FROM: Kristine Pelt and Jeff Coburn, RTI International

TO: Brenda Shine, EPA/OAQPS /SPPD

FOR: Docket ID No. EPA

- HQ

- OAR

- 2010

- 06 82

DATE: January 22

, 201 4

SUBJECT: Technology Review for Industrial Wastewater Collection and Treatment Operations at Petroleum Refineries

1. Purpose

This memorandum documents the technology review for wastewater collection and treatment operations. It reviews control alternatives and estimates the costs and environmental impacts for
the alternatives identified.

2. L egislative Background

The Clean Air Act (CAA) requires the EPA to review promulgated standards periodically to

ensure that national emissions standards for hazardous air pollutants (NESHAP) reflect advances in emissions reduction technology. Specifically, s ection 112(d)(6) of the CAA states that “[t]he Administrator shall review, and revise as necessary (taking into account developments in practices, processes, and control technologies), emission standards promulgated under this
section no less often than every 8 years.” This memorandum documents the technology review for wastewater collection and treatment operations at petroleum refineries subject to 40 CFR part 63

, subpart CC (also known as “Refinery MACT 1”)

.

3. Introduction

Industrial wastewater collection and treatment operations range from simple pre

- treatment operations that discharge to publicly ow ned treatment works (POTW) to full

- scale on

- site treatment system s

. Indirect dischargers, or those facilities that discharge wastewater to a POTW, typically collect, store and pretreat the wastewater prior to discharge to a POTW. T he receiving POTW further treats the wastewater to a level acceptable for discharge to a receiving body of
water. Facilities with on

- site full

- scale wastewater treatment operations consist of collection, storage and treatment units that treat wastewater to a level that is acceptable for discharge to a receiving body or for re

- use in the process.

Wastewater collection includes components such as drains, manholes, trenches

, junction boxes,

sumps, lift stations and sewer lines

. Drains are the first component of the collection system and typically channel wastewater to the process sewer line, although drains can route wastewater to sumps, trenches or ditches. Manholes are acc ess points to the sewer line that allow forTechnical Memorandum

– Technology Review for Industrial Wastewater Collection and Treatment Operations at Petroleum Refineries January 22 , 201 4

2 inspection, maintenance, and cleaning of sewer lines. Junction boxes combine wastewater from multiple sewer lines together for transport to the treatment system.

Treatment systems are divided into three categori es: primary, secondary, or tertiary, depending

on the design, operation, and application of the wastewater treatment system. In primary treatment systems, physical operations remove floatable and settleable solids and oil . Typical primary treatment opera tions include equalization basins and oil

- water separators. In secondary treatment systems such as biological treatment units or steam strippers , biological , separation and chemical processes remove most of the organic matter in the waste water. In tertia ry treatment systems, further treatment or filtering of wastewater is done to “polish” the wastewater for discharge to a receiving body of water or reuse in a process.

Wastewater can be stored a t any point in the wastewater collection and treatment system. However, w astewater storage tanks usually collect and store wastewater at the entrance to or exit
from a wastewater treatment unit. Treatment of wastewater does not occur in wastewater storage tank s . Examples of wastewater storage tank s include steam stripper feed, bottoms and overheads
tanks a nd tanks used to store w astewater removed from sludge.

There are currently many federal regulations that have been written to minimize air emissions
from industrial wastewater collection and t reat ment operations, including NESHAP and new source performance standards (NSPS)

. Although m ost of these regulations are fairly consistent
in the control technologies required for industrial wastewater collection and treatment operations, there are significa nt differences in what is included as wastewater and what triggers the need for
control . One of the purposes of this techn ology review is to identify any new or improved technology, monitoring technique or work practice that has not been identified and im plem ented in an existing regulation for the control of emissions from wastewater collection and treatment.

4. Description of Emission Releases

Volatile organic compounds ( VOC ) are emitted into the air from wastewater collection, treatment and storage sys tems that are uncovered or open to the atmosphere through volatilization of organic compounds at the liquid surface. Emissions occur by diffusive or convective means, or both. Diffusion occurs when organic concentrations at the water surface are much hig her than ambient concentrations. The organics volatilize, or diffuse into the air, in an attempt to reach equilibrium between aqueous and vapor phases. Convection occurs when air flows over the water surface, sweeping organic vapors from the water surfac e into the air. The
rate of volatilization is related directly to the speed of the a ir flow ov er the water surface (EPA,
1998 a )

.

Other factors that can affect the rate of volatilization include wastewater surface area in the unit; temperature of the wastewater; turbulence in the unit; wastewater retention time in the unit; the depth of the wastewater in the unit; the concentration o f organic compounds in the wastewater and their physical properties, such as volatility and diffusivity in water; and the presence of a mechanism that inhibits or competes with volatilization, such as an oil film or bio degradation (EPA, 1998 a )

.Technical Memorandum

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3 Emissions c an also occur from covered tanks as a result of temperature or pressure changes when the vapor in the head space of the tank expands and is expelled through a vent or opening in the tank. Emissions from covered tanks also occur when the liquid level in th e tank increases which displaces vapors from within the tank head space through a vent or opening in the tank.

Emissions from Collection Systems

Emission sources within a wastewater collection system differ among facilities, but they generally include drai ns, manholes, trenches, lift stations, sum ps, and/or junction boxes. As water flows through the components of the collection system or in sewer lines directly below
the se components , emissions may occur by volatilization of organic compou nds at any water/ air
interface. E mission modeling of wastewater collection systems suggests that a large portion of
the emissions from wastewater can occur in the collection phase if the system is complex ( i.e.

, has many components) and open to the atmosphere

. Emissions from these wastewater collection systems are essentially fugitive emissions and can occur across a wide area of the facility.

W astewater is introduced into wastewater coll ection systems through drains and these drains are usually connected directly to sewer lines. Drains may be dedicated to a single piece of equipment ( i.e. , a pump) or may serve several sources. Drains are the most numer ous component in the collection system and some refineries can have in excess of 3

, 000 dra ins ( EPA

, 1985)

. Emissions from drains are generally controlled using a water seal that prevents the direct diffusion or flow of gases from the sewer line to the atmosphere. It can be difficult to determine if a drain seal is working properly

, a nd insufficient water levels in a drain seal can allow VOC to be emitted from the drain into the atmosphere.

Junction boxes receive flow from multiple sewer lines. Junction boxes are square or rectangular
and are sized based on the combined flow rate of t he sewers tied into the junction box. Generally, the flow rate from the junction box is controlled by the liquid level in the junction
box. Some junction boxes have water seals at the entrance and exit to prevent emissions from the junction box vent by i solating the junction box from the rest of the drain system

. Emissions occur from a juncti on box when the junction box is uncovered or is cover ed and vented to the atmosphere without the pres ence of water seals . If the water levels in the junction box seals are inadequate, emissions may also occur.

Trenches and sumps are also used at facilities to collect and transport wastewater

. Trenches are typically open to the atmosphere and covered with grates. Trenches can be located in a process
area to receiv e wastew ater directly from a process and wastewater from process equipment pad
runoff due to spills or cleanup; trenches can also be used to transport wastewater from one process area to another or from one treatment unit to another. Sumps are typically u sed to equalize flow from several trenches before treatment and can also receive flow from process sewers. Sumps are also typ ically open to the atmosphere.

Lift stations are usually the last collection component before treatment. Lift stations are simila r to junction boxes in that they receive wastewater from multipl e sewers; however, lift stations are typically larger than junction boxes. Wastewater is typically pumped from a lift station toTechnical Memorandum

– Technology Review for Industrial Wastewater Collection and Treatment Operations at Petroleum Refineries January 22 , 201 4

4 treatment or can be transported hydraulically to treatment. E missions occur from lift stations when the lift station is uncovered or is covered and vented to the atmosphere.

E

missions from Wastewater Storage Tanks

Wastewater storage tanks usually collect and store wastewater at the entrance to or exit from a

wastewa ter treatment unit. Storage tanks are typically quiescent. In cases where these tanks are uncovered, emissions occur through volatilization of organic compounds at the liquid surface through diffusion and convection as described above. If the tank has a fixed

- roof cover vented to the atmosphere, emissions occur as standing and working losses. Standing loss , also known as breathing loss, is the expulsion of vapor from a tank through vapor expansion and contraction, which are the results of changes in tem perature and barometric pressure

. This loss occurs without any liquid level change in the tank (EPA, 2006)

.
The combined loss from filling and emptying is called working loss

. Evaporation during filling operations is a result of an increase in the liquid level in the tank

. As the liquid level increases, the pressure inside the tank exceeds the relief pressure and vapors are expelled from the tank

. Evaporative loss during emptying occurs when air drawn into the tank during liquid removal
becomes saturate d with organic vapor and expands, thus exceeding the capacity of the vapor

space (EPA, 2006 )

.
Emissions from Treatment Systems

The overall objectives of wastewater treatment at refineries are to: (1) equalize flow and pollutant load by buffering flow surge s in large tanks, (2) separate free and emulsified oils and

so lids from the wastewater by oil

- water separators and flotation unit operations ( e.g. , dissolved
air flotation ( DAF ) or induced air flotation ( IAF ) ), and (3) remove organic matter in the wastewater through destruction or biodegradation.

Wastewater treatment tanks (primary treatment) are upstream of removal or destruction systems ( e.g. , steam strippers, biological treatment). Equalization tanks, oil

- water separators, clarifiers,
and flotat ion units (DAF units or IAF units) are examples of wastewater treatment tanks.
Emissions from these tanks are similar to the emissions from wastewater storage tanks. Emissions from open top tanks occur through diffusion and convection and emissions from covered tanks vented to the atmosphere occur as standing and working losses. However, the rate
of volatilization in these tanks can be greater than from storage tanks if the tank is mixed or sparged (DAFs and IAFs) or in the case of oil

- water separators, the rate of volatilization may be less due to the oil layer.

The most common secondary treatment method used at petroleum refineries is biological

treatmen t ( EPA

, 200 4 )

. Biological waste treatment usually is accomplished by aeration in open basins with me chanical surface aerators or with a diffused air system

. Mechanical surface aerators float on the water surface and rapidly mix the water

. Aeration of the water is accomplished through splashing

. Diffused air systems, on the other hand, aerate the water by bubbling oxygen through the water from t he bot tom of the tank or device (EPA, 1998 a ).Technical Memorandum

– Technology Review for Industrial Wastewater Collection and Treatment Operations at Petroleum Refineries January 22 , 201 4

5 The rate of emissions of organic compounds from biotreatment depends on competing mechanisms. Multiple fate and transport mechanisms are often involved in the ultima te removal of a specific compound

. Specifically, biodegradation, volatilization, adsorption, hydrolysis, and photo degradation are common mechanisms in wastewater treatment that may compete against
each other. Emissions from biological treatment operatio ns are also dependent on how well the unit is designed and operated. B iological systems often exhibit an operational lag phase when there is a significant shift in influent concentration or flows, which can cause a shift in the
dominant removal mechanism across the system

.
Units that remove organics from wastewater through destruction are enclosed units and
emissions would or iginate from a s tack ( e.g. , steam strippers ) . Emissions from destructive units are also dependent on how well the unit is designed a nd operated.

5. Identi fication of Control Technologies

Collection Systems

The available technolog ies for collection systems include : 1) covering or enclosing all openings in the drain system and routing all vents to a control device ; or 2) using water seals (applicable primarily for drain s and junction boxes ) to prevent releases from these components

.
The effectiveness of water seals is dependent on how well the water seals are maintained. If the liquid level in the water seal i s low or there is no wat er present in the seal , the control efficiency of the water seal is greatly reduced. Monitoring the seal using EPA Method 21 (an organic vapor analyzer) can be used to determine if emissions are being released from the water seal, suggesting an insufficie nt seal. More frequent monitoring of the seal will ensure that the water
seal is properly maintained (or that an insufficient seal is corrected in a timely manner). As such, the monitoring frequency is expected to impact the overall control efficiency of a water seal control system

.
Covering openings and routing vents to a control device and using water seals a re control technologies that were available during the development of Refinery MACT 1

. No new technologies were identified for the control of emis sions from wastewater collection systems.

Wastewater Storage and Treatment Tanks

No new technologies for the control of emissions from tanks were identified. The available technologies for the control of emissions from tanks includes equipping the tank wi th a fixed

cover, equipping the tank with a fixed roof cover and routing the vent to a control device, or equipping the tank with a floating roof.

Treatment Technology

The most common treatment technology used at refineries for the removal of organics from wastewater is biological treatment. Steam strippers are also used at refineries for the removal ofTechnical Memorandum

– Technology Review for Industrial Wastewater Collection and Treatment Operations at Petroleum Refineries January 22 , 201 4

6 organics from wastewater. A review of other technologies that can be used for the removal or destruction of organics from wastewater revealed no new readi ly available technologies. A list
of the technologies that were reviewed and a summary of the information collected are provided
in Table 1.

Table 1. Summary of Treatment Technologies

Technology Summary of Information
Activated Carbon Adsorption Activated carbon follows treatment in a biological system because carbon usage would be prohibitively high if used as primary treatment. The capacity of the carbon to adsorb compounds at a given inlet concentration varies widel y by compound.

Activated Sludge Activated sludge treatment involves a continuous b iological treatment system utilizing a suspension of aerobic biological growths in wastewater. In an activated sludge process, the wastewater enters an aeration tank where the microorganisms and org anic compounds are mixed together. Diffused a ir or surface aerators are used to keep the process aerobic and to maintain the solids in suspension in the wastewater. A significant portion of biological sludge generate d in the unit is recovered in a clarif ier and recycled back to the influent of the aeration tank to maintain a high concentration of suspended microorganisms

. Activated Sludge Treatment with Powdered Activated Carbon Biological treatment and carbon absorption occur in a single treatment tank

. Carbon absorption occurs on a powdered activated carbon that is recycled with the sludge but a continuous makeup of activated carbon is required.
Air Stripping Air st ripping is used to separate VOC from contaminated water and heating is required to stri p less volatile compounds. Air stripping o nly provides phase separation while destruction i s achieved in biotreatment. Air stripping also r equires destruction of the separated organics, usually using a carbon adsorber or combustion device. High concentr ation systems require a large amount of air which becomes cost prohibitive. Air stripping is m ore applicable to water with dilute concentrations such as contaminated groundwater.

Chemical Oxidation A c hemical reaction occurs between organics and an oxida nt. Chemical oxidation is a c ost effective and viable remediation technology for VOC and petroleum based contaminants in soil, groundwater, and sediments ( i.e.

, low concentration s )

. Chemical oxidation is n ot commonly used in refinery
wastewater treatment plants but is sometimes used as a tertiary treatment step. The capital and operating cost is high at high concentrations

. Applicability depends on the reactivity of the compound

. Ion Exchange Adsorption Ion exchange adsorption is u sed for inorganic compound removal, exchange, or recovery.
Liquid

- liquid Extraction Liquid

- liquid extraction is u sed for compounds distributed between two immiscible liquids, water and an organic liquid. Further treatment is required to destroy organics.
(continued)Technical Memorandum

– Technology Review for Industrial Wastewater Collection and Treatment Operations at Petroleum Refineries January 22 , 201 4

7 Table 1. Summary of Treatment Technologies (continued)

Technology Summary of Information
Liquid Phase Carbon Adsorption Liquid phase carbon adsorption is used to treat contaminated groundwater. It is effective on low concentration streams at any flow rate and effective on high concentration streams at low flow rates (1 gallon per minute ). Streams with oil and grease may f oul the carbon. Costs are high if used as primary treatment of high concentration streams.
Membrane Separation Membrane separation is u sed for gaseous streams with dilute concentrations of VOC.
Sequencing Batch Reactor A sequencing batch reactor involves a eration, sedimentation, and clarification in a single unit. This technology is u ncommon and has lim ited application in wastewater treatment at petroleum refineries

. Steam Stripping Steam stripping is a continuous distillation process that uses steam to remove hydrocarbons from wastewater. A high concentration organic vapor stream leaves the top of the column and a relatively organic

- free water stream from the bottom of the tower can be recycled back to the process. The overhead vapor stream re quires treatment in a unit such as a condenser or combustion unit.
Trickling Filter The b iological material is attached to a filter to which wastewater comes in contact. Microorganisms are attached to a filter rather than being suspended in the wastewate r. This technology is usually u sed as a polishing step.
Vapor Phase Carbon Adsorption Adsorption is a mass

- transfer operation involving interaction between gaseous components and solid

- phase components. The gas phase (adsorbate) is captured on the solid

- phase (adsorbent) surface by physical or chemical adsorption mechanisms. The most common industrial adsorption systems use activated carbon as the adsorbent.

Biological R emoval

B iological treatment is the most widely used wastewater treatment technology for removal of dissolved organic compoun ds in the oil refining industry ( EPA , 200 4 )

. Biological treatment processes can handle a wide ra nge of flows and concentrations. The two primary classes of biological treatment units are suspended

- grow th and attached

- growth systems. Suspended

growth systems maintain the biomass (flocs) in suspension by mechanical or aeration devic es where biodegradation occurs. Examples of suspended

- growth systems include activated sludge, aerated lagoons, sequencing batch reactors, and membrane bioreactors

. Att ached

- growth systems establish biofilms on fixed surfaces whe re biochemical reactions occur. Examples of
attached

- growth sys tems include trickling filters and rotating biological contacto rs

. Regardless
of the type of biological treatment used, the biochemical reactions are generally the same, with the oxidation of organic compounds and ammonia forming new cells, carbon dioxide, and water ( RTI, 2011a ).

An activated sludge process is the most effective of all bi ologi cal treatment systems available.
As state d above, activated sludge is a continuous suspension of aerobic biological growths inTechnical Memorandum

– Technology Review for Industrial Wastewater Collection and Treatment Operations at Petroleum Refineries January 22 , 201 4

8 wastewater. In an activated sludge process, the wastewater enters an aeration tank where the microorganisms and organic co mpounds are mixed together. Air is injected into the mixture to keep the process aerobic and to maintain the solids in suspension in the wastewater.

To maintain the health of the microorganisms and ensure adequate biologically mediated
oxidation of the or ganic compounds and ammonia, oxygen must be introduced into the system

. There are two basic methods for aerating wastewater : (1) introducing air or pure oxygen into the wastewater through diffusers or other devices, and (2) agitating the water to increas e surface area and promote the gaseou s exchange with the atmosphere. However, the mechanisms that increase dissolved oxygen concentration in the water also increase the emission rate of organic
constituents th rough increased volatilization. The volatiliz ation rate can be affected by the wastewater surface area, turbulence, and temperature; hydraulic retention; water depth; concentration and physical properties of the organic constituents ( e.g. , volatility, diffusivity, inhibitory mechanisms); and atmosphe ric conditions.

Steam stripping

S team stripping is a continuous distillation process that uses steam to remove hydrocarbons from wastewater. Compounds with boiling points less than water and compounds with low solubility in water are easily removed. Higher temperatures in steam stripping versus air stripping allow the removal of heavier, more soluble organics that are not stripp able using air. A high concentration organic vapor stream leaves the top of the column and a relatively organic

- free

water s tream from the bottom of the tower can be recycled back to the process. The overhead vapor stream requires treatment in a unit such as a condenser or combustion unit.

Steam stripping is most applicable to treating wastewaters with organic compounds that a re highly volatile and have a low solubility in water. Organic compounds that have low volatility tend to volatilize less readily and thus are not easily stripped out of the wastewater by the steam. Similarly, organic compounds that are very soluble in w ater tend to remain in the wastewater and also are not easily stripped out by steam.

Oil, grease, solids content and pH of a wastewater stream also affect the applicability of steam stripping to a particular wastewater. High levels of oil, grease, and sol ids can cause operating problems for steam strippers. High or low pH may prove to be corrosive to equipment. However, these problems can usually be circumvented by design or wastewat er preconditioning techniques ( EPA, 1992)

.

6

. Model Development

For thi s analysis, we developed seven model facilities , each with different VOC loading rates to the wastewater collection and treatment plant . We also developed a model process drainage area
and series of wastewater treatment processes that are similar for each of the different

- sized
model facilities. We initially used refinery capacity information from the Energy Information Administration ( EIA ) to develop the three model facilities representing the 20 th , 50 th and
80 th percentile crude distillation capacities ( EIA

, 20 09 ) ; we then developed several additionalTechnical Memorandum

– Technology Review for Industrial Wastewater Collection and Treatment Operations at Petroleum Refineries January 22 , 201 4

9 small model facilities (with capacities below the 20 th percentile facilit y and between the 20 th and
50 th percentile facilities ) to capture a series of volatile organic wastewater loading rates

. E ach
model facility was assigned refinery processing units typical of refineries of that size ( EIA

, 20 09 ) . In general, the larger model refineries are more complex ( i.e.

, ha ve more upgrading process units) than the small model refiner ies

. Once processes were assigned to each model facility, w e then used refinery process

- specific wastewater generation rates and benzene and organic HAP concentrations f rom the EPA’s Locating and Estimating Air Emissions from
Sources of Benzene (EPA, 1998 b ) to estimate the total f low rate and flow

- weighted average
benzene concentration and organic HAP concentration for each of the model facilities

. We
assumed that the total organic concentration was 5 times the total HAP concentration ( i.e. , that organic HAP was 20 percent of the total organic load) based on data received in response to the Petroleum Refinery Information Collection Request (ICR) (EPA, 2011)

. Finally, we assumed
that 75 percent of the total organic load would be VOC detectable using EPA Method 25D. The parameters for the seven model facilities are shown in Table 2.

Table 2. Model Facility Flow Rates and Concentrations

Model Facility Model Capacity (bbl/day) a Flow Rate (MGD) a Organic HAP Concentration (ppmw) a Method 25D VOC Concentration (ppmw) a Benz ene Concentration (ppmw) a VOC Load at Generation

(Mg/yr) a

1 7,000 0.029 111 415 17.2 16.6

2 10,000 0.080 124 464 22.1 51.2

3 20,000 0.81 37 139 5.94 156

4A 50,000 1.95 39 146 6.30 394

4B 60,000 1.95 68 254 5.56 686

5 80,000 2.75 65 244 6.81 927

6 215,000 9.26 64 241 5.64 3,086

a bbl/day = barrels per day ; MGD = million gallons per day ; ppmw = parts per million by weight ; Mg/yr = Megagrams
per year.

Our model wastewater collection and treatment system included individual drain system components, an oil

- wat er sepa rator , an air flotation unit , an equalization tank

, and a biological treatment process

. The wastewater collection and treatment system model was based on
informa tion obtained from the EPA’s AP

- 42 ( EPA, 1998 a )

, VOC Emissions from Petroleum Refinery Wastewater Systems

– Background Information for Proposed Standards (“NSPS QQQ BID”) ( EPA, 1985), and the Emissions Estimation Protocol for Petroleum Refineries ( RTI,
2011 a ). For the collection system, w e assumed that each wastewater stream would travel through or under four drains, a manhole, a jun ction box, a sump, and a lift station. The oil

- wat er separator, equalization tank , and air flotation unit are r eferred to as treatment tanks.Technical Memorandum

– Technology Review for Industrial Wastewater Collection and Treatment Operations at Petroleum Refineries January 22 , 201 4

10 Toxic Release Inventory (TRI) data from the year 2000 indic ates that every refinery that was a direct discharger in that year had some type of biological treatment unit (EPA, 200 4 )

. In some control options, our model include d a steam stripper for selected wastewater streams located upstream of the treatment tanks and a biological treatment process downstream of the treatment
tanks

.
We used four surrogate compounds (benzene, phenol, naphthalene, and 1,2

- dichloroethane) to represent the broad range of compounds that are present in wastewater. Th ese compounds were chosen based on their Henry’s Law constant and their biodegradation rates. Phenol has a low Henry’s Law constant and a high biodegradation rate, meaning it does not readily volatilize from water and is easily biodegraded. The Henry’s L aw constant for 1,2

- dichloroethane is high and the biodegradation constant is low meaning it will readily volatilize from water and is not easily biodegraded. The Henry’s Law constant for benzene is high and the biodegradation constant is moderate meaning it will readily volatilize from water, but it will also readily biodegrade. The volatility of naphthalene is between that for phenol and 1,2

- dichloroethane; like benzene, naphthalene is moderately biodegradable, but it also has a fairly large octanol

- wat er partition coefficient, indicating that naphthalene will tend to remain in the oil or organic layer in an organic separation unit (like a decanter or oil

- water separator)

.
For the model plant configuration used, control costs included adding fixed roofs to three treatment tanks, adding a carbon adsorption system control device for one treatment tank and additional piping to vent the other two treatment tanks to the new control device. Additional modeling w ould be needed to address industry

- specific consi derations and pollutants; however, we anticipate that the cost effectiveness of the various control options and applicability thresholds presented for the model wastewater treatment system (and range of chemical compounds in the wastewater) would be repres entative of the cost effectiveness of these control options for most refinery plant wastewater treatment systems.

7. Emissions Estimates

The VOC loading rates determined for the model plants (see Table 2) were equally divided
between the three more volatil e surrogates: benzene, naphthalene, and 1,2

- dic h loroethane. Phenol, which was a surrogate for non

- volatile components (organics not detected well using EPA Method 25D) , was assumed to be present at concentrations equal to the loading rate for one
of the three individual volatile surrogates

. W e estimated total VOC emissions for each of the
model facilities considering the entire wastewater collection and treatment system. We did evaluate certain control requirements individually, b ut we found that, while wastewater collection system controls appeared to be cost effective at very low VOC loads when considering only the drain system , drain controls without subsequent wastewater treatment tank controls merely suppressed the emissions until the wa stewater treatment tanks, and they did not lead to significant emission reductions considering the system as a whole. Therefore, d ue to the interrelationship of the emissions between various components of the wastewater collection and treatment systems

, e missions were estimated from the system as a whole and not from each component of the system independently. Inlet concentrations to a component were adjusted to account for emissions from any upstream component; therefore, emissions or emissionTechnical Memorandum

– Technology Review for Industrial Wastewater Collection and Treatment Operations at Petroleum Refineries January 22 , 201 4

11 reductions were not accounted for more than once. For example, the inlet concentration to the second uncontrolled drain in the drain system accounted for the emissions fr o m the first
uncontrolled drain and emissions from the entire collection system were used to ad just the inlet
mass loa ding to the oil

- water separator , and so on

. C ontrol options that were modeled included:

1. Control of the drain system components only;

2. Control of the drain system components and equipping oil

- water separators, DAF units, and equalizat ion tanks with fixed roofs; and allowing use of open biological treatment processes meeting minimal performance requirements ;

3. Control of the drain system components; equipping oil

- water separators, DAF units, and equalization tanks with fixed roofs that ve nt to a control device; and allowing use of open biological treatment processes meeting minimal performance requirements ;

4. Control of the drain system components; equipping oil

- water separators, DAF units, and equalization tanks with fixed roofs that vent t o a control device; and allowing use of open biological treatment processes meeting specific fraction biodegraded (f bio ) performance requirements;

5. Control of the drain system components; equipping oil

- water separators, DAF units, and equalization tanks wit h fixed roofs that vent to a control device; and steam stripping wastewater streams with VOC concentrations exceeding 750 parts per million by weight (ppmw) prior to using an open biological treatment processes meeting minimal performance requirements; and

6. Control of the drain system components; equipping oil

- water separators, DAF units, and equalization tanks with fixed roofs that vent to a control device; and steam stripping wastewater streams with VOC concentrations exceeding 375 ppmw prior to using an

o pen biological treatment processes meeting minimal performance requirements.

We also considered requirements to upgrade an open biological treatment process that currently only meets minimal performance requirements to a unit that is well

- mixed and achieve s a destruction efficiency of at least 98 percent

. However, this alternative was inferior to the steam stripping option in terms of both costs and emission reductions. A detailed description of the emissions estimates for each of the components in the wa stewater collection and treatment system is provided below.

Emissions from Collection Systems

Emissions from the model collection systems were estimated using t he Refinery Wastewater Emission Tool (RWET) (RTI, 2011b) . RWET is available on the EPA website and is a tool developed as part of the Emission Estimation Protocol for Petroleum Refineries ( RTI , 2011 a ).
Our m odel collection system assumed that each stream would flow through or under four drains, a junction box, a manhole, a sump, and a lift station. The u ncontrolled collection system also
included 20 meters ( 6 5 feet ) of open trench. L arger, more complex refineries will have more drains, sumps, and junction boxes than smaller refineries, generally because a larger refinery hasTechnical Memorandum

– Technology Review for Industrial Wastewater Collection and Treatment Operations at Petroleum Refineries January 22 , 201 4

12 more process units and collection points. However, RWET models a “drainage area,” which identifies the collection system components that an individual wastewater stream typically encounters. A drainage area is fairly consistent for a given process wastewater

, so two model
dra inage area s (one controlled and one uncontrolled) can be used to estimate the emissions from the collection system

. L arger facilities will simpl y have more model drainage areas than smaller
facilitie s.

Emissions from the model drainage area s were estimate d considering each of the collection system components using the predicted fraction emitted (f
e ) from RWET, which is compound and component specific. RWET estimates emissions from controlled collection system components assuming a 95 percent control effic iency of the component’s uncontrolled emissions. Drains and junction boxes can be controlled using water seals

, and well

- maintained water seals can achieve a VOC reduction efficiency of 95 percent (EPA, 1990). Manholes, sumps, trenches, and lift stations are controlled by covering or enclosing openings and routing vented emissions to a control device. Control devices typically achieve a control or destruction efficiency of at least 95 percent.

Table 3 summarizes the model drainage areas and the aggregate fraction emitted for the four surrogate compounds. The emissions for a model plant were determined based on the loading rate of the surrogate compound times the applicable fraction emitted presented in Table 3.Technical Memorandum

– Technology Review for Industrial Wastewater Collection and Treatment Operations at Petroleum Refineries January 22 , 201 4

13 Table 3. Summary of RWET Inputs and Output s for the Model Drainage Areas

Parameter/Description Value for Uncontrolled Model Drainage Area Value for Controlled Model

Drainage Area
Inputs

Number of uncontrolled drains 4 0

Number of sealed drains 0 4
Linear meters of open trench 20 0

Number of uncontrolled manholes 1 0

Number of sealed manholes 0 1
Number of uncontrolled junction boxes 1 0
Number of controlled junction boxes 0 1

Number of uncontrolled lift stations 1 0

Number of controlled lift stations 0 1
Number of uncontrolled sumps 1 0
Number of controlled sumps 0 0
Outputs
Fraction emitted for benzene surrogate 0.783 0.0311
Fraction emitted for naphthalene surrogate 0.610 0.0208
Fraction emitted for phenol surrogate 0.001 5.5E

- 5
Fraction emitted for 1,2

- dichloroethane surrogate 0.696 0.0253

Emissions from Treatment Tanks

Treatment tanks that were part of our model plant included an oil

- water separator followed by an
equa lization tank followed by an air flotation unit. Emissions from these units were est imated using RWET for uncovered oil

- water separators, uncovered equalization tanks, and uncovered
DAF units, respectively. Specific d esign i nputs needed for RWET for these treatment tanks are dependent on flow rate to the unit and are shown in Table 4

. V alues for temperature, pressure, and wind speed were equal to 25 degrees Celsius, 1.0 atmosphere, and 4.47 meters per second. Power to the aerators in the equalization tank was calculated using the equation the equation below (EPA, 1998 a ).

3 ft 1000 75

. 0 hp Power × =

The number of aerators needed in the equalization tank was calculated using the equation below (EPA, 1998 a ).Technical Memorandum

– Technology Review for Industrial Wastewater Collection and Treatment Operations at Petroleum Refineries January 22, 2014

14 75 Power Aerators =

Table 4 . Summary of RWET Inputs for Treatment Tanks

Model Facility :

Flow Rate d Total API a
Surface Area ( m 2 ) d Total DAF b

Surface
Area c ( m 2 ) d DAF b Depth c

( m ) d DAF b Air
Flow c ( m 3 /s ) d Equal Tank Surface Area c ( m 2 ) d Equal Tank Depth c ( m ) d

1: 0.00127 m 3 /s 1.7 0.91 3 4.5×10 -6 22 5

2: 0.0035 m 3 /s 4.57 2.52 3 1.24×10 - 5 61 5

3: 0.035 m 3 /s 45.8 25.2 3 0.000124 605 5

4A: 0.0858 m 3 /s 112 61.8 3 0.000305 1484 5

4B: 0.0858 m 3 /s 112 61.8 3 0.000305 1484 5

5: 0.121 m 3 /s 158 87.2 3 0.000430 2090 5

6: 0.406 m 3 /s 531 292 3 0.00144 7015 5

a American Petroleum Institute (API) separator or oil

- water separator (API, 1990 ).

b DAF or air flotation unit.

c Metcalf & Eddy, Inc., 2003.

d m 3 /s = cubic meters per second ; m 2 = square meters ; m = meters.

Other inputs needed for RWET are the wastewater flow rate and compound concentration. The flow rate inputs were those determined for the seven model facilities (converted from millions of gallons per day (MGD) to cubic meters per second ( m 3 /s) ), and we assumed that there was no
flow loss in the collect ion system. Concentration inputs were determined both for a controlled collection system and an uncontrolled collection system using RWET . RWET was also used to calculate the losses from the wastewater treatment tanks; t he outlet concentration of the oil- water

sep arator was used as the inlet concentration to the air flotation unit and the outlet concentration from the air flotation unit was used as the inlet concentration of the equalization tank.

RWET calculates emissions from open top (uncontrolled) tre atment tanks , but it does not model
emissions from a fixed roof tank. It is assumed that the treatment tanks operate with a continuous inlet and outlet flow rate so they maintain a fairly constant liquid level (minimal working losses). A control efficien cy of approximately 80 percent was expected when adding a
fixed roof to a wastewater treatment tank based on available literature (77 percent efficiency DAFs with fixed roof, 85 percent oil- water separators with fi xed roof (EPA, 1985) ). To model the effect of a fixed roof tank, the overall mass transfer coefficient calculated for the open
treatment tank was adjusted downward so that the emissions of the “fixed-roof controlled” treatment tanks were approximately 20 percent of the emissions from the open treatment tanks. When the overall mass transfer coefficient decreased, the modeled pollutant concentration within the tank increased, so that emission reductions were not linearly correlated with the overall massTechnical Memorandum

– Technology Review for Industrial Wastewater Collection and Treatment Operations at Petroleum Refineries January 22 , 201 4

15 transfer coefficient. We found that an adjustment factor of 0.02 on the overall mass transfer coefficient yielded emissions approximately 20 percent of the uncontrolled case; therefore, to estimate the impact of the fixed roof tank, we multiplied the uncontrolled overall mass transfer
coefficie nt by 0.02, and used this adjusted value to estimate the emissions (and outlet concentrations) from each treatment tank

.
We also used this overall mass transfer coefficient adjustment factor when modeling the control option of equipping treatment tanks wit h fixed roofs vented to a control device ( i.e. , we assumed no forced draft convection or sweep gas was needed for the control device ). The emissions losses from the tanks and the effluent concentrations were not impacted by the addition of a
control devic e on the tank. The control device was assumed to achieve a 95 percent reduction in
the VOC emissions that would have otherwise been emitted from the covered treatment tank

vent.

Emissions from Biological Treatment Processes and Steam Strippers

Emissions f rom biological treatment process were estimated using RWET for uncovered biological treatme nt units with diffused aeration. As with the treatment tanks, the design inputs for RWET are dependent on flow rate ; they are shown in Table 5. Values for temperat ure, pressure, and wind speed were equal to 25 degrees Celsius, 1.0 atmosphere, and 4.47 meters per second. The model biological treatment process was assumed to have a mixed liquor volatile suspended solids (MLVSS) concentration of 2,000 grams per cubic meter ( g/m 3 ) ; this model biological treatment process was expected to be indicative of a moderately performing biounit

. Model runs were also performed assuming MLVSS concentration of 4,000 g/m 3 to project the
emissions for well

- performing biological treat ment process (those meeting a target f bio )

.
The variability in performance in existing biological treatment units can be significant due to ranges in operating and design parameters, such as the biological degradation rate, surface area of the unit, aeration rate, hydraulic residence time, and the a ctive biomass concentration (EPA, 1994) . While the EPA recognizes that many biological treatment units are well

- designed and operated, some units are not properly designed or well

- operated and we wanted to account for
these units in our emissions estimate s and cost impacts.Technical Memorandum

– Technology Review for Industrial Wastewater Collection and Treatment Operations at Petroleum Refineries January 22 , 201 4

16 Table 5 . Summary of RWET Inputs for Biological Treatment

Model Facility:

Flow Rate Depth a ( m ) Surface Area a ( m ) Air Flow a ( m 3 /s ) Wasted Sludge
Flow Rate a ( m 3 /s )

1: 0.00127 m 3 /s 5 4.6 0.0145 0.000033

2: 0.0035 m 3 /s 5 12.6 0.04 0.00009

3: 0.035 m 3 /s 5 126 0.70 0.0009

4A: 0.0858 m 3 /s 5 309 1.0 0.0022

4B: 0.0858 m 3 /s 5 309 1.0 0.0022

5: 0.121 m 3 /s 5 436 1.53 0.003

6: 0.406 m 3 /s 5 1462 5.23 0.01

a Metcalf & Eddy, Inc., 2003.

In all model runs, the inlet concentration to the biological treatment process was assumed equal to the outlet concentration of the equalization tank. The load to the biological treatment process was less for model runs where the drain system and treatmen t tanks were uncontrolled because of losses from these components upstream of the biological treatment unit. We assumed that any remaining volatile compounds in the effluent from the biological treatment unit would eventually volatilize either in subseque nt polishing processes or weirs prior to final wastewater discharge. That is, we did not consider any control of process units downstream of the biological treatment process and used a worst

- case scenario that remaining VOC would be emitted.

A steam strip per was included as part of the wastewater treatment model to determine how
emissions from the treatment system would change if the streams with the highest VOC concentrations were segregated and treated in a steam strippe r rather than the traditional mode l wastewater treatment system (API separator, DAF, equalization tank) prior to treating the wastewater in a biological treatment unit. We modeled two different scenarios for steam strippers. First, we modeled emissions from the model facility assuming al l streams expected to
have a VOC concentration greater th an 750 ppmw at the point of generation were segregated and treated in a steam stripper

. In the second option, w e modeled emissions from the model facility assuming all streams expected to have a VOC concentration greater th an 375 ppmw at the point of generation were segregated and treated in a steam stripper

. The minimum performing steam stripper is expected to achieve VOC removal efficiencies of greater than 98 percent. The total
flow rate and fraction of the total VOC load directed to a steam stripper is dependent on the size
and mix of process units at the model facilit ies

. Table 6 summarizes the flow rates and concentration of VOC streams directed to a steam stripper for each model facility.Technical Memorandum

– Technology Review for Industrial Wastewater Collection and Treatment Operations at Petroleum Refineries January 22 , 201 4

17 Table 6. Summary of Steam Stripper Flows and C oncentration for Model Facility

Model Facility:

Total Flow Rate Targeting Streams greater th an 750 ppmw VOC: Targeting Streams greater th an 375 ppmw VOC:

Flow rate ( gallon/day ) VOC concentration ( ppmw ) Flow rate, ( gallon/day ) VOC concentration ( ppmw )

1: 0.00127 m 3 /s 140 3,150 20,440 540

2: 0.0035 m 3 /s 1,650 6,350 30,650 840

3: 0.035 m 3 /s 13,700 3,450 89,700 990

4A: 0.0858 m 3 /s 27,500 4,080 201,300 1,020

4B: 0.0858 m 3 /s 68,800 4,660 293,800 1,510

5: 0.121 m 3 /s 84,800 4,970 384,000 1,520

6: 0.406 m 3 /s 290,00 0 5,340 1,100,00 1,810

a Metcalf & Eddy, Inc., 2003.

8

. Control Costs

Whenever possible, we obtained current cost data from vendors or fairly recent cost algorithms

. We also collected cost data used for older rules and inflated older costs to 2010 dollars

. We then

compar ed the escalated cost data to newer cost data to verify the validity of the new cost data.

Cost of Control for Collection Systems

Control options for collection systems include covering or enclosing all components and routing vents to a control device, or as an alternative, equipping drains and junction boxes with water seals. For this analysis, we estimated costs for retrofitting d rains and junction boxes with water
seals. Manhole covers can either be gasket sealed and vented to a control device or retrofitted
with a water seal. The cost s for sealing manholes were based on costs provided by Environmental Sealing Systems C o ., Inc. (ESSCO) for a water seal system applicable for large
catch basins and manholes . The cost for controlling lift stations was based on routing one lift
station ven t to a new dedicated carbon adsorber ; additional lift stations, if present, were assumed
to be piped to the new carbon adsorber or other existing control device (ESSCO, 2010)

.

The NSPS QQQ BID ( EPA, 1985 ) has comprehensive data on the cost of retrofitting and installing a new water seal on drains and junction boxes. However, because the data from t he NSPS QQQ BID are from 1985, we collected current data from ESSCO on equipment costs for retrofitting an existing drain, junction box and manhole with water seals. The ESSCO data included the cost of retrofitting drains, junction boxes, and manholes of different sizes with several types of water seal and control configurations (ESSCO, 2010) . We averaged the cost for these variables to estimate the capital cost to retrofit one drain, one junction box, and one
manhole with a water seal. For drains and ma nholes, it was assumed that excavation and installation would take 16 labor hours ( EPA, 1985) and for junction boxes, it was assumed thatTechnical Memorandum

– Technology Review for Industrial Wastewater Collection and Treatment Operations at Petroleum Refineries January 22 , 201 4

18 no excavation was required (the water seal is above grade on junction boxes using the ESSCO technology) and installati on would take 8 hours. An operator labor rate of $ 60.82 was used to calculate the total labor cost of excavation and installation ( Coburn , 2011 ). We assumed that there are no significant annual operating costs associated with water seals aside from annual monitoring costs . If a water seal is found missing during a monitoring event, pouring water down the drain is expected to alleviate this issue

. The cost to retrofit one drain with a water seal from the NSPS QQQ BID escalated to 2010 dollars is $11 6.83 per drain as compared to the cost to retrofit one drain with a water seal using the ESSCO data of $2 75.04 per drain in 2010 dollars

. The cost to retrofit one junction box with two water seals using the ESSCO data was estimated to be $3 42.80 per junct ion box in 201 0 dollars. These capital costs were annualized assuming a
7 percent interest rate and a 10

- year useful life.

We used the crude oil throughput from our seven model plants and data from the California Air
Resources Board (CARB) / Bay Area Air Quality Management District (BAAQMD) ( Dunn and
Breen , 2004 ) to estimate the number of drains, junction boxes and manholes at each model facility. Data from CARB /BAAQMD included comprehensive details for six existing refineries in California, including inf ormation on facility crude oil throughput in barrels per day (bbl/day)

, and the number of drains, junction boxes, and manholes at each facility. We used the
CARB /BAAQMD data to correlate the number of drains at a refinery to refinery throughput in
barrels per day . We then used the CARB /BAAQMD data to correlate the number of drains at a refinery to the number of junction boxes and manholes.

For lift stations, we assumed that a cover was in place and the cost for control was based on routing the vent to an existing control device or to a new carbon adsorber . Because lift stations
can be located in more remote areas of a facility , we assumed a pipe diameter of 2 inches and a pipe length of 200 feet. Cost also included four tees, a flame arrestor, flanges, a blower and a motor ( EPA, 1985). Costs from the NSPS QQQ BID were escalated to 2010 dollars and compared to the piping costs estimated using more recent online tools. The capital cost in 2010
dollars for piping each lift station to a control device was e stimated to be approximately $6

, 200.
We assumed that the three small est model plant s would have one lift station, the three medium

sized plant s would have two lift stations, and our large plant would have three lift stations

. For
facilities with one lift station, w e made the assumption that the lift stations would be vented to a new carbon adsorber. For facilities with two or more lift stations, we assumed a new carbon
adsorber would be added for one of the lift stations and that the emissions from the o ther lift
stations would be pipe d to this single new carbon adsorber

. For our large facility, we assumed a
new carbon adsorber would be added for one of the lift stations and that the other two lift stations would be piped to this single new carbon adsorb er for control. A detailed discussion of carbon adsorber costs is pr esented in the discussion of the cost to control treatment tanks and in
Table 11

.

Table 7 presents the total retrofit control costs for the collection systems for our seven model
facilities.Technical Memorandum

– Technology Review for Industrial Wastewater Collection and Treatment Operations at Petroleum Refineries January 22 , 201 4

19 Table 7 . Summary of Control Costs for Collection Systems

Model Facility # of Drains # of Junction

Boxes # of Man

holes # of Lift Stns Drain Cost ( $/yr ) a Junction Box Cost

( $/yr ) b Manhole Cost ( $/yr ) a Lift Stn Cost ( $/yr )

1 166 26 84 1 $ 4 5 ,700 $8, 9 00 $2 3

, 1 00 $ 24,200

2 237 36 119 1 $ 65,200 $ 1 2

, 3 00 $ 32

, 7 00 $ 27,900

3 473 71 237 1 $ 1 30 ,000 $ 2 4 ,300 $ 65 ,000 $ 36,800

4A 773 116 387 2 $ 213 ,000 $ 3 9

, 8 00 $ 106

, 0 00 $ 53,500

4B 873 131 437 2 $ 2 40 ,000 $ 4 4

, 9 00 $1 20 ,00 0 $ 57,600

5 1073 161 537 2 $ 2 95 ,000 $ 5 5

, 2 00 $1 48 ,000 $ 64,600

6 2423 363 1212 3 $ 666 ,000 $ 1 25 ,000 $ 333 ,000 $ 96,800

a Number of drains/manholes × $2 75.04

b Number of junction boxes × $3 42.80

A 95 percent control efficiency for water seals can only be obtained if the water seals are well

maintained ( i.e. , constantly contain water ) . If the water seals are not maintained, significant emissions could occur. Therefore, part of the cost associated with water seals includes monitoring the seal to ensure the wate r level in the seal is adequate. W e estimated costs for Method 21 monitoring and for visual monitoring at different monitoring intervals, including weekly, monthly, quarterly, semi

- annually, and annual ly. Method 21 capital costs were estimated assum ing that each refinery would have a monitoring instrument but would have to purchase a data collection system. The capital cost also include s the cost for initial tagging and accounting of the water seals

. The cost of the data collection system ($ 14,500 , from Shine, et al.,
2003 ) was divided by the total number of water seals to estimate the cost per seal ($14,500/3

, 300 = $4.39) . The CARB /BAAQMD data was used to estimate the average number of drains and ju nction boxes at a refinery (2500 drains + 400 junction boxes = 3300 total seals, assuming two seals per junction box). A cost for initial tagging and accounting of $ 23.80 per seal was used ( an

u pdate from the value in Eastman Chemical Co, 1999 ). The annu alized capital cost was estimated using an interest rate of 7 percent and a useful life of 10 years. The total annual cost to monitor one water seal equals the annualized capital cost plus an annual labor cost to physically
monitor the water seal. The annual labor cost is $1.50 per water seal for each time the seal is
monitored ( Parrish, 2006 ). For visual monitoring, we assumed that the cost was the same as Method 21 monitoring without the initial cost of the data collection system

.
Monitoring costs at different frequencies are presented in Table 8

. The analysis shows that the Method 21 and visual monitoring costs are fairly equivalent. As some seals may be difficult to inspect visually ( e.g. , seal is underground), Method 21 monitoring is expected to be more effective because a leak can be detected via Method 21 monitoring even though the seal is not directly visible. Given the similarities in costs, we assumed all required monitoring would be performed via Method 21 for the purposes of estimating the total cost of a control requirement.Technical Memorandum

– Technology Review for Industrial Wastewater Collection and Treatment Operations at Petroleum Refineries January 22 , 201 4

20 Table 8 . Summary of Monitoring Costs for Collection Systems

Monitoring Frequency Method 21 Cost per Seal ( $/yr ) a Visual Cost per Seal ( $/yr ) b

Cost to monitor one seal weekly $ 82.00 $ 81.38

Cost to monitor one seal monthly $ 22.00 $ 21.38
Cost to monitor one seal quarterly $ 10.00 $ 9.38

Cost to monitor one seal semi

- annually $ 7.00 $ 6.38
Cost to monitor one seal annually $ 5.50 $ 4.88

a Total capital investment ( TCI ) per seal = cost of new instrument ($ 14,500 /3

, 300) + 1

- time cost for initial tagging and accounting ( $ 23.80 per seal) = $ 28.19 /component. Annualizing these initial costs using a 7% interest rate and a 10 year life, yields an annualized cost for the initial outlays of $ 4.00 /component/year

. Total annu al cost for the monitoring program per seal = $ 4.00 + ($1.50 × number of times monitored per year)

b TCI per seal = cost for initial tagging and accounting ($ 23.80 per seal × 0.142) = $3. 38

. Total annual cost per seal = $3. 38 + ($1.50 × number of times monitored per year)

In an effort to identify an appropriate monitoring frequency for drain components, we assumed that the control efficiency of seals would increase based on the monitoring frequency. We assumed that monthly monitoring o f water seals would allow the water seal controls to achieve
an overall 95 percent control efficiency. Weekly monitoring was assumed to yield a 98 percent control efficiency, while quarterly or semi

- annually would reduce the overall control efficiency

to 90 percent and 80 percent , respectively. The monitoring costs for our 7 model refineries were estimated by applying the costs in Table 8 to the total number of seals at the model refineries.
The total number of water seals at each of the 7 model refineri es was calculated using the total number of drains and junction boxes per model facility shown in Table 7 and applying the fact that each junction box will have 2 seals. Based on this analysis, either quarterly or monthly
monitori ng appeared to be the mos t cost effective monitoring options. The Method 21 monitoring costs for our 7 model refineries for these two monitoring options are shown in
Table 9

. Quarterly monitoring costs are approximately 2 percent of the annualized costs for the drain system cont rols; monthly monitoring costs are approximately 4 percent of the annualized costs for the drain system controls.Technical Memorandum

– Technology Review for Industrial Wastewater Collection and Treatment Operations at Petroleum Refineries January 22 , 201 4

21 Table 9 . Summary of Monitoring Costs for Collection Systems

Model Facility Drain Emissions for Quarterly Monitoring ( tpy ) a Quarterly Monitoring Costs ($/yr) Quarterly Monitoring Cost Effective

ness ($/ ton ) Drain Emissions for Monthly Monitoring ( tpy ) a Monthly
M onitoring Costs ($/yr) Monthly Monitoring Cost Effective

ness ($/ton) Incremental Cost Effective

ness of Monthly Monitoring

($/t on)

1 1.0 $1,6 60 $18 4 0.50 $3,6 50 $38 3 $3,9 70

2 3.1 $2,3 70 $8 5 1.5 $5, 210 $17 7 $1,8 40

3 9.4 $4, 730 $5 6 4.7 $10, 400 $116 $1,20 0

4A 24 $7, 730 $36 12 $ 17.000 $75 $7 80

4B 42 $8, 730 $23 21 $19, 200 $4 9 $50 0

5 56 $10, 730 $21 28 $23, 600 $44 $4 60

6 187 $2 4,200 $14 93 $53, 300 $30 $31 0

a tpy = tons per year.

Cost of Control for Treatment Tanks

Treatment tanks include an oil

- water separator, an air flotation unit, and an equalization basi n;
t he control cost s for treatment tanks include equipping the tanks with a fixed roof and equipping the tanks with a fixed roof and venting emissions to a control device. Costs for both an existing and a new control device were estimated. An alternative control option for a fixed roof vented to a control device is equipping the tank with a floating roof. Due to the presence of weirs, skimmers and mixers on treatment tanks, it is not always easy to configure a floating roof to these types of tanks. Therefore, we chose to u se a fixed roof routed to a control device as the basis of our cost analysis for treatment tanks.

The cost of installing a fixed roof on a treatment tank was calculated by comparing current
vendor data and fixed roof costs from older rules. First, c urrent vendor data for the cost to install
a fixed roof on a new oil

- water separator for several sized separators was used to calculate an

average fixed roof equipment cost of $49 per square foot (Vanderhooft, 2011) . This cost did not
include the ins tallation c ost. Retrofit costs are expected to be 25 to 40 percent higher than new
construction ( EPA, 1985) so the average retrofit cost (installing a fixed roof on an existing tank)
from the vendor data

, assuming a 33 percent (average of 25 percent and 40 percent ) increase
over new construction

, is $65 per square foot. Second, t he NSPS QQQ BID co ntains a range of costs of $11 to $45 per square foot to install a fixed roof on an oil

- water separator (EPA, 1985)

. These costs were expressed in 1985 dollars and include d the labor and installation cost. When inflated to 2010 dollars ( Chemical Engineering Plant Cost Index ( CE index) 1985 = 325.3 and
CE index 2010 = 550.7), the range of cost s to install a fixed roof from the NSPS QQQ BID is $19 to $76 per square foot. Th erefore, f or this analysis, a value of $76 per square foot was used to estimate the cost of retrofitting an open top tank with a fixed roof

, since the more current vendor data ($65 per square foot) did not include the labor and installation cost. We also added aTechnical Memorandum

– Technology Review for Industrial Wastewater Collection and Treatment Operations at Petroleum Refineries January 22 , 201 4

22 fixed cost of $20,000 to the capital costs for the fixed roofs to cover facility planning, vendor selection, and site preparation costs

. (This cost includes approximately 140 technical hours for evaluating rule requirements and control needs, soli citing offers from vendors, and overseeing
installation

. It also includes 140 maintenance hours to prepare the tank for cover installation, including emptying and cleaning the tank, if necessary, and preparing wastewater storage and
flow diversions as nec essary.)

The cost to install a fixed roof on open top treatment tanks from our seven model facilities are
shown in Table 10 . The annualized capital cost was estimated using assuming an interest rate of
7 percent and a useful life of 20 years. Annual operating and maintenance (O&M) costs were estimated at 14 percent of the total capital cost ( PEDCo

, 19 83).

Table 10 . Summary of Cost to Retrofit Open Top Tanks with a Fixed Roof a

Model Facility Oil

- Water Separator Roof Size ( ft 2 ) Equal Tank Roof Size ( ft 2 ) Air Flotation Unit Roof Size ( ft 2 ) Total Capital
Investment ( $ ) b Annualized Capital
Investment ( $ /yr ) c Annual O&M Cost ( $ /yr ) d Total Annual Cost ( $ /yr )

1 18 10 237 $ 40,100 $ 3,800 $ 5,600 $ 9,400

2 49 27 656 $ 75,700 $ 7,100 $ 10,600 $ 17,700

3 506 275 6,596 $ 580,700 $ 54,600 $ 81,300 $ 135,900

4A 1,205 509 12,200 $ 1,079,000 $ 101,000 $ 151,000 $ 253,000

4B 1,205 509 12,200 $ 1,079,000 $ 101,000 $ 151,000 $ 253,000

5 1,700 936 22,400 $ 1,923,000 $ 181,000 $ 269,000 $ 450,000

6 5,700 3,140 75,400 $ 6,425,000 $ 604,000 $ 899,000 $ 1,503,000

a See Table 4 for model plant tank sizes. Sizes were converted from square meters (m 2 ) to square feet (ft 2 ) for this table.

b Total roof size ft 2 × $76/ft 2 + $20,000

c Annualized capital investment = TCI × capital recovery factor ( CRF ) (CRF = 0.094, 7%, 20 years useful life)

d Taxes, insurance and administrative cost = 4% of capital cost; O&M cost =10% of capital cost ( PEDCo , 1983 ).

The cost of routing the vent on a fixed roof treatment tank to a control device was estimated for both routing the vent to an existing control device and routing the vent to a new, dedicated control device. The cost of routing the vent on a fixed roof tr eatment tank to an existing control device consists mainly of piping costs. Piping costs to an existing control device were estimated
for lift stations

, and we assumed that the piping costs for routing treatment tanks to a control device would be comparab le to that of lift stations ( $6

, 200 per tank )

.
A new carbon adsorption system was used as the basis for estimating the control emissions from treatment tank vents. Due to the variability in the concentration of wastewater, it is difficult to
estimate the concentration of organics in the headspace of treatment tanks. With regards to calculating a control device cost in the NSPS QQQ BID for treatment tanks, the VOCTechnical Memorandum

– Technology Review for Industrial Wastewater Collection and Treatment Operations at Petroleum Refineries January 22, 2014

23 concentration and flow rate of gas from an oil- water separator were estimated to be
880 milligrams per liter and 300 standard cubic feet per minute ( scfm ) , respectively. These
values wer e also used for this analysis and are expected to be most representative of the flow
from the median -sized (80,000 bbl/day) refinery. The Air Compliance Advisor software ( EPA,
2003 ) was used to estimate the cost of various carbon adsorption control systems; these c osts are presented in Table 11.

Table 11 . Cost s of a 300 scfm Carbon Adsor ption System

Equipment Type Capital Cost ( 2008$ ) Annualized Capital Cost ( 200 8 $/yr ) a Annual Operating & Maintenance Cost ( 2008 $/yr ) Total Annual ized Cost ( 2008 $/yr ) Total Annual ized Cost ( 2010 $/yr ) b

2- Bed CA 95% $60,700 $5,710 $60,300 $66,000 $63,200

2- Bed CA 98% $60,700 $5,710 $59,900 $65,600 $62,800

3

- Bed CA 95% $66,200 $6,220 $61,300 $67,500 $64,600

3

- Bed CA 98% $66,200 $6,220 $60,900 $67,100 $64,300

a Annualized capital investment = TCI × CRF (CRF = 0.094, 7%, 20 years useful life)

b Chemical engineering cost index for 2008 = 575.4 and for 2010 = 550.7.

Based on the costs presented in Table 11, a representative capital investment cost of $60,000 and an annualized cost of $64,000 per yr w ere used for a basic carbon adsorption system for the 80,000 bbl/day refinery. Carbon adsorption system costs for other model facilities were estimated using the following power function for both the capital and annualized costs.

4.0



### 80,000 X Throughput

× Plant bbl/d 80,000for Cost = X Throughput Plant Model for Cost      

Each model plant was assumed to have to control each of the three treatment tanks. We assumed that one treatment tank would install a new carbon adsorption system and that the other two tanks would be piped to this new carbon adsorption system. Therefore, each model plant was assumed to incur the costs of one carbon adsorption system and the costs of piping two treatment

ta nks to an “ existing ” control device.

Cost of Upgrading and Monitoring Biological Treatment Processes

Control costs were developed for upgrading an existing biological treatment unit by adding
50 percent additional flow capacity to an existing biological treatment unit if the design of the existing unit is such that it cannot meet the specified f bio

. The capital cost of the wastewater treatment system capacity expansion was estimated using CapdetWorks Version 2.5 (Hydromantis, 2007 ) for a system designed to process 50 percent of the total refinery wastewaterTechnical Memorandum

– Technology Review for Industrial Wastewater Collection and Treatment Operations at Petroleum Refineries January 22 , 201 4

24 flow. The annualized capital cost was calcul ated using an interest rate of 7 percent and a useful life of 20 years. The cost of upgrading th e biological treatment unit for the model facilities is presented in Table 12

. Costs to build a new unit biological treatment unit to handle 100 percent of the refinery wastewater flow are approximately 65 percent higher than the upgrade costs
identified in Table 12

. Costs to build a new biological treatment system may be incurred for refineries that currently send the ir waste water off

- site for biological treatment and the off

- site facility elects to no longer accept the waste water due to the added f bio control requirements.
Nonetheless

, it was assumed that upgrade costs (increasing the capacity of the biological treatment unit by 50 percent) would generally apply for facilities needing to improve their biological treatment unit in order to meet a specific f bio

. Having to meet a specific f bio requirement would also require facilities to perform and initial performance demonstration and may also require additional parameter monitoring. For the model plant assessment of the option to require a specific f bio , it was assumed that these costs were negligible compared to the costs of upgrading the biological treatment unit.

Table 12 . Cost to Upgrade a Biological Treatment Unit

Model Facility Capital Cost ($) a O&M Cost ($/yr) a Annualized Capital Cost ($/yr) b Total Annual Cost ($/yr)

1 $536,000 $11,000 $50,000 $61,000

2 $1,124,000 $26,000 $106,000 $132,000

3 $6,090,000 $186,000 $572,000 $759,000

4A $11,608,000 $396,000 $1,091,000 $1,487,000

4B $11,608,000 $396,000 $1,091,000 $1,487,000

5 $14,864,000 $528,000 $1,397,000 $1,925,000

6 $36,061,000 $1,485,000 $3,390,000 $4,875,000

a EPA, 1980 , escalated to 2010 $.

b Annualized capital investment = TCI × CRF (CRF = 0.094, 7%, 20 years useful life)

Cost of Control for Steam Strippers

The cost of the steam stripper was based on algorithms developed for the National Emission Standards for Organic Hazardous Air Pollutants from the Synthetic Organic Chemical Manufacturing Industry for Process Vents, Storage Vessels, Transfer Operations, and
Wastewater ( HO N ) (Pelt, 1994) . S team stripper cost is dependent on the total flow rate to the steam stripper. The t otal cost of the steam stripper includes an air emissions control device which was assumed to be an existing combustion device. Piping cost to the exist ing control device is included in the HON algorithm.

As described previously, each model plant has a slightly different mix of process units, and therefore different proportion of different strength ( i.e. , VOC concentration) wastewater streams. Table 6 pr esented the projected flow rate and average VOC concentration for each model plantTechnical Memorandum

– Technology Review for Industrial Wastewater Collection and Treatment Operations at Petroleum Refineries January 22, 2014

25 based on VOC thresholds of 375 and 750 ppmw. These data were used as inputs to estimate the steam stripper costs for each model plant/concentration threshold combination. The July 1989 costs in the HON algorithm were escalated to July 2010 using the cost index for specific equipment types ( e.g. , pumps and heat exchangers) and using the overall cost index for plants. The estimated steam stripper costs are presented in Table 13.

Table 13 . Steam Stripper Control Cost Estimates (2010$)

Model Facility 750 ppmw VOC Threshold Option 375 ppmw VOC Threshold Option

Total Capital
Investment ($) Annual O&M Costs ($/yr) Total Annualized Cost a ($/yr) Total Capital
Investment ($) Annual O&M Costs ($/yr) Total Annualized Cost a ($/yr)

1 $290,000 $113,000 $145,000 $794,000 $167,000 $254,000

2 $446,000 $122,000 $171,000 $895,000 $188,000 $286,000

3 $711,000 $153,000 $231,000 $1,289,000 $301,000 $443,000

4A $866,000 $182,000 $277,000 $1,883,000 $509,000 $716,000

4B $1,171,000 $262,000 $391,000 $2,231,000 $676,000 $921,000

5 $1,263,000 $292,000 $431,000 $2,634,000 $841,000 $1,130,000

6 $2,219,000 $670,000 $913,000 $5,060,000 $2,116,000 $2,671,000

a Total Annualized Cost = TCI × CRF + A nnual O&M

, where CRF = 0.094 based on 7%, 20 years

.

9. Impact Estimates for Industrial Wastewater Treatment Plants

Emission and cost i mpacts we re estimated for each of the six options presented in Section 7 considering the entire wastewater collection and treatment plant. The emissions for each of the
six options were compared to a totally uncontrolled wastewater collection and treatment plant (“ baseline ”) to obtain the emission reductions for that option. A brief summary of the six control options are summarized in Table 14 for easy reference.

The environmental and cost impacts for each model facility for each control option are shown in
Table 15 . Overall, each of the options is more cost effective as the size of the facility increases. Controlling only the collection system is not a viable option because it only suppresses emissions to the treatment tanks where most of the volatile compounds will be emitted if these tanks remain uncontrolled. Controlling the collection system and the treatment tanks is also a more cost effective option than controlling the collection system alone

. Controlling the collection system and covering and controllin g the wastewater treatment tanks was always the control option with the lowest overall cost per ton of VOC reduced regardless of the size of the model plant facility.Technical Memorandum

– Technology Review for Industrial Wastewater Collection and Treatment Operations at Petroleum Refineries January 22, 2014

26 Table 14

. Control Options for Model Wastewater Treatment Plants

Control Option Control Option Description

Baseline Uncontrolled drains and treatment tanks

1 Control of the drain system components only

2 Control of the drain system components and equipping oil

- water separators, flotation units, and equalization tanks with fixed roofs

3 Control of the drain system components; equipping oil

- water separators, flotation units, and equalization tanks with fixed roofs that vent to a control device

4 Control of the drain system components; equipping oil

- water separators, flotation units, and

e qualization tanks with fixed roofs that vent to a control device; and requiring open biological treatment processes to meet a specified f bio
.

5 Control of the drain system components; equipping oil

- water separators, flotation units, and equalization tanks with fixed roofs that vent to a control device; and steam stripping wastewater streams with VOC concentrations exceeding 750 ppmw

6 Control of the drain system components; equipping oil

- water separators, flotation units, and equalization tanks with fixed roofs that vent to a control device; and steam stripping wastewater streams with VOC concentrations exceeding 375 ppmw

Table 15 . Impacts for Control Option s for Each Model Facility

Control Option Emission Reduction ( tpy ) Total Capital
Investment C ost ( $/yr ) Total Annualized Cost ( $/yr ) Cost Effectiveness

( $/ton VOC ) Incremental Cost Effectiveness ( $/ton )
Model Plant 1: 16.6 Mg/yr VOC wastewater generated; 9.0 Mg/yr VOC load for Option 1

Baseline 0 Baseline Emissions = 16.4 tpy (14.9 Mg/yr)

1 3.2 $5 70,000 $ 105 ,5 00 $3 3,1 00 $3 3,1 00

2 8.4 $ 610,000 $115,000 $1 3 ,700 $1,800

3 11.5 $ 637 ,000 $13 9 ,000 $1 2

, 2 00 $8,000

4 13.2 $960,000 $175,000 $13,300 $21,100 1

5 11.7 $ 928 ,000 $2 85 ,000 $2 4

, 4 00 $751,100 1

6 15.3 $1,597,000 $394,000 $25, 7 00 $29,600 1

Model Plant 2: 51.2 Mg/yr VOC wastewater generated; 26.2 Mg/yr VOC load for Option 1

Baseline 0 Baseline Emissions = 50. 8 tpy (46.1 Mg/yr)

1 9.3 $ 803 ,000 $1 43 ,000 $1 5

, 4 00 $1 5

, 4 00

2 25.1 $ 8 78 ,000 $1 61 ,000 $6, 4 00 $1,100

3 36.2 $ 910,000 $189,000 $5,2 00 $2,500

4 41.1 $1,588,000 $267,000 $6,500 $16,100 1

5 40.5 $1,355,000 $360,000 $8, 9 00 $39,800 1

6 46.0 $1,805,000 $476,000 $10, 3 00 $20,800 1

(continued)Technical Memorandum – Technolog y Review for Industrial Wastew ater Collection and Treatment Operations at Petroleum Refineries January 22, 2014

27 Table 15. Impacts for Control Option for Each Model Facility (continued)

Control Option Emission Reduction (tpy) Total Capital
Investment Cost ($/yr) Total Annualized Cost ($/yr) Cost Effectiveness

($/ton VOC) Incremental Cost Effectiveness ($/ton)
Model Plant 3: 156 Mg/yr VOC wastewater generated; 69.5 Mg/yr VOC load for Option 1

Baseline 0 Baseline Emissions = 156 tpy (142 Mg/yr)
1 26.5 $1,580,000 $267,000 $10,100 $10,100
2 89.7 $2,160,000 $402,000 $4,500 $2,100
3 134.8 $2,200,000 $440,000 $3,300 $830
4 144.1 $5,872,000 $888,000 $6,200 $48,200 1

5 142.1 $2,910,000 $671,000 $4,700 $31,900 1

6 145.8 $3,490,000 $883,000 $6,100 $56,100 1

Model Plant 4A: 394 Mg/yr VOC wastewater generated; 178 Mg/yr VOC load for Option 1

Baseline 0 Baseline Emissions = 395 tpy (358 Mg/yr)
1 66.2 $2,580,000 $429,000 $6,500 $6,500
2 227.0 $3,660,000 $682,000 $3,000 $1,600
3 338.5 $3,720,000 $736,000 $2,200 $480
4 363.6 $10,720,000 $1,613,000 $4,400 $35,000 1

5 356.2 $4,590,000 $1,010,000 $2,800 $15,700 1

6 366.8 $5,600,000 $1,452,000 $4,000 $41,200 1

Model Plant 4B: 686 Mg/yr VOC wastewater generated; 309 Mg/yr VOC load for Option 1

Baseline 0 Baseline Emissions = 687 tpy (623 Mg/yr)
1 115.1 $2,910,000 $482,000 $4,200 $4,200
2 362.3 $3,990,000 $682,000 $1,900 $810
3 556.2 $4,060,000 $793,000 $1,400 $570
4 620.4 $11,060,000 $1,670,000 $2,700 $13,700 1

5 632.3 $5,230,000 $1,183,000 $1,900 $5,100 1

6 644.1 $6,290,000 $1,714,000 $2,700 $45,000 1

Model Plant 5: 927 Mg/yr VOC wastewater generated; 416 Mg/yr VOC load for Option 1

Baseline 0 Baseline Emissions = 927 tpy (841 Mg/yr)
1 158.0 $3,570,000 $586,000 $3,700 $3,700
2 492.1 $5,500,000 $1,036,000 $2,100 $1,300
3 755.1 $5,570,000 $1,101,000 $1,500 $250
4 839.9 $14,530,000 $2,236,000 $2,700 $13,400 1

5 852.2 $6,830,000 $1,532,000 $1,800 $4,400 1

6 868.2 $8,200,000 $2,232,000 $2,600 $43,900 1

(continued)Technical Memorandum

– Technology Review for Industrial Wastewater Collection and Treatment Operations at Petroleum Refineries January 22, 2014

28 Table 15. Impacts for Control Option for Each Model Facility (continued)

Control Option Emission Reduction ( tpy ) Total Capital
Investment Cost ($/yr) Total Annualized Cost ($/yr) Cost Effectiveness

($/ton VOC) Incremental Cost Effectiveness ($/ton)
Model Plant 6: 3,086 Mg/yr VOC wastewater generated; 1,377 Mg/yr VOC load for Option 1

Baseline 0 Baseline Emissions = 3,089 tpy (2,802 Mg/yr)

1 525.6 $8,020,000 $1,274,000 $2,400 $2,400

2 1,640.4 $14,450,000 $2,778,000 $1,700 $1,300

3 2,523.8 $14,560,000 $2,874,000 $1,100 $110

4 2,801.2 $36,300,000 $5,741,000 $2,050 $10,300 1

5 2,856.6 $16,780,000 $3,788,000 $1,300 $2,700 1

6 2,894.6 $19,620,000 $5,546,000 $1,900 $46,200 1

1 The incremental cost

- effectiveness of Options 3 and 4 are calculated relative to Option 3; the incremental cost

effectiveness of Option 6 is calculated relative to Option 5.

10. Current Control Levels Under the Benzene NESHAP

Emissions from wastewater collection and treat ment operations at refineries are currently regulated under the Benzene Waste NESHAP Operations (BWON)

. In general, the BWON requires control of wastewater collection and treatment units for facilities with a total annual
benzene ( TAB ) of greater than or equal to 10 megagrams per year (Mg/yr). Individual w aste streams at refineries with a TAB greater than or equal to 10 Mg/yr are exempt from control if the
flow -weighted annual average benzene concentration is less than 10 ppmw or the f low rate is
less than 0.02 liters per minute at the point of generation. Because benzene is in nearly all refinery wastewater streams, the model plant analysis suggested that 96 to 100 percent of the HAP loading to the wastewater treatment system would be captured under these BWON stream

specific threshold levels . Therefore, for refineries with tab greater than or equal to 10 Mg/yr, the BWON control provisions are essentially equivalent to Control Option 3 (requiring suppression controls up to a biological treatment unit). For refineries with a TAB of less than 10 Mg/yr, the baseline (uncontrolled) scenario would best project the potent ial (allowable) emissions for these
facilities.

In the BWON, the biological treatment system must meet the criteria of an “enhanced biological unit (EBU)” ( i.e. , an activated sludge treatment unit) or, as an alternative to meeting the criteria
of an EBU, a ffected wastewater streams are required to be treated using a steam stripper or other control device that achieves a 98 percent removal of benzene. Refinery MACT 1 provides identical applicability thresholds to the BWON and references the BWON control requirements. There are very limited requirements for an EBU in the BWON, so the biodegradation efficiency of the EBU may vary widely between different facilities

. Some facilities are expected to have
well -performing EBU (emissions equivalent to Control Opt ion 4) while other facilities may have emissions more similar to those in Control Option 3.Technical Memorandum

– Technology Review for Industrial Wastewater Collection and Treatment Operations at Petroleum Refineries January 22 , 201 4

29 Based on the existing requirements in the BWON (and in Refinery MACT 1), we identified the following “nationwide (NW) control options” (not to be confused with the “model plant” control options previously discussed:

1. Requiring wastewater drain and tank controls at refineries with a total annualized benzene quantity of less than 10 Mg/yr.

2. Requiring specific performance parameters (minimum f bio ) for an EBU beyond those required in the BWON.

3. Requiring wastewater streams above a VOC content of 750 ppmv to be treated by steam stripping prior to any other treatment process for facilities with high organic loading rates ( i.e.

, facilities with TAB of 10 Mg/yr or more)

.
Option 1 was evaluated because refineries with TAB of less than 10 Mg/yr are not required to install any controls on their wastewater treatment system. Option 2 is intended to improve the performance of wastewater treatment systems that use an EBU, and thereby a chieve additional
emission reductions

. Option 3 considers segregated treatment of high strength wastewater streams directly in a steam stripper ( i.e. , not allowing these streams to be mixed and treated in the EBU)

. For the most part, the options are inde pendent of each other, so the costs and cost effectiveness of each these options are considered separately

. In fact, NW Option 3 could be considered an alternative means to limit the use of potentially poor

- performing EBU compared to NW Option 2.

11. Esti mating Nationwide Impacts for Petroleum Refineries

The first step in developing nationwide impact estimates was to estimate the TAB and HAP loading for each of the refineries in the U.S. The process unit cap acities as reported in the
2009 Refinery Capacit y Report (EIA

, 2009) was used together with the factors presented in the
EPA’s Locating and Estimating Air Emissions from Sources of Benzene (EPA, 1998b) to estimate the organic HAP loading and projected VOC loading to the wastewater treatment system for each refinery. Each refinery was then assigned to a model plant based on the total VOC loading. Table 1 6 shows the estimated TAB (benzene loading) and VOC loading for each
of the seven model facilities and how the ranges used to assig ning the model plants to the
facilities . There were no refineries that had projected VOC loadings between 400 and
800 Mg/yr, so the model plant assignments were shifted slightly to provide a mix between model
facilities 4 A and 4B

.

As shown in the table, the t wo smallest model facilitie s have a TAB of less than 10 Mg/yr. Refineries assigned to these model plants would not require control under the BWON based on
the calculated TAB , and these facilities were all assumed to be uncontrolled for the NW baseline
emi ssion estimate

. Under NW Option 1, these refineries would be required to meet the “model plant” Control Option 3 (costs for which are summarized in Table 15).Technical Memorandum

– Technology Review for Industrial Wastewater Collection and Treatment Operations at Petroleum Refineries January 22, 2014

30 Table 16 . Benzene and VOC Load for Model Facilities and Assignments of Model Facilities to Spec ific Refineries

Model Facility Benzene Load at Generation

(Mg/yr) VOC Load at Generation

(Mg/yr) Assigned if Refinery VOC Loading (Mg/yr)

was: Number of Refineries Assigned to Model Plant

1 2.62 16.6 VOC < 50 18

2 9.22 51.2 50≤VOC<80 9

3 24.8 156 80≤VOC <250 15

4A 63.9 394 250≤VOC<300 30

4B 56.0 686 300≤VOC<800 9

5 97.1 927 800≤VOC<2000 42

6 271 3,086 VOC > 2000 19

It is unclear what the actual performance level of refinery EBU are, given the lack of specific operating or performance limits

. For the baseline analysis, we assumed that 80 percent of the refineries assigned to model facilities 3 through 6 had EBU performance comparable to “model plant” Control Option 4, while 20 percent had performance comparable to “model plant” Control Option 3. Therefore, under NW Option 2, 20 percent of the refineries with TAB greater than
10 Mg/yr were projected to need to upgrade their EBU (incremental costs as provided in
Table 12, since these facilities are already expected to have controlled drains and tanks ). Although some refineries currently use steam stripping for certain waste streams, we assumed all refineries would have to add a steam stripper in order to comply with Option 3 (incremental costs as provided in Table 13, since these facilities are alrea dy expected to have controlled drains and tanks).

Based on these assumptions and the number of each model plant (as provided in Table 16), the projected baseline emissions and impacts for the NW options were calculated. These impacts are
summarized in Tab le 17.

Table 17. Nationwide Impacts of Wastewater Control Options for Petroleum Refineries

Control Option Capital Cost (million $) Annual ized Costs (million $/yr) Emis sions Reduction, VOC (tpy) Emis sions Reduction, HAP (tpy) Cost Effec

tive ness ($/ton VOC) Cost Effec

tive ness ($/ton HAP)

Baseline Baseline Emissions: 13,865 tpy VOC and 3,697 tpy HAP

NW 1 19.7 4.2 592 1 58 7, 10 0 26, 6 00

NW 2 22 3 28. 6 2, 06 0 5 49 13,900 52, 1 00

NW 3 14 2 50. 7 3,480 929 14, 50 0 54, 5 00Technical Memorandum

– Technology Review for Industrial Wastewater Collection and Treatment Operations at Petroleum Refineries January 22 , 201 4

31 The cost effectiveness for NW Option 1 (requiring wastewater controls for the small refineries with a TAB less than 10 Mg/yr) is approximately $2 6

, 6 00 per ton of HAP reduced. NW Option s 2 and 3 are each projected to have cost effectiveness over $50,000 per ton of HAP
reduced

. Based on this technology review, t h e BWON control requirements appear to be the

most cost

- effective control requirements. We did not identify any development in technologies or practices that would cost

- effectively reduce HAP emissions from wastewater treatment systems at petroleum refineries beyond the existing requirements in Refinery MACT 1 ( i.e.

, BWON)

.

1 1

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