On May 16, 2024, the U.S. Environmental Protection Agency (EPA) finalized amendments to the New Source Performance Standards (NSPS) that apply to the Synthetic Organic Chemical Manufacturing Industry (SOCMI). This includes updates to existing regulations under 40 CFR 60, Subparts VV/VVa/III/NNN/RRR and issuance of new regulations under 40 CFR 60, Subparts VVb/IIIa/NNNa/RRRa. The SOCMI NSPS Standards were published in the Federal Register (89 FR 42932) and include an effective date of July 15, 2024, with the new regulations triggered by changes made after April 25, 2023. Here is a brief summary of the key changes:
NSPS Subparts VV, VVa, III, NNN, and RRR
- 40 CFR 60, Subparts VV/VVa (SOCMI Equipment Leaks)
- Amended VVa applicability such that it applies to sources constructed, modified, or reconstructed on or before April 25, 2023.
- Reverted back to the original NSPS VV/VVa definition of a “process unit” & removed references to the Legal Stay from the regulations.
- Removed connector monitoring provisions from NSPS VVa.
- Added electronic reporting requirements (CEDRI) for semi-annual compliance reports.
- Revised the definition of capital expenditure in NSPS VVa.
- 40 CFR 60, Subparts III, NNN, RRR (SOCMI Air Oxidation Reactors, Columns, Reactors)
- Amended applicability such that these subparts apply to sources constructed, modified, or reconstructed on or before April 25, 2023.
- Added overlap provisions for flares also subject to requirements in any other Part 60, 61, or 63 Rule.
- Added additional test methods for measuring TOC concentration.
- Added electronic reporting requirements (CEDRI) for performance tests and semi-annual compliance reports.
NSPS Subparts VVb, IIIa, NNNa, and RRRa
- 40 CFR 60, Subparts IIIa, NNNa, RRRa (SOCMI Air Oxidation Reactors, Columns, Reactors)
- Applies to sources constructed, modified, or reconstructed after April 25, 2023.
- The TRE concept is removed from the new standards – alternative descriptions of vents streams that require control are provided.
- Reduce emissions of TOC from all affected vent streams by 98% DRE or to 20 ppmvd.
- MACT CC Flaring Requirements.
- HON Maintenance Vent Option and HON Non-Regenerative Carbon Standard.
- Expanded control/recovery device monitoring provisions.
- Electronic reporting requirements for performance tests and semi-annual compliance reports.
- Note: These regulations do not allow for the use of 40 CFR 65, Subpart F (CAR) as an alternative compliance option and there are no overlap provisions with 40 CFR 63, Subparts F & G (HON).
- New 40 CFR 60, Subpart NSPS VVb
- Applies to sources constructed/modified/reconstructed after April 25, 2023.
- Includes overlap provisions with 40 CFR 63, Subpart H (HON) and 40 CFR 65, Subpart F (CAR).
- Gas/vapor & light liquid valves: quarterly monitoring, 100 ppmv leak definition.
- Connectors: annual monitoring, 500 ppmv leak definition.
- Skip periods for good performance for both valves and connectors.
- Electronic reporting requirements for performance tests and semi-annual compliance reports.
These changes will require chemical plants to rethink their SOCMI NSPS applicability and compliance strategy. To learn more about these changes and how they will impact your SOCMI NSPSsources in the future, Trinity is hosting a
webinar series to review all aspects of the final SOCMI NSPS 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].
