
Since the early 1990's, industrial facilities have become accustomed to being required to comply to specific reporting, record keeping, and other Maximum Achievable Control Technology (MACT) standards that were defined in their Title V Operating Permit for any "major source". The Clean Air Act defines a “major source” as a one that emits, or has the potential to emit, 10 tons per year of any hazardous air pollutant, or 25 tons per year or more of any combination of hazardous air pollutants (HAPs). Sources with emissions below this threshold are classified as “area sources.” Different control standards apply to the source depending on whether or not it is classified as a “major source” or an “area source.”
Last week, the EPA issued a guidance memorandum withdrawing the “once in always in” policy for the classification of major sources of hazardous air pollutants under section 112 of the Clean Air Act. This decision allows industrial facilities the opportunity to reduce HAPs emissions to below major source levels and no longer be required to comply with the major source MACT standards.
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