See the latest EHS federal and state regulatory updates due to COVID-19


On March 12, 2020, amendments to the 2004 National Emission Standards for Hazardous Air Pollutants (NESHAP) for Organic Liquids Distribution (Non-Gasoline) were finalized by the U.S. Environmental Protection Agency (EPA). 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:

  • Revisions have been made to requirements for periods of startup, shutdown, and malfunction (SSM), including removing an exemption for transfer operations during periods of planned, routine maintenance of a control device
  • Flares used as control devices will become subject to the flare provisions in Refinery MACT (Subpart CC), with some modifications
  • Storage tanks that meet the tank capacity and vapor pressure criteria for control will additionally be subject to control of degassing emissions
  • 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
  • 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
  • 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
  • Reports of deviations and flow events from bypass lines will require an estimate of emissions associated with such events
  • 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, register for Trinity's complimentary webinar on May 5, 2020. If you are unable to attend the webinar live, it will be posted on the CSS Webinar Channel within one week of the live webinar.