Strategies To Achieve Compliance With The MON MACT Rule (40 CFR 63 Subpart FFFF)

摘要

The U.S. Environmental Protection Agency (USEPA) has been developing Maximum Achievable Control Technology (MACT) standards designed to reduce hazardous air pollutant (HAP) emissions from stationary emission sources since 1991. USEPA has drafted a rule geared towards batch chemical and certain continuous non-SOCMI facilities. The rule was proposed in early 2002 and regulates HAP emissions from process vents, storage tanks, wastewater streams, and fugitive equipment leaks. This paper presents several case studies of industry's attempts to develop early (pre-emptive) strategies to comply with the anticipated requirements of the MON rule. Once a reliable emissions inventory is established and the facility has determined that it is subject to the MON rule requirements, the appropriate compliance strategy must be selected. Compliance strategies considered for this paper include: 1. MON rule avoidance; 2. Maximum production fiexibility; 3. Emissions averaging plan; and 4. Emissions averaging plan with dedicated process controls. A matrix summarizing the principal findings associated with each compliance strategy is provided in Table 1.