August 5, 2014 

EPA Docket Center 

William Jefferson Clinton West Building 

Attention: Docket ID Number EPA-HQ-OAR-2010-0682 

U.S. Environmental Protection Agency 

Mail-code 28221T 

1200 Pennsylvania Avenue, NW 

Washington, D.C. 20460 

Dear U.S. Environmental Protection Agency (EPA), 

Enclosed are my personal comments about the Petroleum Refinery Sector Risk and 

Technology Review and New Source Performance Standards (air quality), 40 Code of 

Federal Regulations (CFR), Parts 60 and 63. 

1) Page 116 of 813, I agree that direct atmospheric releases from decoking units (DCU) 

are unregulated emissions, must be regulated, and the emissions must be reduced. A 

common thread throughout this discussion, but never stated, is that decoking 

units are archaic and obsolete. The EPA must encourage the refinery industry to 

conduct research to develop a continuous decoking operation where emissions 

can be more easily reduced or captured. The current, slow, discontinuous, air 

pollution generating process requires de-heading, draining, coke cutting, and 

depressurization that should be conducted in an enclosed system where air 

pollutants are either recycled or captured and destroyed. 

2) Page 135 of 813, I support adding a requirement that a visible emissions test be 

conducted each day and whenever visible emissions are observed from a flare. I also 

agree that any time there are visual emissions from a flare that another 5 minute visible 

emissions observation period must be performed and that if visible emissions are 

observed for greater than one continuous minute that the monitoring period shall be 

extended to 2 hours. In no case should visible emissions be allowed for more than 5 

minutes in any 2 hour period. Unless there is an actual emergency that could result 

in extreme plant damage or imminent threat to people who live or work nearby 

that no visible emissions from flares should be allowed. If flares are as efficient 

as is stated (98%) then visible emissions should not occur. 

3) Page 151 of 813, I support using an on-line gas chromatograph and vent gas and 

assist gas flow rate monitoring to determine whether combustion zone operating limits 

are met. We need to bring flares in from the Stone Age and require monitoring 

commensurate with the massive amounts of air pollutants, hazardous or 

otherwise, that are burned or emitted from flares. I do not support the use of grab 

samples since a continuous method to determine whether flares actually destroy 

air pollutants and measurement of air pollutants that flares do emit is needed. 

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4) Page 164 of 813, I do not agree with EPA that wind does not affect flare 

performance. The information that EPA presents is not convincing on this issue 

and at best suggests that additional appropriate data collection is needed. 

5) Page 170 of 813, I do not support bypassing of any air pollution. Any bypassing 

of air pollution should be a violation of CFR 60 and 63, whether an emergency has 

occurred or not because bypassing means that citizens, other life forms, and building 

materials are automatically in danger. An actual monitoring system is needed which 

determines how much of what air pollutants have been released in any bypass. 

6) Pages 184 and 191 of 813, I oppose using optical gas imaging devices in place 

of portable hydrocarbon analyzers (Method 21) which provide an actual 

instantaneous concentration of volatile organic compounds (VOC). Optical gas 

imaging devices are good for initial determinations that a leak might have occurred but 

provide no definitive proof that a leak actually has occurred. These devices detect 

infrared heat waves and not air pollutant concentrations. Only a portable hydrocarbon 

analyzer can determine if a leak has occurred by measurement of VOCs in ppm and 

comparison of this VOC concentration with the leak definition or standard. 

7) Pages 195, 202, and 204 of 813, I do not agree that $3,900 is too much to pay for 

add-on air pollution control technology. Twenty thousand dollars per ton should be the 

limit for ton of VOC/HAP removed . . In the 1970's $3,900 was considered a cost 

effective amount for the recovery of a ton of VOC. The EPA fails to state clearly 

what is cost effective and what criteria this determination is based upon. 

It makes no sense to rely upon "industry-reported emissions inventories" to 

determine cost effectiveness because industries have shown time after time that 

they underestimate their emissions. This is a conflict of interest. There is an 

incentive for industry to underestimate its air emissions since it can then avoid air 

pollution control by affecting EPA cost effectiveness determinations. It is a shame that 

EPA falls for this industry trick. I do support putting more controls on wastewater 

facilities. 

13) Pages 206 through 247 of 813, I support monitoring at the fence-line by the 

refinery industry but I do not support use of a passive diffusive tube monitoring network. 

EPA must rethink the fence-line monitoring requirements and make them 

continuous, state-of-the art, immediate, and inclusive of all significant HAPs, not 

just benzene but also ethyl benzene, xylene, toluene, and 1 ,3-butadiene at a 

minimum. 

The passive method, which EPA proposes to use, is the least accurate (from a quality 

assurance and quality control standpoint) and least sophisticated monitoring method of 

the six monitoring methods that EPA chooses from. The passive diffusive tube 

monitoring network as proposed by EPA does not provide continuous data for HAPs 

and VOCs, allows 2,000 feet between monitoring sites (this could allow large fugitive 

sources and the clouds of VOC or HAPs that are emitted to remain unmonitored), 

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allows for 1-year rolling annual average and 2-week sampling interval which delays 

discovery of air pollution concentrations that are over the fence-line limit and therefore 

makes it much more difficult to determine the source and cause of air pollution. 

Something much quicker for sampling, like instantaneous sampling, is needed. 

The present proposal does not require sufficient elevation of monitoring stations 

so that fugitive emissions from towers and other elevated equipment are reliably 

monitored. 

EPA chooses the passive diffusive tube monitoring network because it is cheap and 

little training is needed. The refinery industry can afford the best equipment and its 

cost. One-half million dollars is "chump change" for the refinery industry. Usually, after 

the refinery industry operates with new regulatory requirements, like the monitoring that 

EPA proposes, it figures out how to comply correctly in an easier manner and for less 

money. EPA should not "poor-boy" this first attempt at refinery fence-line monitoring. If 

EPA gets this wrong there may not be another opportunity to require fence-line 

monitoring for a long time. The public has a right to know what types of HAPs are 

crossing the fence-line and in what the concentrations instantaneously. 

Monitoring that determines this is what the refinery industry must do. 

14) Pages 249 through 256 and page 321 of 813, I do not support a 30% opacity 

limit for fluidized catalytic cracking units. Today's technology is good enough for 

a 10-20% opacity limit. EPA states on page 252 of 813, that "This 30-percent opacity 

limit has been shown to be lenient and high in comparison to recent federal rules that 

have included more stringent opacity limit (e.g., 40 CFR part 60, subpart Db with 20-

percent opacity), and recent state and local agency rules that omit opacity limits 

altogether in favor of operating limits for the emission control systems." 

EPA must push the refinery industry to ensure it uses the best available control 

technology. There is no reason to give the refinery industry a break since oil 

companies are making incredible amounts of money (tens of billions of dollars) 

each quarter. · 

I appreciate this opportunity to comment. Thank you. 

Sincerely, fJJ~(j- ~~ 

Brandt Mannchen 

5431 Carew 

Hou~on,Texas77096 

713-664-5962 

brandtshnfbt@juno.com 

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