Rule 1105.1 Particulate Control Environmental Considerations in Today’s Projects.

Rule 1105.1 Particulate Rule 1105.1 Particulate ControlControl

Environmental Considerations in Environmental Considerations in Today’s ProjectsToday’s Projects

AgendaAgenda

ConocoPhillipsConocoPhillips Los Angeles RefineryLos Angeles Refinery Environmental RegulationsEnvironmental Regulations What does an Environmental Department do ?What does an Environmental Department do ? General Project ConsiderationsGeneral Project Considerations Case Study – Rule 1105.1Case Study – Rule 1105.1

Who is ConocoPhillips ?Who is ConocoPhillips ?

Large Integrated Oil CompanyLarge Integrated Oil Company Does business in over 40 countriesDoes business in over 40 countries Familiar brands – 76, Phillips 66, ConocoFamiliar brands – 76, Phillips 66, Conoco Sustainable DevelopmentSustainable Development

– Ethical StandardsEthical Standards– Environmental ImprovementsEnvironmental Improvements– CommunityCommunity– EnergyEnergy

Los Angeles RefineryLos Angeles Refinery

Mid-sized, about 140,000 bbls/dayMid-sized, about 140,000 bbls/day Worst Crude/Cleanest ProductsWorst Crude/Cleanest Products

– Mostly cracking heavy material distillationMostly cracking heavy material distillation– DistillationDistillation– Treating/removing impurities Treating/removing impurities

Start 1918, Runs 24/7Start 1918, Runs 24/7 About 660 EmployeesAbout 660 Employees One of 6 major refineries in South CoastOne of 6 major refineries in South Coast

Environmental RegulationsEnvironmental Regulations

Clean Air ActClean Air Act Clean Water ActClean Water Act RCRA – WasteRCRA – Waste Emergency Release RegulationsEmergency Release Regulations Toxic RegulationsToxic Regulations Multi-Agency Complex RegulationsMulti-Agency Complex Regulations 33rdrd-Party Intervention-Party Intervention

What Does An Environmental What Does An Environmental Department Do ?Department Do ?

Regulation expertise – air, water, wasteRegulation expertise – air, water, waste Advocate on new legislation/regulationAdvocate on new legislation/regulation Help facility implement new regulationsHelp facility implement new regulations Obtain environmental permitsObtain environmental permits Compliance assurance/continuous improvement Compliance assurance/continuous improvement

management system approachmanagement system approach Maintain reporting/recordkeepingMaintain reporting/recordkeeping Staff of 7 professionals, 6 air emphasisStaff of 7 professionals, 6 air emphasis

General Project ConsiderationsGeneral Project Considerations

Safety – First PrioritySafety – First Priority Environmental ConsiderationsEnvironmental Considerations

– Compliance, permitting, scopeCompliance, permitting, scope

Community ImpactCommunity Impact Schedule (Timing with Outages)Schedule (Timing with Outages) Quality – Will it work when doneQuality – Will it work when done Cost – differentiate alternatives, cost as budgetedCost – differentiate alternatives, cost as budgeted

Why Rule 1105.1 Project ?Why Rule 1105.1 Project ?

SCAQMD RegulationSCAQMD Regulation– Control solid particle emissionsControl solid particle emissions– Control ammonia (precursor)Control ammonia (precursor)

Impacts the Fluid Catalytic Cracking Unit Impacts the Fluid Catalytic Cracking Unit (FCCu)(FCCu)

Particulate limit, 30 lbs/hour to about 6 Particulate limit, 30 lbs/hour to about 6 lbs/hourlbs/hour

Ammonia, no limit to 10 ppmAmmonia, no limit to 10 ppm

What does an FCCu look like ?What does an FCCu look like ?

Project HistoryProject History

Rule passed 12/2003Rule passed 12/2003 Began meeting vendors and setting design Began meeting vendors and setting design

parametersparameters Determined early need for ‘pre-treatment’Determined early need for ‘pre-treatment’

– 33rdrd/4/4thth-stage separators-stage separators

Determined early need for schedule adjustmentDetermined early need for schedule adjustment Installed 3Installed 3rdrd/4/4thth stage separators in November stage separators in November Performing TestingPerforming Testing

New 3New 3rdrd-Stage Separator-Stage Separator

New Flue Gas TrainNew Flue Gas Train

New Third Power HeatRegenerator Stage Recovery Recovery ESP's Stack

Separator Turbine Boiler

FourthStage Bulk

Separator Truck

BulkTruck

Technology ChoicesTechnology Choices

Dry Electrostatic precipitators (ESPs)Dry Electrostatic precipitators (ESPs)

Wet gas scrubberWet gas scrubber

Wet gas scrubber/Wet ESPWet gas scrubber/Wet ESP

ESPESP

SCRUBBERSCRUBBER

EEE

NaOH / Na2CO3

Effluent

Process Water

FCCUOff-Gas

WESPSection

Stack

Absorber Section

OxidationAir

Sump

Safety ConsiderationsSafety Considerations

All technologies selected can and have All technologies selected can and have operated safely.operated safely.– Dry ESPs in FCCu service (CO on start-up)Dry ESPs in FCCu service (CO on start-up)– Wet ESPs ?Wet ESPs ?– ‘‘Batch’ mode operational factorsBatch’ mode operational factors

ESPsESPs Wet Solids handlingWet Solids handling

Community ImpactCommunity Impact

Steam Plume for wet systems (aesthetics)Steam Plume for wet systems (aesthetics)– Perception vs. RealityPerception vs. Reality– Environmental JusticeEnvironmental Justice

TrafficTraffic– ConstructionConstruction– OperationOperation

Who is the community ?Who is the community ?

ScheduleSchedule

Outages (turnarounds) approximately every Outages (turnarounds) approximately every 4 years4 years– Tie-ins are possibleTie-ins are possible

Long lead equipmentLong lead equipment– SteelSteel– VesselsVessels

Competing OrdersCompeting Orders PermittingPermitting

QualityQuality

Dry ESPs have most applicationsDry ESPs have most applications Wet ESPs have leastWet ESPs have least Limits are pushing the edge of technologyLimits are pushing the edge of technology

– Lack of vendor guaranteesLack of vendor guarantees– Test method issuesTest method issues

Transient Conditions (start-ups/upsets)Transient Conditions (start-ups/upsets) Sparing PhilosophySparing Philosophy

CostsCosts

Capital CostsCapital Costs– Sparing PhilosophySparing Philosophy

Operational CostsOperational Costs– EnergyEnergy– Water/Waste ProcessingWater/Waste Processing

Environmental ConsiderationsEnvironmental Considerations

Test method reliabilityTest method reliability– EPA vs. SCAQMD methodEPA vs. SCAQMD method

Future regulation uncertaintyFuture regulation uncertainty– PM 2.5 (2007-2014)PM 2.5 (2007-2014)– Secondary Pollutants (Precursors)Secondary Pollutants (Precursors)

NOx/SOx/NH3NOx/SOx/NH3

– PM 2.5-10 (New EPA effort, state ?)PM 2.5-10 (New EPA effort, state ?)

Environmental Considerations Environmental Considerations

Selective Catalytic Reduction (SCR) for NOxSelective Catalytic Reduction (SCR) for NOx– Other regulationsOther regulations– Unit Expansion (Best available Control Unit Expansion (Best available Control

Technology)Technology)– InstallationInstallation

Temperature/energy considerationsTemperature/energy considerations SO2 – SO3 conversion (dry vs. wet)SO2 – SO3 conversion (dry vs. wet) FoulingFouling Construction (leaving room)Construction (leaving room)

Environmental ConsiderationsEnvironmental Considerations

SOx controlsSOx controls– Other regulationsOther regulations– FCCu expansion – What is BACT ?FCCu expansion – What is BACT ?– Wet systems have a clear advantageWet systems have a clear advantage

Environmental ConsiderationsEnvironmental Considerations

Wastewater treatment - ScrubbersWastewater treatment - Scrubbers– Purge for solids and chloride controlPurge for solids and chloride control– Removal for solidsRemoval for solids

Settling/Filter Press (messy Operation)Settling/Filter Press (messy Operation) Allow settling in existing refinery sewer systemAllow settling in existing refinery sewer system

– Sulfite (oxidation)Sulfite (oxidation) Can POTW take it ? (test method)Can POTW take it ? (test method) Adequate aeration in existing system ?Adequate aeration in existing system ?

Environmental ConsiderationsEnvironmental Considerations

Electrical (ESP vs. Scrubber)Electrical (ESP vs. Scrubber)– Offset by restarting power recover turbine ?Offset by restarting power recover turbine ?

Energy Profile (waste heat recovery)Energy Profile (waste heat recovery) Permitting Complexity (12-18 months)Permitting Complexity (12-18 months)

– California Environmental Quality Act (CEQA)California Environmental Quality Act (CEQA)– Agency experience with ESPsAgency experience with ESPs

Environmental ConsiderationsEnvironmental Considerations

33rdrd-Party Involvement-Party Involvement

FCCu Start-Up/Upset ConsiderationsFCCu Start-Up/Upset Considerations

Plume Mitigation ?Plume Mitigation ?

Plume MitigationPlume Mitigation

WHAT WOULD YOU DO ?WHAT WOULD YOU DO ?