In October 2009, the EPA released new national air toxics standards for small to medium sized chemical manufacturing facilities that meet the “area source” definition (Subpart VVVVVV). More stringent air toxics (also known as NESHAP or MACT) standards currently exist for major sources in the chemical industry. Typically, the EPA grants up to three years for facilities to ensure compliance with newly issued MACT standards. One year has passed for this chemical industry standard and the effected companies should have already begun working towards compliance. The EPA listed nine chemical manufacturing sectors which the new standards regulate. Any new or existing facility in one of these categories that emits one or more of the specified urban air toxics must adhere to the standards. The nine sectors are:
Agricultural Chemicals and Pesticides Manufacturing
Cyclic Crude and Intermediate Production
Industrial Inorganic Chemical Manufacturing
Industrial Organic Chemical Manufacturing
Inorganic Pigments Manufacturing
Miscellaneous Organic Chemical Manufacturing
Plastic Materials and Resins Manufacturing
Synthetic Rubber Manufacturing
Of the 187 listed hazardous air pollutants (HAP), 15 were identified in the standards. These 15 are considered to present the greatest threat to public health from chemical industry area sources and include:
Approximately 450 existing chemical manufacturing area sources are affected by Subpart VVVVVV. The rule includes management practices for all process equipment, equipment leaks, storage tanks, and transfer operations. The final rule also includes leak inspections on a quarterly basis and generally available control technologies (GACT) standards for process vents, storage tanks, heat exchange systems, and wastewater systems. The new standards are anticipated to reduce air toxics nationwide by 248 tons per year and particulate matter by 570 tons per year at an annual cost of $3.2 million. Additionally, the final standards provide exemption to most chemical area sources from Title V permitting.
To review the EPA fact sheet on Subpart VVVVVV, click here. Additional EES Essential Elements articles on air toxics standards can be found here, here, and here. Check our archives for even more MACT standards discussions.
If your facility needs to meet these standards, EES can help you achieve full compliance. Please call me or Tom Petersen at 215-881-9401 for further details.