On April 6th, 2023, the U.S. Environmental Protection Agency (EPA) introduced a proposal that outlined amendments to the New Source Performance Standards (NSPS) that apply to the Synthetic Organic Chemical Manufacturing Industry (SOCMI), including drafts of new regulations under 40 CFR 60, Subparts IIIa, NNNa, RRRa, and VVb. These new, stricter standards include process vent control for all columns/reactors, Refinery MACT flare requirements, changes to address startup, shutdown, and malfunction emissions, and valve leak thresholds of 100 ppm.
While these rules have not yet been finalized, any changes made to affected facility after the rule proposal date can trigger applicability, with compliance due shortly after the rules are finalized. Therefore, potentially subject facilities must now track all changes made to their chemical processes to ensure they do not trigger these new, stricter NSPS standards via new construction, modification, or reconstruction. A summary of rule triggers and how they may apply to your sources are as follows:
- Constructing a new source – The affected facility for NSPS IIIa, NNNa, and RRRa are often individual reactors or distillation columns, so installation of a new or replacement of an existing column or reactor could trigger these new standards. For NSPS VVa, the affected facility is the fugitive components within an entire process unit, so installation of a new process will trigger.
- Modifying an existing source – A modification is any physical change or change in the method of operation of an affected facility that results in increased hourly emissions. For columns and reactors, changes in products, optimization efforts, or replacement of vacuum systems, condensers, reboilers, or receivers could trigger applicability. For NSPS VVb, all fugitive component changes must be evaluated against the definition of capital expenditure to determine if a modification is triggered.
- Reconstructing an existing source – Reconstructions is triggered when changes to an affected facility are greater than 50% of the cost for a comparable new affected facility. For SOCMI NSPS, total costs of all projects started over a two-year period must be considered.
Next steps for training
Trinity will be hosting a new course on SOCMI NSPS compliance covering applicability triggers, existing standards, and the new rules proposed by US EPA. Click here to learn more and to register. If you have any further questions, please feel free to reach out to Inaas Darrat at [email protected].
