Supersedes: 11/15 (Rev. 03) Preparer: Owner: Approver: EHS Team Member EHS Team Member EHS Manager

Transcription

1 Procedure No.: PA Page: 1 of 7 Preparer: Owner: Approver: EHS Team Member EHS Team Member EHS Manager Document Revision Change Table Revision Number Revision Description Revised By Revision Date 01 Changed Header and footer VB 05/08 02 Revised procedure to reflect current program RY 01/12 03 Revised procedure to make more specific to site GW 11/15 04 Revised procedure for clarification GW 2/18

2 Procedure No.: PA Page: 2 of 7 1. PURPOSE To provide a procedure for the Port Arthur site for compliance with the Benzene Waste Operations NESHAP, (BWON), 40 CFR Part 61, Subpart FF. 2. DEFINITIONS 2.1. Chemical manufacturing plant refers to the entire BASF TOTAL Petrochemicals LLC (BTP) facilities Container means any portable waste management unit in which a material is stored, transported, treated, or otherwise handled. Examples of containers are drums, barrels, tank trucks, barges, dumpsters, tank cars, dump trucks, and ships Control device means an enclosed combustion device, vapor recovery system, or flare Individual Drain System means the system used to convey waste from a process unit, product storage tank, or waste management unit to a waste management unit. For BPT this includes all piping that removes liquid waste from the process and routes it to treatment via the wastewater tanks. Drains include above ground piping Process wastewater means water that comes in contact with benzene during manufacturing or processing operations conducted within a process unit; organic wastes, process fluids, product tank draw-down, steam trap condensate, and landfill leachates are not process wastewaters Waste means any material resulting from industrial operations that is discarded or is being accumulated, stored, or treated prior to being discarded, recycled, or discharged Waste stream means the waste generated by a particular process unit, product tank, or waste management unit. The characteristics of the waste stream (e.g., flow rate, benzene concentration, water content) are determined at the point of waste generation. 3. SCOPE This procedure applies to the BTP facilities at Port Arthur.

3 Procedure No.: PA Page: 3 of 7 4. PROCEDURE 4.1. Federal Requirements Wastes must be managed or treated to reduce facility-wide uncontrolled aqueous benzene to less than 6 megagrams per year (Mg/yr). Managing wastes means keeping them controlled until they are returned to the process. Selected wastes can be uncontrolled, providing that the facilitywide 6 Mg/yr ceiling is met. Wastes can be sent off-site, as long as either (1) their uncontrolled aqueous benzene is put toward the 6 Mg/yr ceiling or (2) they are controlled (both on-site and at the receiving facility, until treated or returned to the process.) Tanks must be equipped with an internal or external floating roof (40 CFR 60 Subpart Kb) or a fixed roof, closed-vent system, and control device. Controlled tanks containing only non-aqueous wastes and meeting specific capacity and vapor pressure criteria can have a fixed roof without the closed-vent system and control device. Inspections must be performed at least quarterly and repairs of failures (e.g., of broken seals) must be attempted within 45 days of discovery (or within timeframe set by Subpart Kb, as applicable) BTP has no surface impoundments with BWON applicability Containers must be equipped with covers that are designed for no detectable emissions; must use submerged filling; and must be inspected at least quarterly with necessary repairs attempted as soon as practicable within 15 days of discovery Individual drain systems with BWON applicability are identified on P&ID s and in the field. They must be inspected quarterly with necessary repairs attempted as soon as practicable within 15 days of discovery. BTP s LDAR contractor performs these inspections The CPI and IGF units must maintain fixed roofs, closed-vent system, and control. Openings, such as gaskets, must be inspected at least quarterly with necessary repairs attempted within 15 days of discovery Controlled closed-vent systems must be designed for no detectable emissions; must equip any bypass line with a flow indicator or a car-seal or lock-and-key type valve; must be inspected at least quarterly, with necessary repairs (e.g., holes in ductwork) attempted within 5 days, and completed within 15 days of discovery.

4 Procedure No.: PA Page: 4 of 7 4. PROCEDURE cont d 4.1. Federal Requirements cont d The thermal oxidizer meets control requirements. The permit minimum temperature of 1800 o F is above the 1780 o F used in the performance test required by BWON Flares, must meet 40 CFR requirements regarding visible emissions, flame presence, heat content, and exit velocity The carbon canister system at the Thermal Oxidizer meets BWON control requirements. Performance monitoring is based on exhaust breakthrough, with air permit requirements stricter than Subpart FF requirements. Specifically, exhaust vapor must be monitored daily with spent carbon changeout immediately, (within 24 hours) upon breakthrough determination. BWON defines breakthrough as VOC of 100 ppmv above background. The air permit requires monitoring every 8 hours with changeout of the canisters at 37 ppmv VOC. Other carbon canisters used at the site may have different requirements depending on the service. Contact EHS for determination of requirements for other carbon canisters Monitoring and Testing The benzene quantity must be determined in each waste stream at least annually, based on sufficient information (e.g., chemical purchases, material balances, engineering knowledge, or test results) For initial performance testing, as required by 40 CFR 61 Subpart A, must determine benzene concentration or benzene quantity in waste streams, including effluent from treatment processes other than combustion devices, using appropriate methods from EPA SW-846 or 40 CFR 136, appendix A; must determine benzene emissions from control devices and from combustion treatment processes using EPA methods 2 and 18 (from 40 CFR 60 appendix A) All equipment required to be designed for no detectable emissions, including: tanks, containers, CPI, IGF, and closed vent systems, must be monitored initially and annually by Method 21 (from 40 CFR 60 appendix A), where detectable emissions are indicated by an instrument reading of 500 ppm above background.

5 Procedure No.: PA Page: 5 of 7 4. PROCEDURE cont d 4.2. Monitoring and Testing cont d Control devices, (flares, thermal oxidizer, carbon canisters), must be monitored and records appropriate operating parameters kept Reporting Annual reports must be submitted by April 7 of each year, with Total Annual Benzene quantification, compliance quantification (with 6 Mg/yr ceiling), inspection and monitoring leak data, and other information (control devise performance issues, new regulated systems and so on) Quarterly reports must be submitted (due 30 days after the end of each quarter), with certification that inspections were done and information regarding control device performance issues Site Procedures See BWON Compliance Manual for site sampling requirements. 4.5 Training Training must be conducted and documented for affected individuals with dates and training material content. 4.6 Records Retention Records of all required inspections, tests, monitoring, and reports must be retained for a period of 5 years, in addition to the current year. 5. RESPONSIBILITIES 5.1. Environmental, Health, and Safety Manager The EHS Manager has the primary responsibility for implementation of this procedure EHS Team Member The site EHS Team Member is responsible for: The issuance, re-issuance, administration, and/or interpretation of this procedure. Training of site personnel regarding their obligations under this regulation.

6 Procedure No.: PA Page: 6 of 7 5. RESPONSIBILITIES cont d 5.2. EHS Team Member cont d Ensuring that the required sampling, analysis, and inspections are performed. Ensuring that quarterly reports are submitted as required. Ensuring that annual benzene waste calculations are performed and reported as appropriate. Maintaining records as required by the regulation. Keeping BWON Compliance Manual up-to-date. 6. RELATED DOCUMENTS BWON Compliance Manual See EHS. 40 CFR 61 Subpart A NESHAP General Requirements 40 CFR 61 Subpart FF Benzene Waste Operations

7 Effective: 5/15/08 Internal Approved by: EHS Manager