ENV-17-31 Refinery-wide Maintenance Vent Compliance Program Development Strategies

Description:

As part of the Refinery Sector Rule (RSR)1, the U.S. Environmental Protection Agency removed the startup, shutdown and malfunction (SSM) exemption from the MACT Subpart CC2 for miscellaneous process vents (MPVs). The EPA implemented an alternative MPV group designation type (maintenance vents) with associated work practice standards for vents that emit to the atmosphere only during equipment startup, shutdown, maintenance or inspection. Compliance with the maintenance vent provisions was required by August 1, 2017 (or will be required by August 1, 2018, if the facility was granted a one-year compliance extension); 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)  Phased approach to developing a maintenance vent compliance program (Section 2)  Refinery-wide maintenance vent screening and calculation methods (Section 3)  High level maintenance vent documentation strategies (Section 4)