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EPA amended the Petroleum Refinery NESHAP (a.k.a. "Refinery MACT II") on February 9, 2005 based on concerns of several refineries and industry trade organizations. The amendments clarify rule applicability and monitoring requirements for catalytic cracking units (CCU), catalytic reforming units (CRU), and sulfur recovery units (SRU) and provide new compliance options for some CRUs. The following is a list of the more significant changes to the rule:

• The detailed performance specifications for continuous parameter monitoring systems (CPMS) have been removed. CPMS systems must now be installed, operated, and maintained in a manner that is consistent with manufacturer’s recommendations or other written procedures that assure the equipment will monitor accurately.
• Facilities with affected CCUs that demonstrate compliance with the NSPS PM standard may now calculate volumetric flow rate from the regenerator exhaust using gas analyzer CO₂, O₂, and CO measurements, provided these measurements are taken prior to the addition of air or other gas streams.
• The exemption from organic HAP standards during reactor purging for affected CRUs has been clarified. Purging operations greater than 5 psi are exempt if the uncontrolled emissions of total organic carbon (TOC) or non-methane TOC are less than 20 ppm, corrected to 3% O₂.
• Affected CRUs with an internal scrubber may now demonstrate compliance with an alternative HCl percent reduction standard.
• New compliance options are available for CRUs equipped with a gas-solid adsorption system.

The new amendments are open for public comment until March 11, 2005 or by March 28, 2005 if a public hearing is requested. If no adverse public comments are received, the amendments will become effective April 11, 2005 (the existing compliance deadline).

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Last Revised: February 22, 2005