Sage Environmental Consulting
Sage Environmental Consulting
Sen S.,Sage Environmental Consulting
American Fuel and Petrochemical Manufacturers, AFPM - Environmental Conference 2016 | Year: 2016
On September 29, 2015, the EPA issued a rule revision with potentially severe, wide- reaching consequences for the refinery sector. The Petroleum Refinery Sector Risk and Technology Review and New Source Performance Standards rule, made two significant changes impacting storage vessel applicability and compliance. First, it expanded the applicability of the Group 1 storage vessel classification. Second, and more importantly, the rule mandated new inspection requirements for storage vessels. While certain elements of the rule are clear and affect all facilities similarly, other requirements can only be implemented on a case-by-case basis, making it difficult to establish industrywide best practices. It has been left to facilities to choose which technologies and protocols are best suited to their particular case. This paper will first examine how the rule applies to storage vessels at all refineries, then move on to a case study review of the various tank types, fittings, and units impacted by the new rule. Lastly, we will present a decision-making tool to identify the most applicable maximum achievable control technologies (MACTs) for storage vessels and aid in quicker implementation.
Joyce J.M.,Sage Environmental Consulting
2013 PEERS Conference, Co-located with the 2013 International Bioenergy and Bioproducts Conference | Year: 2013
The combustion air pre-heater (APH) in any boiler or process heater system is a critical operational component of the overall steam and power system, but one that is often under-maintained and often over-looked with regard to improving boiler performance. Regardless ifthe boiler is a solid, liquid, or gaseous fuel boiler, or even a pulp mill recovery boiler, combustion air pre-heater and combustion zone temperature directly correlate to boiler efficiency, and the generation of CO as well as PM emissions with only a minimal potential increase in NOx. This multi-year study presents the data, analysis, and facts to support the idea that every 15-20° F improvement in pre-heater temperature can and does correspond to a 2% to 2.5% improvement in boiler efficiency along with a larger corresponding decrease in boiler air emissions. This is an issue relevant for those facilities looking for positive, cost effective, and innovative solutions to Boiler MACT and NOx RACT compliance. Copyright © (2013) by the TAPPI Press.
Borgianini V.,Sage Environmental Consulting
Proceedings of the Air and Waste Management Association's Annual Conference and Exhibition, AWMA | Year: 2012
Case studies are presented where field observed floating roof fitting counts were found to differ from the counts used to historically calculate permit allowable and actual emissions. These differences, combined with improper controls or operational errors, had a considerable impact on emissions. The condition of the fittings and the impacts on emissions are presented. During visual field inspections performed on external floating roof tanks at two facilities, inaccuracies were found in the number of fittings and the types of controls used. Issues were also observed with the condition and operation of some of the fittings or controls. Improper controls, inaccurate fitting counts, and/or operational errors can have unfavorable consequences. Improper controls can trigger state and/or federal penalties. Inaccurate fitting counts can significantly affect tank emissions estimates and can also lead to regulatory penalties. Improper operation can lead to emission events, inaccurate emissions calculations and regulatory deviations. Recommended protocols for performing accurate field fitting counts and improving fitting integrity are also presented. This is an abstract of a paper presented at the 105th AWMA Annual Conference and Exhibition (San Antonio, TX 6/19-22/2012).
Herman Holm K.,Sage Environmental Consulting
Proceedings of the Air and Waste Management Association's Annual Conference and Exhibition, AWMA | Year: 2012
The New Source Performance Standard (NSPS) Subpart Ja (Standards of Performance for Petroleum Refineries for Which Construction, Reconstruction, or Modifcation Commenced After May 14, 2007), issued by the EPA was first proposed on 5/14/2007, with flare requirements being added in the 6/24/2008 amendments. The flare portions of the rule were retained, until the EPA promulgated the final NSPS on 9/12/2012. NSPS Ja made flares a separate affected facility and included work practice standards specifically for flares, including monitoring requirements, the requirement to have a Flare Management Plan, and the requirement to perform Root Cause Analyses (RCAs). In addition to NSPS Ja, the EPA has also indicated increased interest in flares, especially the monitoring and control, with regards to good air pollution control practices. A discussion covers the new NSPS Ja and its implications for refinery flares. This is an abstract of a paper presented at the 106th AWMA Annual Conference and Exhibition (Chicago, IL 6/25-28/2013).
Joyce J.,Sage Environmental Consulting
American Fuel and Petrochemical Manufacturers, AFPM - Environmental Conference 2015 | Year: 2015
EPA's NSPS Ja Rule which affects almost all refineries in the U.S. is a perplexing Rule on many fronts, but in particular because it does not clearly distinguish whether flare gas volume, mass, or flare emission compliance data is to be reported on a wet or dry basis. Therefore, when a refinery is confronted with how to comply with Ja flare gas emission limits such as the 162 ppmv H2S limit, or 500 lb/day SO2 mass limit, or the 500,000 scf (above baseline) flare gas volume limit, is it a wet or dry basis? Flare gas mass flow meters and Total Sulfur analyzers all produce wet basis data. Depending on how well a flare knockout drum or water seal is functioning, refinery flare gas may contain anywhere from 0% to as high as 20% moisture content in some circumstances. If you are considering costly on-line moisture analyzers or TDLAS (Tunable Diode Laser Atomic Spectroscopy) systems for flare gas moisture measurement, there may be a viable alternative to determine moisture content and at virtually no cost. Sage Environmental Consulting has developed a unique empirical algorithm that can determine flare gas moisture content and which can be programmed into the refinery flare data acquisition system. The algorithm accurately determines moisture content with only a few simple input parameters and has been lab tested with accuracy comparable to TDLAS systems. So why spend up to $100,000 per flare on costly moisture analyzers or TDL's when a low cost alternative may be a viable option.
Lewus T.,Sage Environmental Consulting
Environmental Conference 2013 | Year: 2013
Monitoring heat exchange systems in organic Hazardous Air Pollutant (HAP) service for leaks using the Modified El Paso Method (MEPM) is now something all refineries are familiar with. However, there are varying strategies for how to implement a compliance program to ensure that refineries can identify leaking heat exchangers and make any necessary repairs within the required timeframe. Here we identify the benefits and challenges for heat exchange monitoring compliance programs implemented at refineries nationwide. Specifically, the following aspects of these programs and their impact on compliance will be discussed: • Challenges in identifying leaking heat exchangers; • Challenges in making timely repairs; • Developing effective response procedures for detected heat exchange system leaks; • Identification of which heat exchangers either require a process unit shutdown/load reduction or can be bypassed, and when exchangers qualify for the Delay of Repair (DOR) provisions; and • Reasons/observations for unexpected MEPM readings.
Duckworth K.,Sage Environmental Consulting
Environmental Conference 2013 | Year: 2013
One of the 14 essential elements of the Process Safety Management (PSM) program is the Management of Change (MOC) process, which is intended to meet the 29 CFR 1910 purpose of preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. In an effort to reduce paperwork, the MOC process sometimes includes a provision for changes that will not have an impact on the process (i.e. otherwise exempt from the specific requirements under the MOC process). These changes are considered "replacement in kind," which are essentially changes that leave the equipment exactly the way it was prior to starting the work. This paper considers examples of gaps in the use of replacement in kind and offers a few suggestions on how to avoid having a project fall into these gaps. Many of the presented changes often occur at a refinery. This is an abstract of a paper presented at the Environmental Conference 2013 (New Orleans, LA 10/21-22/2013).
Ellison D.,Sage Environmental Consulting
Web Coating and Handling Conference 2013 | Year: 2013
This session provides leaders with practical information on how to obtain and maintain zero accidents at their facility. We all face the same issues: what is next, how do I find time, what regulations apply, and each time I mention safety everyone thinks there is another rule, procedure or requirement that we must follow. What happens? - nothing changes. Prior to beginning our discussion, we will ask ourselves the following questions: Are you getting the results you want? Are you certain that you can sustain the results in the future - ZERO - no injuries? What must you do to sustain the results or take them to the next stage? Do you know what you need to do differently or what you need to continue doing daily for success? If you continue to do the things you did last year, will you get different results this year? The creation of an organization with zero incidents will not happen overnight. Rather, it is a process of continual improvement, requiring people to change the way they think, work, act and interact. Each of us starts at a different place on the continuum, from a traditional program to a proactive safety program. In the development of a safety program, the key elements are culture management and a safety management system that is monitored and improved systematically. Each of these elements is critical to a plant or organization to obtain and maintain zero injuries. The development of a safety culture must start with the leadership and be driven down to all levels within the organization. Culture is a shared, learned, symbolic system of values, beliefs and attitudes that shapes and influences perception and behavior. Each and every employee resists change and will not change without seeing the benefit. Change does not happen overnight, leadership must show the way through the demonstration of actions not just words. Culture change is an evolution and a change in the basic perception about reality. The focus will be on the culture and management systems that influence the safety behaviors. Leadership must be involved, be positive, be in the hearts and minds of each employee daily, and demonstrate that they care. The position of leadership must empower employees at all levels to take responsibility for safety and ensure all jobs are done safely. The characteristics that drive a successful safety culture are as follows: Safety goals are clear and shared. People manage their own safety behavior without over-reliance on safety policies. People are trusted to make decisions according to the information they know rather than their role in the hierarchy. Rewards are balanced between production, safety and quality. Mistakes are seen as an opportunity to learn. Important information is communicated face-to-face. Safety is seen as a strategic business objective by all. Conflicts regarding safety priorities are resolved, not suppressed. The safety management system outlines the components for building safety excellence within a company and creating a shared safety culture. The safety management system spells out the key requirements for achieving step changes in performance and the direction for continual improvement. This system consists of four key components: 1. Management Commitment and Leadership 2. Meaningful Employee Involvement 3. Risk Management 4. Communication When all four of these are present, and our actions and practices are clearly aligned with the fundamental values and beliefs, a company will succeed in achieving organizational excellence and pride. Safety excellence is about developing a mindset or attitude where each of us makes safety a top priority at all times. The first component, management commitment and leadership, is centered on how the leaders engage with employees each and every day. The leadership is vital in creation of the culture that recognizes and encourages the safety management system. They must be proactive, solution oriented, accountable, have a mindset that encourages and supports employees to reach higher whenever possible, and an attitude that is above all, focused on reinforcing the culture of safety excellence. There is no stronger message as a leader than "walking the talk". Employees remember your actions long after they have forgotten your words. While words are important, they must be backed by action and behavior that support and reinforce what you say. Equally important to setting a positive example through appropriate actions, you must also be conscious of how you respond to safety issues in the workplace: Do you drop everything and focus on resolving the issue? Do you demonstrate that safety really is a top priority? Or do you get around to dealing with the issue when you have time? These behaviors have a much greater impact on employees than anything you say. Remember that you get the level of safety that you demonstrate you want! To create employee ownership and meaningful involvement, you need to provide the employees with information on safety and include them in the implementation planning process where appropriate. Consulting employees during the process greatly enhances their buy-in and support. Also employees need to be involved in as many safety related initiatives as possible. Since all employees are expected to comply with both the intent and spirit of the safety management system, involving employees early on in the change process ensures enhanced commitment and fosters meaningful involvement. In a successful system, we will transform all employees into safety champions and believers, both at work and at home. The third component focuses on risk management. In this component, we must understand three types of risk: catastrophic, serious and minor. Catastrophic risks are those that result in fatalities. In catastrophic risks, a plant cannot wait until an incident occurs to react, but must learn from others, inside and outside the business. A serious risk is one that leads to amputations, hospitalization, disfigurement, broken bones, surgery or prolonged absences. A minor risk is all others. To obtain world class results, we must be proactive and assess all of these risks and have all employees involved in the assessment. The next step after risk assessment is to ensure that all risks are reduced to an acceptable level and the employees are trained on the potential risks. The fourth component is communication, which is a critical success factor for achieving safety excellence. A communication program helps address the many challenges associated with moving employees from awareness and understanding to commitment and action, where full ownership of safety happens. Communication helps the leadership team build trust between management and employees. In building this trust, we will demonstrate a common vision of what it means to work safely, a culture of shared responsibility, a core set of values and operating principles, showing that "I care", providing communication at all levels, and being positive. When success is obtained all employees are fully involved in supporting safety and communicate openly on all safety matters. Effective two way communication plays a key role in safety incident prevention. To ensure that the safety changes continue, a plan-do-check-act continual cycle will enable successful implementation and continuous step changes. These will include audits, review of new information, and management reviews. As an organization moves forward, a plan (multi year) must be developed to address the culture and management system components to ensure actions are in place to reduce risk, change the culture, and visibly demonstrate management and employee engagement. Safety excellence will become a reality at an organization when a critical mass of employees has embraced the Safety Vision and is committed to making the necessary changes on a daily basis. Thereby, providing an organization that has clear direction where people have motivation and love to come to work. And best of all - All Employees return home safely each and every day! Copyright© (2013) by the Association of International Metallizers, Coaters and Laminators.
Nelson T.P.,Sage Environmental Consulting
Environmental Progress and Sustainable Energy | Year: 2013
Criteria and hazardous air pollutant emissions from petroleum refineries in the US have decreased over the last 20 yr despite increasing crude density, changes in sulfur concentrations, increasingly stringent product specifications, and overall increase of refinery production of major fuel types. Refinery emissions of criteria air pollutants have decreased as much as 80% from 1990 to 2010. Emissions of hazardous air pollutants and their associated toxicity hazard potential have decreased nearly 70%. Furthermore, the emissions are not correlated with changes in crude oil sulfur content or density. Trends in annual criteria and hazardous air pollutant emissions and in crude oil density and sulfur content are compared to assess potential relationships between crude quality and refinery emissions. The potential toxicity of hazardous air pollutant emissions is evaluated using USEPA-derived toxicity criteria and then trended to demonstrate the overall reduction in toxicity hazard potential that has occurred. © 2012 American Institute of Chemical Engineers.
Wauhob T.,Sage Environmental Consulting
American Fuel and Petrochemical Manufacturers, AFPM - Environmental Conference 2014: Enforcement Initiatives | Year: 2014
Air emissions from polyethylene (PE) production are receiving more scrutiny as tracking and the shale gas boom has generated cost effective feedstock for ethane cracking and ethylene production. With the advent of self-reporting under the Title V program, it is important to ensure that appropriate Federal Regulatory applicability is evaluated and assigned for emission sources. This distinction can be unclear, especially in the case of voluntary air pollution control devices. Process design may have included control for dilute VOC vent streams that are below regulatory thresholds for control. To reduce future deviation risk, an applicability exercise is used to systematically characterize the exemption criteria of potentially applicable requirements. A vapor oxidizer example for a generalized production line is used in this paper to demonstrate a two-part compliance strategy to alleviate unnecessary compliance burden.