Three NESHAPs amended
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April 07, 2014
Three NESHAPs amended

Following residual risk and technology reviews (RTRs) of three National Emissions Standards for Hazardous Air Pollutants (NESHAPs), the EPA has concluded that no changes to those standards are needed as a result of the reviews.  Apart from the RTRs, the Agency is amending each of the NESHAPs in four areas. 

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Areas addressed by the amendments include start-up, shutdown, and malfunction (SSM); electronic reporting; pressure relief valves; and contact cooling towers.

The Clean Air Act requires that the Agency conduct RTRs of NESHAPs no less frequently than every 8 years to determine if the standards are adequately protective of public health and if amendments should be made based on new technologies.  One of the NESHAPs covered by the rule was issued in 1996; the other two were issued in 1999. 

72 facilities

EPA’s action addresses the NESHAPs for group IV polymers and resins; pesticide active ingredient production; and polyether polyols production.  The Agency’s breakdown of the sources by production activity and the estimated number of affected facilities is as follows:

  • Group IV polymers and resins (P&R IV; 31 active facilities):
    • Acrylonitrile-butadiene-styrene resin (ABS) production
    • Methyl methacrylate-acrylonitrile-butadiene-styrene resin (MABS) production (no active facilities)
    • Methyl methacrylate-butadiene-styrene resin (MBS) production
    • Nitrile resin production (no active facilities)
    • Polyethylene terephthalate resin (PET) production
    • Polystyrene resin production
    • Styrene-acrylonitrile resin (SAN) production
  • Pesticide active ingredient production (18 active facilities)
  • Polyether polyols production (23 active facilities)


For each of the three NESHAPs, the amendments:

  • Eliminate exemptions from emissions standards during periods of SSM; the emissions standards in each rule apply at all times.  This action is consistent with vacatur by the U.S. Court of Appeals for the D.C. Circuit of similar provisions in other rules.
  • Require electronic reporting of performance test results.
  • Require monitoring of pressure relief devices (PRDs) in organic HAP service that release to the atmosphere.


With regard to the P&R IV NESHAP, amendments apply in three additional areas:

  • Requirements are issued for previously unregulated HAP emissions from equipment leaks and process contact cooling towers (PCCTs) in the PET continuous terephthalic acid (TPA) high-viscosity multiple end finisher subcategory, which has one facility currently in operation.
  • Alternative compliance demonstration methods are allowed during periods of start-up and shutdown.  Specifically, facilities may demonstrate compliance by either: (1) keeping records that establish that the raw material feed rate and production rate were both zero; (2) meeting the limit by dividing the emissions rate during start-up or shutdown by the rate of polymer produced from the most recent performance test associated with a production rate greater than zero; or (3) keeping records that establish that the operating parameters of the control device used to comply with the rule were maintained at the level established to meet the emissions limit at maximum representative operating conditions.
  • Lifting a stay, which was issued by rule in February 2001, that applied to requirements for PCCTs at existing sources producing PET using the continuous TPA high- viscosity multiple end finisher process.

The amendments were published in the March 27, 2014, FR.

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