ENV-11-25 Implications of the EPA Residual Risk Information Collection Request (ICR) for Petroleum Refineries (and Others)

Description:

Many of the emissions estimation techniques discussed in the “Emissions Estimation Protocol for Petroleum Refineries” (Protocol) issued in March 2011 for the EPA Residual Risk Information Collection Request (ICR) are significantly different than current industry-wide practices. Key differences in the emissions estimation techniques provided in the Protocol include, but are not limited to, the following: 1. Reporting of additional hazardous air pollutants (HAPs) from combustion sources; 2. Use of AP-42 calculation methods instead of the EPA TANKS4.09d software for emissions estimates from tanks and calculation of maximum hourly emission rates; 3. Use of the refinery wastewater emission tool (RWET) instead of the EPA Water9 software, 4. Revised emissions estimating techniques from equipment leaks; and 5. Updated default stream speciation information. Although the ICR is not considered a compliance-enforcement initiative, the consequences of these new emissions estimates have wide-ranging regulatory compliance implications. Resulting increases in emissions estimates could result in possible exceedance of permit limits, which are based upon traditional calculation methodologies. Refineries may be required to perform additional atmospheric dispersion modeling to demonstrate compliance with the National Ambient Air Quality Standards (NAAQS). Furthermore, updated emissions estimates could also result in the need to change state emissions inventories, and, thus may require revisions to State Implementation Plans (SIPs). Due to the inclusion of additional HAPs from combustion sources along with other aforementioned emissions estimation differences, refineries may be required to update EPA Toxic Release Inventory (TRI) reports. In turn, discrepancies in actual refinery representations of toxic emissions reductions progress over time could arise. Finally, new emissions estimation techniques could result in additional regulations at both the state and federal level, and the associated additional control technologies, operating limits and emissions monitoring systems.