Alternate programs to control leaks of volatile organic compounds (VOC) from petroleum refining equipment

Over 100 refineries are presently subject to state or local regulations covering fugitive VOC emissions. Most state and local regulations provide refiners the opportunity to request and use alternate monitoring methods, schedules, and control techniques provided the proposed alternatives achieve equivalent or greater emission reduction. The impetus of this paper is to present information on equivalent methods that have been demonstrated since promulgation of state and local regulations to control refinery equipment leaks. EPA has published valuable information on alternative control techniques and the emission reductions they achieve. The refining industry is now joined by the gas processing, synthetic organic chemical manufacturing, and polymers manufacturing industries in fugitive control VIA source performance standards (NSPS) or recently released CTG'S. This paper recommends that both control agencies and facility operators utilize the information contained in these documents and the information contained in facility records to modify current programs to achieve greater emission reductions and lower annualized costs.