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Supplement I Presentation of Kevin A. Cavender U.S. Environmental Protection Agency Emissions Standards Division Status of the Friction Haterial MACT(Maximum Achievable Control Technology)Standard Presented June 4, 2000, at the FMSI Annual Meeting Key Largo, Florida
FMSI-0503
FMSI 01252
Status ofthe Friction Material MACT Standard
&
Presented at the Annual Meeting? of the FMSI
' Junem2000
Kevin A. Cavender USEPA/ESD
cavender. kevinQepa.gov
Outline
Overview of EPA's MACT Program Friction materials project hietory Preliminary Finding#1 , Project Schedule * Questions angAnswers
Overview of EPA's MACT Program
Authorized by Section 112 of the 1990 CAA Designed to reduce emissions of Hazardous Air
Pollutants (HAP) Applies to Major Sources of HAP
e 10 tpy of anysingle HAP, or 25 tpy of any combination of HAP Technology based standards
Definition of MACT
Stands for Maximum Achievable Control
Technology
Must meet minimum level of control
Average of best 12% sources
* Average of best S when fewer than 30 sources
MACT for newsources based onthe best controlled similar source
e Referred to as the MACT Floor
EPA can set MACT beyond the Floor
*
Anatomy of a MACT Standard
Found in 40 CFR Part 63
Emission limits
,
Monitoring requirements
Recordkeeping and reporting requirements
General provisions (40 CFR 63 Subpait A)
Friction Materials Project History
Originally listed as Asbestos Processing (June 16.1992)
EPA delisted Asbestoi Processing (Nov. 30.1995)
EPA added Friction Materials Manufacturing to the source category due to organic HAP emissions (June 4,1996)
Industry survey (ICR) sent out in Nov. 1997
Preliminary Findings Affected Sources
Standard WILL apply to 22 major sources that manufacture friction material using conventional wet or dry resin technology
Standard WILL NOT apply to facilities that qnty rebuild or assemble friction products ' facilities that manufacture friction material using the carbonization process
Preliminary Findings Affected Sources
The following emission sources will be covered by
the.ruls
_
Solvent bated mixell
Curing and post back ovens
Saturators
Preliminary Findings Affected Sources
The following emission sources will not be covered in the Friction matedaleMACT
Halogenated solventclegreasing operations
(covered by 40 CFR 63 Subpart T)
Metal parts coming operations (covered by 40 CFR 63 Subpart MMMM)
Machining operations (minimal HAP emissions)
Asbestos emissions covered by 40 CFR 61
Subpart M
'
Preliminary Findings MACTFIoor
Solvent recovery systems are identified as the MACT Floor technologies for solvent based mixers
Thermal oxidizers are identified as the MACT Floor technology for
' Curing and post back ovens
e Saturators
;
Project Schedule
Proposed rule 5/2001 Promulgated rule 5/2p02 e Compliance date vMllHikely be between 2-3 years
after promulgation
Questions And Answers