ENV-06-165 Implementation of MACT Rulemakings

Description:

The Site Remediation Maximum Achievable Control Technology (MACT) requires major sources of hazardous air pollutants (HAP) to manage air emissions from both long-term (e.g., ground water) and short-term (e.g., spill clean-ups) remediation. Like the benzene waste National Emission Standards for Hazardous Air Pollutants (NESHAP), this MACT requires refinery waste staff to learn about air rules, and the air staff to learn about remediation and waste management operations. Understanding the potential for incomplete implementation typical of a “cross-over” rule, Valero Energy Corporation (Valero) retained the services of Environmental Resources Management (ERM) to develop a systematic method for assessing the applicability and compliance status of Site Remediation MACT at each its 16 U.S. refineries of prior to the October 9, 2006 compliance date. By using a standardized, detailed applicability assessment, numerous compliance issues were identified that require interaction between refinery remediation, waste, and air permitting staff at a level previously thought unnecessary. The standardized approach to the applicability assessment provided Valero with information about how various refineries are complying with Site Remediation MACT. This information was shared among the refineries to develop and implement effective compliance strategies prior to the compliance date.