Louisiana Mact Determination
LOUISIANA
REFINERY
MACT DETERMINATION
JULY 26, 1994
July 26, 1994
REFINERY MACT DETERMINATION
Except where this MACT determination is more stringent, the requirements in this document do not supersede existing or future federal or state mandated regulations or requirements. Affected facilities shall comply with the more stringent of the applicable requirement or regulation. This MACT determination is applicable to refineries which are classified as an air toxic major source as defined in LAC 33:III.Chapter 51.Subchapter A.
- Storage Tanks
Affected refineries are required to comply with the most stringent requirements of those listed below and where applicable. This is regardless of when the tank was constructed and regardless of where (which parish) the tank is located.
(1)Tanks storing benzene as defined in LAC 33:III.5143.B must meet the requirements of LAC 33:III.5143 entitled “Emission Standard for Benzene Emissions from Benzene Storage Vessels (Subpart Y)” if applicable according to LAC 33:iii.5141.A.
(2)Tanks storing volatile organic liquids (VOL’s) as defined in LAC 33:III.3301.B and containing Class I and/or Class II VTAPs must meet the design requirements of LAC 33:III.3301 entitled “Standards of Performance for Storage Vessels for Petroleum Liquids (Subpart Kb)” or an equivalent method approved by the Air Quality Division. The maximum vapor pressure of 1.50 psi is to be used to determine applicability of regulation 33:III.3301.C.1 instead of the 0.75 psi.
(3)All other tanks with storage capacity, vapor pressure or storage content that do not require them to be regulated under A.1 or A.2 above and containing Class I and/or Class II VTAPs must meet the requirements of LAC 33:III.2103 entitled “Storage of Volatile Organic Compounds” where applicable.
The exemptions in LAC 33:III.2103.G are not allowed except for JP-4 fuels stored in horizontal underground tanks.
(4)In addition, the following is required for external floating roof storage tanks with a capacity greater than 40,000 gallons and storing a liquid having a total vapor pressure of 1.5 psia or greater and containing Class I and/or Class II VTAPs.
The combined emissions from guide poles/samples wells and stilling well systems from each affected tank must be controlled to an average efficiency of 90 per cent or greater. The method of control must be submitted to the Department for approval.
(5)Inspection, recordkeeping, and reporting schedules for all tanks complying with A.1, 2, 3, and 4 must at a minimum meet the requirements of LAC 33:III.2103 and must meet any other regulation or requirement which the storage tank is subject.
(6)Installation is required by December 20, 1996. Requests for extension from the December 20, 1996 compliance date will be considered on a case by case basis for situations which require the tank to be removed from service to install the controls.
- Waste Water Treatment
40 CFR 61 Subpart FF – National Emission Standard for Benzene Waste Operation.
- Fugitive Emissions
See separate Document.
- Loading/Unloading Facilities
LAC 33:III.2107, .2108, .2131, .2135, and .2137.
- Cooling Towers
Federal regulation 40 CFR 63 Subpart Q proposed August 12, 1993.
- Process Vents
(1)The owner or operator of a miscellaneous process vent shall comply with the requirements of (1)(a), (1)(b) or (1)(c).
(a)Thermal Oxidation with a 98% or greater destruction or removal efficiency of the organic toxic air pollutants.
Halogenated vent streams shall not be vented to a flare.
(b)Reduce pre-control emissions of organic TAP by 98 weight percent or to a concentration of 20 parts per million by volume, on a dry basis, corrected to 3 percent oxygen, whichever is less stringent.
(c)sections N.1 through N.5 of the “Louisiana MACT Determination for Refinery Emission Leaks”.
(2)If a boiler or process heater is used to comply with the percent reduction requirement or concentration limit specified in paragraph (1)(b), then the vent stream shall be introduced into the flame zone.
(3)Halogenated miscellaneous process vent streams that are combusted shall be controlled according to paragraph (3)(a) or (3)(b).
(a)If a combustion device is used to comply with paragraph (1)(b) fir a halogenated vent stream, combustion device to an additional control device, which may be a scrubber or another control device, before it is discharged to the atmosphere. The additional control device shall reduce overall emissions of hydrogen halides and halogens by 99 percent or shall reduce the outlet mass of total hydrogen halides and halogens to less than 1 pounds per hour whichever is less stringent.
(b)A control device, such as a scrubber may be used to reduce the vent stream halogen atom mass emission rate to less than 1 pound per hour prior to any combustion control device, and thus make the vent stream nonhalogenated. The vent stream must comply with the requirements of paragraphs (1)(a) or (1)(b).
The requirements of F.1 through F.3 apply to any miscellaneous process vent which emits a gas stream containing greater than 20 ppmv organic toxic air pollutant that is continuously or periodically discharged during operation of a petroleum refining process unit. Excluded are gaseous streams routed to a fuel gas system for use as fuel, relief valves discharges, episodic or non-routine sources such as those associated with startup, shutdown, malfunction, maintenance, depressurizing, and catalyst transfer operations, and in situ sampling systems, vents from steam strippers applied to meet the wastewater requirements of this MACT determination or the benzene waste NESHAP, fluidized catalytic cracking unit catalyst vents, catalytic reformer regeneration vents, and sulfur plants; and vents from control devices such as scrubbers, boilers, incinerators, and electrostatic precipitators applied to fluidized catalytic cracking unit catalyst regeneration vents, catalytic reformer regeneration vents and sulfur plant vents. Miscellaneous process vents include but are not limited to vents from caustic wash accumulators, distillation towers condensers/accumulators, flash/knock-out drums, reactor vessels, scrubber overheads, stripper overheads, vacuum (steam) ejectors, wash tower overheads, water wash accumulators, and blowdown condensers/
accumulators.
Halogenated vent stream or halogenated stream means a vent stream from a miscellaneous process vent determined to have a mass emission rate of halogen atoms contained in organic compounds of 1 pound per hour or greater; or a catalyst reformer catalytic regeneration vent determined to have a total halogen and halogen halide mass emission rate of 1 pound per hour or greater.
LOUISIANA MACT DETERMINATION
FOR
REFINERY EQUIPMENT LEAKS
(FUGITIVE EMISSION SOURCES)
JULY 26, 1994
1
LOUISIANA MACT DETERMINATION FOR REFINERY EQUIPMENT LEAK
(FUGITIVE EMISSION SOURCES)
SECTION PAGE
A. Applicability and Designation of Sources 1
B. Definitions 1
C. General 4
D. Pumps in Light Liquid Service 5
E. Compressors 6
F. Pressure Relief Devices in Gas/Vapor Service 7
G. Sampling Connection Systems 7
H. Open-Ended Valves or Lines 8
I. Valves in Gas/Vapor Service and in Light
Liquid Service 8
J. Alternative Means of Emission Limitation:
Valves in VTAP Service---Skip Period Leak Detection 9
and Repair
K. Instrumentation Systems; Pressure Relief Devices
in Liquid Service; and Flanges and other
Connectors in Heavy Liquid Service 10
L. Surge Control Vessels and Bottoms Receivers 10
M. Delay of Repair 11
N. Closed-Vent Systems and Control Devices 11
O. Connectors in Gas/Vapor Service and in 13
Light Liquid Service
P. Test Methods and Procedures 16
Q. Recordkeeping Requirements 18
R. Reporting Requirements 20
1
LOUISIANA MACT DETERMINATION FOR REFINERY EQUIPMENT LEAKS
(FUGITIVE EMISSION SOURCES)
A. Applicability and Designation of Sources
1. The provisions of this MACT determination apply to each of the following sources that are intended to operate in volatile organic toxic air pollutant (VOTAP) service: pumps, compressors, pressure relief devices, instrumentation systems, sampling connection systems, openended valves or lines, valves, flanges and other connectors, bottoms receivers, surge control vessels, and control devices or systems that are intended to operate in excess of 300 hours during the calendar year.
2. The provisions of this MACT determination are effective January 1, 1995 unless a later date is specified in the approved Compliance Plan and/or Certification of Compliance and apply to all refineries which are classified as an air toxic major source as defined in LAC 33:III.5103.
3. While the provisions of this MACT determination are effective, a source to which this standard applies that is also subject to the provisions of NSPS, NESHAP, or LESHAP will be required to comply with the most stringent provision of the applicable regulations. If the equipment is regulated by another regulation which requires a more frequent monitoring schedule with a higher leak definition then the monitoring is required to be performed at the more frequent monitoring schedule with the lower leak definition.
4. Upon written request the Air Quality Division will determine within 18 months of promulgation of the Environmental Protection Agency's Refinery MACT Standard which provisions of the Louisiana MACT determination will remain in affect.
B. Definitions
The terms in this MACT determination are used as defined in LAC 33:III.111 except those terms specifically defined in LAC 33:III.5103.A or herein as follows:
Bottoms Receiver means a tank that collects distillation bottoms before the stream is sent for storage or for further downstream processing.
ClosedVent System means a system that is not open to the atmosphere and that is composed of piping, connections, and if necessary, flowinducing devices that transport gas or vapor from a piece or pieces of equipment to a control device.
Connector means flanged, screwed, or other joined fittings used to connect two pipe lines or a pipe line and a piece of equipment. A common connector is a flange. Joined fittings welded completely around the circumference of the interface are not considered connectors for the purpose of this MACT determination.
Control Device means an enclosed combustion device, vapor recovery system, or flare.
Double Block and Bleed System means two block valves connected in series with a bleed valve that can vent the line between the two block valves.
Equipment means each pump, compressor, pressure relief device, sampling connection system, openended valve or line, valve, flange or other connector, bottoms receiver, surge control vessel, and instrumentation system in VOTAP; and any control devices or systems required by this document.
First Attempt at Repair means to take action within 5 days of determining the equipment is leaking for the purpose of stopping or reducing leakage of VOTAP to the atmosphere using best practices.
In Gas/Vapor Service means that a piece of equipment in VOTAPservice contains a gas or vapor at operating conditions.
In Heavy Liquid Service means that a piece of equipment in organic toxic air pollutant service is not in gas/vapor service and is not in light liquid service.
In Light Liquid Service means the equipment contacts a fluid which meets the following conditions:
a) The vapor pressure of one or more of the components is greater than 0.3 kPa at 20°C. Vapor pressure may be obtained from standard reference texts or may be determined by ASTM D-2879.
b) The total concentration of the pure components having a vapor pressure greater than 0.3 kPa at 20°C is equal to or greater than 20 percent by weight.
c) The fluid is a liquid at operating conditions. In Liquid Service means that a piece of equipment in VOTAPservice is not in gas/vapor service.
InSitu Sampling Systems means non-extractive samples or inline samplers.
Instrumentation System means a group of equipment components used to condition and convey a sample of the process fluid to analyzers and instruments for the purpose of determining process operating conditions (e.g., composition, pressure, flow, etc.). Valves and connectors are the predominant type of equipment used in instrumentation systems; however, other types of equipment may also be included in these systems. Only valves nominally 0.5 inches and smaller and connectors nominally 0.75 inches and smaller in diameter are considered instrumentation systems for the purposes of this document. Valves greater than nominally 0.5 inches and connectors greater than nominally 0.75 inches associated with instrumentation systems are not considered part of instrumentation systems and must be monitored individually.
In Vacuum Service means that equipment is operating at an internal pressure which is at least 20 inches of water below ambient pressure.
In VOC Service means for the purposes of this document, that a) the piece of equipment contains or contacts a process fluid that is at least 10 percent VOC by weight (see LAC 33:III.111 of the Louisiana Air Quality Regulations for the definitions of volatile organic compounds or VOC) and
(b) the piece of equipment is not in heavy liquid service.
In VOTAP Service means that a piece of equipment either contains or contacts a volatile fluid (liquid or gas) that is at least 5 percent by weight the sum of Class I and Class II organic toxic air pollutants or that is at least 10 percent by weight the sum of Class I, Class II, and Class III organic toxic air pollutants listed in Table 51.1 of LAC 33:III.51 Subchapter A. In determining which streams must be monitored or controlled, the facility owner or operator has the option of using the 5 percent by weight the sum of Class I and Class II organic toxic air pollutants or 10 percent by weight the sum of Class I, II, and Class III organic toxic air pollutant. The owner or operator must use the same option for all streams in determining which streams will be regulated under this MACT determination and document it in the record required in Section Q.
OpenEnded Valve or Line means any valve, except pressure relief valves, having one side of the valve seat in contact with process material and one side open to atmosphere, either directly or through open piping.
Pressure Release means the emission of materials resulting from the system pressure being greater than the set pressure of the pressure relief device.
Process Unit means equipment assembled to produce a VOTAP organic toxic air pollutant or its derivatives as intermediates or final products, or equipment assembled to use a VOTAP organic toxic air pollutant in the production of a product. A process unit can operate independently if supplied with sufficient feed or raw materials and sufficient product storage facilities.
Process Unit Shutdown means a work practice or operational procedure that stops production from a process unit or part of a process unit. An unscheduled work practice or operational procedure that stops production from a process unit or part of a process unit for less than 24 hours is not a process unit shutdown. The use of spare equipment and technically feasible bypassing of equipment without stopping production are not process unit shutdowns.
Pseudorandom means of, pertaining to, or being random numbers generated by a definite, nonrandom computational process.
Repaired means equipment is adjusted, or otherwise altered, to eliminate a leak as defined in the applicable section of this determinationindicated by one of the following:
(a) an instrument reading of less than 1,000 ppm, less than 2,000 ppm for pumps, less than 5,000 ppm for compressors, and less than 500 for compressors that are designated as no detectable emissions for equipment required to be monitored;
(b) for equipment listed in Sections D and K, there is no indication of liquids dripping, or
(c) for equipment equipped with a leak detection sensor(s), there is no indication by a sensor(s) that a seal or barrier fluid system has failed.
Quarterly means a three-month period. For new sources, the first quarterly period concludes on the last day of the last full month during the 90 days following initial startup. For existing sources, the first quarterly period concludes on the last day of the last full month during the 90 days after the effective date of this MACT determination.
Sensor means a device that measures a physical quantity or the change in a physical quantity, such as temperature, pressure, flow rate, pH, or liquid level.
Surge Control Vessel means feed drums, recycle drums, and intermediate vessels. Surge control vessels serve several purposes including equalization of load, mixing, recycle, and emergency supply.
Volatile means any fluid which has a vapor pressure of 1.5 pounds per square inch absolute or greater under actual flow or storage conditions.
Volatile Organic Toxic Air Pollutant or VOTAP means any Class I, Class II, or Class III volatile organic air pollutant in Table 51.1 of LAC 33:III.51. Subchapter A.
C. General
1. Each owner or operator subject to the provisions of this MACT determination shall demonstrate compliance with the requirements of Sections C through O for each new and existing refinery except as provided in Sections J and P.
2. Compliance with this MACT determination will be determined by review of records, review of performance test results, and/or inspection using the methods and procedures specified in Section P.
3. Each piece of equipment in a process unit to which this MACT determination applies shall be identified such that it can be distinguished readily from equipment that is not subject to this MACT determination. Identification of the equipment does not require physical tagging of the equipment. For example, the equipment may be identified on a plant site plan, in log entries, or by designation of process unit boundaries by some form of weatherproof identification.
4. Equipment that is in vacuum service is excluded from the requirements of Sections D through O if it is identified as required in paragraph Q.5.d.
5. Any equipment that has been physically removed from service, disassembled or dismantled must be monitored to determine if it is leaking in the next scheduled monitoring period or within one year of placing back in service whichever occurs first. A record of the monitoring must be maintained in the log required in Subsection Q.5. Repair of any equipment found leaking must be performed in accordance with the appropriate Section for that type of equipment monitored.
D. Pumps in Light Liquid Service
1. Monitoring
a. Each pump shall be monitored quarterly to detect leaks by the methods specified in Subsection P.2, except as provided in Subsection C.4 and Subsections D.4, 5, and 6 of this Section.
b. Each pump shall be checked by visual inspection each calendar week for indications of liquids dripping from the pump seal. If there are indications of liquids dripping from the pump seal, the pump shall be monitored within 5 days.
2. If an instrument reading of 2,000 ppm or greater is measured, a leak is detected.
3. Repairs
a. When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected, except as provided in Section M.