The United States Environmental Protection Agency (EPA) has proposed revisions to 40 CFR Part 63 Subpart CC, National Emission Standards for Hazardous Air Pollutants From Petroleum Refineries (Refinery MACT).1 This rule proposal is in response to EPA's statutory obligation to have performed both a residual risk assessment and a technology review for each MACT rule. EPA combined these two obligations into a single exercise referred to as risk and technology review (RTR). If this sounds like old news or imparts a sense of deja vu, it's understandable -we've been down this road before. In fact, EPA's residual risk assessment for Refinery MACT has been ongoing for over a decade, during which time multiple rule proposals have withered on the vine.
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