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OAR Box 1784 

Prepped by Ollie Stewart 

Document Number: 

51) ll-B-10 

Docket Number: 

A-84-44 

Printed 10/31/2008 8:05:40 AM Sheet 51 of 143 
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY-*-. Z_i.-L~ 

2*? JAN 1988 

X- , " • — 

MEMORANDUM 

SUBJECT: Trip Report - Plant Visit to Alliance Refinery, B.P. 011 Incorporated 

(a subsidiary of Sohlo), Belle Chasse, Louisiana 

William Larry Elmore, P.E. r 

Standards Documentation Section, ISB, ESED (MD-13) 

FROM 

TO: Kenneth R. Durkee, Chief 

Standards Documentation Section, ISB, ESED (MD-13) 

I. Purpose -.*•• 

The purpose of the visit was to gather Information on refinery 

processes and operations, especially the processes designed to remove and 

recover sulfur from refinery sour gases for a forthcoming new source 

performance standard (NSPS) review. Also, to discuss B.P. 011 Incorporated's 

experience with the refinery fuel gas NSPS. 

II. Place and Date 

Alliance Refinery ''^ 

B.P. 011 Incorporated 

Belle Chasse, Louisiana 

October 23, 1985 

III. Attendees 

Inc. 

W l l 1am Larry Elmore, Environmental Engineer, EPA 

Phillip L. Dzlublnskl, Senior Process Specialist, B.P. 011 

Randall 5. Rhodes, Chemical Engineer, B.P. 011 Inc.r 

Michael J. Ruscak, Senior-Process Engineer, B.P. 011 Inc. 

Humbert© Valnltii, Director-Process Engineering, B.P. 011 Ine. 

• •',. •>•»"•..-...• .JK ' °e-

• iN-1 —JL:.. . uottt*' fleaIV. Discussion "-• v >,;;n. 

Background 

The Alliance Refinery became operational 1n 1971 and Is one of 

the last grass-roots refineries to be constructed 1n the United States. 

Orlylndlly, this refinery had a cfcu^e^fl^ty of 160,000 barrols/day but 

T** ^ 

SYMBOL 

SURNAME 

DATE 

M0D^. 

'J20-1 

EPA Form 1320-1 (12-70) OFFICIAL FILE COPY 

0=0 : 1983 0 - 403-201 
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has been upyraded and expanded to 205,000 barrels/day. This refinery was 

originally designed for sweet Louisiana crude that has an average sulfur 

concentration of 0.3 percent by weight. However, this refinery does 

. refine a limited amount of Alaskan North Slope crude (20,000-25,000 

barrels/day) that has an average sulfur concentration of 1.03 percent by 

•,.. . ••"' V.-.-, weight. -v'/V^'-v v.^-'.-'v. .. ^i" .V .k''i-.i"-u • •*..••;.- •• "' ...-':•.'. 

•''"•£"--*:•'" i'- Amine treatment -y'~ ..,/^M:,,- • ,.. ^... ..._^ _^.A-.-.-^ - - _

;_;"';-

The amine treatment unit and the Claus sulfur recovery unit was 

constructed along with the refinery and became operational in 1971. 

Thus, this emission control system was constructed prior to being required 

by the NSPS. Company personnel cited the following reasons for Installing 

the amine treatment system even though 1t was not required: to prevent 

corrosion of process equipment, health and safety of, refinery personnel, 

.-'--'^•>'-•" and to provide environmental protection.. ?;' \ * > •*. 

*"."'""":: The original amine treatment unit was designed and constructed by Brown 

& Root. This unit consists of three (3) amine contactors and one (1) 

strlpper/amlne regenerator. One of the amine contactors is used to treat 

refinery fuel gas. The other two (2) amine contactors are used to remove 

H2S from the Alkylatlon Unit feed and Gulflner off-gas. These last two 

amine contactors are used for refinery processing rather than refinery 

fuel gas treatment but, their operation Increases the H2S loading of the 

..,_ amine stripper/regenerator, Claus Sulfur Recovery Unit and the Tall Gas 

Treatment Unit. 

In 1978 the capacity of the Fluid Catalytic Cracking Unit was increased 

from 78,000 barrels per day to 89,000 barrels per day. This increase 

triggered a PSD review and permit application and the project was subject 

to NSPS. Compliance with respect to SOg emissions was achieved by limiting 

the H2S content in the refinery fuel gas to 160 ppm, the installation of a 

continuous H2S analyzer on the refinery fuel gas, and the installation of 

a parallel fuel gas amine contactor to act as a spare treater. Thus, the 

.. refinery fuel gas system has two amine contactor vessels, one of which 1s a 

spare unit that can be placed into service during emergencies. Both of the 

amine contactors are capable of handling the total sour gas flow on an 

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:

-

:^x<:-:, '-y^^' y -v;-,'*;*- *•• -\^: 

-".':"/"";>. /'.'.•'<• ' [B.P. 011, incorporated has requested that information Contained in this 

^i. '•'.. "paragraph be classified as confidential.] ': 

'- ** ~ 

,. w fy?" .-Tr— 
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-,;'. Refinery personnel Indicated the most important operating parameters, 

that are used to adjust to varying conditions and to maintain the proper \: 

H2S concentration in the fuel gas are:' adjustment of amine solution 

circulation (Increase circulation rate as H2S load Increases) plus adjust 

the steam rate to the stripper/regenerator vessel 1f regeneration Is 

incomplete (increase steam as H2S concentration increases). Increasing 

the amine solution concentration is used to mitigate any long-term effects 

such as a sustained increase of H2S loading (ex: refining a large amount 

of sour crude). 

[B.P. Oil, Incorporated has requested that information contained in 

this paragraph be classified as confidential. 3 •?***."'-$..--*• : - •••<"*•* - ~-^* 

[B.P. Oil, Incorporated has requested that Information contained in 

this paragraph be classified as confidential.] 

H?S Monitoring and Emission Testing 

The amine system operators record readings of the. amine, system equipment 

operating parameters: pressure, temperature, and flow. This includes the 

process operators who monitor the system from the refinery yard and the 

operators that monitor the controls for the amine treatment unit which * 

are in the fefinery't central '«o^riil..,.rooiii«;.^j...:.; .^-.. ; :^ 

,,-S. ;-. 

The Alliance Refinery utilizes manual samples of the amine solution to 

determine amine strength and ad d gas loading. Laboratory analyses are 

conducted on the lean DEA solution on a dally basis to determine amine 

strength and on a weekly basis to determine ad d gas loadings. 
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•>•> :; . , 

i . 

The Alliance Refinery utilizes a continuous HgS monitor (Beckman 

Model 6750 Process Chromatograph) to demonstrate compliance with the H2S 

standard. The HgS concentration is monitored at a location after the " 

treated refinery fuel gas is blended with natural gas and other refinery -

sweet gas streams,-The HgS cont1nu6us monitoring device readings are -

Krecorded as 3-hour rolling averages 24 hours per day. : No routine manual 

'•*•: sampling of the HgS concentration 1n the fuel gas 1* performed because-the 

laboratory at the refinery Is hot capable of testing low levels of H2S. 

. Thus, the refinery has not conducted any test comparing the continuous 

monitoring device to manual sampling emission tests. A diagnostic check 

that takes approximately one-half-hour per day, is performed five (5) 

times a week. The company reports that the continuous H2S monitoring 

device has provided reliable service and there has not been any persistent 

or recurring problems with the device. The H2S continuous monitor 1s not 

Integrated Into the process as a control system; its.function Is strictly 

a

: process monitor. Company personnel reported that 6 compliance test has. 

3 never been conducted on the amine treater. ',, ,' 

Company personnel pointed out that 1t was extremely Important to 

jaonltor the H2S concentration directly Instead of relying on the operating 

parameters of the amine treater to Indicate H2S concentration. They 

Indicated that It Is possible that flows and pressures within the amine 

treater be within operational guidelines but that the refinery fuel gas 

have a HgS concentration exceeding the NSPS. In other words, the company's 

experience 1s that process parameters do not relate well with H?S 

concentrations. Several causes of this type of occurrence were cited: 

diluted amine solution, incompletely regenerated amine solution, or a 

sulfur overload. Company personnel believe that the HgS continuous 

••_ . monitoring device has allowed them to identify amine system malfunctions 

or inappropriate process conditions that need adjustment in order to 

bring the refinery fuel gas H2S concentration Into compliance in a faster 

manner. 

Combustion Sources and Energy Demand 

[B.P. Oil, Incorporated has requested that information contained 1n 

. this paragraph be classified as confidential^ . . . 4; 
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1 

t 

I . 

! . 

During the late 70's, the refinery was Informed that It was possible 

that the natural gas supply (used for make-up gas) could be cut off. In 

order to prevent this type of action from having an adverse impact on 

refinery operations, the refinery equipped all of Its combustion sources 

such that either gas or fuel oil could be burned. However, the refinery 

lias never burned fuel oil, -«.. ""?'-•.£-•'/•' ".".;, 

COMMENTS OR PROBLEMS WITH THE NSPS > :. -

Company personnel reported no significant difficulties in Interpreting 

the NSPS, achieving the NSPS, and operating the control system to comply with 

the NSPS. '-.... . 

COST DATA . ..":. . .....-,• •.,:'• ••:.,•',,.'..... 

«,' Cost Information which was submitted In response to a 114 questionnaire 

was reviewed. Since the cost information Is current, May 1985, company 

personnel felt that the information was accurate. 

SUMMARY 

The plant visit was very Informative and refinery personnel were quite 

helpful In discussing general plant operation and specifically the amine 

treatment system. 

* ESED/ISB/SDS/WLElmore/chbaker 10/31/85 x5596 Rm.755 MU (MD-13) . -

File No.AIP 8-1-15-2 Project No. 83/03 retyped 11/12/85 chb 

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