On May 15 2014 the EPA released a proposal that would significantly decrease the emissions released, in tons per year (TPY), by petroleum refineries. Their goals include lowering the total tons of toxic air pollutants (SOx, NOx, CO and other pollutants) and volatile organic compounds (VOCs) by 5,600 tpy and 52,000 tpy, respectively. These reductions target 142 large sources, and 7 small sources. The proposal also calls for stronger rules concerning the efficiency of flare ups as well as the monitoring of storage tanks and fence line pollutants.

Flare ups are commonly visible from miles away, and are often used as a signature sign of heavy industry in media. The common image of a flare stack is a tall chimney that shoots flames out of the top. These are called flaring’s, and they occur when excess gasses, typically hydrocarbons (natural gas, propane ethylene, etc) and oxygen are burned off, ejecting water and carbon dioxide into the air.

The Fife ethylene plant at Mossmorran.

These burnings, though, are not complete. Incomplete combustion occurs when the chemical reaction from hydrocarbon and oxygen to CO2 and water is not 100%. When this occurs, the flares send excess chemicals in to the atmosphere. The new proposal will increase the efficiency of these burn offs (acceptable incomplete combustion is 2%). The efficiency of this process is based on a number of different factors that is beyond the scope of this blog. Please review [1] (pg 1-6 in doc) for a more in depth review of what effects efficiency.

The “typical” combustion reaction produces water and carbon dioxide, with excess material of oxygen and hydrocarbons. Different chemical processes require different reactions, though. This is the case for flares that emit Sulfur Dioxide as their incomplete combustion (Proposal pg 272). Any chemical reactions that create incomplete combustions are hazardous to the health of surrounding populations. The hydrocarbons that are emitted by the plants are commonly VOC’s which can react in the air to create a wide range of compounds that can be harmful to human health. While SOx, NOx, and CO have known negative health effects, and are currently controlled by NAAQS. According to the EPA’s socioeconomic factors report, which accompanies the proposal, approximately five million individuals are currently affected negatively by…. (for example, increased risk of cancer)[2]. After the EPA rules go into effect, the number of people impacted by flares will decrease to three million people [3].

Another important change will be the increased use of new technology to monitor storage tanks. Current laws allow for minimal monitoring of smaller storage tanks that have a capacity between 20,000 to 40,000 gallons (proposal pg 181). Currently these storage tanks are required to be visually monitored only and even then, monitoring happens just once every 5 or 10 years depending on the type of storage tank (40 CFR 60.113b – Test and Procedures).

The proposal will require that all tanks above 20,000 gallons have controls and monitoring equipment. An example of a monitoring technique is a “continuous parametric monitoring system” (see [4] for an explanation of this technology). This system combines with other leak detection methods [5] that allow operators to become aware of any leaks before catastrophic failure occurs. Another important change in monitoring equipment will be the requirement for fence line monitoring. The proposed changes require air quality monitoring at the edge of the property to ensure that the pollutants do not travel past the companies property line.

The EPA is required to review emission standards from stationary sources every 8 years. The language in the Clean Air Act of 1990 does not require changes, though. They are only required to review and update rules “as necessary (taking into account developments in practices, processes, and control technologies)” CAA section  112(d)(6). By reviewing the regulations every eight years the EPA allows enough time for technological improvements to occur. In the court case of Natural Resources Defense Council V., EPA ruled that updates are not required since technological improvements may not be cost effective and the EPA has the responsibility to weigh the economic, technological, and health aspects of the its regulations. Frequently updating monitoring technology is expensive, especially if proprietary software and hardware is used. That being said, allowing facilities to be monitored every 5 to 10 years seems like extremely relaxed regulations for something that could potentially damage very large areas.

The EPA says that “A major source facility emits or has the potential to emit 10 or more tpy of any single air toxic, or 25 tpy or more of any combination of air toxics.”  Yet they did not provide a list of the refineries that fall under this category. Until further information is released on which facilities will be affected, it is possible to take the following map, released by the EPA, to be representative of where the largest benefits to this new proposal will be. Geographically, the areas that will be most impacted by the new rules are the Gulf Coast region, followed by Midwest, which have scattered factories, and the West Coast (predominantly California). The Philadelphia and New Jersey region will also be affected.

Locations of Petroleum refineries

To view the full document or the summarization visit: http://www.epa.gov/ttn/atw/petref.html

Footnotes

[1] Flare information

[2] Analysis of Socio-Economic Factors for Populations Living Near Petroleum Refineries (pre-proposal)

[3] Analysis of Socio-Economic Factors for Populations Living Near Petroleum Refineries (post-proposal)

[4] Stationary source emissions monitoring

[5]Underground storage tank leak detection

[6] http://www.epa.gov/ttn/atw/pollsour.html

 

Photo Credit

Fife ethylene plant: © Copyright William Starkey and licensed for reuse under this Creative Commons Licence

Addressing Air Emissions from the Petroleum Refinery Sector

 

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