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.
A Primer on PFAS, a Contaminant Emerged
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.
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.
Aerial Infrared Thermography
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.
Beyond CD Compliance, to Audit or Not?
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.
Clean Air Act Risk Management Plan and General Duty Clause: EPA Enforcement Trends and Other Emerging Issues
The presentation will provide an overview of recent trends for US Environmental Protection Agency (EPA) enforcement of accidental chemical releases and provide updates on emerging regulatory changes.
Common CEMS RATA Failures and Risks
Comprehensive Measurement and Analytical Technologies and Innovative Digital Solutions for RSR Compliance
There are many facets to complying with the new Refinery Sector Rule. This paper will discuss various solutions with regards to flare emissions and the reporting requirements. The paper will look at a comprehensive approach to flare monitoring, including relief valve and flare source monitoring, root cause analysis of flaring events, vent gas analysis, steam and supplemental gas flow measurement and flame detection. It will also include information on technologies to verify instrument accuracy over time and strategies to accomplish the goals of the new ruling in the most cost- effective manner.
Conducting a Threat Assessment of Your Facility’s Airspace
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.
Emissions Reduction Warehousing Analysis: Positioning Your Plant for Growth
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.
Enhanced LDAR Training: An Unconventional Approach to Training LDAR Technicians
Environmental, Health & Safety Driving Grab Sampling Culture
Engineered grab samplers can sometimes be a point of confusion in facilities. LDAR programs require the use of proper sampling connection systems and flushing controls however, compliance with these requirements can fall short if the sampling systems are not given as much attention as other aspects of LDAR programs. The purpose of this presentation is to help LDAR coordinators and other HSE professionals identify and correct compliance pit falls, identify stake holders that are affected by sampling systems, and discuss what can be done to help ensure a culture that demands the use of sampling systems designed to collect a safe, representative, and compliant sample in the field.
EPA’s Modeling Approach to Metals Criteria, How May it Affect State Water Quality Criteria?
This paper will discuss the implications of changing aquatic life water quality criteria for metals on water quality-based effluent limits (WQBELs) for dischargers. For example, EPA Region 6 has recently implemented a policy to evaluate the protectiveness of site-specific water quality criteria for copper developed with the water effects ratio (WER) method using the fresh water copper BLM. Also, EPA’s Office of Water envisions states using the model-based approach to replace state water quality standards.
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.
Good Packing Installation Techniques for Fugitive Emissions Services
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.
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.
Improving Safety with Wireless Monitoring of Safety Showers
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.
Is There A Better Way to Do LDAR?
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.
It's Not Dead, It's Mostly Dead - CD Termination
What is the process for terminating a consent decree with EPA and the Department of Justice? Is the process improved in this Administration or are terminations still stalled by disagreements over terms and what does "done" mean? This presentation will walk through the current overview of PRI CDs that have been terminated and lessons learned for those still open and for future agreements.
LDAR 2.0: LDAR for Environmental Compliance and LDAR for Operational Excellence
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.
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.
Methods for Enhancing Fugitive Emissions Prevention in Chemical Process Pipelines
Most fugitive emission reduction / elimination efforts in the industrial community, especially at chemical and refining facilities have been focused on component monitoring with the implementation of LDAR (Leak Detection and Repair) programs. USEPA studies have shown that the vast majority (between 80 and 90%) of fugitive emissions are associated with valve and connector leaks . While necessary, LDAR programs are, by definition, concerned with fixing leaks when they are encountered, not preventing them. Further, it could be argued that the greatest contribution to lowering fugitive emission rates from connectors and valves is through the use of consistent time-tested assembly and maintenance procedures, and the selection of the best available technology in terms of lowest emission valve packings, gaskets, torqueing equipment, and other equipment. An overview of best practices for achieving lowest fugitive emission rates for bolted flange connectors and valves including a fugitive emissions model for gasketed connectors will be presented.
Navigating TCEQ's "Non Rule" Permit-By-Rule
The presentation focuses on TCEQ's departure from the promulgated regulatory requirements of 30 TAC Chapter 106 into a "Non-Rule" based regulatory framework resulting in an elevated level of uncertainty and permitting costs. The presentation will define the underlying regulatory foundation of 30 TAC Chapter 106 and the strategies to address TCEQ "Non Rule" based information requests such as the "new hour", "affected source actual emission increases", "106.261 Checklist Footnote", etc.
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.
New Developments in Environmental Enforcement
This presentation will discuss new developments in environmental enforcement, including the new guidance on enforcement of incidental takes under the Migratory Bird Treaty Act, the increase in statutory penalties under the various environmental statutes, and the current administrations priorities for environmental enforcement.
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).
On-Going BWON Compliance Concerns
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.
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.
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.
Optical Gas Imaging: Examining Detection Limit and the Resulting Impact on Emissions Inventory
Overcoming Common Gas Sampling Challenges
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.
Process Burner Flames: The Good, the Bad, and The Ugly
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.
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.
Results of Flare Remote Monitoring
Review of Best Practices for Selection, Installation, Operation and Maintenance of Gas Meters for Flare Applications Used for Managing Facility Mass Balance and Compliance
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.
Serving Two Masters; Understanding Texas and EPA Permitting Programs
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.
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.
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.
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.
The Role of Science in Developing Enhanced Oil and Gas Resources, Being Environmentally Sound, and Protecting Water Use
UAVs for Emergency Response: Being Prepared for the Unthinkable
Use of Carbon Dioxide for Effluent and In-Process pH Reduction
Industrial gases, such as nitrogen, oxygen and carbon dioxide have been used in environmental applications for many years. One of the most proven environmental applications for industrial gases, and one of the simplest, is the use of carbon dioxide for pH reduction. Typically, this is to allow discharge of water to a receiving waterway for plants that have an NPDES (National Pollutant Discharge Elimination System) permit with pH limits. It can also be applicable for discharge to a local municipality, as well as for in-process needs. The use of Carbon Dioxide in the appropriate pH range can eliminate the need to utilize mineral acids (sulfuric being the most common), with all of the benefits derived from such a change, such as improved safety, improved control, lower maintenance, etc. As an additional advantage, Carbon Dioxide can be less expensive than acid on a pound for pound basis.
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.
Vaporlock - Scrubber Technology Reducing Carbon Usage for BWON Compliance
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.
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.
Water Efficiency Evaluations: Approaches and Secondary Impacts
Developing an achievable and sustainable water efficiency program requires a holistic approach and intimate knowledge of water usage within the facility - not only the quantity and quality requirements for internal water usage, but also the secondary impacts of water usage that may not be superficially visible. Implementing a program that encompasses the entire spectrum of water resource management can highlight and identify both procedural and engineering requirements for water reduction initiatives, as well as the potential operational and regulatory effects that may develop from water reuse or reduction. This presentation will describe the core principles used to develop an effective water efficiency plan and address specific issues that can arise from implementation of water reduction efforts, including impacts to other media, effects to in-plant processes, and considerations for end-of-pipe wastewater compliance. The ability to have a comprehensive understanding of the implications and pitfalls to meet compliance requirements to meet water quality requirements and limits are key to maintain consistent compliance for both numerical and narrative standards.