On March 12, 2020, the amendments to the 2002 Ethylene Production National Emission Standard for Hazardous Air Pollutants (NESHAP) were finalized by U.S. Environmental Protection Agency (EPA). This finalizes the residual risk and technology review (RTR) for Ethylene Plants. Existing facilities will have three years to comply with the updated provisions. The EPA, per the prepublication version of the Ethylene MACT (EMACT), is finalizing the following:
- Provisions and clarifications for periods of SSM and bypasses, including PRD releases, bypass lines on closed vent systems, in situ sampling systems, maintenance activities, and certain gaseous streams routed to a fuel gas system
- Revisions to the operating and monitoring requirements for flares used as air pollution control devices for EMACT
- Separate standard for storage vessel degassing for storage vessels subject to the control requirements
- Removal of certain exemptions for once-through heat exchange systems to comply with cooling water monitoring requirements
- Overlap provisions for leak detection and repair (LDAR) requirements at facilities subject to both 40 CFR 60, Subpart VVa and the EMACT
- Provisions for performance testing do not include the language that precludes startup and shutdown periods from being considered ''representative''
- Update to heat exchange system to requirements, including but not limited to, requiring the El Paso Method
- Submission of electronic copies of performance test results and reports, Periodic Reports, and Notification of Compliance Status (NOCS) reports
- Updates to the waste requirements
For additional details on the finalized changes, please feel free to click here to attend Trinity's complimentary webinar on April 28, 2020. If you are unable to attend the webinar live it will be posted on our On Demand webpage within one week of the live webinar.
If you have any questions, please contact your local Trinity office at (800) 229-6655.