The Petroleum Refinery Sector Rule:
What’s all the fuss about and what are the key
implications for Texas
(including other industry sectors)?”
AWMA Central Texas Chapter Meeting
January 21, 2016
Presented by All4 Inc.
Kristin M. Gordon, P.E.| [email protected] | 281.937.7553 x301
www.all4inc.com | Philadelphia | Atlanta | Houston | Washington DC
Agenda
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
Background
What’s New? What Changed?
•
•
•
•
•
•
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2
Delayed Coking Units
Flares
Storage Vessels
Fenceline Monitoring
ERT/CEDRI
Startup, Shutdown and Malfunction
Texas/Gulf Coast Implications
Questions
Your environmental compliance is clearly our business.
Background

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
•
•
•
•
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3
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
Your environmental compliance is clearly our business.
U.S. Refineries By State
30
2015 EIA data
# of Refineries
25
20
15
10
5
0
4
States
Your environmental compliance is clearly our business.
What’s New? What Changed?

Delayed Coking Units
• Existing and New – Set MACT Floor per MACT 1
• Existing

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Drum pressure less than 2 psig before decoking
Averaging provisions across facility (60 batch average)
Steam Ejector System
• New

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
5
Drum pressure less than 2.0 psig before decoking
Per source, per-coking cycle basis
Closed Blowdown System
Your environmental compliance is clearly our business.
What’s New? What Changed?

Flares
• Bulk of changes in MACT 1, some in MACT 2
• Cross reference removed to General Provisions, Part
63 Subpart A
• Changes

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
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6
Method of Operation
Operating Limits
Monitoring Requirements
Work Practice Standards
Your environmental compliance is clearly our business.
What’s New? What Changed?

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
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
7
Includes smaller capacity
storage vessels and/or
storage vessels containing
materials with lower vapor
pressures
Some Group 2 tanks become
Group 1
Your environmental compliance is clearly our business.
What’s New? What Changed?

Benzene Fenceline Monitoring
• Action Level – 9.0 ug/m3 rolling annual average (2.8
ppb)
• Monitors at
Fenceline
• Refinery MACT 1
8
Your environmental compliance is clearly our business.
What’s New? What Changed?

Benzene Fenceline Monitoring
• # Monitors
• Where:
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9
Facility Configuration
Fenceline Security
Building Downwash
Background
Neighbors
Refinery Size
Number of
Monitors
< 750 acres
12
750-1,500 acres
18
>1,500 acres
24
Your environmental compliance is clearly our business.
What’s New? What Changed?

Benzene Fenceline Monitoring
• Passive diffusion tubes + blanks
+ duplicates
• Sampling Period = 2 weeks
• Tubes to lab, deploy replacement tubes
• Method 325A

VOCs from Fugitive and Area
Sources
• Method 325B

10
Sampler Preparation and
Analysis
Your environmental compliance is clearly our business.
What’s New? What Changed?

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
11
Your environmental compliance is clearly our business.
What’s New? What Changed?

Benzene Fenceline Monitoring
•
•
•
•
Corrective Action Plan/Root Cause Analysis
Reduced Monitoring
Alternative Monitoring
2 years after effective date

12
Wait? What should facilities be doing now?
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
13
Your environmental compliance is clearly our business.
What’s New? What Changed?

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.
14
Your environmental compliance is clearly our business.
What’s New? What Changed?

CEDRI/ERT cont’d
• E-Reporting includes
the following:

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15
Performance test
results
Monitoring data
Ongoing compliance
reports
Emissions reports
Notifications [e.g.,
Notification of
Compliance Status
(NOCS)]
Your environmental compliance is clearly our business.
What’s New? What Changed?

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
16
Your environmental compliance is clearly our business.
What’s New? What Changed?

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

17
Texas MSS
Your environmental compliance is clearly our business.
Texas/Gulf Coast Implications


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 NextGen
Compliance
18
Your environmental compliance is clearly our business.
Questions?
Contact Information:
Kristin Gordon, P.E.
Houston Office Director
[email protected]
(281) 937-7553 x301
Resources:
all4inc.com/resources
www.all4inc.com | Philadelphia | Atlanta | Houston | Washington DC