RTR FOR ETHYLENE PRODUCTION (EMACT) AND PETROLEUM REFINERY MACT (RSR)
Within the last several years, the EPA has completed its mandated Risk and Technology Review (RTR) for numerous source categories, including but not limited to petroleum refineries and most recently, ethylene producers. With the benefit of reducing toxic air emissions, these rule revisions pose considerable costs and compliance challenges for the petroleum refining and petrochemicals industry. Over the past five years, TRICORD has successfully assisted numerous petroleum refineries across the U.S. with developing and implementing compliance plans for the Petroleum Refinery Sector RTR and revised New Source Performance Standards, commonly referred to as the ‘Refining Sector Rule’ or RSR.
The implementation of a facility-specific RSR compliance program is complicated by the wide-ranging and voluminous nature of the new regulations, as well as their potential impact on the existing compliance, operational and managerial systems at subject facilities. Compliance with RSR has required a significant commitment of technological and personnel resources by most, if not all, functional areas at a given refinery. For example, the elimination of startup, shutdown, and malfunction (SSM) exemptions for emission standards has required some refiners to develop new or updated procedures, incorporate new or additional emissions controls and monitoring equipment, and budget for the increased time and personnel, in an effort to complete the action in accordance with the new rule.
The final RSR became effective on January 30, 2016, and included a wide range of new requirements made via updates to the existing federal requirements covering various petroleum refining processes. Some of the more significant new requirements of the RSR included:
- New emission control requirements for flares, delayed coking units (DCUs), catalytic reforming units (CRUs), storage tanks, and an expanded group of miscellaneous process vents (MPVs);
- The elimination of exemptions from control standards during periods of SSM for Fluidized Catalytic Cracking Units (FCCUs) and Sulfur Recovery Units (SRUs), and introduction of new alternative SSM emission limits for some sources;
- Performance testing requirements for hydrogen cyanide (HCN) and particulate matter (PM) emissions from FCCUs;
- Requirements related to the minimization of certain releases from atmospheric pressure relief devices (PRDs) and flaring events, and Root Cause Failure Analysis (RCFA) for events that do occur;
- Flare combustion efficiency requirements;
- New provisions requiring the development and maintenance of a Continuous Parametric Monitoring System (CPMS) Monitoring Plan for each subject flare system;
- New requirements for Flare Management Plans (FMPs);
- Requirements to conduct regular monitoring of atmospheric benzene emissions at refinery fenceline boundaries; and
- Additional work practice standards for vents and certain loading operations.
The recent Ethylene Production MACT (EMACT) RTR revisions mirror these RSR requirements with some minor differences. The EMACT revisions include, but are not limited to the addition of the following new requirements for ethylene production facilities:
- Work practice standards for activities impacted by the elimination of exemptions for periods of SSM and maintenance:
- Ethylene cracking furnace decoking;
- Atmospheric Pressure Relief Devices (PRD) practices; and
- Maintenance vent practices;
- Heat exchanger/cooling water system monitoring;
- Vent control bypasses;
- New provisions requiring the development and maintenance of a CPMS Monitoring Plan for each subject flare system; and
- New EMACT-specific requirements for FMPs.
TRICORD’s technical and regulatory staff are well positioned to help Ethylene producers with understanding and complying with the EMACT RTR requirements and is currently helping several ethylene production facilities with the preparation and implementation of gap assessments and compliance plans. If you need help, please give one of our service leaders a call.
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