Program Development Guide

This guide is intended to outline the implementation requirements of the Accidental Release Prevention Program under section 112(r) for Illinois effected sources that are Major by definition and require Clean Air Act Permit Program (CAAPP), or Title V permits under 40 CFR Part 70.

Approximately 15-20% of section 112(r) sources in Illinois are also subject to CAAPP permitting requirements. CAAPP requires facilities which routinely emit or have the potential to emit major amounts of criteria pollutants, such as sulfur dioxide, nitrogen dioxide and/or hazardous air pollutants, such as perchloroethylene, to obtain an operating permit for all emissions units on-site.

The Accidental Release Prevention Program under section 112(r) is, therefore, an applicable requirement for CAAPP sources if they use, store, handle, or manufacture any one of the regulated substances above its threshold quantity. A source must indicate whether or not it is subject to the section 112(r) rule in its CAAPP permit application. Illinois EPA has specific responsibilities with respect to section 112(r), including identifying those CAAPP sources which are subject to its requirements and ensuring compliance with the rule. Illinois EPA may use various mechanisms to accomplish this, such as completeness checks of risk management plan (RMP) summary, source audits, record reviews, and facility inspections.

It should be noted, however, that as new emission standards are promulgated by USEPA, sources not previously regulated under 40 CFR Part 70 may become CAAPP sources. For example, when the Publicly-Owned Treatment Works emission standard is finalized in 1998, some wastewater treatment plants will be required to obtain CAAPP permits.

This guide is not intended to provide a complete description of program components, but does include a brief review of section 112(r) requirements under the Clean Air Act Amendments (CAAA) of 1990 and the resulting rule language in 40 CFR Part 68. For more in depth coverage of the rule requirements, the reader is referred to current documents on the Technology Transfer Network (TTN) [(919) 541-5742, under the CAAA, Title III, Policy/Guidance sub-menu], or the Chemical Emergency Planning and Preparedness Office (CEPPO) hotline at 1-800-424-9346.