EPA-456/R-97-003

September 1997

http://www.epa.gov/ttn/uatw

MACT 

IMPLEMENTATION 

STRATEGY

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Research Triangle Park, North Carolina 27711
 ii

Acknowledgments

Members of the Air Toxics Implementation Strategy Development Team, Advisors, and

special participants contributing to the preparation of this document are:

ATIS Development Office

Team Member

Brian Beals EPA Region IV

Karen Blakemore Louisiana Department of Environmental Quality (DEQ)

Belinda Breidenbach Office of Enforcement and Compliance Assurance/Office of

Compliance 

Bob Colby Association of Local Air Pollution Control 

Officials/Chattanooga/Hamilton County Air Pollution Control

Bureau

Deborah Elmore Information Transfer and Program 

Integration Division/Information Transfer Group 

Charlie Garlow Office of Enforcement and Compliance Assurance/Office of

Regulatory Enforcement 

Kent C. Hustvedt Emission Standards Division/Waste and Chemical Processes Group

Bliss Higgins The State and Territorial Air Pollution Program

Administrators/Louisiana DEQ

Vasu Kilaru Emissions, Monitoring and Analysis Division/Air Quality Trends

Analysis Group

Linda Lay Office of Enforcement and Compliance Assurance/Office of

Regulatory Enforcement

Sheila Milliken Information Transfer and Program Integration Division/Integrated

Implementation Group

Doug Neeley EPA Region IV

Lee Page EPA Region IV

Joanna Swanson Information Transfer and Program Integration Division/Operating

Permits Group
ATIS Development Office

Team Member

Acknowledgments - Continued

 iii

Sara Terry Office of Air Quality Planning and Standards/Planning, Resources

and Regional Management Staff

Tony Wayne Emission Standards Division/Policy, Planning and Standards Group 

Gil Wood Information Transfer and Program Integration Division/Program

Review Group

Advisors Office

Karen Blanchard Information Transfer and Program Integration Division/Integrated

Implementation Group

Racqueline Shelton Information Transfer and Program Integration Division/Program

Review Group

ATIS Development Office

Special Participant

Julie Andresen Information Transfer and Program Integration Division/Program

Review Group

Phillip Barnett EPA Region IV

Gerri Pomerantz Information Transfer and Program Integration Division/Program

Review Group

Andy Smith Information Transfer and Program Integration Division/Program

Review Group

Ingrid Ward Information Transfer and Program Integration Division/Program

Review Group

Mary Ann Warner Information Transfer and Program Integration Division/Program

Review Group
 iv

Table of Contents

Section Page

Acknowledgments ........................................................... ii

List of Acronyms and Abbreviations ............................................ vii

Glossary ................................................................. ix

1.0 Introduction ........................................................ 1-1

1.1 Purpose of this Document ........................................ 1-3

1.2 Organization of this Document .................................... 1-3

1.3 Strategy Review and Measuring Success ............................ 1-4

2.0 Roles And Responsibilities Of Implementors ............................... 2-1

3.0 Systematic Communication ............................................ 3-1

3.1 Information Exchange .......................................... 3-2

3.2 Questions and Reaching Resolution ................................ 3-3

3.3 Scheduling ................................................... 3-4

3.4 Tracking ..................................................... 3-5

4.0 Elements of a Successful Implementation Strategy ........................... 4-1

4.1 Education .................................................... 4-1

4.2 Identifying the Source Population Subject to the MACT Standard ......... 4-3

4.3 Outreach .................................................... 4-4

4.4 Small Business Needs ........................................... 4-6

4.5 Compliance Assurance .......................................... 4-6

4.6 Enforcement .................................................. 4-9

4.7 Reference Materials ............................................ 4-9

4.8 Other ...................................................... 4-10

4.8.1 Resources ............................................. 4-10

4.8.2 Permitting ............................................. 4-11

5.0 Development of a Specific MACT Implementation Plan ....................... 5-1

5.1 Assessment of MACT Standards .................................. 5-2

5.1.1 Baseline Implementation Materials and Enhanced 

Implementation Materials .................................. 5-2

5.1.2 Interview with MACT Development Team and 

Representative Implementors ............................... 5-4

5.1.3 Diagnostic Questionnaire .................................. 5-5

5.1.4 Flow Charts for Enhanced Efforts ............................ 5-6

5.2 The Tool Development Agreement ................................. 5-6

5.3 Additional Elements of a Specific MACT Implementation Plan ............ 5-8
Table of Contents (continued)

 v

Appendices

Appendix A. Interview Questions for MACT Development Team and Implementors

Appendix B. Tool Development Agreement

Appendix C. Cost Estimates for Education and Outreach

Appendix D. Unified Air Toxics Website Information

Appendix E. AIRS Facility Subsystem Information

Appendix F. Example Specific Model Implementation Plan (for Ethylene Oxide Commercial

Sterilizers MACT Standard)

Appendix G. Source Identification Cookbook

Appendix H. Example Inspection Checklists

H1. Multimedia Inspection Checklist for Dry Cleaning Facilities

H2. Inspection Checklist for Chromium Electroplating and Anodizing

Appendix I. Contacts

I1. Regional Air Toxics Coordinators

I2. OAQPS and OECA NSPS and NESHAP Contacts

Appendix J. Small Business Regulatory Enforcement Fairness Act (SBREFA)

Appendix K. Master Compliance Timeline for Part 63 NESHAP

Appendix L. MACTRAX
 vi

List of Tables

Page

1-1 Primary Implementation Roles During MACT Processes ................... 1-6

2-1 OAQPS Roles and Responsibilities .................................... 2-4

2-2 OECA Roles and Responsibilities ..................................... 2-7

2-3 Regional Office Roles and Responsibilities .............................. 2-8

2-4 State/Local/Tribal Roles and Responsibilities ............................ 2-9

5-1 Model Tool Development Agreement ................................. 5-17

List of Figures

1-1 A Roadmap to Successful MACT Implementation ........................ 1-7

3-1 Many Opportunities for Information Exchange ........................... 3-6

3-2 Communication Agenda ............................................ 3-7

3-3 Example MACT Standard Implementation Timeline ....................... 3-8

3-4 Implementation Issue Resolution Process .............................. 3-10

5-1 Process for Developing a SMIP ..................................... 5-10

5-2 Questionnaire for Determining Whether Materials Beyond the Baseline Level 

are Needed ..................................................... 5-11

5-3 Flow Chart For Determining If Enhanced Technical Training Is Necessary ..... 5-13

5-4 Flow Chart For Determining If Enhanced Source ID/Notification Is Necessary . . 5-14

5-5 Flow Chart For Determining If Enhanced Public Outreach Is Necessary ....... 5-15

5-6 Flow Chart For Determining If Enhanced Small Business Assistance Is 

Necessary ...................................................... 5-16
 vii

List of Acronyms and Abbreviations

AFS AIRS Facility Subsystem

AIRS Aerometric Information Retrieval System

AQSSD Air Quality Strategies and Standards Division

ATIS Air Toxics Implementation Strategy

CBEP Community-Based Environmental Programs 

EMAD Emissions Monitoring and Analysis Division

ESD Emission Standards Division

ITPID Information Transfer and Program Integration Division

MACT Maximum Achievable Control Technology

MACTRAX MACT Tracking System

MWC Municipal Waste Combustion

MWI Medical Waste Incineration

NESHAP National Emission Standards for Hazardous Air Pollutants

NETI National Enforcement Training Institute

OAQPS Office of Air Quality Planning and Standards

OECA Office of Enforcement and Compliance Assurance

OGC Office of General Counsel

ORE Office of Regulatory Enforcement

PRG Program Review Group

PRRMS Planning, Resources, and Regional Management Staff

PTE Potential to Emit

RATC Regional Air Toxics Coordinator
List of Acronyms and Abbreviations (continued)

 viii

RO Regional Office

SBAP Small Business Assistance Program

SBREFA Small Business Regulatory Enforcement Fairness Act

SMIP Specific MACT Implementation Plan

STAPPA/ALAPCO State and Territorial Air Pollution Program Administrators/Association of

Local Air Pollution Control Officials

TDA Tool Development Agreement

TTN Technology Transfer Network
 ix

GLOSSARY

Air Toxics - Any air pollutant for which a national ambient air quality standard (NAAQS) does

not exist (i.e., excluding ozone, carbon monoxide, PM-10, sulfur dioxide, nitrogen dioxide, and

lead) that may reasonably be anticipated to cause cancer, developmental effects, reproductive

dysfunctions, neurological disorders, heritable gene mutations or other serious or irreversible

chronic or acute health effects in humans.

Delegation - The act of conferring upon a state or local agency, the ability to implement and

enforce federal standards and requirements. The EPA retains concurrent enforcement authority.

Education - Activities, materials, and tools prepared mainly to help the implementors understand

the standard, locate sources, or otherwise implement the standard.

Enabling Materials - Activities, items, or tools prepared mainly for the industry being regulated.

Implementation - Putting into action, carrying out, and completing the activities that promote

compliance with the MACT standard. 

Implementation Materials - Activities, items, or tools prepared mainly for implementors with

specific information about the standard and the source being regulated. 

Implementation Plan - A plan of action designed to promote compliance with the MACT

standard by identifying concrete measures, including preparation of implementation materials.

Implementors - The government agencies responsible for ensuring compliance with the MACT

standard or its approved equivalent.

MACT Partnership - An agreement between the EPA and a region/state/local agency or tribal

entity to share the responsibility of MACT standard development. EPA works with STAPPA, 

ALAPCO and others to identify opportunities for partnerships for source category specific

regulations. The “Share-a-MACT” process is led by EPA with contribution from state and local

agencies and industry. The “Adopt-a-MACT” process is led by a region, state or local agency or

tribal entity with minimal contributions from EPA headquarters. EPA headquarters reviews,

approves, and promulgates the standard.

Maximum Achievable Control Technology (MACT) Standards - Emissions limitations

developed under section 112(d) of the Clean Air Act (National Emissions Standards for

Hazardous Air Pollutants). The limitations are based on the best demonstrated control

technology or practices in similar sources to be applied to major sources emitting one or more of

the listed toxic pollutants. This term is sometimes incorrectly used as a colloquialism to refer to

other technology-based emissions standards developed by the Emission Standards

Division/OAQPS.

Outreach - Activities, materials, or tools prepared mainly to locate affected industries or to

educate those industries and the general public. 
 x

SBREFA Guidance Document - A document to help small businesses understand the

requirements of a standard. Such documents are required by the Small Business Regulatory

Enforcement Fairness Act when a standard may have significant effects on small businesses. See

Appendix J.

Specific MACT Implementation Plan (SMIP) - A specific MACT Implementation Plan that

has been agreed upon by all involved parties, which clearly identifies tools, implementation

materials, roles and responsibilities of implementors, and a schedule for the implementation of a

MACT standard. Contains a Tool Development Agreement.

Tool Development Agreement (TDA) - A table of implementation materials potentially

developed for each MACT standard with assignment of the lead group for each item and

participants in the development of each item. 
 1-1

Section Summary

The purpose of this document is to present a strategy for activities that, if

followed, should be helpful in ensuring that MACT standard emissions

reductions are achieved. This strategy is not mandatory, but does represent the

collective wisdom of many regulators and implementors as to activities that

should be worthwhile. Many of the activities are those that EPA, states and

local agencies have already been using successfully for some standards and

should be successful for other standards as resources allow. This is a “living”

document. That is, as more implementation experience is obtained, EPA will

make appropriate revisions. Communication and coordination among the

implementors is essential.

1.0 INTRODUCTION

Section 112 of the Clean Air Act (CAA) has nineteen subsections [section 112(a) through

section 112(s)] with requirements pertaining to protection of the public and the environment from

adverse effects resulting from the use of and exposure to air toxics . The subsections include

many specific requirements regarding federal, state, local, and tribal programs (e.g.,

section 112(l), which applies to development and approval of state air toxics programs and

delegation of federal authorities; or section 112(r), which applies to accidental releases of air

toxics).

Separate from the effort to prepare this document, the Office of Air Quality Planning and

Standards (OAQPS) has developed a draft air toxics management model which addresses the

interrelationships of these nineteen subsections and their requirements. The draft model

incorporates setting goals, identifying necessary emission reductions, implementing emission

reduction and pollution prevention plans, and evaluating results. Currently, OAQPS is in the

process of developing the goals and performance measures. Other major efforts by OAQPS

include integration of section 112 air toxics requirements with other CAA programs such as the

Title V Operating Permit Program and the New Source Review/Prevention of Significant

Deterioration Program (NSR/PSD).
 1-2

The Air Toxics Implementation Strategy (ATIS) development team was originally formed

to develop a comprehensive plan of activities that should be helpful for implementors to ensure

that the emissions reductions from standards developed under section 112 are actually achieved.

However, since the air toxics management model is still draft and the goals and performance

measures are still under development, the team decided this document should focus on the

implementation of Maximum Achievable Control Technology (MACT) standards, the

cornerstone of the federal air toxics program. That is, two very high priorities for EPA are the

development and implementation of MACT standards. Many of the elements in the strategy are

intended to add administrative efficiencies and reduce duplicative efforts in the MACT

implementation process. Some of the early tasks of the ATIS development team focused on

developing checklists and other tools to ensure that implementation aspects are fully considered

during the development of MACT standards (e.g., efficient and effective integration with Title V

and other programs). However, those tools are not the focus of this document and thus, are not

appended. 

Rather, this document focuses on several issues related to MACT implementation,

including the development of implementation plans, communication and coordination issues, and

allocation of different implementation tasks to specific federal, state, local, tribal, and other

entities. This document is available to all affected government entities and may serve as a

template or model for how the various stakeholders may work together to effectively and

efficiently implement MACT standards. Table 1-1 provides a general overview of different phases

of MACT development and implementation and identifies the primary roles of the responsible

entities during each phase. Figure 1-1 presents graphically the MACT implementation process.

Other important air toxics issues such as integration of MACT implementation with other

air toxics programs (e.g., residual risk standards) and integration of air toxics programs with

criteria pollutant programs are not addressed in this document, but rather will be discussed in a

future document. 
 1-3

1.1 Purpose of this Document

The purpose of this document is to provide a strategy for successful implementation of

MACT standards. This document provides helpful information for efficient and effective

promotion of compliance with MACT standards or their approved equivalents, by helping

implementors decide what should be done, who should do it, and when it should be done. This

document was developed for implementors (government entities tasked with ensuring compliance

with MACT standards); however, industry and the public may find some of the information useful

as well. This document includes recommendations for how to prepare a Specific MACT

Implementation Plan (SMIP) for a MACT standard. This document describes the elements of

such plans and roles and responsibilities of the implementors. It also includes a systematic

communication process for promoting an adequate understanding of the MACT standards and for

coordinating implementation activities. This document is intended to assist implementors by

outlining critical success factors and by identifying recommended materials and activities. 

These recommendations are flexible. This document provides information for the

implementors to identify appropriate implementation activities and ways to accomplish these

activities. EPA anticipates that the implementors will consider the information presented in this

document while they structure their strategy to meet their specific needs. For example, a

relatively simple standard affecting few sources in only one state may require less effort in

development of outreach brochures and other implementation tools than a complex standard with

numerous, small, affected sources located in many states.

1.2 Organization of this Document

Section 2.0 of this document describes the roles and responsibilities of implementors and

Section 3.0 briefly describes communications that need to occur systematically for implementation

efforts to have the highest likelihood of success. Section 4.0 describes implementation elements

that should be considered when developing a SMIP. Section 5.0 describes a method for

determining which implementation elements are appropriate for a SMIP and describes the

preparation of a Tool Development Agreement (TDA). Table and figures are found at the end of
 1-4

the appropriate section to avoid interruptions in the text. Example interview questions are

included (see Appendix A) to help in deciding which implementation materials and activities are

appropriate for each MACT standard. 

Reference materials and examples that implementors may find useful when developing

SMIPs are included in the appendices of this document. For example, a SMIP for the Ethylene

Oxide Commercial Sterilizers standard is included, as well as inspection checklists for dry cleaning

and chromium electroplating facilities. 

1.3 Strategy Review and Measuring Success

The strategy presented in this document was developed by the ATIS development team

along with the managers of their respective organizations as participants, and others as informal

contributors. This strategy is considered a “living document” and comments are welcome. In

addition, information on air toxics implementation successes and example implementation tools

that can be shared with others is especially welcome. EPA and STAPPA/ALAPCO strongly

encourage state, local, and tribal entities to share their implementation tools and place them on the

EPA/STAPPA/ALAPCO Unified Air Toxic Website (see Appendix D for further information

about the website). Comments and information may be sent to the following address:

Mr. Gil Wood 

Program Review Group (MD-12)

Information Transfer and Program Integration Division

Office of Air Quality Planning and Standards

U.S. Environmental Protection Agency

Research Triangle Park, North Carolina 27711

Email: wood.gil@epamail.epa.gov

Implementation of MACT standards is included in the EPA Annual Performance Plans and

Annual Program Performance Reports, as required by the Government Performance and Results

Act and as a priority in the Performance Partnership Agreements between EPA and the states. 

Mechanisms are being developed to measure and track implementation results. Also, EPA will

evaluate the usefulness of this document, and update or revise it as needed. A critical success

factor for implementation activities is that the affected sources and implementors understand the
 1-5

rules, policies, and protocols they are required to implement, including the compliance

requirements and when necessary, the appropriate enforcement response policies. Thus, the

availability of tools to assist in gaining this understanding and in assuring compliance is an

important part of this strategy. This document serves as one of the tools and as a reference to

other tools that should assist the implementors in their efforts.
1-6

Table 1-1. Primary Roles During MACT Development and Implementation 

Phase Headquarters Role Regional Office Role State/Local/Tribal Role Private Sector

Data Gathering Form MACT development Participate in MACT Participate in MACT Provide representative data

team Partnerships and Work Partnerships and Work

Determine data needs

Groups Groups

Proposal Develop MACT Participate in MACT Participate in MACT Review/Comment

Help develop SMIP Groups Groups

Partnerships and Work Partnerships and Work

Review/Comment Review/Comment

Lead development of SMIP Help develop SMIP 

Plan outreach efforts

Promulgation Lead preparation of TDA Participate in preparation of Participate in preparation of Participate in preparation of

Complete development of

MACT Encourage delegation Implement Develop compliance plan

TDA TDA TDA

Compliance Track implementation Track implementation Conduct outreach activities Submit initial notification

Conduct compliance Comply 

assistance activities

Ensure compliance

Continuous Compliance Provide guidance on residual Track compliance Track compliance Continuously comply

risk

Enforce, as needed Inspect Keep records, monitor, and

Enforce, as needed

certify annually

SMIP = Specific MACT Implementation Plan

TDA = Tool Development Agreement
o:\s\g\morisvle\73976599\roadcole.ai

Development of MACT Standards

that can be Implemented 

Efficiently and Effectively 

and that Achieve the

Requirements of the CAA 

Consistent with EPA Goals

Identification 

and Assignment 

of Roles and 

Responsibilities 

for Implementors

Development of 

Specific MACT 

Implementation 

Plans

Development of 

Implementation 

Materials in 

Accordance with Tool 

Development Agreement

Continuation of 

Implementation 

Activities 

Compliance 

Assistance 

Provided, 

as Needed

Enforcement 

Activities, 

as Necessary

Clean Air Act (CAA)

Regulatory 

Authority

Compliance

With 

MACT 

Standard

 1-7

Figure 1-1. A Roadmap to Successful MACT Implementation
 2-1

Section Summary

This section identifies key players in the implementation process and defines

their roles and responsibilities.

2.0 ROLES AND RESPONSIBILITIES OF IMPLEMENTORS

This section provides recommended general roles and responsibilities of implementors in

the MACT implementation process. It is important for the implementors to communicate clearly

with each other and agree to specific roles and responsibilities for each MACT standard. 

Regardless of who is ultimately responsible for each implementation task, it is important to

thoroughly identify the tasks to be completed, who will complete them, and the schedule for

completing them. The Office of Air Quality Planning and Standards (OAQPS) Program Review

Group (PRG) will take the lead in ensuring that a timely and systematic process is established. 

Also during MACT development, PRG will conduct an interview with the MACT development

team lead and representative implementors using the list of questions presented in Appendix A or

similar questions to make a preliminary determination of expected implementation needs.

The details of this section are primarily contained in Tables 2-1 through 2-4, which

identify and assign the numerous roles and responsibilities recommended to implement a MACT

standard. Although the implementors may agree to different roles and responsibilities for a

specific MACT, the rationale behind these recommended roles and responsibilities is explained in

this section.

Successful implementation of MACT standards is a large undertaking and requires

significant time and resources. First, there should be well-defined emission standards that achieve

the requirements of the CAA, are consistent with EPA goals, and are designed to be implemented

as efficiently and effectively as possible. All of the stakeholders, but especially the regional offices

and state, local, and tribal entities, should consider implementation aspects while the standards are 

being developed. Ideally, there will be agreement among all of the stakeholders on the standards

and implementation aspects, and there will be a good faith effort by industry to comply. To
 2-2

bridge the gap between MACT standard development and industry-wide compliance,

implementors (in particular EPA [OAQPS, Office of Enforcement and Compliance Assurance

(OECA), Regional Offices], and state, local, and tribal entities) should complete three

broad-based tasks: 

C Identify the affected regulated sources;

C Inform the affected regulated sources so that they may determine which

requirements apply to them, and understand how to comply with the

requirements; and

C Monitor and assure compliance.

The ultimate responsibility for completing these three tasks is generally delegated to the

state, local, or tribal entity. Considering the burden on the implementors and the similarity of their

needs, it is prudent for them to share the development of implementation tools and other

information, where possible. The primary groups typically responsible for MACT standard

implementation support are:

C Emission Standards Division (ESD)/OAQPS/EPA;

C Information Transfer and Program Integration Division (ITPID)/OAQPS/EPA;

C Emissions Monitoring and Analysis Division (EMAD)/OAQPS/EPA;

C EPA Regional Offices;

C Office of Regulatory Enforcement (ORE)/OECA/EPA;

C Office of Compliance (OC)/OECA/EPA; and

C Air Office of state, local, and tribal entities (including both environmental

agencies and small business assistance offices).

To help the permitting authorities ensure that the three broad-based implementation tasks

mentioned above are successfully completed, the tasks are further subdivided into well-defined

subtasks that are assigned to specific parties. These subtasks and assignments are detailed in

Table 2-1, OAQPS Roles and Responsibilities; Table 2-2, OECA Roles and Responsibilities;
 2-3

Table 2-3, Regional Office Roles and Responsibilities; and Table 2-4, State and Local Offices

Roles and Responsibilities. The roles and responsibilities detailed in Tables 2-1 through 2-4 focus

primarily on activities that take place during or soon after MACT standard development. 

Note that while Tables 2-1 through 2-4 are detailed and explicit, they are intended to be

flexible. That is, the implementors should carefully consider all of the recommendations in this

MACT implementation strategy and agree on changes as appropriate to fit their specific

circumstances. Nonetheless, these tables provide an initial plan of action that identifies subtasks

and assignments currently envisioned for implementation of a MACT standard. Implementor

experiences have demonstrated that a detailed initial plan, ongoing review of execution of the

plan, and feedback mechanisms for adjustments to the plan are prudent for effective

implementation. 
AQSSD = Air Quality Strategies and Standards Division PRRMS = Planning, Resources, and Regional Management Staff

EMAD = Emissions, Monitoring and Analysis Division SBREFA = Small Business Regulatory Enforcement Fairness Act

ESD = Emission Standards Division

ITPID = Information Transfer and Program Integration Division

OECA = Office of Enforcement and Compliance Assurance

2-4

Table 2-1. OAQPS Roles And Responsibilities

Activities ITPID ESD EMAD AQSSD PRRMS

Develop MACT Provides input on: Develops MACT’s that Provides input on test Reviews MACT data Promotes Regional

- Integration with other achieve the requirements of methods and monitoring for coordination with office and state

programs, as needed the CAA, are consistent future residual risk participation through

- Potential to Emit with EPA goals, and are standards such as memorandum of

- § 112(l) issues designed to be Great Waters agreement and

implemented as effectively Programs, Urban Air performance

and efficiently as possible Toxics Strategy, etc. partnerships 

Prepare SBREFA Compliance Provides input and Develops documents with Provides input, as Provides input, as Provides input, as

Assistance Guides and other coordinates with other input from OECA on necessary (e.g., source necessary (e.g., health necessary (e.g., planning

small business outreach materials Small Business assistance compliance assistance testing and monitoring) and environmental and resources)

for area source standards and efforts and assists with activities effects)

small businesses distribution of materials 

Prepare a Specific MACT Leads team effort to Provides team member Provides team member Provides team Provides team member

Implementation Plan (SMIP) for develop SMIP according to member

each standard that includes: MACT Implementation Ensures technical accuracy Provides input on source

- How to identify sources strategy that clarifies roles of SMIP test methods and

- Summary of requirements and lays out process for monitoring 

- Applicability tables setting priorities and

- Compliance checklist systematic communication

- Permit requirements

Develop training materials and Provides vehicle for Provides technical experts Provides technical experts Provides scientific Provides development

classes on newly promulgated training and develops to lecture and review to lecture and review experts to lecture and plan, expertise, and

standards course materials materials materials relating to source review materials Regional office

testing and monitoring relating to health and coordination (e.g., Desk

environmental effects Officers)

Issue specific implementation Prepares guidance Provides technical experts Provides technical experts Provides experts to Coordinates with ITPID

guidance where needed (e.g., (documents or policy to participate in as appropriate answer health and on policy and guidance

section 111(d)/129 State Plans memoranda) development of supporting environmental effects availability

for Municipal Waste guidance questions, when

Combustors) needed Desk Officer assures

communication with the 

Regional office
2-5

Table 2-1. OAQPS Roles And Responsibilities (continued)

Activities ITPID ESD EMAD AQSSD PRRMS

AQSSD = Air Quality Strategies and Standards Division PRRMS = Planning, Resources, and Regional Management Staff

EMAD = Emissions, Monitoring and Analysis Division SBREFA = Small Business Regulatory Enforcement Fairness Act

ESD = Emission Standards Division

ITPID = Information Transfer and Program Integration Division

OECA = Office of Enforcement and Compliance Assurance

Coordinate efforts with other Identifies obstacles to Participates as needed, Participates as needed, Participates as Participates as needed,

implementing offices such as implementation, takes steps answers questions on provides technical needed, provides input on

OECA, Regional offices, states, to overcome obstacles, technical and policy expertise as appropriate provides technical Regional office, state,

locals, and tribes facilitates conference calls, aspects of rules expertise, as local and tribal needs

workshops, visits, etc. appropriate

Report on National Progress in Prepares reports and Establishes goals for Helps develop goals, Helps develop goals, Helps develop

meeting goals provides system operator MACT standards and review progress, refine review progress, information systems and

for information performance measures goals, and overcome refine goals, and encourages participation

management system - determines what reports obstacles overcome obstacles of regions, states, local

Helps develop goals, - receives reports

review progress, refine Helps develop goals,

goals, and overcome Leads development of review progress, refine

obstacles goals and priorities, goals, and overcome

are needed and tribal entities

reviews progress, refines obstacles

goals, and overcomes

obstacles. Ensures

coordination of priorities

among program offices,

Regions, OECA and states,

local and tribal entities.

Develop and maintain Provides and maintains Provides information on Provides information for Provides information Provides information for

communication networks Internet website and MACT for website website for website Internet websites in

coordinates responses as coordination with ITPID

needed Responds to questions Responds to questions Responds to

questions

Prepare enabling documents, and Coordinates the preparation Develops enabling Provides input on source Provides input on Provides input on

implementation documents and of implementation documents for industry, as testing and monitoring as health and readability and

tools documents and tools necessary appropriate environmental effects relationship to overall

Reviews for "Readability" Provides input to ITPID for management

implementation documents

and tools

as appropriate planning and
2-6

Table 2-1. OAQPS Roles And Responsibilities (continued)

Activities ITPID ESD EMAD AQSSD PRRMS

Ensure MACT Delegations and Coordinates Program and Provides expertise on Provides expertise on test Provides expertise as Coordinates with

approval of state rules and Rule Equivalency reviews MACT rule specifics and methods and monitoring as needed Regional offices

programs under Section 112(l) with other Divisions, equivalency needed

OECA, and Regional

offices 

Participate in monthly Air Toxics Coordinates EPA Participates in monthly Participates in monthly Participates in Participates in monthly

Implementation calls with EPA participation in monthly calls as needed calls as needed monthly calls as calls as needed

Regions to exchange relevant calls needed

experiences, to help other

implementors, and to resolve

issues

Provide guidance on Title V Provides guidance on Provides expertise on Provides expertise on test Provides expertise as Coordinates with

permitting and other means to permitting and other means MACT rule specifics and methods and monitoring needed Regional offices

ensure emission reductions to ensure emissions flexibility

reductions

AQSSD = Air Quality Strategies and Standards Division PRRMS = Planning, Resources, and Regional Management Staff

EMAD = Emissions, Monitoring and Analysis Division SBREFA = Small Business Regulatory Enforcement Fairness Act

ESD = Emission Standards Division

ITPID = Information Transfer and Program Integration Division

OECA = Office of Enforcement and Compliance Assurance
2-7

Table 2-2. OECA Roles And Responsibilities

Office Of Regulatory Enforcement Office Of Compliance National Enforcement Training Institute

 (ORE) (OC) (NETI)

Participates in development of goals, priorities, and Participates in development of goals, priorities, and Participates in development of goals, priorities, and

tracking of results. tracking of results. tracking of results.

Develops enforcement response policy for toxics, including

penalty policies, as needed

Provides enforcement assistance to Regional offices Provides compliance assistance to Regional offices Provides enforcement training

Reviews and provides input on SBREFA guides and

enabling documents, as appropriate

Provides compliance checklists and implementation Conducts inspector training

manuals for inspectors

Answers questions from Regional office on applicability Answers questions from Regional offices on applicability

determinations determinations (coordinates with OAQPS and OGC as

appropriate). Compiles answers on Applicability

Determination Index (ADI) on website 

Supports development of section 112 rules, including Supports development of MACT standards to ensure

MACT standards to ensure enforceability enforceability

Participates in regular calls and meetings with OAQPS and Participates in regular calls and meetings with OAQPS

Regional offices and Regional offices

Tracks compliance in conjunction with Regional offices,

states, local and tribal entities 

OAQPS = Office of Air Quality Planning and Standards

OGC = Office of General Counsel

SBREFA = Small Business Regulatory Enforcement Fairness Act
2-8

Table 2-3. Regional Office Roles And Responsibilities

Activities Programs Branch Compliance Branch

Processes 112(l) submittals Processes submittals

Delegates MACT standards Encourages delegation

Completes delegation

Tracks delegation

Conducts outreach to states and sources Conducts outreach as needed to states and Conducts outreach to states and sources as

sources needed 

Provides compliance assistance to states and sources Provides compliance assistance to states

and sources as needed

Ensures that agencies track and report compliance Assists agencies with tracking and

reporting compliance

Conducts inspections and takes enforcement actions Inspects and enforces as necessary

Implements standards and requirements prior to delegation and where states Implements as necessary Implements as necessary

and tribes do not take delegation

Makes 112(g) determinations when necessary Implements 112(g) as necessary Implements 112(g) as necessary

Reviews state plans under section 112(d) and/or section 129 Reviews plans as necessary Reviews plans as necessary

Works with OAQPS, OECA and states with program goals Assists OAQPS, OECA, and states with goals as Assists OAQPS, OECA, and states with

necessary goals as necessary 

Reviews Title V permits and other means to ensure MACT’s are implemented Reviews permits and other means as necessary Reviews permits and other means as

necessary

Reports to Headquarters on status of program implementation Provides Headquarters reports on program

implementation

Provides guidance and responds to technical and policy questions from states, Provides assistance as necessary Provides assistance as necessary

local, and tribal entities on toxics-related issues

Provides assistance to states on applicability determinations Coordinates applicability determinations with Provides input to Programs Branch

OECA, OAQPS, and OGC

Submits determinations in appropriate format to Applicability Determination Supplies Applicability Determination Index Supplies Applicability Determination Index

Index information as necessary information as necessary

Assists Headquarters in rule and guidance document development, including Assists Headquarters as necessary with rule and Assist Headquarters as necessary with rule

Adopt-A-MACT guidance document development and guidance development

Participates in monthly Air Toxics calls with OAQPS, OECA, other Regional Participates in monthly air toxics calls Participates in monthly Air Toxics calls

offices, and state, local, and tribal entities

* The apportioning of the activities within the regional office in this chart is an example that will vary according to the organizational structure of the specific entities.
NESHAP = National Emission Standard for Hazardous Air Pollutant STAPPA/ALAPCO = State and Territorial Air Pollution Program

OECA = Office of Enforcement and Compliance Assurance Administrators/Association of Local Air

Pollution Control Officials

2-9

Table 2-4. State/Local/Tribal Roles And Responsibilities

Activities Air Toxics Section Permits Section Program Section

Small Business Assistance Enforcement/Surveillance

Participate in MACT and other Provides expertise and real- Provides expertise and Provides expertise and Provides expertise and real-world

Section 112 program development world experiences real-world experiences real-world experiences experiences

activities

Participates in possible pilot

testing of specific proposed

MACT’s at Work Group

closure

Participates in Presumptive

MACT and Adopt-a-MACT

programs

Review schedule of upcoming Plans work load Plans work load Plans work load Plans work load

regulations and requirements and

plan work load

Review regulations, fact sheets, Leads state activities and Provides input to Air Provides input to Air Toxics Provides input to Air Toxics Section

implementation guidance, and efforts and requests input Toxics Section as needed Section as needed as needed

other relevant information on the from other sections as

STAPPA/ALAPCO/EPA Unified needed

Air Toxics Website.

Delegate authority Determines if delegation will Coordinates with Air

be requested Toxics Section

Coordinates with Regional

office 

Requests delegation

- delegation agreement

- state rulemaking 

Locate and identify sources Uses procedures in Source Provides helpful Assists in identifying sources Provides assistance when necessary

Identification Cookbook to information to Air Toxics

find sources Section

Coordinates with Regional

office to share information 
2-10

Table 2-4. State/Local/Tribal Roles And Responsibilities (continued)

Activities Air Toxics Section Permits Section Program Section

Small Business Assistance Enforcement/Surveillance

NESHAP = National Emission Standard for Hazardous Air Pollutant STAPPA/ALAPCO = State and Territorial Air Pollution Program

OECA = Office of Enforcement and Compliance Assurance Administrators/Association of Local Air

Pollution Control Officials

Conduct outreach and training for After sources are identified, Provides input to Air Sets up and provides input Provides assistance when necessary

affected sources, as well as other - distributes EPA guidance Toxics Section and support in outreach and

compliance assistance activities - coordinates with Small training for small businesses

Business Assistance

Program Visits sites

- contacts sources

- surveys sources

Make applicability determinations Same system as Part 61 Provides input to Air Provides assistance when

such as Potential to Emit NESHAP (i.e., coordinates Toxics Section necessary

determinations with other sections and

Regional office per

memorandum of agreement)

Inputs information into the

Applicability Determination

Index on website

Develops compliance

tracking system

Coordinates with OECA and

regional office

Make compliance determinations Coordinates with Provides input as Coordinates with Air Toxics Section

and regulatory interpretations Enforcement Section and necessary and Regional office

Regional office

Tracks determination and

provides information to

Regional offices as

necessary
2-11

Table 2-4. State/Local/Tribal Roles And Responsibilities(continued)

Activities Air Toxics Section Permits Section Program Section

Small Business Assistance Enforcement/Surveillance

NESHAP = National Emission Standard for Hazardous Air Pollutant STAPPA/ALAPCO = State and Territorial Air Pollution Program

OECA = Office of Enforcement and Compliance Assurance Administrators/Association of Local Air

Pollution Control Officials

Permit sources Provides training and Writes permit Provides assistance when Reviews permit prior to approval

information and answers necessary

questions

Reviews permit prior to

approval

Make Section 112(g) Develops state program and Coordinates with Air Coordinates with Air Toxics Coordinates with Air Toxics Section

determinations implements it accordingly Toxics Section Section

Conduct compliance inspections Provides mechanism to Coordinates with EPA Federal Conducts source inspections, writes

include sources in inspection Small Business Assistance inspection report, and recommends

schedule Program contacts to provide enforcement action

Provides training/assistance

when necessary

Reviews compliance reports

compliance assistance

Take enforcement actions where Submits, follows through, Coordinates with Federal Coordinates with Air Toxics Section

appropriate and tracks enforcement Small Business Assistance on recommended enforcement action 

requests to Enforcement/ Program 

Surveillance Section Takes enforcement action

Has no involvement in 

enforcement activities

May give 90 days to 1 year

“corrective period”
2-12

Table 2-4. State/Local/Tribal Roles And Responsibilities(continued)

Activities Air Toxics Section Permits Section Program Section

Small Business Assistance Enforcement/Surveillance

NESHAP = National Emission Standard for Hazardous Air Pollutant STAPPA/ALAPCO = State and Territorial Air Pollution Program

OECA = Office of Enforcement and Compliance Assurance Administrators/Association of Local Air

Pollution Control Officials

Review permit applications, plans, Assigns MACT standards to Reviews applications and Provides input when Provides assistance in contacting

and reports staff issues construction/ necessary source or sharing knowledge of

reconstruction permits standard as needed

Evaluate testing and monitoring Reviews and tracks requests

results, and compliance extension and reports

waivers

Review initial notifications, information as needed

implementation plans, and periodic

reports Recommends enforcement

Requests additional

as needed

Provide assistance to small Coordinates with Small Provides input as needed Provides assistance as needed Provides assistance when necessary

businesses Business Assistance

Program

Report to EPA Regional office on Discusses with EPA Provides input to Air Provides input to Air Toxics Provides input to Air Toxics Section

progress of implementing program obstacles requiring attention Toxics Section as needed Section as needed as needed

and identify obstacles prior to submittal of report

Prepares report

Coordinates with other

sections

Participate in monthly Air Toxics Coordinates and participates Participates in monthly Participates in monthly calls Participates in monthly calls as needed

Implementation calls with in monthly calls calls as needed as needed

Regional office and monthly calls

with STAPPA/ALAPCO to

exchange relevant experiences and

to help implementors resolve

issues
2-13

Table 2-4. State/Local/Tribal Roles And Responsibilities(continued)

Activities Air Toxics Section Permits Section Program Section

Small Business Assistance Enforcement/Surveillance

NESHAP = National Emission Standard for Hazardous Air Pollutant STAPPA/ALAPCO = State and Territorial Air Pollution Program

OECA = Office of Enforcement and Compliance Assurance Administrators/Association of Local Air

Pollution Control Officials

Track compliance and reports to Provides input to the Provides input to the Provides input to the Leads state efforts to track compliance

databases Enforcement/Surveillance Enforcement/Surveillance Enforcement/Surveillance

Section as needed Section as needed Section as needed

All of the activities presented here should be included in the roles of the state, local, and tribal entity office. The apportioning of the activities within the state, local, or a

tribal offices in this chart is an example that will vary according to the organizational structure of the specific entities.
3-1 

Section Summary

This section discusses the protocol for successful MACT implementation 

strategy communications, which include PRG’s roles, including the lead for

coordinating implementation tool development activities, how information

should flow among stakeholders, the process to resolve issues, the process to

schedule and track progress, and the Regional Air Toxics Coordinator’s roles

after promulgation. 

3.0 SYSTEMATIC COMMUNICATION

This section describes the recommended Systematic Communication protocols necessary

for successful completion of the MACT implementation strategy. These recommended protocols

serve to ensure that stakeholders transfer critical information in a complete and timely manner.

The need for systematic protocols is underscored by several factors:

C The Air Toxics Program is broad-based, affecting numerous stakeholders in the public,

industrial, and regulatory sectors. 

C The large number and variety of stakeholders makes communication inherently

difficult to manage; systematic communication will ensure the transfer of critical

information that might otherwise be lost via informal communication.

C The MACT standards will be written and implemented over several years; the lessons

learned during the development and implementation of early MACT standards will

facilitate the development and implementation of later MACT standards.

The following subsections describe the elements of the communication system and provide

suggestions for executing and monitoring individual information management tasks. Prior to

promulgation, the Program Review Group (PRG) has the primary responsibility for planning and

coordinating the communications process. They should encourage open and timely 

communication among the responsible parties so that the implementors and their managers can

reach consensus on implementation activities.
3-2 

3.1 Information Exchange

Figure 3-1 schematically illustrates the pathways of information exchange in managing

MACT implementation issues. As shown in the figure, there are numerous participants in the

communication process, including EPA, regulated sources, state and local agencies, tribal entities,

and the public. Information flows to and from each of these entities throughout the

implementation process through such means as internal and external EPA documents, MACT rule

development dockets, the Federal Register, electronic bulletin board systems, electronic mail,

internet websites, technical assistance calls, public meetings, and live and videotaped workshops. 

While Figure 3-1 emphasizes that the information flows to and from many stakeholders,

Figure 3-2 shows what information is exchanged. Some of the items shown in Figure 3-2 (such as

monthly meetings of OAQPS Division Directors) are associated with the ongoing overall

management of air toxics programs, while other items (such as training and outreach) may be

associated with a specific MACT implementation effort. Regardless of whether the items shown

in Figure 3-2 are considered part of the overall management and communication system or part of

an individual MACT implementation effort, successful implementation rests on coordination of

these efforts. The EPA Regional Air Toxics Coordinators have agreed to serve as a team to

ensure good communication and to discuss and resolve issues as necessary among OAQPS,

OECA, OGC, regional offices and the state/local/tribal entities.

The EPA/STAPPA/ALAPCO Unified Air Toxics Website is an invaluable means for

information exchange. It provides air toxic pollution information in a centralized location on the

internet, and is a source of information for the general public, federal, state and local

governments, and sources. The housing of information in an easily accessible, centralized location

greatly encourages sharing information in order to reduce duplication of effort. The Unified Air

Toxics Website contains six different areas of information (Basic Facts, EPA Rules and

Implementation, Pollutants and Sources, Technical Resources, EPA Programs, and State and

Local Agency Programs) that are described in detail in Appendix D. All implementors should

continually review the information on the website for possible applications to their planned tasks
3-3 

and should make their own implementation tools available to others in order to maximize

efficiency and effectiveness.

3.2 Questions and Reaching Resolution

Before promulgation of a standard, ESD usually has the primary responsibility for

developing the standard, which includes responsibility for integrating issues related to Title V,

NSR/PSD, compliance and enforcement, etc. Upon agreement between ESD and PRG, PRG will

have the lead in coordinating the tool development efforts among the implementors for specific

MACT standards with the highest priority implementation needs.

After promulgation, the Regional Air Toxic Coordinators coordinate implementation

efforts, including the management of technical and policy questions from states/local/tribal

entities, and discussion with the MACT development teams leads and/or implementation teams. It

is expected that questions or issues may arise throughout the MACT implementation process. 

These issues should be resolved at the lowest level possible, (e.g., among the active implementors

or the Regional Air Toxics Coordinators) but to the degree that they cannot be resolved at one

level, they should be elevated as quickly as possible to the level at which they can be resolved. 

Industry should direct their technical and policy questions to state and local agencies. 

Most questions should be answered by the state and local agencies by reading the MACT

standard, enabling documents, and implementation documents. To the degree that additional

information or guidance is needed, the state and local agencies may in turn direct their questions

to EPA regional offices. The EPA regional office personnel should coordinate these responses

with their Regional Air Toxic Coordinators. The Regional Air Toxic Coordinators should

coordinate with the Regional Air Toxic Coordinator’s Team and subsequently to the MACT

development team lead as necessary. OECA provides assistance to the Regional Air Toxic

Coordinators, the regional offices, and state and local agencies for applicability determinations,

inspection coordination, and compliance support, when necessary.
3-4 

This post-promulgation communication system is derived from the principle that questions

should be answered by the authorities closest to the affected parties, that is, those that are most

likely to know the details of the specific situation, including state and local rules and policies that

may be relevant. The resolution process should consider the communication system described in

this document to ensure that the roles and responsibilities of the implementors are executed (see

Tables 2-1 through 2-4). EPA expects most questions to be answered at the local, state, tribal, or

regional office levels. This process is shown graphically in Figure 3-4. If necessary, the Air

Toxics Task Force (key managers in OAQPS, OECA, OGC, regional offices, and state/local/tribal

entities) can assist in resolving issues across the stakeholder’s offices and has agreed to meet on

an as-needed basis. Prior to standard promulgation, OAQPS has the lead responsibility for

ensuring that unresolved issues are presented to the Air Toxics Task Force, when necessary. This

would be the responsibility of the Regional Air Toxic Coordinators after standard promulgation.

3.3 Scheduling

Timeliness is critical in the systematic communication process. Implementation activities

should begin prior to promulgation and continue through compliance deadlines set forth in the

standard. The earlier the process begins, the more likely that necessary elements will occur. For

example, ITPID and ESD met to consider implementation aspects of the Medical Waste

Incinerator Emission Guidelines over one year prior to promulgation and the Implementation

Team kickoff meeting was six months prior to promulgation.

Figure 3-3, Example MACT Standard Implementation Timeline, provides a generic

schedule for executing education, source population identification, compliance assurance, and

enforcement activities. The timeline in the figure begins with the effective date for a MACT

standard and continues through five “periods” marked by initial notification, substantive

compliance dates, performance tests, notification of compliance status, and compliance and

continuing periodic reports. This model timeline serves as an example and should be revised as

appropriate to meet specific implementation needs.
3-5 

3.4 Tracking

Tracking activities and progress is another critical issue in the systematic communication

process. PRG/ITPID will maintain an internal database that tracks their SMIP subtask

commitments and the preparation of materials (preparers and reviewers). ITPID has developed

and will maintain the EPA/STAPPA/ALAPCO Unified Air Toxics Website as a vehicle for many

implementors to provide information about their activities and products. The Planning,

Resources, and Regional Management Staff has developed MACTRAX (see Appendix L) to be a

simple, easy-to-use system for states and regions to track their overall status on implementation

(i.e., delegations of MACT standards, source notifications received, and controls installed and

operating). Also, over the next few years, the AIRS Facility Subsystem (AFS) will be

re-engineered and will be an easy-to-use tool for EPA and states to track compliance and

emissions and prepare reports. 

As implementation efforts are completed and individual sources come into compliance

with a specific MACT standard, the Regional Air Toxic Coordinators should identify follow-up

action items, as necessary. The Regional Air Toxic Coordinators should also provide feedback to

the MACT implementors in order to enhance the development of implementation materials and

improve the implementation process for other standards not yet completed or fully implemented. 
EPA

Regional

Offices

EPA - HQ

OAQPS,

OECA,

OGC

Industry

State/Local/Tribal Entities

Public and Other Stakeholders

Figure 3-1. Many Opportunities for Information Exchange

Computer 

Based 

Education 

and Training

(e.g. Website) Public 

Meetings

Reports 

and

Technical

Guidance

o\s\g\morrisville\7397\infoex.ppt

Teleconference

3-6
OAQPS Internal

DD/ADD/GL (Monthly)

• Review Progress/Plans/Budgets

• Set Priorities

• Identify Stakeholder Interests

• Resolve Problems

OD (Quarterly)

• Review Progress

• Set Priorities

• Resolve Cross-office Issues

Implementation Team (Ongoing)

• Staff Support as Necessary, 

Considering Resources and Priorities 

OAQPS/

Regional Offices

Visit (Annual)

• Highlight Successes

• Review Progress

• Identify Obstacles and Solutions

Semi-Annual Reports

• Report Progress

DD/APM/DO Calls (Monthly)

• Agenda as Appropriate

 

DD/APM/DO Meeting (Quarterly)

• Agenda as Appropriate

OAQPS/OECA/

Regional Offices

Staff Level Calls (Monthly and as

 Needed)

• Resolve Implementation Issues

• Develop Implementation

 Recommendations

• Track and Report Progress

• Resolve Issues at Lowest 

 Organizational Level Possible

OAQPS/OECA

DD (Quarterly)

• Review Progress/Plans/Budgets

• Set Priorities

• Resolve Problems

OAQPS/OGC/OECA

Regional Offices/

State/Local/Tribes

Toxics Task Force (As Needed)

• Review Progress/Plans

• Set Priorities

• Resolve Issues

STAPPA Air Toxics Call (Monthly)

• Agenda Set for Each Call

OAQPS Planning Management

 Retreat (Annual)

• Review Progress

• Set Priorities

• Adjust Plans

 

“Aqueduct”/Brown Summit

 Working Meeting on Air Toxics

 Implementation (Annual)

• Identify Staff Level Implementation

 Issues

• Resolve Staff Level Implementation

 Issues

Air Toxics Implementation 

 Conference (Annual)

• Review Progress with a Wide 

 Audience

• Provide Training and Outreach

OAQPS/OECA/

Regional Offices/Public

and Regulated Community

Website (Ongoing)

• Continual Dissemination of

 Information - Regulations/Contacts

Outreach Efforts (Ongoing)

• Workshops/Seminars

• Brochures/Pamphlets

DD

ADD

GL

OD

APM

DO 

= Division Directors

= Associate Division Directors

= Group Leaders

= Office Directors

= Air Program Managers

= Desk Officers

3-7

Figure 3-2. Communication Agenda
1 2 3 4 5

Effective

Date

Initial

Notification

Substantive

Compliance

Dates

Performance

Tests

Notification of

Compliance

Status

Compliance &

Continuing

Periodic

Reports

Education

Identification of Source 

Population Subject to 

MACT Standard

Outreach/Compliance Assistance

Compliance Assurance

Enforcement

Additional Activities

3-8

Source: Model Implementation Plan for MACT Standards

Draft No. 5 - March 7, 1997

Figure 3-3. Example MACT Standard Implementation Timeline
3-9

For existing sources, Period 1 is usually 120 days, and for new sources, Period 1 is usually 120 days from startup;

however, an individual standard may specify a much longer timeframe.

! For existing sources Period 2 may be up to three years, but new sources generally must comply at startup. In

other words, new sources usually do not have a Period 2.

! Period 3 is usually 180 days from the compliance date.

! Period 4 is usually 60 days.

! Period 5, measured as the time before the first periodic report is due, may be three, six, or twelve months, and

subsequent reporting periods may be adjustable depending upon the standard.

! Also note that the entries for each phase indicate a potential duration; it is always advisable to execute the phases

as expeditiously as possible. For example, the source population identification phase may extend past the initial

notification date as these notifications may identify more sources, but the much of the work for this phase should

be completed well before this date.

Figure 3-3. Example MACT Standard Implementation Timeline (Continued)
Sources direct questions to the implementing authority (typically States)

If the implementing authority cannot answer, they 

forward questions to their respective RO

If the RO contact can respond, they provide response and 

send a copy to other ROs and HQ Representatives

If a RO contact cannot respond, they contact other 

RATCs to figure out how to respond. 

RATCs have the lead in providing response to the State and 

sending copies to HQ representatives for a 10-day time limited HQ review

If the resulting action reflects a change in past application of a regulation 

or policy, (requiring coordination with other HQ offices) the designated RO 

contact develops and distributes a one page description of the issue and 

schedules a meeting with appropriate parties

RATCs, OC, ORE, OGC, and OAQPS will determine who will provide response

Sub-Lead region* should send all responses to the Program Review 

Group to compile and provide on the EPA Website

* Region IV is currently the sub-lead region for air toxics. 

RO = Regional Office

HQ = Headquarters 

RATC = Regional Air Toxics Coordinator

OC = Office of Compliance

ORE = Office of Regulatory Enforcement

OGC = Office of General Counsel

OAQPS = Office of Air Quality Planning and Standards

Figure 3-4. Implementation Issue Resolution Process

3-10
4-1 

Section Summary

Considerations for a successful strategy such as education, source population

identification, outreach, small business issues, compliance assurance,

enforcement, reference materials, available resources, and permitting issues are

discussed. 

4.0 ELEMENTS OF A SUCCESSFUL IMPLEMENTATION STRATEGY

The elements recommended for consideration and inclusion in any implementation effort

are described in this section. Examples of how the elements are actually used in a Specific MACT

Implementation Plan (SMIP) are presented in Section 5.0. This section specifically describes

education, source population identification, outreach, small business needs, compliance assurance,

enforcement, and how these elements are critical considerations in any strategy. These elements

are described in more detail in the following paragraphs.

4.1 Education

For purposes of this strategy document, education refers to educating the implementors

rather than educating the affected sources and the public, which is part of outreach. However, for

many rules, some of the sources of information and activities described below may serve the goals

of both education and outreach.

An important source of information is the SMIP which is prepared prior to promulgation

of each MACT (see Section 5.0). The SMIP will provide a summary of the rule and an action

plan for implementing the specific standard through all phases of implementation from education

through enforcement. The SMIP, written for the implementors, would propose specific

procedures for implementation associated with “trigger” dates within the standard such as

notification dates, compliance dates, reporting intervals, and stack test dates.
4-2 

The SMIP should be targeted for implementors, and should be as user-friendly as possible,

avoiding regulatory language in favor of more common language where possible. A good

example, the draft implementation plan for the Ethylene Oxide Commercial Sterilization Facilities

MACT standard, is included in this document as Appendix F. The materials in the SMIP should

use standard policies and procedures as much as possible and highlight significant differences or

issues. This is important because the state agencies, permit writers, inspectors, and other staff

have resource limitations. Materials in the SMIP do not replace the rule; if there are any legal

issues, the rule takes precedence. However, the rule should not be solely relied on because of the

need to quickly and efficiently transfer the needed information.

Even though the plan will provide a useful written summary for an implementing agency,

some training may also be necessary. EPA's traditional training courses for MACT standards,

primarily teleconference satellite courses, are excellent in fulfilling this need. EPA plans to

arrange these courses at optimum times for those standards that have the greatest need. 

The implementors will be asked many questions that may be answered based on the

educational materials and training discussed above. EPA will also provide assistance to the

implementor for specific questions that are not covered in the materials discussed above. To

facilitate the process, the regional offices will identify a contact person for each standard or a

central contact who can then transfer the specific question to the appropriate regional office

person. In turn, appropriate OECA, OGC, and OAQPS contacts (see Appendix I) should be

identified and be available to the regions to address unique questions. Thus, there should be a

confirmed link at each level of the information ladder from EPA headquarters to the regions and

to the states.

To ensure national consistency to the appropriate degree and still allow for site-specific

applications as appropriate, periodic conference calls or electronic mail exchanges between the

contacts for a specific standard should be held following rule promulgation to exchange questions

and answers. The regional offices are expected to regularly communicate with the state, local,

and tribal entities in their region. Regional offices should also help build a body of frequently
4-3 

asked questions and answers for sharing among the implementors. For questions and answers

that are not straightforward, the Regional Air Toxics Coordinators should discuss options and

seek input and/or review from OECA, OGC, and OAQPS as appropriate. To maintain

consistency, these questions and answers should be discussed and drafted among the group, and

approved by the delegated authority. They should also be made available via the Unified Air

Toxics Website. In addition, the implementing agencies should take advantage of the EPA’s and

STAPPA’s electronic services. 

As mentioned before, a SMIP could include lists of available resources such as EPA

Internet websites and websites of the states. In addition to providing access to official guidance

documents and formal response to questions, both EPA and STAPPA have electronic means to

share draft responses and issue papers among the implementors. Using such means to share

information can reduce the risk of an implementor responding incorrectly because of a lack of

understanding of the question. Sharing information is also important for reducing overlapping or

conflicting implementation efforts.

4.2 Identifying the Source Population Subject to the MACT Standard

Identifying a regulation’s affected source population is not always a clear process, but is a

necessary step during the early implementation of the rule. For some regulations that affect only

large facilities, this will not be a concern because most state or local programs are aware of all the

large facilities in their jurisdiction. However, in other cases, identifying the population may be a

daunting task if sources are numerous, small, or collocated. To simplify this process, EPA has

prepared a “Cookbook” to guide agencies through various identification techniques using a

screening process based on available data. The Cookbook was pilot tested in several states and

the results are included in the final version. The Cookbook is included as Appendix G to this

document.

Even after finding potential sources, some questions may remain about a rule’s

applicability. While these questions generally need to be addressed on a case-by-case basis, EPA
4-4 

can provide information to assist in these efforts. The Applicability Determinations Index is a

useful tool to determine if a question has been previously addressed. EPA also can produce

example applicability determinations. For example, for the Hazardous Organic NESHAP (HON),

three applicability determination examples were produced which were very helpful and possibly

prevented some erroneous determinations.

Throughout the source identification process, the delegated agency will be the official

decision maker on applicability determinations. The delegated agency should maintain good

communications with EPA according to the terms of the delegation. 

4.3 Outreach

Outreach is targeted for the general public and regulated community. Outreach

opportunities include using literature to disseminate information about an industry; attending

training courses, trade shows, or meetings; and coordinating with the Small Business Assistance

Program. In many cases, outreach efforts and source population identification are occurring at

the same time. For example, the Small Business Assistance Program may have information on

affected sources to provide to implementors as well coordinating with implementors to provide

information to affected small businesses.

Literature may include fact sheets EPA prepared during rule development or pamphlets

produced by the EPA regional office or a state/local/tribal entity to address specific needs of the

permitting authority or geographic area. EPA also considers preparing plain-English guides (or

other languages) for the regulations, especially those involving area sources or those affecting

small businesses. For example, the draft Plain-English Guide for Perchloroethylene Dry Cleaners

was a very useful and popular document at a Southern Dry Cleaners Show. 

The SMIP should contain sections about pollution prevention opportunities so that the

regulated sources can be educated in that topic and pollution prevention activities can be

implemented as part of the compliance scheme. Technical summary sheets should have a section
4-5 

that highlights pollution prevention options in the rule and/or voluntary pollution prevention

measures the affected source category could take. The plan may also list regional contacts for

pollution prevention information.

Education efforts such as training courses may also provide outreach opportunities. 

Some courses targeted for the implementors may also be appropriate for a public audience and

vice versa. To that end, implementors may be able to attend seminars sponsored by industry

organizations. Often EPA provides technical assistance to these seminars through expert speakers

and other materials. These seminars create excellent opportunities to train the implementors while

gaining some of the industry’s perspective on the rules.

Other training opportunities include satellite downlink courses. These courses are usually

presented by EPA through a university grant and often have trade associations as joint sponsors. 

These courses involve EPA, state, and industry representatives, and the resulting videotapes can

be distributed to an even wider audience.

Implementing agencies should also contact industry associations to arrange outreach

efforts. EPA can facilitate this effort by including names of associations contacted during

standard development and identify any assistance or information the associations may offer. Such

information can be included in the SMIP. The implementing agency should also offer to attend

trade shows and address association meetings. Many times the organizations desire the regulatory

agency’s presence and will provide free space within the shows for displays about the standards.

Just as during the education phase, the implementors should take full advantage of the

information available electronically. The EPA and state websites, and potential telephone hotlines

would particularly be useful in outreach efforts, if these resources are properly equipped and

advertised.

The implementing agency should also remember that the time frame for completing the

source population identification and outreach may be up to three years or as short as six months. 
4-6 

The SMIP will quickly identify this time limit and provide recommendations an implementing

agency may consider to make appropriate plans.

4.4 Small Business Needs

The implementation strategy concepts apply both to MACT standards for large industry

and small businesses. All implementing agencies should coordinate with the Small Business

Assistance Program for their area to assure that they have an appropriate understanding of the

rules and access to training and literature. This coordination is very important to ensure

compliance with SBREFA and EPA’s small business policies. Each implementing agency needs

to understand that small businesses may be major sources and that the Small Business Assistance

Program is a major participant for any rule affecting small business entities. 

If a rule is subject to the Small Business Regulatory Enforcement Fairness Act (SBREFA),

there are specific requirements for the development and distribution of SBREFA Compliance

Guides. EPA must prepare one or more publications as small entity compliance guides, explain in

these guides the actions a small entity must take to comply, and distribute these guides to small

entities through comprehensive sources of information. For example, trade associations may be

appropriate for some industries, and the Small Business Assistance Program may be appropriate

for others. The CAA gives the EPA broad discretion under SBREFA with regard to

implementation, development, and distribution of the guides. Further information is located in

Appendix J, Small Business Regulatory Enforcement Fairness Act. 

4.5 Compliance Assurance

After educating themselves, the regulated community, and the public, and after locating

the sources, the implementors must turn to assuring compliance with the rule. Although different

agencies have different organizations and procedures for compliance assurance, certain major

activities are universal. First, the implementor must establish a system to track compliance. 

There is no new tracking or reporting requirement mandated by this document, but rather, the
4-7 

specific requirements will be agreed to as part of the Performance Partnership Agreement. 

Systematic tracking supplies quick and easy analysis of a source’s compliance status and the

success of the implementation efforts. Initially, the tracking includes receipt of notifications and

grows to periodic reports and inspection results. To accomplish this, the Aerometric Information

Retrieval System (AIRS) is available. An internal system, MACTRAX, is also an option as long

as the AIRS reporting commitments are still met. See Appendix L on the MACTRAX System.

If AIRS is used for tracking, the appropriate data should be entered. If an action code is

missing, the regional office should be notified to have it added. Stand-alone tracking systems may

also be established. This may be advantageous during the early implementation stages to track all

the initial notifications, compliance status notifications, and first periodic reports. Stand-alone

systems provide faster access to compliance data, and the report writing capabilities may be more

flexible. Nevertheless, all required data must be entered into AIRS, and the use of a stand-alone

system is a matter of preference.

Another compliance activity is inspections. Individual affected sources should be targeted

for regular inspections beginning after a rule’s first substantive compliance date. If a rule has

staggered substantive compliance dates, then additional targeting is necessary. This is especially

important for the regional offices which have limited field presence. Whatever targeting model is

used, its weighting factors should be adjusted after a compliance date to ensure that MACT

sources are inspected. In subsequent iterations, the weighting factors can then be reduced to

normal levels merely to ensure continuous regular inspections. Example inspection checklists are

included as Appendix H.

While conducting inspections, the implementor will need to consider whether violations

will be addressed with compliance assistance or enforcement proceedings. Furthermore, because

of resource limitations, compliance assistance priorities should consider where assistance is most

needed and most effective. For example, sources which are expected to have difficulties in

complying, like area sources, small businesses, or sources predominantly owned by persons who

may not understand English well may be the best candidates for compliance assistance. Also, one
4-8 

should note that compliance assistance is only a part of compliance assurance. Assistance is when

the implementor helps define and works with the regulated source in how to achieve compliance. 

Assurance is all the activities the implementor conducts to achieve, monitor, maintain, and track

industry compliance, short of enforcement. These activities are the precursors to enforcement,

when necessary, and naturally include compliance assistance.

Compliance assistance is also a major factor when dealing with small businesses. The

small business programs were created to provide information to small businesses requesting

compliance assistance. Compliance assistance will likely be the response for deficiencies found at

small businesses which report deficiencies voluntarily. Again, appropriate coordination with the

Small Business Assistance Program is critical during this phase of compliance assurance. Please

note that the Small Business Assistance Programs may also conduct site visits.

During this phase, EPA encourages the implementor to present pollution prevention goals

as part of the source inspections. The inspectors should have checklists so that they can easily

identify the necessary pollution prevention activities. Also, the checklists could have suggestions

for other prevention activities which are not required by the rule. The checklists could be similar

to the inspection checklists developed for the dry cleaning facilities MACT standard (see

Appendix H1). Since pollution prevention activities are not always required by the rule, some

states may not be able to incorporate pollution prevention into their inspection scheme. If this is

the case, a great effort at pollution prevention education during the outreach phase of

implementation is all the more important.

Lastly, all federal compliance assurance activities should be coordinated with the state,

local, and tribal entities (See Sections 2.0 and 3.0). This will avoid conflicts and help EPA focus

its resources.
Guidance on the Timely and Appropriate (T&A) Response to Significant Air Pollution 1

Violators (SVs). Memorandum from John S. Seitz and Robert Van Heuvelen,

U. S. Environmental Protection Agency, Office of Air Quality Planning and Standards, to Air

Directors and Regional Counsels. February 7, 1992.

4-9 

4.6 Enforcement

When a violation is discovered at a major source, the implementor should proceed

according to the guidance on “Timely and Appropriate Enforcement Response to Significant Air

Pollution Violators. ” The purpose of the guidance is to enable the implementors to focus 1

enforcement efforts on the highest priority of noncomplying sources and to do so in a timely

manner. The SMIP may include an Enforcement Response Plan (ERP) as guidance on specific

conditions when enforcement is necessary. For all enforcement actions, pollution prevention

benefits should be explained, and the use of pollution prevention projects should be encouraged

when an enforcement settlement is going to include supplemental environmental projects (SEPs).

4.7 Reference Materials

During rule development and certainly at promulgation, various participants need to gain

an understanding of the requirements in the rule and its associated infrastructure. Good sources

of information are the documentation that EPA generated during rule development such as

technical and general fact sheets, Federal Register notices, the rule itself, and the technical support

document that includes the basis for the rule. These documents are usually available promptly on

EPA’s electronic bulletin boards/websites and specifically on the EPA/STAPPA/ALAPCO

Unified Air Toxics Website (See Appendix D for website information). Sometimes additional

information prepared by EPA and the state and local agencies is on the website or available

through hypertext links to other sites. In the near future, this website will contain information on

each MACT standard and its implementation. In order to share information and to avoid

duplicate efforts, this strategy recommends that EPA lead a joint effort with STAPPA to

coordinate the development of tools and make them available on the Unified Air Toxics Website. 
4-10 

It is essential to the SMIP that a list of available resources for the MACT standard are mentioned

with specific instructions on how to access them. 

4.8 Other

During each phase of the implementation of a rule, the implementors will have to deal with

additional considerations that will impact their activities. Some may only affect certain state,

local, or tribal entities or geographic areas while others will be more universal. Some of the

universal considerations include resources, permitting, requests for compliance extensions and

waivers, and impact of SBREFA. The SMIP can provide some assistance with these issues, but

individual planning will be required to adapt the strategies to the structure of each regulating

agency.

4.8.1 Resources

A successful implementation strategy should consider all possible aspects of

implementation, including resources. The availability of resources is always a factor in how much

work can reasonably be performed. Choices will need to be made on where the resources can be

used most effectively and efficiently.

The implementation support activities will likely be in direct proportion to the resources

allocated for such efforts. During the MACT standard development process, PRG/ITPID, ESD,

OECA, and the implementors should discuss possible implementation efforts and prioritize them

with emphasis on the critical elements. The EPA/STAPPA/ALAPCO Committees on Air Toxics

and Training are two current venues that PRG is using to help prioritize needs.

Because implementation needs will likely continue to be greater than the directly available

resources, PRG/ITPID will pursue additional approaches for completing the identified critical

elements of the SMIP. PRG/ITPID may ask implementors to volunteer to prepare certain

materials or share costs with others to prepare specific items. For example, an industry trade
White Paper Number 2 for Improved Implementation of the Part 70 Operating Permits 1

Program. Memorandum from Lydia N. Wegman, U. S. Environmental Protection Agency, Office

of Air Quality Planning and Standards, to EPA Regional Office Directors. March 5, 1996.

4-11 

group may be able to provide a list of affected sources or develop training materials, or a regional

office or state or local agency may be able to develop an inspection checklist or the SMIP. If

these approaches are still insufficient to complete the critical materials, PRG will alert EPA

managers and STAPPA/ALAPCO of the situation for resolution and they may bring the

discussion to the Air Toxics Task Force, if appropriate.

4.8.2 Permitting

Several issues may need to be addressed with regard to permitting. If the source is yet to

receive its operating permit, the implementor must ensure that the permit includes the applicable

requirements of the rule. Also, if the permit has been issued and is not going to expire within

three years, then the implementor must reopen the permit to include the applicable requirements

of the MACT standards. For rules that apply only to major sources there will be discussions

concerning potential to emit and ways to ensure that the source may keep its potential below the

MACT cutoffs and Title V requirements. In this case, the specific MACT implementation plan

could provide examples or ideas about limitations that would be appropriate for a Federally

Enforceable State Operating Permit (FESOP). Also, for sources that have requirements from

more than one regulation, the source may want to take advantage of the streamlining

opportunities afforded in the Title V White Paper 2.1

Other considerations may include requests for compliance extensions, waivers, and other

determinations. These requests must be processed according to the time frames in the rule or

general provisions. Much additional information on Title V and other policy and guidance is

available on the EPA Title V Operating Permit Program website and the EPA Policy and

Guidance website. 
5-1 

Section Summary

This section defines and discusses “baseline” and “enhanced” efforts for the

development of implementation materials, decision making tools and processes

for determining recommended level of effort for a MACT Standard, and the

Tool Development Agreement (TDA).

5.0 DEVELOPMENT OF A SPECIFIC MACT IMPLEMENTATION PLAN

This section describes activities recommended to effectively develop a Specific Model

Implementation Plan (SMIP) using the strategy presented in Section 4.0 and tailoring it to the

specific MACT standard. An assessment is made of the complexity of the standard and the

expected implementation needs. Based on that assessment, a SMIP is developed for that standard

which includes a Tool Development Agreement (TDA) that is agreed to by the participants. The

SMIP should reflect that follow-up and tracking activities are necessary after promulgation. See

Figure 5-1 for a flow diagram illustrating this process. 

The implementation may require different levels of effort and resources for each MACT

standard. The Program Review Group (PRG) in the Information Transfer and Program

Integration Division (ITPID) has the lead role in encouraging the development of a SMIP, and for

coordinating the activities recommended for successful implementation as specified in Section 4.0,

as resources allow. PRG is specifically responsible for developing a TDA that ensures that the

critical implementation materials are prepared or the gap between the need and the resources

available is elevated to EPA managers and STAPPA/ALAPCO as discussed in Section 4.8.1. As

shown in Tables 2-1 through 2-5 (and Table 5-1), ITPID is not responsible for all implementation

activities, or the actual preparation of all implementation materials. Rather, PRG/ITPID will

focus on developing the TDA, coordinating the production of the materials, and preparing some

of the materials. Actual preparation of these materials will be shared among the implementors

(both EPA and non-EPA).
5-2 

5.1 Assessment of MACT Standards

5.1.1 Baseline Implementation Materials and Enhanced Implementation Materials

Certain implementation materials have been identified as “baseline” materials that would

be beneficial for every MACT standard. Any additional items are categorized as “enhanced”

materials. The following subsections describe the decision making process for planning the level

of effort for a MACT standard. For the purposes of this discussion and preparation of the TDA,

the following items are considered “baseline” implementation materials:

Administrative

C Contacts list (e.g., Permitting Authority, Regional Offices, ITPID, ESD, OECA,

OGC);

C Specific delegations guidance where generic guidance is not sufficient;

C Summary of recordkeeping and reporting requirements;

C Specific compliance certification/assurance and enforcement policies/guidelines

where generic guidance is not sufficient;

C Specific data reporting information (AIRS database training, MACT database

training, MACTRAX) where generic guidance is not sufficient; and

C Timeline: compliance schedule (i.e., summary of compliance deadlines).

Technical

C Fact sheets/summary of the standard;

C Currently available list of affected sources and locations;

C Examples of applicable reporting forms (e.g., initial notification, initial statement of

compliance for each control device, checklists);

C Inspector checklists;
5-3 

C Summary of testing and monitoring requirements;

C Summary of operations and maintenance plans/requirements (if required by

MACT);

C Technical support document;

C Specific guidance on relationships to Title V, NSR, Potential to Emit (PTE) where

generic guidance is not sufficient;

C Sample calculations; and

C Applicability flowcharts.

Other implementation materials have been identified as “enhanced” materials. These items

may be useful for implementation of certain MACT standards, in addition to the baseline items. 

How to determine the need for the development of these additional materials is discussed in the

following subsections. 

For purposes of this discussion and preparation of the TDA, the following items are 

“enhanced” implementation materials to be considered:

Technical Training

C Satellite downlinking training sessions;

C Workshops (at 1 or more sites near implementors);

C CD-ROM interactive tools on training;

C Federal Register hypertext; 

C VHS training tapes; 

C On-site training and certification (i.e., at a source) (for implementors or perhaps

sources in conjunction with Small Business Assistance Program or Trade

Association);

C Test method training; and
5-4 

C Example conditions for Title V operating permits.

Source ID/Outreach/Small Business Assistance

C Source identification materials (beyond ESD list and Source ID Cookbook);

C Brochures/pamphlets/plain-English guides (outreach materials);

C Public meetings;

C Small business outreach materials;

C Small business assistance training; and 

C SBREFA Compliance Guide (if necessary).

When determining if enhanced efforts may be needed, the implementors may want to

consider other important factors such as the potential for emission or risk reduction, the degree of

public interest in the standard or regulated industry, or other factors that can affect the overall

significance of a particular MACT standard. In any case, the implementor’s judgement should

always prevail in dictating the starting point for any implementation effort as well as deciding

whether to incorporate additional implementation materials.

5.1.2 Interview with MACT Development Team and Representative Implementors

Tools are available to help PRG and all the implementors plan the expected

implementation needs for each MACT standard. A list containing several types of questions is

useful as a starting point for the initial information gathering phase (see Appendix A). PRG takes

the lead in scheduling and interviewing the MACT development team (usually ESD, but may be a

regional office or state partner, in the case of MACT Partnerships) and representative

implementors to get specific information on that standard and implementation needs. This

information may be helpful in determining the necessary level of implementation effort. Ideas for

particular implementation materials may also be identified during the interview.
5-5 

5.1.3 Diagnostic Questionnaire

A diagnostic questionnaire (Figure 5-2) has been developed as a tool to allow

implementors to systematically examine the different factors that may either justify or preclude the

need for implementation materials beyond the baseline. The questionnaire considers the following

factors: 

• Complexity of the rule;

• Difficulty of determining applicability;

• Cost of compliance;

• Number and size distribution of sources and companies;

• SBREFA requirements;

• Capabilities of trade associations (which affects the need assessments and

leveraging possibilities);

• Degree of controversy or acceptance of the rule by industry, state, local, and tribal

entities, and the public; and

• Capabilities/technical expertise within the industry.

Each of the factors in the questionnaire influences the level of effort recommended for

implementation of a particular MACT standard. For example, the presence of a small number of

facilities in a regulated industry would tend to reduce the necessary implementation effort. 

Conversely, the presence of complex rule language would tend to increase the warranted level of

effort. The questionnaire contains diagnostic questions that review the effects of the various

factors and indicates whether enhanced materials would be useful for implementation of a specific

MACT standard. 

The availability of resources within the implementing agencies is always a factor in

determining how much work can reasonably be performed; however, the questionnaire
5-6 

deliberately does not include available resources as a factor for consideration because the initial

determinations should be based on experience and technical expertise. 

The questionnaire provides a format where points are assigned for each response. The

points are totaled and a score of six or greater indicates that additional efforts should be

considered.

5.1.4 Flow Charts for Enhanced Efforts

Flow charts are included as tools that may help determine where enhanced efforts would

be useful. Figures 5-3 through 5-6 are flow charts for determining if technical training, source

identification/notification, public outreach, or small business assistance may be necessary. Once a

decision is made that enhanced implementation materials may be needed, the specific areas

needing additional effort should be identified. The flow charts are intended to help with this

decision-making process.

5.2 The Tool Development Agreement

Table 5-1 presents one tool, the TDA, that should be used by the MACT development

team and implementors to reach preliminary agreement on the scope of the draft SMIP. PRG will

take the lead on planning the development of the SMIP and coordinating among the various

implementors. After consensus has been reached among the implementors on the preparation of

baseline implementation materials, the areas where enhanced efforts are needed, and the lead for

the preparation of each item/set of materials, the TDA for that MACT standard may be

developed. 

The baseline elements are shaded and are listed first in Table 5-1, followed by the

enhanced elements. For each element listed, suggestions on the lead group and significant

participants have been made. A blank TDA can be found as Appendix B to this document and
5-7 

may be photocopied and used as a planning tool. The TDA contains three groups of columns

which include the following items:

Implementation Materials - The items in this column are the building blocks that make

up a complete MACT implementation plan. Some of the items in this plan will be specific to each

MACT standard while others may be general language unless otherwise specified. For example,

specific language may be used for delegation guidance exceptions and exceptions to compliance

certification/assurance and enforcement policies/guidelines. Items marked with an asterisk

represent those that will be general language unless the specific rule is an exception to the normal

guidance.

Y/N - The Y/N column is to be used for MACT-specific decisions on what materials will

be produced. This decision will be based on the knowledge and expertise of the implementors,

with the assistance of the decision making tools (Figures 5-2 through Figure 5-6 and

Appendix A).

Lead Group - If the material is identified as baseline or as a necessary enhanced tool for a

particular MACT standard, a lead group responsible for coordinating the preparation of that piece

of material will be identified as “lead” in this column. The lead group will not necessarily be the

preparer of the material.

Participants - The final group of columns indicates participants in each implementation

activity. Most of the implementation materials will need input or review from more than one

group. For each item, a check mark indicates whether a certain group is expected to participate in

the development of that material. This participation could be as a preparer or a reviewer, and

does not exclude any other group from participating in the development of that item. Table 5-1

distinguishes responsibilities among nine potentially responsible entities. The entities are

subdivided where responsibilities are specifically targeted for a particular group. 
5-8 

During MACT development, at promulgation and at compliance dates, ITPID and ESD

will likely execute most of the efforts included for the baseline tools with some activities and

materials performed or prepared by the regional offices, OECA, state, local and tribal entities, and

the Small Business Assistance Program. However, the TDA can be tailored towards the specific

needs of the implementors, as appropriate. A model TDA has been prepared and is included as

Table 5-1. Again, all of these materials presume certain activities, roles, and responsibilities by

the implementors in order to facilitate efficient and effective preparation of plans. The plans are

designed to remain flexible so that additional ideas can be accommodated.

Because the MACT standards requiring enhanced implementation efforts are generally

more complex than those requiring only baseline efforts, more intensive and extensive planning

may be necessary. The SMIP may be coordinated with a working group or a team of

implementors. In some cases, it may also be appropriate for the working group or a team to

actively design and plan the SMIP. Such a Working Group or Team could include representatives

from ESD, ITPID, EMAD, OECA, OGC, regional offices, state, local and tribal entities, the

Small Business Assistance Program, and other entities, as needed. Ideally, these representatives

would develop a detailed plan of action during rule development for implementation of the

standard at promulgation. A key consideration in the SMIP and TDA is the timing of the

preparation and availability of the elements. For example, the timing of efforts to promulgate the

rule and develop implementation tools will have to be coordinated so that both efforts are as

effective and efficient as possible.

5.3 Additional Elements of a Specific MACT Implementation Plan

The assessment of the MACT Standard and preparation of the TDA should happen prior

to promulgation. Some tools may be drafted before promulgation, but many cannot be prepared

until after the final promulgation details are known and signed. Other aspects of the MACT

implementation process will also occur after promulgation, such as the following:

C Follow-up and tracking;
5-9 

C Compliance assurance; and

C Enforcement.

All elements discussed in Section 4.0 should be considered for every MACT standard at some

point in the implementation process. Each MACT standard will be unique and will need to be

given individual consideration when developing the SMIP. It may not be possible to predict the

effects of the standard, therefore, tracking with appropriate follow-up activity is necessary for

successful implementation.
O:\s\g\mor\73976599\ATISFIN.ppt

5-10

MACT Development Promulgation

Process

Prepare SMIP

(includes TDA)

PostPromulgation

Follow-up

Activity

Perform assessment of the

MACT Standard using

interview, questionnaire,

and/or flow charts as

needed

Complete Tools in TDA

Figure 5-1. Process for Developing a SMIP

Perform follow-up and

tracking activities and

revise SMIP as needed

Begin drafting tools in

TDA that are not likely to

change during MACT

development process
5-11 

Instructions: For each question below, choose the response that best represents the situation

with your MACT standard. After answering all questions that apply, total your score by

adding the numbers in parentheses that correspond to the answer chosen.

Scoring: 6 total points or greater suggests a need to utilize enhanced implementation

materials beyond the baseline effort. See additional flow charts to determine what types of

enhanced efforts are needed.

1. How would you characterize industry’s involvement in the development of the MACT

standard?

a. Positive (0)

b. Negative (1)

2. Does the MACT standard contain different requirements from what is already in practice

by most of the regulated industry?

a. Yes (1)

b. No (0)

3. How many states contain affected sources?

a. Less than 4 (0)

b. Between 4-10 (1)

c. More than 10 (2)

4. How many affected sources are there?

a. Less than 5 (0)

b. Between 5 & 30 (1)

c. More than 30 (2)

Figure 5-2. Questionnaire for Determining Whether Materials

Beyond the Baseline Level are Needed
5-12 

5. Is the average facility large or small? (“Large” is defined as being more than

500 employees and “small” being less than 500 employees for the purpose of this

question.)

a. Large (0)

b. Small (1)

6. Is the rule subject to SBREFA?

a. Yes (1)

b. No (0)

7. Is the rule complex? (e.g., the rule has many options for compliance)

a. Yes (1)

b. No (0)

8. Do the majority of the affected sources belong to a trade association?

a. Yes (0)

b. No (1)

9. Is it difficult for a source to determine applicability?

a. Yes (1)

b. No (0)

10. What is the cost to comply with this rule?

a. Minimal (0)

b. Significant (1)

TOTAL: _____ points

Figure 5-2. Questionnaire for Determining Whether Materials

Beyond the Baseline Level are Needed (Continued)
O:\s\g\mor\73976599\ATISFIN.ppt

Is there more than one No

option for the source for

control and/or

monitoring?

Probably not necessary to

conduct additional

technical training

Is the source responsible

for determining which

controls or pollution

prevention options are

appropriate?

Start

Yes

May be helpful to

choose enhanced

implementation

materials from TDA in

area of technical

training

No

Yes

Figure 5-3. Flow Chart for Determining if Enhanced

Technical Training is Necessary

STOP

5-13
O:\s\g\mor\73976599\ATISFIN.ppt

Yes Is it known which

sources are affected?

Not necessary to develop

additional

implementation tools to

identify sources

Is the number of

affected sources

expected to be large?

STOP

Start

Yes

May be helpful to choose

enhanced implementation

materials from TDA for

Source ID/Notification

Assistance

No

No

Figure 5-4. Flow Chart for Determining of Enhanced Source

ID/Notification is Necessary

5-14
O:\s\g\mor\73976599\ATISFIN.ppt

Are you aware of any No

actual or perceived

imminent health risks

associated with

emissions from this

source?

May not be necessary to

prepare additional public

outreach materials

May be helpful to

prepare enhanced

implementation

materials from TDA in

area of public outreach

STOP

Start

Yes

No

Yes

Has the public or

environmental

community been vocal

in the development of

this regulation?

Figure 5-5. Flow Chart for Determining if Enhanced Public

Outreach is Necessary

5-15
O:\s\g\mor\73976599\ATISFIN.ppt

May not be necessary to

prepare additional

implementation materials

aimed at small businesses

Start

* There is a specific definition for small business for each SIC code. These definitions are based on

number of employees or dollar amount that the business must equal or be less than in order to

qualify as a small business. A large portion of these SIC codes use 500 employees as the

maximum number to qualify as a small business.

Is the rule subject

to SBREFA?

No Does the average facility

employ less than 500*

employees?

May be helpful to choose

additional implementation

materials from TDA in area of

small business assistance

Must prepare SBREFA

compliance guide

Are sources located in more

than one state?

No

And

Yes

Yes Yes

Figure 5-6. Flow Chart for Determining if Enhanced Small

Business Assistance is Necessary

No

STOP

5-16
MACT: 

Table 5-1. Model Tool Development Agreement

 Implementation Lead

Materials Y/N Group ESD OPG IIG IMG ITG EOG PRG OC ORE

Participantsa

ITPID OECA PRRMS EMAD OGC 

b

BASELINE

AdministrativeContacts list for Y PRG 8 8 8 8 8 8 Lead 8 8 8 8 8 

implementors Specific guidance Y IIG 8 Lead 8 8 8 8 8 8 

on delegations* Summary of Y ESD Lead 8 8 8 8 8 8 

recordkeeping and reportingrequirementsSpecific guidance Y OC 8 8 8 8 Lead 8 8 

on compliance certification,assurance, andenforcementpolicy*Specific data Y IMG 8 Lead 8 88 8 8 

reporting aspects of AIRS*Specific data Y IMG 8 Lead 8 88 8 8 

reporting aspects of MACTdatabase*Specific data Y PRRM 8 8 8 88 Lead 8 

reporting aspects S of MACTRAX*
MACT: 

Table 5-1. Model Tool Development Agreement (continued)

 Implementation Lead

Materials Y/N Group ESD OPG IIG IMG ITG EOG PRG OC ORE

Participantsa

ITPID OECA PRRMS EMAD OGC 

b

Timeline: Y ESD Lead 8 8 8 

compliance schedule

TechnicalFact sheets Y ESD Lead 8 8 8 8 8

(general, technical, andpress release)Summary of the Y ESD Lead 8 8 8 8 8

standard Currently Y ESD Lead 8 8 available list of affected sources Examples of Y OC 8 8 8 Lead 8 

applicable reporting forms(e.g., initialnotification,initial statementof compliance foreach controldevice,checklists).Applicability Y ESD Lead 8 8 888 8 8 8 8 8 8 

flow charts Sample Y ESD Lead 8 888 8 8 8 8 8 8 

calculations 
MACT: 

Table 5-1. Model Tool Development Agreement (continued)

 Implementation Lead

Materials Y/N Group ESD OPG IIG IMG ITG EOG PRG OC ORE

Participantsa

ITPID OECA PRRMS EMAD OGC 

b

Inspector Y OC 8 8 888 8 Lead 8 8 8 8

checklists Summary of Y ESD Lead 8 888 8 8 8 8 8 8 

testing and monitoringrequirementsOperations and Y ESD Lead 8 888 8 8 8 8 8 8 

maintenance plans/requirementsTechnical Y ESD Lead 8 888 8 8 8 8 8 8 

support documentSpecial Y ESD Lead 8 8 888 8 8 8 8 8 8 

relationships to Title V, NSR,PTE*
MACT: 

Table 5-1. Model Tool Development Agreement (continued)

 Implementation Lead

Materials Y/N Group ESD OPG IIG IMG ITG EOG PRG OC ORE

Participantsa

ITPID OECA PRRMS EMAD OGC 

b

ENHANCED

Technical

Training

“CD-ROM” PRG 8 8 Lead 8 8 8 8

interactive tools on trainingFederal Register PRG 8 8 Lead 8 8 8 8

hypertext Workshops (site- OC 8 8 8 Lead 8 8 8specific) (NETI) 

Satellite PRG 8 8 Lead 8 8 8 8

downlink training sessions VHS training PRG 8 8 Lead 8 8 8 8tapes On-site training OC 8 8 8 Lead 8 8 8

and certification (NETI) Example ESD Lead 8 8 888 8 8 8 8 8 8 

conditions for Title V operatingpermitsTest method EMAD 8 8 88 Lead training 
MACT: 

Table 5-1. Model Tool Development Agreement (continued)

 Implementation Lead

Materials Y/N Group ESD OPG IIG IMG ITG EOG PRG OC ORE

Participantsa

ITPID OECA PRRMS EMAD OGC 

b

Test method EMAD 8 8 88 Lead 

training 

Source ID/

Outreach/ SmallBusiness

Source OC 8 Lead 8 8 

identification effort (beyondcookbookinformation provided inAppendix G )Brochures/ PRG 8 8 Lead 8 8 8 8 8

pamphlets/ Plain English Guides(outreachmaterials)Small business ITG 8 Lead 8 8 8 8 8 8

assistance trainingSmall business ITG 8 Lead 8 8 8 8 8 8

outreach materialsSBREFA ESD Lead 8 8 8 8 8 8 8

compliance guide (if necessary)

a Participates as either a provider, preparer, or a reviewer (8)
MACT: 

Table 5-1. Model Tool Development Agreement (continued)

b PRG is responsible for coordinating development of the SMIP and the TDA upon request by ESD and negotiations between ESD and PRG..

c Identify which regional office or which state/local agency

* Generic EPA guidance will be used unless this rule is an exception to that guidance.

EMAD Emissions, Monitoring and Analysis Division OGC Office of General Counsel

EOG Education & Outreach Group OPG Operating Permits Group

ESD Emissions Standard Division ORE Office of Regulatory Enforcement

IIG Integrated Implementation Group PRG Program Review Group

IMG Information Management Group PRRMS Planning, Resources and Regional Management StaffITG Information Transfer Group RO Regional Offices

ITPID Information Transfer and Program Integration Division SBAP Small Business Assistance Program

OC Office of Compliance S/L/T State/Local/Tribal EntitiesOECA Office of Enforcement and Compliance Assurance NETI National Enforcement Training Institute
 

APPENDIX A

Interview Questions for MACT Development Team and Implementors
5-1 

Interview Questions for MACT Developers and Implementors 

to Help Jointly Determine What is Needed for Implementation

This list of questions was designed as an optional In-Person Oral Interview Guide or Tool for

informal discussions of currently available information (or where it may be obtained) as input

for the developers and representative implementors to jointly develop an implementation plan

(i.e., what is needed when) for a specific MACT standard. Precise answers are not necessary. 

Nor do all questions need to be answered at the time of the interview. The initial goal is merely

to obtain enough information to develop a draft plan, including what tools are most needed.. 

Affected Sources

1. How many sources are affected?

What percentage are small?

How many small business or governments are affected?

Is rule subject to SBREFA?

2. Is it known which sources are affected?

How exhaustive is the inventory?

Is there a list of sources?

Does it include locations, addresses, telephone numbers, contacts?

Do you know anyone else that may have a source list?

3. Is this industry already Federally regulated? If so, how?

Are there State/local/tribal rules? If so, what is their general level of control?

4. How many States have affected sources?

How involved have the States and Regions been in developing this standard?

How ready are the States to implement this standard?

Applicability

5. Explain how the source determines if this rule applies to them. 

Specifically, what does the source have to do to determine applicability?

Is this straightforward? That is, what is the level of difficulty for small and large sources to

determine applicability?

Where is this protocol described?

What additional information will the source need to obtain, develop, or record?

Cost of the Regulation

6. What is the cost to comply with this rule?

Benefits of the Regulation

7. What emissions reductions will be achieved?

Which pollutants? What are the general health risks associated with these reductions?
5-2 

Coordination with Stakeholders

8. What level of participation have you received from industry, trade groups, environmental

groups, States, locals, Tribes?

What outreach to States/locals/tribes and industry is necessary?

What education do the Regional Offices need?

Are they calling you with many questions? What would help them answer the questions?

What outreach/education has been requested by the Stakeholders?

What have you done or planned?

9. Who are the relevant trade groups?

How active do you expect them to be in educating their members?

 

10. Who is the Office of Compliance contact?

Office of Regulatory Enforcement?

Office of General Counsel?

Regional Office contacts?

State contacts?

Locals?

Tribes?

Permitting?

What has been the level of participation of these individuals in rule development?

Have they pointed out any implementation concerns?

Have they committed to help on implementation aspects?

 

Real-World Climate

11. What is the climate in EPA, Congress, industry, States, locals, tribes, and the public for this 

rule? Is it a high-profile rule?

Who are the advocates for this rule?

Who are the adversaries for this rule?

12. Has EPA been sued or do you expect EPA to be sued on this rule?

Complexity of the Rule and Compliance Assurance

13. How complex are the requirements?

What are the control and monitoring requirements of the MACT?

How many options are there?

How does the source determine which controls or pollution prevention options are 

appropriate?

Are the monitoring requirements consistent with the enhanced monitoring provision of

section 114(a)(3)? (timely, accurate, replicable) If not, how do they differ?

What are the monitoring system performance specifications and calibration and QA/QC

requirements? Monitoring data availability requirements?

Are any excursions from required monitoring parameters excused from consideration as 

violations of the emission standard?

What are the reporting and recordkeeping requirements? 
5-3 

14. Does the standard require the source to develop inspection/maintenance procedures and an

operating plan? What are the criteria for approvable procedures and plans? 

15. Are inspector checklists needed? Would they be helpful to Regional Offices, states, locals,

tribes, industry? Are examples available?

16. Are there example forms or checklists for the source to use for demonstrating compliance?

17. What are the compliance dates?

18. Is there an Enabling Document available? Are there any gaps in the information available?
 

APPENDIX B

Tool Development Agreement
1

MACT: 

Tool Development Agreement

 Implementation Lead

Materials Y/N Group ESD OPG IIG IMG ITG EOG PRG OC ORE

Participantsa

ITPID OECA PRRMS EMAD OGC 

b

BASELINE

AdministrativeContacts list for

implementorsSpecific guidanceon delegations*Summary ofrecordkeepingand reportingrequirementsSpecific guidanceon compliancecertification,assurance, andenforcementpolicy*Specific datareporting aspectsof AIRS*Specific datareporting aspectsof MACTdatabase*Specific datareporting aspectsof MACTRAX*Timeline: complianceschedule
MACT: 

Tool Development Agreement (continued)

 Implementation Lead

Materials Y/N Group ESD OPG IIG IMG ITG EOG PRG OC ORE

Participantsa

ITPID OECA PRRMS EMAD OGC 

b

2

TechnicalFact sheets

(general, technical, andpress release)Summary of thestandardCurrentlyavailable list ofaffected sources Examples ofapplicablereporting forms(e.g., initialnotification,initial statementof compliance foreach controldevice,checklists).Applicabilityflow chartsSamplecalculationsInspectorchecklistsSummary oftesting andmonitoringrequirements
MACT: 

Tool Development Agreement (continued)

 Implementation Lead

Materials Y/N Group ESD OPG IIG IMG ITG EOG PRG OC ORE

Participantsa

ITPID OECA PRRMS EMAD OGC 

b

3

Operations and

maintenanceplans/requirementsTechnicalsupportdocumentSpecialrelationships toTitle V, NSR,PTE*

ENHANCEDTechnical

Training

“CD-ROM”

interactive toolson trainingFederal RegisterhypertextWorkshops (sitespecific)Satellitedownlink trainingsessionsVHS trainingtapesOn-site trainingand certification
MACT: 

Tool Development Agreement (continued)

 Implementation Lead

Materials Y/N Group ESD OPG IIG IMG ITG EOG PRG OC ORE

Participantsa

ITPID OECA PRRMS EMAD OGC 

b

4

Example

conditions forTitle V operatingpermitsTest methodtraining

Source ID/

Outreach/ SmallBusiness

Source

identificationeffort (beyondcookbookinformation provided inAppendix G )Brochures/pamphlets/ PlainEnglish Guides(outreachmaterials)Small businessassistancetrainingSmall businessoutreachmaterialsSBREFAcompliance guide(if necessary)

a Participates as either a provider, preparer, or a reviewer (8)

b PRG is responsible for coordinating development of the SMIP and the TDA upon request by ESD and negotiations between ESD and PRG..
MACT: 

Tool Development Agreement (continued)

5

c Identify which regional office or which state/local agency

* Generic EPA guidance will be used unless this rule is an exception to that guidance.

EMAD Emissions, Monitoring and Analysis Division OGC Office of General Counsel

EOG Education & Outreach Group OPG Operating Permits Group

ESD Emissions Standard Division ORE Office of Regulatory Enforcement

IIG Integrated Implementation Group PRG Program Review Group

IMG Information Management Group PRRMS Planning, Resources and Regional Management Staff

ITG Information Transfer Group RO Regional Offices

ITPID Information Transfer and Program Integration Division SBAP Small Business Assistance Program

OC Office of Compliance S/L/T State/Local/Tribal EntitiesOECA Office of Enforcement and Compliance Assurance NETI National Enforcement Training Institute
5-6 

APPENDIX C

Cost Estimates for Education and Outreach
5-1 

COST ESTIMATES FOR EDUCATION AND OUTREACH

COST ACTIVITY

$25,000 Estimated cost to develop one day of a classroom training course

(e.g., a four day course would be $100,000). This estimate also

holds for development of self-study materials and technical

manuals, with a manual of about 250 pages being roughly

equivalent to a 3 day classroom course (i.e, $75,000).

$ 2,800 Studio usage for about 5 hours. Includes taping, re-takes and

some graphics support. This amount is also used in estimating

the studio costs for a 5 hour (one day) broadcast.

$ 2,800 plus travel expenses. Estimated cost for field shoots using two

people and camera for about half a day.

$ 400 Estimated hourly cost for uplink usage.

$ 1,500 Estimated cost per minute for finished, broadcast quality video

tape. This is known as a NOVA quality video.

NOTES: • Costs associated with development of high quality CD-ROMS are not yet

available.

• These estimates or “Rules of Thumb” are only rough estimates that should be

helpful in early training and planning sessions. These estimates are still tentative

and are subject to change.

• These estimates can and must be substantially more refined as specific

requirements are known. So, the earlier the Education and Outreach Group

(EOG) becomes involved in the process, the more quickly a reliable cost estimate

can be made.

• The EPA/STAPPA/ALAPCO Training Committee is currently developing a

template for training efforts and has a continuing function of considering training

priorities and coordinating efforts.

C For further information, contact Ron Townsend (919) 541-2498 for MACTspecific planning efforts.
 

APPENDIX D

Unified Air Toxics Website Information
5-1

UNIFIED AIR TOXICS WEBSITE

http://www.epa.gov/ttn/uatw/

SYSOP: Holly Reid, (919) 541-5344

 Nancy Pate, (919) 541-5347

Purpose of Website - To provide the general public, federal, state and local governments and

sources of air toxics pollution information (from basic to very technical) in a centralized location

on the internet. To encourage sharing of information, especially among the federal, state, and

local governments in, order to reduce duplication of effort when implementing air toxics rules and

programs..

Brief description of the 6 areas planned for this website:

Basic Facts

C Describes Unified Air Toxics Website

C Briefly explains what air toxics pollutants and their effects are

C Provides links to citizen guides and brochures on health risks of air toxics and other basic

sources of information

EPA Rules and Implementation

C Lists all air toxics rules and closely related rules

C Provides links to all preamble and rule texts, related policy guidance and access to

implementation materials produced by federal, state or local agencies.

Pollutants and Sources

C Lists the 188 toxic air pollutants regulated by the EPA

C Defines types of air toxic pollutants sources

C Lists 174 source categories of industrial and commercial sources of air toxics

Technical Resources

C List telephone information resources (such as hotlines) and internet technical information

resources (such as centers, clearinghouses) with air toxics information 

C Gives access to select published technical documents and links to document information

resources

EPA Programs

C Describes air toxics programs and its major components 

C Lists all EPA offices with air toxics responsibilities and describes their roles
5-2

State and Local Agency Programs

C Describes federal, state and local air toxics program partnership

C Lists state and local air agency program websites

C Provides a “sharing library” for states and local agencies without websites to display work

products in one centralized location

Topic Areas Per Source Category

Examples of Rule and Implementation Information on this Website

- Proposals, Promulgations

- Background Information and Guidance documents

- FR text

- Contact List

- Fact Sheets (HQ press releases, source list, technical information reports, state fact sheets)

- Source Information (list of potential affected sources, 1990 document for developing source

category list, 1987 Toxic Air Pollutant Source Crosswalk)

- MACT Summary Table and tracking information

- Risk information

- Outreach materials

- Training and workshops

- Presentation and workshops

- Semi-annual summary reports from MACTRAX (Delegation and implementation status)

- Schedules

- Permitting information (initial permit notification forms, permit conditions and guidance,

non-traditional source information, inspection forms and checklists)

- Compliance, Assistance, and Assurance Information (sector notebooks, compliance data,

applicability determination)

- Enforcement

- Environmental indicators

- Questions and answers subsystem 
APPENDIX E

AIRS Facility Subsystem
 5-1

AIRS FACILITY SUBSYSTEM

C AIRS stands for Aerometric Information Retrieval System.

C AIRS is the database management system for the national database for ambient air quality,

emissions (criteria and air toxics related), and compliance data, including permit tracking.

C The AIRS Facility Subsystem (AFS) is one of four subsystems under AIRS. Re- engineering

project currently scheduled to begin in fiscal year 1998.

C Information included in AFS:

< Number and location of facilities in a source category

< Types of control equipment with efficiency estimates

< Emissions estimations from EPA Reference test methods

C For more information, contact Chuck Isbell (ITPID/Information Management Group) at (919)

541-5448.
 

APPENDIX F

Example Specific Model Implementation Plan

 for Ethylene Oxide Commercial Sterilizers MACT Standard
5-1 

Example SMIP for Ethylene Oxide Commercial Sterilizers

The following is a sample of what a Specific MACT Implementation Strategy should

resemble. It includes an explanation of the implementation phases for this regulation. Additional

implementation aids such as applicability flow charts or examples, source listings, trade

associations, specific source identification techniques, standard permit language, inspection

checklists, etc. are not included at this time but are under consideration. 

Even though this regulation has already been promulgated, this sample implementation 

strategy is written as if it was published with the rule. As a result, some sections will refer to

steps that may have already occurred.

Regulation Summary

! Regulation: Ethylene Oxide Sterilization Facilities

! This regulation controls ethylene oxide emissions for sterilization or fumigation

operations.

! Citation: 40 CFR Part 63, Subpart O

! Published: 59 FR 62585

! Effective Date: December 6, 1994

! Applicability: All sterilization sources using ethylene oxide in sterilization or

fumigation operations

! Exemptions: beehive fumigators, research and laboratory facilities, and

operations at sources like doctor or veterinarian offices

! Categories: 1. Sources using less than 1 ton of ethylene oxide are only

required to keep records of 12 month rolling average of

ethylene oxide use

2. Sources using between 1 ton and 10 tons of ethylene oxide

3. Sources using 10 tons or more of ethylene oxide 

! Initial Notification: 1. April 5, 1995 for existing sources, categories 2 & 3

2. 120 days from startup for new sources, categories 2 & 3

! Compliance Dates: 1. December 6, 1998 for sources with startup before

December 8, 1998 

2. Upon startup for sources with startup on or after

December 8, 1998
5-2 

! Emission Points: 1. Sterilization Chamber Vent

99% reduction for categories 2 & 3

2. Aeration Room Vent

99% reduction or 1 ppmv for category 3

3. Chamber Exhaust Vent

99% reduction for category 3

5300 ppmv for category 2

! Performance Tests: June 4, 1999 for existing sources, all emission points 180 days after

startup for new sources, all emission points

! Notification of

Compliance Status: August 3, 1999 for existing sources, all emission points 60 days

after completion of performance tests for new sources, all emission

points

Phase One - Education

EPA will be offering satellite training on this regulation on {date}. The regional offices

should assess their own interest and that of their states and ensure appropriate attendance. The

satellite training will also be video taped. The video tape will be available from {location}, and

EPA expects the video to be available after {date}. 

In addition to this training, EPA has issued a fact sheet which is available on the TTN

bulletin board along with the regulation and the background information document. On TTN, the

fact sheet and rule are dated November 23, 1994 and located in the "Recently Signed Rule"

section of the Clean Air Act board. The background information document, dated June 17, 1993,

is located in the "Title III" section of the same board. Furthermore, the OAQPS Title III online

Q&A bulletin board is available for inquiries about this rule. This information is also accessible

via the United Air Toxic Website at Http://www.epa.gov/oar/oaqps/airtox.

The following are a list of contacts for this rule:

OAQPS: David Markwordt (919) 541-0837

OECA: Karin Leff (202) 564-7068

Region 1: {name}

Region 2: {name}

Region 3: {name}

Region 4: Phillip Barnett (404) 347-2904

Region 5: {name}

Region 6: {name}

Region 7: {name}

Region 8: {name}

Region 9: {name}

Region 10: {name}
5-3 

In addition, this rule may impact small businesses; additional assistance regarding this issue

may be obtained the following regional small business contacts:

Region 1: {name}

Region 2: {name}

Region 3: {name}

Region 4: {name}

Region 5: {name}

Region 6: {name}

Region 7: {name}

Region 8: {name}

Region 9: {name}

Region 10: {name}

Each region should also establish a contact for each of its states and begin communication

regarding the regulation. Regular conference calls, either for this rule alone or as part of a larger

call, are appropriate.

Phase Two - Source Population Identification

Since this rule involves area sources, EPA recommends following the practices and

procedures for identifying sources presented in the "Cookbook" prepared by EPA. Following

these procedures, EPA does not anticipate any difficult applicability questions for these sources.

Phase Three - Outreach

EPA has prepared a fact sheet about this rule and is currently preparing an implementation

document that includes summaries of the requirements of the rule, applicability flow diagrams,

example recordkeeping and reporting forms, inspector checklists, and other information to help

implementation. The video of the satellite training course may provide material to educate the

regulated community about the rule. The implementing agency and regions should be available

for any trade shows related to this industry. Coordination with the small business assistance

program for this regulation is advised.

Source population identification and outreach for this rule should be executed quickly as

the initial notifications are due by April 5, 1995 for existing sources. However, additional time for

outreach is provided in that the first compliance date is December 6, 1998, for an existing source.

Although pollution prevention activities for this source category may be limited, affected

sources should be encouraged to investigate alternative sterilization techniques like antiseptic

washes and thermal drying or using an autoclave where such techniques may be appropriate.

Regional Pollution Prevention Contacts are:
5-4 

Region 1 {name}

Region 2 {name}

Region 3: {name}

Region 4 {name}

Region 5 {name}:

Region 6: {name}

Region 7: {name}

Region 8: {name}

Region 9: {name}

Region 10: {name}

Phase Four - Compliance Assurance

This phase does not begin in earnest until after December 6, 1998. However, the initial

notification is necessary by April 5, 1995. Appropriate information requests may be necessary to

obtain all initial notifications.

Beginning in December 1998, the implementing agency should include this source

category in their inspection planning. As part of this, the implementing agency needs to assure a

presence in the regulated community particularly during the early period after a compliance date. 

If a state or local agency is implementing the rule and is inspecting all major sources, then the

major ethylene oxide sterilization facilities will be addressed. If the state is using the Inspection

Targeting Model or some other targeting method, the agency should assign enough weight to this

source category to insure appropriate coverage. Area sources within a state are somewhat

different. Compliance assurance may be achieved by a combination of techniques including

requiring reports, certifications, record keeping, etc. These factors are usually imposed through

the permitting process.

If EPA is the implementing agency, targeting of major and area sources for inspection is

also needed. Due to EPA's more limited number of inspectors, consideration of regional

resources is important. EPA can maintain a sufficient presence within the sector by using regional

personnel and perhaps contractors. Furthermore, even if EPA is not the implementing agency, the

regional office may wish to establish a small federal inspection presence among the sterilization

facilities.

As time moves beyond the compliance date, less emphasis to this sector may be applied if

compliance rates are good. However, after several years, the sector should be targeted again. In

order to determine compliance rates, the implementing agency must establish a tracking system. 

AIRS is available for this function. If an implementing agency uses another system other than

AIRS, the agency must also ensure that AIRS is updated in accordance with EPA policy on

minimum data elements.

Finally, as part of assessing compliance, the implementing agency needs to decide how to

deal with violations. Whatever the decision, the plan for each implementing agency should be
5-5 

internally consistent and should include pollution prevention options. For this rule, compliance

assistance is not generally advised because there is a period of two and half years to prepare for

the requirements. As stated in phase three, affected sources should be encouraged to investigate

alternative sterilization techniques. Some area sources or small businesses may be granted some

assistance if they have trouble establishing initial compliance, such as an opportunity to re-test.

Phase Five - Enforcement

Notwithstanding any discussion of compliance assistance, the implementing agency should

proceed with enforcement of violations involving an exceedance of an emission limit or a failure

to conduct monitoring. The agency may use its enforcement discretion regarding a single

reporting omissions, such as failure to submit timely an initial notification or a compliance

certification notification, provided prompt correction is made. Enforcement is appropriate for

repeat omissions involving any standard.

Since this rule regulates area sources, the regional offices should consider using field

citations for violations that merit an action. This would simplify the process for the source and

EPA. Also, whenever a SEP is considered as part of an enforcement case settlement, pollution

prevention activities should be encouraged.

Phase Six - Additional Activities

One of the major ancillary activities will involve the permitting of the sources. All sources

other than those using less than one ton of ethylene oxide are required to obtain a Title V permit. 

The permit must contain:

1. the requirement for the initial notification;

2. the emission standards for sterilization chamber vents, aeration room vents, and 

chamber exhaust vents; 

1. the compliance date for each emission point; 

2. the performance test requirement for each vent; 

3. the requirement for the notification of compliance status; 

4. the monitoring requirements;

5. the reporting requirements; and 

6. the applicable General Provisions.
5-6 

Many of these requirements are highlighted in the regulation summary section at the

beginning of this report.

With respect to the General Provisions, the permit may reference the General Provisions

without restating each minute section or may explicitly state each portion. The implementing

agency should be advised that explicitly including all requirements in the General Provisions will

result in a larger permitting effort. Also, many times the General Provisions include options. To

address the options, the permitting agency must answer the following: does the permit contain all

options, growing even larger, or does the permit only contain the options appropriate for the

source? If the latter is used, the permit may have to be reopened every time a source switches

options. Regardless of the technique used to include the General Provisions, the reference table

within the regulation is an excellent guide between the two options.

For area sources, the Title V permitting requirement has been deferred for five years from

the approval of a state’s Title V program. These source must submit their permit application

within 12 months of the expiration of the deferral period.

Other additional activities include processing of special requests: compliance extensions,

performance test waivers, etc. Sufficient resources should be allocated to cover the processing of

these requests. For this rule, such requests should not be excessive. However, there will be

performance tests for multiple emission points for each facility, and these results will need a

review. An implementing agency should anticipate most of these test results beginning in June

1998 and ending in August 1988.

Reference Materials

The following list contains reference materials for this rule and their location.

C Background Information Document (BID), TTN - Clean Air Act Board, Title III Section

etc.
 

APPENDIX G

Source Identification Cookbook
Source Identification Cookbook

Final Draft September 23, 1997

 

ENABLING DOCUMENT

SOURCE IDENTIFICATION PROCEDURES FOR SOURCES

SUBJECT TO REGULATIONS UNDER SECTION 112(d) OF THE

CLEAN AIR ACT AS AMENDED IN 1990

Developed in Cooperation with 

US Environmental Protection Agency

(Region 4, OAQPS, & OECA)

State of Georgia

State of New York

State of Florida

State of Illinois

[ PLEASE REVIEW AND SUBMIT ALL WRITTEN COMMENTS BY

OCTOBER 14, 1996. WRITTEN COMMENTS SHOULD BE MAILED TO:

ANTHONY TONEY

U.S. EPA REGION 4

APTMD

ATLANTA FEDERAL CENTER, 12th FLOOR

100 ALABAMA STREET, N.W.

ATLANTA, GA 30303
 5-ix

TABLE OF CONTENTS

Section Page

ACKNOWLEDGEMENT ..................................................... 1

NOTICE .................................................................. 2

1.0 INTRODUCTION ................................................... 1-1

1.1 Purpose ..................................................... 1-1

1.2 Background .................................................. 1-1

1.3 MACT Implementation Schedule .................................. 1-2

2.0 MACT SOURCE IDENTIFICATION PROCESS ........................... 2-1

2.1 Step 1 ....................................................... 2-3

2.l.1 State/County/Local Business License Processes ................. 2-4

2.1.2 County & City Chamber of Commerce ........................ 2-4

2.1.3 Regional Telephone Directory (i.e., WinPhone, PhoneDisc '95, etc.) . . 2-5

2.1.4 Databases of Corporate Affiliations (e.g., Business Dunn and 

Bradstreet) ............................................. 2-5

2.1.5 Department of Industry & Trade/Commerce .................... 2-6

2.2 Step 2 ....................................................... 2-6

2.2.1 State Department of Revenue ............................... 2-6

2.2.2 State and Local Agency Resources ........................... 2-6

2.2.3 Toxic Release Inventory ................................... 2-7

2.2.4 EPA's RCRA Hazardous Waste Disposal Notification Database ..... 2-7

2.3 Step 3 ....................................................... 2-8

2.3.1 Industry Representatives ................................... 2-8

2.3.2 Trade Associations ....................................... 2-8

2.3.3 Equipment & Raw Material Suppliers/End Product Users .......... 2-9

3.0 COLLOCATED SOURCES ........................................... 3-1

3.1 Collocation, Federally Enforceable Limits, and PTE Policy ............... 3-2

4.0 RESULTS OF PILOT TESTING FOR EXISTING MACTs AND STATE

GENERATED LIST ................................................. 4-1

4.1 State of New York MACT Source Identification Pilot Study ............. 4-1

4.1.1 CD-ROM Databases ...................................... 4-1

4.1.2 Chromium Electroplaters .................................. 4-2

4.1.3 Wood Furniture Manufacturers .............................. 4-3

4.1.4 Conclusion ............................................. 4-4

4.1.5 Other CD-ROM Databases ................................. 4-5
TABLE OF CONTENTS (Continued)

Section Page

 5-x

4.2 State Of Georgia Halogenated Solvent Cleaning

Machine Pilot Study ............................................ 4-5

4.2.1 Introduction ............................................ 4-5

4.2.2 Study and Results ........................................ 4-6

4.2.3 Conclusions ............................................ 4-6

4.2.4 Collocated Sources ....................................... 4-7

4.2.5 Wood Furniture Cookbook ................................. 4-8

4.3 Florida Source Identification Pilot Study ............................. 4-8

4.4 Illinois Environmental Protection Agency (IEPA) ..................... 4-10

APPENDIX A

APPENDIX B

APPENDIX C

APPENDIX D

APPENDIX E

APPENDIX F

APPENDIX G
 5-1

ACKNOWLEDGMENT

This document was prepared by the U.S. Environmental Protection Agency as a result of

Brown Summit II, April 10-12, 1995, in North Carolina. This document is the result of a joint

effort of the following workgroup: Anthony Toney, Linda Anderson-Carnahan, USEPA

Region 4; John Schaefer, EPA OAQPS; Jeff Kenknight, EPA OECA; Susan Fields, Nebraska

Department of Environmental Quality; Jimmy Johnston, Art Stelson and Cindy McAlpine,

Georgia Environmental Protection Division; Mary Sullivan Douglas, STAPPA/ALAPCO; Hank

Naour, Illinois EPA, Bureau of Air Quality; Sarah Laumann, Colorado Department of Health;

John Glunn and Alex Meng, State of Florida Department of Environmental Protection; Thomas

Gentile and Barbara Nuffer, New York State Department of Environmental Conservation. 

EPA would like to thank all individuals that contributed their efforts toward the

development of this project. Your assistance is duly noted and appreciated.
 5-2

NOTICE

This document has been reviewed in accordance with U.S. Environmental Protection

Agency policy and approved for publication. Mention of trade names or commercial products

does not constitute endorsement or recommendation for use.
 1-1

1.0 INTRODUCTION

1.1 Purpose

The primary purpose of this document is to provide State and local environmental

regulatory agencies guidance for identifying and compiling a list of sources subject to regulation

under section 112(d) of the Clean Air Act as amended in 1990. In general, this document

contains guidelines and/or procedures on suggested activities which can be undertaken to identify

such sources subject to maximum available control technology (MACT) standards. Use of this

document will facilitate the efficient implementation of all MACT standards and ensure the level

of environmental protection mandated by the Act. The document assumes a general knowledge

of title III of the Act and the promulgated regulations thereto. Readers not familiar with these

programs should refer to the sections mentioned in the "Background" and to the General

Provision for MACT implementation, 40 CFR 63, Subpart A. This document should clarify

typical questions regarding source identification and should help facilitate the development of

comprehensive lists of affected facilities. As we learn more through the actual process of source

identification, this document will be revised accordingly. It is hoped that this document becomes

an evolving, "living document" that will experience continuous improvement through the fine

tuning of the source identification process.

1.2 Background

Critical to an agency's success in limiting hazardous air pollutant emissions is its ability to

identify sources subject to MACT standards. Listings of specific sources subject to MACT or

procedures that can be used to identify sources within a jurisdiction are necessary for a number of

reasons. The resources required of a regulatory agency to implement a standard will be a function

of the number of sources subject to the MACT. Further, because some sources will not be

required to obtain a title V permit, state and local agencies willing to oversee implementation of

such standards for non-Part 70 sources need to be able to gauge the resources required in order to
 1-2

make a commitment. Finally, sources must be easily and quickly identified to facilitate the

transfer of information on new standards. 

During an April 1995 meeting of EPA OAQPS, OECA, OGC and Regional Offices with

State and Local air program representatives (Brown Summit II), one of the action items identified

included the development of a standard method to identify sources subject to MACT standards. 

The workgroup convened on this action item envisioned the development of a "cookbook" for

this process. 

1.3 MACT Implementation Schedule

 With the promulgation of each MACT standard, there are several administrative actions which

must be undertaken in a relatively short time-frame. These requirements dictate the need for a

comprehensive listing of subject sources. A comprehensive listing of subject sources will ensure

the proper allocation of resources by the implementing agencies. Although MACT requirements

will vary depending on whether a source is an existing, new area or new major facility, the main

events for a facility subject to MACT standards (primarily major sources) are listed below:

1. Source submits an initial notification no later than 120 days after the effective date

of a relevant standard.

2. Source submits a notification at least 60 days before conducting a performance

test; at least 30 days before conducting opacity and visible emission observations. 

3. A source submits a notification of compliance status within 60 days after the

performance test. 

The above listed activity deadlines may be overridden by the specific requirements listed in

an individual MACT standard.
 2-1

2.0 MACT SOURCE IDENTIFICATION PROCESS

Ideally, in the process of developing a MACT for a source category, EPA will attempt to

identify all of the subject facilities in the process of gathering information for the standard. It is

anticipated that specific information (i.e., names and addresses) on subject sources will eventually

be made available by EPA on an electronic database. Unfortunately, a survey of MACT

development project leaders suggests that a complete listing of sources has not and will not be

available in many cases. Furthermore, state and local agencies have sometimes found that lists

provided by EPA can be inaccurate, incomplete or outdated. Although this document will be

applicable to all MACT source categories, we have initially identified two generic groups of hard

to locate sources to which this document will predominantly apply: 1) small, numerous sources

(e.g., dry cleaners); and 2) co-located sources (e.g., halogenated solvent cleaning operations). 

Appendix A contains a listing of the MACT categories and identifies those standards for which a

complete list of subject sources will likely not be available from EPA. The table also contains the

anticipated SIC codes for the source category, the estimated number of subject facilities, their

trade associations, and whether the sources are expected to be collocated in other source

categories.
 2-2

Contained in this section are procedures which can be used to assist in the identification of

sources potentially subject to MACT standards. The procedures outlined in this section should

provide the most effective mechanism for source identification. The initial steps of the following

source identification procedure are designed to provide a comprehensive list of sources potentially

subject to the standard in question. Subsequent steps in the source identification process will

serve to narrow down the list to the sources most likely to be subject to the standard. This series

of steps has been constructed so that at any time during the source identification process, if the

implementing agency feels comfortable that the list is adequate and sufficient, the agency may

decide that it is more efficient to contact all sources identified as opposed to taking additional

steps to narrow down the universe. Implementing agencies may wish to perform the various steps

as they deem appropriate given the nature of the source category and the agency's available

resources (i.e., it may be appropriate to omit early steps and perform the later steps). 

While EPA does not have access to all information necessary to assist in identifying every

affected source, this document contains a prioritized list of resources which could greatly enhance

the process of source identification. Because many of the resources available to state and local

agencies use the Standard Industrial Classification (SIC) codes to identify facilities, the first and

primary step in the identification process is to compile a list of potentially applicable SIC codes. 

A partial listing of SIC codes may be obtained from Appendix A and/or the Background

Information Documents (BID) for each source category as identified by Project Number in

Appendix D. During the standard development process, EPA attempts to identify a list of facility

SIC codes in which the processes subject to the MACT may be located. This information is made

a formal part of the BID and is maintained as a part of the docket for each respective MACT

standards. However, the list of SIC codes identified may not be comprehensive because the

facilities operating within each particular source category type are not specific to that one

manufacturing process. In the initial stages of MACT development, OAQPS & ORD

Environmental Criteria and Assessment Office make every effort to generate a listing of potential

sources subject to standard. After the proposal, information from the docket may be secured

from each respective MACT project lead. A list of the current MACT project leads has been
 2-3

included as Attachment D of this document. After the MACT standard has been proposed, the

docket information may be obtained from the EPA Docket Center or the OAQPS MACT project

lead. As previously mentioned, it is hoped that OAQPS will eventually make the list of sources

identified for each MACT available through an electronic bulletin board system. Such a system

would also allow users to share additional information on source identification techniques as well

as outreach materials developed by different agencies. 

Source identification will usually be a multi-step process which may include the following

activities: (1) development of a list of potential sources; (2) determining which sources are

actually employing the regulated process/equipment or emit the hazardous air pollutant (HAP);

and (3) determining which sources are potentially major, those that will probably seek synthetic

area status, and those which are area sources. The reliability of these listings can be greatly

enhanced through the use of databases, correspondences/dialogue with possible sources, site

visits, agency knowledge and expertise, etc. Throughout the identification process, the

implementing agency should review the generated lists and determine their usefulness. If a list

consists of numerous sources which are obviously not subject to the specific standard, that

particular database may not be appropriate for this process. This situation may occur when the

SIC code is too broad. The recommended activities and/or resources for identifying sources are

listed below:

2.1 Step 1

The EPA will make every effort to provide as much information on specific sources as

possible. The EPA will distribute (or make reasonably available) to each Regional Office the

source identification information obtained during the standard development process. Each

Regional Office will in-turn disseminate information to the respective implementing agencies. 

Using these lists and the information in this "cookbook", each agency should review the

information to determine if any additional identification activities are warranted. Additionally, as

a result of another Brown Summit II action item, EPA is working with state and local agencies to
 2-4

develop an interactive, electronic bulletin board system to disseminate and receive information on

section 112. It is anticipated that a list of identified sources subject to each MACT standard, by

state, will be available on this system. 

Starting with the list of facility SIC codes in which the processes subject to the MACT

may be located (and any additional information available from the EPA), there are a number of

databases and information sources that can be used to locate the names and addresses of

potentially subject facilities. Lists developed from the following databases should be crosschecked against each other to enhance the level of accuracy of the final product, to better define

actual functions of facilities (users vs. Sellers), and to eliminate duplicitave listings from the final

list. Outlined below is a listing of such databases and/or resources: 

2.l.1 State/County/Local Business License Processes

Within each state, county, or local governmental structure, there should be an entity

responsible for issuing business licenses. These agencies should have the capacity to download

information via a computer based on SIC codes or facility types and provide a list of facilities

potentially subject to a specific MACT standard, including names and mailing addresses. These

resources are usually housed within the Revenue and License Departments. Generally, there is a

service charge for the compilation of this information. 

2.1.2 County & City Chamber of Commerce

Chambers of Commerce offices have the capability of supplying a listing of facilities within

their jurisdictions or memberships that fall within specified SIC categories. These offices may be

contacted as to the specific procedures one must follow. There maybe a fee for such services in

some areas.
 2-5

2.1.3 Regional Telephone Directory (i.e., WinPhone, PhoneDisc '95, etc.)

This directory provides a comprehensive listing of all businesses which serve in some

capacity, e.g., sales, manufacturing, repair, etc., under the respective SIC codes. The list is not

always reliable because many listed organizations are not producers or users of the HAPs. 

Additionally, the source's operations (e.g., name, location) may have changed, reducing the

accuracy of the information. One can specify the business type by either its SIC code or by

selecting a key word or phrase. A word of caution, the address provided by this database is the

physical location, not the mailing address. Telephone directories of this type may generally be

obtained from any retail store that sells software packages, e.g., Office Depot, Best Buys,

Compuworld, etc. PhoneDisc is a common brand name that is generally available. Additional

information on PhoneDisc can be obtained by calling 1-800-284-8353 or (617) 639-2900. 

2.1.4 Databases of Corporate Affiliations (e.g., Business Dunn and Bradstreet)

Database software systems such as Dunn & Bradstreet contains a vast amount of useful

business information. Included in the database are parent companies headquartered in the United

States and their subsidiaries, affiliates, and joint ventures. Dunn and Bradstreet offers an easy way

to identify facilities (name and location) and corresponding information such as type of business

and contact persons, based on various forms of facility identification information, including SIC

codes. With Dunn and Bradstreet, one can enter the SIC code or type of business and generate a

listing of facilities within the database that are compatible with the specific search parameters. 

Additionally, Dunn and Bradstreet publishes a multi-volume Directory of Corporate Affiliations

which is the hard copy form of the Dunn and Bradstreet CD ROM version. These type software

packages may be obtained at various local retail computer software stores (Dunn and Bradstreet

database system can be obtained by contacting 1-800-234-3867).
 2-6

2.1.5 Department of Industry & Trade/Commerce

Within each state's governmental structure, the State Department of Industry and Trade or

Commerce has the capability of compiling an annual listing of all manufacturing facilities

operating during that fiscal year. The sources can be identified by SIC or facility type. A copy of

this publication can be obtained through the respective state's Industry and Trade or Commerce

office. The fee for this directory is generally less than $100.00. 

2.2 Step 2

To better refine the list of potential sources generated from the various databases, each

agency should then, to the extent possible, verify the list using the resources listed below which

should have available a more reliable list of known and currently operational facilities. 

2.2.1 State Department of Revenue

By canvassing the data sources above, a comprehensive list of potential-subject sources

may be generated. However, these references may not be completely up to date. A cross check

against recent annual taxation records may serve to narrow the list to currently operating facilities.

2.2.2 State and Local Agency Resources

Within each state and local agency there exists a wealth of knowledge relating to the

location, operation, and existence of sources located in the jurisdiction of the implementing

agency. Such in-house resources include: Enforcement staff, Small Business Assistance

Program, State.

Pollution Prevention Assistance Programs, State/Local Municipal Waste Treatment

Programs, state and local emission inventories, etc. Both staff and program documents may
 2-7

provide valuable leads and timesaving information. The Emission Inventory Development

Guidance published by EPA can serve as a valuable resource in the identification of sources. 

2.2.3 Toxic Release Inventory

It may be possible for regulatory agencies to further refine the list of potential sources

subject to a MACT through the use of the TRI database. Using the HAPs targeted by the MACT

for subject facilities, a cross check of the list generated by the above steps against a TRI list of

facilities with air emissions of targeted HAPs may reveal companies that are less likely to be

subject to the standard, regardless of their SIC code. One drawback of TRI is that many

industries/sources are exempt from its requirements. Also, TRI does not cover all HAPs. The

TRI database may be used to identify covered sources missed in steps 1-7. In this case, a list of

sources filing TRI reports of major emissions of the targeted HAPs is reviewed. This technique

may be especially useful when attempting to identify co-located MACT sources. (See Section 2.1

below) 

2.2.4 EPA's RCRA Hazardous Waste Disposal Notification Database

This database provides a cross-media search function for facilities which are currently

regulated by EPA. Searches within this database may be performed using specific facility

information such as SIC codes, chemical names, chemical releases, etc. Regulatory agencies can

manipulate this database to refine the list generated from steps 1-8 in the same way that the TRI

database is used.

2.3 Step 3

The following are additional resources that can be consulted for information on subject

sources. In many cases, it may not be possible to secure facility names and addresses from these

sources. However, these entities may be amenable to performing various outreach efforts and
 2-8

distributing information pertaining to the rules (e.g., source applicability and notification forms). 

If it is possible to secure a list of facilities from these sources, agencies may wish to utilize this

approach rather than to rely on SIC codes to develop a list of subject sources.

2.3.1 Industry Representatives

One resource often overlooked is industry experts themselves. When contact is made with

a source owner, operator, or environmental officer, much useful information may be obtained. It

is important that an agency representative present such a request as an effort to help potentially

covered sources get the information they need to achieve compliance. Such a request might be

presented in this way: "Do you know of anyone else that might be subject to this rule? I'd like to

get the information out to everyone so they'd have as much lead time as possible to consider the

implications of the rule."

2.3.2 Trade Associations

Regulatory agencies can solicit from national, regional or state associations, lists of

members which identify location and contact personnel for the facilities, or at a minimum, a list of

industry types which may be subject to the particular MACT standard. Trade associations

providing state and local agencies with a list of potentially subject facilities for outreach purposes

may benefit by increasing membership through offering meetings at which EPA makes

presentations on MACT standards. Implementing agencies also have the opportunity to publish

articles, notices, or announcements in trade journals for the affected industries. Although

developed by and for the State of Wisconsin, Attachment G contains a list of trade associations

generally located in each state which are related to various MACT categories. 

2.3.3 Equipment & Raw Material Suppliers/End Product Users
 2-9

Suppliers of raw materials (e.g., chlorinated solvents) and users of end products may

provide an additional resource of information on sources subject to MACT standards. Agencies

should contact the users or distributors of specialty products, materials, chemicals, or any raw

materials used in processes which are subject to MACT regulation, in an effort to obtain

information on the types of facilities, known users, etc. 
 3-1

3.0 COLLOCATED SOURCES

For many Part 63 standards, the regulated process is a small part of an overall

manufacturing process (i.e., degreasers, cooling towers, etc.). In these cases, the primary SIC

code of the facility in which the processes are located may be chiefly indicative of the primary

manufacturing process, rather than possible subordinate activities. For such collocated sources,

the databases and information resources listed in steps 1-6 may fail to generate a comprehensive

list of sources comprising the regulated activities. Therefore, additional efforts may be required

to generate an accurate list of the most likely collocated sources. 

First and foremost, collocated HAP sources are for the most part located at major HAP

sources. Such sources, because they are major, will be required to obtain title V permits, and

usually, will be required to file annual emission inventories to support the title V fee assessment. 

This mechanism can be utilized both directly and indirectly.

By working with the title V and emission inventory staff, the Title V permit application

and annual emission inventory forms can be crafted to directly identify activities which are

routinely collocated, such as degreasers, cooling towers or small boilers. For example, the form

could include a question tied to to a positive report of halogenated organic compounds, such as

"does the facility employ halogenated degreasing processes?" For collocation of other HAPemitting activities subject to various actual or scheduled MACT standards, collocated activities

may be identified indirectly, through review of the actual title V permit applications or annual

emission inventories submitted by major HAP sources. 

The permit application should identify all emission units responsible for emissions of

regulated pollutants, and provide enough information to identify most activities subject to major

MACT standards. If the application does not clearly indicate a source's status relative to other

MACT standards, HAPs reported in the annual emission inventory may suggest that collocation

may be involved. 
 3-2

An example of a collocated source could involve chromium electroplating collocated with

miscellaneous metal parts and products (surface coating) or reinforced plastics composite

production (the primary activity identified by the facility SIC code). Chromium electroplating is

often associated with metal parts manufacturing which is included in several surface coating

source categories, and could easily be distinguished from galvanizing (which is not included in a

listed source category) in the operating permit application itself. On the other hand, chromium

electroplating is less common at facilities involved in reinforced plastic composite production, but

would be suggested by chromium emissions reported in the annual emission inventory.

To obtain a greater sense of reliability, the list of sources identified through these activities

may be refined through various outreach efforts including mail-outs or questionnaires to verify

their status relative to suspected source categories. The level of effort expended by this process

will be governed by agency confidence in the quality of the list at this stage, as well as available

resources.

3.1 Collocation, Federally Enforceable Limits, and PTE Policy

In a memorandum dated May 16, 1995, from John Sietz, Director, EPA, OAQPS, relating

PTE timing issues, the applicability of MACT for collocated sources was presented. In brief, the

memo states that if a facility contains equipment or processes included in multiple source

categories, it is possible that after application of the initial MACT or an earlier MACT standard

reducing the HAP PTE, the status of the source relative to the remaining source categories may

be changed. If compliance with a MACT standard revises a facility's PTE to a level below major

source thresholds, the facility would not be subject to subsequent major source MACT standards. 

Additionally, the memo indicates that a facility may elect to take federally enforceable

limits to lower its PTE below major source thresholds, thereby avoiding the applicability of major

MACT standard(s). This option is available to covered sources up until the first compliance date

in each major MACT standard. Therefore, a source subject to multiple MACT standards might
 3-3

avoid the applicability of all standards by limiting its source-wide PTE before the first compliance

date in any of the standards.

Voluntary federally enforceable limits may also be taken by a source subject to multiple

MACT standards when compliance with a given standard or standards does not sufficiently

reduce the source's PTE. Such a HAP source may avoid coverage under subsequent standards by

taking additional voluntary federally enforceable limits until its source-wide PTE is below the

major source threshold, provided that the limits are taken before the first compliance date in each

of the standards it wishes to avoid.

Neither of these scenarios would relieve the facility from the applicability of those MACT

standards whose initial compliance date passed before the necessary reductions in PTE were

achieved. This "once major, not always major" policy is expected to reduce the burden of MACT

standards on collocated sources. However, the policy does complicate the identification of

sources subject to major source MACT standards, particularly if those standards are promulgated

within a relatively short time. In situations such as these, agencies may wish to identify sources

which have equipment or processes covered by the MACT standard as an initial step, and

subsequently determine major source applicability through additional correspondence or outreach. 
 4-1

4.0 RESULTS OF PILOT TESTING FOR EXISTING MACTs AND STATE

GENERATED LISTS

A number of states pilot tested the MACT identification approaches using lists of sources

previously generated by the regulatory agency for existing MACT standards for comparison. The

following section documents the findings of these pilots.

4.1 State of New York MACT Source Identification Pilot Study 

4.1.1 CD-ROM Databases

CD-ROM databases can be a valuable resource for identifying businesses in specific

industries. These businesses can be sorted by SIC (Standard Industrial Classification) codes or

Yellow Page headings. These databases can be used to create mailing lists of sources who may be

subject to regulations under Section 112(d) of the Clean Air Act as amended in 1990.

The best place to start a search for these databases is in your state library. The New York

State Library has a business CD-ROM database available for use by New York State employees. 

We have used this resource extensively to explore the potential for creating source lists and

discovered positive as well as negative features. Other databases have been located but not

researched and will be listed as potential resources. Most of these databases are available on a

trial basis before purchase for your own research, and we recommend that this be done.

We tested the American Business Disc (ABD), from American Business Information, Inc.

(1-900-555-5211). The following information is contained on the disc:

1. Company name

2. Address

3. Phone number
 4-2

4. Number of employees

5 . Estimated sales volume

6. Credit rating code

7. SIC code

8. Line of business description

You can perform the following searches:

1 . Geography- city, state, ZIP code, county or total U.S.

2. Company name

3. Yellow Page keyword

4. SIC code

5. Employee size range

6. Sales volume

Although you can download or print these records this can only be done for 50 records at

a time. The company will prepare more extensive lists for you for a fee. Since some of our lists

were in the 2,000 sources range, this was a major problem.

We extensively researched two industries with source lists previously compiled from other

databases, chromium electroplaters and wood furniture manufacturers, to cross check the

capability of the ABD to reproduce a similar list. These two searches were analyzed separately.

4.1.2 Chromium Electroplaters

It is impossible to sort out chromium electroplaters from general electroplaters based on

either SIC codes or Yellow Page keywords. We used the SIC code for Electroplating, Plating

and Polishing 3471. We found 268 sources in New York State using the ABD database,

178 sources were identified using the New York State Department of Labor (DOL) list of SIC
 4-3

code 3471. The New York State Department of Environmental Conservation (DEC) currently has

111 chromium electroplaters permitted in New York State. Only 67 of these 111 sources were

found on the ABD.

We have also cross-checked our permit information on chromium electroplaters with

notification forms received by the USEPA Region 2 Office. This cross-check indicated more

direct outreach to NESHAP affected sources is needed. The Region 2 list also identified 11

additional platers who were not found in our current permit system. However, 8 of these 11 were

listed on the ABD.

The ABD did not prove to be totally inclusive, but it contained more sources than the

DOL listing. Attachment F is a list generated using the ABD as well as a printout of a detailed

look at a specific business.

4.1.3 Wood Furniture Manufacturers

A useful resource to identify SIC codes to use for searches is contained in EPA's Sector

Notebook on the Wood Furniture Industry. Page 5 contains a listing of the codes to use for the

wood furniture manufacturing industry. The codes identified are 2511, 2512, 2517, 2521, 2531,

and 2541 are as follows:

SIC CODE Number of Sources Identified

DOL ABD

2511 178 69

2512 43 30

2517 5 6

2521 43 28

2531 11 32
SIC CODE Number of Sources Identified

DOL ABD

 4-4

2541 102 66

TOTAL 382 231

This comparison is not very impressive for the ABD list. However, SIC codes are

frequently listed incorrectly on the DOL listings and since this particular industry has a large

number of similar SIC codes, the number of businesses could be due to inaccuracies in the

assignment of SIC codes.

We identified 21 sources on our DEC list of permitted facilities who were most likely to

be subject to the wood furniture NESHAP. We found 13 of the sources on the ABD.

One problem with searching by company name is that if you have any misspellings or

incorrect names you cannot find them on the ABD. Our permitted sources’ names are not always

100% accurate or the names may have been changed slightly. These possible discrepancies may

also explain the low number for this count.

4.1.4 Conclusion

As you can see from these two very different analyses, the ABD has proven useful but not

foolproof. A listing of permitted sources from your state agency is the best place to start to

locate specific industries. However, we know that these lists are not complete and it is useful to

have a resource to create listings based on SIC codes or Yellow Page keywords. This database is

very useful when you want to do a search of businesses based on the number of employees (e.g.,

to target small businesses who would be eligible for the Small Business Stationary Source

Technical and Environmental Compliance Assistance Programs that are located in each state, as

mandated by the Clean Air Act). Also, you can search by sales volume and determine the largest

businesses, which may produce high emissions. Accuracy of company names is a must when
 4-5

using this database. The biggest problem with the ABD is the ability to download only 50 sources

at a time.

4.1.5 Other CD-ROM Databases

Harris Publishing's New York Manufacturers Directory (1-800-888-5900). These

editions are available for other states. The information provided includes: company name,

address, phone and fax numbers, and SIC codes. It is available as a book or in DOS or Windows

versions on diskette or CD-ROM. The cost varies depending on the size of your state. 

Demonstration diskettes are available.

American Business Information's American Yellow Pages (1-800-555-5666). This

database is for the United States. It includes Yellow Page headings and company names. It is

available on CD-ROM and you can perform searches by company name and Yellow Page

headings. You can download to many label formats to create mailings.

DDA PhoneDisc Business 95. This product was found in the catalog "Windows

Warehouse." The information provided includes: company name, business type, address and

phone number. Searches can be done based on each of these items.

4.2 State Of Georgia Halogenated Solvent Cleaning Machine Pilot Study

4.2.1 Introduction

A pilot study was initiated for EPA Region 4 by the State of Georgia's Environmental

Protection Division to explore methods of locating MACT Standard or NESHAP affected

facilities. The particular MACT Standards chosen for the pilot test were 40 CFR Part 63,

Subpart T, Halogenated Solvent Cleaning Machines, commonly called the Degreaser Standard. 

Three approaches were explored:
 4-6

1. Locating sources using the SIC code list supplied with the MACT Standard and

the ProPhone phone directory.

2. Locating sources using the SIC code list supplied with the MACT Standard and

the Georgia Manufacturing Index.

3. Locating sources using ProPhone and the SIC codes from sources submitting

Initial Notifications for the MACT Standard.

4.2.2 Study and Results

Using ProPhone and the Georgia Manufacturers Index (GMI), we were able to identify

matches for two SIC codes (3442 and 3691) contained in the MACT Standard. ProPhone had 27

matches for SIC code 3442 and 124 matches for SIC code 3691. GMI had 64 matches for SIC

code 3442 and 12 matches for SIC code 3691. Of the identified sources from GMI and

ProPhone, none were on our Initial Notification list. When the listings were reviewed by

inspectors, they indicated that none of the listed sources had degreasers. When compared to our

State listing, we found one additional source which had failed to report their existence due to an

oversight. When attempting to locate degreasers based on the list of SIC codes of reported

degreasers, the list from ProPhone and GMI expanded to more than 3,000 facilities which is the

opposite trend we anticipated. Thus, we concluded that the procedure we initially used, which

was to send every source in the GMI a degreaser informational packet, was the most effective

method to insure proper notification of every source in Georgia.

4.2.3 Conclusions

In conclusion, we found the SIC code list from the MACT Standard, the GMI, and

ProPhone directories did not adequately locate degreasers or halogenated solvent cleaning

machines in Georgia. In addition, we were only able to locate one additional source by actual

inspection of the facilities and that source failed to notify us by oversight. Thus, we conclude that

the initial approach we used, mass mailing, was the most effective in publicizing the MACT
 4-7

Standard and getting sources to report the existence of halogenated solvent cleaning machines. 

The additional paragraph on collocated sources is included for additional insight.

4.2.4 Collocated Sources

One problem facing state regulators is the identification of collocated sources. To give

insight into this problem, we chose two related MACT Standards and made a list of sources

reporting both affected processes. The MACT Standards we chose were halogenated solvent

cleaning machines (40 CFR Part 63 Subpart T) and chromium electroplaters (40 CFR Part 63

Subpart N).

Source Location SIC Code

Delta Airlines Technical Operations Center Atlanta, GA 4512

Hercules Automotive Products, Inc. Pelham, GA Unknown

Lockheed Systems Company Marietta, GA 3721

Northwest Airlines Technical Operations Atlanta, GA 4512

Robins Air Force Base Robins AFB, GA 9711

Roper Pump Company Commerce, GA Unknown

As indicated in the sample above, with the exception of the majority of sources seemingly

being related to the aerospace industry, there isn't any particular trend indicating the collocation of

these processes. Thus, one could conclude that the locating process for these MACT Standards

would require individual searches for these processes. Lastly, the presence of one process at a

facility would not necessarily indicate both are present onsite.

4.2.5 Wood Furniture Cookbook

The same procedures were conducted on the Wood Furniture MACT. Using the GA

Manufacturers Index, there were 465 sources identified. The WinPhone'96 database contained

950 sources with 85 duplicates within database. When comparing the two databases, there were
 4-8

194 sources identified in Winphone that were also contained in the GMI database. However,

GMI had more complete data on sources. Sources potentially subject to the wood furniture

standard were listed in SIC codes: 2434, 2511, 2512, 2517, 2519, 2521, 2531, 2541, 2599, and

5712. SIC Code 5712 included manufacturers & retail stores. Code 5712B is manufacturers of

custom furniture. The other 5712's (A, C, etc) were retail stores, for which there were thousands

of listings. Those listed as only 5712 were included in our reporting, although, this approach may

have inadvertently included some retailers. The GMI database was seemingly was incomplete. 

USEPA's AIRS database had only 5-6 sources. A survey of major and synthetic minor sources

only identified a few facilities. All of which were contained on GMI and/or WinPhone.

4.3 Florida Source Identification Pilot Study

Over the last year, the Florida DEP and the Florida Air Toxics Work Group, composed of

district and county air program staff, have worked together to develop a mechanism for

identifying facilities potentially subject to upcoming MACT standards. This database, known as

TINS, or the Toxics Inventory System, is about to become fully functional and will play a role in

Florida's efforts to locate and outreach to facilities which may become subject to new federal air

rules.

The TINS database is a stand alone subpart of the Department's oracle Air Resources

Management System (ARMS) database and can be accessed through the same procedures. TINS

will contain information about facilities which may be subject to upcoming rules, and therefore the

files will remain separate from the ARMS system. However, when a qualified user provides the

TINS database with the information that signifies that a TINS facility is subject to a promulgated

rule, the TINS facility file will be transferred to ARMS and thereafter directly available through

the ARMS database.

The TINS database uses publicly and commercially available industry databases such as

the Directory of Florida Industries, the Toxics Release Inventory, and others to generate files of
 4-9

facilities that may be subject to an upcoming or recently promulgated rules. A form letter can be

automatically generated which identifies the MACT rule, its applicability, the initial notification

requirements and the address of the agency to receive the facility's notification form.

When a new or proposed MACT is issued, it is anticipated that the Department's Air

Toxics Section will develop the initial TINS facility identification files from an available industry

database and generate letters to the facilities informing them of the rule applicability and

notification requirements. Districts and local program staff may also review the TINS if, to their

knowledge, additional facilities exist that may be subject to the rule, enter the necessary facility

information and generate letters to those facilities.

After an affected facility sends an initial notification to the appropriate permitting agency,

the agency staff can enter a code in a TINS screen that indicates that the facility is subject to the

promulgated rule. When this occurs, the facility's file is transferred to the ARMS database and

the facility is subsequently tracked as a regulated facility. TINS can also generate reports, such as

identified facilities, returned notifications and MACT affected SIC codes.

The TINS database was developed primarily to help with identifying small area sources

such as vapor degreasers and chrome electroplaters that are subject to recently promulgated

MACT standards. We recognized that ARMS may not have records of these facilities, and they

may not be covered by the Toxics Release Inventory either. A versatile, yet simple computer

program was needed that could utilize various industry databases to identify these smaller

operations. 

As the list of candidate general permits continues to grow and the Department searches

for ways to make suitable facilities aware of this permitting mechanism, it may be feasible to use

the TINS database as a means for targeting appropriate facilities and for sending fact sheets to the

facility's address. The TINS database is navigated using the same commands as the ARMS

database and can be learned rather quickly.
 4-10

Appendix C contains replicas of the computer screens in TINS and the directions for its

intended users. A sample form letter that can be generated from TINS is also attached. For more

information about the design and use of the TINS database, please call John Glunn at

(904) 488-0114. To learn more about the functional properties of TINS or for programming

information, please call Alex Men at the same number.

4.4 Illinois Environmental Protection Agency (IEPA)

IPA has used a number of cookbook elements in determining the NESHAP effected

sources in Illinois; the top four sources are D&B, Department of Revenue for both the State and

Chicago, Department of Commerce, and Trade Associations;

These four resources supplemented our standard database (IEPA files, title V data, state

permitting data, AT telephone CD-ROM data) and resulted in significant increases in "hits" for

potential effected sources.

For the Dry Cleaning standard, the Allied Trade Associations resulted in an additional 260

Dry Cleaning sources for consideration; the Chicago Dept. of Revenue added an additional 10

chrome electroplaters; and the State DAR resulted in an additional 2400 solvent cleaning "hits."

IPA is reviewing the CD-ROM telephone directory the Cookbook highlighted and is

expected to establish Agency-wide access to the database.

One of the better sources has turned out to be the Allied Trades Associations. The

solvent cleaning suppliers have also been very cooperative in working with us and their customers

in learning about the standard and understanding the reporting and control requirements.
 

APPENDIX A
 

APPENDIX B
 B-1

FUEL COMBUSTION

Category Promulgation

Industrial Boilers 11/15/2000

Institutional/Commercial Boilers 11/15/2000

Process Heaters 11/15/2000

Stationary Internal Combustion Engines 11/15/2000

Stationary Turbines 11/15/2000

NON-FERROUS METALS PRODUCTION

Category Promulgation

Secondary Lead Smelting 11/15/94

Primary Aluminum Production 11/15/97

Primary Copper Smelting 11/15/97

Primary Lead Smelting 11/15/97

Secondary Aluminum Production 11/15/97

Primary Magnesium Refining 11/15/2000

FERROUS METALS PROCESSING

Category Promulgation

Coke Ovens: Charging, Top Side and Door Leaks 11/15/92

Ferroalloys Production 11/15/97

Steel Pickling - HCl Process 11/15/97

Coke By-Product Plants 11/15/2000

Coke Ovens: Pushing, Quenching, and Battery Stacks 11/15/2000

Integrated Iron & Steel Manufacturing 11/15/2000

Iron Foundries 11/15/2000

Steel Foundries 11/15/2000

MINERAL PRODUCTS PROCESSING 

Category Promulgation

Mineral Wool Production 11/15/97

Portland Cement Manufacturing 11/15/97

Wool Fiberglass Manufacturing 11/15/97

Alumina Processing 11/15/2000

Asphalt Concrete Manufacturing 11/15/2000

Asphalt Processing 11/15/2000

Asphalt Roofing Manufacturing 11/15/2000

Asphalt/Coal Tar Application - Metal Pipes 11/15/2000

Chromium Refractories Production 11/15/2000

Clay Products Manufacturing 11/15/2000

Lime Manufacturing 11/15/2000

Taconite Iron Ore Processing 11/15/2000

PETROLEUM AND NATURAL GAS PRODUCTION
 B-2

Category Promulgation

Petroleum Refineries - Other Sources Not Distinctly Listed 11/15/94

Oil and Natural Gas Production 11/15/97

Petroleum Refineries - Catalytic Cracking (Fluid and Other) Units and Sulfur 11/15/97

LIQUIDS DISTRIBUTION

Category Promulgation

Gasoline Distribution (Stage 1) 11/15/94

Organic Liquids Distribution (Non-Gasoline) 11/15/2000

SURFACE COATINGS PROCESSES

Category Promulgation

Aerospace Industries 11/15/94

Magnetic Tapes (Surface Coating) 11/15/94

Printing/Publishing (Surface Coating) 11/15/94

Shipbuilding and Ship Repair (Surface Coating) 11/15/94

Wood Furniture (Surface Coating) 11/15/94

Auto and Light Duty Truck (Surface Coating) 11/15/2000

Flat Wood Paneling (Surface Coating) 11/15/2000

Large Appliance (Surface Coating) 11/15/2000

Manufacture of Paints, Coatings and Adhesives 11/15/2000

Metal Can (Surface Coating) 11/15/2000

Metal Coil (Surface Coating) 11/15/2000

Metal Furniture (Surface Coating) 11/15/2000

Miscellaneous Metal Parts and Products (Surface Coating) 11/15/2000

Paper and Other Webs (Surface Coating) 11/15/2000

Plastic Parts and Products (Surface Coating) 11/15/2000

Printing, Coating, and Dyeing of Fabrics 11/15/2000

WASTE TREATMENT AND DISPOSAL

Category Promulgation

Solid Waste, Treatment, Storage and Disposal Facilities (TSDF) 11/15/94

Publicly Owned Treatment Works (POTW) Emissions 11/15/97

Hazardous Waste Incineration 11/15/2000

Municipal Landfills 11/15/2000

Sewage Sludge Incineration 11/15/2000

Site Remediation 11/15/2000
 B-3

AGRICULTURAL CHEMICALS PRODUCTION

Category Promulgation

2,4-D Salts and Esters Production 11/15/97

4,6-Dinitro-O-Cresol Production 11/15/97

4-Chloro-2-Methylphenoxyacetic Acid Production 11/15/97

Captafol Production 11/15/97

Captan Production 11/15/97

Chloroneb Production 11/15/97

Chlorothalonil Production 11/15/97

Dacthal (tm) Production 11/15/97

Sodium Pentachlorophenate Production 11/15/97

Tordon (tm) Acid Production

11/15/97

FIBERS PRODUCTION PROCESSES

Category Promulgation

Acrylic Fibers/Modacrylic Fibers Production 11/15/97

Rayon Production 11/15/2000

Spandex Production 11/15/2000

FOOD AND AGRICULTURAL PROCESSES

Category Promulgation

Baker's Yeast Manufacturing 11/15/00

Cellulose Food Casing Manufacturing 11/15/00

Vegetable Oil Production 11/15/00

This comparison is not very impressive for the ABD list. However, SIC codes are

frequently listed incorrectly on the DOL listings and since this particular industry has a large

number of similar SIC codes, the number of businesses could be due to inaccuracies in the

assignment of SIC codes.

Acrylonitrile-Butadiene-Styrene Production 11/15/94

Butyl Rubber Production 11/15/94

Epichlorohydrin Elastomers Production 11/15/94

Epoxy Resins Production 11/15/94

Ethylene-Propylene Elastomers Production 11/15/94

Hypalon (tm) Production 11/15/94

Methyl Methacrylate-Acrylonitrile-Butadiene-Styrene Production 11/15/94

Methyl Methacrylate-Butadiene-Styrene Terpolymers Production 11/15/94

Neoprene Production 11/15/94

Nitrile Butadiene Rubber Production 11/15/94

Nitrile Resins Production 11/15/94

Non-Nylon Polyamides Production 11/15/94

Polybutadiene Rubber Production 11/15/94
 B-4

Polyethylene Terephthalate Production 11/15/94

Polystyrene Production 11/15/94

Polysulfide Rubber Production 11/15/94

Styrene-Acrylonitrile Production 11/15/94

Styrene-Butadiene Rubber and Latex Production 11/15/94

POLYMERS AND RESINS PRODUCTION

Category Promulgation

Acetal Resins Production 11/15/97

Amino Resins Production 11/15/97

Flexible Polyurethane Foam Production 11/15/97

Nylon 6 Production 11/15/97

Phenolic Resins Production 11/15/97

Polycarbonates Production 11/15/97

Reinforced Plastic Composites Production 11/15/97

Alkyd Resins Production 11/15/2000

Boat Manufacturing 11/15/2000

Butadiene-Furfural Cotrimer (R-11) Production 11/15/2000

Carboxymethylcellulose Production 11/15/2000

Cellophane Production 11/15/2000

Cellulose Ethers Production 11/15/2000

Flexible Polyurethane Foam Fabrication Operations 11/15/2000

Maleic Anhydride Copolymers Production 11/15/2000

Methylcellulose Production 11/15/2000

Polyester Resins Production 11/15/2000

Polymerized Vinylidene Chloride Production 11/15/2000

Polymethyl Methacrylate Resins Production 11/15/2000

Polyvinyl Acetate Emulsions Production 11/15/2000

Polyvinyl Alcohol Production 11/15/2000

Polyvinyl Butyral Production 11/15/2000

Polyvinyl Chloride and Copolymers Production 11/15/2000

PRODUCTION OF INORGANIC CHEMICALS

Category Promulgation

Chlorine Production 11/15/97

Cyanuric Chloride Production 11/15/97

Hydrogen Cyanide Production 11/15/97

Sodium Cyanide Production 11/15/97

Ammonium Sulfate Production - Caprolactam By-Product Plants 11/15/2000

Antimony Oxides Manufacturing 11/15/2000

Fume Silica Production 11/15/2000

Hydrochloric Acid Production 11/15/2000

Hydrogen Fluoride Production 11/15/2000

Phosphate Fertilizers Production 11/15/2000
 B-5

Phosphoric Acid Manufacturing 11/15/2000

Quaternary Ammonium Compounds Production 11/15/2000

Uranium Hexafluoride Production 11/15/2000

RODUCTION OF ORGANIC CHEMICALS

Category Promulgation

Synthetic Organic Chemical Manufacturing 11/15/92

MISCELLANEOUS PROCESSES

Category Promulgation

Commercial Dry Cleaning (Perchloroethylene) - Transfer Machines 11/15/92

Industrial Dry Cleaning (Perchloroethylene) - Dry-To-Dry Machines 11/15/92

Industrial Dry Cleaning (Perchloroethylene) - Transfer Machines 11/15/92

Chromic Acid Anodizing 11/15/94

Commercial Sterilization Facilities 11/15/94

Decorative Chromium Electroplating 11/15/94

Halogenated Solvent Cleaners 11/15/94

Hard Chromium Electroplating 11/15/94

Industrial Process Cooling Towers 11/15/94

Butadiene Dimers Production 11/15/97

Polyether Polyols Production 11/15/97

Pulp & Paper Production 11/15/97

Wood Treatment 11/15/97

Aerosol Can-Filling Facilities 11/15/2000

Benzyltrimethylammonium Chloride Production 11/15/2000

Carbon Black Production 11/15/2000

Carbonyl Sulfide Production 11/15/2000

Chelating Agents Production 11/15/2000

Chlorinated Paraffins Production 11/15/2000

Dry Cleaning (Petroleum Solvent) 11/15/2000

Ethylene Processes 11/15/2000

Ethylidene Norbornene Production 11/15/2000

Explosives Production 11/15/2000

Friction Products Manufacturing 11/15/2000

Hydrazine Production 11/15/2000

Leather Tanning adn Finishing Operations 11/15/2000

Marine Vessel Loading Operations 11/15/2000

Oxybisphenoxarsine/1,3-Diisocyanate Production 11/15/2000

Paint Stripper Users 11/15/2000

Photographic Chemicals Production 11/15/2000

Phthalate Plasticizers Production 11/15/2000

Plywood/Particle Board Manufacturing 11/15/2000

Rocket Engine Test Firing 11/15/2000

Rubber Chemicals Manufacturing 11/15/2000
 B-6

Semiconductor Manufacturing 11/15/2000

Symmetrical Tetrachloropyridine Production 11/15/2000

Tire Production 11/15/2000

AREA SOURCE CATEGORIES

Category Promulgation

Chromic Acid Anodizing (Area Sources) 11/15/94

Commercial Sterilization Facilities (Area Sources) 11/15/94

Decortive Chromium Electroplating (Area Sources) 11/15/94

Halogenated Solvent Cleaners (Area Sources) 11/15/94

Hard Chromium Electroplating (Area Sources) 11/15/94
 

APPENDIX C
 

APPENDIX D
 D-1

Table D-1.

Project Title Number Project Lead Phone Number

Project

Acrylic/Modacrylic Fibers Production 93/56 Anthony Wayne (919)541-5439

Aerospace Coating MACT Standard and CTG 91/67B Jim Szykman (919)541-4516

Antimony Oxides Production NESHAP 96/13 Conrad Chin (919)541-1512

Architectural and Industrial Maintenance 89/12 Ellen Ducey (919)541-5408

Coatings

Asbestos MACT/GACT Standard 80/41A Susan Zapata (919)541-5167

Asphalt Roofing and Processing NESHAP 95/04 Juan Santiago (919)541-1084

Baker's Yeast Manufacturing MACT 94/13 Anthony Wayne (919)541-5439

Boat Manufacturing Neshap 95/15 Madeleine Strum (919)541-2383

Case-by-Case MACT Database (Guidance 93/11 Susan Zapata (919)541-5167

Document)

Chlorine Manufacturing NESHAP 92/10 Iliam Rosario (919)541-5308

Chromium Chemicals Manufacturing 93/51 Iliam Rosario (919)541-5308

Chromium Elecroplating MACT Standard 85/02A Lalit Banker (919)541-5420

Chromium Refractories Manufacturing 95/07 Susan Zapata (919)541-5167

NESHAP

Coke By-Product Plants 95/28 Lula Melton (919)541-

Combustion (Gas) Turbines NESHAP & 95/10 Sims Roy (919)541-5263

NSPS

Consolidated Federal Air Rules 95/25 Richard Colyer (919)541-5265

Cyanide Chemical Manufacturing 93/57 Phil Mulrine (919)541-5289

Dry Cleaning MACT Standard 85/06B George Smith (919)541-1549

Electric Utility Air Toxics Study 91/41 William Maxwell (919)541-5430

Ferroalloy Industry MACT Standard 91/45 Conrad Chin (919)541-1512

Flexible Polyurethane Foam Fabrication Oper 96/10 David Svendsgaard (919)541-2380

MACT

Flexible Polyurethane Foam Production 93/49 David Svendsgaard (919)541-2380

Hazardous Organic NESHAP (litigation) 86/23 Janet Meyer (919)541-5254

Hazardous Waste TSDF - RCRA Air Rules 84/11A Michele Aston (919)541-2363

Phase II

Hydrogen Fluoride Production NESHAP 95/13 Richard Colyer (919)541-5265

Industrial and Commercial Waste Incinerators 95/01 George Smith (919)541-1549

Industrial Combustion Coordinated Rule 96/11 Fred Porter (919)541-5251

Making
Table D-1. (Continued)

Project Title Number Project Lead Phone Number

Project

 D-2

Industrial-Commercial-Institutional Boilers 96/04 James Eddinger (919)541-5426

MACT

Integrated Iron & Steel Manufacturing 93/55 Phil Mulrine (919)541-5289

Integ. Rule for Paper, Film, & Foil Coatings 96/02 Dan Brown (919)541-5305

Internal Combustion Engine NESHAP & 95/09 Amanda Jo Agnew (919)541-5268

NSPS

Iron and Steel Foundries MACT Standard 91/59 James Maysilles (919)541-3265

Landfills MACT 96/09 Martha Smith (919)541-2421

Lime Manufacturing NESHAP 95/06 Joseph Wood (919)541-5446

MACT Generic Rule 96/25 David W. (919)541-0837

Markwordt

MACT Partnerships Program Development 94/15 Fred Dimmick (919)541-5625

Manufacture of Tetrahydrobenzaldehyde 93/60 John Schaefer (919)541-0296

(THBA)

Medical Waste Incineration 90/17 Richard Copland (919)541-5265

Mineral Wool Production MACT Standard 92/14 Mary Johnson (919)541-5025

Miscellaneous Cellulose Categories MACT 96/08 Elaine Manning (919)541-5499

Miscellaneous Organic NESHAP (MON) 95/08 Randy McDonald (919)541-5402

Municipal Landfills NSPS and 111(d) 87/28 Martha Smith (919)541-2421

Municipal Waste Combustion Standard II & 91/05 Walter Stevenson (919)541-5264

III

NESHAP for Ethylene Processes 96/18 Warren Johnson (919)541-5124

NESHAP for the Rubber Tire Manufacturing 96/17 Anthony Wayne (919)541-5439

Industry

Nylon 6 Production 93/52 Mark Morris (919)541-5416

Off-Site Waste and Recovery Operations 91/31 Michele Aston (919)541-2363

MACT

Oil & Gas Production & Gas Transmission & 92/06 Martha Smith (919)541-2421

Storage

Organic Liquids (non-gasoline) Distribution 96/05 Michele Aston (919)541-2363

MACT

Other Solid Waste Incinerators 93/07 George Smith (919)541-1549

Petroleum Refinery MACT Standard 90/19 James Durham (919)541-5672
Table D-1. (Continued)

Project Title Number Project Lead Phone Number

Project

 D-3

Petro. Refineries NESHAP: FCC Units, 95/02 Bob Lucas (919)541-0884

Reformers...

Pharmaceuticals Production MACT 93/50 Randy McDonald (919)541-5402

Phosphoric Acid/Phosphate Fertilizers Manuf. 93/53 David Painter (919)541-5515

Plywood & Particle Board Manufacturing 95/11 Stephen Shedd (919)541-5397

Polycarbonates Production 93/63 Mark Morris (919)541-5416

Polyether Polyols Production 93/62 David Svendsgaard (919)541-2380

Polymers and Resins I MACT Standard 90/26 Robert Rosensteel (919)541-5608

Polymers and Resins II MACT Standard 84/01 Randy McDonald (919)541-5402

Polymers and Resins III MACT 91/54 John Schaefer (919)541-0296

Polymers and Resins IV MACT Standard 92/12 Robert Rosensteel (919)541-5608

Portland Cement MACT Standard 91/44 Joseph Wood (919)541-5446

Primary Aluminum MACT Standard 91/43 Steve Fruh (919)541-2837

Primary Copper Smelting MACT Standards 91/61 Eugene Crumpler (919)541-0881

Primary Lead Smelting 94/11 Kevin Cavender (919)541-2364

Primary Magnesium Refining NESHAP 96/12 Iliam Rosario (919)541-5308

Printing/Publishing Industry MACT Standard 91/42 Dave Salman (919)541-0859

Production of Agricultural Chemicals 93/59 Lalit Banker (919)541-5420

Publicly Owned Treatment Works (POTW) 91/30 Bob Lucas (919)541-0884

NESHAP

Pulp and Paper Combustion MACT (MICG) 91/38 Jeffrey Telander (919)541-5427

Pulp and Paper NESHAP CHEM. MILLS 86/15A Penny Lassiter (919)541-5396

NON-COMB (WCPG)

Pulp & Paper NESHAP Non-chem Mills 86/15B Elaine Manning (919)541-5499

(WCPG)

Reinforced Plastic Composites Production 93/58 Madeleine Strum (919)541-2383

Remediation Activities MACT 96/06 Bob Lucas (919)541-0884

Secondary Aluminum MACT Standard 91/46 Juan Santiago (919)541-1084

Semichemical Pulp and Paper 94/04 Jeffrey Telander (919)541-5427

Semiconductor Manufacturing MACT 95/03 David W. (919)541-0837

Markwordt

Sewage Sludge Incineration NESHAP 96/14 Eugene Crumpler (919)541-0881
Table D-1. (Continued)

Project Title Number Project Lead Phone Number

Project

 D-4

Ship Building NESHAP 91/53B Mohamed (919)541-2379

Serageldin

Spandex Manufacturing MACT 96/07 Mary Tom Kissell (919)541-4516

Stage I Gasoline Marketing MACT Standard 77/05A Stephen Shedd (919)541-5397

Steel Pickling - HCl Process MACT Standard 91/08B James Maysilles (919)541-3265

Vegetable Oil Production NESHAP 95/30 James Durham (919)541-5672

Wood Furniture MACT Standard 91/22 Paul Almodovar (919)541-0283

Wood Treatment MACT Standard 91/62 Eugene Crumpler (919)541-0881

Wool Fiberglass Manufacturing MACT 91/47 William Neuffer (919)541-5435
 

APPENDIX E
 E-1

NOTICE OF APPLICABILITY

Source NAME

Source Address

Dear ______:

This notice is provided to the ___________ (implementing Agency) in response to the publication

of the following (state/federal) standards:

40 CFR 40, Part ____ (60, 61, 63, etc.), Subpart ____ (A, NO, etc.)

or

_____ (State) Title/Code ______ (129, 2D.1101, etc.), Chapter ____

____ Please send me an initial notice of applicability form

____ I have reviewed the applicability of this standard and have determined that this facility is not

subject. This determination is based on 

______________________________________________________________________________

______________________________________________________________________________

______________________________________.

All calculations required by the standard are attached. If no calculations or documentation are

required, this data will be maintained and made available upon request by the ____________

(implementing agency). If additional information is needed, please contact me or

________________, of my staff, at (____) XXX-XXXX, ext. XXXX.

__________________________

Responsible Official Title

_________________________

Date 
E-2

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

DIVISION OF AIR POLLUTION CONTROL -- PERMIT SECTION

2200 CHURCHILL ROAD

P.O. BOX 19506

SPRINGFIELD, ILLINOIS 62794-9506

FOR AGENCY USE ONLY

NATIONAL EMISSION STANDARDS FOR

HAZARDOUS AIR POLLUTANTS: 

COMMERCIAL ETHYLENE OXIDE

STERILIZERS AND

FACILITY ID #:

FUMIGATION OPERATIONS

INITIAL NOTIFICATION REPORT

DATE:

FORM MUST BE SUBMITTED BY APRIL 5, 1995

1. Print or type the following for each ethylene oxide (EO) sterilizer or fumigation operation at your facility.

Name of Owner/Operator:

Mailing Address:

City: State: Zip Code:

Physical Location (If Different Than Mailing Address)

Street Address:

City: State: Zip Code:

Contact Person: Phone Number: ( ) 

2. Check the box below if your facility:

a. does not use an ethylene oxide sterilizer or fumigator.

b. is exempt per 40 CFR Part 63.360 (c) - (e):

• uses a beehive fumigator.

• is a research or laboratory facility.

• provides medical services to humans or animals (eg. hospitals, clinics, doctors 

office).

c. uses EO in sterilization or fumigation operations.

If you checked boxes a or b, complete the signiture section only (paragraph 7) and return the form to the

address given at the top of this page. If you checked box c, continue with paragraph 3.

3. Provide the following for the EO sterilizer or fumigation operation:

a. Method of operation (check all operations facility uses):

I) Sterilization Chamber Vent

ii) Aeration Room Vent

iii) Chamber Exhaust Vent

b. Intended control methods to achieve compliance (check all controls that apply):

I) acid-water scrubber
ETO-120694

E-3

ii) catalytic oxidizer

iii) thermal oxidizer

iv) other (describe):________________________

4. Provide the following dates for each EO sterilizer or fumigator (if applicable):

a. Date when construction or reconstruction commenced (mm/dd/yy):

b. Check the applicable date of initial startup (Note: the compliance date):

Compliance Date

Initial startup occurred on or before 12/8/97 12/8/97

Initial startup occurred after 12/8/97 Compliance date = initial startup date

5. This facility is a(n):

i) major source (Using one or more tons of EO)

ii) area source (not major)

6. EO usage over the preceding 12 months (Check one box)

I) source uses less than one ton/year2

ii) source uses one ton/year or more but less than ten tons/year

iii) source uses 10 tons/year or more

 Sterilization sources using less than 1 ton of ethylene oxide are not subject to the emission standards in 40 CFR Part 2

63.362, however, the recordkeeping requirements of 40 CFR Part 63.367(c) apply.

7. I CERTIFY THE INFORMATION CONTAINED IN THIS REPORT TO BE ACCURATE AND TRUE TO THE

BEST OF MY KNOWLEDGE.

Signature Date

Print or type the name and title of the Responsible Official for this facility:

Name Title

A Responsible Official can be:

• The president, vice president, secretary, or treasurer of a corporation that owns the facility,

 or a duly authorized representative that is responsible for the overall operation of the facility,

• An owner of the facility,

• A principal executive officer if the facility is owned by the Federal, State, City, or County government, 

ranking military officer if the facility is located at a military base, or

• A general partner of a partnership that owns the facility.
APPENDIX F
F-1

The American Business Disc. 1995 Edition (c)

This information may not be sold or otherwise provided to any party other than the Licensee. Data has been seeded to

detect unauthorized use.

Company Name: EMPIRE COATING INC Telephone: (716) 589-6842

Address: 215 WEST AVE

City: ALBION State: NY ZIP: 14411

Company Name: RAYCO OF SCHENETADY INC Telephone: (518) 843-8316

Address: 4 SAM STRATTON RD

City: AMSTERDAM State: NY ZIP: 12010

Company Name: O’DONNELL METAL MAINTENANCE Telephone: (518) 943-4878

Address: 249 TRAVIS DR.

City: ATHENS State: NY ZIP: 12015

Company Name: RECORDS RESERVE COPR Telephone: (716) 344-2600

Address: 56 HARVESTER AVE

City: BATAVIA State: NY ZIP: 14020

Company Name: US CHROME COPR OF NEW YORK Telephone: (716) 343-7077

Address: 31 SWAN STREET

City: BATAVIA State: NY ZIP: 14020

Company Name: A & M MFG CO Telephone: (56) 242-0918

Address: 275 FELDMEN CT

City: BAY SHORE State: NY ZIP: 11706

Company Name: TEK DEBURR INC Telephone: (516) 667-7007

Address: 26 CLEVELAND AVE

City: BAY SHORE State: NY ZIP: 11706

Company Name: INDUSTRIAL ELECTROPLATERS INC Telephone: (607) 723-7991

Address: 172 STATE ST

City: BINGHAMTON State: NY ZIP: 13901

Company Name: TRIPLE CITIES METAL FINISHING Telephone: (607) 722-3431

Address: 4 NOWLAN RD

City: BINGHAMTON State: NY ZIP: 13901

Company Name: WILSON ELECTROPLATERS Telephone: (607) 770-4500

Address: 6 EMMA ST

City: BINGHAMTON State: NY ZIP: 13905

Company Name: LIBERTY INDUSTRIAL FINISHING Telephone: (516) 273-4488

Address: 550 SUFFOLK AVE 

 City: BRENTWOOD State: NY ZIP: 11717

Company Name: ACE PLATING WORKS INC Telephone: (718) 665-6500

Address: 800 E 136TH ST

City: BRONX State: NY ZIP: 10454

ABI offers many other business information services, including mailing lists, directories, on-line access,and Info

access. For more information, refer to the “Other Srevices” menu or contact us at (402) 593-4523
The American Business Disc. 1995 Edition (c) (Continued)

F-2

This information may not be sold or otherwise provided to any party other than the Licensee. Data has been seeded

to detect unauthorized use.

Company Name: EMPIRE COATING INC Employees: 0010

Address: 215 WEST AVE Sales: $1 - $2.5 Million

City: ALBION Type of Location: Not available

State: NY Credit Rating: Good

ZIP: 14411

Telephone: (716) 589-6842

C Line of Business Ad Year 

71-02 METAL FINISHERS A 1989 
APPENDIX G
G-1

Alphabetized List of Industry and Business Trade Associations

(e.g., from Wisconsin)

AFSCME, AFL-CIO, Wisconsin Legislative Council

ASFSCME County and Municipal Employees

Administrators and Supervisors Council

Alliance for Animals

Allied Construction Employers Association

American Auto Association of Wisconsin

American Automobile Manufacturer Association

American Camping Association, Wisconsin Section

American Electroplaters & Surface Finishers

American Furniture Manufacturer Association (AFMA)

American Institute Real Estate Appraisal

American Institute of Architects (Wisconsin Society)

American Lung Association of Wisconsin

American Product and Inventory Control Society

American Trucking Association

Animal Protective League Inc.

Associated Builders & Contractors of Wisconsin

Associated General Contractors of Greater Milwaukee

Associated Milk Producers, Inc.

Associated Recyclers of Wisconsin

Association of Consulting Foresters

Auto Dealers Association of Metropolitan Milwaukee

Automotive Service Association of Wisconsin

Badger State Car Wash Association

Bay View Business Association

Bowling Proprietors Association of Wisconsin

Building Owners and Managers Association of Milwaukee

Business and Industry Improvement Council

Chemical Coaters Association

Chicago Lung Association

Citizen's Natural Res. Assn. of Wisconsin, Inc.

Citizen's Commission for Clean Air

Citizens for a Better Environment

Civil Air Patrol, Wisconsin Wing

Clean Water Action Council of Northeast Wisconsin

Coalition of Wisconsin Aging Groups

Combined Health Appeal of Wisconsin

Common Cause In Wisconsin
Alphabetized List of Industry and Business Trade Associations (Continued)

(e.g., from Wisconsin)

G-2

Concerned Auto Recylers of Wisconsin

Conference of Retail Associations

Construction Industry Manufacturers Association

Dairy Council of Wisconsin, Inc.

Environment Wisconsin Inc.

Farm Health & Safety Council of Wisconsin

Federal Reserve Bank of Chicago, Research Department

Forest History Association of Wisconsin

Forest Industry Safety and Training Alliance

Governor's Council On Tourism

Greater Milwaukee Florists Association

Greater Milwaukee Toxics Minimization Task Force

Hispanic Chamber of Commerce

Independent Community Bankers Association of Wisconsin

Independent Contract Lobbyists

Independent Insurance Agents of Wisconsin

Industrial Perforators Association

Industrial Recyclers of Wisconsin

Industry Relations Research Association

Institute Real Estate Management

International Dairy-Deli Bakery Association

Joint Organization for Better Sewer

Kitchen Cabinet Manufacturers Association

Lake Michigan Air Directors Consortium (LADCO)

Lake Michigan Federation

Lakes States Women In Timber

League of Wisconsin Municipalities

League of Women Voters Wisconsin Inc.

Lutherans for Life of Wisconsin Inc.

MRA - The Management Association

Madison Advertising Federation

Manufacturers of Emission Controls Association

Master Builders Association of Wisconsin

Mechanical Contractors Association of Wisconsin

Metro Milwaukee Association of Commerce

Midwest Equipment Dealers Association

Midwest Food Processors Association

Midwest Hardware Association
Alphabetized List of Industry and Business Trade Associations (Continued)

(e.g., from Wisconsin)

G-3

Milwaukee County Labor Council

Municipal Electric Utilities Wisconsin

Milwaukee Indian Health Board, Community Health Centers

Municipal Environmental Association of Wisconsin

NAACP

NAACP-Milwaukee Chapter

National Agri-Business Association

National Association of Social Workers

National Cheese Exchange, Inc.

National Electrical Contractors Wisconsin

National Federation of Independent Business

National Paint & Coating Association

National Telemedia Council

Petroleum Marketers Association of Wisconsin

Planning Council for Health and Human Services

National Association of Wisconsin Theatre Owners

Post-secondary Agriculture Students

Printing Industries of Wisconsin

Professional Fire Fighters of Wisconsin

Professional Insurance Agents of Wisconsin

Protect Animal Life Inc.

Public Enterprise Committee

Public Relation Society of America

Public Safety Communication Officers

Sheet Metal & Air Conditioning Contractor Association

Soap and Detergent Association

Society of Automotive Historians, Wisconsin Chapter

Society of Real Estate Appraisers

Soil Science of America

Soil and Water Conservation Society

Southeast Wisconsin Regional Planning Commission (SEWRPC)

State Bar of Wisconsin

State Engineering Association

State Medical Society of Wisconsin

Tavern League of Wisconsin

Timber Producers Assn. of Michigan & Wisconsin

Trees for Tomorrow, Inc.

United Professional Quality Health Care
Alphabetized List of Industry and Business Trade Associations (Continued)

(e.g., from Wisconsin)

G-4

United States Small Business Association

United Transportation Union-Wisconsin Legislative Board

Urban League

WATVA 

WI Assn. of Plumbing-Heating-Cooling Contractors, Inc.

WI State Employees Union, AFSCME Council 24, AFL-CIO

WISCO

Washington County Land Conservation Council

Wilderness Watch Inc.

Wisconsin AFL-CIO

Wisconsin AFL-CIO Womens Committee

Wisconsin Academy of Sciences, Arts & Letters

Wisconsin Accountants Association

Wisconsin Agri-Business Council, Inc.

Wisconsin Agri-Service Assn., Inc.

Wisconsin Agriculture Association

Wisconsin Air Forces Association

Wisconsin Ambulance Service Association

Wisconsin American Public Works Association

Wisconsin Amusement & Music Operators

Wisconsin Apple Growers Association

Wisconsin Appraisers Coalition

Wisconsin Arborist Association Inc.

Wisconsin Asphalt Pavement Association

Wisconsin Assoc. for Health, Phy. Ed., Recreation & Dance

Wisconsin Association Future Farmers America

Wisconsin Association Homes and Services for Aging

Wisconsin Association Life Underwriters

Wisconsin Association for Adult & Continuing Education

Wisconsin Association for Environmental Education

Wisconsin Association for Middle Level Education

Wisconsin Association for Supervision and Curriculum Dev.

Wisconsin Association of Campground Owners (WACO)

Wisconsin Association of Fairs

Wisconsin Association of Incinerator Operators

Wisconsin Association of Independent College & Universities

Wisconsin Association of Lakes Inc.

Wisconsin Association of Manufacturers Agents
Alphabetized List of Industry and Business Trade Associations (Continued)

(e.g., from Wisconsin)

G-5

Wisconsin Association of Milk & Food Sanitarians

Wisconsin Association of Taxicab Owners

Wisconsin Association of Textile Services

Wisconsin Association of Vocational Agricultural Instructors

Wisconsin Auto Collision Technical Association

Wisconsin Auto Merchandising Council

Wisconsin Automatic Merchandising Council

Wisconsin Automobile & Truck Dealers Association

Wisconsin Automobile Clubs in Association

Wisconsin Automotive Parts Association

Wisconsin Automotive Trades Association

Wisconsin Bakers Association

Wisconsin Bankers Association

Wisconsin Beef Council, Inc.

Wisconsin Berry Growers Association

Wisconsin Beverage Licensees Association

Wisconsin Biotechnology Association

Wisconsin Bowhunters Association Inc.

Wisconsin Broadcasters Association

Wisconsin Builders Association

Wisconsin Business Education Association

Wisconsin Business Womens Coalition

Wisconsin Cable Communications Association

Wisconsin Cast Metals Association

Wisconsin Cattlemens Association

Wisconsin Cattle women Association

Wisconsin Chapter American Fisheries Society

Wisconsin Chapter Association of General Contractors

Wisconsin Chapter Nature Conservancy

Wisconsin Chapter Tax Executives Institute

Wisconsin Chapter Wildlife Society

Wisconsin Cheese Makers Association

Wisconsin Chiropractic Association

Wisconsin Christmas Tree Producers Association

Wisconsin City Management Association

Wisconsin Coin Laundry Association

Wisconsin Communities & Economic Development

Wisconsin Community Education Association
Alphabetized List of Industry and Business Trade Associations (Continued)

(e.g., from Wisconsin)

G-6

Wisconsin Comptel

Wisconsin Concrete Masonry Association

Wisconsin Concrete and Pavement Association

Wisconsin Conference Journeymen Painters

Wisconsin Conference of Churches

Wisconsin Consumer Packaging Council

Wisconsin Contemporary Gift Association

Wisconsin Coop Tobacco Growers Association

Wisconsin Council for the Social Studies

Wisconsin Council of Safety

Wisconsin Counties Association

Wisconsin Counties Mineral Resources Association

Wisconsin Counties Utility Tax Association

Wisconsin County Agents Association

Wisconsin County Executives and Administrators

Wisconsin County Forests Association

Wisconsin County Planning Directors

Wisconsin County Solid Waste Managers Association

Wisconsin Credit Union League

Wisconsin Dairy Products Association Inc.

Wisconsin Dairy Technology Society

Wisconsin Dental Association, Inc.

Wisconsin Dental Laboratory Association

Wisconsin Dietetic Association

Wisconsin Eagle Forum

Wisconsin Economic Development Association

Wisconsin Economics Education Council

Wisconsin Electric Cooperative Association

Wisconsin Electronic Sales and Service Association

Wisconsin Environmental Health Association

Wisconsin Environmental Laboratory Association

Wisconsin Equipment Lessors Association

Wisconsin Fabricare Institute

Wisconsin Farm Bureau Federation Coop

Wisconsin Farm Bureau Service Cooperative

Wisconsin Farm Equipment Association

Wisconsin Federated Humane Societies

Wisconsin Federation of Cooperatives
Alphabetized List of Industry and Business Trade Associations (Continued)

(e.g., from Wisconsin)

G-7

Wisconsin Fertilizer & Chemical Association

Wisconsin Forest Fire Fighters Association

Wisconsin Forest Productivity Council

Wisconsin Foundation for Independent Colleges

Wisconsin Funeral Directors Association

Wisconsin Grain Dealers Association

Wisconsin Greyhound Owners Association

Wisconsin Grocers Association

Wisconsin Grounds Management Association

Wisconsin Groundwater Association

Wisconsin HMO Association

Wisconsin Hatcheries Association

Wisconsin Hazardous Material Responders

Wisconsin Health Care Association

Wisconsin Health Education Center

Wisconsin Health Information Management Association

Wisconsin Health Underwriters Association

Wisconsin Highway Users Conference

Wisconsin Hospital Association

Wisconsin Humane Society

Wisconsin Independent Businesses

Wisconsin Independent Merchants & Manufacturers Association

Wisconsin Independent Tire Dealers & Retread

Wisconsin Information and Referral Providers

Wisconsin Innkeepers Association

Wisconsin Installment Bankers

Wisconsin Institute of CPAs

Wisconsin Institute of Scrap Recycling Industries

Wisconsin Insulation Contractors Association

Wisconsin Insurance Alliance

Wisconsin Jewelers Association

Wisconsin Junior Limousine Association

Wisconsin Land Conservation Association

Wisconsin Land Title Association, Inc.

Wisconsin League of Financial Institutions, Ltd.

Wisconsin Leather Industries Association

Wisconsin Licensees Association

Wisconsin Limousine Association
Alphabetized List of Industry and Business Trade Associations (Continued)

(e.g., from Wisconsin)

G-8

Wisconsin Liquid Waste Carriers Association

Wisconsin Liquor Wholesalers lndependent

Wisconsin Locally Owned Telephone

Wisconsin Manufactured Housing Association

Wisconsin Marketing and Management Association

Wisconsin Master Builders Association

Wisconsin Meat Processors Association

Wisconsin Medical Group Management Association

Wisconsin Medical Record Association

Wisconsin Milk Haulers Association

Wisconsin Milk Marketing Board

Wisconsin Modular Housing Industry

Wisconsin Mortgage Bankers Association

Wisconsin Motorcycle Dealers Association

Wisconsin Movers Association Inc.

Wisconsin National Farmers Organization

Wisconsin Natural Food Associates, Inc.

Wisconsin Newspaper Association

Wisconsin Nurserymen's Association

Wisconsin Organic Growers Association

Wisconsin Paint & Coating Association

Wisconsin Painting & Decor Contractors

Wisconsin Paper Advertising Association

Wisconsin Paper Council

Wisconsin Park and Recreation Association

Wisconsin Petroleum Council

Wisconsin Pharmacists Association

Wisconsin Potato and Vegetable Growers Assc., Inc.

Wisconsin Precast Concrete Association

Wisconsin Primary Health Care Association

Wisconsin Professional Employee Council

Wisconsin Professional Florists Association

Wisconsin Psychiatric Association

Wisconsin Public Health Association Inc.

Wisconsin Public Health Association, Inc.

Wisconsin Pump & Well Suppliers

Wisconsin Railroad Committee

Wisconsin Ready Mixed Concrete Association
Alphabetized List of Industry and Business Trade Associations (Continued)

(e.g., from Wisconsin)

G-9

Wisconsin Real Property Listers Association

Wisconsin Realtors Association

Wisconsin Recreational Independent Inc.

Wisconsin Restaurant Association

Wisconsin Retail Bankers Association

Wisconsin Retail Hardware Association

Wisconsin Retail Lumbermen's Association, Inc

Wisconsin Road Builders Association

Wisconsin Road Builders Association

Wisconsin Rural Development Center

Wisconsin Social Service Association

Wisconsin Society for Clinical Social Work

Wisconsin Society for Ornithology Inc.

Wisconsin Society of Biological Science

Wisconsin Society of Land Surveyors

Wisconsin Society of Mechanical Engineers

Wisconsin Society of Orthodontists

Wisconsin Society of Professional Engineers

Wisconsin Society of Science Teachers

Wisconsin Soft Drink Association

Wisconsin Software Publishers Association

Wisconsin Sporting Goods Association

Wisconsin State Brewers Association

Wisconsin State Council of Carpenters

Wisconsin State Cranberry Growers

Wisconsin State Firefighters Association

Wisconsin State Grange

Wisconsin State Health Council

Wisconsin State Telephone Association

Wisconsin Tavern Hosts

Wisconsin Teachers Credit Union

Wisconsin Teamsters Joint Council #39

Wisconsin Technology Education Association

Wisconsin Tourism Federation

Wisconsin Towing Association

Wisconsin Town Mutual Insurance Co. Association

Wisconsin Town Mutual Insurance Company Assn.

Wisconsin Towns Association
Alphabetized List of Industry and Business Trade Associations (Continued)

(e.g., from Wisconsin)

G-10

Wisconsin Towns Association

Wisconsin Transportation Development Association 

Wisconsin Trappers Association Inc.

Wisconsin Tree Farm Committee

Wisconsin Truck Stop Operators Association 

Wisconsin Trustees Association

Wisconsin Underground Contractors Association

Wisconsin Urban Transit Association

Wisconsin Utilities Association

Wisconsin Veterinarian Medical Association

Wisconsin Warehousemans Association

Wisconsin Water Quality Association

Wisconsin Well Water Association

Wisconsin Wholesale Beer Dist Association, Inc.

Wisconsin Wildlife Federation Inc.

Wisconsin Wine and Spirit Institute

Wisconsin Wineries Association

Wisconsin Women for Agriculture

Wisconsin Woodland Owners Association Inc.

Wisconsin and Upper Michigan Florists Association

Wisconsin-Minnesota Canned Vegetable Council

Wisconsin Apartment Association

Women In Communications Inc.

Womens International Bowling Congress
APPENDIX H

Example Inspection Checklists
APPENDIX H1

Multimedia Inspection Checklist for Dry Cleaning Facilities
 

Multimedia Inspection Checklist For

Dry Cleaning Facilities

(Taken directly from “Multimedia Inspection Guidance

 for Dry Cleaning Facilities” OECA/EPA July 30, 1996.)
DRAFT

 

TABLE OF CONTENTS

I. GENERAL FACILITY AND MANAGEMENT INFORMATION ................. 1

A. General Facility Information .......................................... 1

B. Facility Management ................................................ 2

II. DRY CLEANING PROCESS AREA ........................................ 3

A. Dry Cleaning General Equipment Information ............................. 3

B. Refrigerated Condensers Performance Monitoring .......................... 4

C. Carbon Adsorber Performance Monitoring (complete if carbon adsorbers are

used) ............................................................ 4

D. Leak Detection .................................................... 5

E. Miscellaneous Operation and Maintenance ............................... 6

III. PERC AND PERC WASTE HANDLING AREAS ............................. 6

A. Perc Storage and Dispensing .......................................... 6

B. Satellite Waste Accumulation Area ..................................... 6

C. Hazardous Waste Storage Area ........................................ 7

D. Hazardous Wastes Shipping .......................................... 8

E. Wastewater Management ............................................ 8

IV. RECORDS AND FILES INSPECTION ...................................... 9

A. Reporting ........................................................ 9

B. Recordkeeping ................................................... 10

V. ADDITIONAL COMMENTS ............................................ 11
 1

DRAFT

MULTIMEDIA INSPECTION CHECKLIST FOR DRY CLEANING FACILITIES

I. GENERAL FACILITY AND MANAGEMENT INFORMATION

A. General Facility Information

1. Date of Inspection 

2. Facility Name: 

3. Facility Telephone Number:

4. Facility Address (physical location):

 

5. Mailing Address (if different): 

 

6. Facility Owner Contact Information 

(Name and phone):

 

7. Facility Operator/Manager (if different 

From owner (Name and phone):

8. Inspector(s):

 Name Title/Affiliation Phone Number

(1) 

(2) 

(3) 

 

9. Original establishment date of facility:
Multimedia Inspection Checklist DRAFT

 2

10. Establishment date of current ownership:

11. Establishment date at current location:

12. Is a new annual perc consumption level calculated on the first of each month reflecting usage for the past 12

months? Yes [ ] No [ ]

Record most current annual perc consumption:

Gallons: 

From (month, year) to (month, year)

Date calculated: 

13. Size categorization of facility under federal air emissions regulations (based on information in Question 12):

[ ] Small area source

[ ] Large area source

[ ] Major source

14. Size categorization of facility under federal hazardous waste regulations:

[ ] CESQG

[ ] SQG

[ ] LQG

15. Does the facility have an EPA ID # as a generator of hazardous wastes?

Yes [ ] No [ ]

EPA ID #:

16. Does the facility discharge wastewater into a municipal sewer?

Yes [ ] No [ ]

Name of POTW:

Permit # (if applicable):

If not, please explain.

B. Facility Management

17. Is the dry cleaner a member of a trade association? Yes [ ] No [ ]

If so, name of association: 

If not, ensure that the dry cleaner is aware of the role of trade organizations in providing compliance assistance.

Distribute national or local trade association literature as appropriate to serve as initial contact points.

18. What types of training activities are conducted at the facility (include safety, emergency procedures, and pollution

prevention programs)?
Multimedia Inspection Checklist DRAFT

 3

19. Has a pollution prevention or waste minimization plan been developed by the facility?

Yes [ ] No [ ]

If so, describe:

20. Has the facility evaluated which wastes are probable candidates for reductions through pollution prevention

activities? Yes [ ] No [ ]

If so, list the wastes and describe pollution prevention activities currently being undertaken.

21. Is the facility owner familiar with multiprocess wet cleaning? Yes [ ] No [ ]

Has the facility considered experimenting with multiprocess wet cleaning? Yes [ ] No [ ]

II. DRY CLEANING PROCESS AREA

A. Dry Cleaning General Equipment Information

22. Supply the following information about the dry cleaning machines in use at the facility:

# TypeiInstalled Existing number system(s) system recovery system

Date New or and model Perc filtration recovery perc vapor

Manufacturer Perc vapor Installation date of

ii iii

1

2

3

Dry-to-dry (D) or Transfer (T) i

List all types of filters used ii

Refrigerated condenser (RC) or carbon adsorber (CA) iii

23. New transfer machines are no longer allowed. Is the facility in compliance? Yes [ ] No [ ]

24. If existing transfer machines are used, has the facility performed a thorough cost analysis to determine what the

payback period would be on the purchase of a dry-to-dry machine? Yes [ ] No [ ]

25. Existing transfer machines in major sources must be surrounded in a room enclosure by September 23, 1996. Is

the facility in compliance? Yes [ ] No [ ]

26. Were any carbon adsorbers that are used as perc vapor recovery systems for drying process vapors installed before

September 22, 1993? Yes [ ] No [ ]

27. Does the facility use a carbon adsorber as a residual perc recovery system to vent aeration cycle vapors?

Yes [ ] No [ ]
Multimedia Inspection Checklist DRAFT

 4

B. Refrigerated Condensers Performance Monitoring

28. Are temperature sensors for refrigerated condensers installed for each machine in accordance with manufacturers'

specifications? Yes [ ] No [ ]

29. Are temperature sensors for all machines designed to measure temperatures from 32EF to 120EF to an accuracy

of ±2EF? Yes [ ] No [ ]

30. Record temperature sensor readings if available:

Temperature Sensor #1 #2 #3 compliance

Machine Machine Machine Criteria for

(a) Dryer airstream at condenser outlet (EF) Less than or equal to

45EF

(b) Washer airstream at condenser inlet (EF) none

(c) Washer airstream at condenser outlet (EF) none

(d) Washer airstream net temp. drop {(b) - (c)} (EF) At least 20EF

(e) In compliance? (Y/N)

C. Carbon Adsorber Performance Monitoring (complete if carbon adsorbers are used)

31. Are sampling ports for carbon adsorbers properly located in accordance with federal regulations (8 duct diameters

downstream and 2 duct diameters upstream of any flow disturbance)? Yes [ ] No [ ]

32. Are they kept closed when not in use? Yes [ ] No [ ]

33. Indicate the established period desorption schedule for each machine (as necessary, as indicated by tests, but at least

weekly). Note the date when each adsorber was last desorbed and measure the perc concentration in the exhaust

with a colorimetric detector while the drying cycle is on. (Note: It is important to note that the perc concentration

should usually be measured at the end of a use cycle, just prior to desorption. A measurement taken at any other

time only ensures that the adsorber is in compliance at that time, not necessarily for the duration of the use cycle.

However, given time and logistical limitations, inspections schedules generally cannot accommodate desorption

schedules for each machine.

Machine Indicate Periodic Date Last Measured Perc Use of Carbon Adsorber Perc Concentration

# Desorption Desorbed Concentration in Limit (as indicated by

Schedulei Exhaust Airstream

(A,B, or C as indicated by

table below)ii table below)ii

1

2

3

Indicate schedule specifics (day of week, etc.) i
Multimedia Inspection Checklist DRAFT

 5

Carbon adsorber is used: Indicate with Perc Limit (ppm)

As main perc vapor recovery system A 100

As residual vapor recovery system (tested during aeration while B 100

the door is open)

As residual vapor recovery system (tested during aeration while C 300

the door is closed)

D. Leak Detection

34. Is the odor of perc readily detectable anywhere in the facility? Yes [ ] No [ ]

If so, where?

35. Is the leak detection program conducted weekly or biweekly as required? Yes [ ] No [ ]

36. Allow owner or designated representative to guide you through the facility and demonstrate procedures for the

weekly/biweekly leak detection inspection for each machine. The inspection should include the items listed below.

Tabulate results and record any leaks detected.

Inspection done by:

[ ] Sight, smell, and feel

[ ] Monitoring instrument (Type: )

# #1 #2 #3 Explain all “Yes” answers:

Components: Machine Machine Machine

Signs of Leaking (Y, N, n/a)?

1 Hose & pipe connections,

fittings, couplings, valves

2 Door gaskets & seatings

3 Pumps

4 Solvent tank & containers

5 Water separators

6 Muck cookers

7 Stills

8 Exhaust dampers

9 Diverter valves

10 Filter gaskets and seatings

11 Cartridge filter housings
Multimedia Inspection Checklist DRAFT

 6

37. Are seals and gaskets periodically replaced before they become brittle? Yes [ ] No [ ]

38. What type of solvent leak detection systems are in use?

39. What other methods does the facility use to detect leaks? (e.g., drip pans, etc.)

40. In transfer machines, is the exhaust damper easily accessible? Yes [ ] No [ ]

If not, is there a suitable outlet downstream for testing the proper closure of the exhaust damper?

Yes [ ] No [ ]

E. Miscellaneous Operation and Maintenance

41. Are all machines operated as per manufacturer's specifications and recommendations?

Yes [ ] No [ ]

42. Are machine doors kept closed except when transferring clothes? Yes [ ] No [ ]

43. Are all spent cartridges drained at least 24 hours before disposal? Yes [ ] No [ ]

Alternatively, are they steam stripped before disposal? Yes [ ] No [ ]

III. PERC AND PERC WASTE HANDLING AREAS

A. Perc Storage and Dispensing

44. Is perc stored on-site? Yes [ ] No [ ]

If so, is all perc stored in tightly sealed containers and free from leakage? Yes [ ] No [ ]

45. How frequently is perc delivery available?

46. How is perc delivered to the dry cleaning machines?

B. Satellite Waste Accumulation Area

47. Do satellite waste accumulation areas contain less than 55 gallons of accumulating wastes?

Yes [ ] No [ ]

48. Are all full containers sealed and dated less than 3 days (72 hours) ago? Yes [ ] No [ ]

49. Are all containers tightly closed and free from leakage? Yes [ ] No [ ]

50. Are all containers clearly marked as hazardous waste? Yes [ ] No [ ]
Multimedia Inspection Checklist DRAFT

 7

C. Hazardous Waste Storage Area

51. Are all containers tightly closed and free from leakage or deterioration? Yes [ ] No [ ]

52. Are all containers clearly marked as hazardous waste? Yes [ ] No [ ]

53. Do all containers bear a date representing the day the container was filled and designated for disposal/treatment?

Yes [ ] No [ ]

54. Are all the dates on the containers in compliance with on-site waste storage time limits for generators of hazardous

wastes? (No limit for CESQGs, 180 days for SQGs, 270 days for SQGs that must transport their wastes 200

miles.) Yes [ ] No [ ]

Note the date of oldest container:

If the time limit is exceeded, does the facility have the required EPA permit for storage facilities?

Yes [ ] No [ ]

55. The facility must not be storing quantities of waste in excess of the quantity storage limits. Determine whether the

facility is in compliance as follows:

Determine the total weight of all perc wastes in the storage area. 

Each 15-gallon container can hold about 120 lbs (55 kg) of perc waste.

Each 55-gallon container can hold about 440 lbs (200 kg) of perc waste.

Maximum quantity limits are as follows: CESQG—2,200 lbs; SQG—13,200 lbs.

For 15-gallon containers:

 × 120 lbs/container = lbs in storage # of full containers:

For 55-gallon containers:

 × 440 lbs/container = lbs in storage # of full containers

On-site storage quantity limit (lbs): 

Is the facility in compliance? Yes [ ] No [ ] 

D. Hazardous Wastes Shipping

56. Does the facility ship hazardous wastes off-site? Yes [ ] No [ ]

57. Does the facility track the wastes with a manifest form? Yes [ ] No [ ]

58. Are all containers labeled with the 4-inch DOT POISON label? Yes [ ] No [ ]
Multimedia Inspection Checklist DRAFT

 8

59. Are all containers marked with the proper DOT shipping name and number? Yes [ ] No [ ]

E. Wastewater Management

60. Does the facility discharge industrial wastewater into the following?

Municipal sewer Yes [ ] No [ ]

On-site disposal system which meets the definition of injection well Yes [ ] No [ ]

Holding tank Yes [ ] No [ ]

For discharges to municipal sewers:

61. Does the facility have a current wastewater permit? Yes [ ] No [ ]

If not, has the facility applied for a new permit? Yes [ ] No [ ]

62. What parameters are limited and/or monitored in the facility's permit?

Parameter Limit Monitoring Frequency

(1) 

(2) 

(3) 

63. Is monitoring conducted as required by the permit (with respect to sampling location, frequency)?

Yes [ ] No [ ]

64. Does the facility have a sampling point available which is representative of its process wastewaters discharged to

the POTW? Yes [ ] No [ ]

65. Is the effluent currently in compliance with the limitations established in the Yes [ ] No [ ]

permits?

If not, describe all violations found, including parameter limit exceeded, date of violation, and any follow-up

samples or actions.
Multimedia Inspection Checklist DRAFT

 9

66. Has the discharge changed significantly since the permit was issued? Yes [ ] No [ ]

If so, was the permitting authority notified? Yes [ ] No [ ]

Describe the changes.

67. Describe any wastewater treatment employed at the facility.

68. If the facility discharges to a POTW, has it complied with the recordkeeping and reporting requirements contained

in 40 CFR 403.12(o)? Yes [ ] No [ ]

69. Has the facility ever discharged 15 kg of perc to the POTW within a calendar month?

Yes [ ] No [ ]

If so, were the proper authorities notified of the release? Yes [ ] No [ ]

For discharges to injection wells:

70. Does the facility have a Federal or State UIC permits? Yes [ ] No [ ]

71. Does the facility dispose of perc wastes and/or other hazardous chemicals in the injection well?

Yes [ ] No [ ]

For discharges to holding tanks:

72. Does the facility have the tank pumped out regularly by a licensed waste hauler for proper, legal disposal?

Yes [ ] No [ ]

IV. RECORDS AND FILES INSPECTION

A. Reporting

73. Did the facility file an initial report with EPA (by June 18, 1994, or upon startup for new facilities)?

Yes [ ] No [ ]

Date filed: 

74. Did the facility file a compliance report (within 30 days of startup or 30 days after NESHAP regulations take

effect)?

Yes [ ] No [ ]

Date filed: 

Note to inspector: Ask to see copies of the initial report and compliance report.

B. Recordkeeping
Multimedia Inspection Checklist DRAFT

 10

75. Are the results of temperature sensor monitoring for refrigerated condensers kept on record for the past 5 years of

operations? Yes [ ] No [ ]

Do the results show that all refrigerated condensers are in compliance with performance requirements?

Yes [ ] No [ ]

76. Are the results of colorimetric tube monitoring for carbon adsorbers kept on record for the past 5 years of

operations? Yes [ ] No [ ]

Has a periodic (at least weekly) desorption schedule been established and adhered to for each adsorber?

Yes [ ] No [ ]

Does monitoring of adsorbers take place during the last run prior to desorption? Yes [ ] No [ ]

Do the results show that all carbon adsorbers are in compliance with performance requirements?

Yes [ ] No [ ]

77. Are monthly totals of perc purchase records kept on-site for the past 5 years? Yes [ ] No [ ]

78. Are records of weekly/biweekly inspections for leaks available for each machine for the last 5 years (or since startup

of facility)? Yes [ ] No [ ]

79. Are any detected leaks repaired within 24 hours whenever possible? Yes [ ] No [ ]

80. Are all needed repair parts ordered within 2 working days? Yes [ ] No [ ]

81. Are needed repair parts installed within 5 days of receipt? Yes [ ] No [ ]

82. Note any recurring problems:

83. Are copies of manifest forms maintained on-site for 3 years? Yes [ ] No [ ]

84. Are any return copies of manifest forms (from the waste receiving facility) missing?

Yes [ ] No [ ]

85. If so, have exception reports been filed and copies maintained on-site? Yes [ ] No [ ]

What action has been taken to determine the status of the waste shipment or notify the proper authorities?

86. Are copies of the design specifications and operating manuals for each dry cleaning system and each emission

control device kept on-site at the facility? Yes [ ] No [ ]
Multimedia Inspection Checklist DRAFT

 11

87. Has the solvent mileage been calculated for each machine? Yes [ ] No [ ]

If so, record the results (gallons perc/1,000 lb clothes) 

If not, does the facility owner understand how to calculate solvent mileage and how to use it as a waste

minimization indicator? Yes [ ] No [ ]

V. ADDITIONAL COMMENTS
12

APPENDIX H2

Inspection Checklist for Chromium Electroplating and Anodizing
 1

DRAFT

Chromium Electroplating And Anodizing Inspection Checklist

Inspection Date ______________________

Facility Name ______________________

Facility Address ______________________

______________________

______________________

Attendees ______________________

______________________

______________________

______________________

______________________

______________________

I. EMISSION SOURCE TYPE* and CONTROL EQUIPMENT 

 __ small, existing hard ___ packed-bed scrubber (PBS) 

 __ other hard ___ composite mesh-pad (CMP)

 __ decorative ___ fume suppressant and/no 

wetting agent 

 __ anodizing ___ fume suppressant (FS)

* See details in Attachment 1 (Table 3-1 of the "Guidebook on How to Comply With the

Chromium Electroplating and Anodizing NESHAP).
 2

II. WORK PRACTICES

1. Operation and maintenance plan (O&M) 

Yes___ No___

2. Records of Quarterly inspections:

control devices ___

ductwork ___

monitoring equipment ___

3. Process operating time

4. For tanks using fume suppressant

a. Date and time of each addition of fume

suppressant___________________________

b. For trivalent decorative purchasing records of bath compounds: 

Yes___ No___ 

III. INITIAL PERFORMANCE TEST

Yes___ No___

exemptions:

• decorative or anodizing with wetting agent and surface tension to a max. 45 dynes/cm

• decorative that use a trivalent chromium bath

IV. ONGOING COMPLIANCE MONITORING (Table 5-3 of the Guide). 

For add-on pollution control specified in regulations (use monitoring parameters as per

initial performance test):

1. Composite mesh-pad scrubber

(check daily) pressure drop across the system

Initial test___ Actual___

2. Packed-bed scrubber
 3

(check daily) Pressure drop across system

Initial test___ Actual___

(daily) Velocity pressure at system inlet (i.e. velocity of the gas stream at the inlet of

the unit) 

Initial test___ Actual___

3. Packed-bed scrubber/composite mesh-pad system

(daily) Pressure drop across the mesh-pad system

Initial test___ Actual___

4. Fiber-bed mist eliminator 

(daily) Pressure drop across the mist eliminator

Initial test___ Actual___

(daily) Pressure drop across the control device located upstream of the fiber bed that

prevents plugging

Initial test___ Actual___

5. Wetting Agent or combination wetting agent/foam blanket fume suppressants 

(@4 or 8 hours. See Attachment II, Table 5-3). Surface tension

Initial test___ Actual___

6. Foam blanket-type fume suppressant

(every hour for every new tank solution. If no EE, @4 hours. See Attachment II,

Table 5-3) Foam blanket thickness

7. Fume suppressant/add-on control device

Combination of the above

For control system not specified in the regulations, EPA approved parameters:

V. RECORDKEEPING (except decorative with trivalent bath*)

1. Inspection records

2. Equipment maintenance records
 4

3. Records of the occurrence, duration and cause of excess emissions

4. Performance test results

5. Monitoring data

* for decorative electroplating with trivalent chromium bath submit initial notification and

an initial compliance status report 

VI. REPORTING (except for decorative with trivalent bath*)

1. Initial notification 

Yes____ No____

2. Performance test notification

Yes____ No____

3. Performance test data

__________________ 

4. EER's submission

Yes____ No____ 

* notification and initial compliance status report
 

APPENDIX I

Contacts
 

APPENDIX I1

Regional Air Toxics Coordinators
1 

REGIONAL AIR TOXICS CONTACTS

Janet Bowen Robert Todd

EPA Region I (CAP) EPA Region VI (6PD-R)

J.F.K. Federal Building 1445 Ross Avenue,Suite 700 

Boston, MA 02203-2211 Dallas, TX 75202-2733

PH: (617) 565-3595 PH: (214) 665-2156

Fax: (617) 565-4940 Fax: (214) 665-7263

Umesh Dholakia Richard Tripp

EPA Region II EPA Region VII

290 Broadway 726 Minnesota Avenue

New York, NY 10007-1866 Kansas City, KS 66101

PH: (212) 637 4023 PH: (913) 551-7566

Fax: (212) 637-3901 FAX: (913) 551-7065 

 

Mike Markowski Victoria Parker-Christensen

Alice Chow (enforcement) Ann-Marie Patrie (AP2-A)

EPA Region III (3AT23) Heather Rooney (8ENF-T) R VIII

841 Chestnut Building 999 18th Street, Suite 500

Philadelphia, PA 19107 Denver, CO 80202-2405

Mike (215) 566-2063 VPC: (303) 312-6441

Alice (215) 566-2144 Ann Marie: (303) 312-6524

FAX: (215) 566-2114 Heather: (303) 312-6971

 FAX: (303) 312-6064

Heather’s FAX: (303) 312-6409

Lee Page Mae Wang

EPA Region IV (AR-4) EPA Region IX (A-5-2)

100 Alabama Street, SW 75 Hawthorne Street

Atlanta, GA 30303-3104 San Francisco, CA 94105

PH: (404) 562-9131 PH: (415) 744-1200

FAX: (404) 562-9095 FAX: (415) 744-1076

Bruce Varner Chris Hall

EPA Region V (AE-17J) EPA Region X (OAQ-107)

77 W. Jackson Blvd. 1200 Sixth Avenue

Chicago, IL 60604 Seattle, WA 98101

PH: (312) 886-6793 PH: (206) 553-1949

FAX: (312) 353-8289 FAX: (206) 553-0404

Belinda Breidenbach Julie Andresen

Charlie Garlow, OECA EPA/OAQPS 

Belinda PH:(202) 564-7022 RTP, NC 27711

Charlie PH:(202) 564-1088 PH: (919) 541-5339 

Belinda’s FAX: (202) 564-0050 FAX: (919) 541-2664

Charlie’s FAX: (202) 564-0068
 

APPENDIX I2

OAQPS and OECA NSPS and NESHAP Contacts
 1

List of OAQPS and OECA NSPS and NESHAP Contacts 

(11/07/96)

Regulation - Part 60 OAQPS Contact Phone # OC Contact Phone #

NSPS Subpart A: Jim Szykman 919-541-2452 Sally Mitoff (202) 564-7012

General Provisions Belinda Breidenbach (202) 564-7022

NSPS Subpart D, Da, Rick Copland 919-541-5265 Chris Oh (202) 564-7004

Db, Dc: Boilers Jim Eddinger 919-541-5426

NSPS Subpart E: Fred Porter 919-541-5251 Joyce Chandler (202) 564-7073

Incinerators

NSPS Subpart Ea: Walt Stevenson 919-541-5264 Joyce Chandler (202) 564-7073

Municipal Waste

Combustors

NSPS Subpart F: Joe Wood 919-541-5446 Scott Throwe (202) 564-7013

Portland Cement

NSPS Subpart G: Nitric Bill Neuffer 919-541-5435 Jeff Kenknight (202) 564-7033

Acid Plants

NSPS Subpart H: 919-541- Dawn Banks-Waller (202) 564-7034

Sulfuric Acid Plants

NSPS Subpart I: Asphalt Mary Johnson 919-541-5025 Scott Throwe (202) 564-7013

Concrete Plants

NSPS Subpart J: Fred Porter 919-541-5251 Tom Ripp (202) 564-7003

Petroleum Refineries Gail Lacy 919-541-5261 Dan Chadwick (202) 564-7054

NSPS Subpart K, Ka, Randy McDonald 919-541-5402 Everett Bishop (202) 564-7032

Kb: Storage Tanks

NSPS Subpart L: Kevin Cavender 919-541-2364 Jane Engert (202) 564-5021

Secondary Lead

Smelters

NSPS Subpart M: Brass Eugene Crumpler 919-541-0881 Jane Engert (202) 564-5021

& Bronze

NSPS Subpart N, Na: Phil Mulrine 919-541-5289 Maria Malave (202) 564-7027

BOF
List of OAQPS and OECA NSPS And NESHAP Contacts (continued)

(11/07/96)

Regulation - Part 60 OAQPS Contact Phone # OC Contact Phone #

 2

NSPS Subpart O: Eugene Crumpler 919-541-0881 John Dombrowski (202)564-7036

Sewage Treatment

Plants

NSPS Subpart P: Eugene Crumpler 919-541-0881 Jane Engert (202) 564-5021

Primary Copper

Smelters

NSPS Subpart Q: Al Vervaert 919-541-5602 Jane Engert (202) 564-5021

Primary Zinc Smelters

NSPS Subpart R: Kevin Cavender 919-541-2364 Jane Engert (202) 564-5021

Primary Lead Smelters

NSPS Subpart S: Steve Fruh 919-541-2837 Jane Engert (202) 564-5021

Primary Aluminum

Reduction

NSPS Subpart T, U, V, David Painter 919-541-5515 Cletis Mixon (202) 564-4153

W, X: Phosphate Steve Howie (202) 564-4146

Fertilizer

NSPS Subpart Y: Coal Juan Santiago 919-541-1084 Chris Oh (202) 564-7004

Preparation

NSPS Subpart Z: Conrad Chin 919-541-1512 Jane Engert (202) 564-5021

Ferroalloy Production

NSPS Subpart AA: Steel Phil Mulrine 919-541-5289 Maria Malave (202) 564-7027

Plants, EAF

NSPS Subpart AAa: Phil Mulrine 919-541-5289 Maria Malave (202) 564-7027

Steel Plants, EAF &

AOD

NSPS Subpart BB: Kraft Jeff Telander 919-541-5427 Maria Eisemann (202) 564-7016

Pulp Mills 

NSPS Subpart CC: Al Vervaert 919-541-5602 Scott Throwe (202) 564-7013

Glass Manufacturing
List of OAQPS and OECA NSPS And NESHAP Contacts (continued)

(11/07/96)

Regulation - Part 60 OAQPS Contact Phone # OC Contact Phone #

 3

NSPS Subpart DD: Jim Berry 919-541-5605 Ken Harmon (202)564-7049

Grain Elevators

NSPS Subpart EE: Mohammed 919-541-2379 Scott Throwe (202) 564-7013

Surface Coating, metal Serageldin

furniture

NSPS Subpart GG: Sims Roy 919-541-5263 Chris Oh (202) 564-7004

Stationary Gas Turbines

NSPS Subpart HH: Joe Wood 919-541-5446 Scott Throwe (202) 564-7013

Lime Manufacturing

NSPS Subpart KK: Lead Kevin Cavender 919-541-2364 Jane Engert (202) 564-5021

Acid Batteries

NSPS Subpart LL: Bill Neuffer 919-541-5435 Keith Brown (202) 564-7124

Metallic Mineral

Processing

NSPS Subpart MM: Dave Salman 919-541-0859 Suzanne Childress (202) 564-7018

Surface Coating, Auto 

NSPS Subpart NN: David Painter 919-541-5515 Cletis Mixon (202) 564-4153

Phosphate Rock Steve Howie (202) 564-4146

NSPS Subpart PP: David Painter 919-541-5515 Scott Throwe (202) 564-7013

Ammonium Sulfate

Manufacturing

NSPS Subpart QQ: Dave Salman 919-541-0859 Ginger Gotliffe (202) 564-7072

Graphic Arts, Rotograve

Printing 

NSPS Subpart RR: Dan Brown 919-541-5305 Seth Heminway (202) 564-7017

Pressure Sensitive Tape

& Label Coating

NSPS Subpart SS: Mohammed 919-541-2379 Scott Throwe (202) 564-7013

Surface Coating, Large Serageldin

Appliances
List of OAQPS and OECA NSPS And NESHAP Contacts (continued)

(11/07/96)

Regulation - Part 60 OAQPS Contact Phone # OC Contact Phone #

 4

NSPS Subpart TT: Gail Lacy 919-541-5261 Scott Throwe (202) 564-7013

Surface Coating, Metal

Coil 

NSPS Subpart UU: Juan Santiago 919-541-1084 Andrew Cherry (202) 564-5011

Asphalt Roofing

NSPS Subpart VV: Rick Colyer 919-541-5262 Jeff Kenknight (202) 564-7033

VOC leaks, SOCMI 

NSPS Subpart WW: Gail Lacy 919-541-5261 Scott Throwe (202) 564-7013

Surface Coating,

Beverage Cans

NSPS Subpart XX: Bulk Steve Shedd 919-541-5397 Julie Tankersley (202) 564-7002

Gasoline Terminals Peter Bahor (202) 564-7029

NSPS Subpart AAA: Jeff Telander 919-541-5427 Robert Marshall (202) 564-7021

Woodstoves

NSPS Subpart BBB: Tony Wayne 919-541-5439 Maria Malave (202) 564-7027

Rubber Tire

Manufacture

NSPS Subpart DDD: Bob Rosensteel 919-541-5608 Sally Sasnett (202) 564-7074

Polymer Manufacture 

NSPS Subpart FFF: Dan Brown 919-541-5305 Ginger Gotliffe (202) 564-7072

Flexible Vinyl and

Urethane

NSPS Subpart GGG: David Markwordt 919-541-0837 Tom Ripp (202) 564-7003

Equipment Leaks,

Petroleum Refineries

NSPS Subpart HHH: Susan Wyatt 919-541-5674 Belinda Breidenbach (202) 564-7022

Synthetic Fiber

NSPS Subpart III: Bob Rosensteel 919-541-5608 Jeff Kenknight (202) 564-7033

SOCMI, Air Oxidation
List of OAQPS and OECA NSPS And NESHAP Contacts (continued)

(11/07/96)

Regulation - Part 60 OAQPS Contact Phone # OC Contact Phone #

 5

NSPS Subpart JJJ: Dry Steve Shedd 919-541-5397 Joyce Chandler (202) 564-7073

Cleaning

NSPS Subpart KKK: David Markwordt 919-541-0837 Dan Chadwick (202) 564-7054

Equipment Leaks,

Onshore Natural Gas

NSPS Subpart LLL: David Markwordt 919-541-0837 Dan Chadwick (202) 564-7054

Onshore Natural Gas

NSPS Subpart NNN: Warren Johnson 919-541-5124 Jeff Kenknight (202) 564-7033

SOCMI Distillation

Operations

NSPS Subpart OOO: Bill Neuffer 919-541-5435 Keith Brown (202) 564-7124

Non metallic Mineral

Processing

NSPS Subpart PPP: Bill Neuffer 919-541-5435 Scott Throwe (202) 564-7013

Wool Fiberglass

Insulation

NSPS Subpart QQQ: Randy McDonald 919-541-5402 Tom Ripp (202) 564-7003

VOC from Petroleum Elaine Manning 919-541-5499 Dan Chadwick (202) 564-7054

Wastewater

NSPS Subpart RRR: Bob Rosensteel 919-541-5608 Jeff Kenknight (202) 564-7033

SOCMI Reactor

Processes

NSPS Subpart SSS: Gail Lacy 919-541-5261 Steve Hoover (202) 564-7007

Surface Coating,

Magnetic Tape

NSPS Subpart TTT: Ellen Ducey 919-541-5408 Maria Malave (202) 564-7027

Surface Coating, Plastic

Parts for Business

Machines

NSPS Subpart UUU: Bill Neuffer 919-541-5435 Keith Brown (202) 564-7124

Calciners and Dryers
List of OAQPS and OECA NSPS And NESHAP Contacts (continued)

(11/07/96)

Regulation - Part 60 OAQPS Contact Phone # OC Contact Phone #

 6

NSPS Subpart VVV: Dan Brown 919-541-5305 Maria Malave (202) 564-7027

Polymeric Coating of

Supporting Substrates
List of OAQPS and OECA NSPS And NESHAP Contacts

(11/07/96)

 7

Regulation - Part 61 OAQPS Contact Phone # OC Contact Phone #

NESHAP Subpart A: Jim Szykman 919-541-2452 Belinda Breidenbach (202) 564-7022

General Provisions

NESHAP Subpart B: ORIA (Office of 202-233-9370 Dan Chadwick (202) 564-7054

Radon from Radiation & Indoor

underground Uranium Air)

Mines

NESHAP Subpart C: Al Vervaert 919-541-5602 Jane Engert (202) 564-5021

Berylium

NESHAP Subpart D: Al Vervaert 919-541-5602 Virginia Lathrop (202) 564-7057

Beryllium Rocket Motor

Firing

NESHAP Subpart E: Eugene Crumpler/ 919-541-0881/ Jane Engert (202) 564-5021

Mercury Illiam Rosario 919-541-5308

NESHAP Subpart F: Bob Rosensteel 919-541-5608 Jeff Kenknight (202) 564-7033

Vinyl Chloride

NESHAP Subpart H: ORP 202-233-9370 Joanne Callahan (202) 564-5009

Radionuclides from Virginia Lathrop (202) 564-7057

DOE

NESHAP Subpart I: ORP 202-233-9370 Joanne Callahan (202) 564-5009

Radionuclide Emissions Virginia Lathrop (202) 564-7057

NESHAP Subpart J: Jan Meyer 919-541-5254 Rafael Sanchez (202) 564-7028

Benzene Leaks

NESHAP Subpart K: ORP 202-233-9370 Joanne Callahan (202) 564-5009

Radionuclide from Virginia Lathrop (202) 564-7057

Elemental Phosphorous

NESHAP Subpart L: Lula Melton 919-541-2910 Maria Malave (202) 564-7027

Coke

NESHAP Subpart M: S. Fairchild-Zapata 919-541-5167 Tom Ripp (202) 564-7003

Asbestos
List of OAQPS and OECA NSPS And NESHAP Contacts (continued)

(11/07/96)

Regulation - Part 61 OAQPS Contact Phone # OC Contact Phone #

 8

NESHAP Subpart N: Al Vervaert 919-541-5602 Scott Throwe (202) 564-7013

Inorganic Arsenic From

Glass Manufacture

NESHAP Subpart O: Eugene Crumpler 919-541-0881 Jane Engert (202) 564-5021

Arsenic from Primary

Copper Smelters

NESHAP Subpart P: Al Vervaert 919-541-5602 Jane Engert (202) 564-5021

Arsenic 

NESHAP Subpart R: ORP 202-233-9370 Joanne Callahan (202) 564-5009

Radon from Virginia Lathrop (202) 564-7057

Phosphogypsum Stacks

NESHAP Subpart T: ORP 202-233-9370 Joanne Callahan (202) 564-5009

Radon from disposal of Virginia Lathrop (202) 564-7057

Uranium Mine Tailings

NESHAP Subpart V: Jan Meyer 919-541-5254 Rafael Sanchez (202) 564-7028

Equipment Leaks,

NESHAP Subpart W: ORP 202-233-9370 Joanne Callahan (202) 564-5009

Radon from Operating Virginia Lathrop (202) 564-7057

Mill Tailings

NESHAP Subpart Y: Randy McDonald 919-541-5402 Rafael Sanchez (202) 564-7028

Benzene Storage Vessels

NESHAP Subpart BB: David Markwordt 919-541-0837 Rafael Sanchez (202) 564-7028

Benzene from Transfer

Operations 

NESHAP Subpart FF: Bob Lucas 919-541-0884 Rafael Sanchez (202) 564-7028

Benzene Waste

Operations
List of OAQPS and OECA NSPS And NESHAP Contacts (continued)

(11/07/96)

 9

Regulation - Part 63 OAQPS Contact Phone # OC Contact Phone #

NESHAP Subpart A: Jim Szykman 919-541-2452 Belinda Breidenbach (202) 564-7022

General Provisions

NESHAP Subpart F-H, Jan Meyer 919-541-5254 Jeff Kenknight (202) 564-7033

The HON

NESHAP Subpart L: Amanda Agnew 919-541-5268 Maria Malave (202) 564-7027

Coke Oven Batteries

NESHAP Subpart M: George Smith 919-541-1549 Joyce Chandler (202) 564-7073

Perc Dry Cleaners

NESHAP Subpart N: Lalit Banker / Phil 919-541-5420/ Scott Throwe (202) 564-7013

Chromium Mulrine 919-541-5289

Electroplating

NESHAP Subpart O: David Markwordt 919-541-0837 Karin Leff (202) 564-7068

Ethyline Oxide

Sterilizers

NESHAP Subpart Q: Phil Mulrine 919-541-5289 Mimi Guernica (202) 564-2415

Industrial Process

Cooling Towers

NESHAP Subpart R: Steve Shedd 919-541-5397 Julie Tankersley (202) 564-7002

Gasoline Distribution

NESHAP Subpart Paul Almodovar 919-541-0283 Tracy Back (202) 564-7076

T:Halogenated Solvent

Cleaning

NESHAP Subpart U: Randy McDonald 919-541-5402 Sally Sasnett (202) 564-7074

Polymers & Resins

Group I

NESHAP Subpart W: Randy McDonald 919-541-5402 Sally Sasnett (202) 564-7074

Epoxy Resins & Nonnylon Polymides

NESHAP Subpart X: Kevin Cavender 919-541-2364 Jane Engert (202) 564-5021

Secondary Lead

Smelters
Regulation - Part 63 OAQPS Contact Phone # OC Contact Phone #

 10

NESHAP Subpart Y: David Markwordt 919-541-0837 Virginia Lathrop (202) 564-7057

Marine Vessel Loading

NESHAP Subpart CC: Jim Durham 919-541-5672 Tom Ripp (202) 564-7003

Petroleum Refineries

NESHAP Subpart DD: Michele Aston 919-541-2363 Ann Stephanos (202) 564-7043

Off-Site Waste &

Recovery Operations

NESHAP Subpart EE: Gail Lacy 919-541-5261 Seth Heminway (202) 564-7017

Magnetic Tape

Manufacture

NESHAP Subpart GG: Jim Szykman 919-541-2452 Suzanne Childress (202) 564-7018

Aerospace

NESHAP Subpart II: Mohammed 919-541-2379 Suzanne Childress (202) 564-7018

Ship Building and Repair Serageldin

NESHAP Subpart JJ: Paul Almodovar 919-541-0283 Robert Marshall (202) 564-7021

Wood Furniture

Manufacturing

NESHAP Subpart KK: Dave Salman 919-541-0859 Ginger Gotliffe (202) 564-7072

Printing and Publishing

NESHAP Subpart JJJ: Bob Rosensteel 919-541-5608 Sally Sasnett (202) 564-7074

Polymers & Resins

Group IV
 

APPENDIX J

Small Business Regulatory Enforcement Fairness Act (SBREFA)
Taken from “EPA Interim Guidance for Implementing the 

Small Business Regulatory Enforcement Fairness Act and

Related Provisions of the Regulatory Flexibility Act,” 

prepared by the EPA SBREFA Task Force February 5, 1997

 

4 - 1

Chapter 4

Development and Distribution of SBREFA Compliance Guides

Section Subject Page

I. EPA’s Approach to Compliance Guides 1

II. SBREFA Compliance Guide Template 6

I. EPA’S APPROACH TO COMPLIANCE GUIDES

A. What does SBREFA require?

1. When the Agency prepares a regulatory flexibility analysis for a final rule, SBREFA

Section 212 also requires the Agency to:

a. designate one or more publications regarding such a rule or group of rules as small

entity compliance guides;

b. explain in the guide actions a small entity must take to comply with a rule or group

of rules; and

c. distribute the guides to small entities through “comprehensive sources of

information.”

2. While compliance guides are not themselves judicially reviewable, they may be considered

as evidence of the reasonableness or appropriateness of any penalties or damages in any

civil or administrative action against a small entity. Accordingly, the statute gives us broad

discretion with regard to implementation of these requirements for designation,

development and distribution of the guides. The sections that follow describe how the

Agency has chosen to exercise this discretion, the specifics of which may not necessarily 

be required by SBREFA. As we gain experience, we may issue additional guidance.
Taken from “EPA Interim Guidance for Implementing the 

Small Business Regulatory Enforcement Fairness Act and

Related Provisions of the Regulatory Flexibility Act,” 

prepared by the EPA SBREFA Task Force February 5, 1997

 

4 - 2

B. What is the goal in writing a compliance guide?

The primary goal of the guide is to help small entities-- whether they are small businesses,

communities or non-profits-- to comply with the regulation. You should therefore write

your guide with your audience in mind and recognize that this segment of our regulated

community may have trouble with standard government writing styles. We suggest that

you write in plain and simple language insofar as possible. (While small entities are the

primary audience for the guides, some of the compliance information may also be

applicable to large entities and you may choose to present these similarities/differences as

you develop your guide).

C. Who participates in the development of the Guides?

1. The lead rule-writing office is responsible for developing the rule-specific compliance

guide as part of the rulemaking process.

2. The regulatory development workgroup, as well as representatives from OECA, OGC,

OSBO, OPPT’s Pollution Prevention Division, and regional offices can also provide

assistance/support, or develop sections of the guide, as appropriate. If your regulatory

development workgroup is not represented by the appropriate offices, you should work

through your Steering Committee representative to identify them.

3. Small entity representatives should typically be involved in reviewing the draft compliance

guide after the rule is promulgated so that we have the benefit of their comments and

advice in preparing the final version of the guide.

a. With the exception stated below (b.), draft compliance guides should not be

released to outside parties prior to the rule’s promulgation.

b. In those unusual circumstances where the outline of the compliance guide is clear

to the lead program at the pre-proposal stage, then they may seek review and

feedback from small entity stakeholders at that stage. 

c. You should share the draft compliance guide and solicit comment from small entity

stakeholders after promulgation, but will need to balance such review with a

commensurate concern for timely issuance of the guide.

 

D. When should I begin developing the guide and when will it need to be completed?

1. You should integrate development of the guide into the rulemaking process. Generally,

begin work on your guide as soon as you have enough information to do so. This point

will vary from rule to rule; sometimes it is clear even before the rule is proposed, and in
Taken from “EPA Interim Guidance for Implementing the 

Small Business Regulatory Enforcement Fairness Act and

Related Provisions of the Regulatory Flexibility Act,” 

prepared by the EPA SBREFA Task Force February 5, 1997

 

4 - 3

other cases not enough is known until just prior to final promulgation. In either event,

you should not schedule additional time during the rulemaking process for

development of the guide. The Agency will not ask for extension of any court

deadlines in order to complete compliance guides. 

2. Keep in mind that the goal is to make the guide available after promulgation in sufficient

time for it to be of practical help to small entities in evaluating and implementing their

compliance options before the compliance deadline. You should make every effort to

issue the guide within two months of the promulgation of the final rule.

E. What are the other timing considerations in developing and issuing the Guide?

1. The constraints on outside participation during the final rule phase in development of the

Guide leave a relatively short time after promulgation to both take comment from small

entity stakeholders and issue the final Guide. This makes advance planning and drafting

essential.

Tip: Identify your small entity reviewers early in the process. You should

consider using those small entity representatives who participated in the

development of the proposed rule.

2. If the issuance of your guide may be delayed beyond a month or two, you should issue a 

Fact Sheet or other brief description of the rule as an interim measure.

3. If your rule has a distant compliance date (e.g., two years or more), you may want to reissue the Guide closer to the compliance date.

F. What sorts of questions should I ask my small entity reviewers?

Some suggestions include:

C Is the format appropriate?

C Is the guide clear and easy to read and understand?

C Does the guide accurately describe the rule as published?

C Is the guide useful in planning for compliance?

G. How do I document development of the Guide?
Taken from “EPA Interim Guidance for Implementing the 

Small Business Regulatory Enforcement Fairness Act and

Related Provisions of the Regulatory Flexibility Act,” 

prepared by the EPA SBREFA Task Force February 5, 1997

 

4 - 4

1. If you are doing an Analytic Blueprint you should include plans for developing the guide,

including a time line, and the resources needed. If there is no Blueprint, you should

integrate it into your action or work plan.

2. When you submit your final rule to the Administrator for signature, you must also submit

a schedule for development and completion of the compliance guide.

3. Include your distribution strategy for the guide in the Communications Plan. This is in

addition to your notification plan for the announcement of the rule.

4. Ultimately, the lead office will input information related to the development of the guide

into OPPE’s Regulatory Information System, which is currently under development. Lead

offices may also develop internal methods for tracking the development of the guides.

H. What internal Agency concurrence do I need for the Guide and how do I get it?

You need concurrence from both OGC and OECA. Normally, you will ask members of

your workgroup from these offices to assure that appropriate levels of management in

their offices approve the draft. (OGC and OECA will determine the level of concurrence

they need within their offices). If you don’t have OGC and/or OECA members on your

workgroup, contact your Steering Committee representative who will obtain/identify

contacts for you.

I. When the Guide is in final form, who can help me with distribution?

1. In addition to internal office distribution mechanisms, you should provide Guides to the

Office of the Small Business Ombudsman, the Office of Regional and State/Local

Relations, the Office of Communications, Education and Public Affairs. These offices will

distribute the Guide to their small entity contacts. (You should assure, to the extent it is

feasible, that these offices do not have duplicate distribution lists.)

2. Distribution must be consistent with the recommendations of the Enhanced Public Access

Task Force.

3. Other small business assistance providers include:

C State Technical Assistance Programs for Pollution Prevention

C State Small Business Assistance Programs

C Small Business Development Centers

C Manufacturing Extension Partnership Centers funded by NIST

C Northeast Waste Management Officials Association

C Illinois Hazardous Waste Research and Information Center
Taken from “EPA Interim Guidance for Implementing the 

Small Business Regulatory Enforcement Fairness Act and

Related Provisions of the Regulatory Flexibility Act,” 

prepared by the EPA SBREFA Task Force February 5, 1997

 

4 - 5

C Waste Reduction Resource Center for the Southeast, and

C the Small Business Administration, USDA and OSHA

J. How do we ensure that guides are kept up to date?

1. As a statutory matter, compliance guides may have evidentiary uses in litigation so it is

important that guides be reviewed and revised as needed. It is the responsibility of the

lead office to assure compliance guides are kept current. There is one case in which you

must review an existing guide and several others when revisions may be desirable:

a. Because we must generally review within ten years of promulgation any final rules

for which we conducted regulatory flexibility analyses, the guide will be reviewed

concurrently with the rule on or before the 10-year anniversary.

b. Other circumstances which may occasion revisions include:

C Changes in the rule which affect compliance

C Comments from the public suggesting revisions, or from OECA based on

their experience in enforcing the regulation. (See Appendix, Section C for

instructions on soliciting customer feedback).

C Litigation citing a guide as a reason to challenge the appropriateness of

proposed penalties.

2. You should indicate in every guide that there may be subsequent revisions to the guide

and include information about obtaining the revised guide. Place the most current guide in

the appropriate docket, on a special section in EPA’s internet page, or other electronic

bulletin boards.

Note: OECA may, at a later date, develop sector-specific, multimedia guides which would

integrate rule-specific guides. OECA will notify program offices if and when it undertakes this

project and will coordinate development of such guides through the Agency’s Regulatory

Steering Committee.

II. TEMPLATE FOR COMPLIANCE GUIDES

An Agency workgroup has developed the following template to help you in structuring

your compliance guide, and you should use it in accordance with the guidance given earlier in the

chapter. While SBREFA does not mandate a particular format, we urge you to adopt it so that

we may have general consistency across the Agency and to assure that significant compliance
Taken from “EPA Interim Guidance for Implementing the 

Small Business Regulatory Enforcement Fairness Act and

Related Provisions of the Regulatory Flexibility Act,” 

prepared by the EPA SBREFA Task Force February 5, 1997

 

4 - 6

issues are adequately covered. If your rule does not, for some reason, lend itself to this template,

you may use it as a checklist to ensure that all potentially relevant compliance issues are covered.

The template is organized as follows: 

C Non-italicized text indicates sections which should normally be included in the compliance

guide. 

C We have also included standard language which you may choose to use if it is appropriate

to your rule, and it is presented in italics. You should adapt this standard language to the

specifics of your rule as necessary. 

C Program offices have lead responsibility unless otherwise designated in bold.

Please make your best effort to write your guide in plain language using the guidance at

http://www.blm.gov/nhp/NPR/plaineng.html.
Taken from “EPA Interim Guidance for Implementing the 

Small Business Regulatory Enforcement Fairness Act and

Related Provisions of the Regulatory Flexibility Act,” 

prepared by the EPA SBREFA Task Force February 5, 1997

 

4 - 7

[Insert standard publication header, including the date and appropriate publication number]

SMALL ENTITY COMPLIANCE GUIDE

[insert title of rule or program...]

I. INTRODUCTION

This document is published by the Environmental Protection Agency (EPA) as our

official compliance guide for small entities, as required by the Small Business Regulatory

Enforcement Fairness Act of 1996. Before you begin using the guide you should know that the

information in this guide was compiled and published on [INSERT PUBLICATION DATE]. 

EPA is continually improving and upgrading its rules, policies, compliance programs, and

outreach efforts. You can determine whether EPA has revised or supplemented the information

in this guide by calling [INSERT HOTLINE NUMBER OR INTERNET ADDRESS].

A. Who Should Use this Guide?

1. To the extent possible, the guide should identify all the types/categories of small entities

that will be subject to the rule’s requirements. Bear in mind that other entities may be

indirectly affected but may not be required to comply. This section needs to make this

distinction clear to the reader.

Tip: Use the compliance table from the “Summary” section of your

rule’s preamble to convey this information. Be sure to modify it if

necessary to target small entities.

2. In many cases, the guide will also be useful to larger entities subject to the rule. You may

wish to point out any similarities or differences at this stage but you should not go into

great detail on this subject.

B. What does the Guide Cover? 

C. How do I use the Guide?

D. How do I Obtain a Complete Copy of the Rule? 

List an 800 number, Federal Register citation or the Government Information Locator

Service.
Taken from “EPA Interim Guidance for Implementing the 

Small Business Regulatory Enforcement Fairness Act and

Related Provisions of the Regulatory Flexibility Act,” 

prepared by the EPA SBREFA Task Force February 5, 1997

 

4 - 8

II. WHAT DOES THE REGULATION REQUIRE?

A. What environmental/human health issue(s) does this rule address and why it is

important?

B. Summary of the New Regulation

1. Using plain English, summarize the rule in a narrative format. This should be a simplified

adaptation of the issues you discussed in the rule’s preamble.

2. Additionally, provide a visual description (e.g., chart or flowchart) of the rule’s

requirements as it applies to small entity operations or processes. “Operations” include

traditional facility-based operations and non-traditional based operations such as farms,

communities or schools.

C. Compliance Timetable

Identify in easy-to-read format (e.g., flowchart, time line, timetable) compliance dates for

notifications and other requirements.

D. How Does this Regulation Relate to Other Federal, State, and Local Requirements?

1. Each Program should develop specific template language concerning program delegations

and relationships to other requirements generally, or, where appropriate, referring back

to general provisions applicable to all regulations in a subgroup to which the new

regulation belongs (e.g., New Source Performance Standards under the Clean Air Act). 

Programs have the flexibility to expand this section as appropriate, to address this issue

more specifically.

2. Meanwhile, here is suggested template language which may be appropriate in many cases:

This compliance guide explains your federal compliance

obligations with respect to ______ rule. There may be other state or

local requirements which apply to you which are different from, or

more stringent than, the federal requirements. For example, some

environmental statutes allow EPA to delegate environmental

programs to a state. The state may then promulgate its own rules

which may supersede the federal requirements. For more

information on the rules that apply in your State, please contact

[INSERT CONTACT POINT].
Taken from “EPA Interim Guidance for Implementing the 

Small Business Regulatory Enforcement Fairness Act and

Related Provisions of the Regulatory Flexibility Act,” 

prepared by the EPA SBREFA Task Force February 5, 1997

 

4 - 9

III. STEP-BY-STEP PROCEDURES FOR COMPLIANCE WITH THIS RULE

This is where you break down the rule into discrete subject areas using a step-by-step, 

question/answer approach. Questions in this section will depend on the particular rule. All the

following questions are EXAMPLES of the types of questions that may be appropriate to include. 

A. How can I tell if I am subject to this rule?

B. What requirements am I subject to?

C. When do I need to comply ? (elaborate on flowchart, as appropriate)

D. What do I need to do to comply? 

Be sure to address such questions as:

C How does this rule affect my existing permit?

C How much will it cost to comply with this rule?

E. What, when and how must I monitor or test?

F. What records do I need to keep and for how long?

Include sample forms and calculations.

G. What, when and to whom must I report?

Include sample forms.

H. How do I minimize harm if I think I am out of compliance? (Program lead/OECA

support)

I. Where do I go for help?

Give information on federal, State and local contacts, Agency hotlines, or State Small

Business Assistance Program contacts.

J. What is pollution prevention and how can it affect my operations? (OPPT lead)

1. Discuss pollution prevention and its benefits, including how it may be used to help a

facility/operation save money and/or possibly avoid regulation. 
Taken from “EPA Interim Guidance for Implementing the 

Small Business Regulatory Enforcement Fairness Act and

Related Provisions of the Regulatory Flexibility Act,” 

prepared by the EPA SBREFA Task Force February 5, 1997

 

4 - 10

2. To the extent that there are other pollution prevention opportunities, including those

which may make good business sense or could exempt a small entity from certain

requirements, the program, with support from OPPT, has the option to expand this section

and include this information. 

K. Are there opportunities for flexibility or waivers ?

If this is applicable in a given rule, these opportunities can be highlighted here. For

example, there are circumstances in which the Safe Drinking Water Act allows temporary

variances or exemptions from maximum contaminant levels.

IV. OPTIONAL QUESTIONS AND ANSWERS ABOUT 

FACILITY/OPERATIONS/PROCESSES

Here you want to anticipate questions of potential concern to the regulated community, 

including how the rule fits into the overall regulatory program. Questions will depend on the

rule; the questions below are only EXAMPLES. [Tip: A self-audit checklist can be very helpful

to small entities and may be used alone or in conjunction with a question and answer format.]

A. How do I conduct a self-audit of my facility/firm/operation to help me evaluate

whether I am in compliance with this rule? 

Provide Self-Audit Checklist (Program/OECA) 

B. What are the implications of this rule for my existing permits?

Adapt this to your particular rule or program.

C. How Does this Rule Change How I Handle/ Store Wastes? (if guide were written for

RCRA rule) 

V. THE COMPLIANCE ASSURANCE PROCESS (OECA LEAD)

This section should describe in clear, non-threatening terms why compliance is important, 

the potential consequences of violating the law, and how the entity can work with us to identify

and correct its compliance problems, often without the need for a formal enforcement action or

penalty.

Draft this section to ensure that small entities understand:
Taken from “EPA Interim Guidance for Implementing the 

Small Business Regulatory Enforcement Fairness Act and

Related Provisions of the Regulatory Flexibility Act,” 

prepared by the EPA SBREFA Task Force February 5, 1997

 

4 - 11

C how EPA determines compliance

C what they must do if they discover a violation, and

C the available compliance assistance/enforcement options.

Include only information that is directly relevant to the rule. You may attach more

detailed information, or information you feel may be helpful, in an Appendix.

A. How Is My Operation’s Compliance With Environmental Requirements

Determined?

Discuss compliance assistance, inspections, self-monitoring and the role of citizens.

B. If I Discover a Violation, How Can I Work With The Agency to Correct It?

Discuss compliance incentives policies: Small Communities Policy, Policy on Compliance

Incentives for Small Businesses, Self-Disclosure Policy.

C. If the Agency Discovers a Violation, What Might Be Its Response?

To maximize compliance, EPA implements a balanced program of

compliance assistance, compliance incentives, and traditional law enforcement.

EPA knows that small businesses which must comply with complicated new statutes

or rules often want to do the right thing, but may lack the requisite knowledge,

resources, or skills. Compliance assistance information and technical advice helps

small businesses to understand and meet their environmental obligations.

Compliance incentives, such as our Small Business Policy, encourage persons to

voluntarily discover, disclose, and correct violations before they’re identified by the

government. EPA’s strong law enforcement program protects all of us by targeting

persons who neither comply nor cooperate to address their problems. 

EPA uses a variety of methods to determine whether businesses are

complying, including inspecting facilities, reviewing records and reports, and

responding to citizen complaints. If we learn a person is violating the law, EPA (or

a State, if the program is delegated) may file an enforcement action seeking penalties

of up to $[INSERT STATUTORY MAXIMUM AMOUNT], per violation, per day.

The proposed penalty in a given case will depend on many factors, including the

number, length, and severity of the violations, the economic benefit obtained by the

violator, and its ability to pay. EPA has polices in place to ensure penalties are

calculated fairly. These policies are available to the public. In addition, any
Taken from “EPA Interim Guidance for Implementing the 

Small Business Regulatory Enforcement Fairness Act and

Related Provisions of the Regulatory Flexibility Act,” 

prepared by the EPA SBREFA Task Force February 5, 1997

 

4 - 12

company charged with a violation has the right to contest EPA’s allegations and

proposed penalty before an impartial judge or jury.

In summary, EPA recognizes that we can achieve the greatest possible

protection by encouraging small businesses to work with us to discover, disclose, and

correct violations. That’s why we’ve issued self-disclosure, small business, and

small community policies to eliminate or reduce penalties for small and large entities

which cooperate with EPA to address compliance problems. In addition, we’ve

established compliance assistance centers to serve over a million small businesses.

For more information on these and other EPA programs for small businesses, please

contact [INSERT POINT OF CONTACT]. 

D. What is the legal status of this guide?

A judge can look at a compliance guide in determining what penalty is

appropriate and reasonable, although the content of the guide cannot otherwise be

reviewed by the court.

In this Compliance Guide, we have tried to make clear what you must do to

comply with the applicable law and regulation. This is the minimum required by

SBREFA. You'll notice, however, that here and there we have also included

suggestions for alternative approaches that may make compliance easier and

possibly even reduce costs. We hope you find this presentation of regulatory

requirements useful and the additional information helpful in reaching and

maintaining compliance.

APPENDIX

A. Glossary of Environmental Terms

Define terms which are relevant to the rule but which may be too basic to be defined in

the rule itself. For example, “permit,” “pollution prevention,” “process.”

B. Where to Obtain More Information

This section gives supplemental information. Examples might include other existing

quality compliance guidance, pollution prevention guidance, pollution prevention case

studies, other media contacts, trade associations, or university assistance programs.

C. Questionnaire - How Useful Was This Guide?
Taken from “EPA Interim Guidance for Implementing the 

Small Business Regulatory Enforcement Fairness Act and

Related Provisions of the Regulatory Flexibility Act,” 

prepared by the EPA SBREFA Task Force February 5, 1997

 

4 - 13

Each guide should contain a brief questionnaire to solicit feedback from users as to the

usefulness, readability, and improvements needed for the guide. Questionnaires will be

returned to OPPE/RMD and then forwarded to the Agency contact. Please use the

following page:
Taken from “EPA Interim Guidance for Implementing the 

Small Business Regulatory Enforcement Fairness Act and

Related Provisions of the Regulatory Flexibility Act,” 

prepared by the EPA SBREFA Task Force February 5, 1997

 

4 - 14

Date:____________________

Title of Rule or Program:_________________________________________________

Name of Commenter (optional):____________________________________________

Please take a moment to let us know if you found this guide useful by answering the

following questions. Thank you, your feedback is important to us.

1. I could easily understand what requirements I must meet._______

2. The guide is written in understandable language._______

3. The guide helped me understand the steps I must take to comply with the rule._______

4. If you have suggestions to improve the guide, please indicate below:

Please fold on dashed line, affix postage and return by mail. Thank-you.

Affix

Postage

Here

U.S. EPA

Regulatory Management Division

Mail Code 2136

401 M St. SW

Washington, DC 20460
APPENDIX K

Master Compliance Timeline for Part 63 NESHAP
4 - 1 

Methods for Compilation of the Draft Master Compliance Timeline

The Draft Master Compliance Timeline was developed from an OAQPS/ESD document

that summarized milestone dates for each promulgated NESHAP listed in 40 CFR Part 63. In

general, the milestones are similar for each NESHAP. Where exceptions or unique milestones

were an issue, the information was noted in the Timeline. 

The milestone dates listed are the latest possible dates by which the action item must be

completed. Thus, using the Secondary Lead Smelting NESHAP as an example, if an

Owner/Operator of a Secondary Lead Smelting Facility schedules a Performance Test on

November 20, 1997, instead of the latest possible date (stated in the standard) of December 20,

1997, the first Compliance Status Report must be submitted by January 19, 1998 (i.e., within the

required 60 days) not on February 18, 1998. 

Most NESHAPs follow the steps indicated in the table below, and these milestones are

included in the Master Compliance Timeline.

ACTION ITEM MILESTONE DATEa

Effective Date determined by the EPA

O/O: Initial Notification Due within 120 days of the effective date

O/O: Submit Special Compliance Monitoring or varies by standard

Implementation Plans

EPA/State: Review/Approve Special Compliance Monitoring varies by standard

or Implementation Plans

O/O: Request for Compliance Extension 12 months before the compliance date

EPA/State: Approval for Request of Compliance Extensions 3 months after request

Compliance Date 3 years after Effective Date 

O/O: Notice of Performance Test 30 days before Performance Test

EPA/State: Approval of Site-Specific Test Plan Up to the Performance Test date
4 - 2 

Performance Test 180 days after Compliance Date

Compliance Status Reports First one is due within 60 days of the Performance

Test

Applicability Date for New Sources determined by the EPA

 Source: Fruh, S., Summary of Compliance Dates for Promulgated Part 63 MACT Regulations, December, 1996.

O/O = Owner/Operator

 = Due to the various criteria for determining implementation dates under the Coke Ovens HAP, it was a

not included in the Master Compliance Timeline (with the exception of the Applicability Date for

New Sources”).

Because the following action items are only applicable to new sources (which are a small

percentage of the currently regulated population), they were not included in the Master

Compliance Timeline. 

ACTION ITEM MILESTONE DATE

O/O: Application for Approval to Construct/Reconstruct a determined by the Owner/Operator

Major Emitting Source

EPA/State: Notice of Complete Information 30 days from application

EPA/State: Approval or Disapproval of 60 days from application

Construction/Reconstruction

O/O: Notice of Intended Startup 60 days before startup

 Source: Fruh, S., Summary of Compliance Dates for Promulgated Part 63 MACT Regulations, March, 1997.

O/O = Owner/Operator
MASTER COMPLIANCE TIMELINE

TIMELINE CATEGORY

Applicability Date for New Sources

Effective Date

O/O: Initial Notification Due

O/O: Submit Special Compliance Monitoring or 

Implementation Plans

EPA/State: Review/Approve Special Compliance 

Monitoring or Implementation Plans

O/O: Request for Compliance Extension

EPA/State: Approval of Request for Compliance 

Extensions

Compliance Date

O/O: Notice of Performance Test

EPA/State: Approval of Site-Specific Test Plan

Performance Test

Compliance Status Reports 

O/O = Owner/Operator

Page 1
MASTER COMPLIANCE TIMELINE

TIMELINE CATEGORY

Applicability Date for New Sources

Effective Date

O/O: Initial Notification Due

O/O: Submit Special Compliance Monitoring or 

Implementation Plans

EPA/State: Review/Approve Special Compliance 

Monitoring or Implementation Plans

O/O: Request for Compliance Extension

EPA/State: Approval of Request for Compliance 

Extensions

Compliance Date

O/O: Notice of Performance Test

EPA/State: Approval of Site-Specific Test Plan

Performance Test

Compliance Status Reports 

O/O = Owner/Operator

Page 2
MASTER COMPLIANCE TIMELINE

TIMELINE CATEGORY

Applicability Date for New Sources

Effective Date

O/O: Initial Notification Due

O/O: Submit Special Compliance Monitoring or 

Implementation Plans

EPA/State: Review/Approve Special Compliance 

Monitoring or Implementation Plans

O/O: Request for Compliance Extension

EPA/State: Approval of Request for Compliance 

Extensions

Compliance Date

O/O: Notice of Performance Test

EPA/State: Approval of Site-Specific Test Plan

Performance Test

Compliance Status Reports 

O/O = Owner/Operator

Nov-90 Dec-90 Jan-91 Feb-91 Mar-91 Apr-91 May-91 Jun-91 Jul-91 Aug-91 Sep-91 Oct-91 Nov-91 Dec-91

11/15/90 - 

Coke Ovens

12/9/91 - 

Perchloroethylene 

Dry Cleaning 

Facilities

Page 3
MASTER COMPLIANCE TIMELINE

TIMELINE CATEGORY

Applicability Date for New Sources

Effective Date

O/O: Initial Notification Due

O/O: Submit Special Compliance Monitoring or 

Implementation Plans

EPA/State: Review/Approve Special Compliance 

Monitoring or Implementation Plans

O/O: Request for Compliance Extension

EPA/State: Approval of Request for Compliance 

Extensions

Compliance Date

O/O: Notice of Performance Test

EPA/State: Approval of Site-Specific Test Plan

Performance Test

Compliance Status Reports 

O/O = Owner/Operator

Jan-92 Feb-92 Mar-92 Apr-92 May-92 Jun-92 Jul-92 Aug-92 Sep-92 Oct-92 Nov-92 Dec-92 Jan-93 Feb-93 Mar-93

12/31/92 - 

SOCMI

Page 4
MASTER COMPLIANCE TIMELINE

TIMELINE CATEGORY

Applicability Date for New Sources

Effective Date

O/O: Initial Notification Due

O/O: Submit Special Compliance Monitoring or 

Implementation Plans

EPA/State: Review/Approve Special Compliance 

Monitoring or Implementation Plans

O/O: Request for Compliance Extension

EPA/State: Approval of Request for Compliance 

Extensions

Compliance Date

O/O: Notice of Performance Test

EPA/State: Approval of Site-Specific Test Plan

Performance Test

Compliance Status Reports 

O/O = Owner/Operator

Apr-93 May-93 Jun-93 Jul-93 Aug-93 Sep-93 Oct-93 Nov-93 Dec-93 Jan-94 Feb-94

8/12/93 - Industrial 

Process Cooling 

Towers

11/29/93 - 

Halogenated 

Solvent Cleaning

12/16/93 - 

Chrome 

Electroplating

2/8/94 - Gasoline 

Distribution

9/22/93 - 

Perchloroethylene 

Dry Cleaning 

Facilities

10/27/93 - 

Coke Ovens

12/20/93 - 

Perchloroethyle

ne (Work 

Practice)

Page 5
MASTER COMPLIANCE TIMELINE

TIMELINE CATEGORY

Applicability Date for New Sources

Effective Date

O/O: Initial Notification Due

O/O: Submit Special Compliance Monitoring or 

Implementation Plans

EPA/State: Review/Approve Special Compliance 

Monitoring or Implementation Plans

O/O: Request for Compliance Extension

EPA/State: Approval of Request for Compliance 

Extensions

Compliance Date

O/O: Notice of Performance Test

EPA/State: Approval of Site-Specific Test Plan

Performance Test

Compliance Status Reports 

O/O = Owner/Operator

Mar-94 Apr-94 May-94 Jun-94 Jul-94

3/7/94 - Ethylene Oxide Commercial 

Sterilization Facilities

3/11/94 - Magnetic Tape Manufacturing

5/13/94 - Marine Tank Vessel Loading 

Operations

5/16/94 - Epoxy Resins and NonNylon Polyamides Production

6/6/94 - Aerospace Manufacturing and 

Rework Facilities

6/9/94 - Secondary Lead Smelting

7/15/94 - Petroleum 

Refineries: Other 

Sources Not Directly 

Listed

4/24/94 - 

SOCMI

6/18/94 - Perchloroethylene Dry 

Cleaning Facilities

6/18/94 - Perchloroethylene (Work 

Practice)

Page 6
MASTER COMPLIANCE TIMELINE

TIMELINE CATEGORY

Applicability Date for New Sources

Effective Date

O/O: Initial Notification Due

O/O: Submit Special Compliance Monitoring or 

Implementation Plans

EPA/State: Review/Approve Special Compliance 

Monitoring or Implementation Plans

O/O: Request for Compliance Extension

EPA/State: Approval of Request for Compliance 

Extensions

Compliance Date

O/O: Notice of Performance Test

EPA/State: Approval of Site-Specific Test Plan

Performance Test

Compliance Status Reports 

O/O = Owner/Operator

Aug-94 Sep-94 Oct-94 Nov-94 Dec-94 Jan-95 Feb-95

10/13/94 - Off-Site 

Waste and Recovery 

Operations

12/6/94 - Shipbuilding and Ship Repair Facilities

12/6/94 - Wood Furniture Manufacturing Operations NESHAP

9/8/94 - Industrial 

Process Cooling 

Towers

12/2/94 - Halogenated Solvent Cleaning

12/6/94 - Ethylene Oxide Commercial Sterilization Facilities

12/14/94 -Gasoline Distribution

12/15/94 - Magnetic Tape Manufacturing

1/25/95 - 

Chrome 

Electroplating

8/19/94 - 

SOCMI

10/24/94 - window 

begins for Subpart H 

under SOCMI

Page 7
MASTER COMPLIANCE TIMELINE

TIMELINE CATEGORY

Applicability Date for New Sources

Effective Date

O/O: Initial Notification Due

O/O: Submit Special Compliance Monitoring or 

Implementation Plans

EPA/State: Review/Approve Special Compliance 

Monitoring or Implementation Plans

O/O: Request for Compliance Extension

EPA/State: Approval of Request for Compliance 

Extensions

Compliance Date

O/O: Notice of Performance Test

EPA/State: Approval of Site-Specific Test Plan

Performance Test

Compliance Status Reports 

O/O = Owner/Operator

Mar-95 Apr-95 May-95 Jun-95 Jul-95 Aug-95

3/14/95 -Printing and 

Publishing

3/29/95 - Polymer & 

Resins Group IV

6/12/95 - 

Polymers & 

Resins Group I

3/8/95 - Epoxy Resins and 

Non-Nylon Polyamides 

Production

6/23/95 - 

Secondary Lead 

Smelting

8/18/95 - Petroleum 

Refineries: Other 

Sources Not Directly 

Listed

4/8/95 - Ethylene Oxide Commercial 

Sterilization Facilities

4/14/95 - Magnetic Tape Manufacturing

7/6/95 - Epoxy Resins and Non-Nylon 

Polyamides Production

7/24/95 - Chrome Electroplating

8/29/95 - Halogenated 

Solvent Cleaning

6/25/95 - Chrome 

Electroplating 

(decorative)

Page 8
MASTER COMPLIANCE TIMELINE

TIMELINE CATEGORY

Applicability Date for New Sources

Effective Date

O/O: Initial Notification Due

O/O: Submit Special Compliance Monitoring or 

Implementation Plans

EPA/State: Review/Approve Special Compliance 

Monitoring or Implementation Plans

O/O: Request for Compliance Extension

EPA/State: Approval of Request for Compliance 

Extensions

Compliance Date

O/O: Notice of Performance Test

EPA/State: Approval of Site-Specific Test Plan

Performance Test

Compliance Status Reports 

O/O = Owner/Operator

Sep-95 Oct-95 Nov-95 Dec-95 Jan-96 Feb-96 Mar-96 Apr-96

9/1/95 - Aerospace Manufacturing and 

Rework Facilities

9/19/95 - Marine Tank Vessel Loading 

Operations

12/7/95 - Wood Furniture 

Manufacturing Operations 

12/15/95 - Shipbuilding and 

Ship Repair Facilites

9/8/95 - Industrial Process Cooling 

Tower

10/23/95 - 

Secondary Lead 

Smelting

12/15/95 - Magnetic Tape 

Manufacturing (w/o new 

control device)

9/25/95 - Chrome Electroplating 

(decorative)

3/15/96 - Magnetic 

Tape Manufacturing 

(w/o new control 

device)

10/23/95 - 

window ends for 

Subpart H under 

SOCMI

1/25/96 - 

Chrome 

Electroplating 

(Decorative)

3/8/96 - Industrial 

Process Cooling 

Towers

Page 9
MASTER COMPLIANCE TIMELINE

TIMELINE CATEGORY

Applicability Date for New Sources

Effective Date

O/O: Initial Notification Due

O/O: Submit Special Compliance Monitoring or 

Implementation Plans

EPA/State: Review/Approve Special Compliance 

Monitoring or Implementation Plans

O/O: Request for Compliance Extension

EPA/State: Approval of Request for Compliance 

Extensions

Compliance Date

O/O: Notice of Performance Test

EPA/State: Approval of Site-Specific Test Plan

Performance Test

Compliance Status Reports 

O/O = Owner/Operator

May-96 Jun-96 Jul-96 Aug-96 Sep-96 Oct-96

5/30/96 - 

Printing and 

Publishing

7/1/96 - OffSite Waste and 

Recovery 

Operations

9/5/96 - Polymers and Resins Group I

9/12/96 - Polymers and Resins Group IV

6/13/96 - Shipbuilding 

and Ship Repair 

Facilities

9/3/96 - Wood Furniture Manufacturing Operations

9/19/96 - Marine Tank Vessel Loading Operations

10/28/96 - Off-Site Waste and 

Recovery Operations

6/25/96 - Chrome 

Electroplating (hard & 

anodizing)

9/25/96 - Chrome Electroplating (hard & anodizing)

9/23/96 - Perchloroethylene Dry Cleaning Facilities

5/24/96 - 

Chrome 

Electroplating 

(decorative)

6/23/96 - Chrome 

Electroplating 

(decorative)

7/23/96 - 

Chrome 

Electroplating 

(decorative)

10/21/96 - Chrome 

Electroplating (decorative)

10/23/96 - Perchloroethylene 

Dry Cleaners (control 

hardware)

Page 10
MASTER COMPLIANCE TIMELINE

TIMELINE CATEGORY

Applicability Date for New Sources

Effective Date

O/O: Initial Notification Due

O/O: Submit Special Compliance Monitoring or 

Implementation Plans

EPA/State: Review/Approve Special Compliance 

Monitoring or Implementation Plans

O/O: Request for Compliance Extension

EPA/State: Approval of Request for Compliance 

Extensions

Compliance Date

O/O: Notice of Performance Test

EPA/State: Approval of Site-Specific Test Plan

Performance Test

Compliance Status Reports 

O/O = Owner/Operator

Nov-96 Dec-96 Jan-97 Feb-97

12/16/96 - Gasoline Distribution (also notification date, if using a 

screening equation)

12/16/96 - Shipbuilding and Ship Repair Facilities

12/23/96 - Secondary Lead Smelting

2/18/97 - Petroleum 

Refining (for those 

choosing emissions 

averaging)

11/21/96 - Wood 

Furniture Manufacturing 

Operations (w/ sources 

emitting > 50 tons HAPs 

in 1996)

12/2/96 - Halogenated Solvent Cleaning

12/8/96 - Ethylene Oxide Commercial Sterilization Facilities

12/15/96 - Magnetic Tape Manufacturing (w/new control device)

12/16/96 - Gasoline Distribution

12/24/96 - SOCMI

2/21/97 - Wood Furniture 

Manufacturing 

Operations (w/ sources 

emitting > 50 tons HAPs 

in 1996)

12/15/96 - Magnetic Tape Manufacturing (w/o new control device) 1/25/97 - Chrome Electroplating (hard & 

anodizing)

Page 11
MASTER COMPLIANCE TIMELINE

TIMELINE CATEGORY

Applicability Date for New Sources

Effective Date

O/O: Initial Notification Due

O/O: Submit Special Compliance Monitoring or 

Implementation Plans

EPA/State: Review/Approve Special Compliance 

Monitoring or Implementation Plans

O/O: Request for Compliance Extension

EPA/State: Approval of Request for Compliance 

Extensions

Compliance Date

O/O: Notice of Performance Test

EPA/State: Approval of Site-Specific Test Plan

Performance Test

Compliance Status Reports 

O/O = Owner/Operator

Mar-97 Apr-97 May-97 Jun-97

3/22/97 - Secondary Lead Smelting 6/18/97 - Petroleum Refining (for 

those choosing emissions 

averaging)

3/8/97 - Epoxy Resins and Non-Nylon Polyamides Production 6/23/97 - Secondary Lead Smelting

3/2/97 - Halogenated Solvent Cleaning

3/15/97 - Magnetic Tape Manufacturing (w/new control device)

3/16/97 - Gasoline Distribution

3/16/97 - Shipbuilding and Ship Repair Facilities

3/24/97 -SOCMI

6/8/97 - Epoxy Resins and NonNylon Polyamides Production

4/22/97 - SOCMI 

F&G

5/14/97 - Magnetic Tape 

Manufacturing (w/o new control 

device)

5/25/97 - Chrome Electroplating 

(hard & anodizing)

6/13/97 - Magnetic Tape 

Manufacturing (w/o new control 

device)

6/24/97 - Chrome Electroplating 

(hard & anodizing)

6/13/97 - Magnetic Tape 

Manufacturing (w/o new control 

device)

Page 12
MASTER COMPLIANCE TIMELINE

TIMELINE CATEGORY

Applicability Date for New Sources

Effective Date

O/O: Initial Notification Due

O/O: Submit Special Compliance Monitoring or 

Implementation Plans

EPA/State: Review/Approve Special Compliance 

Monitoring or Implementation Plans

O/O: Request for Compliance Extension

EPA/State: Approval of Request for Compliance 

Extensions

Compliance Date

O/O: Notice of Performance Test

EPA/State: Approval of Site-Specific Test Plan

Performance Test

Compliance Status Reports 

O/O = Owner/Operator

Jul-97 Aug-97 Sep-97 Oct-97 Nov-97

9/1/97 - Aerospace 

Manufacturing and Rework 

Facilities

8/12/97 - Magnetic Tape Manufacturing 

(w/o control device: submitting a plan 

identifying parameters to be monitored for 

capture efficiency)

8/18/97 - Petroleum Refineries: Other 

Sources Not Directly Listed

9/17/97 - Petroleum 

Refineries: Other Sources 

Not Directly Listed

9/21/97 - Secondary Lead 

Smelting 

7/31/97 - Polymers & Resins 

I (Equipment Leaks)

7/31/97 - Polymers & Resins 

IV (Equipment Leaks)

11/21/97 - Wood 

Furniture Manufacturing 

Operations (w/ sources 

emitting > 50 tons HAPs 

in 1996)

8/20/97 - SOCMI F&G

7/24/97 - Chrome 

Electroplating (hard & 

anodizing)

9/19/97 - SOCMI F&G

8/12/97 - Magnetic Tape Manufacturing 

(w/o new control device)

9/19/97 - SOCMI F&G 10/22/97 - 

Chrome 

Electroplating 

(hard & 

anodizing)

Page 13
MASTER COMPLIANCE TIMELINE

TIMELINE CATEGORY

Applicability Date for New Sources

Effective Date

O/O: Initial Notification Due

O/O: Submit Special Compliance Monitoring or 

Implementation Plans

EPA/State: Review/Approve Special Compliance 

Monitoring or Implementation Plans

O/O: Request for Compliance Extension

EPA/State: Approval of Request for Compliance 

Extensions

Compliance Date

O/O: Notice of Performance Test

EPA/State: Approval of Site-Specific Test Plan

Performance Test

Compliance Status Reports 

O/O = Owner/Operator

Dec-97 Jan-98 Feb-98 Mar-98

12/10/97 - Magnetic Tape Manufacturing (w/o control device: 

submitting an alternative limit when a coating operation is not occuring)

3/5/98 - Polymers and Resins Group 

I (emissions averaging)

3/12/98 - Polymers and Resins 

Group IV (emissions averaging)

2/8/98 - Magnetic Tape Manufacturing 

(w/o control device: submitting an 

alternative limit when a coating 

operation is not occuring)

12/7/97 - Wood Furniture Manufacturing Operations (for sources 

emitting < 50 tons HAPs in 1996)

12/16/97 - Shipbuilding and Ship Repair Facilities

3/7/98 - Wood Furniture 

Manufacturing Operations (for 

sources emitting < 50 tons HAPs in 

1996)

12/2/97 - Halogenated Solvent Cleaning

12/15/97 - Gasoline Distribution

12/15/97 - Magnetic Tape Manufacturing (w/new control device)

12/16/97 - Shipbuilding and Ship Repair Facilities

12/23/97 - Secondary Lead Smelting

3/8/98 - Epoxy Resins and NonNylon Polyamides Production

1/1/98 - 

Halogenated 

Solvent 

Cleaning

2/1/98 - Halogenated Solvent Cleaning

3/2/98 - Halogenated Solvent 

Cleaning

1/21/98 - Wood 

Furniture (< 50 

tons HAP)

Page 14
MASTER COMPLIANCE TIMELINE

TIMELINE CATEGORY

Applicability Date for New Sources

Effective Date

O/O: Initial Notification Due

O/O: Submit Special Compliance Monitoring or 

Implementation Plans

EPA/State: Review/Approve Special Compliance 

Monitoring or Implementation Plans

O/O: Request for Compliance Extension

EPA/State: Approval of Request for Compliance 

Extensions

Compliance Date

O/O: Notice of Performance Test

EPA/State: Approval of Site-Specific Test Plan

Performance Test

Compliance Status Reports 

O/O = Owner/Operator

Apr-98 May-98 Jun-98

5/30/98 - Printing and Publishing

5/4/98 - Aerospace Manufacturing and 

Rework Facilities 

5/30/98 - Printing and Publishing

6/30/98 - Printing and Publishing

4/14/98 - Gasoline Distribution

4/20/98 - Wood Furniture Manufacturing Operations (w/ 

sources emitting > 50 tons HAPs in 1996)

5/14/98 - Magnetic Tape Manufacturing 

(w/new control device)

5/15/98 - Shipbuilding and Ship Repair

5/21/98 - Secondary Lead Smelting

4/20/98 - Wood Furniture Manufacturing Operations (w/ 

sources emitting > 50 tons HAPs in 1996)

5/14/98 - Gasoline Distribution

5/15/98 - Shipbuilding and Ship Repair 

Facilities

6/13/98 - Magnetic Tape Manufacturing (w/new control device)

6/21/98 - Secondary Lead Smelting

5/21/98 - Wood Furniture Manufacturing 

Operations (w/ sources emitting > 50 tons 

HAPs in 1996) 

6/13/98 - Gasoline Distribution

6/13/98 - Magnetic Tape Manufacturing (w/new control device)

6/14/98 - Shipbuilding and Ship Repair Facilities

6/21/98 - Secondary Lead Smelting

5/2/98 - Halogenated Solvent Cleaning

Page 15
MASTER COMPLIANCE TIMELINE

TIMELINE CATEGORY

Applicability Date for New Sources

Effective Date

O/O: Initial Notification Due

O/O: Submit Special Compliance Monitoring or 

Implementation Plans

EPA/State: Review/Approve Special Compliance 

Monitoring or Implementation Plans

O/O: Request for Compliance Extension

EPA/State: Approval of Request for Compliance 

Extensions

Compliance Date

O/O: Notice of Performance Test

EPA/State: Approval of Site-Specific Test Plan

Performance Test

Compliance Status Reports 

O/O = Owner/Operator

Jul-98 Aug-98 Sep-98

8/12/98 - Magnetic Tape Manufacturing (w/o control device: 

submitting a plan identifying parameters to be monitored for capture 

efficiency)

9/5/98 - Polymers and Resins Group I (precompliance report)

9/12/98 - Polymers and Resins Group IV 

(pre-compliance report)

7/5/98 - Polymers and Resins Group I 

(emissions averaging)

7/12/98 - Polymers and Resins Group IV 

(emissions averaging)

7/1/98 - Off-Site Waste and Recovery 

Operations

9/5/98 - Polymers and Resins Group I (not 

for equip. leaks/compressors)

9/12/98 - Polymers and Resins Group IV 

(not for equip. leaks/compressors)

7/4/98 - Aerospace Manufacturing and 

Rework Facilities

8/18/98 - Petroleum Refineries: Other Sources Not Directly Listed (for 

those choosing emissions averaging and for floating roof storage 

vessels)

9/1/98 - Aerospace Manufacturing and 

Rework Facilities

7/6/98 - Epoxy Resins and Non-Nylon 

Polyamides Production

9/17/98 - Petroleum Refineries: Other 

Sources Not Directly Listed (those 

choosing emissions averaging)

8/5/98 - Epoxy Resins and Non-Nylon Polyamides Production

9/4/98 - Epoxy Resins and Non-Nylon 

Polyamides Production

7/19/98 - Wood Furniture Manufacturing 

Operations (w/ sources emitting > 50 tons 

HAPs in 1996) 

7/30/98 - Halogenated Solvent Cleaning

8/12/98 - Gasoline Distribution

8/12/98 - Magnetic Tape Manufacturing (w/new control device)

8/13/98 - Shipbuilding and Ship Repair Facilities

8/21/98 - Secondary Lead Smelting

a

 According to a July 29, 1997 memorandum from the Director 

 Commercial Sterilization facilities is expected to move from De

Page 16
MASTER COMPLIANCE TIMELINE

TIMELINE CATEGORY

Applicability Date for New Sources

Effective Date

O/O: Initial Notification Due

O/O: Submit Special Compliance Monitoring or 

Implementation Plans

EPA/State: Review/Approve Special Compliance 

Monitoring or Implementation Plans

O/O: Request for Compliance Extension

EPA/State: Approval of Request for Compliance 

Extensions

Compliance Date

O/O: Notice of Performance Test

EPA/State: Approval of Site-Specific Test Plan

Performance Test

Compliance Status Reports 

O/O = Owner/Operator

Oct-98 Nov-98 Dec-98 Jan-99

12/10/98 - Magnetic Tape Manufacturing 

(with a control device: submitting an 

alternative limit when a coating operation is 

not occuring)

10/5/98 - Polymers and Resins Group I (precompliance report)

10/12/98 - Polymers and Resins Group IV 

(pre-compliance report)

10/1/98 - Off-Site Waste and Recovery 

Operations

10/5/98 - Polymers and Resins Group I (not 

for equip. leaks/compressors)

12/12/98 - Polymers and Resins Group IV

12/7/98 - Wood Furniture Manufacturing 

Operations (for sources emitting < 50 tons 

HAPs in 1996)

12/8/98 - Ethylene Oxide Commercial 

Sterilization Facilitiesa

12/30/98 - Aerospace Manufacturing and 

Rework Facilities

1/30/99 - Aerospace 

Manufacturing and 

Rework Facilities

11/3/98 - Epoxy 

Resins and NonNylon Polyamides

1/15/99 - Petroleum 

Refineries: Other 

Sources Not Directly 

Listed

a According to a July 29, 1997 memorandum from the Director of OAQPS, the compliance date for Ethylene Oxide

 Sterilization facilities is expected to move from December 8, 1997 to December 8, 1998

Page 17
MASTER COMPLIANCE TIMELINE

TIMELINE CATEGORY

Applicability Date for New Sources

Effective Date

O/O: Initial Notification Due

O/O: Submit Special Compliance Monitoring or 

Implementation Plans

EPA/State: Review/Approve Special Compliance 

Monitoring or Implementation Plans

O/O: Request for Compliance Extension

EPA/State: Approval of Request for Compliance 

Extensions

Compliance Date

O/O: Notice of Performance Test

EPA/State: Approval of Site-Specific Test Plan

Performance Test

Compliance Status Reports 

O/O = Owner/Operator

Feb-99 Mar-99 Apr-99 May-99 Jun-99 Jul-99

2/8/99 - Magnetic Tape Manufacturing 

(with a control device: submitting an 

alternative limit when a coating 

operation is not occuring)

4/22/99 - SOCMI 

(Wastewater)

5/30/99 - Printing and 

Publishing

7/1/99 - OffSite Waste and 

Recovery 

Operations

5/6/99 - Wood Furniture 

Manufacturing Operations 

(for sources emitting < 50 

tons HAPs in 1996)

5/6/99 - Wood Furniture 

Manufacturing Operations 

(for sources emitting < 50 

tons HAPs in 1996)

2/28/99 - Aerospace Manufacturing and 

Rework Facilities

6/7/99 - Wood Furniture 

Manufacturing Operations 

(for sources emitting < 50 

tons HAPs in 1996)

2/7/99 - Wood Furniture Manufacturing 

Operations (for sources emitting < 50 

tons HAPs in 1996)

4/28/99 - Aerospace 

Manufacturing and 

Rework Facilities

Page 18
MASTER COMPLIANCE TIMELINE

TIMELINE CATEGORY

Applicability Date for New Sources

Effective Date

O/O: Initial Notification Due

O/O: Submit Special Compliance Monitoring or 

Implementation Plans

EPA/State: Review/Approve Special Compliance 

Monitoring or Implementation Plans

O/O: Request for Compliance Extension

EPA/State: Approval of Request for Compliance 

Extensions

Compliance Date

O/O: Notice of Performance Test

EPA/State: Approval of Site-Specific Test Plan

Performance Test

Compliance Status Reports 

O/O = Owner/Operator

Aug-99 Sep-99 Oct-99 Nov-99 Dec-99

8/18/99 - Petroleum 

Refineries (marine tank 

vessels not electing 

emissions averaging)

9/5/99 - Polymers and Resins Group I (not for equip. 

leaks/compressors)

9/12/99 - Polymers and Resins Group IV(not for equip. 

leaks/compressors)

9/19/99 - Marine Tank Vessel Loading Operations

9/27/99 - Printing and Publishing 10/19/99 - SOCMI 

(Wastewater)

10/27/99 - Off-Site Waste 

and Recovery Operations

10/27/99 - Printing and 

Publishing

11/28/99 - OffSite Waste and 

Recovery 

Operations

10/20/99 - SOCMI 

(Wastewater)

11/26/99 - 

Printing and 

Publishing

12/28/99 - Off-Site 

Waste and Recovery 

Operations

Page 19
MASTER COMPLIANCE TIMELINE

TIMELINE CATEGORY

Applicability Date for New Sources

Effective Date

O/O: Initial Notification Due

O/O: Submit Special Compliance Monitoring or 

Implementation Plans

EPA/State: Review/Approve Special Compliance 

Monitoring or Implementation Plans

O/O: Request for Compliance Extension

EPA/State: Approval of Request for Compliance 

Extensions

Compliance Date

O/O: Notice of Performance Test

EPA/State: Approval of Site-Specific Test Plan

Performance Test

Compliance Status Reports 

O/O = Owner/Operator

Jan-00 Feb-00 Mar-00 Apr-00 May-00

1/5/00 - Polymers and Resins I

1/12/00 - Polymers and Resins IV

1/17/00 - Marine Vessel Tank 

Loading Operations

1/12/00 - Polymers and Resins Group 

IV

2/5/00 - Polymers and Resins I

2/16/00 - Marine Tank Vessel Loading 

Operations

2/5/00 - Polymers and Resins Group I

2/12/00 - Polymers and Resins Group IV

3/17/00 - 

Marine Vessel 

Tank Loading 

Operations

1/25/00 - Printing and Publishing 2/5/00 - Polymers and Resins Group I

2/12/00 - Polymers and Resins Group IV

2/26/00 - Off-Site Waste and Recovery 

Operations

5/16/00 - Marine 

Tank Vessel 

Loading 

Operations

Page 20
4 - 4 

APPENDIX L

MACTRAX
4 - 1 

MACTRAX

C Used by the Regional Offices to transfer information to OAQPS.

C Identifies which State/Locals (S/L) are implementing each MACT standard: 

< thru Title V delegation

< thru implementation agreements

< by Regional Office

C Each Title V program will have a MACTRAX screen per standard

C The information collected in MACTRAX for FY 1997 from S/L’s with delegation authority

will be voluntary.

C The information to be collected in MACTRAX was included for the performance measures

for the Office of Air Research FY 1997-98 Implementation Plan.

C Regions are expected to incorporate performance measures in their FY 1998 State agreements

which would include providing (or at least requesting) the MACTRAX reporting information

for the end of the FY 1997 reporting cycle.

C The Region should identify the States that are not providing the information by adding a note

in the comment field of the delegation screen.

C The regions can use the source-specific information available in AIRS Facility Subsystem

(AFS) as the summary of the source category-specific information needed in MACTRAX. 

State delegation information, which is not provided through AFS, will still need to be entered

into MACTRAX on the same time schedule.