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INSPECTION TOOL FOR THE MISCELLANEOUS ORGANIC CHEMICAL MANUFACTURING NESHAP

It should be noted that some soil types have been shown to exhibit significant degradation of aromatic VOCs in less than 48 hours (Hewitt, et. al., 1999, Environmental Testing and Analysis). Also, Sorini, et. al., (2002, Soil Sediment & Water) observed significant differences between samples that were extruded directly into methanol and samples where methanol was added at a later time to soil extruded into empty VOA vials (where methanol was added through the septum). Based on these findings, where project or program DQOs require a higher degree of accuracy soil samples may need to be chemically preserved. | ÂEPA United States Environmental Protection Agency EPA-305-B-06-002 September 2006 Inspection Tool for the Miscellaneous Organic Chemical Manufacturing NESHAP Table of Contents Section 1.0 Section 2.0 Air Compliance Branch Compliance Assessment and Media Programs Division CAMPD Office of Compliance OC Office of Enforcement and Compliance Assurance OECA U.S. Environmental Protection Agency Washington DC 20460 Disclaimer The statements in this document are intended solely for compliance assistance. This document is to be used in conjunction with the regulations not in place of them. It is not intended nor can it be relied on to create any rights enforceable by any party in litigation with the United States. The U.S. Environmental Protection Agency EPA and State officials may decide to follow the guidance provided in this document or to act in variance with it based on analysis of specific site circumstances. This guidance may be revised without public notice to reflect possible rule changes and changes in EPA s policy. Please be aware that EPA has made its best effort to present an accurate summary of the regulatory requirements in the miscellaneous organic chemical manufacturing NESHAP as promulgated on November 10 2003 and amended on July 1 2005 March 1 2006 and July 14 2006. Note that it is not intended to summarize every option and detail of the rule. Finally in the event that there are typing errors or deviations from the final rule the final rule stands. Table of Contents Table of Contents Section Page I. 0 Background and Purpose of this Document.1-1 1.1 How to Use the Checklists.1-1 1.2 Preparing the Inspection .1-3 2.0 General Applicability .2-1 3.0 Process Vents .3-1 4.0 Storage Tanks Surge Control Vessels and Bottoms Receivers.4-1 5.0 Wastewater Systems.5-1 6.0 Equipment Leaks .6-1 7.0 Transfer Racks .7-1 8.0 Heat Exchange Systems .8-1 9.0 Closed-Vent Systems .9-1 10.0 Control Device and Recovery Device Checklists.10-1 II. 0 Alternative Standard.11-1 12.0 .