Kristin Gordon presented, "The Petroleum Refinery Sector Rule: What’s all the fuss about and what are the key implications for Texas (including other industry sectors)?” at the AWMA Central Texas Chapter Meeting on January 21, 2016.
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The Petroleum Refinery Sector Rule: What’s all the fuss about and what are the key implications for Texas (including other industry sectors)?”
1. 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.| kgordon@all4inc.com | 281.937.7553 x301
AWMA Central Texas Chapter Meeting
January 21, 2016
Presented by All4 Inc.
2. 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. 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. 4 Your environmental compliance is clearly our business.
U.S. Refineries By State
0
5
10
15
20
25
30
#ofRefineries
States
2015 EIA data
5. 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. 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. 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. 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. 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 Size
Number of
Monitors
< 750 acres 12
750-1,500 acres 18
>1,500 acres 24
10. 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 Area
Sources
• Method 325B
Sampler Preparation and
Analysis
What’s New? What Changed?
11. 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. 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. 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. 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. 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. 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. 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. 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 NextGen
Compliance
Texas/Gulf Coast Implications
19. www.all4inc.com | Philadelphia | Atlanta | Houston | Washington DC
Questions?
Contact Information:
Kristin Gordon, P.E.
Houston Office Director
kgordon@all4inc.com
(281) 937-7553 x301
Resources:
all4inc.com/resources