SO 2 Emissions Rolling Average

Transcription

1 SO 2 Emissions Rolling Average Document Number: ECS0109A Revision Date: 2018/08/10 Revision: 2 Review Cycle: 3 Years Standard Administrative Document Owner (Title): Director, Environment / IH Oil Sands Applies To: Upgrading / Energy & Utilities Effective Date: 2018/03/15 Summary of Changes Rev No. Section Changed Revision Made 1 Add Revision #. Set at 1 as no previous Revision # assigned. Reformatted to new template 2 Cyclical review Scope This Standard includes in its scope the Upgrading and Energy Utilities SO 2 emissions sources. Purpose To set minimum environmental operating requirements for monitoring and controlling sulphur dioxide (SO 2 ) emissions to ensure compliance with rolling average limits, as established in Suncor Energy Inc.'s Alberta Environment Operating Approval as amended. Compliance Upgrading and Energy Utilities must ensure compliance with this Standard. Roles and Responsibilities The following individuals and groups have the following roles and responsibilities: Document Owner Document Approver Ensures this document is reviewed according to the required revision cycle. Ensures the document is updated to accommodate changes to Suncor, provincial, and federal regulation. Ensures the document is updated to mitigate risks found as the result of an incident. Ensures this standard is necessary and that it aligns with management and company direction. WARNING - Uncontrolled when printed. The current revision of this document is available in LiveLink. Page 1 of 7

2 References ENP0001A Environmental Incident Reporting ECS0404A - Upgrading Hydrocarbon and Acid Gas Flares Terms, Definitions and Acronyms The following terms, definitions and acronyms are used in this standard: 24-Hour Rolling Sum 365-Day Rolling Average FGD Flaring The arithmetic sum of hourly SO 2 emissions from the specified sources (in tonnes) for a consecutive 24-hour period, which is calculated for any hour by adding the SO 2 emissions during that hour to the SO 2 emissions during the previous 23 hours. This methodology was confirmed with the regulator to satisfy the 24- Hour rolling average requirement. The arithmetic sum of daily SO 2 emissions from the specified sources (in tonnes) for a consecutive 365-day period, which is calculated for any day by adding the SO 2 emissions during that day to the SO 2 emissions during the previous 364 days, and dividing the sum by 365. Flue Gas Desulphurization Any combustion of sour gases, hydrocarbon gases or any offspecification volatile liquids in a flare that occurs during: I. A routine flaring event, which is flaring that is due to: catalyst activation in any process units excess of fuel gas or hydrogen gas routing to a flare from the U1 steam-out oil/sour water separator (5C-18), the U2 steam-out oil/sour water separator (52C-311) and the Plant 7 compressor seals II. An emergency flaring event, which is flaring that exceeds 20 tonnes of SO 2 emissions due to: a process upset an equipment malfunction an unplanned equipment repair, modification, replacement III. A planned major flaring event, which is a non-routine or non-emergency flaring event, that exceeds 20 tonnes per day of SO 2 emissions during the event; normal start-up of any process units (this will be kept here in order to match our approval) normal shutdown of any process units (this will be kept here in order to match our approval) IV. A planned minor flaring event, which is a non-routine or nonemergency flaring event, that is less than or equal to 20 tonnes per day of SO 2 emissions during the event. Page 2 of 7

3 Standard 1. Emissions Limits and Standards 1.1 The combined emission rate of SO 2 to the atmosphere from all sources at the plant, based on a Site wide 24-hour SO2 rolling SUM, shall not exceed: I. 360 tonnes per consecutive 24-hour period, EXCEPT during time periods when it is necessary to start-up two or more upgraders simultaneously to prevent freezeup; and II. 500 tonnes per consecutive 24-hour period during time periods when it is necessary to start-up two or more upgraders simultaneously to prevent freeze-up. 1.2 The combined emission rate of SO 2 to the atmosphere from all sources at the plant, based on a 365-day rolling average, shall not exceed: I. 79 tonnes/day commencing on August 12, SO 2 emissions from all combined sources should steward to remain below an internal target of 72 tonnes/day for the 365 day rolling average while the approval limit is 79 tonnes/day. 2. Operating Requirements 2.1 The Site wide 24-hour SO 2 rolling SUM and 365-day rolling average are enforced by Alberta Energy Regulator. 2.2 Critical periods that may exceed 20 tonnes and/or affect the Site wide 24-hour SO2 rolling SUM may result from single or simultaneous significant emissions events. Significant events may include: Wet gas compressor trips (5K-1 / 5K-5 / 52K-401 / 52K-402) Sulphur recovery unit trips in which alternate destinations for acid gas are not available Plant start-ups and shutdowns FGD outages where the auxiliary fuels are not the primary coke boiler fuel source. Continued on next page Page 3 of 7

4 Continued 2.3 For planned significant events that may approach the Site wide 24-hour SO2 rolling SUM: I. Environmental Affairs will obtain any required authorizations to proceed with the planned work at least one week prior to the planned flaring event; II. Site wide 24-hour SO2 rolling SUM is monitored in OPM (see screenshot). RES (Regulatory Engineering Support) will be available in the event the OPM results need to be validated. If Environmental Affairs needs further clarification, this information will be provided by a member of Regulatory Engineering Support group at cell phone (403) For unplanned significant events that may approach the Site wide 24-hour SO2 rolling SUM limit: I. Upgrading and Energy & Utilities Operations Shift Supervisors are to report incident to Environmental Affairs On-Call at as soon as it is safe to do so, as per ENP0001A Environmental Incident Reporting. II. Environmental Affairs will notify RES (Regulatory Engineering Support) during week days once operations has reported a potentially significant flaring event. During weekends, Environmental Affairs will contact the Process Engineering Manager on-call, who, if required, may contact RES team for additional support. III. 24 hrs rolling sum during flaring events is monitored in OPM (see screen shot above). RES or Process Engineering Manager on-call (or his /her designee) will validate the OPM data, calculate a forecast, and provide information for the following personnel: Production Committee (osg_prod.committee@suncor.com) Planning and Logistics manager on-call Energy and Utilities manager on-call Upgrading Operations manager on-call Upgrading Process manager on-call Site-wide lead (osg_sitewidelead@suncor.com) Environmental Affairs on-call (environment2@suncor.com) RES Regulatory Reporting personnel IV. As required, the Site Wide Lead may elevate the risk associated with the incident and notify appropriate management. Continued on next page Page 4 of 7

5 Continued 2.5 To ensure the 365-day rolling average is not exceeded, SO 2 reduction initiatives shall be developed and implemented to maintain stewardship of the internal target value of 72 tonnes/day. When the rolling average is projected to exceed the 72 tonnes/day internal target, the Production Committee may consider the following actions: I. Projected exceedance to occur within one year: Discuss major outage and turnaround plans to identify potential emission reduction opportunities. Discuss FGD Major and Minor outages to identify potential emission reduction opportunities. Review emissions estimates to ensure the accuracy of the forecast. II. Projected exceedance to occur within nine months: Review the actual versus projection over the previous three months. Discuss major outage and turnaround plans to identify potential emission reduction opportunities. Discuss FGD Major and Minor outages to identify potential emission reduction opportunities. Review emissions estimates to ensure the accuracy of the forecast. III. Projected exceedance to occur within six months: Review the actual versus projection over the previous six months. Identify potential emission reduction opportunities in Upgrading for outages and turnarounds. Identify opportunities in Energy and Utilities for burning of alternative fuels. Identify flaring reduction strategies. IV. Projected exceedance to occur within three months: Implement effective site-wide SO 2 emissions reductions strategies, which could include: Utilization of alternative fuels in Energy and Utilities Flaring reduction strategies Review of additional reduction opportunities 3. Monitoring Requirements 3.1 Daily emissions calculations must be conducted of site-wide SO 2 emission sources during normal plant operation; I. RES is responsible for summarizing SO 2 emissions from flaring sources for Environmental Affairs via the Daily Flare Report; This is an automated report and is issued every day at 10 am. II. Environmental Compliance is responsible for summarizing SO 2 emissions data from Continuous Emissions Monitoring Systems (CEMS) monitored sources twice a week from the following locations: powerhouse stack, FGD, and U1/U2 Thermal Oxidizing Stacks. Continued on next page Page 5 of 7

6 Continued 3.2 During significant upset incidents, resulting in SO 2 emissions that have the potential to approach the daily 360 tonnes limit, refer to Section To ensure the greatest accuracy of the 365-day rolling average forecast, Process Engineering for each Upgrading Cross-Functional Team (CFT) as well as the Energy & Utilities FGD and Water Systems Manager must provide Environmental Affairs with up-to-date information regarding upcoming planned emissions events (Refer to Appendix I). 3.4 EHS is responsible for actual and forecasting site-wide SO 2 in the projected 365- day rolling average a minimum of one year forward. 4. Reporting Requirements 4.1 Environmental Affairs is responsible for reporting major flaring events (greater than 20 tonnes of SO 2 ) and exceedances of the SO 2 rolling limits (outlined in Sections 2.2 and 2.4) to the Coordinated Information Centre (CIC), as per ENP0001A Environmental Incident Reporting. 4.2 Upgrading personnel are required to report to Environmental Affairs On-Call any significant emissions events (as detailed in ECS0404A), which may include: I. Emergency flaring events, including any manual valve open to flare or PSV lift. II. Planned flaring events, where the designated Upgrading CFT is responsible for notifying Environmental Affairs as soon as there is a reasonable awareness of the need to undertake planned flaring that will result in SO2 emissions greater than 20 tonnes. Environmental Affairs is responsible for submitting a "Request to Flare" to Alberta Energy Regulator one week prior to the planned flaring. 4.3 RES must report unplanned and planned flaring emissions to Environmental Affairs. A Report is automated and is issued every day at 10 am and can be used to monitor daily flaring results. 4.4 Energy & Utilities personnel are required to report to Environmental Affairs On-Call any downtime and bypass periods of the FGD. 4.5 RES or the Process Engineering Manager On-Call is responsible for reporting emissions that affect the Site wide 24-hour SO2 rolling SUM as outlined in Section 2.4. Actual and forecasted hourly SO 2 emissions reports must be distributed to personnel outlined in Section 2.4. This information is easy available in OPM. 4.6 Environmental Affairs is responsible for reporting the projected 365-day SO 2 Rolling Average to the Production Committee on a weekly basis. End of Standard Page 6 of 7

7 Appendix 1 SO 2 Stewardship and Reporting Purpose: The stewardship process is to monitor site-wide as well as individual business unit performance as it compares to the Base Forecast throughout the actual performance should be reported for each individual Business Unit on a daily basis. Data is reviewed weekly with the Production Committee, and monthly at a Business Unit. The stewardship reports help to identify trends and areas for improvement, and provide a basis for the future. Owner: Environmental Affairs (EA) Regulatory Engineering Support Upgrading Site Process Engineering Participants: Energy & Utilities (E&U) FGD & Offplots U1 Primary (U1P) Process Engineering Manager and Area U2 Primary (U2P) Process Engineering Manager and Area Upgrading Secondary and Hydrotreating (UPH) Process Engineering Manager and Area Sulphur Complex (UPS) Process Engineering Manager and Area Upgrading Offplots (UPO) Process Engineering Manager and Area Production Committee (PC) Environmental Compliance (EC) Page 7 of 7

8 The following individuals have approved and signed this document. UserName: Sheila Chernys (schernys) Title: Dir OS Enviro & Reg Date: Friday, 10 August 2018, 03:05 PM Mountain Time Meaning: Approver 1 Signed ================================================