The Area Source Mact/Gact Challenge

Dozens of new federal rules, regulating over 180 Hazardous Air Pollutants for relatively small sources, present a new and unique challenge for the air pollution profession.

Over the past two decades, a large number of federal regulations have been adopted to control Hazardous Air Pollutants (HAPs) originating from a wide range of source categories from the corner dry cleaner to petroleum refineries and steel mills. The majority of these standards apply to larger sources classified as “major sources”, although some older standards apply to smaller sources (classified as “area sources”) for such categories as Halogenated Solvent Cleaning and Chrome Plating. Over the past three years, a significant number of new rules have been adopted that specifically apply to area sources, which, by definition, are any sources with HAP emissions that are not major sources. These new regulations will affect a large number of smaller facilities and for many of these facilities the rules will pose significant challenges. Sources will be called on to make significant efforts to quantify HAP emissions, implement new control measures or work practices, and perform additional compliance monitoring activities. Many area sources may find the requirements to determine emission levels and to meet various technical and administrative requirements a significant new challenge since many of these smaller sources have not faced the requirements of complex federal regulations in the past. Sources will be well served to get “ahead of the curve” by performing technical and strategic evaluations before final compliance dates arrive.

Area Source Standards

EPA has compiled a list of source categories for which area source air toxic standards are necessary and must promulgate Maximum Achievable Control Technology (MACT) or Generally Available Control Technology (GACT) standards for each of these categories. These standards are intended to address a group of area sources that collectively represent 90 percent of the area source emissions of the 30 most hazardous air pollutants that present the greatest threat to public health in the largest urban areas. EPA prepared a list of 70 area source categories for which it intended to develop a standard, and prepared a schedule by which each of these standards would be promulgated. In March of 2006, the court established a schedule for the adoption of 50 area source rules with the last to have been completed by June 2009. As of June, EPA has completed most of these standards. These are shown in Table 1 along with the Subpart designation, promulgation (Federal Register) date, final compliance date and construction date defining new versus existing source classification. General information on the lists of area sources can be found at, Click here. Additional information on these standards along with links to the actual rules can be found at, Click here.

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