Alon USA, LP Clean Air Act Settlement

• Overview of Company
• Violations
• Injunctive Relief
• Pollutant Reductions
• Health and Environmental Effects
• Civil Penalty
• Supplemental Environmental Project
• Petroleum Refinery National Priority Case Results
• Comment Period
• Contact

Overview of Company

WASHINGTON (April 19, 2017) -- Alon USA, LP is a wholly-owned subsidiary of Alon USA Energy, is an independent refiner and marketer of petroleum products operating primarily in the southwest and western United States. The Alon refinery is located in Big Spring TX, and has a refining capacity of 73,000 barrels per day (bbl/day), less than 1 percent of total U.S. domestic refining capacity.

Violations

The complaint alleges violations of the Clean Air Act’s Leak Detection and Repair (“LDAR”) requirements, 40 C.F.R. Part 60, Subparts VV and GGG (for leaks of volatile organic compounds) and Part 63, Subpart H (for leaks of hazardous air emissions); and the National Emission Standards for Hazardous Air Pollutants (NESHAP) for benzene wastes, 40 C.F.R. Part 61, Subpart FF. 

Injunctive Relief

The consent decree requires the following actions at the Big Spring refinery, at an estimated cost of a little more than $100 million:

New Source Review/Prevention of Significant Deterioration (NSR/PSD) -- Fluidized catalytic cracking unit (FCCU) and refinery Heaters and Boilers

• FCCU nitrogen oxides (“NO_x”) limits of not more than 20 parts per million (ppm) on a 365-day rolling average basis and 40 ppm on a 7-day rolling average basis.
• FCCU sulfur dioxide (“SO₂”) limits of 25 ppm on a 365-day rolling average basis and 50 ppm on a 7-day rolling average basis.
• Installation of NO_x and SO₂ continuous emission monitors.
• Particulate matter (“PM”) emissions limit of 1.0 pound per 1,000 pounds of coke burned at the refinery's FCCU.
• Carbon monoxide (“CO”) emission limit of 500 ppm on a 1-hour average basis at the refinery's FCCU.
• Installation of controls to achieve an emission rate of 0.040 lb NO_x/mmBTU (pound per million British thermal units of heat input) for heaters and boilers greater than 40 MMBtu/hr.

New Source Performance Standards (NSPS) and Flaring

• Compliance with SO₂ standards of Subparts A and Ja for all combustion devices burning refinery fuel gas, including flares.
• Compliance with SO₂ standards of Subparts A and J at the sulfur recovery plant, including the sulfur pit.

Benzene Waste NESHAP

• Total annual benzene (TAB) less than 10 Mg/yr.
• Compliance with the EPA-preferred "6 BQ" benzene compliance option if the TAB exceed 10 Mg/yr.
• Management of change procedures to ensure that new benzene streams are included in the TAB calculation.
• Conduct laboratory audits.
• Training for those who sample benzene.

Leak Detection and Repair (LDAR) Program

• Refinery-wide compliance with LDAR requirements to reduce volatile organic compounds (“VOCs”) and hazardous air emissions.
• Training, including refresher courses, for refinery personnel with LDAR responsibility.
• Periodic LDAR compliance audits.
• Installation of "low-leaking" valve or valve packing technology in all new applications.

Pollutant Reductions

Once all emissions controls have been installed and implemented, this settlement is estimated to result in the following emissions reductions:

• NO_x emissions by 477 tons per year (tpy)
• SO₂ emissions by 2,455 tpy

The settlement will also result in additional reductions of PM, CO, benzene and other pollutants.

Health and Environmental Benefits

• Nitrogen Oxides - Nitrogen oxides can cause ground-level ozone, acid rain, particulate matter, global warming, water quality deterioration, and visual impairment. Nitrogen oxides play a major role, with volatile organic chemicals, in the atmospheric reactions that produce ozone. Children, people with lung diseases such as asthma, and people who work or exercise outside are susceptible to adverse effects such as damage to lung tissue and reduction in lung function.
• Sulfur Dioxide - High concentrations of SO2 affect breathing and may aggravate existing respiratory and cardiovascular disease. Sensitive populations include asthmatics, individuals with bronchitis or emphysema, children and the elderly. Sulfur dioxide is also a primary contributor to acid deposition, or acid rain.
• Volatile Organic Compounds - VOCs, along with NOx, play a major role in the atmospheric reactions that produce ozone, which is the primary constituent of smog. People with lung disease, children, older adults, and people who are active can be affected when ozone levels are unhealthy. Ground-level ozone exposure is linked to a variety of short-term health problems, including lung irritation and difficulty breathing, as well as long-term problems, such as permanent lung damage from repeated exposure, aggravated asthma, reduced lung capacity, and increased susceptibility to respiratory illnesses such as pneumonia and bronchitis.
• Benzene - Acute (short-term) inhalation exposure of humans to benzene may cause drowsiness, dizziness, headaches, as well as eye, skin, and respiratory tract irritation, and, at high levels, unconsciousness. Chronic (long-term) inhalation exposure has caused various disorders in the blood, including reduced numbers of red blood cells and anemia in occupational settings. Reproductive effects have been reported for women exposed by inhalation to high levels, and adverse effects on the developing fetus have been observed in animal tests. Increased incidences of leukemia have been observed in humans occupationally exposed to benzene. EPA has classified benzene as a Group A human carcinogen.

Civil Penalty

Alon will pay a $456,250 civil penalty.

Supplemental Environmental Project

Alon will implement a Supplemental Environmental Project (“SEP”) to further reduce NOx emissions from refinery heaters.  The SEP is estimated to result in additional NOx reductions of up to 64 tons per year.  Alon will expend $1.5 million on the SEP.

Petroleum Refinery National Initiative Case Results

Through multi-issue, multi-facility settlements, this national priority addresses the most significant Clean Air Act compliance concerns affecting the petroleum refining industry.  See EPA's National Petroleum Refining Initiative for more information.

Comment Period

The proposed settlement, lodged in the U.S. District Court for the District of Kansas, is subject to a 30-day public comment period and final court approval. Information on submitting comment is available at the Department of Justice.

For more information, contact:

Patrick W. Foley
Senior Environmental Engineer
U.S. Environmental Protection Agency (2242A)
1200 Pennsylvania Ave., N.W.
Washington, DC 20460-0001
(202) 564-7978
[email protected]