August 1, 2014

Air Compliance during Start Up, Shutdown & Malfunction (SSM) Activities -There’s a Change in the Wind


On February 12, 2013, the U.S. Environmental Protection Agency (EPA) proposed a rule that would ensure states have plans in place that require industrial facilities across the country to follow air pollution rules during times when the facility is starting up or shutting down, or when a malfunction occurs. Air pollution emitted during these periods may adversely impact the health of people nearby and contribute to smog and other problems in communities that are further downwind.

To comply with standards set forth in the Clean Air Act of 1970, individual states were required to submit and gain approval to the EPA a State Implementation Plan (SIP).   In a recent review of the individual SIP’s, the Sierra Club had identified 39 states that had exemptions, vague or outdated language, very general plan conditions, or just didn’t have a requirement to count emissions during SSM activities.  Examples of SSM activities include roof landings, tank degassing and startup/shutdown of process units, or equipment malfunctions.  By allowing facilities to exceed their normal operating limits during SSM, industry has been allowed to emit certain hazardous substances such as NOX, SO2, PM 10’s, VOC’s, benzene, and others.  The practical effect of EPA's proposed rule, therefore, will be stricter emission limits for those sources that currently rely on a startup, shutdown or malfunction exemptions.

The Sierra Club sued and settled with the EPA by accepting that 36 states would be required to revise their SIP’s.  The general EPA guidance is due to be published May 5, 2015.  After their guidance is published, each of the designated states will have up to 18 months to not only revise their SIP, but be in 80% compliance by the end of the 18 month period.

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