Even the name of a recent Environmental Protection Agency (EPA) rule is complicated: the Petroleum Refinery Sector Risk and Technology Review (RTR) and New Source Performance Standards (NSPS) rule. Its implications are similarly complex. The potential impacts are severe and wide-reaching, affecting almost every petroleum refinery in the United States.

To meet the fast-approaching compliance dates for the rule — including some 2016 deadlines — many refineries must complete a number of complex projects. And because the RTR requirements demand refinery-specific solutions, no single road map toward compliance exists. Is it any wonder refiners are feeling overwhelmed?

Demystifying the EPA’s Air Quality Rules
The final rule, issued in September 2015, is intended to both control air emissions from petroleum refineries and provide the public with information about refinery emissions. The EPA believes the rule will result in an annual reductions of 5,200 tons of hazardous air pollutants and 50,000 tons of volatile organic compounds (VOC).

The regulations range from new benzene fence line monitoring, storage tank, marine vessel loading and venting requirements to more complex requirements for key refinery processing units.

Straightforward Impacts
The rule for continuous fence line monitoring for benzene is the first time such a measure has been required. It’s also one of the more straightforward project impacts, requiring regulated refineries to install from 12 to 24 passive monitoring stations along the fence line to measure ambient benzene concentrations — and to publicly disclose results.

Other clear project requirements that will affect most refineries include:

  • More stringent technical specifications for floating roof tanks.
  • New submerged-fill standards for vessels loaded with refinery products and the removal of splash loading exemptions.
  • Necessary volume flow rate instruments on all lines that allow vents to bypass normal emissions abatement equipment.

Complex, Refinery-Specific Impacts
Other requirements are not as simple, requiring case-by-case evaluations. They include:

  • The elimination of previous startup, shutdown and malfunction (SSM) emissions exclusions, requiring a re-evaluation of units with elevated emissions during SSM periods.
  • A tightening of the standard for Delayed Coking Unit (DCU) venting from 5 psig to 2 psig, requiring a potential update to cycle operations, the recovery of more offgas or routing higher pressure offgas to flare systems.
  • Flares must meet new heating value requirements, potentially requiring new instrumentation and other data collection, with particular challenges occurring during SSM periods.
  • Catalytic reforming purge vents are no longer exempt from emission standards no matter the pressure.

But for refiners, the most difficult change to evaluate and prepare for may be the new rule’s impact on fluid catalytic cracking unit (FCCU) regenerator flue gas vents. My colleagues and I authored an article for the AFPM Q&A and Technology Forum Daily that delves into this issue in great detail.

I’m also speaking on this topic at the American Fuel & Petrochemical Manufacturers (AFPM) Annual Meeting in San Francisco on March 15 at 9:30 a.m. If you’re affected by the new RTR rule, I hope you’ll make plans to attend my presentation. And if you can’t make it, reach out on LinkedIn and I’ll be happy to discuss in more detail.

The industry is paying close attention to these new requirements. The EPA has already proposed to provide more time for refiners to comply with some of the new requirements, but even with an extension the timeline is tight. Has your refinery begun planning for the changes? What aspect are you finding most challenging? Sound off in the comments below, and check out our article in Hydrocarbon Processing magazine.

Blake Soyars, PE, is manager of the Air Quality & Noise Department, specializing in permitting and compliance for refinery, energy and chemical manufacturing customers.