EFA
         United States
         Environmental Protection
         Agency
           Office of Air Quality
           Planning and Standards
           Research Triangle Park NC 27711
EPA-450/3-aS.OC'S
December 1987
         Air
VOC Emissions
From Petroleum
Refinery
Wastewater
Systems —
Background
Information for
Promulgated
Stai  lards
EIS

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                                         EPA-450/3-85-OOlb
VOC Emissions from Petroleum Refinery
  Wastewater Systems — Background
 Information for Promulgated Standards
                 Emissions Standards Division
             U.S. ENVIRONMENTAL PROTECTION AGENCY
                 Offica of Air and Radiation
             Office of Air Quality Planning and Standards
             Rasaarch Triangla Park. North Carolina 27711
                    Daeambr-

                        U,l frivfrefcmenfa? Protection Agency

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This report has been reviewed by the Emission Standards 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 (MO-35). U.S. Environmental Protection Agency, Research Triangle Park NC 27711  or from
National Technical Information Services, 5285 Port Royal Road, Springfield VA 221 61

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                        ENVIRONMENTAL  PROTECTION AGENCY

                       Background  Information  and  Final
                        Environmental  Impact Statement
                   for  Petroleum Refinery Wastewater  Systems
                                 Prepared  by:
Jack'R. Farmer
Director,  Emission Standards Division
U. S. Environmental Protection Agency
Research Triangle Park, NC  27711

1.   The standards of performance would limit emissions of volatile  organic
     compounds  (VOC) from 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."

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

3.   For additional  information contact:
     Mr. Doug Bell
     Standards Development Branch (MD-13)
     U.  S.  Environmental Protection Agency
     Research Triangle Park,  NC  27711
     Telephone:   (919)  541-5568

4.   Copies of this  document  may be obtained from:
     U.  S.  EPA Library (MD-35)
     Research Triangle Park,  NC  27711

     National  Technical  Information Service
     5285  Port Royal  Road
     Springfield,  VA   22161
                                     m

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                               TABLE  OF  CONTENTS


Section                                                                Page


1.0  SUMMARY	i_i

1.1  SUMMARY  OF CHANGES SINCE  PROPOSAL  	   1-1

1.2  SUMMARY  OF IMPACTS OF PROMULGATED  ACTION	1-5

     1.2.1  Alternatives to the Promulgated Action  	   1-5
     1.2.2  Environmental Impacts of the Promulgated Action	1-6
     1.2.3  Energy and Economic Impacts of the Promulgated Action.  .   1-6
     1.2.4  Other Considerations 	   1-6

            1.2.4.1  Irreversible and Irretrievable Commitment
                     of Resources	1-6
            1.2.4.2  Environmental and  Energy Impacts of
                     Delayed Standards  	   1-7
            1.2.4.3  Urban and Community Impacts 	  .  .   1-7


2.0  SUMMARY OF PUBLIC COMMENTS	2-1

2.1  APPLICABILITY OF THE STANDARDS	2-1

2.2  DEFINITION OF AFFECTED FACILITY AND MODIFICATION/
     RECONSTRUCTION	2-13

2.3  SELECTION OF CONTROL TECHNOLOGY 	   2-21

2.4  COST/COST EFFECTIVENESS 	   2-37

2.5  ENVIRONMENTAL AND ECONOMIC IMPACTS	2-43

2.6  MONITORING,  RECORDKEEPING, AND REPORTING REQUIREMENTS 	   2-45

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                                 1.0   SUMMARY
      On  May  4,  1987  the  Environmental  Protection Agency  (EPA)  proposed  new
 source performance standards  (NSPS)  for  petroleum  refinery wastewater systems
 (52  FR 16334)  under  the  authority  of Section  111 of  the  Clean  Air  Act.   The
 standards  limit  atmospheric emissions  of volatile  organic compounds  (VOC)
 from petroleum refinery  wastewater systems.   Public  comments were  requested
 on the proposal  in the Federal  Register.  There were 12  commenters composed
 of industry  representatives,  one industry trade association, and one equipment
 vendor.  The public  comments, along  with responses to these comments, are
 summarized in  this document.  The  comments and responses serve  as  the basis
 for  the  revisions made to the standards  between proposal and promulgation.
 1.1   SUMMARY OF  CHANGES  SINCE PROPOSAL
      In  response to  the  public  comments  and as a result of reevaluation,
 certain  changes  have been made  in  the proposed standards.  The  use of equip-
 ment, work practice, design, and operational  standards to reduce VOC emissions
 from individual wastewater system  components  has not changed.  Also, the
 aggregate facility definition remains in the  regulation, although the type of
 change that  would constitute a modification and bring an existing facility
 under the regulation has been changed.
     The following are changes made to the standards since proposal:
      (1)   all refinery wastewater treatment system components downstream of
 the oil-water separators (with the exception of slop oil facilities) have
 been excluded from coverage under the regulation.   This includes two groups
of components:   (a)  air flotation systems including dissolved air flotation
systems  (DAF's) and  induced air flotation systems  (lAF's);  and (b)  equaliza-
tion basins and other auxiliary tanks, basins, and  equipment  located between
the oil-water separator and the downstream air flotation system.
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     These two groups of components have been exempted under the final
standards based on a reevaluation of safety concerns,  emissions potential,
and cost effectiveness associated with control  of these facilities.  In the
case of DAF's, safety concerns raised by commenters cannot be overcome in a
cost-effective manner.  In the case of both DAF's and  lAF's, the overall VOC
emission reductions would be negligible without use of a closed vent system
and a vapor control device because VOC emissions would be suppressed
temporarily only to be emitted downstream of the air flotation system at
facilities which cannot be cost-effectively controlled under Section 111 of
the Clean Air Act.
     Equalization basins and other auxiliary tanks, basins and equipment
between the oil-water separator and air flotation system have been exempted
for the same reasons.  There are no cost-effective methods of VOC emissions
destruction or removal that have been demonstrated for these facilities.
Further, suppression of VOC emissions at these  points  in the treatment
process merely suppresses temporarily the VOC's downstream to be emitted at
other uncontrolled locations.
     The regulation of slop oil tanks has been  revised slightly.  Storage
vessels, including slop oil tanks and other auxiliary  tanks are now covered
under this Subpart only if they are not an affected facility under Subparts K,
Ka, or Kb of 40 CFR Part 60.  Slop oil tanks and other auxiliary tanks
covered under this NSPS are required to have a  tightly sealed fixed roof.
The requirement that slop oil be collected, stored, recycled, and transported
in an enclosed system prior to reuse, disposal, or resale remains unchanged,
except for the inclusion under the standards of oily wastewater drawn from
slop oil handling equipment.
     (2)  The requirement to ensure "no detectable emissions" from seams,
joints, seals, and gaskets on junction boxes, oil-water separators, and other
equipment having atmospheric or pressure control vents has been deleted in
the final standards.  For these vented facilities, an initial visual inspec-
tion and semiannual inspections thereafter, coupled with follow-up repairs or
maintenance,  is sufficient for monitoring purposes.  The requirement that
closed vent systems be monitored to ensure no detectable VOC emissions
(defined as 500 ppm above background levels) has not been changed.

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      (3)   The aggregate affected facility definition  included in the proposed
 standards  has been retained,  but includes two  changes.   One change is that
 air flotation systems  and  other equipment downstream  of the oil-water
 separator  are no  longer included in  the  aggregate  facility  because such
 facilities are not covered under the final  standards.   The  second change is
 that installation of a new individual  drain system rather than  any physical
 or  operational  change  is necessary to  constitute a "modification" to the
 aggregate  facility.  In this  case, individual  drain system  means all  process
 drains  connected  to  the first common downstream junction box.   If a new
 individual  drain  system is constructed that results in  increased emissions,
 the individual  drain system together with  its  ancillary downstream
 components,  to  and including  the oil-water  separators, would  be  an affected
 facility subject  to  the requirements of  Subpart QQQ.
      (4)   A new paragraph  at  Section 60.690(b) has been added to the
 regulation  concerning  modification.  This provision alters  the application of
 the definition  of modification  in the  General  Provisions (40 CFR Sec-
 tion  60.14)  such  that  the  addition of  a  new individual drain  system will be
 considered  a  modification  to  an  aggregate affected facility.  This  change
 eliminates  the  capital  expenditure exemption contained in Section  60.14(e)
 for the addition  of  new individual drain systems for aggregate facilities,
 making  the  addition  of any  new  individual drain system a modification of the
 aggregate  facility without  regard to cost.  The change also ensures, however,
 that  small  physical  or  operational changes made by the refiner that do not
 significantly increase  emissions will not trigger the applicability of the
 standards for aggregate facilities.
      (5)  The final  rule has been revised to require that vented junction
 boxes be equipped with  vent pipes having a maximum diameter of 10.2 centi-
meters  (4 inches) and a minimum length of 90 centimeters (36 inches).  This
change has been made to reduce VOC emissions from junction box vent pipes,
which are necessary to eliminate the buildup of potentially explosive vapors,
but whose dimensions can significantly affect VOC emission potential.
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     (6)  The inspection schedule for water seals in process drains has been
revised.  Drains that are kept in active wastewater collection service and
are consequently maintained by use,  as well as by precipitation and main-
tenance washing, shall be inspected  monthly, rather than weekly as proposed.
However, for drains that are removed from active service, there is no
assurance that use, precipitation, or maintenance washing will maintain the
water seal.  Consequently, a weekly  visual  or physical  inspection of the
water seal is still required.  However, if a tightly sealed cap or plug is
installed on drains that are not in  active service, then semiannual
inspections are required.
     (7)  The final rule has been clarified as to what  is required when an
oil-water separator that was already fully or partially covered at the time
of proposal is modified or reconstructed.  A modified or reconstructed
oil-water separator shall be equipped with a roof over  the entire separator
tank.  If at the time of proposal (May 4, 1987) a separator is already
equipped with a fixed roof over the  entire separator tank and the facility is
modified or reconstructed, the roof shall be tightly sealed.  If the separator
has a design capacity to treat 38 liters per second [600 gallons per minute
(gpm)] or more of refinery wastewater, the vapor space  shall be vented to a
VOC recovery or destruction control  device.  As an alternative to a fixed
roof vented to a control device, a floating roof may be installed.
     If a partial fixed roof was in  place at the time of proposal and the
oil-water separator has a design capacity to treat 38 liters per second
(600 gpm) or more, upon modification or reconstruction the remainder of the
oil-water separator shall be covered with a fixed roof and the vapor space
shall be vented to a control device.  As an alternative to a fixed roof and
control device, the partial fixed roof may be removed and the entire oil-water
separator covered with a floating roof.
     If a partial fixed roof was  in place at the time of proposal over a
portion of the  separator tank and the oil-water separator has a maximum
design capacity to treat less than 38 liters per second  (600 gpm), upon
modification or reconstruction the remainder of the separator tank shall  be
covered with either a floating roof or a tightly sealed  fixed roof, but shall
not  be required to vent vapors to a recovery or destruction device.

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      (8)   The  recordkeeping  and reporting  requirements  applicable  to  closed
 vent  systems have  been  revised to require  that certain  information  about  the
 operation  of the control device be maintained.  For facilities  using  a
 thermal  incinerator, continuous records must be maintained of the  temperature
 of the gas  stream  in the combustion zone of the incinerator.  Also, records
 of all 3-hour  periods during which the average temperature of the  gas stream
 in the combustion  zone  of the thermal incinerator is more than  28°C (50°F)
 below the  design temperature must be maintained and reported semi annually.
 Similarly,  for facilities using catalytic  incinerators, continuous records of
 the temperature of the  gas stream both upstream and downstream  of  the
 catalyst bed must  be maintained.  Also, records of all 3-hour periods during
 which the  average  temperature measured before the catalyst bed  of  a catalytic
 incinerator is more than 28°C (50°F) below the design gas stream temperature,
 and all 3-hour periods  during which the average temperature difference across
 the catalyst bed is less than 80 percent of the design temperature difference
 across the catalyst bed must be maintained and reported semi annually.  For
 facilities using a carbon adsorber, continuous records of the VOC
 concentration  level or  reading of organics of the control  device outlet
 gas stream or  inlet and outlet gas stream must be maintained.  Records of
 all 3-hour periods during which the average VOC concentration level in
 the exhaust gases of a carbon adsorber is more than 20 percent greater
 than the design concentration level  must be reported semiannually to the
 Administrator.
 1.2  SUMMARY OF IMPACTS OF PROMULGATED ACTION
 1.2.1  Alternatives to the Promulgated Action
     The regulatory alternatives are discussed in  Chapter  6 of the Volume I
 background information document (BID)  for the proposed standards
 (EPA-450/3-85-001a).   These regulatory alternatives  reflect the different
levels of emission control  that were analyzed in determining best demonstrat-
ed technology,  considering costs,  nonair quality health, and environmental
and economic impacts  for petroleum refinery wastewater systems.   These
alternatives remain the same.
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1.2.2  Environmental Impacts of the Promulgated Action
     The final standards would reduce atmospheric emissions of VOC from about
100 newly constructed process unit drain systems, 30 newly constructed
oil-water separators, 18 modified or reconstructed process drain systems, and
a small number of modified or reconstructed oil-water separators by about
2,020 megagrams (Mg) per year (2,225 tons per year) in the fifth year of
implementation.  This is about 60 Mg (65 tons) less than the proposed
standards as discussed in Chapter 7 of the Volume I BID, and reflects the
exclusion of air flotation systems from the final standards.  Implementation
of the standards will not result in any adverse solid waste impact or water
impact.  Therefore, with the changes noted in this section, the analysis of
environmental impact in Volume I of the BID now becomes the final
Environmental Impact Statement for the promulgated standards.
1.2.3  Energy and Economic Impacts of the Promulgated Action
     Energy impacts resulting from the standards are discussed in Chapter 7
of the Volume I BID and have not changed significantly since proposal.  The
economic impacts of the standards have been revised to reflect the exemption
of air flotation systems from the final rule.  The fifth year annualized
costs by model unit and regulatory alternative are summarized in Chapter 9 of
the Volume I BID.  The economic impact of the final standards is estimated to
be $1.1 million.  The economic analysis indicates that no adverse economic
impacts on projected facilities are expected to result from the standards.
1.2.4  Other Considerations
     1.2.4.1  Irreversible and Irretrievable Commitment of Resources.  The
regulatory alternatives defined in Chapter 6 of the Volume I BID would not
preclude the development of future control options nor would they curtail any
beneficial use of resources.  The alternatives do not involve short-term
environmental gains at the expense of long-term environmental losses.  The
alternatives yield successively greater short- and long-term environmental
benefits, with the alternative upon which the final standards are based
                                     1-6

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providing the greatest benefits.  Further, none of the alternatives result in
the irreversible and irretrievable commitment of resources.  No changes in
these considerations have resulted since proposal of the standards.
     1-2.4.2  Environmental and Energy Impacts of Delayed Standards.  As
discussed in Chapter 7 of the Volume I BID,  delay in the standards would
cause a similar delay in realizing the beneficial impacts associated with the
standards.  No changes in the potential  effects of delaying the standards
have occurred since proposal.
     1.2.4.3  Urban and Community Impacts.  There are no urban and community
impacts attributable to the proposed or  promulgated standards.
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                        2.0   SUMMARY OF  PUBLIC COMMENTS
     A  total  of  12  letters  commenting on the proposed standards  and  Volume  I
 of  the  BID  for the  control  of  emissions of VOC from petroleum  refinery
 wastewater  systems  were received.  A public hearing on the proposed  standards
 was not requested.  Written  comments were provided by industry representatives,
 one industry  trade  association, and one equipment vendor.  These comments
 have been recorded  and  placed  in the EPA docket for this rulemaking  (Docket
 Number  A-83-07,  Category  IV).  Table 2-1 presents a listing of all persons
 submitting  written  comments, their affiliations and addresses, and the
 recorded Docket  Item Number  assigned to each comment.
     For the  purpose of orderly presentation, the comments have been
 categorized under the following topics:
     2.1  Applicability of the Standards
     2.2  Definition of Affected Facility and Modification/Reconstruction
     2.3  Selection of  Control Technology
     2.4  Cost/Cost Effectiveness
     2.5  Environmental and  Economic Impacts
     2.6  Monitoring, Recordkeeping, and Reporting Requirements
 2.1  APPLICABILITY OF THE STANDARDS
 2.1.1   Comment:  Three  commenters questioned the need for the standards.  One
 commenter questioned the need to regulate VOC's generally when there is no
 demonstration that specific chemicals are being emitted which affect health
 and welfare, nor is there any demonstration that significant quantities of
 such chemicals are being emitted (IV-D-3,  IV-D-5,  IV-D-8).   One of the
commenters questioned whether the standards should apply outside nonattainment
areas if the concern is over ozone nonattainment (IV-D-3).   Another commenter
had the same concern,  saying that the definition of volatile organic compound
 in Section 60.691 of the proposed regulation  arbitrarily requires regulation
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TABLE 2-1.  LIST OF COMMENTERS ON THE PROPOSED STANDARDS OF PERFORMANCE  FOR
               VOC EMISSIONS FROM PETROLEUM REFINERY WASTEWATER SYSTEMS
Commenter/Affillation                                  Docket Item Number3


Neil J. Wasilk                                              IV-D-1
Environmental Representative
Sohio Oil Company
200 Public Square
Cleveland, Ohio  44114-2375

R. M. Bodin                                                 IV-D-2
Manager, Environmental Services
Citgo Petroleum Corporation
Lake Charles Operations
Box 1562
Lake Charles, Louisiana  70602

Gary M. Whipple                                             IV-D-3
Assistant Director of Environmental
  Affairs
Chemicals and Plastics Group
Union Carbide Corporation
39 Old Ridgebury Road
Danbury, Connecticut  06817-0001

B. F. Ballard,  Director                                     IV-D-4
Environment Control
Phillips Petroleum Company
12 A4 Phillips Building
Bart!esvilie, Oklahoma  74004

Allan A. Griggs, P.E.                                       IV-D-5
Project Manager
Diamond Shamrock Refining and
  Marketing Company
Post Office Box 69600
San Antonio, Texas  78269-6000
                                  Continued
                                      2-2

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   TABLE 2-1  (CONTINUED).   LIST OF COMMENTERS ON THE PROPOSED STANDARDS OF
                            PERFORMANCE FOR VOC EMISSIONS FROM PETROLEUM
                                    REFINERY WASTEWATER SYSTEMS
 Commenter/Affiliation                                   Docket Item Number3


 E. J.  Ciechon,  Esquire                                       IV-D-6
 T. T.  Zale
 Sun  Refining  and  Marketing  Company
 Ten  Penn  Center
 1801 Market Street
 Philadelphia,  Pennsylvania   19103

 Steven M. Swanson, Director                                 IV-D-7
 Health and Environmental Affairs
  Department
 American  Petroleum Institute
 1220 L Street  Northwest
 Washington, D.C.  20005

 U. V.  Henderson,  Jr.                                         IV-D-8
 Associate Director
 Environmental Affairs
 Research  and  Environmental  Affairs
  Department
 Texaco, Inc.
 Post Office Box 509
 Beacon, New York  12508

 R. W.  Hawes, Manager                                         IV-D-9
 J. R.  Britt
 Air and Water Conservation
 Manufacturing Department
 Mobil  Oil Corporation
 3225 Gallows Road
 Fairfax, Virginia  22037

J. G.  Huddle                                                 IV-D-10
Director, Environmental Control
  and  Planning
Amoco Oil Company
200 East Randolph Drive
Post Office Box 6110A
Chicago,  Illinois  60680


                                  Continued
                                      2-3

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  TABLE 2-1 (CONCLUDED).  LIST OF COMMENTERS ON THE PROPOSED STANDARDS OF
                           PERFORMANCE FOR VOC EMISSIONS FROM PETROLEUM
                                   REFINERY WASTEWATER SYSTEMS
Commenter/Affiliation                                  Docket Item Number3


Michael M. DeLeon                                           IV-D-11
Air Programs Supervisor
Tosco Corporation
Avon Refinery
Martinez, California  94553

W. L. Wagner, P.E.                                          IV-D-12
President
Petrex, Inc.
Post Office Box 907
Warren, Pennsylvania  16365
aThe docket number for this project is A-83-07.   Dockets are on file at the
 EPA's Central Docket Section.
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 of organic compounds  that are not  volatile  and/or  do  not  form photochemical
 oxidants,  until  the Administrator  makes  a determination to  exempt a compound
 (IV-D-8).   A third  commenter stated  that several aspects  of the proposed  rule
 constituted excessive regulation of  very small  sources of emissions (IV-D-5).
        Response:  Emissions  of VOC from  petroleum  refinery  wastewater  systems
 represent  a significant  source of  VOC  emissions to the atmosphere.   The EPA
 estimates  that 55.5 gigagrams (Gg) (61,123  tons) of VOC per year are emitted
 from wastewater  treatment processes  at petroleum refineries.   Petroleum
 refinery wastewater systems  are part of  the source category "Petroleum
 Refineries:   Fugitive Sources." This  source category is  included in the  EPA
 Priority List (40 CFR 60.16,  44 FR 49222, August 21,  1979,  and  as amended  by
 47 FR 31876,  July 23,  1982)  and ranks  third on  the list.  The  Priority List
 consists of categories of air pollution  sources that, in  the  EPA's  judgment,
 cause or contribute significantly  to air pollution that reasonably  may be
 anticipated  to endanger  public  health  or welfare.   No information was
 presented  to  demonstrate  that the  EPA's  judgment in listing  this  source
 category is  incorrect.   The  EPA is required by  Section 111  of the Clean Air
 Act to  promulgate standards  of  performance  for  each source  category  on the
 Priority List.
     As stated in the proposal  preamble  on  page 16337, these standards
 regulate VOC  emissions that  are precursors  to the  formation of ozone.  Ozone
 is harmful to human health and welfare.  In addition to contributing to the
 formation  of  ozone,  VOC emissions from petroleum refinery wastewater systems
 include benzene and other potentially toxic constituents such as  xylene and
 toluene.   Benzene has been listed under Section 112 of the Clean Air Act as a
 hazardous  pollutant because  benzene  emissions significantly increase the risk
 of cancer.  Emission controls on VOC's at refinery wastewater systems would
 also reduce emissions of benzene,  xylene, and toluene.
     New source performance  standards (NSPS) apply uniformly nationwide.
 Specific geographic areas would be excluded only if unreasonable  impacts
would result.  New source performance standards are not  limited only to
 attainment areas for any pollutant.  In the case of petroleum refineries,
there is no indication that unreasonable impacts will  result from regulation
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of wastewater treatment systems for refineries in any specific area.  In any
case, most refineries are located in ozone nonattainment areas, which
reinforces the need to reduce VOC's from any new, modified, or reconstructed
wastewater treatment system.
     With respect to the second commenter's concern about regulation of
nonvolatile as well as volatile compounds, EPA is convinced that the defini-
tion of VOC in the regulation does not overreach the objective of this NSPS.
Clearly, the majority of compounds found in refinery process wastewater
streams are volatile and photochemically reactive in nature.  In addition, as
stated above, most wastewater streams at refineries contain toxic con-
stituents.  The emission controls on the wastewater system would provide an
added benefit by also reducing emissions of these toxic constituents.
     Finally, with respect to the third commenter's concern about excessive
regulation of very small sources, the final standards exempt air flotation
systems because regulation of DAF's is not cost effective.  The cost and
economic impacts of regulating individual drain systems and oil-water
separators have been analyzed thoroughly and are considered reasonable.
2.1.2  Comment:  One commenter recommended that a provision be included in
the standards that would exempt facilities with oily wastewater streams
containing only heavier hydrocarbon compounds (IV-D-2).  Streams containing
only these compounds would be expected to have lower emissions than streams
containing lighter, more volatile compounds.  The commenter specifically
recommended that this exemption be in the form of a minimum vapor pressure
requirement of 1.5 psia.  Another commenter suggested that the exemption be
implemented through the use of a minimum relative volatility level (IV-D-3).
Without such an exemption, the commenters stated, the standards would impose
an economic burden on some facilities without accomplishing a significant
reduction in VOC emissions.
       Response;  A cutoff based on vapor pressure or other measure of
volatility for oily wastewater streams was considered during the development
of the proposed regulation, but was not adopted because the total vapor
pressure of the organics in the wastewater has the potential to vary widely
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 and  may change  with  wastewater loading,  composition,  and  temperature.   Among
 other factors that  influence  the  rate  of volatilization are  ambient
 temperature, wind speed  over  the  basin,  and  the  thickness of the  oil  layer.
      An industry survey  showed that  the  organic  loading can  vary  by orders  of
 magnitude  for the same wastewater system (see  Docket  A-83-07,  Item
 No.  II-B-45).   Although  there are no data to reflect  the  degree of change  in
 organic composition  of the wastewater, these changes  can  result from the
 loading variations,  upset conditions,  changes  in operation,  and the addition
 of new process  units.  For these  reasons,  a  vapor pressure cutoff has  not
 been included in the final standards.
 2.1.3   Comment:  Seven commenters  objected to  the requirement  for
 installation of fixed roofs on  DAF's.  The concerns range from poor cost
 effectiveness (mainly due to  low  emissions potential); to safety  (because of
 safety concerns, it  may  be necessary to  purge  the fixed roof to a VOC
 recovery or destruction  device);  to  operation  (roof would interfere with
 operation, reduce downstream  water quality); and to maintenance (roof would
 hinder regular  maintenance) (IV-D-1, IV-D-2, IV-D-5,  IV-D-6, IV-D-7, IV-D-9,
 IV-D-10).
        Response:  In response to these comments, EPA  undertook a  thorough
 reexamination of the technical, economic, and environmental  bases of the
 application of  the NSPS  to air  flotation systems, focusing specifically on
 the  safety problems  and  the low emission potential  of air flotation systems.
As a result of  this  reexamination, the final standards have  been  revised to
exempt  air flotation systems,  including both DAF's and lAF's.
     The analysis undertaken by the Agency included a telephone survey of
refiners with fixed  roofs installed on their DAF's,  as well  as a  review of
the responses to a telephone survey of vendors conducted prior to the
proposal.  Further,  DAF  float  disposal  methods were reviewed to evaluate
potential downstream impacts of controlling these systems.  As a result of
this analysis,  the Agency has  determined that a DAF controlled with a tightly
sealed roof may  pose safety concerns that were not  adequately addressed by
the proposed standards.   An unvented fixed roof may present an explosion and
fire hazard in  some  types of air flotation systems  due to  the buildup of
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explosive vapors inside the cover.  By purging the space beneath the fixed
roof with another gas, such as nitrogen, this safety concern can be
alleviated.  For a system with the vapor space purged and vented to a control
device, the incremental cost effectiveness was estimated to be over
$13,000/Mg ($ll,800/ton) of VOC.  Consequently, EPA concluded there is no
cost-effective method of VOC destruction or removal demonstrated for DAF's.
     Fixed roof controls on air flotation systems serve to suppress VOC emis-
sions temporarily, rather than to destroy VOC.  The VOC emissions that are
suppressed temporarily by the fixed roof system are merely transported
downstream through DAF effluent and froth.  Consequently, the 60 Mg/year
(65 tons/year) VOC emission reduction shown in Volume I of the BID actually
represents the VOC emissions suppressed temporarily by fixed roof controls on
air flotation systems, but emitted downstream at uncontrolled emission
points.
     The Agency did consider DAF froth recycling as an alternative method for
VOC control.   However, recycling has not been demonstrated to be a practical
method of froth disposal for all refiners because the froth may contain
additives such as coagulants.  The majority of refiners landfarm or landfill
froth rather than recycle it.
     Taken together, these considerations led the Agency to decide that the
focus of the standards should be on the control of emissions from individual
drain systems and oil-water separators, including slop oil tanks, rather than
on air flotation systems.  Therefore, air flotation systems are not covered
by the final  standards.
2.1.4  Comment:  One commenter stated that equalization basins located
upstream from the air flotation system should not be included in the
definition of DAF's (IV-D-2).  According to this commenter, these are very
large basins and it would be difficult to place covers on them.  A cover
could also be dangerous due to the large surface area and amount of potential
air leaks into the cover.
       Response;  Equalization basins that are part of an air flotation
system have been excluded from the final standards for essentially the same
reasons that air flotation systems themselves have been excluded (see 2.1.3
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 above).   The  recommended  method  of VOC  control  is  a fixed  roof,  which,  like
 DAF's, would  suppress  VOC emissions temporarily only to be emitted at some
 uncontrolled  location  downstream.   There  are  no cost-effective methods  of VOC
 recovery  or destruction that  have  been  demonstrated for these facilities.
 2.1.5  Comment:   Two commenters  requested clarification of the applicability
 of  the proposed  standards to  slop  oil from oil-water separators  and of  the
 requirement in the  proposed standards that slop oil  be  collected and reused
 or  disposed of in an enclosed system (IV-D-8,  IV-D-9).   The commenters  stated
 that these requirements could extend the  applicability  of  the standards to
 segments  of the  refinery  operation  beyond the wastewater system  itself,  and
 could potentially encompass the  entire  refinery in  cases where slop oil  is
 combined  with refinery feedstock.   The  commenters  suggested that the
 provision for slop  oil be dropped  unless  a technical  basis  for justifying
 such a requirement  can be demonstrated.
       Response:  The  final standards have been  revised  to  clarify the  scope
 of  the regulation of slop oil  and  slop  oil  tanks.   In the  final  standards,
 storage vessels  including slop oil  tanks  auxiliary  to oil-water  separators
 are regulated.   These  storage  vessels are  required  to be covered  with a
 tightly sealed fixed roof.  The  fixed roof can  be vented with a  pressure
 control valve which has been  set at  the maximum  pressure necessary  for  proper
 system operation, but  such that  the  pressure relief  valve  is not  venting
 continuously.  Such a  requirement  is both  technically feasible and  cost-
 effective in view of the  VOC emissions potential of  these uncovered
 facilities.
     Emissions from slop  oil are regulated  under this subpart until  the slop
 oil reenters a process unit or is disposed  of.  The  slop oil and  oily
wastewater drawn  from  slop oil handling equipment must be collected, stored,
transported,  recycled,  reused or disposed of in an enclosed system  (i.e.,  it
must not be open  to the atmosphere).  Once  slop oil  is returned to the
process,  or is disposed of, it is no longer within the scope of this
regulation.   Another limitation on the applicability of this subpart to
storage vessels  including slop oil  tanks is posed by the requirements of
Subparts  K,  Ka,  and Kb that regulate volatile organic liquid storage vessels,
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depending on the size of the facility and the vapor pressure of the liquid
being stored.  The NSPS for petroleum refinery wastewater systems does not
apply to storage vessels that are subject to the requirements of Subparts K,
Ka, or Kb, although the transportation, recycling,  reuse, or disposal of slop
oil remains subject to the NSPS for petroleum refinery wastewater systems and
must be kept in an enclosed system.
2.1.6  Comment:  Four commenters made comments related to the auxiliary
equipment in the wastewater system that is regulated by the NSPS (IV-D-7,
IV-D-8, IV-D-9, IV-D-10).  Three of the commenters  suggested that the
definition of "oil-water separator" not include operations such as holding
tanks, surge tanks, or catch basins where oil separation is incidental to the
primary function of the equipment (IV-D-7, IV-D-9,  IV-D-10).  The commenters
suggested that because the rule is based on economic analyses of emissions
from specific types of separators [conventional American Petroleum Institute
(API) and corrugated plate interceptor], the rule should be limited to only
those types of separators.
       Response:  The definition of oil-water separator in the final rule has
been clarified to include wastewater treatment equipment used to separate oil
from water consisting of a separation tank, which also includes the forebay
and other separator basins, skimmers, weirs, grit chambers, and sludge
hoppers.  Slop oil facilities including tanks are included in this term along
with storage vessels and auxiliary equipment located between individual drain
systems and the oil-water separator.  This term does not include auxiliary
equipment or storage vessels which do not come in contact with or store oily
wastewater.  Auxiliary equipment includes equipment such as holding tanks and
surge tanks.
     The rationale for this determination is that oil-water separators are
commonly used by most refineries as the first step  in refinery wastewater
treatment.  Since oil-water separators remove most  of the VOC with the
skimmed oil, the units following this process will  have lower VOC emissions.
By the same logic it follows that units that either store skimmed slop oil or
precede the oil-water separator and receive oily wastewater have similar VOC
emission potential as the oil-water separator.
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      Auxiliary equipment preceding  the oil-water  separator is  subject to the
 same  control  requirements as  the  oil-water separator.   That is,  for equipment
 having  a design capacity to treat more than 16  liters  per  second (250 gpm)  of
 refinery wastewater,  a  fixed  roof vented  to a control  device,  or a floating
 roof  is required.   For  equipment  with  a maximum design capacity  of 16 liters
 per second  (250 gpm)  or less,  a tightly sealed  cover is required or a floating
 roof  may be used.
      For portions  of  the oil-water  separator such  as the skimming mechanism
 or weirs where it  is  infeasible to  construct a  floating roof,  a  tightly
 sealed  fixed  roof  may be installed.  A tightly-sealed  fixed roof shall also
 be installed  to completely cover  other auxiliary storage vessels such as  slop
 oil tanks.  If the Agency were to allow a mixture  of regulated and unregu-
 lated components upstream of  the  oil-water  separator,  the  effectiveness  of
 the VOC emissions  control at  the  separator  would be negated.
      The rule  does exempt existing  individual drain systems  with catch basins
 in their existing  configuration,  segregated  stormwater removal systems,  surge
 tanks that  receive only  stormwater  runoff,  non-contact  cooling water  systems,
 and any other  tanks or basins which are used for storing non-VOC products
 such  as caustic or coagulant.  In addition,  storage vessels, including slop
 oil tanks,  and  other  auxiliary tanks covered under Subparts  K, Ka,  or Kb are
 exempt  from these  standards.
     Additional cost  analyses were  also performed to ensure  that  the  cost
 effectiveness  of control  for slop oil tanks  is reasonable.    The  cost
 effectiveness  of a  fixed  roof for a 13,250 liter (3,500 gallon)  and
 75,700  liter  (20,000 gallon) slop oil tank was analyzed.  The emission
 potential for  these facilities was calculated based on the VOC content of the
 slop oil.  The cost effectiveness of control was estimated to be $4/Mg
 ($3.60/ton) to $490/Mg ($445/ton)  for a fixed roof on the slop oil tanks.
The Agency considers these costs to be reasonable.
2.1.7   Comment;  One commenter questioned  at exactly what point sludge and/or
oil  is removed from a separator or air flotation system no  longer regulated
by the NSPS (IV-D-8).
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       Response:  The final rule regulates slop oil  until  the slop oil
reenters a process unit.  Until the slop oil  reenters a process unit, it must
be stored, transported, recycled, reused, or  disposed of in an enclosed
system (i.e., it must not come in contact with the atmosphere).  Once slop
oil is returned to the process, it is no longer within the scope of this
regulation.  Sludge-handling facilities and sludge (including air flotation
froth) are not subject to this NSPS,  but are  expected to be regulated under
the Resource Conservation and Recovery Act.
2.1.8  Comment:  Two commenters stated that the proposed standards improperly
include refinery wastewater systems that do not have the potential for
emitting significant amounts of VOC,  such as  facilities handling low vapor
pressure products (e.g., heavy fuel oils, lubricants, greases, and asphalts)
(IV-D-2, IV-D-8).  One commenter (IV-D-2) reported that the highest vapor
pressure for their feedstock was 0.1  psia/
       Response:  In response to this comment, EPA undertook an evaluation of
the emissions potential of facilities handling low vapor pressure products.
As part of this analysis, EPA identified typical  feedstocks, feedstock
characteristics, and other parameters that would influence VOC emissions such
as 10 percent boiling point and wastewater influent  temperature.  In estima-
ting emissions, EPA used the Litchfield method to estimate the percent volume
loss from an oil-water separator under a set  of conditions believed to be
representative of a facility handling low vapor pressure products.
     The conditions used for the Litchfield method were an ambient temperature
of 18°C (65°F), a 10 percent boiling point of 232°C  (450°F), an influent oil
concentration of 880 milligrams per liter (mg/1), and an influent wastewater
temperature of 60°C (140°F).  These conditions differ from those used in
Volume I of the BID to estimate emissions from petroleum refinery oil-water
separators in that the 10 percent boiling point is significantly higher to
account for the low vapor pressure products and the influent temperature is
also higher.  The 10 percent boiling point of 232°C (450°F) was chosen based
on a review of data received in response to a refinery survey.  The influent
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wastewater temperature of 60°C (140°F) was reported to EPA as a typical
influent wastewater temperature for these facilities.  The influent tempera-
ture is higher because of the higher temperatures necessary to process the
heavier hydrocarbons.
     Based on these data, EPA calculated a percent volume loss of
12.6 percent, which is equivalent to an emission factor of 420 Kg/million
gallons of wastewater, the same emission factor used by EPA in estimating
emissions from petroleum refinery oil-water separators.  Therefore, because
the emission potential of facilities handling low vapor pressure products is
equivalent to other refining facilities, they remain subject to the
applicability requirements of the final rule.
2.2  DEFINITION OF AFFECTED FACILITY AND MODIFICATION/RECONSTRUCTION
2.2.1  Comment:  Three commenters felt that the definition of an individual
                                         *
drain system as presented in the proposed rule was inconsistent with the
discussion in the preamble (IV-D-1, IV-D-7, IV-D-8).  The commenters stated
that the definition in the proposed rule was much more expansive than the
definition in the preamble and recommended that the definition in the proposed
regulation be revised.
       Response:  The definition of individual drain systems in the proposed
regulation was intentionally worded to include associated sewer lines and
other junction boxes that carry oily wastewater down to the receiving
treatment unit.  The definition in the proposed rule was not intended to
differ from the definition in the preamble.  The reason for including
associated sewer lines and other junction boxes down to the treatment unit is
that situations could arise where modified or reconstructed individual  drain
systems could be subject to the standards while downstream components would
not be subject to the standards.   With such a mixture of regulated and
unregulated components, the effectiveness of the control techniques for
individual drain systems would essentially be zero.  The definition for
individual drain systems in the final  rule is consistent with the definition
in the proposed regulation.
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2.2.2  Comment:  Three commenters recommended that the proposed regulation be
clarified to exclude tanks, drains, and other ancillary equipment that do not
contain oily wastewater and do not generate VOC emissions.  One commenter
suggested revising the definitions of air flotation systems and oil-water
separators to make these exemptions clear (IV-D-7).  Another commenter
specifically recommended that the requirement for water seals on all
individual drains be amended to clearly provide that only drains that receive
oily wastewater are to be controlled (IV-D-9).  A third commenter recommended
that sewers and oil-water separators for once-through cooling water be exempt
from the regulation (IV-D-1).
       Response:  The Agency did not intend for the NSPS to apply to drains,
tanks, and other ancillary equipment that do not contain or come in contact
with oily wastewater.  As stated in the proposed preamble on page 16335, the
source category to be regulated -includes "any component, piece of equipment,
or installation that receives and processes oily water from refinery process
units."  The regulation has been further clarified to exempt ancillary
equipment that is physically separate from the wastewater collection system
and does not contain or come in contact with or store oily wastewater, as
suggested by the commenters.  For example, the regulation would exempt
storage tanks for non-VOC products such as caustic or coagulant, surge tanks
that receive only stormwater runoff, and non-contact cooling water systems.
2.2.3  Comment:  Six commenters recommended that all requirements for sewer
lines be clearly defined as including "above-grade" sewer lines only (IV-D-1,
IV-D-4, IV-D-7, IV-D-8, IV-D-9, IV-D-10).  The commenters expressed concern
that the rule, as written, could be misinterpreted to mean that in-ground
sewers would have to be excavated to comply with the regulation.
       Response:  It was not EPA's intent to require excavation of buried
sewer lines to comply with the proposed standards.  As stated on page 16337
of the preamble to the proposed regulation, the purpose of the standards is
to regulate VOC emissions from petroleum refinery wastewater systems at
points where the wastewater is exposed to the atmosphere.  Therefore, all
sewer lines that are not buried underground, down to the receiving oil-water
separator, are intended to be subject to the proposed standards.  The require-
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 ment  for sewer lines  is  that  they  be  covered or enclosed  in  such  a way  as  to
 have  no visual  gaps or cracks in joints,  seals, or other  emission interfaces.
 These include  above-grade  sewer lines,  and below-grade  sewer lines that
 consist of open channels or ditches.  The definition of sewer line has  been
 clarified to exclude  buried,  below-grade  sewer lines.
 2.2.4  Comment:   Seven commenters  recommended that the  definition of an
 aggregate facility as a  separate affected facility be deleted from the
 proposed regulation (IV-D-1,  IV-D-2,  IV-D-4, IV-D-5, IV-D-6, IV-D-7, IV-D-9).
 The commenters  stated that a  wastewater treatment system  is  normally designed
 with  excess capacity  and VOC  emissions are more related to surface area than
 to oil  volume.   Further, the  commenters stated that there are no  data to show
 that  an increase  in the  loading of VOC-bearing wastes necessarily results  in
 an increase in  refinery  wastewater VOC emissions.  Therefore, in  the
 commenters"view, it  is  not appropriate to require additional controls  as  a
 result  of increased throughput or  the addition of one new pump, process
 drain,  or process unit.  The  commenters recommended that the standards  should
 be triggered only when the capacity of the wastewater system is expanded.
        Response:  The  EPA disagrees with the commenters' assertion that an
 increase  in the loading  of VOC-bearing wastes does not result in  an increase
 in refinery wastewater system VOC emissions.   Although the amount of waste-
 water surface area exposed to the atmosphere does affect emissions,  the
 concentration of VOC  in  the wastewater along with other factors, such as
 vapor pressure and temperature, are also factors  in determining the emission
 potential.  As a result,  with increases in throughput,  the volatile organic
 loading also increases when the surface area remains constant.   In EPA's
 view,  VOC emissions can  increase with increased  loading even if the capacity
 of the wastewater system (i.e., surface area)  is  not expanded.
     However,  in order to ensure that the application of the standards  to
downstream components  of the wastewater system is triggered only by
significant changes to the system that result  in  emission  increases,  EPA has
amended the definition of affected  facility  in the final regulation.  Under
the proposed rule, any physical  or  operational change made to an aggregate
facility that  resulted in an  emissions increase would have constituted  a
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modification, thereby making the standards applicable to the changed facility
and all regulated downstream components of the wastewater system.  Under the
final rule, the definition of affected facility still includes the "aggregate
facility," but the definition has been amended to clarify what constitutes a
modification that would bring downstream components under the regulation.
     In the final regulation, a new paragraph (b) has been added to
Section 60.690 that states that a modification to an aggregate affected
facility occurs when a new individual drain system (consisting of process
drains connected to the first common downstream junction box) is constructed
and tied into an existing wastewater system.  Under the final regulation, the
new individual drain system and the components of the system downstream from
the new individual drain system become an aggregate affected facility.  This
definition will lead to the control of VOC emissions from new individual
drain systems constructed to serve new process units within the refinery, as
  *
well as from those constructed to serve existing process units.
     The new paragraph (b) also specifies that the capital expenditure
exemption contained in Section 60.14(e)(2) of the General Provisions does not
apply for the addition of a new individual drain system under this
regulation.  Section 60.14(e)(2) states that an increase in the production
rate of an existing facility is not considered a modification if the increase
does not involve a capital expenditure.  A capital expenditure is considered
to be any expenditure greater than 7 percent of the total capital cost of the
facility.  The intent of the capital expenditure clause is to exclude minor
changes from coverage under the NSPS.  The addition of a new individual drain
system is considered to be an significant change to the aggregate facility
because emissions are significantly increased from downstream components of
the wastewater facility.  Therefore, under the final regulation, the addition
of a new individual drain system to an existing wastewater facility that
results in increased emissions would constitute a modification of an
aggregate facility, even if no capital expenditure is involved.  The
capital expenditure exemption is retained for all other physical or
operational changes to wastewater treatment system components.  A small
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 physical  or  operational  change within  an  existing  individual  drain  system
 (such  as  the addition  of a  pump)  that  does  not  constitute  a capital
 expenditure  on  the  aggregate  facility  would not be considered a  modification
 of  the aggregate  facility.  However, such changes  may  still constitute  a
 modification to the individual facility (i.e.,  the individual  drain  system).
 2.2.5   Comment;   Four  commenters  requested  that EPA clarify the  definitions
 of  affected  facilities for  drain  systems  and the applicability of the modifi-
 cation provisions of the standards.  As written, two commenters  (IV-D-8,
 IV-D-10)  found  it difficult to understand which modified or reconstructed
 drain  systems are required  to comply with the standards.   Similarly, a  third
 commenter (IV-D-11)  stated  that it is  not clear in  the regulation what
 triggers  the broader definition of the aggregate affected  facility  (i.e.,
 drain  system, oil-water  separator, and air  flotation system)  versus  only  the
 drain  system as the  affected facility.  This commenter stated  that the
 addition  of  one drain  or similar minor changes  should not  result in  the
 oil-water separator  and  air flotation  system becoming affected facilities.
 This commenter  suggested clarifying the regulation  to explain what situations
 would  trigger the broader definition of "affected facility" and when the
 "offsetting" of small  emission increases  through decreases elsewhere in the
 drain  system would be  allowed.  The fourth commenter (IV-D-6)  recommended
 that EPA  make clear  in the  final  regulation that modifications to refinery
 wastewater systems made  between proposal  and promulgation will not trigger
 applicability of the NSPS if those changes do not require  increases  in the
 capacity  of  the affected wastewater system.   This commenter noted that,  as
 currently written, the proposed regulation carries a risk to refiners that
 any operational  changes  or  process unit modifications which increase VOC
emissions in affected facilities,  no matter how slightly,  may  trigger
applicability of the NSPS.  This  uncertainty will have a serious impact  on
the ability of refiners to run their businesses until  the uncertainty is
removed.  According to this commenter,  refineries cannot remain competitive
if routine changes made now carry  significant future costs.
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       Response:  There are two ways in which the definition of affected
facilities includes individual  drain systems.  The first way is by making
individual drain systems affected facilities.  The second way,  which overlaps
the first, is by defining an "aggregate" affected facility as an individual
drain system together with all  downstream components of the wastewater
system.  Under either definition, the equipment standards and work practice
requirements applicable to the  individual  drain system to control  VOC
emissions are the same.  The primary distinction between the two is in the
treatment of each under the modification provisions of the standards.
     A change in an existing individual drain system which increases
emissions and involves the expenditure of more than 7 percent of the capital
cost of the individual drain system would constitute a modification under the
individual affected facility definition, making the individual  drain system
subject to the standards.  As discussed in the response to Comment 2.2.4, an
"aggregate facility" would become modified upon the construction of a new
individual drain system consisting of all  process drains connected to the
first common downstream junction box, making that system and all downstream
components of the wastewater system subject to the standards, regardless of
the capital cost incurred.
     Further, the definition of modification applicable to an "aggregate
facility" has been amended to clarify the type of change to a facility that
would trigger the application of the standards.  The addition of a new
individual drain system is a significant change to the aggregate facility
resulting in potentially significant increases in the emissions from the
wastewater system and, therefore, would constitute a modification under the
aggregate definition irrespective of cost.  However, if a minor change to the
wastewater system, such as the  addition of one drain, was not a capital
expenditure on the aggregate facility, then it would not constitute a
modification under the aggregate facility definition.  If a new individual
drain system is installed that  results in increased emissions,  not only that
individual drain system, but all downstream components included in the
aggregate facility definition would come under the regulation,  even if no
capital expenditure is involved.  Offsetting of emissions would be allowed
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 for all  changes  to  the wastewater  system pursuant  to  Section  60.14 of the
 General  Provisions.   Offsetting  of emissions  increases  through  decreases  in
 emissions  within the  affected  facility would  be  allowed,  provided the owner
 or  operator  of the  facility  can  adequately demonstrate  that there will  be no
 increase in  emissions.
     The reconstruction provisions remain as  stated in  Section  60.15  of the
 General  Provisions.   Under these provisions,  reconstruction means the replace-
 ment of  components  of an existing  facility to such an extent  that the fixed
 capital  cost of  the new components exceeds 50 percent of  the  fixed capital
 cost that  would  be  required  to construct  a comparable entirely  new facility.
 2.2.6  Comment:   Two  commenters  stated that oil-water separators  and  air
 flotation  systems should be  subject to the NSPS  only  if actually  modified or
 reconstructed  (IV-D-1,  IV-D-7).  Modification of these  units  is best  defined
 in  reference to  design  capacity.   The commenters recommended  that the defini-
 tion of  aggregate affected facility should be modified  to be  consistent with
 40  CFR Section 60.14(e)(2), which  states  that "an increase in production  rate
 of  an existing facility,  if that increase can be accomplished without a
 capital  expenditure on  that facility" is  by itself not  considered to  be a
 modification.
       Response:  As discussed in  the response to Comment 2.1.3,  the  proposed
 standards  have been amended to delete air flotation systems from  the  defini-
 tion of  affected  facility.  Oil-water separators continue to be covered by
 the  standards.  Under the final standards, a change in an existing oil-water
 separator  is considered  a modification,  making the facility an affected
 facility,  if the  change meets the  specifications of 40 CFR Section 60.14.
 For existing individual oil-water  separators,  this includes the provision of
 40 CFR Section 60.14(e)(2) requiring an  increase in production capacity to be
 accomplished through a capital  expenditure in  order to constitute a modifica-
 tion.  To this extent, these standards are similar to  most other NSPS.
However,  as described in the response to Comment 2.2.4,  the addition of a new
 individual  drain system will  trigger modification of the "aggregate
facility,"  which  includes the oil-water  separator.   Consequently,  the
addition  of a new process unit  to a refinery to  increase production will
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constitute a modification if the addition of the process unit includes a new
individual drain system.  Such an addition would be a major physical change
in the wastewater treatment system resulting in a potentially significant
increase in VOC emissions.  This change would constitute a modification of
the aggregate facility regardless of whether or not a capital expenditure is
made.
2.2.7  Comment:  One commenter stated that while increased flows resulting
from new process units will  change the physical state of the system (i.e.,
flow equalization tanks may have higher levels, and residence times may be
shorter in oil-water separators), it is not clear that the facility (i.e.,
the wastewater treatment system) has been modified (IV-D-7).  According to
the commenter, a well-designed wastewater treatment system is capable of
dealing with large short-term variations in loading without any physical
modifications and without any change in operations.
       Response:  Under the final standards, the addition of a new process
unit to the refinery will not, in itself, constitute a modification.  The
addition of a new individual drain system to the wastewater system (regard-
less of whether a capital expenditure is involved) would constitute a
modification of the aggregate facility, as defined in the regulations.   (See
response to Comment 2.2.4 for further detail.)
2.2.8  Comment;  One commenter maintained that  variations in VOC loadings
from changes in the refinery are part of daily  routine (IV-D-7).  These
variations may be attributed to operational changes such as bringing on line
equipment idled by lack of demand or by maintenance, operating existing
equipment continuously rather than on an intermittent basis, performing
periodic procedures such as tank cleaning.  The commenter was concerned that
these normal variations on refinery operations  will result in all  facilities
being declared modified.
       Response;  After consideration of the comments received on  this  issue
in response to the discussion in the preamble to the proposed standards,  EPA
has decided that it is not practical to consider routine variations in
wastewater loading as modifications under this  NSPS.  These variations  are
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 not  changes  to  individual  affected  facilities, such  as  an oil-water  separator
 or individual drain  system,  and normally do not  involve a capital  expenditure.
 If,  however, physical  or operational  changes result  in  increased emissions
 and  a  capital expenditure  is made on  either the  aggregate or  individual
 facility,  that  change  would  constitute a "modification" under the  aggregate
 or individual affected facility definitions, as  applicable.  As discussed in
 the  response to Comment 2.2.4, the  addition of a new individual drain  system
 that results in increased  emissions would also constitute a modification of
 the  aggregate facility, regardless  of whether a  capital expenditure  is
 involved.
 2.2.9  Comment:  One commenter noted  that defining the  term "modification" as
 any.  increase in loading rate appears  to conflict with the Clean Air Act's
 definition of the term, and  is thus beyond the Agency's authority  (IV-D-7).
 The  commenter stated that  it is clear in the Clean Air  Act that a modification
 must involve either a  physical change in a facility  or  a change in the method
 of operation.   According to  the commenter, an increased loading rate is not
 the  same as a change in a  method of operation.
       Response:  After consideration of the issue of increased loading
 raised in the proposal  preamble, and after review of the comments received on
 this issue, EPA has decided  that it is not practical to consider an increase
 in the loading  rate alone  as a modification under this NSPS.  A modified
 facility under  these final  standards is either an existing individual drain
 system or oil-water separator or an aggregate facility that has undergone a
 physical or operational change involving a capital  expenditure,  or an
 aggregate facility to which  a new individual  drain system has been added.
 2.3  SELECTION OF CONTROL TECHNOLOGY
 2.3.1  Comment;   One commenter recommended that process drain seal  and cover
 system requirements be relaxed in service areas where corrosive materials in
the drain system would cause rapid degradation of the equipment (IV-D-8).
       Response:  The presence of corrosive material  in the drain system is
not sufficient reason to relax the requirements for process drain seals and
covers.  In situations where corrosive materials  enter the drain systems it
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may be necessary to construct the required process drain controls and covers
out of the same material that was used to construct the drains themselves.
The drains must also be made of material  that is resistant to the corrosive
action with which the commenter is concerned.  Therefore, it is not unreason-
able that in these situations the drain seal  devices and covers also be made
of this same material.
2.3.2  Comment:  One commenter disagreed  with EPA's statement that it is
common practice to use water seals in drains  (IV-D-5).   The commenter said
that water seals are commonly used in sewer lines to prevent vapors from
flowing upstream from junction boxes, but are generally not used for
individual drains.
       Response:  Several types of individual drains are used in petroleum
refineries.  These include a straight vent pipe with no liquid seal, a drain
with a p-leg trap that provides a liquid  seal in the individual drain, a
drain with an external seal pot which also has a liquid seal, and a completely
closed drain system.  The primary reason  for installing drains with liquid
seals is for safety.  Liquid seals prevent combustible  vapors from passing
through the sewer system and escaping near potential ignition sources.
Because of this, drain seals are commonly used as a fire prevention measure.
A liquid seal also can be used as a vapor control device because molecular
diffusion of VOC to the atmosphere is significantly reduced and convection
effects are eliminated.  During the development of the  proposed standards,
several refineries were identified that employed some type of liquid seal in
the drain pipe.  Therefore, EPA believes  this type of control for drains to
be adequately demonstrated.
2.3.3  Comment:  Three commenters recommended that the  tight seal requirement
for junction box covers be deleted given  that the junction box cover is
vented (IV-D-2, IV-D-4, IV-D-5).  The commenters maintained that the
additional reduction in evaporation rate  does not warrant such a requirement.
       Response:  As described in the Volume I BID, the emission rate of
0.032 kg/hour (0.07 Ib/hr) attributed to  vented junction boxes was based on
the assumption that junction boxes, although vented, were also equipped with
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a sealed cover.  To address the question the commenters have raised regarding
the reduction in emission rate attributable to sealing the cover, the Agency
evaluated data from a study conducted by the Chicago Bridge and  Iron Company.
In this study, emissions were measured from drums filled with hexane.  The
data showed a 23 percent reduction in emissions when a cover on  the drum was
gasketed and clamped, as opposed to an ungasketed cover.  This emission
reduction is believed to be comparable to the emission reduction achieved
when a junction box cover is tightly sealed because the conditions under
which the test was performed are believed to be comparable to the conditions
within a junction box.  As a result, the additional emission reduction due to
a gasketed, as opposed to an ungasketed, cover on a vented junction box is
estimated to be 0.06 Mg/year (0.07 tons/yr).  With an estimated  1,200
junction boxes expected to become affected by the NSPS after 5 years, this
amounts to a VOC emission reduction of 72 Mg/year (80 tons/yr) nationwide.
The cost of gasketing a junction box cover was also evaluated and was found
to be approximately $80/Mg ($73/ton) per junction box.  This cost is
considered reasonable.
2.3.4  Comment:  Two commenters suggested that water seals be provided at the
junction box or sump rather than at each individual drain (IV-D-8, IV-D-9).
The commenters maintained that this would provide equivalent emissions
control and better fire protection.  According to the commenters, seals
located at the junction box would be less likely to evaporate or freeze
during cold weather.
       Response:  The basic principle used to control VOC emissions from
drains and junction boxes is to limit the effects of diffusion and convection
on the volatilization of VOC from the wastewater.  This can be accomplished
by creating a barrier between the atmosphere and the wastewater.  For drains,
the control technique required by the NSPS is to place a water seal in the
drain to form a barrier between the wastewater and the atmosphere.  The
control efficiency of water-sealed drains has been estimated at proposal  to
be 50 percent or greater.  This would reduce the AP-42 emission factor of
0.032 kg/hr (0.07 Ib/hr) for refinery drains to approximately 0.016 kg/hr
(0.035 Ib/hr).  For junction boxes, the mechanism for VOC emissions (i.e.,
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effects of diffusion and convection) are the same as for open drains.  In
addition, since junction box vent pipes are in the same size range as drains,
the VOC emission rate from junction box vents is estimated to be the same as
open drains, or 0.032 kg/hr (0.07 Ib/hr). Therefore, a water seal on a
junction box will also achieve emission reductions of 50 percent or greater.
The commenters are correct, then, in stating that a water seal in a junction
box provides equivalent emission control as a water seal in a drain.
However, the overall emission reduction is not equivalent because there are
many more drains than junction boxes in the refinery wastewater system.  For
example, it is estimated that for every junction box, there are six drains.
Placing a water seal at each of the six drains affords greater overall
emission reduction than placing a water seal at the junction box only.
     As for fire protection, water seals are often used in refineries to
prevent combustible vapors from passing through the sewer system and escaping
near potential ignition sources.  However, as a result of comments received
at the August 1984 meeting of the National Air Pollution Control Techniques
Advisory Committee (NAPCTAC), EPA further evaluated the potential safety
hazard associated with installing water seals in junction boxes.  It was
determined that a water-sealed junction box could pressurize the drain
system, thereby creating a potentially explosive condition.  Therefore, EPA
did not require water seals for junction boxes in the proposed regulation.
This decision was endorsed by one commenter (IV-D-10).  The EPA has evaluated
an alternative control for junction boxes and, as described further in the
response to Comment 2.3.5, specific vent sizes for vents on junction box
covers are now required in the final rule.
     Finally, in response to the comment that a water seal on a junction box
would be less likely to evaporate or freeze, the Agency believes that water
seals on individual drains are no more prone to evaporation or freezing than
water seals at a junction box.  The water seal would be essentially the same
no matter where  it was placed, and both locations are subject to the same
atmospheric conditions and receive the same wastewater.  Therefore, the
requirement for  installing water seals on individual drains remains the same
as proposed.
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 2.3.5   Comment:   One  commenter  (IV-D-2)  stated that the technical  basis  for
 installing  sewer  seals  for  emission  reduction is  flawed.  As described by  the
 commenter,  vapors trapped by the  sewer drain seals will be emitted via the
 junction  box  to prevent the buildup  of potentially explosive vapors.  The
 commenter recommended that  since  sewer seals will not materially reduce
 emissions,  this requirement should be removed from the final standards.
        Response:   As  discussed  in the response to the previous comment,  the
 overall emission  reductions from  process drain seals are greater than from
 controls  on junction  boxes  because of the greater number of process drains
 within  a  process  unit.   The greater  number of drains exposes more  surface
 area and  thereby  provides greater opportunity for volatilization.
     Based  on the assumption that molecular diffusion and convection are the
 primary factors affecting VOC emissions from drains and junction boxes,  and
 in light  of the potential safety problems of water seals on junction boxes,
 vent pipes  are allowed  to provide safe and effective emissions control from
 junction  boxes.   Because the rate of molecular diffusion and convection  are
 influenced  by the  length of the vent pipe and design of the vent pipe opening,
 EPA evaluated the  effects of different size vent pipes.  Since VOC diffusion
 is inversely proportional to the diffusion path length, the greater the vent
 pipe length, the  lower  the  rate at which molecular diffusion can transport
 VOC into  the air.  Also, the diameter of the vent pipe opening affects the
 emissions due to  convection.  Therefore, to restrict emissions from junction
 box vents due to  the  effects of molecular diffusion and convection, EPA has
 determined  that a  vent  pipe having a maximum diameter of 10.2 cm (4 inches)
 and a minimum length  of 90  cm (3 feet) will  be required.   Thus, a vent pipe
 is allowed  to avoid safety  problems,  but a maximum diameter and minimum
 length are  specified  in order to restrict emissions due to the effects of
molecular diffusion and convection.
 2.3.6  Comment;   One commenter stated that the requirement that API separators
 have fixed covers  and a vapor control vent system as a primary control  device
 is not technically sound (IV-D-2).  The commenter explained that it would be
very difficult to achieve gas-tight  seals on all  the openings in the cover
and placing a sweep gas under the covers would create a dangerous situation.
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The commenter recommended that fixed roofs be the alternate control technology
and the floating cover control scheme be the preferred method.  A second
commenter also endorsed floating cover control  as the preferred method
(IV-D-10).
       Response:  The Agency has determined that fixed roofs with vapor
control vent systems are the best demonstrated technology (BDT) for oil-water
separators.  Section 111 of the Clean Air Act requires that standards of
performance be based on the best system of continuous emission reduction that
has been adequately demonstrated, considering costs,  nonair quality health
and environmental impacts and energy requirements.  Floating roofs were not
chosen as the preferred control because floating covers cannot be used on all
types of separators; for example, corrugated plate interceptors (CPI).
However, EPA has made this requirement flexible by allowing floating roofs as
an alternative technology to a fixed roof with a vapor control device.
Inclusion of this alternative was endorsed by another commenter (IV-D-10).
     The EPA disagrees that purging the vapor space to a control device would
be hazardous.  Inert gases such as nitrogen, natural  gas, or fuel gas have
all been used for this purpose.  During development of the standards, a
refinery was visited that was using natural gas for this purpose.  In
addition, two other commenters (see Comment 2.4.3) maintained that not using
a sweep gas would be hazardous.  As a result, as described in the response to
Comment 2.4.3, EPA has reevaluated the cost of purging the vapor space of a
fixed roof with fuel gas and found this cost to be reasonable.
2.3.7  Comment:  Two commenters felt that venting emissions from an oil-water
separator to an existing vapor control device may result in safety concerns
(IV-D-5, IV-D-11).  First, a flame would be present to ignite the potential
explosive vapors under the roof.  Secondly, emergency flare lines are subject
to rapid pressurizations, which could cause a hazardous condition in the
separator.  Furthermore, according to the commenters, this connector would
result in the introduction of  air into hydrocarbon transfer lines, a condition
that  is scrupulously avoided  in most hydrocarbon processing facilities.
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       Response:  The use of an existing flare to combust vapors from an
oil-water separator would not create safety problems if precautions are taken
in the design and operation of the system.  First, the flare should not be
located in such close proximity to the oil-water separator that ignition of
vapors is a serious threat to safety.  In the analysis conducted for this
standard, it was assumed that the flare would be located as far as 60 meters
(200 feet) from the oil-water separator.  Second, controls such as a fluid
seal or flame arrestor are available that would prevent flashback.  These
controls were considered in EPA's previous cost analysis.  Finally, the use
of a purge gas, such as nitrogen, plant fuel gas, or natural gas, and/or the
careful control of the total volumetric flow to the flare would prevent
flashback in the flare stack caused by low off-gas flow.  As described in the
response to Comment 2.4.3, EPA has revised the costs associated with venting
to a control device to include the cost of a fuel gas purge system.  It was
found that even with this additional cost, this requirement is cost
effective.
     The rapid pressure buildup cited by the commenters is typically addressed
through the design of the flare system.  Contacts with flare vendors indicate
that a flare handling an oxygen-laden vent stream should be initially designed
to handle the anticipated potential pressure buildup.
2.3.8  Comment:  One commenter agreed with EPA that a cover is an effective
control device for an API separator (IV-D-11).  Beyond the use of a cover,
however, the commenter felt there has been no vapor control system demon-
strated to be safe and effective for API separators because there were none
discussed in the Volume I BID.  Consequently, the commenter recommended that
control of VOC vapors from API separators through vapor recovery or combustion
systems should not be required.
       Response:  During the development of the NSPS, EPA personnel visited
several refineries and found that VOC destruction and recovery systems were
in use for controlling the vented vapor space from oil-water separators.
Because these technologies are demonstrated for control of VOC emissions,
these standards are based on their use.  These control systems were described
in Chapter 4 of the Volume I BID and include incinerators, flares, process
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heaters, and carbon absorbers.  Another alternative control  available for API
separators is the use of a floating roof that eliminates the vapor space
above the liquid, greatly reducing the potential  for volatilization of VOC
from the oil layer.
2.3.9  Comment:   One commenter said that to use a flare system as a control
device, a separator will have to be operated under positive  pressure
(IV-D-7).  This  is necessary to prevent leakage of outside air into the flare
system and cause a safety hazard.  The commenter felt that this increased
pressure could result in an increase in VOC emissions.
       Response;  A refinery visited during the development  of the standards
vented an oil-water separator equipped with a fixed roof to  a control device
by purging the vapor space with natural gas at a positive pressure in the
range of 1 to 2  cm (0.4 to 0.8 inches) of water.   This pressure was adequate
to maintain a discharge flow of 75 acfm at 15 psig.  The EPA disagrees that
this slight positive pressure would cause an increase in VOC emissions.  As
described in the response to Comment 2.3.10, the control efficiency of a
tightly sealed fixed roof is 99.7 percent.  The effect of the increased
positive pressure would not increase VOC emissions to the atmosphere but may
slightly increase the flowrate to the control device.
2.3.10  Comment:  One commenter questioned the requirement of venting to a
control device for fixed roof-equipped oil-water separators  (IV-D-7).  The
commenter noted there was no basis given in the proposal preamble that
venting to a control device would increase the capture efficiency of a fixed
roof from 85 to 99 percent.
        Response;  The 85 percent capture efficiency to which the commenter
refers is the capture efficiency that has been estimated for fixed roofs not
vented to a control device.  The NSPS requires that fixed roofs vented to a
control device be operated and maintained in a gas-tight condition (i.e., no
detectable emissions as indicated by an instrument reading of less than
500 ppm above background levels).  The capture efficiency of a gas-tight
fixed roof has been estimated to be 99 percent.  This estimate is based on
AP-42 emission factors for deck fittings on volatile organic storage tank
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 access  hatches.  Gasketing  and  sealing  an  access hatch was  assumed  to  be
 comparable  to  the emission  reduction  achieved by gasketing  and  sealing a
 fixed roof.  Deck fitting loss  for the  access hatch was calculated  in  terms
 of Ib/linear foot/year and  applied to a model tank.  The emission reduction
 achieved with  a gasketed fixed  roof over the tank was calculated.   The
 calculations showed that an unbolted, gasketed cover on the model tank
 reduced emissions by 99.7 percent over  an  uncovered tank.
     The actual overall control efficiency for a fixed roof vented  to  a
 control device depends on the efficiency of the control device.  For flares,
 the efficiency is estimated to  be 98  percent.  Therefore, the overall
 efficiency  of  a fixed roof  with vapors  vented to a control  device is
 97 percent  (0.99 x 0.98 = 0.97).
 2.3.11  Comment:  Four commenters stated that placing a fixed roof  on
 oil-water separators and similar devices creates a serious  safety hazard
 because the potential exists for a buildup of explosive vapors  under the
 cover (IV-D-3, IV-D-7, IV-D-8,  IV-D-11).   Furthermore, the  commenters  main-
 tained that covers may actually have  a  negative impact on the environment if
 an explosion occurs that has the potential to shut down the treatment
 facility, resulting in untreated wastewater being discharged.
        Response:  The Agency believes  that a fixed roof is a demonstrated
 technology for oil-water separators and similar tanks or basins, given that
 an estimated 85 percent of  nationwide crude throughput is processed at
 refineries that are located in States requiring covered separators.   Also,
 some oil-water separators,  such as the CPI design are supplied with fixed
 covers.  Therefore,  EPA has concluded that there are no safety hazards
 associated with fixed roofs beyond those normally experienced by industry.
     For DAF's, however,  because of the physical  design characteristics of
 the system, and the use of  air or gas used for flotation,  a greater potential
 for the buildup of explosive vapors under fixed roofs exists for these units.
As discussed in the response to Comment 2.1.3,  because of safety and cost
considerations the fixed  roof requirement for DAF's has been deleted from the
 final  rule.
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2.3.12  Comment;  One commenter recommended that criteria for covering only
part of an oil-water separator, such as the separator forebay where most slop
oil can be recovered, be included in the proposed regulation (IV-D-8).
Another commenter suggested changing the wording "separator tank" to
"separator zone" in the proposed standard since that is the proper
designation for that portion of the oil-water separator that was evaluated by
the Agency (IV-D-9).
        Response:  Covering only part of an oil-water separator such as the
forebay is not an acceptable control strategy for this regulation.  Although
some oil may be removed in the forebay, not all oil-water separator designs
have a skimming device in the forebay.  If the oil  is not skimmed, then the
effectiveness of a fixed roof on the forebay is negated.  Also, the retention
time required to separate the oil varies with the inlet oil concentration,
which can be extremely variable.  Therefore, there is a large emission
potential from the entire separator tank, not just the forebay.  In addition,
EPA has determined that covering the entire oil-water separator tank is cost
effective.  The incremental cost effectiveness for oil-water separators
subject to the standards is about $810/Mg ($735/ton) of VOC controlled by a
fixed roof vented to a control device.  As discussed in the response to
Comment 2.4.3, if the cost of a fuel gas purge system is added, this cost
increases slightly to $850/Mg ($770/ton).
     Regarding the request of one commenter (IV-D-9) that the term "separator
tank" be changed to "separator zone," the intent of the regulation is that
the entire separator tank be covered for the reasons stated above.
2.3.13  Comment;  One commenter was concerned that EPA used a control
efficiency of 85 percent for floating roofs and this efficiency is unrealis-
tically low (IV-D-12).  The commenter believes that with one vapor-mounted
primary seal a floating roof can achieve at least a 90 percent control
efficiency.
        Response;  The commenter appears to have misunderstood the control
efficiency used by EPA in assessing floating roof control for oil-water
separators.  As described on page 16338 of the proposal preamble, EPA has
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 determined that a floating roof with a liquid-mounted primary seal  and a
 secondary seal  can reduce VOC emissions by about 95 percent.   The precise
 emission reduction capability of a well-designed floating roof depends on the
 seal  system and the effectiveness of the refinery's maintenance and repair
 program.
 2.3.14  Comment:   One commenter recommended that if a battery-limit oil-water
 separator is installed at a new,  modified,  or reconstructed process unit, no
 controls on the downstream wastewater treatment  system should be required
 (IV-D-10).   According to the commenter,  battery-limit oil-water separators
 will  eliminate  any significant increase in  hydrocarbon emissions due to  the
 new operation.
         Response:   The commenter  is referring to an oil-water separator,  also
 known as a  unit separator,  that is  dedicated  for use at one process unit.
 Under the final  rule,  battery-limit oil-water separators  are  included in  the
 definition  of oil-water separator and as  such are subject  to  the applicable
 control  requirements.   Installation of a  battery-limit oil-water separator
 will  not cause  modification  of downstream wastewater treatment  components
 unless,  as  explained  in the  response to Comment  2.2.4, an  individual  drain
 system is also  installed  or  a  capital  expenditure is made  on  the aggregate
 facility.
 2.3.15  Comment:   One  commenter,  noting that  some oil-water separators
 equipped with external  floating roofs  are installed  below-grade,  recommended
 that  the regulation be  revised  to allow an opening  in  the  floating  roof for
 stormwater drainage and removal (IV-D-4).  According  to the commenter, an
 opening  in the  roof is  needed to  allow stormwater on  the floating roof to
 enter  the separator.
         Response:  The  EPA agrees with this comment  and has revised the final
 standards to allow stormwater removal through openings in external  floating
 roofs of oil-water separators.  The final standards require that each emer-
gency roof drain be provided with either a flexible fabric sleeve seal or  a
 slotted membrane fabric cover that covers at least 90 percent  of the area  of
the opening.
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2.3.16  Comment:  With regard to floating covers on oil-water separators, one
commenter thought it was unrealistic to require a liquid-mounted primary seal
with an allowable gap width of 3.8 cm (1.5 inches) and a secondary seal with
an allowable gap width of 1.3 cm (0.5 inches) (IV-D-12).  The commenter felt
it would be more reasonable and cost effective to reduce the liquid-mounted
primary seal gap to 0.63 cm (0.25 inches) and eliminate the requirement for
the secondary seal.  Two other commenters recommended that floating covers
with two vapor-mounted seals should be allowed because vapor-mounted seals
are not immersed in oily wastewater, which can weaken the seal structure
(IV-D-7, IV-D-9).
        Response:  The EPA has not allowed gap widths of 3.8 cm (1.5 inches)
and 1.3 cm (0.5 inches) for liquid-mounted primary and rim-mounted secondary
seals, respectively.  Rather, the requirement for liquid-mounted primary
seals is that the total gap area between the primary seal and the separator
wall not exceed 67 cm2/m (3.2 in2/ft) of separator wall perimeter.  The gap
width between the primary seal and separator wall shall not exceed 3.8 cm
(1.5 inches) at any point.  For secondary seals, the total gap area between
the secondary seal and the separator wall shall  not exceed 6.7 cm2/m
(0.32 in /ft) of separator wall perimeter.  The gap width between the
secondary seal and the separator wall shall not exceed 1.3 cm (0.5 inches) at
any point.  However, as a result of this comment, EPA analyzed three different
control scenarios.  These were:  (1) a liquid-mounted primary seal alone,
(2) a vapor-mounted primary seal with no gaps in a secondary seal, and (3) a
liquid-mounted primary seal with a secondary seal having the same gap widths
as in the proposed standards.  These control scenarios were analyzed using
test data that were gathered during development of the Volatile Organic
Liquid Storage Vessels NSPS (40 CFR Part 60, Subpart Kb).
     These data showed that regardless of the type of primary seal, the
addition of a secondary seal system always resulted in lower measured
emissions.  In light of this finding and because a liquid-mounted primary
seal with a secondary seal for floating roofs on oil-water separators has
been determined to be cost effective, EPA has retained the requirement for a
secondary seal.
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      Next, EPA evaluated test data for both liquid-mounted and vapor-mounted
 primary seals with secondary seals.  The liquid-mounted seal  system had
 essentially the same gap widths as were required in the proposed standards.
 The vapor-mounted seal system, by contrast, had no gaps between the storage
 tank wall  and either the vapor-mounted primary seal or the secondary seal.
 The emission test results showed that even with the above-specified gap
 widths, the liquid-mounted primary seal  with a secondary seal  had measured
 emissions  that were lower by a factor of 3 compared to the tight vapor-
 mounted primary seal  with a secondary seal.  As a result of this analysis,
 the seal  and gap width requirements for floating roofs remain  unchanged in
 the final  rule.
      With  regard to the comment that vapor-mounted seals are beneficial
 because they are not  immersed in the oil  and water that can weaken their
 structure,  according  to API Publication  2517:   Evaporation Loss from FxtPrnal
 Floating Roof Tanks,  this problem previously associated with liquid-mounted
 seals has  been reduced.   This is due to  recent  advances in synthetic com-
 pounding that have resulted in materials  with  increased compatibility with
 hydrocarbon products.
 2.3.17 Comment:   One  commenter stated that the  requirement of using gaskets
 and  latches to make access  doors on  lAF's  gas-tight  is  too restrictive
 (IV-D-5).
        Response;   In  response to  other comments on  air  flotation  systems  as
 explained  in  the  response to  Comment  2.1.3,  EPA has  concluded  that air
 flotation systems  should not  be  subject to  the final rule.  Therefore, the
 commenter's  concern has been  addressed.
 2.3.18  Comment;   Four commenters  pointed out that covers  on air flotation
 systems raise  significant safety concerns  (IV-D-1, IV-D-7,  IV-D-9, IV-D-10).
An unvented fixed cover may present an explosion and fire  hazard in  some
types of units due to the buildup of explosive vapors inside the cover.
According to one of the commenters (IV-D-9), either a nitrogen  purge system
or a large vapor space is required to minimize the explosive atmosphere under
the cover.   This sweeping of air over the unit's flotation zone surface would
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offset the control efficiency claimed by EPA in justifying covers for DAF's.
Another of the commenters (IV-D-10) noted that the only OAF system with a
roof reported on in detail in the BID included a ventilation system to dilute
the vapor space.  This commenter said that many refiners would not consider
Regulatory Alternative II to be a realistic alternative because the composi-
tion of the confined vapor space is uncontrolled.  The EPA was urged by each
of these commenters to remove the requirement to cover DAF tanks.
        Response:  The Agency agrees that this is a legitimate concern.  See
response to Comment 2.1.3.
2.3.19  Comment:  Installation of covers on air flotation systems will reduce
the ability of the operator to visually inspect and monitor the system,
according to four commenters (IV-D-1, IV-D-5, IV-D-6, IV-D-7).  This will
reduce the treatment efficiency, and will result in only minimal reduction of
emissions.  Operators will be hindered in their ability to notice and
promptly repair minor maintenance problems.  These commenters believe that,
if undetected, these problem could lead to major failure and might require a
complete system shutdown to facilitate repairs.
        Response:  This does not appear to be a significant problem.  Access
hatches and peep holes allow the operator to monitor the process and make
repairs.  However, for reasons other than those stated by the commenters, EPA
has decided to exempt air flotation systems from the standards as explained
in the response to Comment 2.1.3.
2.3.20  Comment:  Three commenters made comments related to the reduction of
VOC emissions using VOC fugitive emission control programs and source control
programs (IV-D-3, IV-D-6, IV-D-8).  One commenter said that existing VOC
emission control programs in conjunction with sealed process drains and unit
oil-water separators are more cost effective than retrofitting existing
wastewater treatment systems with the proposed controls (IV-D-6).  A second
commenter noted that control of oil-water separators is required regardless
of the extent of wastewater segregation and reuse upstream (IV-D-8).  This
commenter maintained that the proposed regulation did not make adequate
allowance for downstream controls when extensive source control is provided.
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A third commenter stated that the regulation forces the use of add-on control
equipment, preventing the possible use of more effective control such as
elimination (IV-D-3).  This commenter suggested a better approach would allow
flexibility to control the problem at its source and that EPA should consider
setting a de minimus capacity level below which controls are not needed.
        Response;  A source control program approach to controlling VOC
emissions was considered during development of the proposed standards.  This
approach relies on a system of identifying problematic wastewater streams and
upset conditions, coupled with a series of housekeeping measures tailored to
problems arising in each process unit.  This alternative, however, was not
included for several reasons.  First, alternative source control programs,
while possibly reducing VOC emissions in some instances, are not based on
control techniques that are demonstrated.  The EPA cannot establish standards
based on control techniques that are not demonstrated.  Second, the control
techniques used in a source control program may not reduce emissions con-
tinuously, and such a program may be difficult to define or enforce.  However,
as was included in the proposed rule, an alternative emission limitation
provision has been included in the final rule.  Under this provision, an
individual refiner may apply to the Administrator for approval of a source
control program tailored to the circumstances at an individual refinery.  The
alternative control techniques must be shown to be equivalent to the require-
ments of the NSPS in terms of emission reduction.  Contrary to the commenter's
statement (IV-D-8), the NSPS does not prevent the use of source control
programs, nor does it discourage the use of such programs.  Many refiners
employ such programs to minimize hydrocarbon emissions for safety reasons.
Such programs would still be in use even in the absence of an NSPS.
     The EPA did consider the possibility of wastewater segregation and reuse
upstream of the oil-water separator.  In the proposed standards, drain
systems that are designed and used as separate systems for the sole purpose
of collecting stormwater runoff were exempted from the standards.  The final
rule also contains an exemption for cooling water systems using water that
does not come into contact with oil or oily water.
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     Finally, with regard to setting a de minimis emissions level below which
controls are not needed, EPA previously determined that such a format for the
standards is not feasible.  For most refinery fugitive emission sources, it
is not feasible to prescribe performance standards because it is impractical
or economically infeasible to measure emissions from these sources.  For
individual drain systems, determining compliance with a performance standard
would be prohibitively expensive.  In the case of oil-water separators, the
principal limitation with a standard of performance concerns the difficulty
in measuring emission levels.  For these reasons, for petroleum refinery
wastewater systems, a combination of equipment, work practice, design,  and
operational standards was selected for the format of the standards.
     The final standards do include de minimis capacity levels below which
the standards do not apply.  Specifically, oil-water separators with a
maximum design capacity to treat less than 16 liters per second (250 gpm) of
refinery wastewater are not required by Section 60.692-3 to be equipped and
operated with a closed vent system and control device.  De minimis cutoffs
based on influent oil concentration or vapor pressure were also considered,
but were not included in either the proposed or final standards because of
the variability in influent oil concentration and the poor correlation
between vapor pressure and VOC emissions.
2.3.21  Comment:  One commenter said that although the proposed standards
allow alternative means of emission limitation to be used to achieve
equivalent emission reductions, it may be expensive and difficult to verify
equivalent emission reductions (IV-D-8).
        Response:  Section lll(h)(3) of the Clean Air Act permits the use of
alternative means of emission limitation if it will achieve a reduction in
emissions of any air pollutant at least equivalent to the reduction in
emissions achieved by the applicable standard.  The purpose of allowing an
alternative means of emission limitation is to encourage the use of innovative
technologies or systems of continuous emission reduction.  The EPA recognizes
that for the petroleum refinery wastewater system source category, verifying
an alternative means of emission limitation may be difficult, but owners and
operators are at least allowed this alternative if they so choose.
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 2.4  COST/COST EFFECTIVENESS
 2.4.1  Comment;  Three commenters stated that neither the extra cost nor the
 effort of providing water seals in drains and covers with leak detection
 monitoring on junction boxes is unwarranted (IV-D-2, IV-D-4, IV-D-5).  The
 commenters maintain that covers on junction boxes and visual inspection will
 accomplish the goals of the NSPS.
        Response:   The EPA disagrees that requiring water seals in drains is
 unwarranted.   As  a first step toward determining which control techniques
 should be selected as the basis of the proposed standards for individual
 drain systems, EPA analyzed the annualized cost and cost effectiveness of
 controlling VOC emissions and the resultant VOC reduction for three alterna-
 tive control  techniques.   Also considered were nonair quality health and
 environmental, energy,  and economic impacts associated with  alternative
 control  techniques.   For individual  drain systems,  it was found that water
 seals in drains were a  demonstrated technology that could reduce VOC emissions
 from drains by an  estimated 50 percent.   In addition,  this control  was  found
 to  be cost effective [$300/Mg ($270/ton)  for a typical  size  new facility].
 Therefore,  water seals  were chosen  as  the best demonstrated  technology  for
 drains and remain  the selected control alternative  in  the final  rule.
      The Agency does agree,  however, that visual  inspection,  rather than leak
 detection monitoring for  junction box  covers,  is  appropriate.   Therefore,  as
 discussed in  the response to  Comment 2.6.7,  the requirement  for leak
 detection monitoring for  junction box  covers has  been deleted  from  the  final
 rule.
 2.4.2  Comment:  One commenter  stated  that  the cost to retrofit  the  proposed
 drain system  controls on  older  process units would be prohibitive (IV-D-8).
 This commenter  recommended  that drain  systems  in older process  units that are
 modified  or reconstructed  should be exempted from the regulation by  the  same
 logic that was  used  by EPA to exempt facilities with catch basins.
       Response;  An analysis of the cost of retrofitting existing process
drain systems  with p-trap drains was carried out by EPA.  The analysis  is
documented in  Chapter 8 of the Volume  I BID.  The additional  cost required to
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retrofit such a drain compared to installing a new p-trap drain is the cost
for labor and materials for removing the existing drain.   Costs used by EPA
assumed a 3-man crew using a backhoe with a pneumatic jackhammer to remove
concrete around the drain.  It was estimated that each drain would take about
one-half hour to excavate and remove.  Based on these assumptions, EPA
estimated that the additional cost to retrofit existing drains with the
equipment specified in this regulation is $486 per drain.  This results in a
cost-effectiveness estimate of about $850/Mg ($770/ton) VOC controlled for
retrofitted drains, compared to a cost effectiveness of about $300/Mg
($270/ton) VOC controlled for new drains.  This cost-effectiveness level is
considerably less than for systems with catch basins [estimated to be about
$2,100 Mg ($l,900/ton) VOC controlled] and is considered reasonable in light
of the VOC emissions potential of modified or reconstructed individual drain
systems at refineries.
2.4.3  Comment;  Two commenters stated that due to the potential for an
explosive buildup of vapor under fixed roof covers on oil-water separators, a
purging system would be necessary (IV-D-3, IV-D-7).  The commenters said the
costs for purging and controlling the purge stream are not included in the
EPA's cost estimates.
       Response:  As explained in the response to Comment 2.3.6, EPA believes
that a fixed roof is a demonstrated technology for oil-water separators.
Because of the widespread use of fixed roofs, the Agency does not believe
there are safety hazards associated with fixed roofs beyond those normally
experienced by industry.  Therefore, the requirement for fixed roof control
on oil-water separators with a maximum design capacity to treat 16 liters per
second (250 gpm) or less remains unchanged in the final rule.  For oil-water
separators with a design capacity to treat more than 16 liters per second
(250 gpm), a fixed roof with the vapor space vented to a control device, or
floating roof control is required.
     The EPA has reevaluated the cost of purging the vapor space under a
fixed roof to a control device.  The cost of a fuel gas purge system was
calculated for a typical size oil-water separator [47.3 liters per second
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 (750 gpm)].  The incremental cost effectiveness was found to be $850/Mg
 ($770/ton), an increase of about $40/Mg ($36/ton) over the cost of venting
 the vapor space to a control device without purging.  These costs are
 considered reasonable.
 2.4.4  Comment:  Three commenters objected that EPA assumed that an oil-water
 separator can be readily vented to an existing vapor control device (IV-D-1,
 IV-D-5, IV-D-7).  However,  wastewater treatment facilities are often remote
 from areas where process units or flares are located,  and extensive piping
 may be required to make a connection.  The commenters  maintain that the EPA's
 cost analysis should be based on the purchase and operation of a dedicated
 control device.  According  to the commenters,  the true incremental  cost of
 this requirement is unreasonably high,  and fixed covers provide sufficient
 control for all separators.
        Response:   The use of a dedicated control  device for the control  of
 emissions  from the vent of  an oil-water separator was  evaluated during  the
 development of this regulation and  was  found to be too costly  under most
 applications.   However,  the  use of  a dedicated  flare for the control  of these
 emissions  is  not  necessary  in order to  attain compliance with  the final
 standards.   Two other options are available.  The first is  to  vent  the
 oil-water  separator to an existing  flare.  This  option  was  examined  in  the
 development of this  regulation,  with  60  meters  (200  feet) of piping  for
 routing the vent  gases to an  existing flare  being  included  in  the cost
 analysis.   This proved to be  a  reasonable  alternative.   The  other option
 available  to  refinery operators  is  to use  another method of  control.  This
 could  include  either  a floating  roof over  the oil-water  separator, or use  of
 another existing  control device  such as  an incinerator,  carbon  adsorber,
 boiler, or  process heater.  The  cost of  these alternative controls is also
 considered  reasonable.
 2.4.5  Comment;  One commenter felt that the regulation as proposed will
 impose a forced retrofit of control equipment on all existing refineries in a
very short period (IV-D-2).   The commenter maintained that the standards will
exact excessive cost for insufficient environmental gain.
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       Response:  The changes to the proposed regulation dealing with the
modification of an aggregate facility will ensure that only those modifica-
tions to a refinery wastewater system which result in significant increases
in emissions will bring an existing wastewater system under the final
standards.  As explained previously in the response to Comment 2.2.4, a
modification occurs when a new individual drain system is constructed or when
additions to either the individual or aggregate facility constitutes a
capital expenditure.  Minor changes in a wastewater system would not
constitute modifications.  Consequently, it is not anticipated that all
existing refineries will be brought under the standards, and that those which
are will have undergone significant modifications resulting in increases in
emissions.  Consequently, the costs of the standards, in terms of requiring
facilities to install equipment and operate control technologies, will be
focused on those cases where the potential for environmental benefit is
greatest.
2.4.6  Comment;  One commenter stated that the reduction in evaporation rates
that may result from completely sealing the cover on an oil-water separator
would be insignificant and not commensurate with the cost of installing and
monitoring a seal system (IV-D-4).  A second commenter stated that EPA had
overestimated the benefits and underestimated the cost of venting a fixed
roof on an oil-water separator to a control device (IV-D-7).  It was suggested
that this requirement be deleted.
       Response;  The requirement that a fixed roof on an oil-water separator
must be completely sealed and the seal system monitored for no detectable
emissions is applicable to oil-water separators having a design capacity to
treat greater than 16 liters per second (250 gpm) of refinery wastewater.
Separators meeting this requirement and having a fixed roof must also vent
the vapor space to a control device.  As an alternative to a fixed roof with
vapors vented to a control device, oil-water separators may be equipped with
a floating roof.
     The reason for requiring that a fixed roof vented to a control device be
completely sealed and monitored for no detectable emissions is based on an
analysis of the control efficiency that can be achieved by a fixed roof.  The
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 EPA  has  shown  that  a  gas-tight  fixed  roof  on  a tank  can  achieve  a  capture
 efficiency  of  99  percent  compared  to  an  uncovered tank  (see  response  to
 Comment  2.3.10).  When  vented to a 95 percent efficient  control  device,  the
 overall  effectiveness of  venting a gas-tight  fixed roof  to a control  device
 is 94 percent.  This  represents a  substantial incremental emissions reduction
 in VOC emissions  when compared  to  the 85 percent efficiency  attributed to  a
 fixed roof  that is  not  gas-tight.
     In  addition  to being technically feasible, this technology  is also  cost
 effective.  As presented  in the preamble to the proposed standards, the
 incremental cost  effectiveness of  having a gas-tight fixed roof  vented to  a
 control  device compared to having  a fixed roof alone is $810/Mg  ($735/ton)
 for  a typical  size  facility.  As discussed in the response to Comment 2.4.3,
 if the cost of a  fuel gas purge system is added, this incremental cost
 increases slightly  to $850/Mg ($770/ton).  These costs are considered
 reasonable.
 2.4.7  Comment:   Several  commenters stated that the cost effectiveness of  air
 flotation system  controls is marginal and significantly higher than for  other
 elements in the proposed NSPS (IV-D-1, IV-D-5, IV-D-7, IV-D-9).  Two of  the
 commenters  (IV-D-7, IV-D-9) observed  that the cost effectiveness of such
 controls will be  even worse in the future as the result of other proposed
 regulations and industry's increasing efforts to minimize waste production.
 In the view of these  four commenters, it is questionable whether the low
 level of emissions  from these facilities warrant control measures.   Two  of
 the commenters (IV-D-1,  IV-D-5)  noted that EPA's own estimates show that
 fixed roofs on air  flotation systems will control  less than 180 Mg/yr
 (200 tons/yr) of VOC nationwide at the end of 5 years.
       Response:   As stated in Comment Response 2.1.3, the cost effectiveness
of a fixed roof with vapors vented to a control  device on DAF systems is
unreasonably high.  This is largely attributable to  the lower emissions
potential of air flotation systems.  In view of the  Agency's  conclusion that
use of a fixed roof without venting the vapors to  a  control device  would
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result in either a safety hazard or negligible emissions reductions, cost
effectiveness and safety considerations have led the Agency to exclude air
flotation systems from coverage under the final  standards.
2.4.8  Comment:  One commenter (IV-D-9) claimed that EPA's technical
development and economic bases for imposing controls on DAF's are seriously
flawed.  According to this commenter, EPA has grossly overestimated VOC
emissions from DAF's and has underestimated the costs of controls.  For
example, the cost for the additional  equipment needed to use a nitrogen purge
system was not included in the cost analysis, according to this and another
commenter (IV-D-10).  A nitrogen purge system is needed to reduce the hazards
of explosive gases building up under the DAF roof.   These commenters
recommended that EPA withdraw the proposed controls on DAF's from this
rulemaking because the technical basis for them has not been demonstrated and
because they are not cost effective.
       Response:  The emissions estimate used to calculate the cost
effectiveness of controls on DAF's was derived from EPA tests on an operating
DAF.  From these tests, an emission factor of 30 Kg VOC per million gallons
of wastewater was developed.  This emission factor is still believed to be
representative of the types of DAF's used at refineries and the range of
conditions under which DAF's are operated.
     However, as noted in the response to Comment 2.1.3, air flotation
systems have been excluded from the final standards primarily because of
safety concerns and the lack of control a fixed roof alone would afford.  The
Agency agrees with these commenters that a nitrogen purge system would be
needed to alleviate safety problems and that those costs were not included in
the original cost estimation work.  However, the cost effectiveness of
controls for DAF's is very high, not because the costs have been underestimat-
ed, but because a nitrogen purge system requires that vapors be vented to a
control device if VOC emissions are to be controlled.  The cost of a fixed
roof with a control device, coupled with the relatively small resulting
emission reduction, makes the cost effectiveness of controlling these units
unreasonable under Section 111 of the Clean Air Act.
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2.4.9  Comment;  Three commenters stated that the DAF selected for EPA's cost
analysis may not be typical (IV-D-2, IV-D-6, IV-D-10).  Many of the DAF's
being used in the industry are very large [e.g., 30 million liters per day
(8 million gallons per day) per tank].  The commenters noted that an
equipment supplier has estimated that a DAF roof will add approximately
35 percent to the cost of a new DAF.  Retrofit of an existing DAF with a roof
will undoubtedly add more, according to these comments.  One of these
commenters (IV-D-10) and another commenter (IV-D-6) stated that installation
of a DAF roof will not only affect initial installation costs, but will also
add to ongoing maintenance costs due to the need to remove large roof
sections in order to replace internal parts.
       Response:  The EPA believes the size of the DAF tested is
representative of the size range of DAF's in use.  The estimate of 35 percent
of the cost of the entire DAF is consistent with information gathered from
vendors by EPA.  The size of the DAF unit should not appreciably affect the
percentage of the total cost attributable to the roof because the roof cost
[EPA used $215 per square meter ($20 per square foot)] is directly
proportional to the roof size.  With respect to maintenance, vendors report
that DAF roofs can be removed easily, although refiners generally believe the
roofs are heavy and difficult to remove.
     In any case, as explained in the response to Comment 2.1.3, DAF's have
been eliminated from coverage under the final standards for a variety of
reasons.
2.5  ENVIRONMENTAL AND ECONOMIC IMPACTS
2.5.1  Comment:  One commenter questioned EPA's emission estimates for air
flotation systems (IV-D-8).  The commenter maintained that EPA's emission
estimates overpredict actual emissions because in air flotation units the
walls and steady upward displacement of gas caused by the flotation mechanism
minimizes wind effects and evaporative emissions.
       Response:  During the development of the standards, EPA conducted
emission tests on four lAF's and one DAF.  One IAF was treating non-oily
wastewater, so the emission results from this unit were not used to estimate
an emission factor.  As described in the Volume I BID, air purging was used

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to test the air flotation systems.  Because of the air purging, the emission
results represent the emission potential of the systems rather than the
actual emissions resulting from a system operating under normal conditions.
The VOC emissions measured at these systems were variable.  The variation
could be due to design and operational differences between the systems,
differences in the concentration of hydrocarbon in the wastewater, or
differences in the purge rate used during the tests.  Therefore, to account
for these variations, an average emission factor was calculated from the
emission test results to represent emission potential for air flotation
systems.
2.5.2  Comment:  Two commenters stated that the economic impact of the
standards should be reevaluated because the cost impact is major, not minor,
and additional review is required under Executive Order 12291 (IV-D-2,
IV-D-8).  The commenters feel that the economic impact of this regulation is
far greater than that listed in the preface to the regulation.  Compliance
with the proposed regulation in its entirety is estimated to cost a refinery
between $2 and 6 million.  Applying this estimate to the total industry, an
estimate of $130 million to retrofit all refineries is given, not including
operating and monitoring costs.
       Response:  The EPA disagrees with the commenters' contention that the
economic impact of the standards is major (i.e., greater than $100 million),
not minor.  The fifth year annualized costs by model unit and regulatory
alternative are summarized in Chapter 9 of Volume I of the BID.  These cost
estimates show that compliance with the proposed standards will cost the
petroleum refinery industry approximately $1.18 million.  Under the final
standards the economic impact will be $1.1 million.  The impact of the final
standards is slightly less because of the exemption of air flotation systems
from the final rule.
     The commenters did submit estimates of what the commenter determined it
would cost to comply with the NSPS.  Compliance with the proposed regulation
was estimated to be $2 to 6 million for one refinery.  However, the
commenters erred in assuming for these estimates that every single component
of the existing wastewater system would be subject to the standards.  The
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 final  rule is applicable only to new,  modified,  or reconstructed components
 of the wastewater system.   As described in  the Volume I  BID,  EPA estimates
 that  100 newly constructed process  unit drain  systems and 30  new oil-water
 separators will  become subject to the  standards.   In  addition,  18 process
 drain  systems and three oil-water separators are  expected to  become subject
 to the standards because of the modification and  reconstruction provisions.
 Thus,  as described above,  EPA has determined that the economic  impact  of the
 standards will  be approximately $1.1 million,  far less than the $100 million
 established as  the first criterion  for a major regulation under Executive
 Order  12291.
 2.6  MONITORING,  RECORDKEEPING,  AND REPORTING  REQUIREMENTS
 2.6.1   Comment:   Two commenters  stated that the requirement for weekly
 inspection of water seals  on  drains is unnecessarily  stringent  and  would
 present a significant  burden  to  the industry given the large  number and
 location  of these drains  in a refinery (IV-D-7, IV-D-8).   According to the
 commenters,  drains  are  often  located in  areas  that are difficult  or unsafe  to
 inspect routinely.  The  commenters  recommended that the  inspection  frequency
 for process  drains  be reduced  to  once  a month.   The commenters  further state
 that water seals  also tend to  be  maintained by precipitation,  maintenance
 washing,  and  use.
        Response:  The EPA agrees  that  drains that are  kept in wastewater
 collection  service will be maintained  primarily by the refinery wastewater
 that is received  from a process unit,   as well  as by precipitation and main-
 tenance washing.   Inspections  are still required, however, to make  sure that
 the water  seals are present or that seal pots  are properly capped.  Therefore,
 the inspection frequency has been reduced to monthly,   instead of weekly for
drains  in  active service.  For drains  that are  removed from service, there is
no assurance that use,  precipitation,  and maintenance washing  will maintain
the water seal.  Consequently, a weekly visual  or physical inspection is
still  required unless a tightly sealed  cap or plug is  installed.  A semiannual
inspection would be required for tightly sealed caps or plugs  on drains not
in active service.
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2.6.2  Comment:  One commenter recommended that the requirement for a flow
sensor on the flow vent gases to control  devices be eliminated (IV-D-1).  The
commenter stated that flow measurements of these streams are inaccurate,
unreliable, and subject to extensive maintenance requirements.
       Response:  As stated in Section 60.692-7(f)(4), the proposed regulation
requires that a flow indicator be installed on a vent stream to a control
device.  The regulation does not require that flowrate be measured.  Flow
indicators are defined as devices which indicate whether gas flow is present
in a vent stream.  This definition has been included in the regulation to
avoid any misunderstanding of the monitoring requirements.  The EPA has
determined that flow indicators are necessary to ensure that vent streams are
being continually routed to appropriate vapor recovery or destruction
devices.  The Agency has determined that the cost of this monitoring
requirement is reasonable.
2.6.3  Comment;  One commenter recommended that continuous monitoring of
flares by television monitors be allowed in addition to thermocouples and
heat sensing devices (IV-D-1).  The commenter stated that monitoring by
television monitors is equally effective and more reliable.
       Response:  The EPA has determined that detection of a flame by visual
means or by remote video camera is not a suitable monitoring method.  If a
flare is operating smokelessly it can be difficult to determine if a flame is
present.  Therefore, continuous monitoring of flares by television monitors
has not been included in the final standards.
2.6.4  Comment:  One commenter questioned the need for weekly monitoring of
lAF's (IV-D-7).  The commenter stated that maintaining good workplace habits
rather than conducting frequent inspections will guarantee the effectiveness
of control devices on these units and suggested that semiannual inspections
would be adequate to document whether such good habits are being practiced.
       Response:  The inspection and monitoring requirements for lAF's have
been deleted because, as explained in response to Comment 2.1.3, all air
flotation systems have been exempted from the final rule.
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 2.6.5  Comment:   One commenter noted that the definition  of "gas-tight
 condition" in Section 60.691  applicable to lAF's  includes a requirement for
 "no detectable emissions"  (IV-D-8).   The commenter believes this definition
 provides a rather uncertain and moving  target for compliance because the
 detectability of emissions can change with improvements  in testing  instru-
 ments and sophistication of testing  methods.   The commenter suggested that
 the definition be expanded to include "no detectable  emissions  as indicated
 by an instrument reading of less than 500 ppm above background  levels."
        Response:   As discussed in the response to Comment 2.1.3,  air
 flotation systems are not  covered under the final  standards.  However,  the
 comment is still  relevant  to  oil-water  separators vented  to control  devices
 or other affected facilities  with closed vent systems.  A requirement of "no
 detectable emissions" still applies  to  these  facilities.
      The requirement for "no  detectable emissions"  in both  the  proposal  and
 the final  standards  already includes  the provision  suggested  by the  commenter,
 As provided  in Section 60.691,  the term "no detectable emissions" means  less
 than 500 ppm above background  levels, as measured by a detection  instrument
 in accordance with EPA Method  21  in Appendix  A of 40 CFR  Part 60.
 2.6.6  Comment:   One commenter  stated that the time period  of 15  days to
 repair  leaking equipment was chosen arbitrarily and could be difficult to
 meet in  some cases (IV-D-8).  The commenter suggested that  the  rule  be
 amended  to set forth  conditions under which repair may be delayed beyond the
 15  days  in cases  where diligent efforts  to complete the repairs within
 15  days  have been  unsuccessful.
       Response:   Provisions were included in the proposed  regulation in
 Section  60.692-8  for delay of repair if the repair is technically impossible
 to make  without a  complete or partial refinery or process unit shutdown.  Two
 commenters endorsed the inclusion of this provision.  Provisions for delayed
 repair are included in Section 60.697(e)  (recordkeeping requirements) of the
 proposed regulation.   This section requires that an emission point or equip-
ment problem be repaired or corrected in 15 calendar days with the exception
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of drains and floating roofs.  Drains shall  be corrected within 24 hours and
floating roofs shall be repaired within 30 calendar days.  If the repair is
technically impossible to make without a complete or partial  refinery or
process unit shutdown, the expected date of successful  repair of leaking
equipment shall be recorded.  The Agency feels that 15  days allows ample time
for the type of minor repairs that may be necessary (for example, replacing
gaskets or seals).  Also, the provision for delay of repair for major repairs
that may require plant or process unit shutdown allows  the refiner sufficient
flexibility.  Therefore, in the final rule,  delay of repair provisions are
the same as those proposed.
2.6.7  Comment;  Three commenters stated that the applicability of "no
detectable emissions" to specific components of the refinery wastewater
system and the associated requirement for monitoring using a portable hydro-
carbon monitor to detect such emissions was inappropriate and that visual
inspection would be sufficient (IV-D-2, IV-D-4, IV-D-5).  Specifically, the
commenters objected to the application of the standards to equipment with
fixed roof controls that are not required to be vented  to a vapor recovery or
destruction control device, such as junction boxes and  oil-water separators.
       Response;  The final standards have been revised to delete the "no
detectable emissions" monitoring requirement for junction boxes, oil-water
separators, and other components of the affected refinery wastewater system
that are equipped with atmospheric or pressure control  vents not vented to a
control device.  The Agency agrees with the comment that visual inspection
coupled with follow-up repairs and maintenance is sufficient to prevent leaks
of VOC through faulty or poorly maintained joints, seals, or gaskets.
Therefore, the final standards are the same as proposed for visual inspection
of all joints, seams, access doors, and other emission sources on junction
boxes, sewer lines, oil-water separators and any other components of the
refinery wastewater system that are subject to the standards.
     For oil-water  separators with closed vent systems and other closed
systems, such  as closed drain systems, the "no detectable emissions"
requirement specified in the proposed rule is maintained  in the final rule.
For closed vent systems, monitoring and inspection would  be required of
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joints, seams, access doors, and other potential emission sources when  the
facility becomes subject to the standards, and semi annually thereafter  to
ensure that there are "no detectable emissions as indicated by an instrument
reading of less than 500 ppm above background levels."  The EPA Method  21
would be the applicable test method for these facilities.
2.6.8  Comment:  One commenter recommended that all inspection requirements
associated with the proposed regulation should coincide with the inspection
requirements in 52 FR 3748:  Proposed Standards to Limit Air Emissions  of
VOC's at Hazardous Waste Facilities (IV-D-7).  The commenter made the point
that by coordinating the inspection schedules, personnel can perform
inspections which will meet the requirements of both regulations.
       Response:  The commenter is referring to EPA's proposed air emission
standards for volatile organic control from hazardous waste treatment,
storage, and disposal facilities.   The proposed standards cited by the
commenter require a monthly leak detection and repair program for equipment
such as pumps, valves, and pressure relief devices.   Under the petroleum
refinery wastewater systems NSPS,  EPA is requiring that closed vent systems
be monitored for detectable emissions initially and semiannually.  This
requirement does not discourage an owner or operator from coordinating this
inspection with any other inspections they may be required to perform under
other regulations.   However, separate recordkeeping requirements will  still
apply.
                                     2-49

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                               —   TECHNICAL REPORT DATA
                               em read Instructions on the reverse before completing)
    EPA-450/3-85-001b
                                                              3. RECIPIENT'S ACCESSION NO.
    VOC Emissions from Petroleum Refinery Wastewater
    Systems -  Background Information for Promulgated
    Standards
                                                            5. REPORT OATE
                                                               December  1987
                                                            8. PERFORMING ORGANIZATION CODE
                                                             B. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
   Standards Development Branch
   Environmental Protection Agency
   Research Triangle  Park,  NC  27711
                                                              10. PROGRAM ELEMENT NO.

                                                                83/14
                                                                                         i i mu. i
                                                             11. CONTRACT/GftANT NO."

                                                                68-02-3816
                      ME AND ADDRESS
    DAA for Air Quality Planning  and Standards
    Office of Air  and Radiation
    U.S. Environmental  Protection Agency
    Research Triangle Park. North Carolina  ?7711
   SUPPI CIUEIUTADV- ti/t-ro.              w ¥1 I w < r I m  Ml I t t
                                                            13. TYPE OF REPORT AND PERIOD COVERED
                                                              Final
                                                             4. SPONSORING AGENCY CODE
                                                              EPA/200/04
 115. SUPPLEMENTARY NOTES
   Owners or operators  of petroleum refineries would be  required to meet certain
   emissions, design, operation, and work  practice standards  for their wastewater
   treatment systems.   This report contains  a summary of changes to the standards
   made  since proposal,  a summary of impacts of the promulgated standards, and  a
   summary of public comments and EPA responses on the proposal
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                               b.lOENTIFIERS/OPEN ENDED TERMS
                                                                          c.  COSATI Field/Gr
   Air pollution  control
   Intergovernmental  relations
   Reporting and  recordkeeping requirements
   Petroleum refining
                                                 Air pollution  control
18. DISTRIBUTION STATEMENT

  Unlimited
                                              19. SECURITY CLASS (Tllis Report)
                                                Unclassified
                                               20. SECURITY CLASS (Tliiipage)
                                                 Unclassified
21. NO. OF PAGES

     64
                                                                         22. PRICE
EPA Form 2220-1 (R«v. 4-77)   PREVIOUS COITION is OBSOLETE

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