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US EPA Proposes to Amend Off-Site Waste and Recovery Operations NESHAP to Address Monitoring Requirements for Pressure Relief Devices on Containers

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On August 7, 2017, the US Environmental Protection Agency (EPA) proposed to amend the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Off-Site Waste and Recovery Operations (OSWRO) to address the monitoring requirements for pressure relief devices (PRDs) on containers. The proposed amendment would eliminate the additional monitoring requirements for PRDs on containers that were established by a 2015 amendment to the OSWRO NESHAP that imposed monitoring requirements for all PRDs. The 2015 PRD monitoring requirements applied to PRDs on containers in addition to preexisting inspection and monitoring requirements for containers and their closure devices, PRDs included, that were already required by the OSWRO NESHAP. The EPA states that it has determined that the additional monitoring requirements for PRDs are not necessary with regards to PRDs on containers in light of the preexisting monitoring requirements for containers and their closure devices. The EPA is accepting public comments on the proposed rule until September 21, 2017. National Emission Standards for Hazardous Air Pollutants: Off-Site Waste and Recovery Operations, 82 Fed. Reg. 36,713 (Proposed Aug. 7, 2017).

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