SCS Technical Bulletin: 2021, Update to NESHAP, 40 CFR 63 Subparts IIII, MMMM, PPPP, WWWW
The Clean Air Act Amendments of 1990 (the “Act”) requires the United States Environmental Protection Agency (EPA) to regulate hazardous air pollutants (HAPs), also known as air toxics, from industrial categories in two phases. This SCS Technical Bulletin summarizes 40 CFR 63 Subparts III, MMMM, PPPP, and WWWW. SCS makes recommendations for industrial clients to clarify a facility’s compliance position relevant to permit revision applications for Title V operating permits along with upcoming deadlines and the emission control requirements. A facility may still need to comply with SSM provisions, including an SSMP, but only as a state-mandated requirement and not at the federal level.
Please direct technical questions to Pat Sullivan or your SCS project manager.