REPORT

Set Public Hearing September 13, 1996 to
Amend Rule 1176 - VOC Emissions from Wastewater Systems

SYNOPSIS:

Proposed amendments will ensure further reductions of VOC emissions from process drains and other components of wastewater systems located at refineries, oil and gas production facilities, and chemical and industrial plants.

COMMITTEE:

Not applicable.

RECOMMENDED ACTION:

Set Public Hearing September 13, 1996 to Amend Rule 1176

James M. Lents, Ph.D.
Executive Officer

PL:CC:MN:JC:DR:dr

The purpose of Rule 1176 - Sumps and Wastewater Separators, is to reduce VOC emissions from wastewater systems located at oil production fields, refineries, chemical plants, and industrial facilities engaged in the production and distribution of natural gas and petroleum products. The rule originally was adopted on November 3, 1989 and subsequently amended twice, on January 5, 1990 and May 13, 1994, to address SIP changes.

VOC emissions are generated from wastewater systems whenever the surface of a liquid containing VOCs is exposed to the atmosphere. Such emissions are generally a function of the VOC content in the liquid, flow rate of the liquid, drop height of the liquid, material temperature and vapor pressure, exposed area for evaporation, ambient temperature and wind conditions. The proposed rule targets VOC emission sources in a wastewater system from process drains, and components associated with the sewer lines including junction boxes and manhole covers.

Proposal

Based on staff’s analysis of the proposed amendments, more than three tons per day of VOC emission reductions can be achieved at an overall estimated cost of less than $600 per ton of reduction using a combination of controls. The cost estimates, depending on the selection of air pollution control equipment under worst case, could be as high as about $4,400 per ton of reduction. However, staff believes that facilities will utilize the least costly control options, which achieve VOC emission reductions at an overall estimated cost of less than $600 per ton. The emission reductions will result from control of drains and other wastewater system components.

In the proposed amendments refineries will be provided an option to either control repeat emitting drain system components with a combination of increased monitoring and controls, or to install controls on all drain system components. Refineries are provided six months to begin implementation of either option, and have until the end of year 2000 to incrementally control all drains at a rate of 25% each year, if they choose the latter option.

VOC emissions from the intermediate components of sewer lines connecting drain systems to wastewater separators, such as the junction boxes and manhole covers, will be required to be monitored and controlled, if necessary, for all facilities. Facilities are provided six months to begin implementation of the monitoring requirements and up to six months after obtaining Permits to Construct if air pollution control equipment is necessary to control their emissions.

The proposed amendments will also provide increased operational flexibility to facilities by reducing the monitoring and source test frequencies and by exempting specific, insignificant emission sources. The monitoring frequency is adjusted to reduce the monitoring for low-emitting drain component systems from monthly to quarterly, while it will be increased from monthly to weekly for the fewer high-emitting ones. The monitoring frequency will be reduced from monthly to semi-annually for drain system components equipped with controls. This approach allows focusing resources on drain system components with higher potential to emit VOCs.

The source test frequency for air pollution control equipment is also reduced from semi-annually to once a year and other less expensive compliance demonstration alternatives are provided in lieu of source testing. Also, the exemption for bulk loading terminals is extended from those handling gasoline only to all others. This exemption is not expected to result in any significant emission increases.

In addition, review of the proposed amendments pursuant to CEQA have identified no significant adverse impacts. Therefore, staff plans to recommend adoption of the proposed amendments to Rule 1176 to the AQMD Governing Board.

Policy Issues

One of the major policy issues raised as a result of the proposed amendments relates to whether or not the existing uncontrolled drain system components, such as junction box vents and manhole cover openings, should be monitored and controlled. Overall, the proposed amendments require monitoring and control, if necessary, of VOCs from all potential sources of emissions in wastewater systems. Staff believes that since the wastewater system components are all interconnected, partial control of only certain drain system components would not only leave potentially significant VOC emission sources uncontrolled, but may indeed increase emissions from such uncontrolled sources.

Since very little data was available on emissions from junction box vents and manhole cover openings, staff conducted a series of surveys, monitoring and source tests on such sources at all major refineries in 1996. Based on the results of the surveys, staff has concluded that emissions from these sources are significant and emissions can be reduced cost effectively. In addition, the original intent of the rule was to reduce VOC emissions from the entire wastewater system. Therefore, staff has proposed to require monitoring and control, if necessary, of these sources.

The other major policy issue relates to the level of monitoring and control required for sources with various emission potentials. Staff has considered this issue and has recommended to shift industry resources for monitoring and control to wastewater system components with higher potential to emit VOCs. Therefore, staff has proposed an option for refineries to more frequently monitor and control, if necessary, the repeat emitting sources. In addition, staff has proposed to reduce monitoring frequency for low or non-emitting sources and exempt altogether certain other sources with insignificant emissions.

CEQA & Socioeconomic Analysis

Pursuant to CEQA, staff prepared a Draft Supplemental Environmental Assessment (SEA) for the proposed amendments to Rule 1176. The Draft SEA does not identify any significant adverse environmental impacts from the proposed project and has been circulated for a 30-day public review and comment period ending July 29, 1996. All comments received will be addressed and incorporated into the Final SEA for the proposed project.

Potential impacts of the proposed amendments were analyzed using the AQMD’s Socioeconomic REMI model (1993). The analysis estimates that the employment impact resulting from the proposed amendments on average is about seven jobs forgone per year between 1997 and 2010. This number could range to about 50 jobs forgone per year between 1997 and 2010 if the facilities choose the more expensive control option.

Implementation Plan

The proposed amendments will require a certified inspector program to be implemented on or after July 1, 1997 or at a later date approved by the AQMD. This inspectors’ certification program will be jointly implemented with the representatives of the affected industries once the proposed amendments are adopted.

Resource Impacts

The proposed amendments will require development of a certified inspector program and additional monitoring by AQMD inspectors of junction box vents and manhole covers. In the mean time, reduced workloads are expected by the proposed exclusion of bulk terminals from this rule. Overall, minimal impact on AQMD resources is projected.

Attachments

Summary of Proposed Amendments

Rule Development Process

Key Contacts

Proposed Rule Language

Draft Staff Report

Draft Socioeconomic Report

CEQA Analysis