ENV-03-106 Permitting Startup and Shutdown Emissions from Petrochemical Facilities – Policy and Practice

Description:

Regulatory authorities and major sources have long acknowledged that startup and shutdown activities are inherent to plant operations, however, permitting of emissions from these activities has recently begun to receive increased scrutiny as part of the Title V permitting process. Failure to include startup and shutdown emissions in a permit could lead to significant notifications of non-compliance and potential enforcement actions. Although there is much at stake, there is no established formal mechanism for permitting startup and shutdown emissions. The EPA issued a policy in 1999 regarding excess emissions during startups, shutdowns, and malfunctions. This policy represents EPA’s position with regard to State Implementation Plans and enforcement; however, it does not provide clear guidance on permitting of these emissions. In the absence of guidance from EPA, Louisiana developed draft policy to specifically address permitting of startup and shutdown emissions. Louisiana’s draft policy defines the type and magnitude of emissions that may be permitted and provides guidance on how to include them in a Part 70 permit.