Review of PVC NESHAP and MACT

In response to four petitions received for reconsideration, US EPA has provided notice that it will review the PVC NESHAP that was finalized in April 2012. The petitions identified notice and comment issues as well as several technical consistency issues with the rule.

The April 2012 final rule was issued in response to a 2008 settlement agreement with Sierra Club, MEAN, and LEAN to replace the vacated PVC MACT rule. This settlement did not include reconsideration of the existing 2007 PVC area source GACT rule. However, EPA decided to voluntarily review and revise the 2007 area source rule in conjunction with developing the major source MACT standard. Both industry and environmental petitioners have petitioned for reconsideration of the GACT analysis due to notice and comment.

EPA initiated this review in December 2012 and expects to publish a Notice of Proposed Rulemaking in November 2013.

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs.
For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website