ELORA ARANABORGER REFINERY ENVIRONMENTAL INTERN – SUMMER 2014

A LITTLE BIT ABOUT ME…• Hometown: Houston, Texas

• Texas A&M University College of Geosciences

Environmental Studies major

Economics and Geography Double Minor

• Graduating December 2015

• Interests & Hobbies :• Traveling

• Sports (especially all things Aggie related)

• Dancing

• Philanthropy work

• Reading

• Binge watching shows on Netflix and Hulu

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PROJECTS OVERVIEW

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• EPA Boiler MACT - Regulatory Overview/Borger Implementation

• LDAR Review – Refinery Pumps

• Benzene Waste Operations NESHAP (BWON) – Review and Verification

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Borger Refinery

NGL

Benzene Stripper

Dixon Creek Waste Water

Treatment Plant

My Office

EPA BOILER MACT - REGULATORY OVERVIEW

• Federal Regulation• Affects Boilers and Furnaces

in Refinery• Compliance date of Jan. 2016

• Work Practice Standards• Tune-ups

• Energy Assessment

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• Key Personnel Involved• Quarshie Awuah-Okyere, Environmental

Director• Scott Hartman, Environmental Engineer• Alvin Ferguson, Infrared Engineer

• Goals• Identify sources and

affected units covered by requirements

• Determine initial tune-up schedule

• Analyze energy assessment and work practice standards listed in regulation

• Submit final report to EPA

UNDERSTANDING THE REGULATION

• MACT: Maximum Achievable Control Technology

• Affected Sources: Boiler and Furnaces

• Energy use systems: Steam, hot water, electricity

• Tune Up: Optimizes performance of equipment

• Reducing toxic air pollution

• Improving refinery energy efficiency

• Creates and defines work practice standards for affected sources

• Tune-ups

• Energy Assessment

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METHODOLOGY• Evaluated requirements of

regulation and exemptions

• Reviewed all refinery furnaces and boilers• Construction date, fuel source,

firing rate and use

• Determined • Exemptions

• Tune-Up Schedule

• Refinery Energy Usage

• Energy Assessor Qualifications

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REFINERY FURNACES/BOILERS

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PATH FORWARD & FINAL REPORT

• Assessment conducted Spring 2013

• Refinery will most likely meet rule requirements

• Submit findings to EPA

• Schedule Tune-ups

• Spreadsheet for Scheduling and Tracking Tune-Ups

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CHALLENGES & BENEFITS

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• Benefits• Staying ahead of

compliance

• Budgeting advantage

• Optimization of equipment

• Refinery energy systems will run more efficiently

• Challenges• Obtaining date of

construction data

• Understanding vague regulation/interpretation

• Comparing completed energy assessment to regulation requirements

REFINERY PUMPS LDAR REVIEW

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• Goals• Review Pump Leak History

• Identify Repeat Leakers and Pumps on DOR

• Review Pump Type and Pump Service

• Recommend Upgrades

• Key Personnel Involved• Matt Evans, LDAR Coordinator

• Area Reliability Engineers

• Leak Detection and Repair (LDAR)• Federal, State and

Consent Decree Requirement

• Guidelines for monitoring

• Safety

PUMPS REVIEW - COMMONLY-USED TERMS

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LDAR: Leak Detection and RepairDOR: Delay of Repair

Repeat Leakers

WHY IS LDAR IMPORTANT?

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0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

1988 1991 1994 1997 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

Tons

Consent Decree Petroleum Industry Fugitive Emissions

Pre-Consent Decree Post-Consent Decree

METHODOLOGY

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• Reviewed 300+ repeat leakers• Prioritized list of repeat leakers

and worst DOR pumps• Narrowed down 50 worst LDAR

pumps in the refinery• Analyzed relevant environmental

data• Reviewed with Reliability Team

• Received feedback from Area Design Engineers

TOP 15 LDAR PUMPS

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PATH FORWARD/RECOMMENDATIONS

• Project summary• Mechanical upgrade

recommendations• Service

• Seal Types

• Design Failures

• Cost savings

• Environmental impact

• Compliance savings

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CHALLENGES & BENEFITS

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• Benefits• Improved environmental

compliance and performance

• More reliable equipment and processes

• Money saved

• Challenges• Complex regulation and

monitoring procedures

• Disparities between SAP and LDAR database; environmental vs. reliability standards

• Many driving factors

• Relying on reliability information for recommendation

• Complex cost savings calculations and estimates

BENZENE WASTE OPERATIONS NESHAP (BWON) –WHAT GOOD LOOKS LIKE

• Federal Regulation• Regulate Benzene in refinery

waste

• Required by Consent Decree

• Goals• Highlight and update P&ID’s

correctly identifying all BWON streams

• Identify any potential inefficiencies• Suggest how to improve

system and compliance

• Create P66 WGLL Package

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• Key Personnel Involved• Joel Sutton, BWON Coordinator• Quarshie Awuah-Okyere, Environmental

Director• Matt Evans, LDAR Coordinator• Provenance Consulting

WHY IS BWON IMPORTANT?

• Benzene is carcinogenic

• Public health

• Consent Decree

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METHODOLOGY

• Benzene-affected equipment list

• Pull diagrams

• Highlight lines from equipment to wastewater treatment and flare

• Follow the lines through several P&ID’s to end-of-line

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COMPARE P&ID’S TO SCHEMATIC

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CHALLENGES & BENEFITS

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• Benefits• Identify discrepancies and

modify current schematic drawings

• Identify inefficiencies within system

• Troubleshooting during times of non-compliance

• Ensure proper inspections and compliance

• Challenges• Understanding the P&ID’s

• Understanding the BWON system schematics

• Understanding the regulation

SUMMER OF 66BENEFITS

How did P66 benefit from my internship? • Created a preliminary list of the worst

LDAR pumps

• Defined equipment that is subject to new EPA regulations on energy sources within the refinery

• Will help begin a “What Good Looks Like” diagram of our BWON wastewater system

How did I benefit from this internship?

• Technical skills

• Presentation preparation and delivery

• Learning about downstream

• Learning how to work and complete projects

• Real work is not like college

• Learning through experience

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SUMMER OF 66WHAT I LEARNED FROM PHILLIPS 66

• Company dedicated to safety

• Environmental has a presence and priority

• More than just refining gasoline• Midstream, transportation, commercial, fractionation…

• Historical domestic provider of energy to the US

• Room for growth and development within company, no matter background

• Gives back to the community

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OTHER KEY LEARNING EXPERIENCES

• Corporate Auditing

• TCEQ (State) Auditing

• Environmental Consulting Practices

• Corporate Permit Peer-Review

• Waste Management & Labeling

• FLiR Camera Flare Monitoring

• Brine Pond Bird Monitoring

• Seal Gap Inspections

• Stack Testing Procedures

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Flame

Trailing VOC’s

INTERN ACTIVITIES AND TRAININGS

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ACKNOWLEDGEMENTS & REFLECTION

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QUESTIONS?

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BACK-UP SLIDES

TUNE-UP PROCEDURES

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TOP 50 LDAR PUMPS

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LDAR STATS

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0

500

1000

1500

2000

2500

TotalPumps

LDARPumps

BadActors

Currently onDOR

RepeatLeakers

Total

0

200

400

600

800

1000

1200

1400

Components (valves/pumps) on DOR

2009  2010  2011  2012  2013    2014

WHY IS BWON IMPORTANT?

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Benzene-contaminated water at a former remediation site