ENV-15-73 NSPS QQQ Capital Project Review Process

Description:

A New Source Performance Standards (NSPS) Subpart QQQ Capital Project Review is required when the following projects occur within a refinery: - Any capital project or process change which has the potential to change the configuration or affect any component of an existing individual drain system (IDS), oil/water separator (OWS), aggregate facility - Any capital project to construct a “new IDS”, OWS, aggregate facility, or component thereof. The Capital Project Review should be conducted early enough in the general Management of Change (MOC) environmental review process to identify any potential compliance issues resulting from NSPS QQQ impacts and allow sufficient time to address these problems before the equipment design is completed. This paper will explain the process and steps needed in order to complete this review when needed.