Keywords: petroleum refinery, FCC, NSPS, MACT, raw-material quality, pollution control, multi-pollutant emission standard, percentile emission standard, spent catalyst tax
The MACT for petroleum refinery FCCs is a fraud!
This paper is a continuation of the author's research on the MACT regulation for abating pollution from Petroleum Refinery FCCs in the US. This paper highlights the flaws in the recently promulgated MACT for NSPS and non-NSPS FCC units. It details the inadequacies and the potential for perversity in the New Source Performance Standards (NSPS) that are an integral part of the FCC MACT. It elaborates upon the potential for multi-media risk-exacerbations under the NSPS resulting from changes in feedstock quality, 'unit conversion', advances in cracking technology (that favour inferior crudes and feedstock), lack of NSPS standards for NOx emissions, inter-unit transfer of contaminants/pollutants within a refinery, and the blind eye turned by RCRA to the disposal of spent FCC catalyst waste to landfills. The paper also questions EPA's motives as regards sub-categorisation of FCCs and SBREFA concessions. This paper proposes four standards that remedy these deficiencies. The first standard controls heavy metals, PM, and SOx (along with SO2), while the second proposes an integrated percentile control standard for CO (VOC) and NOx emissions. The paper also proposes a percentile standard for opacity and a spent catalyst tax to control environmental risk posed by disposal of spent FCC catalyst waste to landfills. It explains the calibration of the proposed standards using a novel strategy to bridge the regulatory gap between NSPS, MACT and Residual Risk standards and demonstrates how the calibrated standards apply to FCCs processing feedstock of different qualities. The paper concludes by urging the US EPA to rescind the NSPS and the MACT for FCCs and re-promulgate an integrated set of standards for criteria and toxic pollutants along the lines proposed in this paper.