Question 28: The Clean Air Act required refineries to develop and implement a Leak Detection and Repair (LDAR) program to control fugitive emissions. What is the current status of this implementation and who is responsible for it in a typical refinery management structure: production, maintenance or EHS?
Greg Harbison (Marathon Petroleum)
Background/Regulatory Requirements:
Since the inception of the Clean Air Act of 1955 and multiple amendments through 1990, Leak Detection and Repair or LDAR regulations have been a part of air pollution control. Today’s LDAR programs are governed by Federal and State regulations and agreed orders (consent decrees) that provide the control of fugitive emission leaks from process equipment by requiring equipment inspections and leaking equipment repair. As such, the specific requirements can vary company to company or even between refineries operating in different states within the same company. Marathon complies with these regulations.
Equipment Inspections
Components that are LDAR applicable can vary by type and inspection or monitoring frequency. Generally, LDAR components consist of valves, pumps and compressors that are monitored on a quarterly basis. Monitoring requirements can be more stringent for units built or modified post November 2006 and can apply to flanges, connectors, fittings, hatches, and agitators (to name a
few). Process stream speciation determines the applicable regulatory requirements for streams. The typical streams requiring the most rigorous application of LDAR regulations include:
1. gas/vapor streams that are typically > 10% ethane and heavier,
2. light liquid streams are typically heavy naphtha or kerosene depending on specific stream properties, and
3. process streams containing greater than 5% hazardous air pollutants (benzene, methanol, toluene, etc.)
These monitoring requirements can be more or less frequent and have different leak definitions based on different applicable regulations. A leak definition is the threshold in parts per million that a component must reach to be considered leaking. LDAR monitoring is outlined in EPA Method 21, which states that a toxic vapor analyzer (TVA) must be used to assess total volatile organic compound (VOC) leaks from LDAR components. As LDAR regulations become stricter, the leak definitions are increasingly being lowered. With every change in regulation, the LDAR program becomes more challenging to manage since most facilities are required to stay below a facility wide leak percentage for leaking equipment (typically 2%). Thus, a rigorous and well-structured leak repair and maintenance portion of the LDAR program is vital to minimize emissions and maintain compliance.
Program Oversight
A practical LDAR program encompasses multiple people spread across many different job functions. Overall, it is our experience that a successful LDAR program can be successfully managed if several critical items are in place. These include dedicated personnel, a robust software database, good overall management system, well defined roles and responsibilities, and a comprehensive auditing system. At our refineries, it is typically the responsibility of the facility Environmental LDAR Coordinator (HES Professional) to manage and oversee all aspects of the LDAR program. We also use a contract company to conduct the emissions monitoring, and another contract company to make the initial leak repairs on valves (typically injection of a sealant into the valve packing area). Other LDAR applicable components such as motor operated valves (MOV’s), control valves, pumps and compressors are repaired when leaking by qualified individuals within the facility Maintenance Department. The requirements for completing the repairs are often sensitive to equipment and process functionality.
The LDAR Coordinator should have daily communication with the LDAR Monitoring Contractor to go over every open leak Work Order. This information is reviewed and an updated list of all leaks within the facility is given to the Contractor and facility Maintenance Department every day.
Overall, the regulations are complex and can generate an overwhelming amount of information based on the size of the facility and how many leaks are found above the leak definition. A large refinery could have upwards of 70,000 LDAR components governed by state and federal regulations as well as additional requirements from agreed orders. It is imperative to have a functional LDAR database that manages this information. The database should be capable of scheduling all monitoring and repair dates based on applicable regulations for the facility. The progress of the monitoring schedule needs to be easily accessible for all parties involved.
Question 45: What are the procedures/rules governing the transportation and disposal of catalyst contaminated with arsenic, mercury, barium, or other heavy metals? Are there maximum limits for any of these?
SHARPE (Flint Hills Resources, LP)
The spent catalyst needs to be shipped offsite and sent for metals reclamation or disposal. If it is going for disposal, it will have to be characterized to determine if 1) it is a hazardous waste, which it is most of the time, and 2) it meets the applicable Land Disposal Restrictions (LDRs). It would have to be treated, as part of disposal, to meet the LDRs.
Regarding transportation, if the catalyst needs to be shipped offsite for reclamation, it will have to be determined if it is hazardous material or contains hazardous substance. So by default, spent catalysts generally fit into that category. Take a look at the Hazardous Materials’ Table listed on the slide.
Overall, there are no maximum limits for disposal or transportation, but the catalyst does have to be transported and disposed of properly. It ends up being classified as a hazardous waste and subject to all the laws regarding that classification.
CHRIS STEVES (Norton Engineering)
The transportation and disposal of spent catalysts are governed by DOT (Department of Transportation) and RCRA (Resource Conservation and Recovery Act) regulations. A spent catalyst with leachable levels of arsenic, mercury, or barium (or five other regulated heavy metals) above their TCLP limit, will be regulated by the U.S. EPA (Environmental Protection Agency) as RCRA hazardous waste. If the material is spent hydrotreating catalyst from the petroleum refining industry, it will automatically be regulated as RCRA hazardous waste regardless of the metals content. Regulated RCRA hazardous waste must be properly disposed of at an approved treatment, storage, and disposal facility (TSDF). The actual levels of contamination will affect the options and cost for disposal. All RCRA hazardous wastes are regulated as DOT hazardous materials when shipped offsite, and all the basic rules for hazardous materials shipment must be followed.
Question 75: What are the potential problems or negative impacts of utilizing FCC slurry/decant oil as coke drum OH (overhead) line quench oil?
SRIVATSAN (Foster Wheeler USA Corporation)
Again, FCC slurry/decant oil has a similar distillation range to HCGO but a higher endpoint. Although it could possibly be used as just overhead quench, we caution that if the slurry/decant oil is not be filtered properly, it will contain catalyst fines that could accelerate the coke deposition by settling in equipment or piping. We normally recommend using the blowdown tower bottoms as the primary source for quenching the overhead vapor line. The secondary means of quenching is provided using HCGO. LCGO and other gas oils, including slops, can also be used as desired.
PRIBNOW (CITGO Petroleum Corporation)
We do not have any experience using slurry oil as coke drum overhead quench. We utilize slop oil, as Srini mentioned, as a way to vaporize and reprocess that material. We charged slurry oil to our coker when excess capacity was available. However, we found that it degraded the heavy coker gas oil quality back to the FCC. The FCC conversion drops, and catalyst becomes dark; so, we tend not to do that much anymore.
SRINI SRIVATSAN (Foster Wheeler USA Corporation)
The purpose of the coke drum overhead quench oil is to reduce coking reaction by lowering vapor temperature and mitigating coke formation. A portion of the overhead quench is also condensed and forms recycle. Foster Wheeler recommends using the blowdown tower bottoms liquid as the primary means to quench the overhead vapor line, the secondary being the use of HCGO. LCGO and other gas oils including slops can also be used as desired. FCC slurry/decant oil has a similar distillation range as HCGO with a higher endpoint. Although it could possibly be used as an overhead quench, we caution that if the slurry/decant oil is not filtered properly, it may contain catalyst fines that could accelerate coke deposition by settling in equipment or piping.
EBERHARD LUCKE (CH2M Hill)
Although I never worked in a unit that used FCC slurry/decant oil as quench oil, we used it as coker feed; so, my concerns are based on that experience. FCC slurry/decant oil carries a significant amount of cat fines that are difficult to remove from the stream. So I would assume that with the injection of the slurry/decant oil, these cat fines will be introduced into the coke drum overhead system. The fines will end up either on the inside of the vapor line, in the bottom of the fractionator, or carried even further through the system and will act as seeds for coke buildup and cause accelerated fouling/coking of equipment. The cat fines will also most likely cause erosion in the nozzle that is used for quench oil injection. Additionally, quench oil distribution will be poor (but can be fixed by the selection of the correct material).
ROBERTSON (AFPM)
Before we get to the last question, I want to remind you that the Crude P&P is this afternoon at 2:00. During that time, a lot of these issues we have covered will be discussed in more depth. Tomorrow, the Light Tight Oil and FCC P&Ps are run concurrently. If you have any other issues you want to discuss that were not raised in this forum, please attend those P&Ps.