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6/18/2020
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EFO Air Quality Seminar
June 17, 2020
Jeremy Jewell and Kyle Dunn
► Jeremy Jewell• 20 years of air quality consulting experience
• BS Mechanical Engineering, Univ. of Arkansas
• Manager of Oklahoma Operations
• (918) 622-7111
• Chair of EFO’s Air Committee
Introductions
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► Kyle Dunn, PE• 9 years of air quality consulting experience
• BS Chemical Engineering, Univ. of Oklahoma
• Office Location: Tulsa, OK
• (918) 622-7111
Introductions
1. Storage Tanks
2. Engines / RICE
3. Accidental Air Release Reporting Rule
4. Regional Haze
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Storage Tanks► Changes to AP-42 Chapter 7
► Options for Calculating Tank Emissions
► Permitting & Compliance Implications
Background onTank Emissions
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► Fixed-roof tank• Fixed roof at the top of the shell; no floating roof• Vertical/Horizontal; Dome/Cone; Aboveground/Underground
► Internal floating-roof tank• Fixed roof and a light-duty floating roof
► External floating-roof tank• Open top (no fixed roof) but has a floating roof
► Covered (domed external) floating-roof tank• An external-type floating roof and a fixed roof
Types of Atmospheric Aboveground Storage Tanks
Fixed-Roof Tank
Fixed roof (shown ascolumn-supported)
Liquidsurface(nofloatingroof)
Breather ventopen or P/V type
Controlemissions by:- routing to acontrol deviceOR- installing afloating roof.
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Internal Floating-Roof Tank
Fixed roof (shown ascolumn-supported)
Floatingroof(showncutaway)
Open vents(peripheralcirculationvents)
Center vent
External Floating-Roof Tank
No fixed roof (tank is open top)
Floating roof(shown cutaway)
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Covered (Domed External)Floating-Roof Tank
Floatingroof(showncutaway)
Eave vents(peripheralventingtypicallyprovidedunder theeaves)
► Working (Fixed roof) • Vapor displacement during filling
► Breathing (Fixed roof)• Thermal expansion of vapor headspace
► Withdrawal (Floating roof)• Evaporation of clingage whenever emptying tank
► Standing (Floating roof)• Losses from tank seals/fittings/seams
Aboveground Tank Emissions
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Fixed-Roof TankWorking (Filling) Loss
Displaced vaporsflowing outof the vent
Incomingliquid
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Fixed-Roof TankStanding (Breathing) Loss
Heated gasesexpand, raisingthe pressurewithin thetank
Vapors flow outof the vent
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Floating-Roof TankWorking (Withdrawal) Loss
Evaporationfrom thewet shell
(i.e., from liquidleft behind onthe shell after
the liquid leveldrops)Outgoing
liquid
Rim seal(closure devicebetween thedeck and thetank shell)
Deckfittings
(only if theyopen through
the deck tothe liquid)
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Floating-Roof TankStanding Loss
Deckseams
(if bolted)
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► Flashing• Dissolved and/or entrained compounds released from liquid
during pressure decreases and temperature increases• Various methodologies to calculate• Most commonly found in upstream/midstream O&G• Can account for > 90% of total tank emissions
Aboveground Tank Emissions
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Flashing Lossatmospheric tank
Flash gasflowing outof the vent
Incomingliquid(under pressure prior to entering the tank)
Unstable components of the liquid vaporize and bubble out of solution
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Aboveground Tank Emissions
► Maintenance, Startup, & Shutdown (MSS)• Roof Landings• Tank Cleaning (Degassing &
Sludge Removal)• Abrasive Blasting & Painting• Shell Cleaning (Solvents &
Degreasers)• Temporary Control Devices
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Landing a Floating Roof
Vacuum breaker vent
Vapor spaceunder the
deck.
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Tank Cleanings
Fresh air is drawn in through the shell manway, picks up vapors, and is expelled
Multiple air changes each
hour, but retention time is
insufficient to achieve
saturation
Port for measuring concentration at inlet to air mover
AP-42 Changes
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► Volume I: Stationary Point & Area Sources
► Section 7.1 – Organic Liquid Storage Tanks
► Fifth Edition, Supplement D – September ’97• Routine Standing & Working Losses for Floating- and Fixed-Roof Tanks• 2006 Revision added Floating Roof Landing Losses
► July 2018 – Revisions Proposed• Including Tank Cleaning Losses
(methodology was published by API Nov. 2007)
► November 2019 – Revisions Finalized
► March 2020 – Additional Clarifications/Changes
AP-42 Compilation of Air Pollutant Emission Factors
Final AP-42 Chapter 7 Changes► Changed temperature, vapor density, and net
throughput equations
► Distinguished fully and partially insulated tanks
► Added distillate flushing method for landings/cleaning
► Revised roof landing calculation methods
► Added tank cleaning calculations
► Added flashing emissions description
► Included guidance for short-term periods
► Revised solar absorptance terms
► Revised default vapor pressures
► Updated meteorological data
► Various edits/clarifications/corrections
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► Coefficients to 1 significant figure rather than 2• Acknowledging uncertainty in the theoretical heat transfer model
behind the equations
► Use of consistent default tank height-to-diameter (H/D) ratio (0.5)• Defaults previously ranged from 0.45 to 2.0
► Differentiating by tank type• Accounting for insulation, floating roofs
► Using calculated vapor space temperature rather than using liquid surface temp as a surrogate
► Emphasis on using measured liquid bulk temperature rather than assuming equilibrium with ambient conditions
► Correcting some minor errors
Changes in the Temperature Equations
• Old equation:TLA = 0.44 TAA + 0.56 TB + 0.0079 α I
• New equation with new H/D default value:TLA = 0.4 TAA + 0.6 TB + 0.005 α I
• New equation with H/D as a variable:TLA = {0.5 – 0.8 / (4.4 Hs/D + 3.8)} TAA + {0.5 + 0.8 / (4.4 Hs/D + 3.8)} TB + [0.021 αRI + 0.013 (Hs/D) αSI] / (4.4 Hs/D + 3.8)
Fixed-Roof Tank Liquid Surface Temperature
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New equations for:• Fixed-roof tank (uninsulated):
TLA = 0.4 TAA + 0.6 TB + 0.005 α I• Internal floating-roof tank:
TLA = 0.3 TAA + 0.7 TB + 0.004 α I• External floating-roof tank (steel pontoon deck):
TLA = 0.7 TAA + 0.3 TB + 0.008 αRI• External floating-roof tank (double deck):
TLA = 0.3 TAA + 0.7 TB + 0.009 αRI
Fixed & Floating Roof Liquid Surface Temperature
► Added ‘average’ column to paint absorptance• “New, Average, Aged” rather than “Good, Poor”• Average: “Paint is in good condition, but the initial shine has faded”
Another Temperature Issue: Paint Condition / Solar Absorptance
Surface Color
Paint Condition
GoodNew Average
PoorAged
White 0.17 0.25 0.34Beige/Cream 0.35 0.42 0.49Light Gray 0.54 0.58 0.63
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Example – Fixed-Roof Tank
Tank Diameter (ft): 60
Tank Height (ft): 48
Tank Paint Color: White
Floating Roof Type: None
Product: Diesel
Throughput (bbl/yr): 600,000
Location: Port Arthur, TXAverage Annual Temperature
(deg F):68.44
Average Daily Insolation (Btu/ft2·day):
1443.85
Example – Fixed-Roof Tank (Average Ambient Conditions)
H/DPaint
ConditionAnnual Emissions (lbs) % diff
Old equations:
default good 879 n/a
New equations:
variable new 851 –3.1%
default new 847 –3.6%
default average 890 +1.2%
variable average 888 +1.1%
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Example – External Floating-Roof TankTank Diameter (ft): 150
Tank Height (ft): 48
Tank Paint Color: White
Floating Roof Type: Steel pontoon-type deck
Rim Seal Type:Mechanical-shoe seal with rim-mounted secondary
Product: Crude oil
Reid Vapor Pressure (psi): 7
Throughput (bbl/yr): 3,000,000
Location: Port Arthur, TX
Average Annual Temperature (deg F): 68.44
Average Daily Insolation (Btu/ft2·day): 1443.85
Average Wind Speed (mph): 9.64
Example – External Floating-Roof Tank (Average Ambient Conditions)
H/DPaint
ConditionAnnual Emissions (lbs) % diff
Old equations:
default good 3,019 n/a
New equations:
variable new 3,047 +1.0%
default new 3,045 +0.9%
default average 3,103 +2.8%
variable average 3,107 +2.9%
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► Use actual (measured) TB, rather than calculate from ambient► If roof is not insulated, breathing loss occurs:• Calculate TLA and ΔTV from TB and TA
► If fully insulated, TB = TL = TV
• If constant temperature, no breathing loss• If heating is cyclical, breathing occurs; calculate on the basis of
the range in bulk temperature and the frequency of the heating cycle
Guidance for Heated Tanks (Hot Stocks)
► Tank Cleaning Steps• Normal Pump out – Calculated as routine for fixed roof tanks or landing loss
for floating roof tanks• Standing Idle Losses - Calculated as routine for fixed roof tanks or standing
idle landing loss for floating roof tanks • Vapor Space Purge – Manholes open and fans, eductors, or blowers are
started. First air change is the vapor space purge from the tank• Continued Forced Ventilation - Manholes open and fans, eductors, or blowers
are operated• Remain Clean - Tank is Clean and Gas Free (No emissions)• Refilling - Calculated as routine for fixed roof tanks or landing loss for
floating roof tanks
Tank Cleaning
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Calculation Methodologies
► Custom Software Packages (e.g., TankESP or E&P Tank)
► Process Simulators
► Custom Excel- or Access-based Solutions
► Direct Measurement
► Flashing Emissions Methodologies (not affected by AP-42 changes)
► TANKS4.09d
How Can I Calculate My Emissions Now?
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► Final revisions to AP-42 have rendered TANKS 4.09D completely out-of-date
► TANKS 4.09D already had various issues with properly applying the methods of the 2006 revision of AP-42 Chapter 7.1• Monthly emissions estimates are incorrect• Modeling of insulated tanks• Modeling of stock temperature warmer than ambient in uninsulated tanks• Determination of true vapor pressure for temperatures greater than 100 F
► U.S. EPA has acknowledged this for years with warnings on their website
TANKS 4.09D is No Longer Valid
► Tank Emissions Software Program► Built in VBA for MS Access, but packaged as a Runtime application, so MS
Access is not required► Calculates all tank emissions► Pros• Designed to address all TANKS4.0 issues• Developed by Rob Ferry (assisted with developing/modifying AP-42)• Calculates short-term emissions
► Cons• Not easily customizable• Must purchase license
► Ideal for large terminals & refineries
TankESP
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► Software package developed by API
► Calculates working, breathing, & flashing
► Pros• Option to use HP liquid, LP liquid, LP gas, and Geographic Database
(not always allowed)• Easy-to-use interface
► Cons• Does not calculate floating roof emissions• Licenses no longer sold by API• Not updated with recent AP-42 changes
► Ideal for upstream O&G
E&P Tank
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► PROMAX, HYSIS, WINSIM, PROSIM, etc.
► Mainly used to calculate flashing, but some calculate working/breathing as well
► Pros• Large database of chemicals & equations of state• Able to handle wide range of conditions• Customer service & frequent updates
► Cons• Does not calculate floating roof emissions• Can require significant training to use correctly• Must purchase license
► Ideal for complex scenarios & optimization
Process Simulators
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► Calculates all tank emissions
► Pros• Customizable for a specific site to include AP-42, MSS, and flash method of
choice, as applicable • Generally most efficient option, especially if used for both permitting and
ongoing compliance• Generally most cost-effective option but depends on level of customization• Free options available for simple fixed-roof tanks
► Cons• Can require significant expertise to create/use• Needs to be structured for easy interpretation by permit writers
► Ideal for single facilities with fixed-roof tanks or companies with multiple similar sites
Customized Excel Workbook or Access Database
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► Can be used to determine all tank emissions (but not with one test) ► Pros• More accurate than simulation/equation• Can generate a tank emission factor for all representative sites in a region
► Cons• Only provides a snapshot of emissions – use representative conditions &
safety factor• Generally only used for flashing emissions and testing methods usually
require prior approval• Costs vary depending on how many site-specific or representative samples
are needed► Ideal for refined analysis & companies with multiple tanks storing same
representative stock
Direct Measurement
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► Vasquez-Beggs (most widely used), EC/R Method, Valko-McCain, Griswold & Ambler
► Pros• Simple equations• No cost (ODEQ has template for Vasquez-Beggs)
► Cons• Limited range for process inputs• Can significantly overestimate or underestimate emissions• Does not calculate working/breathing emissions
► Ideal for rough/quick estimates or tanks with low throughputs
Correlation Equations for Flashing Emissions
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► Gas-oil ratio determined from pressurized sample upstream of tank
► Only calculates flashing emissions
► Pros• More accurate than simulation/equation• A flashing emission factor can be created for all representative sites in a region• Simplest equation
► Cons• Difficulty/errors during sampling process• Does not calculate working/breathing emissions• Costs vary depending on how many site-specific or representative samples are
needed
► Ideal for refined analysis & companies with multiple tanks storing same representative stock
GOR Analysis
Refining Flash Emissions
Permission provided by BRE
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Most Commonly Asked Questions
► Short-term emissions
► Heated tanks
► Produced water tanks
► H2S emissions
► Potential throughput
► RVP/TVP determinations
► Tanks filled in parallel*
► Vapor recovery towers*
► Calculations based on representative sites*
Permitting & Compliance Implications
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Recent ODEQ Guidance for AP-42 Changes► EPA stated that State agencies have ultimate authority in
determining how the changes will be implemented► DEQ: Permit applications and any compliance demonstrations are
expected to begin using the new methodologies as of 4/9/20► You may need to modify your permit or follow proper disclosure
procedures if the revised emissions cause an exceedance• Unresolved contradiction with previous guidance related to AP-42
changes: “If a changed emission factor increases predicted emissions, it is generally the DEQ's responsibility to initiate a permit modification”
► DEQ does not plan to actively seek any enforcement actions at this time. If you have a potential permit exceedance, they encourage you to reach out to compliance & enforcement to discuss the best option moving forward.
Recent ODEQ Guidance for AP-42 Changes► Tank Cleanings• Oklahoma is in attainment and these are infrequent maintenance
emissions; therefore, ODEQ does not plan to require any company to permit these emissions• Compare emissions against existing limits and modification thresholds
► DEQ TANK Tool• DEQ is working on a simple tank tool that can be used for fixed-roof
tanks storing certain materials
► Flashing Emissions• AP-42 changes didn’t finalize any methodologies for flashing
emissions; therefore continue to utilize existing ODEQ guidance• https://www.deq.ok.gov/wp-content/uploads/air-
division/PG_VOC_Emissions_Flashing_Losses.pdf
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► NSPS K/Ka/Kb – VOL Tanks
► NSPS UU – Asphalt Tanks
► NSPS OOOO/OOOOa – O&G Tanks
► NESHAP G – SOCMI Tanks
► NESHAP R – Gasoline Tanks
► NESHAP CC – Refineries
► NESHAP EEEE – Organic Liquids Tanks
► NESHAP 6B/6C – Gasoline Tanks
► …and others
Don’t Forget NSPS/NESHAP
Engines / RICE► Most recent questions
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First, One Slide on Regional Haze
► 4FA request letters going out this/next week
► 4FAs to be due in August or early September
Is it okay to continue operating this engine?
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► Yes, emergency engines > 560 bkWare still at Tier 2
Can I stillbuy a Tier 2 engine?
► No► Certification standards are averages across a families of engines► Within one family, all engines are certified to the most stringent
standards even if some engines are in a different power range► The test methods for certifications are not EPA Reference Methods► Tier standards for CO for small engines are very large► Alternatives include:• AP-42 (just as bad) and other published factors, e.g., Ventura County• NTE values for diesel engines• Direct sampling• Vendor data
Should Tier/Certification standards be used for PTE calculations?
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Are reconstruction costs aggregated?No, Consider Each Overhaul Independently Yes, Aggregate
ADI A064 (9/24/1981)“Single Planning Decision”
ADI PS41 (12/28/1992)“When the extent of repairs goes beyond the normal maintenance activity necessary to maintain a boiler’s useful life, resulting in a substantial life extension…”
ADI NR69 (10/9/1990)“Single Planning Decision”
40 CFR Part 60 Subpart VVa (11/16/2007) “two years”
ADI NR64 (7/11/1990)“Single Planning Decision”
40 CFR Part 60 Subpart Ja (6/24/2008)“two years”
EPA-453/R-02-005 (11/2002)“…reconstruction project …may occur over some period of time. When these…projects are
intended to be part of a continuous plan…, then they would have to be aggregated…”
Implementation Q&A Document for NESHAP/NSPS for RICE/ICE (4/2/2013)“case-by-case”
► No► 63.6603(f): “An existing non-emergency SI 4SLB and 4SRB
stationary RICE with a site rating of more than 500 HP located at area sources of HAP must meet the definition of remote stationary RICE in § 63.6675 on the initial compliance date for the engine, October 19, 2013, in order to be considered a remote stationary RICE under this subpart.”
► But what about clearly remote engine/site that changed ownership after 2013?• Get the former owner’s remote documentation!
► And what about a remote engine that moves to a new remote location?
Can I still designate an engine as remote?
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► As the rule is written…no► …and no explicit guidance has been provided by EPA to date► However, most relocations involve a change in fuel composition
(e.g. field gas variations for upstream O&G sites), which will have an impact on emissions
► Many permitted sites in Oklahoma already require NOX & CO testing
► Pick an approach, keep records of justification, and be consistent
Do I have to redo the initial stack testing for my non-certified* JJJJ engine?
* Either non-certified from the manufacturer or operated in a manner that voids the certification.
► Yes, but…► Not with emergency engines (federal definition)• Allowances for demand response contracts have been vacated
► You can operate non-emergency engines whenever you want• Emergency demand response• Non-emergency demand response• Peak shaving
Can I participate in a demand response program?
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► Regulatory answer:• Usually 90 % of max
rated load
► Practically…be careful:
What load is required for testing?
► Yes, there are numerous examples. Here is one:► Old 2SLB natural gas engine at transmission station in PA► Pre-project NOX emission rate = 11 g/bhp-hr at max load► PA RACT = “clean burn” technology• “Clean burn” generally refers to various combustion efficiency solutions
designed to reduce NOX by enabling engine operation at higher A/F ratios (i.e., leaner burn)
► Installed a turbocharger, intercooler, new valve system to improve mixing in cylinders, high energy ignition technology, and ignition controls
► Current NOX emission rate = 3 g/bhp-hr at max load► Note: watch out for CO and VOC increases!
Can NOX emissions be reduced for a LB engine?
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► Yes► …but really?► This should be removed from
the site when the temporary (< 12 months) need is ended• Then it can be called a
nonroad engine, not subject to the federal subparts
Should this engine be permitted?
► Maintenance has rented an engine for emergency/backup use because the owned engine is unreliable• In fact, they’ve rented several engines now• And the owned engine is still used during rental swap-outs
► Yes, the “temporary” rental units need to be permitted• The location and purpose is stationary/consistent regardless of
the number of engines used• Need pedigrees for all possible rental units; permit the worst
one
What about temporary rental engines?
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New Accidental Air Releases Reporting Rule
► www.csb.gov► Established by the 1990 CAA► Began operations in Jan. 1998► “Congress directed that the CSB’s
investigative function be completely independent of the rulemaking, inspection, and enforcement authorities of EPA and OSHA”
► “A key function of the CSB is to make recommendations to the EPA about improving the rules designed to prevent chemical accidents.”
Chemical Safety and Hazard Investigation Board
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► Stated purpose: “to ensure that the CSB receives rapid, accurate reports of any accidental release that meets established statutory criteria”
► Central requirement: “owners and operators of stationary sources to report accidental releases that result in a fatality, a serious injury, or substantial property damage”
CSB Accidental Air Release Reporting (AARR) Rule
► Accidental Release - “unanticipatedemission of a regulated substance or other extremely hazardous substance into the ambient air from a stationary source”
► Regulated substance - “any substance listed pursuant to the authority of 40 U.S.C. 7412(r)(3)”
► Extremely hazardous substances - “any substance which may cause death, serious injury, or substantial property damage, including but not limited to, any “regulated substance” at or below any threshold quantity set by the EPA Administrator under 42 U.S.C. 7412(r)(5)”
Definitions (1 of 2)
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► Ambient Air - “any portion of the atmosphere inside or outside a stationary source”
► Stationary source - “any buildings, structures, equipment, installations or substance-emitting stationary activities which [a] belong to the same industrial group, [b] are located on…contiguous properties, [c] are under…common control…”
► Serious Injury - “injury or illness that results in death or inpatient hospitalization”
► Inpatient hospitalization - “formal admission to the inpatient service”
► Substantial property damage - “estimated property damage at or outside the stationary source equal to or greater than $1 million”
► Property damage - “damage to or the destruction of tangible public or private property, including loss of use of that property”• A facility’s loss of revenue from downtime due
to the accidental release is part of the property damage calculation
Definitions (2 of 2)
► Within 8 hours of the accidental release, send an e-mail to [email protected] or call 202-261-7600
► Else, if reported to National Response Center (NRC) pursuant to 40 CFR 302.6, then e-mail or call CSB with the NRC identification number within 30 minutes of the NRC reporting
► Update/correct the initial report within 30 days• Or 90 days if updating was not
possible within 30 days
Report Timing
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► Name and contact info.
► Location information and facility identifier
► Approximate time and brief description of the accidental release
► Indication whether fire, explosion, death, serious injury, and/or property damage has occurred
► Name, CAS #, or identifier of the material(s) involved in the accidental release
► If known, the amount of the release, the number of fatalities, and the number of serious injuries
► Estimated property damage at or outside the stationary source
► Whether the accidental release has resulted in an evacuation order impacting members of the general public and others• The number of persons evacuated;• Approximate radius of the evacuation zone; and• The type of persons subject to the evacuation order
(i.e., employees, general public, or both)
Report Content
► EPA will enforce against failures to self report• Administrative orders• Civil action• Criminal action
► One-year grace period for facilities that report immediately after being notified of the requirement
► Reports will not be published but are available via FOIA
Enforcement
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► CSB is considering issuing guidance on a variety of topics, including:
► Whether an explosion is an “accidental release”► Whether serious injuries that result from an
intentional release (e.g., an approved and controlled discharge) are reportable; and
► Clarification of the definition of “extremely hazardous substances”• However: “The hazard investigation function of the CSB includes identifying
new, previously unknown hazards, even those caused by substances not yet discovered or in widespread use. A narrow definition of ‘extremely hazardous substance’ based on previously established lists or narrow criteria would completely frustrate a key objective of the statute.”
CSB AARR Forthcoming Guidance
Questions / Comments
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CONTACT US
Jeremy JewellPrincipal [email protected]
918.622.7111 x1
Visit us at TrinityConsultants.com
Kyle Dunn, PEManaging [email protected]
918.622.7111 x3
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