&EPA
           United States
           Environmental Protection
           Agency
           Office of Air Quality
           Planning and Standards
           Research Triangle Park NC 27711
EPA-450/3-79-008
March 1979
           Air
A Review of Standards
of Performance for New
Stationary Sources -
Petroleum Refineries
       .

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                             EPA-450/3-79-008
 A  Review  of Standards
of  Performance for New
   Stationary  Sources -
   Petroleum  Refineries
                  by

           Kris Barrett and Alan Goldfarb

        Metrek Division of the MITRE Corporation
           1820 Dolley Madison Boulevard
             McLean, Virginia 22102
            Contract No. 68-02-2526
          EPA Project Officer: Thomas Bibb

       Emission Standards and Engineering Division
                Prepared for

       U.S. ENVIRONMENTAL PROTECTION AGENCY
          Office of Air, Noise, and Radiation
        Office of Air Quality Planning and Standards
       Research Triangle Park, North Carolina 27711

                March 1979

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This report has been reviewed by the Emission Standards and Engineering
Division, Office of Air Quality Planning and Standards, Office of Air, Noise
and Radiation, Environmental Protection Agency, and approved for publica-
tion . Mention of company or product names does not constitute endorsement
by EPA. Copies are available free of charge to Federal employees, current
contractors and grantees, and non-profit organizations - as supplies permit
from the Library Services Office, MD-35, Environmental Protection Agency,
Research Triangle Park, NC 27711; or may be obtained, for a fee, from the
National Technical Information Service, 5285 Port Royal Road, Springfield,
VA 22161.
                     Publication No. EPA-450/3-79-008
                                    11

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                             ABSTRACT
     This report reviews the current Standards of Performance for New
Stationary Sources: Subpart J - Petroleum Refineries.  It includes a
summary of the current standards, the status of current applicable
control technology, and the ability of refineries to meet the current
standards.  Compliance test results are analyzed and recommendations
are made for possible modifications and additions to the standard,
including future studies needed for unresolved issues.
                                 iii

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                          ACKNOWLEDGEMENT
     The authors wish to acknowledge those who gave so generously of
their time and patience during the preparation of this report*  The
many helpful suggestions and technical assistance of Mr. William
Lowenbach and Ms. Sally Price of The MITRE Corporation are greatly
appreciated.
                                   iv

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                          TABLE OF CONTENTS

                                                                Page

LIST OF ILLUSTRATIONS                                           vii
LIST OF TABLES                                                  viii

1.0  EXECUTIVE SUMMARY                                          1-1

1.1  Particulate Matter                                         1-1
1.2  Carbon Monoxide                                            1-3
1.3  Sulfur Dioxide                                             1-4
1.4  Hydrocarbons                                               1-5

2.0  INTRODUCTION                                               2-1

2.1  Purpose and Scope                                          2-1
2.2  Background Information                                     2-2

     2.2.1  Catalytic Cracking Units                            2-5
     2.2.2  Description of Fuel Gas Combustion Device           2-9

3.0  CURRENT STANDARDS FOR PETROLEUM REFINERIES                 3-1

3.1  Facilities Affected                                        3-1
3.2  Pollutants Controlled                                      3-2

     3.2.1  Standard for Particulate Matter                     3-2
     3.2.2  Standard for Carbon Monoxide                        3-2
     3.2.3  Standard for Sulfur Dioxide                         3-3

3.3  Monitoring and Reporting Requirements                      3-3

4.0  STATUS OF CONTROL TECHNOLOGY                               4-1

4.1  Scope of Industrial Operations                             4-1

     4.1.1  Distribution of Sources                             4-1
     4.1.2  Industry Growth Pattern                             4-1

4.2  Applicable Control Technology to Meet Standards            4-3

     4.2.1  Fluid Catalytic Cracker                             4-7
     4.2.2  Fuel Gas Combustion Device                          4-21

4.3  Achievable Emission Levels                                 4-23

     4.3.1  Fluid Catalytic Cracker                             4-23
     4.3.2  Fuel Gas Combustion Device                          4-25

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                    TABLE OF CONTENTS (Concluded)

                                                                Page

4.4  Special Problems Using Control Technologies                4-25

     4.4.1  Wet Scrubbers                                       4-25
     4.4.2  Condensable Participates                            4-28

4.5  Energy Needs and Environmental Effects                     4-30

     4.5.1  Expander Technology                                 4-30
     4.5.2  Carbon Monoxide Oxidation Catalysts                 4-32
     4.5.3  Sulfur Dioxide Catalysts                            4-33

5.0  INDICATIONS FROM TEST RESULTS                              5-1

5.1  Test Coverage in Regions                                   5-1
5.2  Analysis of Test Results                                   5-5

6.0  ANALYSIS OF POSSIBLE REVISIONS TO THE STANDARD             6-1

6.1  Particulate Matter                                         6-1
6.2  Carbon Monoxide                                            6-4
6.3  Sulfur Dioxide                                             6-5
6.4  Hydrocarbons                                               6-7

7.0  CONCLUSIONS                                                7-1

7.1  Particulate Matter                                         7-1
7.2  Carbon Monoxide                                            7-1
7.3  Sulfur Dioxide                                             7-1
7.4  Hydrocarbons                                               7-2

8.0  RECOMMENDATIONS                                            8-1

8.1  Particulate Matter                                         8-1
8.2  Carbon Monoxide                                            8-1
8.3  Sulfur Dioxide                                             8-1
8.4  Hydrocarbons                                               8-2

9.0  REFERENCES                                                 9-1

APPENDIX A      REPORTED FCC UNITS AT PETROLEUM REFINERIES      A-l
                                 vi

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                         LIST OF ILLUSTRATIONS

Figure Number                                                   Page

    2-1          Processing Plan for Complete Modern
                 Refinery                                       2-3

    2-2          Modern Fluid Catalytic Cracking Unit with
                 Controls and Energy Recovery                   2-8

    4-1          Effect of Particle Size on  Collection
                 Efficiency of an Electrostatic  Precipitator     4-9
                                  vii

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                           LIST OF TABLES

Table Number                                                    Page

    2-1         Potential Sources of Atmospheric Emissions
                Within Refineries                               2-6

    2-2         Nationwide Fluidized Bed Catalytic Cracker
                Regenerator Emissions, Uncontrolled             2-10

    4-1         Geographic Distribution of Fluid Catalytic
                Cracker Units                                   4-2

    4-2         Reported Predictions of Refinery Growth
                1977 - 1980                                     4-4

    4-3         Approximate Characteristics of Dust and Mist
                Collection Equipment                            4-15

    4-4         Particle Collection Efficiency                  4-16

    4-5         Effects of Variables on Dust Collection
                Equipment                                       4-18

    4-6         Use of Carbon Monoxide Oxidation Catalyst       4-20

    4-7         Compliance Test Data for Participate Matter     4-24

    4-8         Compliance Test Data for Carbon Monoxide        4-26

    4-9         Compliance Test Data for Sulfur Dioxide         4-27

    4-10        Condensable Participates from FCC Unit
                Regenerators                                    4-29

    5-1         NSPS Compliance Test Data - Petroleum
                Refineries                                      5-2

    5-2         Geographic Distribution of Possible NSPS
                Affected Facilities                             5-3

    6-1         Hazardous Hydrocarbons Emitted from FCC
                Unit Regenerators                               6-8
                                 viii

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1.0  EXECUTIVE SUMMARY




     New Source Performance Standards (NSPS) for petroleum refineries




were promulgated by the Environmental Protection Agency (EPA) on




March 8, 1974.  These standards regulate the emission of particulate




matter and carbon monoxide, and the opacity of flue gases from fluid




catalytic cracking (FCC) unit catalyst regenerators and FCC unit




regenerator incinerator-waste heat boilers.  They also regulate the




emission of sulfur dioxide from fuel gas combustion devices.  These




regulations apply to any affected facility which commenced construc-




tion or modification after June 11, 1973.




     The objective of this report is to review the New Source Perfor-




mance Standard (NSPS) for petroleum refineries in terms of the impact




of new developments in control technology, industry operating condi-




tions, process changes, and other issues that have evolved since the




standards were promulgated.  Possible revisions to the standard,




based on NSPS compliance test results, are also analyzed.  The




following paragraphs summarize the results and conclusions of the




analysis, as well as recommendations for future action.*




1.1  Particulate Matter




     The current NSPS for particulate matter emissions were based




on electrostatic precipitator technology.  The use of multi-stage




cyclones in conjunction with an electrostatic precipitator is still




considered the best demonstrated control technology.  A number of
*This report reflects information and data available  in  June  1978.



                                  1-1

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refineries are using high-efficiency separators to reduce particulate




matter loading prior to energy recovery in an expander turbine.  This




is then followed by a preclpitator.  Bag filters and venturi scrubbers




can also be used on a FCC unit regenerator exhaust gas stream.




     Only one NSPS compliance test was available for analysis during




this task.  The three test runs had a range of emission values from




0.76 to 1.35 kg particulate matter/kg coke burn-off with an average




of 1.01 kg/kg coke burn-off (NSPS - 1.0 kg/kg).  Based on this one




compliance test and previous data from tests performed to support the




standard, no change to the present particulate matter standard is




recommended.




     Technological advances in catalysts, temperature of regeneration




and catalyst-to-feed ratios have had the effect of reducing particu-




late matter mass emission rates.  However, the allowable emission is




based on coke burn-off in the regenerator, not mass rate.  Therefore,




the new technologies which reduce coke formation and therefore coke




burn-off, also reduce the allowable emissions in total kg of particu-




late matter emitted per hour.  This has required the industry to




Increase control of the emission of entrained catalyst.




     Technological advances in controls are limited to new, high-




efficiency third-stage cyclones or separators.  Use of a third-stage




separator may control the effect of increased emissions with time due




to erosion of the regenerator internal cyclones.  Use of a separator




to control turbine blade erosion is mandatory if energy recovery from
                                  1-2

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an expander turbine is incorporated in the FCC unit regenerator flue




gas stream.




     The available compliance test report included an appendix




describing a problem with EPA Reference Method 5 for measuring




particulate matter due to condensable sulfates.  Because this method




is the key to defining particulate matter and it determines the




compliance/noncompliance of an affected facility, it is recommended




that Reference Method 5, as it applies to catalyst regenerator




emissions, be reevaluated.




     An additional recommendation for the particulate matter stan-




dard is to require that the opacity be measured at the same time




the mass emission is measured.  This requirement will provide much




needed data and will ensure that the opacity standard is consistent




with the mass emission limit.




1.2  Carbon Monoxide




     The best demonstrated control technology for carbon monoxide




(CO) is considered to be the carbon monoxide incinerator-waste heat




boiler.  No compliance test data were available for carbon monoxide




emissions from FCC unit regenerators using controls other than carbon




monoxide boilers.  These incinerator waste heat boilers are capable




of reducing the emission of CO to 0 to 14 ppm, far below the current




standard of 500 ppm.  The standard was established at 500 ppm to




permit control of CO emissions by regenerator in-situ oxidation.




There is no data to substantiate the level of CO emissions from
                                   1-3

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regenerators using in-situ oxidation other than journal statements of




"less than 500 ppm."  Approximately 20 percent of the U.S. regener-




ators are operating with CO oxidation promoters (Wallendorf, 1978).




It is recommended that data be collected to ascertain the capabiliy




of these systems to reduce CO and the level of reduction possible,




then reevaluate the CO standard based on this new data.




1.3  Sulfur Dioxide




     Sulfur dioxide emissions from fuel gas combustion devices can be




controlled by reducing the hydrogen sulfide content of the fuel gas




or by flue gas desulfurization (FGD).  The standard was written to




limit the I^S content of fuel gas, although the owner/operator has




the option of using FGD.  The available compliance test data Indicate




that:  (1) all NSPS affected facilities identified chose to limit the




H2& content of fuel gas Instead of using FGD, and (2) the technol-




ogy for reducing I^S concentrations substantially below the present




NSPS limit is being used.  There is no data to show the effect of the




increased sulfur content of feedstock expected with increased Imports.




This relationship should be considered before a decision is made on




whether the standard can be changed to reduce the allowable H2S




content of fuel gas.




     Another recommendation Is to change the definition of a fuel gas




combustion device so that a regenerator incinerator-waste heat boiler




is no longer excluded from compliance with the SOX standard.  The




original rationale for excluding the boiler from the standard, even
                                  1-4

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when using fuel gas as an auxiliary fuel, is not known.  A third




recommendation concerns the monitoring of hydrogen sulfide in fuel




gas.  The lack of a continuous monitoring method for ^2^ ^as been




reported by EPA Regional personnel as a weakness in the current NSPS




(Watson et al., 1978).




     There is currently no NSPS for sulfur dioxide emissions from




the FCC unit regenerator/regenerator incinerator-waste heat boiler.




Arthur D. Little, Inc. (1976) has estimated that a SOX flue gas




control level of 300 ppm or 500 ppm will reduce emissions by 85,000




tons/year and 49,000 tons/year respectively by 1985.  This is a




reduction from their estimate of 480,000 tons/year of SOX emitted




by FCC units in 1985.  It is recommended that further analysis be




done to determine if a suitable standard can be developed and that




this standard include an additional sulfur dioxide allowance for




regenerator incinerator-waste heat boilers using auxiliary liquid




or solid fossil fuels.




1.4  Hydrocarbons




     The emission of hydrocarbons of concern to public health offi-




cials from uncontrolled FCC unit regenerators has been established by




Radian Corporation (Bombaugh et al., 1976).  The actual emissions




released under differing operating conditions or control equipment




have not been determined.  Arthur D. Little, Inc.  (1976) has stated




that the emission of hydrocarbons is negligible when using either  &




CO boiler or high temperature regeneration  (HTR).  New CO oxidation
                                   1-5

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promoters can reduce the temperature at which effective HTR can be




carried out and the emissions from a regenerator under these condi-




tions are unknown.  It is recommended that data he collected to




ascertain the need for a MSPS for hydrocarbon emissions.
                                   1-6

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2.0  INTRODUCTION




2.1  Purpose and Scope




     On March 8, 1974, the Environmental Protection Agency promulgated




New Source Performance Standards (NSPS) for Petroleum Refineries  (39




FR 9315).  Revisions were made on October 6, 1975 (40 FR 46250) and




again on July 25, 1977 (42 FR 37937).  These standards establish




emissions limits and require emission testing; monitoring; and




reporting for particulate matter, opacity, and carbon monoxide from




fluid catalytic cracking unit regenerators, and sulfur dioxide from




fuel gas combustion devices.




      The Clean Air Act Amendments of 1977 require that the Adminis-




trator of the EPA review, and if appropriate, revise established




standards of performance for new stationary sources at least every




four years (Section 111(b)(1)(B)).  This report includes reviews  of




the current standards, the status of current applicable control




technology, and the ability of petroleum refineries to meet the cur-




rent standards.  The compliance test results, information retrieved




from the literature, and discussions with industry representatives




form the basis for analyses of the current standards to determine if




they are sufficient, too stringent, or not stringent enough.  The




problems associated with the monitoring requirements of the standards




were analyzed, and recommendations are made concerning specific




changes or studies to be conducted.  Also discussed are problems  at
                                 2-1

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petroleum refineries that relate directly to the environmental




pollution load emitted and that may affect present or future NSPS.




2.2  Background Information




     A petroleum refinery transforms crude oil  into a variety of




useful products.  The petroleum refining industry produces more than




2500 products that can be categorized into the  following classes:




fuel gas, gasoline, kerosine, fuel oil, lubricating oil, grease, wax,




asphalt, coke, chemicals, and solvents.  There  is no "typical"




refinery, since the number of products and the  product mix varies




widely within a refinery as well as between refineries.  The manu-




facturing processes also vary depending on refinery age, type of




technology, capacity, location, and type of crude processed.




     Petroleum refinery operations involve physical separation of




components of the crude oil  (e.g., crude distillation) and chemical




conversion processes which transform some of the less useful compon-




ents of the oil into more useful products (e.g., cracking of high




molecular weight oils into lower molecular weight products such as




gasoline).




     The processing sequence of a modern refinery is illustrated




in Figure 2-1.  The crude oil is heated and charged to an atmospheric




distillation tower where it is separated Into several light, inter-




mediate, and heavy fractions.  The bottoms from the tower are sent




to a vacuum distillation unit for further separation.  The bottoms




from the vacuum still are thermally cracked in  a coker to produce a
                                 2-2

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                                                                                                      DRY GAS
NI
                                                                                                   STRAIGHT RUN GASOLINE
                                                                                                   LIGHT HYDROCRACKED GASOLINE
                        MIDDLE
                       DISTILLATES
                                                                    HEAVY
                                                                 HTDBOCRACKED
                                                                   GASOLINE
                     HEAVY GAS OIL
                                                               HYDROGEN SULFIDE
                                                         CRACKED GAS
                                           CATALYTIC
                                           GASOLINE
                                             CATALYTIC
                                              CRACKING
                                               UNIT
                       LIGHT FUEL OIL
                   REDUCED
                    CRUDE
                     OIL  _
COKBR GASOLINE
                                    LUBE DISTILLATES
        CRUDE OIL
        SEPARATION
           UNIT
                                                                                                                                         *-FUEL GAS
                                                                                                                                        *-LP GAS
                                                                                                                                            MOTOR
                                                                                                                                           GASOLINE
                                                                                                                                           AVIATION
                                                                                                                                           GASOLINE
                                                                          OLEFINS TO
                                                                            CHEMICAL
                                                                       *-KEROSENE
                                                                       *• LIGHT FUEL
                                                                            OIL
                                                                          DIESEL
                                                                           FUEL
*-SULFUR

  LUBES

  WAXES
  GREASES
                                                                                                                                           HEAVY FUEL
                                                                                                                                             OIL
                                                                                                                                         *-ASPHALT
                                                                        •-COKE
         Source:  Laster, 1973.
                                                                         FIGURE 2-1
                                                     PROCESSING PLAN FOR COMPLETE MODERN REFINERY

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wet gas, coker gasoline, and coke.  A portion of the bottoms from the




vacuum still may be processed into asphalt.  Gas oils from the




atmospheric and vacuum distillation units are used as feedstocks for




the catalytic cracking and hydrocracking units.  These units convert




the gas oils to gasoline and distillate fuel.  The gasoline from




these units is fed to a catalytic reformer to improve the octane




number and then blended with other refinery streams to make gasolines




for marketing.




     The wet gas streams from the distillation, coker, and cracking




units are combined and fractionated into fuel gas, liquified petroleum




gas, and unsaturated and saturated branched chain and straight  chain,




light hydrocarbons containing from 3 to 5 carbon atoms.  The fuel




gas is used as fuel in the refinery furnaces.  The straight chain




saturated hydrocarbons are blended into gasoline.   The  unsaturated




hydrocarbons and the branched chain hydrocarbons, primarily isobutane,




are processed in an alkylatlon unit.  In the alkylation  unit the




unsaturated hydrocarbons react with isobutane to form isoparaffins




which are blended into gasoline  to increase the octane.




     The middle distillates from the crude unit, the coker unit,




and the cracking unit are blended into diesel and jet fuels and




furnace oil.  Heavy vacuum gas oils and reduced crude oil from some




crudes can be processed into lubricating oils, waxes, and grease.




     Only a few process units emit pollutants directly to the




atmosphere—the catalytic cracking unit, the coker, and  the process
                                  2-4

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heaters.  Pump seals, valves, relief vents, leaks, and sampling




operations are sources of fugitive emissions.  Air pollutants




that may be released into the environment from a refinery, and some




of the sources of these emissions, are summarized in Table 2-1.




     2.2.1  Catalytic Cracking Units




     Catalytic cracking is a process for converting heavy oils into




more valuable gasoline and lighter products.  Almost 5 million




barrels of oil are processed daily in catalytic cracking units in the




U.S.  Originally, cracking was accomplished thermally, but catalytic




processes have almost completely replaced thermal cracking because of




the improved yield and quality of the product from the catalytic




process.  Three types of catalytic cracking processes have been used:




the fixed bed (Houdry process), the moving bed (Thermofor process),




and the fluidized bed.




     The fixed bed process is considered obsolete, and only three




refineries still use this process.  The moving bed process is being




phased out and only  16 refineries use this method.




     There are 122 fluidized bed catalytic cracking units currently




operating with the capability of processing 4.7 million barrels of




oil daily.  During the next  2 years an additional 16 fluid bed




catalytic crackers are scheduled to be placed in operation.  The




combined capacity of these units is approximately 321,000 barrels of




oil per day.  However, this  figure does not represent increased




capacity, since some units may replace existing older units.  Also,
                                  2-5

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                                TABLE 2-1

      POTENTIAL SOURCES OF ATMOSPHERIC EMISSIONS  WITHIN REFINERIES
   Type of Emission
              Source
   Participates
   Sulfur Oxides
   Nitrogen Oxides


   Hydrocarbons
   Carbon Monoxide
   Odors
Catalytic Cracker, Fluid Coking,
Catalyst Regeneration, Process
Heaters, Boilers, Decoking Opera-
tions, Incinerators

Sulfur Recovery Unit, Catalytic
Cracking, Process Heaters, Boilers,
Decoking Operations, Unit Regenera-
tions, Treating Units, Flares

Process Heaters, Boilers, Catalyst
Regeneration, Flares

Storage Tanks, Loading Operations,
Water Treating, Catalyst Regenera-
tion, Barometric Condensers, Pro-
cess Heaters, Boilers, Pumps,
Valves, Blind Changing, Cooling
Towers, Vacuum Jets

Catalyst Regeneration, Decoking,
Compressor Engines, Incinerators

Treating Units, Drains, Tank Vents,
Barometric Condensers, Sumps, Oil-
Water Separators
Source:  Dickerman, et al., 1977.
                                  2-6

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although some units represent additions to refinery capacity, this




figure represents the total capacity of the refinery after the




addition.




     The fluidized catalytic cracking (FCC) process uses a catalyst




in the form of fine particles that are fluidized with a vapor.  The




fluidized catalyst is continuously circulated between a reaction zone




and a regeneration zone.  Two types of FCC units are commonly used.




In the "side-by-side" type, the reaction and regeneration chambers




are separate vessels next to each other.  In the stacked type, the




reactor is mounted on top of the regenerator and the two vessels




appear as one when viewed externally.  Other variations in FCC design




and operation relate to the type of catalyst employed and the design




of the catalyst transfer line between the regenerator and the reactor.




However, the operating principles of the various FCC reactors are




essentially the same.




     A schematic diagram of a fluid catalytic cracking unit is




shown in Figure 2-2.  In operation, the gas oil is fed to the bottom




of the riser pipe where it joins the hot, regenerated catalyst.  The




fuel is vaporized and flows upward along with the catalyst particles.




The cracking reaction takes place in the riser.  Because the reaction




is endothermic, cooling of the reacting mixture occurs as it rises




into the reactor.  The product gases exit through the top of the




separator and the catalyst particles drop into the stripper section




where they are blown with steam to strip hydrocarbons that are
                                  2-7

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                                 •*• PRODUCT
CARBON
MONOXIDE
BOILER
                                                                                                   •*-STEAM
ho
do
                                                                                                          ELECTROSTATIC
                                                                                                          PRECIPITATOR
                                                                                                               TO
                                                                                                          ~~^ STACK
                                                                                                            DUST
                                                                                                           STEAM
                                                                                                           TURBINE
                                                          FIGURE 2-2
                                            MODERN FLUID CATALYTIC CRACKING UNIT
                                             WITH CONTROLS AND ENERGY RECOVERY

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entrained on the catalyst.  During the cracking process, the catalyst




loses its activity due to the formation of coke deposits.  In order




to restore the catalytic activity, the spent catalyst is passed into




a regenerator where the coke is burned off in a controlled combustion




process with preheated air.  The hot regenerated catalyst then flows




to the bottom of the riser to mix with incoming gas oil feed and the




cycle is repeated.




     The products of combustion are vented through the top of the




regenerator.  The regenerator vent gases contain particulate matter




from entrained catalyst, sulfur oxides from sulfur retained in the




coke, carbon monoxide from incomplete combustion of coke, hydrocarbons,




nitrogen oxides, aldehydes, and ammonia.  Table 2-2 lists emission




factors for each of these pollutants discharged from an uncontrolled




fluid bed catalyst regenerator along with the potential nationwide




emissions based on the current capacity of fluidized bed catalytic




reactors in the U.S.




     2.2.2  Description of Fuel Gas Combustion Device




     Fuel gas is produced in a refinery from a wide variety of pro-




cess operations including:  crude oil separation, catalytic cracking,




hydrocracking, coking, and reforming.  The gas is treated and then




used in process heaters, boilers, flares, and various other places in




the refinery.  A fuel gas combustion device is quite literally any




equipment in a petroleum refinery that is used to burn fuel gas.




Fluid coking units, fluid catalytic cracking unit incinerator-waste
                                  2-9

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                                        TABLE 2-2

       NATIONWIDE PLUIDIZED BED CATALYTIC CRACKER REGENERATOR EMISSIONS*  UNCONTROLLED
Pollutant
 Emission Factor
(kg/m3 fresh fuel)a
        Estimated
         Maximum
     Dally Emission (kg)b
        Estimated
         Annual
       Emission (kg)b
Partlculatee

Sulfur Oxides

Carbon Monoxides

Hydrocarbons

Nitrogen Oxides

Aldehydes

Ammonia
  0.267 - 0.976

  0.898 - 1.505

       39.2

      0.630

  0.107 - 0.416

      0.054

      0.155
2.1 x 105 - 7.7 x 105

7.1 x 105 - 1.2 x 106
      3.1 x
      5.0 x 10J

8.4 x 104 - 3.3 x 105
      4.3 x 10"
      1.2 x 10"
6.9 x 107 - 2.5 x 108

2.3 x 108 - 3.9 x 108
       1.0 x 10
                                           10
       1.6 x 108

2.8 x 107 - 1.1 x 108

       1.4 x 107
       4.0 x 10'
Vs. EPA, 1973.

 Calculated from capacity data reported In  Cantrell, 1978.

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heat boilers, and facilities that burn fuel gas to produce sulfur or




sulfuric acid are excluded from the NSFS definition of a fuel gas




combustion device.  Flue gases from these sources are vented to the




atmosphere with or without heat recovery and/or treatment.
                                 2-11

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3.0  CURRENT STANDARDS FOR PETROLEUM REFINERIES

3.1  Facilities Affected

     The NSPS for petroleum refineries are applicable to fluid cata-

lytic cracking unit catalyst regenerators, fluid catalytic cracking

unit regenerator incinerator-waste heat boilers, and fuel gas com-

bustion devices that commenced construction or modification after

June 11, 1973.

     The following terms are pertinent to the determination of the

applicability of the NSPS to a facility.

     •  A petroleum refinery is any facility engaged in producing
        gasoline, kerosene, distillate fuel oils, residual fuel oils,
        lubricants, or other products through distillation of petro-
        leum or through redistillation, cracking or reforming of
        unfinished petroleum derivatives.

     •  Construction is the fabrication, erection, or installation
        of an affected facility, or any apparatus to which a standard
        is applicable.  This includes construction that is completed
        within an organization as well as the more common situation
        in which the facility is designed and constructed by a
        contractor.

     •  A modification is any physical change in, or change in the
        method of operation of, an existing facility which increases
        the amount of any air pollutant (to which a standard applies)
        emitted into the atmosphere by that facility or which results
        in the emission of any air pollutant (to which a standard
        applies) not previously emitted into the atmosphere.  However,
        increases in production rates up to design capacity, reloca-
        tion or change in ownership of an existing facility, and fuel
        switches if the equipment was originally designed to accom-
        modate such fuels, are not considered to be modifications.

     •  Reconstruction is the replacement of components of a facility
        to such an extent that the capital costs of the new components
        is greater than 50 percent of the capital costs of a compara-
        ble entirely new facility.  After replacement, the facility
        must be technologically and economically capable of complying
        with the NSPS.  If a facility meets these criteria, it is
        designated an affected facility, regardless of any changes in
        the rate of emissions.
                                   3-1

-------
3.2  Pollutants Controlled

     The NSPS for petroleum refineries regulate the emission of:

     •  particulate matter from FCC unit catalyst regenerators or FCC
        unit regenerator incinerator-waste heat boilers,

     •  carbon monoxide from FCC unit catalyst regenerators, and

     •  sulfur dioxide from fuel gas combustion devices.

     3.2.1  Standard for Particulate Matter

     The standard for particulate matter has been set at 1.0 kg/1,000

kg (1.0 lb/1,000 Ib) of coke burn-off in the catalyst regenerator.

In addition, no gases are to be emitted that exhibit greater than

30 percent opacity except for one six-minute average opacity reading

in any one—hour period.

     In those instances in which auxiliary liquid or solid fossil

fuels are burned in the FCC unit regenerator incinerator-waste heat

boiler, the incremental rate of particulate matter emissions may

exceed the above, but not exceed 0.18 g/million cal (0.10 Ib/million

Btu) of heat input attributable to the auxiliary liquid or solid

fuel.

     3.2.2  Standard for Carbon Monoxide

     The standard for carbon monoxide restricts emissions to no

greater than 0.050 percent by volume of carbon monoxide in gases

discharged from a FCC unit catalyst regenerator.
                                  3-2

-------
     3.2.3  Standard for Sulfur Dioxide
     The standard for sulfur dioxide applies to any fuel gas com-
bustion device.  These devices are defined as any equipment used to
burn fuel gas, such as process heaters, boilers, and flares.
Fluid coking units, FCC unit incinerator-waste heat boilers, and
facilities in which gases are burned to produce either sulfur or
sulfuric acid are not included.
     The standard prohibits the burning of fuel gas containing in
excess of 230 mg I^S/dscm (0.10 gr/dscf) in any fuel gas combustion
device, except as discussed below.  The combustion of process upset
gas in a flare, and process gas or fuel gas released to a flare from
relief valve leakage is exempt from this standard.
     The alternative to the 230 mg ^S/dscm fuel gas standard is
that an owner or operator may elect to treat the gases resulting from
the combustion of fuel gas so as to limit the release of SC>2 to the
atmosphere.  The EPA Administrator must be satisfied that treating
of the combustion gases controls SO2 emissions as effectively as
compliance with the li^S standard.
3.3  Monitoring and Reporting Requirements
     Continuous monitoring is required for opacity, carbon monoxide,
and sulfur dioxide.  The regulations require owners or operators to
install, calibrate, maintain, and operate a continuous monitoring
system for the opacity of emissions from FCC unit catalyst regener-
ators.  The opacity monitoring system is to be spanned at 60, 70, or
80 percent opacity.
                                  3-3

-------
     The continuous monitoring of carbon monoxide emissions from FCC




unit catalyst regenerators will be required on all NSPS affected




facilities as soon as instrument specifications are promulgated by




EPA.  This will require a retrofit of instruments on affected facili-



ties already in place.




     A continuous monitoring system is required for the measurement




of sulfur dioxide in the gases discharged to the atmosphere from the




combustion of fuel gases.  Calibration checks are made using SO2 as



the calibration gas.  The span is set at 100 ppm.  Reference Method 6




is used for conducting monitoring system performance evaluations.




This continuous monitoring system is not required where a continuous




monitoring system for the measurement of hydrogen sulfide is installed.




The EPA has not yet developed performance specifications for hydrogen



sulfide continous monitoring system.  Therefore, owners and operators




electing to monitor R^S are effectively exempt from the SO2 monitoring



requirements (40 FR 46250) until EPA establishes Instrument perform-




ance specifications for an I^S monitor.




     The average coke burn-off rate (thousands of kilograms/hour)




and hours of operation for any FCC unit catalyst regenerator are




required to be recorded daily.  Computation of the coke burn-off




rate is done using the formula in 40 CFR 60.106(4).



     Owners and operators of FCC unit catalyst regenerators who use




an incinerator-waste heat boiler to burn the regenerator exhaust




gases are required to record the dally rate of combustion of liquid
                                  3-4

-------
or solid fossil fuels (liters/hour or kilograms/hour) and the hours

of operation during which these fuels are burned in the boiler.

     The reports required for NSPS affected facilities are submitted

to the EPA Administrator for every calendar quarter within 30 days

of the end of the quarter.

     The following reports of excess emissions are required:

     •  opacity - all one-hour periods that contain two or more six-
        minute periods during which the average opacity exceeds 30
        percent as measured by the continuous monitoring system, and

     •  sulfur dioxide - any six-hour period during which the average
        (arithmetic average of six contiguous one-hour periods)
        emissions of SO2 exceed the standard as measured by the
        continuous monitoring system.
                                  3-5

-------
4.0  STATUS OF CONTROL TECHNOLOGY




4.1  Scope of Industrial Operations




     4.1.1  Distribution of Sources




     There are 285 operating petroleum refineries in the U.S. with a




total capacity of nearly 18 million barrels of crude oil per stream




day.  The largest number of refineries are located in EPA Region VI




(37 percent of total refineries and 45 percent of total capacity)*




Texas, California, and Louisiana are the three largest refinery




states with 19, 14, and 8 percent of the refineries and 27, 14, and




12 percent of the capacity, respectively.




     The fluid catalytic cracker is an essential part of the modern




refinery.  Nearly one-half of all refineries have FCC units as part




of their process.  Table 4-1 shows the distribution of these fluid




catalytic cracking units by EPA Region.  EPA Regions V and VI con-




tain 53 percent of the FCC equipped refineries and 62 percent of the




refinery FCC unit capacity.  Texas, Louisiana, and California are the




states with the largest FCC unit capacity (Cantrell, 1978).




     4.1.2  Industry Growth Pattern




     The growth of the petroleum refinery industry has been affected




by government regulation of fuel prices and the oil embargo.  According




to data presented in the Oil and Gas Journal  (Cantrell, 1978), 27 new




refineries have been built between 1975 and 1978.  Thirteen of these




refineries were built in EPA Region VI.  Although the actual number




of new FCC units built in the same period is unknown, capacity was
                                 4-1

-------
                                        TABLE 4-1
                GEOGRAPHIC DISTRIBUTION OF FLUID CATALYTIC CRACKER UNITS
Fluid Catalytic Cracker Units
Region
I
11 III
IV
V
VI
VII
VIII
IX
X
Total
Number of
Refineries
1978
1
7
16
20
36
100
13
35
44
13
285
75-78
_
(Db
5
-
13
-
3
5
1
26
Number of
Refineries
With FCCU
1978
—
3
6
3
19
45
16
15
13
2
122
Capacity8
1978
_
197
309
120
771
2081
373
175
509
66
4600
75-78
-
10
15
-
86
147
(10)b
5
111
3
368
Percent of
Total
Number
_
2
5
2
16
37
13
12
11
2
100
Capacity
-
4
7
3
17
45
8
4
11
1
100
Sources:  Cantrell, 1975; 1978.
a Capacity in 10^ barrels per stream day*
b Reduction in number of refineries or capacity*

-------
increased by 368,000 barrels per stream day.  A distribution of this




growth in FCC unit capacity is shown in Table 4-1.




     The data from the Oil and Gas Journal (Cantrell, 1978) on




increased capacity of FCC units show that 50 refineries have built




new FCC units or expanded FCC unit capacity during the period 1975-




1978.  It is not within the scope of this report to make a deter-




mination on how many of these units are affected facilities and sub-




ject to the NSPS.  During interviews with each EPA Regional office,




only two FCC units were reported as subject to NSPS.  (Data from EPA




Region IX were not received.)




     In Table 4-2, data from Hydrocarbon Processing  (1978) are pre-




sented to show a planned growth in seventeen FCC units during the




period 1978-1980.  Of these, six projects are under construction and




eleven are in an engineering phase.  Four of the units under con-




struction are indicated as new units.




4.2  Applicable Control Technology To Meet Standards




     The NSPS are based on best demonstrated control technology which




is reasonable from an economic viewpoint.  For this reason, a review




of available control technologies used by petroleum refineries is very




important.  In this section, the control technologies currently used




to meet the NSPS are reviewed.  The technologies are discussed in the




order of their prevalence in the industry.
                                  4-3

-------
                                 TABLE 4-2
             REPORTED PREDICTIONS OF REFINERY GROWTH 1977-1980s
   EPA Region

Region I

  Connecticut
  Maine
  Massachusetts
  New Hampshire
  Rhode Island
  Vermont

Region II

  New Jersey
  New York

Region III

  Delaware
  Maryland
  Pennsylvania
  Virginia

  West Virginia

Region IV

  Alabama
  Florida
  Georgia
  Kentucky
  Mississippi
  North Carolina
  South Carolina
  Tennessee
  Company/City
None indicated
       ii
       it
       n
       ft
    FCC
  CO
Boiler
Refinery
Mobil, Paulsboro
None indicated
None indicated
Crown Central,
Baltimore
Stewart, Piney
  Point
Sun, Marcus Hook
Hampton Roads
Energy, Portsmouth
None indicated
None Indicated
       N
       N
       It

       It

       n
Delta, Memphis
30 Mb/d,U80
  Re,E
                                                                     200 Mb/d,E
                                                                     100 Mb/d,P
                         184.1 Mb/d,
                           E80
25 Mb/d,E79
Phase:  CKJompleted since 9/1/77, EHBngineerlng, P-Planning, Re-Revamp,
        U^Jnder construction
Year:  (77, 78, 79, 80)
* Compiled as of 1/1/78 and reported In thousand barrels/day (Mb/d)
Source:  Hydrocarbon Processing, 1978.
                                      4-4

-------
                           TABLE 4-2 (Continued)
             REPORTED PREDICTIONS OF REFINERY GROWTH 1977-1980"
   EPA Region

Region V

  Illinois
  Indiana

  Iowa
  Michigan

  Minnesota
  Wisconsin
  Company/City
None indicated
Energy Coop,
East Chicago
None indicated
Total Petroleum,
Alma
None indicated
    FCC
ExpnnHion.E


By A Mb/d,C77
  CO
Boiler    Refinery
Region VI

  Arkansas
  Louisiana
  New Mexico
  Oklahoma

  Texas
None indicated
Continental, Lake
Charles
Good Hope, Good Hope
Gulf, Alliance
Marathon, Garyvllle
Murphy, Meraux
Shepherd, Jennings
T&S, Mermentau
Plateau, Bloomfleld
Continental, Ponca
City
Diamond Chamrock,
Dumas
La Gloria, Tyler
Phillips, Sweeny

Sun, Corpus Christ!
Texas City, Texas
City
Tipperary, Ingleside

Unl, Rockport
Union, Nederland
                                            30.8 Mb/d,E79
                                            Ex 55 Mb/d,U
                                            By 11 Mb/d,E79
                                            75 Mb/d,E79
                                            25 Mb/d,E79
5 Mb/d,U77
                                            32.5 Mb/d,U79
                                            Re,E79
                                            Re,C
                                            To 190 Mb/d,E79
                                            To 25 Mb/d,C

                                            By 8 Mb/d,E78
                                            Re.C
                         Exp.,E79

                         10 Mb/d,U
                         10 Mb/d,E78
                                                                     5 Mb/d,C
                                                                  By 15 Mb/d,E78
                                                                     10 Mb/d,E78
Phase:  C-Completed since 9/1/77, E-Englneerlng, P-Planning, Re-Revamp,
        U=Under construction
Year:  (77, 78, 79, 80)
a Compiled as of 1/1/78 and reported in thousand barrels/day (Mb/d)
Source:  Hydrocarbon Processing, 1978.
                                       4-5

-------
                           TABLE 4-2 (Concluded)
             REPORTED PREDICTIONS OF REFINERY GROWTH 1977-1980*
   EPA Region

Region VII

  Kansas
  Missouri
  Nebraska
  Ohio
  Company/City
CRA, Phillipsburg
None indicated
       it
       ti
    FCC
To 9 Mb/d,D79
  Co.
Boiler
Refinery
Region VIII

  Colorado
  Montana
  North Dakota
  South Dakota
  Utah
  Wyoming
Region IX

  Arizona
  California
  Hawaii

  Nevada

Region X

  Alaska
  Idaho
  Oregon

  Washington
Gary Western, Fruita
None indicated
Amoco, Mandan
None indicated
       it
Little America,
Casper
Mountaineer, La Barge
None indicated
Lion, Bakersfield
Hawaiian Independent,
Barbers Point
None indicated
None indicated
       n
Cascade Energy,
Columbia
United Independent,
Seattle
                                            17 Mb/d,E78
                      To 10 Mb/d,D78
                  U
                                                                  By 4.2 Mb/d,P80
                 E78
                      By 7.5 Mb/d, E78
                         30 Mb/d,P

                         Re,E
Phase:  Completed since 9/1/77, B-Bngineering, P-Planning, Re-Revamp,
        D-Cnder construction
Year:  (77, 78, 79, 80)
a Compiled as of 1/1/78 and reported in thousand barrels/day (Mb/d)
Source:  Hydrocarbon Processing, 1978.
                                         4-6

-------
     4.2.1  Fluid Catalytic Cracker




     The fluid catalytic cracker regenerator and regenerator waste




heat boiler have NSPS for opacity, participate matter, and carbon




monoxide*  Opacity and particulate matter will be discussed together




since the controls are the same.  Control of carbon monoxide will




be discussed separately.




     4.2.1.1  Particulate Matter Control.  The present NSPS for opac-




ity and particulate matter was based on the use of electrostatic




precipitators as the best demonstrated control technology, (EPA, 1973a)




Even with new innovations, electrostatic precipitators remain the




best demonstrated control technology for particulate matter.




     Electrostatic precipitators are fine particle agglomerators




combined with a gravity settling chamber.  On FCC unit regenerators,




the precipitator is generally a horizontally mounted steel box con-




taining positive electrodes and grounded plates.  A corona discharge




at the electrode ionizes gases which transfer their charge to the




particles present.  The charged particles then drift to the plates or




electrodes where they agglomerate.  A rapping mechanism knocks these




larger, agglomerated particles free from the plates and electrodes




and they settle into a gravity settling chamber or hopper from which




they are collected and discarded.




     The precipitator efficiency is dependent on:  the effective




voltage of the emitting electrodes, the resistivity of the particulate




matter, the particle drift velocity, the collector plate area,







                                 4-7

-------
the plate rapping cycle, and the velocity, residence time and flow




rate of the gas stream.  The primary design parameter is the collec-




tor plate area.  Operating parameters include electrode voltage




adjustment, plate rapping cycle, velocity distribution, and ammonia



injection to reduce particle resistivity.




     Moderate changes in FCC regenerator operation will not affect




the precipitator efficiency.  However, changes in catalyst (affecting




particle resistivity), flue gas flow, or particle size can affect




efficiency significantly.  Particle size is of particular importance.




As particle size decreases, the efficiency of the precipitator




decreases.  Figure 4-1 shows the effect of particle size on the




efficiency of an electrostatic precipitator.  The particle drift




velocity (w) is proportional to particle radius.  For any given plate




size, efficiency will decrease as particle size decreases.  This is




a very important consideration when designing precipitators for FCC




regenerators built or retrofitted with modern, high efficiency cy-




clones and separators that can remove essentially all particulate



matter greater than 15 microns in diameter (Krueding, 1975).  Other




parameters affecting particle drift velocity, such as electrode volt-




age and gas velocity are controlled to increase the drift velocity of




the smaller particles.  Precipitators for FCC regenerator emissions




are currently designed for gas velocities of 5 to 6 feet per second




and 21 to 27 feet of gas travel for 80 to 95 percent removal effi-




ciency; gas velocities of 3 to 4 feet per second and 30 to 36 feet of







                                 4-8

-------
I

-------
gas travel for 95 to 99 percent removal efficiency; with a distance




of 8 1/2 to 9 3/4 inches between colector plates.  Plate rapping is




done approximately every four hours (American Petroleum Institute,



1978).




     Cyclone technology is integral to the operation of a FCC unit.




The primary purpose of the cyclone is to return entrained catalyst to




the fluid bed.  Multiple cyclones in series are used in the reactor




and the regenerator to reduce the loss of catalyst.  These cyclones




are internal to the process unit and, therefore, cannot be repaired




without suspending operations.  Deterioration of the cyclones is an




important factor in determining the operating period of an FCC unit




since most units operate for more than two years before shutdown.




     A cyclone is a centrifugal dust collection device with a tangen-




tial opening through which a particle carrying gas stream enters a




cylindrical barrel at high speed.  The gas stream is given a downward



spiral which forces the particles to the outer wall of the barrel and




downward to a dust hopper.  The "cleaned" gas stream then exits



through the center of the top of the barrel while the collected




particles return to the fluid bed through a dipleg.  The exhaust gas




stream then passes through a series of one or more additional cyclones




prior to its exit from the regenerator.  A thorough description of




cyclone theory is beyond the scope of this report.  For more complete




information, refer to the Manual on Disposal of Refinery Wastes,




Volume On Atmospheric Emissions (American Petroleum Institute, 1978).
                                 4-10

-------
     There are three important factors that affect emissions from

cyclones (American Petroleum Institute, 1978):

     •  Catalyst attrition - production of fine particles

     •  Particle size - particle collection efficiency decreases
        exponentially with decreasing particle size*

     •  Particle loading - particle collection efficiency increases
        with increased loading*

Catalyst attrition, defined as the production of fines (particles

less than 44 microns in diameter), results almost exclusively from

impaction of particles in the first stage cyclone rather than from

the breakdown of particles in the catalyst bed.  Catalyst attrition

is observed in most installations, and makeup catalyst is required to

maintain the fluid bed in the reactor*  Losses occur through the

cyclones which are incapable of collecting the fines.  The bed

inventory eventually reaches an equilibrium which can consist of as

much as 30 weight percent less than 40 microns (American Petroleum

Institute, 1978).

     The particle collection efficiency of a cyclone is affected by

particle size and gas stream loading.  Efficiency decreases exponen-

tially with decreases in particle size until nearly all fines less

than 5 microns pass through uncollected.  On the other hand, effi-

ciency increases with gas stream loading.  This can amount to as much

as a 60 percent increase in efficiency in a cyclone operating at  35
                                 4-11

-------
percent single particle collection efficiency at no load  (< 1 grain

solid/cubic foot gas) when increased to a load of  1,000 grains

solid/cubic foot of gas (American Petroleum Institute, 1978).

     Filters have been used for the collection of  particulate matter

throughout the industry.  There are various types  and their use

depends on the particular characteristics of the gas stream to be

cleaned.  Filters may be:  flexible tubes, bags, or sheets of

material; semirigid supported fabric or mats of fibrous material;

fixed or packed beds of granular particles; and/or fluidized or

moving beds of granules or fibers.  Pertinent gas  stream  character-

istics are particle size, temperature, moisture content,  corrosivity,

and flammability.  Collectively, these characteristics will determine

the suitability of a filter medium.

     The theory of filtration for particulate matter control is that

collection of particles in the micron range will take place by:

     •  Impaction - of the particle on the filter  medium  due to
        inertial impingement as related to gas stream velocity and
        particle size

     •  Interception - of the particle by the medium due  to the
        size of the particle with respect to the pore size of the
        medium

     •  Diffusion - of extremely small particles due to Brownian
        movement which increases the probability of contact with
        the filter medium

     •  Miscellaneous - mechanisms such as electrostatic  forces,
        thermal effects on agglomeration and Brownian movement,
        and sedimentation of heavy particles in low velocity gas
        streams due to gravity.
                                 4-12

-------
     The filter medium can be used either under pressure or vacuum In

order to maintain gas flow.  As particulate matter Is collected,

filter efficiency Increases because the collected material acts as a

filter medium.  As efficiency Increases however, the energy required

to maintain gas flow Increases*  A trade-off point Is reached where

cleaning or replacement of the medium Is required.

     Cleaning is achieved by gentle shaking or reverse gas flow.

Beds are usually not cleaned but are replaced when the pressure drop

becomes excessive.

     Filters are the most efficient particulate matter control device,

especially for very small (sub-micron) particles.  The cost of this

efficiency is relatively high however, and few filters are used on

FCC unit regenerators.

     Wet Scrubbers can be used to remove gaseous pollutants as well

as particulate matter from flue gases.  Although scrubbers are not as

efficient as fabric filters, they can be used for many gaseous

streams that would be unsuitable for fabric filters due to moisture

content, corrosivity, temperature, or flammability.  Scrubbers have

disadvantages such as cost and resulting sludge disposal*

     The sequence of removing particles from a gas stream by using

scrubber technology can be summarized as:

     •  Conditioning - the particles so that a high degree of contact
        occurs between the particle and liquid
                                 4-13

-------
     •  Separation - of the particle/liquid from the gaseous stream
        using cyclones or impingement baffles

     •  Removal - of the particle/liquid from the scrubber, usually
        as a slurry that can be disposed of as is or dewatered for
        recirculatlon to the scrubber.

     Comparisons of the various particulate matter control tech-

nologies have been made by the American Petroleum Institute (1978).

In Table 4-3, relative cost, particle size collection, pressure drop,

and energy consumption are compared for the four types of control

equipment previously discussed.  Filters and electrostatic preclpi-

tators are capable of removing the smallest particles, but the

precipitators have a substantially lower pressure drop.  Single stage

cyclones, spray towers, and electrostatic precipitators have the

lowest power consumption and the lowest relative cost including

auxiliaries.

     Data on the particle collection efficiency of the various con-

trols are shown In Table 4-4.  Fabric filters and venturi scrubbers

have the highest overall efficiency (American Petroleum Institute,

1978).  Many of the controls discussed show a dramatic decrease in

efficiency when collecting smaller sized particles.  Table 4-4 shows

the particle collection efficiency of particle? 5, 2, and 1 micron

in diameter.  It is apparent from this data that the FCC unit regen-

erator cyclones are incapable of significantly reducing small (<5

micron) particle emissions.  The effects of dust, gas stream, and

collector variables on particulate matter control equipment are
                                 4-14

-------
                                                                       TABLE  4-3
                                             anaaxax CHARACTERISTICS  OF DOST ua> MIST COLLECTION EQUIPMENT
Equipment
Cyclones:
Single
Multiple
Electrostatic preclpltators:
One-stage
Two-stage
Filters:
Tabular
Reverse jet
I Envelope
Ul
Scrubbers:
Spray tower
Jet
Venturi
Cyclonic
Inertia!
Packed
Rotating Impeller
Smallest Particle
Relative Collected
Coat (microns)1'
1-2 15
3-6 5
6-30 <0.1
2-6 <0.1
3-20 O.I
7-12 <0.1
3-20 <0.1

1-2 10
4-10 2
4-12 1
3-10 5
4-10 2
3-6 5
4-12 2
•rCttBBUKA UCOp
(Inches of
water)
0.5-3
2-10
0.1-0.5
0.1-0.3
2-6
2-6
2-6

0.1-0.5
-
10-15
2-8
2-15
0.5-10
Power Used
(kilowatt per
1000 cubic feet per
0.1-0.6
0.5-2
0.2-0.6
0.2-0.4
0.5-1.5
0.7-1.5
0.5-1.5

0.1-0.2
2-10
2-10
0.6-2
0.8-8
0.6-2
2-10
Remarks
Staple, Inexpensive, most widely used
Abrasion and plugging problems
High efficiency, heavy duty, expensive
Compact, air conditioning service
High efficiency, temperature and humidity llmiat
More compact, constant flow
Limited capacity, constant flow possible

Low water use
Pressure gain, high-velocity liquid jet
High-velocity gas stream, higher pressure drop
(40 to 70 Inches) will remove submlcron-slced
particles
Modified dry collector
Abrasion problems
Abrasion problem
"includes auxiliaries.
''With 90-95 percent efficiency  (weight).

          pressure loss, water pumping, and electrical energy.
Source:  American Petroleum Institute, 1978.

-------
                                                           TABU  4-4
                                                PARTICLE COLLECTION EFFICIENCY
Collection Hithod
Cyclone, eedlua efficiency
Cyclone; high-efficiency
Cyclone, Irritated
Electrostatic preclpltetor
Fabric filter
Spray tower
Scrubber; wet Isplngeeent
Scrubber; eelf- Induced apray
Scrubber; venturi
Disintegrator
Overall Efficiency
(percent)
65.3
84.2
91.0
94.1
99.9
96.3
97.9
93.5
99.7
98.5
Efficiency at 5w
(percent)
27
73
87
92
>99.9
9A
97
93
99.6
98
Efficiency et 2u
(percent)
14
46
60
85
99.9
87
92
75
99
95
Efficiency at Ip
(percent)
8
27
42
70
99
55
80
40
97
91
Source:  American Petroleua Institute, 1978.

-------
summarized in Table 4-5.  Many of these variables are limiting




factors due to equipment or regulatory requirements.




     4.2.1.2  Carbon Monoxide Control.  The NSPS for FCC unit regen-




erators require that carbon monoxide emissions not exceed 0.05 percent




(volume) of the flue gases.  The flue gas from an uncontrolled




regenerator typically contains 10 percent carbon monoxide (Murphy




and Soudek, 1977).  The emission of carbon monoxide is reduced by



oxidation to carbon dioxide either in a CO boiler or in the regen-




erator itself (in situ combustion).  The oxidation reaction is




exothermic and the heat generated is removed as steam.




     Carbon monoxide boilers are generally water wall boilers using




carbon monoxide and an auxiliary fuel to maintain firing temperatures




of 700°C to 760°C.  The oxidation of CO to C02 is essentially com-



plete* and FCC regenerators using CO boilers do not have difficulty




meeting the MSPS.




     Increased participate matter emissions are permitted from CO




boilers using solid or liquid fossil fuels as auxiliary fuel.  The




increase is calculated from the heat value of the auxiliary fuel as



0.18 gram of particulate matter per million calories of heat input




attributable to the auxiliary fuel.  An exemption from the particu-




late matter standard for a six-minute period permits soot blowing



from the boiler tubes.




     Regenerator in situ combustion of carbon monoxide is achieved by




either raising the temperature in the regenerator or.by using a CO
                                 4-17

-------
                                                                                 TABLE 4-5
                                                            EFFECTS OF VARIABLES OH DUST  COLLECTIOH EQOIPMENT
                           Variable
            Effect of Dust Variations:
                 Efficiency, particles:
                      <1 micron
                      1-10 micron
                     10-20 micron
                      >20 micron
                 Abrasion resistance
                 Ability to handle sticky, adhesive
                 materials
                 Bridging materials give trouble
                 Fire or explosion hazard minimlted
                 Can handle hygroscopic materials
                 Large  foreign materials cause
                 plugging
   Poor
   Poor
   Poor
Fair to Good
   Fair
   Fair
   Slight
   Fair
   Yes

   Seldom
                                                                               High-Efficiency
                                                                                    Cyclones
    Poor
Poor to Fair
    Good
    Good
    Fair
    Poor
    Tea
    Fair
    Fair

    Yes
                                            Electrostatic
                                            Precipltators
   Good
   Good
   Good
   Good
   Good
   Poor
   Yes
   Poor
With Care

   Yes
                                                Fabric
                                              Collectors
   Good
   Good
   Good
   Good
   Good
   Poor
   Yes
   Poor
With Care

Seldom
                                             Wet
                                          Collectors
Poor to f*ir
Fair to good
   Good
   Good
   Good
Poor to good
   No
   Good
   Yes

Seldom to yes
00
            Effect of Gas Stream Variations:
                 Maximum temperature  (C),
standard construction
Troubles from condensed or entrained
mists or vapors
Corrosive gases attack standard
construction
Collector:
Space
Pressure drop (Inches of water)
Reduced volume adversely affects
collection efficiency
400
Slight
Slight
Large
1-2 Inches
Yes
400
Considerable
Slight
Modest
3-5 Inches
Yes with most
designs
400
Some
Slight
Large
1-2 inches
No
82-135 °
Considerable
Slight
Modest to large
2-6 inches
No
No limit
Slight
Severe
Modest
3-6 inches2
Depends on
ifl^fljp
            *Venturl scrubbers are considered good.
            b Filters for higher temperatures  are available.
            cPressure drop for venturl scrubbers is  in the range  of 10 to 70 Inches of uater.
            Source:  American  Petroleum Institute,  1978.

-------
combustion promoter catalyst.  Very often, in situ combustion, which



generally requires that the FCC regenerator unit be capable of with-



standing continuous operation at 760°C, is not feasible in an older



FCC unit regenerator because of metallurgical constraints.



     Increasing the temperature in the regenerator has a number of



beneficial effects in addition to combustion of coke to carbon dioxide,



such as, increased gasoline yields due to greater carbon removal from



catalyst, and decreased coke formation on catalyst.  The decreased



coke formation reduces the overall carbon monoxide and particulate



matter emissions from the FCC regenerator unit.  It does not affect



the ability to meet the particulate matter standard, as the allowable



emission is based on coke burn-off.  Carbon monoxide emissions have



been reported as negligible when using high temperature regeneration



(Rheaume et al., 1976a).



     Carbon monoxide oxidation catalysts are capable of promoting the



oxidation of CO to C(>2 in the regenerator dense bed.  In addition,



these catalysts Increase the yields of gasoline by Improving regener-



ation i.e., reducing the carbon on regenerated catalyst.  If these



catalysts are added to a regenerator already using high temperature



regeneration, the regenerator temperature is reduced.  Because the



oxidation of CO is exothermic, adding oxidation catalyst to a conven-



tional regenerator will raise the operating temperature.  Table 4-6



shows data from three FCC regenerators used to test a CO oxidation
                                 4-19

-------
                             TABLE 4-6

             USE OF CARBON MONOXIDE OXIDATION CATALYST
Operating Parameter

Regenerator:
Dense, °C
Dilute, °C
Cyclones, °C
Flue gas, °C
Flue gas CO, vol %
NSPS Standard, vol %
Unit
1

1325
1333
1450
1422
0
0.05
A
2a

1303
1304
1405
1370
0
0.05
Unit
3

1336
1362
1370
1375
3.6
0.05
B
43

1326
1324
1321
1325
0.3
0.05
Unit
5

1156
1154
1312
1193
9.3
0.05
C
6a

1296
-
1342
1427
0.4
0.05
1 - conventional catalyst
2 - CCA-22 with conventional catalyst mixture
3 - CBZ-1 catalyst
4 - CCZ-22 catalyst
5 - DHZ-15 catalyst
6 - CCZ-22 catalyst

a CCZ-22 carbon monoxide oxidation catalyst

Source:  Rheaume et al., 1976.
                                 4-20

-------
catalyst.  Carbon monoxide levels were reduced to 0.4 percent or less




depending on the operating temperature.



4.2.2  Fuel Gas Combustion Device



     The NSPS standard for sulfur dioxide limits the concentration




of hydrogen sulfide in fuel gas burned at a refinery.  Hydrogen




sulfide in fuel gas is controlled by amine stripping and hydrodesul-




furization.  The standard also permits, as an alternative, the direct




removal of sulfur dioxide emissions from the fuel gas burner stack




gases.  This can be accomplished, for example, by use of wet scrub-




bers.



     Amine gas treating processes include chemical and physical



solvent processes and dry absorbent processes.  The most common




process in petroleum refineries is the diethanolamina (DEA) process




(Gary and Handwerk, 1975).  In this process, sour refinery gas con-



taining hydrogen sulfide and carbon dioxide contacts DEA in an




absorber unit.  The hydrogen sulfide and carbon dioxide are removed




from the refinery gas and the treated, I^S-free gas Is then used as



fuel elsewhere in the refinery.  The treated gas will usually contain




less than 0.57 gram of sulfur/I00 scm of gas (Gary and Handwerk,




1975). The acid-rich DEA solution is regenerated by steam stripping




in a regenerator or still.  The steam is condensed and the separated




0*28 is piped to a sulfur recovery unit.  The regenerated DEA is



recycled to the absorber unit.
                                 4-21

-------
     Hydrotreating can be applied at any point In the refinery process

stream.  It is applied to a wide variety of feedstocks ranging from

reduced crude to napthas and is used to stabilize products and/or

remove undesirable elements in feedstocks by reaction with hydrogen*

Hydrodesulfurization is the removal of sulfur from feedstocks by

catalytic reaction with hydrogen.  The feedstock is mixed with

hydrogen, heated, and passed over a catalyst where the hydrogen

reacts with sulfur in the feedstock to form hydrogen sulfide.

Excess hydrogen is recovered and recycled and a hydrogen sulfide fuel

gas stream is steam distilled from the feedstock.  The fuel gas

stream is sent to an H2S removal unit and the desulfurized product

is ready for further processing.  Any fuel gas generated from further

processing will be very low in hydrogen sulfide.  Since all products

of this feedstock are also low in sulfur, the use of hydrodesulfurl-

zation has significant effects outside the refinery.

     Wet scrubber technology was discussed previously with regard to

the control of particulate matter emissions.  The removal of sulfur

dioxide from flue gases is the subject of a significant amount of

current research.  Processes now in commercial use are:  ammonia

scrubbing, lime-limestone slurry processes, dry limestone processes,

and the Wellman-Lord process (sodium sulfite scrubber).  At least one

proprietary process using an aqueous caustic solution is being used

on an FCC unit regenerator (American Petroleum Institute, 1978).

There are no known examples of S02 scrubbers on process heater

exhaust streams.
                                 4-22

-------
4.3  Achievable Emission Levels



     The emission levels of particulate matter, carbon monoxide, and




sulfur dioxide from regenerators and fuel gas combustion devices are




discussed in the following section.




     4.3.1  Fluid Catalytic Cracker




     The emission levels achievable from FCC unit regenerators



will be discussed for each of the standards.  There is little data




within the EPA Regional offices on operational units which have been




tested for new source compliance.  This is a shortcoming of the




present reporting system being used by EPA Regional offices.




     4.3.1.1  Particulate Matter.  The emission of particulate matter




can be controlled to less than the present standard of 1 kg/I,000 kg




coke burn-off.  However, there is insufficient data to determine the




actual effect of cyclone deterioration with time.  Table 4-7 shows




the currently available compliance test data on particulate matter




emissions from FCC regenerators.  These data indicate that regenera-




tors equipped with electrostatic preclpitators can reduce the emission




of particulate matter to 1.0 kg/1,000 kg of coke burn-off.  Since




electrostatic precipltators are significantly more attractive eco-




nomically than filter systems or venturl scrubbers, they are consid-




ered as the best demonstrated control technology considering cost for




the control of particulate matter emissions from FCC regenerators.




     The additional particulate matter emission permitted from




carbon monoxide boilers is based on data from typical oil or coal-
                                 4-23

-------
                            TABLE  4-7

          COMPLIANCE TEST DATA FOR PAKTICULATE MATTER
         Refinery
        Particulate
          Matter
(kg/1000 k£ coke burn-off)
  Champlin Petroleum Co.,
        Tx.  (1977)

         Run #1

         Run #2

         Run #3

         Average

  NSPS  Standard
           1.35

           0.91

           0.76

           1.01

           1.0
Source:  EPA, 1978.
                               4-24

-------
fired boilers.  There Is no data to substantiate that emissions can



be reduced below this level.




     4.3.1.2  Carbon Monoxide.  The compliance test data for carbon




monoxide emissions from FCC regenerators is shown in Table 4-8.  It



is apparent from these data that the carbon monoxide boiler is capable




of reducing CO emissions to less than 0.004 percent by volume.  The




use of regenerator In situ combustion of carbon monoxide with or



without promoter catalysts can reduce emissions to nearly zero percent




if operated at a high enough temperature (Rheaume et al; 1976).



     4.3.2  Fuel Gas Combustion Device




     The reduction of sulfur dioxide emissions from the combustion




of fuel gas is done primarily by removing sulfur from the fuel gas by



amlne stripping.  The available data on achievable concentrations of




H2& in fuel gas are shown in Table 4-9.  It is apparent from these




data that it is feasible to reduce the H^S concentration of fuel



gas to less than 230 mg/dscm.




4.4  Special Problems Using Control Technologies




     4.4.1  Wet Scrubbers




     It has been reported that it is not possible to use wet scrubbers




in the State of Alaska (EPA, 1978a).  Although this could affect




compliance with National Ambient Air Standards or possibly state




standards for the reduction of sulfur dioxide emissions, this problem




should not affect compliance with the current NSPS for petroleum




refineries.  The best available control technologies considering cost
                                 4-25

-------
                               TABLE 4-8
                 COMPLIANCE TEST DATA FOR CARBON MONOXIDE
               Refinery
Carbon Monoxide
    (Vol %)
  Champlin Petroleum Co.,  Tx.  (1977)

                Run #1

                Run #2

                Run #3

                Average


            NSPS  Standard
    0.00306

    0.00353

    0.00330


    0.05
Source:  EPA, 1978.
                                 4-26

-------
                            TABLE 4-9

               COMPLIANCE .TEST DATA FOR SULFUR DIOXIDE
            Refinery                            ELS
                                             (mg/dscm)
Mobil Oil Co., N.J. (1977)                      137
Delta Refining, TN. (1976)                        7
Hill Petroleum Co., LA. (1977)                   81
Marathon Oil, LA. (1977)                        121
Getty Refining, KA. (1976)                       65
Standard Oil, CA. (1976)                        229*

NSPS Standard                                   230

*reported as "typical analysis - 0.1 gr BLS/dscf"
Source:  EPA, 1978.
                               4-27

-------
are electrostatic precipitators, either CO boilers or regenerator in




situ combustion, and amine strippers.  It should, therefore, be pos-




sible for petroleum refineries in Alaska to comply with the current




NSPS as it is unlikely that climatic conditions will affect these




controls.




     4.4.2  Condensable Particulates




     It has been reported that a significant portion of the particu-




late matter measured by EPA Reference Method 5 from FCC regenerators




using in situ combustion is condensable matter (Huddle, 1978; and




EPA, 1978).  Since the definition of particulate matter is "...any




finely divided solid or liquid material, other than uncombined water,




as measured by Method 5 of Appendix A to this part or an equivalent




or alternative method" (40 CFR 60.2(V)), the difficulty is not what




is collected, but the measurement of the particulate matter catch.




The problem appears to be caused by the condensation of sulfuric acid




mist in the Reference Method 5 probe and filter.  Sulfuric acid mist




is very hygroscopic and water of hydration remains with the particu-




late matter catch after drying.  The Champlin Petroleum Company com-




pliance test report (EPA, 1978) states the results of various analyt-




ical tests performed on a particulate catch.  The results, summarized




in Table 4-10, showed that over 50 percent of the measured Reference




Method 5 particulate matter catch is other than catalyst fines.
                                 4-28

-------
                            TABLE 4-10
        CONDENSABLE PARTICULATES FROM FCC  UNIT  REGENERATORS
            TEST
              RESULT
ASME Instack filter
NaOH titration of Method 5
catch for
Thermal analysis of Method 5
catch

Sulfate analysis of Method 5
catch

X-ray spectre graph of
Method 5 catch
89% less particulate matter than
Method 5

50%


60% weight loss


64% sulfate


27% H-SO, in probe wash
Source:  EPA, 1978.
                               4-29

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4.5  Energy Needs and Environmental Effects




     Energy consumption has always been a factor in the economics of




industrial operations.  Today it has become a topic of national con-




cern.  Because petroleum refineries use approximately 10 percent of




the crude feedstock for energy requirements within the refinery




itself, reductions in this energy use are of interest from both an




economic and supply viewpoint.  Energy consumption in FCC units can




be reduced through the use of carbon monoxide oxidation promoter




catalysts and energy recovery expansion turbines.




     New technologies that will reduce the emission of pollutants to




the atmosphere are of national interest*  These technologies are of




interest to industry as well because of government regulations,




environmental concern, and very often, excessive emissions are an




indication of inefficient process operations.




     4.5.1  Expander Technology




     Expander turbines are used to recover some of the energy usually




lost in the FCC regenerator flue gas.  The amount of energy that is




actually recovered is dependent on the inlet gas temperature, gas




flow rate, and the pressure drop.  Barbier (1977) has estimated that




the maximum recovery is approximately 45 kcal/kg of flue gas.  In




1973, the largest installation was recovering 15,500 horsepower from




a FCC unit installed at a Martinez, California, refinery in 1966




(Braun, 1973). Since that time, expanders as large as 22,000 hp have




been installed (C.F. Braun & Co., 1976).  Today, an estimated 20,000
                                 4-30

-------
hp can be recovered from the average catalytic cracking unit (Oil and
Gas Journal, 1977).
     Two limiting factors have influenced Installation of the energy
recovery units.  First, erosion of the turbine blades by catalyst
fines destroyed early test units.  Experiments and commercial experi-
ence show that virtually all partlculate matter greater than 10
microns must be removed to keep this erosion within acceptable limits
(Murphy and Soudek, 1977).  The development of third-stage catalyst
separators has solved this problem.  There is a slight reduction in
the efficiency of the turbine due to erosion of the turbine blades
with time, but after five years, refineries can expect to recover 95
percent of the energy recovered under the startup conditions (Barbier,
1977).
     The other limiting factor is temperature.  Present state-of-the-
art turbines cannot use gases over 680°C (Barbier, 1977).  Since flue
gas temperatures from regenerators operating with total In situ com-
bustion can reach 760°C a separator and expander capable of continu-
ous operation at 760°C are required.  Without this capability, gases
must be cooled before passing through the expander.
     The power recovered by the expander Is generally used for the
FCC unit air blower.  Any excess power is used to generate elec-
tricity for use at the refinery.  Yearly savings of $685,000 were
obtained at the Shell Oil Company refinery at Martinez, California.
This level of savings yields a 1.8 year payout on a $1.25 million
investment (Braun, 1973).
                                 4-31

-------
     4.5.2  Carbon Monoxide Oxidation Catalysts




     Carbon monoxide oxidation catalysts were introduced in the early




1970's as an alternative to the zeolite catalysts being used in fluid




catalytic crackers.  Typical of these catalysts are the partial com-




bustion zeolite (PCZ) and complete combustion zeolite  (CCZ) series




catalysts offered by W.R. Grace and Company, Davison Chemical Division.




During their first commercial trial in April 1975, CCA-44 was charged




to a FCC unit operating with high-temperature regeneration.  It is




estimated that there are now (1978) 12 FCC units using CO oxidation




catalysts and 12 more using CO oxidation additives (Wallendorf,




1978).




     The PCZ catalysts promote partial combustion of carbon monoxide




with an increase of  17°C to 28°C in the regenerator and are particu-




larly useful where the metallurgy of the regenerator limits the allow-




able operating temperature.  Where the temperature increase is not a




limiting factor, CCZ catalysts can be used to promote  complete com-




bustion of carbon monoxide in the dense bed with a regenerator




temperature increase of approximately 56°C.  This increase in




regenerator operating temperature is generally accompanied by a




reduced cyclone temperature since CO oxidation no longer occurs in




the cyclones.  Only in the case of replacing catalysts under conven-




tional regeneration conditions with CCZ catalysts is the temperature




increased in both the regenerator bed and cyclones.
                                 4-32

-------
     The advantages of using CO oxidation catalysts are:

     •  Reduced cyclone temperatures When operating with regen-
        erator in situ combustion since the oxidation reaction ia
        held in the regenerator dense bed.

     •  Reduced excess air requirements because burning is promoted
        in the dense bed and increased catalyst activity promotes
        more efficient use of air.  The reduced air requirements
        should decrease the gas volume through the cyclones, and
        the increased catalyst activity permits the reduction of
        catalyst circulation rates.  The combination of these
        effects should reduce the erosion of the cyclone because
        of decreased gas volume and particle loading.

     •  Decreased coke on the regenerated catalyst due to burning
        off more of the coke formed in the reactor and reducing
        the amount of coke formed in the first place.  The less
        coke on the catalyst, the higher the catalytic activity
        and the greater the yield of useful products.  PCZ and
        CCZ catalysts are approximately 40 and 150 times more
        active, respectively, than conventional catalysts (Rheaume
        et al., 1976).

     •  The use of torch oil may be discontinued.  Torch oil is
        often used in the regenerator to maintain the high tem-
        perature required for in situ carbon monoxide combustion.

     •  The emission of carbon monoxide is reduced although the
        actual emissions are dependent on the temperature main-
        tained In the regenerator.

     The only disadvantage to the use of carbon monoxide oxidation

catalysts Is on those FCC units presently using a CO boiler.  The

heat value of the carbon monoxide must be made up using an alternate

fuel.

     4.5.3  Sulfur Dioxide Catalysts

     Some of the sulfur in the FCC feedstock is retained in the  coke

on the surface of the catalyst during the cracking process.  Steam

stripping is used to remove entrained hydrocarbons from this
                                 4-33

-------
deactivated catalyst prior to regeneration.  This leaves a sulfur/coke




covered catalyst for regeneration.  During the regeneration process,




the coke is oxidized to CO and C02, and the sulfur to SOX, pri-




marily S02« The sulfur content of the coke is directly related




to the sulfur content of the feed.  It is estimated that uncontrolled




emissions of SOX from FCC unit regenerators in the U.S. average




805 ppm  and may be as much as 2,750 ppm when high-sulfur feed is




processed (Vasalos et al., 1977).




     Amoco Oil Company has developed a new UltraCat cracking process




which reduces sulfur oxide emissions from FCC unit regenerators.  The




process uses a new catalyst that  retains sulfur  oxides on the catalyst




and returns them to the reactor where they are removed with the prod-




uct stream.  If a low sulfur product is required, the sulfur will




be removed by amine stripping or  hydrotreating and eventually




recovered in a sulfur recovery unit.  Pilot tests indicate that




the new catalyst is capable of reducing sulfur oxide emissions




80 to 90 percent and commercial tests are planned to confirm this




data (Vasalos et al., 1977).
                                  4-34

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5.0  INDICATIONS FROM TEST RESULTS




5.1  Test Coverage in Regions



     In January of 1978, the Metrek Division of MITRE Corporation




made a survey of the NSPS compliance test data available at EPA




Regional offices (Watson et al., 1978).  The Compliance Data System




(CDS) Indicated a total of thirteen tests; however, data were avail-




able for only nine.  There were no reported failures of compliance




tests. The Champlin Petroleum Refinery, Corpus Christ!, particulate




matter test is questionable.  EPA Region VI has indicated that no




retest Is scheduled pending review of the actual method used when




taking the third particulate sample (lowest measured level of par-




ticulate matter) and results of continuous monitoring in the future*




     The NSPS compliance test data for petroleum refineries that is




available at the EPA Regional offices is presented in Table 5-1.




There is one particulate matter test at 1.01 kg/1,000 kg coke burn-




off, no opacity data, one carbon monoxide test at 0.0033 percent, and




seven hydrogen sulfide tests with averages ranging from a low concen-




tration of 1.4 mg H2S/dscm fuel gas to a high of 228.8 mg u^S/dscm



fuel gas.  There are indications in the CDS system that four addi-




tional tests have been performed but the data were not available.




This indicates that a total of 13 tests have been performed (Watson



et al., 1978).




     The data presented in Table 5-2 is presented in contrast to this




figure of thirteen NSPS compliance tests.  This table shows the
                                  5-1

-------
                                                                       TABLE 5-1
                                                   NSPS COMPLIANCE TEST DATA - PETROLEUM REFINERIES
EPA Region
Region II
Mobil Oil, Paulsboro, N.J.
Region IV
Delta Refining, Memphis, TN
Region V
Reglor VI
Charaplin Petroleum, Corpus Christl, TX
Hill Petroleum, Krotz Springs, LA
Marathon Oil, Garyville, LA
Region VII
Getty Refining, El Dorado, KA
Region IX
Chevron U.S.A.., El Segundo, CA
Standard Oil, Richmond, CA
Current NSPS
NSPS Data
Indicated Total Particulate Matter Opacity Carbon Monoxide Sulfur Dioxide
Number of Teats (kK/10 kg coke burnof f) (Z) (DDm) (mg HjS/dscm)
Performed Range Average Range Average Range Average Range Average
3
<2.3-3.9 1.4
1 3.7-14.0 7.3
1
3
0.76-1.35 1.01 30.6-35.3 33
58.3-110.5 80.8
99.4-157.1 120.6
2
42.3-73.5 64.5
1
50.8-117.4 80.0
228.8
1.0 30 500 230
Source:  Watson et al., 1978.

-------
                                                     TABLE 5-2

                             GEOGRAPHIC DISTRIBUTION 0? POSSIBLE HSP8 AFFECTED FACILITIBS
RPA
Region
I
II
III
IV
V
VI
VII
VIII
IX
X
Total
Nusber of lew or
Increased Capacity Fluid
"fl^^vtlc Cracker I*"ft8
Cosvleted* .
-
1/10
4/15
-
11/86
16/149
4/4
7/6
6/112
1/3
50/385
Under .
Construction
(conp. date)
-
1C80)
-
-
-
USA)
1C77)
1(79)
1C79)
1(78)
-
-
1(77)
1(78)
2(79)
1(80)
KRA)
Engineering
(conp. data)
-

1(HA)
1(79)
KHA)
1(78)
6(79)
-
1(78)
-
-
2(78)
7(79)
2 (HA)
Huober of Facilities
Reported by Regional
OfflcesC
Fluid Cat
Cracker
(FCC)
-
-
-
-
-
1
-
w
f
-
1
Fuel Gas
Coobustor
(FOC)
-
3
-
2
1
38
6
6
f
6
62
Future
Sources
(FCC/FGC)
-/IP
-/-
-/-
-/-
-/-
1U, 1P/38U, 37P
-/-
e
f
-/IP
in, IP/380, 39P
'Cantrall, 1975.

 Hydrocarbon Processing, 1978; data as of 1 January 1978.

°Watson at al., 1978. (0 - under construction; P - planned)

 Capacity in 103 barrels per stream day.

eCDS .file does not show any sources planned or under construction.  Dse of these entries varies among the
 Regions.  It should not be assuoed that no new sources are planned or are under construction in this Region.

Tlot available.

-------
distribution of possible NSPS affected facilities.  The EPA Regional

offices have reported that there are two NSPS affected FCC units and

62 fuel gas combustion devices (Watson et al.,  1978).  A literature

search shows that fifty refineries have built new FCC units or

increased FCC unit capacity during the period 1975-1978 (Cantrell,

1975; 1978).*  Data on fuel gas combustion sources is not available.

It is not within the scope of this project to determine which facili-

ties are, in fact, subject to the NSPS.

     In addition to the data on present NSPS affected facilities,

Table 5-2 presents information on the geographic distribution of the

growth of these sources.  The EPA Regional offices reported one FCC

unit under construction and one being planned (Watson et al., 1978).

Hydrocarbon Processing (1978) on the other hand reports six FCC units

under construction (new or being modified/revamped to increase

capacity) and eleven more in the engineering phase.**  Again this

data is presented for further consideration for a determination of

which, if any, of these FCC units might be considered affected

facilities and hence subject to the NSPS.
 *See Appendix A for details on which refineries have reported growth
  during this period.

**See Table 4-2 for details on refineries reporting future growth
  plans.
                                 5-4

-------
5.2  Analysis of Test Results

     There is insufficient compliance test data in CDS to make a

Judgement on the adequacy of the present NSPS for petroleum refineries.

The available compliance test data presented indicates that:

     •  The particulate matter standard is compatible with
        the present state of control technology.

     •  The opacity standard, which was set to match the
        mass standard, is compatible with the present state
        of control technology.

     •  The carbon monoxide standard could be changed to reduce
        the allowable emission of carbon monoxide although the
        present data are insufficient to establish an appropriate
        standard.

     •  The sulfur dioxide standard could also be changed to
        reduce the allowable concentration of hydrogen sulfide
        in fuel gas although more data should be collected which
        will relate the H2& reduction achievable to the sulfur
        content of feedstocks.
                                 5-5

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6.0  ANALYSIS OF POSSIBLE REVISIONS TO THE STANDARD




     This section will approach the analysis of possible revisions



to the NSFS by examining the emission of particulate matter, carbon




monoxide, sulfur dioxide, and hydrocarbons.  The analysis consists of




an examination of the available data in light of environmental,




economic, control technology, and process effects.




6.1  Particulate Matter




     There is -Insufficient data to support a change to the present




particulate matter standard.  New control technologies have been




developed that can reduce the emission of particulate matter effec-




tively, but not to a sufficient degree to justify a change in the



NSPS of 1 kg particulate matter per 1,000 kg of coke burn-off.




     Technological trends in the industry do not appear to signifi-




cantly affect the particulate matter standard.  These trends include




the use of higher temperature reactors and regenerators, and new




catalysts and/or additives.  The actual quantity of particulate




matter emitted will be affected by a reduction In the quantity of




coke formed on the catalyst and a reduction In catalyst flow rates,




thereby reducing catalyst and carbon emissions.  This reduction does




not affect the present standard because allowable emissions are based



on the quantity of coke burned off the catalyst.




     The particulate matter emitted from a FCC unit regenerator con-




sists primarily of catalyst fines produced in the first stage cyclone.




Additional particulate matter is the result of chemical reactions In
                                 6-1

-------
the flue gas which result in the formation of condensable sulfates.




The particles range in size from 0.5 micron to 60 microns in diameter




with as much as 86 percent of these particles greater than 10 microns




in diameter (BalT. rt, 1976).  As a result, a number of control tech-




nologies are suitable for reducing the emission level, but present




data show that electrostatic precipitators are the best demonstrated




control technology considering cost for minimizing the final emission




level.  Only filters are as efficient at removing small particles as




electrostatic precipitators.  Wet scrubbers, which have the potential




for efficient small particle removal, also have the added advantage




(from an environmental viewpoint) of removing sulfur compounds.




     The measurement of particulate matter requires the use of




Reference Method 5 or its equivalent.  It has been recognized in




the past that condensable particulate matter will collect in the




impingers of the Method 5 sampling train.  This material is not




included in the reportable particulate matter catch.  It was also




recognized that condensable particles were being collected in the




sampling probe and on the filter (EPA, 1975).  These particles are




reportable as particulate matter.  Most of these condensable parti-




cles are believed to be sulfuric acid mist, a highly hygroscopic




material, and other sulfates.  Because of this, it is difficult to




actually be assured of the quantity of catalyst fines, condensable




particles, and moisture being measured.  At present, all this mate-




rial is, by definition, particulate matter.
                                 6-2

-------
     There are no CDS opacity data to comment on.  The fact that




there is no requirement to record mass emissions and opacity at the




same time is a shortcoming.  There is no reason to require mass



emission testing whenever opacity is measured, but the reverse would




result in the availability of significant data on the relationship




of opacity and mass emissions from FCC regenerators.



     The particulate matter standard was set at a higher level than




can be attained in newly installed FCC unit regenerator systems.




This was done in recognition of the fact that the systems are nor-




mally operated continuously for up to two years or longer without a




major shutdown.  The internal cyclones are inaccessable for mainte-




nance during the period and because of erosion, emissions tend to




Increase (EPA, 1973b).  It is possible that particulate emissions




could be maintained at a lower level through the use of an additional




high efficiency separator external to the regenerator but upstream of




the precipltator.  This separator is reported to be less prone to




erosion, and, because it is external to the regenerator, is more




accessable for maintenance.  The efficiency of the separator is




dependent on the efficiency of the cyclones preceding It.  This effi-




ciency change is due primarily to the size distribution of the par-




ticles In the Inlet stream.  Efficient cyclones change the size dis-




tribution of the particles in the separator inlet stream and there-




fore reduce the separator efficiency.  Separator efficiencies range
                                 6-3

-------
from approximately 70 percent to over 90 percent In units with highly




efficient internal cyclones to poor cyclones, respectively (Krueding,



1975).




6. 2  Carbon Monoxide




     The NSPS for carbon monoxide can be met by the use of a waste




heat boiler which not only controls emissions but recovers the




heat value of the oxidation reaction of carbon monoxide to carbon




dioxide.  The other commonly used control technology is combustion




of the carbon monoxide in the regenerator itself.  The advantages




of in situ regeneration are:  increased yields of useful products,




decreased emissions of particulate matter, and recovery of waste heat




in an energy expander.  There is no CDS data on the carbon monoxide




emissions from a regenerator using regenerator in situ combustion of




carbon monoxide.




     In the past, the metallurgy of the regenerator and cylones was




a limiting factor which determined those FCC units capable of




operating with high temperature in situ combustion.  The recent




development of carbon monoxide oxidation catalysts and additives has




permitted many units to at least partially, and often completely,




oxidize carbon monoxide in the regenerator without resorting to high




temperatures.  Little data are available on the emission level of




carbon monoxide from FCC unit regenerators using CO oxidation pro-




motors.  An additional advantage of using the oxidation promoter




over conventional high temperature regeneration is that the
                                 6-4

-------
oxidation reaction remains In the dense bed, the cyclone temperature



is reduced, and presumably erosion and particulate matter emissions



will be reduced*  There Is no data as yet to substantiate the last



conclusion, although It Is reasonable.



6.3  Sulfur Dioxide



     The present NSPS for sulfur dioxide limits the concentration of



hydrogen sulflde in fuel gas burned In a petroleum refinery to 230



mg H2S/dscm of fuel gas.  There Is provision for the refinery



owner/operator to reduce sulfur dioxide emissions In flue gas



Instead of hydrogen sulflde In fuel gas.  The CDS data that were



available at the EPA Regional offices Indicate that refineries are



presently reducing the concentration of H2S in fuel gas to levels



substantially below the present NSPS.  There were no data to Indicate



by what amount the H£S concentration was being reduced (efficiency



of the controls) nor how the R^S concentration related to the



sulfur content of the feedstock.



     According to Gary and Handwerk (1975), amlne gas treating units



usually reduce sulfur concentrations to less than 5.72 mg/dscm.  The



concentration of H2& in treated fuel gas reported in the CDS files



ranges from less than 7 mg/dscm to 229 mg/dscm (Watson et al., 1978).



Although the compliance test data show concentrations significantly



above the concentration reported in Gary and Handwerk, most of these



measurements are still substantially below the 230 mg/dscm maximum



concentration allowed by the NSPS.
                                 6-5

-------
     Presently, there is no NSPS for sulfur dioxide emissions from




the fluid catalytic cracker regenerator nor from the regenerator




incinerator waste-heat boiler.  The FCC unit regenerator emissions of




sulfur oxides are oocimated at 2.3 x 108 to 3.9 x 108 kg/yr based




on current FCC capacity and emission factors from the EPA (1973).




In addition, there are additional sulfur oxide emissions from the




regenerator waste heat boiler due to the use of auxiliary fuel.  The




actual quantity of emissions depends on the sulfur content of the




auxiliary gaseous, liquid, or solid fuel.  Even if fuel gas is used




as the auxiliary fuel, there are no requirements to control SOX as




the boiler has been exempted from the sulfur dioxide standard for




fuel gas combustion devices.




     State air pollution standards (1976) for SOX from new source




FCC unit regenerators range from 440 ppm to 2,000 ppm in the flue gas.




However, the actual achievable emission rate is dependent on feed-




stock, feedstock sulfur content, and other process variables.  If




the feedstock is low in asphaltenes, hydrodesulfurization may have




the capability to reduce the sulfur oxide emission rate.  Process




variables such as high temperature regeneration and the use of SOX




recycle catalysts may also be capable of reducing the level of SOX




emitted from the regenerator.  Data are not available to specify the




actual levels of these emissions.
                                 6-6

-------
6.4  Hydrocarbons




     The emission of hydrocarbons from FCC unit regenerators is not



addressed in the present NSPS.  There is a great interest in hydrocar-




bons because of the relationship of many of these compounds with health




hazards and the formation of smog.  A number of potentially hazardous




hydrocarbons are known to be present in the flue gas from an uncon-




trolled FCC unit regenerator.  Table 6-1 lists some of the hydrocar-



bons which are known to be hazardous and are known to be present in




the regenerator flue gas stream.  Of particular concern are the poly-




nuclear aromatics (PNA's) because of their potential carcinogenic




effects.  The most abundant FNA in regenerator flue gas is benzo-a-




pyrene (BAP) with a concentration of 0.218 kg BAP/1,000 barrels of




feed.  The concentration of BAP can effectively be reduced in a car-



bon monoxide boiler to 1.41 x 10~5 kg BAP/I,000 barrels of feed




(Arthur D. Little, Inc., 1976).  There are no data to determine the




concentration of BAP in the flue gas from high temperature (in situ)




regeneration nor in the case of regenerators using CO oxidation pro-




moting catalysts.
                                 6-7

-------
                              TABLE 6-1

    HAZARDOUS HYDROCARBONS EMITTED FROM FCC UNIT REGENERATORS



  Hydrocarbons                                Concentration
                                                   (ppm)

  Aldehydes (as H2CO)                              3-130

  Cyanides (as HCN)                            0.19 - 0.94

  Anthracene                                       2,070a

  Pyrenes                                        40 - 28,000a

  Benzo (ghi) perylenes                          15 - 424a

  Benzo (a) pyrene                                 4 - 460a

  Benzo (e) pyrene                               11 - 3,600a

  Phenanthrenes                                  400,000


a Micrograms per barrel of oil charged

Source:  Bombaugh et al., 1976.
                                 6-8

-------
7.0  CONCLUSIONS
7.1  Particulate Matter
     The available data do not support any changes to the present
NSPS.  New technologies such as high efficiency separators, high
temperature regeneration, and new catalysts have reduced the total
quantity of partlculate matter emitted.  The method of calcu-
lating the allowable emissions has already corrected for the
reduction due to changes In catalysts and operating procedures.  The
current standard remains valid.
     The Reference Method 5 for measuring partlculate matter emis-
sions continues to be controversial because the temperature of the
sampling train affects the amount of condensable particles present In
the measured partlculate matter.
7.2  Carbon Monoxide
     The NSPS for carbon monoxide emissions was based on the use of
regenerator in situ combustion.  This method of controlling carbon
monoxide emissions is less effective than a carbon monoxide boiler.
There are Insufficient data to substantiate any change in the original
finding that it is not practical to control CO emissions to less than
500 ppm by in situ regeneration.  The recent advent and Increased use
of CO oxidation catalysts and additives may have altered that original
finding although no compliance test data were found to substantiate
this.
7.3  Sulfur Dioxide
    . A number of conclusions regarding the present NSPS for sulfur
                                 7-1

-------
dioxide have been discussed previously, namely:

     •  Compliance with the present standard is difficult to ensure
        without a continuous monitoring method.

     •  Compliance test data indicates that a reduction in the
        allowable ^ncentratlon of hydrogen sulfide in fuel gas is
        possible.

     •  The present standard for fuel gas combustion devices has
        excluded regenerator waste-heat boilers even though they may,
        in fact, generate and emit SOX when using fuel gas as an
        auxiliary fuel.

     •  Although a separate standard for particulate matter was
        promulgated for regenerator waste heat boilers using liquid
        or solid fossil fuel, no standard applies to the SOX gen-
        erated when these fuels are used.  This should be examined if
        the SOX standard is revised for fuel gas combustion devices
        or a standard is developed for FCC unit regenerators.

     •  The FCC unit regenerator emits significant quantities of sul-
        fur oxides which are presently uncontrolled.  Control technol-
        ogies for the reduction of sulfur dioxide emissions from
        other industries exist and may be applicable to FCC regener-
        ators, and, in fact, there are FCC regenerators with SOX
        emission controls.  At least ten states have a sulfur oxide
        emission limit for FCC regenerators which apply to existing
        and new sources and may be a source of data on the applica-
        bility of SOX control devices.

     •  Little is known of the actual effect of an increased sulfur
        content of feedstocks on the emission of sulfur oxides from
        the regenerator.  Refineries are being forced to process a
        higher sulfur content feed due to shortages of domestic crude
        and this will have an effect on the final emission level as
        well as on the ability to control the emissions.

7.4  Hydrocarbons

     There is not enough known about the emission of hydrocarbons

from FCC units to justify setting a standard.  The present data

however indicate that:  the uncontrolled emissions are significant,

they depend on the process, and because of potential adverse health

effects, they may require control.
                                 7-2

-------
8.0  RECOMMENDATIONS

     The following recommendations are made regarding the NSPS

for particulate matter, carbon monoxide, sulfur dioxide, and hydro-

carbons .

8.1  Particulate Matter

     •  Do not change the present standard of 1.0 kg/1,000 kg
        coke burn-off and 30 percent opacity.

     •  Reevaluate the Reference Method 5 for particulate
        matter.

     •  Require that opacity be measured when mass loading tests
        are made.

8.2  Carbon Monoxide

     •  Collect data to ascertain the level of carbon monoxide
        emissions from high temperature (in situ) regenerators with
        and without the use of CO oxidation catalysts and additives.

     •  Reevaluate the carbon monoxide standard in light of the
        findings from the above research.

8.3  Sulfur Dioxide

     •  Change the definition of a fuel gas combustion device
        to include the regenerator incinerator-waste heat boiler by
        deleting the exemption.

     •  Develop a continuous monitoring method for hydrogen
        sulfide.

     •  Reevaluate the present standard in light of the effect of an
        increased sulfur content of feedstock on the concentration of
        hydrogen sulfide in fuel gas and of current compliance test
        data on achievable levels of hydrogen sulfide in fuel gas.

     •  Investigate FCC unit regenerator sulfur oxide control tech-
        nology, including cost, performance, applicability, effect of
        feed stocks, etc.  Subject to the findings of such an investi-
        gation* develop a standard for sulfur dioxide emissions from
        FCC unit regenerators.
                                 8-1

-------
8.4  Hydrocarbons
        Evaluate the effect of:  conventional regeneration, CO boil-
        ers, high temperature regeneration, and regeneration with CO
        combustion catalysts and additives on the emission of hydro-
        carbons fr-"" FCC unit regenerators.

        Assess the need for the regulation of hydrocarbon emissions
        from FCC unit regenerators based on results from the above
        research.
                                  8-2

-------
9.0  REFERENCES

American Petroleum Institute, 1978.  Manual on Disposal of Refinery
     Wastes.  Volume on Atmospheric Emissions.  Washington, D.C.

Arthur D. Little, Inc., 1976.  Screening Study to Determine Need
     for SOX and Hydrocarbon NSPS for FCC Regenerators.  NT IS,
     Springfield, VA.  Pfi-275 162.

Balfoort, J.P., 1976.  Improved Hot-Gas Expanders for Cat Cracker
     Flue Gas.  Hydrocarbon Processing 55(3):141-143.

Barbier, J.C., 1977.  Save Energy When Making Gasoline.  Hydrocarbon
     Processing 56(9):85-96.

Bombaugh, K.J., E.G. Cavanaugh, J.C. Dickerman, S.L. Keil, and T.P.
     Nelson, 1976.  Sampling and Analytical Strategies for Compounds
     in Petroleum Refinery Streams, Volumes 1 and 2.  Radian  Corpora-
     tion.  NT IS, Springfield, VA.  PB-251 744 and  PB -251  745.

Braun, S.S., 1973.  Power Recovery Pays Off at Shell Oil.  Oil and
     Gas Journal 71(21):128-134.

C.F. Braun & Company, 1976.  Power Recovery for Fluid Catalytic
     Cracking Units.  Alhambra, CA.

Cantrell, A., 1975.  Annual Refinery Survey.  Oil and Gas Journal
     73 (14): 96-118.

Cantrell, A., 1978.  Annual Refining Survey.  Oil and Gas Journal
     76(12):108-142.

Dickerman, J.C., T.D. Raye, J.D. Colley, and  R.H. Parsons,  1977.
     Industrial Process Profiles for Environmental  Use:  Chapter 3.
     Petroleum Refining Industry.  Radian Corporation.  NTIS,
     Springfield, VA  PB-273 649.

Gary, J.H. and G.E. Handwerk, 1975.  Petroleum Refining, Technology
     and Economics.  Chemical Processing and  Engineering Volume 5.
     L.F. Albright, R.N. Maddox, and J.J. McKetta,  ed.

Huddle, J., 1978.  Personal communication.  J. Huddle, AMOCO  Oil
     Company and K. Barrett, The Metrek Division of The MITRE
     Corporation*

Hydrocarbon Processing, 1978.  World-Wide HPI Construction Boxscore,
     Section 2, Feb. 1978.
                                 9-1

-------
Krueding, A.P., 1975.  Cat Cracker Power Recovery Techniques.
     Chemical Engineering Progress 71(10):56-61.

Laster, L.L., 1973.  Atmospheric Emissions from the Petroleum
     Industry.  National Environmental Research Center, Research
     Triangle Par^-  NC.  NTIS, Springfield, VA.  PB-225 040.

Murphy, J.R. and M. Soudek, 1977.  Modern FCC Units Incorporate
     Many Design Advances.  Oil and Gas Journal 75(3):70-76.

Nader, J., 1978.  Personal communication.  U.S. Environmental
     Protection Agency, Research Triangle Park, and K. Barrett,
     The Metrek Division of The MITRE Corporation.

Oil and Gas Journal, 1977.  Mobil Plans Recovery from FCC Unit.  Oil
     and Gas Journal 75 (9):66.

Rheaume, L., R.E. Ritter, J.J. Blazek, and J.A. Montgomery,  1976.
     New FCC Catalysts Cut Energy and Increase Activity.  W.R.
     Grace & Company.  Oil and Gas Journal 74(20):103-110.

Rheaume, L., R.E. Ritter, J.J. Blazek, and J.A. Montgomery,  1976a.
     Two New Carbon Monoxide Oxidation Catalysts Get Commercial
     Tests.  W.R. Grace & Company.  Oil and Gas Journal 74(21):
     66-70.

U.S. Environmental Protection Agency, 1973.  Compilation of  Air
     Pollutant Emissions Factors, AP-42.

U.S. Environmental Protection Agency, 1973a.  Background Information
     for Proposed New Source Performance Standards:  Asphalt Concrete
     Plants, Petroleum Refineries, Storage Vessels, Secondary Lead
     Smelters and Refineries, Brass and Bronze Ingot Production
     Plants, Iron and Steel Plants, Sewage Treatment Plants.  Volume
     I.  Main Text.  Office of Air Programs, Research Triangle Park,
     North Carolina.

U.S. Environmental Protection Agency, 1973b.  Background Information
     for New Source Performance Standards:  Asphalt Concrete Plants,
     Petroleum Refineries, Storage Vessels, Secondary Lead Smelters
     and Refineries, Brass and Bronze Ingot Production Plants, Iron
     and Steel Plants, and Sewage Treatment Plants.  Volume  III.
     Promulgated Standards.  Office of Air Programs, Research Triangle
     Park, North Carolina.

U.S. Environmental Protection Agency, 1975.  Emission Monitoring
     Requirements and Revisions to Performance Testing Methods.
     40 FR 46250-46271.

                                 9-2

-------
U.S. Environmental Protection Agency, 1978.  Compliance Test Report
     for Champlln Petroleum Company, Corpus Christ!, XX.

U.S. Environmental Protection Agency, 1978a.  Personal communication
     between E.L. Keitz, The Metrek Division of the MITRE Corporation,
     and K.A. Lepic, M.H. Hooper, and B. Swan, EPA Region X.   Jan.
     10-11, 1978.

Vasalos, I.A., E.R. Strong, C.K.R. Hsieh, 6.J. D'Souza, 1977.  New
     Cracking Process Controls FCCU SO^.  Oil and Gas Journal  75(26):
     141-148.

Wallendorf, W., 1978.  Personal communication, W. Wallendorf,  Technical
     Services, W.R. Grace & Company, and K. Barrett, Me trek Division,
     MITRE Corporation.

Watson, J.W., L.J. Duncan, E.L. Keitz, and K.J. Brooks, 1978.  Regional
     Views on NSPS for Selected Categories.  MTR-7772.  Metrek Division
     of The MITRE Corporation, McLean, VA. (Draft)
                                 9-3

-------
           APPENDIX A





REPORTED FLUID CATALYTIC CRACKING




  UNITS AT PETROLEUM REFINERIES

-------
                                    APPENDIX A
                      REPORTED FCC UNITS AT PETROLEUM REFINERIES
                                                             FCC Capacity (Mb/ad)
     EPA Ragion                   Company/City              1975*    197V>Changa*

Ragion It

   Connactieut                Nona raportad
                                     n
   Maaaachuaatta
   Naw Hanpahlra
   Rhoda Island
   Vanont
                                 Subtotal:
Raglan Hi

   Haw Jaraay                Exxon, Uadan                  125      135       10
                             Taxaco. Vaatvllla               40       40        0
   Naw York                  Aahland, North Tonavanda        22       22       _0

                                 Subtotal:                   187      197       10


Raglan Hit
Dalawara
Maryland
Pannaylvanla



Virginia
Wait Virginia

Gatty, Dalawara City
Nona raportad
BP, Marcua Book
Oulf , Fhlladalphia
Sun, Marcua Book
united. Warran
Aavco, Torktom
Nona raportad
Subtotal:
62
-.
40
80
75
10
27
_I_
294
62
_
48
84.6
75
11.5
28
"
309.1
0
_
8
4.6
0
1.5
1
"*
15.1
*Zacraaaa/(aaeraaaa)  la FCC capacity
'Raportad in Mb/cd. Mb/ad calculatad
 (Mb/cd - thouaand barrala par  calandar day, Mb/ad - thouaand barrala par at

Sonreaa:

*Canerall, 1975.

bCantraU, 1978.
                                       A-l

-------
                      REPORTED FCC UNITS AT PETROLEUM REFINERIES

EPA Region
Region IV:
Alabama
Florida
Georgia
Kentucky

Mississippi


North Carolina

Company/City

None reported
ti
M
Ashland, Catlettsburg
Ashland, Louisville
Chevron, Pascagoula
Standard of Kentucky,
Pascagoula
None reported
FCC
1975°


-
-
54
10.5
-

56
-
Capacity
1978">


-
-
54
10
56

-
-
(Mb/ed)
Change*

-
-
-
0
(0.5)
56 *
+
(56)
-
   South Carolina
   Tennessee
                                 Subtotal:
                                                             120.5
                                                                      120
                                                 (0.5)
Region V:

   Illinois
   Indiana
   Iowa
   Michigan
   Minnesota
   Wisconsin
Amoco, Wood River               38       38        0
Clark, Blue Island              24       26        2
Clark, Hartford                 26       26        0
Marathon, Robison               36.5     36.5      0
Mobil, Joliet                   66       92       26
Shell, Wood River               94       94        0
Texaco, Lawrenceville           31       34        3
Texaco, Lockport                30       30        0
Union of CA, Lemont             54       55        1
Amoco, Whiting                 118      140       22
Atlantic Richfield,                                  t
  East Chicago                  48       -       (48)f
Energy Coop, East Chicago       -        48       48
Indiana Farm Bureau,
  Mt. Vernon                     6.1      6.3      0.2
Rock Island, Indianapolis       15       17        2
None reported
Marathon, Detroit               21.5     25.5      4
Total Leonard, Alma             12       -       (12)
Total Petroleum, Alma           -        16       16+
Continental, Wrenshall           9.5      9.5      0
Koch, Pine Bend                 24       -       (24)T
Koch, Rosemont                  -        45       451"
Northwestern, St. Paul Park     21       22        1
Murphy, Superior                 9.7      9.7      0

  Subtotal:                    684.3     770.5    86.2
*Increase/(decrease) In FCC capacity
'('Change in ownership
 Reported in Mb/cd, Mb/ad calculated
 (Mb/cd - thousand barrels per calendar day, Mb/sd

Sources:

"Cantrell, 1975.
                       thousand barrels per stream day)
1,
 Cantrell, 1978.
                                         A- 2

-------
                      IEPOKTED FCC WITS AT PETROLEUM HKHIBRIKS
EPA Region Conpany/City
Region VI:
Arkansas Lion Oil Co., Eldorado
Louisiana Citiea Service, Lake Charles
Exxon, Baton Rouge
Good Hope Raf . , Good Hope
Gulf, Belle Chasaa
Murphy, Keraux
Shall, Horco
Tenneco, Chalaette
Texaco, Convent
Ha* Mexico Shall Oil. Clnlsa
Oklahoaa Apeo, Cyril
Cbaaplln, ""I**
Continental. Ponce City
Hudaon, Cashing
Esrr-MeGaa. Wynnewood
Midland, fflffiifpfl
Sun, Duncan
Sun, Tulaa
Texaco, Heat Tulaa
Viekara, Ardaore
Texas AMerican, Fort Arthur
ASDCO, Texaa City
Atlantic RlrhHeld, Houston
Chaaplin, Corpna Cbristi
Houston
Chevron, El Paao
Coastal Stataa, Corpus
Cbristi
Cosdan, Big Spring
Croan "~"-"*''j Houston
Exxon, Bay town
Gulf. Port Arthur
La Gloria, Tyler
Marathon, Taxaa Ctiy
Mobil. Beanaont
Phillips, Borger
Phillips, Owainy
Shall, Deer Park
Shall, Odaaaa
Southwestern, Corpus
Christi
Suntida, Corpus Christi
Sun, Corpus Christi
Texaco, saarlTIo
Texaco, El Paso
Texaco, Port Arthur
Texaa City, Texaa City
union of Calif., Hnftr1j-"1
Onion of Calif., Beaumont
Bineton. Fort Worth
FCC Caoaclty (Mb/ad)
1975* 1979°

15
125
163
15
78
10.5
100
22
70
7.2
6
19.5
44

11.5
7
25
30,
IB1
13
30
135
69
10
24
22

19
24
43
124
120
10
28.5
80
55
30
70
10.5

9.5
20
-
a,l
H
1351
27
40
3.4

15
125
169
17
78
10.5
100
22
70
7.2
6.7
19
44
7
11.5
-
25
30,
IB1
21.5
32
167
74
54
37.5
22

19
24
43
135
120
10
30
90
. 56
34
70
10.5

12
-
25
8*
7*
1351
27
39
3.4
Change*

0
0
6
2
0
0
0
0
0
0
0.7
(0.5)
A
7f
0 .
(7)
0
0
0
8.5
2
32
5
44
13.5
0

0
0
0
11
0
0
1.5
10
1
4
0
0

2.5
(20)t
25*
0
0
0
(40.+
39*

                                Subtotals                  1933.6   2080.8     147.2
nncraasa/(dacrassa)  la ICC capacity
 Chanaa in oanarahla
'laportad in ht/cd, Vb/sd calculated
 Qfc/ed - thousand barrels par calendar day. Mb/ad - thousand barrela par atraaa day)

Soureaai

*Cantrell, 1975.
                                       A-3

-------
                      REPORTED FCC UNITS AT PETROLEUM REFINERIES
EPA Region
Region VII:
Kansas
Company /City
American Petroleum, El
FCC Capacity
1975" 1978°

11
(Mb/sd)
Change*
(ID*
   Missouri
   Nebraska
   Ohio
  Dorado
APCO, Arkansas City
CRA, Coffeyvllle
CRA, Phillip
Derby. Wichita
Getty, El Dorado
National Coop, McPherson
Pester, El Dorado
Phillips, Kansas City
Skelly, El Dorado
Amoco, Sugar Creek
CRA. Scotts Bluff
Ashland, Canton
Gulf, Toledo
Gulf, Cleves
Standard of Ohio, Lima
Standard of Ohio, Toledo
Sun of Pennsylvania, Toledo

   Subtotal:
 9.2
14.5
 7
10.8

20

32
31
41
 2.4
24.5
20
18
37
55
50
 9.6
16
 8.5
10.8
17
20
11
32

41
 2.4
24.5
19.8
18
37.7
55
50
                                                             383.4    373.3
                                                                                 0.4
                                                                                 1.5
                                                                                 1.5
(31) f
  0
  0
  0
 (0.2)
  0
  0.7
  0
  0

(10.1)
Region VIII:
Colorado



Montana



North Dakota
South Dakota
Utah



Wyoming






Asamera, Commerce City
Continental, Commerce City
The Refinery Corp. ,
Commerce City
Cenex, Laurel
Continental, Billings
Exxon, Billings
Phillips, Great Falls
Amoco, Mandan
None reported
Amoco, Salt Lake City
Chevron, Salt Lake City
Major, Roosevelt
Plateau, Roosevelt
Amoco , Casper
Husky, Cheyenne
Husky, Cody
Pasco, Sinclair
Sinclair, Sinclair
Texaco , Casper
Subtotal:
-
14

7.6
10.5
14
19
1.8
23
-
17
10
5
-
9.5
10
3.3
17.7
_
7
169.4
7
15

-
12
15
19.2
1.8
23
-
18
11
-
5.2
9.4
10
3.3
-
17.7
7
174.6
7T
1
X
(7.6)f
1.5
1
0.2
0
0
-
1
1 +
(5> t
5.2T
(0.1)
0
0 +
(17.7);
17.7 f
0
5.2
*Increase/(decrease) In FCC capacity

 Change in ownership
 Reported in Mb/cd, Mb/sd calculated
 (Hb/cd - thousand barrels per calendar day, Mb/sd - thousand barrels per stream day)

Sources:

"Cantrell, 1975.

bCantrell, 1978.
                                         A-4

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                      REPORTED FCC UNITS AT PETROLEUM REFINERIES
     EPA  Region
Region IX:

   Arizona
   California
   Hawaii
   Nevada
  Company/City
None reported
Atlantic Richfield,
  Carson
Chevron, El Segundo
Chevron, Richmond
Exxon, Benecla
Gulf, Santa Fe Springs
Mobil, Torrance
Phillips, Avon
Powerine Oil, Sante Fe
  Springs
Shell Oil, Martinez
Shell Oil, Wilmington
Texaco, Wilmington
Tosco Corp., Lion Oil, Avon
Union Oil of Calif., Los
  Angeles
Chevron, Barbers Point
Standard of Calif.,
  Barbers Point
None reported

  Subtotal:
                                                              FCC Canai
                                                            1975«
                                              (Mb/ad)
57
_
45
13.5
56
47
11
46
35,
28s
45
14.1
397.6
56
47
55
46
13.5
60
11.5
46
35§
28s
47
45
19
-
509
(1)
47
55
1
0
(47)f
0.5
0
0
Jy
0
19+
0.4.1)*
111.4
Region X:

   Alaska
   Idaho
   Oregon
   Washington
None reported
Shell, Anacortes
Texaco, Anacortes

   Subtotal:
36,
27*

63
36
30*

66
0
3
GRAND TOTAL
                              4232.8   4600.3
                 367.5
•Increase/(decrease) in FCC capacity
 Change in ownership
'Reported in Mb/cd, Kb/ad calculated
 (Mb/cd - thousand barrels per calendar dayt Kb/fed:- thousand barrels per stream day)
Sources:
•Cantrell, 1975.

bCantrell, 1978.
                                          A-5

-------
                                    TECHNICAL REPORT DATA
                             (Please read Instructions on the reverse before completing)
1. REPORT NO.

    EPA-450/3-79-008
2.
                               3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
    A Review of Standards of  Performance for  New
    Stationary Sources - Petroleum Refineries
                               5. REPORT DATE
                                      January 1979
                               6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
    Kris  Barrett and Alan Goldfarb
                               8. PERFORMING ORGANIZATION REPORT NO.
                                       MTR-7825
9. PERFORMING ORGANIZATION NAME AND ADDRESS

  Metrek Division of the MITRE Corporation
  1820 Do!ley Madison Boulevard
  Me Lean, VA  22102
                               10. PROGRAM ELEMENT NO.
                               11. CONTRACT/GRANT NO.
                                 68-02-2526
12. SPONSORING AGENCY NAME AND ADDRESS
                                                              13. TYPE OF REPORT AND PERIOD COVERED
  DAA for Air  Quality Planning and Standards
  Office of Air,  Noise, and  Radiation
  U.  S. Environmental Protection Agency
  Research Triangle Park,  NC  27711	
                               14. SPONSORING AGENCY CODE
                                 EPA   200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
    This  report reviews the  current Standards  of Performance  for New Stationary
    Sources:   Subpart J -  Petroleum Refineries.   It includes  a summary of the
    current  standards, the status of current applicable control  technology, and
    the ability of refineries  to meet the current standards.   Compliance test
    results  are analyzed and recommendations are made for possible modifications
    and additions to the standard, including future studies needed for unresolved
    issues.
17.
                                 KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                 b. IDENTIFIERS/OPEN ENDED TERMS  C. COSATI Field/Group
18. DISTRIBUTION STATEMENT

  Release Unlimited
                 19. SECURITY CLASS (ThisReport}
                   Unclassified
21. NO. OF PAGES
       83
                                                20. SECURITY CLASS (Thispage)
                                                  Unclassified
                                             22. PRICE
EPA Form 2220-1 (R«». 4-77)   PREVIOUS EDITION is OBSOLETE

-------