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.

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