	   U.S. Environmental Protection Agency - October 2007

Compliance and Enforcement National Priority

Clean Air Act, Air Toxics

What is the Environmental Problem?

For the FY 2008-2010 planning cycle, the Air Toxics National Compliance
and Enforcement Strategy will focus on the problem areas of leak
detection and repair (LDAR), industrial flares, and surface coating.  To
address these problem areas, EPA will utilize a combination of
compliance assistance, compliance evaluations and enforcement.

LDAR

Leaking equipment, such as valves, pumps, and connectors, are the
largest source of emissions of volatile organic compounds (VOCs) and
volatile hazardous air pollutants (VHAPs) from petroleum refineries and
chemical manufacturing facilities. The most significant equipment leak
emission sources are pumps, valves, connectors, sampling connections,
compressors, pressure relief devices, and open-ended lines.  The major
cause of emissions from these components is seal or gasket failure due
to normal wear or improper maintenance. 

To reduce emissions from leaking equipment, federal, state, and local
regulations require LDAR programs.  However, recent compliance
evaluations conducted by EPA found significantly higher numbers of
leaking components than were reported by regulated entities.  EPA
believes this discrepancy is due to improper monitoring techniques and
ineffective management of the LDAR program.

 

LDAR was selected as a national initiative in the FY 2005-2007 Air
Toxics Strategy due to widespread noncompliance and the potential for
significant emission reductions when facilities are brought into
compliance.  In FY 2006, EPA achieved over 250,000 pounds in hazardous
air pollutants (HAP) emission reductions from LDAR enforcement and
compliance actions.  With the large universe of sources subject to LDAR
requirements and the high level of noncompliance, EPA will continue to
focus on LDAR in the 

FY 2008-2010 Air Toxics Strategy.

Industrial Flares

Industrial facilities such as chemical manufacturing and petroleum
refining facilities utilize industrial flares to control HAP emissions. 
Clean Air Act regulations require that flares used for control devices
must be operated under specific conditions including having a pilot
flame present, not producing smoke when operated and only combusting
gases with sufficient heat content.  In addition, facilities must use
good engineering control practices when operating equipment, including
following the manufacturer's design specifications.  Failure to follow
these requirements constitutes non-compliance. EPA has found that
facilities not meeting these operating requirements can release
significant levels of HAP emissions.  Ensuring compliance with
industrial flare requirements could significantly reduce the amount of
HAPs emitted from these facilities.

Surface Coating

Since 1990, EPA has promulgated 14 Maximum Achievable Control Technology
(MACT) standards for surface coating categories.  The surface coating
sector is comprised of many facilities that are engaged in the
application of coatings on various substrates including metals, paper,
wood, etc. The coatings are principally comprised of volatile organic
compounds (VOCs), many of which are HAPS.  During the coatings
application process, HAPs not captured or controlled to the degree
required by the MACT standards are emitted into the atmosphere,
adversely impacting the air quality and impairing the health of the
population both in the vicinity of the facilities and in some cases at
substantial distances from the facilities.  Some of these HAPS are
extremely toxic and are known or suspected carcinogens (e.g., methylene
chloride, formaldehyde, acetaldehyde, toluene diisocyanate).  

Why Are We Addressing the Problem?

Experience that EPA and State regulators have had with facilities in
this sector suggests that many of these facilities are currently out of
compliance with the MACT requirements due to lack of understanding of
the regulatory requirements, failure to adhere to the requirements, and
failure to operate and maintain control apparatus according to
manufacturers specifications.  Ensuring compliance with these surface
coating MACTs could significantly reduce the amount of HAPs emitted from
these facilities.   

Highlights from the FY 2005-2007 Planning Cycle

Since FY 2005, the EPA regional offices have conducted compliance
evaluations at sources subject to over 40 different MACT standards. 
These compliance evaluations and subsequent enforcement actions will
result in over one million pounds of HAP emission reductions by the end
of FY 2007.  The compliance monitoring and enforcement experience gained
across the MACT program over the last three years has been extremely
valuable and has contributed to EPA’s ability to narrow the focus of
the Air Toxics Strategy for the FY 2008-2010 planning cycle.  		

Final: Air Toxics Summary		09/24/07

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