Environmental Permitting

Highlights from EPA’s Proposed Rule for Petroleum Refineries

In a recent proposed rulemaking, the EPA announced a number of changes to two emissions standards currently regulating toxic air emissions from petroleum refineries:

1) The National Emission Standards for Hazardous Air Pollutants From Petroleum Refineries (Refinery MACT 1), and
2) The National Emission Standards for Hazardous Air Pollutants for Petroleum Refineries: Catalytic Cracking Units, Catalytic Reforming Units, and Sulfur Recovery Units (Refinery MACT 2).

To determine necessary changes to the standards, the EPA performed residual risk assessments and technology reviews, as required under the CAA. The risk assessment included five analyses:

  1. Estimates of individual source category risk,
  2. Risk estimates from all air toxics emissions at a facility (“total facility risk”),
  3. Risk estimates of cumulative source category risks,
  4. Risk estimates based on the actual emissions reported as emitted, and
  5. Risk estimates based on emissions allowed by the current air toxics standards.

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Technology review is required to review and revise national emissions standards for air toxics and includes the evaluation of advances in “practices, processes and control technologies” that have been introduced since the original standards were issued. In particular, the EPA identified new fugitive emissions monitoring technologies that will help limit unintended emissions from leaks, etc.
Based on the risk assessment and technology review, the EPA proposed the following changes to the Refinery MACT 1 and Refinery MACT 2 standards:

  • Additional emissions control requirements for storage tanks, flares, and coking units at petroleum refineries,
  • Fenceline monitoring of air concentrations at refineries (with an annual average benzene concentration standard at the refinery fenceline measured using 2-week integrated samples)              to ensure proposed standards are being met and that local communities are protected from unintended emissions,
  • Operational requirements for flares to meet a high level of combustion efficiency,
  • MACT controls on delayed coking units,
  • Elimination of exemptions to emissions limits during periods of start-up, shutdown, and malfunction, and
  • Technical corrections and clarifications to the 2008 Petroleum Refinery New Source Performance Standards (NSPS) to improve “consistency and clarity” for facilities regulated under both the NSPS and Refinery MACT 2.

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According to the EPA, the United States currently has 142 major source and seven area source petroleum refineries and 36 small businesses that own petroleum refineries. Under the proposed changes for cokers and storage tanks, the Agency estimates toxic emissions of chemicals like benzene, toluene, and xylene would drop by about 1,800 tons per year (tpy) while emissions of volatile organic compounds (VOCs) would be reduced by about 19,000 tpy. The EPA also conservatively estimates the proposed changes for flaring will bring reductions of 3,800 tpy of hazardous air pollutants (HAPs) and 33,000 tpy of VOCs. In addition, the EPA notes that a “co-benefit” of the changes is the elimination of an estimated 700,000 metric tonnes of CO2 equivalents.

The EPA also estimated the capital cost of the proposed rule is approximately $240 million, with an annualized cost of $40 million, and that the impact on the costs of petroleum products will be negligible.