The US Environmental Protection Agency proposed giving refiners an additional 18 months to comply with portions of air emissions limits that the federal agency published in December 2015. Comments on the proposal, which appeared in the Feb. 9 Federal Register, will be accepted through Mar. 25.
EPA said it received additional information that indicated that deadlines for maintenance vents and periods of startup, shutdown, and hot standby for fluid catalytic cracking units (FCCU) and for sulfur recovery units (SRU) startups or shutdowns do not give refiners enough time to go through their a management of change process.
This process includes addressing safety concerns associated with potential operational or procedural changes and coordinating any changes with other applicable regulatory requirements, the agency explained. The US Occupational Safety and Health Administration and EPA both require it for refiners and other large manufacturing facilities.
As part of the process, EPA said that it anticipates refiners will need to perform an upfront assessment to determine what changes are required to meet the new maintenance vent requirements and standards for FCCUs and SRUs.
“Based on our review of information brought forward by industry representatives, refinery owners or operators may have to adjust or install new instrumentation, including alarms, closed drain headers, equipment blowdown drums, and other new or revised processes and controls in order to comply with these new provisions,” it said.
Facilities also may have to hire a vendor to assist with the project and complete the procurement process, EPA said. It also anticipates that facilities will have to assess risks of chemical accidents and catastrophic events, and review and revise standard operating procedures, as necessary.
Management of change provisions also require that refinery employees involved in a process and maintenance operation, and contract employees whose jobs are affected by the change receive training beforehand, EPA said. “Finally, facilities are required to conduct pre-startup safety reviews and obtain authorization for use to fully implement and start up the modified process and/or equipment,” it added.
The proposal does not affect does not affect the final rule’s flagship requirements such as fenceline monitoring, flares, and delayed coker controls, nor does it change anticipated emission reductions, which include 5,200 tons/year of toxic air pollutants, and 50,000 tons/year of volatile organic compounds, an EPA spokeswoman told OGJ by e-mail.
The compliance deadline for those requirements remains Jan. 30, 2019, 3 years from the rule’s effective date, she said.
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