UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for

EPA ’ s Direct Final Rulemaking

for the California State Implementation Plan

South Coast Air Quality Management District Rule 1114

Petrol eum Refinery Coking Operations

Prepared by: James Shears Reviewed by: Andrew Steckel

October 2014 2



RULE IDENTIFICATION

Agency: South Coast Air Quality Management District

SIP Approved Rule: None

Subject of this TSD: R u le 1114

– Petroleum R efinery Coking Operations

A dopt ed

– May 3 , 2013

Submitted

– February 10, 2014

RULE SUMMARY

– SCAQMD Rule 1114, Petroleum Refinery Coking Operations, i s designed to minimize emissions generated during the delayed coking process by requiring that coke dru m s be depressurized to less than two

p sig prior to venting to atmosphere. Depressurization of delayed coking units to less than five psig is currently required of new refinery coking operations in EPA’s new source performance standard described in 40 CFR 60.103a (c) , “Work Practice Standards”, July 1, 201 1 edition. More stringent d epressurization to less than two psig has been proposed by EPA as described in the Federal Register, “Petroleum Refinery Sector Risk and Technology Review and New Source

Petroleu m Standards; Proposed Rule”, 79 FR 36879 ( June 30, 2014 )

.

SCAQMD regulates the South Coast Air Basin

, which is a n “ extreme ” non

attainment area for the 1

- hour and 8

- hour ozone NAAQS (see 40 CFR part 81).

Rule 1114 is a new rule that is more stringent t han 40 CFR 60.103a(c) , but has equivalent stringency to the EPA

- proposed rule ( 79 FR at 36900 ) for depressurization to less than two psig for appropriately capable or equipped delayed coke units, and include s the following significant provisions :

1. S ection (c) specifies that as of November 1, 2013, the owner or operator of a delayed coking unit shall depressurize each coke drum to less than two psig prior to venting it to atmosphere. As an alternat iv e compliance procedure, the owner or operator of a single coking unit shall be required to depressurize each coke drum to less than five psig until the unit undergo es turnaround and is upgraded after May 1, 2014 or by Decembe r 31, 2016.

F or facilities with multiple delayed coking units

, the facility

- wide average coke drum internal pressure for all the coke drums must be submit ted for the year 2012

. Until turnaround and upgrading is completed between May 1, 2014 and December 31, 2016 , each coke drum, prior to venting to atmosphere, would be depressurized either t o a pressure not to exceed 110% of the 2012 facility

- wide average submitted or to a pressure less than five psig, whichever is feasible. 3



2. Section (d) specifies that, effective November 1, 2013, the owner or operator of a delayed coking unit shall monit or the coke drum pressure and the coke drum atmospheric vent valve position, and record it continuously from feed introduction until atmospheric venting is initiated. If unable to comply with monitoring the vent valve position, the coke drum blowdown

valve position or the temperature of the coke drum vent shall be monitored

until coke drum t urnaround and upgrading is completed . This must occur

between November 1, 2013 and December 31, 2016. The monitoring equipment must be maintained in good operating cond ition except during downtime periods for calibration, maintenance, or repair. The downtime shall not exceed 96 hours per year per coking unit. During downtime, the coke drum pressure and atmospheric vent valve position shall be manually

recorded at five minute intervals beginning 15 minutes prior to atmospheric venting. All monitoring and downtime records shall be kept for at least 5 years and shall be available to the Executive Officer on request (section f).

EVALUATION CRITERIA

- The following criteria were used to evaluate the

submitted rule.

1. E nforceability

- T he 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 evaluate compliance with the CAA § 110(a)(2)(A) requirement for enforceability.

2. Stringency

– CAA §182(b)(2) requires that all areas (including South Coast) which are designated moderate or above nonattainment for national ambient air quality standards (NAAQS) for Ozone, must implement Reasonably Available Control Technology (RACT) for all major sources. Therefore, if there are major sources subject to Rule 1114, the rule should implement R ACT. 40 CFR 60.103a, ( Work Practice Standards

, July 1, 2011

edition ) , and the proposed Petroleum Refinery Sector Risk and Technology

Review and New Source Pet roleum Standards; Proposed Rule

, 79 FR 36879, 36900 ( June 30, 2014 ) were used to help evaluate t he stringency of

Rule 1114

. There are no other state o r local rules concerning coke drum venting pressure requirements

.

3. SIP Relaxation

– Where previous versions of rules have been SIP approved, new submittals must comply with CAA § 110(l) and § 193

rega rding SIP relaxation.

EPA EVALUATION

– The submitted SCAQMD Rule 1114 is more stringent than 40 CFR 60.103a(c) which only requires coke drum depressurization to less than five psig

. Rule 1114 is equivalent in stringency to the EPA

- proposed rule (79 FR

36 900) requiring depressurization to less than two psig for appropriately capable or equipped delayed coking units. This would significantly reduce the emissions 4

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vented into the atmosphere , and is the most stringent such adopted requirement

we are aware of

. Rule 1114 has an alternative compliance process for coke drums only capable of meeting a five psig requirement

, or greater, until they undergo

turnaround and upgrading within the specified time period

. The enforceability of the depressurization process would be substantially enhanced by requiring continuous monitoring of the coke drum pressure and atmospheric vent valve position to ensure that the unit is depressurized to less than two psig when the valve is opened to initiate venting. All monitoring an d downtime records must be kept for at least five years and be available on request.

1. The rule requirements and applicability are clear, and recordkeeping, reporting and other provisions sufficient ly ensure that affected sources and regulators can eval uate and determine compliance with Rule 1114 consistently.

2. The submitted rule is more stringent than 40 CFR 60.103a(c), and equivalent in stringency to the EPA

- proposed rule ( 79 FR 36900)

. As a result, we have determined that this rule fulfils RA CT requirements.

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

with CAA § 110(l) and § 1 93 because (1) the proposed SIP

- approved rule

would not interfere with the on

- going process for ensuring that requirements

for RFP and at tainment of the NAAQS are met, and (2) the requirements in

the submitted rule are more stringent than the existing SIP requirements

.

EPA ACTION

– Th e submitted Rule 1114 improves the SIP and complies with all relevant CAA requirements

. Therefore, EPA sta ff recommends a full approval of

Rule 1114 pursuant to CAA § 110(k)(3)

.

REFERENCES

1. SCAQMD Rule 1114

, Petroleum Refinery Coking Operations, adopted into the SIP on May 3, 2013 and submitted to EPA on February 10, 2014

. 2. 40 CFR 60.103a, Work Practic e Standards, July 1, 2011 edition. 3. Federal Register Volume 79 Number 125, Petroleum Refinery Sector Risk and Technology Review and New Source Petroleum Standards; Proposed
Rule, June 30, 2014.

4

. The Little Bluebook, EPA Region 9, A ugust 2 1, 2001.

5 . The Bluebook, EPA, May 25, 1988

.