Refinery MACT II (2/21/05)
EPA amended the Petroleum Refinery
NESHAP (a.k.a. "Refinery MACT II") on February
9, 2005 based on concerns of several refineries and
industry trade organizations. The amendments clarify rule
applicability and monitoring requirements for catalytic
cracking units (CCU), catalytic reforming units (CRU),
and sulfur recovery units (SRU) and provide new
compliance options for some CRUs. The following is a list
of the more significant changes to the rule:
- The detailed performance specifications for
continuous parameter monitoring systems (CPMS)
have been removed. CPMS systems must now be
installed, operated, and maintained in a manner
that is consistent with manufacturers
recommendations or other written procedures that
assure the equipment will monitor accurately.
- Facilities with affected CCUs that demonstrate
compliance with the NSPS PM standard may now
calculate volumetric flow rate from the
regenerator exhaust using gas analyzer CO2,
O2, and CO measurements, provided
these measurements are taken prior to the
addition of air or other gas streams.
- The exemption from organic HAP standards during
reactor purging for affected CRUs has been
clarified. Purging operations greater than 5 psi
are exempt if the uncontrolled emissions of total
organic carbon (TOC) or non-methane TOC are less
than 20 ppm, corrected to 3% O2.
- Affected CRUs with an internal scrubber may now
demonstrate compliance with an alternative HCl
percent reduction standard.
- New compliance options are available for CRUs
equipped with a gas-solid adsorption system.
The new amendments are open for public comment until
March 11, 2005 or by March 28, 2005 if a public hearing
is requested. If no adverse public comments are received,
the amendments will become effective April 11, 2005 (the
existing compliance deadline).
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Last Revised: February 22, 2005