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Title: An alternate compliance strategy for Title III regulations

The EPA is attempting to incorporate pollution prevention into the Title III regulations and an example of their efforts is evident in the Hazardous Organic NESHAP (HON) rule. The HON rule includes provisions that partially encourage pollution prevention, but compliance for most facilities relies on implementation of reference control technologies (RCT). This paper proposes an Alternative Control Strategy (ACS) for the HON rule that incorporates pollution prevention and flexibility, while encouraging innovative technology. The ACS is defined by converting existing language in the HON rule into a performance based standard permitting regulated facilities to design compliance programs to meet the required hazardous air pollutant (HAP) emission reduction. The ACS meets all emission reduction and other requirements of the HON rule. The ACS was applied to an example facility and assessed using three evaluation methods. The ACS program reduced risk to the local community to a greater extent than the comparable RCT compliance program at a comparable total cost. The ACS concept is applicable to similar Title III and many other regulations, and provides a major step in the progression of moving regulations from the traditional end-of-pipe treatment philosophy to pollution prevention performance based standards. 5 refs., 3 tabs.
Authors:
 [1]
  1. Air Force, Kirtland AFB, NM (United States)
Publication Date:
OSTI Identifier:
621343
Report Number(s):
CONF-960273--
TRN: 98:002183-0003
Resource Type:
Conference
Resource Relation:
Conference: Air and Waste Management Association (AWMA) specialty conference on emerging solutions to VOC and air toxics control, Clearwater Beach, FL (United States), 28 Feb - 1 Mar 1996; Other Information: PBD: 1996; Related Information: Is Part Of Emerging solutions to VOC and air toxics control; PB: 457 p.
Publisher:
Air & Waste Management Association, Pittsburgh, PA (United States)
Country of Publication:
United States
Language:
English
Subject:
54 ENVIRONMENTAL SCIENCES; 29 ENERGY PLANNING AND POLICY; US EPA; POLLUTION REGULATIONS; AIR POLLUTION ABATEMENT; COMPLIANCE; HAZARDOUS MATERIALS; ORGANIC COMPOUNDS