United States
Environmental Protection
Agency
Enforcement and
Compliance Assurance
(2223-A)
EPA/305-B-97-010
September 1997
vvEPA
Petroleum Refinery
MACT Standard
Guidance
-------
NOTICE
The statements in this document are intended solely as
guidance. This document is not intended, nor can it be relied
on, to create any rights enforceable by any party in litigation
with the United States. EPA and State officials may decide to
follow the guidance provided in this document, or to act at
variance with the guidance, based on an analysis of specific
site circumstances. This guidance may be revised without
public notice to reflect changes in EPA's policy.
Mentions of trade names or commercial products in this
document or associated references does not constitute an
endorsement or recommendation for use.
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Petroleum Refinery MACT Standard Guidance
ACKNOWLEDGMENTS
This document was prepared by Science Applications International Corporation under
the direction of Rafael Sanchez of EPA 's Office of Enforcement and Compliance
Assurance, under EPA contract number 68-C4-0072.
The US Environmental Protection Agency's Manufacturing, Energy and Transportation
Division in the Office of Enforcement and Compliance Assurance would like to express
thanks and appreciation to everyone who helped make the Petroleum Refinery MACT
Standard Guidance possible.
Special thanks to the Petroleum Refinery MACT Review Members: Fred Weeks, EPA
Region 1; Harish Patel, EPA Region 2; Paul Dressel, EPA Region 3; Mirza Baig, EPA
Region 4; Kathy Keith, EPA Region 5; Martin Brittain, EPA Region 6; Bill Peterson, EPA
Region 7; Scott Whitmore, EPA Region 8; John Kim, EPA Region 9; Doug Hardesty &
Andrea Longhouse, EPA Region 10; Jim Durham and Larry Brockman, EPA OAQPS,
and Mary Lalley, ERG, Inc.
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Petroleum Refinery MACT Standard Guidance
How TO DOWNLOAD THIS DOCUMENT ELECTRONICALLY FROM THE INTERNET
This document is electronically available through the EPA Public Access server at the
Manufacturing, Energy and Transportation Division Web site:
http://www.epa.gov/envirosense/oeca/metd/ref.html
ADDITIONAL RESOURCES
• Applicability Determination Index (ADI):
http://134.67.104.12/cfdocs/adiwww/adiwww.html-ssi
Additional information and guidance on the applicability of the MACT standard
can be obtained through the EPA's Applicability Determination Index (ADI). The
ADI is a database that contains memoranda issued by EPA on the applicability
and compliance issues associated with the New Source Performance Standards
(NSPS), National Emissions Standards for Hazardous Air Pollutants (with
categories for both NESHAP, Part 61, and MACT, Part 63), and
chlorofluorocarbons (CFC). Recently issued determinations are added to the
database on a quarterly basis.
• Manufacturing, Energy & Transportation Division:
http://www.epa.gov/envirosense/oeca/metd
The Manufacturing, Energy & Transportation Division (METD) is charged with
developing strategies and programs that help organize and better explain,
through inspection guidance and compliance monitoring techniques,
environmental requirements that affect the regulated community.
• Enviro$en$e: http://www.epa.gov/envirosense
CONTACT LIST
EPA Regional Contact List (see Appendix H)
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Petroleum Refinery MACT Standard Guidance
TABLE OF CONTENTS
1. Introduction 1-1
2. The Petroleum Refinery MACT Standard: An Overview 2-1
2.1 Applicability of the Rule 2-2
2.2 How Does a Facility Determine Which Emission Points the Control
Requirements Apply To? 2-3
2.3 What Are the Control Requirements? 2-5
2.4 When Must A Facility Comply? 2-6
3. General Standards 3-1
3.1 What are the Performance Testing Requirements That Must Be
Met By All Regulated Emission Points? 3-1
3.2 What are the Monitoring Requirements For All Regulated
Emission Points? 3-2
3.3 What are the Reporting Requirements For All Regulated Emission
Points? 3-2
3.3.1 What are the Requirements For Permit Applications? 3-3
3.3.2 What are the Requirements for Applications for Approval of
Construction or Reconstruction? 3-3
3.3.3 What are the Requirements for Notification of Compliance
Status (NCS)? 3-4
3.3.4 What are Periodic Reports, and When Are They Required? . . . 3-4
3.3.5 What are the Requirements for Startup, Shutdown, and
Malfunction Plan and Reports? 3-5
3.3.6 What are Reports Required for Special Situations 3-5
3.3.7 When can Facilities Submit Requests for Extension of
Compliance? 3-6
3.3.8 What are the Requirements for Applications for a Performance
Test Waiver? 3-6
3.4 What are the Recordkeeping Requirements? 3-7
4. Emission Points Subject to the Regulation 4-1
4.1 What are the Requirements for Miscellaneous Process Vents? 4-1
4.1.1 What are the Control Requirements for Miscellaneous
Process Vents? 4-1
4.1.2 What are the Testing Requirements for Miscellaneous
Process Vents? 4-2
4.1.3 What are the Monitoring Requirements for Miscellaneous
Process Vents? 4-4
4.1.4 What are the Reporting Requirements for Miscellaneous
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Process Vents? 4-6
4.1.5 What are the Recordkeeping Requirements for Miscellaneous
Process Vents? 4-10
4.2 What are the Requirements for Storage Vessels? 4-10
4.2.1 What are the Control Requirements for Storage Vessels? .... 4-11
4.2.2 What are the Testing Requirements for Storage Vessels? .... 4-12
4.2.3 What are the Monitoring and Inspection Requirements for
Storage Vessels? 4-12
4.2.4 What are the Reporting Requirements for Storage
Vessels? 4-14
4.2.5 What are the Recordkeeping Requirements for Storage
Vessels? 4-17
4.3 What are the Requirements for Wastewater Streams? 4-18
4.3.1 What are the Control Requirements for Wastewater
Streams? 4-18
4.3.2 What are the Testing Requirements for Wastewater
Streams? 4-19
4.3.3 What are the Monitoring Requirements for Wastewater
Streams? 4-19
4.3.4 What are the Reporting and Recordkeeping Requirements
for Wastewater Streams? 4-19
4.4 What are the Requirements for Gasoline Loading Racks? 4-19
4.4.1 What are the Control Requirements for Gasoline Loading
Racks? 4-19
4.4.2 What are the Testing and Monitoring Requirements for
Gasoline Loading Racks? 4-20
4.4.3 What are the Reporting and Recordkeeping Requirements
for Gasoline Loading Racks? 4-22
4.5 What are the Requirements for Marine Tank Vessels? 4-22
4.5.1 What are the Control Requirements for Marine Tank
Vessels? 4-22
4.5.2 What are the Testing and Monitoring Requirements for
Marine Tank Vessels? 4-22
4.5.3 What are the Reporting and Recordkeeping Requirements
for Marine Tank Vessels? 4-23
4.6 What are the Requirements for Equipment Leaks? 4-23
4.6.1 What are the Control Requirements for Equipment Leaks? . . . 4-23
4.6.2 What are the Testing, Inspection, and Monitoring
Requirements for Equipment Leaks? 4-23
4.6.3 What are the Reporting and Recordkeeping Requirements
for Equipment Leaks? 4-24
4.7 Emissions Averaging 4-24
4.7.1 Emissions Averaging Applicability 4-24
4.7.2 Emissions Averaging Credit/Debit System 4-25
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Page
4.7.3 Approval of Emissions Averaging Plan 4-26
4.7.4 Testing, Monitoring, Reporting, and Recordkeeping for
Emissions Averaging 4-26
4.7.5 Recordkeeping for Emissions Averaging 4-27
5. Interrelationship of the Petroleum Refinery MACT Standard with
Other Regulations 5-1
TABLES
Table 2-1 Applicability of the Petroleum Refinery MACT Standard 2-3
Table 2-2 Control Applicability Criteria for Emission Points 2-4
Table 2-3 Control Requirements for Process Units/Emission Points 2-5
Table 4-1 Monitoring Requirements for Combustion Devices 4-5
Table 4-2 Monitoring Requirements for Miscellaneous Process
Vents with Bypass Lines 4-5
Table 4-3 40 CFR Part 63, Subpart CC, Table 10 Parameters 4-7
Table 4-4 Additional Recordkeeping Requirements 4-10
Table 5-1 Overlap of the Petroleum Refinery MACT Standard
(40 CFR 63 Subpart CC) with Existing Regulations 5-4
FIGURES
Figure 2-1 Emission Points within an Affected Source
Figure 2-2 Determination of Applicability for Miscellaneous Process Vents
Figure 2-3 Determination of Applicability for Storage Vessels
Figure 2-4 Determination of Applicability for Wastewater Streams
Figure 2-5 Determination of Applicability for Gasoline Loading Racks
Figure 2-6 Determination of Applicability for Marine Tank Vessel Loading
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Page
Figure 2-7 Determination of Applicability for Equipment Leaks
APPENDICES
Appendix A. Hazardous Air Pollutants A-1
Appendix B. Organic Hazardous Air Pollutants B-1
Appendix C. U.S. Petroleum Refineries Affected by the Petroleum Refinery
Standards C-1
Appendix D. Additional Resources for Petroleum Refining MACT Standard
Enabling Document D-1
Appendix E. Definitions E-1
Appendix F. Checklist for the Petroleum Refinery MACT Standard F-1
Appendix G. Proposed Changes to the MACT Standard G-1
Appendix H. EPA Regions and Regional Contacts H-1
Appendix I. 1995 and 1996 EPA Memos re: Major Source Definitions 1-1
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I. INTRODUCTION
In August 1995, the United States Environmental Protection Agency (EPA) promulgated
the National Standards for Hazardous Air Pollutants (NESHAP) for petroleum refineries
that were originally proposed in July 1992. These standards require petroleum
refineries, that are major sources of Hazardous Air Pollutants (HAPs), to meet emission
standards reflecting the application of the maximum achievable control technology
(MACT). The affected sources at petroleum refineries are defined to include all process
vents, storage vessels, marine tank vessel loading operations, gasoline rack operations,
equipment leaks, and wastewater treatment systems located at the refinery. This
manual was developed to assist refineries in determining the applicability of these new
standards to their operations, and to provide guidance to assist facilities in achieving
and maintaining compliance.
The manual is presented in five chapters. Chapter 1 states the purpose, scope, and
layout of the document. Chapter 2 summarizes the major parts of the regulation,
applicability of the regulation to specific process units, applicable control requirements,
and processes not covered under the new rule. Chapter 3 discusses general standards
applicable to all process units. Chapter 4 builds on the general requirements, and
discusses requirements specific to each type of process unit and for facilities that use
emissions averaging. Finally, Chapter 5 shows where the new Petroleum Refinery
MACT standard overlaps with existing regulations.
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2. THE PETROLEUM REFINERY MACT STANDARD: AN OVERVIEW
The maximum achievable control technology (MACT) standard for petroleum refineries
stems from the Clean Air Act Amendments (the Act) of 1990. Under the Act, EPA is
required to regulate emissions of 188 listed hazardous air pollutants (HAPs), also
known as air toxics. On July 16, 1992, EPA published a list of source categories
(industry groups) that emit one or more of these HAPs. For listed categories of "major"
sources (those that emit 10 tons annually or more of a listed pollutant or 25 tons or
more of a combination of pollutants annually- see Appendix I of this document for
additional information on "major sources), the Act requires EPA to develop standards
that will require the application of maximum achievable control technology.
The list of industry groups to be regulated includes petroleum refineries, because they
are a major source of HAP emissions. Consequently, the MACT standard was
developed to help control this source of emissions.
The Petroleum Refinery MACT standard applies to petroleum refining process units and
related emission points. The standard MACT includes testing, monitoring, reporting,
recordkeeping, and control requirements. Requirements in the MACT standard include
control of HAP emissions from the following emission points within petroleum refining
process units: process vents, storage vessel loading, wastewater collection and
treatment systems, gasoline loading racks, marine tank vessel loading, and equipment
leaks. There are two general approaches to comply with the MACT standard's control
requirements:
(1)
(2)
Implement controls on all emission points that meet the criteria for control in the
rule; or
Use a method called emissions averaging.
This method allows the facilities flexibility to
choose certain emission points for control in
order to achieve the required emissions
reductions in the most cost-effective
manner. In some situations, facilities may
find it more cost-effective to overcontrol
certain emission points and undercontrol
others, so that the overall result would be
greater emissions reductions at less control
cost. The MACT standard spells out how
facilities may use emissions averaging and
which emission points may be included.
This approach can only be used for existing
sources. A detailed explanation of
emissions averaging is found in Chapter 4 of this manual.
Who Will Be Affected By
The Petroleum Refinery
MACT Standard?
There are approximately 165
petroleum refineries as of
January 1, 1997 in the United
States, all of which are
anticipated to be major
sources of HAPs, and
therefore, may be subject to
this regulation.
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Under the Petroleum Refinery MACT standard, the term "source" refers to
the entire refinery, whereas under New Source Performance Standards
(NSPS) and State Implementation Plans (SIPs), sources are most
commonly process units. The MACT standard applies only to major
sources. Under the MACT standard, there are different requirements depending on
whether the facility is an existing source or a new source. The MACT Standard defines
existing and new sources as follows:
Existing sources - sources that commenced construction on or before July 14, 1994;
New sources - sources that commenced construction after July 14, 1994. A process
unit constructed at an existing source is subject to new source requirements if the new
unit has the potential to emit 10 tons per year (tpy) or more of any one HAP or 25 tpy or
more of total HAPs. Otherwise it is subject to the requirements applicable to existing
sources. A change to an existing source or an addition of an emission point is subject
to existing source standards, unless it is a reconstructed source, which is subject to new
source standards.
This chapter provides an overview of the major elements of the rule, including general
applicability, control requirements, and compliance deadlines. General information on
testing, monitoring, reporting, and recordkeeping is given in Chapter 3 and a detailed
discussion of individual emission points is found in Chapter 4.
2.I
APPLICABILITY OF THE RULE
The affected source is the combination of all the emission points located at a refinery,
and each point is considered part of the single affected source. The MACT standard
also applies only to major sources as defined by Section 112(a) of the Clean Air Act
with the potential to emit hazardous air pollutants. For clarification on whether a source
is a major source, see Appendix E. Figure 2-1 gives an example of each of the
FIGURE 2-1. Emission Points Withi
ffected Source
Marine Tank
Vessel Loadim
Gasoline
Loading
Rack
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Petroleum Refinery MACT Standard Guidance
emission points within an affected source. TABLE 2-1 presents the emission points to
which the Petroleum Refinery MACT standard applies. If any of the points in TABLE 2-
1 is not located at the refinery, the MACT standard does not apply.
TABLE 2-1. Applicability of the Petroleum Refinery MACT Standard
The Rule Applies To
The Rules Does Not Apply To
Refineries that are major HAP sources under
either of the following definitions:
- Potential to emit > 10 tons per year (tpy) of
any of the 188 HAPs in Appendix A of this
manual; or
- Potential to emit > 25 tpy of total HAPs
Refining process units at refineries that are
major sources and emit or contain any of the 28
HAPs in Appendix B of this manual
The following emission points within petroleum
refining process units at major sources:
- Miscellaneous process vents that contain >
20 ppmv total organic HAP
- Storage vessels (pressure vessels and
vessels < 40 m3 are exempt)
- Wastewater streams and treatment
operations
- Equipment containing or contacting a fluid is
> 5% by weight total organic HAPs.
The following emission points if located at
refineries that are major sources:
- Marine vessel loading operations
- Gasoline loading racks in SIC 2911
- Storage vessels and equipment leaks
associated with bulk gasoline terminals in
SIC 2911.
Refineries that are not major HAP sources
Equipment that does not emit or contain any of
the HAPs in Appendix B of this manual
Catalytic cracking and reforming catalyst
regeneration vents
Sulfur recovery plant vents
Research and development facilities
Units processing natural gas
Units for recycling discarded oil
Shale oil extraction units
Ethylene processes
Units subject to the hazardous organic
NESHAP (HON) [40 CFR 63 Subparts F, G, H,
and I]
Storm water from segregated storm water
sewers
Spills
Equipment in organic HAP service < 300 hours
during the calendar year.
2.2 How DOES A FACILITY DETERMINE THE EMISSION POINTS TO WHICH THE
CONTROL REQUIREMENTS APPLY?
The introduction to this chapter presented how a facility determines if it is classified as
an existing or new source. Once this determination has been made, a facility must
assess whether it meets the criteria for requiring controls on its emission points. TABLE
2-2 presents the control applicability criteria for each type of emission point. Emission
points that meet these criteria are called Group 1 emission points, while all other
emission points are called Group 2 emission points. Group 1 emission points are
subject to all applicable requirements of the MACT standard. Group 2 emission
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Petroleum Refinery MACT Standard Guidance
points are not subject to the control or monitoring requirements of the MACT
standard. However, Group 2 emission points are subject to certain recordkeeping
requirements.
TABLE 2-2. Control Applicability Criteria for Emission Points
Emission
points
Miscellaneous
Process Vents
For Existing Sources, Controls Must
Be Used If:
(1) Organic HAP concentration > 20
ppmv, and
(2) Total VOC emissions > 33 kg/day.
(1) Organic HAP concentration > 20
ppmv, and
(2) Total VOC emissions > 6.8 kg/day.
Storage
Vessels
(1) Capacity > 177 m3, and
(2) Vapor pressure > 10.4kPa
(maximum) and > 8.3 kPa (annual
average), and
(3) Organic liquid HAP concentration >
4% by weight (annual average).
(1) Capacity> 151 m3, and
(2) Vapor pressure > 3.4 kPa
(maximum), and
(3) Organic liquid HAP concentration >
2% by weight (annual average).
OR
(1) Capacity > 76 and < 151 m3, and
(2) Vapor pressure > 77 kPa (maximum),
and
(3) Organic liquid HAP concentration >
2% by weight (annual average).
Wastewater
Streams
(1) Total annual benzene loading > 10
megagrams per year, and
(2) Flow rate > .02 liters per minute, and
(3) Benzene concentration > 10 ppm by
weight, and
(4) Not exempt from controls under 40
CFR61 SubpartFF.
(1) Total annual benzene loading > 10
megagrams per year, and
(2) Flow rate > .02 liters per minute, and
(3) Benzene concentration > 10 ppm by
weight, and
(4) Not exempt from controls under 40
CFR61 SubpartFF.
Gasoline
Loading
Racks
Part of bulk gasoline terminal located at
facilities designated under SIC 2911 with
gasoline throughput > 75,700 liters per
day.
Part of bulk gasoline terminal located at
facilities designated under SIC 2911 with
gasoline throughput > 75,700 liters per
day.
Marine Tank
Vessel
Loading
(1) Vapor pressure of liquid loaded >
10.3 kPa, and
(2) Emission > 9.1 megagrams of any
HAP or > 22.7 megagrams of total
HAP per year after August 18, 1999.
(1) Vapor pressure of liquid loaded >
10.3kPa
(2) No parallel emission rate cutoffs for
new sources.
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Petroleum Refinery MACT Standard Guidance
Emission
points
Equipment
Leaks
For Existing Sources, Controls Must
Be Used If:
Equipment containing or contacting fluid
that is 5% by weight total organic HAPs.
For New Sources, Controls Must Be
Used If:
Equipment containing or contacting fluid
that is 5% by weight total organic HAPs.
Included at the end of this chapter in Figure 2-2 through 2-6 are decision flowcharts
which show how a facility can determine first if it is subject to the MACT standard, and
second if Group 1 or Group 2 requirements apply. Decision flowcharts have been
included for each emission point that is potentially subject to the MACT standard (i.e.,
miscellaneous process vents, storage vessels, wastewater streams, gasoline loading
racks, marine tank vessel loading, and equipment leaks).
2.3 WHAT ARE THE CONTROL REQUIREMENTS?
TABLE 2-3 summarizes the control requirements for emission points meeting the
criteria in TABLE 2-2. Please note that while TABLE 2-3 provides an inclusive (as
of September 1997) summary of the control requirements for these emissions
points, specific requirements can be found in the referenced section of the Code
of Federal Regulations.
2.4 WHEN MUST A FACILITY COMPLY?
The MACT standard specifies the dates by which each emission point at new and
existing sources must be in compliance with the control requirements. All emission
points at new sources must be in compliance at startup or by August 18, 1995,
whichever is later.
There is a specific compliance date for each emission point at existing sources.
Miscellaneous process vents and gasoline loading racks have a compliance date of
August 18, 1998. Wastewater streams also have a compliance date of August 18,
1998, and sources should be in compliance with the benzene waste operations
NESHAP found in 40 CFR 61 Subpart FF.
Fixed roof storage vessels must be in compliance by August 18, 1998 as well; however,
the preamble suggests compliance by August 18, 1999 if the tank must be replaced.
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TABLE 2-3. Control Requirements for Process Units/Emission Points
Emission points
Miscellaneous Process
Vents
Reduce organic HAPs by 98% or to 20 ppmv using incinerators,
boilers, process heaters, or other devices; or
Use a flare.
Storage Vessels
Comply with storage vessel NESHAP [40 CFR 63 Subpart G], which
requires:
Internal floating roof with specified seals; or
External floating roof with specified seals; or
External floating roof converted to internal floating roof with
specified seals; or
Closed vent system with 95% efficient control device.
Wastewater Streams
Comply with benzene waste operations NESHAP [40 CFR 61
Subpart FF], which requires:
Reducing benzene mass emissions by 99% using suppression
followed by another treatment process (e.g., steam stripping or
biotreatment); and
Reducing emissions from vents from stream strippers, other
waste management, or treatment units by 95% with a control
device or to 20 ppmv at the outlet of the control device.
Gasoline Loading Racks
Comply with gasoline distribution NESHAP [40 CFR 63 Subpart R],
which requires:
Reducing emissions of total organic compounds to 10 milligrams
per liter of gasoline loaded; and
Loading only in vapor tight cargo tanks that have been tested to
assure vapor tightness.
Marine Tank Vessel
Loading
Comply with marine tank vessel loading NESHAP [40 CFR 63
Subpart Y], which requires:
Reducing HAP by 97% for existing sources
Reducing HAP by 98% for new sources.
Equipment Leaks
Comply with equipment leak rules [40 CFR 63 Subpart H or 40 CFR
60 Subpart VV] for existing sources and [40 CFR 63 Subpart H] for
new sources, which require:
Leak detection and repair with specified leak definitions and
monitoring frequencies
Equipment specifications for some types of equipment.
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FIGURE 2-2. Determination of Applicability for Miscellaneous Process Vents
Does the vent contain a gas stream with > 20 ppm by volume organic HAP and is it
continuously or periodically discharged during normal operations?
1 No
Yes
Is the vent/gas stream:
- directly discharged to the atmosphere or
- routed to a control device prior to discharge to the atmosphere or
- diverted to a product recovery prior to control or discharge to the atmosphere?
Note: The above list gives examples of vent or gas streams and may not be all inclusive.
. No
Yes
Does the vent or gas stream come from:
- Gas streams routed to a fuel gas system
- Relief valve discharges
- Leaks from equipment regulated under 40 CFR 63.648
- Episodic or nonroutine releases such as maintenance or upsets
- In situ sampling systems (onstream analyzers)
- Catalytic cracking unit catalyst regeneration vents
- Catalytic reformer regeneration vents
- Sulfur plant vents
- Vents from control devices
63 Subpart CC, G, or FF
testing after decoking
- Vents from storage vessels
- Emissions from wastewater collection and conveyance systems?
\
No
-Yes-
Does the vent or gas stream come from: caustic wash accumulators, distillation lower condensers/
accumulators, blowdown condensers/accumulators, and delayed coker vents?
Wofe: The above list gives examples of where vent or gas streams may originate and may not be all inclusive.
• No
Yes
Is vent associated with an existing or new source?
-Existing-
Existing Source:
Is organic HAP concentration > 20 ppmv, and
total VOC emissions > 33 kg/day?
-Yes-
-NO'
Group 1 miscellaneous
process vent*
Group 2 miscellaneous
process vent*
- New-
New Source:
Is organic HAP concentration > 20 ppmv, and total
VOC emissions > 6.8 kg/day?
Yes-
-No-
Group 1 miscellaneous
process vent*
Group 2 miscellaneous
process vent*
* See Chapter 4 for applicable requirements for Group 1 and Group 2 emission points.
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FIGURE 2-3. Determination of Applicability for Storage Vessels
Storage vessels
provision does
not apply
Is it a tank or other vessel that is used to
store organic liquids? (i.e., is this a storage
vessel "as described in the rule"?)
\
Yes
_*_
Is it permanently attached to a
motor vehicle such as a truck,
railcar, barge or ship?
\
No
_*_
Yes
Is it a pressure vessel designed to operate
in excess of 204.9 kilopascals and without
emission to the atmosphere?
\
No
_*_
Yes
Does it have a capacity less than
40 cubic meters?
\
No
Is it used as a bottoms receiver
tank?
\
No
_*_
Yes
Yes
Is it used as a wastewater
storage tank?
\
No
_*_
Yes
Is tank associated with an
existing or new source?
-Existing-
-New-
Existing Source:
Is capacity > 177 m3 and vapor pressure > 10.4
kPa (maximum) and > 8.3 kPa (annual average)
and liquid HAP content > 4% by weight
(annual average)?
•Yes-
-No
New Source:
Is capacity > 151 m3 and vapor pressure > 3.4 kPa
(maximum), and liquid HAP content > 2% by weight
(annual average)?
OR
Is capacity between 76 and 151 m3, and vapor
pressure > 77 kPa (maximum), and liquid HAP >2%
by weight (annual average)?
-Yes-
_L
Group 1 storage
vessel*
Group 2 storage
vessel*
Group 1 storage
vessel*
Group 2 storage
vessel*
' See Chapter 4 for applicable requirements for Group 1 and Group 2 emission points.
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FIGURE 2-4. Determination of Applicability for Wastewater Streams
Is it water or wastewater that, during production or processing:
Comes into direct contact with or results
from the production or use of any raw
material, intermediate product, finished
product, byproduct, or waste product?
-No-
Yes
Is discharged into any individual drain
system?
-No-
Wastewater provision
does not apply
Yes
I
Does refinery have a total annual benzene
loading> 10 megagrams peryear.and a
flow rate > 0.02 liters per minute, and
benzene concentration^ 10 ppm by
weight, and subject to control requirements
under 40 CFR 61 Subpart FF?
1
r
Group 1 wastewater
stream*
Applicability
criteria are the
same for
existing and
new sources
i
r
Group 2 wastewater
stream*
[Examples of wastewater are: feed tank drawdown; water formed during a chemical reaction or used as a
reactant; water used to wash impurities from organic products or reactants; water used to cool or quench
organic vapor streams through direct contact; and condensed steam from jet ejector systems pulling vacuum
on vessels containing organics.]
' See Chapter 4 for applicable requirements for Group 1 and Group 2 emission points.
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FIGURE 2-5. Determination of Applicability for Gasoline Loading Racks
Is it any of the following:
loading arms, pumps, meters, shutoff valves
relief valves, or
other piping and valves necessary to fill
gasoline cargo tanks?
-No-
Yes
Is it a gasoline loading rack
classified under SIC 2911 ?
•No-
Gasoline loading racks
provision does not apply
Yes
Does it have a gasoline throughput >
75,700 liters (20,000 gallons) per day?
1
r
Group 1 gasoline
loading rack*
Applicability
criteria are the
same for
existing and
new sources
1
r
Group 2 gasoline
loading rack*
See Chapter 4 for applicable requirements for Group 1 and Group 2 emission points.
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FIGURE 2-6. Determination of Applicability for Marine Tank Vessel Loading
Is it a land- or sea-based terminal or
structure that loads liquid commodities in
bulk onto marine tank vessels?
-No-
Marine tank vessel
loading provision
does not apply
Yes
1
Is marine tank vessel loading associated
with an existing or new source?
-Existing-
- New-
Existing Source:
Is vapor pressure of liquid loaded> 10.3 kPa and
emissions > 9.1 megagrams of any one HAP or >
22.7 megagrams of total HAP per year?
1
r
Group 1 marine tank
vessel loading*
New Source:
Is vapor pressure of liquid loaded> 10.3 kPa?
1
r
Group 2 marine tank
vessel loading*
i
r
Group 1 marine tank
vessel loading*
^
r
Group 2 marine tank
vessel loading*
' See Chapter 4 for applicable requirements for Group 1 and Group 2 emission points.
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FIGURE 2-7. Determination of Applicability for Equipment Leaks
Is it a vent from a wastewater system
drain, tank mixer or sample valve on a
storage tank?
-Yes-
No
Is it an emission of organic hazardous air
pollutants from a pump, compressor,
pressure relief device, sampling connection
system, open-ended valve or line, valve,
or instrumentation system "in organic
hazardous air pollutant service" (equipment
containing or contacting fluid > 5% by
weight total organic HAP)?
•No-
Yes
Equipment leaks provision applies
* See Chapter 4 for applicable requirements for Group 1 and Group 2 emission points.
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Floating roof storage vessels have a compliance date of August 18, 2005, or the next
scheduled maintenance and degassing after August 18, 1998, whichever is first.
Marine tank vessel loading must be in compliance by August 18, 1999, unless used in
emissions averaging. If used to generate credit in an emissions average, it must
comply by August 18, 1998, unless a case-by-case 1-year extension is granted.
A compliance date of August 18, 1998 is set for equipment leaks. Sources have the
option of complying with 40 CFR 60 Subpart W or 40 CFR 63 Subpart H, which allows
for 3 phases of emissions reductions. (See Chapter 4 for more detailed information on
compliance dates for equipment leaks.)
2.5 CONCLUSIONS
Chapter 2 provided an overview of the MACT Standard answering the questions of
which facilities must comply; what facilities must do to comply, and when must they
comply. The overview defined the applicability of the MACT Standard to affected
sources, and the various types of emission points associated with the affected sources.
Chapter 2 also defined the control requirements applicable to the various emission
points, noting which points are required to maintain control equipment, and the types of
control or associated emission limit. Finally, Chapter 2 provided compliance deadlines
for each category of emission point. After reviewing the applicability determination flow
charts in Chapter 2, a facility should be able to determine whether the general
requirements to be discussed in Chapter 3, or the specific requirements in Chapter 4
will apply.
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3. GENERAL STANDARDS
Once the refinery has determined which of its emission points are required to comply
with the Petroleum Refinery MACT standard (MACT standard), the refinery must
determine the specific requirements applicable to each emission point. While the
control requirements are specific to each type of emission point at the refinery, the
MACT standard also contains general provisions
that are applicable to all emission points. These
general requirements include performance _ , . . , „
testing, monitoring, reporting, and recordkeeping. General requ.rements for all
In addition, some reporting requirements apply em'ssion P°'nt*mclude; .
only to refineries conducting certain activities. performance testing, monitoring,
reporting (including permit
Chapter 3 discusses the general requirements applications and notifications of
applicable to all emission points at refineries. compliance status), and
Chapter 4 describes the control requirements recordkeeping.
applicable only to specific emission points, as well
as emissions averaging - an alternative method
to controlling emissions.
3.1 WHAT ARE THE PERFORMANCE TESTING REQUIREMENTS THAT MUST BE MET
BY ALL REGULATED EMISSION POINTS?
All facilities are required to conduct an initial performance test of certain pollution control
equipment. (No performance tests are required for floating roofs or process heaters >
44 MWwith vent introduced into the flame zone.) These initial performance tests must
be approved by EPA. To conduct the test, the facility must:
• Notify regulatory authority 30 days prior to conducting a performance test [40 CFR
63.642(d)(2)]
• Conduct tests at maximum representative operating capacity, with controls operating
at either maximum or minimum representative operating conditions for monitored
parameters, whichever result in lower emission reduction [40 CFR 63.642 (d)(3)].
3.2 WHAT ARE THE MONITORING REQUIREMENTS FOR ALL REGULATED EMISSION
POINTS?
Monitoring is required for some Group 1 emission points. Requirements range from
once an hour for miscellaneous process vents routed to a flare, to no monitoring
requirements for Group 1 storage vessels equipped with an external floating roof.
Specific monitoring requirements for each process unit are presented in Chapter 4.
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3.3 WHAT ARE THE REPORTING REQUIREMENTS FOR ALL REGULATED EMISSION
POINTS?
Reporting requirements range from permit applications, and initial notification of
compliance status, to those requesting compliance extensions. With the exception of
periodic reports, all reports are one-time submittals, or one time per incident submittals.
The following types of information/reports must be submitted, where applicable, for each
emission point to the appropriate EPA Regional Office [40 CFR 63.13](See Appendix H
for a list of EPA Regional Offices):
• Permit Applications
• Applications for Approval of Construction or Reconstruction
• Notification of Compliance Status
• Periodic Reports
• Startup, Shutdown, and Malfunction Reports
• Reports Required for Special Situations
• Requests for Extension of Compliance
• Applications for a Performance Test Waiver.
Each of these requirements is presented in the following subsections.
3.3.I WHAT ARE THE REQUIREMENTS FOR PERMIT APPLICATIONS?
All owners or operators of a source subject to
the rule are required to apply for a one-time
Part 70 or Part 71 operating permit from the
appropriate authority. A source may apply for
the permit from either EPA or its State
authority, depending on whether EPA has
approved a State operating permit program.
[40 CFR 63.642(a)]
The source must apply for a permit
from its state if EPA has approved
a State operating permit program
under Part 70. The source must
apply for a permit from its EPA
Regional Office if the State does
not have an EPA operating permit
program under Part 71.
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3.3.2 WHAT ARE THE REQUIREMENTS FOR
APPLICATIONS FOR APPROVAL OF
CONSTRUCTION OR RECONSTRUCTION?
All new or reconstructed sources are
required to submit an application for
approval of construction or reconstruction.
Existing sources are not required to submit
the application, unless new construction or
reconstruction occurs at the source.
General application requirements include
[40 CFR 63.5(d)]:
• Applicant's name and address
• Notification of intent to construct a new
major affected source
• Source description and address
• Identification of relevant standard that
is the basis of the application
Construction means the on-site
fabrication, erection, or installation of
an affected source.
Reconstruction means the
replacement of components of an
affected or a previously unaffected
stationary source to the extent that:
(1) The fixed capital cost of the new
component exceeds 50 percent
of the fixed capital cost that
would be required to construct a
comparable new source; and
(2) It is technologically and
economically feasible for the
reconstructed source to meet
the relevant standard(s)
established by the Administrator
(or a state) pursuant to section
112 of the Clean Air Act.
• Expected commencement and
completion dates of construction or reconstruction
• Anticipated date of startup
• Determination of rule applicability for each process unit (e.g., distillation units,
storage vessels, flexible operation units)
• Actual or expected type and quantity of HAPs emitted
• Additional relevant information as requested by the Administrator.
3.3.3 WHAT ARE THE REQUIREMENTS FOR NOTIFICATION OF COMPLIANCE STATUS (NCS)?
All refineries are required to inform EPA of their compliance status with respect to the
MACT standard. Facilities must submit a NCS report within 150 days after each
applicable compliance deadline. (See Section 2.4 of this manual for compliance dates.)
The report must identify each emission point and method of compliance. This
information may be included as a separate report, as an operating permit application, or
in an amendment to an operating permit application. [40 CFR 63.654(f)] NCS report
requirements include the following:
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• Information on individual emission points to demonstrate compliance, such as range
of monitored parameters. [40 CFR 63.654(f)(1) and (f)(3)]
• Results of continuous monitoring system performance evaluations. [40 CFR
63.654(f)(4)]
• If initial performance tests are required, one example complete test report for each
test method used must be submitted. For additional tests using the same method,
only the results must be submitted. [40 CFR 63.654 (f)(2)]
3.3.4 WHAT ARE PERIODIC REPORTS, AND WHEN ARE THEY REQUIRED?
Periodic reports are required only if compliance exceptions occur within any 6-month
reporting period. If compliance exceptions do occur, periodic reports must be
submitted. The reports must be submitted within 60 days after the end of each 6-
month period. If facilities use emissions averaging, reports must be submitted quarterly.
[40 CFR 63.654(g)]
Periodic reports must include information on compliance exceptions, such as a
description and cause of the exception and corrective action taken. (See Chapter 4 for
each type of emission point.) If a performance test is done for an emission point that is
added or changed from Group 2 to Group 1, include the results, such as percent
emissions reduction or concentration, in the next periodic report. [40 CFR 63.654(g)(7)]
3.3.5 WHAT ARE THE REQUIREMENTS FOR STARTUP, SHUTDOWN, AND MALFUNCTION PLAN
AND REPORTS?
All refineries must develop and implement a startup,
shutdown, and malfunction plan for the entire facility.
The malfunction plan must describe procedures for
operating and maintaining the source during periods
of startup, shutdown, and malfunction. In addition,
the plan must include a program of corrective action
for malfunction of process and air pollution control
equipment used to comply with the relevant
standard. EPA typically defines malfunctions as
rare, unforeseeable occurrences and does not allow
for facilities to operate in malfunction for extended
periods of time.
If corrective actions to address the malfunction are
consistent with the startup, shutdown, and
malfunction plan, submit a statement to this effect in
the semi-annual report. [40 CFR 63.10(d)(5)(l)]
A Startup, Shutdown, and
Malfunction Report is
required to document:
• The start of operation of a
process unit for production
• The cessation of a process
unit for maintenance,
repair, or equipment
replacement
• Any malfunction of a
process unit.
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If a malfunction occurs and corrective actions are not consistent with the startup,
shutdown, and malfunction plan, the following must be done after each malfunction [40
CFR63.10(d)(5)(ii)]:
/ Call the regulatory authority within 2 days after inconsistent corrective actions
commence.
/ Submit a letter within 7 days containing:
- Circumstances of the event
- The reasons for not following the startup, shutdown, and malfunction plan
- Whether any excess emissions and/or parameter monitoring exceedances
occurred.
If a malfunction does not occur during a reporting period, a startup, shutdown, and
malfunction report is not required.
3.3.6 WHAT ARE REPORTS REQUIRED FOR SPECIAL SITUATIONS?
The MACT standard has detailed requirements for testing, monitoring, and
recordkeeping. However, the rule allows for flexibility in meeting these requirements. If
facilities intend to use alternative procedures or devices, additional reports and
approvals are required. For these facilities, the following information must be submitted
18 months before the compliance date for existing sources, or with the application for
approval of construction for new sources:
• Determination of rule applicability to flexible operation units and storage vessels and
distillation units for which use varies from year to year [40 CFR 63.654(h)(6)]
• Request for approval to monitor an alternative control device operating parameter,
with supporting justification [40 CFR 63.654(h)(4)]
• Request for approval to use data compression systems instead of keeping hourly
records, with supporting information [40 CFR 63.654(h)(5)]
• Request to use other alternative monitoring methods, with supporting justification [40
CFR 63.654(h)(5)(iv) and 63.8(f)(4)(ii)]
• Request to establish an alternative emission standard, with a test plan or results of
testing and monitoring. [40 CFR 63.6(g)(2)] (If EPA finds the alternative standard
equivalent to the MACT standard, EPA will request public comment and publish a
Federal Register notice allowing its use.)
3.3.7 WHEN CAN FACILITIES SUBMIT REQUESTS FOR EXTENSION OF COMPLIANCE?
An extension of compliance may be requested if emission reductions have been
achieved early, or if the source is unable to comply with the relevant standard.
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Requests for extension of compliance are allowed only for existing sources and must be
submitted at least 12 months before the compliance date, or 18 months prior if
emissions averaging is used. [40 CFR 63.6(l)(2-3)] (See Chapter 2, Section 2.4 for
compliance dates.) Requests must include the following:
• Description of controls to be installed
• Compliance schedule
• Interim emission control steps.
3.3.8 WHAT ARE THE REQUIREMENTS FOR APPLICATIONS FOR A PERFORMANCE TEST WAIVER?
If a facility is unable to conduct a performance test for reasons such as technical or
economic infeasibility, an extension of compliance has been requested, or other
reasons, the facility must submit an application for waiver of a performance test to the
Administrator. The application must include information justifying the request and
detailing the infeasibility. [40 CFR 63.7(h)(3)(iii)]
3.4 WHAT ARE THE RECORDKEEPING REQUIREMENTS?
All refineries are required to keep records of reports submitted, monitoring results, and
other records for at least 5 years. [40 CFR 63.642(e) and 63.654(l)(4)] In addition,
records must be kept so that they are accessible within 24 hours of request in either
hard copy or computer-readable form. If acceptable to the Administrator, reports may
be submitted on electronic media. [40 CFR 63.642(e)] The following records must be
maintained on site:
• Records of the occurrence and duration of each startup, shutdown, or malfunction of
operation and air pollution control equipment [40 CFR 63.10(b)(2)(l-ii)]
• Records of actions that are consistent and inconsistent with the startup, shutdown,
and malfunction plan [40 CFR 63.10(b)(2)(iv-v)]
• Records of continuous monitoring system calibration checks (if continuous
monitoring is required) [40 CFR 63.10(b)(x)]
• Records for storage vessels [40 CFR 63.654(l)(1)]
• Complete test reports and reported results for any required performance tests
[64.654(l)(2)]
• Values of continuously monitored parameters [40 CFR 63.654(l)(3)]
• Any additional records required by permit.
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3.5 CONCLUSIONS
Chapter 3 discussed the general requirements of the MACT Standard (i.e., those
requirements applicable to all regulated emission points). The chapter presented the
requirements for performance testing, monitoring, reporting, and recordkeeping that
apply to all regulated emission points. For each of these requirements, Chapter 3
discussed only those requirements that apply to every emission point. Additional
requirements applicable to individual emission points are discussed in Chapter 4.
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4. EMISSION POINTS SUBJECT TO THE REGULATION
This chapter summarizes the detailed testing, monitoring, reporting and recordkeeping
requirements specific to each emission point regulated by the MACT standard. In
addition, control requirements for each emission point are described. Unless otherwise
noted, the requirements in Chapter 4 apply only to Group 1 emissions points. With few
exceptions, Group 2 emissions points are subject only to record keeping requirements.
Chapter 4 discusses each of the regulated emission points (i.e., miscellaneous process
vents, storage vessels, wastewater streams, gasoline loading racks, marine tank vessel
loading, and equipment leaks) presenting the applicable requirements. Chapter 4
concludes with a discussion emissions averaging and how this technique can be used
by existing sources in lieu of complying with the applicable control requirements for the
individual emission points. Please note that this chapter does not discuss the
details of all of the MACT Standard requirements for each of these regulated
emissions points. In particular, in the discussion of storage vessels, wastewater
streams, gasoline loading racks, marine tank vessels and equipment leaks this chapter
references other sections of the federal code of regulations to which the refinery may be
required to comply. For further detail on the referenced sections, see the
appropriate section of the Code of Federal Regulations.
4.I WHAT ARE THE REQUIREMENTS FOR MISCELLANEOUS PROCESS VENTS?
Once the refinery has determined which process vents are subject to the MACT
standard, the refinery must then determine the requirements applicable to each vent.
These requirements include controls, monitoring, reporting, and recordkeeping. To
determine if a process vent is subject to the MACT standard, refer to the applicability
flowchart for miscellaneous process vents in Chapter 2.
4.I.I WHAT ARE THE CONTROL REQUIREMENTS FOR MISCELLANEOUS PROCESS VENTS?
If a vent meets the applicability criteria, it must be controlled by:
• Using a flare; or
• Reducing organic HAPs by 98% or to 20 ppmv using incinerators, boilers, process
heaters, or other devices; or
• If a boiler or process heater is used, the vent stream must be introduced into the
flame zone of the control device, or in a location such that the required percent
reduction or concentration is achieved.
The following sections discuss the applicable testing, monitoring, reporting and
recordkeeping requirements associated with each of these control methods.
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4.1.2 WHAT ARE THE TESTING REQUIREMENTS FOR MISCELLANEOUS PROCESS VENTS?
The MACT standard requires that
miscellaneous process vents be controlled
by routing the vents to a flare, incinerator,
boiler, process heater, other approved
device, or bypass lines. Some control
devices for miscellaneous process vents are
required to be tested during a one-time
initial performance test, and in follow-up
tests in the event of process changes. This
performance test must confirm that control
equipment is operating properly, and that
emissions are within specified limits. While
some of the components of the test are
similar for all miscellaneous process vents,
the MACT standard also applies testing requirements based on the control device as
described below.
Miscellaneous Process Vents are
to be Controlled if:
• It is an existing source, and the
vent contains 20 ppmv or more of
organic HAPs, and emits 33
kg/day or more of VOCs
• It is a new source, and the vent
contains 20 ppmv or more of
organic HAPs, and emits 6.8
kg/day or more of VOCs.
INITIAL PERFORMANCE TESTS
Initial performance tests are required for vents routed to a flare and vents using other
approved control devices. When performance tests are required, the test measures
whether equipment is operating according to manufacturer specifications, or whether
equipment is meeting a specified emissions reduction. Vents routed to a flare have
testing requirements designed to measure whether equipment is operating properly,
while other categories of process vents must have more sophisticated equipment that
measures the level of emissions from each controlled vent. Performance tests are not
required to determine percent
reduction when a flare is used.
For vents routed to a flare, the initial
performance test must show that the
flare is operating properly, and that
the emission rate does not exceed
the capacity of the flame to control
the emissions. Based on these
criteria, the initial performance test is
required to measure the following:
• Emissions visibility (There should
be no visible emissions.)
• Net heat value of combusted gas.
Performance tests are not required for:
• Vents routed to a boiler or process heater
>44MW(150MMBtu/hr)
• Vent streams that are introduced into the
flame zone of the boiler or process heater
• A control device for which a performance
test was conducted for determination of
compliance with an NSPS if no process
changes have been made.
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• Flow rate of gases being combusted.
For vents routed to an incinerator or a boiler or process heater < 44 Megawatts (MW)
(150 MMBtu/hr) where the vent streams are not introduced into the flame zone of the
boiler or process heater, the initial performance test must show compliance with the
requirement to reduce organic HAPs by 98% or to 20 ppmv. [40 CFR 63.645 and
63.116 except (d) and (e)]. The organic HAP concentration and percent reduction may
be measured either as total organic HAP or as total organic compounds (TOC) minus
methane and ethane. The sampling point varies depending on whether the facility is
measuring total organic HAP or TOC.
Determining Compliance Using Total Organic HAP
Sample sites must be located at both the inlet and
outlet of the control device, but the inlet sampling
site must be located after the final product recovery
device. If a process vent stream is introduced with
the combustion air or as a secondary fuel into a
boiler or process heater with a design capacity <
44 MW, selection of the location of the inlet
sampling site is required to ensure the
measurement of total organic HAP or TOC (minus
methane and ethane) concentrations in all process
vent streams and primary and secondary fuels
introduced into the boiler or process heater.
Calculating the TOC
Emissions Rate:
TOC can be calculated using
Method 18 or Method 25A of
40 CFR 60 Appendix A, or any
other method or data validated
according to the protocol in
Method 301 of 40 CFR 63
Appendix A. When selecting
the sampling site, refineries
are required to use Test
Methods 1 or 1 A of 40 CFR
60 Appendix A, as appropriate.
Additional guidance on using
these methods can be found in
40 CFR 63(f), (g), and (h).
Determining Compliance Using TOC
As noted above, for vents that must show organic
HAP reduction, owners and operators can measure
that reduction either as total organic HAP or as
TOC minus methane and ethane. To measure the
reduction as TOC minus methane and ethane, the
refinery first must determine TOC according to the
procedures specified below.
Samples must be taken:
After the last product recovery device, but
Prior to the inlet of any control device, and
Prior to any dilution of the process vent stream and release to the atmosphere.
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Test Method 1 describes appropriate testing for sample and velocity traverses for
stationary sources. Test Method 1A describes appropriate testing for sample and
velocity traverses for stationary sources with small stacks or ducts. Traverse site
selection methods are not needed for vents smaller than 0.10 meter in diameter.
FOLLOW-UP TESTS TO PROCESS CHANGES
For Group 2 process vents, whenever the
refinery conducts a process change, the TOC
emission rate must be recalculated to
determine whether the vent remains a Group 2
process vent or becomes a Group 1 process
vent. Recalculation may be based on vent
stream flow rate and TOC measurements as
specified for initial performance tests or best
engineering assessment practices.
4.I.3 WHAT ARE THE MONITORING
REQUIREMENTS FOR MISCELLANEOUS
PROCESS VENTS?
Monitoring devices are not required for boilers
or process heaters > 44MWor in which all vent
streams are introduced into the flame zone. The type and frequency of monitoring
depends on the type of combustion device. All continuous monitoring devices must be
installed, calibrated, maintained, and operated according to manufacturer specifications.
Table 4-1 lists the type of monitoring required for each combustion device. Refineries
with Group 1 miscellaneous process vents may request approval to monitor parameters
other than those listed in Table 4-1 if the refinery uses a control device other than an
incinerator, boiler, process heater, or flare, or wants to monitor a parameter other than
those specified in the table. Refineries that use a vent system with bypass lines have
separate requirements that are described in Table 4-2.
For facilities using other approved control devices, or requesting to monitor other
parameters, a site-specific determination can be requested from the permitting
authority.
What Constitutes a Process
Change?
Process changes include, but are
not limited to, changes in
production capacity, production
rate, or catalyst type; whenever
there is replacement, removal, or
addition of recovery equipment;
and debottlenecking activities.
Process changes do not include
process upsets, unintentional,
temporary process changes, or
changes that are within the range
on which the original calculation
was based.
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TABLE 4-1. Monitoring Requirements for Combustion Devices
Combustion Device
Type of Monitoring Required
Monitoring Location
Flare
Device capable of continuously
detecting the presence of a pilot
flame (including, but not limited
to a thermocouple, an ultraviolet
beam sensor, or an infrared
sensor)
Not specified
Incinerators other than catalytic
incinerators
Temperature monitoring device
with a continuous recorder
In the firebox or in the duct
work immediately downstream
of the firebox in a position
before any substantial heat
exchange occurs
Catalytic incinerators
Temperature monitoring device
with a continuous recorder
In the gas stream immediately
before and after the catalyst
bed
Boiler or process heater with a
design heat input capacity > 44
megawatts, or any boiler or
process heater in which all vent
streams are introduced into the
flame zone
No monitoring required
Not applicable
Boiler or process heater with a
design heat input capacity < 44
megawatts where the vent
streams are not introduced into
the flame zone
Temperature monitoring device
with a continuous recorder
In the firebox
TABLE 4-2. Monitoring Requirements for Miscellaneous Process Vents
with Bypass Lines
Type of Bypass Line Control
Refineries that use a vent system
with bypass line valves that have
not been sealed or secured
Type of Monitoring Required
Flow indicator that determines at
least every hour whether a vent
stream flow is present
At the entrance to any
bypass line that could divert
the vent stream away from
the control device to the
atmosphere
Refineries that use a vent system
with bypass lines, where the
valves have been secured in the
closed position with a car-seal or
a lock-and key-type configuration
Visual inspection at least every
other month to ensure that the
valve is maintained in the closed
position and the vent stream is
not diverted through the bypass
line
At the valve
4.I.4 WHAT ARE THE REPORTING REQUIREMENTS FOR MISCELLANEOUS PROCESS VENTS?
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Reporting requirements for miscellaneous process vents include some requirements
applicable to all control devices, and additional reporting based on the specific control
device. This section discusses the two reports with specific requirements for
miscellaneous process vents: Notice of Compliance Status reports, and Periodic
reports.
NOTICE OF COMPLIANCE STATUS REPORT
As noted in Chapter 3, all refineries are
required to submit a Notice of Compliance
Status report. The NCS may be submitted in
an operating permit application, an amendment
to an operating permit application, a separate
submittal, or any combination of the three. If
the required information has been submitted at
an earlier date, or at different times, and/or in
different submittals, later submittals may refer
to earlier submittals instead of duplicating and
resubmitting previously submitted information.
Information required to be included in the NCS
depends on the type of emission point. For all
miscellaneous process vents, the NCS must
identify each vent, whether the process vent
is Group 1 or Group 2, and, for each Group
1 vent that is not included in an emissions
average, the method of compliance (e.g., use
of a flare or other control device meeting the
requirements of the MACT standard). [40
CFR 63.643(a)]
In addition, miscellaneous process vents with
control devices required to be tested under
the MACT standard must submit information
on each testing method, and results of the
performance test since there are different
requirements for each test and test method
used. Supporting information required for
each test method used is indicated in the box
below. Test results must include the
following information:
• The percentage reduction of organic
HAPs or TOC or the outlet concentration
of organic HAPs or TOC (ppm by volume
When Are NCS Reports
Required?
Notice of Compliance Status
reports are required at startup, or
within 150 days of an applicable
compliance deadline. If the refinery
submits an NCS report prior to the
compliance deadline, it does not
need to submit an additional report
within 150 days of the deadline. It
does, however, need to send a
letter to the Administrator
referencing the earlier notification.
For example, if a new facility
submits an NCS report at startup in
1995, it is required to submit a letter
Required Supporting Information
For Each Test Method Used:
1) Sampling site description
2) Description of sampling and
analysis procedures, and any
modifications to standard
procedures
3) Quality assurance procedures
4) Record of operating conditions
during the test
5) Record of preparation of
standards
6) Record of calibrations
7) Raw data sheets for field
sampling
8) Raw data sheets for field and
laboratory analyses
9) Documentation of calculations
10) Any other information required
by the test method.
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on a dry basis corrected to 3 percent oxygen), determined as specified in 40 CFR
63.116(c)
• For vents controlled by flares, all visible emission readings, heat content
determinations, flow rate measurements, and exit velocity determinations made
during the compliance determination [40 CFR 63.654(f)(1)(iv)(A)]
• For vents controlled by flares, a statement of whether a flame was present at the
pilot light over the full period of the compliance determination [40 CFR
63.654(f)(1)(iv)(B)]
• The value of the monitored parameter specified in 40 CFR 63 Subpart CC, Table 10
(shown in Table 4-3), or a site specific parameter approved by the permitting
authority, averaged over the full period of the performance test.
Results of a prior performance test can be used if that test was conducted using the
methods specified in 40 CFR 63.645 and test conditions were representative of current
operating conditions.
TABLE 4-3. 40 CFR Part 63, Subpart CC, Table 10 Parameters
Control Device
Thermal incinerators
Catalytic incinerators
Boiler or process heater with a design
heat capacity < 44 MW where the vent
stream is not introduced into the flame
zone
Flare
All Control Devices
Parameters to be Monitored
Firebox temperature
Temperature upstream and downstream of the catalyst
bed
Firebox temperature
Presence of a flame at the pilot light
Presence of flow diverted to the atmosphere from the control
device, or monthly inspections of sealed valves
Specific NCS Reports For Vents Controlled By a Flare
In addition to the above requirements, vents controlled by a flare are required to include
performance test results applicable to the specific testing of the flare. For vents routed
to a flare, the NCS report must include the following performance test information:
• All visible readings
• Heat content determinations
• Flow rate measurements
• Exit velocity determinations
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A statement of whether a flame was present at the pilot light over the full period of
the compliance determination
If a parameter other than the presence of a pilot flame is monitored, the acceptable
range for the parameter and the rationale (including any supporting data or
calculations) for the range.
Specific NCS Reports For Vents Routed to
an Incinerator or Boiler or Process Heater <
44 MW Where the Vent Streams are NOT
Introduced Into the Flame Zone.
In addition to the above requirements, vents
routed to an incinerator or boiler or process
heater < 44 MW where the vent streams are not
introduced into the flame zone must include the
following in the NCS report:
• Average firebox temperature (or gas stream
temperature for catalytic incinerators) over
the duration of the performance test
• Acceptable range for the daily average
firebox temperature and rationale for the
range
• Times at which an operating day begins and
ends.
Do NCS Reports Have to be
Submitted If the Same Test is
Conducted for Multiple
Emission points?
Vents for which initial performance
tests are required must also
submit one complete test report
for each test method used for
each emission point. If the
refinery uses the same method for
additional tests, the additional test
results must be submitted, but
additional complete test reports
are not required.
PERIODIC REPORTS
When Are Periodic Reports Required?
Periodic reports are required only if the refinery experiences any compliance exceptions
or periods of excess emissions. Periods of excess emissions are defined as shown in
the box on the following page. Compliance exceptions include any of the exceptions
described in Section 3.3. Compliance exceptions and periods of excess emissions do
not include periods of startup, shutdown, malfunction, performance testing and
monitoring system calibration.
If Periodic Reports Are Required, When Must They Be Submitted?
Periodic reports must be submitted no later than 60 days after the end of each 6-month
period when any compliance exceptions occur. (The first 6-month period begins on the
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Petroleum Refinery MACT Standard Guidance
date the NCS report is required to be submitted.) Quarterly reporting is required if the
refinery uses emissions averaging, which is discussed in Section 4.7 below.
What Must fie Included In Periodic Reports?
General contents of periodic reports are described in Chapter 3. For miscellaneous
process vents, periodic reports must also include excess emissions for the operating
parameters applicable to the vents (either parameters in Table 4-4 of this manual, or
others specified by the permitting authority).
What is a Period of Excess Emissions?
1) An operating day when the daily average value of a monitored parameter, except presence
of a flare or pilot flame, is outside the range specified in the NCS.
2) For each vent routed to a flare, operating days when all pilot flames of a flare are absent.
3) An operating day when monitoring data required to be recorded (see section 4.1.6) is
available for less than 75% of the operating hours.
4) For approved data compressions systems, an operating day when the monitor operated for
less than 75% of the operating hours or a day when less than 18 monitoring values were
recorded.
4.I.5 WHAT ARE THE RECORDKEEPING REQUIREMENTS FOR MISCELLANEOUS PROCESS VENTS?
As with the reporting requirements for miscellaneous process vents, there are also
overlapping recordkeeping requirements for the various control devices, as well as
some recordkeeping requirements specific to individual control devices. For all control
devices, it is necessary to retain for 5 years all information that must be reported.
In addition to information that must be reported, refineries may be required to maintain
records applicable to specific process vents as shown in Table 4-4.
TABLE 4-4. Additional Recordkeeping Requirements
Control Device
Control devices for which an initial
performance test is required (flare,
incinerator, and boiler or process
heater < 44 MW where the vent
streams are not introduced into the
flame zone)
Complete test report for initial performance test results
Times and duration of periods when monitoring devices are
not operating
Vents routed to a flare
Record of each pilot flame determination (or alternate
parameter upon request and approval)
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Vents routed to an incinerator or
boiler or process heater < 44 MW
where the vent streams are not
introduced into the flame zone
Record of each firebox temperature value or a block
average of values for periods of one hour or less
Record of the daily average of firebox temperature.
However, if all hourly temperature values are within the
range reported in the NCS, the facility may record that all
values are within the range instead of daily average values.
For additional information on general recordkeeping requirements applicable to
miscellaneous process vents and all other process units, refer to Section 3.4 of this
manual.
4.2 WHAT ARE THE REQUIREMENTS FOR STORAGE VESSELS?
Group 1 storage vessels covered by the MACT standard include vessels storing organic
liquids that contain organic HAPs. In order to determine if a storage vessel is subject to
the MACT standard, refer to the applicability flowchart for storage vessels in Chapter 2.
The HAP weight percent criteria may be determined using engineering judgement or
test results. The vapor pressure criteria may be determined by using one of the
following:
• Information in standard reference texts
• Methods described in API publication 2517 (Evaporative Loss from External
Floating-Roof Tanks)
• Tests conducted using ASTM Method D2879-83
• Any other approved method.
4.2.I WHAT ARE THE CONTROL REQUIREMENTS FOR STORAGE VESSELS?
Storage vessels, that store a liquid with a maximum true vapor pressure of total organic
HAPs < 76.6 kPa, must be controlled by one of the following control methods [40 CFR
Floating Roofs
(1) Internal floating roof with specified seals; or
(2) External floating roof with specified seals; or
(3) External floating roof converted to internal floating roof with specified seals; (i.e.,
fixed roof installed above the external floating roof)
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Closed Vent Systems
(4) Closed vent system routed to a flare or other control device that reduces HAP
emissions by 95% or to 20 ppmv.
Storage vessels that store a liquid with a maximum true vapor pressure of total organic
HAPs > 76.6 kPa must be controlled by a closed vent system and control device. [40
CFR 63.119(a)(2)] In addition, work practices, as specified in 40 CFR 63.119(b)
through (e), must be followed for each of the control methods.
The above control methods apply to both existing and new sources. For storage
vessels at new sources, deck fitting controls, as specified in 40 CFR 63.119(c)(2)(l)
through (xii), must be installed on all floating roof tanks. In addition, the control
requirements of 40 CFR 63.119(b)(5) and (b)(6) also apply.
As indicated above, the four control methods for storage vessels generally fit into two
categories for testing, monitoring, reporting, and recordkeeping requirements. The first
three methods fall under the category of floating roofs, while the last item is in the
category of closed vent systems with control device. Although some of the
requirements described below are specific to individual control methods within the two
categories, most of the requirements apply to all control methods within each of the two
categories.
4.2.2 WHAT ARE THE TESTING REQUIREMENTS FOR STORAGE VESSELS?
As with other emission points, certain storage vessels are required to be tested during
an initial performance test, and follow-up tests in the event of process changes. This
initial test is required to ensure that the control equipment is operating properly, and that
emissions are within specified limits.
For storage vessels equipped with a closed vent system routed to control device, an
initial performance test must be performed. However, there are no testing requirements
for storage vessels equipped with a floating roof.
INITIAL PERFORMANCE TESTS
Closed Vent System Routed to a Flare
For storage vessels equipped with a closed vent system routed to a flare, testing
requirements include an initial performance test or compliance determination, as
specified in 40 CFR 63.11(b), to ensure compliance with the control requirement to
reduce total organic HAP emissions by 95% or to 20 ppmv. The test must include the
measurement/determination of the following:
• Emissions visibility
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• Net heat value of combusted gas
• Flow rate of gases being combusted
• Exit velocity.
Closed Vent System Routed to a Control Device Other Than a Flare
For storage vessels equipped with a closed vent system routed to a control device other
than a flare, testing requirements include either an initial design evaluation, as specified
in 40 CFR 63.120(d)(1)(l), or an initial performance test, as specified in 40 CFR
4.2.3 WHAT ARE THE MONITORING AND INSPECTION REQUIREMENTS FOR STORAGE VESSELS?
For storage vessels that must apply controls, there are monitoring and inspection
requirements to ensure continuing compliance with the control requirements. The
requirements vary according to the control method used, with similarities for all closed
vent systems and similarities for all floating roofs.
MONITORING REQUIREMENTS
For storage vessels equipped with a closed vent system, the facility must monitor the
parameters proposed in the Notice of Compliance Status report to ensure that the
control device is being properly operated and maintained. There are no monitoring
requirements for storage vessels equipped with floating roofs.
INSPECTION REQUIREMENTS
Inspections of control equipment are also required periodically to demonstrate
compliance with the control requirements. For a closed vent system routed to a control
device, the facility must inspect the closed vent system, as specified in 40 CFR 63.148,
every 12 months.
Floating Roofs
Storage vessels with floating roofs may have a single-seal system or a double-seal
system. For storage vessels equipped with a fixed roof and an internal floating roof or
an external floating roof converted to an internal floating roof, the following inspection
requirements apply for each type of seal system:
Single-Seal System
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/ Visually inspect the internal floating roof and primary seal through manholes and
roof hatches at least once every 12 months after initial fill, or at least every 12
months after the compliance date.
/ Visually inspect the internal floating roof and primary seal each time the storage
vessel is emptied and degassed and at least once every 10 years after the
compliance date.
/ Visually inspect gaskets, slotted membranes, and sleeve seal (if any) each time
the storage vessel is emptied and degassed and at least once every 10 years
after the compliance date (new source only).
Double-Seal System
/ Visually inspect the internal floating roof, primary seal, and secondary seal each
time the vessel is emptied and degassed and at least once every 5 years after
the compliance date; or
/ Visually inspect the internal floating roof and the secondary seal through
manholes and roof hatches at least once every 12 months after initial fill, or at
least every 12 months after the compliance date; and
/ Visually inspect the internal floating roof, primary seal, and secondary seal each
time the vessel is emptied and degassed and at least once every 10 years after
the compliance date.
For storage vessels equipped with an external floating roof, the facility must visually
inspect the external floating roof, the primary and secondary seals, and fittings each
time the vessel is emptied and degassed. In addition, the following inspection
requirements apply for each type of seal system:
Single-Seal System
/ Measure the gaps between the vessel wall and the primary seal by the
compliance date and at least once a year, until a secondary seal is installed.
When a secondary seal is installed, measure gaps between the vessel wall and
both the primary and secondary seal within 90 calendar days of installation, and
then comply with the double-seal inspection requirements below. [40 CFR
Double-Seal System
/ Measure the gaps between the vessel wall and the primary seal during
hydrostatic testing or by the compliance date and at least once every 5 years
thereafter
/ Measure the gaps between the vessel wall and the secondary seal by the
compliance date and at least once a year.
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4.2.4 WHAT ARE THE REPORTING REQUIREMENTS FOR STORAGE VESSELS?
Reporting requirements for storage vessels include Notice of Compliance Status
reports, periodic reports, and internal inspection notification. As with testing and
monitoring, reporting requirements for storage vessels include some requirements
applicable to all four control methods, some requirements applicable to the two general
control categories (i.e., closed vent systems and floating roofs), and some requirements
specific to individual control methods. The following subsections discuss the specific
information required for storage vessels in each of these reports.
NOTICE OF COMPLIANCE STATUS REPORT
Section 3.3.3 of this manual lays out the basic requirements for a NCS report. The
MACT standard sets out additional NCS requirements for storage vessels equipped with
closed vent systems, but not for storage vessels with floating roofs.
Closed Vent System Routed to a Flare
For storage vessels equipped with a closed vent system routed to a flare, the NCS must
also contain the results of the initial performance test, including:
• Flare design, such as steam-assisted, air-assisted, or non-assisted
• Visible emissions readings
• Heat content determinations
• Flow rate measurements
• Exit velocity determinations
• Periods during the compliance determination when the pilot flame is absent.
Closed Vent System Routed to a Control Device Other Than a Flare
For storage vessels equipped with a closed vent system routed to a control device other
than a flare, the NCS must also include:
• Description of the parameter(s) to be monitored to ensure proper operation and
maintenance of the control device
• Explanation of the parameter selection
• Frequency of monitoring
• Design evaluation documentation, as specified in 40 CFR 63.120(d)(1)(l), or results
of the initial performance test including identification of emission points sharing the
control device.
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PERIODIC REPORTS
As mentioned previously in this section and in Chapter 3, periodic reports are only
required if compliance exceptions occur. The information required in periodic reports
falls into the 2 general categories of control methods: closed vent systems and floating
roofs, with a few additional requirements for external floating roofs.
Closed Vent Systems Routed To Any Control Device
For storage vessels equipped with a closed vent system routed to a control device,
periodic reports must include a description of the following:
• Routine maintenance for the control device that was performed during the previous 6
months
• Routine maintenance
anticipated for the control
device for the next 6
months
• For a control device that is
a flare, each occurrence
and cause when the
requirements specified in
40CFR63.11(b)arenot
met
• For a control device other
than a flare, each
occurrence and cause of
monitored parameters
being outside the ranges
documented in the NCS.
Floating Roofs
For storage vessels equipped
with any type of floating roof,
periodic reports must contain
the results of each inspection
in which a failure was
detected. Periodic reports
must include the following
information:
What Are Compliance Exceptions For Storage
Vessels?
Compliance exceptions refer to the following failures
or defects in the control equipment:
• Floating roof not resting on the surface of the
liquid inside the vessel and not resting on the leg
supports
• Liquid floating on the floating roof
• Seal detached from the floating roof
• Holes, tears, or other openings in the seal or seal
fabric
• Visible gaps between the seal and the wall of the
vessel
• Gaskets no longer close off the liquid surface
from the atmosphere
• Slotted membrane has more than a 10% open
area (new source only).
Compliance exceptions also include occurrences
when monitored parameters are outside the
parameters established in the NCS.
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• Date of inspection
• Identification of the storage vessel
• Description of the failure
• Nature and date of repair or date the vessel was emptied.
If a failure or defect is detected during inspection, the facility must repair or empty and
remove the vessel from service within 45 days. If the vessel cannot be repaired or
emptied within 45 days, the facility may utilize up to 2 extensions of up to 30 additional
days each. If an extension is used, periodic reports must also include the following
information:
• Description of the failure
• Statement that alternate storage capacity is unavailable
• Schedule of actions that will ensure that the control equipment will be repaired or the
vessel will be emptied as soon as possible.
Additional reporting requirements for storage vessels equipped with an external floating
roof include notifying the Administrator 30 days in advance of any gap measurement.
Results of each gap measurement in which the requirements of 40 CFR 63.120(b)(3),
(4), (5), or (6) are not met must also be reported in the periodic reports. Such results
must include the following information:
• Date of seal gap measurement
• Raw data and calculations described in 63.120(b)(5) or (6)
• Description of seal conditions that are not met
• Nature and date of repair or date the vessel was emptied.
INTERNAL INSPECTION NOTIFICATION
The third category of reporting directly applicable to storage vessels is notifying the
Administrator of scheduled internal inspections and refilling of empty storage vessels
with organic HAPs. Refineries are required to notify the Administrator at least 30
calendar days prior to filling or refilling each storage vessel with organic HAPs. The 30-
day notification is required except if:
• The internal inspection required by 40 CFR 1209(a)(2), 63.1299(a)(3), or
63.120(b)(10) is not planned, and
• The owner/operator of the refinery could not have known about the inspection 30
calendar days in advance of refilling the vessel with organic HAPs.
If the inspection is not planned and the owner/operator could not have known about it in
advance, the Administrator must be notified at least 7 calendar days prior to refilling the
storage vessel. Notification may be made by telephone and immediately followed by
written documentation demonstrating why the inspection was unplanned. The
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notification may also be made in writing provided that it is received by the Administrator
at least 7 calendar days prior to the refilling.
If the State or local permitting authority has received delegation of the Refinery MACT
(not all states have as of August 1997), they can waive the notification requirements for
all or some storage vessels at petroleum refineries. The State or local permitting
authority may also grant permission to refill storage vessels sooner than 30 days after
submitting the required notification under 40 CFR 64.654(h)(2)(l)(A) or sooner than 7
days after submitting the notification under 40 CFR 64.654(h)(2)(l)(B) on a case-by-
case basis.
4.2.5 WHAT ARE THE RECORDKEEPING REQUIREMENTS FOR STORAGE VESSELS?
There are recordkeeping requirements common to all storage vessels, as well as some
recordkeeping requirements specific to the different control methods. For all storage
vessels, it is necessary to maintain records of Group 1 or Group 2 determinations,
vessel dimensions, and analysis of capacity. In addition, all information required to be
reported must be retained for 5 years.
Closed Vent Systems Routed To Any Control Device
For storage vessels equipped with a closed vent system routed to a control device,
additional recordkeeping requirements include:
• Complete test report for initial performance test results
• Measured values of monitored parameters
• Planned routine maintenance performed, including:
- The first time of day and date the control requirements are not met at the
beginning of the planned routine maintenance, and
- The first time of day and date the control requirements are met at the conclusion
of the planned routine maintenance.
Floating Roofs
For storage vessels equipped with any type of floating roof, recordkeeping requirements
include retaining records of each inspection performed. [40 CFR 63.123(c) and (e)] For
storage vessels equipped with an external floating roof, additional requirements involve
retaining records of each seal gap measurement, including date, raw data obtained in
the measurement, and the calculations described in 40 CFR 63.120(b)(3) and (4).
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4.3 WHAT ARE THE REQUIREMENTS FOR WASTEWATER STREAMS?
In order to determine if a wastewater stream is subject to the MACT Standard, refer to
the applicability flowchart for wastewater streams in Chapter 2. Refineries in
compliance with the benzene waste NESHAP [40 CFR 61 Subpart FF] are considered
to be in compliance with the refinery MACT standard. Provisions of the benzene waste
NESHAP apply to the following wastewater streams at petroleum refineries:
(1) Total benzene loading > 10 Mg per year, and
(2) Flow rate > .02 liters per minute, and
(3) Benzene concentration > 10 ppm by weight, and
(4) Not exempt from controls under the benzene waste NESHAP.
4.3.I WHAT ARE THE CONTROL REQUIREMENTS FOR WASTEWATER STREAMS?
Wastewater streams meeting the applicability criteria above are required to comply with
the control requirements of the benzene waste NESHAP [40 CFR 61 Subpart FF].
These control requirements include the following:
• Wastewater streams must reduce benzene mass emissions by 99% by using
suppression followed by steam stripping, biotreatment, or other treatment process.
• Vents from steam strippers and other waste management or treatment units must
have a control device that achieves 95% emission reduction or 20 ppmv at the outlet
of the control device.
4.3.2 WHAT ARE THE TESTING REQUIREMENTS FOR WASTEWATER STREAMS?
All wastewater streams must comply with the testing requirements of the benzene
waste NESHAP found in 40 CFR 61.340 through 61.355. These sections also specify
the frequency for which testing must be done. If required, periodic measurements of
benzene concentration in the wastewater must be performed.
4.3.3 WHAT ARE THE MONITORING REQUIREMENTS FOR WASTEWATER STREAMS?
All wastewater streams must also comply with the monitoring requirements of the
benzene waste NESHAP found in 40 CFR 61.340 through 61.355. If required,
monitoring of the process or control device operating parameters must be performed.
4.3.4 WHAT ARE THE REPORTING AND RECORDKEEPING REQUIREMENTS FOR WASTEWATER
STREAMS?
All wastewater streams must comply with the reporting requirements of the benzene
waste NESHAP found in 40 CFR 61.356 and 61.357. [40 CFR 63.654(a)] In addition,
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all information required to be reported must be retained for 5 years. [40 CFR
63.654(l)(4)] Since affected sources should already be in compliance with 40 CFR 61
Subpart FF, they will not need to make any changes to their current reporting and
recordkeeping procedures.
4.4 WHAT ARE THE REQUIREMENTS FOR GASOLINE LOADING RACKS?
In order to determine if a gasoline loading rack is subject to the MACT standard, refer to
the applicability flowchart for gasoline loading racks in Chapter 2.
4.4.I WHAT ARE THE CONTROL REQUIREMENTS FOR GASOLINE LOADING RACKS?
Gasoline loading racks that are subject to the MACT standard must be in compliance
with the gasoline distribution facilities NESHAP found in 40 CFR 63 Subpart R, which
requires the following:
(1) Reduce emissions of total
organic compounds (TOC) to
10 milligrams per liter of
gasoline loaded; and
(2) Load gasoline only in vapor
tight cargo tanks that have
been tested to assure vapor
tightness.
4.4.2 WHAT ARE THE TESTING AND
MONITORING REQUIREMENTS
FOR GASOLINE LOADING RACKS?
For all gasoline loading racks
subject to the MACT standard, the
facility must comply with the testing
and monitoring requirements of the
gasoline distribution facilities
NESHAP. These tests are found in
40 CFR 63.425(a) through (c)
(performance tests), 63.425(e)
through (h) (annual certification),
63.425(f) (leak detection tests),
63.425(g) (nitrogen pressure decay
field tests), and 63.427 (continuous
monitoring).
Procedure For Initial Performance Testing
of Gasoline Loading Racks:
Initial performance tests must determine a
monitored operating parameter value for the
vapor processing system using the following
procedure:
1) During the performance test, continuously
record the operating parameters under 40
CFR 63.427.
2) Determine an operating parameter value
based on the parameter data monitored
during the performance test, supplemented
by engineering assessments and the
manufacturer's recommendations, and
3) Provide for the Administrator's approval the
rationale for the selected operating
parameter value, and monitoring frequency
and averaging time. This includes data
and calculations used to develop the value
and a description why the value, monitoring
frequency, and averaging time
demonstrate continuous compliance with
the emission standard in 40 CFR 63.422(b)
or60.112b(a)(3)(ii).
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INITIAL PERFORMANCE TEST
The initial performance test is required to be conducted according to the test methods
and procedures in 40 CFR 60.503, except a reading of 500 ppm must be used to
determine the level of leaks to be repaired under 40 CFR 60.503.
For follow-up tests (required to be conducted following process changes), the refinery is
required to document the reasons for any change in the operating parameter value
since the previous test.
What If A Closed Vent System Is Used To Control Emissions?
If a closed vent system and control device, as specified in 40 CFR 60.112b(a)(3), is
required to comply with the control requirements for gasoline loading racks, initial
performance tests are required. [40 CFR 63.423]
What If a Flare Is Used To Control Emissions?
If a flare is used, and emissions from the gasoline loading rack cannot be measured
using the methods specified in 40 CFR 60.503, the refinery is required to comply with
the provisions of 40 CFR 63.11 (b).
ANNUAL CERTIFICATION TESTS
In addition to the initial performance test, gasoline cargo tanks are required to be tested
annually to certify that emissions controls are functioning properly. The annual
performance test must be conducted according to the vacuum and pressure tests
described in Method 27 of 40 CFR 60 Appendix A.
LEAK DETECTION TESTS
During loading operations, the facility is required to conduct a leak detection test for its
gasoline loading racks according to Method 21 of 40 CFR 60 Appendix A. The tests are
required to be conducted on each compartment during the loading of that compartment,
or while the compartment is still under pressure. In
addition to Method 21, the following additional
requirements for the test apply [40 CFR 63.425]:
To eliminate a positive instrument drift, the dwell
time for each leak detection may not exceed two
times the instrument response time. The
instrument must be purged with ambient air
between each leak detection, and the duration
of the purge must be in excess of two instrument response times.
How Are Leaks Defined?
A leak is defined as a
reading of 21,000 ppm or
more propane.
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• The facility must attempt to block the wind from the area being monitored, and
record the highest detector reading and location for each leak.
ADDITIONAL TESTING REQUIREMENTS
Cargo tanks with manifolded product lines are required to conduct a nitrogen pressure
decay field test on each compartment of each tank. This test is described in 40 CFR
63.425(g). A continuous performance pressure decay test, as described in 40 CFR
63.425 (h), is also required.
CONTINUOUS MONITORING
Gasoline loading racks are required to be in compliance with the continuous monitoring
requirements of 40 CFR 63.427(a) and (b). The continuous monitoring system must be
installed, calibrated, certified, operated and maintained according to manufacturer
specifications. The location where the continuous monitoring system must be installed
depends on the type of system used (e.g., carbon adsorption, refrigeration condenser,
thermal oxidation, or flare).
4.4.3 WHAT ARE THE REPORTING AND RECORDKEEPING REQUIREMENTS FOR GASOLINE
LOADING RACKS?
For gasoline loading racks, the facility must comply with the reporting and
recordkeeping requirements of the gasoline distribution facilities NESHAP found in 40
CFR 63.428(b), (c), (g)(1), and (h)(1) through (h)(3). The initial notification report under
40 CFR 63.428(a) is not required. All required records must be retained for 5 years.
4.5 WHAT ARE THE REQUIREMENTS FOR MARINE TANK VESSEL LOADING?
In order to determine if marine tank vessel loading is subject to the MACT standard,
refer to the applicability flowchart for marine tank vessel loading in Chapter 2.
4.5.I WHAT ARE THE CONTROL REQUIREMENTS FOR MARINE TANK VESSEL LOADING?
Marine tank vessel loading operations that are subject to the MACT standard must be in
compliance with the marine tank loading NESHAP found in 40 CFR 63 Subpart Y, which
requires the following:
Existing Sources'. • Collect vapors discharged during loading
• Load only in vapor tight vessels
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• Reduce collected HAP emissions by 97% or use vapor
balancing.
New Sources'. • Same as existing sources, except reduce collected HAP by
98% or use vapor balancing.
4.5.2 WHAT ARE THE TESTING AND MONITORING REQUIREMENTS FOR MARINE TANK VESSEL
LOADING?
For all marine tank vessel loading operations subject to the MACT Standard, the
refinery must comply with the testing and monitoring requirements of the marine tank
loading NESHAP found in 40 CFR 63.560 through 63.567.
4.5.3 WHAT ARE THE REPORTING AND RECORDKEEPING REQUIREMENTS FOR MARINE TANK
VESSEL LOADING?
For all marine tank vessel loading subject to the MACT standard, the refinery must
comply with the reporting and recordkeeping requirements of the marine tank loading
NESHAP found in 40 CFR 63.566, 63.567(a) and (c) through (I). The Initial Notification
Report under 40 CFR 63.567(b) is not required. All required records must be retained
for 5 years.
4.6 WHAT ARE THE REQUIREMENTS FOR EQUIPMENT LEAKS?
In order to determine if an equipment leak is subject to the MACT standard control
requirements, refer to the applicability flowchart for equipment leaks in Chapter 2. The
5% HAP service criterion is determined using test methods and procedures specified in
40 CFR 63.180.
4.6.I WHAT ARE THE CONTROL REQUIREMENTS FOR EQUIPMENT LEAKS?
For equipment leaks at existing sources, the facility must comply with either of the
following equipment leaks provisions:
(1) 40 CFR 60 Subpart W (synthetic organic chemical manufacturing industry
(SOCMI) equipment leaks NSPS), or
(2) Modified 40 CFR 63 Subpart H (hazardous organic NESHAP (HON) negotiated
regulation).
For equipment leaks at new sources, the facility must comply with modified 40 CFR 63
Subpart H.
4.6.2 WHAT ARE THE TESTING, INSPECTION, AND MONITORING REQUIREMENTS FOR
EQUIPMENT LEAKS?
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Petroleum Refinery MACT Standard Guidance
For all equipment leaks subject to the MACT standard, the refinery must comply with
the testing, inspection, and monitoring requirements for equipment leaks in 40 CFR
60.1046 and 60.1047 (40 CFR 60 Subpart W), or 40 CFR 63.162 through 63.180 (40
CFR 63 Subpart H).
4.6.3 WHAT ARE THE REPORTING AND RECORDKEEPING REQUIREMENTS FOR EQUIPMENT
LEAKS?
For all equipment leaks subject to the MACT Standard, the refinery must comply with
the reporting and recordkeeping requirements for equipment leaks found in 40 CFR
60.1048 and 60.1049 (40 CFR 60 Subpart W), or 40 CFR 63.181 and 63.182 (40 CFR
63 Subpart H).
4.7 EMISSIONS AVERAGING
The Petroleum Refinery NESHAP [40 CFR 63 Subpart CC] is stated as a source-wide
emissions allowance, as represented by the equation in 40 CFR 63.642. As mentioned
in Chapter 2, there are 2 general approaches for petroleum refineries to comply with the
MACT standard's control requirements for achieving the emissions allowance:
(1) Implement controls on all emission points, as discussed in the previous sections
of this chapter; or
(2) Use a method called emissions averaging, which allows flexibility in applying
controls.
Emissions averaging allows facilities to overcontrol some emission points and
undercontrol others in order to achieve the required emissions reductions in the most
cost-effective manner. Additional flexibility is provided by permitting the use of
emissions averaging among petroleum refineries, gasoline distribution facilities, and
marine terminal loading operations located at the same site. Emissions averaging can
only be used for existing sources.
4.7.I EMISSIONS AVERAGING APPLICABILITY
Emissions averaging is allowed for miscellaneous process vents, storage vessels,
wastewater streams, gasoline loading racks, and marine tank vessel loading operations
in SIC 2911 at a refinery. Emissions averaging is not allowed across sources, such as
across different plant sites or between refinery and HON sources (i.e., units having a
hazardous organic air pollutant as its primary product) at the same plant site. In
addition, an emissions estimation is only required for points included in emissions
averages, not for all points in the source.
4-23 September 30, 1997
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Petroleum Refinery MACT Standard Guidance
A limitation on the emissions averaging provision is that States have the authority to
disallow emission averaging and require the application of standard control
requirements to all emission points.
4.7.2 EMISSIONS AVERAGING CREDIT/DEBIT SYSTEM
Emissions averaging provides a credit/debit system for calculating emissions to comply
with the overall emissions allowance. Facilities receive credits for overcontrol of
emission points - control above what is required in Subpart CC, and debits for
undercontrol of emission points - control below what is required in Subpart CC.
Emission credits and debits are calculated on a mass basis using equations in 40 CFR
63.652(g) and (h) to estimate emissions based on actual operations. Credits calculated
must be greater than or equal to debits calculated on an annual basis. [40 CFR
63.652(e)(3)] In addition, debits may not exceed credits by more than 30% in any one
quarter. [40 CFR 652(e)(4)]
The following emission points can be used to generate emissions averaging credits [40
CFR 63.652(c)(1) through (3)]:
• Group 2 emission points
• Group 1 emission points controlled by technology with a higher nominal efficiency
than the reference control technology
• Emission points from which emissions are reduced by pollution reduction measures,
alone or in conjunction with other controls, that get more emission reduction than
required
The following emission points cannot be used to generate emissions averaging credits
[40 CFR 63.652(d)]:
• Emission points already controlled on or before November 15, 1990, unless the level
of control was increased after November 15, 1990. If so, credit is allowed for the
increase only
• Group 1 emission points that are controlled by a reference control technology,
unless the technology has been approved for use in a different manner and a higher
nominal efficiency has been assigned. For example, it is not allowable to claim that
an internal floating roof meeting only the specifications stated in the reference
control technology definition in 40 CFR 63.641 applied to a storage vessel is
achieving greater than 95 percent control
• Emission points on shutdown process units
4-24 September 30, 1997
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Petroleum Refinery MACT Standard Guidance
• Emission points controlled to comply with a State or other Federal rule, unless the
level of control has been increased after November 15, 1990 above what is required
by the State or other Federal rule. If so, credit is allowed for the increase only.
Debits are generated if the required level of control of a Group 1 emission point, such as
98% for miscellaneous process vents and 95% for storage vessels, is not achieved. [40
CFR 63.652(g)] (See Table 2.3 for required level of control.) Debits and credits are
calculated using formulas found in 40 CFR 63.652(g) and (h). Calculations may not
include emissions from the following:
• Wastewater that is not process wastewater or wastewater streams treated in
biological treatment units. Group 1 wastewater streams cannot be left
undercontrolled or uncontrolled to generate debits [40 CFR 63.652(d)(4)]
• More than 20 individual emission points in addition to those controlled by pollution
prevention measures. Where pollution prevention measures are used, no more than
25 emission points total may be included in the average [40 CFR 63.652(f)(1)]
• Emission points during periods of startup, shutdown, and malfunction [40 CFR
63.652(f)(2)]
• Emission points for which continuous monitors are used and excess emissions
occur. [40 CFR 63.652(f)(3)] For these periods, the monthly credits and debits will
be adjusted as specified in 40 CFR 63.652(f)(3)(l) through (iii).
4.7.3 APPROVAL OF EMISSIONS AVERAGING PLAN
Facilities that wish to use emissions averaging to comply with the source-wide
emissions allowance, must submit for approval an emissions averaging plan in the
Implementation Plan or Operating Permit Application. The plan must demonstrate that
the credits will be sufficient to offset the debits under representative operating
conditions. [40 CFR 63.652(e)(3)(l)] The plan may include use of innovative
technologies, different from the reference control technology, provided that the
innovative technologies achieve greater than the level of control required for a Group 1
emission point. In addition, the facility must include a risk assessment in the plan of any
hazards or risks of the plan, such as the risk from one large emission point versus the
risk from combined emission points. Such hazards and risks must be reviewed and
compared to point-by-point compliance.
4.7.4 TESTING, MONITORING, REPORTING, AND RECORDKEEPING FOR EMISSIONS AVERAGING
For each emission point included in an emissions average, facilities must perform
testing, monitoring, reporting, and recordkeeping equivalent to the requirements for
Group 1 emission points that are not included in emissions averaging. [40 CFR
63.653(a)] See Chapter 3 for general requirements and previous sections in this
4-25 September 30, 1997
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Petroleum Refinery MACT Standard Guidance
chapter for emission point specific requirements. One additional requirement is to
maintain the monthly calculations of debits and credits.
4.7.5 RECORDKEEPING FOR EMISSIONS AVERAGING
Requirements for emissions averaging include maintaining the following:
• Initial performance test results (if applicable)
• Monthly debits, credits, and calculations using EPA-specified calculation procedures
• Operating parameter monitoring results.
4.8 CONCLUSIONS
Chapter 4 completed the discussion of requirements of the MACT standard by detailing
requirements that are specific to each emission point, and discussed the alternative
compliance method of emissions averaging. This chapter explained the requirements
for emissions from miscellaneous process vents, storage vessels, wastewater streams,
gasoline loading racks, marine tank vessel loading, and equipment leaks. For each
type of emission point, the chapter discussed control requirements, followed by an
explanation of testing, monitoring, reporting and record keeping requirements. The
chapter concluded by discussing how a facility could use emissions averaging to meet
the requirements of the standard, rather than control each emission point.
4-26 September 30, 1997
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Petroleum Refinery MACT Standard Guidance
5. INTERRELATIONSHIP OF THE PETROLEUM REFINERY MACT
STANDARD WITH OTHER REGULATIONS
This chapter summarizes the interrelationship between the MACT standard and other
regulations. As described in previous chapters, the MACT standard requires that HAP
emissions be controlled from various emission points within the petroleum refinery.
Some of these emission points may also be subject to other existing regulations
including the New Source Performance Standards (NSPS) or other NESHAPs. It was
not EPA's intent to have redundant regulations that put an undue burden on the
owner/operator of a petroleum refinery, but to allow sources to comply with only the
most stringent regulation which will demonstrate compliance with all applicable
regulations.
The applicability of 40 CFR 63 Subpart CC versus 40 CFR 63 Subpart G, hazardous
organic NESHAP (HON), or some other MACT standard, to an emission point is
determined by the primary product produced at the unit. The primary product is that
produced in the greatest mass or volume by the unit. For instance, if the unit produces
a hazardous organic as the primary product, then it is subject to the HON. If a unit is
integral to the petroleum refinery's operations, and produces hazardous organics in
small quantities, it is subject to the petroleum refining MACT standard.
EPA has also included a SIC code reference for petroleum refining (SIC 2911) in the
MACT Standard in order to clarify the applicability of the rule and reduce the potential
confusion of regulatory overlap.
The following describes the relationship of the MACT standard to existing regulations for
each process unit and related emission points:
Miscellaneous Process Vents: There are no existing regulations governing
miscellaneous process vents. Both Group 1 and Group 2 have to comply with the
MACT standard.
Storage Vessels: For storage vessels, there is an overlap between the MACT
standard and the following NSPS:
• 40 CFR 60 Subpart K, performance standards for petroleum liquid storage vessels
that were built or have undergone some kind of modification after June 11, 1973, but
before May 19, 1978
5-1 September 30, 1997
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Petroleum Refinery MACT Standard Guidance
• 40 CFR 60 Subpart Ka, performance standards for petroleum liquid storage vessels
that were built or have undergone some kind of modification after May 18, 1978, but
before July 7, 1984
• 40 CFR 60 Subpart Kb, performance standards for volatile organic storage vessels
that have been modified after July 23, 1984.
The control requirements in the MACT standard reference the storage vessel provisions
in 40 CFR 63 Subpart G. The MACT standard is applicable to all new Group 1 storage
vessels and to existing facilities not governed by 40 CFR 60 Subpart Kb. For Group 2
storage vessels, if the control requirements of Subparts K, Ka or Kb do not apply, the
vessel is subject to Subpart CC. All units that are not subject to Subparts K, Ka or Kb
are subject to the MACT Standard.
Owners/operators of internal floating roof or external floating roof tanks are allowed to
defer upgrading their seals to meet the NESHAP requirements until the next scheduled
inspection and maintenance activity or within 10 years, whichever comes first.
Wastewater Streams: For wastewater streams, the following regulations are cross-
referenced in the MACT standard:
• 40 CFR 60 Subpart QQQ, performance standards for VOC emissions from
petroleum refinery wastewater systems
• 40 CFR 61 Subpart FF, benzene waste operations NESHAP (BWON)
• 40 CFR 63 Subpart G, synthetic organic chemical manufacturing industry (SOCMI)
NESHAP.
New and existing sources in compliance with BWON are in compliance with the MACT
standard. The MACT standard is applicable only to Group 1 streams that are subject to
40 CFR 60 Subpart QQQ. Otherwise, existing regulations are more stringent than the
new rule. The MACT standard also clarifies the applicable provisions of 40 CFR 63
Subpart G.
Gasoline Storage Racks: These sources are governed by 40 CFR 63 Subpart R,
gasoline distribution facilities NESHAP, which is referenced in the MACT standard.
Marine Tank Vessel Loading: These sources are subject to 40 CFR 63 Subpart Y,
marine tank loading NESHAP, which is referenced in the MACT standard.
Equipment Leaks: For equipment leaks, the following regulations are cross-
referenced in the MACT standard:
• 40 CFR 60 Subpart W, performance standards for equipment leaks from SOCMI
process units
5-2 September 30, 1997
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Petroleum Refinery MACT Standard Guidance
• Modified 40 CFR 63 Subpart H, HON negotiated equipment leak standard.
There are no group designations for equipment leaks. New sources must comply with
the 40 CFR 63 Subpart H at startup, whereas existing sources can choose to comply
with either 40 CFR 60 Subpart W or 40 CFR 63 Subpart H. Also, the MACT standard
does not apply to units that are also subject to provisions of the HON.
Table 5-1 presents a summary of the existing regulations that may be applicable to
each emission point controlled under the MACT standard.
CONCLUSIONS
Chapter 5 discussed the relationship between the MACT Standard and existing
regulations. As was indicated in this chapter, the MACT Standard overlaps with certain
requirements for storage vessels, wastewater streams, gasoline storage racks, marine
tank vessel loading, and equipment leaks. Miscellaneous process vents are the one
type of emission point for which there are no existing requirements, and thus no
overlap. This chapter also described other federal standards with which refineries are
required to comply that are referenced in the MACT standard.
5-3 September 30, 1997
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Petroleum Refinery MACT Standard Guidance
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APPENDIX A. HAZARDOUS AIR POLLUTANTS (HAPs)
Chemical Name
Acetaldehyde
Acetamide
Acetonitrile
Acetophenone
2-Acetylam inof luorene
Acrolein
Aery lam ide
Acrylic acid
Acrylonitrile
Allyl chloride
4-Aminobiphenyl
Aniline
o-Anisidine
Asbestos
Benzene (including benzene from gasoline)
Benzidine
Benzotrichloride
Benzyl chloride
Biphenyl
Bis(2-ethylhexyl)phthalate(DEHP)
Bis(chloromethyl)ether
Bromofoim
1,3-Butadiene
Calcium cyanamide
Captan
75070
60355
75058
98862
53963
107028
79061
79107
107131
107051
92671
62533
90040
1332214
71432
92875
98077
100447
92524
117817
542881
75252
106990
156627
133062
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Petroleum Refinery MACT Standard Guidance
Chemical Name
Carbaryl
Carbon disulfide
Carbon tetrachloride
Carbonyl sulfide
Catechol
Chloramben
Chlordane
Chlorine
Chloroacetic acid
2-Chloroacetophenone
Chlorobenzene
Chlorobenzilate
Chloroform
Chloromethyl methyl ether
Chloroprene
Cresols/Cresylic acid (isomers and mixture)
o-Cresol
m-Cresol
p-Cresol
Cumene
2,4-D, salts and esters
DDE
Diazomethane
Dibenzofurans
1 ,2-Dibromo-3-chloropropane
Dibutylphthalate
1 ,4-Dichlorobenzene(p)
63252
75150
56235
463581
120809
133904
57749
7782505
79118
532274
108907
510156
67663
107302
126998
1319773
95487
108394
106445
98828
94757
3547044
334883
132649
96128
84742
106467
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Petroleum Refinery MACT Standard Guidance
Chemical Name
3,3-Dichlorobenzidene
Dichloroethyl ether (Bis(2-chloroethyl)ether)
1 ,3-Dichloropropene
Dichlorvos
Diethanolamine
N,N-Diethyl aniline (N,N-Dimethylaniline)
Diethyl sulfate
3,3-Dimethoxybenzidine
Dimethyl aminoazobenzene
3,3-Dimethyl benzidine
Dimethyl carbamoyl chloride
Dimethyl formamide
1,1 -Dimethyl hydrazine
Dimethyl phthalate
Dimethyl sulfate
4,6-Dinitro-o-cresol, and salts
2,4-Dinitrophenol
2,4-Dinitrotoluene
1 ,4-Dioxane (1 ,4-Diethyleneoxide)
1 ,2-Diphenylhydrazine
Epichlorohydrin (l-Chloro-2,3-epoxypropane)
1 ,2-Epoxybutane
Ethyl acrylate
Ethyl benzene
Ethyl carbamate (Urethane)
Ethyl chloride (Chloroethane)
Ethylene dibromide (Dibromoethane)
91941
111444
542756
62737
111422
121697
64675
119904
60117
119937
79447
68122
57147
131113
77781
534521
51285
121142
123911
122667
106898
106887
140885
100414
51796
75003
106934
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Petroleum Refinery MACT Standard Guidance
Chemical Name
Ethylene dichloride (1,2-Dichloroethane)
Ethylene glycol
Ethylene imine (Aziridine)
Ethylene oxide
Ethylene thiourea
Ethylidene dichloride (1,1-Dichloroethane)
Formaldehyde
Heptachlor
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
Hexamethylene-1 ,6-diisocyanate
Hexamethylphosphoramide
Hexane
Hydrazine
Hydrochloric acid
Hydrogen fluoride (Hydrofluoric acid)
Hydroquinone
Isophorone
Lindane (all isomers)
Maleic anhydride
Methanol
Methoxychlor
Methyl bromide (Bromomethane)
Methyl chloride (Chloromethane)
Methyl chloroform (1,1,1-Trichloroethane)
107062
107211
151564
75218
96457
75343
50000
76448
118741
87683
77474
67721
822060
680319
110543
302012
7647010
7664393
123319
78591
58899
108316
67561
72435
74839
74873
71556
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Petroleum Refinery MACT Standard Guidance
Chemical Name
Methyl ethyl ketone (2-Butanone)
Methyl hydrazine
Methyl iodide (lodomethane)
Methyl isobutyl ketone (Hexone)
Methyl isocyanate
Methyl methacrylate
Methyl tert butyl ether
4,4-Methylene bis(2-chloroaniline)
Methylene chloride (Dichloromethane)
Methylene diphenyl diisocyanate (MDI)
4,4-Methylenedianiline
Naphthalene
Nitrobenzene
4-Nitrobiphenyl
4-Nitrophenol
2-Nitropropane
N-Nitroso-N-methylurea
N-Nitrosodimethylamine
N-Nitrosomorpholine
Parathion
Pentachloronitrobenzene (Quintobenzene)
Pentachlorophenol
Phenol
p-Phenylenediamine
Phosgene
Phosphine
Phosphorus
78933
60344
74884
108101
624839
80626
1634044
101144
75092
101688
101779
91203
98953
92933
100027
79469
684935
62759
59892
56382
82688
87865
108952
106503
75445
7803512
7723140
A-5
September 30, 1997
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Petroleum Refinery MACT Standard Guidance
Chemical Name
Phthalic anhydride
Polychlorinated biphenyls (Aroclors)
1,3-Propane sultone
beta-Propiolactone
Propionaldehyde
Propoxur (Baygon)
Propylene dichloride (1,2-Dichloropropane)
Propylene oxide
1,2-Propylenimine (2-Methyl aziridine)
Quinoline
Quinone
Styrene
Styrene oxide
2,3,7,8-Tetrachlorodibenzo-p-dioxin
1 , 1 ,2,2-Tetrachloroethane
Tetrachloroethylene (Perchloroethylene)
Titanium tetrachloride
Toluene
2,4-Toluene diamine
2,4-Toluene diisocyanate
o-Toluidine
Toxaphene (chlorinated camphene)
1 ,2,4-Trichlorobenzene
1 , 1 ,2-Trichloroethane
Trichloroethylene
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
85449
1336363
1120714
57578
123386
114261
78875
75569
75558
91225
106514
100425
96093
1746016
79345
127184
7550450
108883
95807
584849
95534
8001352
120821
79005
79016
95954
88062
A-6
September 30, 1997
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Petroleum Refinery MACT Standard Guidance
Chemical Name
Triethylamine
Trifluralin
2,2,4-Trimethylpentane
Vinyl acetate
Vinyl bromide
Vinyl chloride
Vinylidene chloride (1,1-Dichloroethylene)
Xylenes (isomers and mixture)
o-Xylenes
m-Xylenes
p-Xylenes
Antimony Compounds
Arsenic Compounds (inorganic including arsine)
Beryllium Compounds
Cadmium Compounds
Chromium Compounds
Cobalt Compounds
Coke Oven Emissions
Cyanide Compounds1
Glycol ethers2
Lead Compounds
Manganese Compounds
Mercury Compounds
Fine mineral fibers3
Nickel Compounds
Polycylic Organic Matter4
Radionuclides (including radon)5
121448
1582098
540841
108054
593602
75014
75354
1330207
95476
108383
106423
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
A-7
September 30, 1997
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Petroleum Refinery MACT Standard Guidance
Chemical Name
Selenium Compounds
CAS Number
0
Note: For all listings above which contain the word 'compounds' and for glycol ethers, the following
applies: Unless otherwise specified, these listings are defined as including any unique chemical substance
that contains the name chemical (i.e., antimony, arsenic, etc.) as part of that chemical's infrastructure.
1 X'CN where X=H' or any other group where a formal dissociation may occur. For example KCN or
Ca(CN)2.
2 Includes mono- and di-ehters or ethylene glycol, diethylene glycol, and triethylene glycol
R-(OCH2CH2)n-OR' where n=1, 2, or 3; R=alkyl or aryl groups; R'=R, H, or groups which, when
removed, yield glycol ethers with the structure: R-(OCH2CH)n-OH. Polymers are excluded from the
glycol category.
3 Includes mineral fiber emisions from facilities manufacturing or processing glass, rock, or slag fibers
(or ther mineral derived fibers) of average diameter 1 micrometer or less.
4 Includes organic compounds with more than one benzene ring, and which have a boiling point
greater than or equal to 100°C.
5 A type of atom which spontaneously undergoes radioactive decay.
A-8 September 30, 1997
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Petroleum Refinery MACT Standard Guidance
APPENDIX B. ORGANIC HAZARDOUS AIR POLLUTANTS
(ORGANIC HAPs)
Chemical Name
Benzene
Biphenyl
Butadiene (1,3)
Carbon disulfide
Carbonyl sulfide
Cresol (mixed isomers)
Cresol (m-)
Cresol (o-)
Cresol (p-)
Cumene
Dibromoethane (1,2) (ethylene debromide)
Dichloroethane (1,2)
Diethanolamine
Ethylbenzene
Ethylene glycol
Hexane
Methanol
Methyl ethyl ketone (2-butanone)
Methyl isobutyl ketone (hexone)
Methyl tert butyl ether
Naphthalene
Phenol
Toluene
Trimethylpentane (2,2,4)
71432
92524
10990
75150
463581
1319773
108394
95487
106445
98828
106934
107062
111422
100414
107211
110543
67561
78933
108101
1634044
91203
108952
108883
540841
B-1
September 30, 1997
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Petroleum Refinery MACT Standard Guidance
Chemical Name
Xylene (mixed isomers)
1330207
Xylene (m-)
108383
Xylene (o-)
95476
Xylene (p-)
106423
B-2
September 30, 1997
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Petroleum Refinery MACT Standard Guidance
APPENDIX C. U.S. PETROLUEM REFINERIES AFFECTED BY THE
PETROLEUM REFINERY STANDARDS
Facility Name
Tesoro Alaska Petroleum
Arco Alaska Inc.
Mapco Inc.
Petro Star Inc.
Arco Alaska Inc.
Petro Star Inc.
Coastal Mobile Refining Co.
Shell Oil Products Co.1
Hunt Refining Company Inc.
Lion Oil Co. Inc.
Cross Oil & Refining Co. Inc.
Berry Petroleum Co.
Anchor Refining Co.
Kern Oil & Refining Co.
San Joaquin Refining Co. Inc.
Sunland Refining Corp.
Texaco Refining and Marketing Inc.
Exxon Corporation
Huntway Refining Co.
Chevron USA Products Co.
Atlantic Richfield Co.
Unocal Corp.
Shell Martinez Refining Co.
City
Kenai
Kuparuk
North Pole
North Pole
Prudhoe Bay
Valdez
Chickasaw/Mobile Bay
Saraland
Tuscaloosa
El Dorado
Smackover
Stephens
McKittirck
Bakersfield
Bakersfield
Bakersfield
Bakersfield
Benecia
Benecia
El Segundo
Carson
Los Angeles/Wilmington
Martinez
State
AK
AK
AK
AK
AK
AK
AL
AL
AL
AR
AR
AR
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
72,000
12,000
128,200
10,000
15,000
26,300
16,500
76,000+
33,500
51,000
6,200
6,700
10,000+
21,400
24,300
12,000
56,000
128,000
8,600
230,000
255,000+
118,750+
148,900
C-1
September 30, 1997
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Petroleum Refinery MACT Standard Guidance
Facility Name
Tosco Corporation
Witco Corporation
Tenby Inc.
Paramount Petroleum Corp.
Chevron USA Products Co.
Santa Maria Refining Co.2
Unocal Corp.
Lunday Thagard Co.
Mobile Oil Corp.
Huntway Refining Co.
Texaco Refining and Marketing
Ultramar Inc.
Conoco Inc.
Total Petroleum Inc.3
Star Enterprise
Young Refining Corporation
Citgo Asphalt Refining Co.
BMP Hawaii Inc.
Chevron USA Products Co.
Clark Oil & Refining Corp.
Clark Oil & Refining Corp.
Mobil Oil Corporation
Indian Refining Partnership
Uno-Ven Company
Marathon Oil Company
Shell Wood River Refining Co.4
Laketon Refining Corp.
City
Martinez
Oildale
Oxnard
Paramount
Richmond
Santa Maria
San Francisco/Santa Maria
South Gate
Torrance
Wilmington
Wilimington
Wilmington
Commerce City
Denver
Delaware City
Douglasville
Savannah
Kapolei
Barbers Point
Blue Island
Hartford
Joliet
Lawrenceville
Lemont
Robinson
Wood River
Laketon
State
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CO
CO
DE
GA
GA
HI
HI
IL
IL
IL
IL
IL
IL
IL
IN
160,000
0
4,000
46,500
230,000
10,000+
103,645+
8,100
130,000
5,500
64,000
68,000
57,500
28,000+
140,000
5,540
28,000
93,500
54,000
80,515
62,500
188,000
80,750
147,000
175,000
271,000+
11,100
C-2
September 30, 1997
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Petroleum Refinery MACT Standard Guidance
Facility Name
Countrymark Cooperative Inc.
Amoco Oil Co.
Farmland Industries Inc.
Texaco Refining and Marketing Inc.
National Coop Refinery Assoc.
Ashland Petroleum Co.
Somerset Refinery Inc.
Exxon Corporation
BP Exploration & Oil Inc.
Mobil Oil Corporation
Canal Refining Co.
Star Enterprise
Calumet Lubricants Co.
Marathon Oil Company
Basis Petroleum, Inc.5
Calcasieu Refining Co.
Citgo Petroleum Coporation
American International Refining Inc.6
Cit-Con Oil Corp.
Murphy Oil USA Inc.
Shell Norco Refining Co.
Placid Refining Co.
Calumet Lubricants Co. Ltd.
Atlas Processing Co. Div. Of Pennzoil
Shell Chemical Co.7
Conoco Inc.
Lakeside Refining Co.
City
Mount Vernon
Whiting
Coffeyville
El Dorado
Me Pherson
Russell/Catlettsburg
Somerset
Baton Rouge
Belle Chasse
Chalmette
Church Point
Convent
Cotton Valley
Garyville
Krotz Springs
Lake Charles
Lake Charles
Lake Charles
Lake Charles
Meraux
Norco
Port Allen
Princeton
Shreveport
St. Rose
Westlake
Kalamazoo
State
IN
IN
KS
KS
KS
KY
KY
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
LA
Ml
22,000
410,000
68,600
94,600
75,600
213,400
5,500
424,000
231,500
170,000
9,500
225,000
7,800
255,000
67,100+
12,500
305,000
27,600+
7,350
100,000
215,000
48,500
8,200
46,200
40,000+
191,000
5,600+
C-3
September 30, 1997
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Petroleum Refinery MACT Standard Guidance
Facility Name
Total Petroleum Inc.
Marathon Oil Company
Koch Refining Company LP
Ashland Petroleum Co.
Southland Oil Company
Chevron USA Products Co.
Southland Oil Company
Ergon Inc.
Conoco Inc.
Exxon Co.
Montana Refining Co.
Cenex
Amoco Oil Co.
Tosco Refining Co.8
Citgo Asphalt Refining Co.
Mobil Oil Corp.
Chevron USA Products Co.
Amerada Hess Corporation
Coastal Eagle Point Oil Co.
Navajo Refining Company
Giant Refining Co.9
Giant Refining Co.
Petro Source Refining Partners
Ashland Petroleum Co.
BP Oil Co.
BP Oil Co.
Sun Refining & Marketing Co.10
City
Alma
Detroit
Rosemount
Saint Paul Park
Lumberton
Pascagoula
Sandersville
Vicksburg
Billings
Billings
Great Falls
Laurel
Mandan
Linden
Paulsboro
Paulsboro
Perth Amboy
Port Reading
Westville
Artesia
Bloomfield
Gallup
Eagle Springs
Canton
Lima
Toledo (Oregon)
Toledo
State
Ml
Ml
MN
MN
MS
MS
MS
MS
MT
MT
MT
MT
ND
NJ
NJ
NJ
NJ
NJ
NJ
NM
NM
NM
NV
OH
OH
OH
OH
45,600
70,000
230,000
67,100
5,800
295,000
11,000
23,000
49,500
44,000
7,000
41,450
58,000
240,000+
40,000
126,000
80,000
0
125,000
57,000
16,800+
20,800
7,000
66,000
161,000
136,000
125,000+
C-4
September 30, 1997
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Petroleum Refinery MACT Standard Guidance
Facility Name
Total Petroleum Inc.
Conoco Inc.
Sinclair Oil Corporation
Sun Refining & Marketing Co.
Gary-Williams Co.11
Chevron USA Products Co.12
Witco Corporation
Sun Refining & Marketing Co.
Sun Refining & Marketing Co.
Sun Refining & Marketing Co.
Pennzoil Products Company
United Refining Inc.
Mapco Petroleum Inc.
Pride Companies L P
Exxon Co. USA
Mobil Oil Corporation
Fina Oil and Chemical Co.
Phillips Petroleum Company
Howell Hydrocarbons & Chemicals Inc.
Citgo Petroleum Corp.15
Coastal Refining & Marketing Inc.
Koch Refining Company Inc.
Neste Trifinery Petroleum Services
Valero Refining Company
Deer Park Refining Ltd. Partnership
Chevron USA Products Co.
Basis Petroleum, Inc.16
City
Ardmore
Ponca City
Tulsa
Tulsa
Wynnewood
Portland (Willbridge)
Bradford
Marcus Hook
Philadelphia-Girard Pt13
Philadelphia-Pt. Breeze14
Rouseville
Warren
Memphis
Abilene
Baytown
Beaumont
Big Spring
Borger
Channelview
Corpus Christ!
Corpus Christ!
Corpus Christ!
Corpus Christ!
Corpus Christ!
Deer Park
El Paso
Houston
State
OK
OK
OK
OK
OK
OR
PA
PA
PA
PA
PA
PA
TN
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
68,000
140,000
54,000
85,000
45,000+
15,000+
10,000
175,000
177,000+
130,000+
15,700
60,000
89,000
42,750
396,000
315,000
55,000
110,000
1,400
130,000+
95,000
255,000
27,000
29,900
215,900
87,000
67,600+
C-5
September 30, 1997
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Petroleum Refinery MACT Standard Guidance
Facility Name
Lyondell-Citgo Refining Co.
Shell Odessa Refining Co.
Crown Central Petroleum Corp.
Clark Oil & Refining Corp.17
Fina Oil and Chemical Co.
Star Enterprise
Age Refining & Marketing
Diamond Shamrock Corp.
Diamond Shamrock Corp.
Phillips Petroleum Company
Amoco Oil Company
Marathon Oil Company
Basis Petroleum Inc.18
La Gloria Oil & Gas Co.
Big West Oil Company
Amoco Oil Company
Chevron USA Products Co.
Crysen Refining Inc.
Phillips Petroleum Company
Amoco Oil Company
Hess of Virgin Islands Corp.
Shell Anacortes Refin Co.19
Texaco Refining and Marketing
Atlantic Richfield Company
Tosco Corporation
Chevron USA Products Co.20
Sound Refining Inc.
City
Houston
Odessa
Pasadena
Port Arthur
Port Arthur
Port Arthur/Neches
San Antonio
Three Rivers
Sunray (Mckee)
Sweeny
Texas City
Texas City
Texas City
Tyler
Salt Lake City
Salt Lake City
Salt Lake City
Woods Cross
Woods Cross
Yorktown
St. Croix
Anacortes
Anacortes
Ferndale
Ferndale
Seattle
Tacoma
State
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
UT
UT
UT
UT
UT
VA
VI
WA
WA
WA
WA
WA
WA
265,000
28,600
100,000
185,000+
175,000
235,000
6,000
132,000
185,000
433,000
70,000
125,400+
55,000
24,000
44,000
45,000
12,500
25,000
53,000
505,000
108,200+
136,000
189,000
95,000
0+
11,900
C-6
September 30, 1997
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Petroleum Refinery MACT Standard Guidance
Facility Name
US Oil & Refining Co.
Murphy Oil USA Inc.
Quaker State oil Refining Corp.
Frontier Refining Inc.
Little America Refining Co.
Wyoming Refining Co.
Sinclair Oil Corporation
City
Tacoma
Superior
Newell
Cheyenne
Evansville/Casper
Newcastle
Sinclair
State
WA
Wl
WV
WY
WY
WY
WY
1994 Capacity
Units*
32,400
33,200
11,500
38,670
24,500
12,555
54,000
* Barrels/Calendar day (one barrel=42 U.S. Gallons). Data extracted from Report 1 -Comparative
Profile Petroleum Refining. EPA Regional or State Reviewers, Regional Review Draft. 10/25/96.
+ Charge Capacity, b/cd. Data extracted from Oil and Gas Journal. Dec. 23, 1996, pp. 85-94.
Endnotes:
1. Formerly LL&E Petroleum Marketing
2. Formerly Conoco
3. Formerly Colorado Refining
4. Possibly same refinery as Shell Oil Company in Roxana Wood River
5. Formerly Phibro Energy USA Inc.
6. Leases Gold Line Refining Ltd.
7. Formerly St. Rose Refining Inc.
8. Formerly Bayway Refining Company
9. Formerly Bloomfield Refining Company
10. Same as Sun Company Inc. (r &M)
11. Same as Kerr-Mcgee Refining Corp.
12. Same as Chevron U.S.A. Inc.
13. Previously combined with Point Breeze Refinery
14. Previously combined with Girard Point Refinery
15. Same as Citgo Refining and Chemical Inc.
16. Previouisly Phibro Energy USA Inc.
17. Formerly Chevron USA Inc.
18. Formerly Diamond Shamrock Corp. in Three Rivers, TX
19. Formerly Shell Oil Company
20. Same as Chevron USA Inc.
C-7
September 30, 1997
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Petroleum Refinery MACT Standard Guidance
APPENDIX D. ADDITIONAL RESOURCES FOR PETROLEUM REFINING
MACT STANDARD GUIDANCE DOCUMENT
DOCUMENTS/REPORTS AVAILABLE ON THE INTERNET:
Clean Air Act signed rules
134.67.104.12/html/caa/rules. htm
Includes compressed files of the Clean Air Act.
Sector Notebook: Profile of the Petroleum Refining Industry. EPA Office of
Compliance. September 1995.http://es.inel.gov/.
This sector notebook provides general information on the petroleum refining
industry, including: industrial processes, chemical releases and transfer profile, and
pollution prevention opportunities. The report also summarizes applicable federal
statutes and regulations, provides a compliance and enforcement history, and
presents compliance assurance and initiatives for the industry.
Air Toxics Regulations: Petroleum Refining. Final Air Toxics Rule for the
Petroleum Refining Industry. July 28, 1995.
www.epa.gov/oar/oaqps/airtox/fsrefine.html
Document written following EPA's issuance of final regulation to reduce emissions
of air toxics from petroleum refineries. Discusses health and environmental benefits
of new rule and flexibility of rule for the industry. Provides background and cost of
information, discusses who will be affected, and includes a FACT sheet.
AIRS Facility Subsystem (AFS Data) - USA Emissions Ranking Report - VOC
www.epa.gov/airs/afsd-voc.html
This report ranks the 100 largest stationary sources of volatile organic compounds
(VOC) emissions in the United States, as of February 28, 1997.
AIRS Facility Subsystem (AFS Data) - USA Emissions Ranking Report - CO
www.epa.gov/airs/afsd-co.html
This report ranks the 100 largest stationary sources of carbon monoxide (CO)
emissions in the United States, as of February 28, 1997.
D-1 September 30, 1997
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Petroleum Refinery MACT Standard Guidance
National Ambient Air Quality Standards (NAAQS)
www.epa.gov/airs/criteria.html
Document lists EPA's national standards set for the six principal pollutants, called
"criteria" pollutants.
EPA Operating Permits Program -- Information
www.epa.gov/oar/oaqps/permits/
Provides a mechanism for gathering all the federal, state, and local requirements
applicable to air pollution sources. Answers questions like: What are the
requirements? What guidance has been prepared? Who are responsible for
implementing the permits programs? What is the approval status for each of the
state and local permitting authorities? What changes are coming?
Environment Canada
www.ns.doe.ca/soe/ch4-31 .html
State of the Environment in Atlantic Region report. Includes chapters describing
process releases from petroleum refining and presents data on air emissions from
refineries.
Center for Transportation and Analysis
www-cta.ornl.gov/data/tedb15/tab21 .htm
Includes the table Refinery Yield of Petroleum Products from a Barrel of Crude Oil,
1978-1993(a).
WEBSITES
t/.S. EPA Office of Air and Radiation (OAR):
OAR Homepage
www.epa.gov/oar/
Includes information on prevention and air toxics. Lists publications, regulations,
and resources. Provides search tool.
OAR Regulations
www.epa.gov/oar/oarregul.html
Contains information on Clean Air Act documents, Clean Air Act operating permits
program, ozone depletion regulations, OAQPS air regulations - schedule, air toxics
regulations - fact sheets, and other regulations, including the federal register online.
OAR Resources
D-2 September 30, 1997
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Petroleum Refinery MACT Standard Guidance
www. epa.gov/oar/oarrsrc. htm I
Lists various services, networks, webpages, databases, software, and contacts that
may be useful.
U.S. EPA Office of Air Quality Planning and Standards (OAQPS):
Transfer Technology Network 2000 (TTN 2000) Home Page
www.epa.gov/oar/ttn_bbs.html
Provides access to various electronic bulletin board systems containing information
about many areas of air pollution science, technology, regulation, measurement,
and prevention. Serves as a public forum for the exchange of technical information
and ideas among users and EPA staff. Includes tools to: 1) estimate air pollutant
emissions, 2) download computer code for regulatory models, 3) read summaries or
details of the Clean Air Act, 4) find a course offered by the Air Pollution Training
Institute, or 5) seek technical support in implementing air pollution programs.
Unified Air Toxics Website: Home Page
www.epa.gov/oar/oaqps/airtox/
Contains basic facts, summaries of EPA regulations, information on pollutants and
sources of pollutants, technical resources, EPA program and contacts, and state
and local programs.
Unified Air Toxics Website: Pollutants & Sources
www.epa.gov/oar/oaqps/airtox/pollsour.html
Provides a list of 188 toxic air pollutants to be regulated by EPA, defines the types
of sources of pollutants, and provides a list of 174 categories of industrial and
commercial sources that emit toxic air pollutants.
Unified Air Toxics Website: EPA Programs
www.epa.gov/oar/oaqps/airtox/epaprogs.html
Describes the following three programs: Hazardous Air Pollutants Strategic
Implementation Plan, National Emission Standards for Hazardous Air Pollutants
(NESHAP), and Maximum Achievable Control Technology (MACT) Standards.
Publications
www.epa.gov/oar/oaqps/publicat.html
Contains air quality and emissions trend reports, newsletters, fact sheets, and
various guides to evaluating exposure to air pollutants.
American Petroleum Institute (API)
D-3 September 30, 1997
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Petroleum Refinery MACT Standard Guidance
www.api.org/
Representing the Nation's oil and gas industries. Contains industry data, facts
about the petroleum industry, and publications such as: NOX Emissions from
Petroleum Industry Operations, October 1979; Petroleum Emission Factor
Information Retrieval System (PEFIRS), July 1993; The Cost Effectiveness of
Carbon Dioxide from Petroleum Sources, July 1991; and, Electric Exchange of
Environmental Compliance Information: A Proposed Approach, August 1995.
One of many documents available from API is the Summary of Question and
Answer Sessions for American Petroleum Institute's Refinery MACT Rule
Workshop. October 23-24, 1995.
D-4 September 30, 1997
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Petroleum Refinery MACT Standard Guidance
APPENDIX E. DEFINITIONS
Affected source means the combination of all emission points at a petroleum refinery.
Each point is considered part of the single affected source.
Boiler means any closed combustion device that extracts useful energy in the form of
steam and is not an incinerator.
Closed vent system means a system that is not open to the atmosphere and is
composed of piping, ductwork, connections, and, if necessary, flow inducing devices
that transport gas and vapor from an emission point to a control device or back into the
process. If gas or vapor from regulated equipment is routed to a process (e.g.,
petroleum refinery fuel gas system), the process is not considered a closed vent system
and is not subject to the closed vent system standards.
Combustion device means an individual unit of equipment such as a flare, incinerator,
process heater, or boiler used for the combustion of organic hazardous air pollutant
(HAP) vapors.
Construction means the on-site fabrication, erection, or installation of an affected
source.
Control device means any equipment used for recovering, removing, or oxidizing
hazardous organic pollutants (HAPs). Such equipment includes, but is not limited to,
absorbers, carbon absorbers, condensers, incinerators, flares, boilers, and process
heaters.
Deck fitting controls means the fittings that pass through or are attached to the deck
or roof of a floating roof tank, and include hatches, gauge floats, and support columns.
Controls may be installed to minimize evaporative losses from the fittings.
Double-seal system means a floating roof having both primary and secondary seals.
Dwell time means the time feeds spend in a reactor (allowing for reactions to occur) or
the time feeds or products spend in a tank.
Emissions averaging means a method of complying with emission limitations, whereby
the affected source may create emission credits by reducing emissions from specific
points to a level below that required by the relevant standard, and those credits are
used to offset emissions from points that are not controlled to the level required by the
relevant standard.
E-1 September 30, 1997
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Petroleum Refinery MACT Standard Guidance
Emission point means an individual miscellaneous process vent, storage vessel,
wastewater stream, or equipment leak associated with a petroleum refining process
unit; an individual storage vessel or equipment leak associated with a bulk gasoline
terminal or pipeline breakout station classified under SIC 2911; a gasoline loading rack
classified under SIC 2911; or a marine tank vessel loading operation located at a
petroleum refinery.
Existing source means a source that commenced construction on or before July 14,
1994.
External floating roof means a pontoon-type or double-deck-type cover that rests on
the liquid surface in a storage vessel or waste management unit with no fixed roof.
Firebox means a chamber (e.g., boiler) where fuels are burned.
Fixed roof means a cover that is mounted on a storage vessel or waste management
unit in a stationary manner and that does not move with fluctuations in liquid level.
Flame zone means the portion of a combustion chamber of a boiler or process heater
occupied by the flame envelope.
Flare means a device used in refineries to combust undesirable volatile gases (e.g.,
methane, ethane, hydrogen sulfide) from process units. Flares also take momentary
surges in gas manufacturing by burning the excess. When burned, these gases are
converted to more favorable compounds which can be emitted into the air.
Flow indicator means a device that indicates whether gas is flowing, or whether the
valve position would allow gas to flow, in a line.
Hazardous organic pollutant or HAP means one of the 188 chemicals listed in section
112(b) of the Clean Air Act, and listed in Appendix A of this manual.
Incinerator means an enclosed combustion device that is used for destroying organic
compounds. Auxiliary fuel may be used to heat waste gas to combustion temperatures.
Any energy recovery section is a separate section following the combustion section and
the two are joined by ducts or connections carrying flue gas.
Internal floating roof means a cover that rests or floats on the liquid surface (but not
necessarily in complete contact with it) inside a storage vessel or waste management
unit that has a permanently affixed roof.
Major source means a source that has the potential to emit 10 tons per year or more
annually of any of the 188 listed hazardous air pollutants (HAPs), or 25 tons per year or
more annually of any combination of HAPs.
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Petroleum Refinery MACT Standard Guidance
Malfunction means any sudden, infrequent, and not reasonably preventable failure of
air pollution control equipment, process equipment, or a process to operate in a normal
or usual manner. Failures that are caused in part by poor maintenance or careless
operation are not malfunctions.
Maximum achievable control technology or MACT means demonstrated
technologies which may be used to achieve acceptable air emissions limits for specific
compounds.
Maximum true vapor pressure means the equilibrium partial pressure exerted by the
stored liquid at the temperature equal to the highest calendar-month average of the
liquid storage temperature for liquids stored above or below the ambient temperature or
at the local maximum monthly average temperature as reported by the National
Weather Service for liquids stored at the ambient temperature.
New source means a source that commenced construction after July 14, 1994.
Organic hazardous air pollutant or organic HAP means any of the 28 organic
chemicals listed in Appendix B of this manual.
Primary seal means the seal that slides against a wall of a floating roof tank as the roof
is raised and lowered. It closes the annular space between the roof and tank wall and
can be constructed of metal or polymer.
Process heater means an enclosed combustion device that primarily transfers heat
liberated by burning fuel directly to process streams or to heat transfer liquids other than
water.
Process unit means the equipment assembled and connected by pipes or ducts to
process raw and/or intermediate materials and to manufacture an intended product. A
process unit includes any associated storage vessels, and includes, but is not limited to,
chemical manufacturing process units and petroleum refining process units.
Reconstruction means the replacement of components of an affected or a previously
unaffected stationary source to the extent that:
(1) The fixed capital cost of the new component exceeds 50 percent of the fixed
capital cost that would be required to construct a comparable new source; and
(2) It is technologically and economically feasible for the reconstructed source to
meet the relevant standard(s) established by the Administrator (or a state)
pursuant to Section 112 of the Clean Air Act.
Recovery device means an individual unit of equipment capable of and used for the
purpose of recovering chemicals for use, reuse, or sale. Recovery devices include, but
are not limited to, absorbers, carbon absorbers, and condensers.
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Petroleum Refinery MACT Standard Guidance
Secondary seal means the seal that provides addition evaporative loss control. It is
mounted on the roof rim or tank wall over the primary seal.
Single-seal system means a floating roof having one continuous seal that completely
covers the space between the wall of the storage vessel and the edge of the floating
roof.
Total organic compound or TOO means those compounds, excluding methane and
ethane, measured according to the procedures of method 18 of 40 CFR 60 Appendix A.
Method 25A may be used alone or in combination with Method 18 to measure TOC as
provided in 40 CFR 63.645.
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Petroleum Refinery MACT Standard Guidance
APPENDIX F. COMPLIANCE CHECKLIST FOR THE
PETROLEUM REFINERY MACT STANDARD
40 CFR PART 63, SUBPART CC
SEPTEMBER 9,1997
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TABLE OF CONTENTS
I. GENERAL APPLICABILITY F-4
II. APPLICABILITY FOR SPECIFIC EMISSION POINTS F-5
A. Miscellaneous Process Vents F-5
B. Storage Vessels F-6
C. Wastewater Streams F-8
D. Gasoline Loading Racks F-8
E. Marine Tank Vessel Loading F-8
F. Equipment Leaks F-9
III. COMPLIANCE DEADLINES F-9
A. All new sources F-10
B. Existing Miscellaneous Process Vents and Gasoline Loading Racks F-10
C. Existing Wastewater Streams F-10
D. Existing Storage Vessels F-10
E. Marine Tank Vessel Loading Operations F-10
F. Equipment Leaks F-10
IV. GENERAL STANDARDS F-10
A. Performance Testing F-10
B. Operating Permits F-11
C. Application for Approval of Construction or Reconstruction F-11
D. Notification of Compliance Status (NCS) Reports F-11
E. Periodic Reports F-11
F. Startup, Shutdown and Malfunction Plans and Reports F-12
G. Reports Required for Special Situations F-13
H. Requests for Extension of Compliance F-13
I. Applications for a Performance Test Waiver F-14
J. Recordkeeping F-14
V. REQUIREMENTS FOR MISCELLANEOUS PROCESS VENTS F-15
A. Miscellaneous Process Vents Control Requirements F-15
B. Miscellaneous Process Vents Testing Requirements F-15
C. Miscellaneous Process Vents Monitoring Requirements F-17
D. Miscellaneous Process Vents Reporting Requirements F-18
VI. REQUIREMENTS FOR STORAGE VESSELS F-21
A. Control Requirements for Storage Vessels F-21
B. Testing Requirements for Storage Vessels F-22
C. Monitoring and Inspection Requirements for Storage Vessels for Storage Vessels
Required to Apply Controls F-22
D. Reporting Requirements for Storage Vessels Equipped with Closed
Vent Systems F-24
E. Recordkeeping Requirements for Storage Vessels F-27
VII. REQUIREMENTS FOR WASTEWATER STREAMS F-28
A. Control Requirements for Wastewater Streams F-28
B. Testing and Monitoring Requirements for Wastewater Streams F-28
C. Reporting and Recordkeeping Requirements for Wastewater Streams F-28
VIM. REQUIREMENTS FOR GASOLINE LOADING RACKS F-29
A. Control Requirements for Gasoline Loading Racks F-29
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B. Testing and Monitoring Requirements for Gasoline Loading Racks F-29
C. Reporting and Recordkeeping Requirements for Gasoline Loading Racks F-30
IX. REQUIREMENTS FOR MARINE TANK VESSEL LOADING F-31
A. Control Requirements for Marine Tank Vessel Loading F-31
B. Testing and Monitoring Requirements for Marine Tank Vessel Loading F-31
C. Reporting and Recordkeeping Requirements for Marine Tank
Vessel Loading F-31
X. REQUIREMENTS FOR EQUIPMENT LEAKS F-31
A. Control Requirements for Equipment Leaks F-31
B. Testing, Inspection, and Monitoring Requirements for Equipment Leaks F-32
C. Reporting and Recordkeeping Requirements for Equipment Leaks F-32
XI. EMISSIONS AVERAGING F-32
A. Emissions Averaging Applicability F-32
B. Emissions Averaging Credit/Debit System F-32
C. Approval of Emissions Averaging Plan F-34
D. Testing, Monitoring, Reporting, and Recordkeeping for Emissions F-34
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GENERAL APPLICABILITY
1. Is the refinery a major HAP source?
[ ] Potential to emit > 10 tons per year (tpy) of any of the 188 HAPs listed in §
112(b) of the Clean Air Act; or
[ ] Potential to emit > 25 tpy of total HAPs.
Yes
No
2.
Do the refining process units at refineries that are major HAP sources emit or
contain any of the following 28 organic HAPs? Please check the substances
below that apply.
Yes
No
Benzene
Biphenyl
Butadiene (1,3)
Carbon disulfide
Carbonyl sulfide
Cresol (mixed isomers)
Cresol (m-)
Cresol (o-)
Cresol (p-)
Cumene
Dibromoethane (1,2)
(ethylene dibromide)
Dichloroethane (1,2)
Diethanolamine
Ethylbenzene
Ethylene glycol
Hexane
Methanol
Methyl ethyl ketone (2-butanone)
Methyl isobutyl ketone (hexone)
Methyl tert butyl ether
Naphthalene
Phenol
Toluene
Trimethylpentane (2,2,4)
Xylene (mixed isomers)
[ ] Xylene (m-)
Xylene (o-)
Xylene (p-)
3. Are any of the following emission points located within petroleum refining
process units? Please check the emission points below that apply.
[ ] Miscellaneous process vents that contain > 20 ppmv total organic HAP
[ ] Storage vessels (pressure vessels and vessels < m3 are exempt)
[ ] Wastewater streams and treatment operations
[ ] Equipment containing or contacting a fluid that is > 5% by weight total
organic HAPs
Yes
No
4. Are any of the following emission points located at a refinery that is a major
source? Please check the emission points below that apply.
[ ] Marine vessel loading operations
[ ] Gasoline loading racks in SIC 2911
[ ] Storage vessels and equipment leaks associated with bulk gasoline
terminals in SIC 2911
Yes
No[ ]
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I. APPLICABILITY FOR SPECIFIC EMISSION POINTS
A. Miscellaneous Process Vents
1. Does the vent contain a gas stream with > 20 ppmv organic HAP and is it
continuously or periodically discharged during normal operations?
Yes
No
2. Is the vent or gas stream any of the following? Please check the descriptions
below that apply.
[ ] Directly discharged to the atmosphere
[ ] Routed to a control device prior to discharge to the atmosphere
[ ] Diverted to a product recovery prior to control or discharge to the
atmosphere
Note: The above list gives examples of vent or gas streams and may not be all
inclusive.
Yes
No
3. Does the vent or gas stream come from any of the following? Please check
the items below that apply.
] Gas streams routed to a fuel gas system
] Relief valve discharges
] Leaks from equipment regulated under 40 CFR 63.648
] Episodic or nonroutine releases such as maintenance or upsets
] In situ sampling systems (on stream analyzers)
] Catalytic cracking unit catalyst regeneration vents
] Catalytic reformer regeneration vents
] Sulfur plant vents
] Vents from control devices
] Vents from any stripping operations applied to comply with the wastewater
provisions of 40 CFR 63 Subpart CC, G, or FF
[ ] Coking unit vents associated with coke drum, depressuring at or below a
coke drum outlet pressure of 15 pounds per square inch gauge,
deheading, draining, ordecoking (coke cutting) or pressure testing after
decoking
[ ] Vents from storage vessels
[ ] Emissions from wastewater collection and conveyance systems
Note: If the answer to question 3 is "Yes", the miscellaneous process vents
provision does not apply.
Yes
No
4. Does the vent or gas stream come from any of the following? Please check
the items below that apply.
Yes
No
[ ] Caustic wash accumulators
[ ] Distillation lower condensers/
accumulators
[ ] Slowdown condenser/
accumulators
[ ] Flash/knockout drums
[ ] Scrubber overheads
Stripper overheads
Vacuum accumulators
Delayed coker vents
Reactor vessels
Note: The above list gives examples of where vent or gas streams originate and
may not be all inclusive.
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5. Is the vent associated with an existing or new source?
[ ] Existing source
[ ] New source
Existing sources - sources that commenced construction on or before July 14,
1994.
New sources - sources that commenced construction after July 14, 1994. A
process unit constructed at an existing source is subject to new source
requirements if the new unit has the potential to emit 10 tons per year (tpy) or more
of any one HAP or 25 tpy or more of total HAPs. Otherwise it is subject to existing
source standards. A change to an existing source or an addition of an emission
point is subject to existing source standards, unless it is a reconstructed source,
which is subject to new source standards.
For an existing source:
6. Is the organic HAP concentration > 20 ppmv, and total VOC emissions > 33
kg/day?
Note: If the answer to question 6 is "Yes", it is a Group 1 miscellaneous process
vent. If the answer is "No", it is a Group 2 miscellaneous process vent.
Fora new source:
7. Is the organic HAP concentration > 20 ppmv, and total VOC emissions > 6.8
kg/day?
Note: If the answer to question 7 is "Yes", it is a Group 1 miscellaneous process
vent. If the answer is "No", it is a Group 2 miscellaneous process vent.
B. Storage Vessels
1 . Is it a tank or other vessel used to store organic liquids?
2. Is it permanently attached to a motor vehicle such as a truck, railcar, barge, or
ship?
3. Is it a pressure vessel designed to operate in excess of 204.9 kPa and without
emission to the atmosphere?
4. Does it have a capacity less than 40 m3?
5. Is it used as a bottoms receiver tank?
6. Is it used as a wastewater storage tank?
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes[ ] No[ ]
Yes [ ] No [ ]
Yes[ ] No[ ]
Yes [ ] No [ ]
Yes[ ] No[ ]
Yes[ ] No[ ]
Note: If any of the answers to questions 2 through 6 is "Yes", the storage vessels provision does not
apply.
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7. Is tank associated with an existing or new source?
[ ] Existing source
[ ] New source
Existing sources - sources that commenced construction on or before July 14,
1994;
New sources - sources that commenced construction after July 14, 1994. A
process unit constructed at an existing source is subject to new source
requirements if the new unit has the potential to emit 10 tons per year (tpy) or more
of any one HAP or 25 tpy or more of total HAPs. Otherwise it is subject to existing
source standards. A change to an existing source or an addition of an emission
point is subject to existing source standards, unless it is a reconstructed source,
which is subject to new source standards.
For an existing source:
8. Is the capacity > 177 m3 and vapor pressure > 10.4 kPa (maximum) and
kPa (annual average) and liquid HAP content > 4% by weight (annual
average)?
Note: If the answer to question 8 is "Yes", it is a Group 1 storage vessel. If the
answer is "No", it is a Group 2 storage vessel.
8.3
Yes
No
For a new source:
9.
Is the capacity > 151 m3 and vapor pressure > 3.4 kPa (maximum) and
liquid HAP content > 2% by weight (annual average)?
OR
10. Is the capacity between 76 and 151m3 and vapor pressure > 77 kPa
(maximum) and liquid HAP > 2% by weight (annual average)?
Note: If the answer to question 9 or 10 is "Yes", it is a Group 1 storage vessel.
both answers are "No", it is a Group 2 storage vessel.
Yes
Yes
No
No
C. Wastewater Streams
1. Is it water or wastewater that, during production or processing:
Comes into direct contact with or results from the production or use of any raw
material, intermediate product, finished product, byproduct, or waste product?
Is discharged into any individual drain system?
Yes
Yes
No
No
2. Does refinery have a total annual benzene loading > 10 megagrams per year,
and a flow rate > 0.02 liters per minute, and benzene concentration > 10 ppm
by weight, and subject to control requirements under 40 CFR 61 Subpart FF?
Note: Wastewater streams applicability criteria are the same for existing and new
sources. If the answer to question 2 is "Yes", it is a Group 1 wastewater stream. If
the answer is "No", it is a Group 2 wastewater stream.
Yes
No
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D. Gasoline Loading Racks
1 . Is it any of the following equipment, which is necessary to fill gasoline cargo
tanks? Please check the equipment below that applies.
[ ] Loading arms [ ] Shutoff valves
[ ] Pumps [ ] Relief valves
[ ] Meters [ ] Other piping and valves
2. Is it a gasoline loading rack classified under SIC 291 1 ?
3. Does it have a gasoline throughput > 75,700 liters (20,000 gallons) per day?
Note: Gasoline loading racks applicability criteria are the same for existing and
new sources. If the answer to question 3 is "Yes", it is a Group 1 gasoline loading
rack. If the answer is "No", it is a Group 2 gasoline loading rack.
E. Marine Tank Vessel Loading
1 . Is it a land- or sea-based terminal or structure that loads liquid commodities in
bulk onto marine tank vessel loading?
2. Is vessel loading associated with an existing or new source?
[ ] Existing source
[ ] New source
Existing sources - sources that commenced construction on or before July 14,
1994;
New sources - sources that commenced construction after July 14, 1994. A
process unit constructed at an existing source is subject to new source
requirements if the new unit has the potential to emit 10 tons per year (tpy) or more
of any one HAP or 25 tpy or more of total HAPs. Otherwise it is subject to existing
source standards. A change to an existing source or an addition of an emission
point is subject to existing source standards, unless it is a reconstructed source,
which is subject to new source standards.
For an existing source:
3. Is vapor pressure of liquid loaded > 1 0.3 kPa and emissions > 9.1 megagrams
of any one HAP or> 22.7 megagrams of total HAPs per year?
Note: If the answer to question 3 is "Yes", it is a Group 1 marine tank vessel
loading. If the answer is "No", it is a Group 2 marine tank vessel loading.
For a new source:
4. Is vapor pressure of liquid loaded > 1 0.3 kPa?
Note: If the answer to question 4 is "Yes", it is a Group 1 marine tank vessel
loading. If the answer is "No", it is a Group 2 marine tank vessel loading.
Yes[ ] No[ ]
Yes[ ] No[ ]
Yes [ ] No [ ]
Yes[ ] No[ ]
Yes[ ] No[ ]
Yes[ ] No[ ]
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F. Equipment Leaks
1. Is it a vent from a wastewater system drain, tank mixer, or sample valve on a
storage tank?
Note: If the answer to question 1 is "Yes", the equipment leaks provision does not
apply.
Yes
No
2. Is it an emission of organic HAPs from any of the following which is/are "iri
organic hazardous air pollutant service" (equipment containing or contacting
fluid > 5% by weight total organic HAP):
pump?
compressor?
pressure relief device?
sampling connection system?
open-ended valve or line?
valve?
instrumentation system?
Note: Equipment leaks applicability criteria are the same for existing and new
sources.
Note to inspector. The applicability sections of this checklist (i.e., General
Applicability and Applicability for Specific Emission Points) determines whether the
Petroleum Refinery MACT Standard applies to a particular refinery, and whether it
applies to a particular emission point. Unless otherwise noted, refineries are
required to control emissions from all Group 1 emission points to which the MACT
standard applies. Group 2 emission points are subject only to recordkeeping
requirements unless otherwise noted in the inspection guide.
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
I. COMPLIANCE DEADLINES
A.
B.
C.
All new sources
Were all emission points in compliance at startup or by August 1 8, 1 995,
whichever was later?
Existing Miscellaneous Process Vents and Gasoline Loading Racks
Were all emission points in compliance by August 18, 1998?
Existing Wastewater Streams
1 . Were all emission points in compliance by August 1 8, 1 998?
2. Are all wastewater streams in compliance with the benzene waste
operations NESHAP (40 CFR 61 , Subpart FF)?
D.
Existing Storage Vessels
1 . Were all fixed roof vessels in compliance by August 1 8, 1 998?
2. Were fixed roof vessels for which the tanks that must be replaced in
compliance by August 18, 1999?
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
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3. Were floating roof vessels in compliance by August 18, 2005, or the next
scheduled maintenance and degassing after August 18, 1998, whichever
is first?
E. Marine Tank Vessel Loading Operations
1. Were operations in compliance by August 18, 1999?
2. Are operations used to generate credit in an emissions average?
If yes, were operations in compliance by August 18, 1998?
If operations were not in compliance by August 1 8, 1 998, was a case-by-
case 1 -year extension granted?
F. Equipment Leaks
1 . Were equipment leaks in compliance by August 1 8, 1 998?
2. For sources that are complying with 40 CFR 60 Subpart VV or 40 CFR 63
Subpart H, are they meeting the deadlines in the 3 phases of emissions
reductions?
Yes[ ]
Yes[ ]
Yes[ ]
Yes[ ]
Yes[ ]
Yes[ ]
Yes[ ]
No[ ]
No[ ]
No[ ]
No[ ]
No[ ]
No[ ]
No[ ]
IV. GENERAL STANDARDS TO ALL APPLICABLE EMISSIONS POINTS
A.
Performance Testing
1 . Did the facility conduct and initial performance test of all pollution control
equipment for which it is required?
(See Section I of this checklist for applicability. If the pollution control
equipment is required by the MACT standard, an initial performance test is
required. Note that no performance tests are required for floating roofs or
process heaters > 44 MWwith vent introduced into the flame zone.)
2. Was the initial performance test approved by EPA?
3. Did the facility notify the regulatory authority 30 days prior to conductinq
each performance test?
4. Were the tests conducted at the maximum representative operating
capacity?
Were controls operating at either maximum or minimum representative
operating conditions for monitored parameters, whichever result in
lower emission reduction? [40 CFR 63.642 (d)(3)])
B.
C.
Operating Permits
Did the owner or operator of the source subject to the standard apply for a one-
time Part 70 or Part 71 operating permit from the appropriate authority?
Application for Approval of Construction or Reconstruction
If the source is a new or reconstructed source, did it submit an application for
approval of construction or reconstruction?
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
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D. Notification of Compliance Status (NCS) Reports
1 . Did the facility submit a Notification of Compliance Status (NCS) within 1 50
days after each applicable compliance deadline?
(See part III of this checklist for applicable compliance deadlines.)
Note: The NCS report may be included as a separate report, as an operating
permit application, or in an amendment to an operating permit application).
2. Did the report identify each emission point and method of compliance?
3. Did the report include the following:
a) Information on individual emission points to demonstrate compliance, such
as range of monitored parameters? [40 CFR 63.654(f)(1) and (f)(3)]
b) Results of continuous monitoring system performance evaluations? [40
CFR 63.654(0(4)]
5. If the facility was required to conduct initial performance tests, did it submit
one example complete test report for each test method used?
Note: For additional tests using the same method, only the results of the each
additional test must be submitted. [40 CFR 63.654 (f)(2)]
E. Periodic Reports
1 . Have any compliance exceptions occurred within any 6-month reporting
period?
a) If yes, has the facility submitted periodic reports within 60 days after
the end of each 6- month period?
b) If the facility uses emissions averaging, has the facility submitted
reports quarterly? [40 CFR 63.654(g)]
F. Startup, Shutdown and Malfunction Plans and Reports
1 . Has the facility developed and implemented a startup, shutdown, and
malfunction plan for the entire facility?
a) If yes, does the malfunction plan describe procedures for operatinq and
maintaining the source during periods of startup, shutdown, and
malfunction?
b) Does the plan also include a program of corrective action for malfunction
of process and air pollution control equipment used to comply with the
relevant standard?
Note: EPA typically defines malfunctions as rare, unforeseeable occurrences and
does not allow for facilities to operate in malfunction for extended periods of time.
2. Has the facility prepared a Startup, Shutdown, and Malfunction Report to
document each:
a) Start of operation of a process unit for production?
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
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b) Cessation of a process unit for maintenance, repair, or equipment
replacement?
c) Malfunction of a process unit?
3. Are corrective actions to address each malfunction consistent with the
startup, shutdown, and malfunction plan?
a) If yes, has the facility submitted a statement to this effect in the semi-
annual report? [40 CFR 63.10(d)(5)(l)]
b) If a malfunction occurs and corrective actions are not consistent with the
startup, shutdown, and malfunction plan, has the facility completed the
following after each malfunction [40 CFR63.10(d)(5)(ii)]:
1) Called the regulatory authority within 2 days after inconsistent
corrective actions commence?
2) Submitted a letter within 7 days containing:
- Circumstances of the event?
- The reasons for not following the startup, shutdown, and
malfunction plan?
- Whether any excess emissions and/or parameter monitoring
exceedances occurred?
Note: If a malfunction does not occur during a reporting period, a startup,
shutdown, and malfunction report is not required.
G.
Reports Required for Special Situations
1 . Does the facility use/intend to use alternative procedures (e.q., procedures
other than those described in the MACT Standard) or devices to comply
with the MACT standard?
a) If yes, has the facility submitted the following information 18 months
before the compliance date for existing sources, or with the approval of
construction for new sources:
Determination of rule applicability to flexible operation units and
storage vessels and distillation units for which use varies from year
to year? [40 CFR 63.654(h)(6)]
Request for approval to monitor an alternative control device
operating parameter, with supporting justification? [40 CFR
63.654(h)(4)]
Request for approval to use data compression systems instead of
keeping hourly records, with supporting information? [40 CFR
63.654(h)(5)]
Request to use other alternative monitoring methods, with
supporting justification? [40 CFR 63.654(h)(5)(iv) and
63.8(f)(4)(ii)]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
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Request to establish an alternative emission standard, with a test
plan or results of testing and monitoring? [40 CFR 63.6(g)(2)]
Note: If EPA finds the alternative standard equivalent to the MACT standard, EPA
will request public comment and publish a Federal Register notice allowing its use.
Prior to conducting the inspection, the inspector should determine whether EPA
has recently adopted any alternative standards equivalent to the MACT standard,
with which the facility intends to comply.
H. Requests for Extension of Compliance
1 . Has the facility requested an extension of compliance either:
a) at least 12 months before the compliance date? or
b) 1 8 months prior if emissions averaging is used?
Note: Facilities may request an extension of compliance if emissions reductions
been achieved early, or is the source is unable to comply with the relevant
standard. Requests for an extension of compliance can only be made for existing
sources.
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
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2. If the facility submitted a request for an extension, did the request include
the following:
a) Description of controls to be installed?
b) Compliance schedule?
c) Interim emission control steps?
1. Applications for a Performance Test Waiver
1 . Is the facility unable to conduct a performance test for reasons such as
technical or economic infeasibility, or other reasons, has an extension of
compliance been requested?
2. If yes, has the facility submitted an application for waiver of a performance
test to the Administrator?
3. Did the application include information justifying the request and detailing
the infeasibility? [40 CFR 63.7(h)(3)(iii)]
J. Recordkeeping
1 . Does the facility keep records of reports submitted, monitoring results, and
other records for at least 5 years? [40 CFR 63.642(e) and 63.654(l)(4)]
2. Are records kept so that they are accessible within 24 hours of request in
either hard copy or computer-readable form? [40 CFR 63.642(e)]
3. Are the following records maintained on site:
Records of the occurrence and duration of each startup, shutdown, or
malfunction of operation and air pollution control equipment? [40 CFR
63.10(b)(2)(l-ii)]
Records of actions that are consistent and inconsistent with the
startup, shutdown, and malfunction plan? [40 CFR 63.10(b)(2)(iv-v)]
Records of continuous monitorinq system calibration checks (if
continuous monitoring is required)? [40 CFR 63.10(b)(x)]
Records for storaqe vessels?. [40 CFR 63.654(l)(1)l
Complete test reports and reported results for any required
performance tests? [64.654(l)(2)]
Values of continuously monitored parameters? [40 CFR 63.654(l)(3)]
Any additional records required by permit?
Yes[ ]
Yes[ ]
Yes[ ]
Yes[ ]
Yes[ ]
Yes[ ]
Yes[ ]
Yes[ ]
Yes[ ]
Yes[ ]
Yes[ ]
Yes[ ]
Yes[ ]
Yes[ ]
Yes[ ]
No[ ]
No[ ]
No[ ]
No[ ]
No[ ]
No[ ]
No[ ]
No[ ]
No[ ]
No[ ]
No[ ]
No[ ]
No[ ]
No[ ]
No[ ]
F-14
September 30, 1997
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Petroleum Refinery MACT Standard Guidance
V. REQUIREMENTS FOR MISCELLANEOUS PROCESS VENTS
A. Miscellaneous Process Vents Control Requirements
1 . Is the source an existing source, and the vent contains 20 ppmv or more
of organic HAPs, and emits 33 kg/day or more of total VOCs?
2. Is the source a new source, and the vent contains 20 ppmv or more of
organic HAPs, and emits 6.8 kg/day or more of VOCs?
a) If yes to 1 or 2, does the facility control its Miscellaneous Process
Vents by:
Using a flare? or
Reducing organic HAPs by 98% or to 20 ppmv using incinerators,
boilers, process heaters, or other devices? or
If a boiler or process heater is used, the vent stream must be
introduced into the flame zone of the control device, or in a
location such that the required percent reduction or concentration
is achieved?
B. Miscellaneous Process Vents Testing Requirements
1. Initial Performance Tests
a) Vents routed to a flare
Does the facility control Miscellaneous Process Vents emissions by
routing vents to a flare or by using other control devices?
1) If the facility uses a flare, has the facility conducted an initial
performance test for each control device?
2) Did the initial performance test show that the flare is operating
properly, and that the emission rate does not exceed the capacity
of the flame to control the emissions?
3) For vents routed to a flare, did the initial performance test
measure the following:
Emissions visibility?
Net heat value of combusted gas?
Flow rate of gases being combusted?
b) Vents routed to an incinerator or a boiler or process heater < 44
MW
For vents routed to an incinerator or a boiler or process heater < 44
MW (1 50 MMBtu/hr) where the vent streams are not introduced into
the flame zone of the boiler or process heater, did the initial
performance test show compliance with the requirement to reduce
organic HAPs by 98% or to 20 ppmv? [40 CFR 63.645 and 63.116
except (d) and (e)]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
F-15
September 30, 1997
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Petroleum Refinery MACT Standard Guidance
c) Vents routed to other control devices
Does the facility control Miscellaneous Process Vents emissions with:
1 ) Vents routed to a boiler or process heater > 44 MW (1 50
MMBtu/hr)? or
2) Vent streams that are introduced into the flame zone of the boiler
or process heater? or
3) A control device for which a performance test was conducted for
determination of compliance with an NSPS if no process changes
have been made?
Note: If the facility answered yes to any of these questions (B.1 .c) performance
tests are not required for these vents.
2. Sampling for initial performance tests
a) Does the facility conduct performance test sampling and analysis
according to the prescribed EPA-approved methods?
3. Follow-up tests to process changes
a) Have any process changes occurred at the facility?
1) If yes, for each process change affecting a Group 2 process vent,
did the facility recalculate the TOC emission rate to determine
whether the vent remains a Group 2 process vent or becomes a
Group 1 process vent?
2) Was recalculation based on vent stream flow rate and TOC
measurements as specified for initial performance tests or best
engineering assessment practices?
Note: That process changes include, but are not limited to, changes in production
capacity, production rate, or catalyst type; whenever there is replacement, removal,
or addition of recovery equipment; and debottlenecking activities.
(Process changes do not include process upsets, unintentional, temporary process
changes, or changes that are within the range on which the original calculation was
based.)
C. Miscellaneous Process Vents Monitoring Requirements
1 . Miscellaneous process vents routed to a flare
For miscellaneous process vents routed to a flare, is a monitoring device
capable of continuously detecting the presence of a pilot flame (including,
but not limited to a thermocouple, an ultraviolet beam sensor, or an infrared
sensor) used?
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
F-16
September 30, 1997
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Petroleum Refinery MACT Standard Guidance
2.
3.
Miscellaneous process vents routed to incinerators other than catalytic
incinerators
For miscellaneous process vents routed to incinerators other than catalytic
incinerators, is a temperature monitorinq device with a continuous recorder
used?
Is the device located in the firebox or in the duct work immediately
downstream of the firebox in a position before any substantial heat
exchange occurs?
Miscellaneous Process Vents routed to catalytic incinerators
For Miscellaneous Process Vents routed to catalytic incinerators, is a
temperature monitoring device with a continuous recorder used?
Is the device located in the gas stream immediately before and after the
catalyst bed?
4.
Note:
5.
Miscellaneous process vents routed to boiler or process heaters with a
design heat capacity <44 megawatts where the vent streams are not
introduced into the flame zone
For miscellaneous process vents routed to boiler or process heaters with a
design heat capacity <44 megawatts where the vent streams are not
introduced into the flame zone, is a temperature monitoring device with a
continuous recorder used?
Is the device located in the firebox?
No monitoring is required for boilers or process heaters.
Refineries that use a vent system with bypass line valves that have not
been sealed or secured.
For refineries that use a vent system with bypass line valves that have not
been sealed or secured, is a flow indicator that determines at least every
hour whether a vent stream flow is present used?
Is the indicator located at the entrance to any bypass line that could divert
the vent stream away from the control device to the atmosphere?
6.
7.
Refineries that use a vent system with bypass lines, where the valves
have been secured in the closed position with a car-seal or a lock-and
key-type configuration.
For refineries that use a vent system with bypass lines, where the valves
have been secured in the closed position with a car-seal or a lock-and key-
type configuration, are the valves visually inspected at least every other
month to ensure that they are maintained in the closed position and the vent
stream is not diverted through the bypass line?
Refineries using other approved control devices
For refineries using other approved control devices or requesting to monitor
other parameters, is the facility complying with any site-specific monitoring
requirements?
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
F-17 September 30, 1997
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Petroleum Refinery MACT Standard Guidance
D. Miscellaneous Process Vents Reporting Requirements
1. Notice of Compliance Status (NCS) reports
a) All miscellaneous process vents affected by the MACT standard
For miscellaneous process vents affected by the MACT standard, has
the refinery submitted an NCS report that identifies the following:
1) Each vent?
2) Whether the process vent is Group 1 or Group 2?
3) For each Group 1 vent that is not included in an emissions average,
the method of compliance (e.g., use of a flare or other control device
meeting the requirements of the MACT standard)? [40 CFR
63.643(a)]
Note: If the required information has been submitted at an earlier date, or at
different times, and/or in different submittals, later submittals may refer to earlier
submittals instead of duplicating and resubmitting previously submitted information.
4) For miscellaneous process vents with control devices required to be
tested under the MACT standard, did the NCS include information on
each testing method, and results of the performance test since there
are different requirements for each test and test method used?
5) For each test method used, did the NCS include the following test
results:
a) The percentage reduction of organic HAPs orTOC or the outlet
concentration of organic HAPs orTOC (ppm by volume on a dry
basis corrected to 3 percent oxygen), determined as specified in
40CFR63.116(c)?
b) The value of the monitored parameter specified in 40 CFR 63
Subpart CC, Table 10 or a site specific parameter approved by the
permitting authority, averaged over the full period of the
performance test?
6) For each test method used, does the NCS include the following
supporting information:
a) Sampling site description?
b) Description of sampling and analysis procedures, and any
modifications to standard procedures?
c) Quality assurance procedures?
d) Record of operating conditions during the test?
e) Record of preparation of standards?
f) Record of calibrations?
g) Raw data sheets for field sampling?
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
F-18
September 30, 1997
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Petroleum Refinery MACT Standard Guidance
h) Raw data sheets for field and laboratory analyses?
1) Documentation of calculations?
j) Any other information required by the test method?
7) If the same test is conducted for multiple emission points, did the
facility submit the following:
a) one complete test report for each test method used for each
emission point?
b) for additional tests using the same method, the additional test
results?
8) Miscellaneous Process Vents Controlled by Flares
a) For vents controlled by flares, did the NCS include the following
test results:
all visible emission readings?
heat content determinations?
flow rate measurements?
exit velocity determinations made during the compliance
determination? [40 CFR 63.654(f)(1)(iv)(A)]
b) For vents controlled by flares, a statement of whether a flame was
present at the pilot light over the full period of the compliance
determination? [40 CFR 63.654(f)(1)(iv)(B)]
c) If a parameter other than the presence of a pilot flame is
monitored, the acceptable range for the parameter and the
rationale (including any supporting data or calculations) for the
range?
Note: Results of a prior performance test can be used if that test was conducted
using the methods specified in 40 CFR 63.645 and test conditions were
representative of current operating conditions.
9) Vents routed to an incinerator or boiler or process heater < 44
MW where the vent streams are not introduced into the flame
zone
In addition to the information required for all miscellaneous process
vents, do NCS reports for vents routed to an incinerator or boiler or
process heater < 44 MW where the vent streams are not introduced
into the flame zone include the following information:
a) Average firebox temperature (or gas stream temperature for
catalytic incinerators) over the duration of the performance test?
b) Acceptable range for the daily average firebox temperature and
rationale for the range?
c) Times at which an operating day begins and ends?
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
F-19
September 30, 1997
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Petroleum Refinery MACT Standard Guidance
2. Periodic reports
a) Has the refinery experienced any compliance exceptions or periods of
excess emissions?
(Compliance exceptions and periods of excess emissions do not include
periods of startup, shutdown, malfunction, performance testing and
monitoring system calibration.)
Yes
No
b) Has the refinery submitted the appropriate periodic reports regarding
the compliance exceptions or periods of excess emissions?
Yes [ ] No [ ]
1) Were the reports submitted no later than 60 days after the end of
each 6-month period when any compliance exceptions occur?
Note: The first 6-month period begins on the date the NCS report is required to be
submitted.
Yes
No
2) If the refinery uses emissions averaging, were the reports
submitted quarterly?
Yes
No[
3) For control devices for which an initial performance test is required
(flare, incinerator, and boiler or process heater < 44 MW where the
vent streams are not introduced into the flame zone), did the
facility submit the following information in the periodic report:
Complete test report for initial performance test results?
Yes [ ] No [ ]
Times and duration of periods when monitoring devices are
not operating?
Yes [ ] No [ ]
4) Periodic Reports for vents routed to a flare
For vents routed to a flare, did the facility submit a record of each
pilot flame determination (or alternate parameter upon request and
approval) in the periodic report?
Yes
No
5) Periodic Reports for vents routed to an incinerator or boiler or
process heater < 44 MW where the vent streams are not
introduced into the flame zone
For vents routed to an incinerator or boiler or process heater < 44
MW where the vent streams are not introduced into the flame
zone, did the facility submit the following information in the periodic
report:
Record of each fire box temperature value or a block average
of values for periods of 1 hour or less?
Yes
No
Record of the daily average firebox temperature?
Note: If all hourly temperature values are within the range reported in the NCS, the
facility may record that all values are within the range instead of daily average
values.
Yes
No
VI. REQUIREMENTS FOR STORAGE VESSELS
F-20
September 30, 1997
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Petroleum Refinery MACT Standard Guidance
A. Control Requirements for Storage Vessels
1 . For storage vessels with floating roofs does the facility use one of the
following control devices?
a) Internal floating roof with specified seals?
b) External floating roof?
c) External floating roof converted to an internal floating roof (i.e., fixed roof
installed above the external floating roof)?
2. For storage vessels with closed vent systems, does the facility use a
closed vent system routed to a flare or other control device that reduces
HAP emissions by 95% or to 20 ppmv?
3. Are all storage vessels that store a liquid with a maximum true vapor
pressure of total organic HAPs > 76.6 kPa controlled by a closed vent
system and control device? [40 CFR 63.1 19(a)(2)]
- If yes, are, work practices, as specified in 40 CFR 63.1 19(b) through (e),
followed for each of the control methods?
4. Storage vessels at new sources
a) In addition to the above control requirements, did storage vessels at new
sources also install deck fitting controls, as specified in 40 CFR
63.119(c)(2)(l) through (xii), on all floating roof tanks?
b) Do storage vessels at new sources also apply the control requirements of
40 CFR63.119(b)(5) and (b)(6)?
B. Testing Requirements for Storage Vessels
1 . Initial Performance Tests for Closed Vent Systems Routed to a Flare
a) For storage vessels equipped with a closed vent system routed to a flare,
has the facility conducted an initial performance test or compliance
determination, as specified in 40 CFR 63.1 1 (b), to ensure compliance
with the control requirement to reduce total organic HAP emissions by
95% or to 20 ppmv?
1) If yes, did the test include the measurement/determination of the
following:
• Emissions visibility?
• Net heat value of combusted gas?
• Flow rate of gases being combusted?
• Exit velocity?
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
F-21
September 30, 1997
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Petroleum Refinery MACT Standard Guidance
2. Initial Performance Tests for Closed Vent Systems Routed to a Control
Device Other Than a Flare
a) For storage vessels equipped with a closed vent system routed to a
control device other than a flare, did the facility conduct either an initial
design evaluation, as specified in 40 CFR 63.120(d)(1)(l), or an initial
performance test, as specified in 40 CFR 63.120(d)(1)(ii)?
C. Monitoring and Inspection Requirements for Storage Vessels for Storage
Vessels Required to Apply Controls
1. Storage vessels equipped with a closed vent system
For storage vessels equipped with a closed vent system, does the facility
monitor the parameters proposed in the Notice of Compliance Status (NCS)
report to ensure that the control device is being properly operated and
maintained?
Note: There are no monitoring requirements for storage vessels equipped with
floating roofs.
2. Closed vent systems routed to a control device
Does the facility inspect closed vent systems routed to a control device
every 12 months as specified in 40 CFR 63.148?
3. Storage Vessels with floating roofs
a) Do the storage vessels have a single-seal system or a double-seal
system?
b) Storage vessels with a single seal system
For storage vessels with a single seal system and equipped with a fixed
roof and an internal floating roof or an external floating roof converted to an
internal floating roof, does the refinery conduct the following inspections:
1) Visually inspect the internal floating roof and primary seal through
manholes and roof hatches at least once every 12 months after initial
fill, or at least every 12 months after the compliance date?
2) Visually inspect the internal floating roof and primary seal each time
the storage vessel is emptied and degassed and at least once every
1 0 years after the compliance date?
3) Visually inspect gaskets, slotted membranes, and sleeve seal (if any)
each time the storage vessel is emptied and deqassed and at least
once every 10 years after the compliance date (new source only)?
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
F-22
September 30, 1997
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Petroleum Refinery MACT Standard Guidance
c) Storage vessels with a double single seal system
For storage vessels with a double single seal system and equipped with
a fixed roof and an internal floating roof or an external floating roof
converted to an internal floating roof, does the refinery conduct the
following:
1) Visually inspect the internal floating roof, primary seal, and secondary
seal each time the vessel is emptied and degassed and at least once
every 5 years after the compliance date? or
2) Visually inspect the internal floating roof and the secondary seal
through manholes and roof hatches at least once every 12 months
after initial fill, or at least every 12 months after the compliance date;
and
3) Visually inspect the internal floating roof, primary seal, and secondary
seal each time the vessel is emptied and degassed and at least once
every 10 years after the compliance date?
d) Storage vessels equipped with an external floating roof
1) For storage vessels equipped with an external floating roof, does the
facility visually inspect the following, each time the vessel is emptied
and degassed:
- external floating roof?
- the primary and secondary seals?
- fittings?
2) For storage vessels equipped with an external floating roof, does the
facility conduct the following additional inspections:
• For single-seal systems, does the facility:
- Measure the gaps between the vessel wall and the primary
seal by the compliance date and at least once a year, until a
secondary seal is installed?
- When a secondary seal is installed, measure gaps between the
vessel wall and both the primary and secondary seal within 90
calendar days of installation, and then comply with the double-
seal inspection requirements? [40 CFR 63.120(b)(1)(ii)]
• For double-seal systems, does the facility:
- Measure the gaps between the vessel wall and the primary
seal during hydrostatic testing or by the compliance date and at
least once every 5 years thereafter?
- Measure the gaps between the vessel wall and the secondary
seal by the compliance date and at least once a year?
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
F-23
September 30, 1997
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Petroleum Refinery MACT Standard Guidance
D. Reporting Requirements for Storage Vessels Equipped with Closed Vent
Systems
1. Notice of Compliance Status Reports
a) Storage vessels equipped with a closed vent system routed to a
flare
For storage vessels equipped with a closed vent system routed to a flare,
does the NCS contain the results of the initial performance test,
including:
• Flare design, such as steam-assisted, air-assisted, or non-assisted?
• Visible emissions readings?
• Heat content determinations?
• Flow rate measurements?
• Exit velocity determinations?
• Periods during the compliance determination when the pilot flame is
absent?
b) NCS Reports for storage vessels equipped with a closed vent
system routed to a control device other than a flare
For storage vessels equipped with a closed vent system routed to a
control device other than a flare, does the NCS also include:
• Description of the parameter(s) to be monitored to ensure proper
operation and maintenance of the control device?
• Explanation of the parameter selection?
• Frequency of monitoring?
• Design evaluation documentation, as specified in 40 CFR
63.120(d)(1)(l), or results of the initial performance test including
identification of emission points sharing the control device?
2. Periodic Reports
a) Have any compliance exceptions regarding storage vessels occurred?
If yes, has the facility submitted the appropriate periodic reports for
storage vessels?
b) Periodic Reports for storage vessels equipped with a closed vent
system routed to a control device
For storage vessels equipped with a closed vent system routed to a
control device, do periodic reports include a description of the following:
• Routine maintenance for the control device that was performed during
the previous 6 months?
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
F-24
September 30, 1997
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Petroleum Refinery MACT Standard Guidance
• Routine maintenance anticipated for the control device for the next 6
months?
• For a control device that is a flare, each occurrence and cause when
the requirements specified in 40 CFR 63.1 1(b) are not met?
• For a control device other than a flare, each occurrence and cause of
monitored parameters being outside the ranges documented in the
NCS?
c) Periodic reports for storage vessels equipped with any type of
floating roof
For storage vessels equipped with any type of floating roof, do the
periodic reports contain the results of each inspection in which a
failure was detected, including:
1) Date of inspection?
2) Identification of the storage vessel?
3) Description of the failure?
4) Nature and date of repair or date the vessel was emptied?
d) Did the facility apply for an extension beyond the 45 day period for
correcting failures identified during inspections of storage vessels?
1) If the facility applied for an extension, did the corresponding
periodic reports also include the following information:
• Description of the failure?
• Statement that alternate storage capacity is unavailable?
• Schedule of actions that will ensure that the control equipment
will be repaired or the vessel will be emptied as soon as
possible?
Note: If the vessel cannot be repaired or emptied within 45 days, the facility may
utilize up to 2 extensions of up to 30 additional days each.
e) Storage vessels equipped with an external floating roof
For storage vessels equipped with an external floating roof, did the
facility conduct any qap measurement?
1) If yes, did the facility notify the Administrator 30 days in advance of
the gap measurement?
2) Were the requirements of 40 CFR 63.120(b)(3), (4), (5), or (6) not
met for any of the gap measurements?
- If yes, were the results of the gap measurement in which the
requirements were not met included in the periodic reports?
- Was the following information included in the reports:
• Date of seal gap measurement?
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
F-25
September 30, 1997
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Petroleum Refinery MACT Standard Guidance
• Raw data and calculations described in 63.120(b)(5) or (6)?
• Description of seal conditions that are not met?
• Nature and date of repair or date the vessel was emptied?
3. Internal Inspection Notifications
a) Did the facility notify the Administrator of filling or refilling of each storage
vessel with organic HAPs?
b) Did the facility notify the Administrator at least 30 calendar days prior to
any scheduled internal inspections?
- If not, was the internal inspection not planned? and
- Could the owner/operator of the refinery not have known about the
inspection 30 calendar days in advance of refilling the vessel with
organic HAPs?
c) If the inspection is not planned and the owner/operator could not have
known about it in advance, did the facility notify the Administrator at
least 7 calendar days prior to refilling the storage vessel?
- If the notification was made by telephone, was it immediately
followed by written documentation demonstrating why the
inspection was unplanned?
- If the notification was made in writing, was it is received by the
Administrator at least 7 calendar days prior to the refilling?
Note: If the State or local permitting authority has received delegation of the
Refinery MACT (not all states have as of August 1997), they can waive the
notification requirements for all or some storage vessels at petroleum refineries.
The State or local permitting authority may also grant permission to refill storage
vessels sooner than 30 days after submitting the required notification under 40
CFR 64.654(h)(2)(l)(A) or sooner than 7 days after submitting the notification under
40 CFR 64.654(h)(2)(l)(B) on a case-by-case basis.
E. Recordkeeping Requirements for Storage Vessels
1) All Storage Vessels
- For all storage vessels, does the facility maintain records of Group 1 or
Group 2 determinations, vessel dimensions, and analysis of capacity for 5
years?
- In addition, does the facility maintain all information required to be reported
for 5 years?
2) Storage vessels equipped with a closed vent system routed to a
control device
For storage vessels equipped with a closed vent system routed to a control
device, does the facility also maintain the following records for 5 years:
a) Complete test report for initial performance test results?
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
F-26
September 30, 1997
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Petroleum Refinery MACT Standard Guidance
b) Measured values of monitored parameters?
c) Planned routine maintenance performed, including:
- The first time of day and date the control requirements are not met at the
beginning of the planned routine maintenance? and
- The first time of day and date the control requirements are met at the
conclusion of the planned routine maintenance?
4) For storage vessels equipped with any type of floating roof, does the facility
retain records of each inspection performed? [40 CFR 63.123c and (e)l
5) For storage vessels equipped with an external floating roof, does the facility
retain records of each seal qap measurement, includinq date, raw data
obtained in the measurement, and the calculations described in 40 CFR
63.120(b)(3)and (4)?
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
VII. REQUIREMENTS FOR WASTEWATER STREAMS
A. Control Requirements for Wastewater Streams
Note: If a refinery is in compliance with the benzene waste NESHAP [40 CFR 61
Subpart FF], it is considered to be in compliance with the refinery MACT standard.
Provisions of the benzene waste NESHAP apply to the following wastewater
streams at petroleum refineries:
(1) Total benzene loading > 10 Mg per year, and
(2) Flow rate > .02 liters per minute, and
(3) Benzene concentration > 10 ppm by weight, and
(4) Not exempt from controls under the benzene waste NESHAP.)
1 . Has the refinery reduced benzene mass emissions from wastewater streams
by 99% by using suppression followed by steam stripping, biotreatment, or
other treatment process?
2. For vents from steam strippers and other waste management or treatment
units, does the facility utilize a control device that achieves 95% emission
reduction or 20 ppmv at the outlet of the control device?
B. Testing and Monitoring Requirements for Wastewater Streams
1 . Do all wastewater streams at the facility comply with the testing
requirements of the benzene waste NESHAP found in 40 CFR 61 .340
through 61 .355?
2. Is testing done at the required frequency?
3. If required, are periodic measurements of the benzene concentration in the
wastewater performed?
4. If required, does the facility conduct monitoring of the process or control
device operating parameter?
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
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C. Reporting and Recordkeeping Requirements for Wastewater Streams
1. Do all wastewater streams comply with the reporting requirements of the
benzene waste NESHAP found in 40 CFR 61.356 and 61.357? [40 CFR
63.654(a)]
Yes
No
2. In addition, is all information required to be reported retained for 5 years?
[40 CFR 63.654(l)(4)]
Note: Since affected sources should already be in compliance with 40 CFR 61
Subpart FF, they will not need to make any changes to their current reporting and
recordkeeping procedures in order to comply with the Petroleum MACT standard.
Yes
No
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Petroleum Refinery MACT Standard Guidance
VIII. REQUIREMENTS FOR GASOLINE LOADING RACKS
A. Control Requirements for Gasoline Loading Racks
Is the facility in compliance with the gasoline distribution facilities NESHAP
found in 40 CFR 63 Subpart R, which requires the facility to:
1. Reduce emissions of total organic compounds (TOC) to 10 milligrams per
liter of gasoline loaded; and
2. Load gasoline only in vapor tight cargo tanks that have been tested to
assure vapor tightness?
Yes
No
B. Testing and Monitoring Requirements for Gasoline Loading Racks
1. Is the facility in compliance with the testing and monitoring requirements of
the gasoline distribution facilities NESHAP found in 40 CFR 63.425(a)
through (c) (performance tests), 63.425(e) through (h) (annual certification),
63.425(f) (leak detection tests), 63.425(g) (nitrogen pressure decay field
tests), and 63.427 (continuous monitoring)?
Yes
No
2. Initial Performance Tests
a) Did the facility conduct an initial performance test for gasoline racks
according to the test methods and procedures in 40 CFR 60.503 (except
using a reading of 500 ppm to determine the level of leaks to be repaired
under 40 CFR 60.503)?
Yes
No
b) Did the facility conduct any follow-up tests following process changes?
Yes
No[
If yes, did the refinery document the reasons for any change in the
operating parameter value since the previous test?
Yes [ ] No [ ]
c) If the facility is using a closed vent system and control device as
specified in 40 CFR 60.112b(a)(3) to control emissions from gasoline
loading racks, did the facility conduct initial performance tests on the
control devices? [40 CFR 63.423]
Yes[ ] No[ ]
d) If the facility uses a flare to control emissions, and emissions from the
gasoline loading rack cannot be measured using the methods specified
in 40 CFR 60.503, is the refinery in compliance with the provisions of 40
CFR 63.11(b)?
Yes[ ] No[ ]
3. Annual Certification Tests
Does the facility conduct annual tests on gasoline cargo tanks to certify that
emissions controls are functioning properly?
Yes
No
If yes, is the annual performance test conducted according to the
vacuum and pressure tests described in Method 27 of 40 CFR 60
Appendix A?
Yes[ ] No[ ]
4. Leak Detection Tests
During loading operations, does the facility conduct a leak detection test for
its gasoline loading racks according to Method 21 of 40 CFR 60 Appendix
A?
Yes
No
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a) Are the tests conducted on each compartment during the loading of
that compartment, or while the compartment is still under pressure?
b) In addition to Method 21 , are the following reguirements for the test
met [40 CFR 63.425]:
• To eliminate a positive instrument drift, does the dwell time for
each leak detection not exceed two times the instrument response
time?
• Is the instrument purged with ambient air between each leak
detection?
• Is the duration of the purge in excess of two instrument response
times?
• Does the facility attempt to block the wind from the area being
monitored, and record the highest detector reading and location for
each leak?
5. Additional Testing Requirements
a) For cargo tanks with manifolded product lines, does the facility conduct a
nitrogen pressure decay field test on each compartment of each tank?
(This test is described in 40 CFR 63.425(g).)
b) Does the facility also conduct a continuous performance pressure decay
test, as described in 40 CFR 63.425 (h)?
6. Continuous Monitoring
Are gasoline loading racks in compliance with the continuous monitoring
requirements of 40 CFR 63.427(a) and (b)?
a) Is the continuous monitoring system installed, calibrated, certified,
operated and maintained according to manufacturer specifications?
b) Is the location where the continuous monitoring system is installed
appropriate to the type of system used (e.g., carbon adsorption,
refrigeration condenser, thermal oxidation, or flare)?
C. Reporting and Recordkeeping Requirements for Gasoline Loading Racks
1 . For gasoline loading racks, does the facility comply with the reporting and
recordkeeping requirements of the gasoline distribution facilities NESHAP
found in 40 CFR 63.428(b), (c), (g)(1), and (h)(1) through (h)(3)?
2. Does the facility retain all required records for 5 years?
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
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Petroleum Refinery MACT Standard Guidance
IX. REQUIREMENTS FOR MARINE TANK VESSEL LOADING
A.
Control Requirements for Marine Tank Vessel Loading
Are all marine tank vessel loading operations that are subject to the MACT
standard in compliance with the marine tank loading NESHAP found in 40 CFR
63 Subpart Y, which requires the following:
1 . For existing sources does the facility utilize controls that:
• Collect vapors discharged during loading?
• Load only in vapor tight vessels?
• Reduce collected HAP emissions by 97% or use vapor balancing?
2. For new sources does the facility utilize controls that:
• Collect vapors discharged during loading?
• Load only in vapor tight vessels?
• Reduce collected HAP by 98% or use vapor balancing?
B. Testing and Monitoring Requirements for Marine Tank Vessel Loading
For all marine tank vessel loading subject to the MACT Standard, does the
refinery comply with the testing and monitoring requirements of the marine tank
loading NESHAP found in 40 CFR 63.560 through 63.567?
Note: The Initial Notification Report under 40 CFR 63.567(b) is not required.
C.
Reporting and Recordkeeping Requirements for Marine Tank Vessel
Loading
1 . For all marine tank vessel loading subject to the MACT standard, does the
refinery comply with the reporting and recordkeeping requirements of the
marine tank loading NESHAP found in 40 CFR 63.566, 63.567(a) and (c)
through (I)?
2. Does the facility retain all records required to be kept for 5 years?
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
X. REQUIREMENTS FOR EQUIPMENT LEAKS
A. Control Requirements for Equipment Leaks
1 . For equipment leaks at existing sources, does the facility comply with
either of the following equipment leaks provisions:
(a) 40 CFR 60 Subpart VV (synthetic organic chemical manufacturing
industry (SOCMI) equipment leaks NSPS)? or
(b) Modified 40 CFR 63 Subpart H (hazardous organic NESHAP (HON)
negotiated regulation)?
2. For equipment leaks at new sources, does the facility must comply with
modified 40 CFR 63 Subpart H?
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
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B. Testing, Inspection, and Monitoring Requirements for Equipment Leaks?
For all equipment leaks subject to the MACT standard, does the refinery
comply with the testing, inspection, and monitoring requirements for
equipment leaks in 40 CFR 60.1046 and 60.1047 (40 CFR 60 Subpart W),
or 40 CFR 63.162 through 63.180 (40 CFR 63 Subpart H)?
Yes
No
C. Reporting and Recordkeeping Requirements for Equipment Leaks
For all equipment leaks subject to the MACT Standard, does the refinery
comply with the reporting and recordkeeping requirements for equipment
leaks found in 40 CFR 60.1048 and 60.1049 (40 CFR 60 Subpart VV), or 40
CFR 63.181 and 63.182 (40 CFR 63 Subpart H)?
Yes
No
XI. EMISSIONS AVERAGING
A. Emissions Averaging Applicability
Did the facility conduct emissions averaging?
Yes
No
- If yes, did the facility conduct emissions averaging only for emission points
at a single refinery?
Note: Emissions averaging is not allowed across sources, such as across different
plant sites or between refinery and HON sources (i.e., units having a hazardous
organic air pollutant as its primary product) at the same plant site. In addition, an
emissions estimation is only required for points included in emissions averages,
not for all points in the source.
A limitation on the emissions averaging provision is that States have the authority
to disallow emissions averaging and require the application of standard control
requirements to all emission points.
Yes
No
B. Emissions Averaging Credit/Debit System
1. Were emission credits and debits calculated on a mass basis using
equations in 40 CFR 63.652(g) and (h) based on actual operations?
Yes[ ] No[ ]
2. Were credits calculated greater than or equal to debits calculated on an
annual basis? [40 CFR 63.652(e)(3)]
Yes[ ] No[ ]
3. Did debits exceed credits by more than 30% in any one quarter? [40 CFR
652(e)(4)]
Yes[ ] No[ ]
4. Were any emission points other than the following used to generate
emissions averaging credits [40 CFR 63.652(c)(1) through (3)]:
• Group 2 emission points.
• Group 1 emission points controlled by technology with a higher nominal
efficiency than the reference control technology.
• Emission points from which emissions are reduced by pollution reduction
measures, alone or in conjunction with other controls, that get more
emission reduction than required?
Yes [ ] No [ ]
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5. Did the facility use any of the following emission points to generate
emissions averaging credits [40 CFR 63.652(d)]:
• Emission points already controlled on or before November 15, 1990,
unless the level of control was increased after November 15, 1990? (If so,
credit is allowed for the increase only.)
• Group 1 emission points that are controlled by a reference control
technology, unless the technology has been approved for use in a different
manner and a higher nominal efficiency has been assigned?
(For example, it is not allowable to claim that an internal floating roof meeting only
the specifications stated in the reference control technology definition in 40 CFR
63.641 applied to a storage vessel is achieving greater than 95 percent control.)
• Emission points on shutdown process units?
• Emission points controlled to comply with a State or other Federal rule,
unless the level of control has been increased after November 15, 1990
above what is required by the State or other Federal rule?
Note: If the facility used any of these emission points, credit is allowed for the
increase only.
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Note: Debits are generated if the required level of control of a Group 1 emission point, such as 98% for
miscellaneous process vents and 95% for storage vessels, is not achieved. [40 CFR 63.652(g)] (See
Table 2.3 for required level of control.) Debits and credits are calculated using formulas found in 40
CFR 63.652(g) and (h).
6. Did the facility conduct calculations from any of the following:
• Wastewater that is not process wastewater or wastewater streams treated
in biological treatment units? (Group 1 wastewater streams cannot be left
undercontrolled or uncontrolled to generate debits) [40 CFR 63.652(d)(4)]
• More than 20 individual emission points in addition to those controlled by
pollution prevention measures?
- Where pollution prevention measures are used, no more than 25
emission points total? [40 CFR 63.652(f)(1)]
• Emission points during periods of startup, shutdown, and malfunction? [40
CFR 63.652(0(2)]
• Emission points for which continuous monitors are used and excess
emissions occur? [40 CFR 63.652(f)(3)] (For these periods, the monthly
credits and debits will be adjusted as specified in 40 CFR 63.652(f)(3)(l)
through (Hi).)
C. Approval of Emissions Averaging Plan
1 . Did the facility submit for approval an emissions averaging plan in the
Implementation Plan or Operating Permit Application?
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
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2. Did the plan demonstrate that the credits will be sufficient to offset the debits
under representative operating conditions? [40 CFR 63.652(e)(3)(l)]
Note: The plan may include use of innovative technologies, different from the
reference control technology, provided that the innovative technologies achieve
greater than the level of control required fora Group 1 emission point.)
3. Did the facility include a risk assessment in the plan of any hazards or risks
of the plan, such as the risk from one large emission point versus the risk
from combined emission points?
- Did the facility review such hazards and risks and compare them to point-
by-point compliance?
D. Testing, Monitoring, Reporting, and Recordkeeping for Emissions
Averaging
1 . For each emission point included in an emissions average, did the refinery
perform testing, monitoring, reporting, and recordkeeping equivalent to the
requirements for Group 1 emission points that are not included in emissions
averaging? [40 CFR 63.653(a)]
2. In addition, did the facility maintain the monthly calculations of debits and
credits?
3. Does the facility maintain the following records for emissions averaging:
• Initial performance test results (if applicable)?
• Monthly debits, credits, and calculations using EPA-specified calculation
procedures?
• Operating parameter monitoring results?
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
Yes [ ] No [ ]
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APPENDIX G. PROPOSED CHANGES
As of September 1997, EPA was currently considering changes to the MACT standard
that would impact this guidance. For information regarding these changes, please
contact EPA's office of Enforcement and Compliance Assurance (see Appendix H for
contact names and phone numbers.)
Wastewater stream control requirements (Section 2, Table 2-3 and Section 5
Table 5-1)
In Table 2-3 (p2-5), wastewater streams control requirements, the guidance states that
refineries are required to Comply with benzene waste operations NESHAP [40 CFR 61
Subpart FF], which requires:
- Reducing benzene mass emissions by 99% using suppression followed by another
treatment process (e.g., steam stripping or biotreatment); and
- Reducing emissions from vents from stream strippers, other waste management, or
treatment units by 95% with a control device or to 20 ppmv at the outlet of the
control device.
The proposed change would allow wastewater stream management units that also
receive streams subject to 40 CFR 63 Subpart G, to comply only with Subpart G.
Notice of Compliance Status Reports(Section 3.3.3, p. 3-)
Section 3.3.3 states that NCS reports must identify each emission point and method of
compliance. EPA is considering requiring the NCS report to identify only each group 1
emission point.
Startup, Shutdown and Malfunction Reports (Section 3.3.5, p.3-)
EPA is considering deleting the requirement to call the regulatory authority within 2 days
after inconsistent corrective actions commence.
The requirement to submit a letter within 7 days containing the circumstances of the
event, reasons for not following the startup, shutdown, and malfunction plan, and
indicating whether any excess emissions and/or parameter monitoring exceedances
occurred is proposed to be changed to require reporting in the next scheduled periodic
report.
Reports required for Special Situations (Section 3.3.6, p. 3-)
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EPA is considering removing the requirement that reports required for special situations
include determination of rule applicability to flexible operation units and storage vessels
and distillation units for which use varies from year to year. [40 CFR 63.654(h)(6)].
EPA proposes to require this information in the Notice of Compliance Status report
instead.
Recordkeeping Requirements
In addition to the recordkeeping requirements listed, EPA is considering requiring the
maintenance of records of Group 2 miscellaneous process vents and Group 2 storage
vessels, including dimensions and capacity.
Miscellaneous Process Vents, Notice of Compliance Status Report
subsection(Section 4.1.4, page )
Currently the Guidance requires identification of all vents. EPA is considering requiring
identification of all Group 1 process vents
Storage Vessels Reporting Requirements
For storage vessels with floating roofs, EPA is considering deleting the requirement to
report raw data and calculations described in 63.120(b)(5) or (6).
Gasoline Loading Racks (Section 4, page 4-19, and Section 5, page 5-2 and Table
5-1)
EPA is considering requiring gasoline loading racks that are subject to both Subpart XX
and the MACT Standard to comply with the MACT standard.
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Petroleum Refinery MACT Standard Guidance
APPENDIX H. EPA REGIONS AND REGIONAL CONTACTS FOR THE
PETROLEUM REFINERY MACT STANDARD IMPLEMENTATION
No Petroleum Refineries in
EPA Region I
Umesh Dholakia
EPA Region II
290 Broadway
New York, NY 10007-1866
PH: (212)637-4023/4065
FAX: (212)637-3901/3998
Paul Dressel
Region III (3AT12)
841 Chestnut Building
Philadelphia, PA 19107
PH: (215)566-2154
FAX: (215)566-2114
Katy Reeves
EPA Region IV (AR-4)
Atlanta Federal Ctr.
61 Forsyth St.
Atlanta, GA 30303-3104
PH: (404)562-9130
FAX: (404) 562-9095
Kathy Keith
EPA Region V (AE-17J)
77 W. Jackson Blvd.
Chicago, IL 60604
PH: (312)353-6956
FAX: (312)353-8289
John York
EPA Region VI (6EN-AT)
1445 Ross Avenue, Suite 700
Dallas, TX 75202-2733
PH: (214)665-7289
FAX: (214)665-7446
Bill Peterson
EPA Region VII. ARTD/APCO
726 Minnesota Avenue
Kansas City, KS66101
PH: (913)551-7881
FAX: (913)551-7065
Heather Rooney
EPA Region VIII (8ENFG-T)
999 18th Street, Suite 500
Denver, CO 80202-2405
PH: (303)312-6971
FAX: (303)312-6064
Nikole Reaksecker/Kingsley Adeduro
EPA Region IX (AIR-4)/(AIR-6)
75 Hawthorne Street
San Francisco, CA94105
PH: (415)744-1187/1177
FAX: (415)744-1076
Doug Hardesty/Andrea Longhouse
EPA Region X (OAQ-107)
1200 Sixth Avenue
Seattle, WA 98101
PH: (206)553-6641/8760
FAX: (206) 553-0404
Jim Durham
(Technical Lead)
Larry Brockman
(Guidance Documents)
Rafael Sanchez
(Compliance Assistance)
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OAQPS. MD-13
RTP, NC 27711
PH: 919-541-5672
FAX: 919-541
OAQPS. MD-12
RTP, NC 27711
PH: 919-541-5394
FAX: 919-541-2664
USEPA, OECA (2223-A)
1200 Pennsylvania Avenue, NW
Washington, DC 20044
PH: 202-564-7028
FAX: 202-564-0050
H-2
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APPENDIX I. EPA MEMOS REGARDING DEFINITIONS OF MAJOR
SOURCES OF HAZARDOUS AIR POLLUTANTS
1-1 September 30, 1997
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