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                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                WASHINGTON, D.C. 20460
                                                                         THE ADMINISTRATOR
Message from the Administrator

Over the past 25 years, our nation has made tremendous progress in protecting public health and
our environment while promoting economic prosperity. Businesses as large as iron and steel
plants and businesses as small as the dry cleaner on the corner have worked with EPA to find
ways to operate cleaner, cheaper, and smarter. As a result, we no longer have rivers catching on
fire. Our skies are clearer. American environmental technology and expertise are in demand
throughout the world.

The Clinton Administration recognizes that to continue this progress, we must move beyond the
pollutant-by-pollutant approaches of the past to comprehensive, facility-wide approaches for the
future. Industry by industry and community by community, we must build a new generation of
environmental protection.

Within the past two years, the Environmental Protection Agency undertook its Sector Notebook
Project to compile, for a number of key industries, information about environmental problems and
solutions, case studies and tips about complying with regulations. We called on industry leaders,
state regulators, and EPA staff with many years of experience in these industries and with their
unique environmental issues. Together with notebooks for 17 other industries, the notebook you
hold in your hand is the result.

These notebooks will help business managers to better understand their regulatory requirements,
learn more about how others in their industry have undertaken regulatory compliance and the
innovative methods some have found to prevent pollution in the first instance. These notebooks
will give useful information to state regulatory agencies moving toward industry-based programs.
Across EPA we will use this manual to better integrate our programs and improve our compliance
assistance efforts.

I encourage you to use this notebook to evaluate  and improve the way that together we achieve
our important environmental protection goals. I am confident that these notebooks will help us to
move forward in ensuring that - in industry after industry, community after community ~
environmental protection and economic prosperity go hand in hand.
                                               Carol M. Browm
           Recycled/Recyclable • Printed with Vegetable Based Inks on Recycled Paper (20% Postconsumer)

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Sector Notebook Project
Petroleum Refining
                                                                  EPA/310-R-95-013
                  EPA Office of Compliance Sector Notebook Project

                Profile of the Petroleum Refining Industry
                                  September 1995
                                Office of Compliance
                    Office of Enforcement and Compliance Assurance
                         U.S. Environmental Protection Agency
                             401 M St., SW (MC 2221-A)
                               Washington, DC 20460
                              For sale by the U.S. Government Printing Office
                      Superintendent of Documents, Mail Stop: SSOP, Washington, DC 20402-9328
                                  ISBN 0-16-048280-1
September 1995
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Sector Notebook Project
Petroleum Refining
This report is one in a series of volumes published by the U.S. Environmental Protection Agency
(EPA) to provide information of general interest regarding environmental issues associated with
specific industrial sectors.  The documents were developed under contract by Abt Associates
(Cambridge, MA), and Booz-Allen & Hamilton, Inc. (McLean, VA).  This publication may be
purchased from the Superintendent of Documents, U.S. Government Printing Office. A listing of
available Sector Notebooks and document numbers is included at the end of this document.
All telephone orders should be directed to:

       Superintendent of Documents
       U.S. Government Printing Office
       Washington, DC 20402
       (202) 512-1800
       FAX (202) 512-2250
       9:00 a.m. to 4:30 p.m., ET, M-F
Using the form provided at the end of this document, all mail orders should be directed to:

      U.S. Government Printing Office
      P.O. Box 371954
      Pittsburgh, PA  15250-7954
Complimentary volumes are available to certain groups or subscribers, such as public and academic
libraries, Federal, State, local, and foreign governments, and the media. For further information and
for answers to questions pertaining to these documents, please refer to the contact names and
numbers provided within this volume.
Electronic versions of all Sector Notebooks are available on the EPA Enviro$en$e Bulletin Board
and via the Internet on the Enviro$en$e World Wide Web. Downloading procedures are described
in Appendix A of this document.
Cover photograph by Steve Delaney, EPA.
September 1995
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Sector Notebook Project
                    Petroleum Refining
                       Contacts for Available Sector Notebooks
The Sector Notebooks were developed by the EPA Office of Compliance.  Particular questions
regarding the Sector Notebook Project in general can be directed to the EPA Work Assignment
Managers:
      Michael Barrette

      US EPA Office of Compliance
      401MSt.,SW(2223-A)
      Washington, DC 20460
      (202) 564-7019
Gregory Waldrip

US EPA Office of Compliance
401MSt.,SW(2223-A)
Washington, DC 20460
(202) 564-7024
Questions and comments regarding the individual documents can be directed to the appropriate
specialists listed below.
Document Number   Industry

EPA/310-R-95-001.  Dry Cleaning Industry
EPA/310-R-95-002.  Electronics and Computer Industry
EPA/310-R-95-003.  Wood Furniture and Fixtures Industry
EPA/310-R-95-004.  Inorganic Chemical Industry
EPA/310-R-95-005.  Iron and Steel Industry
EPA/310-R-95-006.  Lumber and Wood Products Industry
EPA/310-R-95-007.  Fabricated Metal Products Industry
EPA/310-R-95-008.  Metal Mining Industry
EPA/310-R-95-009.  Motor Vehicle Assembly Industry
EPA/310-R-95-010.  Nonferrous Metals Industry
EPA/310-R-95-011.  Non-Fuel, Non-Metal Mining Ind.
EPA/310-R-95-012.  Organic Chemical Industry
EPA/31O-R-95-013.  Petroleum Refining Industry
EPA/310-R-95-014.  Printing Industry
EPA/310-R-95-015.  Pulp and Paper Industry
EPA/310-R-95-016.  Rubber and Plastic Industry
EPA/310-R-95-017.  Stone, Clay, Glass and Concrete Ind.
EPA/310-R-95-018.  Transportation Equip. Cleaning Ind.
        Contact

        Joyce Chandler
        Steve Hoover
        Bob Marshall
        Walter DeRieux
        Maria Malave
        Seth Heminway
        Greg Waldrip
        Keith Brown
        Suzanne Childress
        Jane Engert
        Keith Brown
        Walter DeRieux
        Tom Ripp
        Ginger Gotliffe
        Maria Eisemann
        Maria Malave
        Scott Throwe
        Virginia Lathrop
Phone (202)

564-7073
564-7007
564-7021
564-7067
564-7027
564-7017
564-7024
564-7124
564-7018
564-5021
564-7124
564-7067
564-7003
564-7072
564-7016
564-7027
564-7013
564-7057
   A Federal Facilities Profile is tinder development and will be completed later in 1995.
   (Contact:  Sarah Walsh, 202-260-6118)
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 Sector Notebook Project
Petroleum Refining
                Industry Sector Notebook Contents: Petroleum Refining
List of Exhibits	  iii

List of Acronyms	  iv

I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT	1
   A. Summary of the Sector Notebook Project	1
   B. Additional Information	2

II. INTRODUCTION TO THE PETROLEUM REFINING INDUSTRY	3
   A. Introduction, Background, and Scope of the Notebook	3
   B. Characterization of the Petroleum Refining Industry	4
      1. Product Characterization	4
      2. Industry Size and Geographic Distribution	6
      3. Economic Trends  	10

III.  INDUSTRIAL PROCESS DESCRIPTION	13
   A. Industrial Processes in the Petroleum Refining Industry	13
      1. Crude Oil Distillation and Desalting	15
      2. Downstream Processing	18
      3. Supporting Operations	30
   B. Raw Material Inputs and Pollution Outputs in the Production Line	38
   C. Management of Chemicals in Wastestream	42

IV. CHEMICAL RELEASE AND TRANSFER PROFILE	45
   A. EPA Toxic Release Inventory for the Petroleum Refining Industry 	48
   B. Summary of Selected Chemicals Released  	55
   C. Other Data Sources	61
   D. Comparison of Toxic Release Inventory Between Selected Industries	63

V. POLLUTION PREVENTION OPPORTUNITIES 	67

VI. SUMMARY OF APPLICABLE FEDERAL STATUTES AND REGULATIONS  	77
   A. General Description of Major Statutes	77
   B. Industry Specific Requirements	88
   C. Pending and Proposed Regulatory Requirements  	99
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VII. COMPLIANCE AND ENFORCEMENT HISTORY	103
   A. Petroleum Refining Compliance History	107
   B. Comparison of Enforcement Activity Between Selected Industries  	109
   C. Review of Major Legal Actions	114

Vm. COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES	117
   A. Sector-Related Environmental Programs and Activities	117
   B. EPA Voluntary Programs	118
   C. Trade Association/Industry Sponsored Activity	122
      1. Environmental Programs  	122
      2. Summary of Trade Associations	124

IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/BIBLIOGRAPHY .. 127

END NOTES

APPENDIX A	A-l
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  Sector Notebook Project
                         Petroleum Refining
                                      List of Exhibits

Exhibit 1: U.S. Refinery Products and Yields	  5
Exhibit 2: Large Facilities Dominate Petroleum Refining Industry	  7
Exhibit 3: Crude Oil Distillation Capacity Located Primarily Along Coasts  	  8
Exhibit 4: U.S. Petroleum Refinery Distribution	  9
Exhibit 5: Top U.S. Companies with Petroleum Refining Operations	  10
Exhibit 6: Simplified Process Flow Diagram of Typical Refinery	  13
Exhibit 7: Crude Oil Distillation	  17
Exhibit 8: Simplified Thermal Cracker Flow Diagram	  18
Exhibit 9: Simplified Coker Flow Diagram	  20
Exhibit 10: Simplified Catalytic Cracking Flow Diagram	'...  22
Exhibit 11: Simplified Two-Stage Hydrocracker Flow Diagram 		  24
Exhibit 12: Simplified Hydrotreater Flow Diagram 	  26
Exhibit 13: Typical Refinery Wastewater Treatment System	  33
Exhibit 14: Simplified Glaus Sulfur Recovery Flow Diagram 	  34
Exhibit 15: Typical Material Outputs from Selected Petroleum Refining Processes  	  40
Exhibit 16: Source Reduction and Recycling Activity for Petroleum Industry (SIC 2911)
           as Reported within TRI	  43
Exhibit 17: 1993 Releases for Petroleum Refining Facilities in TRI,
           by Number of Facilities Reporting		  50
Exhibit 18:1993 Transfers  for  Petroleum Refining Facilities in TRI,
           by Number of Facilities Reporting	  52
Exhibit 19: Top 10 TRI Releasing Petroleum Refineries 	  54
Exhibit 20: Top 10 TRI Releasing Facilities Reporting Petroleum Refining SIC Codes to TRI  	  55
Exhibit 21: Pollutant Releases  (short tons/year) 	  61
Exhibit 22: Summary of 1993 TRI Releases and Transfers by Industry	  64
Exhibit 23: Toxics Release Inventory Data for Selected Industries	  65
Exhibit 24: Five-Year Enforcement and Compliance Summary for Petroleum Refining	  108
Exhibit 25: Five-Year Enforcement and Compliance Summary for Selected Industries 	  110
Exhibit 26: One-Year Inspection and Enforcement Summary for Selected Industries	  Ill
Exhibit 27: Five-Year Inspection and Enforcement Summary by Statute for Selected Industries  ..  112
Exhibit 28: One-Year Inspection and Enforcement Summary by Statute for Selected Industries ...  113
Exhibit 29: FY-1993,1994  Supplemental Environmental Projects Overview: Petroleum Refining .  116
Exhibit 30: 33/50  Program Participants Reporting SIC 2911 (Petroleum Refining)	  119
   September 1995
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                                List of Acronyms
AFS -        AIRS Facility Subsystem (CAA database)
AIRS -       Aerometric Information Retrieval System (CAA database)
BBFs -        Boilers and Industrial Furnaces (RCRA)
BOD -       Biochemical Oxygen Demand
CAA -       Clean Air Act
CAAA -      Clean Air Act Amendments of 1990
CERCLA -    Comprehensive Environmental Response, Compensation and Liability Act
CERCLIS -   CERCLA Information System
CFCs -       Chlorofluorocarbons
CO -         Carbon Monoxide
COD -       Chemical Oxygen Demand
CSI -        Common Sense Initiative
CWA -       Clean Water Act
D&B -       Dun and Bradstreet Marketing Index
ELP -        Environmental Leadership Program
EPA -        United States Environmental Protection Agency
EPCRA -     Emergency Planning and Community Right-to-Know Act
FIFRA -      Federal Insecticide, Fungicide, and Rodenticide Act
FINDS -      Facility Indexing System
HAPs -       Hazardous Air Pollutants (CAA)
HSDB -      Hazardous Substances Data Bank
IDEA -       Integrated Data for Enforcement Analysis
LDR -        Land Disposal Restrictions (RCRA)
LEPCs -      Local Emergency Planning Committees
MACT -      Maximum Achievable Control Technology (CAA)
MCLGs -     Maximum Contaminant Level Goals
MCLs -       Maximum Contaminant Levels
MEK. -       Methyl Ethyl Ketone
MSDSs -     Material Safety Data Sheets
NAAQS -     National Ambient Air Quality Standards (CAA)
NAFTA -     North American Free Trade Agreement
NCDB -      National Compliance Database (for TSCA, FIFRA, EPCRA)
NCP -        National Oil and Hazardous Substances Pollution Contingency Plan
NEIC -       National Enforcement Investigation Center
NESHAP -    National Emission Standards for Hazardous Air Pollutants
NO2 -        Nitrogen Dioxide
NOV -        Notice of Violation
NOX -        Nitrogen Oxides
NPDES -     National Pollution Discharge Elimination System (CWA)
NPL -        National Priorities List
September 1995
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NRC -      National Response Center
NSPS -      New Source Performance Standards (CAA)
OAR-      Office of Air and Radiation
OECA -     Office of Enforcement and Compliance Assurance
OPA -      Oil Pollution Act
OPPTS -    Office of Prevention, Pesticides, and Toxic Substances
OSHA -     Occupational Safety and Health Administration
OSW -      Office of Solid Waste
OSWER -   Office of Solid Waste and Emergency Response
OW-       Office of Water
P2 -         Pollution Prevention
PCS -       Permit Compliance System (CWA Database)
POTW -     Publicly Owned Treatments Works
RCRA -     Resource Conservation and Recovery Act
RCRIS -     RCRA Information System
SARA -     Superfund Amendments and Reauthorization Act
SDWA -    Safe Drinking Water Act
SEPs -      Supplementary Environmental Projects
SERCs -     State Emergency Response Commissions
SIC -        Standard Industrial Classification
SO2 -       Sulfur Dioxide
SOX-        Sulfur Oxides
TOC -      Total Organic Carbon
TRI -       Toxic Release Inventory
TRIS -      Toxic Release Inventory System
TCRIS -     Toxic Chemical Release Inventory System
TSCA -      Toxic Substances Control Act
TSS -       Total Suspended Solids
UIC -       Underground Injection Control (SDWA)
UST -      Underground Storage Tanks (RCRA)
VOCs -      Volatile Organic Compounds
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Petroleum Refitting
I.  INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT

LA. Summary of the Sector Notebook Project

                    Environmental policies based upon comprehensive analysis of air, water and
                    land pollution are an inevitable and logical supplement to traditional single-
                    media approaches to environmental protection.  Environmental regulatory
                    agencies are beginning to embrace comprehensive, multi-statute solutions to
                    facility permitting, enforcement and compliance assurance,  education/
                    outreach, research, and regulatory development issues. The central concepts
                    driving the  new policy direction are  that  pollutant releases  to  each
                    environmental medium (air, water and land) affect every other,  and that
                    environmental strategies must actively identify  and address  these inter-
                    relationships by designing policies for the "whole" facility.  One way to
                    achieve a whole facility focus is to design environmental policies for similar
                    industrial facilities.  By doing so, environmental concerns that are common
                    to  the manufacturing  of  similar  products can be  addressed  in a
                    comprehensive manner. Recognition of the need to develop the industrial
                    "sector-based" approach within the EPA Office of Compliance led to  the
                    creation of this document.

                    The Sector Notebook Project was initiated by the Office of Compliance
                    within the Office of Enforcement and Compliance Assurance (OECA) to
                    provide its  staff and managers  with summary information for eighteen
                    specific industrial sectors..  As  other EPA offices, states,  the regulated
                    community, environmental groups,  and the public became interested in this
                    project, the scope of the original project was expanded. The ability to design
                    comprehensive,  common sense environmental protection  measures  for
                    specific industries is dependent on knowledge of several inter-related topics.
                    For the purposes of this project, the key elements chosen for inclusion are:
                    general industry information (economic and geographic); a description of
                    industrial processes; pollution outputs; pollution prevention opportunities;
                    Federal statutory and regulatory framework; compliance history; and a
                    description  of partnerships  that have been  formed between regulatory
                    agencies, the regulated community and the public.

                    For any given industry, each topic listed above could alone be the subject of
                    a lengthy volume.  However,  in order to produce a manageable document,
                    this project focuses on providing summary information for each topic.  This
                    format provides the reader with a  synopsis of each issue, and references
                    where more in-depth information is  available. Text within each profile was
                    researched from a variety of sources, and was usually condensed from more
                    detailed sources pertaining to specific topics.  This approach allows  for a
                    wide  coverage of activities that can be further explored based upon  the
                    citations and references listed at the end of this profile. As a check on the
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Petroleum Refining
                    information included, each notebook went through  an external review
                    process. The Office of Compliance appreciates the efforts of all those that
                    participated in this process and enabled us to  develop more complete,
                    accurate and up-to-date summaries.  Many of those who reviewed this
                    notebook are  listed as  contacts in Section IX and  may be sources of
                    additional information.  The individuals and groups on the list do not
                    necessarily concur with all statements within this notebook.

I.B. Additional Information
Providing Comments
                    OECA's Office of Compliance plans to periodically review and update the
                    notebooks and will make these updates available both in hard copy and
                    electronically.  If you have any comments on the existing notebook, or if you
                    would like to provide additional information, please send a hard copy and
                    computer disk to the EPA Office of Compliance, Sector Notebook Project,
                    401 M St., SW (2223-A), Washington, DC 20460. Comments can also be
                    uploaded to the Enviro$en$e Bulletin Board or the Enviro$en$e World Wide
                    Web for general access to all users of the system. Follow instructions in
                    Appendix A for accessing these data systems.  Once you have logged in,
                    procedures for uploading text are available from the on-line Enviro$en$e
                    Help System.
Adapting Notebooks to Particular Needs
                    The scope of the existing notebooks reflect an approximation of the relative
                    national occurrence of facility types that occur within each sector, hi many
                    instances, industries within specific geographic regions or states may have
                    unique characteristics that are not fully captured in these profiles. For this
                    reason, the Office of Compliance encourages state and local environmental
                    agencies and other groups to supplement or re-package the information
                    included in this notebook to include more specific industrial and regulatory
                    information that may be available. Additionally, interested states may want
                    to  supplement  the  "Summary of Applicable Federal  Statutes  and
                    Regulations" section with state and local requirements.   Compliance or
                    technical assistance providers may  also want to develop the "Pollution
                    Prevention" section in more detail. Please contact the appropriate specialist
                    listed on the opening page of this notebook if your office is interested in
                    assisting us hi the further development of the  information or policies
                    addressed within this volume.

                    If you are interested in assisting in the development of new notebooks for
                    sectors not covered in the original eighteen, please contact the Office of
                    Compliance at 202-564-2395.
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Petroleum Refining
II. INTRODUCTION TO THE PETROLEUM REFINING INDUSTRY

                     This  section provides background information on  the  size, geographic
                     distribution, employment, production, sales, and economic condition of the
                     petroleum refining industry.  The type of facilities  described within the
                     document are also  described  in terms  of their  Standard  Industrial
                     Classification (SIC) codes. Additionally, this section contains a list of the
                     largest companies in terms of sales.

II. A.  Introduction, Background, and Scope of the Notebook

                     Petroleum refining is one of the leading manufacturing industries  in the
                     United States in terms of its share of the total value of shipments of the U.S.
                     economy.  In relation to its economic importance, however, the industry is
                     comprised of relatively few companies and facilities.  The number of
                     refineries operating in the U.S. can vary significantly depending on the
                     information source. For example, in 1992, the Census Bureau counted 232
                     facilities and the Department of Energy reported 199 facilities. In addition,
                     EPA's Toxic  Release Inventory for 1993 identified 159 refineries.  The
                     differences lie in each organization's definition of a refinery.  The Census
                     Bureau's definition is based on the type of product that a facility produces
                     and includes  a number of very  small operations producing a specific
                     petroleum product, such as lubricating oils, from other refined petroleum
                     products.  These small facilities often employ fewer than  10 people and
                     account for only one to two of the petroleum refining industry's total value
                     of shipments.1 In comparison to the typically much more complex, larger
                     and more numerous crude oil processing refineries, these facilities with their
                     smaller and relatively simple operations do  not warrant the same level of
                     attention  from an  economic  and  environmental compliance standpoint.
                     Refineries recognized by the Department of Energy tend to be only the larger
                     facilities which process crude oil into refined petroleum products.3

                     Whenever possible, the facility level data used in this notebook are based on
                     those refineries identified by the Department of Energy's Energy Information
                     Administration. Since the Energy and Information Administration does not
                     collect economic, employment and environmental release information on
                     refineries, other facility level data sources were used. Thus, employment and
                     sales data are based on information collected through the Bureau of Census'
                     Census of Manufacturers for 1992 and environmental release information
                     was obtained from EPA's Toxic Release Inventory.
" Variations in facility counts occur across data sources due to many factors including, reporting and definitional
differences. This notebook does not attempt to reconcile these differences, but rather reports the data as they are
maintained by each source.
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Petroleum Refining
H.B. Characterization of the Petroleum Refining Industry

       II.B.1. Product Characterization
                     Petroleum refining is the physical, thermal and chemical separation of crude
                     oil into its major distillation fractions which are then further processed
                     through a series of separation and conversion steps into finished petroleum
                     products.   The primary  products  of the  industry fall into three major
                     categories: fuels (motor gasoline, diesel and distillate  fuel oil, liquefied
                     petroleum gas, jet fuel, residual fuel oil, kerosene,  and coke); finished
                     nonfuel products (solvents,  lubricating oils, greases, petroleum  wax,
                     petroleum jelly, asphalt, and coke); and chemical  industry feedstocks
                     (naphtha, ethane, propane, butane, ethylene, propylene, butylenes, butadiene,
                     benzene, toluene, and xylene). These petroleum products comprise about 40
                     percent of the total energy consumed in the U.S.2 (based on BTUs consumed)
                     and are used as primary input to a vast number of products, including:
                     fertilizers, pesticides, paints, waxes, thinners, solvents,  cleaning fluids,
                     detergents, refrigerants, anti-freeze, resins, sealants, insulations, latex, rubber
                     compounds, hard plastics, plastic sheeting, plastic foam and synthetic fibers.3
                     About 90 percent of the petroleum products used in the U.S. are fuels with
                     motor gasoline accounting for about 43 percent of the total4 (Exhibit 1).

                     The Standard Industrial Classification (SIC) code established by the Bureau
                     of Census to track the flow of goods and services within the economy is 29
                     for the Petroleum Refining and Related Industries. The petroleum refining
                     industry  is classified as SIC 2911, which includes the production of
                     petroleum products through distillation and fractionation  of crude oil,
                     redistillation  of unfinished petroleum derivatives,  cracking,  or other
                     processes.  The related industries under SIC 29 are: 2951, Asphalt Paving
                     Mixtures and Blocks; 2952, Asphalt Felts and Coatings; 2992, Lubricating
                     Oils and Greases; and 2999, Petroleum and Coal Products, Not Elsewhere
                     Classified.  Certain  products that are produced by the petroleum refining
                     industry are also  produced by other industries,  including: 2865, Cyclic
                     Organic Crudes and Intermediates, and Organic Dyes and Pigments; 2869,
                     Industrial Organic Chemicals;  2819,  Industrial Inorganic  Chemicals,  Not
                     Elsewhere  Classified;  2821,  Plastic  Materials,  Synthetic  Resins,
                     Nonvulcanizable Elastomers; 2873, Nitrogenous Fertilizers; 4613, Refined
                     Petroleum Pipelines; and 5171, Petroleum Bulk Stations and Terminals.5
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Sector Notebook Project
                                     Petroleum Refining
                            MOTOR GASOLINE (43%)
     LIQUEFIED PETROLEUM
     GASES (4.0%)
      • PROPANE
      • ETHANE
      • BUTANE

      FUEL COKE (4.0%)


      KEROSENE (0.3%)
       • ILLUMINATION
       • SPACE HEATING
       • COOKING
       • TRACTOR FUEL
  DISTILLATE FUEL OIL (20.2%)
   • DIESEL FUEL
   • HOME HEATING OIL
   • INDUSTRIAL FUEL
FUEL PRODUCTS 87.5%
            NONFUEL
           PRODUCTS
              5.2%
          ASPHALT AND ROAD OIL
          LUBRICANTS
          NAPHTHA SOLVENTS
          WAXES
          NONFUEL COKE
          MISCELLANEOUS PRODUCTS
RESIDUAL FUEL OIL (6.0%)
 • BUNKER FUEL
 • BOILER FUEL
                           JET FUELS (10%)
                            • KEROSENE TYPE
                            •NAPTHATYPE
                           REFINERY FUEL (4.0%)
                            • REFINERY GAS
                            • REFINERY FUEL OIL
                           PETROCHEMICAL
                            FEEDSTOCKS
                               3.3%
                           NAPHTHA   PROPYLENE
                           ETHANE    BUTYLENE
                           PROPANE
                           BUTANE
          BENZENE
          TOLUENE
ETHYLENE   XYLENE
                                                          ETC.
    (Source: Based on Energy Information Administration, The U.S. Petroleum Industry: Past as Prologue 1970-1992,
                                 September 1993.)


            Exhibit 1: U.S. Refinery Products and Yields
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II.B.2. Industry Size and Geographic Distribution
                    Generally, the petroleum refining  industry can be characterized by a
                    relatively small number of large facilities.  The Department of Energy
                    reported 176 operating petroleum refineries in 1994 with a total crude oil
                    distillation capacity of approximately 15 million barrels per day. Most U.S.
                    crude oil distillation capacity is owned by large, integrated companies with
                    multiple high capacity refining facilities.  Small refineries with capacities
                    below 50,000 barrels per day, however, do play a  significant role in the
                    industry, making up about half of all facilities, but  only 14 percent of the
                    total crude distillation capacity.6

                    A relatively small number of people are employed by the petroleum refining
                    industry in relation to its economic importance. The Bureau of the Census
                    estimates that 75,000 people were directly employed by the  industry  in
                    1992.7 However, the industry also indirectly employs a significant number
                    of outside contractors for many refinery operations, both routine and non-
                    routine. The value of product shipments sold by refining establishments was
                    estimated to be $136 billion in 1992. This accounts for about 4 percent of the
                    value of shipments for the entire U.S. manufacturing sector.8 Based on the
                    number of people directly employed by refineries, the industry has a high
                    value of shipments per employee of $1.8 million. In comparison, the value
                    of  shipments per employee for  the steel manufacturing industry was
                    $245,000 for the same year.9

                    The Bureau of Census employment data for 1992 (the most recent facility-
                    based employment data available) indicated that 60 percent of petroleum
                    refineries had over 100 employees10 (Exhibit 2).
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Exhibit 2: Large Facilities Dominate
Petroleum Refining Industry
Employees per
Facility
1-4
5-9
10-19
20-49
50-99
100-249
250-499
500-999
1000-2499
Total
Number of Facilities
17
7
11
35
22
45
49
26
20
232
Percentage of Facilities
7%
3%
5%
15%
10%
19%
21%
11%
9%
100%
Source: Census of Manufacturers, 1992.
                     For reasons of efficiency in transporting crude oil feed stocks and finished
                     products, petroleum refineries typically were sited near crude oil sources
                     (onshore petroleum terminals, oil and gas extraction areas) or consumers
                     (heavily industrialized areas).  Consequently, the distribution of facilities is
                     more concentrated along the Gulf Coast and near the heavily industrialized
                     areas of both east and west coasts (Exhibits 3 and 4). Based on Department
                     of Energy data for 1994,78 percent of the U.S. crude oil distillation capacity
                     (which is indicative of the amount of crude oil processed) is located in just
                     ten states11 (Exhibit 3).
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Exhibit 3: Crude Oil Distillation Capacity Located Primarily
Along Coasts
State
Texas
Louisiana
California
Illinois
Pennsylvania
Washington
Ohio
New Jersey
Indiana
Oklahoma
Subtotal
Other States (also
includes Virgin Islands
and Puerto Rico)
U.S. Total
Number of
Operable
Refineries
30
19
25
7
8
6
4
4 -.
2
7
112
64
176
Crude Distillation
Capacity (thousand
barrels per day)
3,764
2,360
1,882
956
655
524
430
462
421
404
11,858
3,355
15,213
Percent of U.S.
Total Distillation
Capacity
25%
16%
12%
6%
4%
3%
3%
3%
3%
3%
78%
22%
100%
Source: U.S. Department of Energy/Energy Information Administration, 1994.
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                                       Exhibit 4
                      U.S. Petroleum Refinery Distribution
            Alaska: 4 Refineries
            Hawaii: 2 Refineries
            Puerto Rico: 4 Refineries
            U.S. Virgin Islands: 1 Refinery
                                                          300 400
(Source: U.S. EPA Toxic Release Inventory Database, 1993.)
                     Ward's Business Directory of U.S. Private and Public Companies., produced
                     by Gale Research Inc., compiles financial data on U.S. companies including
                     those operating within the petroleum refining industry. Ward's ranks U.S.
                     companies, whether they are a parent company, subsidiary or division, by sales
                     volume within the 4-digit SIC codes that they have been assigned as their
                     primary activity.  Readers should note that:  1) companies are assigned a 4-
                     digit SIC that most closely  resembles their principal industry; and 2) sales
                     figures include total company sales, including sales derived from subsidiaries
                     and operations not related  to petroleum refining.  Additional sources of
                     company specific financial  information include Standard  & Poor's Stock
                     Report Services, Dun & Bradstreet's Million Dollar Directory, Moody's
                     Manuals, and annual reports.
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Exhibits:
Top U.S. Companies with Petroleum Refining Operations
Rank*
1
2
3
4
5
6
7
8
9
10
Company1"
Exxon Corporation - Irving TX
Mobil Corporation - Fairfax, VA
El du Pont de Nemours and Co. (Conoco Inc.,
Subsidiary) - Wilmington, DE
Texaco Inc. - White Plains, NY
Chevron Corporation - San Francisco, CA .
Amoco Oil Corporation - Chicago, EL
Shell Oil Company - Houston, TX
Atlantic Richfield Company - Los Angeles, CA
BP America Incorporated - Cleveland, OH
Caltex Petroleum Corporation - Dallas, TX
1993 Sales
(millions of dollars)
102,847
56,910
38,031
37,271
35,523
22,320
22,201
18,922
16,200
15,100
Note: * When Ward's Business Directory listed both a parent and subsidiary in the top ten,
only the parent company is presented above to avoid double counting sales volumes.
Not all sales can be attributed to the companies' petroleum refining operations.
b Companies shown listed SIC 2911 as primary activity.
Source: Ward's Business Directory of U.S. Private and Public Companies - 1993.
       II.B.3. Economic Trends
                    The United States is a net importer of crude oil and petroleum products.  In
                    1994, imports accounted for more than 50 percent of the crude oil used in the
                    U.S. and about 10 percent of finished petroleum products.12 The imported
                    share of crude oil  is expected to increase as U.S. demand for petroleum
                    products increases and the  domestic  production of crude oil declines.
                    Imported finished petroleum products serve specific market niches arising
                    from logistical considerations, regional  shortages,  and long-term trade
                    relations between  suppliers  and refiners.  Exports of refined petroleum
                    products, which primarily consist of petroleum coke, residual fuel oil, and
                    distillate fuel oil, account for about four percent of the U.S. refinery output.
                    Exports of crude oil produced in the U.S. account for about one percent of
                    the total U.S. crude oil produced and imported.13
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                    The petroleum refining industry in the U.S. has felt considerable economic
                    pressures in the past decade arising from a number of factors including:
                    increased costs of labor; compliance with new safety and environmental
                    regulations; and the elimination of government subsidies through the Crude
                    Oil Entitlements Program which had encouraged smaller refineries to add
                    capacity throughout the 1970s.14 A rationalization period began after crude
                    oil pricing and entitlements were decontrolled in early 1981.  The market
                    determined that there was surplus capacity and the margins dropped to
                    encourage the closure of the least efficient capacity.  Reflecting these
                    pressures, numerous facilities have closed in recent years.15 Between 1982
                    and 1994, the number of U.S. refineries as determined by the Department of
                    Energy dropped from 301 to 176. Most of these closures have involved
                    small facilities refining less than 50,000 barrels of crude oil per day. Some
                    larger facilities,  however, have also closed in response to economic
                    pressures.16 Industry representatives cited complying with the increasing
                    environmental regulations, particularly, the requirements of the Clean Air
                    Act Amendments of 1990, as the most important factor affecting petroleum
                    refining in the 1990s.17  Despite the closing of refineries in recent years, total
                    refinery output of finished products has remained relatively steady with slight
                    increases in the past two years.  Increases in refinery outputs are attributable
                    to higher utilization rates of refinery capacity, and to incremental additions
                    to the refining capacity at existing facilities as opposed to construction of
                    new refineries.18

                    Demand  for refined petroleum products is expected to increase slowly
                    through 1998 with the growth of the U.S. economy. The rate of increase will
                    average about 1.5 percent per year, which is slower than the expected growth
                    of the economy. This slower rate of increase of demand will be due to
                    increasing prices of petroleum products as a result of conservation, the
                    development  of substitutes for petroleum products, and rising costs of
                    compliance with environmental and safety requirements.19

                    Recent and future environmental and safety regulatory changes are expected
                    to force the petroleum refining industry to make substantial investments in
                    upgrading certain refinery processes to reduce emissions and alter product
                    compositions. For example, industry estimates of the capital costs to comply
                    with the 1990 Clean Air Act Amendments, which mandates specific product
                    compositions are about $35 to $40 billion.20 There is concern that in some
                    cases it may be more economical for some refineries to close down partially
                    or entirely rather than upgrade facilities to meet the new standards. In fact,
                    the U.S. Departments of Energy and Commerce expect refinery shutdowns
                    to continue through the 1990s; however, total crude oil distillation capacity
                    is expected to remain relatively stable as a result of increased capacity and
                    utilization rates at existing facilities.   Increases in demand  for finished
                    petroleum products will be filled by increased imports.
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III. INDUSTRIAL PROCESS DESCRIPTION

                    This section describes the major industrial processes within the petroleum
                    refining  industry,  including the materials and equipment  used, and the
                    processes employed.  The section is designed for those interested in gaming
                    a general understanding of the industry, and for those interested in the inter-
                    relationship between the industrial process and the topics described in
                    subsequent sections of this profile -- pollutant outputs, pollution prevention
                    opportunities, and Federal regulations.  This section does not attempt to
                    replicate published engineering information that is available for this industry.
                    Refer to Section IX for a list of reference documents that are available.

                    This section specifically contains a description of commonly used production
                    processes, associated raw materials, the byproducts produced or released, and
                    the materials either recycled or transferred off-site. This discussion, coupled
                    with schematic  drawings of the identified processes,  provide a concise
                    description of where wastes may be produced in the process. This section
                    also describes the potential fate (via air, water, and soil pathways) of these
                    waste products.

III.A.  Industrial Processes in the Petroleum Refining Industry

                    Crude oil is a mixture of many different hydrocarbons and small amounts of
                    impurities. The composition of crude oil can vary significantly depending
                    on its source.   Petroleum refineries are a complex system of multiple
                    operations and the operations used at a given refinery depend upon the
                    properties of the crude oil to be refined and the desired products.  For these
                    reasons, no two refineries are alike.  Portions of the outputs from some
                    processes are refed back into the same process, fed to new processes, fed
                    back to a previous process, or blended with other outputs to form finished
                    products (Exhibit 6).   The major unit operations typically involved at
                    petroleum refineries are described briefly below. In addition to those listed
                    below, there  are  also many special purpose  processes that cannot be
                    described here and which may play an important role in a facility's efforts to
                    comply with pollutant discharge and product specification requirements.
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                     I §
                               Efi
                                   ...PA L
        (Source: Based on Gary & Handwerk, Petroleum Refining Technology and Economics, 3rd Edition, Marcel &
                                Dekker, Inc., New York, NY, 1994.)


         Exhibit 6: Simplified Process Flow Diagram of Typical Refinery
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                     Refilling crude oil into useful petroleum products can be separated into two
                     phases and a number of supporting operations. The first phase is desalting
                     of crude oil  and the subsequent distillation into its various components or
                     "fractions" (Section IH.A.1). The second phase is made up of three different
                     types of "downstream" processes: combining,  breaking, and reshaping
                     (Section in.A.2).   Downstream processes convert some of the distillation
                     fractions into petroleum products (residual fuel oil, gasoline, kerosene, etc.)
                     through any combination of different cracking, coking,  reforming,  and
                     alkylation processes.   Supporting operations may include  wastewater
                     treatment, sulfur recovery, additive production, heat exchanger cleaning,
                     blowdown systems, blending of products, and storage of products (Section
                     III.A.3). Refinery pollutant outputs are discussed in more detail in Section
                     III.B.

       III.A.1.  Crude Oil Distillation and Desalting

                     One of the most important operations in a refinery is the initial distillation of
                     the crude oil into its various boiling point fractions. Distillation involves the
                     heating, vaporization, fractionation, condensation, and cooling of feedstocks.
                     This section discusses the atmospheric and  vacuum distillation processes
                     which when used in sequence result in lower costs and higher efficiencies.
                     This section also discusses the important first step of desalting the crude oil
                     prior to distillation.
       Desalting
                     Before separation into fractions, crude oil usually must first be treated to
                     remove corrosive salts.  The desalting process also removes some of the
                     metals and suspended solids which cause catalyst deactivation. Desalting
                     involves the mixing of heated crude oil with water (about three to 10 percent
                     of the crude oil volume) so that the salts are dissolved in the water.21  The
                     water must then be separated from the crude oil in a separating vessel by
                     adding demulsifier chemicals to assist in breaking the emulsion and/or, more
                     commonly,  by applying a high potential electric field across the settling
                     vessel to coalesce the polar salt water droplets. The desalting process creates
                     an oily desalter sludge and a high temperature salt water waste stream which
                     is typically added to other process wastewaters for treatment in the refinery
                     wastewater treatment facilities. The water used in crude desalting is often
                     untreated or partially treated  water from  other refining process water
                     sources.22
       Atmospheric Distillation
                     The desalted crude oil is then heated in a heat exchanger and furnace to about
                     750 degrees (F) and fed to a vertical, distillation column at atmospheric
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                     pressure where most of the feed is vaporized and separated into its various
                     fractions by condensing on 30 to 50 fractionation trays, each corresponding
                     to a different condensation temperature. The lighter fractions condense and
                     are collected towards the top of the column. Heavier fractions, which may
                     not vaporize in the column, are further separated later by vacuum distillation.
                     Within each atmospheric distillation tower, a number of side streams (at least
                     four) of low-boiling point components are removed from the tower from
                     different trays.  These low-boiling point mixtures are in equilibrium with
                     heavier components which must be removed. The side  streams are each sent
                     to a different small stripping tower containing four to 10 trays with steam
                     injected under the bottom tray. The steam strips the light-end components
                     from the heavier components and both the steam and light-ends are fed back
                     to the atmospheric distillation tower above the corresponding side stream
                     draw tray.23  Fractions obtained from atmospheric distillation include
                     naphtha, gasoline, kerosene, light fuel oil, diesel oils, gas oil, lube distillate,
                     and heavy bottoms.  Most of these can be sold as finished products, or
                     blended with products from downstream  processes. Another product
                     produced  in  atmospheric distillation, as well as many  other refinery
                     processes, is the light, noncondencible refinery fuel gas  (mainly methane and
                     ethane).  Typically this gas also  contains hydrogen sulfide and ammonia
                     gases. The mixture of these gases is known as "sour gas" or "acid gas." The
                     sour gas is sent to the refinery sour gas treatment system which separates the
                     fuel gas so that it can be used as fuel in the refinery heating furnaces.  Air
                     emissions during atmospheric distillation arise from the combustion of fuels
                     in the furnaces to heat the crude oil, process vents and fugitive emissions.
                     Oily sour water (condensed steam containing hydrogen sulfate and ammonia)
                     and oil is also generated in the fractionators24 (Exhibit  7).
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                                Lightest fractions have the lowest
                                boiling points and continue to rise
                                through trays to top of column
                                where they are drawn off.
                                        Bubble Caps

                                   Liquid Downflow

                                            Vi
                      DESALTED
                      CRUDE OIL
                         Butane and Lighter i^-
                         Gas Processing/Recovery
                         Isomerization

                          Straight Run Gasoline
                          Motor Gasoline Blending
                         N&phtha ^^
                         Catalytic Reforming
                                                                           Kerosene ^    x
                                                                           Hydrotreating     ID
                                                                           Middle Distillate   [L
                                                                           Fuel Blending     HI


                                                                           Light Gas Oil •*•
                                                                           Distillate Fuel Blending
                                                                           Catalytic Cracking
                                                                           Thermal Cracking
                                                                            Heavy Gas Oil •»•
                                                                            Catalytic Cracking
                                                                            Thermal Cracking
                                                                           Straight Run Residue i
                                                                           Vacuum Distillation
                                                                           Thermal Cracking
                                                                           Coking
                  (Source: Based on Energy Information Administration, The U.S. Petroleum Industry: Pastas Prologue
                                               1970-1992, September 1993.)
                                   Exhibit 7:  Crude Oil Distillation
         Vacuum Distillation
                        Heavier  fractions from the  atmospheric  distillation unit  that  cannot be
                        distilled without cracking under its pressure and temperature conditions are
                        vacuum distilled. Vacuum distillation is simply the distillation of petroleum
                        fractions at a very low pressure (0.2 to 0.7 psia) to increase volatilization and
                        separation. In most systems, the vacuum inside the fractionator is maintained
                        with steam ejectors and vacuum pumps, barometric condensers or surface
                        condensers.  The injection of superheated steam at the base of the vacuum
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                     fractionator column further reduces the partial pressure of the hydrocarbons
                     in the tower, facilitating vaporization and separation.  The heavier fractions
                     from the vacuum distillation column are processed downstream into more
                     valuable products through either cracking or coking operations (See Section
                     m.A.2.).25

                     A potential source  of emissions from  distillation of crude oil are the
                     combustion of fuels in the furnace and some light gases leaving the top of the
                     condensers on the vacuum distillation column.  A certain  amount of
                     noncondensable light hydrocarbons and hydrogen sulfide pass through the
                     condenser to a hot well, and then are discharged to the refinery sour fuel
                     system or are vented to a process heater, flare or another control device to
                     destroy hydrogen sulfide. The quantity of these emissions depends on the
                     size of the unit, the type of feedstock, and the cooling water temperature.26
                     If barometric condensers are used in vacuum distillation, significant amounts
                     of oily wastewater can be generated.  Vacuum pumps and surface condensers
                     have largely replaced barometric condensers in many refineries to eliminate
                     this oily wastewater stream.  Oily sour water is also generated in the
                     fractionators.27

       III.A.2. Downstream Processing

                     Certain fractions from the distillation of crude oil are further refined in
                     thermal  cracking (visbreaking),  coking, catalytic  cracking,  catalytic
                     hydrocracking,  hydrotreating,  alkylation, isomerization, polymerization,
                     catalytic   reforming,  solvent   extraction, merox,   dewaxing,  propane
                     deasphalting and other operations. These downstream processes change the
                     molecular structure of hydrocarbon molecules either by breaking them into
                     smaller molecules, joining them to form larger molecules, or reshaping them
                     into higher quality molecules. For many of the operations discussed below,
                     a number of different techniques are used in the industry. While the major
                     techniques used for each process are described, it was not possible to discuss
                     all of the different processes currently in use.

       Thermal Cracking/Visbreaking

                     Thermal cracking, or visbreaking, uses heat and pressure to break large
                     hydrocarbon molecules into smaller, lighter molecules. The process has been
                     largely replaced by catalytic cracking and some refineries no longer employ
                     thermal cracking.  Both processes reduce the production of less valuable
                     products such as heavy fuel oil and cutter stock and increase the feed stock
                     to the catalytic cracker and gasoline yields. In thermal cracking, heavy gas
                     oils and residue from the vacuum distillation process are typically the feed
                     stocks. The feed stock is heated in a furnace or other thermal unit to up to
                     1,000 degrees (F) and then fed to a reaction chamber which is kept at a
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                                                                       FUEL GAS
                                                                         AND
                                                                        IGHTENDS
                                                                     TO AMINE UNITS
             (Source: Based on Gary & Handwerk, Petroleum Refining Technology and Economics, 3rd Edition, Marcel
              Dakker, Inc., New York, NY, 1994, and U.S. EPA Office of General Enforcement, Petroleum Refinery
                                       Enforcement Manual, 1990.)


              Exhibit 8:  Simplified Thermal Cracker Flow Diagram
                    pressure of about 140 psig. Following the reactor step, the process stream is
                    mixed with a cooler recycle stream, which stops the cracking reactions. The
                    product is then fed to a flasher chamber, where pressure is reduced and
                    lighter products vaporize and are drawn off. The lighter products are fed to
                    a fractionating tower where the  various fractions  are separated.  The
                    "bottoms" consist of heavy residue, part of which is recycled to cool the
                    process stream leaving the reaction chamber; the  remaining  bottoms are
                    usually blended into residual fuel (Exhibit 8).28

                    Air emissions from thermal cracking include emissions from the combustion
                    of fuels hi the process heater, vents, and fugitive emissions.29 A sour water
                    stream is generated in the fractionator.30
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       Coking
                    Coking is a cracking process used primarily to reduce refinery production of
                    low-value residual fuel oils to transportation fuels, such as gasoline and
                    diesel. As part of the upgrading process, coking also produces petroleum
                    coke, which is essentially solid carbon with varying amounts of impurities,
                    and is used as a fuel for power plants if the sulfur content is low enough.
                    Coke also has nonfuel applications as a raw material for many carbon and
                    graphite  products including  anodes for the production of aluminum, and
                    furnace electrodes for  the production of elemental phosphorus, titanium
                    dioxide,  calcium carbide and silicon carbide.31  A number of different
                    processes are used to produce coke; "delayed coking" is the most widely used
                    today, but "fluid coking" is expected to be an Important process in the future.
                    Fluid coking produces  a higher grade of coke which is increasingly in
                    demand. In delayed coking  operations, the same basic process as thermal
                    cracking is used except feed streams are allowed to react longer without
                    being cooled. The delayed coking feed stream of residual  oils from various
                    upstream processes is first introduced to a fractionating tower where residual
                    lighter materials are drawn off and the heavy ends are condensed.  The heavy
                    ends are removed and heated in a furnace to about 900 - 1,000 degrees (F)
                    and then fed to an insulated vessel called a coke drum where the coke is
                    formed.  When the coke drum is filled with product, the feed is switched to
                    an empty parallel drum. Hot vapors from the coke drums, containing cracked
                    lighter hydrocarbon products, hydrogen sulfide, and ammonia, are fed back
                    to the fractionator where they can be treated hi the sour gas  treatment system
                    or drawn off as intermediate products. Steam is then injected into the full
                    coke drum to remove hydrocarbon vapors, water is injected to cool the coke,
                    and the coke is removed. Typically, high pressure water jets are used to cut
                    the coke from the drum (Exhibit 9).32

                    Air emissions from coking operations include the process heater  flue gas
                    emissions, fugitive emissions and emissions that may arise  from the  removal
                    of the coke from the coke drum. The injected steam is condensed and the
                    remaining vapors are typically flared. Wastewater is generated from the coke
                    removal  and cooling operations and from the steam injection. In addition,
                    the removal of coke from the  drum can release participate emissions and any
                    remaining hydrocarbons to the atmosphere.
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                            nn
                               COKE
                              DRUMS
                   COKE
              COOLING WATER
*TER>i.   J<
    COKE
PURGE STEAM
                              (       )
                             SUMP TANK    H^EATER
                                i
                                     FUEL GAS
                                        AND
                                     LIGHT ENDS

                                        GASOLINE
                                      .  NAPHTHA
                                       GAS OIL
   FEED Y RECYCLE
            (Source: Based on U.S. EPA Office of General Enforcement, Petroleum Refinery Enforcement
                                     Manual, 1980.)

               Exhibit 9: Simplified Coker Flow Diagram
       Catalytic Cracking

                    Catalytic cracking uses heat, pressure and a  catalyst  to  break  larger
                    hydrocarbon molecules into smaller, lighter molecules.  Catalytic cracking
                    has largely replaced thermal cracking because it is able to produce more
                    gasoline with a higher octane and less heavy fuel oils and light gases. Feed
                    stocks are light and heavy oils from the crude oil distillation unit which are
                    processed primarily into gasoline as well as  some fuel oil and light gases.
                    Most catalysts used in catalytic cracking consist  of mixtures of crystalline
                    synthetic silica-alumina, termed "zeolites," and amorphous synthetic silica-
                    alurriina. The catalytic cracking processes, as well as most other refinery
                    catalyfic"processes, produce coke which collects on the catalyst surface and
                    diminishes its catalytic properties.  The catalyst, therefore, needs to be
                    regenerated continuously or periodically essentially by burning the coke off
                    the catalyst at high temperatures.  The method and frequency in  which
                    catalysts are regenerated are a major factor in the design of catalytic cracking
                    units. A number of different catalytic cracking designs are currently in use
                    in the U.S., including fixed-bed reactors, moving-bed reactors, fluidized-bed
                    reactors, and once-through units. The fluidized- and moving-bed reactors are
                    by far the most prevalent.33
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                     Fluidized-bed catalytic cracking units (FCCUs) are by far the most common
                     catalytic cracking units. In the fluidized-bed process, oil and oil vapor pre-
                     heated to 500 to 800 degrees (F) is contacted with hot catalyst at about 1,300
                     (F) either in the reactor itself or in the feed line (riser) to the reactor. The
                     catalyst is in a fine, granular form which, when mixed with the vapor, has
                     many of the properties of a fluid.  The fluidized catalyst and the reacted
                     hydrocarbon  vapor  separate mechanically in the reactor and  any  oil
                     remaining on the catalyst is removed  by steam stripping.  The cracked oil
                     vapors are then fed to a fractionation tower where the various desired
                     fractions are  separated and collected.  The  catalyst flows into a  separate
                     vessel(s) for either single- or two-stage regeneration by burning off the coke
                     deposits with air (Exhibit 10).34

                     In the moving-bed process, oil is heated to up to  1,300 degrees (F) and is
                     passed under pressure through the reactor where it comes into contact with
                     a catalyst flow in the form of beads or pellets. The cracked products then
                     flow to a fractionating tower where the various compounds are separated and
                     collected.  The catalyst is regenerated in a continuous process where deposits
                     of coke on the catalyst are burned off. Some units also use  steam to strip
                     remaining hydrocarbons and oxygen from the catalyst before being fed back
                     to the oil  stream.  In recent years moving-bed reactors have largely been
                     replaced by-fluidizedrbed reactors.35
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                                          PRODUCTS
                                                         STEAM
                                                        CO BOILER
                           RISER
                       FEED-
                                                                   FUEL GAS TO AMINE UNIT
                                                                ELECTROSTATIC
                                                                PRECIPITATOR
                                              REGENERATOR
                                                 AIR
      -CATALYST

'AIR TRANSFER LINE
                      (Source: Based on U.S. EPA Office of General Enforcement, Petroleum Refinery Enforcement
                                                Manual, 1980.)

                      Exhibit 10: Simplified Catalytic Cracking Flow
                                                Diagram
                    Catalytic cracking is one of the most significant sources of air pollutants at
                    refineries.  Air emissions from catalytic cracking operations include: the.
                    process heater flue gas  emissions, fugitive emissions, and  emissions
                    generated during regeneration of the catalyst.  Relatively high concentrations
                    of carbon monoxide can be produced during regeneration of the catalyst
                    which is typically converted to carbon dioxide either hi the regenerator or
                    further downstream hi a carbon monoxide waste heat boiler.36 hi addition,
                    a significant amount of fine catalyst dust is produced in FCCUs as a result of
                    the constant movement of the catalyst grains against each other.  Much of
                    this dust, consisting primarily of alumina and relatively small amounts of
                    nickel, is carried with the carbon monoxide stream to the carbon monoxide
                    burner. The catalyst dust is then separated from the resulting carbon dioxide
                    stream via cyclones and/or electrostatic precipitators and is sent off-site for
                    disposal or treatment.37 Generated wastewater is typically sour water from
                    the fractionator containing some oil and phenols.  Wastewater containing
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                     metal impurities from the feed oil can also be generated from the steam used
                     to purge and regenerate catalysts.38

       Catalytic Hydrocracking

                     Catalytic hydrocracking  normally utilizes  a  fixed-bed catalytic cracking
                     reactor with cracking occurring under substantial pressure (1,200 to 2,000
                     psig) in the presence of hydrogen.  Feedstocks to hydrocracking units are
                     often those fractions that are the most difficult to crack and cannot be cracked
                     effectively in catalytic cracking units.  These include: middle distillates,
                     cycle oils, residual fuel oils and reduced crudes.  The hydrogen suppresses
                     the formation of heavy residual material and increases the yield of gasoline
                     by reacting with the cracked products. However, this process also breaks the
                     heavy,  sulfur  and nitrogen bearing  hydrocarbons and releases these
                     impurities to where they could potentially foul the catalyst. For this reason,
                     the feedstock is often first hydrotreated to remove impurities before being
                     sent to the catalytic hydrocracker. Sometimes hydrotreating is  accomplished
                     by using the first reactor of the hydrocracking process to remove impurities.
                     Water also has a detrimental effect on some hydrocracking catalysts and must
                     be removed before being fed to the reactor. The water is removed by passing
                     the feed stream through a silica gel or molecular sieve dryer. Depending on
                     the products desired and the size of the unit, catalytic hydrocracking is
                     conducted  in either single  stage or multi-stage  reactor processes.  Most
                     catalysts consist of a crystalline mixture of silica-alumina with small amounts
                     of rare earth.metals (Exhibit II).39

                     Hydrocracking  feedstocks  are usually first hydrotreated to remove the
                     hydrogen sulfide and ammonia that will poison the catalyst.  Sour gas and
                     sour water streams are  produced at the  fractionator,  however, if the
                     hydrocracking feedstocks are first hydrotreated to remove impurities, both
                     streams will contain relatively low levels of hydrogen sulfide and ammonia.
                     Hydrocracking  catalysts are typically regenerated off-site after two to four
                     years of operation. Therefore, little or no emissions are generated from the
                     regeneration processes. Air emissions arise from the process heater, vents,
                     and fugitive emissions.40'41
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                  HYDROGEN   HYDROGEN
                    MAKEUP
                  HEATER
           FEED
     FIRST
STAGE REACTOR
                                SECOND STAGE REACTOR
                                                         FUEL GAS
                                                         >•  AND
                                                        LIGHT ENDS

                                                             GASOLINE
                                                                          NAPHTHA
                                                                          GAS OIL
                                       HEAVY OILS
        (Source: Based on U.S. EPA Office of General Enforcement, Petroleum Refinery Enforcement Manual, 1980.)

             Exhibit 11:  Simplified Two-Stage Hydrocracker
                                    Flow Diagram
Hydrotreating/Hydroprocessing

                    Hydrotreating and hydroprocessing are similar processes used to remove
                    impurities such as sulfur, nitrogen, oxygen, halides and trace metal impurities
                    that may  deactivate process catalysts.  Hydrotreating also upgrades the
                    quality of fractions by converting olefins and diolefms to paraffins for the
                    purpose of reducing gum formation in fuels.  Hydroprocessing,  which
                    typically uses residuals from the crude distillation units, also cracks these
                    heavier molecules to lighter more saleable products. Both hydrotreating and
                    hydroprocessing units are usually placed upstream  of those processes in
                    which sulfur and nitrogen could have adverse effects on the catalyst, such as
                    catalytic reforming and hydrocracking units. The processes utilize catalysts
                    in the presence of substantial amounts of hydrogen under high pressure and
                    temperature to react the  feedstocks  and impurities with hydrogen.  The
                    reactors are nearly all fixed-bed with catalyst replacement or regeneration
                    done after months or years of operation often at an off-site facility.42 In
                    addition to the treated products,  the process produces a stream of light fuel
                    gases, hydrogen sulfide, and ammonia. The treated product and hydrogen-
                    rich gas are cooled after they leave the reactor before being separated.  The
                    hydrogen  is recycled to the reactor.
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                                                                        FUEL GAS/
                                                                        LIGHT ENDS
                              HYDROGEN
                               RECYCLE
     FEED
               HEATER
                          REACTOR
HYDROGEN
SEPARATOR
I
                                  AMINE UNIT
                                                                      STRIPPER
                                                                     STEAM
                                                 LOW PRESSURE
                                                  SEPARATOR
                               TREATED
                               PRODUCT
          (Source: U.S. EPA Office of General Enforcement, Petroleum Refinery Enforcement Manual, 1980.)

          Exhibit 12: Simplified Hydrotreater Flow Diagram
       Alkylation
                    The off-gas stream may be very rich in hydrogen sulfide and light fuel gas.
                    The fuel gas and hydrogen sulfide are typically sent to the sour gas treatment
                    unit and sulfur recovery unit. Catalysts are typically cobalt or molybdenum
                    oxides on alumina, but can also contain nickel and tungsten. Air emissions
                    from hydrotreating may arise from process heater flue gas, vents, and fugitive
                    emissions (Exhibit 12).43
                    Alkylation is used to produce a high octane gasoline blending stock from the
                    isobutane formed primarily during catalytic cracking and coking operations,
                    but also  from  catalytic reforming, crude  distillation and  natural gas
                    processing.  Alkylation joins an olefin and an isoparaffin compound using
                    either a sulfuric acid or hydrofluoric acid catalyst. The products are alkylates
                    including propane and butane liquids.  When the  concentration of acid
                    becomes less than 88 percent , some of the acid must be removed and
                    replaced with stronger acid, hi the hydrofluoric acid process, the slip stream
                    of acid is redistilled.  Dissolved polymerization products are removed from
                    the acid as a thick dark oil.  The concentrated hydrofluoric  acid is recycled
                    and the net consumption is about 0.3 pounds per barrel of alkylates produced.
                    Hydrofluoric acid alkylation units require  special engineering design,
                    operator training and safety equipment precautions to protect operators from
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                     accidental contact with hydrofluoric acid which is an extremely hazardous
                     substance.  In the sulfuric acid process, the sulfuric acid removed must be
                     regenerated in a sulfuric acid plant which is generally not a part of the
                     alkylation unit and may be located off-site. Spent sulfuric acid generation is
                     substantial; typically in the range of 13 to 30 pounds per barrel of alkylate.44
                     Air emissions from the alkylation process may arise from process vents and
                     fugitive emissions.
       Isomerization
                     Isomerization is used to alter the arrangement of a molecule without adding
                     or removing anything  from the original molecule.  Typically, paraffins
                     (butane or pentane from the crude  distillation unit) are converted  to
                     isoparaffins having a much higher octane. Isomerization reactions take place
                     at temperatures in the range of 200 to 400 degrees (F) in the presence of a
                     catalyst that usually consists of platinum on a base material. Two types of
                     catalysts are currently in use. One requires the continuous addition of small
                     amounts of organic chlorides which are converted to hydrogen chloride in the
                     reactor. In such a reactor, the feed must be free of oxygen sources including
                     water to  avoid deactivation' and corrosion problems.  The other type of
                     catalyst uses a molecular sieve base and does not require a dry and oxygen
                     free feed. Both types of isomerization catalysts require an atmosphere of
                     hydrogen to minimize coke deposits; however, the consumption of hydrogen
                     is negligible. Catalysts typically need to be replaced about every two to three
                     years or longer.45 Platinum is then recovered from the used catalyst off-site.
                     Light ends are stripped from the product stream leaving the reactor and are
                     then sent to the sour gas treatment unit.  Some isomerization units utilize
                     caustic treating of the light fuel gas stream to neutralize any entrained
                     hydrochloric acid. This will result in a calcium chloride (or other salts) 'waste
                     stream. Air emissions may arise from the process heater, vents and fugitive
                     emissions.46 Wastewater streams include caustic wash and sour water.47
       Polymerization
                     Polymerization is occasionally used to convert propene and butene to high
                     octane gasoline blending components. The process is similar to alkylation
                     in its feed and products, but is often used as a less expensive alternative to
                     alkylation.  The reactions typically take place under high pressure in the
                     presence of a phosphoric acid catalyst.  The feed must be free of sulfur,
                     which poisons the catalyst; basic materials, which neutralize the catalyst; and
                     oxygen, which affects the reactions. The propene and butene feed is washed
                     first with caustic to remove mercaptans (molecules containing sulfur), then
                     with an amine solution  to remove hydrogen  sulfide, then with water to
                     remove caustics and amines, and finally dried by passing through a silica gel
                     or molecular sieve dryer.48 Air emissions of sulfur dioxide may arise during
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                     the caustic washing  operation.  Spent catalyst, which typically is not
                     regenerated, is occasionally disposed as a solid waste.49  Wastewater streams
                     will contain caustic wash and sour water with amines and mercaptans.50

        Catalytic Reforming

                     Catalytic reforming uses catalytic reactions to process primarily low octane
                     heavy straight run (from the crude distillation unit) gasolines and naphthas
                     into high octane aromatics (including benzene).  There are four major types
                     of reactions which occur during reforming processes: 1) dehydrogenation of
                     naphthenes to aromatics; 2) dehydrocyclization of paraffins to aromatics; 3)
                     isomerization; and 4) hydrocracking. The dehydrogenation reactions are
                     very endothermic, requiring that the hydrocarbon stream be heated between
                     each catalyst bed.  All but the hydrocracking reaction release hydrogen which
                     can be used in the hydrotreating or hydrocracking processes. Fixed-bed or
                     moving bed processes are utilized  in a  series of three to six reactors.
                     Feedstocks to catalytic reforming processes are usually hydrotreated first to
                     remove sulfur, nitrogen and metallic contaminants. In continuous reforming
                     processes, catalysts can be regenerated one reactor at a time, once or twice
                     per day, without disrupting the operation of the unit. In semi regenerative
                     units, regeneration of all reactors can be carried out simultaneously after
                     three to 24 months of operation by first shutting down the process.51 Because
                     the recent reformulated gasoline rules have limited the allowable amount of
                     benzene hi gasoline (Section VLB), catalytic reforming is  being used less as
                     an octane enhancer than in past years.

                     Air emissions from catalytic reforming arise from the process heater gas and
                     fugitive emissions.  The catalysts used in catalytic reforming processes are
                     usually very expensive and extra precautions are taken to ensure that catalyst
                     is not lost.  When the catalyst has lost its activity and  can no longer be
                     regenerated, the catalyst is usually sent off-site for recovery of the metals.52
                     Subsequent air emissions from catalyst regeneration is, therefore, relatively
                     low. Relatively small volumes of wastewater containing sulfides, ammonia,
                     and mercaptans may be generated from the stripping tower used to remove
                     light ends from the reactor effluent.53

       Solvent Extraction

                     Solvent extraction uses solvents to dissolve and remove aromatics from lube
                     oil feed stocks, improving viscosity, oxidation  resistance, color and  gum
                     formation.  A number of different solvents are used with the two most
                     common being furfural and phenol, typically, feed lube stocks are contacted
                     with the solvent in a packed tower or rotating disc contactor. Each solvent
                     has  a different solvent-to-oil ratio and  recycle ratio within  the tower.
                     Solvents are recovered from the oil stream through distillation and steam
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                    stripping in a fractionator. The stream extracted from the solvent will likely
                    contain high concentrations of hydrogen sulfide, aromatics, naphthenes and
                    other hydrocarbons, and is often fed to the hydrocracking unit.  The water
                    stream leaving the fractionator will likely contain some oil and solvents.54

       Chemical Treating

                    In petroleum refining, chemical treating is used to remove or change the
                    undesirable properties associated with sulfur, nitrogen, or oxygen compound
                    contaminates in petroleum products.  Chemical treating is accomplished by
                    either extraction or oxidation (also known as sweetening), depending upon
                    the product  Extraction is used  to remove  sulfur  from the very light
                    petroleum fractions, such as propane/propylene (PP) and butane/butylene
                    (BB).  Sweetening, though, is more effective on gasoline and middle
                    distillate products.

                    A typical extraction process is "Merox" extraction. Merox extraction is used
                    to remove mercaptans (organic sulfur compounds) from PP and BB streams.
                    PP streams may undergo amine treating before the  Merox extraction  to
                    remove excess H2S which tends to fractionate with PP and interferes with the
                    Merox process. A caustic prewash of the PP and BB removes any remaining
                    trace H2S prior to Merox extraction.

                    The PP and BB  streams are passed up through the trays of an extraction
                    tower.   Caustic solution  flowing down the extraction  tower  absorbs
                    mercaptan from the PP and BB streams. The rich caustic is then regenerated
                    by oxidizing the mercaptans to disulfide in the presence of aqueous Merox
                    catalyst  and the  lean caustic recirculated to  the extraction tower.  The
                    disulfide is insoluble in the caustic and can be separated.

                    Oxidation or  "sweetening" is used on gasoline and distillate fractions.  A
                    common oxidation process is also a Merox process that uses a solid catalyst
                    bed.  Air and a minimurn amount of alkaline caustic ("mini-alky" operation)
                    is injected into the hydrocarbon stream. As the hydrocarbon passes through
                    the Merox catalyst bed, sulfur mercaptans are oxidized to disulfide.  hi the
                    sweetening Merox process, the caustic is not regenerated. The disulfide can
                    remain with the gasoline product, since it does not possess the objectionable
                     odor properties of mercaptans; hence, the product has been  "sweetened."55

                     hi the extraction process, a waste oily disulfide stream leaves the separator.
                     Air emissions arise from fugitive hydrocarbons and the process vents on the
                     separator which may contain disulfides.56
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       Dewaxing
                     Dewaxing of lubricating oil base stocks is necessary to ensure that the oil
                     will have the proper viscosity at lower ambient temperatures. Two types of
                     dewaxing processes are used: selective hydrocracking and solvent dewaxing.
                     hi selective hydrocracking, one or two zeolite catalysts are used to selectively
                     crack the wax paraffins. Solvent dewaxing is more prevalent. In solvent
                     dewaxing, the oil feed is diluted with solvent to lower the viscosity, chilled
                     until the wax is crystallized, and then filtered to remove the wax.  Solvents
                     used for the process include propane and mixtures of methyl ethyl ketone
                     (MEK) with methyl isobutyl ketone (MIBK) or MEK with toluene.  Solvent
                     is recovered from the oil and wax through heating, two-stage  flashing,
                     followed by steam stripping. The solvent recovery stage results in solvent
                     contaminated water which typically is sent to the wastewater treatment plant.
                     The wax is either used as feed to the catalytic cracker or is deoiled and sold
                     as industrial wax.  Air emissions may arise from fugitive emissions of the
                     solvents.57
       Propane Deasphalting
                     Propane deasphalting produces lubricating oil base stocks by extracting
                     asphaltenes and resins from the residuals of the vacuum distillation unit.
                     Propane is usually used to remove asphaltenes due to its unique solvent
                     properties. At lower temperatures (100 to 140 degrees F), paraffins are very
                     soluble in propane and at higher temperatures (about 200 degrees  F) all
                     hydrocarbons are almost insoluble in propane.  The propane deasphalting
                     process is similar to solvent extraction in that a packed or baffled extraction
                     tower or rotating disc contactor is used to mix the oil feed stocks with the
                     solvent, hi the tower method, four to eight volumes of propane are fed to the
                     bottom of the tower for every volume of feed flowing down from the top of
                     the tower. The oil, which is more soluble in the propane dissolves and flows
                     to the top.  The asphaltene and resins flow to the bottom of the tower where
                     they are removed  hi  a propane mix.  Propane is recovered from the two
                     streams through two-stage flash systems  followed  by steam  stripping in
                     which propane is condensed and removed by cooling at high pressure in the
                     first stage and at low pressure hi the second stage. The asphalt recovered can
                     be blended with other asphalts or heavy fuels, or can be used as feed to the
                     coker. The propane recovery stage results in propane contaminated water
                     which typically is sent to the wastewater treatment plant. Air emissions may
                     arise from fugitive propane emissions and process vents.58
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       III.A.3. Supporting Operations
                    Many important refinery operations are not  directly  involved in the
                    production of hydrocarbon fuels but serve in a supporting role. Some of the
                    major supporting processes are discussed below.
       Wastewater Treatment
                    Relatively large volumes of water are used by the  petroleum refining
                    industry.  Four types of wastewater are produced:  surface water runoff,
                    cooling water, process water, and sanitary wastewater. Surface water runoff
                    is intermittent and will contain constituents from spills to the surface, leaks
                    in equipment and any materials that may have collected in drains.  Runoff
                    surface water also includes water coming from crude and product storage
                    tank roof drains.

                    A large portion of water used in petroleum refining is used for cooling.
                    Cooling water typically does not come into direct contact with process oil
                    streams and therefore contains less contaminants than process wastewater.
                    Most cooling water is recycled over and over with a bleed or blowdown
                    stream to the wastewater treatment unit to control the concentration of
                    contaminants and the solids content in the water.  Cooling towers within the
                    recycle loop cool the water using  ambient air.  (See  Storage  Tanks and
                    Cooling Towers)  Some cooling water, termed "once through," is passed
                    through a process unit once and is then discharged directly without treatment
                    in the wastewater treatment plant.  The water used for cooling often contains
                    chemical additives such as chromates, phosphates, and antifouling biocides
                    to prevent scaling  of pipes and biological growth.  (It should be noted,
                    however, that many refineries  no longer use chromates in cooling water as
                    anti-fouling  agents.)  Although cooling water usually does not come into
                     direct contact with oil  process  streams, it also may contain some oil
                     contamination due to leaks in the process equipment.59

                     Water used in processing operations also accounts for a significant portion
                     of the total wastewater.  Process wastewater arises from desalting crude oil,
                     steam stripping operations, pump gland cooling, product fractionator reflux
                     drum drains and boiler blowdown. Because process water often comes into
                     direct contact with oil, it is usually highly contaminated.60

                     Petroleum refineries typically utilize  primary and  secondary  wastewater
                     treatment. Primary wastewater treatment consists of the separation of oil,
                     water and solids in two stages. During the first  stage, an API separator, a
                     corrugated plate interceptor, or other separator design is used. Wastewater
                     moves very slowly through the separator allowing  free oil to  float to the
                     surface and be skimmed off, and solids to settle to the bottom and be scraped
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                     off to a sludge collecting hopper. The second stage utilizes physical or
                     chemical methods to separate emulsified oils from the wastewater. Physical
                     methods may include the use of a series of settling ponds with a long
                     retention tune, or the use of dissolved ah- flotation (DAF).  In DAF, air is
                     bubbled through the wastewater, and both oil and  suspended solids are
                     skimmed off the top.  Chemicals, such as ferric hydroxide or aluminum
                     hydroxide, can be used to coagulate impurities into a froth or sludge which
                     can be more easily skimmed off the top. Some wastes associated with the
                     primary treatment of wastewater at petroleum refineries may be considered
                     hazardous  and include:  API separator sludge, primary treatment sludge,
                     sludges from other gravitational separation techniques, float from DAF units,
                     and wastes from settling ponds (Exhibit 13).61

                     After primary treatment, the wastewater can be discharged to a publicly
                     owned  treatment works or undergo  secondary treatment  before  being
                     discharged directly to surface waters under a National Pollution Discharge
                     Elimination System (NPDES) permit. In secondary treatment, dissolved oil
                     and   other  organic pollutants  may  be consumed   biologically  by
                     microorganisms. Biological treatment may require the addition of oxygen
                     through a number of different techniques, including activated sludge units,
                     trickling filters, and rotating biological contactors.  Secondary treatment
                     generates bio-mass waste which is typically treated anaerobically, and then
                     dewatered.62

                     Some refineries employ an additional stage of wastewater treatment called
                     polishing to meet discharge limits. The polishing step can involve the use of
                     activated carbon,  anthracite coal,  or  sand to filter out any remaining
                     impurities, such as biomass, silt, trace metals and other inorganic chemicals,
                     as well as any remaining organic chemicals.63'64

                     Certain refinery wastewater streams are treated  separately, prior  to the
                     wastewater treatment plant, to remove contaminants that would not easily be
                     treated after mixing with other wastewater. One such waste stream is the
                     sour water  drained from distillation reflux drums.   Sour water contains
                     dissolved hydrogen sulfide and other organic sulfur compounds and ammonia
                     which are stripped in a tower with gas or steam before being discharged to
                     the wastewater treatment plant.65

                     Wastewater treatment plants are a significant source of refinery air emissions
                     and solid wastes.   Air releases arise  from fugitive emissions from the
                     numerous tanks, ponds and sewer system drains. Solid wastes are generated
                     in the form of sludges from a number of the treatment units.
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         (Source: Based on U.S. EPA Office of General Enforcement, Petroleum Refinery Enforcement Manual,
                                         1980.)


           Exhibit 13: Typical Refinery Wastewater Treatment System
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 Gas Treatment and Sulfur Recovery
                     Sulfur is removed from a number of refinery process off-gas streams (sour
                     gas) in order to meet the SOX emissions limits of the CAA and to recover
                     saleable elemental sulfur.  Process off-gas streams, or sour gas, from the
                     coker, catalytic cracking unit, hydrotreating units and hydroprocessing units
                     can contain high concentrations of hydrogen sulfide mixed with light refinery
                     fuel gases.  Before elemental sulfur can  be recovered, the fuel gases
                     (primarily methane and ethane) need to be separated from the hydrogen
                     sulfide.  This is typically accomplished by dissolving the hydrogen sulfide
                     in a chemical solvent.  Solvents most commonly  used are amines, such as
                     diethanolamine (DEA).  Dry'adsorbents such as molecular sieves, activated
                     carbon, iron sponge and zinc oxide are also used.  In the amine solvent
                     processes, DEA solution or another amine solvent is pumped to an absorption
                     tower where the gases are contacted and hydrogen sulfide is dissolved in the
                     solution. The fuel gases are removed for use as fuel in process furnaces in
                     other refinery operations.  The amine-hydrogen sulfide solution is then
                     heated and steam stripped to remove the hydrogen sulfide gas.66

                     Current methods for removing sulfur from the hydrogen sulfide gas streams
                     are typically a combination of two processes: the Glaus Process followed by
                     the Beaven Process, Scot Process, or the Wellman-Land Process. The Glaus
                     process consists  of partial combustion of the hydrogen sulfide-rich  gas
                     stream (with one-third the stoichiometric quantity of air) and then reacting
                     the resulting sulfur dioxide and unburned hydrogen sulfide in the presence
                     of a bauxite catalyst to produce elemental sulfur (Exhibit 14).
                            STEAM
                                 REHEATER
                                                REHEATER
  ACID GAS
(MAY CONTAIN Nty
                                                            GLAUS TAIL GAS TO DESULFERIZATION UNIT
             BOILER FEEDWATER
                                                  LIQUID SULFER
            (Source: Based on U.S. EPA Office of General Enforcement, Petroleum Refinery Enforcement Manual, 1980.)

               Exhibit 14: Simplified Glaus Sulfur Recovery Flow
                                           Diagram
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                    Since the Glaus process by itself removes only about 90 percent of the
                    hydrogen sulfide in the gas stream, the Beaven, SCOT, or Wellman-Lord
                    processes are often used to further recover sulfur. In the Beaven process, the
                    hydrogen sulfide in the relatively low concentration gas stream from the
                    Claus process can be almost completely removed by absorption hi a quinone
                    solution. The dissolved hydrogen sulfide is oxidized to form a mixture of
                    elemental sulfur and hydro-quinone.  The solution is injected  with air or
                    oxygen to oxidize the hydro-quinone back to quinone. The solution is then
                    filtered or centrifuged to remove the sulfur and the quinone is then reused.
                    The Beaven process is also effective in removing small amounts of sulfur
                    dioxide, carbonyl sulfide, and carbon disulfide that are not affected by the
                    Claus process. These compounds are first converted to hydrogen sulfide at
                    elevated temperatures in a cobalt molybdate catalyst prior to being fed to the
                    Beaven unit.67-68 Air emissions from sulfur recovery units will consist of
                    hydrogen sulfide, SOX and NQ in the process tail gas as well  as fugitive
                    emissions and releases from vents.

                    The SCOT process is also widely used for removing sulfur from the Claus
                    tail gas.  The sulphur compounds in the Claus tail gas are converted to
                    hydrogen sulfide by heating and passing it through a Cobalt-molybdenum
                    catalyst with the addition of a reducing gas. The gas is then cooled and
                    contacted with a solution of di-isopropanolamine (DIPA) which removes all
                    but trace amounts of hydrogen sulfide. The sulfide-rich DIPA  is sent to a
                    stripper where hydrogen sulfide gas is removed and sent to the Claus plant.
                    The DIPA is returned to the absorption column.

       Additive Production

                    A number of chemicals (mostly alcohols and ethers) are added to motor fuels
                    to either improve performance or meet federal and state environmental
                    requirements. Since the 1970s, alcohols (methanol and ethanol) and ethers
                    have been added to gasoline to increase octane levels and reduce carbon
                    monoxide generation in place of the lead additives which were being phased
                    out as required by the 1970 Clean Air Act. In 1990, the more stringent Clean
                    Air Act Amendments (see Section V.B) established minimum and maximum
                    amounts of chemically combined oxygen in motor fuels as well as an upper
                    limit on vapor pressure.  As a result, alcohol additives have been increasingly
                    supplemented or replaced with a number of different ethers which are better
                    able to meet both the new oxygen requirements and the vapor pressure limits.

                    The most common ethers being used as additives are methyl tertiary butyl
                    ether (MTBE), and tertiary amyl methyl ether (TAME). Many of the larger
                    refineries manufacture their own supplies of MTBE and TAME by reacting
                    isobutylene and/or isoamylene with methanol. Smaller refineries usually buy
                    their  supplies from chemical  manufacturers  or the larger  refineries.
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                     Isobutylene is obtained from a number of refinery sources including: the light
                     naphtha from, the FCCU and coking  units,  the by-product from  steam
                     cracking of naphtha or light hydrocarbons during the production of ethylene
                     and propylene, catalytic dehydrogenation of isobutane, and conversion of
                     tertiary butyl alcohol recovered as a  by-product in the manufacture of
                     propylene oxides. Several different processes are currently in use to produce
                     MTBE and TAME from isobutylene and methanol.  Most processes use a
                     two-stage acidic ion exchange resin catalyst.  The reaction is exothermic and
                     cooling to the proper reaction temperature is critical in obtaining the optimal
                     conversion efficiency.  The process usually produces an MTBE or TAME
                     stream and  a relatively small  stream of unreacted hydrocarbons  and
                     methanol.  The methanol is extracted  in a water wash and the resulting
                     methanol-water mixture is distilled to recover the methanol for recycling.

       Heat Exchanger Cleaning

                     Heat exchangers are used throughout petroleum refineries  to heat or cool
                     petroleum process streams. The heat exchangers consist of bundles of pipes,
                     tubes, plate coils, or steam coils enclosing heating or cooling water, steam,
                     or oil to transfer heat indirectly to or  from the oil process stream.  The
                     bundles are cleaned periodically to remove accumulations of scales, sludge
                     and any oily residues. Because chromium has almost been  eliminated as a
                     cooling water additive, wastes generated from the cleaning of heat exchanger
                     bundles no longer account for a significant portion of the hazardous wastes
                     generated at refining facilities. The sludge generated may  contain lead or
                     chromium, although some refineries which do not produce leaded gasoline
                     and which use non-chrome corrosion inhibitors typically do not generate
                     sludge that contains these constituents.  Oily wastewater is also generated
                     during heat exchanger cleaning.69

       Slowdown System

                     Most refinery process units and equipment are manifolded into a collection
                     unit, called the blowdown system: Slowdown systems provide for the safe
                     handling and disposal of liquid and gases that are either automatically vented
                     from the process units through pressure relief valves, or that are manually
                     drawn from units. Recirculated process streams and cooling water streams
                     are often manually purged to prevent the  continued build up of contaminants
                     in the stream. Part or all of the contents of equipment can also be purged to
                     the  blowdown system prior to  shutdown  before  normal or  emergency
                     shutdowns.  Blowdown systems  utilize  a series  of flash drums  and
                     condensers to separate the blowdown into its vapor and liquid components.
                     The liquid is typically composed of mixtures of water and hydrocarbons
                     containing sulfides, ammonia, and other contaminants, which are sent to the
                     wastewater treatment plant.   The gaseous  component typically contains
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                    hydrocarbons, hydrogen sulfide, ammonia, mercaptans, solvents, and other
                    constituents, and is either discharged directly to the atmosphere  or  is
                    combusted in a flare. The major air emissions from blowdown systems are
                    hydrocarbons in the case of direct discharge to the atmosphere and sulfur
                    oxides when flared.
       Blending
                    Blending is the final operation in petroleum refining.  It consists of mixing
                    the products in various proportions to meet specifications such as vapor
                    pressure, specific gravity, sulfur content, viscosity, octane number, cetane
                    index, initial boiling point, and pour point. Blending can be carried out in-
                    line or in batch blending tanks. Air emissions from blending are fugitive
                    VOCs from blending tanks, valves, pumps and mixing operations.70
       Storage Tanks
                     Storage tanks are used throughout the refining process to store crude oil and
                     intermediate process feeds for cooling and further processing. Finished
                     petroleum products are also kept in storage tanks before transport off site.
                     Storage tank bottoms are mixtures of iron rust from corrosion, sand, water,
                     and emulsified oil and wax, which accumulate at the bottom of tanks.  Liquid
                     tank bottoms (primarily water and oil emulsions) are periodically drawn off
                     to prevent their continued build up.  Tank bottom liquids and sludge are also
                     removed during periodic cleaning of tanks for inspection. Tank bottoms may
                     contain  amounts  of  tetraethyl or tetramethyl lead (although  this  is
                     increasingly rare due to the phaseout of leaded products), other metals, and
                     phenols.  Solids generated from leaded gasoline storage tank bottoms  are
                     listed as a RCRA hazardous waste.71-72

                     Even if equipped with floating tops, storage tanks account for considerable
                     VOC emissions at petroleum refineries.  A  study  of petroleum refinery
                     emissions found that the majority of tank losses occurred through tank seals
                     on gasoline storage tanks.73
       Cooling Towers
                     Cooling towers cool heated water by circulating the water through a tower
                     with a predetermined flow of ambient air pushed with large fans. A certain
                     amount of water exits the system through evaporation, mist droplets and as
                     bleed or blowdown to the wastewater treatment system. Therefore, make-up
                     water in the range of about five percent of the circulation rate is required.74
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III.B. Raw Material Inputs and Pollution Outputs in the Production Line

                    Raw material input to petroleum refineries is primarily crude oil; however,
                    petroleum refineries use and generate an enormous number of chemicals,
                    many of which leave the facilities as discharges of air emissions, wastewater,
                    or  solid waste.  Pollutants generated  typically include VOCs, carbon
                    monoxide (CO), sulfur oxides (SOJ, nitrogen oxides (NQ ), particulates,
                    ammonia (NH3), hydrogen sulfide (H2S), metals, spent acids, and numerous
                    toxic organic compounds. Exhibit 15 summarizes the main pollutant outputs
                    for each major refinery process.

                    When discussing material outputs of the petroleum refining industry, it is
                    important to note the relationship between the outputs of the industry itself
                    and the outputs resulting from the use  of refinery products.  Petroleum
                    refineries play  an  important role in  the U.S.  economy,  supplying
                    approximately 40 percent of the total energy used in the U.S. and virtually
                    all of the energy consumed in the transportation sector. The pollutant outputs
                    from the  refining facilities, however, are modest in comparison to  the
                    pollutant outputs realized from the consumption of petroleum products by the
                    transportation sector, electric utilities, chemical manufacturers  and other
                    industrial and commercial users.
       Air Emissions
                    Air emissions from refineries include fugitive emissions of the volatile
                    constituents in crude oil and its fractions, emissions from the burning of fuels
                    in process heaters, and  emissions  from the various refinery processes
                    themselves. Fugitive emissions occur throughout refineries and arise from
                    the thousands of potential fugitive emission sources such as valves, pumps,
                    tanks, pressure relief valves,  flanges, etc.  While  individual leaks  are
                    typically small, the sum of all fugitive leaks at a refinery can be one of its
                    largest emission sources.  Fugitive  emissions can be reduced through a
                    number of techniques, including improved leak resistant equipment, reducing
                    the number of tanks and other potential sources and, perhaps the most
                    effective method, an ongoing Leak Detection and Repair (LDAR) program.

                    The numerous process heaters used in refineries to heat process streams or
                    to generate steam (boilers) for  heating or steam stripping, can be potential
                    sources of SOX, NOX, CO, particulates and hydrocarbons emissions. When
                    operating properly and when burning cleaner fuels such as refinery fuel gas,
                    fuel oil or natural gas, these emissions  are relatively low.  If, however,
                    combustion is not complete, or heaters are fired with refinery fuel pitch or
                    residuals, emissions can be significant.75
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                     The majority of gas streams exiting each refinery process contain varying
                     amounts of refinery fuel gas, hydrogen sulfide and ammonia. These streams
                     are collected and sent to the gas treatment and sulfur recovery units to
                     recover the refinery fuel gas and sulfur.  Emissions from the sulfur recovery
                     unit typically contains some H2S, SOX  and NQ. Other emissions sources
                     from refinery processes arise from periodic regeneration of catalysts. These.
                     processes generate streams that may contain relatively high levels of carbon
                     monoxide,  particulates  and  VOCs.   Before being  discharged  to the
                     atmosphere, such off-gas streams may be treated first through a carbon
                     monoxide boiler to burn carbon monoxide and any VOCs, and then through
                     an electrostatic precipitator or cyclone separator to remove particulates.76
       Wastewater
                     Wastewaters consist of cooling water, process water, sanitary sewage water,
                     and storm water.  Wastewaters are treated in onsite wastewater treatment
                     facilities and then discharged to POTWs or discharged to surfaces waters
                     under NPDES permits. In addition, some facilities use underground injection
                     of some wastewater streams. (See Wastewater Treatment in Section III. A.)

                     Many refineries unintentionally release, or have unintentionally released in
                     the past, liquid hydrocarbons to ground water and surface waters. At some
                     refineries contaminated ground water has migrate off-site and resulted hi
                     continuous "seeps" to  surface waters.   While  the actual  volume  of
                     hydrocarbons released in such a manner are relatively small,  there is the
                     potential to contaminate large volumes of ground water and surface water
                     possibly posing a substantial risk to human health and the environment.
       Other Wastes
                     Other wastes are generated from many of the refining processes, petroleum
                     handling operations, as well as wastewater treatment.  Both hazardous and
                     non-hazardous wastes are generated, treated and disposed. Residual refinery
                     wastes are typically in the form of sludges, spent process catalysts, filter clay,
                     and incinerator ash.  Treatment of these wastes includes incineration, land
                     treating off-site, land filling onsite, land filling off-site, chemical fixation,
                     neutralization, and other treatment methods.

                     A significant portion of the non-petroleum product outputs of refineries is
                     transported off-site and sold as byproducts.  These outputs include sulfur,
                     acetic acid, phosphoric acid, and recovered metals. Metals from catalysts
                     and from  the crude  oil that  have deposited on the catalyst during the
                     production often are recovered by third party recovery facilities.
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                        Petroleum Refining
Exhibit 15: Typical Material Outputs from Selected Petroleum
Refining Processes
Process
Crude oil
desalting
Atmospheric
distillation
Vacuum
Distillation
Thermal
Cracking/
Visbreaking
Coking
Catalytic
Cracking
Catalytic Hydro-
cracking
Air Emissions
Heater stack gas (CO, SOX,
NOX, hydrocarbons and
participates), fugitive emissions
(hydrocarbons)
Heater stack gas (CO, SOX,
NOX, hydrocarbons and
participates), vents and fugitive
emissions (hydrocarbons)
Steam ejector emissions
(hydrocarbons), heater stack
gas (CO, SO,, NC^
hydrocarbons and particulates),
vents and fugitive emissions
(hydrocarbons)
Heater stack gas (CO, SOX,
NOX, hydrocarbons and
particulates), vents and fugitive
emissions (hydrocarbons).
Heater stack gas (CO, SO^
NOX) hydrocarbons and
particulates), vents and fugitive
emissions (hydrocarbons) and
decoking emissions
(hydrocarbons and particulates).
Heater stack gas (CO, SOX,
NOX, hydrocarbons and
particulates), fugitive emissions
(hydrocarbons) and catalyst
regeneration (CO, NOX) SOX,
and particulates)
Heater stack gas (CO, SOX,
NOX, hydrocarbons and
particulates), fugitive emissions
(hydrocarbons) and catalyst
regeneration (CO, NOX, SO^
and catalyst dust).
Process Waste Water
Flow=2.1 Gal/Bbl
Oil, H2S, NH3, phenol,
high levels of
suspended solids,
dissolved solids, high
BOD, high temperature.
Flow=26.0 Gal/Bbl
Oil, H2S, NH3,
suspended solids,
chlorides, mercaptans,
phenol, elevated pH.
Flow=2.0 Gal/Bbl
Oil, H2S, NH3) phenol,
suspended solids, high
oH. BOD.. COD.
Flow=1.0 Gal/Bbl
HighpH,H2S,NH3,
suspended solids, COD.
Flow=15.0 Gal/Bbl
High levels of oil,
suspended solids,
phenols, cyanides, H2S,
NH3, high pH, BOD,
COD.
Flow=2.0 Gal/Bbl
High COD, suspended
solids, H2S, relatively
low levels of BOD.
Residual Wastes
Generated
Crude oil/desalter sludge
(iron rust, clay, sand, water,
emulsified oil and wax,
metals)
Typically, little or no
residual waste generated.
Typically, little or no
residual waste generated.
Coke dust (carbon particles
and hydrocarbons)
Spent catalysts (metals
from crude oil and
hydrocarbons),
spent catalyst fines from
electrostatic precipitators
(aluminum silicate and
metals)
Spent catalysts fines
(metals from crude oil, and
hydrocarbons)
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Process
Hydrotreating/
Hydroprocessing
Alkylation
Isomerization
Polymerization
Catalytic
Reforming
Solvent
Extraction
Dewaxing
Propane
Deasphalting
Merox treating
Wastewater
treatment
Air Emissions
Heater stack gas (CO, SOX,
NOX, hydrocarbons and
particulates), vents and fugitive
emissions (hydrocarbons) and
catalyst regeneration (CO, NOX,
SOJ
Heater stack gas (CO, SOX,
NOX, hydrocarbons and
particulates), vents and fugitive
emissions (hydrocarbons)
Heater stack gas (CO, SO^
NOX, hydrocarbons and
particulates), HC1 (potentially
in light ends), vents and
fugitive emissions
(hydrocarbons)
H2S from caustic washing
Heater stack gas (CO, SOX,
NOX, hydrocarbons and
particulates), fugitive emissions
(hydrocarbons) and catalyst
regeneration (CO, NOX, SO,)
Fugitive solvents
Fugitive solvents, heaters
Heater stack gas (CO, SOX,
NOX, hydrocarbons and
particulates), fugitive propane
Vents and fugitive emissions
(hydrocarbons and disulfides).
Fugitive emissions (H2S, NH3,
and hydrocarbons)
Process Waste Water
Flow=1.0Gal/Bbl
H2S,NH3,HighpH,
phenols suspended
solids, BOD, COD.
Low pH, suspended
solids, dissolved solids,
COD, H2S, spent
sulfuric acid.
Low pH, chloride salts,
caustic wash, relatively
lowH2SandNH3.
H2S, NH3, caustic wash,
mercaptans and
ammonia, high pH.
Flow=6.0 Gal/Bbl
High levels oil,
suspended solids, COD.
Relatively low H2S.
Oil and solvents
Oil and solvents
Oil and propane
Little or no wastewater
generated.
Not Applicable
Residual Wastes
Generated
Spent catalyst fines
(aluminum silicate and
metals).
Neutralized alkylation
sludge (sulfuric acid or
calcium fluoride,
hydrocarbons).
Calcium chloride sludge
from neutralized HC1 gas.
Spent catalyst containing
phosphoric acid.
Spent catalyst fines from
electrostatic precipitators
(alumina silicate and
metals).
Little or no residual wastes
generated.
Little or no residual wastes
generated.
Little or no residual wastes
generated. •
Spent Merox caustic
solution, waste oil-disulfide
mixture.
API separator sludge
(phenols, metals and oil),
chemical precipitation
sludge (chemical
coagulants, oil), DAF
floats, biological sludges
(metals, oil, suspended
solids), spent lime.
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Process
Gas Treatment
and Sulfur
Recovery
Blending
Heat exchanger
cleaning
Storage Tanks
Slowdown and
flare
Air Emissions
SOX, NOX, and H2S from vent
and tail gas emissions.
Fugitive emissions
(hydrocarbons)
Periodic fugitive emissions
(hydrocarbons)
Fugitive emissions
(hydrocarbons)
Combustion products (CO, SOX,
NOX and hydrocarbons) from
flares, fugitive emissions
Process Waste Water
H2S, NH3, amines,
Strerford solution.
Little or no wastewater
generated
Oily wastewater
generated
Water drained from
tanks contaminated with
tank product
Little or no wastewater
generated
Residual Wastes
Generated
Spent catalyst.
Little or no residual waste
generated.
Heat exchanger sludge (oil,
metals, and suspended
solids)
Tank bottom sludge (iron
rust, clay, sand, water,
emulsified oil and wax,
metals)
Little or no residual waste
generated.
Sources: Assessment of Atmospheric Emissions from Petroleum Refining, Radian Corp., 1980; Petroleum
Refining Hazardous Waste Generation, U.S. EPA, Office of Solid Waste, 1994.
HI.C. Management of Chemicals in Wastestream
                     The Pollution Prevention Act of 1990 (PPA) requires facilities to report
                     information about the management of TRI chemicals in waste and efforts
                     made to eliminate or reduce those quantities. These data have been collected
                     annually in Section 8 of the TRI reporting Form R beginning with the 1991
                     reporting year. The data summarized below cover the years 1992-1995 and
                     is meant to provide a basic understanding of the quantities of waste handled
                     by the industry, the methods typically used to manage this waste, and recent
                     trends in these methods. TRI waste management data can be used to assess
                     trends in source reduction within individual industries and facilities, and for
                     specific TRI chemicals.  This information could  then be used as a tool in
                     identifying opportunities for pollution prevention compliance assistance
                     activities.

                     From the yearly data presented below it is apparent that the portion of TRI
                     wastes reported as recycled on-site has increased and the portions treated or
                     managed through energy recovery on-site have decreased between 1992 and
                     1995 (projected).   While the quantities reported for  1992 and 1993  are
                     estimates of quantities already managed, the quantities reported for 1994 and
                     1995 are projections only. The PPA requires these projections to encourage
                     facilities to consider future waste generation and  source reduction of those
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                    quantities as well as movement up the waste management hierarchy. Future-
                    year estimates are not commitments that facilities reporting under TRI are
                    required to meet.

                    Exhibit 16 shows that the petroleum refining industry managed about 1.6
                    billion pounds of production-related waste (total quantity of TRI chemicals
                    in the waste from routine production operations)  in  1993 (column B).
                    Column C reveals that of this production-related waste, 30 percent was either
                    transferred off-site or released to the environment. Column C is calculated
                    by dividing the total TRI transfers and releases  by the total quantity of
                    production-related waste. In other words, about 70 percent of the industry's
                    TRI wastes were managed on-site through recycling, energy recovery, or
                    treatment as shown in columns E, F and G, respectively.  The majority of
                    waste that is released or transferred off-site can be divided into portions that
                    are recycled off-site, recovered for energy off-site, or treated off-site as
                    shown in columns H, I and J, respectively.  The remaining portion of the
                    production related wastes (4 percent), shown in column D, is either released
                    to the  environment through  direct discharges  to  air, land, water, and
                    underground injection, or it is disposed of off-site.
Exhibit 16: Source Reduction and Recycling Activity for Petroleum Industry (SIC 2911)
as Reported within TRI
A
Year
1992
1993
1994
1995
B
Quantity of
Production-
Related
Waste
(106 lbs.)a
1,476
1,600
1,867
1,717
C
% Released
and
Transferred11
24%
30%
—
_—
D
% Released
and
Disposed0
Off-site
3%
4%
4%
4%
On-Site
E
%
Recycled
10%
14%
19%
21%
F
% Energy
Recovery
37%
36%
37%
32%
G
% Treated
22%
20%
15%
17%
Off-Site
H
%
Recycled
27%
26%
25%
27%
I
% Energy
Recovery
<1%
<1%
<1%
<1%
J
% Treated
<1%
<1%
<1%
<1%
a Within this industry sector, non-production related waste < 1 percent of production related wastes for 1993.
b Total TRI transfers and releases as reported in Sections 5 and 6 of Form R as a percentage of production related
wastes.
c Percentage of production related waste released to the environment and transferred off-site for disposal.
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IV. CHEMICAL RELEASE AND TRANSFER PROFILE
                    This section is designed to provide background information on the pollutant
                    releases that are reported by this industry. The best source of comparative
                    pollutant release information is the Toxic Release Inventory System (TRI).
                    Pursuant to the Emergency Planning and Community Right-to-Know Act,
                    TRI includes self-reported facility release and transfer data for over 600 toxic
                    chemicals.  Facilities within SIC Codes 20 through 39 (manufacturing
                    industries) that have more than 10 employees, and that are above weight-
                    based reporting thresholds are required to report TRI on-site releases and off-
                    site transfers.  The information presented within the sector notebooks is
                    derived from the most recently available (1993) TRI reporting  year, and
                    focuses primarily on the on-site releases reported by each sector. Because
                    TRI requires consistent reporting regardless of sector, it is an excellent tool
                    for drawing comparisons across industries.

                    Although this sector notebook  does not present historical information
                    regarding TRI chemical releases over time, please note that in general, toxic
                    chemical releases have been declining.  In fact, according to the 1993 Toxic
                    Release Inventory Data Book, reported releases dropped by 42.7 percent
                    between 1988  and 1993. Although on-site releases have decreased, the total
                    amount of reported toxic waste has not declined because the amount of toxic
                    chemicals transferred off-site has increased.  Transfers have increased from
                    3.7 billion pounds in 1991 to 4.7 billion pounds in 1993. Better management
                    practices have led to increases in off-site transfers of toxic  chemicals for
                    recycling.  More detailed information can be obtained from EPA's annual
                    Toxics Release Inventory Public Data Release book (which is available
                    through the EPCRA Hotline at 800-535-0202), or directly from the Toxic
                    Release Inventory System database (for user support call 202-260-1531).

                    Wherever possible, the sector notebooks present TRI data as the primary
                    indicator  of chemical release within each industrial category.  TRI data
                    provide the type, amount and media receptor of each chemical released or
                    transferred. When other sources of pollutant release data have been obtained,
                    these data have been included to augment the TRI information.
TRI Data Limitations
                     The reader should keep in mind the following limitations regarding TRI data.
                     Within some sectors, the majority of facilities are not subject  to TRI
                     reporting because they are not considered manufacturing industries, or
                     because they are below TRI reporting thresholds. Examples are the mining,
                     dry cleaning, printing, and transportation equipment cleaning sectors.  For
                     these sectors, release information from other sources has been included.
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                     The reader should also be aware that TRI "pounds released" data presented
                     within the notebooks is not equivalent to a "risk" ranking for each industry.
                     Weighting each pound of release equally does not factor in the relative
                     toxicity of each chemical that is released.  The Agency is in the process of
                     developing an approach to assign toxicological weightings to each chemical
                     released so that one can differentiate between pollutants with significant
                     differences in toxicity.  As a preliminary indicator of the environmental
                     impact of the industry's most commonly released chemicals, the notebook
                     briefly summarizes the toxicological properties of the top chemicals (by
                     weight) reported by each industry.

Definitions Associated with Section IV Data Tables

       General Definitions

                     SIC Code — is the Standard Industrial Classification (SIC) is a statistical
                     classification standard used for all establishment-based Federal economic
                     statistics. The SIC codes facilitate comparisons between facility and industry
                     data.

                     TRI Facilities — are manufacturing facilities that have 10 or more full-time
                     employees and are above  established chemical throughput  thresholds.
                     Manufacturing facilities are defined as facilities  in  Standard Industrial
                     Classification primary codes 20 to 39. Facilities must submit estimates for
                     all chemicals that are on the EPA's defined list and are above  throughput
                     thresholds.

       Data Table Column Heading Definitions

                     The following definitions are based upon standard definitions developed by
                     EPA's Toxic Release Inventory Program. The categories below represent the
                     possible pollutant destinations that can be reported.

                     RELEASES -- are an on-site  discharge of a toxic  chemical to  the
                     environment. This includes emissions to the air, discharges to bodies of
                     water, releases at the facility to land, as well as contained disposal into
                     underground injection wells.

                     Releases to  Air (Point  and Fugitive Air Emissions) ~ Include all air
                     emissions from industry activity. Point emission occur through confined air
                     streams as found in stacks, ducts, or pipes. Fugitive emissions include losses
                     from equipment leaks, or evaporative losses from impoundments, spills, or
                     leaks.
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                     Releases to Water (Surface Water Discharges) ~ encompass any releases
                     going directly to streams, rivers, lakes, oceans, or other bodies of water. Any
                     estimates for stormwater runoff and non-point losses must also be included.

                     Releases to Land — includes disposal of toxic chemicals in waste to on-site
                     landfills, land  treated or incorporation into soil,  surface impoundments,
                     spills, leaks, or waste piles. These activities must occur within the facility's
                     boundaries for inclusion in this category.

                     Underground  Injection — is a contained release of a fluid into a subsurface
                     well for the purpose of waste disposal.

                     TRANSFERS - is a transfer of toxic chemicals in wastes to a facility that
                     is geographically or physically separate from the facility reporting under
                     TRI. The quantities reported represent a movement of the chemical away
                     from the reporting facility.  Except for off-site transfers for disposal, these
                     quantities do  not necessarily represent entry of the  chemical into  the
                     environment.

                     Transfers to POTWs — are wastewaters transferred through pipes or sewers
                     to a publicly owned treatments works (POTW).  Treatment and chemical
                     removal depend on  the  chemical's nature  and treatment methods  used.
                     Chemicals not treated or destroyed by the POTW are generally released to
                     surface waters or land filled within the sludge.

                     Transfers to Recycling - are sent off-site for the purposes of regenerating
                     or recovering  still valuable materials.   Once these chemicals have been
                     recycled,  they  may  be returned  to  the originating facility or  sold
                     commercially.

                     Transfers to Energy Recovery - are wastes combusted off-site in industrial
                     furnaces for energy recovery. Treatment of a chemical by incineration is not
                     considered to be energy recovery.

                     Transfers  to Treatment  —  are  wastes moved  off-site  for  either
                     neutralization, incineration, biological destruction, or physical separation.
                     In some cases, the chemicals are not destroyed but prepared for further waste
                     management.

                     Transfers to  Disposal — are wastes taken to another facility for disposal
                     generally as a  release to land or as an injection underground.
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 IV.A. EPA Toxic Release Inventory for the Petroleum Refining Industry

                     The amount of TRI chemicals generated by the petroleum refining industry
                     provides a gross profile of the types and relative amounts of toxic chemical
                     outputs from refining processes.  Additional  information, which can be
                     related back to  possible compliance requirements, is available  from the
                     distribution of chemical  releases  across  specific  media within the
                     environment. The TRI data requires filers to list releases to air, water, and
                     land separately.  The distribution across media can also be compared to the
                     profile of other industry sectors.

                     The petroleum refining industry releases 75 percent of its total TRI poundage
                     to the air, 24 percent to the  water (including  20 percent to underground
                     injection and 4 percent to surface waters), and  1 percent to the land.  This
                     release profile differs from other TRI industries which average approximately
                     59 percent to air, 30 percent to water, and 10 percent to land. Examining the
                     petroleum refining industry's TRI reported toxic chemical releases highlights
                     the likely origins of the large air releases for the industry (Exhibit  16).

                     According to TRI data, in 1993 the petroleum refining industry released
                     (discharged to the air, water, or land without treatment) and transferred
                     (shipped off-site) a total of 482 million pounds of pollutants, made up of 103
                     different chemicals.  This represents about 11 percent of the total pounds of
                     TRI chemicals released and transferred by all manufacturers that year. In
                     comparison, the chemical industry (SIC 28) produced 2.5 billion pounds that
                     year, accounting for 33 percent of all releases and transfers.

                     Overall, the petroleum refining industry's releases declined between 1988 and
                     1993.  Between 1991 and 1993 the decrease in releases was 6.7 percent
                     compared to the average for all industries of 18 percent.  In the same period,
                     however, transfers were reported to increase 65 percent which is higher than
                     the  average increase  in transfers of 25  percent for all  manufacturing
                     industries. A large portion of the increases were in the  form of transfers to
                     recycling. Spent sulfuric acid generated in the alkylation process makes up
                     about half of all transfers of TRI listed chemicals off-site.  At the facility
                     level, the industry reported a level of pollution prevention activities of 42
                     percent of all refineries which is slightly higher than the overall average of
                     about 35 percent of TRI reporting facilities.

                     Comparisons  of the reported pounds released  or transferred per facility
                     demonstrate that the petroleum refining industry is far above average in its
                     pollutant releases and transfers per facility when compared to other TRI
                     industries. Of the twenty manufacturing SIC codes listed hi the TRI database,
                     the  mean amount of pollutant release per facility (including petroleum
                     refining) was approximately  120,000 pounds.  The TRI releases of the
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                     average petroleum refining facility (SIC 2911) were 404,000 pounds, making
                     the industry 3.4 times higher in per facility releases than for other industries.
                     For transfers, the mean of petroleum refining facilities was about 13 times as
                     much that of all TRI manufacturing facilities (202,000 pounds transferred
                     off-site per facility compared to 2,626,000 per refinery). These high releases
                     and transfers per facility reflect the large volumes of material processed at a
                     relatively small number of facilities.

                     Of the top ten most frequently reported toxic chemicals on the TRI list, the
                     prevalence of volatile chemicals explains the air intensive toxic chemical
                     loading of the refining industry.  Nine of the ten most commonly reported
                     toxic  chemicals are highly volatile.   Seven of the  ten are  aromatic
                     hydrocarbons (benzene, toluene, ethylbenzene, xylene, cyclohexane, 1,2,4-
                     trimethylbenzene  and ethylbenze).   Aromatic  hydrocarbons are highly
                     volatile compounds and make up a portion of both crude oil and many
                     finished petroleum products. Ammonia, the ninth most commonly reported
                     toxic chemical, is also released and transferred from petroleum refineries in
                     large quantities. Ammonia may be found in high concentrations in process
                     water streams from steam distillation processes and in refinery sour gas.  The
                     primary means of release to the environment is through underground
                     injection of wastewater and emissions to air. Gasoline blending additives
                     (i.e., methanol, ethanol, and MTBE)  and chemical feedstocks (propylene,
                     ethylene and napthalene) are also commonly reported to TRI.  Additives and
                     chemical feedstocks are, for the most part, released as air emissions due to
                     their high volatility.  A significant portion of the remaining chemicals of the
                     reported  TRI toxic chemicals are metals compounds, which are typically
                     transferred off-site for recovery or as a component of hazardous wastes.
                     Although it is not the most frequently reported toxic chemical released or
                     transferred, sulfuric acid is, by far, generated in the largest quantities. Spent
                     sulfuric acid is primarily generated during the alkylation process.  The acid
                     is typically transferred off-site for regeneration.
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49
SIC 2911

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     Sector Notebook Project
                                                                                                  Petroleum Refining
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                                                              51
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                                                                                       Petroleum Refining
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-------
 Sector Notebook Project
                            Petroleum Refining
                      The TRI database contains a detailed compilation of self-reported, facility-
                      specific chemical releases. The top reporting facilities for this sector are
                      listed below (Exhibit 19). Facilities that have reported only the SIC codes
                      covered under this notebook appear on the first list.  Exhibit 20 contains
                      additional facilities that have reported the SIC code covered within this
                      report,  and one or more SIC codes that are  not within the scope of this
                      notebook.  Therefore, the second list includes facilities that conduct multiple
                      operations — some that are under the scope of this notebook, and some that
                      are not. Currently, the facility-level data do not allow pollutant releases to
                      be broken apart by industrial process.
Exhibit 19: Top 10 TRI Releasing Petroleum Refineriesb
Rank
1
2
3
4
5
6
7
8
9
10
Facility
Amoco Oil Co. - Texas City, TX
Mobil Oil - Beaumont, TX
Chevron - Port Arthur, TX
BP Oil Co. Alliance Refinery - Belle Chasse, LA
Coastal Refining - Corpus Christi TX
Phillips P. R. Core Inc. - Guayama PR
Hess Oil St. Croix Refinery - Kingshill VI
Sun Refining & Marketing Co. - Tulsa, OK
Koch Refining Co. - Rosemount, MN
Koch Refining Co. - Corpus Christi TX
Total TRI Releases
in Pounds
13,196,734
4,312,079
2,513,247
1,992,942
1,827,682
1,806,163
1,720,814
1,555,245
1,395,612
1,329,136
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
b Being included in this list does not mean that the release is associated with non-compliance with environmental
laws.
September 1995
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                          Petroleum Refining
Exhibit 20: Top 10 TRI Releasing Facilities Reporting Petroleum Refining
SIC Codes to TRT
Rank
1
2
3
4
5
6
7
8
9
10
SIC Codes
Reported in
TRI
2911
2911,2869,2865,
2821
2911
2911
2911,2869,2992
2911,2819,2869
2911
2911,2869,2873
2911
2911
Facility
Amoco Oil Co. Texas City Refinery - Texas City, TX
Shell Oil Co., - Deer Park, TX
Mobil Oil Beaumont Refinery - Beaumont, TX
Chevron USA Products, Port Arthur Refinery - Port Arthur, TX
Lyondell-Citgo Refining Co. Ltd. - Houston, TX
Citgo Petroleum Corp. - Lake Charles, LA
BP Oil Co. Alliance Refinery - Belle Chasse, LA
Chevron Products Do. Pascagoula Refinery - Pascagoula, MS
Coastal Refining & Marketing Inc. - Corpus Christi, TX
Phillips P.R. Core Inc. Phillipa Paraxylene Inc. - Guayama, PR
Total TRI
Releases
in Pounds
13,196,734
4,542,726
4,312,079
2,513,247
2,340,426
2,116,136
1,992,942
1,922,457
1,827,682
1,806,163
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
IV.B. Summary of Selected Chemicals Released
                    The following is a synopsis of current scientific toxicity and fate information
                    for the top chemicals (by weight) that facilities within this sector self-
                    reported as released to the environment based upon 1993 TRI data. Because
                    this section is based upon self-reported release data, it does not attempt to
                    provide information on management practices employed by the sector to
                    reduce the release of these chemicals.  Information regarding  pollutant
                    release reductions over time may be available from EPA's TRI and 33/50
                    programs, or directly from the industrial trade associations that are listed in
                    Section LX of this document.  Since these descriptions are cursory, please
                    consult the sources referenced below for a more detailed description of both
                    the chemicals described in this section, and the chemicals that appear on the
                    full list of TRI chemicals appearing in Section IV. A.

                    The brief descriptions provided below were taken from the 1993  Toxics
                    Release  Inventory  Public Data Release  (EPA,  1994),  the  Hazardous
                    Substances Data Bank (HSDB), and the Integrated Risk Information System
c Being included on this list does not mean that the release is associated with non-compliance with environmental
laws.
September 1995
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                           Petroleum Refining
                      (IRIS), both accessed via TOXNETd.  The information contained below is
                      based upon exposure assumptions that have been conducted using standard
                      scientific procedures.  The effects listed below must be taken in context of
                      these exposure assumptions that are more fully explained within the full
                      chemical profiles in HSDB.

       Ammonia (CAS: 7664-41-7)

                      Sources.  Ammonia is formed from  the nitrogen bearing components of
                      crude oil and can be found throughout petroleum refineries in both the
                      gaseous and aqueous forms. Gaseous ammonia  often leaves distillation,
                      cracking and treating processes mixed with the sour gas or acid gas along
                      with refinery fuel gases and hydrogen sulfide.  Aqueous ammonia is present
                      in the sourwater generated in the vacuum distillation unit and steam strippers
                      or fractionators.  Some release sources include, fugitive emissions, sour gas
                      stripper, sulfur unit and wastewater discharges.

                      Toxicity. Anhydrous ammonia is irritating to the skin, eyes, nose, throat, and
                      upper respiratory system.

                      Ecologically, ammonia is a source of nitrogen (an essential element for
                      aquatic plant growth), and may therefore contribute to  eutrophication of
                      standing or slow-moving surface water, particularly in nitrogen-limited
                      waters  such as  the Chesapeake Bay. In addition,  aqueous ammonia is
                      moderately toxic to aquatic organisms.

                      Carcinogenicity.  There  is currently no evidence  to  suggest that this
                      chemical is carcinogenic.

                      Environmental Fate.  Ammonia combines  with  sulfate ions  in the
                      atmosphere and is washed  out by rainfall,  resulting in rapid return of
                      ammonia to the soil and surface waters. Ammonia is a central compound in
                      the  environmental cycling  of nitrogen.   Ammonia in  lakes, rivers, and
                      streams is converted to nitrate.
4 TOXNET is a computer system run by the National Library of Medicine that includes a number of toxicological
databases managed by EPA, National Cancer Institute, and the National Institute for Occupational Safety and
Health. For more information on TOXNET, contact the TOXNET help line at 800-231-3766. Databases included in
TOXNET are: CCRIS (Chemical Carcinogenesis Research Information System), DART (Developmental and
Reproductive Toxicity Database), DBIR (Directory of Biotechnology Information Resources), EMICBACK
(Environmental Mutagen Information Center Backfile), GENE-TOX (Genetic Toxicology), HSDB (Hazardous
Substances Data Bank), IRIS (Integrated Risk Information System), RTECS (Registry of Toxic Effects of Chemical
Substances), and TRI (Toxic Chemical Release Inventory). HSDB contains chemical-specific information on
manufacturing and use, chemical and physical properties, safety and handling, toxicity and biomedical effects,
pharmacology, environmental fate and exposure potential, exposure standards and regulations, monitoring and
analysis methods, and additional references.
September 1995
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                          Petroleum Refining
                    Physical Properties.  Ammonia is a corrosive and severely irritating gas
                    with a pungent odor.

       Toluene (CAS: 108-88-3)

                    Sources.  Toluene is a component of crude oil and is therefore present in
                    many refining operations.  Toluene is  also produced during catalytic
                    reforming and is sold as one of the large volume aromatics used as feedstocks
                    in chemical manufacturing. Its volatile nature makes fugitive emissions its
                    largest release source.  Point air sources may arise during the process of
                    separating toluene  from  other  aromatics  and  from solvent dewaxing
                    operations where toluene is often used as the solvent..

                    Toxicity.  Inhalation or ingestion of toluene can cause headaches, confusion,
                    weakness, and memory loss. Toluene may also affect the way the kidneys
                    and liver function.

                    Reactions of toluene (see environmental fate) in the atmosphere contribute
                    to the formation of ozone in the lower atmosphere.  Ozone can affect the
                    respiratory system,  especially in sensitive individuals such as asthma or
                    allergy sufferers.

                    Some studies have shown that unborn animals were harmed when high levels
                    of toluene were inhaled by their mothers, although the same effects were not
                    seen when the mothers were fed large quantities of toluene. Note that these
                    results may reflect similar difficulties in humans.

                    Carcinogenicity.   There is currently no evidence to  suggest that  this
                    chemical is carcinogenic.

                    Environmental Fate.  A portion of releases of toluene to land and water will
                    evaporate.  Toluene may also be degraded by microorganisms.  Once
                    volatilized, toluene in the lower atmosphere will react with other atmospheric
                    components contributing to the formation of ground-level ozone and other
                    air pollutants.

                    Physical Properties. Toluene is a volatile organic chemical.

       Xvlenes (Mixed Isomers) (CAS: 1330-20-7)

                    Sources.  Xylene isomers are a component of crude oil and are therefore
                    present in many refining operations. Xylenes are also produced during
                    catalytic reforming  and are sold as one of the large volume aromatics used
                    as feedstocks in chemical manufacturing. Xylene's volatile nature make
September 1995
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 Sector Notebook Project
                           Petroleum Refining
                     fugitive emissions the largest release source.  Point air sources may arise
                     during the process of separating xylene from other aromatics.

                     Toxicity.   Xylene are rapidly absorbed into the body  after inhalation,
                     ingestion, or skin contact. Short-term exposure of humans to high levels of
                     xylene can cause irritation of the skin, eyes, nose, and throat, difficulty in
                     breathing, impaired lung function, unpaired memory, and possible changes
                     in the liver and kidneys.   Both short-  and long-term exposure to high
                     concentrations can cause effects such as headaches, dizziness, confusion, and
                     lack of muscle coordination. Reactions of xylene (see environmental fate)
                     in the atmosphere contribute to the  formation of ozone in the lower
                     atmosphere. Ozone can affect the respiratory system, especially in sensitive
                     individuals such as asthma or allergy sufferers.

                     Carcinogenicity.   There  is currently no evidence  to suggest  that this
                     chemical is carcinogenic.

                     Environmental Fate.  A portion of releases to land and water will quickly
                     evaporate, although some degradation by  microorganisms will occur.

                     Xylene are moderately mobile in soils and may leach into groundwater,
                     where they may persist for several years.

                     Xylene are volatile organic chemicals.   As such, xylene in the lower
                     atmosphere will react with other atmospheric components, contributing to the
                     formation of ground-level ozone and other air pollutants.

       Methyl Ethvl Ketone (CAS: 78-93-3)

                     Sources. Methyl ethyl ketone (MEK) is used hi some refineries as a solvent
                     hi lube oil dewaxing.  Its extremely volatile characteristic makes fugitive
                     emissions its primary source of releases,to the environment.

                     Toxicity.  Breathing moderate amounts of methyl ethyl ketone (MEK) for
                     short periods of time can cause adverse effects on the nervous system ranging
                     from headaches, dizziness, nausea, and numbness in the fingers and toes to
                     unconsciousness. Its vapors are irritating to the skin, eyes, nose, and throat
                     and can damage the eyes. Repeated exposure to moderate to high amounts
                     may cause liver and kidney effects.

                     Carcinogenicity.  No agreement exists over the  carcinogenicity of MEK.
                     One source believes MEK is  a possible  carcinogen in humans based on
                     limited animal evidence.  Other sources  believe that there  is insufficient
                     evidence to make any statements about possible carcinogenicity.
September 1995
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                          Petroleum Refining
                    Environmental Fate. Most of the MEK released to the environment will
                    end up in the atmosphere.  MEK can contribute to the formation of air
                    pollutants in the lower atmosphere. It can be degraded by microorganisms
                    living in water and soil.

                    Physical Properties. Methyl ethyl ketone is a flammable liquid.

       Propvlene (CAS: 115-07-1)

                    Sources.  Propylene (propene) is one of the  light ends formed during
                    catalytic and thermal cracking and coking operations. It is usually collected
                    and used as a feedstock to the alkylation unit.  Propylene is volatile and
                    soluble hi water making releases to both air and water significant.

                    Toxicity.   At low concentrations, inhalation of propylene  causes mild
                    intoxication, a tingling sensation, and an inability to concentrate. At higher
                    concentrations, unconsciousness, vomiting, severe vertigo, reduced blood
                    pressure, and disordered heart rhythms may occur.  Skin or eye contact with
                    propylene causes freezing burns.

                    Reaction of propylene (see environmental fate) in the atmosphere contributes
                    to the formation of ozone in the lower atmosphere. Ozone can affect the
                    respiratory  system, especially in sensitive  individuals such  as asthma  or
                    allergy sufferers.

                    Ecologically, similar to ethylene, propylene has a stimulating effect on plant
                    growth at low concentrations, but inhibits plant growth at high levels.

                    Carcinogenicity.   There is currently no  evidence to  suggest that this
                    chemical is carcinogenic.

                    Environmental Fate. Propylene is degraded principally by hydroxyl ions
                    in the atmosphere.  Propylene released to soil and water is removed primarily
                    through volatilization. Hydrolysis, bioconcentration, and soil adsorption are
                    not expected to be significant fate processes of propylene in soil or aquatic
                    ecosystems. Propylene is readily biodegraded by microorganisms in surface
                    water.

                    Physical Properties. Propylene is a volatile organic chemical.

       Benzene (CAS: 71-43-2)

                    Sources.  Benzene is a component of crude oil and is therefore present in
                    many refining operations.  Benzene  is also  produced during catalytic
                    reforming and is sold as one of the large volume aromatics used as feedstocks
September 1995
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Sector Notebook Project
                          Petroleum Refining
                     in  chemical manufacturing.   Benzene's volatile nature makes fugitive
                     emissions the largest release source. Point air sources may arise during the
                     process of separating benzene from other aromatics.

                     Toxicity.  Short-term inhalation of benzene  primarily affects the central
                     nervous system and respiratory system. Chronic exposure to benzene causes
                     bone marrow toxicity in animals and humans, causing suppression of the
                     immune system and development of leukemia.  Ingestion of benzene is rare.

                     Reactions of benzene (see environmental fate) in the atmosphere contributes
                     to the formation of ozone in the lower atmosphere (troposphere). Ozone can
                     affect the respiratory system,  especially in sensitive individuals such as
                     asthma or allergy sufferers.

                     Carcinogenicity. Benzene is a known human carcinogen, based on both oral
                     and inhalation exposures.

                     Environmental Fate. A portion of benzene releases to soil and surface
                     waters evaporate rapidly.  Benzene is highly mobile in the soil and may leach
                     to  groundwater.    Once in  groundwater,  it is  likely  biodegraded  by
                     microorganisms only in the presence of oxygen.

                     Benzene is not expected to significantly adsorb  to sediments, bioconcentrate
                     in aquatic organisms or break down in water.   Atmospheric benzene is
                     broken down through reacting with chemical ions in the air; this process is
                     greatly accelerated in the presence of other air pollutants such as nitrogen
                     oxides or sulfur dioxide.  Benzene is fairly soluble in water and is removed
                     from the atmosphere in rain.

                     As a volatile chemical, benzene in the lower atmosphere will react with other
                     atmospheric components, contributing to the formation of ground-level ozone
                     and other air pollutants, which can contribute to respiratory illnesses in both
                     the general and highly susceptible populations, such  as asthmatics  and
                     allergy-sufferers.
September 1995
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                          Petroleum Refining
IV.C. Other Data Sources
                    In addition to chemicals covered under TRI, many other chemicals are
                    released.  For example, the EPA Office  of Air  Quality Planning and
                    Standards has compiled  air pollutant emission factors for determining the
                    total air emissions  of priority pollutants  (e.g., VOCs, SOX, NQ, CO,
                    particulates, etc.) from many refinery sources.77

                    The EPA Office of Air's Aerometric Information Retrieval System (AIRS)
                    contains a wide range of information related to stationary sources of air
                    pollution, including the emissions of a number of air pollutants which may
                    be of concern within a particular industry.  With the exception of volatile
                    organic compounds (VOCs), there is little overlap with the TRI chemicals
                    reported above. Exhibit 18 summarizes annual releases of carbon monoxide
                    (CO), nitrogen dioxide  (NO2), particulate  matter of 10 microns or less
                    (PM10), total particulates (PT), sulfur dioxide (SO2), and volatile organic
                    compounds (VOCs).
September 1995
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Exhibit 21: Pollutant Releases (short tons/year)
Industry Sector
Metal Mining
Nonmetal Mining
Lumber and Wood Production
Furniture and Fixtures
Pulp and Paper
Printing
Inorganic Chemicals
Organic Chemicals
Petroleum Refining
Rubber and Misc. Plastics
Stone, Clay and Concrete
Iron and Steel
Nonferrous Metals
Fabricated Metals
Computer and Office Equipment
Electronics and Other Electrical Equipment
and Components
Motor Vehicles, Bodies, Parts and
Accessories
Dry Cleaning
CO
5,391
4,525
123,756
2,069
624,291
8,463
166,147
146,947
419,311
2,090
58,043
1,518,642
448,758
3,851
24
367
35,303
101
NO2
28,583
28,804
42,658
2,981
394,448
4,915
103,575
236,826
380,641
11,914
338,482
138,985
55,658
16,424
0
1,129
23,725
179
PM10
39,359
59,305
14,135
2,165
35,579
399
4,107
26,493
18,787
2,407
74,623
42,368
20,074
1,185
0
207
2,406
3
PT
140,052
167,948
63,761
3,178
113,571
1,031
39,062
44,860
36,877
5,355
171,853
83,017
22,490
3,136
0
293
12,853
28
SO2
84,222
24,129
9,419
1,606
541,002
1,728
182,189
132,459
648,155
29,364
339,216
238,268
373,007
4,019
0
453
25,462
152
voc
1,283
1,736
41,423
59,426
96,875
101,537
52,091
201,888
369,058
140,741
30,262
82,292
27,375
102,186
0
4,854
101,275
7,310
Source: U.S. EPA Office of Air and Radiation, AIRS Database, May 1995.
September 1995
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                          Petroleum Refining
IV.D.  Comparison of Toxic Release Inventory Between Selected Industries

                     The following information is presented as a comparison of pollutant release
                     and transfer data across industrial categories. It is provided to give a general
                     sense as to the relative  scale of releases and transfers within each sector
                     profiled under this project. Please note that the following figure and table do
                     not contain releases and transfers for  industrial categories  that are not
                     included in this project,  and thus cannot be used to  draw conclusions
                     regarding the total release and transfer amounts that are reported to TRI.
                     Similar information is available within the annual TRI Public Data Release
                     Book.

                     Exhibit 22 is a graphical representation of a summary of the 1993 TRI data
                     for the petroleum refining industry and the other sectors profiled in separate
                     notebooks.  The bar graph presents the total TRI releases and total transfers
                     on the left axis and the triangle points show the average releases per facility
                     on the right axis.  Industry sectors are presented in the order of increasing
                     total TRI releases. The graph is based on the data shown in Exhibit 23 and
                     is meant to facilitate comparisons between the relative amounts of releases,
                     transfers, and releases per facility both within and between these sectors. The
                     reader should note, however, that differences in the proportion of facilities
                     captured by TRI exist between industry sectors. This can be a factor of poor
                     SIC matching and relative differences in the number of facilities reporting to
                     TRI from the various sectors, hi the case of petroleum refining, the 1993
                     TRI data presented here covers 159 facilities. These facilities listed SIC 2911
                     (petroleum refining) as a primary SIC code.
 September 1995
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 Sector Notebook Project
                        Petroleum Refining
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64
SIC 2911

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Sector Notebook Project
                        Petroleum Refining









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V. POLLUTION PREVENTION OPPORTUNITIES

                    The best way to reduce pollution is to prevent it in the first place.  Some
                    companies have creatively implemented pollution prevention techniques that
                    improve efficiency and increase profits while at the same time minimizing
                    environmental  impacts.  This can be done in many ways such as reducing
                    material inputs, re-engineering processes to  reuse by-products, improving
                    management practices, and employing substitution of toxic chemicals. Some
                    smaller facilities are able to actually get below regulatory thresholds just by
                    reducing pollutant releases through aggressive pollution prevention policies.

                    In order to encourage these approaches, this  section provides both general
                    and company-specific descriptions of some pollution prevention advances
                    that have been  implemented within the petroleum refining industry.  While
                    the list is not exhaustive, it does provide core information that can be used
                    as the starting point for facilities interested in  beginning their own pollution
                    prevention projects. When possible, this section provides information from
                    real activities  that can  be, or are being, implemented by this sector —
                    including a discussion of associated costs, time frames, and expected rates of
                    return.  This section provides summary information from activities that may
                    be, or are being implemented by this sector. When possible, information is
                    provided that gives the  context in which the technique can be effectively
                    used.   Please  note that the activities described in this section do  not
                    necessarily apply to all facilities that fall within this sector.  Facility-specific
                    conditions must be carefully considered when pollution prevention options
                    are evaluated, and the full  impacts of the change must examine how each
                    option affects air, land and water pollutant releases.

       Drivers and Barriers to Pollution Prevention in the Petroleum Refining Industry

                    Pollution prevention in the petroleum refining  industry is expected to become
                    increasingly important as federal, state and municipal regulations become
                    more stringent and as waste disposal costs rise.  According to the American
                    Petroleum Institute, the industry currently spends a significant amount of
                    money every year on environmental quality and protection78. This provides
                    the industry with a strong incentive to find ways to reduce the generation of
                    waste and to lessen the  burden of environmental compliance investments.
                    For the petroleum refining  industry, pollution prevention will primarily be
                    realized through improved operating procedures, increased recycling, and
                    process modifications.

                    A cooperative effort of the Amoco Corporation and EPA to study pollution
                    prevention at an operating oil refinery identified a number of cost effective
                    pollution prevention techniques for the refinery that could also be adopted by
                    other refineries.  In addition, the American  Petroleum Institute (API)  has
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                     assembled a compendium of waste minimization practices for the petroleum
                     industry based on a survey of its members. Brief descriptions of some of the
                     more widespread pollution prevention techniques found to be effective at
                     petroleum refineries are provided below.  For more detail on the pollution
                     prevention options listed below and for descriptions of facility- and process-
                     specific options refer to the above mentioned documents and other pollution
                     prevention/waste minimization documents listed in Section IX - Resource
                     Materials.

                     Although numerous cases have been documented where petroleum refineries
                     have simultaneously reduced pollution outputs and operating costs through
                     pollution prevention  techniques,  there  are  often  barriers  to  their
                     implementation.  The primary barrier to most pollution prevention projects
                     is cost. Many pollution prevention options simply do not pay for themselves.
                     Corporate investments typically must earn an adequate return on invested
                     capital for the shareholders and some pollution prevention options at some
                     facilities may not meet the requirements set by the companies.  In addition,
                     the  equipment used in the petroleum refining industry are very capital
                     intensive and have very long lifetimes. This reduces the incentive to make
                     process modifications to (expensive) installed equipment that is still useful.
                     It should be noted that pollution prevention techniques are, nevertheless,
                     often  more cost-effective than pollution reduction through  end-of-pipe
                     treatment. A case study based on the Amoco/EPA joint study claimed that
                     the  same pollution reduction  currently realized  through  end-of-pipe
                     regulatory requirements at the Amoco facility could be achieved at 15
                     percent the current costs using pollution prevention techniques.

                     A number of regulatory disincentives to voluntary reductions of emissions
                     from petroleum refineries also exist. Many environmental statutes define a
                     baseline period  and measure progress in pollution reductions from  that
                     baseline.  Any reduction in emissions before it is required could lower a
                     facility's baseline emissions.  Consequently, future regulations requiring a
                     specified reduction from the baseline could be more costly to achieve
                     because the most cost-effective reductions would already have been made.
                     With no credit given for voluntary reductions, those facilities that do the
                     minimum may be in  fact be rewarded  when emissions reductions are
                     required.

                     The 1990 Clean  Air  Act Amendments aimed to encourage voluntary
                     reductions above the regulatory requirements by allowing facilities to obtain
                     emission credits for voluntary reductions hi emissions. These credits would
                     serve as offsets against any potential future facility modifications resulting
                     in  an increase  in  emissions.   Other   regulations  established by  the
                     amendments, however, will require the  construction of major new units
                     within  existing  refineries to produce  reformulated fuels.  These new
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                    operations will require emission offsets in order to be permitted. This will
                    consume many of the credits available for existing facility modifications. A
                    shortage of credits for facility modifications will make it difficult to receive
                    credits for emission reductions through pollution prevention projects.

                    Under the Clean Water Act, discharge of water-borne pollutants is limited by
                    NPDES permits. Refineries that easily meet their permit requirements will
                    often have their permit limits changed to lower values. Because occasional
                    system upsets do occur resulting in significant excursions above the normal
                    performance values, refineries feel  they  must maintain a  large operating
                    margin below the permit limits to ensure continuous compliance.  Those
                    refineries that can significantly  reduce  water-borne emissions through
                    pollution prevention techniques may find the risk of having their permit
                    limits lowered to be a substantial disincentive.

                    Wastes failing a Toxicity Characteristic (TC) test are considered hazardous
                    under RCRA. There is less incentive for a refinery to attempt to reduce the
                    toxicity of such waste below the TC levels because, even though such
                    toxicity reductions may render the waste non-hazardous, it may still have to
                    comply with new Land Disposal treatment standards under subtitle C of
                    RCRA before being land disposed. Similarly, there is little positive incentive
                    to reduce the toxicity of listed refinery hazardous wastes because, once listed,
                    the waste is subject to subtitle C regulations without regard to how much the
                    toxicity levels are reduced.

                    Examples of Process or Equipment Modifications Options

                    Place secondary seals on storage  tanks - One of the largest sources of
                    fugitive emissions from refineries is storage tanks containing gasoline and
                    other volatile products.  These  losses can be  significantly reduced by
                    installing secondary seals on storage tanks.  The Amoco/EPA joint study
                    estimated that VOC losses from storage  tanks could be reduced 75 to 93
                    percent.  Equipping an average tank with a secondary seal system was
                    estimated to cost about $20,000.

                    Establish leak detection and repair program - Fugitive emissions are one
                    of the largest sources of refinery hydrocarbon emissions. A leak detection
                    and repair (LDAR) program consists of using a portable  VOC detecting
                    instrument to detect leaks during regularly scheduled inspections of valves,
                    flanges, and pump seals.  Leaks are then repaired immediately or are
                    scheduled for repair as quickly as possible. A LDAR program could reduce
                    fugitive emissions 40  to  64  percent,  depending on the frequency of
                     inspections.
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                     Regenerate or eliminate filtration clay - Clay from refinery filters must
                     periodically be replaced.  Spent clay often contains significant amounts of
                     entrained hydrocarbons and, therefore, must be designated as hazardous
                     waste.   Back washing spent clay  with  water or steam can reduce the
                     hydrocarbon content to levels so that it can be  reused or handled as a
                     nonhazardous waste. Another method used to regenerate clay is to wash the
                     clay with naphtha, dry it by steam heating and then feed it to a burning kiln
                     for regeneration.  In some cases clay filtration can be replaced entirely with
                     hydrotreating.

                     Reduce the generation of tank bottoms - Tank bottoms from crude oil
                     storage tanks constitute a large percentage of refinery solid waste and pose
                     a particularly difficult disposal problem due to the presence of heavy metals.
                     Tank bottoms are comprised of heavy hydrocarbons, solids, water, rust and
                     scale.  Minimization of tank bottoms is carried out most cost effectively
                     through careful separation of the oil and water remaining in the tank bottom.
                     Filters and centrifuges can also be used to recover the oil for recycling.

                     Minimize solids leaving the desalter - Solids entering the crude distillation
                     unit are likely to eventually attract more oil and produce additional emulsions
                     and sludges. The amount of solids removed from the desalting unit should,
                     therefore, be maximized. A number of techniques can be used such as: using
                     low shear mixing devices to mix desalter wash water and crude oil; using
                     lower pressure water in the desalter to avoid turbulence; and replacing the
                     water jets used in some refineries with mud rakes which add less turbulence
                     when removing settled solids.

                     Minimize cooling tower blowdown - The dissolved solids concentration in
                     the recirculating cooling water is controlled by purging or blowing down a
                     portion of the cooling water stream to the wastewater treatment system.
                     Solids in the blowdown eventually create additional sludge in the wastewater
                     treatment plant.  However, the amount of cooling tower blowdown can be
                     lowered by minimizing the dissolved solids content of the cooling water. A
                     significant portion of the total dissolved solids in the cooling water can
                     originate in the cooling water makeup stream in the form of naturally
                     occurring calcium carbonates.  Such solids can  be controlled  either by
                     selecting a source of cooling tower makeup water with less dissolved solids
                     or  by removing  the dissolved solids from  the  makeup water stream.
                     Common treatment methods include: cold lime softening, reverse osmosis,
                     or electrodialysis.

                     Install vapor recovery for barge loading - Although barge loading is not
                     a factor for all refineries, it is an important emissions  source for many
                     facilities. One of the largest sources of VOC emissions identified during the
                     Amoco/EPA study was fugitive emissions from loading of tanker barges. It
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                    was estimated that these emissions could be reduced 98 percent by installing
                    a marine vapor loss control system.  Such systems could consist of vapor
                    recovery or VOC destruction in a flare.

                    Minimize FCCU decant oil sludge - Decant oil sludge from the  fluidized
                    bed catalytic cracking unit (FCCU) can contain significant concentrations of
                    catalyst fines. These fines often prevent the use of decant oil as a feedstock
                    or require treatment which generates an oily catalyst sludge.  Catalysts in the
                    decant oil can be minimized by using a decant oil catalyst removal system.
                    One system incorporates high voltage electric fields to polarize and capture
                    catalyst particles in the oil. The amount of catalyst fines reaching the decant
                    oil can be minimized by installing high efficiency cyclones in the reactor to
                    shift catalyst fines losses from the decant oil to the regenerator where they
                    can be collected in the electrostatic precipitator.

                    Control of heat exchanger cleaning solids - In many refineries, using high
                    pressure water to clean heat exchanger bundles generates and releases water
                    and entrained solids to the refinery wastewater treatment system. Exchanger
                    solids may then attract oil as they move through the sewer system and may
                    also produce finer solids and stabilized emulsions that are more difficult to
                    remove.  Solids can be  removed at the heat exchanger cleaning pad by
                    installing concrete overflow weirs around the surface drains or by covering
                    drains with a screen.  Other ways to  reduce solids generation are by using
                    anti-foulants on the heat exchanger bundles to prevent  scaling and by
                    cleaning with reusable cleaning chemicals that also  allow for  the  easy
                    removal of oil.

                    Control of surfactants in wastewater - Surfactants entering the refinery
                    wastewater  streams will increase the  amount of emulsions and sludges
                    generated.  Surfactants can enter the  system from a number of sources
                    including: washing unit pads with detergents; treating gasolines with an end
                    point over 400 degrees (F) thereby producing spent caustics;  cleaning tank
                    truck tank interiors; and using soaps  and cleaners for miscellaneous tasks.
                    In addition, the overuse, and mixing of the organic polymers used to separate
                    oil, water and solids in the wastewater treatment plant can actually stabilize
                    emulsions.   The use of surfactants should be minimized  by educating
                    operators, routing surfactant sources to a point downstream of the DAF unit
                    and by using dry cleaning, high pressure water or steam to clean oil surfaces
                    of oil and dirt.

                    Thermal treatment of applicable sludges - The toxicity and volume of
                    some deoiled and dewatered sludges can be further reduced through thermal
                    treatment. Thermal sludge treatment units use heat to vaporize the water and
                    volatile components in the feed and leave behind a dry solid residue.  The
                    vapors  are  condensed for  separation into the hydrocarbon and water
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                    components. Non-condensible vapors are either flared or sent to the refinery
                    amine unit for treatment and use as refinery fuel gas.

                    Eliminate use of open ponds - Open ponds used to cool, settle out solids
                    and store process water can be a significant source of VOC emissions.
                    Wastewater from coke cooling and coke VOC removal is occasionally cooled
                    in open ponds where VOCs easily escape to the atmosphere.  In many cases,
                    open ponds can be replaced with closed storage tanks.

                    Remove unnecessary storage tanks from service - Since storage tanks are
                    one of the largest sources of VOC emissions, a reduction in the number of
                    these tanks can have a significant impact.  The need for certain tanks can
                    often be  eliminated through improved production  planning and more
                    continuous operations.  By minimizing the number of storage tanks, tank
                    bottom solids and decanted wastewater may also be reduced.

                    Replace old boilers - Older refinery boilers can be a significant source of
                    SOX, NOX and particulate emissions. It is possible to replace a large number
                    of old boilers with a single new cogeneration plant with emissions controls.

                    Modify the FCCU to allow the use of catalyst fines - Some FCCUs can be
                    modified to recycle some of the catalyst fines generated.

                    Reduce the use of 55-galIon drums - Replacing 55-gallon drums with bulk
                    storage can minimize the chances of leaks and spills.

                    Install rupture discs and plugs - Rupture discs on pressure relieve valves
                    and plugs in open ended valves can reduce fugitive emissions.

                    Install high pressure power washer - Chlorinated solvent vapor degreasers
                    can be replaced with high pressure power  washers which do not generate
                    spent solvent hazardous wastes.

                    Refurbish or eliminate underground piping - Underground piping can be
                    a source of undetected releases to the soil and groundwater. Inspecting,
                    repairing or replacing underground piping with surface piping can reduce or
                    eliminate these potential sources..
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                    Examples of Potential Waste Segregation and Separation Options

                    Segregate process waste streams - A significant portion of refinery waste
                    arises  from oily  sludges found in  combined  process/storm  sewers.
                    Segregation of the relatively clean rainwater runoff from the process streams
                    can reduce the quantity of oily sludges  generated.  Furthermore, there is a
                    much higher potential for recovery of oil from smaller, more concentrated
                    process streams.

                    Control solids entering sewers - Solids released to the wastewater sewer
                    system can  account for a large portion of a refinery's oily sludges.  Solids
                    entering the sewer system (primarily soil particles) become coated with oil
                    and are deposited as oily sludges in the API oil/water separator.  Because a
                    typical sludge has a solids content of 5 to 30 percent by weight, preventing
                    one pound of solids from entering the sewer system can eliminate 3 to 20
                    pounds of oily sludge.  The Amoco/EPA study estimated that at the
                    Yorktown facility 1,000 tons of solids  per year enter the refinery sewer
                    system.  Methods used to control solids include: using a street sweeper on
                    paved areas, paving unpaved areas, planting ground cover on unpaved areas,
                    re-lining sewers, cleaning solids from ditches and catch basins, and reducing
                    heat exchanger bundle cleaning solids by using antifoulants in cooling water.

                    Improve recovery of oils from oily sludges - Because oily sludges make up
                    a large portion of refinery solid wastes, any improvement in the recovery of
                    oil from the sludges can significantly reduce the volume of waste. There are
                    a number of technologies currently in use to mechanically separate oil, water
                    and solids, including: belt filter presses, recessed chamber pressure filters,
                    rotary vacuum filters, scroll centrifuges, disc centrifuges, shakers, thermal
                    driers and centrifuge-drier combinations.

                    Identify benzene sources and install upstream water treatment - Benzene
                    in wastewater can often be treated more  easily and effectively at the point it
                    is generated rather than at the wastewater treatment plant after it is mixed
                    with other wastewater.

                    Examples of Recycling Options

                    Recycle and regenerate spent caustics  - Caustics used to absorb  and
                    remove hydrogen sulfide and phenol contaminants from intermediate and
                    final product streams can often be recycled. Spent caustics may be saleable
                    to chemical recovery companies if concentrations of phenol or hydrogen
                    sulfide are high enough. Process changes in the refinery may be needed to
                    raise the concentration of phenols in the caustic to make recovery of the
                    contaminants economical. Caustics containing phenols can also be recycled
                    on-site by reducing the pH of the caustic until the phenols become insoluble
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                     thereby allowing physical separation.  The caustic can then be treated in the
                     refinery wastewater system.

                     Use oily sludges as feedstock - Many oily sludges can be sent to a coking
                     unit or the crude distillation unit where it becomes part of the refinery
                     products. Sludge sent to the coker can be injected into the coke drum with
                     the quench water, injected directly into the delayed coker, or injected into the
                     coker blowdown contactor used in separating the quenching products.  Use
                     of sludge as a feedstock has increased significantly  in recent years and is
                     currently carried out by most refineries. The quantity of sludge that can be
                     sent to the coker is restricted by coke quality specifications which may limit
                     the amount of sludge solids in the coke. Coking operations can be upgraded,
                     however, to increase the amount of sludge that they can handle.

                     Control and reuse FCCU and coke fines - Significant quantities of catalyst
                     fines are often present around the FCCU catalyst hoppers and reactor and
                     regeneration vessels.  Coke fines are often present around the coker unit and
                     coke storage areas. The fines can be collected and recycled before being
                     washed to  the sewers  or migrating off-site via the wind.  Collection
                     techniques include dry sweeping the catalyst and coke fines and sending the
                     solids to be recycled or disposed of as non-hazardous waste. Coke fines can
                     also be recycled for fuel use.  Another collection technique involves the use
                     of vacuum ducts  in dusty areas (and vacuum hoses for manual collection)
                     which run to a small baghouse for collection.

                     Recycle lab samples - Lab samples can be recycled to the oil recovery
                     system.

                     Examples of Training and Supervision

                     Train personnel to reduce solids in sewers - A facility training program
                     which emphasizes the importance of keeping solids out of the sewer systems
                     will help reduce that portion of wastewater treatment plant sludge arising
                     from the everyday activities of refinery personnel.

                     Train personnel to prevent soil contamination - Contaminated soil can be
                     reduced by educating personnel on how to avoid leaks and spills.

                     Examples of Potential Material Substitution

                     Use non-hazardous degreasers - Spent conventional degreaser solvents can
                     be reduced or eliminated through  substitution with less  toxic and/or
                     biodegradable products.
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                    Eliminate chromates as an anti-corrosive - Chromate containing wastes
                    can be reduced or eliminated in cooling tower and heat exchanger sludges by
                    replacing chromates with less toxic alternatives such as phosphates.

                    Use high quality catalysts - By using catalysts of a higher quality, process
                    efficiencies can be increased  while  the required frequency of catalyst
                    replacement can be reduced.

                    Replace ceramic catalyst support with activated alumina supports -
                    Activated alumina supports can be recycled with spent alumina catalyst. .
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VI. SUMMARY OF APPLICABLE FEDERAL STATUTES AND REGULATIONS

                    This section discusses the Federal regulations that may apply to this sector.
                    The purpose of this section is to highlight and briefly describe the applicable
                    Federal requirements, and to provide citations for more detailed inforrnation.
                    The three following sections are included:

                    •      Section VI. A contains a general overview of major statutes
                    •      Section VLB contains a list of regulations specific to this industry
                    •      Section VI.C contains a list of pending and proposed regulations

                    The descriptions  within  Section  VI are  intended  solely  for general
                    information.  Depending upon the nature or scope of the activities at a
                    particular facility, these summaries may or may not necessarily describe all
                    applicable environmental requirements.  Moreover, they do not constitute
                    formal interpretations or clarifications of the statutes and regulations.  For
                    further information, readers should consult the Code of Federal Regulations
                    and other state or local regulatory agencies.  EPA Hotline contacts are also
                    provided for each major statute.

VI.A.  General Description of Major Statutes

Resource Conservation and Recovery Act (RCRA)

                    The Resource Conservation And Recovery Act (RCRA)  of 1976, which
                    amended the Solid Waste Disposal Act, addresses solid (Subtitle D)  and
                    hazardous (Subtitle C) waste management activities.  The Hazardous  and
                    Solid Waste Amendments (HSWA) of 1984 strengthened RCRA's hazardous
                    waste management provisions and added Subtitle  I,  which  governs
                    underground storage tanks (USTs).

                    Regulations promulgated pursuant to Subtitle C of RCRA (40 CFR Parts
                    260-299) establish a "cradle-to-grave" system governing hazardous waste
                    from the point of generation to disposal.  RCRA hazardous wastes include
                    the specific materials listed  in the regulations (commercial  chemical
                    products, designated  with the code "P"  or  "U"; hazardous wastes from
                    specific  industries/sources,  designated with the  code  "K";  or hazardous
                    wastes from  non-specific  sources, designated with the  code  "F")  and
                    materials which  exhibit a  hazardous  waste  characteristic  (ignitability,
                    corrosivity, reactivity, or toxicity and designated with the code "D").

                    Regulated entities  that generate hazardous waste are subject to waste
                    accumulation, manifesting, and record keeping standards. Facilities  that
                    treat, store, or dispose of hazardous waste must obtain a permit, either from
                    EPA or from a State agency which EPA has authorized to implement the
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                     permitting program. Subtitle C permits contain general facility standards
                     such as contingency plans, emergency procedures, record keeping and
                     reporting requirements, financial assurance mechanisms, and unit-specific
                     standards. RCRA also contains provisions (40 CFR Part 264, Subpart S and
                     §264.10) for conducting corrective actions which govern the cleanup of
                     releases of hazardous waste or constituents from solid waste management
                     units at RCRA-regulated facilities.

                     Although RCRA is a Federal statute, many States implement the RCRA
                     program. Currently, EPA has delegated its authority to implement various
                     provisions of RCRA to 46 of the 50 States.

                     Most RCRA requirements are not industry specific but apply to any company
                     that transports, treats, stores, or disposes of hazardous waste. Here are some
                     important RCRA regulatory requirements:

                     •      Identification of Hazardous Wastes (40 CFR Part 261) lays out the
                           procedure every generator should follow to determine whether the
                           material created is considered a hazardous waste, solid waste, or is
                           exempted from regulation.

                     •      Standards for Generators of Hazardous Waste (40 CFR Part 262)
                           establishes the responsibilities  of  hazardous waste  generators
                           including obtaining  an ID number, preparing a manifest, ensuring
                           proper  packaging and  labeling, meeting  standards  for  waste
                           accumulation units, and record keeping and reporting requirements.
                           Generators can accumulate hazardous waste for up to 90 days (or 180
                           days depending on the amount of waste generated) without obtaining
                           a permit.

                     •      Land Disposal Restrictions (LDRs) are regulations prohibiting the
                           disposal of hazardous waste on land without prior treatment. Under
                           the LDRs (40 CFR  Part 268), materials must meet land disposal
                           restriction (LDR) treatment standards prior to placement in a RCRA
                           land disposal unit (landfill, land treatment unit, waste pile, or surface
                           impoundment).   Wastes  subject to the LDRs include solvents,
                           electroplating wastes, heavy metals, and acids. Generators of waste
                           subject  to the LDRs  must provide notification  of such to the
                           designated TSD facility to ensure proper treatment prior to disposal.

                    •      Used Oil storage and disposal regulations (40 CFR Part 279) do not
                           define Used  Oil  Management Standards impose  management
                           requirements   affecting   the   storage,  transportation,  burning,
                           processing, and re-refining of the used oil. For parties that merely
                           generate used oil, regulations establish storage standards. For a party
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                          considered a  used oil marketer  (one  who  generates and sells
                          off-specification used oil directly to a used oil burner), additional
                          tracking and paperwork requirements must be satisfied.

                    •     Tanks and Containers used to store  hazardous waste with a high
                          volatile organic concentration must meet emission standards under
                          RCRA. Regulations (40 CFR Part 264-265,  Subpart CC) require
                          generators to test the waste to determine the concentration of the
                          waste, to  satisfy tank and container  emissions standards, and to
                          inspect and monitor regulated units. These regulations apply to all
                          facilities who store such waste, including generators operating under
                          the 90-day accumulation rule.

                    •     Underground Storage Tanks (USTs) containing petroleum and
                          CERCLA  hazardous  substance are regulated under Subtitle  I of
                          RCRA. Subtitle I regulations (40 CFR Part 280) contain tank design
                          and release detection requirements, as well as financial responsibility
                          and corrective action standards for USTs. The UST program also
                          establishes increasingly  stringent  standards, including  upgrade
                          requirements for existing tanks, that must be met by 1998.

                    •     Boilers and Industrial  Furnaces (BIFs) that use or burn  fuel
                          containing hazardous waste must comply with strict design and
                          operating standards.  BIF regulations (40 CFR Part 266, Subpart H)
                          address  unit  design, provide performance standards,  require
                          emissions  monitoring, and restrict the type of waste that may be
                          burned.

                    EPA's RCRA/Superfund/UST Hotline, at (800) 424-9346, responds to
                    questions and distributes guidance regarding all RCRA regulations.  The
                    RCRA Hotline operates weekdays from 8:30 a.m. to 7:30 p.m., ET, excluding
                    Federal holidays.

 Comprehensive Environmental Response, Compensation, And Liability Act (CERCLA)

                    CERCLA, a 1980 law commonly known as Superfund, authorizes EPA to
                    respond to releases, or threatened releases, of hazardous substances that may
                    present an imminent and substantial endangerment to public health, welfare,
                    or the environment. CERCLA also enables EPA to force parties responsible
                    for environmental contamination to clean it up  or to reimburse the Superfund
                    for  response costs incurred by EPA.  The Superfund Amendments and
                    Reauthorization Act (SARA) of 1986 revised various sections of CERCLA,
                    extended the taxing authority for the Superfund, and created a free-standing
                    law, SARA Title III, also known as the Emergency Planning and Community
                    Right-to-Know Act (EPCRA).
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                     The CERCLA hazardous substance release reporting regulations (40 CFR
                     Part 302) direct the person in charge of a facility to report to the National
                     Response Center (NRC) any environmental release of a hazardous substance
                     which exceeds a reportable quantity.  Reportable quantities are defined and
                     listed in 40 CFR §302.4.  A release report may trigger a response by EPA or
                     by one or more Federal or State emergency response authorities.

                     EPA implements hazardous substance responses according to procedures
                     outlined in  the  National Oil  and  Hazardous  Substances  Pollution
                     Contingency Plan (NCP) (40 CFR Part 300). The NCP includes provisions
                     for permanent cleanups, known as remedial actions, and other cleanups
                     referred to as "removals." EPA generally takes remedial actions only at sites
                     on the National Priorities List (NPL), which currently includes approximately
                     1,300 sites.  Both EPA and states can act  at other  sites; however, EPA
                     provides responsible parties the opportunity to conduct removal and remedial
                     actions and encourages community involvement throughout the Superfund
                     response process.

                     EPA'sRCRA/Superfiind/USTHotline, at (800) 424-9346, answers questions
                     and references guidance pertaining to the Superfund program. The CERCLA
                     Hotline operates -weekdays from 8:30 a.m. to 7:30 p.m., ET, excluding
                     Federal holidays.

Emergency Planning And Community Right-To-Know Act (EPCRA)

                     The Superfund Amendments and Reauthorization Act (SARA) of 1986
                     created EPCRA, also known as SARA Title HI, a statute designed to improve
                     community access to information about chemical hazards and to facilitate the
                    development of chemical emergency response plans by State and local
                    governments.  EPCRA required the establishment  of State emergency
                    response commissions (SERCs),  responsible for coordinating certain
                    emergency response activities and for  appointing local emergency planning
                    committees (LEPCs).

                    EPCRA and the EPCRA regulations (40 CFR Parts 350-372) establish four
                    types of reporting obligations for facilities which store or manage specified
                    chemicals:

                          EPCRA §302 requires facilities to notify the SERC and LEPC of the
                          presence of any "extremely hazardous substance" (the  list of such
                          substances is in 40 CFR Part 355, Appendices A and B) if it has such
                          substance in excess of the substance's threshold planning quantity,
                          and directs the facility to appoint an emergency response coordinator.
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                           EPCRA §304 requires the facility to notify the SERC and the LEPC
                           in  the event  of a non-exempt release exceeding the reportable
                           quantity of a CERCLA hazardous substance or an EPCRA extremely
                           hazardous substance.

                    •      EPCRA  §311 and §312 require a facility at  which a hazardous
                           chemical, as defined by the Occupational Safety and Health Act, is
                           present in an amount exceeding a specified threshold of chemical use
                           to  submit to the SERC, LEPC and local fire department material
                           safety data sheets (MSDSs) or lists of MSDS's  and hazardous
                           chemical inventory forms (also known as Tier I and II forms). This
                           information helps the local government respond in the event of a spill
                           or release of the chemical.

                    •      EPCRA §313 requires manufacturing facilities included in SIC codes
                           20 through 39, which  have ten or more employees, and which
                           manufacture, process, or use specified chemicals in amounts greater
                           than threshold quantities, to submit an annual toxic chemical release
                           report. This report, commonly known as the Form R, covers releases
                           and  transfers  of toxic  chemicals   to  various  facilities  and
                           environmental media, and allows EPA to compile the national Toxic
                           Release Inventory (TRI) database.

                    All information submitted pursuant to EPCRA regulations is publicly
                    accessible, unless protected by a trade secret claim.

                    EPA's EPCRA Hotline, at (800)  535-0202, answers questions and distributes
                    guidance regarding the emergency planning and community right-to-know
                    regulations.  The EPCRA Hotline operates weekdays from 8:30 a.m. to 7:30
                    p.m., ET, excluding Federal holidays.
 Clean Water Act (CWA)
                    The primary objective of the Federal Water Pollution Control Act, commonly
                    referred to as the CWA, is to restore and maintain the chemical;, physical, and
                    biological integrity of the nation's surface waters. Pollutants regulated under
                    the CWA include "priority" pollutants, including various toxic pollutants;
                    "conventional" pollutants, such as biochemical oxygen demand (BOD), total
                    suspended solids (TSS), fecal coliform, oil and grease, and pH; and "non-
                    conventional" pollutants, including any pollutant not identified as either
                    conventional or priority.

                    The CWA regulates both direct and indirect discharges. The National
                    Pollutant Discharge Elimination System (NPDES) program (CWA §402)
                    controls direct discharges into navigable waters. Direct discharges or "point
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                     source" discharges are from sources such as pipes and sewers.  NPDES
                     permits, issued by either EPA or an authorized State (EPA has presently
                     authorized forty States to administer the NPDES program), contain industry-
                     specific, technology-based and/or water quality-based limits, and establish
                     pollutant monitoring reporting requirements.  A facility that intends to
                     discharge into the nation's waters must obtain a permit prior to initiating a
                     discharge. A permit applicant must provide quantitative analytical data
                     identifying the types of pollutants present in the facility's effluent. The
                     permit will then set forth the conditions and effluent limitations under which
                     a facility may make a discharge.

                     A NPDES permit may also include discharge limits based on Federal or State
                     water quality criteria or standards, that were designed to protect designated
                     uses of surface waters, such as supporting aquatic life or recreation.  These
                     standards, unlike the technological standards, generally do not take into
                     account technological feasibility or costs.   Water quality criteria and
                     standards vary from State to State, and site to site, depending on the use
                     classification of the receiving body of water.  Most States follow EPA
                     guidelines which propose aquatic life and human health criteria for many of
                     the 126 priority pollutants.

                     Storm Water Discharges

                     In 1987 the CWA was amended to require EPA to establish a program to
                     address storm water discharges,  hi response, EPA promulgated the
                     NPDES storm water permit application regulations.  Stormwater discharge
                     associated with industrial activity means the discharge from any conveyance
                     which is used for collecting and conveying stormwater and which is directly
                     related to manufacturing, processing or raw material storage areas  at an
                     industrial plant (40 CFR 122.26(b)(14)).   These regulations require that
                     facilities with the following  storm water discharges apply for an NPDES
                     permit: (1) a discharge associated with industrial activity; (2)  a discharge
                     from a large or medium municipal storm sewer system; or (3) a discharge
                     which EPA or the State  determines to contribute to a violation of a water
                     quality standard or is a significant contributor of pollutants to waters of the
                     United States.

                     The term "storm water discharge associated with industrial activity" means
                     a storm water discharge from one of 11  categories of industrial activity
                     defined at 40 CFR 122.26. Six of the categories are defined by SIC codes
                     while the other five are identified through narrative descriptions of the
                     regulated industrial activity. If the primary SIC code of the facility is one of
                     those identified in the regulations, the facility is subject to the storm water
                     permit application requirements.  If any activity at a facility is covered by
                     one of the five narrative categories,  storm water discharges from those areas
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                     where the activities occur are subject  to  storm water discharge permit
                     application requirements.

                     Those facilities/activities that are subject to storm water discharge permit
                     application requirements are identified  below.  To determine whether a
                     particular facility falls within one of these categories, the regulation should
                     be consulted.

                     Category i:  Facilities subject to storm water effluent guidelines, new source
                     performance standards, or toxic pollutant effluent standards.

                     Category ii:  Facilities classified as SIC 24-lumber and wood products
                     (except wood kitchen cabinets); SIC 26-paper and allied products (except
                     paperboard containers and products);  SIC 28-chemicals and allied products
                     (except drugs and paints); SIC 291-petroleum refining; and SIC 311-leather
                     tanning and  finishing.

                     Category iii: Facilities classified as SIC  10-metal mining; SIC 12-coal
                     mining; SIC 13-oil and gas extraction; and SIC 14-nonmetallic mineral
                     mining.

                     Category iv: Hazardous waste treatment, storage, or disposal facilities.

                     Category v: Landfills, land application  sites, and open dumps that receive
                     or have received industrial wastes.

                     Category vi: Facilities classified as SIC  5015-used motor vehicle parts; and
                     SIC 5093-automotive scrap and waste material recycling facilities.

                     Category vii: Steam electric power generating facilities.

                     Category viii:  Facilities classified as SIC  40-railroad transportation; SIC
                     41-local passenger transportation; SIC 42-trucking and warehousing (except
                     public warehousing and storage); SIC 43-U.S. Postal Service; SIC 44-water
                     transportation; SIC 45-transportation by air; and SIC 5171-petroleum bulk
                     storage stations and terminals.

                     Category ix: Sewage treatment works.

                     Category x:  Construction activities except operations that result in the
                     disturbance  of less than five acres of total land area.

                     Category xi: Facilities classified as SIC  20-food and kindred products; SIC
                     21-tobacco products; SIC 22-textile  mill products; SIC 23-apparel related
                     products; SIC 2434-wood kitchen cabinets manufacturing; SIC 25-furniture
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                     and fixtures; SIC 265-paperboard containers and boxes; SIC 267-converted
                     paper and paperboard products; SIC 27-printing, publishing, and allied
                     industries; SIC 283-drugs; SIC 285-paints, varnishes, lacquer, enamels, and
                     allied products; SIC  30-rubber and  plastics; SIC 31-leather and  leather
                     products (except leather and tanning and finishing); SIC 323-glass products;
                     SIC 34-fabricated metal products (except fabricated structural metal); SIC
                     35-industrial and commercial machinery and computer equipment; SIC 36-
                     electronic and  other  electrical equipment and components;  SIC 37-
                     transportation equipment (except ship  and boat building and repairing); SIC
                     38-measuring, analyzing, and controlling instruments; SIC 39-miscellaneous
                     manufacturing industries; and SIC  4221-4225-public  warehousing and
                     storage.

                     Pretreatment Program

                     Another type of discharge that is regulated by the CWA is one that goes to
                     a publicly-owned treatment  works (POTWs). The national pretreatment
                     program (CWA §307(b)) controls the indirect discharge of pollutants to
                     POTWs by "industrial users." Facilities regulated under §307(b) must meet
                     certain pretreatment standards. The goal of the pretreatment program is to
                     protect municipal wastewater treatment plants from damage that may occur
                     when hazardous, toxic, or other wastes are discharged into a sewer  system
                     and to protect the toxicity characteristics of sludge generated by these plants.
                     Discharges to a POTW are regulated  primarily  by the POTW itself, rather
                     than the State or EPA.

                     EPA has  developed general  pretreatment standards and technology-based
                     standards for industrial users of POTWs in many industrial categories.
                     Different  standards may  apply to existing  and new sources within each
                     category.  "Categorical" pretreatment standards applicable to an industry on
                     a nationwide basis  are developed by EPA.   In addition, another kind  of
                     pretreatment standard, "local limits," are developed by the POTW in order,
                     to assist the POTW hi achieving the effluent limitations in its NPDES permit.

                     Regardless of whether a State is authorized to implement either the NPDES
                     or the pretreatment program, if it develops its own program, it may enforce
                     requirements more stringent than Federal standards.

                     EPA's Office of Water, at (202) 260-5700, will direct callers with questions
                     about the CWA to  the appropriate EPA office.  EPA  also maintains a
                     bibliographic  database of Office of Water publications which can be
                     accessed through the Ground Water and Drinking Water resource center,  at
                     (202) 260-7786.
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Safe Drinking Water Act (SDWA)
                    The SDWA mandates that EPA establish regulations to protect human health
                    from contaminants in drinking water. The law authorizes EPA to develop
                    national drinking water standards and to create a joint Federal-State system
                    to ensure compliance with these standards. The SDWA also directs EPA to
                    protect underground sources of drinking water through the control of
                    underground injection of liquid wastes.

                    EPA has developed primary and secondary drinking water standards under
                    its SDWA authority.   EPA and  authorized States enforce  the primary
                    drinking water standards, which are, contaminant-specific concentration
                    limits that apply to certain public drinking water supplies. Primary drinking
                    water standards consist of maximum contaminant level  goals (MCLGs),
                    which are non-enforceable health-based goals, and maximum  contaminant
                    levels  (MCLs), which are enforceable limits set as close to MCLGs as
                    possible, considering cost and feasibility of attainment.

                    The SDWA Underground Injection Control (UIC) program (40 CFR Parts
                    144-148) is a permit  program which  protects  underground sources of
                    drinking water by regulating five classes of injection wells.   UIC permits
                    include design, operating, inspection, and monitoring requirements. Wells
                    used to inject  hazardous wastes must also comply with RCRA corrective
                    action standards in order to be granted  a RCRA  permit, and must meet
                    applicable RCRA land disposal restrictions standards.   The  UIC permit
                    program is primarily State-enforced, since EPA has  authorized  all but a few
                    States to administer the program.

                    The SDWA also provides for a Federally-implemented Sole Source Aquifer
                    program, which prohibits Federal funds from being expended on projects that
                    may contaminate the sole or principal source of drinking water for a given
                    area, and for a State-implemented Wellhead Protection program, designed to
                    protect drinking water wells and drinking water recharge areas.

                    EPA's Safe Drinking Water Hotline, at (800) 426-4791, answers questions
                    and distributes guidance pertaining to  SDWA  standards.   The Hotline
                    operates from 9:00 a.m. through 5:30 p.m., ET, excluding Federal holidays.
Toxic Substances Control Act (TSCA)
                    TSCA granted EPA authority to create a regulatory framework to collect data
                    on chemicals in order to evaluate, assess, mitigate, and control risks which
                    may be posed by their manufacture, processing, and use. TSCA provides a
                    variety of control methods to prevent chemicals from posing unreasonable
                    risk.
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                     TSCA standards may apply at any point during a chemical's life cycle.
                     Under TSCA §5, EPA has established an inventory of chemical substances.
                     If a chemical is not already on the inventory, and has not been excluded by
                     TSCA, a premanufacture notice (PMN) must be submitted to EPA prior to
                     manufacture or import. The PMN must identify the chemical and provide
                     available information on health and environmental effects. If available data
                     are not sufficient to evaluate the chemicals effects,  EPA can impose
                     restrictions pending  the development of Information  on  its health and
                     environmental  effects.  EPA can also restrict significant new uses  of
                     chemicals based upon factors such as the projected volume and use of the
                     chemical.

                     Under TSCA §6, EPA can ban the manufacture or distribution in commerce,
                     limit the use, require labeling, or place other restrictions on chemicals that
                     pose unreasonable risks.  Among  the chemicals EPA regulates under §6
                     authority are asbestos, chlorofluorocarbons (CFCs),  and polychlorinated
                     biphenyls (PCBs).

                     EPA's TSCA Assistance Information Service, at (202) 554-1404, answers
                     questions and distributes guidance pertaining to Toxic Substances Control
                     Act standards. The Service operates from 8:30 a.m. through 4:30 p.m., ET,
                     excluding Federal holidays.
Clean Air Act (CAA)
                    The CAA and its amendments, including the Clean Air Act Amendments
                    (CAAA) of 1990,  are designed to "protect and enhance the nation's air
                    resources so as to promote the public health and welfare and the productive
                    capacity of the population."  The CAA consists of six sections, known as
                    Titles, which direct EPA to establish national  standards for ambient air
                    quality and for EPA and the States to implement, maintain, and enforce these
                    standards  through  a variety of mechanisms.   Under the CAAA, many
                    facilities will be required to obtain permits for the first time.  State and local
                    governments oversee, manage, and enforce many of the requirements of the
                    CAAA. CAA regulations appear at 40 CFR Parts 50-99.

                    Pursuant to Title I  of the CAA, EPA has established national ambient air
                    quality standards (NAAQSs) to limit levels of "criteria pollutants," including
                    carbon monoxide,  lead,  nitrogen dioxide, particulate matter, ozone, and
                    sulfur dioxide. Geographic areas that meet NAAQSs for a given pollutant
                    are classified as  attainment areas; those that do not meet NAAQSs are
                    classified as non-attainment areas. Under §110 of the CAA, each State must
                    develop a State Implementation Plan (SIP) to identify sources of air pollution
                    and to  determine what reductions are required to meet Federal air quality
                    standards.
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                    Title I also authorizes EPA to establish New Source Performance Standards
                    (NSPSs), which are nationally uniform emission standards for new stationary
                    sources falling within particular industrial categories. NSPSs are based on
                    the pollution control technology available to that category of industrial
                    source  but  allow  the  affected industries  the  flexibility to  devise  a
                    cost-effective means of reducing emissions.

                    Under Title I, EPA establishes and enforces National Emission Standards for
                    Hazardous Air Pollutants (NESHAPs), nationally uniform standards oriented
                    towards controlling particular hazardous air pollutants (HAPs). Title III of
                    the CAAA further directed EPA to develop a list of sources that emit any of
                    189 HAPs, and to develop regulations for these categories of sources. To
                    date EPA has  listed 174 categories  and developed a schedule for the
                    establishment of emission standards.  The emission standards are being
                    developed for both new and existing sources based on "maximum achievable
                    control technology (MACT)."  The MACT  is defined as the control
                    technology achieving the maximum degree of reduction in the emission of
                    the HAPs, taking into account cost and other factors.

                    Title II of the CAA pertains to mobile sources, such as cars, trucks, buses,
                    and planes.  Reformulated gasoline, automobile pollution control devices,
                    and vapor recovery nozzles on gas pumps are a few of the mechanisms EPA
                    uses to regulate mobile air emission sources.

                    Title IV establishes a sulfur dioxide emissions program designed to reduce
                    the formation of acid rain.  Reduction of sulfur dioxide  releases will be
                    obtained by granting to certain sources limited emissions allowances, which,
                    beginning in 1995, will be set below previous  levels of sulfur dioxide
                    releases.

                    Title V of the CAAA of 1990  created an  operating permit program for all
                    "major sources" (and certain other sources) regulated under the CAA. One
                    purpose of the operating permit is  to include in a single document all air
                    emissions requirements that apply to a given facility. States are developing
                    the permit programs in accordance with guidance and regulations from EPA.
                    Once a State program is approved by EPA, permits will be issued and
                    monitored by that State.

                    Title VI is  intended to protect stratospheric ozone  by phasing out the
                    manufacture of ozone-depleting chemicals and restricting their use and
                    distribution.  Production of Class I  substances, including 15 kinds of
                    chlorofluorocarbons (CFCs), will be phased out entirely by the year 2000,
                    while certain hydrochlorofluorocarbons (HCFCs) will be phased out by
                    2030.
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                     EPA's Control Technology Center, at (919) 541-0800, provides general
                     assistance and information on CAA standards.  The Stratospheric Ozone
                     Information Hotline, at (800) 296-1996, provides general information about
                     regulations promulgated under Title  VI of the CAA, and EPA's EPCRA
                     Hotline, at (800) 535-0202, answers questions about accidental release
                    prevention under  CAA  §112(r).  In  addition, the Technology Transfer
                     Network Bulletin Board System (modem access (919) 541-5742)) includes
                     recent CAA rules, EPA guidance documents, and updates of EPA activities.

 VI.B. Industry Specific Requirements

                     The petroleum  refining industry is  unique  in that the environmental
                     requirements aimed at the industry are of two basic types: (1) requirements
                     mandating specific product qualities  for the purpose of reducing the
                     environmental impacts associated with the downstream use of the product;
                     and (2) requirements directed at reducing the environmental impacts of the
                     refineries themselves. Presently, some of the most significant environmental
                     statutes affecting refineries economically are geared toward altering the
                     product formulation with the aim of reducing pollutant releases from use of
                     the finished products (primarily fuels). Since 1970, various product quality
                     regulations have been  promulgated  affecting specific formulations of
                     gasoline and other fuels.  These formulations  often require  significant
                    process  changes  and  capital  investments at  petroleum  refineries.
                     Environmental requirements aimed at reducing the pollution outputs from
                    refinery operations themselves  also require significant investments to
                     change the processes  and equipment.   These requirements aimed at
                    reformulating  refinery products and  reducing emissions from  refinery
                    operations make petroleum refining one of the most heavily regulated
                    industries.

 Clean Air Act of 1970 (CAA)

                    Of the various environmental statutes affecting the industry, the CAA of
                     1970 and the CAAA of 1990 have had, and will continue to have, the most
                    significant impact on the petroleum refining industry.

                    The 1970 CAA authorized EPA to establish, in 1971, the National Ambient
                    Air Quality Standards (NAAQS) which set standards for sulfur dioxide,
                    nitrous oxides, carbon monoxide, ozone, non-methane hydrocarbons, opacity
                    and total suspended particulates in the ambient air. The Act also established
                    a schedule for the reduction and eventual elimination of lead in gasoline. In
                    1978, a national ambient air standard for lead was established.   More
                    complex refining techniques  such as incorporating more  downstream
                    conversion units,  catalytic processes,  octane boosting  additives, and
                    lubricating additives, were developed to make up for the properties lost as a
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                    result of reducing lead anti-knock additives. Another provision of the Act
      •••••'         limited the sulfur content in residual and distillate fuel oils used by electric
                    utilities and industrial plants.  To meet the demand for low-sulfur fuels,
                    desulfurization processing units were developed.80

Clean Air Act Amendments of 1990 (CAAA)

                    Despite a major reduction in automobile emissions  after the 1970 CAA,
                    many areas of the U.S. were not in  compliance with the NAAQS.  These
                    areas, termed "nonattainment areas," became an  important subject of the
                    1990 amendments to the 1970 CAA.  The CAAA of 1990 provide much
                    more stringent requirements than the original CAA.  The Act is organized
                    into nine titles: Urban Air Quality, Mobile Sources,  Toxic Air Pollutants,
                    Acid Rain Control, Permits, Stratospheric Ozone  Depletion, Enforcement,
                    General Provisions, and Research.  The major requirements altering product
                    formulations to reduce emissions from mobile sources are contained in four
                    programs:  the Oxygenated Fuels  Program,  the Highway Diesel Fuel
                    Program, the Reformulated Fuels  Program,  and the Leaded Gasoline
                    Removal Program.  Additional programs aimed at reducing air emissions
                    from the refineries themselves and which have significant impacts on
                    refineries include: New Source Review (NSR), New Source Performance
                    Standards (NSPS), and National  Emission Standards for Hazardous  Air
                    Pollutants (NESHAP).81

                    Oxygenated Fuels Program

                    The Oxygenated  Fuels Program required  that  by  November 1992, all
                    gasoline sold in the 39 carbon monoxide nonattainment areas must have a
                    minimum of 2.7 percent oxygen (by weight) for at  least four winter months.
                    The higher oxygen content lowers the levels of carbon monoxide produced
                    during combustion. In California's carbon monoxide nonattainment areas,
                    the winter  fuel oxygen content is set at 1.8 to 2.2  percent because it is
                    expected that higher oxygen levels increase nitrogen oxide emissions to
                    unacceptable levels (for which the area is also in nonattainment).

                    In response to the program, the domestic capacity to produce oxygenates for
                    oxygenated fuels has increased 59 percent from 1991 to 1993. This required
                    significant investments in oxygenate production facilities at both refineries
                    and at nonrefinery stand-alone facilities that produce ethanol  from grain,
                    methyl tertiary butyl ether (MTBE) from  oil field butane streams,  and
                    methanol from natural gas.82 The mandatory use of ethanol as an oxygenate,
                    however, was overturned by a court in May of 1995.
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                     Highway Diesel Fuel Program

                     The Highway Diesel Fuel Program required that the sulfur content of all
                     highway diesel fuel be reduced from 0.5 percent to 0.05 percent (by weight)
                     by October 1, 1993.  Small refineries (below 18,250 thousand barrels of
                     crude oil throughput per year) were given the option of using tradeable
                     credits on sulfur reduction as a means of compliance until December 31,
                     1999. The program also requires that the cetane index, which measures the
                     self-ignition quality of diesel fuel, must be maintained at a minimum of 40.

                     Increased construction of desulfurization downstream units, such as catalytic
                     hydrocracking and hydrotreating units is underway to comply with these new
                     requirements. Small refineries not wanting to invest in new downstream
                     units may have the  option of producing  only distillate fuel oil for non-
                     highway use.  Diesel  fuel and distillate fuel oils can be interchanged;
                     however, as of October 1,1993, distillate fuel oil and diesel fuel with high
                     sulfur content were marked with a dye to prevent sale for highway  use.
                     Industry estimates a capital cost of $3.3 billion to comply with the Highway
                     Diesel Fuel Program.83

                     Reformulated Fuels Program

                     The  Reformulated Fuels Program,  or Reformulated Gasoline (RFG)
                     Program, requires the use of reformulated gasoline by January 1, 1995 in
                     nine U.S. metropolitan areas (more than 250,000 people) with the worst
                     ground level ozone problems. Other nonattainment areas can "opt in" to the
                     program as a way of reducing ozone  levels.  EPA can delay a request to  opt-
                     in for up to three years if the supply of reformulated gasoline is not large
                     enough. Such reformulated gasoline must have a minimum oxygen content
                     of two percent by weight, a maximum benzene content of one  percent by
                     volume, and no lead or manganese.  In addition, the year round average of
                     nitrogen oxide emissions may not exceed that of a 1990 summertime baseline
                     gasoline; the 1990 baseline tailpipe emissions of volatile organic compounds
                     and toxic air pollutants (TAPs) must be reduced by 15 percent; and benzene
                     must be below 1 percent.   By  1998,  a new "complex"  formula for
                     reformulated gasoline will replace the original "simple" formula. By 2000,
                     TAPs emissions are to  be reduced by at least 20 percent, VOC emissions
                     reduced by at least 25  percent, and NOX emissions reduced by at least 5
                     percent in the summertime.84

                     Of the four highway fuels programs, complying  with the reformulated
                     gasoline rules will require the largest process changes. Gasoline formulation
                     will need to be upgraded to reduce the aromatic and VOC emissions from
                    motor vehicles. The catalytic reforming process is expected to be used less,
                    thereby lowering the levels of benzene and  other aromatics  produced.
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                    Hydrotreating units will be utilized more in order to meet the lower sulfur
                    specifications.  It is uncertain how many nonattainment areas will eventually
                    opt-in to the program, which could have a significant effect on the capacity
                    needs for the various downstream processes. As of June 1995,18 areas have
                    opted-in.

                    Leaded Gasoline Removal Program

                    The fourth program to limit emissions from mobile sources prohibits the sale
                    of leaded gasoline for use in motor vehicles after 1995. The CAA 1970 has
                    already reduced lead content substantially and the elimination of leaded gas
                    is not expected to  create significant changes in the industry.85

                    Reid Vapor Pressure Regulations of 1989 and 1992

                    The Reid Vapor Pressure (RVP) regulations were implemented by the EPA
                    to reduce emissions of VOCs and other ozone precursors.  The regulations
                    set  standards for the volatility of summertime motor gasoline in some U.S.
                    urban areas.  The program was implemented in two  phases with the first
                    beginning in the spring of 1989 and the second in 1992. The Phase I summer
                    volatility standards limited the average Reid Vappr Pressure (a measure of
                    the volatility of motor gasoline) to a maximum of 10.5 psi  and 9.0 psi in
                    certain areas of the country. The Phase II summer volatility standards set a
                    nationwide maximum RVP of 9.0 psi and, in some ozone nonattainment
                    cities in the south, the standard was set at 7.8 psi. Phase n will stay in effect
                    through the summer of 1994 in the nine  RFG areas. In 1995,  the VOC
                    standards of the 1990 CAAA Reformulated Gasoline Program will take the
                    place of the RVP regulations.

                    The Phase I standards were met by reducing the amount of butane blended
                    into gasoline. In addition to having a high RVP, butane is also high octane.
                    To  compensate for the resulting loss in  octane and volume  both crude oil
                    inputs and the use of catalytic cracking and alkylation units have increased.
                    The Phase II standards were met by increasing downstream processing and
                    the blending with high-octane, lower RVP components. To  meet the RVP
                    regulations, large capital investments were made in facilities to produce these
                    blending components.86

                    New Source Review and New Source Performance Standards

                    The 1990 CAA New Source Review (NSR) requirements apply  to new
                    facilities, expansions of existing facilities, or process modifications.  New
                    sources of the NAAQS "criteria" pollutants in excess of "major" levels
                    defined  by   EPA  are  subject  to  NSR  requirements  (40  CFR
                    §52.21(b)(l)(i)(a)-(b)). NSRs are typically conducted by the state agency
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                    under standards set by EPA and adopted by the state as part of its state
                    implementation plan (SIP).  There are two types of NSRs: Prevention of
                    Significant Deterioration (PSD) reviews for those areas that are meeting the
                    NAAQS; and nonattainment (NA) reviews for areas that are violating the
                    NAAQS.  Permits are required to construct or operate the new source for
                    PSD and NA areas.  For NA areas, permits require the new source to meet
                    lowest achievable emission rate (LAER) standards and the operator of the
                    new source must procure reductions in emissions of the same pollutants from
                    other sources in the NA area in equal or greater amounts to the new source.
                    These "emission offsets" may be banked and traded through state agencies.
                    For PSD  areas, permits  require the best available control technology
                    (BACT), and the operator  or owner of the  new  source must conduct
                    continuous on-site ah* quality monitoring for one year prior to the new source
                    addition to determine the effects that the new emissions may have  on air
                    quality.  EPA  sets  the minimum standards for LAER and BACT for
                    petroleum refinery NSRs in its new source performance standards (NSPS),
                    40CFRPart60:
                    Subpart J
Standards of Performance for Petroleum Refineries
                    Subpart K,K,K    Standards of Performance for Volatile Organic Liquid
                                     Storage Vessels

                    Subpart GG      Standards of Performance for Stationary Gas Turbines

                    Subpart GGG     Standards of Performance for Equipment Leaks of VOC
                                     in Petroleum Refineries
                    Subpart NNN
                    Subpart QQQ
Standards of Performance for VOC  Emissions  from
SOCMI  Distillation Operations  (manufacturing  of
organic chemicals e.g., MTBE)

Standards of Performance for VOC  Emissions  from
Petroleum Wastewater Systems87'88
                    National Emission Standards for Hazardous Air Pollutants (NESHAP1

                    Under Title IE of the 1990 CAAA, EPA is required to develop national
                    emission standards for 189 hazardous air pollutants (NESHAP) including
                    benzene and approximately 20  other chemicals typically emitted at
                    petroleum refineries.  The development of the NESHAP regulations are
                    taking place in two phases. In the first phase, EPA is developing maximum
                    achievable control technology (MACT) standards for all new and existing
                    sources (James Durham, U.S. EPA, Office of Air, (919) 541-5672). EPA can
                    give a six year extension of NESHAP requirements in exchange for an
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                    enforceable commitment to an early reduction of emissions by 90 percent.
                    At the time this document went to print EPA  estimated that the MACT
                    standards for petroleum refineries  would be finalized by the end of July
                    1995. The second phase of the NESHAP regulations is to be implemented in
                    2000 and requires assessing whether or not remaining risk after the MACT
                    standards have been implemented is acceptable.89 For petroleum refineries,
                    the following NESHAPs apply, 40 CFR Part 61:

                    SubpartJ     National Emission  Standards for Equipment Leaks  of
                                 Benzene

                    Subpart M    National Emission Standards for Asbestos (Demolition and
                                 Renovation)

                    Subpart V    National Emission Standards for Equipment Leaks (Fugitive
                                 Emission Sources)

                    Subpart Y    National Emission Standards for Benzene Emissions from
                                 Benzene Storage Tanks

                    Subpart BB   National' Emission Standards for Benzene Emissions from
                                 Benzene Transfer Operations

                    Subpart FF   National Emission Standards for  Benzene Waste Operations

                    In addition, Subpart E (National Emission Standards for Mercury) will apply
                    if the refinery has a wastewater treatment plant sludge incinerator.90

 Resource Conservation and Recovery Act (RCRA)

                    RCRA gives EPA the authority to establish a list of solid and hazardous
                    wastes, and to establish standards and regulations for handling and disposing
                    of these wastes.  Although the costs of complying with RCRA requirements
                    may not be as great as that of the 1990 CAAA, there are significant  capital
                    and operational costs as well as administrative  costs related  to permitting,
                    technical studies and analytical requirements.

                    The majority of solid wastes generated at refineries  are non-hazardous
                    residuals. Most of these wastes are typically recycled within the refinery or
                    are landfilled or incinerated onsite as non-hazardous wastes. Some of these
                    wastes are sent off-site for treatment, land disposal or land treatment (land
                    farming). A number of wastes commonly generated at refineries, however,
                    are hazardous under  RCRA.  The largest number of different  RCRA
                    hazardous  wastes  are generated  during wastewater  treatment prior to
                    discharge.  These could include:  API separator sludge (K051); slop oil
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                     emulsion solids (K049); other primary oil-water separator sludge, barscreen
                     debris (F037); characteristic wastes containing chromium (D007) or lead
                     (D008); dissolved air flotation floats (K048); and all other sludge, floats and
                     used filter bags (F038). Other potential refinery wastes regulated under
                     RCRA include those generated from cleaning of heat exchanger bundles
                     (K050), desalter mud (F037), laboratory wastes (F003, F005, D001, etc.),
                     spent alkylation sulfuric acid (D002; except when used to produce virgin
                     sulfuric acid, 40 CFR §261.4(a)(7)) and leaded tank bottom corrosion solids
                     (K052), waste paint materials (D001), and wastes containing  benzene
                     (D018).91  Spent process catalysts are occasionally RCRA characteristic
                     hazardous wastes for reactivity due to benzene (DO 18) or for toxiciry due to
                     sulfur on the catalyst surface (D003).92

                     Some of the handling and treating requirements for RCRA hazardous wastes
                     generators are covered under 40 CFR Part 262 and involve: determining
                     what constitutes a RCRA hazardous waste (Subpart A); manifesting (Subpart
                     B); packaging, labeling and accumulation time limits (Subpart C); and record
                     keeping and reporting (Subpart D).93

                     Many refineries store some hazardous wastes at the facility for more than 90
                     days and, therefore, are a storage facility under  RCRA  and must have a
                     RCRA treatment, storage and  disposal facility (TSDF) permit (40 CFR
                     §262.34). Some of the specific requirements that may apply to refineries that
                     are  TSD  facilities are  covered under 40  CFR Part  264,  and  include:
                     contingency plans and emergency procedures (40 CFR Part 264 Subpart D);
                     manifesting, record keeping and reporting (Subpart E); use and management
                     of containers (Subpart I); tank systems (Subpart J); surface impoundments
                     (Subpart K); land treatment (Subpart M); incinerators (Subpart O), although
                     few refineries incinerate hazardous wastes onsite; corrective action of
                     hazardous waste releases (Subpart S); air emissions standards for process
                     vents of processes that process or generate hazardous wastes (Subpart AA);
                     emissions  standards for leaks  in hazardous waste handling  equipment
                     (Subpart BB); and emissions standards for containers, tanks, and surface
                     impoundments that contain hazardous wastes (Subpart CC).

                     The 1984 Hazardous and Solid Waste Amendments (HSWA)  to  RCRA
                     require that any area at a facility where solid wastes have been routinely and
                     systematically released  at a treatment, storage,  or disposal facility  are
                     required to carry out "corrective actions." Corrective action requirements are
                     decided by EPA or the states on a facility-by-facility basis and can extend to
                     remediation beyond the facility boundary.  Since most refineries  have filed
                     for RCRA permits and because it is common for refineries to have released
                     wastes to the environment, it is expected that most refineries will eventually
                     undergo a RCRA corrective action.  The costs of remediating contamination
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                    that has occurred over the life of a refinery could potentially be one of the
                    most costly items facing a facility.94

                    A number of RCRA wastes have been prohibited from land disposal unless
                    treated to meet specific standards under the RCRA Land Disposal Restriction
                    (LDR) program.  The wastes covered by the RCRA LDRs are listed in 40
                    CFR Part  268,  Subpart C and Include  a number of wastes commonly
                    generated at petroleum refineries. Restrictions on common refinery wastes
                    include toxicity characteristic wastes, which include those containing greater
                    than 0.5 ppm benzene (D018) and sludges from refinery process wastewater
                    treatment systems (F037). Restrictions on D018 wastes are expected to
                    further reduce the amount of refinery wastes that are treated by landfarming
                    off-site which has already been reduced significantly in recent years for both
                    hazardous and non-hazardous wastes.95 To meet the LDRs, these wastes are
                    typically treated through incineration.  In addition to the land disposal
                    restrictions, standards for the treatment and storage of restricted wastes are
                    also described hi Subparts D and E, respectively.96
Clean Water Act (CWA)
                     Petroleum refinery wastewater released to surface waters is regulated under
                     the  CWA.  National Pollutant Discharge Elimination System (NPDES)
                     permits must be obtained to discharge wastewater into navigable waters (40
                     Part 122). Effluent limitation guidelines for wastewater discharged from
                     petroleum refineries were promulgated in 1985 and are currently being
                     reviewed for updating in 1995 (Ronald Kirby, U.S. EPA Office of Water,
                     (202)-260-7168). The effluent guidelines for the Petroleum Refining Point
                     Source Category are listed under 40 CFR Part 419  and are divided into
                     subparts according to the processes used by the refinery:

                     Subpart A    Applies to facilities using topping (distillation) and catalytic
                                  reforming

                     Subpart B    Applies to facilities using topping and cracking

                     Subpart C    Applies to  facilities  using  topping,  cracking  and
                                  petrochemical operations

                     Subpart D    Applies to facilities using topping, cracking and lube oil
                                  manufacturing

                     Subpart E    Applies to  facilities that use topping, cracking, lube oil
                                  manufacturing and petrochemical operations.
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                      In addition to the effluent guidelines, facilities that discharge to a POTW
                      may  be required to meet National  Pretreatment  Standards  for  some
                      contaminants.  General pretreatment standards applying to most industries
                      discharging to a POTW are described in 40 CFR Part 403.  Pretreatment
                      standards applying specifically to the Petroleum Refining Category are listed
                      in the subparts of 40 CFR Part 419 (as shown above).97

                      The term "storm water discharge associated with industrial activity" means
                      a storm water discharge from one of 11 categories of industrial activity
                      defined at 40 CFR 122.26.If the primary SIC code of the facility is one of
                      those identified hi the regulations, the facility is subject to the storm water
                      permit application requirements.  If any activity at a facility is covered by
                      one of the five narrative categories, storm water  discharges from those areas
                      where the  activities occur are subject to  storm  water discharge permit
                      application requirements.

                      Those facilities/activities that are subject to storm water discharge permit
                      application requirements are identified below. To determine whether  a
                      particular facility falls within one of these categories, the regulation should
                      be consulted.

                      Category i: Facilities subject to storm water effluent guidelines, new source
                     performance standards, or toxic pollutant effluent standards.

                      Category ii:  Facilities classified as SIC 24-lumber and wood products
                     (except wood kitchen cabinets); SIC  26-paper  and allied products (except
                     paperboard containers and products);  SIC 28-chemicals and allied products
                     (except drugs and paints); SIC 291-petroleum refining; and SIC 311-leather
                     tanning and finishing.

                     The recent storm water rules  require certain facilities with storm water
                     discharge from any one of 11 categories of industrial activity defined at 40
                     CFR 122.26 be subject to the storm water permit application requirements
                     (see Section VIA). Petroleum refineries are covered in Category ii by virtue
                     of SIC code. The Storm Water Rule (40 CFR §122.26(b)(14) subparts (i, ii))
                     requires the capture and treatment of stormwater at all facilities falling under
                     SIC code 291, including petroleum refineries. Required treatment of storm
                     water flows are expected to remove a large fraction of both conventional
                     pollutants, such as suspended solids and biological oxygen demand (BOD),
                     as well as toxic pollutants, such as certain metals and organic compounds.98

Safe Drinking Water Act (SDWA)

                     Those refineries that dispose of wastewater in underground injection wells
                     are subject to the underground injection control (UIC) program of the Safe
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                    Drinking Water Act. The UIC program is aimed at protecting usable aquifers
                    from contaminants migrating from injection wells. The program requires a
                    permit for the placement of fluids into a well.  Injection wells are also subject
                    to substantive standards and criteria that may require a study of the potential
                    of the well to contaminate the groundwater (40 CFR Parts 143-147). An
                    injection well is classified in one of five categories (Class I-V) which reflect
                    the relative risk of contaminating usable aquifers based on the proximity to
                    drinking water supplies and the hydrogeological conditions in the area.
                    Regulations vary for each well class.  The UIC program is closely related to
                    the RCRA program. Injection wells into which hazardous waste is injected
                    constitute a land disposal facility under RCRA and, therefore, also require
                    a RCRA permit. Under the RCRA regulations, injection wells with permits
                    under  the  UIC  program  and  which  meet certain additional  RCRA
                    requirements, are considered to have a RCRA permit (40 CFR  §270.60(b)).99

Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)

                    Petroleum and crude oil are specifically exempt from  listing in CERCLA.
                    Wastes generated during the refining process and refined petroleum products
                    containing CERCLA hazardous substances above specific levels are covered
                    under CERCLA. Therefore, past releases of hazardous substances from a
                    refinery are likely to require remedial clean-up actions under Superfund.100

Emergency Planning and Community Right-to-Know Act (EPCRA)

                    Refineries are also covered by the reporting requirements of the Emergency
                    Planning and Community Right-to-Know Act (EPCRA).  The Community
                    Right-to-Know provisions require that facilities with ten or more employees
                    that manufactured, processed, or otherwise used a listed toxic chemical in
                    excess of the "established threshold" must annually file a Toxic Chemical
                    Release form with EPA and the state (EPCRA §313; 40 CFR Part 372).
                    Facilities must submit material safety data sheets or the equivalent and Tier
                    I/Tier II annual inventory report forms to the appropriate local emergency
                    planning commission and emergency response and fire departments (EPCRA
                    §§ 311-312; 40 CFR Part 370). Those handling "extremely hazardous
                    substances"  are also required  to submit a one-time notice to the state
                    emergency response commission (EPCRA §302(A); 40 CFR Part 355).
                    Unintentional releases of a reportable quantity of a CERCLA hazardous
                    substance or an extremely hazardous substance must be reported to the state
                    emergency  planning  commission  and  the  local emergency planning
                    commission (40 CFR Part 304).101 Petroleum refineries are likely to use or
                    produce a number of the chemicals listed, including ammonia, chlorine,
                    hydrogen sulfide, methyl mercaptan,  sulfur dioxide and sulfuric acid.

 1990 Oil Pollution Act and Spill Prevention Control and Countermeasure Plans
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                     The 1990 Oil Pollution Act establishes strict, joint and several liability
                     against onshore and offshore facilities that discharge oil or pose a substantial
                     threat of discharging oil to navigable waterways.  The act requires that
                     facilities posing a substantial threat of harm to the environment prepare and
                     implement more rigorous Spill Prevention Control and Countermeasure Plan
                     required under the CWA (40 CFR § 112.7). Standards have been set for tank
                     equipment, spill prevention control plans, and vessels.   An important
                     requirement affecting refining facilities is oil response plans  for above
                     ground storage tank facilities. There are also criminal and civil penalties for
                     deliberate or negligent spills of oil.  Regulations covering response to oil
                     discharges and contingency plans (40 CFR Part 300), and facility response
                     plans to oil discharges (40 CFR Part 112) are being revised and finalized in
                     1995.102

 OSHA Health Standards and Process Safety Management Rules

                     The Occupational Safety and Health Administration (OSHA) limits benzene
                     exposure in the workplace at petroleum refineries (29 CFR §1910.1028).
                     Benzene is a common emission of petroleum refining operations.  Control
                     strategies  may  involve  substantial process  changes  and  equipment
                     modifications. OSHA has also developed safety management rules requiring
                     refineries  to conduct a detailed review of all operational processes  to
                     determine workplace risk and  injury potential to workers  and to define
                     courses  of action in  the case of emergencies (29 CFR §1910). Industry
                     reports that this  regulation may prove to be relatively  costly due to the
                     numerous and complex process units at petroleum refineries.103
State Statutes
                     Some of the most important state regulations affecting the petroleum refining
                     industry are those of the California Air Resource Board (CARB).  The
                     CARB Phase n regulations for reformulated gasoline sold in California are
                     more stringent than the federal CAAA.  The South Coast Air Quality
                     Management District (SCAQMD) in southern California has an Air Quality
                     Maintenance Plan which aims to reduce emissions of sulfur oxides, nitrogen
                     oxides, particulates and VOCs from stationary sources.  For refineries, one
                     of the most important requirements will be an 8  percent reduction in
                     emissions  of  NOX  by  1996.104   Refineries must  also carry  out  a
                     comprehensive leak identification, maintenance, and inspection program.
                     VOC emissions from sumps, wastewater systems and sewers are also limited,
                     and any emission increases must be offset by emission decreases within the
                     facility. Certain refineries must conduct analyses for carcinogenic risks to
                     neighboring populations, and new units or facility  modifications cannot
                     exceed specified limits for increased specified cancer risk to individuals in
                     the  surrounding  community.   Industry  representatives reported  that
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                    substantial emission controls and changes in facility operations would be
                    needed to meet the SCAQMD requirements.105

                    Refineries are also affected by some state statutes that designate waste oils
                    as hazardous waste.  In some states, such as California, any oily waste or
                    waste  oil generated  in a refinery process must  be handled as a RCRA
                    hazardous waste.

VI.C. Pending and Proposed Regulatory Requirements

Energy Policy Act of 1992

                    The Energy Policy Act of 1992 provided for a number of programs aimed at
                    reducing the U.S. dependence on foreign oil through increased domestic oil
                    production, the use of alternative fuels, and  increases in energy efficiency.
                    Some programs established by the Energy Policy Act may have significant
                    effects on the petroleum refining industry in the long term.

                    The Energy Policy  Act mandates  the phase-in of  alternative  fuels in
                    government and private automobile and truck fleets.  A national  goal for
                    2010 has been set for 30 percent of the light-duty vehicle market to be
                    powered by natural gas, electricity, methanol, ethanol, or coal-derived liquid
                    fuels.  The Act  also requires that efficiency standards be set for all new
                    federal  buildings,  buildings with federally backed  mortgages,   and
                    commercial and industrial equipment. Research and development programs
                    are being sponsored for high-efficiency engines and superconducting electric
                    power systems.  The effects of these programs will ultimately reduce the
                    growth rate of demand for refined petroleum products in the U.S.106
Clean Water Act (CWA)
                    Effluent limitations guidelines for wastewater discharge from petroleum
                    refineries are currently being reviewed by the Office of Water for possible
                    updating in 1995 (Ronald Kirby, U.S. EPA Office of Water, (202)-260-
                    7168).  Specifically, the Office of Water is evaluating the need to reduce
                    selenium releases which, in the past, have exceeded water quality standards.
                    Selenium releases are usually only found in facilities processing California
                    crude oil. Effluent guidelines for selenium will, therefore, probably only
                    affect these facilities.107
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Clean Air Act Amendments 1990 (CAAA)
                    Most of the programs of the CAAA are being phased-in over a period often
                    years between 1990 and 2000.  Some of the requirements of the CAAA have
                    not yet been set and, as mentioned above, there is a great deal of uncertainty
                    as to the effects that these unspecified standards will have on the industry.
                    The Reformulated Gasoline Program and the NESHAP standards may have
                    the most  significant future requirements  on  the industry.   Under  the
                    Reformulated Gasoline Program, a "complex" formula  for reformulated
                    gasoline is scheduled  to go into effect in  1998.  The standards for this
                    formula were not yet finalized as of June 1995. It is not known how many
                    other nonattainment areas will eventually "opt in," thereby creating more
                    demand for reformulated gasoline. Several nonattainment areas have already
                    sought to "opt out" of the program.108

                    The NESHAP standards are scheduled to be promulgated by EPA by late
                    July 1995  (James Durham, U.S. EPA, Office of Air, (919) 541-5672). The
                    standards required will be in the form of MACT standards.  The NESHAP
                    standards will likely be similar to those developed for the chemical industry
                    and will cover air emissions from many refinery processes including, but not
                    limited to, most catalytic processes,  industrial boilers,  process heaters,
                    storage tanks and equipment, process  vents,  and wastewater treatment
                    facilities.  The standards for the control of benzene emissions will require
                    significant capital investments.109

                    Under Title V of the CAAA 1990 (40 CFR Parts 70-72) all of the applicable
                    requirements of the Amendments are integrated into one federal renewable
                    operating permit. Facilities defined as "major sources" under the Act must
                    apply for permits within one year from when EPA approves the state permit
                    programs.  Since most state programs were  not approved until after
                    November 1994, Title  V permits will, for the most part, begin to be due in
                    late 1995. A  facility is designated as a major source if it includes sources
                    subject to  the NSPS acid rain provisions or NESHAPS, or if it releases a
                    certain amount of any one of the CAAA regulated pollutants (SOX, NOX, CO,
                    VOC, PMj0, hazardous air pollutants, extremely hazardous substances, ozone
                    depleting substances, and pollutants covered by NSPSs) depending on the
                    region's air quality category. Although revisions to the definition of what
                    constitutes a  major source  were being negotiated at the  time  that this
                    document  went to press (August 1995), it is important to note that major
                    source  determination will likely be based on a facility's potential emissions
                    and not its actual emissions.  These revisions to the Title V rules were
                    expected to be published hi late August 1995. Title V permits may set limits
                    on the amounts of pollutant emissions; require  emissions monitoring, and
                    record  keeping and reporting. Under a separate rule, the Continuous Air
                    Monitoring Rule (CAM) being developed, continuous monitoring of certain
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                    emissions from certain facilities may be required (Peter Westlin, U.S. EPA,
                    Office of Air, (919) 541-1058).  Facilities are required to pay a fee for filing
                    for a permit and are required to pay an annual fee based on the magnitude of
                    the facility's potential emissions.110

Resource Conservation and Recovery Act (RCRA)

                    EPA  is studying fourteen refinery theoretical waste streams for potential
                    additions to the RCRA hazardous waste lists under a settlement agreement
                    with the Environmental Defense Fund (Maximo Diaz, Jr., Office of Solid
                    Waste and Emergency Response, (202)-260-4786).  A decision is to be made
                    on each stream by October 31, 1996.  Treatment standards under the Land
                    Disposal Restrictions program will be developed for any wastes listed.
                    Alternatives to listing are also being considered, including  management
                    standards based on pollution prevention, recycling, reclamation, or feedstock
                    to other manufacturing processes.111

                    In 1994, a Refinery Workgroup comprised of representatives from OSWER,
                    Office of Water, and Office of Regulatory Council reviewed the issues
                    surrounding a RCRA/CWA interface pertaining to contaminated ground
                    water seeps to surface water from petroleum refineries. The legal authorities
                    over seeps still remains unclear, hi a report completed in September 1994,
                    the Workgroup recommended that the legal authority pertaining to seeps to
                    surface waters should be made on a case-by-case basis.  The report also
                    discussed the various authorities and circumstances in which they should be
                    utilized.
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VII. COMPLIANCE AND ENFORCEMENT HISTORY

              Background

                     To date, EPA has focused much of its attention on measuring compliance
                     with specific environmental statutes. This approach allows the Agency to
                     track compliance with the Clean Air Act, the Resource Conservation and
                     Recovery Act, the Clean Water Act, and other environmental statutes.
                     Within lite last several years, the Agency has begun to supplement single-
                     media compliance indicators with facility-specific, multimedia indicators of
                     compliance, hi doing so, EPA is in a better position to track compliance with
                     all statutes at the facility level, and within specific industrial sectors.

                     A major step  in building the capacity to compile multimedia data  for
                     industrial sectors was the creation of EPA's Integrated Data for Enforcement
                     Analysis (IDEA) system.  IDEA has the capacity to "read into" the Agency's
                     single-media databases, extract compliance records, and match the records
                     to individual facilities. The IDEA system can match Air, Water, Waste,
                     Toxics/Pesticides/EPCRA, TRI, and Enforcement Docket records for a given
                     facility, and generate a list of historical permit, Inspection, and enforcement
                     activity. IDEA also has the capability to analyze data by geographic area
                     and corporate holder.  As the capacity to generate multimedia compliance
                     data improves, EPA will make available more in-depth compliance and
                     enforcement information. Additionally, sector-specific measures of success
                     for compliance assistance efforts are under development.

              Compliance and Enforcement Profile Description

                     Using inspection, violation and enforcement data from the IDEA system, this
                     section provides information  regarding the historical  compliance and
                     enforcement activity of this sector. In order  to mirror the facility universe
                     reported in the Toxic Chemical Profile, the data reported within this section
                     consists of records only from the TRI reporting universe. With this decision,
                     the selection criteria are consistent across sectors with certain exceptions.
                     For the sectors that do not normally report to the TRI program, data have
                     been provided from EPA's Facility Indexing System (FINDS) which tracks
                     facilities in all media databases. Please note, in this section, EPA does not
                     attempt to define the actual number of facilities that fall within each sector.
                     Instead, the section portrays the records of a subset of facilities within the
                     sector that are well defined within EPA databases.

                     As a check on the relative size of the full sector universe, most notebooks
                     contain an estimated number of facilities within the sector according to the
                     Bureau of Census (See  Section II).  With sectors dominated by small
                     businesses, such as metal finishers and printers, the reporting universe within
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                     the EPA databases may be small in comparison to Census data. However,
                     the group selected for inclusion in this data analysis section should be
                     consistent with this sector's general make-up.

                     Following this introduction is a list defining each data column presented
                     within this section.  These values represent a retrospective summary of
                     inspections or enforcement actions, and solely reflect EPA, state and local
                     compliance assurance activity that have been entered into EPA databases.
                     To identify any changes in trends, the EPA ran two data queries, one for the
                     past five calendar years (August 10, 1990 to August 9, 1995) and the other
                     for the most recent twelve-month period (August 10, 1994 to August 9,
                     1995).  The five-year analysis gives an average  level of activity for that
                     period for comparison to the more recent activity.

                     Because most inspections focus on single-media requirements, the data
                     queries presented in this section are taken from single media databases.
                     These databases do not provide data on whether inspections are state/local
                     or EPA-led. However, the table breaking down the universe of violations
                     does give the reader a crude measurement  of the EPA's and states' efforts
                     within each media program.  The presented data illustrate the variations
                     across regions for certain sectors.6 This variation may be attributable to
                     state/local  data entry variations,  specific geographic  concentrations,
                     proximity to population centers, sensitive ecosystems, highly toxic chemicals
                     used in production, or historical noncompliance.  Hence, the exhibited data
                     do not rank regional performance or necessarily reflect which regions may
                     have the most compliance problems.

       Compliance and Enforcement Data Definitions

              General Definitions

                     Facility Indexing System (FINDS) ~ this system assigns a common facility
                     number to EPA single-media permit records.  The FINDS identification
                     number allows  EPA to  compile and  review all  permit,  compliance,
                     enforcement and pollutant release data for any given regulated facility.

                     Integrated Data for Enforcement Analysis (IDEA) - is a data integration
                     system that can retrieve information from the major EPA program office
                     databases.  IDEA uses the FINDS identification number to "glue together"
' EPA Regions include the following states: I (CT, MA, ME, RI, NH, VT); II (NJ, NY, PR, VI); III (DC, DE, MD,
PA, VA, WV); IV (AL, FL, GA, KY, MS, NC, SC, TN); V (IL, IN, MI, MN, OH, WI); VI (AR, LA, NM, OK, XX);
VII (IA, KS, MO, NE); VIII (CO, MT, ND, SD, UT, WY); IX (AZ, CA, HI, NV, Pacific Trust Territories); X (AK,
ID, OR, WA).
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                    separate data records from EPA's databases. This is done to create a "master
                    list" of data records for any given facility.   Some of the data systems
                    accessible through IDEA are:  AIRS (Air Facility Indexing and Retrieval
                    System, Office of Air and Radiation), PCS (Permit Compliance System,
                    Office of Water), RCRIS (Resource Conservation and Recovery Information
                    System, Office of Solid Waste), NCDB (National Compliance Data Base,
                    Office of  Prevention,  Pesticides,  and  Toxic Substances),  CERCLIS
                    (Comprehensive  Environmental   and  Liability   Information  System,
                    Superfund), and  TRIS  (Toxic Release  Inventory  System).  IDEA  also
                    contains information from outside sources such as Dun and Bradstreet and
                    the Occupational Safety and Health Administration (OSHA).  Most  data
                    queries displayed in notebook sections IV and VII  were conducted using
                    IDEA.

              Data Table Column Heading Definitions

                    Facilities in Search — are based on the universe of TRI reporters within the
                    listed SIC  code range.  For industries not covered under  TRI reporting
                    requirements,  the notebook uses the FINDS universe for executing  data
                    queries.  The SIC code range selected for each search is defined by each
                    notebook's selected SIC code coverage described in Section II.

                    Facilities Inspected -- indicates the level of EPA and state agency facility
                    inspections for the facilities in this data search.  These values show what
                    percentage of the facility universe is inspected in a 12 or 60 month period.
                    This column does not count non-inspectional compliance activities such as
                    the review of facility-reported discharge reports.

                    Number of Inspections ~ measures the total  number of inspections
                    conducted  In this sector. An inspection event is counted each time it is
                    entered into a single media database.

                    Average Time Between Inspections — provides an average length of time,
                    expressed in months, that a compliance inspection occurs at a facility within
                    the defined universe.

                    Facilities with One or More Enforcement Actions — expresses the number
                    of facilities that were party to at least one enforcement action within the
                    defined time period.  This category  is broken down further into federal and
                    state  actions.   Data are obtained  for administrative, civil/judicial, and
                    criminal enforcement actions.  Administrative actions include Notices of
                    Violation (NOVs).  A facility with multiple enforcement actions is  only
                    counted once in this column (facility with three enforcement actions counts
                    as one). All percentages that appear are referenced to the number of facilities
                    inspected.
September 1995
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                           Petroleum Refining
                    Total Enforcement Actions ~ describes the total number of enforcement
                    actions identified for an industrial sector across all environmental statutes.
                    A facility with multiple enforcement actions is counted multiple times (a
                    facility with three enforcement actions counts as three).

                    State Lead Actions -- shows what percentage of the total enforcement
                    actions are taken by state and local environmental agencies.  Varying levels
                    of use by states of EPA data systems may limit the volume of actions
                    accorded  state enforcement  activity.   Some states extensively report
                    enforcement activities into EPA data systems, while other states may use
                    their own data systems.

                    Federal Lead Actions — shows what percentage of the total enforcement
                    actions are taken by the United States Environmental Protection Agency.
                    This value includes referrals from state agencies. Many of these actions
                    result from coordinated or joint state/federal efforts.

                    Enforcement to Inspection  Rate — expresses how often enforcement
                    actions result from inspections. This value is a ratio of enforcement actions
                    to inspections and is presented for comparative purposes only. This measure
                    is a rough indicator of the relationship between inspections and enforcement.
                    This measure simply indicates historically how many enforcement actions
                    can  be attributed to  inspection activity.   Reported  inspections  and
                    enforcement actions under the Clean Water Act (PCS), the Clean Air Act
                    (AFS) and the Resource Conservation and Recovery Act (RCRA) are
                    included  in  this  ratio.      Inspections   and  actions  from   the
                    TSCA/FIFRA/EPCRA database are not factored into this ratio because most
                    of the actions taken under  these programs are not the result of facility
                    inspections.  This ratio does not account for enforcement actions arising from
                    non-inspection compliance monitoring activities (e.g., self-reported water
                    discharges) that can result in enforcement action within the CAA, CWA and
                    RCRA.

                    Facilities with One or More Violations Identified -- indicates  the number
                    and percentage of inspected facilities having a violation identified in one of
                    the following data categories:  In Violation or Significant Violation Status
                    (CAA);  Reportable  Noncompliance,  Current   Year Noncompliance,
                    Significant  Noncompliance  (CWA);  Noncompliance  and  Significant
                    Noncompliance (FIFRA, TSCA, and EPCRA); Unresolved Violation and
                    Unresolved High Priority Violation (RCRA). The values presented for this
                    column reflect the extent of noncompliance within the measured time frame,
                    but do not distinguish  between the severity  of the  noncompliance.
                    Percentages within this column can exceed 100 percent because facilities can
                    be in violation status without being inspected. Violation status may be a
September 1995
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Sector Notebook Project
                          Petroleum Refining
                    precursor to an enforcement action, but does not necessarily indicate that an
                    enforcement action will occur.

                    Media Breakdown of Enforcement Actions and Inspections  — four
                    columns identify the proportion of total inspections and enforcement actions
                    within EPA Air, Water, Waste, and TSCA/FIFRA/EPCRA databases. Each
                    column is a percentage of either the  "Total Inspections,"  or the "Total
                    Actions" column.

VILA. Petroleum Refining Compliance History

                    Exhibit 24 provides an overview of the reported compliance and enforcement
                    data for the refining industry over the past five years (August 1990 to August
                    1995). These data are also broken out by EPA Region thereby permitting
                    geographical comparisons.  A few points evident from the data are listed
                    below.

                    •      Almost all of the facilities identified in the database search were
                           inspected in the past five years. These facilities were inspected on
                           average every three months.

                    •      The ratio  of enforcement actions to  inspections  varied  widely
                           between Regions over the past five  years with little or no direct
                           correlation to the number of facilities in the Region or the proportion
                           of state lead versus federal lead actions.

                    •      Those facilities with one or more enforcement actions had, on
                           average, over the five year period, almost eight enforcement actions
                           brought against them.
September 1995
107
SIC 2911

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Sector Notebook Project
                        Petroleum Refining



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108
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Sector Notebook Project
                           Petroleum Refining
VII.B. Comparison of Enforcement Activity Between Selected Industries

                     Exhibits 25 and 26 allow the compliance history of the petroleum refining
                     sector to be compared to the other industries covered by the industry sector
                     notebooks.   Comparisons  between  Exhibits  25  and  26 permit  the
                     identification of  trends in compliance  and enforcement records of the
                     industry by comparing data covering the last five years to that of the past
                     year. Some points evident from the data are listed below.

                     •      Of those sectors listed, the petroleum refining industry has been the
                           most frequently inspected industry over the past five years.

                     •      The industry has a relatively  large proportion of facilities with
                           violations and  enforcement  actions,  in  comparison to the other
                           sectors.

                     •      The rate of enforcement actions  per inspection for the industry is
                           relatively high, and has changed little over the past year.

                     Exhibits 27 and 28 provide a more in-depth comparison between petroleum
                     refining industry  and other  sectors  by breaking out the compliance and
                     enforcement data by environmental statute.  As in the previous Exhibits
                     (Exhibits 25 and 26), the data cover the last five years (Exhibit 27) and the
                     last one year (Exhibit 28) to facilitate the identification of recent trends. A
                     few points evident from the data are listed below.

                     •      The number of inspections carried out under each environmental
                           statute as a percent of the total has changed little between the average
                           of the past five years and that of the past year. Inspections under
                           CAA appear to be slightly more frequent while inspections under
                           RCRA appear to be slightly less frequent.

                     •      The distribution of enforcement actions between statutes has also
                           changed very  little between the past five years and one year.
                           Enforcement  actions under RCRA  decreased  slightly while
                           enforcement actions under CWA have increased slightly.
September 1995
109
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                        Petroleum Refining


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SIC 2911

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Sector Notebook Project
                                                           Petroleum Refining
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Sector Notebook Project
                                                             Petroleum Refining
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                                   113
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 Sector Notebook Project
                           Petroleum Refining
VII.C.  Review of Major Legal Actions
                    Major Cases/Supplemental Environmental Projects

                    This section provides summary information about major cases that have
                    affected this sector, and a list of Supplementary Environmental Projects
                    (SEPs). SEPs are compliance agreements that reduce a facility's stipulated
                    penalty in return for an environmental project that exceeds the value of the
                    reduction. Often, these projects fund pollution prevention activities that can
                    significantly reduce the future pollutant loadings of a facility.

       VII.C.1. Review of Major Cases

                    Historically, OECA's Enforcement Capacity and Outreach Office does not
                    regularly compile information related to major cases and pending litigation
                    within  an  industry sector.   The staff are willing  to pass along such
                    information to Agency staff as requests are made. (Office of Enforcement
                    Capacity and Outreach 202-260-4140) In addition, summaries of completed
                    enforcement actions are published each fiscal year in the Enforcement
                    Accomplishments Report.  To date, these summaries are not organized by
                    industry sector. (Contact: Robert Banks, 202-260-8296)

       VII.C.2. Supplementary Environmental Projects

                    Supplemental environmental projects (SEPs) are an enforcement option that
                    requires the non-compliant facility to complete specific projects. Regional
                    summaries of SEPs undertaken in the 1993 and 1994 federal fiscal years
                    were reviewed. Eleven projects were undertaken that involved petroleum
                    refineries, as shown in the following table.

                    In the petroleum refinery sector, no single statute engendered the majority of
                    SEPs.   Due to differences  in regional descriptions, the specifics of the
                    original violations are not known.  Overall, Clean Air Act (CAA) violations
                    were the most common amongst petroleum refineries; even so, only three out
                    of the ten projects were due to CAA violations.

                    The  SEPs  in  the  petroleum refinery sector can be grouped into four
                    categories:

                    •      Process change.   Two  SEPs involved the discontinuation  of
                           particular crude oil units  that generated regulated waste streams.
                           Costs to companies were $3,200,000 and $2,000,000, respectively,
                           the most costly of all petroleum refinery SEPs.
September 1995
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                           Leak prevention. Facilities improved leak detection and prevention
                           technologies in piping or tanks as the result of four projects. Original
                           violations for these SEPs were RCRA, CAA, and the Oil Pollution
                           Act (OPA).  Cost to company ranged from $265,000 to $800,000.

                           Control technology improvement/installation.  The three CAA
                           related original violations all had control technology improvements
                           or installations as projects.  Sulfuric air emissions (H2S, SO2) were
                           reduced in  two cases (a reduction of 274 tons/year of SO2) and
                           opacity monitoring was initiated in the third case. Cost to company
                           ranged from $85,000 to $270,000.

                           Non-process related projects.  Some SEPs involved projects that
                           were not directly related to the petroleum refining process.  In one
                           case, PCB-containing transformers were removed as the result of a
                           TSCA violation. Other cases involved equipment donations to Local
                           Emergency  Planning Commissions due to CERCLA non-reporting
                           violations. Cost to company ranged from $9',000 to $19,000.
September 1995
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                                                           Petroleum Refining
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                                  116
                                                                     SIC 2911

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 Sector Notebook Project
                           Petroleum Refining
 VIII.  COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES

                     This section highlights the activities undertaken by this industry sector and
                     public  agencies to  voluntarily  improve  the  sector's  environmental
                     performance.   These activities include those independently initiated by
                     industrial trade associations.  In this section, the notebook also contains a
                     listing and description of national and regional trade associations.

 VIII.A.  Sector-Related Environmental Programs and Activities

 Common Sense Initiative

                     The EPA's Common Sense Initiative (CSI) was announced in November of
                     1993 to encourage  pollution prevention in a few pilot industrial sectors
                     including: iron  and  steel,  electronics,  metal  plating  and  finishing,
                     automobiles, printing, and petroleum refining.  The program shifts regulatory
                     focus from concentrating on individual pollutants and media, to industry-
                     wide approaches to environmental problems.  An EPA team has been
                     assigned to each industry and a strategic plan will be drawn up to identify
                     opportunities to coordinate rulemaking and to streamline record-keeping and
                     permitting requirements.  The teams are working with industry to identify
                     innovative  approaches  in  pollution  prevention  and   environmental
                     technology. Co-chairs for  the Petroleum Refining Committee are Elliot
                     Laws, Assistant Administrator for the Office of Solid Waste and Emergency
                     Response; and Jane Saginaw, Regional Administrator - Region VI. Starting
                     in November of 1994, meetings of most stakeholders including EPA and
                     other government officials, industry representatives, and  environmental
                     groups, have been held to explain the Initiative and its goals as well as to
                     exchange ideas on how to best prevent pollution in the petroleum refining
                     industry. (Contact: Petroleum Refining Team Leaders, Meg Kelly, Office of
                     Solid Waste and Emergency Response, 703-308-8800; Gerald Fontenot,
                     Region VI - Air Branch, 214-665-7205; and OECA staff lead, Tom Ripp,
                     202-564-7003.)

EPA Regional Compliance and Enforcement Activities

                     A number of regions have focused on enforcement and compliance activities
                     that affect Hie petroleum refining sector.  Region V is currently carrying out
                     a geographic enforcement initiative which includes the petroleum refining
                     industry (Contact: Reg Pallesen, 312-886-0555).  In addition, the EPCRA
                    program of Region V conducts a minimum of six outreach training sessions
                     annually, one in each state, which cover all industries. In Region VIII the
                    NPDES  Branch began an enforcement initiative aimed  at petroleum
                    refineries in FY94. The initiative addresses surface water and groundwater
                    contamination  by focusing  on the prevention and elimination of future
                    discharges. The RCRA branch of Region VIE is developing a program for
                    FY95 that includes forming a Multi-Media Refinery Workgroup that will
September 1995
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Sector Notebook Project
                          Petroleum Refining
                    integrate its activities with the Common Sense Initiative Workgroup.  One
                    of the issues to be examined by the workgroup are integrated permits for
                    watersheds.   Region  EX is  working with the  National  Enforcement
                    Investigation Center on  a multi-media  petroleum refining enforcement
                    initiative.

VIII.B. EPA Voluntary Programs
33/50 Program
                    The "33/50 Program" is EPA's voluntary program to reduce toxic chemical
                    releases and transfers of seventeen chemicals from manufacturing facilities.
                    Participating companies pledge to reduce their toxic chemical releases and
                    transfers by 33 percent as of 1992 and by 50 percent as of 1995 from the
                    1988 baseline year.  Certificates of Appreciation have been given out to
                    participants meeting their 1992 goals.  The list of chemicals includes
                    seventeen high-use chemicals reported in  the Toxics Release Inventory.
                    Exhibit 30 lists those companies participating in the 33/50 program that
                    reported the SIC code 2911 to TRI.  Many of the companies shown listed
                    multiple SIC codes and, therefore,  are likely to carry  out operations  in
                    addition to petroleum refining. The SIC codes reported by each company are
                    listed in no particular order. In addition, the number of facilities within each
                    company that are participating in the 33/50 program and that report SIC 2911
                    to TRI are shown. Finally, each company's total 1993 releases and transfers
                    of 33/50 chemicals and the percent reduction in these chemicals since 1988
                    are presented.

                    The petroleum refining industry as a whole used, generated or processed all
                    seventeen target TRI chemicals.  Of the target chemicals, benzene, toluene,
                    xylene and methyl ethyl ketone are released and transferred most frequently
                    and in similar quantities.  These four toxic chemicals account for about 5
                    percent of TRI releases and transfers from petroleum refining facilities.
                    Twenty six companies listed under SIC 2911 are currently participating in
                    the 33/50 program.  They account for 29 percent  of the 91 companies
                    carrying out petroleum refining operations, which is significantly higher than
                    the average for all industries of 14 percent participation.  Exhibit 30 also
                    shows that within these 26 companies, 99 facilities reporting SIC 2911 are
                    participating in the 33/50 program. This comprises about 62 percent of the
                    petroleum refining facilities reporting to TRI. (For more information,
                    contact: Mike Burns, 202-260-6394 or the 33/50 Program 202-260-6907)
September 1995
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Exhibit 30: 33/50 Program Participants Reporting SIC 2911 (Petroleum Refining)
Parent Company
Amerada Hess Corporation
American Petrofina Holding Co.
Amoco Corporation
Ashland Oil Inc.
Atlantic Richfield Company
BHP Holdings (USA) Inc.
BP America Inc.
Chevron Corporation
Cibro Petroleum Bronx Inc.
Citgo Petroleum Corporation
Clark USA Inc.
E. I. Du Pont De Nemours & Co
Exxon Corporation
Kerr-McGee Corporation
VIobil Corporation
New Street Capital Corporation
Pennzoil Company
Phillips Petroleum Company
Quaker State Corporation
Shell Petroleum Inc.
Star Enterprise
Sun Company Inc.
Texaco Inc.
Unocal Corporation
JSX Corporation
Witco Corporation
City, State
New York, NY
Dallas, TX
Chicago, IL
Russell, KY
Los Angeles, CA
San Francisco, CA
Cleveland, OH
San Francisco, CA
Bronx, NY
Tulsa, OK
Saint Louis, MO
Wilmington, DE
Irving, TX
Oklahoma City, OK
Fairfax, VA
Atlanta, GA
Houston, TX
Bartlesville, OK
Oil City, PA
Houston, TX
Houston, TX
Radnor, PA
White Plains, NY
Los Angeles, CA
Pittsburgh, PA
New York, NY
SIC Codes
Reported
2911,5171
2911
2911,2951,2992
2911
2911
2911
2911
2911
2911,5171
2911
2911
2911
2911,5171
2911
2911,2869
2911
2911
2911,2819
2911,2992
2911,2869
2911
2911
2911
2911
2911
2911
Number of
Participating
Facilities
4
2
7
3
3
1
5
11
1
2
2
4
5
3
6
1
3
4
1
6
5
5
5
4
5
1
1993 Releases
and
Transfers
(Ibs)
1,286,125
747,799
4,632,163
723,562
2,435,248
64,365
1,597,404
2,794,502
4,025
1,164,354
33,982
1 1,740,853
2,469,930
374,098
4,263,284
2,544
2,594,107
2,367,877
292,587
3,240,716
601,640
2,826,737
514,803
238,520
1,510,772
327,611
%
Reduction
1988 to
1993
50
40
50
50
2
***
24
50
***
20
***
50
50
35
50
50
30
50
6
55
50
50
50
50
25
50
* = not quantifiable against 1988 data.
** = use reduction goal only.
*** = no numerical goal.
Source: U.S. EPA, Toxics Release Inventory, 1993.
Environmental Leadership Program
                    The Environmental Leadership Program (ELP) is a national initiative piloted
                    by EPA and  state agencies hi which facilities have  volunteered to
                    demonstrate innovative  approaches  to  environmental management and
                    compliance. EPA has selected 12 pilot projects at industrial facilities and
                    federal installations which will demonstrate the  principles  of the ELP
                    program. These principles include: environmental management systems,
                    multimedia compliance assurance, third-party verification of compliance,
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                    public measures of accountability, community involvement, and mentoring
                    programs. In return  for  participating,  pilot participants receive public
                    recognition and are  given a period of time  to  correct any violations
                    discovered during these experimental projects.  At present, no petroleum
                    refineries are carrying out ELP pilot projects.  (Contact: Tai-ming Chang,
                    ELP Director 202-564-5081 or Robert Fentress 202-564-7023)
Project XL
                     Project XL was initiated in March 1995 as a part of President Clinton's
                     Reinventing Environmental Regulation initiative.  The  projects seek to
                     achieve cost effective environmental benefits by allowing participants to
                     replace or modify existing regulatory requirements on the condition that they
                     produce greater environmental benefits. EPA and program participants will
                     negotiate and sign a Final Project Agreement, detailing specific objectives
                     that the regulated entity shall satisfy. In exchange, EPA will allow the
                     participant a certain degree of regulatory flexibility and may seek changes
                     in underlying regulations or statutes. Participants are encouraged to seek
                     stakeholder support from local governments, businesses, and environmental
                     groups.  EPA hopes to implement fifty pilot projects in four categories
                     including facilities, sectors, communities, and government agencies regulated
                     by EPA. Applications will be accepted on a rolling basis and projects will
                     move to implementation within six months of their selection. For additional
                     information,regarding XL Projects,  including application procedures and
                     criteria, see the May 23,1995 Federal Register Notice. (Contact Jon Kessler
                     at EPA's Office of Policy Analysis 202-260-4034)
Green Lights Program
                     EPA's Green Lights program was initiated in 1991 and has the goal of
                     preventing pollution by encouraging U.S. institutions to use energy-efficient
                     lighting technologies.  The program has over  1,500  participants which
                     include major corporations; small and medium  sized businesses; federal,
                     state and local governments; non-profit groups;  schools; universities; and
                     health care facilities. Each participant is required to survey their facilities
                     and upgrade lighting wherever it is profitable.  EPA provides technical
                     assistance to the participants through a decision support software package,
                     workshops and manuals, and a financing registry. EPA's Office of Air and
                     Radiation is responsible for operating the Green Lights Program. (Contact:
                     Maria Tikoff at 202-233-9178 or the Green Light/Energy Star Hotline at
                     202-775-6650)
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WasteWi$e Program
                    The WasteWi$e Program was started in 1994 by EPA's Office of Solid
                    Waste and Emergency Response.   The program is  aimed at reducing
                    municipal  solid wastes  by  promoting waste  minimization, recycling
                    collection and the manufacturing and purchase of recycled products. As of
                    1994, the program had about 300 companies as members, including a number
                    of major corporations. Members agree to identify and implement actions to
                    reduce their solid wastes and must provide EPA with their waste reduction
                    goals along with yearly progress reports. EPA in turn provides technical
                    assistance to member companies and allows the use of the WasteWi$e logo
                    for promotional purposes.  (Contact: Lynda Wynn 202-260-0700 or the
                    WasteWi$e Hotline at 800-372-9473)
Climate Wise Recognition Program
NICE*
                    The Climate Change Action Plan was initiated in response to the U.S.
                    commitment to reduce greenhouse gas emissions in accordance with the
                    Climate Change Convention of the 1990 Earth Summit.  As part of the
                    Climate Change Action Plan, the Climate Wise Recognition Program is a
                    partnership initiative run jointly by EPA and the Department of Energy. The
                    program is designed to reduce  greenhouse gas emissions by encouraging
                    reductions across all sectors of the economy, encouraging participation in the
                    full  range of Climate  Change  Action Plan initiatives, and  fostering
                    innovation. Participants in the program are required to identify and commit
                    to actions that reduce greenhouse gas emissions. The program, in turn, gives
                    organizations early recognition  for their reduction commitments; provides
                    technical assistance through consulting services, workshops, and guides; and
                    provides access to the program's centralized information system.  At EPA,
                    the program is operated by the Air and Energy Policy Division within the
                    Office of Policy Planning and Evaluation. (Contact: Pamela Herman 202-
                    260-4407)
                    The U.S. Department of Energy and EPA's Office of Pollution Prevention
                    are jointly administering a grant program called The National Industrial
                    Competitiveness through Energy, Environment, and Economics (NICE3). By
                    providing grants of up to 50 percent of the total project cost, the program
                    encourages industry to reduce industrial waste at its source and become more
                    energy-efficient and cost-competitive through waste minimization efforts.
                    Grants are used  by industry to design, test, demonstrate, and assess the
                    feasibility of new processes and/or equipment with the potential to reduce
                    pollution and increase energy efficiency.  The program is open to all
                    industries; however, priority is given to proposals from participants in the
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                    pulp and paper, chemicals, primary metals, and petroleum and coal products
                    sectors. The program has worked with the petroleum industry to evaluate the
                    feasibility of using a closed-loop solvent extraction system to recover
                    organic material from solid wastes normally disposed of off-site. (Contact:
                    DOE's Golden Field Office 303-275-4729)

VIII.C. Trade Association/Industry Sponsored Activity

       VHI.C.l. Environmental Programs

       Global Environmental Management Initiative

                    The Global Environmental Management Initiative (GEMI) is made up of
                    group of leading companies dedicated to fostering environmental excellence
                    by business.  GEMI promotes a worldwide business ethic for environmental
                    management and sustainable development, to improve the environmental
                    performance of business through example and leadership.  In 1994, GEMI's
                    membership consisted of about 30 major corporations including Amoco
                    Corporation.

       Amoco - U.S. EPA Pollution Prevention Project

                    The Amoco - U.S. EPA Pollution Prevention Project was a voluntary joint
                    project to study pollution prevention opportunities at an industrial facility.
                    The Amoco Oil Cofnpany's refinery at Yorktown, Virginia was used to
                    conduct a multi-media assessment of releases to the environment, then to
                    develop and evaluate options to reduce these releases. The project identified
                    pollutant release points and cost effective pollution prevention techniques.
                    In addition, a number of important observations were made relating to:
                    differences in TRI estimated releases  and actual  releases,  regulatory
                    obstacles to implementing pollution prevention programs, and incentives for
                    pollution prevention.  A project summary report was issued in January
                    1992.112

       API Residual Management Survey

                    The American Petroleum Institute (API) has conducted  yearly surveys of
                    residual  materials  generation  and  residual  management  practices  at
                    refineries. The survey collects data on about 30 different waste streams, their
                    management techniques and pollution prevention activities of API members.
                    A yearly report is issued titled, "Generation and Management of Residual
                    Materials."  This  report is available from the American Petroleum Institute.
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       API Ground-water Research Program

                     API conducts research to assist the petroleum industry in dealing with its
                     groundwater contamination problems. The research is aimed at the problems
                     faced by the petroleum industry, including petroleum refineries, but is made
                     available to those outside the industry as well.  Research studies evaluate
                     techniques and  develop new  methods to detect, monitor and cleanup
                     groundwater contamination. Numerous manuals and reports have  been
                     published  and periodic conferences  and  workshops  on groundwater
                     monitoring and cleanup techniques are sponsored.

       Compendium of Waste Minimization Practices

                     The American Petroleum Institute sponsored a waste minimization practices
                     compendium in the Summer of 1990 to summarize waste minimization
                     techniques for oil and gas exploration and production, refining and marketing
                     industries. The compendium contains a literature survey and case studies.

       Petroleum Environmental Research Forum

                     The Petroleum Environmental Research Forum is  an industry group that
                     shares research costs and findings that relate particularly to the petroleum
                     industry.  The Forum has funded research on pollution prevention in the
                     industry.

       API STEP Program

                     The STEP (Strategies for Today's Environmental Partnership) program was
                     developed by API member companies  to address public environmental
                     concerns by improving the industry's environmental, health, and safety
                     performance; documenting performance improvements; and communicating
                     them  to the public.  The foundation for STEP is the API Environmental
                     Mission and the API Guiding Environmental Principles.  The program also
                     includes a series of environmental strategic plans; a review and revision of
                     existing industry standards; documentation of industry environmental, health,
                     and safety performance; and mechanisms for obtaining public input.  In
                     1992, API endorsed, as part of STEP, adoption of management practices as
                    an API recommended practice.  The management practices contain the
                    following  elements: pollution prevention, operating and process safety,
                    community awareness, crisis readiness, product stewardship, proactive
                    government interaction,  and resource conservation.  The management
                    practices  are  an outline  of actions to help  companies  incorporate
                    environmental health and safety concerns into their planning and decision
                    making. Each company will make its own decisions on how and whether to
                    change its operations.  API has developed a compilation of resources that
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                    provide recommendations and guidance on various operational areas of the
                    oil  industry to assist API  members with their  implementation  of the
                    management practices. (Contact: Walter Retzch, API, 202-682-8598)

       VHI.C.2. Summary of Trade Associations

                    The trade  and professional  organizations serving the petroleum refining
                    industry are either  specific  to  petroleum refining or  to the petroleum
                    production, refining and distribution as a whole. Further differences  in
                    membership are based on company size and ownership. More specifically,
                    the large, multinational oil companies are members of industry-wide trade
                    groups and the small, independent petroleum refiners are members of both
                    industry-wide  and small, independent trade groups.   The major trade
                    organizations are discussed below.
                    American Petroleum Institute
                    1220 L St. NW
                    Washington, DC 20005
                    Phone: (202) 682-8000
                    Fax: (202) 682-8030
                  Members: 300
                  Staff: 400
                  Contact: Alison Kerester
                    The American Petroleum Institute (API) is the largest trade group for the
                    petroleum refining industry, with the largest membership and budget. API
                    represents the major oil companies, and independent oil producers, refiners,
                    marketers, and transporters of crude oil, lubricating oil, gasoline, and natural
                    gas. API conducts and promotes research in the petroleum industry and
                    collects data and publishes statistical reports on oil production and refining.
                    Numerous manuals, booklets, and other materials are published on petroleum
                    refining to assist members in environmental compliance.
                    National    Petroleum
                    Association
                    1899LSt.NW1000
                    Washington, DC 20036
                    Phone: (202) 457-0480
                    Fax: (202) 457-0486
    Refiners
                  Members: 370
                  Staff: 28
                  Contact: Norbert Dee, Ph.D.
                    The National Petroleum Refiners Association (NPRA) was founded in 1902
                    and represents  virtually  all  domestic  refiners  and  petrochemical
                    manufacturers using processes similar to refineries. NPRA's membership
                    includes both large companies and many small and independent companies.
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                    Mid-Continent Oil and Gas Association
                    801 Pennsylvania Ave. NW
                    Suite 840
                    Washington, DC 20004
                    Phone: (202) 638-4400
                    Fax: (202) 638-5967
                     Members: 7500
                     Staff: 6
                     Contact: Mr. Modiano
                    The Mid-Continent Oil and Gas Association was founded in 1917 and
                    represents  oil  and gas  producers, royalty owners,  refiners, gasoline
                    manufacturers,  transporters, drilling contractors, supply and equipment
                    dealers and wholesalers,  bankers, and other individuals interested in oil
                    business.
                    American Independent
                    Refiners Association/
                    Western Independent
                    Refiners Association
                    801 S. Grand Ave., 10th Fl.
                    Los Angeles, CA 90017
                    Phone: (213) 624-8407
                 Members: AIRA: 27, WIRA: 9
                 Contact: Craig Moyer
                    The American Independent Refiners Association (AIRA) was founded in
                    1983  and represents independent oil refiners and companies that supply
                    services to the independent refining industry.  The  Western Independent
                    Refiners Association (WIRA) was founded later to address the specific needs
                    of refiners on the west coast.  The associations are separate, but closely
                    affiliated with many of the members of WIRA also members of AIRA.
                    Neither organization has a full-time staff.  Much of the  associations'
                    activities are carried out by members and outside consultants. Through the
                    associations'  cooperative  environmental  services,   members are  each
                    responsible for a federal or state agency and/or office, monitoring the
                    environmental issues, and reporting to members. Outside consultants are
                    hired to look at safety and environmental compliance issues.
                    Western States Petroleum Association
                    505 N. Brand Blvd., Ste. 1400
                    Glendale, CA 91203
                    Phone: (818) 545-4105                    Members: 60

                    The  Western States Petroleum Association  was founded  in  1917 and
                    represents oil and gas producers, royalty  owners, refiners, gasoline
                    manufacturers, transporters,  drilling contractors,  supply  and equipment
                    dealers and wholesalers, bankers, and other individuals interested in the oil
                    business.
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IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/BIBLIOGRAPHY'

                      For further information on selected topics within the petroleum refining
                      industry a list of contacts and publications are provided below:

 Contacts
Name
Tom Ripp
i
Ken Garing
Linda Tekrony
Jim Durham
Ron Kirby
Max Diaz
Meg Kelly
Katherine Keith
Ken Cooper
John Kim
Paul Boys
Gregory Filas
Nancy Johnson
Alison Kerester
Norbert Dee, Ph.D.
Organization
EPA/OECA
EPA/NEIC
EPA/NEIC
EPA/OAR
EPA/OW
EPA/OSWER
EPA/OSWER
EPA/Region V
EPA/Region VI
EPA/Region IX
EPA/Region X
DOE/EIA
DOE/OFE
API
NPRA
Telephone
(202) 564-7003
(303) 236-3636
(303) 236-3636
(919)546-5672
(202) 260-7168
(202) 260-4786
(703) 308-8748
(312)353-6956
(713) 983-2148
(415) 744-1263
(206) 553-1567
(202) 586-1347
(202) 586-6458
(202) 682-8346
(202) 457-0480
Subject
Regulatory requirements and compliance
assistance
Industrial processes and regulatory
requirements (Air)
Industrial processes and regulatory
requirements (RCRA)
Regulatory requirements (Air)
Regulatory requirements (Water)
Regulatory requirements (Solid waste)
CSI lead - Source reduction
Inspections, regulatory requirements
(Air), and enforcement
Inspections and regulatory requirements
(Water, RCRA and TSCA)
Inspections and regulatory requirements
(Air)
Inspections and regulatory requirements
(Air)
Industry financial information
Environmental issues
Federal environmental requirements
Federal environmental requirements
 OECA: Office of Enforcement and Compliance Assistance
 NEIC: National Enforcement Investigations Center
 OAR: Office of Air and Radiation
 OW: Office of Water
 OSWER: Office of Solid Waste and Emergency Response
 EIA: Energy Information Administration
 OFE: Office of Fossil Energy
 API: American Petroleum Institute
 NPRA: National Petroleum Refiners Association
 f Many of the contacts listed above have provided valuable background information and comments
 during the development of this document.  EPA appreciates this support and acknowledges that the
 individuals listed do not necessarily endorse all statements made within this notebook.
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General Profile
The U.S. Petroleum Industry: Past as Prologue, 1970-1992, Energy Information Administration,
September, 1993. (DOE/EIA-0572)

Petroleum: An Energy Profile, Energy Information Administration, August, 1991. (DOE/EIA-
0545(91)

U.S. Industrial Outlook 1994, Department of Commerce.
                                                                      <
1992 Census of Manufacturers Preliminary Report Industry Series: Petroleum and Coal
Products, Bureau of the Census, June 1994. (MC92-1-29A(P))

Process Descriptions	

Petroleum Refining - Technology & Economics, Gary & Handwerk, 3rd Edition, Marcel Dekker,
Inc., New York, N.Y., 1994.

Petroleum Refining for the Non-Technical Person, 2nd ed., William L. Leffler, Perm Well
Publishing Company, Tulsa, Oklahoma, 1985.

Handbook of Petroleum Refining Processes, Meyers, R.A., McGraw-Hill Book Company, New
York, 1986.

Petroleum Refining Distillation, Watkins, R.N., Gulf Publishing, Inc., Houston, TX, 1979.

Petroleum Refinery Enforcement Manual, U.S. EPA Office of Enforcement, by PEDCo
Environmental Inc., Arlington, Texas, March 1980. EPA-340/1 -80-008.

Release Profiles	

Compilation of Air Pollutant Emission Factors, 3rd ed., Ch. 9, William M. Vatavuk, August
1977.

Assessment of Atmospheric Emissions from Petroleum Refining, R.G. Wetherold, Radian
Corporation, Austin, Texas and U.S. EPA, Office of Research and Development, Washington,
DC, April, 1980. (EPA-600/2-80-075e)

Petroleum Industry Environmental Performance, Third Annual Report, American Petroleum
Institute, Washington, DC, 1995.

Petroleum Refinery Enforcement Manual, U.S. EPA Office of Enforcement, by PEDCo
Environmental Inc., Arlington, Texas, March 1980. EPA-340/1-80-008.
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Hazardous Waste Generation: 1. Petroleum Refining, U.S. EPA, Office of Solid Waste, January
1994.

Amoco - U.S. EPA Pollution Prevention Project, Yorktown, Virginia, Project Summary, U.S.
EPA, January 1992.

The Generation and Management of Wastes and Secondary Materials in the Petroleum Refining
Industry: 1987-1988, American Petroleum Institute, February 1991. (API Pub. no. 4530)

Generation and Management of Wastes and Secondary Materials: Petroleum Refining
Performance, 1989 Survey, American Petroleum Institute, June 1992. (API Pub. no. 303)

Generation and Management of Wastes and Secondary Materials: Petroleum Refining
Performance, 1990 Survey, American Petroleum Institute, August 1993. (API Pub. no. 324)

Generation and Management of Wastes and Secondary Materials: Petroleum Refining
Performance, 1991 Survey, American Petroleum Institute, May 1994. (API Pub. no. 329)

Toxics Release Inventory, Public Data Release, 1992, U.S. EPA, Office of Pollution Prevention
and Toxics, April, 1994. (EPA 745-R-94-001)

Dioxin andFurans - A Primer: What They Are and How to Measure Them, American Petroleum
Institute, Washington, DC, March 1990.

Refinery Waste-water Priority Pollutant Study - Sample Analysis and Evaluation of Data,
American Petroleum Institute, Washington, DC, December  1981.

Environmental Design Considerations for Petroleum Refining Crude Processing Units,
American Petroleum Institute, February 1993. (API Pub. no. 311)

Pollution Prevention	

Hazardous Waste Minimization: Part V Waste Minimization in the Petroleum Industry, Leeman,
J.E., JAPCA 38, no. 6, June 1988.

Waste Minimization in the Petroleum Industry a Compendium of Practices, American Petroleum
Institute, November 1991. (API Pub. no. 3020)

Amoco - U.S. EPA Pollution Prevention Project, Yorktown,  Virginia, Project Summary, U.S.
EPA, January 1992.

Case Study: Identifying Pollution Prevention Options For a Petroleum Refinery, Balik, J.A., and
Koraido, S.M., Pollution Prevention Review. Summer 1991.
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New Catalyst Designs Meet Environmental Challenges of the 1990's, Corbgett, R.E., Oil & Gas
Journal. October 1,1990.

Dry Scrubber Reduces SO2 in Calciner Flue Gas, Brown, G.W., Roderick, D., and Nastri, A.,
Oil & Gas Journal. February 18,1991.

Innovative Improvements Highlight FCC's Past and Future, Avidan, A. A., Edwards, M., Owen,
H., Oil & Gas Journal. January 8,1990.

Pollution Prevention: Strategies for Petroleum Refining (Fact Sheet), Center for Hazardous
Materials Research (CHMR), Pittsburgh, PA.

Pollution Prevention Opportunities in Petroleum Refining (Fact Sheet), U.S. EPA Region III,
Philadelphia, PA, October, 1990.

Pollution Prevention Opportunities Checklists, County Sanitation Districts of Los Angeles
County, January 1991.

Regulatory Profile	

Sustainable Environmental Law, Environmental Law Institute, West Publishing Co., St. Paul,
Minn., 1993.

Issues Affecting the Refining Sector of the Petroleum Industry, Hearings Before the Committee
on Energy and Natural Resources, United States Senate, Washington, DC, May 19, 1992,
Cheyenne, WY, May 28,1992, U.S. GPO, Washington, DC, 1992.

Costs to the Petroleum Industry of Major New and Future Federal Government Environmental
Requirements, American Petroleum Institute, Washington, DC, October 1993. (API Discussion
Paper #070R)

U.S. Petroleum Refining: Meeting Requirements for Cleaner Fuels and Refineries, Volumes I-VI,
National Petroleum Council Committee on Refining, U.S. Department of Energy, August 1993.

U.S. Petroleum Strategies in the Decade of the Environment, Williams, Bob, Penn Well Books,
Tulsa,OK,1991.

Environmental Related Issues Taking Their Turn in Restructuring Industry, Williams, Bob, Oil
& Gas Journal. January 22,1990.

Clean Air Act Complicates Refinery Planning, Scherr, R.C., Smalley, G.A., and Norman, M.E.,
Oil & Gas Journal. May 27,1991.

Clean Air Amendments Put Big Burden on Refinery Planners, Scherr, R.C., Smalley, G.A., and
Norman, M.E., Oil & Gas Journal. June 10,1991.
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 U.S. Regs Cause Refiners to Rethink Wastewater Systems, Norman, M.E., Kapoor, S., Smalley,
 G.A., and Daniel, B.M., Oil & Gas Journal. June 1,1992.

 U.S. Refiners Choosing Variety of Routes to Produce Clean Fuels, Ragsdale, R., Oil & Gas
 Journal. March 21,1994.
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                                     END NOTES

 1. 1992 Census of Manufacturers Preliminary Report Industry Series: Petroleum and Coal
 Products, Bureau of the Census, June 1994. (MC92-1-29A(P))

 2. Petroleum: An Energy Profile, Energy Information Administration, August, 1991.
 (DOE/EIA-0545(91), p. 5.

 3. Petroleum Refining for the Non-Technical Person, 2nd ed., William L. Leffler, PennWell
 Publishing Company, Tulsa, Oklahoma, 1985.

 4. Petroleum: An Energy Profile, Energy Information Administration, August, 1991.
 (DOE/EIA-0545(91)

 5. Standard Industrial Classification Manual.

 6. United States Refining Capacity.  Washington, D.C.: National Petroleum Refinery
 Association, January 1, 1994.

 7. 1992 Census of Manufacturers Industry Series: Petroleum and Coal Products, Bureau of the
 Census, June 1994. (MC92-I-29A)

 8. Ibid.

 9. 1992 Census of Manufacturers Industry Series: Blast Furnaces, Steel Works, and Rolling and
 Finishing Mills, Bureau of the Census, May 1994. (MC92-I-29A)

 10. 1992 Census of Manufacturers Industry Series: Petroleum and Coal Products.  Bureau of
 Census, 1987 (MC92-I-29A).

 11. United States Refinery Capacity.  Washington, D.C.: National Petroleum Refinery
Association, January 1, 1994.

 12. The U.S. Petroleum Industry: Past as Prologue, 1970-1992, Energy Information
Administration, September, 1993.  (DOE/EIA-0572)

 13. U.S. Industrial Outlook 1994, Department of Commerce.

 14. Ibid.

 15. API comments on draft document.

 16. Statement of the American Petroleum Institute.

 17. Statement of the American Petroleum Institute, Issues Affecting the Refining Sector of the
Petroleum Industry, Hearings Before the Committee on Energy and Natural Resources, United
States Senate, Washington, DC, May 19 and 28, 1992, U.S. Government Printing Office,
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Washington, DC: 1992.

18. U.S. Industrial Outlook 1994, Department of Commerce.

19. U.S. Industrial Outlook 1994, Department of Commerce.

20. Lichtblau, John H., Petroleum industry Research Foundation, Inc., New York, NY. Prepared
statement for the Hearings before the Committee on Energy and Natural Resources, United
States Senate, One Hundred Second Congress, Second Session, on the Issues Affecting the
Refining Sector of the Petroleum Industry, Washington, DC, May 19,1992. U.S. Government
Printing Office, Washington:  1992. ISBN 0-16-039466-X.

21. Petroleum  Refining - Technology & Economics, Gary & Handwerk, 3rd Edition, Marcel
Dekker, Inc., New York, N.Y, 1994.

22. Ibid.

23. Ibid.

24. U.S. EPA.  Development Document for Effluent Limitation Guidelines: New Source
Performance Standards and Pretreatment Standards for the Petroleum Refining Point Source
Category.  Ruddy, D., Project Officer, Office of Water Regulations and Standards, Washington,
D.C.: U.S. EPA, October 1982.

25. Petroleum  Refining - Technology & Economics, Gary & Handwerk, 3rd Edition, Marcel
Dekker, Inc., New York, N.Y., 1994.

26. Assessment of Atmospheric Emissions from Petroleum Refining, R.G. Wetherold, Radian
Corporation, Austin, Texas and U.S. EPA, Office of Research and Development, Washington,
DC, April, 1980. (EPA-600/2-80-075e)

27. U.S. EPA.  Development Document for Effluent. Limitation Guidelines: New Source
Performance Standards and Pretreatment Standards for the Petroleum Refining Point Source
Category.  Ruddy, D., Project Officer, Office of Water Regulations and Standards, Washington,
D.C.: U.S. EPA, October 1982.

28. Petroleum Refining for the Non-Technical Person, 2nd ed., William L. Leffler, PennWell
Publishing Company, Tulsa, Oklahoma, 1985.

29. Assessment of Atmospheric Emissions from Petroleum Refining, R.G. Wetherold, Radian
Corporation, Austin, Texas and U.S. EPA, Office of Research and Development, Washington,
DC, April, 1980. (EPA-600/2-80-075e)

30. U.S. EPA. Development Document for Effluent Limitation Guidelines: New Source
Performance Standards and Pretreatment Standards for the Petroleum Refining Point Source
Category.  Ruddy, D., Project Officer, Office of Water Regulations and Standards, Washington,
D.C.: U.S. EPA, October 1982.
September 1995
          SIC .2911

-------
 Sector Notebook Project
Petroleum Refining
 31. Petroleum Refining - Technology & Economics, Gary & Handwerk, 3rd Edition, Marcel
 Dekker, Inc., New York, N.Y., 1994.

 32. Petroleum Refining for the Non-Technical Person, 2nd ed., William L. Leffier, PennWell
 Publishing Company, Tulsa, Oklahoma, 1985.

 33. Petroleum Refining - Technology & Economics, Gary & Handwerk, 3rd Edition, Marcel
 Dekker, Inc., New York, N.Y., 1994.

 34. Ibid.

 35. Ibid.

 36. Petroleum Refinery Enforcement Manual, U.S. EPA Office of Enforcement, by PEDCo
 Environmental Inc., Arlington, Texas, March 1980. EPA-340/1 -80-008.

 37. Petroleum Refining - Technology & Economics, Gary & Handwerk, 3rd Edition, Marcel
 Dekker, Inc., New York, N.Y., 1994.

 38. U.S. EPA. Development Document for Effluent Limitation Guidelines: New Source
 Performance Standards and Pretreatment Standards for the Petroleum Refining Point Source
 Category.  Ruddy, D., Project Officer, Office of Water Regulations and Standards, Washington,
 D.C.: U.S. EPA, October 1982.

 39. Petroleum Refining - Technology & Economics, Gary & Handwerk, 3rd Edition, Marcel
 Dekker, Inc., New York, N.Y., 1994.

 40. Ibid.

 41. Petroleum Refinery Enforcement Manual, U.S. EPA Office of Enforcement, by PEDCo
 Environmental Inc., Arlington, Texas, March 1980. EPA-340/1-80-008.

 42. Petroleum Refining - Technology & Economics, Gary & Handwerk, 3rd Edition, Marcel
 Dekker, Inc., New York, N.Y., 1994.

 43. Petroleum Refinery Enforcement Manual, U.S. EPA Office of Enforcement, by PEDCo
 Environmental Inc., Arlington, Texas, March 1980. EPA-340/1-80-008.

 44. Petroleum Refining - Technology & Economics, Gary & Handwerk, 3rd Edition, Marcel
 Dekker,.Inc., New York, N. Y., 1994.

45. Ibid.

46. Petroleum Refinery Enforcement Manual, U.S. EPA Office of Enforcement, by PEDCo
Environmental Inc., Arlington, Texas, March 1980. EPA-340/1-80-008.
September 1995
         SIC 2911

-------
Sector Notebook Project
Petroleum Refining
47. U.S. EPA. Development Document for Effluent Limitation Guidelines: New Source
Performance Standards and Pretreatment Standards for the Petroleum Refining Point Source
Category. Ruddy, D., Project Officer, Office of Water Regulations and Standards, Washington,
D.C.: U.S. EPA, October 1982.

48. Petroleum Refining - Technology & Economics, Gary & Handwerk, 3rd Edition, Marcel
Dekker, Inc., New York, N.Y., 1994.

49. Petroleum Refinery Enforcement Manual, U.S. EPA Office of Enforcement, by PEDCo
Environmental Inc., Arlington, Texas, March 1980. EPA-340/1 -80-008.

50. U.S. EPA. Development Document for Effluent Limitation Guidelines: New Source
Performance Standards and Pretreatment Standards for the Petroleum Refining Point Source
Category. Ruddy, D., Project Officer, Office of Water Regulations and Standards, Washington,
D.C.: U.S. EPA, October 1982.

51. Petroleum Refining - Technology & Economics, Gary & Handwerk, 3rd Edition, Marcel
Dekker, Inc., New York, N.Y., 1994.

52. Personal interviews with EPA staff and comments on draft document by API.

53. U.S. EPA. Development Document for Effluent Limitation Guidelines: New Source
Performance Standards and Pretreatment Standards for the Petroleum Refining Point Source
Category. Ruddy, D., Project Officer, Office of Water Regulations and Standards, Washington,
B.C.: U.S. EPA, October 1982.

54. Petroleum Refinery Enforcement Manual, U.S. EPA Office of Enforcement, by PEDCo
Environmental Inc., Arlington, Texas, March 1980. EPA-340/1-80-008.

55.  Provided by Carole L. Engelder, PhD, PE, Amoco Corporation, Permitting and Operating
Services, Texas City, Texas, May 1995.

56. Ibid.

57. Petroleum Refining - Technology & Economics, Gary & Handwerk, 3rd Edition, Marcel
Dekker, Inc., New York, N.Y., 1994.

58. Ibid.

59. Petroleum Refining for the Non-Technical Person, 2nd ed., William L. Leffler, PennWell
Publishing Company, Tulsa, Oklahoma, 1985.

60. Ibid.

61. Petroleum Refinery Enforcement Manual, U.S. EPA Office of Enforcement, by PEDCo
Environmental Inc., Arlington, Texas, March 1980. EPA-340/1 -80-008.
September 1995
          SIC 2911

-------
 Sector Notebook Project
Petroleum Refining
 62. Ibid.

 63. Petroleum Refining - Technology & Economics, Gary & Handwerk, 3rd Edition, Marcel
 Dekker, Inc., New York, N.Y., 1994.

 64. Petroleum Refinery Enforcement Manual, U.S. EPA Office of Enforcement, by PEDCo
 Environmental Inc., Arlington, Texas, March 1980. EPA-340/1 -80-008.

 65. Ibid.

 66. Petroleum Refining - Technology & Economics, Gary & Handwerk, 3rd Edition, Marcel
 Dekker, Inc., New York, N.Y., 1994.

 67. Ibid.

 68. Petroleum Refinery Enforcement Manual, U.S. EPA Office of Enforcement, by PEDCo
 Environmental Inc., Arlington, Texas, March 1980. EPA-340/1-80-008.

 69. Handbook of Petroleum Refining Processes, Meyers, R.A., McGraw-Hill Book Company,
 New York, 1986.

 70. Petroleum Refining for the Non-Technical Person, 2nd ed., William L. Leffler, PennWell
 Publishing Company, Tulsa, Oklahoma, 1985.

 71. Personal interviews with EPA staff.

 72. Assessment of Atmospheric Emissions from Petroleum Refining, R.G. Wetherold, Radian
 Corporation, Austin, Texas and U.S. EPA, Office of Research and Development, Washington,
 DC, April, 1980. (EPA-600/2-80-075e)

 73. Wetherold, R.G., Radian Corporation. Assessment of Atmospheric Emissions from
 Petroleum Refining: Volume 5. Appendix F. U.S. Environmental Protection Agency,
 Washington, DC, 1980. EPA-600/2-80-075e.

 74. Petroleum Refining - Technology & Economics, Gary & Handwerk, 3rd Edition, Marcel
 Dekker, Inc., New York, N.Y., 1994.

 75. Petroleum Refinery Enforcement Manual, U.S. EPA Office of Enforcement, by PEDCo
Environmental Inc., Arlington, Texas, March 1980. EPA-340/1-80-008.

 76. Petroleum Refining - Technology & Economics, Gary & Handwerk, 3rd Edition, Marcel
Dekker, Inc., New York, N. Y., 1994.

77. Compilation of Air Pollutant Emission Factors, Volume I: Stationary Point and Area
Sources, Chapter 9, Petroleum Industry. U.S. EPA, Office of Air and Radiation, Office of Air
Quality Planning and Standards, Research Triangle Park, North Carolina, U.S. Government
Printing Office, Washington, D.C., September 1985.
September 1995
         SIC 2911

-------
Sector Notebook Project
Petroleum Refining
78. Costs to the Petroleum Industry of Major New and Future Federal Government
Environmental Requirements. American Petroleum Institute, Washington, D.C., October 1993.

79. Amoco - U.S. EPA Pollution Prevention Project, Yorktown, Virginia, Project Summary,
January 1992.

80. The U.S. Petroleum Industry: Past as Prologue, 1970-1992, Energy Information
Administration,  September, 1993. (DOE/EIA-0572)

81. Ibid.

82. Ibid.

83. Ibid.

84. Ibid.

85. Ibid.

86. Ibid.

87. Sustainable Environmental Law, Environmental Law Institute, West Publishing Co., St.
Paul, Minn., 1993.

88. 40CFRPart60.

89. Sustainable Environmental Law, Environmental Law Institute, West Publishing Co., St.
Paul, Minn., 1993.

90. 40CFRPart61.

91. 40 CFR Part 262.

92. Telephone interviews with EPA staff.

93. 40 CFR Part 262.

94. Sustainable Environmental Law, Environmental Law Institute, West Publishing Co., St.
Paul, Minn., 1993.

95. Telephone interviews with EPA staff.

96. 40 CFR Part 268.

97. 40 CFR Parts 403 and 419.

98. Telephone interviews with EPA staff.
September 1995
          SIC 2911

-------
Sector Notebook Project
Petroleum Refining
99. Sustainable Environmental Law, Environmental Law Institute, West Publishing Co., St.
Paul, Minn., 1993.

100. Ibid.

101. 40 CFR Parts 313, 302, and 304.

102. Sustainable Environmental Law, Environmental Law Institute, West Publishing Co., St.
Paul, Minn., 1993.

103. Ibid.

104. Telephone interview with CARB staff.

105. Issues Affecting the Refining Sector of the Petroleum Industry, Hearings Before the
Committee on Energy and Natural Resources, United States Senate, Washington, DC, May 19,
1992, Cheyenne, WY, May 28, 1992, U.S. GPO, Washington, DC, 1992.

106. Sustainable Environmental Law, Environmental Law Institute, West Publishing Co., St.
Paul, Minn., 1993.

107. Telephone interview with EPA staff.

108. The U,S. Petroleum Industry: Past as Prologue, 1970-1992, Energy Information
Administration, September, 1993. (DOE/EIA-0572)

109. Telephone interview with EPA staff.

110. The Clean Air Act Amendments: Strategies for the 1990s. Hale and Dorr, Counsellors and
Law and TRC Environmental Consultants, Inc.

111. Telephone interview with EPA staff.

112.  Amoco - U.S. EPA Pollution Prevention Project, Yorktown, Virginia, Project Summary,
January 1992.
September 1995
          SIC 2911

-------

-------
              INSTRUCTIONS FOR DOWNLOADING NOTEBOOKS
                   Electronic Access to the Sector Notebooks  via
                 the Enviro$en$e World Wide Web (E$WWW) and
                 the  Enviro$en$e Bulletin Board System (E$BBS)
       The1 Sector Notebooks are available through two electronic systems, the Enviro$en$e
Bulletin Board System (via modem connection), and the Enviro$en$e World Wide Web (via
Internet).  The Enviro$en$e Communications Network is a free, public, interagency-supported
system operated by EPA's Office of Enforcement and Compliance Assurance and the Office of
Research and Development. The Network allows regulators, the regulated community, technical
experts, and the general public to share information regarding:  pollution prevention and innovative
technology; environmental enforcement and compliance assistance; laws, executive orders,
regulations and policies; points of contact for services and equipment; and other related topics. The
Network welcomes receipt of environmental messages, information and data from any public or
private person or organization. This document first provides summary information on E$WWW
access, then provides information on downloading protocols from within die E$BBS.


A.     ACCESS  THROUGH ENVIRO$EN$E WORLD WIDE WEB

             To access the Sector Notebooks through the Enviro$en$e World Wide Web, set
       your World Wide Web Browser to the following address:

       WWW/INTERNET ADDRESS:   http://es.inel.gov/

       HOTLINE NUMBER FOR E$WWW ONLY: 208-526-6956

       EPA E$WWW MANAGER:  Myles Morse, 202-260-3161
                                                       <
             From the Enviro$en$e home page, click on "Compliance and Enforcement" to
       obtain instructions on how to access the Sector Notebooks and how to provide comments.
       Names, e-mail addresses, and telephone numbers will also be provided should you require
       assistance.  The same documents listed below under the E$BBS instructions are available
       on the E$WWW. Adobe Acrobat formats are also available on E$WWW.


B.     ACCESS  THROUGH THE  ENVIRO$EN$E BULLETIN BOARD  SYSTEM  -
       Instructions  for Connecting, Registering and  Downloading Notebooks

       E$BBS MODEM CONNECTION NUMBER:    703-908-2092

       HOTLINE FOR E$BBS ONLY:  703-908-2007

       MANAGER:   BBS Platform: Louis Paley, 202-260-4640

             The following instructions are condensed from longer documents that provide
       information on the full features of the Enviro$en$e Bulletin Board. Further documentation
       is available on-line in the files that are listed at the end of this Appendix.
                                        A-l

-------
STEP  1.     ESTABLISHING MODEM SETTINGS

             Connecting to the ENVIRO$EN$E BBS is done using a modem and
      communications software. The modem can be either an internal or external model
      connected directly to your computer or part of a modem pool that is accessible through your
      Local Area Network (LAN) system. The communications software (e.g.. CrossTalk,
      ProComm, QModem, Microphone, etc.) is what allows you to access and control your
      modem. Your software needs to be set to the values noted below (many of these settings
      are the standard defaults used):

      •      Telephone number - 703-908-2092 (Tip: Be sure you have entered
             the appropriate dialing prefix; e.g., 9 for an outside line, 1 for long
             distance...)

      •      Baud rate - up to 14,400 BPS is supported  (always select the highest
             speed which YOUR modem will support).

      •      Terminal Emulation  -  BBS, ANSI, VT-100, VT-102 etc. (Tips:
             Do not use TTY. After you log in, if you see screen characters appear on
             the lines where you need to enter information, chances are that you need to
             properly set your terminal emulation.  The emulation can normally be reset
             before or during communication with Enviro$en$e).

             Data Bits - 8  (Eight).

      •      Stop Bits - 1 (One).

      *      Parity -  None.

      •      Transfer Protocols - ZModem,  YModem, XModem, HS/Link,
             BiModem, ASCII (text files only). If your communications software
             supports ZModem, this will increase upload/download efficiency.  You
             must select the same protocol that BOTH your communications software
             and the BBS support so that they can "talk the same language" when
             sending and receiving files.
            Error correction/data compression protocols
            other older, hardware-dependent ones are supported.
v.32,  v.42, and
            Refer to your communications software manual on how to set and save the
      communication parameters noted above (these will generally be the default). Also check to
      make sure you know where the communications software will send the files you
      download. Due to document sizes it is best not to download Sector Notebooks to floppy
      disks.
                                       A-2

-------
STEP 2.    CONNECTING AND REGISTERING

       •      Connect to E$BBS via a modem, using communications software set to the
             above settings by dialing:

                                  (703)  908-2092

             NOTE: EPA Employees can access E$ directly via LAN from the Agency Lan
             Services Menu or Icon and then follow the instructions below. The end of this
             document lists additional resources for accessing E$BBS through the LAN.

             Once you are in the BB S, hit the ENTER/RETURN key twice (2) to accept
             the default values for the screen.

       •      on successive pages, type your first name and hit
             ENTER/RETURN; type your last name and hit ENTER/RETURN;
             and type your password (if you have NOT registered yet,
             make one up, and remember it for subsequent  logons to
             E$) and hit ENTER/RETURN; and

       •      Register (first time only) and immediately receive access to the BBS
             for 120 minutes per day;

                   Type responses to the Registration questions, and hit
                   ENTER/RETURN to begin using ENVIRO$EN$E. (Tip: the last
                   registration question is Country?	)

                   You may need to hit ENTER/RETURN several times to move past System
                   News and Alert messages.

STEP 3.    DOWNLOADING SECTOR NOTEBOOKS

             The files that appear on the following table can be downloaded from E$. Most files
       cannot be viewed on-screen within the E$BBS.  As indicated on the following table, each
       document appears in several formats - WordPerfect 5.1 (PC), WordPerfect 6.1 (PC),
       Microsoft Word 5. la (Mac) or WordPerfect 2.0 (Mac). Please note that the quality of
       formatting and graphics is highest in the file version in which the notebook was originally
       created. The high quality versions are underlined on the following list of filenames.

       Information on Macintosh/Microsoft Word Files

       Available Macintosh files are not compressed. The files are easily identified by the seventh
       and eighth position in the filename - which is "MA." The extension They can be directly
       downloaded and read using Microsoft Word 5.la, or within other  word processing
       software that supports conversion of Microsoft Word 5. la documents. Conversion to
       other programs may alter formatting and graphics quality.

       Information on PC/WordPerfect Files

       The WordPerfect files are all compressed ("zipped" files ending with the .ZIP extension)
       files that need to be decompressed ("unzipped") after they are downloaded.  The notebooks
       that are available in WP 5.1 and WP 6.0 are zipped together (this is why the filenames on
       the following table are the same). When these files are downloaded and "unzipped," you
       will have a version with the extension ".WP5" and one with ".WP6".
                                        A-3

-------
                Available Notebooks, Filenames  and File  Formats
Profile of  the	Industry         PC WP 5.1

Dry Cleaning                       DRYCLNSN.ZIP
Electronics and Computer          ELECMPSN.ZIP
Wood Furniture  and Fixtures       WDFURNSN.ZIP
Inorganic Chemical                INRGCHSN.ZIP
Iron and Steel                     IRONSTSN.ZIP
Lumber and  Wood Products          LMBRWDSN.ZIP
Fabricated  Metal Products         FABMETSN.ZIP
Metal Mining                       METMINSN.ZIP
Motor Vehicle Assembly            MOTVEHSN.ZIP
Nonferrous  Metals                 NFMETLSN.ZIP
Non-Fuel, Non-Metal Mining        NOMTMISN.ZIP
Organic Chemical                  ORGCHMSN.ZIP
Petroleum Refining                PETREFSN.ZIP
Printing                           PRINTGSN.ZIP
Pulp and Paper                     PULPPASN.ZIP
Rubber and  Plastic                RUBPLASN.ZIP
Stone, Clay, Glass and Concrete   STCLGLSN.ZIP
Transportation  Equipment Cleaning TRNSEQSN.ZIP
 PC WP 6.1
   Macintosh
Word 5.1a/WP2.0
DRYCLNSN.ZIP
INRGCHSN.ZIP
IRONSTSN.ZIP
ORGCHMSN.ZIP
PETREFSN.ZIP
PRINTGSN.ZIP
PULPPASN.ZIP
  DRYCLNMA
  ELECMPMA
         .WP2
         ,WD5
                WDFURNMA.WD5
   INRGCHMA
   IRONSTMA
   LMBRWDMA
         ,WP2
         .WP2
         .WD5
  FABMETMA.WD5
  METMINMA.WD5
  MOTVEHMA.WD5
  NFMETLMA.WD5
  NOMTMIMA.WD5
           ,WP2
           ,WP2
           ,WP2
           ,WP2
           .WD5
ORGCHMMA
PETREFMA
PRINTGMA
PULPPAMA
RUBPLAMA
                STCLGLMA.WD5
TRNSBOSN.ZIP    TRNSEQMA.WP2
Note: Underlined  files  contain the highest quality format/graphics

STEP 3 CONTINUED -  PROCEDURES FOR DOWNLOADING

      •     From the E$ Main Menu, select "D" to Download then hit ENTER/RETURN.

      •     Type in the Sector Notebook filename from above that you would like to select for
            downloading  and hit ENTER/RETURN.

      •     The system will ask you to select a file transfer protocol. Select the file transfer
            protocol that matches what you have selected within your PC communications
            software (ZModem is recommended) and hit ENTER/RETURN. (Tip: ZModem
            users may also be allowed to enter more than one filename to download more than
            one document at a time. Simply continue to enter a new filename each time a new
            filename prompt appears on the screen. This option is disabled for other users.)

      •     At this point,  you may

                   begin  downloading by hitting ENTER/RETURN. This should begin the
                   download if you are using the ZModem transfer protocol.  If you don't see
                   information on the screen showing the progress of the download, follow the
                   next step.

      •     If the download does not begin after following the last step, you need to tell your
            communications software to start receiving the file. To do this, look for a
            "RECEIVE" icon or command on your communications software menu and activate
            it. This tells your software to begin the download.
                                      A-4

-------
STEP 4
When the download is completed, a message will appear on the screen to confirm
transmission.

The downloaded file will appear in the folder or directory that you defined in your
communications software.

Repeat the above procedure to download other notebooks.

Macintosh users can logoff using the [GJoodbye command from the main menu

THE FOLLOWING STEP MUST BE TAKEN BY  ALL USERS  THAT
HAVE DOWNLOADED ZIPPED FILES (files with a ".ZIP" filename
extension)  FROM E$.  MACINTOSH USERS CAN SKIP  THIS
STEP.

      In order to read the zipped file(s) you have downloaded, you
      must download  the decompression software required to
      "unzip" your files. To download the decompression software, follow
      the same download instructions given above.  Type in the filename
      "PKZ204G.EXE" and hit ENTER/RETURN.  You only need to download
      this file to your hard drive once.

Logoff using the [G]oodbye command from the main menu.

To end the phone connection, the user should use the "hang up" or "terminate call"
option provided with your communications software.

DECOMPRESSING  ".ZIP'D" DOWNLOADED FILES (PC Only -
Macintosh files do not need to  be decompressed)
             After you have downloaded a compressed (".ZIP") file to your PC, you must
      decompress it to its original format and size by using the "PKUnzip" file which you
      downloaded at the beginning of Step 3. The file which you downloaded;
      "PKZ204G.EXE", contains PKZip.EXE and PKUnzip.EXE files. PKUNZIP will
      decompress the file, returning it to its original size and format as if it had never been
      compressed or transmitted over the BBS. To use the PK commands (pkunzip.exe &
      pkzip.exe), you must be at the DOS prompt (third-party software interfaces exist for
      Windows).  For details on how to use either command, simply type the command at the
      DOS prompt (without any parameters, i.e., just type "PKUNZIP") and hit
      ENTER/RETURN. Since parameters are required for the PKs to work they will
      automatically go into help mode and give you a brief explanation of how they work. If a
      user needs more direction, there is full documentation included in the PKZ204G.EXE in
      the "Hints"  file.

      To decompress any file, use PKUNZIP.EXE by taking the following steps:

      •      Go to the DOS C: prompt and type PKUNZIP.EXE; then,

      •      Type "PKUNZIP [Filename]" (e.g.. the filename and the path of the
             compressed file you wish to decompress).

             NOTE: after the paired files are unzipped, two files will exist, one with the
             extension ".WP5" and one with the extension ".WP6.
                                       A-5

-------
       COMMENTING OR PROVIDING ADDITIONAL INFORMATION ON THE
       SECTOR NOTEBOOKS VIA E$BBS

             Comments on the Sector Notebooks, or supplemental documents of interest can be
       uploaded to the Enviro$en$e BBS. Follow upload instructions that appear on the screen,
       or look at the instructions for compressing and uploading documents. The instructional
       documents are listed below under Section D of this Appendix. All documents that you
       upload will be publicly accessible, and should contain a short abstract (less than 50 words)
       that describes the document. It is recommended that this abstract contain the words "Sector
       Notebook Comments," the title of the Notebook that the comments are directed toward,
       and the words "SIC «Insert applicable 2-digit SIC code»".

             NOTE: To help the system operator know what you've uploaded and where it
             should be put within the BBS, it is helpful to send a message to the system
             operator.  Before logging out of E$, you will be given the option to comment to the
             system operator (Sysop). Please indicate what files you have sent, and that the
             comments or supplemental documents should be placed in Directory 51 - "Sector
             Compliance Information and Notebooks."  Messages can also be sent to the Sysop
             from the main menu using the Message option.
D.    ADDITIONAL  RESOURCE DOCUMENTS AVAILABLE ON E$BBS
             The following files can be viewed from the "Bulletins" section of E$BBS main
      menu.  To receive these documents electronically, the files can be downloaded (and
      viewed) from Directory #160 (utilities). If you would like to download these files, follow
      the same procedures that are outlined (Section C). The directions for direct dial modem
      users are different than the directions for EPA LAN users. How you have accessed the
      E$BBS determines which of the paired files below that you should follow.
      Entered E$
       via Modem

      CONREGWP.TXT


      FINDVIEW.TXT


      CONVCOMP.TXT


      DNLDTXWP.TXT


      DNLDZPWP.TXT


      UPLOADWP.TXT


      SNHOWTO.TXT
 Entered E$
  EPA LAN

 CNREGLAN.TXT


 FNDVWLAN.TXT


 CVCMPLAN.TXT


 DNLTXLAN.TXT


DNZPLAN.TXT


UPLDLAN.TXT


SNHOWLAN.TXT
Description of  File


How to  Connect and Register  on the E$BBS
via Modem
Finding and Viewing Files  from E$BBS via
Modem
Converting,  Compressing &  Uncompressing
Files via Modem
Flagging and Downloading "Uncompressed"
Files from  E$BBS
Flagging and Downloading "Compressed"
Files from  E$BBS
Directions  for Uploading Files  via Modem
to the  E$BBS
Contains this document "Appendix  A -
Downloading Instructions"
                                       A-6
                                                          •U.S. Government Printing Office: 1996 — 413-399

-------
           To order other  EPA Sector  Notebooks
                          use  the form  below
        United States Government
        INFORMATION
Order Processing Code:
* 3212
                               Charge your order.
                                       It's easy!

                                  Fax your orders (202) 512-2250
                               Phone your orders (202) 512-1800
Qty.


















Stock Number
055-000-00512-5
055-000-00513-3
055-000-00518-4
055-000-00515-0
055-000-00516-8
055-000-00517-6
055-000-00519-2
055-000-00520-6
055-000-00521-4
055-000-00522-2
055-000-00523-1
055-000-00524-9
055-000-00525-7
055-000-00526-5
055-000-00527-3
055-000-00528-1
055-000-00529-0
055-000-00514-1
Title
Dry Cleaning Industry, 104 pages
Electronics and Computer Industry, 160 pages
Fabricated Metal Products Industry, 164 pages
Inorganic Chemical Industry, 136 pages
Iron and Steel Industry, 128 pages
Lumber and Wood Products Industry, 136 pages
Metal Mining Industry, 148 pages
Motor Vehicle Assembly Industry, 156 pages
Nonferrous Metals Industry, 140 pages
Non-Fuel, Non-Metal Mining Industry, 108 pages
Organic Chemical Industry, 152 pages
Petroleum Refining Industry, 160 pages
Printing Industry, 124 pages
Pulp and Paper Industry, 156 pages
Rubber and Plastic Industry, 152 pages
Stone, Clay, Glass and Concrete Industry, 124 pages
Transportation Equipment Cleanina Industry, 84 oaaes
Wood Furniture and Fixtures Industry. 132 oaaes
Price
Each
* 6.50
»11.00
"11.00
$ 9.00
* 8.00
* 9.00
"10.00
"11.00
* 9.00
* 6.50
S11.00
"11.00
* 7.50
"11.00
"11.00
* 7.50
" 5.50
* 8.00
Total for Publications
Total
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