Cover Story

Parti

Recent Air Regulations:

Impact on Turnaround Vapor
Deinventory Strategies
With the onset of new environmental regulations, turnaround teams must look to
temporary vapor-control strategies to ensure compliance during non-routine operations

T
urnarounds are one of the I Paul Anderson
most anticipated and time­ and
intensive events in a plant’s Chris Longo
cycle, and are an essential GEM Mobile
part of continuous operations in the Treatment Services
petroleum refining and petrochemi­
cal industries. A turnaround is a
scheduled event wherein an entire IN BRIEF
process unit in a refinery or manu­ TURNAROUND UNIT
facturing site is taken offline for an DEINVENTORY
extended period of time to perform TEMPORARY VAPOR-
maintenance, modifications, inspec­ *1*1 CONTROL PROCESSES
tions, catalyst regeneration or chan- ]
CHEMICAL CLEANING
geouts, as well as any related proj- FIGURE 1. Turnarounds are a challenging- but critical- part of any
ectS (Figure 1) Turnarounds provide process unit's lifecycle, because they provide a window PLANNING,ol opportunity
DESIGN AND
■ , . .. to perform maintenance and other Fimportant tasks
an important window of opportunity COMPLIANCE
for essential maintenance tasks and allow efficiently. Temporary vapor-control systems
for safe and efficient servicing or replace- can provide solutions to meet some of these
ment of process equipment. If done cor- regulatory challenges during non-routine
rectly, turnarounds can potentially lead to events like turnarounds,
huge gains in the facility’s productivity and
output. However, turnarounds are also Turnaround unit deinventory
extremely costly events in terms of direct One important part of the turnaround pro­
costs for labor, tools, heavy equipment and cess is the unit deinventory phase. Unit dein­
materials used to execute these projects, ventory begins when feed is cut to the unit.
If the budget balloons or the timeline un- Liquids and vapors are removed from the
expectedly expands, it can have disastrous unit using a variety of transfer methods, in­
effects on a company’s bottom line. eluding liquid pumping, pressuring off, inert-
Petroleum refinery turnarounds are becom­ gas purging, steaming and chemical circula­
ing more difficult and increasingly expensive. tion or injection.
New environmental regulations present po­ After deinventory is complete, the unit ei­
tential challenges in turnaround performancether undergoes chemical cleaning or purg­
by adding complexity, extending completioning to bring the unit’s vapor concentration
times and incurring additional costs. While fa­ to the minimum level dictated by safety and
cilities may be fully in compliance with theseenvironmental requirements. Once these ac­
regulations during normal operations, it maytivities are complete, the unit is safe to open
be difficult to meet these rigorous standardsto atmosphere and equipment, components
during non-routine activities, including turn­ and catalysts can be removed for further
arounds and the associated unit shutdown cleaning, inspection, repair and replacement
and startup. Operators and contractors are as needed.
constantly challenged with how to complete Numerous facility turnarounds are being
turnaround tasks quickly, safely and more impacted by environmental restrictions

CHEMICAL ENGINEERING WWW.CHEMENGONLINE.COM DECEMBER 2018 33

 FIGURE 2. New emissions reg­ Liiii t'llL JjJT
ulations are causing operators
to seek alternatives to flaring
during turnarounds
¥
I

t
'n
A
FIGURE 3. Portable vapor combustion systems can provide
an effective solution for environmental compliance during
turnarounds

Source Performance Standards 40 CFR 60

Subparts J/JA and Refinery Sector Rules
related to the National Emission Standards
for Hazardous Air Pollutants (NESHAP
MACT CC and MACT UU), have imposed
emissions limits and necessitated monitor­
ing and reporting tasks that make flaring
a less desirable option (Figure 2). Several
examples of the impact of Refinery Sector
Rules on refinery units are described in Table
driven by the evolution of new federal stan­ 1. In response, operators of facilities have
dards from the U.S. Environmental Protec­ increasingly looked to recapture vapors dur­
tion Agency (EPA; Washington D.C.; www. ing maintenance periods through the use of
epa.gov) under the umbrella of Mainte­ flare-gas recovery units (FGRUs).
nance Startup and Shutdown (MSS) regu­ In FGRUs, liquids and gases are recovered
lations and Refinery Sector Rules. These the majority of the time. After recovery, they
changes create the potential for bottlenecksare cleaned and utilized as fuel gas in facil­
and potential delays during the turnaround ity heaters and various other facility process
deinventory process. units. Under normal operating conditions,
In the past, refineries were granted much essentially all gases that are produced are
greater flexibility to vent emissions dur­ routed to the refinery fuel-gas system, al­
ing turnarounds. A common approach for lowing them to be used for combustion in
many states was to allow turnaround vapor refinery heaters and boilers. Typical refinery
deinventory activities to vent emissions fuel-gas systems are configured so that the
to the atmosphere or flares. Venting could fuel-gas header pressure is maintained by
occur during depressurizing a unit, steam­ adding excess natural gas to meet the net
ing or purging process equipment or chemi­fuel requirement. This provides a simple way
cal cleaning using steam or chemicals. The to keep the system in balance, so long as
recent implementation of Refinery Sector fuel gas needs exceed the volume of gas­
Rules has made turnaround flaring an in­ eous products produced. Flaring often oc­
creasingly uphill battle. curs during unit startups and shutdowns or
Changes to EPA regulations, such as New when pieces of equipment associated with a
unit are taken out of service.
TABLE 1. SELECTED REFINERY SECTOR RULES’ IMPACT ON PROCESS UNITS For safety and environmental reasons,
Process unit Refinery Sector Rule impact equipment maintenance results in the need to
Delayed coker Atmospheric venting requirement drops from 5 to 2 psig remove source hydrocarbons from process
(MACT CC) equipment and associated piping before
Catalytic reformer 5 psig exemption removed. Active purging vents must now opening.
be Typical decommissioning proce­
(MACT UUU) routed to an emissions-control system dures include multiple steps of depressuring,
Sulfur recovery nitrogen, gas, or steam purging or chemical
For affected sulfur recovery units (SRUs), purge gas during
(MACT UUU) injection. During these steps, the quality of
startup and shutdown must now be sent to flare or incinerator
Must comply with Hazardous Air Pollutant (HAP) emissions
Fluid catalytic cracking unit thepre­
fuel gas is degraded and at times cannot
(MACT UUU) viously exempt during periods of startup and shutdown be recovered.
Distributed equipment FGRUs are also limited due to their inability
During startup and shutdown, prevent release of vapors until
(Pressure release devices) process fluids are removed and lower explosive limit (LEL) is
to accept or process certain vapor streams
(MACT CC) brought below 10% in a timely fashion. For example, nitrogen,
34 CHEMICAL ENGINEERING WWW.CHEMENGONLINE.COM DECEMBER 2018
steam and hydrogen sulfide (H2S) all pres­ FIGURE 4. Portable liquid H2S
-o scrubbers can be employed
ent unique obstacles to the FGRU that can during turnarounds to remove
slow down or overwhelm its capabilities. A 1
summary of these impacts on FGRUs and
*
M
i toxic acid gases that pose
environmental issues
flares is given in Table 2.
As a result, refineries have begun identify­
ing and addressing turnaround maintenance
activities that may lead to problematic pro­ - i
£
cess streams being sent to the FGRU. Ad­ ■
dressing these activities through the use
of alternative vapor-control devices has
allowed many facilities to recover lost time designed specifically for periods of startup
and return the team to its “pre-regulatory” and shutdown.
turnaround schedules. Effective vapor-control strategies em­
The curtailing of flare emissions by the ployed during shutdowns include flare­
ERA will have a broad range of practical less shutdown capability, hydrocarbon
implications on industry, but of particular pre-treatment or eliminating the flare sys­
concern will be the use of vapor-control tems as primary destruction sources.
equipment (FGRU and flares) during these Additional benefits include continuous
periods of startup and shutdown. Some re­ environmental compliance involving moni­
strictions placed on flares, such as requiringtoring, data recording and final compliance
minimum operating temperatures, specific reporting documentation.
component concentration or mass limita­ These vapor-control strategies are being
tions and removal efficiencies, will often successfully integrated into turnaround
be difficult or impossible to achieve during planning and serve as best practices for fa­
these interim periods. Avoiding penalties cilities recently challenged with meeting new
during these spans may require facilities to environmental regulations associated with
utilize temporary vapor-control equipment turnaround activities.

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 Issue Impact
TABLE 2. IMPACTS E
FLARE-GAS RECOVERY UNITS AND FLARES
Solution Benefits

High gas volumes Deinventory delays, compressor issues Thermal vapor combustion Improved fuel gas quality and reduced flare load

Nitrogen concentrations Negative heating impact, compliance with NSPS J/JAThermal vapor combustion Improved fuel gas quality and reduced flare load
(Continuous emissions monitoring systems; CEMS)
H2S concentrations S02 compliance deviations, possible CEMS violation Caustic scrubbing prior to Environmental regulatory compliance
thermal combustion

Steam volume and Compressor issues, limited reliability and Heat exchanger and conden- Improved reliability and predictable decontamina-
temperature performance sate-collection system tion schedule

Temporary vapor-control processes pounds (VOCs) using an enclosed vapor

Newly emerging regulatory requirements combustion unit (VCU), which produces
brought about a need for a comprehen­exhaust gases that are primarily carbon
sive approach to develop environmentaldioxide and water (Figure 3). The VCU
vapor-control strategies. Processes for is equipped with various automated
vapor and liquids removal and chemicalsafety devices, flow and combustion
cleaning are being integrated into the temperature transmitters and monitor­
operational shutdown procedures to ing systems designed to handle a wide
mitigate safety risks, eliminate environ­ range of vapor concentrations and flow-
mental bottlenecks, shorten the shut­ rates. Due to the transient nature of unit
down sequence and increase schedule vapor deinventory, manned operation
reliability, all while meeting environmen­of the VCUs is required. In many cases,
tal regulatory requirements. the vapor destruction in such units
Facilities must strive for vapor- is greater than 99.9% and provides
control processes that mitigate prob­ regulatory compliance with refinery
lematic process variables and com­ emission standards.
pounds that exist during the shutdown Liquid scrubbing. This process can
and cleaning processes prior to in­ be used to remove toxic acid gases,
troduction into a facility’s FGRU or such as H2S, hydrofluoric acid (HF) and
flare system. ammonia (NH3), which would present
Temporary unit deinventory vapor- safety and air-emissions compliance
control processes include: thermal issues if released directly to the atmo­
vapor destruction, liquid scrubbing, car­sphere or thermally combusted, pro­
bon adsorption, heat exchanger coolingducing acid gases such as SOx, HF
and condensing, condensate removal, or NOx. Liquid scrubbing provides a
as well as pressure and temperature mechanism wherein vapor contacts a
control. These temporary vapor-con­ liquid caustic or other chemical solution
trol processes are described in the and undergoes a chemical reaction in
following sections. which the acid gases are removed from
Thermal vapor combustion. This the vapor stream and converted into
method involves processing hydrocar­ less toxic salts or other compounds that
bon vapors or volatile organic com­ remain. Post-scrubbing acid-gas vapor
Cooling water
source >
Coofcng water
Process < source
Condensate
Vapors
> ESD control .
Pressure regulators vaiye
c Heat exchanger
I
)
Knockout
vessel

Liquid condensate
storage >
&

HXH
Packed scrubber
tower
o
Vapor combustion
unit
a
.< Suppk me ital
fi el

FIGURE 5. This process flow

diagram shows a typical layout of
Vapor combustion
several vapor-control systems in Saubfrnq unit
o
a refinery turnaround solution >
36 CHEMICAL ENGINEERING VWVW.CHEMENGONLINE.COM DECEMBER 2018
concentrations of less than 10 parts per mil­ rs5»i
n
lion (ppm) are achievable under proper op­ -.
erating conditions. Figure 4 shows portable
liquid H2S scrubbing equipment. Liquid
scrubbing can also remove hydrocarbons or
*
VOCs from vapors using liquid solvents or 1;
chemistry in certain applications.
Heat exchanger cooling and condensa­
tion. Cooling and condensation in heat ex­ ’ it.

changers are also important processes dur­

ing unit vapor deinventory. In some cases,
elevated temperatures or steam may exist
in the vapor stream, usually during the unit
hydrocarbon clearing and chemical clean­
ing phases. Vapor temperatures as high as
400°F can be encountered during reactor
purging. These conditions can cause prob­
lems for FGRUs and vapor processing sys­ sures, which are typically less than 10 psi. figure 6. Even if facilities are
in full compliance (luring nor­
tems. To mitigate these issues, the vapor is With unit pressures as high as 300 psi, pres­
mal operations, non-regular
cooled to temperatures below 150°F using sure reduction using regulators and controltasks like turnarounds may
shell-and-tube heat exchangers, and any re­valves becomes an essential part of the necessitate additional, tempo-
sultant condensable hydrocarbon or steam overall vapor-control system operation and rary vapor-controi schemes to
is collected and removed to storage. process design. meet new emissions-control
regulations
Controlling pressure. Pressure control of A typical process flow diagram and refin­
the vapor stream during the deinventory ery site layout for these equipment and com­
phase is of critical importance when vari­ ponents is shown in Figure 5. Figures 6 and
able unit pressures need to be managed to 7 illustrate temporary vapor-control systems
ensure proper vapor-control system pres- installed into units undergoing turnarounds.

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CHEMICAL ENGINEERING WWW.CHEMENGONLINE.COM DECEMBER 2018 37

 FIGURE 7. Mobile vapor-control systems The engagement of multiple facil­
are an effective way to ensure environ­
mental compliance during non-routine ity departments and contractors under
operations, including shutdowns one emissions-management process
and startups allows for streamlined communication
and compliance execution during mul­
i tiple phases of the turnaround. This
‘.*1
enhances safety and operational per­
formance, schedule reliability, cost ac­

r ", countability and regulatory compliance

for the vapor-control activities.
In summary, many refineries are being
faced with challenges in performing unit
These vapor-control processes can be shutdowns and startups under newly
integrated into the facility shutdown planenacted regulatory requirements In
and regulatory compliance program. many cases, the unit shutdown is being
performed for the first time under new
Chemical cleaning regulations and no historical process
Another critical challenge of the turn­ or procedures are available to follow.
around deinventory process is posed Updated timelines and budgets incor­
by process-unit liquids deinventory and porating these new requirements must
chemical cleaning. Chemical cleaning isbe prepared.
a critical part of unit decontamination — Early engagement of refinery opera­
it is required in order for the unit to be tions, environmental, maintenance and
opened to the atmosphere and compo­ planning personnel, along with experi­
nents to be removed for further cleaningenced refinery turnaround vapor-control
and repair. It accelerates the unit vapor-contractors, is of critical importance in
control completion timeline by removingestablishing a predictable deinventory
sources of hydrocarbons inside the unit,timeframe and budget. The unit dein­
allowing vapor concentrations to be re­ ventory phase sets the pace for the
duced to safe levels more rapidly. maintenance portion of the turnaround,
These processes also pose vapor- and incremental time and cost savings
control challenges due to the potential on the front-end can help with the overall
to emit hydrocarbons, and therefore turnaround performance. ■
must be included into the vapor-con­ Edited by Mary Page Bailey
trol strategy. This involves coordinated
vapor-control planning and execution Authors
with the facility, as well as the chemical Paul Anderson is group president of
cleaning contractor. GEM Mobile Treatment Services. Inc­
T an Evergreen North America Industrial
Sen/ices company (1196 E. Willow
Planning, design and compliance Street. Signal Hill. CA 90755; Phone:
A collaborative vapor-control approach 562-436-2999; Email: paul.anderson®
gem-mobile.com). Anderson founded
used to develop the best strategy may GEM Mobile Treatment Services in
include the following activities: 1994, and the company was integrated
• Proper engagement of refinery opera­Services in 2015.into Evergreen North America Industrial
Anderson has over 25 years of experience
tions, environmental and maintenancein mobile vapor control and wastewater treatment, and has
teams with relevant third-party vapor- designed and operated turnaround vapor-control and waste­
water-treatment processes for numerous turnarounds. He
control and chemical-cleaning providershas been involved with numerous refinery planning. MOC.
• Evaluation of the turnaround unit- PHA and other relevant engineering and safely process ses­
deinventory project scope sions related to process unit deinventory. Anderson holds a
B.S.Ch.E. from Oregon State University.
• Development of a detailed schedule
Chris longo is a corporate regulatory
and timeline compliance manager at GEM Mobile
• Preparation of written procedures, Treatment Services Inc., an Evergreen
process flow diagrams (PFDs), piping North America Industrial Services com­
■a
pany (Same address as above;
and instrumentation diagrams (P&IDs) cnris.longo@gem-mobile.com). Longo
and contingency plans has over 10 years of experience in cor­
• Involvement in the management of porate environmental regulatory com­
pliance, including federal, state and
change (MOC) and process hazard local air-permit management, federal
analysis (PHA) processes and state regulatory rules oversight and interpretation and
regulatory agency and customer compliance interface. He
• Assessment of regulatory compliance holds a B.A. in geography and environmental studies from
permitting, monitoring and reporting California State University Long Beach.
38 CHEMICAL ENGINEERING WWW.CHEMENGONLINE.COM DECEMBER 2018