Don't get lost in the “alphabet soup” of Part 63 NESHAP Subparts A to ******* (up to 7 letters with 125 subparts and counting)!
With the 1990 amendments to the Clean Air Act (CAA), EPA mandated significant new air quality programs including an expanded list of 189 hazardous air pollutants (HAP) [Section 112(b)] and a list of source categories for which new NESHAP regulations for both major and area sources of HAP must be developed [Section 112(c) and (d)]1. Emissions standards for major sources are established on the basis of Maximum Achievable Control Technology (MACT) with differing requirements for new and existing sources. A less stringent emissions standard basis, known as Generally Available Control Technology (GACT) standards, is allowed for area sources. The Part 63 NESHAP designated source categories typically represent an industrial source classification (e.g., Synthetic Organic Chemical Manufacturing Industry in Subparts F, G, and H) but can also represent an emission source type (e.g., Industrial, Commercial, and Institutional Boilers and Process Heaters in Subpart DDDDD or “Boiler MACT”).
After the initial round of technology-based emissions standards are established, EPA is required to perform an additional round of NESHAP rulemaking to assess any remaining risk to public health. If "residual risk" (determined through an air dispersion modeling-based human health risk assessment) for a source category is found, EPA issues revised health-based emissions standards for that source category to further reduce HAP emissions. Every eight years thereafter, EPA must revisit the NESHAP standard to determine if any developments in technology or human health risk require updates to the regulations.
Prompted by the plain writing initiative for all U.S. government agencies, EPA organizes Part 63 NESHAP following a question and answer (Q&A) format intended to be more approachable for the public. While this format may represent an improvement to previous regulatory schemes, Part 63 NESHAP require specialized experience and skills to decrypt EPA's not so plain language intended for a “layman.” Whether your facility has triggered a Part 63 NESHAP for the first time or you have been complying with the same regulation since the 1990's, Trinity has you covered with a full range of NESHAP compliance support services.
Am I subject to this subpart? - NESHAP Applicability Determination Support
Determining the boundaries of the NESHAP affected source at your facility is not always straightforward and can require interpretations of process details, regulatory definitions, and industry precedent. Trinity maintains an extensive library of technical and regulatory resources to ensure your affected source determinations take full advantage of all possible exemptions and alternative means of compliance. Empowered with the right applicability determinations supplied by Trinity, you can be sure the costs and resources for your Part 63 NESHAP compliance program are being spent wisely and consistent with the regulations.
What limitations/work practice standards must I meet? - NESHAP Program Development Support
Part 63 NESHAPs often contain multiple compliance options with differing emissions standards, operating limits, and work practice standards. Choosing the right option for your source can minimize future compliance risk and minimize the costs/labor resources for demonstrating compliance. Trinity understands the advantages and disadvantages of many NESHAP compliance approaches and can provide strategic guidance for your site in choosing the best option.
What are my initial/ongoing compliance requirements? - NESHAP Program Implementation Support
Demonstrating initial compliance under the Part 63 NESHAP regulations often involves the preparation and submittal of a comprehensive Notice of Compliance Status Report (NOCSR) demonstrating that your source not only can comply with the applicable emissions standards but also has met all of the associated testing, monitoring, recordkeeping, and reporting requirements along the path of initial compliance. Since the inception of the Part 63 NESHAP program, Trinity has developed hundreds of NOCSRs across many NESHAP source categories, so we are uniquely positioned to support your facility in preparing high quality initial compliance reports.
Demonstrating ongoing compliance under the Part 63 NESHAP covers a wide range of monitoring activities from the most stringent continuous emissions monitoring systems (CEMS) and continuous parametric monitoring systems (CPMS) to the least stringent annual (or less frequent) visual inspections. Trinity knows the engineering fundamentals, practical applications, and regulatory implications of many common emissions or parametric monitoring systems that can be leveraged for your facility . Trinity can also develop inspection programs that satisfy all regulatory requirements and are built on solid personnel workflows and documentation platforms. Work with Trinity to develop and implement a successful NESHAP compliance monitoring program, including the appropriate regulatory plans and documentation, that maximizes the opportunity for consistent and sustainable compliance.
What records must I keep? What notifications/reports must I submit and when? - NESHAP Recordkeeping and Reporting System Support
Timely, well-organized, and clearly documented records are the cornerstone of any NESHAP compliance program. Whether your facility relies on paper forms, user-entered electronic databases, or mobile/cloud-enabled solutions, Trinity can help enhance and streamline your NESHAP recordkeeping systems to ensure optimum performance.
Periodic NESHAP reports can span volumes of regulatory citations, compliance statements, and supporting documentation. Responsible parties for preparing or contributing to these reports must initiate work weeks in advance of the regulatory deadline and still experience “crunch time” right up to the due date. Partnering with Trinity on a NESHAP reporting project will remove a significant resource burden on your staff and instill confidence that regulatory requirements are being met.
With more than four decades of experience in air regulations and permitting, Trinity can be of great value in helping you interpret EPA's Part 63 NESHAP rulemaking information and determine effective Part 63 NESHAP compliance solutions for your operations. For assistance, contact Trinity at (800) 229-6655.1Major sources of HAP are those with source-wide annual potential emissions exceeding 10 tons per year (tpy) of an individual HAP or 25 tpy of total HAP. An area source is a facility with HAP emissions below the major source threshold (also referred to as a minor source under other air programs).