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May 19, 2014
Significant revisions proposed for refinery NESHAPs

The results of EPA’s residual risk and technology review (RTR) of two existing air standards affecting the petroleum refinery sector indicated that compliance with the standards does not expose populations surrounding refineries to an unacceptable risk of cancer.  That is good news for the industry, which believes additional actions to protect the environment and public health are unnecessary. 

But EPA’s RTRs look at two additional factors.  First, the technology review is intended to determine if there are new emissions control developments that industry should be forced to adopt if the Agency considers the cost to be reasonable.  Second, the Clean Air Act’s (CAA) residual risk provision is based on the premise that National Emissions Standards for Hazardous Air Pollutants (NESHAPs) must protect public health with an ample margin of safety

After looking at both these issues the EPA is proposing new requirements for the refinery sector at a sectorwide capital cost estimated by the Agency at $240 million and an annual cost of $40 million.  The proposal is a clear manifestation of the administration’s expressed desire to ensure that rulemaking supports environmental justice.  According to the EPA, 142 major source and 7 area source refineries will be affected by the proposed actions. 

Affected population

The proposal would address two rules—the 1995 NESHAP from petroleum refineries, called Refinery MACT I (maximum achievable control technology), and the 2002 NESHAP for petroleum refineries:  catalytic cracking units, catalytic reforming units (CRU), and sulfur recovery units (SRU), called Refinery MACT II.  The CAA directs the EPA to conduct RTRs of NESHAPs within 8 years after issuance. 

Health risks to low-income and minority populations living near petroleum refineries have been a consistent concern of environmental and public health advocacy groups.  In September 2012, the EPA responded to a lawsuit filed by groups by committing to completing RTRs and issue a proposal (or a determination that a proposal was unnecessary) for Refinery MACT I and Refinery MACT II by May 15, 2014, and take final action on any proposal by April 17, 2015.  The EPA states that the proposed actions will lower the cancer risk to 1 in 1 million or less for 1 million of the 5 million people living within 50 kilometers of the targeted refineries. 

Storage tanks

The RTRs looked at a wide range of specific emissions sources within refineries, including storage vessels, equipment leaks, gasoline loading racks, marine vessel loading operations, cooling towers/heat exchange systems, wastewater collection and treatment, fluid catalytic cracking units (FCCU), flares, miscellaneous process vents, CRU, and SRU.  For most of these sources, the EPA determined that the existing standards protect public health with an ample margin of safety.

The exception is storage tanks.  The Agency’s proposed regulations would require guidepole controls and other fitting controls for existing external or internal floating roof tanks and also expand coverage of the standards to tanks with less storage capacity as well as tanks containing materials with lower vapor pressures than those covered by the existing MACTs.  The Agency says these additional controls would result in an approximately 910 tons per year (tpy) reduction in HAPs, or a 40 percent reduction from storage vessels at refineries.

Fenceline monitoring

In addition and, in a more direct response to concerns about exposure of nearby populations to HAPs, the proposal would require refinery operators to monitor benzene emissions at the facility fenceline and report the monitoring data on a semiannual basis to the Agency.  Benzene itself is a HAP and, under the proposal, serves as a surrogate for other HAPs, particularly those in fugitive emissions that may be released because of equipment leaks and other malfunctions.  Should the facility record benzene above the specified fenceline concentration limit, the facility would need to undertake corrective action.  

The proposal would also remove the exemption from emissions limits during periods of shutdown, start-up, and malfunction, the same action the EPA has been taking in its RTRs of other NESHAPs.  In addition, technical corrections to the existing standards are proposed, mainly in response to petitions from industry.  These include a clarification that flares are subject to performance test requirements; a requirement that corrective action be completed to repair faulty (leaking or plugged) air or water lines within 12 hours of identification of an abnormal pressure reading during the daily checks; and a revision to the frequency of the particulate matter  performance test.

Overall, the Agency believes the proposed changes will reduce HAP emissions by 5,600 tpy and VOC emissions by 52,000 tpy.

The proposal proposal

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