(123c) Ethylene Risk and Technology Review Reconsideration, What NOW?

EPA promulgated the Ethylene Risk and Technology Review (RTR) National Emission Standard for Hazardous Air Pollutants (NESHAP, 40 CFR, Part 63, Subpart XX and Subpart YY) on July 6, 2020. It is applicable to new and existing ethylene production units. The final rule included requirements for furnace and decoke operations, flares, process vents, heat exchange systems and pressure relief devices. Environmental non-governmental organizations filed a petition requesting EPA to reconsider certain sections of the rule. EPA granted the request and is working through the reconsideration process. This paper will review the potential impact of the reconsideration request.