Contributed by Jamie Godbold, Senior Project Manager, PPM Consultants
EPA has finalized a number of new rules which have the potential to significantly impact both ongoing and future operations. In some cases, additional or more efficient control devices might be required to comply with lower emission standards. You may also need to modify your current permits prior to construction, modification or operation of affected equipment. Understanding and evaluating your compliance options and deadlines is critical to developing an effective implementation strategy.
Amendments to the SOCMI NESHAP Rules
National Emission Standards for Hazardous Air Pollutants (NESHAP) rules applicable to the Synthetic Organic Chemical Manufacturing Industry (SOCMI) referred to commonly as the Hazardous Organic NESHAP, or HON, and the Group I & II Polymers and Resins Industry (P&R I and P&R II)…
- Were finalized on May 16, 2024 with an effective date of July 15, 2024
- Applies to existing flares, heat exchange systems, process vents, storage vessels, transfer racks, wastewater and equipment leaks at SOCMI facilities
- Requires fenceline monitoring for certain pollutants
- Removes various exemptions (e.g., periods of startup, shutdown, and malfunctions (SSM))
- Affects the following Subparts under 40 CFR Part 63:
- F: Synthetic Organic Chemical Manufacturing Industry (SOCMI)
- G: SOCMI for Process Vents, Storage Vessels, Transfer Operations, and Wastewater
- H: Equipment Leaks
- I: Certain Processes Subject to the Negotiated Regulation for Equipment Leaks
- U: Group I & II Polymers & Resins
- W: Epoxy Resins Production and Non-Nylon Polyamides Production
How PPM Can Help
As an Environmental Manager, you have a lot to deal with. Ensuring that ongoing operations remain in compliance and that future projects stay on track and under budget is a daunting task. Keeping up with proposed rules and their potential impacts is even more difficult. Because your time is limited, having a consultant who understands your needs and can simplify the complex world of environmental regulations is critical to your success and your company’s profits.
PPM personnel have experience with performing regulatory reviews, applicability determinations, gap analyses, Title V/NSR air permitting, and compliance evaluations. Regardless of your industry type or the complexity of your facility, PPM can assist you with evaluating your compliance options and in developing a strategy that is tailor-made to fit your needs. If you have any questions or would like to discuss specific needs, please give us a call.
PPM offers a broad range of environmental capabilities to business, industry, and government from a resource pool of more than 100 professionals in seven locations in the United States. We have earned our clients’ trust by delivering results and consistently exceeding their expectations. If you have any questions, please reach out to me at jamie.godbold@ppmco.com.