## EPA Workshop for Environmental Justice Communities **on Proposed Updates to Emission Standards for**  **Refineries**

Tuesday, July 1 , 2014
9:00 am

– 4:30 pm (8:30 am check

- in) The California Endowment’s Oakland Conference Center 1111 Broadway, 7th Floor, Oakland, CA 94607

Workshop Objectives

• Provide an in

- depth review of the proposed refinery emission standards rule (refinery rule) with a focus on technical issues.

• Provide EPA staff with a better understanding of key community concerns about the refineri es

.

• Enhance the effectiveness of the public engagement process during this rulemaking.

Tuesday July 1, 2014

8:30 am

– 9:00 am Arrival and Registration
9:00 am

– 9:20 am Welcome, Introductions and Overview

Welcome and Introductions

- Laura McKelvey, U.S. EPA, Office of Air Quality Planning and Standards

- Deldi Reyes, U.S. EPA, Region 9

Rules of Engagement During the Open Comment Period

- Laura McKelvey, U.S. EPA, Office of Air Quality Planning and Standards

Workshop and Agenda Overview and Ground Ru les
Facilitator: Vernice Miller

- Travis, Skeo Solutions
9:20 am

– 9:50 am Experiences and concerns of fenceline communities and the potential for communities and advocates to impact the refinery rule

- Dr. Henry Clark, West County Toxics Coalition

- Jesse Marquez, Coalition for a Safe Environment

- Patrice Lee, Alaskan Community Action on Toxics
9: 5 0 am

– 10 : 50 am Context and E volution of the Proposed Refinery R ule
Facilitator: Vernice Miller

- Travis, Skeo Solutions

• Background for the proposed refinery rule

- Laura McKelvey, U.S. EPA, Office of Air Quality Planning and Standards

- Brenda Shine, U.S. EPA, Office of Air Quality Planning and Standards

- Clean Air Act and the evolution of the refinery rule

- Purpose of the refinery rule

- EPA’s EJ policies

• Overview of the Clean Air Act authorities and refinery rule

• Brief synopsis of the proposed amendments in the refinery rule

- Flares

- Delayed cokers- Storage tanks

- Startup, Shutdown and Malfunction (SSM) exemptions

- Fenceline monitoring

• Discussion of other technical issues related to the refinery rule
Facilitator: Vernice Miller

- Travis, Skeo Solutions

• Prioritizing the issues for “Drilling Down on Key Issues” dialogue
Facilitator: Vernice Miller

- Travis, Skeo Solutions

10:50 am

– 12:00 pm Drilling Down on Key Issues (two

- way facilitated dialogue about key issues and concerns identified in previous session)
Facilitator: Vernice Miller

- Travis, Skeo Solutions

• Discussion topics

- EPA rationale for rule change

- How would proposed rule change th e identified key issues?

• Question and answer dialogue

• Presentations by participants, as relevant to the issue 12:00 pm

– 12:45 pm BREAK/LUNCH 12:45 pm

– 3:30 pm Drilling Down on Key Issues (continued) (two

- way facilitated dialogue about key
issues and concerns)
Facilitator: Vernice Miller

- Travis, Skeo Solutions 3:30 pm

– 4:15 pm Next S teps Facilitator: Vernice Miller

- Travis, Skeo Solutions

• Public hearing and commenting process

• What happens to comments submitted by the public?

4:15

– 4:30 pm Wrap

- up and ConclusionAttendeeList7‐9‐14LastName FirstName OrganizationAffiliation EmailAddress AddressBailey Diane NRDC dbailey@nrdc.org 111SutterSt.20thFloor,SanFrancisco,California94002Bardet Marilyn BeniciansforaSafeandHealthyCommunity mjbardet@comcast.net Benicia,California94510Bird Kate SkeoSolutions kbird@skeo.com 13136thAvenue,LakeCharles,Louisiana70601Clark Dr.Henry WestCountyToxicsCoalition henryc11@prodigy.net 305ChesleyAvenue,Richmond,California94801Cort Paul Earthjustice pcort@earthjustice.org SanFrancisco,California94131Engelbert Bruce SkeoSolutions bengelbert@skeo.com SanDiego,California0Griffith Tamhas MartinezEnvironmentalGroup tamhas@gmail.com Martinez,California94553Grow Richard USEPA grow.richard@epa.gov 75Hawthorne,SanFrancisco,California94105Gunkelman Jay (independentofanyorganization) qeegjay@sbcglobal.net 2210PruneStreet,Pinole,California94564Kang Helen GoldenGateUniversity,EnvironmentalLawandJusticeClinichkang@ggu.edu SanFrancisco,California94105Karras Greg CommunitiesforaBatterEnvironment gkarras@cbecal.org Oakland,California94612Kent Michael ContraCostaHealthServices michael.kent@hsd.cccounty.us 597CenterAve.,Suite100,Martinez,California94553Kerridge Kathy BeniciansforaSafeandHealthyEnvironment salfano@skeo.com Benicia,California94510Larson Denny GlobalCommunityMonitor denny@gcmonitor.org POBox1784,Richmond,California94805Lee Patrice CitizensforCleanAir(CCA);AlaskaCommunityActiononToxics(ACAT)patricelee3294@gmail.com Fairbanks,Alaska99712Marquez Jesse CoalitionforaSafeEnvironment jnm4ej@yahoo.com 1601N.WilmingtonBlvd.Ste.B,Wilmington,California90744Miller‐Travis Vernice SkeoSolutions vmiller‐travis@skeo.com Bowie,Maryland20721Newell Brent CenteronRace,Poverty&theEnvironment bnewell@crpe‐ej.org 1999HarrisonStreet,Suite650,Oakland,California94612Penn Paul CaliforniaEnvironmentalProtectionAgency paul.penn@calepa.ca.gov 1001Ist,Sacramento,California95812Reyes Deldi USEPA reyes.deldi@epa.gov 75HawthorneSt,SanFrancisco,California94105Zamora Abraham CRPE abe_zamora@berkeley.edu 1932HearstAve,AptF,BerkeleyCA94709Bandrowski Mike USEPARegion9 bandrowski.mike@epa.govDavidson Ken USEPARegion9 davidson.ken@epa.govStewart Kathleen USEPARegion9 stewart.kathleen@epa.govMcKelvey Laura EPAOAQPSShine Brenda EPAOAQPSKelly Shaheerah USEPARegion9 kelly.shaheerah@epa.govLaw Nicole USEPARegion9 law.nicole@epa.govSolomon Gina CaliforniaEnvironmentalProtectionAgency gina.solomon@calepa.ca.govHayes Kevin CRPE khayes@crpe.orgTammru Biruk NRDC btammru@nrdc.org

# A Brief Overview of the: CAA authorities Proposed Refinery Residual Risk and Technology Review

Public Outreach Presentation July 1, 2014

U.S. Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park, NC

# Purpose

► 

# Provide background information on the rulemaking
process

► 

# Inform the public on Proposed Petroleum Refinery Sector Risk and Technology Review and New Source Performance Standards that were signed by the Administrator on May 15, 2014. Describe how written comments can be submitted to the docket.

► 

# Note: This webinar is intended to be an educational overview of the proposal and does not cover all of the proposal details. W e will **not** be taking comments on the rule during this webinar. Please refer back to the proposal when crafting your written comments.

2

# Section 112 of the Clean Air Act 

# Overview

► 

# Establishes requirements for setting national emission standards for hazardous air pollutants (NESHAP)

► 

# A hazardous air pollutant is defined as “any air pollutant listed pursuant to subsection (b) of this section [CAA section 112]”

► 

## There are currently 189 pollutants on the HAP list (the complete list is available online at: http://www.epa.gov/ttn/atw/overview.html)

► 

# Stationary sources are broken down into two categories: major and

area

► 

## A major source “means any stationary source or group of stationary sources located within a contiguous area and under common control that emits or has the potential to emit considering controls, in the aggregate, 10 tons per year or more of any hazardous air pollutant or 25 tons per year or more of any combination of hazardous air pollutants”

► 

## An area source “means any stationary source of hazardous air pollutants that is not a major source”

# Regulation of Toxic Pollutants

► 

# The Clean Air Act listed 189 (now 183) toxic air pollutants (that may cause cancer or serious health problems)

► 

# There are literally thousands of sources of toxic air pollutants (also called hazardous air pollutants or HAPs)

► 

# Sources range from gigantic oil refineries to the dry cleaner on the corner, as well as mobile sources (cars, trucks, planes, trains)

► 

# Clean Air Act requires EPA to set standards for specific source types

# Clean Air Act Requirements

► 

# New Source Performance Standards (NSPS)

► 

# CAA section 111(b) requires EPA to set and periodically review, emission standards for new sources of criteria air pollutants (CAP), volatile organic compounds (VOC ) and other pollutants

► 

# Maximum Achievable Control Technology (MACT)

► 

# CAA section 112 requires EPA to:



# • S et emission standards for toxic air pollutants from stationary sources reflecting the maximum achievable control technology (MACT) based on the best performing facilities in an industry



# • Conduct r esidual r isk and technology r eviews (RTR) of these MACT standards

5

# Section 112 of the Clean Air Act 

# Emission Standards

► 

# Per section 112(d), “the Administrator shall promulgate regulations establishing emission standards for each category or subcategory of major sources and area sources of hazardous air pollutants listed for regulation pursuant to subsection (c) of this section in accordance with the schedules provided in subsection (c) and (e) of this section”

► 

# Emission standards “require the maximum degree of reduction in emissions of the hazardous air pollutants...the maximum degree of reduction in emissions that is deemed achievable for new sources in a category or subcategory shall not be less stringent than the emission control that is achieved in practice by the best controlled similar source, as determined by the Administrator”

► 

# The above is speaking to the maximum achievable control technology or MACT program

# Section 112 of the Clean Air Act 

# MACT Program

► 

# Under the MACT program emission limits for existing sources are established by:

► 

## Examining “the average emission limitation achieved by the best performing 12 percent of the existing sources (for which the Administrator has emissions information)... or by examining “the average emission limitation achieved by the best performing 5 sources (for which the Administrator has or could reasonably obtain emission information) in the category or subcategory for categories or subcategories with fewer than 30 sources)

► 

# For area sources the Administrator may “elect to promulgate standards or requirements applicable to sources in such categories or subcategories which provide for the use of generally available control technologies or management practices by such sources to reduce emissions of hazardous air pollutants”

# Section 112 of the Clean Air Act 

# Risk and Technology Review (RTR)

► 

# Residual risk review and technology review required within 8 years of promulgation of MACT standards

► 

# 2

- step risk analysis

1. 

## Determine if risk is acceptable considering health information only, and if not acceptable, tighten standards so risks are acceptable

2. 

## Determine if standards provide an ample margin of safety, which considers health info, costs and feasibility



## ► 

# Risk review includes inhalation risk assessment (cancer and non

cancer) and screens to assess multipathway, whole facility, acute and environmental risks

► 

## Can perform refined multipathway assessments in limited cases if screens show potential multipathway human health risk



## ► 

# Technology review takes into account new developments in practices, processes and control technologies considering cost and feasibility

► 

# We also consider previously unregulated processes and HAP, and we make technical corrections

# Available Resources

► 

## Overview of section 112 (this includes the list of HAPs): http://www.epa.gov/ttn/atw/overview.html

► 

## For further explanation of major and area sources and a list of source categories please visit: http://www.epa.gov/ttn/atw/pollsour.html

► 

## For a listing of all of the NESHAP/MACT final rules please visit: http://www.epa.gov/ttn/atw/mactfnlalph.html

► 

## For an overview of the risk and technology review program please visit: http://www.epa.gov/ttn/atw/rrisk/rtrpg.html

► 

## Plain English guide to Clean Air Act: http://www.epa.gov/air/caa/peg/

► 

## State, local, tribal and federal partnerships: http://www.epa.gov/ttn/atw/stprogs.html

# Clean Air Act Requirements (cont.)

► 

# EPA is required to conduct two reviews and update the existing standards, if necessary



# • Residual Risk Assessment : To determine whether additional emission reductions are warranted to protect public health or the environment; this is a one

- time requirement



# • Technology Reviews : To determine if better emission control approaches, practices or processes are now available; required every eight years

10

# Past Rulemakings On the Refinery Sector

NSPS

► 

## 1974 NSPS

– covers fuel gas combustion devices, FCCU and sulfur plants

► 

## 2008 and 2012 NSPS

– covers same above and delayed cokers , flares and process heaters specifically



# MACT

► 

## Promulgated 2 MACT standards for refineries

► 

## 1995 MACT (known as MACT 1) covers non

- combustion or evaporative sources, such as equipment leaks, tanks, wastewater, miscellaneous process vents; amended to cover heat exchange systems, including cooling towers

► 

## 2002 MACT (known as MACT 2) covers combustion sources: catalytic cracking units

, catalytic reforming units and sulfur recovery units



# Risk and Technology Review (RTR)

► 

## 2007

– proposed risk and technology r eview amendments for non

- combustion sources

► 

## 2009

– withdrew amendments related to risk review due to insufficient data; amendments promulgated for heat exchanger systems and amended in 2013

11100%

% Increase of sulfur i n

GAS OIL 80

Q) Cl c: 60

111 .::: (.)



# - c: Q) (.)



### ... 40

Q) c.

20

1992 19 97 2002 2007 2012

i

. t

cr e ase del vm t lncd u s ; ng of 1 9 'JO avere 9 eEPA Pit 1-Louisiana

EPA Pit 2- Texas

EPA Pit 3-lndlana

EPA Pit 4-Calif o rnia

EPA Pit 5-Virgin Is.

EPA Pit 6-Hawaii

EPA Pit 7-Loulsiana
SCAQMD Pit E

- CA
SCAQMD Pit D

- CA

EPA Pit 8 -lllin o is
SCAQMD Pit A- C A
SCAQMD Pit C-CA

Ch e vron-Richmond

EPA Pit 9-Penn s ylv.
SCAQMD Pit B-CA 

### I H

70 80 Minimum !/ &maximum lbs/1,000 bbls

0 10 2 0 30 40 50 60

FCC particulate matter emissions (lbs/1 ,000 barrels oil feed)

950

•

-­ annual average obse rv ation

m o del >: ns**~** c:: 0**~** 900

650

800

confidence I n terva l (Mean 95%)**~** E

c:: :;

.c 750

7 00

-­ confi d ence I nt erva l (Obs. 95%)**~** 0 0 650

600

550 R 2 = 0

. 925

p <0

. 0001
55,000 65,000 75

, 000

oil feed rate (bar rels/day)

## Coalition For A Safe Environment

Petro l eum Refinery Sector Risk and Technology Review

& 

### New Source Performance Standards

Public Comments

6-30-2014

1. Community Fenceline Monitoring

a. Mandatory Real-Time 24/7 Fenceline Monitoring.
b. Mandatory Fenceline Monitoring Data posted on Federal/State/ AQMD agency websites in real
time.

c

. Mandatory website on-line capability to print and download reports of each facility per Flare incident, weekly, monthly, annually and 5, 10, 20 year reports.
d

. Mandatory that all air emissions and chemicals be monitored not as select few.

2. Flaring

a

. Mandatory MACT to prevent Flaring.
b. Mandatory MACT to eliminate and reduce Flaring such as Vapor Recovery Systems.

c

. Ban on Routine Flaring.
d. Mandatory Flaring Reduction Plan

.
e. Annual review of Flaring Reduction Plan.
f

. Mandatory Enforcement Program & Penalties for failure to achieve Flare Reduction Plan requirements.

g. Mandatory Combustion Efficiency Standards

. h

. Mandatory back-up power to prevent Flaring

. i. Mandatory accurate reporting of Flaring incident emissions. j. Mandatory Public Health & Environmental Mitigation Fund based on 

### $ 500,000

. per metr i c ton of
released chemical emissions.
k

. Prohibition of annual averaging of emission data to hide significant emission release spikes and public exposure to major flaring incidents, fires and explosions.

3. More Stringent Pollution Control From All Sources

a

. Identify all oil refinery emission sources. b. Identify the MACT for each emission source

.
c. Mandatory MACT for each emission source. d. Mandatory that all oil refinery emission sources be monitored in Real-T ime 24/7.

e. Mandatory inventories of all emission sources. f. Mandatory Maintenance & Parts Replacement Plan & Schedule.

g

. Incorporation of the 3-Strikes Rule for reoccurring parts and systems breakdowns.4

. Close All Unlawful Loopholes

a. Void all existing exemptions and waivers.
b. Eliminate Startup, shutdown & malfunction exemptions.

c

. Eliminate all storage tank pressure r el ief valves and bypass exemptions

.

5. Need Public Health Impacts Research Data On All Chemicals

a. Determination of all carcinogenic public health impacts.
b. Determination of all neurological public health impacts.

c. Determination of all non-carcinogenic public health impacts

. d. Determination of all bio-cumulative public health impacts.

6. Phase-Out Plan Of Highly Dangerous Chemicals

a

. Identification of the most hazardous and toxic chemicals.
b

. Mandatory Hazardous & Toxic Chemical Phase

- Out Plan.

7. Public Health & Safety Limits Of All Chemicals Per National Academy of Sciences

a. Mandatory public health exposure limit on all chemicals.
b

. Mandatory public safety limit on all potential hazard scenarios.

8. Public Health Cumulative Risk Assessments

a. Mandatory Health Impact Assessment (HIA) & Public Health Survey to be included in Health Risk
Assessments at every oil refinery

. b. Mandatory Up-Dated Health Risk Assessments every four years.

c. US EPA sponsorshi p of public health research on oil refinery fenceline communities. There is little

to no public health research on US oil refinery communities

. Ban petroleum industry sponsored public health studies

.

9. Current Risk Assessment Deficiencies

a. Mandatory assessment of extra harm and risk to highly vulnerable sensitive receptors such as children

, seniors, pregnant woman, persons with pre-existing health conditions and Environmenta l
Justice Communities.
b. Mandatory inclusion of inhalation risk from all chemicals. Currently excluded arsenic & nickel etc.

c. A Life Time Cancer Risk of 100 in 1 million is not acceptable for any single chemical or cumulative
chemicals.
d

. The USEPA's use of the term I/ degree of uncertainty/' is unacceptable. The USPEA must provide a method or sponsor a research entity to establish the most accurate certainty, based on the best
available scientific research

. The USEPA must incorporate the Precaut i onary Principle when in
doubt.

Coalition For A Safe Environment

1601 N. Wilmi ngto n Blvd., S te .B, Wilmington, CA 90744
JesseN. Marquez jnm4ej @ yahoo.com 310-704-1265

# Overview of the Clean Air Act and the Proposed Petroleum Refinery Sector Risk and Technology Review and New Source Performance Standards

Public Outreach Presentation San Francisco, CA July 1, 2014

U.S. Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park, NC

# Purpose

► 

# Today’s presentation is part of EPA’s overall outreach strategy to stakeholders; today, we will:

► 

# Provide information on the Clean Air Act requirements

► 

# Describe previous EPA regulations done for the refining sector

► 

# Inform the public on Proposed Petroleum Refinery Sector Risk and Technology Review and New Source Performance Standards that were signed by the Administrator on May 15, 2014.

► 

# Note: This presentation is intended to be an educational overview of the proposal and does not cover all of the proposal details. We will **not** be taking comments on the rule during this presentation. However, if you plan to submit comments, please follow the guidelines outlined in the upcoming public/written comment period sections of this workshop.

2

# Overview

► 

# Clean Air Act Requirements

► 

# Overview of the Refinery S ource C ategory

► 

# Refineries Emit a Wide Range of Pollutants

► 

# Health Effects of Specific Pollutants

► 

# HAP Emitted with Existing Controls in Place

► 

# Past Rulemakings on the Refining S ource C ategory

► 

# Overview of Proposed Rule

► 

# Proposed Amendments

► 

# What Does a Residual Risk Analysis Show?

► 

# What is Environmental Justice?

► 

# Demographic Analyses

► 

# Fenceline Monitoring Case Study

► 

# Q&A

3

# Clean Air Act (CAA) Requirements

► 

# New Source Performance Standards (NSPS)

► 

# CAA section 111(b) requires EPA to set and periodically review, emission standards for new sources of criteria air pollutants (CAP), volatile organic compounds (VOC ) and other pollutants

► 

# Maximum Achievable Control Technology (MACT)

► 

# CAA section 112 requires EPA to:



# • S et emission standards for toxic air pollutants from stationary sources reflecting the maximum achievable control technology (MACT) based on the best performing facilities in an industry



# • Conduct r esidual r isk and technology r eviews (RTR) of these MACT standards

4

# Clean Air Act Requirements (cont.)

► 

# EPA is required to conduct two reviews and update the existing standards, if necessary



# • Residual Risk Assessment : To determine whether additional emission reductions are warranted to protect public health or the environment; this is a one

- time requirement



# • Technology Reviews : To determine if better emission control approaches, practices or processes are now available; required every eight years

5

# Overview of Refinery Source Category

► 

# There are currently 142 large (major sources) and 7 small (area source) petroleum refineries in the United States

► 

# There are 36 small businesses that own petroleum refineries

► 

# Refineries are responsible for 20,000 tons per year hazardous air pollutant (HAP) emissions

► 

# In 2011 EPA completed first

- ever comprehensive information collection request

► 

# This proposed rulemaking includes both MACT and NSPS standards

• 

## Risk and Technology Review (RTR) for MACT CC and MACT UUU

• 

## Technical corrections to NSPS Ja resulting from issues raised by API

6

# Refineries Emit a Wide Range of Pollutants

► 

# Criteria Air Pollutants (CAP)

► 

## Sulfur dioxide (SO 2 

## )

► 

## Oxides of Nitrogen (NO X 

## )

► 

## Carbon Monoxide (CO)

► 

## Particulate Matter (PM)

► 

# Volatile Organic Compounds (VOC)

► 

## Organic compounds that are photochemically reactive

► 

# Hazardous Air Pollutants (HAP)

► 

## Carcinogenic HAP, including benzene, naphthalene,1,3

- butadiene, polycyclic aromatic hydrocarbons (PAH)

► 

## Non

- carcinogenic HAP, including hydrogen fluoride (HF) and hydrogen c yanide (HCN)

► 

## Persistent bioaccumulative HAP, including mercury

► 

# Other Pollutants

► 

## Greenhouse gases (GHG)

► 

## Hydrogen sulfide (H 2 

## S)

7

# Health Effects of Specific Pollutants

8 

## Compound Acute Chronic

Benzene Neurological effects,
irritation of the eye, skin and respiratory tract Blood disorders (reduced number of red blood cells and aplastic anemia), cancer

PAHs Skin disorders, depression of the immune system Skin disorders (dermatitis, photosensitization), depression of the immune system, damage to the respiratory tract, cataracts,

cancer

Nickel Damage to the lungs and kidneys, gastrointestinal distress, disfunction of the immune system Dermatitis, asthma like syndrome, decreased lung function, disfunction of immune system, cancer
Hydrogen Cyanide Eye irritation, headaches, confusion, gastrointestinal distress, death Eye irritation, headaches, fatigue, chest pains, nosebleeds

# How much HAP do these sources emit with existing controls in place?

11 Combustion
9%

FCCU
25%

Storage

10%

Wastewater
14% Equipment Leaks
15% Flares

6% Cooling Towers
10% Miscellaneous
11% 

### Petroleum Refinery HAP Emissions: 20,145 TPY

# Past Rulemakings On the Refinery Sector

NSPS

► 

## 1974 NSPS

– covers fuel gas combustion devices, FCCU and sulfur plants

► 

## 2008 and 2012 NSPS

– covers same above and delayed cokers , flares and process heaters specifically



# MACT

► 

## Promulgated 2 MACT standards for refineries

► 

## 1995 MACT (known as MACT 1) covers non

- combustion or evaporative sources, such as equipment leaks, tanks, wastewater, miscellaneous process vents; amended to cover heat exchange systems, including cooling towers

► 

## 2002 MACT (known as MACT 2) covers combustion sources: catalytic cracking units

, catalytic reforming units and sulfur recovery units



# Risk and Technology Review (RTR)

► 

## 2007

– proposed risk and technology r eview amendments for non

- combustion sources

► 

## 2009

– withdrew amendments related to risk review due to insufficient data; amendments promulgated for heat exchanger systems and amended in 2013

10

# Leading Up to this Proposal....

► 

# Finalized flare minimization requirements in NSPS Ja in 2012

► 

# Most refinery flares will be affected in the next few years

► 

# In addition to minimization, requires flow and sulfur monitors on flares

► 

# Recent PFTIR tests indicate reasonable operating envelope for good combustion efficiency for flares

► 

# Peer review in 2012

► 

# ICR effort in 2011 to collect data on

► 

# Processes, Equipment, & Controls

► 

# Emissions Inventories

• D evelopment and public comment on emission estimation protocol CY2010

► 

# Feed (crude oil) sampling characteristics

► 

# Emissions Source Testing

11

# Overview of Proposed Rule

► 

# The EPA is proposing:

► 

# Emission control requirements for storage tanks, flares and delayed coking units at petroleum refineries

► 

# Fenceline standard that sets a benzene action level and monitoring of the fenceline as a development in practices for managing emissions of toxic pollutants from fugitive sources

► 

# To eliminate exemptions during periods of startup, shutdown and malfunction

► 

# Technical corrections and clarifications to the 2008 Petroleum Refinery New Source Performance Standards

12

# Proposed Amendments

► 

# Flares: Establish more stringent operating requirements to ensure good combustion is achieved. These operating requirements will require facilities to:

• Measure & monitor the flow of waste gas going to the flare



# • Measure & monitor the content of the waste gas going to the flare



# • Measure & monitor any air or steam added into the flare



# ► 

# Storage Tanks: Upgrade storage tank controls and lower applicability thresholds

• Upgrade roof deck fitting controls ( gasketed covers for roof openings, sleeve and wipers for guide poles)



## • Require control of tanks >20,000 gal and >1.9 psi or >40,000 gallons and >.75 psi



## • Reference Part 63 Subpart WW and SS (standard s tandards)



# ► 

# Delayed Cokers (DCU): Do not allow emissions to the atmosphere from the steam vent until the drum pressure is below 2 psig (pounds per square inch gauge)

13

# Proposed Amendments

► 

# Fenceline Monitoring:

► 

# Deploy passive monitors surrounding the refinery at the fenceline

► 

# Using 2 week average concentration readings, calculate annual average benzene concentration and compare against action level

► 

# Conduct root cause analysis and corrective action upon exceedances of the action level; 9 μg/m 3

14 

# ► 

# Startup, Shutdown and Malfunction (SSM)

► 

# Propose to remove SSM exemptions and add limits for certain sources during startup and shutdown

► 

# Bypasses and discharges of toxic emissions through pressure relief devices are a violation of standard; requirements to monitor discharges via direct monitoring or monitoring of operating conditions

# What Does a Residual Risk Analysis Show?

15 

# ► 

# Risk deemed to be “acceptable ” under CAA Section 112(f)

► 

# Highest maximum individual risk (MIR) is estimated at 60 in a million (actuals) and 100 in a million ( allowables )

► 

# Sector

- wide population at risk greater than 1 in 1 million is predicted at 5,000,000; Highest MIR driven by equipment leaks from naphthalene and benzene; cancer incidence of 0.3 cases/year driven by PAHs from DCU

► 

# Analysis estimates that m aximum Hazard Index (HI) of 0.9 from HCN from FCCU

► 

# Maximum a cute non

- cancer risk predicted a hazard quotient (HQ) of 5 due to emissions of nickel from FCCU

► 

# Analysis estimates that proposed amendments for DCU and storage tanks result in 1.4 MM fewer people with risks greater than 1

- in

- 1 million and reduce cancer incidence about 18%

# Cancer Incidence By Source By HAP

16 0.000 0.020 0.040 0.060 0.080 0.100 0.120 0.140 0.160 0.180Cancer Incidence (cases per year)

Refinery Source 

## Actuals vs Post

- processed Allowables Cancer Incidence Comparison

Other

Arsenic compounds

Chromium (VI) compounds

Formaldehyde

Ethyl benzene

Ethylene dibromide

1,3

- Butadiene

Benzene

Nickel compounds

2

- Methylnaphthalene

Naphthalene

PAH

# What Is Environmental Justice?

► 

# EPA defines Environmental Justice (EJ) as “the fair treatment and meaningful involvement of all people regardless of race, color, national origin or income with respect to the development, implementation and enforcement of environmental laws, regulations and policies”

► 

# Executive Order **Federal Actions to Address Environmental Justice in Minority**  **Populations and Low**

**- Income Populations**  [E.O. 12898] was signed by President Clinton on February 16, 1994, and calls for federal agencies

“ **to the greatest extent practicable and permitted by**

**law, to identify . . . and address . . . as appropriate, disproportionately high and adverse human health**  **or environmental effects of agency programs, policies and actions on minority populations and**  **low income populations”**

17

# Demographic Analyses

► 

# To determine potential EJ issues, demographic analyses of the minority, low

- income and indigenous populations were conducted

► 

# Percentages of different social, demographic and economic groups within populations living near facilities were compared with total percentages of demographic groups nationwide

18

# Demographic Analysis (cont.)

19 

### Nationwide Population with Cancer Risk at or Above 1

- in

- 1 Million (pre

- controls) Population with Cancer Risk at or Above 1

- in

- 1 Million (post controls) Total Population 312,861,265 5,204,234 3,765,225 Race by Percent White 72 50 49 All Other Races 28 50 51 Race by Percent White 72 50 49 African American 13 28 31 Native American 1 1 1 Other and Multiracial 14 21 19 Ethnicity by Percent Hispanic 17 29 24 Non

- Hispanic 83 71 76 Income by Percent Below Poverty Level 14 21 22 Above Poverty Level 86 79 78 Education by Percent Over 25 and without High School Diploma 15 23 23

Over 25 and with a High School Diploma 85 77 77

*There is no population with a Chronic Hazard Index above 1

# Q&A

20

# Key Issues and Considerations in the Proposed Petroleum Refinery Sector Risk and Technology Review and New Source Performance Standards

Public Outreach Presentation New Orleans, LA June 26

- 27, 2014

Andrew Bouchard U.S. Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park, NC

# Overview

► 

# Refinery Flow Diagram

► 

# Technical Considerations



# • Storage Vessels (Tanks)



# • Flares



# • Delayed Coking Units



# • Fenceline Monitoring

► 

# More Information

22

# Refinery Flow Diagra m

23

# Storage Vessels (Tanks)

► 

# Refinery MACT CC currently requires control of existing storage vessels:

► 

# ≥ 177 m 3 

# (46,760 gallons) by volume

► 

# Stored

- liquid max. true vapor pressure (VP) ≥1.5 psia

► 

# Proposal would change these thresholds to also require control for:

► 

# Smaller tanks (≥20,000 gallons) storing liquids with VP ≥1.9 psia

► 

# Tanks with capacities >40,000 gallons storing liquids with VP ≥0.75 psia

► 

# Proposal also requires additional equipment requirements for tanks with floating roofs

► 

# Guidepole controls

► 

# Fitting controls

► 

# Represents 40% reduction in the baseline emissions for tanks

24

# Flares

25 

## Vent Stream Gas Collection Header

Knockout Drum

Drain Purge Gas



## Liquid Seal Ignition Device

Air Line

Gas Line 

## Flare Tip Pilot Burner



## Stack Seal

Flare Stack To Fuel Gas System



## Flare Gas Recovery Compressor

Steam Line

## Clear flames can cause poor combustion efficiency and emit hydrocarbon and CO pollutants



#  

# Operating range may be tighter

 

# Additional supplemental fuel may be needed Preferred Flame (Luminous color) Black, smoky discharge indicates particulate emissions 

# Flare Operating Envelope

26 Courtesy of John Zink

# Delayed Coking Unit Vent Diagram

27 

## Blowdown Off

- gas Compressor

Steam Blowdown Settling

Drum Blowdown Condenser

Blowdown Tower To Main Fractionator

Coke to Pit To Wet Gas Compressor

Light Slop Oil to Main Frac 

## Coke Drum Steam Vent

Sour Water to Sour Water Stripper

# Delayed Coker Steam Vent

28

# Low cost

sensor networks Different technologies and approaches to detect and measure pollutants over extended areas and time

Mobile inspection systems (GMAP) 

# Monitoring for Assessment of Fugitives

Cost and Feasibility of Widespread DeploymentSpatial and temporal resolution



# Auto GC networks Open

- path optical systems

## N 

# Low

- Cost Sensors C an Provide 24

- 7 Observation and Enable N ew R egulatory Approaches

Facility fenceline monitoring Passive Sampling

• Locate passive samplers around the perimeter of each refinery

• Calculate annual average concentration

• If rolling average concentration exceeds benzene concentration standard (the action level), initiate tiered approach to positively identify facility contribution and conduct corrective action to reduce emissions

# Passive Monitor Locations (FHR, 633, 634 )

Solar Estates (633) FHR Fenceline

Oak Park (634) Inner Harbor (631)

N

31

# Comparison of Passive and Auto GC at Solar Estates (site 633 )

0 100 200 300 400 500 600 700 800 900 1000 1100 1200

0 5 10 15 20 25Benzene Concentration (pptv)



## Sampling Period 633 passive
633 GC

32

## Wi nd Emerging low cost sensors provide a variety of new solutions for 24

- 7 coverage

Fenceline with passive sensors

In

- plant sensor networks

Community monitoring

# More Information

► 

# Consolidated Petroleum Refinery Rulemaking Website

► 

# http:// www.epa.gov/ttn/atw/petref.html

► 

# EPA Contact Information

► 

# Brenda Shine, EPA Office of Air Quality Planning and Standards (919) 541

- 3608 or at shine.brenda@epa.gov

► 

# Andrew Bouchard, EPA Office of Air Quality Planning and Standards (919) 541

- 4036 or at bouchard.andrew@epa.gov

34U.S. Environmental Protection Agency Office of Air Quality Planning & Standards 

### Resources
The links below pro vide more information on the p roposed rule :

Consolidated Petroleum Refinery Rulemaking Repository http://www.epa.gov/ttn/atw/petref.html

Proposed Rule http://www.epa.gov/ttn/atw/petrefine/20140515fr.pdf Fact Sheet http://www.epa.gov/ttn/atw/petrefine/20140515factsheet.pdf



### Submitting Comments
EPA will accept comment on the proposal for 60 days after publication in the Federal Register. Comments, identified by Docket ID No. EPA

- HQ

- OAR

- 2010

- 0682 , may be submitted by one of the following methods:

• Federal eRulemaking Portal: http://www.regulations.gov

- follow the online instructions for submitting comments.

• Email: A

- and

- R

- Docket@epa.gov

- include docket ID No. EPA

- HQ

- OAR

- 2010

- 0682 in the subject line
of the message.

• Fax: (202) 566

- 9744

• Mail: Send your comments to:
Environmental Protection Agency EPA Docket Center (EPA/DC), Mailcode 28221T Attention Docket ID No. EPA

- HQ

- OAR

- 2010

- 0682 1200 Pennsylvania Avenue, NW Washington, DC 20460

• Express mail, commercial delivery, hand delivery or courier: Such deliveries are only accepted during the docket's normal hours of operation, and special arrangements should be made for deliveries of boxed information. Deliver your comments to:
EPA Docket Center, Room 3334 EPA WJC West Building 1301 Constitution Avenue, NW Washington, DC 20004

The public comment period is anticipated to begin on June 30, 2014. Once the public comment period begins, the comment period will remain open for 60 days. 

# Proposed Rule Information

EPA Workshop for Environmental Justice Communities

on Proposed Updates to Emission Standards for RefineriesU.S. Environmental Protection Agency Office of Air Quality Planning & Standards 

### Upcoming Hearings and Events
The EPA will be holding two public hearings on the refineries rule:

• July 16, 2014 , Banning’s Landing Community Center, 100 E. Water Street, Wilmington, CA 90744

• August 5, 2014 , Alvin D. Baggett Recreation Building 1302 Keene Street in Galena Park, TX, 77 547

The hearings be held from 9 AM to 8 PM with a lunch break from 12 to 1 PM and a dinner break from 5 to 6 PM.



### Points of Contact

For questions about the proposed rule

Environmen tal Protection Agency Office of Air Quality Planning and Standards Brenda Shine Phone: (919) 541

- 3608 Email: shine.brenda@epa.gov

To register for the public hearings

Environmen tal Protection Agency Office of Air Quality Planning and Standards Virginia L. Hunt Phone: ( 919 ) 541

- 0832 Email: hunt.virginia@epa.gov

For general questions about the public hearings

Environmen tal Protection Agency Office of Air Quality Planning and Standards Angela Hackel Phone: (919) 541

- 5262 Email: hackel.angela@epa.gov

For questions about facilities in your area

E nvironmental Protection Agency Region 9

, Air Program Mike Bandrowski Phone: (415) 947

- 4194 Email: bandrowski.mike@epa.gov