2012 Regulatory Update - Brimstone STS Regulatory Update September 12, ... –Root cause analysis...

2012 Sulfur Recovery Symposium Regulatory Review

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2012 Regulatory UpdateSeptember 12, 20122012 Sulfur Recovery SymposiumSonnenalp Resort, Vail, Colorado

By: Philip J. Oberbroeckling, P.E.Consulting EngineerTechnical Assurance - Process Design & TechnologyHouston Refining LP, A LyondellBasell Company

2012 Sulfur Recovery Symposium, Vail Colorado September 11-14, 2012 2

2012 Regulatory Topics

• NSPS Subpart Ja Status• GHG Regulation Current Status• Proposed NSPS Subpart OOOO Status• H2S TRI Reporting Status• 2012 Fuel Specification Changes• National Ambient Air Quality Standards:

– (NO2 and SO2) Current Status

• Proposed New NAAQS for PM2.5 and New Definition• Cross-State Air Pollution Rule (CSAPR) Status• Permitting Developments:

– PM2.5 NSR definition change– New U.S. Facility


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New Source Performance Standard (NSPS) -Subpart Ja updates

• Updated revisions finalized on June 1st awaiting publication in the Federal Register

• Definition of fuel gas combustion devises updated to exclude flares:– Main result is that there is no longer a long-term sulfur limit on gases

sent to a flare

• List of “newly added connections” that don’t trigger a flare modification:– Basically, a new connection to a flare must result in an emissions

increase to trigger a modification

– e.g. Gas recovery and amine sweeter add-ons don’t trigger

• Flare flow limits have been eliminated


New Source Performance Standard (NSPS) -Subpart Ja updates

• Applicable flares:

– Must be continuously monitored for TRS using method 15A

–Emergency/intermittent-only flares are not required to continuously monitor flow rate if releases are limited and the water seal is monitored

– Root cause analysis and corrective action plan are required for releases above 500,000 scf/d and 500 lbs SO2 in a 24-hour period

• Key Sulfur Recovery Change:– Definition of a sulfur recovery facility is revised to include off-site

facilities processing sour gas from refineries


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Green House Gas (GHG) Regulation

• U.S. Federal Appeals Court upheld the rules on June 26th

• On June 29th, the EPA issued a final rule that does not revise the permitting thresholds from the GHG Tailoring rule:

– Facilities that emit at least 100,000 tpy CO2e will be subject to Title V permitting requirements

– PSD permitting for new construction projects emitting at least 100,000 tpy CO2e GHG and modifications at existing facilities that increase GHG emissions by at least 75,000 tpy CO2e

• EPA is finalizing a streamlining approach to use “plant-wide applicability limits” (PALs):

– Should assist with minor changes/modifications

• Stay tuned – its not going away!


NSPS Subpart OOOO Status

• Final rule became effective on August 16th

• New regulation impacts:– The sulfur recovery efficiency requirement is 99.9% for NG sulfur

recovery units > 5 tpd feed rate with H2S content 50%– Add leak detection and repair (LDAR) programs for fugitive

emissions– Storage tanks with 1 BPD condensate throughput or 20 BPD

crude throughput must have 95% Vapor recovery efficiency or flare controlled

– New – control requirements for centrifugal compressors– New – rod packing replacement requirements for reciprocating

compressors– New – control requirements for pneumatic controllers


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H2S Toxic Release Inventory Reporting Status

• Administrative stay has been lifted; all facilities subject to EPRCA/SARA 313 will be required to add H2S into their 2012 TRI Report (submission deadline July 1, 2013)

• H2S emissions/release information will now be more readily available to the public:– More public/environmental advocacy group scrutiny

• The reported quantity of the toxic chemicals for your plant TRI Report will increase:– Example: Heavy sour refinery will see an increase in

total inventory reported of approximately 1 to 1.5%


2012 Fuel Specification Changes

• January 1st, 2012:– Global maritime bunker fuel must be a maximum of 3.5%

sulfur (down from 4.5%)

• June 1st, 2012:– Locomotive and marine diesel produced by large refiners

must be 15 ppm sulfur max

• North American ECA became enforceable on August 1st, 2012:– Maritime ECA bunker fuel must be a max of 1.0% sulfur

– July 13th, Alaska filed a lawsuit in the U.S. District Court in Anchorage to block the requirement

– Note: ECA bunker fuel spec drops to 0.1% sulfur in 2015


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National Ambient Air Quality Standards (NO2)

• New Standard Implemented on January 22, 2010

• 1-hour standard of 100 ppb (annual standard of 53 ppb retained)

• On February 29th, the EPA declared all areas of the U.S. were found to be in attainment or unclassifiable

• On July 17th, Federal Appeals Court upheld the standard

• Work continues to implement the 219 monitor network required for program compliance by 1/1/2013


National Ambient Air Quality Standards (SO2)

• New Standard implemented on June 2, 2010

• 1-hour standard of 75 ppb

• 24-hour standard of 140 ppb and annual standard of 30 ppb eliminated


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Under Previously Existing SO2 NAAQSCounties Designated Nonattainment for SO2

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Refining Locations


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• New Standard implemented on June 2, 2010

• 1-hour standard of 75 ppb

• 24-hour standard of 140 ppb and annual standard of 30 ppb eliminated

• EPA denied request to reconsider the new standard on January 26th, 2011:

– Several industry and interest groups filed lawsuits

• EPA first proposed a revised implementation approach using both monitoring and refined modeling:

– Received significant negative feedback on the revised approach



• On April 12th, EPA issued letters to the states removing modeling requirements for unclassified areas for the 2013 SIP submittals

• EPA drafted a “whitepaper” outlining the implementation plan issues, options and questions to facilitate “stakeholder” discussions

• EPA held separate individual “stakeholder” group meetings to get feedback on implementation approach (May 30th to June 1st, 2012):– Environmental and Public Health Organization (EGSs)– State, Local and Tribal regulating entities (SLTs)– Industry


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Entity Monitoring Modeling Implementation

Environmental & Public Health Groups (ESG)

Not adequate Needed Based on both

States, Locals & Tribes(STLs)

Adequate with modifications

Not representative (over predicts)

Hybrid Approach(case-by-case)

Industry Adequate with modifications

Not representative (over predicts)

Based on monitoring only

Entity Other Key Feedback

EGSs • ~Half of the key problematic sites are currently unmonitored• Concerned about delays with “unclassifiable” designations

SLTs • Industry has been very cooperative with monitoring• Who will bare the cost of additional monitoring

Industry • Phased approach should be used for adding monitoring• If possible, resolve problem areas without non-attainment status

Principle feedback from the meetings:



• As a result of the stake hold feedback, the EPA has determined that it had insufficient data to complete all the attainment designations by June 1st, 2012:– July 27th, EPA extended the deadline to June 3rd, 2013

• On July 20th, Federal Appeals Court dismissed the lawsuits and upheld the standard:

– The program will be moving forward to implementation

• Stay tuned!


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• Note: Delays are not retroactive to new PSD, Title V and other applicable permitting activities:– All new permitting activities must be modeled against

the new standard - immediately– Impact example: Sour oil and gas operations in Texas

currently applying for Maintenance, Start-up, Shutdown (MSS) permitting activity: Applications are due January 5th, 2014 Preliminary modeling showing facilities without

redundant SRU capacity are having trouble meeting the standard when flaring for SRU outages

Flaring needed to prevent damage from well shut-ins


National Ambient Air Quality Standards (PM2.5)

• On June 14, 2012; EPA proposed to change the NAAQS for fine particulate matter:– New annual standard to between 12 – 13 μg/m3 from

current standard of 15 μg/m3

– Retain the current 24-hour standard of 35 μg/m3– Set a new separate fine particle standard to improve

visibility, primarily in urban areas between 28 - 30 deciviews: One deciview represents the minimal perceptible change in

visibility to the human eye

• New standard would leave very little margin against background levels


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• To give some perspective:– Assume a human has total particle deposition (note:

studies show actual deposition between 17 and 39% depending on particle size)

– Assume the particles are retained for lifetime (note: the majority of PM2.5 are soluble compounds – not retained)

– Person lives 80 years and weighs 175 lbs, averaging 16 breaths per minute at 0.5 liters per breath over their lifetime

– Total air intake = 5,939,645 ft3 over lifetime

Under Old Standard Under New Proposed Standard

0.0056 lb (0.0032% of body weight)

0.0045 lb (≈1 US dime)(0.0026% of body weight)

Total Lifetime (80 years) Particulate Accumulation



• Why is PM2.5 important to the Sulfur Recovery Industry?

• SO2 released to the atmosphere forms sulfate particles through many different homogeneous and heterogeneous reactions:– SO2 + OH radicals/H2O2 → SO3 + H2O → H2SO4

– SO2 + H2O → H2SO3 + ozone/H2O2 → H2SO4

– SO2 + OH radicals/H2O2 → H2SO4

– Reactions driven by photochemistry, atmospheric metals catalyzied and enhanced by ozone and humidity levels

– Sulfuric acid aerosols, NH3 neutralization and condensation/coagulation form the particulates

• Sun light reflecting off the particles causes haze


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Crustal MaterialElemental CarbonOrganic CarbonNitrates

Sulfates

Eastern United States Western United States

Contribution of Various Particulates to Haze

• Sulfates are the largest contributor to U.S. regional haze problems

Source: Camnet, 2012

Sulfates



• Coal-fired power plants have been targeted as the primary contributor, but all SO2 sources will be looked at heavily:– Oil refineries are on the list

• High concern that new projects will have to implement strict PM/SO2 controls

• Areas currently thought to not have a PM problem may not achieve attainment. Areas of concern:– Urban areas with high mobile source traffic– Industrial areas with high truck and rail traffic– Could force additional controls for SO2 emissions

• This is early in the process and we need to watch it closely!


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Cross-State Air Pollution Rule (CSAPR)

• Rule was finalized on July 6, 2011 and published in the Federal Register on August 8, 2011(76 FR 48208)

• This is a replacement for the Clean Air Interstate Rule which regulates electric utilities

• This rule requires 28 states to significantly improve air quality by reducing power plant emissions that contribute to ozone and/or fine particle pollution in other states


States controlled for both fine particulates (annual SO2 and NOX) and ozone (ozone season NOX) (21 states)

States controlled for both fine particulates only (annual SO2 and NOX) (2 states)

States controlled for ozone only (ozone season NOX) (5 states)

States not covered by the Cross-State Air Pollution Rule

Cross-State Air Pollution Rule


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Cross-State Air Pollution Rule (CSAPR)

• The rule originally implemented massive reductions in SO2 emissions in a very short time frame (was January 1, 2012) – so short that most sites would not have possibly installed controls in time to meet limits

• As a result, many utilities were looking at fuel switching in 2012 and 2013 to try to minimize penalties

• Oil, pet coke-fired and coal utility boilers and power plants would have been looking for lower sulfur versions or alternatives to their regular fuel

• Many utilities were looking at switching to NG-fired units

• U.S. Federal Appeals Court issued a stay on the rule on December 30th, 2011 to complete a judicial review


Cross-State Air Pollution Rule (CSAPR) Status

• Earthjustice filed an August 6th lawsuit to force older high emissions coal-fired power plants to install controls rather than seeking compliance under CSAPR

• On August 21st, the Court vacated and remanded the rule back to the EPA:– EPA used the “good neighbor provision” to impose emissions

reductions on upwind States without regard to the limits imposed by the statutory text

– EPA quantified States’ good neighbor obligations and simultaneouslyset forth EPA-designed Federal Implementation Plans (FIPs) departing from the good neighbor provision thus violating the CAA

– The court also ordered EPA to continue administering the Clean Air Interstate Rule (CAIR) pending promulgation of a valid replacement


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Clean Air Interstate Rule (CAIR)

• The rule provides states with a solution to the problem of power plant pollution that drifts from one state to another

• CAIR covers 27 eastern states and the District of Columbia


Clean Air Interstate Rule (CAIR)

• The rule uses a cap and trade system to reduce the target pollutants - sulfur dioxide (SO2) and nitrogen oxides (NOx) -by 70 percent

• States must achieve required emission reductions using one of two compliance options:

– Meet the state’s emission budget by requiring power plants to participate in an EPA-administered interstate cap and trade system that caps emissions in two stages

– Meet an individual state emissions budget through measures of the state’s choosing


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New Permitting Developments

• On March 12th (published March 16th), EPA proposed changes to the New Source Review program to change the definition of PM2.5 to include condensable particulates

• This includes sulfuric acid mists

• This is a measure to fix the inadvertent error in 2008 where this was left out

• Biggest impact potential is on new projects at sulfuric acid plants



• A new major facility sulfur recovery project in the US has a regulatory driven stack emissions limit of 12 ppmv SOx emissions (0% O2, dry basis)

• Constitutes a regulatory required sulfur recovery efficiency of 99.993%

• Claus/TGU/Incinerator/Scrubber configuration– Post-incineration caustic scrubbing

• Other pollutant limitations:– CO = 12.7 ppmv

– NOx = 5.2 ppmv

• Driven by a project BACT determination (??? - protocol concern)


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Best Available Control Technology (BACT)

• A pollution control standard mandated by the United States Clean Air Act

• Current EPA standard for all polluting sources that fall under the New Source Review and is determined on a case-by-case basis

• Governing regulatory agency determines what air pollution control technology will be used to control a specific pollutant to a specified limit

• Typically defined from EPA and agency “clearing houses”:– Not necessarily a requirement– Note: local agency’s clearing house has no listing for sulfur recovery

• When a BACT is determined, factors such as energy consumption, total source emission, regional environmental impact, and economic costs are taken into account


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Defining and Establishing BACT

• Technologies being available don’t necessarily qualify them as BACT when the clearly established definitions/guidelines by the EPA (ultimate governing body) are properly applied

• Application of alternative technologies should consider impact items such as:

– Emissions & energy consumption from manufacturing and shipping the chemicals used

– Energy consumption of operating the additional equipment

– Impacts to other systems (e.g. waste water treatment system)

– Total lifetime cost of emissions controlled

• Technology applications must also consider the control requirements


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Control Technology Requirements

• What are the regulatory control technology requirements:

– RACT, or Reasonably Available Control Technology, is required on existing sources in areas that are not meeting national ambient air quality standards (i.e., non-attainment areas).

– BACT, or Best Available Control Technology, is required on major new or modified sources in clean areas (i.e., attainment areas).

– LAER, or Lowest Achievable Emission Rate, is required on major new or modified sources in non-attainment areas.

• What is the specific driver for this project?


Technology Drivers – What is this area’s status

• The area/city where the facility/project is located:– Has previous 8-hour NAAQS SO2 attainment status

– Recommended for new NAAQS 1-hour SO2 attainment status

– Non-attainment for NAAQS PM2.5/10 and Ozone Sulfates formed by SO2 contribute to fine particulate pollution

• Therefore; a case could be made for a “LAER” application for SO2 emissions due to PM2.5 non-attainment status

• Proper analysis would demonstrate the TGU/Scrubber combination to not be a BACT application, but possibly a LAER application for PM2.5 control


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• Because of the permitting philosophy of this project – the EPA is provided with additional justification to make a case for a new sulfur recovery Federal BACT requirement

• There could be RACT ramifications:– For existing facilities in newly established 1-hour SO2 NAAQS

non-attainment areas

• Permitting philosophy details make a difference!– Follow permitting protocols, period!

– When case-by-case technology exceptions are accepted –clearly and correctly define the premise for that direction!

– Work with your agency permitting engineer to ensure that the details and wording are correct

– Remember – local determinations can have nation-wide impacts!


What’s Next?

• The battle over the SO2 NAAQS is over; attention needs to be turned to a proper and prudent implementation plan:– Work diligently with your local authority - for the most part

they are on our side!

• Wait to see how the EPA will respond to the CSAPR ruling

• Industry needs to push for reasonableness on the PM2.5Standard:– Request the EPA to wait for SO2 NAAQS effects to take hold

before implementing additional burdensome change

– Encourage your local authorities to do the same

• The trillion dollar question – 2012 election outcome?

• Stay tuned!


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2012 Sulfur Recovery Symposium, Vail Colorado September 11-14, 2012

Thank you for your attention

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Special Thanks to:Jason Graves, P.E.

of Waid Environmental for his assistance with the topical research for the Regulatory Update.


Disclaimer:All information (“Information”) contained herein is provided without compensation and is intended to be general in nature. You should not rely on it in making any decision. LyondellBasell accepts no responsibility for results obtained by the application of this Information, and disclaims liability for all damages, including without limitation, direct, indirect, incidental, consequential, special, exemplary or punitive damages, alleged to have been caused by or in connection with the use of this Information. LyondellBasell disclaims all warranties, including, but not limited to, the implied warranties of merchantability and fitness for a particular purpose, that might arise in connection with this information.

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About the Author:

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Philip Oberbroeckling, P.E. is a Consulting Engineer for LyondellBasell providing sulfur recovery and refining technical support to the Houston, Texas Refinery. Over Philip’s 22 years of service in the refining industry, he has held numerous engineering and management positions in Process, HSSE and Operations including a 5-year tenure as the Operations Superintendent of the Houston Refinery 1000 LT/D Sulfur Recovery Complex. Philip has a Chemical Engineering degree from Iowa State University and is a registered Professional Engineer in Montana and Texas. Philip has authored over 30 conference papers and presentations on sulfur recovery and refining topics. Philip is a member of the Sulfur Recovery Symposium Technical Advisory Committee and Chairman of the Environmental and Safety Committee.


References

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NSPS Subpart Ja Status:•http://www.epa.gov/ttn/oarpg/t1/fr_notices/refineryrule.pdf

Proposed NSPS Subpart OOOO Status•http://www.epa.gov/airquality/oilandgas/actions.html

GHG Regulation Current Status:•http://www.epa.gov/NSR/documents/20120702fs.pdf

H2S TRI Reporting Status:•http://yosemite.epa.gov/opa/admpress.nsf/d0cf6618525a9efb85257359003fb69d/e5917955bbcef0408525793e004acc4a!OpenDocument

Proposed New NAAQS for PM2.5 and New Definition•http://www.epa.gov/pm/actions.html•http://www.epa.gov/airquality/particlepollution/actions.html•http://www.hazecam.net/poor-vis.aspx•http://erj.ersjournals.com/content/28/2/286.full.pdf•http://yalmalki.kau.edu.sa/Files/155/Researches/59757_30334.pdf

Cross-State Air Pollution Rule (CSAPR) Status:•http://www.epa.gov/airtransport/•http://www.epa.gov/airtransport/actions.html•http://www.gpo.gov/fdsys/pkg/FR-2011-08-08/pdf/2011-17600.pdf

National Ambient Air Quality Standards:•http://www.epa.gov/air/sulfurdioxide/pdfs/20120522whitepaper.pdf•http://www.epa.gov/air/sulfurdioxide/pdfs/20120530HighLevelSummary.pdf•http://www.epa.gov/air/sulfurdioxide/pdfs/20120531HighLevelSummary.pdf•http://www.epa.gov/air/sulfurdioxide/pdfs/20120601HighLevelSummary.pdf•http://www.epa.gov/so2designations/regs.html•http://www.epa.gov/air/sulfurdioxide/pdfs/so2implementationnoafs.pdf•http://www.epa.gov/airquality/sulfurdioxide/pdfs/20120320factsheet.pdf

PM2.5 NSR definition change:•http://www.epa.gov/airquality/sulfurdioxide/pdfs/20120320factsheet.pdf

New Permitting Developments:•http://www.epa.gov/oar/caaac/pdfs/BACT_source_definition_questions.pdf•http://www.hunton.com/files/Publication/f96384f1-3771-420c-a39a-c280e02b4600/Presentation/PublicationAttachment/6f5caf94-5b30-4069-b91d-2eb0ed928220/Debunking_BACT.pdf

2012 Regulatory Update - Brimstone STS Regulatory Update September 12, ... –Root cause analysis...

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