Before enactment of the 1990 amendments to the CAA, many states developed programs for toxic air pollutants. Some states developed regulations that required new and modified sources of toxic air pollutants to minimize emissions by using T-BACT. These programs can be modified with EPA guidance from the 1990 amendments.


States with NAAQS exceedances have adopted and submitted SIPs to the EPA detailing how they plan to meet the NAAQS within a reasonable time. These SIPs require the installation of RACT for selected stationary sources. Regulating agencies determine RACT on a case-by-case basis within each industry, considering the technological and economic circumstances of the individual source. The EPA has issued a control techniques guideline (CTG) document to provide guidance on RACT for the control of volatile organic compound (VOC) emissions in nonat-tainment areas. The 1990 amendments require the EPA to issue CTGs within three years for eleven categories of stationary sources for which CTGs have not been issued.

—William C. Zegel lution activities. This survey showed that every state had an air toxics program. The approaches used by states varied but generally fell into three categories:

• Formal regulatory programs

• Comprehensive policies

• Informal programs

The approaches used by local agencies are as diverse as the state programs, but they can be categorized similarly.






Cadmium and its compounds

Chlorine and hydrogen chloride

Fluorine, hydrogen fluoride and silicon fluoride

Baking furnace and smelting furnace for manufacturing glass using cadmium sulfide or cadmium carbonate as raw materials.

Calcination furnace, sintering furnace, smelting furnace, converter and drying furnace for refining copper, lead, or cadmium.

Drying facility for manufacturing cadmium pigment or cadmium carbonate.

Chlorine quick cooling facility for manufacturing chlorinated ethylene.

Dissolving tank for manufacturing ferric chloride.

Reaction furnace for manufacturing activated carbon using zinc chloride.

Reaction facility and absorbing facility for manufacturing chemical products.

Waste incinerator (HCl)

Electrolytic furnace for smelting aluminium (harmful substances are emitted from discharge outlet).

Electrolytic furnace for smelting aluminum (harmful substances are emitted from top).

Baking furnace and smelting furnace for manufacturing glass using fluorite or sodium silicofluoride as raw material.

Reaction facility, concentrating facility, and smelting furnace for manufacturing phosphoric acid.

Condensing facility, absorbing facility, and distilling facility for manufacturing phosphoric acid.

Reaction facility, drying facility, and baking furnace for manufacturing sodium triple-phosphate.

Reaction furnace for manufacturing superphosphate of lime.

Baking furnace and open-hearth furnace for manufacturing phosphoric acid fertilizer.

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