APTIM is a leader in environmental services with expertise in environmental engineering and consulting, decommissioning and decontamination, and remediation and restoration.
APTIM provides full scale small cap engineering, procurement and construction services (EPC), including processing units, civil service, earthworks, and fuel system projects.
APTIM manages complex government and private sector programs using tactical planning and operational excellence with proven project delivery and control systems.
Enhanced LDAR Training: An Unconventional Approach to Training LDAR Technicians
Todd Morrison
- Insight Environmental
Description
Is your LDAR training up to date with modern technology? This presentation will detail the process of incorporating technology such as 3D modeling and virtual and augmented reality into your LDAR training.
Eliminating H2S & SO2 Emissions at SRU, Coker and Other Sulfur Handling Units of Refineries
Jim Woodard, Sean Kirkpatrick
- Vapor Point, LLC
Description
The Federal Environmental Protection Agency (EPA) and state enforcement agencies have placed greater attention on the use of flares, and have in recent years placed new stringent regulations in place to directly impact flare operations (NSPS Subpart Ja), but are also imposing new National Ambient Emissions Standards
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 Volatile 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.
This paper/presentation will be focused on how the deployment of mobile technologies eliminates H2S & SO2 emissions resulting in improved worker safety while eliminating concerns with Ja regulations.
Autonomous Real-Time VOC Analyzer & Passive Fenceline Tubes – Data Comparison of New Technology to Method 325
Jason Robles
- CAMSCO
Description
In accordance with Method 325, passive sorbent tubes are currently deployed and continuously sampling at refineries across the US & Canada. The method is also applied in a number of new applications including the Proposed Organic Liquids Distribution (OLD) rule, Consent Decrees, State Enforcement & Community Monitoring. With the popularity Method 325 is gaining, and the need to investigate elevated readings, there is a growing demand for real-time data. Camsco conducted a study comparing data generated from one of the latest real-time VOC analyzers and passive tubes. In this presentation, we will review comparison study results and discuss steps taken to bridge the gap between the analyzers real-time data & passive tubes analyzed via TD/GC/MS.
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.
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.
How Do You Feel About Storing Your Emissions Data in the Cloud?
Matthew Radigan
- REGS, LLC
Description
Cloud computing means storing and accessing data and programs over the Internet instead of your computer's hard drive. In order to implement a cloud solution, you need some basic tools to connect your data source(s) to the Internet. Connection to the cloud storage needs to be secure, reliable and accessible. Turn on any new WiFi enable device, click through some prompts and you are connected. Technology made it so easy that it doesn’t even require a conscious thought to participate. Will the same environment that drives my social life translate to my workplace and more importantly, help me successful manage my critical air emissions compliance data. Required tools, feasibility and practicality of using cloud computing for compliance applications will be covered during the presentation.
Don Kinder - MarkWest, Jake Fournier - Marathon, and Deever Bradley - ERM
-
Description
MarkWest migrated away from the AWP for LDAR compliance monitoring. We left where everyone is trying to go and reverted back to M21 monitoring for our LDAR programs. Will have some stats and such to show the difference in leak % with OGI vs M21.
LDAR Case Study Comparison of Conventional Method 21 vs Alternative Work Practice
Terence Trefiak
- Montrose Air Quality
Description
I am the Managing Director of Target Emission Services. We provide fugitive emission surveys for the natural gas industry (transmission, processing, storage and LNG). We specialize in using Optical Gas Imaging (OGI) to detect hydrocarbon leaks and vents for regulatory compliance (EPA Subpart W - Green House Gas). However, we have started to utilize OGI to meet our natural gas processing clients various LDAR requirements (EPA OOOO and KKK) by following the Method 21 Alternative Work Practice (AWP) which allows for the use of optical infrared hydrocarbon detection. This AWP was released to provide industry with an option to use Optical Gas Imaging to replace “conventional” TVA type LDAR equipment for Method 21 facility inspections. OGI uses a specialized filtered infrared camera to provide a real time video of hydrocarbon gas leaks that are invisible to the human eye. The camera can survey up to 1000-1500 components per hour (compared to only 50 components/hour with conventional equipment), surpassing both the efficiency and effectiveness of traditional hand held gas analyzers. In addition many components that are classified as difficult to monitor using conventional hand held equipment can be readily scanned at a distance with the camera. A video of each emission source can also be recorded to provide the exact location of the leak and helps to ensure that the correct repair actions are being made. The use of OGI is on average 10 – 20 times more efficient that conventional LDAR equipment presenting a significant cost savings.The main questions are, • Is the AWP approach as actually as effective as the conventional LDAR approach? • Why are most LDAR contractors not using the AWP approach?• What are the tangible benefits (cost, # and size of leaks detected, safety, etc.) of OGI vs Conventional?My presentation will attempt to answer these questions using actual case study data from 2 large gas processing facilities. The presentation will compare survey results from both OGI and conventional monitoring and show specific examples (survey cost/durations, leak videos, etc.)
Issues of non-compliance and poor system performance are frequently discovered during CEMS program audits. The presentation will also focus on best practice implementation that can assist facilities in ensuring that their CEMS programs are compliant with applicable regulatory requirements and help utilize limited resources as efficiently as possible. Real world examples of CEMS audit findings will be outlined and ways to avoid such issues will be discussed.
Jason Voskuhl & Kurt Kraus
- Honeywell UOP Callidus
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.
Stephen Saint Vincent
- Saint & Tiller Technologies
Description
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.
Do you find Major New Source Review applicability confusing? Have you noticed that even the initial step of trying to figure out project increases (much less the rest of the program) already starts to descend into a confusing mess? When it comes to calculating project increases these days, the “devil is in the details”. This presentation will provide background and suggested approaches on the new the EPA guidelines along with insight on some states’ decision on implementation.
Large Area Fugitive Emission Monitoring In All Conditions
Dr. Sophie Purser
- 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.
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.
Auditing in the New Decade: Creating Value by Reducing Environmental Liabilities and Risks
Tim Wilkins & Eric Hodek
- Bracewell LLP & Ramboll
Description
Environmental liabilities pose significant risks in mergers, acquisitions, and ongoing concerns. Our presenters will discuss practical strategies for stakeholders, owners, or operators to leverage audit protections to strengthen their financial position.
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.
The U.S. EPA promulgated Clean Air Act regulations for upstream oil and gas facilities initially in 2011. While these regulations have been amended and expanded on several occasions to cover a variety of sources, emission data from upstream oil and gas facilities indicate that vapor resulting from the pressure drop from separation represents the largest single source of VOCs. Initial focus was on controlling or destroying the VOCs, although recovery of the rich gas is also a potential source of additional profit. The presentation compares and contrasts several of the standard methods for addressing these emissions from atmospheric storage and presents new technology for optimizing profitability while significantly reducing emissions and flaring. The effectiveness of reducing emissions of criteria pollutants as well as greenhouse gas emissions is also contrasted.
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.
Alternative Work Practice: How Revisions May Affect Refineries
Karen Marsh
- US EPA
Description
On December 22, 2008, EPA published a voluntary alternative work practice for LDAR using optical gas imaging. Since promulgation, advancements have been made in leak detection technologies that warrant examination of revisions to the alternative work practice. EPA plans to propose revisions to the alternative work practice in 2020 which may impact how refineries would implement the alternative. This presentation will discuss key questions, related to refineries, that EPA is considering during development of this proposal.
Particulate Testing: Modern Solutions to Modern Limits
Justin Sullivan
- Alliance Source Testing
Description
Particulate matter (PM) with diameters less than 10 and 2.5 micrometers pose a significant health risk to local communities. Because of this, regulations regarding PM 10 and PM 2.5 are ever increasing. The methodology used to test for PM is advancing to meet the needs of modern standards. Other Test Method (OTM) 37 offers a superior approach to PM testing as compared to traditional sampling techniques. This discussion will take an in depth look at several side by side comparisons of data from OTM 37 and traditional sampling methods. Topics discussed will include reduced test time, greater analytical sensitivity, and decreased bias from interferents.
NSPS OOOOa: Updates, Equivalency, and the Alternative Work Practice
Karen Marsh
- US EPA
Description
On October 15, 2018, EPA proposed technical revisions to the NSPS OOOOa. The proposal addressed many topics, including the application process for the use of emerging technologies for fugitive emissions detection. There have been various efforts to develop frameworks for understanding equivalency but several questions remain unanswered, particularly around how EPA will evaluate potential alternatives. On December 22, 2008, EPA published a voluntary alternative work practice for LDAR using optical gas imaging, which may provide some insight into future equivalency evaluations for sources in NSPS OOOOa. Since promulgation of the alternative work practice, advancements have been made in leak detection technologies that warrant examination of revisions to that rule as well. This presentation will provide a brief status update of the technical amendments to NSPS OOOOa including examining key questions regarding emerging technologies and equivalence to the OGI fugitive emissions program. This presentation will also explore how updates for the alternative work practice may provide insight for evaluating equivalency for OOOOa. 1 Hour Presentation.
Are You Ready? Contingency Planning for the RMP Amendments and Litigation
Justin Savage, Simone Jones
- Sidley Austin, LLP
Description
The RMP Amendments impose several burdensome obligations, including reporting up to the Board of Directors. EPA’s attempt to repeal or narrow the amendments will likely be tied up in litigation in the DC Circuit, but in the meantime, compliance deadlines are soon approaching. In the midst of this uncertainty, this session will discuss the DC Circuit litigation, enforcement trends, and planning for the amendments.
Applications and Field Results for Quantitative Optical Gas Imaging
Jon Morris
- Providence Photonics
Description
Optical Gas Imaging (OGI) is gaining traction as the best available Leak Detection and Repair technology(LDAR) for the detection of fugitive emissions. The NSPS OOOOa regulations, for the first time, have allowed for OGI as the primary LDAR technology. In addition, the emerging field of Quantitative Optical Gas imaging (QOGI) has opened up new applications and new possibilities for OGI. A recent QOGI method which allows operators to determine emission rates using a handheld optical gas imager. The technology has been tested and validated through various field studies and independent testing.This presentation will discuss applications and field testing results for QOGI in the upstream oil and gas industry. QOGI results are compared to known release rates and other quantitative methods. Applications for QOGI in both upstream and downstream oil and gas and petrochemical industries. Comparisons are made between available quantification technologies in the context of Leak Detection and Repair.
Boiler and Process Heater Tuning as a Best Management Practice
John Bacon
- TRC Consulting
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.
Tiny Habits® and Behavior Design to Transform the EH&S Workspace
Shirley Rivera
- Resource Catalysts
Description
A first-of-its-kind approach, Shirley brings Tiny Habits and Behavior Design to complement existing EH&S practices - think compliance management, training, refreshers, and workspace culture. Behavior Design, a field of study by Stanford Behavior Scientist, BJ Fogg, PhD., is based on a set of models and methods to design solutions that can influence behaviors. Behavior Design shares a similar context - environment, interactions, choice - with behavior-based safety programs, procedures development, and training endeavors. Attendees of this session will learn the Fogg Method and Tiny Habits, which simplifies habit formation. They will self-design three tiny habits that match one’s environment to practice and discover opportunities to apply the method in their workspace and personal lives
Advanced Technology for Real Time Fence-Line Perimeter Monitoring
Gilad Shpitzer
- Atmosfir Optics Ltd.
Description
Atmosfir Optics, Ltd., will present the D-fenceline System, an advanced software application, applied to classical FTIR, Open Path Technology, providing significant and unique improvement to remote sensing of fence-line boundaries. We will discuss how these unique algorithms have been applied in the field to drive detection limits down an order of magnitude, pinpoint emission sources with an advanced triangulation algorithm, and increase confidence in using real time data for rapid mitigation and alerts, with instantaneous, real time spectral validation against the NIST reference spectra.
Ultra-Low Steam Consumption, High Capacity Smokeless Flare
Clayton Francis
- 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.
Implementation of California's Refinery Fenceline Monitoring Rule
George Lipinski, Brian Cochran
- Spectrum Environmental Solutions, LLC
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.
Leveraging Digital Twin technology to reduce inspection-related defects and optimize your LDAR program
Boun Sananikone, David Tullos
- Bureau Veritas
Description
LDAR programs are based upon accurate inspections, timely repair, and proper identification of required components which need to monitored. Without the aforementioned, components working in parallel, your program maybe missing critical inspection points. Learn how Bureau Veritas is improving internal quality and helping our clients develop world-class fugitive emissions programs through our methodology.
The Forecast for Your LDAR Program Looks Cloudy, and Why That’s a Good Thing
Christopher Tucker
- InspectionLogic Corporation
Description
InspectionLogic has worked hard to move LDAR to a cloud based solution. We have learned a ton along the way and the benefits for everyone involved are huge! Come learn why moving your LDAR program to the cloud is a good thing and how it will benefit you, your facility, and your technicians. Topics will include data security, data accessibility, and what an “always connected” handset really means for LDAR technicians.
Flare System Control and Optimization at Refineries and Chemical Plants
Lei Sui
- Baker Hughes
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.
Per the court-mandated timeline, the EPA is currently working through the statutorily-required risk and technology review (RTR) for the ethylene NESHAP (40 CFR Part 63, Subpart XX and Subpart YY). Industry trade groups have been engaged in meetings with EPA as this process has moved forward. It is anticipated the proposed rule, late this fall, will impact current ethylene operations. It is anticipated the rule will mirror certain aspects of the refinery rule, such as the flare and PRD language and likely will address furnace stack emissions and decoke emissions (both decoke to the fire box and decoke to an atmospheric pot) and potentially waste water emissions.
This presentation will discuss the possible proposed rules and the potential impact on the ethylene facilities.
ZEVAC® - Reducing gas released during routine operations & maintenance
Brad Sando
- TPE Midstream
Description
Intentional release of natural gas during routine operations and maintenance has been identified by the US House Pipeline Safety Bill as an area to implement best-available technology for capturing released gas. Make ZEVAC® your BAT/BACT for reducing or eliminating release activity, as it was designed specifically to handle high frequency, low volume events keeping the gas safely in the piping system. Look to ZEVAC® to reduce or eliminate emissions throughout the value chain, whether you’re upstream, gathering, transmission, storage or distribution. For NGL operators, ZEVAC® Q is an industry first compressor technology capable of handling both liquid and vapor phase. Q is a safe alternative to thermal controls and flaring.
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.
The presentation will cover the new building downwash options included in the August 2019 version of AERMOD. The current Plume Rise Model Enhancements (PRIME) formulation in AERMOD has a number of theoretical flaws that have been documented on the treatment of downwash in AERMOD. A renewed interest and scrutiny of these downwash shortcomings fueled a parallel, yet complementary, effort led by industry and EPA. These efforts led to the new experimental Alpha options available in the new version of AERMOD. These Alpha options were developed by the PRIME2 committee and EPA’s Office of Research and Development The current presentation will cover the new Alpha options developed along with the implications of this new process to add new science to the regulatory model.
Barr will demonstrate its free Microsoft Excel spreadsheet tools for storage tank emissions, LDAR program review and compliance reporting, and MACT CC flare NHVcz standards
Emerging Technologies in Leak Detection and Quantification
Stephen Conley, PhD.
- Scientific Aviation
Description
With scientifically-outfitted airplanes, a drone-based quantification and LDAR platform, a mobile laboratory and continuous monitoring devices (in development), Scientific Aviation has become a trusted voice in emissions research and management. Come hear what we’ve learned in our years of global experience, including our in-situ quantification methods and our perspective on emerging technologies in emissions research.
Selecting the Most Cost-Effective Technologies for PFAS Treatment
Steve Woodard
- ECT2
Description
Since 2014, The United States Air Force Civil Engineering Center (AFCEC) has been conducting on-going response activities to remediate groundwater impacted by poly- and perfluoroalkyl substances (PFAS) at the former Pease Air Force Base in Portsmouth, New Hampshire. AFCEC’s response included the installation and operation of a full-scale regenerable ion exchange (IX) resin system to remediate groundwater in the source area impacted by years of firefighting training activities. The resin system was selected based on the results of a comprehensive pilot test that evaluated and compared the effectiveness of multiple treatment technologies.
In parallel, PFAS contamination was detected at elevated levels in the City of Portsmouth (City) public water supply in 2014. The Haven water supply well, located on the Pease Tradeport, was immediately shut down by the City. The source of PFAS contamination was traced back to the historical use of firefighting foam at the nearby Pease Air Force Base.
A SORBIX RePURE regenerable resin system was installed to meet the primary source area remediation objective of treating the groundwater PFOS+PFOA concentration to below the 0.07 µg/l Health Advisory Level. Design, installation and startup of the full-scale SORBIX system was completed from fall 2017 to spring 2018.
Based on the successful application of ion exchange resin at the former fire training area, The City decided to run a pilot test to evaluate the effectiveness of single-use IX resin versus bituminous Granular Activated Carbon (GAC). The pilot system was designed and fabricated to pump directly from the Haven Well and facilitated comparison of the two technologies at four different empty bed contact times (EBCTs); 2.5, 5, 7.5 and 10 minutes.
The full-scale source area regenerable resin PFAS remediation system has successfully treated groundwater with a total influent average PFAS concentration of 48 µg/l since April 2018. The treated water quality from the SORBIX RePURE resin system has been consistently non-detect for PFOS+PFOA compounds, readily achieving compliance with the 0.07 µg/l HAL target. Operational modifications have been made to address and correct minor challenges with the resin regeneration system, and regenerant recovery and related waste minimization processes have proven highly effective. No PFAS waste has needed to be hauled off site after more than 16 months of operation.
The IX resin results were similarly successful in the City’s public water supply pilot test. The influent total PFAS concentration averaged 3.5 µg/l over the course of the year-long evaluation. The IX resin substantially outperformed the GAC on all 12 PFAS that were present at detectable levels. The GAC column was operated until PFOA+PFOS breakthrough reached 0.07 µg/l at the 10-minute EBCT. This occurred at approximately 13,000 bed volumes (BVs), roughly 2.5 months into the test. By contrast, the IX resin effluent from the shortest (2.5-minute) EBCT column remained well below the 0.07 µg/l HAL, even after treating more than 171,000 BVs over a 12-month period. Based on the results of the comparative pilot test, the City selected IX resin for full-scale implementation to remove PFAS from the Haven water supply. The City’s engineer, Weston & Sampson, led the evaluation and attributed the selection of IX resin to the smaller footprint and lower capital and O&M costs associated with the technology. The full-scale system is scheduled to commence operation in 2020.
Upcoming MACT Residual Risk and Technology Reviews - What to Expect and Lessons Learned from the Refinery Sector Rule (RSR)
Rose E. Waypa
- Barr Engineering
Description
EPA has proposed multiple updates to rules following a residual risk and technology review (RTR) that will incorporate 2015 Refinery Sector Rule (RSR) requirements into rules affecting the chemical and petrochemical industries, including facilities subject to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Miscellaneous Organic Chemical Manufacturing (MON), Organic Liquids Distribution (OLD), and Ethylene Production. Proposed rule updates include incorporating new work practice standards (i.e., pressure relief devices and maintenance vents), developing innovative outside-the-unit monitoring techniques (i.e., fenceline monitoring), establishing comprehensive control device operating requirements (i.e., flares), addressing startup and shutdown operations against continuous emissions limits, and modernizing reporting and recordkeeping requirements (i.e.,CEDRI and ERT), all consistent with the final RSR updates. This presentation will focus on lessons learned from the implementation and the first year of compliance with the final RSR updates, and how those lessons learned can be applied to the industries affected by the latest RTRs. The presentation will include a step-wise approach to identifying compliance gaps, developing a work plan, and implementing new monitoring equipment and compliance procedures.
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.
Safety Showers and Location Awareness - Improving Safety with Wireless Monitoring
Marcio Donnangelo
- Emerson Automation Solutions
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.
Daniel Boreman
- Emission Monitoring Service, Inc. (EMSI)
Description
In an environment where so much emphasis is placed on safety, it is easy for workers to lose sight of who is truly responsible for individual safety. Complacency is arguably one of the biggest hazards faced by LDAR monitoring technicians in the field environment. This presentation highlights just how easy it is, even with the best intentions, to become complacent and offers some techniques to get workers re-focused and combat complacency.
New and Emerging Fenceline Monitoring Technologies: Current vs Emerging Technology Strategies for Sampling and Quantitation of HRVOC and OHAP in Ambient and Emission Sources
Peter Zemek
- Montrose Environmental
Description
Various types of sampling and analysis strategies have been developed and implemented for the identification and quantitation of HRVOC and other OHAP. This presentation will present the advantages and disadvantages of the current testing methods, and compare and contrast them to emerging technologies that are currently in development for the field and laboratory. Discussion will focus on sampling and analysis techniques including gas chromatography via USEPA Method 18, USEPA Method 320 for organics, optically enhanced FTIR for low level detection of specific organic analytes, and quantitation of various ultra-low detection limit concentrations of HRVOC and OHAP using real-time Proton Transfer Time of Flight Mass Spectroscopy (PTR) and GC Interfaced PTR compliance testing by EPA Method 18. Emphasis will be placed on the emerging technologies utilized by PTR mass spectrometry instrumentation.
A New Way to Measure Toxic Gases with Wireless and IIoT
Josh Hernandez
- Emerson Automation Solutions
Description
Toxic gases remain in the top issues facing the oil and gas industry from a safety perspective. Hydrogen sulfide (H2S) gas, Carbon Monoxide (CO), and Oxygen depletion (O2) are among the most common hazards in the process industries. The gases are extremely toxic and dangerous to personnel who work in these areas. These gases can accumulate in any area where oil or natural gas is processed, stored, or transported. Many cases of people sickened or killed by toxic or harmful fumes are reported throughout the world. Emerson provides a solution to keep end users safe with wireless technology
Advantages of Hot-Filter Cooled OGI technology for Leak Detection and Quantification
Ram Hashmonay
- Opgal
Description
The ability to manually replace or automatically swap filters in an OGI camera provide many advantages for various OGI applications. This presentation reviews several OGI applications, where swapping the filter provides better detection sensitivity, longer range, compounds' classification, and more accurate quantification.
Holistic Asset Management Using Methane Data & Analytics
Aaron Van Pelt
- Picarro
Description
Advances in mobile methane detection technology and analytics allow natural gas emissions data to be collected at a speed and scale not previously possible. Concurrent advances in “Big Data” Analytics allow better-informed conclusions to be drawn from that data and action taken. Such data-driven decisions are showing substantial financial benefits in pipe replacement, risk reduction, leak survey and emissions reduction. Methane data can be collected across a natural gas network and then used for multiple applications – an example being annual patrols to find and repair the highest-emitting leaks wherein secondary uses of the same data might be for improved prioritization of pipeline replacement projects and for risk-based leak survey. This revolution in the rapid, wide-scale collection and use of methane data is driving gas operators to use it in all aspects of how they manage their assets.
This presentation will describe, in simple terms, the three types of airborne gas leak detection solutions. The presentation will then highlight how recent technology advances are reducing operational leak monitoring costs by 60% to 90%. The presentation will answer the questions “What is Gas Mapping LiDAR”.
Vapor Lock Scrubber Technology Reducing Carbon Usage for BWON Compliance
Jim Woodard, Jeff St. Amant
- Vapor Point, LLC
Description
Vapor Point has been contracted by many refining clients, who have been challenged with the proper design of BWON related controls, to determine the most effective control system when considering cost and efficiency. The challenge with many BWON applications is the significant variability in contaminate concentrations which poses challenges in designing the vapor control system. Predominately, activated carbon is considered a BACT for BWON applications, while thermal oxidizers/combustors are also considered BACT, but not as widely utilized. Changing emissions characteristics of a refinery waste system, can render a well-conceived design selection ineffective.
This discussion will focus on carbon absorption systems and how incorporating the VaporLockTM under the correct circumstances improves the system design providing improved margins through direct (activated carbon changeouts), and indirect costs savings (unaccounted for man hours for carbon changeouts/exchanges, and environmental management associated with monitoring and NESHAP requirements for new and spent carbon canisters). We’d like to further highlight, that over the past nine years, we have encountered several clients that elected to utilize a combustion device due to the peak loading during high emission events, ultimately recognizing increased costs due to propane/fuel consumption and maintenance downtime due to the operating conditions of the combustion device.
This presentation will review a specific application where Vapor Point was enlisted by a Major Gulf Coast Refinery to investigate the ability to decrease carbon usage at a sump emissions control point which was part of the facilities BWON program. Vapor phase carbon is required per the site’s consent decree as the primary control device at various control points across the facility. The client selected one area where a significant increase in carbon consumption had occurred over a period of time. This sump emissions control point was selected as the pilot project for the installation of Vapor Point’s proprietary liquid scrubber system to decrease the loading of volatile organic compounds (VOCs) and specifically the benzene on the primary control device, vapor phase carbon.
MPLX LP, through its subsidiaries MarkWest Liberty Midstream & Resources, L.L.C. and Ohio Gathering Company, L.L.C., has entered into a first-of-its-kind agreement with the U.S. Environmental Protection Agency, the Commonwealth of Pennsylvania and the U.S. Department of Justice to implement design and operating improvements at pipeline launcher and receiver stations. As a result of these best management practices, emissions from these operations are expected to be reduced by as much as 85 percent. As part of the agreement, we are sharing our proprietary designs for “pig ramps” to minimize liquid loss during pig retrieval and information on the installation of depressure systems to reduce the pressure in the launcher/receiver chamber prior to opening.
Handheld and Small-UAV Laser Sensors for Natural Gas Leak Imaging and Quantification
Michael B. Frish, Paul Wehnert & Milton Heath III
- Physical Sciences & Heath Consultants
Description
We present lightweight handheld and aerial natural gas leak survey tools that cost-effectively locate, visualize, and directly quantify emissions from small infrastructure sources, e.g. valves, meters, etc. These tools adapt our widely-used laser sensors (the RMLD®) to platforms that spatially scan the laser beam to create images of emission plumes with high sensitivity, spatial resolution, and temporal resolution. Early prototypes have been deployed aboard small (24”) semi-autonomous unmanned aerial and in a man-portable configuration.
Texas Ozone Nonattainment Area Reclassification & Potential Implications on Your Operations
Kristin Gordon
- ALL4 Inc.
Description
In ALL4’s presentation, we will discuss the September 23, 2019 USEPA reclassification of the Houston-Galveston-Brazoria (HGB) and Dallas-Fort Worth (DFW) nonattainment areas to serious nonattainment for the 2008 eight-hour ozone NAAQS. We will share the potential impacts on facilities located in the HGB and DFW areas including but not limited to:
- Updates to major source nitrogen oxides (NOx) and volatile organic compounds (VOC) potential to emit (PTE) thresholds;
- Construction and operating permits implications (New Source Review and Title V Operating Permits);
- Permit by Rule (PBR) and Standard Permit authorization registration and/or certification of emissions via E-permitting mechanism; and
- Timeline for demonstrating compliance.
Closed Loop Flare Operations and Remote Measurement of Flare Gas Flow Rate
Yousheng Zeng
- Providence Photonics
Description
A Video Imaging Spectral Radiometry (VISR) device is integrated into a flare control system to automatically adjust steam assist based on the smoke level of the flare. The VISR device is also used to remotely measure flare gas flow rate. The results of these new features and applications will be presented.
The air quality permitting process is a data-driven process. Federal permit applicability (do you trigger PSD?), netting calculations, rule applicability, emission calculations, etc. require input data. A permit application cannot be prepared or reviewed without access to the necessary information required by the rules and regulations. Finding, retrieving, and manipulating the dozens of available data sets adds days, even weeks to the processes to prepare and review the permit application. Do you really want to expedite the air quality permit process? NaviKnow Solutions has developed 21st century tools where you can easily locate, access, and download the information needed to complete or review air quality permit applications ALL in one location. We have also developed tools to significantly automate the application review. See how a significant amount of time can be shaved off the air quality permit application process without having to pay for an "expedited" permit application review.
A Wastewater Solution for an Air Pollution Problem
Todd Lusk
- 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.
Photochemical Modeling for Ozone Inter-Precursor Trading
Qi Zhang
- GHD Services
Description
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.
The National Emission Standard for Benzene Waste Operations (BWON or Subpart FF) is a complex regulation that is difficult to assess in the context of a due diligence assessment. These assessments are conducted within compressed schedules, essential documentation is typically limited or unavailable, and the liabilities for non-compliance are significant. Given the complexity of the BWON regulation, even a seasoned practitioner can miss a significant compliance issue, which could result in a costly corrective actions and potential enforcement exposure for a new owner. Further complicating the due diligence are Subpart FF enhanced requirements mandated in Consent Decrees. Assessing compliance with these enhanced requirements is just as important as compliance with the regulation itself. Given this complex backdrop, Subpart FF assessment during a due diligence must have a laser focus on those requirements of most importance for the acquisition. This presentation draws upon the presenter’s experience in performing detailed Subpart FF assessments in the context of a due diligence and from litigation related to BWON compliance. The presentation uses case study examples to illustrate key areas of inquiry that should be part of the assessment, and provides helpful and practical recommendations for evaluating key aspects of a Subpart FF compliance program. This presentation will also be of interest to BWON professionals with ongoing operations as it provides a “mental checklist” of areas of potential exposure in their BWON compliance program.
20% of PRVs in a typical operation are potentially leaking. Undetected and therefore not reported PRV releases occur more often than operators realize and are one of the major causes to compromise valve sealing integrity. PRVs are the last line of defense against process overpressure and it is critical that all releases be reported and recorded for process safety root cause analysis, including near miss safety events.
Join this session with Anderson Greenwood Crosby PRV team to discuss wireless monitoring solutions that enable operators to correlate real time PRV information with process data and maintenance records to improve environmental, occupational and process safety management.
Integrating Speciation Data For Chemical Plants and Refineries
John Beath
- JBE
Description
A surprising number of reports rely on chemical speciation data for purchased chemicals, feedstocks, intermediate streams and products. Recent experience with an EPA NEIC inspection underscored the value in centralizing this data for consistency. Calculations related to quantities present onsite (Tier Two), release reporting and threshold determinations (EPCRA/SARA), emissions calculations (EI/TRI), TSCA Manufacturing Inventory (coming in 2020), RMP (Maximum Intended Inventory), PSM (operator process information), OSHA Hazard Communication, and permit applications could benefit from a carefully orchestrated process. Imagine if the system you develop internally could answer simple questions for emergency situations like what’s the composition of the material in that drum, or that heat exchanger; and imagine if a process was in place to keep all of the content revised as process changes occur.
Avoiding Under-Reporting and Over-Reporting of Fenceline Plant Emissions
James Shinkle
- Optical Scientific
Description
Using a point measurement wind sensor for fenceline applications will result in under or over-estimating large body wind movement from your plant. OSI’s Long-baseline Optical Anemometer provides path-averaged wind data to give you an honest and accurate picture of plant emissions and can be a valuable tool in the case of an accidental release.
Flare Gas Measurement Lessons Learned from Refineries & Future of Chemical Plants
Arnold Griswold
- 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.
Methane Emissions - Adopting a find it, fix it mentality!
Scott Wallis
- Score Valves
Description
When companies detect a fugitive emission on their asset, it usually gets added to a leak register for repair at the next convenient opportunity. Because so many "weeps" can exist at any one time, if the repair program is not efficient and weeps are not repaired in a timely manner, this not only costs the asset money and affects performance, it becomes a serious safety and environmental issue. If just one leak was to escalate and shut the plant down, this has a huge financial cost and knock on impact. The message - It can be avoided if we find and repair our weeps regularly.
Benzene Fence-line Emissions at Refineries: What Legal Standard Applies?
Simone Jones and Marshall Morales
- Vinson & Elkins
Description
With refinery fence-line data now publicly available, EPA, states and private parties appear to be aggressively mining the data to determine whether any concerns exist. In particular, EPA appears to be taking the position that 9 mg/yr standard is only the starting point for analysis and that other agencies’ legal standards should inform risk and compliance. What standard should refineries aim to hit with benzene emissions?
As the U.S. EPA begins expanding the flare requirements first found in the Refinery Sector Rule to other industries, newly affected facilities need to begin planning the installation of new monitoring on covered flares. This potentially includes pilot monitoring, visible emissions monitoring, vent gas flow monitoring, assist gas flow monitoring, and net heating value and/or composition monitoring; all of which will be required to meet the new requirements. This presentation will summarize the monitoring required by the new flare requirements and describe some of the technologies which may be used to comply with the regulations’ requirements.
Jason Voskuhl & Kurt Kraus
- Honeywell UOP Callidus
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.
The State of Fenceline Monitoring Systems Lessons from the California Experience
Randy Gibbons
- Terra Applied Systems
Description
Several air quality regulating bodies in California are requiring major petroleum refiners to implement fenceline monitoring programs using open path sensing technologies. The first continuous open path Fenceline Monitoring system in California was at the Unocal Rodeo refinery (now P66) installed in 1996. This TAS system is effectively the prototype for projects currently being required at most other California refineries. Broader interest in similar fenceline systems has increased in recent years for environmental impact and general safety. The California experience provides some good examples to discuss the state of the technologies and the successful implementation of fenceline monitoring programs and systems. TAS has a unique perspective having been instrumental in creating the design and guiding implementation for most of these systems in partnerships with several refiners and local companies.
Success cannot be defined or achieved without realistic purpose. Communicating purpose and building this into design before committing to engineering is often a significant obstacle. Several purposes for the California fenceline monitoring initiatives were defined in early regulation support studies. However, most of the refinery projects were being started without design purpose awareness.
Technology and product readiness for these systems were not as clearly defined as regulators or even manufacturers understood. Sensor detection capabilities were overstated by operators, consultants, and some manufacturers. This led to unrealistic expectations in regulations and monitoring plans. Community attention as well as regulations requiring standards for uptime and data quality presented challenges to current products and practices. This has driven improvements in methods, equipment, and support systems. It has required manufacturers to transition products and systems from various stages of commercial readiness to address full industrial implementation. As systems come online and continuous operations are scrutinized, further developments are ongoing.
Designing open path systems is not as simple as it would appear. Regulations written to operate continuously at the limits of the technology require close attention to details usually not important to refinery engineers. This often becomes a challenge. It can be aggravated in plan execution as environmental and construction challenges are often met by compromising design details. Close attention at every step of implementation is important.
Most of the new experts promoting themselves in this California initiative operate in effect under a batching support and quality assurance paradigm. This is largely accepted by regulators and customers, but it carries risks. Experience with dozens of safety and operations critical open path systems, TAS brings a design paradigm of continuous operations that is well suited to the demands of operating in refinery and other heavy industry environments.
Craig O’Neill and Chris Beadle
- FLIR & IntelliView Technologies
Description
Optical gas imaging (OGI) has been a part of leak detection and repair for over a decade. From starting as a handheld solution to ensure safe work practices in the oil and gas industry to becoming the best system of emissions reduction (BSER) as defined by the EPA in US methane detection regulations, OGI has become a foundation of the oil and gas industry for emissions mitigation. One recent key advancement of OGI is the introduction of uncooled solutions for this technology. Uncooled OGI solutions offer the oil and gas industry a lower cost, smaller solution for methane detection that can easily be utilized for continuous 24/7 monitoring. As the oil and gas industry looks for advanced solutions to streamline methane mitigation and more efficiently diagnose leaks, new fixed uncooled OGI solutions will be able to detect and identify emissions. A combination of uncooled OGI cameras from FLIR and advanced analytics from IntelliView Technologies provides the market with an anonymous and reliable solution.
Sinclair Wyoming Refining Company (SWRC) and Sage ATC will lead a diverse panel
discussion examining the practical and technical challenges presented by implementing the
Refinery Sector Rule miscellaneous process vent (MPV) and maintenance vent documentation
requirements into everyday compliance.
On the practical side, SWRC will discuss unique challenges faced at the refinery level, including
MPV group classification, monitoring and documenting maintenance activities, and helping
operators understand and adjust to the new requirements. On the technical side, Sage ATC will
discuss broader industry perspectives including efficient approaches to tracking and monitoring
maintenance activities, a deep dive to MPV monitoring and compliance management, and
strategic considerations when developing and implementing MPV procedures and practices.
The panel discussion will be interactive and adaptive. Members of the audience will be polled to
determine the practical, technical, and legal issues that the audience members are facing, and the
presentation will be adapted to focus on the issues of greatest interest. Members of the audience
will also be polled to submit questions, e.g., technical and legal questions or concerns that they
may not be comfortable having attributed to their companies.
Process Burner Flames: The Good, the Bad, and The Ugly
Charles Baukal, Bill Weimer, & John McGuire
- 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.
What is digital transformation? Digital transformation allows the use of data on a daily basis to reduce emissions, improve safety, reduce cost and increase mechanical availability. An everyday example is tire pressure. 5 years ago we checked the air pressure in our tires once a month. Now there is a tire pressure indicator that displays the pressure of each tire when we start the car. Properly inflated tires increase gas mileage (reduce cost and reduce emissions), have fewer blow-outs (improve safety) and increase the life of the tire (increase mechanical availability).
Similarly, flare flow was not measured 5 to 10 years ago. Most facilities now measure the flow, concentration, supplemental fuel and steam (or air for air assisted flares). This results in operators scrambling to find the source of flow when the measured flow or concentration goes outside a constraint (sulfur, Btu, opacity, etc.). The digital transformation for flares is the use of Emerson’s non-intrusive transmitter based flow detection enabled with Mesh Technology, Score Valves Midas meters (surveys and installations), BH FLareIQ, and Extrel’s Mass Spectrometry to identify in real time the source and impact of flare flow, composition and control.
These technologies constitute the digital transformation of flare operation. The identification of the source of the gas on a real time basis is the manifestation of the digital transformation to reduce cost, reduce emissions, improve safety and increase mechanical availability.
The oil and gas industry faces a similar digital transformation in the coming years. Satellites will detect emissions each day. Annual, Semi-annual or Quarterly monitoring of valves, pumps, and flanges do not produce the same result as a daily check from a satellite or a canary in the community. The satellite does not have the resolution to see small leaks. However any of the larger leaks will be visible from satellites and will be corrected in a manner of days or
Assessing the Human Health Risks to Fugitive Airborne Ethylene Oxide Emissions
Benjamin Chandler
- GHD Services
Description
A recent study by the US EPA Integrated Risk Information System indicated and increased carcinogenic potential for community exposures to airborne Ethylene oxide (EtO) around facilities using EtO. The resulting changes to the EtO risk criteria by the US EPA have increased public scrutiny for EtO users to reduce emissions and ensure healthy conditions within neighboring communities. This presentation will focus on strategies for measuring ambient levels of EtO in outside air for the purpose of determining potential human health risks. Integrated air sampling methodologies will be discussed along with predictive air dispersion modeling capabilities and emission control solutions. A brief history of the EPA rule changes for Texas will also be presented as the basis for regulatory compliance.
Leak Detection and Repair (LDAR) is often an afterthought during the permitting phase of a project. Common issues include: underestimated counts of fugitive emission components (valves, flanges, etc.), application of LDAR program reduction efficiencies to components that aren’t monitored, overgeneralized stream compositions, and lack of design team knowledge with respect to LDAR requirements. Failure to address these issues can result in significant penalties, underscored by numerous consent decrees issued by EPA over the past few years. The presentation will discuss best practices to address these common issues based experience with permitting and LDAR program implementation at various facilities in the US.
Meeting Flare Emissions Regulations with BTU Measurement
Tom Watson
- AMETEK Process Instruments
Description
Learn how mass spectrometer technology can be used to meet emissions requirements by measuring BTU in the flare gas. This session will cover the methods of BTU determination, and will outline the advantages of a mass spectrometer analyzer - speed, accuracy, range, etc. - while discussing application specifics, and total cost of ownership and maintenance needs. There will also be a review of mass spectrometry technology, components, and functions.
Measurement & Speciation Using Mass Spectroscopy Flare Gas Composition
Chuck deCarlo
- Extrel Core Mass Spectrometers
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.
Baker Hughes is at the forefront of the next wave of smart and efficient energy technologies that help operators discover and produce oil and gas. Technology enabling the electrification of surface facilities and pressure pumping equipment offering significant potential for operational and efficiency gains.
What to Aggregate: Geographic and Temporal Considerations in Identifying Major Modifications
Eric Groten and Eric Hodek
- Vinson & Elkins and Ramboll
Description
Our presenters will discuss implications of defining your project, both spatially and temporally, for PSD permitting providing some information and insight on aggregation issues and strategies to facilitate project aggregation reviews.
The Clean Air Act imposes PSD preconstruction permitting requirements on new major sources or modifications at existing major sources. Determination of “major” in both of these contexts relies on defining the scope of your project, both spatially and temporally. With “aggregation” being informed by state and federal guidance, policy, and case interpretations, project reviews and roles have become quite complex and pose risk to project schedules and economics. This presentation will provide some information insight on aggregation issues and strategies to facilitate project aggregation reviews.
International Cross-Party Efforts to Improve Valve Reliability
Dave Anderson
- Score Valve
Description
Given the important role many automated valves have in reliably containing and manipulating process fluids flow where there are safety, environmental or efficiency implications, it is of critical importance to know that they are fit for purpose and capable of functioning correctly on demand. Furthermore, the control and automation of these operational valves must also have the best possible reliability to ensure zero in-service failures is achieved and maintained.
For these reasons, big efforts are being put into developing guidelines, technical reports and recommended practices by a wide range of technical experts worldwide, from the manufacturing, services and operating communities to achieve these goals.
This paper will highlight some of the ongoing work of the subject matter experts, technical standards committees and other collaborative working groups around the globe and what implications their work is likely to have on guiding the enhancement of automated valves reliability moving forward.
An overview of the work on design for reliability and operational asset management for reliability models will focus delegates’ attention on what controls and practices they currently have in place in their own organizations for valve specification, selection and management and what they may want to additionally implement moving forward, from the latest international publications / thinking.
New case studies from major oil and gas operating companies and the technical solutions they have deployed will be examined for effectiveness and compliance with the recommended best practices.
LUMEN Terrain - Continuous Ground-Based Digital Methane Monitoring
Myalee Muller
- Baker Hughes
Description
Launched in 2017, Avitas Systems is a Baker Hughes company focused on improving safety, protecting the environment, reducing asset downtime and decreasing overall inspection time and cost over traditional manual methods. To do so, Avitas Systems uses automated robotics and its suite of Artificial Intelligence software to accelerate inspections and provide applied intelligence to its customers, so that they can act on it rapidly, by accessing Avitas’s SaaS platform and optimizing their maintenance & repairs plans.
In the Permian, Avitas Systems uses drones to accelerate such well sites inspections data gathering, then processes images and videos with its AI-based Computer Vision algorithm to create useful risk-based reports to Oil & Gas operators. Our goal is to inspect hundreds of Permian well sites in one day, and report to each operators the next morning for their 7 am operation meeting, so they can not only better plan and prioritize their daily routes, but also take the necessary parts and tools required to maintain or repair identified equipment issues or failure.
Some of the critical inspection points are liquid or gas leaks, such as Fugitive Methane Emissions (“FME”), flares status and efficiency, advanced corrosion damage, overall equipment status (heaters, separators, scrubbers, pumps), tank volumetric, hazardous material, proper signage, solar panel position and overall well site operating conditions.
Learn more at www.avitas-systems.com
Current emissions monitoring techniques and technologies are unable to meet growing demands for FME inspections in a cost-effective or efficient manner. SeekOps enables responsible energy production through rapid, efficient, and cost-effective FME monitoring.
Avitas - LUMEN Sky - Aerial Drone-based Digital Methane Monitoring
Myalee Muller
- Baker Hughes
Description
Launched in 2017, Avitas Systems is a Baker Hughes company focused on improving safety, protecting the environment, reducing asset downtime and decreasing overall inspection time and cost over traditional manual methods. To do so, Avitas Systems uses automated robotics and its suite of Artificial Intelligence software to accelerate inspections and provide applied intelligence to its customers, so that they can act on it rapidly, by accessing Avitas’s SaaS platform and optimizing their maintenance & repairs plans.
In the Permian, Avitas Systems uses drones to accelerate such well sites inspections data gathering, then processes images and videos with its AI-based Computer Vision algorithm to create useful risk-based reports to Oil & Gas operators. Our goal is to inspect hundreds of Permian well sites in one day, and report to each operators the next morning for their 7 am operation meeting, so they can not only better plan and prioritize their daily routes, but also take the necessary parts and tools required to maintain or repair identified equipment issues or failure.
Some of the critical inspection points are liquid or gas leaks, such as Fugitive Methane Emissions (“FME”), flares status and efficiency, advanced corrosion damage, overall equipment status (heaters, separators, scrubbers, pumps), tank volumetric, hazardous material, proper signage, solar panel position and overall well site operating conditions.
HSE Buy-in, How to Give it, How to Get it, and How to Keep it.
Tom Hutchins
- Kinder Morgan
Description
We all have great ideas, but many fail to get accepted by management and others fail after initial implementation challenges.
Getting and keeping senior management buy-in and support are critical success factors for any project or program.
The presentation will provide insights into key elements of obtaining senior management buy-in and the keeping the support during the implementation and operations phases of projects.
Methane Emissions - Whatever you do… do something!
Scott Wallis
- Score Valve
Description
Touching on the impact that methane emissions have on companies, acknowledge that they will have some form of strategy in place for managing their emissions on their assets, cover these broadly but highlight improvement opportunities, concluding with an empowering message around best "current" practices.
Why Process Mass Spectrometry is an increasingly popular option for EPA BTU monitoring compliance. Reasons include speciation, high reliability and excellent linearity without needing carrier gas.
Lightweight, Modular OOOOa Certified OGI Camera Core for Handheld, UAV, or Fixed Mount CMS
Jeff Leake
- Sierra Olympic Technologies, Inc.
Description
The Ventus (OGI) camera core features a 640 x 512, 15-micron pixel-pitch, "Hot" midwave-infrared (MWIR) detector array providing unmatched thermal sensitivity and weighs only 580 grams (1.28 lbs.), with lens. Designed to optimize the detection and visualization of hydrocarbon gas leaks, such as methane, propane, butane, and 20 others. The “Hot-MWIR” Ventus OGI is a lightweight, low-power, camera core that can be integrated into gimbals/enclosures for manned or unmanned aerial system platforms or for fixed mounted continuous monitoring systems. Sierra-Olympic’s compact (146.6 mm x 70.9 mm x 73.1 mm/5.77 in x 2.70 in. x 2.88 in.) OGI camera features a special narrow bandpass cold filter in a miniature, long-life, closed-cycle Stirling cooler with an f/1.5 cold shield and an optimized, light weight, f/1.5, 25mm lens. State-of-the-art components including the detector, cooler, and lens design, combine with a selection of digital and analog inputs/outputs (Camera Link, H.264 IP Video, NTSC/PAL video plus RS-232/RS-422 serial camera control) to make this camera core an ideal optical gas imaging solution for integrators, OEMs and end users. Additional features include: a 32GB SD storage card, Contrast Limited Adaptive Histogram Equalization (CLAHE), Local Area Processing (LAP), Automatic Gain Control (AGC), Sharpening, DeNoise, Gas Enhancement Mode (GEM) and Electronic Image Stabilization (EIS). Optional items will include Target Tracking, Telemetry, NMEA and GPS i/o.
Satisfying RSR at Turndown - Clayton Francis - Zeeco, Inc.
Clayton Francis
- Zeeco, Inc.
Description
Nothing in plants must turn down like a flare. Lots of equipment achieve turndown rates 10:1, sophisticated transmitters might reach 1,000:1, yet a refinery flare can turn down 100,000:1. With the new rules applied, operators are experiencing unacceptable flame quality in this low range. Join a discussion on how those shortcomings were overcome.
You’ve Got PFAS. How to Prepare, Dispose and Respond
Ward Swanson
- Barr Engineering
Description
Per- and polyfluoroalkyl substances (PFAS) are emerging contaminants of concern in soil, groundwater and drinking water systems. PFAS releases have the potential to impact water supplies and are a challenge to capture and remove. Due to their chemical properties and widespread use, PFAS typically have multiple source areas and can be ubiquitous in most urban areas. For the oil and gas industry, their primary link and liability to the issue is through the training and use of Aqueous Film-Forming Foam (AFFF) concentrates.
Most refinery and fuels industry facilities have used AFFF either in training or for fire suppression for the simple fact that AFFF is extremely effective in putting out difficult fires and as a result it saves lives and prevents large scale fire damage. However, due to this use, most facilities likely have a PFAS signature associated with their AFFF releases that can touch multiple areas of their facility. This presentation will provide information on some tools and approaches from simple to complex on how a facility can identify what PFAS may be associated with their use and where it has migrated based on Barr’s nearly 20 years of PFAS investigation including case studies from refining and industrial sites. This presentation will discuss how to inventory current and legacy supply of AFFF containing PFAS and replacement and disposal options. Barr Engineering Co. will also discuss case studies for assisting terminal and refineries identify risks, respond to agency inquiries and prepare for emergency response situations based on our work which has included installation of emergency water treatment systems.
Attendees will leave the short presentation with an understanding of the complexity of the chemistry as well as an idea for approaches to audit current PFAS risk and prepare in the event of an emergency where these chemicals are used.
Facilities using pressure-assisted multi-point ground flares have requested Alternative Means of Emissions Limitations (AMELs) from the U.S. EPA to operate above the limits on exit velocity found in the General Provisions and Refinery Sector Rule. On October 9, 2019, the U.S. EPA proposed amendments to the Ethylene Maximum Achievable Control Technology (MACT) standards. These proposed changes include a new set of compliance requirements for ground flares without the need to request an AMEL. This presentation will review the new requirements for ground flares found in the Ethylene MACT draft rule. The presentation will also discuss how these proposed changes could affect ground flares in other sectors and the future of the AMEL process.
Passive Ultrasonic Imaging: a novel LDAR tool for gas leak detection and quantification
Florian Perrodin
- Distran Ltd
Description
Ultrasound as a leak detection method in Oil & Gas has been used with little success in the past due to its time consuming nature, and the heavy training requirements. Instead of using a single microphone, novel devices such as Distran Ultra Pro have a microphone array that produces acoustic pictures instead of playing sound like previous devices. Overlaid with an optical image in real-time, the user is able to instantly pinpoints the leaks in a radius of 30 feet. The technique allows additionally to quantify leakages rate in real-time. Advantages and limits of the technique will be presented.
Safety's Competitive Advantage and the Future of the Safety, Health, and Environmental Profession - Colin Brown - Board of Certified Safety Professionals
Colin Brown
- Board of Certified Safety Professionals
Description
Compliance with state and federal regulations is the absolute minimum and does not ensure the safety and health of workers. Safety and health in today's dynamic industry space must no longer be defined as the absence of harm and death. How do you turn safety into a competitive advantage, and what does the future hold for the profession entrusted with employee and customer well-being? This presentation highlights how professional development through accredited certification can change organizational culture and drive results through SH&E leadership.
Learning Objectives
Upon completion, the participant will be able to:
Describe why compliance is not enough to reduce injuries and loss in construction.
Recognize at least three ways that safety makes a company competitive.
Leverage training and certification to drive higher levels of safety and productivity.
Show how H&S is important not only for workers but also for front-line supervisors and executives.
New Technology with the Potential to eliminate PFAs and PFOAs from water sources
Ray Ozdemir, Jeff St. Amant
- Framergy Inc. & Vapor Point, LLC
Description
PFAs and PFOAs have generated significant public and environmental regulatory interest recently. While there do exist current treatment approaches, the options are limited. Vapor Point working with its partner Framergy, Inc have begun exploring the industrial usability of a new material science known as Metal Organic Frameworks. Through this partnership, we’ve performed lab and pilot scale testing of various technologies important to our industry including absorption of light hydrocarbons from atmospheric emissions, separation of light hydrocarbons, capture of H2S from vapor and aqueous phase sources and absorption of contaminates in waste waters.
This presentation will review the developments of this new material science for the capture and destruction of PFAs and PFOAs. We will review our current progress as part of our current EPA SBIR Grant, focused on elimination of the contaminates from drinking water supplies.
New Flare Requirements within the Ethylene, MON, and OLD MACTs
Herman Holm
- Spectrum Environmental Solutions, LLC
Description
Regulations requiring improved monitoring and control of flares at petroleum refineries are starting to be passed along to other manufacturing sectors. In October 2019, the U.S. EPA proposed amendments to the Generic Maximum Achievable Control Technology Standards for Ethylene Production (EMACT). Among those amendments are new monitoring and operational requirements related to flares at ethylene production facilities. Also, in recent months, the U.S. EPA has published draft rules affecting organic liquid distribution (OLD) operations and portions of the chemical sector. These requirements are found in what are commonly referred to as the OLD MACT and Miscellaneous Organic NESHAP (MON). This presentation will summarize the new flare requirements and will draw heavily on the lessons learned from implementing the similar flare requirements in the refining sector.
Innovative Sampling and Analysis Techniques for Stack Sampling of PFAS Compounds in Air Emissions from Stationary Sources
Wesley Fritz
- Weston Solutions, Inc.
Description
As air emissions come under heightened focus as a potential PFAS exposure pathway, the need for accurate and defensible PFAS emissions testing data is necessary. This presentation will discuss the derivation of the modified methods developed for the stack emissions sampling and analysis and the results and findings from this work.
Steve Hall
- Spectrum Environmental Solutions, LLC
Description
Reducing emissions of ethylene oxide has recently become a focus of U.S. EPA following revised risk assessments for the compound. On November 11, 2019, the U.S. EPA released a pre-publication version of proposed amendments to the Miscellaneous Organic NESHAP (MON). The MON amendments include new monitoring and testing requirements for control devices used to control ethylene oxide emissions. Part of these new requirements include continuous monitoring of ethylene oxide concentrations using Fourier Transform Infrared (FTIR) Continuous Emissions Monitoring System (CEMS) for control devices other than a flare. This presentation will describe how FTIR can be used to monitor ethylene oxide and elaborate on the continuous ethylene oxide monitoring requirements found in the MON.
Using Smart Meter Verification to Digitally Transform Environmental Reporting
Meha Jha
- 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. 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.
Intro to EMACT, OLD, HON, and MON Compliance Gases- Take-aways from RSR Experience
Andy Shurtleff
- Airgas
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.
SPOD: Continuous VOC Monitoring for Targeted Grab Sample Acquisition
Jacob Melby
- SENSIT Technologies
Description
The SENSIT® SPOD is solar-powered fenceline monitoring system for VOCs. This low-powered, easily deployable system combines wind and VOC measurements to identify and locate emission sources in real-time. When combined with the highly configurable sample acquisition system, the SENSIT SPOD can enable targeted grab sampling using evacuated canisters or sorption tubes for later laboratory VOC analysis.
Utilizing Temporary Control Systems to Meet Recent EPA MACT Subpart CC and to Eliminate Flare Gas Recovery Bottlenecks During Maintenance and Turn-Around Activities
Jim Woodard, Sean Kirkpatrick
- Vapor Point, LLC
Description
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.
This has resulted in FGR becoming a bottleneck to operators’ ability to deinventory and decontaminate units for maintenance activities, resulting in additional costs in meeting these new standards. Vapor Point has successfully implemented temporary liquid and vapor phase management systems to minimize these impacts, helping operators maintain schedule while reducing cost impacts.
This paper/presentation will be focused on how the deployment of mobile technologies can help operators reduce and potentially improve operational execution/efficiency, if implemented correctly.
The Brave New World of Renewable Fuels Projects – A Permitting Perspective
Bart Leininger, P.E.
- Ashworth Leininger Group (ALG)
Description
More and more facilities are considering projects to add renewable fuel sources to their mix of product offerings. Some of these projects are mandated by federal and state laws; other projects are pursued to take advantage of the tax and other credits available for producers of low carbon fuels. Renewable fuels projects have introduced a host of permitting issues, many of which are not understood by local and state regulators. This presentation provides helpful insights on the permitting process, and provides recommendations to streamline the process. The presentation leverages experiences in permitting a variety of renewable fuels projects.
Comprehensive CEMS Stack 102: Process Optimization
Dean Kotecki
- Envea
Description
Continuous monitoring instruments for bag–house filter performance control, bag leak detectors, flue gas & solid flow moisture monitoring, level detection, reagent injection control, etc. allowing the optimization of your processes: raw material & energy savings, reduction of environmental impacts.
California Rule 1180 Fence Line Monitoring Regulation: Lessons Learned and planning for Regulatory Compliance
Gilad Shpitzer
- Atmosfir Optics Ltd.
Description
Atmosfir Optics, Ltd, will discuss California’s South Coast’s Air Quality Measurement Division’s Rule 1180 fence-line monitoring requirements, how they came into existence, where they protect public health, and where there are inconsistencies as applied to known risk levels. We will discuss cost effective ways to apply advanced technology that can quickly adapt to potential upcoming requirements from other regulators that may use this rule as a model. Lessons learned from supporting a refinery’s response will be presented.
Optical Flow Sensors for Environmental Compliance and Process Control
Donn Williams
- Optical Scientific
Description
OSI's Optical Flow Sensor (OFS) can help you comply with EPA’s Organic Liquids Distribution MACT, RSR and Ja regulations. Unaffected by temperature, pressure, density or gas concentration, OFS makes drift-free flow measurements on flare stacks, thermal oxidizers and a host of similar routine and extreme processes alike with no shutdown needed to install.
Opening Up the Opportunities for Performance Verification and Reliability Enhancement of Valves
Dave Anderson
- Score Valves
Description
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.
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.
Isn’t It Ironic? A Case Study On Dry Seal vs. Wet Seal Centrifugal Compressor Emissions
Brandon Mogan
- Montrose
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”.
After years of close coordination, the Federal Aviation Administration (FAA) and Departments of Defense, Energy, Justice, and Homeland Security (DOD, DOE, DOJ, and DHS) obtained congressional relief in order to test, operate, and evaluate systems that detect and mitigate unmanned aircraft systems (UAS) in the United States. The National Defense Authorization Acts of 2017 and 2018 granted the DOD and DOE counter-UAS (C-UAS) authorities in 2018 the FAA Reauthorization Act provided DHS and DOJ with their authorities. FAA also received authority in the FAA Reauthorization Act of 2018 to employ CUAS, for test and evaluation. The Act became Pub. L. 115-254 and amends Titles 46 (Domestic Security), 14 (United States Coast Guard), and 49 (Transportation) Preventing Emerging Threats Act of 2018 (“the Act”) authorizing the DHS and DOJ to engage in certain C-UAS activities, notwithstanding provisions of Title 18 and Title 49 that prohibit the interception of communications and interference with aircraft. The Act authorizes DHS and DOJ to conduct C-UAS activities against unmanned aircraft systems (UAS) that poses a credible threat to the safety or security of a “covered facility or asset,” as defined by the Act.
Cyber threats collectively now exceed the danger of physical attacks against us. This is a major sea change for my department and for our country’s security.
Ray Ozdemir and Jeff St. Amant
- Framergy Inc. & Vapor Point, LLC
Description
"While technology focus in our industry has been centered on automation and monitoring capabilities, little new science has been developed. Vapor Point working with its partner framergy, Inc have begun exploring the industrial usability of a new material science known as Metal Organic Frameworks. Through this partnership, we’ve performed lab and pilot scale testing of various technologies important to our industry including absorption of light hydrocarbons from atmospheric emissions, separation of light hydrocarbons, capture of H2S from vapor and aqueous phase sources and absorption of contaminates in waste waters.
This presentation will review the developments of this new material science for the absorption and reuse of captured VOCs from otherwise atmospheric emissions. We will review our current progress as part of our current EPA SBIR Grant, focused on absorption of light VOCs not easily managed with Activated Carbon.
"
Utilizing Vapor Lock Technology for Tank Degassing and Tank Vent Management versus Thermal Destruction or Activated Carbon
Jim Woodard, Jeff St. Amant
- Vapor Point, LLC
Description
State and Local Agency actions have added emphasis to the management of emissions from large API 650 storage tanks, as a result of regulatory action and/or public engagement. In the US most API 650 storage tanks, which are in a service where there is a potential for VOC emissions, have been outfitted with internal floating roofs, which are considered by the EPA as BACT. Historically, tank owners have had requirements for controlling emissions from tanks when existing tank attachments have malfunctioned, or when the tank is being prepared for maintenance activities. Thermal destruction devices are the most commonly used control technologies for managing tank emissions, but they may not be the most efficient or effective.
This presentation will review the development of a new Vapor Lock technology for the management of tank emissions during degassing and cleaning operations, demonstrating improved operational performance, while reducing cost impacts to clients.
New Technology for the Removal of Sulfur Compounds from Hydrocarbon Products, Helping Combat Economic Strains Caused by Tier II and III Sulfur Credits
Jeff St. Amant
- Vapor Point, LLC
Description
While technology focus in our industry has been centered on automation and monitoring capabilities, little new science has developed in meeting the challenges that high sulfur oil and gas production has brought with it. Vapor Point and its partnership with Baker Hughes has developed new mobile technologies focused on helping clients mitigate quality issues with hydrocarbon feedstocks and products. In addition to this new mobile deployment, Vapor Point has created new chemistries capable of extracting sulfur species such as butyl mercaptan, which cannot be managed with amines or other specialty chemical technologies.
This presentation will discuss existing applications where Vapor Point has assisted clients with improving the quality of both feedstocks and saleable fuels by removing unwanted sulfur contamination such as Hydrogen Sulfide, Methyl Mercaptan, Ethyl Mercaptan, Propyl Mercaptan and Butyl Mercaptan.
Recent Spectrum laboratory results using only the standard MCT detector have yielded the conclusion that a 5 m cell could NOT provide low enough detection to meet the EPA reporting limit (data concentration >= 3X standard deviation of data collection). However, all of FTIR manufacturer B systems are 5 m cell systems and further, Manufacturer B does not have the option for using an alternative detector.
Spectrum provided a 10 and 29 m cell, and data indicates no difficulty meeting a reporting limit below the regulatory threshold, even below ~15 ppbvd concentrations.
Recent data resulting from the alternative detector on FTIR A devices pushed the standard deviation low enough that Spectrum could detect and report data < 27 ppb (at <3*S.D.) in a small 5 m cell. With this short cell, Spectrum demonstrated detection of formaldehyde concentrations of 12 ppbvd with a SD of 4 ppb. This early data set was taken at 3-minute time averages. Future studies will be increased to 5-minute averaging that should take the 0.004 SD to sqrt(3/5)*0.004 = 0.003 ppb.
Future field validations may be performed with EPRI to demonstrate even lower detection limits using Spectrum’s standard 10 m cell and its new detector arrangement. Spectrum anticipates these future results to demonstrate a DL less than 5 ppbvd, and these results will be shared shortly.
Taking Advantage of the Audit Privilege When Performing EH&S Compliance Assessments
Joel LeBlanc, P.E.
- Ashworth Leininger Group (ALG)
Description
In recent months, the Oklahoma Department of Environmental Quality made effective the Oklahoma Environmental, Health and Safety Audit Privilege Act, which is available to aircraft manufacturing, chemicals, oil and gas processing, plastics, cement, food and meat processing, and paper products. This is a continuation of a national trend towards immunity from civil and administrative penalties for regulated entities that perform voluntary EHS audits and then remedy and disclose any discovered violations. This presentation will discuss which certain key requirements that must be met to qualify for immunity and compare Oklahoma’s Audit Privilege Act to the 2017 revision of the Texas Act.
Large Area Fugitive Emission Monitoring in All Conditions - Laser Dispersion Spectroscopy
Dr. Sophie Purser
- Mirico
Description
MIRICO’s technology is designed to continuously and autonomously measure total facility methane emission rates, as well as detect, localise and quantify fugitive emissions. We will present data exemplifying the use of the technology in adverse weather conditions with no reduction in performance. It is the use of the novel laser dispersion spectroscopy technique which allows the instrument to output such accurate, precise and reliable measurements, even in rain, snow, or fog.
EPA’s New Accident Prevention Program Implementation and Other Regulatory Reforms to Expect Before the Election
Shannon Broome
- Hunton, Andrews, Kurth
Description
One of the hallmarks of the Trump Administration’s regulatory reform efforts has been its partial reversal and reconsideration of the US EPA’s chemical accident prevention provisions, which were finalized in December 2019. EPA has also recently reformed several aspects of Clean Air Act permitting that are vitally important to petroleum, chemical, and other manufacturing companies. What does the future hold for these reforms and how have they delivered on the promise of a win/win situation for the regulated community and environmental benefits?
Conforming to ASTM-D7036: Self-Declaration vs. Third-Party Accreditation
David Fricker
- A2LA
Description
Confidence in test data is paramount to acceptance, and both users and customers want assurance of quality. In general, testing bodies that choose accreditation rather than self-declaration demand a higher quality of work to maintain that accreditation and strive to produce more reliable results. In turn, customers have greater confidence in the accuracy and validity of the data from these testing bodies. Accreditation also provides the industry with confidence that a testing body is subject to regular oversight as a motivator to continually improve their operations. The ongoing verification of compliance ensures that the testing body’s results are consistently dependable and defensible.
Live Demo: Improving Sample Probe, Chiller, and Filter Performance
Donny Klotz
- M&C TechGroup North America
Description
Live demonstration to teach the audience about the many ways in which various Continuous Emissions Monitoring System components can be improved, optimized and properly specified for various applications. We'll discuss sample transport and conditioning considerations associated with extractive probe configurations, gas chiller options, filtration materials and temperature controls, and help end-users identify and overcome common CEMS challenges.
Satellite-based Hyperspectral Analysis for Emissions Detection, Integrity Monitoring and Compliance
Peter Weaver
- Orbital Sidekick
Description
Analysis of hyperspectral imagery (HSI), collected by micro-satellite, is poised to provide unparalleled global daily leak and emissions detection capability for the chemical, oil and gas industries. Space-based HSI offers an ability to directly find leaks, detect threatening construction activity, identify physical changes to soil and vegetation caused by leaked product, and even distinguish between specific hydrocarbon liquids or vapors. In this presentation, OSK will discuss the state-of-the-art for using HSI to detect fugitive emissions. It will provide examples of inspection findings using Spectral IntelligenceTM. And, it will provide insight on how HSI can improve the operator’s ability to cost-effectively understand the conditions at and around their assets.
DHS CISA Stakeholder Engagement Strategy – Regional Service Delivery Model
Michael Dailey
- Department of Homeland Security
Description
Regional Offices could identify organizations that have not traditionally served as members of CISA-led sectors to further inform risk mitigation solutions by focusing on sector-specific regional issues. The resulting regional-level networks would directly expand CISA's reach into multiple stakeholder segments. Creating a “one-stop shop” at the regional level for issues associated with CISA-led sectors would significantly enhance customer experience. Regional-level collaboration mechanisms (discussion forums, roundtables, and workshops) would enhance knowledge transfer among public and private sector stakeholders through discussions tailored to the regional landscape.
Digital Camera Visible Emissions Method (Alternative Method 082) in lieu of Method 9 for Visible Emissions
Shawn Dolan
- 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.
Large Area Fugitive Emission Monitoring in All Conditions - Laser Dispersion Spectroscopy
Dr. Sophie Purser
- MIRICO
Description
MIRICO’s technology is designed to continuously and autonomously measure total facility methane emission rates, as well as detect, localise and quantify fugitive emissions. We will present data exemplifying the use of the technology in adverse weather conditions with no reduction in performance. It is the use of the novel laser dispersion spectroscopy technique which allows the instrument to output such accurate, precise and reliable measurements, even in rain, snow, or fog.
Uzi Ibrahim, Michael Quiroga, Michael Lichko
- 4C Marketplace, Asylon
Description
A roundtable giving an overview of Counter UAS, Regulatory Framework, Presentation/Response Planning and a Primer on Radar and Radio Frequency Detection Systems Strategies
Counter UAS Discussion
An introduction into what Counter UAS means, the different components of it as well as the difference between detection and mitigation
Prevention: Doing a Threat Assessment of your Facility’s Airspace
Detection: Various Systems and how to use them
Observation Without Limits
An introduction in Ground and Aerial Radars
Aerial Armor and the Benefits
An introduction in RF Based Detection
From its inception nearly 15 years ago, Optical Gas Imaging (OGI) has steadily evolved from being classified as a little-known emerging technology to now being a well-understood and accepted fugitive emission solution. OGI has advanced beyond the classification of “alternative” regulatory technology to being widely accepted and regarded as one of the most cost-effective approaches for leak detection. OGI is even listed as a Best System for Emissions Reduction (BSER) in the 2016 NSPS OOOOa regulation. True cost-effectiveness has been shown in OGI’s ability to safely inspect difficult to monitor components, which have historically added to inspection man-hours and equipment expense, such as those required to build scaffolding or use personnel lift equipment. OGI has also been shown to reduce costs by allowing more components to be inspected in a shorter amount of time, effectively helping to find the larger (long-tail) leaks faster. Once known only as a qualitative leak detection technique, OGI can now quantify leaks via Quantitative Optical Gas Imaging (qOGI) analysis which further simplifies the visualization and measurement of gas emissions. Newer, lower-cost OGI detectors now allow for cost-effective continuous, autonomous leak detection complete with alarming and recording capabilities. Other advancements in OGI detectors have reduced power requirements which allow them to be used in UAV payloads where miles of pipe or other difficult to monitor components and equipment can be quickly and safely inspected. This paper will give more detail and insight into the progression and evolution of this exciting technology.
Autonomous Security Programs: Building Autonomous Infrastructure and Use Cases for Automation
Uzi Ibrahim, Michael Quiroga, Michael Lichko
- 4C Marketplace, Asylon
Description
The Crawl, Walk, Run progression from zero to Autonomous UAVs flying around your facility:
People
Training and Certifications
Programs
Assigning Roles and Responsibilities
Policy
Interfacing with the FAA
Use Case for Automation
An introduction into Autonomous Security Design, and the potential Environmental benefits of Autonomous Infrastructure.
Use Cases to be discussed are as follows:
Security
Emergency Management
Environmental
Industrial Hygiene and Liability Mitigation
A New Era of LDAR in Texas: Industries Can Now Use OGI in Lieu of Method 21 to Meet “28” Series LDAR Requirements
Brandon Morgan
- Tora Consulting
Description
Last year, Tora Consulting, LLC (Tora) obtained the first ever approval in Texas for the use of optical gas imaging (OGI) technology as an alternative to the Method 21 monitoring requirements of TCEQ’s “28” series boilerplate leak detection and repair (LDAR) programs (e.g., 28MID, 28VHP, etc.). The approval was a milestone, paving the way for others in Texas to implement a more efficient, effective, and economical OGI-based LDAR program. The presentation will discuss Tora’s approach for negotiating the approval, summarize the OGI-based LDAR program, and provide an overview of important permitting considerations for those interested in making the change.
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.
I got 99 problems… now what? Best Practices for Addressing Audit Findings
Courtney Edge
- Trinity Consultants
Description
Conducting a gap assessment or audit is a great starting point for getting your LDAR program into compliance – but that’s only the first of many steps. After findings, observations, and recommendations are identified, corrective actions must be developed and prioritized appropriately. Depending on the scope and number of identified issues, this can be a daunting task but there are ways to manage the stress and work load accordingly. This presentation will cover what to do after the completion of an audit or gap assessment of your LDAR program.
Utilizing Temporary Control Systems to Meet Recent EPA MACT Subpart CC and to Eliminate Flare Gas Recovery Bottlenecks During Maintenance and Turn-Around Activities
Jim Woodard, Sean Kirkpatrick
- Vapor Point, LLC
Description
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.
This has resulted in FGR becoming a bottleneck to operators’ ability to deinventory and decontaminate units for maintenance activities, resulting in additional costs in meeting these new standards. Vapor Point has successfully implemented temporary liquid and vapor phase management systems to minimize these impacts, helping operators maintain schedule while reducing cost impacts.
This paper/presentation will be focused on how the deployment of mobile technologies can help operators reduce and potentially improve operational execution/efficiency, if implemented correctly.
Steven Shedd, Shawn Perceful, Ann Ratliff
- Department of Homeland Security
Description
CFATS 101 - CFATS is the Nation’s first regulatory program focused specifically on security at high-risk chemical facilities. The Cybersecurity and Infrastructure Security Agency (CISA) manages the CFATS program by working with facilities to ensure they have security measures in place to reduce the risks associated with certain hazardous chemicals, and prevent them from being exploited in a terrorist attack
EPA is proposing multiple Risk and Technology (RTR) rules in 2019 that will affect the chemical and petrochemical industries, including the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Miscellaneous Organic Chemical Manufacturing (MON), Organic Liquids Distribution (OLD), Ethylene Production, and Stationary Combustion Turbines. This presentation will review changes EPA is proposing to make to various NESHAP as a result of their risk reviews, technology reviews, or in response to past court decisions. These changes affect startup and shutdown, stringency of the standards, maintenance procedures, monitoring, and reporting. We will highlight proposed changes that are similar to the Refinery Sector Rule, changes that increase stringency of standards for ethylene oxide emission sources, and where various chemical and petrochemical sector rules will now have slightly different requirements. The presentation will also discuss industry comments submitted to EPA on the major proposed changes.
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