Proposal:

Amend Rule 1176 - VOC Emissions from Wastewater Systems

Synopsis:

Proposed amendments will establish revised monitoring and controls that will reduce VOC emissions by 3.0 tons per day through year 2010 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:

1. Certify the Final Supplemental Environmental Assessment for Proposed Amended Rule 1176 - VOC Emissions from Wastewater Systems.

2. Amend Rule 1176 - VOC Emissions from Wastewater Systems.

James M. Lents, Ph.D.
Executive Officer

Background

The purpose of Rule 1176 - Sumps and Wastewater Separators, is to reduce VOC emissions from wastewater systems located at refineries, oil production fields, chemical plants, and other 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 box vents and openings in 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.

Based on recent additional comments provided by industry, the proposed amendments have been revised from those in the Set Hearing package to provide increased flexibility and cost savings to the affected sources. The major changes include a reduced monitoring frequency and, in some cases, a complete exemption from monitoring requirements for specific drain system components and a three-month extension in the effective date of the rule to allow for characterization, selection and implementation of a control strategy for drain system components, and in particular junction boxes, at refineries.

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

VOC emissions from the intermediate components of sewer lines connecting drains 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 nine months to assess emission levels from junction box vents and manhole cover openings and to develop a control strategy. At that time, facilities begin implementation of their selected control strategy and are provided with up to six months after obtaining Permits to Construct if air pollution control equipment which requires a Permit to Construct and Operate is necessary to control emissions from any wastewater system components.

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. In the latest proposed amendments, the monitoring frequency for refineries is reduced from monthly to quarterly for low-emitting drain component systems, and from monthly to semi-annually and annually for drain system components equipped with controls and for inaccessible components, respectively. The monitoring frequency is also reduced from monthly to quarterly for all drain system components and to semi-annually and annually for specific drain system components for facilities which can demonstrate that a significant percent of the drain system components at their facilities are non-emitters. 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.

In addition, the monitoring frequency is reduced from monthly to quarterly for all drain system components and to semi-annually and annually for specific drain system components for all other non-refinery facilities subject to this rule.

This approach allows focusing resources on drain system components with higher potential to emit VOCs. The reduced monitoring and source testing frequencies, for example, could result in cost savings close to $148,000 per year just for one of the large refineries alone. The reduced monitoring frequency will also result in cost savings in excess of $73,000 per year as a whole, for other non-refinery facilities such as oil and gas production, chemical and other industrial facilities.

Also, the exclusion of bulk loading terminals from the applicability of the rule is extended from those handling gasoline only to all others. This exclusion is not expected to result in any significant emission increases, and will result in altogether additional monitoring cost savings in excess of $57,000 per year for the affected facilities.

Review of the proposed amendments pursuant to CEQA have identified no significant adverse impacts. Therefore, staff recommends adoption of the proposed amendments to Rule 1176.

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. However, in order to address industry’s concerns, staff has proposed a period of nine months to allow refineries to better characterize their emission sources and to select and implement the appropriate control strategy.

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 to reduce the monitoring frequency for sources with lower potential to emit, while focusing resources more to monitor and control, if necessary, the high and repeat emitting sources. In addition, staff has proposed to reduce source test frequencies for air pollution control equipment and to 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 did not identify any significant adverse environmental impacts from the proposed project and was circulated for a 30-day public review and comment period ending July 29, 1996. One comment letter was received and it has been incorporated into the Final SEA which is included in this final board package. No significant changes were made to the SEA between the Draft and the Final version.

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. A notice will be sent to all affected sources informing them of the start of implementation of the certification program.

Resource Impacts

The proposed amendments will require development of a certified inspector program, additional monitoring of junction box vents and manhole covers and additional review of the wastewater system compliance plans and control strategies by AQMD staff. In the mean time, reduced workloads are expected by the proposed exclusion of bulk terminals and other sources from this rule. Overall, existing AQMD resources will be sufficient to implement the proposed changes to this rule with minimal impact on the budget.

Attachments
Summary of Proposed Amendments
Rule Development Process
Key Contacts
Resolution
Proposed Rule Language
Staff Report
Socioeconomic Report
CEQA Analysis