Introduction In 2001-2002, EPA performed an initial risk assessment, commonly refered to as the Risk Test, for all ~155 U.S. petroleum refineries. EPA looked at the risk associated with emissions of all relevant hazardous air pollutants (HAPs) from refinery point sources including process heaters & boilers, flares and thermal oxidizers, wastewater collection and treatment systems, cooling towers, fugitive equipment leaks, storage tanks, product loading operations, miscellaneous process vents, CRUs, FCCUs, and SRUs. The results of the Risk Test showed that the risk associated with inhalation of benzene emissions from RMACT 1 sources was potentially significant enough to justify additional, more detailed analysis. Consequently, these templates are designed to collect information on benzene from RMACT 1 sources. However, summary information is requested on the last page for benzene emissions from non-rmact 1 sources as well (e.g., HON units). The next phase of this analysis involves EPA performing a more detailed risk assessment of benzene sources from a representative subset of petroleum refineries. Approximately twenty refineries have been selected for this analysis. These refineries are being asked to provide EPA with the necessary data to allow EPA to perform the risk assessments. Detailed information will be required on benzene emissions and on other source characteristics. The attached spreadsheets attempt to provide a relatively straightforward method for collecting these data. The facility is not required to use these spreadsheets; they are only a tool. If the facility already has an existing database that contains the information that is being requested, it is not required to use these spreadsheets but rather can provide the existing database extract to EPA. A facility can also elect to submit any existing Health Risk Assessment (HRA) or other risk assessment that has been performed for the facility, provided this risk assessment is reasonably representative of current operations. In general, the California refineries subject to AB 2588 will have such an HRA. Please be sure to include all of the pertinent data that was used for this assessment, including the inputs to the emissions model, such that EPA can repeat the assessment for sources of benzene, should they so choose. If you elect either of the above alternatives and therefore do not choose to complete the tables on the spreadsheets, please note that you must complete the questions that follow each of the tables. It is important that EPA is able to understand, in sufficient detail, the basis for your benzene emission estimates. At the same time that EPA is performing their Residual Risk analyis, they plan to perform their 8-yr review of the MACT standards required by 112(d)(6) of the Act. To this end, it is important that you answer the questions that require you to identify any additional changes that the facility has made to reduce benzene emissions from each point source category. Included here would be source reduction activities, such as changes to operations, tank water draw procedures, work practices, etc. as well as any changes made to startup, shutdown, maintenance, depressuring, or catalyst transfer procedures. Lastly, these spreadsheets focus on the RMACT 1 benzene emissions sources. On the last page, please identify any additional significant sources of benzene that you are aware of, if any, and provide the same type of information on emission rates, modeling parameters, and control techniques as per the RMACT 1 spreadsheets. Please provide the requested, preferably electronically - by July 31, 2005 - to: Rob Ferry The TGB Partnership 1325 Farmview Road Hillsborough, NC 27278 Rob.Ferry@TGBpartnership.com (919) 644-8250 voice (919) 644-8252 fax
General Notes 1. The emissions data to be provided should be based on the most currently available estimates (e.g. 2004) that are representative of ongoing operations. To the extent that existing Health Risk Assessments and other risk assessments (and their supporting emissions data) are provided as an alternative, these assessments should be based on data that are reasonably representative of current operations. If the facility has an approved project, or anticipated change to a project, that will either increase or decrease emissions but is not yet constructed or on line, the facility may elect to report both current as well as future estimated emissions (i.e. emissions post start-up of the project). 2. A scaled plot plan should be provided. The scaled plot plan needs to have accurate and coordinates (lat-long coords) marked for a least one specific point. of the facility is a critical factor in the health risk model. It is strongly advised that you locate your facility using lat-long coords, and that you confirm that these coordinates are correct. 3. Please provide a process diagram, if available, or a list of all emission sources and control devices labeled with unique ID codes. Where it makes sense, sources can be grouped (e.g. fugitives, tanks, wastewater conveyance, etc). Each listed emission source (or group of sources) and control device shall be located on the plot plan by its ID code. As an alternative to a plot plan, UTM coordinates may be submitted for each emission point or group of emission points. For grouped sources, the UTM coordinates should be to the centroid of the group. 4. Facilities can respond to this questionnaire with either electronic (preferred) or paper versions.
Facility Name/: Cooling Towers (2,3) Controls (4) Cooling Tower Identifier Monitoring Exit Velocity Exit Temp. Recirculation Rate Diameter and Process Units Served (1) (tons/yr) (Yes/No) (decimal degdecimal deg (m/sec) (deg K) (gpm) (m) (m) (1) Indicate each cooling tower and the process units served by that tower (e.g., vacuum distillation, FCCU, etc - if acronyms are used, please provide a key). Please identify each cooling tower by its ID code. (2) Describe in detail how the emissions were calculated. For each emission source, indicate A, B, C, D and/or E below, and provide the necessary information. Also, please describe the emission speciation method and data source(s). A. Source testing Test method used: Number/frequency of tests: B. Emission Factor Factors used: Bases for factors (e.g. AP-42): C. Engineering Calculation Variables included in calculation: Calculation method: D. Modeling Model used: Inputs to model: Describe how emissions were calculated: E. Estimation Method of estimation(published data, similar sources, process knowledge, etc): (3) Are cooling towers subject to a permit limit on total VOC or benzene emissions? If so, please provide the limit. (4) Are these cooling towers monitored for hydrocarbon leaks? If yes, describe below (e.g. type and frequency of monitoring). Is this monitoring required by state/local regulation or permit, or is it performed volunatarily? Please describe below any additional changes that the facility has made to reduce benzene emissions from cooling towers.
Facility Name/: Fugitive Equipment Leaks (2,3,4) Valves Pumps Compressors Connectors Other Process Process Process Length Process Width Process Process Unit Identifier (1) (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr)decimal degdecimal deg (m) (m) (m) (1) Indicate each process unit that is controlled by an LDAR program. It is acceptable to group by process unit type (e.g. crude units, reformers, etc., or other logical grouping method), but multiple process unit areas are not to be grouped together. If a breakdown of fugitive equipment leaks by process unit is not readily available, then engineering judgment may be used to apportion the total fugitive equipment leaks to the individual process units. (2). Describe in detail below what method(s) was used to estimate the emissions. That is, identify which method you used from "EPA Protocol for Equipment Leak Estimates (EPA-453/R-95-017)". Describe how the benzene wt. % was determined. Put N/A if certain components are not included in your LDAR program, e.g. connectors. Please describe "other", if applicable State below your current leak repair thresholds for each of these components (e.g. 10,000 ppm for valves, etc. Describe monitoring method, including type of monitor, method of recording data, how leak rates are converted to mass emission rates Has this facility ever monitored leaks from heat exchangers? If yes, please describe. (3) Are fugitive equipment leaks subject to a permit limit on total VOC or benzene emissions? If so, please provide the limit (4) If fugitive equipment leaks are not available by type of component, then report the total of all components (for each process unit area) under the column labeled 'Other'. Please describe below any additional changes that the facility has made to reduce benzene emissions from equipment leaks
Facility Name/: Storage Tanks (2,3) Emission Controls Floating-Roof Tanks Fixed Roof Primary Seals, Liquid- or Mech Shoe- Mounted Secondary Seals, Rim- Mounted Slotted Guidepole Controls (4) Vapor Recovery or Balancing Tank or Tank or Tank or Length Tank or Width Tank or Tank Identifier (1) (tons/yr) (Yes/No) (Yes/No) (Yes/No) (Yes/No) (decimal deg(decimal deg (m) (m) (m) (1) Indicate those tanks that store materials with a benzene content > 0.1 wt.%. Identify whether the tank is an internal floating-roof tank (IFRT), external floating-roof tank (EFRT), or fixed-roof tank (FRT - i.e., with no floating roof), and whether it is a Group 1 or Group 2 MACT tank. Please identify each tank by its ID code. It is acceptable to provide this information as blocks or areas of tanks that store the same type of material (e.g. crude oil, gasoline/naphtha, middle distillates,), that is, where the benzene content and the emissions controls are expected to be similar. Please indicate the number of tanks included in the block/area. It is expected that grouping might only be done where there is a battery of small, identical Group 2 tanks for which individual tank data are not available. Where you have tank-by-tank data available, however, please provide it. (2) Describe in detail below how the emissions were calculated (e.g. TANKS ver 4.xx). If some other calculation method (engineering estimate, emission factor, testing, etc) was used, describe the method and how the emissions were derived. Also, please describe the emission speciation method and data source(s). (3) Are storage tanks subject to a permit limit on total VOC or benzene emissions? If so, please provide the limit. (4) Note: This is significant only for EFRTs equipped with slotted guidepoles. For other tanks (e.g. IFRTs, EFRTs without slotted guidepoles, or that are domed), indicate N/A. Please describe below any additional changes that the facility has made to reduce benzene emissions from storage tanks.
Facility Name/: Wastewater Treatment System (2,3) Controls (4) Sealed/ Monitored Conveyance System Flow Rate Length Width Wastewater Collection System (1) (tons/yr) (Yes/No) (gpm) (decimal deg)(decimal deg) (m) (m) (m) (2,3) Controls (4,5) Level of Control Flow Rate Length Width Wastewater Treatment Units (1) (tons/yr) (O/C/CD) (gpm) (decimal deg)(decimal deg) (m) (m) (m) (1) Please provide a wastewater collection and treatment flow diagram indicating which units have controls, the type of control, and the regulation requiring the control. The wastewater collection system includes all process drains and junction boxes, together with their associated sewer lines, down to the wastewater treatment unit. The wastewater treatment unit typically begins with the forebay of the oil-water separator. Please identify each unit by its ID code. Please indicate and describe any wastewater streams that go offsite for treatment. (2) Describe in detail below how the emissions were calculated. For example, WATER 9 or TOXCHEM, etc. If another calculation method (engineering estimate, emission factor, testing, etc) was used, describe method and how emissions were derived. Also, please describe the emission speciation method and data source(s). Include emissions from process drains here and not on the fugitive equipment leaks sheet. (3) Are wastewater treatment facilities subject to a permit limit on total VOC or benzene emissions? If so, please provide the limit. (4) Is your facility subject to the BWON with TAB > 10 Mg/yr (and thus is subject to BWON controls)? If yes, indicate below the compliance option chosen (i.e. 2 Mg, 6 BQ, etc.). Please provide your most recent Total Annual (TAB) and Quantity (BQ) Reports (subpart FF, Part 61). If your conveyance system is sealed and monitored, please describe. (5) O = open (uncovered), C = covered (but not routed to controls), CD = covered and routed to a control device. Please describe below any additional changes that the facility has made to reduce benzene emissions from wastewater conveyance and treatment systems.
Facility Name/: Misc Process Vents (Group 2) (2,3) Controls (4) Vent Identifier and Indicate Vent Vent Diameter Exit Velocity Exit Temp. Process Unit Served (1) (tons/yr) Type decimal degdecimal deg (m) (m) (m/sec) (deg K) (1) List any RMACT1 Group 2 miscellaneous process vents, and their associated process units Please identify each vent by its ID code. Note: Given the high degree of control provided by process heaters and incinerators, VOC/HAP emissions associated with Group 1 MPVs are insignificant. VOC emissions associated with Group 2 MPVs are typically uncontrolled and therefore can be of more significance. (2) Describe in detail how the emissions were calculated. For each emission source, indicate A, B, C, D and/or E below, and provide the necessary information. Also, please describe the emission speciation method and data source(s) A. Source testing Test method used: Number/frequency of tests: B. Emission Factor Factors used: Bases for factors (e.g. AP-42): C. Engineering Calculation Variables included in calculation: Calculation method: D. Modeling Model used: Inputs to model: Describe how emissions were calculated: E. Estimation Method of estimation(published data, similar sources, process knowledge, etc): (3) Are miscellaneous process vents subject to a permit limit on total VOC or benzene emissions? If so, please provide the limit (4) Indicate type of control device used (e.g. process heater/boiler, thermal incinerator, vapor recovery unit, etc.). Please describe below any additional changes that the facility has made to reduce benzene emissions from miscellaneous process vents.
Facility Name/: Marine Vessel Loading Controlled/Recovered (2,3) Annual Volume Loaded Vent Vent Diameter Exit Velocity Exit Temp. Controlled/Recovered Emission Point (1) (tons/yr) (Million Bbls) decimal degdecimal deg (m) (m) (m/sec) (deg K) Uncontrolled (2,3) (5) Annual Volume Loaded Length Width Uncontrolled Vessel Loading Dock ID (4) (tons/yr) (Million Bbls) decimal degdecimal deg (m) (m) (m) (1) Identify individual vapor recovery or abatement sources. Please identify each control device and its associated loading dock(s) or berth(s) by their ID codes. Please include any wastewater streams generated by marine vessel loading, if not already included on wastewater sheet. Please describe the type of control (e.g., flare, thermal combustion, vapor balancing, carbon adsorption, etc.) (2) Describe in detail below how the emissions were calculated. Also, please describe the emission speciation method and data source(s). (3) Are marine loading operations subject to a permit limit on total VOC or benzene emissions? If so, please provide the limit. (4) Identify individual docks or berths where marine vessels may be loaded without a vapor recovery/control system. Please identify each dock or berth by its ID code. Please include any wastewater streams generated by marine vessel loading (e.g., ballast water), if not already included on wastewater sheet. (5) Modeling area should approximate the dimensions of a standard marine vessel. Please describe below any additional changes that the facility has made to reduce benzene emissions from marine vessel loading.
Facility Name/: Gasoline Loading Racks Controlled/Recovered (2,3) Annual Volume Loaded Truck/Car Tightness Vent Vent Diameter Exit Velocity Controlled/Recovered Emission Point (1) (tons/yr) (Million Bbls) (4) decimal degdecimal deg (m) (m) (m/sec) (deg K) Exit Temp. Uncontrolled (2,3) (6) Annual Volume Loaded Length Width Uncontrolled Loading Rack ID (5) (tons/yr) (Million Bbls) (decimal deg)decimal deg (m) (m) (m) (1) Identify individual vapor recovery or abatement sources. Please identify each control device and its associated loading rack(s) by their ID codes. Please include any benzene transfer operations. Please include any wastewater streams generated by gasoline loading, if not already included on wastewater sheet. Please describe the type of control (e.g., flare, thermal combustion, vapor balancing, carbon adsorption, etc.) (2) Describe in detail below how the emissions were calculated. Also, please describe the emission speciation method and data source(s). (3) Are gasoline loading racks subject to a permit limit on total VOC or benzene emissions? If so, please provide the limit. (4) Indicate the standard for tank truck tightness in terms of the 5-minute limit on pressure drop (e.g., NSPS 3", MACT 1"). If not subject to tank truck tightness requirements, enter 'NA'. (5) Identify individual racks that may be operated without a vapor recovery/control system. Please identify each rack by its ID code Please include any benzene transfer operations. Please include any wastewater streams generated by gasoline loading, if not already included on wastewater sheet. (6) Modeling area should approximate the dimensions of a rack loading area. Please describe below any additional changes that the facility has made to reduce benzene emissions from gasoline loading and benzene transfer operations.
Facility Name/: Data Year: Other Significant Sources of (2,3) Controls (4) (Yes/No) Other Other Other Other Description (1) MACT Source Category (tons/yr) (decimal deg(decimal deg) (1) Describe each operation. Please identify each emission point by its ID code. Examples could include units subject to the HON (and not Refinery MACT), flares not otherwise specified, benzene transfer operations, and ethylene units. If benzene emissions from an other-than RMACT 1 source would be more readily reported in the format of one of the pages for a specific type of emission point, a copy of that page may be made for reporting such 'other' emissions. The page should have a note added at the top identifying that page as being from 'other' sources, and identifying the MACT Source Category. (2) Describe in detail how the emissions were calculated. For each emission source, indicate A, B, C, D and/or E below, and provide the necessary information. Also, please describe the emission speciation method and data source(s). A. Source testing Test method used: Number/frequency of tests: B. Emission Factor Factors used: Bases for factors (e.g. AP-42): C. Engineering Calculation Variables included in calculation: Calculation method: D. Modeling Model used: Inputs to model: Describe how emissions were calculated: E. Estimation Method of estimation(published data, similar sources, process knowledge, etc): (3) Are these other sources subject to a permit limit on total VOC or benzene emissions? If so, please provide the limit. (4) Describe how benzene emissions are controlled.