ENV-16-82 Implementation of a Maintenance Vent Compliance Program

Description:

As part of the Refinery Sector Rule (RSR)1, the EPA removed the startup, shutdown and malfunction (SSM) exemption from the MACT Subpart CC2 for miscellaneous process vent (MPVs). The EPA implemented an alternative MPV group designation type (maintenance vents) with associated work practice standards for vents that only emit to the atmosphere during startup, shutdown, maintenance or inspection of the equipment. Compliance with the maintenance vent provisions is required by August 1, 2017; however, between February 1, 2016 and the compliance date, sources must comply with the general duty to minimize emissions for each maintenance venting activity.3 This paper provides a discussion of the following: • Overview and regulatory applicability (Section 1) • Emission limits, standards, and compliance procedures for determining MPV classification (Section 2) • Calculation methodologies (Section 3) • Recordkeeping requirements (Section 4) • Reporting requirements (Section 5) • Implementation challenges and case studies (Section 6) • Recommended steps for performing a gap assessment for MPV compliance (Section 7)