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Miscellaneous Organic Chemical Manufacturing
NESHAP (MON) Summary


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4. What Are the Continuous Compliance Requirements?

Inspecting controlsThe 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.

IncineratorContinuous 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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