Miscellaneous Organic Chemical Manufacturing
NESHAP (MON) Summary
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3. What Are the Testing and Initial Compliance Requirements?
Process Vents
 The
final rule requires calculation of uncontrolled emissions
as a first step in demonstrating compliance with the 98 percent
or 95 percent reduction requirement for batch process vents.
This initial calculation of uncontrolled emissions is not
required if the source chooses to control process vents using
the alternative standard or using specified combustion devices.
For continuous process vents, the final rule requires calculation
of the TRE index values using the procedures contained in
the HON for continuous process vents.
 To verify that the required reductions have been achieved,
you must either test or use calculation
methodologies, depending on the emission stream characteristics,
control device, and the type of process vent. For each continuous
process vent with a TRE less than or equal to 1.9, compliance
with the percent reduction emission limitation must be verified
through performance testing. For batch process vents, initial
compliance demonstrations must be conducted in accordance
with the requirements in the Pharmaceuticals
Production NESHAP (40 CFR part 63, subpart GGG). Specifically,
performance tests are required for control devices handling
greater than 9.1 Mg/yr (10 tpy) of HAP, while either engineering
assessments or performance tests are allowed for control
devices with lower loads and for condensers. Performance
tests must be conducted under worst-case conditions if the
control device is used to control emissions from batch process
vents.
Storage Tanks, Transfer Racks, and Wastewater
To demonstrate initial compliance with emission limits
and work practice standards for storage tanks, transfer
racks, and wastewater systems, the final rule allows you
to either conduct performance tests or document compliance
using engineering calculations. The initial compliance procedures
are specified in 40
CFR part 63, subpart SS (National Emission Standards
for Closed Vent Systems, Control Devices, Recovery Devices
and Routing to a Fuel Gas System or a Process), subpart
WW (National Emission Standards for Storage Vessels
(Tanks - Control Level 2)), and subpart
G (the HON), for control devices used to reduce
emissions from storage tanks and transfer racks, storage
tanks controlled with floating roofs, and wastewater sources,
respectively.
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