ENV-09-30 How will the EPA Proposed Monitoring Requirements for Leaks in Cooling Tower Return Lines from Heat Exchangers in Organic HAP Service Affect You?

Description:

The proposed rule requires monitoring for leaks in the cooling tower return lines from heat exchangers in organic HAP service. This is notable because it specifically requires Modified El Paso Method (MEPM) sampling. Other Federal rules include monitoring provisions for heat exchange system leaks, but none specifically use the MEPM prescribed in this rule. Although the MEPM has been used in Texas for many years, it has not been used in the same context as presented in the Refinery MACT 1 amendments. Therefore, this rule will have far reaching impacts associated not only with the new monitoring requirements and equipment, but with the rigorous recordkeeping and documentation required for heat exchange systems and may also affect other regulatory programs including air permitting, emission inventory reporting, and EPCRA and CERCLA release reporting. The implications of the proposed rule requirements and strategic considerations for implementation will be discussed and solutions will be outlined.