EMPLOYEE PARTICIPATION KEY TO MEETING ENVIRONMENTAL GOALS

Anne K. Rhodes
Refining/Petrochemical Editor

Environmental compliance in the refining industry during the 1990s will require a much different approach than in past decades, when technology application was the key.

Today's challenges require every employee to participate in developing solutions, and to be committed to meeting compliance goals.

This is the stance taken by ARCO Products Co. at its 250,000 b/d Los Angeles refinery (Fig. 1). The company claims the philosophy leads to collective, grassroots innovation, pollution prevention, and policies and procedures that meet multiple environmental goals.

Refinery environmental, health, and safety manager Leigh Noda says the Carson, Calif., refinery near Los Angeles has found simple, "low-tech" solutions to individually small problems. Collectively, however, the implementation of these ideas has improved the refinery's environmental performance, and at low cost.

The key to making this happen, says ARCO, is employee involvement, which is highest on the refinery's list of environmental management objectives.

COMPLIANCE

Dirt on a refinery road may seem to be nothing more than a nuisance. But in the refinery sewer system, it becomes a hazardous waste. Driving around ARCO's Carson refinery are street sweepers that pick up dirt before it can enter the sewer system.

This is just one of the ways this refinery contends with the strict regulations outlined in the article beginning on p. 64.

ARCO believes it takes the participation of every operator, craftsman, supervisor, and engineer in the plant to achieve and maintain regulatory compliance. The key elements of ARCO's environmental program are:

Involvement-Plant personnel are involved in finding ways to reduce waste and improve environmental performance.
Training-Environmental requirements and procedures are integrated into the training and procedures that employees receive. Employees should understand that environmental requirements must be met like any other job requirement.
Incentive goals and recognition-The commitment of operators and craftsmen to environmental compliance is rewarded.
Audits-Weekly supervisory and quarterly environmental, health, and safety audits of performance ensure compliance efforts remain on track. Biennial company audits also are conducted.
Environmental incident investigation-An investigation team, led by the first-level supervisor of the affected area, determines the causes and corrective actions when environmental incidents occur. The results of the investigation are communicated throughout the plant to prevent a recurrence of the incident, or the occurrence of a similar incident.
Performance evaluations-Environmental performance is a part of each employee's performance appraisal.
Documented procedures-The plant personnel responsible for compliance have written an environmental procedures manual and pocket handbook.

ACHIEVEMENTS

ARCO's program shows that, when refinery personnel are given the necessary tools and information, they make environmental awareness part of their daily jobs. One example of how this works is the elimination of violations resulting from open-ended refinery pipes.

Refinery management made the operators aware of the violations that had been received for missing bull plugs in lines. ARCO established an incentive goal to encourage work aimed at addressing the problem. As a result, a number of ideas for reducing these violations were submitted.

The catalytic reformer team, for example, developed a procedure whereby they painted all bull plugs with a bright color, making them more visible. The operators also devised an inspection checklist that is used to check the plugs daily.

This combination earned the team recognition in an in-house publication and an award. As the result of the refinery's incentives pro,-ram and the participation of the operators, this type of leak has been eliminated.

In another example, the increased awareness and efforts of plant personnel reduced benzene discharge concentrations after start-up of the refinery's system for compliance with National Emissions Standards for Hazardous Air Pollutants for benzene.

Fig. 2 shows the refinery's benzene Neshap collection system. Streams including water draw from the tank farms, desalter wash water, and ground water are collected. The streams are hard-piped to a steam stripper, which removes the benzene.

Closed-loop benzene sample points were installed to enable the samplers to prevent hydrocarbons and benzene from being drained to the sewer system during sampling. When used properly, this system eliminates the need to purge the lines to the sewer.

The success of this equipment is dependent on the operators' recognition of the importance of keeping the benzene streams out of the sewer system, according to Noda.

As proof of the operators' increased awareness and the proper use of the equipment, plant personnel have reduced benzene emissions to 0.2-0.3 ppm from 2-4 ppm, sax-in- the refinery an estimated $300,000/year in fees.

SEPARATOR SOLIDS

A multidisciplinary group studied the major sources of the dirt that washes into the refinery sewer system and becomes separator solids. About 50% of the dirt was found to come from the Alaska North Slope crude oil that the refinery processes; about 25% was native soil; and the remaining 25% was precipitated hardness (CaCO3).

With this information, plant personnel were asked to identify ways to reduce the generated solids. Each idea was evaluated based on economics, including the costs of labor, chemicals, treatment, transportation, and disposal. As a result, says Noda, several source-reduction procedures have been implemented:

The refinery streets are swept every day, rather than twice per week, to prevent dirt from entering the sewer system.
The sewer drains from tank-farm containment berms were redesigned to reduce dirt entrainment into the system. To reduce entrainment further, the refinery is in the process of segregating its sewer systems.
Parking areas were paved to reduce the amount of dirt washing into the sewers during rain storms. Additional areas are being paved, where possible.
Fluid catalytic cracking (FCC) catalyst fines are dumped through a closed tube into completely closed containers. The former system was to dump the material into open-top bins, which were then dumped and vacuumed, allowing catalyst to blow around and settle on the ground. As a welcome side-effect of the new procedure, the performance of the refinery's electrostatic precipitator has improved because the catalyst is no longer "bridging."
The catalytic polymerization reactors are dry-drilled. The old system involved drilling out the tubes into a catch basin using water. The water was then weired to the sewer system. The refinery is evaluating the possibility of recycling the material for use as fertilizer (H3PO4) at a potential savings of $1 million/year.

Noda says refinery personnel have identified many similar point-source reductions which have been implemented.

AIR EMISSIONS

The refinery is controlling air emissions by implementing the same sort of innovations.

For example, Southern California has unique requirements for emptying storage tanks. The rules allow, for materials with an Rvp of less than 2.6 psi, the removal of liquid and cryogenic processing of vapors. This procedure costs about $50,000 and requires 1-2 weeks.

As a result of ideas submitted by operators, ARCO pumps 7 ft of water into the tank, skims off the top layer, and reprocesses the material, at a cost of only $1,000. The water is then sent to the refinery sewer system.

Before a tank is returned to service, the roof is refloated using low-benzene, low-vapor-pressure fluids like alkylate, for example. This prevents air emissions and prohibits benzene from dissolving in the water and being released to the atmosphere.

Like the other innovations discussed, these procedures resulted from suggestions made by plant personnel.

ARCO also restricts emissions from tanks and other containers by:

Using covers on all waste water separators to reduce emissions. The collected gases are vented through carbon canisters to capture an), hazardous air pollutants.
Replacing high-vapor-pressure materials in the tanks with low-vapor-pressure materials before the tanks are opened.

TECHNOLOGY INNOVATIONS

Technological innovations implemented at the refinery include:

The installation of low-NOx burners on almost all refinery heaters to reduce the formation of NOx. The use of this technology has reduced the need for selective catalytic reduction of NOx.
The diversion of gases that normally would be flared to the refinery's cogeneration facility to eliminate nonemergency flaring and convert the gases to steam and electricity. The cogen plant produces all of the refinery's steam and enough electricity to power 400,000 homes.
The recovery, dewatering, and drying of solids from the API separators to reduce the volume of solids requiring recycling. A centrifuge is used to reduce the water content to 60%, and a steam dryer further reduces the water content to 3%. The recovered oil is reprocessed and the solids are sent to a cement kiln at a cost of about $600/ton.

Other control measures include:

Installing buffer as seals on reciprocating compressors.
Retrofiting pumps with tandem seals.
Replacing some packed valves with bellows seals.
Preventing dust from sandblasting operations from hitting the ground by catching it on plastic sheeting. (Because the dust may be considered hazardous by the State of California, the refinery makes sure it is collected and properly disposed of.)
Controlling coke dust by storing refinery coke in a barn. (Coke stored outside is kept wet to control dust.)

OTHER PROCEDURES

ARCO is eliminating sources of groundwater contamination by relocating a number of underground pipelines aboveground. And existing storage tanks are being retrofitted with double bottoms. Of the refinery's 120 tanks, 80 have been fitted with the new bottoms.

Work on both of these projects is continuing, says Noda.

Among the refinery's recycling procedures is the reuse of some process waters as desalter wash water. And boiler blowdown is reused as service water for washing down units.

Another recycling process is the use of nonhazardous refinery soils in asphalt for paving refinery roads.

WASTE SEGREGATION

California has a number of unique waste disposal regulations that are much stricter than federal standards. To reduce the disposal costs resulting from these rules, the refinery has instituted an elaborate system of waste segregation and disposal.

By separating wastes upstream, nonhazardous materials do not become contaminated with hazardous materials. The amount of hazardous waste requiring disposal, therefore, is decreased, as are disposal costs.

At the Carson refinery, employees work hard to segregate trash as it is deposited. Wastes are separated, at the point of generation, according, to type:

Hazardous waste, such as oily rags, paint sludge, grease, catalysts, and asbestos.
Nonhazardous waste, such as common trash, dirt, and catalyst support balls.
Recyclables, such as plastic sample bottles, cans, wood, glass, plastics, and metals.

These wastes are collected in color-coded satellite containers (55-gal drums). Each day, these drums are emptied into larger waste containers, also color-coded to denote the type of waste involved.

When the drums are emptied, they are inspected by hand and resorted, if necessary. And before the nonhazardous wastes are transported for disposal, they are checked once again to make sure they contain no hazardous materials. ARCO has proven that, with a little innovative thinking and the involvement of affected personnel, simple measures can have a big impact. The inclusion of all employees in the refinery's environmental program boosts morale, engenders pride, an saves money.