2015 Ozone Standards and Current and Potential Shortage of Emission Reduction Credits
What is the current status of the historical ERC trading programs in the long standing non-attainment areas (Houston, Baton Rouge, Dallas, California and Northeast). What lessons can be learned. Any interstate trading allowed? Any interpollutant trading allowed? How can companies mitigate these risks?
A False Sense of Security - Shifts in EPA’s Implementation of PSD Capable of Accommodating Determination and The Demand Growth Exclusion
The 2002 NSR Reforms provided additional flexibility to exclude emissions from existing operations; however, EPA provided little guidance as to how this emissions calculus is to be performed. Come hear the insight gained by the presenter during recent experience in performing a complex and detailed PSD applicability evaluation in the context of utilizing the Demand Growth Exclusion.
Expansion Projects’ Potential Impact on Wastewater & Liquid Streams in Open Systems
Does the change have the potential to impact the liquid streams in open systems determinations and would potential controls be required. The presentation will also include best practices and be based on recent experiences with USEPA’s expectations.
Flameless Oxidation Systems
Flex Permits as they Pertain to the Chemical Facilities
New Source Review: Will “Continuing Violations” Continue?
EPA and the Department of Justice have long argued that violations of new source review provisions under the Clean Air Act results in “continuing violations.” By arguing that violations for new source review provisions stretch back beyond the five year statute of limitations in the Clean Air Act, EPA and DOJ have been able to reach back to alleged violations (in some cases) decades earlier. The threat of civil penalties, applied at the statutory maximum under the Clean Air Act, for each day of a violation, has caused some prospective defendants to settle with EPA and DOJ on extremely favorable terms, agreeing to install tens of millions in pollution controls and pay millions in penalties. But most of the courts (including the Third, Seventh, Eighth, and Eleventh Circuits) that have addressed the issue have rejected EPA’s and DOJ’s argument that a violation of the new source review provisions is a “continuing violation.” A few courts (including the Sixth Circuit) have upheld EPA’s approach. This presentation will explore recent court decisions on this subject and discuss the Trump administration’s potential plans for new source review enforcement in the coming years.
Photochemical Modeling with CAMx for Ozone Inter-Precursor Trading
In a typical ozone Nonattainment New Source Review (NNSR) project, one requirement is to offset the project emissions of the ozone precursor (nitrogen oxides [NOx] or volatile organic compounds [VOCs]) with emissions reduction credits (ERCs) obtained from a source within the nonattainment area. As allowed by many state agencies, sometimes permit applicants choose to offset one ozone precursor with another precursor for various reasons, primary due to the ERCs for one precursor being unavailable or too expensive. To support this inter-precursor trading, state agencies and the United States Environmental Protection Agency (US EPA) require a photochemical grid modeling analysis to demonstrate the inter-precursor trading will not adversely affect the area’s attainment demonstration.
TCEQ Air Quality Permitting Effects Evaluation
This presentation will give the history of and the current practices of health and welfare effects evaluations conducted for TCEQ air quality permitting matters.
The Top 10 Priorities in Air Permitting for Regulatory Changes
BWON Compliance in the Post-CD Era
The refinery Consent Decrees added “enhanced provisions” to the BWON. Refineries complied by doing more than the BWON citations required, with the enhanced provisions sometimes dominating compliance demonstration. So what will happen as the Consent Decrees are terminated? Will all those enhanced provisions become a thing of the past? Or will it perhaps be advisable to retain some of them with as much attention as ever? The speaker brings decades of BWON compliance experience to a strategic analysis of what to do in the post-CD era. Some enhanced provisions have accomplished their goal and can readily be abandoned; for example, the laboratory audits. Other provisions offered a resolution of citation vagueness, leading to the question: what will we do if we abandon those provisions? The carbon canister breakthrough provisions come to mind. Perhaps most importantly, there are the provisions—notably the end-of-line activities—that regulators will continue to implement regardless of whether the refinery abandons them. The speaker’s extensive experience in the wastewater aspects of the BWON can shed useful light on ideas surrounding the continued critical requirements for TAB and uncontrolled benzene quantifications. These and other pressing topics of on-going BWON compliance¬—still a high regulatory priority—will be raised during the session, with plenty of time allocated for real-time discussion to get to the issues of interest to the attending audience.
BWON Lab Audits
Downstream Confirmation of Benzene Loading
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. Attendees of this webinar will learn a logical approach to developing a valuable downstream characterization plan, based on evaluating the wastewater system and the POG discharges that are managed at the downstream location. The uses, limitations, and benefits of the downstream information will be emphasized. Topics Covered: Benefits of a solid downstream characterization program. How to develop and implement the downstream characterizations. Using the upstream-downstream evaluation.
CEMS Panel: Consultation for Audience Members
Common CEMS RATA Failures and Risks
Difficult CEMS Applications at Refineries and Chemical Plants
Flare Compliance: Replacing GCs with Mass Spectrometers
National Uniform Emissions Standards & Community Right To Know Act
Overcoming Common Gas Sampling Challenges
Simplifying CEM Reporting: The Revolution in Data Acquisition & Handling
Stack Test Preparedness and Guidance
Tunable Diode Lasers: CEMS and Process Monitoring
How to Integrate Drones into Routine Operations
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.
Next Generation Enforcement: Environmental Enforcement in the Trump Era
This topic will examine environmental enforcement to date in the Trump administration. The New York Times recently reported that environmental enforcement has significantly declined during the first year of the Trump administration. While some of the decline may be attributed to trends from the prior administration, it is apparent that the Trump administration plans to reduce funding and resources for environmental enforcement and rely more upon state enforcement and self-auditing. This topic will explore some of the long-term trends in reduced environmental enforcement over time as technology is increasingly used to help monitor and enforce compliance, and the federal government increasingly relies on information-sharing with states, citizens groups, and tribes to improve environmental compliance. I will also examine the Trump administration’s new environmental enforcement policies to date, and discuss the implications for companies of the reduction in federal environmental enforcement (including the potential for a crazy quilt-work of haphazard and inconsistent state and citizen enforcement).
Perfluorinated Compounds: The Emerging Contaminant that Emerged Decades Ago
In the spring of 2016, EPA set new, lower health advisory levels in drinking water for two common perfluorinated chemicals (PFOS and PFOA) that had formerly been widely used in consumer products including Teflon and Scotchgard. The new health advisory levels (for chemicals that had already been regulated for decades and long-since phased out) have set off a flurry of regulation and litigation as states have adopted EPA’s guidance as enforceable standards for drinking water, and plaintiffs’ attorneys have filed class actions and personal injury lawsuits stemming from the presence of PFOS and PFOA in local drinking water supplies. Perfluorinated chemicals have captured the attention of local, state, and federal politicians, and now appear to be a key target for further health analysis, regulation, and remediation across the country. Federal funding has been provided for further study of perfluorinated compounds stemming from firefighting foam contamination at military bases, and EPA recently designated at least one former PFOA manufacturing site as a Superfund site. While there is some evidence that perfluorinated compounds can cause certain cancers at elevated concentrations, recent health studies have been mixed. Perfluorinated chemical contamination has been well-documented for decades, so the recent flurry of regulatory activity and litigation is surprising—and may ultimately not be warranted. EPA’s new health advisory levels for perfluorinated compounds are extremely conservative—to the point that they may be overly-protective and result in investigation and remediation of sites that do not warrant the expenditure of EPA’s and the states’ scarce resources.
The Regulation of Oil & Gas Activities Under the Trump Administration
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.
TSCA Reform, Take 2: Reconciling Trump’s Deregulatory Agenda and a Congressionally-Mandated Program
The presentation will begin with a brief history of the challenges faced by both EPA and industry under the prior statute, how those challenges ultimately set the stage for enactment of the first major amendments to any federal environmental statute in the last quarter century, and the prior Administration’s initial efforts to implement the new law.
Development of an Elevated Flare Tip to Ease 40 CFR 63.670 Compliance
The new flare related provisions in 40 CFR 63.670 and the potential for increased enforcement give rise to the opportunity for new technology to ease compliance for operators. The impetus and results from a research and development program for a new high efficiency elevated flare tip is presented. Realistic industrial scale testing was used to validate the flare design.
Eliminating H2S and SO2 Emissions at SRU, Coker, and Other Sulfur Handling Units of Refineries
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.
Flare Gas Composition Analysis and QA/QC – Lessons Learned and Lessons Lost
The now infamous “Table 13” of the Refinery Sector Rule in 40 CFR 63.670 will be presented and discussed along with a review of the historical approach to the flare gas composition analyzer’s Quality Assurance (QA) requirements. The experts at Spectrum Environmental Solutions, LLC (Spectrum) have been involved with a wide variety of industrial flare related issues within the petroleum and petrochemical related industry sectors including detailed instrumentation support. The presentation will provide an understanding of the periodic analyzer QA requirements as generally provided in EPA Performance Specification 9 for GC’s highlighting the shortcomings of the Table 13 RSR requirements, and some recent Flare consent decrees, to provide possible solutions for a reliable flare gas composition analyzer’s quality assurance demonstration.
Flare System Control and Optimization for MACT CC RSR 63.670
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.
Flare System EPA Compliance – How to Simplify Three Projects’ Execution While Saving on Installation Costs and Improving Productivity
This seminar describes three different flare system applications including a non-intrusive way to monitor individual pressure relief devices, a wireless solution for simplifying pilot flame monitoring, and an effective way to control steam-to-flare.
How to Control Flares to Comply with RSR-63.670 Rules
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 a control system for a steam 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.
Mass Spectrometers for BTU in Flare Determination
Mass Spec is an increasingly common process monitoring analyzer, returning BTU in flare results in under 30 seconds for compliance with EPA RSR flare monitoring requirements.
New Flare Design with Key Focus Being on a New Way to Manage and Minimize Steam Usage
Overcoming challenges meeting RSR Flare Monitoring Requirements
The deadline for complying with the flare monitoring requirements under the new Refinery Sector Rule (RSR) is fast approaching (January 30, 2019). What options do you have if you are faced with the challenges meeting the compliance deadline due to unusually long lead time for instruments, turnaround scheduling, project implementation, or other technical issues? A range of possible scenarios are discussed in this presentation, including use of the Video Imaging Spectral Radiometer (VISR) method as an alternative method, and request for an extension of 1 year, 2 years, or 5 years. The discussions will also include the timing, conditions, and procedure for requesting an extension.
RSR Automation, Flare.IQ System
RSR SSM Impacts and Solutions for NHV Management
This presentation focuses on the new challenges resulting from the RSR elimination of SSM exemptions and alternative solutions for maintaining compliance while minimizing cost impacts.
The Final Flare Requirements – Latest Update on the Refinery Sector Flare Rule
The experts at Spectrum Environmental Solutions, LLC (Spectrum) have been involved with a wide variety of industrial flare related issues within the petroleum and petrochemical related industry sectors. This presentation will lay a solid foundation for the rest of the conference presentation day as Spectrum will highlights the recent Federal flare rules specifically promulgated for the petroleum refinery sector. The intent will also be to provide the attendees with an understanding of the most likely flare improvement requirements anticipated by industry within future rulemaking for ethylene and chemical facility flares.
Ultrasound Theory as it Pertains to Flare Meters
Detection Limits for Optical Gas Imaging
Optical Gas Imaging (OGI) is an effective tool for equipment leak detection. Despite the fact that OGI has been used for leak detection for over a decade, its detection limit is an elusive performance metric. There is a persistent tendency to compare the OGI detection limit to the leak definition in the Leak Detection And Repair (LDAR) programs (e.g., 10,000 ppm, 2,000 ppm, 500 ppm, etc.). A substantial body of research has been performed that has shed some light on the OGI detection limits, the factors that dictate the detection limits, and the relationship between the OGI detection limits and the LDAR leak definition. These findings should help better define the capabilities and limitations of OGI as a leak detection method, and advance the OGI technology to the next level of adoption as a primary leak detection method.
Good Packing Installation Techniques for Fugitive Emissions Services
Current Fugitive Emission Standards for Valves and Laboratory Test Methods
The presentation will give a brief history of fugitive emission test standards since the early 1990's and detailed information of the test parameters of the ones used most frequently today. Descriptions of the test methods and equipment used to perform these tests will be shown. In addition, some of the difficulties that valves have to successfully pass these tests will be described.
Environmental, Health & Safety Driving Grab Sampling Culture
Discussion on how Sinclair Wyoming Refining Company is driving its grab sampling culture through the environmental, health, and safety departments.
Forge Bonding Valve Repair
The purpose of this presentation is to demonstrate the benefits of a field proven valve repair technology being offered by Forge Tech, Inc. That technology utilizes Forge Bonding to permanently attach a double sealed injection port to the valve packing area of in-service leaking valves in order to allow injection of new generation sealants into the packing gland to meet regulatory mandated leakage thresholds. The forge bonded injection port does not create a potential leak point, does not degrade over time, is safe to install, and is permanent. This technology eliminates hazards associated with traditional in-service valve leak sealing while improving the asset through installation of an injection fitting which provides a leak-free permanent maintenance platform.
LDAR 2.0: LDAR for Environmental Compliance and LDAR for Operational Excellence
Levels of Compliance
This presentation focuses on the various levels of compliance that a company can take within an LDAR Program. From being in regulatory compliance to consent decrees to taking preventative measures and actively seeking improvement.
OOOOa LDAR Compressor Station Case Study Results
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.
Quad Oa LDAR - Process and Procedures
OTA will provide insight into their current operations, processes, and procedures to comply with these new standards. We will cover the requirements of the standard, including survey technique(s) and monitoring plans, and how to best meet the objectives.
The Future Technology of LDAR
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.
What is a Connector? When Do I Have to Monitor It?
This presentation will cover what is a connector across multiple program types including for emission quantification via monitoring purposes. Furthermore, the presentation will cover when monitoring of connectors is required.
Acoustic Condensate Stabilization
Acoustic Condensate Stabilization is a novel technique that is proving to be highly effective and efficient. The stabilization process is driven by dynamic pressure of an acoustic field, causing mass transport of high volatile species into gas phase. The process is non thermal, making it a much safer alternative. The overall process equipment is much simpler and less costly to operate.
Navigating through the Challenges of NSPS OOOOa
This presentation provides guidance to navigate through the challenges of the NSPS OOOOa regulation. The tools discussed aid with applicability determinations of various emission sources to the regulation.
ONE Future – The Search for The Best Way to Reduce Methane Emissions
The ONE Future Commitment is intended to drive action to achieve segment-specific methane emissions intensity reductions, established through the ONE Future Coalition. ONE Future's overall goal is to achieve a methane emissions "leakage rate" (defined as emissions per volume of production or volume of throughput) of 1% or less along the natural gas value chain by 2025. The option allows each operator to determine the most efficient and effective means for managing and reducing methane emissions. The option will also help stimulate research and development to best manage and minimize methane emissions.
Permian Basin Environmental Success story: Revenue Sharing with Vent Gas
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.
Reduce Turnaround Loading of H2S to the Flare Utilizing New Scrubber Technology
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.
Utilizing Mobile Treatment Systems to Aid in Process Unit Deinventory – Meeting Refiners’ Challenges with MACT CC
The implementation of Refinery RTR is creating significant concern to operations, in how they approach equipment deinventory. New MACT standards restricts refiners’ ability to openly purge process equipment to the atmosphere, eliminating the SSM exemption, while placing significant constraints on when units can be opened to the atmosphere. Recent opinions have defined that all options will result in increased time commitment, resulting in additional cost to refiners. Advances in the application of liquid scrubbers have proven to be effective in helping refiners meet that challenges placed upon them helping reduce cost impacts.
Utilizing Mobile Treatment Systems to Capture Lost Profits Resulting from Flared or Reprocessed Fuels
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.
Waste Heat - a New Profit Center
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.
Benzene Fenceline Monitoring; Regulation Updates & Lessons Learned for Ongoing Compliance
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.
Navigating New Rules for Startup, Shutdown and Malfunction Under the Refinery Sector Rule
Refinery-wide Maintenance Vent Compliance Program Development Strategies
The requirements for “maintenance vents” under the Refinery Sector Rule (RSR) demand development of a formalized compliance program and coordination from a multi-disciplinary refinery stakeholder team. The team must evaluate compliance options while managing compliance risk and refinery resources for completing detailed calculations and implementing the new procedures into refinery operations. Many in the industry are creating a streamlined refinery-wide maintenance vent compliance program to ensure day-one compliance and on-going program sustainability. This presentation will outline our experiences with developing high-level compliance programs, including large-scale maintenance vent screening tactics, strategies for encouraging organizational stakeholder involvement, and lessons learned
MACT CC vs MACT WW
Method Update Rule - Impact to Detection Limits
I will present an overview of the new EPA Method Update Rule (MUR), and how this impacts the laboratory determination of detection limits. Details on how the new algorithm impacts variance estimates, and the resulting MDLs will be discussed. Laboratory data showing pre and post MUR method detection limits will be provided.
New Technology for Treatment of Refinery Chemical Cleaning Waste Water
Refinery Waste Water Treatment Plants (WWTP) have seen increased waste water volumes as refinery feedstocks have changed, with small ppm increased in water content in crude oil causing WWTP facility to become undersized. Additionally, with the shift in cleaning operations from steam out, to flooded fill and circulations, to today’s preferred methods of vapor phase chemical cleaning, the volumes and quality of the water generated from these operations has changed. Some refinery WWTP operations have had difficulty managing these change waste water conditions, resulting in significant volumes stored in temporary or permanent tankage which the refineries are unable to process. A new technology was developed to help specific refineries treat these chemical cleaning waste streams, allowing refinery WWTPs to more easily process the waste water.
Treatment of Merox Spent Caustic with a Combined Catalytic Oxidation – Biological Treatment Process
Water Reuse Solutions in Small Communities by Fixed Film Based Package Treatment and Innovation Disinfection Processes
This presentation will elucidate the fundamentals of the integration of fixed film reactors with the disinfection agents of the 21st Century. This type of treatment can develop inexpensive treatment systems for package plants in sensitive environments where their effluent can be sustainable for wetland areas.