Refinery-wide Maintenance Vent Compliance Program Development Strategies. Presented by Phil Fish, Barr Engineering Co.

Transcription

1 Refinery-wide Maintenance Vent Compliance Program Development Strategies Presented by Phil Fish, Barr Engineering Co. April 2018

2 Presentation Overview Miscellaneous Process Vent (MPV) and Maintenance Vent (MV) Overview Group 1 MPV vs. Group 2 MPV vs. MV Three phases of refinery-wide MV compliance program development Steering Mobilizing Implementing Two equipment screening approaches for sorting equipment into smaller groups Reference-Volume approach Three-Groups approach Program documentation considerations Ongoing program improvement strategies

3 MV Regulatory Background MPVs are broadly defined as gas streams discharged from a process unit Dec rule adds work practice standards (WPS) resulting from removal of the Startup, Shutdown, Malfunction (SSM) exemption Compliance date of August 1, 2017, or 2018 if extension has been granted Prior to compliance date, comply with general duty to minimize emissions for each maintenance activity EPA technical rule amendments signed on March 19, 2018

4 MPV Group Designations Group 1 MPV >72 lb VOC/day emissions Route to flare, heater or CE Group 2 MPV <72 lb VOC/day emissions One-time notification For vents only used as a result of startup, shutdown, maintenance, or inspection of equipment where equipment is emptied, depressurized, degassed or placed into service MV >72 >72 lb VOC inventory Measure LEL (or <5 psi) MV <72 <72 lb VOC inventory Document calculations MV Blinding <2 psi (proposed) Document justification

5 Three basic steps: Individual MV Compliance Flow Chart 1. Determine applicability (before event) 2. Control and monitor emissions for compliance (during event) 3. Complete required recordkeeping and reporting

6 Phased Compliance Strategy I Steering What are the interpretations, assumptions and risks with different compliance approaches? Who is responsible for certain tasks? II Mobilizing How will each piece of equipment comply? How do we estimate VOC emissions or the mass contained? III Implementing How do we manage compliance on a day-to-day basis for individual equipment maintenance? How do we manage compliance for large unit TARs?

7 Steering Phase (1/2) Goal: Determine key interpretations, assumptions and risks for compliance. Non-linear may need to revisit initial decisions based on new/additional information EPA rule changes or clarifications Field measurements Chemical cleaning vendor guarantees On-board key refinery stakeholders Operations, Maintenance, Engineering, Turnaround Planner, Environmental, Safety

8 Steering Phase (2/2) Evaluate current venting practices Can the refinery meet the WPS today? What are the current procedures when equipment is >10% LEL? How is equipment vented during planned TAR? What pyrophoric equipment is connected to a pure hydrogen supply? Align on key regulatory interpretations G2 MPV vs. MV Review EPA s April 2017 responses to AFPM/API July 2016 request for clarifications. Evaluate practice changes or strategies Additional purge cycles Longer chemical cleaning Capital projects to better prepare equipment for venting

9 Mobilizing Phase (1/2) Goal: Collect additional information and assimilate into spreadsheet(s) to determine how to comply for each vent. Follow the key Steering Team decisions and interpretations. Smaller team Engineering, Environmental, Turnaround Planner Evaluate available process stream data sets HYSYS/ASPEN modeling, storage tank representations, etc.

10 Mobilizing Phase (2/2) Gather inventory of vents (equipment and piping sections) Develop calculation templates Calculate VOC mass in gas and residual liquid from equipment and associated piping Utilize assumptions to screen equipment into smaller groups Gather empirical data to inform steering decisions

11 Empirical Data Mobilizing Phase - Calculation Refinement Hierarchy Method 21 screening Method 18 bag sampling Field-measured T&P Refinements Steam / nitrogen purging Realistic T&P Equipment measurements Worst-case Saturated temperature Maximum pressure per Safety Process stream speciation Increasing effort Increasing accuracy Increasing sensitivity to changes

12 Mobilizing Phase - Equipment- Based Screening Screen equipment into smaller groups Reference-Volume approach Three-Groups approach Searching for low-hanging fruit Exclude small equipment unable to contain 72 lb VOC of vapor Worst-case assumptions Doesn t account for clingage or liquid heel Rule of thumb -type exercise Can the equipment contain >X% of 72 lb VOC with worst-case assumptions? Safety factor to account for uncertainty (clingage) Utilize process engineer s knowledge/experience to reduce calculation burden and improve accuracy

13 Reference- Volume (RV) Screening Approach 72 lb RV (X ft 3 ) >72 lb VOC Towers Reactors Drums Small drums w/ piping Large HX w/ piping Long piping runs Compliance Demonstration Strategy WPS (LEL or, if cannot measure LEL, <5 psi) <72 lb VOC HX Pumps Filters MV Calculation Documentation (or possibly treat as G2 MPV) VOC Volume

14 Three-Groups Screening >72 lb VOC Towers Reactors Drums Compliance Demonstration Strategy WPS (LEL or, if cannot measure LEL, <5 psi) Approach 72 lb V 72 (X ft 3 ) Approx 72 lb VOC Small drums w/ piping Large HX w/ piping Long piping runs WPS or MV Calculation Documentation VOC Volume HX Pumps Filters <72 lb VOC MV Calculation Documentation (or possibly designate as G2 MPV)

15 Equipment List RV or V 72 Analysis RV or V 72 Process Engineer Questionnaire Unit Process Engineer Questionnaire Workflow Equipment <<RV or V 72 Equipment ~V 72 ±X% Equipment >>RV or V 72 Done MV Calculation Documentation Refine or WPS Refine or WPS Three-Groups Approach Only

16 Implementing Phase Goal: Determine boots on the ground compliance approach. Full stakeholder team Operations, Maintenance, Engineering, Turnaround Planner, Environmental, Safety Incorporate WPS into day-to-day operations Safe Work Permits Separate MV documents or inventories listing equipment subject to WPS Establishing procedures for evaluating venting during upcoming turnarounds Develop recordkeeping procedures

17 MV Compliance Plan Document Consolidating MV determinations, calculations and documentation into a single plan Plan main text includes: Rule definitions Steering team decisions and interpretations Appendices include: Unit-specific discussion, calculations and process engineer questionnaires Example recordkeeping forms Refinery-wide background documentation RV/V 72 calculations

18 Program Improvement Strategies The goal is to reduce compliance burden or improve accuracy Additional sampling or recordkeeping Method 21 screening (concentration) or Method 18 bag sampling (speciation) equipment to validate calculations Recording T&P data for routine maintenance activities to refine calculations Revising SOPs to improve calculation parameters E.g., do not vent if system pressure is >3 psig. Updating MOC procedures to evaluate changes to MV applicability

19 Thank you Contact information: Phil Fish Barr Engineering Co. (952)