Marine Loading Operations	Wastewater Systems	Flares, PRVs, etc	Storage Tanks	Equipment Leaks

Background Information
The U.S. EPA has set national ambient air quality standards (NAAQS) to protect public health. One of the NAAQS is the one-hour standard for ozone. The Bay Area exceeds the national ozone standard. The federal Clean Air Act Amendments require states and regions, such as the Bay Area, to prepare attainment plans for non-attainment pollutants. The Bay Area adopted the Ozone Attainment Plan in 1999 and revised it in 2001.

The Revised 2001 Ozone Plan updates, amends, and strengthens the 1999 Plan and establishes a strategy to attain the national one-hour ozone standard by 2006. The strategy includes control measures and identifies areas where further study is necessary. A major area of concern is the petroleum refineries. The control measures include Storage Tanks, Flare Monitoring, Equipment Leaks, and Process Vessel Depressurization. The areas where further study is required include Marine Loading, Wastewater Systems, Storage Tanks and Flare Blow down Systems.

Overview of Control Measures and Further Studies:

Marine Loading Operations (Further Study 11)

BAAQMD Regulation 8, Rules 44 and 46, currently require controls for loading of specified cargoes such as gasoline, gasoline blending stocks, aviation gas, JP-4 aviation fuel, and crude oil. This measure will identify current emissions and emissions controls, and compliance. The measure will determine if further emissions reductions are feasible by enhancing enforcement, requiring additional controls, and/or by expanding the rule to currently exempt cargoes. In addition, emissions from housekeeping operations such as ballasting, purging, and gas freeing will be examined.

Project Lead and District Contact: Fred Tanaka, Air Quality Engineer

Wastewater Systems (Further Study 9)
BAAQMD Regulation 8, Rule 8, District New Source Review, and EPA's National Emission Standard for Benzene Waste Operations (40 CFR Part 61, Subpart FF) currently require control of most components of refinery wastewater systems. This measure will determine whether there are significant potential emission reductions from control of any remaining uncontrolled components of the wastewater system, or through other measures.

Project Lead: Tim Dunn, Air Pollution Specialist, ARB

District Contact: Damien Breen, Air Quality Specialist II

Flares, PRVs, Blow down Systems, Process Vessel Depressurization (Control Measures 15 and 17, Further Study 8)

This measure will address emissions from pressure vessels and pressure relief devices that vent directly to atmosphere, uncontrolled Blow down system, and flares. This measure will determine emissions, potential to reduce emissions through enhanced enforcement, additional control requirements, and/or expansion of the scope of the current regulations. Staff will evaluate current industry practices and consider the feasibility of requirements to implement prevention measures to minimize or eliminate venting to the atmosphere. In addition, staff will evaluate the impact of incorporating an emission standard into this measure.

Project Lead and District Contact: Alex Ezersky, Air Quality Specialist II

Storage Tanks (Control Measure 12 and Further Study 10)
This measure will examine current emissions, and potential for further emission reductions from enhanced enforcement, additional control requirements, and/or expansion of the applicability of the current rules to tanks storing lower vapor pressure liquids not currently subject to District Regulation 8, Rule 5. Staff will explore the feasibility of improved controls and more stringent tank cleaning standards. This measure will attempt to determine whether retrofitting external floating roof tanks, controlling lower vapor pressure liquids, and more stringent tank cleaning standards would be technically feasible and cost effective.

Project Lead and District Contact: Julian Elliot, Senior Air Quality Engineer

Equipment Leaks (Control Measure 16)
This measure will explore requiring replacement valves meet BACT requirements or that they be leakless valves. The measure will add a requirement for EPA approval on Alternate Inspection and Emission Reduction Plans. The measure may also add incentives to encourage the early replacement of valves with low-emission or leakless valves.

Project Lead and District Contact: Victor Douglas, Air Quality Specialist II

Monthly Board Briefings for 2002