SOCMI Chemical Rules - HON/P&R I/NSPS RTR Final Amendments

Environmental Consulting

April 24, 2024

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In March 2024, US EPA signed the final amendments to the following rules:

40 CFR 63 Subparts F, G and H (HON)
40 CFR 63 Subparts U and W (P&R MACT I and II)
40 CFR 60 Subparts VV, VVa, III, NNN, RRR (SOCMI NSPS)
40 CFR 60 Subparts VVb, IIIa, NNNa, RRRa (SOCMI NSPS)

These updates include significant changes to the SOCMI rules that include, but are not limited to the following:

Removal of Startup, Shutdown, Malfunction (SSM) provisions and updates to bypass provisions;
Updates to control determinations (removal of the TRE calculation, and more);
Fenceline monitoring for a select group of pollutants (ethylene oxide, chloroprene, benzene, 1,3 butadiene, vinyl chloride, ethylene dichloride);
Updated flare standards, including requirements for flare monitoring systems and management plans;
Ethylene oxide and chloroprene specific requirements;
Pressure Release monitoring and management requirements;
Maintenance venting and tank degassing standards;
Updated monitoring requirements (heat exchangers, non-regenerative carbon systems, and more);
Updates to overlap provisions and removal of certain exemptions; and
Tightened SOCMI NSPS provisions.

The timeline for compliance with the updated regulations is provided as follows:

HON
- New EO Provisions (includes flares and PRD under EO provisions) – 2 years after promulgation
- Fenceline Monitoring
  - Commence Fenecline monitoring in 2 years
  - Initial report after 12 months of data has been collected
  - Corrective Action Requirements Apply in 3 years
- All other provisions – 3 years after promulgation
NSPS
- IIIa/NNNa/RRRa/VVb standards apply upon promulgation for sources constructed/modified/reconstructed after April 25, 2023
- SOCMI NSPS apply promulgation

The pre-publication of the rules has been uploaded by US EPA. Trinity will be hosting a webinar series to review all aspects of the final amendments to the SOCMI rules. Please be sure to register here. If you have any questions or need help with your facility, please feel free to reach out to Inaas Darrat at [email protected].

I joined Trinity Consultants because I wanted to take my experience as an engineering student and apply it to a job that was people-oriented and allowed me to explore a wide range of industries. In my time at Trinity, I’ve had the opportunity to both work on a variety of projects and develop my own areas of expertise. As someone who was interested in air dispersion modeling early on, I’ve had the opportunity to grow my experience in that subject area without sacrificing opportunities to try new projects and work with great people. As a Senior Consultant, I now support clients in a variety of industries including data centers, surface coating, Portland cement, lime manufacturing, oil and gas, and more. My project work covers a broad range as well, including air dispersion modeling, routine compliance support, new construction permitting, and stack testing support.

Sam Najmolhoda

Senior Consultant