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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.
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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.
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(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.
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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
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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.
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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
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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.
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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).
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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.
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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.
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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.
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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
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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.
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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
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• 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.
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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.
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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.
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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
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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)
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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.
September 1995
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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.
September 1995
128
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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.
September 1995
129
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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.
September 1995
130
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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.
September 1995
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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,
September 1995
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
Price
The total cost of my order is $_
_. Price includes regular shipping and handling and is subject to change.
Company or personal name
(Please type or print)
Additional address/attention line
Check method of payment:
Q Check payable to Superintendent of Documents
QGPO Deposit Account I I I I M I | — I I
Q VISA a MasterCard
Street address
City, State, Zip code
I (expiration date) Thank you for your order!
Daytime phone including area code
Purchase order number (optional)
Important: Please include this completed order form with your remittance
Authorizing signature 9/95
Mail to: Superintendent of Documents
P.O. Box 371954, Pittsburgh, PA 15250-7954
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