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 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 kgordon@all4inc.com(281) 937-7553 x301

Resources:

all4inc.com/resources