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Table 1.3

Comparison of Different Environmental Management Options for the Yorktown Refinery

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Selection Criteria for Release Reduction Projects 1. Current and Expected Regulatory Requirements

(Table 4.5) (Note 3)

2. Cost-Effective Release Reduction (Table 4.6)

3. Cost-Effective Benzene Exposure Reduction (Table 4.7).
4. Multiple Criteria (Table 4.47 (Note 4)
4a.
Work Group

(Top 4)
4b. Amoco

(Top 4) 40. EPA/Virginia

(Top 4)
5. Most Favored--All Rankings, All Evaluators (Table 4.8)

Notes:
1. VOC • Volatile Organic Compounds

HC * Liquid Hydrocarbons

Listed NW = Solid, Mazardous Waste 2. Values are rounded. See tables 4.1 through 4.7 for

details.

3.

Regulatory and Statutory Programs considered include Benzene NESHAP, Ozone non-attainment, likely Clean Air Act requirements under MACT and HON rules. Multiple criteria included release reduction potential, benzene exposure reduction potential, cost, impact on liability, transferability to other facilities, status in pollution prevention hierarchy, etc. See Section 4.0 for discussion.

-25Table 3.2

Selected Pollution Prevention Engineering Projects The following projects were identified for further study as a result of the Pollution Prevention Workshop in Williamsburg and subsequent Workshop meetings.

1. Reroute Desalter Effluent: Hot desalter effluent water

currently flows into the process water drainage system at Combination unit. This project would install a new line and route this stream directly to the API Separator. This reduces volatile losses from the sewer system by reducing process sewer temperature and oil content. Volatile losses at the API Separator increase slightly.

2. Improve Desalter System: Evaluate installation of adjunct

technology (e.g., centrifuge, air flotation, or other technology) on desalter water stream prior to discharge into the underground process drainage system. This reduces oil and solids waste loads in the sewer system, affecting the waste water treatment plant and volatile losses from the drainage system.

3. Reduce FCU Catalyst Fines: Evaluate possible performance of

more attrition resistant FCU catalyst to reduce fines production. (Subsequent review with catalyst vendors indicated the Refinery was already using the most attrition resistant catalyst available.) Two other fines reduction options were considered.

3a.

Replace FCU Cyclones: Assess potential for reducing
emissions of catalyst fines (PM10) by adding new cyclones in
the regenerator.

3b.

Install Electrostatic Precipitator at FCU: Assess potential
of electrostatic precipitator in reducing catalyst fines
(PM10) emissions.

4. Eliminate coker Blowdown Pond: Change operating procedures

for coke drum quench and cooldown so that an open pond is no longer needed. This reduces volatile losses from the hot blowdown water.

5. Install Seals on Storage Tanks: Double seals or secondary

seals will reduce fugitive vapor losses. Recovery efficiency varies from tank to tank, depending on the hydrocarbon stored and construction details. Table 3.3 provides additional information.

5a.

Secondary Seals on Gasoline Tanks: Secondary rim mounted seals on tanks containing gasoline.

5b.

Secondary Seals on Gasoline and Distillate Tanks: Secondary rim mounted seals on tanks containing gasoline and distillate material.

50.

Secondary Seals on ALL Floating Roof Tanks:
mounted seals on all floating roof tanks.

Secondary rim

5d.

Option 5c + Internal Floaters on Fixed Roof Tanks: Secondary rim mounted seals on floating roof tanks and the installation of a floating roof with a primary seal on all fixed roof tanks.

5e.

Option 5d + Secondary Seals on Fixed Roof Tanks: Secondary rim mounted seal on all floating roof tanks and the installation of a floating roof with a primary and secondary seal on all fixed roof tanks.

6. Keep Soils out of Sewers: Use road sweeper to remove dirt

from roadways and concrete areas which would otherwise blow or be washed into the drainage system. Develop and install new sewer boxes designed to reduce soil movement into sewer system, particularly from Tankfarm area. Estimate cost for installation on a Refinery wide basis. Both items reduce soil infiltration, in turn reducing hazardous solid waste generation.

7. The Benzene Waste Operations NESHAP requires control of

benzene emissions from refinery wastewater sources. Three separate projects (7A, 7B, and 7C) were identified to meet these requirements. Specific design and construction features of these projects will aid with meeting anticipated requirements of some future regulations, such as storm water permitting, RCRA corrective action, the Primary Sludge rule and land disposal restrictions.

7A. Drainage System Upgrade: Install above-grade, pressurized

sewers, segregating storm water and process water systems.

7B.

Upgrade Process Water Treatment Plant: Replace the API
Separator with a covered gravity separator and air
floatation system. Capture hydrocarbon vapors from both
units.

Convert Blowdown Stacks: Replace existing atmospheric blowdown stacks with flares. This reduces untreated hydrocarbon losses to the atmosphere, but creates criteria pollutants.

70.

8. Change Sampling Systems: Install flow-through sampling

stations (speed loops) where required on a refinery-wide basis. These replace existing sampling stations and would reduce oil load in the sewer or drained to the deck.

9. Reduce Barge Loading Emissions: Estimate cost to install a

marine vapor loss control system. Consider both vapor recovery and destruction in a flare.

10.

Sour Water System Improvements: Sour water is the most
likely source of Refinery odor problems. Followup on
projects previously identified by Linnhoff-March engineering
to reduce sour water production, improve sour water
stripping.

11.

Institute LDAR Program: Institute a leak detection and repair program for fugitive emissions from process equipment (valves, flanges, pump seals, etc.) and consider costs and benefits.

11a

Annual LDAR Program with a 10,000 PPM hydrocarbon leak level

11b. Quarterly LDAR Program with a 10,000 PPM hydrocarbon leak

level

11c. Quarterly LDAR Program with a 500 PPM hydrocarbon leak level

J

Figure 2.2 Pollution Prevention Sampling Program

(Number of Samples)

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