Weston Solutions, Inc

MACT Monitoring, Recordkeeping, and Reporting - The Hidden Requirements

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Courtesy of Courtesy of Weston Solutions, Inc


The maximum achievable control technology (MACT) standards established under the national emission standards for hazardous air pollutants (NESHAPs) of 40 CFR 63 may include easily overlooked, sometimes onerous and questionably appropriate requirements incorporated by reference to the MACT General Provisions of 40 CFR 63, Subpart A. These requirements are easily overlooked during the comment periods because they do not appear important, if they are recognized at all, and review time is usually limited. Therefore, these “hidden” requirements may be rarely commented on regarding their practical implementation and value. Similarly, these requirements are also easily overlooked when a compliance strategy is being developed. The General Provisions, understandably, were apparently developed with large and complex sources and control devices in mind. However, the same provisions are often incorporated by reference into standards regulating much simpler sources and control devices. The potential problems are accentuated because of the limited time available both in standards development and in comment periods that make it difficult to address these incorporations by reference for practical implications and appropriateness. This paper outlines some of the consequences of this situation and suggests a more detailed and realistic assessment and awareness of these requirements.

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