2018 Presentations - 4C Conference



2018 Breakout Presentations

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On April 3, 2018, hundreds of environmental professionals gathered to attend
breakout presentation sessions covering cover tons of health, safety, and environmental topics.

The presentations given at the 2018 conference have been compiled and made available for download. Check the list of presentations below to download the presentations you were most interested in.


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Click the buttons below to download presentations by track, or download the entire collection of 2018 breakout presentations.

“4G” Combustion Technology for Flares

Chris Ferguson - Director, Callidus Technologies Systems, Honeywell

Description

As flare regulations tighten there has been increased emphasis on monitoring and controlling flaring. While there have been advances in steam control systems and plume monitoring systems there has not been a fundamental change in flare combustion technology for decades. This presentation introduces “4G” combustion technology which changes the paradigm of currently available “3G” flare combustion technology, and sets the bar for the next generation of flare design.

A Case Study of Implementing a Data Acquisition and Handling System for Compliance with the Refinery Sector Rule

Eric Swisher & Brian Fowler - Technical Manager & Director of Engineering & Marketing, ALL4 Inc. & ESC

Description

Implementation of the increased monitoring and compliance assurance requirements of 40 CFR Part 63 Subpart CC (National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries) or “Refinery MACT” requires both the installation of continuous parameter monitoring system (CPMS) hardware (e.g., flow monitors, mass spectrometer, gas chromatograph, etc.) and the software (i.e., the means for managing the data collected by the hardware for purposes of demonstrating compliance). Regardless of the chosen data management solution, various decisions and considerations by the refiner are required to implement the measurement, calculation, and reporting provisions required for the new compliance parameters. This presentation will focus on the lessons learned at multiple refineries from the implementation of a CPMS data management solution that relies on a data acquisition handling system (DAHS) to satisfy the flare requirements of the Refinery MACT effective on or before January 30, 2019. The “lessons learned” are generally applicable to refineries that must comply with upcoming Refinery MACT requirements for flares. However, the lessons learned from the flare CPMS data management solution will also provide refiners insight that can be applied to compliance data management projects considered to replace existing compliance data management systems such as continuous emission monitoring systems (CEMS) for heaters, boilers, and process sources. Specifically, the presentation will explore various aspects of a CPMS data management system, including: 1. Integration challenges, 2. Hardware (instrument/analyzer) communications, 3. Data validation, 4. Quality assurance/quality control (QA/QC) 5. Data substitution, 6. Regulatory decisions, 7. Inclusion of existing applicable requirements, 8. Routine versus event-based data management, 9. Alarm configurations, and 10. Reporting requirements.

A Modern Approach to Dispersion Modeling

Robert Opiela - CEO, Naviknow

Description

Dispersion modeling has been performed in the same way with the same tools since the 1990's. NaviKnow has been developing a modern approach with today's technology to shorten weeks of analysis to just days. See what NaviKnow is doing and where we are going.

A Primer on PFAS, a Contaminant Emerged

Stephen Zemba - Project Director, Sanborn, Head & Associates, Inc.

Description

This presentation will provide an overview of the knowledge and concerns that have recently emerged concerning Poly- and Perfluorinated Alkyl Substances (PFAS), a class of chemicals widely used as a component of firefighting foams, in the manufacture of non-stick and waterproof coatings, and numerous other applications. The presentation will discuss the sources of PFAS, their behavior and persistence in the environment, and potential toxicity on human health and the environment.

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A Screening-Level Assessment Method for Tank Emissions at a Petrochemical Facility

Muqeeth Syed & Colin Welburn - , HollyFrontier & Welburn Consulting

Description

In January 2017, the Ontario Ministry of the Environment and Climate Change (MOECC) updated its guidelines for screening out insignificant sources and contaminants released in negligible amounts from regulatory dispersion modelling reports. The latest MOECC guidance requires a more detailed screening process for contaminants that are emitted in negligible amounts and for sources that emit contaminants in negligible amounts. One of the insignificant sources common to petrochemical facilities is the low-temperature handling of compounds with a vapour pressure less than 1 kilopascal (kPa). The guidelines now require a description of the contaminants being handled, the volume and filling rate of the storage tank, a calculation to demonstrate the vapour pressure for each process or operation, the location of each source on the property, and distance from source to property line. Facilities with multiple tanks and compounds on site could find this new requirement onerous, representing as it does a significant increase in their emissions assessments and reporting requirements. To meet the new guidelines, the study facility, which operates 156 tanks storing more than 100 distinct products, opted to develop an Excel-based algorithm for performing screening-level calculations. Its goal was to identify any of the facility’s filling operations that could potentially exceed Ontario's Air Contaminant Benchmarks and would thus require further analysis. This paper describes an economical, conservative, replicable, and systematically documented method for the screening of air quality impacts from multiple tank filling operations. We present the structure of the algorithm, the results of the screening process, and the challenges that were overcome to complete the project.

A Wastewater Solution for an Air Pollution Problem

Todd Lusk - Senior Engineer, SLR Consulting

Description

The regulatory requirements for managing benzene- and VOC-laden streams from wastewater treatment units require refineries to implement vapor control technologies that are often expensive to implement and/or operate. This session presents another option – the VOC BioTreatTM process, an alternative control technology that utilizes unit operations already in place at most wastewater treatment facilities and can substantially reduce the costs associated with BWON compliance. The presentation will provide information on the necessary steps to evaluate, model, test, and implement the VOC BioTreatTM process, and will describe case studies to support the economic and environmental benefits.

Aerial Infrared Thermography

Gary Strahan - CEO, Infrared Cameras Inc.

Description

The future of using Infrared cameras for Aerial Thermogaphy using Unmanned Aerial Vehicles. ICI has two patents around this process and has invested years in developing a true end to end solution.

Automating Manual Data QAQC

Robert Williams - Senior Environmental Specialist, TEAM

Description

Description coming soon.

BACT – Creating Latitude within Regulatory Boundaries

Mellitanya Stephenson - HSE Representative II (Air Quality) , Anadarko Petroleum Corporation

Description

Key points covered during presentation: 1) How BACT Tier 1, 2, and 3 fit into permit process and potential constraints associated with BACT; 2) Value of flexibility in BACT for operations; 3) Helpful strategies to establish value added BACT Tier 1; and 4) Potential financial benefits and reduced compliance obligations/constraints of establishing effective BACT.

Benzene Fenceline Monitoring Emission Source Investigation: Using OP-FTIR to Identify Source(s) of Fugitive Emissions

Jessica Little & David Berkowitz - Senior Environmental Engineer & Director of Business Development, Pasadena Refining & Enthalpy Analytical/Montrose Environmental

Description

Is your BFM Program being impacted by near field, mobile sources, or something you have yet to identify? This presentation will highlight the process of setting up an OP FTIR program at a refinery along the Houston ship channel in an effort to better understand off-site/near field contributions to BFM results. We’ll focus on strategy for program set up, explore lessons learned, data analysis, and discuss our conclusions.

Benzene Fenceline Monitoring; Regulation Updates & Lessons Learned for Ongoing Compliance

Jesse Miller - General Manager, Camsco

Description

The presentation will review the latest updates to the benzene fenceline monitoring refinery sector rule, as stated in the Approved Test Method (ATM-122), as well as practical lessons learned for refineries and consultants engaged in compliance.

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Benzene Fenceline Monitoring: Laboratory Insights for a Successful Program

Shannon Hulbert - Project Manager, Enthalpy Analytical, LLC

Description

With thousands of Benzene Fenceline Monitoring samples arriving at Enthalpy Analytical each year for analysis, there are bound to be notable errors and issues which may impact data quality and the overall success of a Fenceline Monitoring Program. This presentation highlights common errors encountered with Method 325B passive samplers and provides suggestions to streamline technical and field sampling aspects to alleviate reporting concerns.

Case Study of Heater/Boiler Tune-Ups

John Bacon - Market Director, TRC Solutions

Description

While most facilities perceive 40 CFR 63 Subpart DDDDD (Boiler and Heater MACT, or MACT DDDDD) as costly regulation, four years of data compiled from the annually and biennially recurring tune-ups indicates the opposite is true. In fact, regular boiler and process heater tuning for natural gas fired sources can lead to considerable cost savings related to fuel use and a simple payback on the tune-ups services within months. The purpose of this presentation is intended to enlighten the audience on the benefits of boiler and process heater tuning, using data compiled from tune-ups performed on nearly 600 combustion sources, and conducted in accordance with the Boiler MACT work practice standard. Also, how a facility can further benefit from the regular performance of these services beyond the regulatory framework.

CEM Improvements For Refinery and Chemical Plants

Tim Kuiken - National Sales Manager, M&C Tech Group

Description

Continuous Emissions Monitoring Systems (CEMS) are constantly in need of attention, maintenance and improvements. In many cases, the original CEMS supplied to a facility or fleet are mediocre in design and performance, or simply might not be a good “fit” for the application or process conditions. Tim Kuiken has helped hundreds of his clients design and improve their CEMS in a wide variety of industries and applications. This presentation will focus on the many considerations you can make to ensure that you are getting >98% uptime and data availability, as well as give you some important tools for troubleshooting any issues you might me having at your facility. Topics include: • Sample Probes and Extraction • Sample Transport Bundles / Umbilicals • Sample Gas Conditioning and Handling • Scrubbers, Filters and Converters • Overall Analyzer Protection

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CEMS Lessons Learned

Ty Smith - President, Cemtek Group Inc.

Description

Coming soon.

ClearSign Combustion’s DuplexTM Technology Achieves 5ppm cNOx in a California Refinery

Venkatesh Iyer - Senior Research Engineer, ClearSign Combustion

Description

ClearSign Combustion has developed, patented and commercialized a revolutionary low emission combustion technology called DuplexTM. A Duplex system can achieve net emissions lower than a SCR system for a variety of different types of combustion applications including boilers, heaters and flares.

Common CEMS RATA Failures and Risks

Paula Metz - Technical Services Assistant Manager, Alliance Source Testing

Description

This presentation will focus on thing that may cause a CEMS RATA to fail and what can be done on the facility side and by the stack tester to reduce the potential for failures.

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Conducting a Threat Assessment of Your Facility’s Airspace

Uzkar Ibrahim - VP of Business Development, Sage EHS International, 4C Marketplace

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Contractor Management

Ric Hartung - General Manager, Process & Safety Solutions LLC

Description

Currently there are a large number of facilities covered by Process Safety Management (PSM) that either use a third party or manage their own contractor safety programs. Numerous compliance audits and National Emphasis Program (NEP) inspections has revealed a serious gap. While these third parties may do an adequate to good job in obtaining contractor information, evaluating statistics, and managing documentation, most fail to meet the requirement outlined in the PSM Regulation regarding contractor evaluations and verification. This gap leaves the host employer vulnerable to significant OSHA & EPA violations and fines. At issue, is the requirements outlined in several sections in the PSM regulation starting in sub-section (f)(4) stating that “the employer shall develop and implement safe work practices to provide for the control of hazards during operations such as lockout-tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel. These safe work practices shall apply to employees and contractor employees” (emphasis added). This indicates that the host employer’s safe work practices apply to not only its own employees, but also to the contractors that perform work in the covered process. The host employer responsibilities are further outlined in sub-section (h)(2)(v) such that “The employer shall periodically evaluate the performance of contract employers in fulfilling their obligations as specified in paragraph (h)(3) of this section. For the host to fulfill PSM obligations regarding contractors, it must verify that the contractor has received safe work practice training, including site-specific requirements, such as but not limited to, the potential hazards that may be present in the facility. The contractor may use their own safe work practices, but this would need to be agreed upon beforehand and the host “must” evaluate each safe work practice to ensure that they are equivalent or more stringent, than their own.

Design & Operation Guidelines for Low Heater Emissions

Erwin Platvoet - Founding Partner, XRG Technologies, LLC

Description

The challenge to minimize emissions from a fired heater starts with good burner design, backed up by a properly executed burner test. But it doesn’t end there; the burner test only demonstrates the lowest theoretical emissions for a single burner under controlled conditions. In the field, however, several factors conspire against the designers and operators, occasionally resulting in emissions that are significantly higher than anticipated. This presentation will demonstrate how heater design, operation and maintenance can impact the actual emissions of pollutants and offers some practical guidelines for both designers and operators.

Development of a Wall-Sticking Drone for Non-Destructive Ultrasonic and Corrosion Testing

Rami Mattar - NPD Director , AMERAPEX CORPORATION

Description

Refinery structures require frequent inspection, maintenance to maintain structural health, and safe work practices; however, accessing structures is getting harder and harder due to their enormous height and size. In order to deal with this problem, many researchers have developed several robots for wall crawling, yet there is much progress beyond this that is needed. One of the primary reasons that existing wall crawling robots haven’t been used more widely in the field are risks associated with accidental fall of the equipment due to operational failure from the harsh environment like strong winds and the unpredictability of rough surface conditions. Therefore, we tried to develop a wall-sticking aerial robot platform that can approach any area on the structure by flying to and sticking on the target. The robot is equipped with electro-magnetic hold/mount elements to “stick” the sensor probe on the ferro-magnetic surface of the structure. This paper covers installing the wall-sticking mechanism on the aerial robot.

Ditching Your Major Source MACT Requirements

Nicholas Petrich - Chemical Engineer, Barr Engineering

Description

The U.S. EPA issued a new guidance memorandum that repealed the “once in, always in” (OIAI) policy, allowing reclassification of a major source of hazardous air pollutants (HAPs) to an area source. The new guidance concluded that the OIAI policy was contrary to Section 112 of the Clean Air Act (CAA) and that the U.S. EPA did not have the authority to restrict a source from becoming an area source after the first compliance date of the applicable MACT standards. Therefore, a major source that obtains federally enforceable limits on its HAP potential-to-emit (PTE) below the major source thresholds can become an area source. Industrial facilities have the opportunity to consider whether they could operate as area sources of HAPs. This presentation will provide guidance on how and why a facility can become an area source, including the benefits and challenges. A regulatory overview will be provided including the common major source standards that would no longer apply, the potentially applicable area source requirements, and why some requirements won’t go away even though the specific MACT standards may no longer apply. A technical review will also include the critical factors for calculating site-specific HAP emissions from key sources such as process fugitive equipment leaks, wastewater treatment, process combustion, and storage tanks. Lastly, key aspects of implementing federally enforceable emission limits and transition from major source standards will be discussed. Attendees will leave the presentation with an understanding of the advantages of becoming an area source and whether they should sharpen the pencil on their HAP emission calculations.

DOT Control Room Management Risk-Based Alarm Management

Trish Thomason - , Integrity Solutions

Description

Coming Soon.

Downstream Confirmation of Benzene Loading

Bruce Douglas - Principal Consultant, Trinity Consultants

Description

Downstream flow rates and concentrations can reflect the characteristics of the total wastewater throughput managed at the facility, where all sewered wastewaters have come together into one stream. Experience indicates that downstream characterization can provide the most accurate values for facility wastewaters. However, the BWON citations emphasize the need to characterize wastes upstream, at the points of generation (POGs), because the rule-writers were concerned that benzene could volatilize from the waste as it flowed through the waste management system. Thus, the TAB quantification must be based on the upstream POG characterizations. It is valuable to assess the accuracy of POG results by comparing the downstream values with the sum of upstream POG values in the sewered streams. Although benzene is dynamic in a refinery sewer system—potentially volatilizing or transferring between the oil and water phases—it is reasonable to expect downstream loadings to be similar to the values derived from summing POG numbers. Agreement in the upstream-downstream evaluation lends confidence to the TAB quantification, the 6BQ or 2-Mg quantification (if needed), and the overall claim of the facility that the BWON wastes were properly identified.

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Efficacy of Moving Bed Biological Reactor (MBBR) for Water Reuse and Distributed Treatment Systems: Industrial and Municipal Applications

Paul Gallego - Process Engineer, Headworks International

Description

Water is a precious resource to sustain both our societal and industrial needs. However, availability of usable water is severely depleting globally. Reuse of treated wastewater has been gaining ground globally to preserve water resources. MBBR is an attached growth treatment process where the biomass is attached to the surface of media as fixed films while the media itself are in continuous motion in the bioreactor by aeration. It offers multiple advantages over suspended growth processes as described in the following. MBBR is a very compact system that occupies a limited space. It is a modular system that can be designed keeping future expansions in mind. An existing treatment system can be easily retrofitted as MBBR with minimal civil works required to accommodate larger load and flow conditions. It is very stable and adjusts automatically to varying load and flow conditions while withstanding shock and toxic loads. During low periods, MBBR can be kept running without much difficulty. This system also does not require any recycling of the sludge and hence no need to maintain MLSS. The chemical consumption is much less compared to a similar advanced technology like MBR. All key internal components for MBBR are very reliable and last a long time with no need for maintenance for several years. It does not require continuous monitoring and highly skilled operators making it suitable for remote operation as needed. These attributes make MBBR very suitable for localized applications in distributed treatment mode. This paper will present the typical treatment trains for: industrial reuse of flowback and produced water in hydrofracturing applications; indirect reuse for landscaping and agricultural applications; and direct, indirect and de-facto potable water reuse. Principles of each of the above three applications will be presented with the help of case studies.

Eliminating H2S & SO2 Emissions at SRU, Coker and Sulfur Pits of Refineries

Jim Woodard - National Sales Account Executive, Vapor Point, LLC

Description

Vapor Point applies high efficiency liquid scrubbing systems to eliminate Hydrogen Sulfide (H2S), Sulphur Dioxide (SO2) other Sulfur Species as well as other Hazardous Air Pollutants (HAPs) and Volitale Organic Compounds (VOCs). Specially designed temporary vessels for liquid and vapor phase product management have also been developed and are key elements in some applications. These control system concepts and resulting proven processes were developed with input from refining personnel who needed alternative technologies that would offer operational flexibility eliminating the various sulfur contaminates. The vapor phase emission control systems and specially designed process vessels have met the needs of the refining industry with numerous field implementations.

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Emerging Trends in Owner Compliance

George Perrett - Vice President of Market Development, Industrial Safety Training Council (ISTC)

Description

Safety Councils work for petrochemical plants and their contractors to facilitate innovative ways to reduce incident rates resulting in a 95% reduction in recordable accidents. 2018 marked an evolution in deliverables, slowly migrating away from training to develop new workforce compliance and risk management processes. Working within the industry we developed several internationally recognized Best Practices for contractor compliance, risk management, labor cost management. The petrochemical industry consortium, ISTC, made up of downstream and midstream operators, collaborated with contractors bringing years of quantitative data to identify problems that are developing or have occurred in the workplace and formulating solutions, cost structures and most importantly compliance management to combat future issues. The presentation, outlines several of the best practices in contractor compliance and provides insight toward the direction of future efforts associated with hiring, compliance, auditing, accident response and even Department of Homeland Security, CFATS inspections. Specific industry incidents and actual cases are highlighted to demonstrate the reasoning behind the emerging trends and seeks input from audience members on the potential impact to their business operations. Recently adopted across a variety of global operational excellence teams, Emerging Trends in Workforce Compliance is designed to serve as a barometer of future downstream, and midstream compliance requirements.

Emissions Reduction Warehousing Analysis: Positioning Your Plant for Growth

Blake Soyars - Department Manager, Air Quality & Noise Services, Burns & McDonnell

Description

Competitive site selection evaluations are standard for strategic projects. An emission reduction warehousing analysis provides competitive advantages for existing major source facilities wanting to host the next big project. A warehousing analysis identifies emissions reduction projects across the facility, estimates total installed cost and timeline for each project, and quantifies available emissions reductions. Emission reductions projects are ranked to determine the lowest cost options for avoiding or minimizing air permitting delays and costs. Without a warehousing analysis, site selection committees may apply worst-case assumptions for federal Prevention of Significant Deterioration and Nonattainment New Source Review air permits, including longer permit timelines and higher costs for emission offsets and emission control technologies. This presentation will start with an overview of federal nonattainment designation actions under the current EPA administration. Then we will outline the steps for conducting a warehousing analysis and the competitive advantages for facilities, especially those located in designated nonattainment areas.

Emissions Reduction Warehousing Analysis: Positioning Your Plant for Growth

Blake Soyers - Department Manager, Air Quality & Noise Services, Burns & McDonnell

Description

Competitive site selection evaluations are standard for strategic projects. An emission reduction warehousing analysis provides competitive advantages for existing major source facilities wanting to host the next big project. A warehousing analysis identifies emissions reduction projects across the facility, estimates total installed cost and timeline for each project, and quantifies available emissions reductions. Emission reductions projects are ranked to determine the lowest cost options for avoiding or minimizing air permitting delays and costs. Without a warehousing analysis, site selection committees may apply worst-case assumptions for federal Prevention of Significant Deterioration and Nonattainment New Source Review air permits, including longer permit timelines and higher costs for emission offsets and emission control technologies. This presentation will start with an overview of federal nonattainment designation actions under the current EPA administration. Then we will outline the steps for conducting a warehousing analysis and the competitive advantages for facilities, especially those located in designated nonattainment areas.

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Enabling Distributed Environmental Compliance Management

Brent Allred - Program Manager, Northrop Grumman Technology Services

Description

Assuring compliance with new and evolving local, state, federal, and even foreign environmental regulations across dispersed enterprises such as the military and many commercial entities is a daunting endeavor for environmental managers at all tiers of the enterprise. It is challenging to maintain compliance risk at an acceptable level while faced with budgetary and manpower constraints in a climate of ever increasing and constantly evolving regulations. To keep pace, many Air Force and Army installations have implemented strategies and tools aimed at distributing the compliance and associated data management workload in order to drive efficiencies in meeting compliance demonstration, recordkeeping and regulatory reporting requirements. This strategy has been largely enabled by the successful implementation and institutionalization of modern information management solutions such as the Air Force’s Air Program Information Management System (APIMS) and the commercially-hosted equivalent, Environmental Program Information Management System (EPIMS). Proper implementation of these systems has been proven to reduce the manpower required to demonstrate compliance and satisfy reporting requirements, while reducing compliance risk. APIMS is a web-based information management system owned by the Air Force. It is hosted at the Defense Information Systems Agency (DISA) and is available to Air Force users worldwide. EPIMS shares the exact same software baseline, is commercially hosted on Amazon Web Services (AWS), and is used by other federal and commercial users under a software as a service (SaaS) subscription model. These proven solutions are being rapidly adopted, with a current user base of over 5,000 regular users and over 150,000 transient users at over 200 installations worldwide. The system was designed to provide all tiers of the enterprise, from the shop level to headquarters level, the tools required to effectively manage compliance risk and to satisfy recordkeeping and reporting requirements. Key compliance activities where APIMS/EPIMS support the distribution of compliance management and drive automation include: generation of air emissions inventories; multi-media compliance assessment management; refrigerant compliance management; RICE NESHAP compliance, storage tank compliance management, and Clean Air Act section 118(d) vehicle inspection and maintenance compliance. APIMS is a proven compliance automation solution that has saved its users countless man-hours, when compared to historical compliance methods. This presentation will highlight specific real world examples of how automation and the distribution of compliance management strategies has helped system users reduce compliance risk and reduce the manpower required to effectively manage environmental compliance in today’s regulatory climate.

Enhanced LDAR Training: An Unconventional Approach to Training LDAR Technicians

Todd Morrison - CEO, Insight Environmental

Environmental Enforcement Developments in the Trump Administration

Matt Thurlow - Partner, Baker & Hostetler LLP

Description

This presentation will provide an overview of recent environmental enforcement developments in the Trump administration. The presentation will review EPA's new National Compliance Initiatives, regulatory changes under the Clean Air Act, and other pending changes under Acting Administrator Wheeler's EPA. The presentation also will focus on technological developments and how they are changing compliance and enforcement.

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Environmental Enforcement Update

Carrick Brooke-Davidson - Counsel, Vinson & Elkins

Description

Under the Trump administration, EPA and DOJ have issued several new policies and directives which affect environmental enforcement. This presentation will discuss these new developments, including the, EPA’s new policy on national compliance initiatives, EPA's new policy on referrals to DOJ, DOJ's statement on environmental enforcement policy and principals, and the DOJ policy on use of agency guidance in enforcement. The new DOJ policies are especially significant as they apply to all DOJ enforcement litigation, not just EPA.

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EPA NSR Reforms: How to Capitalize Now and Later

Kristin Gordon - Houston Office Director, ALL4 Inc.

Description

This presentation will provide an overview of the most challenging issues posed by the New Source Review (NSR) construction permitting program for expansion projects. The key aspects of NSR will be summarized along with how they fit in with real world projects (and what makes them most challenging for real world projects). The discussion will then lead to the common sense regulatory and policy reforms that are needed to address these challenges. Finally, we will discuss the current status and anticipated implementation of upcoming reforms to the NSR program by Congress and U.S. EPA. This presentation could serve as an overview for those following the regulatory reform process and also as a primer to those that are attending the in depth NSR workshops.

EPA’s Amendments to the RMP Rule – What Are Company Compliance Obligations Under the New Rules and the Old Ones?

Dan Gruzca - Counsel, Hunton, Andrews, Kurth LLP

Description

On January 13, 2017, EPA finalized numerous changes to the existing RMP regulations on accident prevention program elements, emergency preparedness requirements and provisions related to sharing information with the public and local emergency planners/responders. The RMP Amendments were to take effect as of March 14, 2017 but were delayed by EPA until February 19, 2019. However, The RMP Amendments became immediately effective on September 21, 2018 when the delay rule was vacated by the U.S. Court of Appeals for the D.C. Circuit. On December 3, 2018, EPA published a final rule that will incorporate the RMP Amendments into the Code of Federal Regulations. This now raises a series of issues related to compliance obligations for facilities under several provisions for the 2017 RMP Amendments. Interpreting the new language may also be informed by the fact that on May 30, 2018, EPA proposed to revise the provisions of the 2017 RMP Amendments, proposing to rescind amendments relating to safer technology and alternatives analyses, third-party audits, incident investigations, information availability and several other minor regulatory changes This presentation will sort out compliance obligations for facilities under the new rules and the old ones.

Evaluation of Innovative Methane Detection Technologies

Tim Taylor - Environmental Protection Specialist III / IR Camera Work Lead, Colorado Air Pollution Control Division

Description

The Evaluation of Innovative Methane Detection Technologies summarizes the technical-regulatory guidance document of the same title published by the Interstate Technology & Regulatory Council (ITRC) in September 2018 (https://methane-1.itrcweb.org/). Over the last number of years, several state, national and international governments have passed or are considering methane emission regulations related to oil and natural gas production and distribution. Historically, gas detection technologies used to regulate fugitive emissions in the oil and gas sector had to comply with EPA’s Method 21 requirements. With the advent of optical gas imaging (OGI) technologies, EPA established an alternative work practice (AWP) to allow inclusion of manually operated infrared cameras for leak detection. EPA's amendments to the New Source Performance Standards (NSPS) on methane and volatile organic compounds (VOC) for oil and gas sources include Method 21 and OGI technologies as approved compliance methods, as well as the option for approving new leak detection technologies. Colorado and Pennsylvania allow similar options in their regulation of methane and VOC from oil and gas operations. In response, innovators are currently developing new technologies that go beyond Method 21 and OGI. However, there is no standard methodology or protocol to evaluate performance of new technologies like these as compared to Method 21 or OGI. The ITRC guidance document seeks to provide a framework for evaluating methane and VOC detection technologies for use in meeting existing and forthcoming leak regulations, assisting with inventory monitoring and reporting, and for enhancing safety. The document also identifies regulatory barriers and opportunities for new or innovative leak detection technologies. The guidance document does not purport to provide "the answer" on how to evaluate leak detection technologies, particularly in regard to determining equivalency of new technologies or methods with existing, approved technologies or methods. However, the document does provide a starting point in this ongoing challenge and discussion, which continues beyond the publication of the document and will be refined further over time, including through efforts such as the Path to Equivalency project being lead by the Methane Emissions Technology Evaluation Center (METEC) at Colorado State University, and the Canadian Environmental Protection Agency's Leak Detection Technology Equivalency framework currently under development.

Evolution of EPA Rules from Obama to Trump and Beyond

Suzanne Murray - Partner, HaynesBoone

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Experiences with UAV Inspections and Data-Analytics

Shailendra Singh - Director, Business Development, Honeywell Aerospace

Description

UAV’s are being used extensively in the oil-gas industry to increase safety and quality of data. Honeywell has combined its aerospace and oil-gas expertise to offer oil-gas companies UAV based inspections and data-analytics services. Honeywell will share its experiences in the UAV inspections and data-analytics to increase safety and efficiencies.

Federal, State and Local Enforcement

James Smith - Shareholder, Crain, Caton & James

Description

The presentation will highlight recent federal environmental enforcement trends and update state and local enforcement developments.

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Fenceline Monitoring for Benzene: What Does a Year's Worth of Data Say?

Nicole Bryson - Experienced Sales/Account Manager, Customer Service, ALS

Description

Major source refineries in the United States were required to begin fenceline monitoring of benzene in January 2018 via passive sampling technology in order to comply with the Refinery Sector Rule. Ten months in, what does the data look like? Is benzene frequently being detected at fencelines of refineries, and if so, at what concentrations? Can any conclusions be drawn, or generalizations made? Is this monitoring necessary? As a laboratory analyzing thousands of samples a month from refineries around the country, ALS Environmental will have a broad, robust data set to examine for trends, in advance of the Compliance and Emissions Data Reporting Interface (CEDRI) which will not be available until Spring 2019. The data set will be analyzed for trends and variability with regard to seasonality and geography, as well as any other factors that may come to light over the course of the year.

Flare LESS Profit MORE

Michael J. McMahon - CEO, EcoVapors Recovery Systems

Description

Over the past several years, it has become clear that tank flash gas often contains oxygen, which gas gatherers and interstate pipelines have placed increasing tighter limits on due to its corrosive effect on their steel pipelines and processing plants. So, unless this rich gas can be removed from the oil before it enters the tanks, or the oxygen is removed from the gas, the entire tank flash gas stream is usually incinerated on site. That’s wasteful and generates unnecessary emissions, lost profits, and in some cases royalties, are the most tangible consequences of flaring tank vapor gas, but there are also environmental aspects. Even though the industry has made significant progress in reducing venting and flaring, regulators are having to take a closer look. Flaring significantly reduces site emissions of Volatile Organic Compounds, or VOCs. That’s a good thing. However, it also generates nitrogen oxides, or NOx, as a by-product of combustion, and that’s not good as it also contributes to the development of ground level ozone. In summary, burning off flash gas reduces VOCs, but also contributes to ozone pollution. Once the oxygen is removed, this rich, valuable gas stream can be sold to enhance profits. And, flaring only has to occur in the case of the rare emergency. Now that publicly-traded E&P companies are facing mounting pressure from their institutional shareholders to generate returns on capital instead of growing production at any cost, monetizing tank vapor gas to increase profits and boost returns seems like a no-brainer. Never mind the growing pressure from environmental activists. Removing oxygen from tank vapor gas just makes sense, and dollars too. At EcoVapor we have that solution it is the ZerO2.

Flare System Control and Optimization for MACT CC RSR 63.670

Dan Johnson - Sr. Product Manager, Baker Hughes, A GE Company

Description

The new Refinery Sector Rule (RSR), passed by the EPA in December 2015, extends and strengthens the regulations governing stationary emission sources, specifically flares in refineries. It calls for the control and monitoring of flare systems, including, for example, meeting the specific requirements of Net Heating Value in combustion zone gas ( NHVcz), smokeless combustion and actual flare tip velocity(Vtip) for steam assist flare systems and additional Net Heating Value dilution parameter(NHVdil) for air assist flare systems. A flare control design, which takes live input of speed of sound from flare meters, was implemented to achieve real-time control using measurement of average molecular weight of an unknown hydrocarbon mixture from the sound of speed. This information can be used by the control system to determine the net heating value of vent gas as well as provide a dynamic ratio control for steam, this provides for a more efficient and responsive control scheme. Combined with the requirement of vent gas NHV imposed by Vtip, a continuous, efficient flare operation of supplemental gas will be demonstrated. By utilizing real time control via the speed of sound measurement provided by the flare meter, the risk of having a block of non-compliance is mitigated. Flare control systems using other schemes, such as controls based on feedbacks from Gas Chromatograph (GC) or calorimeters, were discussed in the paper. Practical implementation of this methodology and data are also discussed in this paper.

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Future of Flare Compliance and Flare Forecast

Troy Boley - Vice President, Spectrum Environmental Solutions, LLC

Description

A decade-plus focus on flares has resulted in several final flare rules, and more are likely on the way! Confidence in efficient combustion is the clear objective. A review of the various flare monitoring systems as required under NSPS Ja and MACT CC has served the refinery sector, but all may not be so simple as we look ahead to other industry sectors. Opportunities for improvement with respect to waste gas flow management, more minimization and continuous process improvement, and data management and documentation are plentiful. In addition, the era of widespread refinery flare projects will soon be behind us, and facilities must look towards the incorporation of the flare rules and their selected approaches into their Title V permit provisions. Soon, many will be tasked with discerning whether the new flare data suggest that there are possible permit deviations or even violations. A look back and look ahead into the expanding issues of flaring will be presented.

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Ground Flares, Air Quality Approvals and Requirements

Blake Soyars - Department Manager, Air Quality & Noise Services, Burns & McDonnell

Description

Pressure-assisted multi-point ground flare systems are used to control organic vapor emissions for a growing number of chemical manufacturing facilities. Ground flares serve the same purpose as conventional elevated flares, but current air quality regulations and approval processes are more complicated for ground flares. We will present key steps and challenges in the ground flare approval process, including the TCEQ Alternate Method of Control (AMOC) process and EPA Alternative Means of Emission Limitation (AMEL) process. We will discuss key compliance and permitting implications specific to ground flares at Texas chemical facilities. We will share actual permitting and approval timelines for example Texas ground flare projects.

Heated Sample Lines... "Don't judge a sample line by it's jacket - it's much more!"

Otto Hirsch - Global Product Manager, Thermon Inc.

Description

Heated sample lines are the transport between the extraction source (the probe) to the final and critical analyzing monitor. The sample will only be as good and accurate as what the monitor receives. Therefore, it is imperative that the specification, design, manufacturing, installation and maintenance of the sample line be taken into consideration before, during and after. All heated sample lines are not the same and each component plays an intricate part, including – the type and size of tube used, the type of heater, the insulation, the sensor, sensor placement, how the line is constructed, and the outer jacket - as well as the design, the installation and the maintenance. Heated sample lines are preinsulated/pretraced/ and jacketed and therefore all the components and the construction are not visible. There is an old saying: “Don’t judge a book by its cover”. The same can be said for heated sample lines: “Don’t judge a heated sample line by its jacket”. So, whats inside? This presentation/discussion will cover what a heated sample is, the components - tubing types, type of electrical heaters available, outer jacket options, control options, and construction, as well as accessories, installation and maintenance. In addition, can all sample lines be repaired or adjusted in the field and what to do when its time to replace the line. It’s not just a sample line, it’s a custom integral component to complete a total system solution!

How a Six Sigma Methodology Can Reduce Your Fugitive Emissions

Dale Rice - Corporate Environmental Engineer , VSP Technologies

Description

Flange and valve leaks account for up to 90% of the fugitive emissions for a typical chemical plant or refinery. A Six Sigma process can be used to effectively address this by optimizing a plant’s fluid sealing management program. Based on practical experience, a successful program integrates a series of eight sequential steps in the gasket / valve packing use process. However, achieving sustained quality improvement requires a clear commitment to employee training and making decisions based on established standards, not assumptions or guesswork. The elements of this Six Sigma process will be presented and discussed.

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How Digital Transformation Can Impact Compliance for Environmental and Safety Regulation

Marcio Donnangelo & Julie Valentine - , Emerson Automation Solutions

Description

This presentation will give you an overview of how Digital Transformation is eliminating layers of complexity to bring pre-interpreted field data directly to those who need to make decisions and take action. Two examples will be highlighted: • Environmental reporting involves flow measurements which must be verified to be accurate. Discovery of an inaccurate measurement can be costly for operators as they may pay fines from the last date they can prove accurate measurement. Meter verification tools make it simple and convenient to prove accuracy over time. Operators will be notified of problems immediately to avoid misreporting and allowing for immediate corrective action. • PRVs are no longer isolated mechanical devices that rely on manual rounds as part of a preventive maintenance program. Release and leakage alerts can be wirelessly monitored, and then integrated into reporting and analytical systems. Powerful tools are now available to interpret these patterns and predict future releases before they occur.

How IoT Will Impact Environmental Monitoring

Phillip Black - Product Marketing Director, Wood

Description

While the US EPA's Next Generation Compliance Initiative has concluded, the focus generated a number of conversations about the potential of small consumer devices in air quality monitoring. It also attracted the attention in the Middle East and Asia where accurate monitoring and reporting have historically been challenging. The global focus on compact sensors collecting more data, commonly referred to as the internet of things (IoT), means that more monitoring can be accomplished, but how can the information be trusted? Learn how other countries are investigating the combination of IoT with blockchain technology to increase confidence in their environmental reporting frameworks.

How to Control Flares to Comply with RSR-63.670 Rules

George Cheng - CTO, CyboSoft

Description

Oil refineries must comply with EPA RSR-63.670 rules and chemical plants will need to meet similar regulations in future. Flares must maintain a minimum combustion zone net heating value of 270 Btu/scf. In addition, for air assisted flares, the combustion zone net heating value dilution parameter must be above 22 Btu/sq.ft. In order to achieve these goals, flare control systems are critical. Technically, flare control is very difficult because: (1) The vent gas flow can change widely; (2) The heating value in vent gas can change widely and quickly; (3) Nitrogen is often used as purge gas to maintain positive pressure in the vent pipe, making the process more complex; (4) There are large and varying time delays in the heating value control loops, and (5) The heating value process is extremely nonlinear in different operating conditions. Flares are difficult to control using conventional PID controllers. Model-based control can be costly to develop and maintain. CyboSoft is offering a field-proven flare control solution with its CyboCon Model-Free Adaptive (MFA) control software. In this presentation, we will show how to design control systems for a steam assisted flare and an air assisted flare. We will run real-time control simulations to compare the performance when controlling combustion zone net heating value with different methods under varying operating conditions. CyboSoft’s Flare Process Modeling and Control Simulation Software will be used to demonstrate the following results: (1) A flare process is under good control where the combustion zone net heating value is above 270 But/scf under varying operating conditions; (2) A flare process may not meet the 270 But/scf requirement due to poor steam control; and (3) A flare process is not controlled well due to slow GC data. In the Q&A session, we can discuss: (1) Flare control system design considerations, (2) Vent gas heating value measurement, (3) 15-min data block calculations, and (4) How to integrate a flare control system with an existing DCS.

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How to Digitally Power A Cross-Functional Process Safety Management Program

Doug Martin - Vice President, Business Development, Gensuite, LLC

Description

• Leveraging a digital EHS system to identify opportunities for process safety management (PSM) improvements • Building the bridge between EHS & PSM programs to drive engagement and efficiency • Finding the needle in the haystack: Pinpoint PSM risks in your EHS data

How to Digitally Power A Cross-Functional Process Safety Management Program

Doug Martin - Vice President, Gensuite, LLC

Description

• Leveraging a digital EHS system to identify opportunities for process safety management (PSM) improvements • Building the bridge between EHS & PSM programs to drive engagement and efficiency • Finding the needle in the haystack: Pinpoint PSM risks in your EHS data

How to Integrate Drones into Routine Operations

Steven Fargo - CEO, DataWing Global

Description

DataWing uses aviation skills learned from years of Air Force flying and unmanned services to help large clients scale and integrate drones into routine operations. This presentation will identify how drones and drone-related technology can add value to environmental inspection programs and services. The presenter will also cover the necessary steps required to build a safe and secure drone program in minimum time so that organizations can start realizing this opportunity soon and meet operational and budgetary goals.

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Implementation of California's Refinery Fenceline Monitoring Law

George Lipinski - President and Co-founder, Spectrum Environmental Solutions

Description

Passive sorption tubes are not enough. The Governor of California signed AB-1647 into law on October 9, 2017, and the South Coast Air Quality Management District adopted Rule 1180 – Refinery Fenceline Monitoring on December 1, 2017. This rule requires state-of-the-art open-path optical equipment to measure “ppb levels” of various air pollutants at or near the property boundary of petroleum refineries processing greater than 40,000 barrels per day. This presentation will highlight for the conference what refinery sites must do for implementation before January 1, 2020, with an emphasis on conceptual fenceline project design, the requirements of the Air Monitoring Plan and Quality Assurance Project Plan, and the potential for utilizing this technology in other states beyond California.

Improving Safety with Wireless Monitoring

Marcio Donnanngelo - Global Business Development Manager, Emerson Process Management

Description

Think you’re covered? Radios aren’t always enough. Find out how to improve safety by monitoring safety shower and eye-wash stations, as well as comply with OSHA without incurring complex installation and deployment costs. A safety shower system integration using wireless technology is not only cost-effective, but can provide instant alerts and quick and effective response time.

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Industrial Gases for Wastewater and Other Environmental Applications in Today’s Refinery

Vince Hartley - Principal Applications Engineer, Airgas, an Air Liquide Company

Description

As Sustainability becomes a more mainstream driver for refining and petrochemical operations, they are also faced with even tighter discharge limitations. Additionally, the mantra of “doing more with less” remains a constant. In turn, the case for utilizing innovative solutions to meet compliance requirements grows ever stronger. This presentation is focused on means of reducing negative emissions, environmental and capital cost impacts and enhancing systems performance associated with pH control, aerobic wastewater treatment and blanketing of hydrocarbons through employment of alternative treatment method solutions. A primary focus is on the known advantages from safety, control, VOC emissions and regulatory aspects compared to commonly utilized options, especially use of mineral acids.

Integrating sUAS with Traditional Methods of Critical Infrastructure Security and Counter Drone Technology

Kwasi Perry - Founder, UAV Survey Incorporated

Description

Kwasi Perry a former Geospatial Intelligence Officer and Multi-Intelligence Fusion Specialist with the National Geospatial Intelligence Agency will discuss how to effectively integrate sUAS platforms into existing methods of critical infrastructure security such as fixed cameras, manned patrols, security fencing, and K9 units. Flight planning, and surveillance with the sUAS that utilize low observable techniques will be discussed. These best practices are sUAS manufacturer agnostic with a few exceptions. Kwasi will also speak about the state of counter-sUAs technologies.

Intricacies of Permitting Fugitive Emissions

Inaas Darrat & Courtny Edge - Director - Chemical Sector Services, Principal Consultant, Trinity Consultants

Description

The Air Permits Division of the Texas Commission on Environmental Quality (TCEQ) published a revised technical guidance document for Chemical Source Fugitive (APDG 6422) in June of 2018. This guidance is aimed to assist with appropriately permitting fugitive sources. With the revision published in June of 2018, TCEQ provides clarification on many contentious issues perhaps most notably more transparent guidance on what types of streams must be considered when quantifying fugitive emissions. This presentation will discuss when and how to permit fugitive emission sources based on TCEQ guidance as well as USEPA expectations.

Introduction to AFPM/API Advancing Process Safety Programs

Ryan Wong - Advanced Safety Engineer, ExxonMobil representing AFPM

Description

American Fuel and Petrochemical Manufacturers (AFPM) and American Petroleum Institute (API) have been managing the Advancing Process Safety (APS) Programs since 2010. This presentation will give a brief overview of the programs, the tool kit that has been created, and AFPM’s Safety Portal. The discussion will be framed around how these tools can be beneficial to an Environmental Professional and how they can aid in the industry-wide knowledge sharing efforts.

Is There A Better Way to Do LDAR?

Brian Whitley and Andrew Gunn - Vice President and Corporate Compliance Manager, Emission Monitoring Service, Inc. (EMSI)

Description

Is there a better way to do LDAR? For years we have cast a broad net over the program and called it compliance. With a closer look we now can call it a waste of money and resources. Is there a smarter way? Yes, there is. Join me and see data that shows a much better way to move the needle and lower our emissions while simultaneously lowering our cost. Smarter LDAR is real. A smaller carbon footprint can exist for every facility by utilizing modern technology and historical data. I hope to see you there.

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Isn’t It Ironic? A Case Study On Dry Seal vs. Wet Seal Centrifugal Compressor Emissions

Brandon Mogan - President & Principal Advisor, Tora Consulting, LLC

Description

The EPA has been pushing hard for the conversion from wet- to dry-seal centrifugal compressors for decades in an attempt to reduce emissions from the natural gas industry. Ironically, the opposite may have happened. Data from a recent study by Tora Consulting on centrifugal compressors most commonly found in the industry indicates that emissions from dry seal units are orders of magnitude higher than emissions from their wet seal counterparts. This presentation will provide the ultimate example of “missing the forest for the trees”.

Large Area Fugitive Emission Monitoring In All Conditions

Mohammed Belal - Co-founder & Director , MIRICO

Description

We present a detailed description and experimental results for a new laser sensing technique in combination with a gas emission survey method that remotely detects and maps the locations of multiple gas emission sources distributed across an extensive area. This presentation will focus on the application of this approach to methane and present results form an experimental evaluation of its performance using 17 calibrated releases, with support from he National Physical laboratory to create traceable standards. Our laser sensing approach, which we call Laser Dispersion Spectroscopy (LDS), uses changes in refractive index incurred by the optical beam to measure molecular concentration as opposed to traditional methods that depend of the intensity of the optical beam to quantify emission. The sensor offers improvements in precision, beam length, accuracy whereby the system inherently isolates common noise sources and offers enhanced performance in open path environments where detected optical intensity variation occurring form artefacts such as rain, water vapour result in inaccuracies when using traditional absorption techniques. Our experimental data set comprise of 7 optical beams that are sequentially steered on a timescale of ˜1Hz. Simultaneously we acquire 3D ultrasonic anemometry data and use this to drive a simple plume eddy dispersion model.

LDAR - Real World Problems

Earl Hassel & Jeff O'Neal - LDAR Coordinators, Chevron Phillips Chemical Company

Description

Real World LDAR is a presentation of the day to day struggles for monitoring, routine and non-routine maintenance and the best practice efforts to help minimize these struggles. We will show some good tools to use to prevent the repeat of bad actor leaks and ways to discover modifications outside of a Management of Change process.

LDAR 2.0: LDAR for Environmental Compliance and LDAR for Operational Excellence

Steve Probst and Dave Anderson - Co-Founder & CEO and Sales and Marketing Director, 4C Marketplace and Score Valves

Description

Description coming soon.

LDAR 2025 – What Does The Future Look Like and How Will The Industry Evolve?

Jerry Duke Jr. - Director of Business Development, HydroChemPSC

Description

This presentation will dive into the future state of LDAR, the technologies, and how the Alternative Work Practice (AWP) will drive the change. Remote sensing, drone and infrared camera technologies are improving every day and will drive big change within the LDAR industry. What we thought was a pipe dream is now a reality.

Managing Major Source Aggregation Air Permitting Risks

Blake Soyars - Department Manager, Air Quality & Noise Services, Burns & McDonnell

Description

Operating companies with capital investment plans may be exposed to project aggregation risks if: Multiple new facilities are constructed within several miles of each other (facility aggregation); or multiple capital projects are performed at the same facility with overlapping construction or short intervals between project activities (project aggregation). EPA has historically applied several project aggregation tactics to require a federal New Source Review (NSR) air permit and facility aggregation tactics to require federal Title V operating permits. Federal NSR and Title V permits involve extensive public notification and comment processes and additional compliance burdens. Federal permitting for capital projects can cause lengthy project delays, require additional expensive air pollution abatement equipment, and drive other unexpected costs. We will discuss past agency challenges, key risk indicators, the latest developments, and strategies to manage the risks.

Mass Spectrometers for BTU in Flare Determination

Robert Paddison & Don Rodriguez - Regional Sales Manager - Process Mass Spectrometry & RSM - North America Process Monitoring Sales Leader, Thermo Fisher Scientific

Description

Process mass spectrometry is a fast and effective technique for measuring flare BTU and increasingly popular for regulatory compliance.

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Measurement Technologies and Innovative Digital Solutions for Flare Management

Description

Knowing the effects of flare system activity is not the same as knowing the hidden causes coming from behind the headers. And just controlling the flare stack is not enough. New asset monitoring technologies give granular insight into ancillary equipment for better flare management operations. With this never-captured-before data and analysis, you’ll be able to make timely corrections or elimination of the root causes. Find out how to get to the next level of operational performance and compliance with this new diagnostics technology.

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Measuring Low Level Particulate and Eliminating Positive Bias with OTM-37

Justin Sullivan & Andrew Kendall - Senior Project Manager & Operations Manager, Alliance Source Testing

Description

Certain sources emit particulate matter (PM) at rates which render traditional particulate testing methods (EPA Methods 5, 201A, & 202) inadequate. Another class of sources finds positive bias in EPA method 202 measurements for condensable particulate matter (CPM) as a result of compounds present in process streams. Recently promulgated OTM-37 makes accurate measurement of particulate from these previously problematic source types possible. Larger particles are collected in PM cyclones, and smaller and condensable particulate matter are collected on a 47-mm filter. The sample gas is diluted with cool, dry air to avoid artifact formation while still allowing the measurement of CPM. OTM-37 measurement sensitivity is in micrograms, as opposed to milligram sensitivity in EPA Method 5, 201A, & 202.

New EPA Flare Regulations – How Does Gas Measurement Help?

Arnold Rivas-Griswold - Regional Manager North America, Fluenta Inc.

Description

EPA’s Refinery Sector Rule is about to come online. The new rule will cover all aspects of combustion efficiency to ensure the flare operation is done in a manner that is safe for the environment and safe for the operation of the facility. Refineries will undoubtedly need to take some actions irrespective of whether they use steam or air assisted flares in order to ensure heating values of at least 300 BTU/scft of gas at the flare. This can be done by monitoring gas composition, steam/air flow and flare gas flow rate. As flow rate is part of the calculation supplied to meet the requirements put forward by the EPA, a gas flow meter will need to be used to provide that piece of the puzzle. This presentation will discuss how ultrasonic flow meters have been used to determine the flowrates in refineries and other facilities. A discussion will follow focused on how this technology helps the facility operator comply with the existing and new EPA regulations, and on how much more can be done from the metering perspective to help the implementation of the new EPA rule.

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Nonparametric Trajectory Analysis (NTA) to Locate Local Emission Sources of Volatile Organic Compounds (VOCs) Potentially Affecting Fence-line Monitoring Programs

Robert Wallace - Business Lead, Source Location Group

Description

Nonparametric Trajectory Analysis (NTA), a receptor-oriented data analysis method can provide the average TVOC concentration as recorded at a receptor, provided the air parcel has passed through a specific point prior to reaching the receptor site. We demonstrate the approach using a diffusive sensor technology and a 5-minute sampling interval from a single station to reveal information on all local, near-field source locations within a ten-kilometer radius. Using this method, about 18,000 data points of total volatile organic compound (TVOC) observations were collected in a two-month period in Galena Park, Texas. The NTA plot for Galena Park during August and September of 2018 shows that TVOC contributions includes two significant source areas, neither of which includes the major processing units along the Ship Channel but both sources areas are apparently associated with railroad tank car and tanker truck loading/unloading operations, and storage tanks. High-frequency sampling of ambient air increases the information content available for discerning source locations and source characteristics as compared to traditional methods using averaging periods. For example, two-week average data obtained from passive samplers typically mask patterns that contain information about source locations and contributions. More frequent recording of concentration data and wind direction/speed can greatly improve the attribution of interfering, non-regulated emission sources in conjunction with fence-line monitoring programs.

Obtaining the Vertical Wind and Flux Profile with Optical Technology

James Shinkle - Business Development, Optical Scientific

Description

This presentation will discuss LOA technology and how it can be used to help obtain the vertical wind and flux profile. There are many benefits of using a LOA Technology (Long Path Optical Anemometer) as a tool for tracking movements of large bodies of air, hazardous wind movements and atmospheric turbulence. We will discuss applications where LOA and OWV (Optical Wind and Vortex) Sensors have been combined with other instruments to more accurately monitor air pollution movement and wake vortex. Developed in the 1970‘s by ERL/NOAA, LOA simultaneously measures the average wind across the optical beam (crosswind) and the turbulence (CN2) over the measurement path. LOA and OWV have proven LOA technology in a number of diverse applications, including monitoring pollution drift from Denver to Greeley Colorado, tracking the movement of noxious odor from a large scale hog farm and measuring airflow velocity of HF gases from aluminum smelting operations where it has received EPA Method 14 Equivalency Approval. LOA technology has been extensively field tested as part of NASA’s Airspace Systems Program to help Airports to detect the effects of a wake vortex on or near ground level. Using two or more LOAs can provide large area 2 dimensional wind vectors that no other sensors could possibly measure. Adding additional sensors three or more LOAs to form a closed contour, provides not only large area 2-dimensional wind vectors, it can also provide the near ground vertical wind (below the inversion layer). This versatile technology results in both very powerful research tool and rugged / time proven operational instrument to provide critical information for large areas wind, dust, pollution and be set up for monitoring and tracking in one, two or three spatial dimensions.

Oil and Gas Enforcement and Compliance Monitoring Update

Natalie Topinka & Kosta Loukeris - Environmental Scientist & Environmental Engineer, EPA

Description

This presentation will provide an overview of some of EPA’s recent enforcement cases and compliance monitoring activities at gas processing plants, production well pads, and pipeline pigging operations. The discussion will include field inspectors’ observations and areas of focus for improving operational best practices.

On-Going BWON Compliance Concerns

Ken Garing - Principal, Ken Garing & Associates

Description

Compliance issues with the BWON requirements have evolved since the regulation was introduced in the 90’s. In the early 2000’s, numerous deficiencies, ranging from the identification of regulated waste streams to the proper operation of control equipment, resulted in enhanced BWON requirements being included in the refinery global consent decrees. Since that time, a tremendous amount of work has been directed to this effort and the refining sector has made great strides in improving compliance with the BWON regulation. Mr. Garing will present his thoughts on where current efforts could be focused to further improve compliance.

On-line GC Solution to Comply with Flare Measurement Requirements

Ulrich Gokeler - Manager of Business Development, Siemens Industry

Description

On line GC measurement solutions are often utilized to satisfy and comply with a wide variety of flare measurement regulations. 63.670 (RSR), Chapter 115 (TCEQ HRVOC) and Subpart Ja, Rule 1118 (SCAQMD)for example. There are similarities between several regulations permitting to share the same analytical configuration. Often GCs are the default choice because reliability, familiarity and maintainability. Utilizing on-line analyzers successful is not necessarily the analyzer but the knowledge of sample transport and sample conditioning design, validation needs and simplicity of maintenance. This presentation will discuss analytical similarities especially between RSR and HRVOC, explain proven and reliable analytical configuration and possible validation simplifications.

OOOOa LDAR Compressor Station Case Study Results

Terence Trefiak - President, Target Emission Services

Description

In 2017, the EPA OOOOa regulation has come into effect. This regulation imposes OGI LDAR monitoring at new and modified compressor stations across the USA. Many of these facilities had no previous LDAR requirements and there has been significant speculation on what will be found during these monitoring events.

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Optical Gas Imaging: Examining Detection Limit and the Resulting Impact on Emissions Inventory

Jon Morris - CTO, Providence Photonics

Description

Optical Gas Imaging (OGI) has been widely used for detecting gas leaks from process equipment. However, the detection limit of an OGI camera has been an elusive performance metric and has not been systematically characterized and quantified. A substantial body of research has been performed that has shed some light on the OGI detection limits and the factors that dictate the detection limits. The OGI detection limit expressed as ppm-m can be calculated at a pixel level as a function of ΔT (differential temperature between the gas plume and the background), the OGI camera type, and the specific gas in question. Furthermore, the OGI detection limit expressed as a minimum mass leak rate (e.g., grams per hour -denoted DLgph) can be calculated based on the ΔT and the distance from the OGI camera to the leak location. With an OGI DLgph expressed as a function of ΔT and distance, an OGI leak survey protocol can be established that will provide operators a flexibility of using the most suitable combination of ΔT and distance in the field to achieve the same minimum detection limit. A numerically defined OGI detection limit will enable establishment of an emission factor for “non-detects” in a Leak Detection And Repair (LDAR) program. The contribution of the non-detects can be a significant contributor to the total fugitive emissions in an emission inventory due to the overwhelming number of components in the non-detect category. If a higher DLgph is adopted in a leak survey protocol, the emission factor for the non-detects will be higher, and vice versa. If desired, a DLgph value can be mapped to a “leak definition” in a conventional LDAR program, providing a transition from a Method 21 based LDAR program to an OGI based LDAR program for more efficient management of fugitive emissions.

Optimizing NG Compressor Station Permitting

Joel LeBlanc - Ashworth Leininger Group,

Description

This presentation puts forth a blueprint for a natural gas compressor station which maximizes compression capacity while maintaining an air emissions minor source status. The presentation will review common emissions sources, go into detail about equipment design considerations for minimizing emissions, and highlight best management practices.

Permian Basin Environmental Success Story: Revenue Sharing with Vent Gas

Jeff Voorhis - Engineer, Hy-Bon Engineering

Description

Lower crude oil and natural gas prices have made it more challenging for O&G operations to justify spending capital on the capture and reselling of vent gas. The lack of options on the spending capital have lead companies to flare or release to the atmosphere a valuable resource that could easily pay for the expense of the capture equipment.

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PFAS - Analysis and Data Quality

David Gratson - Senior Technical Chemist, Environmental Standards

Description

Following on the PFAS Primer presentation, this talk will outline the challenges with the analysis of PFAS substances. Research laboratories have been identified hundreds of PFAS analogs and telomers in ground and drinking water. Yet, the EPA, DOD, and ASTM published methods account for only a small subset of potential PFAS chemicals of concern at any particular site. In addition, the published EPA method (537, ver. 1.1) was prepared for drinking water matrix, yet it has been modified by most laboratories and extended to general ground water, surface water, as well as soils/sediments. Significant differences have been identified in how the commercial laboratory community has modified this method. The presenter will provide an overview on the analytical methods for PFASs with focus on the use of LC/MS-MS. Method details and how they can impact data quality and comparability will be described.

Pipeline Jurisdiction Analysis: A Look Inside Plant Facility Fencelines

Bruce Beighle - Partner, Integrity Solutions

Description

The purpose of a “jurisdiction analysis” is to evaluate and justify the applicability of federal and state pipeline safety regulations for gas and hazardous liquid pipeline segments and associated facilities. Pipelines within “complex facilities” can be subject to U.S. DOT PHMSA, DHS USCG, OSHA and/or EPA regulations, so a plant operator’s first step towards compliance is to correctly delineate agency jurisdiction limits and identify applicable regulations. Recently federal and state pipeline safety inspectors are looking inside the fence line of storage facilities, transportation facilities and plant facilities connected to regulated pipelines and asking operators to justify the connected facilities as being exempt. Significant changes and interpretations related to 49 CFR Parts 192 and 195 pipeline jurisdiction applicability criteria have been made by DOT PHMSA, often resulting in confusion and misapplication by plant operators.

Plant Turnaround Unit Flare Minimization Vapor Control Strategies

Paul Anderson & Chris Longo - , GEM, An Evergreen North America Company

Description

Turnarounds are one of the most anticipated and time intensive events in a plant’s cycle. Turnarounds are an essential part of continuous operations in the refining and petrochemical industries. They provide an important window of opportunity for essential maintenance tasks, and they also allow equipment to safely and efficiently be replaced or serviced, meeting regulatory requirements. If done correctly, they can potentially lead to huge gains in the facility’s productivity and output. However, turnarounds are also extremely costly events. If the budget balloons or the timeline unexpectedly expands, it can have disastrous effects on a company’s bottom line. Numerous facility turnarounds are being impacted by increasing environmental restrictions driven by the evolution of new federal EPA standards, MSS Regulatory Compliance and Refinery Sector Rules. Over the past 5 years, GEM has taken a comprehensive approach developing environmental vapor control strategies that are integrated into the operational shutdown procedures that are mitigating safety risks, eliminating environmental bottlenecks, shortening the shutdown sequence and increasing reliability of schedule, all while meeting environmental regulatory requirements. Our vapor control strategy during shutdown allows for flare-less shutdown capability, eliminating the flare systems as primary destruction sources, as well as providing continuous environmental compliance, monitoring, data recording, and final compliance reporting documentation. GEM also provides vapor processing that mitigates problematic process variables and compounds that exist during the shutdown and cleaning process, prior to introduction into a facility’s flare gas recovery unit or flare system. The vapor control processes include thermal vapor destruction, liquid scrubbing, carbon adsorption, heat exchanger cooling and condensing, condensate removal, as well as pressure and temperature control. These vapor control processes can be integrated into the facility shutdown plan and regulatory compliance program. These vapor control strategies are being successfully integrated into turnaround planning and serve as best practice for facilities recently challenged with meeting new environmental regulations associated with turnaround activities.

Potential Impacts of Recent U.S. EPA Region 6 Guidance on CMS Downtime and Data Calculation

Eric Swisher - Technical Manager, All4 Inc.

Description

In June of 2017, U.S. EPA Region 6 issued guidance in response to a written inquiry from Oklahoma Department of Environmental Quality (ODEQ) that provides an interpretation for the reporting of downtime for continuous monitoring system (CMS) and the process by which hourly averages are calculated for purposes of demonstrating compliance with an emission standard. The interpretation of U.S. EPA Region 6 differs from the widely accepted practice currently utilized by many facilities. This presentation will focus on the specifics of the guidance, impacts on current (and past) compliance demonstrations, actions currently in process to seek further clarification of the guidance, and the recent developments in the application of the guidance by regulatory agencies.

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Preparing for the Storm? Next Year’s Public Posting of Benzene Fenceline Data from Refineries

Heather Palmer & Byron Taylor - Partner, Sidley Austin, LLP

Description

This session will focus on the rise of “non-standard” enforcement actions against refineries and chemical facilities in the U.S. based on air quality modeling and limited ambient monitoring. We will explore how government agencies and private parties are now relying on data collected through Integrated Risk Information System (IRIS) assessments, National Air Toxics Assessments (NATA) results and/or Agency for Toxic Substances and Disease Registry (ATSDR) health consultation letters to initiate enforcement actions and class action lawsuits. We will also discuss how the public posting of benzene fenceline data from refineries could further accelerate this emerging trend.

Real-Time Analysis of Stack Gases

Koji Ishikawa - , Horiba

Description

The ENDA-7000 stack gas analyzer system designed to continuously measure the concentrations of nitrogen oxides (NOx), sulfur dioxide (SO2), carbon monoxide (CO), carbon dioxide (CO2), oxygen (O2), and ammonia (NH3) in stack flue gas streams. The ENDA-7000 series integral sample conditioning system ensures sample integrity for accurate measurements. The ENDA-7000 is based upon the HORIBA GH-700 series multi-channel analyzer is capable of measuring up to six different combustion gases simultaneously. Using a modular design, Chemiluminescence, non-dispersive infrared, non-dispersive ultraviolet and magneto-pneumatic modules are configured for the necessary measurements. The presentation will discuss the use of multi-gas analyzer technology to accurately measure components by minimize baseline drift, automate system operations, while being compliant for USEPA 40 CFR 40/60/75

Realtime Flare Gas Monitoring with Mass Spectrometer

Charles deCarlo - Marketing Manager, Extrel CMS LLC

Description

As refineries continue to optimize their approach RSR 63.670 compliance, new regulations for flare emissions are set to hit a broad range of industries over the next five years. The goal is to ensure the destruction of Hazardous Air Pollutants (HAPs) prior to release into the atmosphere, but drastic changes in vent gas composition make controlling that efficiency difficult. Getting the full composition of the vent gas quickly allows operations to apply corrections as soon as possible. Flare gas mass spectrometers measure hydrocarbons, carbon oxides, hydrogen, sulfurs, moisture and various volatile organics, and report concentrations and Net Heating Value (NHV) to the control system in seconds. Examples from recent ethylene flare gas regulations and MON sites will be covered in the discussion, along with data from oil refinery flare events.

Recent TCEQ Permitting and Modeling Changes – Lessons Learned and Future Strategies

Frank Dougherty - Consulting Engineer, ALL4 Inc.

Description

The Texas Commission on Environmental Quality (TCEQ) has enacted impactful changes to the way it requires permitting and modeling projects to be completed and submitted. These changes, most of which are required by June 2019, include the introduction of several new air permitting and modeling spreadsheets designed to streamline the air permitting process. During this presentation, we will summarize, review lessons learned, and provide examples on how to use these new workbooks, which are intended to significantly reduce the amount of TCEQ spends reviewing applications.

Reduce Turnaround Loading of H2S to the Flare and FGR Utilizing New Scrubber Technology

Jim Woodard & Jace Bigler - Business Development Manager and Chemical Engineer, Vapor Point, LLC

Description

Refineries are looking for alternative technologies to flares that can provide flexibility during various operations and maintenance activities. During unit shutdowns and turnarounds, there may be periods that the refinery Flare Gas Recovery System capacity can be challenged. The Vapor Point Scrubber system was utilized to ensure compliance with permit limits for H2S and SO2 emissions by scrubbing sour flare gases. Vapor Point has developed processes to aid the refining market with meeting the new compliance requirements while maintaining operational efficiencies. Vapor Point applies high efficiency liquid scrubbing systems to remove VOC, H2S, and other HAPS during different phases of unit decontamination. Specially designed temporary vessels for liquid and vapor phase product management have also been developed and are key elements in some applications. The vapor phase emission control systems and specially designed process vessels have met the needs of the refining industry with numerous field implementations.

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Refinery Flares Roundup - Lessons Learned doing Recent Flare Projects

Herman Holm - Director, Environmental Services, Spectrum Environmental Solutions, LLC

Description

The RSR refinery flare rule is now in full effect. It’s true that every flare is unique, and there are multiple paths to compliance, particularly when it comes to the instrumentation, controls, and compliance approaches. After the installation of the flow meters, control valves, and an analyzer, many find themselves swimming in a sea of control options. There are several potential paths forward to consider, and each has the objective of managing steam and supplemental gas addition in a fashion that minimizes cost. The RSR only specifies the calculations used to demonstrate compliance and makes no reference to the specific control techniques required to achieve said compliance. It will be up to each facility to determine the optimal control technique for each of their flares. A review of several control options, the documentation of the control systems, and data management techniques will be provided to help in achieving both flare control and demonstrating future compliance.

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Refinery Sector Rule - Top 10 Lessons Learned

Andy Shurtleff - Market Manager- Refining and Petrochemicals , Airgas

Description

Description coming soon.

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Regulatory Outlook Under the Remaining Term of the Trump Administration

Shannon Broome - Partner/Office Managing Partner, San Francisco , Hunton Andrews Kurth LLP

Description

Coming soon.

Residual Assessment for Oil and Gas for Potential Reuse

Robert Reimers, Ph.D. - Director of Asepticys, Inc, President of Paradigm International, Inc. and Adjunct Professor , Tulane University

Description

This presentation will elucidate the approach to assess oil and gas residuals. These residuals can fall into three categories, (1) hazardous wastes, (2) solid waste or (3) a residual that is outside the solid waste arena. The testing runs through three tiers of testing: 1. Alert level assessment (bulk density criteria) 2. Extraction testing (availability to environmental release) 3. Impact on biological organisms or biological processing. All these tiers relate to human health and environmental impact. The testing will be elucidated with various examples.

Results of Flare Remote Monitoring Test Sponsored by PERF

Yousheng Zeng - CEO, Providence Photonics

Description

The Petroleum Environmental Research Forum (PERF) sponsored a comprehensive blind test of flare remote monitoring technologies. The test protocol included extractive sampling as a control method and invited four organizations to test their respective technologies to remotely measure the performance of an elevated industrial flare. The test was conducted at the research and test facility of John Zink Hamworthy Combustion (JZHC) in Tulsa, Oklahoma from October 17th to 27th of 2016 and was administered by JZHC.. A wide range of flare operating conditions and environmental conditions were tested, including various fuel gas compositions, fuel gas flow rates, and steam flow rates, and NHVCZ levels. Providence Photonics’ Video Imaging Spectral Radiometer (VISR) was one of the four technologies tested. This presentation describes the range of test conditions and the blind test results for the VISR method.

RMP Litigation and Enforcement Update – Will the Amendments Survive?

Justin Savage & Tim Webster - Partners, Sidley Austin, LLP

Description

This session will focus on the compliance strategies for addressing developments in the RMP regulations, including whether the RMP Amendments will survive anticipated litigation. Other topics of discussion will include EPA enforcement, Title V, and citizen suits.

Safety as a Customer Service: Effective Communication for the Safety Professional

Daniel Boreman - HSSE Director, EMSI

Description

The saying goes, "it’s not what you say but how you say it". In this presentation we will explore some effective communication techniques for both delivering and receiving information in safety, work and even at home. We will discuss how a few customer service experiences, both good and bad, helped the presenter to redefine and improve his approach to positive and effective communication.

Serving Two Masters; Understanding Texas and EPA Permitting Programs

Johnny Vermillion - Program Manager, Air Quality, Spirit Environmental

Description

Ever Googled the differences between the state and federal regulatory agency requirements and how to meet both requirements? Well…good luck! Rid yourself of the internet nonsense and come learn some gems of knowledge from Johnny Vermillion, PE. Johnny will decipher the twisted similarities and differences between the two agencies. He will bring clarity to the cloudiness and help you avoid potential pitfalls with his explanation of the two sets of expectations. Johnny has roughly 30-years of first-hand knowledge with this exact topic. He retired from the TCEQ over a year ago and joined Spirit as an expert in our field. He has many years of experience when it comes to working and coordinating efforts between the State (TCEQ) and Federal (EPA) air permitting programs.

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Simplifying CEM Reporting:The Revolution in Data Acquisition & Handling

Brian Fowler - Director of Implementations & Marketing, ESC

Description

This session will provides a quick overview of current pressures that are requiring earlier and more accurate data validation, compliance averaging and recordkeeping. Then we’ll look at how a Data Acquisition and Handling Systems (DAS or DAHS) makes validated averages available immediately after acquisition for CEMS, COMS and CPMS. How does this change the flow and use of compliance data? Finally we’ll dig into passages from the RSR changes to MACT CC to examine the details of how different the recordkeeping and reporting for this rule will be as we enter the first year of compliance. Whatever solution you are planning to use, this session should provide helpful insight.

Status/Updates on NSPS OOOOa

Karen Marsh - US EPA, OAQPS, Sectors Policies and Programs Division, US EPA

Description

On October 15, 2018, the U.S. Environmental Protection Agency (EPA) proposed targeted improvements to the 2016 New Source Performance Standards (NSPS) for the Oil and Natural Gas Industry, including amendments to the fugitive emissions monitoring requirements in the rule. EPA accepted public comments on this proposal through December 17, 2018. This presentation will provide an overview of the proposal and information provided through the public comments.

Taking LDAR QAQC to the Next Level Using Technology

Derrick Mauk - Director of Quality and Training, Bureau Veritas

Description

1. Evolution of QAQC in LDAR a. Timeline of LDAR Program QAQC b. How basic QAQC was “Good Enough” c. When did QAQC begin to build d. Consent Decree Requirements stepped up QAQC e. Where do we go in the future 2. Monitoring Technology a. Technician has more info in the field b. Monitoring software and how it helps build quality 3. Field Auditing Technology a. Tools b. Processes 4. Database QAQC Technology a. Outside databases and tools used in QAQC b. Reporting on QAQC 5. Data Trending and how it helps QAQC a. What data do we look at b. How much data do we look at 6. Accountability a. What do we do with QAQC data b. Who do we share the data with c. How do we coach using the data 7. Increasing QAQC as we move forward a. Doing more than the minimum 8. As we move forward a. What does the future look like in LDAR QAQC b. How do we get there c. What do the results look like d. Who benefits

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Tanks Enforcement Update

Kosta Loukeris - Environmental Engineer, EPA

Description

This presentation will provide an overview of some of EPA’s recent enforcement cases and compliance monitoring activities at gasoline terminals, chemical plants, and other types of facilities. The discussion will include field inspectors’ observations and areas of focus for improving operational best practices.

The Dirty Dozen: Our Worst CEM Field Stories of 2018

Don Klotz - Business Development Manager, M&C Tech Group

Description

A glimpse into both common, and unique CEM challenges which hinder refinery, petrochemical and chemical compliance. From the sample extraction point, to the vents of the analyzers, every inch of the CEM sample path can cause major problems with data capture and compliance. This presentation will benefit both skilled, and novice, CEM technicians, managers and supervisors by reviewing detailed accounts of CEM downtime, and the symptoms and solutions associated with each issue.

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The Future Technology of LDAR

Joshua Pinter - Product Manager, CNTRAL Inc.

Description

In this presentation we will go over the current state of LDAR technology, including both hardware and software, and showcase emerging technologies that will dramatically shape the future workflows and efficiencies of the LDAR industry. From new mobile devices that allow for far more functionality than past generations to brand new technology that is still 2 - 5 years away from reaching mainstream, such as augmented reality. This presentation is aimed to not only get people prepared for the future and how our workflows will change but also to get people excited about the future of LDAR and the advancements that are coming, including heads up displays so you can have both hands free to monitor.

The LNG Bridge

Joan Fontaine - VP/Energy Services, Sanborn, Head & Associates Inc.

Description

Natural gas has been called a “bridge” fuel by those who foresee a transition to renewable energy, but the bridge may be lengthy given the plentiful reserve supply that has been identified. Natural gas production continues to increase, making new uses of natural gas attractive. New natural gas infrastructure has not necessarily kept pace, and markets for natural gas are ripe for development. Liquefied Natural Gas (LNG) provides opportunities for greater use, allowing natural gas to reach customers that currently do not have pipeline access or can benefit from a backup supply at times of seasonal gas shortage. This presentation will focus on successful LNG applications that have provided energy and economic security to industries and institutions. Example case studies will include LNG installations at: 1) a gas-fired power plant to supply gas during seasonal shortages, 2) an industry with large boilers that was able to substitute gas for heating oil, and 3) a university in the northeast that could maintain its supply of gas for campus heating during winter gas shortages.

The Regulation of Oil & Gas Activities Under the Trump Administration

John B. King - Partner, Breazeale, Sachse & Wilson LLP

Description

Oil and gas are our primary sources of energy. Regulations affecting this sector impact our entire economy. As such, it is vitally important that we understand the regulatory requirements and burdens being placed on this sector. During the Obama Administration, EPA and other agencies finalized regulations affecting the oil and gas sector. Upon assuming office, President Trump issued numerous executive orders and presidential memoranda announcing his plans for enhancing oil and gas production and reviewing Obama-era policies and regulations affecting oil and gas activities. Agencies, such as EPA and Interior, have stayed and/or rescinded certain regulations and have indicated that other regulations are being reviewed to determine if they should be revised or rescinded. As a result, many of the regulations issued by the Obama Administration are being or will be modified or repealed. Overall, the presentation will provide an overview of the actions taken by the Trump Administration to support the oil and gas industry through expanded production or decreased regulatory burdens.

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The Role of Science in Developing Enhanced Oil and Gas Resources, Being Environmentally Sound, and Protecting Water Use

Davis L. Ford - President, Davis L. Ford & Associates

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The Tanstaafl Principle: Secondary Impacts of Water Reduction Efforts

Todd Lusk - Senior Engineer, SLR Consulting

Description

When industrial facilities consider projects to improve water efficiency, the primary drivers are usually a combination of economics and water scarcity. However, reductions in water usage can produce a whole suite of secondary impacts that may not be readily apparent when developing the case for or against implementation. This presentation describes some of the key considerations that refineries should evaluate as part of any water efficiency program, as well as a case study where one refinery had to balance cost, compliance, and community impacts as part of its water management program.

Tramp Air Effects on Fired Heaters

Charles Baukal - Energy Leader, Director, John Zink Co. LLC

Description

John Zink Hamworthy Combustion field personnel inspect thousands of burners each year. Too often those flames are not only bad but sometimes potentially dangerous. There are a number of conditions needed for good flames. Burners should be operating at or near their design conditions which includes the excess air and draft levels, and the design firing rate (fuel pressure) and fuel composition. The combustion air must be properly distributed, the fuel must be clean, and both the air and fuel must be properly controlled. The burner and its associated equipment (e.g., tile and pilot) must also be properly installed and maintained. There are some visual indicators that should be checked for proper burner operation. These include uniformity (all flames in a given heater should normally look about the same), proper flame color, no leaning between flames or into process tubes, no pronounced hot spots or dark spots on the burner tiles, no irregular flame movement (e.g., no pulsing), and no unusual sounds (e.g., flashback). Bad flames can lead to increased pollution emissions, reduced thermal efficiency, and unplanned shutdowns. Common reasons for bad flames include improper burner maintenance and operation. Dirty fuel is particularly problematic as it can cause fuel injectors to plug which can create multiple problems. Ugly flames can be dangerous and need to be corrected as soon as possible. Examples of these irregular flames include flame impingement, huffing or pulsing, or severely lifted flames. The purpose of this presentation is to discuss proper burner operation and what good flames look like and then to contrast that with lots of examples of improper burner operation including the causes and corrections. This information can be used in the risk-based inspection and performance monitoring processes. Typically, equipment has a function statement (primary/secondary) and performance objectives and ranges. The consequences when the function of the equipment has failed is documented in the earlier processes.

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UAVs for Emergency Response: Being Prepared for the Unthinkable

Johnny Morrison - Drone Operations Manager - Chief Pilot, Insight Environmental

Description

Are you prepared to handle the unthinkable incident at your facility? Insight Environmental reacted quickly and professionally when the Husky Superior Refinery experienced a catastrophic event during a turn around. Outfitted with the most advanced UAVs equipped with thermal and optical gas imaging sensors, Insight provided support for firefighting and asset protection efforts until the fires were out. Is your facility ready to react to the unthinkable? What advanced tools do you have in place to ensure the safety of your employees while protecting your assets? Come and see how Insight handled a major incident when one of our clients needed us the most

Ultra-Low Steam Consumption, High Capacity Smokeless Flare

Clayton Francis - Application Engineering Manager , Zeeco

Description

This paper will introduce the technology behind, test data for, and industry challenges addressed by a new Ultra-Low Steam Consumption, High Capacity Smokeless Flare design developed by Zeeco, Inc. This flare technology is designed to further improve flaring efficiency and reduce steam consumption while continuing to meet the EPA Code of Federal Regulations, Chapter 1, Subchapter C, Part 63, Subpart CC requirements. We will focus on how the design addresses known industry challenges in high capacity, low steam consumption flaring, such as needing the ability to operate at low flare gas pressure since many applications have a maximum flare gas pressure at the flare tip of 3 psig. The paper will detail how this new design can achieve as low as 0.17 lbs. steam / lbs. flare gas at 20% of maximum flow rate, with the maximum flow rate achieved at a flare gas pressure of 3 psig. The above data is based upon a 5 mph wind with less than Ringlemann 1 opacity and a flare gas that is 100% propylene. For smokeless operation with propylene, other current steam assisted flare designs require approximately 0.5 lbs. steam / lbs. flare gas and / or a much higher flare gas pressure at maximum flaring capacity. Ultra-Low Consumption Steam Assisted Flaring is very important since any reduction in the required steam flow rate saves not only money, but also reduces the emissions produced from the production of the required higher steam flows. A key feature of this technology is that the air and steam mixture leave the flare at the same elevation as the flare tip exit, meaning no pre-mixing of air into the flare stream. Other current industry designs mix the air and steam with the flare gas prior to exiting the flare tip, negatively impacting the NHVcz according to the new calculation parameters required by MACT CC. Zeeco’s design more efficiently mixes the steam and air together and then mixes the resulting stream with the flare gas, creating a final mixture with a significantly increased volume of air. When the resulting mixture interacts with the flare gas at the tip exit, the increased air volume is readily available for combustion, meaning the flare is less likely to smoke. Since the design more efficiently mixes the air and steam together, less steam is required to achieve smokeless operation. Furthermore, the inherent efficiency of the mixing delivers a design less dependent upon using flare gas pressure to achieve smokeless operation. The flare can successfully operate at lower gas pressures at maximum flow rate.

Understanding Cooled vs Uncooled Optical Gas Imaging

Ron Lucier and Craig O’Neill - Senior Instructor and Global Business Development Manager, FLIR

Description

For over a decade, FLIR Systems has manufactured infrared cameras to visualize gas leaks of various kinds. These optical gas imaging (OGI) cameras are developed to “see” a variety of gases including hydrocarbons, carbon dioxide, sulfur hexafluoride, refrigerants, carbon monoxide, ammonia and more. These imagers are used to mitigate emissions, increase production efficiency, ensure safe work environments and more by a variety of industries. One great advantage of OGI cameras compared to other inspection technologies is the speed in which the technology can locate leaking components while not interrupting the industrial process. Historically OGI cameras have been designed with cooled infrared detectors that offer several advantages over uncooled thermal detectors but often come with a higher cost. Advancements in the technology of uncooled detectors have allowed the OGI camera manufacturers like FLIR to design and develop lower cost OGI solutions for these industries. While these are often lower in cost, there are some limitations versus imagers with cooled detectors. This paper will explain the differences in the two detector technologies and compare advantages/disadvantages of both.

Update on Fugitive Emission Standards for Valves, Packing and Gaskets

Matthew Wasielewski - President, Yarmouth Research and Technology, LLC

Description

Low-E valves and gaskets are now a requirement for most petro/chemical producers in the United States and that requirement is starting to spread world-wide. What test standards should you be specifying for your products, as a manufacturer or an end-user? How are the products tested? The most common laboratory test standards for valves include ISO 15848-1 and API Standards 622, 624 and 641. These standards are used for testing valve packing, linear and quarter-turn valves. This presentation will briefly describe the history of these standards with emphasis on the current published revisions and upcoming revisions. Details of the test parameters, along with the equipment, test setups and methods used to perform these tests will be discussed. In addition, typical failure modes will be examined. Current fugitive emission testing activities of gaskets will also be mentioned. The presentation will provide useful information to the manufacturers, users and purchasers of valves, gaskets and packing

Upstream O&G Air Permitting 101

Adrienne Rosecrans - Environmental Program Manager, Ashworth Leininger Group

Description

This presentation gives a high level overview of air permitting requirements for air emissions sources from the wellhead all the way through Midstream gas treatment facilities. The web of federal and state applicable air permitting and regulatory requirements can be complex to navigate. We will discuss permit applicable equipment types, current federal and state permitting programs and practices, some key best practices, and recent oil and gas industry developments.

Use of Open Path UV-DOAS as an Alternative Method to Meet Fenceline Monitoring Provisions for Federal Benzene Monitoring Rule

Don Gamiles - President, Argos Scientific Inc.

Description

On December 1, 2015 the EPA finalized the Risk and Technology Review for petroleum refineries. Among other things, the finalized rule requires petroleum refineries to conduct fence-line monitoring on a continuous basis. Benzene is the target compound, and an annual average, action level of 9 µg/m3 is established, triggering a refinery lead root cause analysis and corrective action. The fence-line monitoring provisions found in 40 CFR 63.658 describe the use of a network of passive diffusive tube samplers placed along the refinery’s boundary as the primary method for detecting fugitive emissions of benzene. The fence-line monitoring provisions allow a refinery owner or operator to submit a request for an alternative test method, such as open-path instrumentation. The use of this type of technology presents the opportunity to meet the requirements of the rule in a way that is more simplified and cost effective, while offering advantages in terms of potentially identifying and eliminating data points corresponding to outside emission sources. A field validation study has been conducted using latest generation, open-path UV-DOAS technology manufactured by Argos Scientific Inc., to detect benzene at a refinery fence-line on a continuous basis. The study includes a case study on the lessons learned in developing this program.

Using Optical Flow Sensor Technology to Meet EPA J/Ja and RSR Requirements

Donn Williams - Executive V.P. / Co-founder, Optical Scientific

Description

EPA (Environmental Protection Agency) Refinery Sector Rule (RSR) 40 CFR 63.670, presents the petroleum refining industry with significant challenges in keeping greenhouse gas emissions from flare events within specified limits. This presentation will show how using Optical Flow Sensor (OFS) technology can provide a proactive, real-time data solution to monitoring and controlling airassist lines, steam-assisted lines and flare lines and/or stacks to assure maximum combustion efficiency and prevent over-steaming, excess aeration and flame lift-off. One technology can handle the wide application variations and the OFS unique advantages allow the operator unprecedented measurement accuracy and control of a large-scale and dynamically-volatile processes all while saving cost during all phases – acquisition, installation and maintenance.

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Utilization of In Vitro Fish Cytotoxicity Assays for Use in Whole Effluent Toxicity Testing and Toxicity Identification and Reduction Evaluations

Justin Scott - PhD Student / Research Assistant, Integrative Biology, Oklahoma State University

Description

The clean water act established environmental regulations for wastewater facilities that discharge effluents into native surface waters by requiring them to perform Whole Effluent Toxicity (WET) testing. WET tests are biomonitoring assays that use live laboratory organisms to evaluate effects of potential toxicants to native aquatic populations. Current WET test methods are rather laborious, not very cost effective, and lack detail in identifying the toxicant mode of action. Moreover, the use of live animal testing has become a growing ethical concern. Utilization of cultured fish cell lines offer a high throughput approach, allowing simultaneous measurement of multiple toxicological endpoints. Cell viability is evaluated by indicator dyes that measure cell metabolic activity, lysosomal integrity, and membrane integrity. In this study, we have calculated effect concentrations reducing viability of 50% (EC50s) of 14 toxicants commonly found in wastewater effluent samples and correlated them to lethality in live organisms (LC50) from literature data. Further research for utilizing a polarized epithelia that can be specific to identifying common and emerging contaminants of concern are currently being investigated. Specific cell lines and their mechanistic endpoint responses have shown potential for applications in WET testing, as well as a complementary tool to current toxicity identification and reduction evaluation strategies in wastewater treatment facility operations.

Utilizing Mobile Treatment Systems to Capture Lost Profits Resulting from Flared or Reprocessed Fuels

Sean Kirkpatrick & Jim Woodard - COO & National Sales Account Executive, Vapor Point, LLC

Description

This paper/presentation will focus on how clients have been able to recover fuels that have been routed to flare systems due to specification misses, and how a mobile treatment approach was able to allow refinery clients to not only reduce the VOC and H2S/SO2 load to their flare system, but also recover a saleable product yielding increased profitability. The presentation will also discuss how this mobile technology can be used to supplement refinery hydrotreater operations during outage, helping prevent the requirements for storage and reprocessing of refined products.

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Utilizing Savings, Safety, and Reliability With Energy Surveys

James Nipper - Vice President, Petro Chemical Energy

Description

This presentation will go over the importance of energy surveys such as air & gas leak surveys, steam leak surveys, steam trap surveys, and insulation surveys. The presenter will discuss the importance of doing annual surveys based on information from our companies case studies. He will show how each survey can save you money from an economical view and how each survey can make your plant safer to work in and run more reliable. This is a very simple best practice project that can save your plant money and down time and to keep your employees safer and will help reduce your carbon foot print.

Vapor Lock Scrubber Technology Reducing Carbon Usage for BWON Compliance and Temporary Tank Storage

Sean Kirkpatrick - Chief Operations Officer, Vapor Point, LLC

Description

Vapor Point’s VaporLock™ control technology has been utilized within many areas of BWON operations, while also providing for the elimination of other HAPs such as Hydrogen Sulfide and Ammonia. Common applications include API Sumps and Separators, Dissolved Air/Nitrogen Floatation Systems, Tank Vent Emissions Controls, Sludge Processing Operations, Vacuum Truck and Frac Tank Controls and we have even designed equipment for the complete by-pass of existing sump systems.

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Visible Emissions Management Using Best Available Technology

Shawn Dolan - President, Virtual Technology, LLC

Description

ASTM D7520-16 and US EPA Alternative Method 082, have revolutionized Visible Emission Management practices over the last 7 years. Community Air Quality Awareness has become a litigation boiling pot, as smart phones, and low cost Particulate and Ozone monitors, have flooded the monitoring markets, making monitoring readily available to everybody everywhere. The exponential growth of the community monitoring market over the last two years will be reviewed and strategies to embrace community monitoring as a means of compliance assurance will be discussed in this presentation.

Waste Heat - a New Profit Center

Loy Sneary - President/CEO, Gulf Coast Green Energy

Description

Gulf Coast Green Energy, Bay City, Texas will make a presentation on their waste heat-to-power solutions for the O&G industry. Solutions discussed will be additional fuel efficiencies for large engines, compressed gas cooling and using flare gas for a beneficial use (making power). All three applications use wasted heat to produce on-site power which reduces the cost of power for the site. The presentation will highlight the successful Dept. of Defense funded project to reduce fuel consumption in large engines. Also highlighted will be the successful flare reduction trial. The project was funded by the Houston Advanced Research Center (HARC) and its Environmentally Friendly Drilling Systems (EFD) and the U.S. Dept. of Energy. Hess Corp. provided the HA-Rolfsrud well pad near Keene N.D. for the trial as well as engineering and electrical expertise. The purpose of the trial was to put flare gas to a beneficial use by using an organic Rankine Cycle generator. EFD and HARC contracted with Gulf Coast Green Energy (GCGE) for the Trial. GCGE is a distributor for the ElectraTherm Power+ Generator which generates power form wasted heat. The presentation will be made by Gulf Coast Green Energy’s CEO Loy Sneary and will include an overview of the projects from design to installation/commissioning, and through the successful sustained operations. Also the Texas A&M on-site environmental assessment will be presented for the flare project which found that the trail had significant emissions reductions compared to the existing flares or gensets which burn flare gas.

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Who Are Your Keepers

Tom Lane - Vice President of HSE, The Miller Group

Description

This presentation will describe how a well meaning experienced temporary worker has changed the world by releasing Killer Bees. It will help Supervisors and Managers understand the importance of training, oversight, and having a workforce that isn't hesitant to ask questions.

Wireless OGI

Omer Yanai - Vice President, Industrial Business Unit, OPGAL

Description

Oilfield digitization has started to change the way decisions are made. While early adopters are employing innovations to the production and processing of product, only a few are applying digitization technologies to address emissions reduction and LDAR operations. Optical Gas Imaging (OGI) cameras are commonly used to detect leaks in the oil&gas industry, but until recently they were used as a stand-alone isolated device. Opgal has recently launched its EyeCGas 2.0 camera which enables wireless connectivity as an enabler for LDAR digitization. In the presentation we will cover the new capabilities and opportunities which are becoming possible with this technology.

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