On May 31, 2020, the U.S. Environmental Protection Agency (EPA) finalized amendments to the Miscellaneous Organic NESHAP (40 CFR 63, Subpart FFFF - the MON). Compliance deadlines for these changes will be three years after federal register publication for most new provisions, with the exception of LDAR related changes (60 days) and new ethylene oxide provisions (2 years).
Highlights of the key changes in the MON final amendments include:
- Replacement of current Startup, Shutdown, Malfunction (SSM) provisions with work practice standards for maintenance venting, tank degassing and pressure relief devices venting to atmosphere, with the obligation to “comply at all times;”
- Replacement of existing test requirements for Heat Exchange Systems with the Modified El Paso Method;
- Reduction in leak definition for pumps at existing batch processes from 10,000 to 1,000ppmv and clarifications to initial monitoring requirements for new and replaced components;
- New design standards, monitoring and operational requirements for flares controlling ethylene oxide, olefin and polyolefin sources (direct application of Refinery MACT CC Flare provisions);
- Clarifications and enhanced monitoring requirements for non-regenerative and regenerative absorbers and ground flares;
- Electronic Reporting to US EPA through CEDRI for all compliance related reporting within the MON; and
- Enhanced control, monitoring and operational requirements for process vents, storage tanks and equipment in ethylene oxide service.
The work practice standards for pressure relief devices venting to atmosphere, maintenance venting and storage tank degassing included in these amendments are entirely new program requirements and will extend MON compliance programs into areas historically excluded from the burden of proof associated with the NESHAP standards.
With careful planning, these new requirements can easily be integrated into existing site procedures without the need to create new add-on compliance programs to comply, especially for PSM and RMP regulated sites. Thoughtful enhancements to existing site programs for Process Hazard Analysis (PHA), Incident Investigation, Hot Work, Line Break and Vessel Entry Permit and Appendix C Isolation Procedures can be used to implement the new MON work practice requirements into existing industry-wide systems while minimizing the administrative burden and complexity of these new requirements on operations personnel.
For more information and to dive deeper into the details of the MON amendments, please watch our “ MON RTR Complimentary Webinar”.
Trinity's Chemical Sector Services (CSS) Group is well versed in helping chemical and refining industry personnel navigate their way through successful, streamlined implementation of regulatory requirements - from gap identification to capital planning, program development and implementation. If you would like assistance assessing the regulatory implications the MON amendments for your facility, please contact Trinity's CSS team at 713.552.1371, x 209.