Chemical Manufacturing area sources, whether minor under Title V or for HAP, are coming under increased scrutiny from federal and state regulators. State regulators are increasingly focused on ensuring VOC and HAP emissions from all operations are identified, calculated, and given enforceable limits to ensure area source status, along with requiring detailed calculations to support both continuous and batch process vent emissions.
At the federal level, regulators continue to apply scrutiny to fugitive equipment leak emissions, where a leak detection and repair program is often required to maintain area source status. In addition to equipment leak fugitives, EPA inspections and 114 requests are ever more attentive to fugitive emissions from wastewater treatment plant emissions, even requiring facilities to conduct sampling to support existing analyses or to develop new emission calculations.
Broad range of scrutiny
US EPA has also started taking a hard look at applicability of area source NESHAPs (such as CMAS) and the SOCMI NSPS Standards (40 CFR 60, Subparts III/NNN/RRR/VVa), conducting detailed investigations and taking aggressive stances on SOCMI NSPS applicability. With new, more stringent SOCMI NSPS standards (Subparts IIIa/NNNa/RRRa/VVb) proposed in April 2023 and expected to be finalized in early 2024, even more scrutiny could be applied here, including for sources already subject to SOCMI NSPS standards. For the NESHAPs, updates to the Chemical Manufacturing Area Source rule (or CMAS, 40 CFR 63, Subpart 6V) are due in November 2024, applying more scrutiny to subject sites as EPA gathering data for the rule review and update. And while US EPA is making Benzene Waste Organic NESHAP (BWON) a bigger focus area for larger chemical plants, this extra attention may soon be seeping to area source inspections as well.
Training is available to help
Therefore, it is more important than ever for area sources to refocus and button up their air compliance programs. To help support this key industry segment, Trinity Consultants will be providing a new 1-day course on February 7, 2024, focusing on emission calculations and regulatory applicability for HAP area sources. The course will cover how to develop a site-wide emissions inventory, with a detailed look at quantifying fugitive equipment leaks and wastewater emissions.
In addition, we will cover applicability and compliance for key chemical manufacturing area source rules, provide recommendations for BWON compliance records, and discuss how RCRA area rules may overlap with other Part 60 standards. You can also check out its partner course covering SOCMI NSPS compliance here. If you have any further questions, please feel free to reach out to David Dempsey at [email protected].
