Regulatory Background
Title III of the 1990 Clean Air Act Amendments (CAAA) required the Environmental Protection Agency (EPA) to establish Maximum Achievable Control Technology (MACT) standards for major and area sources of Hazardous Air Pollutants (HAPs); many of these standards directly impact the organic chemical manufacturing industry. MACT standards for many chemicals were first established under the Hazardous Organic NESHAP (HON) in 1994. Since then, the EPA has focused its efforts on regulating HAP emissions from various other industry source categories. Major sources that did not “fit” into a defined source category are regulated by a “catch all” category for “miscellaneous organic” sources known as MON (40 CFR Part 63 Subpart FFFF).
The MON was first proposed in the Federal Register on April 4, 2002 and initially included both Subpart FFFF for miscellaneous organic chemical manufacturing and Subpart HHHHH for miscellaneous coating manufacturing. Following a Public Hearing and significant comments by manufacturers and chemical industry trade associations the EPA revised the proposed rule and published a final MON rule for chemicals on November 10, 2003. Manufacturers subject to the rule must be in compliance by November 10, 2006.
Facilities are initiating their MON compliance efforts by assessing the applicability of MON to their site-specific process units and associated operations. The requirements of Subpart FFFF are applicable to miscellaneous organic chemical manufacturing process units (MCPUs) that are located at, or are a part of, a major source of HAP emissions, and if the MCPU uses or produces HAP and is not part of an affected source under another MACT. For the MON rule, applicable organic chemicals include:
1. An organic chemical or chemicals classified using the 1987 version of SIC Code 282, 283, 284, 285, 286, 287, 289, or 386, with certain exceptions;
2. An organic chemical or chemicals classified using the 1997 version of NAICS Code 325, with certain exceptions;
3. Quaternary ammonium compounds and ammonium sulfate produced with caprolactam;
4. Hydrazine; and
5. Organic solvents classified in any of the covered SIC or NAICS codes recovered using nondedicated solvent recovery devices.
Note that batch vents in units previously exempted by Subpart F (HON) are now covered by Subpart FFFF.
The requirements in Subpart FFFF do not apply to:
1. Research and development facilities, as defined in section 112(c)(7) of the CAAA;
2. Any MCPU that manufactures ammonium sulfate as a byproduct, under certain restrictions;
3. “Affiliated operations” at Subpart GG, KK, JJJJ, MMMM, and SSSS affected facilities (Includes: Mixing or dissolving of coating ingredients, Coating mixing for viscosity adjustment, Color tint or additive blending, Adjustment of pH, Cleaning of coating lines and coating line parts, Handling and storage of coatings and solvent, and Conveyance and treatment of wastewater);
4. Fabricating operations such as spinning a polymer into its end use; and
5. Tall oil recovery systems.
Subject facilities are developing long-range compliance strategies to document exemptions, identify and select the most efficient and cost effective compliance strategies for their specific process units and operations, and budget for compliance and capital expenditures. Compliance strategy development includes assessing the use of “family of materials” groupings, identifying miscellaneous organic chemical processing units (MCPU), data collection for process vent emissions and wastewater, developing Group 1 / Group 2 designations, and numerous other activities. A summary of compliance standards for existing and new or reconstructed facilities is provided in the table below. Please note that there are numerous compliance options available and not all are listed.
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Chemical
Manufacturing Subpart FFFF |
For Existing Facilities |
For New and Reconstructed Facilities |
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1.
Process Vents - Continuous [See Table 1 of FFFF] |
Either reduce OHAP by ≥ 98%, closed vent system to a flare, ≤ 20 ppmv outlet1, or maintain TRE2 > 1.9. | Either reduce OHAP by ≥ 98%, closed-vent system to a flare, ≤ 20 ppmv outlet2, or maintain TRE2 > 5.0. |
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2.
Process Vents - Batch [See Table 2 of FFFF] |
For total batch vent emissions ≥ 10,000 lb/yr, reduce OHAP by ≥ 98%, or ≤ 20 ppmv outlet1. Alternatively, reduce OHAP by ≥ 95% using recovery devices. | For total batch vent emissions ≥ 3,000 lb/yr, reduce OHAP by ≥ 98%, or ≤ 20 ppmv outlet1. Alternatively, reduce OHAP by ≥ 95% using recovery devices. |
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3. Process Vents -
Hydrogen Halida (HF/HCI) and Halogen (Cl2)
HAPs [See Table 3 of FFFF] |
For total process uncontrolled halogen halide and halogen HAP emissions ≥ 1,000 lb/yr, reduce by ≥ 99% or ≤ 20 ppmv outlet for combustion and non-combustion streams. | For total batch vent emissions ≥ 1,000 lb/yr of Hydrogen Halide and Halogen HAP, reduce HAP by ≥ 99% or ≤ 20 ppmv outlet for combustion and non-combustion streams. |
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4.
Process Vents - Particulate Matter HAPs [See Table 3 of FFFF] |
No control required. | For total batch vent emissions ≥ 400 lb/yr Particulate Matter, reduce PM HAP by ≥ 97% by weight. |
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5.
Storage Tanks [See Table 4 of FFFF] |
Reduce HAP emissions ≥95% or to ≤ 20 ppmv of TOC or OHAP or IFR/EFR3 (≥ 1 0,000 gal and ≥ 1.0 psia). | Reduce HAP emissions ≥ 95% or to ≤ 20 ppmv of TOC or OHAP or IFR/EFR3 (≥ 10,000 gal and ≥ 1.0 psia). |
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6.
Transfer Racks [See Table 5 of FFFF] |
Reduce OHAP emissions ≥ 98%1 or to ≤ 20 ppmv for facilities that transfer > 0.17 million gallons per year and ≥ 1.5 psia. | Reduce OHAP emissions ≥ 98%1 or to ≤ 20 ppmv for facilities that transfer > 0.17 million gallons per year and ≥ 1.5 psia. |
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7.
Leak Detection Program [See Table 6 of FFFF] |
Full leak detection program with monitoring for all MCPU4 associated systems. Batch processes must comply with Subpart TT or Subpart UU. Continuous processes must comply with either Subpart H (CAR) or Subpart UU. An MCPU with at least one continuous process vent (even if the process is otherwise batch) must comply with Subpart UU. | Full leak detection program with monitoring for all MCPU4 associated systems. All processes much comply with Subpart H (CAR) or Subpart UU. |
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8.
Wastewater Treatment [See Table 7 of FFFF] |
Control if ≥ 50 ppmw Table 8 and ≥ 10,000 ppmw Tables 8 and 9, or ≥ 1,000 ppmw Tables 8 and 9 and flowrate of ≥ 1 lpm, or ≥ 30,000 ppmw Table 9 and > 1 TPY. Develop and implement Maintenance WW plan, cleaning fluids are considered process fluids. Vapor suppression and route to closed-vent system with ≥ 95% removal. | Control of very volatile OHAP if ≥ 10 ppww and ≥ 50 ppmw Table 8 and ≥ 10,000 ppmw Tables 8 and 9, or ≥ 1,000 ppmw Tables and 9 and flowrate of ≥ 1 lpm, or ≥ 4,500 ppmw Table 9 and ≥ 1 TPY. Vapor suppression and route to closed-vent system with ≥ 95% removal. |
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1 If using
a halogen reduction device after a combustion
control device, reduce halogens by a 99% or to
≤ 0.45 kg/hr or to ≤ 20 ppmv. If using a
halogen reduction device before a combustion
control device, reduce halogens to ≤ 45 kg/hr or ≤ 20
ppmv.
2 TRE = Total Resource Effectiveness 3 Internal Floating Root/External Floating Root (IFR/EFR) 4 Miscellaneous Organic Chemical Manufacturing Process Unit |
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About Dixon Environmental
Dixon Environmental (www.dixonenvironmental.com) provides permitting and environmental compliance, engineering, and data management services to chemical, pharmaceutical, and industrial manufacturers. Dixon Environmental specializes in MACT compliance for batch and continuous chemical manufacturing facilities, and was contracted by both the American Chemistry Council and SOCMA to provide technical consultation on the MON rule. Dixon Environmental is currently working with SOCMA to develop the MON Resource Center, an internet based MON compliance assistance tool.
