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Proposed New and Revised Emission Factors for Flares and Proposed New Emission Factors for Certain Refinery Process Units and Proposed Determination for No Changes to VOC Emission Factors for Tanks and Wastewater Treatment Systems

***We are extending the deadline for submitting written comments on these proposed actions to December 19, 2014. We are currently negotiating a revised deadline for taking final action and will announce that new deadline once it is established.

Background


EPA is proposing certain actions in compliance with a consent decree entered into with Air Alliance Houston, Community In-Power and Development Association, Inc., Louisiana Bucket Brigade and Texas Environmental Justice Advocacy Services (“Plaintiffs”). Air Alliance Houston, et al. v. McCarthy, No. 1:13-cv-00621-KBJ (D.D.C.). The consent decree resolves litigation in which Plaintiffs alleged that EPA failed to perform nondiscretionary duties pursuant to Clean Air Act (CAA) section 130 to review, and, if necessary, revise the emission factors for volatile organic compounds (VOC) for flares, liquid storage tanks (“tanks”), and wastewater collection, treatment, and storage systems (“wastewater treatment systems”) at least once every three years. Under the terms of the consent decree, by August 19, 2014, EPA will review and either propose revisions to the VOC emission factors for flares, tanks and wastewater treatment systems under CAA section 130, or propose a determination under CAA section 130 that revision of these emission factors is not necessary. By December 19, 2014. EPA will issue final revisions to the VOC emission factors for flares, tanks and wastewater treatment systems, or issue a final determination that revision of these emission factors for flares is not necessary. EPA will post each proposed revision or determination (or combination thereof), and each final revision or determination (or combination thereof), on its AP-42 website on the dates indicated above.

Proposed Actions

EPA has evaluated all of the data collected during the 2011 Refinery Information Collection Request (ICR), the data referenced in the Complaint, and other test data available to the Agency for flares, tanks and wastewater treatment systems. Based on this evaluation, we are proposing a new VOC emission factor for flares. We are also proposing emissions factors (or emissions estimation methodologies) for certain refinery operations and pollutants that are not covered by the consent decree. Specifically, we are proposing to update Sections 5.1, 8.13, and 13.5 of AP-42 to incorporate the following new and revised emissions factors.

Emission Sources
Pollutants
Flares NOx(revised), CO(revised), VOC
Sulfur Recovery Units NOx, CO, THC
Catalytic Reforming Units THC
Hydrogen Plants NOx
Fluid Catalytic Cracking Units HCN

We previously developed a refinery emissions estimation protocol in response to a Data Quality Act petition which was used in the 2011 Refinery ICR. The refinery emissions estimation protocol lists and ranks available methods for calculating emissions from refineries. We are proposing to update Sections 1, 5, and 6 of the refinery emissions estimation protocol with these new emission factors.

Based on our review of the available emissions data for tanks and wastewater treatment systems, we found that the data was not adequate to allow for revisions to existing emissions estimation methods for those sources. Therefore, we are proposing a determination that revisions of the VOC emission factors for tanks and wastewater treatment systems are not necessary.

Supporting Documents for Proposed Actions

As noted above, based on our review of the reports cited by the Plaintiffs in their complaint and other available test data for flares, tanks and wastewater treatment systems, we propose to create a new VOC emission factor for flares. We are also proposing that no revision is necessary to the VOC emission factors for tanks and wastewater treatment systems because the available emissions data for tanks and wastewater treatment systems are not adequate to allow for revisions to existing emissions estimation methods for those sources. A report describing the review of these documents and the basis for our findings is available by clicking on the following link:

DRAFT EPA Review of Available Documents for Developing Proposed Emissions Factors for Flares, Tanks, and Wastewater Treatment Systems   (PDF 3,173K).

As listed above, we are proposing to include seven new emission factors and two revised emission factors in AP-42 based on our review of approximately 200 test reports collected during the 2011 Refinery ICR and development of a peer-reviewed study on Parameters for Properly Designed and Operated Flares. A report that summarizes our review and analysis of these test reports and describes the development of these emissions factors is available by clicking on the following link:

DRAFT Review of Emissions Test Reports for Emissions Factors Development for Flares and Certain Refinery Operations   (PDF 1,232K).

We are proposing revisions for three sections of AP-42 to incorporate the revised/new factors. These proposed revisions can be accessed at the following links:

  • AP-42 Chapter 5: Petroleum Industry Section 5.1 Petroleum Refining  
  • AP-42 Chapter 8: Inorganic Chemical Industry Section 8.13 Sulfur Recovery 
  • AP-42 Chapter 13: Miscellaneous Sources Section 13.5 Industrial Flares  
  • We are also proposing to revise the Refinery Emissions Estimation Protocol to incorporate the revised/new factors, as well as to incorporate a new procedure for estimating emissions from delayed coking units:

    Draft Emission Estimation Protocol for Petroleum Refineries - Version 3.0 posted August 19, 2014.

    Public Comment

    We seek your comments on all aspects of these proposed actions regarding new and revised emission factors for flares, and the proposed revisions to the refinery protocol document, as well as on the newly proposed emission factors for certain process units at refineries. We also seek your comments on our proposed determination that revisions to the VOC emission factors for tanks and wastewater treatment systems are not necessary. Please submit your written comments on the above referenced documents and the proposed actions to AP-42 by December 19, 2014. Questions should be e-mailed to Gerri Garwood at garwood.gerri@epa.gov and comments should be e-mailed to refineryfactor@epa.gov.

    Below is a link to written comments and questions received:

    Comments and Questions as of December 4, 2014   (PDF 37,149K).

    Below is a link to view comment attachments that could not be included in the above document:

    Attachments to Comments and Questions as of December 4, 2014   (ZIP 11,277K).

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