A pending Information Collection Request (ICR) from the U.S. Environmental Protection Agency (EPA) will require all 152 operating petroleum refineries in the United States to update their air emissions inventories in accordance with the newest protocols and may require them to conduct air emissions testing on an accelerated schedule. According to the National Petrochemical & Refiners Association(NPRA) and the American Petroleum Institute(API), up to 2,000 man-hours per refinery will be required to respond to the ICR.

The EPA will use the data it receives to update the New Source Performance Standards (NSPS) and Maximum Achievable Control Technology (MACT) regulations governing refinery operations. The EPA accepted comments on the draft ICR until March 4, 2011. Refineries should expect to receive a Section 114 ICR in early April.

As part of the ICR, the EPA will survey all operating refineries in the United States and will ask respondents for:

1. Detailed facility design, cost and operating information
2. A revised 2010 air emissions inventory detailing the emissions of both criteria and hazardous air pollutants
3. Distillation column feed analysis
4. New emissions testing

More details and the approximate timeline for each element are provided below.

Facility Information

The EPA recently informed industry trade groups that the facility information component of the ICR will be due on May 31, 2011. Detailed process and emissions source information for process units, storage tanks, atmospheric vents, wastewater systems, and loading operations must be included, and the applicable requirements must also be identified. Additionally, cost information for recently-installed air pollution control devices must also be reported.

Updated Air Emissions Inventory

A new and updated robust 2010 emissions inventory will be due on June 30, 2011. This inventory must be conducted in accordance with the EPA’s new Emission Estimation Protocol for Petroleum Refineries (Version 2.1 – Final ICR Draft). The inventory must follow a hierarchy for calculating emissions:

1. Direct measurement (e.g., continuous emissions monitoring systems)
2. Fuel analysis/mass balance (fuel usage, assumed destruction efficiency)
3. Source-specific stack testing to derive source-specific emission correlations
4. Default emission factors (listed in the ICR Emission Estimation Protocol document)

For units or emission points that are not addressed by the Emission Estimating Protocol, respondents must report estimates based on the Toxic Release Inventory (TRI) report, state emission inventories or other engineering estimates, or process knowledge. Wastewater system emissions must be made using the Refinery Wastewater Emission Tool (RWET) specified in the ICR.

The large number of pollutants included in the ICR is expected to result in a dramatic increase in the number of emissions estimates that will need to be prepared. Analysis conducted by Environmental Resources Management (ERM)suggests that most refineries will report at least twice as many emissions estimates in this response as in typical emission inventories.

Distillation Column Feed Analysis

Distillation column feed analysis requirements mandate that the feed to the refinery’s first distillation column be sampled and the results reported by August 31, 2011. Three sets of composite samples must be collected using ASTM methods at approximately 30-day intervals. The samples must be analyzed for mercury, chlorine, sulfur, antimony, beryllium, cadmium, chromium, cobalt, lead, manganese, nickel, and selenium.

New Emissions Testing

New emissions test data for emission sources are due August 31, 2011. By that date 96 facilities must conduct source tests for emissions from fluid and thermal catalytic cracking units, fluid and delayed cokers, catalytic reforming units, hydrocrackers, hydrogen plants, asphalt blowing units, sulfur recovery units, fuel gas systems, cooling water systems, and wastewater treatment systems. The ICR lists the specific refineries that must conduct these source tests.

Strategic Considerations

The information needed to complete an ICR is typically housed in numerous locations throughout the operating refinery, including the environmental, process engineering, operations, and logistics departments. The most efficient way to gather the necessary information is usually by enlisting help from the various departments. A successful information collection process should begin with a bit of awareness training; this initial outreach has had a huge payoff in ERM’s experience.

Refiners should expect some differences in emissions estimates from past years. In addition, these new emissions estimating techniques may further impact TRI reporting protocols and future permit plans. Differences will need to be carefully evaluated to avoid future problems.

Companies that are subject to this ICR should carefully consider the size of the effort and the tight schedule. ERM recommends that refiners implement the project in parallel tracks that can run independently under the supervision of a strong project manager who maintains a coordinated system for information tracking and meeting interim internal deadlines.

About the Authors

Ken Weiss, P.E., is the Managing Partner for the Global Air Practice at ERM. He has more than 38 years of experience in managing air quality issues for government and industry. He is a recognized national authority on Title V operating permit programs and New Source Review who has assessed the impact of the Clean Air Act on numerous U.S. corporations and facilities and developed cost-effective implementation strategies. Before joining ERM, Ken managed the environmental affairs department for a Fortune 125 company involving seven major production facilities. He is a member of the Editorial Review Board for “The Air Pollution Consultant” and a peer reviewer, by invitation, for the Air Pollution Training Institute and a recent contributing author to Perry’s Chemical Engineers Handbook.

Rob Gronewold, P.E., is a program director at ERMwho specializes in oil and gas industry compliance. Mr. Gronewold has more than 25 years of experience in industrial and regulatory settings across a broad range of environmental permitting, compliance, and enforcement support activities. Prior to joining ERM, Mr. Gronewold was the managing director for corporate environmental affairs at a large independent U.S. refining and marketing company. In that role he provided oversight and guidance for environmental compliance and permitting for all media, with an emphasis on air regulatory programs. He also coordinated the firm’s federal Consent Decree compliance programs, responses to Clean Air Act Section 114 inquiries, and contingent liability reserves.

Photograph: Oil Refinery by Daniel West, Sacramento, California, U.S.A.

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