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Refinery MACT II Reminders (2/22/05)

The compliance deadline for EPA’s proposed Petroleum Refinery NESHAP, also known as the Refinery MACT II, is rapidly approaching. For most existing sources, the compliance deadline is April 11, 2005. However, the rule allows an additional 150-day grace period to conduct the initial compliance testing, which would extend the "drop-dead" compliance date to 9/8/05. At this time, sources must submit the Notification of Compliance Status as per 63.9(h)(2)(ii) of the general NESHAP provisions and Table 42 of Refinery MACT Rule. Affected sources should also be aware of other notification requirements and deadlines:

  • Sources that need to conduct performance testing for demonstrating initial compliance must submit notification at least 30 calendar days before the test is scheduled to begin.
  • For sources that are not required to conduct performance testing for demonstrating initial compliance, the notification of compliance status must be submitted no later than 30 calendar days following the initial compliance demonstration.
  • Sources must submit an operation, maintenance, and monitoring plan for each affected source, control system, and continuous monitoring system along with the Notification of Compliance Status.
  • Sources must develop and submit a Startup, Shutdown, and Malfunction (SSM) Plan along with the Notification of Compliance Status.

The first ongoing compliance report is due on July 31st if initial compliance occurs before June 30th or January 31st, 2005 if initial compliance is demonstrated after June 30th.

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RMB Consulting & Research, Inc.
Last Revised: February 22, 2005