PLANT DESIGN: ENVIRONMENTALCONSIDERATIONS

INTROS – KAT GALLOWAY

UT Chemical Engineering 2003 (focus on environmental)

Internships at a chemical plant on the ship channel and for environmental companies, undergraduate research with Dr. Allen

Member of Theta Tau – engineering fraternity

UNC Chapel Hill Environmental Sciences Master’s 2008 (focus on air quality)

Worked for large environmental consulting firms doing air permitting and air quality work: URS (AECOM), ARCADIS

Formed Bright Sky Environmental in 2018 – an environmental consulting firm focused on oil and gas

2 UT interns! www.BrightSkyENV.com

Board member at the Texas Alliance of Energy Producers

Board member at the Texas Well Protected Energy Foundation

PUTTING THE ENVIRONMENT INTO CONTEXT Environmental protection rules in the US have evolved over the last 100+ years, starting with protection of natural

resources (National Parks, Wilderness, etc) and then merging into protection of human health and the environment.

Clean water and sanitation, Water Pollution and Control Act

Solid waste and disposal

EPA formed in 1970 under President Nixon – federal monitoring, standard-setting, and enforcement of environmental protection

Clean Air Act

Federal Insecticide, Fungicide, and Rodenticide Act

Endangered Species Act

Hazardous Materials Transportation, Resource Conservation and Recovery Act

Emergency Planning and Right to Know

Water Quality Act

BENZENE: HEALTH EFFECTS

Benzene is a colorless/light yellow liquid and has a slightly sweet smell.

Present in the naphtha reforming process and is one of the top 20 chemicals used in the US.

Present in volcanoes/fires and cigarette smoke.

Benzene is a known human CARCINOGEN via all routes of exposure: long-term exposure to high levels of benzene in the air can cause leukemia.

Other variations of benzene are possible carcinogens.

Real world note: OSHA requires that the employer shall maintain in the workplace copies of all SDS sheets for hazardous chemicals. Expect for the chem plant/refinery to cover benzene in their safety training.

Toxicological Profile for benzene: https://www.atsdr.cdc.gov/toxprofiles/tp3-c8.pdf

REGULATION OF BENZENE

Due to its toxicity, it is highly regulated by the US EPA and other federal entities.

Applicable regulations include:

OSHA (safety) exposure standards

EPA national primary drinking water standards

EPA reportable quantities in water (releases)

FDA standards in bottled drinking water

EPA Superfund (remediation/cleanup)

EPA emergency planning and community right-to-know

EPA hazardous waste reporting

EPA air permitting and compliance

Each state may have its own environmental regulations, so always learn state-specific requirements!

AREAS OF ENVIRONMENTAL CONCERN AT A CHEMICAL PLANT/REFINERY

• Stormwater and discharges• Water treatment plant

• Waste generation and disposal

• Air permitting and compliance• GHG reporting

• Risk Management Plan• Toxic Substances Reporting• Toxic Release Reporting

Safety Air

WaterWaste

AIRChevron Richmond Refinery: ©ABC 7 news

Sturgeon Refinery: ©JWN Energy

White & fluffy = steam (good) Black = smoke and incomplete combustion

EPA: AIR PERMITTING You’ve designed your naphtha reformer, yay! Can you build it yet? No way. You’ll need permits before you break

ground.

Air permitting is a complex process in which you quantify the potential emissions from all pieces of equipment and outline how to comply with all state and federal air rules.

Determine emissions from every flare, heater, boiler, fugitive emissions from piping, tanks, engines, stack, cooling tower, maintenance activity, etc.

An air permit must be prepared, submitted, and approved prior to any construction. Two years in advance minimum for a facility such as this.

Benzene is listed on EPA’s list of 187 hazardous air pollutants in the Clean Air Act more regulation

Example air permit application: https://www.marathonpetroleum.com/content/documents/Operations/Refining/El_Paso/WRT%20Permit%2093546%20-%202020%20Renewal%20-%20App%20v1.1.pdf

EXAMPLE: COMBUSTION AIR EMISSIONS Emissions include products of combustion (NOx, CO, PM, HAP, CO2)

Engines associated with compressors or generators

Emissions = Hp x C x EF

Hp = equipment maximum power rating (hp)

C = Equipment specific fuel consumption (Btu/hp-hr)

EF = Emission factor (lb/MMBtu)

Heaters/Boilers

Emissions = (HI / HV) x EF

HI = Equipment heat input rating (MMBtu/hr)

HV = Heating value of fuel combusted

EF = Emission factor (lb/106 scf)

AIR REGULATIONS Air emissions from refineries (and other sources) have regulations that apply to specific pieces of equipment – these

are regulated through EPA’s “New Source Performance Standards” (NSPS) NSPS Subpart J and Ja - Standards of Performance for Petroleum Refineries

For particularly hazardous pollutants (i.e., benzene), EPA additionally regulates emissions through “National Emission Standards for Hazardous Air Pollutants” (NESHAP). Sources subject to NESHAPs are required to conduct performance testing to demonstrate compliance and are generally required to

monitor control device parameters continuously.

NESHAP MACT Subpart CC (1995) regulates miscellaneous process vents, storage vessels, wastewater, equipment leaks, gasoline loading racks, marine tank vessel loading and heat exchange systems

MACT Subpart UUU (2002) regulates process vents on catalytic cracking units (CCU, including fluid catalytic cracking unit (FCCU)), catalytic reforming units (CRU), and sulfur recovery units (SRU)

MACT (2009) maximum achievable control technology (MACT) standards for heat exchange systems which were not originally addressed in Subpart CC.

BENZENE FENCELINE MONITORING

Context: Human exposure to benzene and environmental justice for low-income residents near refineries

EPA 40 CFR 63 Subpart CC in 2015 requires that refineries install passive fenceline benzene monitors along the perimeter of the refinery and to take action if the levels are high.

The benzene concentrations are measured using monitoring tubes placed around the property boundary of the refinery. Each tube measures a sample of the ambient air at the fenceline over a continuous two-week period and is replaced by a new tube at the end of each sampling period.

Benzene action level is 9 ug/m3 over a one-year period– facility must initiate an action plan within 5 days of the exceedance and must complete a root cause analysis and initial corrective action within 45 days of exceedance

GREENHOUSE GAS REPORTING

Applicable to a set of industries and emissions categories, such as:

Petroleum refining

Oil and Gas Production/Processing/Gathering

Cement manufacturing

Electricity generation

Iron and steel production

Petrochemicals

Mandatory annual emissions reporting

Data available to the public:

EPA Flight (GHG): https://ghgdata.epa.gov/ghgp/main.do#

Envirofacts (environmental programs): https://enviro.epa.gov/

WATER

WATER QUALITY

National Pollutant Discharge Elimination System (NPDES)

Clean Water Act prohibits discharge of pollutants through a point source into a “water of the United States” unless they have an NPDES permit

Contains limits on what can be discharged

Monitoring and reporting requirements

Protects water quality and human health

“water of the US” is a navigable water used for interstate travelers, source of fish/shellfish, etc.

Not needed if you discharge to a treatment plant

STORMWATER CONSTRUCTION PERMIT

NPDES applicable to construction that disturbs natural land

Emphasis on pollution control and best management practices to reduce erosion

Stormwater Pollution Prevention Plan (SWPPP or SWP3)

Preparedness and contingency plans

Review of impaired waterways and determination of TMDLs (total maximum daily loads)

Water sampling requirements – routine and within certain timeframes of large rain events

WASTEWATER PROCESSING & DISPOSAL

Refineries and some chemical plants have their own industrial wastewater treatment plant

Municipal treatment facility is not configured to handle a wide range of hydrocarbons and free oil from a refinery

Industrial wastewater permit:

Describe sources of wastewater

Treatment techniques

Outfalls/disposal methods

Stormwater management

Testing

WASTE

HAZARDOUS WASTE GENERATION

Hazardous waste: A solid waste with properties that make it dangerous or capable of having a harmful effect on human health or the environment.

Specific listed hazardous wastes (industrial categories)

Characteristic wastes: when present in a waste, indicates that the waste poses a sufficient threat to merit regulation as hazardous Ignitability

Corrosivity

Reactivity

Toxicity

Examples of listed hazardous wastes:

Spent solvent wastes

Petroleum refining

Electroplating and other metal finishing wastes

Dioxin-bearing wastes

Chlorinated aliphatic hydrocarbons production

Wood preserving wastes

Petroleum refinery wastewater treatment sludges

Coking

EPA REGULATION OF HAZARDOUS WASTES

Regulations apply based on the amount of waste a facility generates per month

Very Small Quantity Generators (<100 kg/mo)

Small Quantity Generators (100 – 1000 kg/mo)

Large Quantity Generators (>1000 kg/mo)

Waste accumulation limits

Storage and handling requirements

Manifest requirements (shipping waste off-site)

Preparedness and prevention

Disposal rules

Waste minimization

Reporting

CHEMICAL SAFETY

TOXIC RELEASE INVENTORY (TRI)

Part of the Emergency Planning and Community Right-to-Know Program

Developed in response to Bhopal incident (1984 methyl isocyanate gas release at Union Carbide India Limited pesticide plant)

Tracks releases of certain toxic chemicals – subject by industry category

Annual reporting if subject

Data available to the public

Watch 1:35 EPA movie: https://www.epa.gov/toxics-release-inventory-tri-program/what-toxics-release-inventory

RISK MANAGEMENT PLAN (RMP)

Part of the 1990 Clean Air Act

Requires that facilities that produce extremely hazardous substances develop and report a risk management plan

Identifies chemical hazardous

Steps to take in case of an emergency

Identification of worst-case accidents and off-site modeling of consequences

What emergency response crews need to do

Prevention plan

Training and coordination with emergency response

QUESTIONS? Kat GallowayPresident

Bright Sky Environmental, LLC2121 Lohmans Crossing Road, Suite 504Lakeway, Texas 78734Phone: 281-217-8233Kat@BrightSkyENV.comwww.BrightSkyENV.com

Join the Clubhouse Group“Oil & Gas: Environmental Roundtable”

ADDITIONAL THOUGHTS IF WE HAVE TIME

WHAT IS ESG? ENVIRONMENTAL, SOCIAL, CORPORATE GOVERNANCE

Non-financial topics that have financial relevance to a company influences investing strategies and board decisions

Metrics that a company chooses (or potentially required) to report that are above-and-beyond environmental regulations

Will ESG reporting be mandatory in the US?

How companies:

Reduce emissions/pollution:

Energy use, waste, spills, natural resource conservation, decarbonization

Minimize environmental risk

Treat workers

Build trust in community

Manage supply chain

Read this: https://www.sec.gov/news/public-statement/coates-esg-disclosure-keeping-pace-031121

ENVIRONMENTAL HOT BUTTONS

Biden Administration climate change policies:

https://www.whitehouse.gov/briefing-room/statements-releases/2021/01/27/fact-sheet-president-biden-takes-executive-actions-to-tackle-the-climate-crisis-at-home-and-abroad-create-jobs-and-restore-scientific-integrity-across-federal-government/

Shifting definitions of “Waters of the US” with regards to Clean Water Act:

https://www.jdsupra.com/legalnews/another-new-era-wotus-rule-2020-update-16662/

Energy transition and energy poverty: Check out UT’s Scott Tinker Switch Energy Alliance

2 minute trailer https://switchon.org/films/switch-on/

PREPARING FOR YOUR CHEMICAL ENGINEERING CAREER

Congrats, you’re almost there! UT is an amazing school and you are equipped with the tools needed to enter intothe chemical engineering industry, pursue higher education, or whatever your next goal is!

Develop your own brand. You are a unique individual, and you must OWN your professional reputation bymaintaining a good brand. Critical:

Foundation of thorough technical skills and QA/QC

Flexibility – say “yes” to challenging projects and to projects that aren’t exactly what you thought you’d want to do after graduation

Communication – talk with your team about project progress, roadblocks, and timing concerns so that the team can move forward

Integrity – admit mistakes and do the right thing

Find mentors at every job

Pursue your FE/PE early on in your career. Life gets complicated as you get older.

Be an ambassador of engineering – get your horns up!