NSPS QQQ Insights Bill Stewart February 2017

Transcription

1 Bill Stewart February /20/2017 Page 1

2 Objective Discuss the key aspects of NSPS QQQ to assist in lowest cost compliance options Recommend steps for enhanced compliance 2/20/2017 Page 2

3 Discussion Topics Understanding the Affected Facility Use of the catch basin exclusion Use of offsets Segregation of stormwater Opting to treat wastewater as BWON/MACT CC Group 1 stream Records and support documentation Robust Project Review Process 2/20/2017 Page 3

4 Understanding the Affected Facility A clear understanding of the Affected Facility is key for any NSPS Clearly outlining this equipment is key to defining if something is new, modified or reconstructed There are 3 different affected facilities in QQQ (IDS, OWS, AF) Site wide sewer system drawings recommended to help make a proper determination Review from external regulatory experts to verify determination Sewer changes are not common Very few hours normally required to conduct a verification low cost 2/20/2017 Page 4

5 Use of the Catch Basin Exclusion A catch basin within the existing configuration exempts an IDS from being modified or reconstructed Existing is May 4, 1987 configuration is not defined A new IDS cannot have a downstream catch basin Defining all of the equipment in the IDS as an affected facility is key 2/20/2017 Page 5

6 Use of Offsets A question of modification is common for sewer changes (add a drain to an existing IDS) An NSPS modification requires a capital expenditure (7% of cost basis) and an increase in emissions within the affected facility Offsetting the emissions can be a very cost effective option Retrofit existing drains with water seals for the IDS affected facility Adding improved tank seals or carbon control for the OWS affected facility 2/20/2017 Page 6

7 Segregation of Stormwater Stormwater only systems are not regulated by QQQ Must be designed and operated for the sole purpose of collecting stormwater Must be segregated from the process wastewater collection system Segregation is not defined Discussion of segregation design documents, use of water seals within a comingled system 2/20/2017 Page 7

8 Opting to Treat Wastewater as BWON/MACT CC Group 1 Stream MACT CC overlap provisions in (o)(1) provide the basis There is no de minimis amount of oil to exclude an oily wastewater system A wastewater stream can be treated as a Group 1 stream and then the water is not regulated under QQQ Route wastewater to a BWON treatment system Consider the economics of treatment versus QQQ controls 2/20/2017 Page 8

9 Records and Support Documentation Good documents provide the basis for Accurate regulatory determinations Evidence to support audits/compliance determinations Supporting environmental staff transitions Changes over time within a large industrial complex can create uncertainties for future review determinations Did a sewer modification on a unit impact the downstream equipment; which equipment? Suggest site-wide drawings showing wastewater equipment/interconnectivity 2/20/2017 Page 9

10 Robust Project Review Process The most important environmental system for any company Evidence the numerous NSR and regulatory compliance actions Change management for environmental is a key system Review needed early in the design phase Ongoing review needed through the project (changes from the prior review can significantly affect rule applicability) Tools can be created to ensure high level of compliance and documentation Review tool should cover all environmental aspects Review tool serves as documentation 2/20/2017 Page 10

11 Summary The key to a strong QQQ compliance position while minimizing costs is: A good understanding of the rule, especially of the 3 affected facilities Making full use of rule exclusions which include Offsets within the affected facility Use of the catch basin exclusion Stormwater segregation Treating oily wastewater as Group 1 under MACT CC Documentation systems A robust project review process 2/20/2017 Page 11