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Black T.,Trihydro Corporation | Wood-Black F.,Trihydro Corporation
Journal of Chemical Health and Safety | Year: 2013

On March 26, 2012, the Occupational Safety and Health Administration (OSHA) issued its Final Rule on the new Hazard Communication Standard, 29 CFR 1910, 1915, and 1926, FR Vol. 77, No. 58, page 17574. This Final Rule modified the existing Hazard Communication Standard to conform the United Nations' Globally Harmonized system (GHS) of Classification and Labeling of Chemicals. Per the Summary provided by OSHA, the modifications outlined in the action would "significantly reduce costs and burdens while also improving the quality and consistency of information provided to employers and employees regarding the chemical hazards and associated protective measures.". While the aims as stated in the Summary and the modifications proposed seem minor there are some major challenges with the changes. As with any regulation or change, the challenges are not necessarily obvious to the common observer nor are they obvious to those charged with the implementation of the Final Rule. © 2013 Division of Chemical Health and Safety of the American Chemical Society.

Christopher J.,Trihydro Corporation
Society of Petroleum Engineers - SPE E and P Health, Safety, Security and Environmental Conference - Americas 2015 | Year: 2015

The U.S. Environmental Protection Agency (EPA) and several states have implemented, or propose to implement, new environmental regulations targeting air emission reductions from oil and gas facilities, including, for example, NSPS OOOO. As these programs mature, the industry is tasked with establishing increasingly complex compliance programs, including facilities that have not previously been subject to significant regulatory attention. While most operators have traditionally dealt with requirements established by the state oil and gas commissions, these regulations present a new type of concern for operators. Establishing systematic procedures and protocols can assist operators in meeting their compliance obligations in a consistent and defensible manner. The new air regulations often require testing or other observations, tracking data, and reporting obligations. Colorado's recently finalized Regulation 7 requirements often require the use of infrared cameras to observe hydrocarbon leakage from equipment, as well as audible, visual and olfactory (AVO) observations. While state regulations may not require procedures, training, or recordkeeping formats, it is in the operators' best interest to establish these steps to meet their internal requirements as well as establishing defensible data to demonstrate ongoing compliance. For example, if an infrared camera is used to detect hydrocarbon leaks, establishing a monitoring protocol ensures that the monitoring is conducted consistently, and that leak records will be tracked appropriately. A work practice procedure will establish responsibilities for tracking any discovered leaks, implementing maintenance requirements, and maintaining records to demonstrate compliance. When local operating personnel are responsible for compliance, establishing a training program and appropriate recordkeeping provisions will also help to ensure consistent program implementation. By establishing a systematic compliance effort, oil and gas operators can implement cost-effective strategies to meet these new compliance obligations. The optimal compliance approach will vary between operators based on internal resources and systems, and may require increasing staff resources or using external resources to meet these increasingly complex requirements. It is important for operators to consider these factors now to avoid unnecessary compliance hurdles down the road. Copyright 2015, Society of Petroleum Engineers.

Pruis J.,Trihydro Corporation | McAlexander B.,Trihydro Corporation
American Fuel and Petrochemical Manufacturers, AFPM - Environmental Conference 2015 | Year: 2015

Trihydro Corporation (Trihydro) is performing a pilot study using wind power as a "green" groundwater remediation technology. The purpose of the pilot study is to remediate dissolved phase contamination at a former refinery as a boundary control. A set of windmills with pneumatic diaphragm pumps generate compressed air that is distributed to a series of air sparge wells. Typically used for pond aeration, windmills are relatively inexpensive and do not require utility connections. This technology provides quick and easy installation at remote locations. In comparison to conventional air sparge system blowers, windmill air generation rates are low; therefore, this remediation technology uses a system to store compressed air and deliver it to the subsurface in discrete pulses. Such pulsing is performed entirely with a series of pneumatically powered mechanical valves bypassing the need for complex electronic controls (e.g. a PLC) that require electrical power, batteries, solar panels, etc. In additional to optimizing other operational parameters, the pilot study will evaluate if pulsing air can overcome the potential shortcomings of the relatively low windmill air generation rate and achieve a radius of influence (ROI) comparable to conventional systems. Mechanical design considerations and preliminary field results are also provided.

Knauf M.,Trihydro Corporation
Environmental Conference 2013 | Year: 2013

In July of 2012, refineries, along with other manufacturers, were required to submit chemical production information under the Toxic Substance Control Act's (TSCA) Chemical Data Reporting Rule (CDR). The CDR is the most comprehensive set of information on chemical substances and their proposed uses available to EPA and the public. While supporting several facilities with the CDR, Trihydro Corporation (Trihydro) faced several challenges during the 2012 submission period related to regulatory changes from the previous submission year and general reporting complications. Resolving the issues led Trihydro to develop best practices and recommendations to reduce the CDR burden for future reports. Since the CDR required reporting is every four years, Trihydro also recommends several practices that facilities should be doing in the meantime. Many of Trihydro's recommendations are based on knowledge of the 2012 reporting period and the current regulation, TSCA reform is underway in Congress. While much of the reform is proposed, facilities should be aware of potential changes to the regulation.

Walls S.,Trihydro Corporation | Knauf M.,Trihydro Corporation
American Fuel and Petrochemical Manufacturers, AFPM - Environmental Conference 2014: Enforcement Initiatives | Year: 2014

The U.S. Environmental Protection Agency (EPA) finalized new work practice standards for refinery flares on December 22, 2012. A component of the new work practice standard applicable to flares as cited in New Source Performance Standards (NSPS) Subpart Ja is the requirement to develop and implement a Flare Management Plan (FMP) for each affected refinery flare. The FMP for existing flares that have been or will be modified between June 24, 2008 and November 11, 2015 must be submitted to EPA for review by November 11, 2015. The FMP document is required to contain the following information: a listing of all flare connections, design and operational data for flare systems, an assessment of minimization alternatives, and an estimation of baseline flow for different operating scenarios. While supporting refineries in the development of FMPs, Trihydro Corporation (Trihydro) faced several challenges in identifying flare connections, capturing minimization practices, and estimating baseline flows. As such, this paper presents practical ideas and concepts that Trihydro believes will result in the efficient preparation of FMP's. Trihydro assisted refineries with the identification of flare connections by collecting data from historical flare studies and leveraging information from existing pressure relief valve databases. Additionally, Trihydro performed P&ID reviews to identify flare connections. Some of the P&ID reviews were performed with the refinery process engineering group which significantly reduced the review time. Trihydro also reviewed publicly available Flare Minimization Plans from California refineries to identify successful minimization practices. Refineries with flare gas recovery systems experience infrequent flaring events with short duration under normal operation, while experiencing short periods of high flow as a result of specific refinery activities. Refineries with flare gas recovery systems could benefit from developing a baseline flow for normal operation and a separate baseline flow for events that result in short periods of high flow such as vessel depressurization and purging. Refineries without flare gas recovery experience more constant flaring; however, based on our experience, these refineries may also benefit from developing multiple baseline flows for activities that result in higher relief gas flow volumes.

McAlexander B.L.,Trihydro Corporation
Environmental Impact Assessment Review | Year: 2014

Petroleum-contaminated site management typically counts destruction of hydrocarbons by either natural or engineered processes as a beneficial component of remediation. While such oxidation of spilled hydrocarbons is often necessary for achieving risk reduction for nearby human and ecological receptors, site assessments tend to neglect that this also means that the pollutants are converted to greenhouse gases and emitted to the atmosphere. This article presents a suggestion that the current and long term greenhouse gas emissions from spilled hydrocarbons be incorporated to petroleum site assessments. This would provide a more complete picture of pollutant effects that could then be incorporated to remedial objectives. At some sites, this additional information may affect remedy selection. Possible examples include a shift in emphasis to remedial technologies that reduce pollutant greenhouse gas effects (e.g., by conversion of methane to carbon dioxide in the subsurface), and a more holistic context for considering remedial technologies with low emission footprints. © 2014 Elsevier Inc.

Wood-Black F.,Trihydro Corporation
NPRA Environmental Conference Papers | Year: 2010

The Toxic Substance Control Act (TSCA) is a regulation that typically does not get much notice in the refining industry except when the periodic inventory update rule (IUR) comes around. According to the EPA, the next reporting period is from 6/1/2010 to 9/30/2011, with the calendar year 2010 being the reporting year. Each IUR period requires facilities to evaluate their production in terms of quantity and process to ensure that the TSCA report is completed accurately. A discussion on the TSCA, with emphasis on preparing for the IUR covers potential reforms and reviews of TSCA; details required by the IUR; data gathering and process steps necessary to complete the IUR; lessons learned from EPA audits; and insights from the current regulatory discussions. This is an abstract of a paper presented at the 2010 Environmental Conference (San Antonio, TX 9/20-21/2010).

The development of new technologies is generally exciting and offers a number of benefits to society and users. However, as these technologies are developed there is a bias towards the positive impacts and very little consideration to the potential negatives or thought toward what may be some of the unintended consequences. By focusing on a few case studies, this chapter will consider the unintended cosequences of societal choices, governmental regulations, diversion of resources, and ultimately the ethical implications of technological trends and potential solutions to the energy issue. © 2012 American Chemical Society.

Mcalexander B.L.,Trihydro Corporation | Tuggle K.V.,Trihydro Corporation
Remediation | Year: 2015

Greenhouse gas emissions assessments for site cleanups typically quantify emissions associated with remediation and not those from contaminant biodegradation. Yet, at petroleum spill sites, these emissions can be significant, and some remedial actions can decrease this additional component of the environmental footprint. This article demonstrates an emissions assessment for a hypothetical site, using the following technologies as examples: excavation with disposal to a landfill, light nonaqueous-phase liquid (LNAPL) recovery with and without recovered product recycling, passive bioventing, and monitored natural attenuation (MNA). While the emissions associated with remediation for LNAPL recovery are greater than the other considered alternatives, this technology is comparable to excavation when a credit associated with product recycling is counted. Passive bioventing, a green remedial alternative, has greater remedial emissions than MNA, but unlike MNA can decrease contaminant-related emissions by converting subsurface methane to carbon dioxide. For the presented example, passive bioventing has the lowest total emissions of all technologies considered. This illustrates the value in estimating both remediation and contaminant respiration emissions for petroleum spill sites, so that the benefit of green remedial approaches can be quantified at the remedial alternatives selection stage rather than simply as best management practices. © 2015 Wiley Periodicals, Inc.

Wood-Black F.,Trihydro Corporation
Journal of Chemical Health and Safety | Year: 2011

The Toxic Substance Control Act (Act or TSCA) has been in place since 1976 with the primary, goal of reducing risks to the environment or to human health from chemical exposure by implementing, controls at the point of their manufacture, distribution, use, and/or disposal. This Act provides the, Environmental Protection Agency (EPA) with the authority to require reporting, record-keeping and, testing requirements, and restrictions relating to chemical substances and/or mixtures. This work, describes some important changes to the Inventory Update Rule to take effect in 2011. © 2010.

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