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Miscellaneous Organic Chemical Manufacturing
NESHAP (MON) Summary
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4. What Are the Continuous Compliance Requirements?
The
final rule requires monitoring, inspections, and calculations
to demonstrate ongoing compliance. Typically, continuous monitoring
(i.e., every 15 minutes) of emissions or operating parameters
is required when using a control device or wastewater treatment
device. If operating parameters are monitored, operating limits
must be established during the initial compliance demonstration.
Periodic inspections are required for emission suppression
equipment on waste management units and floating roofs on
storage tanks and wastewater tanks. For processes that have
Group 2 batch process vents (i.e., total organic HAP emissions
less than 10,000 lb/yr), you must track the number of batches
produced to show that emissions remain below the Group 1 threshold.
Continuous monitoring requirements for control devices are specified in 40
CFR part 63, subpart SS, with some exceptions specified in the final rule.
For example, the final rule requires
that monitoring data during periods of startup,
shutdown, and malfunction (SSM) [PDF] be used in daily averages, whereas
subpart SS excludes such data from averages. For batch process vents, you may
request approval to set operating limits for individual or groups of emission
episodes using the results of the performance test and applicable supplementary
information. To use this approach, you must provide rationale for your selected
operating limits in your precompliance report. As an alternative to daily averaging,
the final rule also allows averaging over a batch or segment of a batch for control
devices used to reduce emissions from batch process vents. For control devices
that do not control more than 1 tpy of HAP emissions, only a daily verification
that the control device is operating as designed is required.
Inspections for floating roofs must be conducted in accordance with 40
CFR part 63, subpart WW. All monitoring and inspection requirements for wastewater
systems must be conducted in accordance with 40
CFR part 63, subpart G.
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