June 7, 2023
8:45AM - 9:45AM
HON and SOCMI NSPS Proposed Revisions - Overview and What to Expect Next
Gary Daves, Sr. Regulatory Professional, TRICORD Consulting
With the U.S. EPA’s HON Risk and Technology Review (RTR) close to completion and the proposed revisions to the HON and other SOCMI air rules imminent, what does the future hold for the petrochemical sector air quality requirements? As a result of litigation by organizations including Texas Environmental Justice Advocacy Services and Louisiana Environmental Action Network, U.S. EPA is currently under a consent decree requirement to sign a rule package with proposed revisions to the HON and several other SOCMI rules in March 2023. Affected rules in the package include the HON and NSPS Subparts III, NNN, RRR, and VVa. This presentation will provide an overview of the proposed revisions and cover some of industry’s concerns with the proposed rules. For example, Startup, shutdown, and malfunction (SSM) exemptions will be eliminated as a result of a federal court decision several years ago. In other MACT rules that have had SSM exemptions removed, like the Refinery MACTs (Subparts CC and UUU) and the Ethylene MACT, EPA has added work practice standards to provide facilities compliance options during startup and shutdown periods. However, the HON affects a broader range of facility types than the Refinery MACT standards and Ethylene MACT, and environmental professionals from some SOCMI facilities have expressed concern that EPA’s stated focus on ethylene oxide and chloroprene could mean the proposed HON SSM revisions will not adequately address manufacturing processes for other chemicals. The presentation will also outline the proposed implementation schedules of the various HON and NSPS revisions and how facilities should prepare for the changes, including data collection. Additionally, lessons learned from facilities that have already implemented similar requirements for flare monitoring and operations, process vents, maintenance vents, heat exchange systems, and fence line monitoring will be shared.