NESHAP Articles
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The Reality and Implications of SSM and NESHAPs
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, ...
By All4 Inc.
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`Facing the New Emission Standards for Hydrochloric Acid Pickling,` presented at the SUR
Introduction Under the 1990 Clean Air Act Amendments (CAAA), U.S. EPA is required to regulate sources of hazardous air pollutants (HAPs). Primarily, HAP emissions are regulated through National Emission Standards for Hazardous Air Pollutants (NESHAPs), which are codified under Title 40 Code of Federal Regulations (CFR) Part 63. NESHAPs address HAP emissions from a particular process, such as ...
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Affirmative Defense is Vacated for the Cement Industry
I wrote a blog back in February that was intended to raise the awareness level of the cement industry regarding new requirements for their MACT operations and maintenance (O&M) plans. As part of addressing action items related to that blog, many owners/operators that are affected by 40 CFR Part 63, Subpart LLL – National Emission Standards for Hazardous Air Pollutants (NESHAP) From the ...
By All4 Inc.
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A new approach to SSM emissions management
On October 16, 2009, the United States Court of Appeals for the District of Columbia Circuit (DC Circuit) mandated the vacatur of the “Startup, Shutdown, and Malfunction (SSM) exemption” allowed under General Provisions in Subpart A of the National Emission Standards for Hazardous Air Pollutants (NESHAP).1 Under the SSM exemption, NESHAP Subpart A previously stipulated that an ...
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MACT Monitoring, Recordkeeping, and Reporting - The Hidden Requirements
ABSTRACT The maximum achievable control technology (MACT) standards established under the national emission standards for hazardous air pollutants (NESHAPs) of 40 CFR 63 may include easily overlooked, sometimes onerous and questionably appropriate requirements incorporated by reference to the MACT General Provisions of 40 CFR 63, Subpart A. These requirements are easily overlooked during the ...
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NESHAP SSM exemption Vacatur mandated by the DC circuit
The National Emission Standards for Hazardous Air Pollutants (NESHAP), codified in 40 Code of Federal Regulations (CFR) Part 63, set emission standards and monitoring, recordkeeping, and reporting requirements for specific source categories that emit HAPs. NESHAP Subpart A, the General Provisions, includes general requirements for NESHAP subject facilities, including provisions for startup, ...
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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 ...
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Major Source Boiler MACT Compliance with Oxygen Trim Systems
The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters promulgated at 40 CFR Part 63, Subpart DDDDD, commonly referred to as the Major Source Boiler MACT (MSBM) standards, provide multiple continuous compliance options that require monitoring. Among these options is the use of a continuous ...
By All4 Inc.
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Standing on the MACT Floor
ABSTRACT Three MACT standards have impacted manufacturing operations at the Boeing Philadelphia site. These standards apply to Aerospace Manufacturing and Rework, Halogenated Solvent Cleaning, and Chromium Anodizing. In order to meet the requirements imposed by the standards, qualifications programs were established and conducted by the Materials and Process Engineering group to approve ...
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New requirements finalized in RICE NESHAP
EPA finalized portions of the National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines (RICE NESHAP). The rule was promulgated into the existing RICE standards located in 40 CFR Part 63, Subpart ZZZZ on March 3, 2010. The newly incorporated standards were originally proposed on February 25, 2009 and apply only to stationary RICE. The proposed ...
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New requirements finalized in RICE NESHAP
On February 17, 2010, EPA finalized portions of the National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines (RICE NESHAP). The rule was promulgated into the existing RICE standards located in 40 CFR Part 63, Subpart ZZZZ on March 3, 2010. The newly incorporated standards were originally proposed on February 25, 2009 and apply only to stationary RICE. ...
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`Utilizing Compliance Management Solutions to Implement an Effective SSM plan,` published in Chemical Engineering Progress, August 2002
Section 112(d) of the Clean Air Act, as amended in 1990, mandates EPA to regulate HazardousAir Pollutants (HAPs) for a variety of source categories. The intent of these regulations is torequire affected major sources to apply the Maximum Achievable Control Technology (MACT)as a method for minimizing HAP emissions.1 These MACT standards are also known as NationalEmission Standard for Hazardous Air ...
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Petro-chemical processor meets national emission standards for hazardous air pollutants
A multitude of chemical and petroleum processing facilities across the country are now faced with having to meet new National Emission Standards for Miscellaneous Organic Chemical Manufacturing. One specific NESHAP is 40 CFR part 63, subpart FFFF. The applicability of meeting this NESHAP is: A facility must be a major source of HAP emissions Process units that: Produce organic chemicals that are ...
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Cellulosic biofuels meets national emission standards for hazardous air pollutants - Case study
Cellulosic Biofuels meets National Emission Standards for Hazardous Air Pollutants A multitude of new cellulosic bio-fuel processing facilities across the country are now faced with having to meet new National Emission Standards for Miscellaneous Organic Chemical Manufacturing. One specific NESHAP is 40 CFR part 63, subpart FFFF. The applicability of meeting this NESHAP is: A facility must be a ...
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Cement Manufacturing - Balancing Growth with Air Quality Requirements
In most areas of the U.S., it appears that the recession is a bad memory and the signs of recovery are all around us. As described by the Portland Cement Association (PCA) on its website[1], “following the strongest cement consumption gains in seven (7) years in 2012, cement consumption growth will continue in 2013 with a 6.2% increase.” PCA continues to explain that “the ...
By All4 Inc.
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December 2005 - Regulatory Update
The Onyx Environmental Services - Environmental, Health, Safety, and Transportation department is pleased to present the Monthly Regulatory Update. The update contains a brief summary of the proposed and final rules from EPA, OSHA, and DOT published in the Federal Register in the past calendar month. If you have any questions, comments, or suggestions regarding the Monthly Regulatory Updates, ...
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Petro-Chemical Processor meets National Emission Standards for Hazardous Air Pollutants - Case study
A multitude of chemical and petroleum processing facilities across the country are now faced with having to meet new National Emission Standards for Miscellaneous Organic Chemical Manufacturing. One specific NESHAP is 40 CFR part 63, subpart FFFF. A facility must be a major source of HAP emissions Process units that: Produce organic chemicals that are not subject to other MACT standards ...
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`A Case Study in Implementation of the NESHAPs for the Portland Cement Industry at a Major Source,` appeared in Cement Americas magazine, July/August 2003
Introduction Located at 40 CFR 63, Subpart LLL, the Portland Cement (PC) MACT standard poses a significant regulatory hurdle to the cement industry-Facilities subject to its requirements had to complete initial performance testing and develop their first substantial semi-annual monitoring report by January 31, 2003. The final Portland Cement MACT rule was promulgated on June 14, 1999, and ...
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Inspection Manual: Federal Equipment Leak Regulations for the Chemical Manufacturing Industry
Untitled Document Abstract The purpose of this manual is to enhance an inspector's ability to conduct more complete and effective inspections at facilities in the chemical industry that are subject to Federal equipment leak regulations. Equipment leak standards are designed to reduce or eliminate emissions of volatile organic compounds (VOCs), volatile hazardous air pollutants ...
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Case study - ETO sterilizer abatement
OVERVIEW Product sterilization companies are generally required to utilize a pollution control device for treatment of exhaust gases from their aeration room and sterilization chambers. In the United States, they need to be in compliance with NESHAP (National Emission Standards for Hazardous Air Pollutants) regulations that dictate a 99% destruction efficiency of EtO (Ethylene Oxide), or ...
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