EPA-4SO/2-77-025
October 1977
(OAQPS NO. 1.2-081)
GUIDELINE SERIES
CONTROL OF REFINERY
VACUUM PRODUCING SYSTEMS,
WASTEWATER SEPARATORS
AND PROCESS UNIT
TURNAROUNDS
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
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EPA-450/2-77-025
(OAQPS NO. 1.2-081)
CONTROL OF REFINERY VACUUM
PRODUCING SYSTEMS, WASTEWATER
SEPARATORS AND PROCESS
UNIT TURNAROUNDS
Emissions Standards and Engineering Division
Chemical and Petroleum Branch
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
October 1977
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OAQPS GUIDELINE SERIES
The guideline series of reports is being issued by the Office of Air Quality
Planning and Standards (OAQPS) to provide information to state and local
air pollution control agencies; for example, to provide guidance on the
acquisition and processing of air quality data and on the planning and
analysis requisite for the maintenance of air quality. Reports published in
tnis series will be available - as supplies permit - from the Library Services
Office (MD-35), Research Triangle Park, North Carolina 27711; or, for a
nominal fee, from the National Technical Information Service, 5285 Port
Royal Road, Springfield, Virginia 22161.
Publication No. EPA-450/2-77-025
(OAQPS No. 1.2-081)
11
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TABLE OF CONTENTS
Page
Chapter 1.0 Introduction 1-1
1.1 Need to Regulate Petroleum Refineries 1-1
1.2 Sources and Controls of Hydrocarbons from Refineries .. 1-2
1,3 Regula tory Approach 1-3
Chapter 2.0 Sources and Types of Emissions , 2-1
2.1 Vacuum Producing Systems 2-1
2.2 Wastewater Separators 2-6
2.3 Process Unit Turnarounds 2-7
2.4 References 2-9
Chapter 3.0 Emission Control Techniques 3-1
3.1 Vacuum Producing Systems 3-1
3.2 Wastewater Separators 3-1
3.3 Process Unit Turnaround 3-2
3.4 References < 3-5
Chapter 4.0 Cost Analysis 4-1
4.1 Introduction 4-1
4.2 Control of Emissions from Vacuum Producing Systems 4-5
4.3 Control of Emissions from Wastewater Separators 4-11
4.4 Control of Emissions from Process Unit Turnarounds 4-11
4.5 Cost Effectiveness 4-13
4.6 References 4-15
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Page
Chapter 5,0 Effects of Applying the Technology 5-1
5.1 Impact of Control Techniques on Volatile Organic
Compound Emissions 5-1
5.2 Other Environmental Impacts 5-2
5.3 Energy Impact 5-2
5.4 Summary 5-4
5. 5 References 5-4
Chapter 6.0 Enforcement Aspects , 6-1
6.1 Affected Facility 6-1
6.2 Format of Regulation 6-1
6.3 Compl iance and Monitoring 6-2
IV
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LIST OF TABLES
Page Page
Table 2-1 Typical Vacuum Jet Non-Condensable Hydrocarbon Vapor
Concentration 2-3
Table 4-1 Technical Parameters Used In Developing Control
Costs 4-3
Table 4-2 Cost Parameters Used in Computing Annualized Costs 4-7
Table 4-3 Control Cost Estimates For Model Existing Petroleum
Refinery Emission Sources 4-10
Table 5-1 Volatile Organic Compound Emission Reduction 5-3
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LIST OF FIGURES
Page
Figure 2-1 Vacuum Producing System Utilizing a Two Stage Contact
(Barometric) Condenser 2-4
Figure 2-2 Vacuum Producing System Utilizing Booster Ejector For
Low-Vacuum Systems 2-5
Figure 3-1 Corrugated Plate Interceptor 3-3
Figure 3-2 API Separator With Floating Roof Cover 3-3
VI
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ABBREVIATIONS AND CONVERSION FACTORS
EPA policy is to express all measurements in agency documents in
metric units. Listed b^lo., are abbreviations and conversion factors
for British equivalents of metric units-
Abbreviations
kg - kilogram
m - cubic meter
m - square meter
m ton - metric ton
Mg - megagram
3 ^
kg/10 ,11° - kilograms per thousand cubic
meters
m /day - cubic meters per day
Conversion Factor
kg X 2.2 = pound (Ib)
Ib X 0.45 = kg
m3 X 0.16 = barrel (bbl)
bbl X 6.29 = m3
m2 X 10.8 = square feet (ft2)
ft2 X 0.093 = m2
m ton X 1.1 = ton
ton X 0.91 = m ton
Mg = m ton
kg/103m3 X 0.35 = lb/103bbl
lb/103bbl X 2.86 = kg/103m3
m3/day X 0.16 = bbl/day
bbl/day X 6.29 = m3/day
Frequently used measurements in this document
15,900 m/day
5560 m3/day
30.5 m
61 m
100,000 bbl/day
35,000 bbl/day
100 ft
200 ft
122 m
9.3m2
465m2
$81.80/nT
400 ft
100 ft2
5000 ft 2
$13.00/bbl
vii
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1.0 INTRODUCTION
This document is related to the control of volatile organic
compounds (VOC) from petroleum refineries. The specific sources discussed
herein are vacuum producing systems, wastewater separators, and process
unit turnarounds, (i.e. shutdown, repair or inspection and start UD of a
process unit). A program for monitoring and maintenance of leaks from
pumps, compressors, valves, etc. will be discussed in a future document.
The VOC emitted from these sources are primarily C~ through Cfi paraffins
and olefins which are photochemically reactive (precursors of oxidants).
1.1 NEED TO REGULATE PETROLEUM REFINERIES
Many State or local regulations governing petroleum refineries
require the same controls outlined in this document. Some areas still
exist, however, where these sources are not controlled. Estimated annual
nationwide emissions from vacuum producing systems, wastewater separators,
and process unit turnarounds are currently 730,000 metric tons. This
represents 3.8 percent of total VOC emissions from stationary sources.
Control techniques guidelines are being prepared for those
industries that emit significant quantities of air pollutants in areas
of the country where National Ambient Air Quality Standards (NAAQS) are
not being attained. Petroleum refineries are a significant source of
VOC and tend to be concentrated in areas where the oxidant NAAQS are
likely to be exceeded.
1-1
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1.2 SOURCES MO CONTROLS OF VOLATILE ORGANIC COMPOUNDS FROM REFINERIES
Volatile organic compounds are emitted to the atmosphere from
vacuum producing systems by direct venting of non-condensable streams.
These VOC are controlled by venting to a firebox in many existing
refineries. The installed capital cost of controlling vacuum pro-
ducing systems in a refinery that processes 15,900 cubic meters of
crude oil per day is estimated to be $23,700 when surface condensers or
vacuum pumps are used and $49,600 when contact condensers are used.
Due to the value of the recovered product, controlling vacuum producing
systems results in a credit of $115 or $106 per metric ton of emission
reduction, respectively, for the two systems.
VOC are also emitted from uncovered wastewater separators. Large
reductions in hydrocarbon emissions can be accomplished through covering
these separators. The capital cost of covering a 465 square meter
forebay and separator at a 15,900 cubic meter per day refinery is
$62,800. Again due to the value of the product recovered, the
operator realizes a net credit of $100 for each metric ton of emission
reduced.
When a process unit is depressurized during a turnaround, VOC
can be emitted to atmosphere. These emissions can be controlled by
piping the VOC to a flare or to the fuel gas system. The capital cost
for piping is approximately $97,600 for a 15,900 cubic meter per day
refinery. If no hydrocarbons are recovered (all flared), the cost
effectiveness is a cost of $5.00 per metric ton of emission reduction.
However, if the hydrocarbons are recovered as fuel gas, a net credit
of $100 per metric ton of emission reduction is realized by the operator,
1-2
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1.3 REGULATORY APPROACH
Regulations for vacuum producing systems and wastewater separators
should be written in terms of equipment specifications and regulations
for process unit turnarounds should be written in terms of operating
procedures. It is suggested that non-condensables from vacuum producing systems
should be combusted in a firebox and the wastewater separators be covered.
Also, all process units should be depressurized to a flare, fuel gas
system or to some other combustion device before being opened for inspection
or maintenance. These controls represent the presumptive norm that can
be achieved through the application of reasonably available control
technology (RACT). Reasonably available control technology is defined
as the lowest emission limit that a particular source is capable of meeting
by the application of control technology that is reasonably available
considering technological and economic feasibility. It may require
technology that has been applied to similar, but not necessarily identical
source categories. It is not intended that extensive research and
development be conducted before a given control technology can be applied to
the source. This does not, however, preclude requiring a short-term
evaluation program to permit the application of a given technology to a
particular source. This latter effort is an appropriate technology-forging
aspect of RACT.
1-3
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2.0 SOURCES AND TYPES OF EMISSIONS
Petroleum refining is the third largest industry in the United
States and represents a potential volatile organic compound (VOC) emission
problem by virtue of the large quantities of petroleum liquid refined and
the intricacy of the refining process. The major point sources of VOC
emissions from petroleum refineries considered in this document
include (1) vacuum producing systems, (2) wastewater separators, and
(3) process unit turnarounds. The emissions from these sources will vary
from one petroleum refinery to another depending upon such factors as
refinery size and age, crude type, processing complexity, application
of control measures, and degree of maintenance. Emissions from other
potential point sources of VOC emissions such as process heaters and
boilers, fluid catalytic cracker regenerators, sulfur plants, equipment
leaks, and storage tanks are not addressed.
2.1 VACUUM PRODUCING SYSTEMS
The vacuum producing systems attendant to vacuum distillation
and other refinery processes are potential sources of atmospheric
emissions of VOC. Three types of vacuum producing systems may be used
for refinery distillation:
Steam ejectors with contact condensers.
Steam ejectors with surface condensers.
Mechanical vacuum pumps,
2-1
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Vacuum is created within a vacuum producing system by removal of
non-condensable gases and process steam by steam jet ejectors. Non-
condensables consist primarily of (1) light ends from incomplete
fractionation of the feed, (2) gases produced by cracking or overheating
of the feedstock, and (3) air dissolved in charge stock and in water used
in generating steam. A typical composition of the non-condensable stream
is 75 percent hydrocarbons, 9 percent hydrogen sulfide, 5 percent carbon
monoxide, 3 percent hydrogen and 8 percent air. The uncontrolled hydro-
carbon emission factor for all types of vacuum producing devices is 170
O O p
kilograms per thousand cubic meters (kg/10 m ) of refinery throughput.
The composition of the hydrocarbons is shown in Table 2-1. It can be
seen that about 85 weight percent or 145 kg/10 m of these emissions
are VOC.
2.1.1 Steam Ejectors with Contact Condensers
Direct contact or barometric condensers are used for maintaining
a vacuum by condensing the steam used in the ejector jet plus steam removed
from the distillation column. In the contact condenser, condensable
VOC and steam from the vacuum still and the jet ejectors are condensed
by intimately mixing with cold water. The non-condensable VOC is
frequently discharged to the atmosphere. A two stage steam jet ejector
is shown in Figure 2-1 and a three stage ejector with a booster is shown in
Figure 2-2. These are typical of vacuum producing systems used in existing
refineries.
2-2
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Table 2-1. TYPICAL VACUUM JET O-CONDENSABLE HYDROCARBON
VAPOR CCNCENTRATION3
Hydrocarbon
Methane*
Ethane*
Ethyl ene
Propane**
Butanes
Butenes
Pentanes
Pentenes
Hexanes
Hexenes
Benzene
Heptenes
Volume
Percent
23.0
10.5
0.8
12.5
26.1
3.2
16.5
4.4
1.9
0.8
0.2
0.1
Weight
Percent
7.8
6.7
0.5
11.7
32.3
3.8
25.3
6.6
3.5
1.4
0.3
0.1
100
100
* Non-reactive hydrocarbons
** Low reactive hydrocarbons
?_'
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Figure 2-1. VACUUM PRODUCING SYSTEM UTILIZING A TWO STAGE CONTACT
(BAROMETRIC) CONDENSER4
WATER
INCOMING
NONCONDENSABLES
AND PROCESS
STEAM
BAROMETRIC LEG
BAROMETRIC
CONDENSERS
m STEAM
i
JL 2nd STAGE
t
TO ATMOSPHERE
OR TO A
CONDENSER FOR
JET STEAM
HOT WELL
2-4
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Figure 2-2. VACUUM PRODUCING SYSTEM UTILIZING BOOSTER
EJECTOR FOR LOW-VACUUM SYSTEMS5
JET STEAM
CONDENSER WATER
INCOMING
NONCONDENSABLES
AND PROCESS STEAM
BAROMETRIC LEG
H HOT WELL
3rd STAGE
I
TO ATMOSPHERE
OR A CONDENSER
OR TO OTHER
NONCONDENSING
STAGES
2-5
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2.1.2 Steam Ejectors with Surface Condensers
Modern refiners favor the use of surface condensers instead of
contact condensers. In a surface condenser, non-condensables and
process steam from the vacuum still, mixed with steam from the jets, are
condensed by cooling water in tube heat exchangers and thus do not come
in contact with cooling water. This is a major advantage since it reduces
by twenty-five fold the quantity of emulsified wastewater that must be
treated. A disadvantage of surface condensers is their greater initial
investment and maintenance expense for the heat exchangers and additional
cooling tower capacity necessary for the cooling water.
2.1.3 Mechanical Vacuum Pumps
Steam jet have been traditionally favored over vacuum pumps.
Recently, however, due to higher energy costs for generating-steam, and
cost for disposing of wastewater from contact condensers, vacuum pumps
are being used. In addition to energy savings, vacuum pumps have greatly
reduced cooling tower and/or wastewater treatment requirements compared
to steam ejector systems. Aside from the stripping steam, the ejected
stream is essentially all hydrocarbon so it can be vented through a small
condenser before being combusted in a flare or sent to the refinery fuel
gas system.
2.2 WASTEWATER SEPARATORS
Contaminated wastewater originates from several sources in
petroleum refineries including, but not limited to, leaks, spills, pump
and compressor seal cooling and flushing, sampling, equipment cleaning,
2-6
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and rain runoff. Contaminated wastewater is collected in the process
drain system and directed to the refinery treatment system where oil
is skimmed in a separator and the wastewater undergoes additional
treatment as required.
Refinery drains and treatment facilities are a source of emissions
due to evaporation of VOC contained in wastewate^. VOC will be emitted
wherever wastewater is exposed to the atmosphere. As such, emission points
include open drains and drainage ditches, manholes, sewer outfalls, and
surfaces of forebays, separators and treatment ponds. Due to the
safety hazards associated with hydrocarbon-air Fixtures in refinery
atmospheres, current refinery practice is to seal sewer openings and use
liquid traps downstream of process drains, thus minimizing VOC emissions
q
from drains and sewers within the refinery. The emission factor
33 9
for wastewater separators is 570 kg/10 m of wastewater processed. All
of these emissions are assumed to be reactive.
2.3 PROCESS UNIT TURNAROUNDS
Refinery units such as reactors, fractiorators, etc. are periodically
shut down and emptied for internal inspection end maintenance. The process
of unit shutdown, repair or inspection and start-up is termed a unit
turnaround. Purging the contents of a vessel to provide a safe
interior atmosphere for workmen is termed a vessel blowdown. In a typical
process unit turnaround liquid contents are pulped from the vessel to some
available storage facility. The vessel is then depressurized, flushed
with water, steam, or nitroqen and ventilated. Depending on the refinery
2-7
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configuration, vapor content of the vessel may be vented to fuel gas
system, flared, or released directly to atmosphere. When vapors are
released directly to atmosphere, it is through a blowdown stack which is
usually remotely located to ensure that combustible mixtures will not
be released within the refinery. The emission factor for refinery process
unit turnaround is 860 kg/10 m of refinery throughput.
2-8
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2.4 REFERENCES
1. Personal communication be::«een R. Fritz, Exxon Research and
Engineering, Florham Park, New Jerse-,and Monsanto Research Corporation,
May 3, 1976,
2. "Revision of Evaporative -. rrocarbon Emission Factors,"
EPA Report No. 450/3-76-039, Radian lorporation, August 1976.
3. "Screening Study for Vacua- Distillation Units in Petroleum
Refineries," EPA Report No. 450/3-7?-330, Monsanto Research Corporation,
December 1976.
4. Ibid.
5. Ibid.
6. "A Program to Investigate Carious Factors in Refinery Siting,"
Council on Environmental Quality anc the Environmental Protection Agency,
Radian Corporation, July 1974.
7. Monroe, E.S., "Vacuum Pumcj Can Conserve Energy." The Oil
and Gas Journal, February 3, 1975.
8. Letter with attachments fr:m R. E. Van Ingen, Shell Oil
Company to Don R. Goodwin, EPA. Je^ary 10, 1977.
9. "Emissions to the Atmosphe-e From Eight Miscellaneous Sources
in Oil Refineries." Joint District. redera1 and State Project for the
Evaluation of Refinery Emissions. :fjort No. 8, June 1958.
10. "Revision of Evaporative Emission Factors," op. cit.
2-9
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3.0 EMISSION CONTROL TECHNIQUES
This chapter describes existing technology for control of volatile
organic compound (VOC) emissions from vacuum producing systems, wastewater
separators, and process unit turnarounds. The effect these controls have
on the emission of other air pollutants, water pollution, solid waste and
energy is discussed in Chapter 5, Effects of Applying the Technology.
3.1 VACUUM PRODUCING SYSTEMS
Steam ejectors with contact condensers, steam ejectors with
surface condensers, and mechanical vacuum pumps all discharge a stream
of non-condensable VOC while generating the vacuum. Steam ejectors
with contact condensers also have potential VOC emissions from their
hot wells. VOC emissions from vacuum producing systems can be prevented
by piping the non-condensable vapors to an appropriate firebox, incinerator,,
or (if spare compressor capability is available) compressing the vapors
and adding them to refinery fuel gas. The hot wells associated with
2
contact condensers can be covered and the vapors incinerated. Controlling
vacuum producing systems in this manner will result in negligible emissions
of hydrocarbons from this source. Such systems are now in commercial
operation and have been retrofitted in existing refineries.
3.2 WASTEWATER SEPARATORS
Reasonable control of VOC emissions from wastewater separators consists
of covering the forebays and separator sections thus minimizing the amount 01
3-1
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oily water exposed to atmosphere. Commercially operating systems
include (1) a solid cover with all openings sealed totally enclosing
the compartment liquid contents and (2) a floating pontoon or double-
deck type cover, equipped with closure seals to enclose any space
between the cover's edge and compartment wall. Also, any gauging
and sampling device in the compartment cover can be designed to provide
a projection into tha liquid surface to prevent VOC from escaping.
The sampling device can also be equipped with a cover or lid that is
in a closed position at all times except when the device is in actual
use. Figure 3-1 shows a corrugated plate interceptor (CPI) wastewater
separator. The CPI Is smaller than the API separator (Figure 3-2) and
is especially effective when used in the processing unit area for initial
c
oil-water separation. A CPI is inherently controlled by a fixed roof
cover. Figure 3-2 shows an API wastewater separator with a floating
roof cover. The emission factor for wastewater systems controlled by
33 6
covering the forebay and separator is 30 kg/10 m of refinery throughput.
3.3 PROCESS UNIT TURNAROUND
As stated in Chapter 2 a typical process unit turnaround would
include pumping the liquid contents to storage, purging the vapors by
depresburizing, flushing the remaining vapors with water, steam or
nitrogen, and ventilating the vessel so workmen can enter. The major
potential source of VOC emissions is depressurizing the vapors to the
atmosphere. After t^e vapors pass through a knockout pot to remove
the condensable hydrocarbons, the vapors can be either added to the
fuel gas system, flared, or directly vented to atmosphere. Atmospheric
emissions will be greatly reduced if the vapors are combusted as fuel gas
3-2
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Figure 3.1 Corrugated Plate Interceptor
LIGHT
COMPONENTS
HEAVY
OMPONENTS
Figure 3.2 API Separator with Floating Roof Cover'
8
PUM
Lilt
3-3
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or flared until the pressure in the vessel is as close to atmospheric
pressure as practicably possible. The exact pressure at which the vent
to the atmosphere is opened will depend on the pressure drop of the
disposal system. Most refineries should easily be able to depressurize
processing units to five psig or below before venting to the atmosphere.
Many refineries depressurize a vessel to almost atmospheric pressure
followed by steaming the vessel to the flare header before opening to
atmosphere. ' ' In some refineries the hydrocarbon concentration
19
is as low as 1 to 30 pe-vent before the vessel is vented to atmosphere.
The emission factor for controlling process unit turnaround by de-
pressurizing to flare is 15 kg/"0 m of refinery throughput.
3-4
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3.4 REFERENCES
1. Kinsey, R.H. Air Pollution Engineering Manual, 2nd Edition,
AP-40, EPA May 1973.
2, Letter with Enclosures from B.A. McCrodden, Standard Oil
Company of Ohio, to J. L, Delaney, Monsanto Research Corporation,
June 16, 1976.
3. "Revision of Evaporative Hydrocarbon Emission Factors,"
EPA Report No, 450/3-76-039, Radian Corporation, August 1976.
4. Emissions to the Atmosphere from Eight Miscellaneous
Sources in Of! Refineries," Joint District, Federal and State
Project for the Evaluation of Refinery Emissions. Report No. 8.
June 1958,
5. Trip Report on Visit to Four New Orleans, Louisiana
Petroleum Refineries from Kent C. Hustvedt to James F. Durham, EPA,
dated December 8, 1976.
6. "Revision of Evaporative Hydrocarbon Emission Factors,"
op. cit.
7. "Evaluation of Pollution Potential of Proposed Hampton
Roads Energy Company Refinery, Portsmouth, Virginia," Pacific
Environmental Sciences, Inc., EPA Report No. 450/3-76-037, November 1S'76.
8. Kinsey, R.H. op. cit.
9. Letter with attachments from Carleton B, Scott, Union Oi"
Company of California, to Don R. Goodwin, EPA, December 3, 1976.
3-5
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10. Letter with attachments from L. Kronenberger, Exxon Company,
U.S.A.,to Don R. Goodwin, EPA, February 2, 1977.
11. Letter with attachments from I.H. Gilman, Standard Oil
Company of California, to Don R. Goodwin, EPA, November 30, 1976.
12. Letter with attachments from R. E. Van Ingen, Shell Oil
Company, to Don R. Goodwin, EPA, January 10, 1977.
13. "Revision of Evaporative Hydrocarbon Emission Factors,"
op. cit.
3-6
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4.0 COST ANALYSIS
4.1 INTRODUCTION
4.1.1 Purpose
The purpose of this chapter is to present estir.:ted costs for
control of volatile organic compound (VOC) emissions from refinery
sources at existing petroleum refineries.
4.1.2 Scope
Estimates of capital and annualized costs are presented for
controlling emissions from three existing refinery sources (facil ities)--
vacuum producing systems, waste water separators, and process unit
turnarounds. The two emission control techniques used to control the
three sources are (1) covers for wastewater separators and (2) piping
to firebox(es) or flare header system(s) for emissions from vacuum
producing systems and process unit turnarounds. Control costs are
developed for an existing medium size model petroleji refinery with
throughput of 15,900 m^/day. Cost effectiveness measures, such as
annual ized costs/credits perMg of controlled emissions, are shown for
the three facilities.
4.1.3 Use of_ Model Emission Sources
Petroleum refineries vary considerably as to s~:e, configuration
and age of facilities, product mix, and degree of control. Because of
the difficulties of typifying refinery configurations, this cost analysis
is based on a medium size model refinery rather than on a series of
typical refineries.
4-1
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Table 4-1 lists the technical parameters used for the three
model emission sources—vacuum producing systems, wastewater separators,
and process unit turnarounds. Parameters are shown for two types of
vacuum producing systems—those using surface condensers or mechanical
vacuum pumps and those using contact (barometric) condensers. The
parameters were selected as being representative of existing facilities
2
based on information from an American Petroleum Institute oublication,
petroleum refineries, equipment vendors, a major refinery contractor,3
and a leading oil industry journal survey. Although model point source
control costs may differ, sometimes appreciably, with actual costs
incurred, they are the most useful means of determining and comparing
emission control costs.
4.1.4 Bases for Capital and Annualized Cost Estimates
Capital cost estimates represent the total investment required
to purchase and install a particular control system. Cost estimates
were obtained from petroleum refineries, equipment vendors and a major
refinery contractor. Retrofit installations are assumed. Costs for
research and development, production losses during installation and
start-up, and other highly variable costs are not included in the
estimate^. All capital costs reflect second quarter 1977 dollars.
Annualized control cost estimates include operating labor, maintenance,
utilities, credits for petroleum recovery, and annualized capital charges.
Credits for petroleum recovery have been calculated using EPA emission
factors for the emission sources. For the purposes of recovery credits,
all emissions are considered to be equivalent to light crude oil.
4-2
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II.
Ill
Table 4-1. TECHNICAL PARAMETERS USED IN
DEVELOPING CONTROL COSTS9
Refinery Throughput:
15,900 m3/day
VOC Emission Factors:
Before
Control
(Kg/lOV)
145
570
860
Control
Efficiency
(%)
100
95
98
After
Control
(Kg/103mJ)
0
30
15
IV.
Vacuum Producing Systems:
Wastewater Separators:
Process Unit Turnarounds:
Recovered Emissions Factors
Vacuum Producing Systems;k
Wastewater Separators:
Process Unit Turnarounds:0
Operating Factor:
365 days per year.
Vacuum Producing Systems Using either Surface Condensers p_r_
Mechanical Vacuum Pumps:
VPS Throughput:6 5,560 m3/day
Piping: 61.0 m length
Valves: 6 plug type
Flame Arrestor: One metal gauze type
Recovered Petroleum
170 Kg/103m3
540 Kg/103m3
0 Kg/103m3 (none)
or 845 Kg/103m3 (all)
4-3
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VI- Vacuum Producing Systems Using Contact (Barometric) Condensers
VPS Throughput:6 5,560 m3/day
Piping: 122.0 m length
Valves: 12 plug type
Flame Arresters: 2 metal gauze type
Hot well cover area: * 9.3 m2
VII. Wa s t ewa t e r Se p a ra to r Are a:^
465 m2
III. Process Unit Turnarounds:
Number of Process Units: 10
Piping: 30.5 m length per unit
Valves: 2 plug type per unit
1^- Diameters of Piping, Valves and Flare Arrestors:"
5.1 cm to 20.3 cm
Except as noted, parameter values are taken from Chapters 1,2,3 and 5.
It is assumed that all of the emissions (170 Kg per 103m3 of refinery
throughput) will be recovered, but that only the reactive emissions
(85 weight percent of the total or 145 Kg per 103m3 of throughput) will
be counted as controlled emissions.
Recovering none or all of the emissions corresponds to the minimum or
maximum amounts possible; the actual amount recovered by a refinery
may be anywhere between these values.
EPA estimate.
Based on average size of VPS for U.S. refineries per Reference 4.
References 5 and 6.
-Reference 2.
References 3,7 and 8,
4-4
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The annualized capital charges are sub-divided into capital
recovery costs (depreciation and interest costs) and costs for property
taxes, insurance and administration. Depreciation and interest costs
have been computed using a capital recovery factor based on a 10 year
depreciation life of the control equipment and an interest rate of 10%
per annum. Costs for property taxes, insurance and administration are
computed at 4% of the capital costs. All annualized costs are for one
year periods commencing with the second quarter of 1977.
4.2 CONTROL OF EMISSIONS FROM VACUUM PRODUCING SYSTEMS
4-2.1 Mode], Cost Parameters
The recommended technique for vacuum producing systems (VPS) is
by piping controlled VQC emissions to a firebox, (see section 3.1).
Table 4-2 presents cost parameters for VPS control equipment and
includes cost data for four typical diameters and two common materials
of piping, valves and flame arresters. Piping cost parameters are
given for 30.5m lengths so that actual lengths needed by refineries may
be estimated in multiples of 30.5 m. These parameters are based on
data from petroleum refineries^'"5'<»12,13 equipment vendors ''
•3 Q
a major refinery contractor * and EPA estimates.
4.2.2 Control Costs
Table 4-3 shows the estimated costs of controlling VOC emissions
from two types of vacuum producing systems--VPS using contact (barometric)
condensers and VPS using surface condensers or mechanical vacuum pumps.
The former VPS control equipment consists of two pipe lines (with
valves, flame arrestor and by-pass) and a hot well cover. The latter
4-5
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VPS control equipment is only one pipe line (with valves, flame
arrester and by-pass). This cost analysis assumes that all of the
emissions will be recovered, but that only the reactive emissions
will be counted as controlled emissions. Thus, the petroleum credit
is based on recovering 170 Kg of emissions per 103p3 of refinery
throughput while the controlled emissions is based on 145 Kg of emissions
per lOV of refinery throughput (85 weight percent of total emissions).
It is also assumed that existing refineries have all other equipment
needed to control emissions, such as compressors, condensers, hot
wells, accumulators, Dumps and etc. Thus, the costs of this equipment
are not included in the analysis.
From Table 4-3, it is seen that the control technique for VPS
using surface condensers or mechanical vacuum pumps has an estimated
capital cost of $23,700, but should result in a net annualized credit
(savings) of about $96,700 for a medium sized refinery. The cor-
responding estimates for VPS using contact (barometric) condensers are
$51,600 and $89,000. The credits are due to the value of the recovered
petroleum. These cost estimates are based on the use of 15.2 cm diameter
304 stainless steel piping, 316 stainless steel plug valves, 316 stainless
steel metal gauze flame arresters and 6.3 mm plate 304 stainless steel
hot well covers. Stainless steel control devices are used because of the
potential corrosive nature of the hydrocarbon streams.
4-6
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Table 4-2. COST PARAMETERS USED IN COMPUTING ANNUALIZED COSTS
I. Recovered Petrol earn Value:a
$8l.80/m3
II. Piping
Installed Capital Cost per 30.5m:
Material Diameter
5.1 cm 10.2 cm 15.2 cm 20.3 cm
Carbon Steel $1120 $1770 $2325 $2890
304 Stainless Steel $2780 $5290 $7760 $10,470
Annual Operating and Maintenance Cost:0
4% of Installed Capital Cost
Life:d 10 years
III. Plug Type Valves:
Purchase Prices:6 Diameter
ASTM A 216-60
316 Stainless Steel
Installation Cost:f
10 hr @ $!3.00/hr
Annual Operating and Maintenance Cost:d
15% of Installed Capital Cost
Life:6 10 years
5.1 cm
$125
$150
10.2 cm
$360
$450
15.2 cm
$675
$870
20.3 cm
$1200
$1410
4-7
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IV. Metal Gauze F1ame Arrestors:
Purchase Prices:9 Diameter
5.1 cm 10.2 cm 15.2 cm 20.3 cm
Ductile iron with 4.8mm
stainless steel grid $230 $550 $980 $1730
316 stainless steel with
4.8mm stainless steel grid $550 $1280 $2030 $3830
Installation Cost:^
10 hr @ $13.00/hr
Annual Operating and Maintenance Cost: '9
15% of Installed Capital Cost
Life:9 10 years
V. Hot Well Covers: (9.3 m2 area)
Installed Capital Cost:1"'"'1 $4,200
Annual Operating and Maintenance Cost:c
4% of Installed Capital Cost
Life: 10 years9
VI. Wastewater Separator and Forebay Covers;
Installed Capital Cost;J
$135/m2
Annual Operating and Maintenance Cost:f
10% of Installed Capital Cost
Life: 10 years
EPA estimate for light crude oil.
4-8
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References 3 and 9; based on piping material cost plus labor
cost of $15.00/hr for field welding and $13.00/hr for erection,
Referece 6.
Reference 3.
eReference 7.
EPA estimate.
^Reference 8.
Reference 5.
1 Reference 10.
^References 11, 12 and 13.
4-9
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Table 4-3. CONTROL COST ESTIMATES FOR MODEL EXISTING PETROLEUM REFINERY EMISSION SOURCES
(Throughput: 15,900 m3/day)
Facility Size
ar.d
Control Devices
Installed Capital Cost
($000)
Annual Operating and
Maintenance Cost ($000)e
Annual i zed Capital
Charges ($000)f
Annual Recovered
Petroleum Credits
($000)
Net Annual! zed Cost/
(Credit) ($000)^
Controlled Emissions
(Mg/yr)i
Cost (Credit) per Mg
of Controlled Emis-
sions ($/Mg)J
Affected Emission Sources (Facilities)
Vacuum Producing Systems (VPS)
a
5560 m^/day throughput
61.0 m piping
6 valves
1 flame arrestor
23. 7C
1.9
4.8
(103.4)9
(96.7)
840
(115.10)
b
5560 m3/day throughput
122.0 m piping
12 valves
2 flame arresters
9.3m2 hotwell cover area
51. 6C
3.9
10.5
(103".4)g
(89.0)
840
(106.00)
Wastewater Separators
(WWS)
465m2 separator
and forebay area
62. 8d
6.3
12.7
(328. 7)9
(309.7)
3100
(99.90)
Vocess Unit Turnarounds
(PUT)
10 process units
30.5 m piping per unit
2 valves per unit
97. 6C
6.1
19.8
0.0k
25. 9^
4900
5.30k
Totals for the Control
of All Three
Emission Sources
VPSa+WWSJ-PUT
184.1
14.3
37.3
(432.1)1
(380. 5)1
8840
(43. OO)1
VPSb+WWS+PUT
212.0
16.3
43.0
(432. I)1
(372. 8)1
8840
(42. 20)1
I
o
aVacuum Producing Systems using either surface condensers or mechanical vacuum pumps.
bVacuum Producing Systems using contact (barometric) condensers.
cUsing 15.2 cm diameter 304 stainless steel piping and 15.2 cm diameter 316 stainless steel plug valves; when required, using
15.2 cm diameter stainless steel metal gauze flame arrestor(s) and 6.3 mm 304 stainless steel plate for hotwell cover.
dProduct of cover area (465m2) and unit cost ($135/m2).
eP1ping, valves, flame arresters, hotwells covers and wastewater separator covers O&M costs are 4*, 15%, 15*, 4*, and 10*,
respectively, of Installed capital costs.
fCapital recovery costs (using capital recovery factor with 10* annual interest rate and 10 year equipment life) plus 4* of installed
capital costs for property taxes, insurance, and administration.
^Reference 14.
^Sum of annual operating and maintenance cost, annualized capital charges, and annual recovered petroleum credits.
1Product of (Throughput per day) x (Controlled emissions per throughput) x (365 days per year).
•^Net Annualized Cost/(Credit) divided by Controlled Emissions per year.
kThese values assume that none of the PUT emissions are recovered; however, 1f all PUT emissions are recovered then the Annual
Petroleum Credits would be approximately $514,300, the Net Annualized Credit would be about $488,400, and the Credit per Mg of
Controlled Emissions would be $99.70.
Hhese values assume that none of the PUT emissions are recovered; however, if all PUT emissions are recovered then the credits
(savings) will increase about $514,300; thus, the credits per Mg of Controlled Emissions will increase to approximately $101,20
and $100.40, respectively.
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4.3 CONTROL OF EMISSIONS FROM WASTEWATER SEPARATORS
4.3.1 Model Cost Parameters
The recommended control technique consists of covering wastewater
separators and forebays (see Section 3.2). Table 4-2 shows the cost
parameters for wastewater separator and forebay covers. These parameters
11 12 13
are based on data in section 114 letters from petroleum refineries' '*
and EPA estimates.
4.3.2 Control Costs
Table 4-3 presents the estimated costs of controlling VOC emissions
from wastewater separators and forebays based on a cover area of 465 m2
for a medium size (15,900 m3/day) refinery.^ This cost analysis assumes
that the cover totally encloses the separator and forebay areas so that
all of the controlled emissions will be captured. Thus, the petroleum
credit is based on recovering 540 Kg of emissions per 103m3 of throughput.
It is also assumed that existing refineries will have all other equip-
ment needed to recover petroleum from the controlled emissions.
Although this control technique has an estimated capital cost of
$62,800, it should result in a net annualized credit (savings) of about
$309,700 for a medium size refinery. This credit (savings) is due to
the value of the recovered petroleum.
4.4 CONTROL OF EMISSIONS FROM PROCESS UNIT TURNAROUNDS
4.4.1 Mode1 Cost Parameters
The technique recommended for process unit turnarounds (PUT) is
to pipe the controlled emissions to flare header systems or to
4-11
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fireboxes (see Section 3.3). Table 4-2 presents cost parameters
for PUT control devices including cost data of four sizes and two
different materials of piping and valves. Piping cost data are given
in 30.5 m multiples. These cost parameters are based on data from
petroleum refineries, equipment vendors, a major refinery contractor
and EPA estimates.
4,4.2 Control Costs
The estimated costs of controlling VOC emissions from ten process
units are shown in Table 4-3. Each process unit has 30.5 m of piping
and two valves. Because of the potential corrosiveness of the streams,
the cost estimates are based on using 15,2 cm diameter 304 stainless
steel piping and 316 stainless steel plug valves. This analysis assumes
that none of the controlled emissions will be captured; thus, there
are no oetroleum recovery credits. However, some refineries already
have facilities for recovering the hydrocarbons; therefore, the credit
of recovering the emissions is also shown in Table 4-3. Further, it
is assumed that existing refineries have all other equipment needed
to control emissions, such as knockout pots, flare header systems and
etc. Therefore, the only control costs are piping and valve costs.
The PUT control method has an estimated capital cost of $97,600
and a net annualized cost of approximately $25,900 with no petroleum
recovery. But, if all the emissions are recovered and are equivalent to
light crude oil, this control method should provide an annualized
credit (savings) of about $488,400 for a medium sized refinery.
4-12
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4.5 COST EFFECTIVENESS
The cost effectiveness of controlling the three existing
refinery VOC sources is also shown in Table 4-3. Control of both
types of vacuum producing systems (with surface condensers or mechanical
vacuum pumps and with contact condensers) and wastewater separators
should result *n estimated credits (savings) of $115.10 per Mg, $106.00
per Mg, and $99.90 per Mg, respectively, of controlled emissions for
the model medium size refinery. Another cost effective measure is that
the Net Annualized Credit is 4.1 times, 1.7 times and 4.9 times, respec-
tively, the Installed Capital Cost of the control devices. Control of
process unit turnarounds is estimated to cost $5.30 per Mg if the con-
trolled emissions are flared. But, if all controlled emissions are
recovered as fuel, then estimated credits (savings) of $99.70 per Mg
should be obtained. It should be noted that recovering none or all of
the PUT emissions correspond to the minimum or maximum amounts possible;
the actual amount recovered by a refinery may be anywhere between these
amounts.
Control of all three VOC emission sources should result in net
annual credits (savings) regardless of the type of vacuum system con-
densers and whether or not controlled emissions are recovered from
process unit turnarounds (PUT). However, it can be seen from Table 4-3
that the least cost effective control is for a refinery that uses contact
condensers and flares controlled emissions from PUT, while the most cost
effective control pertains to a refinery that uses surface condensers
4-13
-------
or mechanical vacuum pumps and recovers all PUT controlled emissions.
The estimated credits (savings) per Mg of controlled emissions are
$42.20 for the former refinery configuration and $101.20 for the latter
configuration. The Net Annualized Credit is 1.8 times and 4.9 times,
respectively, the Installed Capital Cost of the two configurations.
i-14
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4.6 REFERENCES FOR CHAPTER 4.0
1. K. C. Hustvedt, U.S. EPA. Memo to J. F. Durham, U.S. EPA,
dated July 6, 1977.
2. "Hydrocarbon Emissions from Refineries," American Petroleum
Institute Publication No. 928, July, 1973.
3. W. Shoemaker, Fluor Corporation. Memo to file by R. H. Schippers,
U.S. EFA, dated July 18, 1977.
4. "Annual Refinery Survey," Oil and Gas Journal, March 28, 1977.
5. A. Frederickson, Murphy Oil Co., Meraux, Louisiana. Memo to
file by R. A. Quaney, U.S. EPA, dated October 4, 1977.
6. T. Hoover, Southwestern Refining Co., Corpus Christi, Texas.
Memo to file by R. A. Quaney, U.S. EPA, dated October 6, 1977.
7. T. Norton, Union Pump Co., Battle Creek, Michigan. Memo to
file by R. A. Quaney, U.S. EPA, dated October 3, 1977.
8. J. Columbus, Protecto Seal Co., Bensenville, Illinois. Memo
to file by R. A. Quaney, U.S. EPA, dated October 3, 1977.
9. W. Shoemaker, Fluor Corporation. Memo to file by R. A, Quaney,
U.S. EPA, dated October 4, 1977.
10. F. Walters, Burlington Engineering & Sales Company, Graham,
North Carolina. Memo to file by R. A. Quaney, U.S. EPA, dated
October 11, 1977.
11. I. H. Gilman. Section 114 letter from Standard Oil Company of
California, dated November 30, 1976.
12. C. B. Scott. Section 114 letter from Union Oil Company of
California, dated December 3, 1976.
13. L. Kronenberger. Section 114 letter from Exxon Company, U.S.A.,
dated February 2, 1977.
14. R. H. Schippers, U.S. EPA. Miscellaneous Refinery Emission Credit
memo to file, dated August 5, 1977.
4-15
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5.0 EFFECTS OF APPLYING THE TECHNOLOGY
The reduction in atmospheric emissions and other environmental
consequences of applying the control technology presented in Chapter 3
are discussed in this section. A comparison will be made between volatile
organic compound (VOC) emissions that will occur from refineries applying
the emission controls outlined in Chapter 3 and the emissions from refineries
that previously had a lesser level of control. These reductions will be
described in terms of reductions per 1000 cubic meters of throughput.
Other beneficial and adverse impacts which may be directly or indirectly
attributed to the operation of these systems will also be assessed.
5.1 IMPACT OF CONTROL TECHNIQUES ON VOLATILE ORGANIC COMPOUND EMISSIONS
The control techniques discussed in Chapter 3 are basically
consistent with what many existing State and local regulations require.
Table 5-1 shows the percent of January 1, 1977, refinery throughput that
is located in States with regulations for control equivalent to the
controls presented in Chapter 3. In addition, many refineries located
in States without controls will have considerably less emissions than
the uncontrolled emissions factors would indicate. Still there are many
areas where emission reductions similar to those shown in Table 5-1 car,
be attained through application of controls.
5-1
-------
Table 5-1 can be used to determine the emission reduction resulting
from controlling a previously uncontrolled refinery. The annual emission
reduction for a 15,900 cubic meter per day (medium sized) refinery would
be almost 8900 metric tons. The emission reduction would be correspondingly
less if any of the emission sources already have some degree of control.
5.2 OTHER ENVIRONMENTAL IHPACTS
The controls outlined in Chapter 3 will have minimal impact on water
pollution and solid waste. When VQC vapors are captured and com-
busted as refinery fuel gas, there can be appreciable increases in
emissions of sulfur dioxide^ In certain instances i.t may be necessary to
remove the hydrogen sulfide from the hydrocarbon stream before it can
be combusted. In all sources where sulfur is present, applying the control
techniques will result in an appreciable reduction in odors.
5,3 IMPACT
Combusting VOC from vacuum producing systems and process
unit turnarounds and covering wastewater separators will not reauire an
appreciable increase in energy use. If the vacuum producing system
non-condensables (170 kilograms per 1000 cubic meters of refinery
throughput) are combusted in a process heater or boiler, large fuel
savings can result. The annual fuel savings for a 15,900 m refinery
would be about 1300 cubic meters of crude oil. Additional fuel savings
can be accomplished from combusting the process unit turnaround vapors
as fuel gas.
5-2
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Table 5-1. VOLATILE ORGANIC COMPOUND EMISSION REDUCTION
Affected
Facility
Vacuum producing
system
Wastewater
separator
Process unit
turnaround
Percent /I
controlled
25
80
40
Uncontrolled /2
refinery
emissions
(kg/103m3)
145
570
860
Controlled /_3
refinery
emissions
(kg/103m3)
Neg.
30
15
Emission /4
reduction
(kg/103m3)
145
540
845
Total
1575
45
1530
/!_ Percent of January 1,-1977, refinery throughput located in states with
2 3
controls equivalent to those discussed in Chapter 3. '
12^ As defined in Chapter 2.
A3 As defined in Chapter 3.
/4_ Reduction in emissions resulting from controlling a previously
uncontrolled refinery -
5-3
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5.4 SUMMARY
This chapter has shown that although many refineries are already
under state and local regulations, there are large reductions in emissions
that would occur from controlling the remaining refineries. These controls
can be implemented with minimal other environmental impacts and potential
energy savings.
5.5 REFERENCES
1. Annual Refining Survey. The Oil and Das Journal. March 28, 1977.
2. "Screening Study for Vacuum Distillation Units in Petroleum
Refineries," EPA Report No, 450/3-76-040, Monsanto Research Corporation,
December 1976.
3. "Screening Study for Miscellaneous Sources of Hydrocarbon
Emissions in Petroleum Refineries," EPA Report No. 450/3-76-041, Monsanto
Research Corporation, December 1976.
5-4.
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6.0 ENFORCEMENT ASPECTS
The purpose of this chapter is to define facilities to which
regulations will apply, to select appropriate regulatory format, and
to recommend compliance and monitoring techniques.
6.1 AFFECTED FACILITY
In formulating regulations it is suggested that the affected
facility be defined as each individual source within a petroleum refinery
complex. A petroleum refinery complex is defined as any facility engaged
in producing gasoline, kerosene, distillate fuel oils, residual fuel oils,
lubricants or other products through distillation of petroleum or through
redistillation, cracking, rearrangement or reforming of unfinished
petroleum derivatives. Included in the sources are vacuum producing systems,
wastewater (oil/water) separators, and process units that are opened for
maintenance and inspection. These sources are discussed in Chapter 2.
In certain instances the emission reduction potential for controlling
one of these sources can be so small that it would not justify applying
controls, such as a vacuum producing system on a lube unit with negligible
non-condensable VOC. These cases should be addressed on a case by case
basis by the proper air pollution control agency.
6.2 FORMAT OF REGULATION
It is recommended that equipment specifications be used in
6-1
-------
regulating volatile organic compound (VOC) emissions from refinery
vacuum producing systems and wastewater separators and that process unit
turnaround VOC emissions be controlled by specifying operating procedures,
6.3 COMPLIANCE AND MONITORING
The equipment specifications recommended for petroleum refineries
include 1) combustion of non-ccmdensables from condensers, hot wells or
accumulators for vacuum producing systems, and 2) covers for all forebays
and wastewater separators. It is recommended that upon adoption of
equipment specifications, t-e air pollution control agency should have
the refinery operator submit a plan for achieving compliance with the
regulation. In many cases, the refinery will already be in compliance
with the equipment regulations and they should so state. When the
refinery is not in compliance with the suggested regulations, the agency
and the operator should agree on a timetable for compliance. Included
in this timetable should be dates for ordering, receiving, installation,
and startup of necessary equipment. Pollution control equipment should
be checked by an air pollution control agency inspector at least once a
year to ensure the equipment is operating properly.
When a process unit is shut down for a turnaround the agency should
require that the vessel be depressurized to vapor recovery, flare or a
firebox. Here again the refinery operator should submit a plan for achieving
compliance with the regulation. Each fractionator, reactor, stabilizer, etc.
should be addressed, preferably grouped in the most likely combination for
a given unit turnaround. No VOC should be .directly discharged to atmosphere
6-2
-------
until vessel pressure is less than 5 psig. The refinery operator
should keep a record of each process unit turnaround listing as a minimum
the date the unit was shut down, the approximate vessel hydrocarbon
concentration when the hydrocarbons were first discharged to atmosphere,
and the approximate total quantity of hydrocarbons emitted to the atmosphere.
These records should be kept for at least two years and be made available
to the air pollution control agency inspector during any compliance
inspection of the refinery.
6-3
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TECHNICAL REPORT DATA
readtasiructior.son the reverse before completing/
1. REPORT NO,
4. TITLE AND SUBTITLE
Control of Refinery Vacuum Producing Systems,
Wastewater Separators and Process Unit Turnarounds
_______ _____
Kent C. Hustvedt, ESEQ
Robert A. Quaney, SASQ
3. RECIPIENT'S ACCESSION'NO,
5. REPORT DATE
1
o. PERFORMING ORGANIZATION coos
9. PERFORMING ORGANIZATION NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
8. PERFORMiNG ORGANIZATION REPO'f T !\O.
\ QAgps NO. i .?-n8i
i10, PROGRAM ELEMENT NO,
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
13. TYPE OF REPORT AND PERIOD COVERED
14, SPONSORING AGENCY CODE
15, SUPPLEMENTARY NOTES
16. ABSTRACT
|_Jbis report provides the necessary guidance for development of
regulations to limit emissions of volatile organic compounds (VOC) from
refinery vacuum producing systems, wastewater separators and process unit
turnarounds. \This guidance includes equipment specifications for vacuum
producing~sysfems and wastewater separators, and operating procedures for
process unit turnarounds, all of which represent reasonably available control
technology (RACT). An example cost analysis for evaluating the cost
effectiveness of these refinery controls is also presented.
17,
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b,IDENTIFIERS/QPEN ENDED TERMS
c. COSATI Field/Group
Air Pollution
Control Equipment
Hydrocarbons
Petroleum Refining
Vacuum Producing Systems
Wastewater Separators
Process Unit Turnaround
Air Pollution Control
Stationary Sources
Hydrocarbon Emission
Control
13
14
07
13
18. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (This Report/
Unclassified
21. NO. OF PAGES
47
20, SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
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Office of Administration
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