MACT II Reminders (2/22/05)
The compliance deadline for EPAs
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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Last Revised: February 22, 2005