United States      Office of Air Quality       EPA-450/3-85-001 a
           Environmental Protection  Planning and Standards     February 1985
           Agency        Research Triangle Park NC 27711

           Air
&EB&     VOC Emissions       Draft
           From Petroleum      EIS
           Refinery
           Wastewater
           Systems—
           Background
           Information for
           Proposed Standards

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                                   EPA-450/3-85-001a
VOC Emissions from Petroleum Refinery
   Wastewater Systems— Background
   Information for Proposed Standards
              Emission Standards and Engineering Division
                        u.S. Environmental Protection Agent)
                            5, library (PL-12J)
              U.S. ENVIRONMENTAL PROTECTION AGENCY
                   Office of Air and Radiation
               Office of Air Quality Planning and Standards
              Research Triangle Park, North Carolina 27711

                      February 1985

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This report has been reviewed by the Emission Standards and Engineering Division of the Office of Air
Quality Planning and Standards, EPA, and approved for publication. Mention of trade names or commercial
products is not intended to constitute endorsement or recommendation for use. Copies of this report are
available through the Library Services Office (MD-35), U.S. Environmental Protection Agency, Research
Triangle Park, N.C. 27711, or from the National Technical Information Services, 5285 Port Royal Road,
Springfield, Virginia 22161.

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                       ENVIRONMENTAL PROTECTION AGENCY

       Background Information and Draft Environmental  Impact Statement
                                     for
                    Petroleum Refinery Wastewater Systems
Prepare
                              ____
     R. Farmer     {        v—        -                     /  Datj6
Director, Emission Standards and Engineering Division
U. S. Environmental Protection Agency (MD-13)
Research Triangle Park, North Carolina  27711

     1.   The proposed standards of performance would limit emissions of
volatile organic compounds from new, modified, and reconstructed petroleum
refinery wastewater systems.  Section 111 of the Clean Air Act (42 U.S.C.  7411),
as amended, directs the Administrator to establish standards of performance
for any category of new stationary source of air pollution that "...
causes or contributes significantly to air pollution which may reasonably be
anticipated to endanger public health or welfare."  It is anticipated that
areas with high concentrations of petroleum refineries, such as the Gulf
Coast and the West Coast, would be particularly affected.

     2.   Copies of this document have been sent to the following Federal
Departments:  Labor, Health and Human Services, Defense, Transportation,
Agriculture, Commerce, Interior, and Energy; the National Science Foundation;
the Council on Environmental Quality; State and Territorial Air Pollution
Program Administrators; EPA Regional Administrators; Local Air Pollution
Control Officials; Office of Management and Budget; and other interested
parties.

     3.   The comment period for review of this document is 75 days from the
date of publication of the proposed standard in the Federal Register.
Mr. Gilbert Wood or Ms. Debbie Wells may be contacted at (919) 541-5578
regarding the date of the comment period.

     4.   For additional information contact:

          Mr. James F. Durham
          Emission Standards and Engineering Division (MD-13)
          U. S. Environmental Protection Agency
          Research Triangle Park, North Carolina  27711
          Telephone:  (919) 541-5671

     5.   Copies of this document may be obtained from:

          U. S. Environmental Protection Agency Library  (MD-35)
          Research Triangle Park, North Carolina  27711
          Telephone:  (919) 541-2777

          National Technical  Information Service
          5285 Port Royal Road
          Springfield, Virginia  22161
                                    in

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                              TABLE OF CONTENTS

Chapter/Section                                                     Page
 1.  SUMMARY	  1-1
     1.1  Regulatory Alternatives	  1-1
     1.2  Environmental Impact	  1-2
     1.3  Economic Impact	  1-4
 2.  INTRODUCTION	  2-1
     2.1  Background and Authority for Standards	  2-1
     2.2  Selection of Categories of Stationary Sources	  2-4
     2.3  Procedure for Development of Standards of Performance....  2-5
     2.4  Consideration of Costs	  2-7
     2.5  Consideration of Environmental Impacts	  2-8
     2.6  Impact on Existing Sources	  2-8
     2.7  Revision of Standards of Performance	  2-9
 3.  DESCRIPTION OF PETROLEUM REFINERY WASTEWATER SYSTEMS AND VOC
     EMISSIONS	  3-1
     3.1  Introduction and General Information	  3-1
          3.1.1  Petroleum Refining Industry	  3-1
          3.1.2  Overview of Petroleum Refinery Wastewater Systems.  3-3
            3.1.2.1  Sources of Refinery Wastewater	  3-6
            3.1.2.2  Future Trends in Refinery Wastewater
                     Generation	  3-14
     3.2  Petroleum Refinery Wastewater Processes and VOC
          Emissions	  3-17
          3.2.1  Process Drain Systems	  3-17
            3.2.1.1  Description of Process Drain System	  3-17
            3.2.1.2  Process Drain Types	  3-19

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Chapter/Section                                                       Page

            3.2.1.3  Junction Box Types	  3_2i
            3.2.1.4  Factors Affecting Emissions from Process
                     Drains and Junction Boxes	  3-25
            3.2.1.5  VOC Emissions from Process Drains..,	  3-27
            3.2.1.6  VOC Emissions from Junction Boxes..	  3-27

          3.2.2  Oil-Water Separators	  3_28

            3.2.2.1  Types of Oil-Water Seperators	  3-28
            3.2.2.2  Major Factors Affecting VOC Emissions	'..  3-30
            3.2.2.3  VOC Emissions from Oil-Water Separators	  3-37

          3.2.3  Air Flotation Systems	  3_41

            3.2.3.1  Description of Air Flotation Systems	  3-41
            3.2.3.2  Factors Affecting Emissions	  3-46
            3.2.3.3  VOC Emissions from Air Flotation Systems	  3-51

          3.2.4  Miscellaneous Wastewater Treatment  Processes	  3-53

            3.2.4.1  Intermediate Treatment Processes	  3-53
            3.2.4.2  Secondary Treatment Processes	'.'.'.'.'.  3-54
            3.2.4.3  Additional  Treatment Processes	  3-56
            3.2.4.4  VOC Emissions from Miscellaneous Wastewater	
                     Treatment Processes	  3.55

     3.3   Growth  of Source Category	  3_57

          3.3.1  Process Drains  and Junction Boxes	  3.57

          3.3.2  Oil-Water Separators	  3.57

          3.3.3  Air Flotation	  3_58

     3.4   Baseline  Emissions	  3_50

          3.4.1  Process Drains  and Junction Boxes	  3-60

          3.4.2  Oil-Water Separators	  3_6Q

          3.4.3  Air Flotation Systems	  3_66

     3.5   References	  3.57
                                   VI

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Chapter/Section                                                       Page

 4.  EMISSION CONTROL TECHNIQUES	 4-1

     4.1  Methods for Reduction of VOC Emissions	 4-2

          4.1.1  Process Drains and Junction Boxes	 4-2

            4.1.1.1  Methods for Controlling VOC Emissions	 4-2
            4.1.1.2  Effectiveness of VOC Emission Controls	 4-3

          4.1.2  Oil-Water Separators	 4-9

            4.1.2.1  Methods for Controlling VOC Emissions	 4-11
            4.1.2.2  Effectiveness of VOC Emission Controls	 4-14

          4.1.3  Air Flotation Systems	 4-14

            4.1.3.1  Methods for Controlling Emissions	 4-15
            4.1.3.2  Effectiveness of VOC Emission Controls	 4-17

     4.2  Control of Captured VOC	 4-20

          4.2.1  Flare Systems	 4-20

            4.2.1.1  Operating Principles	 4-21
            4.2.1.2  Factors Affecting Efficiency	 4-23
            4.2.1.3  Control Efficiency	 4-24
            4.2.1.4  Applicability	 4-26

          4.2.2 Carbon Adsorption	 4-26

            4.2.2.1  Operating Principles	 4-26
            4.2.2.2  Factors Affecting Performance and
                     Applicability	 4_27
            4.2.2.3  Control Efficiency	 4-30

          4.2.3  Incineration	 4-30

            4.2.3.1  Operating Principles	 4-30
            4.2.3.2  Factors Affecting Performance and
                     Appl icabi 1 ity	 4-30
            4.2.3.3  Control Efficiency	 4-34
                                   VII

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Chapter/Section                                                       paqe

          4.2.4  Catalytic Oxidation ................................. 4.34

            4.2.4.1  Operating Principles ............................ 4.34
            4.2.4.2  Factors Affecting Performance and
                     Appl icabi 1 i ty ................................... 4_36
            4.2.4.3  Control Efficiency .............................. 4-36

          4.2.5  Condensation ........................................ 4.35

            4.2.5.1  Factors Affecting Performance and
                     Appl icabi 1 i ty ................................... 4-38
            4.2.5.2  Control Efficiency .............................. 4-40

          4.2.6  Industrial Boilers and Process Heaters .............. 4-40

            4.2.6.1  Operating Principles ............................ 4-40
            4.2.6.2  Factors Affecting Performance and
                     Applicability ................................... 4-41
            4.2.6.3  Control Efficiency ....... .................... .,. 4_42

     4 . 3  References ................................................. 4.44

 5.  MODIFICATION AND RECONSTRUCTION ................................. 5_!

     5.1  General Discussion of  Modification and Reconstruction
          Provisions                                                   _
          5.1.1  Modification ........................................ 5-1

          5.1.2  Reconstruction ...................................... 5_2

     5.2  Applicability of Modification and Reconstruction
          Provisions to VOC Emissions from Petroleum Refinery
          Wastewater Systems ......................................... 5_2

          5.2.1  Modification ........................................ 5_3

          5.2.2  Reconstruction .......................... ............. 5.3

 6.   MODEL UNITS AND REGULATORY ALTERNATIVES .......................... 6-1

     6.1  Model  Units ...................................... ........... 6_1

          6.1.1  Process  Drains and  Junction Boxes ......... ........... 6-1

          6.1.2  Oil -Water Separators ................................ 6-3
                                  vm

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Chapter/Section                                                       page
          6.1.3  Air Flotation Systems	  6-3
     6.2  Regulatory Alternatives	  6-6
     6.3  References	  6-8
 7.   ENVIRONMENTAL IMPACTS	  7-1
     7.1  Introduction	  7_1
     7.2  Air Pollution Impacts	  7-1
          7.2.1  Estimated Emissions  and Percent Emission
                 Reduction for Model  Units	  7-1
          7.2.2  Projected VOC Emissions for Petroleum Refinery
                 Wastewater System Source Category	  7-1
          7.2.3  Secondary Air Pollution Impacts	  7-6
          7.2.4  Summary of Air Pollution Impacts	  7-7
     7.3  Water Pollution Impacts	  7-7
     7.4  Solid Waste  Impacts	  7-7
     7.5  Energy Impacts and Water Usage	  7-7
     7.6  Other Environmental  Concerns	  7-9
     7.7  References	  7_H
 8.   COSTS	  8_j
     8.1  Cost  Analysis  of Regulatory Alternatives	  8-1
          8.1.1  Process  Drains  and Junction  Boxes	  8-1
           8.1.1.1  Regulatory  Alternative  II - Water Sealed
                    Drains  and  Junction  Boxes	  8-1
           8.1.1.2  Regulatory  Alternative  III  - Closed  Drain
                    System	  8-5
                                   IX

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Chapter/Section                                                       Page

          8.1.2  Oil-Water Separators	 8-8

            8.1.2.1  Regulatory Alternative II - Covered
                     Separators	 8-11
            8.1.2.2  Regulatory  Alternative III - Covered
                     Separators with Vapor Control Systems	 8-11

          8.1.3  Air Flotation Systems	 8-16

          8.1.4  Incremental Cost Effectiveness	 8-16

     8.2  Other Cost Considerations	 8-20

     8.3  References	 8-22

 9.  ECONOMIC IMPACTS	 9-1

     9.1  Industry Characterization	 9-1

          9.1.1  General Profile	 9-1

            9.1.1.1  Refinery Capacity	:	 9-1
            9.1.1.2  Refinery Production	 9-3
            9.1.1.3  Refinery Ownership, Vertical Integration
                     and Diversification	 9-3
            9.1.1.4  Refinery Employment and Wages	 9-7

          9.1.2  Refining Processes	 9-7

            9.1.2.1  Crude Distillation	 9-10
            9.1.2.2  Thermal Operations	 9-10
            9.1.2.3  Catalytic Cracking	 9-10
            9.1.2.4  Reforming	 9-10
            9.1.2.5  Insomerization	 9-10
            9.1.2.6  Alkylation	 9-12
            9.1.2.7  Hydrotreating	 9-12
            9.1.2.8  Lubes	 9-12
            9.1.2.9  Hydrogen Manufacture	 9-12
            9.1.2.10 Solvent Extraction	 9-12
            9.1.2.11 Asphalt	 9-12

          9.1.3  Market Factors	 9-12

            9.1.3.1  Demand Determinants	 9-12
            9.1.3.2  Supply Determinants	 9-15
            9.1.3.3  Prices	 9-18

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Chapter/Section                                                       page
            9.1.3.4  Imports	 9-18
            9.1.3.5  Exports	 9-18
          9.1.4  Financial Profile	 9-22
     9.2  Economic Impact Analysis	 9-25
          9.2.1  Introduction and Summary	 9-25
          9.2.2  Method	 9-25
          9.2.3  Analysis	 9-28
          9.2.4  Conclusions	 9_32
     9.3  Socioeconomic and Inflationary Impacts	 9-36
          9.3.1  Executive Order 12291	 9-36
            9.3.1.1  Fifth-Year Annualized  Costs	 9-36
            9.3.1.2  Inflationary Impacts	 9-36
            9.3.1.3  Employment Impacts	* 9.49
          9.3.2  Small  Business Impacts  - Regulatory Flexibility Act. 9-40
     9.4  References	 g_42

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APPENDICES                                                            Page
  A.  Evolution of the Background Information Document	 A-l
  B.  Index to Environmental Considerations	 B-l
  C.  Emission Source Test Data	 C-l
      C.I  Emission Measurements	 C-l
           C.I.I  Chevron, U.S.A., Inc.  Refinery - El Segundo,
                  California	 C-l
           C.I.2  Golden West Refinery - Sante Fe Springs,
                  California	 C-3
           C.I.3  Phillips Petroleum Company, Sweeny, Texas	 C-26
      C.2  VOC Screening of Process Drains	 C-51
      C. 3  References	 C-55
  D.  Emission Measurement and Continuous Monitoring	 D-l
      D.I  Introduction	 D-l
      D.2  Emission Measurement Experience	 D-l
           D.2.1  Air Flotation and Equalization Basin Test	 D-2
             D.2.1.1  Vent Gas Flow Rate	 D-2
             D.2.1.2  Total Organic Concentration Measurement	 D-3
             D.2.1.3  Gaseous Organics Speciation	 D-3
             0.2.1.4  Wastewater Sampling and Analysis	 D-4
             D.2.1.5  Process Drain Screening Surveys	 D-5
      D.3  Performance Test Methods	 D-5
           D.3.1  VOC Concentration Measurement	 D-5
           D.3.2  Gas Flow Measurement	 D-6
           D.3.3  Mass Flow	 D-7
           D.3.4  Emission Reduction Efficiency Determination	 D-7
           D.3.5  Performance Test Time and Costs	 D-7

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Appendices                                                            page
     D.4  Monitoring Systems and Devices	 D-7
          D.4.1  Monitoring of Vapor Processing Devices	 D-8
          D.4.2  Monitoring of Combustion Devices	 D-9
            D.4.2.1  Incinerators	 D-9
            D.4.2.2  Boilers or Process Heaters	 D-10
            D.4.2.3  Flares	 D-10
     D.5  References_
                                  xm

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                               LIST OF TABLES
Table                                                                 Page

1-1   Assessment of Environmental, Energy and Economic Impacts
      for Each Regulatory Alternative Considered for Petroleum
      Refi nery Wastewater Systems	 1-3

3-1   Classification of Refinery Wastewater Treatment Processes	 3-5

3-2   Wastewater Sources and Generation Rates	 3-8

3-3   Qualitative Evaluation of Wastewater Characterization by
      Fundamental Refinery Processes	 3-13

3-4   Factors for Calculating Emission Losses Using the Litchfield
      Method	 3-38

3-5   Data Used to Calculate Emission Factor	 3-40

3-6   Typical DAF Design Characteristics	 3-49

3-7   Summary of Results of EPA Tests on Air Flotation Systems	 3-52

3-8   Projected Annual Increase in Refinery Wastewater from 1985 to
      1989	 3-59

3-9   Existing State Regulations Applicable to Oil-Water Separators
      in Petroleum Refineries	 3-61

3-10  Summary of Baseline Control for Oil-Water Separators	 3-64

3-11  Estimate of Crude Throughput at Refineries Having Varying
      Emission Controls	 3-65

4-1   Summary of Screening Values for Individual Drains	 4-5

4-2   Summary of Emission Rates and Emission Reduction for Drains
      With a Leak Rate > 100 PPM	 4-6

4-3   Assumptions for Estimating Benzene Emissions from Example
      Drains	 4-8

4-4   Benzene Emissions from Each Drain Configuration	 4-10

4-5   Physical Constants and Condensation Properties of Some
      Organi c Sol vents	 4-37
                                    xiv

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Table

6-1   Process Drains Model Unit Parameters	 6-2

6-2   Oil-Water Separators Model Unit Parameters	 6-4

6-3   Air Flotation Model Unit Parameters	 6-5

6-4   Regulatory Alternatives	 6-7

7-1   Estimated Emissions and Emission Reductions for Each
      Model Unit and Regulatory Alternative	 7-2

7-2   Projected VOC Emissions from New and Modified/
      Reconstructed Process Drain Systems for Regulatory
      Alternatives in Period from 1985 - 1989	 7-3

7-3   Projected VOC Emissions from New and Modified/
      Reconstructed Oil-Water Separators for Regulatory
      Alternatives in Period from 1985 - 1989	 7-4

7-4   Projected VOC Emissions from New and Modified/
      Reconstructed Air  Flotation Systems for Regulatory
      Alternatives in Period from 1985 - 1989	 7-5

7-5   Summary of Annual  Emissions and Emission  Reduction  by
      1989 for Source Category  (New and Modified/Reconstructed
      Uni ts)	 7-8

7-6   Energy Requirements and Water Demand - Regulatory
      Alternative  III for Process Drains and Junction Boxes,
      Oil-Water Separators, and Regulatory Alternative II
      for Air Flotation  Systems	 7-10

8-1   Components and Factors of Total Capital Investment	 8-2

8-2   Components,  Factors and Rate of Total Annual  Cost	 8-3

8-3   Total Direct Capital Cost of Major Equipment  for
      VOC Control on Process Drain Systems	 8-4

8-4   Annualized Cost and Cost  Effectiveness of Regulatory
      Alternatives for New Process Drain and Junction Box
      System	 8-6

8-5   Annualized Cost and Cost  Effectiveness of Regulatory
      Alternatives for Retrofitting a Process Drain and
      Junction Box Emission Reduction System	 8-7
                                     XV

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Table
8-6   Basis for Buried Tank Subsystem Cost Estimate for
      Regulatory Alternative III	 8-9
8-7   Annual Utility Costs for Regulatory Alternatives	 8-10
8-8   Annualized Cost and Cost Effectiveness of Regulatory
      Alternatives for a Retrofit Control System on an API
      Oil-Water Separator	 8-12
8-9   Annualized Cost and Cost Effectiveness of Regulatory
      Alternatives for New API Oil-Water Separators	 8-13
8-10  Cost Breakdown of Major Equipment for VOC Control  for
      Oil-Water Separators and Air Flotation Systems	 8-14
8-11  Operating Parameters and Costs of Carbon Adsorber	 8-15
8-12  Annualized Cost and Cost Effectiveness of Regulatory
      Alternatives for DAF Systems	 8-17
8-13  Annualized Cost and Cost Effectiveness of Regulatory
      Alternatives for IAF Systems	 8-18
8-14  Incremental Cost Effectiveness of Regulatory Alternatives	 8-19
8-15  Statutes That May Be Applicable to the Petroleum
      Refining Industry	 8-21
9-1   Total and Average Crude Distillation Capacity by Year -
      United States Refineries, 1973 - 1983	 9-2
9-2   Percent Volume Yields of Petroleum Products by Year -
      United States Refineries, 1974 - 1981	 9-4
9-3   Production of Petroleum Products by Year - United  States
      Refineries, 1972 - 1981	 9-5
9-4   Number and Capacity of Refineries Owned and Operated
      by Major Companies - United States Refineries, 1983	 9-6
9-5   Employment in Petroleum and Natural Gas Extraction and
      Petroleum Refining by Year - United States, 1972 - 1981	 9-8
9-6   Average Hourly Earnings of Selected Industries by  Year -
      United States, 1972 - 1981	 9-9
                                   xvi

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 Table

 9-7   Estimated Gasoline Pool  Composition by Refinery Stream -
       United States Refineries, 1981 ................................. 9-11

 9-8   Refined Product Demand Projections for U.S. Refineries
       Under Three World Oil  Price Scenarios 1983 - 1986 - 1989 ....... 9-14

 9-9   Price Elasticity Estimates for Major Refinery Products
       by Demand Sector - United States, 1990 ......................... 9-16

 9-10  Crude Oil  Production and Consumption by Year - United
       States, 1970 - 1982 ............................................ 9-17

 9-11  Average Wholesale Prices:  Gasoline, Distillate Fuel  Oil
       and Residual  Fuel  Oil  by Year -  United States, 1968 - 1982 ..... 9-19

 9-12  Imports of Selected Petroleum Products by Year -  United
       States, 1969 - 1981 ............................................ 9_2Q

 9-13  Exports of Selected Petroleum Products by Year -  United
       States, 1969 - 1981 ............................................ 9_2i

 9-14  Profit Margins for Major Corporations  with Petroleum
       Refinery Capacity,  1977  -  1981  (Percent) ....................... 9-23

 9-15  Return on  Investment of  Major Corporations with Petroleum
       Refinery Capacity  1977 - 1981 .................................. g_24

 9-16  Total  Annual ized  Control  Costs for  a New  Refinery,
       Regulatory Alternative II ......................................  g_2g

 9-17  Total  Annual ized Control Costs for  a New  Refinery,
       Regulatory Alternative III .....................................  9_30

 9-18  DOE  Projected  Prices and Domestic Refinery Demand Under
       Three  World Oil Price Scenarios,  1989 ..........................  9_31

 9-19   Price  and  Total Demand Under  Regulatory Alternatives
       11 and  IH [[[  9-33

 9-20   Changes  in  1989 Price and Demand Compared with 1983
       Basel i ne Level s
9-21  Summary of Fifth Year Annual ized Cost by Model Unit and
      Regulatory Alternative .....................................     9_37


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Table

C-l   Summary of Daily Emission Rate Averages: Continuous
      Monitoring Results, Chevron Refinery, El Segundo,
      California	 C-4

C-2   Gas Chromatography Results from DAF System, Chevron
      Refinery, El Segundo, California	 C-5

C-3   Gas Chromatography Results from Equalization Basin, Chevron
      Refinery, El Segundo, California	 C-8

C-4   Gas Chromatography and Emission Rates from IAF System,
      Chevron Refinery, El Segundo, California	 C-ll

C-5   Liquid Samples Taken on 8/3/83 - Chevron Refinery, El
      Segundo, California	 C-12

C-6   Liquid Samples Taken on 8/4/83 - Chevron Refinery, El
      Segundo, California	 C-14

C-7   Liquid Samples Taken on 8/5/83 - Chevron Refinery, El
      Segundo, California	 C-15

C-8   Liquid Samples Taken on 8/8/83 - Chevron Refinery, El
      Segundo, California	 C-16

C-9   Liquid Samples Taken on 8/9/83 - Chevron Refinery, El
      Segundo, California	 C-19

C-10  Liquid Samples Taken on 8/10/83 - Chevron Refinery, El
      Segundo, California	 C-20

C-ll  Liquid Samples Taken on 8/11/83 - Chevron Refinery, El
      Segundo, California	 C-21

C-12  Liquid Samples Taken on 8/12/83 - Chevron Refinery, El
      Segundo, California	 C-25

C-13  Daily Emission Rate Averages  at IAF Outlet - Golden West
      Refinery, Santa Fe Springs,  California	 C-28

C-14  Gas Chromatography Results from IAF System - Golden West
      Refinery, Santa Fe Springs,  California	 C-29

C-15  Liquid Samples Taken on 8/16/83 - Golden West Refinery,
      Santa Fe Springs, California	 C-31
                                   xvm

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T ui
Table                                                                 — a-

C-16  Liquid Samples Taken on 8/17/83 - Golden West Refinery,
      Santa Fe Springs, California ................................... c-33

C-17  Liquid Samples Taken on 8/18/83 - Golden West Refinery,
      Santa Fe Springs, California ................................... c~38

C-18  Liquid Samples Taken on 8/19/83 - Golden West Refinery,
      Santa Fe Springs, California ................................... C-40

C-19  Daily Emission Rate Averages at IAF Outlets - Phillips
      Petroleum, Sweeny, Texas ....................................... c~43

C-20  Gas Chromatography Results from IAF #1  (South IAF) -
      Phillips Petroleum, Sweeny, Texas .............................. C-44

C-21  Gas Chromatography Results from IAF #2  (North IAF) -
      Phillips Petroleum, Sweeny, Texas .............................. C-46

C-22  Liquid Samples Taken on 9/20/83 - Phillips  Petroleum,
      Sweeny , Texas .................................................. ^-47
 C-23   Liquid  Samples  Taken  on  9/21/83  -  Phillips  Petroleum,
       Sweeny , Texas ..................................................  c~48

 C-24   Liquid  Samples  Taken  on  9/22/83  -  Phillips  Petroleum,
       Sweeny , Texas ..................................................  C-49

 C-25   Liquid  Samples  Taken  on  9/23/83  -  Phillips  Petroleum,
       Sweeny , Texas ..................................................  c"5^
 C-26  Summary of Emission Rates and Emission Reduction for
       Drains with a Leak Rate > 100 PPM (Phillips Petroleum,  etc) ----  C-52

 C-27  Summary of Process Drain Screening - Golden West
       Refinery, Santa Fe Springs, California .........................  C-53

 C-28  Summary of Process Drains Screening - Total
       Petroleum, Alma, Michigan ......................................  C-54
                                     xix

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                               LIST OF FIGURES

Figure                                                                page

3-1   Geographical Distribution of Petroleum Refineries
      in the United States as of January 1, 1984	 3-2

3-2   Block Diagram of a Petroleum Refinery Oily Waste-
      water System	 3.4

3-3   Example of a Segregated Wastewater Collection and
      Treatment System	 3_7

3-4   Atmospheric Distillation System	 3-15

3-5   Two Stage Steam Actuated Vacuum Jet System	 3-16

3-6   General Refinery Drain System	 3-18

3-7   Types of Individual Refinery Drains for Oily Waste-
      water	 3_2Q

3-8   Closed Drain and Collection System	 3-22

3-9   Refinery Drain System Junction Boxes	 3-23

3-10  Gas Trap Manhole	 3-24

3-11  Oil-Water Separator	 3_29

3-12  Corrugated Plate Separator	 3-31

3-13  Effect of Ambient Air Temperature on Evaporation	 3-33

3-14  Effects of 10% Point on Evaporation	 3-34

3-15  Effect of Influent Temperature on Evaporation	 3-35

3-16  Relationship Between Vapor Pressure, Wind Speed and
      Loss Rate	 3-36

3-17  Interaction of Gas Bubbles with Suspended Solid or
      Liquid Phases	 3-42

3-18  Dissolved Air  Flotation System	 3-43

3-19  Mechanism of an Impeller Type IAF	 3-45
                                    xx

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Figure                                                                Page
3-20  Mechanism of a Nozzle Type IAF	 3-47
4-1   Floating Cover on an API Separator	 4-12
4-2   Polyurethane Foam Seal on a Floating Roof	 4-13
4-3   Example of DAF Emission Control  System	 4-16
4-4   Examples of DAF and IAF Control  Systems	 4-18
4-5   Steam-Assisted Elevated Flare System	 4-22
4-6   Schematic of Non-Regenerative Carbon Adsorption System
      for VOC Control	 4-28
4-7   Schematic of Incineration System for VOC Control	 4-31
4-8   Typical Effect of Combustion Zone Temperature on
      Hydrocarbon and Carbon Monoxide Destruction Efficiency	 4-33
4-9   Schematic of Catalytic Oxidation System for VOC Control	 4-35
4-10  Condensation System	 4-39

C-l   Dissolved Air Flotation System with Sample Location	 C-2
C-2   Equalization Basin with Sample Location	 C-7
C-3   Induced Air Flotation System at Chevron - El Segundo,
      California	 C-10
C-4   Wastewater Treatment Facilities at Santa Fe Springs,
      California	 C-27
C-5   Schematic Representation of the IAF Process with Sample
      Points and Induced Air System: Phillips Petroleum, Sweeny,
      Texas	 C-41
C-6   IAF - Outlet Sample Locations Fabricated: Phillips
      Petroleum - Sweeny, Texas	 C-42
                                    xxi

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                                 1.  SUMMARY

     Standards of performance for new stationary sources are established
under Section 111 of the Clean Air Act (42 U.S.C. 7411), as amended in 1977.
Section 111 directs the Administrator to establish standards of performance
for any category of new stationary source of air pollution which "causes or
contributes significantly to air pollution which may reasonably be
anticipated to endanger public health or welfare."

1.1  REGULATORY ALTERNATIVES

     The analysis of environmental, economic, and energy impacts were based
on consideration of three regulatory alternatives for each emission source.
The regulatory alternatives are given below:

Process Drain Systems:

     Regulatory Alternative I:   No additional control.
     Regulatory Alternative II:  Require water seals on process drains and
                                 junction boxes.
     Regulatory Alternative III: Require completely closed drain systems
                                 with vapors vented to a control device.
Oil-Mater Separators:

     Regulatory Alternative I:   No additional control.
     Regulatory Alternative II:  Require separators to be covered.
     Regulatory Alternative III: Require gasketed and sealed fixed roof with
                                 vapors vented to a control device.
Air Flotation Systems:

     Regulatory Alternative I:   No additional control.
     Regulatory Alternative II:  Require gasketed and sealed fixed roofs and
                                 access doors.
     Regulatory Alternative III: Require gasketed and sealed fixed roofs and
                                 access doors with vapors vented to a
                                 control device.

     Regulatory Alternative I  requires no action.  Under this alternative,
emissions would be controlled  to levels established by existing State
regulations.  Of the  sources  included in this NSPS, only oil-water
separators  are regulated by existing regulations.

     Requiring water  seals on  process drains will result in emission
reductions  of 50 percent or more when compared to Regulatory Alternative I.
A  cover on  an oil-water separator  will result in emission reduction of 85

NOTE:  Regulatory Alternative  II for process drain systems  has been modified
       in  the proposed  standards  (40 CFR Part 60, Subpart QQQ).  Only
       process drains will be  required to have water seals.  Junction boxes
       will  be required to have a  tightly sealed cover.
                                    1-1

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percent.  A fixed roof on a dissolved air flotation system will  result in
emission reductions of at least 77 percent.  Gasketing and sealing an
induced air flotation system will result in at least a 23 percent reduction.
Again, these emission reductions are those achieved in comparison to
Regulatory Alternative I.

     The more stringent requirements of Regulatory Alternative III result in
a 98 percent reduction in emissions from process drain systems.   A fixed
roof on an oil-water separator or dissolved air flotation system with
captured VOC vented to a control device will result in emission  reductions
of 94 to 97 percent, depending on the efficiency of the control  device.
Gasketing and sealing an IAF system and venting the captured VOC to a
control device will result in emission reductions of 70 to 85 percent, again
depending on the efficiency of the control device.  All emission reductions
are those achieved in comparison to Regulatory Alternative I.

1.2  ENVIRONMENTAL IMPACT

     Implementation of either Alternative II or Alternative III  for all
three emission sources will result in a beneficial impact on air quality.
Implementation of Alternative II will reduce VOC emissions by approximately
1630 Mg/yr in 1989.  This represents a 50 percent reduction below Regulatory
Alternative I.  Implementation of Alternative III will reduce VOC emissions
by approximately 3055 Mg/yr in 1989.  This represents a 95% percent
reduction below Alternative I.  It should be noted that the regulatory
alternatives can be independently applied to each of the three emission
sources.  Therefore, depending upon the specific regulatory alternative
picked for each source, the actual emission reduction achieved by the NSPS
can range from 1630 Mg/yr to 3055 Mg/yr.  These reductions in VOC emissions
can be accomplished without causing any adverse environmental impacts.

     No water pollution impact will result from implementation of any of the
regulatory alternatives.  Small quantities of water will be required if
regenerative carbon adsorbers are used to control VOC vented from oil-water
separators and air flotation systems.  However, the quantity of  water needed
will be insignificant.

     Solid waste will be generated by carbon adsorption systems  if they are
used for VOC control.  Again, the amount of solid waste generated will be
minimal.  Energy impacts will result only by implementing Regulatory
Alternative III.  These impacts are also expected to be minimal.

     Table 1-1 summarizes the environmental and energy impacts of the
regulatory alternatives.  A more detailed analysis of these impacts is
presented in Chapter 7.
                                    1-2

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            TABLE 1-1.  ASSESSMENT OF ENVIRONMENTAL,  ENERGY,  AND ECONOMIC IMPACTS FOR EACH REGULATORY ALTERNATIVE
                                    CONSIDERED FOR PETROLEUM  REFINERY  WASTEWATER SYSTEMS
CO


Administrative
alternative
Regulatory Alternative I
Regulatory Alternative II
Regulatory Alternative III
aKEY: + Beneficial impact
- Adverse impact
0 No impact
1 Negligible impact

Air
impact
0
+2
+3
2
3
4
5

Water
impact
0
0
0
Small impact
Moderate impact
Large impact
Very large impact
Solid
waste
impact
0
0
0





Energy
impact
0
0
0





Economic
impact
0
0
-1





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1.3  ECONOMIC IMPACT

     The preliminary economic analysis indicates that the fifth-year
annualized costs of the most costly regulatory alternatives for each
emission source are $6.3 million dollars.  This is well  below the $100
million level that Executive Order 12291 identifies as the threshold for
major regulatory actions.  Additionally, the price increase and output
reduction due to the most costly alternatives are 0.1 percent and
0.03 percent, respectively.
                                     1-4

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                              2.   INTRODUCTION

2.1  BACKGROUND AND AUTHORITY FOR STANDARDS

     Before standards of performance are proposed as a Federal  regulation,
air pollution control methods available to the affected industry and the
associated costs of installing and maintaining the control  equipment are
examined in detail.  Various levels of control based on different
technologies and degrees of efficiency are examined.  Each  potential level
of control is studied by EPA as a prospective basis for a standard.   The
alternatives are investigated in terms of their impacts on  the  economics and
well-being of the industry, the impacts on the national economy, and the
impacts on the environment.  This document summarizes the information
obtained through these studies so that interested persons will  be able to
see the information considered by EPA in the development of the proposed
standard.

     Standards of performance for new stationary sources are established
under Section 111 of the Clean Air Act (42 U.S.C. 7411) as  amended,  herein-
after referred to as the Act.  Section 111 directs the Administrator to
establish standards of performance for any category of new  stationary source
of air pollution which "... causes, or contributes significantly to air
pollution which may reasonably be anticipated to endanger public health or
welfare."

     The Act requires that standards of performance for stationary sources
reflect "... the degree of emission reduction achievable  which (taking
into consideration the cost of achieving such emission reduction, and any
nonair quality health and environmental impact and energy requirements) the
Administrator determines has been adequately demonstrated for that category
of sources."  The standards apply only to stationary sources, the construc-
tion or modification of which commences after regulations are proposed by
publication  in the Federal Register.

     The  1977 amendments to the Act altered or added numerous provisions
that apply to the process of establishing standards of performance.

     1.   EPA is required to list the categories of major stationary sources
that have not already been listed and regulated under  standards of
performance.  Regulations must be promulgated for these new categories on
the following schedule:

     a.   25 percent of the listed categories by August 7,  1980.
     b.   75 percent of the listed categories by August 7,  1981.
     c.   100 percent of the listed categories by August 7, 1982.
                                     2-1

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A governor of a State may apply to the Administrator to add a category not
on the list or may apply to the Administrator to have a standard of
performance revised.

     2.   EPA is required to review the standards of performance every four
years, and, if appropriate, revise them.

     3.   EPA is authorized to promulgate a standard based on design,
equipment, work practice, or operational procedures when a standard based on
emission levels is not feasible.

     4.   The term "standards of performance" is redefined, a new term
"technological system of continuous emission reduction" is defined.  The new
definitions clarify that the control system must be continuous and may
include a low- or non-polluting process or operation.

      5.   The time between the proposal and promulgation of a standard under
Section 111 of the Act may be extended to six months.

      Standards of performance, by themselves, do not guarantee protection of
health or welfare because they are not designed to achieve any specific air
quality levels.  Rather, they are designed to reflect the degree of emission
limitation achievable through application of the best adequately demon-
strated technological system of continuous emission reduction, taking into
consideration the cost of achieving such emission reduction, any nonair
quality health and environmental impacts, and energy requirements.

      Congress had several reasons for  including these requirements.   First,
standards with a degree of uniformity  are needed to avoid situations where
some  States may attract industries by  relaxing  standards relative  to  other
States.   Second, stringent standards enhance the potential for  long-term
growth.   Third, stringent  standards may help achieve long-term  cost  savings
by  avoiding  the need  for more  expensive retrofitting when pollution  ceilings
may be reduced  in the future.   Fourth,  certain  types of standards  for
coal-burning  sources  can adversely affect the coal market by driving  up the
price of  low-sulfur coal or  effectively excluding certain coals  from  the
 reserve base  because  their untreated pollution  potentials are high.
 Congress  does  not intend that  new source performance standards  contribute to
these problems.   Fifth, the  standard-setting process should  create incentives
for improved  technology.

      Promulgation of  standards  of performance does  not  prevent  State  or
 local  agencies  from adopting more stringent  emission limitations for  the
 same sources.   States are  free under  Section  116  of the Act  to  establish
even more stringent emission limits than those  established  under Section  111
 or  those  necessary  to attain or maintain the  National  Ambient Air  Quality
 Standards (NAAQS) under Section 110.   Thus,  new sources may  in  some cases be
 subject to limitations  more  stringent  than  standards of performance under
 Section 111, and  prospective owners and operators  of new  sources should  be
 aware of  this possibility  in planning  for  such  facilities..
                                      2-2

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     A similar situation may arise when a major emitting  facility is  to  be
constructed in a geographic area that falls under the prevention  of signifi-
cant deterioration of air quality provisions of Part C of the Act.   These
provisions require, among other things, that major emitting  facilities  to be
constructed in such areas are to be subject to best available control
technology.  The term best available control technology (BAT), as defined in
the Act, means

     ... an emission limitation based on the maximum degree of
     reduction of each pollutant subject to regulation under this Act
     emitted from, or which results from, any major emitting facility,
     which the permitting authority, on a case-by-case basis, taking
     into account energy, environmental, and economic impacts and other
     costs, determines is achievable for such facility through
     application of production processes and available methods,
     systems, and techniques, including fuel cleaning or  treatment or
     innovative fuel combustion techniques for control of each such
     pollutant.  In no event shall application of "best available
     control technology" result in emissions of any pollutants which
     will exceed the emissions allowed by an applicable standard
     established pursuant to Section 111 or 112 of this Act.
     (Section 169(3))

     Although standards of performance are normally structured in terms
of numerical emission limits where feasible, alternative  approaches are
sometimes necessary.  In some cases physical measurement  of  emissions
from a new source may be impractical or exorbitantly expensive.
Section lll(h) provides that the Administrator may promulgate a design
or equipment standard in those cases where it is not feasible to
prescribe or enforce a standard of performance.  For example, emissions
of hydrocarbons from storage vessels for petroleum liquids are greatest
during tank filling.  The nature of the emissions, high concentrations
for short periods during filling and low concentrations for  longer
periods during storage, and the configuration of storage  tanks make
direct emission measurement impractical.  Therefore, a more  practical
approach to standards of performance for storage vessels  has been
equipment specification.

     In addition, Section lll(i) authorizes the Administrator to  grant
waivers of compliance to permit a source to use innovative continuous
emission control technology.  In order to grant the waiver,  the
Administrator must find:  (1) a substantial likelihood that  the technology
will produce greater emission reductions than the standards  require or  an
equivalent reduction at lower economic, energy, or environmental  cost;
(2) the proposed system has not been adequately demonstrated; (3) the
technology will not cause or contribute to an unreasonable risk to the
public health, welfare, or safety; (4) the governor of the State  where  the
source is located consents; and (5) the waiver will not prevent the
attainment or maintenance of any ambient standard.  A waiver may  have
                                     2-3

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conditions attached to assure the source will  not prevent attainment of any
NAAQS.  Any such condition will  have the force of a performance standard.
Finally, waivers have definite end dates and may be terminated earlier if
the conditions are not met or if the system fails to perform as expected.
In such a case, the source may be given up to 3 years to meet the standards
with a mandatory progress schedule.

2.2  SELECTION OF CATEGORIES OF STATIONARY SOURCES

     Section 111 of the Act directs the Administrator to list categories of
stationary sources.  The Administrator "...  shall include a category of
sources in such list if in his judgment it causes, or contributes signifi-
cantly to, air pollution which may reasonably be anticipated to endanger
public health or welfare."  Proposal and promulgation of standards of
performance are to follow.

     Since passage of the Clean Air Amendments of 1970, considerable
attention has been given to the development of a system for assigning
priorities to various source categories.  The approach specifies areas of
interest by considering the broad strategy of the Agency for implementing
the Clean Air Act.  Often, these "areas" are actually pollutants emitted by
stationary sources.  Source categories that emit these pollutants are
evaluated and ranked by a process involving such factors as (1) the level  of
emission control (if any) already required by State regulations, (2) estimated
levels of control that might be required from standards of performance for
the source category, (3) projections of growth and replacement of existing
facilities for the source category, and (4) the estimated incremental amount
of air pollution that could be prevented in a preselected future year by
standards of performance for the source category.  Sources for which new
source performance standards were promulgated or under development during
1977, or earlier, were selected on these criteria.

     The Act amendments of August 1977 establish specific criteria to be
used in determining priorities for all major source categories not yet
listed by EPA.  These are (1) the quantity of air pollutant emissions that
each such category will emit, or will be designed to emit; (2) the extent  to
which each such pollutant may reasonably be anticipated to endanger public
health or welfare; and (3) the mobility and competitive nature of each such
category of sources and the consequent need for nationally applicable new
source standards of performance.

     The Administrator is to promulgate standards for these categories
according to the schedule referred to earlier.

     In some cases it may not be feasible immediately to develop a standard
for a source category with a high priority.  This might happen when a
program of research is needed to develop control techniques or because
techniques for sampling and measuring emissions may require refinement.  In
the developing of standards, differences in the time required to complete
                                     2-4

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the necessary investigation for different source categories must also be
considered.  For example, substantially more time may be necessary if
numerous pollutants must be investigated from a single source category.
Further, even late in the development process the schedule for completion of
a standard may change.  For example, inability to obtain emission data from
well-controlled sources in time to pursue the development process in a
systematic fashion may force a change in scheduling.  Nevertheless, priority
ranking is, and will continue to be, used to establish the order in which
projects are initiated and resources assigned.

     After the source category has been chosen, the types of facilities
within the source category to which the standard will apply must be
determined.  A source category may have several facilities that cause air
pollution, and emissions from some of these facilities may vary from
insignificant to very expensive to control.  Economic studies of the source
category and of applicable control technology may show that air pollution
control is better served by applying standards to the more severe pollution
sources.   For this reason, and because there is no adequately demonstrated
system for controlling emissions from certain facilities, standards often do
not apply  to all facilities at a source.  For the same reasons, the standards
may not apply to all air pollutants emitted.  Thus, although a source
category may be selected to be covered by a standard of performance, not all
pollutants or facilities within that source category may be covered by the
standards.

2.3  PROCEDURE FOR DEVELOPMENT OF STANDARDS OF PERFORMANCE

     Standards of performance must  (1) realistically reflect best
demonstrated control practice; (2) adequately consider the cost, the nonair
quality health and environmental impacts, and the energy requirements of
such control;  (3) be applicable to existing sources that are modified or
reconstructed as well as new  installations; and  (4) meet these conditions
for all variations of operating conditions being considered anywhere in the
country.

     The objective of a  program for developing standards is to identify the
best technological system  of  continuous emission reduction that has been
adequately demonstrated.   The standard-setting process involves three
principal  phases of activity:  (1)  information gathering,  (2) analysis of
the information, and  (3) development of the standard of performance.

     During  the information-gathering phase,  industries are queried through
a  telephone  survey, letters of inquiry, and plant visits by EPA representa-
tives.  Information is also gathered from many other sources, and a
literature search is conducted.  From the knowledge acquired about the
industry,  EPA  selects certain plants at which emission tests are conducted
to provide reliable data that characterize the pollutant emissions from
well-controlled existing facilities.
                                      2-5

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     In the second phase of a project, the information about the industry
and the pollutants emitted is used in analytical studies.   Hypothetical
"model  plants" are defined to provide a common basis for analysis.   The
model plant definitions, national pollutant emission data, and existing
State regulations governing emissions from the source category are  then  used
in establishing "regulatory alternatives."  (For the reactor processes
standard, there are a few deviations from this model plant and regulatory
analysis approach, as described in Chapters 6 through 8.)   These regulatory
alternatives are essentially different levels of emission  control.

     EPA conducts studies to determine the impact of each  regulatory alter-
native on the economics of the industry and on the national economy, on  the
environment, and on energy consumption.  From several possibly applicable
alternatives, EPA selects the single most plausible regulatory alternative
as the basis for a standard of performance for the source  category  under
study.

     In the third phase of a project, the selected regulatory alternative is
translated into a standard of performance, which, in turn, is written in the
form of a Federal regulation.  The Federal regulation, when applied to newly
constructed plants, will limit emissions to the levels indicated in the
selected regulatory alternative.

     As early as is practical in  each standard-setting project, EPA
representatives discuss the possibilities of a standard and the form it
might take with members of the National Air Pollution Control Techniques
Advisory Committee.  Industry representatives and other interested  parties
also participate in these meetings.

     The information acquired in  the project is summarized in the background
information document (BID).  The  BID, the standard, and a  preamble
explaining the standard are widely circulated to the industry being
considered for control, environmental groups, other government agencies, and
offices within EPA.  Through this extensive review process, the points of
view of expert reviewers are taken into consideration as changes are made to
the documentation.

     A "proposal package" is assembled and sent through the offices of EPA
Assistant Administrators for concurrence before the proposed standard is
officially endorsed by the EPA Administrator.  After being approved by the
EPA Administrator, the preamble and the proposed regulation are published in
the Federal Register.

     As a part of the Federal Register announcement of the proposed
regulation, the public is invited to participate in the standard-setting
process.  EPA invites written comments on the proposal and also holds a
public hearing to discuss the proposed standard with interested parties.  All
public comments are summarized and incorporated into a second volume of  the
                                     2-6

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 BID.   All  information reviewed and  generated  in  studies  in  support  of the
 standard of performance  is  available  to  the public  in  a  "docket"  on file in
 Washington, D.C.

      Comments  from the public  are evaluated,  and the standard  of  performance
 may be altered in  response  to  the comments.

      The significant  comments  and EPA's  position on the  issues raised are
 included in the "preamble"  of  a promulgation  package,  which also  contains
 the draft  of the final regulation.  The  regulation  is  then  subjected  to
 another round  of review  and refinement until  it  is approved by the  EPA
 Administrator.  After the Administrator  signs  the regulation,  it  is
 published  as a "final  rule"  in the  Federal Register.

 2.4  CONSIDERATION OF COSTS

      Section 317 of the  Act  requires  an  assessment of  economic  impact with
 respect to any standard  of  performance established under Section  111  of the
 Act.   The  assessment  is  required to contain an analysis of:  (1)  the  costs
 of  compliance  with the regulation,  including the  extent to which  the  cost of
 compliance varies  depending  on  the effective date of the regulation and the
 development of less expensive  or more efficient methods of compliance;
 (2) the potential  inflationary  or recessionary effects of the  regulation;
 (3) the effects the regulation  might  have on small businesses with  respect
 to  competition; (4) the  effects of the regulation on consumer  costs;  and
 (5) the effects of the regulation on energy use.  Section 317  also  requires
 that  the economic  impact assessment be as extensive as practicable.

      The economic  impact of  a  proposed standard upon an industry  is usually
 addressed  both  in  absolute terms and  in  terms of  the control costs that
 would  be incurred  as  a result of compliance with  typical, existing State
 control  regulations.  An incremental approach is  necessary because both new
 and existing plants would be required to comply with State regulations in
 the absence  of a Federal  standard of performance.  This approach requires a
 detailed analysis  of  the economic impact from the cost differential  that
 would  exist  between a proposed  standard of performance and the typical State
 standard.

     Air pollutant emissions may cause water pollution  problems, and
 captured potential  air pollutants may pose a solid waste  disposal  problem.
 The total environmental impact of an emission  source must,  therefore, be
 analyzed and the costs determined whenever possible.

     A thorough study of  the profitability and price-setting mechanisms of
 the industry is essential to the analysis so that an accurate  estimate of
potential adverse economic  impacts  can be made for proposed  standards.  It
 is also essential  to know the capital  requirements for  pollution control
systems already placed on plants so  that  the additional capital requirements
necessitated by these  Federal standards  can  be placed  in  proper perspective.
                                     2-7

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Finally, it is necessary to assess the availability of capital  to provide
the additional control  equipment needed to meet the standards  of
performance.

2.5  CONSIDERATION OF ENVIRONMENTAL IMPACTS

     Section 102(2)(C)  of the National Environmental  Policy Act (NEPA)  of
1969 requires Federal agencies to prepare detailed environmental impact
statements on proposals for legislation and other major Federal actions
significantly affecting the quality of the human environment.   The objective
of NEPA is to build into the decision making process  of Federal agencies a
careful consideration of all environmental aspects of proposed actions.

     In a number of legal challenges to standards of performance for various
industries, the United States Court of Appeals for the District of Columbia
Circuit has held that environmental impact statements need not be prepared
by the Agency for proposed actions under Section 111 of the Clean Air Act.
Essentially, the Court of Appeals has determined that the best system of
emission reduction requires the Administrator to take into account counter-
productive environmental effects of a proposed standard, as well as economic
costs to the industry.   On this basis, therefore, the Court established a
narrow exemption from NEPA for EPA determination under Section 111.

     In addition to these judicial determinations, the Energy Supply and
Environmental Coordination Act (ESECA) of 1974 (PL-93-319) specifically
exempted proposed actions under the Clean Air Act from NEPA requirements.
According to Section 7(c)(l), "No action taken under the Clean Air Act shall
be deemed a major Federal action significantly affecting the quality of
human environment within the meaning of the National  Environmental Policy
Act of 1979."  (15 U.S.C. 793(c)(l)).

     Nevertheless, the Agency has concluded that the preparation of environ-
mental impact statements could have beneficial effects on certain regulatory
actions.  Consequently, although not  legally required to do so by
Section 102(2)(C) of NEPA, EPA has adopted a policy requiring that
environmental impact statements be prepared for various regulatory actions,
including standards of performance developed under Section 111 of the Act.
This voluntary preparation of environmental impact statements, however, in
no way legally subjects the Agency to NEPA requirements.

     To implement this policy, a separate section in this document is
devoted solely to an analysis of the  potential environmental impacts
associated with the proposed standards.  Both adverse and beneficial impacts
in such areas as air and water pollution, increased solid waste disposal,
and increased energy consumption are  discussed.

2.6  IMPACT ON EXISTING SOURCES

     Section  111 of the Act defines a new source as". . . any stationary
source, the construction or modification of which is commenced  .  .  ."  after
                                     2-8

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the proposed standards are published.  An existing source is redefined as a
new source if "modified" or "reconstructed" as defined in amendments to the
general provisions of Subpart A of 40 CFR Part 60, which were promulgated in
the Federal Register on December 16, 1975 (40 FR 58416)

     Promulgation of a standard of performance requires States to establish
standards of performance for existing sources in the same industry under
Section lll(d) of the Act if the standard for new sources limits emissions
of a designated pollutant (i.e., a pollutant for which air quality criteria
have not been issued under Section 108 or which has not been listed as a
hazardous pollutant under Section 112).  If a State does not act, EPA must
establish such standards.  General provisions outlining procedures for
control of existing sources under Section lll(d) were promulgated on
November 17, 1975, as Subpart B of 40 CFR Part 60 (40 FR 53340).

2.7  REVISION OF STANDARDS OF PERFORMANCE

     Congress was aware that the level  of air pollution control  achievable
by any industry may improve with technological advances.   Accordingly,
Section 111 of the Act provides that the Administrator "...  shall, at
least every four years, review and, if appropriate, revise ..." the
standards.  Revisions are made to assure that the standards continue to
reflect the best systems that become available in the future.   Such
revisions will not be retroactive, but  will  apply to stationary  sources
constructed or modified after the proposal  of the revised standards.
                                    2-9

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              3.  DESCRIPTION OF PETROLEUM REFINERY WASTEWATER
                          SYSTEMS AND VOC EMISSIONS

     This chapter presents a description of petroleum refinery wastewater
systems.  Section 3.1 provides general information about the petroleum
refining industry and also presents an overview of petroleum refinery
wastewater systems.  Section 3.2 describes the processes used in the waste-
water system and emissions from these processes.  Section 3.3 presents
growth estimates for the source category while Section 3.4 presents baseline
emissions from petroleum refinery wastewater treatment systems.

3.1  INTRODUCTION AND GENERAL INFORMATION

     Wastewater is generated by many of the refining processes used by the
petroleum refining industry.  This wastewater is collected by a plant wide
sewer system, which carries the flow to a treatment system.  An introduction
to petroleum refining processes and the related wastewater collection and
treatment systems is presented in the following sections.  Section 3.1.1
presents a general discussion of the petroleum refining industry, while
Section 3.1.2 covers sources of wastewater from petroleum refining.

3.1.1  Petroleum Refining Industry

     The petroleum refining industry is defined by Standard Industrial
Classification  (SIC) Code 2911 of the U.S. Department of Commerce.  SIC
Code 2911 includes facilities primarily engaged in producing hydrocarbon
materials through the distillation of crude petroleum and its fractionation
products.  As of January 1, 1984, there were 220 operating refineries in the
United States.  They are distributed among 34 states with 44 percent of the
refineries located in Texas, California, and Louisiana.  This represents 18,
17, and 9 percent of the total number of refineries, respectively, in these
three states.  Approximately 28 percent of the total crude refining capacity
is located in Texas.  California contains 15 percent of the total crude
capacity while  Louisiana holds 14 percent.1  The geographic distribution of
U.S. refineries is shown in Figure 3-1.

     The refining industry in the United States has experienced a reversal
in growth trends as a result of the reduction in consumption of petroleum
products that has occurred since 1978.  U.S. crude oil runs peaked at
14.7 million barrels per day in that year.  Crude oil runs have decreased
each year since then reaching 12.5 million barrels per day for 1981 and
11.5 million barrels per day in early 1982.  Since January 1, 1981, more
than 75 refineries have discontinued operations.  It is expected that
refinery activity will recover somewhat and projections for 1985 and 1990
estimate crude  oil runs of 14.4 million barrels per day and 13.4 million
barrels per day, respectively.2

-------
oo
                Alaska - 4
                Hawaii - 2
                Figure 3-1.  Geographical Distribution of Petroleum Refineries in the United States
                             as of January 1, 1984.

-------
     Based on the above forecasts, very few, if any, new refining facilities
will be built at undeveloped sites over the next 10 years.  However, it will
be necessary for refineries to modernize and expand downstream processes at
existing refinery sites to allow increasingly heavier and higher sulfur
crude oils to be processed.2  This will allow for the production of lighter
and higher quality products that will be demanded by the marketplace.3  In
1980, approximately 15 percent of the crude processed in the United States
was heavy, with a sulfur content over 1 percent.  This quantity will have to
increase as 85 percent of foreign crude reserves and 58 percent of U.S.
crude reserves have a high sulfur content.4

3.1.2  Overview of Petroleum Refinery Wastewater Systems

     Most petroleum refineries use some type of wastewater collection and
treatment system as part of their operations.  These systems are designed to
collect wastewater generated during the refining process as well as storm
water run-off from the facility grounds.  Wastewater is treated by various
means to remove contaminants such as hydrocarbons and phenols.  The specific
design of such a system will depend on the quantity of wastewater generated,
the contaminant concentration, and the necessary level of treatment.
Generally a wastewater collection and treatment system will consist of the
following:5

       •  A drainage and collection system;
       •  Gravity oil-water separators;
       •  Air flotation systems for further oil removal from the
          separator effluent, if necessary; and
       •  Secondary treatment, if needed, following oil removal.

     Figure 3-2 illustrates the components of an example petroleum refinery
wastewater system.  As shown, wastewater is collected by individual drains
located throughout each process unit area.  The drains feed into a series of
lateral sewers which converge into junction boxes.  Wastewater from the
junction boxes is led  to the oil-water separators by gravity flow or
pumping.  These separators can either be small units which handle the  flow
from one process unit  or a group of process units,  or they can be large
separators which handle the wastewater from the whole refinery.  Air flota-
tion may also be used  after the oil-water separators if secondary oil
removal is necessary.  Following oil removal, secondary and tertiary treat-
ment processes can be  used to further  improve wastewater quality before
discharge.  Refineries which dispose of wastewater  by direct discharge  into
surface waters must meet effluent guidelines established under the authority
of the Clean Water Act (40 CFR 419).   Refineries which direct their
wastewater to a Publicly Owned Treatment Works  (POTW) must meet pretreatment
standards which have also been established under the authority of the  Clean
Water Act.6  Refineries may also dispose of some or all of their wastewater
in disposal wells, surface ponds located on site, or through contractors.7,8
Others not discharge any wastewater.9   Table 3-1 lists the various
processes which can be used by a refinery and the objectives of each
treatment stage.

-------









Process
Unit
o o o 5^^
~ ^


Branch
Dra i n

r




Process
\ \ni t

000^

\
i
u .

Drain


[] Possible Location of


Slop Oil
Tank











-, ! Trunk
t
\

Drain


'


Junction

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                    TABLE 3-1.  CLASSIFICATION OF REFINERY WASTEWATER
                                   TREATMENT PROCESSES
Treatment
      Objectives
  Example Processes
Primary Treatment
Intermediate Treatment
Secondary Treatment
Tertiary Treatment
Free Oil and Suspended
Solids Removal
Emulsified Oil, Free
Oil, Suspended Solids,
and Colloidal
Solids Removal
Dissolved Organics
Removal, Reduction
in BOD and COD
Final Polishing
API Separators
Parallel Plate Separators
CPI Separators

Dissolved Air Flotation
Induced Air Flotation
Coagulation-Flotation
Coagulation-Precipitation
Filtration

Activated Sludge
Trickling Filters
Aerated Lagoons
Oxidation Ponds
Rotating Biological Contactors

Carbon Adsorption
Filtration
                                    3-5

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     A facility's wastewater system can consist of separate collection  and
treatment systems each designed to handle wastewater streams containing
similar levels of contamination.10,11   A simplified flow diagram of a
segregated system handling four basic  types of wastewater is shown  in
Figure 3-3.  The non-oily sewer system collects wastewater that does not
contain significant quantities of oil.  This water can be directed  through
oil-water separators which can remove  oil from leaks or spills.11*  The  oily
cooling water sewer handles wastewater which has been lightly contaminated
with hydrocarbons from leaks in the heat exchanger equipment and from
stormwater runoff.  This water can also be treated by oil separation before
it undergoes secondary treatment or is discharged.ltf  Process water
originates from a variety of processes which use water or steam, and may
contain oil, emulsified oil and various chemicals.  This wastewater is
usually treated by oil separation and  may require further secondary
treatment.12  Sanitary wastewater from lavatories and locker rooms  must be
treated by an inplant sewage treatment facility or it can be discharged to  a
local POTW.12

     3.1.2.1  Sources of Refinery Wastewater.  A petroleum refinery is  a
complex operation consisting of a number of interdependent processes.   Over
150 separate processes were identified in a 1977 EPA survey of the  petroleum
refining  industry.15   Each refining process consists of a series of unit
operations which cause chemical and physical changes in the feedstock or
products.  Each unit operation may have different water usages associated
with it.  The wastewater is generated by a variety of sources including
cooling water, condensed stripping steam, tank draw offs, and contact
process water.

     The  total wastewater  flow generated by a refinery varies from one
refinery  to another.  Some of the factors which influence the quality of
wastewater produced are:

          •  the process configuration of the refinery;
          •  age of refinery and degree of good "housekeeping" practiced
             within the refinery;
          •  the degree of air-cooling and of wastewater reuse to minimize
             the overall water demand of the refinery;
          •  type of  cooling water system;
          t  whether  or not the refinery handles  tanker  ballast water; and
          •  annual rainfall at the refinery.16

Some of  the major sources  of wastewater within  a  refinery are shown in
Table  3-2.  This  table provides a brief description of the  specific
wastewater sources  from each of these processes,  the U.S. production
capacity  for the  process,  and  the estimated wastewater generation  rates.  As
can  be seen from  this table, the wastewater may not be directly discharged
to the sewer system.  It may first undergo  some type of  treatment,  such as
steam  stripping  for the removal of sulfides, mercaptans  and  phenolics.
Additionally,  the discharge of cooling water blowdown  from  the cooling water
                                    3-6

-------
     Non-OHy Water
         -  cooling tower blowdown (€5  and lighter)
         -  oil-free storm water { from non-tank and non-process area)
         -  once through cooling-water  (£5 and lighter)
         -  steam turbine condenser water
         -  boiler blowdown
         -  water treatment plant filter backwash
         -  roof drainage
Clean Water
Sewer
Emergency
Oil-Water
Separator
Oily Cooling Water (Light Contamination)
- cooling tower blowdown (C$ and heavier)
- once through cooling water (Cq and heavier)
- oily storm water from tank and process area
Oilv Cool i no -^
Water Sewer

API Separator




Air Flotation

	 ^"~

GO
 I
     Process Water  (Oily-Water)
         - desalter water
         - tank  drawoffs
         - steam stripper bottoms (sour water strippers)
         - cooling water from pumps and compressor jackets,  glands and pedestals
         - barometric condenser water
         - contact process water and condenced stripping steam from fractiona-
           tion  columns
Oily Water Sewer
API Separator
                                            Air Flotation
     Sanitary Waste
                              mitarv
                                            Secondary
                                            Trea tment
                                                                                                                             12  13
                            Figure 3-3.    Example  of a  Segregated Wastewater Collection  and  Treatment System.   »

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                                      TABLE  3-2.   WASTEWATER  SOURCES AND GENERATION RATES  17>18>19>20
CO

CO
Process
Crude Separation
Crude Storage
Desalting
Atmospheric
Distillation
Process
Description Waste Water Sources
Store crude oil in tanks Residual water in crude
Removal of salt, water Water washing
and water soluble
compounds from crude
Separates light hydro- Condensed stripping steam
carbons from crude in a from overhead accumulator
distillation column under
atmospheric pressure
U.S.
Process
Capacity
MMB/SD
>6.9
>6.9
>6.9
Waste Water Generation Factors (Gal/bbl)
Direct Indirect.
to Via
Sewer Cooling-Tower
2.0
0.002
0.3
Direct Via Direct Via
Sour Water Chemical
Treatment Treatment Total
2.0
2.1 - 2.1
0.04 -- 0.3
Gas Processing
Separates gases,  such as
LPG;  fuel gas; isobutane;
butylene and light
naphtha, from the light
ends  of the atmospheric
distillation unit
Caustic and water wash
N/A      0.08       0.07
                                                                                                                3.2
                                                                              3.3
Vacuum
Distillation
Hydrogen
Production
Light Hydrocarbon
Processing
Naphtha Hydro-
desulfurization
Separates heavy gas oil
from the bottoms of the
atmospheric distillation
unit, under a vacuum
Produces hydrogen from
either light hydocarbons
( s team-hydroca rbon
process) or heavy oils
(partial oxidation
process). Used for hydro-
treating processes
Removes sulfur and nitro-
gen from naphtha stream
from atmospheric distil-
lation through catalytic
treatment with hydrogen
Jet ejectors, 6.9 0.8 1.3
barometric condensers
Partial oxidation: 1900.0 65.0 46.0
water quench/wash (MMcfd) (MMcfd) (MMcfd)
Steam-hydrocarbon :
caustic and water wash
Condensed stripping 6.6a 0.06 0.4
steam from overhead
accumulator
5.2 - 7.3
111.0
(MMcfd)
1.4 -- 1.9

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                                                            TABLE  3-2.   (Continued)
Process
Catalytic
Reforming
Process
Description Waste Water Sources
Converts low octane Condensed stripping steam
naphthas into high octane from overhead accumulator
gasoline blending compounds
by contacting feedstock
with hydrogen over a
catalyst
U.S.
Process
Capacity
MMB/SD
3.9
Waste Water Generation Factors (Gal/bbl)
Direct
to
Sewer
0.22
Indirect
Via
Cooling-Tower
1.0
Direct Via
Sour Water
Treatment
0.004
Direct Via
Chemical
Treatment Total
1.2
       Isomerization
Converts n-butane,
n-pentane and n-hexane
into their respective
isoparaffins
                                                      Caustic washer
                               N/A
          0.24
           1.0
                                                                                                                                           1.2
      Alkylation
CO

10
Catalytically combines
an olefin with an
isoparaffin to form high
octane gasoline blending
compounds
Overhead accumulator on
fractionation tower,
caustic washer (sulfuric
acid alkylation process)
0.92
0.41
                                                                                                         5.7
                         0.40
                                                       6.5
      Middle and Heavy
      Distillate
      Processing

        Chemical Sweeting  Chemically removes
                           mercaptans,  hydrogen
                           sulfide and  sulfur
                           Water washers, caustic        N/A        N/A
                           washer, spent caustic
                                                   N/A
                                   N/A
                                     N/A
                                  N/A
Hydrodesulfuri-
zation



Removes sulfur, nitrogen
and metallic compounds
through catalytic
treatment with hydrogen

Overhead accumulator on
fractionator (steam
strippers), sour water
stripper bottoms

1.9 0.088

0.12


0.95

0.58


5.2 — 0.2
(kerosene)
3.4 — 4.1
(light
gas/oil )
      Catalytic Cracker
Converts heavy petroleum
fractions to lighter
products using a  high-
temperature catalytic
process
Overhead accumulators
and steam strippers on
the fractionator, catalyst
regeneration
6.0
1.1
3.0
                                                                                                                       5.4
                                                       9.5

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                                                             TABLE  3-2.  (Continued)
Process
Process
Description
U.S.
Process
Capacity
Waste Water Sources MMB/SO
Waste Water Generation Factors (Gal/bbl)
Direct Indirect Direct Via Direct Via •
to Via Sour Water Chemical
Sewer Cooling-Tower Treatment Treatment Total
       Hydrocracking
                     Converts heavy petroleum
                     fractions to lighter
                     products using a cata-
                     lytic cracking in the
                     presence of hydrogen
                            High  and  low pressure
                            separators,  accumulator
                               fractionator
                              0.94
            0.64
                                                                                                         0.81
                                                                 3.0
                                                         4.5
                                                       on
       Lube Oil Processing
       solvent refining
                     Removal  of aromatics,
                     unsaturates,  naphthenes
                     and asphalts  from lubri-
                     cating-oil  base  stocks
                     using  solvents such as
                     furfural  or phenol
                            Bottom  from  fractionation     0.23
                            towers, contact process      (est)
                            water
                                       11.0
                      1.6
                                                                                                                                          13.0
to
 i
Dewaxing
Removal of wax from
lubricating-oil  base
stocks using solvents,
such as MEK or propane,
under reduced temperature
conditions.
Compressor cooling
0.23(est)   5.8
6.7
                                                                                                                                           12.5
Lubricating-oil
finishing
(hydrotreating)
Residual Hydro-
Carbon Processing
Visbreaking
Removes sulfur, nitrogen
and metallic compounds
through catalytic treat-
ment with hydrogen
Reducing the viscosity of
residual feed materials
through mild thermal
cracking
Overhead accumulator 0.23 H/A N/A
on fractionator
Accumulator on the N/A N/A N/A
fractionator
N/A - N/A
N/A N/A N/A
      Coking
                    Converts crude oil residue
                    and tar pitch products
                    into gas, oil, and
                    petroleum coke by a
                    thermal cracking process
                           Contact process water and    N/A
                           steam overhead accumulators (56 T/D)
                                        31
                     2.6
              0.70
6.4

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                                                           TABLE  3-2.   (Continued)
Process
Deasphaltlng
Process
Description Waste Water Sources
Removes asphaltic Steam jet ejectors,
materials from heavy condensers
oil and residual
fractions using solvent
extraction
U.S.
Process
Capacity
MMB/SD
N/A
Waste Water Generation Factors (Gal/bbl)
Direct
to
Sewer
N/A
Indirect
Via
Cool ing-Tower
N/A
Direct Via
Sour Water
Treatment
N/A
Direct Via
Chemical
Treatment
N/A
Total
N/A
     alncludes:  Pretreating catalytic  reformer feeds;  naphtha desulfurizing; naphtha,  olefin or aromatics saturation;  straight run distillate;

                other distillate;  lube-oil polishing.
OJ
i
         Notes:
                N/A:  Not Available

                MMB/SD:  Million Barrels per Stream Day

-------
system can be considered an indirect discharge to the  sewer system.   There
are also general  sources of wastewater not specific to any  one  process  which
are not listed in the table.  These sources include pump  and compressor
cooling water, pump and compressor seal  water, stormwater runoff,  equipment
washing, steam traps, and leaks or spills.

     Based on the information presented  in Table 3-2,  the processes  which
generate the largest volume of wastewater are catalytic cracking,  vacuum
distillation, crude desalting and crude/product storage.   Additionally, the
wastewater streams from these processes  contain high concentrations  of  oil,
emulsified oil and COD as shown in Table 3-3.  Thus, these  streams may  be
the major sources of VOC compounds in the wastewater.

     The specific source of wastewater within each process, as  shown in
Table 3-2, will vary depending on the process design and  operating
characteristics.   A general evaluation can be made of  some  of the  major
sources of wastewater, as follows:

Crude Oil and Product Storage.  During storage, a water layer accumulates
below the oil and is drained off at intervals.  The water layer is likely
saturated with VOC which is often carried along as a water  emulsion  when the
water layer is drawn off to the sewer.

     Water associated with crude may come from the production unit or from
the ballast water used by tankers and product vessels. Tankers used to ship
crude and products generally use water as ballast.  The crude is loaded on
top of the ballast water, most of which  is displaced during loading.
However, large quantities of water may remain as emulsion.   This emulsion
often does not break and the water cannot be removed by the tanker crew. A
significant quantity often remains and is pumped along with the crude to the
refinery.22

Crude Desalting.   Desalters are a major source of oil  and oil-water  emulsion
loss to the refinery sewer system.23  An oil-water emulsion is  purposely
formed in the desalter to allow salt removal.  Most emulsions are  likely to
pass through oil-water separators and are, therefore,  potential sources of
VOC emulsions throughout the refinery wastewater system.

     When the emulsion is not completely resolved into two components,  an
interface of emulsion forms and builds up to the point where it is period-
ically discharged to the oily sewer system through the water outlet.  Such
an emulsion interface is usually stabilized with solids from the repro-
cessing of slop oil and the use of stripped foul water.  Additionally,
wastewater containing various removed impurities is discharged  from  the
desalter to the wastewater system.  Some of these desalting processes
require holding the crude at high temperatures. The temperature of the
desalting wastewater often exceeds 95°C.22  Such high  temperatures may  cause
VOC to volatilize from the wastewater system.
                                    3-12

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                             TABLE 3-3.  QUALITATIVE  EVALUATION OF WASTEWATER  CHARACTERISTICS  BY FUNDAMENTAL
                                          REFINERY  PROCESSES21
u>
Fundamental Processes
Crude Oil and Product Storage
Crude Oil Desalting
Crude Oil Distillation
Thermal Cracking
Catalytic Cracking
Hydrocracking
Reforming
Polymerization
Alkylation
Isomerization
Solvent Refining
Dewaxing
Hydrotreating
Drying and Sweetening
BOD
1
2
1
1
2
--
0
1
1
--
--
3
1
3
COD
3
2
1
1
2
--
0
1
1
--
1
3
1
1
Phenol
--
1
2
1
3
--
1
0
0
—
1
1
—
2
Sulfide
—
3
3
1
3
2
1
1
2
--
0
0
2
0
Oil
3
1
2
1
1
--
1
1
1
—
—
1
--
0
Emulsified
Oil
2
3
3
—
1
--
0
0
0
--
1
0
0
1
ph
0
1
1
2
3
—
0
1
2
—
1
--
2
2
Temp.
0
3
2
2
2
2
1
1
1
--
0
—
--
0
Ammonia
0
2
3
2
3
--
1
1
1
—
—
—
0
1
Chlorides
_
3
1
2
1
—
0
1
2
--
—
—
0
0
Acidity
0
0
0
0
0
--
0
1
2
—
0
--
0
1
Alkalinity
_
1
1
2
3
—
0
0
0
-_
1
--
1
1
Susp.
Solids
2
3
1
1
1
—
0
1
2
—
—
--
0
2
       3  -  Major Contribution

       2  -  Moderate Contribution

       1  -  Minor Contribution

       0  -  Insignificant Contribution

       --  -  No data

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Overhead Accumulator Fractlonation Column.   Overhead vapors from
fractionation columns are condensed and collected in an accumulator,  as
shown in Figure 3-4.  The water originates  from condensed stripping  steam
and residual water in the feed.  The water  is separated from the product in
the accumulator and discharged to the wastewater treatment system.   Since
this water has been in direct contact with  the product it can contain
soluble hydrocarbons.25  This type of wastewater source can be found  in  many
processes which use distillation for product separation.   These processes
include atmospheric distillation, catalytic reforming, hydrodesulfurization,
and cracking operations.

Steam Jet Ejectors/Condensers.  A steam jet ejector is a device which uses
one fluid to pump another.It is usually used as a vacuum pump for
distillation columns.  In this device, high velocity steam is discharged
across a suction chamber that is connected  to the equipment being
evacuated.26  Figure 3-5 shows an example of a steam jet ejector.

     After the ejector, a condenser can be  used to condense the vapors.26
This can either be a direct contact (barometric) or surface type (shell  and
tube) condenser.  Of the two types, barometric condensers generate  the
largest quantity of wastewater, as the vapors from the column are condensed
by direct contact with a water spray.  Since the water directly contacts the
vapors, it can contain soluble and emulsified oil.26

Cooling Tower Slowdown.  A portion of the water used for non-contact cooling
water must be regularly discharged in order to control the build up  of
dissolved solids in the system.  This water may contain VOC from leaks in
the heat exchanger equipment.14

     3.1.2.2  Future Trends in Refinery Wastewater Generation.  The  future
trends in petroleum refinery wastewater production depend on many variables.
These variables include future environmental regulations, new refinery
technology, new refinery feedstocks, and water reuse and conservation
practices.  Environmental regulations relating to both water and air
pollution control will affect wastewater generation.  More stringent water
regulations may result in further water conservation practices or addition
of wastewater treatment facilities.  Regulations controlling air pollutants
from refinery boilers and process heaters may require flue gas scrubbers
which would result in additional wastewater generation.27

     New refinery technology  is constantly being developed.  Although it is
difficult to predict technology development, it can be predicted with some
certainty that refineries will become increasingly complex.  Increased
complexity  in a refinery has  been shown to result in increased wastewater
generation.  This has been demonstrated in one study which compared
wastewater  production of a topping and integrated refinery.27

     As mentioned in Section  3.1.1., future crude supplies will be higher in
sulfur content.  Processing higher sulfur crude oils will require more
                                     3-14

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       CRUDE CHARGE
GAS  TO LPG
 RECOVERY
SALT WATER
                                                                                       LSR GASOLINE
                                                                                       TO TREATING
                                                                                         NAPHTHA
                                                                                         GAS OIL
                                                                                      TOPPED CRUDE  TO
                                                                                        VACUUM TOWER
                   Figure 3-4.  Atmospheric Distillation  System.
                                                                        24
                                              3-15

-------
                                    MTER
          SUCTION
                        STEM
J
                                                STEM
                                            T
                                        FIWE INCINERATOR
                                                    TO
                                   MTER AND CONDENSABLE*
Figure  3-5.   Two-Stage Steam  Actuated Vacuum Jet System.
                                                               28
                              3-16

-------
 hydrogen  synthesis  units.   Hydrogen  synthesis  units  require  large amounts of
 steam which  will  lead to increases  in  wastewater  production.  Some of  the
 increases in wastewater production will  be  offset by the  trend  towards water
 conservation.   Water conservation in a refinery will  include practices such
 as:

      •  replacement of once through  cooling water systems with  circulatory
         systems using evaporative cooling towers;
      t  raising the level  of concentration  cycles  within  existing
         circulatory cooling water systems by reducing the amount of
         blowdown;
      • more usage  of air-cooling rather than  water-cooling, and
      • more intensive efforts  to reduce water-cooling and steam heating
         needs  by  using more process  heat recovery.

 3.2   PETROLEUM REFINERY WASTEWATER PROCESSES AND  VOC EMISSIONS

      As discussed in Section 3.1.2,  a  basic petroleum refinery wastewater
 treatment system  consists  of a  drain system connected to a series of
 treatment steps.  This  section  will  discuss each of  the major components in
 this  system.   The sources  and factors  affecting emissions, and emission
 estimates from major sources will be presented.  The components examined
 include process drain systems,  oil-water separators, air flotation systems
 and miscellaneous treatment processes.

 3.2.1  Process  Drain  Systems

     Although  the number of process drains may vary widely among refineries
 and individual  process  units, the general layouts of process drain systems
 are similar.   The process  drain system,  the types of process drains, and the
 emissions  from  process  drains and junction boxes are described below.

     3-2.1.1   Description  of Process Drain System.  In petroleum refineries,
 oily water from various sources enters the oily water collection system
 through numerous, generally  small, individual  process drains.  Many of these
 drains are open to the  atmosphere.  The  numbers of these drains in
 refineries have been  estimated to be more than 1000 in some medium-sized
 refineries and in excess of 3000 for some large refineries.29,30,35

     The general principles of refinery drain  systems are well
defined.5,30,32  Details of the individual  drain systems  do vary,  however,
depending on the needs of a specific facility  and on the  design  choices made
by individual refiners.  Variations  can include pipe size, type  of traps,
processes handled, and type of junction boxes.

     A generalized refinery drain system is  conceptually  illustrated  in
Figure 3-6.  Liquid  is collected in  individual  small  drains  distributed
throughout each process unit.  Some  drains may  be  dedicated  to a single
piece of equipment (e.g., a single pump), while others might  serve  several
                                   3-17

-------
                     REFINERY  PROCESS UNIT
U)
I
CO
1 I

/ k i
Ltrr's /"i"
\ i/ i

f r-i
	 I..-*.! i
' '
. i
Junction
1SPrs Boxes
TTJ" ";


6 6 o
Trunk
j -i
. J Branch
1 i Sewer
!___]
Junction Box
REFINERY PROCESS UNIT

| 	 1
' Branch
"' ' Sewer
1 1
1 	 _J
Junction Box
Tn Uactc
Sewer
» Watp
                                                                                     Treatment
                                        Figure 3-6.   General  Refinery Drain System.

-------
sources.  In some cases, these drains may be completely closed instead of
open to atmosphere.  The individual  drains are connected directly to lateral
sewer lines.  There may be several  lateral lines in a process unit.   The
lateral sewers from the process drains flow into junction boxes,  which
provide effective vapor seals.  The  vapor seals prevent hydrocarbons from
backing up into other lateral  lines  and confine any fire or explosion to a
small area.

     The wastewater leaves the junction boxes through branch lines.   Branch
lines from refinery units and  processing areas generally flow through a
gas-trap manhole before entering the trunk line system.  The gas-trap
manhole is often located at the boundaries of the process unit and prevents
vapor from the trunk system from backing up into the sewer lines.  Manholes
also serve to isolate the individual branch lines.  Because the function and
structure of junction boxes and gas-trap manholes are similar, both will be
referred to collectively as junction boxes in this document.

     The trunk sewer system carries  wastewater from the branch sewers to the
wastewater treatment system.  The number and configuration of lateral,
branch, and trunk lines vary considerably among refineries.

     Current design practice normally provides for segregated wastewater
sewers.  Storm drainage systems are  separated from oily water drains and
sewers.  Clean process water and condensate may also be drained into the
storm drains.  In some cases,  additional wastewater streams, such as foul
water, may have separate drain and sewer systems33.  Separate systems, such
as storm drains, may also be configured with lateral, branch, and trunk
sewers.  Storm water runoff is generally collected by open troughs or sumps
covered with iron or steel grating and located below grade.

     In general, the refinery  sewer  system is designed for gravity flow of
the liquid.  Pumping of wastewater is minimized because of the tendency to
form oil-water emulsions.  In  cases  where pumping cannot be avoided, special
pumps are used to reduce the formation of emulsions.

     3.2.1.2  Process Drain Types.   Several types of individual drains are
used in petroleum refineries.   These types of drains are shown in
Figure 3-7.  A configuration common  in older refineries is shown  in
Configuration A. A straight section  of pipe, usually four to six  inches in
diameter, extends vertically to a height of 4-6 inches above grade.   The
pipe is connected directly to  a lateral sewer line with the pipe  directed
either straight down or at an  offset.  There is no liquid seal to prevent
vapors from rising from the lateral  line, which is normally connected to
several other drains.  Drain lines/piping from the various sources within
the process unit generally terminate just within, at, or slightly above the
mouth of the process drain.  There is often more than one drain line
directed to a single drain opening.
                                   3-19

-------
  V/7T
                  DRAIN
                  PIPE

                  DRAIN
                  RISER
                                                               DRAIN
                                                               PIPE
                     (ALTERNATE OFFSET
                    .  CONFIGURATION)
                         \
           OPEN, UNSEALED
           CONFIGURATION A
                                                     P-LEG SEAL
                                                   CONFIGURATION B
V / / / / /
                     DRAIN
                      PIPE
OfUi
                            SEAL
                           " POT
                       / / / / A
              SEAL POT
          CONFIGURATION C
                                                          DRAIN
                                                           PIPE
                                                                 DRAIN
                                                                 RISER
                                                   CLOSED DRAIN
                                                  CONFIGURATION 0
Figure  3-7.   Types  of Individual Refinery Drains  for Oily  Wastewater.
                                 3-20

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     Another drain type used in refineries is shown in Configuration B in
Figure 3-7.  The straight section of the drain inlet is connected below
grade to a "P"-bend which provides a liquid seal  in the individual  drain.
Vapors from the downstream drainage system are prevented from escaping by
the liquid seal.

     An external liquid seal arrangement is shown in Configuration  C.   A cap
covers the drain opening, and the bottom edge of the cap extends below the
level of the drain entrance.  Liquid from the various drain pipes falls into
the drain area outside of the cap and then flows  under the edge of  the cap
and into the drain line.  Thus, the liquid seal  prevents emissions  of those
vapors which may be present in the downstream drainage system.  A "P"-seal
is not needed in this configuration.  The drain cap can be easily removed to
clean the drain entrance and drain line, if necessary.

     A completely closed drain system was observed in one refinery  process
unit.34  This type of drain is illustrated in Configuration D of Figure 3-7.
The drain riser extends about 12-18" above grade.  The top of this  riser is
completely sealed with a flange.  Drain pipes are welded directly to the
riser at points between grade and the flange seal.  In some cases,  an
"extra" drain nozzle is also welded to the riser.  This line is normally
closed with a valve, but provides access to the closed drain system for
intermittent and infrequent needs such as pump drainage.  Hoses or  flexible
lines can be connected to the riser valve from the liquid source.

     All the drains in this system are connected through lateral and branch
drain lines to an underground collection tank.  To avoid the danger of
explosion, the entire system is purged with some type of gas which  does not
contain oxygen (such as refinery fuel gas or nitrogen).  The underground
tank is vented to the flare system.  This closed drain system prevents any
VOC emissions to the atmosphere.  The complete system is shown schematically
in Figure 3-8.

     3.2.1.3  Junction Box Types.  Lateral and branch sewers generally flow
through trapped junction boxes before entering the trunk (and/or branch)
sewers.  The purpose of the junction boxes is to permit ready access to the
sewer lines to facilitate cleaning and inspection, as well as to isolate the
branch or lateral sewers from one another.  This  isolation prevents the
travel of hydrocarbon vapors from one line to another and thus reduces the
area in which a fire or explosion could occur.5  A typical vented junction
box is shown in Figure 3-9.  The junction boxes are normally vented to
prevent siphoning and vapor locks.  A junction box equipped with a  vent seal
pot is shown in Figure 3-9.  A small amount of water flows continually down
the vent pipe and into the seal pot, assuring a continuous seal. A third
type of junction box is shown in Figure 3-10.  This type of junction box is
often referred to as a gas trap manhole.

     Most vents on junction boxes are at least 4 inches in diameter.23
Smaller vents can develop problems such as freezing during low temperatures
                                    3-21

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PROCESS UNIT
 BOUNDARY
        RY       / —
        IL/
LATERAL
 DRAIN
l
T
                         BRANCH
                         SEWER
                        VAPOR TO
                      FLARE SYSTEM
                  FUEL GAS
                   PURGE
INDIVIDUAL
  DRAIN
                                                     OILY WASTE PUMPED
                                                  ^  TO INTERMEDIATE
                                                     STORAGE TANKS OR
                                                    OIL WATER SEPARATORS
                                                     UNDERGROUND
                                                    COLLECTION TANK
            Figure 3-8.  Closed Drain and Collection System.
                               3-22

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 SEAL
WATER
                  -VENT
GAS TIGHT
  COVER
                                              GRADE
                                           -CONCRETE
             WATER-

              (a) TYPICAL JUNCTION BOX




                  VENT
                             SEAL
                              POT
                                             7
        (b) JUNCTION BOX WITH WATER-SEAL POT
      Figure 3-9   Refinery Drain System Junction Boxes
                       3-23

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Vent
                        Gas Tight Lids
                                                   Vent
Figure 3-10.   Gas Trap Manhole.32
                  3-24

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or clogging from gradual deposition of scale and sediment.   The vent usually
drains to the junction box and is free of excessive bends and other
obstructions which might cause blockages.

     3.2.1.4  Factors Affecting Emissions From Process Drains and Junction
Boxes.  VOC are known to be emitted from refinery process drains.dbThe
factors influencing emissions are the composition of wastewater entering the
drain system, drain design characteristics, and climatic factors.
Specifically, these factors include:

        Rate of molecular diffision of compounds through air and water;
        Rate of convection;
        Solubility and vapor pressure of the compounds found in the
        wastewater stream;
        Frequency and composition of wastewater discharge through the drain;
        Wastewater temperature;
        Ambient temperature;
        Wind speed;
        Length of drain or vent pipe;
        Length of water seal; and
        Concentration of compounds in the sewer vapor space and in the waste
        water

      No predictive theoretical or even semi-theoretical models for process
drain emissions have been published.  However, some factors affecting
emissions can be evaluated by theoretical means.  These factors include
diffusion and convection.

      The rate at which molecular diffusion can transport volatile compounds
through air can be calculated by using the following formula:37
                                BT          x '1

 Where:

 N.  =   Flux  (mole/sec)
 A   =   Exposed surface area  (cm2)
 p   =   Molar Density  (mole/cm3)
 By  =   Diffusion path length  (cm)
 Y.  =   Initial concentration  (atm)
 Y   =   Final concentration (atm)
 DV  =   Diffusion coefficient  (cm2/sec)

     The density and diffusion coefficient are both controlled by the
 temperature of the vapor in  the drain pipe.  Thus, the factors which control
 molecular diffusion through  air are temperature, drain design, solution
                                    3-25

-------
density, and the concentration gradient.   Since the coefficient  is  inversely
proportional to the diffusion path length, the greater the drain length,  the
lower the flux rate.  Another controlling factor is the media through  which
the compound is diffusing.  For example,  the diffusion coefficient  for
benzene through air is 0.085 cm2/sec while the diffusion coefficient for
benzene through water is 1.02 x 10-5 cm2/sec.

     The rate of molecular diffusion is very small  and can be overshadowed
by the effects of convection.  This effect was demonstrated by one  study
which showed that the rate of diffusion of hexane through different size
openings was 1.0 to 31.7 times the calculated diffusion rate.38   This  study
was based on the results of laboratory evaluations  of the emission  rates
from different size and shaped fittings placed into covered drums containing
hexane.  These fittings ranged from circular open pipes to complex  shaped
steel support structures.  The rate was found to depend on the design of  the
opening.  A small covered opening had less convective flux than a complex
shaped  large opening.

     Another factor which may influence the convective flux is wind speed.39
One study showed that the mass transfer coefficient for a spilled compound
is proportional to u°'78 where u  is equal to the wind speed.  Convective
flux can therefore  increase the total flux through an uncontrolled drain
pipe.   For a water  sealed drain (with no VOC contamination in the water),
the molecular diffusion through the water layer will control the mass flux
and convection cannot increase this rate.  Thus, water seals can reduce VOC
emissions by eliminating the effects of convection.

     The rate at which compounds  can transfer across the wastewater/air
interface and the resulting equilibrium concentration will also control the
emission rate.  The faster the mass transfer rate, the greater  the potential
for high vapor concentrations.  The state of the compounds (i.e., whether
the compound  is dissolved in the  wastewater  or  in  a separate phase) will
also affect this rate.   The effects of film transport can be assumed to be
negligible.   To estimate  the maximum potential  vapor concentration, Henry's
law can then  be used  to estimate  vapor concentrations over solutions while
the vapor pressure  can be used to estimate the  vapor concentration over an
immiscible  phase.

     The final controlling factor is the  rate  and  composition of the
wastewater  stream entering a water sealed drain.   If the wastewater stream
is highly contaminated, the water seal may become  saturated with the
compounds in  the stream.  Additionally,  if the  compounds  are  immiscible with
water,  they may float on  top  of the water seal.  In either of these cases,
the effectiveness of  the  water seal will  be  negated, and  the  drain will act
as  if  no seal were  present until  the VOC  are weathered  off or drain is
flushed with  fresh  water.   Fresh  water flowing  into such  a drain can  flush
out any residual compounds,  restoring  the effectiveness  of the  water  seal.
                                     3-26

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     3.2.1.5  VOC Emissions From Process Drains.  A study sponsored by the
EPA is the only study in which the emission rate from drains has been
measured.36  A 1958 study of refinery emissions in Los Angeles County
provided an overall emission rate estimate for the combined process drain
and wastewater treatment system.k°  However, this estimate was based
primarily on qualitative observations.  Little, if any, quantitative
emission data were obtained.  Additionally, the VOC emissions from drains
alone cannot be estimated from this information.

     The EPA-sponsored study of atmospheric VOC emissions in petroleum
refineries was published in 1980.36  The results of this study were used to
develop emission factors for fugitive sources, including drains, in
petroleum refineries.  These factors have since been included in EPA's
AP-42.41  The emission factor for refinery drains is 0.032  (0.010, 0.091)
kg/hr-drain.  The numbers in parentheses are the lower and upper limits of
the 95% confidence interval about the average value of 0.032 kg/hr-drain.

     The VOC emission measurements were made on a total of 49 process
drains.36  The ratio of trapped  (liquid-sealed) to untrapped drains in the
sampled population was not determined.  These drains were sampled in  13
different refineries, and the sampled population was intended to be
reasonably representative of refinery practices in the 1976-1979 time
period.  It seems probable that  the majority of the drains were unsealed,
since  it was not common practice to install individually sealed drains.
This is borne out in responses to inquiries of refineries by the California
Air Resources Board  in  1978.30   The responses indicated that the majority of
the refinery drains were not equipped with  liquid seals.   It is assumed  in
this document that the  emission  factor  represents emissions from untrapped
drains.

     An additional screening study of process drain emissions was conducted
at three refineries  in  1983.  The results of this study are discussed in
detail  in  Section  4.1.1.2.  The  purpose of  the  study was to determine the
emission reduction achievable by water  sealed drains.  The  drains were not
bagged and  emission  rates were  not determined.  For this reason, the
screening  values obtained were  not used to  determine an emission factor.

      3.2.1.6  VOC  Emissions from Junction Boxes.  There are no  studies of
VOC emissions from junction boxes.   For the purposes of this document, it  is
assumed that all junction  boxes  are  sealed  and  vented  to atmosphere.   Since
the diameters of the vent  lines  are  in  the  same size range  as those  of
drains,  the mechanism  for  VOC emissions was assumed to be  the same as that
for open,  untrapped  drains.   Under these  conditions, the emission  rate from
junction  box vents was  estimated to  be  the  same as  the emission rate  from
open  drains.  Thus,  the junction box  vent emission  factor  is estimated to  be
0.032  kg/hr-junction box.
                                    3-27

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3.2.2  Oil-Water Separators

     Oil-water separators are commonly used by most refineries  as  the
primary method of separating and removing oil  from oily process water.
Since these separators remove much of the VOC  with the skimmed  oil,  the
units following this process will have lower VOC emissions.k2

     Oil-water separators are the first step in the treatment of refinery
wastewaters.  Most refinery layouts provide sufficient difference in
elevation between the oil-water separator and  the various areas being
drained to cause the oily process waters to flow by gravity to and through
the oil-water separator.   Some refineries have installed small oil-water
separators close to the source of the oily-water.  This minimizes the
formation of emulsions which cannot be removed by a separator and provides
overall improvements in efficiency of VOC recovery.10,"  The operation of
oil-water separators and the emissions from this system will be discussed in
more detail in the following sections of this chapter.

     3.2.2.1  Types of Oil-Water Separators.  All oil-water separators rely
on  the  different densities of oil, water, and solids for successful
operation.  Within the separator, the wastewater stream is led to a
quiescent zone where the various phases  separate.  Oils and solids with
specific gravities less  than that of water float to the top of the aqueous
phase,  while heavy sludges and  solids sink to the bottom of the vessel.  As
mentioned earlier, oil-water separators  will  not break emulsions nor will
they separate substances in  solution.^

     The most commonly used  type of oil-water separator is the American
Petroleum  Institute  (API)  type  separator.  A  typical API separator  is  shown
in  Figure  3-11.   In API  separators, the  influent wastewater passes  through
trash  bars  and  a  skimmer (the forebay)  before entering the quiescent zone of
the separator  (main bay).   In this quiescent  zone, the wastewater velocity
 is  kept very  low  to prevent  any turbulent  mixing.  Here, free  oil droplets
 rise to the surface where  they  coalesce.1*6  The  resulting oil  layer is then
 skimmed from  the  water  surface  at  the downstream  end of the tank.

      Several  types  of skimmers  are currently  used  including  rotary  drums,
 slotted pipes,  and  floating  oil  skimmers.47   These can  be used in both the
main bay and  forebay.   In  the main bay,  slowly  moving  paddles  or  a  water
 spray  can  be  used to  direct  the oil  layer  to  the  end  of the  tank where it
 can be skimmed.   API  separators have  been, for  many years,  constructed with
 reinforced concrete.tt8   However,  at  least  one supplier offers  fiberglass
 packaged units.49

      Other separator designs have been  developed that enhance  the coalescing
 of oil droplets and therefore improve the  oil  removal  efficiency  of the
 unit.   Collectively,  these separators can  be  referred to  as  enhanced  oil-
 water separators.  The  most commonly used  enhanced oil-water separator is
 the corrugated plate interceptor (CPI).
                                     3-28

-------
CO
 I
IN3
                             Tr*«h r«ck
                             Pltfform
                                                          Deilgned for Imtrting rubber

                                                          b»lloon ttoppert. lor diverting llowi »nd-
                                                          tot clttnino lepMctor section. Sluice gttit

                                                          or gat* v»lv*t mty b« lmtct<«d If d*tlr«d.
                                                                                                   Sklmm»d-ol| pump
                           Covtr lorcbty
                             lfd«lr*d
                   Flight icr*p«r chain iprocktt
                                       OH cklmn»ri
                                                                                 WoodfllBhticrtpw
                             Oil rtUnllon b»fl|i
               Diffusion device (vertical b»fll«)

                                                                                                       ON iklimner
                                                                                                              \
                                                                                                               \
                                                                             Flow
                                                                          6*ctlon A-A
                                                                                                                 Oil-retention bilfli
                           Note:
This diagram is  not to  scale.   A  typical  API  separator  is  about
15  feet wide by  60  feet long.
                                              Figure  3-11.   Oil-Water Separator.
                                                                                         45

-------
     A corrugated plate interceptor, shown in Figure 3-12, consists of a
number of parallel corrugated plates mounted from 2 to 4 cm apart at a 45°
to 50° angle to the horizontal.   Between 12 and 48 plates are typically
used.  Wastewater flows downward between the plates, with the lighter oil
droplets floating upward into the tops of the corrugation, where they
coalesce.  The oil droplets move up the plates to form a floating layer that
is skimmed from the surface of the treatment tank.49  These systems do not
use moving paddles to collect the oil on the surface nor are sludge rakes
used.

     By using these plates the effective coalescing surface area in a CPI  is
increased.  Thus, for the same wastewater treatment capacity a CPI will have
a smaller surface area than a corresponding API separator,.  This smaller
surface area enables the systems to be supplied as prefabricated units,
usually including a cover.  Manufacturers offer prefabricated systems which
can handle flow rates from 2 gpm to 2,000 gpm.

     3.2.2.2  Major Factors Affecting VQC Emissions.   Volatilization of
organic compounds from the oily surface of an oil-water separator is a
complex mass transfer phenomenon.  The force behind the volatilization
process is the drive to reach equilibrium between the oil layer and the
atmosphere.  This driving force can be considered to be the difference in
partial pressure of a compound between the two phases.51  The rate at which
volatilization will occur per unit surface area can be assumed to be
proportional to the difference between the vapor pressure of a compound in
the liquid phase and its partial pressure in the gas phase.

     Four studies have examined the physical and chemical factors which
control this transfer process.  One study, conducted by Litchfield52, used
a small hot water bath to simulate the operating conditions of a API
separator.  Tests were conducted by placing weighed pans of actual API
separator influent oil in the hot water bath.  After 24 hours the pans were
reweighed and the losses calculated.52  The results of this study related
the percent volume loss of oil in a separator to the ambient temperature,
influent wastewater temperature, and the 10 percent true boiling point of
the influent oil.  The 10 percent point is an indication of the oil's vapor
pressure.  The lower the 10 percent true boiling point, the higher the vapor
pressure.

     The relationship developed by Litchfield is as follows:52

            V = -6.6339 + 0.0319X - 0.0286Y + 0.2145Z

     where:
               V = Percent volume loss after 24 hours
               X = Ambient temperature (°F)
               Y = 10% point (°F)
               Z = Influent temperature (°F)
                                    3-30

-------
OJ
 I
CO
,,OH«Mromtr      OHUytr^
                                                                                        Ad|utt*bl« InUf v«lr
                                                                                                                    Conerttt
                                                          V *•'•
                                                       -'      "$ V-'t
                                                  Oil|»obule»   /J *A«*.
                               nstmbly con«l«ln9 of
                           24 or
                           pir»IUI pl»ltl
                     CUtn-wtur -"
                     outlet channtl
                                                         8«dl(n«nl trip
                        ConcrtM
                                           Figure  3-12.   Corrugated  Plate Separator.
                                                                                             50

-------
     This equation predicts losses within 2.58 percent with a  confidence
limit of 95 percent.   These three independent variables accounted  for
82 percent of the total  losses.52  The factors not taken into  account  during
this study include the thickness of the oil  layer, the average wind
velocity, and the surface area of the separator,  all  of which  can  affect  the
emission rate.

     The results of the  study showed that ambient temperature  had  the  least
effect on the percent volume of oil lost.  For each 10°F increase  in ambient
temperature, a 0.3 percent increase in losses was experienced, shown in
Figure 3-13.  As shown in Figure 3-14, a 20°F decrease in the  10 percent
point of the influent oil will increase losses by 0.6 percent.  Influent
temperature had the greatest effect on the loss rate  amounting to  a  2.2
percent increase in losses for every 10°F increase in temperature, as  shown
in Figure 3-15.

     The second study, by Jones and Viles53, concluded that the variables
controlling air emissions from API separators were the vapor pressure  of  the
influent oil and the wind speed over the basin.  Figure 3-16 shows the
results of this study.  As can be seen, an increase in either  the  wind
velocity or the vapor pressure will increase the  emission rate.

     Several other factors can also affect the VOC emission rate including
surface area of separator, time of exposure (frequency of oil  skimming) and
oil layer thickness.5k  These factors are interrelated, as the size  of the
separator and frequency  of oil removal will  control the oil layer  thickness.
This oil layer may suppress VOC emissions because the volatilization of VOC
from the oil layer will  change its composition as more volatile compounds
are lost.55  If no fresh oil is mixed with the surface oil layer and the
rate at which VOC can diffuse into this layer is  small, the emission rate
could decrease with time.  The weathered oil layer could then  act  as a
blanket and suppress vapor emissions.

     Two theoretical  models for predicting VOC emissions from  separators
were developed by the Shell Oil Company.  The first model predicts the mass
transfer of VOC from an  open flat oil surface into a  well developed  wind
profile.  The air is assumed to flow over flat terrain before  encountering
an oil surface that is level with the terrain.  Mass  transfer  is assumed  to
be gas phase controlling.  The mass transfer coefficient is calculated based
on an eddy diffusion model that includes a logarithmic distribution  of wind
speed with height.56

     The second model developed by Shell is based on  the Sherwood-Pigford
correlation and the Colburn j factor.  This correlation is based on  a
boundary layer solution  of momentum transfer for  flow over flat plates.   The
Sherwood-Pigford correlation is used to calculate the average  mass transfer
coefficient which is then used to estimate the average mass flux of  VOC.56
                                   3-32

-------
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1° 11 12 13 14 15 16 17 18 19 20
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Note: Constant 10% point of 300°F
Figure 3-13.   Effect of Ambient  Air  Temperature  on  Evaporation.52
                          3-33

-------
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         10   11  12   13   14   15   16  17   18   19   20


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         Mote:  Ambient Temperature of 40°F and influent

                temperature of 140°F
         Figure 3-14.  Effect of 10* Point on Evaporation.52
                               3-34

-------
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        Note:   10% point of 300°F and ambient air
               temperature of 40°F
Figure 3-15.   Effect  of  Influent Temperature on Evaporation.52
                          3-35

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O.iS
0.16
                          Vapor presure (psia)
     Figure 3-16.   Relationship between Vapor Pressure, Wind Speed, and
                   Loss  Rate.
                                    3-36

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      A  method  for  applying  the  second model to  predicting emissions from
 site  specific  separators was  also  developed by  Shell.  This method is based
 on  measuring the evaporation  rate  of a  specific  liquid hydrocarbon from open
 pans  placed in the oil-water  separator.  The measured volatilization rate is
 then  adjusted  by a series of  correction factors  to estimate the
 volatilization rate of  the  separator oil.  Correction factors were developed
 for the boiling point of the  test  liquid, temperature of the liquid surface,
 wind  speed, height of the measurement of wind speed, and length of the
 liquid  surface.56

    .3.2.2.3   VOC  Emissions From Oil-Water Separators.  The earliest
 detailed study of  VOC emissions from oil-water separators was performed in
 1958  in Los Angeles County.57  This study estimated the emissions from
 sumps,  drains  and  API separators to range from 30 kg/1000 m3 of crude to
 600 kg/1000 m3  of  crude with an average refinery emission rate of
 2700  kg/day.58  Based on this average rate and a reported wastewater flow of
 31.9  million gallons per day, the emission factor was 85 kg/MM gallons of
 wastewater flow.58  The emission factor listed in AP-42 is based on the
 600 kg/1000 m3  of  crude value reported by the Los Angeles County study.kl

      There have been many changes since 1958 in the quantity and quality of
 wastewater generated in refineries and the associated emissions.  In
 addition to decreasing wastewater flow, industry has  reduced the amount of
 oil lost to the wastewater streams.59  These two trends  would  indicate that
 the emission factors determined in 1958 are higher than  today's  or at least
 that the lower end of the range is more representative of today's
 operations.

     Due to the large surface area size of oil-water  separators  and the
 physical/chemical  characteristics of oil,  it is  difficult to make  direct
measurements of VOC emissions.59  Recent estimations  of  VOC  emissions  have
 been based on  the  study done by Litchfield.   A  discussion of these emission
estimates follows:

               American  Petroleum Institute60.  The  API estimated an
               annual  emission rate for an  API  separator  based on  the
               factors  shown in  Table  3-4.   The  results,  based on
               Litchfield's  study,  showed  an  estimated 12 percent
               volume  loss.   This  results  in  an  emission  factor  of
               600  kg/MM gallons  of wastewater using  an  influent oil
               concentration of  0.15%  (1500  ppmV) and a specific
               gravity of 0.88.

               State of  California61. The State  of  California, in  1979,
               estimated the annual  emission rates  for the API
               separators located  in their State.  The bases for these
               calculations  are shown in Table 3-4.  California
               estimated that  about  half the separators at refineries
               in the State  were completely covered.  From these,  VOC
               emissions were  thought to be minimal.  Most of the  oil-
               water separator systems at the remainder of the
                                   3-37

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                          TABLE 3-4.  FACTORS FOR CALCULATING EMISSION LOSSES USING THE
                                             LITCHFIELD METHOD60'61

Study
API
California
Ambient
Temperature
(°F)
50
65
Influent
Temperature
(°F)
120
110
10%
Point
(°F)
300
300
Influent
Cone.
(ppmV)
1,500
2,000
Flow
(gpm)
5,000
17,500a
Refinery
Caoacity
(ms/day)
16,000
192,000b
Emission
Rate o
(kg/1000 mj
of crude)
256
68
Volume
Percent Loss
(%)
12
10


      aFlow of wastewater in all of California to  uncovered  separators.
CO
<       Total  State refining capacity.

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                refineries were partially covered.   Often a covered
                primary separator was followed by an uncovered
                separator.  For the  oil -water separator systems that
                were partially covered, 950 cubic meters (6000 bbls)  per
                day of oil entered oil-water separators in the State.
                The State assumed that 80 percent of the 950 cubic
                meters per day of oil was recovered  in the covered  part
                of separators.   That is, 760 cubic meters per day of  oil
                were recovered and 190 cubic meters  per day entered the
                uncovered part of the separator.  Litchfield's method
                was used to  estimate a volume loss  rate of 10 percent
                which equals  an emission factor of 666 kg per MM gallons
                of wastewater for the uncovered portion of the
                ^eponnn°rs',,  The  1>nlet o1 T  concentration was  assumed to
                be 2000 ppmV.
   P    rh         IaCt°rS  deve1°Ped by API  and the State of  California using
 API s«SUnJ« fnUdy "T be US6d t0 Calcu1ate the current emissions from9
 infinoK   •?       !6Vera1 reasons-  Both of these studies use higher
 influent oil concentrations than recent industrial contacts  and a review of
 current data have indicated.  As refineries are trying to reduce both ?he
 quantities of wastewater generated and the amount of oil  contamination  a

 The^h P±° PpmV°;1%)  °1r 8?° r"9/L' is a more accu?aie ?ur^! S?L?e.
 The high emission factor calculated by the API study was based on wastewatPr
 generation rates which have been significantly reduced since tha? studv was

 ba°s n'oft   AP? ^ ^ ^ the Calif°^a Stud* -«J2d Sat
 onTfor      Par
develoedmhveMthfe?5ed ^ She11 ^  m°re C0mp1ex than  the
developed by Litchfield.  However, these models are more  applicable to site
fiPld  t^51lCaT0n!-  Addl'tionally, neither model has beePn ISeq ately
                   f
     data   hi     hf2r6i ^^ th^ LUchfield method is basedon measured
                                                       method  for
from
present day refineries.   The  influent temperature was selected based on
  *a  "     fd " S6Veral refine^"    These temperature        °
..»tsrsa-r--

        /U '" emiS$1°n faCt°r °f 42°  kg/MM 9allons of wastewater wa     °
                                  3-39

-------
   TABLE 3-5.  DATA USED TO CALCULATE EMISSION FACTOR

Ambient Temperature:                          65°F
Influent Temperature:                         120°F
10% True Boiling Point:                      300°F
Influent Oil Concentration:                 1000 ppmV (880 mg/L)
Specific Gravity:                             0.88
                         3-40

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     A recent study by the State of California estimated a wastewater to
crude throughput ratio of O.5.59  Using this estimate, the VOC emission
factor of 420 kg/MM gallon of wastewater is equivalent to 56 kg/1000 md
crude.

3.2.3  Air Flotation Systems

     Air flotation is commonly used in refinery wastewater treatment systems
to remove free oil, colloidal solids, emulsified oil and suspended solids.
Air flotation usually follows the oil-water separator and precedes
biological treatment.  The air flotation process, types of air flotation
systems, and emissions from air flotation systems are described below.

     3.2.3.1  Description of Air Flotation Systems.  In air flotation
systems, bubbles are formed by introducing gas or air directly into the
wastewater by mechanical means.  These bubbles become attached or entrained
with free and emulsified oil, suspended solids, and colloidal solids,
causing the combined density of these substances to be less than the density
of the liquid phase.  The bubbles, therefore, create a buoyancy which allows
these substances to rise to the surface of the flotation chamber where they
are  removed.  The basic mechanisms by which air or gas bubbles intereact
with  suspended substances are shown  in Figure 3-17.65,65

      Two types of air flotation systems are used in petroleum refinery
wastewater treatment.  These are the dissolved air flotation system  (DAF)
and  the induced air flotation system (IAF).   Both systems rely on basic
flotation principles for removing free and emulsified oil, colloidal and
suspended solids.  However, the two  systems have a number of mechanical and
structural differences.  Each system will be  described separately followed
by a  general comparison of  the two.

      Dissolved Air Flotation.   In a  DAF system, wastewater is saturated with
air  or gas under pressure and passed into a flotation chamber at atmospheric
pressure.  The reduction  in  pressure results  in the formation of small
bubbles which interact with  colloidal  and suspended solids and free  and
emulsified oil, and carry these to the surface of the flotation chamber.
Here, the floated material  is removed  by mechanical flight scrapers.65  A
DAF  system is shown  in  Figure 3-18.

      The  DAF can be divided  into a number of  sub-processes:   1) pretreatment
of the waste stream,  2)  solution of  the gas,  3) dissolution  of the  gas,
4) mixing of the gas  bubbles  and wastestream;  5) flotation of the colloidal
and  suspended solids  and  free and emulsified  oils,  and  6)  removal and
disposal  of  the floated material.  The overall design of the system  varies
from site to site  and depends on the needs  of the  refinery.  Pretreatment  of
the  waste stream can  consist  of pH adjustment and/or  the addition of
chemical  coagulants  followed  by flocculation.  The  coagulation/flocculation
process  assists flotation by  breaking  the colloidal suspensions and oily
emulsions in the wastewater and by forming  a  floe which  can  easily  interact
with bubbles in the  flotation chamber.  Commonly used coagulants  include
 lime, ferric chloride,  alum,  and various-cationic  polyelectrolytes.68,69


                                     3-41

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                      Precipitation of the
                      gas oo the solid or
             Solid
               oil globule
                                                    Collision of ruing gu
                                                    bubble and suspended
                                                          phase
                        / Contact angle

           Gas-bubble   Gas bubble has
                                                  O
                                              Rising air bubble

A)   Adhesion of  a bubble  to  a  solid or liquid  surface
                        Contact angle
                                        Floe structure
                      O  O
                   Rising gas bubbles

B)   Trapping of  gas  bubble in a  floe  structure
                       Suspended solids
            Gas-bubble      I
              nuclei        *
             formation    f~\
            O
                     O
                           O
                                                              Gas bubbles are
                                                            trapped within the 3oc
                                                           or in surface irregularities
                              O
Rising gas bubble
Gas bubble
                    Rising gas bubble

C)   Incorporation of gas  bubbles  into  floe structure
  Figure  3-17.   Interaction of Gas  Bubbles with Suspended Solids  or
                  Liquid  Phases.65
                                     3-42

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                                                   Motor & gear
CO


co
Skimmings hopper
                                                Rising-air
                                                bubbles with
                                                attached oil
                                                                                     Pressure Releasing Valve
                                                                                                            ZJ
                                                                                                     Oily-water influent
                               Figure  3-18.   Dissolved  Air  Flotation  System (DAF).67

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     Air  is most commonly used as the flotation gas in a DAF system.
 However,  nitrogen and  natural gas have also been used in refinery applica-
 tions.70,71  The choice of the gas is dependent on cost, availability, and
 safety  considerations.  Nitrogen and fuel gas can reduce the likelihood of
 an  explosion in the  flotation system.

     Three principal modes are used for pressurizing and mixing gas with the
 wastewater stream.   In full stream pressurization, the entire influent is
 pressurized, aerated,  and then released to the flotation tank.  In split
 stream  pressurization, a portion of the influent is pressurized, aerated,
 and then  mixed with  the remainder of the influent after reduction in
 pressure.  And finally, recycle pressurization involves recycling a portion
 of  the  effluent which  is then pressurized and mixed with the influent after
 reduction of the pressure.

     DAF  flotation tanks can be rectangular or circular.  Retention times
 and quantity of recycle water are variable.  Skimming mechanisms also vary
 from system to system.

     Induced Air Flotation. Induced air flotation has been used extensively
 in  the  mining industry for ore beneficiation.  Only recently has the IAF
 been introduced as a treatment process for refinery wastewater.  In induced
 air flotation, bubbles can be produced by the following techniques:
 (1)  mechanical shear or propellers; (2) diffusion of gas through a porous
 medium, or (3) mixing of a gas and liquid stream.72  The bubbles formed
 interact with suspended solids and oils and carry these substances to the
 surface of the IAF where they are removed by a surface skimmer.  Two types
 of  IAF  systems are commonly used for treating refinery wastewater.  These
 are  the impeller type, which use mechanical shear, and nozzle type systems,
 which mix gas and a liquid stream.

     The  impeller IAF is the older of the two systems.   It consists of a
 rotating  impeller suspended between a cylindrical  stand-pipe and draft tube.
 Rotation of the impeller generates  a liquid vortex flow pattern with a gas
 liquid  interface.   The interface extends from the midpoint of the inner wall
 of  the standpipe through the interior of the impeller section down to the
 upper portion of the tube axis.   The gas cavity formed within the vortex
will be at sub-atmospheric pressure.   As a result, gas from the  vapor space
 of  the flotation cell is induced through gas inlet ducts into the interior
of the rotor.   Impeller rotation causes liquid to circulate upward from the
 bottom of the cell.   The liquid  and gas phases are mixed by the impeller and
gas  bubbles are formed.  Further gas liquid mixing occurs when the waste-
water passes  through a disperser which  surrounds  the impeller.   After
escaping the  mixing region,  gas  bubbles enter a quiescent region of the
cell.  Here,  the gas bubbles  attach to  suspended  materials  and  rise to the
surface of the cell  where they are  removed.73  The mechanisms of an impeller
 IAF are shown in Figure 3-19.
                                    3-44

-------
             Air Induction
Two Phase

Mixing
              |gyn;BftXXPMy^JjM««t^*J
              tt^_
^
       ft
                           i
                          Gas Control Valve
I    I
                       )  V
    N


    J
Float
          Figure 3-19.  Mechanism of an Impeller Type IAF.
                                        73
                        3-45

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     The nozzle  IAF is mechanically simpler than the impeller type.  In the
nozzle  IAF, treated effluent is recycled to the flotation cells.  Air or gas
is drawn into the liquid by means of the venturi effect and bubbles are
formed  through agitation of the liquid-gas mixture.  The gas bubbles formed
in the  nozzle type are distributed throughout the flotation cell as opposed
to the  concentration of bubbles in the upper portion of the impeller type.
A nozzle type IAF is shown in Figure 3-20.

     Both the nozzle and impeller IAF systems are multi-staged units usually
consisting of four flotation cells in series.  Contaminant removal
efficiency increases as wastewater moves from cell to cell.  Chemical
conditioning can also increase the efficiency of both IAF systems.

     Comparison of DAF and IAF Systems.  The DAF and IAF systems have been
shown to be equally effective in removing oil and suspended solids from
refinery wastewater when operated properly.71*  For both systems, the factors
affecting flotation performance include influent characteristics, hydraulic
loading, chemical conditioning, and the operation of the skimmer.
Additionally, DAF performance can be influenced by the recycle rate and gas
pressure while the performance of an impeller IAF is influenced by impeller
speed and impeller submergence level.  A DAF is characterized by relatively
quiescent flotation, high retention times, and usage of small quantities of
(dissolved) gas.  An IAF is a more turbulent system, has lower retention
times,  and uses large quantities of recirculated (ambient) gas.  Both
systems can be improved by chemical conditioning.  A DAF, because of the
quiescent flotation, may be more suitable for use with a wide range of
chemical coagulants.  An impeller IAF has a tendency to inhibit floe
formation because of the sheering action of the impellers.  However, the
nozzle  type IAF does not subject the floe formed to high sheering and is
therefore better suited for chemical  conditioning.68,7*

     3.2.3.2  Factors Affecting Emissions.  The factors affecting VOC
emissions from air flotation systems  are much the same as those affecting
emissions from API separators.   Five factors which are the same include:

          quantity of VOC in wastewater entering the air flotation system;
          exposed surface area  of the system;
          temperature of the wastewater;
          ambient temperature;  and
          wind flow across the  surface of the flotation chamber.

     The above factors were discussed in detail  in Section 3.2.2.2.   The
quantity of VOC in wastewater entering the air flotation system is dependent
on the processes preceding air  flotation.   Most of the light end VOC would
be expected to be removed from  the wastewater in preceding processes.   An
increase in the concentration of volatile  compounds in the influent oil,
however, will  increase the emission rate.52,53
                                    3-46

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       Gas Drawn Down
         Standpipe
Delivery Tube From
Recirculation Pump
Float

                                                           Skimmer
      Figure  3-20.   Mechanism  of a Nozzle Type  IAF.
               73
                             3-47

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     Factors affecting emissions which are unique to air flotation include:

          •  use of air or gas used for flotation; and
          •  physical design characteristics of the flotation system.

Use of Gas for Flotation

     A factor which is unique to air flotation systems is the introduction
of a gas into the wastewater.  This gas could act to strip out volatile
hydrocarbons.  The factors which control the stripping rate include the
surface area available for transfer (interfacial area), air flow rate,
temperature, and residence time of stripping.75  This relationship can be
expressed as follows:73

          C  - s = (C -S)-(k)(A)(t)/(V)
           T»         0

     where:    C.  =  Final concentration (mg/L)

               C   =  Initial concentration (mg/L)

               S   =  Concentration of unstrippable compounds (mg/L)

               A   =  Area available for transfer

               V   =  Volume of liquid (L)

               T   =  Residence time (min)

               K   =  Constant

     Although first order kinetics may not be applicable to all  the
compounds in the wastewater stream, it has been shown to be true for some
compounds and waste streams from petroleum refining and petrochemical
manufacturing.75,76  This equation can be simplified by assuming that the
compounds in the wastewater are completely soluble and that an overall
mass-transfer coefficient, K, can be used in place of the term (k)(A)/(V).75
This coefficient is a function of many factors including air flow rate,
water temperature, and tank configuration.

     The relative amount of emissions due to air stripping and evaporation
was estimated by examining the properties of an example VOC, benzene.
Theoretical calculations were performed to estimate the emissions of benzene
due to air stripping as well as evaporation from a DAF system.  The
operational and design characteristics of the DAF system were assumed to be
the same as an actual refinery DAF system tested by the EPA.77  The
characteristics are given in Table 3-6.

     The emissions due to air stripping can be estimated by using the above
equation.  The overall mass transfer coefficient was not readily available
in the literature.  Experimental studies of another compound, acetone,
                                   3-48

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   TABLE  3-6.  TYPICAL  DAF  DESIGN CHARACTERISTICS77'80
 Volume of DAF System:
 Influent Flow:
 Recycle
 Air Temperature
 Wind Speed
 Diameter of DAF
 Area
 Residence Time:
 Initial Concentration:
 Concentration of Unstrippable Compounds:
Air Flow Rate:
 174,000 gallons
 1,800 gallons/minute
 520 gallons/minute
70°F
16,000 meters/hr
15.8 meters
          p
197 meters
1.25 hr
700 mg/L
0 mg/L
1.5 cfm
                         3-49

-------
indicate a value of 0.006/hr for K at the low air flow used in DAF systems.
Based on this value, the mass-transfer coefficient for benzene can be
related to that for acetone by the following equation:78

               KB . (NpR)B2/3  (Nsc)B-2/3

               KA   (NpR)A2/3  (NscV^


     where:
          KR   = mass-transfer coefficient for benzene
          1C   = mass-transfer coefficient for acetone
         / M   A
         ^ PR'B = Prandtl number for benzene =  4.37

         (NpR)/\ = Prandtl number for acetone = 22.3

         (NSC'B = Schmidt number for benzene =  0.299

         'NSC'A = Schmidt number for acetone =  0.32

      Based on this  equation,  the mass-transfer coefficient  for benzene is
 0.0096/hr.   Using  this  coefficient and the  DAF parameters  shown  in Table
 3-6,  the benzene losses due  to  air stripping  are  estimated  to be  0.3  kg/MM
 gallons of wastewater.

      The emissions due  to  evaporation of benzene  from the  DAF system can  be
 estimated by using relationships  developed  for calculating  emissions  from
 oil  spills.   One method based on  mass transfer theory and  laboratory
 experiments  closely agrees with field data.79 This  equation, based  on first
 order kinetics,  is as follows:

      f,   r.  _ ~\ k  ) \ n) \ r ) \ t }l \ n . )
      C = C  e    g             t
      where:

           C  = Mass of compound remaining (mg)
           C  = Initial  mass of compound (mg)
           k° = Mass transfer coefficient (/atm hr)
           A9 = Surface area  (m2)
           P  = Vapor pressure of compound (atm)
           t  = Time  (hr)
           n  = Total number  of moles of liquid in float

         .               0.78  ri-0.11s  -0.67
      and: .     0.0292  y	d     be	
           K  =              —^
      where:
            y  = Wind  speed  (m/hr)
            d  = Tank  diameter  (m)
            S  = Gas-phase Schmidt  number =rl.76
            Rc = Gas constant =  8.206  x  10   atm m3/(mole  K)
            T  = Temperature (K)
                                     3-50

-------
      Based on these equations and the input variables given in Table 3-6,
 the emission rate of benzene due to evaporation is estimated to be 2.6 Kg/MM
 gallons.  This shows that emissions due to air stripping are small (less
 than 10% of total emissions) compared to the losses due to evaporation.  It
 should be noted that the total benzene emissions of 2.9 kg/MM gallons
 estimated by the theoretical calculations compares with measured emissions
 of 3.1 kg/MM gallons during EPA tests.  The details of these tests are
 presented in Appendix C.

 Design Characteristics

      The physical design characteristics of air flotation systems are also
 important factors influencing emissions.  The flotation chamber in a  OAF is
 usually open to the atmosphere where ambient conditions such as wind  speed
 can increase volatility of the VOC.   Therefore, the flotation chamber will
 be the major emission point for a  DAF.

      IAF systems, on the other hand, are usually supplied with  a  cover
 This consists  of a roof and two access doors on each  of the  four  flotation
 chambers.   These doors  can be gasketed and  sealed  to  reduce  emissions.
 Further, lAF's  are usually equipped  with a  pressure/vacuum relief valve so
 that the system can be  operated gas  tight.   One study  showed that the access
 doors  and  pressure/vacuum relief valves  are the major  point  of  emissions
 from IAF systems.81

      The action  of the  skimmer  mechanisms in  both  DAF  and  IAF systems  can
 also affect  emissions.   If a  skimmer is  not in  operation,  a  film  of oil will
 form on  the  surface  of  the flotation tank and inhibit  the  release  of  VOC
 Constant skimming  of the oil  allows  for  greater mass transfer of  VOC  to the
 atmosphere.  The  effect  of skimmer operation  on VOC emissions was  observed
 during emissions  testing of a DAF.77

 .,  ^ 3.2.3.3  VOC  Emissions From Air Flotation  Systems.  Emissions from air
 notation systems were estimated from  the results of EPA tests on  five  air
 flotation systems.   These  tests were performed  on one DAF and four IAF
 systems.  The details of the tests are included in Appendix C of this
 document.

     Three of the  IAF systems and the DAF system treated oily process
wastewater while one IAF system treated only non-oily wastewater.   The
 influent wastewater characteristics of the DAF and three lAF's treating oilv
process wastewater were similar.  As expected, the influent wastewater
characteristics of the IAF treating non-oily wastewater differed greatly
from the other four systems.  Therefore, only emissions results  from the
tests of the four systems treating  oily wastewater were used  to  estimate an
emission factor.


aivenT?n Shll*? ?f *??  ^i^5  USed t0 est1mate the emission factor are
given in Table  3-7.  It  should be noted that air purging was  used  to test
                                   3-51

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               TABLE 3-7.  SUMMARY OF RESULTS OF EPA TESTS ON
                           AIR FLOTATION SYSTEMS77'82'83
Refinery
Chevron
Golden West
Phillips
Phillips
Air Flotation
     Type
     DAF
     IAF
     IAF
     IAF
   Emission
Factor (kg VOC/MM
gal Wastewater)
     30.0
     21.2
      5.0
      4.5
     1572
                                    3-52

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 all four systems.  Therefore, the emission results represent the emission
 potential of the systems rather than the actual emissions resulting from a
 system operating under normal conditions.  The discussion and calculations
 given in the preceding sections have shown that air stripping is not a major
 cause of VOC emissions from a DAF system.  Since evaporation losses are the
 major cause of VOC emissions, the emission potential  of IAF and DAF systems
 would be equal if both are considered to have flotation chambers open to the
 atmosphere.  The air purging of the systems during the tests created
 conditions similar to those that would exist if both  types of systems were
 open to the atmosphere.

        As shown in Table 3-7, the VOC emissions measured at these systems
 varied over a wide range.  This  variation could be due to design and
 operational differences between  the systems, differences in the concentra-
 tion of hydrocarbons  in the wastewater,  or differences in the purge rate
 used during the tests.   Therefore,  to account for these variations  and due
 to the fact that the  emission tests represent emission potential, an average
 uncontrolled emission factor was calculated.   This uncontrolled emission
 factor for air flotation  systems is 15.2 kg/MM gallons of wastewater.
 However,  as discussed previously, an IAF does not normally operate  in  a
 completely uncontrolled state because a  cover is  usually provided   The
 emission  factor for an  IAF  under normal  operating conditions  is  estimated to
 be 3.0 kg/MM gallons  of wastewater.   The derivation of this  emission factor
 is presented in Section 4.1.3.2.

 3.2.4  Miscellaneous  Wastewater  Treatment Processes

     Following  oil-water  separation  and  air  flotation,  wastewater streams
 can  be further  treated  by a  number  of processes as  shown  in Table 3-1  and
 Figure 3-2.   The majority of  the oil  and  VOC  in the wastewater  is removed  in
 primary and  intermediate  treatment.   Hence,  the potential  for VOC emissions
 from the  treatment processes which  follow  is  greatly reduced.  There may be
 situations,  however,  where a processs such as equalization precedes air
 flotation.   In  these  situations, the  emission potential may be higher.  A
 brief description of  the  miscellaneous treatment processes is given below.

     3.2.4.1  Intermediate Treatment  Processes.  The intermediate treatment
 processes discussed in this section include coagulation-precipitation,
 filtration, and equalization.  Air flotation, which represents about 75
 percent of the  intermediate treatment processes, has been discussed in
 detail  in Section 3.2.3.  Coagulation-precipitation and filtration remove
 emulsified oil and suspended solids  which have not been removed in the
 primary treatment processes.  Equalization is used to  balance the quantity
 and quality of the wastewater before entering downstream treatment.

     Coagulation-Precipitation.  Coagulation-precipitation begins with the
 addition of cnemical  coagulants to the wastewater.  Chemicals used for
coagulation include lime,  ferric  chloride, alum, and various cationic
polymers.   The wastewater  and coagulant are then rapidly mixed in a  tank
                                    3-53

-------
which is followed by slow agitation of the mixture in a flocculation
chamber.  The coagulant breaks the oily emulsion by reducing charge
repulsion between particles and allowing the particles to combine and form a
floe structure.  The floe particles are then allowed to settle or float by
gravity in a precipitation or sedimentation tank.8Lf

     Filtration.  Filtration can be used as both an intermediate treatment
process and as a polishing step.  Several types of filtration devices have
been developed for removing free and emulsified oil from refining waste-
waters.  These filters range from units using a simple sand medium to those
containing media which exhibit specific affinities for oil.85

     The filtering medium is usually contained within a basin or tank and is
supported by an underdrain system.  The underdrain system allows the
filtered water to be drawn off while retaining the filter medium in place.
The filter must be frequently backwashed to prevent a buildup of solids in
the medium which would reduce the filtration rate.  The spent backwash water
contains the suspended solids removed from the water and must be treated.86

     Equalization.  Flow equalization is used to balance the quantity and
quality of wastewater before further treatment.  Equalization has been found
to greatly improve treatment results.  Biological processes as well as
physical-chemical systems operate more efficiently if the composition and
flow of the wastewater feed is relatively constant.  Periodic and unpre-
dictable large discharges can occur in any refinery.   Equalization basins
act to minimize the effects of these increased loadings on downstream
treatment processes.

     The size of an equalization system is dependent on the storage capacity
required.  Tanks or basins may be used.  Equalization basins can consume
large land areas.  They are often aerated to maintain aerobic conditions in
the wastewater and to alleviate odor problems.

     3.2.4.2  Secondary Treatment Processes.  The secondary treatment
processes which will be discussed include activated sludge, trickling
filters, aerated lagoons, oxidation ponds, and rotating biological
contactors.  Secondary treatment processes are used to remove dissolved
organics through oxidative decomposition by microorganisms.  The processes
used in each refinery are determined by the flow and contaminant
characteristics of the wastewater to be treated.87

     Activated Sludge.   Activated sludge is a continuous flow, biological
treatment process which uses microorganisms to remove organic materials by
biochemical synthesis and oxidative reaction.  The microorganisms convert
the organics to carbon dioxide, water, and new cell material.  The process
is carried out in a reaction tank where the wastewater is mixed with the
microorganisms in the presence of oxygen.   Oxygen is  supplied to the tank
either by mechanical aerators or a diffused air system.   A clarification
tank follows the reaction tank to allow for liquid-solids separation.  A
                                   3-54

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  portion of the  microorganisms settled out in the clarifiers  is recycled to
  the reaction7tank while the excess is sent to sludge  handling
facilities.87,88
  tnmtlln?    9  Fl1te^.  Trickling filters can  be  used as complete secondary
  treatment  processes or as-pretreatment devices  to  reduce the organic load on
  subsequent activated sludge units.  A trickling filter consists of a  a?ae
  open  topped vessel containing a packed medium that provides a growth site

              nH^h- /a%te!!ater is "*«"y applied to the mediumby a rotary
             and the treated wastewater is  collected in an underdrain system

             n                                                       ~

      flerated Lagoons.  Aerated lagoons are medium depth basins (about 10


  bal   ""Zen uMSlfid'?81^  ?"**? °f waste^ °" • continuous
  oasis,  uxygen is supplied to  the  lagoon by mechanical devices such as

  surface aerators and submerged turbine aerators.  Microorgani  m  convert

  dissolved or suspended organics  in the wastewater to stable organic" ca
            are maintained without mechanical mixing.   Aeration  is achieved

 present"^ thpSnnenrHat ?e SUrfaCe dnd by the Ph°tosynthetic  action of a gae
 present in the pond.  Microorganisms then cause aerobic  degradation of
 organic contaminants in the wastewater. 90               ueyrdaation or



 refinervdwas?P anH^uf6 ^ ??e?-in the past as  the onl^  treatment of
 refinery waste and also as a polishing step for the effluent from physical-

 chemical  or other biological waste treatment processes.  MulticeTlular oonds
 are used in some instances,  especially if the oxidation  pond  s u ed as a
 basic  treatment unit rather than polishing unit.9*


 ic  a Rot.atl'n9  Biological Contactor.    A  rotating biological contactor fRBC)

 toaPthPr  fnJ°S  ?r°'eS? that bn'n9S  wastewater, air, and m croSrgan?sms   }
          r v          ™   py               '.^'ir-  1n
plastic   When the process  is placed in operation, the microbes   n  the
rpmnual  anrl ^v-;^-,4-,-„„ _.r 	 .    ..      ^yuMiu mauler  MI  tne  tank.  BUD

                                         is inversely proportional to the
                                  3-55

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     3.2.4.3   Additional Treatment Processes.  Following secondary
treatment, a number of processes are used to remove dissolved organics and
suspended solids that remain in the wastewater.  These processes include
clarification, polishing ponds, and carbon adsorption.  Filtration, which
has been described under intermediate treatment, may also be used in this
stage of treatment.

     Clarification is used to remove suspended solids by gravity separation
and always follows biological treatment systems.  Clarification tanks can be
circular or rectangular in shape and have a depth of up to 15 feet.  The
settled solids are transported along the bottom- of the tank by a scraper
mechanism.  When following an activated sludge system, clarification helps
to produce a concentrated return sludge flow which helps to sustain
biological treatment.92  Polishing ponds also remove suspended solids by
gravity separation.  The depth of a polishing pond is usually 3 to 5 feet.

     Carbon adsorption can be used to remove non-biodegradable and toxic
organics which may be present in the wastewater after biological treatment.
Activated carbon systems have functioned both as polishing units following a
biological system and as the major treatment process in a physical/chemical
treatment system.  However, the use of activated carbon adsorption processes
has not. been widespread for refinery wastewater treatment.93,94

     3.2.4.4  VOC Emissions for Miscellaneous Wastewater Treatment
Processes.  The majority of the oil in a refinery wastewater is removed by
the oil-water separator.  The effluent leaving the oil-water separator
usually contains oil  and grease concentrations less than 200 mg/1.95
Concentrations may be higher or lower at some plants depending on the design
of the system and the retention time of the wastewater in the oil water
separator.  In general, separators can remove 50 to 99 percent of the
separable oil in a refinery wastewater.89

     Because the concentrations of oil and other pollutants are highest when
entering the separator, the greatest potential for VOC emissions from
treatment processes would be from that source.  Air flotation systems often
follow oil-water separators.  Due to their location in the treatment scheme
air flotation is the next largest potential source of VOC emissions.  As
wastewater continues to move through the treatment scheme, additional
quantities of pollutants are removed and the quality of the wastewater
improves.  Secondary treatment processes also remove organic material by
biological means which further reduces the potential for air emissions.

     A limited amount of emissions data are available for the treatment
processes discussed in this section.  One study estimated VOC emissions from
an activated sludge system while a second study described a theoretical
method for estimating emissions from oxidation ponds.

     In estimating VOC emissions from an activated sludge system, the air
stripping rate for organics in a typical refinery wastewater was calculated.
                                    3-56

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The wastewater flowing to the activated sludge system was assumed to have a
chemical oxygen demand (COD) of 600 mg/1.   Using these two parameters, mass
VOC emissions were calculated for a 90,000 barrel  per day refinery.   The
calculated emission factor was 0.006 pounds per barrel of crude throughput
(17 kg per thousand cubic meters).76   This emission factor is based on
wastewater flow of 50 gallons per barrel  of crude.  Using the estimated
wastewater flow to crude ratio of 0.5, the emission factor would 0.0025
pounds per barrel of crude.  Due to the aeration mechanism and retention
time common in activated sludge systems,  this factor can be assumed  to
represent the maximum emissions which would result from all of the treatment
processes following oil removal.  Very little, if any, VOC would remain in
the wastewater following activated sludge treatment.

     One study indicated that VOC emissions from oxidation ponds can be
estimated by determining the surface area of the pond, the concentration of
the various organic compounds in the wastewater, the molecular weight of the
compounds, and by calculating the overall mass transfer coefficient  of each
compound.96  Actual examples of emissions from oxidation ponds used  to treat
refinery wastewaters were not given.

3.3  GROWTH OF SOURCE CATEGORY

     This section present growth estimates for each emission source in the
source  category.  Section 3.3.1 will discuss growth estimates for process
drains  and junction boxes.  Section 3.3.2 and 3.3.3 will discuss growth
estimates for oil-water separators and air flotation  systems, respectively.

3.3.1   Process Drains and Junction Boxes

     Estimates of new process drains and junction boxes  can be made by
evaluating projected  refinery construction.  Available sources indicate  that
approximately  102 new process units will be built in  the five year period
from 1985 to  1989.97,98,99  These new process units will include
approximately 4,900 new drains  and  1,000 new junction boxes.   In addition to
new units, it  is also expected  that a number of process  units will be
expanded and/or  modified.97  Approximately 180 process units will be
expanded and/or  modified by  1989.   It is estimated  that  10 percent of  the
drain  systems of these process  units will be affected by the
modification/reconstruction provisions of the NSPS.   Therefore,
approximately  5,800 drains  and  1,200 junction boxes will be affected  by  the
NSPS  in the  five year period  from  1985 to  1989.

3.3.2   Oil-Water Separators

     An estimate of new oil-water  separators  to be  built from  1985  to  19fc9
can be made  by evaluating  new construction and expansion of existing
refineries.   New process units  and  expansion  of existing process units will
result in  additional  wastewater generation.   Using  1983  construction
projections,  it  is estimated  that  approximately 136,000  barrels  per day
                                     3-57

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 (5.7 MMgpd)  of wastewater will be produced by new process, units and
 expansion  of existing process units.100,98  Table 3-8 lists these expected
 increases  for some of the major refinery process units.  These units will
 account  for  approximately 124,000 barrels per day of new wastewater.  It is
 estimated  that additional new process units and auxiliary refinery
 operations will produce an additional 10 percent increase in wastewater.
 Therefore, the total estimated annual increase in wastewater production is
 136,000  barrels per day.  It is assumed, based on projected construction
 rates, that  similar wastewater production increases can be expected each
 year from  1985 to 1989.

     Closer  analysis of construction projections shows that a large portion
 of the new process units will not significantly increase wastewater
 generation at a specific refinery.  Unused capacity of existing separators
 should handle any small increases in wastewater.  However, there are a
 number of major construction projects planned which may warrant additional
 oil-water separators.  These projects include greenfield refineries and
 expansion of existing refineries to handle heavy, sour crudes.  Large
 separators may be needed to treat wastewater produced by these projects.
 Further, some refineries use unit oil-water separators to recover oil at the
 source of generation.  Addition of new process units will therefore call for
 the addition of some smaller separators.

     Based on projected refinery construction and subsequent wastewater
 increases, it is estimated that 30 new oil-water separators can be expected
 over the five-year period from 1985-1989.  The majority of these separators
 are expected to be small in size because most of the constructions projects
 are minor.  A few large separators will  be required by major projects.
 Additionally, it was assumed that another 10 percent (3 o'il-water
 separators) may become modified affected facilities during this time period.

 3.3.3.   Air Flotation

     Although addition of a new oil-water separator may not necessarily
 warrant a new air flotation system,  increases in wastewater generation  may
 result in some refineries adding air flotation.   Further, air flotation
 alone may be added in an effort to upgrade existing wastewater treatment
 facilities.  Estimates of new air flotation systems can be derived using the
 growth  estimates for oil-water separators.   Available information indicates
 that approximately 75 percent of the operating refineries use air flotation
 in their wastewater  treatment systems.

     Assuming that the number of new air flotation  systems will  be about
 75 percent of the new oil-water separators,  it is estimated that 25 new air
 flotation systems will  be built over the five-year  period from 1985-1989.
Modified air flotation systems  are assumed  to equal  approximately 10 percent
of the  new air flotation systems  (i.e. 3 air  flotation  systems).
                                    3-58

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                    TABLE 3-8.   PROJECTED  ANNUAL  INCREASE IN REFINERY WASTEWATER FROM 1985 TO 1989
u>
in
Increased
Capacity From
Process New Units (Mbbl/d)
Hydrotreating
Hydro refining
Light Ends
Cat keform/Platformer
Vacuum Distillation
Hydrogen (MM cfd)
Lube Oil
A^kylatior.
Cat Polymerization
Thermal Cracking/CoKing
Hydrocracking
Crude Distillation
FCC

146
136
-
75
-
243.7
-
7.7
11.0
61.2
13.0
80.0
101.0

Increased
Capacity From
Expansion (Mbbl/d)
-
-
23.7
142.0
95.0
-
20.1
-
101.7
99.8
83
19.5

Wastewater Increase
Generation In Wastewater
Factor (gal/bbl) (thousand gal/day)
4.0
2.5
1.2
7.3
111.1
12.1
6.5
-
6.4
4.4
3.4
9.5

584
-
118
1,037
(MM cfd) 37.6
-
180.7
-
1,042
496
554
1,144
5,194 M gal /day
(124,000 bbl/day)

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3.4  BASELINE EMISSIONS

     The baseline emission level  is the level  of control  that is  achieved by
industry in the absence of NSPS.   Baseline reflects the emission  controls
currently required by state regulations.   Section 3.4.1 will  discuss
baseline control for process drains and junction boxes.  Sections 3.4.2 and
3.4.3 will discuss baseline control for oil-water separators  and  air
flotation systems, respectively.

3.4.1  Process Drains and Junction Boxes

     There are presently no specific state regulations controlling VOC
emissions from process drains and junction boxes.  A few refineries do exist
that apply various levels of control to process drains for emission offset
purposes   These control measures  include water sealed or capped drains.
However,  due to absence of  state regulations, new drain systems may or may
not use any  control measures.  Therefore, baseline control for process
drains and junction boxes  is assumed to be no control.

     Current nationwide VOC emissions  from process drains can be estimated
by applying  the  emission  factor given  in  Section 3.2.1.5 to  an estimate  of
the  national drain population.  The nationwide  drain population  can be
estimated by extrapolating  data from the  EPA  study36 and the California
study  30   The  uncontrolled  emission rate  of VOC from an estimated  145,940
drains  is 40.6 gigagrams  per year  (Gg/yr), with an approximate 95  percent
confidence interval  range of 6.6  to 174.2 Gg/yr.   This estimate  does  not
 include  the  uncertainty  in the estimate of total  drain population.

      Current nationwide  VOC emissions  from junction boxes  can  be estimated
 by applying  the emission  factor  given  in  Section 3 2.1.6  to  the  nationwide
 junction box population.   Based  on information  collected  in  the  California
 study30, it  is estimated  that  one junction box  is  needed  for every six
 drains.   Therefore,  the number of junction boxes nationwide  is  one sixth the
 number of drains, or approximately 24,300.  The estimated VOC emission rate
 from junction boxes is therefore 6.8  Gg/yr.

      Based on the emission factors presented in Sections 3.2.1.5 and 3.2.1.6
 and the growth projections presented  in Section 3.3.1, the baselin®  f.  .
 emissions from process drains and junction boxes in the 120 new, modified,
 and reconstructed process  units will  be  1920 Mg per year in 1989.

 3.4.2  Oil-Water Separators

      Nearly all states where petroleum refineries are presently located have
 some regulations controlling VOC  emissions from oil-water separators.   These
 regulations vary considerably due to  provisions for various exemptions  in
 many states    Table 3-9  provides  an overview of existing state  regulations
 applicable  to oil-water  separators.   As  shown  in  the  table, some  states have
 designated  minimum  separators capacity,  emission  level, or  vapor  pressure  as
 criteria for  coverage by regulations.
                                     3-60

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TABLE 3-9.  EXISTING STATE REGULATIONS APPLICABLE TO OIL-WATER SEPARATORS
            IN PETROLEUM REFINERIES.


Alabama

Alaska
Arizona

Arkansas

California
Colorado
Connecticut
Delaware
Florida

Georgia

Hawa i i
Idaho
Illinois
Indiana
Iowa
Kansas


Kentucky
Louisiana

Maine

Maryland
Massachusetts
Michigan

Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire

New Jersey
New Mexico
New York

North Carolina
North Dakota
Ohio


ATTAINMENT NO NO COVER COVER MINIMUM SIZE
AREA SOURCES REGULATION SEPARATORS FOREBAYS OTHER CUTOFF
x sources with potential
to emit < 100 TPY
X
x sources with potential
to emit < 100 TPY
X

X X
X
X
x emits _< 10 Ib/day
x emits < 15 Ib/day
and < 3 Ib/hr
x sources with potential
to emit < 100 TPY
X
X
X
X
X
y
A sources with potential
to emit < 100 TPY
x recovers < 200 gal /day
f
x
sources with potential
to emit < 100 TPY
X
X
x receive > 200 gal /day
VOC ~
X
X
X
X
X
X
V
A source with potential
to emit < 100 TPY
X
X

x x i 200 gal /day
recovered
X
X

x i 200 gal /day
recovered
NOTES






a
b
c













e










g






h
i





                                3-61

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                                            TABLE  3-9.   (Continued)
— 	 ' 	 . 	
ATTAINMENT NO NO
AREA SOURCES REGULATION
Oklahoma
Oregon
Pennsylvania

Rhode Island X
South Carolina X
South Dakota X
Tennessee
Texas


Utah
Vermont X
Virginia
Washington
West Virginia
Wisconsin
Wyomi ng X
District of Columbia X
TOTALS 10 10 2
COVER COVER MINIMUM SIZE
SEPARATORS FOREBAYS OTHER CUTOFF NOTES
X
X
x receive > 200 gal /day
VOC


a
X X

* receive > 200 gal /day e,j
VOC
X
k
x emissions > 7.3 tons/yr, 1
40 Ib/day, and 8 Ib/hr
x emissions < 25 TPY
X
X


25 4 2
NOTES
a.   No 100 TYP sources exist.
b.   California's regulations vary by Air Quality  Management Districts  (AQMD).  Bay Area AWMD exempts separators
     processing < 200 gal/day organic liquids  or organic  liquids with Reid vapor pressure <_ 0.5 psi.  San Diego County
     has no sources.  South Coast AQMD exempts units which handle only  coal tar products and gravity separators used
     exclusively for the production of crude oil if the water  fraction  entering contains less than 5 ppm hydrogen
     sulfide plus organic sulfides and less  than 100 ppm  ammonia.  The  Kern County AQMD exempts separators based on the
     surface area of the separator, the oil  recovery rate, and the estimated fractional volume loss of oil.
c.   Colorado regulation No. 7 provides for  VOC emission  control for oil separation equipment.  Covers listed as an
     option for vapor loss control.
d.   Must install air pollution control equipment  with 85 percent efficiency or more.
e.   Exempts separators used exclusively in  conjunction with crude oil  production.
f.   Requires sealed openings, floating roofs  with closure seals, vapor disposal systsns, or other approved equipment.
     In actual  applications only the forebay on a  separator is required to be covered ° although regulation states all
     components unless exempted.
g.   This reflects the Kansas City area; there are no refineries in the St.Louis area.
h.   No regulations have been established because  emissions from refinery sources are considered insignificant.
i.   New York City Metropolitan Area and upstate New York.
j.   In nonattainment areas, VOC must have a true  vapor pressure of _> 0.5 psia; in certain other counties VOC must have
     a true vapor pressure of >_ 1.5 psia.
k.   All VOC contaminated wastewater must be directed to  the separator.
1.   Vapor control system must be at least 95  percent efficient.
                                                         3-62

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      As a result of state regulations, separators can generally be divided
 into three classes.  State regulations may require separators to be fully
 covered, partially covered, or they may not be regulated.  In order to
 determine the proportion of each type of separator, state agencies in major
 oil refining states were contacted.  In addition, information on individual
 refineries in a number of states was compliled.  Table 3-10 summarizes the
 information obtained.

      The information given in Table 3-10 was used to estimate the level  of
 control required for new separators.  The percentage of covered,  partially
 covered, and uncovered separators in each state was applied to the crude
 throughput in that state.   For example, if it is known that 100 percent  of
 the separators in a state  are required to be covered,  100 percent of the
 crude throughput is assumed to be processed at refineries with covered
 separators.   Crude throughputs were calculated using 1983 refining capacity
 figures and  assuming 60 percent capacity utilization (1982 estimate1")
 Applying the percentages to crude throughput in each state provided an
 estimate of  nationwide  crude  processed at refineries with the  different
 levels  of control.   These  estimates are shown  in Table  3-11.

 iK>m A"ordi"9  to Table 3-11,  the nationwide crude  throughput  in  1983  was
 So   ?n^  5ublc meters  of  crude Per calendar day (lOV/cd).   Of this,
 1348 x  lO^mVcd,  or approximately 85 percent,  was processed at  refineries
      ^e^ated in states requirin9  separators  to  be  covered.   Further,
 o                                                o  e covere.   urer,
42 x 10V/cd, or approximately 5 percent was processed at refineries
required to have partially covered separators.  And the remaining 10 percent
was processed at refineries in states with no regulations.  Assuming that
new refinery construction will be proportional to the current breakdown of
refining capacity by state, it is estimated that 85 percent of the new oil-
water separators will be required to be covered, 5 percent will be required
to be partially covered, and 10 percent will  not be covered at all.

     Current nationwide VOC emissions from oil-water separators can  be
estimated by applying the emission factor given in Section 3.2.2.4 to the
n?vlnate%h  C™de.tnrou9hput given in Table  3-11.   Consideration  must be
             
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                           TABLE  3-10.   SUMMARY OF  BASELINE  CONTROL  FOR OIL-WATER SEPARATORS
GO
 I
CTi
-P*
State
California
- Bay Area
- Kern County
- South Coast
Delaware
Illinois
Indiana
Louisiana
New Jersey
Ohio
Oklahoma
Pennsylvania
Texas
Other States

% Separators % Separators
Fully Covered Partially Covered

100
40
90
100
50
90
80 20
100
100
100
85
100
85

% Separators
Uncovered Comments


60 Only large refineries covered by
regulation
10 Some small refineries may be exempt

50 Some separators exempted by
regulation
10 Smaller refineries may be exempt
Covering forebay only can meet
regulations under exemption
provisions


15

15 85 refineries in these states, 33%
of which are located in attainment
areas
     References:   101,102,103,104,105,106,107,108,109,110

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       TABLE 3-11.  ESTIMATE OF CRUDE THROUGHPUT AT REFINERIES HAVING  VARYING EMISSION CONTROLS
State
California
- Bay Area
- Kern County
- South Coast
Delaware
Illinois
Indiana
Louisiana
New Jersey
Ohio
Oklahoma
Pennsylvania
Texas
Other States
IT : : 	
Total
Crude-Xapacity
(lOV/cd)
397
128
52
217
22
159
74
349
80
82
75
114
721
495
2,568
-, Crude Throughput
Crude Throughput At Refineries With
At Refineries With Partially
Covered Separators Covered Separators
—
772 -
133
1174
132
48
42
167 42
482
492
452
58
4332
2385
1,348 42
Crude Throughput
At Refineries
With Uncovered
Separators


19
13

48
2




10

60
152
 Capacity utilization of 60% used to estimate crude throughput,(Referem e 112)

feState regulations require all  separators to be covered.

 Only three large refineries covered by regulation requiring covers.   This accounts for 40% of
 crude throughput.
4.

 Assumes 90% of crude throughput designated to covered separators.   Some small refineries assumed
 to oe exempt.

 Assumes 85% of crude throughput designated to covered separators.

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3.4.3  Air Flotation Systems

     There are currently no state regulations that apply directly to
controlling VOC emissions from air flotation systems.   However,  some states
may apply regulations applying to oil  recovery facilities to air flotation.
Further, new source reviews of refinery sites may call  for control  of
emissions from air flotation.   California is one state  where new source
reviews have been applied to these systems.   Two refineries have been
located that control emissions from air flotation for odor control  purposes.
Both of these refineries are located in California.70,71

     Control of emissions from air flotation would be on a site  specific
basis.  Because of this, it is difficult to  determine how may, if any,  new
air flotation systems would be controlled.   Therefore,  baseline  control for
air flotation systems is assumed to be no control.

     Current nationwide VOC emissions  from air flotation systems can be
estimated by using the emission factor given in Section 3.2.3.3.  It is
assumed that 75 percent of the refineries in the U.S. use air flotation.
Using this information, current baseline VOC emissions  are estimated to be
0.64 Gg/year.

     Baseline emissions from new and modified air flotation systems are
estimated to be 84 Mg per year in 1989.  This estimate  is based  on the
emission factors presented in  Section  3.2.3.3 and the assumption that
50 percent of the new air flotation systems  will be DAF systems  and
50 percent will be IAF systems.  Current information indicates that
approximately 30 percent of existing air flotation system are IAF systems.
However, the number of IAF systems is  expected to increase since this
technology is a relatively new application for petroleum refinery wastewater
systems.  There is no distinct preference for either type of system and
therefore, new air flotation systems can be  expected to be equally
distributed between the two types of systems.
                                    3-66

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  3.5   REFERENCES

  1.    Annual Refinery  Survey.  Oil and Gas Journal.  81(12): 128-153
       March 21, 1983.                                —

  ?"    r«i* Envi>onmenta1 Protection Agency.  Development Document for
       Effluent Limitations Guidelines and Standards for the Petroleum
       M   r™9,!^!?1 Source Cate9<>ry.  Washington, D. C.  Publication
       No. EPA 440/1-82/014.  October 1982.  p. 22-23.

  3.    Changes Ahead for Tomorrow's Refinery to Include 'Uniform Look'
       Worldwide.  Hydrocarbon Processing.  60(6): 13.  June 1980.
                          I"
5.   American Petroleum Institute.   Manual  on Disposal  of Refinery Waste -
     Volume on Liquid Wastes.   Washington,  D.C.   1969.   p.  3-3.


6'   ™^E!X1TTO!!ta\™otect!on  Agency'   Code of Federal  Regulations.
     Tit e 40  Chater
                         ™               '
            40, Chapter 419,  Washington,  D.C.   Office of the Federal
      Register.  October 18,  1982.

 7.    [rip Report.   Laube,  A.M.  and G.  DeWolf,  Radian Corporation,  to
      R.  J.  McDonald  EPA:CPB.   July 1983.   Report  of March  14,  1983 visit  to
      Tosco  Corporation in  Bakersfield, California.

 8.    Trip Report.   McDonald, R.  and J. Durham,  EPA:CPB,  to  file.   June  1982
      Report of June 8, 1982  visit  to Shell  Oil  Company  in Norco! Louisiana
 9.    Ref.  2,  184-187.
 10.  Trip  Report.  McDonald, R. and J. Durham, EPA:CPB, to file   June 198?
     Report of June 9, 1982 visit to Exxon Company's refinery in
     Baton Rouge, Louisiana.                                J
                                       C°rp°ration> to R.J. McDonald,

                                       °f ^ 18' 1983 Vls1t t0 Texaco i
12.  Ref. 5, p. 3-5.

13.  Jones, H.R   Pollution Control  in the Petroleum Industry   Pollution
                                         - New
14.   Ref.  5, p.  3-4.

15.   Ref.  2, p.  49.
                                  3-67

-------
16.  U.S. Environmental Protection Agency.  Assessment of Atmospheric
     Emissions from Petroleum Refining.  Volume 5:  Appendix F, Technical
     Report.  Wetherold, R. G., (Radian Corporation).  Publication No. EPA
     600/l-80-075e.  April 1980.  p. 389.

17.  Ref. 13, p. 315.

18.  Finelt, S., J.R. Crump.  Predict Wastewater Generation.  Hydrocarbon
     Processing.  56_:(8)159-166, August 1977.

19.  Dickerman, J.C., T.D. Raye, J.D. Colley, and R.H., Parsons.  (Radian
     Corporation) Industrial Process Profiles for Environmental Use:
     Chapter 3.  Petroleum Refinery Industry.  Prepared for U.S. Environ-
     mental Protection Agency.  Washington, D.C.  Publication No. EPA
     600/2-77-023C.  January 1977.  pp. 16-79.

20.  Cantrell, A.  Annual Refining Survey.  Oil and Gas Journal. 18(12):
     128-130.  March 21, 1983.

21.  Ref. 2, p. 55.

22.  Ref. 2, p. 25.

23.  Willenbrink, R.  Wastewater Reuse and In-Plant Treatment.  AICHE
     Symposium Series-Water.  1973.  p. 672.

24.  Ref. 16, p. 127.

25.  Ref. 19.  p. 22.

26.  Perry, J.H.  Chemical Engineers' Handbook, Fifth ed.  New York,
     McGraw-Hill.  1973.  p. 6-30.

27.  Manning, F.S. and E.H. Snider.  Environmental Assessment Data Base  for
     Petroleum Refining Wastewaters and Residuals.  U.S. Environmental
     Protection Agency.  Ada, Oklahoma.  Publication No. EPA 600/2-83-010.
     February 1983.  p. 65-67.

28.  Los Angeles County Air Pollution Control District.  Air Pollution
     Engineering Manual.  Second Edition.  Prepared for the U.S. Environ-
     mental Protection Agency.  Research Triangle Park, N.C. Publication
     No. AP-40.  May 1973.  p. 698.

29.  Dames and Moore.  Economic Impact of  Implementing Volatile Organic
     Compound Group  II Regulations  in Ohio.   Prepared for U. S. Environ-
     mental Protection Agency, Region V.   Chicago, Illinois.  December  1981.
                                     3-68

-------
  30.   Memo from Mitsch,  B.F.,  Radian Corporation,  to file.   June 15  1984
       Response  to California Air Resources  Board Survey of  Refining'lndustry.

  31.   Beychock,  M.R.   Aqueous  Wastes from Petroleum and Petrochemical  Plants
       New York,  John  Wiley  and Sons  1967.

  32.   Brown,  J.D.,  and 6.T.  Shannon.   Design  Guide  to  Refinery  Sewers
       Hydrocarbon Processing and Petroleum  Refiner.  42(5): 141-144
       May 1963.                                      —

  33.   Wigren, A  A.  and F.L.  Burton.   Refinery Wastewater Control .   Journal of
       Water Pollution  Control  Federation.   44(1):117-128.  January  1972.

  34.   Trip Report   A.H. Laube  and R.6.  Wetherold,  Radian Corporation, to
       R.  J. McDonald   EPA:CPB   July  19, 1983.  Report of March 25,  1983 visit
       to  Sun Oil  Refinery in Toledo, Ohio.

  35.   Powell, D., P. Peterson,  K. Luedtke, and L. Levanas.   (Pacific
       Environmental Services) Development of Petroleum Refinery Plot Plans
       P^Ear!!idrf0rDUM*'  Environmental Protection Agency.  Research Triangie
       Park, N.C., Publication No. EPA-450/3-78-025.  June,  1978.
 36.  U.S. Environmental Protection Agency.    Assessment of Atmospheric
      Emissions from Petroleum Refining.  Volume 1:  Technical  Report.
38.  Laverman, R.J., T.J.  Haynie, and J.F.  Newbury.   Testing Program to
     Measure Hydrocarbon Emissions from a Controlled Internal  Floating Roof
     Tank   Prepared for American Petroleum Institute.   Chicago Bridge and
     Iron Company.   Chicago,  Illinois.   March 1982.

                   Ca!cu!at1on  of Evaporative Emissions  from Multicomponent
                 S'   Environmenta1  Science  and Technology.   16.(10) :726-728.
 39'
     October  1982
4°'  J}L«nI1Ut1?n ^^Distnct/County of Los Angeles.  Emissions to the
     Atmosphere from Petroleum Refineries in Los Angeles County.  Report
     No. 8.  Los Angeles, California. 1958.

41.  U.S. Environmental Protection Agency.  Compilation of Air Pollutant
     Emission Factors.   Third ed.  Research Triangle Park, N C   EPA AP-42
     August 1977.  p. 9.1-10.  (Supplement 11 Update, October 1980)

42.  Ref. 24.  p. 394.
                                   3-69

-------
43.  Letter from Kronenberger, L., Exxon Company, U.S.A., to Goodwin, D. R.,
     EPA:ESED.  February 2, 1977.  p. 14.  Response to Questionnaire.

44.  Ref. 13,  p. 175.

45.  Ref. 5, p. 6-5.

46.  Ref. 5, p. 5-3.

47.  Ref. 45, p. 6-3, 6-7

48.  Ref. 45, p. 6-13.

49.  Ref. 13, p. 175.

50.  Ford, D.L. and R.L. Elton.  Removal of Oil and Grease from Industrial
     Wastewater.  Chemical Engineering/Deskbook Issue.  October 17, 1977.
     p. 52.

51.  MacKay, D.  Solubility, Partition Coefficients, Volatility, and
     Evaporation Rates.  In:  The Handbook of Environmental Chemistry,
     Volume 2, Hutzinger, 0. (ed.)  Springer-Verlag, 1980.  p. 37.

52.  Litchfield, O.K.  Controlling Odors and Vapors from API Separators.
     Oil and Gas Journal.  6^(44):60-62.  November 1, 1971.

53.  Ref. 28.  p. 675.

54.  American Petroleum Institute.  Hydrocarbon Emissions from Refineries
     API Publication No. 928.   Washington, D.C.  July 1973.  p. 35.

55.  Ref. 51, p. 43.

56.  Letter and attachment from Caughman, W.L., Jr., Shell Oil Company, to
     Durham, J., EPA.  May 30, 1984.   Norco refinery wastewater system.

57.  Air Pollution Control  District/Los  Angeles.  Emissions to the
     Atmosphere from Petroleum Refineries in Los Angeles County.  Final
     Report No. 9.   Los Angeles,  California.   1958.   p.  52.

58.  Radian Corporation.  Control  Technique for Volatile Organic Emissions
     from Stationary Sources.   Prepared  for U.S. Environmental  Protection
     Agency.   Research Triangle  Park, N.C.  Publication No.  EPA
     450/1-78-022.   May 1978.   p.  141.

59.  Vincent, R.   Control of Organic  Gas Emissions from  Refinery Oil-Water
     Separators.   California Air  Resources  Board.   Sacramento,  California
     April  1979.   p. 4.
                                  3-70

-------
  60.   Ref. 54,  pp. 35-37.


  61.   Ref. 59,  pp. 6-8.


  62.   Ref. 2, p. 76.
 63'  S^iS?1" M! *!?*•• B%and Hunt' G" Rad1an Corporation,  to  file.   June
      19, 1984.  Influent Temperature to Oil -Water Separators.


 64.  Letter from Litchfield, D.  K. , Amoco Oil  Company,  to  Hunt, G.  E  ,
      Radian Corporation.  May 8, 1984.                         •"•&•»
 65'  ^tr±'tN*Lp  industrial  Water Pollution  Origins, Characteristics and
      Treatment.  Reading,  Massachusetts,  Addison-Wesley 1978.  p. 122.
 66.  Ref. 50,  p.  52-53.

 67.  Ref. 50,  p.  53.


 68-
                             .              Air  Flotation-

69
      mf^th'S"  R:EvSell?ck> and T'R- Galloway.  Removal of Emulsified
      Oil  with  Organic  Coagulants and Dissolved Air Flotation.  Journal of
      the  Water Pollution Control Federation.  50:331-346.  February 1978.


 70.   Telecon.   Laube,  A.H., Radian Corporation, with Carleton, R  E   IVEC

                   ^ 3' 1982'  Wastewat^ treatment sys?em at IVEC
      Baerfeld


 71.   Trip Report.  Laube, A.H. , Radian Corporation, to EPA:CPB.
                                                lon.   Flotation General



74.  Steiner, J L., G.F.  Bennett,  E.F.  Mohler, and L.T. Clere   Air

     Prac?ice°n MjS^Q0!^6^"6^3     ter"  Chemical
     Kractice.  ^4U2):39-45.   December
75.  Engelbrecht   R.S., A.F. Gaudy, and J.M. Cederstrand.  Diffused Air

     LrS^VtfhV°iat11epWare-Comp0nentS of Petrochemical Wtes.
     February  lm        Pollution Control Federation.  33:(2)128-135.
                                  3-71

-------
76.  Richardson, C.P., S.O. Ledbetter.  Hydrocarbon Emissions from Refinery
     Wastewater Aeration.  Industrial Waste.  24(4):26-28.
     July/August 1978.

77.  U.S. Environmental Protection Agency.  Emission Test Report. Petroleum
     Refinery Wastewater Treatment System Chevron U.S.A., Incorporated (El
     Segundo, California).  TRW Environmental Operations.  Research Triangle
     Park, North Carolina.  EMB Report No. 83WWS2.  March 1984.

78.  Sherwood, T.K., and R. Pigford.  Absorption and extraction.  New York,
     McGraw-Hill.  1952 p. 58-63.

79.  Drivas, P.J.  Calculation of Evaporative Emissions from Multicomponent
     Liquid Spills in 3jrd Joint Conference on Applications of Air Pollutant
     Meteorology, American Meteorological Society and Air Pollution Control
     Association, San Antonio, Texas, January 1982.

80.  Adams, C.E., and W.W. Eckenfelder (eds.)  (Associated Water and Air
     Resources Engineers, Inc.)  Process Design Techniques for Industrial
     Waste Treatment.  Nashville, TN,  Enviro Press. 1974.

81.  Letter and attachment from Stein, D.A., Envirosphere Company, to
     Mitsch, B., Radian Corporation.  July 18, 1983.  NSPS for Refinery
     Wastewater Systems.

82.  U.S. Environmental Protection Agency.  Emission Test Report.  Petroleum
     Refinery Wastewater Treatment System, Golden West Refining Company
     (Santa Fe Springs, California).  TRW Environmental Operations.
     Research Triangle Park, North Carolina.  EMB Report No. 83WWS4.  March
     1984.

83.  U.S. Environmental Protection Agency.  Emission Test Report.  Petroleum
     Refinery Wastewater Treatment System, Golden West Refining Company
     (Sweeny, Texas).  TRW Environmental Operations.  Research Triangle
     Park, North Carolina.  EMB Report No. 83WWS3.  March 1984.

84.  U.S. Environmental Protection Agency.  Treatability Mannual.
     Volume III:  Techniques for Control/Removal of Pollutants.
     Washington, D.C.  Publication No. EPA 600/8-80-042c.  July 1980.
     p. III.4.3-1.
85.
86.
87.
88.
Ref.
Ref.
Ref.
Ref.
24,
81,
24,
81,
P-
P-
P-
P-
388.
389.
390.
III. 5.1-1.
                                     3-72

-------
 89.  Ref. 13,  p. 193.

 90.  Ref. 24,  p. 392.

 91.  Ref. 13,  p. 202.

 92.  Ref. 81,  p. III. 4.2-4.

 93.  Ref.81,  p. III. 5.3-3.

 94.  Ref. 2,   p. 158.

 95.  Ref. 81,  p. 4.1-1 - 4.1-33.

 96.  Shen, T.T.   Estimation of Organic Compound Emissions  from Waste
      Lagoons.  Journal of the Air  Pollution Control  Association
      32:(1)79-82. January 1982.

 97.  HPI  Construction Boxscore.  Hydrocarbon Processing.   October  1983.

 98.  Cantrell,  Aileen.  Worldwide  Construction  Oil and  Gas Journal  81(17)
      April  25,  1983.                                                —"

 99.  U.S.  Environmental  Protection Agency.   VOC Fugitive Emissions  in
      Petroleum  Refinery  Industry. Background for Proposed  Standards
      Research Triangle Park,  N.C.  Publication  No. EPA  450/3-81-015a
      November 1982.

 100.  HPI  Construction  Boxscore.  Hydrocarbon  Processing.   June  1983.

 101.  Telecon.  Laube,  A.H.,  Radian Corporation with Nan Kileen, Louisiana
      Air Quality  Division.  August 4,  1983.   Baseline information -
      Louisiana air quality regulations.


 102.  Telecon.  Mitsch, B.F., Radian Corporation, with Dr. John Reed, State
      of Illinois.  September 6, 1983.  Baseline emissions.


 103. Telecon.  Laube, A.H., Radian  Corporation, with  Ken Kearney, State of
      Indiana.  August 31, 1983.  Baseline - Indiana regulations.

 104. Telecon.  Mitsch, B.F., Radian Corporation, with Dick  Rule
     Pennsylvania Bureau of Air Quality Control.  September 6, 1983
     Pennsylvania regulations.

105. Telecon.  Laube, A.H., Radian  Corporation,  with  Larry  Wonders,
                        Bureau of Air Control.  August  31,  1983.  Baseline
                                   3-73

-------
106. Telecon.   Laube, A.M., Radian Corporation,  with  John  Swanson,  Bay  Area
     Air Quality Management District.   August 16,  1983.  Baseline
     information - Bay Area regulations.

107. Telecon.   Laube, A.H., Radian Corporation,  with  John  Powell,  South
     Coast Air Quality Management District.   August 2,  1983.   Baseline  -
     South Coast Air Quality Management District regulations.

108. Telecon.   Mitsch, B.F., Radian Corporation, with Tom  Paxson,  Kern
     County Air Pollution Control District.   September  7,  1983.   Baseline
     emissions.

109. Memo from  Machin, J.L., Radian Corporation,  to  S.A.  Shareef,  Radian
     Corporation.  August 25, 1983.  Report  of Meeting  with Texas  Control
     Board.

110. Environmental Reporter.  State Air Laws.  Volumes  1-3.  Washington,
     D.C., Bureau of National Affairs, Inc.   1983.

111. U.S. Environmental Protection Agency.  Code of Federal Regulations.
     Title 40, Chapter 419, Washington, D.C.  Office of the Federal
     Register.  October 18, 1982.
                                    3-74

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                        4.  EMISSION CONTROL TECHNIQUES

      Petroleum refinery wastewater systems contain several  sources  of
 volatile organic compound (VOC)  emissions.  These emissions result  from  the
 evaporation of VOC from oily wastewater at points, or sources,  where  the
 wastewater is exposed to the atmosphere.   Three sources  of  emissions  are
 process drain systems, oil-water separators,- and air  flotation  systems
 These sources and their uncontrolled emissions  have been described  in
 Chapter 3.

      There are only a limited number of methods available to  reduce VOC
 emission from refinery wastewater systems.   These methods depend upon one or
 more of the following basic  principles:

           •    reduction of  VOC  entering  the wastewater  system;
           «    reducing the  surface  area  of wastewater exposed  to the
                atmosphere; and
           •    enclosing the  system  to  isolate  it  from the  atmosphere.

      The reduction  of VOC entering the wastewater  system is very desirable
 trom both  an  economic and environmental standpoint.  Many,  if not most
 refineries  are  actively  pursuing  this approach, and have found it to  be cost
 effective.1   The  reduction can be achieved  by reducing either the total
 quantity of oily  water  sent to the wastewater system or by  reducing the
 quantity of VOC in  the oily water.  One plant reported reductions of  50-55
 percent  in  the quantity  of fresh water used for cooling towers and boilers 2
 Another  refinery  reported a reduction of 90 percent in the volume of
 wastewater.d

      It must be recognized, however, that there is diversity among
 refineries  in terms of the design and arrangement of their wastewater
 ^!^ms» as well as the volume and composition of wastewaters.  Thus,  it  is
 difficult to quantitatively define either the general  effectiveness  of such
 rpKTLVSnr01"? ™C enter1n9 the wastewater system or the resultant
 reduction in VOC emissions.

     Other methods are available  for reducing VOC emissions  by reducing the
surface area of wastewater exposed to the  atmosphere and/or  enclosing  all or
part of the emission sources.   In a  few  cases,  the effectiveness  of  some  of
in detail inSSectionG4 f3SUred °r est1mated-   These methods are  discussed

     There are a number of technologies  that are available to  either
             +Ct 2rKrecover and/or Process  VOC from gaseous  streams which

                                            '
                                  4-1

-------
               flares;
               carbon adsorption;
               incineration;
               condensation;
               industrial boilers and heaters; and
               catalytic oxidation.

These control technologies are reviewed and discussed in Section 4.2.

4.1  METHODS FOR REDUCTION OF VOC EMISSIONS

     Methods which can be used to reduce and/or capture VOC emissions  from
sources in the wastewater system are described in the following sections.

4.1.1.  Process Drains and Junction  Boxes

     Process drains and junction boxes, as described in Section 3.2.1, make
up the wastewater collection system within a refinery.   The VOC emissions
result from vaporization from the open surfaces of drains and vents on the
junction boxes.  The technologies for reducing these emissions are discussed
below.

     4.1.1.1  Methods for Controlling VOC Emissions.  The alternatives for
reducing emissions from oily water process drains and junction boxes involve
some type of closure or seal.  A common method involves the use of a P-leg
in the drain line with a water seal.  A less common, but more effective
method, is a completely closed drain system.  Junction box emissions can be
reduced with a water-filled seal pot.

     As described in Section 3.2.1, many refinery drains are connected
directly to lateral sewer lines, which in turn are generally connected to
several other drains.  There is no seal or other means for preventing  VOC
vapors present in the sewer line from escaping to the atmosphere through the
open drains.  A water seal in the drain can result in a reduction in the
emissions from open drains.

     A P-leg water seal was discussed in Section 3.2.1.2.  Such a seal could
prevent a substantial portion of the VOC in the drain system from entering
the atmosphere.  It is possible that some emissions will occur from the
surface of the liquid seal in the leg of the trap which is open to the
atmosphere.  Emissions will be less than those from an open drain unless the
drain is allowed to dry out and the water seal is lost.

     The vent lines from sealed junction boxes may be equipped with
water-filled seal pots, as discussed and illustrated in Section 3.2.1.3.  As
long as the seal pot is filled with liquid, it will provide an effective
barrier for emissions.  The only means whereby VOC emissions can occur are
by diffusion through the water seal, a breach of the water seal, or from
leakage around the cover of the junction box.  A small, continuous flow of
                                    4-2

-------
 water can be directed into the seal pot to keep it filled to the desired
 level.  Leaks around the cover can be eliminated or minimized by proper
 seals or caulking.  Pressure/vacuum valves could also be used to prevent
 emissions from junction box vents.  However, use of this control technique
 has not been found in an operating refinery.

      There are several  factors which affect the performance of water-sealed
 drains and junction boxes in reducing VOC emissions.   Some of these factors
 are the drainage rate,  composition of the liquid entering the drain,
 temperature of the liquid entering the drain, the diameter of the drain, and
 ambient atmospheric conditions.  The most important factor in the
 performance of the junction box seal pot is the pressure within the junction
 box.  If a significant  pressure buildup occurs, the water seal  will  be
 breached and VOC will be emitted from the vent.

      As discussed previously in Section 3.2.1,  a completely closed  drain
 system was observed in  a BTX unit at one refinery.•»  This system prevents
 exposure of any oily wastewater to the atmosphere within the process unit
 Thus, VOC emissions to  the  air are completely eliminated within the  process
 unit.  This is  assuming  that the system does  not leak.

      In this type of control  system the mouth of the  vertical drain  riser  is
 closed with a flange.   Equipment drain lines  are piped  into  the flange or
 directly into the perimeter of the drain risers depending on  the  number  of
 connecting lines  required per drain.   The waste liquid  flows  into the drains
 which are  connected to  lateral  sewer lines.   Drainage flows  through  the
 underground lateral  drains  to a  buried collection  tank.   The  collected
 liquid is  pumped  to an oil-water  separator.   A  fuel gas  purge removes VOC  to
 a  control  device.   The entire system is  purged  by  the fuel gas  and  is
 maintained at a very slight  positive  pressure (^ 0.5  -  1.0"  H?0).

      Since the  system is completely  closed, there  are very few  factors which
 would seriously affect its performance with the  exception  of equipment
 failures and  equipment leaks.  Parameters such  as wastewater flow rates,
 wastewater composition, and  system  temperature may affect  the amount of
 material being directed to the control device,  but emissions within the unit
 will  be unaffected.

      4.1.1.2  Effectiveness of VOC Emission Controls.   The effectiveness of
 water  seal drains in reducing VOC emissions has  been evaluated using two
 methods.   First, process drains at three petroleum refineries were screened
 for VOC concentration with a portable hydrocarbon analyzer.  And second,  a
 theoretical analysis of  the effectiveness of water seals was conducted
These two methods are discussed below.

     A portable organic  vapor analyzer (OVA) was used  to screen  drains at
three refineries.   The drains at one refinery were uncontrolled  5  The
drains at the second refinery were equipped  with water seals.6  And  the
drains at the third refinery were equipped with  seal pots having caps which
                                  4-3

-------
could be manually removed.7  The drains having seal  pots  were  screened  with
the cap in place and after the cap had been removed.   Removing the  cap  broke
the water seal on the drain and left the drain in an  uncontrolled state.

     The results of the screening study were analyzed using two approaches.
In the first approach, all screening values from uncontrolled  drains were
averaged and compared with the average of all screening values from
controlled drains.8  A total of 200 screening values for controlled drains
were included in the analysis and 169 screening values for uncontrolled
drains.  The averaged screening values were converted to leak rates using
the  correlation established in an EPA study of atmosphere emissions from
petroleum refineries.9  This correlation is as follows:

     Log1Q  (Non Methane Leak Rate, ppmv) =  -4.9 + 1.10 Log1Q  (Max.  Screening

     Value)
The  leak  rate for  controlled drains was 0.00353 Ibs/hr.  The  leak rate for
uncontrolled  drains was 0.00592  Ibs/hr.  Based on the  leak  rates derived
from averaging  screening  values,  the  emission reduction  achieved by water
seals  is  approximately 40 percent.

     The  second approach  used  to  evaluate  the screening  results  was to
evaluate  the  drains  at the refinery  having capped drains both before and
after  the cap was  removed.  Seventy-six  drains were  evaluated using this
method.   The  number of drains  evaluated  is smaller than  the total  number  of
 drains screening because  some  drains  were  already uncapped, the  caps could
 not be removed, or the data taken were for various  reasons unusable
 (e.g.  cap was not sealed, cap  could not be put  in place, or another VOC
 source was near drain).   If multiple readings were  taken on one  drain, the
 last reading was used in  the analysis if it was  the  lowest of a
 consistently declining  set of readings.   If multiple readings varied
 substantially for the same drain, an average value  was used.   The  results or
 this approach are shown  in Table 4-1.  The results  indicate an emission
 reduction of approximately 50 percent.

      A further analysis  grouped drains into two categories to see  if the
 uncontrolled leak rate had any effect on the emission reduction that could
 be  achieved.  Those with  uncontrolled screening values  less  than 100 ppm
 were placed in one group  while those with values greater than 100 ppm were
 placed in a second group.  Of the 76 uncontrolled drains that were screened,
 18  had values greater than 100 ppm.  The  screening value,  estimated leak
 rate, and the emission reduction factor for each of these  drains is shown in
 Table 4-2.

       As  shown  in  the table, the  average emission reduction was approximately
 50  percent.  In most cases, the  percentage  reduction  for  individual drains
 was greater  than  50  percent.   One drain had a negative  percentage reduction.
  If this  value  is  removed, the  emission  reduction would  be  74 percent.
                                     4-4

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        TABLE 4-1.  SUMMARY OF SCREENING VALUES FOR INDIVIDUAL DRAINS
M.  * n  •            ,
# of Drains Screened              Type of Drain              (Ibs/hr)



       76                           Controlled                  0.10184


       76                           Uncontrolled               0.20484
                                   4-5

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        TABLE 4-2. SUMMARY OF EMISSION RATES AND EMISSION REDUCTION FOR DRAINS WITH A LEAK RATE >100 PPM
I
CTl
-. 	 	 	 — — • 	
	 	 	 	 F$t1 mated
ll«4 4-
unit
27.1
26.2
27.2

25

Drain
No
6
7
17
3
1
2
3
11
12
11
19
23
69
83
84
85
86
94
Screening
Cap On
12
10
10
4
40
2,000
7
50
40
10
8
120
20
12
7
70
70
1,000
8
Values
Cao Off*
1,000
100
120
100
110
1,750
300
300
400
178
300
400
120
150
200
100
300
1,500
150
Emission
Cap On
0.00019
0.00016
0.00016
0.00005
0.00073
0.05384
0.00011
0.00083
0.00016
0.00012
0.00244
0.00034
0.00019
0.00011
0.00135
0.00135
0.02512
0.00012
0.08737
Rate, LB/HR
Cap Off*
0.02512
0.00200
0.00244
0.00200
0.00222
0.04649
0.00668
0.00792
0.00376
0.00668
0.00917
0.00244
0.00312
0.00428
0.00200
0.00668
0.03924
0.00312
0.17536
__— ^— — — — — •
Est. Emission
Reduction
LB/HR %
0.02493
0.00184
0.00228
0.00195
0.00149
-0.00735
0.00657
0.00709
0.00360
0.00656
0.00673
0.00210
0.00293
0.00417
0.00065
0.00533
0.01412
0.00300
0.08800
99.2
91.8
93.4
97.5
66.9
-15.8
98.4
89.5
97.3
98.2
73.4
86.1
93.8
97.4
32.5
79.8
36.0
96.2
"5OO
    *Reading(s) taken after cap had been removed for a while.

-------
     Based on the analyses of drains screening data, emission reductions of
40 percent to 50 percent are achievable by water seal drains.  Values for a
specific drain can vary from 0 percent to 99 percent.

     A theoretical analysis of the effectiveness of water seal drains was
also conducted.  As discussed in Chapter 3, emissions from drains are
primarily influenced by the forces of convection and diffusion.  Three types
of drains were evaluated using benzene as an example compound:  an uncon-
trolled drain, a P-trap water sealed drain with no contaminated water and a
P-trap water sealed drain saturated with benzene from a contaminated stream.

     The benzene emissions due to molecular diffusion through the water seal
were estimated based on the equation presented in Section 3.2.1.3.  The
assumptions used to estimate emissions are presented in Table 4-3,  The
emissions due to convection were estimated based on a study which showed
that the total emissions due to convection and molecular diffusion were 1.0
to 31.7 (average of 25) times molecular diffusion.114 This value was then
adjusted to account for windspeed by by making three assumptions.  First, it
was assumed that the mass transfer coefficient for benzene is proportional
to p °.78, where y is the windspeed. 1;*  Second, it was  assumed that the
windspeed at which the convection data was collected was not greater than
one ft/second.  And finally,  windspeed used for the example calculations was
10 ft/second.  Based on the above,  the mass flux  of benzene was  calculated
to be 150 times molecular diffusion.

     The benzene emissions  due to diffusion through the  water seal  were
calculated based on the following equation:12


                          NA  =  DV A CAV le fraction of benzene

              XBJ  =  Initial  mole  fraction of  water

              Xg,,  =  Final mole fraction of water

              A   =  Cross sectional area of drain
                                  4-7

-------
TABLE 4-3.  ASSUMPTIONS FOR ESTIMATING BENZENE EMISSIONS FROM EXAMPLE DRAINS
Uncontrolled Drain

     Benzene concentration in vapor phase = 0.125 atm
     Wastewater temperature =Q150 F
     Ambient temperature = 70 F
     Drain diameter = 4 in
     Length of drain = 4.25 ft
     Average temperature in drain = 110 F   2
     Diffusion coefficient in air = 0.097 cm /sec
     Total mass transport 150 times molecular diffusion
     Benzene concentration at top of drain = 0 mg/L
     Wind speed =  10 ft/sec

 P-Trap  Water Sealed Drain with  Clean Wastewater

     Length of water seal = 1.6 ft  Q
     Temperature  of water seal  = 68 F
     Drain  diameter =  4  in
     Length of drain above water seal  = 2.25 ft_5    2           oc
     Diffusion coefficient  in water =  1.02  x 10    cm /sec at 68 F
     Henry's Law  applies                  3       o
     Henry's Law  coefficient  =  5.49 x  10    atm/m  mole
      Concentration at  bottom  of water  seal  in  equilibrium with vapor phase
      Concentration of  benzene  at top of water  seal  = 0 moles/L
      No convection (i.e.,  diffusion through water seal controls mass
      transfer)

 P-Trap Water Sealed Drain  with Contaminated Wastewater

      Water seal  saturated  with benzgne
      Temperature of water seal  = 68 F
      Length of drain above water seal  = 2.25 ft
      [tJanift.T ul  drain   4 in
      lienieno concentration at  top of drain = 0 mg/L
      Solubility of benzene in  water = 1780 mg/1
      Total mass transport 150  times molecular diffusion
      Continuous wastewater flow into drain
      Wind speed = 10 ft/sec                            2,
      Diffusion coefficient of  benzene in air = 0.085  cm  /sec

  References:  10,11,12,13,14,15
                                       4-8

-------
      Based on the above discussion along with the assumptions presented in
 Table 4-3, the benzene emissions from each drain configuration were
 calculated.  The results are presented in Table 4-4.

      As shown in the table, the clean water seal is estimated to reduce
 emissions by about 99.9 percent over the uncontrolled drain.   This reduction
 is due to the elimination of the effects of convection.   The  water seal also
 acts as a barrier to molecular diffusion, greatly slowing down the movement
 of benzene through the drain.

      The estimate of emissions from a water seal saturated with benzene show
 how the seal  could lose its effectiveness.   The emissions from a water seal
 contaminated  with benzene was  calculated to be 555 gm/day. This is over 1  7
 times the rate of an uncontrolled drain and over 2 x 105  times the emission
 rate from an  uncontaminated water seal.   The increase in  emissions over an
 uncontaminated water seal  is due to the fact that benzene does not have to
 diffuse through a water seal.   The  length of the diffusion path is greatly
 reduced and the convection effects  are not  eliminated.

      In an actual  refinery sewer system,  there will  be both contaminated and
 uncontaminated water seals.  The larger  percentage will be uncontaminated
 water seals as shown by the  drain screening  data.  Of the 76  drains with
 caps properly placed,  only three had  a  screening value of 100 ppm  or greater
 in the  controlled states  (caps  on).   The  low  screening values  of the other
 73 drains  indicate very little  or no  contamination.   Additionally,  the  vapor
 space in  the  sewer pipe may  not be  saturated with hydrocarbon  as assumed in
 the  example calculations.  Only 19  drains at  the refinery having capped
 drains  were found  to have  a  screening  value of 100 ppm or greater with  the
 cap  off, and  only  six  drains had values between  50 and 100 ppm.

      Using  both the  screening analysis and theoretical analysis as bases  it
 is estimated  that water seal drains reduce VOC emissions  by 50 percent   The
 screening  study indicates emission  reductions of 40 to 50 percent are
 achievable.   The theoretical analysis indicates  that emission  reduction may
 be much greater, particularly with a well maintained water seal   Water
 seals can be maintained by periodic inspection of the drains to ensure the
 seal  is in place.

     A completely closed drain  system can capture virtually 100% of the VOC
 emissions.  The overall reduction in VOC emissions will  depend on the
 efficiency of the control device.  For example, a smokeless flare can
 achieve about a 98 percent destruction efficiency.

 4.1.2  Oil-Water Separators

     Oil-water separators,  as described in Section 3.2.2,  rely on gravity
separation to  remove  the oil  fraction  of the wastewater stream.   The VOC

-------
         TABLE 4-4.  BENZENE EMISSIONS FROM EACH DRAIN CONFIGURATION
CONFIGURATION       EMISSIONS DUE TO    EMISSIONS DUE TO           TOTAL
	     MOLECULAR DIFFUSION      CONVECTION            EMISSIONS
                      (gm/day)             (gm/day)              (gm/day)


Uncontrolled Drain       2.1                 312                   315

Uncontaminated           0.0026              	                   0-0026
Controlled Drain

Contaminated             3.7                 551                   555
Controlled Drain
                                      4-10

-------
  emissions occur as a result of vaporization  from the open surfaces of

  described      Parat°rS'  ^ techno1°9les for ^ducing these emissions  are
    «.. H      Metl?°ds for Controlling  VOC  Emissions.  The most effective
 method for controlling VOu emissions from  oil-water separators is  to use
 either floating or fixed roofs.18   This will reduce VOC emissions  by:

           •    Reducing the oil  surface exposed to the atmosphere,
           •    Reducing the effects of wind velocity, and
           •    Insulating the  oil  layer from solar radiation.

 unth thfiX6d ryf Ca" be installed on  m°st separators without  interfering
 with the oil-skimming system.  The roof may be constructed of  various
 materials^including truncated  case aluminum segments, steel  plates,  or
 concrete.  ,   ,   ,     The roof can be mounted on the sides of  the seoarator
 or supported  by  horizontal  steel beams set into the sides  of the tank 18?i
 Thp rnnfc ncnall./ h=>i,« „,,-  4-.-«uj.	 .      ...  ->lv"=°  "' i-"c tari^..  ,
 and" 2?ntenaSn?I ?ihS2Ve ?^ tfght 2cceSS d°°rs which a™ ™«      nspection
 and maintenance. 21 ,22  Tne sace b                          .        H
                           space between the roof and  the   .        H
 separator can  be  sealed using a urethane or neoprene gasket. i8,22
                                   fl'X6d roofs may co"stitute an  explosion
M      n    h  -                   ate th1s P^blem the vapor spac
blanketed with either plant  gas or  an inert gas, such as nitrogen.
 or fire™          .
               '     °rd   t0 eliminate th1s  ^blem  the vapor space can be
     In contrast to  fixed roofs, which are always  above  the oil layer
floating roofs  actually float on the oil  surface.   This  eliminates most of
the vapor space above the liquid, thus greatly reducing  the potential for
volatilization  from  the oil layer.  To prevent the roof  fromP?nterferinT
with the operation of the flight scraper,  the water level can be raised in
the separator so that the top of the oil  surface is  above the flijht fcrlper

      '       "      °f " f1                                           P
 Fi>re4-l.           °f "  f10ati"9  ^ °n 3" API sePa^tor is  shown
      ?^;s^?^a;^r-^-
        9       USl'      f°am WraPPed W1'th  a  coa*ed fabric.9 The
with a nylon-polyurethane fabric.2^  This seal  is  shown  in Figure 4-2

     There are  several factors which can affect the overall performance of
InJT fyP6S f  r°°fS in reduc1ng VOC ^missions.  The most Ebvious is the
degree of maintenance.  The seals must be kept  in  good condition to minimize
leakage around  joints and seals.  With the  exception of  lea age  the Control
                                  4-11

-------
1

%
1
'//,
'//,
\
1
I
ADJACENT FLOATING COVEH

GUIDE
DEVICE
SKIMMING
MANHOLE
£/ |J MAIN 'E NANCE AND
^A y INSPECTO, MANHOLE
* c^

ADJACENT FLOATING COVER
1

^
^
%
^
^
XX-
^
%
^
%
%
^
g?
I
I
v%%M%%%%%%^^
                                                       . I (QUID
                                                        lEVEL
     Figure 1-1.  Floating Roof on an API Separator.
                                                    23
                        4-12

-------
      Floating Roof
                                                                                   Polyurethane Foam
                                                                               Wall of Separator Basin
Floating Roof
                                                                                         Mylon-Polyurethane Wrap
                                                                     Polyurethane Foam
                  Figure 4-2.   Polyurethane Foam Seal  on a Floating Roof.26

-------
 effectiveness  of  closed  systems which are vented to recovery or destruction
 devices  is  relatively  insensitive  to variations in system parameters.  The
 efficiency  of  those  covered units  which are vented to the atmosphere depends
 on  system variables  such as VOC content of the incoming water, the
 temperature of the liquid  phase, the ambient temperature, amount of solar
 insulation, extent of  surface area, and thickness of the oil layer.  All of
 these  factors  were discussed in detail in Section 3.2.2.2.

     4.1.2.2  Effectiveness of VOC Emission Controls.  Very little data are
 available regarding  the  reduction  of VOC emissions which can be achieved by
 installing  a roof on an  oil-water  separator.  The only documented study,
 done by  Litchfield,  found  that by  using 2 inch thick Foamglas slabs as a
 floating cover, the  evaporation losses could be reduced by 85 percent.23
 Other  sources  report varying levels of emission reduction but give no
 supporting  documentation.  The American Petroleum Institute stated that a
 floating or fixed roof would reduce emissions by 90 percent to 98 percent.27
 In  AP-42, an emission  reduction value of 96 percent was reported.28
 Further, in a  recent study the State of California estimated that a
 90  percent  reduction in  emission could be  achieved  by  using roofs.29  All of
 these  emission  reduction estimates are based on qualitative information.
 Therefore,  these  sources were not  used to estimate the efficiency of
 covering a  separator.

     It  should  be noted  that the foamglass slabs used by Litchfield were not
 sealed.  Some  loss may have occurred from gaps between the slabs or gaps
 between  the slabs and tank wall.   The 85 percent reduction calculated from
 the Litchfield  data is,  therefore,  representative of the emission reduction
 achievable  by  a simple fixed or floating cover.

     Theoretical analyses have indicated that a floating roof equipped with
 a primary liquid mounted seal  and  a secondary seal  can achieve a higher
 emission reduction than 85 percent.  The sealing system would eliminate the
 potential leakage due to gaps  in the cover.   These  analyses are discussed in
 Appendix E.

     The use of a fixed roof with vapors  vented to  a control device will
 result in a   greater overall control of captured VOC emissions.21  Due to
 some possible leakage,  the capture  efficiency of the roof in this type of
 control system would be approximately 99  percent.   The  actual  efficiency of
 the system will depend  on the  efficiency  of the control  device.   For
 example, the efficiency of a  flare  is estimated to  be  98 percent.
 Therefore, the overall  efficiency of a fixed  roof with  vapors  vented to a
 flare would   be 97 percent (0.99 x 0.98 =  97%).   The  efficiencies of various
 control devices are discussed  in Section  4..2.

 4.1.3  Air  Flotation Systems

     Air flotation systems  are  used to remove free  and  emulsified  oil,
 suspended solids,  and colloidal  solids  from  refinery wastewater.   Their
operation has been described  in  Chapter 3.2.3.   VOC  emissions  occur as  a
                                   4-14

-------
 result of volatilization from the exposed surface of the air flotation
 system.  The methods for controlling these emissions are described below.

      4.1.3.1  Methods for Controlling Emissions.  Methods for controlling
 VOC emissions from air flotation systems differ depending upon the type of
 air flotation system.  Induced air flotation systems (IAF) usually are
 equipped with a roof while dissolved air flotation systems (DAF) are open to
 the atmosphere.  Gas or air used for flotation in an IAF is usually
 recirculated in the vapor space while the gas or air used for flotation in a
     is introduced into the system from an outside source.
 *u  T«rntro1 of VOC emissions from an IAF can be accomplished by operating
 the IAF under gas-tight conditions.  IAF systems usually are equipped with a
 roof having eight access doors on the sides.  The access doors can be
 gasketed and tightly sealed during operation of the system.   A slight
 negative pressure is created in the vapor space of the IAF due to the action
 of the impellers or recycled wastewater.  The impellers or recycled
 wastewater create a vortex which draws  gas or air into the wastewater.   The
 only emissions resulting from a gas tight IAF would be from breathing
 losses.  The breathing losses would result in VOC being emitted  through  an
 atmospheric vent or pressure/vacuum valve located on the roof of the  cover
 The pressure/vacuum valve is needed to  safely operate the system.

      VOC emissions from DAF systems can  be controlled by placing a  fixed
 roof on the flotation  chamber.   Because  of the slight positive pressure
 created by the flotation gas or air,  the roof must be provided with an
 atmosphere vent or vent equipped with a  pressure/vacuum valve.   Only  fixed
 roofs  can be used  for  DAF systems due to the design  of the systems
 Floating roofs would interfere  with the  skimming  devices  and  inhibit  the
 formation of floating  oil  and suspended  solids. *8   Fixed  roofs would  be  of
 the same type and  design as  covers  discussed for  oil-water separators.  At
 least  twoQ refineries presently  use  fixed  roofs with  atmospheric  vents on DAF
 O Jf O IrfClll^ «   B

 t.   /  "1°':e1str1ngent  level  of  control for both IAF  and DAF systems would be
 to  completely  seal  the  flotation  chamber with a fixed  roof and vent the
 captured  VOC  to a  control device    Incinerators, flares, process heaters  or
 carbon  absorbers are some of  the  devices used to control the collected
 vapor.   VOC emissions captured by a fixed roof are diverted to the control

                          S  ($UCh as "Hr°^ ' or ^<* ^ to purge the
with IS"! ^rSnr168 ha!ie been 1dent1f1ed as ^ing emission control  systems
with captured VOC vented to a control device.  In one refinery, the  two DAF
a£ ™?w?Vn Til6 wa??ewatr treatment system are covered and the  vapors
are collected.  The collected vapors are directed to an incinerator.
Nitrogen is used as the DAF flotation gas and fuel gas from the plant fuel
gas system is used as the source of fuel for the incinerator.   The control
system shown in Figure 4-3 was installed by the refinery to control  odors
arising from the wastewater system.34            ermery to control  odors
                                   4-15

-------
effluent
                     nitrogen gas supply
                                                                  collected vapors from
                                                                  oil-water separator
1 rover
_• HAT ^^*. —
•^ Dili "^*. —
r*- " r
I I
^_ recycle *-
' tank 1
| T Aw ! L
I v^ !
1
DA
to-

•ecycle
tank i
f
V,
cover
Hastewater from
F «c on -water separator


^
1 Pi""P
7
•-^ stack
i
                                                   incinerator
          \
--O
                                                                            Blower
                                             fuel gas
                                             from plant
                                             supply
                    Figure 4-3.  Example of OAF Emission Control System.

-------
       A second  refinery uses a segregated wastewater system.  The bulk of the
  oily  wastewater  is  treated by two DAF's operating in parallel to treat the
  effluent  from  the one oil-water separator.  The flotation chambers are
  covered,  and the vapors are collected and directed to an activated carbon
  SLaX,.  ThniTflJS-alS? US6d t0 treat effluent from a second oil-water
  separator.  The  IAF is also covered, and its vapors are collected and
  directed  to two  55-gallon drums filled with activated carbon.  The system
  was installed  to eliminate odor problems,32 and is shown in Figure 4-4.
 rha KThe thl>d refi"ery uses fuel 9as in the DAF systems.   The flotation
 chambers are covered and the vapors are recycled to the refinery fuel  gas

        "                        purge a1r t
    .  f.1-3-2  Effectiveness of VOC Emission Controls.   The  effectiveness of
 emission control techniques differs between the IAF and DAF systems   An IAF
 is usually provided with a roof which results  in some  emis  ion  reduction
 Operating the IAF with the access doors  in a closed state achieves
 additional reduction in emissions.   The  DAF system  usually  is not eouiooed
 with a roof and is therefore in a totally  uncontrolled  state!      *  PP

      Emission reduction achieved by covering a  DAF  will  be  less than that
 for a gas-tight IAF or a covered oil-water separator.   This ?  due to the
 sight positive displacement of gas caused by the flotation mechanism.
 Ufnoril?nl ??**** F*™**  1n Section  3-2-3-2 examined  the effect of
 evaporation and air stripping on emissions  from  a DAF.   Example desian
 specifications  for the DAF were chosen and  input parameters based on^he
 ?nM,,E5U!lS  "elf  US;d •?  Ca1culatl'n9 emissions.  These  input parameters
 Zr±d,t    '?  i^ Ol1  concent™tion and  influent benzene concentration.
 Appropriate calculations were then  used to estimate benzene losses due to
 evaporation and  air stripping.   The analyses indicate that the major cause
 of emissions  is  evaporative  losses.  Evaporative losses have been  estimated
 a  DAFCwm  rH?0  ErCent  °f ^6  t?tal losses'   U is assumed that coveHng
 a  DAF will  reduce  the  evaporative losses by at  least 85 percent  as
 determined  by Litchfield.  The air stripping losses  would continue to  be
 emitted through  the atmospheric vent. Therefore, the overall emission
 (0  9Cx S?85)^f !^  by 3 f1xed roof w111  be at least  77  percent
anH cSif3 !Jf    V   ^mission reduction achieved by a  completely  gasketed
and sealed IAF can be made using test data,  a  laboratory  study  and
reduc?6™9 Judgment.  Consideration must first  be  giJen  to  the emission
T/ir .      tnicveo oy an iAr operating under "normal"  conditions   A tvoical
spa/H expJ;cted.to.be operated with the doors  closed  but  not gasketed and
PS?I'BW*«H hi ^;ss.10" reductTon achieved by  a  gasketed  and sealed IAF can be
estimated by calculating an emission factor  for  an  IAF  operatina under four
conditions:  completely uncovered;  covered with  the doo?s open-covered with

sealed0?"'   '^ ^  "Ot 93Sketed;  and COVered with the doo« JasketeS and
                                  4-17

-------
 i
t—«
oo
                       Induced air  	
                Wastewater from
                oil-water separator




or

~1
f Cover
IAF

r
A
__1
	

                            Plant air 	
Wastewater from —
oil-water separator
                           Plant air  .__>._
                                                           Cfflucnt
                                                                  Both OAF's tightly covered
Effluent

                                                                                              Activated
                                                                                               carbon
                                                                                                bed
rn ; '


\
1


                                                                                                                  55 gallon
                                                                                                              drums containing
                                                                                                              activated carbon
                                                               I) lower
                                        figure 4-4.   Examples  of DAF and IAF  Control  Systems,

-------
  IAF isSarox?l1j'v  fr^r/i2'3;?' the *missio" potential  of  an  uncovered
  Is based on  tesfdat*   L ^  ?alljns °f !a stewater-   This  emission factor
  is cased on  test  data.  An emission factor for a covered IAF  with all the
  Section lT?Tn'tan be *Sti™ted US1'"9 engineering judgment   n      '
  SSi!?nJ  :?7  f  ^  1S e*tirnated that a ^'sely sealed  cover  on  an  oil-water
  separator will  reduce emissions by about 85 percent.  This estimate  s bllZ
  on the  Utchfield Study.  It is assumed that the roof on an IAF  wJu Id reduce
  the emissnons from the top of the IAF by 85 percent.  An IAF  system with all
  the access doors  open would have 50 percent of the surface area  exposed
       GStlte          °n design ^Deifications of an IAF prov^ded^yT
                          '  f 1SS1°nS Were meaured *™   u      !«  w th
                          °f contro1 were Placed °" the drums.   One level  of
 cover                               gaps between the tank wal1  a"d  he
                                            the                      - be
                                     sss
                                                                      area

                     12.6 %
                   0.02 Ib/hr


                   X = 0.079 Ibs/hr
 thP rllpr -H H   rat?/rom the drum  having a cover with a 1/8" gap between
 the cover and drum walls was measured to be 0.02 Ibs/hr.  This reDrespntTa
 75 percent reduction over the drum with 50 percent of the surface area
 tLTfyc; ExtraP?lat^9 these data to an IAF system? it can be StiSJed
 that a 75 percent reduction will occur if the doors are closed (over the
                                                  1n a"    ssionc   r of
^naSl menti?"ed  above  the emission reduction achieved by an  oil-water
separator equipped with  a cover is about 85 percent.   Therefore  it is
assumed that the emission reduction for an IAF with all  doors  closed would
                                  4-19

-------
also be at least 85 percent.  An 85 percent emission reduction over the
uncontrolled state would result in an emission factor of 2.3 kg/MM gallon
for the IAF.  Therefore, the emission reduction achieved by gasketing and
sealing an IAF is 3.0 - 2.3 = 0.7 kg/MM gallons, a 23 percent reduction from
the typical operating condition.

     The emission reduction achieved by tightly covering a DAF or IAF and
venting the captured emissions to a control device will be dependent on the
efficiency of the control device.  Venting the emissions to a control device
will require some type of purging system.  As discussed in Section 3.2.3.3,
the emission potential of the DAF and IAF is equal when both systems are
purged.  However, the percentage emission reduction achieved by the vent
system will be less for the  IAF because some control is achieved by the
cover normally found on the  system.  For example, tightly  covering a DAF and
venting the emissions to a  flare will reduce emissions by  approximately
97  percent.  This assumes a  99  percent capture efficiency  for the roof and a
98  percent  destruction  efficiency  for the  flare.  The destruction efficiency
of  a flare  has been established by a number of studies which  are discussed
in  the  following  section.   Tightly covering an  IAF  and venting the emissions
to  a flare  will  reduce  emissions  by  85 percent.   Although  the amount of  VOC
captured  and destroyed  is equivalent to  that  for  the DAF,  the percentage
reduction from  the  uncontrolled state  is  less  since some  control  is  achieved
by  the  cover normally  found on  the "uncontrolled" IAF.

4.2 CONTROL OF  CAPTURED VOC

      There are  several  methods  that  may  be used to  control VOC emissions,
 either by recovery of VOC from gas streams or by destruction of  the  VOC  by
means  of combustion.   These methods  include the following:

                flare systems;
                carbon adsorption;
                incineration;
                condensation;
                industrial boilers and process heaters; and
                catalytic oxidation.

      Some of these control methods, such as flare systems, incineration,
 carbon adsorption, and process heaters have been applied  to the VOC
 emissions from refinery wastewater sources.  Others have  the potential  for
 application to these sources.  All of the above  listed control methods  are
 described  in the section which follow.  In addition, factors which affect
 their performance are discussed and control efficiencies  are defined.

 4.2.1  Flare Systems

      Flares are  a method of controlling VOC emissions by  thermal
 destruction.  This is  a proven technology that  is  used for controlling  a
 wide range of gaseous  emissions.  A brief description of  the technology,
                                     4-20

-------
^^
         considerations, and a Sod for
            '                        °f
         nr.    roces
                              J: the 8as
        4-21

-------
Gas Collection Header
and Transfer Line  (1)
                                        Steam Nozzles(9)
                                          Gas Barrier{6)
                                          Flare Stack(5)
                Knock-out
                Drum(2)
I
                            T
                              Drain
                                          Gas(4)
        Water	
         Seal(3)
                                                                       Flare Tip(8)
                                                 Pilot Burners(7)
 Steam Line


 Ignition Device



 Air Line

• Gas Line
                      Figure 4-5.   Steam-Assisted  Elevated Flare  System.
                                                 4-22

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reactions that form carbon.  Significant disadvantages of steam usage are
the increased noise and cost.  The steam requirement depends on the
composition of the gas flared, the steam velocity from the injection nozzle,
and the tip diameter.  Although some gases can be flared smokelessly without
any steam, typically 0.15 to 0.5 kg of steam per kg of flare gas is
required.  Gases with heating values of below about 18 MJ/scm (500 Btu/scf)
may be flared smokelessly with steam or air assist.

     Steam injection is usually controlled manually with the operator
observing the flare (either directly or on a television monitor) and adding
steam as required to maintain smokeless operation.  Several  flare
manufacturers offer devices such as infrared sensors which sense flare flame
characteristics and adjust the steam flow rate automatically to maintain
smokeless operation.

     Some elevated flares use forced air instead of steam to provide the
combustion air and the mixing required for smokeless operation.  These
flares consist of two coaxial flow channels.  The combustible gases flow in
the center channel and the combustion air (provided by a fan in the bottom
of the flare stack) flows in the annulus.  The principal advantage of air
assisted flares is that expensive steam is not required.  Air assist is
rarely used on large flares because air flow is difficult to control when
the gas flow is intermittent.  About 0.8 hp of blower capacity is required
for each 100 Ib/hr of gas flared.39

     Ground flares are usually enclosed and have multiple burner heads that
are staged to operate based on the quantity of gas released  to the flare.
The energy of the flared gas itself (because of the high nozzle pressure
drop) is usually adequate to provide the mixing necessary for smokeless
operation and air or steam assist is not required.  A fence  or other
enclosure reduces noise and light from the flare and provides some wind
protection.  Ground flares are less numerous and have less capacity than
elevated flares.  Typically they are used to burn gas "continuously" while
steam-assisted elevated flares are used to dispose of large  amounts of gas
released in emergencies.40

     4.2.1.2  Factors Affecting Efficiency.  The flammability limits of the
gases flared influence ignition stability and flame extinction.  (Gases must
be within their flammability limits to burn.)  When flammability limits are
narrow, the interior of the flame may have insufficient air  for the mixture
to burn.  Fuels with wide limits of flammability (for instance, H2 and
acetylene) are therefore usually easier to burn.  However, in spite of wide
flammability limits, CO is difficult to burn because it has  a low heating
value and slow combustion kinetics.

     The auto-ignition temperature of a fuel affects combustion because gas
mixtures must be at high enough temperature to burn.  A gas  with low
auto-ignition temperature will ignite and burn more easily than a gas with a
high auto-ignition temperature.  Hydrogen and acetylene have low
auto-ignition temperatures while CO has a high one.
                                   4-23

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     The heating value of the fuel  also affects the flame stability,
emissions, and flame structure.   A  lower heating value fuel  produces  a
cooler flame which does not favor combustion kinetics and also is  more
easily extinguished.  The lower flame temperature will also  reduce buoyant
forces, which reduces mixing (especially for large flares on the verge of
smoking).  For these reasons, VOC emissions from flares burning gases with
low Btu content may be higher than  those from flares which burn high  Btu
gases.

     The density of the gas flared  also affects the structure and  stability
of the flame through the effect on  buoyancy and mixing.  The velocity in
many flares is very low, therefore, most of the flame structure is developed
through buoyant forces as a result  of the burning gas.  Lighter gases
therefore tend to burn better.   The density of the fuel also affects  the
minimum purge gas required to prevent flashback and the design of the burner
tip.

     Poor mixing at the flare tip or poor flare maintenance  can cause
smoking (particulate).  Fuels with  high carbon to hydrogen ratios  (greater
than 0.35) have a greater tendency  to smoke and require better mixing if
they are to be burned smokelessly.

     Many flare systems are currently operated in conjunction with baseload
gas recovery systems.  Such systems are used to recover hydrocarbons  from
the flare header system for reuse.   Recovered hydrocarbons may be  used as a
feedstock in other processes or as  a fuel in process heaters, boilers or
other combustion devices.  When baseload gas recovery systems are  applied,
the flare is generally used to combust process upset and emergency gas
releases which the baseload system  is not designed to recover and
unrecoverable hydrocarbons.  In some cases, the operation of a baseload gas
recovery system may offer an economic advantage over operation of a flare
alone since sufficient quantity of  useable hydrocarbons can  be recovered.

     4.2.1.3  Control Efficiency.  This section presents a review of  the
flares and operating conditions used in five studies of flare combustion
efficiency.  Each study summarized  in Table 4-1.

     Palmer experimented with a 1.3 cm (1/2-inch) ID flare head, the  tip of
which was located 1.2 m (4 feet) from the ground.  Ethylene  was flared at
15 to 76 m/s (50 to 250 ft/sec) at  the exit, 0.1 to 0.6 MW (0.4 x  106 to
2.1 x 106 Btu/hr).  Helium was added to the ethylene as a tracer at 1 to
3 volume percent and the effect of  steam injection was investigated in some
experiments.  Destruction efficiency (the percent ethylene converted  to some
other compound) was 97.8 percent.kl

     Siegel made the first comprehensive study of a commercial flare  system.
He studied burning of refinery gas  on a commercial flare head manufactured
by Flaregas Company.  The flare gases used consisted primarily of hydrogen
(45.4 to 69.3 percent by volume) and light paraffins (methane to butane).
                                   4-24

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Traces of H2S were also present in some runs.  The flare was operated from
30 to 2900 kilograms of fuel/hr (287 to 6,393 Ib/hr), and the maximum heat
release rate was approximately 68.96 MW (235 x 106 Btu/hr).  Combustion
efficiencies (the percent VOC converted to C02) averaged over 99 percent.42

     Lee and Whipple studied a bench-scale propane flare.  The flare head
was 5.1 cm (2 inches) in diameter with one 13/16-inch center hole surrounded
by two rings of 16 1/8-inch holes, and two rings of 16 3/16-inch holes.
This configuration had an open area of 57.1 percent.  The velocity through
the head was approximately 0.9 m/s (3 ft/sec) and the heating rate was
0.1 MW (0.3 x 106 Btu/hr).  The effects of steam and crosswind were not
investigated in this study.  Destruction efficiencies were 99.9 percent or
greater.1*3

     Howes, et al. studied two commercial flare heads at John Zink's flare
test facility.  The primary purpose of this test (which was sponsored by the
EPA) was to develop a flare testing procedure.  The commercial flare heads
were an LH air assisted head and an LRGO (Linear Relief Gas Oxidizer) head
manufactured by John Zink Company.  The LH flare burned 1,043 kg/hr
(2,300 Ib/hr) of commercial propane.  The exit gas velocity based on the
pipe diameter was 8.2 m/s (27 ft/sec) and the firing rate was 13 MW
(44 x 106 Btu/hr).  The LRGO flare consisted of 3 burner heads located 0.9 m
(3 feet) apart.  The 3 burners combined fired 1,905 kg/hr (4,200 Ibs/hr) of
natural gas.  This corresponds to a firing rate of 24.5 MW (83.7 x 106 Btu/hr),
Steam was not used for either flare, but the LH flare head was in some
trials assisted by a forced draft fan.  Combustion efficiencies for both
flares during normal operation were greater than 99 percent.1*4

     A detailed review of all four studies was done by Joseph, et al. in
January 1982.40  A fifth study45 determined the influence on flare
performance of mixing, Btu content, and gas flow velocity.  A steam-assisted
flare was tested at the John Zink facility using the procedures developed by
Howes.  The test was sponsored by the Chemical Manufacturers Association
(CMA) with the cooperation and support of the EPA.  All of the tests were
with an 80 percent propylene, 20 percent propane mixture diluted as required
with nitrogen to give different heat content values.  This was the first
work which determined flare efficiencies at a variety of "nonideal"
conditions where lower efficiencies had been predicted.  All previous tests
were of flares which burned gases which were very easily combustible and did
not tend to soot (i.e., they tended to burn smokelessly).  This was also the
first test which used the sampling and chemical analysis methods developed
for the EPA by Howes.  The steam-assisted flare was tested with exit flow
velocities ranging up to about 19 m/s (63 ft/sec), with heat contents from
11 to 84 MJ/scm (300 to 2,200 Btu/scf) and with steam to gas (weight) ratios
varying from 0 (no steam) to 6.86.  Air-assisted flares were tested with
fuel gas heat contents as low as 3 MJ/scm (83 Btu/scf).  Flares without
assist were tested down to 8 MJ/scm (200 Btu/scf).  All of these tests,
except for those with very high steam to gas ratios, showed combustion
efficiencies of over 98 percent.  Flares with high steam to gas ratios
                                    4-25

-------
(about 10 times more steam than that required for smokeless operation) had
lower efficiencies (69 to 82 percent) when combusting 84 MJ/scm
(2,200 Btu/scf) gas.

     After considering the results of these five studies, the EPA has
concluded that 98 percent combustion efficiency can be achieved by steam-
assisted flares with exit flow velocities less than 19 m/s (63 ft/sec) and
combustion gases with heat contents over 11 MJ/scm (300 Btu/scf) and by
flares operated without assist with exit flow velocities less than 18 m/s
(60 ft/sec) and burning gases with heat contents over 8 MJ/scm
(200 Btu/scf).  Flares are not normally operated at the very high steam to
gas ratios that resulted in low efficiency in some tests because steam is
expensive and operators make every effort to keep steam consumption low.
Flares with high steam rates are also noisy and may be a neighborhood
nuisance.

     The EPA has a program under way to determine more exactly the
efficiencies of flares used in the petroleum refining industry/SOCMI and a
flare test facility has been constructed.  The combustion efficiency of four
flares (1 1/2 inches to 12 inches ID) will be determined and the effect on
efficiency of flare operating parameters, weather factors, and fuel
composition will be established.  The efficiency of larger flares will be
estimated by scaling.

     4.2.1.4  Applicability.  Flares are commonly used at refineries as
emission control devices.  They can be used for almost any VOC stream and
can handle fluctuations in VOC concentration, flow rate, and inerts content.
Flares should be applicable to the control of VOC emissions from oil-water
separators, air flotation systems, and closed drains systems.  Flares would
be particularly attractive for these processes if existing flares are
accessible at a given refinery.  Small ground flares dedicated to the
wastewater treating units might be considered as an alternative to directing
the captured VOC emissions into the refinery flare system.

4.2.2  Carbon Adsorption

     Carbon adsorption is a method of controlling VOC emissions by fixation
of the organic compounds to the surface of activated carbon.  When the
capacity of the carbon to adsorb VOC is exhausted, the spent carbon is
replaced or regenerated.  Carbon adsorption is a proven technology for the
control of numerous organic compounds from a wide variety of industrial
sources, including refinery wastewater sources.46  The theory and operating
principles of carbon adsorption have been extensively reviewed in the
literature.  A brief description of the technology, factors affecting its
performance, and its potential as a VOC control method for refinery
wastewater sources are discussed in this section.

     4.2.2.1  Operating Principles.  Two basic configurations of carbon
adsorption systems are typically used for VOC control--regenerative and
non-regenerative systems.
                                  4-26

-------
     In regenerative systems, multiple and separate carbon beds are
typically used to remove and concentrate organic compounds from a gas
stream.  The beds alternate adsorption/regeneration duty in a cyclical
manner.  Regeneration of spent carbon is normally accomplished by in situ
thermal desorption of the organics, usually by stripping with low pressure
steam.  The desorbed organics and steam are condensed and separated.  The
water phase is reused, further processed, or discarded without further
treatment.  The recovered organic phase is typically reused.  In a refinery
application, the recovered organics would be reprocessed or used as fuel.

     In non-regenerative systems, the basic absorption mechanism is
identical.  However, when activated carbon in a non-regenerative system
becomes spent, it is simply replaced with a fresh charge.  The spent carbon
is discarded or reactivated off-site for eventual reuse.  Equipment
requirements are much less complex, but periodic carbon replacement is
necessary.

     The feasibility of using regenerative or non-regenerative carbon
adsorption for a particular VOC control application is determined primarily
by operating economics, with the cost difference largely dependent on the
required frequency of regeneration or carbon replacement.  VOC sources
within refinery wastewater systems are expected to emit varying
concentrations and types of organics, but at relatively low total mass
rates.  Therefore, the activated carbon charge in a VOC control system would
probably become spent only at infrequent intervals.  For this reason and
other  described in the following discussion, the less complex
non-regenerative configuration appears to be more applicable to the control
of VOC emissions from refinery wastewater sources.

     A typical non-regenerative system is shown in Figure 4-6.  The effluent
gas  streams are ducted to one or multiple parallel vessels containing
activated carbon particles held in fixed beds.  The VOC are adsorbed onto
the  surface of the carbon, and the treated gas exits at a very low  VOC
concentration.  As the capacity of the carbon bed to adsorb additional VOC
is exceeded,  the outlet VOC  concentration begins to increase.  This increase
in concentration is  referred to as VOC breakthrough and signals the need for
carbon replacement.

      4.2.2.2  Factors Affecting Performance and Applicability.   Factors  that
affect the adsorption capacity of activated carbon in non-regenerative
systems  include:

          •    VOC type and  inlet mass loading;
          •    moisture content of the inlet gas;
          •    temperature of the inlet gas; and
          •    carbon type,  amount, and condition.

Similarly, these factors determine the performance and  applicability  of
carbon adsorption as a VOC control method for refinery  wastewater  sources.
                                    4-27

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                                                    TREATED

                                                      GAS
                      v\\\\\\\\
                     ACTIVATED CARBON
                     .\V\\\\\
                                    \  \
Figure 4-6.  Schematic of Non-Regenerative Carbon Adsorption System
            for VOC Control.
                      4-28

-------
     The types of VOC vented to a carbon adsorption system from wastewater
sources are variable.  The majority of the compounds are low boiling
compounds since wastewater system normally operate at temperatures below
140°F.  Typical compounds emitted during emissions testing of air flotation
systems included paraffins and aromatics such as benzene, toluene, and
xylene.  The nature of the organics emitted would not result in any
significant carbon fouling problems.  However, if severe carbon fouling did
occur, off-site carbon reactivation (non-regenerative systems) would be the
most practical choice, since high boiling compounds are difficult to remove
by steam stripping.  Furthermore, if the carbon would need regeneration/
replacement only infrequently, the organics on the carbon may become even
more irreversibly adsorbed due to chemical or polymerization reactions that
may occur because of the long residence time on the carbon.  While the light
molecular weight of the emitted organics may preclude severe carbon fouling,
the full potential adsorption capacity of the carbon might not be realized.
Activated carbon has a greater affinity for larger nonpolar molecules; very
light organics can pass through carbon virtually uncontrolled.46

     The VOC mass rate is determined by the inlet gas flow rate and the VOC
concentration.  The VOC mass rate is of significance in determining the
service life of the carbon.  The inlet gas flow rate affects the gas-phase
residence time in the bed and therefore the VOC control efficiency.  If VOCs
are conveyed in an oxygen-containing gas stream, the inlet VOC concentration
is of significance for safety reasons—the concentration should be outside
of the explosive range of the mixture.  In a refinery wastewater control
application, the source(s) might be purged with nitrogen or refinery fuel
gas to reduce the possibility of oxygen contamination.  Nitrogen may be the
preferred purge gas; fuel gas would not only increase the chance of an
explosive situation but would also represent an additional VOC loading for
the carbon adsorption control system.

     Moisture content of the inlet gas stream affects the adsorption
capacity of the carbon for VOCs.  Water vapor competes with organic
compounds for adsorption sites, particularly at moisture levels
corresponding to relative humidities greater than 50 percent.  Therefore,
saturation or near-saturation levels of moisture in VOC-laden gas streams
from wastewater sources may significantly inhibit the ability of carbon
adsorption systems to control VOCs.  Demister pads are used by one refinery
to remove excess moisture from the VOC gas stream.47

     VOC adsorption capacity is inversely related to inlet gas temperature.
Most carbon adsorption systems are designed to treat gas streams having
temperature lower than 120°F.  The temperatures of VOC-laden gas streams
from refinery wastewater sources should be within the acceptable range.

     Finally, the properties of the carbon within the beds significantly
affect the VOC control efficiency.  Many types and grades of carbon are
available.  Selection of the appropriate carbon types and amount will
determine its adsorption capability and service life.  The ease of
                                    4-29

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replacement is important to the overall design, whether the carbon is
removed from containment vessels (e.g., by vacuum) or whether the
containment vessels themselves are removable (e.g., 55-gallon drums).48

     4.2.2.3  Control Efficiency.  Well-designed and operated state-of-the-
art carbon adsorption systems can reliably remove 95 percent of many types
of VOCs from contaminated gas streams.49  Some systems are capable of
achieving VOC control efficiencies exceeding 99 percent.50  A non-regenera-
tive system tested at one refinery was operating at 90 percent efficiency.
This system was controlling VOC emissions from an equalization tank of the
wastewater treatment system.47

     A non-regenerative carbon adsorption system must be designed and
operated conservatively and/or be monitored continuously to ensure that it
is controlling VOC emissions efficiently.  Frequent replacement of carbon
and continuous monitoring of the treated exhaust gas for VOC content are two
methods whereby maximum VOC control efficiency can be maintained.

4.2.3  Incineration

     Incineration, or thermal  oxidation, is a method for controlling VOC
emissions by high-temperature oxidation of the organic compounds to carbon
dioxide and water.  Incineration is recognized as the most universally
applicable of available VOC control methods because it can be used to
destroy essentially all  types of organic compounds from a variety of
sources, including refinery wastewater sources.51,52,53  The technology is
described briefly in this section, with emphasis placed upon its potential
as a VOC control  device for wastewater sources.

     4.2.3.1  Operating Principles.  Design specifications for incinerators
used for VOC control devices may vary considerably, but the basic design and
operating principles are represented by the schematic system shown in
Figure 4-7.  In this system, the VOC-laden gas stream is ducted from the
emission sources  to a burner zone.   A flame is established in the burner
zone by combustion of auxiliary fuel  (e.g., refinery fuel  gas) and air.  The
high-temperature  gases are expanded into a combustion chamber maintained at
a constant temperature,  typically in the range of 1000°F to 1600°F.  The
gases remain in the combustion zone for a residence time sufficient to
oxidize the VOC,  typically 1 second or less.   The combustion products are
then exhausted to the atmosphere.  Heat recovery (e.g.., inlet air preheat)
can be employed to minimize fuel  consumption.

     4.2.3.2  Factors Affecting Performance and Applicability.  A number of
factors determine the effectiveness of incineration as a VOC control  method.
These include:

               inlet waste stream characteristics;
               temperature;
               residence time;
               auxiliary fuel/air requirements; and
               other design parameters.


                                   4-30

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                 voc-
                LADEN
                 GAS
 EXHAUST TO
ATMOSPHERE
AUXILIARY
  FUEL
1
r
BURNER
A

COMBUSTION
ZONE



OPTIONAL
HEAT
RECOVERY
I

                  AIR
           Figure 4-7.  Schematic of Incineration System for VOC  Control.
                                  4-31

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The effect of these factors on incineration systems is discussed below.

     Incineration represents a flexible control  method in terms  of inlet VOC
type and concentration.  Factors relevant to induction of the inlet waste
stream from refinery wastewater to an incinerator are similar to those
described for carbon adsorption in Section 4.2.2.  In summary, oxygen-free
purge gases would be preferred.  One possible handicap inherent  with an
incineration system might be the necessity of a  relatively constant inlet
flow rate.  VOC-laden gases can be allowed to "breathe" through  a carbon
adsorber, but an incinerator may require a steadier inlet flow rate of waste
gases from wastewater sources in order to sustain stable flame conditions.
An incinerator can handle minor flow fluctuations, but more severe flow
fluctuations might require the use of a flare for VOC control.5k

     Combustion zone temperature can have a pronounced effect on VOC
destruction efficiency and auxiliary fuel consumption.  The required
temperature, which is controlled by the auxiliary fuel flow rate, would  be
determined by the VOC type and the required level of control.  Figure 4-8
represents an example case showing the effect of combustion zone temperature
on VOC destruction efficiency.

     In addition to combustion zone temperature, gas-phase residence time in
the combustion zone also contributes to the degree of completion of the
oxidation reaction.  Residence times on the order of 0.3 seconds to
1.5 seconds are typical for VOC control applications.5\55,56,57

     Auxiliary fuel and air requirements also affect the operation of an
incinerator.  Fuel type affects the design of an incinerator and fuel rate
determines its operating costs.  Some excess air is required for proper
fuel/air mixing and completion of the combustion reaction.  However, too
much excess air can have a negative impact on auxiliary fuel requirements
(heat losses) and design size.

     Other factors affect the performance and applicability of incineration
as a VOC control method for refinery wastewater  sources.  A major
consideration is heat recovery.  Primary or secondary heat recovery is often
utilized to minimized operating costs.  Primary  heat recovery refers to  heat
exchange between the hot combustion gases and the cool inlet VOC-laden gas
or auxiliary air stream.  Secondary heat recovery refers to heat transfer
between an incinerator gas stream and an adjacent, yet separate, process
stream.  Use of secondary heat would be limited  to those situations in which
such a process stream was adjacent and available to serve as a heat sink.

     Incineration represents a simple and reliable method of VOC control,
but several problems can limit its performance.   Fouling can occur,
particularly on heat exchange surfaces, although the probability of
significant fouling may be low for a refinery wastewater control
application.  Incinerator internals may be subject to corrosion  in the
presence of sulfur- or halogen-containing compounds.  The existence of the
                                    4-32

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                   100
00
CO
                        HYDROCARBONS
                             ONLY
                                                      HYDROCARBON AND CARBON
                                                      MONOXIDE (PER LOS ANGELES
                                                        AIR POLLUTION CONTROL
                                                          DISTRICT RULE 66)
                            1200
1250
1300    1350     1400
  TEMPERATURE. °F
                                                                      1450
                                          1500
1550
                         Figure 4-8.  Typical Effect of Combustion Zone Temperature on
                                    Hydrocarbon and Carbon Monoxide Destruction Efficiency.55

-------
former would be expected in refinery wastewater effluent gases,  but its
potential for causing corrosion problems in an incinerator is unknown.
Also, operation of an incinerator can be expected to result in secondary
emissions of oxides of nitrogen, carbon monoxide, and possibly
combustion-created organic reaction products.  However, proper design and
operation of the incinerator should result in negligible secondary emission
problems.

     4.2.3.3  Control Efficiency.  Incineration of VOCs from refinery
wastewater would be expected to achieve destruction efficiencies equivalent
to those achieved in other applications (i.e., 90 percent to 99+ percent at
temperatures between 1,000°F and 1,600°F).51+,56,58,59,60  The performance of
incineration with regard to VOC destruction efficiency would not be expected
to degrade over a period of time, as is typically the case for carbon
adsorption and catalytic oxidation systems.

4.2.4  Catalytic Oxidation

     Catalytic oxidation is a method of controlling VOC emissions by
oxidation to carbon dioxide and water in the presence of a catalyst.  Many
factors important to the design and operation of a catalytic oxidation VOC
control system parallel  those of an incineration system, which were
described above.  Therefore, the discussion in this section will be limited
to those aspects of catalytic oxidation that cause it to differ
significantly from incineration with regard to VOC control.

     4.2.4.1   Operating Principles.  Catalytic oxidation featues the use of
a metal- or metallic-alloy based catalyst to promote higher rates of VOC/
oxygen reactions at lower energy (temperature) levels.  Thus, temperature
and auxiliary fuel  requirements are lowered.  A schematic diagram of a
typical catalytic oxidation system is shown in Figure 4-9.  It is generally
similar to the incineration system described previously, except for the
presence of a catalyst chamber downstream of the burner zone.

     In operation, the VOC-laden gas is typically heated to 500°F to 900°F
by contact with hot combustion products of an auxiliary fuel/air burner.
The heated gas then enters the catalyst chamber.  The catalyst chamber
contains the catalyst material fixed on a substrate structure of large
surface area (e.g., pellets or a honeycomb configuration).  The catalyst
consists of platinum-, palladium-, copper-, chromium-, nickel-, cobalt-,
managanese-, or rhodium-based material layered onto the substrate.56,59  VOC
oxidation occurs in the  catalyst bed, with subsequent release of heat and an
increase in temperature.  The treated gas, at 700°F to 1200°F, exits the
reaction chamber and is  exhausted to the atmosphere.  Temperature is
controlled by auxiliary  fuel flow rate; the controlling temperature can be
measured at the catalyst inlet or outlet or as the average of the inlet and
outlet.52,53,56
                                    4-34

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               VOC-LADEN
                  GAS
                                         •CATALYST
                                                      EXHAUST TO
                                                     ATMOSPHERE
                                                                         4
AUXILIARY
  FUEL
1
'
BURNER
t
r

%
s^s
-



OPTIONAL
HEAT
RECOVERY


                 AIR
Figure 4-9.
                           Schematic of  Catalytic Oxidation System for
                           VOC Control.
                                    4-35

-------
      4.2.4.2   Factors Affecting Performance and Applicability.  Catalytic
 oxidation present potential advantages over incineration, but its use is
 limited because of  its sensitivity to inlet waste stream characteristics.

      If inlet  VOCs  are relatively heavy in molecular weight, they may
 collect or polymerize on the catalyst surface, thus reducing the available
 surface area of the catalyst.  Also, the presence of sulfur-, halogen-, or
 heavy metal-containing compound in the inlet gas can poison the catalyst or
 suppress its activity.56,59  The presence of the former could be expected in
 waste gas streams from refinery wastewater.  When the catalyst is poisoned
 or deactivated, a portion of the inlet VOCs can either pass through the
 system uncontrolled or be converted to aldehydes, ketones, or organic
 acids.57  Also, typical catalytic oxdiation systems are unable to handle
 excursions of  high  inlet VOC concentrations.  Excessive VOC loading can
 increase the heat release in the catalyst bed such that temperatures become
 high  enough to sinter (deactivate) or volatilize the catalyst.

      The gradual loss of catalyst activity due to any of the reasons
 described above introduces additional maintenance requirements for catalyst
 cleaning and/or replacement.

      4.2.4.3  Control Efficiency.   Catalytic oxidation systems can achieve
 VOC destruction efficiencies approaching 99 percent.59,61  However, certain
 data  indicate that, to achieve destruction efficiencies approaching or
 exceeding 95 percent, operating temperatures have to increase to levels that
 threaten to sinter or deactivate the catalyst.56  Recent test data for
 catalytic oxidation systems used in other industrial for VOC control
 indicate that half of the tested units achieved greater than 90 percent VOC
 destruction.57  The remaining tested units were capable of achieving 80 or
 90 percent VOC destruction.57

 4.2.5 Condensation

      In a vapor containing two components, one of which is essentially
 non-condensible at system conditions, condensation of the condensible
component occurs when its partial  pressure exceeds its vapor pressure.  Any
component in a vapor mixture can ultimately be condensed if the temperature
 is lowered far enough.   The point  where condensation first occurs is called
 the dew point.   As the  vapor is cooled below the dew point, condensation
will  continue until  the partial pressure in the vapor phase is once again
equal  to the vapor pressure of the liquid phase at the lower temperature.

      In the cases where the hydrocarbon concentration in the gas phase is
high,  condensation is relatively easy.   When concentrations are low,
condensation at reasonably achieved temperatures can be difficult.
Table  4-5 contains some examples of the temperatures required to achieve
90-95  percent condensation of some organic solvents.   It can be seen that
relatively low temperatures are needed,  even for compounds such as  xylene,
toluene, benzene and hexane.52  These compounds are  commonly found  in
gaseous emissions from  wastewater  systems.
                                   4-36

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                  TABLE 4-5.   PHYSICAL CONSTANTS AND CONDENSATION PROPERTIES OF SOME ORGANIC SOLVENTS61
-fc
 i

^j
                                   25% of LEL     90% Condensation   95% Condensation    90%  Condensation

                                 Concentration     From  25% of LEL   From  25% of  LEL      From  200  ppm

                Normal          Partial     Dew     Partial           Partial            Partial

m,nnrt,,nH      DB
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     There are two ways to obtain condensation.  First, at a given tempera-
ture, the system pressure may be increased until the partial pressure of the
condensible component exceeds its vapor pressure.  Alternately, at a fixed
pressure, the temperature of the gaseous mixture may be reduced until the
partial pressure of the condensible component exceeds its liquid-phase vapor
pressure.  In practice, condensation is achieved mainly through removal  of
heat from the vapor.  Also in practice, some components in muHi component
condensation may dissolve in the condensate even though their boiling points
are below the exit temperature of the condenser.

     Condensers employ several methods for cooling the vapor.  In surface
condensers, the coolant does not contact the vapors or condensate; condensa-
tion occurs on a wall separating the coolant and the vapor.  In contact
condensers, the coolant, vapors, and condensate are intimately mixed.

     Most surface condensers are common shell-and-tube heat exchangers.   The
coolant usually flows through the tubes and the vapors condenses on the
outside tube surface.  The condensed vapor forms a film on the cool tube and
drains away to storage or disposal.  Air-cooled condensers are usually
constructed with extended surface fins; the vapor condenses inside the
finned tubes.

     Contact condensers usually cool the vapor by spraying an ambient
temperature or slightly chilled liquid directly into the gas stream.  Contact
condensers also act as scrubbers in removing vapors which normally might not
be condensed.  The condensed vapor and water are then usually treated and
discarded as waste.  Equipment used for contact condensation includes simple
spray towers, high velocity jets, and barometric condensers.

     Contact condensers are, in general, less expensive, more flexible and
more efficient in removing organic vapors than surface condensers.  On the
other hand, surface condensers may recover marketable condesate and minimize
waste disposal problems.  Often condensate from contact condensers cannot be
reused and may require significant wastewater treatment prior to disposal.
     The coolant used in surface condensers depends on the saturation
temperature (dew point) of the VOC.  Chilled water can be used to bring
temperatures as low as 7°C,  brines down to -34°C, and reons below -34°C.
     The major pieces of equipment in a condenser system consist of the
condenser, refrigeration system, storage tanks, and pumps.  A typical
arrangement is shown in Figure 4-10.

     4.2.5.1  Factors Affecting Performance and Applicability.  Condensers
are not well  suited to treatment of gas streams containing VOC with low
boiling points or streams  containing large quantities of inert and/or
noncondensible gases such  as air, nitrogen, or fuel gas (methane).

     Condensers used for VOC control must often operate at temperatures
below the freezing point of  water.   Thus, moist vent streams (such as would
be present in gas streams  from wastewater sources)  must be dehumidified
before treatment to prevent  the formation of ice in the condenser.
                                    4-38

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•
VOC-LADEN- 	 	
GAS * »•
C0(
RE1

DEHl*
)LANT
fURN
1

UNIT ^ MA
^L m
i V
1 T"

f COOLANT
REFRIGERATION
PLANT

CLEANED
GAS OUT
IN ^V
NDENSER J
i ,
CONDENSED
VOC
!'
STORAGE
L^. TO PROCESS
OR DISPOSAL
Figure 4-10.   Condensation System.
                                  54
              4-39

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     Participate matter should be removed because it may deposit on the tube
surfaces and interfere with gas flows and heat transfer.  Gas flow rates in
the range of 100-200 cfm are typical of the capacities of condensers used as
emission control devices.

     Vent streams containing less than 0.5 percent VOC are generally not
considered for control by condensation.63

     Oil-water separators and air flotation systems usually operate at
temperatures below 140°F.  The vapor streams from these sources will
generally be saturated with water and will probably contain a large number
of compounds with a broad range of boiling points.  It is doubtful whether a
condenser system can be effective as a primary VOC control device.  There
could conceivably be applications in which the gas stream from the emission
sources is first passed through a condenser to recover some of the "higher
boiling" compounds.

     4.2.5.2  Control Efficiency.  The VOC removal efficiency  of a
condenser is highly dependent upon the type of vapor stream entering the
condenser, and on the condenser operating parameters.   Efficiencies of
condensers usually vary from 50 to 95 percent.61*

4.2.6  Industrial Boilers and  Process Heaters

     Industrial boilers and heaters are widely used for the thermal
destruction of captured VOC emissions.  A brief description of the
technology, factors affecting its performance and its  potential as a VOC
control method for refinery wastewater sources are discussed below.

     4.2.6.1  Operating Principles.  Boilers and process heaters are used
extensively in petroleum refineries.  They represent a potential emissions
control system for combusting captured VOC emissions from sources in
refinery wastewater systems.

          Industrial  Boilers.  Most refineries use boilers to provide steam
for direct use of various processes (e.g., light end strippers), for heating
and for the production of electrical power (via steam  turbines).  Boilers in
refineries are fired with the most available (and economical) fuel, such as
purchased natural gas, refinery fuel gas (mostly methane), residual oil, and
and combinations of these various fuel types.   Surveys of industrial boilers
used in the chemical  industry have shown that the majority are of watertube
design, and it seems  reasonable to assume that similar situation prevails in
the petroleum industry.5/+

     A watertube boiler is designed such that hot combustion gases are
present outside of heat transfer tubes.   Water flows inside the tubes and is
vaporized  by the heat that is transmitted through the tube walls.  The
tubes are interconnected to stream drums in which the  steam and hot water
are collected, separated, and stored.   The water tubes are relatively small
                                    4-40

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in diameter (2.0 inch being a typical diameter) to produce high liquid
velocities, good heat transfer, rapid response to steam demands, and
relatively high thermal efficiency.65  The thermal efficiency of the tubes
and drum system can be as high as 85 percent.  The efficiency can be
increased by recovering heat from the flue gas by exchange with combustion
air or feedwater.

     When firing natural gas, forced or natural draft burners are used to
thoroughly mix the incoming fuel and combustion air.  If a waste gas stream,
such as that from an oil-water separator vent, is combusted in a boiler, it
can either be mixed with the incoming fuel or fed directly to the furnace
through a separate burner.  A particular burner design commonly known as a
high intensity or vortex burner can be effective for waste gas streams with
low heating values (i.e., streams where a conventional burner may not be
applicable).  Effective combustion of streams with low heating values is
accomplished in a high intensity burner by passing the combustion air
through a series of spin vanes to generate a strong vortex.

     Furnace residence time and temperature profiles for industrial boilers
vary as a function of the furnace and burner configuration, fuel type, heat
input, and excess air level.66  This model predicts mean furnace residence
times of from 0.25 to 0.83 seconds for natural gas-fired water tube boilers
in the size range from 4.4 to 44 MW (15 to 150 x 106 Btu/hr).  Furnace exit
temperatures for this range of boiler sizes are at or above 1475°K (2810°F).
Residence times for oil-fired boilers are similar to those of the natural
gas-fired boilers.5tf

     Process Heaters.  Process heaters are used in petroleum refineries as
reboilers for distillation columns and to provide heat for reaction (naptha
reforming, thermal cracking, coking) and for preheating feed stocks.
Natural gas, refinery fuel gas, and various grades of fuel oil are all used
to fire process heaters.

     There are many variations in the design of process heaters, depending
on the application considered.  In general, the radiant section consists of
the burner(s), the firebox, and a row of tubular coils containing the
process fluid to be heated.  Most heaters also contain a convective heat
transfer to the process fluid.

     Process heater applications in the petroleum refining industry can be
broadly classified with respect to firebox temperature: (1) low firebox
temperature applications such as steam superheaters, and (3) high firebox
temperature applications such as thermal cracking furnaces and catalytic
reformers.  Firebox temperatures within the refining industry can be
expected to range from about 750°F for preheaters and reboilers to more than
2000°F for coking process furnaces.

     4.2.6.2  Factors Affecting Performance and Applicability.  The primary
function of boilers and heaters in refineries is to generate  steam and
                                   4-41

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provide process heat, respectively.  Their successful operation is critical
for the successful operation of refinery process units.  Thus, it is
extremely important that any injection of waste gases be done in a manner
that precludes any reduction in the efficiency, operability, and/or
reliability of the affected heater or boiler.  Variability in the flow rate
or composition of gas streams from wastewater sources could have an effect
on the combustion characteristics and heat output if the stream represents a
significant source of fuel relative to the normal fuel rate.

     Waste streams containing relatively high concentration of chlorinated
or sulfur-containing compound could cause corrosion problems in
heater/boilers that are not designed to handle either the compounds or their
combustion products.  When such VOC compounds are burned, the flue gas
temperature must be maintained above the acid dew point to prevent acid
condensation and subsequent corrosion.  However, the VOC being emitted from
refinery wastewater sources is expected to contain minimal amounts of
sulfur- or halogen-containing compounds.

     If the volume of the waste gas stream is significant when compared to
that of the heater/boiler fuel, its injection could affect the heat transfer
characteristics of the furnace.  Heat transfer characteristics are dependent
on the flow rate, heating value, and elemental composition of the waste gas
stream, and the size and type of heat generating unit being used.  Often,
there is no significant alteration of the heat transfer, and the organic
content of the water gas stream can, in some cases, lead to some reduction
in the amount of fuel required to achieved the desired heat production.
Wastewater streams are expected to be relatively small compared to the total
amount of fuel provided to most heaters and boilers in refineries.

     If the waste stream volume is significant, and the heat content
relatively low, the change in heat transfer characteristics after injecting
the waste stream could have an adverse effect on the heater/boiler
performance.  Even equipment damage could result.  In addition to these
reliability problems, there are also potential safety problems associated
with ducting wastewater emission vent to a boiler or process heater.
Variation in the flow rate and organic content of the vent stream could
cause extensive damage.  Another related problem is flame fluttering which
could result from these variations.  Potential flashback is another
possibility that must be considered.  Presently, there is only one refinery
known to be venting emissions from an air flotation system to a process
heater.67  No safety problems have been reported by the refinery.

     4.2.6.3  Control Efficiency.   Some testing has been performed to
evaluate the performance of boilers and heaters in destroying hydrocarbon
gases injected into the flame zones of the combustion devices.  The EPA
sponsored a test to determine the capability of an industrial boiler for
destroying polychlorinated biphenyls (PCB).68  A relatively small quantity
of PCB is added to the fuel oil which is then burned in the boiler.  The
test results indicated that more than 99.9 percent of the PCB was destroyed
in the boiler.
                                   4-42

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     Other tests conducted by EPA measured  the efficiency  of  five  process
heaters for destroying a mixture of benzene off-gas  and  natural  gas.69,70,71
The heaters were representative of those with both low-  and medium-
temperature fireboxes.  In both types of heaters,  more than 99  percent  of
the total Cj to C6 hydrocarbons in the gas  injected  into the  flame zone was
destroyed.

     Thus, when boilers or process heaters  are available,  it  appears  that
they are acceptable control devices for waste gas  streams.   In  general, they
appear to be at least 98 percent efficient  for destroying  VOC in the  vapor
phase.  The collected VOC gas streams from  refinery  wastewater  sources  may,
in some cases, be suitable for control with this technology.
                                   4-43

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4.3  REFERENCES

1.   Vincent, R.  Control of Organic Gas Emissions from Refinery Oil-Water
     Separators.  California Air Resources Board.  Sacramento, California.
     April 1979, p.  4.

2.   Racine, W.J.  Plant Designed to Protect the Environment.  Hydrocarbon
     Processing.  5J.(3):115.  March 1972.

3.   Trip Report.  R.J. McDonald to J. Durham, EPArCPB.  June 10, 1982,  p.
     2.  Report of June 9, 1982 visit to Exxon Company, Baton Rouge
     Refinery.

4.   Trip Report.  Laube, A.M., and R.G. Wetherold to R.J. McDonald,
     EPA:CPB, July 19, 1983.  Report of March 25, 1983 visit to Sun Oil
     Company, Toledo, Ohio Refinery.

5.   Memo and Attachment from Mitsch, B.F., Radian Corporation, to file.
     November 11, 1983.  Screening Data from Process Drains at Total
     Petroleum, Alma, Michigan.

6.   Memo and Attachment from Mitsch, B.F., Radian Corporation, to file.
     November 11, 1983.  Screening Data from Process Drains at Golden West
     Refinery, Santa Fe Springs, California.

7.   Memo and Attachment from Mitsch, B.F., Radian Corporation, to file.
     November 11, 1983.  Screening Data from Process Drains at Phillips
     Refinery, Sweeny, Texas.

8.   Memo from Wetherold, B. and Mitsch, B. F., Radian Corporation to file.
     January 26, 1984.  Analysis of Drain Screening Data from Phillips,
     Sweeny, Texas.

9.   U.S. Environmental Protection Agency.  Assessment of Atmospheric
     Emissions from Petroleum Refining.  Volume 3.  Appendix B:  Detailed
     Results.  Wetherold, R. G., L. P. Provost, and C. D. Smith.  (Radian
     Corporation.)  Research Triangle Park, N.C.   Publication No. EPA
     600/2-80-075C.  April 1980.

10.  Thibodeaux, L.J.  Chemodynamics.  New York,  John Wiley and Sons.  1979.

11.  Dean, J.A.   Lange's Handbook of Chemistry.  New York, McGraw-Hill Book
     Company.  1979.

12.  Treyball, R.E.  Mass-Transfer Operations.  New York, McGraw-Hill Book
     Company.  1980.

13.  Reid, R.C., J.M. Pransnitz and T.F. Sherwood.  The Properties of Gases
     and Liquids.  New York, McGraw-Hill Book Company.  1977.
                                    4-44

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14.  McAllister, R.A. (TRW, Incorporated) Internal Floating Roof Technical
     Analysis.  (Prepared for U.S. Environmental Protection Agency.
     Research Triangle Park, North Carolina.  January 1983.

15.  McCabe, W.C., J.C. Smith.  Unit Operations of Chemical Engineering.
     New York, McGraw-Hill Book Company.  1976.

16.  Drivas, P.O.  Calculation of Evaporative Emissions from Multicomponent
     Liquid Spills.  Environmental Science and Technology JL6_( 10):726-728.
     October 1982.

17.  Los Angeles County Air Pollution Control District.  Air Pollution
     Engineering Manual.  Second Edition.  Prepared for the
     U. S. Environmental Protection Agency.  Research Triangle Park, N.C.
     Publication No. AP-40.  May 1973.  p. 675.

18.  American Petroleum Institute.  Manual on Disposal of Refinery Wastes;
     Volume on Atmospheric Emissions.  API Publication 931.  Washington D.C.
     1976, p. 7-6.

19.  Trip Report.  Laube, A.H. and G. DeWolf, Radian Corporation,
     R.J. McDonald, EPArCPB.  July 12, 1983.  Report of March 14, 1983 visit
     to Tosco Corporation in Bakersfield, California.

20.  Trip Report.  Laube, A.M., Radian Corporation, to EPArCPB.
     May 17, 1983.  Report of March 17, 1983 visit to Mobil Oil in Torrance,
     California.

21.  Trip Report.  Laube, A.H. and G. DeWolf, Radian Corporation, co
     R.J. McDonald, EPArCPB.  June 3, 1983.  Report of March 14, 1983 visit
     to Champ!in Petroleum Company in Wilmington, California.

22.  Utah Bureau of Air Quality.  Engineering Review Analysis - Summary.
     Installation of Covers on Wastewater Separators at Chevron, U.S.A.,
     Inc.  Salt Lake City, UT.  May 1983, p. 1-2.

23.  Litchfield, O.K.  Controlling Odors and Vapors from API Separators.
     Oil and Gas Journal.  6jK44)r60-62.  November 1, 1971.

24.  Trip Report.  Wetherold, R.G. and A.H. Laube, Radian Corporation, to
     R.J. McDonald, EPArCPB.  July 19, 1983.  Report of March 25, 1983 visit
     to Sun Oil Company's refinery in Toledo, Ohio.

25.  Utah Bureau of Air Quality.  Engineering Review Analysis.  Summary.
     Installation of Covers on Wastewater Separators at Amoco Oil Company.
     Salt Lake City, UT.  December 1981.

26.  Letter and attachment from F.L. Blumquist, Petrex, Inc., to B. Mitsch,
     Radian Corporation, February 14, 1984.  Standard drawing for seal on
     floating cover.
                                   4-45

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27.  Ref.  17.  p. 7-2.

28   US  Environmental Protection Agency.  Compilation of Air Pollutant
     Emission Factors.  Third Edition.  Research Triangle Park, N.C.
     Publication No. AP-42.  August 1977.  P. 9.1-19.

29.  Ref.  1, p. 10.

30.  Telecon, Mitsch, B.F., Radian Corporation, with Bassett, C., Huntway
     Refining Company.  April 25, 1984.  Conversation about DAF system.

31   Telecon, Mitsch, B.F., Radian Corporation, with Crawford, D.,  Sigmor
     Refining.  June  29, 1983.  Conversation about DAF system.

32.  Memo  from  Mitsch, B.F., Radian Corporation, to  file.  June 15, 1984.
     Response to  California Air Resources Board Survey of  Refining  Industry.

33.  Telecon.   Laube, A.H.  Radian Corporation with  F.E.  Carleton,  IVEC.
     December 3,  1982.  Wastewater treatment system.

34  Trip  Report.   Laube,  A.H., Radian Corporation,  to McDonald,  R.J.,  EPA.
     May 17, 1983.   Report of  March  17, 1983 visit  to  Mobil  Oil Corporation
      Refinery at  Torrance, California.

 35.   Memo  from  Mitsch, B.F.,  Radian  Corporation,  to file.   May 16,  1984.
      Regulatory Alternative II for Air Flotation  Systems.

 36.   Memo from Hunt, G.  and Mitsch,  B., Radian Corporation to file.  April
      16, 1984.   Analysis of Emission Potential for Induced and Dissolved Air
      Flotation  Systems.

 37.  Laverman,  R.J., T.J. Haynie, and J.F. Newbury   Jesting Program to
      Measure Hydrocarbon Emissions from a Controlled Internal Floating Root
      Tank.   Prepared for American Petroleum Institute.  Chicago Bridge and
      Iron Company.   Chicago,  Illinois.  March 1982.

 38   Kalcevic, V.   (IT Enviroscience).  Control Device Evaluation  Flares  and
   '  the  Use of Emissions as  Fuels.   In:  U.S. Environmental Protection
      Agency.   Organic Chemical Manufacturing Volume 4:  Combustion Control
      Devices.  Research Triangle Park,  N.C.  Publication  No. EPA
      450/3-80-026.   December  1980.   Report  4.

  39.  Klett, M.G. and J.B.  Galeski.   (Lockhead Missiles and  Space
      Company,  Inc.)   Flare Systems  Study.   (Prepared  for  U.  S. Environmental
      Protection  Agency.)   Huntsville, Alabama.   Publication No.
      EPA-600/2-76-079.   March 1976.
                                     4-46

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 40-
             .
 41>   n!v!tr'/r?-  A T^Cfr Tech"lq"e for Determining  Efficiency of an
      Elevated  Flare.  E. I. duPont Nemours and Company, Wilmington, DE.




 42'   Flakes' KphD'n °n?rf f+Conve^sif of Flare Gas in Refinery High
      February  mo'. DlSSertatlon>  ^ndericiana University, Karlsruhl, FRG.
"

"
45.   McDaniel,  et  al.   (Engineering-Science.)  A Report  of a  Flare
          "
                            ^  Radia" C<"-P°^tfon to R.J.  McDonald,
                                  4-47

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51.  U.S. Environmental Protection Agency.  Control of Volatile Organic
     Compound Emissions from Air Oxidation Processes  in Synthetic Organic
     Chemical Manufacturing Industry.  Preliminary Draft Report.  June 1981.
     EPA-450/3-82-001a  Air Oxidation Processes in Synthetic Organic
     Manufacturing  Industry - Background Information  for Proposed Standards
     October, 1983.

52.  Waid, D.E.  "Controlling Pollutants Via Thermal  Incineration"  Chemical
     Engineering Progress  68(8):57-58, August 1972.

53.  Trip Report.   Laube, A.H.  Radian Corporation, to R.J. McDonald,
     EPA:CPB.  May  17, 1983.  Report of March 17, 1983 visit of Mobil Oil
     Corporation, Torrance, California Refinery.

54.  U.S. Environmental Protection Agency.  Distillation Operations in
     Synthetic Organic Chemical Manufacturing Industries.  Background
     Information for Proposed Standards.  Draft.  Research Triangle Park,
     N.C.  October  1982.  EPA-450/3-83—005a.  December 1983.

55.  U.S. Environmental Protection Agency.  Flexible  Vinyl Coatings and
     Printing Operations.  Background Information for Proposed Standards
     Draft EIS.  January 1983.  EPA-450-3-81-016a.

56.  Sittig, M.  Incineration of Industrial Hazardous Wastes and Sludges.
     Park Ridge, N.J.  Noyes Data Corporation, 1979.

57.  Radian Corporation.  Characterization of VOC Emissions from Thermal
     Incinerators, Test Report, Plant T-l.  Prepared for U.S. Environmental
     Protection Agency.  EPA 600/284-118a-i.  July 1984.

58.  U.S. Environmental Protection Agency.  Background Information Document
     for the Pressure Sensitive Tape and Label Surface Coating Industry.
     May 1983.  EPA-450/2-80-003a.  September 1980.

59.  U.S. Environmental Protection Agency.  Control  of Volatile Organic
     Compounds Emissions from Air Oxidation Processes in Synthetic Organic
     Chemical Manufacturing Industry.  Preliminary Draft Report.  June 1981.

60.  Barrett, R.E., and P.R. Sticksel.  Preliminary Environmental  Assessment
     of Afterburner Combustion System.  Prepared for the U.S. Environmental
     Protection Agency.  EPA 600/7-8-153.  Research Triangle Park, N.C.
     June 1980.

61.  Jennings, M.S., N.E.  Krohn, and R.S. Berry, Radian Corporation.
     Control  of Industrial  VOC Emission by Catalytic  Incineration.
     Volume 1.  Prepared for U.S.  Environmental  Protection Agency.
     April  26, 1984.
                                    4-48

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62.  U.S. Environmental Protection Agency.  Control of Volatile Organic
     Emissions from Existing Stationary Sources - Volume I:  Control Methods
     for Surface Coating Operations.  EPA 450/2-76-028.  Research Triangle
     Park, N.C.  November 1976.

63.  Controlling Emissions with Flare Towers.  Chemical Week.  132(21):49.
     May 25, 1983.

64.  Erikson, D.G.  (I.T. Enviroscience.)  Control Device Evaluation.
     Condensation.  U.S. Environmental Protection Agency.  Organic Chemical
     Manufacturing.  Volume 5:  Adsorption, Condensation, and Absorption
     Devices.  Research Triangle Park, N.C.  Publication No.
     EPA-450/3-80-027.

65.  U.S. Environmental Protection Agency.  Background Information Document
     for Industrial Boilers.  Research Triangle Park, N.C.Publication No.
     450/3-82-006a.  March 1982.

66.  U.S. Environmental Protection Agency.  A Technical Overview of the
     Concept of Disposing of Hazardous Wastes in Industrial Boilers.  Draft.
     Cincinnati, Ohio.  EPA Contract No. 68-03-2567.  October 1981.

67.  Trip Report.  Mitsch, B.F., Radian Corporation.  September 30, 1983.
     Report on Emissions Test at Golden West Refinery, Santa Fe Springs,
     California

68.  U.S. Environmental Protection Agency.  Evaluation of PCB Destruction
     Efficiency in an Industrial Boiler.  Research Triangle Park, N.C.
     EPA Contract No. 600/2—81-055a.  April 1981.

69.  U.S. Environmental Protection Agency, Emission Test Report on
     Ethyl benzene/Styrene.  Amoco Chemicals Company (Texas City, Texas).
     Reserch Triangle Park, North Carolina.  EMB Report No. 79-OCM-13.
     August 1979.

70.  U.S. Environmental Protection Agency.  Emission Test Report.  El Paso
     Products Company (Odessa, Texas).  Research Triangle Park, North
     Carolina.   EMB Report No. 79-OCM-15.   April 1981.

71.  U.S. Environmental Protection Agency.  Emission Test Report.  USS
     Chemicals  (Houston, Texas).  Research Triangle Park, North Carolina.
     EMB Report No. 80-OCM-19.  August 1980.
                                   4-49

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                     5.   MODIFICATION AND RECONSTRUCTION

     In accordance with  Title 40 of the Code of Federal  Regulations (CFR),
Sections 60.14 and 60.15, an existing facility can become an affected
facility and, consequently, subject to applicable standards of performance  if
it is modified or reconstructed.  An "existing facility," defined in
40 CFR 60.2, is a facility of the type for which a standard of performance  is
promulgated and the construction or modification of which was commenced prior
to the proposal date of  the applicable standards.  The following discussion
examines the modification and reconstruction provisions  and their
applicability to petroleum refinery wastewater systems,  specifically, to
process drain systems, oil-water separators, and air flotation systems.

5.1  GENERAL DISCUSSION  OF MODIFICATION AND RECONSTRUCTION PROVISIONS

5.1.1  Modification

     Modification is defined in Section 60.14 as any physical or operational
change to an existing facility which results in an increase in the emission
rate of the pollutant(s) to which the standard applies.   Paragraph (e) of
Section 60.14 lists exceptions to this definition which  will not be
considered modifications, irrespective of any changes in the emission rate.
These changes include:

     1.   Routine maintenance, repair, and replacement;
     2.   An increase in the production rate not requiring a capital
          expenditure as defined in Section 60.2;
     3.   An increase in the hours of operation;
     4.   Use of an alternative fuel or raw material if, prior to the
          standard, the  existing facility was designed to accommodate that
          alternative fuel or raw material;
     5.   The addition or use of any system or device whose primary function
          is the reduction of air pollutants, except when an emission control
          system is removed or replaced by a system considered to be less
          environmentally beneficial;
     6.   The relocation or change in ownership of an existing facility.

     As stated in paragraph (b), emission factors, material balances,
continuous monitoring systems, and manual emission tests are to be used to
determine emission rates expressed as kg/hr of pollutant.  Paragraph (c)
affirms that the addition of an affected facility to a stationary source
through any mechanism -- new construction, modification, or reconstruction  —
does not make any other  facility within the stationary source subject to
standards of performance.  Paragraph (f) allows provisions of the applicable
                                     5-1

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subpart to supersede any conflicting provisions  of 40  CFR 60.14    Paragraph
(g) stipulates that compliance be achieved within 180  days of the completion
of any modification.

5.1.2  Reconstruction

     Under the provisions of Section 60.15, an existing facility becomes an
affected facility upon reconstruction, irrespective of any change in emission
rate   A source is  identified for consideration as a reconstructed source
when:  (1) the fixed capital costs of the new components exceed 50 percent of
the fixed capital costs that would be required to construct a comparable
entirely new  facility, and  (2) it is technologically and economically
feasible to meet the applicable  standards set forth in this part   The final
iudqment on whether a replacement constitutes reconstruction will be made by
the Administrator of EPA.   As stated in Section  60.15(f), the Administrator's
determination of reconstruction  will be based on:

      1    The fixed capital cost of the replacement in comparison to the
           fixed  capital  cost  of  constructing  an  entirely new  facility,
      2    The estimated life  of  the facility  after  replacements  compared  to
           the life  of  a comparable  entirely new  facility;
      3.    The extent to which the components  being  replaced  cause or
           contribute to the emissions  from the  facility; and
      4    Any economic or technical limitations  in  compliance with  applicable
           standards of performance  which  are  inherent in the proposed
           replacements.

      The purpose of the reconstruction provision is to ensure that  an  owner
 or operator does not perpetuate an  existing facility  by replacing all  but
 minor components,  support structures, frames, housing, etc . rather than
 totally replacing  it in order to avoid being subject to applicable
 performance  standards.  In accordance with Section 60.5, EPA wi  .  upon
 request, determine if an action taken constitutes construction (including
 reconstruction).   As with modification, individual standards may include
 stifle provisions which  refine and limit the  concept  of reconstruction in
 40 CFR 60.15.

 5 2   APPLICABILITY OF MODIFICATION AND RECONSTRUCTION PROVISIONS TO VOC
       EMISSIONS  FROM PETROLEUM REFINERY WASTEWATER  SYSTEMS

       Chances in refinery  product demand  and  in  available  refinery  feedstocks
 are  expected to result Va  number of modernization  and alteration projects
 at  existing  refineries  over  the next  several years.   Some of these projects
 coutd resuit in exi ting  process drain systems, oil-water separators   and air
  flotation systems  becoming subject to  regulation under  provisions  of  Sections
  60  14 and 60.15.   Examples in which this could  occur are presented below.
                                       5-2

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  5.2.1  Modification
                         '
                                              "^rational change to an
are an increase in organic loa
                                                                     events

      3.    Changes  in  product  slates.

      1.    Changes  in  the  type of  crude  oil  processed.
 Determination o



 5-2.2  Reconstruction
                                                        r«ult '" these
                              uinffed.
NSPS under the reconstruction prov sionl    RecoSsinirlfn  "^ .SUbJeCt t0 the
the criteria given in Section ? 1  ?   n!l  ^construction is determined by

made on a case by case basis"         Determination of reconstruction will  be
                                   5-3

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                6.   MODEL UNITS AND REGULATORY ALTERNATIVES

     The purpose of this chapter is to define model  units and identify
regulatory alternatives.  Model units are parametric descriptions of a
representative cross-section of the units that, in the judgment of EPA are
likely to be constructed, modified or reconstructed.  The model unit
parameters are used as a basis for estimating the environmental, energy,  and
economic impacts associated with the application of the regulatory
alternatives to the model units.

6.1  MODEL UNITS

     Petroleum refinery wastewater systems differ considerably from site  to
site.  Because wastewater characteristics such as flow rate and oil content
may be unique to each refinery, various treatment schemes and techniques  may
be employed by each refinery.  For this reason, it is difficult to define a
model petroleum refinery wastewater system and more reasonable to define
model units for specific emission sources in petroleum refinery wastewater
systems.  Section 6.1.1. discusses model units for process drains and
junction boxes.  Sections 6.1.2 and 6.1.3 discuss model units for oil-water
separators and air flotation systems, respectively.

6.1.1  Process Drains and Junction Boxes

     An EPA study of emissions in petroleum refineries provided information
on the population of fugitive emission sources.1  Included in the sources
counted were drains and pumps.  Thus, drain populations as well as the
ratios of drains to pumps, were obtained for several refinery process units
of varying complexities.  Further, information gathered by California Air
Resources Board has allowed estimates of junction box population, and ratio
of drains to junction boxes to be developed.2  These relationships were used
in developing model units.  The number of process drains and junction boxes
in a process unit was found to be dependent on the complexity of the unit
and independent of unit capacity or size.  Therefore, model units are
developed on the basis of drain population.

     Model units for process drains and junction boxes are presented in
Table 6-1.  Refinery process units have been grouped into three model units
based on the complexity of the process unit.  Model  Unit A represents
process units of high complexity.  It should be noted that within the high
complexity model unit category, process units can be of varying capacity.
Using information acquired in the EPA and California studies, the number  of
pumps in these process units is estimated to be ten.  Applying a ratio of
2.75 drains per pump, an estimate of 94 drains is derived.  Further, using
the ratio of six drains per junction box, it is estimated that sixteen
junction boxes are located in these units.
                                    6-1

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                                       TABLE  6-1.  PROCESS DRAINS MODEL UNIT PARAMETERS
cr>
i
no
— '
Model
Unit
A


B




C



	 	 	 — 	
Representative
Process Unit Types
Crude Distillation
Fluid Catalytic Cracking

Treating Processes
Lube Oil Processing
Alkylation
Catalytic Polymerization
Isomerization
Thermal Cracking/Coking
Solvent Extraction
Hydrocracking
Hydrotreating
Hydrorefining
Light Ends/LPG
Catalytic Reforming
Vacuum Distillation
Hydrogen Manufacture

Model Uni
Range
Small3
Average
Large
Small3
Average
Large



Small3
Average
Large'

Number of sources
t Capacities in ModelcUnit
CapacUy p ump Boxesd (
20
47 34 94 16
113
3
17 16 44 8
36



5
28 10 28 5
67
	 . 	 . 	

Uncontrolled
•missions (Kg/yr)

30.8


14.6




9.3


       Average of smallest 10 percent of representative  unit  types.



       Average of largest 10 percent of representative unit types.


       Estimated using factor of 2.75 drains/pump.   (Reference  1).


       Estimated using factor of 6.0 drains/junction box.  (Reference 2).

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  esti JtprfTJT £ dra1nS a"? Junct1on boxes  in  Model Units B and C are
  estimated using the same method.  Model  Unit  B represents orocess unit!
  medium complexity while Model Unit C represents  uRllsSf'l
 6.1.2  Oil -Water Separators
      Model Units for oil-water separators are presented in Table 6 ?   ^

                                       Surface ^" of the
                                                      modei
                                                                      .
             f^ 1s  the  area  of  the separator that is open to the




6.1.3.   Air  Flotation Systems
        te»]]e,tlAS«.»ll.bl?e  ""*8' 5° gpm' approach" tte
        indicate that DAF f^t™« »u       Conversations with vendors and
                                      '
                                   6-3

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          TABLE 6-2.  OIL-WATER SEPARATORS MODEL UNIT PARAMETERS
Wastewater flow
Model plant
A
B
C
thousand BPD (gpm)
50
25
2
(1500)
(750)
(50)
Surface
Arga
m
107
58
58
UncontrolledbVOC
emissions
kg/hr
37.8
18.9
1.3
Mg/yr
331.0
165.6
11.0
aRefers to the surface area of the separator that will  be  open  to  the
 atmosphere.   Surface areas were calculated using American Petroleum
 Institute (API) design specifications (Reference 3).

Calculated using Litchfield Method assuming conditions listed  in  Table 3-5.
                                     6-4

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                TABLE 6-3.   AIR FLOTATION  MODEL  UNIT  PARAMETERS
M d Surface3
Uncontrol
led VOC
- DAF*
Uncontrolled VOC

A 50 (1500) 70.0
B 25 (750) 35.0
C 2 (50) 2.3
1.37
0.63
0.05
12.0
6.0
...
0.27 2.4
0.14 1.2

 Refers to the surface area of the dissolved air flotation  system  only
 Surface areas calculated using formula that assumes  1  square  foot of
 surface area is required for 2 gpm of wastewater flow  (Referent  1)   The

  ostTf ?orn?ro? 91?AF °^ f°r * °AF Slnce  this area will  determine 'thl
 cost or control.  IAF systems come equipped with covers.

 Uncontrolled emissions for a DAF are based  on  the emission factor

 walSat'r f^.^'  ^ ™^™ ^ is  15'2 ^ Per ^llons  of
^controlled emissions  for an  IAF are based on the emission factor
 determined  by testing.  The emission factor has been modified ^account

 section  "I?3r j"PPll6d  Wlth the IAF SyStem as exPlained i" Chapte? 4
                                   6-5

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flow rates than 1500 gpm are possible.   However, flow rates greater than
1500 gpm would most likely be handled in multiple units to allow for
operating flexibility.

     Surface areas for air flotation systems were calculated using an
empirical formula provided by a vendor.7  The surface areas are only
applicable to DAF systems.  Most IAF systems used in refinery applications
come equipped with covers.  Surface area represents the area of the DAF
system open to atmosphere.  The uncontrolled emission levels for air
flotation systems are based on emissions testing conducted by EPA at three
petroleum refineries.

6.2  REGULATORY ALTERNATIVES

     This section presents  regulatory alternatives  for controlling  VOC
emissions from process  drains, oil-water separators,  and  air flotation
systems.  These  regulatory  alternatives  are  summarized in Table 6-4.

Regulatory  Alternative  I

     Regulatory Alternative  I  represents no additional  control  over baseline.
 Baseline control  is defined as  the level of control current y  achieved by
 industry.  This  usually reflects  the degree of control  required by state and
 local  regulations.   Regulatory  Alternative I provides the basis for
 determining the  impacts of other  regulatory alternatives.

 Regulatory Alternative II

      Regulatory Alternative II  provides a higher level of control than
 required by Regulatory Alternative I.  For process drains, th   alternative
 requires all drains and junction boxes to be water sealed.  Oil-water
 separators are to be completely covered with either a fixed or float ng
 cover   Dissolved air  flotation systems are required to  be covered with a
 tightly  sealed fixed roof.  For induced air flotation systems, work
 practices  are required to  operate  the  IAF under gas-tight conditions.  These
 control  techniques  have been discussed  in Chapter  4.

 Regulatory Alternative III

       Regulatory Alternative  III  requires  the  highest  level  of  emission
 reduction    For process  drains,  a completely  closed  drain system is  required
 with  vapors  vented to  a  control  device.   Under Regulatory Alternative III,
 Sl-wlter  separators are also  required to be  completely  covered  with a
 qasketed and sealed fixed  roof with vapors  to be vented  to a  control  device.
 Mr flotation  systems, both  DAF  and IAF,  are  also required to be completely
  covered with a  fixed roof with vapors  vented  to a control device.   The
  control techniques for Regulatory Alternative III have  been discussed in
  Chapter 4.
                                       6-6

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                                      TABLE 6-4.   REGULATORY ALTERNATIVES
 Regulatory
 Alternative
 Process  Drains
No Additional
Control
Oil-Water Separators   No Additional
                       Control


Air Flotation Systems  No Additional
                       Control
                                                  II.
                                          Water-sealed process  drains
                                          and junction boxes.
                   Fixed  or floating  covers.
                  DAF systems provided with  a
                  gasketed and sealed fixed  roof,
                  vented to atmosphere.   IAF
                  systems maintained gas-tight
                  by gasketing and sealing access
                  doors.
                                                                                   III.
Completely closed drain  system
with vapors led  to a control
device.

Gasketed and sealed fixed roof
with vapors vented to a
control device.

Gasketed and sealed fixed roof
with vapors vented to a
control device.

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6.3  REFERENCES

1    U.S. Environmental Protection Agency.  Assessment of Atmospheric
     Emissions from Petroleum Refining.  Volume 1:  Technical Report.
     Wetherold, R. G. and D. D. Rosebrook (Radian Corporation).  EPA
     Publication No. 600/2-80-075a.  April 1980.

2.   Memo from Mitsch, B. F., Radian Corporation, to file.  June 15, 1984.
     Response to California Air Resources Board Survey of Refining Industry.

3    American Petroleum  Institute.  Manual on Disposal of Refinery Wastes,
     Volume on Liquid Wastes.  Chapter 5.  Washington, D.C.  1969.

4    US. Filter  Fluid Systems Corporation.  HydroceHl Induced Air Flotation
     Separator.   Bulletin No.  HY-1181-6M.

 5    Telecon.  Mitsch, B. F.,  Radian  Corporation, with Jim  Wahl, AFL
      Industries.   July 13,  1983.  Conversation  concerning sizes of DAF
      systems.

 6.   Telecon.  Mitsch, B.  F.,  Radian  Corporation, with Chuck Bassett,
      Huntway  Refining Company, Benicia,  California.   June M, wJ.
      Conversation concerning the wastewater treatment system at  Huntway.

 7.   Komline  Sanderson.   Dissolved Air Flotation.  Bulletin No.  KSB
      123-8106.
                                     6-8

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                            7.   ENVIRONMENTAL  IMPACTS
  7.1  INTRODUCTION
          '                                                              ••'•-
  7.2   AIR  POLLUTION  IMPACTS
                  ^
          — -  ••» • I t%*l\,«ll\*l^

 described in Chapter 4.

 alternatives for each
                                                      Wastewater System
from ndifti/conrrtedodiS-f5  ^ ^°JeCted  VOC
1989.  Table 7-2 lists oroiect ion,  JH    Uni?  dunng  the  Period  1985 to
process drain systems  PTab?es 7  I  InH H ?nd.modl'fl'ed/reconstructed

modified/reconstructed ol 'wate "sepamols an'd  a'ir'n'I0^ f°r "6W and
respectively.                    separators and  air flotation systems,
be built Kith 3
                                             S?"*" Un1U are est1mated
                                                                  unns'
                                   7-1

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                    TABLE  7-1    ESTIMATED  EMISSIONS  AND  EMISSION  REDUCTIONS  FOR
                            EACH MODEL UNIT  AND  REGULATORY  ALTERNATIVE
Model Units3
. 	 	 — •
Process Drains and Junction Boxes
A
B
C
Oil-Vlater Separators
A
B
C
Air Flotation Systems (DAF)
A
B
C
Air Flotation Systems (IAF)
A
B
C
Regulatory Alternatives
Estimated Emissions, Mg/yr (% Reduction From Reg. Alt. I)

30.8 (0)
14.6 (0)
9.3 (0)
331.0 (0)
165.6 (0)
11.0 (0)
12.0 (0)
6.0 (0)
0.4 (0)

2.36
1.18
0.07

15.4 (50)
7.3 (50)
4.7 (50)
49.7 (85)
24.8 (85)
1.7 (85)
2.8 (77)
1.4 (77)
0.1 (77)

1.81 (23)
0.91 (23)
0.06 (23)
III
0.6 (98)C
0.3 (98)C
0.2 (98)C
9.9 (97)C
5.0 (97)C
0.3 (97)C
0.4 (97)C
0.2 (97)C
0.01 (97)C

0.4 (85)C
0.2 (85)C
0.01 (85)C
aModel Units are described in Chapter 6.
bp.egulatory Alternative I represents no control.
cCaptured VOC emissions vented to an existing flare.

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                                   VOC
                       Year
Number of  Affected Model Units
                                                                         Each Regulatory Alternative  (Mg/yr)
                       1985
                       1986
                       1987
                       1988
                       1989
6
12
18
24
30
6
12
18
24
30
                      12
                      24
                      36
                      48
                      60
 384
 768
1152
1536
1920
192
384
576
768
960
 8
15
23
31
38
1
CO
                               ™»ul"M°"s-  F°r P™«ss drains  and Junction

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                TABLE 7-3   PROJECTED VOC EMISSIONS  FROM NEW AND  MODIFIED/RECONSTRUCTED OIL-WATER
                TABLE / d.     Jtutu    FQR REGULATORY ALTERNATIVES IN  PERIOD  FROM 1985 - 1989
Total Annual VOC Emissions Projected for
Year Number of Affected Model Units
A
1985 1
1986 2
1987 3
1988 4
1989 6
B
2
4
6
8
11
C
3
6
9
12
16
Each Regulatory Alternative (Mg/yr)
Baseline3
527
828
926
1030
1211
II
104
208
312
416
597
III
21
42
62
83
119
Baseline  reflects  the  current  level of control required by State regulations.  The State regulations for

 oil-water separators are  presented  in Section 3.4.

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TABLE 7-4.   PROJECTED VOC EMISSIONS FROM NEW AND MODIFIED/RECONSTRUCTED AIR FLOTATION
                 SYSTEMS  FOR  REGULATORY ALTERNATIVES  IN  PERIOD  FROM 1985 -  1989
— - — - — , 	 .... _ ----- 	 , , _ 	 _ _
Year Number of Affected

Pt
1985 i

1986 ?

1987 3
o
1988 4

1989 6

JJ








11
Model Units
c

2

4

6

8
11
lotal Annual VOC Emissions Projected for
Each Regulatory Alternative (Mg/yr)
Baseline9

14.8

29.7

44.5

59.3
85.1
II
- ~-
4.7

9.5

14.2

18.9
27.1
III

0.7

1.5

2.2

3.0
4.3

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would continue over the next five years and that approximately 10 percent of
the drain systems in existing units with ongoing construction projects will
be impacted by the NSPS under the modification/reconstruction provisions.

     Estimates of the number of modified/reconstructed oil -water separators
and air flotation systems were determined by assuming that these units will
equal 10 percent of the new units.  Therefore, it is estimated that
approximately three oil-water separators and three air flotation systems
will be impacted by the NSPS under the modification/reconstruction
provisions during the five-year period.

      In Tables  7-2, 7-3,  and 7-4,  baseline  reflects  the level of control
currently  required  by State  regulations.   Baseline for the three emission
sources Jere  presented  in Section  3.4.  OnlV^^i/TJKaJp6
currently  controlled by State  regulations.  As  a  result of the  State
regulations,  about  85 percent  of  the  new  separators  will  be  covered,
 5 percent  partially covered, and  10 percent uncovered.
      The projected emissions for process  drain  systems  weren5sjj"a*!j  "JS
 emission factors determined for drains and junction  boxes  and  the  projected
 growth estimate discussed above.  For oil-water separators,  similar
 information was used along with information regarding current  State
 reflations.  The projected emissions reflect the current  percentage of
 separates estimated to be fully covered, partially  covered, and uncovered.

      Projected emissions from air flotation systems  are based on the
 emission factors and projected growth estimates   Further  as discussed in
 Chapter 3, it is estimated that 50 percent of the new units will be IAF
 systems and 50 percent will be DAF systems.

 7.2.3   Secondary Air Pollution  Impacts

       Secondary air  pollution  impacts  are  those  impacts gyrated by the
 emission  control  techniques.   Control  techniques required by Regulatory
 AHernaJive  II  include water  seals for drains  and junction  boxes, covers for
 o 1-water separators and DAF  systems, and gas-tight  operation for   AF
 systems.   These  controls would not create any  secondary air pollution
 impacts.

       Regulatory Alternative III for  all  three  emission sources  require VOC
  destruction devices.   Carbon  adsorption  systems require steam to  be used  tor
  regeneration of the carbon beds.   Fuel combustion to produce  steam  may
  relult in emissions of some air pollutants.   However,  the Quantity  of air
  pollutants produced is expected to be minimal.  For example,  if all new
  separators and air flotation systems required a designated carbon adsorber
  the amount of natural  gas needed to produce steam to regenerate these units
  is estimated to be 1.82 million cubic feet per year.  The amount of
  secondary pollutants generated by burning this amount of natural  gas would
  be approximately 1.1 pounds of S0x and 255 pounds of NO^1
                                      7-6

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7.2.4

incr-ent.,
7.3  WATER POLLUTION  IMPACTS
 processes.
                                regulatoryalternatives «ou,d not  have an


                                i i S   H?4u=-<-
                              in organic loading to subsequent treatment
 for the0seofaSeWaertn          l ^™  * Beater affinity
 of VOC In the oil phase was about one ?h™«n!!ai-r Ph^e'  The co"centration
 Phase.   To the extent  that rnnS^i?  Jh?usand tlmes that  in the water
 these  VOC will ££#  be^pTe ^in ^^if an'd'^6"  7****™ °f VOC'
 processes.  Suppression into thpJ? ^      a?d removed to recovery
 great  if the va' or ^ J  « of a  epa   to' 'or Sr JlS**-* eXPeCted t0 be as
 (as  required by Regulatory Alternat?w« r?f ?   flotation system is  purged
 flotation).   However  when
 be directed             '
 would occur.
                                        °r seParators and air

                                        ^"^-' the V°C removed
                                        adverse  impact on water  quality
                                        0fSol1d
 7.4  SOLID WASTE  IMPACTS

     There will not be a
 result of implementing the  reauiamrv an-Q™  *•      T,     •  	
 source of solid wastewill  be^rom carboaSJnrn?'  The °"ly P°SSible
 carbon is  disposed rather than regenerated  sml??™" S^.temS'  If activated
will  be produced.              regenerated, small quantities of solid waste

7.5  ENERGY IMPACTS AND  WATER USAGE
                                7-7

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TABLE 7-5   SUMMARY OF ANNUAL EMISSIONS AND EMISSION REDUCTION  BY  1989  FOR  SOURCE
TABLL / b.  buniWKT j£TEGQRY (NEW AND MODIFIED/RECONSTRUCTED  UNITS)
	 • 	
__ 	
Emission Source Regulatory Alternative
Process Drains and I
Junction Boxes
II
III
Oil -Water Separators I
II

III

Air Flotation Systems i
II
III
Annual
Emissions by 1989
(Mg/yr)
1920

960
38
1211
597
0

84

27
4

% Reduction From
Baseline
-

50
98
-
54
91

_

69
95

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 for air flotation systems would result in consumption of small  quantities of
 steam, water, electricity and fuel gas.  As explained in Chapter 6? these
 alternatives require that VOC be captured and vented to a control  device
 In some cases, refinenes will have existing control devices accessible to
 these emission sources.  Only blowers would be required to transport the VOC
 MnSr,6*1??!!9 C°ntr°] deVice'  Electricity would be required  tSpower the
 blowers   if designated control devices are needed, utilities would be
 required to operate the control device.  In the case of carbon  aborbers
water, steam, and electricity would be needed.                  d^oroers,

     Tabl? 7~n is-,a summar> of utility requirements which would result  from
7.6  OTHER ENVIRONMENTAL  CONCERNS

     Implementation  of the  regulatory alternatives is not expected to result

                                  7-9

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              TABLE 7-6   ENERGY REQUIREMENTS AND WATER DEMAND - REGULATORY ALTERNATIVE III FOR PROCESS
                           DRAINS AND JUNCTION BOXES, OIL-WATER SEPARATORS, AND REGULATORY
                                      ALTERNATIVE II FOR AIR FLOTATION SYSTEMS
Emission Source # Affected Units by Fuel Gasa t}^.}^
1989 (MM scf/yr) (kWh/yr)





i— «
o
Process Drains
Oil -Water Separators
Oil -Water Separators0
Air Flotation Systems
Air Flotation Systems
a
120
33
33
28
28

13 352,350
161,730
330,000
137,230
280,000

Water Steam
(nT/yr) (Mg/yr)
-
-
12,400 354
_
10,528 300

 Fuel  gas assumed to be used to purge closed  drain system.

Assumes existing control  device available.   Electricity  requirements  for  blowers to transport  VOC  to
 control device.   Cost sharing possible  between  separators  and  air  flotation systems but  has not been
 considered in this analysis.

Electricity, steam, water, needed for blower, carbon  adsorption  system.   Cost  sharing  possible between
 separators and air flotation systems but has not been considered in  the analysis.

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7.7  REFERENCES

1.   U.S.
                                                            Air
                                                            13.

2.
                                             „„„      ^  . ..     -lerjc
                                  7-11

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                                  8.  COSTS

     This chapter presents the methods used to estimate costs for
controlling volatile organic compounds (VOC) from petroleum refinery
wastewater systems.  Cost estimates are given for each regulatory
alternative and model unit described in Chapter 6.  In Chapter 9, the
results of this cost analysis are used to determine the economic impact of
the regulatory alternatives.

8.1  COST ANALYSIS OF REGULATORY ALTERNATIVES

     The costs of major equipment (covers for oil-water separators and air
flotation systems) needed for the regulatory alternatives were acquired from
actual installations in the refining industry.  The costs of additional
equipment such as piping, blowers, and vapor control devices were estimated
using engineering references.1,2,3,4,5  Standard costing procedures devised
by Uhl1,* were then used to estimate capital and annual costs for each model
unit and regulatory alternative.  Tables 8-1 and 8-2 present the cost
algorithms used in the analysis.  All costs were updated to third quarter
1983 dollars using Chemical Engineering Plant Cost Indices.8

     Section 8.1.1 presents the costs associated with implementing the
regulatory alternatives for process drains and junction boxes.  Sections
8.1.2 and 8.1.3 present the costs associated with implementing the
regulatory alternatives for oil-water separators and air flotation systems,
respectively.  For all three emission sources, costs for both new and
retrofitted control systems are discussed.

8.1.1  Process Drains and Junction Boxes

     Regulatory alternatives for process drains and junction boxes have been
discussed in Section 6.2.  Regulatory Alternative I requires no additional
control and, therefore, does not result in any costs.  The costs for imple-
menting Regulatory Alternatives II and III are discussed below.

     8.1.1.1  Regulatory Alternative II - Water Sealed Drains and Junction
Boxes.

     New Process Drains and Junction Boxes.  A P-trap water sealed drain was
used as the basis for estimating the costs for Regulatory Alternative II.  A
P-trap drain has been illustrated in Figure 3-7.  The materials needed to
construct uncontrolled, P-trap, and closed drains are given in Table 8-3.
The materials needed for these drain types were derived from actual
installations and from engineering judgement.   The cost associated with
implementing Regulatory Alternative II is the additional cost of a P-trap
drain over an uncontrolled drain.  The difference in total  depreciable
investment (TDI) between an uncontrolled drain and a P-trap is approximately
172 dollars.  The difference in cost is due primarily to additional
                                    8-1

-------
        TABLE 8-1.   COMPONENTS  AND  FACTORS  OF  TOTAL  CAPITAL  INVESTMENT3
Direct Costs

   Purchased equipment costs
   Installation costs include:

   Piping
   Structural Steel
   Concrete
   Electrical
   Instrumentation
   Other  (paint,  insulation,  etc.)
   Installation labor


                           Total  Direct  Capital  Cost  (TDC)  =
 Indirect Cost
    Engineering and supervision (10% of TDC)
    Miscellaneous field expenses (5% of TDC)
                                                Subtotal A = 1.15 x TDC
    Contractors' fees (10% of subtotal A)
    Contingencies (15% of subtotal A)
                                                Subtotal B = 1.25 x Subtotal A
     Interest  during  construction  (12%  of  subtotal  B)
     Startup (5% of  subtotal  B)
                         Total  Depreciable Investment (TDI)  = 1.17  x Subtotal  B
  References 1 and 2.
                                           8-2

-------
         TABLE 8-2.  COMPONENTS, FACTORS, AND RATE OF TOTAL ANNUAL COST3
  Basis:  24 hour/day, 365 d/yr.
  Direct Annual Operation and Maintenance Expenses (O&M)

       Labor     - Operating
                 - Maintenance
                 - Supervisory
                 - Other

       Materials - Operating
                 - Maintenance

       Fuel  gas

       Electricity

       Other  (list as  required)


 Total Direct O&M (DOM)


 Indirect Annual O&M Expenses

      Overhead
      General and administration
      Insurance and Property Taxes


 Total  Indirect O&M (IOM)


 Total  Annual  O&M Expenses  (TAOE)


 Capital Recovery  (CR)  (Capital
  recovery factor for  10% over
  10 years x TDI)

Total Annual Cost
  hr/yr x $14.00/hrb
  2.5% of TDC
  10% of O&M labor
       -0-

       -0-
  2.5% of TDC

  annual  usage  x  $3.50/1000  scfc

  annual  usage  x  $.05/kWhc




 Sum of the above
 70% of all labor
 2% of TDI
 2% of TDI
 Sum of the above



 DOM +  IOM



 0.163  x TDI


•	  .. .—.	__

TAOE + CR
bReferences 1 and 2.
Reference 6.
 Reference 7.
                                   8-3

-------
       TABLE 8-3.  TOTAL DIRECT CAPITAL COST OF MAJOR EQUIPMENT FOR
                   VOC CONTROL ON PROCESS DRAIN SYSTEMS0


1.
2.


Uncontrolled Drain System
Straight Pipe (4" diameter, 4.25 ft)
Wye (cast iron, no hub)

Total Installed3
Cost ($)
20
58
Total 78
     Water Sealed Drain Systems
P-Trap Drain

1.   Straight Pipe (4" diameter, 4.25 ft)
2.   Wye (cast iron, no hub)
3.   P-trap (4" cast iron, 1/4 bend-3)
4.   El bend (4" cast iron)
Water Seal Pot on Junction Box

1.   Straight Pipe  (4" diameter, 1 ft)
2.   1/4 bend (4" cast iron)
3.   Cup  (6" welded)
4.   Water refill line (20 ft 1/2 steel pipe)
5.   Globe value  (bronze)
6.   1/4  bends  (2)  (1/2" steel)
7.   Tee  (1/2"  cast iron)
      Closed Drain System
 Closed Drain
 1.    Straight Pipe (4"  diameter,  4.25 ft)
 2.    Wye (cast iron,  no hub)
 3.    Flange (4" carbon  steel  #150)
 4.    Union (3/4" carbon steel)
 Underground Tank and Purge Gas System

 1.   Fabricated tank0

 2.   Purge Gas System
                                                  Total
                                                  Total
                                                   Total
     20
     58
     77
     25
    180
      5
     25
     65
     28
     30
     20
     42
    215
      20
      58
     113
      13

     204
$44,298.00

$ 2,585.00
  'Cost includes materials and labor, 3rd quarter 1983 dollars.
  'Reference 3.
  'Breakdown of materials given in Table 8-6.
                                     8-4

-------
materials and labor needed for the P-trap.  Therefore, 172 dollars
represents the cost per drain of implementing Regulatory Alternative II.

     A water seal pot with a water line was used as the VOC reduction
technique for junction boxes.  The water seal pot has been illustrated in
Figure 3-9.  The materials used to construct a water seal pot and the
associated costs are given in Table 8-3.  Using these cost estimates and the
costing algorithms given in Table 8-1, total cost for controlling VOC from
junction boxes was estimated to be $362 dollars per junction box.

     The costs for implementing Regulatory Alternative II for new process
drain model units are shown in Table 8-4.  These costs were derived by
applying the costs of P-traps drains and controlled junction boxes to the
number of drains and junction boxes in each model unit.  Additionally, the
cost effectiveness of controlling VOC emissions from each model unit is
provided in the table.  Cost effectiveness estimates for Regulatory
Alternative II are approximately $350 per Mg.

     Retrofit Process Drains and Junction Boxes.  The cost for retrofitting
an existing process unit with P-trap drains and controlled junction boxes
was also estimated.  The additional cost required to retrofit a P-trap drain
over installing a new P-trap drain is the cost of materials as well as labor
and equipment necessary to remove the existing drains.  Costs were based on
a three man crew using a backhoe with a pneumatic jackhammer to remove
concrete around the drain.  Using engineering judgement, it was estimated
that each drain would take one-half hour to excavate.  Table 8-5 presents
the costs for retrofitting water sealed drains in each model unit.  The cost
is $486 per drain.  The cost of retrofitting a junction box with a water
seal is considered minimal because no excavation is necessary.

     It is expected that most units which would be affected by the
modification/reconstruction provisions would be down for reasons other than
drain retrofitting.  Therefore, no cost due to production losses would
result from implementing the NSPS.

     8.1.1.2  Regulatory Alternative III - Closed Drain System.

     New Process Drains and Junction Boxes.  A completely closed drain
system similar to that installed at one refinery10 was used as the basis for
the cost evaluation.  The closed drain system uses sealed drains and an
underground collection tank.  The collection tank is purged with fuel gas to
reduce the risk of explosions.  The purge gas is then vented to an existing
control device, such as a flare.  The closed drain system has been
illustrated in Figure 3-8.

     The materials needed to install closed drains are given in Table 8-3.
As with P-trap drains, the difference in cost between installing a closed
drain and an uncontrolled drain is used for all cost calculations.  The
difference in TDI is approximately $210 per drain.
                                   8-5

-------
00
I
en
                           TABLE 8-4.  ANNUALIZED COST AND COST EFFECTIVENESS OF REGULATORY ALTERNATIVES
                                       FOR NEW PROCESS DRAIN AND JUNCTION BOX SYSTEM


Regulatory
Alternative

I


n


III



Model
Unit

A
B
C
A
R
C
Ac
B
CC


Drains

94
44
28
94
44
28
94
44
28
• "..-•' ••«•"" '


Junction Boxes

16
8
5
16
8
5
16
8
5
1 ~ \t~~ L ' ™----l—

Total
Depreciable
Investment
($1,000)
NO CONTROL


22.00
10.50
6.60
150.00
90.60
63.40



Annual Cost ($1000)
Di rect
Expense

COSTS


0.65
0.31
0.19
11.31
8.93
8.00
Indirect
Expense




1.11
0.53
0.34
11.70
8.60
7.40
Capital
Recovery




3.58
1.71
1.08
24.61
14.77
10.81
Total
Annual
Cost
($1,000)




5.34
2.54
1.61
47.62
32.30
26.16

Emission
Reduction
(Mg/yr)




15.4
7.3
4.6
30.2
14.3
9.1

Cost
Effectiveness
($/Mg)




350
350
350
1580
2260
2880
      a.  Keguiatory Alternative  i  -  N    -
          Regulatory Alternative  II - Require P-traps on all drains and seal pots on junction boxes.
          Regulatory Alternative  III  -  Require a sealed drain system vented to a control device.

      b.  Costs  are based  on  the  factors  and computational algorithms of Table 8.1 and 8.2.  All costs  are
          in  3rd quarter  1983 dollars.

      c.  The capital  cost of an  underground collection tank was calculated assuming 42 drains.  Costs  for
          other  size Grain systems  were estimated by the following gquation (Reference 9):
          Cost = (Cost of  tank for  a  42 drain system) # of drains
                                                           42
          Total  depreciable investment  for  piping equal for all systems.

-------
               TABLE 8-5.
                                                      ^^
     Regulatory
     Alternative3
            Model
            Unit
                        _  Tota1           Annual  Cost  ($1000)b
                        Depreciable^   Direct  Indirect   Capital
                        Investment     Exoense   Fxnpnco  Bar«,,,^,,
                                                     Total
                                                     Annual
                                                      Cost
                                                 Emission
                                                Reduction
                                                                     —  -,.„,, V.V-,,   vapitai     LOST.    Keauctlo
                                                                 Expense  Expense  Recovery   ($1,000)    (Mg/yr)
                                                   NO CONTROL COSTS
oo
I
         II
       III
             A
             B
             C
94
44
28

94
44
28
16
 8
 5

16
 8
 5
51,
24,
                                                       15.4
1.61
0.76
0.48
2.65
1.25
0.79
                                                      182,
                                                      105,
                                                          12.29     13.33
                                                       75.8
                                                           9.40
                                                           8.29
                    9.36
                    7.83
    a.  Regulatory Alternative  I  - No action
    b.
                                                                 5SB
Total  depreciable  investment for piping equaT^oTaYlTys terns.
                                                                                            .„
                                                   Cost
                                                 Effectiveness
                                                   ($/Mg)
8.39
3.96
2.51
29.76
17.18
12.35
12.65
5.97
3.78
55.38
35.94
28.47
15.4
7.3
4.6
30.2
14.3
9.1
820
820
820
1,830
2,510
3,130

-------
     The materials and methods used to estimate the cost of constructing the
underground collection tank and purge system are shown in Table 8-6.   The
tank was sized to handle wastewater from a process unit having 42 drains.
The annual cost for operating the underground tank and purge system includes
the electricity to operate the sump pump and fuel gas for the purge system.
The costs for these utility requirements are shown in Table 8-7.L  The cost
effectiveness for implementing Regulatory Alternative III for each model
unit is also shown in Table 8-4.  The cost effectiveness estimates range
from $1580 per Mg for Model Unit A to $2880 per Mg for Model Unit C.

     Retrofit Process Drains and Junction Boxes.  The cost for retrofitting
an existing process unit with a closed drain system was also estimated.  The
additional cost of retrofitting a closed drain system over installing a  new
drain  system is the labor and equipment needed to excavate the existing
uncontrolled drains and weld on the  necessary piping.  Additional materials
are  also  needed which add to the cost of a  closed drain system.   Costs were
based  on  a three  man  crew using a backhoe with a  pneumatic jackhammer to
remove concrete around  the drain.   Field welding  was  also  necessary to
attach the piping to  the existing drain.   It was  estimated  that  each drain
would  take one-half hour to  excavate and  7  manhours  to  prepare and weld  the
necessary piping.3  The cost would  be $546  per  drain.   The  cost  for
 installing an  underground  tank  is  the same  as  that  given  in  Table 8-b.
Utility requirements  for  the purge  system  are  shown  in  Table 8-7.

      It is expected  that most units which  would be  affected  by the
modification/reconstruction  provisions would be down for reasons other  than
 drain retrofitting.   Therefore, no costs  due to production losses would
 result from  implementing  the NSPS.

      Table 8-5 presents the costs of retrofitting closed drain system for
 each model unit.   Additionally, cost effectiveness estimates for
 imolementinq Regulatory Alternative III for each model  unit are given.   Cost
 effectives values range from $1830 per Mg for Model  Unit A to $3130 per
 Mg for Model Unit C.

 8.1.2  Oil-Water Separators

       Regulatory  Alternatives for oil-water separators have been  discussed in
 Section  6 2   Regulatory Alternative I requires  no additional control and
 therefore does not result in any costs.  The costs for implementing
 Regulatory Alternatives II  and III  are discussed below.

       The costs of covers for separators were provided by  industry and
 represent retrofit costs.   These costs may include  the cost  for  primary
 seals and are therefore conservative.  The costs for providing  a cover  on a
 newly installed  separator were derived from the  retrofit  costs.   For this
 reason,  retrofit costs are  presented first.
                                     8-8

-------
     TABLE 8-6.   BASIS FOR BURIED TANK SUBSYSTEM COST ESTIMATE
                 FOR REGULATORY ALTERNATIVE III
Direct capital cost based on vessel  estimate using methods  of
Richardson .

Vessel specifications:  7 feet, i.d., 10.75 feet tangent-to-tangent
length, ellipsoidal head, 5/16 inch  thick carbon steel,  welds spot
checked.  Vessel volume is approximately 400 ft  (3000 gal).   In
practice an externally coated steel  is likely to be used and  costs of
such coating are implicitly assumed  to be within the overall  estimate
contingency allowance.

Vessel buried in excavation 11 feet  deep by 14.75 feet long by 11 feet
wide.  Vessel rests directly on sand or gravel  within excavation, and
backfilled with original overburden.

Vessel contains two manways:  36" diameter and  24" diameter extending
to ground surface.  First manway is  welded to exterior wall of vessel
to provide access from above ground  to piping nozzles attached to
vessel wall.   Second manway penetrates wall of  vessel to provide access
to vessel interior.  Manways are covered with a bolt-on cover.

Two sump pumps each rated at 40 gpm, 25 psig discharge pressure, and
requiring 1 hp motors are used to pump vessel liquid to wastewater
treatment.  Motors are located on ground level  cover of 36" manway.
Piping and shafts extend through manway, and then through nozzles in
vessel wall.

Piping from plant fuel gas system to tank, installed.  Piping between
tank and facility flare system, installed.
                                                             4
Installation costs were estimated based on factors in Guthrie  for
horizontal process vessels and pumps.

Vessel capacity is directly proportional to the number of drains in the
system.  Therefore, the number of drains was used as the sizing factor.

Total Direct Capital Cost of Tank:  $44,298, Total Direct Capital Cost
of piping:  $2585
                               8-9

-------
                                          TABLE 8-7.  ANNUAL UTILITY COSTS FOR REGULATORY  ALTERNATIVES
CO
 i
Process Regulatory
Alternative
Process Drain System - New and III
Retrofit
Oil -Water Separator-New and III
Retrofit



CPI System HI




DAF System HI




IAF System HI




Model
Unit
Aa
Ra
?a
k
Bb
cb
Ac
Bc
CK
Ab
Bb
DL.
Cb
Ac
Bc
Cc
Ab
Bb
Cb
Ac
Bc
CK
Ab
Bb
Cb
Ac
Bc
Cc
Water
-
-
0.010
0.010
0.010
-
_
0.010
0.010
0.010
-
„
0.010
0.010
0.010
-
_
0.010
0.010
0.010
Utility
Steam
-
-
0.574
0.574
0.574
-
_
0.574
0.574
0.574
-
_
0.574
0.574
0.574
-
_
0.574
0.574
0.574
Cost ($1000)
Electricity
0.087
0.136
0.278
0.245
0.245
0.245
0.500
0.500
0.500
0.245
0.245
0.245
0.500
0.500
0.500
0.245
0.245
0.245
0.500
0.500
0.500
0.245
0.245
0.245
0.500
0.500
0.500
Fuel Gas
0.217
0.342
0.696
-
-
-
-
*
-
-
-
-
_
-
-
-
-
_
-
-
-
—
         aThe electrical  requirements are based on  a  pumping  rate of one-half  the pumps design capacity for 2 920 hours per year^ The fuel
          gas usage is based on a complete turn over  of  the collecton tank's vapor space every 24 hours, based on a tank sized for 42
          drains   The utility costs were also adjusted  for the  different  tank sizes using the following equation.
                             (
          Utility Cost =  U42
          Where:  U.- = Utility cost for a tank serving  42 drains
                    D = Number of drains in Model  Unit.
         bCaptured VOC emissions vented to an existing control  device.
         cCaptured VOC emissions vented to a dedicated device (carbon adsorber).

-------
     8>1:?'i ^Re9ulator.y  Alternative II - Covered Separators    Information
was provided by the refining  industry regaTdTnT^tf^r^feal
installations of fixed  and floating roofs on existing  oil-water separators

£ iIv??2%«J!n??d fr0m $11ift lt0 $45/ft2 f°r ««dyroofs and froT^/rt^
to $93/ft* for floating roofs. 12  The wide r     -      t   -  d   to
differences in material of construction, size of the roof, type of roof  and
problems encountered during installation.   To account  for alfof these
factors  an average cost  for  installing a fixed or  floating roof was
developed using all available information.  The average cost for ""tailing

  '  e     f °in                                                 *
                                          .                           a
  to   in  f °Min? r°°f °n an 6Xisting ^-"ater separator is $56/ft*    The
  total depreciable investment for Regulatory Alternative II was calculatPH hv

       n            C°S              r°°f  ^Ulred b* eac* "^  ™
 detailed cost breakdown of a retrofitted roof was prol  ded  by oeflner
 It was determined that 33 percent of the costs for retrofitting would not
 have been required for a roof on a newly installed separator   TMs fiSSr
 is supported by  standard engineering estimations  that consider retrofit
 construction to  be 25 to 40 percent higher than new construction^   App

                                                            ™
      Table  8-9 presents the costs for Regulatory Alternative II for new
 j  rjJs.nSr'rSu ^ erectiveness  esJim^tes f°* *•* «^° »  "
 mo ^"g'for M^efunltT  " ™"9e f™  $4° P6r "9 for Mode' "»" A
 <•„„, J!i'V'?  Re8"at°rv Alternative  III  - Covered

operating parameters also given l^tS'Sble^ '     i Ty   qu Sts" or
these systems and associated costs have been  shown  in Table sT
                                  8-11

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TABLE 8-8.  ANNUALIZED COST AND COST EFFECTIVENESS OF REGULATORY  ALTERNATIVES FOR
            A RETROFIT CONTROL SYSTEM ON AN API  OIL-WATER SEPARATOR
Regulatory
Alternative




a.
b.
c.
d.
I
II
III

Regulatory
Regulatory
Regulatory
Model
Unit
A
B
C
A
B
C
£
cc
d
?-
h Total
Total Annual Cost ($1000) Annual Emission
Depreciable Direct Indirect Capital Cost Reduction
Investment Expense Expense Recovery ($1,000) (Mg/yr)
($1,000)
Cost
Effectiveness
($/Mg)
NO CONTROL COST
64.
34.
34.
70.
40.
40.
134.
105.
105.
Alternative I -
Alternative II
Alternative III
Costs based on the factors
All costs are 3rd quarter
VOC emissi
VOC emissi
ons vented
ons vented
to an
to a
50
90
90
50
50
50
70
10
10
2.01
1.09
1.09
10.87
9.95
9.95
13.94
12.92
12.92
3.31
1.80
1.80
9.52
8.01
8.01
12.81
11.31
11.31
10.
5.
5.
11.
6.
6.
21.
17.
17.
51
70
70
49
78
78
96
15
15
No action
- Require all oil -water separators to
floating roof.
- As alternative II plus a vapor col
and
1983
exi
computational
dollars.
sting control
dedicated control
algorithms of
device
device
•
15.83
8.59
8.59
31.88
24.74
24.74
48.56
41.38
41.38
be covered
lection and
281.3
140.8
9.3
321.1
160.6
10.7
311.4
155.7
10.3
with a
control
60
60
920
100
150
2,310
160
270
4020
fixed or
system
Table 8-1 and Table 8-2.




(carbon adsorber system).

-------
                      TABLE 8-9.
                           ANNUALIZED COST AND COST EFFECTIVENESS OF REGULATORY
                           ALTERNATIVES FOR NEW API OIL-WATER SEPARATORS
O3
— — 	 — 	 _
Regulatory Model
Alternative3 Unit
	 — 	
I

II
III


A
B
C
A
B
C
Ac
Bc
Cc
d
BH
Cd
Total Annual Cost ($1000)b Annual
Depreciablg Direct Indirect Capital Cost
Investment Expense Expense Recovery ($1,000)
($1 ,000)
Emission
Reduction
(Mg/yr)
Cost
Effectiveness
($/Mg)
NO CONTROL COSTS

42.6
23.1
23.1
48.6
29.1
29.1

112.8
93.3
93.3

1.32
0.72
0.72
10.19
9.58
9.58

13.16
12.55
12.55

2.20
1.19
1.19
8.41
7.40
7.40

11.71
10.70
10.70

6.94
3.76
3.76
7.92
4.74
4.74

18.39
15.21
15.21

10.47
5.67
5.67
26.52
21.72
21.72

43.26
38.46
38.46

281.3
140.8
9.3
321.1
160.6
10.7

311.4
155.7
10.3

40
40
610
80
140
2,030

140
250
3,730
   a.
   b.
Regulatory Alternative I - No action
   c.   VOC  emissions  vented  to  an existing control device.

   d.   VOC  emissions  vented  to  a dedicated control device (carbon adsorber system).

-------
     TABLE 8-10.  COST BREAKDOWN OF MAJOR EQUIPMENT FOR VOC CONTROL FOR
                  OIL-WATER SEPARATORS AND AIR FLOTATION SYSTEMS
                                             Unit Cost ($/ft2)b
Oil-Water Separators

1.  Cover - New  (Fixed or Floating)                  37
2.  Cover - Retrofit (Fixed or Floating)             56

Dissolved Air Flotation Systems

1.  Roof - Fiberglass fixed                          20
Induced Air Flotation Systems                Unit Cost ($)

1.  Pressure/Vacuum Valve                           290
2.  Latches                                         100


Fittings for Vapor Collection System
(Oil-Water Separators and Air Flotation)     Total Installed Costa'b
1.
2.
3.
4.
5.
Carbon Steel pipe (200'x 2" 40 std)
Tees (4) (2" carbon steel 40 std)
Flame arrester (2" aluminum)
Flanges (2" carbon steel)
Blower and Motor (3/4 Hp)
725
278
370
62
2130
^Reference 3.
 3rd quarter 1983 dollars.
                                   8-14

-------
      TABLE 8-U-   OPERATING PARAMETERS AND COSTS OF CARBON ADSORBER3



 1.    Operating Parameters

   a)  VOC  concentration = 880 mg/L
   b   Operating capacity = 7 lb/1000 Ib carbon
   c   VOC  content = 0.25 Ib VOC/1000 scf
   d   Carbon requirement = 0.5 Ib carbon/1000 scf
   e   Flow rate of gas = 300 scfm
   f j  Temperature = 100°F
   g)  Gas velocity = 100 fpm
   h)  Bed depth = 3 ft.

   Ji  BPeTaSrer,e "Tf?6-5 1n-  H2°/ft' °f «rb™
   k)  Carbon = 270 Ibs
   1)  Steam = 0.3 Ibs/lb carbon  (93% efficiency)
             = 23652 Ibs/yr

2.    Costs

   a)   Total  Depreciable  Investment             $70 213 00
   b)   Annual  Cost                              wu^u.uu
         carbon replacement                     $
         steam                                  I   K
         electricity                            J   573.56
         cooling water                          $
         labor (0.5 mhr/shift)
Reference 5.
                                  8-15

-------
     The costs for implementing Regulatory Alternative III  for oil-water
separators are presented in Tables 8-8 and 8-9.   Table 8-8  presents the
costs for separators retrofitted with covers.   Table 8-9 presents costs for
covers installed on new separators.

8.1.3  Air Flotation Systems

     Three regulatory alternatives for air flotation systems have been
discussed in Section 6.2.  Regulatory Alternative I requires no additional
control and therefore results in no costs.  Regulatory Alternative II for
DAF  systems requires the flotation chamber to be covered with a fixed roof.
For  IAF systems, this alternative requires the system to be operated
gas-tight.  Regulatory Alternative III requires the flotation chamber of
both types of systems to be tightly covered with captured VOC vented to a
control device.

      For  purposes  of the cost analysis, DAF and IAF systems are  considered
separately.   IAF  system are constructed with roofs and,  therefore, do  not
incur the cost  for adding  a roof.  DAF systems have open flotation tanks  and
must have a roof  installed.  For  this reason, control  costs for  DAF  systems
are  higher than IAF systems.

      The  major  equipment costs  for controlling VOC  from air flotation
systems are  listed in  Table 8-10.  The cost for a  fiberglass  roof was
acquired  from information  provided by industry and  equipment  vendors.13,
The  TDI for  installing a roof  on  a DAF system  is  $20/ft2.   This  cost can  be
applied to both new and retrofitted  units due  to  the  minimal  modifications
which would  be  required for a  retrofitted roof.

      IAF systems can be made  gas tight by gasketing the access doors which
 serve to cover the system.  For Regulatory Alternative II,  costs are added
 for the pressure/vacuum valve, latches,  and gasketing.  Additional  costs  for
 the piping and blower are  included for Regulatory Alternative III.

      Two situations have been considered in estimating costs  for Regulatory
 Alternative III.  As with  oil-water separators,  it is expected that an
 existing control device may be accessible to the air flotation system.
 However, some cases may exist where a dedicated control device is needed.
 Therefore, costs have been calculated for both situations.  Again, the
 dedicated control device  is assumed to be a carbon adsorber.

      Tables of 8-12 and 8-13 present the annual  costs and cost effectiveness
 estimates for  DAF  and  IAF systems, respectively.  Costs for utility
 requirements for  the control system  are  shown in Table  8-7.

 8.1.4  Incremental Cost Effectiveness

       The incremental  cost effectiveness  between Regulatory Alternative II
 and III  was  calculated for new and  retrofit process  drain systems,  new and
 retrofit oil-water separators  and both types of air  flotation system.    The
 results  of these  calculations  are presented in Table 8-14.


                                      8-16

-------
CO
I
               TABLE  8-12.  ANNUALIZED COST AND COST EFFECTIVENESS  OF  REGULATORY ALTERNATIVES FOR DAF SYSTEMS
       Regulatory
       Alternative3
     a.
     b.
           II
          III
Model
Unit
— ' • •' i-
A
B
C
A
B
C
Ac
Cc
d
BH
Cd
..in.
Total
Depreciable
Investment
($1,000)
Annual Cost ($1000)
Direct Indirect Capital
Expense Expense Recovery
Total
Annual Emission
Cost Reduction
($1,000) (Mg/yr)
— -•••-—• — -
Cost
Effectiveness
($/Mg)
NO CONTROL COSTS

15.0
7.5
0.5
21.1
13.5
6.5
85.3
77.8
70.7

0.47
0.24
0.02
9.43
9.20
8.98
12.30
12.07
11.85

0.77
0.39
0.03
6.98
6.60
6.24
10.29
9.90
9.54

2.44
1.22
0.08
3.45
2.21
1.06
13.89
12.67
11.52

3.69
1.85
0.12
19.86
18.01
16.28
36.48
34.64
32.91

9.2
4.6
0.3
11.6
5.8
0.39
11.3
5.6
0.38

400
400
400
1,710
3,110
41,740
3,230
6,190
86,600
Regulatory Alternative I - No action
Regulatory Alternative I! - Requires  a  fixed  cover

R                      '" - ReqU'>eS a "**"
                                                                vapor Election and control syste. on ,„
Alfcons
                                                         '1*>r1tl"$ °f
                                                                                           8-2.
     c.  VOC emissions vented to  an  existing control device

     d.  VOC emissions vented to  a dedicated control devices (carbon adsorber system).

-------
oo
CO
                  TABLE 8-13.  ANNUALIZED COST AND COST EFFECTIVENESS OF REGULATORY ALTERNATIVES FOR  IAF  SYSTEMS8
Total
Regulatory , Model Depreciablj
^^^^_^?fS)
I A
B NO
C
II A
B
C
III A^j
Cd
ce
a. Cost for vapor control
b. Regulatory Alternative
CONTROL

0.4
0.4
0.4
6.0
6.0
6.0
70.2
70.2
70.2
device
I - No
- — 	 	 lotal
Annual Cost ($1000)° Annual Emission
> Direct Indirect Capital Cost Auction
: Expense Expense Recovery ($1,000) (Mg/yr)


0.01
0.01
0.01
8.96
8.96
8.96
11.83
11.83
11.83
only, system
action


0.02
0.02
0.02
6.21
6.21
6.21
9.51
9.51
9.51
assumed



0.06
0.06
0.06
0.98
0.98
0.98
11.44
11.44
11.44
to be covered



0.10
0.10
0.10
16.15
16.15
16.15
32.78
32.78
32.78
— 	 „..! ••.•




0.55
0.27
0.02
1.96
0.98
0.06
1.66
0.83
0.05


Cost
Effectiveness
(S/Mg)


180
370
5,560
8,240
16,480
269,170
19,750
39,350
655,600
	


            d.
            e,
Rpmilatnrv    ernave    -
Regulatory Alternative III - Vapor collection and control  system
Costs are based on the factors and computational algorithms of Table 8-1 and 8-2.
All costs are 3rd quarter 1983 dollars.
VOC emissions vented to an existing control device.
VOC emissions vented to a dedicated control device (carbon adsorber system).

-------
                                       TABLE 8-14.
               Process
          Drain System - New
          Drain  System - Retrofit
          Oil-Water Separator  - New
                                            INCREMENTAL COST EFFECTIVENESS OF REGULATORY ALTERNATIVES
Model
Unit
                               A
                               B
                               C

                               A
                               B
                               C
                                      Ab
oo
 i
         Oil-Water  Separator-Retrofit  Aa
         Dissolved Air Flotation
                                     Ab
                                     Rb
                                     C"
        Induced Air Flotation
                                              	—	—_
                                           Regulatory Alternative II
                                         Annual Cost   Emission Reduction
                                          ($1,000)          (Hg/yr)
  5.34
  2.54
  1.61

 12.65
  5.97
  3.78

 10.47
  5.67
  5.67

 10.47
  5.67
  5.67

15.83
 8.59
 8.59

15.83
 8.59
 8.59

 3.7
 1.8
 0.1
                                         3.7
                                         1.8
                                         0
                                                0.1

                                                0.1
                                                0.1
                                                0.1
                              15.4
                               7.3
                               4.6

                              15.4
                               7.3
                               4.6

                            281.3
                            140.8
                              9.3

                            281.3
                            140.8
                              9.3

                            281.3
                            140.8
                              9.3

                            281.3
                            140.8
                              9.3

                              9.2
                              4.6
                              0.3

                             9.2
                             4.6
                             0.3

                             0.55
                             0.27
                             0.01

                             0.55
                            0.27
                            0.01
^SSrT SS!»: ^STP*^^          <«:
    (carbon adsorblr)        '  °V6r; Re9"latory Alternative III:
                                     Regulatory Alternative III
                                   Annual Cost  Emission Reduction
                                     ($1,000)       (Mg/yr)
 47.62
 32.30
 26.21

 55.38
 35.94
 28.47

 26.52
 21.72
 21.72

 43.26
 38.46
 38.46

 31.88
 24.74
 24.74

 48.56
 41.38
 41.38

 19.9
18.0
16.3
                                    36,
                                    34.
                                                                            32.9

                                                                            16.2
                                                                            16.2
                                                                            16.2

                                                                            32.8
                                                                            32.8
                                                                            32.8
  30.2
  14.3
   9.1

  30.2
  14.3
   9.1

 321.1
 160.6
  10.7

 311.4
 155.7
  10.3

321.1
160.6
 10.7

311.4
155.7
 10.3

 11.6
  5.8
  0.4

 11.3
  5.6
 0.4
                                                     96
                                                     98
                                                   0.06

                                                   1.66
                                                   0.83
                                                   0.06
                                                                                                                    Incremental
                                                                                                                    Cost ($/Mg)
    2,860
    4,250
    5,470

    2,890
    4,280
    5,490

     400
     810
   11,460

    1,090
    2,200
  32,790

     400
     810
  11,460

   1,090
   2,200
  32,790

   6,750
  13,500
 162,000

  15,620
  32,800
328,000

  11,420
  22,680
322,000

 29,460
 58,390
654,000
                                                                               unp CT'.iss;p"s vented to an existing control device
                                                                               VOC missions vented to a dedicated control devicl'

-------
8.2  OTHER COST CONSIDERATIONS

     Environmental, safety, and health statutes that may cause an
expenditure of funds by the petroleum refining industry are listed in
Table 8-15.  Specific costs to the industry to comply with the provisions,
requirements, and regulations of the statutes are unavailable.  However,
some references are listed which provide cost estimates for complying with
specific regulations.15,16,17

     Few refineries are expected to close solely due to the cost of
compliance with the total regulatory burden.  The costs incurred by the
petroleum refining industry to comply with all health, safety, and
environmental regulations are not expected to prevent compliance with the
proposed NSPS for refinery wastewater systems.
                                     8-20

-------
                                                    B-IS.   MAIU.tS  THAT  MAY  BE  APPLICABLE  TO THE PETROLEUM REFINING INDUSTRY
                       Statute
             Clean Air Act and Amendements
            Clean Water Act (Federal
             Water Pollution Act)
CO
 i
N5
           Resource Conservation and
            Recovery Act
          Toxic Substances Control Act
Applicable provision, regulation or
      requirement of statute


• State Implementation plans

t National  emission  standards  for
    hazardous  air pollutants
     Benzene fugitive emissions
                                                 t New source performance standards
                                                      Air oxidation
      Volatile organic liquid storage


  • PSD construction permits

  • Non-attainment  construction  permits

  • Discharge  permits

  • Effluent limitations guidelines

  • New source performance standards

  • Control of all  spills and discharges


  t Precreatment requirements

  • Monitoring and reporting

  • Permitting  of Industrial  projects
     that impinge on wetlands or
     public waters

 • Environmental  impact statements

 • Permits for treatment,  storage, and
     disposal  of  hazardous wastes

 t Establishes system  to track
     hazardous wastes

 • Establishes recordkeeping,
     reporting, labeling and
     monitoring system for
     hazardous wastes

 • Superfund

•  Premanufacture notification
• Labeling, recordkeeping
• Reporting requirements
• Toxicity testing
                                                                                                Statute
                                                                                             Occupational Safety &
                                                                                              Health Act
 Coastal Zone Management
  Act
National Environmental
 Policy Act

Safe Drinking Water Act


Marine Sancutuary Act
                                                                        Applicable  provision,  regulation,  or
                                                                              requirement  of  statute
                             • Walking-working surface standards

                             • Means of agress standards

                             • Occupational  health and environ-
                                 mental  control  standards

                             • Hazardous material  standards
                             • Personal  protective equipment
                                 standards

                             • General environmental  control
                                 standards

                             • Medical and first aid  standards

                             •  Fire protection standards

                            •  Compressed gas and compressed
                                air equipment
                            • Welding, brazing, and cutting
                                standards
                                                                      • States may vote federal  permits
                                                                          for plants to be sited in
                                                                          coastal  zone
                                                                                                                       • Requires environmental  impact
                                                                                                                           statements

                                                                                                                       t Requires underground injection
                                                                                                                           control  permits

                                                                                                                       • Ocean  dumping  permits
                                                                                                                       • Recordkeeping  and reporting

-------
    REFERENCES
    Uhl   V  W   A Standard  Procedure  for  Cost Analysis of Pollution Control
    Operations.   Volume 1:   User  Guide.   Research Triangle Park, North
    Carolina.   Publication No.  EPA 600/8-79-018a.
2   Uhl, V.W.   A Standard Procedure for Cost Analysis  of
    Operations.  Volume II:   Appendices.   Research  Triangle  Park,  North
    Carolina.   Publication No.  EPA 600/8-79-018b.

•}   Richardson Engineering Services, Inc.   The Richardson Rapid
    Construction Cost Estimating System.  1982-1983 edition.  Richardson
    Engineering Services, Inc., San Marcos, Ca.

4.  Guthrie, K.M.  Process Plant Estimating Evaluation and Control .
    Craftsman  Book Company of America, Sol ana Beach, La., iy/4.

 5   U S  Environmental Protection Agency.  Organic Chemical Manufacturing
    Volume 5:  Absorption, Condensation, and Absorption Devices   Report 1.
    U.S. Environmental Protection Agency, Research Triangle Park, North
    Carolina.  Publication No.  EPA  450/3-80-027.  December  1980.

 6.  U.S. Bureau  of Labor Statistics.   National Employment,  Hours  and
    Earnings,  Average  Hourly Earnings  of  Production Workers:   Petroleum
    Refining.  Dialog  Data Base File #178.   March  1983.

 7   Energy Information Administration.  Monthly  Energy Review.  Washington
     D.C.  DOE/EIA-0035(83/09).   September 1983.

 8.   C.E.  Plant Cost  Index.   Chemical  Engineering.   90(20) :7.
     October 3, 1983.

 9.   Perry, R. H. and C.  H.  Chilton.  Chemical Engineers'  Handbook   Fifth
     edition.   New York,  McGraw-Hill Book Company.   1973.  p.  
-------
16.
    rochat
    rotecn.  Salt

Ca??fornia'°   t0
      -
Lake City,
                                       n          W1'th J1m
                                       December 8, 1983.  Conversation
                                                      E1 Segund"   °
 14.
15.

17.
                               8-23

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                         9.  ECONOMIC IMPACT
  9.1   INDUSTRY CHARACTERIZATION

  9.1.1  General Profile
      9.1.1.1  Refinery Capacity.  On January 1, 1984, there were 220
 petroleum refineries operating in the United States with a total crude
 capacity of 2,653,000 m3 per stream day.1  With respect to location
 refining capacity is fairly well -concentrated,  with 57 percent of  '
 /SSS?  o ^de throughput caPacity located in three states:   Texas
 (28%), California (15%), and Louisiana (14%).

      Although refining capacity grew steadily through the  1970s   a
 similar trend in capacity growth  has not  continued  into the  1980s   as
 be ?LpH fn   H^'H The decr?ase 1n the  ™te of  capacity  expansion  can
 be traced to reduced consumption  resulting  from rising  prices, the
 slowdown of  economic growth,  the  availability of  substitutes  in  some
 ?nS  nHnl?n-'ia!  *h
-------
     TABLE  9-1.   TOTAL  AND  AVERAGE  CRUDE  DISTILLATION CAPACITY BY YEAR
                    UNITED  STATES REFINERIES,  1973-19833
	
Year
(January 1)
1974
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984

Number of
Refineries
247
259
256
266
285
289
297
303
273
225
220
• • • ••• .. ,— 	
Total Capacity
(m3/sd)b>c
2,365,000
2,459,000
2,494,000
2,689,000
2,801,000
2,870,000
2,975,000
3,080,000
2,957,000
2,704,000
2,653,000
Average Refinery
Capacity
(m-Vsd)0
9,600
9,500
9,700
10,100
9,800
9,900
10,000
10,200
10,800
12,000
12,000
References 1 and  3 through  12.
t>Note:  Capacity in stream days.
cl m3 = 6.29 barrels.
                                      9-2

-------
  ,.    9-1-1-2  Refinery Production.   In terms of total national  output,
  the percentage yields of most refined petroleum products have  remained
  constant over recent years, although several exceptions are noted
  below.  The percentage yields of  refined petroleum products from crude
  ?Vi  n , ?-years 1974 throu9h 1981 are summarized in Table 9-2, while
  Table 9-3 lists the average daily output of the major products.

       The diversity of refinery product output  varies with refinery
  capacity. Large integrated refineries operate  a wide variety of process-
   ? T-tS4 ^hus enabl1r)9 the production of many or all  of the products
  noted in Table 9-2. Other refineries are relatively small,  have only a
  few processing units, and produce selected products such as  distillate
  oil ana asphalt.

  fl ,   9-1-1*3   Refinery Ownership. Vertical  Integration  and Diversification
  A large portion or domestic  refining capacity  is owned  and operated by	
        vertically integrated oil companies,  both domestic and interna-
            " T!1!!31"  r 18  c?ntr°lled by  independent refiners such as
                                                      State,
 nr^J3ble !"4 M18*5 twenty comPanies with the greatest capacity to
 process crude oil.  Based upon the capacities noted,  and a total
 domestic capacity of 2,704,000 m3 per stream day,  the 4- and "firm
 concentration ratios are 27 and 47 percent, respectively.  These ratios
        63 Pelatively h1gh de*™ of ^ership concentration of re??nery
 of tha »»•  y ??nershlP.ls Dut one  aspect of the vertical  integration
 in JK*. K01" °   comPanies.  Such companies are integrated "backward"
 in that they own or  lease crude oil production facilities, both domestic
 and international, as well as the means to transport crude by way of
 pipeline and tankers.  On the international  level, access  to Saudi-
 Arabian crude is maintained through Aramco which is owned  by four
 and^bi]     comPan1es:   Exxon, Standard Oil of California, Texaco,


                                 by pipeline, the major  oil companies
                                 1 for the
 rssr^ri^rj^j: x ^thr»r;i^sirpsy1
 ad independent operators  «ho charter tankers I oil  cLpanies an5
 of th» ;.i,J  ,p rese??e of '"dependent tanker operators is a resu
                                    ^-^^"
rfir .J"?11^ ma[!y °f^he  low-volur"e refinery products are marketed
directly by the refiners themselves, the sale of gasoline on the  retail
nnprltn5 ^"tl** ^mar^ b* franchised dealers and independent
operators.  The major refiners do,  however, have a high degree  of
control over the distribution of their products  with regard to  market
                               9-3

-------
      TABLE  9-2.   PERCENT  VOLUME  YIELDS  OF  PETROLEUM  PRODUCTS  BY  YEAR
                     UNITED STATES REFINERIES,  1974-19813
                                (Percent)
	 Product 	
Motor Gasoline
Jet Fuel
Ethane
Liquefied Gases
Kerosene
Distillate Fuel Oil
Residual Fuel Oil
Petrochem. Feedstocks
Special Naphthas
Lubricants
Wax
Coke
Asphalt
Road Oil
Still Gas
Miscellaneous
Processing Gain*3
Total c
1974
45.
6.
0.
2.
9
8
1
6
1.3
21.8
8.7
3.0
0.8
1.6
0
2
3
0
3
0
3
103
.2
.8
.7
.2
.9
.5
.9
.9
1975
46.5
7.0
0.1
2.4
1.2
21.3
9.9
2.7
0.6
1.2
0.1
2.8
3.2
0.1
3.9
0.7
3.7
103.7
1976
45.5
6.8
0.1
2.4
1.1
21.8
10.3
3.3
0.7
1.3
0.1
2.6
2.8
0.0
3.7
1.0
3.5
103.5
1977
43.4
6.6
0.1
2.3
1.2
22.4
12.0
3.6
0.6
1.2
0.1
2.5
2.9
0.1
3.6
1.0
3.6
103.6
1978
44.
6.
0.
2.
1.
22.
12.
3.
1
6
1
3
2
4
0
6
0.6
1.2
0.1
2.5
2.9
0
3
1
3
103
.1
.6
.0
.6
.6
1979
43.0
6.9
0.1
2.3
1.3
21.5
11.5
4.7
0.6
1.3
0.1
2.6
3.1
—
3.8
0.8
3.6
103.6
1980
44.
7.
-
2.
1.
19.
5
4
-
4
0
7
11.7
5.1
0.7
1.3
0.1
2.7
2
0
4
0
4
104
.9
.1
.0
.8
.4
.4
1981
44.8
7.6
0.1
2.4
0.9
20.5
10.4
4.7
0.6
1.3
0.1
3.1
2.7
— -
4.3
0.7
4.2
104.2
aReference 13.  Section VIII, Tables 4-4a.
bProcessing Gain = Product Yield - Process Feed (Input)
cTotals exceed 100 percent because product yields are greater than process
 feeds by an amount equal to the processing gain.  In the catalytic reforming
 process, for example, straight-chain hydrocarbons are converted to branched
 configurations with hydrogen as a by-product, resulting in an overall net
 increase in volume.
                                      9-4

-------
          TABLE 9-3.   PRODUCTION OF  PETROLEUM PRODUCTS  BY  YEAR
                    UNITED STATES REFINERIES, 1972-1981*»b
                               (1,000 m3/cd)c
Year
1972
1973
1974
1975
1976
1977
1978
1979
1980
1981
Motor
Gasoline
1,000
1,039
1,011
1,037
1,088
1,118
1,140
1,132
1,083
1,019
Distillate
Fuel Oil
419
449
424
422
465
521
501
503
440
416
Residual
Fuel Oil
127
154
170
197
219
279
266
270
262
209
Jet Fuel
135
137
133
138
146
155
155
161
159
154
Kerosene
35
35
25
24
24
27
24
29
22
19
NGL and LRGd
57
60
54
49
54
56
N.A.
54
N.A.
N.A.
aReference 13.  Section VII.  Tables 5, 6, 6a, 7, 7a, 14, 15, 16, 16a,
 17, and 17a.
bTotal  and product output reports may vary slightly by data source.
cl m3 = 6.29 barrels.
dNGL = Natural Gas Liquids; LRG = Liquefied Refinery Gases.
                                     9-5

-------
TABLE 9-4.  NUMBER AND CAPACITY  OF  REFINERIES  OWNED AND OPERATED
                      BY MAJOR COMPANIES
                UNITED STATES REFINERIES,  1983
                                              a,b
Company
._'•-* • • • • -
Chevron
Exxon
Shell
Amoco
Texaco
Gulf
Mobil
ARCO
Marathon
Union Oil
Sohio/BP
Conoco
Ashland
Sun
Cities Service
Phillips
Champlin
Getty
Tosco
Koch 	 	
Number of
Refineries
12
5
7
7
9
5
6
5
4
4
3
5
5
3
1
3
3
3
3
2
Crude Capacity
(1,000 m3/cd)
212
191
176
161
149
140
135
113
93
78
72
61
59
57
51
47
46
45
41
38
  Reference  14.
  bRecent mergers  have  combined Chevron with Gulf, and
   Texaco with  Getty.
                                 9-6

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area.  This is so because the major refiners select sites for the
construction of service stations before the facilities are leased to
independent operators under franchise agreements.  The major refiners
do maintain the direct operation of some service stations for purpose
of measuring the strength of the retail market.  However, no more
than 5 percent of all facilities in operation are managed in this
fashion. 16

     Many of the firms that operate refineries, notably the larger oil
companies, are diversified as well  as vertically integrated.  Several
refiners are vertically integrated through the manufacture of petrochem-
icals and resins.  Among the firms that have interests in these areas
are Getty Oil, Occidental Petroleum, and Phillips Petroleum.  Ashland
Oil's construction division operates the nation's largest highway
paving company.

     Several instances of diversification can be observed.  Exxon
Enterprises develops and manufactures various high-technology products.
The Kerr-McGee Corporation is the largest supplier of commercial grade
uranium for electricity generation and also manufactures agricultural
and industrial chemicals.  Mobil Oil Corp. is owned by Mobil Corp.
which owns both Montgomery Ward and Co. and The Container Corporation
of America.  The Charter Co., the largest of the independent refiners,
is also engaged in broadcasting, insurance, publishing, and commercial
printing.

     9.1.1.4  Refinery Employment and Wages.  Total employment at
domestic petroleum refineries has grown steadily since the mid-1960s,
with minor disruptions during periods of economic contractions.  As
Table 9-5 demonstrates, there were 170 thousand workers employed at
refineries in 1981. l7 With 303 refineries operating that year,11
average employment at each refinery is approximately 560 persons.

     The average hourly earnings of petroleum refinery workers have
consistently exceeded average wage rates for both the mining and
manufacturing industries.18  Petroleum refinery hourly earnings have
also exceeded those  for other sectors of the oil industry as noted in
Table 9-6.

9.1.2  Refining Processes

     Refineries process crude oil through a series of physical and
chemical processes into many individual products.  The four major
product areas are as follows:

     t    Transportation fuels — motor gasoline, aviation fuel;

     •    Residential/commercial fuels — middle distillates;

     •    Industrial/utility fuels — residual fuel oils; and

     •    Other products -- liquified gases and chemical process feeds.
                                 9-7

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     TABLE 9-5.  EMPLOYMENT IN PETROLEUM AND NATURAL GAS EXTRACTION
                    AND PETROLEUM REFINING BY YEAR
                        UNITED STATES, 1972-19819
                              (1,000 Workers)
Year
1972
1973
1974
1975
1976
1977
1978
1979
1980
1981
Petroleum and
Natural Gas Extraction
268.2
277.7
304.5
335.7
360.3
404.5
417.1
476.3
547.4
657.2
Petroleum
Refining
152.3
149.9
155.4
154.2
157.1
160.3
163.0
168.5
154.2
169.6
aReference 13.  Section V.   Table 2.
                                       9-8

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      TABLE 9-6.  AVERAGE HOURLY EARNINGS OF SELECTED INDUSTRIES BY YEAR
                          UNITED STATES, 1972-19813
                                  ($/Hour)b
Year
1972
1973
1974
1975
1976
1977
1978
1979
1980
1981
"H - i - .- — .
Petroleum
Refining
5.25
5.54
5.96
6.90
7.75
8.44
9.32
10.08
10.94
12.17
— — •— .... - , , ,. . — 	
Petroleum and
Natural Gas Extraction
4.00
4.29
4.82
5.34
5.76
6.23
7.01
7.73
8.55
9.49
Total
Manufacturing
3.81
4.08
4.41
4.81
5.19
5.63
6.17
6.69
7.27
7.98
Total
Mi ni nn
4.41
4.73
5.21
5.90
6.42
6.88
7.67
8.48
9.18
10.06
Reference 13.  Section V.
bCurrent dollars.
Table 2.
                                   9-9

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As noted in Table 9-2,  motor gasoline is  by  far  the  largest  volume
SJoduct of U S. refineries.  Motor gasoline  is produced  through b ending
?e products of various refinery units such  as those described below.
Estimated 1981 gasoline pool composition  is  presented in Table 9-7.

     9121  Crude Distillation.  The initial step  in refining crude
 oil  still  provides  feedstock  for downstream processing and some final
 products.21
      9122  Thermal  Operations.   Thermal cracking operations  include
      ar cokin  as ^11  as  vi sbreaki n9 .   In each  of these  operations,

while gas, gasoline, and heavier fractions are recycled.

     Coking is a severe form of thermal  cracking in »*Jch.th* ^J"5
held at a high cracking temperature long enough for coke to form and
settle out.  The cracked products are separated and drawn off and
heavier materials are recycled to the coking operations.2"

       123  Catalytic Cracking.  Catalytic cracking is used to
      se  the yield  and quality of gasoline blending stocks and produce
       9
  increase
  selectively fractured  into smaller  olefinic molecules.   The  use  of  a
  rltalvst permits  operations at  lower temperatures  and  pressures  than
  thoseyreqPufSn thermal  cracking.  In  the fluidized  catalytic  crack-
  Iro processes  a  finely-powdered catalyst is  handled  as  a fluid  as
  opposed to the beaded  Jr pelleted catalysts employed  in  fixed and
  moving bed processes.20
       9.1.2.4  Reforming.  Reforming is a molecular rearrangement
  proces^ to convert low-octane feedstocks to high octane  gasoline
  blending stocks or to produce aromatics for petrochemical uses
  Hydrogen is a significant co-product of reforming, and is in turn,  the
  major  source of hydrogen  for processes such as hydrotreating and
  i some rizat ion.

        q 1 2 5  Isomerizaton.  Isomerization, like  reforming,  is  a
  molecular  rearrangement process  used to obtain higher octane blending
  stocks   In  this  process, light  gasoline materials (primarily butane,
  pentane,  and  he  aSe), are converted to  their  higher octane  isomers.
                                    9-10

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 TABLE 9-7.   ESTIMATED  GASOLINE  POOL COMPOSITION BY REFINERY STREAM
                   UNITED STATES REFINERIES, 19813
Stream
Re formate
FCC Gasoline
AT kyl ate
Raffinate
Butanes
Coker Gasoline
Natural Gasoline
Light Hydrocrackate
I some rate
Straight Run Naphtha
Total
Amount
(m3/cd)
355,000
408,000
162,000
17,000
75,000
15,000
30,000
22,000
16,000
86,000
1,186,000
% of
Total
29.9
34.4
13.7
1.4
6.3
1.3
2.5
1.9
1.3
7.3
100.0
Reference 19.
                               9-11

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     9.1.2.6  Alkylation.   Alkylation  involves  the  reaction  of  an
isoparaffin (usually isobutane)  and an olefin  (propylene  or  butylenes)
in the presence of a catalyst to produce a high octane  alkylate,  an
important gasoline blending stock.20'22

     9.1.2.7  Hydrotreating.  Hydrotreating is  used to  saturate olefins
and improve hydrocarbon streams by removing unwanted materials  such as
nitrogen, sulfur, and metals.  The process uses a selected catalyst in
a hydrogen environment.20  Hydrofining and hydrodesulfunzation are
two subprocesses used primarily for the removal of sulfur from  feed-
stock and finished products.  Sulfur removal is typically referred to
as "sweetening."

      9.1.2.8  Lubes.  In addition to or in place of drying and sweeten-
ing of'hydrotreating units,  petroleum fractions, in the lubricating oil
range are further processed  through solvent, acid, or clay treatment in
the production of motor oils  and other  lubricants.  These subprocesses
can be  used to finish waxes  and for other  functions. 20

      9.1.2.9   Hydrogen Manufacture.   The manufacture of  hydrogen has
become  increasingly  necessary to maintain  growing  hydrotreating opera-
tions.   Natural  gas  and by-products from  reforming  and other processes
may  serve  as  charge  stocks.   The gases  are purified of sulfur  (a
catalyst poison)  and processed  to  yield moderate to high purity hydro-
gen.   A small  amount of hydrocarbon impurity is  usually  not detrimental
to processes  where  hydrogen will be used.

      9.1.2.10  Solvent  Extraction. Solvent extraction processes
 separate petroleum  fractions or remove impurities  through the  use  of
 differential  solubilities  in particular solvents.   Desalting is  an   2j
 example whereby water  is  used to  wash water soluble salts from crude.
 Several complex refining  processes employ solvent  extraction during the
 production of benzene-related compounds.

      9.1.2.11  Asphalt.  Asphalt is a residual product of crude dis-
 tillation. It is also generated from  deasphalting and  solvent  decarbon-
 izing — two specialized steps that increase the quantity of cracking
 feedstock.21

 9.1.3  Market Factors

      9.1.3.1  Demand Determinants.  Most  projections of  refined product
 demand conclude that in terms of total refinery output,  existing
 capacity is capable of satisfying demand  over the foreseeable future.  '
 However, expansions and modifications  will be undertaken at existing
 refineries in order to allow the  processing of greater  proportions of
 high-sulfur crudes, and to  permit the  production  of increasing levels
 of high-octane  unleaded gasoline.  It  is  also possible  that shifts  in
 demand on  the  regional level may  allow the construction of a  few  new
  small  refineries,  and several  of  these projects are currently known to
  be  planned or  under construction.
                                   9-12

-------
 ma,-«     J*        S°E estimates of daily demand levels for the four
 major  refinery products are presented under several assumptions regard-
 ing the  world price of oil.  Reduced driving and greater vehicle
             aYV°m*1ned.t0 reduce the future demand for m°tor gasoline.
        th    lndlcates'.jt is unlikely that gasoline demand will,
 Th   rn  i f?recasj Period, reach those levels observed during 1983.
 This conclusion ho ds true for all assumptions regarding the future of
 world oH prices with the exception of the low price scenario for 1985.
    n!!d v**1  9"o11?e demand  d°*s  ™t,  however,  imply that
    gasoline production facilities  are currently  capable of
n          '1     ru1rtS-   In  articular   the continued
 Phseout o     d       1-           cuar,    e  contnued
 pnase-out of leaded gasoline and demand for higher  octane  ratings will
 CThp ovSnme/Hdri0nS t0 ref1nery caPaci'ty-   Consequently,  refiner
 ti'on r.St •    -° ln7ease Backing,  catalytic  reforming, and  alkyla-
 tion capacities in order to maintain octane requirements. fs

 tr-,-a1DKS^llate f!Jel  oils are  used 1n  home  heating, utility  and indus-
 trial  boilers   and as diesel  fuel. Unlike  the other three major
 petroleum product  categories  noted in  Table 9-8, demand for  distillate
 fuel  oil  is  projected to increase  under all price scenarios   Thl
                                                                  and
                   «    ,   H             the
               ?nr''rk
depressed residual  fuel  demand  in  1982,  and  that  1 n"e growth  n

                                9-13

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       TABLE 9-8.   REFINED PRODUCT DEMAND PROJECTIONS  FOR U.S.
          REFINERIES UNDER THREE WORLD OIL PRICE  SCENARIOS
                               1983-1986-19893

World
Crude
Oil Price b»c
Year
1983
Low
Mid
High
1989
Low
Mid
High
$/BBL.
30.00
21.00
28.00
38.00
26.00
36.00
45.00
$/m3
188.70
132.09
176.12
239.02
163.54
226.44
283.05
Demand (1,000 m3/cd)
Motor Distillate Residual
Gasoline
988.7
1,015.7
941.7
869.7
883.8
814.3
764.9
Oil
425.8
609.3
539.0
482.4
625.5
534.3
485.2
Oil
209.1
422.0
388.8
329.2
425.9
361.0
276.1
Jet
Fuel
160.5
184.6
180.0
173.4
196.9
189.5
183.6

Total0
2,320.79
2,880.53
2,657.94
2,419.68
2,796.68
2,514.29
2,287.66
aReference 23, pp.  68,  103,  138.

bReference 23, p. 17.

C1982 dollars.

dTotal includes the four products listed plus all  other  refined  products.
                                         9-14

-------
  products, most  analysts agree  that in the short-term,  quantity demanded

     °             '            hanges due to the in*b?m* <* ™^
                               ogies.  However, as the  focus shifts  to
                                -  A?  n°ted 1n the  Pilous section,
                                 refined petroleum  products will  be
      Attempts to reduce dependence upon imported oil have focused unnn




                                                                  ic
  P     ocuolec^l^Jc^f^?- reL"h?riCU'ar'
were

                              9-15

-------
TABLE 9-9.  PRICE ELASTICITY ESTIMATES FOR  MAJOR  REFINERY  PRODUCTS
                         BY DEMAND SECTOR
                        UNITED STATES, 1990*
Demand Sector
Residential
Commeri cal
Industrial

Transportation



Refinery Product
Distillate Oil
Distillate Oil
Distillate Oil
Residual Oil
Gasoline
Distillate Oil
Residual Oil
Jet Fuel
Price Elasticity13
-0.46
-0.45
-0.64
-0.45
-0.45
-0.89
-0.09
-0.52
 Reference  28,  p.  333.
 DPercent change in quantity  demanded  in  response to a one percent
  increase in  price.
                                  9-16

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           TABLE 9-10.  CRUDE OIL PRODUCTION AND CONSUMPTION  BY  YEAR
                          UNITED STATES,  1970-1982*
                             (1,000,000 m3/year)b
Year
1970
1971
1972
1973
1974
1975
1976
1977
1978
1979
1980
1981
1982
Production0
559
549
549
534
486
465
452
457
485
474
500
497
503d
Imports0
77
98
129
188
202
238
308
384
369
376
303
240
20ld
Consumption6
633
649
680
723
688
703
760
841
854
850
802
753
703
Exports6
0.8
0.1
0.1
0.1
0.2
0.3
0.5
2.9
9.2
13.6
16.7
13.2
13.7
Year-End
Stocks6
44
41
39
39
42
43
45
55
60
68
27
34
37
Stocks as Percent
of Consumption
6.94
6.36
5.76
5.33
6.13
6.14
5.97
6.57
7.01
8.05
3.37
4.51
5.26
Reference 2, p. 073  (1970-1979 data).
bl m3 = 6.29 barrels.
cReference 13.  (1980-1981  data).
dReference 29.  Table 2.
Deference 29.  Table 22, (1980-1982 data).
                                    9-17

-------
     9133  Prices.   Table  9-11  indicates historic wholesale price
level s'for'gasoTTnT: distillate  fuel  oil,  and  residual fuel oil.  For
each product, a pattern of stable  prices,  followed by  ^d price
increases in 1974 and  1979 through 1981, can be  observed.  The increases
observed during both periods  can be attributed to the  pass-through  of
increases in the price of crude  oil  supplied by  the OPEC nations.

     Future prices of  refined products will  continue to  rise  in  response
to increases in the price of  both imported and domestic  crude   The
Department of Energy expects  that average  wordwide  crude  oil  P"ces
should increase at an annual  rate of about 3.1 percent up  to  1989  (see
Table 9-19).

     9134   Imports.   Imports of both crude oil  and  refined products
are expected tytontTnue to decline through the  1980s.  In the case of
crude oil,  the  fall in  import levels can be attributed to increases; in
the price of OPEC oil,  and the  increased production of domestic crude
prompted by its price  decontrol.

      Low sulfur (sweet)  crudes  are generally  more desirable than high
 sulfur  (sour)  crudes  because the  refining of  the latter requires a
 larger  investment  in  desulfurization  capacity to meet process as well
 as environmental  needs.  While  more  than  half of the  current crude
 imports are sweet,  only 15 percent  of OPEC's  total oil reserve  is  sweet
 crude.30  Consequently, it is most  likely that  future imports will
 contain higher proportions of sour crudes and thus make sour crude
 processing a more profitable investment for many refineries.

      With  regard to refined  petroleum products, the  importation of most
 of these products is  expected to decline  as  it  has  since  the mid-1970s.
 Table 9-12 shows that for the major refined  products, imports  peaked
 during 1973-1974.  In general,  imports of refined  products  have been
 relatively small compared with  production at  domestic/efinenes.   One
 notable exception is  residual  fuel oil.   The relatively high ratio of
 imports to domestic production  of this product  is..att"bj*^ t'S?,,
 orientation of U.S. refineries toward the production of higher levels
 of more valuable lighter products, such as motor gasoline, through the
 "cracking"  of  residual  oil.  The importation of greater amounts of
 residual oil  is therefore required to satisfy the requirements of
 utilities  and  large  industrial  boilers in this country.

      9  1  3.5   Exports.   Exports  of crude oil and refined petroleum
 products  are  a small  portion of  total U.S. production  and amount to
  less than  eight percent of  the volume imported.31  All exports are
  controlled by a strict licensing policy  administered by the U.S.
  Department of Commerce.  Recently,  crude oil exports have increased  in
  response  to the Canada-United  States Crude Oil Exchange Program.  The
  program is mutually  beneficial in  that acquisition costs are minimized
  through improved efficiency of transportation.

       Table 9-13 summarizes  recent trends in  major  refined  Product
  exports.   The decline in exports through the 1970s  can  be  attributed to


                                   9-18

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         TABLE  9-11.   AVERAGE  WHOLESALE  PRICES:   GASOLINE, DISTILLATE FUEL
                            OIL,  AND  RESIDUAL FUEL OIL BY YEAR
                                  UNITED STATES,  1968-1982a
                                      (tf/liter)
Year
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978
1979
1980
1981
1982
Gasolineb»c
4.4
4.5
4.7
4.8
4.7
5.2
8.1
9.5
10.3
11.2
11.8
16.4
24.0
26.9
24.7
Distillate Fuel Oilb>c
2.7
2.7
2.9
3.1
3.1
3.6
5.6
8.2
8.7
9.8
9.9
14.3
21.3
26.0
24.4
Residual Fuel Oilb»c
1.5
1.5
1.9
2.6
3.0
3.4
6.8
6.8
6.6
7.9
7.4
10.2
14.6
18.2
16.7
aCurrent dollars.
Reference 12, p. 079 (1968-1979).
cReference 29.  Table 42 (1980-1982).
                                   9-19

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       TABLE 9-12.
IMPORTS OF  SELECTED PETROLEUM  PRODUCTS  BY  YEAR
    UNITED  STATES,  1969-19813
          (1,000 m3/cd)
Year
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978
1979
1980
1981
Motor
Gasoline
10
11
9
11
21
32
29
21
34
31
29
22
24
Distillate
Fuel Oil
22
24
24
29
62
46
25
23
40
27
31
22
27
Residual
Fuel Oil
201
243
252
277
295
252
194
225
216
214
182
146
127
Jet Fuel
20
23
29
31
34
26
21
12
12
14
14
13
6
Kerosene
0.5
0.6
0.2
0.2
0.3
0.8
0.5
1.4
3.0
1.7
1.4
1.5
1.1
NGL and LRG
6
8
17
28
38
34
29
31
32
22
37
NA
NA
aReference 13.  Section VII,  Table 5,  6,  6a,  7,  7a,  14,  15,  16,  16a,  17,  17a.
NA - not available.
                                      9-20

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         TABLE 9-13.  EXPORTS OF SELECTED PETROLEUM PRODUCTS BY YEAR
                          UNITED STATES, 1969-19819
                                (1,000 m3/cd)
Year
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978
1979
1980
1981
Gasoline
0.3
0.2
0.2
0.2
0.6
0.3
0.3
0.5
0.3
0.2
0.0
0.2
0.3
Distillate
Fuel Oil
0.5
0.5
1.3
0.5
1.4
0.3
0.2
0.2
0.2
0.5
0.5
0.5
0.8
Residual
Fuel Oil
7.3
8.6
5.7
5.2
3.7
2.2
2.4
1.9
1.0
2.1
1.4
5.2
18.8
Jet Fuel
0.8
1.0
0.6
0.3
0.8
0.3
0.3
0.3
0.3
0.2
0.2
0.2
0.3
Kerosene NGL and LRG
0.2 5.6
4.3
0.2 4.1
4.9
4.3
4.0
4.1
4.0
2.9
3.2
NA
NA
NA
'Reference 13.  Section VII, Tables 5, 6, 6a, 7,  7a, 14,  15,  16,  16a, 17 and 17a
NA - not available.
                                   9-21

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both increased domestic demand and the expansion of foreign refining
capacity.

9.1.4  Financial Profile

     The financial status of the oil industry is generally regarded as
strong, although recent supply/demand imbalances have affected profit-
ability. Recent below average performance has been attributed to a
number of factors including, reduced demand due to conservation,
oversupply due to new discoveries, and major recessions in Western
Europe and the United States.32

     Profit margins and returns on investment for both major oil
companies and independent refiners are summarized in Tables 9-14 and
9-15.   In those tables, profit margin refers to net (after-tax) income
as  a percentage of sales, while return on investment expresses net
(after-tax) income as  a percentage  of total  investment or  total assets,
                                   9-22

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          TABLE 9-14.   PROFIT MARGINS FOR MAJOR CORPORATIONS WITH
                       PETROLEUM REFINERY CAPACITY,  1977-1981*
                                     (Percent)
Company
Integrated- Internat 1 onal
British Petroleum
Exxon Corp.
Gulf Oil
Mobil Corp.
Royal Dutch Petroleum
Standard 011 of California
Texaco, Inc.
Integrated-Domestlc
Amerada Hess
American Petroflna
Atlantic Richfield
Diamond Shamrock
Getty 011
Kerr-McGee
Murphy Oil
Occidental Petroleum
Phillips Petroleum
Shell 011
Standard Oil (Indiana)
Standard Oil (Ohio)
Sun Co
Union Oil of California
Refiners
Ashland Oil
Charter Co.
Crown Central Petroleum
Holly Corp.
Quaker State
Tesoro Petroleum
Tosco Corp.
1977
3.0
4.5
4.2
3.1
6.0
4.9
3.3

3.9
3.6
6.4
10.6
9.9
5.5
4.2
3.6
8.2
70
. <5
7.8
5.2
.6
5.9

3 A
• *J
1 ^
1 . J
2.0
3.8
6n
»u
0.1
1.2
1978
3.1
4.6
4.4
3.2
5.0
4.8
3.0

3.0
2.8
6.5
7.8
9.3
5.7
3.9
0.1
10.2
.4
7.2
8.7
4.9
6.4

4-»
.7
1f\
.2
2.8
3.5
4/1
.9
2.4
1.6
1979
8.9
5.4
5.5
4.5
11.1
6.0
4.6

7.5
5.2
7.2
7.6
12.5
6.0
6.6
5.9
9.4
7.8
8.1
15.0
6.6
6.6


8.1
8.7
6.8
2.6
4.9
2.5
4.1
1980
6.9
5.5
5.3
4.7
6.3
5.9
4.4

6.9
4.9
7.0
6.4
8.6
5.2
7.7
5.7
8.0
7.8
7.3
16.4
5.6
6.5


2.5
1.1
1.5
2.2
3.1
2.9
1.9
— i • • n . .1 _
1981
4.2
5.2
4.4
3.8
4.7
5.4
4.0

2.3
2.9
6.0
6.8
6.6
5.5
6.7
4.9
5.5
7.9
6.4
14.5
7.2
7.4


1.0
1.1
0.2
1.4
3.0
2.6
0.7
Deference 14,  p.  088.
                                    9-23

-------
      TABLE 9-15.  RETURN ON INVESTMENT OF MAJOR CORPORATIONS

                   WITH PETROLEUM REFINERY CAPACITY 1977-19813

                                 (Percent)
Company 	 	
Integrated-International
British Petroleum
Exxon Corp.
Gulf Oil
Mobil Corp.
Royal Dutch Petroleum
Standard Oil of California
Texaco, Inc.
Integrated-Domesti c
Amerada Hess
American Petrofina
Atlantic Richfield
Diamond Shamrock
Getty Oil
Kerr-McGee
Murphy Oil
Occidental Petroleum
Phillips Petroleum
Shell Oil
Standard Oil (Indiana)
Standard Oil (Ohio)

-------
 9.2  ECONOMIC IMPACT ANALYSIS

 9.2.1  Introduction and Summary

      In the following sections the economic impacts of the regulatory
 alternatives noted  in Chapter 6 are discussed.  Also presented is a
 summary of the method used  to estimate such impacts.  In general
 h£°nrIUn*15P!CtiLare  descr1bed 1n terms of the price increases that may
 be prompted by the  various  regulatory alternatives, and the potential
 reductions in petroleum product output that could result as consumers
 respond to increased  prices.  The socioeconomic impacts of the proposed
 NSPS including inflationary,  employment, balance of trade, and small
 business  impacts are  addressed in Section 9.3.  As noted in that
 a?t*™^-     flftj-yea r.a!™ual i zed costs of tne most    t]   regulator
 alternatives  are $6.3 million, well below the $100 million level  that
           Order 12291 identifies as the threshold for major regulatory
          rfuard to *he Price ^creases and industry-wide  output

9.2.2  Method
     As explained in Chapter 3,  the  petroleum refinery wastewater
and tTeat0  ftCth Wastew!ter from  ™merous P°i"ts throughout the refinery
and treats it by way of the separation and flotation processes ore-
IfvllLt*nrlbed'   S^Ch w«tewater  is generated throSgh the option
of various process  units and  mav also be* tho rOC1,n. «* <.*	.^.
      at thr               als° b  the --""'tsto™ w«e
      i?     SS^-S-- .--"Basons  the costs  ofoperatin,
                                P°te"t1a' 'rtc« a"d °»W «-P«t, has
                               9-25

-------
    t  the estimation of the annualized control cost per unit of
       output produced at a new refinery (i.e. required price
       increase),

    •  the estimation of the price per unit of refinery output and
       total output demanded in 1989, as well as the demand curve
       for petroleum products  in that year, and

    •  the estimation of product prices and demand  from domestic
       refineries  in 1989 both with  and without the costs  related to
       the wastewater NSPS.

Each of these tasks is discussed  in greater detail  below.

     For  purposes of this  analysis  it is  assumed that  the  market  for
refined petroleum products  is basically  competitive, and that there  is
little competition from  imports of  refined products.  It is also
assumed that, as projected by the U.S. Department  of Energy (DOE  ,
conned economi? growth will  result in 1989 prices and production
levels that are higher than those currently observed.  Under such
conditions, 1989 prices and output will  be influenced by changes in the
cost structure of the few totally new refineries expected  to be con-
structed over the next five years.  This is true because these refiner-
ies will have higher average total costs relative to existing refiner-
ies  and as such, will determine the point of intersection between the
industry supply  and demand curves.  Consequently, even though most new
unit constructions and modifications will  occur at  existing  refin-
eries, the major focus of this analysis is upon the extent to which
NSPS costs will  increase the total  per unit cost of new refineries.

     The estimation of the extent  to  which the cost/price  structure of
a new  refinery  will be affected, entails  the  approximation of the
annual capacity of a new  refinery, the number of process  units that
will  comprise such a  refinery, and the total  annualized costs to  the
 refinery  to  control  VOC emissions  from  all process drain  systems, the
 oil-water  separator,  and  the air  flotation system    In  this  regard  it
 has been  assumed that  any  new  refinery  will  be relatively small  with
 daily capacity of 4,000  m3  (about  25,000 Bbl), and will  require
 controls  on  drains at  six  process  units,  two each  for Model  Units A,  B,
 and C   The  refinery is  also assumed to have one  oil-water separator
 and one  air  flotation system.   It  should be noted  that in summarizing
 NSPS control costs for the refinery, three "worst  case" assumptions are
 made.  That is, it is assumed that dedicated control  devices are needed
 for both the oil-water separator and air  flotation systems, and that
 these systems are of the API and DAF types respectively.   All three
 assumptions imply higher NSPS control costs.

      Both the  average size of the expected new refinery and number of
  process units  were selected after review  of the capacity and complexity
  of those new refineries currently under construction, as reported in
  published summaries of new  refinery  construction  activities.     10
  the extent that a new refinery may  have  fewer process units, total
                                   9-26

-------
  costs to the refinery will  be  lower.   Finally, per unit annualized
  costs are estimated  through the division  of total annualized NSPS
  control  costs  for the refinery by  its  expected annual volume of output.

       The next  step in this  method  entails the estimation of price per
  unit and total  domestic  refinery output for the year 1989.  This year
  is of concern  because it  represents the fifth complete year after
  proposal,  and  because the current  planning horizon of the industry
  extends  to about  that point, given the time required to plan, design
  and construct  completely new refineries.

       The estimation  of 1989 price and output, as well as the demand
  curve for  refined  products  in  that year, has been made possible through
  the results  of  DOE econometric models.  In particular, published
  results  generated  by  DOE's  Intermediate Future Forecasting System
  UFFS) allow the estimation of equilibrium price and  quantity under
  several  assumptions  regarding  future world crude oil  prices.3"

       Some  results of the IFFS model have been  noted  in Table 9-8 and
  are used in the following section to approximate  the  demand  curve for
  refined  products as it might exist  in 1989.   The  equation  for the
  demand curve for refined petroleum  products  in 1989,  has been estimated
  in  this  analysis by observing two points that  lie on  the curve,  and
  solving  for the straight line that  includes  those two points.   As  shown
 IL ™ 1°  •Tiln91ao«t1°-' the points  Se1ected  are quantity demanded  at
 the most likely 1989  price and  quantity demanded  if the  1989 price  is
 about 25 percent higher.   The straight  line  connecting these two  points
 provides an approximation of the 1989 demand curve because the two
 points estimate the level  of demand expected in that  year  if all
 factors other than price  are held constant.  In reality  the  demand
 curve is probably  not linear, but for the  purpose of  this analysis
  oonartyJS assi^med  because the  control costs will add  very little to
 1989 baseline prices.  Consequently, the movement up  the demand curve
 v«™ cl  /^   as/onsumers resP°nd to slightly higher prices will be
 very small, thus reducing  the significance of the precise shape of the
 demand curve in  that  area.
 in iQ«Qnally'^St1m^!S Of prices and the demand curve ^r the industry
 IL Ms tojether with estimates of the costs per unit attributable to
 the NSPS, will allow approximations of the degree to which industrv-
 W-?H  TK* U111 fal1 short of the outPut level that wou?d be ejected
 Hn^ln^5'5'  .SUC5 10Wer 1ndustry-wide output will  have impl'ca-
 fnr Lf?Ln   f0?^ °f "!W caPac1ty ^quired to meet the future demand
 for refined petroleum products.  Estimates of 1989 demand under the two
 iTfiQ d^°aryHalternat1Vf ^ made by Slmply Solvi'n9 the equation for the
 1989 demand curve  under the assumption that 1989 prices  will  be hiaher
 by  the amount of the NSPS control  costs.  A horizontal  supply  curve if

whichThlYspTrn^ h-lS RP °f the ana1*si*> a"d the  extent to
a™ *!•,.«.  ?       ft thlS CUrve upward 1s Drained  by  the
annual ized  control  costs.   The following section details  the quanti-
tative application  of the method outlined  above             Q
                                 9-27

-------
 9.2.3  Analysis

     As explained in the previous section the focus of this analysis is
 upon the  cost structure of a hypothetical new refinery, and in particu-
 lar the extent to which the NSPS costs will increase the per unit cost
 of the refinery, and ultimately the market clearing price of all
 refined petroleum products.  Tables 9-16 and 9-17 demonstrate the
 calculation of annualized cost on a refinery basis assuming that the
 new refinery will have daily capacity of 4,000 m3 (about 25,000
 Bbl/day)  and will have six process units and both an oil-water separa-
 tion and  an air flotation system.  According to the data shown in these
 tables, total annualized control costs for the refinery are $26.50
 thousand  and $285.36 thousand for Regulatory Alternatives II and III
 respectively.

     In order to express these costs on a per unit output basis, the
 annualized costs are divided by total annual output.  Assuming the
 refinery  operates 350 days per year and at 60 percent of the designed
 capacity, annual output is 840,000 m3 (5,283,600 Bbl).  Thus on a per
 unit basis the annualized cost are $0.03 and $0.34 per m3 for Regula-
 tory Alternatives II and III respectively ($0.005 and $0.05/Bbl).

     As noted in the previous section, the results of DOE modelling
 activities have allowed the estimation of equilibrium prices and
 quantities in 1989.  While DOE has projected United States refinery
 demand under three possible world crude oil  prices (in 1982 dollars)
 these prices have been converted to domestic wholesale prices for
 refined products to allow the approximation of the 1989 demand curve.

     The  relevant price and quantity data are summarized in Table 9-18.
 The world crude oil  prices are those reported by DOE, and are also
 noted in Table 9-8 of Section 9.1.  To convert crude prices to wholesale
 prices for refined products, the crude prices have been increased by
 8.55 percent according to recently observed price differences between
 the two products.35  The 1989 wholesale price estimates (in 1982
 dollars) are presented in the third and fourth columns of Table 9-18.
 Finally, because the control  costs presented in  Chapter 8 are expressed
 in terms of third quarter 1983 dollars, the 1989 wholesale prices (in
 1982 dollars) are updated according to the GNP price deflator.

     The equilibrium price and quantity for 1989 are assumed to be
those represented by the mid-level  price scenario.  Table 9-18 shows
this equilibrium price and quantity level  to be  $257.16 per m3
 ($40.88/Bbl)  and 2,514.29 thousand m3 per day (15,814.90 thousand
Bbl/day).  The slope of the demand curve in  the  immediate area of this
equilibrium can  be approximated from the data provided by Table 9-18.
Because the table summarizes demand levels expected  when all  factors
other than price are held constant, the demand curve in the area
immediately above the mid-price equilibrium  can  be approximated by
solving for the  straight line between  the price/quantity points defined
by the  high and  mid-price scenarios.  When the two points ($257.16,
2,514.29 thousand m3/day)  and ($321.45, 2,287.66 thousand m3/day)
are considered the following  equation  for the demand curve is obtained:

                                 9-28

-------
                 TABLE 9-16.  TOTAL ANNUALIZED CONTROL COSTS FOR A
                     NEW REFINERY, REGULATORY ALTERNATIVE IIa
                                 ($1,000 1983)
 Model
 Unit
                      Annualized
                      Cost/Unit
 Number
of Units
 Annualized
Cost/Refinery
Process Drain Systems
       A
       B
       C
Oil -Water Separator
Air Flotation System
                        $5.34b
                         1.61b
                         5.67C
                         1.85d
   2
   2
   2
   1
   1
 TOTAL
  $10.68
    5.08
    3.22
    5.67
    1.85
   26.50
Capacity = 4,000 m3.
bTable 8-4.
cTable 8-9.
dTable 8-13.
                                    9-29

-------
              TABLE 9-17.  TOTAL ANNUALIZED CONTROL COSTS FOR A
                  NEW REFINERY, REGULATORY ALTERNATIVE IIIa

                              ($1,000 1983)
Model
Unit
Process Drain Systems
A
B
C
Oil -Water Separator
Air Flotation System

Annual i zed
Cost/Unit

$47.62b
32.30b
26.21b
38.46C
34.64d

Number
of Units

2
2
2
1
1
TOTAL
Annuali zed
Cost/Refinery

$ 95.24
64.60
52.42
38.46
34.64
285.36
aCapacity = 4,000 m3.

bTable 8-4.

cTable 8-9.  API separator with emissions vented to a dedicated control device,

dTable 8-13.  OAF system with emissions vented to a dedicated control device.
                                      9-30

-------
                  TABLE 9-18.  DOE PROJECTED PRICES AND DOMESTIC REFINERY DEMAND
                           UNDER THREE WORLD OIL PRICE SCENARIOS, 1989
to
CO
1— «
World Crude
Oil Price, 1989a
(1982 $'s)
(t / f>U T * * r»
S/Bbl $/m3
Low 26.00 163.54
Mid 36.00 226.44
High 45.00 283.05
== — - 	 	 	 ..
U.S. Wholesale
Prices 1989b
(1982 $'s)
$/Bbl
28.22
39.08
48.85
$/m3
177.52
245.80
307.25
	 "• — ' ' -'— •' - - i, 	 	
U.S. Wholesale
Prices 1989°
(1983 $'s)
$/Bbl
29.52
40.88
51.11
$/m3
185.72
257.16
321.45
-'•:
Total U.S.
Demand
(1 000 m
1,000 Bbl
17,591.09
15,814.90
14,389.40
- :
Refinery
1989d
3/dav1
/ ua_y )
1,000 m3
2,796.68
2,514.29
2,287.66
bjrud|5pr1ees converted to wholesale prices for refined products, by applying a factor of
dTable 9-8.

-------
      Quantity (1,000 m3/day)  =  3,420.811  -  3.525125  Price,

 where price and  quantity  are  the  independent and dependent variables,
 respectively.

      The final step  in  the  analysis  is  to add the NSPS costs per
 refinery to the  1989 equilibrium  price  for  refined products, and
 estimate 1989 demand levels from  the  demand equation noted above.
 With regard to prices,  it has been shown that the 1989 industry base-
 line price  of $257.16 per m3 would increase to $257.19 and $257.50
 per mj under Regulatory Alternatives  II and III respectively, if all
 costs are passed through  in the form  of higher prices.  Solving the
 demand equation  for  these prices  decreases the estimate of 1989 quantity
 demanded from the  1989  baseline of 2,514.29 thousand m3 per day to
 2,514.18 thousand m3  per day and  2,513.09 thousand m3 per day
 under Regulatory Alternatives II  and  III, respectively.  All 1989 prices
 and demand  levels  are summarized  in Table 9-19.

 9.2.4  Conclusions

      The general conclusion to be derived from the preceding analysis
 is  that the NSPS for refinery wastewater systems will have very little
 impact upon either the  firms that refine petroleum products or the
 consuming public.  Table 9-20 summarizes the changes in price and
 quantity demanded that  can be expected as both the demand for and
 supply of petroleum  products from domestic refineries grows until the
 year 1989.   As indicated, market  forces alone will  increase the price
 of  refined  products  by  about $42.86 per m3  ($6.81/Bbl)  over that
 period (i.e., from $214.30/m3  in  1983, to $257.16/m3 in 1989 as
 shown  in Table 9-19).   Such forces will  determine the market clearing
 price  and quantity in 1989 and include such factors  as: the price of
 imported and domestic crude oil  and the proportions  of each used by
 domestic refineries; the prices of alternative sources  of energy; the
 growth  of the United States and international  economies;  and the costs
 of  other inputs into the refinery industry (e.g.  labor  and capital).

      If the  NSPS costs are also considered in  addition  to the factors
 noted  above, the prices of refined products  would show  very little
 additional  increases.   If the  industry incurs  the costs related  to
 Regulatory  Alternative II, the price  of refined  products  would  increase
 about  $42.89 per m3  ($6.82/Bbl), or $0.03 per  m3  (less  than $0.017
 Bbl) more than they would without the NSPS.  If  the higher costs  of
 Regulatory Alternative III are incurred, the increase would be  about
 $0.34 per m3 ($0.05/Bbl).

     Although the increases  noted above  are  very  low, and  may in fact
 be  imperceptible  to the average consumer,  the method  used  in  this
 analysis allows  some approximation of sales  decreases that  would occur
 as consumers encounter the slightly higher prices.   Table  9-20  shows
 that in 1989, demand would be  193.50  thousand m3  per  day  (1,217.11
thousand Bbl/day) higher than  in 1983, if  the NSPS is not  promulgated.
 However, with the standard,  demand would be  193.39 thousand m3 per


                                 9-32

-------
                                        TABLE  9-19.   PRICE AND TOTAL DEMAND

                                      UNDER  REGULATORY ALTERNATIVES II AND III


                              (3rd  quarter 1983 dollars, 1,000 m3/day, 1,000 Bbl/day)
                                       Demand
                                                                                  Alt
         ic Meters  (.3,    $214.30     2,320.79     $257.16   2>514.29     $257.19
<£>
I
                                                                                                $40.93    iS.807.34
                                                              thr°U9h  GNP  !""licit  Pri« ^"«or where


     "Crude prices converted to wholesale prices  for  refined  products  by factor of  1.0855.

     cTable 9-18.

-------
                     TABLE 9-20.  CHANGES  IN 1989 PRICE AND DEMAND
                         COMPARED WITH 1983 BASELINE LEVELS

               (3rd  quarter  1983 dollars,  1,000 m3/day, 1,000 Bbl/day)
Changes Under
Reg. Alt. Ia
Price Demand
Changes Under
Reg. Alt. II
Price Demand
Changes Under
Reg. Alt. Ill
Price Demand
Cubic Meters (m3)     $42.86      193.50    $42.89      193.39      $43.20      192.30


Barrels (Bbl)	$ 6.81    1,217.11    $ 6.82    1,216.40      $  6.86    1,209.55

aNo NSPS control,  thus these increases in price and  quantity  demanded  are
 due to market forces alone.
                                        9-34

-------
and i5?2Jn'S thouf "d BbVday) higher under Regulatory Alternative II
nnl  D   i* USa«? m  per day d.209.55 thousand  Bbl/day)  higher
^ceWS^KT1:6,,^1-. ThUS' RTlat°ry Alte?iaJ]!e  n  would
reauce iy«y demand by about 110 m3 per day  about  710  Bbl/dav) anH
SlaXry Alte:nat1ve HI ^ 1,200 m3 per day  (about  7,560 Bbl/day)
Sin tehCOmpet!tlVe market and caPacit^ utilization  assumptions
made in th s analysis, it should be concluded that  planned  additions to
industry-wide capacity would be reduced by these small  amounts if
either Regulatory Alternative II or III is promulgated
                              9-35

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9.3  SOCIOECONOMIC AND INFLATIONARY IMPACTS

     The previous section has described how  the petroleum  refining
segment of the national  economy might be affected  by  this  NSPS.   In
this section the scope of the analysis is expanded so that the  probabil-
ity of broader economic effects might be assessed.  Among  the issues
examined are those related to inflation, employment,  the balance of
trade, and the potential for adverse impacts upon  small  businesses.

9.3.1  Executive Order 12291

     According to the guidelines established by Executive  Order 12291
"major rules" are those that are projected to have any of  the following
impacts:

     •   an  annual effect on  the economy of $100 million or more,

     •   a major  increase in  costs  or  prices for consumers, individual
         industries,  federal, state, or local government agencies, or
         geographic  regions,  or

      t  significant  adverse  effects  on competition,  employment,  invest-
         ment, productivity,  innovation, or  on  the ability of the United
         States  - based  enterprises to compete  with foreign-based
         enterprises in  domestic or export markets.

      Each of these topics  are  examined in the  following sections.

      9.3.1.1  Fifth-Year Annualized Costs.   The determination  of
 fifth-year annual 1 zed costs is demonstrated in Tables 9-21 and  9-22.
 Table 9-21 shows the expected fifth-year cost  for each model unit under
 each regulatory alternative.  The total costs  noted  in this table are
 determined through consideration of the annualized costs  presented  in
 Chapter 8 and the number of new unit constructions,  reconstructions and
 modifications noted in Chapter 7.  The costs presented in both tables
 are the highest that should be incurred under the regulatory alterna-
 tives, because  it has been assumed that control devices do not exist at
 the refineries  that will be affected  by the NSPS.

      Table 9-22 summarizes  the fifth-year costs  in terms  of extremes.
 Because Regulatory  Alternative I  entails no controls above those
 already employed, no incremental  fifth-year costs are  incurred.  If
 Regulatory Alternative  II is  proposed  for all model  units, the total
 annualized costs in the fifth-year after proposal would  be  about $0.7
 million.   Finally,  under Regulatory  Alternative  III, the most  stringent
 and  costly alternative, fifth-year costs are  about  $6.3  million.

       It should  be  noted that  the  fifth-year costs under  all regulatory
  alternatives are well  below the  $100 million  threshold specified in  the
  Executive  Order.

       9.3.1.2  Inflationary Impacts.   The proposal of this NSPS will
  have virtually no effect  upon the rate of  inflation in the domestic

                                   9-36

-------
                                       TABLE  9-21.   SUMMARY  OF FIFTH YEAR ANNUALIZED COST

                                           BY MODEL  UNIT  AND REGULATORY  ALTERNATIVE



                                              (1,000 -  3rd quarter  1983  Dollars)
10
i
u>
Model
Unit
Process Drain Systems (New)3 A


r
L.

Process Drain Systems (Retrofit)*5 A





Oil -Water Separators (New)c A





Oil -Water Separators (Retrofit)d A





• 	 • 	 . 	 __
Regulatory
Alternative
II
III

III

III
II
III
II
III
II
III
II
III
I
III
II
III
II
III
II
III
II
III
Annual ized Cost
Per Unit
$ 5.34
47.62
2.54
32.30
1.61
26.21
12.65
55.38
5.97
35.94
3.78
28.47
10.47
43.26
5.67
38.46
5.67
38.46
15.83
48.56
8.59
41.38
8.59
41.38
Number of
Units
27
27
27
27
51
51
3
3
3
3
9
9
5
5
10
10
15
15
1
1
1
1
1
1
Total
Annual ized Cost
$ 114.18
1,285.74
68.58
872.10
82.11
1,336.71
37.95
166.14
17.91
107.82
34.02
256.23
52.35
216.30
56.70
384.60
85.05
576.90
15.83
48.56
8.59
41.38
8.59
41.38
                                                                                             (continued)

-------
                                                 TABLE 9-21
vo

CO
CO
Model
Unit
Air Flotation (New)6 A


r

Air Flotation (Retrofit)f A
R

r

aTable 8-4.
bTable 8-5.
cTable 8-9.
dTable 8-8.
6Table 8-13.
fTable 8-13.
-. — _ 	 	 — 	 	 •- .-
Regulatory Annual i zed Cost
Alternative Per Unit 	
II
III
II
III
II
III
II
III
II
III
II
III






3.69
36.48
1.85
34.64
0.12
32.91
3.69
36.48
1.85
34.64
0.12
32.91






Number of
Units
5
5
10
10
10
10
1
1
1
1
1
1






Total
Annual i zed Cost
18.45
182.40
18.50
346.40
1.20
329.10
3.69
36.48
1.85
34.64
0.12
32.91







-------
                   TABLE  9-22.   RANGE  OF  FIFTH-YEAR ANNUALIZED
                         COST OF AFFECTED FACILITIES


                     (1,000 - 3rd quarter 1983 Dollars)
                                         Regulatory  Alternative	
                                 	if              ~!TT
Process Drain Systems (New)      $0            $294.87          $3,494.55


Process Drain Systems (Retrofit)  0              89.88             530.19


Oil-Water Separators (New)        0             194.10           1,177.80


Oil-Water Separators (Retrofit)   0              33.01             131.32


Air Flotation (New)              0              38.15             857.90


Air Flotation (Retrofit)          £               5.66             104.03

            TOTAL                0             655.67	6.295.79
                                     9-39

-------
economy.  Even if consumers eventually bear all  of  the  fifth-year costs
noted above, price increases would be imperceptable as  the  total  annual
value of the industry's output exceeds $100 billion.

     9.3.1.3  Employment Impacts.  The costs related to this NSPS would
have little effect upon the level of employment, in  the  petroleum
refining industry.  Table 9-5 shows that about 169,600  persons were
employed in the industry in 1981.  Based upon industry  capacity of
about 3,000,000 m3 per day during that year, the approximate capacity
per worker  is 18 m3 per day.  As reported in Section 9.2.4 the
regulatory  alternatives evaluated would reduce the need for planned
expansions  in capacity up to  1989 by  110 and 1,200 m3 per day for
Regulatory  Alternatives II and  III respectively.  Using the 18 m  to
1  ratio of  daily capacity to  workers  noted above, and the expected
baseline increase in demand of  193.5  thousand m* per day (Table
9-20)  the  growth in refinery employment over the next five years
would'be about  10,750 workers without the NSPS.  Because the decreases
in demand  from  the  1989 baseline are  110 and 1,200 nr,3 per day for
Regulatory  Alternatives II  and  III respectively, these alternatives
could  reduce  the  growth in  employment by six and 67 workers.

 9.3.2   Small  Business  Impacts - Regulatory  Flexibility Act

      The  Regulatory Flexibility Act,  which  became  effective on  January
 1, 1981,  requires the  identification  of potentially adverse impacts  of
 Federal*regulations upon  small  entities including  small  businesses.
 The Act requires that  a Regulatory Flexibility Analysis  (RFA)  be
 completed for all Federal  regulations that could have  a  significant
 adverse economic impact on a substantial  number of small  entities.  The
 following discussion will  show that  this NSPS will  not affect a substan-
 tial number of small businesses.

      For the purposes of this discussion.a small  refinery is defined as
 one that has crude oil capacity of less than 3,180 m3  per day (20,000
 Bbl per day).  This level  is based upon the recent definition of  small
 refiner" made by EPA in establishing lead content rules for gasoline
 refiners.  In those rules a  small refinery is defined  as one that
 produces fewer than 1,590 m3 per day (10,000 Bbl per day) of gasoline.
 Because on a national level  about half of total refinery throughput is
 gasoline,  the  crude oil capacity of  the small refinery is  in this
 analysis,  assumed to be twice  the gasoline output or 3,180 m  per day
 (20,000 Bbl  per day).

      According to  the most  recent OAQPS/Economic Analysis  Branch
 guidelines,  the  NSPS must  affect more  than 20 percent of all small
 businesses in  the  industry  in  order  to be defined  as one that  affects  a
 "substantial"  number  of small  businesses.  Currently about one-thirtof
 all domestic refineries have crude oil  capacity of  less than 3,180  m
 per day  (20,000 Bbl per day).   Because there  are  about  220 petroleum
 refineries operating  (Table 9-1), about 75 are considered  to be small
 refineries.   However,  the most recent  survey  of refinery  construction
 and reconstruction activities shows  that  of  about  75  current  refinery


                                   9-40

-------
construction and reconstruction projects, only five are being undertaken
at small refineries as defined above.  Therefore fewer than seven
percent of the small refineries will be affected by the standard  if
the current distribution of construction activity continues.  Because
there is no reason to presume that the current distribution of construc-
ts? ?hi^nHm°Hn9 -!1!™5 ?f ^M°US SlZ6S w111 Chan9e> U is concluded
that this standard will not affect a substantial  number of small
refineries, and for this reason a Regulatory Flexibility Analysis is
not required.
                               9-41

-------
9.4   REFERENCES

 1.  Cantrell, A. Annual  Refining Survey.   Oil  and  Gas  Journal.
     71(14).  April  2,  1973.

 2.  Cantrell, A. Annual  Refining Survey.   Oil  and  Gas  Journal.
     72(13).  April  1,  1974.

 3.  Cantrell, A. Annual  Refining Survey.   Oil  and  Gas  Journal.
     73(14): 98.  April  7,  1975.

 4.  Cantrell, A. Annual  Refining Survey.   Oil  and  Gas  Journal.
     74(13): 129.  March  29, 1976.

 5.  Cantrell, A. Annual  Refining Survey.   Oil  and  Gas  Journal.
     75(13): 98.  March  28, 1977.

 6.  Cantrell, A. Annual  Refining Survey.   Oil  and  Gas  Journal.
     76(12): 113.  March  20, 1978.

 7.  Cantrell, A. Annual  Refining Survey.   Oil  and  Gas  Journal.
     77(3): 127.  March  26, 1979.

 8.  Cantrell, A. Annual  Refining Survey.   Oil  and  Gas  Journal.
     78(12): 130.  March  24, 1980.

 9.  Cantrell, A. Annual  Refining Survey.   Oil  and  Gas  Journal.
     79(12): 110.  March  30, 1981.

10.  Cantrell, A. Annual  Refining Survey.   Oil  and  Gas  Journal.
     80(12): 128.  March  22, 1982.

11.  Cantrell, A. Annual  Refining Survey.   Oil  and  Gas  Journal.
     81(12): 128.  March  21, 1983.

12.  Standard and Poor's.  Industry Surveys - Oil,  August  7,  1980
     (Section 2).  p.  074.

13.  American Petroleum  Institute.  Basic  Petroleum Data Book.   1983.

14.  Standard and Poor's.  Industry Surveys - Oil.   November  4,  1982
     (Section 2). p. 075.

15.  Reference 12, p.  081.

16.  Reference 12, p.  079.

17.  Reference 13, Section  V,  Table 2.

18.  Reference 13, Section  V,  Table 1.
                                 9-42

-------
19.  Cost of Benzene Reduction in  Gasoline  to  the  Petroleum  Refining
     Industry.  U.S. Environmental  Protection  Agency.   Office  of Air
     Quality Planning and Standards.   EPA-450/2-78-021.  April  1978,  p.
     1-3.

20.  Jones, Harold.  Pollution Controls in  the Petroleum Industry.
     Noyes Data Corporation.  Park Ridge,  NO.   1973.   332 pp.

21.  1978 Refining Process Handbook.   Hydrocarbon  Processing.   56(g):97-
     224.  September 1978.

22.  Boland, R.F., et al.  Screening  Study  for Miscellaneous Sources  of
     Hydrocarbon Emissions in Petroleum Refineries.   EPA Report No.
     450/3-76-041.

23.  Energy Information Administration.  U.S.  Department of  Energy.
     1983 Supplement to the Annual Energy Outlook.  DOE/EIA-0408(82).

24.  GAO Sees U.S. Refining Capacity Adequate  for Future.  Oil and Gas
     Journal.  81(7):60.   February 14, 1983.

25.  Hoffman, H.C.  Components for Unleaded Gasoline.  Hydrocarbon
     Processing.  59(2):57.

26.  Reference 14. p. 075.

27.  Reference 14. p. 075.

28.  Energy Information Administration.  U.S.  Department of Energy.
     Annual Report to Congress 1979.  Vol.  3.  p. 114.

29.  Reference 23. p. 154, 139.

30.  Johnson, Axel R.  Refining for the Next 20 Years.  Hydrocarbon
     Processing.  59(2):57.   February 1980.

31.  Beck, J.R. Production Flat; Demand, Imports Off.  Oil and Gas
     Journal.  78(4):108.  January 28, 1980.

32.  Reference 14.  p. 057.

33.  HPI Construction Boxcore.  Hydrocarbon Processing Section 2.
     October  1983.  pp. 3-8.

34.  Reference 33.  pp. 17, 68, 103, and 138.

35.  The Petroleum Situation.  The Chase Manhattan Bank, N.A.  7(1):4.
     March 1983.
                                 9-43

-------
                                   APPENDIX A

                EVOLUTION OF THE BACKGROUND INFORMATION DOCUMENT
  ,nnnw          n     study was to devel °P background information to
  support New Source Performance Standards (NSPS) for petroleum ref nery
  u  eerW?ontrra^t toStheW5nitPHn ^ ^^  Perf°med by «ad1an  Cation
  unaer contract to the United States Environmenta  Protection  Aqencv  (EPA)
                                ^
P ant
plant
  n
  its
  refinery "astewater  systems.   From  the  screening  study  H was      uded that




                         f \"? em1SS1'°nS testl'"9 »*s deteSd' during Ihe'
                         testing was then conducted at three refineries.

          Ch!fonolo9> whicn f°Hows lists the major events which have occurred
 st.    dev^°Prne"t f background information for New Source Performance
 Standards for petroleum refinery wastewater systems.        ^rrormance
 June 8, 1982
 June 8, 1982
 June 9, 1982
 October 26-28, 1982
 November 3, 1982

 November 10, 1982

 January 25, 1983
 February
 March  14
 March  15
 March  16
 March  16
 March  17
 March  18
March  25
March  30
April  6,
April 6,
 2, 1983
, 1983
, 1983
, 1983
, 1983
, 1983
, 1983
,  1983
,  1983
 1983
 1983
                    Plant  Visit  to Gulf Oil, Belle Chasse, Louisiana
                    Plant  Visit  ot Shell Oil, Norco, Louisiana
                    Plant  Visit  to Exxon, Baton Rouge, Louisiana
                    Plant  Visit  to Phillips Petroleum, Woods Cross, Utah
                    Meeting held between Radian Corporation and EPA to
                    discuss Phase I of project
                    Outline for Source Category Survey Report Submitted to

                    Findings of Source Category Survey Report presented to

                   Workplan for Phase II  submitted to EPA
                   P ™J Hi!!! 1° Champlin  Oil, Wilmington,  California
                   Plant Visit to Tosco,  Bakersfield,  California
                   Plant Visit to Chevron U.S.A.,  El  Segundo,  California
                         Visit to Union Oil, Wilmington,  California
                   PI™* V  -I 1° T°bl1 Ol1' Torrance, California
                   Plant Visit to  Texaco, Wilmington, California
                   Plant Visit to  Sun Oil,  Toledo, Ohio
                   Meeting with  EPA to discuss  Testing Program
                   Plant Visit to  Phillips  Petroleum, Sweeny, Texas
                   Test  Request  submitted to Emission Measurement Branch of
                                    A-l

-------
May 3, 1983

May 11, 1983
May 12, 1983

May 13, 1983
June 2, 1983
July 28, 1983

August 1-12, 1983
August 15-19, 1983

August 30, 1983

September 19-23,
1983
October 7-8, 1983

November 23, 1983
March 14, 1984

July 12, 1984

August 28, 1984

October 10, 1984
November 7, 1984
Meeting with EPA to discuss inclusion of air
flotation systems and process drain systems in NSPS
Test Request sent to Phillips Petroleum, Sweeny, Texas
Test Request sent to Chevron U.S.A., Inc., El Segundo,
California
Test Request sent to Mobil Oil, Torrance, California
Meeting held EPA to discuss test plans
Test Request sent to Golden West, Santa Fe Springs,
California
Emission Test at Chevron, U.S.A., El Segundo, California
Emission Test at Golden West, Santa Fe Springs, August
California
Concurrence Memorandum submitted to EPA for Model
Plant Parameters and Regulatory Alternatives
Emission Test at Phillips Petroleum, Sweeny, Texas

Information requests sent to industry concerning fixed
roofs installed on API oil-water separators
BID Chapters 3-6 Sent to Industry
Concerrence Meeting on Regulatory Approach to NSPS
Development
BID, Preamble, and Regulation sent to NAPCTAC Committee
Members
NAPCTAC Meeting

Steering Committee Package sent to committee members
Meeting with Representatives of the American Petroleum
Institute
                                    A-2

-------
                                 APPENDIX B

                    INDEX TO ENVIRONMENTAL CONSIDERATIONS

     This appendix consists of a reference system which is cross-indexed
with the October 21, 1974, Federal Register (39 FR 37419) containing EPA
guidelines for the preparation of Environmental Impact Statements.  This
index can be used to identify sections of the document which contain data
and information germane to any portion of the Federal  Register guidelines.
                                    B-l

-------
                                 APPENDIX B

              CROSS-INDEX TO ENVIRONMENTAL IMPACT CONSIDERATION
Agency Guidelines for Preparing
Regulatory Action Environmental
Impact Statements (39 FR 37419)
Location Within the Background
  Information Document (BID)
1.   Background and Summary of
      Regulatory Alternatives
      Statutory Basis for the
       Standard
       Industry Affected
       Processes Affected
       Availability  of  Control
        Technology
       Existing Regulations
        at State or Local  Level
 2.   Environmental, Energy, and
       Economic Impacts of Regulatory
       Alternatives

       Health and Welfare Impact
The regulatory alternatives from
which standards will be chosen for
proposal are given in Chapter 6,
Section 6.2.

The statutory basis for proposing
standards is summarized in Chapter
2, Section 2.1.

A description of the industry to
be affected is given in Chapter 3,
Section 3.1.

A description of the process to be
affected is given  in Chapter 3,
Section 3.2.

Information on the availability
of control technology  is  given
in Chapter 4.

A dicussion of existing  regulations
for  the industry  to be affected by
the  standards  are  included in
Chapter 3,  Section 3.4.
 The impact of emission control
 systems on health and welfare
 is considered in Chapter 7,
 Section 7.2.

      Continued
                                     B-2

-------
       CROSS-INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS (Concluded)
Agency Guidelines for Preparing
Regulatory Action Environmental
Impact Statements (39 FR 37419)
     "~~™-^MMMamH^.^^_

      Air Pollution
      Water  Pollution
     Solid Waste Disposal
     Energy
     Costs
     Economics
  Location  Within  the  Background
    Information  Document  (BID)


  The air pollutant impact of the
  regulatory alternatives are
  considered in  Chapter 7,
  Section 7.2.

  The impacts of the regulatory
 alternatives on water pollution are
 considered in Chapter 7,
 Section 7.3.

 The impact of the regulatory
 alternatives  on solid waste
 disposal  are  considered  in
 Chapter 7, Section  7.4.

 The impacts of  the  regulatory
 alternatives  on energy use  are
 considered in Chapter 7,
 Section 7.5.

 The cost impact of the emission
 control systems is considered in
 Chapter 8.

 Economic impacts of the regulatory
alternatives are considered in
Chapter 9.
                                  B-3

-------
                                  APPENDIX C



                           EMISSION  SOURCE TEST DATA
,•„ ^Th! pu!:pose  of this appendix is to present VOC emissions  test  data
in the development  of  this background information document  VOC  emissi
                          s  acgroun   normation document   VOC emissions

     ec? online0 '^^on'r ^ n?™*« «>y the U.S.  Environm^n    °
 flotation M?Sy?nwi     refinery, tests were conducted  on a  dissolved  air
 notation system (DAF), an induced air flotation system flAF)   and  an


 S^ttVttlrt ref^ SeC°rd I6""™*' teStS "^ c°"*ctedao      ,AF
 iHHftTA  V  Ju     • r?f"lery. tests were conducted on two  IAF systems   In







 C.I   EMISSION MEASUREMENTS



 C'1'1  .CnevrQ". U.S.A.. Inc.  Refinery  -  El  Segundo.  California  1
  anatchnnw                in the Effluent
treatment «JLm   h !   i        SyStemS are 1ncl"<*ed in the effluent
                                                                   s
                                  C-l

-------
       Dissolved   Air Flotation T-302

       (Not operating during test period)
o
                                                  Dissolved Air Flotation
                                                          T-202
                                                                                 Sampling
                                                                                 Location
                                                   Flash Mix    Flocculation Tank
                                                    T-200           T-201
                                            I
                                                                                                              2000 scfm
                                                                                                               blower
Activated
carbon beds
                                                                                                              2000 scfm
                                                                                                               bl ower
                         Fiaure C-l.  Dissolved Air Flotation System with Sample Location,

-------
                        monitoring of the DAF are shown  in Table C-l   The

  are shown In'Table'c^™'*5 1nClUd6 methane*  Gas chromatograpHy results



      The equalization basin is shown in Figure C-2.  As with the DAF thi<

  basin 1S completely covered.  Ventilation holes are located on one side of
  the basin and outlet nnrtq *™ in^*^ ™ +k "-*.:.•__..  on one side of
   te        0scct                             .        w r
    t ?n ; j'Stsr ^^^^^^^-™
  that on the DAF system.  Continuous monitoring at VOC level was conducted at

  ^^T^^U^T^rt'h??,!1""™ 6as1n and th" " ^ ^«-
                                                            the
            was calculated and used as the IAF outlet flow
 the
Ctl*2  Golden West Refinery - Santa Fe Springs  California?









blower serves to        ''''
                              C-3

-------
             TABLE C 1   SUMMARY OF DAILY EMISSION  RATE AVERAGES: CONTINUOUS  MONITORING
             TABLE C-l.  SUMMARY W^^ RERNERYj EL SEGUNDO>  CALIFORNIA
TEST DAY                 8/3/83    8/4/83    8/5/83    8/8/83    8/9/83    8/10/83     8/11/83




SAMPLE LOCATION


OAF Outlet
(Ibs/hr  Total  Hydrocarbon) 7.18      6.37      6.85      6.75      8.11       6.17        9.01
Equalization Tank

(Ibs/hr Total  Hydrocarbon)  4-lQ      4-65      4-24

-------
                TABLE C-2.  GAS CHROMATOGRAPHY RESULTS FROM DAF SYSTEM
                            CHEVRON REFINERY, EL SEGUNDO, CALIFORNIA
DATE
TIME
ANALYTICAL RESULTS
(ppmv as compound)
C-l
C-2
C-3
C-4
C**
-5
Hexane
Benzene
Heptane
Toluene
m-Xylene
o-Xylene
TOTAL HYDROCARBON
8/3
1135-
1235


46.8
5™ •
.7
6.8
3.8

1.9
10.1
11.0
10.0
39.2
6.8
3.4
8/3
1445-
1545


46.5
7.0
8.1
5.0

3.4
16.9
15.1
11.8
45.3
6.1
3.0
8/4
930-
1010


53.6
6.4
8.3
4.9

4.9
23.0
19.8
21.3
55.5
15.9
7.9
8/4
1430-
1515


45.5
5.3
6.2
4.4

3.8
15.1
13.2
6.6
32.4
7.7
3.0
^^^•••ma^^
8/5
900-
945


53.8
6.7
7.1
4 2
• • &
4.6
10.7
24.4
2.6
46.7
13.6
5.0
•
8/5
1500'
1530


58.3
6.5
8.3


0.6
18.0
35.0
44.4
10.4
3.8
                        145
         168
CONTINUOUS MONITOR
  DATA

  Hydrocarbon Level
  (ppmv as C3H8)

  Emission Rate
  Hbs/hr  Total
  Hydrocarbon)
                                           217
                            143
                                                             179
510      526


  6.69     6.;
                                              185
568      339      583      482


  8-59     4.35     7.82     6.38
                                    C-5

-------
TABLE C-2.  GAS CHROMATOGRAPHY RESULTS FROM DAF SYSTEM
            CHEVRON REFINERY, EL SEGUNDO, CALIFORNIA (Continued)
DATE
TIME
ANALYTICAL RESULTS
(ppmv as compound)
C-l
C-2
C-3
C-4
C-5
Hexane
Benzene
Heptane
Toluene
m-Xylene
o-Xylene
TOTAL HYDROCARBON
(ppmv as compound)
CONTINUOUS MONITOR
DATA
Hydrocarbon Level
(ppmv as C3H8)
Emission Rate
(Ibs/hr Total
Hydrocarbon)
8/8
1100-
1300
55.3
4.5
5.6
4.0
3.4
16.1
39.8
46.4
11.3
3.9
190

495
6.72
8/8
1500-
1530
52.9
3.9
5.0
4.8
4.0
26.2
63.6
75.1
20.7
8.2
264

580
7.87
8/9
915-
1040
37.5
2.4
2.2
3.6
4.8
12.8
49.2
28.3
17.1
6.0
22.4
186

709
9.68
8/9
1400-
1455
34.8
1.8
2.6
3.2
4.8
0
8.0
44.4
17.4
7.0
24.2
148

592
8.09
8/10
904-
1004
26.4
2.1
2.0
1.7
0
6.7
23.7
7.0
0
12.7
5.2
87

460
5.28
8/11
1315-
1415
29.2
0
2.1
6.5
9.2
19.1
55.2
0
61.5
10.0
10.2
203

622
8.2
                             C-6

-------
                    2000 scfm
                       blower
                                                                     Ventilation Holes
         Activated
         Carbon Bed
o
                      2000
                   scfm Blower
                                   Sample Location
Equalization Basin T-500
                                    Figure C-2.  Equalization Basin with Sample Location.

-------
      TABLE C-3.  GAS CHROMATOGRAPHY RESULTS FROM EQUALIZATION BASIN
                  CHEVRON REFINERY, EL SEGUNDO, CALIFORNIA
DATE
TIME

LOCATION

RUN NO.
ANALYTICAL RESULTS
(ppmv as compound)
C-l
C-2
C-3
C-4
C-5
Hexane
Benzene
Heptane
Toluene
m-Xylene
o-Xy1ene
8/3
1600-
1700


1

27.0
2.0
0
0
0
0
7.7
29.2
4.6
1.7
8/4
1053-
1235

Venti
1

29.4
1.2
0
0
0
2.3
9.7
25.5
4.0
1.5
8/4
1431-
1510

lation air
2

24.6
0
0
0
0
2.1
4.9
13.6
1.7
0
8/5
930-
1000


1

17.7
0
0
0
0
1.4
7.8
18.7
3.6
1.1
8/5
1228-
1252


2

20.4
1.8
0
0
0
2.1
12.5
29.8
7.0
2.4
8/5
1400-
1510
Carbon
house
outlet
OUT

22.3
1.6
0
0
0
0
20.4
26.8
0
TOTAL HYDROCARBON
(ppmv as compound)  72

CONTINUOUS MONITOR
  DATA

  Hydrocarbon Level
  (ppmv as C3Hg)    150
        74
         47
         50
  Emission Rate
  (Ib/hr)
4.07
        182
4.87
         167
4.45
         155
3.98
                                      76
         155
                                       3.98
                                       72
                                                179
                                        4.65
                                     C-8

-------
                            TABLE C-3.  (Continued)
 DATE

 TIME

 LOCATION


 RUN NO.

 ANALYTICAL  RESULTS
 (ppmv  as compound)
  C-l
  C-2
  C-3
  C-4
  C-5
 Hexane
 Benzene
 Heptane
 Toluene
 m-Xylene
 o-Xylene

 TOTAL HYDROCARBON
 (ppmv as compound)

CONTINUOUS MONITOR
  DATA

  Hydrocarbon Level
  (ppmv as C3H8)

  Emission Rate
  Ob/hr)
8/12/83
Ventilation
    air

     1
   15.4
    0
    0
    0
    0
    5.8
   38.6
    0
    0
   14.8
    5.6
  89
8/12/83
8/12/83
 284


   7.54
  _C_arbon house exhaust

      1               2
     24.
      0
      0
      0
      0
      0
      0
      0
     0
     0
     0
    24
 23.
  0
  0
  0
  0
  0
  0
  0
  0
  0
  0
                                     23
                  29


                   0.77
                                   C-9

-------
  -VWw-
Wastewater from API
separator
  o
   I
                                     Induced Air Flotation System
                                      Uffl
                                     OUTLET  >
                                            Jl
                                                    r
                                                           Anemometer
Flow Measurement
Adaptation
                                        Activated
                                        Carbon  Drum
       Gaseous
       Emissions
Sampling  Location
 Mobile Lab
                Figure C-3.  Induced air flotation system at Chevron -  El Segundo, California.

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      TABLE C-4.  GAS CHROMATOGRAPHY AND EMISSION RATES FROM IAF SYSTEM
                  CHEVRON REFINERY, EL SEGUNDO, CALIFORNIA
DATE                     8/11           8/11           8/12           8/12

TIME                     0924-          1213-          1213-          1040-
                         0942           1245           1254           1120

LOCATION                   Ventilation air              Carbon drum outlet

RUN NO.                   1212

ANALYTICAL RESULTS
(ppmv as compound)
 C-l                     1602           2818           2156           1762
 C-2                        7.6         3217              8.2            4.5
 C-3                       18.2         2913             21.8           12.8
 C-4                       42.0           80.5           72.1           36.4
 C-5                      283            220            510            110
 Hexane                  1288           6127           2005           2033
 Benzene                  835           2642           2101           1074
 Heptane                  826            938            793            449
 Toluene                  421              0              0              0
 m-Xylene                 252            105            385            168
 0-Xylene                 145             31.7          106             67.8

TOTAL HYDROCARBON
(ppmv as compound)       5720         19,092           8158           5717

CONTINUOUS MONITOR
  DATA

  Hydrocarbon Level
  (ppmv as C3Hg)          6950           7300           7222           6601

  Emission Rate
  (Ib/hr)                   0.20           0.21            0.18        0.16
                                    C-ll

-------
                TABLE C-5.   LIQUID SAMPLES TAKEN Ort 8/3/83 -
                            CHEVRON REFINERY, EL SEGUNDO, CALIFORNIA
                                     COD    Oil/grease   TOC    TCO
                                     mg/L      mg/L      mg/L   mg/L
Liquid Composite Samples
DAF-in

DAF-out

EQ-out


2,969
3,008
1,748

1,911
1,870

491
535
133
144
123
120

— 71. 56
—
— 30.90
—
— 21. 00

Volatile Organic Samples
DAF-in #1 VOA (1650)a                  —         —        611     —
DAF-out #1 VOA (1650)                  —         —        365     —
EQ-out VOA (1650)                      —         —        661     —

aTime sample taken.
                               (Continued)
                                 C-12

-------
             TABLE C-5.   LIQUID SAMPLES TAKEN ON 8/3/83 - CHEVRON REFINERY
                         EL  SEGUNDO,  CALIFORNIA (Continued)
                                        Compound
                                                            pq/1
Liquid Composite Samples



OAF Influent













DAF Effluent








Equilization Basin Effluent



Toluene
Cg
C9
C9
Cio
GH
C12
Ci2
Cj2
Cl2
Cl2
C12
C12
Cj3
Ci3
Cl4
Cj5
cls
Toluene
C9
CIQ
Cio
Cn
Cii
Cii
C12
Cl3
Toluene
C9
Cg
CIG
Cio
13.302
2.278
1.328
1.040
17.709
2.679
4.207
4.940
5.339
12.214
2.932
1.436
1.930
1. 487
10.496
3.128
4.838
3.570
3.066
3.643
2.595
15. 412
4.972
5.549
0.828
1.383
2.679
2.232
2.257
3.301
2.460
11.538
3.927
3.617
                                                          1.180
Note:
                         be  determined due to a co-eluting peak in the

Note:  These values were calculated  using  average
                                                            factors of
                                   C-13

-------
           TABLE C-6.  LIQUID SAMPLES TAKEN ON 8/4/83 -
                       CHEVRON REFINERY, EL SEGUNDO, CALIFORNIA
COD Oil /grease TOC
mg/L mg/L mg/L
Liquid Composite Samples
DAF-in

DAF-out


EQ-out

Volatile Organic Samples
DAF-in-VOA pm (1500)
DAF-in-VOA (1000)
DAF-out VOA pm (1500)



DAF-out VOA (1000)
EQ-out VPA (1000)
EQ-out VOA (1500)

4,024 440 —
4,228 441 —
1,545 125 —
1,585 94 —
1,565 126 —
2,033 148 —
2,155 142 —

— — 484
	 	 a
— — 478
— — 475
— — 550
— — 542
~ — 464
~ — 455
~ ~ 511
Sample lost; replaced with aliquot  from  DAF-in  liquid composite samples.
Result was 1,096 mg/L.
                                C-14

-------
                   TABLE C-7.  LIQUID SAMPLES TAKEN ON 8/5/83 -
                               CHEVRON REFINERY, EL SEGUNDO,  CALIFORNIA
                                        COD    Oil/grease   TOC     TCO
                                        mg/L      mg/L      mg/L    mg/L
 Liquid Composite Samples

 DAF"1n                                8,056     6.14        —

 DAF-out                               2>179     2 37        __

 £Q'out                                1,240     110         —

                                       1,301     109         —

 Volatile  Organic Samples

 DAF-in  VGA  (0915)                       __       _           a

 DAF-in  VGA  (1530)                       __       _         722

 DAF-out VOA (0915)                      __       _         578

 DAF-out VOA (1530)                      __       __         713

 EQ-out VOA (1530)                       __       _         60Q

EQ-out VOA (0915)                       _-       __
                                                               b
        ^7^ a!.iquot from EQ-°ut liquid  composite samples.  Results are
        ,4/6 mg/L.
                                    C-15

-------
                   TABLE C-8.   LIQUID  SAMPLES TAKEN ON 8/8/83 -
                               CHEVRON REFINERY, EL SEGUNDO, CALIFORNIA
                                        COD     Oil /grease   TOC    TCO
                                        mg/L      mg/L      mg/L   mg/L
 Liquid Composite Samples
                                                 383        —    41.94

                                      2,114      376        —      —

 DAF'°Ut                              1,470      0.21       _    22.38

 API-2 Inlet A (201)                   20.3      6.4        -     1.74

 API-2 Inlet B (202)                  2,560     65.49       -    84.00

 API-2 Inlet C (203)                    463     20 g        __     g 3Q

 API-2 Inlet D (204)                    480     26>97       _     Q ^


 API"4                                2,440     18.26       —    45.66

 Volatile Organic  Samples

 DAF-in VOA  (1100)                       __       _         538     —

 DAF-in VOA  (1500)                       _       _          a     _

 DAF-out VOA  (1100)                      __       —         622     —

 DAF-out VOA  (1500)                      __       _
                                                             b      —
 Sample  lost; replaced with aliquot from DAF-in  liquid composite samples
 TOC result  is 016 mg/L.


^Sample  lost; replaced with aliquot from DAF-out  liquid composite samples
 TOC result  is 774 mg/L.



                                   (Continued)
                                     C-16

-------
          TABLE C-8.   LIQUID SAMPLES TAKEN ON 8/8/83 -  CHEVRON  REFINERY
                      EL SEGUNDO, CALIFORNIA (Continued)
Liquid Composite Samples
                                             Compound
                    mq/1
  DAF Influent
 OAF Effluent
                                             Toluene
                                             C12
                                             Cl2
                                             C«
                                             C12
                                             16
Toluene
C9
C9
cio
                    9.920
                    2.312
                   13.518
                                                               3.
                                                               3.
                                                               1.
                      935
                      901
                      871
                   4.727
                   1.407
                   0.783
                   0.801
                   4.496
                     837
                     838
                     285
 3.136

 5.085
10.601
 3.697
 3.284
 1.210
 API #2 Influent
   (Site 202)
Toluene
C8
                                            10
                                            12
 2.571
 1.
 2.
005
065
                                                             23.039
                                                              1.
                                                              7.
                    858
                    464
                 12.990
                  5.835
                  0.932
                  0.051
                  1.153
                  4.145
                 14.226
                           (Continued)
                                    C-17

-------
      TABLE C-8.  LIQUID SAMPLES  TAKEN ON 8/8/83 - CHEVRON REFINERY,
                  EL SEGUNDO,  CALIFORNIA  (Continued)
                                            Compound            rog/1
                                              :13               13.544
                                              j"                4.316
                                              :14                8-411
                                              :!!                2.306
                                                                9.465
                                                                7.679
                                              G;;               59.638
                                              Cil               45.744
                                              Ci9               65.488

API #2 Influent                               Toluene           2.165
  (Site 203)                                  C8                1-034
                                              Toluene            6.595
API #4  Influent                               C8                ni'ftt
                                              Co                IZ.obo
                                                                 3.390
                                                                 3.291
                                                                 3.341
                                                                 8.448
                                                                 2.436
                                                                 1.395
                                                                 1.447
                                                                 7.986
                                                                 1.654
                                                                 5.173
                                                                 1.388
                                               C«               5.558
                                               ci*               4.977
                                               cj*              46.394
                                       C-18

-------
TABLE C-9.  LIQUID SAMPLES TAKEN ON 8/9/83 -
            CHEVRON REFINERY, EL SEGUNDO, CALIFORNIA

Liquid Composite Samples
OAF- out
API-2 Inlet A (201)
API-2 Inlet B (202)
API-2 Inlet C (203)
API-2 Inlet D (204)
API-4
Volatile Organic Samples
OAF- in VOA (0900)
OAF- in VOA (1342)
DAF-out VOA (0900)
DAF-out VOA (1340)
COD Oil /grease TOC
mg/L mg/L mg/L
•••••••••i—, 	
~™""*— — — — — — — _ -. -— ^_ __ ^_ ^ ^— «
1,579 154 —
693 61. 56 —
3,155 19.50 —
5,179 32.27 —
2,230 18.28 —
620 23.90 —
— ~ 482
— — 440
— — 341
— __ cnn
                                                   TCO
                                                   mg/L
                   C-19

-------
                TABLE C-10.   LIQUID  SAMPLES  TAKEN ON 8/10/83 -
                             CHEVRON REFINERY,  EL SEGUNDO, CALIFORNIA

Liquid Composite Samples
DAF-in
DAF-in
OAF-out
API-2 SP 201
API-2 SP 202
API-2 SP 203
API-2 SP 204
COD
mg/L
2,170
2,121
2,078
594
2,764
950
2,635
Oil /grease TOC
mg/L mg/L
23.80 —
53.98 —
47.75 —
33.80
42.48 —
70.03 —
32.62 —
TCO
mg/L
_
—
—
—
—
—
—
Volati1eOrganic Samples
DAF-in VOA (0920)                       —       —         619
DAF-in VOA (1600)                       —       —         471
DAF-out VOA (0920)                      —       —         546
DAF-out VOA (1600)                      —       —         511
                                      C-20

-------
TABLE C-ll.  LIQUID SAMPLES TAKEN ON 8/11/83 -
             CHEVRON REFINERY, EL SEGUNDO, CALIFORNIA
COD Oil /grease TOC TCO
mg/L mg/L mg/L mg/L
Liquid Composite Samples
DAF-in
DAF-out
lAF-in
lAF-out
API-4
API-2 SP 201
API-2 SP 202
API-2 SP 203
API-2 SP 204
Volatile Organic Samples
DAF-in VOA (0900)
DAF-in VOA (1530)
DAF-out VOA (0900)
DAF-out VOA (1530)
lAF-in VOA (1000)
lAF-in VOA (1600)
lAF-out VOA (1000)
lAF-out VOA (1600)

2,316 43.74 — 95.26
1,410 54.92 — 22.42
811 61.58 — 12.58
201 46.73 - 11.06
1,616 43.59 — 96.20
100 17.97 — 9.20
1,700 37.24 — 30.68
99 24.45 — 8.60
450 33.06 — 51.98
~ — 530 —
— — 355 —
— — 454 —
— — 343 —
~ — 64.5 —
— — 402 —
134
~ — 52.0 —
                (Continued)
                    C-21

-------
               TABLE C-ll.
LIQUID SAMPLES TAKEN ON 8/11/83 -  CHEVRON  REFINERY,
EL SEGUNDO, CALIFORNIA (Continued)
                                              Compound
                                     mg/1
Liquid Composite Samples
_._ _ .. . Toluene
DAF Influent r
vg

C8
C8

CQ
Q9
CIQ
Cio
c
Ci2
Cj.3
Cj.3

Cis

Ci.7

Q
C2o
Toluene
DAF Effluent C8
Co
Q
C
clo

C
Cl3
Toluene
IAF Influent Cg
Toluene
IAF Effluent Cg
14.141
1.211
1.471
5.429
1.901
2.553
6.035
3.027
5.068
7.398
6.526
15.370
14.351
4.388
9.436
10.194
6.915
58.459
47.247
44.281
28.031
4.430
0.838
0.805
7.528
4.021
3.658
1.375
0.852
0.920
1.549
0.668
1.334
0.581
                                 (Continued)
                                        C-22

-------
TABLE C-ll.  LIQUID SAMPLES TAKEN ON 8/11/83 -  CHEVRON REFINERY,
             EL SEGUNDO, CALIFORNIA (Continued)
                                Compound
mg/1
API #4 Influent ™uene
L8
C8
C9
C9
C9
C9
Cio
Cio
Cio
C10
CIQ
ClO
Cn
Cn
Cn
Ci2
C13
C15
Cie
ADI #2 Influent Toluene
(Site 202) cs
C9
C9
CIQ
Cio
Cn
^13
Ci3
Cis
Cl4
Cis
ADI #2 Influent Toluene
(Site 203)
39.430
28.123
11. 348
4.708
2.586
0.954
13.200
3.242
1.512
1.126
4.686
3.127
2.379
1.349
1.502
1.561
1.976
1.679
1.832
2.025
2.221
1.434
1.188
3.697
3.205
3.147
1.684
4.622
1.450
2.900
4.285
3.544
0.902

                (Continued)
                            C-23

-------
   TABLE C-ll.  LIQUID SAMPLES TAKEN ON 8/11/83 - CHEVRON REFINERY
                EL SEGUNDO,  CALIFORNIA (Continued)
                                         Compound           mg/1
API #2 Influent                          Toluene           <0.5
   (Site 204)                             Cn               4.055
                                         CM               l. 755
                                         Cn               1.505
                                         Cn               1.002
                                         Cn               1.395
                                         Cn               2.130
                                         Ci2               12.261
                                         Ci2               3.872
                                         Ci2               4.312
                                         Cis               10.914
                                         Ci4               7.363
                                         Cis               3.839
                                         C16               70.078
                            C-24

-------
TABLE C-12.  LIQUID SAMPLES TAKEN ON 8/12/83 -
             CHEVRON REFINERY, EL SEGUNDO, CALIFORNIA
COD Oil /grease TOC TCO
mg/L mg/L mg/L mg/L
Liquid Composite Samples
lAF-in
lAF-out
API-4
API-2 SP 201
API-2 SP 202
API-2 SP 203
API-2 SP 204
Volatile Orqanic Samples
lAF-in VGA (0900)
lAF-in VOA (1250)
lAF-out VOA (0900)
lAF-out VOA (1330)

320 14.14 — —
302 64.95 — —
202 26.5 — _
405 12.0 — —
1,584 70.71 — __
1,000 36.74
a ' a a a
~ — 86.0 —
— — 57.0 —
~ — 162 —
— — 46.0 —
                    C-25

-------
     Continuous monitoring of VOC from the IAF to the fired heater was
conducted at a sample point located on the outlet duct of the IAF.  The IAF
system and sample point are shown in Figure C-4.   EPA Method 25A was used in
monitoring the VOC.  Gas chromatography was used  to identify the major
volatile components of the vent stream.  A summary of the results of the
continuous monitoring of the IAF is shown in Table C-13.   The total
hydrocarbon measurements include methane.  Gas chromatography results are
shown in Table C-14.

     In addition to the gaseous samples taken at Golden West, liquid samples
of wastewater going to and from the API separators and IAF system were
obtained.  As with the samples acquired at Chevron, these samples were
analyzed for COD, oil and grease, TOC, and TCO.  The results of the analyses
are shown in Table C-15 to C-18.

C. 1.3   Phillips  Petroleum Company - Sweeny, Texas3

     The refinery wastewater system at Phillips consists of two separate
oil-wastewater separation facilities.  Wastewater generated in the  older
sections of the  refinery  is first treated  by  dual API separators  which are
followed by a dissolved air flotation  system.  Wastewater generated  by the
new process units  is  treated in  three  corrugated plate interceptor  (CPI)
type separators  which are followed  by  two  IAF systems.   The VOC emission
tests were conducted  on the two  IAF systems.

     The  IAF  systems  operate in  parallel  and  are  identical  in  size  and
structure.  Both are  designed  to be operated  gas  tight,  and each  has eight
access  doors  located  on the  sides of  the units.   In  order  to  test VOC
emissions  from  the two  systems,  the access doors were tightly  secured.   A
steady  air  flow  was  introduced into the  units using  a blower.   An outlet
location was  fabricated so  that  continuous monitoring of the  VOC
concentrations  from the  IAF  could be  measured.  Figures  C-5  and  C-6 show the
 IAF systems  and  sample  locations.

      EPA Method  25A was used  to  measure  VOC concentrations from the IAF
 systems.   A summary of the results  are shown in  Table C-19.   The total
 hydrocarbon measurements  include methane.  In addition,  gas chromatography
 (EPA Method 18)  was used  to identify  the major volatile  components of  the
 vent stream.   The gas chromatography  results are shown  in Table C-20 for the
 south IAF system and in Table  C-21 for the north IAF system.

      In addition to the gaseous samples  taken at Sweeny, liquid samples of
 wastewater going to and from the CPI  separators  and IAF  systems were
 obtained.   As with the samples acquired at Chevron and Golden West, these
 samples were analyzed for COD, oil  and grease, TOC, and  TCO.  The results  of
 the analyses are shown in Table C-22 to C-25.

                                              Text continues on Page C-51
                                     C-26

-------
       Air 9 1" H20
                                    Covered and Sealed IAF
               IAF-INLET,
o
 I
ro
 Hater
 Hater
         API-INLET
   Covered
API Separator
   Covered
API Separator
                     IAF
                      Q
                                                  Platform
                                                                         IAF-OUTLET
                                                (GAS SAMPLE)
                                                                 IAF-OUTLET
                                                                (PROCESS SAMPLE)
                                                    Open  Bays
•Fired
Heater
                                                                        Blower
                Water
              Discharge
                     Figure  C-4. Wastewater treatment facilities at Santa Fe Springs, California.

-------
      TABLE C-13.  DAILY EMISSION RATE AVERAGES AT IAF OUTLET -
                   GOLDEN WEST REFINERY, SANTA FE SPRINGS, CALIFORNIA
 Toct na..                            Average Emission Rate
 lesr uay                     (Ib/hr Total Hydrocarbon as
8/15/83                                       1.40

8/16/83                                       1.39

8/17/83                                       1.14

8/18/83                                       1.23

8/19/83                                       1.39
                                 C-28

-------
TABLE C-14.
GAS CHROMATOGRAPHY RESULTS FROM IAF SYSTEM -
GOLDEN WEST REFINERY, SANTA FE SPRINGS, CALIFORNIA
DATE
TIME

ANALYTICAL RESULTS
(ppmv as compound)
C-l
C-2
C-3
C-4
C-5
Hexane
Benzene
Toluene
m-Xylene
o-Xylene
TOTAL HYDROCARBON
(ppmv as compound)
CONTINUOUS MONITOR
DATA
Hydrocarbon Level
(ppmv as C3H8)
Emission Rate
Obs/nr Total
Hydrocarbon)
8/16
735-
835


74.0
6.8
14.2
38.6
52.0
115
1357
1346
933
326

4262



6772
1.47 .
8/16
1020-
1120


110
9.4
22.1
269
250
370
2851
2486
1458
467

8292



7104
1.54
8/16
1235-
1335


90.8
9.6
14.4
108
130
1068
2424
2321
1578
510

8253



7087
1.54
8/17
0745-
0845


138
7.8
19.0
140
183
180
1758
1629
905
305

5265



7008
1.15
8/17
1000-
1100


135
20.9
78.5
315
685
577
3638
2376
813
283

8921



8675
1.42
8/17
1153-
1253


262

122
365
341
vi A
524
w <_™
3530
2476
885
308

8813



8811
1.45
                    (Continued)
                         C-29

-------
TABLE C-14.  GAS CHROMATOGRAPHY RESULTS FROM IAF SYSTEM  -
             GOLDEN WEST REFINERY,  SANTA FE  SPRINGS,  CALIFORNIA  (Continued)
DATE
TIME

ANALYTICAL RESULTS
(ppmv as compound)
C-l
C-2
C-3
C-4
C-5
Hexane
Benzene
Toluene
ra-Xylene
o-Xylene
TOTAL HYDROCARBON
(ppmv as compound)
CONTINUOUS MONITOR
DATA
Hydrocarbon Level
(ppmv as as C3H8)
Emission Rate
(Ibs/hr Total
Hydrocarbons)
8/18
1030-
1146


44.5
3.0
4.2
10.5
14.9
49.7
547
889
647
236

2446



5975

1.08

8/18
1310-
1410


94.7
4.1
8.0
96.5
71.0
81.4
1106
166T
1164
407

4695



6725

1.21

8/19
850-
950


66.0
5.3
8.1
28.4
90.3
93.5
865
1110
640
228

3135



6205

1.37

8/19
1030-
1130


72.8
6.8
10.9
50.7
78.9
116
1236
1785
890
297

4544



6327

1.43

                                 C-30

-------
                 TABLE C-15.   LIQUID SAMPLES  TAKEN  ON  8/16/83  -   GOLDEN  WEST

                              REFINERY,  SANTA FE  SPRINGS,  CALIFORNIA
                                         COD     Oil/grease   TOC    TCO

                                         mg/L      mg/L       mg/L   mg/L

                          *

 Liquid Composite Samples



 IAF"1n                                2,323     11.31       .—   104.46

 lAF-out                                 QnQ     ,n OQ
                                         909     21.89,       —   4Q.78


 API"1n                                2,020     23.37       —   25.64

 Volatile Organic  Samples


 lAF-in  VOA (0805)                        —       _       344       __


 lAF-in VOA (1400)                        __       _
                                                           i J^JL       «•»*

 lAF-out VOA (0805)                       __                ,„
                                                           £.31       —•

IAF-out VOA (1400)
                               (continued)
                                   C-31

-------
       TABLE C-15.
LIQUID SAMPLES TAKEN ON 8/16/83 - GOLDEN WEST REFINERY,
SANTA FE SPRINGS, CALIFORNIA (Continued)
                                               Compound
                                               mg/1
.iguid Campsite Samples
  IAF  Influent
   IAF  Effluent
   API Influent
                             Toluene
                             C8
                             C10
                             CIQ
                             CIQ
                             Ci2
                             C13
                             Cis
                             Cl4
                             ClB
                             C16
                             CIT
                             C18
                             C19
                             C2o
                             C2i
                             C22

                             Toluene
                             C8
                             C9
                             C9
                             Tol uene
                             C8
                             C9
                             C10
                             Cjo
                             C12
                             C»
                             Cl4
                             Cl5
                             C16
                             Cl7
  7.611
  5.581
 28.782
  8.904
  6.967
 11.572
 12.999
  3.990
  6.041
 11.920
  5.032
229.816
 60.938
 65.569
 34.653
 34.247
 24.253

  3.721
  1.841
  0.899
 21.115
  6.998
 13.501
  1.!
    546
    632
    749
    522
    173
    765
    646
    699
    621
    ,395
                                                                  65.244
                                       C-32

-------
        TABLE C-16.  LIQUID SAMPLES TAKEN ON 8/17/83 - GOLDEN WEST REFINERY
                     SANTA FE SPRINGS, CALIFORNIA
 Liquid Composite Samples
 lAF-in
 lAF-out
 API-in
 Volatile Organic Samples
 lAF-in  VGA (0740)
 lAF-in  VOA (1300)
 lAF-out VOA (1300)
lAF-out VOA (0740)
                                        COD     Oil/grease   TOC    TCO
                                                  mg/L       mg/L    mg/L
4,089     14.09
2,328      4.59
5,628     17.6J2
—   158.5
—   109.32
—   244.30
                    554
                    426
                    323
                    137
                               (Continued)
                                  C-33

-------
TABLE 016   LIQUID  SAMPLES  TAKEN  ON  8/17/83  -  GOLDEN WEST  REFINERY,
             SANTA FE SPRINGS,  CALIFORNIA (Continued)
                                          Compound             mg/1
Liquid Composite Samples
Toluene
C7
Cg
IAF Influent £8
c»
Cg

C9
C9
C9

Q
C9
C9
C9

Cio
Cjo
Cin
Cii
Cn
Cn
Cn

Cii

Ci2
Cl2
Ci2
Cl2
Cl2
Q
c
Cl4
Cl4

ClS

Cl6
Cl7
C17
76.223
1.835
3.602
2.422
2.066
5.420
17.959
6.712
3.833
1.632
2.160
2.644
3.057
4.577
2.640
5.201 -
5.709
3.968
8.078
11.172
4.848
2.108
3.772
1.906
1.556
2.039
7.783
2.979
2.162
2.496
13.111
14.532
7.058
3.105
4.510
3.376
10.791
4.026
5.481
2.347
91.409
224.621
                         (Continued)

                                   C-34

-------
TABLE C-16.   LIQUID SAMPLES  TAKEN  ON  8/17/83  -  GOLDEN WEST REFINERY,
             SANTA FE SPRINGS,  CALIFORNIA  (Continued)
                                     Compound            ma/1
Cl8
clg
Cj9
C20
C21
C22
C23
C24

IAF Effluent glutnt
C7
C7
C8
C8
C8
C8
C8
C8
C9
C9
C9
Cg
Cg
C9
C9
Cjo
C10
Cio
CK>
Cjo
Cio
CIQ
CJQ
Cn
^11
C11
Cii
Cn
Cn
clx
cxl
Cn
87.140
84.054
110.444
73.046
90.032
73.718
46.656
55.906
30.594
50.025
0.482
0.516
0.957
0.688
0.563
2.543
10.277
3.919
1.296 '
0.628
0.618
1.126
1.611
2.743
1.290
30.117
2.226
2.117
0.971
0.588
0.889
9.658
20.001
2.108
0.666
1.663
2.282
0.674
2.144
0.726
0.916
0.681
1.092
                                                        2.921
                              C-35

-------
TABLE C-16.   LIQUID  SAMPLES  TAKEN  ON  8/17/83  - GOLDEN WEST  REFINERY,
             SANTA FE  SPRINGS,  CALIFORNIA  (Continued)
                                       Compound            mg/1
C12
C12
C12
C12
Cjs
C13
Cja
Cl4
Cl4
Cl5
Cl5
Cie
C17
Cig
C19
C2o
C21
C22
C23
C24
API Influent Toluene
C7
C7
C8
C8
C8
C8
C8
C9
C9
C9
C9
C9
C9
C9
Cjo
C!Q
CXQ
C10
Cio
Cio
Cjo
(Continued)
C-36
1.337
1.231
1.445
7.804
8.226
1.390
1.850
2.598
1.808
5.846
2.174
84.094
105.381
39.690
50.973
36.077
29.241
20.598
23.798
14.621
23.873
1.593
2.085
2.157
5.764
24.131
9.263
2.470
3.303
4.726
6.821
3.696
1.205
4.956
9.215
5.188
2.297
2.867
1.772
8.807
4.265
2.081



-------
TABLE C-16.  LIQUID SAMPLES TAKEN ON  8/17/83 - GOLDEN WEST REFINERY,
            SANTA FE SPRINGS, CALIFORNIA  (Continued)
                                       Compound              mq/1
                                          Cn                3.670
                                          Cn                1-726
                                          Cn                3.837
                                          Cn                4.716
                                          Cn                1.931
                                          Cn                1.812
                                          Cia                5.883
                                          Cn                2.842
                                          Cn                6.898
                                          C12                2.667
                                          C12                3.212
                                          C12                3.528
                                          C12                2.250
                                          C12               15.183
                                          C12               15.331
                                          C13                7.276
                                          C14               15.577
                                          C14                7.765
                                          C15                3.512
                                          C16               63.229
                                          C17              180.452
                                          C18               86.216
                                C-37

-------
 TABLE C-17.  LIQUID SAMPLES TAKEN ON 8/18/83  -  GOLDEN WEST REFINERY
              SANTA FE SPRINGS,  CALIFORNIA
                                       COD    Oil/grease   TOC    TCO
                                       mg/L      mg/L      mg/L   mg/L
Liquid Composite Samples
IAF-in
lAF-out
API-4 (1130)

1,162
1,111
1,364

31.83
16.71
15.16

— 46.48
— 34.34
— 36.04
Volatile Organic Samples
IAF-in VGA (1050)                       _       _        204      —
IAF-in VOA (1500)                       —       _        283      —
lAF-out VOA (1050)                      —       _         __      _
lAF-out VOA (1500)                      —       _        315      __
                                 C-38

-------
TABLE C-17.   LIQUID SAMPLES  TAKEN  ON  8/18/83  -  GOLDEN WEST REFINERY
             SANTA FE SPRINGS,  CALIFORNIA  (Continued)
                                           Compound            mq/1
                                            Toluene           9.752
 IAF Influent                               C8                 4.435
                                            C8                 1.832
                                            C9                 1.299
                                            C9                22.145
                                            C10               7.012
                                            C10              14.987
                                            C12               2.081
                                            C15               1.203
                                            C18              29.697

                                            Toluene           5.949
 IAF Effluent                               Cg                 £.174
                                            C9                 l!o71
                                            C9                16,975
                                            C10               5.575
                                            C10              10.822
                                            C12               0.853

 nnr T  .ci    4.                               Toluene           5.477
 API Influent                               Q                 2 531
                                            Cg                 0^971
                                            C9                 1.052
                                            C9                17.101
                                            C10               5.889
                                            C10              12.505
                                            C12               1.399
                                            Cjs               0.976
                                            C1R              25.959
                               C-39

-------
    TABLE C-18,   LIQUID  SAMPLES TAKEN ON 8/19/83 - GOLDEN WEST REFINERY
                 SANTA FE  SPRINGS, CALIFORNIA
                                       COD    Oil/grease   TOC     TCO
                                       mg/L      mg/L      mg/L    mg/L
Liquid Composite Samples
lAF-in                                1,194      348        —
lAF-out                                 830      332        —
                                        960      203r  .    ' —
API-in                                 3,482    1,321       —
Volatile Organic Samples
lAF-in VOA (0830)                       —       —         £89
lAF-in VOA (1400)                       —       —         509
lAF-out VOA (0830)                      —       —         293
lAF-out VOA (140)                       —       —         607
                                   C-40

-------
                                TOP VIEW
FROM RAPID
o
                                            i—ir-i
                                   INJEaiONS
                    P--      n       n
                                   IAF It . SOUTH
                                                           P  IAF - C
                           INTEGRATED IA6 SAMPLE POINT
EXHAUST
                      '     '  »
                            HjO/AIR INJECTIONS
                   [i       n        n	n
I      I'	II	1'	II	1
             INTEGRATED IA6 SAMPLE MINT
                                                          IT
                 mm
                                                   EXHAUST
                                                                        V S  TO IIOUXICAL TREATMENT
           PIMP
             IAF- 0
                                        HEATED SAMPLE LINES FOR
                                        CONTINUOUS TNC ANALYZERS
                               SIDE VIEW
                                   i
                                                                                                     END VIEW
                                                                 i
                        Figure C-5.   Schematic  Representation of the  IAF Process with  Sample  Points
                                       and  Induced Air  System:   Phillips  Petroleum -  Sweeny, Texas.

-------
                                              END VIEW
                       4* FLEXDUCT TO ANEMOMETER.
                       THEN TO EXHAUST
o

r\>
TEfUON LINE 10 INTECMTEO
•At SAWtING WIT
                                                                             FABRICATED METAL REDUCING
                                                                             COLLAR INSERTED IN PLACE
                                                                             OF REMOVED IAF DOOR
                                                                                  DOOR REMOVED
                                                                                           IAF UNIT
              Figure  C-6.   IAF Outlet  Sample Locations  Fabricated:   Phillips  Petroleum
                              c. .^^nt,   Tava c

-------
     TABLE C-19.  DAILY EMISSION RATE AVERAGES AT IAF OUTLETS
                  PHILLIPS PETROLEUM, SWEENY,  TEXAS
    Test Day
      Average Emission Rate
Ob/hr Total  Hydrocarbon  as C  HJ
         1             IAF
    8/15/83
    8/16/83
    8/17/83
    8/18/83
    8/19/83
     0.51
     0.47
     0.71
     0.93
    0.36
0.34
0.54
0.80
0.42
IAF #2 not on-line for monitoring on 9/19/83
                               C-43

-------
TABLE C-20.  GAS CHROMATOGRAPHY RESULTS FROM IAF #1 (SOUTH IAF) -
             PHILLIPS PETROLEUM, SWEENY, TEXAS

DATE
TIME
ANALYTICAL RESULTS
(ppmv as compound)
C-l
C-2
C-3
C-4
C-5
Hexane
Benzene
Heptane
Toluene
m-Xylene
o-Xylene
TOTAL HYDROCARBON
(ppmv as compound)
CONTINUOUS MONITOR DATA
Hydrocarbon Level
(ppmv as C3H8)
9/20/83
1500

87.2
4.9
6.7
18.4
20.4
145.3
161.1
25.9
139.4
45.4
20.7
675.4

1834
Emission Rate
(Ib/hr) (Total Hydrocarbon)0.72
9/20/83
1645

57.7
—
4.2
11.7
17.6
85.9
99.0
16.8
95.2
34.2
12.4
434.7

1577
0.62
9/21/83
1100

65.1
4.3
3.9
15.2
20.3
110.0
135.2
37.0
94.1
33.3
10.3
528.7

1625
0.67
9/21/83
1430

57.5
6.0
4.7
1.1
3.9
63.6
95.1
21.1
67.0
21.1
8.5
349.6

1508
0.62
                           (Continued)
                                C-44

-------
     TABLE  C-20.   GAS  CHROMATOGRAPHY  RESULTS  FROM IAF #1  (SOUTH IAF}
                  PHILLIPS  PETROLEUM,  SWEENY,  TQAS                 J
DATE
TIME
ANALYTICAL RESULTS
(ppmv as compound)
C-l
C-2
C-3
C-4
C-5
Hexane
Benzene
.Heptane
Toluene
m-Xylene
o-Xylene
TOTAL HYDROCARBON
(ppmv as compound)
CONTINUOUS MONITOR DATA
9/22/83
0930

218.2
6.2
5.6
21.2
52.4
352.2
353.4
—
217.4
118.4
43.2
1388.2

-
9/22/83
1430

197.5
5.7
6.0
15.5
16.2
213.5
201.1
78.7
140.2
62.4
18.9
955.7

9/23/83
0915

115.7
4.0
2.7
4.6
10.5
41.3
60.9
20.2
53.7
26.2
10.0
349.8

Hydrocarbon Level
(ppmv as C3H8)
3358
Emission Rate
(Ib/hr) (Total Hydrocarbon)!.41
2087


   0.87
                          1199


                             0.41
                                C-45

-------
         TABLE C-21    GAS CHROMATOGRAPHY RESULTS FROM IAF #2 (NORTH IAF) -
                      PHILLIPS PETROLEUM, SWEENY, TEXAS
DATE
TIME
ANALYTICAL RESULTS
(ppmv as compound)
C-l
C-2
C-3
C-4
C-5
Hexane
Benzene
Heptane
Toluene
m-Xylene
o-Xylene
TOTAL HYDROCARBON
(ppmv as compound)
CONTINUOUS MONITOR
Hydrocarbon Level
(ppmv as C3H8)
Emission Rate
(lb/hr)(Total
Hydrocarbon)
9/21/83
0930

58.7
4.2
4.4
17.5
21.5
128.5
134.3
35.9
. 84.0
26.1
8.1
523.2
DATA
1739
0.55
9/21/83
1545

78.6
7.5
5.9
22.6
10.5
133.7
171.8
46.6
116.5
43.9
13.6
651.2

2319
0.74
9/22/83
1050

226.2
7.3
5.6
21.5
59.5
292.5
287.0
113.1
178.2
73.9
20.0
1284.8

3428
1.11
9/22/83
1550

167.2
3.8
3.6
8.6
7.7
109.7
122.4
50.2
96.5
46.9
14.5
631.1

2892
0.94
9/23/83
1015

93.0
3.4
2.2
3.5
8.9
33.1
53.4
20.3
52.2
26.1
8.5
251.2

1278
0.52
IAF #2 not monitored on 9/20/83 during Run No.  1 and Run No. 2.
                                       C-46

-------
            TABLE C-22.  LIQUID SAMPLES TAKEN ON 9/20/83 -
                         PHILLIPS PETROLEUM, SWEENY, TEXAS

Liquid Composite and Grab Samples
IAF #2-out-D
IAF #l-out-C
lAF-inlet-A1
CPI-3-in (1700)
CPI-2-out (1700)
CPI-2-out (1700)
CPI-3-in (1700)
Void of Air Samples
COD
mg/1
539.3
628.4
4221.8
2061.4
681.2
2267.1
2810.7

Oil/grease
mg/1
40.6
150.1
3059.5
1065. 1
69.6
121.0
339.9

TOC
mg/1








 CPI-2-out (1813)
 IAF  #2-out-C  (1830)
 CPI-3-in  (1700)
 lAF-in-A  (1830)
 IAF  #2-out-C  (1030)
 CPI-2-in  (1700)
 lAF-in-A  (1030)
 CPI-l-in  (1700)
CPI-3-out (1700)
IAF #2-out-D (1830)
IAF #l-out-C (1030)
 502.5
 308.5
 205
 478.5
 107
 664.5
 358
 478.5
 204
 138
229.5
                                     C-47

-------
              TABLE C-23.  LIQUID' SAMPLES TAKEN ON 9/21/83 -
                           PHILLIPS PETROLEUM,  SWEENY,  TEXAS
  Liquid Composite and Grah
  CPI-3-out (0930)
  CPI-2-in (0945)
  CPI-l-in (0945)
  lAF-in-A1
  IAF #2-out-D
  IAF #l-out-C
  CPI-2-inlet  (0945)
  CPI-1-out  (0930)
  CPI-3-out  (0930)
  Void of  Air  Samples
  CPI-l-in (1600)
  CPI-3-in (1600)
  CPI-2-in (1600)
 CPI-2-out (1600)
 CPI-3-out (1600)
 CPI-1-out (1600)
 CPI-2-inlet (0945)
 IAF #2-out-D  (1445)
 IAF #l-out-C  (0855)
 CPI-1-inlet (0945)
 lAF-in-A  (0855)
 IAF #2-out-D  (0855)
 CPI-2-outlet  (0930)
 CPI-3-outlet  (0930)
 CPI-3-inlet (0945)
 IAF #l-out-C  (1445)
 IAF-in-A1  (1445)
CPI-1-outlet (0930)
                                               COD
                                               mg/1
 1991.0
 2149.1
 2697.8
 1476.6
 2300.7
 1369.5
 1042.7
2114.8
2395.0
            Oil/grease
               mg/1
 269.6
 267.4
 687.7
 126.0
 34.2
 58.0
 40.5
168.3
209.4
                TOC
                mg/1
                           310
                           259
                           250
                           157.5
                           198
                           549
                           36
                          218.5
                          129.5
                          155.5
                          237
                          226.5
                          223.5
                          194.5
                          451.5
                          242
                          278
                         262.5
                                     C-48

-------
TABLE C-24.  LIQUID SAMPLES TAKEN ON 9/22/83
             PHILLIPS PETROLEUM, SWEENY, TEXAS


"' " ™ ' - •- 1 — -
Liquid Composite and Grab Sample
CPI #3-out1et (0930)
lAF-in-A1
IAF-#l-out-C
CPI-#l-inlet (0940)
CPI-#l-outlet (0930)
CPI-#3-inlet (0940)
CPI-#2- inlet (0940)
CPI-#2-outlet (0940)
IAF-#2-out-D
Void of Air Samples
CPI-#3-outlet (0920)

IAF-#2-out-D (0920)
CPI-#2-outlet (1600)
CPI-#2-inlet (1600)
CPI-#2-inlet (0930)

IAF-#l-out-C (0920)
IAF-#l-out-C (1600)

IAF-in-A' (0920)

CPI-#l-out1et (0920)
CPI-#2-out1et (0920)

CPI-#l-in1et (1600)
IAF-in-A' (1600)
CPI-#3-outlet (1600)

IAF-#2-out-D (1600)
CPI-#l-outlet (1600)
CPI-#3-inlet (1600)

CPI-#l-inlet (0930)
CPI-#3-inlet (0930)
COD Oil/grease TOC
mg/1 mg/1 mg/1
« j < •

3000.5 232.5
2941.7 262.8
1312.9 152.3
1811.2 32.1
3400.2 705.3
2290.5 31.7
2065.1 34.8
5045.2 4293.6
1140.3 74.4

T f\ *°l C
192. 5
410
80
199.5
^ f\ /^ r
302. 5
366
C ft f> f
688. 5

531. 5
146.5

194 5
±*J ~ i <•/
166
274

242 5
<• T^ t_ • *J
335
*/*/^
396
f\^ f\ f
210 5
t» JL w • <•<
297
<• — ' /
*inr»
                      C-49

-------
TABLE C-25.  LIQUID SAMPLES TAKEN ON 9/23/83
             PHILLIPS PETROLEUM, SWEENY, TEXAS

Liquid Composite and Grab Samples
CPI-#3-outlet (1000)
lAF-in-A1
CPI-#l-inlet (0930)
CPI-#2-inlet (0930)
CPI-#3-outlet (1000)
CPI-#3-inlet (0930)
CPI-#l-outlet (1000)
CPI-#2-outlet (0930)
IAF-#2-out-D
IAF-#l-out-C
Void of Air Samples
CPI-#3-in (1000)
CPI-#l-outlet (1000)
IAF-in-A' (0900)
CPI-#2-outlet (1000)
IAF-#2-out-D (0900)
lAF-tt-out-C (0900)
CPI-#3-out1et (1000)
CPI-#l-in (1000)
CPI-#2-in (1000)
COD
mg/1
1503.3
160.9
1604.4
29194
1352.2
1135.2
2230.3
2354.4
1927.6
1910.7









Oil/grease
mg/1
469.4
250 ..0
107.4
10617
90.0
48.3
405.6
336.2
21.2
26.6









TOC
mg/1
••









204.5
105
224.5
444.5
248
225.5
251
107
153.5
                           C-50

-------
C.2  VOC SCREENING OF PROCESS DRAINS

     Process drains at three refineries were screened using a portable VOC
analyzer.  Process drains were screened at Phillips Petroleum in Sweeny,
Texas, Golden West in Santa Fe Springs, California, and Total Petroleum in
Alma, Michigan.

     At Phillips Petroleum, the process drains are sealed with steel  caps.
The caps have a handle for manual  removal  and rest on supports over the
drain inlet.  The drain inlet consists of a circular sump about 6-8 inches
deep and about 12 inches in diameter.   Within the sump is the opening of the
vertical drain pipe which connects below grade to the drain line for the
process unit.  A water seal is formed  between the inside annulus formed by
the drain pipe and the side of the cap, and the cap side and circular watts
of the sump.

     Screening values were taken at each drain while the drain was capped.
These screening values represent emissions from controlled drains.  The caps
were then removed and left off for a period of time.  The screening values
recorded after the cap had been removed for a period of time represented
emissions from uncontrolled drains.  Only drains that were properly sealed
and maintained were included in the analysis.

     The screening values of the controlled and uncontrolled drains can be
converted to leak rates (Ibs VOC/hr) using the correlation established in an
EPA study of atmospheric emissions from petroleum refineries.1  This
correlation is as follows:

     Log1Q (Non Methane Leak) = -4.0 + 1.10 Log1Q (Max. Screening Value)

A summary of the screening values  is given in Table C-26.

     Process drains were also screened at Golden West (Santa Fe Springs,
California) and Total Petroleum (Alma, Michigan).  The process drains at
Golden West are designed with water seals.  However, it was difficult to
determine if the water seals were  being maintained at the time of the
screening.  The process drains at  Total Petroleum were not sealed.
Summaries of the screening results from these refineries are given in
Tables C-27 and C-28.
                                   C-51

-------
                    TABLE C-26.
SUMMARY OF EMISSION RATES AND EMISSION REDUCTION FOR DRAINS

WITH A LEAK RATE GREATER THAN 100 PPM (PHILLIPS PETROLEUM, SWEENY, TEXAS)
o
en
ro
Drain
Unit No.
27.1 6
7
17
26.2 3
27.2 1
2
3
11

12
25 11
19
23
69
83
84
85
86
94

Screening Values
Cap On Cap Off*
12
10
10
4
40
2,000
7
50
40
10
8
120
20
12
7
70
70
1,000
8

1,000
100
120
100
110
1,750
300
300
400
178
300
400
120
150
200
100
300
1,500
150

Estimated
Emission Rate, LB/HR
Cap On Cap Off*
0.00019
0.00016
0.00016
0.00005
0.00073
0.05384
0.00011
0.00083

0.00016
0.00012
0.00244
0.00034
0.00019
0.00011
0.00135
0.00135
0.02512
0.00012
0.08737
0.02512
0.00200
0.00244
0.00200
0.00222
0.04649
0.00668
0.00792

0.00376
0.00668
0.00917
0.00244
0.00312
0.00428
0.00200
0.00668
0.03924
0.00312
0.17536
Est. Emission
Reduction
LB/HR %
0.02493
0.00184
0.00228
0.00195
0.00149
-0.00735
0.00657
0.00709

0.00360
0.00656
0.00673
0.00210
0.00293
0.00417
0.00065
0.00533
0.01412
0.00300
0.08800
99.2
91.8
93.4
97.5
66.9
-15.8
98.4
89.5

97.3
98.2
73.4
86.1
93.8
97.4
32.5
79.8
36.0
96.2
5U700

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TABLE C-27.  SUMMARY OF PROCESS DRAIN SCREENING -  GOLDEN  WEST REFINERY,
             SANTA FE SPRINGS, CALIFORNIA

Drain
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
Total Drains Screened
Average Screening Value
Avg. Non-Methane Leak Rate
Screening Value (ppmv)
30
30
70
20
15
15
20
10
10
70
.
700
15
30
70
10
20
10
50
_
_
10,000
10,000
10,000
300
200
50
700
500
1,000
30
150
.
10,000
20
15
20
15
10
80
20
20
40
50
10
10
15
10
10
49
725
= 0.064 kg VOC/hr
                                  C-53

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TABLE C-28.
SUMMARY OF PROCESS DRAINS SCREENING
TOTAL PETROLEUM, ALMA, MICHIGAN
Drain
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
Total Drains Screened
Average Screening Value
Avg. Non-Methane Leak Rate
Screening Value (ppmv)
800
0
0
120
260
0
0
-
0
180
10,000
10,000
4,500
1,000
10,000
10,000
0
0
640
450
3,500
710,000
0
3,000
60
1,000
10
10
10
50
3,500
150
10
10
10
10
10
10
10
10
10
10
10
100
600
10
50
200
48
= 1470
= 0.14 kg VOC/hr
                                C-54

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    References
       fnu         P™tecti°n A9ency.   Emission  Test  Report.  Petroleum

     Se^ndoy EffSET/^JrrS4 SyStem'  Chevro"  U'S-A"  Incorporated  H
     Segundo, California).   TRW Environmental  Operations.   Research Triarm P
     Park, North Carolina.   EMB Report No.  83WWS2.  March  1984      Tna"9'e
     D f     ,,         Protection  Agency.   Emission Test Report   Petroleum

     ^i!Jr?pH;St?WaterrT^JtinenSSysteDI' Golden West Refining Company  e
     Itesearch TrianT*  Callforrna)'   TRW Environmental Operations.
     March 1984.    9 e   ar '   ort   arolina.  EMB"
3.
        ironmental  Protection  Agency.   Emission Test Report.  Petroleum
(SweenY  ?£«?a%Jrftment  ^™> Phillips Petroleum Company
£%  M*  IuXrS)'-,.TRW Envi™nmental Operations.  Research Trianqle
Park, North Carolina.   EMB Report No. 83WWS3.  March 1984  nangle
                                 C-55

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              PETROLEUM REFINERY WASTEWATER TREATMENT SYSTEMS
        APPENDIX D:   EMISSION MEASUREMENT AND CONTINUOUS MONITORING

 U.I  INTRODUCTION

      This appendix  describes the measurement method experience that was
 gained during the emission testing portion of this study, the potential
 continuous monitoring procedures, and the recommended performance test
 procedures.   The purpose of this appendix is to define the methodologies
 used to collect the data to support a new source performance standard, to
 recommend procedures to demonstrate compliance with a standard,  and to
 describe alternatives for monitoring either process parameters or emissions
 to indicate  continued compliance with a standard.

 D.2  EMISSION MEASUREMENT EXPERIENCE

      Tne purpose of the field study in this project was to provide estimates
 of the organic compound release rates from several  types of devices used in
 wastewater treatment plants.   There was insufficient information  available
 to estimate  the uncontrolled volatile organic compound emission  rate from
 induced air  flotation devices,  dissolved air flotation devices,  and equali-
 zation basins.   Testing was performed at three refineries that use these
 devices.   However,  the  true "uncontrolled"  emission  rate could not be
 measured because none of the  devices were open directly to the atmosphere.
 All  of the devices  were equipped with a cover,  and  four of the six devices
 tested were  equipped with  an  add-on emission control  system.   These devices
 were selected for testing  because the organic  compounds released  from  the
 wastewater in the device were or could  be collected  in a duct  or  vent  and
 the  mass  flow rate  could be measured.   This  approach  was used  to  estimate
 what the  emission rate  would  have been  from  an  uncovered device because  of
 the  difficulty  of measuring a dispersed fugitive emission.   It is  necessary
 to  assume  that  the  dominant factors  affecting  the organic  emission  rates
 from these type  devices  are wastewater  and  device-related,  and that
 meteorological  variables such as  air  temperature and  wind  speed are  secondary
 parameters.

     Tests were  conducted  at one  dissolved air  flotation  (DAF) unit, three
 induced air flotation (IAF) units,  and  one equalization  basin.   These tests
 included measurements of the gaseous  flow rate  and organic content,  and
 various tests to characterize the wastewater organic  content before  and
 after the  treatment units.  Screening surveys were conducted on the  drain
 systems in various process  units  at three refineries  to  estimate the occur-
 rence of the  fugitive emissions  for various  drain designs.  Emission rate
measurements were not made  for drains, junction boxes, oil/water separators
 and  uncovered or open primary or  secondary treatment processes.
                                  D-l

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 D.2.1  Air Flotation and Equalization Basin  Tests

      The procedures used to characterize the emissions prior to control  at the
 two types of air flotation devices and the covered equalization basin were similar
 and are discussed below in terms of the parameters that were measured.

      D.2.1.1  Vent Gas  Flow Rate.   At the  dissolved air flotation  unit,  the
 equalization basin, and one of  the induced air  flotation devices  the covered
 head spaces were ventilated by  induced draft blowers.   At the units  with
 relatively high flow rates, EPA Method 2 (see Reference 1)  was used  to measure
 the gas velocity.   This method  is  based on the  use of  a pi tot tube to traverse
 the flow area to calculate an average gas  velocity.  The gas density was cal-
 culated based on a fixed gas (02,  C02,  N2, CO)  analysis by  gas chromatography
 with thermal  conductivity detection.   Using  the duct area,  the gas volumetric
 flow rate was calculated.  Since the  blowers operated  at constant  speed  with
 no  changes in the  ventilation area,  the measured flows were relatively constant
 No  problems were experienced using Method  2  at  these sources.

      At one IAF that was equipped  with  an  induced draft blower,  the  flow rate
 was expected to be too  low to measure  with a pi tot tube,  so a  positive
 displacement volumetric flow meter was  installed.   This procedure  is essentially
 EPA Method 2A.   Due to  a small  pressure  head and large amounts of  water  conden-
 sate,  the flow  rneter approach did  not  work.   At another IAF where  no induced
 blower  was used, a similar volumetric  flow meter (a  turbine meter) was
 installed.   It  was found that the  actual flow was  less than the  minimum
 rating  of the smallest  meter that  was  commercially  available.

      The  procedure finally used  at these two  sites was  to construct  a  flow
 meter system  using a  vane  anemometer  in  a  housing  of the  same  diameter.   This
 system  routed all  of  the vent stream through  the  anemometer at velocities
 sufficient  to be detectible  by  the anemometer,  with  a  negligible meter pressure
 differential.   This measurement  system  is  described  in  more  detail in  Reference 2.

     The  final  type  flow measurement was at  an  induced  air  flotation unit that
 normally  did  not have an  induced or a forced  ventilation system.   The  inspection
 doors on  the  unit  cover  were temporarily sealed  and a  portable blower was used
 to  establish  positive ventilation.  Flow measurements were  made using  the
 anemometer  system  described above.  No problems were encountered in the actual
 measurement of  the  flow  rate, but  it was found  that the doors could not be
 perfectly  sealed and  that  the flow supply and exhaust rates  had to be measured
 to  account  for  the  leakage at the doors.

     In summary, it was  found that for systems equipped with large capacity
 blowers,  LPA  Method 2 (pitot tube traverses)  can be used successfully to
 determine volumetric gas flow.   Where there is no forced ventilation  or the
 ventilation rate is deliberately maintained at low levels,  large volumes of
 condensate can be  present, low pressure heads may not drive a flow meter, and
 the flow rate may be below the range of commercially available volumetric flow
meters.  These conditions existed at several  facilities and commercially available
meters could not be used.  A fabricated meter based on  an anemometer  normally
used for low velocity air flows  was used with success at these difficult sources.
                                   D-2

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     D.2.1.2  Total  Organic Concentration Measurement.   Procedures similiar
to EPA Method 25A were used to measure the total  organic or hydrocarbon
concentration in the vent stream.   A sample was continuously withdrawn from
the vent stream through a heated Teflon® sample line to a flame ionization
analyzer. Propane in nitrogen mixtures were used to calibrate the analyzers.
For aliphatic and aromatic hydrocarbons, such as are expected at a refinery,
the total instrument response is relatively proportional to carbon content
and can be used as a measure of total hydrocarbon concentration.  The result
of this measurement is a gaseous hydrocarbon equivalent concentration as
propane.  The molar density of propane was used to calculate a mass per unit
volume result.

     The analyzers were zeroed and calibrated with propane standards before,
during, and after testing each day.  For those systems that operated con-
tinuously during a multiple-day test, calibrations were performed at 4- to
8-hour intervals.  The zero and calibration drifts were within the acceptable
range in Method 25A.

     The only problems encountered with the use of this method was the eventual
condensation of high molecular weight organic aerosols in the instruments which
led to instability, noise, and flameout.  When these conditions occurred, the
instruments had to be purged with clean air until the signal stabilized.  This
problem was minimized when an instrument equipped with a totally heated
enclosure was used.

     D.2.1.3  Gaseous Organics Speciation.  Gas chromatographic techniques
were used to identify the major volatile components of the vent streams prior
to control.  The basic techniques described by EPA Method 18 were used.  An
integrated sample was collected into an inert, flexible plastic bag and these
samples were analyzed by two chromatograph systems.  The purpose of these
determinations was to identify the major components and to estimate an average
flame ionization response factor to evaluate the carbon proportionality of
the total hydrocarbon analyzer result.

     One of the gas chromatograph systems was used to separate methane through
pentane.  The calibration mixture for this analyzer consisted of GI - Cs species
so that specific identification and quantification was possible.  The second
system was used to separate higher boiling point compounds in the range of Ce
to Cg.  Benzene and m-xylene were used as calibration species.  Specific identi-
fication and quantification was possible for these two compounds.  The other
compounds were identified by retention time and quantified by using the closer
(benzene or xylene) calibration factor based on the number of carbon atoms in
the molecule.

      No specific problems were encountered in conducting these tests.  The
collection of the samples into bags was straightforward.  In some cases,
condensate was observed in the bags, but analysis of this material indicated
negligible organic content.  The only uncertainty is whether or not any sig-
nificant amounts of compounds with a higher boiling point than Cg were present.
This is unlikely because of the relatively high boiling points of compounds
heavier than Cg, and the relatively low source temperatures.
                                   D-3

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      0.2.1.4   Wastewater  Sampling and Analysis.  Water  samples were  collected
 before  and  after  the wastewater  treatment  devices  that  were  tested In order
 to  characterize the wastewater and to determine  if there were any simple
 tests that  could  be used  as an indicator of expected hydrocarbon emission
 rates.

      Samples were collected using techniques  similar to those used by the
 refineries  for process operation control.  Composites were made from individual
 grab  samples taken periodically  during in  the test day.  The composite sample
 volume  was  approximately  1 gallon.  The samples were stored  and shipped on ice
 to  minimize the loss of volatile components.  Additional samples were collected
 into  void-of-air  (VOA) vials where all the head space could  be eliminated to
 obtain  a  sample for total carbon analysis.

      No specific  problems were encountered with the collection of samples from
 flowing streams in pipes.  Where samples had to be collected from a  quiescent
 pool  (e.g., an API separator forebay), there is some uncertainty about the
 representativeness of a dipped grab sample.  During sample shipment, several
 of  the  void-of-air (VOA)  sample vials were broken  because of freezing.  Since
 no  expansion area was left in the bottle, the container broke when the sample
 remained  in direct contact with ice for extended periods.  Also, it  is possible
 that  during a storage period of several  weeks, coagulation and settling occurred
 so  that a homogenous mixture could not be regenerated for analysis.  This
 problem may not have occurred if the analysis had  been  performed within 1 day
 and the samples could have been stored at nearly ambient conditions.

      The water samples were analyzed for total organic  carbon, chemical oxygen
 demand, oil and grease, total  chromatographical organics (organic speciation),
 and volatile organics by a purge and trap technique.

      Total organic carbon was determined using an  automatic analyzer that
measures the carbon dioxide resulting from the photochemical  oxidation of
organic carbon after the inorganic carbon has been removed by purging.  This
procedure does not measure the volatile compounds  that  are removed by the purge
 stream.    Variation can also be caused by nonrepresentative collection of heavy
organics in the aliquot transfer syringe used to inject the sample into the
analyzer.

     The chemical  oxygen demand method is based on the quantity of oxygen
required to oxidize the organic matter in the sample under controlled conditions.
Organic and oxidizable inorganic carbon  is measured.  Volatile straight chain
aliphatics are not appreciably oxidized,  partly due to their presence as
volatiles in the head space where they do not come into contact with the
oxidizing liquid.

     Oil and grease content was determined by a gravimetric determination of
fluorocarbon-113 extract!ble compounds.   The solvent evaporation step of the
process removes short chain hydrocarbons  and simple aromatics due to evaporation.

     Total chromatographicable organics  was performed by gas chromatography with
flame ionization detection.   The sample  was prepared by extracting the water
with methylene chloride and injecting the extract to the chromatograph.   This


                                  D-4

-------
  procedure allowed speciation of C7 to C25 compounds.   A solvent volume  reduction
  step in the analysis tends to volatilize short straight chain  aliphatics  and
  simple aromatics with a boiling point less than 100°C,

       The purge and trap procedure used was EPA Method  624  (see Reference  5)
  with component identification by mass spectrometry.             "ererence  b)
Thn  Th.VeS*Us °f a11  the analy$es weire ni'ghly variable from day-to-day.
2?e result  a?KS t0 ^ fY °"e p™cedure that *1e1ded consistently  reason-
able results.   These were also significant variations from the results  obtained
orocefs contro?  *£?* Op?rat?rs for those Parameters that were  measured for
K con5r?hH?h  ™* sai"P1e Stora9e time and storing the sample  on  ice may
have contributed to the  inconsistencies.   Also,  all  of the routine procedures

      er
  BecauterofP?hf°rnied  *"? ? 6XClude the m°re V°latile compounds frohe result.
  Because of  these  inconsistencies, it is not possible to determine if any of the
  ^procedures would yield results that would predict hydrocarbon em?« ion
 were               * would.be necessary to determine if the inconsistencies
 were caused by field sampling, storage, or analysis techniques.
 ** th0'2'1'!- P™0655, Drain Screening Surveys.  Portable analyzers were used
 at three refiner.es to survey the unit drain systems.   The purposl of these

 ofrfuaft?vde ^^"T 'V^6 W3S a ^nlflcant differenced  the occurrence
 of fugitive emissions from drain systems of different designs.   EPA Method 21
 techniques were used.   The meter reading at the centroid of the cross-seaional
 opening to atmosphere was recorded.   A leaking source  was tentatively iSenJlfled
 when the meter reading at the source exceeded the  ambient meter reading

      There were no problems encountered in  conducting  the field tests
 However  the identification of the source of some  detected eS sslSns  ias  diffi-
 cult.   In some cases it was found that the  source  of a  detected emission  was
 an open-ended line that terminated at the drain, rather  than from  the Snder
 ground drainage  system.   Also,  since the source of the  detected emission  was"
 not necessarily  concentrated or  steady, the  variability  of a meter  "Id?™ at
 a  source was more  than  was  observed  at other  types of fugitive  emission s^ces.

 D.3  PERFORMANCE TEST METHODS

     The  specific  combination of measurements that would be necessary to
 demonstrate  compliance  depends on  the  format of a  standard   The options
 nc ude  specification of a  VOC emission concentration limit  a  VO? miss rate
 limit, or a minimum  VOC removal efficiency requirement.  The procedures
 recommended  for determination of each of these values are descVS ?n this
 section.  The estimated cost of each type of performance tesHs afso presented.

 D'3-!  VOC Concentration Measurement

     3ne, /ecpmmended VOC measurement method  is Reference Method  25A nr ?^R
  n z t on'A      r            °     aSe°US °r3a"1C <™ ™  9
;«„!  :  2-  na ^zer>  aPP1les to the measurement of total  gaseous oraanir
          ^s C0alIba?atedC?nS;Stl'n9 ?f 3lkaneS  a"d •''o.atlc^Soc.rtS    The
           I  calj Crated in terms of propane or  another  appropriate  orqanic
           A sample is extracted from the  source through a heSted sa£?e line
                                   D-5

-------
and qlass fiber filter and routed to  A  flame  ionization  analyzer  FIA).   Provi-
sions are included for eliminating the  heated sampling line  and glass  fiber
filter under some sampling conditions.   Results  are  reported as concentration
equivalents of the calibration gas or organic carbon.

     Method 25B, "Determination of Total Gaseous Organic Concentration Using
a Nondispersive Infrared Analyzer," is identical to  Method 25A except that a
different instrument is used.  Method 25B applies to the measurement of total
gaseous organic concentration of vapor consisting primarily of alkanes.  The
sample is extracted as described in Method 25A and is analyzed with a non-
dispersive infrared analyzer (NDIR).

      In both  the FIA and NDIR analysis approaches, instrument calibrations are
based on  a single reference compound.  For refinery wastewater systems propane
is  the rec^nended calibration compound.  As a  result, the  sample concentration
measurements  are on the basis of  that reference and are not necessarily true
hydrocarbon concentrations.  Calculation of  emissions on a mass basis will
not be affected because the  response of the  instruments is  proportional to
carbon content for similar compounds, which  in  this case, are crude petroleum
components.   Mass results would  be equivalent using either  the concentration
and molecular weight  based on  a  reference gas or  theTJrue concentration and
true average  molecular weight  of the hydrocarbons.  The advantage  of  using  a
 single  component calibration is  that chromatographic techniques are not
 required to isolate  and quantify the  individual  compounds  present.

      The VOC  analysis techniques discussed above  measure  total hydrocarbons
 including methane and ethane.   Chromatographic  analyses during prior  field  tests
 have indicated that significant quantities of methane and  ethane may  sometimes
 be present in the vapors  emitted.  If it is  expected  that methane  or  ethane
 is present in significant quantities,  appropriate samples  are required for
 chrLtographic analysis  to adjust the results  to a.«0"methan^n°ne^h^ls'
 "Reference Method 18:  Measurement of Gaseous Organic  Compounds  by Gas Chroma-
 tography" would be applicable for this measurement.

 D.3.2  Gas Flow Measurement

      Reference Methods 2, 2C, 2A, and 2D are recommended as applicable for
 measurement  of  gaseous flow rate.  "Method  2:  Determination of Stack Gas
  Velocity and Volumetric Flow Rate (Type S PI tot Tube)" applies when the duct
 or pipe  diameter is larger  than  12 inches and  the flow is constant and contin-
 SouS.   "Method 2C:  Determination of Stack  Gas  Velocity and  Volumetric Flow
  Rate from  Small  Stacks or Ducts  (Standard PI tot Tube)" JPPl^s when the duct
  diameter is  less than 12 inches  and the flow is  constant and continuous.   ^
  "Method 2A-   Direct  Measurement of  Gas Volume  Through  Pipes  and Small Ducts
  applies to'the measurement  of volumetric flow  where a  totalizing  gas  volume
  meter  is installed  in the  duct  and  a  direct reading is obtained.  This method
  can be  used  in the  general  temperature range of  0-50°C, with a flow  range
  dependent on the meter size.   Temperature and  pressure measurementsare made
  to correct the volume to standard conditions.   "Method 20:   Measurement of
  Gas Volume How Rate's in Small  Pipes  and Ducts"  applies when Method  2A  cannot
  be used because the vent size is too large  or  when pressure drop  restnctions
  prevent reducing the duct size to that of a volumetric meter   This  method
  incorporates the use of  a device to measure gas flow  rate  such  as an orifice,
  a venturi, or a rotameter.   The flow rate  is integrated with time to compute
                                     D-6

-------
  an average  volume  flow.   This  method  must  be  applied with  caution  to  inter-
  mittant or  variable  gas  flow rates.

  D.3.3   Mass Flow

      The VOC concentration  and volume measurements  are combined  to determine
  ^ue ?,^5 f1ow>  To determi'ne tne total  VOC mass during the entire  test period
  the VOC mass flow  is  determined for small  incremental periods; each 5-minute  '
  interva  and increment thereof when the processor is operating,  and each 15-minute
  interval  and increment thereof during non-operation.  These incremental flows are
  then summed for the entire  test period.  Because VOC concentrations and flow rate
  may vary significantly within  a brief time period,  these short incremental
  calculation  intervals are needed so that short-term variations in flow rates can
  be  properly  weighted  in  the  calculations.

  D-3-4   Emission Reduction Efficiency  Determination

      The  recommended procedures for determining the VOC concentration and gas
  flow would be performed  simultaneously at the control  device inlet and outlet
  thf rnnt!!T5nt- Wou1d.ube combined to compute a VOC mass flow before and after
  the control   device.  The mass  flows would be used to calculate a VOC removal
  c r ri c 1 c n c y •

  D.3.5   Performance Test Time and Costs
 ^      i1e"f 5 2f a Perfonnance test is specified in the applicable regulation
 and is selected to be representative for the process being tested.   Wastewater
 treatment operations are generally steady,  although there may be periods  where
 intermittent high organic content wastes are treated.   In general,  a performance
 test would consist of three to six runs, each lasting about 2 hours. perT°™ance

      It is estimated that for most operations,  the field  testing could  be
 completed in 2 to 3 days (i.e.,  two or  three 8-hour work  shifts)  with an  extra
 day for setup, instrument preparation,  and  cleanup.
 of v?  tnSL°Lc5VeSTin9  VdrieS Wlth  the  length of  the  test  and  the "unber
 ot vents  to be  tested.   The cost  is estimated at  $6,000  - $10,000  for  VOC con-
                           * °"e vent> "d $12'000 ' $15-oco f°r  t"
D.4  MONITORING SYSTEMS AND DEVICES

     The purpose of monitoring is to ensure that the emission control system is
being proper y operated and maintained after the performance test.  One can either
±±ly TlZr the r?gulated Pollutant, or instead, monitor an operational
parameter of the emission control system.  The aim is to select a relatively
inexpensive and simple method that will indicate that the facility is in con-
tinual  compliance with the standard.                       «.iniy is in con

     The use of monitoring data is the same regardless of whether the VOC outlet
concentration or an operational parameter is selected to be monitored   The

       ron?^ f6 1nSt?!Jed an? °perat1ng Pro"erl*  before the first perfomance
       Continual  surveillance is achieved by comparing the monitored value of
Tell
test.
                                  D-7

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the concentration or parameter to the value which occurred during the last
successful performance test, or alternatively, to a preselected value which is
indicative of good operation.  It is important to note that a high monitoring
value does not positively confirm that the facility is out of compliance; instead,
it indicates that the emission control system is operating in a different manner
than during the last successful performance test.

     Two types of emission reduction systems can be used to control  vent streams
from covered water treatment devices.  These are combustion and vapor processing.
Potential monitoring approaches for these control systems are discussed below.

D.4.1  Monitoring of Vapor Processing Devices

     There are presently no demonstrated continuous monitoring systems com-
mercially available which monitor vapor processor operation in the units of VOC
removal efficiency.  This monitoring would require measuring not only inlet and
exhaust VOC concentrations, but also inlet and exhaust volumetric flow rates.
An overall cost for a complete monitoring system is difficult to estimate due
to the number of component combinations possible.  The purchase and installation
cost of an entire monitoring system (including VOC concentration monitors, flow
measurement devices, recording devices, and automatic data reduction) is estimated
to be $25,000.  Operating costs are estimated at $25,000 per year.  Thus,
monitoring in the units of efficiency is not recommended due to the potentially
high cost and lack of a demonstrated monitoring system.

     Monitoring in units of mass of VOC emitted would require measurements only
at the exhaust location, as discussed above.  The cost is estimated at $12,000
for purchase and installation plus $12,500 annually for  operation, maintenance,
calibration, and reduction.

     Monitoring equipment is commercially available, however, to monitor the
operational or process variables associated with vapor control system operation.
The variable which would yield the best indication of system operation is VOC
concentration at the processor outlet.  Extremely accurate measurements would not
be required because the purpose of the monitoring is not to determine the
exact outlet emissions but rather to indicate operational and maintenance
practices regarding the vapor processor.  Thus, the accuracy of a FIA (Method
25A) type instrument is not needed, and less accurate, less costly instruments
which use different detection principles are acceptable.  Monitors for this
type of continuous VOC measurement, including a continuous recorder, typically
cost about $6,000 to purchase and install, and $6,000 annually to calibrate,
operate, maintain, and reduce the data.  To achieve representative VOC concen-
tration measurements at the processor outlet, the concentration monitoring
device should be installed in the exhaust vent at least  two equivalent stack
diameters from the exit point, and protected from any interferences due to
wind, weather, or other processes.

     The EPA does not currently have any experience with continuous monitoring
of VOC exhaust concentration of vapor processing units at wastewater treatment
units in petroleum refineries.  Therefore, performance specifications for the
sensing instruments cannot be recommended at this time.   Examples of such
specifications that were developed for sulfur dioxide and nitrogen oxides
continuous instrument systems can be found in Appendix B of 40 CFR 60.


                                  D-8

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      For some vapor processing systems, there may be another process parameter
  besides the exhaust VOC concentration which is an accurate indicator of system
  operation.  However, all acceptable process parameters for all systems cannot be
  specified.  Substituting the monitoring of vapor processing system process
  parameters for the monitoring of exhaust VOC concentration is valid and accept-
  able if it can be demonstrated that the value of the process parameter is an
  indicator of proper operation of the processing system.  Monitoring of any such
  parameters would have to be approved by enforcement officials on a case-by-case
  basis.  Parameter monitoring equipment would typically cost about $3,000 plus
  $3,000 annually to operate, maintain, periodically calibrate, and reduce the
  data into the desired format.

  D.4.2  Monitoring of Combustion Devices

      D.4.2.1  Incinerators.  Incinerators used to comply with a standard need
  to be maintained and operated properly if the standard is to be achieved on a
  continuous basis.  Continuous inlet and outlet emission monitoring would be the
  preferred method of monitoring because it would provide a continuous  direct
 measurement of actual  emissions and destruction efficiency.   However!  no continuous
 monitor measuring total  VOC has been demonstrated for incinerators controlling
 vent streams.   Moreover,  such a monitoring  system would be extremely complex
 and labor-intensive,  and it would be relatively expensive when  two monitors are
 required to ensure  that  a  certain destruction  efficiency  is  maintained.

      The incinerator operating parameters that affect performance  are  tempera-
 ture  type  of  compound,  residence time,  inlet  concentration,  and flow  regime
 Of these variables,  the  last two  have  the smallest  impact on  incinerator per-
 formance.   Residence  time  is essentially  set after  incinerator construction
 unless  the  vent  stream flow rate  is changed.   Moreover, at temperatures above
 760 C,  compound  type has little effect on combustion  efficiency.

  .    Test results and theoretical calculations  show that  lower temperatures can
 cause significant decreases in control device  efficiency.  Test results also
 indicate that  temperature increases  can also adversely affect control device
 efficiency.  In terms of cost, temperature monitors are relatively  inexpensive
 costing  less than $5,000 installed  with strip charts, and are easily and cheaply
 operated.  Given the large  effect of temperature on efficiency and the low cost
               m°n1tors' thl's Var1able is clearly an effective parameter to
     Where a combustion device is used to incinerate waste VOC streams alone
flow rate can be an important measure of destruction efficiency since it relates
directly to residence time in the combustion device.  Flow rates of fugitive
emission vent streams are typically small in comparison to other streams that
may be ducted to the same incinerator.  As a result, flow rate may not alwavs
give a reliable indication of the vent stream residence time 1n the iJclnSStor
But an indication of emission vent stream flow rate to the incinerator gives
assurance that VOC is being routed for proper destruction.  Flow rate monitors
at an estimated installed cost of less than $2,000, are inexpensive and easy to
operate.   Therefore, since flow rate monitors give an indication that organics-
laden streams are being routed for destruction and since they are inexpensive
flow rate is also an effective parameter to monitor for incinerators   Flow  '
rate meters should be installed,  calibrated,  maintained, and  operated according
                                  D-9

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to the manufacturer's specifications and should be equipped with a continuous
recorder.  They should have an accuracy of 5 percent of the flow rate being
measured and should be installed on combustion device inlets.

     D.4.2.2  Boilers or Process Heaters.   If an emissions vent stream is intro-
duced into the flame zone of a boiler or process heater., it is necessary to
know that the boiler or heater is operating and that the waste gas is being
introduced into the boiler or heater.  Maintenance of records  such as steam
production records would indicate periods  of operation.  Flow  indicators could
provide a record of flow of the vent stream to the boiler or heater.   For
smaller heat producing units less than 44  MW (150 million Btu/hr heat input),
temperature should also be measured to ensure optimum operation.  Monitoring
temperature for boilers or heaters with heat design capacities greater than 44
MW would not be necessary.  These larger units always operate  at high temperatures
(>1100°C) and stable flow rates to avoid upsets and to maximize steam generation
rates.  Maintenance of records that indicate periods of operation would be
sufficient for these larger boilers or heaters.

     D.4.2.3   Flares.  Because flares are not enclosed combustion devices, it
is not feasible to measure combustion parameters.  Moreover, temperatures and
residence times are more variable throughout the combustion zone for flares
than for enclosed devices and, therefore,  such measurements would not necessarily
provide a good indicator of flare performance even if measurable.

     The typical method of monitoring continuous operation of  a flare is visual
inspection.  However, if a flare is operating smokelessly, it  can be difficult to
determine if a flame is present, and it may take several hours to discover.  The
presence of a flame can also be determined through the use of  a heat sensing
device, such as a thermocouple or ultra-violet (U-V) beam sensor on a flare's
pilot flame.  If a flame is absent, the temperature probe can  be used to alert
the plant operator.  The cost of available thermocouple sensors ranges in price
from $800 to $3,000 per pilot.  (The more expensive sensors in this price range
have elaborate automatic relight and alarm systems.)  One drawback of thermo-
couples is that they burn out if not installed properly.  The  cost of a U-V
sensor is approximately $2,000.  However,  the U-V system would not be as accurate
as a thermocouple in indicating the presence of a flame.  The  U-V beam is
influenced by ambient infrared radiation that could affect the accuracy.
Interference between different U-V beams would make it difficult to .monitor
flares with multiple pilots.  U-V sensors are designed primarily to monitor
flames within enclosure combustion devices.  Therefore, thermocouples are a
superior monitoring methodology for flares.  To ensure that a  vent stream is
being continuously vented to a flare, a flow indicator can be  installed on the
vent stream.
                                 D-10

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D.5  REFERENCES

 1.  U. S. Environmental  Protection Agency.  Code of Federal  Regulations.
     Title 40, Part 60, Appendix A: Reference Methods.   Washington, D.C
     Office of the Federal  Register.  July 1, 1983. p.  347-558

 2.  U. S. Environmental  Protection Agency.   Emission Test Report.  Petroleum
     Refinery Wastewater  Treatment System, Chevron U.S.A., Incorporated (El
     Segundo, California).   TRW Environmental Operations.  Research  Triangle
     Park, North Carolina.   EMB Report No. 83WWS.   March 1984.

 3.  U.S.  Environmental Protection Agency.  Emission Test Report.   Petroleum
     Refinery Wastewater  Treatment System, Phillips Petroleum Company
     (Sweeny, Texas).   TRW  Environmental  Operations.   Research Triangle
     Park, North Carolina.   EMB Report No. WWS3.   March  1984.

 4.  U.  S. Environmental  Protection Agency.   Emission Test Report.  Petroleum
     Kefinery Wastewater  Treatment System, Golden  West Refining  Company
     (Santa Fe Springs, California).   TRW  Environmental  Operations.
     Research Triangle  Park,  North Carolina.   EMB  Reports  No.  WWS4
     March 1984.

 5.  U.S.  Environmental Protection Agency.  Code of Federal Regulations
     Title 40,  Part 136.  Guidelines Establishing  Test Procedures for
     the Analysis  of Pollutants—Method 624.   Washington,  D.C. Office
     of  the Federal Register. July 1,  1984. p. 227-236.
                                D-ll

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V REPORT NO.

   EPA-450/3-85-001a
4 TITLE AND SUBTITLE
                                     TECHNICAL REPORT DATA
                                               the revene
   VOC Emissions from Petroleum Refinery Wastewater Systems
  Background Information for Proposed Standards
» PERFORMING ORGAN.2AT.UN NAME AND ADDRESS
  Air Quality  Planning and Standards
  Office of Air and  Radiation
  U.S. Environmental  Protection Agency
  Research Triangle  Park.  N.P..   27711
12- SPONSORING AGENCY NAME AND ADDRESS	'
  DAA Air Quality Planning  and  Standards
  Office of Air and  Radiation
  Environmental Protection Agency
  Research Triangle  Park, N.C.  27711
                                                                . SHUNSOHING AGENCY CODE
IS. SUPPLEMENTARY NOTES
                                                               3. RECIPIENT -S ACCESSION NO.
                                                              5 REPORT DATE
                                                                  February. 1985	
                                                              6. PERFORMING ORGANIZATION CODE"


                                                              8.'PERFORMING ORGANIZATION REPORT No"
                                                              "lO. PROGRAM ELEMENT NO'."


                                                              n.CONTRACI/GRANTNO.

                                                                     68-02-3816

                                                              1~3 TYPE OF REPOHT AND PER.OD COVEREo'
                                                                     Final
 6. ABSTRACT'
                                        ou
 refinery wastewater  sy       under  he authoritv ^m?nCf -Standdrds  (NSPS) for Petroleum
 Three emission sources  in  a  petroleum refinprv^ct eC,tl0n  U1  °f  the C1ean Al> Act.
 in terms of their design and^pera?inq ch^acUi ttl %" treatme;S  s^stem ^re discussed
 volatile organic compounds  (VOC)" emissi'Sn con?rn? t^   Ct°rS arect1ng  emissions of
              for MMch
                 —"—————>—.	
                 DESCRIPTORS


^ir pollution
pollution control
Standards of performance
/OC emissions
'etroleum refineries
Wastewater treatment systems
                                	—	.
                                KEY WORDS AND DOCUMENT ANALYSIS
           • STATEMENT


nlimited
"      i..	
A. Form 2220-1 (Re». 4.77)
                                                              ENDED TERMS
                                                Air Pollution
                     e«=rv,OL,5 EC'T'CN .S OBSOLETE
  Unclassified
SECURITY CLASS ,T*is page',
  Unclassified
                          C.  COSATI f ifld/Croup


                                 13B
                                                                          "Ti. NO. OF PAGE'S"
                                                                                315

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