1. MON @ New Orleans / ACC / SOCMA November 2003 Randy McDonald, OAR, USEPA

2. Outline Status of NESHAP Status of NESHAP General applicability General applicability General requirements General requirements MACT standards MACT standards Notifications, reports, and records Notifications, reports, and records

3. Status 40 CFR Part 63 Subpart FFFF 40 CFR Part 63 Subpart FFFF NESHAP for Miscellaneous Organic Chemical Manufacturing NESHAP for Miscellaneous Organic Chemical Manufacturing Publication date - ? Publication date - ? Technical corrections/rule amendments Technical corrections/rule amendments

4. Layout of Rule Applicability Applicability General requirements - reference (with exceptions) to subpart SS General requirements - reference (with exceptions) to subpart SS MACT standards MACT standards Alternative standards Alternative standards Reporting and recordkeeping Reporting and recordkeeping

5. Applicability - Who’s Out Minor Sources Minor Sources Inorganic chemical manufacturers Inorganic chemical manufacturers Affected sources covered by other MACT Affected sources covered by other MACT Research and development facilities Research and development facilities End use operations End use operations Fabrication Fabrication Spinning Spinning Molding Molding Forming Forming

6. Applicability – Who’s In Major sources Major sources MCPU process, use, or produce organic HAP, HCl, HF, or Cl2 MCPU process, use, or produce organic HAP, HCl, HF, or Cl2

7. MCPU Processing equipment, including storage tanks and loading racks, operated to produce NAICS 325 organic chemical Processing equipment, including storage tanks and loading racks, operated to produce NAICS 325 organic chemical Chemical may be family of materials Chemical may be family of materials Chemical may be isolated intermediate Chemical may be isolated intermediate CMPU that has batch vents CMPU that has batch vents

8. Isolated intermediate Product of a process that’s stored Product of a process that’s stored Marks the end of a process, i.e., MCPU Marks the end of a process, i.e., MCPU Storage reflects long term, not batch cycle Storage reflects long term, not batch cycle Examples Examples Stored intermediate is used onsite and shipped offsite Stored intermediate is used onsite and shipped offsite Stored intermediate feeds two different processes Stored intermediate feeds two different processes

9. Family of Materials Product is a grouping of similar material Product is a grouping of similar material Near identical HAP emission profiles Near identical HAP emission profiles Near identical manufacturing equipment Near identical manufacturing equipment Advantages Advantages Reduced reporting and recordkeeping Reduced reporting and recordkeeping Consistency with Title V permit Consistency with Title V permit Less operating scenarios Less operating scenarios Possible P2 option Possible P2 option

10. Affected Source Existing Existing Facility-wide collection of MCPU, heat exchange system, and wastewater system Facility-wide collection of MCPU, heat exchange system, and wastewater system New New New or reconstructed facility-wide operations New or reconstructed dedicated MCPU with PTE of 10/25 tons

11. Example #1 –Affected Source If An affected source adds new equipment to existing MCPU Then New source standards do not apply if new equipment does not constitute reconstruction of dedicated MCPU or facility-wide source

12. Example #2 – Affected Source If An affected source adds new equipment to create new MCPU Then New source standards do not apply if no reconstruction of facility-wide source or construction of dedicated 10/25 ton MCPU

13. Example #3 – Affected Source If If Major source adds new equipment and begins producing MON chemical for the first time at the facility Major source adds new equipment and begins producing MON chemical for the first time at the facilityThen Facility becomes a new affected source. Any process changes and additions are also subject to new source standards

14. Primary Product Nondedicated equipment Nondedicated equipment Single process unit group (PUG) per §63.2435(e) Single process unit group (PUG) per §63.2435(e) Option for subparts GGG, MMM, and FFFF Option for subparts GGG, MMM, and FFFF

15. Overlapping rules MON as alternative compliance MON as alternative compliance Tanks - 40 CFR part 60 subparts Kb and Y Tanks - 40 CFR part 60 subparts Kb and Y Vents – subparts DDD, III, NNN, and RRR Vents – subparts DDD, III, NNN, and RRR Racks – part 61 subpart BB Racks – part 61 subpart BB Equipment leaks Equipment leaks part 60 subpart VV part 60 subpart VV part 61 subpart V part 61 subpart V Wastewater Wastewater part 63 subparts GGG and MMM part 63 subparts GGG and MMM part 61 subpart FF part 61 subpart FF

16. Process Unit Group Identify equipment associated with at least one nondedicated MCPU Identify equipment associated with at least one nondedicated MCPU Add other nondedicated process unit with common equipment Add other nondedicated process unit with common equipment Determine primary product for 5 year period and comply with subpart GGG, MMM, or FFFF Determine primary product for 5 year period and comply with subpart GGG, MMM, or FFFF Adding process units allowed Adding process units allowed Redetermine primary product every 5 years Redetermine primary product every 5 years

17. PUG and Overlapping Standards

18. No shared processing equipment – no PUG No shared processing equipment – no PUG May comply with FFFF for wastewater May comply with FFFF for wastewater

19. General Standards Compliance requirements - subpart SS Compliance requirements - subpart SS §63.982 (b) for closed vent with flare §63.982 (b) for closed vent with flare §63.982 (c) for closed vent with control §63.982 (c) for closed vent with control §63.982 (d) for fuel gas system (tanks and racks) §63.982 (d) for fuel gas system (tanks and racks) §63.982 (e) for recovery device (continuous vents) §63.982 (e) for recovery device (continuous vents) §63.994 for halogen reduction device §63.994 for halogen reduction device

20. Review of subpart SS Standardized standards Standardized standards Closed vent systems Closed vent systems Control devices – flare and nonflare Control devices – flare and nonflare Recovery devices Recovery devices Routing to fuel gas system or process Routing to fuel gas system or process Process vents Process vents Storage tanks Storage tanks Transfer racks Transfer racks Equipment leaks Equipment leaks

21. Subpart SS Closed vent system requirements Closed vent system requirements Bypass monitoring Bypass monitoring Inspections Inspections Flare requirements Flare requirements Incinerators, boilers, and process heaters Incinerators, boilers, and process heaters Performance tests Performance tests Monitoring requirements Monitoring requirements

22. Subpart SS Absorbers, condensers, carbon adsorbers Absorbers, condensers, carbon adsorbers used as control devices used as control devices used as recovery devices used as recovery devices Performance tests Performance tests Monitoring requirements Monitoring requirements Halogen scrubbers Halogen scrubbers Testing Testing Monitoring Monitoring General performance test requirements General performance test requirements Recordkeeping Recordkeeping

23. General Standards Determine halogenated vent per §63.115 Determine halogenated vent per §63.115 Combined emission streams Combined emission streams Use design evaluation from subpart GGG for small control devices Use design evaluation from subpart GGG for small control devices Supplemental gases defined in MON Supplemental gases defined in MON

24. General Standards No excused excursions No excused excursions No percent reduction compliance demonstration with TOC No percent reduction compliance demonstration with TOC No flare control for halogenated vents, HCl, HF, or Cl2 No flare control for halogenated vents, HCl, HF, or Cl2 Use Table 4 for surge control vessels and bottom receivers Use Table 4 for surge control vessels and bottom receivers

25. Standards for Continuous Vents Table 1 for Group 1 vents Table 1 for Group 1 vents 98 percent reduction or 20 ppmv 98 percent reduction or 20 ppmv Flare (or boiler per subpart SS) Flare (or boiler per subpart SS) Recovery to TRE of 1.9 Recovery to TRE of 1.9 Reduce halogens after combustion by 99 percent, to 20 ppmv, or 0.45 kg/hr Reduce halogens after combustion by 99 percent, to 20 ppmv, or 0.45 kg/hr Reduce halogen atoms before combustion to 20 ppmv or 0.45 kg/hr Reduce halogen atoms before combustion to 20 ppmv or 0.45 kg/hr Use §63.982(e) if using recovery device Use §63.982(e) if using recovery device

26. Standards for Batch Vents Table 2 for Group 1 vents Table 2 for Group 1 vents Reduce total HAP from sum of vents by 98% Reduce total HAP from sum of vents by 98% Reduce total HAP from sum of vents by 95% with recovery device Reduce total HAP from sum of vents by 95% with recovery device Reduce HAP from any individual vent with flare or to 20 ppmv Reduce HAP from any individual vent with flare or to 20 ppmv Reduce halogen from halogenated vent before or after combustion device Reduce halogen from halogenated vent before or after combustion device

27. Batch Vents Determine group status Determine group status No emission estimates required w/ alternative standard or control device operated at hypothetical worst case No emission estimates required w/ alternative standard or control device operated at hypothetical worst case Exceptions to subpart SS Exceptions to subpart SS Process condensers not control devices Process condensers not control devices Initial compliance under worst-case conditions Initial compliance under worst-case conditions Daily or block averaging allowed Daily or block averaging allowed Periodic verification for devices < 1 tpy Periodic verification for devices < 1 tpy Correction for supplemental gases Correction for supplemental gases

28. Hydrogen Halide and Halogen HAP Table 3 Table 3 Reduction by 99% for vents from affected process (sum of vents > 1,000 lb/yr) Reduction by 99% for vents from affected process (sum of vents > 1,000 lb/yr) Reduction to 20 ppmv Reduction to 20 ppmv Comply with §63.994 Comply with §63.994 Design evaluation allowed for any size device Design evaluation allowed for any size device Caustic strength may be monitored Caustic strength may be monitored

29. Standards for Storage Tanks Table 4 for Group 1 tanks Table 4 for Group 1 tanks Comply with 40 CFR part 63 subpart WW Comply with 40 CFR part 63 subpart WW Comply with subpart SS requirements for process vents Comply with subpart SS requirements for process vents Reduce halogen from halogenated vent before or after combustion device Reduce halogen from halogenated vent before or after combustion device Use vapor balancing alternative from subpart GGG Use vapor balancing alternative from subpart GGG

30. Standards for Transfer Racks and Equipment Leaks Table 5 for Group 1 racks Table 5 for Group 1 racks Table 6 for eq. lks. Table 6 for eq. lks. Comply with subpart TT for batch only MCPU Comply with subpart TT for batch only MCPU Pressure testing allowed Pressure testing allowed Flexible hoses not considered in reconfiguration Flexible hoses not considered in reconfiguration

31. Standards for Wastewater Table 7 for Group 1 wastewater streams Table 7 for Group 1 wastewater streams 10,000 ppmw total HAP (>50 ppmw Table 8) 10,000 ppmw total HAP (>50 ppmw Table 8) 1,000 ppmw total HAP at 1 liter per minute 1,000 ppmw total HAP at 1 liter per minute 30,000 ppmw Table 9 (<50 ppmw Table 8) 30,000 ppmw Table 9 (<50 ppmw Table 8) Planned routine maintenance – 240 hours for wastewater tanks Planned routine maintenance – 240 hours for wastewater tanks Offsite management and treatment Offsite management and treatment RCRA treatment needs no certification RCRA treatment needs no certification Table 9 HAP streams to offsite treatment Table 9 HAP streams to offsite treatment

32. Compliance Alternatives Pollution prevention Pollution prevention Emissions averaging Emissions averaging 20/50 ppmv outlet standard 20/50 ppmv outlet standard

33. Notifications and Reports Initial notification Initial notification Notification of performance test Notification of performance test Precompliance report Precompliance report NOC status report NOC status report Compliance reports Compliance reports

34. Records As required by referenced subparts As required by referenced subparts Operating scenario Operating scenario Group 2 batch vent emissions Group 2 batch vent emissions PUG documentation PUG documentation

35. Questions?