A Technical Review of the Subpart Ja Monitoring and Instrumentation Requirements with Respect to Other Refinery Regulatory Programs for Streamlining Compliance Demonstration at non-Flare Affected Facilities

摘要

Refiners have been diligently coordinating efforts to comply with EPA's updated New Source Performance Standard (NSPS) for petroleum refineries at 40 CFR 60 Subpart Ja since its original promulgation in June 2008 and efforts have continued, and even increased, since the September 2012 regulatory revisions. Subpart Ja provides new emission limits and monitoring options for fluid catalytic cracking units (FCCUs), fluid coking units (FCUs), sulfur recovery plants (SRPs), process heaters, and fuel gas combustion devices (FGCDs). Work practice standards also apply to delayed coking units (DCUs) and flares. Flares are also regulated under Subpart Ja, and due to the November 2015 compliance date for modified flares, refining companies have been working on compliance strategies. These preparations have proven to be a significant multi-disciplinary level of effort needed to facilitate compliance within an organization. The focus of this paper is on the new monitoring and instrumentation requirements for non-flare affected facilities. Discussion of the extensive flare requirements are not considered in this paper. This paper will compare the emission limits, monitoring and instrumentation requirements, and potential areas of concern within Subpart Ja for each non-flare affected facility against those of a typical refinery that is subject to 40 CFR 60 Subpart J (Subpart J), 40 CFR 63 Subpart CC (MACT CC) and 40 CFR 63 Subpart UUU (MACT UUU). Although MACT UUU contains emission limits for affected facilities when Subpart J may not apply, it is assumed for purposes of streamlining this analysis that refineries that comply with the MACT UUU requirements also comply with Subpart J. In addition, strategic monitoring and instrumentation considerations are provided in order to streamline compliance within a Part 70 Title V permit.