Miscellaneous Metal Parts Coating Maximum AchievableControl Technology (MACT) Overview and Application

摘要

As part of its obligation under Title III of the 1990 Federal Clean Air Act Amendments(FCAAA), the U.S. Environmental Protection Agency (EPA) promulgated the MiscellaneousMetal Parts Coating Maximum Achievable Control Technology (MACT) standard on January 2,2004. The standard, found in 40 CFR Part 63, Subpart MMMM, is intended to significantlyreduce the emissions of defined hazardous air pollutants (HAPs) below current levels. Onlymajor sources of HAPs are potentially subject to Subpart MMMM. A major source of HAPs is asite with a potential to emit 10 tons/yr of a single HAP or 25 tons/yr of all listed HAPs, in theaggregate. Sites with existing operations potentially subject to this subpart must comply with theregulation or take measures to become a minor source of HAPs prior to the January 2, 2007compliance date.To evaluate whether a facility is required to comply with Subpart MMMM, two steps must beconsidered. First, the entire site must be assessed to identify if it is a major source of HAPs. Ifthe site is major, the coatings used and subsequently, the individual coating operations must thenbe considered for applicability. The compliance options include: compliant materials and/orcoating emissions with and without controls.Sites may choose one of the compliance options or a combination of them. However, with theseoptions also come increased monitoring, recordkeeping, testing, and reporting requirements.Therefore, a fourth option[ PLD1] – becoming a synthetic minor HAP source prior to the January 2,2007 Subpart MMMM compliance deadline – may be a cost-effective alternative to MACTapplicability for some sites.This paper presents an overview of the miscellaneous metal parts coating MACT regulation andhow coating facilities may be affected by its requirements and outlines the analysis process byproviding an example of applicability assessments of several facilities and an analysis of if andwhen early installation of controls is an effective alternative to MACT applicability andcompliance.