The final Refinery Sector Rule (RSR) was published in the Federal Register on December 1, 2015 and became effective on February 1, 2016. The RSR amended 40 Code of Federal Regulations (CFR) 63, Subpart CC (Refinery MACT I), and Subpart UUU (Refinery MACT II). The final rule establishes new and stringent emission controls, work practice standards, fenceline monitoring, and changes in monitoring requirements for several pollutants for several units covered under Refinery MACT I and Refinery MACT II. The EPA has established several deadlines for compliance with the new requirements some of which are coming up. Is your refinery prepared to meet the upcoming deadlines associated with the RSR?
- August 1, 2017 – Deadline for new maintenance vent SSM process/procedure implementation: Refinery MACT I no longer exempts from the definition of Miscellaneous Process Vents (MPVs) those vents used only for startup, shutdown, maintenance (SSM), or inspection of equipment. Instead the work practice standards are now required if these vents are classified as Maintenance Vents. The EPA developed new requirements for maintenance vents to follow during SSM of process equipment. These requirements go beyond what you may already be doing to satisfy Texas MSS permit requirements. Are you comfortable that you can comply with the new work practice standards for maintenance vents? Compliance with these standards is required on or before August 1, 2017.
- August 1, 2017 – Deadline for Continuous Parametric Monitoring Systems New Requirements and for Additional Performance Testing: Under Refinery MACT II, among several changes, the EPA newly requires facilities to follow prescribed accuracy and calibration requirements for all Continuous Parametric Monitoring Systems (CPMS). The rule also requires a performance test to be conducted on each FCCU for compliance with Particulate Matter (PM) and Hydrogen Cyanide (HCN) emissions on or before August 1, 2017. Has your facility already conducted or scheduled these tests?
- January 30, 2018 – Deadline to begin initial fenceline monitoring for benzene: Under Refinery MACT I, the EPA newly requires refineries to monitor benzene concentrations along fencelines. The initial fenceline monitoring must begin on or before January 30, 2018. Have you started a pilot program to identify any potential hot spots? If you think you'll need a site specific monitoring plan for compliance, one needs to be submitted to EPA as soon as possible to allow time for review and approval.
Trinity has developed RSR Implementation Guidelines and RSR compliance gap analyses for several major refineries in Texas and across the nation. We work closely with facilities in developing a status check on the implementation of the new programs for RSR compliance and identifying potential gaps. If you need to evaluate your site's readiness for any of the above requirements, or other RSR requirements, Trinity Consultants would be happy to assist.
Additionally, Trinity is holding a Complimentary Roundtable Discussion on August 10, 2017 in Houston, Texas. This roundtable will be used to provide a platform to discuss the issues and ambiguities faced by the industry in implementing the requirements of the rules, and a discussion on the path forward for future planning strategies for upcoming implementation deadlines. For more information on how Trinity can assist your RSR compliance efforts, please contact your local Trinity office by calling (800) 229-6655.