Increased Compliance Flexibility: Croda Inc. Mill Hall, PA 'Once In, Always In (OIAI)' Policy Reversal

摘要

This submitted abstract highlights a practical example of applying the "Redassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act" effective February 8, 2018, commonly referred to as U.S. EPA's "once in, always in" (OIAI) policy reversal. Specifically, the Croda Inc. Mill Hall, PA facility (Croda) worked with ALL4 LLC (ALL4) to develop and submit an air quality construction permit application to request removal of Clean Air Act Section 112 major source Maximum Achievable Control Technology (MACT) standards from the facility Title V operating permit (TVOP). Croda previously established federally enforceable synthetic minor limitations for both hazardous air pollutants (HAP) and volatile organic compounds (VOC) but maintained a TVOP due to the OIAI policy. The proposed permit revisions will ai!ow Croda to operate under a State-Only Operating Permit (SOOP) as a synthetic minor facility for both HAP and criteria pollutants. This scenario is operationally advantageous for the batch and semi-continuous chemical processing at the facility, which produces over 250 products. The platform presentation will highlight the following three key components of the project. The reduced compliance burden achieved with the use of the OIAI policy reversal, including: 1.Elimination of 40 CFR Part 63, Subpart H leak detection and repair (LDAR) requirements. 2.Elimination of unique work practices and emissions limitations for individual reactors that differ from those applicable to a reactor set. The reduced compliance burden achieved with changes to the strategy for compliance assurance to reflect SOOP versus TVOP requirements, including: 3.Reduced sampling and analysis of reactor headspace and spent resin, which was formerly required for every batch to assure TVOP compliance. Croda and ALL4 conducted a detailed statistical analysis of historic sample data to justify reduced sampling events. The reduced sampling events in turn reduce potential personnel chemical exposure during the sampling events. 4.Revisions of monitoring, recordkeeping, and reporting conditions, including permit hygiene improvements. The process Croda and ALL4 used to achieve the removal of the MACT standards and revisions to compliance assurance approaches, including: 5.State considerations for applicable permit condition revisions (e.g., consideration of best available technology (BAT), reasonably available control technology (RACT), ozone transport region (OTR) requirements, etc.). 6.Monitoring, recordkeeping, and reporting revisions allowed by the state agency. 7.The state agency application and negotiation process used to convert from a TVOP to a SOOP.