The Reality and Implications of SSM and NESHAPs

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Courtesy of All4 Inc.

In this edition of ALL4's 4 The Record newsletter, The Reality and Implications of SSM and NESHAPs, Roy R., Eric S., and Mark W. discuss the recent changes to the National Emission Standards for Hazardous Air Pollutants (NESHAP) rule and how that applies to facilities.  The article takes you through what NESHAPs means for compliance during operational periods outside of normal operations, especially focusing on periods of startup, shutdown, and malfunction.

ALL4’s project experience often involves industrial clients that are subject to  one (1) or more of the National Emission Standards for Hazardous Air Pollutants (NESHAPs) for source categories (40 CFR Part 63). NESHAPs regulate  emissions of hazardous air pollutants (HAPs) either directly or through the use  of a surrogate pollutant (e.g., carbon monoxide in lieu of regulating a vast  number of organic HAPs that can be emitted from a combustion process). NESHAP-affected  facilities must comply with a given numerical emission standard for the HAPs regulated by the  applicable Part 63 subpart – no surprise there. However, determining the applicability of the  numerical limits during atypical operating modes has been a complicated issue since the  inception of NESHAP standards in the early 1990s. In this article, ALL4 looks at how the  NESHAPs have presented an ever-evolving challenge that has raised serious questions about  the compliance obligations of an affected facility. Specifically, this article addresses not what  applies during “normal” operations, because that is typically well understood and black or  white. Rather, we address what recent changes to the NESHAPs mean for compliance during  operational periods outside of normal operations, namely periods of startup, shutdown, and  malfunction (SSM).

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