EPA Finalizing NESHAP MACT Standards Organic Liquid

68 FR ???? (Not Yet Published)

The EPA will soon publish the National Emission Standards for Hazardous Air Pollutants (NESHAP) rules for Organic Liquids Distribution (OLD), excluding gasoline. A preview of the final rule is located on the EPA’s Technology Transfer Network at http://www.epa.gov/ttn/oarpg/t3pfpr.html.

The source category involves distribution of organic liquids (non-gasoline) into, within, or out of a plant site. The OLD operations must be located at plant sites that are major sources of HAP emissions or are major sources themselves. Potential OLD sources include storage operations if not covered by another NESHAP and transfer operations into or out of tanks or transfers to cargo tanks, containers or pipelines. The rule has provisions for monitoring equipment leaks.

Excluded activities are R&D facilities, oil and natural gas production facilities that meet the source definition in 40 CFR Part 63, Subpart HH, and natural gas transmission and storage facilities that meet the source definition in 40 CFR Part 63, Subpart HHH.

A major HAP facility is one that emits or has the potential to emit 10 tons per year of any one HAP or 25 tons per year of a combination of HAPs. EPA has determined that the following HAPs may be emitted: benzene, ethyl benzene, toluene, vinyl chloride, and xylenes.

Organic liquids are defined in the rule as non-crude oil liquids that contain at least 5 % by weight of any of the 98 organic HAPs or HAP combinations listed in the rule and have a total liquid vapor pressure of 0.1 psia or greater. This definition does not include gasoline, fuels used or dispensed on-site, kerosene (No. 1 distillate oil), diesel (No. 2 distillate oil), asphalt, heavier distillate and fuel oils, hazardous waste, wastewater, and ballast water.

Controls will be required for storage tanks greater than or equal to 5,000 gallons in capacity, if the stored liquid is not crude oil, and if the annual average true vapor pressure of the total organic HAP of the liquid is >4 psia. Operators will be required to install closed vent systems and control devices that can meet a 95% control efficiency for the organic HAPs.

Sources can demonstrate that total organic compounds (TOC) is an appropriate surrogate for organic HAPs. As an alternative, sources can exhaust the tank emissions to a combustion control device that meets an exhaust level at the outlet of 20 ppmv of organic HAP. Compliance can also be achieved by capturing and routing emissions to a fuel gas system or a process located at the facility. Additionally, tank owners can meet a work practice standard (WPS) by use of an internal or external floating roof.

The rule will apply to transfer racks that process over 800,000 gallons of organic liquids per year. Operators will be required to install a closed vent system and control device to demonstrate a control efficiency of 98% for organic HAPs. TOC can be used as a surrogate for HAP if demonstrated. As an alternative, combustion control devices can meet a 20 ppmv outlet concentration limit (as TOC or HAP).

Sources must undertake a leak detection and repair program (LDAR) for pumps, valves and sampling connections that are in organic liquid service at least 300 hours per year. Sources may also be required to perform leak tightness testing on transport vehicles at affected transfer rack locations.

Sources will be required to establish capture and control system operating parameters during an initial performance test, a Startup, Shutdown, and Malfunction (SSM) Plan, and possibly a control device design evaluation.

Sources would be subject to initial notification requirements, notification of performance testing, notification of compliance status and periodic (semi-annual) reporting and several recordkeeping requirements.

For additional information, please contact Air/Compliance Consultants, Inc. at 412-826-3636.