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LDAR / Fugitive Emissions Prevention

The Future Technology of LDAR

Joshua Pinter - CNTRAL Inc.

Description

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

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Environmental Legal

Environmental Enforcement Developments in the Trump Administration

Matt Thurlow - Baker & Hostetler LLP

Description

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

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Air Permitting

A False Sense of Security - Shifts in EPA’s Implementation of PSD Capable of Accommodating Determination and The Demand Growth Exclusion

Everard Ashworth - Ashworth Leininger Group

Description

The 2002 NSR Reforms provided additional flexibility to exclude emissions from existing operations; however, EPA provided little guidance as to how this emissions calculus is to be performed. Come hear the insight gained by the presenter during recent experience in performing a complex and detailed PSD applicability evaluation in the context of utilizing the Demand Growth Exclusion.

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Environmental Legal

The Regulation of Oil & Gas Activities Under the Trump Administration

John B. King - Breazeale, Sachse & Wilson LLP

Description

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

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Flares for Regulatory Compliance

Eliminating H2S & SO2 Emissions at SRU, Coker and Other Sulfur Handling Units of Refineries

Sean Kirkpatrick - Vapor Point, LLC

Description

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

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BWON

Downstream Confirmation of Benzene Loading

Bruce Douglas - Trinity Consultants

Description

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

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LDAR / Fugitive Emissions Prevention

Is There A Better Way to Do LDAR?

Brian Whitley - Emission Monitoring Service, Inc. (EMSI)

Description

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

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LDAR / Fugitive Emissions Prevention

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.

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EHS Best Management Practices

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.

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CEMS

Common CEMS Program Audit Findings

Eric Wiley - VIM Technologies

Description

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.

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Flares for Regulatory Compliance

“4G” Combustion Technology for Flares

Chris Ferguson - Honeywell

Description

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

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LDAR / Fugitive Emissions Prevention

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

Jon Morris - Providence Photonics

Description

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

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LDAR / Fugitive Emissions Prevention

Evaluation of Innovative Methane Detection Technologies

Tim Taylor - Colorado Air Pollution Control Division

Description

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

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CEMS

CEMS Lessons Learned

Ty Smith - Cemtek Group Inc.

Description

CEMTEK KVB-Enertec is a System Integrator and full service organization that builds & supports continuous emissions monitoring systems (CEMS) to meet EPA 40 CFR Part 60, 64, & 75 regulatory requirements and process control monitoring systems on a variety of applications and sources including chemical, cement, glass, refinery, power, biomass, paper, and many others. In this paper we will discuss lessons learned when testing, purchasing and deploying new monitoring technologies to measure NOx, SO2, CO, HCl, NH3, H2S, HF, HCN using lasers & DOAS compared to conventional technologies ranging from Dry Extractive, Dilution, Hot Wet, and In-situ for compliance and process monitoring.

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EHS Best Management Practices

Acoustic Condensate Stabilization

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.

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BWON

On-Going BWON Compliance Concerns

Ken Garing - Ken Garing & Associates

Description

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

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CEMS

Common CEMS RATA Failures and Risks

Paula Metz - Alliance Source Testing

Description

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

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CEMS

Simplifying CEM Reporting:The Revolution in Data Acquisition & Handling

Brian Fowler - ESC

Description

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

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Environmental Legal

Federal, State and Local Enforcement

James Smith - Crain, Caton, & James

Description

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

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EHS Emerging Technologies

How IoT and Blockchain Technology Can Transform Environmental Monitoring

Phillip Black - Wood Group

Description

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

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Flares Instrument Analyzers and Sensors

On-line GC Solution to Comply with Flare Measurement Requirements

Ulrich Gokeler - Siemens Industry

Description

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

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EHS Best Management Practices

EcoVapors Recovery Systems - Flare LESS Profit MORE

Michael J. McMahon - EcoVapors Recovery Systems

Description

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

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Air Permitting

EPA NSR Reforms: How to Capitalize Now and Later

Kristin Gordon - ALL4 Inc.

Description

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

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LDAR / Fugitive Emissions Prevention

Understanding Cooled vs Uncooled Optical Gas Imaging

Ron Lucier and Craig O’Neill - FLIR

Description

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

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EHS Best Management Practices

Contractor Management

Ric Hartung - Process & Safety Solutions LLC

Description

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

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EHS Emerging Technologies

Case Study: California Refinery Achieves 5ppm cNOx with DuplexTM Technology

Venkatesh Iyer - ClearSign Combustion

Description

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

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Fenceline Monitoring

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

Don Gamiles - Argos Scientific Inc.

Description

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

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LDAR / Fugitive Emissions Prevention

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.)

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Oil & Gas

Design & Operation Guidelines for Low Heater Emissions

Erwin Platvoet - XRG Technologies, LLC

Description

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

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Oil & Gas

Status/Updates on NSPS OOOOa

Karen Marsh - US EPA

Description

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

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BWON

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

Sean Kirkpatrick - Vapor Point, LLC

Description

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

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Oil & Gas

Oil and Gas Enforcement and Compliance Monitoring Update

Natalie Topinka & Kosta Loukeris - EPA

Description

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

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Chemical

Emerging Trends in Owner Compliance

George Perrett - Industrial Safety Training Council (ISTC)

Description

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

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Air Permitting

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

Frank Dougherty - ALL4 Inc.

Description

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

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Environmental Legal

What’s Happening on RMP and PSM in the Courts and in the Trump Administration? Will the Rule Stay Delayed or Should Companies Prepare to Comply with the New RMP Rule Now?

Shannon S.Broome - Hunton & Williams, LLP

Description

In the waning days of the Obama Administration, EPA’s Office of Land and Emergency Management issued a set of sweeping and controversial regulations to “modernize” the Risk Management Plan (RMP) program. The new administration has delayed these rules while considering revisions. This presentation will review the upcoming requirements if they go into effect and the litigation of the rules and the delay rule, on which oral argument is being held in the U.S. Court of Appeals for the D.C. Circuit on March 16, 2018. It will recommend steps companies can take to be ready if the rules go into effect soon and provide predictions on what might be proposed as revisions to the Obama regulation.

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Air Permitting

Ethylene RTR, What’s the Outlook?

Britney Head - ExxonMobil

Description

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.

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CEMS

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

Justin Sullivan - Alliance Source Testing

Description

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

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LDAR / Fugitive Emissions Prevention

Back from the Future

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.

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Air Permitting

Upstream Oil & Gas Air Permitting 101

Adrienne Rosecrans - Ashworth Leininger Group

Description

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

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Flares for Regulatory Compliance

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.

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EHS Emerging Technologies

How Digital Transformation Can Impact Compliance for Environmental and Safety Regulation

Marcio Donnangelo & Julie Valentine - Emerson Automation Solutions

Description

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

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Flares Instrument Analyzers and Sensors

Does CZNHV Track Flare Performance?

Yousheng Zeng - Providence

Description

The new Refinery Sector Rule (RSR) promulgated on December 1, 2015 requires facilities to continuously monitor Combustion Zone Net Heating Value (CZNHV) and flare tip velocity as a way to ensure high combustion efficiency (CE) and destruction efficiency (DE) of flares. The deadline for complying with these new requirements will be January 30, 2019. An experiment has been conducted on a steam assisted flare and an air assisted flare to evaluate CE under various vent gas and steam/air assist conditions with varying CZNHV and flare tip velocities. The CE was measured by both extractive sampling method and a new remote and continuous flare CE monitoring method – Video Imaging Spectro-Radiometry (VISR). The CE measured by both methods were examined along with the associatedCZNHV. The results show that high flare CE can be achieved with low CZNHV, much lower than the regulatory limits established in the RSR. The effectiveness of CZNHV as a suitable surrogate parameter for flare CE is examined within the regulatory context of the RSR regulations.

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Air Permitting

Calculating Project Increases

Johnny Vermillion - Spirit Environmental

Description

Coming soon.

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Air Permitting

Air Quality Tools for the 21st Century

Robert Opiela - NaviKnow

Description

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.

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BWON

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.

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Environmental Legal

New Developments in Environmental Enforcement

Carrick Brooke-Davidson - Vinson & Elkins

Description

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

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Air Permitting

RTR Update

Britney Head - ExxonMobil

Description

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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Air Permitting

Optimizing NG Compressor Station Permitting

Joel LeBlanc - Ashworth Leininger Group

Description

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

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Oil & Gas

Upstream Oil & Gas Emissions Inventory Calculations

Danielle Nesvacil - TCEQ

Description

Coming soon.

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Air Permitting

Once in, Not Always In

Nicholas Petrich - Barr Engineering

Description

The EPA issued new guidance that repealed the “once in, always in” policy, allowing reclassification of a major source of hazardous air pollutants (HAPs) to an area source. Therefore, a major source that obtains federally enforceable limits on its HAP potential-to-emit below the major source thresholds can become an area source. This presentation will provide guidance on how and why a facility can become an area source, including the benefits and challenges. A regulatory overview will be provided, including the common major source standards that would no longer apply, the potentially applicable area source requirements, and why some requirements won’t go away even after reclassification. Also, a technical review will include the critical factors for refining site-specific HAP emissions.

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Air Permitting

New Building Downwash Options in AERMOD

Sergio Guerra - GHD Services

Description

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.

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Flares for Regulatory Compliance

The Final Flare Requirements – Latest Update on the Refinery Sector Flare Rule

Troy Boley - Spectrum Environmental Solutions, LLC

Description

The experts at Spectrum Environmental Solutions, LLC (Spectrum) have been involved with a wide variety of industrial flare related issues within the petroleum and petrochemical related industry sectors. This presentation will lay a solid foundation for the rest of the conference presentation day as Spectrum will highlights the recent Federal flare rules specifically promulgated for the petroleum refinery sector. The intent will also be to provide the attendees with an understanding of the most likely flare improvement requirements anticipated by industry within future rulemaking for ethylene and chemical facility flares.

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LDAR / Fugitive Emissions Prevention

Data Analysis and How it can Improve your LDAR Program

Derrick Mauk - Bureau Veritas

Description

1. What data can be analyzed? – A discussion of all LDAR data that is collected and what can be mined. 2. What data should be analyzed? – A discussion of what LDAR data should we be looking and paying attention to. 3. How do you perform data analysis? – Methods of how to mine through the Hundreds of Thousands of LDAR Data points. 4. Proactive Data Mining for Compliance. – How proactive data mining can prevent compliance issues? 5. Data Analysis to improve productivity. – How to insure good productivity. How to prevent bad productivity. 6. How can proactive data analysis can improve Inventory Projects? - Discussion on how performing data analysis on inventory projects can provide more accurate data.

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Chemical

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.

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PFAS

A Practitioner’s Guide to PFAS – Lessons learned and best practices to ensure project efficiency and desired outcomes

Tiffany Thomas - EnSafe

Description

Coming soon.

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Environmental Legal

It's Not Dead, It's Mostly Dead - CD Termination

Suzanne Murray - HaynesBoone

Description

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.

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Fenceline Monitoring

New and Emerging Fenceline Monitoring Technologies

Peter Zemek - Montrose Environmental

Description

Coming soon.

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Flares Instrument Analyzers and Sensors

Flare Guardian Project

Clayton Francis - Zeeco

Description

Eliminate the inaccuracies and delayed results inherent to indirect flare monitoring. Directly monitors flare performance in real-time rather than determining compliance and combustion efficiency through a time-consuming, repetitive process of measuring inputs, assuming reactions and velocities, and arriving at an assumed operating status.

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Flares Instrument Analyzers and Sensors

Flare System Control and Optimization at Refineries and Chemical Plants

Dan Johnson - 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.

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Flares Instrument Analyzers and Sensors

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.

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Flares Instrument Analyzers and Sensors

Ultrasonic Flowmeters Meeting the Flare Flow Measurement Challenges for Steam, Fuel Gas & Waste Gas Measurement

Dr. Lei Sui - Baker Hughes

Description

Coming soon.

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Flares for Regulatory Compliance

The Proposed Flare Requirements of Ethylene MACT – Latest Update

Troy Boley - Spectrum Environmental Solutions

Description

Coming soon.

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EHS Emerging Technologies

LUMEN Terrain - Continuous Ground-Based Digital Methane Monitoring

Dan Johnson - Baker Hughes GE

Description

Coming soon.

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Oil & Gas

GHGSat, Methane Detection using Satellites

Stephanie Germain - GHGSat

Description

Coming soon.

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EHS Emerging Technologies

LUMEN Sky - Aerial Drone-Based Digital Methane Monitoring

Dan Johnson - Baker Hughes

Description

Coming soon.

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Oil & Gas

HSE Buy-in, How to Get it and How to Give 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.

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EHS Best Management Practices

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”.

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Launching and Receiving

Launcher and Receiver Consent Decree

Rob McHale - MPLX G&P, Jake Fournier - Marathon -

Description

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.

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Environmental Legal

Using Police Investigations Process for Industrial Accident Scenes

Keith Farrell -

Description

Whether an event was an accident or an incident, the potential to have its ultimate conclusion in civil, state, or federal court is a realistic probability.  All information and evidence gathered from the event scene is used to support the corporation investigator’s testimony and to represent the corporation’s position in legal proceedings.  Thus, investigators are required to present their information and evidence in an acceptable manner for a court of law.  This presentation will highlight the requirements of collection documentation and chain of custody procedures as applied to industrial incident scenes.

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Environmental Legal

Double Trouble: An Update on General Duty Obligations

Paul Seals - Guida, Slavich & Flores

Description

Owners and operators of petroleum refineries are subject to General Duty obligations under the Clean Air Act (“CAA”). These duties are specified in theAccidental Release Preventions rules at 40 C.F.R. Part 68, which implement CAASection 112(r), as well as obligations under New Source Performance Standards(“NSPS”) at 40 C.F.R. Part 60 and Maximum Achievable Control Technologies(“MACT”) under national emission standards for hazardous air pollutants(“NESHAP”) at 40 C.F.R Part 63. The General Duty obligations are aimed at hazardous substance accident prevention through the development of risk management planning (“RMP”) and the observance of “good air pollution control practices” during periods of startup, shutdown, and malfunction (“SSM”).This session will present recent developments regarding RMP, includingEPA’s March 2016 proposal to amend the RMP rule and EPA’s enforcement initiatives focused on reducing accidental releases at industrial and chemical facilities, including petroleum refineries. Through these enforcement cases, EPA is attempting to encourage the early adoption of Next Gen Enforcement components, including the use of third-party audits as proposed in the RMP rulemaking. The second half of this session will also focus on the General Duty obligations in NSPS and MACT requirements. Specifically, the new RefiningSector Rule has made significant changes to SSM requirements in MACT,Subparts CC and UUU. How do General Duty obligations come into play based on the new SSM requirements and potential enforcement actions relating to SSM?What potential benefits may refiners obtain from an evaluation and potential revision of current refinery programs for compliance with these General Duty obligations?

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BWON

Benzene Waste Operations NESHAP In the FLIR Age

Calvin Niss - Trihydro

Description

By now, most petroleum refineries and chemical plants that are affected facilities have mature BenzeneWaste Operations NESHAP (BWON) and Consent Decree compliance programs. Affected petroleum refineries and chemical plants should have a reasonable and accurate accounting of their total annual benzene and uncontrolled benzene waste generation rates. If this is the case, then BWON compliance at these facilities should focus on effective benzene emission controls (i.e. complying with NESHAP waste management standards). Pursuant to rule requirements, these standards are straight- forward and include installing controls, completing periodic inspections, repairing equipment if necessary, and reporting deficiencies.This presentation will focus on a review of the current equipment standards. We will also discuss recent enforcement actions and EPA’s use of a forward looking infrared (FLIR) camera to look for volatile organic compound (VOC) leaks from wastewater treatment waste management units.

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EHS Best Management Practices

Best Practices for Vapor Recovery Systems to Reduce Venting and Flaring with Economic Benefit

Jeff Voorhis - HY-BON

Description

Existing and evolving regulatory requirements require oil and gas producers to reduce venting and flaring of natural gas from their operations. Regulatory agencies tightening venting and flaring emissions include Environment Canada, the U.S. Environmental Protection Agency’s (USEPA), U.S. Department of the Interior, state/province environmental and oil and gas mining regulatory agencies. These rules seek to minimize the loss of natural resources and to reduce air pollution emissions. The air pollutants of concern include volatile organic compounds (VOCs) and the greenhouse gases methane and carbon dioxide. The source of the natural gas is primarily flash gas liberated from the storage of crude oil and condensate. The presentation discusses the drivers for reducing venting and flaring and gives a step by step approach to vapor recovery from project identification to ultimate success in sending gas to a gathering or sales pipeline. The characteristics of storage tank vent gas are discussed. Steps include identifying project scope and emission standards, design data needs, best design practices, installation, commissioning and monitoring systems. The use of smart systems to measure and monitor system operation and the amount of gas recovered is included. Also covered is the design and use of vapor recovery towers (VRTs) to reduce the chance of oxygen entering the vapor recovery systems.Supplemental emission controls using vapor combustion units as backups to the vapor recovery system is also addressed. The presentation will also introduce new technologies used to automate the detection and reporting of leaks from open thief hatches used on storage tanks and Linear Rod Pumps.

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EHS Emerging Technologies

H2S Monitor & Safety Shower Technology

Marcio Donnangelo - Emerson Process Management

Description

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

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EHS Best Management Practices

MPV, PRD & MSS Best Management Practices at Refineries & Opportunities for Chemical Plants

Troy Knuston - Sinclair Oil

Description

Coming soon.

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EHS Best Management Practices

Flare Gas Composition Analysis and QA/QC & Best Management Practices

Herman Holm - Spectrum Environmental Solutions, LLC

Description

The now infamous “Table 13” of the Refinery Sector Rule in 40 CFR 63.670 will be presented and discussed along with a review of the historical approach to the flare gas composition analyzer’s Quality Assurance (QA) requirements. The experts at Spectrum Environmental Solutions, LLC (Spectrum) have been involved with a wide variety of industrial flare related issues within the petroleum and petrochemical related industry sectors including detailed instrumentation support. The presentation will provide an understanding of the periodic analyzer QA requirements as generally provided in EPA Performance Specification 9 for GC’s highlighting the shortcomings of the Table 13 RSR requirements, and some recent Flare consent decrees, to provide possible solutions for a reliable flare gas composition analyzer’s quality assurance demonstration.

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EHS Best Management Practices

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.

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Air Permitting

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.

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EHS Best Management Practices

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.

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BWON

BWON Auditing

Bart Leininger - Ashworth Leininger Group

Description

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.

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BWON

BWON Masterclass

Steve Probst - 4C Marketplace and Conference

Description

Coming soon.

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BWON

BWON Process

Think Environmental -

Description

Coming soon.

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CEMS

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.

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LDAR / Fugitive Emissions Prevention

Methods for Enhancing Fugitive Emissions Prevention in Chemical Process Pipelines

Dale Rice - VSP Technologies

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.

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EHS Best Management Practices

Process Burner Flames: The Good, the Bad, and The Ugly

Doug Basquez, Charles Baukal - HollyFrontier Corporation, John Zink Co. LLC

Description

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

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PFAS

Identifying Potential Off-site PFAS Sources to Limit Liability at Fuel & Petrochemical Facilities

John Cuthbertson - AECOM

Description

Coming soon.

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EHS Emerging Technologies

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.

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EHS Emerging Technologies

Location Awareness - Improving Safety with Wireless Monitoring

Marcio Donnangelo - Emerson Automation Solutions

Description

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

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EHS Emerging Technologies

Advanced Data Collection Technologies for Rugged Field Work

Craig O'Niell - Juniper Systems

Description

Coming soon.

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Fenceline Monitoring

Fenceline Monitoring with OP-FTIR

Troy Boley - Spectrum Environmental Solutions

Description

Coming soon.

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Fenceline Monitoring

New Applications in Fenceline Monitoring

Jesse Miller - CAMSCO

Description

Fenceline Monitoring via passive samplers is a robust, highly sensitive and accurate monitoring technique. While Fenceline Monitoring is best known for Method 325 (Refinery Fenceline Monitoring), this technology is now used in a wide variety of new monitoring applications. We will discuss the history, equipment used (Thermal Desorption, Sampling or Sorbent Tubes) as well as current real-world scenarios, other than refineries, utilizing Fenceline Monitoring.

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Fenceline Monitoring

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.

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Fenceline Monitoring

New and Emerging Fenceline Monitoring Technologies

Troy Boley - Spectrum Environmental Solutions

Description

Coming soon.

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Fenceline Monitoring

Calibration Gas for Fenceline Monitoring

Phil Midgett - Airgas

Description

Coming soon.

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Fenceline Monitoring

TCEQ Fenceline Monitoring Update

Sabine Lange - TCEQ

Description

Coming soon.

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Fenceline Monitoring

Portable GC for Fenceline Monitoring

Chris Chopkoff - SGS

Description

Coming soon.

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Flares Instrument Analyzers and Sensors

Optical Flow Sensors for Environmental Compliance and Process Control

- 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.

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Flares Instrument Analyzers and Sensors

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.

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Flares Instrument Analyzers and Sensors

Flare Panel Moderated by Spectrum Environmental Solutions

- Multiple

Description

Coming soon.

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Flares Instrument Analyzers and Sensors

Comprehensive Measurement and Analytical Technologies and Innovative Digital Solutions

Marcelo Carugo - Emerson Process Management

Description

Digital technologies provide strategies to reduce flare flow in the most cost-effective manner. Flare emissions reporting requirements, flare monitoring, relief valve, flare source monitoring, root cause analysis, flaring events, vent gas analysis, steam and supplemental gas flow measurement, flame detection, digital solutions.

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Flares for Regulatory Compliance

Reduce Turnaround Duration By Eliminating Flare/Flare Gas Recover Using New Scrubber Technology

Jim Woodard - Vapor Point LLC

Description

The refining industry is challenged with the development of alternative technologies to control hazardous and regulated emissions such as Hydrogen Sulfide and Total VOC compounds.  FederalAgencies, through rule promulgation and Consent Decree, have emphasized a highlighted effort to minimize flare usage as a control device.  The current rule promulgation of NSPS subpart Ja, RefineryMACT, and the Refinery Technology Rule each will provide challenges to perform de-inventory and decontamination phases of turnarounds in a timely manner.  The direct impact of regulatory action is on the shoulders of those responsible for the planning, execution, and management of turnaround activities.  Vapor Point will present case histories on projects at multiple refineries and multiple process units requiring various control requirements.  Presentation will demonstrate very common challenges that refiners face under the new EPA regulations and solutions that have been successfully deployed in the field with the new scrubber technology package.

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Flares for Regulatory Compliance

Flare Panel Moderated by Spectrum Environmental Solutions

Multiple -

Description

Coming soon.

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Flares for Regulatory Compliance

MSS Support Services

TBD - Gem Mobile

Description

Coming soon.

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LDAR / Fugitive Emissions Prevention

EPA AWP Approved

Karen Marsh - US EPA

Description

Coming soon.

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Environmental Legal

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.

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Oil & Gas

Reducing Blowdown Emissions

Karen Nielsen - Kinder Morgan

Description

Coming soon.

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Digital Transformation

Data Collection, Process Automation & Reporting Mobilized for Environmental Health & Safety

Jack Phur - Mobile Epiphany

Description

Coming soon.

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Digital Transformation

5 Reasons to Digitize your Oil & Gas Crews

Luke Carton - Parsable

Description

Giving O&G crews the digital tools to raise their performance is an overlooked opportunity of potentially immense proportions. You can generate incremental ROI with every job you digitize. Multiply that by all the complex nested jobs within your operations — and stretching across O&G value chains.

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Digital Transformation

Visible Emissions BACT – Digital Monitoring Technique for Opacity

Shawn Dolan - Virtual Technology

Description

This paper will review 10 years of the evolution of Visible and nuisance emission monitoring process. The evolution overview will include the national and international standards achieved and the operational status of digital visible emission management programs around the world. The paper will address implementation issues encountered and updates made to the standards to accommodate field operations. The paper will address the evolution of camera technology, and the use of the various, hand held, fixed mounted, mobile drones and personal cameras. The paper will explore the various ways these technologies are being used to manage Visible and Nuisance Emission programs around the Globe. The paper will discuss the pro's and con's of the various recording devices and the sources that require opacity monitoring. From the Early Warning System on the Freeway, to the monitoring of visibility on the street corner to estimate PM load, Digital Images continue to excel in the advancement of inexpensive wide area monitors. The paper will conclude with the comparison of the old to the new in terms of information quality and sustainability, while visualizing the path forward over the next decade.

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Launching and Receiving

Right of Way Using Drones

Peter Walper - Texas Energy Raters

Description

Coming soon.

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Launching and Receiving

Pipeline Blowdowns and Distribution

Doug Sahm - TPE Midstream

Description

Coming soon.

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Oil & Gas

Do you have the Right Tank? Thief Hatch?

James Van Horne - SLR International Corporation

Description

Coming soon.

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Oil & Gas

Quadcopter Drones, Fixed Wing Drone, Helicopters, or Fixed Wing Plane?

David Furry - Leak Surveys Inc.

Description

Coming soon.

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Oil & Gas

Airborne LIDAR Pipeline Inspection Systems

Tim Goolsby - Lasen

Description

Coming soon.

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Oil & Gas

Industry Programs Panel

Matt Todd - The Environmental Partnership, Richard Hyde - ONE Future, Isable Mogstad - Environmental Defense Fund -

Description

Coming soon.

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Oil & Gas

Diversity & Leadership Panel

Sucheta Gokhale - HollyFrontier, Maury Dobbie - Colorado Research Collaboratory, Uzi Ibrahim - 4C Marketplace -

Description

Coming soon.

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Oil & Gas

Drone Based OGI OOOOa (Quadcopter Drone)

Roy Massengale - Enrud

Description

Coming soon.

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Oil & Gas

MethaneSAT 2021 Satellite Methane Detection Coming Soon

Tom Ingersol - Environmental Defense Fund

Description

Coming soon.

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Oil & Gas

Satellite-based Hyperspectral Analysis for Emissions Detection, Integrity Monitoring and Compliance

Tushar Prabhakar, Peter Weaver, & Tushar Prabhakar - 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.

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Oil & Gas

Applications and Field Results for Quantitative Optical Gas Imaging

Jon Morris - Providence Photonics

Description

Coming soon.

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EHS Emerging Technologies

Visible Emissions Management Using Best Available Technology

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.

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Oil & Gas

Methane Data Collection, Gas Infrastructure, Transformational Analytics, Actionable Results

Chris Rella, Aaron Van Pelt - Picarro

Description

Coming soon.

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Oil & Gas

Laser Dispersion Spectroscopy – Large Area Fugitive Monitoring

Mohammed Belal - Mirico

Description

Coming soon.

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Oil & Gas

Gas Mapping LiDAR (GML) Methane Emission Quantification & Operational Efficiency

Peter Roos - Bridger Photonics

Description

Coming soon.

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