An Overview of NSPS Subpart QQQ VOC Emissions from ... · Overview of NSPS Subpart QQQ 4/3/18 Page...

4/3/18 Overview of NSPS Subpart QQQ

An Overview of NSPS Subpart QQQ –

VOC Emissions from Petroleum

Refinery Wastewater Systems

Michelle Yakubisin

Senior Engineer, ERM

© Copyright 2018 by ERM Worldwide

Group Limited and/or its affiliates (‘ERM’).

All Rights Reserved. No part of this work

may be reproduced or transmitted in any

form or by any means, without prior

written permission of ERM.


Objectives

• Importance of 40 CFR Part 60 Subpart QQQ (NSPS QQQ)

• Overview of NSPS QQQ

• Applicability

• Definitions

• Control standards

• Recordkeeping and reporting

• Q&A


Why is NSPS QQQ Important?

• Confusion on the basics

• Lack of precedent and consistency

• Sometimes overlooked during the MOC and project planning process

• More focus on BWON (so QQQ may be forgotten)

• Not heavily enforced, but some cases have been significant

• United States v. Ashland Inc. 2002 Plea Agreement

• Required an upgrade of all refinery process sewers, junction boxes, and drains to NSPS

QQQ standards

• Required payment of $9+ million in fines and restitution


Applicability

• What is subject to NSPS QQQ?

• Applies to affected facilities located in refineries for which construction,

reconstruction, or modification commenced after May 4, 1987:

• Individual drain system (IDS)

• Oil-water separator (OWS)

• Aggregate facility

• What is not subject to NSPS QQQ?

• Stormwater sewer system

• Ancillary equipment that is physically separate from the wastewater system and

does not come into contact with or store oily wastewater

• Non-contact cooling water systems Italics indicates definition in §60.691 or 60.2


Individual Drain System (IDS)

• IDS means all process drains connected to the first common downstream

junction box; includes all such drains and common junction box, together

with their associated sewer lines and other junction boxes, down to the

receiving oil-water separator


Oil-Water Separator (OWS)

• OWS means wastewater treatment equipment used to separate oil from

water consisting of a separation tank, which also includes the forebay and

other separator basins, skimmers, weirs, grit chambers, and sludge

hoppers

• Also includes slop oil facilities, including tanks

• Also includes storage vessels and auxiliary equipment located between

IDS and OWS

• Does not include storage vessels or auxiliary equipment that does not come in

contact with or store oily wastewater


Example IDS and OWS

to


Aggregate Facility

• Aggregate facility means an IDS together with ancillary downstream sewer

lines and OWS, down to and including the secondary OWS, as applicable


Example Aggregate Facility


Construction

• Construction means fabrication, erection, or installation of an affected

facility

• In NSPS terms, entire affected facility needs to be added to meet

construction definition


Reconstruction

• Reconstruction means replacement of components of an existing facility

such that:

• Fixed capital cost of new components exceeds 50% of fixed capital cost to

construct a comparable new facility

• It is technologically and economically feasible to meet NSPS Standards

• As such, reconstruction is triggered under QQQ when there is a major

change to an affected facility, regardless of whether VOC emissions

increase


Modification

• Modification means any physical or operational change to an existing

facility which results in an increase in the emission rate

• To modify an affected facility under NSPS QQQ, a project must change

the oily water sewer system (not change a source of wastewater

discharging into the sewers) and must result in increased VOC emissions

within the affected facility. Other exclusions may apply

• Changes excluded from modification are in § 60.14(e):

• A change to the oily water sewer or OWS is excluded if:

» Results in no increase of VOC (kg/hr) in affected facility; OR

» Costs < 7% of the cost basis of the affected facility prior to the change


Control Requirements• Drains

• Water seal controls (seal pot, p-leg trap, or other type of trap filled

with water that is capable of creating a water barrier between the

sewer and atmosphere)*

• Junction boxes (e.g., manhole)

• Cover with tight seal around the edge

• Bolts and gaskets conservative; metal to metal is okay

• May have open vent pipe; pipe ≥ 90 cm (3 ft) in length and ≤ 10.2 cm

(4 in) in diameter

• Sewer lines

• Cannot be open to atmosphere

• Covered or enclosed; no visual gaps or cracks

P-trap water seal

*Can install completely closed drain system as an alternative to water seals

Tight seal on junction box


Inspection Requirements

Equipment Frequency* Inspection Check

Drain – active service Monthly Indications of low water levels or other conditions

that could reduce the effectiveness of water seal

controlsDrain – out of service Weekly

Drain – out of service w/

tightly sealed cap or plug

Semiannually Cap or plug is in place and is properly installed

Junction box Semiannually Cover is in place and has tight seal around edge

Aboveground sewer line Semiannually Indications of cracks, gaps, or other problems that

could result in VOC emissions

*All equipment types require an initial inspection followed by inspections at the noted frequency


Repair Requirements

*Delay of repair is allowed if repair is technically impossible without a complete or partial refinery or process unit shutdown; repair must occur before end of next refinery or process unit shutdown

Equipment Repair Attempt Timing*

Drain – active service Add water or make first effort at repair as soon as practicable,

but no later than 24 hours after detectionDrain – out of service

Drain – out of service w/ tightly

sealed cap or plug

Junction box Make first effort at repair as soon as practicable, but no later

than 15 calendar days after broken seal or gap is identified

Aboveground sewer line Make first effort at repair as soon as practicable, but no later

than 15 calendar days after crack or gap is identified


OWS Requirements

• OWS tank, slop oil tank, storage vessel, or other auxiliary equipment must

have a fixed roof vented to a control device, except no control device is

required for limited small separators

• A floating roof is acceptable alternative standard

• NSPS K, Ka, and Kb are acceptable equivalent standards for storage vessels

• Roof doors and openings need to be gasketed and latched

• Inspect seals, access doors, and other openings semiannually

• Make first effort at repair as soon as practicable, but no later than 15 calendar

days after broken seal/gasket or other problem is identified


Closed Vent Systems and Control Devices

• Closed vent systems and control devices must be:

• Operated at all times when emissions may be vented to them

• Designed and operated with no detectable emissions (i.e., VOC reading < 500

ppm during initial and semiannual inspections)

• Vent stream must be equipped with a flow indicator

• Gauging and sampling devices must be gas-tight

• Make first effort at repair as soon as practicable, but no later than 30

calendar days after detection


Recordkeeping

• Location and date of corrective actions to conform with standards

• Delay of repair information for components that cannot undergo repair:

• Expected date of repair

• Reason for delay

• Signature of person who decided repair could not be conducted without

shutdown

• Date of successful repair or corrective action


Recordkeeping cont.

• Copy of design specs for all equipment used to comply with NSPS QQQ

• Location of capped or plugged drains

• Drawings demonstrating that stormwater sewer (or other non-VOC sewer) is segregated

from oily water sewer

• Plans and drawings demonstrating that non-contact cooling water does not contact

hydrocarbons or oily wastewater and is not circulated through a cooling tower

• Operating records and performance efficiency demonstration for closed vent systems

and control devices, if used to comply with QQQ


Reporting

• Notification required for:

• Construction, reconstruction, or modification of an affected facility

• Actual date of initial startup

• Initial certification of compliance

• Semiannual report should include:

• All drain inspections not conforming to standard

• Gaps, cracks, or other problems in junction box covers

• Repairs/corrective action(s) taken and dates of corrective actions

• Other information, as applicable


Questions?

Michelle Yakubisin

Senior Engineer, ERM

Walnut Creek, CA

[email protected]

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