UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for

EPA ’s Direct Final Rulemaking

for the California State Implementation Plan

Mojave Desert Air Quality Management Dist rict

Rule 4 64 Oil

- Water Separators

Prepared by: James Shears Reviewed by: Andrew Steckel

February 201 5 2



RULE IDENTIFICATION

Agency: Mojave Desert Air Quality Management District ( MD A QM D )

SIP Approved Rule: Rule 464

– Oil

- Water Separato rs Amended

– August 24, 1994

Submitted

– October 19, 1994 EPA Approved

– September 27, 1995 (60 FR 49772)

Subject of this TSD: Rule 464

– Oil

- Water Separators

Amended

– June 2 3 , 201 4

Submitted

– November 6 , 2014

RULE SUMMARY

–

MD AQMD Rule 464

, Oil

- Water Separators , is designed to limit VOC emissions

from oil

- water separators consistent with EPA design criteria guidance described in the Control Techniques Guidance (CTG) document titled, “Control of Refinery Vacuum Producing Systems, Wastewater Separ ators and Process Unit Turnarounds” (EPA

– 450/2

- 77

- 025). While this CTG states applicability to petroleum refinery sources, Rule 464 does not specify the refinery industry because this industry is non

- existent in the MDAQMD. It applies instead to simila r wastewater separator equipment used in other industries

. To reflect current RACT, Rule 464, as amended, will update the rule applicability, definitions, floating cover seal tolerances, control device efficiency, fugitive vapor leak violation limits, con tainer storage of skimmed oil and tar, recordkeeping, and test

methods

.

MD AQM D regulates portions of Riverside County and San Bernardino County.
Portions of the MDAQMD we re classified as severe nonattainment for the 1997 8

- hour ozone NAAQS (see 40 CFR part 81) . Regarding Rule 46 4, because the

District had an existing SIP rule for this CTG category, the District committed to adopting an updated RACT rule for oil

- water separators as part of its 2006 RACT

SIP. 1

T he following are the significa nt provision s of Rule 464

.

1. Section (A)(2) updates the rule’s applicability to oil

- water separators including air flotation units, and process units or containers used to store

skimmed oil or tar from oil

- water separators. The size limitation for
exempt ed containers has been moved to the exemption section, Section (D).

1 8

- Hour Reasonably Available Control Technology

– State Implementation Plan Analysis (RACT SIP Analysis), August 2006. 3



2. Section (C)(1)(a)(ii) is modified to specify floating cover or double

- deck type cover seal tolerances

.

3. Section (C)(1)(a)(iii) updates the overall control efficiency from 90% to 95%

to m eet RACT

.

4. Section (C)(1)(c) has been added to cover oil or tar skimmed from oil

- water separators charged to process units with feed or transferred to a container with a control system with at least 9 0% control efficiency by weight in order

to meet RACT.

5. Section (C)(3) reduces fugitive leak violations from 10,000 ppm to 500

ppm

.

6. Section s (D)(1)(b) and (D)(1)(c) clarifies t he exemptions for systems collecting less than 760 liters/day or for systems with a RVP of less than 25 mm Hg.

7. Section (F)(4) updates the recordkeeping requirement from 2 years to 5

years

.

8. Section (G)(3)(a) and (c) include s additional test methods

.

EVALUATION CRITERIA

- The following criteria were used to evaluate the

submitted rule.

1. Enforceability

- The Bluebook ( Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations, EPA, May 25, 1988) and the Little Bluebook ( Guidance Document for Correcting Common VOC & Other Rule Deficiencies, ( EPA Region 9, August 21, 2001) were used to help ev aluate compliance with the CAA § 110(a)(2)(A) requirement for enforceability.

2. Stringency

- EPA ’ s CTG titled

, “Control of Refinery Vacuum Producing Systems, Wastewater Separators and Process Unit Turnarounds” (EPA

– 450/2

- 77

- 025 , October 1977 ), and oth er state and local rules for this category were used to help evaluate the RACT requirements of CAA § 182(b)(2) and § 182(f).

3. SIP Relaxation

– Where previous versions of rules have been SIP approved, new submittals must comply with CAA § 110(l) and §1 93 regarding SIP relaxation.

EPA EVALUATION

– The submitted MD AQMD Rule 464 is more stringent than

the CTG and meets RACT requirements

. The overall control efficiency of the oil

water separator vapor control device is increased from 90% to 95% by weight

. A new provision is added that skimmed oil or tar removed from the oil

- water 4



separator transferred to a secondary system shall have a 90% control efficiency by weight. Fugitive vapor leak monitoring now defines a leak at 500 ppm or more instead of 10,000 pp m. More extensive documentation / recordkeeping is now required of all written or machine

- recorded operator inspections, VOC measurements including background levels, source tests, repairs, replacements

and re

- inspections. Alternative test methods are allo wed as long as the methods have been approved by EPA, CARB and the APCO.

1. The rule requirements and applicability are clear, and recordkeeping, reporting and other provisions sufficiently ensure that affected sources and regulators can evaluate and det ermine compliance with Rule 464

.

2. The submitte d rule is as stringent as other air district rules , such as the San Joaquin Valley United Air Pollution Control District Rule 4625 and the South Coast Air Quality Management District Rule 1176

, for this category

, and it is more stringent than EPA ’ s 19 77 CTG. As a result, we have determined that

this rule fulfils RACT requirements.

3. W e propose to determine that our approval of the submittal would comply

with CAA § 110(l) and § 193 because (1) the pro posed SIP revision would

not interfere with the on

- going process for ensuring that requirements for RFP and attainment of the NAAQS are met, and (2) the requirements in the submitted rule are more stringen t than the existing control requirements that they would replace and are approved for the SIP.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION

– The following revision is not currently the basis for rule disapproval, but is

recommended for the next time the rule is amended.

1. Section (G)(3) (a) spe cifies a CARB test method for analyzing halogenated exempt compounds as being ARB Method 22. The correct test method is

ARB Method 422.

EPA ACTION

- The submitted Rule 464 complies with all relevant CAA requirements. Therefore, EPA staff recommends a full approval of Rule 464 pursuant to CAA § 110(k)(3)

.

REFERENCES

-

1. Mojave Desert Air Quality Management District ( MD AQM D )

, “Final Staff Report Proposed Amendments to Rule 464

– Oil

- Water Separators”

, as submitted to the EPA on November 6 , 2014.

2

. S an Joaquin Valley Unified Air Pollution Control District (S JVU AQMD), Rule 4625, “Wastewater Separators”, December 15, 2011. 5



3

. South Coast Air Quality Management District ( SC AQMD), Rule 1176, “VOC Emissions from Wastewater Systems”, September 13, 1996.

4. Bay Area Air Quality Management District (BAAQMD), Regulation 8, Rule 8, “Wastewater Collection and Separation Systems”, September 15, 2004.

5. CTG, “Control of Refinery Vacuum Producing Systems, Wastewater Separators and Process Unit Turnarounds” (EPA

- 450 /2

- 77

- 025, October 1977).

6. The Little Blueb ook, EPA Region 9, August 21, 2001.

7

. The Bluebook, EPA, May 25, 1988.