NSPS SOCMI YYY is expected to be promulgated shortly!  If you make a SOCMI Table 1 compound IN ANY QUANTITY and don’t meet one of the following exemptions, you will have to meet at least some of the requirements of the proposed SOCMI Subpart YYY. 

2.4  Exemptions

The following processes or products are currently excluded from the Subpart YYY provisions:

• Research and development facilities.  Research and development facilities, as defined in 40 CFR 60.771, primarily conduct research and development into new processes and products.  They are not are not significantly involved in the manufacturing or products for commercial sale.
• Petroleum refining process units.  As defined in 40 CFR 60.771, are units that produce transportation fuels, heating fuels, or lubricants.  These units also include processes that separate petroleum or separate, crack, or reform unfinished derivatives.  These units are excluded regardless of whether the units supply feedstocks that include chemicals listed in Table 1 to this subpart to CPU that are subject to the provisions of Subpart YYY.
• CPU that are located in coke by-product recovery plants.
• Solvent reclamation, recovery, or recycling operations at a hazardous waste treatment, storage, and disposal facility (TSDF) requiring a permit under RCRA that are not part of a SOCMI CPU.
• Organic chemicals extracted from natural sources or totally produced from biological synthesis, such as pinene, coconut oil acids, sodium salt, fatty acids, tall oil, tallow acids, potassium salt, and beverage alcohol. Petroleum stock is not considered a natural source for the purposes of this subpart.
• Sources that contain organic peroxides may request, in writing, to have the control requirements of Subpart YYY waived if the owner or operator cannot meet the applicable requirements because of safety reasons.  Request must be submitted at least 90 days prior to the NOCS report due date and is subject to review and approval/disapproval by the administrator.

Want to know more about how to determine applicability for SOCMI YYY, what your site needs to be doing now to comply, or the latest technology solutions for managing recordkeeping and reporting?   Attend the May 4th webinar and subscribe to our mailing list.  To register, e-mail your contact information to info@dixonenvironmental.com or call us today at (610) 722 – 9444.