Modified Ethanol Emission Report

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TRINIDAD BULK TRADERS LIMITED

ETHANOL EMISSION TESTING REPORT

FIELD TESTING CARRIED OUT BY: DARLENE K OONJAL & DEVI RAMBARAN REPORT PREPARED BY: DARLENE K OONJAL & DEVI RAMBARAN



TABLE OF CONTENTS

Air quality 2

-emission survey

-emission measurements

The purpose of ethanol emission testing

5

Sampling points for emission testing

7

Results 8

Conclusions

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AIR QUALITY CONTROL

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Air quality control needs vary from small areas such as industrial parks

influenced by more than one emission sources, to those from large

areas, such as an urban area. Air pollution refers to the presence in the

atmosphere of one or more contaminants in quantities/and or

characteristics that will, over a period be injurious to or unreasonably

interfere with public health and welfare or natural environmental

processes. Contaminants may be categorized as particulate matter

and gases and their associated forms, including dust, smoke, fumes,

mist and vapour.

Generally, sources of air contaminants may be classified as

• stationary,

• mobile or

• fugitive (in which T.B.T.L’s ethanol emission would be

categorised).

They may be attributed to point sources, such as industrial stack

emissions; transportation activities, and uncontrolled sources

(fugitive). A substance is not normally identified as an air contaminant

until its presence and concentration contribute to a deleterious effect.

Air contaminants originate in a wide variety of chemical compositions

and different physical states and are emitted from a diversity of

sources.

CHARACTERIZATION

The characterization of an emission stream begins with a survey of

facility operations and determination of emission locations. The

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emissions must be quantified through a sampling and measurement

program and in some cases ambient air monitoring may be required or

desirable.

EMISSION SURVEY

The first step in characterizing air pollution from an industrial facility is

the emission survey, which locates sources and defines quantities for

all air contaminants.

Source Identification:

The identification of emission sources begins with a review of process

flow sheets and associated data. With the design drawings at hand, an

inspection of the plant may be done to verify available records and

provide input. Design drawings were referred to relating to the plant

structure as well as Tank Farm to properly indicate where specific

pipes and valves were located in relation to the transport and storage

of the ethanol product. This enabled us to locate ideal testing

locations.

Emission Quantification--Compliance Program: Source testing is

required to define needs to achieve compliance, (Draft Air Pollutions

Rules, as well as OSHA) to demonstrate effectiveness of new control

techniques, or to provide records of continuing compliance based on

quantitative field results from individual sources.

THE APPLICATION OF EMISSION MEASUREMENTS

Measurement of plant emissions provides a database for determination

of needs for

new control equipment

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effectiveness of existing control equipment

compliance with emission regulations and/or permit

requirements

losses of products or by-products via the emission

THE PURPOSE OF ETHANOL EMISSION TESTING

Fugitive emissions may be sufficient to cause violations of ambient airquality standards even after implementation of source controls.

Fugitive chemical emissions as a gas or as liquid emitting gas may

occur as an uncontrolled release from an industrial process, and

similar control approaches to those used for particulates may apply.

Fugitive emissions may also occur from leaking equipment. The

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pollutants of most concern are volatile organic compounds. A problem

arises when the number of relatively small sources from equipment

leaks and other non-process sources accumulate to an undesirable

level. Typical sources include leaks from:

• Valves

• Pumps

• Compressors

• Pressure-relief valves

• Sampling connections

•

Open-ended lines• Flanges

Emission control of these equipment-related sources is unit specific.

Valves: With the exception of check and relief valves, a stem is used

to operate an industrial process valve. A source of a fugitive gas

emission comes from a failure of the stem to be adequately sealed.

The failure may be caused by improper installation, deterioration

overtime, and/or wear from use.

Pumps: the typical fugitive gas emissions from pumps occur because

of sealant failure.

Sampling connections: Since purging of sampling lines is a source of

fugitive emissions, closed-purge sampling systems should be used.

Particularly in the chemical process industry, a plant may have many

open-ended valves and lines to drain, purge or vent a process fluid.

Open-ended lines: particularly in the chemical process industry, a

plant may have open-ended valves and lines to drain, purge or vent a

process fluid.

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The emission monitoring has been implemented to ensure that

releases do not adversely affect the health of the workers at T.B.T.L’s

plant. The majority of the monitoring would be done at ground level to

determine the effect it would have on the workers. This ensures that

the OSHA requirements have been met and continuously monitored as

well as keeping with the environmental standards proposed by the

local environmental body, the Environmental Management Authority

(EMA).

SAMPLING POINTS FOR EMISSION TESTING

There are several points on T.B.T.L’s plant and in Tank Farm that

requires monitoring in order to detect leaks and faulty equipment. The

following sites have been identified as the preferred sampling points.

Also indicated are the sampling times.

1. Tank Farm-Tank 20 when there is loading and lifting of

product.

2. Tank Farm-All Tanks (20, 70, 42, 43) when they are inactive.

3. Tank Farm-Tanks 70, 42 and 43 when there are loading and

lifting of feedstock.

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4. Shift Tanks located on T.B.T.L’s plant- when there is product

lifting and no activity.

5. Pump House- at the 16” Line when there is loading and no

activity.

NOTE: Measurements at Tank Farm would include one sample

done at the base of the tank near the main valve and at the

top of the tank near the Dip port.

The above sampling points have been chosen since these are key

areas where there would be the transfer and storage of ethanol. There

would be T.BT.L personnel as well as contractual workers interacting in

some of these areas on a daily basis, for instance the Shift Tanks and

as such, the sampling points reflect where there may be the most

exposure to ethanol fumes.

RESULTS OF ETHANOL EMISSION TESTING

Table 1.0 indicates the Results for the first round of Ethanol Emission

tests carried out at T.B.T.L’s plant and associated infrastructure(s).

CONCENTRATION OF ETHANOL EMISSIONPERTAINING TO TBTL OPERATIONS

DATESURVEYED

LOCATIONOPERATION

INPROGRESS

CONCENTRATION OF ETHANOL

DETECTED(ppm)

PERMISSABLE

LIMIT(ppm)

OBSERVATIONS/COMMENTS

21.08.2009 Tank 20-Tank

Farm Tank wasinactive

Below detectionlimit

1000ppm(OSHA)

Taken at valve locateat the base of the tan

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02.09.2009 Tank 20-Tank


1000ppm1000ppm(OSHA)

Met the OSHArequirement

03.09.2009 Tank 42-Tank


>4000ppm1000ppm(OSHA)

Due to the height ofthe tank (50 ft) off th

ground poses nosignificant health risk

to workers.

03.09.2009 Tank 43-Tank


3000ppm1000ppm(OSHA)

Due to the height othe tank (51.75 ft) ofthe ground poses nosignificant health risk

to workers.

03.09.2009 Tank 70-Tank


200ppm1000ppm(OSHA)

Below the OSHArequirement

03.09.200916"line at

Pump HousePlant Down

Below detectionlimit

1000ppm(OSHA)

Below the OSHArequirement

ETHANOL EMISSION TESTS CARRIED OUT ON AN OPEN SAMPLE

26.08.2009Shift TankArea (opensample)

Plant Down 500ppm1000ppm(OSHA)

Line between T9521 & T9522

26.08.2009 Shift Tank Plant Down 200ppm1000ppm(OSHA) T9521

G

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The above graph illustrates the test that was carried out on an open

sample on the plant. In particular, it was taken on an open line

between T9521 and T9522 Shift tanks. This was done to confirm the

ability of the Drager Tubes to effectively detect and measure ethanol

fumes.

G

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The above graph illustrates the result for Tank 20 (base valve), and as

can be seen it is well within the OSHA specification, and therefore

poses no significant health and safety as well as environmental risk.

p

m )

The above graph of the ethanol tests atop Tank 20 indicates that the

result is 1000ppm, which is the specification set by OSHA. It poses a

health and safety as well as environmental risk; however, it does not

exceed the limit.

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(p

p m )

The above graph indicates the ethanol emission results for Tank 43

(top). It can be seen that the results exceed that of the OSHA

specification, however, due to its location (Tank Farm- refer to analysis

of results) the ethanol emissions would not greatly affect humans or

the environment.

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G

(p

p m )

The above graph indicates that the ethanol emissions detected at Tank

70 (Top) are within the OSHA specified limit and as such does not pose

a significant heath and safety as well as environmental risk.

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From Table 1.0, it can be seen that there are some instances where

the concentration of the ethanol detected is above that stipulated by

occupational standards. It is important, however, to note the sampleareas in which these readings were detected.

It was detected in Tank Farm, atop Tanks 42 and 43. These tanks are

located in an area of a considerable distance away from residential

zones and therefore poses minimal or no threat to humans.

They are approximately 50 feet (Tank 42) and 51.75 feet (Tank 43)

from the ground. Taking into consideration also at this height, there

are mild to strong gusts of wind, which would ensure that there is no

local build up of the ethanol fumes. As a result, they pose no threat to

human health since the chances of such an exposure is minimal due to

the mere location and conditions of the Tanks.

CONCLUSION

The purpose of the ethanol emission tests being conducted at T.B.T.L

is to detect any leaks in its plant and supporting infrastructure, as well

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as to ensure that the ethanol emissions do not pose any considerable

health effects to humans. Furthermore, this would also contribute to

the continuous air-monitoring program at T.B.T.L and ensure that there

are no safety hazards posed by the fumes.

The results from the first ethanol emission trials indicate that there are

considerable emissions detected on the tanks located on Tank Farm-

Tanks 42 & 43. However, these would not affect humans due to its

location (that is height off the ground) and the conditions at

those heights (winds).

The tests conducted on the plant (Shift Tanks), Pump House and Tanks

70 & 20 all were well within the OSHA permissible limits of 1000ppm.

It is therefore a reasonable conclusion that T.B.T.L’s activities do not

pose a significant environmental or health and safety threat to its

workers as well as surrounding residents.

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Modified Ethanol Emission Report