Refinery-wide Maintenance Vent Compliance Program Development - - PowerPoint PPT Presentation

Refinery-wide Maintenance Vent Compliance Program Development Strategies

Presented by Phil Fish, Barr Engineering Co. – pfish@barr.com April 2018

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

MV Regulatory Background

• MPVs are broadly defined as gas streams

discharged from a process unit

• Dec. 2015 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

MPV Group Designations

Group 1 MPV

>72 lb VOC/day emissions Route to flare, heater or CE

MV>72

>72 lb VOC inventory Measure LEL (or <5 psi)

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 Document calculations

MVBlinding

<2 psi (proposed) Document justification

Individual MV Compliance Flow Chart

• Three basic steps:

1. Determine applicability (before event) 2. Control and monitor emissions for compliance (during event) 3. Complete required recordkeeping and reporting

Phased Compliance Strategy

Steering I

• What are the interpretations, assumptions and

risks with different compliance approaches?

• Who is responsible for certain tasks?

Mobilizing II

• How will each piece of equipment comply?
• How do we estimate VOC emissions or the mass

contained?

Implementing III

• How do we manage compliance on a day-to-day

basis for individual equipment maintenance?

• How do we manage compliance for large unit

TARs?

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

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

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.

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

Mobilizing Phase - Calculation Refinement Hierarchy

Worst-case

• Saturated temperature
• Maximum pressure per Safety
• Process stream speciation

Refinements

• Steam / nitrogen purging
• Realistic T&P
• Equipment measurements

Empirical Data

• Method 21 screening
• Method 18 bag sampling
• Field-measured T&P

Increasing effort Increasing accuracy Increasing sensitivity to changes

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

Reference- Volume (RV) Screening Approach

>72 lb VOC

• Towers
• Reactors
• Drums
• Small drums w/ piping
• Large HX w/ piping
• Long piping runs

<72 lb VOC

• HX
• Pumps
• Filters

VOC 72 lb

WPS (LEL or, if cannot measure LEL, <5 psi) MV Calculation Documentation (or possibly treat as G2 MPV)

Compliance Demonstration Strategy

Volume RV (X ft3)

Three-Groups Screening Approach

>72 lb VOC

• Towers
• Reactors
• Drums

Approx 72 lb VOC

• Small drums w/ piping
• Large HX w/ piping
• Long piping runs

<72 lb VOC

• HX
• Pumps
• Filters

VOC 72 lb

WPS (LEL or, if cannot measure LEL, <5 psi) MV Calculation Documentation (or possibly designate as G2 MPV) WPS

• r

MV Calculation Documentation

Compliance Demonstration Strategy

Volume V72 (X ft3)

RV or V72 Process Engineer Questionnaire Workflow

Equipment List RV or V72 Analysis Unit Process Engineer Questionnaire Equipment <<RV or V72 Equipment ~V72±X% Equipment >>RV or V72

Refine

• r WPS

Done – MV Calculation Documentation Refine

• r WPS

Three-Groups Approach Only

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
• perations

− Safe Work Permits − Separate MV documents or inventories listing equipment subject to WPS

• Establishing procedures for evaluating

venting during upcoming turnarounds

• Develop recordkeeping procedures

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/V72 calculations

Program Improvement Strategies

• The goal is to reduce compliance burden
• r 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

Thank you

Contact information: Phil Fish Barr Engineering Co. (952) 842-3643 pfish@barr.com