Miscellaneous
Organic
NESHAP
(
MON)
EPA/
American
Chemistry
Council
Meeting
August
20,
2002
1:
00
 
5:
00
pm
Eastern
Time
EPA
Call
In
Number
 
919
541
4332
Tentative
Agenda
Applicability
and
Affected
Source
1.
Need
for
a
Clear
Compliance
Roadmap
2.
Key
Definitions
­
MCPU,
MOCMP
and
Family
of
Materials
3.
Overlap
and
Duplication
­
MON
&
OLD
(
storage
tanks
and
intervening
tanks),
Part
60,
61,
65
MON
&
PAI,
Pharma
Recommendations
on
How
to
Streamline
Overlap
Emission
Limitations
1.
Separate
Batch
&
Continuous
2.
Definition
of
Process
Vent
3.
Regulating
Storage
Tanks
as
Process
Vents
Compliance
Dates
1.
Three
years
to
comply
for
existing
MON
facilities
2.
Early
LDAR
Opt­
In
3.
Storage
Tanks
with
Nonconforming
Seals
Miscellaneous
1.
QA/
QC
2.
Status
of
wastewater
for
soluble
HAPs
3.
Earthjustice
MON
Comments,
Other
Organizations
Who
Commented?
