Email from Torrence Refinery:

From: Lynch, Diane E <DIANE.LYNCH@pbfenergy.com> 
Sent: Friday, December 6, 2019 7:21 PM
To: Witosky, Matthew <Witosky.Matthew@epa.gov>
Cc: Reese, J Derek <j.derek.reese@exxonmobil.com>; christopher.w.armstrong@exxonmobil.com; Tse, Valerie B <VALERIE.TSE@pbfenergy.com>
Subject: RE: Follow-up on Question about Emission Inventory for a Facility

Hi Matthew,

On behalf of the Torrance Refining Company, below is our response to your information request:

 The Torrance Refinery is committed to meeting our compliance obligations with all applicable legal requirements, including the Asbestos NESHAP and SCAQMD Rule 1403.
 In general, our internal procedure requires us to sample in triplicate all suspected asbestos-containing material (ACM); if it was unsafe or impractical to sample a material, the material was presumed to be ACM (through remediation to disposal). 
 Once a material has been deemed ACM (through sampling or presumptive), a qualified asbestos abatement contractor remediates the material in accordance with R1403; the remediated ACM is then handed off to a waste contractor who prepares it for shipment to a TSDF. The ACM is weighed before transport off-site to a TSDF, and the weight is used in our emission inventory calculations.
 For the purposes of emission reporting, the total weight of remediated ACM is converted to tons, then multiplied by the SCAQMD default Emission Factors (0.006 lb/ton for PM, 0.0015 lb/ton for asbestos), and included in the Refinery's annual emission report submittal. The total weight of remediated ACM may also include any material that is presumed to contain Asbestos, as well as the weight of incidental items, such as asbestos-contaminated PPE, glove bags, bin liners, etc. 
 All asbestos remediation activities are documented to demonstrate compliance with SCAQMD Rule 1403 as well as the Asbestos NESHAP.

Please don't hesitate to call or email me if you have any further questions. Thank you,

Diane Lynch
Environmental Scientist
Torrance Refining Company
(310) 212-4743


Asbestos NESHAP Part 61 Subpart M

§61.145   Standard for demolition and renovation.
    (a) Applicability. To determine which requirements of paragraphs (a), (b), and (c) of this section apply to the owner or operator of a demolition or renovation activity and prior to the commencement of the demolition or renovation, thoroughly inspect the affected facility or part of the facility where the demolition or renovation operation will occur for the presence of asbestos, including Category I and Category II nonfriable ACM. The requirements of paragraphs (b) and (c) of this section apply to each owner or operator of a demolition or renovation activity, including the removal of RACM as follows:
    (1) In a facility being demolished, all the requirements of paragraphs (b) and (c) of this section apply, except as provided in paragraph (a)(3) of this section, if the combined amount of RACM is
    (i) At least 80 linear meters (260 linear feet) on pipes or at least 15 square meters (160 square feet) on other facility components, or
    (ii) At least 1 cubic meter (35 cubic feet) off facility components where the length or area could not be measured previously.
    (2) In a facility being demolished, only the notification requirements of paragraphs (b)(1), (2), (3)(i) and (iv), and (4)(i) through (vii) and (4)(ix) and (xvi) of this section apply, if the combined amount of RACM is
    (i) Less than 80 linear meters (260 linear feet) on pipes and less than 15 square meters (160 square feet) on other facility components, and
    (ii) Less than one cubic meter (35 cubic feet) off facility components where the length or area could not be measured previously or there is no asbestos.
    (3) If the facility is being demolished under an order of a State or local government agency, issued because the facility is structurally unsound and in danger of imminent collapse, only the requirements of paragraphs (b)(1), (b)(2), (b)(3)(iii), (b)(4) (except (b)(4)(viii)), (b)(5), and (c)(4) through (c)(9) of this section apply.
    (4) In a facility being renovated, including any individual nonscheduled renovation operation, all the requirements of paragraphs (b) and (c) of this section apply if the combined amount of RACM to be stripped, removed, dislodged, cut, drilled, or similarly disturbed is
    (i) At least 80 linear meters (260 linear feet) on pipes or at least 15 square meters (160 square feet) on other facility components, or
    (ii) At least 1 cubic meter (35 cubic feet) off facility components where the length or area could not be measured previously.
    (iii) To determine whether paragraph (a)(4) of this section applies to planned renovation operations involving individual nonscheduled operations, predict the combined additive amount of RACM to be removed or stripped during a calendar year of January 1 through December 31.
    (iv) To determine whether paragraph (a)(4) of this section applies to emergency renovation operations, estimate the combined amount of RACM to be removed or stripped as a result of the sudden, unexpected event that necessitated the renovation.
    (5) Owners or operators of demolition and renovation operations are exempt from the requirements of §§61.05(a), 61.07, and 61.09.
* * * * * 
(b) Notification requirements. Each owner or operator of a demolition or renovation activity to which this section applies shall:

* * * * * 
    (c) Procedures for asbestos emission control. Each owner or operator of a demolition or renovation activity to whom this paragraph applies, according to paragraph (a) of this section, shall comply with the following procedures:
    (1) Remove all RACM from a facility being demolished or renovated before any activity begins that would break up, dislodge, or similarly disturb the material or preclude access to the material for subsequent removal. RACM need not be removed before demolition if:
    (i) It is Category I nonfriable ACM that is not in poor condition and is not friable.
    (ii) It is on a facility component that is encased in concrete or other similarly hard material and is adequately wet whenever exposed during demolition; or
    (iii) It was not accessible for testing and was, therefore, not discovered until after demolition began and, as a result of the demolition, the material cannot be safely removed. If not removed for safety reasons, the exposed RACM and any asbestos-contaminated debris must be treated as asbestos-containing waste material and adequately wet at all times until disposed of.
    (iv) They are Category II nonfriable ACM and the probability is low that the materials will become crumbled, pulverized, or reduced to powder during demolition.
    (2) When a facility component that contains, is covered with, or is coated with RACM is being taken out of the facility as a unit or in sections:
    (i) Adequately wet all RACM exposed during cutting or disjoining operations; and
    (ii) Carefully lower each unit or section to the floor and to ground level, not dropping, throwing, sliding, or otherwise damaging or disturbing the RACM.
    (3) When RACM is stripped from a facility component while it remains in place in the facility, adequately wet the RACM during the stripping operation.
    (i) In renovation operations, wetting is not required if:
    (A) The owner or operator has obtained prior written approval from the Administrator based on a written application that wetting to comply with this paragraph would unavoidably damage equipment or present a safety hazard; and
    (B) The owner or operator uses of the following emission control methods:
    (1) A local exhaust ventilation and collection system designed and operated to capture the particulate asbestos material produced by the stripping and removal of the asbestos materials. The system must exhibit no visible emissions to the outside air or be designed and operated in accordance with the requirements in §61.152.
    (2) A glove-bag system designed and operated to contain the particulate asbestos material produced by the stripping of the asbestos materials.
    (3) Leak-tight wrapping to contain all RACM prior to dismantlement.
    (ii) In renovation operations where wetting would result in equipment damage or a safety hazard, and the methods allowed in paragraph (c)(3)(i) of this section cannot be used, another method may be used after obtaining written approval from the Administrator based upon a determination that it is equivalent to wetting in controlling emissions or to the methods allowed in paragraph (c)(3)(i) of this section.
    (iii) A copy of the Administrator's written approval shall be kept at the worksite and made available for inspection.
    (4) After a facility component covered with, coated with, or containing RACM has been taken out of the facility as a unit or in sections pursuant to paragraph (c)(2) of this section, it shall be stripped or contained in leak-tight wrapping, except as described in paragraph (c)(5) of this section. If stripped, either:
    (i) Adequately wet the RACM during stripping; or
    (ii) Use a local exhaust ventilation and collection system designed and operated to capture the particulate asbestos material produced by the stripping. The system must exhibit no visible emissions to the outside air or be designed and operated in accordance with the requirements in §61.152.
    (5) For large facility components such as reactor vessels, large tanks, and steam generators, but not beams (which must be handled in accordance with paragraphs (c)(2), (3), and (4) of this section), the RACM is not required to be stripped if the following requirements are met:
    (i) The component is removed, transported, stored, disposed of, or reused without disturbing or damaging the RACM.
    (ii) The component is encased in a leak-tight wrapping.
    (iii) The leak-tight wrapping is labeled according to §61.149(d)(1)(i), (ii), and (iii) during all loading and unloading operations and during storage.
    (6) For all RACM, including material that has been removed or stripped:
    (i) Adequately wet the material and ensure that it remains wet until collected and contained or treated in preparation for disposal in accordance with §61.150; and
    (ii) Carefully lower the material to the ground and floor, not dropping, throwing, sliding, or otherwise damaging or disturbing the material.
    (iii) Transport the material to the ground via leak-tight chutes or containers if it has been removed or stripped more than 50 feet above ground level and was not removed as units or in sections.
    (iv) RACM contained in leak-tight wrapping that has been removed in accordance with paragraphs (c)(4) and (c)(3)(i)(B)(3) of this section need not be wetted.
    (7) When the temperature at the point of wetting is below 0 °C (32 °F):
    (i) The owner or operator need not comply with paragraph (c)(2)(i) and the wetting provisions of paragraph (c)(3) of this section.
    (ii) The owner or operator shall remove facility components containing, coated with, or covered with RACM as units or in sections to the maximum extent possible.
    (iii) During periods when wetting operations are suspended due to freezing temperatures, the owner or operator must record the temperature in the area containing the facility components at the beginning, middle, and end of each workday and keep daily temperature records available for inspection by the Administrator during normal business hours at the demolition or renovation site. The owner or operator shall retain the temperature records for at least 2 years.
    (8) Effective 1 year after promulgation of this regulation, no RACM shall be stripped, removed, or otherwise handled or disturbed at a facility regulated by this section unless at least one on-site representative, such as a foreman or management-level person or other authorized representative, trained in the provisions of this regulation and the means of complying with them, is present. Every 2 years, the trained on-site individual shall receive refresher training in the provisions of this regulation. The required training shall include as a minimum: applicability; notifications; material identification; control procedures for removals including, at least, wetting, local exhaust ventilation, negative pressure enclosures, glove-bag procedures, and High Efficiency Particulate Air (HEPA) filters; waste disposal work practices; reporting and recordkeeping; and asbestos hazards and worker protection. Evidence that the required training has been completed shall be posted and made available for inspection by the Administrator at the demolition or renovation site.
    (9) For facilities described in paragraph (a)(3) of this section, adequately wet the portion of the facility that contains RACM during the wrecking operation.
    (10) If a facility is demolished by intentional burning, all RACM including Category I and Category II nonfriable ACM must be removed in accordance with the NESHAP before burning.

