction
ratio
0
.46
.54
.35
.44
.15
.03
.29
.64
.27
0
0
.04
.39
.39
;20
.37
.91
.6
.36
.70
.78
A - 11
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PROPOSAL
March 1994
Source
23
24
25
26
27
28
29
29
Technology
#
1
6
4
4
4
4
6
1
Uncontrolled
emissions •
(tons/yr)
95
96
64
98
168
196
186
255
Controlled
emissions
(tons/yr)
10
16
25
31
45
63
186
26
Emission
Reduction
Ratio
.89
.83
.61
.68
.73
.68
0
.90
A - 12
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PROPOSAL
March 1994
Step C Computing the Emission Reduction Ration for the
-MACT- Affected Emission Unit
Because there are 30 sources, the MACT floor should be based
on the arithmetic mean of the emission reduction ratios achieved
by the best 12% of existing emission units. Twelve percent of 30
emission units is equal to 3.5 sources. The owner or operator
should round up all fractions to the next largest number. The
MACT floor is equal to the arithmetic mean of the emission
reductions obtained by the best 4 sources in the source category.
Reviewing the data above, the MACT floor equals an emission
reduction ratio of 0.88 ([0.91 + 0.90 + 0.89 + 0.83]/4) or the
emission-reductions that can be achieved when control
technologies 1 or 5 are used. In this example, the nature of the
•
product requires a specific type of coating. Technology l and 5
are inappropriate for application to this MACT-affected emission
unit. The owner or operator continues with the analysis to
identify other technologies that can meet a 0.88 emission
reduction ratio.
Step D Determine a MACT emission limitation (MEL)
The owner or operator of the MACT-affected emission unit
needs to calculate an uncontrolled emission rate for the MACT-
affected emission unit. Because current design specifications
for the existing emission unit cause a larger uncontrolled
emission rate than any other designs used in the past 5 years, •
A - 13
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PROPOSAL
March 1994
the current operational designs will be used to determine the
uncontrolled emissions. With the existing coating material, the
MACT-affected emission unit has an uncontrolled emission level'of
125 tons/yr total HAPs. The MEL for this emission unit would be
•
MEL = 125 tons/yr * (1 - 0.88)
= 15 tons/yr
Step 4 Select a control technology to meet the MACT Emission
Limitation.
In this case, the owner or operator must select a control
technology that allows the source to meet the MACT emission
limitation. Because the owner and operator can not use any of
• *
the identified control technologies to meet the MACT floor,
control technologies to control similar emission points will be
considered. In this example, the similar emission points have
operational losses. Review of control technologies to control
operational losses identifies add-on control devises such as a
carbon absorber, a thermal or catalytic incinerator, or a
condenser. The owner or operator should conduct a costs, non-air
quality health and environmental impacts and energy requirements
analysis on the available control technologies.
The major source already has a catalytic incinerator on
site. The emissions from the spray application equipment and
spray booth could be channeled to the incinerator. Thi$ would
A - 14
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PROPOSAL
March 1994
require the installation of a venting system including a pump
mechanism. It would also require an increased volumetric flow
rate to the incinerator and increase auxiliary fuel requirements.
The incinerator had been operating at a 90% efficiency. With an
increased volumetric flow rate, the efficiency is projected to
drop to 87% efficiency. The owner and operator must obtain an
additional 1% emission reductions. Possible control technologies
include increasing the operating temperature of the incinerator,
or adding electrostatic application to the spray process to
enhance transfer efficiency. Limiting the hours of operation at
the MACT-affected emission unit could be considered if the
reduced production were part of an overall source reduction
program.
Use of the specialized coating in this operation will
increase the concentration of hazardous pollutants in the water
used for the water curtain. The proposed control technology does
not affect the concentration of pollutants in the wastewater.
This could be considered a negative environmental impact and may
be reason to consider another control technology to meet the MACT
emission limitation. In this instance, the owner or operator
will not violate the NPDES permit, so the MACT candidate will not
be eliminated from consideration.
The owner or operator uses this step to demonstrate that
despite the increase in volumetric flow rate and the auxiliary
fuel requirement, a significant increase in criteria pollutant
A - 15
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PROPOSAL
March 1994
emissions does not occur. The owner or operator concludes that
the impacts associated with use of this technology are
reasonable.
After reviewing the technologies the owner or operator
selects the incinerator with a limit on the hours of operation.
The owner or operator proposes to start a training program for
*
spray booth operators to decrease the error and product rejection
rate. By doing this, the owner or operator can reduce the hours
of operation and still meet customer demands for the product.
This option was chosen over the other two because increasing the
incinerator's operating temperature would require additional
auxiliary fuel input, and enhancing the transfer efficiency with
electrostatic application would be cost prohibitive. The owner
or operator would document that use of the selected control
technologies can reduce emissions to the required level.
The owner or operator would move to Tier III of the analysis
and document the MACT emission limitation, and suggest
appropriate conditions to assure that this MACT emission
limitation is federally enforceable.
A - 16
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PROPOSAL
March 1994
Example 3
When the MACT floor is Equal to "No Control"
Description of Maior Source;
A pesticide manufacture historically sent its waste to an
off-site commercial treatment, storage and disposal facility
(TSDF). The TSDF is no longer accepting wastes. The
manufacturer has decided to treat its own waste on-site. The
solvent/aqueous/pesticide mixed waste will be passed through a
distillation column where the organic solvents will be vaporized
and then condensed into a distillate receiver. The solvent will
be transferred using tank cars to a tank farm that will be
located at another portion of the plant. It will be stored there
for later use. The pesticide-laden wastewater will be sent from
the distillation column to a carbon adsorber where the pesticide
will be removed from the wastewater. The wastewater will be
recycled to the manufacturing process. The adsorber will be
periodically steam stripped to regenerated the carbon. The major
source will increase emission by greater than a de minimis amount
for a HAP. The modification will require a MACT determination.
A - 17
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PROPOSAL
March 1994
Tier I
Step 1) Identify the MACT-affected emission unit(s)
MACT-affected emission units: 1) each storage tank
2) the distillation column,
condenser, and distillate
^
receiver
3) the three carbon absorbers
4) pumps, feed lines and
transfer lines
5) loading racks
The two process units that contain emission points affected
by this modification are the recycling process, and the tank
farm. The equipment and apparatus associated with the affected
emission points are pumps, feed lines, a distillation column, a
condenser, a distillate receiving tank, three carbon absorbers
and transfer lines, a loading rack, and storage tanks. The owner
or operator will consider the three carbon absorbers and the
associated emission points as one emission unit because a single
control technology could be practically designed to cover all
three affected emission points. The owner or operator will also
group the distillation column, distillate receiver and condenser
into one MACT-affected emission unit. The feed lines, pumps, and
transfer lines would have equipment leak emission losses and
*
A - 18
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PROPOSAL
March 1994
would be another affected emission unit. The owner and operator
has decided to consider the emission points and equipment for the
loading rack and tanks as separate MACT-affected emission units.
If all the tanks were structurally similar in design, one
determination could be made that would be applicable to all the
tanks.
%
Step 2) Identify the source category for the major source and the
MACT-affected emission unit
Source category: 2,4-D salt and esters production
The pesticide manufacture produces the pesticide 2,4,-D. .
There is a specific source category for 2,4,-D salt and esters
production. The pesticide manufacture fits the description of
this source category.
Step 3) Hake a MACT floor finding
For simplicity, this example MACT analysis will only be
continued for a tank emission unit. All the storage tanks will
be structurally similar, so only one MACT determination will be
required. The manufacturer has reviewed existing data bases and
determined that less than 12% of tanks in the source category are
controlled. Therefore the MACT floor is equal to "no control".
This is not automatically an acceptable "control" measure, so the
A - 19
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PROPOSAL
March 1994
owner or operator will move to Tier II of the MACT analysis. In
Tier II of the analysis control technologies for similar emission
points from outside the source category will also be considered.
A - 20
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PROPOSAL
March 1994
owner or operator will move to Tier II of the MACT analysis. In
Tier II of the analysis control technologies for similar emission
points from outside the source category will also be considered.
A - 20
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PROPOSAL
March 1994
Tier II
Step 1) List All Available Control Technologies
The following technologies have been identified as possible
control technologies that can be applied to a storage tank to
control working and breathing emission losses:
Emission control
efficiency
*
1. fixed-roof 86-99
2. fixed-roof plus internal floating roof 97-99
3. fixed roof vented to a carbon canister 95-100
4. fixed-roof vented to a combustion devise 99-100
5. fixed-roof vented to carbon absorber 99-100
6. pressure tank 95-100
Step 2) Eliminate Technically Infeasible Control Technologies
All of the available control technologies are technically
feasible.
Step 3) Conduct a Non-air Quality Health, Environmental,
Economic and Energy Impacts Analysis
The following series.of tables illustrate a non-air quality
health, environmental, cost and energy impacts analysis for each
control option.
Table 1 presents information describing the various control
technologies that are technically feasible. Secondary air
impacts as well as energy impacts and other resource demands.
A - "21
-------
PROPOSAL
March 1994
Table l
Control Option
Secondary Air
Impacts
Resource Demands
1 fixed roof
none
none
2 fixed roof +
internal roof
none
none
3 pressure tank
none
none
4 cover and
vented to
carbon canister
emission if
carbon regenerated
disposal of
container, solvents
for regeneration
5 cover and vent
to combustion
devise
increased CO, NOx,
SOx, and
particulate
emissions
fuel source,
disposal of ash
6 cover and vent to
carbon absorber
emissions when
carbon regenerated
disposal of spent
carbon, solvents
for regeneration
A - 22
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PROPOSAL
- March 1994
Table 2 presents the control options along with- their costs
and emission reductions. The average cost effectiveness of each-
control option is also presented. The average cost effectiveness
is the ratio of the total annual cost to the total amount of HAP
removed. Note that the control options are presented in terms of
increasing annual cost (i.e., control option 1 has the smallest
annual cost, control option 2 has the second smallest annual
cost, etc.)
Using Table 2, several control options can be eliminated
from further consideration. Control option 3 should be
eliminated because control option 2 achieves the same amount of
HAP reductions but at a lower cost. Control option 2 should be
eliminated because control option 4 achieves a greater degree of
emission reduction for lower cost. The elimination of control
options 2 and 3 reduces the number of technically feasible and
economically efficient options to four control technologies.
Table 3 presents the incremental cost effectiveness of the
remaining options. The incremental cost effectiveness of control
option 1 is the same as its average cost effectiveness since
control option 1 is the first incremental option from the
baseline. The incremental cost effectiveness of control option 4
is the ratio of the difference in cost between options I and 4 to
the difference in HAP emission reductions between the two ratios.
A - 23
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Table 2
PROPOSAL
March 1994
CONTROL
OPTION
1
2
3
4
5
6
CONTROL
EFFICIENCY
93
96
96
98
99
100
ANNUAL COST
($)
85,000
113,000
232,000
110,000
136,000
189,000
EMISSION
REDUCTION
(Mg/Yr)
72
88
88
92
103
117
AVERAGE
COST-
EFFECTIVENESS
<$/Mg)
1,161
1,264
2,636
1,156
1,320
1,615
Table 3
CONTROL
OPTION
1
4
5
6
ANNUAL COST
($)
85,000
110,000
136,000
189,000
EMISSION
REDUCTION
(Mg/Yr)
72"'
92
103
117
AVERAGE
COST-
EFFECTIVENESS
($/Mg)
1,161
1,156
1,320
1,615
INCREMENTAL
COST
EFFECTIVE-
NESS ($/Mg)
1,250
2,364
3,766
A - 24
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PROPOSAL
March 1994
Step 4) Identify MACT
Examination of the cost effectiveness of the' various control
options can lead to the elimination of some control options.
Control option 6 is eliminated because the incremental cost is
deemed too high. The incremental cost of control option 5 is
deemed acceptable but upon closer examination, the secondary air
and energy impacts make this option undesirable. The incremental
cost of both options 1 and 4 are deemed acceptable; however,
control option 1 is eliminated because other considerations
(secondary air impacts, etc) do not preclude the selection of
control option 4 which achieves a greater degree of emission
reductions.
The owner or operator should progress to Tier III.
A - 25
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-------
PROPOSAL
March 1994
Appendix B
Forum of Anticipated Questions
1. When computing the number of sources in^the "best 12% of
similar sources in the source category" should the number of
sources be rounded to the nearest or next largest whole number?
For example if there are forty-five similar sources in the source
category would the "best 12%" include 5 or 6 sources.
The number should be rounded to the next largest number. In
the example the "best 12%" would include 6 sources.
2. How many decimal points should be in the emission reduction
ratio, and the manufacturer's efficiency rating?
The emission reduction ratio should be carried to two
decimal places. The efficiency rating should be rounded to
the nearest whole number.
3. Should the emission limitation(s) be based on overall HAP
emissions or emissions of an individual HAP?
The emission limitation may be based on overall HAP
emissions or a specific emission limitation may be specified
for an individual HAP. A specific emission limitation may
B - l
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PROPOSAL
March 1994
be established if health risks warrant placing an individual
emission limitation, or if an individual emission limitation
is needed to make the overall HAP emission limitation
federally enforceable.
•
4. If a major source increase emissions above a de minimis
amount due to a modification what emission points are subject to
the MACT determination: all emission points contributing to an
above de minimis increase, emission points whose increases can be
summed above de minimis, or the "straw that backs the de minimis
level".
Example: Assume de minimis is 9 tpy.
Increase in emissions tpy
Emission point 1 3
Emission point 24 .
Emission point 3 6
Do all the sources require a MACT determination, because all
increase in emissions. Or, do Emission points 2 and 3 require a
MACT determination because the sum of the emissions from these
points exceed de minimis, or just Emission point 3 because it
causes de minimis to be exceed?
All thrtfe emission points would require a MACT determination
because the sum total of emission increases exceeds a de
B - 2
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PROPOSAL
March 1994
minimis amount.
5. If a non-major source undergoes a construction,
reconstruction or modification and increases emissions above a
de minimis amount, and reclassifies the source as a major source
based on its potential to emit is a case-by-case MACT
determination required? If so, is existing source or new source
MACT required?
The source would be reclassified as a major source and will
be required to file for a Part 70 or Part 71 permit, but it
would not be subject to any determination under Section
112(g) until it reconstructs, constructs, or modifies again.
6. Is there an official form to apply for a MACT determination?
No. The application for a MACT determination is required to
contain certain information, but there is no official form
required by the Federal government. However, reviewing
agencies may develop there own official form.
7. Is the MACT emission limitation always based on add-on
control devises?
No. The MACT emission limitation should be based on the
B - 3
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PROPOSAL
March 1994
best control technologies which can include add-on controls,
work practices, pollution prevention methods, etc.
^
8. A major source modification results in an above de minimis
increase in emissions of a HAP. The owner or operator can offset
emission from some of the emission points that contribute to the
above de minimis increase, but not all of the emission points.
Is a MACT determination required for those emission points that
could be offset?
An above de minimis increase in HAP emissions must be
completely offset, or all emission points contributing to
the increase require a MACT determination. In this
instance, a MACT determination would be required.
9. A major source has agreed to participate in the early
reductions program. Through this program, an owner or operator
of a major source can obtain a compliance extension for a future
MACT standard, if a 90% reduction in emissions is achieved before
promulgation of that relevant emission standard. If the major
source proposes to modify is a MACT determination required.
A MACT determination is not required for major source
participating in the early reductions program, if the source
continues to meet the early reductions committment. If the
source is no longer able to meet the 90% reductions, a MACT
determination would be required.
*
B - 4
-------
, PROPOSAL
March 1994
10. In the course of conducting a MACT analysis, the owner or
operator discovers that the MACT floor is equal to 97% control.
Could the owner or operator enter the early reductions program
and only obtain 90% control?
•
If a relevant emission standard has not yet been proposed,
the owner or operator could join the early reductions
program and avoid a MACT determination. The owner or
operator would be required to participate in this program
before beginning any construction, reconstruction, or
modification.
B -
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-------
PROPOSAL
March 1994
Appendix C
DEFINITIONS
Act - the Clean Air Act as amended in 1990 (42 U.S.C. 7401 et
seg., as amended by Pub. L. 101-104 Stat. 2399).
Administrator - the United States Environmental Protection Agency
or his or her authorized representative (e.g a State that has
been delegated the authority to implement the provisions of this
part.)
Affected emission point - an emission point identified as being
part of a modification, construction or reconstruction and
requiring a MACT determination.
Alternative test method - any method of sampling and analyzing
for an air pollutant that is not a test method in 40 CFR Part 63
and that has been demonstrated to the Administrator's
satisfaction, using Method 301 in Appendix A of Part 63, to
produce results adequate for the Administrator's determination
that it may be used in place of a test method specified in that
part.
Approved permit program - a State permit program approved by the
Administrator as meeting the requirements of 40 CFR Part 70, or a
federal permit program established under 40 CFR Part 71.
Controlled emissions - the sum of all hazardous air emissions
from all emission points given the maximum design capacity
currently in use by the emission unit taking 'into consideration
the application of all existing control technologies and
federally enforceable limits.
Control technology - measures, processes method," systems, and
techniques to limit the emission of hazardous air pollutants
including, but not limited to, measures which
(1) reduce the volume of, or eliminate emissions of, such
pollutants through process changes, substitution or
materials or other modifications,
(2) enclose systems or processes to eliminate emissions,
(3) collect, capture or treat such pollutants when released
from a process, stack, storage or fugitive emissions point,
(4) are design, equipment work practice, operational
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„ March 1994
Appendix C
DEFINITIONS
Act - the Clean Air Act as amended in 1990 (42 U.S.C. 7401 et
seq., as amended by Pub. L. 101-104 Stat. 2399).
Administrator - the United States Environmental Protection Agency
or his or her authorized representative (e.g a State that has
been delegated the authority to implement the provisions of this
part.)
Affected emission point - an emission point identified as being
part of a modification, construction or reconstruction and
requiring a MACT determination.
Alternative test method - any method of sampling and analyzing
for an air pollutant that is not a test method in 40 CFR Part 63
and that has been demonstrated to the Administrator's
satisfaction, using Method 301 in Appendix A of Part 63, to
produce results adequate for the Administrator's determination
that it may be used in place of a test method specified in that
part.
Approved permit program - a State permit program approved by the
Administrator as meeting the requirements of 40 CFR Part 70, or a
federal permit program established under 40 CFR Part 71.
Controlled emissions - the sum of all hazardous air emissions
from all emission points given the maximum design capacity
currently in use by the emission unit taking into consideration
the application of all existing control technologies and
federally enforceable limits.
Control technology - measures, processes method, systems, and
techniques to limit the emission of hazardous air pollutants
including, but not limited to, measures which
(1) reduce the volume of, or eliminate emissions of, such
pollutants through process changes, substitution or
materials or other modifications,
(2) enclose systems or processes to eliminate emissions,
(3) collect, capture or treat such-pollutants when released
from a'process," stack, storage or fugitive emissions point,
(4) are design, equipment work practice, operational
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March 1994
standards (including requirements for operator training or
certification) as provided in subsection (h), or
(5) are a combination of above.
Commenced - with respect to construction, reconstruction or
modification of a stationary source, that an owner or operator
has undertaken a continuous program of construction,
reconstruction or modification or that an owner or operator has
entered into a contractual obligation to undertake and complete,
within a reasonable time, a continuous program of construction,
reconstruction, or modification.
Compliance date - the date a MACT-affected emission unit is
required to be operating and meeting all the. requirements of the
Notice of MACT Approval. For new sources this date is upon
start-up. For existing sources this date should be as soon as
practicable, but no later than 3 years from the effective date,
or as otherwise specified by a relevant emission standard.
Compliance Plan - the action and schedule necessary to bring a
MACT-affected emission unit into compliance with the Notice of
MACT Approval.
Construct - to fabricate (on site), erect, or install a
stationary source which is or may be subject to a standard,
limitation, prohibition, or other federally enforceable
requirement established by the Administrator (or a State within
approved permit program) pursuant to Section 112 of the Act.
Construction of a major source - fabrication, erection, or
installation of a major source that emits 10 tpy of a single HAP
or 25 tpy of any combination of HAPs.
Continuous emission monitoring system (GEMS) - the total
equipment, meeting the data acquisition and availability •
requirements of this part, used to sample, condition (if
applicable), analyze, and provide a permanent record of
emissions.
Continuous monitoring system (CMS) - a continuous emission
monitoring system or a continuous parameter monitoring system.
Controlled emission level (GEL) - the maximum amount of HAP that
could be emitted from the unit-under current design specification
and at full capacity utilization taking into consideration the
application of federally enforceable controls.
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PROPOSAL
March 1994
De minimis - An amount of increased HAP emissions, below which an
owner or operator of a modified major source does not have to
obtain offsets or undergo a MACT determination before increasing
emissions.
Effective date - the date a Notice of MACT Approval is signed and
issued by a permitting agency, or the date specified in a
promulgated emission standard.
Emission Unit - one emission point or the collection of emission
points within a major source requiring a MACT determination.
An emission unit can be defined (by the permitting authority) as
any of the following:
(1) An emitting point that can be individually
controlled, e.g. a boiler, a spray booth, etc.
(2) The smallest grouping of emission points, that,
when collected together, can be commonly controlled by a single
control device or work practice.
(3) A grouping of emission points, that, when
collected together, can be commonly controlled by a single
control device or work practice.
(4) A grouping of emission points that are
functionally related. Equipment is functionally related if the
operation or action for which the equipment was specifically
designed could not occur without being connected with or relying
on the operation of another piece of equipment.
(5) A grouping of emission points that, when collected
together, comprise a building, structure, facility, or
installation.
Existing Source - a source that is not constructed or
reconstructed.
Federally enforceable - all limitations and conditions which are
enforceable by the Administrator, including those requirements
established by State or Local agencies who have received
delegation to impose such limitations through an approved Part 70
permit program or through Section 112(1) of the Act.
Requirements developed pursuant to Part 60 and Part 61 of this
chapter and requirements within any applicable State
Implementation Plan are also considered federally enforceable.
To be federally enforceable, the limits and conditions must
undergo public review and be reported to the EPA. Emission
limits that are considered federally enforceable include limits
on the allowable capacity of the equipment; requirements for the
installation, operation and maintenance of pollution control
technologies; limits on hours of operation; and restrictions on
amounts of materials combusted, stored or produced. To be
federally enforceable, restrictions on operation, production or
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PROPOSAL
March 1994
emissions must reflect the shortest practicable time period (in
no event for a period in excess of 30 days.) General limitations
such as yearly limits (e.g. tons per year) are not considered
federally enforceable. The use of hourly, daily, weekly, or
monthly rolling averages are acceptable. Any federally
enforceable limitations or conditions must be practically
enforceable and ensure adequate testing, monitoring, and
recordkeeping to demonstrate compliance with the limitations and
conditions.
Fugitive emissions - emissions from a stationary source that
could not reasonably pass through a stack, chimney , vent or
other functionally equivalent opening:
Hazardous Air Pollutant (HAP) - any air pollutant listed in
Subpart C of 40 CFR Part 63 pursuant to Section 112(b) of the
Act. When there is a discrepancy between the hazardous air
pollutant list in Section 112(b) and the list in Subpart C, the
list in Subpart C shall supersede the list in Section 112(b).
Installation schedule - an enforceable schedule of actions or
operations leading to compliance with a MACT emission limitation.
Maximum achievable control technology (MACT) - a control
technology that achieves a maximum degree of reduction in
emissions of the hazardous air pollutants with consideration to
the costs of achieving such emission reductions, and the non air
quality health and environmental impacts and energy requirements.
MACT-affee-ted emission unit - an emission unit or source
requiring a MACT determination.
MACT analysis - the process an owner/operator conducts to define
the MACT floor, recommend a MACT emission limitation, and select
the MACT.
MACT determination - a process conducted by the Administrator to
evaluate a major source's ability to comply with the requirements
of 40 CFR Part 63, Subpart B.
MACT emission limitation (MEL) - the maximum achievable control
technology emission limitation for the hazardous air pollutants
listed under Section 112(b) of the Act that the Administrator
(or a State with an approved permit program) determines through a
promulgated emission standard or on a case-by-case basis to be
the maximum degree of reduction in emissions of the HAPs with
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PROPOSAL
March 1994
consideration to the costs of achieving such emission reductions
and the non air quality health and environmental impacts and
energy requirements.
If the Administrator or reviewing agency determines that it
is inappropriate to prescribe a numerical or efficiency based
MACT emission limitation a specific design, equipment/ work
practice, operational standard, or combination thereof, may be
prescribed instead. Such standard shall, to the degree possible,
set forth the emissions reduction achievable by implementation of
such design, equipment, work practice, or operation, and shall
provide for compliance by means which achieve equivalent results.
MACT floor - for new sources or constructed or reconstructed
major sources: a level of hazardous air pollutant emission
control that is achieved in practice by the best controlled
similar source as determined by the Administrator.
For a existing sources or a modification to a major source
the MACT floor is:
(a) the average emission limitation achieved by the best
performing 12 percent of existing sources (for which
the Administrator has emission information), excluding
those sources that have, within 18 months before the
emission standard is proposed or within 30 months
before such standard is promulgated, whichever is
later, first achieved a level of emission rate or
emission reductions which compiles, or would comply if
the source is not subject to such standard, with the
lowest achievable emission rate (as defined by Section
171 of the Act) applicable to the source category and
prevailing at the time, in the category or. subcategory
for categories and subcategories with 30 or more
sources; or,
(b) The average emission limitation achieved by the best
performing 5 existing sources for sources with less
than 30 sources in the category or subcategory.
Major source - any stationary source or group of stationary
sources located within a contiguous area and under common control
that emits or has the potential to emit considering controls, in.
the aggregate, 10 tons per year o~r more of any hazardous air
pollutant or 25 tons per year or more of any combination of
hazardous air pollutants^ unless the Administrator establishes a
lesser quantity as codified in Subpart C of 40 CFR Part 63, or in
the case of radionuclides, different criteria from those
specified in this sentence.
A
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PROPOSAL
March 1994
Notice of MACT Approval (NOMA) - a document issued by a reviewing
agency containing all federally enforceable conditions necessary
to enforce the application of, and operation of MACT such that
the MACT emission limitation is met.
Owner or operator - any person who owns, leases, operates,
controls, or supervises a stationary source.
Part 70 permit - any permit issued, renewed, or revised pursuant
to 40 CFR Part 70.
Part 71 permit - any permit issued , renewed, or revised
pursuant to Part 71 of this chapter.
Permit program - a comprehensive State or Federal operating
permit system established pursuant to regulations codified in 40
CFR Part 70 or Part 71.
Permit revision - any permit modification or administrative
permit amendment to a Part 70 or Part 71 permit as defined in
those parts.
Permitting agency -
(1) The State air pollution control agency, including local
agencies or Indian tribes, authorized by the Administrator to
carry out a permit program under 40 CFR Part 70.
(2) The Administrator, in the case of EPA-implemented permit
programs under 40 CFR Part 71.
Potential to emit - the maximum capacity of a stationary source
to emit a pollutant under its physical and operational design.
Any physical or operational limitation of the capacity of the
stationary source to emit a pollutant, including air pollution
control equipment and restrictions on hour of operation or on the
type or amount of material combusted, stored, or processed, shall
be treated as part of its design if the limitation or the effect
it would have on emissions is federally enforceable.
Project - all activities associated with construction,
reconstruction, or modification of a source including design,
fabrication, erection, installation and start-up.
Reconstruction - the replacement of components of an existing
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major source to such an extent that (1) the fixed capital cost of
the new components exceeds 50 percent of the fixed capital cost
that would be required to construct a comparable entirely new
source, and (2) it is technologically and economically feasible
for the reconstructed source to meet the Section 112(d) emission
standard(s), alternative emission limitation(s), or equivalent
emission limitation(s) established by the Administrator ( or a
State with an approved permit program) pursuant to Section 112 of
Act. Upon reconstruction, an affected source is subject to
Section 112(d) standards for new sources, including compliance
dates, irrespective of any change in emissions of hazardous air
pollutants from that source.
Relevant standard - (1) an emission standard, (2) an alternative
emission standard, (3) an alternative emission limitation, (4) an
equivalent emission limitation that applies to a stationary
source regulated by such standard or limitation. A relevant
standard may include or consist of.a design, equipment work
practice, or operational requirements or other measures, process,
method, system or technique (including prohibition of emissions)
that the Administrator (or a State with an approved permit
program) determines is achievable for a constructed or
reconstructed major source, new or existing source to which such
standard or limitation applies. Every relevant standard
established pursuant to Section 112 of the Act includes Subpart A
of this part and all applicable appendices of Parts 51, 60, 61,
and 63 of Chapter 40 of the code of federal regulations that are
reference in that standard.
Similar emission unit - two or more sources or emission units
that have similar emission types and can be controlled using the
same type of control technology.
Similar emission type - See Section 2.4 of Chapter 2.
Source - an emission unit, or as otherwise specified in an
applicable 40 CFR Part 63 emission standard.
Start-up - beginning operation of a source or emission unit.
State - all non-federal permitting authorities, including local
agencies, interstate associations, and State-wide programs, that
have delegated authority to implement (1) the provisions of 40
CFR Part 63; and/or (2) the permit program established under Part
70 of this chapter. State shall have its conventional meaning
where clear from the context.
Stationary source - any building, structure, facility or
installation that emits or may^emit any air pollutant. For the
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PROPOSAL
March 1994
purposes of 40 CFR Part 63, stationary sources are listed in
categories pursuant to Section 112(c) of the ACT and published in
the Federal Register. (See Appendix D)
f*
Uncontrolled emissions (UCEL) - the maximum amount of HAP that
could be emitted from the unit under current design
specifications and at full capacity utilization. For existing
sources, design specifications used within the past five years
may be used, if a pollution prevention method was enacted at the
source within the period of time (See Section 3.2).
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Appendix D
Initial List of Categories of Major and Area
Sources of Hazardous Air Pollutants
Fuel Combustion
Category Name
Engine Test Facilities .
Industrial Boilersb
Institutional/Commercial Boilers6
Process Heaters
Stationary Internal Combustion Engines6
Stationary Turbines6
Non-Ferrous Metals Processing
Category Name
Primary Aluminum Production
Secondary Aluminum Production
Primary Cooper Smelting
Primary Lead Smelting
Secondary Lead Smelting
Lead Acid Battery Manufacturing
Primary Magnesium Refining
Ferrous Metals Processing
Category Name
Coke By-Product Plants
Coke Ovens: Charging, Top Side, and Door Leaks
Coke Ovens: Pushing, Quencing, and Battery Stacks
Ferroalloys Production
Integrated Iron and Steel Manufacturing
Non-Stainless Steel Manufacturing - Electric Arc
Furnace (EAF) Operation
Stainless Steel Manufacturing-Electric Arc
Furnace (EAF) Operation
Iron Foundries
Steel Foundries
Steel Pickling-HCI Process
Mineral Products Processing
Category Name
Alumina Processing
Asphalt/Coal Tar Application-Metal Pipes
Asphalt Concrete Manufacturing
Asphalt Processing
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Appendix D
Asphalt Roofing Manufacturing
Chromium Refractories Production
Clay Products Manufacturing
Lime Manufacturing
Mineral Wood Production
Portland Cement Manufacturing
Taconite Iron Ore Processing
Wool Fiberglass Manufacturing
Petroleum and Natural Gas Production and Refining
Category Name
Oil and Natural Gas Production
Petroleum Refineries-Catalytic Cracking
(Fluid and other) Units, Catalytic
Reforming Units, and Sulfur Plant Units
Petroleum Refineries-Other Sources
Not Distinctly Listed
•
Liquids Distribution
Category Name
Gasoline Distribution (Stage 1)
Organic Liquids Distribution (Non-Gasoline)
Surface Coating Processes
«
Category Name
Aerospace Industries
Auto and Light Duty TrucJ: (Surface Coating)
Flat Woods Paneling (Surface Coating)
Large Appliances (Surface Coating)
Magnetic Tapes (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
Printing/Publishing (Surface Coating)
Shipbuilding and Ship Repair (Surface Coating)
Wood Furniture (Surface Coating)
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Appendix D
Waste Treatment and Disposal
Category Name
Hazardous Waste Incineration
Municipal Landfills
. Sewage Sludge Incineration
Site Remediation
Solid Waste Treatment, Storage and
Disposal Facilities (TSDF)
Publicly Owned Treatment Works (POTW) Emissions
Agricultural Chemicals Production
Category Name
2.4-D Salts and Esters Production
4-Chloro-2-Methylphenoxyacetic Acid Production
4.6-Dinitro-o-Cresol Production
Captafol Production
Captan Production
Chloroneb Production
Chlorothalonil Production
Dacthal (tm) Production
Sodium Pentachlorophenate Production
Tordon (tm) Acid Production
Fibers Production Processes
Category Name
Acrylic Fibers/Modacrylic Fibers Production
Rayon Production
Spandex Production
Food and Agricultural Processes
Category Name
Baker's Yeast Manufacturing
Cellulose Food Casing Manufacturing
Vegetable Oil Production
Pharmaceutical Production Processes
Category Name
Pharmaceutical Production
Polymers and Resins Production
Category Name
Acetal Resins Production
Acrylonitrile-Butadiene-Styrene Production
Alkyd Resins Production
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Appendix D
Aminb Resins Production
Boat Manufacturing
Butadiene-Furfural Cotrimer (R-ll)
Butyl Rubber Production
Carboxymethylcellulose Production
Cellophane Production
Cellulose Ethers Production
Epichlorohydrin Elastomers Production
Epoxy Resins Production
Ethylene-Propylene Elastomers Production
Flexible Polyurethane Foam Production
Hypalon (tm) Production
Maleic Anhydride Copolymers Production
Methylcellulose Production
Methylcellulose Production
Methyl Methacrylate-Aerylonitrile-Butadiene-
Styrene Production
Methyl Methacrylate-Butadiene-Styrene Terpolymers
Production
Neoprene Production
Nitrile Butadiene Rubber Production
Non-Nylon Polyamides Production
Nylon 6 Production
Phenolic Resins Production
Polybutadiene Rubber Production
Polycarbonates Production
Polyester Resins Production
Polyethylene Teraphthalate Production
Polymerized Vinylidene Chloride Production
Polymethyl Methacrylate Resins Production
Polystyrene Production
Polysulfide Rubber Production
Polyvinyl Acetate Emulsions Production
Polyvinyl Alcohol Production
Polyvinyl Butyral Production
Polyvinyl Chloride and Copolymers Production
Reinforced Plastic Composites Production
Styrene-Acrylonitrile Production
Styrene-Butadiene Rubber and Latex Production
Production of Inorganic Chemicals
Category Name
Ammonium Sulfate Production-Captrolactam
By-Product Plants
.Antimony Oxides Manufacturing
Chlorine Production
Chromium Chemicals Manufacturing
Cyanuric Chloride Production
Fume Silica Production
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Appendix D
Hydrochloric Acid Production
Hydrogen Cyanide Production
Hydrogen Fluoride Production
Phosphate Fertilizers Production
Phosphoric Acid Manufacturing
Quaternary 'Ammonium Compounds Production
Sodium Cyanide Production
Uranium Hexafluoride Production
Production of Organic Chemicals
Category Name
Synthetic Organic Chemical Manufacturing
Miscellaneous Processes
Category Name
Aerosol Can-Filling Facilities
Benzyltrimethylammonium Chloride Production
Butadiene Dimers Production
Carbonyl Sulfide Production
Chelating Agents Production
Chlorinated Paraffins Production
Chromic Acid Anodizing
Commercial Dry Cleaning (Perchloroethylene)
Transfer Machines
Commercial Sterilization Facilities
Decorative Chromium Electroplating
Dodencanedioic Acid Production
Dry Cleaning (Petroleum Solvent)
Ethylidene Norbornene Production-
Explosives Production
Halogenated Solvent Cleaners
Hard Chromium Electroplating
Hydrazine Production
Industrial Dry Cleaning (Perchloroethylene)
Transfer Machines
Industrial Dry Cleaning (Perchloroethylene)
Dry-to-Dry Machines
Industrial Process Cooling Towers
OBPA/1,3-Diisocyanate Production
Paint Stripper Users
Photographic Chemicals Production
Phthalate Plasticizers Production
Plywood/Particle Board Manufacturing
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Appendix 0
Polyether Polyols Production
Pulp and Paper Production
Rocket Engine Test Firing
Rubber Chemicals Manufacturing
Semiconductor Manufacturing
Symmetrical Tetrachloropyridine Production
Tire Production
Wood Treatment
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