MACT Updates May Require Real-Time Results Disclosure

  

Meeting MACT Head On

Under the Clean Air Act (CAA), the EPA regulates toxic air emissions called hazardous air pollutants (HAPs). There are currently 188 chemicals on the HAPs list, which are known or suspected to cause cancer or other serious health effects or adverse environmental effects. Through a two-phased approach, the EPA regulates toxic air emissions from fixed industrial sources, such as petroleum refineries. The first step is developing technologically based standards for controlling these toxic emissions from an industrial group, referred to as the source category. Under this phase, the EPA determines the maximum achievable control technology (MACT) standards. Within eight years, the EPA must complete the second phase using a risk-based approach called the risk and technology review (RTR). In the second phase, the EPA can revise emissions standards and update the MACT.

What Is MACT?

Maximum achievable control technology, or MACT, is air pollution technology that's already in use by the lowest emitting sources for the industry. For oil refineries, pressure relief devices (PRDs) and the associated use of flares are the primary regulatory focus. In addition to technology to reduce the frequency of PRD use and flaring, oil refineries must monitor the PRDs and establish preventative measures for HAPs directly released into the atmosphere. Facilities must conduct root cause investigations for release events and then implement corrective actions. Reports of release events and corrective action are required semi-annually. The second phase includes the EPA assessing any remaining health risks from the industrial source. This must occur within eight years of MACT standards approval. It's a review of the MACT standards and an analysis of new technologies. During this risk-based phase, the EPA determines if additional health-protective standards are required. The EPA will also look at across-the-fence considerations, such as environmental justice.

Air Pollution Limits Are Under Review for Petroleum Refineries Soon

For petroleum refineries, the EPA issued the updated MACT rule in 2015, but delayed implementation until 2020 because of appeals. Many refineries are near residential areas, and these rules are intended to reduce the impact on those communities specifically and for general air pollution improvements. One of the current requirements is continuous monitoring of benzene at the fence line for all wind directions. Despite the delays in implementing the current MACT, the EPA must continue the evaluation of potential adverse public health impacts within eight years. Additional air pollution controls and prevention requirements could be around the corner.

Getting Ahead of Changes

The Biden Administration is pushing to implement aggressive air emissions rules, especially related to climate change. While the current push is for power plant emissions, it's likely that any industrial sector with an open window for air emissions evaluations will get similar treatment. The MACT rules for petroleum refineries are nearing the end of the eight-year review period to consider additional health-protective standards. As part of the MACT rule review, the EPA assesses current practices versus what is achievable with more current technology applied. Facilities need to understand and anticipate future regulatory requirements for air quality monitoring. The residential areas around many petroleum refineries include disproportionately affected populations. To reduce impacts, the EPA could require additional monitoring and pollution reduction requirements within the next few years. Under the CAA's Toxic Release Inventory (TRI) program, communities have had some information about releases from facilities, but under the current MACT, more information is available. When cancer risk and petroleum refinery emissions have been linked together, the adjacent community has easier access to the refinery's emission records than ever before. New rules may increase access to include real-time fence line sensor data. Aegex Technologies has products available with technology to detect and monitor leaks through the NexVu intrinsically safe IoT sensors. Contact Aegex to discuss our digital solutions to meet MACT requirements head-on.