1. Rule 1105.1 Particulate Control Environmental Considerations in Today’s Projects

2. Agenda  ConocoPhillips  Los Angeles Refinery  Environmental Regulations  What does an Environmental Department do ?  General Project Considerations  Case Study – Rule 1105.1

3. Who is ConocoPhillips ?  Large Integrated Oil Company  Does business in over 40 countries  Familiar brands – 76, Phillips 66, Conoco  Sustainable Development –Ethical Standards –Environmental Improvements –Community –Energy

4. Los Angeles Refinery  Mid-sized, about 140,000 bbls/day  Worst Crude/Cleanest Products –Mostly cracking heavy material distillation –Distillation –Treating/removing impurities  Start 1918, Runs 24/7  About 660 Employees  One of 6 major refineries in South Coast

5. Environmental Regulations  Clean Air Act  Clean Water Act  RCRA – Waste  Emergency Release Regulations  Toxic Regulations  Multi-Agency Complex Regulations  3 rd -Party Intervention

6. What Does An Environmental Department Do ?  Regulation expertise – air, water, waste  Advocate on new legislation/regulation  Help facility implement new regulations  Obtain environmental permits  Compliance assurance/continuous improvement management system approach  Maintain reporting/recordkeeping  Staff of 7 professionals, 6 air emphasis

7. General Project Considerations  Safety – First Priority  Environmental Considerations –Compliance, permitting, scope  Community Impact  Schedule (Timing with Outages)  Quality – Will it work when done  Cost – differentiate alternatives, cost as budgeted

8. Why Rule 1105.1 Project ?  SCAQMD Regulation –Control solid particle emissions –Control ammonia (precursor)  Impacts the Fluid Catalytic Cracking Unit (FCCu)  Particulate limit, 30 lbs/hour to about 6 lbs/hour  Ammonia, no limit to 10 ppm

9. What does an FCCu look like ?

10. Project History  Rule passed 12/2003  Began meeting vendors and setting design parameters  Determined early need for ‘pre-treatment’ –3 rd /4 th -stage separators  Determined early need for schedule adjustment  Installed 3 rd /4 th stage separators in November  Performing Testing

11. New 3 rd -Stage Separator

12. New Flue Gas Train

13. Technology Choices  Dry Electrostatic precipitators (ESPs)  Wet gas scrubber  Wet gas scrubber/Wet ESP

14. ESP

15. SCRUBBER EEE NaOH / Na 2 CO 3 Effluent Process Water FCCU Off-Gas WESP Section Stack Absorber Section OxidationAir Sump

16. Safety Considerations  All technologies selected can and have operated safely. –Dry ESPs in FCCu service (CO on start-up) –Wet ESPs ? –‘Batch’ mode operational factors  ESPs  Wet Solids handling

17. Community Impact  Steam Plume for wet systems (aesthetics) –Perception vs. Reality –Environmental Justice  Traffic –Construction –Operation  Who is the community ?

18. Schedule  Outages (turnarounds) approximately every 4 years –Tie-ins are possible  Long lead equipment –Steel –Vessels  Competing Orders  Permitting

19. Quality  Dry ESPs have most applications  Wet ESPs have least  Limits are pushing the edge of technology –Lack of vendor guarantees –Test method issues  Transient Conditions (start-ups/upsets)  Sparing Philosophy

20. Costs  Capital Costs –Sparing Philosophy  Operational Costs –Energy –Water/Waste Processing

21. Environmental Considerations  Test method reliability –EPA vs. SCAQMD method  Future regulation uncertainty –PM 2.5 (2007-2014) –Secondary Pollutants (Precursors)  NOx/SOx/NH3 –PM 2.5-10 (New EPA effort, state ?)

22. Environmental Considerations  Selective Catalytic Reduction (SCR) for NOx –Other regulations –Unit Expansion (Best available Control Technology) –Installation  Temperature/energy considerations  SO2 – SO3 conversion (dry vs. wet)  Fouling  Construction (leaving room)

23. Environmental Considerations  SOx controls –Other regulations –FCCu expansion – What is BACT ? –Wet systems have a clear advantage

24. Environmental Considerations  Wastewater treatment - Scrubbers –Purge for solids and chloride control –Removal for solids  Settling/Filter Press (messy Operation)  Allow settling in existing refinery sewer system – Sulfite (oxidation)  Can POTW take it ? (test method)  Adequate aeration in existing system ?

25. Environmental Considerations  Electrical (ESP vs. Scrubber) –Offset by restarting power recover turbine ?  Energy Profile (waste heat recovery)  Permitting Complexity (12-18 months) –California Environmental Quality Act (CEQA) –Agency experience with ESPs

26. Environmental Considerations  3 rd -Party Involvement  FCCu Start-Up/Upset Considerations  Plume Mitigation ?

27. Plume Mitigation

28. WHAT WOULD YOU DO ?