NESHAP amendments proposed for manufacturers
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January 10, 2014
NESHAP amendments proposed for manufacturers

Following Clean Air Act (CAA) residual risk and technology reviews (RTRs), the EPA is proposing amendments to National Emissions Standards for Hazardous Air Pollutants (NESHAP) affecting three source categories—acrylic and modacrylic fibers production (AMF), amino/phenolic resins production (APR), and polycarbonate production (PC).  The biggest impact of the proposed amendments would be experienced by the 18 APR facilities subject to NESHAP.  Four PC facilities and one AMF facility are also affected. 

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The existing NESHAPs for the three source categories were issued in 1999 and 2000.  The CAA directs the EPA to review NESHAPs every 8 years to determine if amendments are in order (1) to ensure that the emissions standards protect the public health with an ample margin of safety (the residual risk review); and (2) to ensure that NESHAP is up to date with practices, processes, and control technologies that have occurred since the standards were promulgated (the technology review). 

Technology amendments

For all three source categories, the Agency’s residual risk review determined that NESHAPs did not require amendments.  However, the technology review has resulted in proposed amendments for the source categories as follows:

  • AMF.  The proposal would eliminate the less stringent of two currently available options for complying with leak detection and repair program requirements; the more stringent compliance requirement would be retained.  In addition, the proposal would establish an emissions limit for existing sources for certain fiber spinning lines that were not previously regulated. 
  • APR.  The EPA is proposing to establish emissions standards for storage vessels and continuous process vents for existing sources.
  • PC.  The proposal would eliminate the less stringent of two currently available options for complying with leak detection and repair program requirements; the more stringent compliance requirement would be retained.  

Four parts of the proposal would also affect each source category:

  • Revisions to ensure that the standards apply at all times, including during periods of start-up, shutdown, and malfunction (SSM);
  • Required electronic reporting of performance test results;
  • Clarification of open-ended lines by adding a definition for what constitutes a sealed, open-ended line; and
  • Required monitoring of pressure relief devices (PRDs) in organic hazardous air pollutant (HAP) service, which release to the atmosphere; also addition of a provision indicating that a pressure release from a PRD in organic HAP service, unless routed to a control device or process, is a violation of the emissions standard.

Deadlines

The proposed amendments would require facilities to comply:

  • Immediately with the storage vessel, spinning line, and SSM revisions;
  • No later than 1 year after promulgation with the equipment leak revisions; and
  • No later than 3 years after promulgation with the continuous process vent and pressure relief device monitoring revisions.

The proposal was published in the January 9, 2014, FR.

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