On January 9, 2019, the Bay Area Air Quality Management District (BAAQMD) published amendments to three of its regulations relevant to refinery operations. Amendments were made to Regulation 6, Rule 5: Particulate Emissions from Refinery Fluidized Catalytic Cracking Units (Rule 6-5) and Regulation 11, Rule 10: Hexavalent Chromium Emissions from All Cooling Towers and Total Hydrocarbon Emissions from Petroleum Refinery Cooling Towers (Rule 11-10) as required by the enforcement agreement of lawsuit Valero, et al. v. Bay Area Air Quality Management District. Similarly, amendments were also made to Regulation 12, Rule 15: Petroleum Refining Emissions Tracking (Rule 11-15) as required by the enforcement agreement from Western States Petroleum Association (WSPA), et al. v. Bay Area Air Quality Management District.

The amended refinery rules reflect the following revisions:

  • Rule 6-5, Section 111 clarifies the exemption for emissions abated by a wet scrubber.
  • Rule 6-5, Section 301 removes placeholder emission limits for condensable particulate matter and sulfur dioxide.
  • Rule 11-10, Sections 105 through 107 clarify the limited exemptions for cooling towers not in petroleum refining service and small cooling towers.
  • Rule 11-10, Section 304 standardizes the monitoring requirements to a weekly monitoring schedule with option for twice-monthly monitoring given consecutive results below the Leak Action Level.
  • Rule 11-10, Section 305 modifies leak action requirements to align with NESHAP Subpart CC conditions.
  • Rule 11-10, Section 401 clarifies cooling tower sampling requirements.
  • Rule 11-10, Section 402 removes Best Modern Practices which could conflict with process safety management requirements.
  • Rule 11-10, Section 504 removes no longer applicable operating recordkeeping requirements.
  • Rule 12-15, Sections 205 and 209 clarify definitions and applicability.
  • Rule 12-15, Section 206 removes cargo carrier emissions inventory requirements.
  • Rule 12-15, Section 401 clarifies the emission calculation methodology to be used for estimating greenhouse gas emissions from refinery fuel gas systems.
  • Rule 12-15, Sections 402 through 404 and 501 clarify the review and approval process for Annual Emissions Inventories, Air Monitoring Plans, and Fence-line Monitoring Plans.
  • Rule 12-15, Sections 405 and 406 address comment periods for emissions inventory and air monitoring guidelines.
  • Rule 12-15, Section 408 modifies monthly crude slate reporting requirements.
  • Rule 12-15, Section 407 clarifies designation of confidential information.

Interested parties can learn more about the amendments in the Refinery Rules Final Staff Report or the BAAQMD website. For any questions regarding the amended refinery rules, please contact Divya Agarwal at dagarwal@trinityconsultants.com or (510) 285-6351.