U.S. EPA Issues Long-Awaited Petroleum Refinery Rule Package
Posted: September 30th, 2015Author: All4 Staff
On September 29, 2015, U.S. EPA issued the long-awaited Petroleum Refinery Rule Package. After considering more than 200,000 comments on the June 2014 proposed rule package, U.S. EPA issued the final revisions to the Maximum Achievable Control Technology (MACT) and New Source Performance Standards (NSPS) Refinery Air Rules (i.e., 40 CFR Part 63, Subparts CC and UUU, Refinery MACT 1 and Refinery MACT 2; and, 40 CFR Part 60, Subparts J and Ja, respectively). The final package encompasses the risk and technology review (RTR) of Refinery MACT 1 and MACT 2. Additionally, it provides technical corrections and clarifications for the 2008 NSPS.
Today’s blog focuses on the major changes from the proposed rules. For more information on the proposed rules, please refer to my previous blog: U.S. EPA Proposes Overdue Refinery Air Rules, as well as ALL4’s May 2014 and June 2014 4 The Record articles for more in-depth looks at flare requirements, benzene fenceline monitoring, and related requirements. In addition, please refer to John Slade‘s blog post about Refinery MACT risk assessment.
So, what changed and what stayed the same from the proposal?
Let’s get started with benzene fenceline monitoring, jump into flare combustion efficiency requirements, discuss delayed coking units (DCU), and wrap things up with everyone’s favorite, Startup, Shutdown and Malfunction (SSM).
Benzene Fenceline Monitoring
For the most part, the benzene fenceline monitoring requirements remain the same as the proposal. The key differences include imposing a tighter implementation schedule [reduced from three (3) years to two (2) years after promulgation]. U.S. EPA specifies alternative monitoring technologies as part of the final rule and clarifies monitor siting and analytical procedures. U.S EPA now requires reporting on a quarterly basis rather than semiannual. Additionally, U.S. EPA provides an incentive for reducing fugitive emissions by providing an option to decrease sampling locations for remaining consistently 10% below the benzene fenceline concentration trigger.
Flare Combustion Efficiency
U.S. EPA’s flare operating requirements maintain the emissions reductions projected in the proposal; however, the compliance approach is streamlined. U.S. EPA is allowing refineries to use a higher adjusted heating value as long as the refinery has a hydrogen monitoring system. Refineries can choose between a 15-minute feed forward or a 15-minute block average for compliance demonstration purposes. The requirements are also simplified to a single net heating value operating limit in the flare combustion zone of greater than or equal to 270 British Thermal Units per standard cubic foot (BTU/SCF). Refineries also are allowed to use limited sampling to demonstrate compliance for non-variable flare gas compositions.
The majority of the DCU requirements remain the same as the proposal with some additional flexibility. The final rule allows for averaging across all DCU at a facility to meet the 2 pounds per square inch gauge (psig) requirement. For new sources, a 2.0 psig (on a per-coking cycle basis) MACT floor is established and does not allow for facility-wide coke drum averaging. Additionally, U.S. EPA took into account cost data provided by commenters, as well as revised DCU emissions (resulting from revised emission factors) in the final rule.
In the proposed rule, refineries were required to comply at all times, as the SSM exemptions were removed. In the final rule, U.S. EPA establishes work practice standards for pressure relief devices (PRDs) and emergency flaring that include proactive requirements (e.g., instrumentation, operator training, improved process control) and root cause analysis along with corrective action. Additionally, U.S. EPA’s final rule will require refineries to make operational changes to prevent PRD releases and emergency flaring. This approach is in lieu of building additional flares to control releases.
Promulgation of the rule can be expected in the Federal Register in the coming weeks or month. Upon promulgation, refineries have three (3) years to demonstrate compliance with the rule, with a few exceptions, including the 2-year requirement for benzene fenceline monitoring implementation.
Stay tuned to future ALL4 4 The Record articles where we’ll provide an in-depth analysis of some of the key requirements of the final rule and the impacts on refineries.