Reclassification of Major Sources as Area Sources

In 1995, the United States Environmental Protection Agency (US EPA) issued a memo known as the Once-in-Always-In (OIAI) policy that effectively made all major source designations permanent regardless of whether emission reductions lowered facility emissions of hazardous air pollutants (HAP) to less than major source thresholds. On January 25, 2018, the US EPA released another memo that ultimately reversed the OIAI policy to allow major source facilities to reclassify as area sources. This new memo became known as the Major MACT to Area (MM2A) policy memo.

Overview of Reporting Requirements - Major (MACT) and Area Sources of Hazardous Air Pollution

If your facility emits Hazardous Air Pollutants (HAP), you are a major or an area source of HAP.

Major Sources of HAPs (Maximum Achievable Control Technology (MACT)

Major sources are medium to large industrial facilities that emit 10 tons per year of any of a single HAP, or 25 tons per year of a combination of HAPs. These sources may release HAPs from equipment leaks, when materials are transferred from one location to another, or during discharge through emission stacks or vents.