An Overview of NSPS Subpart QQQ VOC Emissions from Petroleum Refinery Wastewater Systems

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1 An VOC Emissions from Petroleum Refinery Wastewater Systems Michelle Yakubisin Senior Engineer, ERM Copyright 2018 by ERM Worldwide Group Limited and/or its affiliates ( ERM ). All Rights Reserved. No part of this work may be reproduced or transmitted in any form or by any means, without prior written permission of ERM. 4/3/18 Page 1

2 Objectives Importance of 40 CFR Part 60 Subpart QQQ (NSPS QQQ) Overview of NSPS QQQ Applicability Definitions Control standards Recordkeeping and reporting Q&A 4/3/18 Page 2

3 Why is NSPS QQQ Important? Confusion on the basics Lack of precedent and consistency Sometimes overlooked during the MOC and project planning process More focus on BWON (so QQQ may be forgotten) Not heavily enforced, but some cases have been significant United States v. Ashland Inc Plea Agreement Required an upgrade of all refinery process sewers, junction boxes, and drains to NSPS QQQ standards Required payment of $9+ million in fines and restitution 4/3/18 Page 3

4 Applicability What is subject to NSPS QQQ? Applies to affected facilities located in refineries for which construction, reconstruction, or modification commenced after May 4, 1987: Individual drain system (IDS) Oil-water separator (OWS) Aggregate facility What is not subject to NSPS QQQ? Stormwater sewer system Ancillary equipment that is physically separate from the wastewater system and does not come into contact with or store oily wastewater Non-contact cooling water systems Italics indicates definition in or /3/18 Page 4

5 Individual Drain System (IDS) IDS means all process drains connected to the first common downstream junction box; includes all such drains and common junction box, together with their associated sewer lines and other junction boxes, down to the receiving oil-water separator 4/3/18 Page 5

6 Oil-Water Separator (OWS) OWS means wastewater treatment equipment used to separate oil from water consisting of a separation tank, which also includes the forebay and other separator basins, skimmers, weirs, grit chambers, and sludge hoppers Also includes slop oil facilities, including tanks Also includes storage vessels and auxiliary equipment located between IDS and OWS Does not include storage vessels or auxiliary equipment that does not come in contact with or store oily wastewater 4/3/18 Page 6

7 Example IDS and OWS to 4/3/18 Page 7

8 Aggregate Facility Aggregate facility means an IDS together with ancillary downstream sewer lines and OWS, down to and including the secondary OWS, as applicable 4/3/18 Page 8

9 Example Aggregate Facility 4/3/18 Page 9

10 Construction Construction means fabrication, erection, or installation of an affected facility In NSPS terms, entire affected facility needs to be added to meet construction definition 4/3/18 Page 10

11 Reconstruction Reconstruction means replacement of components of an existing facility such that: Fixed capital cost of new components exceeds 50% of fixed capital cost to construct a comparable new facility It is technologically and economically feasible to meet NSPS Standards As such, reconstruction is triggered under QQQ when there is a major change to an affected facility, regardless of whether VOC emissions increase 4/3/18 Page 11

12 Modification Modification means any physical or operational change to an existing facility which results in an increase in the emission rate To modify an affected facility under NSPS QQQ, a project must change the oily water sewer system (not change a source of wastewater discharging into the sewers) and must result in increased VOC emissions within the affected facility. Other exclusions may apply Changes excluded from modification are in 60.14(e): A change to the oily water sewer or OWS is excluded if:» Results in no increase of VOC (kg/hr) in affected facility; OR» Costs < 7% of the cost basis of the affected facility prior to the change 4/3/18 Page 12

13 Control Requirements Drains Water seal controls (seal pot, p-leg trap, or other type of trap filled with water that is capable of creating a water barrier between the sewer and atmosphere)* Junction boxes (e.g., manhole) Cover with tight seal around the edge Bolts and gaskets conservative; metal to metal is okay May have open vent pipe; pipe 90 cm (3 ft) in length and 10.2 cm Tight seal on junction box (4 in) in diameter Sewer lines Cannot be open to atmosphere Covered or enclosed; no visual gaps or cracks P-trap water seal *Can install completely closed drain system as an alternative to water seals 4/3/18 Page 13

14 Inspection Requirements Equipment Frequency* Inspection Check Drain active service Monthly Indications of low water levels or other conditions that could reduce the effectiveness of water seal Drain out of service Weekly controls Drain out of service w/ tightly sealed cap or plug Semiannually Cap or plug is in place and is properly installed Junction box Semiannually Cover is in place and has tight seal around edge Aboveground sewer line Semiannually Indications of cracks, gaps, or other problems that could result in VOC emissions *All equipment types require an initial inspection followed by inspections at the noted frequency 4/3/18 Page 14

15 Repair Requirements Equipment Drain active service Drain out of service Drain out of service w/ tightly sealed cap or plug Junction box Aboveground sewer line Repair Attempt Timing* Add water or make first effort at repair as soon as practicable, but no later than 24 hours after detection Make first effort at repair as soon as practicable, but no later than 15 calendar days after broken seal or gap is identified Make first effort at repair as soon as practicable, but no later than 15 calendar days after crack or gap is identified *Delay of repair is allowed if repair is technically impossible without a complete or partial refinery or process unit shutdown; repair must occur before end of next refinery or process unit shutdown 4/3/18 Page 15

16 OWS Requirements OWS tank, slop oil tank, storage vessel, or other auxiliary equipment must have a fixed roof vented to a control device, except no control device is required for limited small separators A floating roof is acceptable alternative standard NSPS K, Ka, and Kb are acceptable equivalent standards for storage vessels Roof doors and openings need to be gasketed and latched Inspect seals, access doors, and other openings semiannually Make first effort at repair as soon as practicable, but no later than 15 calendar days after broken seal/gasket or other problem is identified 4/3/18 Page 16

17 Closed Vent Systems and Control Devices Closed vent systems and control devices must be: Operated at all times when emissions may be vented to them Designed and operated with no detectable emissions (i.e., VOC reading < 500 ppm during initial and semiannual inspections) Vent stream must be equipped with a flow indicator Gauging and sampling devices must be gas-tight Make first effort at repair as soon as practicable, but no later than 30 calendar days after detection 4/3/18 Page 17

18 Recordkeeping Location and date of corrective actions to conform with standards Delay of repair information for components that cannot undergo repair: Expected date of repair Reason for delay Signature of person who decided repair could not be conducted without shutdown Date of successful repair or corrective action 4/3/18 Page 18

19 Recordkeeping cont. Copy of design specs for all equipment used to comply with NSPS QQQ Location of capped or plugged drains Drawings demonstrating that stormwater sewer (or other non-voc sewer) is segregated from oily water sewer Plans and drawings demonstrating that non-contact cooling water does not contact hydrocarbons or oily wastewater and is not circulated through a cooling tower Operating records and performance efficiency demonstration for closed vent systems and control devices, if used to comply with QQQ 4/3/18 Page 19

20 Reporting Notification required for: Construction, reconstruction, or modification of an affected facility Actual date of initial startup Initial certification of compliance Semiannual report should include: All drain inspections not conforming to standard Gaps, cracks, or other problems in junction box covers Repairs/corrective action(s) taken and dates of corrective actions Other information, as applicable 4/3/18 Page 20

21 Questions? Michelle Yakubisin Senior Engineer, ERM Walnut Creek, CA 4/3/18 Page 21