(36d) Air Quality Regulations Path for the Ethylene Industry

This paper will analyze the evolution of key air quality regulations over the last twenty five years as related to the Ethylene industry.  It will focus on two important aspects of air quality¯permitting and compliance, and try to explain how the picture (within the context of state and federal rules) has changed considerably over time.   It will outline the important aspects air quality regulations for facilities that are planning expansion/changes in the near future as well as those that are simply trying to stay in compliance.

For Ethylene facilities that are planning expansions/changes at the site in the near future, air permitting for modifications and/or new construction has become increasingly challenging.   The new short-term National Ambient Air Quality Standards (NAAQS) for NO2, PM2.5, and SO2 are extremely stringent and facilities will have to do a fair amount of planning and assessment internally before giving a new expansion project the green light.   There is a distinct possibility that in order to ameliorate the off-site impacts for these pollutants, additional controls or operational restrictions may be required during permitting.  The NAAQS for ozone (with NOx and Volatile Organic Compounds (VOC) as precursors), may present a slightly different problem while trying to permit VOC emissions in certain areas of the country.  In areas deemed as nonattainment for ozone (like the Houston/Galveston area), availability of emission offsets for VOC may seriously impede projects.  Then, there is the usual slate of New Source Performance Standards (NSPS) to contend with, that regulate emissions from process vents, storage tanks, steam generating units, and fugitive components (e.g. valves, connectors, pumps, etc.).  And if that wasn’t exciting enough, EPA has added one more pollutant called Greenhouse Gases (GHGs) to the smorgasbord of permitting.  Yes, GHG is now a PSD pollutant (with a very low “modification” trigger level ), and so any new project at an Ethylene facility will most likely result in an extensive Best Available Control Technology (BACT) review for GHG as part of PSD permitting.

Even for an “existing” source that is not contemplating any expansions or changes, the last 25 years have brought in their wake, a myriad of rules to comply with on a day to day basis.  These include Federal Rules like the Maximum Achievable Control Technology (MACT) standards targeting hazardous air pollutants (HAP) emissions from process vents, storage tanks, transfer racks, cooling towers, and fugitive components and the Benzene Waste NESHAP (BWON) standards regulating benzene emissions from waste/wastewater generated from Ethylene facilities.  At the State Level, these include the plethora of rules promulgated as part of State Implementation Plans (SIP) regulating VOC, NOx, PM, and SO2 emissions from various sources.  In all, most States now have more stringent operational standards for flares (with even more in the pipeline), fugitive components monitoring, and compliance with Maintenance, Startup, and Shutdown (MSS) permits/plans.  Finally, under the Title V program and its semi-annual deviation report and annual certifications, most Ethylene facilities must develop and implement robust internal programs in order to maintain and demonstrate ongoing compliance with all applicable permit requirements.