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On March 12, 2020, amendments to the 2004 National Emission Standards for Hazardous Air Pollutants (NESHAP) for Organic Liquids Distribution (Non-Gasoline) (OLD) were finalized by the U.S. EPA. The OLD Maximum Achievable Control Technology (MACT) standard (40 CFR 63 Subpart EEEE) applies to sites with OLD operations (sites that store and distribute organic liquids other than gasoline) that are major sources of HAP. Operations and equipment at terminals, crude oil pipeline stations, refineries, and various manufacturing facilities subject to OLD MACT requirements include storage tanks, transfer racks, equipment leaks, and loading and unloading of transport vehicles and containers.

The EPA is finalizing the results of its residual risk and technology review (RTR), as required by the Clean Air Act (CAA), as well as additional amendments to enhance the effectiveness of the rule. Existing facilities will have three years to comply with the updated provisions, with some exceptions. The EPA, per the prepublication version is finalizing the following:

  • Storage tank control of degassing: Storage tanks that meet the tank capacity and vapor pressure criteria for control will additionally be subject to control of degassing emissions
  • Storage tank control thresholds: The vapor pressure thresholds triggering control requirements for storage tanks have been lowered for certain capacity ranges, but up to ten years is allowed to upgrade floating-roof storage tanks that become subject to control due to the lower thresholds
  • Startup, shutdown, and malfunction (SSM): Revisions have been made to requirements for periods of SSM, including removing an exemption for transfer operations during periods of planned, routine maintenance of a control device
  • Flares: Flares used as control devices will become subject to the flare provisions in Refinery MACT (Subpart CC), with some modifications
  • CEMS performance specifications: Provisions have been added specifying performance specification requirements for CEMS, augmenting the quality control requirements for CEMS, and specifying how CEMS data must be reduced
  • Test methods: Changes have been made to the test methods acceptable for use in conducting performance testing as well as for determining the true vapor pressure and HAP content of the organic liquid
  • Deviation and flow event emission estimates: Reports of deviations and flow events from bypass lines will require an estimate of emissions associated with such events
  • Electronic submittal of reports: Performance test results and reports, Periodic Reports, and Notification of Compliance Status (NOCS) reports will be required to be submitted electronically

For additional details on the finalized changes, you can register through the following link to view the recording of Trinity's complimentary webinar on the OLD MACT revisions or you can contact Brian Burdorf at 972.661.8100, or any of Trinity's terminal industry experts.