Original Date: 09/14/1998
Revision Date: 01/18/2007
Best Practice : Synthetic Minor Approach to Title III Clean Air Compliance
Raytheon Missile Systems Company (RMSC) performed a cost-benefit analysis to determine whether the company should voluntarily limit its hazardous air pollutant (HAP) emissions to avoid costly regulatory requirements, or pursue a restrictive, less production-focused method available under the major source status. The company opted for the Synthetic Minor approach, and agreed to voluntarily restrict its emissions below the threshold for the major source status. This approach allows the company to avoid prescriptive and intrusive requirements imposed under that category.
The company’s incentive for pursuing the Synthetic Minor status for HAP was to avoid the National Emission Standard for Hazardous Air Pollutants’ (NESHAP’s) requirements, and to reach the maximum achievable control technology legislated for the aerospace industry. These regulations restrict a facility to a maximum of 25 tons of HAPs per year, which narrowly qualified RMSC’s facility. The additional levels of compliance, capital costs for abatement equipment, and elevated need for comprehensive record keeping made the Synthetic Minor approach more attractive to the company.
The NESHAP standard is unique because once a facility commits to these requirements by choosing the major source status, there is no opportunity to alter that decision. This stringent regulation is binding regardless of whether the initial criteria used to determine a facility’s status are still applicable in the future. In addition, the NESHAP standard addresses all sources of HAP emissions, regardless of whether they are production related.
The Synthetic Minor approach enables RMSC to validate its low levels of pollutants via reports to show the facility’s chemical usage and emissions. The company also had to enhance its existing database system via capital expenditures to specifically track all HAP fuels and chemicals issued and stored at the facility. However, the costs incurred through the Synthetic Minor approach were much less than if the company had chosen the major source status. Additional benefits include a near real-time snapshot of HAP containing materials on-site, and a consistent source of valuable information for prioritizing P2 opportunities and evaluating the effectiveness of implemented P2 projects.
For more information see the
Point of Contact for this survey.