Refinery MACT II Compliance – Are We There Yet?
Refinery MACT II, 40 CFR Part 63 Subpart UUU, was published in Federal Register on April 12, 2002 by the U.S. Environmental Protection Agency (EPA). This rule, as a subpart of the National Emission Standards for Hazardous Air Pollutants (NESHAP), controls hazardous air pollutants from catalytic cracking units (CCU), catalytic reforming unit (CRU), sulfur recovery units (SRU), and bypass lines within these units at a petroleum refinery. Although most of the existing affected units have been regulated by other federal and state air pollution control programs such as New Source Performance Standards (NSPS) and State Implementation Plans (SIP) prior to this rule, there are many additional requirements that refineries must implement to comply with the new rule. Most refineries have made significant efforts to meet the compliance requirements for this rule. With the three-year compliance date quickly approaching, it is time for refineries to thoroughly review their requirements to ensure all critical actions can be completed prior to the regulatory deadlines. This paper provides a quick glance at the requirements with approaching deadlines and strategies to meet some of the critical requirements.