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Complying with MACT standards may seem complicated, but it becomes easier to understand when you break it down to its individual components.
In order to comply with MACT standards, you have three options that you can take at your facility.
A combination of these 3 options can be used to stay in compliance, but this must be considered as part of emissions limits based on a 12-month rolling average.
This is true in all cases except when an add-on control device is used. In this case, compliance is determined through emissions testing.
The MACT model point value is a figure that is used as a substitute for emission levels for each MACT standard. They only apply to MACT standards and cannot be used in the calculation of any other emission factors.
The value is used as a way of ranking the performance of different techniques that reduce HAPs emissions. Using this option to show MACT compliance allows for you to take different approaches in choosing your reduction techniques.
Each MACT standard (or NESHAP) provides you with the equations to calculate the MACT model point value. It is based on the HAP content of the material and the application method that you're using.
The values for each approach are then averaged and compared to the limits that are given in the MACT standard documentation. This allows you to see if your operations are in compliance.
The equations used in calculating the MACT model point values only account for the HAP content and the application method used to apply the material. These two factors are seen as easy to determine. Other factors that play a role in emissions (such as part thickness, operator technique, curing time etc.) are much harder to determine and are not accounted for in the equations.
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