Organizing MACT Recordkeeping and Reporting Requirements

摘要

Since 1993, EPA has promulgated nearly 2,000 pages of regulations dealing with facilities and processes that emit hazardous air pollutants. For the thousands of businesses affected by EPA's maximum achievable control technology (MACT) standards, the ongoing recordkeeping and reporting provisions included within these regulations are often very difficult to implement. Due to numerous cross-references and exceptions within the MACT standards, determining which requirements apply and under what conditions can be a daunting task. This paper describes a structured approach used to categorize the recordkeeping and reporting requirements of every MACT standard issued so far. The organizational approach relied on establishing a set of categories and subcategories. The recordkeeping and reporting categories and subcategories were chosen based on their applicability across the broad range of MACT standards. Once the categorization criteria were decided upon, each regulation was reviewed in detail, one-by-one, to identify all the recordkeeping and reporting provisions and assign them to categories and subcategories. Within a given standard, cross-references were dealt with by incorporating the cross-referenced provisions into the data tables for the regulation under review. In this way, a complete set of recordkeeping and reporting requirements, including those incorporated by reference, was produced for each standard. The organizational approach allowed applicable requirements to be identified based on the type of data or report involved. For example, all of the recordkeeping requirements associated with performance tests, including those only incorporated by reference, could be easily identified. The results of identifying and categorizing all the MACT recordkeeping and reporting requirements were presented in a set of easy to use, logically organized tables and spreadsheets that allow the user to quickly determine which requirements apply to their particular plant site. Through a detailed review of each regulation, and application of a standard set of categorization criteria, the recordkeeping and reporting requirements of EPA's MACT standards could be presented in an organized fashion.