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ENV-16-18 Industry Challenges Dealing with the EPA Ethylene MACT RTR

Amy Marshall, AECOM

Format:
Electronic (digital download/no shipping)

Associate Member, International Member, Petrochemical Member, Refining Member - $0.00
Government, NonMember - $35.00

Description:

EPA started gathering information to support a residual risk and technology review (RTR) of the Ethylene MACT over 2 years ago. In 2016 there has been an increase in activity because EPA anticipates being given a court-ordered deadline to complete the work. Industry reviewed a draft testing ICR and provided comments to EPA in an attempt to reduce the burden, but was provided a final ICR in April 2016 that looked much like the draft. The testing being requested of 9 companies (21 facilities) is extensive and will take a significant amount of effort to complete by the November 2016 deadline. Facilities that decoke their ethylene furnaces through a decoking pot stack will experience sampling challenges similar to those the refinery industry experienced when first sampling delayed cokers. AECOM performed a pre-test for the American Chemistry Council at a member facility to characterize the challenges and provide guidance to facilities as they prepare to conduct sampling to meet EPA’s requirements. We expect that many compounds EPA is requesting to be sampled as part of the ICR will be challenging to measure at levels above the method detection limits. This paper and presentation will discuss both the sampling challenges and the potential regulatory implications of the data that will be collected, and provide thoughts on the actions EPA could take as part of the RTR.

Product Details:

Product ID: ENV-16-18
Publication Year: 2016