www.all4inc.com | Philadelphia | Atlanta | Houston | Washington DC
The Petroleum Refinery Sector Rule: What’s all the fuss about and what are the key
implications for Texas (including other industry sectors)?”
Kristin M. Gordon, P.E.| [email protected] | 281.937.7553 x301
AWMA Central Texas Chapter Meeting
January 21, 2016
Presented by All4 Inc.
2 Your environmental compliance is clearly our business.
Agenda
Background
What’s New? What Changed?
• Delayed Coking Units
• Flares
• Storage Vessels
• Fenceline Monitoring
• ERT/CEDRI
• Startup, Shutdown and Malfunction
Texas/Gulf Coast Implications
Questions
3 Your environmental compliance is clearly our business.
Refinery Sector Rule
• 40 CFR Part 63, Subparts CC and UUU (“Refinery MACT 1” and “Refinery MACT 2”)
• 40 CFR Part 60, Subpart J and Ja
• regulations.gov @ EPA-HQ-OAR-2010-0682-0840
Rulemaking timeline
• Proposed – June 30, 2014, 200k+ comments
• Signed – Final` September 29, 2015
• Federal Register – December 1, 2015
• Effective Date – February 1, 2016
Varying Effective Compliance Dates
Background
4 Your environmental compliance is clearly our business.
U.S. Refineries By State
0
5
10
15
20
25
30
# o
f R
efi
ne
rie
s
States
2015 EIA data
5 Your environmental compliance is clearly our business.
Delayed Coking Units
• Existing and New – Set MACT Floor per MACT 1
• Existing
Drum pressure less than 2 psig before decoking
Averaging provisions across facility (60 batch average)
Steam Ejector System
• New
Drum pressure less than 2.0 psig before decoking
Per source, per-coking cycle basis
Closed Blowdown System
What’s New? What Changed?
6 Your environmental compliance is clearly our business.
Flares
• Bulk of changes in MACT 1, some in MACT 2
• Cross reference removed to General Provisions, Part 63 Subpart A
• Changes
Method of Operation
Operating Limits
Monitoring Requirements
Work Practice Standards
What’s New? What Changed?
7 Your environmental compliance is clearly our business.
Storage Vessels
• Refinery MACT 1
• Part 63/Subpart WW (Generic MACT) Requirements
Guidepole controls and other fitting controls for existing external or internal floating roof tanks
• Revised Group 1 definition
Includes smaller capacity storage vessels and/or storage vessels containing materials with lower vapor pressures
Some Group 2 tanks become Group 1
What’s New? What Changed?
8 Your environmental compliance is clearly our business.
Benzene Fenceline Monitoring
• Action Level – 9.0 ug/m3 rolling annual average (2.8 ppb)
• Monitors at Fenceline
• Refinery MACT 1
What’s New? What Changed?
9 Your environmental compliance is clearly our business.
Benzene Fenceline Monitoring
• # Monitors
• Where:
Facility Configuration
Fenceline Security
Building Downwash
Background
Neighbors
What’s New? What Changed?
Refinery SizeNumber of Monitors
< 750 acres 12
750-1,500 acres 18
>1,500 acres 24
10 Your environmental compliance is clearly our business.
Benzene Fenceline Monitoring
• Passive diffusion tubes + blanks+ duplicates
• Sampling Period = 2 weeks
• Tubes to lab, deploy replacement tubes
• Method 325A
VOCs from Fugitive and AreaSources
• Method 325B
Sampler Preparation and Analysis
What’s New? What Changed?
11 Your environmental compliance is clearly our business.
Benzene Fenceline Monitoring
• Collect 1 year of data, report quarterly via CEDRI (stay tuned)
• Neighbors
Background Concentrations
Near Field Sources
• Meteorological Monitoring Station
• Site Specific Monitoring Plan
What’s New? What Changed?
12 Your environmental compliance is clearly our business.
Benzene Fenceline Monitoring
• Corrective Action Plan/Root Cause Analysis
• Reduced Monitoring
• Alternative Monitoring
• 2 years after effective date
Wait? What should facilities be doing now?
What’s New? What Changed?
13 Your environmental compliance is clearly our business.
What’s New? What Changed?
CEDRI/ERT
• Increasing # of NSPS and NESHAPs/MACT require electronic reporting, or “E-Reporting”.
• E-Reporting is completed using U.S. EPA’s Compliance and Emissions Data Reporting Interface (CEDRI).
• CEDRI is located on U.S. EPA’s Central Data Exchange (CDX).
• Some reports (e.g., stack test results) compiled using the Electronic Reporting Tool (ERT) before being uploaded to CEDRI.
Two separate entities
14 Your environmental compliance is clearly our business.
CEDRI/ERT cont’d• Final revisions to Refinery MACT 1 and Refinery MACT 2
reporting provisions require use of ERT and CEDRI. Fenceline monitoring data [40 CFR §63.655(h)(8)]
Results of performance tests or CEMS performance evaluations [40 CFR § § 63.655(h)(9) and 63.1575(k)]
• Note: other Subparts refineries may be subject to (i.e., Boiler MACT) may also have E-Reporting requirements.
What’s New? What Changed?
15 Your environmental compliance is clearly our business.
CEDRI/ERT cont’d
• E-Reporting includes the following:
Performance test results
Monitoring data
Ongoing compliance reports
Emissions reports
Notifications [e.g., Notification of Compliance Status (NOCS)]
What’s New? What Changed?
16 Your environmental compliance is clearly our business.
Startup, Shutdown and Malfunction (SSM)
• SSM exemptions removed per 2008 DC Circuit vacature
• No excess emissions exemption
• No SSM Plan requirement
• Alt Limits or Work Practice Standards for select sources
• MACT 1 – PRDs, MPVs, Flares, Others
• MACT 2 – FCCU, CRU, SRU
What’s New? What Changed?
17 Your environmental compliance is clearly our business.
Startup, Shutdown and Malfunction (SSM)
• General Duty to minimize emissions (MACT 1 and 2)
• NSPS SSM exemption still applies
Ja – FCC and SRU
• Existing Permit Considerations
Texas MSS
What’s New? What Changed?
18 Your environmental compliance is clearly our business.
Rule Implementation and Compliance Challenges over the next 3 yrs+
Impacts on other rules/industry
• Fenceline Monitoring
• Removal of any SSM relief
• Flares
• Public Role
• Aligning with NextGenCompliance
Texas/Gulf Coast Implications
www.all4inc.com | Philadelphia | Atlanta | Houston | Washington DC
Questions?
Contact Information:
Kristin Gordon, P.E. Houston Office Director [email protected](281) 937-7553 x301
Resources:
all4inc.com/resources
